DIRECT EXAMINATION BY MS. FOSTER:
MS. FOSTER: Good morning, Ms. Sankar.
ANANYA SANKAR: Good morning.
MS. FOSTER: Are you currently employed?
ANANYA SANKAR: Yes.
MS. FOSTER: Where do you work?
ANANYA SANKAR: At the U.S. Attorney's Office for the Southern District of New York.
MS. FOSTER: What is your title?
ANANYA SANKAR: I'm a paralegal specialist.
MS. FOSTER: How long have you worked at the U.S. Attorney's Office?
ANANYA SANKAR: A little over two years.
MS. FOSTER: What are your duties and responsibilities as a paralegal specialist at the U.S. Attorney's Office?
ANANYA SANKAR: I help organize anything in evidence from various federal agencies, and I also assist attorneys with trial preparation.
MS. FOSTER: You just listed a number of duties and responsibilities that you have as a paralegal specialist. Are those the roles that you played in this case?
ANANYA SANKAR: No.
MS. FOSTER: What was your role, if any, in this case?
ANANYA SANKAR: I had no role.
MS. FOSTER: Besides what we're going to talk about today?
ANANYA SANKAR: Correct.
MS. FOSTER: Turning to this case, were you asked to confirm the accuracy of charts summarizing certain evidence?
ANANYA SANKAR: Yes.
MS. FOSTER: How many charts did you review?
ANANYA SANKAR: I reviewed two charts.
MS. FOSTER: Ms. Sankar, there's a binder in front of you. Do you see that?
ANANYA SANKAR: Yes.
MS. FOSTER: Could you please look at the documents marked Government Exhibit 1410, Government Exhibit 1410-R, Government Exhibit 1411 and Government Exhibit 1411-R and look up at me when you're done.
ANANYA SANKAR: OK.
MS. FOSTER: Do you recognize those documents?
ANANYA SANKAR: Yes.
MS. FOSTER: What are they?
ANANYA SANKAR: These are the summary charts I was asked to verify the accuracy of.
MS. FOSTER: And are Government Exhibits 1410-R and 1411-R just redacted versions of Government Exhibits 1410 and 1411?
ANANYA SANKAR: Yes.
MS. FOSTER: Who prepared these summary charts?
ANANYA SANKAR: The prosecutors did.
MS. FOSTER: Who confirmed their accuracy?
ANANYA SANKAR: I did.
MS. FOSTER: What did you do to confirm their accuracy?
ANANYA SANKAR: I was given government exhibits that I used to verify the accuracy of the information in the charts, which summarizes those exhibits.
MS. FOSTER: At a high level, what kind of underlying documents did you review to check the accuracy of the charts?
ANANYA SANKAR: I reviewed text messages from cell-phone extractions, I reviewed call logs containing call records and I reviewed audio files, images and videos pulled from devices.
MS. FOSTER: Were all of those various documents, the source documents that you listed and that the charts rely on, exhibits in this case?
ANANYA SANKAR: Yes.
MS. FOSTER: Did you select the exhibits that would be used in this chart?
ANANYA SANKAR: No, I did not.
MS. FOSTER: Who selected the exhibits?
ANANYA SANKAR: The attorneys did.
MS. FOSTER: Can you describe the volume of exhibits that were included in these charts?
ANANYA SANKAR: They were hundreds and hundreds of pages of documents.
MS. FOSTER: Are the charts that you reviewed fair and accurate summaries of the underlying exhibits that you reviewed?
ANANYA SANKAR: Yes.
MS. FOSTER: Your Honor, the government now offers Government Exhibits 1410, Government Exhibit 1410-R, Government Exhibit 1411 and Government Exhibit 1411-R into evidence.
THE COURT: Are there any objections that have not been previously resolved by the Court?
MS. GERAGOS: Nothing other than our previous objections, your Honor.
THE COURT: All right. Those exhibits will be admitted on the terms indicated by Ms. Foster.
(Government Exhibits 1410, under seal; 1410-R; 1411, under seal; and 1411-R received in evidence)
MS. FOSTER: Your Honor, my apologies, but the government would offer 1410 and 1411 under seal.
THE COURT: Those will be admitted under seal and the redacted exhibits will be admitted.
MS. FOSTER: Ms. Foster, could you please display Government Exhibit 1411-R.
MS. FOSTER: Ms. Sankar, is this one of the charts that you reviewed for accuracy?
ANANYA SANKAR: Yes.
MS. FOSTER: Can you please explain to the jury what Government Exhibit 1411-R shows, at a high level?
ANANYA SANKAR: This is a timeline that involves text messages between various different participants and then also audio file, images and videos pulled from particular devices.
MS. FOSTER: OK. I want to break that down.
MS. FOSTER: You mentioned that this chart includes text messages, is that right?
ANANYA SANKAR: Correct.
MS. FOSTER: Is it fair to say that the majority of the records on this chart are text messages?
ANANYA SANKAR: Yes.
MS. FOSTER: Were those text messages found on multiple people's devices or just one person's devices?
ANANYA SANKAR: On multiple people's devices.
MS. FOSTER: How do you know that?
ANANYA SANKAR: They were pulled from various cell-phone extractions, which could have been from various different devices.
MS. FOSTER: And do you know that based on a stipulation?
ANANYA SANKAR: Yes.
MS. FOSTER: Who, if anyone, is a party to each of the text messages that appears on this chart?
ANANYA SANKAR: Kristina Khorram.
MS. FOSTER: And is Ms. Khorram speaking with different people in these messages or the same person?
ANANYA SANKAR: With different people.
MS. FOSTER: Are the text communications on this chart between Ms. Khorram and one other person, or are some group chats?
ANANYA SANKAR: Some of them are group chats.
MS. FOSTER: You also mentioned that this chart includes photos, videos and audios, is that right?
ANANYA SANKAR: Correct.
MS. FOSTER: Were those photos, videos and audios found on one person's device or multiple people's devices?
ANANYA SANKAR: Those files were all found on one person's device.
MS. FOSTER: And whose device were those found on?
ANANYA SANKAR: Kristina Khorram.
MS. FOSTER: How do you know that?
ANANYA SANKAR: I was also given a stipulation verifying that.
MS. FOSTER: Ms. Foster, could you please pull up Government Exhibit 1301, briefly.
MS. FOSTER: Ms. Sankar, what does this show?
ANANYA SANKAR: This is the stipulation that verifies particular exhibits come from Kristina Khorram's device.
MS. FOSTER: OK. We will come back to exactly how you did that using the stipulation in a second. But Ms. Foster, can you now take down Government Exhibit 1301 and return to 1411-R. Thank you.
MS. FOSTER: Now, let's look at this chart. In what order are the records listed in this chart?
ANANYA SANKAR: These are in chronological order.
MS. FOSTER: And how many pages is this chart?
ANANYA SANKAR: It's about -- it's 33 pages.
MS. FOSTER: Focusing on the top row of page 1, what is the date of the earliest record on this chart?
ANANYA SANKAR: March 18, 2016.
MS. FOSTER: Ms. Foster, can we please go to page 33, and can you please highlight the last row.
MS. FOSTER: Ms. Sankar, what is the date of the last record on this chart?
ANANYA SANKAR: February 26, 2024.
MS. FOSTER: Does this chart include all text messages, audio files, videos or photos that Ms. Khorram had over this time period or just some?
ANANYA SANKAR: Just some.
MS. FOSTER: And do you know why these specific records were included on the chart?
ANANYA SANKAR: No, I do not.
MS. FOSTER: Ms. Foster, can we please go back to page 1.
MS. FOSTER: Ms. Sankar, there are various gray bars shown on this page. What do those indicate?
ANANYA SANKAR: Those indicate shorter lapses in time. So it could be, maybe, a couple hours or just a few days.
MS. FOSTER: OK. And sometimes is it just a few minutes too?
ANANYA SANKAR: Yes.
MS. FOSTER: Ms. Foster, can we go to the second page.
MS. FOSTER: On this page there appears to be blue bars. What do those indicate?
ANANYA SANKAR: Those indicate larger lapses in time. So it could be multiple weeks or multiple months.
MS. FOSTER: Now I want to go through the columns. What does the column titled date and time, time zone show?
ANANYA SANKAR: That is the date and time the original text message was sent, or it's the date and time the audio, image or video was created on the device.
MS. FOSTER: And is the time zone of the date and time of the record also indicated in this column, where available?
ANANYA SANKAR: Yes.
MS. FOSTER: What is the time zone listed for most of the records on this chart?
ANANYA SANKAR: A majority of them are in Universal Coordinated Time.
MS. FOSTER: Is that UTC?
ANANYA SANKAR: Yes.
MS. FOSTER: Were there certain times you could not tell from the underlying records what time zone the record is in?
ANANYA SANKAR: Yes.
MS. FOSTER: In those cases, what is indicated in that first column?
ANANYA SANKAR: There's either no time zone indicated or an asterisk.
MS. FOSTER: Turning to the next column, what does record type indicate?
ANANYA SANKAR: That indicates whether it's a text message that's being displayed in the row or whether it's an audio file, image or video taken from a device.
MS. FOSTER: And where it's an audio, image or video file, what else does it indicate in this column?
ANANYA SANKAR: It will indicate whose device it was taken from.
MS. FOSTER: Focusing on this first page, what is the record type of each of the files on this page?
ANANYA SANKAR: These are text messages.
MS. FOSTER: Ms. Foster, can we please turn to page 16.
MS. FOSTER: Ms. Sankar, directing your attention to that last row, row 251, what is the record type for this row?
ANANYA SANKAR: This is an audio file found on Kristina Khorram's device.
MS. FOSTER: Now, Ms. Foster, can we go back one page, to page 15.
MS. FOSTER: Ms. Sankar, directing your attention to row 223, what is the record type for this row?
ANANYA SANKAR: This is an audio message.
MS. FOSTER: Is an audio message different than an audio file?
ANANYA SANKAR: Yes. An audio message is sent within a text message chat, and an audio file is just a file found on the device.
MS. FOSTER: Ms. Foster, can we go now back to page 1.
MS. FOSTER: Turning to the next two columns, what does the "from" column indicate?
ANANYA SANKAR: "From" is the sender of the text message and "to" is the recipient of the text message.
MS. FOSTER: Looking at these first few rows, there appears to be a name associated with each of the numbers in these columns. Is that the name of the person believed to use that phone number?
ANANYA SANKAR: Correct.
MS. FOSTER: Now, I want to walk through how that is reflected in the underlying exhibits that you checked. Ms. Foster, could you please pull up Government Exhibit 1312-R.
MS. FOSTER: Ms. Sankar, what is this?
ANANYA SANKAR: This is a stipulation I was given identifying which phone numbers are used by which individuals.
MS. FOSTER: OK. And so focusing just on the first row, who does it say is the user of the 4111 number?
ANANYA SANKAR: Brendan Paul.
MS. FOSTER: Are all of the numbers listed on that summary chart listed in this stipulation?
ANANYA SANKAR: No, they are not.
MS. FOSTER: For where they aren't listed and identified next to an individual user, what name on the summary chart is listed next to the number?
ANANYA SANKAR: The contact name from the original government exhibit.
MS. FOSTER: Now, Ms. Foster, can you please take this down and pull up Government Exhibit 1411-R again.
MS. FOSTER: Going to the next column, what does the column titled content or file name show?
ANANYA SANKAR: This is the content of the actual text message or it's the file name of that audio, image, video file, and sometimes it's just the picture of the image found on the phone.
MS. FOSTER: And now finally the last column, what does source GX indicate?
ANANYA SANKAR: This is the original government exhibit I used to verify the accuracy of the information in each row.
MS. FOSTER: Now I want to just walk through a few examples of how you confirmed the information on this chart. Ms. Foster, can you please go to page 7, rows 44 to 99.
MS. FOSTER: Ms. Sankar, what type of records do these rows show?
ANANYA SANKAR: These are text messages.
MS. FOSTER: And how can you tell that from this chart?
ANANYA SANKAR: It's listed under record type.
MS. FOSTER: Are all of the text messages shown here from the same date?
ANANYA SANKAR: Yes.
MS. FOSTER: What is that date?
ANANYA SANKAR: December 29, 2019.
MS. FOSTER: And is that indicated in the date and time column?
ANANYA SANKAR: Yes.
MS. FOSTER: Who were these messages between?
ANANYA SANKAR: Ryan Lopez and Kristina Khorram.
MS. FOSTER: Where do you see that on this chart?
ANANYA SANKAR: In the "from" and "to" columns.
MS. FOSTER: Ms. Sankar, can you please read Mr. Lopez's first three text messages?
ANANYA SANKAR: "LOL. Think I saw one of the cowboys today. You can spot them in the lobby like an escort. I forgot to tell you about it."
MS. FOSTER: How does Ms. Khorram respond to Mr. Lopez's messages about seeing one of the cowboys?
ANANYA SANKAR: She responds by sending four laughing emojis and then says: BTW, how long is he going to stay awake?
MS. FOSTER: What does Mr. Lopez then respond?
ANANYA SANKAR: "LOL. I'm guessing until tomorrow night."
MS. FOSTER: What exhibit did you review to check the accuracy of the information in these rows?
ANANYA SANKAR: Government Exhibit C366.
MS. FOSTER: And is that indicated in the source column?
ANANYA SANKAR: Yes.
MS. FOSTER: Ms. Foster, could you please pull up Government Exhibit C-366 and go to page 2.
MS. FOSTER: Starting with the message three from the bottom, Ms. Sankar, could you just walk through how you confirmed the accuracy of the information on each of the rows you just walked through?
ANANYA SANKAR: So, first, I verified that the date and time listed on the government exhibit -- so December 29, 2019 -- and each of those times was correct in the date time column. And then I made sure that the phone number listed for the sender or the recipient -- in this case, this is the sender -- of the text messages, was accurate. And then I verified whether, based on that earlier stipulation we saw, there was a name of an individual we knew was attached to the phone number. Otherwise, I listed the contact name, Ryan Lopez. And then I made sure that the content of the text message was also accurate.
MS. FOSTER: Ms. Foster, can we turn to the second page, or the next page.
MS. FOSTER: And does this page show the remaining text messages that were excerpted on that chart?
ANANYA SANKAR: Correct.
MS. FOSTER: Here, the 2886 number is listed as associated with the contact K.K. main phone. Why did the chart say the person associated with this number was Kristina Khorram?
ANANYA SANKAR: Based on the stipulation I was given, it listed that 2886 number as belonging to an individual named Kristina Khorram.
MS. FOSTER: And that's that stipulation we just walked through?
ANANYA SANKAR: Yes.
MS. FOSTER: To confirm, is this entire exhibit, C366, longer than the excerpt in the chart?
ANANYA SANKAR: Yes, it is.
MS. FOSTER: So the chart just includes an excerpt of this exhibit, is that right?
ANANYA SANKAR: Yes.
MS. FOSTER: If someone wanted to look at the longer chat that is excerpted in the chart, where would they go?
ANANYA SANKAR: To the original government exhibit.
MS. FOSTER: That's cited in the chart?
ANANYA SANKAR: Yes.
MS. FOSTER: Now I want to walk through another example. Ms. Foster, can we please go back to page 16 of Government Exhibit 1411-R.
MS. FOSTER: Ms. Sankar, directing your attention to that last row, row 251, what type of record does that row show?
ANANYA SANKAR: This is an audio file found on the device.
MS. FOSTER: And whose device was it found on?
ANANYA SANKAR: Kristina Khorram.
MS. FOSTER: What does it state is the date of this audio file?
ANANYA SANKAR: January 30, 2023.
MS. FOSTER: What is indicated in the content or file name column?
ANANYA SANKAR: This is the file name of that audio file on the phone, on the device.
MS. FOSTER: What exhibits did you review to check the accuracy of this row?
ANANYA SANKAR: I used Government Exhibit 349 -- C349B and then 1301, which is the stipulation.
MS. FOSTER: And are those all indicated in that source column?
ANANYA SANKAR: Yes.
MS. FOSTER: Now I want to walk through each of these exhibits. Ms. Foster, could you please pull up Government Exhibit 1301.
MS. FOSTER: Is this that stipulation that we looked at earlier?
ANANYA SANKAR: Yes.
MS. FOSTER: And generally, what does this stipulation show?
ANANYA SANKAR: This shows that certain ranges of government exhibits given to me contain information pulled from devices.
MS. FOSTER: OK. Can we turn to page 2, paragraph 4.
MS. FOSTER: What government exhibit does it state that C349 and C349B, which were the other exhibits cited in that chart for row, what exhibit they're extracted from?
ANANYA SANKAR: They're subdivisions of C300.
MS. FOSTER: And Ms. Foster, can we go back to page 1 and highlight paragraph 1b.
MS. FOSTER: Who does it state in paragraph B is the person who that C300 was seized from?
ANANYA SANKAR: Kristina Khorram.
MS. FOSTER: Ms. Foster, could we now please pull up Government Exhibit C-349.
MS. FOSTER: Ms. Sankar, what does this show?
ANANYA SANKAR: This is an extraction report from that device seized from Kristina Khorram.
MS. FOSTER: And does this show metadata for that audio recording on line 251?
ANANYA SANKAR: Yes.
MS. FOSTER: What is the file type indicated on this metadata?
ANANYA SANKAR: This is a recording, an audio recording.
MS. FOSTER: And is that indicated under type?
ANANYA SANKAR: Yes.
MS. FOSTER: What date is associated with the audio file in this exhibit?
ANANYA SANKAR: Under time stamp, it says January 30, 2023.
MS. FOSTER: Is that the same time stamp and date that was listed on the summary chart?
ANANYA SANKAR: Yes.
MS. FOSTER: And does it have the name of the -- the file name of the audio file?
ANANYA SANKAR: Yes. Under file.
MS. FOSTER: Ms. Foster, can we now go back to Government Exhibit 1411-R and go back to page 16.
MS. FOSTER: OK. Again, focusing on row 251, so, we've now walked through two of the exhibits cited in that source column, C349 and 1301. What is that last exhibit cited there?
ANANYA SANKAR: 1301.
MS. FOSTER: Sorry?
ANANYA SANKAR: Oh, sorry.
MS. FOSTER: C349B, what is that one?
ANANYA SANKAR: That is the audio file itself.
MS. FOSTER: Ms. Foster, could you please play the first minute and ten seconds of Government Exhibit C349B.
(Media played)
MS. FOSTER: Thank you, Ms. Foster. OK. Now that we've walked through two examples of how you confirmed the accuracy of certain of the rows on this chart, I now want to walk through some of the other records that are included here. So Ms. Foster, can we please go back to page 1.
MS. FOSTER: We're going to start by talking about rows 1 through 31, which are on pages 1 to 2. And using that paper copy in front of you, Ms. Sankar, what is the date of the messages in these rows?
ANANYA SANKAR: March 18, 2016.
MS. FOSTER: Through when? Sorry.
ANANYA SANKAR: Through March 20, 2016.
MS. FOSTER: So these messages are from that two-day period?
ANANYA SANKAR: Yes.
MS. FOSTER: What type of records are shown in rows 1 through 31?
ANANYA SANKAR: These are text messages.
MS. FOSTER: Who were the parties who send and receive the text messages in these rows?
ANANYA SANKAR: Some are Kristina Khorram and Dave Shirley Assist and others include Melissa Feola.
MS. FOSTER: Let's start at the beginning. So, directing your attention to the first four rows, who are these first four messages between?
ANANYA SANKAR: Kristina Khorram and Dave Shirley Assist.
MS. FOSTER: What generally do these seem to be about?
ANANYA SANKAR: Setting up a hotel room.
MS. FOSTER: Can you please read Ms. Khorram's messages in these rows, and I'll read Dave Shirley's.
ANANYA SANKAR: March 18, 2016, at 7:49 p.m., Kristina Khorram says to Dave Shirley Assist: "Can you head to the Four Seasons on Brickell side and set up his room. He's about to go now. He said bring Gatorade, water, chicken noodle soup too. Thank you. He wants you to go right now, please."
MS. FOSTER: "OK. Cool." After these four messages, is there then a gray bar denoting a jump in time?
ANANYA SANKAR: Yes.
MS. FOSTER: And approximately how long is that jump in time?
ANANYA SANKAR: About 30 minutes.
MS. FOSTER: And then turning to the set of messages after this gray bar, who are the participants in the messages shown in rows 6 to 15?
ANANYA SANKAR: Kristina Khorram and Dave Shirley Assist.
MS. FOSTER: So the same participants?
ANANYA SANKAR: Yes.
MS. FOSTER: And do these text messages appear to be related to the earlier conversation about setting up a hotel?
ANANYA SANKAR: Yes.
MS. FOSTER: Now focusing on the next batch of messages from rows 16 to 20, are these still messages between Kristina Khorram and Dave Shirley?
ANANYA SANKAR: Yes.
MS. FOSTER: And can you please read Ms. Khorram's messages in these rows and I'll read Dave Shirley's: "OK. Is an Uber taking them still?"
ANANYA SANKAR: "Yeah, he's on way."
MS. FOSTER: "Roc riding with him. "OK."
ANANYA SANKAR: "No to Roc. Just CC and PD."
MS. FOSTER: And now, after these messages, is there another gray bar?
ANANYA SANKAR: Yes.
MS. FOSTER: And what time jump does that indicate?
ANANYA SANKAR: It's about an hour.
MS. FOSTER: Now, focusing on line 22, who is this text between?
ANANYA SANKAR: Melissa Feola and Kristina Khorram.
MS. FOSTER: And can you read that text?
ANANYA SANKAR: "Adjoining room not avail. Hotel now sold out. Talked one-bedroom down to 2,550 per his request plus booked it."
MS. FOSTER: And after this message, is there another jump in time?
ANANYA SANKAR: Yes.
MS. FOSTER: Approximately how long?
ANANYA SANKAR: About a day, to the next morning.
MS. FOSTER: Now I will -- and who are these messages between?
ANANYA SANKAR: Dave Shirley Assist and Kristina Khorram and Melissa Feola.
MS. FOSTER: OK. I will read Mr. Shirley's messages. And can you please read Ms. Khorram's? Dave Shirley to Kristina Khorram: "Clayton Howard needs access to room."
ANANYA SANKAR: "Hey, M. Dave needs to add the name Clayton Howard to the Four Seasons hotel room. He needs access ASAP. Can you help?"
MS. FOSTER: Ms. Foster, can you please turn to the next page.
MS. FOSTER: Keep reading.
ANANYA SANKAR: "They are giving him a hard time."
MS. FOSTER: Dave Shirley Assist: "I got it added." Now, after these messages, is there a subsequent jump in time?
ANANYA SANKAR: Yes. Again, about a day.
MS. FOSTER: And can you please read Ms. Khorram -- and is it again between Ms. Khorram and Dave Shirley after that jump in time?
ANANYA SANKAR: Yes.
MS. FOSTER: Can you read Ms. Khorram's messages, and I'll read Mr. Shirley's.
ANANYA SANKAR: At 6:29 p.m.: "Definitely yes to your mom's. Also can you $4,000 cash from Roc to PD hotel. He said just ask Roc for it. Thanks."
MS. FOSTER: Dave Shirley: "OK. Did you ask Roc already or should I hit him?"
ANANYA SANKAR: "Haven't asked him yet so you can just hit him."
MS. FOSTER: Thank you. And are all those messages we just went through, are they from that two-day time period you just mentioned?
ANANYA SANKAR: Yes.
MS. FOSTER: Now, I want to jump ahead and talk about another set of records on this chart.
MS. FOSTER: Can we look at rows 33 to 49, and before these rows, is there a blue bar?
ANANYA SANKAR: Yes.
MS. FOSTER: And again, what does that blue bar indicate?
ANANYA SANKAR: A larger lapse in time, so this one looks like about three months.
MS. FOSTER: OK. And what is the type of record shown in these rows?
ANANYA SANKAR: These are text messages.
MS. FOSTER: Who are the participants in these text messages?
ANANYA SANKAR: Kristina Khorram, Ryan Lopez and Dave Shirley Assist.
MS. FOSTER: Can you please read Ms. Khorram's messages, starting at row 33, and I'll read the others.
ANANYA SANKAR: At 2:35 a.m.: "Heads-up. He's probably about to do wild king tonight."
MS. FOSTER: Mr. Shirley: Shit. Need to re-up on baby oil and shit."
ANANYA SANKAR: "Yeah, you can head out and get everything ready. Also sounds like now he is going to Malibu."
MS. FOSTER: Is there a jump in time?
ANANYA SANKAR: Yes.
MS. FOSTER: Approximately how long?
ANANYA SANKAR: About an hour.
MS. FOSTER: Mr. Shirley: "Forgot to grab the money and package from you. SMFH."
ANANYA SANKAR: "Ugh." Dave: "Well, you still might see me. LOL."
MS. FOSTER: Dave Shirley: LOL. Just give it to Fah just in case." And now is there a subsequent jump in time?
ANANYA SANKAR: Again, about half an hour.
MS. FOSTER: Can you read Ms. Khorram's message?
ANANYA SANKAR: "Dave, get the envelope from Fah."
MS. FOSTER: "I got it. Thank you." Is there then about 36 hours of a jump in time?
ANANYA SANKAR: Yes.
MS. FOSTER: Can you keep reading?
ANANYA SANKAR: "Hey, have you heard from him at all?"
MS. FOSTER: Mr. Shirley: "Nope, not at all." Is there then about a six-hour jump in time?
ANANYA SANKAR: Yes.
MS. FOSTER: And I'll read Mr. Shirley's message: "If he doesn't answer, I can get an envelope from downstairs and leave it at the door." Is there then about a minute between the next two -- between that message and the next one?
ANANYA SANKAR: Yes.
MS. FOSTER: And who is the next message from and to?
ANANYA SANKAR: From Kristina Khorram to Cassie Ventura.
MS. FOSTER: And what does Ms. Khorram say to Cassie Ventura?
ANANYA SANKAR: "Hi. Dave is at your door with the green."
MS. FOSTER: Now I want to jump ahead in time to another set of records on this chart. Ms. Foster, can we please go to page 8. And can we please focus on rows 124 to 133, which appear at the bottom of -- and these -- sorry. 124 starts at the bottom of page 8 and 133 goes through page 9.
MS. FOSTER: Ms. Sankar, are all of the communications in these rows from the same date?
ANANYA SANKAR: Yes.
MS. FOSTER: What is that date?
ANANYA SANKAR: November 14, 2021.
MS. FOSTER: What type of record is shown in these rows?
ANANYA SANKAR: These are text messages.
MS. FOSTER: Who are the participants in all of the text messages in that batch I just spoke about?
ANANYA SANKAR: Sean Combs and Kristina Khorram.
MS. FOSTER: Ms. Sankar, starting at row 124, can you please read Ms. Khorram's messages, and I'll read Mr. Combs's messages: "Is room ready now?"
ANANYA SANKAR: "On with them now. Any minute. Joey's there to check in and heard Jane on the way to hotel too, so he can drop bags and let her in."
MS. FOSTER: "I'm on way. I really don't want them to know it's me. LOL. No unneeded charges."
ANANYA SANKAR: "OK. I would wait until at least Joey and Jane get into the room."
MS. FOSTER: Ms. Foster, turn to the next page. A. "And then you go, so maybe like 20 min and maybe you are up in the room and stuff is too."
MS. FOSTER: What does this chart show happens about 30 minutes later, after Ms. Khorram sends that prior text?
MS. GERAGOS: Objection.
THE COURT: Hold on for one second. Can you rephrase the question.
BY MS. FOSTER:
MS. FOSTER: Is there a jump in time?
ANANYA SANKAR: Yes.
MS. FOSTER: And approximately how long is that?
ANANYA SANKAR: About 30 minutes.
MS. FOSTER: And can you read the next message?
ANANYA SANKAR: From Sean Combs to Kristina Khorram: "I'm room. Thank you."
MS. FOSTER: And then is there another jump in time?
ANANYA SANKAR: Yes.
MS. FOSTER: About how many minutes?
ANANYA SANKAR: Again, about, maybe, 20 minutes.
MS. FOSTER: What does Ms. Khorram then write to Mr. Combs?
ANANYA SANKAR: "Hotel called. Paul coming up."
MS. FOSTER: This message mentioned someone named Paul, is that right?
ANANYA SANKAR: Yes.
MS. FOSTER: Are there additional messages in this chart that mention a Paul?
ANANYA SANKAR: Yes, there are.
MS. FOSTER: OK. We'll come back to that, but let's skip ahead in time again. Ms. Foster, can we please go to page 11.
MS. FOSTER: Ms. Sankar, directing your attention to rows 169 to 191, which start on this page and then go through the following page, what is the date range of these records?
ANANYA SANKAR: February 12, 2022, until March 3, 2022.
MS. FOSTER: Sorry. Through 191.
ANANYA SANKAR: Oh. Apologies. February 12, 2022, until February 14, 2022.
MS. FOSTER: So about a two-day period?
ANANYA SANKAR: Yes.
MS. FOSTER: What type of record is shown in all these rows?
ANANYA SANKAR: These are text messages.
MS. FOSTER: And who are these messages between?
ANANYA SANKAR: Kristina Khorram and Sean Combs and some Jane and Kristina Khorram.
MS. FOSTER: OK. You mentioned that one of the participants in these messages is someone named Jane. Was Jane a real name of a person on the records you reviewed?
MS. FOSTER: OK. Your Honor, before I display the next exhibits, could we turn off the overflow feed and the TV screen?
THE COURT: All right. I'll ask the deputy to turn off those feeds. Just let us know when we have that off.
COURT CLERK: Yes, your Honor. One moment. Ready to proceed, your Honor.
THE COURT: All right. Ms. Foster, you may proceed.
MS. FOSTER: Ms. Foster, would you please display just for the witness, the Court and the jury what is in evidence as Government Exhibit 3R-121.
MS. FOSTER: Do you see that document, Ms. Sankar?
ANANYA SANKAR: Yes.
MS. FOSTER: Without saying the name, what type of document is shown in this exhibit?
ANANYA SANKAR: This is a driver's license.
MS. FOSTER: And how do you refer to the person on this driver's license in your chart?
ANANYA SANKAR: Jane.
MS. FOSTER: Why did you refer to this person as Jane?
ANANYA SANKAR: That was the alias told to me by the attorneys to be used for this individual.
MS. FOSTER: OK. Thank you, Ms. Foster. You can take this down, and we can turn back on the screens. Ms. Foster, can you please display Government Exhibit 1411R again and go back to page 11.
MS. FOSTER: OK. Ms. Sankar, could you now read rows 169 -- read Ms. Khorram's messages in rows 169 to 171.
ANANYA SANKAR: February 12, 2022, at 3:44 p.m.: "You just told me the One a few hours ago. "We had hotel already. "Also, just FYI, just to share, your damage charges on the One hotel are always high because of all the white."
MS. FOSTER: Is there then a jump in time?
ANANYA SANKAR: Yes.
MS. FOSTER: How long is that?
ANANYA SANKAR: Four hours.
MS. FOSTER: Sorry. Is it also the next day?
ANANYA SANKAR: Oh. Apologies. Yes, the next day.
MS. FOSTER: And who are the messages between after the gray bar?
ANANYA SANKAR: Jane and Kristina Khorram.
MS. FOSTER: Can you please read Ms. Khorram's messages, and I'll read Jane's: Jane: "Hi, hon. Yes, pulling up to airport, yay. How are you? Hopefully, the 14th, morning is OK with the room. I'm excited to surprise him."
ANANYA SANKAR: "OK. Great. I'm good. It all always works out."
MS. FOSTER: Is there then another jump in time?
ANANYA SANKAR: Yes.
MS. FOSTER: And how long?
ANANYA SANKAR: Through the next day.
MS. FOSTER: Can you keep reading Ms. Khorram's messages?
ANANYA SANKAR: "Also, ask them if they can bring up, like, 15 bath towels for two."
MS. FOSTER: "OK. Will do. Hey, just thinking ahead. He's always bringing cash. Maybe when security arrives, he could also have that with him. He always brings around 5 to 10K."
ANANYA SANKAR: "I'll remind him. He's got his cash with him."
(Continued on next page)
By Ms. Foster (Continued)
MS. FOSTER: Can we turn to the next page. Is there then a jump in time indicated by the gray bar?
ANANYA SANKAR: Yes.
MS. FOSTER: Approximately how long is that? Do you need us to go back to the prior page? We can do that. Ms. Foster, could we just briefly go back?
ANANYA SANKAR: About 20 minutes.
MS. FOSTER: Thank you. Can we go back? Thank you. Then can you read Ms. Khorram's messages? And who are the messages to directly after that gray bar?
ANANYA SANKAR: They're from Kristina Khorram to Sean Combs.
MS. FOSTER: Can you please read them?
ANANYA SANKAR: FYI. They are going through bags at FBO, so you should carry your black with backpack.
MS. FOSTER: Is there another gray bar?
ANANYA SANKAR: Yes.
MS. FOSTER: How long of a jump in time does that indicate?
ANANYA SANKAR: About an hour.
MS. FOSTER: I'll read Jane's message, if you can read Ms. Khorram's. KK still landing at 2P, right, then 45 min drive to hotel. I went to run an errand, and also they're expecting people to leave the presidential suite by 12P hopefully. Room decor begins at 1P. Take 30 to 40 min.
ANANYA SANKAR: Hey, you will be good on timing. We are just now taking off.
MS. FOSTER: Is there then another jump in time?
ANANYA SANKAR: Yes.
MS. FOSTER: Approximately how long?
ANANYA SANKAR: About three hours.
MS. FOSTER: Who are those messages from and to?
ANANYA SANKAR: From Kristina Khorram to Sean Combs.
MS. FOSTER: Can you please read those two messages?
ANANYA SANKAR: Also Jane asked if you could bring 5 to 10K in cash. It's all in your safe.
MS. FOSTER: Is there then another jump in time?
ANANYA SANKAR: Yes.
MS. FOSTER: How long approximately?
ANANYA SANKAR: An hour.
MS. FOSTER: What is shown after that gray bar?
ANANYA SANKAR: This is an audio message sent in the text message chain.
MS. FOSTER: Just focusing on the source row, which I think is hidden now, what is the source for that audio file?
ANANYA SANKAR: C-629-3-A.
MS. FOSTER: Ms. Foster, can you just please quickly play C-629-3-A.
(Audio played)
MS. FOSTER: I want to turn to another batch of records on this chart. Ms. Sankar, directing your attention to the rows starting at row 193 on this page, through 218, which follows onto -- which continues onto page 14. Do you see those in the chart in front of you?
ANANYA SANKAR: Yes.
MS. FOSTER: What is the date range of this batch of records?
ANANYA SANKAR: March 3, 2022 until March 4, 2022.
MS. FOSTER: So about a day period?
ANANYA SANKAR: Yes.
MS. FOSTER: What type of record is shown in those rows?
ANANYA SANKAR: These are text messages.
MS. FOSTER: And who are the text messages between in all of these rows?
ANANYA SANKAR: Kristina Khorram and Jane.
MS. FOSTER: At some point does it change?
ANANYA SANKAR: Yes.
MS. FOSTER: And who does it then become?
ANANYA SANKAR: Jessica Ruiz and Kristina Khorram.
MS. FOSTER: Just focusing on the messages from row 193 through the end of page 12, just generally what is the substance of these messages?
ANANYA SANKAR: It looks like they're's setting up a flight.
MS. FOSTER: Who is the flight for?
ANANYA SANKAR: Jane.
MS. FOSTER: Okay. Ms. Foster, can we turn to the next page.
MS. FOSTER: How much longer is this message from the ones we just read? How much after?
ANANYA SANKAR: It's about an hour later.
MS. FOSTER: And what appears to be shown in this message?
ANANYA SANKAR: This is flight information.
MS. FOSTER: And who sends that flight information?
ANANYA SANKAR: Jessica Ruiz.
MS. FOSTER: To?
ANANYA SANKAR: To Kristina Khorram.
MS. FOSTER: Who does the flight appear to be for?
ANANYA SANKAR: Arthur, Jr., Paul.
MS. FOSTER: Where is the flight from?
ANANYA SANKAR: It's from Los Angeles.
MS. FOSTER: And where does it appear to be to?
ANANYA SANKAR: Miami International Airport.
MS. FOSTER: What does it appear that the date of the flight is?
ANANYA SANKAR: March 6, 2022.
MS. FOSTER: Now, Ms. Foster, can we turn to the next page.
MS. FOSTER: Ms. Sankar what does CTD indicate at the top of that row?
ANANYA SANKAR: That just means the entire message didn't fit in the box on the previous page, so it's just continued in the next column.
MS. FOSTER: Is there then a message after this one?
ANANYA SANKAR: Yes.
MS. FOSTER: Who is that from?
ANANYA SANKAR: From Jessica Ruiz.
MS. FOSTER: Is it also to Ms. Khorram?
ANANYA SANKAR: Why.
MS. FOSTER: What does she write in that message?
ANANYA SANKAR: Paul.
MS. FOSTER: Is there then a gray bar after that message?
ANANYA SANKAR: Yes.
MS. FOSTER: And does that -- how long of a time does that denote?
ANANYA SANKAR: About two and a half hours.
MS. FOSTER: And who are the messages between after that gray bar?
ANANYA SANKAR: Kristina Khorram and Jane.
MS. FOSTER: Can you please read Ms. Khorram's messages, and I'll read Jane's.
ANANYA SANKAR: At 11:38 p.m. Hey, per PD, can you swing by Mapleton on your way to airport to pick up Guido package?
MS. FOSTER: Hey babe. Yes, of course. I asked Jess if they could grab me earlier.
ANANYA SANKAR: Yeah. Just text her and let her know when you want the car.
MS. FOSTER: Okay, cool.
ANANYA SANKAR: Hi. Security at the Mapleton house has the package. LMK when you are on the way.
MS. FOSTER: Sound good babe.
ANANYA SANKAR: Loved the previous message.
MS. FOSTER: Hey babe, we'll be at Mapleton by 7:45P.
ANANYA SANKAR: Loved the previous message.
MS. FOSTER: Hi hun. I'm here at back gate.
ANANYA SANKAR: Hey, sorry. Just saw you called. All good
MS. FOSTER: Yes, all good, smiley face. I'll message you once I'm on plane?
ANANYA SANKAR: Loved the previous message.
MS. FOSTER: Hi KK. Taking off now, exclamation mark. See you in the a.m. Now, just focusing on the row 205, who is the individual who is mentioned as associated with the package in that row?
ANANYA SANKAR: Guido.
MS. FOSTER: Are there additional chats in this chart that mention Guido?
ANANYA SANKAR: Yes.
MS. FOSTER: Okay. I want to talk about those.
MS. FOSTER: So, Ms. Foster, can we please go ahead in time to page 10.
MS. FOSTER: Now, directing your attention to row 141, what type of record is shown in this?
MS. GERAGOS: Objection to going ahead in time.
THE COURT: I'm sorry.
MS. GERAGOS: Objection to going ahead in time.
THE COURT: All right. Can you rephrase?
MS. FOSTER: Oh. What is this -- I withdraw "going ahead in time." And what is the record showing here in row 141?
ANANYA SANKAR: This is a text message.
MS. FOSTER: Who is it between?
ANANYA SANKAR: Jane and Kristina Khorram.
MS. FOSTER: Oh sorry, 144. I'm sorry, who is this one between?
ANANYA SANKAR: Kristina Khorram and Sean Combs.
MS. FOSTER: And who sends the message?
ANANYA SANKAR: Kristina Khorram.
MS. FOSTER: What is the date?
ANANYA SANKAR: December 16, 2021.
MS. FOSTER: What does Ms. Khorram write in this message?
ANANYA SANKAR: They said Guido still hasn't dropped off package to house.
MS. FOSTER: Now, Ms. Foster, could we please go to page 15. Could you please focus on rows 223 to 234.
MS. FOSTER: Ms. Sankar, what is the date of all the messages in this group?
ANANYA SANKAR: July 23, 2022.
MS. FOSTER: What type of records are shown in those rows?
ANANYA SANKAR: These are a mix of text messages and audio messages.
MS. FOSTER: Who are the audio and text messages between?
ANANYA SANKAR: Sean Combs and Kristina Khorram.
MS. FOSTER: What type of message is the first message that's shown in that row 223?
ANANYA SANKAR: It's an audio message.
MS. FOSTER: What is the source for that audio message?
ANANYA SANKAR: C-657-A.
MS. FOSTER: Ms. Foster, can you please play C-657-A.
(Audio played)
MS. FOSTER: What does Ms. Khorram write after that audio message?
ANANYA SANKAR: Yeah, been working on it. London sold out, so waiting on other options.
MS. FOSTER: Is there then a gap in time?
ANANYA SANKAR: Yes.
MS. FOSTER: Approximately how long?
ANANYA SANKAR: About 30 minutes.
MS. FOSTER: What is the file after that gap in time?
ANANYA SANKAR: It's an audio message.
MS. FOSTER: What is the source for that audio message?
ANANYA SANKAR: C-657-B.
MS. FOSTER: Ms. Foster, could we please play C-657-B.
(Audio played)
MS. FOSTER: Is there a response from Ms. Khorram to that message?
ANANYA SANKAR: Yes.
MS. FOSTER: What is the response?
ANANYA SANKAR: Okay.
MS. FOSTER: Is there then a gap in time?
ANANYA SANKAR: Yes.
MS. FOSTER: Approximately how long?
ANANYA SANKAR: 20 minutes.
MS. FOSTER: What is then -- who then writes the text message?
ANANYA SANKAR: Kristina Khorram.
MS. FOSTER: To whom?
ANANYA SANKAR: Sean Combs.
MS. FOSTER: What does Ms. Khorram write?
ANANYA SANKAR: Guido outside.
MS. FOSTER: Is there another gray bar indicating a lapse in time?
ANANYA SANKAR: Yes.
MS. FOSTER: Approximately how long is that lapse?
ANANYA SANKAR: About 12 minutes.
MS. FOSTER: What then is sent by Mr. Combs?
ANANYA SANKAR: Another audio message.
MS. FOSTER: What is the source for that audio message?
ANANYA SANKAR: C-657-C.
MS. FOSTER: Ms. Foster, could we please play C-657-C.
(Audio played)
MS. FOSTER: Does Ms. Khorram respond to that message?
ANANYA SANKAR: Yes.
MS. FOSTER: What does she write?
ANANYA SANKAR: Yeah, it's been handled.
MS. FOSTER: Ms. Foster, can we please go to page 17. And I want to direct your attention to another group of messages starting at row 271 through 275 which continue on to that next page. Are all of these messages from the same date?
ANANYA SANKAR: Yes.
MS. FOSTER: And what is that date?
ANANYA SANKAR: April 14, 2023.
MS. FOSTER: Who are the messages between?
ANANYA SANKAR: Faheem Muhammad, Robin Greenhill, Sean Combs and Kristina Khorram.
MS. FOSTER: Okay. Can you please read Mr. Muhammad's messages, and I'll read Mr. Combs' messages?
ANANYA SANKAR: 12:26 a.m. Faheem says $1,200 spend on flower today. $1,500 owed to Guido for misc. Let me know if approved to pay.
MS. FOSTER: Ms. Foster, can you please turn to the next page. No, hold up.
ANANYA SANKAR: About three hours later. This has been approved by PD. Paying now. Same vendor from above. An additional $1,800 has been approved.
MS. FOSTER: Approved. Does this chart summarize any chats in which drugs are mentioned?
ANANYA SANKAR: Yeah.
MS. FOSTER: Ms. Foster, can we go back to page 16.
MS. FOSTER: Ms. Sankar, directing your attention to rows 245 to 249, what date are all of these messages and time?
ANANYA SANKAR: November 24, 2022.
MS. FOSTER: What type of records are shown in these rows?
ANANYA SANKAR: Text messages.
MS. FOSTER: Who are these text messages between?
ANANYA SANKAR: Kristina Khorram, two different numbers for Sean Combs, and Faheem Muhammad.
MS. FOSTER: Could you please read Ms. Khorram's messages and I'll read Mr. Combs?
ANANYA SANKAR: At 1:00 a.m., Puff can you text Fah what you need him to pick up before his flight to Miami, please.
MS. FOSTER: Audio message. I told you.
ANANYA SANKAR: No, all you asked was if someone was coming from Miami to bring something. You didn't give the final info. I'll call you when off this group call or you can just call Fah directly as well.
MS. FOSTER: Molly 15 pills. Don't text though.
MS. GERAGOS: Objection.
MS. FOSTER: Oh don't. Text think though.
THE COURT: I thought that resolved the objection. I'm not hearing anything --
MS. GERAGOS: That resolved the objection.
THE COURT: Let's proceed.
MS. FOSTER: You previously walked through some messages about money in connection with hotel room messages, is that right?
ANANYA SANKAR: Yes.
MS. FOSTER: Are there additional messages summarized in this chart on that topic?
ANANYA SANKAR: Yes.
MS. FOSTER: Ms. Foster, can you please turn to page 18. Now, directing your attention to rows 277 to 278, what is the date of both mention on those rows
ANANYA SANKAR: April 20, 2023.
MS. FOSTER: And what type of messages are shown here?
ANANYA SANKAR: Text messages.
MS. FOSTER: Who are those texts between?
ANANYA SANKAR: Faheem Muhammad, Robin Greenhill, Sean Combs and Kristina Khorram.
MS. FOSTER: And can you please read Mr. Muhammad's texts, and I'll read Mr. Combs.
ANANYA SANKAR: 2:17 a.m. just gave 5K to Brendan for hotel.
MS. FOSTER: Sean Combs: Okay. Are there also additional messages in this chart that discuss cash?
ANANYA SANKAR: Yes.
MS. FOSTER: Does this chart also summarize certain messages involving Ms. Cassie Ventura?
ANANYA SANKAR: Yes.
MS. FOSTER: Have we previously reviewed some of those messages?
ANANYA SANKAR: Yes.
MS. FOSTER: And are there additional messages in which Ms. Vent is a participant, or is discussed?
ANANYA SANKAR: Yes, there are.
MS. FOSTER: Ms. Foster, can we go back to page 5.
MS. FOSTER: Ms. Sankar, directing your attention to rows 71, which start on this page, through row 85 on the following page, do all of these messages happen on the same day?
ANANYA SANKAR: Could you go to the next page, please. Yes they do.
MS. FOSTER: What is that date?
ANANYA SANKAR: May 2, 2017.
MS. FOSTER: What type of records are shown in those rows?
ANANYA SANKAR: These are text messages.
MS. FOSTER: And who are they between?
ANANYA SANKAR: Cassie Ventura and two different numbers for Kristina Khorram.
MS. FOSTER: Is there also a few messages between Ms. Khorram and Mr. Roche, Derek Roche?
ANANYA SANKAR: Yes, I believe on the previous page.
MS. FOSTER: Oh, sorry -- we'll come back to it. Can you please read Ms. Khorram's message, and I'll read Ms. Ventura's message.
MS. FOSTER: WTF
ANANYA SANKAR: A couple hours later. You okay?
MS. FOSTER: No, but you should talk to him. I'm sure you don't want to get involved, but he said I was an asshole which I owned up to but no one deserves being dragged by their hair. I locked the door for my safety. I invited one girl BC he wanted her there. I don't have my stuff. I don't even have money. I'm fucked.
ANANYA SANKAR: He went right up after you left and haven't seen him since, but I will try and talk to him when he's up. And I can help when you want your stuff. That red money pouch with cash should be in one of your bags. I threw it to Ralph to put in there, so hopefully that will help till you come back here.
MS. FOSTER: Thanks babe. He's up texting me. Then who are the next two messages between?
ANANYA SANKAR: Derek Roche and two different numbers for Kristina Khorram.
MS. FOSTER: And how long after the prior message we read with Ms. Ventura and Mr. Khorram do those messages occur?
ANANYA SANKAR: A minute later.
MS. FOSTER: I'll read Mr. Roche's messages if you can read Ms. Khorram's. WTF.
ANANYA SANKAR: Ugh, I know.
MS. FOSTER: Could we go to another batch of records starting at row 87 which is at the bottom of this page, through 92, at the bottom of -- at the bottom of the following page. Okay. When do these messages occur relative to the prior messages we read, approximately?
ANANYA SANKAR: These are about a year later.
MS. FOSTER: What is the date of all the messages in rows 87 to 93?
ANANYA SANKAR: April 20, 2018.
MS. FOSTER: What type of records are shown in these rows?
ANANYA SANKAR: These are text messages.
MS. FOSTER: And who are they between?
ANANYA SANKAR: Cassie Ventura and Kristina Khorram.
MS. FOSTER: Again, I'll read Ms. Ventura's message if you could please read Ms. Khorram's. Hey, I'm sorry about last night. I can't do the violent scary kick me out of my own house stuff any more. I got Kerry and bounced. I hope your night didn't suck. I didn't get to do my sleep study last night because I rushed out and didn't even bring anything. I have a lot to do today, including going to their office. I called. They haven't charged for canceling. I don't even know what to say. I just can't any more.
ANANYA SANKAR: Two hours later. Are you okay? I don't know what else to say but I'm here if you need anything, heart emoji.
MS. FOSTER: Ms. Foster could we turn to the next page. I'll just read the remaining messages on -- in the top three rows. Or I'll read Ms. Ventura's if you could read Ms. Khorram's. I'm okay, just bummed. I don't know what's going on, but I just want to stay focused.
ANANYA SANKAR: I'm sure. Stay focused though. It's not worth de-railing, that much I know.
MS. FOSTER: Definitely. Does this chart also summarize certain records in which Jane is a participant or is discussed?
ANANYA SANKAR: Yes.
MS. FOSTER: Did we walk through some of those messages already?
ANANYA SANKAR: Yes, we did.
MS. FOSTER: Now I want to talk about some other messages involving Jane on this chart and walk through those chronologically.
MS. FOSTER: Ms. Foster, could we go to page 20.
MS. FOSTER: Now, focusing on row 300, what is shown on that row
ANANYA SANKAR: A text message.
MS. FOSTER: From and to whom?
ANANYA SANKAR: From Kristina Khorram to Sean Combs.
MS. FOSTER: What is the date of that message?
ANANYA SANKAR: May 16, 2023.
MS. FOSTER: Could you please read this message?
ANANYA SANKAR: FYI - Robin said she paid Jane's rent last week.
MS. FOSTER: Okay. I want to go to page 23. Focusing on the group of records in rows 328 to 361, which continues through page 26.
MS. FOSTER: How long of a time jump is there between these records and that one we just saw?
ANANYA SANKAR: Could we go back to the previous record?
MS. FOSTER: Yeah. It is 20 -- sorry, page 20.
ANANYA SANKAR: So about six months.
MS. FOSTER: Okay.
ANANYA SANKAR: Five, six months.
MS. FOSTER: Could we please go back to 23.
MS. FOSTER: Are all of the messages in rows 328 to 361 sent on the same date?
ANANYA SANKAR: Could we scroll to 361, please. Yes, they are.
MS. FOSTER: Except for the last message -- oh no, you're right. Sorry.
MS. FOSTER: Could we go back to page 23?
MS. FOSTER: What type of record are shown in these rows?
ANANYA SANKAR: These are text messages.
MS. FOSTER: Who are they between?
ANANYA SANKAR: Jane and Kristina Khorram.
MS. FOSTER: And are they all from the same exhibit, just looking at the source column, briefly?
ANANYA SANKAR: Yes, they are.
MS. FOSTER: Could you please read just the first three messages from Jane to Ms. Khorram?
ANANYA SANKAR: Also just keeping it real W you. I'm not doing any more hard partying. We recently got into a pretty big fight, and I'm putting my foot down about it. No more hotel nights and all of that stuff. So I hope he's not expecting a hotel night type of vibe for me because I just can't. I don't want to turn up like that. Just wanna celebrate him like a normal person would. I can definitely bring a cake and some flowers, and I can work on balloons. Then Friday I'm going to wrap his gift up really cute and have it sent to the house and all that.
MS. FOSTER: What is the date of this chat?
ANANYA SANKAR: November 2, 2023.
MS. FOSTER: Can we please now go to page 26. What is shown in row 363?
ANANYA SANKAR: That is a legal filing.
MS. FOSTER: What is the name of that legal filing?
ANANYA SANKAR: Ventura v. Sean Combs, et al.
MS. FOSTER: And what is the date of that filing?
ANANYA SANKAR: November 16, 2023.
MS. FOSTER: How long after those last messages in which Jane said she's not doing any more hard partying is this legal filing from?
ANANYA SANKAR: Two weeks.
MS. FOSTER: What are the next rows shown on this chart, 365 and 366?
ANANYA SANKAR: These are audio files found on Kristina Khorram's device.
MS. FOSTER: What is the date of these two audio files?
ANANYA SANKAR: November 19, 2023.
MS. FOSTER: How far apart are the times of the audio files?
ANANYA SANKAR: About 20 minutes.
MS. FOSTER: And how much after the legal filing are these audio files?
ANANYA SANKAR: Three days later.
MS. FOSTER: Now, again, what device were these found on?
ANANYA SANKAR: Kristina Khorram's device.
MS. FOSTER: Directing your attention to the from and to columns, what does that indicate?
ANANYA SANKAR: That indicates who the participants within that audio recording might be.
MS. FOSTER: And how did you determine that?
ANANYA SANKAR: I was shown a transcript by the prosecutors of prior testimony which indicates that Jane acknowledges she listened to this audio file, and it was her speaking on both with Sean Combs.
MS. FOSTER: And what is indicated in the content or file name column?
ANANYA SANKAR: That is the file name of the audio file found on the device.
MS. FOSTER: What is the audio file exhibit number for both of these audio files?
ANANYA SANKAR: The first one is C-348-A-R, and the second one is C-348-B-R.
MS. FOSTER: Ms. Foster, could we please play Government Exhibit C-348-A-R.
(Audio played)
MS. FOSTER: Can you also please play C-348-B-R.
(Audio played)
MS. FOSTER: Thank you.
MS. FOSTER: Again, whose device were those found on?
ANANYA SANKAR: Kristina Khorram's.
MS. FOSTER: Now, is there a jump in time after these audio files?
ANANYA SANKAR: Yes.
MS. FOSTER: Approximately how long?
ANANYA SANKAR: About three days -- two days.
MS. FOSTER: What are the messages in the three rows below? What date are those from?
ANANYA SANKAR: November 21, 2023.
MS. FOSTER: Who are they between?
ANANYA SANKAR: Kristina Khorram and Sean Combs.
MS. FOSTER: And are these text messages?
ANANYA SANKAR: Yes.
MS. FOSTER: Could you please read Ms. Khorram's messages, and I'll read Mr. Combs.
ANANYA SANKAR: If you cannot be honest with me, this doesn't work. We literally just went through you choosing to keep things to yourself and hide them, and we know this put us where we all are now. We all know what your kryptonite is and where you don't make the best choices. And that downstairs was weird and felt like a lie. It's not sitting right with me at all.
MS. FOSTER: Come take my phone.
ANANYA SANKAR: Has nothing to do with taking your phone if you're starting to lie about anything to me. I'm just saying that will break me. And I'll just feel like we are about to live this shit all over again.
MS. FOSTER: Ms. Foster, could we go to the next page.
MS. FOSTER: Focusing on the first five messages on this page, when are these sent relative to the ones we just read?
ANANYA SANKAR: A few hours later.
MS. FOSTER: Can we go back?
ANANYA SANKAR: Few minutes later.
MS. FOSTER: And who are the messages on this next page between?
ANANYA SANKAR: Sean Combs and Kristina Khorram.
MS. FOSTER: Are these text messages again?
ANANYA SANKAR: Yes.
MS. FOSTER: Can you read Ms. Khorram's messages and I'll read Mr. Combs. Make sure Robin is not doing anything dumb like not having that rent paid on time. Can you make sure she paid for this month please. And please let me know when she hits me because when you don't, it's not the best decision. Call me. Why you not picking up?
ANANYA SANKAR: Robin said her rent was paid.
MS. FOSTER: Okay. Now, turning to the next row, row 378, what is shown here
ANANYA SANKAR: This is an image found on Kristina Khorram's device.
MS. FOSTER: And what does that image appear to be of?
ANANYA SANKAR: It's a picture of a phone screen with text messages on it.
MS. FOSTER: Why do you say a phone screen with text messages on it?
ANANYA SANKAR: You can see the edges of the screen which indicates it's probably not a screenshot and most likely a picture of a phone screen.
MS. FOSTER: What is the creation date and time of this image?
ANANYA SANKAR: December 28, 2023 at 12:23 a.m.
MS. FOSTER: Do you know who sent and received this message?
MS. FOSTER: Why not?
ANANYA SANKAR: There is no phone number or contact name listed in this image.
MS. FOSTER: Can you read just the first three sentences of the message?
ANANYA SANKAR: I don't believe the lovely dovey stuff. You don't need to go there with me. I was confused and couldn't concentrate for three years and feel extremely exploited, heartbroken and manipulated by you. In that time I lost many work opportunities following you around being high and coerced into this dark and humiliating lifestyle.
MS. FOSTER: And does it continue?
ANANYA SANKAR: Yes.
MS. FOSTER: Now, Ms. Foster, can we turn to the next page.
MS. FOSTER: What appears on this page?
ANANYA SANKAR: This is also an image of text messages chats on a phone.
MS. FOSTER: Is that from the same date?
ANANYA SANKAR: Yes.
MS. FOSTER: What is that date?
ANANYA SANKAR: December 28, 2023.
MS. FOSTER: Can you read the last four gray bubbles shown in this photo?
ANANYA SANKAR: You are the only opportunist here. You exploited the fuck out of me. You win. Three years of being used, and you had three years of fun with my body. You broke me. Our situation has never ever been fair to me. You asked me what I needed to move on, and now you're upset.
MS. FOSTER: And, Ms. Foster, can we turn to the next page.
MS. FOSTER: What is shown on this page?
ANANYA SANKAR: Text messages.
MS. FOSTER: And when are these messages sent relative to that image we just looked at?
ANANYA SANKAR: On the same day.
MS. FOSTER: Approximately how long after?
ANANYA SANKAR: Maybe a few hours after.
MS. FOSTER: Who are the text messages between?
ANANYA SANKAR: Jane and Kristina Khorram.
MS. FOSTER: Could you please read Jane's messages here?
ANANYA SANKAR: Hey, I know I would normally not involve you in anything, but he just threatened me about my sex tapes that he has of me on two phones. He said that he would expose me and send them to my baby daddy. He has been bothering me for two months after all I've been asking for is my space. I keep telling him that I just need some time with God and that I need time to move on from him. We broke up two weeks before the controversy for a lot of things stated in that lawsuit that I personally felt in my experience with him. When shit hit the fan, I had already entered into my own depression caused by him. He knew that and all I asked for was my space and quiet time. I'm traumatized from my experience with him, and I'm just privately healing and he keeps bothering me. He invites to fly me out, and I politely decline each time. Today he went from asking me who I'm seeing over and over again and saying he feels abandoned by him, how I've hurt him.
And when I reiterate all the trauma he's caused me and how mistreated I feel, he says I'm blackmailing him and started yelling and going crazy and saying charge him so we can both move on. And after I did what he asked me to do, came up with a number for everything he's put me through. Now he is threatening me and saying he would call the police and expose my tapes and send them to my child's father, and all of these evil ass bipolar psychotic episodes he's fucking having on me. Mind you, these are sex tapes where I am heavily drugged and doing things that he asked of me for the past three years that I am currently recovering from. It's all so extremely hurtful, very hurtful. For him to exploit me all this time and then threaten me W sex tapes. Please talk some sense into him because it isn't fair to me at all whatsoever. I'm beyond hurt by him.
MS. FOSTER: Ms. Foster, can we turn to the next page?
MS. FOSTER: What does Ms. Khorram respond?
ANANYA SANKAR: Hey there, about to read all this, and then call you in a bit. I really haven't seen or spoken to him in two days though.
MS. FOSTER: And what does Jane respond?
ANANYA SANKAR: Yes.
MS. FOSTER: Can you just read the first few sentences?
ANANYA SANKAR: I'm sure we're both emotionally drained right now. It's okay, no need to call. I'm just really stressed with him saying he would expose my sex tapes.
MS. FOSTER: Sorry. Can you just finish actually?
ANANYA SANKAR: I just sincerely want him to give me my space and quiet time. I'm not bothering him at all for anything at all. You are his right-hand woman, and woman to woman maybe if you hear my side, you can just simmer him down because he listens to you. It's okay just enjoy your night. I'm drained. Been crying all day. I'm fine. Thank you KK.
MS. FOSTER: Thank you. What shows up next on this chart?
ANANYA SANKAR: This is another image of a text message chat on the phone.
MS. FOSTER: Does it appear to be related to the prior images?
ANANYA SANKAR: Yes.
MS. FOSTER: When is this sent relative to that last text that we saw from Jane to Ms. Khorram?
ANANYA SANKAR: Two hours later.
MS. FOSTER: And can you just read the last three bubbles in this photo?
ANANYA SANKAR: Threatening me with sex tapes with men you had me fuck for your entertainment. Low. You are the one who has shown your truest colors to me. I'm clearer than I've ever been. So stop texting me and move on. You have taken me away from my family and fucked up the whole move. You win.
MS. FOSTER: Can we please turn to the next page, Ms. Foster.
MS. FOSTER: Does Ms. Khorram then write Jane a message?
ANANYA SANKAR: Yes.
MS. FOSTER: At what time?
ANANYA SANKAR: 5:34 a.m.
MS. FOSTER: What does she write?
ANANYA SANKAR: Just tried you.
MS. FOSTER: Okay. Turning to the next three rows, rows 390 to 392, what is shown in these rows?
ANANYA SANKAR: These are videos found on Kristina Khorram's device.
MS. FOSTER: Whose device were -- you've already answered. Again, whose device were these found on?
ANANYA SANKAR: Kristina Khorram.
MS. FOSTER: What is the date and time of these videos?
ANANYA SANKAR: December 28, 2023 at 6:07 a.m.
MS. FOSTER: How long after that is that last text from Ms. Khorram to Jane?
ANANYA SANKAR: Half an hour later.
MS. FOSTER: What generally do these videos show?
ANANYA SANKAR: These are videos of a phone with text messages pulled up on it.
MS. FOSTER: Do they appear to be the same text messages we saw photos of?
ANANYA SANKAR: Yes.
MS. FOSTER: Ms. Foster, can we just pull up the exhibit cited in the last row GX-C-362-E and play it.
(Audio played)
MS. FOSTER: What do you hear in the background of this video?
ANANYA SANKAR: A woman's voice.
MS. FOSTER: What appears to be holding the phone?
ANANYA SANKAR: Someone's hand.
MS. FOSTER: Okay. Do you see that hand in this picture?
ANANYA SANKAR: Yes.
MS. FOSTER: What do you notice about the hand?
ANANYA SANKAR: It has like a long kind of manicured nail.
MS. FOSTER: Now, Ms. Foster, can we go back to Government Exhibit 1411-R. I want to walk through a final batch of mention from this chart. Can we turn to page 31.
MS. FOSTER: Ms. Sankar, directing you to the messages starting at rows 398 through 4014, which is on the next page, what is the date of all of these messages?
ANANYA SANKAR: February 18, 2024.
MS. FOSTER: How long is that after which that conversation between Jane and Ms. Khorram and those photos were on her device?
ANANYA SANKAR: A year later.
MS. FOSTER: Is it a full year?
ANANYA SANKAR: A little over a year later.
MS. FOSTER: Sorry?
ANANYA SANKAR: Apologies. It is two months later.
MS. FOSTER: Okay. And who are these messages between?
ANANYA SANKAR: Brendan Paul and Kristina Khorram.
MS. FOSTER: Can you please read Ms. Khorram's messages, and I'll read Mr. Paul's. About to head to Jane's. he's on a call walking around out back. Seeing if he wants me to go as well. Ask J9 to drive.
ANANYA SANKAR: Liked the previous message.
MS. FOSTER: En route to guests.
ANANYA SANKAR: Yeah, that was me he was on the phone with. LOL. He mentioned going there. You might need king stuff potentially.
MS. FOSTER: He had me hop in super fast, so I don't have, but I'll make it happen if so. I think he just wants to say what's up and check on her because she's been sick, so fingers crossed, I'll keep you updated. Is there a lapse of time between that message and the next one?
ANANYA SANKAR: Yes.
MS. FOSTER: And how long?
ANANYA SANKAR: About three hours.
MS. FOSTER: What does Ms. Khorram write?
ANANYA SANKAR: They just chilling at her house?
MS. FOSTER: Yeah, he's just going with the flow.
ANANYA SANKAR: LOL, so basically he's lit?
MS. FOSTER: Isn't lit lit. I just spoke with him over the phone, maybe a little but seemed totally fine. And then is there another gap in time?
ANANYA SANKAR: Yes.
MS. FOSTER: About how long?
ANANYA SANKAR: Six hours.
MS. FOSTER: PD act -- is it the same participants?
ANANYA SANKAR: Yes.
MS. FOSTER: PD active now. Running to Wal-Mart for them.
ANANYA SANKAR: Like wild king mode active or Gucci bag active?
MS. FOSTER: In between the two.
ANANYA SANKAR: Copy.
MS. FOSTER: If that makes sense, LOL. Now that we've gone through a number of different mention from Government Exhibit 1411-R, did we go through all of the messages in this Government Exhibit or just some of them?
ANANYA SANKAR: Just some of them.
MS. FOSTER: Your Honor, if you want to take a break, we're about to turn to another chart.
THE COURT: Very good. We're about to take a break at this time. Be back in 15 minutes. Thank you all members of the jury. All rise
(Jury not present)
THE COURT: Be back in 15.
(Recess)
THE COURT: Ms. Foster, are we prepared to move forward.
MS. FOSTER: Yes, we are.
THE COURT: Let's bring back Ms. Sankar, and then we'll bring our jury in.
(Witness and jury present)
THE COURT: Ms. Foster, you may proceed when ready.
MS. FOSTER: Ms. Foster, can you now pull up Government Exhibit 1410-R.
BY MS. FOSTER:
MS. FOSTER: Ms. Sankar, is this another summary chart that you reviewed for accuracy?
ANANYA SANKAR: Yes.
MS. FOSTER: Can you please explain what Government Exhibit 1410-R shows.
ANANYA SANKAR: This is a timeline of communications including text messages between three participants: Sean Combs Damion Butler and Mia. It also includes call records taken from call logs.
MS. FOSTER: And is Mr. Butler also listed by an a/k/a here?
ANANYA SANKAR: Yes.
MS. FOSTER: What is it?
ANANYA SANKAR: D-Roc.
MS. FOSTER: What order are these calls and text messages listed in the summary chart?
ANANYA SANKAR: In chronological order.
MS. FOSTER: Can we focus on the top row of page 1. What is the earliest communication on this chart?
ANANYA SANKAR: November 18, 2023.
MS. FOSTER: How many pages is this chart?
ANANYA SANKAR: 11 pages.
MS. FOSTER: Ms. Foster, can we go to page 11?
MS. FOSTER: What is the last entry on this chart?
ANANYA SANKAR: February 7, 2024.
MS. FOSTER: You mentioned before that one of the participants in these communications is someone named Mia, is that right?
ANANYA SANKAR: Correct.
MS. FOSTER: Was Mia the real name of the person on the records you reviewed?
MS. FOSTER: Your Honor, before I display the next exhibit, I would ask we turn over the overflow feed and TV screen again.
THE COURT: Let me ask the deputy to confirm when that has been done. DEPUTY CLERK: Ready to proceed, your Honor.
THE COURT: Ms. Foster.
MS. FOSTER: Ms. Foster, can you display for the witness, the Court, and the jury what is in he evidence as Exhibit 3T-113.
MS. FOSTER: Ms. Sankar, can you let me know when you see that.
ANANYA SANKAR: I see it.
MS. FOSTER: Without saying the name, what type of document is shown in this exhibit?
ANANYA SANKAR: This is a passport.
MS. FOSTER: How did you refer to the person shown in the passport in your chart?
ANANYA SANKAR: Mia.
MS. FOSTER: Why did you refer to this person as Mia?
ANANYA SANKAR: I was told that Mia is the alias being used for this individual.
MS. FOSTER: Thank you, Ms. Foster. You can take this down. Can you please publish Government Exhibit 1410-R again.
MS. FOSTER: Now I want to go through each of the columns on this chart. Can we start with the first column titled date and time ET. What does that show
ANANYA SANKAR: That is the date and time the text message was sent or when the call was initiated.
MS. FOSTER: We can turn back on the overflow screen. Great. Thank you.
MS. FOSTER: Is there a time zone listed for these records?
ANANYA SANKAR: Yes.
MS. FOSTER: And what is that time zone?
ANANYA SANKAR: Eastern Standard Time.
MS. FOSTER: Is that indicated by the ET?
ANANYA SANKAR: Yes.
MS. FOSTER: What does the second column record type show?
ANANYA SANKAR: This indicates whether the row represents a text message or a call record.
MS. FOSTER: And what does the from and to columns indicate?
ANANYA SANKAR: From is the sender of the text message or the initiator of the phone call, and then to is the recipient of the text message or the call.
MS. FOSTER: Turning to the next column content/duration of call, what does that show?
ANANYA SANKAR: That shows the content of the text message sent or the duration of the phone call.
MS. FOSTER: And finally, turning to the final column source, what does that show?
ANANYA SANKAR: That is the Government Exhibit I used to verify the accuracy of each row.
MS. FOSTER: Now, before we go through this chart, I want to go through an example of how you verified the information of it. Ms. Sankar, can you please read the first two rows?
ANANYA SANKAR: November 18, 2023 at 7:12 a.m. Damien Butler to Sean Combs. I need to hear your voice bro. Love you, heart emoji.
MS. FOSTER: 11/19/2023, 10:36 a.m. Text message from Sean Combs to Damien Butler. Thank you for checking on me. Really appreciate you. Love you.
MS. FOSTER: What is the source for both of these messages?
ANANYA SANKAR: H-104-A1 and H-104-A1-R.
MS. FOSTER: Is that the source you checked these text messages against?
ANANYA SANKAR: Yes.
MS. FOSTER: Ms. Foster, can you pull up H-104-A1-R and turn to page 2. A. These are text messages shown in a cellphone extraction.
MS. FOSTER: Are those the two texts we just went through in the chart?
ANANYA SANKAR: Yes.
MS. FOSTER: Can you just walk through briefly how you confirmed the information on this chart using this exhibit?
ANANYA SANKAR: So first at the bottom right corner, that lists the date and time the text message was sent, so I made sure that was accurate. And then if you look at top left corner, that is the from, the sender of the message, and the to, the recipient. So I verified that the phone numbers were accurate, and then I used the stipulation we talked about previously to make sure that the owner or the contact name was connected to an individual we knew that used the phone number, and then I verified that the actual content of the message was also accurate.
MS. FOSTER: Here what time zone are the messages listed in?
ANANYA SANKAR: These are in Universal Coordinated Time.
MS. FOSTER: What times were they listed than the chart we looked at?
ANANYA SANKAR: Eastern Standard Time.
MS. FOSTER: How did you determine what time these messages were sent in Eastern Standard Time?
ANANYA SANKAR: I used a time converter.
MS. FOSTER: From UTC to ET?
ANANYA SANKAR: Yes.
MS. FOSTER: Ms. Foster, can we go back to the first page of Government Exhibit 1410-R.
MS. FOSTER: I now want to walk through the various entries on this chart in chronological order, and starting after the first two rows. Can you please read Mr. Butler's messages and calls, and I'll read the other party's messages and calls.
ANANYA SANKAR: November 23 at 1:14 p.m. Damion Butler to Sean Combs. Happy Thanksgiving to you and the family. I miss y'all. I will send you a picture of my plate later. Let's keep the tradition going on. Let me see what your plate looking like. Love you man. Heart emoji. See you soon. Then the next day in the evening. Love you man. I'm here for you. I feel I need to see you and chill with you for a couple of days. I didn't wanna be in your space. I haven't spoken to you, but just letting you know if you need a real friend I'm here.
MS. FOSTER: The following day, Sean Combs to Damion Butler: Love you. Calling you. That same minute Sean Combs to Damion Butler. Call me.
ANANYA SANKAR: Few minutes later, Damion Butler to Sean Combs: I tried calling you back. I will try again in ten minutes.
MS. FOSTER: About 20 minutes later Sean Combs to Damion Butler: Call you back, talking to the kids. And just stopping there, it indicates that there are some calls between Mr. Combs and Mr. Butler. Does this chart summarize every single communication between them or just some?
ANANYA SANKAR: Just some.
MS. FOSTER: Understood. Can you read now starting at row 11?
ANANYA SANKAR: Three days later, Damion Butler to Sean Combs: Hey, I will see you tomorrow this time. Love you.
MS. FOSTER: A few hours later Sean Combs to Damion Butler: Love you?
ANANYA SANKAR: The next day Damion Butler to Sean Combs: Heading to the house. And then the next day, Damion Butler to Mia: Hey what's up, Mia?
(Continued on next page)
MS. FOSTER: Could we please turn to the next page.
MS. FOSTER: That day, November 30, 2023, Mia to Damion Butler: D-Roc, exclamation marks. That same minute, Mia to Damion Butler: "Hi, hi, hi. How are you?" Exclamation marks. A minute later, Mia to Damion Butler: "I miss so fucking much," exclamation marks, "ah." Exclamation marks.
ANANYA SANKAR: A minute later, Damion Butler to Mia: "A lot has been going on. Where are you in the world?"
MS. FOSTER: A minute later, Mia to Damion Butler: "E. Are you all good. I'm in Virginia Beach at the moment. Are you in NYC? How have you been with everything going on?"
ANANYA SANKAR: A few minutes later, Damion Butler to Mia: "I'm about to call you." And then Damion Butler calls Mia for 13 minutes and 29 seconds. About an hour later Damion Butler to Sean Combs: "can you text Mia's phone number."
MS. FOSTER: About 15 minutes later, Sean Combs calls Mia for zero seconds. A few days later, Sean Combs texts Damion Butler: "hey, it's Puff. Wanted you to have this number too since I'm on this phone today. Thank you again for coming and being here with me today. Love you brother."
ANANYA SANKAR: A few minutes later, Damion Butler to Sean Combs: "OK, bro. I'm coming back."
MS. FOSTER: The next day, Sean Combs calls Damion Butler for 47 seconds. The following day, Sean Combs calls Damion Butler for seven seconds. On December 5, 2023 -- oh. I read yours. I'm sorry.
ANANYA SANKAR: On December 5, 2023, at 6:49 p.m., Damion Butler calls Sean Combs for one minute and ten seconds. And then ten minutes later, Damion Butler texts Mia: "Your boy said to call him. He doesn't want anything or need you to do anything. He just called me." And then on February 2, 2024, about two months later, Damion Butler texts Mia: "Good morning. How are you doing? Did you ever speak to P? He called me a couple of days ago."
MS. FOSTER: Later that day, Sean Combs texts Damion Butler: "Call me, King." A minute later, Sean Combs calls Damion Butler for four seconds. A minute later, Sean Combs calls Damion Butler for two seconds. That same minute, Sean Combs texts Damion Butler: "call me. Important."
ANANYA SANKAR: Ten minutes later, Damion Butler calls Sean Combs for four minutes and 57 seconds. And then ten minutes later, Damion Butler texts Mia: Are you OK? I can't believe you're not hitting me back."
MS. FOSTER: Later that day, Mia writes to Damion Butler: "Hi, D. So sorry. I've just been scuba diving all day, and I didn't have my phone on the boat. I'm OK. I've been better, but I'm alive. Hahaha. How are you? No, I haven't talked to him. He only tried me once, and I missed it, b I don't have my phone alerts on ever, and I called back W no answer & left it at that and have terrible service here just in case my messages come through late. What are you up to?"
ANANYA SANKAR: And then, I believe a few minutes later, Damion Butler texts Mia: "I'm glad you're good. Of course you're scuba diving. You're crazy. We're chilling in PA. We're opening up another restaurant on the 17th. Where you scuba diving at? Honestly, I haven't been seeing or dealing with people. I'm in my own bubble. I had enough. I'll just keep in touch with the people that reach out to me and dude hits me from Tom Tom. All I can do is give advice, moral support. Love have a way. Call me. Feel me? He told me he just wants to ask you something. He doesn't want nothing from you or anything. Enjoy your time. When you get a minute, call me. But where you scuba diving at? I seem to need skiing. I need to show you off."
MS. FOSTER: Later that day, Mia to Damion Butler: "Ah, D. Miss you so much," exclamation marks. "I know how much shit you deal with all over and in every direction, and staying in your bubble is super smart to protect your mentality from any more bullshit than you need. We've all got our own bullshit to take care of, right? And sometimes when we are natural caretakers we tend to ignore our needs, and everyone assumes we're OK, but we need love/help/empathy too. So just know it's OK to not be OK or to remove yourself from the takers from time to time so you can recharge and relax and take care of D-Roc. I've been in my own bubble too, and I have all of my phone alerts on silent and hidden just to take steps to help myself because those alerts remind me of being in trouble, which is why I'm not quick at replying, so never take it personal. It just means I haven't seen your message. And I see your message, of course, I'll reply ASAP. I love you so much." And what does the CTP indicate at the bottom there?
ANANYA SANKAR: That just indicates that the message is so long it didn't all fit into one text block, and so it's continued on the next page in the next row.
MS. FOSTER: Ms. Foster, can we go to the next page.
MS. FOSTER: "I'm in this tiny little third world country island off of Honduras, where you don't have to wear shoes or brush your hair and you're in a bathing suit all day and drinks are like a dollar and nobody judges hashtag island life, but not glamorous, covered in mosquitoes and just in love with nature. But I do charitable shit here, like helping out local families, grow small businesses, building their little houses, whatever they need, etc., (that I can physically do because I'm out of scrilla money). Congratulations on your new restaurant. That's fucking huge. I'm so, so, so proud of you. And APs love you all so much. I def want to snowboard with you. That would be the best video ever."
ANANYA SANKAR: Ten minutes later, Damion Butler to Mia: "I'm so proud of you. You're my sister for real. If you need anything, I can help. I'm not rich, but I'm not broke either. I love you. Let's talk sometime tomorrow. I want to hear your voice. Plus I want to hear about Honduras. I'm sure it's beautiful and peaceful. Is there a time difference? That might have been a stupid question, but hey, let me know so I can call you tomorrow." Four minutes later, Damion Butler to Mia: "Let me know how I can send you something."
MS. FOSTER: Later that day, Mia to Damion Butler: "You're my brother for real, forever, ever. I don't care how many days, weeks go by. I always know we pick up where we left off, and you're always my heart. No, I'd never ask for anything. I've never been in such a low spot/in debt. But that's no problemo, and I'll figure it out one day, I hope. But I'm always here to help you all out in any ventures or anything you all need, etc.," exclamation mark; Can sell dah. That's not a dumb question about the time zone. It's usually one hour behind NY, but they don't have Daylight Savings Time here, so sometimes it's two hours behind, like right now it's 8:53 p.m. Tomorrow I'm diving, but call me whenever, and when I resurface I'll call you back, of course, when/if I can find wi-fi," exclamation mark. "Love you so much, D." Exclamation mark.
ANANYA SANKAR: Three minutes later, Damion Butler to Mia: "OK. I will try you tomorrow. And I know you didn't ask me for anything. I'm allowed to send my sister a gift."
MS. FOSTER: Thirty minutes later, Mia to Damion Butler: "Hahaha. Send me anything at all. The little GPH file only pays for ages, big pop out of nowhere, universe synchronicities."
ANANYA SANKAR: A minute later, Damion Butler loved Mia's previous message. The next day, Damion Butler texts Mia: "I'm going to try to call you in 15 minutes. If I don't catch you, I will try you later or tomorrow."
MS. FOSTER: Later that day, Mia responds to Damion Butler: "Hi, D. Love you. Try me manana, of course. I was on a little boat all day and didn't have service." That day, Mia writes to Damion Butler: "staying in a tiny bungalow shack with no electricity or running water, but who cares when you can poop in this." sends photo.
ANANYA SANKAR: The next morning, Damion Butler to Mia: He laughed at the previous message and loved the previous image. "I feel asleep last night. I'm an early bird. I'm up, like, 5 a.m. every day. That water looks so good." And then about six hours later, Damion Butler texts Mia: "You up?" And then about three hours later, Damion Butler calls Mia for two seconds. And then two minutes later, Damion Butler texts Sean Combs: "Hey, bro. She hit me back. I'm trying to call her now." A minute later, Damion Butler texts Sean Combs a copy of a previous message that Mia had sent him.
MS. FOSTER: Approximately three hours, later Sean Combs writes to Damion Butler: "Let me know when you reach her." Later that night, Sean Combs writes to Mia: "Hey, Mia. It's Puff. Let me know when you get ten min to talk. Love." Why are there -- just focusing on that row again, why are there asterisks on the date/time and from and to columns?
ANANYA SANKAR: So, these particular messages are actually a screenshot of a text conversation, and so we're not exactly sure of the time zone or who the participants in the conversation are. We just have the contact names to go off of.
MS. FOSTER: Can we pull up that screenshot, which is in evidence as 3T-102-R.
MS. FOSTER: Is this the screenshot?
ANANYA SANKAR: Yes.
MS. FOSTER: And does it say 9:10 p.m., February 4, 2024?
ANANYA SANKAR: Yes.
MS. FOSTER: And you're saying you can't tell the time zone, is that right?
ANANYA SANKAR: Yes.
MS. FOSTER: Why did you list the participants as Mia and Sean Combs for this chat?
ANANYA SANKAR: In the first message, you can see that it says: "Hey, Mia, it's Puff," indicating that this message is addressed to Mia. And it looks like Puff or Puff Daddy 2017 is the sender.
MS. FOSTER: Can we go back to the 1410R chart. Going to the next page -- oh, sorry. We have two more. The next day, Sean Combs called -- sorry, can we go back one page.
MS. FOSTER: After Sean Combs writes: "Hey, Mia. It's Puff. Let me know when get 10 min to talk, love," Sean Combs, the next day, called Mia for two seconds.
ANANYA SANKAR: And then about an hour later, Damion Butler calls Mia for three seconds.
MS. FOSTER: Now can we go to the next page.
MS. FOSTER: On February 6, 2024, at 6:12 a.m., Sean Combs calls Mia three times: One time for three seconds; one time for two seconds; one time for zero seconds. Two minutes later, he calls for six seconds and 11 seconds, and then about an hour later, he calls for four seconds. And why are there asterisks in the time in rows 65 and 66?
ANANYA SANKAR: We also don't have time zones for those two calls.
MS. FOSTER: They're not listed in the records?
ANANYA SANKAR: Correct.
MS. FOSTER: OK. Can we go to the next rows.
MS. FOSTER: The next day, at 6:08 p.m., Sean Combs writes to Mia: "Hey, I don't want to be blowing up your phone. Just needed to talk to you for ten minutes. Just need my memory jogged on somethings. You were my right hand for years. I just need to speak to you to remember who was even around me, and it would be good to hear your voice. But if you don't want to, all good. Just let me know. Love. Hope you're well." Heart hands emoji, prayer hands emoji, heart. And is this from that same screenshot we saw previously?
ANANYA SANKAR: Yes.
MS. FOSTER: And is that why there's asterisks?
ANANYA SANKAR: Yes, correct.
MS. FOSTER: That same day, at 5:20 p.m., Sean Combs writes to Damion Butler: "Hey, I don't want to be blowing up your phone. Just needed to talk to you for ten minutes," and continues to send the message that he had just sent to Mia. Why are these messages out of order in this chart?
ANANYA SANKAR: So, because we don't have the time zone for the message in row 68, in the screenshot it's listed as 6:08 p.m. However, due to later context in these messages, we can understand it was sent before.
MS. FOSTER: You mean it was sent, row 68 was sent after 69; is that what you're saying?
ANANYA SANKAR: Yeah.
MS. FOSTER: Sorry. Before.
ANANYA SANKAR: Yeah. Row 68 was sent before row 69.
MS. FOSTER: I see. So the time is after, but the context indicates that it may be before?
ANANYA SANKAR: Yes.
MS. FOSTER: Got it. 15 minutes later, Sean Combs calls Damion Butler for four seconds. And that same minute Sean Combs texts Damion Butler: "Call me when you can, king." Can we go to the next page, please?
ANANYA SANKAR: At 5:40 p.m., on February 7, Damion Butler texts Sean Combs: "I'm calling in ten minutes. I'm pulling up to my house. You're never blowing up my phone, bro. Don't talk even talk like that. I'm here whenever you want to talk. I'm here to help in any way I can." And then nine minutes later, Sean -- sorry.
MS. FOSTER: Nine minutes later, Sean Combs sends an audio message to Damion Butler: "No. That's my fault. That's what I sent to Mia. I sent that message to Mia because I've been trying to reach her. She ain't picking up the phone. But yeah. But hit me, when you get a couple of minutes. Love. Hope you're doing well." And is that that context you meant?
ANANYA SANKAR: Yes.
MS. FOSTER: Got it.
ANANYA SANKAR: And then a couple minutes later, Damion Butler calls Mia for five seconds and then again for two seconds. And then four minutes later, Damion Butler texts Sean Combs another copy of a message that Mia had previously sent to Damion Butler.
MS. FOSTER: And is that a message we previously walked through?
ANANYA SANKAR: Yes.
MS. FOSTER: And can we turn to the next page.
ANANYA SANKAR: And then a few minutes later, Damion Butler calls Sean Combs for one second and then texts Sean Combs: "That's the last text I got from her, and now the phone is not even ringing but it's ringing like out the country." And then Damion Butler calls Sean Combs two more times, once for three seconds and then another for two seconds. A few minutes later, he texts: "I feel like you text music phone. I'm in the crib for the day. I'm not going nowhere. I'm going to jump in the shower, so hit me back when you can."
MS. FOSTER: Approximately 18 minutes later, Sean Combs calls Damion Butler for five seconds.
ANANYA SANKAR: And then about an hour later, Damion Butler calls Sean Combs for zero seconds.
MS. FOSTER: We can take this down.
MS. FOSTER: Aside from reviewing the charts you just testified about and preparing to testify today, did you have any other involvement in this case?
MS. FOSTER: No further questions.
THE COURT: All right. Thank you, Ms. Foster. Ms. Geragos.
MS. GERAGOS: Thank you, your Honor.
CROSS-EXAMINATION BY MS. GERAGOS:
MS. GERAGOS: Good morning, Ms. Sankar. My name is Teny Geragos. I just have a few questions for you.
ANANYA SANKAR: Good morning.
MS. GERAGOS: Why don't we just start with what we just left on, Government Exhibit 1410-R. All right. And this is the chart we just walked through, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. And this chart starts on November 18, 2023, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. And the first message there is from Damion Butler to Sean Combs saying: "I need to hear your voice, bro. Love you." Right?
ANANYA SANKAR: Correct.
MS. GERAGOS: And if we could pull up just very briefly 1411-R, page 26, please. All right. If we could go to line 363.
MS. GERAGOS: That is two days earlier, right, 11/16/23?
ANANYA SANKAR: Yes.
MS. GERAGOS: And it's a legal filing?
ANANYA SANKAR: Correct.
MS. GERAGOS: And it's Ventura v. Sean Combs, et al., right?
ANANYA SANKAR: Correct.
MS. GERAGOS: If we could go back to 1410-R. All right. 1410-R, the one we were at previously. OK. We went through this in detail, so I won't spend too much time on it, but could we turn to page 4. All right.
MS. GERAGOS: And this is a text message from Damion Butler to Mia, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Oak. And here -- I won't go through the whole thing again, but Damion Butler says, about halfway down, "He told me he just wants to ask you something. He doesn't want nothing from you or anything. Enjoy your time. When you get a minute call me." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And if we could go to page 6. All right.
MS. GERAGOS: And then line 41 is a message from Mia to Damion Butler, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And then if you look about halfway down that message, she writes, in parentheses, "that I can physically do BC I'm out of scrilla dollars," right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And in response to that, Mr. Butler writes: "I'm so proud of you. You're my sister for real. If you need anything, I can help. I'm not rich, but I'm not broke either. I love you." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And could we go to the next page to see her response. All right.
MS. GERAGOS: And then she says -- I'm skipping over some texts because we just went over them, but she says: "No, I've never asked for anything. I've never been in such a low spot/in debt, but that's my problem. I'll figure it out one day, I hope," right?
ANANYA SANKAR: Yes.
MS. GERAGOS: If we could jump ahead to page 9. All right.
MS. GERAGOS: Now we are on February 7 of 2024, right, from line 68, February 7 of 2024?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. And now this is Mr. Combs's message to Mia, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And he says: "Hey, I don't want to be blowing up your phone. Just need to talk to you for ten minutes. Just need my memory jogged on some things. You were my right hand for years so I just want to speak to you to remember who was even around me. It would be good to hear your voice, but if you don't want to, all good. Just let me know." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And if we could go to the next page, to line 72. All right.
MS. GERAGOS: Now, this is the same day, right, February 7?
ANANYA SANKAR: Yes.
MS. GERAGOS: And this is Mr. Butler to Mr. Combs?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And Mr. Butler says: "I'm here whenever you want to talk and I'm here to help in any way I can." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And then Mr. Combs responds, right below this -- he has a few lines, and he says: "Because I've been trying to reach her. She ain't picking up the phone." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Now, if we could go to the last page, page 11. All right.
MS. GERAGOS: And this is same day, February 7?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. And Mr. Butler says: "That's the last text I got from her, and now the phone is not even ringing but it's ringing like out of the country." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And there's no -- after Mr. Butler says that to Mr. Combs, there's no more calls recorded between Mr. Combs and Mia on this chart, right?
ANANYA SANKAR: Not on this chart.
MS. GERAGOS: OK. And there's no more calls recorded between Mr. Butler and Mia on this chart, right?
ANANYA SANKAR: Yeah. Not on this chart.
MS. GERAGOS: OK. And there's no more texts between Mr. Combs and Mia after this message, right?
ANANYA SANKAR: Not on this chart.
MS. GERAGOS: OK. And there's no more messages between Mr. Butler and Mia, right?
ANANYA SANKAR: Not on this chart.
MS. GERAGOS: Not on this chart. OK. All right. We'll take that down. If we could pull up 1411-R, please.
MS. GERAGOS: All right. So we went through how this was put together and your involvement in this, but generally, these -- this is a 33-page exhibit, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: And it spans from 2016 to 2024?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. So eight years?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. And they're select messages from eight years into 33 pages, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Certainly not all of the messages sent on Ms. Khorram's phone in those eight years, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And generally, we looked at some text messages regarding flower or green and tree, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And then there were a few text messages about someone named Guido?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. And we saw some audio messages, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And so this chart here starts on March 18 of 2016, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: And are you aware that Ms. Khorram was working for many years before that?
MS. GERAGOS: OK. That's not part of what your review was?
MS. GERAGOS: OK. So you just received this, and this chart starts in 2016?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. If we could -- well, we looked at the chicken noodle soup text. So let's go to page 2. All right.
MS. GERAGOS: So it jumps ahead from March 19 of 2016 to June 16 of 2016, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. Actually, let's go back to page 1. Sorry. I missed a question.
MS. GERAGOS: All right. Those bottom two messages, lines 24 to 25, you see there's a message from Dave Shirley to Kristina Khorram that says: "Clayton Howard needs access to room"?
ANANYA SANKAR: Yes.
MS. GERAGOS: Was this the only message that you reviewed where Clayton Howard is mentioned?
ANANYA SANKAR: I believe the one below it also mentions that name.
MS. GERAGOS: OK. So right underneath it, one minute later, it's the same message -- it's the same. Sorry. One minute later it says the name Clayton Howard needs to be added to the hotel room, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: So these messages within one minute of each other are the only times that Clayton Howard is mentioned, from what you saw?
ANANYA SANKAR: From what I remember -- I don't really want to look at the whole chart again, but I believe so, in this chart.
MS. GERAGOS: OK. And understand it's 33 pages, but from what you recall, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. So let's go to the next page. All right. So we, if we go down to line 51 -- we didn't go through these on direct so I just want to briefly go through them.
MS. GERAGOS: We skip from March 2016 to June 2016, right, up ahead -- I mean up above?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. And then it skips ahead from June to August of 2016, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And this message is between -- what date is this message?
ANANYA SANKAR: August 18, 2016.
MS. GERAGOS: All right. And this is from Nat Moar 2022 to Kristina Khorram?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. So if you want to be Nat and I will be Kristina, what does Nat say?
ANANYA SANKAR: "The story will run."
MS. GERAGOS: All right. Can we go to the next page: "Shit, tonight?"
ANANYA SANKAR: "Yes, we are all waiting. "The only reason it's running is because of police report. "TMZ has not run yet."
MS. GERAGOS: And then Kristina sends Nat a screenshot there. Do you see that?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And this says: "Diddy and Cassie have called it quits following an explosive argument that ended with cops rushing to her home, TMZ has learned. "Sources close to the couple tell TMZ they got into a heated argument in a car Wednesday afternoon after Cassie told Diddy she wanted to break up. We're told Diddy got pissed off and suspicious enough to grab her phone and started scrolling through. "Our sources say Diddy jumped out of the car in Beverly Hills, phone in hand, and she took off with the driver. "Diddy eventually came home and returned the phone but then took two cars parked outside. "Cassie told her mom about the phone incident before Diddy came home and returned it, and the mom called the cops on him." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Then it continues. OK. And then Nat --
MS. GERAGOS: You can be Nat.
ANANYA SANKAR: "Is it bad?"
MS. GERAGOS: "They spun it so it looks like a breakup fight. But it's what I expected/it's short." Next page. And then she sends a TMZ article?
ANANYA SANKAR: "It's better than it was. It's fine. I'm so happy it's just this."
MS. GERAGOS: "It definitely could have been worse." And can we -- do you see how it says the source for this is C-354?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. Could we go to C-354C, please, which is in evidence.
MS. GERAGOS: OK. Is this a message between Nat Moar and K.K. main phone on the same date, August 18, 2016?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And again, we went over this, but the 2886 number associated with K.K. main phone, you saw from the stipulation is Ms. Khorram, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. Could we go to page -- could we go to page, the last page of this exhibit. OK. If we could go -- sorry, the page before and this page next to each other.
MS. GERAGOS: All right. Does Nat say there: "On with Cassie"?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. And Ms. Khorram says: "OK. After?"
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. And Nat says: "Who gave you this? Call office." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And Ms. Khorram writes: "They're running it now"?
ANANYA SANKAR: Yes.
MS. GERAGOS: And then it says: The story will run -- shit -- tonight." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. So the "on with Cassie" and "OK, after," those were not included in the chart, right?
ANANYA SANKAR: No, I don't think so.
MS. GERAGOS: OK. And then if we go to the next page, Nat says, about halfway down the page, "The only reason it's running is because of police report." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And Ms. Khorram says: "He says can you text me what they say after you speak to them, please, so I can show to him?"
ANANYA SANKAR: Yes.
MS. GERAGOS: And then Nat responds: "She is worried it's running and wanted me to get story in advance. I told her that cannot happen." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. We can take that down. OK. If we could pull up again -- get the numbers right, 1411. Perfect. OK.
MS. GERAGOS: If we go to those last two lines, lines 66 and 67. Those are messages from Ms. Khorram to Ms. Ventura?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. Can you read those?
ANANYA SANKAR: "Hey, love. Just wanted to send to you in case PR hasn't already so you don't get blindsided. How are you doing through all this? Know it's a lot for you too. Here for you if you need me."
MS. GERAGOS: OK. Let's go to the next page. All right.
MS. GERAGOS: So we've skipped ahead from August 2016, and now the create date of this message in line 69 is September 30 of 2016, correct?
ANANYA SANKAR: Correct.
MS. GERAGOS: So that date and time and time zone reflects the metadata, but it doesn't reflect the actual date of the messages, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. And then there's a blue line there, and we skip ahead almost a year, until May 2 of 2017, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. And these messages we went through on direct examination, so I won't go through them all again, but were you asked to include any other exhibit from May 2 of 2017?
MS. GERAGOS: OK. Could we pull up what's already in evidence as Defense Exhibit 1616. All right.
MS. GERAGOS: Is this -- if you tilt your head to the right, are these messages on May 2 of 2017?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And these were not included in your chart, right?
MS. GERAGOS: OK. Could we go to the next page, please.
MS. GERAGOS: Have you seen these messages before?
MS. GERAGOS: OK. Could we go to the next page, please.
MS. GERAGOS: Have you seen this before?
ANANYA SANKAR: No. Not that I remember.
MS. GERAGOS: OK. All right. Could we go now back to 1411-R. Thank you. And go to page 6.
MS. GERAGOS: All right. So if we look at lines 82 -- 80 to 85, I can be Ms. Ventura and you can be Ms. Khorram. Ms. Ventura says: If I can come get my stuff when he's knocked, LMK, BC I might go home to FT."
ANANYA SANKAR: "Of course. Always here for you, hope you know that."
MS. GERAGOS: "I do. Love you."
ANANYA SANKAR: "Love you too."
MS. GERAGOS: All right. And then if you look, then there's another, about a year period between these two messages; that's what the blue indicates?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. And then again, we went through these messages on direct, so I'm not going to belabor it, but on 89, what does Ms. Khorram write to Ms. Ventura?
ANANYA SANKAR: "Are you OK? I don't know what else to say, but I'm here if you need anything." Heart emoji.
MS. GERAGOS: All right. And then we leave off at April 20 of 2018. And how long of a gap is there between 92 and 94?
ANANYA SANKAR: About six months, maybe -- sorry, about a year.
MS. GERAGOS: Year and a half?
ANANYA SANKAR: Year and a half.
MS. GERAGOS: OK. There's no messages included here from the summer of 2018, right?
MS. GERAGOS: And nothing from the fall of 2018?
MS. GERAGOS: And really nothing until almost the very last day of 2019, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. And if we look at the messages 94 to 99, those are the only messages included from the year 2019, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. And they're all from the same day, does that sound -- does that look right?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. And then if you look at 2020, 2020 is fully captured in lines 101 to 110, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. And the messages here, in 2020, they span four different days, right; there's May 17 of 2020, May 18 of 2020, May 19 and then July 24 of 2020?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. And if you look at line 106, let's just -- let's take 105 to 110, Phil Pines writes: "Is he going somewhere?" And you can be Ms. Khorram.
ANANYA SANKAR: "Personal store run. "With Faheem."
MS. GERAGOS: "He dismissed me. About to do EOD."
ANANYA SANKAR: "Copy thanks. Think they will go for a while? "Liked 'yeah with Guido stopping by for sure.'"
MS. GERAGOS: OK. If we go up ahead, to line 101, Phil Pines write to say Ms. Khorram: "He got somebody from someone, blue pills, probably molly. "Just FYI." right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And then is Ms. Khorram's response with the face palm emoji?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. All right. And so then the blue indicates another about year, over a year has passed between messages, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And here, I can bring it up if you want, but this is a message between Ms. Khorram and Sean Combs in response to him asking if she can look at his phone. Does that sound right?
ANANYA SANKAR: If I could take a look at the exhibit, I could verify that.
MS. GERAGOS: OK. Let's look up C367. All right. If we go to the next page, next page, next page. Let's just keep going until we find it. Next page, next one, next one. All right. Let's go back. We don't have to do it. We can take it down. All right. It's because we pulled up the wrong message. I think that's the problem. It's C367. OK. Next page. All right.
MS. GERAGOS: So do you see here your message, which is included -- not your message, the message which is included in your chart: "Yes, I have been checking. Only new messages that haven't been opened."
ANANYA SANKAR: Yes.
MS. GERAGOS: Did you listen to the audio message right before it?
ANANYA SANKAR: I don't believe I listened to it, no.
MS. GERAGOS: OK. You just verified that the message that was on the chart was the message that was in the original message?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. So let's go back to the chart then. OK.
MS. GERAGOS: So here it says: Yes, I've been checking, only new messages that haven't been opened." And then if we skip ahead, it says: "Paul Cowboy wrote available." right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And could we pull up what's already in evidence as Defense Exhibit 3016, page 14.
MS. GERAGOS: All right. Have you reviewed this message at all?
ANANYA SANKAR: I don't believe so.
MS. GERAGOS: OK. And is the contact name here Paul Cowboy?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. We can take it down. OK. We can go to the next page, please. All right.
MS. GERAGOS: We went through some of these, but do you see down below, on November 14 of 2021, there were text messages between Mr. Combs and Ms. Khorram?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. If we could go to -- so you included several text messages here, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. So if we go to the next page. All right.
MS. GERAGOS: And then it ends at line 129, right, that message chain?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. If we could go to the underlying record, C-622-1-R, please. And go to page 12. OK.
MS. GERAGOS: Is that a message from Ms. Khorram to Mr. Combs on that date, at the top?
ANANYA SANKAR: Yes.
MS. GERAGOS: And she says: "Checking in on you. You OK over there?"
ANANYA SANKAR: Yes.
MS. GERAGOS: And that wasn't included in the chart, right?
MS. GERAGOS: OK. We could go back to the exhibit. All right. Could we go, please, to page 9. OK.
MS. GERAGOS: If we could go to lines 139 to 140, I don't think we read through these on direct, these are from several days later, right?
ANANYA SANKAR: Yes, three days later.
MS. GERAGOS: OK. Could you be Jane and I'll be Ms. Khorram?
ANANYA SANKAR: "Hey, hun. Hope you're doing well. Sorry for this late text. I think I'm having a bad comedown from the week. I just want to make sure Sean is OK and not feeling bad. Just checking in. TY. Good night."
MS. GERAGOS: "Hi, love. Aww. I'm sorry to hear that. Yeah, he's been good actually since we got here. He's been up and moving and in great spirits. Maybe try taking 5HTP. Sometimes I know that helps people. Also trying to think of the other stuff that helps...maybe like happy weed? To help with an upswing? Also I know like pure chocolate helps with something in your brain too. I'll see if there are any other tricks too. You might also just need extra sleep," exclamation point. Can we go to the next page, please?
ANANYA SANKAR: "Hey, hun. Good morning. OK. That's so good to hear. Honestly you're right. Maybe I was just going and going because I was having a bit of vertigo for about two days. I drank OJ AND vitamins yesterday. I'm waking up finally feeling normally. Going to get all those things you listed. Thank you, hun. Have a great day today."
MS. GERAGOS: We didn't look at these on direct, but if we go down to lines 146 to 160, and these are from about a month later, right, December 30, 2021?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And if you could, Jane writes to Ms. Khorram: Hey, babe. I was just trying to get a hold of Sean. It's a little time sensitive. Would you mind telling him to give me a call? Thanks so much, babe." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Then if we could go down to line 55, Jane writes: If he wants he can drop it off at my building as well if it's any easier. Maybe place in a shoe box or something. My front desk can hold for me. Just an option." And Ms. Khorram responds: "PD talks to him directly. "I don't speak with him. LOL." right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Then line 159, Ms. Khorram writes: FYI, PD said the package will be dropped to Mapleton for you to pick up." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: You don't list any calls between them in these messages, right, between Jane and Ms. Khorram?
ANANYA SANKAR: Not on this chart.
MS. GERAGOS: OK. If we go to the next page, please.
MS. GERAGOS: All right. So we -- if we could look at lines 169 and below, these are from February 12, 2022, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And we looked at those, 169 to 171, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: On direct. OK. So if we go to line 163, these are between Jane and Ms. Khorram, right?
MS. GERAGOS: Did I say the wrong -- I should have -- 173 to 175 are between Jane and Ms. Khorram, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. So Jane writes: "Hi, hun. Yes, pulling up to airport, yay," with a smiley face, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: "How are you? "Hopefully the 14th morning is OK w the room. I'm excited to surprise him." And what does Ms. Khorram respond?
ANANYA SANKAR: "OK. Great. I'm good. It all always works out."
MS. GERAGOS: OK. And if we could unzoom, then Jane asked, on line 179: "Just thinking ahead. He always bringing cash, so maybe when security arrives, should they also have that with them? He always bring around 5 to 10K." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: If we could go to the next page, line 185, this is from Jane to Ms. Khorram, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And she says: "K.K. Still landing at 2P, right? Then 45-min drive to hotel? I went to run an errand and also they're expecting ppl to leave the presidential suite by 12P hopefully and room decor begins at 1P, takes 30 to 40 minutes." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: You didn't include any photos of the room decor in this chart, right?
ANANYA SANKAR: Not in this chart.
MS. GERAGOS: OK. Could we just bring up very briefly for the witness what's already in evidence as Government Exhibit E-119 and E-120 next to each other -- E -- yeah, perfect. And E-120.
MS. GERAGOS: Have you seen these before?
MS. GERAGOS: OK. We can take those down, and we could bring up E122 and E123 next to each other.
MS. GERAGOS: All right. Have you seen these before?
MS. GERAGOS: OK. And they were not included in your chart, right?
ANANYA SANKAR: Not in the chart, no.
MS. GERAGOS: OK. If we could go back to our exhibit, please. If we could go to -- we were just on page 12 -- perfect -- lines 193 to 195.
MS. GERAGOS: Jane -- Ms. Khorram texts Jane: "Hi, love. Here with P now and wanted to work on booking you on the Thursday night redeye he said so you can land Friday morning. LMK if that still works and we will get locked in," exclamation, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And that's about, almost, a little over two weeks after the messages we just looked at?
ANANYA SANKAR: Yes.
MS. GERAGOS: And Jane responds: "Hey, love. Yes let's do it," with a winkie, a wink face?
ANANYA SANKAR: Yes.
MS. GERAGOS: Let's skip ahead to page 15 -- actually, sorry. Page 14. I misread. All right. Lines -- starting at lines 205.
MS. GERAGOS: This is again March 3 of 2022?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. And these are more texts between Ms. Khorram and Jane?
ANANYA SANKAR: Yes.
MS. GERAGOS: And Ms. Khorram writes, in line 205: Hey, per PD, can you swing by Mapleton on your way to airport to pick up Guido package?" Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And you don't note in here any phone calls between Ms. Khorram and Jane, right?
MS. GERAGOS: OK. All right. Now let's go to page 15. OK.
MS. GERAGOS: So if we look at July 23 of 2022, there are several messages here between Ms. Khorram and Mr. Combs, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. And the underlying exhibit here is C657, right? Do you see that, and C657A?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And here the messages that are included are: "Yeah, been working on it. London sold out so waiting on other options." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And that's -- and then we go -- there's an audio message, an "OK," and "Guido outside," right?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. And if we could go to the underlying exhibit, please, C657. All right. And if we could go to the last page -- sorry. Page 14. For C657. I think this is the wrong exhibit. OK. Sorry. Could we go back to the actual exhibit, 1411R, to page 15, please. OK. That appears to be a mistake. Can I confer with Ms. Foster, please?
THE COURT: Yes, you may.
MS. GERAGOS: Thank you. Could you give me two minutes to check my computer?
THE COURT: Yes. That's fine. While we're waiting, I'm going to stand up for a second, if anyone wants to join me.
MS. GERAGOS: The collaboration is working again, and I believe Ms. Foster will pull up the new 657.
THE COURT: All right.
MS. GERAGOS: And then we'll go back to our system.
THE COURT: All right. OK. So everyone can be seated at this time and we'll proceed.
BY MS. GERAGOS:
MS. GERAGOS: All right. Just to reorient ourselves, we were looking at 23 of 2022 on 1411-R. Remember that?
ANANYA SANKAR: Yes.
MS. GERAGOS: Then I had asked to go to the underlying record, which was C657, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: OK. And so these were the messages that we were just looking at: "Yeah, been working on it, London sold out. Still waiting on other options." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: If we could go to page 14 of that exhibit. OK.
MS. GERAGOS: If you go to the bottom, Ms. Khorram writes: "Booking Waldorf same room. Joey there now. Room will be ready in two hours." Do you see that?
ANANYA SANKAR: Yes.
MS. GERAGOS: The number associated with Mr. Combs writes: No, don't book." See that?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. Thank you so much, Ms. Foster. I think we can move back to Mr. McLeod. Thank you. OK. He's got it.
MS. GERAGOS: OK. Those messages, "no, don't book," are not included in this chart, right?
MS. GERAGOS: OK. Just "London sold out" and "waiting on other options," right?
ANANYA SANKAR: Correct.
MS. GERAGOS: And "Guido outside" below is also included, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: All right. And these messages on page 15 are all from 2022?
ANANYA SANKAR: Yes.
MS. GERAGOS: If we could go to the next page, page 16. All right.
MS. GERAGOS: This is now -- if you look at line 248, which we went through on direct, that is November 24 of 2022?
ANANYA SANKAR: Yes.
MS. GERAGOS: About five months after the message we just saw, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And then Mr. Combs writes: "Molly 15 pills/don't. Text think -- though." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. And let's go to -- let's go to the next page, to page 17. All right.
MS. GERAGOS: Now these messages are February 25 of 2023, between Ms. Khorram and Jane. Do you see that, lines 253 to 256?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And Ms. Khorram write to say Jane: "Hi, hope you're great. Call me when you get five min. Thanks." And how about two hours later: "sorry to bother but trying to make plans and he is pushing me to get an answer today," exclamation point, "LMK. Will just be a two min call." right?
ANANYA SANKAR: Yes.
MS. GERAGOS: About two minutes later, what does Jane write to Ms. Khorram?
ANANYA SANKAR: "Hey, K.K. Happy belated birthday. Sorry. Just not in the mood to talk on the phone. My answer to him was no and it is still no. Thank you. Hope you're great too."
MS. GERAGOS: And then two minutes later, Ms. Khorram writes to Jane: "Aww, thank you," exclamation, exclamation, "Ahh. OK. Sorry. Didn't know that part. Will let him know. Keep me posted if anything changes. XX," exclamation point, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And if we could go to page -- just go to the bottom.
MS. GERAGOS: On April 14 of 2023, this is a text message from Faheem to Robin, Mr. Combs and Ms. Khorram, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And here, it says: $1,200 spent on flower today. $1,500 owed to Guido for misc. Let me know if approved to pay." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. Could we go to the next page, page 18, line 280, and -- all right.
MS. GERAGOS: That message is April 24, 2023, again from Faheem, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And it says: "Per Joey looking to get $4,800 approval for tree today. This should be enough to last four weeks. Let me know if approved." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. If we go to page 19, please, we didn't go through some of these messages.
MS. GERAGOS: At the top, lines 287 to 288, and bottom part of Ms. Khorram's message to Mr. Combs, on line 287, says: Today seems stress driven. Let's turn it around and breathe. Try and have fun at the game and then you will have your release moment tonight at the studio. We control our own energy. Stay light." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And he says: "I want Frank. I don't want to speak to anyone. I'm done. And if you can't get me better, I can't take no more. I can't. My life is the same bullshit every day. I'm about to cancel everything. Presentation not done. Album not done. Video not done. New video not done. Roots not done. Assistants out of wack. June can't remember a T-shirt. Ect. Ect. Ect. Wack." Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: If we go to line 290, right below it, this is another message from Faheem, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And it says: "$2,000 PD personal," right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And then: "$5,000 PD personal"?
ANANYA SANKAR: Yes.
MS. GERAGOS: And "$5,300PD personal"?
ANANYA SANKAR: Yes.
MS. GERAGOS: And "$2,500 approved for Flower approved 4/25 Joey," right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Could we just go to the next page to line 302. OK.
MS. GERAGOS: And this is another message from Faheem to the same group chat, right -- same group of people, I should say. I don't know if it's same group chat.
ANANYA SANKAR: Yes, same group of people.
MS. GERAGOS: OK. And this is: "Joey expenses spent out of pocket and need to be reimbursed," and this says -- I'm paraphrasing -- flower $3,100, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: "Tips at clubs, $200"?
ANANYA SANKAR: Yes.
MS. GERAGOS: "Space 2560," right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Bathroom attendant 1,000?
ANANYA SANKAR: Yes.
MS. GERAGOS: "New flower to be delivered soon, 3350," right?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And then Mr. Combs writes "approved," right?
ANANYA SANKAR: Yes.
MS. GERAGOS: If we could go to page 21, please. All right. Lines 309 to 313, I don't think we went through these on direct, so I'll go through them quickly.
MS. GERAGOS: These are from June 17 of 2023?
ANANYA SANKAR: Yes.
MS. GERAGOS: OK. And Ms. Ruiz writes, I put Jane's number on there as well, right?
ANANYA SANKAR: "I put Jane's name on there."
MS. GERAGOS: I'm sorry. Name on there as well. Thank you for catching that. And Ms. Khorram responds: "and Paul the trainer was added to the manifest." right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Could we go to the next page, page 22, and -- all right.
MS. GERAGOS: Lines 316 to 318, these are July 17 of 2023?
ANANYA SANKAR: Yes.
MS. GERAGOS: And OK, this is again same, same group, Faheem, Robin, Mr. Combs and Kristina Khorram?
ANANYA SANKAR: Correct.
MS. GERAGOS: And then he says: "Team need to approve this request from PD/15K cash approval in L.A. for PD personal," right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And Mr. Combs, on line 318, approves it, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And you didn't have any -- you don't have any messages around here about hotels or anything like that included in the chart, right?
ANANYA SANKAR: Not in the chart.
MS. GERAGOS: Not in the chart. OK. OK. Could we go to page 23. I think that for this next part, your Honor, we would need to shut off these screens and the overflow screens because I don't think the source exhibit is redacted.
THE COURT: I'll ask the deputy to confirm when that's done.
(Continued on next page)
BY MS. GERAGOS: (Continued)
MS. GERAGOS: These on page 23, these are messages on November 2 of 2023, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: And these that we're looking at generally are between Jane and Ms. Khorram, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And it starts with Jane to Ms. Khorram saying: Also just keeping it real W you, I'm not doing any more hard partying. And we read those messages on direct, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Do you recall that? Okay.
THE COURT: Ms. Geragos, I think we're ready to go.
MS. GERAGOS: Perfect.
MS. GERAGOS: If we could pull up C-250, please. This is the underlying source Government Exhibit, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Okay. If we could zoom out, please. This starts at 6. Could we go page before, please. All right. So it starts if we could go to line 1 through 3 and zoom there. Perfect.
MS. GERAGOS: And these are messages between Jane and Ms. Khorram, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And these are the earlier messages from what we just saw?
ANANYA SANKAR: Yes.
MS. GERAGOS: Okay. And, again, on November 2 of 2023?
ANANYA SANKAR: Yes.
MS. GERAGOS: And Ms. Khorram writes to Jane: Hi. Call me when you can. And Jane responds: Okay. Gonna FT audio call you, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And about 40 minutes later, Jane writes to Ms. Khorram: Feeling so bad and ill prepared. I would have had this super cute, but honestly wasn't prepared till after London. Loose what he was telling me, so I had a take care of a lot of things on my end today, you know. Would it be okay if you guys booked a private room for us maybe for dinner? I thought the private room at Cecconi's was cute because it has a heart in it, but I don't know about the food or ... go to the next page. He also enjoys the food at Ocean Prime, but it's kinda running joke place with us cus it's always where we go, LOL, like good old Ocean Prime. Or Baltaire is really sleek and cute, the room there too, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: You see those messages? And then the message is the one in the chart. Does that look right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Let's take this down. And once we take it down, now we can put the screens back on, your Honor. Is it on in the overflow? Great. We can now let's skip ahead to page 26.
MS. GERAGOS: Here we listened to the audio at lines 365 and 366 on direct, and then the next message is about five hours later that -- I'm sorry -- two days later that Ms. Khorram writes to Mr. Combs, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: She says: If you cannot be honest with me, this doesn't work. We literally just went through you choosing to keep things to yourself and hide them, and we know this put us where we all are now. We all know what your kryptonite is and where you don't make the best choices. And that downstairs was weird and felt like a lie, and it's not sitting right with me at all, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And he says: Come take my phone. And she says: Has nothing to do with taking your phone. If you're starting to lie about anything to me, I'm just saying that will break me, and I'll just feel like we are all about to live this shit all over again, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And if we look at the next page on page 27, the messages now jump from November 21 of 2023 to December 28 of 2023, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And we read part of the message in line 378 here, do you remember that?
ANANYA SANKAR: Yes.
MS. GERAGOS: Can you read that entire message starting at "I was confused" and read the whole one this time?
ANANYA SANKAR: I was confused and couldn't concentrate for three years and feel extremely exploited, heartbroken and manipulated by you. In that time I lost many work opportunities following you around, being high and coerced into this dark and humiliating lifestyle. Meanwhile, my peers and colleagues excelled in both meaningful and personal relationships and financial stability. Whereas in three years I turned down work opportunities and healthy relationships to cater to all your exhausting fetishes and needs. I feel sexually exploited, mentally damaged, and emotionally drained by you. I want my wasted three years of time reimbursed and given back to me in the monetary amount of 100K per year and 15 months left of our two year agreement of rent. $450K to move on from the resentment of feeling exploited, manipulated, heartbroken, drugged, and all the loss of potential income.
MS. GERAGOS: We can unzoom. Skip ahead to page 30, please.
MS. GERAGOS: All right. There these are on the same date of December 28 of 2023?
ANANYA SANKAR: Yes.
MS. GERAGOS: And then there's another screenshot on 386 at 12/28/2023. Do you see that?
ANANYA SANKAR: Yes.
MS. GERAGOS: I shouldn't say screenshot. There's a -- I think you said it appeared to be a photograph of a screen?
ANANYA SANKAR: Yes.
MS. GERAGOS: Which is slightly different, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: And then here, it says: You baited me into this psychotic bipolar episode today. I have been leaving you alone. I should have never engaged, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Do you see that message? Okay.
MS. GERAGOS: If we could go to page 31, please. If we could look at lines -- sorry -- line 394. This is a different group chat.
MS. GERAGOS: This is February 9 of 2024 between Brendan Paul, Ms. Khorram, J9 and Faheem, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: This says: Hi. Following up on cash reimbursement. KK is aware and wanted me to make this thread. The following is downward arrow $4,200 flower, $125 store run for personal items, $85 for online personal order, $780 for personal Gucci items, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And Faheem says: We got you covered once Duke come on shift, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And then these next chats on February 18 of 2024, do you see those from 398 down?
ANANYA SANKAR: Yes.
MS. GERAGOS: These messages -- these messages don't mention anything about a hotel, right?
ANANYA SANKAR: Not that I can see.
MS. GERAGOS: Fair to say that the -- what's redacted here is the location of Jane's home?
ANANYA SANKAR: Yes.
MS. GERAGOS: And he -- and it says here, if you look at line 402 from Brendan Paul to Ms. Khorram: I think he wants to say what's up and check on her because she's been sick so fingers crossed. I'll keep you updated, right? Do you see that?
ANANYA SANKAR: Yes.
MS. GERAGOS: We looked at these before, but lines 404 to 405, Ms. Khorram writes to Mr. Paul: They're just chilling at her house?
ANANYA SANKAR: Yes.
MS. GERAGOS: And Mr. Paul writes: Yeah, he said he's going with the flow LOL. Right?
ANANYA SANKAR: Yes.
MS. GERAGOS: So it indicates that they're at her home, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: If you go to next page, page 32, Ms. Khorram writes: LOL. So basically he's lit? Paul writes: Isn't lit lit. I just spoke with him over the phone. Maybe a little but seem totally fine, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: If we go to the next day, February 19 of 2024, these are messages between Mr. Paul and Ms. Khorram again, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: And this says: PD active now. Running to Wal-Mart for them. And Ms. Khorram says: Like wild king mode active or Gucci bag active? And Mr. Paul says: In between the two, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: If that makes sense. He says that below, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And if you go to -- there's no messages here between Ms. Khorram and Jane, right, in February that you see from this date?
ANANYA SANKAR: Not that I can see on this page.
MS. GERAGOS: Okay. And then line 416 is from Brendan Paul to Ms. Khorram, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: He says: Hey B. So TMW he's coming to visit me. He told me to text you. In regards to have everything set up here. I'm here tonight and TMw morning if you want to start early. We can joosh up the place together. He writes: Just got this from Jane, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: There's no messages here regarding cash, right, not in this chart from this day?
ANANYA SANKAR: Not that I can see.
MS. GERAGOS: If we go down to February 26, you see on lines 429 to 430, Ms. Khorram to Mr. Perez, do you see that?
ANANYA SANKAR: Yes.
MS. GERAGOS: And she writes: How does he look. Do you see that?
ANANYA SANKAR: Yes.
MS. GERAGOS: And he writes: Shockingly okay. Way better than usual, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: If we go to the next and last page, this is page 33, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: All right. And the chart ends here at February 26 of 2024, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: There is no messages after this in the chart that you had to review, right?
ANANYA SANKAR: Correct.
MS. GERAGOS: Okay. And here it says: His messages have been little. Copy. Okay, keep me posted from Ms. Khorram to Mr. Perez, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: And Mr. Perez says: I don't know mood yet, but he physically looks fine if you had to put him in front of someone today, but he did just take a full bar so I think he'll be sleep soon, right?
ANANYA SANKAR: Yeah.
MS. GERAGOS: Then Mr. Perez says: Ordered him breakfast. Checking on drip and masseuse, right?
ANANYA SANKAR: Yes.
MS. GERAGOS: Okay.
MS. GERAGOS: May I have one moment?
THE COURT: You may.
MS. GERAGOS: No further questions.
THE COURT: Thank you, Ms. Geragos. Ms. Foster, any redirect?
MS. FOSTER: Just a minute.
REDIRECT EXAMINATION
MS. FOSTER: Could we please pull up Defense Exhibit 1616.
BY MS. FOSTER:
MS. GERAGOS: Ms. Sankar, do you remember being shown this on cross-examination?
ANANYA SANKAR: Yes.
MS. GERAGOS: Is Ms. Khorram a participant in this chat?
MS. GERAGOS: And going to the chart that you have been walking through 1411-R, is Ms. Khorram a participant at all of those chats?
ANANYA SANKAR: Yes.
MS. GERAGOS: And do you also remember being shown some photos of a room on cross-examination?
ANANYA SANKAR: Yes.
MS. GERAGOS: And do you remember that they had the prefix Government Exhibit E dash?
ANANYA SANKAR: Yes.
MS. FOSTER: Ms. Foster, could we pull up Government Exhibit 1301 and go to page 5? Can you highlight paragraph 32.
MS. GERAGOS: What does it say on the stipulation? What device does it say the Government Exhibits with the prefix E come from?
ANANYA SANKAR: They are from a iCloud account for a Jane Doe user.
MS. GERAGOS: And, again, the photos on 1411-R, whose device were those found from?
ANANYA SANKAR: Kristina Khorram.
MS. FOSTER: No further questions.
THE COURT: Thank you, Ms. Foster. Anything further, Ms. Geragos?
MS. GERAGOS: No, your Honor, thank you.
THE COURT: Thank you, Ms. Sankar.
(Witness excused)
THE COURT: The government may call its next witness.
MS. JOHNSON: Your Honor, the government calls Special Agent DeLeassa Penland.
THE COURT: All right.
MS. JOHNSON: May I approach the witness and to put some binders?
THE COURT: You may.
MS. JOHNSON: Thank you. DeLEASSA PENLAND, called as a witness by the Government, having been duly sworn, testified as follows: DEPUTY CLERK: Can I ask you to give the Court your first and last name and please spell your first and last name.
ANANYA SANKAR: DeLeassa Penland: D-E capital L-E-A-S-S-A; P-E-N-L-A-N-D.
THE COURT: Ms. Johnson, you may proceed when ready.
MS. JOHNSON: Thank you, your Honor.