(In open court)
THE COURT: I think we're good to proceed.
MS. GERAGOS: Wonderful.
BY MS. GERAGOS:
MS. GERAGOS: After this trip, you go to Turks and Caicos in the Bahamas with Mr. Combs, right?
MS. GERAGOS: And I think you said you fell even deeper into your feelings on that trip, right?
MS. GERAGOS: Would you -- you said it was a lust-filled and passionate trip, right?
MS. GERAGOS: You've talked a lot about Mr. Combs speaking about his fantasies and foreplay during hotel nights. Did he speak about those things when you guys were making love or having sex on the Turks and Bahamas trips?
JANE: I would say that watching pornography started then pretty heavily; that we would -- during our lovemaking, he would have the pornography playing, and he would say little things at the time.
MS. GERAGOS: What were those little things that he would say even back then?
MS. GERAGOS: And would you -- would he play pornography every time that you were making love on that trip?
MS. GERAGOS: It was a mix, but it started, you would say, on that trip?
MS. GERAGOS: And that was February of 2021?
MS. GERAGOS: At the end that of trip, I think you said that he gave you money but you didn't have to ask for it, right?
MS. GERAGOS: And he sent you a wire of, I think, approximately $10,000?
MS. GERAGOS: And you were really grateful, right?
MS. GERAGOS: You thought that was really nice?
MS. GERAGOS: Because you had childcare and other things you had to take care of, right?
MS. GERAGOS: And so you accepted it when he gave it to you?
MS. GERAGOS: All right. You also talked about a time that you had -- you took a large ecstasy pill on that trip, right?
MS. GERAGOS: And once you -- when you took that, you said you had a pretty bad reaction, right?
MS. GERAGOS: And then KK helped you after that, right?
MS. GERAGOS: What did she do to help you with that bad reaction?
JANE: She turned on the shower, and she got me in the shower, and everybody was just kind of around and making sure that I was okay.
MS. GERAGOS: Okay.
MS. GERAGOS: And even after you felt better from that bad reaction, how long until you took the next ecstasy?
MS. GERAGOS: And then you took that on your own, right? He provided it to you, right?
MS. GERAGOS: And you took it, right?
MS. GERAGOS: Could we look at -- this is not admitted, but Government Exhibit E-161 and E-162? We can put them side by side up on the screen. Those aren't in your binder.
MS. GERAGOS: Have you looked at -- before we started, this is E-161. Have you looked at this video before?
MS. GERAGOS: We would with Ms. Comey's consent, we move to admit Government Exhibit E-161?
MS. COMEY: No objection if it's under seal, your Honor.
MS. GERAGOS: Under seal.
THE COURT: All right, government Exhibit E-161 will be admitted under seal.
(Government's Exhibit E-161 (sealed) received in evidence)
MS. GERAGOS: Could we play that for the jury and the parties.
(Videotape played)
MS. GERAGOS: Did you take that video?
MS. GERAGOS: Is that in Turks or the Bahamas?
MS. GERAGOS: And that's the villa that you guys were staying in?
MS. GERAGOS: And I noticed in that video, you had light-colored nails, right?
MS. GERAGOS: That's something that you had even before the hotel night started, right?
MS. GERAGOS: And that was the villa they had people there giving you green juices, right?
MS. GERAGOS: It was a really nice villa, right?
MS. GERAGOS: Can we go to E-162, which, with the government's consent, I believe we could admit under seal?
MS. COMEY: No objection.
THE COURT: E-162 will be admitted under seal.
(Government's Exhibit E-162 (sealed) received in evidence)
(Videotape played)
MS. GERAGOS: Where is this?
MS. GERAGOS: Is that you sitting with Mr. Combs?
MS. GERAGOS: And that's the next villa that you stayed at?
MS. GERAGOS: If we could go for the witness and the parties only to E-165.
MS. GERAGOS: Did you take this video?
MS. GERAGOS: With the government's consent, I believe we'd like to admit E-165.
MS. COMEY: No objection.
MS. GERAGOS: And I don't think this needs to be under seal.
MS. COMEY: I agree, your Honor.
THE COURT: 165 will be admitted.
(Government's Exhibit E-165 received in evidence)
MS. GERAGOS: Let's play.
(Videotape played)
MS. GERAGOS: So is this Turks or Bahamas?
MS. GERAGOS: And this is one of the videos that you say you'd like to take of Mr. Combs when you were together?
MS. GERAGOS: And you're really enjoying your time on the beach there, right?
MS. GERAGOS: Okay. And then at the end of this trip, I think you testified that — or maybe you didn't — that he gave you bags and shoes and a bracelet and money. Do you remember that?
JANE: I believe it was before this trip, kind of I think around the first time that we went to dinner, that Miami, that five-day Miami trip, there was shoes, bags and a bracelet.
MS. GERAGOS: What was the bracelet?
MS. GERAGOS: And did you pick that out?
MS. GERAGOS: So then he got you that bracelet?
MS. GERAGOS: Then how many shoes did you get?
MS. GERAGOS: What was the bag?
MS. GERAGOS: And you were happy with those gifts, right?
MS. GERAGOS: And at this time when you guys were in Turks and the Bahamas and even before, he had told you that he was seeing many women, right?
MS. GERAGOS: Is that something he was upfront with you about from the beginning?
MS. GERAGOS: What did he tell you about seeing many women?
MS. GERAGOS: And what term did he use to describe his dating life?
MS. GERAGOS: And you were okay with that?
MS. GERAGOS: You didn't exactly love that he had multiple other girlfriends, right?
JANE: At first it wasn't something that I minded. It was -- I was just getting to know him too; but then later on it, you know, as emotions grew deeper and feelings get deeper, then, of course.
MS. GERAGOS: Yeah, because you were -- he was -- you considered him your partner and your lover, right?
MS. GERAGOS: And as you got some more and more in love with him, it was harder that he had a lot of other girlfriends, right?
JANE: What was hard for me was the imbalance in treatment. When I walked into this relationship, I thought that, you know, he was just evenly dating. And then as many more years passed, then, you know, it was definitely difficult when there became a relationship that just publicly very -- looked like a monogamous committed relationship, and that I didn't sign up for.
MS. GERAGOS: I'll get to that relation -- I know what you're talking about. I'll get to that in a little bit.
But do you remember right after your Turks and Caicos trip, he had another girl fly in on a trip that he was on?
MS. GERAGOS: That's right.
MS. GERAGOS: That was something that even then, even though you weren't as deep in love with him as maybe later in other years, bothered you, right?
MS. GERAGOS: Even then, because you had just had kind of a wonderful 20 days with him, right?
MS. GERAGOS: And he was, from your perspective, so easily able to shift to another girl?
MS. GERAGOS: And that hurt your feelings?
MS. GERAGOS: Okay. And do you remember calling that woman some insults?
MS. GERAGOS: What kind of names would you call her?
MS. GERAGOS: I understand.
JANE: And I really do love women.
I -- back in the day, I was very colorful with my words. I would say that I called them a hoe or, mmm, I think that was the term I probably used most often.
MS. GERAGOS: Did you ever used like brothel escort, anything like that?
MS. GERAGOS: But because you were pretty jealous, right?
MS. GERAGOS: Because he's your lover?
MS. GERAGOS: Okay. So then you talked about, you know, later on in the relationship he had a public relationship that looked from the outside to be a monogamous one, and that was really hurtful, right?
MS. GERAGOS: That was really hard. So that was with someone named Yung Miami or Caresha, right?
MS. GERAGOS: And he started dating her after you?
MS. GERAGOS: And how long after you?
MS. GERAGOS: Yep. And he was really public in that relationship?
MS. GERAGOS: And your relationship by contrast was very private, right?
MS. GERAGOS: And so he would -- and he would put her on Instagram, right?
MS. GERAGOS: And she would put him on her Instagram, right?
MS. GERAGOS: And that was really hurtful?
MS. GERAGOS: And that was something that you, for lack of a better term, fought over for a long time in your relationship once he started dating her?
JANE: Yeah, it was definitely not something that I signed up for. I didn't sign up to date a man that was in a public relationship.
MS. GERAGOS: And you told him that, right?
MS. GERAGOS: And then he was also sometimes with his ex, Gina, right?
MS. GERAGOS: And that would bother you too, right?
MS. GERAGOS: And someone named Jesse?
MS. GERAGOS: And he -- that was one of the people that you talked about who he took to London and he took to Wyoming, right?
MS. GERAGOS: And that was hurtful, right?
MS. GERAGOS: They got to go on those trips?
MS. GERAGOS: With Caresha or Yung Miami when he put her out in public, he was also kind of showering her with gifts very publicly, right?
MS. GERAGOS: Like you had seen that he had gotten her a Maybach, right?
MS. GERAGOS: And you were really upset about that because you weren't getting the same type of gifts?
MS. GERAGOS: And then you asked for a Van Cleef necklace and bracelet, right?
MS. GERAGOS: And so then he got that for you, right?
MS. GERAGOS: Because you wanted, as you said, it was the imbalance of a relationship, and you wanted something really nice as well?
MS. GERAGOS: So we've talked a little bit about your jealousy. But would you also say that Mr. Combs was very jealous?
MS. GERAGOS: Very possessive?
MS. GERAGOS: Can you explain you talked about Bear yesterday, and that was somebody who gave you $9,000 in about January of 2024, right?
MS. GERAGOS: And you hadn't even met this person, right?
MS. GERAGOS: But you didn't meet -- I guess you didn't meet him in the January 2024 time period when he gave you that $9,000, right?
MS. GERAGOS: So when Mr. Combs found out about this, he was extremely jealous, right?
MS. GERAGOS: And he was kind of going over and over and over again in his mind?
MS. GERAGOS: Because he didn't want his woman to be with another guy, and in his mind you were with another guy?
MS. COMEY: Objection.
MS. GERAGOS: You weren't with Bear, right?
MS. GERAGOS: But in his mind, you thought that he thought that, right?
MS. COMEY: Objection.
THE COURT: That's sustained.
MS. GERAGOS: It's a confusing question.
He was very jealous of the Bear situation, right?
MS. COMEY: Objection.
THE COURT: That's sustained.
MS. GERAGOS: Did you perceive him as being very jealous of Bear when he found out about the $9,000?
MS. GERAGOS: Okay. You spoke when, you know, you saw Mr. Combs get those -- meet the dealer, for lack of a better term, in Miami in November, and then you had took -- started taking the ecstasy in Turks and Caicos in 2021, you knew that Mr. Combs would use a lot of drugs, right?
MS. COMEY: Objection to form.
THE COURT: It's overruled.
JANE: At that point, I didn't really know how much he consumed drugs, but I know that he consumed them. I didn't know like the quantity or anything.
MS. GERAGOS: Okay. You just knew that he consumed them?
MS. GERAGOS: Do you remember telling the government that after just about two to three dates, you already thought that he was sad, depressive, and had shaky hands?
JANE: Yes. It was actually on our second date on our way to Turks when I was on the plane. I was facing him, and I could just see his eyes, and I could just see his hands and his teeth, and I could tell that he wasn't taking very good care of himself, maybe on the surface but not internally.
MS. GERAGOS: What about his eyes made you feel that way?
JANE: I felt that he was developing jaundice. I felt that his gums were gray, probably from drug use. And I felt that his hands were shaky probably from overconsuming alcohol.
MS. GERAGOS: Do you remember speaking to him about wanting him to go to rehab when you initially started dating?
MS. GERAGOS: What did you tell him?
JANE: I told him that we should actually take a trip to Thailand. I know of a rehabilitation center that my friend's parents go to that's really nice, and it's like a 30-day program.
MS. GERAGOS: And what was his reaction, if any, to that?
MS. GERAGOS: And what did you tell him?
MS. GERAGOS: At what point in the relationship? Was this before Turks? Was it after Turks that you told him that?
MS. GERAGOS: So when you said, Look at you --
MS. GERAGOS: Okay.
MS. GERAGOS: Is it fair to say you wanted him to be a lot healthier?
MS. GERAGOS: And you are pretty healthy, right? You work out?
MS. GERAGOS: You eat well?
MS. GERAGOS: You eats your fruits and vegetables?
MS. GERAGOS: And so you wanted him to work out and to eat well, right?
MS. GERAGOS: And you drink tea, is that fair?
MS. GERAGOS: And you wanted him to drink tea instead of coffee perhaps?
MS. GERAGOS: And you wanted him to focus on the good parts of bettering himself, right?
MS. GERAGOS: That's part of why you wanted him to go to rehab as well?
MS. GERAGOS: And so you felt at the beginning that he was a drug addict, right?
JANE: I felt that in the beginning I didn't really know how to label it. I just felt that I encountered somebody that was overdoing the partying.
MS. GERAGOS: And is that because, for example, in Turks, he was taking ecstasy almost every day?
JANE: I would say -- in that time I would say that he was more celebratory, but then as our relationship continued, I noticed a very strong pattern, and I still didn't even really label it as a drug addict. I think now -- now I would say that, but then I just would say that he was a really big party guy.
MS. GERAGOS: Okay. Do you remember saying that your friend dated Frank, the butler?
MS. GERAGOS: And that Frank had indicated if you would recommend a certain health protocol, he would follow it for a few days?
MS. GERAGOS: So you would recommend those protocols to him?
MS. GERAGOS: What kind of protocols would you recommend?
JANE: I would recommend just like things for his digestive system. I would recommend other types of sleep aids so that he would stop consuming the really hard-core sleep aids. I would just try to recommend anything for him that didn't rupture just like his natural well-being.
MS. GERAGOS: And you knew that Mr. Combs was also on antidepressants, right?
JANE: Later on I found that out, yes, maybe close to the end a little bit that they were actually antidepressants.
MS. GERAGOS: Do you remember telling the government that he couldn't stop cold turkey?
MS. GERAGOS: Right. And you wanted to get him off of the Xanax and the antidepressants and the Prozac and all of those prescriptions, right?
JANE: Yes, as you just listed them. I didn't even know a lot of that, but yes, he was in a lot of things, and I just wanted him to get back into his natural form and his like natural state.
THE COURT: Ms. Gergos, when you get to a good spot, why don't we take a break?
MS. GERAGOS: Can I just ask three more questions?
THE COURT: Of course.
MS. GERAGOS: You thought that he couldn't really handle the war in his mind?
MS. GERAGOS: Do you remember saying that he couldn't handle the war in his mind?
MS. GERAGOS: And do you remember even one time during a hotel night, you spoke to him about him wanting to get ketamine therapy?
MS. GERAGOS: And you thought that that may help him with his depression?
JANE: Actually, he was telling me about ketamine therapy and all this research that he found out about it, and he was like telling me about what it was.
MS. GERAGOS: And is that something that you were encouraging also?
MS. GERAGOS: Okay. But he was telling you that he wanted to get ketamine therapy and doing the research on it, right?
MS. GERAGOS: Your Honor, I could stop right here.
THE COURT: We'll take a 15 minute break and come back.
Thank you, members of the jury. All rise.
(Continued on next page)
(Jury not present)
THE COURT: I'm sure Ms. Comey told you this, but you're not able to have any conversations with the government.
(Witness not present)
THE COURT: Ms. Comey, anything to raise before we take our break?
MS. COMEY: No. Thank you, your Honor.
THE COURT: Anything, Ms. Geragos?
MS. GERAGOS: No. Thank you, your Honor.
THE COURT: All right, we'll come back in 15.
(Recess)
MS. GERAGOS: We were just discussing, your Honor, I think we could stop at 3:00 today. I know tomorrow is also a short day, and then it would -- I think it would still give me sufficient time and all of Thursday if I need it. I'm seeing a nod from the front, so...
MS. COMEY: Your Honor, we defer to Ms. Geragos. As long as I have a little bit of time for redirect, very brief redirect on Thursday, and this witness can make her flight, we would love to end early today.
THE COURT: So it's up to you, Ms. Geragos, but do you think you would be able to complete your cross-examination by Thursday because I'm prepared to be here until 5:00. But if you would like to utilize that time for anything else or you think that given what you have, you'll be able to complete it within the time you've indicated, then that's certainly fine.
MS. GERAGOS: Then let's just check again at the lunch break, but I do think I could complete it by Thursday, it seems like that.
THE COURT: Very good. So I have no issues with that.
MS. GERAGOS: Okay. Great.
THE COURT: Let's bring the witness back if we can.
(Witness and jury present)
THE COURT: Ms. Geragos, you may proceed when ready.
MS. GERAGOS: Thank you, your Honor. Jane, resumed CROSS-EXAMINATION CONTINUED
BY MS. GERAGOS:
MS. GERAGOS: Hi again, Jane.
MS. GERAGOS: It's a hard one.
When we just ended, we were talking about how he had wanted to get ketamine therapy. I'll just shift for a second.
I think you said earlier that taking care of Mr. Combs was one of your favorite parts of the relationship, right?
MS. GERAGOS: And you loved that quality time with him, right?
MS. GERAGOS: And so after these hotel nights or times when you would just go over to his house on Mapleton and you could be in his bedroom with him, would you have quality time with him during those times?
MS. GERAGOS: Can you explain what you -- you said you got to watch Dateline, I think it was?
MS. GERAGOS: And that was his favorite show?
MS. GERAGOS: Would you watch other movies?
MS. GERAGOS: And then we also talked about your house before the break, and there were times that he came over to your house where you would have drinks and hang out and do a movie night, right?
JANE: He would come over, and it would usually lead to a majority of the time one of these nights.
MS. GERAGOS: But there were times where it wouldn't be one of these nights, right?
MS. GERAGOS: Do you remember telling the government that there were at least two times where he -- after you moved in, you would have drinks, hang out, and do a movie night?
MS. GERAGOS: Okay. And you also spoke yesterday about a time where he told you he was going to have surgery, and you felt really bad, right?
MS. GERAGOS: And did he have one surgery or more than one surgery throughout your relationship with him?
MS. GERAGOS: And after that surgery, did you go to his home, and when he had downtime, assist him and take care of him and make sure he was comfortable?
MS. GERAGOS: And you assisted him with crutches?
MS. GERAGOS: And you just made sure that he wasn't in pain, and that he was okay, right?
MS. GERAGOS: And you liked that quality time with him, right?
MS. GERAGOS: Because he was your partner and your lover, and you wanted to take care of him, right?
MS. GERAGOS: And those times with him were sacred to you?
MS. GERAGOS: And you really, really wanted to please him, right?
MS. GERAGOS: You wanted him to be happy?
MS. GERAGOS: You mentioned a few times on direct examination that there were times that he felt bored or you thought he felt bored, you would mention having an entertainer come, right?
MS. GERAGOS: In that one instance where he seemed bored?
MS. GERAGOS: Because you wanted him to be excited and feel fulfilled, right?
MS. GERAGOS: Do you remember telling the government that you deeply loved him and enjoyed just about every minute with him during hotel nights?
JANE: I -- yeah, during hotel nights the portion of me and him, yes, I loved that part of me and him.
MS. GERAGOS: And can you just explain that little bit more, what that part, and that's after a round would be done or after all the entertainers or one or two of the entertainers would leave and it was just time together?
JANE: I would say when we would initially first meet at the hotel, we would have some alone time, and that was one favorite part. And then the next favorite part would then --
MS. GERAGOS: Let me stop you then, and then we'll go into it.
How long would that alone time be?
JANE: I would say it could vary between 30 minutes to an hour, really just the time before an entertainer comes.
MS. GERAGOS: What would you do during that 30 minutes to an hour?
JANE: We would either just have drinks or start taking an ecstasy pill or we would make love or halfway make love.
MS. GERAGOS: Okay. And would there be drinks set up, like champagne and other types of alcohol or -- and just normal beverages too, non-alcoholic?
MS. GERAGOS: And then you would like that time to connect with him, right?
MS. GERAGOS: And so that could last for like 30 to an hour, right?
MS. GERAGOS: But it could also last longer than that, right?
MS. GERAGOS: I interrupted you when you were about to get to the next part.
JANE: Oh, just that whenever it was just the moments that we would start making love was the moments that I really enjoyed in these nights with him.
MS. GERAGOS: And then how long after an entertainer would leave did you guys then end up going to his home either in Bel Air or Miami?
JANE: I would say after one of these nights, I guess we would just be together ourselves, and we would then have that time to just have for each other, and then we would go to one of the residences.
MS. GERAGOS: Would you guys during this time together -- I know you said he was really tired, but were you guys able to talk and express feelings to one another?
MS. GERAGOS: Umm, after.
MS. GERAGOS: And then what about before?
JANE: Before, it would be like ending together in the hotel and then moving on to a residence, just me and him, and then we would have that.
MS. GERAGOS: Time together?
MS. GERAGOS: Do you remember telling the government that during these nights he was really good about being with you and being in your head and giving you the attention that you craved during these nights?
MS. GERAGOS: And that he would cater to you?
MS. GERAGOS: How would he cater to you?
MS. GERAGOS: And that he would give you the compliments that you wanted while in those rooms?
(Continued on next page)
BY MS. GERAGOS:
MS. GERAGOS: Did he give you affection outside of the rooms?
MS. GERAGOS: You enjoyed his affection, right?
MS. GERAGOS: And so even when there were times that he came to your house and that there wouldn't be men there or entertainers, he gave you affection as well, right?
MS. GERAGOS: Was it on a heightened level during these nights?
MS. GERAGOS: He's more larger than life and inspiring but not as affectionate when it's not during these nights?
MS. GERAGOS: OK. Got it.
You testified that by about November of 2021, you realized that this was just becoming the dynamic of your relationship, right?
MS. GERAGOS: OK. And that -- do you remember telling the government that you accepted the dynamic at that time because you just wanted any amount of time with him?
JANE: I accepted the dynamic as far as -- that's a little fuzzy for me. I guess I -- yeah. I guess I kind of knew what I was seeing this was becoming, and I was already hooked onto the love and I just kind of was going with it.
MS. GERAGOS: OK. And do you remember telling the government in one of your meetings with them that you felt that you couldn't say no because you wanted to prove yourself and to make him happy and to be the one he desired?
MS. GERAGOS: And why is that?
JANE: Why? Because I loved him very much and I liked making him happy, and I liked to make him happy and satisfy him.
MS. GERAGOS: And you perceived these nights as things that could satisfy him, right?
MS. GERAGOS: OK. Do you remember telling the government that he would say that you guys didn't have to do anything and that he didn't need these nights and that he would be defensive whenever you brought up his feelings?
MS. GERAGOS: OK. And that when he would tell you he didn't need these, you knew deep down that he did?
MS. GERAGOS: OK. And he knew -- when you would leave or have a break with him, he knew how to make you feel better?
MS. COMEY: Objection.
THE COURT: Sustained.
BY MS. GERAGOS:
MS. GERAGOS: Do you remember telling the government that he knew how to make you feel better?
MS. COMEY: Objection.
THE COURT: I think you just need to rephrase the question.
MS. GERAGOS: OK. Thanks, your Honor.
MS. GERAGOS: Do you remember that there were times where you would voice something to him and that he knew how to get you to come back, essentially?
MS. COMEY: Objection. Vague and time frame.
BY MS. GERAGOS:
MS. GERAGOS: All right. Starting in August of 2023, do you remember voicing certain things to him and he would be defensive in response?
MS. COMEY: Objection.
THE COURT: Sustained.
BY MS. GERAGOS:
MS. GERAGOS: All right. Do you -- let me just move on. Do you remember telling the government that Combs was driven by desires and you were driven by your love of him?
MS. COMEY: Objection.
THE COURT: Overruled.
MS. GERAGOS: If you don't remember, it's fine. Do you remember saying you were driven by your love of him?
MS. GERAGOS: OK. All right. I want to go back to the beginning of the relationship. You've talked a lot about red lights and oil and ecstasy during these nights.
Before you had your first hotel night with him in May of 2021, would he use red lights and oil outside of that first hotel night?
MS. GERAGOS: OK. So this was not something that was exclusively used for hotel nights?
MS. GERAGOS: OK. After the first time that you met him and Don -- or that you met Don, I should say, in May of 2021, did you start doing research on this lifestyle?
JANE: In the middle of our relationship, I think, in maybe 2022, I came upon a word called -- because I was just trying to figure out my relationship. I came upon a word that was called a "cuck," "cuckolder."
MS. GERAGOS: And what is that?
JANE: That is a man who is in a relationship with a woman and he's turned on watching his woman have sex with another man.
MS. GERAGOS: And so you came upon that word while researching what was going on in your relationship?
MS. GERAGOS: OK. And so is that -- was that word -- so what did that word mean to you? When you were researching it, what did that mean to you?
JANE: That word meant to me -- well, I was just trying to understand what was going on, so I guess I -- what did that word mean to me? I was just, like, this is spot-on.
MS. GERAGOS: OK. And were you researching what a cuck is?
MS. GERAGOS: And so you learned what you just said the definition was. What else did you learn about this?
JANE: I was just trying to kind of deep dive on all the reasons why they had derived so much pleasure from watching their woman be with other men.
MS. GERAGOS: And what effect did that have on you?
MS. GERAGOS: And what were some of those reasons?
MS. COMEY: Objection. I'm not sure if it's calling for hearsay, your Honor.
MS. GERAGOS: Effect on the listener, your Honor.
THE COURT: I don't think the question is calling for hearsay, but maybe you can rephrase the question to avoid the objection.
MS. GERAGOS: I think my question was what effect did it have on you, and I think that that would --
THE COURT: Well, that wasn't the question, but why don't we get a fresh question and we'll see if there's an objection.
BY MS. GERAGOS:
MS. GERAGOS: What was your understanding -- you said that it helped you get an understanding. What was your -- how did it help you get an understanding?
JANE: I just wanted to know why my partner wanted so many of these nights and what was driving him. I was just trying to find an understanding of it that he wasn't vocal about.
MS. GERAGOS: And so what was your understanding that you learned?
JANE: I mean there was a multiple list of reasons. One of them was that the cuck derives pleasure seeing his woman receive pleasure from the other man, and a few other things.
MS. GERAGOS: What were some of the other things?
MS. COMEY: I'm going to object at this point.
THE COURT: That's overruled.
JANE: Some of the other things were that cucks could also have a real curiosity that they're too ashamed to experience themselves and so they use the woman to venture out in this curiosity without actually doing the act itself.
MS. GERAGOS: And did you ever say that he was using the words "voyeurism" in the wrong way? Did you learn -- actually, let me strike that.
Did you ever learn about the word "voyeurism"?
JANE: I didn't dive too deep on that word, but he liked to use the words "voyeurism" and "escapism."
MS. GERAGOS: And did you ever research, if you did, the word "voyeurism" or "escapism"?
JANE: No. I think I pretty much -- I had more of a -- I would use the word "cuck" for him more so.
MS. GERAGOS: OK. And so when you guys started these hotel nights and an entertainer would come, did he -- I think you said that the first 30 minutes to an hour is just you and him time, time that you cherished, right?
MS. GERAGOS: And then the entertainer would come, right?
MS. GERAGOS: Did you spend and did he spend time talking and laughing with the entertainer?
MS. GERAGOS: I think you had mentioned some of them you grew fond of, like Paul?
MS. GERAGOS: And so would you guys talk and laugh with that person?
MS. GERAGOS: And so would you guys have conversations?
MS. GERAGOS: How long did that last?
MS. GERAGOS: Yeah. Before the sexual activity or the foreplay, I think, you mentioned or even the time where you would dance or pour oil on yourself, how long would the talking and just the conversations last?
MS. GERAGOS: And what kind of questions and conversations would you have?
JANE: I would just strike up, like, small conversation, asking them how they're doing and what's been new with them, etc.
MS. GERAGOS: And then at that point, would you already be in the lingerie and the heels?
MS. GERAGOS: Would you change into that right when you got into the room, or at what point?
MS. GERAGOS: OK. And how long would -- I think we talked about a pattern, and so I'm just asking generally between -- I'll do what Ms. Comey did. Between May of 2021 and October of 2023, how long would the time when you were in your lingerie and heels and you would be dancing, how long did that period last?
MS. GERAGOS: Yes.
MS. GERAGOS: Would you guys play music?
MS. GERAGOS: Did you have play lists that you liked?
MS. GERAGOS: OK. And you spoke on direct how you were really good at making everybody think that you wanted to be there, right?
MS. GERAGOS: And you were very sweet to the entertainers?
MS. GERAGOS: You would ask them questions about themselves?
MS. GERAGOS: You asked him about -- you asked Mr. Combs about himself, right?
MS. GERAGOS: And you guys were all laughing and joking and talking to one another, right?
MS. GERAGOS: And then you talked about how there would be foreplay and fantasy talk for hours and hours and hours, right?
MS. GERAGOS: And I think you testified that that was what you perceived to be Mr. Combs's favorite part of the night?
MS. GERAGOS: And then you said the actual act of the sex was a lot shorter, right?
JANE: At times. It could vary. It would be shorter or longer. Some could last for a very, very long time.
MS. GERAGOS: OK. So that was not -- that varied, the length of sex varied?
MS. GERAGOS: OK. And then you talked about filming these. You were OK with it being filmed, right?
MS. GERAGOS: And he said that they were just for you and him, right?
MS. GERAGOS: You understood that he didn't want anybody else to have them either, right?
MS. GERAGOS: And that was part of why you and him ended up getting your own phone for these, right?
MS. GERAGOS: Because you wanted to make sure that nobody could get a hold of the recordings?
MS. GERAGOS: Because, as you said, it was easy to get into his phone, right?
MS. GERAGOS: And you liked that you and Mr. Combs could watch these videos back and that he would get pleasure out of it, right?
MS. GERAGOS: You testified about a movie screen that you got him for his birthday in 2023, right?
MS. GERAGOS: And you said that was to watch either pornography or to watch some of these videos, right?
MS. GERAGOS: And you knew that one of the things he was going to watch on it was your videos, right?
MS. GERAGOS: And you liked making your partner happy?
MS. GERAGOS: And you knew that he would derive pleasure from watching these videos, right?
MS. GERAGOS: And so you put on a good show for him in these videos because you knew he would watch them back, right?
MS. GERAGOS: OK. He was always very happy in these hotels, right?
MS. GERAGOS: OK. And charming -- you said charming and loving?
MS. GERAGOS: And would you ask him questions, like, do you want me to do this or do you want me to do that, when you were with these entertainers?
MS. GERAGOS: And tell me why you did that.
MS. GERAGOS: And you knew the things that you could say during these nights that would turn him on?
MS. GERAGOS: And you had -- you kind of set ground rules in these rooms; I think you talked about your ground rules were that no entertainers could use drugs, right?
MS. GERAGOS: And can you tell us a little bit about why?
JANE: I just didn't want to have a stranger be out of their mind in a very vulnerable environment with me.
MS. GERAGOS: And you also talked about condoms and how you wanted -- you wanted -- you asked twice for men to wear condoms, right?
MS. GERAGOS: The first time we listened to that recording of Don, right?
MS. GERAGOS: And ultimately, after that, he was given a condom to wear, right?
MS. GERAGOS: OK. You testified earlier that Sean decided when a hotel night would end early, right?
MS. GERAGOS: And that sometimes you would give him subtle cues when you wanted them to end?
MS. GERAGOS: And his response, you said, was let's end on a high note, right?
MS. GERAGOS: What did that mean to you?
MS. GERAGOS: That he wanted to end on a high note meant that he wanted more?
MS. GERAGOS: And what would you say in response to that?
MS. GERAGOS: And you wouldn't stop it?
MS. GERAGOS: OK. There were a few instances that we talked about -- and I'll just lead you through these quickly -- where you did voice that you wanted something to end, right?
MS. GERAGOS: And then he listened?
MS. GERAGOS: But did you remember telling the government that there were a few instances where you wanted a hotel night to end early and it would end?
MS. GERAGOS: OK. And you said when you became more vocal about your feelings about this, he respected that, right?
MS. GERAGOS: OK. So we looked at -- and if we could just bring it up quickly -- Government Exhibit 2A634, which is in evidence.
MS. GERAGOS: There was this individual, right?
MS. GERAGOS: All right. We could take this down.
MS. GERAGOS: You said you were immediately repulsed by him, right?
MS. GERAGOS: And he did not look nice, he smelled?
MS. GERAGOS: Just for the court reporter you have to say yes or no.
MS. GERAGOS: And you told Mr. Combs I'm not attracted to him, right?
MS. GERAGOS: And he said, are you sure, basically, and then said no worries and dismissed the man, right?
MS. GERAGOS: He didn't say no worries?
JANE: I was with this man for about, I would say another hour or two, and it took some time and Sean could see that this really wasn't -- there was no chemistry, at that time he was finally, was, like, OK.
MS. GERAGOS: Do you remember testifying that Mr. Combs said no worries?
MS. GERAGOS: And it just didn't work and he left, right?
MS. GERAGOS: OK. And if we could bring up Government Exhibit 2A610, which is in evidence.
MS. GERAGOS: This was another one of the individuals that you dismissed also, right?
MS. GERAGOS: All right. You could take the photo down.
MS. GERAGOS: You told Mr. Combs you did not find this man attractive, right?
MS. GERAGOS: I think the word was "repulsed"?
MS. GERAGOS: After two times? I think I cut you off. I just want to make sure the record is clear
MS. GERAGOS: OK. So you went out with him, Mr. Combs into a different room first, right?
MS. GERAGOS: And then you gave it another go?
MS. GERAGOS: And then you got him into the room again, right?
MS. GERAGOS: And you said I am repulsed by this man?
MS. GERAGOS: And you said Mr. Combs seemed a little agitated, but then he let him go, right?
MS. GERAGOS: And then you talked about an Italian man in New York where there was also -- you also dismissed him, right?
MS. GERAGOS: And that was the same New York trip, that was September of 2023 that we discussed yesterday, right?
MS. GERAGOS: That was the trip where you guys went to a lounge after you had landed?
MS. GERAGOS: And while you were in air he sent you -- Mr. Combs sent you a link to a Cowboys 4 Angels person, right?
MS. GERAGOS: And you said that you kind of -- you felt so much anxiety on that plane flight, right?
MS. GERAGOS: And so then when you went into the Trump Hotel later that evening, this man was there, the Italian, you called him, right?
MS. GERAGOS: But you did not want to participate with him, right?
MS. GERAGOS: And so after that happens, after you saw him and after you -- after you saw him, you dismissed him, right?
MS. GERAGOS: And Mr. Combs said OK?
MS. GERAGOS: OK. Even though you thought he may be agitated, right?
MS. GERAGOS: And then it was after that that you were feeling badly, and so you texted Kabrale, right?
JANE: There was a unspoken kind of, like, how you -- like what's the plan B? Like, what are we going to -- I don't know, like how are you going to make this up? There was an undertone of that, and so I --
MS. GERAGOS: You just said it was unspoken?
JANE: There was certain energy that there needed to be someone else there in the room, and so I took it upon myself to message Kabrale.
MS. GERAGOS: So you felt an energy, but he didn't say something, right?
JANE: Well, he would say things like what's the plan B or what else? What else? Like, what else? So me being just that I understand my partner, I knew what that meant.
MS. GERAGOS: So this Italian man came to the Trump Hotel, this was the same person he had texted you about, right?
MS. GERAGOS: You were not attracted?
MS. GERAGOS: You dismissed him?
MS. GERAGOS: And the energy and the undertone was there should be somebody else, right?
MS. GERAGOS: And then you reached out to Kabrale?
MS. GERAGOS: All right. You also testified on direct examination about your teeth. Do you remember that?
MS. GERAGOS: The government had asked you whether this was -- I think asked, this was right after the Turks trip, right?
MS. GERAGOS: Yes.
MS. GERAGOS: After the second Turks trip, in 2023.
MS. GERAGOS: OK.
MS. GERAGOS: And the government got up and said, questioned you and said that he did not like your teeth, right?
MS. COMEY: Objection.
MS. GERAGOS: I can rephrase.
THE COURT: All right.
BY MS. GERAGOS:
MS. GERAGOS: Do you remember saying -- do you remember testifying that it was because Mr. Combs did not like your teeth?
MS. GERAGOS: OK. You previously said that he was right and that you love your teeth now, right?
MS. GERAGOS: OK. And from what you understand, are you familiar with people getting veneers? Is this bizarre behavior, to get veneers?
MS. COMEY: Objection.
THE COURT: Overruled.
MS. GERAGOS: This was something you're OK with, right?
MS. GERAGOS: And so you got them, right?
MS. GERAGOS: OK. If you could what's admitted put up A10453, government exhibit.
All right. If you could go to page 15, please -- I'm sorry. Go to page 12.
MS. GERAGOS: He says: So they give natural. I can't really see. So they give natural. Right?
MS. GERAGOS: What does that mean, they give natural?
MS. GERAGOS: What does --
MS. GERAGOS: What does the term mean they give -- could you explain for those of us who don't know what give --
MS. GERAGOS: -- natural means?
MS. GERAGOS: OK. Because was it important that your teeth look natural and very good?
MS. GERAGOS: And that was important to you too, right?
MS. GERAGOS: OK. And you can take this down.
MS. GERAGOS: And you testified that you love them, right?
MS. GERAGOS: OK. And then you talked about your nipple piercing that you got, right?
MS. GERAGOS: And that Ms. Khorram helped set up the appointment for you?
MS. GERAGOS: And did she go with you?
MS. GERAGOS: You went by yourself?
MS. GERAGOS: And you made that decision to do that, right?
MS. GERAGOS: And then you made the decision to go, right?
MS. GERAGOS: And you made the decision to get it done?
MS. GERAGOS: And then you made the decision to take them out, right?
MS. GERAGOS: Because it snagged and it hurt?
MS. GERAGOS: OK. We also talked a lot about ecstasy in the hotel rooms and otherwise. You were willing to do drugs with him, right, even though that wasn't part of your daily occurrence?
JANE: My partner had drugs around, and he would encourage me to take them. Or he would already see me and be like, here.
MS. GERAGOS: And how old are you at this time?
MS. GERAGOS: 35?
MS. GERAGOS: And when he would say here or when they were around, you would take them, right?
MS. GERAGOS: I think you've talked about several different types of drugs that you used while you were in your relationship with Mr. Combs. You said, for example, you tried ketamine but you didn't like it, right?
MS. GERAGOS: So you decided you weren't going to take ketamine anymore, right?
MS. GERAGOS: And then you talked about cocaine; you tried it maybe one or two times, I think, you said?
MS. GERAGOS: And you did not like cocaine so you didn't take it?
MS. GERAGOS: So you had cocaine around, right?
MS. GERAGOS: But you decided after those two times that you took it that you didn't like it?
MS. GERAGOS: OK. So you decided not to take it more?
MS. GERAGOS: OK. You talked about, but you did take ecstasy, and then we also heard about the liquid drug that you took that we talked about yesterday?
MS. GERAGOS: And can you tell us why you liked -- why you preferred ecstasy over the other drugs?
JANE: I feel that ecstasy made me feel extremely sexual and liberated, and it just helped me get through these nights with men as well.
MS. GERAGOS: You took ecstasy with Mr. Combs even when there weren't men there, right?
MS. GERAGOS: Si -- yes. Sorry.
JANE: Yes. When I was with Mr. Combs, we would also take ecstasy, just me and him as well, on some occasions, yes.
MS. GERAGOS: OK. And so it was not only when you were in hotel nights or with other men that you would take ecstasy, right?
MS. GERAGOS: OK. And it made you feel liberated. Can you explain that?
JANE: Yes. It just got me out of my mind, not think too much and just kind of focus in on the sexual energy and just being, like, really sexual and into the moment.
MS. GERAGOS: OK. From your -- when you took ecstasy, Mr. Combs was doing it as well with you, right?
MS. GERAGOS: From your perspective, how was Mr. Combs on ecstasy?
JANE: I felt that he was -- he was him. He was just happy, charismatic, just big energy, sexual, high.
MS. GERAGOS: I think you previously said that he wasn't in his normal life or when he wasn't on ecstasy, he was, perhaps, maybe a little bit more aggressive?
JANE: Oh, I see.
I feel like when I would see him before ecstasy, he would seem a bit agitated or just kind of stressed from the day. And I feel like once he took ecstasy, he was more upbeat, happy, in a good mood.
MS. GERAGOS: It softened him up?
MS. GERAGOS: Was he more -- did you observe him to be a little bit more creative on it?
JANE: Creative, yes. I would say he would listen to music and have these good, creative thoughts.
MS. GERAGOS: And how long, in your experience, would an ecstasy high last?
JANE: I would say I kind of had to -- from one pill, we would break them up. At just various points in the night, I would say I would take, like, a little pill every two to three hours up until, like, the final kind of moment, or whatever.
MS. GERAGOS: OK. So how many -- a small portion of one pill, is that right?
MS. GERAGOS: So it's not like an entire pill, like that one that you took in Turkos and Caicos; it's a smaller portion of one pill?
JANE: It varied. I would take small -- sometimes I would take big, a pill, and then sometimes it would be broken down. It kind of varied.
MS. GERAGOS: You talked that there were a couple of times at hotel nights where you cried. Do you remember that? There were two times in particular?
MS. GERAGOS: And the first time you were on the bed and you cried, and he didn't know what was wrong, right?
MS. GERAGOS: And you wanted him to hold you and be there with you?
MS. GERAGOS: And then he didn't, right; he moved what he needed around?
MS. GERAGOS: And he held you?
MS. GERAGOS: You testified that he sat with you and held on to you, right?
MS. GERAGOS: And you held on to him, right?
MS. GERAGOS: And he provided that support that you needed at that time, right?
MS. GERAGOS: Was he also -- he was also on ecstasy at that moment as well?
MS. GERAGOS: OK. And then you talked about a second time in the middle of the relationship where you were in the shower with him. Do you remember that?
MS. GERAGOS: Were you in the shower because you -- first of all, why were you in the shower at that moment?
MS. GERAGOS: Were you taking a shower because you needed it because of the drugs, or was it at the end of the hotel night and you would always take a shower then?
MS. GERAGOS: OK. And do you remember testifying that you had spotty memories of this incident?
MS. GERAGOS: And that his response when you started crying was, he was too high and he couldn't see this, right?
MS. GERAGOS: So he was also on drugs at that same moment as well, right?
MS. GERAGOS: Can't see this?
MS. GERAGOS: OK. And so you've also talked about how he'd be agitated from the week and he would feel a lot of pressure from work. Did he talk about something on Fridays called fuck-it Friday?
MS. GERAGOS: What is fuck-it Friday?
MS. GERAGOS: And what was your impression of why he had what he called fuck-it Friday?
JANE: I think he just felt a lot of pressure from, I don't know, various things in his personal life, and then he would want to just party big on Fridays.
MS. GERAGOS: And you would party big with him too when you were with him, right?
MS. GERAGOS: OK. Do you remember that Ms. Comey asked you on direct examination whether you ever carried drugs for Sean? Do you remember that?
MS. GERAGOS: And you answered twice, right?
MS. GERAGOS: And you said that you had spoken to K.K. over the phone about this?
MS. GERAGOS: I want to show you what has been marked as Defense Exhibit 3246, and it should be behind 246 in your binder. I hope that there's a 246 there. If not, we'll put it on the screen.
MS. GERAGOS: OK. If we could show both pages.
MS. GERAGOS: All right. Tell me when -- if you could review it first, if you could read pages 1 and 2, tell me when you're done with that and I'll move to the next two pages.
MS. GERAGOS: All right. Next two pages, if you could review these two pages.
MS. GERAGOS: All right. Next two.
MS. GERAGOS: All right. And then just to make this easy, could you also look at what's marked as 3248. That also should be in your binder, but if not, we can bring it up on the screen.
MS. GERAGOS: Pages.
MS. GERAGOS: OK. Do you recognize both 3246 and 3248 as chats between you and Kristina Khorram?
MS. GERAGOS: OK. Are these both from December of 2021?
MS. GERAGOS: One is from December 2, right?
MS. GERAGOS: And one is from December 30?
MS. GERAGOS: I believe, with the government's consent, we offer these, your Honor.
MS. COMEY: Under seal, your Honor, but no objection.
MS. GERAGOS: Under seal.
THE COURT: 3246 and 3248 will be admitted under seal.
(Defendant's Exhibits 3246 and 3248, sealed, received in evidence)
MS. GERAGOS: Let's go to the first one, to 3246, please, if we could put both pages, one and two.
MS. GERAGOS: This is a chat between you and Ms. Khorram, December 2 of 2021, and you and her are discussing flight options, right?
MS. GERAGOS: All right. So if we could go to pages 3 and 4.
MS. GERAGOS: All right. So if you go down on page 3, and Ms. Khorram says: On conference call. Call you back. Right?
MS. GERAGOS: And then you respond: Hey. In the car. I asked if he had something for me. He said no, right?
MS. GERAGOS: OK. Take that down, please.
MS. GERAGOS: And she says: No. You have to go to Mapleton to get. LOL. Security has it for you at Mapleton. Right?
MS. GERAGOS: And you respond: OMG, OK. And she said: That's why I said call me when you're close, so security can run it out. Right?
MS. GERAGOS: And she said: Sorry. Thought that was clear where I said house. Right?
MS. GERAGOS: And you said: Tell driver if you need to get it prior to getting me. And she said: LOL. No he can't. Right?
MS. GERAGOS: And then next page, and she says: Kind of personal. LOL. Right?
MS. GERAGOS: All right. Is this in reference to one of the times that you -- that you took, transported the drugs for Mr. Combs?
MS. GERAGOS: And in this message, you are not speaking on the phone with her, right?
MS. GERAGOS: OK. And she's just saying it's kind of personal, right?
MS. GERAGOS: OK. All right. Could we go to 3248, under seal, already in evidence.
MS. GERAGOS: OK. And this is a message from December 30 of 2021, right?
MS. GERAGOS: And you reach out to K.K. and say: Hey, babe. I was just trying to get a hold of Sean. It's a little bit time sensitive. Would you mind telling him to give me a call? Thanks so much, babe?
MS. GERAGOS: And she says: Hi. Yes, I'll text him now. Right?
MS. GERAGOS: At the next page, she says, at the top of the page: Also think he's going to have you pick up a package before as well, so plan extra time for picking that up. LOL. Right?
MS. GERAGOS: And say: Copy. LOL. Yup. Got it. If he wants, he can drop it off at my building as well if that's any easier. Maybe place in a shoe box or something. My front desk can hold it for me. Just an option. Right?
MS. GERAGOS: And Ms. Khorram responds: PD talks to him directly. I don't speak with him. Right?
MS. GERAGOS: And that's in reference -- is this in reference to the drugs that you were taking to Miami?
MS. GERAGOS: And she says -- and then you say: OK. Got it. Right?
MS. GERAGOS: So in that instance you guys are not talking on the phone together, right?
MS. GERAGOS: There was conversation over the phone?
MS. GERAGOS: OK. Can I -- I'd like to pull up for the witness only -- well, first, can we put that back up.
MS. GERAGOS: Do you see that Ms. Khorram's phone number ends in 2886?
MS. GERAGOS: OK. And you see your phone number, right?
MS. GERAGOS: OK. I'd like to offer, I believe, with the consent of the government -- no; Ms. Johnson will correct me if I'm wrong -- 3313A into evidence.
MS. COMEY: Your Honor, I think we've had some ongoing discussions about that exhibit. If we could have the lunch break to work those out before they come in, I think we could end up not objecting.
MS. GERAGOS: OK. So then I'll just show it to the witness just to refresh right now, your Honor.
THE COURT: All right.
MS. GERAGOS: If we could pull up just for the witness 3313A, both pages side by side, please.
MS. GERAGOS: And you said you remembered having conversations in between?
MS. GERAGOS: All right. So showing you, to refresh your recollection, your records from your phone number we were just looking at.
MS. COMEY: Objection, your Honor.
THE COURT: That's sustained.
MS. GERAGOS: OK. If we could please look on page 2, and if we could zoom in.
MS. GERAGOS: And please tell me whether this refreshes your recollection as to whether you had any phone calls with Ms. Khorram's number after that.
MS. GERAGOS: 2886.
MS. GERAGOS: But -- so does that refresh your recollection if you had a call with her on December 1?
MS. GERAGOS: OK. And then if we could go -- A. And also --
THE COURT: Hold on.
MS. GERAGOS: This isn't in evidence, so --
THE COURT: Hold on.
Ms. Geragos, I think this is going to be easier if you could have the discussion with the government and use it in a different way, unless you want to take it down and ask some questions.
BY MS. GERAGOS:
MS. GERAGOS: All right. Is it your testimony, Jane, that you spoke with Ms. Khorram on the phone after one of these messages?
MS. GERAGOS: OK. We will come back to that.
THE COURT: Or we could have a sidebar and address it right now.
MS. GERAGOS: Let's just do that, your Honor. I think it would be easier.
(Continued on next page)
(At sidebar)
MS. GERAGOS: I believe that we had agreement as to these 12 pages so long as I do not say these are all of the calls they could have possibly had, and I redacted the kind of cell-site information, the locations of the calls.
But how would you like to do this.
THE COURT: Well, let's first hear what the nature of the objection, if there is any, is.
MS. JOHNSON: I'm not sure there is an objection right now, but we're trying to just confirm with the defense about what this exhibit actually is and how it should come in.
What has been marked is cell-site returns for this witness's phone, so it shows -- what it shows is anything that hit a cellular number. That is not necessarily all communications that one makes on a phone. So while these are business records, which we agree they are a limited set of business records, in the ordinary course, to get cell-site information into the record, we need to call an expert to testify as to cell sites.
We proposed a stipulation that explains sort of what these records are and what they are not. I understand that defense doesn't want to stipulate to that, so that's what we are trying to talk about, because they are only things that had a cellular number, not anything that went through, for example, text message, wi-fi, which can include FaceTime calls, and the like.
That's the complication.
THE COURT: OK. So just walking through the steps, there's no objection on authenticity or business records grounds.
MS. JOHNSON: Exactly.
THE COURT: The only objection is on 403 grounds.
MS. JOHNSON: Yes, for being confusing.
THE COURT: All right. I think it's going to be used --
You're just using it to show that there was not a number. Again, I understand the objection is that the cell-site records will not record conversations such as wi-fi calls or text messages, right?
MS. JOHNSON: Yes. Or FaceTime, for example.
THE COURT: Or FaceTime calls. All right.
MS. GERAGOS: I'll just get into this after lunch, your Honor.
THE COURT: OK.
MS. GERAGOS: It's fine.
THE COURT: All right.
(Continued on next page)
(In open court)
THE COURT: Ms. Geragos, you may proceed.
MS. GERAGOS: Thank you, your Honor.
MS. GERAGOS: You testified on direct that you remembered discussing this with K.K. over the phone, right?
MS. GERAGOS: And you testified that you asked K.K. whether it was OK, right?
MS. GERAGOS: And why would K.K. know whether this is OK or not?
JANE: Because she was asking me to do it, and so I just asked if it was OK to put it in my luggage like that.
MS. GERAGOS: OK. Could we bring up 3248 again. That is in evidence. And if we could go -- both pages, please.
MS. GERAGOS: OK. So she says, on page 2: Also think he's going to have you pick up a package before as well, right?
MS. GERAGOS: So she's not asking you to do it here, right? She says: He's going to have you pick up a package before as well, right?
MS. GERAGOS: And she says: Plan extra travel time for picking that up, right?
MS. GERAGOS: So her question was, her assertion was to plan extra travel time, right?
MS. GERAGOS: And then you respond: Got it. Copy. LOL. You got it. If he wants, he can drop it off at my building as well if that's any easier. Right?
MS. GERAGOS: That was about him, meaning Mr. Combs?
MS. GERAGOS: OK. If we could unzoom -- A. Actually, no. I think if he wants, he can drop it off at my building as well, he's going to have -- I'm not sure there if I'm talking about Mr. Combs or security.
MS. GERAGOS: OK. And K.K. says: PD talks to him directly. I do not speak with him. Right?
MS. GERAGOS: OK. And you said, on direct examination, that K.K. said, it's fine, I do it all the time, just put it in your check-in luggage, right?
MS. GERAGOS: Ms. Khorram, when she travels with Mr. Combs, she travels on his private plane, right?
MS. GERAGOS: She's not traveling commercially, right?
MS. GERAGOS: When she travels with Mr. Combs, she travels on his private plane, right?
MS. GERAGOS: Were you and Ms. Khorram close, or no?
MS. GERAGOS: We've seen a lot of text messages between the two of you, right?
MS. COMEY: Objection.
THE COURT: Overruled.
BY MS. GERAGOS:
MS. GERAGOS: But you and Ms. Khorram would text more than you would talk on the phone, right?
MS. GERAGOS: There were times over the three-and-a-half-year relationship, of course, that you guys spoke on the phone, right?
MS. GERAGOS: But -- but generally you and her were not close, right?
MS. GERAGOS: OK. And fair to say that that was a point of contention for you?
MS. GERAGOS: Because -- can you explain why?
MS. GERAGOS: And that was hard, because Ms. Khorram was always with Mr. Combs, right?
MS. GERAGOS: And so if Ms. Khorram didn't like you, you thought that that would be difficult for your relationship with your lover and your partner?
MS. GERAGOS: OK. And can you explain a little bit why that was?
JANE: I believe that she had very strong opinions about me, which influenced a great deal of how Sean also treated me.
MS. GERAGOS: OK. We talked a lot on direct examination about the entertainers, and you said that in the beginning, Mr. Combs would find entertainers from Cowboys 4 Angels, right?
MS. GERAGOS: And, and that's how you -- that's how he found Don, from your understanding, right?
JANE: Later on in our relationship, I realized that Sean was always saying cowboys, and then he said that Don was from Cowboys, like later on in our relationship.
MS. GERAGOS: OK. And do you remember saying that you found Don to be handsome?
MS. GERAGOS: We looked at a photo of him. Would you a say he's much more handsome in person?
MS. GERAGOS: What kind of features about him that made him handsome to you?
MS. GERAGOS: And Paul -- you said that Paul was gentle and that you had chemistry with him, right?
MS. GERAGOS: And there was a warm energy about Paul that you liked, right?
MS. GERAGOS: And over time you really took a liking to Paul, right, as a friend?
JANE: Given my circumstances, I found Paul -- I don't know what the word is. If I had to do what I had to do, at least there was somebody that had a warm energy about them to do this with.
MS. GERAGOS: You talked yesterday on direct about the time in July of 2024 where you were in Miami, right?
MS. GERAGOS: And you said I miss Paul, right?
MS. GERAGOS: And so you guys called Paul to come over to Miami, right?
MS. GERAGOS: And you genuinely missed him, right?
MS. GERAGOS: And I think you testified yesterday that after that time that Paul came over, you said it was an unbelievable sexual experience, right?
JANE: At that time I had consumed a lot of ecstasy and then I was introduced to a new liquid molly, and so a lot of heightened emotions and sexual energy definitely entered that whole experience.
MS. GERAGOS: And that that experience really -- you held good feelings about that experience, right?
MS. GERAGOS: And I think you testified that you made love to Paul?
MS. GERAGOS: That day, right?
MS. GERAGOS: Do you remember what -- what was the nickname that you, Paul and Mr. Combs had for each other?
MS. GERAGOS: Can you explain that?
JANE: Trifecta, I don't even know, because it's three, and I think Sean was the one who said trifecta. And then it became trifecta.
MS. GERAGOS: Would you compare yourselves to sports stars?
MS. GERAGOS: Who?
MS. GERAGOS: Who was Kobe?
MS. GERAGOS: OK. And who was Paul?
MS. GERAGOS: The Lakers help you a little?
MS. GERAGOS: Shaq. OK. And who was Mr. Combs?
MS. GERAGOS: OK. Michael Jordan?
MS. GERAGOS: Do you remember during your experiences with Paul or when you would speak to Paul that you would call him -- you would call him your boyfriend?
MS. GERAGOS: Playfully, flirtatious, like call him your boyfriend, not that he was your actual boyfriend but playfully you would call him that?
MS. GERAGOS: OK. And you called him and Mr. Combs during these nights and on these videos your boys, right?
MS. GERAGOS: Do you remember telling Paul that you were happy you got to explore your sexuality with him?
MS. GERAGOS: And, and was Paul really nice to you?
MS. GERAGOS: And you really did like him as a person, right?
MS. GERAGOS: And then you testified on direct that you wanted to have more control over your situation so you would find other entertainers to bring in, right?
MS. COMEY: Objection.
THE COURT: Just rephrase the question.
BY MS. GERAGOS:
MS. GERAGOS: Do you remember testifying on direct examination that you wanted to have more control over the situation?
MS. GERAGOS: OK. And so the first way you testified that you exerted that control was DMing Kabrale, right?
MS. GERAGOS: OK. So you've -- you and -- and just tell me if I'm wrong about any of this, but that you were watching, you and Mr. Combs were watching Kabrale on Blacked, is that right?
MS. GERAGOS: And Blacked is a porn site?
MS. GERAGOS: And that you DMed him after you started watching him, right?
MS. GERAGOS: OK. So can you explain how that came about?
JANE: I remember it was just put on the Free Play, and then we saw a video that we liked and we kept watching the specific actor in that video and kept watching more of that actor's video. And that's how we found the page, that personal page.
MS. GERAGOS: You kept watching more and more of that pornography and you guys both liked it?
MS. GERAGOS: OK. And so then you went on your Instagram and you found him on Instagram?
MS. GERAGOS: Mr. Combs was right next to you, right?
MS. GERAGOS: And what was he saying that was encouraging?
JANE: Can you get that dick? Do you think you can get that dick? Do you like that dick? Hit up that dick.
MS. GERAGOS: And you DMed him on Instagram?
MS. GERAGOS: That's a bold -- that's a bold move, right?
MS. COMEY: Objection, your Honor.
THE COURT: Sustained.
BY MS. GERAGOS:
MS. GERAGOS: When you DM somebody on Instagram, is that a private message?
MS. GERAGOS: When you DM somebody on Instagram, can that person screenshot the DM?
MS. GERAGOS: OK. And was it your idea when -- you said on direct examination it was your idea to DM him, right?
MS. GERAGOS: Why?
MS. GERAGOS: So at that time in your relationship, this was about -- does October 2021 sound right?
MS. GERAGOS: OK. So at that time it had been about five months of other entertainers, right?
MS. GERAGOS: And so then you were alone with Mr. Combs, right?
MS. GERAGOS: And you were both watching this pornography?
MS. GERAGOS: And then you had the idea to DM Kabrale, right?
MS. GERAGOS: And because it -- I think you said on direct that this was the context of your relationship, and you were going to choose who the entertainers were, right?
MS. GERAGOS: And so you sent Kabrale a DM yourself with the encouragement, you said, of Mr. Combs, right?
MS. GERAGOS: OK. And he did not ask you to reach out to him, right? He was encouraging it, right?
MS. GERAGOS: OK. And do you remember telling the government that Combs was surprised and really happy because he had never had a girl pick the guy before? Right?
MS. GERAGOS: And was that in the moment that he was telling you he was happy, or when did you learn that?
MS. GERAGOS: OK. And you also testified on direct that the first time Kabrale came, you can't remember exchanging any money, right?
MS. GERAGOS: OK. And the first time he came, you told Combs that you were bringing somebody from Atlanta, right?
MS. GERAGOS: OK. On Kabrale, I think yesterday you talked about a time where he was texting you and he sold a tape to a media company, right?
MS. GERAGOS: Mr. Combs was really upset about that, right?
MS. GERAGOS: He was adamant that you should call the police, I think, you said?
MS. GERAGOS: And he told you he was so sorry that this happened?
MS. GERAGOS: And he did not want this tape released, right?
MS. GERAGOS: He was livid and pissed?
MS. GERAGOS: And he was trying to figure out how to make sure that it doesn't get released, right?
MS. GERAGOS: And so then you spoke -- and I don't want to know what you talked about, but you spoke to an attorney about this?
MS. GERAGOS: And then you made the decision that you were going to ignore the extortionate threats Kabrale was making, right?
MS. GERAGOS: And when Kabrale did end up selling the tape to the media company, Combs was really angry, right?
MS. GERAGOS: He didn't want this -- from your perspective, he didn't want you to have to go through this, right?
MS. GERAGOS: And he did not want this out about himself either, right?
MS. GERAGOS: And then we talked, shifting gears, that you had reached out to Kabrale, and then you talked about Antoine. Do you remember approximately what time you reached out to Antoine?
MS. GERAGOS: Would you say approximately 2022?
MS. GERAGOS: OK. So after it had been many months of Kabrale, you then found Antoine?
MS. GERAGOS: And did you find Antoine the same way, through the same Blacked porn site?
MS. GERAGOS: And how often had you been, you and Mr. Combs, if at all, you and Mr. Combs been watching Antoine before you reached out to him?
MS. GERAGOS: OK. And then you reached out to him on Instagram as well?
MS. GERAGOS: Did you grow to have a nice personal relationship with Antoine also?
MS. GERAGOS: OK.
MS. GERAGOS: And I think you said Antoine never traveled, that he would meet up with you and Mr. Combs only in Los Angeles, right?
MS. GERAGOS: And the first time I think that you FaceTimed Antoine -- first time you started talking to Antoine you FaceTimed him, right?
MS. GERAGOS: And was that a screen share the same way it was with Kabrale as well?
MS. GERAGOS: Was that something you perceived made Mr. Combs really happy?
MS. GERAGOS: And so then you made arrangements to meet Antoine for the first time as well after that FaceTime, right?
MS. GERAGOS: All right. You talked also on direct about, often, a lot about Mr. Combs's assistants? You talked about Jonathan, Brendan, right?
MS. GERAGOS: And then you talked about security. You talked about J9 and Faheem and some others, right?
MS. GERAGOS: And you said that at times they would bring cash to Mr. Combs at the hotel, right?
MS. GERAGOS: Did they ever -- from your perspective, did they ever see any of the entertainers?
MS. GERAGOS: How did they -- from what you saw, how did they give Mr. Combs cash?
MS. GERAGOS: And he would take it, or you would take it?
MS. GERAGOS: OK. And then they would leave, right?
MS. GERAGOS: And they would not come into the room, from what you saw, right?
MS. GERAGOS: OK. And to your knowledge, only if you know, would security be the ones, the employees of his who would keep track of the cash that he had and keeping it safe?
MS. GERAGOS: OK. And then when they came, the escorts or -- I mean the security or the assistants, you also wouldn't volunteer to them that an entertainer was there, right?
MS. GERAGOS: Because, as you've said earlier today, privacy was of utmost importance, right?
MS. GERAGOS: And when you had assistants -- I think you talked about how Jonathan and you, there was at least one instance where you and Jonathan got outfits after the concert or during the concert?
MS. GERAGOS: And you didn't say this is because an entertainer is going to come to the hotel later, right?
MS. GERAGOS: And to your knowledge, did K.K. have any knowledge that escorts were joining the hotels?
MS. GERAGOS: And you never talked to her about it, right?
MS. GERAGOS: I want to bring up what's already in evidence as A442-12.
If we could go to page 8.
MS. GERAGOS: OK. So this is a message between you and Mr. Combs, right?
MS. GERAGOS: All right. And then you, in this first message, on the top, it seems to be a reply to Mr. Combs's message, is that right?
MS. GERAGOS: OK. And he says: Yeah, I think the party could have been better. No fault of yours. And you say: The party could have been better? Really? Why? .., Right?
MS. GERAGOS: And then Mr. Combs responds: OK. Where? You find the place. I can't have K.K. know. Damn. Right?
MS. GERAGOS: Do you remember telling the government that K.K. would disapprove of him partying at the time because he was trying to focus on his business and his album?
MS. GERAGOS: OK. And so she -- he did not -- you perceived that he did not want K.K. to know that he was partying, right?
MS. GERAGOS: OK. Can you take that down.
MS. GERAGOS: Do you remember yesterday we were talking about your December 2023 messages with K.K. after your fight with Mr. Combs?
MS. GERAGOS: And you reached out to her because you felt she was really close with Mr. Combs, right?
MS. GERAGOS: And you wanted her assurance that he was not going to release anything, right?
MS. GERAGOS: And during that conversation you understood -- or she said don't worry, nothing is going to happen, right?
MS. GERAGOS: And you felt comforted by that, right?
MS. GERAGOS: And did you feel better after she said that, that nothing was going to happen?
MS. GERAGOS: And that nothing would be released?
MS. GERAGOS: OK. And then she said to you, just why don't you guys give each other space, like, just please give each other space, right?
MS. GERAGOS: Do you remember telling the government in previous meetings with them that during this phone conversation, that she said she would ensure that he gave you space?
MS. GERAGOS: And that she said to you also I don't understand why you guys won't stop. This is why we're in the predicament right now we're in, because he just won't stop?
MS. GERAGOS: And that was because it was right after Cassie's lawsuit?
MS. GERAGOS: And that she said to you in that conversation the best thing for you guys right now is to just stop talking for a while, right?
MS. GERAGOS: And you said he actually listened to her because he gave you your space, right?
MS. GERAGOS: And you were very appreciative of that, right?
MS. GERAGOS: And then you went to Paris, I think, you said, or Las Vegas?
MS. GERAGOS: And you actually had some time away, some space?
MS. GERAGOS: Some time to yourself?
MS. GERAGOS: And from your perspective K.K. made sure that happened, right?
THE COURT: Ms. Geragos, when you get to a good spot, we'll take our lunch break.
MS. GERAGOS: Just three more questions. I didn't realize we were already at lunch.
MS. GERAGOS: All right. So we've talked a little bit about privacy and how you perceived Mr. Combs didn't want this out, right?
MS. GERAGOS: OK. I would like to bring up A442-11.
If we could go to page 20. This is admitted.
MS. GERAGOS: All right. This is a message between you and Mr. Combs on April 19 of 2023, right?
MS. GERAGOS: And do you recall, because I believe you had looked at this with the government, that you guys are speaking about getting an Airbnb here, right?
MS. GERAGOS: All right. And then he says how do we know if there's no cameras?
MS. GERAGOS: And you respond: There is, but we can have security cover them. Right?
MS. GERAGOS: And if we could go to the next page.
MS. GERAGOS: And at the bottom you say: I can just say it's my anniversary and we just want to cover cameras so we can feel comfortable. LOL. We can have security go in first and do a sweep. Right?
MS. GERAGOS: And that was because he did not want anybody to know about this, right?
MS. GERAGOS: So this is right when you were getting the house, right?
MS. GERAGOS: OK. Your Honor, this is a perfect time for a break.
THE COURT: All right. Very good. Thank you.
Members of the jury, we will take our lunch break, and we will be back around 1:20.
(Continued on next page)
(Jury not present)
THE COURT: All right. We'll come find you.
(Witness not present)
THE COURT: Please be seated.
Ms. Geragos, are we still on pace for 3 p.m.?
MS. GERAGOS: I think so, your Honor. Let me just -- I do think so. I'll let you know right after the brunch break. I'm going faster than I expected.
THE COURT: OK. Good.
Anything that the defense would like to raise?
MS. GERAGOS: Not for me.
THE COURT: Anything, Ms. Comey?
MS. COMEY: No. Thank you, your Honor.
THE COURT: All right. We'll be back at 1:20.
(Luncheon recess)
AFTERNOON SESSION 1:20 p.m.
(Jury not present)
THE COURT: The first issue to pick up, is 45 minutes not enough time for the lunch break?
MS. GERAGOS: It is hard, your Honor. For the defense, I can say that, but this week we were trying to be very efficient and -- but it is hard, that I will say.
THE COURT: Good to know.
MS. GERAGOS: I think on days that we end at 3:00, it does make sense to have the 45 minutes.
THE COURT: If we're going to 3:00, and there isn't a time crunch, we can have some updates then, and we will take a longer break. I understand it's a logistical hurdle to get everything ready and also have lunch 45 minutes.
MS. GERAGOS: I do think I'd like to end at 3:00 today, and then I can cut tonight and tomorrow morning. We have our short day tomorrow morning. I will be done by Thursday and allow Ms. Comey time for redirect.
THE COURT: Very good. Any issues to address before we bring Jane back in?
MS. GERAGOS: No.
MS. COMEY: No, your Honor.
THE COURT: Let's bring the witness back in.
(Continued on next page)
(Witness and jury present)
THE COURT: Jane, you understand you're still under oath.
THE COURT: Ms. Geragos, you may proceed when ready.
BY MS. GERAGOS:
MS. GERAGOS: Good afternoon, Jane.
MS. GERAGOS: We talked about earlier this morning about your career before you met Mr. Combs, and we talked about content creation and how you were an influencer but you also did some modeling, right?
MS. GERAGOS: Can you explain what the modeling was? What was that career?
JANE: Early on I did some print modeling, which was in magazines, more like swimwear modeling. I did music videos. I was on commercials. I did a couple movies. This was just like early on. So just various like entertainment modeling jobs.
MS. GERAGOS: I want to bring up just for the witness and the parties Defense Exhibit 3007. We could put both pages so that the witness can review it. Let me know when to go to the next page.
MS. GERAGOS: Are these text messages between you and Mr. Combs from October 29 to about November 1 of 2021?
MS. GERAGOS: Do you recognize them to be messages between the two of you?
MS. GERAGOS: Your Honor, we move to admit 3007 under seal.
MS. COMEY: No objection.
THE COURT: 3007 will be an admitted under seal.
(Defendant's Exhibit 3007 under seal received in evidence)
MS. GERAGOS: Could we just for the jury publish these please. If we could quickly go to pages 10 and 11. The next page. Next page. Next page. Next one. And then 14 and 15 side by side.
MS. GERAGOS: I realize this is around Halloween, right?
MS. GERAGOS: Are you dressed up in a Halloween costume?
MS. GERAGOS: Are these examples of modeling photos?
MS. GERAGOS: But would you do a shoot for the party because if you go to the next page --
JANE: Yes. So this was at a Halloween event, and this was my costume. And then I went to a Halloween event and took some photos there too. These are just like candid iPhone photos.
MS. GERAGOS: Okay, so these are not modeling shoots?
MS. GERAGOS: These are just your Halloween shots, basically?
MS. GERAGOS: Okay, from your iPhone.
MS. GERAGOS: So if could we go to page 5 of this exhibit and put 4 and 5 next to each other.
MS. GERAGOS: You guys are discussing here. You say, My spot is empty. Just chill baby whatever. Just want to see you, so LMK, which is let me know, right?
MS. GERAGOS: How to drive soon?
MS. GERAGOS: There are some audio messages. And on the next page, on page 5, he says, What you trying to do pick it up. What you trying to do?
You say, whatever baby I'm yours.
He said, I had a rough day. I want you to lead. Can you lead tonight, right?
MS. GERAGOS: Can you go to the next page?
MS. GERAGOS: He says, Can you lead me? I want to be led.
You say, of course baby. Okay let's freshen up get cute for each other. Have a little drink and see where the vibe takes us, right?
MS. GERAGOS: And what do you say after that?
MS. GERAGOS: With a heart face emoji, is that what it looks like right after?
MS. GERAGOS: And he says on the next page, Don't feel like being around people, right?
MS. GERAGOS: And you say, okay baby about to head your way. 24 minutes?
MS. GERAGOS: And do you remember that after these messages, you did a hotel night with Mr. Combs?
MS. GERAGOS: If we could go to F-101, which is in evidence, page 10 and 11 next to each other.
MS. GERAGOS: These are messages between you and Kabrale?
MS. GERAGOS: And in these messages, which appear to be a day after and UTC time, October 30, you're reaching out to him saying, Baby send me any jerk off videos. I'm touching myself RN, right?
MS. GERAGOS: Is this -- if you recall, is this when you're with Mr. Combs at his home? Are you at a hotel, and you're reaching out to him? How does this come about?
JANE: Yes. I'm in a hotel with Mr. Combs partying. We were probably under the influence, and he's asking me to reach out to Kabrale to send explicit videos or photos, and so I'm doing an outreach right here, just doing that right here.
MS. GERAGOS: And you're telling Kabrale, I'm touching myself right now, right?
MS. GERAGOS: And then you say, I love a rock hard cock jerking to me anything that's in your phone, right?
MS. GERAGOS: If we could take that down and jump to page 23. I just meant zoom out. Sorry. I'll get better at that terminology.
MS. GERAGOS: And this is a couple days afterwards, like three days afterwards on November 2nd. He says, Yes please do beautiful I can't wait to meet you. I really enjoyed your energy on FT, right?
MS. GERAGOS: That's the FaceTime that you spoke about on direct examination?
MS. GERAGOS: And then you say -- you loved the two messages, and you say, We're off to a good start then. LOL. Okay I'll be in touch soon, right?
MS. GERAGOS: Ant then he says, Okay love keep me updated. And then it's about five days -- four days later, I apologize, that you reach out to him again, right?
MS. GERAGOS: And that is Mr. Combs' birthday is November 4?
MS. GERAGOS: So it's like two days after his birthday that you reach out to him again?
MS. GERAGOS: So if we could bring up -- and if we could go to the next page, sorry. Continue. We could have the two side by side 24 and 25? Thank you.
MS. GERAGOS: He says -- or you say, Okay I might have a little time off if you want to spontaneously come tomorrow night or Monday, I'll organize, right?
MS. GERAGOS: And you say, But we'll talk then before then once I see it's even possible, right?
MS. GERAGOS: So here you are planning something for a few days in advance, right?
MS. GERAGOS: And was that for a planned hotel night that was going to take place in a few days?
JANE: These messages kind of give me that I'm with Mr. Combs, and we're trying to figure out how we're going to see Kabrale and when we will see him.
MS. GERAGOS: You remember doing a hotel night October 30, a couple days before that, right?
MS. GERAGOS: And then you're with him in between, you're with him then a couple days after his birthday?
MS. GERAGOS: And then you plan -- you think that then you're planning a hotel night for a few days from then, right?
MS. GERAGOS: Okay.
MS. GERAGOS: Could we bring up Defense Exhibit 3011 for the witness and the parties only. And we could have them side by side so she can review them.
I actually move this in because it's a parallel exhibit, unless Ms. Comey --
MS. COMEY: No objection so long as it's under seal, your Honor.
MS. GERAGOS: It's under seal, of course.
THE COURT: Defense Exhibit 3011 will be admitted under seal.
(Defendant's Exhibit 3011 under seal received in evidence)
MS. GERAGOS: This can be published to the jury.
MS. GERAGOS: These messages here are November 5, 2021, right?
MS. GERAGOS: Same date as we were just looking at?
MS. GERAGOS: So you sent him some emojis there on the top left and say, Thinking of you.
He says, I have a plan. Sunday fun day. Fly ATL in. Paul. Freak fest birthday celebration, right?
MS. GERAGOS: And you respond, Hey birthday boy. Sounds like a bloody good time, right?
MS. GERAGOS: You say, Because I'm still going to be bleeding, right?
MS. GERAGOS: He says, Okay think what day works for you, right?
MS. GERAGOS: Because I want to see that ATL with you, right?
MS. GERAGOS: And ATL is Kabrale?
MS. GERAGOS: And he says, Have you been thinking about it?
MS. GERAGOS: What do you respond with?
JANE: I say, Maybe midweek baby. A little bit, what am I going to do with all that dick LOL. What you wanna see baby.
MS. GERAGOS: Is that an emoji right next to what you want to see baby?
MS. GERAGOS: It's a smirk emoji like you want him to tell you what he wants, right?
MS. GERAGOS: And he says, So many things?
MS. GERAGOS: If we could go to the next one. Page. Okay.
MS. GERAGOS: And if we look at page 4, you say, You can only see those videos when you're with me, and then you send him a porn video, right?
MS. GERAGOS: Is that Kabrale in the porn video?
MS. GERAGOS: Is that -- and this is an example of Blocked, the porn that you were watching --
MS. GERAGOS: -- of Kabrale?
And he says, Girl I ask you have you been thinking about it? And send me a picture so I can envision you, right?
MS. GERAGOS: Okay. if we could go to the next two pages.
MS. GERAGOS: And he says, You haven't thought about it?
And what do you say?
JANE: I have. Curious what that would feel like super deep inside me. Pulling in and out of my tight walls and hitting past my G spot.
MS. GERAGOS: And he says, Damn. I want to see it. How you handle.
What does how you handle means?
MS. GERAGOS: And then you respond to him, You'll be right there pouring the warm oil on my clit watching go slowly deep and out.
So here you say warm oil. Can you explain for the jury why warm oil? What is the process of the baby oil at the hotel nights or any night with Mr. Combs?
JANE: Well, here I'm following his lead where he says I want you to lead, so I'm fantasy talking about the things that he likes, and one of them being about this oil which he prefers like hot, warm oil. Like in the bathtub it like gets warm, and then we take it out and we just like pour it all over each other's body or he likes it when I pour it all over my body or an entertainer's body.
MS. GERAGOS: And then the next page on page 6, you continue with six more texts, right?
MS. GERAGOS: And about halfway down you say, Jerking Paul hovering over me while he waits his turn, right?
MS. GERAGOS: When you say he waits his turn, is that reference to Kabrale?
MS. GERAGOS: So what you're saying to Mr. Combs in this exchange is you're giving him the fantasy talk that you believe he liked, right?
MS. GERAGOS: And you're telling him the fantasy talk is that you would have Kabrale, and then Paul would have to wait his turn, right?
MS. GERAGOS: And -- and then if we could look at -- we could take this down now -- Defense Exhibit 3014-R. If the witness could review that, please.
MS. GERAGOS: And tell me when to move on to the next page.
MS. GERAGOS: Have you reviewed it?
MS. GERAGOS: Is this a message between you and Mr. Combs on November 8 of 2021?
MS. GERAGOS: We move to admit 3014-R under seal, your Honor.
MS. COMEY: No objection.
THE COURT: So 3014-R will be admitted.
(Defendant's Exhibit 3014-R under seal received in evidence)
MS. GERAGOS: This is a message couple days after, right?
MS. GERAGOS: And you text him. This can be published to the jury.
Night baby hope you're feeling a little better. Sweet dreams, right?
MS. GERAGOS: He says, Good morning.
You say, Good morning handsome. I just looked at my phone. You dropped off your child and now heading home to get ready for my day how you feeling baby, right?
MS. GERAGOS: Next page.
Then you're saying -- he says, I'm good baby. How are you.
You say, Good babe. Just gonna shoot a little today, right?
MS. GERAGOS: What is that about, what is that shoot?
JANE: I was shooting for one of the -- this post was a necklace post. I had to shoot a quick photo with a necklace.
MS. GERAGOS: Okay. That was a paid spot?
MS. GERAGOS: Okay.
MS. GERAGOS: If we could go to the next page.
MS. GERAGOS: And then you just you're sending him photos, right?
MS. GERAGOS: You go to the next page. All right. And he loves the photos, right?
MS. GERAGOS: And he sends like the heart face there?
MS. GERAGOS: And then he sends you a message, I want to eat your pussy.
And he says, How far from my house, right?
MS. GERAGOS: And then you send two emojis, right? What are those emojis?
MS. GERAGOS: What is that connotation?
MS. GERAGOS: If we could go to the next page.
MS. GERAGOS: And then on page 8, you say, Wanna come over my place after 4:00 p.m., right?
MS. GERAGOS: With a smirk emoji?
MS. GERAGOS: And he says, I can't. I have studio, right?
MS. GERAGOS: You say, Okay baby I'm free after 3 so tell me. I want to sit on your face, right?
MS. GERAGOS: Go to the next page. If we go now to --
MS. GERAGOS: You say at the bottom of page 9, what you want to do baby.
Come by -- he says, Come by if you want.
You say, Okay baby 5-ish, okay?
MS. GERAGOS: This voice note at of November 8, 2021 at 11:46 p.m. we would like to admit under 3041-A under seal and play that?
MS. COMEY: I'm sorry, your Honor. I don't think I had the chance to listen to that.
MS. GERAGOS: We can move on.
MS. GERAGOS: You said, Baby LOL I said I'm free after 3 so you tell me, right?
MS. GERAGOS: Go to the next page.
MS. GERAGOS: You say, I'm getting ready to head your way, right?
MS. GERAGOS: He says, I got to go somewhere at 8.
You say, Okay I'll stop by and hug in squeeze you, right?
MS. GERAGOS: And it's after this that you have another hotel night. Does that sound right?
MS. GERAGOS: Why don't we go Defense Exhibit 3016 for the witness, just page 1 right now. And then if we skip ahead to page 3 so she can review it. And then next page. Next page. Next page.
MS. GERAGOS: Have you reviewed these messages with the government? Are you familiar with them?
MS. GERAGOS: We move to admit 3016 under seal, your Honor.
MS. COMEY: No objection.
THE COURT: Exhibit 3016 will be admitted under seal.
(Defendant's Exhibit 3016 under seal received in evidence)
MS. GERAGOS: Could we go to page 2. This is November 9, right?
MS. GERAGOS: And you write, Driving and just thinking of you, right?
MS. GERAGOS: And what do you say?
MS. GERAGOS: And he responds, What you wanna do? Be explicit. And then he has an emoji there, right?
MS. GERAGOS: What does that emoji mean to you?
MS. GERAGOS: And what is your response?
JANE: In response to his be explicit, I say, I wanna suck Paul's dick while you give me that strong stroke game.
MS. GERAGOS: When he asks and says be explicit, you respond about Paul, right?
MS. GERAGOS: Okay. And go to the next. And then what do you say next?
MS. GERAGOS: Why don't we put them side by side so we can see that it's a continuation, those two pages.
MS. GERAGOS: So at 4:19 a.m. UTC time you say that, and then -- and then one minute later, you continue, right?
MS. GERAGOS: So in playing in this fantasy talk that I know that my lover likes, I then begin to say, I wanna suck Paul's dick while you give me that strong stroke game.
I say, I loved you rubbed oil all over my legs my body kissed me and put it deep in me with my legs back.
When you look me in my eyes giving me every hard inch so wet, like that's the only last dick I'm supposed to have, stroking a hard dick next to me while a hard one is inside me. And then I was thinking a heart, another emoji and water.
MS. GERAGOS: So the white emoji is thinking?
MS. GERAGOS: And then the water is that supposed to be a sexual emoji?
MS. GERAGOS: Okay.
And he responds with, Whew, right?
MS. GERAGOS: And so he asks you to be explicit. You give him the fantasy talk that he likes. And he says whew?
MS. GERAGOS: Okay. So next page.
And you send him a photo. And then on page 5, you say, My daddy left me all alone come and keep me company. The store closest at 12 so just in case you need me to go LMK, let me know, right?
MS. GERAGOS: LOL. Me miss you.
He responds, what are you gonna get?
MS. GERAGOS: And what do you say?
MS. GERAGOS: So this is a store you could get lingerie, the outfits that he likes, right?
MS. GERAGOS: If we could go next two pages. Go ahead. Next two pages. All right.
MS. GERAGOS: So then on page 8, you say, What do you wanna do, right?
MS. GERAGOS: Right.
And then you say -- what do you say in response?
JANE: I said, Spend time with my favorite person. I send an attachment. And I said, These are my fav.
And I said, What do YOU wanna do?
MS. GERAGOS: What does he respond with?
MS. GERAGOS: So he asks you, What do you want to do?
You respond with what you -- you respond that you want to spend time with your favorite person. I assume that's Mr. Combs?
MS. GERAGOS: And then you say, What do YOU want to do?
And he responds with, Want me and Paul to stop by, right?
MS. GERAGOS: And then the next page there's an -- I'm not sure what that is. What is that?
MS. GERAGOS: And then you say, I don't have all the things you like here. More than welcome to come baby, right?
MS. GERAGOS: And he says, So just us?
MS. GERAGOS: And then the next page.
MS. GERAGOS: He says, Wanna meet at my house?
And you say, Sure baby when.
And he says, I can't have Paul at my house, right?
MS. GERAGOS: And he would tell you that he can't have any of the entertainers at his house, right?
MS. GERAGOS: At his house -- at any house he has, there's a house manager, right?
MS. GERAGOS: There's housekeepers. Sometimes his employees are there, right?
MS. GERAGOS: And his -- sometimes his children could be there?
MS. GERAGOS: And his bedroom is not really set up for the privacy of having an entertainer there, right?
MS. GERAGOS: And so it's not -- his bedroom is not exactly isolated for that, right?
MS. GERAGOS: So he says, I can't have Paul at my house.
And you say, Yes, we know baby. I don't mind my place I just didn't grab a few things from the store that you like, right?
MS. GERAGOS: Like your drinks and stuff. I have oils. Normally I have that, right?
MS. GERAGOS: And I think when we had looked at a lot of these messages on direct examination, you testified that you knew he would like the fantasy talk that he said. You knew it would turn him on, right?
MS. GERAGOS: And you realized that with Paul there, this was becoming the dynamic of your relationship, right?
JANE: Yes, as you can see here, we're talking about wanting to see each other and the option that he's giving me is him and Paul.
MS. GERAGOS: And you say, Sure baby, right?
JANE: Because that was the only option I was given, and I wanted to see my lover and so I'm accepting that.
MS. GERAGOS: And you had said -- this was -- he said, What do you want to do? You said you wanted to see him. And then you asked him, What do YOU, in all caps, want to do, right? And that was the option that he said when you said What do YOU want to do, right? We could go back, right?
MS. GERAGOS: Why don't we go back. If we look at page 8.
JANE: He says, What you wanna do?
I say, Spend time with my favorite person, which is him. And then I send an attachment. I say, These are my fav.
And then I say, What do you want to do? And he gives me the option of Want me and Paul to stop by. That was my option.
MS. GERAGOS: That was an option, and that was a question that he posed, right?
MS. GERAGOS: Okay. If we could bring up Defense Exhibit 3018-R. And for your information, this is the corresponding exhibit of Government Exhibit A-1046 and A-1047. If we could show this to the witness.
And I would move to admit this, your Honor, because I have an agreement with the --
MS. COMEY: No objection, so long as the redaction I requested on page 16 is applied.
MS. GERAGOS: Yes. That's why it's 3018-R.
THE COURT: Has this been properly redacted?
MS. COMEY: I think it needs to be under seal, your Honor, and I think even the sealed version I have requested a redaction on page 16.
MS. GERAGOS: That's exactly right. If you look, your Honor, page 16 has the requested and agreed upon redaction.
THE COURT: 3018-R will be admitted under seal.
(Defendant's Exhibit 3018-R received in evidence)
MS. GERAGOS: Jane, if you could look at page 2. We could put 2 and 3 next to each other.
He says, If you could do something freak nasty today, what would it be? Are you in the mood, right?
MS. GERAGOS: And you respond by saying, LOL. Is that the smirk emoji?
MS. GERAGOS: Can you explain the smirk emoji?
MS. GERAGOS: Is it flirtatious?
MS. GERAGOS: Okay. And you say, Put something sexy on just to have fun with you baby and I'm always in the mood, right?
MS. GERAGOS: And he says, Just me?
MS. GERAGOS: And then it goes the next page, right?
And you love it. And you say, Yes... right?
MS. GERAGOS: And he says, You can't handle no more with question marks and laughing emojis, right?
MS. GERAGOS: And those are says it joking, You can't handle no more, right?
MS. GERAGOS: And you respond about 20 seconds later, I was just going to add unless you wanna play, right?
MS. GERAGOS: And he says, I have had so much sex that it would have to be some freak shit, but you would have to want it too. Maybe you need a break, right?
MS. GERAGOS: So his options are, I've had so much sex it would have to be some freak shit, but you would have to want it too, right?
JANE: The option he's giving me here is that he's asking me if I'm in the mood, what kind of mood you in, you can't handle no more, trying to encourage and insinuate for me to have sex with someone else.
MS. GERAGOS: And then he says, Maybe you need a break?
JANE: That's more of like a tease just to kind of tease me and taunt me like as if I can't keep performing. And here I am in 2021 really madly in love and wanting to please him, appease him, and just saying like I'm in great spirits, like no worries, yes, I'm all good. So I'm agreeable here.
MS. GERAGOS: You're agreeable, and you're telling him, I'm just fine baby?
MS. GERAGOS: And you -- at that, you know, at that time you really loved Mr. Combs, and you wanted to do what he wanted to do, right?
MS. GERAGOS: And so here, instead of saying, I need a break, you say I'm just fine baby?
MS. GERAGOS: Even though he says maybe you need a break, right?
JANE: Even though he says I need a break, the undertone of that is I can't handle any more, kind of teasing and taunting me to have one of these nights.
MS. GERAGOS: And you see the teasing up above almost with the crying laughing emojis, right?
MS. GERAGOS: And you respond to that -- but he had an iPhone, right?
MS. GERAGOS: So you put the laughing -- you react with laughter to his laughing emojis?
MS. GERAGOS: Okay. So you guys are teasing and playing here with each other?
MS. GERAGOS: If we could go to page 4.
MS. GERAGOS: And you say -- after you said, I'm just fine baby, what do you say to him?
MS. GERAGOS: Yes.
MS. GERAGOS: With the kiss emoji, exactly.
MS. GERAGOS: What does he say?
JANE: He says, I want it to come from you LOL. To be honest, I may be talking shit. LOL. I don't know what I want to do. I'm lost in the sauce. I need guidance.
MS. GERAGOS: And you laugh at that response from him, right?
MS. GERAGOS: And then you loved I need guidance, right?
MS. GERAGOS: And what do you write next?
JANE: I start to pick up on that cue of I need guidance, and he wants me to kind of start this turn on scenario. So I start to say, Want to see me suck some hard dick in the hotel room. I can shower and get ready to go to the store if you want some fresh outfits.
MS. GERAGOS: And the next page?
JANE: I say, You know I love fucking you all day. You had me coming so good all day and night until dawn.
MS. GERAGOS: And he says, I need something exciting. I'm jaded LOL, right?
MS. GERAGOS: And you laugh at that?
MS. GERAGOS: And then you send some laughing emojis, and say, Oh wee, now we've seen the best, it's like ... LOL, right?
MS. GERAGOS: And go to next page.
MS. GERAGOS: And then you say, Well, ATL is a treat for when album is finished. Paul? You want to invite a girl. Let's play we can do whatever. Wanna peak into a sex party LOL, right?
MS. GERAGOS: So have you and him been talking about how Kabrale is the treat for when he's done with his album?
MS. GERAGOS: Is that something you would speak about during the nights with just you and him?
MS. GERAGOS: Do you have an independent recollection, or you don't?
MS. GERAGOS: You write, Well, ATL is the treat for when album is finished, right?
MS. GERAGOS: So do you have an independent recollection of what that means?
MS. GERAGOS: That's fine.
So do you remember then you say, Paul.. question mark, meaning Paul, the entertainer, right?
MS. GERAGOS: Then you say, You want to invite a girl? Let's play. We can do whatever. Let's peak into a sex party, right?
MS. GERAGOS: Next page.
MS. GERAGOS: Then you send -- is that a GIF, a meme, or what is that?
MS. GERAGOS: And then you say, I'm going to start drinking, with some playful emojis, right?
MS. GERAGOS: And then he says, LOL.
And you say I'm gonna shower in this other bathroom baby, right?
JANE: I just want to clarify when I said, Want to peak into a sex party, I remember at this point Sean was telling me about sex parties and how we should go to one. So that was just something I was giving him options, options that he's already explored or was telling me about.
MS. GERAGOS: So he had brought this up with you previously?
MS. GERAGOS: And then you are saying it back to him as an option for something you guys can do, right?
MS. GERAGOS: And in response in fantasy talk essentially? Or is this an option -- are you actually wanting to go to a sex party or is this fantasy talk?
JANE: I am under the guidance of -- I think if we scroll back up, he's asking me to guide him, lead him.
MS. GERAGOS: Why don't we go to page 4 and 5.
JANE: I'm just in response to his I need guidance, I'm giving him an array of options that I know that he would want to hear or would like to do, and these things are, as you know, things that I would have preferred not to do, but I know my lover really liked to do, so I'm just saying these things to give him options from his I need guidance text.
MS. GERAGOS: Do you remember after this -- after these messages, you do have a hotel night?
MS. GERAGOS: Okay. If we could go ahead to page 19.
MS. GERAGOS: You say -- this is a few days ahead on November 15 at 1:58. Hey, my love I'm home. I had an incredible time with you, with a heart emoji, right?
MS. GERAGOS: My baby have a beautiful day in Miami, right?
MS. GERAGOS: He responds with a heart emoji as well?
MS. GERAGOS: Why is the "my baby" in quotes?
MS. GERAGOS: At all times or during these nights or when?
JANE: Mmm, I remember this night the way I was saying like, my baby, my baby. Like he really liked the way I said that.
MS. GERAGOS: Okay. All right.
If we could go to Defense Exhibit 3023-R, which is the corresponding exhibit to Government Exhibit A-104-10, A-104-11 and A-104-12, which is admitted. This is redacted, your Honor. By pre-agreement of the parties, we'd like to move to admit this under seal.
MS. COMEY: No objection.
THE COURT: What's the number?
MS. GERAGOS: 3023-R.
THE COURT: All right. The exhibit will be admitted under seal.
(Defendant's Exhibit 3023-R under seal received in evidence)
MS. GERAGOS: This is a few days later --
MS. GERAGOS: This can be published to the jury. Sorry.
MS. GERAGOS: This is a few days later, November 22, 2021?
MS. GERAGOS: If you go to page 6, all right. You say, My love I just looked at some flights I can arrive tomorrow night at 8:30 and leave tomorrow morning Thursday in time for the holiday. Text me when you wake up. Let me know what you think.
MS. GERAGOS: It is zoomed in?
MS. GERAGOS: Take as much time as you need. We'll go through them.
MS. GERAGOS: I'd like to now admit with the agreement of the government 3023-A, which is the voice note at 10:19 a.m. UTC time?
MS. COMEY: No objection.
MS. GERAGOS: Under seal.
THE COURT: It will be admitted under seal.
MS. GERAGOS: Actually, your Honor, I don't think that this one would have to be under seal, now that I'm thinking about it.
THE COURT: Any objection to it not being admitted under seal?
MS. COMEY: If this is the voice note sent by Mr. Combs, no objection.
THE COURT: Admitted.
(Defendant's Exhibit 3023-A received in evidence)
MS. GERAGOS: Can we play voice note 3023-A, which is his voice notes?
(Audio played)
MS. GERAGOS: Then you -- that's at 10:19 a.m. you see that audio message?
MS. GERAGOS: And if we go to your audio message here, which is 10:52:16 a.m., which is 3023-B which we would like to admit under seal.
MS. COMEY: No objection.
THE COURT: This exhibit will be admitted under seal.
(Defendant's Exhibit 3023-B under seal received in evidence)
(Audio played)
MS. GERAGOS: If we could go to the next page, to page 8. What is page 8? Can you put 8 and 9 next to each other?
You send another audio message at 10:53, which is 3023-C, which we move to admit under seal.
MS. COMEY: No objection.
THE COURT: It will be admitted under seal.
(Defendant's Exhibit 3023-R under seal received in evidence)
MS. GERAGOS: Can we play that, please.
(Audio played)
MS. GERAGOS: In these three voice notes -- you can zoom out -- he says, You always wanted to set some shit up. The last vision we had, it was Don and ATL. See you put it together baby, right?
Do you remember listening to that?
MS. GERAGOS: And you said, That's definitely super easy for me to set up for sure, but I'm confused because didn't you say you wanted to save that for the grand finale, and this was going to be a showstopper situation, right?
JANE: Yes, I'm trying to make excuses to get out of this thing that he's encouraging for me to set up.
MS. GERAGOS: You said, It's supposed to be the big grand finale, the big boom, just fireworks, showstopper situation, right?
JANE: Yes. Prior to this, I do remember having a hotel night and how he said that he wanted to see Don and Sly or whoever, and that's what he wanted to see, like two of the main guys. And so I'm feeding into what he wants to hear here, and I'm hearing him kind of say like I want to see you set that up. And --
MS. GERAGOS: But he says -- you agree with me that he says, You always wanted to set some shit up for tomorrow night. The last vision we had was it was Don and ATL, right? That's what he said in his voice mail that we listened to?
JANE: Yes, but the undertone of that is -- I hear these things entirely differently, but yes that is what he said in the voicemail, and that is what I said in the voicemail, but I just know the undertones here.
MS. GERAGOS: Okay. And then if we go ahead to page 10 and 11. All right.
So we looked at page 11 on direct examination, do you remember that? Let's sit this one out. Have a beautiful day? I'm definitely feeling some type of way. Home girls posting being there with you, so I genuinely thought you were just missing me. I thought on a quick one to two day trip you wanted to see me, but you wanted a Don and Sly moment in that time hotel vibes, right?
MS. GERAGOS: So the government went over the other text message with you in their preparation with you?
MS. GERAGOS: They didn't show you the preceding text messages?
MS. GERAGOS: They showed you starting at around this section, right?
MS. GERAGOS: So they never showed for you the voicemails before when you guys were talking when Mr. Combs said, You always wanted to set some shit up, and the last vision we had was Don and ATL, right?
MS. GERAGOS: Understood. Let me ask you some questions about this. You said, Home girls posting being there with you, right?
MS. GERAGOS: Posting, does that mean on Instagram?
MS. GERAGOS: And yesterday you had said -- we had read a message, I should say, where you were saying you didn't have any post-able from your relationship with him after three and a half years, right?
MS. GERAGOS: And that was upsetting to you because you wanted to be able to post some things on Instagram, right?
JANE: It was upsetting to me that I had endured the majority of the pressure of this relationship, and that when I looked up, I had just been in a chaotic whirlwind of a dark life that I wasn't proud of, and I just look up and there's like I did nothing with my life in those years, but I could see that he offered really beautiful other things to the other girls that they were able to share, et cetera, et cetera, so that's what I meant there.
MS. GERAGOS: So here when you're referring to home girls posting being there with you, that's referring to another girl he's with posting on Instagram or another social media site being with him, right?
JANE: This here is upsetting for me because he's reaching out to me specifically talking about a fantasy or specifically initiating conversation regarding me having sex with two men. And so I'm here thinking assuming that he's just genuinely thinking about me, but it's about these men. And then I look online, and I see that he's spending quality time with another girl, the things that I would have preferred that he messaged me about, but this is -- this was the dynamic, so here this is where the frustration starts because I'm being woken up being -- talking about men and then --
MS. GERAGOS: Another girl is posting being with him?
MS. GERAGOS: And you hadn't gotten on the plane yet, right?
MS. GERAGOS: You were still in your bed in Los Angeles?
MS. GERAGOS: And then you said, Let's sit this one out because you were upset, right? Have a beautiful day, right?
MS. GERAGOS: I'm definitely feeling some type of way?
MS. GERAGOS: Because -- and then the next message that he reads and receives from you is: Home girl is posting being there with you, right?
MS. GERAGOS: So I genuinely thought you were just missing me, is that in reference to the voice notes that we just heard?
MS. GERAGOS: Okay. And then you say, I thought on a quick one to two day trip, you wanted to see me, but you wanted Don and Sly moment within that time hotel vibes, right?
MS. GERAGOS: Let's go to the next page.
And then you say, and you hadn't gotten on the plane yet, right? And you say, So I come in and do that while you go back to being laid up and boo'd for days. I see what I'm turning into in your eyes while home girl is literally ran through and fucks your friends behind your back. And did you get her a fucking Chanel bag on top of that. LOL. Crazy. I don't like how you're treating me and what I'm seeing. I need a breather and a break from you. This doesn't make me feel good at all. Your true intentions with me are in plain sight. Hope you had a great Thanksgiving, right?
MS. GERAGOS: And you say, Don't say you fucking miss me and you're bored over there. Just don't say shit to me at all. You don't deserve me, right?
MS. GERAGOS: Let's unpack that. You are saying, So I come in, meaning if you were to travel there, he'd go back to being laid up with the girl for days, right?
JANE: Just re-wind a little bit. So I mean to say, So I come in, meaning and do that, meaning hotel nights. And then while you go back, meaning after that, you go back to being laid up, which means spending quality time and boo'd up for days with another girl he's dating and giving this girl quality time, and not me after I've done a hotel night with strangers.
MS. GERAGOS: And then you say, And did you get her a fucking Chanel bag on top of that? LOL. Crazy.
JANE: Yes. My misdirected anger towards the women when my anger is truly for him and how mistreated I feel in this relationship.
MS. GERAGOS: And are you mistreated because this other person got a Chanel bag? Why are you saying Chanel bag?
JANE: I'm being mistreated because the pressure that my partner was putting on me was for me to have sex with strangers, and when he leaves me, he goes and spends quality time and shopping and dining, et cetera, et cetera with the others.
MS. GERAGOS: Did this person post a Chanel bag on their stories --
MS. GERAGOS: -- on Instagram?
And you didn't get the Chanel bag. This other person was getting a Chanel bag, right?
MS. GERAGOS: You got a Van Cleef necklace, right?
MS. GERAGOS: You got a Bottega bag, right?
JANE: After three and a half years, I really don't think I garnered much from this relationship.
MS. GERAGOS: What is a Bottega bag?
MS. GERAGOS: I actually don't. What is a Bottega bag?
MS. GERAGOS: How much do Bottega bags run?
THE COURT: Jane, I'm going to ask you to just respond to Ms. Geragos' questions and your lawyer can follow it up. A. Okay. Thank you.
MS. GERAGOS: I'm asking roughly how much a Bottega bag costs?
MS. GERAGOS: Okay. And a Chanel bag, how much does a Chanel bag cost?
MS. GERAGOS: And after these text messages, you made the decision not to get on a plane?
MS. GERAGOS: Okay. Do you recall if right after these text messages you went to Miami?
MS. GERAGOS: You don't have an independent recollection either way?
JANE: If you can provide me something to jog my memory back. If I did or not, I'm not really sure.
MS. GERAGOS: Let's look at the next page.
You say, Ain't nobody just come to work out. She's been there for days and posting the studio. Stop lying. Funny thing is I don't even care, I don't even fucking care who you lay up with, right?
MS. GERAGOS: And if we go to the next page.
And then we could go right here and read those messages.
MS. GERAGOS: You're saying, You been saying you miss me and want to see me, but you're lying. You just want the hotel shit, right?
MS. GERAGOS: And then at the bottom, you say, Bitch is super ran through and fucks your friends. You think I care about this. Off this, right?
MS. GERAGOS: And all he responds is, Have a blessed day, right?
MS. GERAGOS: And good-bye right?
MS. GERAGOS: Of course. Let's take a break.
THE COURT: Thank you.
Members of the jury, we'll take a break and be back in ten minutes.
All rise for the jury.
(Continued on next page)
(Jury and witness not present)
THE COURT: Please be seated.
Anything to address during the break?
MS. COMEY: No, your Honor.
THE COURT: Ms. Geragos.
MS. GERAGOS: No.
THE COURT: All right. Come back in ten.
(Recess)
THE COURT: Let's bring in the witness and we will then bring in our jury.
(Continued on next page)
(Witness present; jury present)
THE COURT: Members of the jury, welcome back. Just so you know, in our effort to always be streamlining the proceedings, we're going to be ending earlier today, so we will be ending around 3:00 p.m. Just wanted to let you know that.
MS. GERAGOS: We'll end the day with some levity, your Honor.
BY MS. GERAGOS:
MS. GERAGOS: Jane, are you ready to proceed?
MS. GERAGOS: No problem.
Right before our break, you said: This was a chaotic whirlwind of a dark life I wasn't proud of. I just look up and there's nothing else I did with my life in these years, but he offered beautiful things to the other girls that they were able to share. Do you remember that?
MS. GERAGOS: And you said that quality time is shopping and dining, right?
MS. GERAGOS: Okay. You just testified this morning about multiple businesses that you were running during your relationship with him, right?
MS. GERAGOS: You had a swimsuit brand?
MS. GERAGOS: And you got to sell swimsuits and model for your swimsuit brand?
MS. GERAGOS: And you also had a dress brand, right?
MS. GERAGOS: You were an entrepreneur during your relationship with him, right?
MS. GERAGOS: And you still are, right?
MS. GERAGOS: And you also talked about the house that you live in now, right?
MS. GERAGOS: And in that house, you've lived there for how long?
MS. GERAGOS: Almost three years, right?
MS. GERAGOS: And before your house, you were living in an apartment?
MS. GERAGOS: And now you live in this home, right?
MS. GERAGOS: And how many square feet, if you know, is this home?
MS. GERAGOS: How big was your apartment beforehand?
MS. GERAGOS: So it's a significantly bigger home than the apartment beforehand, right?
MS. GERAGOS: Without telling me the location, it's in a nice area of Los Angeles, right?
MS. GERAGOS: And you're able to parent your child in this nice home, right?
MS. GERAGOS: And you're able to provide him -- her -- the child a large back yard, right?
MS. GERAGOS: And a big home for your child, right?
MS. GERAGOS: And that's important to you right?
MS. GERAGOS: And Mr. Combs, you testified, put $20,000 of an investment into your businesses, right?
MS. GERAGOS: And that was something that meant a lot to you, right?
MS. GERAGOS: Because you wanted to build your dress business?
MS. GERAGOS: You were living in L.A. for a portion of your relationship with him?
MS. GERAGOS: And you traveled to New York City also with him?
MS. GERAGOS: Okay. And you also did get a lot of quality time with him at his homes, right?
MS. GERAGOS: And you really appreciated and loved that quality time, right?
MS. GERAGOS: And that was the time you craved that you had with him?
MS. GERAGOS: And that was the time you looked forward to the most?
MS. GERAGOS: Because that's when you got to be close to your partner?
MS. GERAGOS: And close to your lover?
MS. GERAGOS: And that was really, really important to you?
MS. GERAGOS: Okay. And so when you say that you looked up and there's nothing I did with my life in these years, you had two businesses, that one is now profitable, right?
JANE: I would say that had I not dove headstrong on this relationship, I probably would have been a bit more successful in that time frame, but that's neither here nor there. Umm -- so that's my answer to that.
MS. GERAGOS: Okay. I want to go ahead to Defense Exhibit 3033, which is the corresponding exhibit, your Honor, to A-104-16 and A-104-17, which is admitted. This is a defense exhibit, and I believe Ms. Comey does not have an objection to it.
MS. COMEY: That's correct, your Honor. I was checking my list. No objection.
THE COURT: All right.
MS. GERAGOS: Under seal.
THE COURT: Defense Exhibit 3033 will be admitted under seal.
(Defendant's Exhibit 3033 under seal received in evidence)
MS. GERAGOS: If we could publish this for the jury.
You could put pages side by side.
MS. GERAGOS: This is December 13, 2021, right?
MS. GERAGOS: So it's approximately a month after the text messages that we were looking at, right?
MS. GERAGOS: All right. And in these messages you send him, Night, my love. Sexy dreams with a kiss emoji, right?
MS. GERAGOS: And he sends you an emoji back?
MS. GERAGOS: OK. And you loved that emoji. And then what emojis do you send him?
MS. GERAGOS: OK. And what do the clouds indicate, if anything?
MS. GERAGOS: Okay. And then he says, I'm on my plane. You turn me the fuck out for real. When am I seeing you again? You got me fiending. I can't stop thinking about being nasty with you. If I could just be nasty every day, I would. Send me one of your fav videos. What have you been thinking about, right?
MS. GERAGOS: OK. And next page.
MS. GERAGOS: And he corrects himself and says, dick. LOL. And what do you respond with?
JANE: I say, mmm, daddy. Wish I was drinking your hard dick and sliding it up and down my wet clit and pussy, up and down, love when you deep stroke me, deep and slow. I never had a dick make me come as many times as you.
MS. GERAGOS: And he responds, Just landed in NYC, right?
MS. GERAGOS: What did you say?
JANE: I said, Right now, thinking about it, I could have my legs wide open for you every single day.
MS. GERAGOS: He says, When you going to bring that back to me? When am I going to see you again, right?
MS. GERAGOS: And you say, I don't have the videos, babe. You got to send me good ones, but I'm def remember everything, right?
MS. GERAGOS: So when he asks when you going to bring that back to me, what is your impression of what he means by that; is it you?
MS. GERAGOS: And when am I seeing you again, right?
MS. GERAGOS: So he's talking about you, right?
MS. GERAGOS: And your answer is: I don't have the videos, babe. You got to send me some good ones, but I def remember everything, right?
MS. GERAGOS: Is this in reference to a hotel night that you had with him just a couple days beforehand?
MS. GERAGOS: Okay. And so your response is about the videos, right?
MS. GERAGOS: That you guys take during that hotel night?
MS. GERAGOS: Because he wants to see them -- these are things that you would watch when you were together?
MS. GERAGOS: Can we go to 3 and 4.
MS. GERAGOS: And then you say, You tell me, baby, and glad my daddy landed safely. Ten wet strokes. I'm craving you too, right?
MS. GERAGOS: OK. And he says, when you free again? I want you now, right?
MS. GERAGOS: Okay. And he -- and you respond, You love it and you say, Maybe later this week. I want you always, right?
MS. GERAGOS: Okay. If we could go ahead to page 5 -- 5 and 6, I should say.
Without reading the -- I'll read the first text.
MS. GERAGOS: What is that first emoji? What -- can you explain those three emojis that we see?
JANE: Yes. It's like an emoji with a mind that's blown off and two monkey faces with the eyes covered.
MS. GERAGOS: And then you say, Nasty. And then the nickname of your true name, right?
MS. GERAGOS: And what do you say after that?
MS. GERAGOS: And then what do you say?
JANE: I want to get sexy and dress up for you, daddy. Mama needs to feel sexy. Sometimes I just like sitting next to you with some wine and take you all in with my eyes.
MS. GERAGOS: And he says, We don't have to be debaucherous, LOL. Right?
MS. GERAGOS: And you said on direct that debaucherous means -- is it something that you guys would talk about with respect to those nights, or that's how you would refer to it, is that right?
MS. GERAGOS: So you're saying, I want to get sexy and dress up for you. I need to make you make me feel sexy.
And he says, We don't have to be debaucherous, right?
MS. GERAGOS: So if we could go to pages -- let's go to the next two pages.
MS. GERAGOS: And you say -- you send him a selfie, right?
MS. GERAGOS: And you say, Everything about us turns me on, right?
MS. GERAGOS: And I -- he says, I can do all that, right?
MS. GERAGOS: And then what do you say?
JANE: I said: LOL, with a heart eyes and a kiss face. I've been having a little fantasy in my mind.
MS. GERAGOS: And he says: I even know how to make love without oil and outfits. Tell me please.
JANE: I say, Next time I see you, I want to wear something different. My lingerie and my hair. I want to be intoxicated with wine. That's when I feel my sexiest and have you watch me, my perfect man I ever wanted, with heart eye emojis, just looking fine for me.
MS. GERAGOS: And then he responds, Okay. Let's do it. I didn't know that. You don't have to do molly, right?
MS. GERAGOS: He says he didn't know that you -- that's when you feel your sexiest, right?
MS. GERAGOS: Okay. And you say, Can we have a night of love, right?
MS. GERAGOS: And love is capitalized. Why is the L in love capitalized?
MS. GERAGOS: Okay. Let's go to the next page.
MS. GERAGOS: And then he says, Of course, right?
MS. GERAGOS: And you say, Then we can get slutty the following day or so, LOL, with multiple L's, right?
MS. GERAGOS: So what does that mean?
JANE: That means, because I want to be fair, that typically he doesn't really want, like, the boring, romantic stuff. He wants the debaucherous stuff. So here, I'm kind of saying let's start it off with, like, wine and romance, like, sexy with my hair down, because he often preferred my hair in a ponytail, and I just wanted to wear my hair down for him. And then he says, of course. But then, I know my partner and what he likes and what he wants. Debauchery is what we nicknamed these nights so --
MS. GERAGOS: And that's why you say, Then we can get slutty the following day or so, LOL?
MS. GERAGOS: And you say, I want to be in a silk dress and heels, right?
MS. GERAGOS: And his response is, We don't have to go crazy for the rest of the year, right?
MS. GERAGOS: And that's his response. You send: We can get slutty following day or so, LOL, at 5:09 -- 5:00 p.m. and 09 seconds, and he sends that response pretty much immediately after, right?
MS. GERAGOS: And then you say, Even smelling you next to me turns me on, and you emphasize we don't have to go crazy for the rest of the year, right?
MS. GERAGOS: Can you explain for those of us who don't have iPhones what does the emphasis mean?
MS. GERAGOS: And then if we go up to page 10.
MS. GERAGOS: He says, Okay. Let's switch it up, right?
MS. GERAGOS: And you say, I will believe it when I see it, with a smirk, right?
MS. GERAGOS: And we've talked about the smirk; you've indicated that that means flirtation, right?
MS. GERAGOS: And then what do you say next?
MS. GERAGOS: And I love your intensity?
MS. GERAGOS: And then what do you say after that?
MS. GERAGOS: With a heart?
MS. GERAGOS: Okay. And he says: What do you mean -- or what you mean. Right?
JANE: Yes, because I'm sensing some sort of, like, rejection here, like, we don't have to go crazy for the rest of the year, after I kind of start talking about what I want. And I feel like he's feeling, like, some sort of rejection or something. And so I'm just --
MS. GERAGOS: Mr. McLeod, can you please put up page 10, please. Zoom out, please, so we can see the whole message.
MS. GERAGOS: He says: Okay. So let's switch it up. Right?
MS. GERAGOS: Is that when you're sensing rejection?
MS. GERAGOS: Why don't we put 9 and 10 back together? A. I'm sensing rejection under we don't have to go crazy for the rest of the year.
MS. GERAGOS: That's when you felt -- is that an example of an undertone that you felt?
MS. GERAGOS: When he says, We don't have to go crazy for the rest of the year?
MS. GERAGOS: And then you emphasize that, right?
MS. GERAGOS: And then he responds to your emphasis by saying: Okay. Let's switch it up, right?
MS. GERAGOS: And you say, I will believe it when I see it, with the flirtatious smirk emoji, right?
MS. GERAGOS: And you say: LOL, with a heart?
MS. GERAGOS: And then you tell him you love his intensity and it's okay with you, with a heart, right?
MS. GERAGOS: And he asks -- he's asking you -- you say: It's okay with me with a heart at 5:01:27 seconds p.m. And four seconds later he says: What you mean. Right?
MS. GERAGOS: He's asking you what you mean?
MS. GERAGOS: And what do you say in response?
JANE: I said: I love that we have that freedom with one another. It's a whole other level of eroticism.
MS. GERAGOS: Can we go to the next two pages.
MS. GERAGOS: He says, You don't think I can do it, LOL, right?
MS. GERAGOS: And then what do you say?
MS. GERAGOS: And can you read your next two messages?
JANE: Yes. No. I just know you, like, it -- and I don't mind it either, baby. I just want some sexy, romance time with my baby for a second.
MS. GERAGOS: And he says: Nope, I'm going to make you beg for debauchery. Right?
MS. GERAGOS: So he says: We don't have to do it. And then: You don't think I can. And you respond: No. I just know you like it, and I don't mind it either, baby. I just want some sexy, romance time with my baby for a second. Right?
MS. GERAGOS: And he -- he, reading what you just said, two seconds later, writes, Nope. I'm going to make you beg for debauchery, right?
MS. GERAGOS: And you put a laughing -- you laugh responding to that message?
MS. GERAGOS: Like you emphasized the laughter with the iPhone?
MS. GERAGOS: And you say: Okay, baby. Let's try this out and see how we feel. I love it all with you, right?
MS. GERAGOS: And then he says, Baby, you see how I've been holding back. I don't need no help?
MS. GERAGOS: And then if we could go to the next page.
MS. GERAGOS: And he says, Baby, I know how and love the times where it's just me and you, right?
MS. GERAGOS: And you love that message?
MS. GERAGOS: And he says, LOL?
MS. GERAGOS: And then you send him -- you send him some emojis. What do those emojis indicate?
MS. GERAGOS: Okay. And he says, I'll fuck your head up, and you emphasize that, right?
MS. GERAGOS: So let's put 14 and 15 up next to each other.
All right. So if we could --
MS. GERAGOS: Then you send him several text messages, which you don't have to read out loud, but you say: You definitely intoxicate me mentally. Every stroke feels like the most pleasure-filled orgasmic. I can't even describe it. Let's have a night of drowning in each other. Right?
MS. GERAGOS: And then you respond, at the end of page 15: Hope your treatment goes well, my love. Message me when you're done. Wish I was cuddling and sleeping with you after big hug or kiss. Right?
MS. GERAGOS: Your Honor, I could do one more exhibit or we could stop now, whatever.
THE COURT: Why don't we do one last one.
MS. GERAGOS: Okay. Perfect.
Let's go to Defense Exhibit 3034, which is the corresponding exhibit to A-104-18.
MS. COMEY: No objection if it's being offered your Honor.
MS. GERAGOS: We're offering this under seal your Honor.
THE COURT: All right. Exhibit 3034 will be admitted under seal.
(Defendant's Exhibit 3034, sealed, received in evidence)
MS. GERAGOS: Could we go to page 13, please.
MS. GERAGOS: All right. So you write, on page 13 -- I skipped ahead a bit -- I miss you, baby. Can't stop thinking about you and being nasty with you too. I love, love having that intensity with you. Do you remember writing that?
MS. GERAGOS: What do you say next?
JANE: I said: Remember when we just got home from hotel and eating, just shooting the shit, and we were just staring at each other, just telling each other how much we wanted each other right in that moment. My whole body was throbbing for you. Should I keep reading?
MS. GERAGOS: So -- no. Thank you. Is this an example of the time where you got to have quality time with him and you get home from the hotel and you get to talk to one another?
MS. GERAGOS: And then you get to -- I think you said this morning you guys would make love to each other after that, and that would be a really intense and wonderful time between you two?
MS. GERAGOS: And so you're telling him here in this message, on December 14, do you remember that time that we had together that was really intense and my whole body was just throbbing for you?
MS. GERAGOS: And then you say: Still can't believe we came at the same time too. Wish you were in bed with me. Night, my baby. Right?
MS. GERAGOS: And then you send some more texts the next day. Do you see that on page 14?
MS. GERAGOS: Okay. If we could go to the next page, 15 and 16 next to each other.
MS. GERAGOS: And then at the bottom of page 15 you send him a selfie, right?
MS. GERAGOS: And what do you write under the selfie?
JANE: I said: Wish you were here. We can play our videos on TV and lock each other in the room all day.
MS. GERAGOS: And is this a reference to the videos that you guys would record during hotel nights?
MS. GERAGOS: And so you sent him a selfie at 6:54 p.m. UTC, right?
MS. GERAGOS: And you told him: I wish you were here. We could play our videos on TV and lock each other in the room all day. Right?
MS. GERAGOS: And you wanted to show him videos and recap and watch and talk about it, right?
MS. GERAGOS: Okay. And what does he respond with on the next page?
MS. GERAGOS: And says -- and then you respond. You say: Okay, and then you send him several emojis, right?
MS. GERAGOS: And what are those emojis indicative of?
MS. GERAGOS: If we could go to page -- we'll skip ahead to page 29 of this exhibit.
(Continued on next page)
BY MS. GERAGOS:
MS. GERAGOS: OK. This is -- there we go. This is several days after, right; the ones we were just looking at were December 14?
MS. GERAGOS: OK. And this is December 24, 2021?
MS. GERAGOS: And you say: Just looked. I don't see anything on the blogs at all. Night, baby. Sweet dreams. Right?
MS. GERAGOS: Is this a reference to you guys looking through the blogs to make sure nobody essentially had spotted you or caught you out?
MS. GERAGOS: OK. And then he says: You're so sweet. Right?
MS. GERAGOS: And you respond with emojis?
MS. GERAGOS: Oh, I see. OK. Explain that photo on the left with the bears.
MS. GERAGOS: I see. This is Christmas Eve?
MS. GERAGOS: OK. So he says: You're so sweet. Right?
MS. GERAGOS: And he says: That shit was so fucking sexy the other night. Damn. Right?
MS. GERAGOS: And what do you say in response?
JANE: I emphasized that text, and I said: I haven't stopped thinking about it, about all of it, just keeps getting better and better.
MS. GERAGOS: What does he say?
MS. GERAGOS: Can we go to the next page?
MS. GERAGOS: What do you say in response?
JANE: I said: Just how sexy the room was, so much sexual tension. It was all just making me wet seeing -- to see it and the way you made me come. I'll never -- I never came so hard like that in my life.
MS. GERAGOS: What are those emojis next to that text message?
MS. GERAGOS: OK. Is the crying upset crying or happy crying? What does that crying indicate?
MS. GERAGOS: OK. And then what do you say after that?
MS. GERAGOS: Are you saying that because you want to know how he felt the other night?
MS. GERAGOS: And he says: I loved it. Right?
MS. GERAGOS: And you respond with some emojis again?
MS. GERAGOS: The smurf emoji we talked about; flirtatious, right?
MS. GERAGOS: And kissing emojis?
MS. GERAGOS: And you say sheesh, right?
MS. GERAGOS: OK. And then you send him a song that says: You light my fire. I feel alive with you, baby. You blow my mind. I'm satisfied. Outstanding. Right?
MS. GERAGOS: And then afterwards you send a message: Baby, I just got my package. I haven't opened it yet. Going to wait to open it until tomorrow. You're so sweet, my baby. Right?
MS. GERAGOS: And is that in reference to your Christmas present?
MS. GERAGOS: OK. I think, your Honor, I can stop now.
THE COURT: All right. Very good.
Thank you, members of the jury.
We'll be back here tomorrow to start at 1 p.m., and if you are here early, there will be a lunch here. So if you get here a little bit early, it's an incentive to get here early, there will be lunch for you.
Same instructions. Don't speak with each other about the case. Don't speak with anybody else, and don't look up anything about the case.
With that, we'll see you tomorrow to start at 1 p.m.
(Continued on next page)
(Jury not present)
THE COURT: All right. Thank you, Jane. We'll see you here tomorrow.
(Witness not present)
THE COURT: Please be seated.
Ms. Comey, anything to address before we adjourn?
MS. COMEY: No. Thank you, your Honor.
THE COURT: Ms. Geragos.
MS. GERAGOS: I don't have anything, your Honor.
THE COURT: OK.
So I'll see everybody here at 12:30 tomorrow to address any issues that we need to.
(Adjourned to June 11, 2025, at 12:30 p.m.)