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Sean Combs— Case Archive
2025 Federal TrialtranscripttranscriptJoseph Cerciello — Cross/Redirect (Part 3) - Day 33 - 2025 Federal TrialDefense counsel continued cross-examining HSI Special Agent Joseph Cerciello about records underlying Government Exhibit 1406; on redirect, he said he had not seen sexual, loving, or affectionate messages between Jane and Combs.
Maurene R. ComeyMary C. SlavikMarc A. AgnifiloTeny R. GeragosArun SubramanianJoseph CercielloMS. GERAGOSJoseph CercielloTHE COURTMS. SLAVIKJurorMS. COMEYMR. AGNIFILOCourt Clerkcrosssidebarredirect
2025 Federal Trial/Day 33/June 24, 2025
3 pages·1 witness·2,235 lines
Exhibit rulings, Cerciello's cross-examination, and the parties' decisions to rest ended the evidentiary phase as the court reserved decision on the Rule 29 motion.
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CrossRedirect

2.Joseph Cerciello — Cross/Redirect (Part 3)

Maurene R. Comey Teny R. Geragos Joseph Cerciello
Source PDF · file page 35 ↗
1,903 lines
Joseph Cerciello — Cross
CrossCrossJoseph Cerciello — Cross Joseph Cerciello Teny R. Geragos
1

MS. GERAGOS: Thank you, your Honor.

Could we pull up what's already in evidence as Government Exhibit 1406, please, and go to page 3. CROSS-EXAMINATION CONTINUED

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BY MS. GERAGOS:

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MS. GERAGOS: OK. Just to orient ourselves, we were looking, do you recall looking at row 6, which was December 17 to December 21, 2021, when we broke yesterday?

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MS. GERAGOS: OK. And the names in this row correspond; they say Jane, Combs, Don and Kabrale, right?

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MS. GERAGOS: OK. So we are -- and do you see, under Jane, there's several AX explicit videos here?

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MS. GERAGOS: Do you see that there's AX701, and that corresponds to the metadata, right?

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MS. GERAGOS: And then AX701- and then 65, and then all of the numbers after that correspond to a video, right?

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MS. GERAGOS: OK. And so then there's a 701-114. Do you see that? We highlighted it, but it would be the row right below it --

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MS. GERAGOS: -- 114. And then 145 is right next to 114?

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MS. GERAGOS: OK. So I will ask that we turn off the attorney screens and the public screens and we start our morning with some videos. If everybody could use their audio Listen Talk machines, and Ms. Becker will test them to see whether we can hear the music.

OK. Perfect. So everybody can hear the music.

With your Honor's permission, could I please walk to Ms. Becker?

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THE COURT: You may.

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BY MS. GERAGOS:

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MS. GERAGOS: But first we will play as AX701-114, which as you just testified is -- you checked the metadata; it corresponds to that date range, correct?

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MS. GERAGOS: OK. Ms. Becker, can you please play from the beginning until two minutes and 26 seconds, please, whenever you get a chance.

There's an issue. One moment.

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MS. SLAVIK: Your Honor, I believe there's an issue with one of the jurors.

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THE COURT: Oh. Sorry. It's not working? It may have been that it just turned off.

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JUROR: It says low battery.

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THE COURT: It says low battery. OK. We need another one.

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MS. GERAGOS: We're also having an issue on our end, so with your Honor's permission, we just need a minute to charge.

Your Honor, what we'll do is we'll charge the ones that are dead, and we'll come back to them at a later point in the examination so that we don't have to waste everybody's time right now, if that makes sense.

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THE COURT: That's fine.

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MS. GERAGOS: OK. So everybody can put the Listen Talk machine to the side.

Let me just confer one more moment with Ms. Becker -- or Ms. Comey.

Your Honor, may I ask that the deputy take any from the jurors that are currently out of battery; that way we can charge while the examination goes?

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THE COURT: Very good.

Let me ask the jurors to take a look at your device. If you press the button, you should see a battery meter, and if you have no battery, could you raise your hand and we'll charge it for you.

Anybody?

Looks like everybody has --

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MS. GERAGOS: OK. All right. So it's just on our end. So ours will be charging then.

All right. So we'll just go back to this exhibit. We can turn the screens on. Wonderful.

Between December 17 and December 21 of 2021, could we please bring up the corresponding exhibit to the government exhibit here, which is -- and we'd have to turn off the screens for this now, Defense Exhibit 3034, which is in evidence. And I just want to confirm that the overflow screen is also off, which I've confirmed with the deputy.

All right. Good. OK. If we could go to page 30 of this exhibit, please, and 31, next to each other.

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MS. GERAGOS: All right. These are from -- do you see that these are from December 24 of 2021?

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MS. GERAGOS: OK. And the 3286 number you've testified is Mr. Combs, right?

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MS. GERAGOS: OK. And December 24, he writes: "You're so sweet." And she responds with several emojis. Right?

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MS. GERAGOS: OK. And what is his response there?

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JOSEPH CERCIELLO: "That shit was so fucking sexy the other night. Damn."

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MS. GERAGOS: All right. And she emphasizes that message and says: "Phew. I haven't stopped thinking about all of it. Just keeps getting better and better." Right?

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MS. GERAGOS: And what does he respond with?

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JOSEPH CERCIELLO: "What part you been thinking about."

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MS. GERAGOS: And she says: "Just how sexy the room was..so much sexual tension. It was all just making me wet, see it." And "the way you made me come I've never came like that in my life," with several emojis. Right?

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MS. GERAGOS: OK. And below she says: "Did you love it, baby?" And he says: "Loved it." Right?

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MS. GERAGOS: And she responds with several heart eyes emojis and says "sheesh." Right?

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MS. GERAGOS: And you can look, if you have the binder in front of you, at 1406, the next event -- we could pull it up, I suppose, on page 3. The next event listed or the next date range listed is December 31, 2021, to January 3 of 2022. Do you see that?

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MS. GERAGOS: OK. And one of the names listed here under Jane, Combs, Paul, is Kabrale. Do you see that there?

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MS. GERAGOS: You don't list any of the Kabrale messages with Jane in this chart. Is there a reason that you didn't include those?

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JOSEPH CERCIELLO: Anything that's included in this chart is what was provided to me.

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JOSEPH CERCIELLO: So if it wasn't provided to me, it wouldn't be in the chart.

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MS. GERAGOS: OK. Why don't we go to Defense Exhibit 3328, page 103.

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MS. GERAGOS: All right. These messages start from the previous date range, which is December 20 of 2021. Do you see that?

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MS. GERAGOS: OK. And at the bottom of the page, on the left, which is page 103, he writes to -- Kabrale writes to Jane: "We had a pretty intense night. Yes, focusing on my last minute fix this weekend and cooking for my family." Right?

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MS. GERAGOS: OK. And then on the next page, which is 104, she writes: "Elaborate on intense haha. Send me a reminder." Do you see that?

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MS. GERAGOS: All right. And what does he respond with?

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JOSEPH CERCIELLO: "LOL, that was, like, the roughest sex we ever had. You were talking so dirty to me and taking me so deep, I loved it."

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MS. GERAGOS: Could we go to the next two pages.

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MS. GERAGOS: And she writes: "Haha, LOL," with several emojis and mind-blown emoji; "def one for the books," one of the monkey emojis, "send me something." And what does he respond with?

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JOSEPH CERCIELLO: "Most definitely, just keeps getting better and better." And that looks like a smirking emoji.

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MS. GERAGOS: OK. Great.

Could we go to the next two pages, please. Thank you.

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MS. GERAGOS: And then on December 21, UTC time, at 12:26 a.m., Jane writes: "Damn, baby. You got me so hot. You want to come back tonight or tmw morning," with several heart-face emojis. Right?

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MS. GERAGOS: "How come I can't make you come that fast," with a wondering emoji. "You holding out on me." And then five minutes later: "Wake up," with several emojis. Right?

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MS. GERAGOS: And how does he respond?

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JOSEPH CERCIELLO: "Baby, I would love to, but I'm a little busy this week with this Christmas shit, and I scheduled content."

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MS. GERAGOS: And she says: "Quick trip tmw morning, back by 3." And the next page, on page 108, she has eye emojis and says "pls." Right?

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MS. GERAGOS: If we could go to the next two pages, please, 109 and 110. All right.

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MS. GERAGOS: And these are December -- these now, starting at page 109, are December 31 of 2021, UTC time, 7:04 p.m., right?

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MS. GERAGOS: OK. And here, she reaches out to Kabrale and says: "Happy new years," with a celebration emoji and a heart-face emoji, and says: "I'm in Miami. LMK if you want to come tonight," the heart face and kiss, the lips emoji. Right?

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MS. GERAGOS: OK. What does he respond with?

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JOSEPH CERCIELLO: "Happy new year, love. I'm supposed to be cooking for my family today."

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MS. GERAGOS: OK. And she loves that message and says: "Oh, love that. You want to try to come TMW..? Morning?" How does he respond?

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JOSEPH CERCIELLO: "Yes, I'm definitely down for that."

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MS. GERAGOS: Could we go to page 113, please.

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MS. GERAGOS: OK. And then January 1 of 2022, at 7:50 p.m., UTC time Jane writes: "Are you free to travel today? Would love to have you," with four heart emojis. Right?

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MS. GERAGOS: OK. And then there's an attachment missing, but I think you testified yesterday that .JPEG indicates it's probably a photo, right?

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JOSEPH CERCIELLO: Most likely, yes.

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MS. GERAGOS: OK. And she says: "Here's your flight info," exclamation point; "I'll have hotel info later tonight, excited to see you." And how does he respond?

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JOSEPH CERCIELLO: "Excited to see you as well, love," and two heart kissing emojis.

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MS. GERAGOS: OK. Could we go to page 119, please.

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MS. GERAGOS: OK. And this is January 2, 2022, 4:55 a.m. UTC time -- 5:08 a.m., I apologize, UTC time: "Hey, babe. You OK? How far are you? Keep me posted. Really want you here already," with three hearts. Right?

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MS. GERAGOS: OK. How does he respond?

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JOSEPH CERCIELLO: "OK, baby. Imma just wait out these seven mins. He'll be here soon. It's busy on Uber, rn, so I don't want to risk waiting for another."

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MS. GERAGOS: OK. If we could skip ahead to page 121, please. All right.

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MS. GERAGOS: And she writes, down below, January 2, 2022, 5:22 a.m., UTC time: "Can't wait to see you," exclamation point. Right?

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MS. GERAGOS: OK. And how does he respond?

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JOSEPH CERCIELLO: "OTW, baby. Likewise," and another heart kissing emoji.

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MS. GERAGOS: OK. We can take this down.

We can go back to 1406. All right.

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MS. GERAGOS: And so those correspond with the date ranges here, which is December 31, 2021, to January 3 of 2022. Do you see that?

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MS. GERAGOS: But none of the messages between Kabrale and Jane from that date range were included here on this chart, right?

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JOSEPH CERCIELLO: That's correct.

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MS. GERAGOS: OK. If we could go to next page, page -- well, let's skip ahead to page 5 -- well, let's go to page 4.

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MS. GERAGOS: On page 4, there's two more date ranges here. We have February 8, 2022, to February 12, 2022. Do you see that?

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MS. GERAGOS: And then you have one right after that, which is February 14, 2022, to February 16 of 2022, right?

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MS. GERAGOS: OK. And then let's go to the next page.

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MS. GERAGOS: And then the next one is March 4 of 2022 to March 7 of 2022, right?

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MS. GERAGOS: OK. And now, line 11 lists April 4 of 2022 to April 6 of 2022, right?

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MS. GERAGOS: All right. And then under names here, you write Jane, Combs and Italian. Do you see that?

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MS. GERAGOS: Under Italian, the corresponding government exhibit cited is A104-25, right?

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MS. GERAGOS: OK. So I'm just going to bring up the defense corresponding exhibit to that government exhibit, which is Defense Exhibit 3050, please.

All right. Could we go to pages 2 and 3 side by side.

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MS. GERAGOS: You see how these are the same date, April 4 of 2022?

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MS. GERAGOS: OK. All right. So this is a message between Mr. Combs and Jane, and the top message is her loving a message, which is a message from Mr. Combs saying: "So what you want to do? I'm horny as fuck." Do you see that?

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MS. GERAGOS: All right. Could you read Mr. Combs's response?

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JOSEPH CERCIELLO: First response is four question marks. "I've been having crazy fantasies about Leo, you and Leo, LOL."

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MS. GERAGOS: OK. And then the next page, at the top left -- I'll just skip ahead for efficiency purposes -- she writes: "Baby, I want to make love to you. I haven't selfishly had you to myself for five months. I'm fine w the other stuff, but.....I really just need you right now." Right?

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MS. GERAGOS: And how does he respond?

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JOSEPH CERCIELLO: "OK. Whatever you want. Are you horny, or is it just me? What have you been thinking about?"

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MS. GERAGOS: And she laughs at the "are you horny or is it just me" message and says: "It's me too." Right?

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MS. GERAGOS: Can we please go to page 4. All right.

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MS. GERAGOS: And then down below, he writes: "See if the Italian is free at alls today after we spend some one-on-one time. How many you got for me." Right?

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MS. GERAGOS: And how does she respond?

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MS. GERAGOS: OK. So if we could skip ahead to page 8, please. All right.

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MS. GERAGOS: And in this message, on April 4, 2022, at 10:30 p.m. UTC, she says: "See you around 6:30 P, 7P, baby. Want to go to dinner first or anything..? That would be nice. As far as hotel... L'Ermitage? Waldorf...either one is nice. One is private. The other a little sexier." And how does he respond?

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JOSEPH CERCIELLO: "Where you want to eat at?"

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MS. GERAGOS: She says: "Ocean Prime was nice. The same place for my b'day?" Do you see that?

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MS. GERAGOS: OK. Can we take that down, please?

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MS. COMEY: Your Honor, for the record, I'm not sure that was in evidence, but I have no objection to it being in evidence. So I just want to make sure the record is clear that it's been admitted.

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MS. GERAGOS: I believe it was in evidence, but I truly apologize if it was not. And I formally offer 3050, which I had written there was no objection.

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MS. COMEY: No objection. It just wasn't on our list of admitted exhibits, so I wanted the record to be clear.

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THE COURT: Defense Exhibit 3050 will be admitted to the extent it was not.

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MS. GERAGOS: Under seal.

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THE COURT: Under seal.

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MS. GERAGOS: Thank you.

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(Defendant's Exhibit 3050, sealed, received in evidence)

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MS. GERAGOS: All right. Could we please go to Defense Exhibit 3051, please, which is the corresponding exhibit to Government Exhibit A10426, and put pages 1 and 2 side by side. All right.

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MS. GERAGOS: These messages are dated April 5 of 2022, right?

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MS. GERAGOS: And that falls within the date range of row 11?

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MS. GERAGOS: OK. All right. Do you see on page 1, Mr. Combs's initial text to Jane, he says: "I got some new tricks for you. Imma bend them legs all the way back and do all types of acrobatics. LOL." Right?

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MS. GERAGOS: All right. And do you see -- if you skip to the next page, on page 2, at the top, she says: "Your dick is the only dick that can make me come." Right?

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MS. GERAGOS: And then what is his response, those next two messages?

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JOSEPH CERCIELLO: First message is an audio message, and then he follows up with two texts: "I saw the Italian stallion make you have multiple orgasms. I'm on my way."

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MS. GERAGOS: And she responds: OK, baby. I'm leaving in five mins," with a -- I guess that's a kiss emoji. Right?

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JOSEPH CERCIELLO: Yeah, looks like lips.

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MS. GERAGOS: All right. Could we go to pages 4 to 5 of this same exhibit, please. All right.

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MS. GERAGOS: Do you see that we've now jumped ahead to April 7 of 2022?

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MS. GERAGOS: UTC time?

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MS. GERAGOS: And this is the date after the date range on row 11, right?

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MS. GERAGOS: OK. And do you see, do you see, he starts and says: "How you, baby," and she responds: "Hey, baby. I'm good. How about you"?

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MS. GERAGOS: And what does he say in response?

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JOSEPH CERCIELLO: "Great. Checking on you. Adderall is the greatest, LOL."

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MS. GERAGOS: OK. Do you see on the next page, April 7, 10:11 p.m., she writes to him: "Still thinking about you loving all over me," with a drool face emoji and a kiss emoji?

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MS. GERAGOS: OK. And that's the day after; that's the day after row 11, right?

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MS. GERAGOS: All right. So the next line here in 14 -- make sure I have the exhibit right, 1406, is April 13 of 2022 to April 14 of 2022, right?

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MS. GERAGOS: If we go to the next page, on page 6, the next date is July 18 of 2022, right?

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MS. GERAGOS: So there's several months in between line 12 and line 13, right?

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MS. GERAGOS: And as you mentioned, you only reviewed the exhibits that the government gave you; you didn't review anything else related to times they were seeing each other between -- times that Jane and Mr. Combs may have seen each other that were not on this chart, right?

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JOSEPH CERCIELLO: Correct. Whatever was given to me is what I reviewed.

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MS. GERAGOS: OK. So you didn't review any other exhibits between that time period where they were communicating with each other or talking about seeing each other, right?

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MS. GERAGOS: OK. And that's why it skips from April of 2022 to July of 2022, right?

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MS. GERAGOS: OK. All right. If we then skip ahead to row 15, the next -- that date is August 25 of 2022 to August 27 of 2022, right?

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MS. GERAGOS: All right. And the names listed there are Jane, Combs and Paul, right?

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MS. GERAGOS: OK. Under Jane, you have several photo exhibits, Government Exhibit E306, E307. Could we bring those two exhibits up, please, and side by side.

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MS. GERAGOS: All right. And these are photographs that you checked were from that date range, right?

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MS. GERAGOS: And does it reflect they're at a dinner table here?

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MS. GERAGOS: All right. They're eating?

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MS. GERAGOS: Mr. Combs has food in front of him?

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MS. GERAGOS: And a drink in front of him?

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MS. GERAGOS: All right. If we could go back to the chart. OK.

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MS. GERAGOS: And then, under Jane, you list Government Exhibit A-510-F, right?

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MS. GERAGOS: All right. So if we could bring up Defense Exhibit 3070, which is the corresponding defense exhibit to A-510-F, and go to page 8 and 9, please. All right.

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MS. GERAGOS: Do you see that these are from August 27 of 2022, UTC time?

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MS. GERAGOS: OK. And Jane writes: "Home, baby. I love you." Right?

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MS. GERAGOS: How does he respond?

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JOSEPH CERCIELLO: "Mad. I feel mangled. I can barely keep my eyes open at this game. Fucked. LOL." And it looks like a laughing-crying emoji.

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MS. GERAGOS: OK. She writes: "OMG, baby, proud of you for pushing through," with tear emojis; "please get some food in your system," pray emoji; "I feel mangled too. I'm beat," with a laughing emoji; "I took a shower sitting down. LOL." How does he respond?

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JOSEPH CERCIELLO: "How you feel."

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MS. GERAGOS: "Mangled, LOL." How does he respond?

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JOSEPH CERCIELLO: "Something was off in that batch."

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MS. GERAGOS: "You took a lot, baby," smiley face emoji; "making love to you is one of the best feelings," with a smile -- tear emoji and several hearts. Right?

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MS. GERAGOS: OK. Could we go to page 10, next page.

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MS. GERAGOS: And then he just responds with a heart face, right?

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MS. GERAGOS: Could we please go back to 1406, please. All right.

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MS. GERAGOS: And you see how under -- we're on line 15 right now -- under both Combs and Paul, you cite to Government Exhibit G-102, pages 10 to 16?

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MS. GERAGOS: OK. Could we pull up G-102, page 16 and 17, please. All right.

Could we just zoom. Perfect. All right.

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MS. GERAGOS: These are from -- the message on the left is page 16, which you included in the chart, right?

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MS. GERAGOS: OK. And these are messages between Mr. Combs and Paul Arthur, and that's why you included them under Combs and Paul, right?

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MS. GERAGOS: And Combs writes to Paul: "Come over." Right?

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MS. GERAGOS: And Paul -- how does Paul respond?

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MS. GERAGOS: What does he say after that?

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JOSEPH CERCIELLO: "Ran into security/driver."

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MS. GERAGOS: And then the next page, which is page 17, which is on the right, you did not include on the chart, right?

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JOSEPH CERCIELLO: That's 17? No.

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MS. GERAGOS: Yes. OK. And Mr. Combs writes: "damn. What they say?" And then: "All good. Happy b'day." Right?

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MS. GERAGOS: OK. We can take that down and bring 1406 back up. All right.

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MS. GERAGOS: Next entry is August 30 of 2022 to August 31 of 2022, right?

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MS. GERAGOS: OK. And the names listed there are Jane, Combs and Paul?

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MS. GERAGOS: OK. And listed under Combs is a government exhibit, A-510-H. Do you see that?

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MS. GERAGOS: OK. So I'd like to bring up Defense Exhibit 3071-R, which is the corresponding defense exhibit to A-510-H, and if we could please go to page 8, please. All right. And page 9, both next to each other, make things easier.

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MS. GERAGOS: All right. And in this message Jane writes: "My place is free tonight." Right?

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MS. GERAGOS: OK. And then he just responds: "Call me"?

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MS. GERAGOS: See that?

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MS. GERAGOS: OK. If we could just skip ahead to page 15, please. All right.

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MS. GERAGOS: And these messages are from UTC time, August 31, 2022. Do you see that?

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MS. GERAGOS: All right. And that corresponds to the ending date range of row 16, right, which is August 30 to August 31?

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MS. GERAGOS: OK. And here Jane writes to Mr. Combs: "Stroking me to heaven tonight. I'm a little mind blown. LOL. Had so much fun, baby. I'll be waiting for you. Love you." And then about an hour and 45 minutes later, she writes: "Baby love, heart, before you lose service..I just genuinely wanted to tell you how much I appreciate your love and care for me. I got on my knees and had a heartfelt thank you to God for my healthy child and for our genuine friendship. I'll never take you for granted and will always make sure you always feel loved and supported by me. My love for you is unconditional and for life. Wishing you the most beautiful eye-opening heart chakra spiritual journey loving trip. Love you so much," with a, I describe this emoji heart and fire. Right?

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MS. GERAGOS: OK. And if we could unzoom it.

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MS. GERAGOS: And he responds with -- I think those are called bit emojis, but I'm not exactly sure, with the face and some hearts, right?

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MS. GERAGOS: OK. Why don't we go to, back to 1406, page 7, please. All right.

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MS. GERAGOS: So the next entry here is approximately a month later, right? We were just looking at August 30th to 31st, and now we are looking at the next entry, which is September 24th to 25th of 2022?

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MS. GERAGOS: OK. And we looked a little bit at this on direct yesterday. You said the location here is 200 South Mapleton and Las Vegas, right?

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MS. GERAGOS: OK. In the flight records you had -- and I'll just correct you; it's Van Nuys. In the flight records, you had Van Nuys to Las Vegas and Las Vegas to Van Nuys, right?

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MS. GERAGOS: Is there a reason why you put Las Vegas as the location here also, in addition to 200 South Mapleton?

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JOSEPH CERCIELLO: Those were the exhibits that were given to me to add to the chart.

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MS. GERAGOS: OK. But you didn't have any evidence of Paul being in Las Vegas, right?

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JOSEPH CERCIELLO: Unless it was given to me, no.

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MS. GERAGOS: OK. Why don't we just pull it up, just to confirm. If we could go to --

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MS. GERAGOS: Under Paul you have written GXG102 pages 31 to 35, right?

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MS. GERAGOS: OK. So let's pull that up. All right.

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MS. GERAGOS: And looking at these messages, these are messages between Paul and Mr. Combs, right?

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MS. GERAGOS: All right. And they're talking about meeting in Burbank, right?

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MS. GERAGOS: All right. Let's go to the next two pages. All right.

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MS. GERAGOS: And then they switch and Mr. Combs says to Paul: "Actually 200 South Mapleton." Right?

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MS. GERAGOS: And he says -- Mr. Arthur says, on page 34: "On my way. 15 minutes away." Right?

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MS. GERAGOS: And let's just go, to make sure we look at everything, to page 35.

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MS. GERAGOS: And then here, again, they talk more about going to Burbank; that's the same address in Burbank, right?

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MS. GERAGOS: All right. And this is September 24 of 2022?

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JOSEPH CERCIELLO: The top message?

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MS. GERAGOS: Sorry. I'm sorry. That's the October 1 of 2022. But the top one, it says "three minutes away" and refers to the 200 South Mapleton message, right?

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MS. GERAGOS: OK. So that's why you have -- if we could go back to 1406 -- you have 200 South Mapleton there and it corresponds to that government exhibit, correct?

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MS. GERAGOS: But Las Vegas, there's nothing that you reviewed that indicates Paul was in Las Vegas, right?

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JOSEPH CERCIELLO: No. Just the flight records for Jane.

306

MS. GERAGOS: OK. Let's just quickly check the flight records. If we could pull up six -- under Jane it lists 6G-116. Let's go to the next page.

307

MS. GERAGOS: This shows -- VNY is the airport code for Van Nuys, right?

309

MS. GERAGOS: OK. Let's go to next page. All right.

310

MS. GERAGOS: And if you look at the passengers, without saying everybody's names, Paul Arthur is not listed as a passenger here on this flight manifest, right?

312

MS. GERAGOS: OK. And if we could go to, I think, the next page -- all right.

313

MS. GERAGOS: And if we look at the passengers on the leg 2 -- so leg 1 is Van Nuys to Las Vegas. Do you see that on the left side of the screen?

315

MS. GERAGOS: Saturday, September 24?

317

MS. GERAGOS: All right. And then the next page, which is Sunday, September 25, that's leg 2. They're returning back into Van Nuys, right?

319

MS. GERAGOS: All right. And Paul Arthur isn't listed as a passenger on that leg of the flight either, right?

321

MS. GERAGOS: OK. So if we could go back to 1406, please.

322

MS. GERAGOS: So what is the reason then for listing Las Vegas in row 17?

323

JOSEPH CERCIELLO: Because at that date range, I was given exhibits that show that there were people traveling to and from Vegas at that time.

324

MS. GERAGOS: OK. So this is just to show that both Jane and Combs went to Las Vegas?

326

MS. GERAGOS: OK. OK.

Next, next line here is about five days later. It's October 1 of 2022, in Burbank, California, right?

328

MS. GERAGOS: All right. And we just looked at that one message in G102 that showed Burbank, right?

330

MS. GERAGOS: OK. So why don't we then go to --

331

MS. GERAGOS: See under Jane, you have listed here G103, pages 43 to 47. That's a conversation between Jane and Paul, right?

332

JOSEPH CERCIELLO: I don't have that memorized.

333

MS. GERAGOS: No problem. Let's bring it up. G103, page 43 to 44. Perfect.

334

MS. GERAGOS: Do you see that this is, without saying her number, this is a message between Jane and Paul?

336

MS. GERAGOS: OK. And here, this is a reach-out from Jane to Paul on October 1 of 2022, right?

338

MS. GERAGOS: And she says: "Hey, hey. Ready for some fun tonight." Right?

340

MS. GERAGOS: OK. And what does he respond with?

341

JOSEPH CERCIELLO: "Absolutely."

342

MS. GERAGOS: And next page?

343

JOSEPH CERCIELLO: There's no message in the first one. "How you feeling?"

344

MS. GERAGOS: She responds: "Great." Right?

346

MS. GERAGOS: Next two pages. And she says: "The butlers are meeting to help for about 30 minutes, 30 to 45 minutes, so I was saying about an hour or so. What time did he tell you to come?" What does he respond with?

348

MS. GERAGOS: She says: "Maybe 1:45." How does he respond?

350

MS. GERAGOS: "There's a lobby if you are early, but I just asked guys your ETA. I think ten mins so add 15 to that." Right?

352

MS. GERAGOS: All right. So if you could go to G102, pages 37 and 38, please. All right.

353

MS. GERAGOS: And this is a message between Mr. Arthur and Mr. Combs, right; same day?

355

MS. GERAGOS: OK. And Mr. Combs writes to Paul: "We in a serious vibe. How you feeling." Right?

357

MS. GERAGOS: All right. How does Paul respond?

358

JOSEPH CERCIELLO: "I'm feeling good."

359

MS. GERAGOS: And Mr. Combs writes: "LMG." Right?

361

MS. GERAGOS: OK. If we could go to, next page, please. All right.

362

MS. GERAGOS: And then on the left side of the screen, on page 39, Mr. Combs writes to Paul: "Hold up. The staff is outside. They leave now. Hang tight." Right?

364

MS. GERAGOS: All right. Let's go back to 1406, please. All right.

365

MS. GERAGOS: So looking at this page, and this is page 7, the first time you see Antoine show up in your chart, 1406, is item -- row 19, right?

367

MS. GERAGOS: Because if you look, it's in front of you. We could go through all the pages, but if you look at pages 1 through 6, there's no mention in the names column anywhere of Antoine, right?

369

MS. GERAGOS: He first shows up October 8 of 2022?

370

JOSEPH CERCIELLO: He shows up within that time frame, yes.

371

MS. GERAGOS: OK. And that's 19 time periods into your chart, right?

375

MS. GERAGOS: OK. If we could, if you look under, let me check.

376

MS. GERAGOS: If you look under Jane and also under Paul, you cite to G103, page 48 to 51. Do you see that?

378

MS. GERAGOS: All right. Could we go to G103 and just put up pages 49 and 50 next to each other. All right.

379

MS. GERAGOS: And you see that -- and again, this is 103, which is a message chain between Jane and Paul, right?

381

MS. GERAGOS: All right. And this is October 8 of 2022, UTC time, Jane writes: "OK. Cool. Not sure what the vibe is today, but will def hit you up and see where you're at and all that." Right?

383

MS. GERAGOS: How does he respond?

384

JOSEPH CERCIELLO: "OK. Sounds good."

385

MS. GERAGOS: Next page, she writes: "What's your availability today? We're trying to meet in the BH, if trying to meet in the BH or Burbank area?" And what does he respond?

386

JOSEPH CERCIELLO: "I'm available after eight."

387

MS. GERAGOS: And she says: "OK. Great. Keep me posted," exclamation point. Right?

389

MS. GERAGOS: Now, that is again on October 8 of 2022, right, UTC time?

391

MS. GERAGOS: All right. So let's go to G-102 at pages 41 and 42, which you have listed under Combs.

392

MS. GERAGOS: All right. And these are messages between Combs and Paul, right?

394

MS. GERAGOS: All right. And on the left-hand side, these are the ones we were just looking at, the middle text message is afterwards; it's October 9 of 2022 at 2:09 p.m. UTC time, right?

396

MS. GERAGOS: OK. And Mr. Combs writes to Paul the address in Burbank, right?

398

MS. GERAGOS: OK. And all right. Let's head back to 1406. All right.

399

MS. GERAGOS: So we're leaving off, and again, this is the first time Antoine appears on your chart, and that's row 19 on page 7, and we're on October 8th to 9th of 2022, right?

401

MS. GERAGOS: All right. So next page is page 8, and that next date is about a month later, on November 6 of 2022, right?

403

MS. GERAGOS: All right. And the names listed here are Jane, Combs and Paul, right?

405

MS. GERAGOS: All right. So under Jane you have listed G103, pages 51 to 65, right?

407

MS. GERAGOS: And then, and then also under Jane is Government Exhibit A-104-35, right?

409

MS. GERAGOS: Let's just take those in turn. If we could pull up G103, 51 and 52 side by side. All right.

410

MS. GERAGOS: And this is again a message between Paul and Jane, and you see the message on the left-hand side, that's Jane to Paul on November 5, so one day earlier, 10:55 p.m. UTC time, right?

412

MS. GERAGOS: And she writes: "Hey, P. Hope you're well. Are you possibly free this evening? It's for his b'day." Right?

414

MS. GERAGOS: And what does he respond with?

415

JOSEPH CERCIELLO: "I'll be back in town tomorrow morning."

416

MS. GERAGOS: She says: "Oh, OK. What time do you land?"

417

MS. GERAGOS: Next two pages.

418

MS. GERAGOS: What does he say?

420

MS. GERAGOS: OK. She says, on the next page, skipping some messages: "LOL. Safe travels." Right?

422

MS. GERAGOS: OK. Let's go to the next two pages.

423

MS. GERAGOS: And she says: "No way you can arrive late tonight." Right? How does he respond?

425

MS. GERAGOS: She says: "OK. Darn. See you bright and early in Burbank. Haha." How does he respond?

427

MS. GERAGOS: She says: "Hey, P. Have you landed yet? Do you need addy here?" And she gives him the address in Burbank, right?

429

MS. GERAGOS: We can go to the next two pages.

430

MS. GERAGOS: And then she responds again: "LMK when you land," exclamation point. And how does he respond?

431

JOSEPH CERCIELLO: "Just landed."

432

MS. GERAGOS: "OK. Great," exclamation, exclamation, "come," exclamation, exclamation. Right?

434

MS. GERAGOS: Next page. And then he says: "Five mins away," and she says: "Hi. OK," right?

436

MS. GERAGOS: All right. So now let's look at Government Exhibit A-104-35, if we could go to page 4.

437

MS. GERAGOS: This is the messages between the two of them that you have listed under her name in the chart, right? Do you recall citing to A-104-35?

439

MS. GERAGOS: OK. And if you see on the last message, which is November 10 of 2022, she says: "Baby, just settled in. Love and appreciate you..here if you need me," with two hearts. Right?

441

MS. GERAGOS: OK. Let's go back to our chart. So the next entry we have is December 18, yes, to December 20 of 2022. The jury's seen that.

442

MS. GERAGOS: So we'll skip ahead to the next entry, which is row 22, January 9 of 2023, right?

444

MS. GERAGOS: All right. And you have several photos under Jane, the GX E281 to E283. Do you see that?

446

MS. GERAGOS: And we also have E285?

448

MS. GERAGOS: All right. Could we take those in turn. If we could go to E281 and then two put them side by side.

449

MS. GERAGOS: Those are photos of the two of them that you determined to be during that date range?

451

(Continued on next page)

452

BY MS. GERAGOS:

453

MS. GERAGOS: If we could go to 283 and 285 -- sorry E-283 and E-285. That's another photo of them that you determined to be from that date range, right?

455

MS. GERAGOS: Do you see that bracelet there that she's wearing?

457

MS. GERAGOS: And then E-285 is on the right side of the screen, right?

458

JOSEPH CERCIELLO: I can't see the exhibit number. It says Menu.

459

MS. GERAGOS: Why don't we just have E-285 up and take down E-283. You see E-285?

461

MS. GERAGOS: This was found on her phone?

462

JOSEPH CERCIELLO: I believe the iCloud, yes.

463

MS. GERAGOS: The iCloud, I apologize. You're right, the iCloud.

465

MS. GERAGOS: There's several heels here, several female outfits. Do you see that?

467

MS. GERAGOS: Do you see on the bottom part of the -- middle part of the screen, I should say, the boxer briefs that are -- there's two of them there. Do you see those?

468

JOSEPH CERCIELLO: I can't decipher what those are. Not on this screen, no.

469

MS. GERAGOS: Yeah, this screen is a little hard to see at times. Okay. No problem.

Could we bring up Defense Exhibit 3080-R, page 3.

Do you see that this is January 12, 2023 at 5:16 a.m. that's UTC time?

471

MS. GERAGOS: And this is two days-ish, maybe one day, after the entry at line 22, which is January 9, 2023 to January 10, 2023, right?

473

MS. GERAGOS: All right. And she writes to him: "Love you baby. Hope you have a good night. I'm gonna sleep early. I loved every minute WU," right?

475

MS. GERAGOS: If we could take that down. If we go to the next page, which is page 9.

476

MS. GERAGOS: The next entry there is January 20, 2023 to January 22, 2023, right?

478

MS. GERAGOS: And this is -- I think we could just turn the screen back on and put up 1407-R, and go to page 30. We can turn on the screens very briefly. We don't do it in detail since we've already done it in detail on direct examination.

479

MS. GERAGOS: Starting at page 30 here, this corresponds to generally to line 23 of 1406, right?

481

MS. GERAGOS: And the first record here listed at line 337 is a travel record from Las Vegas to SNA for Kabrale Williams. Do you see that?

483

MS. GERAGOS: And you didn't have any -- you didn't review any exhibits that showed that either Jane or anybody affiliated with Mr. Combs booked that travel record, right?

484

JOSEPH CERCIELLO: Booked that Spirit Airlines travel record?

486

JOSEPH CERCIELLO: I don't remember I would have to see that exhibit.

487

MS. GERAGOS: Okay. We could -- I think we can bring up 6J-104.

We're having trouble bringing it up.

Can we go quickly to page 32 here? The last two lines, lines 359 and 360, are messages from Jane to Combs and Combs to Jane, right?

489

MS. GERAGOS: Jane says: "Want to send one of the guys here to drop everything off?" Do you see that?

491

MS. GERAGOS: And how does he respond?

492

JOSEPH CERCIELLO: "I don't want them to know."

493

MS. GERAGOS: If we could skip ahead to page 37. And then Combs writes to Jane on line 413: "Paul gonna meet us at 9:30," right?

495

MS. GERAGOS: If you could go to the next page. And the next page.

Actually, what we should do -- I'm so sorry to do this Mr. Deputy. Can we turn off the screens again? Am I good to proceed? Can we pull up DX-3083 which is the corresponding Defense Exhibit to those and go to page 13, please and page 14.

If we could actually go to page 12 and 13 next to each other.

496

MS. GERAGOS: You see that message from Mr. Combs, he says: "Paul gonna meet us at 9:30," right?

498

MS. GERAGOS: And her response on the next page is: "Okay baby. All sounds good," with a winky face and a tongue-out face emoji, right?

500

MS. GERAGOS: If we could go to -- then below on the last two messages on page 13, she writes: "Everything is going to be lovely when we see each other. I'll text as soon as I am in the car, okay. Okay. Perfect. I'm rushing. No worries. I'll be fast," right?

502

MS. GERAGOS: And then if we could go to 14 and 15, please.

503

MS. GERAGOS: And he says: "Can I walk in on you and Paul? I would like that, WYD," right?

505

MS. GERAGOS: And she says: "Yes."

And he says: "Okay. So what time should I tell him?"

And how does she respond?

506

JOSEPH CERCIELLO: "Maybe 9:30 so he doesn't run into anyone?"

507

MS. GERAGOS: If we could go back to 1407-R. If we could go to page 43.

We could very briefly I think turn back on the public screen

508

THE COURT: Are the screens back on?

509

MS. GERAGOS: They're back on.

510

MS. GERAGOS: At this point now we're at page 43 on January 21 of 2023, she writes to him: "Good morning" smiley face. UR in town. Are you awake," right?

512

MS. GERAGOS: At this point we looked at these messages at length yesterday, so I don't want to go one by one, but at this point she already sent money to Cowboys4Angels, do you remember that, the day before?

513

JOSEPH CERCIELLO: I'd have to review that.

514

MS. GERAGOS: We could go -- let's turn the screens off then.

515

THE COURT: Let's turn the screens off.

516

MS. GERAGOS: We could go back to 1406 page 9. Do.

517

MS. GERAGOS: You remember this text where Combs sends to Jane the flight -- if you look under Reggie, "The flight is $420. And this is an overnight rate. You can Cash App the $420 for the flights and the $680. Total $1100. $Cowboys4Angels," right?

519

MS. GERAGOS: Do you recall that?

521

MS. GERAGOS: At this point, she has also communicated with Paul, do you recall that?

Jane had communicated with Paul by this point? If not, we can pull up the exhibit.

522

JOSEPH CERCIELLO: Yeah, I don't remember every interaction.

523

MS. GERAGOS: I understand.

524

MS. GERAGOS: Why don't we go to G-103, page 68.

525

MS. GERAGOS: Do you see how the bottom message here, she reaches out to Paul and says: "Hey P!"?

527

MS. GERAGOS: Let's go to the next two pages, please.

528

MS. GERAGOS: And she says: "Just wondering if you were here yet. If not, it's okay. I need a sec anyway," right?

530

MS. GERAGOS: The next page, she says: "Okay, let me make sure the coast is clear," right?

532

MS. GERAGOS: And then do you remember looking at the messages from these times where -- I mean, from the day before where she told Mr. Combs that it was a thumbs up for debauchery night?

533

JOSEPH CERCIELLO: I remember generally, yes.

534

MS. GERAGOS: And then we just looked at 1407-R where she then texts Kabrale, where she says, "Hey, good morning. UR in town. Are you awake?" Right, the one we just looked at?

536

MS. GERAGOS: Could we pull up Defense Exhibit 3084, page 3, please. Let's go to page 1 so we could see the participants.

537

MS. GERAGOS: This is between Mr. Combs and Jane, right?

539

MS. GERAGOS: And these are from January 24, 2023, 4:00 a.m., UTC time though, right?

541

MS. GERAGOS: So this is directly after the line item in 23 which is January 20, 2023 to January 22, 2023?

543

MS. GERAGOS: So can we please now go to page 3. We could zoom in on the bottom two messages.

544

MS. GERAGOS: And she says, "I'm home baby. Thank you for prioritizing our dinner. Means a lot to me. Safe travels to you, the fam, and the team. I love you," right?

546

MS. GERAGOS: If we could go back to 1406 -- this is 1407. We could go back to 1406. Sorry. Government Exhibit 1406. There we go, page 9.

547

MS. GERAGOS: So we just finished briefly reviewing what we've already extensively reviewed which is January 20, 2023 to 22 of 2023, right?

549

MS. GERAGOS: All right. And now the jury has seen a lot on item 24, but the item 24 is February 7, 2023 to February 10 of 2023, right?

551

MS. GERAGOS: That's at the Nobu Hotel?

553

MS. GERAGOS: Let's go to the next page.

554

MS. GERAGOS: These two date ranges cover March of 2023, right?

556

MS. GERAGOS: So there's a date in March 15 of 2023, that's Miami, Florida. And then Turks and Caicos is the 16th to the 19th, right?

558

MS. GERAGOS: If we could pull up -- then if we could just go to the next page, which is page 10 -- I mean, 11. Thank you.

559

MS. GERAGOS: Then right after Turks and Caicos, you list Four Seasons, Miami, Florida, March 21 of 2023 to March 23 of 2023, right?

561

MS. GERAGOS: Could we go to -- and Kabrale is listed there?

563

MS. GERAGOS: And then the conversations between Kabrale and Jane are GX-F-101, do you recall that?

565

MS. GERAGOS: So we could just go to the corresponding Defense Exhibit, which is 3328, please, and go to page -- start at page 171.

566

MS. GERAGOS: This is the corresponding exhibit. These start at March 16 of 2023, right?

568

MS. GERAGOS: And Jane here writes: "Hey, how are you? Hope all is well. Sorry haven't been in touch. Just been busy W life. I was wondering I had some time off this Friday-Saturday. Would you be able to come to Turks by any chance? You would need a passport, and I think vaccination card. LMK what you think."

What does he respond with?

569

JOSEPH CERCIELLO: "Wassup lovely. You're good. Yes, I will be available I. definitely have my passport. I don't have a vaccination card though."

570

MS. GERAGOS: She says: "Hi. Okay. Hmm. I'll see if we have any connections to make one or would you have any in ATL?"

What does he say?

571

JOSEPH CERCIELLO: "I'll ask around."

572

MS. GERAGOS: She responds: "Yes" with a hands up emoji. And she says down below, "Hey, good morning. Okay. Great. I'll ask. I tried asking if a photo proof was enough or if it needed to be hard copy. I'll re-ask again. Didn't hear back! But yes LMK," right?

574

MS. GERAGOS: All right. Then if you could go to 175 to 176, please.

575

MS. GERAGOS: And now this is a few days later. This is March 21 of 2023, right?

577

MS. GERAGOS: This is a date that corresponds to row 27 on page 11 of 1406?

579

MS. GERAGOS: She reaches out to him and says: "Hey, how are you? Would you happen to be available tonight for this 10:59 flight to Miami, by any chance?"

And how does he respond?

580

JOSEPH CERCIELLO: "Wassup beautiful. Yes, I could make it."

581

MS. GERAGOS: "Okay, Let me try to work this out" with a fairy emoji and more emojis."

He loves that message, right?

583

MS. GERAGOS: She says: "Okay. I'm organizing it now. It should take about an hour to get this flight. There's only one left. Hope I can get it in time," right?

585

MS. GERAGOS: Next page, she says: "Hi. You're all set! Don't miss your flight. LOL! I'll let you know hotel to meet up once I have it," right?

587

MS. GERAGOS: How does he respond?

588

JOSEPH CERCIELLO: "Bet it up lovely" with a smiley emoji "Excited to see you as always. I'll let you know when I'm at the airport."

589

MS. GERAGOS: She says: "Me too." She says: "Okay. Cool." Smiley face, right?

591

MS. GERAGOS: Could we go to 179 to 180?

592

MS. GERAGOS: All right. Now, do you see her message at the bottom there on March 22, 10:13 p.m. UTC time?

She says: "Tonight was amazing. Thank you for always bringing that good energy. I can't find my gold bracelet. If you remember where I put it, LMK" with prayer hands "TYSM," right?

594

MS. GERAGOS: What does he respond with?

595

JOSEPH CERCIELLO: "Wassup lovely. No problem, and it should be on the sheets on the floor by the couch last place I seen it."

596

MS. GERAGOS: Could we go to page 182. All right.

597

MS. GERAGOS: She says: LOL!! OMGGGG. Okay. I'm glad you got some. I'm about to sleep now. Tonight was fun!Text me when you land."

And what does he say?

598

JOSEPH CERCIELLO: "Good night lovely. Definitely had a great time with you baby," with a smiling emoji.

599

MS. GERAGOS: Okay. We can take that down.

600

MS. GERAGOS: The next date listed here on row 28 is April 19 of 2023 to April 20 of 2023, right?

602

MS. GERAGOS: And the names listed are Jane, Combs, and Paul?

604

MS. GERAGOS: Under Paul, it says G-103, pages 102 to 113?

606

MS. GERAGOS: Could we go to G-103 but start earlier at page 87, please.

607

MS. GERAGOS: Do you see that these are messages between Jane and Paul?

609

MS. GERAGOS: All right. And these start on page 87 a little bit earlier than April 19, right? They start on April 14, 2023 UTC time?

611

MS. GERAGOS: And these pages 87 and 88, these are not included in your chart, right?

613

MS. GERAGOS: And Jane writes here: "Hey, Paul. Hope you're well. I'm trying to organize a welcome home evening for Sean. I don't think it will be this weekend but I'm not too sure ... Either way just wanted to know your schedule this weekend and 17th week? Thank you!" right?

615

MS. GERAGOS: And he responds saying: "Hey" and Jane's true name "I'm available 17th to the 20th," right?

617

MS. GERAGOS: She says: "Okay, those dates are perfect. We'll all be in LA. Okay, those dates are perfect. We'll all be in LA," right?

619

MS. GERAGOS: I guess it's edited. It's an edited message. The label says edited?

621

MS. GERAGOS: And he loves that message?

623

MS. GERAGOS: Then if we could go to the next two pages.

624

MS. GERAGOS: She says: "I'm thinking 18th, but keep you posted," right?

626

MS. GERAGOS: He responds: "Okay"?

628

MS. GERAGOS: And she says: "You're free Thursday the 20th and unavailable Friday the 21st," right?

630

MS. GERAGOS: How does he respond?

632

MS. GERAGOS: And then two text below, she says to him -- and this is the 15th now, April 15, 2023 at 3:47 p.m. UTC?

634

MS. GERAGOS: She says: "Hey P. Good morning. Sean's schedule is more flexible for today. Are you possibly also available too? Thank you," right?

636

MS. GERAGOS: Next page.

637

MS. GERAGOS: And then she says: "NVM. It might be for Tuesday," right?

639

MS. GERAGOS: Two texts below, she says: "Hey Paul" -- and this is the 17th now, April 17, 5:38 p.m., page 91, right?

641

MS. GERAGOS: This still -- page 91 and page 92 are still not what's listed in your chart on line 28, right?

643

MS. GERAGOS: And she says: "Hey Paul. Good morning! Sean just texted me Thursday .... And you have to leave at what time Friday? Thank you."

And what does he say?

645

MS. GERAGOS: She says: "Oh boy LOL."

What does he say?

646

JOSEPH CERCIELLO: "LOL I know."

647

MS. GERAGOS: So she says: "Okay. Cool we'll see you for sure Thursday. Maybe we'll link earlier," right?

649

MS. GERAGOS: She says: "Okay. And so you have to be out at 7:00 a.m. or like 6:00 a.m."?

And what does he say?

651

MS. GERAGOS: She says: "Okay. Got it. Thanks P. Keep you posted," right?

653

MS. GERAGOS: Go to the next two pages.

654

MS. GERAGOS: She asks again on the 17th, "Are you also available Wednesday," right?

656

MS. GERAGOS: And the next page she says: "Okay, perf. Then try and organize," right?

658

MS. GERAGOS: And then at the bottom, she says: "Hi. When are you back FR UR trip," right?

660

MS. GERAGOS: Next two pages. Thank you. All right.

661

MS. GERAGOS: And if you look at page 98, she writes him: "What time do you land the 22nd? That might actually work a lot better for us," right?

663

MS. GERAGOS: "I'll relay message. I think Saturday is best," right?

665

MS. GERAGOS: Okay. If we could keep going.

666

MS. GERAGOS: Pages 99 and 100 are more messages with them organizing, correct? Do you see that?

668

MS. GERAGOS: Okay. We could go to the next two pages.

669

MS. GERAGOS: And then at 102, which is the page on the right, she writes: "Hey, did he give you a time for today? It's around 6," right

671

MS. GERAGOS: And that's when you start -- in the chart, that's when you start the government exhibit for this time period, right?

673

MS. GERAGOS: Which is April 19, is that right?

675

MS. GERAGOS: Okay. If we do just go one -- sorry, I wanted to go back to that exhibit and go a few more pages. If we could go to the next two pages. And then if we could --

676

MS. GERAGOS: Paul says: "He didn't give me a time," right?

677

MS. GERAGOS: And if we could just zoom in -- I'm not sure it will show up. If we could zoom in on the attachment on page 104.

678

MS. GERAGOS: Do you see how that says: "L'Ermitage Beverly Hills"?

679

JOSEPH CERCIELLO: It appears that way, yes.

680

MS. GERAGOS: And Jane is sending that to Paul, right?

682

MS. GERAGOS: And that's what you determined to be -- to fall in the date range on row 28, right?

If you look at row 28, you list location as the L'Ermitage Hotel?

684

MS. GERAGOS: Could we go to the next two pages?

685

MS. GERAGOS: So he -- and then if you look at her message on the bottom on the left: "He just 445. So give it a beat for security and drop off," right?

687

MS. GERAGOS: Then the next page, she says: "Running a little behind. I think it's going to be closer to 6 honestly." You see that?

689

MS. GERAGOS: Okay. If you go to the next two pages.

690

MS. GERAGOS: And she says: "He just pulled up so give it a beat," right?

692

MS. GERAGOS: And the next page, on page 108, she says: "He's still making sure everyone's gone outside," right?

694

MS. GERAGOS: How does he respond?

696

MS. GERAGOS: "Okay, that's perfect" is her response, right?

698

MS. GERAGOS: Next two pages.

699

MS. GERAGOS: And then if you look at the page 110, she says: "OMG P! You should have been here. Come! How long," right?

701

MS. GERAGOS: All right. Next page.

702

MS. GERAGOS: And then if you look at page 112, she says: OMG. Okay. Hurry. I thought you meant you were 25 min away."

"Paul how far are you," right?

704

MS. GERAGOS: And then she gives him the room number on page 113. Do you see that?

706

MS. GERAGOS: Let's go back to 1406. Perfect. All right.

707

MS. GERAGOS: And then the next row is row 29. Do you see that?

709

MS. GERAGOS: The names listed there are the same Jane, Combs, and Paul, right?

711

MS. GERAGOS: And under Jane, you list Government Exhibit A-442-12. Do you see that?

713

MS. GERAGOS: All right. If we could pull up the corresponding Defense Exhibit to that Government Exhibit, which is 3127, please, and go to pages 1 and 2.

714

MS. GERAGOS: Here he writes at the bottom on April 24, 2023, "Can we have a party at your house later? I'll set up. Let me know. Or tomorrow?" Right?

716

MS. GERAGOS: The next he writes four question marks, right?

718

MS. GERAGOS: She responds: "Hey baby, call me back"?

720

MS. GERAGOS: How does he respond?

721

JOSEPH CERCIELLO: "In booth. Can you tonight? What's your vibe? I still got some freak in me."

722

MS. GERAGOS: She loves that message. And says: "You want me baby. Yes. tonight works" kissy face, wink with tongue out face "Give me my dick."

And how does he respond?

723

JOSEPH CERCIELLO: "Yeah, I think the party could have been better. No fault of yours."

724

MS. GERAGOS: If we could go to the next two pages.

725

MS. GERAGOS: He says: "Reach out" -- that's your line. How does he respond?

726

JOSEPH CERCIELLO: "Reach out to the Italian."

727

MS. GERAGOS: She says: "My house isn't free because there's open boxes and clothes everywhere." And emphasizes, "Yeah, I think the party could have been better," right?

729

MS. GERAGOS: And he how does he respond?

731

MS. GERAGOS: She says: "The party could have been better, really? Why..."

And how does he respond?

732

JOSEPH CERCIELLO: "Okay. Where. You find place. I can't have KK know. Damn."

733

MS. GERAGOS: She says: "Okay" -- sorry -- "I'll reach out. How about P?"

How does he respond?

734

JOSEPH CERCIELLO: "Imma reach out."

735

MS. GERAGOS: And she says on page 4: "Italian is avail. I said I'd confirm time and location once I have it."

How does he respond?

736

JOSEPH CERCIELLO: "Okay. Can you find location PLS."

737

MS. GERAGOS: Can we skip ahead to page 24 of this and 25.

738

MS. GERAGOS: She writes on April 25, 12:14 a.m. UTC time, so that's the 24th: "Should we postpone TMW. I need to find the card and try and book the room on our own and organize a few things on my end."

And how does he respond?

739

JOSEPH CERCIELLO: "No, I'll handle. No stress. Just fine for me."

740

MS. GERAGOS: Then if you look at page 25, halfway down the page starting with: "You okay?"

How does he respond?

741

JOSEPH CERCIELLO: "You okay? If you ain't in the mood. You in the mood?"

742

MS. GERAGOS: She says: "Yes. Just wanting to feel prepared," right?

744

MS. GERAGOS: If we could go to -- perfect.

She says: "didn't know you were unsatisfied."

And how did he respond?

745

JOSEPH CERCIELLO: "So will you be parpared by 11?"

746

MS. GERAGOS: Then if you look at the next page, page 27, she says: "I stopped to got a couple more outfits N stuff."

What does he respond with?

747

JOSEPH CERCIELLO: "I booked already."

748

MS. GERAGOS: Then she responds: "Okay, baby. Just tidying up here and ordering dinner and then getting ready. Should I tell Italian 11:30 and then just LMK where."

And what does he say?

750

MS. GERAGOS: Next page, she writes to him: "Hustler is on the way there. If there's anything last minute we need, just LMK babe," right?

752

MS. GERAGOS: What does he respond?

753

JOSEPH CERCIELLO: "Whatever you think."

754

MS. GERAGOS: She says okay with a -- I suppose that's a thinking emoji and says: "Joey just called me. Are him and I supposed to talk about anything," right?

756

MS. GERAGOS: So if we could go to page 34 and 35, please.

757

MS. GERAGOS: At the bottom of this page, he writes: "Did you get pill? Hit me when coast clear. Hey," right?

759

MS. GERAGOS: What does she respond with?

760

JOSEPH CERCIELLO: "Hey babe, yeah. Joey is gone I hope and Italian is pulling up."

761

MS. GERAGOS: If we could now go to 37 or -- 37 -- page 37. All right.

762

MS. GERAGOS: So do you see the bottom of this page is April 25, 2023 at 11:38 p.m. UTC time?

764

MS. GERAGOS: She writes: "You dicked me down so amazing baby. You had this pussy so juicy all night. Damn," right?

766

MS. GERAGOS: Can we go to next page?

767

MS. GERAGOS: She says: "I love you loving on me n me you," right?

769

MS. GERAGOS: And that is if you look at -- if we go back to 1406, row 29 of page 11. No. No. Government Exhibit 1406. Thank you. And page 11.

770

MS. GERAGOS: And that is -- that corresponded to the end of the date range here in row 29, right?

772

MS. GERAGOS: And if we go to the next page, it's about three weeks later, May 15 to May 16 of 2023, right?

774

MS. GERAGOS: All right. And there are no -- you list several Government Exhibits under Jane, Combs, Paul and Kabrale. Do you see that?

776

MS. GERAGOS: You don't list any communications between Jane and Combs for this date range.

Is there a reason why you didn't list any communications between the two of them that correspond to this date range?

777

JOSEPH CERCIELLO: Again, if it's not listed on the chart, it's because they weren't provided to me as an exhibit to review.

778

MS. GERAGOS: Okay. Could we pull up --

779

MS. GERAGOS: Let me ask you this way: Do you remember reviewing Government Exhibit A-442-15 or do you not know either way?

780

JOSEPH CERCIELLO: I would have to see the exhibit.

781

MS. GERAGOS: Could we pull it up just for the witness and the parties only A-442-15.

782

MS. GERAGOS: Do you see in the -- the question is only whether --

783

MS. GERAGOS: We could go to the next page, you could see the dates.

784

MS. GERAGOS: -- whether you reviewed this exhibit when preparing the chart?

785

JOSEPH CERCIELLO: If this exhibit is listed in the chart, anywhere in the chart, then yes, I reviewed it. I just --

786

MS. GERAGOS: Okay, but it doesn't refresh your recollection looking at it as to whether you reviewed it?

787

JOSEPH CERCIELLO: No. I've seen a lot of exhibits that look like this, and I just don't have it memorized.

788

MS. GERAGOS: Okay. Understood.

789

MS. GERAGOS: Pull up Defense Exhibit 3130. This is in evidence so it can be for the jury as well.

790

MS. GERAGOS: Do you see that this is May 12 of 2023?

792

MS. GERAGOS: And this is just a few days before for the entry listed on row 30 which is May 15, 2023 to May 16 of 2023, right?

794

MS. GERAGOS: Could we go to page 3 and 4, please.

795

MS. GERAGOS: And do you see that Jane writes here: "I know what you like daddy," right?

797

MS. GERAGOS: What does he respond?

798

JOSEPH CERCIELLO: "The last time with chef or time after."

799

MS. GERAGOS: She says: "You gotta delete our texts after. LOLLLL" with many L's. "The last time at The London when I was super hot, you were like" and then multiple emojis, right?

801

MS. GERAGOS: She says: "At the London before you left for NYC, we didn't film. You forgot it." With an emoji. "You promised you wouldn't forget," right?

803

MS. GERAGOS: Can we go to page 5, please?

804

MS. GERAGOS: How does he respond?

805

JOSEPH CERCIELLO: "Can't nobody fuck with you. Come get all this nasty kinky loving."

806

MS. GERAGOS: All right. And she loved both of those messages and then sends several emojis: The smirk face we've talked about, the kissy face, devil face, eggplant emoji, several kiss faces and tongue-out emojis, right?

808

MS. GERAGOS: She says: "I hear you daddy n I'm coming baby. Nasty kinky good loving."

On the next page on page 6, she says: "Baby can you send me something TMW so I can arrange it and get a few things? Baby I love you. I'm message you as soon as I wake up. That video you sent me was hot" with like the sweat emoji, the smirk emoji and several others, and then says: "Can't wait," right?

810

MS. GERAGOS: If we could go to page 8, please.

811

MS. GERAGOS: She writes May 12, 4:14 p.m.: "Chef's avail Monday. Hi babe. Trying to reach you," right?

813

MS. GERAGOS: She says: "Baby, was just needing you to help me arrange a couple things and get a few things today for the trip but can't reach you. Think we won't make the cutoff time."

Then a few hours later: "Baby all is set" with hearts, right?

815

MS. GERAGOS: If we could go to -- if you look at your 1406 at line 30, under Kabrale, you list the Government Exhibit F-101 there, right? Do you see that?

817

MS. GERAGOS: Could we just go to the corresponding Defense Exhibit, which is 3328, and go to page 189. If we could go pages side by side, that would be helpful.

818

MS. GERAGOS: These are the same date, May 12 of 2023. Do you see that? And then on the right side, it's May 13 of 2023, but all in UTC time, do you see that?

820

MS. GERAGOS: She says: "Hey good morning. Happy Friday" smiley face. "Was just wondering your availability this Monday, the 15th to fly into Miami," right?

822

MS. GERAGOS: On the next page, skipping ahead in some text message, she says: "Hey so would you be able to come to Miami maybe early evening this Monday. I'll do the flights now and figure out the hotel maybe the night before or day of once I know," right?

824

MS. GERAGOS: We could go to next page. If you look at page 191, are they texting there to coordinate flights?

825

JOSEPH CERCIELLO: It appears that way, yes.

826

MS. GERAGOS: Could we skip ahead to page 195 and 196, please.

827

MS. GERAGOS: This is May 15, right, which is the date listed on your chart?

829

MS. GERAGOS: And she says: "I'm just setting up the hotel now, and I'll send to you shortly," right?

And then do you see on page 196, he says: "just boarded love."

She loves that message. And she says: "okay yay" with several celebration emojis?

831

MS. GERAGOS: Let's go to the next two.

She says: "Text me when you land safely."

What does he respond with?

832

JOSEPH CERCIELLO: "I landed baby. Just called my Uber to the hotel."

833

MS. GERAGOS: She says: "Okay" with a -- I guess a celebration emoji.

"Text me when you check in and rush over" with a smiley face, right?

835

MS. GERAGOS: The next page she sends him: "You okay?"

And that is about 20 minutes later, right?

837

MS. GERAGOS: And sends him several more emojis, right?

839

MS. GERAGOS: If we could go to page 199. All.

840

MS. GERAGOS: She says here on May 16, 3:05 a.m. UTC time: "Give me a sec. Clearing out the assistant. They had to stop by to drop off stuff. Can you wait in lobby for an SEC," right?

842

MS. GERAGOS: How does he respond?

844

MS. GERAGOS: She says: "Give me like ten more mins. I'm trying to rush them out. Hi. Can you call 640 Chavez," right?

846

MS. GERAGOS: Then this is several hours later: "Hey hon. Hope you're resting well. We just wanted to say thanks for coming out and always bringing your good energy" heart. "Also do you have Zelle I can send you payment through there," right?

848

MS. GERAGOS: If we could go back to 1406. Government Exhibit 1406, page 12.

849

MS. GERAGOS: There's several E series exhibits on Jane's name here, right?

851

MS. GERAGOS: Could we just pull up -- just we'll review just a few of them, E-278 and E-279.

852

MS. GERAGOS: These were photos from Jane's iCloud account, right?

854

MS. GERAGOS: And you reviewed these. They were taken at approximately this time period, right?

856

MS. GERAGOS: Could we pull up E-287 and E-288 side by side.

857

MS. GERAGOS: These are two photos taken also from her iCloud account, right?

859

MS. GERAGOS: And if we could then pull up E-289 and E-292 side by side. Actually, I don't think we need E-289. We could pull up E-292.

860

MS. GERAGOS: Do you see that, that's a photo of Jane from her iCloud?

862

MS. GERAGOS: And then E-293 and E-295.

863

MS. GERAGOS: These are also two photos of them taken from her iCloud account?

865

MS. GERAGOS: From that same date range, right?

867

MS. GERAGOS: All right. If we go back to Government Exhibit 1406.

868

MS. GERAGOS: Listed under Paul is G-101, pages 16 to 26, right?

870

MS. GERAGOS: Could we pull up G-101 and go to page 23, please. Let's do 22 and 23 side by side.

871

MS. GERAGOS: Paul writes to Mr. Combs: "Just got my food. I'll be there in 30 minutes," right?

873

MS. GERAGOS: He says: "All good."

On the next page, he says: "you don't have to king. for real you good," right?

875

MS. GERAGOS: And Paul says: "Yeah. Just needed some food. Other than that, I'm good," right?

877

MS. GERAGOS: And then if we could look at what's already in evidence as Government Exhibit A-442-16. Go to pages 7 and 8.

878

MS. GERAGOS: These are from approximately the same time period, right, May 15?

880

MS. GERAGOS: Do you see that?

882

MS. GERAGOS: And if you look at your chart, you have it in front of you, this was not -- A-442-16 was not included in your chart, right?

884

MS. GERAGOS: For row 30.

885

JOSEPH CERCIELLO: No, it's not listed.

886

MS. GERAGOS: This is a message you see between Jane and Combs?

888

MS. GERAGOS: And she writes: "I'm just here baby. I'm showering now," right?

890

MS. GERAGOS: What does he respond with?

891

JOSEPH CERCIELLO: "What you want me to do. Me and Paul gonna finish a workout. Then we're coming over."

892

MS. GERAGOS: And it continues?

893

JOSEPH CERCIELLO: "Do you wanna make love or you wanna lay out? What's your vibe?"

894

MS. GERAGOS: She says: "Can you bring me some positive energy tea when you come. Forgot my pack."

What does he say?

895

JOSEPH CERCIELLO: "What's your vibe?"

896

MS. GERAGOS: She says: "Can you and I see each other a sec? I haven't seen u."

Next page?

897

JOSEPH CERCIELLO: "Wanna come here?"

898

MS. GERAGOS: "Okay. Sure."

What does he say?

899

JOSEPH CERCIELLO: "Imma come over there. I want you. I'm sorry."

900

MS. GERAGOS: She says: "After I get dressed, I'll text you. You can just come here. It's fine. I just want to see you. Haha, jinx," right?

902

MS. GERAGOS: We can now go back to Government Exhibit 1406, page 12.

903

MS. GERAGOS: So we reviewed several Government Exhibits and a Defense Exhibit from row 30. And then the next entry date is May 19, 2023 to May 20 of 2023. Do you see that?

905

MS. GERAGOS: Listed there is Jane, Combs, Paul and Kabrale, right?

907

MS. GERAGOS: Could we look at AH-442-17, and go to page 12.

Actually, if we could go back to the chart.

908

MS. GERAGOS: Do you see that under Jane and under Combs, you didn't list an A-442-17?

910

MS. GERAGOS: Can we pull it up, please, and go to page 12.

911

MS. GERAGOS: Do you see that this is from the same approximate date range of May 19 of 2023?

913

MS. GERAGOS: This is a message between Mr. Combs and Jane?

915

MS. GERAGOS: What does Mr. Combs write?

916

JOSEPH CERCIELLO: "Is chef still here?"

917

MS. GERAGOS: She says: "No. JK."

Then she says: "Yes. LOL."

He says: "Where is he?"

She says: "Out here," right?

919

MS. GERAGOS: This was not included in the chart, right?

921

MS. GERAGOS: You also listed in the chart 3D-114-A-R. So if we could pull that up, that first page.

922

MS. GERAGOS: Do you see these are text message between several of the personal assistants?

923

JOSEPH CERCIELLO: I don't know if they are.

924

MS. GERAGOS: You don't know. Okay. No problem.

Do you see then the message, it lists May 19 of 2023 at 8:48 p.m. Do you see that?

926

MS. GERAGOS: Do you see Kristina Khorram at the bottom says: "List of what Jane wants for hotel. Maybe new outfits. Shorts for him size large. Fruits. Shakes. Juices," right?

928

MS. GERAGOS: And the response is: "Copy. We got fruits, shakes, and juices. I'm about to run to store quick and send her outfit options," right?

930

MS. GERAGOS: Ms. Khorram responds: "Just send to me, and I'll send to her for now," right?

932

MS. GERAGOS: We just saw a message from Kabrale. So if we could bring up the corresponding Defense Exhibit to Government Exhibit F-101, which is 3328, and go to pages 205 to 206.

933

MS. GERAGOS: These messages begin on May 20, 2023 at 1:25 a.m. UTC time. So it would be May 19, East Coast time, right?

935

MS. GERAGOS: And she reaches out to him and says: "Hey, what are you doing tonight," right?

937

MS. GERAGOS: And she says -- if you go to the next page on 206 -- "Okay, did you eat and everything? Feel hydrated and everything? I'll be at 1 Hotel residential side," right?

939

MS. GERAGOS: If we could skip ahead to 207 and 208. If you look at 208 on the right side of the page, I'm skipping ahead.

940

MS. GERAGOS: She writes to him on May to, 2023, this is -- now it's 6:27 p.m. UTC time. "Hey hun! I had a great time WU as usual! Just forward your Addy. Have a safe flight and we'll talk soon." Do you see that?

942

MS. GERAGOS: If we could pull up Defense Exhibit 3136, please.

943

MS. GERAGOS: Do you see this is a message from Jane to Mr. Combs on May 22 of 2023?

945

MS. GERAGOS: This is a couple days after the entry we just looked at in row 31?

947

MS. GERAGOS: She writes to him: I love you baby. I thank God for you every day. You are so special to me. I love every single moment WU. Congrats on your interview today! Can't wait to see you" with several heart emojis, right?

949

MS. GERAGOS: And just a few more from this date. If we could bring up Government Exhibit E-113.

950

MS. GERAGOS: We looked at that. And that is something that you put in, if you look at your chart, under Combs for that date range, right?

952

MS. GERAGOS: And then you also under Jane put E-297.

953

MS. GERAGOS: So could we bring up E-297 and E-298, which were also under Jane and Combs in your chart.

954

MS. GERAGOS: These are also several photos from that date range?

956

MS. GERAGOS: Let's pull up Government Exhibit 1407.

957

MS. GERAGOS: So we just finished looking at row 31. That's May 19 to the 20th of 2023, right?

959

MS. GERAGOS: So the next row is a month after that. If you go to the next page on page 13, do you see that it's June 16 to 17th?

961

MS. GERAGOS: So the next exhibits that you looked at were a month after the May 2023, right?

963

MS. GERAGOS: Okay. And you list here Jane, Combs, and Paul, right?

965

MS. GERAGOS: All right. There's no Kabrale listed there, right?

967

MS. GERAGOS: Can we bring up the messages with Kabrale, which is 3328 and go to 210 to 211, please.

968

MS. GERAGOS: Do you see that this is from a few days earlier June 13 of 2023?

970

MS. GERAGOS: She writes here June 13, 2023 at 2:02 a.m.: "I was just wondering your schedule for this coming Friday, the 16th for LA," right?

972

MS. GERAGOS: And she -- he responds. And then she says: "Okay," smiley face. "I'll know for sure by TMW and keep you posted," right?

974

MS. GERAGOS: Then the next page is a message that begins on June 14 of 2023 at 11:07 p.m. UTC time, right?

976

MS. GERAGOS: And she says: "Hey" with multiple Y's, smiley. "Hope you're having a good day! Just wanted to update you that the schedule keeps changing a little bit. So hard for me to plan it. Going to try my best to let you know as soon as I get a solid plan," right?

978

MS. GERAGOS: If we could go back to the chart, please. All right. And you list under Jane A-442-19 here, right?

980

MS. GERAGOS: So I just want to pull up the corresponding Defense Exhibit, which is Defense Exhibit 3145. If we could bring that up and go to page 8, please. And this is from June 16 -- if we could go page 8 and 9 next to each other. Perfect.

981

MS. GERAGOS: This is June 16, 2023 at 4:00 a.m., which is UTC time. And he writes: "Friday 2:00 a.m. I land," right?

983

MS. GERAGOS: And she says: "Okay. Straight to hotel or home. LMK what you want me to do BC Imma little confused," right?

985

MS. GERAGOS: If we could go to 10 and 11, please.

She writes to him: "I really don't like how you spoke to me. Felt really passive aggressive and weird. You had zero complaints about the last time. Why would you say you had complaints? You said it was the most rejuvenating trip we've ever had together and we had such a loving time. You hardly called or FaceTimed me, and a lot was going on. I've been chill, sweet, loving, not pressing you about anything. I operate better feeling loved and appreciated. Positive reinforcement. Let's be positive and happy. Remember that bad stressful Friday you had last time? Nobu night? And how I turned your entire day around? We took it back to your place and then the at 1Star ... I just got like you called and gave me a rundown of all the things I'm doing wrong. Imma little confused by it ... But ... Have a good night and sweet dreams."

And then the next morning, she says: "Good morning and happy happy happy, it's Friday," right?

987

MS. GERAGOS: Could we go to 12 and 13, please.

She says -- and then he responds: "P not free tonight," right?

989

MS. GERAGOS: She says: "Really ... I thought he was WU," right?

991

MS. GERAGOS: And he says: "No."

She says: "Don't worry. I'm waiting to hear back FR chef and Italian. It's still early. Both their schedules were tight, so I'm just trying to see again," right?

993

MS. GERAGOS: What does he respond with?

994

JOSEPH CERCIELLO: "No need. I just wanna see you. I'm tiger anyway."

995

MS. GERAGOS: What does he say after that?

997

MS. GERAGOS: She says: "Okay baby. We're going to have a great time together regardless. I always just want you."

What does he respond with?

998

JOSEPH CERCIELLO: "Party back on."

999

MS. GERAGOS: And if we go to -- that was about four hours later -- if we could go back.

Okay, that "Party back on" is about four hours after "I always just want you"?

1001

MS. GERAGOS: If we could go to 14 and 15.

1002

MS. GERAGOS: All right. And he says: "Man what's up with my party? Get creative."

And she responds with: "Drink lots of water and vitamins" heart.

"Do you want me to tell you who I got or?"

And what does he say?

1003

JOSEPH CERCIELLO: "No N but I have a surprise too."

1004

MS. GERAGOS: She says: "Okay baby" with several emojis and a heart, right?

1006

MS. GERAGOS: What does he say?

1007

JOSEPH CERCIELLO: "Who's first?"

1008

MS. GERAGOS: "Maybe Italian at 2:00 a.m. What time is your surprise coming?"

What does he say?

1009

JOSEPH CERCIELLO: He says: "I'll keep you posted."

1010

MS. GERAGOS: If we could go to page 17, please.

He says: "You got chef?"

And she says: "We were trying so hard to make it work with the flight times and hours that he was free, but it wasn't working. He had a really big chef gig he couldn't get out of. You know I was trying for my cheffy poo," right?

1012

MS. GERAGOS: He says -- what does he say in response?

1013

JOSEPH CERCIELLO: "LOL. Okay. I'm headed to airport in like an hour."

1014

MS. GERAGOS: Could we just go to Defense Exhibit 3328, pages 209 to 210.

1015

MS. GERAGOS: These are messages -- we've seen this exhibit before between Jane and Kabrale, right?

1017

MS. GERAGOS: And this is the same time period -- approximate time period of June 13, right?

1019

MS. GERAGOS: And she says to him June 13: "Hey, hope you're well. How have you been," right?

1021

MS. GERAGOS: If you look at the next page, she writes: "I was just wondering your schedule for this coming Friday the 16th for LA," right?

1023

MS. GERAGOS: And she says later in the message: "Okay, I'll know for sure by TMW and keep you posted. Enjoy Florida," right?

1025

MS. GERAGOS: Let's go to the next two pages.

1026

MS. GERAGOS: On June 14, she writes to him: "Hey, hope you're having a good day! Just wanted to update you that the schedule keeps changing a little, so hard for me to plan it. Gonna try my best to let you know as soon as I get a solid plan," right?

1028

MS. GERAGOS: Next two pages, she writes on June 16 here: "Hi, sorry for this late text. It's no rush. Let me know if you possibly be up for coming to LA Saturday early morning or maybe late Friday night, but IDK how your schedule is. Night." Smiley face, right?

1030

MS. GERAGOS: If we could go to the next two pages, please. All right.

1031

MS. GERAGOS: If you look at page 216, she says: "Okay so ... how much would it need to be compensated if you did miss chef gig." Surprise face. "Just out of curiosity, not me trying to see if it can still work."

What does he respond?

1032

JOSEPH CERCIELLO: "Sorry love. Will definitely make it happen next time. I could have did it if I had more of a heads up to move things around."

1033

MS. GERAGOS: Could we go back then to Defense Exhibit 3145, and go to page 20.

1034

MS. GERAGOS: Then she says: "I want you to break me in" -- this is back between Combs and Jane.

She says: "I want you to break me in first though. It's been three weeks. Are you horny for me?"

What does he say?

1035

JOSEPH CERCIELLO: "I wanted to watch you on FaceTime being bad. Am I gonna get to see that?"

1036

MS. GERAGOS: She says: "I think so baby. W timing, yeah. I'm gonna sort it out," right?

1038

MS. GERAGOS: If we could go to page 29. All right.

Then they just say "love you" to each other, right?

1040

MS. GERAGOS: If we could go back now to 3228 pages, 213 and 214 side by side. Actually, we just looked at those, sorry. Go to G-103 page 116.

1041

MS. GERAGOS: These are messages between Paul and Jane, right?

1043

MS. GERAGOS: These are from the date range that we're looking at in line 32, which is June 16 to 17, right?

1045

MS. GERAGOS: But these G-103 -- this exhibit, I don't see it listed here in your chart?

1047

MS. GERAGOS: So you didn't -- did you review these part of the messages or you don't recall?

1048

JOSEPH CERCIELLO: Not for that particular row. If it shows up somewhere else, then yes, but not that particular row.

1049

MS. GERAGOS: For this particular row, let's run through it quickly.

Here on the 16th, she writes: "Hey Paul. Hope you've been doing well. I was just wondering, Sean told me you're not available tonight. Are you available or are you not? LOL."

And what does he say?

1050

JOSEPH CERCIELLO: "I can't make it tonight."

1051

MS. GERAGOS: And she says: "Boo LOL," right?

1053

MS. GERAGOS: And then if you go to G-102, can we go to that and go to page 124.

1054

MS. GERAGOS: And you see these were included in your chart, right? Do you have it in front of you do you see?

1056

MS. GERAGOS: And this is between Paul and Mr. Combs, right?

1058

MS. GERAGOS: And Mr. Combs writes: Hotel. Hurry. She horny as fuck. I need help," right?

1060

MS. GERAGOS: Then he responds later, and says: "Help," right?

1062

MS. GERAGOS: Then he says: "How long? This is the 911 freak emergency. LOL," right?

1064

MS. GERAGOS: If we could go to the next page. And then, sorry, next page. And he says -- Paul responds "LOL," right?

1066

MS. GERAGOS: If we zoom in on that photo on the top left. You see that?

1068

MS. GERAGOS: It's an image that Mr. Combs sends to Paul?

1070

MS. GERAGOS: Does that look like Shaq?

1072

MS. GERAGOS: All right. Could we go back to our chart, 1406, Government Exhibit 1406?

1073

THE COURT: Could we have a brief sidebar?

1074

(Continued on next page)

sidebarsidebarCross-Examination and Lunch Schedule
1075

(At the sidebar)

1076

THE COURT: I mainly did that to give the jurors a little break, but also get a time check.

1077

MS. GERAGOS: I'm taking longer than I expected. I still have to play about four videos and approximately just a few, not going to go through all of 1407, but maybe I would say I guess half an hour to 45 minutes?

1078

THE COURT: Half hour to 45 minutes. Is there an appropriate time for a break that you would suggest? It's now 11:35 are.

1079

MS. GERAGOS: We could break now because we'll still be done by lunch.

1080

THE COURT: If we took a break now, we'll come back at 11:50. And then you're saying from that point you would have about 30 to 45 minutes?

1081

MR. AGNIFILO: Do you think that's right?

1082

THE COURT: We would go to 12:30, is what you're saying?

1083

MS. GERAGOS: Or go to 12:45.

1084

THE COURT: Either way, you'll be done.

1085

MS. GERAGOS: I hope I'll be done. I have cut it shorter than Ms. Comey, and I'm really trying.

1086

THE COURT: You go as long as you want. I'm trying to understand the schedule because I'm trying to make sure that we're doing things in the right cadence. Does that make sense?

So to go to lunch, we can take that at 12:45. I don't see an issue for that. If we go to 12:45, I'd be inclined to take a break now. And if you can finish after lunch, that's fine with me.

1087

MS. GERAGOS: Okay, that's fine with me.

1088

MS. COMEY: Your Honor, to be honest, I have no objection to the length of are cross. I think issue was just that the prediction was an hour or an hour and a half, which we're now at three hours.

1089

MS. GERAGOS: My prediction was obviously off.

1090

THE COURT: I have no issues with the time of anything. I'm just trying to make the schedule work for everybody.

Ms. Comey do you have a sense of what your redirect would look like?

1091

MS. COMEY: Two to three minutes.

1092

THE COURT: You'll go as long as you need to. The plan would be in the afternoon to have this witness off the stand?

1094

THE COURT: Very good. Then we'll break.

1095

(Continued on next page)

CrossCrossJoseph Cerciello — Cross Joseph Cerciello Teny R. Geragos
1096

(In open court)

1097

THE COURT: Thank you, members of the jury. We're going to take a break. Just a spoiler alert. We're going to take a break and come back at 11:50.

Thank you.

1098

(Jury not present)

1099

THE COURT: We'll see you back here 11:50.

1100

(Witness not present)

1101

THE COURT: All right.

1102

(Recess)

1103

THE COURT: Welcome back.

Please be seated.

Let's bring back the witness.

1104

(Jury present)

1105

THE COURT: Please be seated.

Ms. Geragos, you may proceed when ready.

1106

MS. GERAGOS: Thank you, your Honor.

Can we please bring up Government Exhibit 1406 again, please, and go to page 13. Page 13, please. All right.

1107

MS. GERAGOS: Special Agent, we just finished reviewing records from row 32 before the break. Do you recall that?

1109

MS. GERAGOS: OK. And so the next row is July 4 of 2023, right?

1111

MS. GERAGOS: All right. And underneath Combs and under Paul, who are two of the names listed there? You have Government Exhibit 101, pages 27 to 33. Do you see that?

1113

MS. GERAGOS: Could we just bring that up, pull up pages 30 to 31.

1114

MS. GERAGOS: And you list the location as Los Angeles, right?

1116

MS. GERAGOS: All right. And here, Mr. Combs writes to Paul: "Security knows to let you in the back." Right?

1118

MS. GERAGOS: All right. If we could go to the next page, page 33.

1119

MS. GERAGOS: At the bottom of the page, on the left-hand side, on page 32, he writes to Paul: "Just say P, not Paul. OK?" And Paul writes: "OK." Do you see that?

1121

MS. GERAGOS: He says: "They're waiting." Right?

1123

MS. GERAGOS: All right. Could we bring up --

1124

MS. GERAGOS: And these correspond to July 4, 2023, approximately 11 a.m. UTC time, right?

1126

MS. GERAGOS: OK. Could we go to defense exhibit admitted 3152, please.

1127

MS. GERAGOS: And this is July 7 of 2023, 4:40 a.m. UTC time, right?

1129

MS. GERAGOS: And here Jane writes: "Just wanted to say you make me smile. I loved living in the moment w u just spending time in the sunshine and laughing, listening to your music and making love to you. It was our little partay, soirée, all day, rosé. LOL. Love you to the moon emoji and back." Right?

1131

MS. GERAGOS: Could we go back to 1406.

1132

MS. GERAGOS: Next row is 34, and the date that corresponds there is August 12 of 2023, right?

1134

MS. GERAGOS: OK. And the government exhibit that you listed under Jane and Combs is A442-33. Do you see that?

1136

MS. GERAGOS: OK. Could we go to -- could we go to that exhibit, A442-33 and go to pages 5 and 6, please.

1137

MS. GERAGOS: And he writes, down below, on the first part of the page: "Movie night was off the chain. You tell me." Right?

1139

MS. GERAGOS: And she responds: "Delicious. When are you free?" Right?

1141

MS. GERAGOS: OK. If we could go to the next two pages.

1142

MS. GERAGOS: And he says: "I'll let you know," and they continue corresponding, right?

1144

MS. GERAGOS: All right. Could we go to Defense Exhibit 3172, which is the corresponding defense exhibit to this exhibit and go to page -- pages 1 to 4.

1145

MS. GERAGOS: Do you see that there?

1147

MS. GERAGOS: All right. And this is from August 11, 2023, UTC time. Do you see that?

1149

MS. GERAGOS: OK. And she writes -- he writes to her: "What you feel" and "I'm working out with Paul now." Right?

1151

MS. GERAGOS: And she responds: "Baby, can you have one of the guys print an NDA, or do you want me to text them?" Right?

1153

MS. GERAGOS: And what does he respond?

1154

JOSEPH CERCIELLO: "What did you say about the new guy? What's your vibe?"

1155

MS. GERAGOS: And then what is his next two text messages?

1156

JOSEPH CERCIELLO: "What does tomorrow look like?" And "how can we pull that off without me killing myself? LOL. I'm working out with Paul now."

1157

MS. GERAGOS: And she responds: "Yeah, he seems cool, babe. Hopefully he doesn't know anybody we know. LOL. So I'm just going to make sure he signs the paper and stuff. Basically tomorrow I believe Paul lands around 2 p.m., and then you have your concert." And "do you have going on after the concert? Paul leaves tonight for Vegas at 6 p.m. and comes back tomorrow at 2 p.m." And then if we, 0and then there's some, two text messages after that, right?

1159

MS. GERAGOS: If we go to the next two page.

1160

MS. GERAGOS: And he says -- how does he respond at the top of the page?

1161

JOSEPH CERCIELLO: "Paul is here with me now."

1162

MS. GERAGOS: She says: "Yes, I know, but he has to leave at 6 p.m. for the airport, and I'm not free yet until 8:30 p.m./9 p.m." How does he respond?

1164

MS. GERAGOS: And she says: "Trust me, I was texting him all morning. I was drilling every hour of his day. I was trying to find some sort of loophole." And she laughed at the "gotcha" message, right?

1166

MS. GERAGOS: And he says: "So we try something new to night or we wait until after the concert tomorrow? What you want to do?" And then: "Maybe if you ask Paul to cancel his night, his answer will be different." Right?

1168

MS. GERAGOS: Could we go to pages 8 and 9, please. All right.

1169

MS. GERAGOS: And she says, in these messages: "How about Edition? Yeah, I loved the One. It was a nice vibe," exclamation. "But we weren't sure how you were feeling. So no dinner, right..just trying to figure out a drink spot with K.K. now." And what does he say?

1170

JOSEPH CERCIELLO: "Call Italian."

1171

MS. GERAGOS: And what does he say after that?

1172

JOSEPH CERCIELLO: "I'm a little hungry. Where you want to go and will you be on time?"

1173

MS. GERAGOS: And she says: "OK. Let's circle back to Baltaire. What do you think? Baltaire, great food and drinks. Hariettes, One hotel rooftop, mostly good for drinks and light bites. Yes, I'll be on time. OK on Italian. I'll send text." And what does he respond?

1174

JOSEPH CERCIELLO: "Whatever makes my baby happy."

1175

MS. GERAGOS: OK. And she says -- it has a smiley face and then his face, right?

1177

MS. GERAGOS: All right. Could we go to pages 13 and 14. OK.

1178

MS. GERAGOS: Then she says to him: "I'm in a good mood, baby. Sorry. Just rushing and feeling pressure. See you soon." And how does he respond?

1179

JOSEPH CERCIELLO: "OK, please, baby because I'm stressed out, I'm not rushing nothing."

1180

MS. GERAGOS: On the next page he asks her: "Hey, you have the NDA?" And she responds with an NDA doc. Do you see that?

1182

MS. GERAGOS: OK. And can you now go to page 18 of this exhibit, please. All right.

1183

MS. GERAGOS: So this is August 13, 2023, at approximately 3:54 a.m. UTC time, right?

1185

MS. GERAGOS: And they're sending several messages to each other here?

1187

MS. GERAGOS: All right. And at the bottom, on August 13, 2023, at 10:58 p.m., that's several hours after, right?

1189

MS. GERAGOS: OK. And she writes: "Daddy love you," exclamation point; "sheesh," exclamation, exclamation, exclamation. That dick had me sloppy all night," with many exclamation points and one, two -- 13 emojis with hearts. Right?

1191

MS. GERAGOS: With different kiss emojis, cat with heart-face emojis and tongue-out emojis, right?

1193

MS. GERAGOS: She says: "I'm back in mommy mode. Back to school shopping now for my child. First day of school's tomorrow. Hope you have fun cooking dinner tonight w the family," with several hearts. Right?

1197

MS. GERAGOS: OK. And that is, again, August 13, which is a day after the line item 34 on page 13, right?

1199

MS. GERAGOS: OK. And if we go back to 1406, please. Great. That's 34, so that's August 12, 2023.

If we go to the next page, row 35, which is September 17, 2023, to September 19 of 2023, that corresponds to many, many chats that are within 1407, which we looked at extensively yesterday.

1200

MS. GERAGOS: Do you remember that? Do you remember looking at 1407?

1201

JOSEPH CERCIELLO: I remember looking at 1407, yes.

1202

MS. GERAGOS: OK. So if we could pull up 1407 and go --

1203

MS. GERAGOS: We're not going to look through it one by one, but do you recall looking at 1407, if we could go to page 48? Do you see how, starting at page 48, there are several messages that begin in the middle of September here?

1205

MS. GERAGOS: And so this, these messages that are in this chart correspond with line item 35, right?

1207

MS. GERAGOS: OK. And if we go to -- I just want to highlight a few messages that I don't think were in the chart. If we go to page 82 here. All right.

1208

MS. GERAGOS: There's several records here from September 21 of 2023, hotel records and travel records. Do you see that, on lines 823 to 824?

1210

MS. GERAGOS: OK. Could we pull up Defense Exhibit 3187, please, which is already in evidence.

1211

MS. GERAGOS: All right. And this is from the same date, right, September 21 of 2023?

1213

MS. GERAGOS: All right. If we could go to --

1214

MS. GERAGOS: And then at the bottom, Mr. Combs writes: "Yes, headed to ATL. I feel so bad." Right?

1216

MS. GERAGOS: And she responds: "It's OK, baby. We really wanted to see each other. Still happy we did. I'm just going to stock up on my sick stuff and take it easy." Right?

1218

MS. GERAGOS: Could we go to pages 3 and 4.

1219

MS. GERAGOS: And here, she sends him several messages, again, on September 21 of 2023, right?

1221

MS. GERAGOS: All right. And the first thing is a payment detail to Bridget Collins of a thousand dollars, right?

1223

MS. GERAGOS: And it says: "Payment sent on Venmo. Here's the receipt. You can forward to her for her bum ass cowboy. LOL." Right?

1225

MS. GERAGOS: And then she says: "Thank you for sending me money, baby. I love you. I'm heading home now." Right?

1227

MS. GERAGOS: And none of these messages were included in 1407, right?

1228

MS. GERAGOS: Go back to 1407, go to page 82.

1229

MS. GERAGOS: If you look at September 21 of 2023, those were not included, right?

1231

MS. GERAGOS: Have you seen that message before, the bum ass cowboy message?

1232

JOSEPH CERCIELLO: No, I don't recall that.

1233

MS. GERAGOS: OK. And if we could go to Defense Exhibit 3327, which is in evidence, and go to pages 4 and 5 next to each other. All right.

1234

MS. GERAGOS: And this is from September 18, 2023, right?

1236

MS. GERAGOS: All right. And she writes to him: "Hey, baby. The guys are done." And he says "OK." Right?

1238

MS. GERAGOS: And she writes: "Should I invite Chef over or wait until you're back." Right?

1240

MS. GERAGOS: OK. Let's go to, back to 1406, please, Government Exhibit 1406, page 14.

All right. So, we've looked through those messages extensively. I'll spare everyone from speed-reading through them.

1241

MS. GERAGOS: Our next row is 36, right? And this is just a few days after row 35, right?

1243

MS. GERAGOS: Just about five days?

1245

MS. GERAGOS: And the location here is Miami, Florida, right?

1247

MS. GERAGOS: OK. And if we go to Defense Exhibit 3191, which is the corresponding exhibit, and go to pages 4 to 6. All right.

1248

MS. GERAGOS: And do you see that these are from the approximate date September 24 of 2023?

1250

MS. GERAGOS: All right. And here, Jane writes to Combs: "I was just looking at weather in Bahamas. LOL," with the eye emoji. "You did promise me that quick Miami to island yacht trip that we haven't got to do yet. You're ready to lock me in a hotel. I already know you. LOL," with the crying face. Right?

1252

MS. GERAGOS: And she says: "Baby, I can more than likely come. We can figure out plans when we're both up. If you're serious, just have someone text me in the morning about travel in case you're asleep or anything. Love you, baby." Right?

1254

MS. GERAGOS: And he says, on the next page: "Where are my phones?" Right?

1256

MS. GERAGOS: And she says: "I gave our phone to John. The morning I left I handed it to him. Can you make sure and LMK when you have it." Right?

1258

MS. GERAGOS: And he responds later in a message: "He has it. Don't worry"?

1260

MS. GERAGOS: Could we go to 5 and 6. All right.

1261

MS. GERAGOS: And then he says: "I can't even look. It will drive me crazy." Right? Do you see that on the right side?

1262

JOSEPH CERCIELLO: On the right side, yes.

1263

MS. GERAGOS: All right. And she laughs at those messages -- laughs at that message, and says: "You might blow up, daddy, like a locomotive," with a train and smoke and a shocked face and more smoke, and says "muy caliente," with a sweating face. "That shit was different. All of it. Gonna close by eyes. Message me when you're up." Right?

1265

MS. GERAGOS: All right. And do you see that "that shit was different, all of it" was sent September 24, 2023, at 9:37 a.m. UTC time?

1267

MS. GERAGOS: All right. Could we go to Defense Exhibit 3328, page 258, please. All right.

1268

MS. GERAGOS: And you see this is a message between Jane and Kabrale on September 24, that same day?

1270

MS. GERAGOS: All right. And do you see that this first message is from three minutes later, at 9:40 a.m.?

1271

JOSEPH CERCIELLO: Three minutes later from?

1272

MS. GERAGOS: From 9:37 a.m., that we just looked at.

1274

MS. GERAGOS: OK. And she writes to Kabrale: "Hey, hun. Sorry for the late message. Just text me in the morning. Just wanted to see your availability for possibly Sunday evening and also Monday, Tuesday. It won't be all those days. Just wanted to see your schedule. Thank you," exclamation point, "speak soon," with smiley face. Right?

1276

MS. GERAGOS: All right. And then he responds much later, at 2:05 p.m., the next day, right?

1278

MS. GERAGOS: All right. So let's go back to 3191, defense exhibit, and go to pages 7 and 8.

1279

MS. GERAGOS: OK. And he -- Combs responds to close my eyes message: "Wow. This is crazy. I'm mad we didn't have a second round. We shouldn't have went for a walk." Do you see that?

1281

MS. GERAGOS: Do you remember the messages we reviewed yesterday where Jane had said that we went out for a walk? Do you recall those?

1282

JOSEPH CERCIELLO: I don't recall.

1283

MS. GERAGOS: No problem.

1284

MS. GERAGOS: All right. "Get to the airport, baby. Wake up. I need you," with a prayer emojis, "I'm going to withdraw." Right?

1286

MS. GERAGOS: All right. And then the next page, she writes: "Baby, just opening my eyes. It's OK, baby. It's best we walked BC we probably would have gotten more sick we already been up so long that night. It was perfect how it all played out. OK, babe. Just waiting for flight options." Right? And then the next message, she writes: "Also at the end remember I came twice w u, and we came together same time. It was incredible, babe. Don't regret anything because everything felt right." right?

1288

MS. GERAGOS: And how does he respond?

1289

JOSEPH CERCIELLO: "I want to spend this beautiful daw with you, baby. I'm greedy. LOL."

1290

MS. GERAGOS: Go to the next page, please, next two. All right.

1291

MS. GERAGOS: And they're, just at the end of page 10, she writes to him -- I'm skipping many messages. She writes: "Baby, I know OMGGG," exclamation, "I never want to get to that point again. LOL. It's OK. We left the party hot," in capital letters. Right?

1293

MS. GERAGOS: All right. So now if we go back -- this is at 2:10 p.m., do you see that?

1295

MS. GERAGOS: Now if we go back to Defense Exhibit 3328, page 258 and 259. All right.

1296

MS. GERAGOS: All right. So if you look, then that message from Kabrale is at 2:05 p.m., about five minutes before that message we just saw, right? Do you see 2:05:46?

1298

MS. GERAGOS: OK. With the message we just saw about leaving the party hot was at 2:10 p.m.?

1300

MS. GERAGOS: OK. And then she responds: "Hey, good morning. OK. So possibly this evening to Monday evening works for you? I think that would be best, and just in case what time Tuesday do you need to return, at least by morning, right?" Right?

1302

MS. GERAGOS: OK. And then the next page, on 259 -- I'm skipping ahead -- she writes: "OK. Cool. That might be good so doesn't feel too rushed." Right?

1304

MS. GERAGOS: OK. And if we go to the next page, to 260. All right.

1305

MS. GERAGOS: And here it's just more messages, if you see this page coordinating with him. Do you see that?

1307

MS. GERAGOS: All right. Let's go back to 3191 to pages 15 and 16, please. OK.

1308

MS. GERAGOS: And this is now back to the messages between Combs and Jane, right?

1310

MS. GERAGOS: OK. And she writes, in the middle, on the left side: "The flight sold super fast for the ones I was searching for Chef, and I'm on this flight searching everywhere and nothing for tonight, but for TMW morning is available." Right?

1312

MS. GERAGOS: Let's skip ahead two pages -- I mean to 17 and 18. Thank you.

1313

MS. GERAGOS: And he says: "Want me to look?" She says: "No. We already left an envelope for Williams last time." right?

1315

MS. GERAGOS: OK. And if we go to those two messages on the right side of the page, he writes: "I'm on way to Miami. I'm good. I'm not rushing. We have a great movie notebwarmup. What you in the mood to do." Right?

1317

MS. GERAGOS: OK. If we could go to 19.

1318

MS. GERAGOS: "Dinner? Or do you just want to ravish me?" Do you see that?

1320

MS. GERAGOS: All right. Let's go to page 22. We'll skip ahead some messages. All right. And she -- actually, just go 21 and 22. Sorry.

1321

MS. GERAGOS: And she writes: "Ravish you in the middle of a restaurant." Right? And he had sent her several flights, right?

1322

JOSEPH CERCIELLO: Before that, yes.

1323

MS. GERAGOS: Before that, yeah. And then he says: "What should I say?" Do you see that?

1325

MS. GERAGOS: And she writes: "They're going to be googling this ninja," with several emojis. Right?

1327

MS. GERAGOS: Could we go to 24 and 25, please. OK.

1328

MS. GERAGOS: And at the bottom of the page, he says -- she says: "Send me Chef flight when you have." Right?

1330

MS. GERAGOS: OK. And the next page he says: "OK. On it. Don't wear too much makeup pls. You're in your bag right now." Right?

1332

MS. GERAGOS: OK. What does she say?

1333

JOSEPH CERCIELLO: "OK, I won't. I'm not too tan rn because I've been inside."

1334

MS. GERAGOS: All right. And he says: "All good." And she writes: "Daddy want to see mommy be bad tonight." Right?

1336

MS. GERAGOS: Could we please go to 26 and 27, please. All right.

1337

MS. GERAGOS: And these are more messages between the two of them?

1339

MS. GERAGOS: She says: "Excited to see you. Slide that dick in me at the restaurant, no panties," with water emojis. Right?

1341

MS. GERAGOS: All right. Could we please go to 30 to 31.

1342

MS. GERAGOS: All right. And she writes: "I love" -- and halfway down the page: "I love making your dick rock hard. I'm going to blow your mind tonight, baby. I'll get ready fast and bring this wet wet right to you. Can't wait to lick your nipples while you stroke me." Right?

1344

MS. GERAGOS: And what does he respond with?

1345

JOSEPH CERCIELLO: "You betta -- we betta go back to where we stopped right from that point."

1346

MS. GERAGOS: And she says: "OK, so drool," with a tongue out. Right?

1348

MS. GERAGOS: And: "Hmmmmm. I got the same outfit and horny pussy," and loved his message and says: "I'm about to jump off the screen right on to you." Right?

1350

MS. GERAGOS: And if we go to pages 32 to 33. All right.

1351

MS. GERAGOS: And then she says, halfway down the page: "I probably would have jumped back into what we were doing." Right?

1353

MS. GERAGOS: And he said: "Thank God for today." Right?

1355

MS. GERAGOS: And the next page she said: "Yes, I did, daddy. I love being kinky for you. I love driving you wild. I want to feel everything." Right?

1357

MS. GERAGOS: OK. And then she sends him more emojis with the drool and writes: "I'm begging you." Right?

1359

MS. GERAGOS: OK. Can we go to page 34, please. All right.

1360

MS. GERAGOS: And now they're just sending more messages to each other on this day, right?

1362

MS. GERAGOS: All right. Let's go to page 40. All right.

1363

MS. GERAGOS: She sends him a photo here. Do you see that on the left side of your page?

1365

MS. GERAGOS: All right. Is this the same dress that we looked at yesterday that was in 1407?

1366

JOSEPH CERCIELLO: It appears quite similar, yes.

1367

MS. GERAGOS: OK. Could we go to pages 51 to 52. All right.

1368

MS. GERAGOS: And she writes: "It's sexy here in the hotel," and then later writes: "I'll see you, love you, nasty boy." Right?

1370

MS. GERAGOS: OK. And then later, on the next page, on 52, writes: "OK, baby. I'm here getting ready. Yeah, we need to run to the fruit store." Right?

1372

MS. GERAGOS: And he asks what she needs, and she says: "Heels size 9 and outfits, baby, pls. Thank you. I didn't bring anything. Just that one outfit." Right?

1374

MS. GERAGOS: Could we just skip ahead to 55. All right.

1375

MS. GERAGOS: And he just sends -- she sends him: "Baby, you know I'm still getting over being sick. I didn't have time to do my nails. I'm pale and all that. Just letting you know." And how does he respond?

1376

JOSEPH CERCIELLO: "I fucking love it."

1377

MS. GERAGOS: All right. And she sends him a love emoji, right?

1379

MS. GERAGOS: All right. If we could just go quickly back to 3328 to page 269 and 270. All right. Actually, just -- sorry. I meant to go to 276 to 277. All right.

1380

MS. GERAGOS: And she writes to him: "I hope you make it. Hi." Do you see that?

1382

MS. GERAGOS: All right. And then on the next page, she says: "I was shouting all sorts of positive energy in the air, hahahaha. It's a special night. We are celebrating," exclamation point, it's meant to be," exclamation, exclamation. Right?

1384

MS. GERAGOS: If we could go to the next page, page 278. All right.

1385

MS. GERAGOS: And do you see here she writes: "Don't tell Alex you're seeing me PS, LOL. That's the main driver." Right?

1387

MS. GERAGOS: OK. If we could go to page 282. OK.

1388

MS. GERAGOS: And you see on, this message, which is September 25, 2023, 9:07 UTC time -- do you see that?

1390

MS. GERAGOS: She says: "Hey, hun. Here's your travel back info. Tonight was amazing as per usual." Right?

1392

MS. GERAGOS: And how does he respond?

1393

JOSEPH CERCIELLO: "Thanks, beautiful. Yes indeed. Always enjoy your company."

1394

MS. GERAGOS: OK. Great. Could we go back to 1406, please, page 14. All right.

1395

MS. GERAGOS: And then the next -- we were just looking at messages that correspond to September 24 to September 26, right?

1397

MS. GERAGOS: All right. And then the next message -- and then the next line relates to September 30 of 2023, which you detail in your -- in 1407. Do you recall that?

1399

MS. GERAGOS: OK. Let's just quickly look at -- I think we talked about this just a little bit yesterday.

1400

MS. GERAGOS: There's no other third party in the names column of 37, right; just Jane and Combs?

1402

MS. GERAGOS: All right. So if we just go to page 88 of 1407. All right.

1403

MS. GERAGOS: And line 913, she writes to Combs -- and this is September 30: "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 always want you all the time. I enjoyed our time together so much. I love you baby. Have a great show." Right?

1405

MS. GERAGOS: All right. Let's go back to 1406, please. All right. And the next page. All right.

1406

MS. GERAGOS: And then row 38 we looked extensively at yesterday with the messages at 1407. Do you recall that?

1408

MS. GERAGOS: All right. So I won't repeat it here, and -- but after October 17, 2023, to October 18 of 2023, there's no entries from October 17, 2023 -- there's no location entries, I should say, until February 8 of 2024, right?

1410

MS. GERAGOS: All right. And did you review records that showed they saw each other between that time period?

1412

MS. GERAGOS: OK. So you don't know either way whether they saw each other between that time period?

1414

MS. GERAGOS: OK. But the next entry you have after October 17 is the Ventura v. Combs lawsuit, filed November 16 of 2023, right?

1416

MS. GERAGOS: And line 40 is -- row 40 corresponds to February 8 to February 9 of 2024, and you have Don listed as another name in that column there. Do you see that?

1418

MS. GERAGOS: And it corresponds to A513. Do you see that?

1420

MS. GERAGOS: All right. Could we pull up A513. All right. If we could pull pages 1 and 2 next to each other. All right.

1421

MS. GERAGOS: Do you see the dates on A513 on March 5 of 2022?

1423

MS. GERAGOS: All right. Could we go to the next two pages. All right.

1424

MS. GERAGOS: Do you see here these are also sent March 5 of 2022?

1426

MS. GERAGOS: All right. And are there any more pages? These also were sent March 5 of 2022?

1428

MS. GERAGOS: All right. And March 5. All right.

1429

MS. GERAGOS: And then on page 8, it says July 23 of 2022?

1431

MS. GERAGOS: All right. Next few. All right.

1432

MS. GERAGOS: And then the ending text is July 23 of 2022?

1434

MS. GERAGOS: OK. So why did you list -- if we could go back to 1406 to page 15. Why did you list Don, page 15; why did you list A513 under Don there?

1435

JOSEPH CERCIELLO: Can you go back to A513, first page?

1437

JOSEPH CERCIELLO: Thank you. Can you zoom in? Thank you.

1438

MS. GERAGOS: Do you see how the start time here was March 5 of 2022?

1439

JOSEPH CERCIELLO: Yes. So, for that, it was to show, in Mr. Combs's phone, how the name that Don was saved as.

1441

JOSEPH CERCIELLO: In his contacts.

1442

MS. GERAGOS: -- just to show the phone number?

1443

JOSEPH CERCIELLO: That it was Donald James, yes.

1445

JOSEPH CERCIELLO: Associated with that phone number.

1446

MS. GERAGOS: Understood, because then if you go under Don on 1406 at line 40, there's 5A-204-3, and then these are phone records?

1447

JOSEPH CERCIELLO: I -- they might be. Again, I don't remember what every exhibit is.

1449

JOSEPH CERCIELLO: I would have to see that.

1450

MS. GERAGOS: Let's try to bring up 5A-204-3.

1451

MS. GERAGOS: Safe to say you don't remember reviewing any messages between Combs and Don or Jane and Don from this time period of February 8 to February 9?

1452

JOSEPH CERCIELLO: Again, if they're not listed on the chart, then I didn't review --

1453

MS. GERAGOS: Then you didn't review --

1455

MS. GERAGOS: OK. Then we can take that down. Thank you.

1456

MS. GERAGOS: Then the next line here from between 40 and 41 is March 10 of 2024, right?

1458

MS. GERAGOS: It's about a month after?

1460

MS. GERAGOS: OK. Can we please bring up, and we could turn on the screen for this, 14 -- Government Exhibit 1411-R. And go to page 31. All right.

1461

MS. GERAGOS: Do you see starting at line 398 of this chart begins on February 18 of 2024 at 3:42 GMT?

1463

MS. GERAGOS: All right. And this date of February 18 of 2024, that's not listed anywhere on your chart at 1406, right?

1465

MS. GERAGOS: OK. And then line 399, says, is a message from Kristina Khorram to Brendan Paul that says, she liked it, saying: "About to head to Jane's. He's on a call." Right?

1467

MS. GERAGOS: And at lines 404 to 405, Kristina writes to Brendan: "They're just chilling at her house?" And Brendan responds: "yeah, he said he's going with the flow, LOL." right?

1469

MS. GERAGOS: And then if we could go to page 32, and Kristina writes: "LOL. So basically he's lit?" Do you see that?

1471

MS. GERAGOS: And Brendan responds: "Isn't lit lit. I just spoke to him over the phone. Maybe a little but seemed totally fine." Right?

1473

MS. GERAGOS: Then there's more messages from lines 409 to 414. Do you see that?

1475

MS. GERAGOS: All right. And those are between Brendan Paul and Kristina Khorram; do you see that in the "from" and "to" columns?

1477

MS. GERAGOS: And again, February 19, 2024, is not listed on your chart, right?

1479

MS. GERAGOS: You didn't review any messages or phone calls between Mr. Combs and a third party or Jane and a third party from either February 18 of 2024 or February 19 of 2024, right?

1480

JOSEPH CERCIELLO: Not -- not -- if those exhibits were not provided to me for the sole purpose of chart 1406, then no.

1481

MS. GERAGOS: OK. And then if we go to -- if you go a little bit lower, starting at line 416, do you see there are more messages here between Brendan Paul and Kristina Khorram?

1483

MS. GERAGOS: All right. And he -- and this message from Brendan Paul, on February 24, 2024, he writes: "Hey, B. So tmw he's coming to visit me. He told me to text you in regards to just have everything set up here." And then a little bit later, he says: "Just got this from Jane." Right?

1485

MS. GERAGOS: OK. And February 24, 2024, is not listed on 1406, right?

1487

MS. GERAGOS: And you didn't review any messages between either Jane and a third party or Mr. Combs and a third party related to February 24 of 2024, right?

1488

JOSEPH CERCIELLO: If it wasn't for 1406, then no.

1489

MS. GERAGOS: All right. And if you could, on lines 429 and 430, at the bottom, Kristina Khorram texts Jonathan Pérez and says: "How does he look?" And Jonathan says: "Shockingly OK. Way better than usual." Right?

1491

MS. GERAGOS: OK. Next page. All right. And line 432, Jonathan writes to Kristina: "I don't know mood yet but he physically looks fine if you had to put him in front of someone today. But he did just take a full bar so I think he'll be asleep soon." Right?

1493

MS. GERAGOS: All right. Let's go back to 1406.

1494

MS. GERAGOS: And the messages we just looked at were February 26 of 2024. Do you recall that?

1496

MS. GERAGOS: All right. And just to ask again, there's no messages here -- there's no entry here for February 26 of 2024, right?

1498

MS. GERAGOS: All right.

1500

MS. GERAGOS: All right. And now, line -- row 41 lists Jane, Combs and Paul, right?

1502

MS. GERAGOS: All right. Could we go to A207D, which you have listed under Jane. And go to the next page. All right.

1503

MS. GERAGOS: And this is -- this is between Combs and Jane, right?

1505

MS. GERAGOS: All right. And she says on the second page: "I just have to get us ready here and I can come. I just have a spray tan and can't shower until 9 p.m., so I may come to you a bit frumpy at first."

1506

MS. GERAGOS: Could we put it down, please. Sorry. All right. Could we turn off the public screen.

All right. Now we can put up G103, page 152 and 153.

1507

MS. GERAGOS: And you see on your chart, under Jane -- I think you have it in front of you -- you list G103, right?

1509

MS. GERAGOS: OK. And this is a message from Jane to Paul. Do you see that?

1511

MS. GERAGOS: OK. And she writes: "Hey, P. Hope all is well," exclamation point, "Are you in town and free this evening?" Do you see that?

1513

MS. GERAGOS: And he writes yes, right?

1515

MS. GERAGOS: And on the right side of the page, she writes: "OK, great. I'll get info to you ASAP." Right?

1517

MS. GERAGOS: OK. Let's go to the next two pages.

Next two pages.

1518

MS. GERAGOS: Do you see -- what two pages do you see in front of you?

1520

MS. GERAGOS: OK. There we go. OK.

1521

MS. GERAGOS: And see the bottom, now we're at 156 and 157, right?

1523

MS. GERAGOS: All right. And she writes: "Hey, P. We're going to reschedule more than likely for tomorrow," exclamation point. Right?

1525

MS. GERAGOS: And then the next page, she says: "Hey, P. Good morning, how's your schedule today/tonight?" Right?

1527

MS. GERAGOS: And if we go to the next two pages.

1528

MS. GERAGOS: And you see how she writes: "Good morning. Haha. OK. Great. Trying to organize. Keep your phone on you you you." Right?

1530

MS. GERAGOS: Now could we go to A207-E, which you had listed under Jane. Page 4, please. All right.

1531

MS. GERAGOS: And this is a message between Jane and Combs?

1533

MS. GERAGOS: All right. And she writes: "Baby, he said 11:02 a.m." Right?

1535

MS. GERAGOS: And he says: "That was so good" -- and this is several hour -- almost 12 hours later, right? "That was so good, I want more," his response?

1537

MS. GERAGOS: OK. And she loved that message, right?

1539

MS. GERAGOS: OK. Could we go back to G103 to page 167. All right. And do you see these messages, 167 starts with -- actually, let's go 166 and 167. All right.

1540

MS. GERAGOS: And do you see that Paul writes to Jane, at the bottom, on the left-hand side of the screen: "At the residence entrance"?

1542

MS. GERAGOS: All right. And she responds: "Stay really tight behind me for the gate. And then I'm going to pull up into my driveway and you're going to turn right into my garage." Right?

1544

MS. GERAGOS: And that's on the 12th?

1545

JOSEPH CERCIELLO: Of March, yes.

1546

MS. GERAGOS: Of March. OK. And then do you see right after that, on March 15, she writes to him: "Hey, P. Sorry for the late text. Had a great time with you the other night. Just curious, what's your day like tomorrow maybe around 1 or 2 p.m. just for a short while? LMK when you can. Thanks." right?

1548

MS. GERAGOS: And he says: "I'm out of town until Thursday"?

1550

MS. GERAGOS: All right. Could we go to the next two pages, please.

1551

MS. GERAGOS: And then on the 19th, she writes: "Hey, P. Hope all is well. Just curious what time you land in L.A. on Thursday and if you're available when you land?" Right?

1553

MS. GERAGOS: And he says: "I'm back." And she responds: "Fish," exclamation, exclamation, "And you ain't seen nothing, you def this." Right?

1555

MS. GERAGOS: And this on the 19th?

1556

JOSEPH CERCIELLO: Of March, yes.

1557

MS. GERAGOS: Of March. OK. And if we could go to the next two pages.

1558

MS. GERAGOS: And he says: "I literally landed an hour ago. Let me know what works for you." Right?

1560

MS. GERAGOS: She says: "LMAO, no way," exclamation, exclamation, "That's crazy. Let Paul into my house. OK. Maybe TMW. Just hold it for us, pls. I don't want to time you. Maybe early evening or evening time." Right?

1562

MS. GERAGOS: Let's go to next two pages.

1563

MS. GERAGOS: And she, skipping ahead, says: "Hi. Hopefully you are free late night." And this is March 20 at 9:42 p.m.?

1565

MS. GERAGOS: OK. And the next page, skipping ahead a bit, she says: "Hey, P. Him and I just got together now." Right?

1567

MS. GERAGOS: All right. Next two pages.

1568

MS. GERAGOS: And then she says, on the 21st at 3:14 p.m. UTC time: "LMK your ETA when you have it." Right?

1570

MS. GERAGOS: Could we please go back to 1406.

1571

MS. GERAGOS: That was the 21st of March that we just looked at. All right. And if we could -- so we just looked at messages spanning from row 41, which was March 10, 2024, and then if we could go to 22, to March 21 of 2024. Do you recall that?

1573

MS. GERAGOS: And those messages are 103 that we just reviewed, between 167 and 176, are contained within March 21 of 2024, right; under Paul, it says G103?

1575

MS. GERAGOS: OK. And then the next entry that you have here is Combs posts IG video, right?

1577

MS. GERAGOS: And here, the name here is Combs. Do you see that?

1579

MS. GERAGOS: And you have flight records for Jane?

1581

MS. GERAGOS: And so you had flight records for Jane going from LAX to Miami on May 14, right?

1583

MS. GERAGOS: And that's five days before Combs posts IG video?

1585

MS. GERAGOS: All right. And there's no other records for any third party from that line, in that line item, right?

1587

MS. GERAGOS: OK. And she leaves on the day before the IG video. She leaves on May 18. Do you see that on the flight records?

1589

MS. GERAGOS: All right. And then item -- row 44, we looked at that yesterday in your chart on 1407, right?

1591

MS. GERAGOS: OK. The timeline for June 18 to June 19 is in your timeline?

1593

MS. GERAGOS: OK. Could we just go -- we'll just review a couple of those line items. If we could go to 1407, page 120. All right. And this shows -- actually, let's go to 119, please.

1594

MS. GERAGOS: Line 1220 is Jonathan Pérez to Faheem and Kristina saying: "Just the normal her being jealous over other women and yelling at him." Do you see that?

1596

MS. GERAGOS: All right. Next page. And 1221, Jonathan writes again: "Just heard from him and he said not to come. All good." Right? A. Yes.

1597

MS. GERAGOS: And then about six hours after that, you write the first phone call from Jane to Antoine. Do you see that, in 1222?

1599

MS. GERAGOS: And that's two seconds?

1601

MS. GERAGOS: All right. And then about ten minutes after that is a second phone call, and that's from Antoine to Jane, right?

1603

MS. GERAGOS: And that's zero seconds?

1605

MS. GERAGOS: Does that mean -- do you know, does that mean it connected? What does zero seconds mean?

1606

JOSEPH CERCIELLO: So, in my experience dealing with investigations and telephone companies -- I think I said this earlier -- the telephone companies start the clock of a phone call when it starts ringing. It doesn't necessarily mean that the phone call between the two parties connected. It's when you start hearing the dial -- the ringing on the phone. That's when their clock starts.

1607

MS. GERAGOS: OK. Got it. And then about 45 minutes later, Antoine calls Jane again, and that's 43 seconds, right?

1609

MS. GERAGOS: And then about four hours after that, Kristina writes: "Hi. Can someone go pick up PD ASAP, please." Right?

1611

MS. GERAGOS: OK. And then if we could then go to page 124.

1612

MS. GERAGOS: These ones are redacted, but do you recall seeing a video, E273?

1613

MS. GERAGOS: And that's in lines 1247. We don't have the public screens on, so we could bring it up.

1615

MS. GERAGOS: You see it. OK. Could we bring up E273.

And if we could play the video.

1616

(Media played)

1617

BY MS. GERAGOS:

1618

MS. GERAGOS: All right. And the date for that was June 22 of 2024, right?

1620

MS. GERAGOS: OK. If we go back to 1406, please, and to page 17. All right.

1621

MS. GERAGOS: You don't have any flight records for row 45, right?

1623

MS. GERAGOS: OK. So you list here July 31, 2024, but it doesn't list that she arrived in Miami several days earlier, right?

1624

JOSEPH CERCIELLO: If I wasn't provided those records, I don't have them.

1625

MS. GERAGOS: OK. And it doesn't show -- you list the location as Miami, Florida, right?

1627

MS. GERAGOS: You don't show that she's staying at the Four Seasons?

1629

MS. GERAGOS: OK. At this time, your Honor, we could play -- we have two videos to play, if we could turn off the attorney screens. Actually -- sorry. I should pull up again just to establish it, 1406, page 17. OK.

1630

MS. GERAGOS: The names under item 45 are Jane, Combs and Paul, right?

1632

MS. GERAGOS: OK. And the videos here, the explicit, two of the explicit videos here under Jane are EX173 and EX176, right?

1633

JOSEPH CERCIELLO: Two of the three, yes.

1634

MS. GERAGOS: Two of the three. And then there's some, 177, it's under both Jane and Paul, right?

1636

MS. GERAGOS: And the dates for these are July 31, 2024, right?

1637

JOSEPH CERCIELLO: Through August 1.

1638

MS. GERAGOS: To August 1?

1640

MS. GERAGOS: OK. And you reviewed the metadata of these, right?

1642

MS. GERAGOS: OK. So we are going to turn off the attorney screens, and I think Ms. Becker has them ready to go. But if we could first test to make sure that everybody's video -- I mean audio's working -- or sound, I should say.

OK. Seems everybody's sound is working. So with your Honor's permission -- hold on.

We have one, two, three, four. We're out of sound. Mr. Deputy?

1643

THE COURT: All right. Raise your hand if your device is not working. All right. So that's three, four -- it's working now? I think three.

Do we have three extra devices?

1644

MS. GERAGOS: These devices were actually on before we replaced them.

1645

THE COURT: Yes. So one thing is let's make sure that you press the power button.

1646

MS. GERAGOS: OK. Once we try that, let's see if it works.

1647

THE COURT: All right. Now I'm getting thumbs up.

Raise your hand at this point if you don't have a working device.

All right. I think we have working devices for everybody.

1648

MS. GERAGOS: We're all hearing music. I don't know if anybody has a microphone they could put to the side.

All right. I think it's good.

May I go to Ms. Becker?

1650

MS. GERAGOS: Thank you.

1651

MS. GERAGOS: Agent, we are first going to watch Government Exhibit EX173, which Ms. Becker will play that entire video.

1652

(Media played)

1653

MS. GERAGOS: OK. We just watched EX173, and Ms. Becker is going to pull up EX176 and start at the beginning until one minute and 30 seconds.

1654

(Media played)

1655

MS. GERAGOS: I'll just ask everybody at the attorneys' tables to move their microphone.

All right. We will resume it now.

1656

(Media played)

1657

THE COURT: Are we getting some interference?

1658

MS. GERAGOS: I think she could hear it through the microphones.

1659

THE COURT: All right. So let's do this. I'll ask the deputy to mute out the microphones.

1660

COURT CLERK: Yes, your Honor. One moment.

OK.

1661

(Media played)

1662

MS. GERAGOS: Your Honor, can you hear it without your headphones on? Because I think -- (inaudible)

1663

THE COURT: First of all -- so, let me ask the deputy. Did we mute out the microphones?

1664

COURT CLERK: I did, your Honor.

1665

THE COURT: All right. So I'm going to ask the jurors, if you can, look at your devices and I'll ask everyone to do this and reduce the volume if you can. I have it at 20 percent. You should be able to hear it, but let's reduce it, because I think the default volume on these devices is at the upper end. So if we reduce the volume, we should still be able to hear it, but it should not be able to be heard in the courtroom.

1666

MS. GERAGOS: OK. We're going to start it again at one minute and -- right now we're at one minute and 30 seconds. We're going to start it again at about 59 seconds.

1667

THE COURT: All right.

1668

MS. GERAGOS: Thank you.

1669

(Media played)

1670

MS. GERAGOS: OK. We're going to skip ahead to two minutes and 30 seconds and play until three minutes and ten seconds.

1671

(Media played)

1672

MS. GERAGOS: OK. We just paused it at three minutes and ten seconds, and we're going to skip ahead to seven minutes and ten seconds and pause at eight minutes and 20 seconds.

1673

(Media played)

1674

MS. GERAGOS: OK. And then skipping ahead to eight minutes and 35 seconds and we'll pause at nine minutes and 46 seconds.

1675

(Media played)

1676

MS. GERAGOS: OK. We'll skip ahead about ten minutes in the video and watch from 19 minutes and five seconds to 19 minutes and 47 seconds.

1677

(Media played)

1678

MS. GERAGOS: If we could turn the screens back on and the microphone back on.

I'll just put the attorney screens back on, not the public screens.

All right. Could we pull up -- almost done -- Defense Exhibit 3306, and go to ten minutes and 38 seconds, please.

Stop it here.

1679

MS. GERAGOS: And do you see in the message here, at the bottom, Jane writes: "Thank you again for a beautiful time. I have the best memories w u"? Do you see that?

1681

MS. GERAGOS: All right. We'll take that down. I just have a few things, more things to ask about 1409.

Could I just bring up 1408, which we looked at yesterday, and could I have that side by side with --

1682

MS. GERAGOS: Do you remember looking at 1408 yesterday and going through that?

1684

MS. GERAGOS: And then side by side with 4H141. All right.

1685

MS. GERAGOS: And this invoice we looked at yesterday, 4H141, and it was an invoice to Sean Combs for various expenses paid by CE Opco for Sean Combs. Do you recall that?

1687

MS. GERAGOS: And we looked at several of the amounts, and they correspond with the invoice within this. Do you recall that?

1689

MS. GERAGOS: And the amount here is listed $22,825.73, right?

1691

MS. GERAGOS: OK. Could we pull up --

1692

MS. GERAGOS: And the invoice date is 9/30, 2023, and the due date is October 30, 2023?

1694

MS. GERAGOS: All right. Could we go to 4D131, government exhibit, page 91. All right.

Page 91, please.

1695

MS. GERAGOS: Do you see that same amount, if we could -- do you see this is Sean Combs; this is a bank account for Sean Combs --

1697

MS. GERAGOS: -- at the top? And it lists October 31, 2023?

1699

MS. GERAGOS: All right. And could we go to October 10.

1700

MS. GERAGOS: And it says account transfer to account CE Opco LLC. Do you see that?

1702

MS. GERAGOS: And it lists that exact same amount, $22,825.73?

1704

MS. GERAGOS: All right. Could we pull up 1409, please. Government Exhibit 1409. We didn't go through this one yesterday on cross, so I just want to do it now.

1705

MS. GERAGOS: Do you see how, with the first name listed here is Brendan Paul and the amount listed is $11,734.42 at the Miami Beach Edition?

1707

MS. GERAGOS: All right. Could we go to Government Exhibit 4H-129 and go to page 2. All right. And if we could do our best to blow that up. All right. Can we highlight -- perfect.

1708

MS. GERAGOS: Do you see that there is an $11,734 charge there, Miami Beach Edition? Do you see that?

1710

MS. GERAGOS: All right. And that corresponds to what we just looked at with Brendan Paul --

1712

MS. GERAGOS: Do you see that?

1713

MS. GERAGOS: Can we just bring the first page up of this exhibit, 4H129. All right.

1714

MS. GERAGOS: This is another invoice, invoice 1640. Do you see that?

1716

MS. GERAGOS: And it's billed to Sean Combs accounts payable?

1718

MS. GERAGOS: And again, this is various expenses paid by CE Opco for Sean Combs from August 2023 to October 2023, right?

1720

MS. GERAGOS: In the amount of $58,338.64?

1722

MS. GERAGOS: All right. And listed in 1409, it was listed Jessica Ruiz as the account holder, right?

1724

MS. GERAGOS: OK. So if we could go back to 1409. All right.

1725

MS. GERAGOS: And if we look at line 3, it lists Jane with an American Air Lines flight LAX to Miami, right?

1727

MS. GERAGOS: In the amount of $3,026.90?

1729

MS. GERAGOS: All right. Could we bring up Government Exhibit 4H141, please.

1730

MS. GERAGOS: Do you see this is another invoice we just looked at; it's the CE Opco invoice?

1732

MS. GERAGOS: All right. Let's go to page 2, please. All right. And if we go to the bottom of the page, if we could zoom in on that.

1733

MS. GERAGOS: There's a corresponding charge here, $3,026 for Jane, airfare. Do you see that?

1735

MS. GERAGOS: All right. And we just looked at the fact that Sean Combs's bank account reimburses CE Opco for this entire invoice, right?

1737

MS. GERAGOS: OK. Let's go back to 1409, please. All right.

1738

MS. GERAGOS: And No. 4 listed Jane, Fuentes Transportation. The account holder is Jessica Ruiz?

1740

MS. GERAGOS: And the amount is $155.99?

1742

MS. GERAGOS: All right. Could we please go back to 4H141 that we were just looking at. All right.

1743

MS. GERAGOS: And do you see that about two items below it, it has one -- 155.99. Do you see that also for Jane?

1745

MS. GERAGOS: And right below that it also has Kabrale Williams, 187.18?

1747

MS. GERAGOS: OK. And if we could go back -- if we could to 1409. All right.

1748

MS. GERAGOS: And do you see that 5 and 6 have Cardinal Valet LLC for Jane?

1750

MS. GERAGOS: Let's go to 4H130, please.

1751

MS. GERAGOS: Do you see that this is another CE Opco invoice for various expenses paid by CE Opco for Sean Combs from January until November of 2023?

1753

MS. GERAGOS: And this is in the amount of $74,788.69. Do you see that?

1755

MS. GERAGOS: The date is November 30, 2023; due date is the next day, 2023, right?

1757

(Continued on next page)

1758

MS. GERAGOS: And this is a bill to Sean Combs for those various expenses, right?

1760

MS. GERAGOS: It says the respective break down and backups are attached, right?

1762

MS. GERAGOS: If we could please go to the next page, please. If we could go to the bottom of the page, do you see that it lists Jane's true name there, airfare is $948?

1764

MS. GERAGOS: If you go to the next page, page 3, if we could go down a little bit further down below, it's hard for me to see the lines. Do you see Cardinal Valet right above where the cursor just was, Cardinal Valet, there's two expenses.

1765

JOSEPH CERCIELLO: It's hard to see.

1766

MS. GERAGOS: If we could move the cursor up slightly?

1768

MS. GERAGOS: Cardinal Valet, you see Jane's true name, you see Los Angeles-Miami?

1770

MS. GERAGOS: 9/24, if we could highlight?

1771

JOSEPH CERCIELLO: Yes, I see it.

1772

MS. GERAGOS: I know it would be great if we could highlight it for the jury.

Then there are two charges $324.50, right?

1774

MS. GERAGOS: And $768.25?

1776

MS. GERAGOS: All right. And then if we could go back to 1409, and lines 11 and 12 have Kabrale Williams there, right?

1778

MS. GERAGOS: There's a $420 charge and a $187.18 charge, right?

1780

MS. GERAGOS: If we could go to 4H-130, which we were just looking at.

1781

MS. GERAGOS: That's what I cite to in this chart, right? So you looked at this chart before?

1782

JOSEPH CERCIELLO: Go back to the exhibit?

1783

MS. GERAGOS: We can go back to 1409. Line 11 cites to 4H-130, right?

1785

MS. GERAGOS: You looked at 4H-130 while putting together this chart?

1787

MS. GERAGOS: If we could go back to 4H-130 at page 2. And I think I meant to say actually page 3. Then if you could go down below. Perfect.

1788

MS. GERAGOS: Do you see how it says airport concierge Williams K, in the amount of $420.

1790

MS. GERAGOS: And in your chart in 1409, you wrote the account holder as Jess Ruiz and CE Opco, but you didn't write that Mr. Combs personally paid for these, right?

1791

JOSEPH CERCIELLO: No, I didn't.

1792

MS. GERAGOS: Even though you had reviewed 4H-130?

1794

MS. GERAGOS: Let's pull up 4H-130 and put it side by side with 4D-131. If we could go to page 96 of 4D-131.

1795

MS. GERAGOS: This is again Sean Combs' personal bank account records, right?

1797

MS. GERAGOS: And this date on this record is November 30 of 2023, right?

1798

JOSEPH CERCIELLO: On the one to the right.

1799

MS. GERAGOS: The one to the right, Sean Combs. Underneath Sean Combs it, says November 30, 2023, right?

1801

MS. GERAGOS: All right. And if you look here on the invoice on the left, which is 4H-130, the total due is $74,000. Do you see that?

1803

MS. GERAGOS: And 788.69, right?

1805

MS. GERAGOS: Do you see on the right in Sean Combs' personal bank records, there's an account transfer from his personal bank account to CE Opco LLC in the amount of $74,788.69, right?

1807

MS. GERAGOS: And if we could go to the one, which I haven't showed the payment out yet. Go to 4H-129, please. And have that on the left. And pull up 4D-131, page 95 on the left -- I mean on the right. I apologize.

1808

MS. GERAGOS: Again, this is Mr. Combs' personal bank account records, right?

1810

MS. GERAGOS: And the date here is November 30, of 2023?

1812

MS. GERAGOS: The amount of the invoice for various expenses paid by CE Opco for Sean Combs is $58,338.64, right?

1814

MS. GERAGOS: And then if you go on the right on November 15, there's an account from his personal bank account to CE Opco LLC in the amount of $58,338.64, right?

1816

MS. GERAGOS: If we could take that down, please? Your Honor, may I have one moment?

1818

MS. GERAGOS: We have one more video, and then we're done. The one that wasn't working this morning. If we could pull up -- turn the attorneys' screens off.

1819

MS. GERAGOS: And do you remember this morning, Special Agent, when we were looking at December 17, 2021, and you had looked at and this is page 3 of your chart, if you just want to reorient yourself, 701-114. You had confirmed the metadata was from that month, right?

1821

MS. GERAGOS: That's a great question. 1406, page 3. You had reviewed the metadata, and it related to this event, right? I mean, this time period?

1823

MS. GERAGOS: So why don't we just play, if Ms. Becker can turn off the attorneys' screens and everybody can put in their headphones, and we can play 701-45, please.

1824

(Media played)

1825

MS. GERAGOS: We're playing the wrong video. We're going to play 701-45.

For the record, that was 701-114, which is in evidence from the same time period.

1826

(Media played)

1827

MS. GERAGOS: Thank you so much, Agent.

Please go back to investigating threats to New York City. I appreciate it.

1828

THE COURT: All right. Redirect.

1829

REDIRECT EXAMINATION

1830

MS. COMEY: Thank you, your Honor. I'll be brief.

1831

MS. GERAGOS: Agent, do you remember looking at financial records just now?

1833

MS. GERAGOS: In essence, do they show that Sean Combs paid to transport Kabrale Williams across state lines?

1834

MS. GERAGOS: Objection.

1835

THE COURT: Sustained.

1836

MS. GERAGOS: Do those financial records show that Sean Combs paid for transportation bills for Kabrale Williams in September of 2024?

1837

MS. GERAGOS: Objection.

1838

THE COURT: That's sustained. Rephrase.

1839

MS. GERAGOS: Did we just look at financial records from September of 2024?

1841

MS. GERAGOS: Did they show that Sean Combs paid for a number of different travel services?

1843

MS. GERAGOS: Were those travels services for Kabrale Williams?

1845

MS. GERAGOS: Did those travel records result Kabrale Williams crossing state lines?

1846

MS. GERAGOS: Objection.

1847

THE COURT: Sustained.

1848

MS. GERAGOS: Did they reflect that Kabrale Williams was traveling from Atlanta to Florida?

1850

MS. GERAGOS: Do you remember watching videos from July 31, 2024 and August 1, 2024 just a few moments ago?

1852

MS. GERAGOS: Do you know one way or the other what, if any, drugs Jane had taken before she was filmed on those videos?

1853

MS. GERAGOS: Objection.

1854

THE COURT: Sustained.

1855

MS. GERAGOS: Do you recall being asked about dates that were not on your chart in 1406 on cross-examination?

1857

MS. GERAGOS: Is the chart meant to show every single time that Jane and Sean Combs met with a third party, or just the times that are reflected in the records that were provided to you?

1858

JOSEPH CERCIELLO: Just the times in the records that were given to me.

1859

MS. GERAGOS: And do you recall being shown text messages that were not cited in the chart that you reviewed for this case?

1861

MS. GERAGOS: Is it your understanding that the charts are meant to reflect every single message in this case or just the subset you were shown?

1862

JOSEPH CERCIELLO: Just the records that I was shown.

1863

MS. GERAGOS: Do you remember being shown a variety of text messages from a few days before or a few days after some of the entries in Government Exhibit 1406?

1865

MS. COMEY: I'd like to pull up Government Exhibit 1406, please, and let's turn to page 15 -- no -- 16. I'm sorry, 15. I was right the first time. 1406, page 15 please:

1866

MS. GERAGOS: Could you tell us the dates on row 38, please?

1867

JOSEPH CERCIELLO: Row 38, 10/17/2023 to 10/18/2023.

1868

MS. GERAGOS: What is the next entry of after that?

1870

MS. GERAGOS: What about the next entry in row 39?

1871

JOSEPH CERCIELLO: I'm sorry. Ventura v. Combs filed 11/16/2023.

1872

MS. COMEY: I'd like to pull up some messages from just a few days before and after those events. Let's pull up Government Exhibit A-

1873

MS. GERAGOS: Objection. Beyond the scope.

1874

MS. COMEY: Your Honor, it's directly responsive to the extensive cross-examination we just heard.

1875

THE COURT: Are these exhibits that the witness has reviewed in preparing the charts?

1876

MS. COMEY: No, your Honor. But they're from the time period, and similar to the way Ms. Geragos just showed a number of different exhibits that are in evidence from around the time period, I think it's perfectly appropriate for me to do the same thing on redirect.

1877

MS. GERAGOS: It's beyond the scope.

1878

THE COURT: Let's have a side bar very briefly.

1879

(Continued on next page)

sidebarsidebarRedirect Scope for Summary Chart
1880

(At the sidebar)

1883

MS. COMEY: Ms. Geragos spent multiple hours pulling you up text messages that are not cited in the chart implying they should have been or implying they apply context to the date. Me pulling up two exhibits, two pages from two exhibits around these dates that show it was a whole bunch of different context that's not captured in the chart. It's not always favorable to the defense. Some of it is favorable to the prosecution.

I think that is perfectly appropriate in response to the hours of cross-examination we just sat through where Ms. Geragos pulled up exhibit after exhibit after exhibit that is not cited in the chart and that this agent did not review.

I will be very brief.

1884

MS. GERAGOS: I believe it's beyond the scope. I didn't ask anything about messages around Ventura v. Combs, and I did not go through because we spent hours of it on direct, well, spent an hour of it on direct examination from October 17 to October 18 of 2023. I didn't do that because the jury already heard it. I went through events that the jury had not seen the text messages about before, either on my cross-examination Jane or on direct examination of this witness. My objection is based in scope and relevance to the examination.

1885

MS. COMEY: Your Honor, the examination --

1886

THE COURT: Look, here's the deal. You can obviously show the jury those exhibits which are in evidence, right?

1887

MS. COMEY: Yes, your Honor.

1888

THE COURT: You can show the jury those exhibits during your closing argument. This witness was put on for the purpose of establishing a foundation and presenting the summary charts that are now in evidence. And in cross-examination Ms. Geragos was permitted to show the limited extent of those charts by pointing to communications outside of those charts.

However, this witness has nothing to say about other exhibits that are corroborative of what's in the chart that you never reviewed. That would be the proper subject of the closing argument and you can present those very same exhibits in two days when you have closings.

1889

MS. COMEY: I understand, your Honor, but my point is the cross-examination, which just went on for many hours was suggesting to the jury that this chart is misleading because it was leaving out messages and didn't cite messages. Ms. Geragos made this point multiple times. The chart doesn't cite messages that are favorable to the defense. That was the point, and I would just like to make this one response, one response that shows that we were not cherrypicking within that chart only messages that were favorable to the government because that's the impression that this jury has been left with. So even if I could just show one message to make clear that it's not a cherrypicked chart where we just put in and cited the messages that are favorable to us. We left out messages that were favorable to us.

1890

THE COURT: This witness had nothing to do with the selection of messages for the chart, so for that reason, the objection is sustained.

1891

(Continued on next page)

RedirectRedirectJoseph Cerciello — Redirect Joseph Cerciello Maurene R. Comey
1892

(In open court)

1893

MS. COMEY: Ms. Becker, please pull up 1406, page 16.

1894

MS. COMEY: Agent, do you remember being asked about June 18, 2024 and June 19, 2024?

1896

MS. COMEY: In the records that you reviewed, did you see any text messages between Jane and Combs that were sexual in nature?

1898

MS. COMEY: Did you see any messages between Jane and Mr. Combs that were loving or affectionate in nature?

1899

JOSEPH CERCIELLO: No, I did not.

1900

MS. COMEY: I have no further questions.

1901

THE COURT: Nothing further, Ms. Geragos.

1902

MS. GERAGOS: Nothing further.

1903

THE COURT: Thank you very much, Agent Cerciello.

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