4.Jonathan Perez — Direct/Cross/Redirect/Recross

MS. SMYSER: Good morning, Mr. Perez.

MS. SMYSER: How old are you?

MS. SMYSER: Where are you from?

MS. SMYSER: How far did you go in school?

MS. SMYSER: I want to direct your attention to the end of 2021. Were you working around that time?

MS. SMYSER: Where were you working?

MS. SMYSER: Combs Entertainment or Combs Enterprises?

MS. SMYSER: Would you mind just pulling the mic closer to you? When you were at Combs Enterprise, did the company ever change its name?

MS. SMYSER: What was your role at Combs Enterprises or Combs Global?

MS. SMYSER: Whose personal assistant were you?

MS. SMYSER: Ms. Foster, could you please pull up what's in evidence as Government Exhibit 2A-101.

MS. SMYSER: Mr. Perez, on the screen in front of you, do you recognize the person who's depicted here?

MS. SMYSER: Who is that?

MS. SMYSER: Do you know Mr. Combs by any other names?

MS. SMYSER: What did you call him?

MS. SMYSER: You can take that down, Ms. Foster.

MS. SMYSER: Mr. Perez, when did you start working for Mr. Combs?

MS. SMYSER: Do you still work for him?

MS. SMYSER: When did you stop?

MS. SMYSER: How did you first learn about the job opening as Mr. Combs' assistant?

MS. SMYSER: Who is KK?

MS. SMYSER: What's Ms. Khorram's title?

MS. SMYSER: How did you know Ms. Khorram when she reached out?

MS. SMYSER: And did you get or take a job at that time?

MS. SMYSER: Okay. Mr. Perez, next I want to show you what's in evidence as Government Exhibit 2A-301. Do you recognize this person?

MS. SMYSER: Who is that?

MS. SMYSER: And when approximately did Ms. Khorram reach out to you about the job as personal assistant?

MS. SMYSER: You can take that down, Ms. Foster.

MS. SMYSER: When Ms. Khorram reached out, what did she say?

MS. SMYSER: How did you respond?

MS. SMYSER: When you say "to do a trial," what are you talking about?

MS. SMYSER: Did you end up doing that trial?

MS. SMYSER: How long did that last?

MS. SMYSER: What happened at the end of that week?

MS. SMYSER: Did you take that job?

MS. SMYSER: So when you became a personal assistant for Mr. Combs, what were your responsibilities at the high level?

MS. SMYSER: When you were working as a personal assistant, where were you physically working?

MS. SMYSER: Where did Mr. Combs live in LA?

MS. SMYSER: What about in Miami?

MS. SMYSER: Mr. Perez, what was your salary when you were a personal assistant?

MS. SMYSER: How often were you paid?

MS. SMYSER: What entity paid you when you were a personal assistant?

MS. SMYSER: Who was your direct supervisor when you were a personal assistant?

MS. SMYSER: And you said she was chief of staff, right?

MS. SMYSER: How often about, if at all, did you see Ms. Khorram interact with Mr. Combs?

MS. SMYSER: For from what you could see, how would you describe Ms. Khorram's relationship with Mr. Combs?

MS. SMYSER: Did they also appear to have a personal relationship?

MS. SMYSER: And what was that from your perspective?

MS. SMYSER: And when you started as a personal assistant, what were the nature of your interactions with Mr. Combs?

MS. SMYSER: How were you getting instructions on what to do in those months?

MS. SMYSER: When you started communicating more with Mr. Combs, did he also provide you instruction?

MS. SMYSER: When your interactions with Mr. Combs increased, did you continue to get instruction from Ms. Khorram also?

MS. SMYSER: When you started working for Mr. Combs, were there any other personal assistants?

MS. SMYSER: How many?

MS. SMYSER: How many personal assistants did Mr. Combs typically have when you were there?

MS. SMYSER: What other personal assistants did you work with?

MS. SMYSER: And did Mr. Combs have any butlers when you were there?

MS. SMYSER: And how often did Mr. Rodriguez and the personal assistants you listed interact with Mr. Combs?

MS. SMYSER: I want to talk about some of the people you mentioned.

MS. SMYSER: First, Ms. Foster, can we show the witness, the Court and parties what's been marked for identification as Government Exhibit 2A-315.

MS. SMYSER: Do you recognize the person depicted here?

MS. SMYSER: Who is this?

MS. SMYSER: How do you know Mr. Pines?

MS. SMYSER: Is it a fair and accurate depiction of him?

MS. SMYSER: Your Honor, the government offers Government Exhibit 2A-315.

MS. SMYSER: Ms. Foster, could you please publish that for the jury.

MS. SMYSER: Mr. Perez how often did -- or how long did Mr. Pines work for Mr. Combs while you were there?

MS. SMYSER: Did you interact with Mr. Pines after he left his job with Mr. Combs?

MS. SMYSER: Under what circumstances?

MS. SMYSER: And when you were getting marijuana with Mr. Pines, were you getting it for yourself or for someone else?

MS. SMYSER: For Mr. Combs?

MS. SMYSER: I want to show you next what's been marked for identification as Government Exhibit A-322. So this is just for the witness, Court and parties.

MS. SMYSER: Mr. Perez, do you recognize this person?

MS. SMYSER: Who is it?

MS. SMYSER: Do you know Frankie's last name?

MS. SMYSER: How do you know Mr. Santella?

MS. SMYSER: Is it a fair and accurate depiction of Mr. Santella?

MS. SMYSER: Your Honor, the government offers Government Exhibit 2A-322?

MS. SMYSER: Ms. Foster, could you please publish that for the jury.

MS. SMYSER: Mr. Perez how long did Mr. Santella work as a personal assistant while you were there?

MS. SMYSER: What did he do after being a personal assistant?

MS. SMYSER: For whom?

MS. SMYSER: You can take that down, Ms. Foster. And next I want to show you what's been marked for Government Exhibit A-303. This is also for the witness, Court and parties.

MS. SMYSER: Do you recognize this person, Mr. Perez?

MS. SMYSER: Who is it?

MS. SMYSER: How do you know Mr. Chavez?

MS. SMYSER: Is it a fair and accurate depiction of Mr. Chavez?

MS. SMYSER: Your Honor the government offers Government Exhibit 2A-303?

MS. SMYSER: Ms. Foster, will you please publish that for the jury.

MS. SMYSER: Mr. Perez, when did Mr. Chavez work for Mr. Combs relative to you?

MS. SMYSER: You can take that down, Ms. Foster. Next I want to show you what's already in evidence as Government Exhibit 2A-313.

MS. SMYSER: Do you recognize this person

MS. SMYSER: And who is that?

MS. SMYSER: How do you know Mr. Paul?

MS. SMYSER: And when did Mr. Paul work for Mr. Combs relative to you?

MS. SMYSER: Okay. You can take that down, Ms. Foster. And next I'm going to show you what's in evidence already as Government Exhibit 2A-317.

MS. SMYSER: Do you recognize this person?

MS. SMYSER: Who is it?

MS. SMYSER: And is that the butler you mentioned earlier?

MS. SMYSER: When did Mr. Rodriguez work for Mr. Combs, if you know?

MS. SMYSER: From what you could see, what were Mr. Rodriguez's responsibilities as compared to those of personal assistants?

MS. SMYSER: Ms. Foster, you can take that down.

MS. SMYSER: Mr. Perez, when you were working as a personal assistant, what were your typical hours?

MS. SMYSER: Were there other assistants who typically worked at night?

MS. SMYSER: When you say Frank, are you referring to Frank Rodriguez?

MS. SMYSER: Did Mr. Combs have security when you were there?

MS. SMYSER: Who were some of the security personnel?

MS. SMYSER: I want to show you what's in evidence as Government Exhibit 2A-203. Do you recognize this person?

MS. SMYSER: Who is that?

MS. SMYSER: What was Faheem's role?

MS. SMYSER: What, if any, role did Mr. Muhammad have with regard to cash?

MS. SMYSER: And if you needed cash in your capacity as a personal assistant, how would you go about getting it?

MS. SMYSER: You can take that down, Ms. Foster.

MS. SMYSER: Next I want to show you what's in evidence as Government Exhibit 2A-206. Do you recognize this person?

MS. SMYSER: Who is that?

MS. SMYSER: Do you know J9 by any other names?

MS. SMYSER: Do you know his last name?

MS. SMYSER: What was J9's role?

MS. SMYSER: You can take that down.

MS. SMYSER: Were you aware of someone named Abdu?

MS. SMYSER: Who is that?

MS. SMYSER: What about someone named Duke?

MS. SMYSER: When you were working for Mr. Combs, did Mr. Combs have any stylists?

MS. SMYSER: Who was that?

MS. SMYSER: Do you know Jun's last name?

MS. SMYSER: All right. Mr. Perez, I want to shift topics. When you were employed by Mr. Combs, were you aware of the term "king night"?

MS. SMYSER: How did you learn that term?

MS. SMYSER: What did you understand the term king night to mean?

MS. SMYSER: I want to show you a document, Mr. Perez. Could you just look in the binder that's to your left, the one closest to you. If you open it up, there's a picture in the front left. Do you see that?

MS. SMYSER: That's marked as Government Exhibit A-402, which is an exhibit that's in evidence under seal. Mr. Perez, I'm going to refer to the person in this photograph as Jane, and I ask you to do the same, okay?

MS. SMYSER: Do you recognize Jane?

MS. SMYSER: How do you recognize her?

MS. SMYSER: When you say "guest," what do you mean?

MS. SMYSER: Was Jane with Mr. Combs for any king nights when you were there?

MS. SMYSER: How would you typically learn that Mr. Combs was going to have a king night?

MS. SMYSER: How much notice would you generally get from Ms. Khorram or other assistants about a king night?

MS. SMYSER: At a high level, what were personal assistants required to do for king nights?

MS. SMYSER: We'll talk about some of those items in a bit. But where did these king nights typically take place?

MS. SMYSER: And who would book the hotel rooms?

MS. SMYSER: What was her name?

MS. SMYSER: How did you know Jessica Ruiz was the one who helped book hotels?

MS. SMYSER: Did you ever talk with her about hotel nights?

MS. SMYSER: About the rooms used for hotel nights?

MS. SMYSER: Was Jessica saved in your phone?

MS. SMYSER: What was her contact in your phone?

MS. SMYSER: Were there times when king nights were not in hotel rooms?

MS. SMYSER: Where did they occur when they weren't in hotel rooms?

MS. SMYSER: Were there any at Jane's home?

MS. SMYSER: Which assistants were primarily responsible for helping with king nights when you were there?

MS. SMYSER: And were there assistants who typically helped in the evenings?

MS. SMYSER: Were there ever times when you set up king rooms yourself?

MS. SMYSER: Approximately how many times?

MS. SMYSER: And why were you not involved with setting up king nights more often?

MS. SMYSER: When you set up hotel rooms, what kind of items did you bring to the hotel room?

MS. SMYSER: What kinds of personal items would you bring?

MS. SMYSER: Did you ever include honey in your setup for king nights?

MS. SMYSER: What was your understanding of what that was used for?

MS. SMYSER: I want to show you what's in evidence as Government Exhibit 1B-265?

MS. SMYSER: Do you recognize what's in this photo?

MS. SMYSER: What is it?

MS. SMYSER: Is it the same honey that you would use for king nights?

MS. SMYSER: You can take that down.

MS. SMYSER: Mr. Perez, you mentioned bringing lights to these hotel rooms. What kinds of lights did you bring?

MS. SMYSER: Were those lights set to a particular color?

MS. SMYSER: Where would you get the items that you needed to set up a king night at a hotel?

MS. SMYSER: And if they weren't in the house, where would you purchase them?

MS. SMYSER: Were there any other stores that you went to in order to purchase these kinds of items?

MS. SMYSER: Did you ever go to sex stores?

MS. SMYSER: Who told you to go to those sex stores?

MS. SMYSER: And what, if anything, would you purchase there?

MS. SMYSER: What kinds of shoes?

MS. SMYSER: And how would you pay for the items that you purchased for king nights?

MS. SMYSER: Where would you get the cash to purchase these items?

MS. SMYSER: Ms. Foster, could you please pull up what has been marked for identification as Government Exhibit 1A-205.

MS. SMYSER: Do you recognize this, Mr. Perez?

MS. SMYSER: What is it?

MS. SMYSER: Where is this Astroglide being stored?

MS. SMYSER: And how do you know that?

MS. SMYSER: Your Honor, the government offers Government Exhibit A-205.

MS. SMYSER: Could we please publish that for the jury.

MS. SMYSER: You mentioned these were being stored at Mapleton, is that right

MS. SMYSER: You can take that down, Ms. Foster.

MS. SMYSER: Mr. Perez, when you were there, did personal assistants have any role related to cleanup from a king night?

MS. SMYSER: Did you ever clean up from a king night?

MS. SMYSER: When you went to clean up hotel rooms after a king night, what generally did they look like?

MS. SMYSER: And how so?

MS. SMYSER: What did you do when you cleaned up these hotel rooms?

MS. SMYSER: Would you do anything else when you were in the room?

MS. SMYSER: Did you do that cleaning before or after hotel staff helped clean?

MS. SMYSER: Why would you do it before?

MS. SMYSER: When there were king nights, how long would Mr. Combs generally be away for?

MS. SMYSER: Were there any times you saw Mr. Combs and his guest after a king night?

MS. SMYSER: How would they typically appear?

MS. SMYSER: At the end of king nights, what, if anything, would assistants arrange for Mr. Combs and his guest?

MS. SMYSER: What's the purpose of a drip or an IV?

MS. SMYSER: I want to direct your attention to the binder that's closest to you first.

MS. SMYSER: Could you please look through that binder and look up to me when you're done.

MS. SMYSER: And for the record, what's contained in this binder is what's been marked for identification as Government Exhibits 3D-108, 3D-110, 3D-117, 3D-118, 3D-123, 3D-125, 3D-126, 3D-127, 3D-129 and 3D-130.

MS. SMYSER: Do you recognize these documents?

MS. SMYSER: What are they?

MS. SMYSER: Whose text messages are they?

MS. SMYSER: And who generally are you communicating with?

MS. SMYSER: Are some of the communications with Mr. Combs?

MS. SMYSER: What about with Jane?

MS. SMYSER: Are these fair and accurate representations of your text messages with these individuals?

MS. SMYSER: Next I want to direct your attention to a second binder in front of you. Do you see that?

MS. SMYSER: Could you again please look through the contents of this binder and look up when you're done.

MS. SMYSER: The record this binder contains what's been marked for identification as Government Exhibits 3D-103-A, 3D-107-A, 3D-107-BR, 3D-108-AR, 3D-109, 3D-112-AR, 3D-113-A, 3D-114-AR, 3D-115-A, 3D-116-A, 3D-117-A, 3D-120-A, 3D-123-AR, 3D-123-BR, 3D-129-A, 3D-129-BR, C-404-A, J-120, J-121, and J-122.

MS. SMYSER: Do you recognize those documents, Mr. Perez?

MS. SMYSER: And what are they?

MS. SMYSER: Whose text messages are they?

MS. SMYSER: And how do you know they are your communications?

MS. SMYSER: Is that the same for the binder you looked at previously also?

MS. SMYSER: And who generally are you communicating with in these text messages?

MS. SMYSER: Are there some with Mr. Combs?

MS. SMYSER: And are there some with Jane?

MS. SMYSER: Do some of these communications contain redactions?

MS. SMYSER: Are those redactions of Jane's true name?

MS. SMYSER: Are these fair and accurate representations of your text messages?

MS. SMYSER: So, your Honor, the government now offers Government Exhibits 3D-103-A, 3D-107-A, 3D-107-BR, 3D-108-AR, 3D-109, 3D-112-AR, 3D-113-A, 3D-114-AR, 3D-115-A, 3D-116-A, 3D-117-A, 3D-120-A, 3D-123-AR, 3D-123-BR, 3D-129-A, 3D-129-BR, C-404-A, J-120, J-121 and J-122?

MS. SMYSER: Ms. Foster, could you please pull up Government Exhibit 3D-112-A.

MS. SMYSER: Mr. Perez, did you sometimes communicate with Mr. Combs and other employees regarding hotel nights?

MS. SMYSER: So here what are we generally looking at?

MS. SMYSER: And are you on this text message thread?

MS. SMYSER: Who are the other participants in this thread?

MS. SMYSER: So I want to zoom in, Ms. Foster, on the heading on the top left.

MS. SMYSER: This says Frank Black (Yellow) and Frank Black (Red). What does that mean?

MS. SMYSER: So did he have a yellow phone and a red phone?

MS. SMYSER: And was Jane also in this group text?

MS. SMYSER: So these are the participants in the text, is that right?

MS. SMYSER: You can zoom out, Ms. Foster. I want to zoom in on the last two messages from August 12, 2023.

MS. SMYSER: Mr. Perez, did you send these messages here?

MS. SMYSER: And what did you say in the first text?

MS. SMYSER: And here why are you sending this text?

MS. SMYSER: And were hotels often in your name or other personal assistants' names?

MS. SMYSER: What did you say next?

MS. SMYSER: Was this about a king night?

MS. SMYSER: You can take that down, Ms. Foster. Could you please pull up Government Exhibit 3D-114-A.

MS. SMYSER: Is this another one of your text messages?

MS. SMYSER: Who are the participants in this particular chat?

MS. SMYSER: So can we zoom in on the bottom half of the page?

MS. SMYSER: So KK first says: Checking in. How's the setup going? How much longer do y'all need? What did you understand her to be talking about?

MS. SMYSER: Joey responds: It's going. Should be done in 30. And then Kristina says: Okay, please keep me posted. List of what Jane wants for hotel. Maybe new outfits, shorts for him size large. Fruits, shakes, juices. And how did you respond?

MS. SMYSER: What store are you referring to?

MS. SMYSER: And what kinds of outfits are you talking about here?

MS. SMYSER: So Kristina responds: Just send to me, and I'll send to her for now. Thanks. What did you understand her to be talking about?

MS. SMYSER: Ms. Foster, could we please turn to page 2 of this chat. Could we zoom in on the top half before there is a new date.

MS. SMYSER: How did you respond to Kristina's message?

MS. SMYSER: Then Kristina says: Is room done yet? Joey says: Bellmen coming up to get our luggages. Kristina says: So how much longer till room is done done? How did you respond?

MS. SMYSER: And what did you mean when you said "room is done"?

MS. SMYSER: And what store are you going to?

MS. SMYSER: Kristina then says: Copy. Let me all when y'all are on way to store. And how did you respond?

MS. SMYSER: Then Kristina liked your message.

MS. SMYSER: When were these text messages sent?

MS. SMYSER: At what time?

MS. SMYSER: Kristina says: Is PD at hotel yet? Who is she referring to here?

MS. SMYSER: Joey said: He's on the way per security. And then Kristina liked that message.

MS. SMYSER: Could we please zoom out, and could we zoom in on the last two texts of this chat.

MS. SMYSER: Mr. Perez, Joey says: Here Ricky 40 away. Who is Ricky

MS. SMYSER: Did Mr. Combs have any other people who provided him IV's during this time period?

MS. SMYSER: And who were some of those people?

MS. SMYSER: Was there an individual named Garrett?

MS. SMYSER: Then when Joey says "Ricky 40 away," what do you understand him to be talking about there?

MS. SMYSER: Kristina then says: Joey, how's cleanup going? What did you understand her to be asking about?

MS. SMYSER: Let's zoom out, Ms. Foster. And could you turn to the next page and zoom in on the top two messages.

MS. SMYSER: Joey then said: Slipped and fell twice. But calling bell cart in about ten minutes.

MS. SMYSER: Could you zoom out, please. And you can take that down.

MS. SMYSER: Mr. Perez, I want to talk about another topic. Was there ever a time that you saw a video of Jane and someone other than Mr. Combs?

MS. SMYSER: Remember approximately when this was?

MS. SMYSER: Where were you at the time you heard about this video?

MS. SMYSER: How did it come about that you learned of the video?

MS. SMYSER: And what was the videographer's name who showed you the video?

MS. SMYSER: Where did you go after you heard Brandon yelling?

MS. SMYSER: Where was Brandon at the time you went to go meet him?

MS. SMYSER: Was there anyone else in the theater with you?

MS. SMYSER: And did you end up watching the video?

MS. SMYSER: What device was the video on?

MS. SMYSER: Who generally used that iPad?

MS. SMYSER: And from what you saw, what did the video show?

MS. SMYSER: And was there anyone else in the video?

MS. SMYSER: What did the other man look like?

MS. SMYSER: Did you recognize that man?

MS. SMYSER: Who, if anyone, did you tell about the video?

MS. SMYSER: Who did you tell first?

MS. SMYSER: How soon after seeing the video did you tell Mr. Combs?

MS. SMYSER: And what did you tell him?

MS. SMYSER: And how did he react?

MS. SMYSER: Did you have any further conversations with Mr. Combs about this video?

MS. SMYSER: You mentioned that you told KK, is that right?

MS. SMYSER: How soon after you told Mr. Combs did you tell KK?

MS. SMYSER: What did KK say to you in this conversation?

MS. SMYSER: What did you tell KK about what was on the video?

MS. SMYSER: Did you tell her that Mr. Combs was on the video?

MS. SMYSER: Did there come a time when you spoke with KK about this video a second time?

MS. SMYSER: When approximately was that?

MS. SMYSER: Where were you when you had this conversation with KK?

MS. SMYSER: And how did that conversation come about?

MS. SMYSER: Did she say why she wanted you to reiterate this --

MS. SMYSER: And did you convey to her the same things you've been talking about today?

MS. SMYSER: Did you record that conversation, Mr. Perez?

MS. SMYSER: What was your understanding of whether that conversation was being recorded?

MS. SMYSER: Ms. Foster, could you please pull up what's in evidence as Government Exhibit 1301 which is a stipulation between the parties. First I want to focus in on paragraph 1B. It says: On or about March 25, 2024 at the Miami Opa-Locka Airport in Opa-Locka, Florida, law enforcement agents from Homeland Security Investigations seized Government Exhibit C-300 a cellphone from 1's person. Could we now zoom in on paragraph 4, which is on the next page. This paragraph says: Government Exhibits C-300-A through C-364, including the subdivisions thereof, are true and accurate excerpts of data extracted from Government Exhibit C-300. Your Honor, the government offers pursuant to this stipulation Government Exhibit C-349, C-349-B and C-349-C.

MS. SMYSER: Mr. Perez, I want to direct you attention to a disk which should be next to the binders in front of you. Do you see that?

MS. SMYSER: Could you pick it up? That disk contains Government Exhibit C-349-B and C-349-C. Did you review that disk in advance of your testimony?

MS. SMYSER: What does it contain?

MS. SMYSER: And how do you know that's what's on the disk?

MS. SMYSER: Did you also sign the disk?

MS. SMYSER: All right. Ms. Foster, could you please first pull up for the witness and parties only what has been marked for identification as Government Exhibit T-349-BT side by side with C-349-CT.

MS. SMYSER: Mr. Perez, do you recognize these documents here?

MS. SMYSER: What are they?

MS. SMYSER: And did you review these transcripts before testifying today?

MS. SMYSER: Are they accurate transcripts of what was on the recordings on the CD you reviewed Government Exhibits C-349-B and C?

MS. SMYSER: Your Honor, the government offers Government Exhibit C-349-BT and C-349-CT as aids to the jury.

MS. SMYSER: We can take that down for now, Ms. Foster. Before we listen to the recordings, can we please pull up Government Exhibit C-349 for the jury. I just want to focus on a few things here. Could you please zoom in on the first four columns.

MS. SMYSER: Mr. Perez, I want to direct your attention to the column labeled Title. What does that say below it?

MS. SMYSER: Next I want to direct your attention to the column labeled Time Information. What is under the heading timestamp?

MS. SMYSER: And what is the time listed?

MS. SMYSER: You can take that down, Ms. Foster. Ms. Foster, could you please display for the jury Government Exhibit C-349-BT. Could we also please pull up Government Exhibit C-349-B for the jury to listen to. Could we start by playing the first 15 seconds that of recording, Ms. Foster.

MS. SMYSER: Whose voice did you just hear, Mr. Perez?

MS. SMYSER: Could we continue playing.

MS. SMYSER: Stop right there.

MS. SMYSER: When Ms. Khorram says "an outside person brought up something about it," what did you understand her to be referring to

MS. SMYSER: So someone who didn't work for Mr. Combs?

MS. SMYSER: Let's continue playing through 128, please.

MS. SMYSER: Was that your voice on the recording just now?

MS. SMYSER: When you say, "Brandon the shooter," what did you mean by the shooter?

MS. SMYSER: Could we please continue playing through two minutes and 13 seconds.

MS. SMYSER: Can you pause it there.

MS. SMYSER: Did you ever learn what, if anything, was on the camera footage Ms. Khorram was referencing?

MS. SMYSER: Let's continue playing through 356 please.

MS. SMYSER: Can we just pause it right there.

MS. SMYSER: So you just referenced PD. Who are you talking about there?

MS. SMYSER: Earlier you referenced Rob. Who is that?

MS. SMYSER: And you also referenced Geo. Who is that?

MS. SMYSER: Let's continue playing, please.

MS. SMYSER: Could you please pause it there.

MS. SMYSER: Why did you not feel comfortable deleting the video?

MS. SMYSER: Could we please continue to play through 4:05.

MS. SMYSER: What investigation are you referring to?

MS. SMYSER: And who ordered that investigation?

MS. SMYSER: Let's continue playing now through 4:20.

MS. SMYSER: What did you mean when you were talking about it being filmed on that device?

MS. SMYSER: And the investigation you referred to earlier, was that an investigation by staff?

MS. SMYSER: Let's continue playing, please.

MS. SMYSER: Pause it there, Ms. Foster.

MS. SMYSER: Who is Deon?

MS. SMYSER: Please continue playing.

MS. SMYSER: Ms. Foster, you can take that down. And let's pull up Exhibit C-349CT for the jury. Can we also start playing Government Exhibit T-349C T just for about the first six seconds.

MS. SMYSER: Who is talking here?

MS. SMYSER: Is this a continuation of that prior recording that we just listened to?

MS. SMYSER: Let's continue playing through one minute and two seconds.

MS. SMYSER: Could we pause it there.

MS. SMYSER: Was it true that no one else was in the theater besides you and maybe Geo and Brandon?

MS. SMYSER: Why did you not tell KK about Chef K?

MS. SMYSER: Why did you not mention the original time that she was in the theater?

MS. SMYSER: Could we please play through the end.

MS. SMYSER: You can take that down, Ms. Foster.

MS. SMYSER: Mr. Perez, were these two recordings we just listened to part of a larger conversation with KK?

MS. SMYSER: Aside from Chef K not being in the theater, was anything else you told KK not true?

MS. SMYSER: Did you have any follow-ups with KK about this?

MS. SMYSER: And after these conversations with KK, did anyone else who worked for Mr. Combs ever bring up this video to you?

MS. SMYSER: And when did Faheem bring up the video relative to this conversation?

MS. SMYSER: Where were you when this conversation took place with Faheem?

MS. SMYSER: And what did Faheem say to you?

MS. SMYSER: And how did you respond to Faheem?

MS. SMYSER: Had you ever told Faheem about the video before this conversation with him?

MS. SMYSER: Are you aware of how Faheem knew about that incident?

MS. SMYSER: Your Honor, I probably have another 15 or 20 minutes if you would like to break now.

MS. SMYSER: No, your Honor.

MS. SMYSER: Yes, we'll get Mr. Pérez.

MS. COMEY: Your Honor, if I may? When Mr. Pérez is done but before the jury is dismissed, we have another big list of exhibits to admit that will help us get all of our summary charts together over the weekend once these are in.

MS. COMEY: Thank you, your Honor.

MS. SMYSER: Thank you, your Honor.

MS. SMYSER: Mr. Pérez, did you receive a subpoena requiring you to testify at this trial?

MS. SMYSER: Do you want to be testifying at this trial?

MS. SMYSER: Is there also an order compelling you to testify even if your testimony might incriminate you?

MS. SMYSER: What is your understanding of what that order requires you to do?

MS. SMYSER: Does it require you to tell the truth?

MS. SMYSER: Does the order protect you if you intentionally make false statements today?

MS. SMYSER: In other words, can you still be prosecuted for perjury if you were to lie?

MS. SMYSER: I want to show you what's in evidence as Government Exhibit 1B236.

MS. SMYSER: Do you recognize this, Mr. Pérez?

MS. SMYSER: What is it?

MS. SMYSER: What was typically kept inside of Mr. Combs's Gucci pouch?

MS. SMYSER: Would you mind pulling the mike just a little bit closer to you. A. Drugs and money. Oh, sorry.

MS. SMYSER: What kind of drugs?

MS. SMYSER: And before king nights, what, if any, responsibilities did you have related to the Gucci pouch?

MS. SMYSER: What responsibilities, if any, did you have related to the Gucci pouch here?

MS. SMYSER: Yes.

MS. SMYSER: Where typically was the Gucci pouch located?

MS. SMYSER: Was that backpack typically with Mr. Combs?

MS. SMYSER: When he went to king nights, was it typically with him?

MS. SMYSER: Ms. Foster, you can take that down, and let's pull up Government Exhibit 3D115A.

MS. SMYSER: Who is part of this conversation?

MS. SMYSER: Could you zoom out for a second.

MS. SMYSER: And let's zoom in on the bottom half of the page, please.

MS. SMYSER: What date were these sent?

MS. SMYSER: So Rob says: Yo, will you locate his Gucci pouch in his bathroom. Here, when Rob says his Gucci pouch in his bathroom, who did you understand Rob to be referring to?

MS. SMYSER: And how do you respond?

MS. SMYSER: What did Rob say next?

MS. SMYSER: And does that finish LOL?

MS. SMYSER: What did you say in response?

MS. SMYSER: What did you mean in that text?

MS. SMYSER: You can take that down, Ms. Foster. And I want to pull up Government Exhibit 3D107A.

MS. SMYSER: Who is part of this chat, generally?

MS. SMYSER: I want to focus you on your first text message here, which --

MS. SMYSER: Ms. Foster, could we please zoom in on the middle of the page.

MS. SMYSER: What date was this text sent?

MS. SMYSER: And what did you say?

MS. SMYSER: What is the Balenciaga pouch?

MS. SMYSER: Let's zoom out.

MS. SMYSER: And can we look at Joey's response and the next four texts?

MS. SMYSER: How does Joey respond here?

MS. SMYSER: What do you say in response?

MS. SMYSER: Why did you say cocaine?

MS. SMYSER: And where should that cocaine have been?

MS. SMYSER: And Rob says in response: He prob needs it at PT. What did you understand him to be referring to?

MS. SMYSER: What is PT here?

MS. SMYSER: All right. Let's take that down, please.

MS. SMYSER: Mr. Pérez, as part of your employment, did you have any role in obtaining drugs?

MS. SMYSER: And what did you do, generally?

MS. SMYSER: What did you do related to drugs?

MS. SMYSER: And who would ask you to grab or purchase drugs?

MS. SMYSER: And who were you getting those drugs for?

MS. SMYSER: Did other personal assistants also purchase or grab drugs for Mr. Combs?

MS. SMYSER: Thank you, your Honor.

MS. SMYSER: Mr. Pérez, what drugs did you purchase or grab for Mr. Combs?

MS. SMYSER: Who did you get these drugs from?

MS. SMYSER: And how did you learn of this person named Baby Girl and this person named Guido?

MS. SMYSER: And who told you about them?

MS. SMYSER: How would you pay for the drugs when you were purchasing them?

MS. SMYSER: Where did you get the cash?

MS. SMYSER: And if you're going to security, who from security would you ask for cash?

MS. SMYSER: Would you submit receipts to Faheem for cash purchases?

MS. SMYSER: Ms. Foster, could you please pull up Government Exhibit 3D129A.

MS. SMYSER: What are we generally looking at here?

MS. SMYSER: Could we zoom in on the first text message.

MS. SMYSER: What date did you send that message?

MS. SMYSER: Could you read the message?

MS. SMYSER: You referenced Fah here. Who is that?

MS. SMYSER: What about Dontray?

MS. SMYSER: And who is Guido?

MS. SMYSER: And why did $700 go to Guido?

MS. SMYSER: Did you submit receipts to Faheem when you purchased drugs?

MS. SMYSER: All right. Let's zoom out.

MS. SMYSER: And the next two messages, what are those?

MS. SMYSER: Are those some of the receipts that you were referring to in your prior text message?

MS. SMYSER: Let's turn to the last page of this chat, please, Ms. Foster. And could you please zoom in on the last text message.