MS. COMEY: Thank you, your Honor. DIRECT EXAMINATION CONTINUED
BY MS. COMEY:
MS. COMEY: Good morning, Agent.
JOSEPH CERCIELLO: Good morning.
MS. COMEY: I'd like to start by pulling up just for the witness and the parties, Ms. Becker, Government Exhibit J-141-A, which is the redacted version of J-141.
And as Ms. Becker's pulling this up, your Honor, I'm going to offer J-141-A, and I'm going to withdraw any prior versions of J-141 or J-141-A, pursuant to the parties' discussions with your Honor on Friday.
THE COURT: All right. So those prior versions will be withdrawn and the renewed J-141-A will be admitted.
MS. COMEY: Thank you, your Honor.
(Government Exhibit J-141-A received in evidence)
MS. COMEY: I see we're having technical difficulties pulling it up, but if Ms. Geragos is all right with it, I'll move on.
MS. GERAGOS: Yes. No objection to the renewed J-141-A.
MS. COMEY: Thank you, Ms. Geragos.
All right. Ms. Becker, I'll ask you to please pull up what's in evidence as Government Exhibit 1406 and go to page 7, row 17, please. And we can publish that.
And your Honor, I'm going to be pulling up some exhibits that are sealed pursuant to the pseudonym order, so I'm going to ask that the public screens please be turned off if they're not already.
THE COURT: All right. I'll ask the deputy to confirm when that is done.
MS. COMEY: But we can go ahead and look at this while we're talking.
Can we go to page 7, please, Ms. Becker, and I want to take a look at row 17.
MS. COMEY: Agent, what's the date of this row?
JOSEPH CERCIELLO: 9/24, 2022, to 9/25, 2022.
MS. COMEY: And what are the two locations listed in the location column?
JOSEPH CERCIELLO: The first location is 200 South Mapleton, Los Angeles, California. The second location is Las Vegas, Nevada.
MS. COMEY: And what are the names in this row?
JOSEPH CERCIELLO: Jane, Combs and Paul.
MS. COMEY: And what are the flight records?
JOSEPH CERCIELLO: Flight records are for Jane 924 Silver Air flight from Van Nuys to Las Vegas -- sorry if I pronounced that wrong -- and 924 Silver Air flight from Las Vegas to Van Nuys.
MS. COMEY: And how about the financials column?
JOSEPH CERCIELLO: Financial transactions for Paul on 9/26 in the amount of $2,500 cash deposit into Arthur Fitness LLC account.
MS. COMEY: I'd like to take a look at some exhibits relating to this date. Let's start with Government Exhibit G-102 and pull up pages 31 and 32 side by side, please.
COURT CLERK: Confirming that the overflow for the evidence is off.
MS. COMEY: Thank you so much, Mr. Deputy.
MS. COMEY: Zooming in on the left page, looking at the second text on the left, what's the date of that?
JOSEPH CERCIELLO: 9/24, 2022.
MS. COMEY: So is that the first date of the date range we were looking at in row 17?
JOSEPH CERCIELLO: Yes.
MS. COMEY: And are these text messages between Mr. Combs and Paul Arthur?
JOSEPH CERCIELLO: Yes.
MS. COMEY: All right. I'd just like to read through these five messages.
MS. COMEY: Would you please read Mr. Combs in the blue, and I'll read Mr. Arthur in the green.
JOSEPH CERCIELLO: "How far?"
MS. COMEY: "Ten mins."
JOSEPH CERCIELLO: "OK."
MS. COMEY: And then there's an address and says, "correct?"
Can we please go to pages 33 and 34.
MS. COMEY: You can keep reading, Agent.
JOSEPH CERCIELLO: "No. 200 S. Mapleton."
MS. COMEY: "On my way. 15 mins away."
JOSEPH CERCIELLO: "K."
MS. COMEY: We can take that down. Thank you.
And now I'd like to look at Government Exhibit C-271-A-R, pages 1 and 2, please.
And can we zoom in on the gray box on the top left of page 1, please.
MS. COMEY: What's the date of this message exchange?
JOSEPH CERCIELLO: September 24, 2022.
MS. COMEY: Is that the same day we were just reading messages from?
JOSEPH CERCIELLO: Yes.
MS. COMEY: And who are the participants in this message exchange?
JOSEPH CERCIELLO: Participants are Puff, Kristina Khorram and an email address for Kristina Khorram.
MS. COMEY: OK. Let's look now over at page 2.
MS. COMEY: Does the first text here come from Mr. Combs?
JOSEPH CERCIELLO: Yes, it does.
MS. COMEY: And does it contain a screenshot of a text with someone named Annicka?
JOSEPH CERCIELLO: Yes.
MS. COMEY: In the screenshot, what does Annicka say in the top left?
JOSEPH CERCIELLO: "Hey, love. I have a studio session tomorrow from 3 to 5 p.m. I just remembered."
MS. COMEY: And then are the four messages in response in this screenshot?
JOSEPH CERCIELLO: "Wow. We'll -- OK. Damn. I was excited. Move the studio time. I'll pay D.it really wanted to have fun -- really wanted to have a fun night in Vegas with you. Hit me. No stress either way. I understand. Call me when you can."
MS. COMEY: And then in the next message, does Mr. Combs send Kristina Khorram an audio message?
JOSEPH CERCIELLO: It --
MS. COMEY: The next message in the exhibit, is that an audio message?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: I'd like to listen to it, and we'll need to use headphones for that. So if everyone remembers to press the silver button on the top to turn on their headphones.
Ms. Becker, do you mind running the test when you have a moment, please, to make sure everyone's headphones are working.
I see now some thumbs up.
All right. Ms. Becker, would you please go ahead and play C-271-A1.
(Media played)
MS. COMEY: Now let's look back at Government Exhibit C-271-AR. Everyone can keep their headphones on. We'll be listening to another audio message in a moment.
Can we pull up pages 3 and 4 -- or keep your headphones handy, rather. Sorry.
MS. COMEY: Does Mr. Combs then send another audio message?
JOSEPH CERCIELLO: Yes.
MS. COMEY: OK. I'd like to now please listen to it. Let's play Government Exhibit C-271-A2. I don't believe this one requires the headphones. The next one will.
(Media played)
MS. COMEY: OK. Your Honor, I think we may just need the headphones because flipping back and forth between the headphones and audio system doesn't seem to be working.
We'll do C-271-A2, please.
(Media played)
BY MS. COMEY:
MS. COMEY: Going back to the text messages, please, in C-271-AR, how does Kristina respond to these audio messages?
JOSEPH CERCIELLO: "She's going to come. She's just going to fly out and land and meet us in Vegas at 6:30 p.m. Then she will be with us all night. Better so you can focus on getting performance right when we land, since you didn't rehearse tonight."
MS. COMEY: And then how does Mr. Combs respond?
JOSEPH CERCIELLO: "OK." And then sends another audio message.
MS. COMEY: Let's listen to that audio message. And this one does require headphones, C-271-A3, please, Ms. Becker.
(Media played)
MS. COMEY: Let's go back to C-271-AR, please, and look at the remaining text messages. And they're at pages 3 and 4.
MS. COMEY: After the audio message, how does Ms. Khorram respond?
JOSEPH CERCIELLO: "Whatever you want. BTW, your nightstand has plan B in drawer so you have."
MS. COMEY: Could you please read Mr. Combs's responses in the next four messages?
JOSEPH CERCIELLO: The first message is Mr. Combs liked Kristina's first message. "Do you think the other girl really wants to come? Because if she's flaky the -- if rather know now. Fuck it. I'll bring both. LOL."
MS. COMEY: And then how does Ms. Khorram respond?
JOSEPH CERCIELLO: "She seems excited when I spoke to her on the phone."
MS. COMEY: And then does Mr. Combs send another audio message?
JOSEPH CERCIELLO: Yes.
MS. COMEY: I'd like to listen to that, please.
Ms. Becker, are we able to listen to that publicly, or do we need to use the headphones?
All right. We'll use the headphones, C-271-A4.
(Media played)
MS. COMEY: Let's go back to C-271-AR, pages 3 and 4, please.
MS. COMEY: And what does -- and in the text after that audio message we just left, does Mr. Combs indicate "Jane coming"?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Let's go to pages 5 and 6 of this document.
MS. COMEY: Could you read for us what Mr. Combs writes at the top of this page?
JOSEPH CERCIELLO: "Keep homegirl pls. Thanks."
MS. COMEY: Then does Mr. Combs then send five audio messages in a row?
JOSEPH CERCIELLO: Yes.
MS. COMEY: I'd like to listen to all of those, so Ms. Becker, if you would please play, in order, Government Exhibits C-271-A5, A6, A7, A8 and A9 back to back.
(Media played)
MS. COMEY: Was there 271-A9, please, Ms. Becker?
(Media played)
MS. COMEY: Let's pull up, please, Government Exhibit C-271-AR again, please, and go to pages 5 and 6.
MS. COMEY: What does Mr. Combs send to Ms. Khorram on the right hand of the page after sending those Voicenotes?
JOSEPH CERCIELLO: He sends a photo of jewelry.
MS. COMEY: And then does he send one more Voicenote?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Let's listen to that. That will be the last one for this exhibit, Government Exhibit C-271-A10.
(Media played)
MS. COMEY: We can set the headphones aside. Thank you so much.
Now let's please turn to Government Exhibit C-271-AR, and we can go to page 7 now, please, Ms. Becker.
Just page 7. There we go.
MS. COMEY: How does Ms. Khorram respond to the most recent messages we heard from Mr. Combs?
JOSEPH CERCIELLO: "One, working on drip. Two, Jess will work on hotel options when she's up, but you have a room at the Waldorf Vegas as a backup. Three, reminder plan B in your nightstand. Four, is Paul coming to Vegas with you too? Five, Benny the jeweler has Van Cleef. He's giving me some pieces and did all of Yung's, and it's the exact same but at cost. He can get to us this week when he gets back to NYC if you're able to wait." We'll have you a ton -- "will save you a ton." Sorry. "Please lmk on last two things. Will hold on buying until I hear from you."
MS. COMEY: We can take that down. Thank you.
I'd like to go now, please, to Government Exhibit 1406 and go to page 1.
MS. COMEY: Agent, were there explicit videos cited throughout this chart that we see on the screen?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Generally -- have you reviewed all of the videos that are cited in this chart?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Generally, what do those videos show?
JOSEPH CERCIELLO: They are sexual encounters.
MS. COMEY: Is there one female in every video?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Who is that?
JOSEPH CERCIELLO: Jane.
MS. COMEY: And is she always with one or more males?
JOSEPH CERCIELLO: Yes.
MS. COMEY: And who, if anyone, were you able to recognize across all the videos?
JOSEPH CERCIELLO: I was able to recognize an individual by the name of Kabrale and videos that I've seen Sean Combs.
MS. COMEY: And were there other men as well in the videos?
JOSEPH CERCIELLO: Yes, there were.
MS. COMEY: Are those videos in total multiple hours?
JOSEPH CERCIELLO: Yes.
MS. COMEY: And are many of the videos many minutes long, each video individually?
JOSEPH CERCIELLO: Yes.
MS. COMEY: We're not going to play all of those videos here, but we're going to walk through several examples over the next few minutes, so I'm going to ask, please, to turn off the attorney screens.
With the Court's permission, I'm going to walk over to Ms. Becker so that I can review her screen, and then I will ask that everyone have headphones available.
THE COURT: All right. That's fine.
MS. COMEY: Ms. Becker, before you pull up the videos, if you could keep up 1406, page 1, and look at row 3.
MS. COMEY: Now, looking at row 3, what's the date of this row?
JOSEPH CERCIELLO: 11/8, 2021, to 11/10, 2021.
MS. COMEY: Can you just point out for the jury how you can know which exhibits are the explicit videos cited here?
JOSEPH CERCIELLO: The explicit exhibits are marked with AX or GX.
MS. COMEY: Does GX mean government exhibit?
JOSEPH CERCIELLO: I'm sorry. Yes. They would be AX exhibits.
MS. COMEY: Are there multiples cited for this particular date?
JOSEPH CERCIELLO: Yes.
MS. COMEY: OK. I'd like to pull up the metadata for those. Let's go to Government Exhibit AX-102, pages 1 and 2, please.
MS. COMEY: Is this the metadata from multiple videos from that date range we just saw in the chart?
JOSEPH CERCIELLO: Yes.
MS. COMEY: And so are there multiple videos from this date?
JOSEPH CERCIELLO: Yes.
MS. COMEY: I want to look at a clip from one example.
Can we go to row 4 at the top of page 2, please, and look at the creation date in the bottom of the middle column, please.
MS. COMEY: What's the creation date?
JOSEPH CERCIELLO: 11/10, 2021.
MS. COMEY: I'd like to go ahead and play a clip from that, please.
Ms. Becker, would you please pull up AX-102-D and play the first two minutes and 30 seconds.
(Media played)
MS. COMEY: We can take that down. Thank you, Ms. Becker.
Let's go back to 1406, please, page 2, row 5.
MS. COMEY: What's the date of row 5, Agent?
JOSEPH CERCIELLO: Row 5 is 12/3, 2021, to 12/6, 2021.
MS. COMEY: And what explicit video or videos are cited in this row?
JOSEPH CERCIELLO: AX-103 and AX-103-A.
MS. COMEY: I'd like to look at the metadata, please.
Let's go to Government Exhibit AX-103, and I want to look at row 1.
MS. COMEY: What's the creation date at the bottom middle of the column?
JOSEPH CERCIELLO: Creation date, 12/4, 2021.
MS. COMEY: Let's please pull up Government Exhibit AX-103A, and I'd like to play from 50 seconds through the end of the video, please.
(Media played)
MS. COMEY: Let's go back to 1406, page 3, row 6, please.
MS. COMEY: Agent my question for you will be what is the date for this row, row 6?
JOSEPH CERCIELLO: Row 6, 12/17, 2021, to 12/21, 2021.
(Continued on next page)
BY MS. COMEY: (Continued)
MS. COMEY: Another multiple explicit video cited in this row?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Let's look at some metadata.
MS. COMEY: Can you pull up AX-104, Ms. Becker. You can zoom out of that, please.
Are we seeing the metadata for one of the videos cited in the row we were just looking at?
JOSEPH CERCIELLO: Yes.
MS. COMEY: I'm sorry, Ms. Becker. Could you zoom back in and highlight the creation date, please.
MS. COMEY: What's the creation date?
JOSEPH CERCIELLO: 12/18/2021.
MS. COMEY: Let's watch a clip of this. Can we please pull up be Government Exhibit AX-104-A and play just the first 45 seconds, please.
(Media played)
MS. COMEY: Now let's please pull up the metadata for other videos from this date. Let's go to Government Exhibit AX-701, page 1, please.
MS. COMEY: Agent, is this metadata for additional videos related to the same date range that we were looking at?
JOSEPH CERCIELLO: Yes.
MS. COMEY: I'd like to go to page 18, please.
MS. COMEY: Looking at the number next to video are there approximately 50 explicit videos recorded during the date range in row 6 of 1406?
JOSEPH CERCIELLO: Yes.
MS. COMEY: I want to watch clips from -- we're going to watch clips from two of those. Let's start with AX-701-65 please, and would you please play the whole video, Ms. Becker.
(Media played)
MS. COMEY: Now, let's play AX-701-79. Would you please play the first 45 seconds, and then I'll tell you the next clip to play, please.
(Media played)
MS. COMEY: Please go ahead to minute three and play until the five minute mark.
(Media played)
MS. COMEY: Skip ahead to 7 minutes and 40 seconds and play to the end please, Ms. Becker.
(Media played)
MS. COMEY: Let's go back to 1406, page 4, please, Ms. Becker. And we'll look now at row 8.
MS. COMEY: Agent, what's the date of row 8?
JOSEPH CERCIELLO: 2/8/2022 to 2/12/2022.
MS. COMEY: Are there explicit videos cited in this row?
JOSEPH CERCIELLO: There are.
MS. COMEY: Let's watch a clip from one, please. Let's go to Government Exhibit AX-702-F as in Frank: Skip ahead to the 2 minute mark and play until the 3 minute and 32nd mark, please.
Let's go now back to 1406, please, page 4, row 9.
MS. COMEY: What is the date of this row?
JOSEPH CERCIELLO: 2/14/2022 to 2/16/2022.
MS. COMEY: Are there multiple explicit videos cited in this row?
JOSEPH CERCIELLO: Yes, there are.
MS. COMEY: I'd like to look at metadata for some. Let's pull up AX-105, pages 1 and 2, please.
MS. COMEY: Is this metadata for videos related to the entry we were just looking at in 1406?
JOSEPH CERCIELLO: Yes.
MS. COMEY: I'd like to pull up a clip of one now. Let's go to Government Exhibit AX-105-C. We'll play from the beginning through the one minute mark, please.
(Media played)
MS. COMEY: Let's go metadata for more videos from this date, please. Let's go to AX-703, page 9, please.
MS. COMEY: Agent, is this metadata for more videos related to the same row of 1406?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: Are there multiple videos from that date range?
JOSEPH CERCIELLO: Yes.
MS. COMEY: We're going to watch clips from a couple let's start with AX-703-42. Play from the 2 minute mark to the 3 minute mark, please.
(Media played)
MS. COMEY: Let's go now to Government Exhibit AX-703-91. We'll play until the 1 minute and 30 second mark, please, and then pause it.
(Media played)
MS. COMEY: Let's skip ahead to the 4 minute mark and then play until the 5 minute mark, and then you can take this down, Ms. Becker.
(Media played)
MS. COMEY: Let's go back to 1406, page 6, please, row 16.
MS. COMEY: Looking at row 16, what's the date, Agent?
JOSEPH CERCIELLO: 8/30/2022 to 8/31/2022.
MS. COMEY: Does this row also have an explicit video?
JOSEPH CERCIELLO: Yes, it does.
MS. COMEY: Would you tell us the citation for that, please?
JOSEPH CERCIELLO: That would be Government Exhibit EX-166.
MS. COMEY: I'd like to look at the metadata for that. Can we pull up EX-166-M, and zoom in on the last modified date, please.
MS. COMEY: What is the last modified date?
JOSEPH CERCIELLO: Last modified date, 8/31/2022.
MS. COMEY: I'm going to play a clip of this video EX-166. Please play the first 60 seconds, and then take it down, Ms. Becker.
(Media played)
MS. COMEY: Let's go back to 1406 page 7, row 19, please.
MS. COMEY: What is the date of row 19?
JOSEPH CERCIELLO: 10/8/2022 to 10/9/2022.
MS. COMEY: Does this also have an explicit video?
JOSEPH CERCIELLO: It does.
MS. COMEY: This is the last clip we'll watch. Let's go to Government Exhibit AX-1102-A and play for the first two minutes.
(Media played)
MS. COMEY: Thank you, Ms. Becker. You can take that down, and we can turn the attorneys' screens back on and folks can set aside their headphones.
MS. COMEY: Agent, have you reviewed the remaining videos cited in the chart?
JOSEPH CERCIELLO: I have.
MS. COMEY: Do they generally depict the same type of content we saw in all those clips?
JOSEPH CERCIELLO: Yes, they do.
MS. COMEY: In total, do they last many hours?
JOSEPH CERCIELLO: They do.
MS. COMEY: We're not going to play clips from the rest, but I want to point out the other rows that cite videos.
MS. COMEY: Let's go back to Government Exhibit 1406, page 9, please.
You can turn that on for the attorneys' screens. Thank you, Ms. Becker.
MS. COMEY: Looking at page 9, row 24, what is the date?
JOSEPH CERCIELLO: 2/7/2023 to 2/10/2023.
MS. COMEY: Does this also have explicit videos?
JOSEPH CERCIELLO: It does.
MS. COMEY: Let's go now to page 10, row 25, what's the date?
JOSEPH CERCIELLO: 3/15/2023.
MS. COMEY: Does this also have explicit videos?
JOSEPH CERCIELLO: It does.
MS. COMEY: Let's go to page 11, row 27, what's date?
JOSEPH CERCIELLO: 3/21/2023 to 3/23/2023.
MS. COMEY: Does this date also have explicit videos?
JOSEPH CERCIELLO: It does.
MS. COMEY: Let's look at page 13, row 33, please. What's date?
JOSEPH CERCIELLO: 7/4/2023.
MS. COMEY: Does this date also have explicit videos?
JOSEPH CERCIELLO: It does.
MS. COMEY: Go to page 17, row 45, please. What's the date?
JOSEPH CERCIELLO: 7/31/2024 to 8/1/2024.
MS. COMEY: Does this also have explicit videos?
JOSEPH CERCIELLO: It does.
MS. COMEY: And, finally, looking at row 46, what's the date?
JOSEPH CERCIELLO: 8/8/2024.
MS. COMEY: Does this also have explicit video?
JOSEPH CERCIELLO: Yes.
MS. COMEY: We can take down 1406.
I want to move on now to a different chart.
Let's go to Government Exhibit 1408.
MS. COMEY: And as we're pulling it up, I want to ask you, you said you reviewed four charts in total for this case, is that right?
JOSEPH CERCIELLO: Correct.
MS. COMEY: Do the three other than 1406 take a deeper dive at the evidence of some of the date ranges in 1406?
JOSEPH CERCIELLO: Yes.
MS. COMEY: We're going to look at those now.
MS. COMEY: Can we please pull up what's in evidence as Government Exhibit 1408.
MS. COMEY: Now, agent looking at the dates for this chart, is this a deeper dive at the row in 1406 that covers September 17 through 19th, 2023?
JOSEPH CERCIELLO: Yes, it does.
MS. COMEY: I want to take a look at that row in 1406 before we go through this chart. Can we please go back to 1406 page 14, row 35 Ms. Becker.
MS. COMEY: Looking at row 35, could we please take a look -- what is the date range for this row?
JOSEPH CERCIELLO: 9/17/2023 to 9/19/2023.
MS. COMEY: And what is in the location column?
JOSEPH CERCIELLO: Location is Trump International Hotel, New York, New York and the Whitby new York, New York.
MS. COMEY: Let's look at the next column, please. What are the names?
JOSEPH CERCIELLO: Jane, Combs, Robert, Kabrale.
MS. COMEY: Let's go to the next column please what are the flight records?
JOSEPH CERCIELLO: A flight record for Jane on 9/17, a flight from LAX to JFK.
9/22, car pickup at LAX.
And a flight record for Kabrale, 9/18 united flight from Atlanta to Newark
and 9/19 United flight from Newark to Atlanta.
MS. COMEY: Finally, let's look at the financials column, please.
JOSEPH CERCIELLO: It's a financial record in the name of Robert on 9/21, $1,000 Venmo payment from Jane to Bridget Collins for remaining balance.
9/21 there's a $500 Zelle payment from Collins Productions to Robert Boese for remaining balance.
And Kabrale, there's a financial transaction on 9/19. Jane texts: "I'm going to ask what the status of the cash is now. Hit you in few."
MS. COMEY: Thank you.
MS. COMEY: Let's go now to Government Exhibit 1408 again.
MS. COMEY: Can you tell us generally what is contained in this chart?
JOSEPH CERCIELLO: In this chart are names, date ranges, a business name which is a hotel or airline, a dollar amount, a payment method and the account holder of that payment method.
MS. COMEY: So is name the customer consuming the service that's being paid for here?
JOSEPH CERCIELLO: Correct.
MS. COMEY: And is date the date that the service is provided?
JOSEPH CERCIELLO: Yes.
MS. COMEY: And is business name the business that's providing the service?
JOSEPH CERCIELLO: Correct.
MS. COMEY: What are the brackets under each business name?
JOSEPH CERCIELLO: The corresponding Government Exhibit .
MS. COMEY: Does that Government Exhibit provide the source for the name, date and business columns?
JOSEPH CERCIELLO: It does.
MS. COMEY: And what information is contained in amount?
JOSEPH CERCIELLO: Would be the dollar amount of that service.
MS. COMEY: What information is contained in payment method?
JOSEPH CERCIELLO: Payment method would be the way in which that payment -- the service was paid for.
MS. COMEY: And what is in brackets underneath the payment method in each row?
JOSEPH CERCIELLO: Those would also be the corresponding government exhibits.
MS. COMEY: Do those contain the amount, the payment method, and the account holder?
JOSEPH CERCIELLO: Yes.
MS. COMEY: What is contained in account holder?
JOSEPH CERCIELLO: That would be the name on the account of the payment method.
MS. COMEY: I want to look through these rows. Who are the three names in the name column on this chart?
JOSEPH CERCIELLO: First one is Jonathan Perez. Jane, Kabrale Williams -- and Jane again.
MS. COMEY: Is it just those three names?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Which services are associated with the name Jonathan Perez?
JOSEPH CERCIELLO: That would be Trump International Hotel.
MS. COMEY: I'd like to look at the record cited here, Ms. Becker. Would you please pull up Government Exhibit 7Y-120 side by side with 7Y-121.
MS. COMEY: What kinds of records are these?
JOSEPH CERCIELLO: These are hotel bills for reservation.
MS. COMEY: Looking down at the bottom left footer of each of these, what is the address listed?
JOSEPH CERCIELLO: One Central Park West, New York, New York, 10023.
MS. COMEY: Is that the same address in both records?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: In what borough is that address located?
JOSEPH CERCIELLO: Manhattan.
MS. COMEY: Looking at the top left of these records just below hotel name, what is the name underneath the hotel logo on each of these documents?
JOSEPH CERCIELLO: Jonathan Perez.
MS. COMEY: For 7Y-120 on the left, what is the room number looking at the top right?
JOSEPH CERCIELLO: Room number is 0508.
MS. COMEY: What's the arrival date for that room?
JOSEPH CERCIELLO: Arrival 9/17/2023.
MS. COMEY: What is the checkout date?
JOSEPH CERCIELLO: Departure at 9/18/2023.
MS. COMEY: Does this record have the times of arrival and departure or just the dates?
JOSEPH CERCIELLO: Just the dates.
MS. COMEY: Let's look over at 7Y-121. What's the room number?
JOSEPH CERCIELLO: Room number 0510.
MS. COMEY: What's the arrival?
JOSEPH CERCIELLO: Arrival 9/18/2023.
MS. COMEY: What's the departure?
JOSEPH CERCIELLO: Departure 9/19/2023.
MS. COMEY: Same question does this record tell us the time of the check in and check out or just the dates?
JOSEPH CERCIELLO: No, just the dates.
THE COURT: Ms. Comey, can we turn on the overflow rooms or do we still need to keep those off?
MS. COMEY: Your Honor, I think I'm about to pull up a record that has Jane's true name.
THE COURT: Can you let us know when --
MS. COMEY: Yes, your Honor.
MS. COMEY: Let's go back to 1408, please. And looking at Government Exhibit -- let's look at the payment method for the hotel --
MS. COMEY: Your Honor if you want me to be turning on and off, I'm happy to do that. This next record is not going to have Jane's true name in it.
THE COURT: I think we should turn it on. I think it takes just a few seconds to turn it off.
MS. COMEY: That's fine. I'll let Mr. Deputy know when we can turn it back off. We can go ahead and turn it back on then.
MS. COMEY: So looking at the payment method what was the payment method?
JOSEPH CERCIELLO: An Amex, American Express.
MS. COMEY: What was the number?
JOSEPH CERCIELLO: 8-57009.
MS. COMEY: Who is the account holder?
JOSEPH CERCIELLO: The account holder is Sean Combs.
MS. COMEY: Let's pull up the underlying exhibit. Can we go to Government Exhibit 4A-121, and go to page 18 and 19, please.
MS. COMEY: What kind of record is this?
JOSEPH CERCIELLO: This is an American Express credit card bill.
MS. COMEY: Whose name is at the top left of each of these pages?
JOSEPH CERCIELLO: Sean Combs.
MS. COMEY: Looking at the bottom of page 18 on the left, what is the charge at the bottom row?
MS. COMEY: If we could zoom in on that, please.
JOSEPH CERCIELLO: The name of the charge is Trump International Hotel.
MS. COMEY: Are the arrival and departure dates the same dates we saw looking at the Trump Hotel records just a moment ago?
JOSEPH CERCIELLO: Yes.
MS. COMEY: What is the total charge?
JOSEPH CERCIELLO: $2,597.11.
MS. COMEY: We can look at the top right. Take this down, Ms. Becker. Thank you. And then looking over at the next page, going four down, could you zoom in on that, please.
MS. COMEY: What record is this?
JOSEPH CERCIELLO: This is also another charge on 9/19/2023, Trump International Hotel.
MS. COMEY: What's the arrival and departure dates?
JOSEPH CERCIELLO: Arrival date 9/18/2023. Departure date 9/19/2023.
MS. COMEY: Is that the same check-in and check-out dates we saw in the second Trump Hotel record we looked at a moment ago?
JOSEPH CERCIELLO: That's correct.
MS. COMEY: What's the cost of this stay?
JOSEPH CERCIELLO: $2,490.17.
MS. COMEY: Let's go back to Government Exhibit 1408.
MS. COMEY: What transportation services were provided to Jane?
JOSEPH CERCIELLO: Premier Travel and Jet Blue and UDEW Transporters.
MS. COMEY: On what dates?
JOSEPH CERCIELLO: 9/17/2023.
MS. COMEY: Who paid for all of those?
JOSEPH CERCIELLO: Payment account holder is the name Jessica Ruiz/CE Opco LLC.
MS. COMEY: Using what payment method?
JOSEPH CERCIELLO: An Amex. The number is 8-44006.
MS. COMEY: I'd like to look at that record, so if we could turn off the public screens, please. Let's please pull up Government Exhibit 6D-101, pages 1 and 2.
MS. COMEY: Is this a Jet Blue record?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: Let's take a look at page 1. Is this 6D-101, pages 1 and 2? 6D as in David, please, pages 1 and 2.
MS. COMEY: Is this a Jet Blue record?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Let's look under header. Do you see Jane's true name without saying it out loud?
JOSEPH CERCIELLO: Yes, I do.
MS. COMEY: Can you read what it says below pre-reserved seats on the left?
JOSEPH CERCIELLO: Sorry, read?
MS. COMEY: On the left. On the left, Ms. Becker, on page 1.
MS. COMEY: Below pre-reserved seats, please, can you just tell us the date and airport codes?
JOSEPH CERCIELLO: September 17, 2023, LAX-JFK.
MS. COMEY: Let's go now on the right. Is this another record with Jane's true name?
JOSEPH CERCIELLO: It is.
MS. COMEY: Can you read for us the reserved seats date and airport codes?
JOSEPH CERCIELLO: September 21, 2023, JFK-LAX.
MS. COMEY: Going back to 1408, please.
MS. COMEY: How are both of those flights paid for?
JOSEPH CERCIELLO: With the Amex ending in 8-44006.
MS. COMEY: Let's take a look at that credit card bill. Pull up Government Exhibit 4A-150, page 2666.
MS. COMEY: What kind of record is this?
JOSEPH CERCIELLO: This is an American Express bill.
MS. COMEY: Can you see who it was prepared for up at the top?
JOSEPH CERCIELLO: Jessica Ruiz/CE Opco LLC.
MS. COMEY: What is the closing date for this record?
JOSEPH CERCIELLO: Closing date is 9/19/2023.
MS. COMEY: Looking at the first charge on this page, what kind of charge is this?
JOSEPH CERCIELLO: This is a charge for Jet Blue Airways.
MS. COMEY: Underneath passenger ticket, does it say Jane's true name?
JOSEPH CERCIELLO: It does.
MS. COMEY: What is the from?
JOSEPH CERCIELLO: Los Angeles.
MS. COMEY: What is the to?
JOSEPH CERCIELLO: JFK.
MS. COMEY: Let's take a look at page 2974 of this same record, please. Can we zoom in on the section around the middle that has all of the 2023 dates, please.
MS. COMEY: Are these payment records for the same American Express account?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: Looking at the 2 October 2023, it's about four lines down, and the 30 October 2023. Over on the right who was the -- what was the name of the payment maker for those statements?
JOSEPH CERCIELLO: Payment maker would be Bad Boy Ent.
MS. COMEY: Finally, let's pull up pages 3371 side by side with 3381, please.
MS. COMEY: Are these screenshots of the payment page for the same account?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Are they for the same payments that we just looked at in the spreadsheet on the other page?
JOSEPH CERCIELLO: Yes, they are.
MS. COMEY: Whose name is up at the top?
JOSEPH CERCIELLO: Jessica Ruiz.
MS. COMEY: Let's go back now to 1408. And we can turn on the public screens. What transportation services were provided to Kabrale Williams?
JOSEPH CERCIELLO: United Airlines.
MS. COMEY: On what dates?
JOSEPH CERCIELLO: On 9/18/2023 and 9/19/2023.
MS. COMEY: How were those paid for?
JOSEPH CERCIELLO: Those were paid with a Visa 4220.
MS. COMEY: Who was the account holder for that Visa?
JOSEPH CERCIELLO: Jane.
MS. COMEY: Finally, down at the bottom row, what do we see on the last row here?
JOSEPH CERCIELLO: It's a wire transfer to Jane Doe.
MS. COMEY: From who?
JOSEPH CERCIELLO: Sean Combs.
MS. COMEY: For how much?
JOSEPH CERCIELLO: $5,000.
MS. COMEY: I'm sorry we need to turn off the public screens again, so that I can pull up those exhibits, please. Let's go to Government Exhibit 4H-128.
MS. COMEY: We see an email chain here?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Let's zoom in on the bottom email, please.
MS. COMEY: Looking at the first email in this chain, who is it from?
JOSEPH CERCIELLO: Robin Greenhill.
MS. COMEY: And what is her email address?
JOSEPH CERCIELLO: Robin@team-TriStar.com.
MS. COMEY: Who is it to?
JOSEPH CERCIELLO: Team Combs.
MS. COMEY: And what is the date?
JOSEPH CERCIELLO: The date is 9/21/2023, September 21, 2023.
MS. COMEY: Can we please pull up page 2 next to this page now, please, Ms. Becker.
MS. COMEY: Does Robin send a screenshot?
JOSEPH CERCIELLO: Yes.
MS. COMEY: And at the screenshot on the right of the screen, does it say, "Hey please send" and then Jane's true name "5K now, please? Thank you."
JOSEPH CERCIELLO: Yes, it does.
MS. COMEY: Is the response: "Hi. Happy Thursday. Hope you are having a great day. Will do"?
JOSEPH CERCIELLO: Correct.
MS. COMEY: Let's look at Government Exhibit 4D-132, please. Ms. Becker, I'll ask you to free the headers on this Excel, and then scroll down to row 161, please.
MS. COMEY: Looking at row 161, without saying it out loud -- well, you can say out loud who is the debit party name?
JOSEPH CERCIELLO: Debit party name Sean Combs.
MS. COMEY: And the beneficiary, is that Jane's true name?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: What is the amount?
JOSEPH CERCIELLO: The amount is 5,000.
MS. COMEY: And what is the transaction date?
JOSEPH CERCIELLO: 9/21/2023.
MS. COMEY: And is that the same day that Robin Greenhill sent that screenshot to Team Combs that we saw in the other exhibit?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: We can take this down. Thank you.
I'd like to now go to the next chart you reviewed, Government Exhibit 1409. Can we look at the second page 2 just briefly, please, Ms. Becker.
MS. COMEY: Going back to the first page, is this a deeper dive into the September 24, 2023 through September 30, 2023 dates on the earlier chart?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: I'd like to look at the earlier chart first. Let's go back to 1406, page 14, please.
MS. COMEY: And we'll look at rows 36 and 37. So for 36 and 37, I want to start by looking at the dates. What are the dates of 36 and 37?
JOSEPH CERCIELLO: 36 is 9/24/2023 to 9/26/2023. And for 37, the date is 9/30/2023.
MS. COMEY: Let's skip over to the flight records column, please. Looking at the flight records column, what is the flight for Jane in row 36?
JOSEPH CERCIELLO: 36 Jane 9/24, flight from LA to Miami.
MS. COMEY: And then what is the flight for Jane in row 37?
JOSEPH CERCIELLO: Dated 9/30, flight from Fort Lauderdale to LAX.
MS. COMEY: Do these two rows fall in between her arrival to Miami and her departure from Miami?
JOSEPH CERCIELLO: Yes, it does.
MS. COMEY: Can you tell us the location for the first row, row 36, and September 24 through September 26?
JOSEPH CERCIELLO: Location would be the Edition Hotel, Miami, Florida.
MS. COMEY: What are the names?
JOSEPH CERCIELLO: Paul, room 1108. And Williams room 1102.
MS. COMEY: And then is that the hotel reservation names?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Let's now go to the names column. What are the names in the names column?
JOSEPH CERCIELLO: Jane, Combs, Kabrale.
MS. COMEY: And then going over to flight records, what flight records are there for Kabrale?
JOSEPH CERCIELLO: Kabrale, 9/24 a flight from Atlanta to Fort Lauderdale and 9/26 American Airlines flight from Miami to Atlanta.
MS. COMEY: Let's go to row 37, the 9/30/2023 date. What's the location for that row?
JOSEPH CERCIELLO: Miami, Florida.
MS. COMEY: What are the names here?
JOSEPH CERCIELLO: Jane and Combs.
MS. COMEY: Now that we've looked at that, let's go back to Government Exhibit 1409, please. Are we all able to pull up pages 1 and 2 simultaneously, Ms. Becker.
MS. COMEY: Generally, what's contained in this chart, agent?
JOSEPH CERCIELLO: This chart consists of names, date ranges, business, the amount for the business, and the payment, method and, again, the account holder's name for that particular payment method.
MS. COMEY: Does it contain essentially the same kind of information we saw in the last financial chart 1408?
JOSEPH CERCIELLO: Yes, it does.
MS. COMEY: Does it use the same column headers?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Looking at this chart, what names are listed as receiving services during this date range?
JOSEPH CERCIELLO: Brendan Paul, Kabrale James, Jane.
MS. COMEY: You said Kabrale James?
JOSEPH CERCIELLO: I'm sorry, Kabrale Williams and Jane.
MS. COMEY: Let's look first at -- let's go to page 1 now please, Ms. Becker.
MS. COMEY: What is in Brendan Paul's name?
JOSEPH CERCIELLO: It's a date range of 9/24/2023, the Miami Beach Edition.
MS. COMEY: What was the amount for that hotel stay?
JOSEPH CERCIELLO: The amount was $11,734.42.
MS. COMEY: How was that paid for?
JOSEPH CERCIELLO: With a Amex number 8-44006.
MS. COMEY: Who was the account holder?
JOSEPH CERCIELLO: Jessica Ruiz/CE Opco LLC.
MS. COMEY: Is that the same American Express account we looked at records for just a moment ago?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: Let's look at Kabrale Williams. Can you walk us through what services he received according to this chart?
JOSEPH CERCIELLO: Kabrale Williams, between the date range of 9/24/2023 to 9/26/2023, the Miami Beach Edition Hotel.
MS. COMEY: How was that paid for?
JOSEPH CERCIELLO: With an Amex 8-44006.
MS. COMEY: The same one we've been talking about?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Who was the account holder?
JOSEPH CERCIELLO: Jessica Ruiz/CE Opco LLC.
MS. COMEY: Did that same Amex pay for the rest of Kabrale Williams' services on this chart?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Can you walk us through what Kabrale Williams is listed under for the rest of this chart, please?
JOSEPH CERCIELLO: Row 8 Kabrale Williams 9/24/2023, Southwest Airlines, Atlanta to Fort Lauderdale.
Row 9, Kabrale Williams 9/24/2023, Travel agency service fee.
Row 10, Kabrale Williams 9/25/2023, Travel agency service fee.
Row 11, Kabrale Williams 9/25/2023, airport Concierge of Atlanta.
Row 12, Kabrale Williams 9/25/2023, Fuentes Limousine Service.
And Kabrale Williams 9/26/2023, American Airlines, Miami to Atlanta.
MS. COMEY: I apologize. I realize the public screens can be on for this.
MS. COMEY: Let's look now at the services for Jane. Can you walk us through what we see on page 1 for Jane?
JOSEPH CERCIELLO: Row 3, Jane 9/24/2023, American Airlines, LAX to Miami.
Row 4, Jane 9/24/2023, Fuentes Transportation.
Row 5, Jane 9/24/2023, Cardinal Valet LLC.
Row 6, Jane 9/24/2023, Cardinal Valet LLC.
And row 7, Jane, 9/24/2023, Greg Transportation Service.
MS. COMEY: Finally, let's go to page 2, please.
MS. COMEY: Would you walk us through the last three rows of this chart for Jane?
JOSEPH CERCIELLO: Row 14, Jane 9/29/2023, Travel agency service fee.
Row 15, Jane 9/30/2023, Jet Blue Airlines, Miami to LAX.
And row 16, Jane 9/30/2023, Travel agency service fee.
MS. COMEY: Thank you. We can take that down.
Your Honor, I'm about to move on to another chart. I don't know if you wanted to take a morning break or if I should go ahead?
THE COURT: Let's keep going for a little bit, and we can take a break when we come to a good landing point at 11:00 a.m.
MS. COMEY: Sure. Thank you, your Honor.
MS. COMEY: Agent, would you take a look at the binder next to you?
MS. COMEY: In the meantime, Ms. Becker, would you pull up what's been marked for identification as Government Exhibit 1407.
MS. COMEY: Agent, my question for you is: Do you recognize that?
JOSEPH CERCIELLO: Yes.
MS. COMEY: What is it?
JOSEPH CERCIELLO: This is one of the can charts I reviewed.
MS. COMEY: Is this the fourth and final chart that you reviewed in connection with this case?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Did you follow the same process you've described for us before to verify the accuracy of this chart?
JOSEPH CERCIELLO: Yes, I did.
MS. COMEY: And can you give us a sense of what kinds of records this chart summarizes?
JOSEPH CERCIELLO: Again, this chart consists of date ranges, record types, whether it was a text message, airline record, audio messages or photos. There's a to and from column which would be who sent the text message or --
MS. COMEY: Before we go into the content of the columns, just the kinds of records you reviewed.
JOSEPH CERCIELLO: I'm sorry. It would be telephone records, airline records and financial records.
MS. COMEY: Did you also review text messages?
JOSEPH CERCIELLO: Yes.
MS. COMEY: What was the volume of all of those records?
JOSEPH CERCIELLO: This was in the thousands.
MS. COMEY: Thousands of pages?
JOSEPH CERCIELLO: Yes, ma'am.
MS. COMEY: Did you review the underlying exhibits to confirm that this chart accurately reflects the information contained in the source materials?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Your Honor the government offers 1407 in evidence.
THE COURT: Any objections, other than those the Court has previously ruled on?
MS. GERAGOS: No, your Honor.
THE COURT: Government Exhibit 1407 will be admitted.
(Government's Exhibit 1407 received in evidence)
MS. COMEY: Let's publish those to the public screens -- actually, not to the public screens. This has Jane's information in it, so we need to keep the public screens off. I apologize.
Let's publish that to the jury, please.
MS. COMEY: Now, would you please walk us through the columns of this chart?
JOSEPH CERCIELLO: Sure.
The columns consist of a date range with specific dates and times. The record type: To -- from and to columns, which would be who would send the information and the receiver. The content of that information. And the last column is the government's exhibit source.
MS. COMEY: Is that the source of the information in the row?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: Does this chart offer a deeper dive into a handful of the rows contained in the chart at Government Exhibit 1406?
JOSEPH CERCIELLO: Yes.
MS. COMEY: What's the date of the first row of this chart?
JOSEPH CERCIELLO: It would be 11/8/2021.
MS. COMEY: Let's go to the last page, page 125, please.
MS. COMEY: What is the date of this last row?
JOSEPH CERCIELLO: 6/26/2024.
MS. COMEY: In what order are the rows organized?
JOSEPH CERCIELLO: From earliest to latest.
MS. COMEY: Let's go back to page 1, please.
MS. COMEY: Does this chart contain every single message that the participants in this chart sent or received for the entire period we just went through?
MS. COMEY: Does this chart just focus on messages from a few of the rows we looked at in Government Exhibit 1406?
JOSEPH CERCIELLO: Yes.
MS. COMEY: But to be clear, does this chart contain all of the messages from every row in 1406, or just some?
JOSEPH CERCIELLO: Just some.
MS. COMEY: And are there more -- many more messages between the folks referenced in this chart that are not contained in this summary exhibit?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Who decided what messages to include?
JOSEPH CERCIELLO: The prosecution team.
MS. COMEY: Does this chart contain every single piece of evidence from every time period in this chart, or just some?
JOSEPH CERCIELLO: Just some.
MS. COMEY: Who decided what evidence to include?
JOSEPH CERCIELLO: Again, the prosecution team.
MS. COMEY: How did you go about verifying this chart?
JOSEPH CERCIELLO: I was given the chart and I was also given a list of the Government Exhibits, and one by one I would make sure that the rows and the Government Exhibits matched up.
MS. COMEY: Are there instances where the Government Exhibit cited is significantly longer than the content that is in this chart?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: How would someone go about checking to see what is contained in the full Government Exhibit cited?
JOSEPH CERCIELLO: They can request the Government Exhibit and read it in its entirety.
MS. COMEY: Now, are there gray bars between some rows in this chart?
JOSEPH CERCIELLO: Yes.
MS. COMEY: I want to take a look at those.
Do those separate the date ranges corresponding to rows in 1406?
JOSEPH CERCIELLO: Yes.
MS. COMEY: So let's orient ourselves to that. On page 1, what's the first date for this section?
JOSEPH CERCIELLO: 11/8/2021.
MS. COMEY: Let's go to page 26. What date does this first section end?
JOSEPH CERCIELLO: 11/11/2021.
MS. COMEY: And then after the gray bar, at what date does the next section start?
JOSEPH CERCIELLO: 11/14/2021.
MS. COMEY: Let's go to page 30.
MS. COMEY: At what date does this second section end?
JOSEPH CERCIELLO: 11/17/2021.
MS. COMEY: At what date does that next section start?
JOSEPH CERCIELLO: 1/18/2023.
MS. COMEY: Let's go to page 48. At what date does this third section end?
JOSEPH CERCIELLO: 1/25/2023.
MS. COMEY: And then what is the date of the next section?
JOSEPH CERCIELLO: 9/4/2023.
MS. COMEY: Let's go to page 82. At what date does this section end?
JOSEPH CERCIELLO: 9/21/2023.
MS. COMEY: What date starts after the gray bar?
JOSEPH CERCIELLO: 9/29/2023.
MS. COMEY: Let's go to page 88. At what date does this section end?
JOSEPH CERCIELLO: 10/2/2023.
MS. COMEY: Let's go to page 89. What date does the next section start?
JOSEPH CERCIELLO: 10/16/2023.
MS. COMEY: Finally, let's go to page 115. When does that section end?
JOSEPH CERCIELLO: 10/30/2023.
MS. COMEY: When does the last section begin?
JOSEPH CERCIELLO: 6/18/2024.
MS. COMEY: In total, are there seven date ranges contained in this chart?
JOSEPH CERCIELLO: There are.
MS. COMEY: Who picked the date ranges to include in the chart?
JOSEPH CERCIELLO: The prosecution team.
MS. COMEY: I'd like to start by focusing first on the section that covers September 2023, that same period as those financial charts we were just looking at. Let's go to page 48, please.
MS. COMEY: Can you tell us what time zone in section is in?
JOSEPH CERCIELLO: Eastern Standard Time.
MS. COMEY: How do we know that?
JOSEPH CERCIELLO: Up top it says EST.
MS. COMEY: Are each of the sections in across this chart in different time zones?
JOSEPH CERCIELLO: Yes.
MS. COMEY: So did the times for the underlying records get converted in this chart to all be the same time zone that's indicated in the header for each section?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Let's look at the corresponding row. Can we go to 1406, page 14, please. We'll look at row 35.
MS. COMEY: Is this the row that corresponds with what we were just looking at in 1407?
JOSEPH CERCIELLO: Yes, it does.
MS. COMEY: What are the dates?
JOSEPH CERCIELLO: 9/17/2023 to 9/19/2023.
MS. COMEY: What are the names?
JOSEPH CERCIELLO: Jane, Combs, Robert and Kabrale.
MS. COMEY: Now let's go back to 1407, page 48.
MS. COMEY: Does this section start a bit before the date range we just saw in the chart on 1406?
JOSEPH CERCIELLO: Yes, it does.
MS. COMEY: Before we walk through this section, I want to take a look at how this works and how these exhibits are cited.
What is the first row for this event, row 525?
JOSEPH CERCIELLO: It would be a hotel record.
MS. COMEY: What kind of hotel record?
JOSEPH CERCIELLO: This would be a hotel record for the Whitby Hotel.
MS. COMEY: What's the date of the arrival?
JOSEPH CERCIELLO: 9/4/2023.
MS. COMEY: What's the content of this record?
JOSEPH CERCIELLO: Mr. Frank Black, room 703.
MS. COMEY: What's the source?
JOSEPH CERCIELLO: Government Exhibit GX-7X-151.
MS. COMEY: Let's take a look. Ms. Becker, would you please pull up Government Exhibit 7X-151, page 1.
MS. COMEY: What's the name at the top left of this record?
JOSEPH CERCIELLO: Mr. Frank Black.
MS. COMEY: What is the arrival date at the top right?
JOSEPH CERCIELLO: 9/4/2023.
MS. COMEY: What's the departure date?
JOSEPH CERCIELLO: 9/21/2023.
MS. COMEY: Does that include the date range that we saw in the chart a moment ago?
JOSEPH CERCIELLO: It does.
MS. COMEY: Let's go back now to Government Exhibit 1407, page 48, please.
MS. COMEY: Could you tell us what's in the next row of this section 526?
JOSEPH CERCIELLO: Dated 9/15/2023, it's a text message from Jane to Sean Combs.
MS. COMEY: What does the text message say?
JOSEPH CERCIELLO: "Should we have Jess start looking for Sunday night flights? Miss you more. I can't wait to hold you and kiss you."
MS. COMEY: What's the source?
JOSEPH CERCIELLO: Government Exhibit A-104-59-P.
MS. COMEY: What's in parentheses next to it?
JOSEPH CERCIELLO: Page 1203.
MS. COMEY: Let's take a look at that exhibit. Ms. Becker, would you pull up Government Exhibit A-104-59-P and go to page 2 of the PDF.
MS. COMEY: Let's start in the top left. Is this the text message you just read out loud for us?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: Is it from Jane to Mr. Combs?
JOSEPH CERCIELLO: It is.
MS. COMEY: Now let's look at the bottom right of this page. The gray number in the bottom right, the gray number, please.
MS. COMEY: The page number on the bottom right, please, is that the same page number that you just read out as the citation in 1407?
JOSEPH CERCIELLO: Yes.
MS. COMEY: So when there's a page number in this chart, is it referring to the gray number in the bottom right-hand corner of the exhibit page?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: So is this government exhibit an excerpt of a much longer document?
JOSEPH CERCIELLO: It is.
MS. COMEY: Let's go back to Government Exhibit 1407, page 48, and look at one more example of how this works before we read through the chart.
MS. COMEY: What is row 527?
JOSEPH CERCIELLO: 527 is a text message on 9/16/2023 from Jane to Sean Combs.
MS. COMEY: What does she write?
JOSEPH CERCIELLO: "Love and miss you. Mines forever."
MS. COMEY: What's the source?
JOSEPH CERCIELLO: Government Exhibit A-442-37, page 1182.
MS. COMEY: Let's pull that up, please. Would you please pull up Government Exhibit A-442-37, and go to page 2 of the PDF, please.
MS. COMEY: Is the top left text that text you just read from the chart?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: Then let's look at the page number that was cited. Looking at the bottom right gray number, is that the page number that is cited as the source for this exhibit?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Let's go back to 1407, please, page 48.
MS. COMEY: Are the rest of the messages on this page between Jane and Mr. Combs from that same exhibit we were just looking at?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: I want to go ahead to page 49 now and look at line 540, please.
MS. COMEY: In line 540, is this a text message from Mr. Combs to Jane?
JOSEPH CERCIELLO: Yes.
MS. COMEY: What does he write?
JOSEPH CERCIELLO: "Tell me when you can come tomorrow."
MS. COMEY: How does Jane respond?
JOSEPH CERCIELLO: "Night."
MS. COMEY: And then who does Mr. Combs text next in line 542?
JOSEPH CERCIELLO: He texts Kristina Khorram.
MS. COMEY: What does he text Kristina Khorram?
JOSEPH CERCIELLO: "Can you get Jane here tomorrow?"
MS. COMEY: How does Kristina respond?
JOSEPH CERCIELLO: She likes that message.
MS. COMEY: What does she say in the next row?
JOSEPH CERCIELLO: "Okay."
MS. COMEY: And what is the next text that Kristina sends to Mr. Combs at 1:06 p.m. on September 16, 2023?
JOSEPH CERCIELLO: "FYI, Jane just told me she's not come to NYC."
MS. COMEY: What's the text we see at the bottom of this page, page 546?
JOSEPH CERCIELLO: It's a text messages from Jane to Sean Combs.
MS. COMEY: What does she write?
JOSEPH CERCIELLO: "I'm not coming to New York. I feel disrespected that you have to unnecessarily brag online that you fucked for 48 hours straight on a trip you said you were asleep on. Then text me that you're horny and need my videos to get your dick hard to fuck someone else. It's clear you just want -- it's clear you just want me there to use me for a hotel binge. You got plenty of hoes for that."
MS. COMEY: Let's go to page 50, please.
MS. COMEY: Was does Mr. Combs write to Jane in the next two rows?
JOSEPH CERCIELLO: 547?
MS. COMEY: 547 and 548, yes.
JOSEPH CERCIELLO: Sean Combs to Jane: "What happened I dad."
Sean Combs to Jane: "I'm sad. What happened."
(Continued on next page)
BY MS. COMEY:
MS. COMEY: And then in the next row, row 549, does Jane send the same text message but to a different phone number for Sean Combs?
JOSEPH CERCIELLO: Yes.
MS. COMEY: And then what does she write in row 550?
JOSEPH CERCIELLO: Jane to Sean Combs: "I don't want to be used and locked in a room to perform and fulfill your fantasies. Coming to the realization of what this really is."
MS. COMEY: How does Mr. Combs respond in line 551?
JOSEPH CERCIELLO: Sean Combs to Jane: "Girl, that was podcast talk. I haven't even had sex."
MS. COMEY: Let's go ahead now to page 51, line 563, please.
MS. COMEY: Looking at line 563, what's the date of this message?
JOSEPH CERCIELLO: 9/16, 2023.
MS. COMEY: And who sends it?
JOSEPH CERCIELLO: Jane.
MS. COMEY: To whom?
JOSEPH CERCIELLO: Sean Combs.
MS. COMEY: What does she write?
JOSEPH CERCIELLO: "As much as I want to see you, I just know what you want me out there for. It doesn't make me feel good. You got other women available and willing to do that."
MS. COMEY: And how does Mr. Combs respond in the next row?
JOSEPH CERCIELLO: Sean Combs to Jane: "Bye always tipping on me."
MS. COMEY: Let's go now to page 52, line 566, please.
MS. COMEY: Is this a text from Jane to Mr. Combs?
JOSEPH CERCIELLO: Yes.
MS. COMEY: What does she write?
JOSEPH CERCIELLO: "I wish we could jog this back to when we first started dating and just getting to know each other. Ever since I opened Pandora's box, I've never been able to close it. One night of fun turned into the entirety of our relationship, and now it's all I'm expected to do and get called for. It's hurting me bc I'm so much more than being loved in the dark in hotel rooms, doing things that make me feel disgusted with myself. I'm confusing your lust for me as real love. My heart is really in this, and it's breaking. I don't want to play this role in your life anymore. It's dark, sleazy and makes me feel disgusted with myself. I feel it's the only reason you have me around and why you pay for the house. I don't want to feel obligated to perform these nights with you in fear of losing the roof over my head. I don't want to keep feeling like that anymore. I'm crying as I type this. We just need to talk like adults and figure out where we'll go from here."
MS. COMEY: Let's go to page 53, please.
MS. COMEY: Does Jane then send the same message to Mr. Combs's other phone?
JOSEPH CERCIELLO: Yes.
MS. COMEY: How does Mr. Combs respond in the next line?
JOSEPH CERCIELLO: Sean Combs to Jane: "Girl, stop."
MS. COMEY: Let's go to page 54, please.
MS. COMEY: Does Mr. Combs then send an audio message to Jane?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Now, in the content column here, what is the italic text in that box?
JOSEPH CERCIELLO: That's a transcription from the audio message.
MS. COMEY: What is the nonitalicized text below the italics? Is that the file name for the audio message?
JOSEPH CERCIELLO: Yes.
MS. COMEY: After the audio message, what does Combs text to Jane in line 570?
JOSEPH CERCIELLO: Sean Combs to Jane: "Let's talk. I'm fucked up. Call me ASAP."
MS. COMEY: And what does Jane respond with in the next line?
JOSEPH CERCIELLO: Jane to Sean Combs: "Call me back."
MS. COMEY: After Jane texts Combs "call me back," who does Jane text next in line 572?
JOSEPH CERCIELLO: Kristina Khorram.
MS. COMEY: How long after Jane's text to Combs "call me back" does Jane then text Kristina?
JOSEPH CERCIELLO: About 15 minutes.
MS. COMEY: And what does she text to Kristina?
JOSEPH CERCIELLO: "Hi, K.K. OK. We spoke. I'll be able to travel tmw. Just let me know. Thank you."
MS. COMEY: Would you please read the next three lines for us of this page?
JOSEPH CERCIELLO: Sean Combs to Jane: "Love you, baby. Can't wait to you." Jane to Sean Combs: "I love you too." Kristina Khorram to Jane: "OK. Cool. Going to text now for options with Jess."
MS. COMEY: Let's go to page 55, please, line 582.
MS. COMEY: In line 582, what is noted in this row?
JOSEPH CERCIELLO: This is a hotel record for Trump International Hotel.
MS. COMEY: Is that one of the Trump records that we looked at a moment ago?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Is there a time for check-in here?
MS. COMEY: So is this at the beginning of the day of September 17, 2023, in this chart?
JOSEPH CERCIELLO: Yes.
MS. COMEY: And is that because you do not have a specific time of when the check-in was?
JOSEPH CERCIELLO: That's right.
MS. COMEY: Does it necessarily mean the check-in was at the beginning of September 17?
JOSEPH CERCIELLO: No, it doesn't.
MS. COMEY: Let's look at row 584.
MS. COMEY: Over the next few rows, are those between Sean Combs and Jane?
JOSEPH CERCIELLO: Yes.
MS. COMEY: I'd like to read those out loud.
MS. COMEY: Would you please read Mr. Combs and I'll read Jane.
JOSEPH CERCIELLO: "Good morning. The countdown begins."
MS. COMEY: "Good morning. Yes," three Ss, smiley face, smiley face.
JOSEPH CERCIELLO: "You in plane yer"
MS. COMEY: "Not yet, babe. Car pickup in 30 mins. Taking off at 11:21 a.m. I'll message you soon as board. Did you get some good rest? Get some more sleep if you can..."
JOSEPH CERCIELLO: "Going back to sleep."
MS. COMEY: And then what is the next row in line 591?
JOSEPH CERCIELLO: A text message from Joey Chavez to Faheem Muhammad.
MS. COMEY: And what does Joey text to Faheem?
JOSEPH CERCIELLO: "Fah -- nine about to give me the $6,750 soon."
MS. COMEY: Let's go to page 56, please.
MS. COMEY: What does Jane send to Combs in line 592?
JOSEPH CERCIELLO: She sends a photograph of a dress.
MS. COMEY: What does she write above?
JOSEPH CERCIELLO: "Babe, I brought this just in case we do anything, but I didn't have time to grab the right red heels for it. Is it OK if someone can grab a pair for me, please?"
MS. COMEY: How does Mr. Combs respond in the next two lines?
JOSEPH CERCIELLO: "OK. "Send all sizes."
MS. COMEY: Let's go to page 57.
MS. COMEY: And looking at line 596, what do we see in this line?
JOSEPH CERCIELLO: This is a photograph of a dress.
MS. COMEY: And who sent it to whom?
JOSEPH CERCIELLO: Sean Combs sent it to another phone for Sean Combs and a name of Jun, J-U-N.
MS. COMEY: What does Mr. Combs text to that same group in the next line?
JOSEPH CERCIELLO: Sean Combs to that group: "Text Jane pls."
MS. COMEY: Then looking down at line 599, what is in this row?
JOSEPH CERCIELLO: This is a audio message from Sean Combs to Paul Arthur.
MS. COMEY: Let's listen to it.
Would you please play, Ms. Becker, Government Exhibit A-166-H.
(Media played)
BY MS. COMEY:
MS. COMEY: Who did Mr. Combs send that audio message to on September 17, 2023, at 2:38 p.m.?
JOSEPH CERCIELLO: Paul Arthur.
MS. COMEY: And then in the next row, what does Mr. Combs text?
JOSEPH CERCIELLO: Sean Combs to Jane: "Let's have a good time. Do you have your passport?"
MS. COMEY: Let's go now to page 58, please.
MS. COMEY: What does Mr. Combs text Jane in the next row, line 601?
JOSEPH CERCIELLO: "We're going to dinner. I'm have you do a little shopping. Miss you. Can't wait to see you."
MS. COMEY: Now let's go down to row 612 at the bottom of this page.
MS. COMEY: Is that about an hour later on the same date?
JOSEPH CERCIELLO: Yes, just about.
MS. COMEY: Who does Mr. Combs text?
JOSEPH CERCIELLO: Paul Arthur.
MS. COMEY: What does he write?
JOSEPH CERCIELLO: "I do BK today. Call me."
MS. COMEY: How does Mr. Arthur respond?
JOSEPH CERCIELLO: "In L.A."
MS. COMEY: Let's go to page 59, please.
MS. COMEY: How does Combs respond in line 614?
JOSEPH CERCIELLO: "Damn."
MS. COMEY: And then looking at row 615, who is the very next text message from?
JOSEPH CERCIELLO: The text message from Bridget Kreshover.
MS. COMEY: To whom?
JOSEPH CERCIELLO: Sean Combs.
MS. COMEY: What time?
JOSEPH CERCIELLO: 4:09:06 p.m.
MS. COMEY: On September 17, 2023?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Is that right?
JOSEPH CERCIELLO: Yes.
MS. COMEY: What does Bridget write to Mr. Combs?
JOSEPH CERCIELLO: "Hello. This is Bridget from Cowboys 4 Angels. How can I help you?"
MS. COMEY: Are there several texts between Bridget and Sean Combs over the next few lines?
JOSEPH CERCIELLO: Yes, there are.
MS. COMEY: I'm going to ask you to read Mr. Combs and I'll read Bridget. You go ahead with line 616, please.
JOSEPH CERCIELLO: "Hey, in NYC. Do you have entertainment for after midnight."
MS. COMEY: "I can try," exclamation point, exclamation point. Is the next text from Kristina Khorram to Mr. Combs?
JOSEPH CERCIELLO: It is.
MS. COMEY: What does she write?
JOSEPH CERCIELLO: "We should take photos by this...on 57th and 6th...right by hotel."
MS. COMEY: Let's continue reading the exchange between Mr. Combs and Bridget Kreshover. You can go ahead.
JOSEPH CERCIELLO: "Who's this."
MS. COMEY: "Bridget and Betsi."
JOSEPH CERCIELLO: "Can I speak to Bridget."
MS. COMEY: "Yes, I'm here." Now, on the very next line, who does Mr. Combs text?
JOSEPH CERCIELLO: Jane.
MS. COMEY: And how long after the last text from Bridget does Mr. Combs text Jane?
JOSEPH CERCIELLO: About two minutes.
MS. COMEY: What does he text her?
JOSEPH CERCIELLO: "Hey, where's Chef."
MS. COMEY: And then about an hour later, what does Mr. Combs text Jane?
JOSEPH CERCIELLO: "Entertainment or movie night? Let me know so if I have to get hotel."
MS. COMEY: And are the rest of the texts between Bridget and Mr. Combs?
JOSEPH CERCIELLO: Yes.
MS. COMEY: I'll read Bridget and you read Mr. Combs, and we'll continue with the next page.
Bridget: "https://cowboys4angels.com/cowboy/Cody. Great guy. He's solid."
JOSEPH CERCIELLO: "OK. I'll hit you with info and stop raising my rates. I'm a long timers."
MS. COMEY: "It's not about your rate. It's about the guy's rates. You want the best guys. They got the highest rates." Who sends the next two texts?
JOSEPH CERCIELLO: Jane.
MS. COMEY: What does Jane send in row 632 at 7:05 p.m.?
JOSEPH CERCIELLO: "Just got to wi-fi again. "Not sure baby."
MS. COMEY: What does Jane send two minutes later to Mr. Combs's other phone?
JOSEPH CERCIELLO: "Baby, just got wi-fi again."
MS. COMEY: And then what does Mr. Combs send to Jane in the next two lines?
JOSEPH CERCIELLO: "OK. I have a surprise if that's OK. Just one. Don't want you -- don't want you feel like a in sexy. "Sending pict now."
MS. COMEY: Who does Mr. Combs send the next two texts to in lines 636 and 637?
JOSEPH CERCIELLO: Bridget Kreshover.
MS. COMEY: What does he write?
JOSEPH CERCIELLO: "Will talk. I don't agree, but we'll holla. No problem love."
MS. COMEY: Then in row 638, what does Mr. Combs send to Jane?
JOSEPH CERCIELLO: It's a link.
MS. COMEY: Is it the same link that we saw on the prior page from Bridget to Mr. Combs?
JOSEPH CERCIELLO: Yes.
MS. COMEY: And then what does Bridget write in the next line?
JOSEPH CERCIELLO: "Some of the men have different rates. You can find each men's rates on their individual profiles. Just open their pages and there's an orange button that says view rates. I'm contractually obligated to the rates on the website for each person as that's the rate we agreed on when they signed me as their agent and at each renewal."
MS. COMEY: Let's go now, please, to page 61. Line 645, please.
MS. COMEY: Looking at line 645, who does Mr. Combs send the next three text messages to?
JOSEPH CERCIELLO: Bridget Kreshover.
MS. COMEY: Would you read those three text messages, please?
JOSEPH CERCIELLO: "All good. "Let do 1 a.m. Trump. "NYC Columbus Circle."
MS. COMEY: Who are the participants in the next line?
JOSEPH CERCIELLO: Brendan Paul and Faheem Muhammad.
MS. COMEY: For the next two lines, I'll read Brendan Paul and you read Faheem Muhammad, please. "You aware of what's happening tonight after performance."
JOSEPH CERCIELLO: "Possible dinner or strip club."
MS. COMEY: "Jane is in town. We got a spot at Trump hotel, but John is setting up now, room 508."
JOSEPH CERCIELLO: "Copy. Perfect. Man down."
MS. COMEY: Going down not to line 655, what date and time is that entry?
JOSEPH CERCIELLO: 9/17, 2023, 9:14:12 p.m.
MS. COMEY: What does Jane text to Sean?
JOSEPH CERCIELLO: "Zero Bond, Casa Cipriani. My friend said for private, just chill drink spot if you're up for it."
MS. COMEY: Let's go to page 62, and looking at the top line, does Jane then send the same text message to Mr. Combs's other number?
JOSEPH CERCIELLO: Yes.
MS. COMEY: And then what is in the very next line?
JOSEPH CERCIELLO: It's a text message from Bridget Kreshover to Sean Combs.
MS. COMEY: What does it say?
JOSEPH CERCIELLO: "He'll be there."
MS. COMEY: And what does Mr. Combs say to Jane two minutes later?
JOSEPH CERCIELLO: "I'm with whatever."
MS. COMEY: And then what does Mr. Combs say to Bridget one minute later?
JOSEPH CERCIELLO: "Send numbe. It may be like 1 if that's OK."
MS. COMEY: And how does Bridget respond in the next two rows?
JOSEPH CERCIELLO: "Yeah, he couldn't get to you til after midnight anyway he said." Bridget then sends a phone number to Sean Combs.
MS. COMEY: Let's pull up stipulation -- move this chart to the left, please, Ms. Becker, and then on the right, can we please pull up stipulation 1312 and go to page 3.
MS. COMEY: And is the number in this row, 661, a number ending in 2311?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Who is the individual user of that number listed in the stipulation?
JOSEPH CERCIELLO: Robert Boese, a/k/a Robby.
MS. COMEY: Let's go back now to 1407, page 62.
MS. COMEY: After Mr. Combs receives Robby's number, what does he text to Jane?
JOSEPH CERCIELLO: "You hungry? Let's go somewhere close to hotel. Set with K.K."
MS. COMEY: And what does he say in the next line to Jane?
JOSEPH CERCIELLO: "I'll meet you there after show. T 11."
MS. COMEY: And how does Jane respond in the next three lines?
JOSEPH CERCIELLO: Jane loved the message "you hungry? Let's go somewhere close to hotel set... "OK. I'll text K.K., babe "OK. Sounds good, 11 P."
MS. COMEY: Let's turn to page 63 and look at line 668.
MS. COMEY: What does Bridget Kreshover send to Sean Combs in this row?
JOSEPH CERCIELLO: It's a screenshot of Cody's rates.
MS. COMEY: And then looking down to line 670, what does Jonathan Pérez text to Faheem Muhammad on September 17 at 11:24 p.m.?
JOSEPH CERCIELLO: "Trump security said there is a garage you can enter on 61st and Broadway for private access. They said call the front desk and then provide a phone number."
MS. COMEY: What does Mr. Pérez send in the next two rows?
JOSEPH CERCIELLO: "One Central Park West New York, New York, 10023, United States, room 508, Jonathan Pérez."
MS. COMEY: And how does Faheem respond?
JOSEPH CERCIELLO: "We 15 mins away. You there."
MS. COMEY: And is the address and room number consistent with the Trump hotel records we looked at earlier this morning?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Your Honor, I think this is a good breaking point if you want to take a morning break.
THE COURT: All right. Very good. We'll take a break now. Come back at 11:15.
Thank you, members of the jury.
(Continued on next page)
(Jury not present)
THE COURT: We'll see you back here 11:15.
(Witness not present)
THE COURT: Please be seated.
Ms. Comey, about how much longer do you have on direct?
MS. COMEY: At least an hour, your Honor.
THE COURT: At least an hour.
MS. COMEY: At least an hour, given that the chart is quite long. We have quite a bit to go through, but I will try to move it along.
THE COURT: If that's the at least, what's the --
MS. COMEY: It could be two hours.
THE COURT: OK. Understood.
Anything further from the government before we take a break?
MS. COMEY: No, your Honor.
THE COURT: Anything from the defense?
MR. AGNIFILO: No. Thank you.
THE COURT: All right. We'll see everyone 11:15.
(Recess)
(Continued on next page)
(Jury present)
THE COURT: Please be seated.
Ms. Comey, you may proceed when ready.
MS. COMEY: Thank you, your Honor.
Ms. Becker, can we go back to Government Exhibit 1407 and go to page 64. I want to take a look at line 676, please.
MS. COMEY: Looking at line 676, toward the top, what does Faheem text to Jonathan on September 17, 2023, at 11:42 p.m.?
JOSEPH CERCIELLO: "Yes, we are pulling up."
MS. COMEY: And then two texts down, at 11:43 p.m., what does Jonathan text to Faheem?
JOSEPH CERCIELLO: "In elevator with Jane."
MS. COMEY: And then in the next two rows, what does Jane text to Mr. Combs's two phones at 11:50 p.m.?
JOSEPH CERCIELLO: "Hey, baby. I think it closes soon."
MS. COMEY: And then looking at line 681, what is the entry there?
JOSEPH CERCIELLO: It's a hotel record for Trump International Hotel.
MS. COMEY: And is that for September 18, 2023?
JOSEPH CERCIELLO: Yes.
MS. COMEY: Does that start off the day of September 18?
JOSEPH CERCIELLO: Yes, it does.
MS. COMEY: And is that the second Trump record that we looked at earlier this morning?
MS. COMEY: Is that the one that has no check-in time?
JOSEPH CERCIELLO: Correct.
MS. COMEY: So does that mean that this second hotel room was checked into at 12 a.m. or just that there's no time so it starts off the day?
JOSEPH CERCIELLO: There's just no time of check-in.
MS. COMEY: Let's go now to line 683.
MS. COMEY: What does Sean Combs text to Bridget Kreshover at 12:18 a.m. on September 18?
JOSEPH CERCIELLO: "OK. 2 a.m."
MS. COMEY: How does Bridget respond?
JOSEPH CERCIELLO: "Should he start heading in?"
MS. COMEY: And then at 2:02 a.m., that same morning, what does Frank Rodriguez text to Faheem?
JOSEPH CERCIELLO: "Plz bring Gucci bag."
MS. COMEY: How does Faheem respond?
JOSEPH CERCIELLO: "It's in car."
MS. COMEY: And then at 2:15 a.m., what does Sean Combs text to Bridget Kreshover?
JOSEPH CERCIELLO: "In a sec."
MS. COMEY: And then who does Sean Combs text with in the next three lines?
JOSEPH CERCIELLO: Robert Boese, a/k/a Robby.
MS. COMEY: I'd like to read through this. Could you please read Mr. Combs and I'll read Robby. You can go ahead.
JOSEPH CERCIELLO: "508 Pérez in ten min."
MS. COMEY: "Got it."
JOSEPH CERCIELLO: "What name did I give them to you."
MS. COMEY: "Robby."
JOSEPH CERCIELLO: "OK. Calling down now."
MS. COMEY: Liked the previous message. What time was that message, that last message from Robby to Mr. Combs?
JOSEPH CERCIELLO: 2:36:39 a.m.
MS. COMEY: Looking at line 693, just to highlight it for the jury.
MS. COMEY: And how much time passes before the next entry in row 694?
JOSEPH CERCIELLO: Just a little under three hours.
MS. COMEY: So what time does Jane send the next message?
JOSEPH CERCIELLO: 5:08:51 a.m.
MS. COMEY: And who does she text early on the morning of September 18 in this row?
JOSEPH CERCIELLO: Kabrale Williams.
MS. COMEY: What does she text to Kabrale?
JOSEPH CERCIELLO: "Hey, you would you like to come to NYC for a day."
MS. COMEY: And then about 50 minutes later, who does Faheem text in the next line?
JOSEPH CERCIELLO: To Jane.
MS. COMEY: What does Faheem text to Jane? Going up at line 695, what does Faheem text to Jane?
JOSEPH CERCIELLO: "Will be there in ten mins with the cash."
MS. COMEY: How does Jane respond?
JOSEPH CERCIELLO: "OK. Great. Room 508. Do you have a key?"
MS. COMEY: How does Faheem respond?
JOSEPH CERCIELLO: "Yes, he has it."
MS. COMEY: And then for the rest of this page, who is Jane texting with?
JOSEPH CERCIELLO: Kabrale Williams.
MS. COMEY: Let's read through those. You read Kabrale. I'll read Jane, starting at line 698.
JOSEPH CERCIELLO: "Yes, I would, love."
MS. COMEY: "OK. Let me set it up now...but call me rm real quick."
JOSEPH CERCIELLO: "Kabrale Williams."
MS. COMEY: Then in the next line, is a there a date of birth and email address?
MS. COMEY: "Babe, flight is at 10:23 a.m. Can you make that? Hey, I just need your driver's license number and expiration date." Does Mr. Williams appear to send that?
JOSEPH CERCIELLO: Yes, he does.
MS. COMEY: "You're in the line for 10:23. Keep you posted shortly."
MS. COMEY: Let's go to the next page, page 66, please. I'd like to look down at line 715.
MS. COMEY: What does Jane text to Kabrale at 7:26 a.m. on September 18?
JOSEPH CERCIELLO: "FaceTime me really quick," with a heart emoji.
MS. COMEY: And then who texts Mr. Combs in the very next line at 8:17 a.m.?
JOSEPH CERCIELLO: Bridget Kreshover.
MS. COMEY: What are the three texts that Bridget Kreshover sends at 8:17 and 8:18 a.m. on the next three lines?
JOSEPH CERCIELLO: "Good morning. There was a mistake with the cash. We are $600 short. Can you please CashApp $600 Cowboys 4 Angels."
MS. COMEY: And the next --
JOSEPH CERCIELLO: "Also Venmo or Zelle if that's easier."
MS. COMEY: And then what are the last two lines of this page, 719 and 720?
JOSEPH CERCIELLO: They are text messages between Jane and Kabrale Williams.
MS. COMEY: What does Jane say and what does Kabrale say?
JOSEPH CERCIELLO: "LMK when you're at airport." Kabrale Williams to Jane: "Be there soon, love."
MS. COMEY: Let's go to page 67 and look at line 722.
MS. COMEY: Are these texts between Sean Combs and Bridget Kreshover?
MS. COMEY: From the same date?
MS. COMEY: You read Sean. I'll read Bridget. Please start at 722.
JOSEPH CERCIELLO: "LOL. He couldn't even perform."
MS. COMEY: "I'm confused. Our agency provides time and companionship. You're paying for the gentleman's time."
JOSEPH CERCIELLO: "He's lucky he got that, but all good. You will have by tomorrow."
MS. COMEY: "It doesn't matter what happens on an appointment. You could go skydiving or dancing. The cost of the time is the same."
JOSEPH CERCIELLO: "Whoa. I'm not trying to be smart with you. I thought you would want to know how that felt. Talk nice to me pls because I always talk nice to you. Have a blessed day. Being that I'm a long-time customer. That's all. Don't get upset. Not that deep at all."
MS. COMEY: "Love, well, I'm not trying to be smart with you. I thought..."
JOSEPH CERCIELLO: "That's the best in NYC."
MS. COMEY: "I apologize if my tone came across as anything other than respectful. I didn't think you had made the mistake. I was under the impression that someone else handled that."
MS. COMEY: Let's go to the next page.
MS. COMEY: Looking at line -- at the line 731, Bridget continues: "Our agency has to dot every I and cross every T to make sure we stay within a specific guideline to be clear about what the agency offers and sells. Sometimes the formality of that feels rigid. It's not intended." And then down at line 733, what is the entry in line 733?
JOSEPH CERCIELLO: 9/18, 2023, 10:53 a.m., travel record, United Airlines, Atlanta to Newark airport for Kabrale Williams.
MS. COMEY: And then looking down at line 736, what are the -- and 737, what text messages does Sean Combs send to Bridget Kreshover?
JOSEPH CERCIELLO: "It's all good. All love. Sorry for any unnecessary stress. Anyone else in NYC. LOL."
MS. COMEY: Are the next lines between Jane and Kabrale?
MS. COMEY: I'll read Jane. You read Kabrale. "Room 508 under Pérez. Hit me when you land."
JOSEPH CERCIELLO: "Just landed, love."
MS. COMEY: "Great," exclamation point, exclamation point. "LMK your ETA once you are in the car."
JOSEPH CERCIELLO: "ETA 2:06 RN."
MS. COMEY: "OK. Perfect. We might be switching rooms at that time, so you might have to wait in lobby just for a second until I get the room number."
JOSEPH CERCIELLO: "OK. Got that."
MS. COMEY: Let's go to page 69, and let's look down, please, at line 758, toward the bottom.
MS. COMEY: What does Jane text Kabrale Williams at 3:57 p.m. on September 18?
JOSEPH CERCIELLO: "Room 510 under Pérez. No rush."
MS. COMEY: How does Kabrale respond?
JOSEPH CERCIELLO: "Fine. I'll come up in a second."
MS. COMEY: Let's go to page 70 and look at line 760.
MS. COMEY: Who does Jonathan Pérez text at 4:45 on September 18?
JOSEPH CERCIELLO: Faheem Muhammad.
MS. COMEY: What does he write?
JOSEPH CERCIELLO: "FYI. He's back in room with guest now. We about to feed him. We'll let you know if we hear of any more movement. I gave Dontray a key to his new room, 510."
MS. COMEY: And are the next few texts between Bridget and Mr. Combs?
MS. COMEY: I'll read Bridget and you read Mr. Combs. "Grant might be available."
JOSEPH CERCIELLO: "Who's that?"
MS. COMEY: Sends a photograph.
JOSEPH CERCIELLO: Disliked an image.
MS. COMEY: And then what does Jane send at row 765?
JOSEPH CERCIELLO: Jane sends a text message to Kabrale Williams: "Hey, hun. We stepped out for some air real quick."
MS. COMEY: At what time does Jane send that message to Kabrale?
JOSEPH CERCIELLO: 2:20:18 a.m.
MS. COMEY: And how much time passed between the prior page -- we can go back to if you want -- when Kabrale Williams said "coming up" and "come up in a sec" in line 759 and that next text that we saw from Jane?
JOSEPH CERCIELLO: Sorry. Can you go back to the other time?
MS. COMEY: So from 759 --
JOSEPH CERCIELLO: About ten hours. I'm sorry. Yeah, about ten hours.
MS. COMEY: Let's go now, please, to page 71. I'd like to look at line 770.
MS. COMEY: What time is this -- what date and time is this message?
JOSEPH CERCIELLO: 9/19, 20 -- I'm sorry. 770?
MS. COMEY: Yes, line 770.
JOSEPH CERCIELLO: Sorry. 9/19, 2023, 7:50 a.m.
MS. COMEY: And what do we see in this row?
JOSEPH CERCIELLO: It's a text message.
MS. COMEY: From who to whom?
JOSEPH CERCIELLO: Richie Nektalov to Brendan Paul, AY Rafi drip NY. Frank Rodriguez and Ashley Nektalov.
MS. COMEY: What's the content?
JOSEPH CERCIELLO: "Good morning. Please send us location so we can determine what time a nurse could make it out to you guys. Please provide all three patients' names with age and what type of bag they would like."
MS. COMEY: Let's go to page 72 at line 772, please.
MS. COMEY: And is this a continuation of the same group chat?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: What does AY text the group on line 772?
JOSEPH CERCIELLO: "Also are we doing the same IV on all 3?"
MS. COMEY: And what does Brendan Paul text the group in the next line?
JOSEPH CERCIELLO: "Sounds good. I'm going to him now. Keep y'all posted. All IVs would e the same."
MS. COMEY: Let's go to page 73, please, line 776.
MS. COMEY: What is this entry?
JOSEPH CERCIELLO: A text message from Jane to Kabrale.
MS. COMEY: At what time?
JOSEPH CERCIELLO: 11:59:01 a.m.
MS. COMEY: And what does Jane text Kabrale at that time?
JOSEPH CERCIELLO: "Hi. LOL. OMG. You're awake. The Whitby Hotel."
MS. COMEY: Let's continue reading. I'll read Jane. You read Kabrale. You can go ahead with line 777.
JOSEPH CERCIELLO: "LOL. Yes, I am."
MS. COMEY: "I'm going to ask what the status of the cash is now. Hit you in a few."
JOSEPH CERCIELLO: "OK. Bet sounds good, my love. They tryna kick me out."
MS. COMEY: "What? Let me see now."
JOSEPH CERCIELLO: "They keep asking what's my check-out time. Lady said the check-out was 12."
MS. COMEY: "LMK when you head out because team might be there soon. Don't want them to intercept you."
JOSEPH CERCIELLO: "I just left out."
MS. COMEY: Your Honor, I understand that we now have a redacted version of this document available so that we can put it up on the public screen. So what I'll do now is I'll formally offer Government Exhibit 1407R publicly and ask that 1407 remain under seal, and we'll have Ms. Becker switch so that the public can see it.
THE COURT: OK. Very good.
MS. GERAGOS: No objection.
MS. COMEY: Taking down 1407, pulling up 1407R and going to page 74 of 1407R with the public screens on.
MS. COMEY: Looking at page 74, at row 786, at 12:47 p.m. on September 19, 2023, what does Jane text Kabrale?
JOSEPH CERCIELLO: "OK. Great. And LMK when you get your envelope. Just say to front desk there's an envelope for Williams."
MS. COMEY: And what does she write next?
JOSEPH CERCIELLO: "Any issues LMK."
MS. COMEY: Let's go down to line 794 at 1:20 p.m.
MS. COMEY: What does Jane text Kabrale at that time?
JOSEPH CERCIELLO: "Did you get envelope yet."
MS. COMEY: How does Kabrale respond?
JOSEPH CERCIELLO: "Yes, I just picked it up."
MS. COMEY: Let's go now, please, to page 75.
MS. COMEY: Is this the same group chat we saw in some earlier lines?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: Can you walk us through the three entries on this page, please?
JOSEPH CERCIELLO: "AY texts the group: "Any update?" Brendan Paul responds: "how soon can you get to the Whitby?" Brendan Paul: "He just asked."
MS. COMEY: Let's go now to page 77, and I'll ask you to walk us through the entries on this page.
JOSEPH CERCIELLO: Richie Nektalov: "Still three drips." Brendan Paul: "Two." Brendan Paul: "With extra Benadryl."
MS. COMEY: And now page 78, would you please walk us through the first two entries on that page?
JOSEPH CERCIELLO: From Richie: "Send please full names. I must enter it." Brendan Paul: "sean Combs, Jane."
MS. COMEY: Let's go now to page 81, please, and look at line 818.
MS. COMEY: Can you read for us what's in line 818?
JOSEPH CERCIELLO: It's a text message on 9/19, 2023, at 5:26 p.m. from AY to the group: "IV drip 1000ml sodium chloride." May need help with that other word.
MS. COMEY: You can skip over that word.
JOSEPH CERCIELLO: "B12, B complex, zinc, vitamin C, calcium, magnesium, amino acids, Toradol, glutathione. At night he gets extra magnesium sometimes as much as 1600mg. At night, he sometimes gets Benadryl 25mg."
(Continued on next page)
MS. COMEY: Let's go to page 82, please.
MS. COMEY: Can you just walk us through the last four lines of this section, lines 821, 822, 823 a 824 please.
JOSEPH CERCIELLO: 821, 9/19/2023 at 8:51 p.m. is a text message -- airline record -- sorry -- EWR to ATL. United Airlines, Kabrale Williams. Row 822, 9/19/2023 is a hotel record for Trump International Hotel, Trump International, New York, room 510, Jonathan Perez. Row 823, 9/21/2023, hotel records for the Whitby Hotel, Mr. Frank Black, room 703. And row 824 is 9/21/2023, travel records Greg Transportation, LAX flight B6323, Jane's house, Greg Transportation Service. Jane.
MS. COMEY: Let's look now at the next section after the gray bar. What date does the next section start?
JOSEPH CERCIELLO: 9/29/2023.
MS. COMEY: Let's go to the corresponding row in 1406.
Ms. Becker, would you pull up Government Exhibit 1406, page 14, row 37, please.
MS. COMEY: Is this the Miami date that we looked at earlier this morning that has two rows in 1406?
MS. COMEY: Do they fall between Jane's flight to Miami on September 24 and her flight from Miami on September 30?
MS. COMEY: And does the section of 1407 we're about to look at focus on the time around the September 30, 2023, date in row 37?
JOSEPH CERCIELLO: Yes, it does.
MS. COMEY: Let's go back to 1407, please. I'd like to look at line 827 at --
MS. COMEY: And what's the time zone for this section of the chart?
JOSEPH CERCIELLO: Eastern Standard Time.
MS. COMEY: Looking at September 29, 2023, at 10:01 p.m., who does Sean Combs attempt to call?
JOSEPH CERCIELLO: Donald James.
MS. COMEY: And then about half an hour later, what does Sean Combs text to Kristina Khorram?
JOSEPH CERCIELLO: "Fly Chelsea in. Get her a hotel."
MS. COMEY: Let's go to page 83, please, and look at line 829.
MS. COMEY: Who does Mr. Combs text in the next line?
JOSEPH CERCIELLO: Paul Arthur.
MS. COMEY: What does he text?
JOSEPH CERCIELLO: "How you king."
MS. COMEY: Let's read the next few. You read Mr. Combs. I'll read Paul Arthur.
"I'm good. Heading back to the U.S. today."
JOSEPH CERCIELLO: "Stop in Miami. LOL."
MS. COMEY: "How's Sunday?"
JOSEPH CERCIELLO: "Imma meet you in LA."
MS. COMEY: "Okay. Cool." After that, who does Mr. Combs text at 10:49 p.m. on September 29?
JOSEPH CERCIELLO: Kristina Khorram.
MS. COMEY: You read Mr. Combs. I'll Ms. Khorram.
JOSEPH CERCIELLO: "Did Jane book her flight."
MS. COMEY: "We have one on hold for her tomorrow. Let me know if we should book. Chelsea getting on a 10:00 a.m. flight."
JOSEPH CERCIELLO: "What's up with Jane leaving."
MS. COMEY: "We have a flight for Jane. She would have to leave house by 2:15 p.m. Let me know if we are good to lock that one in."
JOSEPH CERCIELLO: "Okay. Perfect."
MS. COMEY: And then who did Mr. Combs text in the next line at 12:11 a.m. on September 30, 2023?
JOSEPH CERCIELLO: Paul Arthur.
MS. COMEY: What does he write?
JOSEPH CERCIELLO: "Damn. Wish you were here."
MS. COMEY: And then how much time passes between row 843, the last text between Mr. Combs and Kristina Khorram, and row 845, the next text between them?
JOSEPH CERCIELLO: About four hours.
MS. COMEY: What does Mr. Combs text Ms. Khorram at about 4:06 a.m. on September 30?
JOSEPH CERCIELLO: "What's up."
MS. COMEY: Let's go to the next page, please.
MS. COMEY: Throughout this page, I would ask that you read Mr. Combs and I'll read Ms. Khorram. You can go ahead.
JOSEPH CERCIELLO: "What's up?" Question mark, question mark, question mark, question mark, question mark.
MS. COMEY: "Call me."
JOSEPH CERCIELLO: "Text me. What's wrong? I'm busy. What's wrong?"
MS. COMEY: "I'll just come talk to you when you get back to house then."
JOSEPH CERCIELLO: "Also Jane not leaving tomorrow. Got to get her a room. And I don't want to talk next. Text me. Hello. Why I playing?"
MS. COMEY: "Just please next time y'all decide to randomly leave when you're partying, you have to tell us. Like you can't just lave like that in the middle of a night in an Uber and lit with a guest. That is when bad shit can happen. You know this."
MS. COMEY: Let's go to page 85.
MS. COMEY: Pick it up at line 862. You read Mr. Combs.
JOSEPH CERCIELLO: "No, go to sleep."
MS. COMEY: "I didn't want to hit you with this while you were out, but it's not cool to do that cause it something were to happen, we would be fucked."
JOSEPH CERCIELLO: "All good."
MS. COMEY: "Puff, seriously, that is reckless."
JOSEPH CERCIELLO: "I love you to death but you have to stop."
MS. COMEY: Who does Mr. Combs text in the rest of the page?
JOSEPH CERCIELLO: Paul Arthur.
MS. COMEY: You read Mr. Combs. I'll read Paul Arthur.
JOSEPH CERCIELLO: "WYA."
MS. COMEY: "On board. Landing at JFK 4:00 p.m. I can be in Miami tonight."
JOSEPH CERCIELLO: "Come."
MS. COMEY: "Landing in Miami at 11:30 p.m."
JOSEPH CERCIELLO: "Imma have to meet you in LA. I forgot I got a show."
MS. COMEY: "LOL. Okay."
JOSEPH CERCIELLO: "You're more than welcome to chill at crib if you need some sun."
MS. COMEY: "Okay. How long will you be in Miami for?"
JOSEPH CERCIELLO: "Another week."
MS. COMEY: "Okay." And then does Mr. Combs text with Ms. Khorram?
MS. COMEY: You read Mr. Combs. I'll read Ms. Khorram.
JOSEPH CERCIELLO: "Can you see if the drip can come now, please. Hey, I told you to get that for hotel. Thank you. The Edition."
MS. COMEY: "Huh? Yes, Chelsea has a room at Edition for one night only because then she will move to house when Jane leaves." Then what does Mr. Combs text to Paul Arthur in the next two rows?
JOSEPH CERCIELLO: "Naw, come here. For sure. And I got parties when you land."
MS. COMEY: Let's continue with you reading as Mr. Combs and I'll read as Ms. Khorram.
JOSEPH CERCIELLO: "Send to the One."
MS. COMEY: "Sold out. This weekend is nuts."
JOSEPH CERCIELLO: And pls send maids up now. Do your best shortcake."
MS. COMEY: What does Paul Arthur text to Sean Combs?
JOSEPH CERCIELLO: "Bet I'll be there."
MS. COMEY: Then going to Ms. Khorram and Mr. Combs: "Only options for Chelsea were Edition king room or Mandarin Oriental Brickell."
MS. COMEY: Let's go to page 87.
MS. COMEY: And picking up with line 895, you read Mr. Combs. I'll read Ms. Khorram.
JOSEPH CERCIELLO: "You got this."
MS. COMEY: "We got the room though, for Chelsea. King room just for today. I'm confused."
JOSEPH CERCIELLO: "I need to get her a suite. Imma be over there. PLS rush maids up now so I can go to bed, please. Thank you very much."
MS. COMEY: "Oh, she can't come here?"
JOSEPH CERCIELLO: "KK, can you please just do what I say. Thank you very much."
MS. COMEY: "Yes. Sorry. Had done exactly what you asked. That's why I'm confused."
JOSEPH CERCIELLO: McClarity keep Chelsea at the Edition and figure out a one-bedroom suite for me and Jane somewhere else."
MS. COMEY: "Okay. So we are anceling Jane travel?"
JOSEPH CERCIELLO: "Yes."
MS. COMEY: Go to page 88.
MS. COMEY: What does Paul Arthur text Sean Combs at the top of this page?
JOSEPH CERCIELLO: "No worries. LA it is."
MS. COMEY: Then let's go down to line 914.
MS. COMEY: What does line 914 show?
JOSEPH CERCIELLO: It's a financial record from TriStar and a travel record for Jet Blue.
MS. COMEY: For what type of flight?
JOSEPH CERCIELLO: Miami to Los Angeles.
MS. COMEY: Who was the passenger?
JOSEPH CERCIELLO: Jane.
MS. COMEY: Before she left what did she send to Mr. Combs in the prior line, line 913?
JOSEPH CERCIELLO: From Jane to Sean Combs: "You were in a deep sleep. I didn't want to wake you. Thank you for loving on me fr head to toe. Cuddles, slow dancing and kissing me in the rain. I desire you. I will always want you all the time. I enjoyed our time together so much. I love you baby. Have a great show."
MS. COMEY: Then the bottom three messages from Joey Chavez to Faheem Muhammad, I'll read Joey. You read Faheem. "Let me know if we can get this money squared away. Don't think we'll be spending any more for a little bit bit."
JOSEPH CERCIELLO: "Total is $4,450."
MS. COMEY: "Correct."
MS. COMEY: OK. Now I want to go to a different section. Let's go up to page one of this document, please.
MS. COMEY: What's the first date of this first section?
JOSEPH CERCIELLO: 11/8/2021.
MS. COMEY: Let's look at the corresponding row in Government Exhibit 1406. Let's go to 1406, page 1, row 3, please.
MS. COMEY: Can you walk us through row 3, please, Agent?
JOSEPH CERCIELLO: The date range is 11/8/2021 to 11/10/2021. The location is the L'Ermitage hotel in Los Angeles, California. The name on the room is Pines, room 517. Under the names column, it's Jane, Combs, Kabrale, and Paul. For flight records, there's a flight record for Kabrale on 11/9 Delta flight from Atlanta to LAX. And on 11/11, Alaska Airlines flight from LAX to Atlanta. And then two financial transactions, one for Kabrale on 11/9, $900 Cash App/block payment from Jane to Williams "Sly Diggler" for flight. And another transaction for Paul on 11/9, 1K cash deposit into Arthur Fitness LLC account.
MS. COMEY: Let's go back to 1407, page 1, please.
1407-R, page 1. Thank you, Ms. Becker.
MS. COMEY: What is the time zone for this section of the chart?
JOSEPH CERCIELLO: Pacific Standard Time.
MS. COMEY: What is the first row?
JOSEPH CERCIELLO: A hotel record.
MS. COMEY: And like the other hotel records, does this one not have a time?
JOSEPH CERCIELLO: Correct.
MS. COMEY: So is it just at the beginning of the day?
MS. COMEY: Can you read for us the next text in line 2?
JOSEPH CERCIELLO: Line 2, it's a text from James Fountain, a/k/a J9, to Faheem Muhammad: "ASA. I grabbed 10K from safe for PD. I have it in my possession. I'll let you know when I hand it over."
MS. COMEY: What does Mr. Combs text to Faheem at 12:10 p.m. that same day?
JOSEPH CERCIELLO: "What time will I get the money?"
MS. COMEY: And how does Faheem respond?
JOSEPH CERCIELLO: "Right now sir."
MS. COMEY: And at 4:49 p.m., what does J9 text to Faheem?
JOSEPH CERCIELLO: "Gave PD the 10K."
MS. COMEY: Then looking at the next few lines, who are these texts between?
JOSEPH CERCIELLO: They are between Sean Combs and Jane.
MS. COMEY: I'll read Jane. You read Mr. Combs. You can go ahead and start at line 6.
JOSEPH CERCIELLO: "What you wanna do."
MS. COMEY: "Spend time w my favorite person. "These are my fav. "What do you wanna to do."
JOSEPH CERCIELLO: "Want me and Paul to stop by."
MS. COMEY: Unknown emojis. "I don't have all the things you like here...more than welcome to come, baby."
JOSEPH CERCIELLO: "So just us. "Wanna meet me at my house."
MS. COMEY: Let's turn now to the next line and continue reading: "Sure baby. "When?"
JOSEPH CERCIELLO: "I can't have Paul at my house."
MS. COMEY: Laughed at the previous message. "Yes, we know, baby. LOL. I don't mind my place. I just didn't grab a few things fr store that you like. Like...your drinks and stuff. I have oils etc. Normally have all that stuff." Who does Mr. Combs text at 11:24 p.m. in line 24?
JOSEPH CERCIELLO: Paul Arthur.
MS. COMEY: What does Mr. Combs write?
JOSEPH CERCIELLO: "You up? It's love."
MS. COMEY: How does Paul Arthur respond?
JOSEPH CERCIELLO: "Yeah."
MS. COMEY: Let's go now to the next page, please. Let's go, actually, down to page 5.
MS. COMEY: And looking at page 5, down at line 66, what does Sean Combs send to Paul Arthur?
JOSEPH CERCIELLO: An audio message.
MS. COMEY: Let's listen to Government Exhibit A-120-A please, Ms. Becker.
(Media played)
BY MS. COMEY:
MS. COMEY: About an hour after that voice message, who does Kabrale Williams text?
JOSEPH CERCIELLO: Jane.
MS. COMEY: What does he say?
JOSEPH CERCIELLO: "What's up, lovely? I fell asleep early."
MS. COMEY: Let's keep reading. I'll read Jane. You read Kabrale: "Hey, babe. You up? I'm free tmw. Is it crazy I fly out tmw...or today for you actually. I'm so horny. I need you."
JOSEPH CERCIELLO: "Yes, I am baby, and I'm most definitely down. I would love to see you."
MS. COMEY: "We need to have a convo first, baby. "I'm touching myself rn wyd."
MS. COMEY: Let's go to the next page.
JOSEPH CERCIELLO: "Okay, love. Want me to call you?"
MS. COMEY: "Yes, baby, pls. Jus call. Ft me. Are you solo. "Only FaceTime me if you're solo, pls..."
JOSEPH CERCIELLO: "Okay, baby."
MS. COMEY: "Okay. Send me your full name."
MS. COMEY: Let's pause.
MS. COMEY: How much time passed between the "okay, baby" text in line 84 and "okay, send me your full name" in line 85?
JOSEPH CERCIELLO: About 45 minutes.
MS. COMEY: Let's keep reading: "Babe, can I give you cash for your flight? Might be easier."
JOSEPH CERCIELLO: "Kabrale Williams."
MS. COMEY: "I'm a little drunk Rn. I might spell it wrong. LMK how much the total is rn."
JOSEPH CERCIELLO: "$713 it's saying rn."
MS. COMEY: "Is this number your Zelle."
JOSEPH CERCIELLO: "Naw I don't have Zelle just CashApp and Apple Pay."
MS. COMEY: Go to page 7, and let's go now down to line 104 and keep reading.
MS. COMEY: "What your Cash App. "What's."
JOSEPH CERCIELLO: "$Kabrale."
MS. COMEY: Jane to Sly Diggler: "Subject: flight. Total USD 900.00. Status: expired. Waiting on sender. "Send me your Venmo when you have it, babe."
JOSEPH CERCIELLO: "My Venmo is @slydiggler."
MS. COMEY: "Doing now."
MS. COMEY: Go to page 8.
JOSEPH CERCIELLO: "Bet baby."
MS. COMEY: "Bc it's 4 a.m. It's fucking with me bad. "Give me till 9 a.m. "Call me. "My bank is really F up. I have it all for you here. Can someone use their card for now for your ticket and I got you soon as you land. "Driver n all "Hotel. "I got you. "Just get to me. "Make it happen, baby need you...bad."
JOSEPH CERCIELLO: "Baby IDK if I'll make it this time."
MS. COMEY: "No. No. "You're coming. "Travel agent finally woke up." At what time does Jane send the message "travel agent finally woke up"?
JOSEPH CERCIELLO: 5:51:30 a.m.
MS. COMEY: "You up babe...still down to come?" One minute later, what does Kristina Khorram text to Sean Combs?
JOSEPH CERCIELLO: A phone number.
MS. COMEY: Let's look at the next page, please.
MS. COMEY: Looking down at line 129, does that same phone number then communicate with Mr. Combs' phone?
MS. COMEY: What's the name associated with that number?
JOSEPH CERCIELLO: Jessica Ruiz.
MS. COMEY: Before that text message, looking at the top, what does Jane text to Kabrale in line 127?
JOSEPH CERCIELLO: "Call me when you see this babe. She's ready to book you but just need to confirm with you. Hit me."
MS. COMEY: What does Kristina Khorram text to Sean Combs in the next line, three minutes later?
JOSEPH CERCIELLO: "Also if faster you can always just book the flight online or have them do and we can reimburse."
MS. COMEY: What does Jessica Ruiz text Sean Combs at 7:15 a.m.?
JOSEPH CERCIELLO: "Good morning. Jess here calling you back."
MS. COMEY: In the next audio message, can you read us the italicized text of what Mr. Combs sends to Jessica Ruiz?
JOSEPH CERCIELLO: "Okay. I'll call you in a second."
MS. COMEY: Down at line 132, is that an audio message that Mr. Combs sends to Kristina Khorram?
MS. COMEY: Let's play it. Please play GX-A-141-B.
(Media played)
BY MS. COMEY:
MS. COMEY: Let's go to page 10, please, and look at line 136. I'll read Kristina. You read Sean Combs. "FYI -- till they get there he sajd was more in the plastic target bag in the closet. "You good over there? "Are we extending room till tomorrow?"
JOSEPH CERCIELLO: "Yes."
MS. COMEY: "Okay cool. "Baby oil dropped outside the door." What does Jane text to Kabrale a few minutes later?
JOSEPH CERCIELLO: "Which flight can you get on today? My agent is on standby. LMK."
MS. COMEY: And then in the next two rows, are there audio messages?
MS. COMEY: Is the first from Sean Combs to Kristina Khorram and the second from Sean Combs to Jessica Ruiz?
MS. COMEY: Let's play them.
Ms. Becker, would you please play Government Exhibit A-141-C and then A-112-B.
(Media played)
BY MS. COMEY:
MS. COMEY: Looking at row 145, the same minute Mr. Combs sends that voice message to Jessica Ruiz, what does Jane text message to Kabrale Williams?
JOSEPH CERCIELLO: "What's your full name and DOB."
MS. COMEY: In line 147, what does Kabrale respond to Jane?
JOSEPH CERCIELLO: "Kabrale Williams."
MS. COMEY: Let's go to the next page please.
MS. COMEY: In line 148, does Kabrale send what appears to be his date of birth?
MS. COMEY: Down at line 151, at 10:23 a.m. does Jane send Sean Combs that same information Kabrale just sent her?
MS. COMEY: Then down at line 154, at 10:24 a.m., who does Sean Combs send that same information to?
JOSEPH CERCIELLO: Jessica Ruiz.
MS. COMEY: And then what does Jessica Ruiz respond on line 157 at 10:25 a.m.?
JOSEPH CERCIELLO: "Got it. One sec."
MS. COMEY: Let's go to page 123 please and look at line 158.
MS. COMEY: What does Jessica Ruiz send Sean Combs at 10:30 a.m.?
JOSEPH CERCIELLO: Want me to read it?
MS. COMEY: Yes, please.
JOSEPH CERCIELLO: "Here's two options. Delta one way. ATL at 3:49 p.m. LAX at 5:49 p.m. Biz class $1,150. Coach $674. Delta one way ATL at 4:59 p.m. LAX at 6:59 p.m. Prem. economy $784. Coach $594."
MS. COMEY: And then one minute later, does Mr. Combs send Ms. Ruiz an audio message?
MS. COMEY: Is the content of it one of the times listed in Jessica Ruiz's prior message?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: Which time?
JOSEPH CERCIELLO: 3:49.
MS. COMEY: And then down at row 163, what does Mr. Combs send to Jessica Ruiz just a couple minutes later?
JOSEPH CERCIELLO: An audio message.
MS. COMEY: Let's play that, please. Play Government Exhibit A-112-D.
(Media played)
BY MS. COMEY:
MS. COMEY: How does Jessica respond?
JOSEPH CERCIELLO: "Will do."
MS. COMEY: Let's go to page 13.
MS. COMEY: In the next two lines, what does Jane text to Kabrale?
JOSEPH CERCIELLO: "She's booking I'll forward soon as I get the details. "349."
MS. COMEY: Is that the same time that Sean Combs sent an audio message minutes earlier to Jessica Ruiz?
MS. COMEY: In line 168, at 10:47 a.m., what does Jessica Ruiz send to Sean Combs?
JOSEPH CERCIELLO: "Here's the flight."
MS. COMEY: What does she send that same minute in the next line?
JOSEPH CERCIELLO: A screenshot of the flight information.
MS. COMEY: Down at the bottom, just a couple minutes later, what are the two texts that Jane sends to Kabrale?
JOSEPH CERCIELLO: "You're set babe. LMK when you get to the airport??"
MS. COMEY: Let's go to page 14 and line 183, please
MS. COMEY: What does Kristina Khorram send to Sean Combs at 11:03 a.m. the same day?
JOSEPH CERCIELLO: "I ordered fruit plates, water, water pitcher, smoothies and ginger ale that will come from room service."
MS. COMEY: How does Mr. Combs respond?
JOSEPH CERCIELLO: He sends an audio message.
MS. COMEY: What's the text of that audio message?
JOSEPH CERCIELLO: "Where's my phone at though?"
MS. COMEY: Let's go to page 15, line 185.
MS. COMEY: How does Ms. Khorram respond?
JOSEPH CERCIELLO: "I have it sorry I'll have to bring to you -- took cause of the Guido text."
MS. COMEY: And then what does Kabrale text Jane in the next line?
JOSEPH CERCIELLO: "Okay babe finna head to the airport."
MS. COMEY: In line 187, is this an audio message from Sean Combs to Kristina Khorram?
MS. COMEY: Let's play that, please. Government Exhibit A-141-I.
(Media played)
MS. COMEY: Let's go now to line 189.
MS. COMEY: How does my Khorram respond to Mr. Combs?
JOSEPH CERCIELLO: "I think you should just say something urgent came up you have to deal with and can she do tomorrow instead -- instead of lying about leaving town. What do you think?"
MS. COMEY: How does Sean Combs respond?
JOSEPH CERCIELLO: He likes that message.
MS. COMEY: And then down at line 192, what does Kristina Khorram send to Sean Combs?
JOSEPH CERCIELLO: "Confirming I'm sending from me right? Not from your phone."
MS. COMEY: How does Sean Combs respond?
JOSEPH CERCIELLO: "Yes."
MS. COMEY: Up at the message we skipped in line 191, what does Kabrale text to Jane?
JOSEPH CERCIELLO: "At the airport love see you soon."
MS. COMEY: Let's go to page 16.
MS. COMEY: In line 194, how does Kristina Khorram respond to Sean Combs?
JOSEPH CERCIELLO: "Honestly I think she would want to hear direct from you, especially cause of how you left it last night...you could literally just text her the below Hey baby I'm sorry but something urgent came up today and I have to deal with it. Can I take you out to dinner tomorrow tonight instead? I'm sorry."
MS. COMEY: A few minutes later, what does Kabrale text to Jane?
JOSEPH CERCIELLO: "Just boarded I'll text you when I land."
MS. COMEY: What's in the next row, row 196?
JOSEPH CERCIELLO: A travel record from Atlanta to LAX for Kabrale Williams.
MS. COMEY: In the next row, what does Jessica Ruiz send to Sean Combs at 1:40 p.m.?
JOSEPH CERCIELLO: It's a hotel reservation for Kabrale Williams.
MS. COMEY: Who does Sean Combs send that same reservation to about 14 minutes later?
JOSEPH CERCIELLO: To Jane.
MS. COMEY: Let's go to page 17 and look at line 203.
MS. COMEY: Who does Jane send that same information to a few minutes later?
JOSEPH CERCIELLO: Kabrale Williams.
MS. COMEY: Could you read for us what's in the next two rows?
JOSEPH CERCIELLO: Row 204 is a text message from Guido to Sean Combs.
"Hey, it's Guido." 205 is a text message from Guido to Sean Combs: "You good?"
MS. COMEY: And then what does Sean Combs send to Kristina in the next line?
JOSEPH CERCIELLO: It's an audio message.
MS COMEY: Let's play it, please, Government Exhibit A-141-K.
(Audio played)
JOSEPH CERCIELLO: MS COMEY: Let's skip ahead now please to page 19, line 219.
MS. COMEY: What does Kristina Khorram send to Sean Combs at 4:10 p.m. on November 9?
JOSEPH CERCIELLO: It's a text message. "This is the list I sent Phil to bring.
"4 of those young coconuts.
"2 Alfred's iced vanilla lattes (whole milk extra syrup)
"7 bottles baby oil.
"7 bottles Astroglide
"his Apple TV
"Lana and."
MS COMEY: Let's go now to page 20 and look at lines 226 and 227.
MS. COMEY: Are those both audio messages that Mr. Combs sent to Ms. Khorram?
MS. COMEY: Same day at about 4:20 and 4:21 p.m.?
JOSEPH CERCIELLO: Correct.
MS COMEY: Let's play them. Ms. Becker, would you please play Government Exhibits C-621-B and C-621-C.
(Audio played)
MS. COMEY: How did Ms. Khorram respond in the same minute?
JOSEPH CERCIELLO: "Okay. Will have Phil grab the soup too. Head up. It will take him longer to get to you."
MS. COMEY: What did Mr. Combs write about 12 minutes later?
JOSEPH CERCIELLO: "Weed."
MS. COMEY: Then what did he send that same minute?
JOSEPH CERCIELLO: Audio message.
MS COMEY: Let's play it, please, Government Exhibit C-621-D.
(Audio played)
MS. COMEY: How does Ms. Khorram respond?
JOSEPH CERCIELLO: "Okay."
MS. COMEY: One minute later, does Mr. Combs send her another voice note?
JOSEPH CERCIELLO: Yes.
MS COMEY: Let's play it please, Government Exhibit A-141-Q.
(Audio played)
JOSEPH CERCIELLO: MS COMEY: Let's go to page 21 and look at line 233.
MS. COMEY: What's in this line?
JOSEPH CERCIELLO: It's a text message from James Fountain a/k/a J9 to Faheem Muhammad.
MS. COMEY: Is this just a few minutes after the voice note we heard where Mr. Combs was asking for $5,000?
MS. COMEY: What does J9 write to Faheem?
JOSEPH CERCIELLO: "ASA. I'm grabbing 5K out of the safe for PD taking it to his hotel room."
MS. COMEY: What does Kristina Khorram send to Sean Combs a few minutes later?
JOSEPH CERCIELLO: "Security on way with cash now."
MS. COMEY: After that, does Sean Combs send a voice note?
JOSEPH CERCIELLO: Yes.
MS COMEY: Let's listen to it, Government Exhibit A-141-R.
(Audio played)
MS. COMEY: Now I want to look down at row 239.
Is that an explicit video with a timestamp of 5:19 p.m.?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: The same day?
MS. COMEY: Let's look now at page 22, line 243. What does Jessica Ruiz text to Sean Combs?
JOSEPH CERCIELLO: "Had to change driver Rodney," and phone number.
MS. COMEY: Who does Jane send that same information to a couple minutes later?
JOSEPH CERCIELLO: Kabrale Williams.
MS. COMEY: Then down at line 246, what does Kabrale text to Jane?
JOSEPH CERCIELLO: "Okay bet love just landed."
MS. COMEY: What does he say next?
JOSEPH CERCIELLO: "OTW to you."
MS COMEY: Let's go to page 24 now, skip ahead, and look at line 266.
MS. COMEY: Who does Jane text at 7:12 p.m.?
JOSEPH CERCIELLO: Kabrale Williams.
MS. COMEY: What does she say?
JOSEPH CERCIELLO: "Room 517 last name is Pines."
MS. COMEY: How does he respond?
JOSEPH CERCIELLO: "Yeah, I got to go to the lobby.
MS. COMEY: What does he write next?
JOSEPH CERCIELLO: "Headed up."
MS. COMEY: What does Jane say?
JOSEPH CERCIELLO: "Okay."
MS. COMEY: What are the next four entries?
JOSEPH CERCIELLO: Those are explicit videos.
MS. COMEY: How long after Kabrale says "headed up," is the first -- is the first timestamp for the first of those videos?
JOSEPH CERCIELLO: About 45 minutes.
MS COMEY: Let's go to page 25, please and look at line 279.
MS. COMEY: What is in line 279?
JOSEPH CERCIELLO: It's a financial record JP Morgan.
MS. COMEY: And what does it show?
JOSEPH CERCIELLO: For Arthur Fitness LLC, $1,000.
MS. COMEY: Finally, let's go to page 26, and to wrap up to this section, can you tell us what we see on the last two lines of this section, 290 and 291?
JOSEPH CERCIELLO: It's a hotel record -- sorry. Row 290 is a hotel record L'Ermitage Beverly Hills, Phillip Pines Amex 3008.
And then row 291 are travel records from Ascot Travel and Alaska Airlines from LAX to ATL for Kabrale Williams.
MS. COMEY: Let's look now at the next section. What is the date of the next section, line 292?
JOSEPH CERCIELLO: 11/14/21.
MS. COMEY: What's the time zone?
JOSEPH CERCIELLO: Pacific Standard Time.
MS COMEY: Let's look at the corresponding row. Can we go to Government Exhibit 1406, page 2, row 4 please.
MS. COMEY: Looking at row 4, can you tell us what's in the date, location and names columns?
JOSEPH CERCIELLO: 11/13/2021 to 11/14/2021. Location is the Waldorf Astoria Beverly Hills. Names are Jane, Combs, and Paul.
MS COMEY: Let's go back to 1407, page 26, and look at line 292:
MS. COMEY: Looking at line 292, I'll read Kristina Khorram. You read Sean Combs.
"Checking in. What's your plan?
"What time are you going to be done with your current guest?
"Think you should be solo with the girls."
JOSEPH CERCIELLO: "I'll be there at 5."
MS. COMEY: "And then you will leave to the jet at 4:00 a.m. ... cool?
"They as they sold out so just trying to see if they can override it. No room is booked yet.
"And he's already packing the bags.
"So that will be ready wherever you go.
"We are still trying a few more options, update coming shortly."
Then in the next row, what does J9 text to Faheem at 5:23 p.m.?
JOSEPH CERCIELLO: "Just gave PD 10K out of safe."
MS. COMEY: We will continue reading. I'll read Ms. Khorram. You read Mr. Combs.
"Waldorf has a junior suite for $2,400. London sold out. L'Ermitage only has a regular room with double beds. Bel Air sold out. Edition can't do. 1 Hotel can't do.
"Maybourne $2,275. Library suite (used to be the montage) Waldorf has a junior suite for $2,400. London sold out. L'Ermitage only has a regular room with double beds. Bel Air sold out. Edition can't do. 1Hotel can't do. Think the Waldorf maybe.
"Thoughts?
"Should we book the Waldorf?
"Should we book the Waldorf?"
JOSEPH CERCIELLO: "Are you talking about because of the hotels or you mean for you to do?
MS. COMEY: "Fairmont in Century City Fairmont Gold Signature, 1br suite 975 sqr ft. $2,295.
"Do you want to lock one in?
"Do you want to lock one in?
"Okay cool, sending Joey ASAP."
JOSEPH CERCIELLO: "Okay. Is room ready now?"
MS. COMEY: "On with them now. Any minute. Joey is there to check in. And heard Jane on way to hotel too so he can drop bags and let her in."
JOSEPH CERCIELLO: "I'm on way. I really don't want them to know it's me. LOL. No unneeded charges."
MS. COMEY: "Okay. I would wait till at least Joey and Jane get in the room and then you go. So maybe like 20 min? So at least they are up in the room and stuff is too.
"Issue don't go yet.
"Issue don't go yet."
What does Jane send to Mr. Combs at 7:06 p.m.?
JOSEPH CERCIELLO: "Okay. Packing up my things and on way. I'll hit you when I'm five away."
MS. COMEY: What does Mr. Combs send to Ms. Khorram?
JOSEPH CERCIELLO: "I'm room. Thank you."
MS. COMEY: Then what does Mr. Combs send to Jane?
JOSEPH CERCIELLO: "Okay."
MS. COMEY: Then at 7:30 p.m., what does Ms. Khorram sends to Mr. Combs?
JOSEPH CERCIELLO: "Hotel called. Paul coming up."
MS. COMEY: Then in the same minute, what does she sends to Mr. Combs' other phone?
JOSEPH CERCIELLO: "Hotel called. Paul coming up."
MS. COMEY: What does Jane text to Mr. Combs in the next line?
JOSEPH CERCIELLO: "Baby I'm five min away."
MS. COMEY: Can you read line 332. How much longer -- or what time is line 332 text from Jane to Mr. Combs?
JOSEPH CERCIELLO: 5:58 a.m.
MS. COMEY: And how long is that after Ms. Khorram texted Sean Combs "hotel called Paul coming up" twice?
JOSEPH CERCIELLO: About 14 hours.
MS. COMEY: Can you read for us what Jane texted to Mr. Combs at 5:58 a.m.?
JOSEPH CERCIELLO: From Jane to Sean Combs: "Hey my love, I'm home. I had an incredible time with you, my baby. Have a beautiful day in Miami."
MS. COMEY: How many days later is the next text from Jane to Ms. Khorram?
JOSEPH CERCIELLO: Two days.
MS. COMEY: What does Jane text to Ms. Khorram in that row?
JOSEPH CERCIELLO: "Hey hun. Hope you're doing well. Sorry for this lat text. I think I'm having a bad comedown fr the week and I just want to make sure Sean is okay and not feeling bad. Just checking. TY good night."
MS. COMEY: Let's go to page 30. How does Ms. Khorram respond?
JOSEPH CERCIELLO: "Hi love. Aww, I'm sorry to hear that. Yeah, he's been good actually since we got here. He's been up and moving and in good -- in great spirits. Maybe try taking 5HTP, sometimes I know that helps people. Also trying to think of the other stuff that helps ... maybe like happy weed? To help with an upswing? Also I know like pure chocolate helps with something in your brain too. I'll see if there are any other tricks too. You might also just need extra sleep.
MS. COMEY: Let's go down now to the next section starting at line 337. What time zone this section in?
JOSEPH CERCIELLO: Pacific Standard Time.
MS. COMEY: What's the date of the first entry in this section?
JOSEPH CERCIELLO: 1/18/2023.
MS COMEY: Let's look at the corresponding row, and go to 1406, page 9, row 23, please.
MS. COMEY: Looking at row 23, could you walk us through what's in this row, please?
JOSEPH CERCIELLO: The date range is 1/20/2023 to 1/22/2023. The location is the London Hotel in Los Angeles, California, and the room 229 in the name of Chavez with damage. The names are Jane, Combs, Paul, Reggie, and Kabrale. There's flight records for Paul, 1/19 American Airlines flight from JFK to LAX.
Flight record for Reggie 1/20. Combs text Jane. "The flights is $420 and this is an overnight rate. You can Cash App the $420 for the flights and the $680. Total $1,100 Cowboys4Angels.
And a flight record for Kabrale 1/18, Spirit Airlines flight from LAS to SNA.
And then financial transactions for Paul on 1/24, $900 cash deposit.
On 1/25 a $600 cash deposit for Reggie, a Cash App screenshot.
And for Kabrale there are no records.
MS COMEY: Let's go back to 1407, page 30. And let's look at lines 337 and 338.
MS. COMEY: What are in those two lines?
JOSEPH CERCIELLO: Travel records.
MS. COMEY: Are those two of the travel records you just summarized for us?
MS. COMEY: What is the third entry in the section line 339?
JOSEPH CERCIELLO: It's a text message from Kabrale Williams to Jane.
MS. COMEY: Is that on January 19, 2023?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: What does he text Jane?
JOSEPH CERCIELLO: "What's up beautiful? I'm in LA till the 24th."
MS. COMEY: What's the next entry in line 340?
JOSEPH CERCIELLO: It's a hotel record for The London.
MS. COMEY: Is that another hotel record doesn't have a time?
JOSEPH CERCIELLO: Correct.
MS. COMEY: Could the time check-in be later on the 20th?
MS. COMEY: Let's go to page 31. Who does Combs send an audio message to?
JOSEPH CERCIELLO: To Jane.
MS COMEY: Let's play it, please, Government Exhibit A-159-B.
(Audio played)
MS. COMEY: How does Jane respond eight minutes later?
JOSEPH CERCIELLO: In a text message: "Yeah, it's a thumbs up but listen, the shopping online was taking too long. I've been super busy but I want to look cute for you PLS. Can I go into Nieman's with the budget today, and can Jun put on his file or however that works? Can I text Jun or someone? It's Friday. I want a have a pretty day with my man and have some fun later. We have a lot to celebrate as well."
MS. COMEY: Skipping down to line 344, does Mr. Combs send Jane another audio message?
JOSEPH CERCIELLO: Yes, he does.
MS COMEY: Let's play that A-159-C, please.
(Audio played)
MS. COMEY: How does Jane respond in the next row?
JOSEPH CERCIELLO: "Okay babe. The gifts were 7."
MS. COMEY: And what does Mr. Combs say in response?
JOSEPH CERCIELLO: "Where are the gifts at?"
MS. COMEY: What does Jane say?
JOSEPH CERCIELLO: "Returned them remember."
MS. COMEY: What does Mr. Combs say?
JOSEPH CERCIELLO: "Okay."
MS. COMEY: And what does Jane say?
JOSEPH CERCIELLO: "You said I could just get some other things. You didn't like them on me."
MS COMEY: Let's go to page 32 and look at line 350.
MS. COMEY: Who text messages Jane at 10:33 a.m.?
JOSEPH CERCIELLO: Kristina Khorram.
MS. COMEY: What does she write?
JOSEPH CERCIELLO: "Hi. Happy Friday. Can you send me your account info, please."
MS. COMEY: In the next three lines, how does Jane summoned?
JOSEPH CERCIELLO: "Hey love. Happy Friday. Yes, Bank of America, Jane" with account number and routing number.
MS COMEY: Let's look at line 357.
MS. COMEY: Who does Mr. Combs text at 10:41 a.m.?
JOSEPH CERCIELLO: Bridget Kreshover.
MS. COMEY: What does Mr. Combs write?
JOSEPH CERCIELLO: "Hello. Is Vegas available today?"
MS. COMEY: Then down at line -- let's go to Jane -- in the next text, what does Jane write?
JOSEPH CERCIELLO: "Okay. LOL."
MS. COMEY: Then what does she write?
JOSEPH CERCIELLO: "Want to send one of the guys here to drop everything off?"
MS. COMEY: How does Mr. Combs respond?
JOSEPH CERCIELLO: "I don't want them to know."
MS. COMEY: Let's go page 33. Looking at line 361, what does Bridget Kreshover text to Sean Combs?
JOSEPH CERCIELLO: "He's available." And then photos of Southwest Airlines flight itineraries.
MS. COMEY: Is this a text exchange that you and I read on Friday between Ms. Kreshover and Mr.Sean Combs in a separate exhibit?
JOSEPH CERCIELLO: Yes, it is.
MS COMEY: Let's skip ahead then to page 34, and look at line 376.
MS. COMEY: Line 376 at 12:44 p.m., who does Mr. Combs text?
JOSEPH CERCIELLO: Jane.
MS. COMEY: Is he sending the content of a text from Bridget just a couple minutes earlier up in line 373?
MS. COMEY: And then does Jane like Mr. Combs' text?
JOSEPH CERCIELLO: Yeah, she does.
MS. COMEY: Does he send Jane an audio message?
JOSEPH CERCIELLO: Yes.
MS COMEY: Let's play it, Government Exhibit A-159-G, please.
(Audio played)
MS. COMEY: Then one minute later, in line 380, what is the record in that line?
JOSEPH CERCIELLO: It's a financial record, Cash App from Jane to C4A. It's titled: "Meeting paid out U.S. dollars $1,100."
MS. COMEY: In the next line, does Jane send Sean Combs a screenshot?
MS. COMEY: In the next line 382, what does she text to Mr. Combs?
JOSEPH CERCIELLO: "Send this as proof of payment."
MS. COMEY: Then looking at lines 383 and 384. In 383 who is texting Mr. Combs?
JOSEPH CERCIELLO: Bridget Kreshover.
MS. COMEY: Who does Mr. Combs text in the very next line?
JOSEPH CERCIELLO: Paul Arthur.
MS. COMEY: What does Mr. Combs text to Paul Arthur?
JOSEPH CERCIELLO: "You in LA?"
MS COMEY: Let's go to page 35.
MS. COMEY: What do Paul and Mr. Combs write in the next three lines? Would you read them for us, please.
JOSEPH CERCIELLO: Paul Arthur to Sean Combs: "Yes. Cool Ima hit you later. Cool."
MS. COMEY: Then for the rest of this page, is this a continuation of the text messages between Bridget and Mr. Combs that you and I read on Friday?
JOSEPH CERCIELLO: Yes.
MS COMEY: Let's go to page 36, please.
MS. COMEY: Let's look at line 402. At 6:07 p.m., what does Mr. Combs send to Paul Arthur?
JOSEPH CERCIELLO: It's an audio message.
MS COMEY: Let's play it, Government Exhibit A-159-I.
(Audio played)
MS. COMEY: Two lines down, who does Mr. Combs send an audio message to three minutes later?
JOSEPH CERCIELLO: Joey Chavez.
MS COMEY: Let's play that Government Exhibit A-210-A-5.
(Audio played)
JOSEPH CERCIELLO: MS COMEY: Let's go ahead to page 37 now, please.
MS. COMEY: And look at line 410. Is this an audio message that Mr. Combs sends to Ms. Khorram?
MS. COMEY: Let's play A-159-I or J. Excuse me, J.
(Audio played)
MS. COMEY: Then in the next line, does Bridget Kreshover text Sean Combs "he's reaching out"?
MS. COMEY: Then what does Ms. Khorram text Sean Combs in the next line?
JOSEPH CERCIELLO: "Yes. I will send to Joey and have him come up."
MS. COMEY: Then what does Mr.Sean Combs text to Jane a few minutes later?
JOSEPH CERCIELLO: "Paul gonna meet us at 9:30."
MS COMEY: Let's go ahead to page 38 now, please.
MS. COMEY: Looking at page 38, who does Mr. Combs send an audio message to in 419?
JOSEPH CERCIELLO: Sean Combs to Kristina Khorram.
MS COMEY: Let's play that. Let's play Government Exhibit A-159-O please.
(Audio Played)
MS. COMEY: And then down at line 423, who does Mr. Combs send an audio message to?
JOSEPH CERCIELLO: Frank Rodriguez.
MS COMEY: Let's play that, Government Exhibit A-159-Q.
(Audio message)
MS. COMEY: How does Frank respond?
JOSEPH CERCIELLO: "Yes, sir. I will have everything you need."
MS COMEY: Let's go to page 39, please.
MS. COMEY: Looking at lines 427 and 428, what does Frank Rodriguez send to Sean Combs at 7:31 and 7:32 p.m.?
JOSEPH CERCIELLO: "Medical grade K. MDMA. Purple and black pen. 2CB pill. Orange and blue box. DMT pen. 3/4 puffs. Do you need cash for tonight?"
MS. COMEY: Over the next few lines, is Mr.Sean Combs texting with Jane?
MS. COMEY: Let's go line 440. Who does he text with at line 440?
JOSEPH CERCIELLO: Paul Arthur.
MS. COMEY: What does Paul Arthur say?
JOSEPH CERCIELLO: "Which spot?"
MS. COMEY: How does Mr. Combs respond?
JOSEPH CERCIELLO: "The London."
MS COMEY: Let's go to page 40.
MS. COMEY: Does this have a text message between Mr. Combs and Paul Arthur, part of which we read on Friday?
JOSEPH CERCIELLO: Yes.
MS COMEY: Let's go to page 41 and look at line 460.
MS. COMEY: What record is in line 460?
JOSEPH CERCIELLO: It's a travel record, Southwest Airlines, Las Vegas to LAX. Michael Ejiawoko.
MS. COMEY: Is that one of the travel records you read for us from the other chart a bit ago?
MS. COMEY: Look at line 463.
Does this begin a text message exchange between Reggie and Sean Combs?
JOSEPH CERCIELLO: Yes, it does.
MS. COMEY: Let's go ahead and read these. I'll read Reggie. You read Sean Combs.
"Hey, this is Reggie. Just letting you know we are taking off now. Flight time is 40 mins."
Then does Frank send a text Sean Combs: "I'm outside"?
MS. COMEY: Then let's continue reading. You can read Mr. Combs.
JOSEPH CERCIELLO: "No prob. Around 3:30. We up all night and day. All good."
MS. COMEY: "I land in 15 mins. You want me to wait until 3:30"?
JOSEPH CERCIELLO: "Cool."
MS. COMEY: "I'm 20 min away."
JOSEPH CERCIELLO: "Hit me when you get to the hotel."
MS COMEY: Let's go to page 42.
MS. COMEY: "Okay. I'm here." What time does he text "I'm here"?
JOSEPH CERCIELLO: 2:25:51 a.m.
MS COMEY: Let's skip ahead to page 43, please.
MS. COMEY: Is this a continuation of the same conversation?
MS. COMEY: I'll read Reggie.
"Ten minutes."
JOSEPH CERCIELLO: "Okay, meet at London in 30. We ready."
MS. COMEY: "Okay."
JOSEPH CERCIELLO: "Room 229. Yes Rodriguez."
MS. COMEY: "Okay."
Then what time is that last text in line 486?
JOSEPH CERCIELLO: 4:56:56 a.m.
MS. COMEY: How much time passes between that and the next text in line 487?
JOSEPH CERCIELLO: About four hours.
MS. COMEY: Who does Jane text at 8:17 a.m.?
JOSEPH CERCIELLO: Kabrale Williams.
MS. COMEY: What does she write?
JOSEPH CERCIELLO: .Hey. Good morning. You are in town. Are you awake?"
MS. COMEY: Then about ten minutes later, who does Sean Combs text?
JOSEPH CERCIELLO: Paul Arthur.
MS. COMEY: What does Mr. Combs text?
JOSEPH CERCIELLO: "Wyd."
MS. COMEY: Then at 8:33 a.m., what does Jane text to Kabrale?
JOSEPH CERCIELLO: "London Hotel. LMK when you're on the way, I'll give you the info."
MS. COMEY: How does Kabrale respond?
JOSEPH CERCIELLO: "Okay bet love I'll be OTW in about 30 mins."
MS. COMEY: Let's go to page 44, and look at line 492. At 9:13 a.m., on January 21, what does Frank Rodriguez send to Sean Combs?
JOSEPH CERCIELLO: It's a photograph.
MS. COMEY: What does Frank Rodriguez text to Sean Combs a few minutes later?
JOSEPH CERCIELLO: "No more blue ones."
MS. COMEY: Let's go to page 45 and look at lines 495 and 496. At 9:16, what does Frank text to Sean Combs?
JOSEPH CERCIELLO: Another photo.
MS. COMEY: What does Frank text that same minute to Sean Combs?
JOSEPH CERCIELLO: "Only this left of blues."
MS. COMEY: And then going down to line 499, what does Jane text to Kabrale?
JOSEPH CERCIELLO: "Have them call Rodriguez 229."
MS. COMEY: Then at line 501 at 9:31 a.m., what does Frank Rodriguez text to Sean Combs?
JOSEPH CERCIELLO: "I'm outside."
MS. COMEY: How much time passes between that line in 501 and then line 502?
JOSEPH CERCIELLO: About 15 minutes.
MS. COMEY: Who texts Jane at that point?
JOSEPH CERCIELLO: Kabrale Williams.
MS. COMEY: What does Kabrale Williams text Jane?
JOSEPH CERCIELLO: "Coming up love."
MS. COMEY: Let's go to page 46 and look at line 506.
Is this a flight for Michael Ejiawoko?
MS. COMEY: And then line 507 at 11:17 a.m., what does Paul Arthur text to Sean Combs?
JOSEPH CERCIELLO: "Home."
MS. COMEY: Then let's go to page 47, line 521. Can you tell us what's in this row?
JOSEPH CERCIELLO: This is a hotel record for The London. The content is the London, Joseph Chavez damaged furniture.
MS. COMEY: Let's go now to page 48. What are the last three lines of this section of the chart?
JOSEPH CERCIELLO: Row 522 is a travel record Spirit Airlines, SNA to LAS in the name of Kabrale Williams.
Row 523 is a financial record Arthur Fitness LLC $900.
And another financial record in row 524, Arthur Fitness $600.
MS COMEY: Let's go to the second to last of these date ranges, page 89, please, Ms. Becker.
MS. COMEY: What is the time zone for this section of the chart?
JOSEPH CERCIELLO: 10/16/2023.
MS. COMEY: What's the time zone?
JOSEPH CERCIELLO: Sorry. Pacific Standard Time.
MS. COMEY: And you answered my next question. What's the first date of this section?
JOSEPH CERCIELLO: 10/16/2023.
MS COMEY: Let's look at the corresponding row in 1406. Can we please go to page 38 of 1406.
MS. COMEY: What's the date? Page 16, line 38. What's the date range for line 38?
JOSEPH CERCIELLO: 10/17/2023 to 10/18/2023.
MS. COMEY: Walk us through this row.
JOSEPH CERCIELLO: Location L'Ermitage Hotel, Los Angeles, California. The names for this row are Jane, Combs, Rico and Paul. Flight records for Rico. Bridget Kreshover texts Combs. "He's coming from Vegas, so he can do a minimum of four hour. Appointment rate $1,450.
Financial records for Paul. On 10/18, $260 Zelle payment from Arthur to Collins Productions LLC.
And on 10/30, $3,000 cash deposit into Arthur Fitness account.
MS. COMEY: Is this the last row in this chart before the Ventura lawsuit was filed?
JOSEPH CERCIELLO: Yes.
MS COMEY: Let's go back to Government Exhibit 1407, page 89, please. 1407-R. I'm sorry, Ms. Becker.
MS. COMEY: Who is Mr. Combs texting with at the beginning of this chart?
JOSEPH CERCIELLO: Jane.
MS. COMEY: I will read Jane. You read Mr. Combs.
"I don't want to be fucked and mistreated. I don't feel like performing loveless cold sex."
JOSEPH CERCIELLO: "I don't want to. Chill 4 real. Your detective skills got your mind going crazy."
MS. COMEY: "I'm not a porn star. I'm not an animal. I need a break. I don't want to do anything. I've hit a wall."
JOSEPH CERCIELLO: "I'll make only love to you."
MS. COMEY: "It's been three years of me having to fuck strangers. I'm tired."
JOSEPH CERCIELLO: "So we're breaking up?"
MS. COMEY: "My spirit and my soul is tired. I need a break mentally and spiritually."
JOSEPH CERCIELLO: "You wrong."
MS. COMEY: "Sex is sacred to me, and I can't be used like this any more. I just wanted to make you happy, but it's creating a war inside me. I need a break. I can't be in another hotel room doing drugs and performing exhausted for days. Brain fog and can't concentrate."
JOSEPH CERCIELLO: "I don't want that for you."
MS. COMEY: "I need a break."
JOSEPH CERCIELLO: "Let's spend the day. Just me and you. No strangers. Please. It's my only day off."
MS. COMEY: "It's loveless for me. And nothing satisfies you, and you always push me to do more and more."
JOSEPH CERCIELLO: "Let me make love do you. It's filled with love."
MS. COMEY: "Spend the day with your family or Gina. I need time to myself."
JOSEPH CERCIELLO: No. I wanna see you. We don't have to have sex. I want to spend the day with you. Please."
MS. COMEY: "You beat the love out of us. You make it crystal clear exactly what you want me for. The proof is in each and all of our experiences. You're going to spend the day what lovebombing me? So you can get what you want? It's not genuine. I've hit a mental and spiritual wall. I'm built for love. I'm not built for this. I'm tired. I need a break please call someone else."
JOSEPH CERCIELLO: "I said we don't have to have srx. Let me love on you. Baby please. I was sleep."
MS. COMEY: "I'm not trying to fuck strangers to fulfill your fetishes."
JOSEPH CERCIELLO: "You got it all the wrong."
MS. COMEY: "You talk to me and treat me like a piece of animal anyone can fuck on."
JOSEPH CERCIELLO: "You're crazy."
MS. COMEY: "I need a break please respect that."
JOSEPH CERCIELLO: "When do I talk to you crazy?"
MS. COMEY: "You want to have me suck some dick so you can jet off to an island with Gina or Yung. And have me do the dirty shit in hotel room after hotel room."
JOSEPH CERCIELLO: "Baby call me cause you tripping."
MS. COMEY: "I'm mentally and spiritually drained. This is hurting my entire being."
JOSEPH CERCIELLO: "Imma leave you alone."
MS. COMEY: "And then you jet off and take every other women on trips and dates and just make me the one to do the dirty shit. I'm tired."
Let's go ahead now please to page 94, and look at line 992.
Is this a continuation of the conversation between Mr. Combs and Jane?
JOSEPH CERCIELLO: It is.
MS. COMEY: You read Mr. Combs. I'll read Jane.
JOSEPH CERCIELLO: "Are you going to let me in our house? Are you going to let me in our house? Are you going to let me in our house? Are you going to let me in our house?"
MS. COMEY: "I just put child to bed. I had my phone on silent. She needed a room about because she was in town. Wtf kind of lame ass lie is that?"
One minute later, who does Jonathan Perez text?
JOSEPH CERCIELLO: Brendan Paul, Joey Chavez, Frank Rodriguez and Kristina Khorram.
MS. COMEY: What does Mr. Perez text to that group?
JOSEPH CERCIELLO: "Me and security headed to pick up guest from The Edition and then come back to Mapleton."
MS. COMEY: Let's go now please to -- in the rest of the page, is Brendan Paul texting with Jonathan Perez?
MS. COMEY: I'll read Brendan Paul. You read Jan Perez.
"Baby KK told me head out. They don't want me to see the that girl, clearly. Second she got the plot from Puff, she told me exit. LOL."
JOSEPH CERCIELLO: "Huh. This has nothing to do with you. Promise."
MS. COMEY: Can you read the top line.
JOSEPH CERCIELLO: "KK didn't even know what was going on."
MS. COMEY: Then does Jonathan Perez text the same group we saw on the prior page?
MS. COMEY: Would you please read the next two text he writes?
JOSEPH CERCIELLO: "PD and guest in master. He's about to KO.
"EOD end of day report 10/16. PD with guest Satchel-Maybach. Bose speakers - office. Garage soundbox - garage. PD phones - red with PD, yellow with KK, green in car. Music laptop - charging office. Big laptop - Office. Large iPad - Office. Content iPad - Office. Apple watch - charging office. Blue tooth-1 in PD. Pack reading glasses - one w PD, 1 in satchel, 2 in Goyard, 1 packed, 1 with PD. Lumen - goyard. Excite - charging."
MS. COMEY: Let's go to page 96, please, and look at line 1014.
Who sends a text to Sean Combs at 9:46 the next morning?
JOSEPH CERCIELLO: Gina 2023.
MS. COMEY: What does she text to Mr. Combs?
JOSEPH CERCIELLO: "I'm ready for the car babe."
MS. COMEY: Let's go now to page 98, please. Let's look at line 1023. Is that is this from that same morning?
MS. COMEY: What does Sean Combs text to Jane less than an hour after the text we just read from Gina?
JOSEPH CERCIELLO: "I'm so stressed. Too much going on. And on top of that I'm horny as fuck." Fuck with numerous C's and K's.
MS. COMEY: What does he write next?
JOSEPH CERCIELLO: "SMH."
MS. COMEY: How does Jane respond?
JOSEPH CERCIELLO: "Just breathe and take things one step at a body. Your body wants you to take it easy."
MS. COMEY: Let's skip to page 99 and line 1032. Who does Brendan Paul text at 1:51 p.m. that same day?
JOSEPH CERCIELLO: He texts Brendan Paul, Joey Chavez Frank Rodriguez and Kristina Khorram.
MS. COMEY: What does Brendan text that group at 1:51 p.m.?
JOSEPH CERCIELLO: "Jane on her way to Mapleton."
MS. COMEY: What does Jane write to Combs in the next two lines?
JOSEPH CERCIELLO: "Hey, driving down since it almost at Mapleton. Hi I'm here."
MS. COMEY: How does Mr. Combs respond in line 1035?
JOSEPH CERCIELLO: "In my room."
MS. COMEY: How long after that text is the next text from Sean Combs in the chart at line 1036?
JOSEPH CERCIELLO: About two hours.
MS. COMEY: Who does he text?
JOSEPH CERCIELLO: Sean Combs to Bridget Kreshover.
MS. COMEY: You read Mr. Combs. I'll read Bridget.
JOSEPH CERCIELLO: "Hey. I'm in LA. Is the same person available today from last time?"
MS. COMEY: "Hey last time in LA? Mayson right?"
Bridget sends a photo to Sean Combs.
JOSEPH CERCIELLO: "Yes".
MS. COMEY: "Okay. Let me see. What time?"
JOSEPH CERCIELLO: "11:30."
MS. COMEY: "I'm waiting for his response. He's coming from Vegas so he can do a minimum of four hour. Appt rate $1,450."
JOSEPH CERCIELLO: "Hold up. I thought he was here."
MS. COMEY: "He's in Vegas rn. He goes between both."
JOSEPH CERCIELLO: "When is the latest I can let yo."
MS. COMEY: "5:30 p.m."
In the next line at 4:38 p.m., what does Brendan Paul text to Jonathan Perez?
JOSEPH CERCIELLO: "Four pairs of heels dropped off papi."
MS. COMEY: Let's continue reading Sean Combs and Bridget Kreshover's conversation. You reeled Combs. I'll read Kreshover.
JOSEPH CERCIELLO: "Okay. We'll be in bed hills. 11:30."
MS. COMEY: "Okay here's his number" and provides a phone number.
"You can coordinate."
Let's go now down to line 1060. Does Sean Combs then text the same number that Bridget Kreshover sent him in line 1055?
MS. COMEY: What's the name associated with that?
JOSEPH CERCIELLO: Rico Bozant, a/k/a Rico Luv.
MS. COMEY: You read Sean Combs. I'll Rico Bozant?
JOSEPH CERCIELLO: "Hey."
MS. COMEY: "Hey what's good. I fly back at 7:00 so I'll be able to make it at 11:30."
Then in the next line, 1063, who does Kristina Khorram text?
JOSEPH CERCIELLO: Brendan Paul, Joey Chavez, Frank Rodriguez and Jonathan Perez.
MS. COMEY: What does she write?
JOSEPH CERCIELLO: "Prepped for hotel. Jess booking now. Then Brendan please go and set up the hotel."
MS. COMEY: Let's look down at line 1070. What does Kristina Khorram send to the same group about an hour later?
JOSEPH CERCIELLO: "Hotel will be L'Ermitage. Brendan, you can go set up as soon as Jess locks it in."
MS. COMEY: Let's go to page 103 and look at line 1071.
How does Brendan respond in the next two texts?
JOSEPH CERCIELLO: "Almost done with prep. Room 517."
MS. COMEY: Let's go down to line 1079. What does Sean Combs text to Kristina Khorram at 9:34 p.m.?
JOSEPH CERCIELLO: "Don't have KT next to me. Cause of Jane."
MS. COMEY: Let's keep reading the conversation. I'll read Kristina Khorram. You read Sean Combs.
"She's in same section VIP is small. The VIP section super small is what I'm saying. KT is in here."
JOSEPH CERCIELLO: Disliked "The VIP section super small is what I'm saying."
"Get me my own section. The love section."
MS. COMEY: "It's open dance floor. Then only one section on the side. Unless you want to be in sound booth - no one is there."
Looking at line 1089, what does Jonathan text Faheem at 9:43 p.m.?
JOSEPH CERCIELLO: 10:03 p.m. ETA for me and guest.
MS. COMEY: Going down to line 1095, what does Jane text Combs at 10:07 p.m.?
JOSEPH CERCIELLO: "Hi baby I'm here."
MS. COMEY: Then looking ahead at page 105, please, and look at line 1099. What is in this row?
JOSEPH CERCIELLO: That's a photo of Sean Combs.
MS. COMEY: What's the source of that photo?
JOSEPH CERCIELLO: Jane's iCloud.
MS. COMEY: What's the time of that photo?
JOSEPH CERCIELLO: 10:23:25 p.m.
MS. COMEY: Let's go now to page 106, please, and look at line 1107. Who does Brendan Paul text at 11:03 p.m. that same night?
JOSEPH CERCIELLO: James Fountain a/k/a J9 and Dontray PD security.
MS. COMEY: What does Brendan write?
JOSEPH CERCIELLO: "Keep me posted on PD arrival. I have keys for y'all."
MS. COMEY: Then going down to line 1110, how does J9 respond to the group?
JOSEPH CERCIELLO: "What hotel?"
MS. COMEY: Then how does Brendan Paul respond to the group in the next three lines?
JOSEPH CERCIELLO: "9291 Burton Way, Beverly Hills, California, 90210, United States. L'Ermitage room 517. Edition?"
MS. COMEY: Is the last word you just read from Rico Bozant to Sean Combs?
JOSEPH CERCIELLO: Yes. Sorry.
MS. COMEY: Let's go to page 107 and look at line 1118.
On line 1118, what does J9 text to that same group at 11:18 p.m.?
JOSEPH CERCIELLO: "Three minutes out."
MS. COMEY: How does Brendan Paul respond?
JOSEPH CERCIELLO: "Coming down."
MS. COMEY: In the next two messages, what does Brendan Paul send to Jonathan Perez?
JOSEPH CERCIELLO: "Big drunk. PD asking how far out y'all are."
MS. COMEY: Looking down at line 1124, what does Brendan Paul text to Jonathan Perez at 11:27 p.m. the same night?
JOSEPH CERCIELLO: "He bugging she been there so long."
MS. COMEY: Let's go to page 108, and look at line 1127.
How does Jonathan Perez responds?
JOSEPH CERCIELLO: "What's wrong."
MS. COMEY: What does Brendan Paul write in the next two messages?
JOSEPH CERCIELLO: "He is tweaking. It took so long. Told me to go downstairs. She's still ten min out."
MS. COMEY: Now let's look down at lines 1134, 1135 and 1136.
Who does Sean Combs text in all of those lines?
JOSEPH CERCIELLO: Rico Bozant.
MS. COMEY: Would you read those three text, please?
JOSEPH CERCIELLO: "L'Ermitage Hotel. Let me know when you on way."
MS. COMEY: How does Rico respond?
JOSEPH CERCIELLO: "About to head out. I'll be there around 12:20."
MS. COMEY: Let's look at page 109 and go to line 1141.
What does Sean Combs send to Brendan Paul at 12:05 a.m. on 10/18?
JOSEPH CERCIELLO: It's an audio message.
MS COMEY: Let's play it, please, Government Exhibit A-168-B.
(Audio played)
MS. COMEY: How does Brendan Paul respond that same minute?
JOSEPH CERCIELLO: "517 - Brendan Paul."
MS. COMEY: What does Sean Combs send to Rico Bozant that same minute?
JOSEPH CERCIELLO: "Last name Paul. Room 517."
MS. COMEY: Let's go ahead now to page 110, and look at lines 1152, and 1153.
What does Rico Bozant text to Sean Combs at 12:23 and 12:24 a.m.?
JOSEPH CERCIELLO: "Here coming up. Can you call front desk. She said she doesn't have a Paul."
MS. COMEY: Let's look down at line 1158 on this same page.
Who does Sean Combs text at 2:04 a.m.?
JOSEPH CERCIELLO: Paul Arthur.
MS. COMEY: How long after Rico text "here coming up" in line 1152 did Combs text Paul Arthur in line 1158?
JOSEPH CERCIELLO: A little before two hours. Just about two hours.
MS. COMEY: What does Sean Combs text to Paul Arthur at 2:04 a.m.?
JOSEPH CERCIELLO: "King."
MS. COMEY: And then about six hours later, at 8:25 a.m., what does Sean Combs text to Paul Arthur on October 18?
JOSEPH CERCIELLO: "Yo, I think she's tapping out."
MS. COMEY: Let's go ahead now to page 111, please, and look at line 1162.
At 8:33 a.m., what does Sean Combs text to Paul Arthur?
JOSEPH CERCIELLO: "Yo. You up?"
MS. COMEY: Going down to line 1166, what does Sean Combs text to Paul Arthur?
JOSEPH CERCIELLO: "Room 517 under Paul."
MS. COMEY: How does Paul Arthur respond at 9:45 a.m. in line 1168?
JOSEPH CERCIELLO: "On my way."
MS. COMEY: Let's go to page 112, please.
What does Paul Arthur write at the top of the page?
JOSEPH CERCIELLO: "15 mins away."
MS. COMEY: How does Sean Combs respond?
JOSEPH CERCIELLO: "Okay."
(Continued on next page)
BY MS. COMEY:
MS. COMEY: Looking down now at line 1173, what does Brendan Paul text to Faheem Muhammad at 11:16 a.m. on October 18th?
JOSEPH CERCIELLO: "Extending hotel."
MS. COMEY: And then at 11:75, a couple of hours later, what does Kristina Khorram text to Faheem?
JOSEPH CERCIELLO: "Fah, PD ready to be picked up from the hotel."
MS. COMEY: Let's go now to page 113, line 1180, please.
MS. COMEY: What does Mr. Combs text to Kristina Khorram at 12:59 p.m.?
JOSEPH CERCIELLO: "I already took two Ambien. I'm night night."
MS. COMEY: What time does he send that message?
JOSEPH CERCIELLO: 12:59:13 p.m.
MS. COMEY: Let's go ahead now to page 115 and look at line 1194.
MS. COMEY: Through the end of this, I'll read Jane, and you read Mr. Combs.
On October 21, 2023, 7:28 a.m. -- so is this a few days later?
MS. COMEY: -- "You told me to tell you if I needed or wanted anything. I said yes. Then you just left. I text you about it and no word. Can you just make sure not to make me feel high and dry like that. I already did not want to do anything, and I did. Can you make sure they put something in my account, please? You have me feeling a little crazy and feeling used, like I got tricked into a party, and you're not communicating."
JOSEPH CERCIELLO: "How you today?"
MS. COMEY: Is that text you just read three days after the text I just read?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: "Doing good, HBU."
"Hey, I'm not going to lie. I still feel really upset with you and how everything played out. I just need some time to myself. I feel violated and manipulated by you. So if you need to make other arrangements with your stupid hoes for this week or weekend, I think you should do that."
And then what's the last entry in this section?
JOSEPH CERCIELLO: Row 1199, dated 10/30/2023, is a financial record — JP Morgan, $3,000, Arthur Fitness, LLC."
MS. COMEY: Finally, let's turn to the last section of this chart.
What is the time zone?
JOSEPH CERCIELLO: Pacific Standard Time.
MS. COMEY: What is the first date?
JOSEPH CERCIELLO: 6/18/2024.
MS. COMEY: Let's look at the corresponding row, and go to 1406, page 17, line 44. Oh, page 16, line 44.
MS. COMEY: Would you please walk us through line 44 of this entry?
JOSEPH CERCIELLO: The date range is 6/18/24 to 6/19/24.
The location is Jane residence in California.
The names are: Jane, Combs, and Anton, no flight records.
Financials for Combs.
6/19, Jonathan Perez texts Faheem Muhammad: "He's asking me to bring him his cash. He wasn't sure how much you were holding for him. He said he thinks ten."
On 6/20, Jonathan Perez texts Faheem Muhammad: "Hi Fah. Putting PD on this text with us. Need $3,500 cash ASAP for his guest. I'm going to take it to her."
MS. COMEY: Let's go back to Government Exhibit 1407, page 115, please.
I want to go ahead to 116, please.
MS. COMEY: Look at line 1205.
Who texts Jonathan Perez at 10:00 a.m. on June 18, 2024?
JOSEPH CERCIELLO: Kristina Khorram.
MS. COMEY: What does she write?
JOSEPH CERCIELLO: "Heads up, PD going to guest house tonight."
MS. COMEY: Let's go now to line 1208.
MS. COMEY: What does Jonathan --
MS. COMEY: I'm sorry, 1207.
MS. COMEY: What does Jonathan Perez write to Kristina Khorram?
JOSEPH CERCIELLO: "Copy."
MS. COMEY: And then line 1208, what does Jonathan Perez write to Faheem Muhammad?
JOSEPH CERCIELLO: "Hi Fah. We need 600 for Phil ASAP, please. We are out, and PD is about to go to Jane's house."
MS. COMEY: What does Faheem text to Bro Dontray in the next two lines?
JOSEPH CERCIELLO: "Bro, can you call Jonathan? He needs $600."
MS. COMEY: And then at 6:13 p.m., what does Jonathan Perez text to Faheem Muhammad and Kristina Khorram?
JOSEPH CERCIELLO: "Me and PD en route to Jane's house."
MS. COMEY: Let's look at page 117. Actually, can we take this down, turn off the public screens, and pull up the unredacted version so the jury can see the redacted pieces, please.
So going back to page 116 and -- actually, 117.
MS. COMEY: Looking in 117, are these photographs from Jane's iCloud?
JOSEPH CERCIELLO: Yes, they are.
MS. COMEY: What time does the metadata reflect?
JOSEPH CERCIELLO: 7:01:58 p.m.
MS. COMEY: And for the next row?
JOSEPH CERCIELLO: 7:03:38 p.m.
MS. COMEY: Let's go to page 118.
MS. COMEY: Are these two more photographs from Jane's iCloud?
MS. COMEY: What does the metadata reflect for row 1214?
JOSEPH CERCIELLO: 7:35:48 p.m.
MS. COMEY: How about 1215?
JOSEPH CERCIELLO: 8:31:10 p.m.
MS. COMEY: Let's go to page 119, please.
MS. COMEY: Is the top line another photograph from Jane's iCloud?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: What does the metadata show?
JOSEPH CERCIELLO: 8:34:34 p.m.
MS. COMEY: And then at 9:46 p.m. that same day, what does Jonathan Perez text to Faheem and Kristina?
JOSEPH CERCIELLO: "Heads up, him and guest are fighting. I'm about to head back and pick him up."
MS. COMEY: And then at 10:09 p.m., what does Kristina text to Jonathan?
JOSEPH CERCIELLO: "Hey, let us know if he actually ends up going home or ends up staying."
MS. COMEY: How does Jonathan respond?
JOSEPH CERCIELLO: He liked that message.
MS. COMEY: What does Jonathan text to Faheem and Kristina at 10:14 p.m.?
JOSEPH CERCIELLO: "Just the normal her being jealous over other women and yelling at him."
MS. COMEY: Let's go to page 120, please, and look at line 1221.
MS. COMEY: What does Jonathan then text to Faheem and Kristina a few minutes later?
JOSEPH CERCIELLO: "Just heard from him. He said not to come. All good."
MS. COMEY: Looking at lines 1222, 1223, and 1224, what is reflected in those lines?
JOSEPH CERCIELLO: Those are phone calls.
MS. COMEY: Between who and who?
JOSEPH CERCIELLO: Jane and Shamel Douglas, a/k/a Antoine.
MS. COMEY: What time are those three phone calls?
JOSEPH CERCIELLO: The first one is 4:17:19 a.m., the second one is 4:26:33 a.m., and the third one is 5:19:42 a.m.
MS. COMEY: How much time passes between the 5:19 a.m. call in line 1224 and the next entry in line 1225?
JOSEPH CERCIELLO: About four hours.
MS. COMEY: So at 9:22 a.m., what does Kristina Khorram text to Faheem and Jonathan?
JOSEPH CERCIELLO: "Hi. Can someone go pick up PD ASAP."
MS. COMEY: How does Jonathan respond at 9:28 a.m.?
JOSEPH CERCIELLO: "Fah, he's asking me to bring him his cash. Is at house? He wasn't sure how much you were holding for him. He said he thinks 10. Let me know. I'm going to head out shortly."
MS. COMEY: How did Faheem respond three minutes later?
JOSEPH CERCIELLO: "Robin never gave us the ash. She said it was too late. We left that day, but will get more dropped off today. We don't have more on hand, but tring to get more now."
MS. COMEY: Who does Jane call seven minutes later?
JOSEPH CERCIELLO: Shamel Douglas, a/k/a Antoine.
MS. COMEY: About two and a half hours later, what does Bro Dontray text to Faheem?
JOSEPH CERCIELLO: "Headed back to Mapleton."
MS. COMEY: What does Bro Dontray text to Faheem at 12:50 p.m.?
JOSEPH CERCIELLO: "Back at Mapleton."
MS. COMEY: Let's go to the next page, please.
MS. COMEY: At the top of the page, on June 19, 2024, at 4:49 p.m., what does Jonathan text to Faheem?
JOSEPH CERCIELLO: "Hi Fah. Do you have cash at the house that you can reimburse me with? $600 from yesterday, plus the attached receipts from the trip and today, total $1,254.89, or at least the $600, and I can submit others to Tri Star if I have to. Thank you."
MS. COMEY: In the next line, is the next entry the next day, on June 20, 2024?
MS. COMEY: Who does Jane call at 11:16 a.m. that day?
JOSEPH CERCIELLO: Shamel Douglas, a/k/a Antoine.
MS. COMEY: And less than an hour later, who does Faheem Muhammad text?
JOSEPH CERCIELLO: Marina at Tri Star.
MS. COMEY: What does he write?
JOSEPH CERCIELLO: "Hope all is well. Can we please pay the invoices from May 16th to the 31st? It's 1,571 and 1,572."
MS. COMEY: Let's keep reading. I'll read Marina; you read Faheem.
"Hi Faheem. All is well. Working on the cash request, and let me follow up on these two invoices for you."
JOSEPH CERCIELLO: "Okay. Please let me know."
"I also have a few reimbursements that I will send over shortly. Do you think you can make a check available? Also, the actual cash amount is $5,600, not $5,000. I forgot to include $600 cash request from the day before."
MS. COMEY: "Ugghhh, Faheem! Do you have these reimbursements ready to go? Cash request was sent to the bank already for 5K to be reimbursed to you and 15K for Mr. Combs. You will need to the difference on your reimbursed expense. Do you need to template?"
JOSEPH CERCIELLO: "We can wait on the reimbursement. I still have to put it all together, which make take another hour or so. Is it okay to pick up the 5K now?"
MS. COMEY: Go to page 122.
MS. COMEY: "Banking is working on the request. They haven't confirmed if it's ready to be picked up. Our banking coordinator will pick up the cash, and I'll have it ready for you at the office."
"Okay. Banking coordinator is headed to pick up the cash now. How soon will you be in the office?"
Now, looking at row 1241, a few hours later, what does Jonathan Perez text to Faheem?
JOSEPH CERCIELLO: "Hi Fah! Putting PD on this text with us. Need $3,500 cash ASAP for his guest. I'm going to take it to her. Let me know how to get it."
MS. COMEY: How does Faheem respond?
JOSEPH CERCIELLO: "Copy. I can give it to you now."
MS. COMEY: What does Jonathan Perez write?
JOSEPH CERCIELLO: "Can you leave it in an envelope with security, and I'll come grab it and will take to her. Thank you."
MS. COMEY: Later that day, at 7:04 p.m., who does Jane call?
JOSEPH CERCIELLO: Shamel Douglas, a/k/a Antoine.
MS. COMEY: Let's go to the next page.
MS. COMEY: And about 15 minutes later, what photo -- where does this photo come from?
JOSEPH CERCIELLO: Jane's iCloud.
MS. COMEY: Let's go to the next page.
MS. COMEY: Is this photo in line 1246 about one minute later?
MS. COMEY: And then row 1247, what's the date and time of that?
JOSEPH CERCIELLO: The date is 6/22/24, and the time is 3:38 p.m.
MS. COMEY: Is this a video from Jane's iCloud?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: Have you watched the video?
JOSEPH CERCIELLO: I have.
MS. COMEY: What injuries are visible on Jane in the video?
MS. GERAGOS: Objection.
THE COURT: Sustained.
BY MS. COMEY:
MS. COMEY: What, if anything, is observable about Jane in the photograph in this chart?
MS. GERAGOS: Objection.
THE COURT: Sustained.
BY MS. COMEY:
MS. COMEY: Does this show a clear image of her face?
JOSEPH CERCIELLO: Yes, it does.
MS. COMEY: Let's go to page 1248 -- line 1248.
MS. COMEY: What is the date of this?
JOSEPH CERCIELLO: 6/26/2024.
MS. COMEY: At what time?
JOSEPH CERCIELLO: 6:38 p.m.
MS. COMEY: What kind of file is this?
JOSEPH CERCIELLO: This is a video file.
MS. COMEY: And what is the source?
JOSEPH CERCIELLO: Jane's iCloud.
MS. COMEY: Is this from about a week after June 18, 2024?
JOSEPH CERCIELLO: Yes, it is.
MS. COMEY: No further questions, your Honor.
THE COURT: All right. Thank you, Ms. Comey.
Thank you, members of the jury. We'll take our break at this point and come back at 1:45 or thereabouts. Thank you very much.
As I've always told you, please don't have any communications with each other about the case or about anything having to do with the case. Otherwise, have a great lunch. We'll be back at 1:45.
All rise.
(Continued on next page)
(Jury not present)
(Witness temporarily excused)
THE COURT: Please be seated.
Anything further from the government before we break for lunch?
MS. COMEY: No, your Honor.
THE COURT: There was some good speed reading there.
MS. COMEY: I tried, your Honor.
THE COURT: Anything from the defense?
MR. AGNIFILO: No, your Honor. Thank you.
THE COURT: All right. Very good.
We'll be back at 1:45.
(Luncheon recess)
AFTERNOON SESSION 1:45 PM
(Trial resumed; jury not present)
MS. COMEY: No.
(Jury present)
THE COURT: Please be seated.
Ms. Geragos, you may proceed when ready.
MS. GERAGOS: Thank you, your Honor.
CROSS-EXAMINATION BY MS. GERAGOS:
MS. GERAGOS: Good afternoon, Special Agent.
JOSEPH CERCIELLO: Good afternoon.
MS. GERAGOS: At this time, your Honor, I would just like to correct the record as to one exhibit that I offered, which was 3206B. That does not exist, so I'd like to offer 3106-B under seal, please.
MS. COMEY: No objection, your Honor.
THE COURT: Under seal.
(Defendant's Exhibit 3106-B under seal received in evidence)
MS. GERAGOS: At this time, I'd like to offer 3051, 3070, 3127-A, 3172, all under seal, please.
MS. COMEY: No objection.
THE COURT: Those exhibits will be admitted under seal.
(Defendant's Exhibits 3051, 3070, 3127-A, and 3172 under seal received in evidence)
MS. GERAGOS: If we could pull up Government Exhibit 1304, which is a stipulation between the parties, and go to page 2, please.
If we could go to paragraph 9. This lists that Government Exhibits 4H — and I will read — 129 through 4H-133 and 4H-141 are true and accurate records from Tri Star Sports & Entertainment Group. So, at this time, I'd like to offer 4H-129, 4H-130, and 4H-141.
THE COURT: Any objection?
MS. COMEY: No objection.
THE COURT: Those exhibits will be admitted.
(Government's Exhibits 4H-129, 4H-130, and 4H-141 under seal received in evidence)
MS. GERAGOS: Can we go to page 10, please. And if we can blow up 63.
This lists that Government Exhibits 3P-101 to 3P-111, 3P-120 through 3P-122, are true and accurate records from Cowboys 4 Angels as registered fictitious name of Collins Productions. If we can unzoom out.
At this time, I'd like to offer 3P-105, 3P-107, 3P-121, and 3P-122.
MS. COMEY: No objection.
THE COURT: Those exhibits will be admitted.
(Government's Exhibits 3P-105, 3P-107, 3P-121, and 3P-122 received in evidence)
MS. GERAGOS: I think I should have said this: For the 4H- records that I moved in, I would have to offer them under seal and provide a redacted copy later.
THE COURT: All right, that's fine.
MS. GERAGOS: We can take that down.
Let's start. If we could bring up Government Exhibit 1408, please.
BY MS. GERAGOS:
MS. GERAGOS: Special Agent, do you remember looking at this earlier today, Government Exhibit 1408?
MS. GERAGOS: We looked at pretty much all of these records listed here in this page.
If we could look at lines 1 and 2. The accountholder for lines 1 and 2 under Jonathan Perez is Sean Combs, right?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: That's his personal name, right?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: And then for lines 3, 4, and 5, you listed the accountholder as Jessica Ruiz/CE Opco LLC.
Do you see that?
MS. GERAGOS: And then we had also looked at lines 8, 9, 10, 11, which were also listed with Jessica Ruiz/CE Opco LLC, right?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: And then we had --
MS. GERAGOS: If we could pull up -- out of an abundance of caution, can we shut off the screen, your Honor?
Thank you.
MS. GERAGOS: And we looked at 4A-150 at page 2974, and this was a payment for this credit card bill.
Do you remember that?
MS. GERAGOS: And we looked at the payments here that corresponded to those bills.
Do you remember that?
MS. GERAGOS: Could we, please, pull up what's under seal, but in evidence, 4H-141.
MS. GERAGOS: This is -- do you see at the top of this, this lists as CE Opco LLC invoice 1625?
MS. GERAGOS: And this lists as bill to Sean Combs?
MS. GERAGOS: It's his personal name, right?
MS. GERAGOS: And attention to accounts payable?
MS. GERAGOS: And it has the date of September 30, 2023?
MS. GERAGOS: And it lists, "Please pay $22,825.73"?
MS. GERAGOS: And the description here is various expenses paid by CE Opco for Sean Combs — September 2023, right?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: And then it says underneath that: Respective breakdown is attached.
Do you see that?
MS. GERAGOS: Can we go to the next page, please.
If we can zoom -- yes, thank you.
MS. GERAGOS: Do you see that this is an account quick report?
MS. GERAGOS: This is essentially a report from QuickBooks? Do you see that?
JOSEPH CERCIELLO: Where it says QuickBooks?
MS. GERAGOS: If you don't know, then no problem.
Do you see how it says account quick report?
MS. GERAGOS: Now, if we could, side by side, please, put up 1408 next to it, please.
Let's go to line 3.
MS. GERAGOS: Line 3 lists Jane, 9/17/23, Premier Travel, $50, right?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: Do you see --
MS. GERAGOS: If we could go to the 141.2, and if we could highlight, seven lines down, 9/16/23 expense, travel agency services — JetBlue.
MS. GERAGOS: And do you see it has the true name of Jane?
MS. GERAGOS: And it says agency -- it says, Los Angeles/New York, agency fee, support other?
MS. GERAGOS: And it says, other receivables, A/R, Sean Combs, $50, right?
MS. GERAGOS: And now -- there it is blown up.
Do you see that there?
MS. GERAGOS: So now let's go to line 4 in 1408 and highlight that.
If we can go to -- perfect. That would be great.
MS. GERAGOS: Do you see on line 4 of 1408, it lists Jane's name, right? The date is 9/17/2023?
MS. GERAGOS: And the business name says JetBlue, LAX to JFK, right?
MS. GERAGOS: And the amount is $1,537.90.
Do you see that?
MS. GERAGOS: And it lists the accountholder as Jessica Ruiz/CE Opco LLC.
Do you see that?
MS. GERAGOS: Can we highlight, please, and blow up the line right underneath what we just saw. If we can make it bigger for everybody to see, since I'm constantly having -- thank you.
MS. GERAGOS: Now, do you see here, it lists September 16, 2023 expense, airfare, JetBlue, it lists Jane's true name there.
Do you see that?
MS. GERAGOS: It says, 9/17, Los Angeles - New York, right?
MS. GERAGOS: Other receivables, A/R, Sean Combs, and it lists the exact same amount, right, $1,537.90?
MS. GERAGOS: And that corresponds exactly to line 4 in 1408, right?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: We can unzoom out there.
Now let's look at line 5.
MS. GERAGOS: Again, that's a line that corresponds with Jane, right, on line 5 of 1408?
MS. GERAGOS: Again, same date, September 17th of 2023.
Do you see that?
MS. GERAGOS: UDEW Transporters, Inc., for $204?
MS. GERAGOS: Also, accountholder Jessica Ruiz/CE Opco LLC.
Do you see that?
MS. GERAGOS: So now let's go back to 4H-141, highlight, and if we could blow that up. Zoom, I should say, instead of blow it up.
MS. GERAGOS: Now, that lists 9/18/2023, it lists the exact same business name of UDEW Transporters, Inc., right?
MS. GERAGOS: It lists Jane's true name on the 17th, right?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: And the exact same amount, $204, accounts receivable, Sean Combs.
Do you see that?
MS. GERAGOS: Okay, great.
MS. GERAGOS: Let's go down to -- let's look at line 6.
MS. GERAGOS: That's Kabrale Williams. That shows that the accountholder of that Visa is Jane, right?
MS. GERAGOS: And the same with the next line, Kabrale Williams, the accountholder of that Visa is Jane?
MS. GERAGOS: And then if we can go to line 8, it lists Jane on September 21st, 2023, the business name there is Premier Travel, it's $50, and you write, Jessica Ruiz/CE Opco LLC.
Do you see that?
MS. GERAGOS: So if we could go to our 4H-141 there, and go to the line we were just looking at. Perfect.
MS. GERAGOS: Do you see how it's the same day or one day before, it says it has $50?
MS. GERAGOS: Now we can unzoom there.
Now let's look at line 9.
MS. GERAGOS: That name is the same, it's associated with Jane, it's a JetBlue flight, JFK to LAX, right?
MS. GERAGOS: You wrote it's $1,427.90?
MS. GERAGOS: And it's associated with the same accountholder, Jessica Ruiz/CE Opco, right?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: Now, if we go right below the one we were just looking at. Yeah, exactly.
MS. GERAGOS: On this account quick report, it lists that exact flight for Jane, and it lists it in her true name for September 21st, 2023, from New York to Los Angeles, in the exact same amount of $1,427.90, right?
MS. GERAGOS: Let's go to the next two.
MS. GERAGOS: Line 10, again, we've got a UDEW Transporters, Inc., for $204 in the accountholder of Jessica Ruiz for CE Opco LLC?
MS. GERAGOS: Now, if we go and look at the $204 charge right there, and that's the exact expense that's associated in 1408 listed in 4H-141, right, and it lists other receivables, A/R, Sean Combs, and $204, right?
MS. GERAGOS: Our last one, and then we can move on: Line 11 lists Jane as well, and Cardinal Valet LLC, $627, the accountholder is Jessica Ruiz/CE Opco LLC, right?
MS. GERAGOS: Now if we go right there, to — perfect — Cardinal Valet, and that's the exact same charge on 4H-141, page 2, it lists the exact same charge for Jane and her true name.
Do you see that there?
MS. GERAGOS: All right, perfect.
MS. GERAGOS: We can unzoom there, and we can take down 1408, and just go back to the first page of 4H-141.
MS. GERAGOS: Again, this lists -- this is an invoice, right, 4H-141?
MS. GERAGOS: And this is billed to Sean Combs personally for accounts payable, right?
MS. GERAGOS: And the description here is various expenses paid by CE Opco for Sean Combs for that month, September of 2023, right?
MS. GERAGOS: Did the trial team ever show you this document?
MS. GERAGOS: You had never seen this while you were putting together 1408?
MS. GERAGOS: You only saw the AmEx records and the bill-out record?
JOSEPH CERCIELLO: I saw the government exhibits that are listed on 1408 at that row.
MS. GERAGOS: Okay.
You can take water. I have my water as well.
JOSEPH CERCIELLO: I'm good.
MS. GERAGOS: All right.
Just to be clear, you had never seen this invoice before today, right now?
JOSEPH CERCIELLO: No, not that I'm aware of.
MS. GERAGOS: Okay. All right.
MS. GERAGOS: We can turn back on the screen, and then we can pull up Government Exhibit 1406.
MS. GERAGOS: This is another chart we looked at extensively that you reviewed, and you checked the government exhibits that correspond with the chart, right?
MS. GERAGOS: And you list certain dates in the chart, and then you list certain event types in the chart.
So, if we could go to page 15, on line or row 39, you listed a lawsuit, Ventura v. Combs, filed November 16th of 2023.
You see that?
MS. GERAGOS: And then the next page, line 43, you also listed a time when Combs posts, it says, IG video, I assume you mean Instagram video, right?
MS. GERAGOS: You did not list the date of a lease for Jane's home in this chart, right?
MS. GERAGOS: Can we just turn off the public monitors very quickly, and we'll turn them back on again.
Can we just pull up what's already in evidence as 4H-122.
MS. GERAGOS: Do you see this month-to-month rental agreement, lease agreement, here in Jane's true name?
MS. GERAGOS: And this is dated April 4th of 2023?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: Have you ever seen this exhibit?
MS. GERAGOS: Okay.
MS. GERAGOS: We can take this down, and we can turn on the monitors and pull up 1406 again.
MS. GERAGOS: So, you list, by my count, 27 rows in your chart before April 4th. So if can we go to page 1, you have three; next page, several; next page --
MS. GERAGOS: All right. And keep going. Going. Going. Here we go.
MS. GERAGOS: So, April 4th of 2023 would be on approximately -- if you had put it in there, it would have been on approximately page 11 of this chart, right?
JOSEPH CERCIELLO: What was the date, 4?
MS. GERAGOS: April 4th of 2023.
MS. GERAGOS: And after April 4th of 2023, by my count, there are 17 rows in your chart that correspond to a location. So, let's see, there's 28, 29 — go to the next page -- 30, 31, 32, 33, 34, 35, 36, 37, 38, 40, 41, 42 -- 43 corresponds to a location because in the flight records, you say LAX to Miami, right?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: And then there's 44, 45, and 46, right?
MS. GERAGOS: And then fair to say there are several times when Jane and Combs see each other, and those times are just not documented in this chart?
JOSEPH CERCIELLO: That's possible, yes.
MS. GERAGOS: Because there's just not every time that they see each other is documented in this list; this, what you have here, was just checking that the times and locations match the government exhibits, right?
JOSEPH CERCIELLO: Yes. I was asked to look at these charts and the corresponding exhibits.
MS. GERAGOS: Can we go to page 14?
MS. GERAGOS: Line 37, I just wanted to ask you about this. We looked at the messages here extensively this morning in 1407-R, but line 37 corresponds with September 30th of 2023, right?
MS. GERAGOS: And this location here, you wrote Miami, Florida, and the names associated here are Jane and Combs, right?
MS. GERAGOS: And there are no other third parties in this row, right?
MS. GERAGOS: Because then you cite here to G 102, page 145 to 152.
MS. GERAGOS: And if we could pull that exhibit up, and that's not under seal, so we can pull that up.
If we can go to page 145, and then have two pages side by side.
MS. GERAGOS: We looked at these text messages within 1407-R this morning.
Do you remember that?
MS. GERAGOS: In these messages between Paul Arthur and Combs, you see Combs asks Paul Arthur: "Stop in Miami?"
And then he says: "I'ma meet you in L.A."
Right?
MS. GERAGOS: If we go to the next two pages.
MS. GERAGOS: And you see Combs say: "Damn, wish you were here."
And Arthur, on the next page, saying: "I can be in Miami tonight."
And he says: "Come."
Right?
MS. GERAGOS: If we go to the next two pages.
MS. GERAGOS: And then Combs writes later: "I'ma have to meet you in L.A. I forgot I had a show."
And the next page, he says: "You're more than welcome to chill at crib if you need some sun. How long will you be in Miami for, another week," right?
MS. GERAGOS: And if you go to the next two pages.
MS. GERAGOS: And then at the very last message here, it says: "No worries. L.A. it is," right?
MS. GERAGOS: So you had --
MS. GERAGOS: If we could go back to 1406, page 14.
MS. GERAGOS: You had written this exhibit, G 102, page 145 to 152, which we just looked at, under Miami, Florida, but you had no evidence to show that Paul was in Miami, Florida, on that date in question, right?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: And then we looked at several messages from pages 82 to 88 this morning on 1407-R that showed Jane and Combs together, but there was nothing in there about a third party or anybody else there that day, right?
JOSEPH CERCIELLO: Not that I had records of.
MS. GERAGOS: Okay. All right.
MS. GERAGOS: Why don't we go to page 1 of this exhibit.
MS. GERAGOS: So, we looked at there was a five-month gap between row 1 and row 2.
Remember that?
MS. GERAGOS: Here, under Don, you had shown us the phone call, and then you said that because of hotel retention policies, you weren't sure if there were times that they met each other in between these five months that was not associated -- you weren't sure if there was a location in between these five months because of hotel retention policies, right?
MS. COMEY: Objection; misstates the testimony.
MS. GERAGOS: Let me just rephrase. That was confusing.
BY MS. GERAGOS:
MS. GERAGOS: You talked about record retention policies on direct examination, right?
MS. GERAGOS: You're aware this investigation began November of 2023?
JOSEPH CERCIELLO: I'm not aware of when the investigation started.
MS. GERAGOS: Okay. You're aware that when an investigation starts, grand jury subpoenas can be cut, right?
JOSEPH CERCIELLO: They can be, yes.
MS. GERAGOS: And that can go back a number of years, right?
JOSEPH CERCIELLO: What --
MS. GERAGOS: You can cut a grand jury subpoena that asks for records for a very long period of time, right?
MS. GERAGOS: And the time period you're looking at here is 2021, right, on this first page?
MS. GERAGOS: And we looked at several hotel records from Miami between 2021 and 2024, you've written them in this chart, right?
MS. GERAGOS: So, you were able to review hotel records from the one hotel in Miami.
You see that on the first line?
MS. GERAGOS: You were able to -- and several other lines, you'll see St. Regis Bal Harbour, right?
MS. GERAGOS: And SLS Brickell.
You remember reviewing that?
JOSEPH CERCIELLO: That one, I don't remember.
MS. GERAGOS: We'll get to that eventually if you don't remember off the top of your head.
Mr. C. hotel, do you recall that?
JOSEPH CERCIELLO: I remember Mr. C, yes.
MS. GERAGOS: The Nobu Hotel, do you remember that?
MS. GERAGOS: And Four Seasons, do you remember that?
JOSEPH CERCIELLO: Four Seasons, I remember.
MS. GERAGOS: So let's look at --
MS. GERAGOS: Do we have 1407-R available yet?
MS. GERAGOS: This is the chart that we have just been looking at today.
Do you recall this?
MS. GERAGOS: And this starts at November 8th of 2021?
MS. GERAGOS: And do you see that the first text on line 6, on November 8th of 2021, is Mr. Combs to Jane: "What you want to do?"
And she says: "Spend time w my favorite person"?
MS. GERAGOS: "These are my fave. What do you wanna do?"
Do you see that?
MS. GERAGOS: And his response is: "Want me and Paul to stop by"?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: Okay.
MS. GERAGOS: Could we take that down and turn off the public screens, please, and pull up the exhibit that's cited there, which is A104-5.
Could we go to page 4.
MS. GERAGOS: Do you see these messages on pages 4 and 5 of 104-5?
MS. GERAGOS: These messages were not included in your chart, right?
MS. GERAGOS: So, the top message, Jane writes: "I'm horny for you."
You see that?
MS. GERAGOS: And then what does Mr. Combs write here in the response?
JOSEPH CERCIELLO: "What you wanna do?"
Keep going?
MS. GERAGOS: Keep going.
JOSEPH CERCIELLO: "Be explicit."
MS. GERAGOS: And then there's a blank message, and she writes: "I wanna suck Paul's dick while you give me that strong stroke, baby. I loved you rubbed oil all over my legs, my body, kiss me, and put in deep in me w my legs back. When you look me in my eyes, giving me every hard inch...so wet..."
MS. GERAGOS: If we could go to the next two pages.
MS. GERAGOS: Now, these messages on these two pages are also not included in your chart, right?
The chart at 1407, to be exact.
JOSEPH CERCIELLO: No, I don't believe so.
MS. GERAGOS: And she says: "Like that's the only and last dick I'm supposed to have. Stroking a hard dick next to me while a hard one is inside me," heart emoji.
And what does he write?
JOSEPH CERCIELLO: "Wheww."
MS. GERAGOS: And she laughed at this and said: "Having wine. Miss you."
MS. GERAGOS: Next two pages.
MS. GERAGOS: Now, these two pages, if you could review them, on pages 8 and 9, those are also not included, right?
JOSEPH CERCIELLO: No, I don't believe so.
MS. GERAGOS: So Jane sends Mr. Combs a photo, and he writes: "Damn."
She says: "My daddy left me all alone. Come and keep me company. The store closes at 12A. So just in case you need me to go, LMK. LOL. Me miss you."
What does he respond with?
JOSEPH CERCIELLO: "What you gonna get?"
MS. GERAGOS: "Just need outfits."
And these two pages, pages 10 and 11 of 104-5, are also not included in the chart, right, which to be specific, the chart at 1407?
MS. GERAGOS: She writes: "Mmm, I have some here, but mostly black dominatrix style."
What does he say?
JOSEPH CERCIELLO: "K. I'll hit you."
MS. GERAGOS: "That means...good night, LOL."
What does he say?
JOSEPH CERCIELLO: "LOL. Don't know."
MS. GERAGOS: And she loves that message.
MS. GERAGOS: Could we go to the next two pages?
MS. GERAGOS: And this last message on page 13, "What you wanna do" is what you start with in 1407, right?
JOSEPH CERCIELLO: Yes, I believe so.
MS. GERAGOS: And in this message — I'll just read what she says — "No stress, baby. Hit me TMW when you wake up," right?
MS. GERAGOS: And he writes: "Just finished"?
MS. GERAGOS: We can go back to 1407.
And if we go -- we can just skip ahead to page 5.
MS. GERAGOS: And these are several messages here between -- we reviewed these several messages between Jane and Kabrale, right?
MS. GERAGOS: I'm going to bring up, just so we can see the actual messages, what's in evidence as Defense Exhibit 3328 under seal, page 17.
These are messages between Jane and Kabrale. So, here, this starts out several days earlier UTC time, November 6, 2021, 8:51 p.m.
Do you see that?
MS. GERAGOS: And you did not include any messages from November 6th of 2021 in 1407, right?
JOSEPH CERCIELLO: I'd have to see 1407 at that time period.
MS. GERAGOS: Okay.
MS. GERAGOS: Well, we can go back to page 1 of 1407.
MS. GERAGOS: It starts on the 8th.
Do you see that?
MS. GERAGOS: So let's head back to 3328. And then we can put 17 and 18 side by side.
MS. GERAGOS: And, here, on November 6th, Jane writes: "Hey, how are you?" Smiley face.
And he writes: "What's up, love. I'm good. About to shoot with my homie for his brand," right?
MS. GERAGOS: And down on the page, she writes: "Okay. I might have a little time off..if you want to spontaneously come TMW night or Mon, I'll organize, but we'll talk before then once I see it's even possible," right?
MS. GERAGOS: And what does he respond?
JOSEPH CERCIELLO: "Okay, love. Monday night would be nice. Fasho," with an emoji.
MS. GERAGOS: With an emoji.
And she loves that?
MS. GERAGOS: And she writes "Okay" with several heart face emojis?
MS. GERAGOS: Can we go to the next two pages, please.
MS. GERAGOS: He responds, "Hey, baby. How are you today," on November 7, UTC time 11:53, right?
MS. GERAGOS: And she responds, on November 8th at 12:01 a.m. UTC: "Hey, cutie. I'm good. How's your Sunday?"
And he says: "Pretty good, love. Just got back from cooking for a brunch" and sends messages that are missing here, right?
JOSEPH CERCIELLO: Yes. It looks like images.
MS. GERAGOS: Images, right.
And you can tell that from the JPEG?
MS. GERAGOS: And she writes: "Sheesh, you need to come with a warning sign," with several monkey closed-face emojis and a sweat emoji?
MS. GERAGOS: And she writes: "How was the brunch? Jesus Christ, LOL...these pics."
What does he say?
JOSEPH CERCIELLO: "LOLL. It was good. They loved the food for the most part."
MS. GERAGOS: Can we skip to the next two, please. I'm just going to go to the page on the right.
MS. GERAGOS: He writes: "LOL. You will never be hungry around me," kiss face emoji. "I'm serving orgasms and foodgasms," with a smiley face emoji, right?
MS. GERAGOS: She laughs at that and sends several more emojis and says: "That's def the first time I've heard that. LOL."
He says: LOL. I'm one of a kind baby," right?
MS. GERAGOS: Can we go to the next two pages, please.
MS. GERAGOS: These messages are from November 9, 2021, 2:35 a.m. UTC time.
Do you see that, the ones on the left?
MS. GERAGOS: She writes to him: "Hey, how's your day, friend? Hit me when you can talk."
And how does he respond?
JOSEPH CERCIELLO: "What's up lovely. I fell asleep early."
MS. GERAGOS: And she says on the bottom: "I'm free TMW. Is it crazy if I fly you out TMW...or today for you actually. I'm so horny, I need you," right?
MS. GERAGOS: And what does he respond with?
JOSEPH CERCIELLO: "Yes, I am, baby, and I'm most definitely down. I would love to see you."
MS. GERAGOS: "We need to have a convo first, baby. I'm touching myself RN WYD."
We looked at those messages in 1407, right?
MS. GERAGOS: So, let's skip ahead, then, because we've seen a lot of these, to page 28 and 29.
MS. GERAGOS: We've talked about this in this courtroom before, but the Cellebrites, which is what you reviewed, do not have emojis.
Do you recall that?
JOSEPH CERCIELLO: That I --
MS. GERAGOS: The Cellebrite extracts that you reviewed did not have the emojis within them?
JOSEPH CERCIELLO: I don't know if I testified to that about emojis.
MS. GERAGOS: Okay. But do you recall that when you reviewed the Cellebrite extracts that you used to make 1407, that you did not see the emojis within those Cellebrite extractions?
JOSEPH CERCIELLO: I don't remember seeing --
MS. GERAGOS: On 1407, you didn't include any emojis within the messages that we looked at this morning and this afternoon with Ms. Comey, right?
JOSEPH CERCIELLO: I don't believe so, no.
MS. GERAGOS: Okay. So let's look at this on page 28.
Jane writes: "I'll give you extra, of course," with a heart face emoji, right?
MS. GERAGOS: "And if you make me squirt," and then a flirtatious emoji as well, right?
MS. GERAGOS: "LOL"?
MS. GERAGOS: And that's an example of a message with an emoji that you didn't include in the chart, right? The emoji was not included, right?
JOSEPH CERCIELLO: I don't believe so, no.
MS. GERAGOS: Okay. And then she writes another one with a heart faced emoji and then a kissy face emoji, right?
MS. GERAGOS: And what does he write?
JOSEPH CERCIELLO: "IDK if I can wait -- if I can wait, lovely."
MS. GERAGOS: Now let's skip ahead to page 36 and 37. She writes -- if you look at page 26, this is November 9, 9:54 p.m. She loved his message "At the airport, love. See you soon," with a kiss face emoji, right? She loved that message?
MS. GERAGOS: And then a few messages below, she writes: "I'm too excited RN," with two heart eye emojis. She writes those there, right?
MS. GERAGOS: The next page you see, "I'm too -- I'm excited too, baby" -- he writes, "I'm excited too, baby. Can't wait to see you," with more emojis, right?
MS. GERAGOS: Okay. If we can go to 38 and 39, again, we looked at these messages in 1407, right? Do you remember that?
MS. GERAGOS: So, at the top, he writes, "I'm excited too, baby. Can't wait to see you," with a kiss emoji. And below, on November 10, 2021, at 2:03 a.m. UTC, she writes, "Hey, baby welcome back to L.A. Text me after you freshen up, and I'll have you come to our room. Can't wait," with several heart eyes emojis as well, right?
MS. GERAGOS: And then if you look at the next page, there are some more text messages — oops, if we can go back, please — text messages between the two that we looked at in 1407. These ones include the emojis that she sends to him, including the monkey face one and several smiley faces or one smiley face.
Do you see that?
MS. GERAGOS: If we could go ahead to 44 to 46 or 44 to 45, and he writes to her, November 11, 2:23 p.m. UTC, "I had so much fun with you," smiley face, right? And she loves that message at the bottom of the page?
MS. GERAGOS: On the next page, on November 11th, 7:18 UTC time, she writes, "Hey, thank you for being so sweet and such a gentleman," with hearts, "I really had a great night WU. Safe travels today," right?
MS. GERAGOS: Now, we looked at several videos on direct examination, so I wanted to -- well, we can show a few more. If we can just pull up 1406 so that the witness has it in front of him, and go to page 1.
MS. GERAGOS: If you look at line 3, you list several videos, explicit videos, the AX series, under Jane.
Do you see that?
MS. GERAGOS: So AX-102, which you stated was the metadata, right?
MS. GERAGOS: And you list AX-102- -- do you see how there's a G underneath that as well?
MS. GERAGOS: And an S as well at the end?
MS. GERAGOS: And you verified that the metadata was from a date within November 8th to November 10th?
MS. GERAGOS: And I think at this point, if we can turn the attorneys' screens off as well, and with your Honor's permission, if I could go over to Ms. Becker?
THE COURT: Very well.
MS. GERAGOS: Thank you.
We'll first watch AX-102-G -- or we can pull up, actually, AX-102, page 2, which is the metadata, and go to line 7.
MS. GERAGOS: Do you see the metadata for that, line 7?
MS. GERAGOS: And it lists November 10, 2021, at 4:37.
Do you see that?
MS. GERAGOS: I'll switch back to Ms. Becker. If we can, please, first test the headphones and make sure they work.
Everybody hears piano music, so let's start at AX-102-G at two minutes and 11 seconds and play to three minutes and seven seconds.
(Video played)
MS. GERAGOS: Next, we are going to play four minutes and 45 seconds to seven minutes and 35 seconds, of this same exhibit, AX-102-G.
(Video played)
MS. GERAGOS: Okay. We paused at seven minutes and 35 seconds. And if anybody has trouble with the sound, there are volume buttons on the side; the up arrow is louder, the bottom arrow is quieter.
If we could skip ahead of that same exhibit, AX-102-G, and go to 13 minutes and 40 seconds and play through to 14 minutes and 15 seconds, please.
(Video played)
MS. GERAGOS: We also, on 1406, looked at AX-102-S, which was also a video from this time period, so we're going to bring that up next. And we're going to play -- first, we're going to play the first minute of that video.
(Video played)
MS. GERAGOS: We're going to skip ahead 17 seconds and play from one minute and 17 seconds to one minute and 40 seconds.
(Video played)
MS. GERAGOS: Now we're going to skip ahead to two minutes into the video and play until two minutes and 40 seconds.
(Video played)
MS. GERAGOS: Agent, do you recall also on direct examination reviewing video AX-103-A from page 2, line 5 of your chart between the dates of December 3rd and December 6th of 2021?
JOSEPH CERCIELLO: Can I see the chart to verify that?
MS. GERAGOS: Yes. Do you have a paper copy in front of you? It might just make things a little bit easier.
JOSEPH CERCIELLO: Can you reference the chart again?
MS. GERAGOS: Of course. Page 2, row 5.
JOSEPH CERCIELLO: And what's the exhibit?
MS. GERAGOS: AX-103-A.
MS. GERAGOS: And we watched a portion of that on direct. Do you recall?
JOSEPH CERCIELLO: I believe we did, yes.
MS. GERAGOS: So we're going to now just play the entire video for that.
(Video played)
MS. GERAGOS: All right. That concludes the video portion for today. Let's see. We can turn -- I think we have to keep off the public screens for right now, but if you could pull up 1406, page 2, please.
MS. GERAGOS: We looked at several from -- well, actually, page 1, and the video that we just looked at was AX-103, which was line 5, right?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: That's listed within the date time of 12/3/21 to 12/6/2021, right?
MS. GERAGOS: If we could pull up Defense Exhibit 3328 at page 51. It's the corresponding exhibit to F101, which you had listed there.
This is listed as December 3, 2021 UTC time. And Jane messages Kabrale and says, "Hey, you, what are you up to?" smiley face, right?
MS. GERAGOS: What does he respond with?
JOSEPH CERCIELLO: "What's up love?" heart emoji. "I'm just chilling in Houston with my friend till my flight. How are you?"
MS. GERAGOS: He says: "When is your flight, babe? And where to? Wanna come to Miami tonight..."
What does he say?
JOSEPH CERCIELLO: "I would but really -- I would but really love to. But I have a chef gig tomorrow."
MS. GERAGOS: "Aww when are you free? You wanna come Saturday night to Sunday? I'm not free Monday and on...so LMK. I have a small freedom window," with a smiley heart emoji. "Come after your chef gig tomorrow...is that possible?" with I guess a wondering emoji and a heart emoji, right?
MS. GERAGOS: What does he respond with?
JOSEPH CERCIELLO: "I'm definitely free Sunday. I can make that happen, love."
MS. GERAGOS: "Okay. Sunday!"
MS. GERAGOS: Next two pages, please.
MS. GERAGOS: "I'll get on it," kissy face, "Send me your name and DOB again, babe. Sunday a.m. okay WU? Not too early but, yeah, LMK. What airport?" Right?
MS. GERAGOS: And then, just skipping ahead, she says, "Perfect, babe. Keep you posted by early evening. Safe travels...can't wait to see you," with several emojis and a heart face emoji, right?
MS. GERAGOS: And he says, "Can't wait to see you too, beautiful," right?
MS. GERAGOS: If we can go to the next two pages.
MS. GERAGOS: And she says, "What time is your event finishes Saturday night?"
What does he say?
JOSEPH CERCIELLO: "I should be done with that at like 2:30 a.m."
MS. GERAGOS: "Damn. Call me whenever you can FTE FT me."
And if we go to the next two pages, please. And on the right side of the page on December 5, 2021 at 12:57 a.m. UTC, she writes, "Hey, babe. It's an 8:35 a.m. flight that lands you at 10:40 a.m...By noon you should be settled in the hotel. It's the best option RN schedulewise. LMK if you can make that," smiley face.
And below what does he respond with?
JOSEPH CERCIELLO: "Yup, I'll make it happen, love."
MS. GERAGOS: And she responds with several emojis, right?
MS. GERAGOS: Now, if we could go to Government Exhibit 104-9, which you had listed under Jane in 1406, and go to page 13.
Actually, we can put page 13 and 14 next to each other.
And, here, Jane writes, "The chef can fly on Sunday morning. Surprise. LMK if you want me to text Jess about it," right? Is that what she writes?
MS. GERAGOS: And if we could go to the next two pages, please, and she writes: "To pregame. Says we need" -- I can't see what it says. There we go. "-- hydrating drinks lollipops and/or gums, healthy, easy foods to bring, etc, basically all the things we do already. Let's do alkaline water, chia pudding, soups, Gatorade."
And what does he write?
JOSEPH CERCIELLO: "Let's."
MS. GERAGOS: Next one.
JOSEPH CERCIELLO: "WYA."
MS. GERAGOS: She says, "Hey, babe. En route! WHBU."
So let's go back to 3328, please, at page 65.
And these are from later that day, the messages we were just looking at, right?
MS. GERAGOS: She's responding back and forth. And if you can go to -- actually, sorry, I meant to say page 68 and 69.
He writes at the top -- what does he write at the top? And this is December 5th of 2021, 6:41 p.m. UTC.
What does he write?
JOSEPH CERCIELLO: "Gotta give you all the energy I can, but you know I'll always have plenty of energy for you." And it looks like a smirking emoji.
MS. GERAGOS: Emoji? Okay.
She responds, with several emojis, "No, no, take it later." And she emphasized his message, and said, "That's a proven fact," with several emojis, right?
MS. GERAGOS: If you could go to the next page, pages 70 to 71.
MS. GERAGOS: If you look at the bottom, she writes to him, "Okay, rest up! I'll call you if the time is any later or anything, but get your rest," with several emojis, right?
MS. GERAGOS: And the next page, she says, "Hey, babe. Wakey wakey."
What does he respond with?
JOSEPH CERCIELLO: "What's up, baby? Are you here yet?"
MS. GERAGOS: We can go to the next two pages.
MS. GERAGOS: They continue to correspond that day, right?
MS. GERAGOS: If we can skip to pages 77 and 78.
MS. GERAGOS: And then she writes to him — and this is December 6th now, at 8:28 p.m. UTC — "Hey, I'm going to book your flight tonight at 10:30P."
What does she respond?
JOSEPH CERCIELLO: "Okay, lovely. Thank you," with a heart faced emoji. "It's such a rainy day, I really would have been happy just chilling with y'all."
MS. GERAGOS: And then the next page, he writes -- What does he write on December 6, 2021, 9:51 p.m. UTC?
JOSEPH CERCIELLO: "Okay. I enjoyed you so much. I loved every second. You're amazing, baby. I'm so appreciative of you, really," heart emoji. You can have me whenever you need me.
MS. GERAGOS: She writes, "Awww slyyy," and loves that message, right?
MS. GERAGOS: "So happy. You are such a sweetheart. Thank you for making me feel beautiful."
What does he write in response?
JOSEPH CERCIELLO: "You called me by my government name too. I was like oh, we getting real personal."
MS. GERAGOS: Can we go to the next two pages.
MS. GERAGOS: And she responds, halfway down the page, with another emoji and says, "LOL. I like your name."
And then he responds. What does he respond with?
JOSEPH CERCIELLO: "LOL. Thank you, love," with a heart emoji.
MS. GERAGOS: She responds, "Getting flashbacks," with an emoji with the drool coming down the mouth, right?
MS. GERAGOS: What does he respond with?
JOSEPH CERCIELLO: "All ready," with a heart faced emoji. "I know that pussy still throbbing for me."
MS. GERAGOS: And she says, "Send me a little something to remind me," with a smirk face emoji, right?
MS. GERAGOS: And then there are several attachment missings, .HEIC probably photo files, but it doesn't show you, right?
JOSEPH CERCIELLO: Correct.
MS. GERAGOS: If we can go to the next page, halfway down the page, she says, "And don't worry about it. We just had a little moment over here, LOL," right?
MS. GERAGOS: If we could go back, please, to 1406, and we can go to the next page — next page, page 3, perfect — and then if you look at the next page, it's item 6, is December 17th of 2021 to December 21st of 2021. And you write the location as 1 Hotel Miami, right?
MS. GERAGOS: And there are several explicit videos under Jane listed there.
Do you see that AX-104 and AX-701 and several others within that? Do you see that?
MS. GERAGOS: And then the flight records and financials, right?
MS. GERAGOS: And one of the other names listed here is Kabrale.
Do you see that at the bottom?
MS. GERAGOS: So if we could go now go back to Defense Exhibit 3328 and go to page 81 and -- sorry, the next two pages.
So, December 15th on page 84, you see that Jane reaches out to Kabrale and says, "Hey, you," right?
MS. GERAGOS: And she says, down below on the page, "So I was just thinking ahead. What are you doing on Saturday?" right?
MS. GERAGOS: And what does he say?
JOSEPH CERCIELLO: "My day's been well. I just ran errands and got a retwist WBU, my love."
MS. GERAGOS: Okay. And the next page — I'll skip ahead — she says, "Okay," smiley face, "So I'll be traveling. And maybe if things work out, you could come, too, but I'm not 100 percent certain of plans. However, if you were to come, you would need to get a PCR test by Thursday. So you could have the PCR paper by Friday, but the plans are still up in the air. Just thinking ahead," with the thinking emoji, "What do you think?
Go to the next page, please.
What does he respond with?
JOSEPH CERCIELLO: "I'm down most definitely. Would love to come wherever we're going."
MS. GERAGOS: And she loves that message. And says, "You know it will always be great," with a heart faced emoji. "Okay. So just so we have it, try to find a place for Thursday, and then you'll have it by Friday. And then I should know by Friday midday. By 'place,' I mean testing center. Has to be PCR," with a smiley face, right?
MS. GERAGOS: On the next page, skipping ahead, she says, "Hey, forgot to ask, you have a passport, right?" Do you see that?
MS. GERAGOS: And he responds. And then she says "Ah, okay. You would need a passport. No worries, then, about taking the test. You should def try and get a renewed passport soon, though," right?
MS. GERAGOS: Let's skip ahead to pages 91 and 92. And this is December 17th of 2021, 4:45 UTC time.
MS. GERAGOS: She writes, "Get some good rest tonight. Hit you later or tomorrow," smiley face.
What does he respond with?
JOSEPH CERCIELLO: "Okay, great, because I miss you," heart emoji. "You want me to come see you, right?"
MS. GERAGOS: And she says, "Ah, me, too. Yeah, def. I'm in Miami."
And the rest of the messages on this page are them coordinating between her flights to Miami.
Do you see that?
MS. GERAGOS: Could we go to the next page, please.
And she writes, "The airport is Chicago O'Hare ORD, right," you're all set," smiley face, right?
MS. GERAGOS: Could we go skip ahead to page 97.
(Continued on next page)
BY MS. GERAGOS:
MS. GERAGOS: Let's skip ahead to page 97. She says December 17, it's later that day, 9:02 p.m., "You made it?!" And what does he respond with?
JOSEPH CERCIELLO: "Yep waiting to board now."
MS. GERAGOS: She responds with several emojis and celebration emojis?
MS. GERAGOS: If we could -- and this is the last page for today. Go to page 102 please.
MS. GERAGOS: And this is December 18, 4:54 p.m., she writes: "Okay. Perfect. I had a great time WU."
Do you see that?
MS. GERAGOS: What does he respond with?
JOSEPH CERCIELLO: "Me too baby. You were amazing per usual."
MS. GERAGOS: This is a good place to stop, your Honor. It's 3:00 p.m.
THE COURT: All right. Very good. Thank you very much.
Members of the jury, we'll be back here to start at 9:00 a.m. tomorrow.
Please do not speak with each other about the case, and nobody else about the case. And do not look up anything about the case. With that, we'll see you tomorrow morning to start at 9:00 a.m. All rise.
(Continued on next page)
(Jury not present)
THE COURT: See you tomorrow. I'm sure you've been told this, but you're not allowed to speak with the government.
(Witness not present).
THE COURT: Please be seated.
Ms. Comey, anything to raise before we adjourn?
MS. COMEY: No, I don't believe so, your Honor.
THE COURT: Ms. Geragos, anything to raise before we adjourn? How much time do you think you have left?
MS. GERAGOS: An hour -- an hour and 15, I guess. Based on what I just did, it would seem like another hour and 15. It might be a little bit longer, but --
THE COURT: Take as much time as you need. There will be a couple of hours in the morning, and at that point I think the proposal was that we would have the jury take a break, a long break, handle the Rule 29 motions, and then tomorrow the defense would be prepared, if the Rule 29 motions are denied, to present their case tomorrow. Is that right?
MS. GERAGOS: That's right. I think there may be -- I'm looking at Ms. Estavao. There may be some evidentiary issues for your Honor to work out tomorrow morning that we have been conferring with the government on, if I have that right. Once they are done, we will be able to present our case once we have that worked out.
THE COURT: All right. And so then Wednesday in the morning charge conference.
MS. GERAGOS: If that's how your Honor -- that's fine.
THE COURT: Wednesday morning charge conference. That will give the parties time to integrate the charge into their closings, and we'll have closings on Thursday. Is there anything that we need to address in terms of the mechanics of the closings? Like how long, ballpark. Again, I'm not holding anybody to anything, so -- but I just want to know for scheduling purposes what we anticipate. A minimum, like give me whatever you want.
MS. GERAGOS: I would guess based on our conversations, the government's will be at least four hours, ours will be at least four hours. I don't expect the charge to happen until, you know, midday Friday.
THE COURT: So the parties will think in their minds about the appropriate places for breaks.
MS. GERAGOS: Yeah.
THE COURT: If you want it to be -- I'm happy to tell the jury to just sit tight for the entire thing, but...
MS. GERAGOS: No, I think usually in these types of closings, we probably take a break in between like at the two-hour mark. That's my experience. We'll talk about it though.
THE COURT: I'm just trying to map it out. Whatever the parties come up with, that's fine by me. So we'll do that on Thursday or part of the day on Friday. Charge the jury on Friday, and then the jury will deliberate.
Have we worked out the laptop and other exhibits?
MS. GERAGOS: The government has put together the laptop. I'm going to review it myself with at least the government paralegals, I'm not sure how many of the AUSAs. And we'll do that today. So if there are any issues, tomorrow we'll be able to bring those to the Court.
THE COURT: I really put in that Monday deadline just to make sure we had it, but now that we have it...
MS. GERAGOS: We have it. They've loaded it. We are just going to review it. We want to make sure the right exhibits are on there and review everything to make sure the 106 issues and everything that we've been talking about, and the right exhibits are on the laptop.
THE COURT: I will ask in an appropriate place on Thursday, for reasons I'm sure you appreciate, that it's on there.
MS. GERAGOS: I understand.
THE COURT: And there will be, I believe, a monitor and hookup for the laptop so people don't need to be crowded around the laptop screen.
MS. GERAGOS: I was going to ask that.
THE COURT: I think that we have a screen and an ability to hook that into the laptop.
Anything else that comes to mind to address?
MS. GERAGOS: Ms. Shapiro is standing up.
MS. SHAPIRO: Your Honor, I just had a quick question about the format of what you want from the parties with respect to the Court's draft charge for the charge conference. So we're going to meet and confer with the government this afternoon, and maybe we will be able to do it in a format the Court suggested. However, in the event, as I understand, the government may have very substantial objections and revisions to propose and whether -- I don't know if that's the case, but they had indicated it might be. And if that's the case, I suspect we will have a lot of objections to their objections. And so what I wanted to ask the Court was whether the Court would give parties some leeway, depending how the meet and confer goes, it may be more efficient simply to have each side put in their proposals, and then rather than trying to put together a document that's just filled with redline and comment bubbles that are very hard to decipher. So that was just the request.
Hopefully, when they said substantial revisions, they didn't really mean it, and we won't have those problems, but I just wanted to see if the Court would give us a little flexibility if the parties determine it may be more efficient to proceed in a slightly different way.
THE COURT: I agree that it would be more efficient for you because you wouldn't have to reconcile the two versions. Look, if you --
MS. SHAPIRO: I'm just worried that we may have a lot of objections to what they're proposing, and I want to make sure the Court can see what they are, and that we are not somehow, you know, at a disadvantage because there's not enough time and it's not clear enough what our problems are with what their proposals are.
THE COURT: So you're going to try to give me one version, but if it isn't feasible for the reasons that you've identified, then each side would have their own version. And as to, let's say, that in the RICO conspiracy section you have a couple of proposed additions, you would have a comment bubble that explains those. And then you would also address what the government has put in their proposal because you would have already talked about that. Meaning, I could go section by section with the two drafts, and I would understand both sides' positions on everything. Is that fair?
MS. SHAPIRO: Yes, that's the idea. I'm just asking for a little flexibility if it turns out we need it. It's going to be efficient for you as well to have --
THE COURT: It's fine, as long as there's just two versions, and not two versions along with other materials because I just don't want to miss anything. I want to make sure I've captured all the parties' arguments.
MS. SHAPIRO: That's fine. I will say we were also -- we may have a short letter for one or two particular issues where we feel like we need to explain it a little more.
THE COURT: Where you can't fit it in a comment bubble?
MS. SHAPIRO: Right. Thank you.
MS. SLAVIK: Just one more question, your Honor.
For the summations on Thursday and Friday, did the Court intend to sit the full day or abbreviated 3:00 day?
THE COURT: On Thursday.
MS. SLAVIK: On Thursday and Friday.
THE COURT: I think I would prefer to do the full day, because otherwise we're talking about, what, four or five hours? It's going to be disjointed. I think the parties should talk and see if they could come up with a proposal that makes sense.
As I said, I was happy to keep them there longer if it makes sense in light of what they're hearing, and it's -- I don't want to disrupt either side's presentation. So that's my main goal. So I'm happy, and I'm sure the jury will appreciate that they're staying, but it's for a critical part of the case.
MS. SLAVIK: Thank you, your Honor.
MS. GERAGOS: We'll discuss and let your Honor know.
THE COURT: Anything to address from either side? We'll see everyone here tomorrow at 8:30.
(Trial continued June 24, 2025 at 8:30 a.m.)