DIRECT EXAMINATION BY MS. SLAVIK:
MS. SLAVIK: Good morning, Mr. Paul.
BRENDAN PAUL: Good morning.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit A-101.
MS. SLAVIK: Mr. Paul, do you recognize the individual in this photo?
BRENDAN PAUL: I do.
MS. SLAVIK: Who is that?
BRENDAN PAUL: Sean Combs.
MS. SLAVIK: How do you know Mr. Combs?
BRENDAN PAUL: That was my former boss.
MS. SLAVIK: What was your position under Mr. Combs?
BRENDAN PAUL: An assistant to him.
MS. SLAVIK: How long did you work as Mr. Combs' assistant?
BRENDAN PAUL: Around 18 months.
MS. SLAVIK: And during what timeframe?
BRENDAN PAUL: Late 2022 to March of 2024.
MS. SLAVIK: What was the last date of your employment?
BRENDAN PAUL: March 25, 2024.
MS. SLAVIK: What happened on March 25, 2024?
BRENDAN PAUL: I was arrested at the Opa-Locka Airport when we were on our way to a family vacation.
MS. SLAVIK: Where is the Opa-Locka Airport?
BRENDAN PAUL: Miami, Florida.
MS. SLAVIK: Why were you arrested?
BRENDAN PAUL: Possession of cocaine.
MS. SLAVIK: Why were you in possession of cocaine?
BRENDAN PAUL: It was in my go Goyard, which was my bag for personal assistant duties.
MS. SLAVIK: Why was cocaine in your Goyard bag?
BRENDAN PAUL: I was sweeping his room early that morning and put it in my bag to put it elsewhere and forgot about it while I was packing.
MS. SLAVIK: When you say "his" room, whose room are you referring to?
BRENDAN PAUL: Mr. Combs.
MS. SLAVIK: We'll circle back to this, Mr. Paul, but first I want to talk about how you came to work for Mr. Combs. Where are you from?
BRENDAN PAUL: Cleveland, Ohio.
MS. SLAVIK: Did you go to college?
BRENDAN PAUL: I did.
MS. SLAVIK: When did you graduate?
BRENDAN PAUL: 2022.
MS. SLAVIK: What did you do after you graduated?
BRENDAN PAUL: I built a studio in my parents' basement with my dad pursuing music production.
MS. SLAVIK: So it was a music studio that you built?
BRENDAN PAUL: Correct.
MS. SLAVIK: Approximately when did you learn about the position as Mr. Combs' personal assistant?
BRENDAN PAUL: Middle of 2022, a couple months after graduation.
MS. SLAVIK: How did you learn about this position?
BRENDAN PAUL: I was called to help manage direct the Crew League Season 4, which was owned by Revolt through Elie Maroun.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 2A-312.
MS. SLAVIK: Do you recognize the individual in this photo, Mr. Paul?
BRENDAN PAUL: I do.
MS. SLAVIK: Who is this?
BRENDAN PAUL: Elie Maroun.
MS. SLAVIK: Can you explain to the jury who Mr. Maroun is?
BRENDAN PAUL: He was a former assistant to Mr. Combs and also helped with his tour management, other things.
MS. SLAVIK: And Mr. Maroun is the individual who told you about the personal assistant position for Mr. Combs?
BRENDAN PAUL: Correct.
MS. SLAVIK: Thank you. You can take this down, Ms. Foster.
MS. SLAVIK: When Mr. Maroun told you about the assistant position, what, if any, advice did he give you?
BRENDAN PAUL: He told me to get in to get out. If you have a girlfriend, break up with her, and you're never going to see your family.
MS. SLAVIK: What did you understand him to mean when he said get in to get out?
BRENDAN PAUL: Build a Rolodex of, you know, clientele and get out.
MS. SLAVIK: In other words, make connections, is that right?
BRENDAN PAUL: Correct.
MS. SLAVIK: And what did you understand him to mean when he said break up with your girlfriend?
BRENDAN PAUL: Just that it was going to be a really tumultuous job that required all of my attention.
MS. SLAVIK: Same thing about never seeing your family?
BRENDAN PAUL: Correct.
MS. SLAVIK: Did you interview for the position, Mr. Paul?
BRENDAN PAUL: I did.
MS. SLAVIK: When was that?
BRENDAN PAUL: I want to say late October, early November of 2022.
MS. SLAVIK: Where did the interview take place?
BRENDAN PAUL: At Mr. Combs' residence in Los Angeles.
MS. SLAVIK: Do you remember the address of that residence?
BRENDAN PAUL: 200 South Mapleton Drive.
MS. SLAVIK: What happened once you arrived at the Mapleton address for the interview?
BRENDAN PAUL: I arrived, entered the middle gate. A former assistant let me in. And I went to the left of the house where the security office was, walked in those doors, was greeted by a security officer and gave him my ID. They scanned it, and I signed an NDA, and then was walked to the home office inside of the house.
MS. SLAVIK: Who was in the home office when you arrived?
BRENDAN PAUL: Kristina Khorram and Frankie Santella.
MS. SLAVIK: Who is Frankie Santella?
BRENDAN PAUL: He was Puff's music manager.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit A-322.
MS. SLAVIK: Do you recognize the individual in this photo, Mr. Paul?
BRENDAN PAUL: I do.
MS. SLAVIK: Who is that?
BRENDAN PAUL: Frankie Santella.
MS. SLAVIK: He is one of the individuals who was there in the home office that day?
BRENDAN PAUL: Correct.
MS. SLAVIK: And who is Kristina Khorram?
BRENDAN PAUL: That is Puff's chief of staff.
MS. SLAVIK: Did you know her by any other names?
BRENDAN PAUL: KK.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 2A-301.
MS. SLAVIK: Do you recognize the individual in this photo, Mr. Paul?
BRENDAN PAUL: I do.
MS. SLAVIK: Who is this?
BRENDAN PAUL: KK.
MS. SLAVIK: Thank you. You can take this down.
MS. SLAVIK: So what happened when you arrived in the office where Mr. Santella and KK were?
BRENDAN PAUL: I had about a 20-minute interview, and then they asked me how soon I could start.
MS. SLAVIK: Did you accept the position?
BRENDAN PAUL: I did.
MS. SLAVIK: When did you start working as Mr. Combs' assistant?
BRENDAN PAUL: I had to travel to Nebraska because my dad was recently diagnosed with prostate cancer, to catch a football game where he went to college, and then I came back that Monday to LA.
MS. SLAVIK: So A couple of days later after the interview?
BRENDAN PAUL: Four days.
MS. SLAVIK: During your first couple of weeks on the job, where did you work?
BRENDAN PAUL: Out of his residence in Los Angeles.
MS. SLAVIK: That's the 200 South Mapleton address?
BRENDAN PAUL: Correct.
MS. SLAVIK: Who gave you instructions during that time period?
BRENDAN PAUL: It mainly came from assistants who were there before me.
MS. SLAVIK: Did KK provide you instructions as well?
BRENDAN PAUL: Not much.
MS. SLAVIK: What were you instructed to do by the other assistants?
BRENDAN PAUL: I helped organize suitcases, do Amazon returns, pick up things at pharmacies, packed a lot of joints in the garage, coordinated with chef on meals and timing, things like that.
MS. SLAVIK: What do you mean by "pack a lot of joints"?
BRENDAN PAUL: Just like cones, I stuffed marijuana into cones.
MS. SLAVIK: What, if any, interactions with Mr. Combs did you have during this first couple of weeks on the job?
BRENDAN PAUL: Almost zero.
MS. SLAVIK: Were you given instructions on how to interact with Mr. Combs?
BRENDAN PAUL: KK told me to kind of just stay clear while I got used to the environment before I met him.
MS. SLAVIK: Were you eventually introduced to Mr. Combs?
BRENDAN PAUL: I was.
MS. SLAVIK: At what point?
BRENDAN PAUL: Two or three weeks into the job.
MS. SLAVIK: Who introduced you to Mr. Combs?
BRENDAN PAUL: Kristina did.
MS. SLAVIK: Can you describe that interaction?
BRENDAN PAUL: She came to the garage, told me to grab something to take notes with. They were having a listening party out back for his new album. I sat in on that. Took notes on what I thought. And then once it was over, she grabbed me and introduced me to Mr. Combs in the back yard.
MS. SLAVIK: When you say "she," you mean KK?
BRENDAN PAUL: I do.
MS. SLAVIK: After this interaction, how frequently did you interact with Mr. Combs throughout your tenure?
BRENDAN PAUL: Almost every day.
MS. SLAVIK: Who was your direct supervisor?
BRENDAN PAUL: KK.
MS. SLAVIK: And what was KK's role?
BRENDAN PAUL: Chief of staff.
MS. SLAVIK: What was your understanding of KK's job responsibilities as Mr. Combs' chief of staff?
BRENDAN PAUL: She basically ran the enterprise, maintained all of his schedule, helped out with the family, things of that nature.
MS. SLAVIK: How often did Mr. Combs and KK communicate throughout the day?
BRENDAN PAUL: Like all day every day.
MS. SLAVIK: How did they communicate?
BRENDAN PAUL: Texts, phone calls, in person.
MS. SLAVIK: What, if any, access did Ms. Khorram or KK have to Mr. Combs' electronic devices?
BRENDAN PAUL: I believe, I mean, full access to his business phone.
MS. SLAVIK: Did you observe KK use Mr. Combs' business phone?
BRENDAN PAUL: I did.
MS. SLAVIK: In what way?
BRENDAN PAUL: Just responding to all the texts he would get because it would be thousands and thousands a day.
MS. SLAVIK: Now, you mentioned a couple of your tasks during the first few weeks on the job, but can you describe more generally your responsibilities as a personal assistant for Mr. Combs?
BRENDAN PAUL: Yeah. Make sure he was on time to appointments, make sure that his meals were on time, his workouts were in order, packing bags, unpacking bags, making sure travel was on point.
MS. SLAVIK: Did Mr. Combs have other personal assistants when you worked for him?
BRENDAN PAUL: He did.
MS. SLAVIK: Approximately how many?
BRENDAN PAUL: At one point there was five of us, then four, and then two.
MS. SLAVIK: Were their responsibilities similar to what you just described?
BRENDAN PAUL: Yeah, we all had basically the same responsibilities, but we divided our task on our strong suits.
MS. SLAVIK: And what do you mean by that?
BRENDAN PAUL: Like being a former college basketball player, I focused a lot with Mr. Combs on his workouts, his meal plans, music because of my music background, and then we kind of just divvied and conquered.
MS. SLAVIK: Mr. Paul, I want to run through a few of the assistants that you worked with.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 2A-314.
MS. SLAVIK: Mr. Paul, do you recognize the individual in this photo?
BRENDAN PAUL: I do.
MS. SLAVIK: Who is this?
BRENDAN PAUL: Jonathan Perez.
MS. SLAVIK: How do you know Jonathan Perez?
BRENDAN PAUL: He was an assistant with me.
MS. SLAVIK: Did his employment as an assistant overlap with yours?
BRENDAN PAUL: It did.
MS. SLAVIK: Thank you, Ms. Foster. Could you take this down and publish what's in evidence as Government Exhibit 2A-317.
MS. SLAVIK: Who is depicted in this photo, Mr. Paul?
BRENDAN PAUL: Frank Rodriguez.
MS. SLAVIK: And how do you know Frank Rodriguez?
BRENDAN PAUL: He's Mr. Combs' butler.
MS. SLAVIK: How did the role of butler compare with the role of personal assistant?
BRENDAN PAUL: It was pretty similar. Just he was -- basically just would never leave Puff's side when it came to if he needed water, chapstick, a lighter, whatever it was, he was there for it.
MS. SLAVIK: Did Frank's employment overlap with yours?
BRENDAN PAUL: It did.
MS. SLAVIK: Did Mr. Combs have a butler before Frank Rodriguez?
BRENDAN PAUL: Yes.
MS. SLAVIK: What was that butler's name?
BRENDAN PAUL: I believe his name was Dean.
MS. SLAVIK: Thank you Ms. Foster. You can take this down, and please publish what's in evidence as Government Exhibit 2A-303.
MS. SLAVIK: Do you recognize who's depicted in this photo, Mr. Paul?
BRENDAN PAUL: I do.
MS. SLAVIK: Who is this?
BRENDAN PAUL: Joey Chavez.
MS. SLAVIK: How do you know Joey Chavez?
BRENDAN PAUL: He was an assistant with me.
MS. SLAVIK: Did his employment overlap with yours?
BRENDAN PAUL: It did.
MS. SLAVIK: Thank you, Ms. Foster. You can take this down.
MS. SLAVIK: Mr. Paul, did you speak with the assistants that we just looked at throughout the day?
BRENDAN PAUL: Yeah, all day every day
MS. SLAVIK: What modes of communication did you use?
BRENDAN PAUL: Mainly group chat text messages, but also, you know, FaceTime, in person.
MS. SLAVIK: Did you have any group chats involving KK?
BRENDAN PAUL: I did.
MS. SLAVIK: What did you discuss in these group chats?
BRENDAN PAUL: Just Mr. Combs' whereabouts, what was on the daily schedule, what was happening, basically a play-by-play of the day.
MS. SLAVIK: Mr. Paul, in preparation for your testimony today, did you review certain communications from when you were Mr. Combs' assistant?
BRENDAN PAUL: I did.
MS. SLAVIK: There should be a binder next to you on the witness stand. Do you see that?
BRENDAN PAUL: I do.
MS. SLAVIK: Can you grab that and flip through it. Just look up at me when you finished flipping through it. What is contained in this binder Mr. Paul?
BRENDAN PAUL: Text messages, photos, anything from my time of employment with Mr. Combs.
MS. SLAVIK: Did these text messages and photos come from your phone?
BRENDAN PAUL: They did.
MS. SLAVIK: Did you review the contents of that binder before you testified today?
BRENDAN PAUL: I did.
MS. SLAVIK: How do you know that?
BRENDAN PAUL: Because we did it together.
MS. SLAVIK: Did you initial the binder?
BRENDAN PAUL: Correct.
MS. SLAVIK: Are the communications and the photos contained in the binder fair and accurate?
BRENDAN PAUL: Yes.
MS. SLAVIK: Your Honor, the government moves to admit the exhibits contained in the binder which are available at Government Exhibit 1510. Ms. Foster, could you please pull up Government Exhibit 1510. Your Honor, the government moves to admit the exhibits listed on the demonstrative at Government Exhibit 1510 with certain exhibits as indicated offered under seal pursuant to the Court's pseudonym order.
THE COURT: Any objection?
MR. STEEL: No, sir.
THE COURT: These exhibits will be admitted and the sealed exhibits will be admitted under seal.
(Government's Exhibits 3G-105; 3G-107; 3G-108; 3G-111; 3G-112, sealed; 3G-112-R; 3G-113; 3G-116; 3G-118, sealed; 3G-118-R; 3G-119; 3G-123; 3G-126; 3G-127; 3G-129; 3G-133; 3G-135; 3G-136, sealed; 3G-136-R; 3G-137; 3G-142; 3G-149; 3G-149; 3G-154, and 3G-157 received in evidence)
MS. SLAVIK: Thank you. You can take that down, Ms. Foster.
MS. SLAVIK: Mr. Paul, did Mr. Combs have other staff that you interacted with regularly?
BRENDAN PAUL: Yeah.
MS. SLAVIK: Did he have security staff?
BRENDAN PAUL: He did.
MS. SLAVIK: Who do you remember being part of Mr. Combs' security staff?
BRENDAN PAUL: Faheem Muhammad was the head of his security. Duke Ellington and Abdul were like the Miami main guys, and then J9 who was also known as James, and Diontae were the LA guys.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 2A-203.
MS. SLAVIK: Mr. Paul, do you recognize the individual in this photo
BRENDAN PAUL: I do.
MS. SLAVIK: Who is this?
BRENDAN PAUL: Faheem Muhammad.
MS. SLAVIK: Do you know Faheem by any other names?
BRENDAN PAUL: We just call him Fah.
MS. SLAVIK: You could take this down, Ms. Foster. Could you please publish what's in evidence as 2A-206.
MS. SLAVIK: Do you recognize this individual, Mr. Paul?
BRENDAN PAUL: I do.
MS. SLAVIK: Who is this?
BRENDAN PAUL: J9.
MS. SLAVIK: And did you know J9 by any other names?
BRENDAN PAUL: Just James.
MS. SLAVIK: Can you remind the jury of what James' position was?
BRENDAN PAUL: He was basically Puff's driver, also security.
MS. SLAVIK: And he was primarily located in Los Angeles, you said?
BRENDAN PAUL: Yes.
MS. SLAVIK: Thank you. You can take that down, Ms. Foster.
MS. SLAVIK: Mr. Paul how many hours per week would you typically work as a personal assistant?
BRENDAN PAUL: Anywhere from 80 to a hundred.
MS. SLAVIK: How many days per week?
BRENDAN PAUL: It -- I mean, it varied depending on his schedule and what assistants were around, but anywhere from four to six.
MS. SLAVIK: Were you off on the days that you didn't work?
BRENDAN PAUL: I was always on call.
MS. SLAVIK: Were you paid a salary?
BRENDAN PAUL: I was.
MS. SLAVIK: What was your salary?
BRENDAN PAUL: $75,000 to start.
MS. SLAVIK: And did that change eventually?
BRENDAN PAUL: January of 2024, I got a raise so -- to a hundred thousand.
MS. SLAVIK: So you started being paid a hundred thousand dollars in January of 2024?
BRENDAN PAUL: Correct.
MS. SLAVIK: How often were you paid?
BRENDAN PAUL: Biweekly.
MS. SLAVIK: Were you paid by a corporate entity?
BRENDAN PAUL: I was.
MS. SLAVIK: Do you remember what corporate entity?
BRENDAN PAUL: Combs Enterprises.
MS. SLAVIK: Ms. Foster, could you please publish for the parties, the witness, and the Court what's been marked for identification as Government Exhibit 3A-158.
MS. SLAVIK: Mr. Paul, do you see your name on this spreadsheet?
BRENDAN PAUL: I do.
MS. SLAVIK: Looking at the line for salary, was this the approximate amount of your biweekly paycheck in January of 2024?
BRENDAN PAUL: Yes.
MS. SLAVIK: Your Honor the government offers Government Exhibit 3A-158 into evidence?
MR. STEEL: No opposition.
THE COURT: 3A-158 will be admitted.
(Government's Exhibit 3A-158 received in evidence)
MS. SLAVIK: Could you please publish this for the jury, Ms. Foster? Could you highlight the row that says Brendan Paul, please.
MS. SLAVIK: Mr. Paul, can you point out the amount of your biweekly paycheck in January 2024?
BRENDAN PAUL: $4,166.67.
MS. SLAVIK: And that's when you were earning approximately $100,000 per year?
BRENDAN PAUL: Correct.
MS. SLAVIK: Thank you. You can take this down.
MS. SLAVIK: When you worked as an assistant for Mr. Combs, where were you based?
BRENDAN PAUL: Both Los Angeles and Miami Beach, Florida.
MS. SLAVIK: Why did you work in both Los Angeles and Miami?
BRENDAN PAUL: Because that's where his residence were.
MS. SLAVIK: You mentioned the address of the Los Angeles residence. What was the address of the Miami residence?
BRENDAN PAUL: 1 and 2Star Island Drive.
MS. SLAVIK: Ms. Foster, could you please publish for the witness, Court, and parties only Government Exhibits 1B-288 and 1B-289 side by side.
MS. SLAVIK: Mr. Paul, what's depicted in these photos?
BRENDAN PAUL: That's his adjacent bathroom in 2 Star Island, his Miami home. We would call that her bathroom.
MS. SLAVIK: Are these fair and accurate photos of the her bathroom in Mr. Combs' Miami residence?
BRENDAN PAUL: They are.
MS. SLAVIK: Your Honor the government offers 1B-288 and 1B-289 into evidence.
MR. STEEL: No objection.
THE COURT: 1B-288 and 1B-289 will be admitted.
(Government's Exhibits 1B-288 and 1B-289 received in evidence)
MS. SLAVIK: Ms. Foster, can you please publish this for the jury.
MS. SLAVIK: Mr. Paul, can you explain to the jury what they're looking at?
BRENDAN PAUL: Just a bathroom in his home.
MS. SLAVIK: Which bathroom is this?
BRENDAN PAUL: His -- not his main bathroom. It was the adjacent bathroom to his main bathroom. We would call this her bathroom.
MS. SLAVIK: What residence was this in?
BRENDAN PAUL: 2 Star Island.
MS. SLAVIK: In Miami?
BRENDAN PAUL: Correct.
MS. SLAVIK: You can take this down, Ms. Foster.
MS. SLAVIK: Mr. Paul, when you were based in Los Angeles, where did you live?
BRENDAN PAUL: Airbnb's all over Los Angeles.
MS. SLAVIK: And what about when you were in Miami?
BRENDAN PAUL: Airbnb's all over Miami.
MS. SLAVIK: Was KK based in Miami as well?
BRENDAN PAUL: She was.
MS. SLAVIK: Where did KK live in Los Angeles?
BRENDAN PAUL: She had an apartment up the street.
MS. SLAVIK: How close was that to the Mapleton residence?
BRENDAN PAUL: Maybe four minutes.
MS. SLAVIK: Where did KK live in Miami?
BRENDAN PAUL: In 2 Star Island.
MS. SLAVIK: Did you ever travel for work, Mr. Paul?
BRENDAN PAUL: I did.
MS. SLAVIK: How frequently?
BRENDAN PAUL: Pretty frequently.
MS. SLAVIK: How often did you travel with Mr. Combs?
BRENDAN PAUL: I think I was on his private jet three or four times.
MS. SLAVIK: When you did travel with him, did you travel by private jet?
BRENDAN PAUL: I did.
MS. SLAVIK: Otherwise you traveled separate from Mr. Combs, is that right?
BRENDAN PAUL: Yes, majority of the time.
MS. SLAVIK: What was the purpose of traveling separately from Mr. Combs?
BRENDAN PAUL: It was my duty to advance any travel that he had. By advance, I mean basically I would go there early with his stylist, and we would set up his rooms.
MS. SLAVIK: What was the purpose of advancing locations?
BRENDAN PAUL: Just so when he walked in, everything was seamless and he had everything he needed.
MS. SLAVIK: Did others travel with you when you advanced locations?
BRENDAN PAUL: Yes.
MS. SLAVIK: Who was that?
BRENDAN PAUL: Stylists, sometimes photographers. Really just depended on what we were doing, where we were going.
MS. SLAVIK: When you traveled separate from Mr. Combs, how would you travel?
BRENDAN PAUL: Commercial.
MS. SLAVIK: Who booked your travel when you traveled in connection with your employment?
BRENDAN PAUL: His travel manager.
MS. SLAVIK: Who was that?
BRENDAN PAUL: Jessica Ruiz.
MS. SLAVIK: What was her role?
BRENDAN PAUL: Travel manager.
MS. SLAVIK: What did she do?
BRENDAN PAUL: Booked flights for the entire, I guess, organization.
MS. SLAVIK: During your tenure as an assistant, did you ever accompany Mr. Combs to club appearances?
BRENDAN PAUL: Couple times.
MS. SLAVIK: Can you explain to the jury what a club appearance is?
BRENDAN PAUL: It's when you get paid to show up at a club.
MS. SLAVIK: What, if anything, did Mr. Combs say about how much money he made from club appearances?
BRENDAN PAUL: I never heard him say anything about how much he made in club appearances.
MS. SLAVIK: Did you ever hear discussions about payment for club appearances?
BRENDAN PAUL: I did.
MS. SLAVIK: What were those discussions?
BRENDAN PAUL: That if he was going to do a club appearance, they needed to sell cases of Deleón, and I think he normally would ask for $150,000.
MS. SLAVIK: How frequently did Mr. Combs do club appearances when you were a personal assistant?
BRENDAN PAUL: Not very frequently.
MS. SLAVIK: Can you ballpark?
BRENDAN PAUL: Maybe eight times in total while I was there.
MS. SLAVIK: Do you remember which clubs?
BRENDAN PAUL: LIV in Miami, Vendôme in Miami. Those were the two I went to.
MS. SLAVIK: Who accompanied Mr. Combs to club appearances?
BRENDAN PAUL: Security, his butler, always another assistant, family sometimes.
MS. SLAVIK: Now, Mr. Paul, you said that you worked approximately 80 to a hundred hours per week as Mr. Combs personal assistant?
BRENDAN PAUL: I did.
MS. SLAVIK: Did you ever go for long stretches without sleep?
BRENDAN PAUL: I did.
MS. SLAVIK: What was the longest period you went without sleep?
BRENDAN PAUL: There was some naps in between, close to three days.
MS. SLAVIK: You said there were naps in between --
BRENDAN PAUL: Yes.
MS. SLAVIK: -- out of three days? Why did you go without sleep for that long?
BRENDAN PAUL: We were in New York releasing his last album.
MS. SLAVIK: How did you feel after you stayed awake for three days?
BRENDAN PAUL: I was young so I was able to handle it.
MS. SLAVIK: What, if anything, did you do to stay awake and alert during your employment for Mr. Combs?
BRENDAN PAUL: Prescription Adderall and the rare, rare use of cocaine.
MS. SLAVIK: Prior to working for Mr. Combs, what, if any, drugs did you take?
BRENDAN PAUL: Smoked marijuana.
MS. SLAVIK: No other drugs?
BRENDAN PAUL: No.
MS. SLAVIK: So just stepping back a little bit, Mr. Paul, can you describe the work environment when you were Mr. Combs' assistant?
BRENDAN PAUL: I mean, it was intense. There was a lot to get done, but we managed.
MS. SLAVIK: How would you describe the mission as Mr. Combs' personal assistant?
BRENDAN PAUL: Just make sure he's always happy.
MS. SLAVIK: And what happened if Mr. Combs wasn't happy?
BRENDAN PAUL: I mean, we would just do whatever we could to make sure that that didn't happen.
MS. SLAVIK: What, if anything, did Mr. Combs say if you told him no?
BRENDAN PAUL: That he doesn't take no for an answer.
MS. SLAVIK: What was Mr. Combs' expectation of his assistants?
BRENDAN PAUL: He used to say that he wants us to move like SEAL Team Six.
MS. SLAVIK: What was your understanding of what he meant by moving like SEAL Team Six?
BRENDAN PAUL: Just being militant, get things done without him asking, nothing taken by surprise.
MS. SLAVIK: Was there ever a time that Mr. Combs fired you?
BRENDAN PAUL: There was.
MS. SLAVIK: How many times did he fire you?
BRENDAN PAUL: Two or three times.
MS. SLAVIK: Is there a particular time that stands out in your mind?
BRENDAN PAUL: Yeah, there was one instance.
MS. SLAVIK: Approximately when was that?
BRENDAN PAUL: I want to say late October, early November of 2023.
MS. SLAVIK: And what were the circumstances?
BRENDAN PAUL: I forgot his lululemon fanny pack when he wanted to go on a walk.
MS. SLAVIK: What do you remember Mr. Combs saying to you after you forgot his lululemon fanny pack?
BRENDAN PAUL: Just like I don't want to see your face. Call KK. Tell her you're fired.
MS. SLAVIK: What was Mr. Combs' demeanor when he said that to you?
BRENDAN PAUL: Just as if like a parent or coach was disappointed with you.
MS. SLAVIK: What was his tone?
BRENDAN PAUL: Angry.
MS. SLAVIK: Had you ever seen Mr. Combs angry like that before?
BRENDAN PAUL: Rarely.
MS. SLAVIK: What did you do after he fired you?
BRENDAN PAUL: I went to lululemon, bought fanny pack, gave it to the assistant who came to cover me, and I went back to my Airbnb.
MS. SLAVIK: Did you call KK?
BRENDAN PAUL: I did.
MS. SLAVIK: What did she say?
BRENDAN PAUL: Just to lay low for a little bit, and that she'll figure it out, and everything should be fine.
MS. SLAVIK: What did you do next?
BRENDAN PAUL: Laid low, took her advice.
MS. SLAVIK: Did you eventually resume your job?
BRENDAN PAUL: I did.
MS. SLAVIK: How did that happen?
BRENDAN PAUL: I advanced London after his birthday, and a few days while in -- after being in London, I saw him again, and he was like, "Oh hey." I was like, "Hey."
MS. SLAVIK: Who told you to advance London?
BRENDAN PAUL: KK.
MS. SLAVIK: By advancing London, you mean setting things up before Mr. Combs arrived?
BRENDAN PAUL: Correct.
MS. SLAVIK: Did you ever speak to Mr. Combs about this incident?
BRENDAN PAUL: No.
MS. SLAVIK: Did you ever speak to KK about it?
BRENDAN PAUL: A few times.
MS. SLAVIK: Did you ever bring concerns to human resources when you were Mr. Combs' assistant?
BRENDAN PAUL: No.
MS. SLAVIK: Why not?
BRENDAN PAUL: I mean, it just wasn't a thing.
MS. SLAVIK: And what do you mean by that?
BRENDAN PAUL: I mean, it -- HR even forgot to pull my federal taxes like my first six to eight months. So if we had problems, we'd go directly to Mr. Combs or Kristina.
MS. SLAVIK: Before we move on, Mr. Paul, did you receive a subpoena requiring you to testify at this trial today?
BRENDAN PAUL: I did.
MS. SLAVIK: And is there also an order compelling you to testify even if your testimony might incriminate you?
BRENDAN PAUL: Yes.
MS. SLAVIK: What is your understanding of what that order requires you to do?
BRENDAN PAUL: Tell the truth.
MS. SLAVIK: What is your understanding of the protections that you get under this order?
BRENDAN PAUL: That what I say can't be used against me.
MS. SLAVIK: Does this order protect you from prosecution from any crimes that you may have committed in the past?
BRENDAN PAUL: No.
MS. SLAVIK: Does this order protect you if you lie today?
BRENDAN PAUL: No.
MS. SLAVIK: In other words, you could still be prosecuted for perjury if you lie?
BRENDAN PAUL: Yes.
MS. SLAVIK: Mr. Paul, did you ever witness Mr. Combs use drugs while you were an assistant?
BRENDAN PAUL: I did.
MS. SLAVIK: What type of drugs?
BRENDAN PAUL: Cocaine, ketamine, ecstasy, marijuana.
MS. SLAVIK: How often did you observe Mr. Combs use drugs?
BRENDAN PAUL: Not like too often.
MS. SLAVIK: Ballpark?
BRENDAN PAUL: Once a month.
MS. SLAVIK: Were there other times where you didn't see Mr. Combs actually use drugs but he seemed high?
BRENDAN PAUL: Yeah.
MS. SLAVIK: Did Mr. Combs keep drugs in his homes?
BRENDAN PAUL: It wasn't like a planned thing to just like keep drugs in his home, but there were drugs in his home sometimes, yes.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 3G-149.
MS. SLAVIK: Do you recognize this photo, Mr. Paul?
BRENDAN PAUL: I do.
MS. SLAVIK: What is it?
BRENDAN PAUL: That's my hand.
MS. SLAVIK: And what is in your hand?
BRENDAN PAUL: On the left is ecstasy. On the right is 2C.
MS. SLAVIK: Can you explain to the jury what 2C is?
BRENDAN PAUL: It's basically just ketamine and some Molly in powder form, dyed pink for the aesthetic.
MS. SLAVIK: Did you take this photo?
BRENDAN PAUL: I did.
MS. SLAVIK: When did you take it?
BRENDAN PAUL: Really early in my employment, in the first few weeks of the new year of 2023.
MS. SLAVIK: Where was this photo taken?
BRENDAN PAUL: In the office of his Mapleton home.
MS. SLAVIK: And when you say his Mapleton home, you mean Mr. Combs'?
BRENDAN PAUL: Yes.
MS. SLAVIK: Why did you take this picture?
BRENDAN PAUL: Because it was left on the desk, and me not knowing -- being new not knowing where it should go, I sent it to the assistants asking where I should put it.
MS. SLAVIK: Do you remember what you ultimately did with ecstasy and 2C that was in your hand?
BRENDAN PAUL: I assume I put it in one of his bags.
MS. SLAVIK: You can take this down, Ms. Foster.
MS. SLAVIK: Mr. Paul, were you ever instructed to obtain drugs for Mr. Combs?
BRENDAN PAUL: I was.
MS. SLAVIK: Who instructed you to obtain drugs for Mr. Combs?
BRENDAN PAUL: He did himself or other assistants.
MS. SLAVIK: What types of drugs did you buy for Mr. Combs?
BRENDAN PAUL: Marijuana, 2C, cocaine, ketamine, ecstasy.
MS. SLAVIK: Let's start with marijuana. How often did you buy marijuana for Mr. Combs?
BRENDAN PAUL: Whenever we were low, I would say like once every two months.
MS. SLAVIK: And in what quantity did you buy marijuana?
BRENDAN PAUL: We bought two different strains, eight ounces each.
MS. SLAVIK: What do you mean by two different strains?
BRENDAN PAUL: There were two types of marijuana strains that he liked.
MS. SLAVIK: Which were those?
BRENDAN PAUL: King Louis and Sunset Sherbet.
MS. SLAVIK: How much did you pay for these marijuana purchases?
BRENDAN PAUL: In total, it was $4,200.
MS. SLAVIK: Who did you buy marijuana from?
BRENDAN PAUL: Phillip Pines.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 2A-315.
MS. SLAVIK: Do you recognize the individual in this photo?
BRENDAN PAUL: I do.
MS. SLAVIK: Who is it?
BRENDAN PAUL: Phillip Pines.
MS. SLAVIK: Who is Mr. Pines?
BRENDAN PAUL: He was one of Puff's former assistants before me.
MS. SLAVIK: And you bought marijuana from Mr. Pines?
BRENDAN PAUL: I did.
MS. SLAVIK: Thank you. You can take this down, Ms. Foster.
MS. SLAVIK: Besides marijuana, you said that you were instructed to purchase ecstasy, cocaine, 2C and ketamine, right?
BRENDAN PAUL: Yes.
MS. SLAVIK: You explained that 2C is the pink powder that we saw in the previous photo?
BRENDAN PAUL: Yes.
MS. SLAVIK: What is ketamine?
BRENDAN PAUL: Horse tranquilizer.
MS. SLAVIK: Are you familiar with the term K-Pops?
BRENDAN PAUL: Yes.
MS. SLAVIK: What does that mean?
BRENDAN PAUL: It's just ketamine in a lollipop form.
MS. SLAVIK: How many times did you buy these types of drugs for Mr. Combs?
BRENDAN PAUL: Less than ten, more than five.
MS. SLAVIK: In what quantity did you buy the drugs?
BRENDAN PAUL: I mean, what I would consider personal use, one to two grams at a time.
MS. SLAVIK: How much did you typically pay for a purchase?
BRENDAN PAUL: Anywhere from $3- to $500.
MS. SLAVIK: Now, you said that sometimes other assistants asked you to get drugs for Mr. Combs?
BRENDAN PAUL: I did.
MS. SLAVIK: Can you explain what you mean by that?
BRENDAN PAUL: Just like if they were with him, and he asked or they knew that it would come up, and I was not with him and also at work, I would just be like, okay, what time are they coming? And I would just go grab it and bring it to them.
MS. SLAVIK: So occasionally you would pick up packages without actually purchasing the drugs. Do I have that right?
BRENDAN PAUL: Correct.
MS. SLAVIK: What did that involve exactly?
BRENDAN PAUL: What I just explained.
MS. SLAVIK: How did you and Mr. -- excuse me -- how did you and other assistants obtain drugs for Mr. Combs?
BRENDAN PAUL: We would text the drug dealer and then the drug dealer would come to either of the homes.
MS. SLAVIK: Do you remember the names of some of these drug dealers?
BRENDAN PAUL: I do.
MS. SLAVIK: What are they?
BRENDAN PAUL: Guido, One Stop, Baby Girl.
MS. SLAVIK: Any others?
BRENDAN PAUL: There's an Ovi.
MS. SLAVIK: How do you spell Ovi?
BRENDAN PAUL: I think it's O-V-I.
MS. SLAVIK: Did you communicate with all these individuals you just mentioned?
BRENDAN PAUL: Not all of them, no.
MS. SLAVIK: With the individuals you did communicate, how did you communicate?
BRENDAN PAUL: I was introduced to them either through texts or phone calls.
MS. SLAVIK: Ms. Foster, could you please publish for the parties only what's been marked for identification as Government Exhibit 2A-508.
MS. SLAVIK: Do you recognize the individual in this photo, Mr. Paul?
BRENDAN PAUL: I do.
MS. SLAVIK: Who is it?
BRENDAN PAUL: He goes by the name Guido.
MS. SLAVIK: Is this a true and accurate picture of Guido?
BRENDAN PAUL: Yeah.
MS. SLAVIK: The government offers Government Exhibit 2A-508.
MR. STEEL: No objection, your Honor.
THE COURT: 2A-508 will be admitted.
(Government's Exhibit 2A-508 received in evidence)
MS. SLAVIK: Could you publish for the jury, Ms. Foster.
MS. SLAVIK: Can you explain to the jury who is depicted in this photo, Mr. Paul?
BRENDAN PAUL: Guido.
MS. SLAVIK: Who is Guido?
BRENDAN PAUL: The drug dealer in Los Angeles.
MS. SLAVIK: Did you see Guido at Mr. Combs' home?
BRENDAN PAUL: I did.
MS. SLAVIK: Once or more than once?
BRENDAN PAUL: Maybe two times.
MS. SLAVIK: You can take this down.
MS. SLAVIK: You mentioned a drug dealer named Baby Girl as well, is that right
BRENDAN PAUL: Yes.
MS. SLAVIK: What, if any, drugs did you buy from her?
BRENDAN PAUL: Honestly, I don't remember off the top of my head.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 3G-123, and put pages 1 and 2 side by side.
MS. SLAVIK: Mr. Paul, what is this?
BRENDAN PAUL: It's a conversation between me, Jonathan Perez, who was another assistant, and Baby Girl.
MS. SLAVIK: And what is the date of this conversation?
BRENDAN PAUL: February 20, 2024.
MS. SLAVIK: Could you zoom out, Ms. Foster, and please blow up the chat on page 2.
MS. SLAVIK: And could you explain to the jury what's happening in this chat?
BRENDAN PAUL: I'm being introduced to Baby Girl through Jonathan Perez.
MS. SLAVIK: Jonathan Perez is introducing you to Baby Girl?
BRENDAN PAUL: Yes.
MS. SLAVIK: How were you introduced to other drug dealers?
BRENDAN PAUL: Same kind of thing or just given a number and handled it from there.
MS. SLAVIK: Who gave you their numbers?
BRENDAN PAUL: Most of the time it was other assistants.
MS. SLAVIK: Did Mr. Combs ever give you contact information for drug dealers?
BRENDAN PAUL: Once or twice.
MS. SLAVIK: And focusing back on this particular chat, why were you reaching out to Baby Girl?
BRENDAN PAUL: I believe to secure drugs.
MS. SLAVIK: For who?
BRENDAN PAUL: Mr. Combs.
MS. SLAVIK: And focusing on the last couple of chats, do you see the message from Baby Girl LA Plug at 11:47 that says: "Is it for you or Puff?"
BRENDAN PAUL: I do.
MS. SLAVIK: What do you say in response?
BRENDAN PAUL: "Puff."
MS. SLAVIK: Can you read your next chat?
BRENDAN PAUL: "But please don't disclose that. You can tell whoever it's for me."
MS. SLAVIK: What did you mean by that?
BRENDAN PAUL: It was just very important to keep his profile low as he was a celebrity, and people could screenshot this and could say, hey, I was asked to get drugs for Diddy.
MS. SLAVIK: Thank you, Ms. Foster. You can take this down.
MS. SLAVIK: After you obtained drugs for Mr. Combs, what typically did you do with them?
BRENDAN PAUL: Either gave them directly to him or put them in his Gucci pouch.
MS. SLAVIK: What is the Gucci pouch?
BRENDAN PAUL: It's just a place where we would keep drugs.
MS. SLAVIK: Who told you to put the drugs in the Gucci pouch?
BRENDAN PAUL: Something I learned from former assistants.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 1B-236.
MS. SLAVIK: Do you recognize this photo, Mr. Paul?
BRENDAN PAUL: I do.
MS. SLAVIK: What is this?
BRENDAN PAUL: The Gucci pouch.
MS. SLAVIK: Who did the Gucci pouch belong to?
BRENDAN PAUL: Mr. Combs.
MS. SLAVIK: Where did Mr. Combs keep the Gucci pouch?
BRENDAN PAUL: Kept it in a backpack or he kept it in his room or on his person.
MS. SLAVIK: Which staff members, if any, handled the Gucci pouch?
BRENDAN PAUL: Assistants.
MS. SLAVIK: Did the security ever handle the Gucci pouch?
BRENDAN PAUL: Not that I'm aware of.
MS. SLAVIK: Under what circumstances did the assistants handle the Gucci pouch?
BRENDAN PAUL: Just whenever he'd ask for it.
MS. SLAVIK: You can take this down. Thank you.
MS. SLAVIK: Did you ever pick up prescription drugs for Mr. Combs?
BRENDAN PAUL: Yes.
MS. SLAVIK: Where did you pick up the prescriptions?
BRENDAN PAUL: Pharmacies.
MS. SLAVIK: Under whose names were the prescriptions?
BRENDAN PAUL: Sean Combs and Frank Black.
MS. SLAVIK: Can you explain who Frank Black is?
BRENDAN PAUL: It was his alias for discretion.
MS. SLAVIK: What do you mean by that?
BRENDAN PAUL: We would use an alias so pharmacists or hotels wouldn't know that it was Sean Combs.
MS. SLAVIK: Mr. Paul, are you familiar with Cialis?
BRENDAN PAUL: I am.
MS. SLAVIK: What is that?
BRENDAN PAUL: Just like another form of saga.
MS. SLAVIK: Did Mr. Combs use Cialis?
BRENDAN PAUL: He did.
MS. SLAVIK: Where did he keep that?
BRENDAN PAUL: I mean, we kept it in med bags, and we also kept it in his nightstand like pill case.
MS. SLAVIK: Were you ever asked to pick up prescription drugs without a prescription for Mr. Combs?
BRENDAN PAUL: Once.
MS. SLAVIK: Who asked you to do that?
BRENDAN PAUL: He did.
MS. SLAVIK: And what type of drugs did he ask you to pick up?
BRENDAN PAUL: Xanax.
MS. SLAVIK: Where did you get the prescription drugs without the prescription?
BRENDAN PAUL: I didn't.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 3G-119 and place pages 1 and 2 side by side.
MS. SLAVIK: Mr. Paul, what is this communication?
BRENDAN PAUL: Text between Mr. Combs and I.
MS. SLAVIK: And do you see the contact that says, Love red phone?
BRENDAN PAUL: Yes.
MS. SLAVIK: What is that?
BRENDAN PAUL: I refer to Mr. Combs as Love, and that was his personal phone, the red phone.
MS. SLAVIK: You mentioned earlier in your testimony that he had a business phone and a personal phone?
BRENDAN PAUL: Yes.
MS. SLAVIK: So you said the red phone is his personal phone?
BRENDAN PAUL: Correct.
MS. SLAVIK: What was his business phone?
BRENDAN PAUL: The yellow phone.
MS. SLAVIK: What is the date of this chat that we're looking at?
BRENDAN PAUL: February 14, 2024.
MS. SLAVIK: And, Ms. Foster, could you please zoom in on the chat on the second page.
MS. SLAVIK: So Mr. Combs says: You get me zans. And what do you say?
BRENDAN PAUL: Still working on it. Have two leads should be able to get by tomorrow. Waiting to hear back from one more person too.
MS. SLAVIK: What was your understanding of what Mr. Combs meant by you get me zans?
BRENDAN PAUL: He wanted xanax.
MS. SLAVIK: The zans refers to xanax?
BRENDAN PAUL: Yes.
MS. SLAVIK: Are you familiar with any other names for xanax?
BRENDAN PAUL: Sticks, bars.
MS. SLAVIK: And what did you mean by "I have two leads"?
BRENDAN PAUL: Just that I was asking around to see if anybody had them.
MS. SLAVIK: Who were you asking?
BRENDAN PAUL: Friends.
MS. SLAVIK: Did you ultimately obtain xanax for Mr. Combs?
BRENDAN PAUL: He got it, but it wasn't from me.
MS. SLAVIK: Thank you, Ms. Foster. You can take this down.
MS. SLAVIK: Did you speak with other assistants about buying drugs for Mr. Combs?
BRENDAN PAUL: Yeah.
MS. SLAVIK: In what context?
BRENDAN PAUL: I mean, I guess just talking about it.
MS. SLAVIK: With other assistants?
BRENDAN PAUL: Yeah.
MS. SLAVIK: Now, you talked about how much you would have to pay for the drugs that you bought for Mr. Combs. How did you pay for those drugs?
BRENDAN PAUL: Mainly in cash.
MS. SLAVIK: Where did you get cash from?
BRENDAN PAUL: Either from the Gucci pouch or from security.
MS. SLAVIK: And how many times did security give you cash for drugs?
BRENDAN PAUL: Less than ten, more than five.
MS. SLAVIK: Do you remember who specifically from security gave you cash?
BRENDAN PAUL: It mainly came from Faheem or whoever Faheem directed.
MS. SLAVIK: What did you tell security or Faheem about why you needed cash?
BRENDAN PAUL: That I needed cash for PD, who was P.Diddy's personal items.
MS. SLAVIK: Did you have to make any sort of formal request to get cash?
BRENDAN PAUL: No formal request, but I would always put it in writing.
MS. SLAVIK: How did you put it in writing?
BRENDAN PAUL: Through texts.
MS. SLAVIK: Did you have to file any sort of report with the finance team that you had taken cash to pay for Mr. Combs' drugs?
BRENDAN PAUL: No.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 3G-135 and put up pages 1 and 2 side by side.
MS. SLAVIK: What is this communication, Mr. Paul?
BRENDAN PAUL: It's a group chat between J9, KK, Faheem and myself.
MS. SLAVIK: Can you remind the jury who J9 is?
BRENDAN PAUL: One of Mr. Combs' security.
MS. SLAVIK: What is the date of this chat?
BRENDAN PAUL: February 9, 2024.
MS. SLAVIK: Ms. Foster, could you please zoom in on the conversation.
MS. SLAVIK: Mr. Paul, could you please read your first message?
BRENDAN PAUL: "Yeah. Hi. Following up on cash reimbursement. KK is aware and wanted me to make this thread. The following is 44,200 flower, which is marijuana, $125 store run for personal items, $85 for online personal order, $780 for personal Gucci items. Total $5,190."
MS. SLAVIK: What does Faheem respond?
BRENDAN PAUL: "We got you covered once Duke come on shift."
MS. SLAVIK: Mr. Paul, focusing on your first message, what did you mean by "KK is aware"?
BRENDAN PAUL: Just that I told her that I was making this group chat because I hadn't been reimbursed in months.
MS. SLAVIK: And this reimbursement was for things that you purchased for Mr. Combs?
BRENDAN PAUL: Correct.
MS. SLAVIK: What does $4,200 flower mean?
BRENDAN PAUL: Just as the amount of money that was spent on marijuana.
MS. SLAVIK: Are you familiar with any other terms for marijuana?
BRENDAN PAUL: Weed.
MS. SLAVIK: What about tree?
BRENDAN PAUL: Sure.
MS. SLAVIK: Focusing on the line that says $780 for personal Gucci items, what did you mean by that?
BRENDAN PAUL: Hard drugs.
MS. SLAVIK: And what about Gucci items, what did you mean by that?
BRENDAN PAUL: Exactly what I just said, hard drugs.
MS. SLAVIK: That you later put in the Gucci pouch?
BRENDAN PAUL: I don't know if I put them there. That's just the money that I was owed.
MS. SLAVIK: And Faheem responds: "We got you covered once Duke comes on shift." Who is Duke?
BRENDAN PAUL: Security in Miami.
MS. SLAVIK: Thank you, Ms. Foster. You can take this down.
MS. SLAVIK: Mr. Paul was there ever a time that you took drugs in Mr. Combs' presence?
BRENDAN PAUL: Once.
MS. SLAVIK: Approximately when was that?
BRENDAN PAUL: At an after-party at Coachella.
MS. SLAVIK: Where were you and Mr. Combs?
BRENDAN PAUL: In a master bathroom of the Airbnb.
MS. SLAVIK: Were you working?
BRENDAN PAUL: I was.
MS. SLAVIK: Can you describe what happened?
BRENDAN PAUL: He had 2C with him. He asked me to try it to see if it was good.
MS. SLAVIK: Did he give you anything?
BRENDAN PAUL: I did it, yes.
MS. SLAVIK: What did the 2C look like?
BRENDAN PAUL: It was pink.
MS. SLAVIK: Had you ever tried 2C before?
BRENDAN PAUL: I had not.
MS. SLAVIK: I'm sorry?
BRENDAN PAUL: I had not.
MS. SLAVIK: Is this something wanted to do?
BRENDAN PAUL: I wanted to prove my loyalty, yeah.
MS. SLAVIK: How did you feel after you took the 2C?
BRENDAN PAUL: A little euphoric, but I don't think I did enough to actually like feel the full effect.
MS. SLAVIK: Were you able to continue working after that?
BRENDAN PAUL: Yes.
MS. SLAVIK: What did Mr. Combs say to you after you took the 2C?
BRENDAN PAUL: He asked if it was good.
MS. SLAVIK: And then what happened?
BRENDAN PAUL: I said I think so.
MS. SLAVIK: And what happened after that?
BRENDAN PAUL: We continued on with our night.
MS. SLAVIK: Shifting to a different topic, Mr. Paul, are you familiar with the term wild king nights?
BRENDAN PAUL: I am.
MS. SLAVIK: Can you tell the jury what wild king nights are?
BRENDAN PAUL: Mr. Combs and a significant other were going to a hotel for the night.
MS. SLAVIK: And what did you understand wild king nights to involve?
BRENDAN PAUL: Partying, alcohol, sex, drugs.
MS. SLAVIK: Your Honor may I approach the witness?
THE COURT: You may.
MS. SLAVIK: Mr. Paul, I've handed you what's in evidence as a sealed exhibit, Government Exhibit 2A-402. Without saying the name, do you recognize the individual depicted in this exhibit?
BRENDAN PAUL: I do.
MS. SLAVIK: I'm going to refer to her as Jane, and I'm going to ask you to do the same thing, okay?
BRENDAN PAUL: Okay.
MS. SLAVIK: Do you know Jane?
BRENDAN PAUL: I do.
MS. SLAVIK: How do you know her?
BRENDAN PAUL: One of Mr. Combs' girlfriends while I was employed.
MS. SLAVIK: Did Jane participate in wild king nights during your employment are with Mr. Combs?
BRENDAN PAUL: She did.
MS. SLAVIK: Did Mr. Combs have other girlfriends?
BRENDAN PAUL: He did.
MS. SLAVIK: Did girlfriends other than Jane participate in wild king nights?
BRENDAN PAUL: Not that I'm aware of.
MS. SLAVIK: Mr. Paul, who called these nights, these hotel stays wild king nights?
BRENDAN PAUL: Kristina.
MS. SLAVIK: Did you call them that?
BRENDAN PAUL: No.
MS. SLAVIK: What did you call them?
BRENDAN PAUL: Just he's going to the hotel.
MS. SLAVIK: Did they always take place at hotels?
BRENDAN PAUL: Not always.
MS. SLAVIK: Where else did they take place?
BRENDAN PAUL: His residence. Her residence.
MS. SLAVIK: Was there a point in time when these wild king nights stopped being at hotels?
BRENDAN PAUL: Sure.
MS. SLAVIK: Approximately when was that?
BRENDAN PAUL: After the Cassie lawsuit.
MS. SLAVIK: What, if any, role did assistants have with respect to wild king nights?
BRENDAN PAUL: Setting up and cleaning up.
MS. SLAVIK: Did you personally set up hotel rooms for wild king nights?
BRENDAN PAUL: On a few occasions.
MS. SLAVIK: And did you personally clean hotel rooms after wild king nights?
BRENDAN PAUL: On a few occasions.
MS. SLAVIK: When in your tenure did you begin setting up and cleaning up hotel rooms for wild king nights?
BRENDAN PAUL: Six to eight months in probably.
MS. SLAVIK: What, if anything, did KK tell you about what role you should have in wild king nights?
BRENDAN PAUL: She didn't really want me involved in them.
MS. SLAVIK: Did she explain why?
BRENDAN PAUL: No.
MS. SLAVIK: Which assistants primarily were responsible for setting up and cleaning up wild king nights?
BRENDAN PAUL: Frank, our butler, and Joey Chavez.
MS. SLAVIK: Approximately how many times did you personally set up hotel rooms for wild king nights?
BRENDAN PAUL: Three or four times.
MS. SLAVIK: Who instructed you to do that?
BRENDAN PAUL: Kristina.
MS. SLAVIK: Approximately how many times did you clean up hotel rooms after wild king nights?
BRENDAN PAUL: Also three or four times.
MS. SLAVIK: And who instructed you to do that?
BRENDAN PAUL: Kristina.
MS. SLAVIK: Mr. Paul, I want to show you a couple of documents.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 3G-112-R.
MS. SLAVIK: Mr. Paul, can you explain to the jury what they're looking at?
BRENDAN PAUL: Yeah. This is from like an iPhone notes app of his schedule that KK would create.
MS. SLAVIK: And why did you have this note in your phone?
BRENDAN PAUL: Because that's how we referred to our schedule.
MS. SLAVIK: And you said that KK wrote this note?
BRENDAN PAUL: Correct.
MS. SLAVIK: What was KK's role in maintaining Mr. Combs' schedule through notes?
BRENDAN PAUL: That was her role.
MS. SLAVIK: Did you ever make a note like this?
BRENDAN PAUL: No.
MS. SLAVIK: I want to direct your attention to the third line, starting with Wednesday 2/8. Could you please read that from there until Friday 2/10?
BRENDAN PAUL: "Finance meeting at house (then no other work for the day). Jane arrives early Wednesday morning and going to hotel. PD doing dinner with Jane for her birthday (Brendan working on reservation). Be ready for a wild king night at her hotel. Jess finalizing hotel today. I have her gift arriving Tuesday morning so will send info so y'all can wrap for him to give when he's ready. Thursday 2/9 no work. Most likely wild king day continued at hotel. Friday 2/10 Jane leaves town around noon. PD has video shoot that night. Frankie has all info and running point on this."
MS. SLAVIK: Focusing on the entry for Wednesday 2/8 where it says "Brendan working on reservation," what reservation were you working on?
BRENDAN PAUL: I believe it was Nobu.
MS. SLAVIK: Nobu, the restaurant?
BRENDAN PAUL: Yes.
MS. SLAVIK: Did you make a dinner reservation for Jane's birthday?
BRENDAN PAUL: I believe so.
MS. SLAVIK: That was at Nobu?
BRENDAN PAUL: Yes.
MS. SLAVIK: Then it says: "Be ready for a wild king night at her hotel." What does that mean?
BRENDAN PAUL: Exactly what it says.
MS. SLAVIK: Can you explain your interpretation?
BRENDAN PAUL: Yeah. That he's going to go party at the hotel after dinner.
MS. SLAVIK: And it says: "Jess finalizing hotel today." Just remind the jury who Jess is?
BRENDAN PAUL: That was his travel manager.
MS. SLAVIK: And for Thursday 2/9, it says: "No work most likely wild king day continued at hotel." What does that mean?
BRENDAN PAUL: That he's just going to continue partying.
MS. SLAVIK: You can take this down, Ms. Foster. Thank you.
MS. SLAVIK: Approximately how often did wild king nights take place?
BRENDAN PAUL: I mean, not extremely often. Probably once a month.
MS. SLAVIK: And you mentioned that wild king nights took place sometimes in hotels?
BRENDAN PAUL: Correct.
MS. SLAVIK: In what cities did those wild king nights take place?
BRENDAN PAUL: Los Angeles and Miami.
MS. SLAVIK: Do you recall do you remember what hotels?
BRENDAN PAUL: L'Ermitage, the London, and then there was one in Miami, The Edition.
MS. SLAVIK: Under whose name were these hotels generally booked?
BRENDAN PAUL: Under assistants' names or under Frank Black.
MS. SLAVIK: Did wild king nights ever take place at Mr. Combs' residences?
BRENDAN PAUL: Yes.
MS. SLAVIK: Which residence?
BRENDAN PAUL: Both Miami and Los Angeles.
MS. SLAVIK: Did wild king nights take place in any other residences?
BRENDAN PAUL: Jane's home.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 3G-127.
MS. SLAVIK: Focusing now on the first page, Mr. Paul, what is this?
BRENDAN PAUL: It's a text message between KK and I.
MS. SLAVIK: What is the date of this communication?
BRENDAN PAUL: February 19, 2024.
MS. SLAVIK: Ms. Foster, could you zoom in on the conversation.
MS. SLAVIK: And, Mr. Paul, could you read your first text?
BRENDAN PAUL: "PD active now. Running to Wal-Mart for them."
MS. SLAVIK: And KK says: "Like wild king mode active or Gucci bag active?" And what do you say in response?
BRENDAN PAUL: "In between the two."
MS. SLAVIK: "Copy."
BRENDAN PAUL: "If that makes sense LOL."
MS. SLAVIK: "LOL." So does this chat relate to a wild king night?
BRENDAN PAUL: Yes.
MS. SLAVIK: Do you remember where this particular wild king night was?
BRENDAN PAUL: Jane's residence.
MS. SLAVIK: And reading your first text what -- excuse me -- "PD active now," what did you mean by that?
BRENDAN PAUL: Just like he was up and moving about.
MS. SLAVIK: And what did you mean when you said: "Running to Wal-Mart for them?"
BRENDAN PAUL: I believe I went to get like soups, towels, a few other things that they both had requested.
MS. SLAVIK: Why did you get towels?
BRENDAN PAUL: I don't know.
MS. SLAVIK: KK then asked: "Like wild king mode active or Gucci bag active." What did you understand that to mean?
BRENDAN PAUL: Like is he partying, is he getting high.
MS. SLAVIK: And when you respond "in between the two," what did you mean by that?
BRENDAN PAUL: Like I think he's about to start partying, and I think he's about to get high.
MS. SLAVIK: Did you set up for this wild king night?
BRENDAN PAUL: Yeah.
MS. SLAVIK: At Jane's residence?
BRENDAN PAUL: Correct.
MS. SLAVIK: Thank you. You can take this down, Ms. Foster.
MS. SLAVIK: So what exactly did setting up a hotel or residence for a wild king night entail?
BRENDAN PAUL: You would go before he got there. You would call room service, have them bring up extra sheets, extra towels, water, fruit plates. And then myself would bring lights, Astroglide, baby oil, liquor, champagne, small toiletries, toothbrush, toothpaste, cologne, that sort of thing.
MS. SLAVIK: How did assistants know what to bring during a wild king night?
BRENDAN PAUL: We created a running list. We had a lot of lists.
MS. SLAVIK: Where did you keep the lists?
BRENDAN PAUL: In the shared notes like in the notes app and shared file that we named PD personal.
MS. SLAVIK: Who did you share that note with?
BRENDAN PAUL: All the other assistants. I wasn't the one who created it.
MS. SLAVIK: You mentioned the Gucci pouch a moment ago?
BRENDAN PAUL: Yes.
MS. SLAVIK: Did the Gucci pouch go to wild king nights?
BRENDAN PAUL: It did.
MS. SLAVIK: Who brought the Gucci pouch to wild king nights?
BRENDAN PAUL: It would be on Mr. Combs' person.
MS. SLAVIK: You ran through a bunch of different supplies for wild king nights?
BRENDAN PAUL: Yes.
MS. SLAVIK: How did you obtain those supplies?
BRENDAN PAUL: We would just tell the house, the property managers of both locations what we were running low on and what to order, and make sure we were always stocked on everything.
MS. SLAVIK: Who was in charge of stocking those supplies at Mr. Combs' residences?
BRENDAN PAUL: It kind of just depends what it was.
MS. SLAVIK: In terms of the baby oil and Astroglide, who was responsible for stocking those items?
BRENDAN PAUL: Property manager.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 3G-154.
MS. SLAVIK: What does this photo show, Mr. Paul
BRENDAN PAUL: A cabinet in her bathroom, which wasn't his main bathroom, in the Mapleton residence.
MS. SLAVIK: And why did you take this photo?
BRENDAN PAUL: Because we had a new property manager who I didn't think was very good, and I sent him a picture of this on how I wanted things organized.
MS. SLAVIK: What exactly is being organized in this photo?
BRENDAN PAUL: As it shows, baby oil and Astroglide.
MS. SLAVIK: Thank you. You can take that down, Ms. Foster.
MS. SLAVIK: Did you ever have to buy the supplies that you -- for a wild king night yourself?
BRENDAN PAUL: Once.
MS. SLAVIK: How did you pay for those supplies?
BRENDAN PAUL: Credit card.
MS. SLAVIK: Your personal credit card?
BRENDAN PAUL: Personal credit card.
MS. SLAVIK: And when you paid for those supplies with your personal credit card, were you reimbursed?
BRENDAN PAUL: Yeah. It took a long time, but I was.
MS. SLAVIK: How did the reimbursement process work?
BRENDAN PAUL: You would take pictures of all your personal receipts, write out exactly why you paid for what you paid for. Then KK would need to approve it, send it back to you, and then you would put Robin and the rest of them in an email chain.
MS. SLAVIK: You mentioned Robin, who is Robin?
BRENDAN PAUL: Robin Greenhill.
MS. SLAVIK: And who is that?
BRENDAN PAUL: One of his financial people at TriStar.
MS. SLAVIK: And what is TriStar?
BRENDAN PAUL: A financial company, to my knowledge.
MS. SLAVIK: Did you ever provide Mr. Combs with cash in connection with wild king nights?
BRENDAN PAUL: If he would ask for it, yeah, one time.
MS. SLAVIK: Who instructed you to bring Mr. Combs cash in that instance?
BRENDAN PAUL: He did himself, but I didn't bring it to him. I gave it to him before he went.
(Continued on next page)
BY MS. SLAVIK:
MS. SLAVIK: How much cash did you give him?
BRENDAN PAUL: $5,000.
MS. SLAVIK: How did you get that cash?
BRENDAN PAUL: Through security.
MS. SLAVIK: And you said this was before a wild king night?
BRENDAN PAUL: I did.
MS. SLAVIK: Who specifically from security, if you remember?
BRENDAN PAUL: I don't.
MS. SLAVIK: Were you aware of other assistants bringing or getting cash for Mr. Combs before wild king nights?
BRENDAN PAUL: Yeah, once or twice.
MS. SLAVIK: Did assistants typically deliver cash to Mr. Combs before wild king nights?
BRENDAN PAUL: I don't know the exact answer to that. It just varied on the situation.
MS. SLAVIK: Were you aware of any instances in which cash was delivered during a wild king night?
BRENDAN PAUL: One time.
MS. SLAVIK: What were those circumstances?
BRENDAN PAUL: Frank left it at the front desk of a hotel.
MS. SLAVIK: Frank left cash at a hotel?
BRENDAN PAUL: Yes.
MS. SLAVIK: And did Frank tell you about this?
BRENDAN PAUL: Yeah, because he, I was, like, where you going? He said I have to run back to a hotel.
MS. SLAVIK: What did he tell you about leaving cash at a hotel?
BRENDAN PAUL: That he left it at the front desk.
MS. SLAVIK: How did he leave it?
BRENDAN PAUL: I believe in an envelope.
MS. SLAVIK: Mr. Paul, were there ever times that Mr. Combs contacted you during a wild king night?
BRENDAN PAUL: A couple times.
MS. SLAVIK: How would he contact you?
BRENDAN PAUL: Via FaceTime or audio text messages.
MS. SLAVIK: Ms. Foster, could you please publish what's in evidence as Government Exhibit 3G142.
MS. SLAVIK: Mr. Paul, can you explain to the jury what this shows?
BRENDAN PAUL: Just, like, outfits from a sex store.
MS. SLAVIK: And why did you take this photo?
BRENDAN PAUL: He had asked me to run to the sex store, so I took pictures of things, sent it to them -- sent it to him. He never responded, so I went back to his residence.
MS. SLAVIK: And who was with Mr. Combs at the time that he made this request of you?
BRENDAN PAUL: Jane.
MS. SLAVIK: And you said he didn't respond?
BRENDAN PAUL: Correct.
MS. SLAVIK: So what did you do?
BRENDAN PAUL: I went back to his residence.
MS. SLAVIK: Thank you, Ms. Foster. You can take those down.
MS. SLAVIK: Mr. Paul, you also mentioned that you cleaned up hotel rooms after wild king nights. Do you remember that?
BRENDAN PAUL: Correct.
MS. SLAVIK: Approximately how many times did you do that?
BRENDAN PAUL: Three or four times.
MS. SLAVIK: What did that involve?
BRENDAN PAUL: Just going to the hotel room after he left, putting on gloves and putting towels and sheets in a nice pile; cleaning up as best you could, throwing out empty bottles of baby oil, liquor. Just cleaning, in a sense.
MS. SLAVIK: You said that you put on gloves?
BRENDAN PAUL: Yeah.
MS. SLAVIK: Why did you put on gloves?
BRENDAN PAUL: For sanitary reasons.
MS. SLAVIK: What, if anything, did you observe when you cleaned up hotel rooms after wild king nights?
BRENDAN PAUL: Just that it was kind of in disarray.
MS. SLAVIK: Did you ever observe drug residue?
BRENDAN PAUL: One time.
MS. SLAVIK: And can you explain what you saw?
BRENDAN PAUL: Saw a white powder substance. I don't know what it was.
MS. SLAVIK: What was the purpose of cleaning up hotel rooms after wild king nights?
BRENDAN PAUL: To avoid getting damages charges.
MS. SLAVIK: Did you leave tips for hotel cleaning staff?
BRENDAN PAUL: I did.
MS. SLAVIK: In cash?
BRENDAN PAUL: Yes.
MS. SLAVIK: How did you get the cash for the tips?
BRENDAN PAUL: I just always had some cash on me.
MS. SLAVIK: Was it your personal cash?
BRENDAN PAUL: Yes.
MS. SLAVIK: Ms. Foster, could you please pull up what's in evidence as Government Exhibit 3G157.
MS. SLAVIK: Mr. Paul, what does this photo show?
BRENDAN PAUL: A hotel room after he had left.
MS. SLAVIK: And do you remember when you took this photo?
BRENDAN PAUL: Sometime in late 2023, I would assume.
MS. SLAVIK: And this was in connection with your cleanup of a hotel room after a wild king night?
BRENDAN PAUL: Correct.
MS. SLAVIK: Why did you take this photo?
BRENDAN PAUL: To send it to the travel manager, to be, like, hey, there's probably going to be some damage charges just in case she wanted to dispute them with the hotel.
MS. SLAVIK: Can you remind the jury who the travel manager was?
BRENDAN PAUL: Jessica Ruiz.
MS. SLAVIK: Thank you. You can take that down.
MS. SLAVIK: Now, Mr. Paul, you said that you would set up hotel rooms with a variety of supplies before wild king nights. Do you remember that?
BRENDAN PAUL: Correct.
MS. SLAVIK: So, typically when you'd set up hotel rooms for wild king nights, what would already be in the room when Mr. Combs arrived?
BRENDAN PAUL: I guess what do you mean by that?
MS. SLAVIK: What supplies did you bring to wild king nights before Mr. Combs arrived?
BRENDAN PAUL: Toiletries, lights, candles, incense, baby oil, Astroglide, condoms, liquor, champagne, soup. I mean the list goes on.
MS. SLAVIK: And you also testified that Mr. Combs brought his Gucci pouch to wild king nights?
BRENDAN PAUL: I mean -- yeah, I had seen him bring it a few times.
MS. SLAVIK: And just remind the jury what was in the Gucci pouch.
BRENDAN PAUL: Drugs.
MS. SLAVIK: And you testified that on occasion you purchased drugs for Mr. Combs, is that right?
BRENDAN PAUL: Yes.
MS. SLAVIK: And on those occasions when you purchased drugs, other than marijuana, can you just remind the jury approximately how much money you paid for those drugs?
BRENDAN PAUL: Anywhere from a hundred to $500.
MS. SLAVIK: What, if anything, did Mr. Combs do if he needed something during a wild king night?
BRENDAN PAUL: Called us, as in assistants.
MS. SLAVIK: You or other assistants, is that right?
BRENDAN PAUL: Yes.
MS. SLAVIK: And you also testified that occasionally you cleaned up after wild king nights, is that right?
BRENDAN PAUL: Correct.
MS. SLAVIK: And when a wild king night was at a hotel, you left cash tips for the cleaning staff?
MR. STEEL: Objection, your Honor.
BRENDAN PAUL: Correct.
THE COURT: Hold on. Sorry. If there's an objection, just hold on for a second until we resolve that. Grounds.
MR. STEEL: Asked and answered.
THE COURT: That's overruled. Ms. Slavik.
BY MS. SLAVIK:
MS. SLAVIK: You can answer, Mr. Paul.
BRENDAN PAUL: Can you ask the question again?
MS. SLAVIK: The question was whether you left cash tips for the hotel cleaning staff when you cleaned up after wild king nights.
BRENDAN PAUL: I did.
MS. SLAVIK: And separately, Mr. Paul, you testified that you and other assistants provided Mr. Combs with cash in connection with wild king nights?
BRENDAN PAUL: Occasionally, yeah.
MS. SLAVIK: And the one time that you did it, just remind the jury of how much you gave him.
BRENDAN PAUL: $5,000.
MS. SLAVIK: Did you provide Mr. Combs with cash in that amount in any other context?
BRENDAN PAUL: Not that I'm aware of.
MS. SLAVIK: Just wrapping up, Mr. Paul, you said that your last day working for Mr. Combs was on March 25, 2024?
BRENDAN PAUL: Correct.
MS. SLAVIK: Ms. Foster, could you please publish for the witness, Court and parties what's been marked for identification as Government Exhibit 1C109.
MS. SLAVIK: Mr. Paul, do you see this photo?
BRENDAN PAUL: I do.
MS. SLAVIK: What is it?
BRENDAN PAUL: That's me, Kristina and Mr. Combs.
MS. SLAVIK: Your Honor, the government moves to admit Government Exhibit 1C109.
MR. STEEL: No objection.
THE COURT: All right. 1C109 will be admitted.
(Government Exhibit 1C109 received in evidence)
MS. SLAVIK: Ms. Foster, could you please publish this to the jury.
MS. SLAVIK: Mr. Paul, can you explain to the jury what they're looking at?
BRENDAN PAUL: This is Mr. Combs, Kristina and I boarding a private jet to go on a vacation to the Bahamas.
MS. SLAVIK: Whose private jet were you on?
BRENDAN PAUL: It's not his. It was rented.
MS. SLAVIK: Where was this photo taken?
BRENDAN PAUL: At the Miami Opa-Locka Airport.
MS. SLAVIK: When was this photo taken?
BRENDAN PAUL: March 25, 2024.
MS. SLAVIK: Where were you planning to travel before you were arrested?
BRENDAN PAUL: The Bahamas.
MS. SLAVIK: And you were getting to the Bahamas on this private plane?
BRENDAN PAUL: Correct.
MS. SLAVIK: This was work travel for you?
BRENDAN PAUL: Yes.
MS. SLAVIK: You said that you were arrested for cocaine possession on that day, is that right?
BRENDAN PAUL: Yes.
MS. SLAVIK: Just remind the jury why you had cocaine that day.
MR. STEEL: Objection.
THE COURT: That's sustained.
BY MS. SLAVIK:
MS. SLAVIK: Why did you have cocaine that day, Mr. Paul?
THE COURT: That's sustained, right? I think the grounds are asked and answered.
MR. STEEL: Yes.
THE COURT: Yes. Sustained.
BY MS. SLAVIK:
MS. SLAVIK: Was the cocaine yours, Mr. Paul?
THE COURT: That's overruled.
BY MS. SLAVIK:
MS. SLAVIK: It was not your cocaine?
BRENDAN PAUL: Correct.
MS. SLAVIK: Did you tell law enforcement that it wasn't your cocaine?
MS. SLAVIK: Why not?
BRENDAN PAUL: Loyalty.
MS. SLAVIK: Whose cocaine was it?
BRENDAN PAUL: Mr. Combs's.
MS. SLAVIK: Mr. Paul, you were arrested that day?
BRENDAN PAUL: I was.
MS. SLAVIK: What is the status of your criminal case?
BRENDAN PAUL: My charges have been dropped, because I have a really good lawyer.
MS. SLAVIK: What, if anything, did you do to have those charges dropped?
BRENDAN PAUL: I went into a pretrial diversion program where I took over 20 drug classes and a bunch of random drug testing.
MS. SLAVIK: What, if any, interactions did you have with Mr. Combs after you were arrested?
BRENDAN PAUL: Zero.
MS. SLAVIK: When was the last time you saw Mr. Combs?
BRENDAN PAUL: In this photo, basically, March 25.
MS. SLAVIK: When was the last time you spoke with Mr. Combs?
BRENDAN PAUL: Same day.
MS. SLAVIK: One moment, your Honor. No further questions at this time.
THE COURT: All right. Thank you. Cross-examination.
CROSS-EXAMINATION BY MR. STEEL:
MR. STEEL: Good morning.
BRENDAN PAUL: How you doing?
MR. STEEL: I'd like to put into perspective some of your answers. OK?
MR. STEEL: You are -- would you describe yourself as an extremely hard worker?
BRENDAN PAUL: Correct.
MR. STEEL: And you set your sights on goals, and then you go after those goals. Is that fair to say?
BRENDAN PAUL: 100 percent.
MR. STEEL: And you give everything that you have to accomplishing these goals, mentally and physically, true?
BRENDAN PAUL: That's how I was raised.
MR. STEEL: And you strive for perfection, fair?
BRENDAN PAUL: Yeah.
MR. STEEL: And I'm not saying this is the only example, but you actually worked so hard that you walked on to college basketball, true?
BRENDAN PAUL: Correct.
MR. STEEL: And it's not just any basketball program; you walked on to a school in this state a couple hours away at Syracuse University, right?
BRENDAN PAUL: Yes.
MR. STEEL: And you were able to do that and you played for, you mentioned, like, a coach?
BRENDAN PAUL: Yeah, Jim Boeheim.
MR. STEEL: Yeah. An iconic coach, right?
BRENDAN PAUL: Yeah.
MR. STEEL: And you actually had time in the games where you played, in fact, in the ACC tournament, true?
BRENDAN PAUL: Correct.
MR. STEEL: And you played against North Carolina?
BRENDAN PAUL: I did.
MR. STEEL: And I know Syracuse, your team, won the game, right?
BRENDAN PAUL: Yeah.
MR. STEEL: But then Covid hit, and everything shut down, true?
BRENDAN PAUL: Yeah.
MR. STEEL: I know that's just one example of athletics, but you also studied hard, you worked hard academically, true?
BRENDAN PAUL: I did.
MR. STEEL: And sir, is it correct that you achieved ACC academic honors in 2019, 2020?
BRENDAN PAUL: It is.
MR. STEEL: Same year as you're playing for the team, right?
BRENDAN PAUL: Yes.
MR. STEEL: And that is -- and you say that's how you were raised, that's your makeup, right?
BRENDAN PAUL: 100 percent.
MR. STEEL: And it's still your makeup today, right?
BRENDAN PAUL: Yes.
MR. STEEL: And it was your makeup when you asked for and you did get the opportunity to work for Sean?
BRENDAN PAUL: Yes.
MR. STEEL: True?
BRENDAN PAUL: True.
MR. STEEL: And after graduating college, I think you said you were -- I previously said it was in 2022, correct?
BRENDAN PAUL: Yes.
MR. STEEL: And then you told about, you wanted to do work, you wanted to focus your concentration with your work ethic on the music industry, right?
BRENDAN PAUL: Music/entertainment, yeah.
MR. STEEL: And the business side of it as well, right; you wanted to learn everything?
BRENDAN PAUL: Yeah.
MR. STEEL: You wanted to soak it all in, true?
BRENDAN PAUL: Yes.
MR. STEEL: And you mentioned that you and your father actually built out a music studio for you?
BRENDAN PAUL: We did.
MR. STEEL: And then you used your contacts through basketball to eventually get you, and you explained the gentleman, who it was, but you got to work with another iconic person -- Sean Combs, true?
BRENDAN PAUL: I did.
MR. STEEL: And you were excited about that job, right?
BRENDAN PAUL: For sure.
MR. STEEL: And that is something that you undertook because even you were told get in, get out, break up with your girlfriend, you're not going to see your family, you took that just like you do all of your goals; you took that as this is a great opportunity, true?
BRENDAN PAUL: Yes.
MR. STEEL: And you did it with eyes open, right?
BRENDAN PAUL: I did.
MR. STEEL: Nobody fooled you about how hard it was going to be work with such an iconic person as Mr. Combs, right?
MR. STEEL: And you welcomed that?
BRENDAN PAUL: I did.
MR. STEEL: Because you wanted to learn the business side of music, true?
BRENDAN PAUL: Yes.
MR. STEEL: The music side of music, the actual songs, true?
BRENDAN PAUL: Yes.
MR. STEEL: The production, right?
BRENDAN PAUL: Yup.
MR. STEEL: You also were going to be with a billionaire and see what that lifestyle's like and how to react and how to attract good people, right?
BRENDAN PAUL: Yes.
MR. STEEL: And you're how old in 2022?
BRENDAN PAUL: 23 years old.
MR. STEEL: And you're making $75,000 a year, true?
BRENDAN PAUL: Yes.
MR. STEEL: And you are getting unbelievable opportunities because of Sean Combs, right?
BRENDAN PAUL: Yes.
MR. STEEL: Now, you mentioned some of the things that you did to the jury, and they were, you know, important; I'm not saying they're not important, but, you know, workouts and meals and packing and unpacking and travel, calling, and timeliness, those are all things that you did every day, right?
BRENDAN PAUL: Correct.
MR. STEEL: Because Mr. Combs gets, I think your word was thousands of text messages a day, true?
BRENDAN PAUL: Yes.
MR. STEEL: No one can handle that, right?
MR. STEEL: So he needed a support staff to really get him through where he's going to be and how he has to answer and to dissect what is important and what has to be prioritized, right?
BRENDAN PAUL: He did.
MR. STEEL: And that was one of your responsibilities, right?
BRENDAN PAUL: Yes.
MR. STEEL: And he trusted you; you know that?
BRENDAN PAUL: Yes.
MR. STEEL: And he let you about be around him and see his phone and see his activities, true?
BRENDAN PAUL: He did.
MR. STEEL: And you welcomed that?
BRENDAN PAUL: I did.
MR. STEEL: And you enjoyed being with Sean Combs, true?
BRENDAN PAUL: Yes.
MR. STEEL: And what you stated is that you worked approximately, you know, the number of hours that you talked about, four to six days a week, is that true?
BRENDAN PAUL: Yeah, 80 to 100 hours a week.
MR. STEEL: And that's approximately -- I'm not saying this is perfect math, but it's approximately nine in the morning to 11 o'clock p.m., four days a week. Is that fair?
BRENDAN PAUL: Yeah, sometimes later.
MR. STEEL: OK. And during that time you are definitely helping Sean Combs, right?
BRENDAN PAUL: Yes.
MR. STEEL: And you're helping your coworkers, right?
BRENDAN PAUL: Yeah.
MR. STEEL: You're also helping yourself, true?
BRENDAN PAUL: Depends what you mean by that.
MR. STEEL: You're learning?
BRENDAN PAUL: Yes.
MR. STEEL: And this was, like, an amazing opportunity for growth in your mind, right?
BRENDAN PAUL: 23, it was pretty incredible.
MR. STEEL: Yeah, and we'll talk about that in a minute, if you don't mind, but you're referring to the release of a record album, right?
BRENDAN PAUL: Yes.
MR. STEEL: OK. Now, the prosecutor was asking you a lot about drugs. Do you remember a lot of those questions?
BRENDAN PAUL: Yes.
MR. STEEL: You made it clear to the jury, and you've always made it clear, you are not some drug mule, right?
BRENDAN PAUL: Absolutely not.
MS. SLAVIK: Objection.
THE COURT: Overruled.
BY MR. STEEL:
MR. STEEL: Am I right?
BRENDAN PAUL: Absolutely not.
MR. STEEL: And that means -- some jurors may not know what that means. That means somebody who was just sneaking around --
MS. SLAVIK: Objection.
BY MR. STEEL:
MR. STEEL: -- getting drugs for a person. Is that true?
THE COURT: That's sustained.
BRENDAN PAUL: My understanding --
THE COURT: That's sustained.
BY MR. STEEL:
MR. STEEL: What's your understanding of what a drug mule is?
BRENDAN PAUL: Someone who traffics kilos and kilos of drugs across the world.
MR. STEEL: And what you're doing is, on a few occasions, I think you said between five and ten?
BRENDAN PAUL: Correct.
MR. STEEL: Out of 18 months of working next to Sean Combs for sometimes 10, 12, 14 hours a day, you're talking about a minuscule amount of times dealing with drugs, true?
BRENDAN PAUL: Me personally handling them, yes.
MR. STEEL: Yeah. And this was a minor part of what you did with Sean Combs and the other coworkers, right?
BRENDAN PAUL: Absolutely.
MR. STEEL: And we're also talking about -- when you said trafficking, we're also talking about between $100 of drugs or $200, $300, $400, maybe a maximum of $500, that's what we're talking about, right?
BRENDAN PAUL: It is.
MR. STEEL: That's it, correct?
BRENDAN PAUL: Yes.
MR. STEEL: And but the prosecutor was asking you all these questions about drugs --
MS. SLAVIK: Objection.
THE COURT: Yes. No preambles. Just ask questions.
BY MR. STEEL:
MR. STEEL: OK. This was clearly just personal use for Mr. Combs?
MS. SLAVIK: Objection.
THE COURT: Rephrase.
BY MR. STEEL:
MR. STEEL: To your observation, this was clearly just personal-use amount of drugs for Mr. Combs --
MS. SLAVIK: Objection.
MR. STEEL: -- is that your understanding?
THE COURT: That's overruled.
BRENDAN PAUL: Yes, that's my understanding.
MR. STEEL: Now, you mentioned one time that Sean -- excuse me, Mr. Combs asked you to see whether drugs were good; that's the only time that you ever saw Sean Combs ask anybody to do drugs, is that right?
BRENDAN PAUL: Correct.
MR. STEEL: Now, you mentioned -- I'm going to call her what I think you call her. You call her K.K., right?
BRENDAN PAUL: Uh-huh.
MR. STEEL: True?
BRENDAN PAUL: Yes.
MR. STEEL: And K.K.'s not a drug user, is she, to your knowledge?
BRENDAN PAUL: Not that I'm aware of.
MR. STEEL: And K.K.'s not even a drinker of alcohol, to your knowledge, true?
BRENDAN PAUL: Correct.
MR. STEEL: Now, you were also asked about wild king night, or you called it, I think, you know, hotel night or setup night, or something like that, right?
BRENDAN PAUL: Yes.
MR. STEEL: And that was like the drugs; that's also personal to Mr. Combs, right?
MS. SLAVIK: Objection.
THE COURT: Sustained. Rephrase.
BY MR. STEEL:
MR. STEEL: Did you consider it to be his personal time?
BRENDAN PAUL: Yeah, I considered it to be like an escape, alone time.
MR. STEEL: And that's because you noticed that it's with his significant other or one of -- he had several girlfriends, you made clear, right?
BRENDAN PAUL: Yes.
MR. STEEL: But it was with a significant other, one of the girlfriends, Jane, right?
BRENDAN PAUL: Correct.
MR. STEEL: And it was Mr. Combs's opportunity to escape the thousands of texts and go off somewhere to be by himself along with Jane, true?
BRENDAN PAUL: Yes.
MR. STEEL: And just like the drugs, that was his personal event, is that -- from your observation, is that true?
MS. SLAVIK: Objection.
THE COURT: That needs to be rephrased.
BY MR. STEEL:
MR. STEEL: From your observation, that was his personal time, right?
BRENDAN PAUL: Yes.
MR. STEEL: Much like the drugs, that was his personal use --
MS. SLAVIK: Objection.
BY MR. STEEL:
MR. STEEL: -- right?
THE COURT: Sustained.
BY MR. STEEL:
MR. STEEL: Now, when you would set up either a hotel or at a home, did you ever notice Jane to be hesitant when you spoke with her in preparing for one of these nights?
BRENDAN PAUL: I did not.
MR. STEEL: Did you ever notice that she was apprehensive about appearing at one of these nights that you're describing?
MR. STEEL: Did you ever, afterwards, when you spoke with Jane, think that she was in any way sorry or, or upset that she participated --
MS. SLAVIK: Objection.
BY MR. STEEL:
MR. STEEL: -- with Mr. Combs?
THE COURT: That's sustained.
BY MR. STEEL:
MR. STEEL: From your personal observation, did you speak with Jane after one of these nights?
BRENDAN PAUL: Almost every time.
MR. STEEL: And did you ever notice anything that would cause you pause to think that she was not a willing participant?
MS. SLAVIK: Objection.
THE COURT: Overruled.
BRENDAN PAUL: Absolutely not.
MR. STEEL: Now, if you would have noticed that there was any type of what you believed to be nonconsented-to sexual conduct, you would not have worked there, true?
MS. SLAVIK: Objection.
THE COURT: Sustained.
BY MR. STEEL:
MR. STEEL: You mentioned on your direct examination, I believe, that K.K. ran the enterprise. Do you remember something like that you saying?
BRENDAN PAUL: Around there.
MR. STEEL: Now, you're not saying a criminal enterprise, are you?
MS. SLAVIK: Objection.
THE COURT: That's overruled.
MR. STEEL: You're saying because the title of the company you got paid for was Combs Enterprises, right?
BRENDAN PAUL: Yes.
MR. STEEL: And you would not work for a criminal, would you?
MS. SLAVIK: Objection.
THE COURT: That's overruled.
BRENDAN PAUL: Absolutely not.
MR. STEEL: And you didn't work for a criminal, as you sit here today, looking back, right?
MS. SLAVIK: Objection.
BY MR. STEEL:
MR. STEEL: Am I right?
THE COURT: Sustained.
MR. STEEL: I didn't hear you, your Honor.
MR. STEEL: You never thought that the king night included anything that was criminal, did you?
MS. SLAVIK: Objection.
THE COURT: Overruled.
MR. STEEL: Now, you care about your reputation, right?
BRENDAN PAUL: Absolutely.
MR. STEEL: And you care about your family; you said that's how you were raised, right?
BRENDAN PAUL: That's the most important thing to me.
MR. STEEL: And you're a reflection on your family, true?
BRENDAN PAUL: Thousand percent.
MR. STEEL: Now, when you got arrested in March 2024, you hired one of the best lawyers in the country, true?
BRENDAN PAUL: I did.
MR. STEEL: And your lawyer's here today?
BRENDAN PAUL: He is.
MR. STEEL: And that's Brian Bieber, from the state of Florida, right?
BRENDAN PAUL: Yes, sir.
MR. STEEL: And your case eventually -- you said you went through some program -- I'm not saying it was rigorous, but it got dismissed in the state of Florida, right?
BRENDAN PAUL: Correct.
MR. STEEL: And that a small amount of drug case?
BRENDAN PAUL: .7 grams.
MR. STEEL: And it was personal use, at best, right?
MS. SLAVIK: Objection.
THE COURT: Sustained.
BY MR. STEEL:
MR. STEEL: And the only reason you had those drugs is because you said you were cleaning in Sean's, in or around Sean's room and you found the drugs, right?
BRENDAN PAUL: Correct.
MR. STEEL: And you put them into your bag and you forgot you put them in there when you got on the plane, true?
BRENDAN PAUL: Correct.
MR. STEEL: Sean Combs didn't ask you to bring these drugs with you, right?
BRENDAN PAUL: He did not.
MR. STEEL: He didn't even know you had them on you, right?
MR. STEEL: And K.K. didn't ask you to bring these drugs with you, did she?
MR. STEEL: It was a mistake, right?
BRENDAN PAUL: Yes.
MR. STEEL: So when you told the officers everything in that bag belongs to me, you did not realize that you had left this small amount of drugs in the bag, right?
BRENDAN PAUL: That is correct.
MR. STEEL: And then when they pulled it out, you're like, oh, my God, I forgot I put it in there, right?
BRENDAN PAUL: Heart drop.
MR. STEEL: That's it; that's the whole case, right?
BRENDAN PAUL: Yes.
MR. STEEL: And that case is dismissed?
BRENDAN PAUL: Correct.
MR. STEEL: Now let's talk about -- you mentioned 2023; that was an incredible time, true?
BRENDAN PAUL: Yeah.
MR. STEEL: And you started at the very end, maybe November, of 2022 with Sean, true?
BRENDAN PAUL: Yeah.
MR. STEEL: And we'll --
BRENDAN PAUL: Trial, trial period, but --
MR. STEEL: We'll say November, December --
BRENDAN PAUL: Yeah.
MR. STEEL: And by 2023, there's a gigantic focus on an album release, right?
BRENDAN PAUL: Yes.
MR. STEEL: And you had front-row seats, and actually your fingerprints are on that album; you participate in that, true?
BRENDAN PAUL: Correct.
MR. STEEL: And you did everything from the business side as well as the music side, in the studio or outside the studio, to get that album released, true?
BRENDAN PAUL: Yes.
MR. STEEL: And you were asked about staying up three days, which sounds like a lot, but this was also exhilarating, wasn't it?
BRENDAN PAUL: Correct.
MR. STEEL: You wanted to stay up those three days because that's -- the end of those three days is when the album actually got finished and released, right?
BRENDAN PAUL: I don't know if I wanted to.
MR. STEEL: It was a requirement to get this out on time, true?
BRENDAN PAUL: Yes.
MR. STEEL: And everybody was working like that, right?
BRENDAN PAUL: Correct.
MR. STEEL: Including Mr. Combs?
BRENDAN PAUL: Yes.
MR. STEEL: He is not just demanding people to work hard; he's like you, he works hard himself, right?
BRENDAN PAUL: Yes.
MR. STEEL: And when that album was released, do you remember the name of it, by any chance?
BRENDAN PAUL: The Love Album: Off the Grid.
MR. STEEL: And it got tremendous receipt by the community, right?
BRENDAN PAUL: It did.
MR. STEEL: That you were getting your lessons, your teachings too, you got a lot out of this, right?
BRENDAN PAUL: I did.
MR. STEEL: The drugs that you saw Sean take at times --
BRENDAN PAUL: Yes.
MR. STEEL: -- you said a couple times you noticed he was under the influence, you watched him take drugs and then observed him thereafter?
BRENDAN PAUL: Yes.
MR. STEEL: And when I say drugs, you call them, quote, hard drugs, right?
BRENDAN PAUL: Yes.
MR. STEEL: And is it true that from your observation, Sean became even more focused on what he was doing under the influence of those drugs?
BRENDAN PAUL: I mean yeah, he got extremely creative.
MR. STEEL: And it was even better than -- from your observation, than when he wasn't on those hard drugs, right?
BRENDAN PAUL: I think it was different.
MR. STEEL: And he would work for hours and hours, notebooks all over and come up with ideas that was just an explosion, and you witnessed that, right?
BRENDAN PAUL: Correct.
MR. STEEL: And he was happy; he didn't hurt anybody, right?
MR. STEEL: As of today, Mr. Paul, looking back, would you think that -- everything you've gone through, as you sit here today, would you think that you are indebted to Sean Combs for the experiences that he has opened up to you?
BRENDAN PAUL: I guess what do you mean by indebted?
MR. STEEL: Was it a good -- did you learn lot with him?
BRENDAN PAUL: I did.
MR. STEEL: Good experiences?
BRENDAN PAUL: I would say for the most part.
MR. STEEL: And you have no ax to grind against Mr. Combs, do you?
MS. SLAVIK: Objection.
THE COURT: That's sustained.
BY MR. STEEL:
MR. STEEL: You had mentioned with the prosecutor that you received immunity, the honorable attorney Bieber got you immunity. Remember those questionings?
BRENDAN PAUL: Yes.
MR. STEEL: And that forces you or compels you to tell the truth, right; that allows you to tell the truth? Right?
BRENDAN PAUL: It does.
MR. STEEL: But even without immunity, you were going to tell the truth, right?
MS. SLAVIK: Objection.
BRENDAN PAUL: Of course.
THE COURT: Overruled. A. Of course.
MR. STEEL: Your Honor, may I just have one moment to look over notes?
THE COURT: You may.
MR. STEEL: Thank you, your Honor. Thank you so much, and good luck to you.
BRENDAN PAUL: Thank you.
THE COURT: Any redirect?
MS. SLAVIK: Yes, your Honor, but before we do that, could we have a brief sidebar?
THE COURT: You may.
(Continued on next page)
(At sidebar)
MS. COMEY: Your Honor, are we allowed to have three now? Because if so --
THE COURT: I was going to mention it, but -- We don't need three people. We said two. So who wants to retreat?
MR. AGNIFILO: Can I just hear what it is and then we'll --
THE COURT: No. Let's just have someone retreat. Stick to the rules. So who's going to retreat?
MR. AGNIFILO: All right.
MS. SHAPIRO: Make sure you object.
MS. SLAVIK: Your Honor, I believe there was a line of cross from Mr. Steel that opened the door to an issue that I didn't bring up on direct. On cross-examination, Mr. Steel asked about whether the witness understood that anything criminal was taking place in the hotel rooms. I did not elicit on direct examination what, if any, understanding Mr. Paul had as to what the cash that he brought Mr. Combs to these wild king nights was used for, because my understanding is that he would say, well, I didn't know for sure, but we thought that it was used for escorts. I understand that that's speculative, and that's why I didn't bring it up on cross-examination, but I believe that Mr. Steel's line of cross, which also called for speculation as to whether anything criminal was taking place in those hotel rooms, has opened the door to my questioning.
THE COURT: Well, it may, in fact, have opened the door, but that doesn't -- he's still not allowed to speculate. So how do you get around that issue? I think that's fair. It's what you're saying, but given the questioning that if you wanted to probe into what his understanding was, then that would be fair game. In fact, I don't know that Mr. Steel would object to that. Would you?
MR. STEEL: I would just object -- we raised the issue before and didn't come to your Honor before because we resolved it. But it's speculation. I didn't ask him to speculate. I asked did you know anything criminal, did you believe anything criminal, from what you were doing. I wasn't going to ask him to speculate.
MS. SLAVIK: Your Honor, it clearly calls for speculation, and I think that we're entitled to ask Mr. Paul the questions that I just mentioned to impeach that testimony. Alternatively, we could strike the answer to the question that Mr. Steel asked, because it did call for speculation. I think it either opens the door to our question, or it has to be struck from the record.
THE COURT: All right. I understand. Let me take a look at the transcript.
MR. STEEL: Step back?
THE COURT: Yes.
(Continued on next page)
(In open court)
THE COURT: Members of the jury, just wait one second. We're just checking something, and we'll be right back with you. Ms. Slavik, on redirect examination, you can ask what the witness's understanding was as to the issue that we addressed. However, if he doesn't have a basis for personal knowledge, then there would be an objection, I take it, and so we'll see what knowledge the witness has.
MR. STEEL: Your Honor, could we approach again or -- just for a moment?
THE COURT: Yes, you may.
(Continued on next page)
(At sidebar)
MR. STEEL: Thank you.
THE COURT: The question that was asked was you never thought that there was anything criminal involved in the king nights, right?
MR. STEEL: Maybe.
THE COURT: It is what you asked.
MR. STEEL: Whatever was said.
THE COURT: May not gotten every letter or every word, but that's what you asked. So why wouldn't Ms. Slavik be able to ask a parallel question? You didn't establish foundation for asking what his basis was for having one view one way or the other. You asked the question. He answered it. And so why wouldn't Ms. Slavik be able to ask essentially the same question?
MR. STEEL: Because I think we know the answer. And the answer's going to be I just assumed, I just --
THE COURT: Then she can ask without assuming.
MR. STEEL: It's a dead end to say that because I raised the issue, the government went back to the witness, gave us some notes and said I'm just assuming.
THE COURT: I think you're talking about one form of the question. However, Ms. Slavik, in response to what you asked, would be able to, in fact, ask the witness about his lack of understanding as to, for instance, the purpose for which cash was to be used at the king nights, right, establishing that he didn't know what --
MR. STEEL: If he didn't know, that's fine.
THE COURT: So there are some questions that you can ask in response to the question that Mr. Steel asked to establish that he would have a lack of knowledge as to certain things that in other testimony and evidence the government has argued shows a criminal, you know, basis, whether it's for escorts -- do you understand what I'm saying?
MS. SLAVIK: No. I'm sorry.
THE COURT: I'm saying that to the extent that your understanding is that the witness will say that he doesn't know what the money was for, right, that part of it, Mr. Steel doesn't object to, because there would be no objection to that. So you would, I think, fairly be able to say so you don't know one way or the other what the money was used for, whether its purposes were legitimate or whether its purposes were criminal. And I take it there would be no objection to that question.
MR. STEEL: That question I would not have an objection to.
MS. SLAVIK: Your Honor --
THE COURT: And so I'm not sure what the difference is.
MS. SLAVIK: -- I just don't think that that necessarily covers it, and I think that the colloquy that we're having right now illustrates that that line of cross-examination was improper from Mr. Steel, because as you never thought anything criminal was going on at a wild king night -- first of all, it calls for speculation. Secondly, this is a lay witness who can't opine on whether something is criminal or not. That's not an appropriate question to ask.
THE COURT: I didn't understand him as opining on whether it was criminal. It's just whether he believed that he was --
MR. STEEL: He's not.
THE COURT: -- involved in something that was criminal.
MS. SLAVIK: Your Honor, I think it's an improper line of questioning, and I think that because Mr. Steel asked him to speculate as to whether anything criminal was taking place, I think that we're entitled to ask him to speculate as to what he thought was going on at these hotel nights.
THE COURT: I'm not going to go down that route. However, I'll consider what happens in redirect, and if there's any testimony that should be stricken, then I'll make that determination. But for present purposes, I think there's no objection to establishing his lack of knowledge. So you can establish his lack of knowledge as to the purposes, whether legitimate or criminal, or anything that was happening. And he if he says I just don't know one way or the other, then that's, I think, responsive to the concern raised on the cross-examination. So let's take it from there, and then we'll address it after we hear the testimony.
(Continued on next page)
(In open court)
THE COURT: Ms. Slavik, you may proceed.
REDIRECT EXAMINATION BY MS. SLAVIK:
MS. SLAVIK: Mr. Paul, do you remember Mr. Steel asking you on cross-examination whether you thought that anything criminal was taking place in hotel rooms during wild king nights?
BRENDAN PAUL: Yes.
MS. SLAVIK: Did you know what was taking place during wild king nights?
BRENDAN PAUL: There was sex happening, maybe partying.
MS. SLAVIK: Were you there?
BRENDAN PAUL: I was not.
MS. SLAVIK: So do you have any reason to believe that you know whether what was going on that the wild king nights were legitimate or illegitimate?
MS. SLAVIK: And Mr. Steel asked you whether you believed that anything was, anything illegal was happening in those hotel rooms, right?
BRENDAN PAUL: Correct.
MS. SLAVIK: What did you believe the money that you provided Mr. Combs with was being used for?
MR. STEEL: Objection.
THE COURT: That's sustained. Lay some foundation to ask that question.
BY MS. SLAVIK:
MS. SLAVIK: Mr. Paul, you testified about supplying Mr. Combs with money before wild king nights, right?
BRENDAN PAUL: I did.
MS. SLAVIK: And just remind the jury of how much that was.
BRENDAN PAUL: $5,000.
MS. SLAVIK: And you set up supplies before wild king night --
BRENDAN PAUL: Yes.
MR. STEEL: Objection.
BY MS. SLAVIK:
MS. SLAVIK: And you obtained supplies for Mr. Combs during wild king nights when he needed them during wild king nights, is that right?
MR. STEEL: Objection.
THE COURT: That's overruled.
BRENDAN PAUL: Can you repeat that?
MS. SLAVIK: Yes. When Mr. Combs asked you for items during wild king nights, you provided those?
MS. SLAVIK: When you asked -- or excuse me, did Mr. Combs ask you for items during wild king nights?
BRENDAN PAUL: Once.
MS. SLAVIK: And then he didn't respond when you got back to him?
BRENDAN PAUL: Correct.
MR. STEEL: Objection, your Honor.
THE COURT: Overruled. You've got to get closer to the microphone. We can't hear you.
BY MS. SLAVIK:
MS. SLAVIK: So you got things for Mr. Combs before wild king nights --
MR. STEEL: Objection.
THE COURT: Leading or --
MR. STEEL: Yes.
THE COURT: OK. Can we rephrase some of these questions, and then you can ask them.
MS. SLAVIK: Yes, your Honor.
MS. SLAVIK: Mr. Paul, what did you supply hotel rooms with before wild king nights?
MR. STEEL: Objection.
THE COURT: Overruled.
BRENDAN PAUL: Liquor, baby oil, Astroglide, lights, candles, incense, toiletries.
MS. SLAVIK: And if Mr. Combs needed things during wild king nights, who did he reach out to?
BRENDAN PAUL: Assistants.
MS. SLAVIK: And what would assistants do when Mr. Combs asked for things during wild king nights?
BRENDAN PAUL: Tell him where it was.
MS. SLAVIK: And after wild king nights, what was your responsibility?
MR. STEEL: Objection, your Honor.
THE COURT: That's overruled.
BRENDAN PAUL: To clean up the hotels.
MS. SLAVIK: And you said that when you cleaned up hotels, you left cash tips for hotel cleaning staff?
MR. STEEL: I'm going to object for two bases, your Honor.
THE COURT: Excuse me?
MR. STEEL: Basis for objection.
THE COURT: Can you just move that microphone closer to you.
MR. STEEL: Two bases for objection, your Honor.
THE COURT: Two bases? Well, which one -- I know one of them. What's the other one?
MR. STEEL: Leading. Asked and answered.
THE COURT: OK. That's overruled. Ms. Slavik.
BY MS. SLAVIK:
MS. SLAVIK: Do you need me to remind you of what the question was?
BRENDAN PAUL: Yes.
MS. SLAVIK: When you cleaned up hotel rooms, you left cash tips for hotel workers?
BRENDAN PAUL: I did.
MS. SLAVIK: And did Mr. Combs supply you with that cash?
MS. SLAVIK: That was cash that came from your own pocket, is that right?
BRENDAN PAUL: Correct.
MR. STEEL: Objection.
THE COURT: Overruled.
BY MS. SLAVIK:
MS. SLAVIK: So, and you also testified that you provided Mr. Combs with cash before wild king nights?
BRENDAN PAUL: Once.
MS. SLAVIK: And what was the amount of that cash?
MR. STEEL: Objection.
THE COURT: Overruled.
BRENDAN PAUL: $5,000.
MS. SLAVIK: So, Mr. Paul, if assistants were available to bring Mr. Combs whatever he needed during wild king nights, what was your understanding of why he needed $5,000 in advance of the wild king night?
MR. STEEL: Objection.
THE COURT: That's sustained.
BY MS. SLAVIK:
MS. SLAVIK: Mr. Paul, did you have any understanding -- excuse me. Strike that. Mr. Paul, you provided Mr. Combs with $5,000 in advance of a wild king night?
MR. STEEL: Objection.
THE COURT: That's overruled. Last time.
BRENDAN PAUL: Yes.
MS. SLAVIK: Did you provide Mr. Combs with similar amounts of cash in any other contexts?
BRENDAN PAUL: Not that I remember.
MS. SLAVIK: You were asked by Mr. Steel about working for a criminal. Do you remember that?
BRENDAN PAUL: Yes.
MS. SLAVIK: How many times did you buy drugs for Mr. Combs?
BRENDAN PAUL: Less than ten, more than five.
MS. SLAVIK: And did other assistants buy drugs for Mr. Combs?
BRENDAN PAUL: Yes.
MS. SLAVIK: How often?
BRENDAN PAUL: I don't know.
MS. SLAVIK: You were also asked on cross-examination about whether you viewed the opportunity to work for Mr. Combs as an unbelievable opportunity. Do you remember that?
BRENDAN PAUL: I do.
MS. SLAVIK: And you also were asked about whether you thought it was an amazing opportunity for growth. Do you remember that?
BRENDAN PAUL: I do.
MS. SLAVIK: Can you remind the jury how your employment with Mr. Combs ended?
BRENDAN PAUL: I was arrested.
MS. SLAVIK: Sitting here today, Mr. Paul, how do you feel about Mr. Combs?
BRENDAN PAUL: It's complicated.
MS. SLAVIK: Nothing further, your Honor.
THE COURT: All right. Thank you, Ms. Slavik. Mr. Steel, anything further?
MR. STEEL: Thank you. No.
THE COURT: All right. Thank you very much, Mr. Paul.
(Witness excused)
THE COURT: The government may call its next witness.
MS. COMEY: Your Honor, I believe that we have some exhibits that we wanted to read into the record first, if that's all right. I'll defer to Ms. Smyser.
MS. SMYSER: Your Honor, the government next will offer exhibits that are listed in Government Exhibit 1511, which is a demonstrative. And Ms. Foster, could you please put that up on the screen. I will hand a copy up to the court reporters, but this demonstrative, Government Exhibit 1511, contains exhibits, some of which are designated as sealed pursuant to a court pseudonym order, and I would ask that all of these be admitted per the terms in Government Exhibit 1511.
THE COURT: Any objection, Mr. Driscoll?
MR. DRISCOLL: I'm just waiting to see it on the screen, your Honor.
MS. GERAGOS: I don't believe we have any objection to these, your Honor.
THE COURT: Did you say hopefully?
MS. GERAGOS: No. We do not have any objection to these.
THE COURT: All right. The exhibits referenced in Government Exhibit 1511 will be admitted with the sealed items being admitted under seal.
(Government Exhibits A-134; A-134-A; A-134-B; A-134-C; A-137; A-137-A; A-137-B; A-137-C; A-415; A-416-A; A-416-B; A-416-C; A-430-E; A-430-E1; A-430-E2; A-432; A-515-A; A-515-A1; A-515-A2; A-515-A3; A-516-A; A-551; A-926; C-271-A, sealed; C-271-A-R; C-271-A1, sealed; C-271-A2, sealed; C-271-A3, sealed; C-271-A4, sealed; C-271-A5, sealed; C-271-A6, sealed; C-271-A7, sealed; C-271-A8, sealed; C-271-A9, sealed; C-271-A10, sealed; C-626-5, sealed; C-626-5-R; C-626-7 and H-110 received in evidence)
MS. SMYSER: Thank you, your Honor. Ms. Foster, you can take that down. And could you please pull up what is in evidence as Government Exhibit C641. And turn to page 4, please. I'm going to start reading with the second text message on this page, which is from Mr. Combs: "After studio I'm going off the grid until 12 p.m. Be at the house at one for the 3 p.m. You clear now? And spoke to Ben and team. They're cool. Love. "I'm done. Not speaking anymore. "Do you have one person's I can count on because I can't do it. The rest can.something else." Kristina Khorram: "OK," and liked after studio I'm going after grid until 12 p.m. Can we go to the next page. Kristina Khorram: "For off the grid moment, I prefer you use Joey. He is most trustworthy, as you know. Or we can also ask Frank to come in, if I can get him to answer his phone. I just had a talk with all of them as well. Today seems stress-driven. Let's turn it around and breathe. Try and have fun at the game, and then you won't have your release moment tonight after studio. We control our own energy. Stay light."
SEAN COMBS: "I want Frank. I don't want to speak to anyone. I'm done. And if you can't give 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. The presentation is not done, album not done, video not done, new video not done, roots not done. Assistants out of wack and on and on. June can't remember a T-shirt. ECT, ECT, ECT. Wack."
KRISTINA KHORRAM: "I'll call Frank again now."
SEAN COMBS: "Whatever. What's the plan?"
KRISTINA KHORRAM: "Sending someone to Frank's apartment because he's not answering anyone's calls. I will track him down, and he can help you. If you need any setup or anything, just let me know and I can have the guys help but stay out of your sight and do before you even get anywhere. June is making sure he always has three to four backups of all basic things you ever ask for. He will be making sure he has all those by tomorrow. Assistants are on track to make sure they stay on point and not drop the ball on any little thing. They will be staying clear away from you tonight unless you change your mind."
SEAN COMBS: "OK. So have Joey stay. Don't worry about Frank." And these were sent on April 25 of 2023. Could you take that down, please, and pull up Government Exhibit A430E, and let's turn to the first page. Can you zoom in on these texts, please. The first one is sent on May 15, 2023, from Mr. Combs to Ms. Khorram: "Who can go set room?"
KRISTINA KHORRAM: I'll get it handled. Can they go now?" Can we turn to the next page, please.
SEAN COMBS: "Who is it?"
KRISTINA KHORRAM: John or Brendan. They can both help to make it faster. Normally I would send Frank or Joey, but my hands are tied. Frank called out from work again today, and it's Joey's birthday today so he's off." Then there is an audio message, so could we please play Government Exhibit A430E1.
(Media played)
MS. SMYSER: Please go to the next page. Mr. Khorram responds: I don't but right now he's at the house. So having him help gather stuff if you are moving fast. Then John can go put in the room. If possible. How fast are you moving?" Mr. Combs sends an audio message, so could you please play Government Exhibit A430E2.
(Media played)
MS. SMYSER: Ms. Khorram responds: "OK. John will go to hotel."
SEAN COMBS: "I need John to go to her now, please."
KRISTINA KHORRAM: "OK. He is leaving now."
SEAN COMBS: "Please now. He should have been left." You can take that down.
MS. JOHNSON: And your Honor, we have another few message threads to enter into the record, and if it's OK with the Court, we would propose a break after these threads.
THE COURT: All right. Very good.
MS. JOHNSON: Ms. Foster, could you please pull up Government Exhibit 1402, page 22, line 67. And can you please highlight line 67, the date of March 12, 2017, to March 14, 2017, in New York City. Can you please pull up Government Exhibit B413. B413, not 314. Thank you. Thank you so much. Can you please turn to page 2, and starting at the second thread, which is from Mr. Combs, sent on March 13, 2017, at 2:15 a.m. UTC from Mr. Combs to Casandra Ventura: "Do you want me to hit Garren for big man? LOL." Go to the next page, please.
CASANDRA VENTURA: "You can if you want. You only sent one pic." Next message, from Mr. Combs: "RM 4901." From Mr. Combs: "Call me." That message is sent at 3/13 -- March 13, 2017, at 4:37 a.m. The next message, from Ms. Ventura to Mr. Combs, is sent March 13, 2017, at 1:59 p.m. UTC. It reads: "WTF. Really?" Next page, please. "I think it will always be black and white. You threw out all my shit. I can dig it." Can you skip the next two pages, please. Picking up at 2:03 p.m. UTC from Ms. Ventura: Nah, I didn't. You bust my head in. Beat." Asterisk, asterisk. From Mr. Combs: "You're crazy." From Ms. Ventura: "OK." From Mr. Combs: "Let's stop talking. You dead wrong. Flipping on me for what?"
CASANDRA VENTURA: "Ain't flipping. I can come back so we can talk, but you know I fight."
SEAN COMBS: "Wat? Fight who?" Exclamation point, question mark. From Ms. Ventura: "I'm just at the door. Just LMK what I'm supposed to do." From Mr. Combs: "So we're clear this time. We're taking a.Break? This is really how you wanna leave this? You sure." From Ms. Ventura: "No. I just don't want to be beat down for being defiant or.ever. You treat me and make me feel like I don't matter." From Mr. Combs: "You started all of this. You really think you can have me jerk my dick for ten hours and not come. Your nuts. One minute you down asking about shit. Then the next minute you acting like you doing something you don't want to. Make up your minds. I'm trying to figure out how I get this nut out my dick." From Ms. Ventura: "I guess I'm not down with abuse. It doesn't make sense to me." From Mr. Combs: "I got you. So all this is happening without you tripping." From Mr. Combs: "I damn sure don't MK sense to me." From Ms. Ventura: "You hit me in the head two good times. That didn't make me feel good. I know I'm not crazy." From Mr. Combs: "I'm hurt. I'm tired of this fuck shit. You have disrespected so much in last 12 months. I have no respect for you to play me in friont a dick. Wow. You think you talking to on of your little fuck boys. They can have you with that shit. I'm not taking no more."
CASANDRA VENTURA: "OK." And if you can skip ahead two pages, to the bottom, from Mr. Combs, on March 13 at 2:46 p.m.: "Did you ever get any female escorts num's." You can take that down now, and please pull up Government Exhibit B414. Can you go to page 2, please. And from Ms. Ventura to Mr. Combs on March 18, 2017, at 5:53 p.m. UTC: "At this point you can tell me and I'm listening...you at a point in your life where you want to party and have a good time and I'm at a point where I have to focus or I'll never become anything. I'm not saying I can't ever party. I had so much fun in Miami, but then I realized that doing that opened the door to that being my sole purpose in seeing you. I know if I said no to it in New York, it would have been a problem. Those were my last nights with you. You only see me one way. You treat me like a hooker, to be honest. You always want to call one so bad, and you have one. This hooker has been here for ten years."
SEAN COMBS: "Wow." We can take that down and can you please pull up Government Exhibit 421A, which is a photograph. I'm sorry. That's my fault. B421A. You can take that down now, Ms. Foster, and can you please pull up Government Exhibit B421. And can you start at page 4, please. From a communication on May 2, 2017, at 3:18 p.m. UTC from Ms. Ventura to Mr. Combs: "That was you. You hurt me so bad. I'm so fucked up. And so heartbroken. I never intended to show you did respect if that's what you felt but some of your values are loose. All I wanted was to have a good time, and you took all of your anger out on me per usual. I know I don't treat you badly. I might say some bullshit here and there, but I'm not a bad persons." Next page, please: "Person. I just appreciate and love you. I can't sleep. I've been crying since I got here. I don't understand what you expect of me sometimes. I smile. I'm happy. I love you.
I give you love, and as soon as I turn my head for a second and you get fucked up, you drag me down the hall by my hair. I'm 30 years old. This isn't play play anymore. I felt like I was dead last night and it wasn't happening to me bc seeing my light was so beautiful." Focusing on the bottom message, please: "I was serious about Rita coming over because that's what you wanted and I had no attitude despite what you felt. I was scared of your rage. I talk out of line sometimes and I do apologize, but that doesn't mean J don't love you. And the love you have for me shouldn't equate to what you 'do' for me. I'm so in love with you, and you can't even see it. And my heart is shattered that you acted the way you did. Physicalities, take it somewhere else. Boris had to tackle you, Puff. That's not love. That's possession. I have been getting cuts." From Mr. Combs to Ms. Ventura on May 7, 2017, at 3:26 p.m. UTC: "Thant makes two of us.
But I'm not gonna let someone shit on me when all I've done was be nice. You broke my heart this time. You were negative all night. And then when owner said we can't have people over, you flip. You don't treat me like the king. Any other woman in the world would have been so happy, but not you. You're wack for not keeping it real. I'm not gonna go back and forth when I and everyone knows you was acting like a bitch. I can't take it anymore. I want after a night like that for my woman to be so happy. If you a different type of unappreciative chick. You did and you fucked up." Can you take that down, please, and pull up Government Exhibit B424, please. This is from Mr. Combs to Ms. Ventura on May 2 at 3:38 p.m. UTC: "You need to ask someone how you were acting. If I would have did all of that for any girl in the world, she would have been so happy and so nice to me, but no, not you. Always talking back and all fucking night. I wish I didn't waste my time, money and energy.
I'm heartbroken and going back to bed. You should get some rest also. Maybe you'll see clearer." From Mr. Ventura to Mr. Combs: "Talk to your people. They'll tell you. Or they won't because all they do is suck you. K.K. won't. Talk to her. And I didn't ask to go to met, so don't put that on me. I asked to have my record come out after a million years." And can you take that down and pull up Government Exhibit 1411, page 5, line 74. Which is a text from Ms. Ventura to Ms. Khorram. Sorry. Line 74. Thank you. A text from Ms. Ventura to Ms. Khorram, reading: "I'm sure" -- on May 2, 2017, at 3:54 p.m. UTC: "I'm sure you don't want to get involved, but he said I was an asshole, which I owned up, but no one deserves being dragged by their hair. I locked the door for my safety."
MS. GERAGOS: We have 106 issues, your Honor. I would like to read other parts of those messages right now, please.
THE COURT: All right. Any objection?
MS. JOHNSON: Of the ones I displayed?
MS. GERAGOS: Yes.
THE COURT: All right. Ms. Geragos, you may proceed.
MS. GERAGOS: Thank you. Can we please bring up Government Exhibit B-414, please. Could we go to page 2.
THE COURT: Ms. Johnson, you're standing up. Before you start reading, is there an issue?
MS. JOHNSON: Yes. Can I confer with Ms. Geragos briefly?
THE COURT: Yes, you may.
(Continued on next page)
THE COURT: Ms. Geragos, are you prepared to proceed?
MS. GERAGOS: I'm sorry. I think we need a break, your Honor, to discuss some things.
THE COURT: We're going to take a short break. We're going to be ending early today around 1:00 p.m. So we'll take a 20-minute break and come back at about 1:30.
(Jury not present)
THE COURT: Ms. Geragos, is there anything to raise now or do you need time to work things out with Ms. Johnson?
MS. GERAGOS: I think I could put this on the record. There was a 106 objection that we had that we met and conferred about, from my records. We expanded this Exhibit, which is B-414-H. We had requested, and the government had agreed, to include the later message where Ms. Ventura writes "I love our FO's when we both want it." Our revised version has that. It was not read into the record. We need to read that into the record right after this break.
MS. JOHNSON: I need a moment to look back through all the 106 objections. The version I have does not have that text, but I need a moment to look at that. In addition, 106 is to the admissibility of evidence. If Ms. Geragos wants to read this in her case in chief, that's fine, but it does not need to be read into the record on our case.
MS. GERAGOS: Your Honor, they chose to read this in after their summary witness got off the stand. 106 is not just when -- it's not as a matter of when the government feels that we can put in a message. We are asking under 106 for the entirety of a message to have it be understood properly, which is what 106 requires, to have the jury see the next page of this, which is Ms. Ventura saying, "I love our FO's when we both want it." To have to wait till our case in chief to read the next page would be highly prejudicial and not in keeping with 106.
THE COURT: Let me ask, Ms. Johnson, and make sure I understand the issue. This is B-414 in evidence?
MS. GERAGOS: Yes. This is what we have -- what the defense has was revised after our conferrals with the government because we had requested these last two pages. They are important to understanding the entire communication.
THE COURT: I understand that. So this is all in evidence. And for some reason everyone is reading stuff that's already in evidence to the jury, okay? And there was no objection from the defense as to Ms. Smyser and Ms. Johnson doing that. You're saying you'd like to read it, but what's the basis for that? Because I think Ms. Johnson is saying this is all in evidence, and so Rule 106 just relates to the introduction of statements into evidence. And so what she's saying is, in terms of the reading of things, like, you can read whatever you want that's in evidence on your case, but on what basis do you get to read it on the government's case based on what the government put forth?
MS. GERAGOS: The government put on a summary witness, had this evidence in their chart for the summary witness. I would have read it on cross-examination if I knew they were going to do this after. Once they did it after, I didn't object because I thought they would read the entire exhibit because that leaves a prejudicial impressions for the jury to not have the communications two messages after that says "I love our FO's" and to do it after the witness is off the stand and say that then I can't put in these messages because I have to wait until the case in chief is highly prejudicial to the defendant.
THE COURT: What's the basis for doing what you want to do? If you've got a basis for doing what you want to do, I'm all ears.
MS. GERAGOS: It's misleading, your Honor. It is misleading. We didn't object to them reading things in evidence because we didn't understand that they were going to only read portions. And so that's the basis, it leaves a misleading effect on the jury.
THE COURT: Like literally what you want to do is read these four text messages?
MS. GERAGOS: These all I'm asking to do. I'm not going to read the defense exhibits that we put in after these messages. But there was a time and place for Ms. Johnson to do this. It was with Special Agent Penland. I went through the messages in detail, in detail, and they did not do that. And so now they're doing that at this point, but then I should be able to read what I had asked for at 106 -- and let me just back up, your Honor. We went through this exhaustive process with Ms. Ventura when she went on her direct to introduce a lot of messages for the sake of efficiency, for the Court, the parties, and the jury, so that she wouldn't have to be on the stand for longer than she had to. So this was introduced at that time, and I wasn't expecting that because it was introduced at that time, at a later point I wouldn't be able to read the revised messages because at the time of introduction they decided not to ask Ms. Ventura about this. So it's prejudicial and misleading.
THE COURT: Hold on. Is there anything else other than these four --
MS. GERAGOS: No, that's it.
THE COURT: Here is how I would resolve that. I think as a technical matter, Ms. Johnson, you're correct 106 relates to the introduction of evidence, meaning the admission of certain evidence. However, looking at the Advisory Committee Notes, the way in which this is supposed to work, or what it's supposed to apply to, is when there's actually a witness on the stand or evidence being presented to the jury that would be misleading and create a misimpression if certain other completing statements were not also shared with the jury at the exact same time. That's the reason for the rule. Those are the examples that are given in the rule. So while the parties through agreement have introduced these exhibits into evidence, when the government is reading certain exhibits into evidence, I think it's fair at that time to have the completing statements also read because for the same reason as the rule contemplates, that failure to do so would leave a misimpression in the jury's mind potentially. So since there's no objection, this is already all in evidence, and we're talking about four messages that are coming right after the messages the government read to the jury. I think it's fair for the defense to read those without any further comment with what they have to do with anything.
MS. JOHNSON: Your Honor, I would ask two things of the Court. I certainly did not intend to be misleading here. As the Court may remember, Ms. Ventura's exhibits were not a straightforward process. I thought that the exhibit that was admitted did not have the last two pages. I was not trying to be misleading to the jury. So if the Court will allow these four text messages to be read, I would like to read them because I don't want to leave them with a misimpression.
THE COURT: That's fair.
MS. JOHNSON: If that is the standard, I will say that we don't stand up on cross and ask for other portions to be read. 106 is about admissibility of a document, not about what comes in when either side presents it.
THE COURT: I didn't understand the last point you're making. You're saying that when you have a witness on the stand and you go through a message, you obviously don't go through everything, right?
MS. JOHNSON: Exactly.
THE COURT: Right, but that's because in cross-examination the defense can come back and complete anything they want. So there could be an objection raised, I suppose, given the nature of the statements and what you're actually eliciting. But the way the parties have handled it, and, Ms. Geragos, you can correct me, but the way it's been handled to date is the government asks whatever they want on direct, and on cross you then ask about the different other statements that are made. That's just how it's been handled. Here, there is no witness on the stand, and so you're reading things into the record. So if you're reading things into the record, then I'm not sure that it should be treated in any different way; meaning, we could do it with Ms. Geragos completing the statements, but, Ms. Johnson, you say you'll do it. There's no objection to that. So you can go ahead and do it. But this is an atypical circumstance because we haven't had that many circumstances where anything has been read into the record that's already in evidence in the way the government just did. It's happened a couple times without any dispute or objections from the defense. The defense has an objection in this particular instance. I think it may have more to do with just the number of documents and exhibits that overlap with each other, and that's why it happened this time. But it's easy enough to clean up so that there is no even potential prejudice.
MS. GERAGOS: That's right. And also when they have a witness on direct and skip ahead, we don't object to that either because that's what direct and cross are for, they can go back to any messages that are not read out loud. This is just in this particular circumstance that there is no misleading impression left with the jury.
THE COURT: Understood. Anything to address before we take a now 12-minute break?
MS. GERAGOS: Not from us, your Honor.
THE COURT: We'll come back in 12 minutes.
(Recess)
(Continued on next page)
(Jury present)
THE COURT: Please be seated. Anything from the government before it calls its next witness?
MS. JOHNSON: Yes, your Honor. We'd like to finish reading one of the chats into the record.
THE COURT: All right.
MS. JOHNSON: Ms. Becker, can you please pull up Government Exhibit B-414? And, with apologies, I read the long version last time. Can you go to page 2 please, Ms. Becker. Can you zoom in on the top? Starting from the beginning, Ms. Ventura to Mr. Combs: On March 18, 2017 at 5:35 p.m. UTC. At this point you've been telling me and I'm listening. You're at a point in your life where you want to party and have a good time, and I'm at a point where I have to focus or I'll never become anything. I'm not saying I can't ever party. I had so much fun in Miami, but then I realized doing that opened the door to that being my sole purpose in seeing you. I knew if I said no to it in New York, it would have been a problem. Those were my last nights with you. You only see me one way. You treat me like a hooker, to be honest. You always want to call one so bad, and you have one. This hooker has been here for ten years.
SEAN COMBS: Wow. Going to the next page.
MS. JOHNSON: Please don't play victim. If you can, go to our last messages. That's all you wanted, and that's why I was upset. I love our FO's -- go to the last page -- when we both want it.
THE COURT: With that, the government may call its next witness.
MS. COMEY: Your Honor, the government calls Joseph Cerciello. JOSEPH CERCIELLO, called as a witness by the Government, having been duly sworn, testified as follows: DEPUTY CLERK: Please give the Court your first and last name, and spell your first and last name.
BRENDAN PAUL: Joseph Cerciello. J-O-S-E-P-H; C-E-R-C-E-I-L-L-O.
THE COURT: Ms. Comey, you may proceed.
MS. COMEY: Thank you, your Honor.