Condensed Transcript
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
Plaintiff,
CASE NO.
-vs- 502008CA028051
X.XXXMB AD
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
LARRY VISOSKI
October 15, 2009
10:18 p.m.
515 N. Flagler Drive
Suite P200
West Palm Beach, Florida
Reported By: Wendy Beath Anderson
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
4440 PGA Boulevard
ESQUIREa* Alexarter Gallo Coop or
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
EFTA01110326
Larry ViSOSki October 15, 2009
3
I P4 114£ CIRCUIT COURT OP TIM TIPTIMITE J-3DICIAL CIKUIT 1 • . -
IN MD IOR MLR REACH 010.TY, PLOPZDA
CASE MO. 5020010101POSIx110111 AD 2 INDEX
3 • • •
4
Plaintiff. 5 WITNESS: DIRECT CROSS REDIRECT RECROSS
6
JeFTISC nmxx. LARRY VLSOSK1
Defendant. 7
BY MR. EDWARDS: 6
MOOStt10N OP LAY vilest! a BY MR. CRITTON: 214
rIturenay, October 15. 3004 BY MR. EDWARDS: 220
toils - 1:11 pa. 9 BY MR. CRITTON: 221
10
511 N. Plagler Drive 11
Suite Me
Neer MIN. Satoh, florid.. 1)401 12 • • •
13 EXHIBITS
1141p9ftej Sy, 14 • • -
Wendy death Anderson, RPR, CRR. PPR 15
votary Public, State Of Plorida
,racialre Direesttlen Ninglowil 16 NUMBER DESCRIPTION PAGE
int pale brad, Office Jeb 113)541 17 PLAINTIFFS EX. 1 FLIGHT LOG BOOT(
(MARKED IN PREVIOUS DEPO)
28
19 PLAINTIFFS EX. 2 MESSAGE PAD 119
PLAINTIFF'S EX. 3 MESSAGE PAD 119
20 PLAINTIFF'S EX. 4 COMPLAINT 139
PLAINTIFF'S EX. 5 INMATE VISITOR LOG 161
21
22
23
24
25
2 4
APPEARANCES: 1 PROCEEDINGS
On behalf of the Plaintiff: 2 ...
BRADLEY J. EDWARDS. ESQUIRE
T ADLER 3 Deposition taken before Wendy Beath Anderson.
4 Certified Rash'rne Reporter and Notary Pudic in and for
5 the State of Florida at Large. in the above cause.
6 ---
On behalf of the Defendant:
ROBERT D. CRITTON, JR., ESQUIRE 7 MR. EDWARDS: We're going to put something on
ITT 8 the record about -- well, we'll do it this way -
9 MR. REINHART: Do it at the end, alter we get
10 10 him -- whatever you want. It's your show.
12 On behalf of die Witness: 11
12 MR. EDWARDS: Okay. There were -- I don't
12 oven think Mr. Welds Is aware of this. There was
13 13 a subpoena duces team for this witness, as well as
1111= 14 the previous witness, which was another pilot. Dave
14
as ALSO PRESENT: is Rogers. and that duces tocurn was to bring the
16 MES E UtRE
16 flight logs related from 1998 through 2005. What
17 27 was produced at the previous deposition were flight
is
TIME i R WITZ PA. 1$ logs from 2002 through 2005, and now Mr. Reinhart
19 19 has agreed to produce the remainder of the flight
20 logs requested, those going from 1998 through 2002.
20
RICHARD H. WILLITS. ESQUIRE (VIA TELEPHONE) 21 MR. REINHART: Correct. They're pilot logs,
22 A P.A. 22 not night logs. There are other records we
22 23 Indicated are corporate records, and with those you
23 24 have to deal with Mr. Critton.
24
25 25 MR. CRITTON: However, with the proviso, too,
Toll Free: 866.709.8777
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Suite 600
ESQUIRE Oalloo ComPal
4440 PGA Boulevard
Palm Beath Gardens, FL 33410
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EFTA01110327
Larry Visoski October 15, 2009
5 7
that we're going to work out that these records are 1 the question and you need to wait until I finish asking
to be used within the confines of this litigation 2 the question.
and not to be spread to the press or anyone else. 3 A. So yotfre not allowed to interrupt me?
because they do contain confidential information as 4 O. And you're not allowed to interrupt me.
to who may have been on the plane and other records 5 A. Like I just did?
of Mr. Rogers, which but for the subpoena would 6 O. Right.
have been only available to the FAA or some other 7 MR. CRITTON: Cara just snickered when you
law enforcement agencies. a said yotfve been accused because she recognizes
9 MR. EDWARDS: Okay. Is that all you want to 9 irs true.
10 put on? 13 MR. EDWARDS: I don't know what the meaning of
11 MR. CRITTON: Yes. 11 her snickering was.
12 MR. EDWARDS: I'm not saying I necessarily 12 BY MR. EDWARDS:
13 agree or disagree with you. Thais something that 13 Q. But for what ifs worth, if you don't
14 well deal with some other day. 14 understand the question or I've asked a bad question, I
15 MR. CRITTON: Bruce, you'd better produce 15 don't want you to guess. Give me the best answer to the
16 these records, but there has to be some sort of 16 best of your knowledge and if you need me to rephrase
17 understanding before - 17 rt. I wilt
18 MR. REINHART: Correct. 18 A. Okay.
19 MR. EDWARDS: I won't do anything until you 19 O. Okay. Tell me your current address.
20 file whatever you - until we work whatever it is 20 A
21 out in court. ill say that on the record, that
U
22 I'm not doing anything with the records outside of 22 Q. How long have you lived there?
23 my office until some Judge deals with It. 23 A. Approximately nine years.
24 MR. REINHART: And for the record, I'll adopt 24 Q. Okay. Who do you live there with?
25 what Mr. Craton said on this one limited occasion. 25 A. My wife and one chid al this tine.
6 8
MR. EDWARDS: Al right. 1 O. All right. How many children do you have?
2 Thereupon. 2 A. Two.
(LARRY VISOSKI) 3 Q. How old are they?
4 having been first duly sworn or affirmed, was examined 4 A. Fifteen and eighteen.
5 and testified as follows: 5 Q. And is the 18-year-old, is not living with
THE WITNESS: Yes, I do. 6 you?
DIRECT EXAMINATION 7 A. She's off in school.
8 BY MR. EDWARDS: a Q. Okay. What school Is that?
9 Q. Can you tell us your name for the record 9 A. Syracuse.
10 A. Lawrence Visoski, Jr. 10 Q. Who's your employer right now?
11 Q. And Mr. Visoski, have you ever had your 11 A. NES, LLC.
12 deposition taken before? 12 Q. How long has NES, LLC been your employer?
13 A. No. 13 A. I'm guessing. I'd say back 1991. I have to
14 O. Okay. Here's the process: I'm going to ask 14 do the math, but 17, 18 years.
15 you questions. You're going to give us answers. Try to 15 O. Has that been your only employer since 1991?
16 give us answers that we all understand and that the 16 A. Yes.
17 court reporter can take down, such as yes, no. or some 17 O. And has that been your only source of income
18 other verbal answer that we can understand. It's easy 18 since 1991?
19 when we get in a casual conversation to nod or shake 19 A. Yes.
20 your head, and the court reporter is not writing 20 Q. And what is NES, LLC?
21 pictures or anything else. 21 A. I don't really know. I mean, rt's the company
22 A. I understand. 22 that my check comes from.
23 O. The other thing is, and I've been accused of 23 Q. What do you do for NES, Lie that results in
24 this In other depositions -- I donl know if it's true 24 them paying you?
25 or not -- but I need to wait until you finish answering 25 A. I am chief pilot for the aircraft and
Toll Free: 866.709.8777
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Suite 600
ESQUIR
.m E 4440 PGA Boulevard
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irnvw.esquiresolutIons.coM
EFTA01110328
Larry Visoski October 15, 2009
9 11
. helktopters. 1 O What floor or suite number is NES. LLC In?
0. And do you have a specific boss or somebody 2 A. I believe — well, I don't know that NES, LLC
you answer to at NES, LLC? A has an office there. I know that's where Leslie has the
A. Several people would call to schedule flights 4 phone number where I call So I don't know for a fact
from the office, being it either Mr. Epstein or, you 5 rf NES. LLC has an office there.
know. I would lust get a phone call and they would 6 O. And whet suite number, then, would Leslie
schedule a trip. 7 Gruff sit in to answer that telephone number at
Q. Okay. Aside from Mr. Epstein, who else would MIM
A. I think It's 10F.
9 there be that would call to schedule flights? 9
10 A Leslie. 10 Q. And when you stay a
11 0. Leslie who? 11 what suite number or what apartment number do you stay
12 A. Leslie Gruff. 13 in?
13 Q. When's the last time you talked to Leslie 13 A. 12C.
14 Gruff? 14 0. And how about Dave Rogers, where does he stay?
15 A. Probably two weeks ago, three weeks ago. 15 A. I'm guessing, because it's been some time
16 Q. And where is she currently? 16 since we've been there, 108, but don't quote me on
17 A. I believe in New York, is where I spoke to her 17 0. Who are the other people in that building that
18 on the phone last. 18 you know to stay there on a reguku — fairly regular
19 Q. What's the telephone number you call to reach 19 basis?
20 Leslie Gruff? 20 A. the seen people in the elevator that. you
21 A. 21 know, have been on the airplane. Case in point. maybe
22 Q. And what address is Leslie Gruff at? 22 but I dorYt know totaled that she Wes
23 A. Do you mean where the office Is located? 23 there, or anybody else for that matter.
24 0. Correct 24 0. Okay. When you say you've mein..
25 A. 25 on the elevator
10 12
1 0. And It's my understanding from other A. I only assume she Wes there. I don't know
2 depositions that there are also apartments In trial. 2 for a fact. rm hying to be honest and factual for
building? 3 you. So I couldn't honestly say if I knew she lived
4 A. Yes. 4 there or not
5 Q. And Mr. Epstein either owns or leases or rents 5 0. Where do you thine Wes?
6 certain of those apartments. Is that your 6 A. I would think she lives there.
7 understanding? 0. You don't have a bettor location?
a MR. CROTON: Form; speculation. 8 A. I don't have another location.
9 THE WITNESS: I'm only speculating. I 9 0. Anybody else?
10 don't -- to my understanding, I don't know. 2o A. Not to my knowledge. I mean, I'd only be
11 BY MR. EDWARDS: 11 guessing that people We in that builckng that -- you
12 0. Do you know other people that live in that 12 know, I don't have any facts to prove that they actually
13 building? 13 live there. I mean, I don't think you want me to guess.
14 A. Well, it would be myself. Dave Rogers - wet 0. Well, NES, LLC, would you say that the owner
35 when you say "live,' explain. 15 or controller of that company Is Jeffrey Epstein?
16 0. When you're saying yourself and Dave Rogers - 16 MR. CRITTON: Form.
17 A. See, we don't live there. I mean, we have -- 17 THE WITNESS: I don't know that for a tact.
18 we would stay there when we would have a trip. 1e BY MR. EDWARDS:
19 Q. Okay. When you would fly up to New York and 19 0. Jeffrey Epstein is somebody you've Indicated
20 land in New Yogic, the place where you would stay, is 20 that you've worked for for 17 or 18 years, right?
21 the 21 A, Yes.
22 A. Yes, that's corned. 22 0. And over the 17 or 18 years you've become
23 0. That's also a location you've indicated in 23 personally close with him as wee, correct?
24 this deposition that Is the office for NES, LLC? 24 MR. CRITTON: Form.
25 A. Yes. 25 THE WITNESS I Oaf* understand how you mean
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE •• SOM.!. Oal *U./al
4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esqulresolutlons.com
EFTA01110329
Larry Visoski October 15, 2009
13 is
1 'dose.' Define that. 1 you know. televisions and such.
2 BY MR. EDWARDS: 2 O. Is that another hobby or job or something of
3 a Wel, rpm so than just a pilot that takes him 3 yours?
4 from Point A to Point B? 4 A. Both.
5 A. That is my job. 5 O. Does he pay you for that?
6 O. Right. But you know him on a personal level 6 A. Not any more than my salary.
7 and that you've had personal conversations that don't 7 O. What's your current salary?
8 necessarily deal with flying from Point A to Point B; A. At this time, 180,000.
9 isn't that right? 9 O. And what aro you paid $180,000 to do?
10 MR. CRITTON: Form. 10 A. To manage his aircraft.
11 THE WITNESS: More specific, meaning we talk 11 O. What does that entail?
12 about cars. I mean, does that make you a personal 12 A. Schedufing maintenance. Anything that has to
13 friends? 13 do with any flight, whether it be weather, flight
14 BY MR. EDWARDS: 14 planning, time and distance to and from a location, any
15 O. Have you ever gone to his house to eat? 15 logistics involved In running an operation that has
16 A. No. 16 aircraft.
17 O. Have you been to his New York home? 17 O. In addition to the 180,000, does he give yc.
18 A. Yes. 1$ bonuses as welt?
19 O. How many occasions have you been to his New 19 A. There have been Christmas bonuses.
20 York home? 20 O. Over the years, you mean, there have been
21 MR. CRITTON: Object to form. 21 Christmas bonuses?
22 THE WITNESS: We normally pick up luggage In 22 A. Yes.
23 the lobby, so it would probably be quite often. 23 O. Is 180,000 the most he's ever paid you?
24 Any time we depart out of New York, we stop by the 24 A. No.
2S house and pick up luggage and head to the aircraft. 25 O. All right Were you making when was the
14 16
BY MR. EDWARDS: 1 last time that you were making an amount different than
2 O. Other than picking up luggage, have you been 2 180,000?
3 to his home to visit or socialize with him? 3 A. Last year.
4 A. Not to socialize, no. 4 O. That would be 2008?
s a Have you been to his Palm Beach home? A. That would be correct. Yeah, we all took a
A. To? 6 salary cut, I don't know the exact date. It might have
O. To Mr. Epstoin's Palm Beach house? 7 been 2008, last year. It was last Christmas wo all took
8 A. Right. 8 a 10 percent salary cut.
9 O. Have you been there? 9 Q. Do you know why?
10 A. Yes. 10 A. Economic reasons.
11 O. Have you been inside? 11 O. And who told you that you were going to have
12 A. Yes. 12 to take the salary cut?
13 O. And how many occasions have you been inside 13 A. Darren Indyke.
14 that home? 14 Q. And did you ask for an explanation?
15 A. The same, as far as picking up luggage, and 15 A. lie explained it was due to economic reasons
16 that would be on a regular basis, you know, for a 16 throughout the country.
17 departure. We wouldn't always go to the house to pick 17 O. Okay. So In 2008, how much was -- were you
18 up luggage, but it made it easier for loading the 18 being paid by NES, LLC?
19 aircraft getting it done prior to departure. 19 A. 200.000.
20 Q. Is that the only reason that you have ever 20 O. And is 200,000 the most that you've ever made
22 gone to the Palm Beach home over the last 18 years. is 21 from NES, LLC?
22 to pick up luggage? 22 A. Yes. sir.
23 A. No. 23 O. And on top of that $200,000, did you get a
24 Q. What other reasons have you gone there? 24 bonus that year as well?
25 A I've set up several home theater equipments. 25 MR. REINHART: Which year are you bildng
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Larry Visoski October 15, 2009
17 19
about? 1 my paycheck. So I don't even know what's written on the
MR. EDWARDS: 2008. 2 lop of it.
THE WITNESS: That year, I think we skipped 3 0. That would be something that only your wife
Christmas bonuses that year. The last bonus might 4 would see. I'm assuming?
have been 2007. 5 A. You're right, since she probably wouldn't know
BY MR. EDWARDS: 6 the answer either, because she's looking et the right
Q. If you ever got a bonus from Mr. Epstein — 7 column and not the top column.
and I'm only deriving this from you using the term a 0. Right. When is the first time that you had
9 'Christmas bonus' 9 heard the name NES, LLC, that company?
10 A. Holiday bonus. 10 A. Fwe. Six years, and even questioned what'd
11 Q. -- am I correct to assume sorry. Am I 11 stood for. And I think to this day I couldn't answer
12 correct to assume that if you got a bonus, there was 12 that honestly, what It stands for.
13 only one and it was at the end of the year, around the 13 0. Okay. But it's your understanding that the
14 holidays? 14 NES, LLC is paying you for the work that you do as a
15 A. Yes. 15 pilot or maintain the planes for Jeffrey Epstein?
16 Q. Okay. And how much was the 2007 holiday 16 A. To my understanding, yes.
17 bonus? 17 a And back In 1991. do you know If It was a
18 A. I'd have to ask my wife. to be honest. I 18 dffereert company that was paying you or if it was
19 haven't seen my paycheck in 27 years. so I believe it 19 Jeffrey Epstein directly paying you?
20 was 310.000. 30 A. I don't remember. I mean, I don't
21 Q. And in 2007 you also made $200,000? 21 0. Okay. Throughout your career with -- as a
22 A. Yes. 22 pilot laJeffrey Epstein, since 1991, has there ever
23 Q. Okay. 23 been a time when you believe you we paid directly from
24 A. With a question mark. I'm trying to be as 24 Jeffrey Epstein personally versus some company?
25 accurate as I can, but yes. 25 A. Not to my kncrertedge, no.
18 20
0. Something pretty close to mat? 0. Okay. So whether s was NES. LLC or some
A. Yes, sir. 2 other company, it was all of a sudden a company name, to
0. Okay. So with the bonus it was 210,000. 3 the best of your linoviedge?
roughly? 4 A. Exactly, yes.
5 A. Right. 5 0. And back in 1991, do you remember
0. Okay. And how long were you making that 6 approximately how much you were being paid that year?
salary? 7 A. Fifty-live or 80.000. is maybe what I started.
A. Probably -- he was very religious about giving 8 0. Okay.
9 annual increases. so I would probably say 2006, you A. You're going back a long ways.
10 know. It was -- we would get Increment increases of 10 0. Yes.
11 five or $10,000 each year. So I would say 2006. So it 11 A. I'm trying.
12 graduated. you know, progressive. 13 0. Your relationship goes back that far. There
13 0. Okay. Do you remember the progression if we 13 why I those that year.
14 start at 1991? Do you remember roughly what the 14 A. Right.
15 progression was up through 2007/2008, when you were 15 0. Okay. Did you get bonuses even back that far?
16 making $200,000? 16 A. Yes, sir.
17 A. No, I wouldn't know the progression. 17 0. And do you remember what your bonuses were
15 0. Okay. Do you remember what you were making as approiknately?
19 from -- and was NES, LLC the company paying you back in 19 A. 5,000. I mean. that was laird of the — the
20 1991? 20 starting point.
21 A. I don't know. I don't remember. Let me say 21 0. Okay. In addition to moneary bonuses. were
22 it that way. I don't remember. 22 there ever gifts or any other type of compensation that
23 O. Okay. When how long do you remember NES, 21 NES, LLC or Jeffrey Epstein provided you?
24 LW being the payer of your check? 24 A. Yes.
25 A. Personally, two years. because I've never seen 25 0. And is that over the span of the 18 years?
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21 23
A. Yes. 1 Q. But more so than that, if there's going to bo
O. Okay. Ten me what some of those items are. 2 a casual conversation about a peel or a pool heater or
A. I remember one specifically was a pool heater. 3 whatever, Ws going to be with you most likely if he's
Q. Excuse me? 4 going to be talking to pilots, right?
A. A pool heater. 5 MR. CRITTON: Form.
Q. When was that? 6 THE WITNESS: Right.
1995-ish. 7 BY MR. EDWARDS:
Q. Okay. Why did you get that? O. Okay. And you feel like over the years yoke
9 A. I had built a pool and I didn't have a heater 9 relationship with Jeffrey Epstein has boon pretty good?
10 and he kind of laughed at me saying, 'How can you have a 10 A. Yes.
11 pool without a heater?' So he says, 'You ought to get a 11 O. And you have been closer to him over the years
12 heater." 12 as you've grown to know him?
13 Q. Where were you when you had that conversation? 13 MR. CRRTON: Form.
14 A. In the airplane. 14 THE WITNESS: The same throughout the same
15 O. How ofd he know that you had bunt a pool? 15 year. We never got any closer than 1991 than I am
16 A. Just in general conversation, 16 wilt him now. I'm very professional at what I do
17 O. You were having a conversation with Jeffrey 17 and know the line between being professional and
18 Epeteli? 18 thinking you're somebody's buddy.
19 A. Yes. 19 BY MR. EDWARDS:
20 O. And this is something that was happening on 20 O. Okay. So thars not something that you think
21 the airplane, this conversation? 21 you are? You don't think you're his buddy?
22 A. Dung the flight Yeah, It would have been 22 A. No, sir.
23 We on cruise or something. 23 O. Do you consider yourself his friend?
24 Q. Okay. When you say during the flight,' does 24 A. I believe so.
2s that — 25 Q. Do you think he considers you his friend?
22 24
A. Again, you're going back a long ways. 1 A. I think so.
2 O. I understand. We're larking about 1995 right 2 O. All right. What makes you think that?
now. 3 MR. CARTON: Speculation.
A. Yes. 4 THE WITNESS, He's always been kind and
5 O. You're having a conversation with Jeffrey 5 respectful.
6 Epstein. Who is flying the airplane? 6 BY MR. EDWARDS:
7 A. The auto pilot and there's two crew. O. Ever invited you to dinner?
8 O. Okay. So are you back in the back portion or A. No, sir.
9 Is he up In the cockpit? 9 Q. Have you ever associated or socialized with
10 A. Up in the cockpit. t0 him during the day at any of his homes?
11 O. Okay. Jeffrey Epstein sometimes comes up 11 A. Only during a business reason.
12 there? 12 O. Okay. What are the other are the places
13 A. Just, yeah, in between the two pilot seats. 13 that you believe that Mr. Epstein owns? I know we've
14 Q. All right. Is that something that was 14 talked about this Manhattan -- the Manhattan house.
15 typical, to have conversations like that? IS I've read the altos about it, the Palm Beach mansion.
16 A. Mm-hmm. 16 But what other places are you familiar with that
1? O. Yes? 17 Mr. Epstein owns?
18 A. Yes. No nodding. 18 MR. CRITTON: Form; predicate, speculation.
19 O. And woukl those conversations be directed 19 THE WITNESS: To answer it honestly. I don't
20 mainly with you or with the other pilots as well? 20 know specifically that he owns any of the
21 A. Mainly with me. 21 residences, to be honest. I would only assume that
22 Q. I mean, you've kind of been described as the 22 he owns. So if you want me to answer honestly. I
23 main guy or the main pilot. Wouldn't you consider that 23 don't know that he owns any of the other.
24 pretty much your role, right? 24 BY MR. EDWARDS:
25 A. Well, that's chief pia 25 Q. Okay. Well, what would be the basis for your
Toll Free: 866.709.8777
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Larry Visoski October 15, 2009
25 27
assumption that he owns the home in Pakn Beach? 1 O. Am those private airports?
2 A. He goes there, but I don't assume -- you don't 2 A. Public.
a have to own a house to go to it. 3 O. Public, okay. Are there any private landing
Q. And not only does he go there, you're aware places where you would land any airplanes in New Mexico?
that he spends the night there: he resides there 5 A. There are.
6 sometimes, correct? 6 0. That you have landed
A. Yes. 7 A. That I have.
5 0. When he's in Palm Beach, Mat's where he — 0. - his airplane?
9 A. He sloops. 9 A. Yes.
10 0. sleeps? Right. When he's in New York, do 10 0. Where?
11 you know where he sleeps? 11. A. We have a 4500-foot strip on the ranch.
12 A. No. 12 0. When you say 'we.' yourself and somebody'
13 Q. But you've been to a particular house in New 13 A. The company.
14 York that's a very large house that we've all read about 14 Q. What company?
15 that you picked up luggage at, right? 15 A. Well. I should say I see where you're going
16 A. Yes, sir. 16 waft that. The ranch owns — whoever owns the ranch.
17 MR. CRITTON: Form. 17 The ranch has a runway on it.
18 BY MR. EDWARDS: 16 Q. Okay. And you've landed an airplane on that
19 0. And that home, do you know that — I know that 19 noway?
20 you're saying that you haven't done a public record 20 A. That ranch. yes.
21 search to make sure that Jeffrey Epstein owns it. 21 Q. How many times do you think you've landed
22 A. Yeah. 22 there?
23 0. But you assume that he does? 23 A. Ten.
24 A. Assuming. 24 Q. All right. And have you been inside his
25 0. That's where he sleeps when he's in New York? 25 ranch?
26 28
MR. CRITTON: Form. 1 A. Yes.
2 THE WITNESS: I assume. 2 MR. CRITTON: Form to the last question.
3 BY MR. EDWARDS: 3 MR. REINHART: Can you clarify, the physical
4 0. That's where his luggage is when you pick it 4 ranch or the residences or the structures on the
up? 5 ranch?
6 A. Doesn't mean he owns It. 6 MR. EDWARDS: I don't have a good visual
0. Right. But that's where it is? 7 appreciation for it.
A. Yes, sir. 8 BY MR. EDWARDS:
9 0. Do you know of anybody else who owns that home 9 Q. Why don't you describe it in your words what
10 in New York? 10 this ranch Mal We are talking about looks like. And
11 A. No. 11 I've heard it referred to as the Zorro Ranch. Have you
12 0. Okay. Have you been to his ranch in New 12 heard that?
13 Mexico? 13 A. I've heard that.
14 A. Yes. 14 0. That's the ranch we're all familiar with,
15 MR. CFUTTON: Form. 15 we're talking about where the runway is and everything
16 BY MR. EDWARDS: 16 else?
17 0. How many times have you been to his ranch in 17 A. Yes.
18 New Mexico? 18 0. Describe it in your own words, the landscaping
19 MR. CRITTON: Form: predicate. 19 of this ranch. What do we have on it?
20 THE WITNESS: A guesstimate. fifty times, only 20 A. There is a house up on the hal, a large
21 due to the fact that we would fly there. 21 house.
22 BY MR. EDWARDS: 22 O. How big?
23 0. And where would you land? 23 A. Big. I've read 40,000 square feet In the
24 A. Depending upon the aircraft, either 24 paper.
25 Albuquerque or Santa Fe. 25 O. Have you been to it?
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29 31
1 A. Yes. 1 A. Yes. sir.
2 Q. Does that seem like it's feasible, 2 Q. And he sleeps there?
3 approximately 40,000 -- 3 A. Yes.
4 A. I think so. yes. 4 Q. Okay.
5 Q. What else do we have on it? A. I assume he does.
6 A. There Is a compound that hes kind of motel 6 0. You assume he sleeps?
7 room type -- they call it bunkhouse. 7 A. I do. I think.
8 0. Where's the bunkhouse located? 8 Q. Okay.
9 A. At the entrance to the ranch. 9 MR. CRI1TON: This Is really --
10 0. Okay. And what Is that primarily used for? 10 BY MR. EDWARDS:
11 A. For the people that work on the ranch, they 11 0. Other than the pool heater in 1995. have you
12 reside there. It's also a place where anybody that 12 ever received any other gifts on top of the compensation
13 traveled on the airplane would stay. It's lTd of Eke, 13 from Mr. Epstein?
14 you know, a hotel room. 14 A. I did get land on the ranch to build a house.
15 0. And how far is that from the first house that 15 Q. What do you mean you got land on the ranch?
16 you deserted, the 40.000 square foot house? 16 A. He deeded me land to build a home.
17 A. Its probably 4 miles. 17 Q. When was that?
is Q. Okay. So the Zone Ranch is a rather large 1$ A. Ten years ago at least
19 area of property? 19 Q. Do you know 4 he's ever deeded anyone else in
20 A. Yes. 20 this world land on the ranch to bultd a home?
21 0. And how many times I know we just talked 21 A. Not to my knowledge.
22 about how many times you've been In the house, but how 22 0. Why did he do that?
23 many times have you been on that ranch in New Mexico, 23 A. We would vacation out there and my wife Ion
24 the Zorro Ranch? 24 In love with New Mexico and we were looking for
2s A. Thirty to fifty times over the years. mars 25 property.
30 32
1 a guesstimate. 0. And did you talk to him about that?
0. Is that over when was the first time that 2 A. Yes. He knew I •• he was aware I was looking
you went to that ranch? 3 for a home and he says, 'Well, I have so much land. I
A. A guess, I don't know when it was. actually, 4 could (PO you a spot to build a home on.' So I built a
E.. our first trip, but 1995/94. 5 house.
Q. Okay. And do you believe Jeffrey Epstein 6 0. So how long has a home actually been on that
7 and/or a corporation owned or controlled by him to be 7 ProPeffn
8 the sole owner of that ranch? 8 A. Nine years.
9 A. I don't know any of those details. 9 Q. And !hats a home that you own?
10 Q. Have you ever talked to Jeffrey Epstein about 10 A. Yes. sir.
11 who owns that ranch? 11 O. And that's a home that was when I say 'you
12 A. No. 12 own it" Is there a mortgage on it or did he give 4 to
13 0. Do you know of anybody else who may own that 13 you free and clear?
14 ranch? 14 A. No, no, I paid for the house. I made payments
15 A. Not to my knowledge. 15 on it.
16 Q. Other than Jeffrey Epstein, do you know of 16 0. All right. So what did he actually give you?
17 anybody else who regularly stays there when they're in 17 A. 4O-acres of land.
18 New Mexico? 18 0. That you did not have to pay for?
19 A. Not to my knowledge. 19 A. You know. I'd have to go back and look I
o Q. Does Jeffrey Epstein stay there when you're In 20 think it was — I had to pay something for it I don't
21 New Mexico? 21 remember.
22 A. He has. 22 Q. How often have you visited that piece — that
23 Q. And he has a key to the place? 23 home that you own?
24 A. I don't know if there's a key. 24 A. My wife would spend summers out there with the
25 Q. One way or another, he gets in, right? 25 kids.
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Q. Okay. But that's on the Zorro Ranch? 1 A. 1800 square feet.
2 A. Yes. 2 0. Were you ever at that house at the same time
3 Q. So in addition to the 50 or so times you've 3 when he's at his house that's on that Zorro Ranch?
4 been to the Zono Ranch, you've been to your property 4 A. Yet
that's on the Zorro Ranch? 5 O. All right. We started back in 1991 with you
6 A. Yes, which over the years, Ws once-a•year 6 making around $55,000 a year and that has progressed
7 vISIta. So I mean, it is included in the 50 times that 7 over tine to a point where in 2007 you were making
8 I've been there. a $200,000 a year. I don't want to go through every
9 0. Okay. And cad you have a conversation with 9 single year; that would take a really long time. But
10 htrn that led to him giving you or gifting you 40-acres 10 the progression, was that on a yearly basis normally or
11 of land? 11 after two years or three years?
12 A. We talked about it because he knew I was 12 A. Yearly basis.
13 looking fora home out there. 13 0. Okay. And would that normally be in
14 Q. Okay. In gifting you that land, did you 14 increments of?
15 consider yourself at that point in time to be more than 15 A. $5,000.
16 just his pilot, as more of a friend? 16 0. Okay. You've talked about a couple other
17 A. No. You're using the word *gifting.' I paid 17 gas that have been given to you from Jeffrey Epstein
18 for the land. I don't recall what it was. But you use 18 over the years: one is a pool heater in 1995 and now
19 ttre word 'friend.' I don't know that a -- sure• he was 19 some 40 acres of land on his New Mexico ranch. Any
20 a friend. I mean... 20 other gifts you can think about?
21 0. Well, did he give Dave Rogers any land out on 21 A. No other gifts.
22 the New Mexico ranch? 22 Q. Okay. I don't want to split hairs with you.
23 A. No. 23 You obviously thought about that answer before giving
24 0. Okay. When you say you paid for it, I thought 24 it. What other Items are you thinking about that he's
25 that I asked that question, "Did you pay for the 25 given to you or cut you a discount on or otherwise that
34 36
40•acres?" I thought your answer was, don't know, 1 you feel was compensation for you working for him?
rd have to go back and look.' 2 A. I drive a company car. I mean...
3 Are you saying now that you did pay for that 3 O. Okay. What kind of car?
land? 4 A. A Hummer.
A. I don't remember. If there was a sum of 5 0. You say 'a company car." That's owned by NES,
6 mOney, It was just for, you know. the legal purpose of a 6 LLC?
transfer of ownership of the lend. 7 A. No, I think the registration has Zorro
0. Okay. If 4 was a substantial amount of 8 Development on it.
9 money, that's something that you would have remembered? 9 0. What is Zorro Development?
10 A. Oh, exactly. No. It was not a substantial 10 A. I believe that's the ranch, or et least it has
11 amount. 11 the name of the ranch. I don't know what the entity Is
12 Q. Okay. Do you remember approximately how much 12 0. And It's your understanding that that's a
13 money you had to give Jeffrey Epstein for that land? 13 company vehicle?
14 A. I would only be guessing. ft might have been 14 A. Yes.
15 five defiers. To my knowledge, 1 don't remember. 15 0. And where Is that vehicle primarily garaged'
16 0. Okay. So when I'm saying he gave you the 16 A. At my bane.
17 land, he may have actually given you the land? 17 Q. In West Palm Beach or in the Zorro Ranch?
to A. Sure. 18 A. No, here in West Palm Beach.
19 0. Okay. And to the best of your knowledge. he's 19 Q. All right. And is there only one company
20 never given anyone else land out there? 20 vehicle that you're issued?
21 A. Not to my knovrtadgo. 21 A. Yes, sir.
22 MR. CRITTON: Form. 22 O. And is that something that was that you did
23 BY MR. EDWARDS: 23 net have to pay for?
24 0. All right. How big is this house that you 24 A. No. it's just something I drive. I mean, it's
25 built on the ranch? 25 not titled to me or anything like that. It's just a car
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37 39
1 that I drive. 1 0. And which airplane was that?
2 0. All right You've worked ter him for 18 2 A. The Hawker.
1 years. I don't even know how long the Hummer would 3 0. Does he stilt have the Hawker?
4 last, but presumably, that's not the car you've had over 4 A. No.
5 the entire 18 years. Have you allays had a company car? 5 0. How long did he have that plane?
A. No, I haven't, no. 6 0. Flve years. guesstimate: four or Ilve years.
0. When did you get the Hummer? 0. So sometime in the mid '90s?
8 A. Probably three years ago. a A. Yes.
9 0. Do any other members of Mr. Epstein's piloting 9 0. Did you keep any type of logs or documentation
10 team have company cars? 10 as to who would have been flying on that airplane if you
13 A. No. 11 transported any individuals?
12 0. Only you? 12 A. The same logs as you possess now are the
13 A. Yes. 13 Nght logs.
14 0. And do you know how that decision was made to 14 0. Okay.
15 get you a company vehicle? 15 A. That's the standard for the industry.
16 A. No. 16 Q. So that's something that you kept, or that
17 0. What do you use that vehicle for? 17 Dave Rogers kept?
18 A. To and from the airport. 18 A. Dave Rogers.
19 0. AU nght. Do you use it for personal reasons 19 0. Okay. If there are any documents out there
20 also? 20 with names of passengers on any of the flights involving
21 A. I guess. yea. 21 planes owned or controlled by Jeffrey Epstein and/or his
22 0. I mean, that's your primary vehicle? 22 companies, those would be documents in the possession of
23 A. Yes. or I drive my wife's car. 23 Dave Rogers and not yourself?
24 0. Which Is? 24 A. Oh, the corporation actuay, they belong to.
25 A. Type of car? 25 Q. Okay.
38 40
1 O. Yes. 1 MR. REINHART: That was a compound question.
2 A. A Mercedes. 2 You might want to split it In half.
3 0. Ands that something that was also a gift 3 MR. EDWARDS: Okay.
4 from Mr. Epstein? 4 BY MR. EDWARDS:
5 A. No, sir. S Q. What documents do you believe exist that
6 0. What type of Mercedes Is that? 6 indicate names of individuals that have been passengers
7 A. AML 430, ten years old. 7 on Mr. Epstein's airplanes?
O. MI right. Are there any other items — MR. REINHART: Are we going back all the way
9 company car, the land In New Mexico, the pool healer — 9 from '91 to the present?
30 any other items that Mr. Epstein has given you over time 10 MR. EDWARDS: Sire.
11 as compensation or reward or anything else? 11 THE WITNESS: You're talking about the Hawker?
12 A. No. sir. 12 BY MR. EDWARDS:
13 0. And your only income is from Mr. Epstein or 13 0. Any airplanes. What documents would there bo?
14 his companies? 14 A. There would be the same: Right logs and
19 A. Correct. 15 passenger manifests would exist.
16 0. Okay. And It's been that way since 1991? 16 0. And are either of those required?
17 A. Yes. 17 A. The flight log is required for the aircraft to
18 0. How did you meet Mr. Epstein or became 18 track times and landings.
19 involved with him in 1991? 19 0. And In the flight log. is it required that you
20 A. We heard at the airport that Mr. Epstein was 20 designate the names of the passengers?
21 purchasing an airplane when Dave Rogers and myself were 21 A. No.
22 living in Columbus, and we had the opportunity to 22 0. That's just something that Dave Rogers did on
23 interview with him, and we did and got the job. 23 his own?
24 O. And this is before he owned the airplane? 24 A. Everybody does that. ICs more for Internal
25 A. Yes. 25 Revenue.
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41. 43
1 0. Okay. If something happens, they know who is 1 A. Jeffrey would always critique Dave's flying
2 on the plane? 2 capabeities, and I tried to help Dave and explain to
3 A. Exactly, weight and balance. 3 him what Jeffrey likes and doesn't like. And Jeffrey's
4 0. Have you ever kept any flight logs that have 4 also conveyed these likes and dislikes. And Dave
5 names of people on the airplane? maintained continuing with certain piloting techniques
6 A. When you say 'kept? I have filkxl out flight 6 that were just not comfortable to passengers. And this
7 logs or the passenger manifest, yes. 7 went on through the years. and Jeffrey just got tired of
8 0. By 'kept' I meant maintained to where they're it one day.
f/ in your possession either on paper or computer? 9 0. What specifically were Jeffrey Epstein's likes
10 A. We keep -- 10 and dislikes with respect to the flight of the plane?
11 MR. REINHART: Can you differentiate a flight 11 MR. CRITTON: Let me put in a form here. But
12 log from the plot's log that we showed you 12 I don't know what this has to do with anything in
13 earlier? 13 this case.
14 MR. EDWARDS: Okay. 14 MR. EDWARDS: I understand that, Bob.
15 BY MR. EDWARDS: 15 MR. CRITTON: I want to use this for some
16 0. I'm talking about -- I dont know that Ws 16 other depositions where we -- we've gone beyond the
17 called a flight log. a pilot's log or any kind of fog. 17 wope.
18 A. They are different. yea. 18 THE WITNESS: The case In point, the last
19 0. Yeah. I'm asking about, have you kept or do 19 straw was there was a technique called quiet flying
20 you have any documentation that would indicate the names 20 where you would retard the throttles well short of
21 of passengers that have flown on any of Jeffrey 21 the runway and pretty much glide the airplane in
22 Epstan's planes? 22 Well, if you don't do that correctly, you have to
23 A. No. 23 spool the engines up just prior to touching down
24 0. Either in the form of paper or on a computer? 24 that -- because you're losing air speed and it's an
25 A. No. 25 uncomfortable sound and feeling for the passengers
42 44
1 0. Makes that easy. 1 thinking that you're not going to make the runway.
2 A. Okay. 2 And it was a continuous practice of Dave doing that
3 0. In 1991, were you the chief 0100 3 to be neighbor friendly as opposed to being
4 A. No. 4 passenger-comfort friendly.
5 0. Somebody else was the chief pilot? 5 BY MR. EDWARDS:
6 A. Yes. 6 0. Okay.
7 Q. Who's that? 7 A. Hence, the transfer of power.
8 A. Dave Rogers. 8 0. Has he ever discussed with you where he wants
9 0. All right. At what point in time did you 9 you to be, whether that is -stay in the cockpit when I
10 become chief pilot and switched with Dave Rogers? 10 have people on the airplane," or don't intermingle with
11 A. Six years ago; five, six years ago. 11 the passengers or anything else?
12 0. Why? 12 A. He's never stated that to us.
13 A. Professionalism, technique. 13 MR. REINHART: Could you clarify which "h0
14 0. What do you mean by that? 14 you're talking about?
15 A. The way Dave would operate an aircraft. 15 MR. EDWARDS: I'm talking about Jeffrey
16 Jeffrey knew the difference when I was flying and when 16 Epstein.
17 Dave was flying. 17 MR. REINHART: ()Say.
18 0. How do you know he knew the difference? 18 BY MR. EDWARDS:
19 A. Just -- 19 Q. You understood that?
20 0. He told you? 20 A. Yes.
21 A. Yes. He knew the difference that if ho never 21 0. It's my understanding that in the -- wall
22 came up front, he knew who was flying, who landed. 22 tell me other than the Hawker, what other airplanes have
23 0. And what was the conversation that he had with 23 you flown for Jeffrey Epstein?
24 you that resulted in you becoming chief plot, switching 24 A. A Gulfstream.
25 positions with Dave Rogers? 25 0. Does he still have that plane?
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A. Yes, sir. 1 and who was on the flights?
O. How bier:deplane is that? 2 A. One flight I believe we went to Sebring and
A. Large corporate Jet. 3 another flight we went to Nassau, Bahamas.
O. How long has he had it? 4 O. And who did you go to Nassau, Bahamas with?
A. Fourteen years; 13.14 years. A. I'd have to look at the flight log, but I
O. And other than the Gulf stream, what other 6 think It I behave. I think
wa
airplanes does he have? 7 that was the three passengers. to the best of my
A. When you say she; obviously. these are a knowledge.
company-owned -- 9 O. And ills my understanding that little
O. Jeffrey Epstein or his companies. 10 St. James is an island that Jeffrey Epstein owns or
A. A Boeing 727. 12 controls?
22 O. Wee, I know that's a very large airplane. I 21 MR. CRITTON: Fenn.
13 think that's been described by other people, so I'm not 13 THE WITNESS: I don't know that he owns it.
14 going to have you do that But there's partitions In 14 BY MR. EDWARDS:
15 that airplane in the back rooms of that airplane. 15 O. Has he ever been to an island called Little
16 right? 16 St. James?
17 A. Yes. 17 A. Yes.
Is O. Several different partitions to where if the 3.0 O. And have you been there with Jeffrey Epstein?
19 pilot comes out of the cockpit, you don't necessarily 19 A. I've been there when he was there.
20 see ell the passengers? 20 O. Have you flown on an airplane with him to that
21 A. Yes 21 destination?
22 O. Thars true? 22 A. No.
23 A. Yes. 23 O. AP right. When you say you've been there
24 O. Okay. 24 when he was there, how did that come about?
25 MR. REINHART: Keep your voice up so she can 25 A. We flew into St Thomas and then we flew to
46 48
hear you. 1 Little St. James In a helicopter.
THE WITNESS: Oh. 2 O. And do you fly the helicopter as well?
MR. REINHART: And so Mr. Willits can hear 3 A. Yes.
you. 4 O. How many helicopters are owned or controlled
BY MR. EDWARDS: 5 by Jeffrey Epstein and/or corporations associated with
O. Other than the Gulfstream and the Boerig and 6 him?
the Hawker, what other airplanes has Jeffrey Epstein 7 MR. CRITTON: Form.
owned over the years? THE WITNESS: At this time. one.
A. Thetis& 9 BY MR. EDWARDS:
I0 O. And currently still owns or the companies 10 O. And has that helicopter been flown in the last
11 associated with him own the Gultstream and the Boeing? 11 two years?
12 A. Yes. 12 A. Just for routine maintenance.
13 O. And in the past two years, have you flown 13 Q. And when you and let's say when
14 those two airplanes? 14 ME and Story Cowells and flew torsau. do
15 A. Just for routine flights to keep them loose 15 you know the purpose of that trip?
16 or, you know you know what I mean. 16 A. No.
17 O. Have those two airplanes been flown by anyone 3.7 O. How long did you Way?
113 else in the last two years? 18 A. Five hours.
19 A. No. 19 O. Did you pick anybody up there?
20 O. Have those two airplanes been flown In the 20 A. No. Meaning passengers?
21 last two years for any reason other than routine 21 a Yes.
22 maintenance-type flights? 22 A. NO.
23 A. We've had one two flights I think in the 23 O. What happened? You landed the airplane and
24 past two years. 24 then what?
25 O. And what were the purposes of those flights 25 A. The passengers left. Dave and I went and had
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lunch. The passengers showed up and we came back. I to his Island? We never landed on Ns Island. We
2 0. Have you ever stayed at the home that is on 2 landed In St. Thomas.
Uttle St. James? 3 0. Got it.
A. No. 4 A. I was just trying to be exact.
5 a Have you known Jeffrey Epstein to stay at that 5 0. Thank you.
6 home? 6 A. It's a small island.
A. I don't know that fora fact. 7 0. Okay. So how is it that when Mr. Epstein
a 0. Okay. Do you believe that he is the owner or 8 wants to go to Little St. James. what is the path that
9 controller or has some interest in the home or the 9 you take to got actually to the island of Little
10 island of Utile St. James? 10 St. James?
11 MR. CRITTON: Form. 11 A. I don't understand the question.
12 THE WITNESS: I have no knowledge of that 12 0. Well, you just told me you fly the airplane to
13 being a fact. 13 St. Thomas?
14 BY MR. EDWARDS: 14 A. Right.
15 0. And you have no belief that that is a fact? 15 0. And then what?
16 A. Exactly. 16 A. Then sometimes I would go get the helicopter
17 0. When you say you've been there when he was 17 or he could also take a boat to the island. But
18 there, how many times has that occurred? 18 normally the helicopters located on St. Thomas. rd
19 A. Estimating, a hundred times. 19 fire up the helicopter, come pick him up, drop him at
20 0. Okay. 20 the Island and I come back to St. Thomas.
21 A. Trying to give an honest answer. 21 0. And when he stays on St. James. you drop Nth
22 0. Okay. And in the approximate rm not going 22 of on St. James. I suppose you're going to tell me you
23 to hold you to a hundred times• but in the approximately 23 don't know if he slays there or not?
24 hundred times — 24 A. Exactly.
25 A. Sure. 25 0. But do you stay
50 52
0. for what period of lime are we talking A. I don't. I mean .-
2 about? 2 0. Well, he either stays there or someone else
A. During what period of time? 1 picks him up in a helicopter or he swims away?
Q. Right. 4 A. Coned.
A. Let's see, when did all this happen? What, 5 0. Okay. You stay on St. Thomas?
6 2007? So eight years prior to whenever he stopped 6 A. Yes.
flying. So... 0. Okay. Is there a place that you've stayed on
8 Q. W99? 8 61. James. even
9 A. Yeah, I guess. yes. 9 A. No, rve never.
10 0. I mean, that sounds lace a right 10 0. So in the hundred or more times that you've
11 A. Sounds about right, yeah. Don't hold me to it 11 been to the island, Is it my understandng that each of
12 again. 12 those times you've been there to drop of Jeffrey
13 0. All right. 13 Epstein and'or any passengers and you've immediately
14 A. You're going beck a long way. 14 left and gone to St. Thomas?
15 0. So from approximately the 198/99 time frame 15 A. Yes, sir.
16 when Jeffrey Epstein would fly to Little St. James, 16 Q. You never been inside that home that's located
17 would you be the pilot? 17 an SL James?
18 A. Yes. Is A. Yes, I've been inside the NOM/
19 Q. Okay. And you say that you've been there — I 19 0. How many times have you been inside the home?
20 thought that you Just told me that you've been there the 20 A. I mean, ten, fifteen times.
21 same time he was there. but then I thought the 21 Q. And for what occasion?
22 subsequent question was well, were you on the flight 22 A. I've set up the theater system that's in the
23 with him, and I thought your answer was no. Maybe I 23 living room.
24 misunderstood that. 24 0. Okay.
25 A. No, you said the question "Have you ever flown 25 A. So it would be there to work to hook up a TV
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1 or a stereo. 1 Q. It seems b be I mean, you seem Ike
2 Q. And do you knew Les Wexler? 2 somebody Mite has common sense. It seems like somebody
3 A. No, I don't. 3 that knows Jenny Epstein?
4 Q. Have you ever met him before? 4 MR. CARTON: Form.
5 A. I have met him. BY MR. EDWARDS:
6 Q. Do you know of any relationship between Los 0. Correa..?
7 Wexler and Jeffrey Epstein? 7 A. Yes.
8 A. I don't know what — to what extent they have Q. All right. And do you believe that there is a
9 a relationship, no. 9 business relationship there or a personal relationship
10 Q. Do you know if they know one another? 10 there, from your observations?
11 A. I don't know that for a fact. They talk to 11 A. rd only be speculating. When they get on the
12 one another, so I would assume. But I don't know to — 12 airplane. my focus is forward and flying safety. So I
13 Q. How do you know they talk to one another? 13 don't — you know. I'd only be guessing at either one of
14 A. I've seen them speak to one another at the 14 those Iv o.
15 foot of the airplane. 15 0. Okay. Have you ever socialized wit..
16
17
Q. All right. Have you ever flown the
airplane any of the airplanes with Les Wexler as a
16
17
MR'
A. No.
18 passenger? 16 Q. Other than speaking with her on the airplane,
19 A. No. 19 have you spoken with her eisewhere?
20 Q. Have you ever flown the airplanes will 20 A. Over the phone, in passing. I mean, walking
21 Ma as a passenger? 21 down the street In New York. I mean, yes.
22 A. Yes. 22 Q. Why would you cal or why would
23 Q. And do you knottla 23 she cal you?
24 A. Yes. 24 A. She would call me to schedule the aircraft for
25 Q. And for how long have you knowrar 25 a departure.
54 56
A. I'm guessing, six years. I mean, don't hold 1 Q. And have you ever called her?
2 me to it. I'm not the greatest on length of times, but 2 A. Yes.
3 six, seven years, I think. 3 Q. When's the last time you talked W=1
4 0. Flow did you moot her? 4
Mi?
A. I guess I was introduced. She was on a Bight 5 A. A week ago.
6 of ours. 6 Q. What was the occasion?
0. You were introduced to her by whom? 7 A. We were discussing carpet for one of the
A. She may have introduced herself. I mean, 8 aircraft.
9 you're going back a ways. I don't know the official 9 Q. And where was she when you were talking with
10 introduction, how it went. 10 her?
11 Q. And to your knowledge, what is her is she 11 A. I don't know. tt was over the phone.
12 associated or affiliated in some way with Jeffrey 12 Q. Dld she call you or you call her?
13 Epstein? 13 A. No, I called her on her cell.
14 MR. CRITTON: Form. 14 Q. Okay. And that's a New York number?
15 THE WITNESS: I would assume so. I don't know 15 A. I don't know. It's on speed dial.
16 to what level or what actually her job description 16 Q. Do you have your phone with you?
17 Is. 17 A. Yes.
MI BY MR. EDWARDS: 18 O. Could you tel me what that number is?
19 Q. All right. Well, how many flights have you 19 A. SUre.
20 flown where she and Jeffrey Epstein have been passengers 20 0. Thanks.
21 together on one of the airplanes that we've been 21 A. Sure.
22 &cussing? 22 Q. WNch airplane were you discussing carpeting
23 A. I'd only bo guessing again. 23 for?
24 O. We're talking hundreds of flights, though? 24 A. Was actually -- actually. It was for the
25 A. Sure. sure, a lot of Illshts. 25 helicopter. Now that I'm thinking about ft. the
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t helicopter. 1 O. How long have you known
2 Q. In the last two years, did you tell me the 2 A. I don't know, five years. A guess again.
3 helicopter has flown? 3 four, five years.
A. Yes. 4 O. Do you know what her relationship is, if any.
5 O. And where to? 5 with Jeffrey Epstein?
6 A. I have flown the helicopter to Fort Lauderdale 6 A. I do not know.
on several occasions for maintenance. rve flown it to 7 O. Do you 'mow if she knows Jeffrey Epstein?
s Miami. And I try to fly the helicopter at least every 8 A. I would assume so. They tare_ I would
9 two weeks Just either by myself to run it up to its — 9 imagine she knows him.
10 it's Important that it keeps moving. 10 O. And how many times has she been on the
11 O. Other than maintenance-type flights, have you 11 arplane or the helicopter on flights at the same time
12 flown the helicopter in the last couple of years? 12 as a passenger with Jeffrey Epstein?
13 A. Yes. 13 A. Many. I'd have to look at the logs.
14 O. And who was on the helicopter? 14 O. Hundreds of times?
15 A. I flew to Miami with Mr. Epstein. 15 MR. CRITTON: Form.
16 0. When was that? 16 THE WITNESS: Sure.
17 A. It was a couple weeks ago or a month ago, I 17 BY MR. EDWARDS:
15 think. Ia O. If you were going to, as somebody who has been
19 O. For what? 19 Jeffrey Epstein's pilot for 18 years, tell me today who
20 A. Sony? 20 the five closest people are to Jeffrey Epstein, would
21
22
O. For what occasion? 21
22
IM be one of them?
MR. CRITTON: Form.
A. I think he had a meeting with his attorneys in
23 Miami. 23 THE WITNESS, I'd only be guessing and
24 0. Today is October the 15th. Is this during the 24 speculating. I have no idea.
25 month of October that you had this flight in the 25
58 60
1 helicopter with Mr. Epstein? 1 BY MR. EDWARDS:
2 A. I'd have to look at the book to be exact for 2 O. Okay. Well, as his pilot and the person who
3 you. 3 travels with Jeffrey Epstein on the majority of his
4 Q. Okay. But it's either the end of September or 4 flights, who are the people who travel most frequently
5 the beginning of October? 5 with Jeffrey Epstein?
6 A. Yeah. 6 A. I'd have to look at the logs.
7 O. How do you know that ho was meeting with his 7 MR. REINHART: Can we get a time period?
8 attorneys? 8 BY MR. EDWARDS:
9 A. I believe that he had mentioned that he was 9 O. In the last ten years, which people travel
10 meeting his attorneys. 10 most frequently with him?
11 Q. Did he tell you why? 11 A. I'd have to look at the flight logs to give
12 A. No. 12 you an accurate answer.
13 Q. Why did he tell you he was meeting with his 13 O. You can't give me one single name of somebody
14 attorneys? Did you ask him? 14 who you would say is a frequent flyer?
35 A. No. 15 A.
16 O. Okay. That's just something that he said to 16 O.
17 you in conversation? 17 A. Yes.
A. Yes. sir. 1e O. else?
19 Q. Was there anyone else on the airplane besides 19
20 you and Mr. Epstein? 20 O.
21 A. Yes. 21 A. Yeah.
22 O. Who was that? 22 O. Okay. Anybody else?
23 A. 23 A. Just mainly those two.
24 O. who? 24 Q. How about Ghislaine Maxwell?
25 A. 25 A. Not for some time.
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1 0. What's your understanding between the I Miami?
2 relationship of Sillslathe Maxwell and Jeffrey Epstein? 2 A. Twenty-five minutes.
3 A. I don't really know. 3 0. And did they talk to one another during that
4 0. AM right. So when lyoi say you're guessing 4 tier?
the a know or are 5 A. No.
6 associated with Jeffrey Epstein, that guess Is being 6 0. They were both completely silent during that
7 made on the with the observation that they have been 7 flight?
8 frequent flyers with Jeffrey Epstein on more than 8 A. Yes.
9 hundreds of flights on his private plane? 9 0. Okay. Is that typical when they are on
10 A. Yes, that's what I'm b • it on. 10 flights together. especially with the helicopter, whore
11 Q. And do you know whet Is 11 you're in pretty close quarters, that they would ahciain
12 staying these days? 12 from speaking to one another?
13 A. No. 13 MR. CRITTON: Form.
14 0. Do you know what car she's driving these days? 14 THE WITNESS: Yeah, it would be typical. Irs
15 A. No. I don't. 15 very noisy and communicating in a hohcopter is.
16 0. Okay. Do you know if she's Wing with 16 you know, not that comfortable.
17 Jeffrey Epstein these days? 17 BY MR. EDWARDS:
18 A. I don't know that. 18 0. Over the last five • have
19 Q. Do you 3310W howe met Jeffrey 19 known or been familiar withor• have you
20 Epstein? 30 heard her and Jeffrey Epstein conversing with one
21 A. I don't. 21 another?
22 0. Were you on an international flight bringing 22 A. I've heard them conversing, but if you ask me
23 her into the country horn some other country at any 23 what they had said, I could say it -- I wouldn't even
24 time? 24 know what they had said to each other. I've seen them
25 A. I don't know. 25 talking to each other.
62 64
MR. REINHART: Can we clarify? You mean with 1 Q. But you don't remember a single lit
Mr. Epstein or 2 conversation between Jeffrey Epstein and=
3 MR. EDWARDS: No. 3
4 BY MR. EDWARDS: 4 A. An honest answer, no.
0. Did you ever bring from some 5 0. Okay. And the same for have you
foreign country into the United States? 6 seen or have you seen Jellrey Epstein speak with
A. I'd have to look at the log books, honestly. 7 IIIIIIk
8 0. That's not something you remember? 8 A. hoe seen him speak with her, yes.
9 A. No. I mean, she I think she's been on 9 Q. Can you tell me a single specific conversation
10 Europe trips with us. and I think she's returned from 10 that ve overheard between Jeffrey Epstein and
11 Europe with us, but I could not say that hones . 11
12 0. On this recent helicopter flight with 12 A. One thing that comes to mind would be make
13 and Jeffrey Epstein, did you talk with them 13 sure we have Oreo cookies on the airplane. II would be
14 during that flight? 14 something completely nonchalant.
Is A. No. 15 0. Okay. And do you know or have
16 0. Where rid the flight go from? And obviously, 16 of any employment relationship between
17 it landed In Mlaml, but where did you leave from? 17 Jeffrey Epstein?
18 A. West Palm Beach. 16 A. I have no kno 0 of n of that.
19 0. And did= and Jeffrey Epstein arrive 19 Q. Do you know if works for Jeffrey
20 together? 20 Epstein?
21 A. You know, I don't remember. I was out at the 21 A. I do not know.
22 helicopter and I think they both started walking up. So 22 Q. Do you know it schedules massages
23 I don't know if they came separately or not. I was 23 for Jeffrey Epstein?
24 already at the heloopter. 24 A. I have no idea.
25 Q. How long is that flight from Palm Beach to 25 0. Has Jeffrey Epstein ever indicated to you that
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1 he is fascinated or infatuated or appreciates or loves women?
2 or likes massages? 2 MR. CRITTON: Form.
3 A. I have no knowledge of that. 3 THE WITNESS: No.
4 0. All right. How about ObisSeine Maxwell, has 4 BY MR. EDWARD$:
5 she ever talked to you about massage therapy or have you 5 0. You think that this is just a story that a
6 ever overheard her talking about that? 6 bunch of underage women hove made up?
7 A. No. A. Speculation.
0. You certainly read the papers over the last MR. CRITTON: Objection. Nov Ws
9 couple of years, correct? 9 argumentative. Who gives a dam what he thinks cue
10 A. Not on my top ten list. I mean. I've read a 10 way or another? If he has personal knowledge —
11 couple articles, but I'm not one to focus on that so 11 MR. EDWARDS: You're objecting to the form?
12 much as some people would. 12 MR. CRTITON: It's argumentative.
13 0. Okay. When the hI1Esiigation about Jeffrey 13 MR. EDWARDS: You're objecting to the form'
14 Epstein came about, the criminal investigation you're 14 MR. CRITTON: Yes.
15 aware that's what I'm talking about. right? 15 MR. EDWARDS: Okay.
16 A. That was last year? 16 BY MR. EDWARDS:
17 0. Welk it was a couple years ago. 17 0. Is that something that you believe that a
18 A. Right, okay. 18 bunch of women some of which know each other, some
19 O. Did you speak with Jeffrey Epstein about that 19 don't, some of which have been on the airplane and some
20 investigation? 20 which haven't -- made this up, that Jeffrey Epstein
21 A. No. 21 engaged in some sexual conduct with them?
22 O. Were you told not to speak with him about that 22 MR. CRITTON: Form.
23 investigation? 23 THE WITNESS: What I believe doesn't matter in
24 A. I think we knew ourselves that we weren't -- 24 this case, does It?
25 It wouldn't be proper to even bring it up. 25
66 68
0. All right. When you read In the newspapers 1 BY MR. EDWARDS:
2 the allegations that Mr. Epstein was involved with 2 0. I need an answer. Do you believe It? Do you
3 numerous underage girls for sexual reasons, were you 3 believe these girls made this up?
4 surprised? 4 MR. CRITTON: Form.
A. I didn't believe it. 5 MR. REINHART: I'm going to instruct him not
6 Q. Do you believe d today? 6 to answer. Move on.
A. I don't believe it. 7 MR. EDWARDS: Is there a privilege that we're
0. You don't believe that Jeffrey Epstein was 8 asserting?
9 Involved with underage girls in a sexual way? 9 MR. REINHART: No, It's irrelevant It's
10 MR. CRITTON: Form. 10 harassment and not likely to lead to discoverable
11 THE WITNESS: You're asking for my opinion, 11 evidence.
12 and I don't think my opinion Is relevant In that 12 MR. EDWARDS: I'm going to put on the record
13 matter. 13 right now that it is -- we are allowed discovery
14 BY MR. EDWARDS: 14 into a RICO count. We are also allowed discovery
15 O. I think it's relevant. Can you just tell me 15 Into the intent of Mr. Epstein in developing a
16 whether today you believe that Jeffrey Epstein has 16 criminal enterprise designed to sexually exploit
17 engaged In sex with underage girls? 17 and sexually abuse underage girls. We believe that
18 MR. CRITTON: Form; speculation. irrelevant, 18 In doing so, he associated intentionally with
19 always. 19 people of similar beliefs that sex with underage
20 THE WETNESS: Ifs Irrelevant. 20 girls Is okay, and that there have been many
21 BY MR. EDWARDS: 21 discussions with this witness, as won as many
22 Q. I need an answer. 22 other witnesses with - to insure his protection
23 A. I don't believe he had sex with underage 23 from law enforcement that they not answer these
24 women. 24 specific questions. And thus, the opinions and
25 Q. Or engaged in any swami acts with underage 25 beliefs of all of these witnesses that we are
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alleging associated with this criminal enterprise 1 A. It's an opinion, and I behave that he has
2 are certainty reasonably calculated to lead to the 2 not.
3 discovery of admissible evidence. And if you're 3 0. Okay. Isn't It true that at some point in
4 still instructing the witness, based on that 4 time you learned that Jeffrey Epstein has strike
• proffer, not to answer any of these questions, inn that.
6 going to continue to ask the questions and you can 6 MR. CRITTON: When you ultimately get to a
7 instruct him not to answer and we can go to the 7 good place to break, wit you let us know?
Court. a MR. EDWARDS: Lefs break now.
9 MR. REINHART: My response is to his opinion 9 (A break was had at 11:28 a.m.)
10 whether people making allegations in this case are so BY MR. EDWARDS:
11 Whiting or making up a story is Irrelevant to 11 0. All right. Eighteen years of being a pilot
12 what you just said. So I am going to instruct hkn 12 for Jeffrey Epstein and in terms of being able to name
13 not to answer any question that goes to his opinion 13 somebody that you would say youVe observed with Jeffrey
14 of someone else's motivation or the truth of facts 14 Epstein and would classify that person as Jeffrey
15 to which he has no knowledge. 15 Epstein's friend, can you name anybody?
16 So yes, fin instructing him not to answer. 16 A. I-' just people that we see
17 MR. CRITTON: Let me add in my part. Is that I 17 routinely on the airplane.
18 think -- you're certainly not only capable to ask 0. mars people you see routinely in the last
19 questions with regard to what his personal 19 five to ten years, right?
20 knowledge Is, and if he knows something or he has 20 A. Yes.
21 reasonable basis for it certainly you are entitled 21 0. Prior to that time, anybody that you've
22 to that Information. I think you've asked those 22 noticed as Jeffrey Epstein's friend may be Ghistaine
23 questions and he's given you straightforward 23 Maxwell?
24 answers as to what he knew or what he didn't know 24 A. What time frame?
25 under those circumstances. And as to what his 25 O. Is that a person that at some point in time
70 72
thoughts are on something which he has no factual 1 you would classify as Jeffrey Epstein's friend?
basis or even an assumption to know one way or 2 A. I would dassify it. I don't know if it's
another is irrelevant That's ultimately for a 3 true.
• fact-finder in this case. 4 O. But that's only because they were on iho
5 While it's interesting, it's argumentative and s airplane together?
• I don't think he's •-1mean, do it on a 6 A. Yes.
+ question-by-question basis. If he has knowledge. 7 0. Do you know whet Jeffrey Epstein dons for a
3 thafs great, but to argue your case with this 8 frying in your 18 years of observing and talking with
9 witness or any other witness doesn't servo a 9 Jeffrey Epstein?
10 purpose and I think is, you know — I think ifs 10 A. No.
11 not a good use of our time, Ill put it that way. 11 0. No idea?
12 But you know, you can go ahead and ask. 12 A. No.
13 MR. EDWARDS: I can ask the question and if 13 0, Ever asked him?
14 the witness is being instructed not to answer, 11 A. No, actuary.
15 wallet a judge decide whether he needs to answer 15 0. Ever boon curious?
16 the question and whether it's discoverable or not. 16 A. Sure.
17 MR. REINHART: Absolutely. Make your record. 17 0. Ever done anything to satisfy that curiosity?
10 BY MR. EDWARDS: le A. If you moan Googlo it, not realty, actually.
19 0. Do you have any reason to bebeve that Jeffrey 19 I mean. I realty have not.
20 Epstein engaged in sexual activity with underage women? 20 0. Okay. So in 18 years of traveling and being
21 A. I have no reason to believe. 21 the pilot and driving — and taking this person, Jeffrey
22 0. Okay. So as you sit here today, based on your 22 Epstein. from one property in New York to New Mexico and
23 18 years of knowledge, experience and observation of 23 Florida and around the world, you have no idea what he
24 Jeffrey Epstein, is it your belief that he has not had 24 does in terms of how he makes money?
25 sex or engaged in sexual activity with underage women? 25 A. No, sir.
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0. I was produced this flight log tell me if 1 0. But it's evident that the plane is being used,
Fin using the wrong term. What is this called, this 2 at least for this tine period. January ol 2002 through
book that I've been provided by Dave Rogers? 3 2005, on a fairly regular basis. I mean. we're looking
A. I've never seen that book. 4 at January 6th, 1tth, 130, 13th, 14th, right?
O. I'll you see it. I don't know that It was A. Uti-huh.
r. always In a book, so maybe that's why you haven't seen 6 0. I mean, Is that something that you would say
it. Tel me what we're looking at. 7 accurately reflects the amount of use of Jeffrey
A. Wee, Judging with the name at the bottom, I a Epsten's planes?
9 believe this Is Dave's flight log, log book. 9 A. Yes.
10 0. I didn't know if it was called a flight log. 10 0. So he travels quite frequently?
11 A. Pilot log book, law's that? That's the 11 A. Yes.
12 appropriate name. 12 O. And he travels with many different people.
13 0. It was marked as Composite Exhbit 1 13 4 87
14 Roasts deposition. SS Indicated by the exhibit sticker. 14 MR. CRITTON: Form.
15 Wel mark it the same in your deposition as well. 15 THE WITNESS: Yee
16 MR. CRITTON: Why don't you refer to it as 16 MR. CRITTON: Can I ask one question? I was
17 his? 17 wondering what happened, who has possession of now
18 MR. EDWARDS: Fine. 18 what's the original Exhibit No. 1 of Mr. Rogers'
19 BY MR. EDWARDS: 19 deposition? Did you retain it?
20 0. ITS the pilot log book of Dave Rogers? 20 MR. REINHART: The actual book Itself?
21 A. Yes. 21 MR. EDWARDS: The court reporter took it.
22 0. And the years provided in this book are 2002 22 right?
23 through 2005; I can represent that to you. I'm going to 23 MR. CRITTON: The one marked as an exhibit.
24 ask you about certain people that David Rogers wrote 24 did you keep that?
25 down as being on the airplane and I want to ask you if 25 MR. REINHART: This is it.
74 76
you know who they are. This person right here et 1 MR. EDWARDS: This Is it?
2 It seems hke she flew on numerous frights. Do 2 MR. CRITTON: Who took it horn the deposition
3 you know whO that is? 3 the other day?
A. No. I heard the name, but I don't know who 4 MR. EDWARDS: I have this one right now.
that is. MR. REINHART: That's the only copy?
6 Q. All right. Is that somebody that you remember 6 MR. EDWARDS: Okay.
7 seeing on any of the flights that you were on? MR. CRITTON: So you took the original?
A. What year are we talking about here? I don't 8 MR. EDWARDS: Apparently. It has the original
9 remember. 9 sticker.
to O. Well, this is January 2002. You'd probably 10 MR. CRITTON. When I say "the original,* the
11 know how to read this book a little bit better than me, 11 original copy. Would you have someone recreate
12 so I don't know. 12 what you've got and send It to us so we have It?
13 A. He keeps his a lot more current, so I know the 13 MR. EDWARDS: Sure. In fact, why don't I wait
14 name. If she walked in here right now, I would probably 14 until I get the whole thing and I'll copy all the
15 look right through her, to be honest. 15 pages and send It to you Instead of piecemeal.
16 O. Do you know what affiliation or relationship 16 MR. HOROWITZ: You mean before the transcript
17 she had with Jeffrey Epstein? 17 comes?
18 A. No. 18 MR. EDWARDS: We can copy it.
19 0. Okay. There are various — each row I'm told 19 MR. CRITTON: If you give it to me. It copy
20 by David Rogers is a different flight and it indicates 20 it and send It back to you.
21 where it takes off from and where it lands, et cetera. 21 MR. REINHART: I have a copy. It Just doesn't
22 There's a lot of other information, especially over on 22 have the exhbit sticker on.
23 this Side of the page that I'm not familiar with, nor do 23 MR. EDWARDS: That's what was told to me the
24 I need to be. 24 other day, that's why I took it.
25 A. Right. 25 MR. CRITTON: I want something — I Just don't
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want to — If you give me a copy. put a I that es, door it?
sticker on it. 2 A. NO.
MR. REINHART: Or Just copy the page that haS 3 O. Okay. Do you know what the purpose of her
the exNblt sticker on it. 4 being on the airplane tight along with Jeffrey Epstein.
MR. CRITTON: Sony. 5 GNstaine Maxwell aricillIMI would be?
BY MR. EDWARD$: 6 A. No.
0. Like On thiS flight, we have 'JE.` I'm 7 Q. Okay. Do you know how it comes about that
assuming that's Jeffrey Epstein, correct? Milleets on that flight? How does she even know
9 A. Yes, I'll assume. 9 there's a flight available?
10 Q. 'GM, Ghislaine Maxwell, right? 10 A. I don't know.
11 A. Yes. 11 0. All right. Well, let's go down to somebody
12 Q. 12 that we may all know a little bit better. Febniary
13 A. I would assume. 13 2002, there's a flight that has Bill Clinton, tour
14 0. I mean - okay. And then this name, do you 14 Secret SenAce agents and then instead of listing names
15 recognize that person? 15 or initials or anything also, ifs just listed as two
16 A. Never heard it. 16 males, one female, Jeffrey Epstein, Ghislaine Maxwe
17 0. And therm? 17 and d forget veto Dave Rogers told me ■'
18 A. Yes. 16 I. Do you remember who that is?
19 O. You've heard that name? 19 A No.
20 A. I've heard the name. 20 0. Okay. Either way, how ht It that someone like
21 0. Not sure who that is, though? 21 Bill Calton gets on a Jeffrey Epstein light?
22 A. No. 22 MR. CRITTON: Form.
23 Q. There's only one, two, throe, four, five. six 23 THE WITNESS: I don't know,
24 people on that fight? 24 BY MR. EDWARDS:
25 A. Uh-huh. 25 0. Do you know before the fight takes off that
78 80
1 0. That's pretty typical of the amount of Bill Clinton's going to be a passenger on the flight?
2 passengers that you would have on a fight? 2 A. Yes.
A. It varied, sure. 3 Q. And how do you know? How do you get that
4 0. Okay. But it varied between — If we look a 4 information?
S few lines down, Jeffrey Epstein and Ghislaine Maxwell 5 A. The day before I'd get a phone call from, say.
6 were the only two passengers. Certainly there were 6 a saying we're leaving tomorrow going to wherever,
flights like that as well, right? and sometimes she'll say who's going, sometimes she
a A. Mm-hmm. 8 wont On a case where President Clinton would be on
9 0. And so it varied from having one or two people 9 board, we would put a lithe extra catering on board or
10 to six or seven people, right? 10 do that little extra TLC to the aircraft.
11 A. Yes. 11 0. If it's leaving — this says its leaving from
12 0. What's the most people that you remember 12 MIA and where sit landing?
13 traveling on any of Jeffrey Epstein's airplanes? 13 A. HPN I believe is White Plains.
14 A. Twenty-five. 14 Q. Okay. Do you remember that flight?
15 Q. Okay. That would be a rarity, wouldn't you 15 A. I remember being on It.
16 say? 16 0. Well. I mean, if you look through here.
17 A. Oh, yeah. 17 obviously you had BA Clinton on the airplane ten or
IS 0. Because I've looked through this log. I 18 twenty times. right?
19 haven't seen any place where there were 25. but there 19 A. Yeah. He's my main focus I remember him
20 are lines that have maybe eight or nine people listed. 20 being on the aircraft, sure.
21 A. Right. 21 0. Do you remember him being on the airplane with
22 0. Let's see. There's a fright from 22 younger girls?
23 January 15th sorry, January 17th, January 20th and 23 MR. CRITTON: Form.
24 January 22nd of 2002 that all That 24 THE WITNESS: No.
25 defiant serve to refresh your recollection as to who 25
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1 BY MR. EDWARDS: 1 this time with Doug Band, three Secret ,
2 O. Okay. Do you know what his relationship was 2 Jeffrey Epstein, Ghislaine Maxwell Do
3 with Jeffrey Epstein? 3 you remember that flight?
4 A. No. 4 A. Where did we go?
5 O. Do you know if they were friends? 5 0. Starts In JFK.
6 A. Assuming. 6 A. Flight.
7 O. But you're assuming why? Just because he's on O. Where is that?
8 his plane? 8 MR. CARTON: Do you have a date?
9 A. Yeah. 9 MR. EDWARDS: March 18th. 2002.
10 O. Okay. So you assume that the people that are 10 THE WITNESS: EGGW I believe is Luton,
11 listed on here are friends of Jeffrey Epsten's and 11 England.
12 that's why they are riding on his plane? 12 BY MR. EDWARDS:
13 A. I'm speculating. 13 0. Okay. Do you remember flying to England?
14 0. I'm Just not familiar with the -- because rye 14 A. I do remember flying to England. I just don't
15 never been on a private flight with the manner in 15 remember that trip. What airplane were we In? We were
16 which you go about getting on one of these flights. I 16 in the Boeing.
17 mean, you have to, I guess, know that Jeffrey Epstein 17 O. Do you remember the purpose of the trip?
18 has a plane, that it's going from a destination that you 18 A. No.
19 are at and want to go to, and that it's avelable and 19 O. Do you know who Doug Band is?
20 those kind of things. Can you tell me, enlighten me -- 20 A. I heard he's Clinton's, how would you say,
21 A. Weil, it's not publicly offered, no. it would 21 assistant. I mean, I've seen that in the newspaper.
22 be no different than you limping In your car and knowing 22 seen a on CNN.
23 you're going to the mall. I moan, It's not public 23 O. Okay. Did you ever hoar that Doug Band and
24 information, you know, where planes are coming to and 24 Ghlslane Maxwell were together. even for a day or a
25 from, and you don't put your name out there to get 25 night?
82 84
onboard a flight. 1 A. No.
0. Does Jeffrey Epstein charge these people as 2 a Did you ever hear that Doug Band and Ghislaine
3 passengers? 3 Maxwell were the people attributed to introducing ea
4 A. I don't know. 4 Clinton and Jeffrey Epstein?
O. Okay. Are these people such as Bill Clinton. 5 MR. CRITTON: Form.
6 does that mean that &a Clinton called or 6 THE WITNESS: I don't know.
somebody affiliated with Jeffrey Epstein to get on the 7 BY MR. EDWARDS:
8 plane or that Jeffrey Epstein called Bill Clinton and O. All right. There's another flight here on
9 asked do you want a ride? 9 January I can/ read this upside down. Maybe it says
c MR. CRITTON: Form; predicate. 10 May —
11 THE WITNESS: I have no idea. 11 A. Looks like.
12 BY MR. EDWARDS: 12 0. -. 22nd, 2002 Again, with President BS
13 O. No idea? 13 Clin . Can you tell me who
14 A. No idea whatsoever. 14 and are?
15 O. Joe Pagano, do you know who that is? 15 A. I don't remember.
16 A. Yes. 16 0. Would you know them if you saw them?
17 O. What's his relationship with Jeffrey Epstein, 17 A. Probably not because the names don't even ring
18 or what was it back in Febnia sorry, March 17th of 18 a boll.
19 2002, when he and and Jeffrey Epstein and 19 O. All right. And then there are plenty of
20 Todd and one female were on this flight? 20 flights. many of eights vA 1 Epstein,
21 A. I don't know to what extent or what his 21 Ghlslaine Maxwell and are the primary
22 relationship is. He Just was a passenger on the 22 passengers. or at least are some of the passengers on
23 airplane. 23 the flights, correct?
24 0. Okay. And the next day sorry, two days 24 A. Mrn-timm. yes.
25 later on the 19th of March, Bill Clinton flies again, 25 0. And still, as you sit here, you being the
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1 pilot of these flights, you're not sure what their 1 we're referring to the same flight on June 21st of 2002,
2 relationship is or whether any of them were socially 2 that includes Jean Luc Brunel, Jeffrey
3 connected in any real way? 3 Epstein. Chelan° MeueveliMillit, Mose are the
4 MR. CRITTON: Form. 4 passengers of the flight, does that serve to jog your
5 THE WITNESS: No. When you're flying the 5 memory as to wt as is?
6 airplane, there's a lot more going on than A. No. I mean, you see how frequently wo fly. I
7 passengers' relations. 7 mean. it's the passengers in the back are so far
8 BY MR. EDWARDS: 8 removed from an operation of commanding an airplane like
9 O. All right. You remember this person.l. 9 that, Its nothing that sticks 11 your head.
10 OM are you familiar with her at all? 10 O. And you as the pilot, is there any way that
11 A. I remember the name, that's it. 11 you would know what's going on In the back of the
12 O. What do you think her relationship is to 12 airplane?
13 Jeffrey Epstein? 13 AL No. My concerns are all on the optical!.
14 A. No idea. 14 MR. CRITTON: Brad, the last one that you
15 MR. CARTON: What date are you on. Brad? mentioned, was that the same date. June 21st. '02?
16 MR. EDWARDS: Oh, sorry. I am at June 21st, 16 MR. EDWARDS: Yes.
17 2002. 17 BY MR. EDWARDS:
18 BY MR. EDWARDS: 18 O. There's another name here that I was going to
19 Q. Tilers not somebody that you specifically 19 ask you do you know. June 23rd. 2002.
20 remember? 20 are you familiar with that name?
21 A. Mm-mm, no. 21 A. No.
22 Q. No? Is that somebody that you think was a 22 O. Also on the same flight with Jean Luc Brunel.
23 regular flyer for any period of time in Jeffrey 23 That doesn't help to jog your memory either, right?
24 Epstein's life? 24 A. No.
25 A. Not a regular. 25 O. That's somebody that you remember as a
86 88
O. Okay. Jean Luc Brunel, is that a name that 1 frequent passenger?
2 you know? 2 A. Who are you referring to?
3 A. Yes. 3 O. =NM ?
4 O. Now do you know that name? 4 A. No.
5 A Orly because it's a unique name and his attire Q. Dr...larecki, is that somebody that you
6 79 very unique. So you remember certain things. So I remember frying?
7 know he who that Is. 7 A. I know the name. He may have been on the
8 Q. Do you know what he does? 8 airplane once or twice. I'm guessing only.
9 A. No. 9 Q. Do you remember meeting him?
10 O. Do you know his association with Jeffrey 10 A. Yes. I have met him.
11 Epstein, if any? 11 O. Do you remember his purpose for being on the
17 A. No, I don't know what the relationship Is. 12 airplane?
13 O. Nave you ever heard of him owning or running 13 A. No, Sir.
14 or managing a modeling company? 14 O. Amanda Venaro, do you remember her purpose tot
15 A. I have seen that in the paper a taw years 15 being on the airplane?
16 back. 16 A. No.
17 O. Okay. Other than seeing it in the Pats, have 17 MR. REINHART: Can we get a date?
18 you ever talked to Jean Luc Brunel or Jeffrey Epstein 18 MR. EDWARDS: I was asking him if he
19 about owning or running or managng a modeling company? 19 remembered Amanda Venom. I wasn't referring to a
20 A. No. 20 specific night.
21 O. Do you know if Jeffrey Epstein's affiliated 21 BY MR. EDWARDS:
22 with the modeling company that's owned. run or managed 22 O. You dent remember her being on the flight?
23 by Jean Luc Brunel? 23 A. I don't remember the name.
24 A. No, I have no idea. 24 O. Me showing you the flight isn't going to jog
25 a And seeing that this is a flight now, that 25 the memory?
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A. No. The name that would launch it first 1 see her name, that doesn't change your opinion as to
2 MR. CRITTON: Could I ask you a question? You 2 whether or not you remember her or what --
3 have the original exhibit marked at the deposition. 3 A. I remember the name, you know, that's all.
It looks like it's been highlighted. 4 0. Do you remember about what age she was when
MR. EDWARDS: I highlighted it. 5 the was flying on the airplane?
6 MR. CRITTON: Oh. okay. So you've highlighted 6 A. No.
7 the original exhibit that's marked for the 7 0. This could be somebody who is 50 years old or
a deposition? I just want the record to reflect ten years old, for all you know?
9 that. MR. CRITTON: Form.
10 MR. EDWARDS: Yeah. 10 THE WITNESS: Yes.
11 MR. CRITTON: Okay. Thank you. 11 BY MR. EDWARDS:
12 MR. EDWARDS: At the time I highlighted It I 12 0. Okay.
13 didn't realize I was holcing on to the original 13 A. I mean, I would only be guessing at an age.
14 exhibit. I didn't realize that until you just 14 Q. Yeah, but I mean• you don't remember her at
15 pointed that out. 15 all. So you don't --
16 MR. CRITTON: I've noticed that. 16 A. I remember the name, exactly.
17 MR. EDWARDS: So now when I give it to you, 17 0. Other than the name?
18 I'm giving you my work product as wet. I don't 18 A. Right. yes, sir.
19 see how this works against you, but anyway. 19 0. But you can't even come close to putting a
30 BY MR. EDWARDS: 30 face with that name?
21 0. Melissa Stall. is that a name that you 21 A. I mean, no. I mean, it you said draw her
22 remember? 22 picture with I couldn't come close to even getting
23 A. No. 23 s.
24 0. Okay. And then Jean Luc Brunel is Somebody 24 Q. Okay. You remember this flight where
25 who I noticed flew relatively frequently, so is that why 25 President Clinton, Kevin Spacey and Chris Tucker,
90 92
1 you -- that name jogs your memory a little better than 1 Jeffrey Epstein. Ghislaine Maxwell?
2 some of these other people? 2 A. Yes.
A. He dresses uniquely. 3 Q. From JFK to what is this, LPAZ?
4 0. In what way? 4 A. LPAZ, that Is
A. Just loud clothes, so something that you would 5 0. South Attica or something?
6 remember, that's all. 6 A. No, it's the Azores Islands, Santa Maria.
7 0. Do you know his role in Jeffrey's ide? 7 0. Do you know the purpose of that trip?
8 A. No. a A. That was a fuel stop.
9 Q. Ever heard that he is affiliated with Jeffrey 9 0. Okay. And do you know why Chris Tucker and
10 Epstein because they both have a sexual attraction to 10 Kevin Spacey were on that airplane?
11 underage girls? 11 A. No.
12 MR. CRITTON: Form. 12 0. Did you talk to them?
13 THE WITNESS: You're making an assumption on 13 A. They came up in the cockpit and said hello.
14 that_ 14 So they conversed, nothing more.
15 BY MR. EDWARDS: 15 0. Another name that is on here a few times, I'm
16 Q. Have you ever heard that? 16 specifically referring right now to the dates of
17 MR. REINHART: He's asked you if you ever 17 September 23rd and 24th of 2002, is Ron liturkle. Do you
18 heard that. 18 know who that Is Ron Buride?
19 BY MR. EDWARDS: 19 A. I know what that is, yes. I didn't realize he
20 0. It your answer is no, It's no. 20 was on our airplane.
21 A. I'm sorry, I thought you said they did. No. I 21 0. Right now that is the first time that you
22 have not. 22 remember Ron Burkle being on your airplane?
23 0. Okay. I keep highighting this name, 23 A. Yeah.
24 MB just because it looks like somebody that's 24 0. You don't know the purpose fix him being on
25 regularly flying on the airplane. But Me more that you 25 that airplane?
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A. No. Granted, I'M seeing this for the first 1 BY MR. EDWARDS:
2. time, so I'm trying to — 2 0. Okay. You don't remember which tights it
0. Let me ask you that. Because this was given 3 would have been where there would have been girls under
to me at a deposition of Dave Rogers. who I understand 4 the age of 18?
5 was the chief pilot for Mr. Epstein. and now y0ute the MR. CRITTON:
cheap pilot. but you always kind of worked in tandem, 6 THE WITNESS: Wel, I would have to look at
7 correct? 7 the fright logs.
A. Sure; we complemented each other. 8 BY MR. EDWARDS:
9 0. And you both worked for the same company that 0. Irs not illegal to have somebody under the
10 fries Jeffrey Epstein's airplanes, right? 10 age of 18 on a flight anyway, right?
11 A. Yes. 11 A. No, not at all.
12 0. So I was of the presumption, which may have 12 0. Were you ever aware that you, as plot, wore
13 been - I may have been misled here, or I may have, you 13 transporthig girls under the age of 18 who were supposed
14 know, misunderstood the purpose behind this book or how 14 to be models?
15 it was created. I thought that you had probably seen 15 MR. CRITTON: Form.
16 this before at some point in time? 16 THE WITNESS: I had no knowledge.
17 A. Oh, no. 17 BY MR. EDWARDS:
18 0. Dld you know that Dave Rogers was keeping this 18 0. Okay. You never knew who the people on th,_
19 book? 19 airplane were, what their purpose was, their role with
20 A. No. I know he keeps a Piet log book. 20 Jeffrey Epstein or Jean Luc Brunel?
21 0. Okay. But you didn't know he was keeping the 21 A. No.
22 names of the people who were on the airplane? 22 Q. All right. Do you knot I?
23 A. No. Its not required. so I mean, it's.. 23 A. No, I dont remember that name.
24 0. So today is the first time that you are 24 Q.
25 teaming that the names of the people that we on the 25 A. I remember the name.
94 96
1 airplane was kept by Dave Rogers? 1 0. She flew frequently at least for a period of
A. Yes, in his log book. 2 lime. Do you remember that?
0. Okay. And it's my understanding when you fly 3 A. Yes.
4 back into the country through Customs. you have to 4 0. Is that somebody that you thought was familiar
report the people that are on the airplane, right? 5 with the modeling industry or related to the modeling
A. Yes. 6 industry?
0. And who would create that document or call 7 A. No.
a that information into Customs? 0. Okay. And these people, did Jeffrey Epstein
A. Whoever the captain was for the day. 9 ever tell you how he was associated with any of them?
0. At times would that be you? 10 A. No.
11 A. Yes. 11 0. Did you ever wonder how he was associated with
12 0. Okay. And at times when you would come into 12 any of thorn?
13 the country with passengers — well, not at times. 13 A. No. never interested.
14 Didn't you else have to report their date of birth? 14 Q. And on several of these on most of these,
15 A. Sure. 15 the names or Initials of the people that are on the
16 0. At tines weren't there also people that you 16 flight are listed. Do you know on the occasions where
17 would bring in from other countries into the United 17 it lists generically two females or three females or six
18 States that were under the age of 18? 18 females, do you know why that was done?
19 A. Yes. 19 A. Just because we didn't know our the
20 0. And at some times those were flights that 20 person's name. We hied to do the best we could to keep
21 Included Jean Luc Brunel and girls that were under the 21 the records.
22 age 0118, right? 22 0. When you say 'we tried to do the best that we
23 MR. CRITTON: Form. 23 could
24 THE WITNESS: I don't remember those flights. 24 A. Dave and I.
25 25 0. Okay. But the first time that you learned
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1 that he kept anybody's names was today, right? 1 at the airport office that I had turned Into
2 A. Well, I didn't know he kept them in his log 2 counsel that has the passenger names on them.
book. We would fill out the passenger manifest as 3 BY MR. EDWARDS:
4 we're — having passengers' names in your pilot log 4 0. Okay.
5 book, he's probably the only person in the world that • A. It's called a passenger manifest.
6 does that. 6 0. Okay.
0. Okay. 7 MR. REINHART: Right.
8 A. So when you were mentioning putting the names • BY MR. EDWARD$:
9 down, when you said female or mate, you know, I was 9 0. The passenger manifest, just so I understand
10 referring to the passenger manifest. 10 exactly what that is. ten me. Tell me in your own
11 0. For each of these same flights, then, that 11 words.
12 we're referring to out of this log book that was marked 12 A. It's departure time, the city, the landing
13 as Composite Exhibit 1 in Dave Rogers' deposition, am I 13 time exactly and the passengers that would have been on
14 understanding you correctly, then, there would also be a 14 that flight.
15 passenger manifest for each of these flights? 25 0. And at times on that passenger manliest would
16 A. Yes. 16 you IS also generically female or male?
17 0. Now, where would I find the passenger 17 A. Yes. That was the document I was referring to
18 manifest? Who keeps that documentation? 18 staling that if we didn't know a person, we did not go
19 A. Corporate -- our corporate office. 19 out of our way to find out a name. We just put in to
20 Q. Which is whom? 20 account for how many people were on the aircraft at that
21 A. Up in New York, Darren Indyke. 21 time.
22 0. At what corporation is that, though? 22 0. Who is currently in the custody or control --
23 A. NES, LW. I guess. 23 sorry. Who currently maintains or has possession of the
24 MR. REINHART; Do you know for sure? 24 passenger manifest from 1998 through the present,
25 THE WITNESS: I don't know for sure. I moan, 25 through today for those airplanes that you flew related
98 100
1 when you say -- we would just send them up to New 1 to Jeffrey Epstein?
2 York. 2 A. I currently have, which counsel has now. 2005,
3 BY MR. EDWARDS: 3 I believe, until the present time. And the records
• Q. Did you ever keep a copy of them? 4 previous to that I believe were turned into counsel with
A. No. 5 the previous investigation with Jack Goldbergers
6 0. Why did you keep a passenger manifest? 6 office, I believe. I believe they maintain those
7 A. Just for tracking of to have the times on 7 records,
s there for -- 8 Q. When you Say "turned into counsel." there are
9 MR. REINHART: Can I confer with him on one 9 a lot of counsel involved here.
10 thing before you ask a question? to A. Jack Goldberger's office. I believe.
11 MR. EDWARDS: Yeah, yeah. 11 0. When you say "the previous investigation,'
12 (Off the record discussion.) 12 you're talking about the criminal investigation?
13 MR. REINHART: Mr. Edwards. let him amend his 13 A. Exactly, yes, sir.
14 prior answer. I think he misunderstood the 14 0. And you're aware in that criminal
15 question is investigation, obviously, that Jeffrey Epstein pled
16 MR. EDWARDS: I don't know what question we're 16 guilty to certain charges, correct?
17 amounting the answer to. 17 A. From what I read. yes.
10 MR. REINHART. Lot me clarity this way: As 18 O. Well, you did visit him In jail, right?
19 the passenger manifests, they are corporate 19 A. Yes. We didn't talk about that.
20 documents of either JEGE or Hyperion Air, whatever 20 0. Okay. You knew In order to go to jail.
21 company owns the plane. Mr. Visoski has physical 21 though, you have to be convicted of some crime, right?
22 custody of them. He retains them but they're not 22 MR. CRITTON: Form; argumentative.
23 his documents. They're the corporate documents. 23 THE WITNESS: Yes.
24 So they're not in New York. 24 BY MR. EDWARDS:
25 THE WITNESS: Those are the ones that I have 25 Q. It wasn't ►ke he was visiting the Jail and
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1 you were visiting and you happened to bump into each Q. And for the passenger manifest prior to 2005.
2 other. You actually went to see him while he was an 2 how far do those passenger manifests go back In time?
3 inmate In Jail? 3 A. They should go back. I guess. to 1991 or
4 A. Right, yes. 4 whenever we started existence.
O. Okay. So when were talking about the 5 Q. And did you turn them over from 1991 all the
6 criminal investigation, were talking about the criminal 6 way through to 2O05?
7 investigation revolving around the allegations of 7 A. I deal know. I didn't tum them in. Dave
8 Jeffrey Epstein engaging in sex acts with minors? 8 Rogers did.
9 MR. CRITTON: Form. 9 O. Are you in possession of a copy of any of
10 BY MR. EDWARDS: 10 those materials?
11 O. That's the criminal investigation you're 11 A. No.
12 talking about, right? 12 O. I thought that, you know, ten minutes ago when
13 MR. CRITTON: Form. 13 we were taking about this you said you had them back at
14 THE WITNESS: I don't know the full definition 14 an once or -•
15 of really what happened there. I know that it was 15 A. That was the office, the airplane office.
16 something to do with solicitation of prostitution. 16 which I've given to Bruce, which is the current log. He
17 That's al I road. 17 is in possession of them now. I had possession of them.
18 BY MR. EDWARDS: 18 O. Okay. What he's in possession of --just so I
19 O. Okay. Were you aware that the allegations 19 know what documents are where, he's in possession of the
20 revolved around underage girls or gins under the ago of 20 passenger manifests from 2005 through the present?
21 18? 21 A. Correct.
22 MR. CRITTON: Form. 22 Q. It I want to obtain the passenger manifests
23 THE WITNESS: I was aware it revolved around 23 from 1998 through 2005. Mars something that 1 woulc
24 it, yes, 24 request from whom?
25 25 THE WITNESS: Help me out. That's --
1 02 104
I BY MR. EDWARDS: I MR. REINHART: If you know.
O. Who first made you aware of that? 2 THE WITNESS: I don't know who possesses them
A. The newspaper. 3 right now. They were turned into Jack Goldberger's
O. Wore you ever questioned by the police? 4 office a year and a half or two years ago.
A. I don't know who questioned me, actualy. I BY MR. EDWARDS:
6 did have a questioning session, but I don't even 6 Q. You started out by indicating that you sent
7 remember who questioned me. 7 these passenger mardests, or a copy thereof, to Darren
8 O. Where did that take place? 8 Indyke or someone at NES. LLC; is that correct?
A. I don't remember. 9 A. Correct.
10 O. At your house? 10 O. If I requested them from NES, LLC, that's
11 A. No. I'm thinking it was Jack Goldberger's 11 somebody at some point in time was in possession of all
12 office, or n may have been downtown al the Pen Beach 12 the passenger manifests?
13 County Courthouse or something in that area there. 13 A. Sure.
14 O. Okay. So it either happened at an attorneys 14 O. And NES, LLCS address is the one you gave me
15 office that represented -- 15 a
.
16 A. Exactly, yeah, I think so. 16 A. I believe so. I don't know what address
17 O. — Jeffrey Epstein or the other side? 17 they're using for that. I know that --
18 A. Yeah. 18 O. But Darren Indyke's the attorney that I would
19 Q. And during that questioning, is that when you 19 call —
20 turned over the passenger manifest from prior to 2006? 20 A. Yes, sir.
21 A. Yes. 21 O. - and he could probably steer me m the right
22 O. And you turned those manifests directly over 22 clrection?
23 to Jack Goldberger? 23 A. Yes.
24 A. Yes. Actually. I bees Dave Rogers did 24 MR. CRITTON: Form.
25 that. I wasn't in possession of those records. 25
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BY MR. EDWARDS: 1 hello.
0. Do you know Amy Taylor? 2 Q. That's somebody who was on the airplane
A. Yes. 3 multiple times?
4 a How do you know her? 4 A. More than once. I mean. I have no account for
A. She was on the airplane. 5 how many times.
0. How old is she? 6 0. Well, I've asked you about a bunch of names,
A. I have no idea. 7 most of which you don't really remember. but that's one
0. Age range? 8 name you do remember.
9 A. Twenly-eight. 9 A. Yeah, I remember the name, yeah.
10 0. NoW? 10 0. Okay. And that's somebody who you actually --
11 A. Yeah, 28, or maybe if not older now. She was 11 you would remember the face too?
12 probably 28 probably. I guess. She was somebody in her 12 A. I might remember Amy's face.
13 late 20s. 13 Q. A8 right. Do you remember why she would have
14 0. So we're talking about 2003? There what I'm 14 ever been on your airplane?
15 trying to understand. 15 A. No idea.
16 A. I'm guessing. 16 Q. President Andres Postrana, at the time I guess
17 0. We're talking 2009 now. We're saying 28. By 17 That was the president of Colombia back m February
18 that do you mean in 2003 she was 23 or 24 years old? 18 sorry, March 200 of 2003. Do you know who that is?
19 A. You're having me guess on her age. 19 A. I don't remember him being on the airplane,
20 Q. Yeah. 20 but I know who that Is.
21 A. I mean. I can't be accurate. 21 0. Okay. He's on the airplane with Jeffrey
22 0. Somebody between 18 and 25? 22 Epstein, Ghislaine Maxwell, IMMIand Jean Luc
23 MR. CRITTON: Fonn. 23 Brunel?
24 BY MR. EDWARDS: 24 A. Where hid we go?
25 0. At the erne you were seeing her back in •- 25 Q. Fillet you look at it. I'm talking about
106 108
A. II you want me to guess •- 1 this line, PSI, left out of Palm Beach?
0. No. I don't want you to guess. 2 A. Palm Beach to Nassau. I'm sorry. I don't
A. I don't 'mow then. 3 remember Mat one.
0. Wet. if I say between ten and fifty? 4 0. When we're saying we're going down to Nassau,
A. That's a range. 5 is that a place that you frequently went to with the
Q. If I say between ten and fifty, you're not 6 airplane?
7 guessing there anymore. You know she's in there, right? 7 A. No, not at all.
a A. She's in the middle there, yeah. 8 0. And is that a route that you would take for
9 0. Okay. How can we narrow that down? We're 9 the ultimate destination to be Little St. James?
10 talking about somebody in her 20s? 10 A. No.
11 A. In her 20s. 11 Q. If the ultimate destination was Little
12 0. At least that's what you believed? 12 St. James show me a flight where the ultimate
13 A. Yes. 13 destination was Little St. James.
14 Q. All right. Is that somebody that you know to 14 A. Yeah, right here. TIST, Mat's St. Thomas.
15 be associated or friendly with Ghislaine Maxwell? 15 Q. Okay. So on that flight that you just pointed
16 A. I don't know. 16 to, March 27th, 2003, we have Jeffrey Epstein, ME
17 Q. Do you know what her relationship was to 17 MI --again, Brent Tyndall - do you k^oti,
18 Jeffrey Epstein or Ghislaine Maxwelr? 18 who Brent Tyndall Is?
19 A. No. 19 A. Yes.
20 0. Do you know where she is now? 20 0. And who is that?
21 A. No idea. 21 A. I believe he was the chef.
22 Q. When's the last time you talked to her? 22 0. And (phonetic), is that
23 A I don't know. What date do you have on there? 23 somebody you know to be a model these days?
24 0. February 2003. 24 A. I have no idea.
25 A. So, probably that long ago. I may have sald 25 0. Do you remember that flight?
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109 111
1 A. No. 1 film wound Jeffrey Epstein?
2 Q. Do you remember Naomi Campbell, picking her up 2 A. No.
3 from St. Thomas along with Jean Luc Brunel? 3 0. All right.
4 A. I remember her being on board. I don't 4 A. No.
5 remember the flight. 5 Q. do you know that name?
6 0. Do you know Joel Pashcow? 6 A. No.
7 A. Yes. 7 Q. She was on several flights. You don't
8 0. How do you know him? remember seeing her?
9 A. He was on the airplane. 9 A. No.
10 0. And is that somebody you knew at one point in 10 0. All right. And how about Alan DershmWtz, I'm
11 time to be a friend of Jeffrey Epstein's? 11 sure you know wto that is?
12 A. He was on the airplane. I don't know what the 12 A. Sure. He's famous.
13 relationship was. 13 0. What was your understanding of Alan
14 0. Do you know what the relationship Is today? 14 Dershowites relationship with Jeffrey Epstein?
15 A. No idea. 15 A. Never talked about A.
16 Q. How about Todd Mister, do you know what that 16 0. Forrest Sawyer. do you know why he was on your
17 relationship Is or was today? 17 airplane?
18 A. No. 18 A. Never heard the name, actually.
19 Q. Do you remember him? 19 0. Really?
20 A. No. 20 A. No.
21 Q. Not at all? 21 0. Larry Summers?
22 A. I mean, I know the name. I don't know. 22 A. I know the name. I don't remember flying him
23 0. Paula Epstein, do you know who that is? 23 0. Have you ever talked to Joe Fontanela?
24 A. Yes. 24 A. Yes.
25 0. Who Is that? 25 0. How do you know him?
110 112
1 A. That's Jeffreys morn. 1 A. He usually drops Jeffrey off at the airport.
2 0. She's passed away? 2 0. In fact, you've called him directly before,
3 A. Yes. 3 right?
4 0. At least that's your understanding, right? 4 A. Yes.
5 A. That's what I heard, yes. 5 0. You still have his number?
6 0. Oka . do you know her? 6 A. I haven't — yes. I think I still got it in my
7 A. , I know the name. 7 memory.
8 O. Somebody who flew on the airplane with some 8 Q. Okay. What is it?
9 regularity? 9 A. It's been a few years.
10 A. Yes. 10 kind of an easy one.
11 0. And do u know her to be friends of Ghislaine 11 MR. CRITTON: 917 is the first --
12 Maxwell or or Jeffrey Epstein? 12 THE WITNESS: Yes.
13 MR. CRITTON: Form. 13 MR. CRITTON: Who was this for?
14 THE WITNESS: I have no idea who she was 14 MR. REINHART: Joe, Joe Fontanela.
15 friends with. 15 MR. EDWARDS: Fontanela.
16 BY MR. EDWARDS: 16 BY MR. EDWARDS:
17 Q. All right. Do you know what rote she ever 17 Q. Do you know his address, where he resides?
18 played, if she played one, In Jeffrey Epstein's life? 18 A. No, I don't.
19 A. No. 19 0. Do you know if he — what his role is in
20 O. All right. Glenn Dubin, are you familiar with 20 Jeffrey Epstein's life?
21 Mm? 21 A. Not really. He just •. ho drove the car.
22 A. Yes. 22 Q. He drove what car?
23 0. How do you know Glenn Dubin? 23 A. The car up In Now York.
24 A. I met him on the airplane. 24 Q. Okay. Do you know if he's a housekeeper up at
25 Q. Outside of the airplane, have you ever seen 25 that house up in New VOW?
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113 115
A. I don't know what his role Is. 1 O. Do you know did you tell me, do you knov
Q. Have you ever worked fora company caked Air 2 what Leslie Gruff does for Jeffrey Epstein?
3 Ghislalne? Do you know that company? 3 A. I don't know her exact tine.
A. Yes. 4 O. You talked to all of these individuals at some
5 Q. Do you know what that company does? 5 point in time, either on the phone or in person, right?
A. No. 6 A. Yes.
Q. Have you ever been an employee of that 7 Q. And you don't 'mow whether they playa role in
company? 8 Jeffrey Epstein's life, or if they do, what they do?
9 A. No. 9 A. Exactly.
10 Q. Do you know who runs that company? 10 Q. And how do you decide who you're going to call
11 A. No. 11 for what reason?
12 O. IS Jeffrey Epstein associated with that 12 A. For example? Can you be more specific?
13 COmpany? 13 O. If you're going to make a telephone call and
14 A. I don't know. 14 you're going to talk to let's say Leslie Gruff, why
15 O. How have you heard of that company? 15 would you choose to call her?
16 A. It's the company name that our registration 16 A. I don't know. You're having me make the phone
17 for the helicopters is under, Air Ghislatne. 17 call. I don't know why I would call her.
18 O. Is that somebody who's ever paid you, a 18 O. Have you ever called her?
19 company who's ever paid you? 19 A. I think, yes, I've called her, sure.
20 A. No. 20 O. Why? What would be the reason that you would
21 O. Do you know Igor Zinoviev? 21 call her? Somebody told you to call her? Here. Carl
22 A. Yes. 22 this number?
23 O. How do you know him? 23 A. I may have called her maybe to find out if w,.
24 A. Met him on the airplane. 24 had a departure time for any specific trip. I mean,
25 O. What is your understanding of his allikelion 25 that would be...
114 116
1 with Jeffrey Epstein? 1 O. Okay. So you're calling her related to
2 A. I don't know. He doesn't talk much. 2 Jeffrey Epstein?
3 O. Okay. And Sandy Berger, do you know who that 3 A. Sum.
4 le? 4 O. Okay. So you know that she plays some role in
5 A. I don't know. some aspect of Jeffrey Epstein's life, whatever that is?
6 O. Do you know any reason why you would have 6 A. Right.
trim him on the airplane? 7 O. Okay. So when I'm asking these questions
$ A. I don't even know the name. about those people, and I feel like I'm getting answers
9 O. 9 that I'm not *fly not sure that these people have any
10 A. I know the name 10 role in their life, that's not that's not completely
11 O. Somebody who flew on the plane pretty 11 accurate, right?
12 regularly? 12 MR. CRITTON: Form; argumentative.
13 A. I would have to look at the logs. I think 13 BY MR. EDWARDS:
19 we've had that name on several -- it's a common first 14 Q. I mean, you do know that these people are
15 name. I'm not familiar really on who that is. 15 somehow Involved with him, whether socially or
16 Q. What about Bella, do you know who Bella is? 16 business-wise or otherwise, and during the course of
37 Is that a name you ever heard? 17 your years, you've made telephone calls on his behalf or
18 A. Yes. 15 to coordinate things with them right?
19 Q. Works up in the New York office or something? 19 A. Right.
20 A. Yes. 20 MR. CRITTON: Object to the form. You said
21 O. Have you ever spoken with Bella personally? 21 'these people."
22 A. Yes. 22 BY MR. EDWARDS:
23 O. Do you know what she does for Jeffrey Epstein, 21 O. I'm talking about That's
24 N anything? 24 somebody you called before, right?
25 A. I don't know exactly what her role is. 25 A Sure.
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117 119
O. What would be a reason you called 1 BY MR. EDWARDS:
2 2 0. Do you remember making that phone call after
3 MR. CRITTON: Object to form. Probably the 3 reading the message?
• same reasons he said two hours ago, for scheduling 4 A. Let me look al the date here. Okay. March.
5 purposes. But you've covered that. Go ahead and 5 MR. REINHART: The question is, do you
• answer it again. 6 remember making the call?
• THE WITNESS: For scheduling purposes, would 7 THE WITNESS: Okay, let me. "Person for the
8 be my only reason to call her. 8 car will be here in 15 minutes to drop off foam and
9 BY MR. EDWARDS: 9 Panora.' I don't know.
10 0. That's funny that you used the exact same 10 BY MR. EDWARDS:
11 words that Mr. Clifton wants you to use. 11 0. That doesn't mean anything to you?
12 MR. CRITTON: It's what he said two hours ago. 12 A. That doesn't — I mean, you're talking four
13 BY MR. EDWARDS: 13 years ago. I can't answer that accurately. I mean...
14 O. What would be the reason why you would call 14 MR. REINHART: So the answer is you don't
15 Ms. Maxwell, Ghislaine Maxwell? 15 recall?
16 A. Same reason. 16 THE WITNESS: Yeah, I don't recall
17 0. That's not somebody you call these days, 17 BY MR. EDWARDS:
18 though, right? 18 O. If you don't remember, that's fine.
19 A. I haven't seen her in some time. 19 (Plaintiffs Exhibit Nos. 2 AND 3 were marked
20 0. What made you stop calling Ghislaine Maxwell 20 kw Identification.)
21 where you thought at one point in time you thought she 21 BY MR. EDWARDS:
22 was a person to call related to your job? 22 0. So Ill show you Exhibit 3, the same type of
23 A. Just was no reason to. 23 document, and I can make the representation that It
24 0. Is that somebody who you think is still 24 was message pads provided by the state attorney's office
25 affiliated or associated with Jeffrey Epstein or -- 25 relative to the criminal investigation revolving around
118 120
whatever he does? 1 Jeffrey Epstein. So that's how I have these documents.
A. I'd only can speculating. I don't know. 2 I'm not trying to pull out old documents.
C All nit. Do you know the number 3 MR. CRITTON: What's the date?
4 MR. EDWARDS: March 19th.
MR. CRITTON: Could it slowly. E tt 5 MR. REINHART: The question is, do you
MR. EDWARDS: Thank you. And just 6 remember the call!
in case you didn't get it, rm going to mark those 7 THE WITNESS: Toni from Midnight Express is
as an exhibit so that we can read them later. at' help me out — 'convention center with new
9 BY MR. EDWARDS: 9 boat. They are two points — two parts of this."
10 O. Do you know that number? 10 BY MR. EDWARDS:
11 A. Yes. 11 0. "Show"?
12 O. What Is that number? 12 A. "Show up the water" --
13 A. That's my cell phone 13 MR. REINHART: "On the water."
14 O. Okay. Is that still your cell phone? 14 THE WITNESS: "On the water and at the
15 A. Yes, sir. 15 center.'
16 O. All right. rm going to show you two 16 BY MR. EDWARDS:
17 documents here or pieces of paper. Well mark them as 17 O. Do you remember making that call?
is Exhibit 2 and Exhibit 3. The nun coo re dated 18 A. No. I mean, Torn from Midnight Express is at
19 March 5th, 2005. Do you remember making this telephone 19 convention center with new boat. They are two parts
20 call? And just for the record, this looks like a 20 of' I mean
x message that's being taken relative to a phone can that 21 0. But as Jeffrey Epstein's Met. why would you
22 you made. 22 be leaving such a message about Tom from Midnight
23 MR. REINHART: So the question Is does he 23 Express relative to boats and a boat show?
24 remember making the phone call, 24 A. I help out with boat purchases or, you know,
25 25 anything to do with, you know, that moves. So I mean,
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1 0. And has he consulted with you on each of the
Q. Okay. When you say "you help out with boat 2 purchases?
purchases,' what do you mean? 3 A. Not every one of them, no.
A. Stye my opinion, whether or not whether to buy 4 Q. Does he own any boats now that you're awnr,
a certain boat. h's just a hobby. I have knowledge on 5 of?
boats. Not only just airplanes but, you know, 6 A. I don't know if he owns them or not.
O. You give your opinion to whom? 7 Q. Okay. Do you know of any boats that he
A. To Jeffrey. controls or maintains?
9 0. Okay. And Jeffrey Epstein obviously, at least 9 A. Himself or?
10 in your mind, you believe he wants your opinion? io 0. How about this III ask you this way.
11 A. Yes. 11 don't want to split hairs with you here: I know we ve
12 0. Okay. So boats Is another thing that Its two 12 been talking about corporations and things iike that.
13 of you have discussed? 13 A. Yes he.
14 A. Yes. 14 Q. Do you know of any boats that he is the person
IS Q. All right. And so this a conversation or at 15 with the most control over?
16 least some evidence that a conversation existed between 16 A. Yes.
17 yourself and Jeffrey Epstein relative to a boat or a 17 0. Okay. Where would those boats be located tini
18 boat show? Is what lend of boat are we talking about?
19 A Correct. 19 A St. Thomas is the location. II would be a
20 Q. Do you remember having that conversation? 20 34-foot Inflatable boat. I know that one specificaly.
21 A. We've had many conversations about boats acid 21 Q. Okay. Do you know when he made that purchase^
22 different boat stows. If you're referring to this one 22 A Eight years ago, seven years ago. It was a
23 in '05, I don't recall this one. 23 while ago.
24 0. Okay. So aside from being a pilot — which 24 Q. Is that smelting you had had input in"
25 throughout this entire deposition I believe your 25 A. Not on that one specifically, no.
122 124
testimony has been, you know, you're just the pilot for Q. Is there any ether boat that you know of
him -- it looks like there's some other rote that you're 2 Jeffrey Epstein being the primary user of or the primary
playing here in his life. I'm not suggesting that you 3 controller of?
aro or you are not. I'm Just saying from the appearance 4 A. I mean, there's boats in St. Thomas. I mean.
5 of this, it looks that way. Is there anything else that 5 it's not pan of my job, you know, what goes on with tne
6 you want to tel me or that you want to clarify in terms 6 boats or who controlled them. It's more of an opinion
7 of the role that you play in Jeffrey Epstein's life 7 of what horsepower should bo on the back of the boat,
outside of being just his pilot? 8 hull designs. It's out of my area.
9 MR. REINHART: Let me object to form. He also 9 Q. But your sole responsibility or your sole
10 told you he installs the audio and video equipment 10 obligation that you have ever had with Jeffrey Epstein
11 before. 11 relative to boats is just giving some opinions about the
12 MR. EDWARDS: Co rrn.t. 12 boat?
13 THE WITNESS: I have an interest in boats. 23 A. Mm-hmm.
14 You know, with the island, I don't Mirth I bought 14 Q. Is that yes?
15 any boats, you know, for the company, but he 15 A. Yes, yes.
16 appreciates my opinion on boat purchases. 16 Q. Okay. Al right. Has he ever gWen you his
17 BY MR. EDWARDS: 17 opinions about boats?
18 O. Okay. 18 A. Sure. We'vo discussed it back and forth.
19 A. Having the knowledge of aviation and things 19 Q. Other than boat conversations, have you ever
20 that move quite fast. So I have consulted with him on 20 talked other conversations. such as
21 boat items. 21 A. Cars.
22 Q. How many boat purchases are you aware of 22 0. Okay. How about such as -- have you ever
23 Jeffrey Epstein making In the time period that you've 23 known Jeffrey Epstein to have a girlfriend, somebody you
24 known him? 24 consider a girlfriend?
25 A. Two or three. 25 A. No.
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1 Q. In the 18 years and all the travels you had 1 0. Did he ever fly anywhere else with you either
2 with torn, do you know anything about Jeffrey Epstein's 2 by helicopter or airplane in the last two years?
3 sex life? 3 A. We flew one time to the Sikorsky plant.
4 A. No. 4 0. What's the Sikorsky plant?
5 Q. Do you know who he has Sex with? 5 A. That's where they build the Sikorsky
6 A. No. 6 helicopters. It's in Palm Beath County.
7 Q. Do you know if he has sex with anybody? 7 Q. And when was that?
8 A. I don't know. 8 A. Probably a month ago. I'm guessing.
9 Q. Do you know If he's ever had sex on the 9 0. For what purpose?
10 airplane while you've been piloting it? 10 A. They gave us a tour at a facility.
11 A. I have no idea. 11 Q. Who's they?
12 Q. That's something that you just wouldn't know 12 A. Sikorsky.
13 because you're up in the cockpit? 13 Q. And who requested the tour of the facility?
14 A. That is correct. 14 A. They offered it to our flight department.
15 THE WETNESS: Could I take a two-minute 15 a And who went?
16 bathroom break just to lose my coffee? 16 A. Jeffrey, myself, and Igor.
17 MR. EDWARDS: Sure. 17 Q. And if I wanted documentation of either of
18 (A break was had at 1235 p.m.) 18 those trips, the trip to Miami or the trip to the
19 BY MR. EDWARDS: 19 Sikorsky plant, who would have that documentation?
20 0. All right. We're back on the record. Over 20 A. I would.
21 the years you've indicated that the any gifts or 21 Q. So I could request it from your attorney to
22 other items or things given to you by Jeffrey Epstein 22 get it from you?
23 exclusively are the pool heater, the 40-acres of land 23 MR. REINHART: Let me Just check.
24 and the -- 24 (Off the record discussion.)
25 A Use of a company -- 25 MR. REINHART: Okay. He has custody of it,
126 128
Q. -- and the use of a company car? 1 but they're corporate documents. So you'd have to
2 A. Yes. 2 request it from Mr. Critton, who I understand
3 0. That's it? 3 represents all the corporations.
4 A. (Nodding.) 4 THE WITNESS: Yes.
5 Q. Okay. BY MR. EDWARDS:
6 A. Yes, sorry, yes. 6 Q. What's the corporation that the document was
7 0. And the flight to Miami that was recent 7 prepared for?
6 taken, other than Jeffrey Epstein and A. Meaning who — what, lace Air Ghislaine, the
9 was there anybody else on that night? 9 owner of the helicopter? Yes, Air GhlSlaine.
10 A No. 10 Q. Air Ghislaine?
11 0. How long -- did you also fly them back from 11 A. That's the helicopter.
12 Miami to Palm Beach? 12 Q. And the name Ghislaine is obviously not that
13 A No. He drove back. 13 typical of a name. Is that reference or related to
14 0. When you say "he drove back" who drove back? 14 Ghistaine Maxwell?
15 A. Well, I assume he drove back I did not fly 15 A. I would assume. I have no knowledge.
16 him back. 16 Q. Nobody's ever told you that?
1.7 Q. When's the next time you saw him again? 17 A. Nobodys brought it up.
la A_ I would only be guessing. A week later, I 18 Q. Okay. And how long were you at the Sikorsky
19 mean. 19 facility?
20 Q. Okay. And was that in Palm Beach County when 20 A. Three hours, four hours.
21 you saw him the next lime/ 21 Q. And what time of day was this?
22 A. Yes, sir. 22 A. Nine in the morning. Nine, I think, and we
23 Q. Do you know of him leaving Palm Beach County 23 returned at one, something like that.
24 in the last two years on any other occasion? 24 Q. And was the purpose to buy or purchase
25 A. No. 25 anything?
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129 131
A. They have a new helicopter being developed 0. Back in his office?
2 there, so there trying to look for investors in it. 2 A. Yes. sir.
3 So they were Just kind of pushing their product. 3 0. What was that conversation?
4 O. Do you know what Jeffrey Epstein does for a 4 A. Give me a time frame. I mean. I've been them
5 living for business today, these days? 5 several times.
6 A. No. 6 0. Okay. How many times do you think you've beer
7 Q. Do you know or have you ever been to the 7 to the Florida Science Foundation?
8 Florida Science Foundation? A. Twenty, thirty. I mean...
9 A. Yes, sir. 9 Q. Well. the Florida Science Foundation's only
10 0. And do you know what the Florida Science 10 been around since late 2007; is that right?
11 Foundation does? 11 MR. CRITTON: Form.
12 A. Not exactly. 12 BY MR. EDWARDS:
13 Q. Well, generally? 13 0. Something around that?
14 A. No, I don't. I mean, really, I don't 14 A. I don't know exactly.
15 0. Okay. Is it your understanding that Jeffrey 15 O. NI right. So In the last 2O years in the
16 Epstein is somehow affiliated with the Florida Science 16 last couple of years you've been there 20 or 30 times,
17 Foundation? 17 approximately?
18 A. It's my understanckng that, yes. 18 A. Yee sir.
19 0. I mean, did you just by happenstance stumble 19 0. And during those tines when you've been there,
20 into the Florida Science Foundation, or was it related 20 without having to go through each conversation, did you
21 to your relationship with Jeffrey Epstein? 21 ever talk to him about the fact that he was on probation
22 A. rye heard that's where his office was. I 22 or that he was --
23 mean, I have no other -- 23 A. No.
24 0. Why did you go there? 24 0. -• any part of the criminal investigation?
25 A. Talk about airplanes. 25 A. No, not at all.
130 132
0. Talk to who? 1 0. What was the purpose of the conversation?
2 A. Jeffrey. 2 A. We were sometimes talking about TVs, you know,
3 O. Jeffrey just happened to be at the Florida 1 the latest plasma that's out there, LCD, you know,
.1 Science Foundation? 4 setting up a stereo systems, you know, In the Palm Beach
A. Yes. house. Thars usually the main thrust of our
0. How did you know that he was going to be at 6 conversations these days.
the Florida Science Foundation? 7 O. How woukl you know to go to the Florida
8 A. He called me and told me. Science Foundation on each of those occasions? Would he
9 0. And he said come to the %Title Science 9 just cal you?
10 Foundation to talk to me about what? 10 A. Yeah, he would call me and say come on by or I
11 A. Maintenance on the airplanes, upcoming. It's 11 got a brochure on a new Samsung.
12 an ongoing. 12 O. With each time you were at the Florida Science
13 0. And did he have an office there? 1.3 Foundation, how long would you stay typicaly?
14 A. Yes. 14 A. Ten, fifteen minutes. Not much more than
15 0. So this is when you walked in. this is the 15 mat.
16 place that's right next to Jack Goldberger's office? 16 0. You would go there for ten or fifteen minUteS,
17 MR. CRITTON: Form. 17 have a conversation about a n.f and leave?
18 THE WITNESS: Yes. 18 A. Yes, sir.
19 BY MR. EDWARDS: 19 0. Why coukkrt you have that conversation over
20 Q. And you walk in and there's a reception desk 20 the ptione? What was it about?
21 right there? 21 MR. CRITTON: Form.
22 A. Yes. 22 THE WITNESS: It it was pertaining to a TV and
21 0. Is that where you talked or did you talk 23 I'd have a brochure, a picture ol the TV one
24 somewhere behind that reception desk? 24 particular TV we looked at it was the size of a -
25 A. Behind the reception area. 25 like five foot diagonal, so 1 had a photo of myself
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1 standing next to it or the salesperson. So I moan, 1 A. We've landed in Parts.
2 there's a reason to visually show him something 2 O. You're aware that he has some control over
3 reference to that. 3 another piece of property over there?
4 BY MR. EDWARDS: 4 A. I know we've picked up luggage at a residence.
O. Did you ever communicate with Jeffrey 5 I don't know to what extent his ownership is, if any.
6 Epstein -- you can send him an e-mail, right? You could 6 O. All right.
have done that? A. Right.
a A. Yes. 8 O. And are you aware that he has some employees
9 O. To send him the picture or something Ike 9 that listen to what he says that work in that house?
10 that, that was an option? 10 MR. CRITTON: Form.
11 A. Right. 11 THE WITNESS: In Paris, yes, there is one
12 O. And what's Jeffrey Epstein's e-mail address 12 person there.
13 that you use? 13 BY MR. EDWARDS:
14 A. I have to do it on my computer, you know, 14 O. What's his name?
15 with — I have to type in the prompts for it because 15 A. Voltzan. Because I always thought there was
16 it's a long e-mail address. 16 nobody there.
17 O. Okay. How long have you e-mail corresponded 17 O. Vuttzan Cauldron (phonetic)?
18 with Jeffrey Epstein? 18 A. I don't know exactly. I would have to look It
19 A. Probably two years. A year to tyro years. I 19 up.
20 mean, les fairly - something we just started doing. I 20 O. Have you talked to him before?
21 mean. we'd never done that in the past. 21 A. No.
22 O. Wei, in the past he was In jail or have some 22 O. When you've been in Paris --
23 restrictions? 23 A. You're not going to ask why?
24 A. The restrictions, yes. 24 O. Well, I'm assuming he doesn't speak English.
25 O. So you you'd see tem on the airplane 25 A. There you go. okay.
134 136
1 frequently? 1 O. So I thought there was no need tor that?
2 A. Exactly. 2 A. Okay. I just wanted to see.
3 O. So when you didn't see him on the airplane 3 O. Where do you stay when Jeffrey Epstein Is in
4 frequently, then some of your correspondence was by 4 Pans?
5 e-mail, other times by telephone? 5 A. A hetet
6 A. Mm-hrnm. 6 Q. Okay. And in New Mexico, when you land there.
7 O. And other times in person? 7 you stay on the ranch somewhere. but at your place?
A. Yes- 8 A. I stay at my place.
9 O. And what was your e-mail — what was the 9 O. And In New York, you have an apartment that he
10 substance of the e'mall correspondence that you would 10 sets you up at, right. the 301?
11 have with Jeffrey Epstein? 11 A. Yes. I have a oleos I could stay.
12 A. It would have to be related. I mean, you have 12 O. And In St. Thomas?
13 to give me a topic. I mean, whether it be a car 13 A. Hotel.
14 O. Never about the criminal Investigation? 14 O. And in Paris you stay at a home?
15 A. Oh, no, no, never. 15 A. (Nodding.)
16 O. Do you know what his intention is or his plans 16 O. Are there any other properties such as what we
17 are for when he is off probation? 17 were talking about today — I'm not saying Jeffrey
18 A. No idea. 18 Epstein Is the sole owner or direct owner, but any other
19 Q. Or off community control? 19 properties that you're familiar with that Jeffrey
20 A. I have no Idea. 20 Epstein is - has direct a ss to and at least it gives
21 O. Has ho ever indicated to you he wants you to 21 the appearance to you that he is the owner or controller
22 fly him to some other location outside the United States 22 of that property?
23 to live permanently? 23 MR. CRITTON: Form.
24 A. Oh. no. 24 THE WITNESS: Name the list that you've
25 O. Have you ever flown to his place in Parts? 25 stated.
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137 139
1 BY MR. EDWARDS: 1 BY MR. EDWARDS:
2 O. The Manhattan house. 2 Q. And ask you about some of the allegations in
3 A. Yes. 1 here and see if you know anything about them. It
4 0. Mansion or whatever we want to call it, the 4 indicates he owns a flight of aircraft that includes a
5 Zorro Ranch, the island of St. James. the Palm Beach 5 Guffstream, a helicopter, and a Boeing 727. True?
6 house. a MR. CRITTON: What's the question?
7 A. Mm-hinm. 7 THE WITNESS: Please repeat.
8 O. And the Paris place. 8 BY MR. EDWARDS:
9 A. There all I'm SWAM of. 9 O. Are you aware of him owning a Gulfstream IV
10 O. And have you ever at any of those five places 10 aircraft, a helicopter and a Boeing 727? I think we
11 hung around him and stayed around him for -- during the 11 talked about it, right?
12 daytime for the course of an entire day? 12 A. Right.
13 A. No. 13 0. Okay. And it indicates a fleet of motor
14 O. Afl right. So do you know what he does during 14 vehicles?
15 his days while he's there? 15 MR. CRITTON: Wait a minute. He said right,
16 A. No. 16 is that we talked about it, as distinct from him
17 O. Are you aware of a list of underage guts that 17 knowing one way or another.
18 is kept to come over and service him each of those days? 18 THE WITNESS: What's the question?
19 MR. CRITTON: Form. 19 BY MR. EDWARDS:
20 THE WITNESS: Absolutely not. 20 0. Do you know that he owns those things?
21 BY MR. EDWARDS: 21 A. I do not know that he owns them.
22 0. I'm the fast person to ever even imply that 22 O. Do you believe that he owns those things?
23 to you, right? 23 MR. CRITTON, Form.
24 A. A list, yes, you are. 24 THE WITNESS: I would be guessing, so.
25 0. Okay. Have you ever been made aware that 25
138 140
keeps a list of underage girls to service 1 BY MR. EDWARDS:
2 Jeffrey Epstein for sexual purposes? 2 Q. What does the company NES. LLC, do to your
3 A. I am not aware of them. 3 knowledge?
MR. CRITTON: Form to the last question. 4 A. I have no idea.
5 BY MR. EDWARDS: 5 O. How does that company generate profit. if you
Q. Have you ever been made aware that Ghistaine 6 know?
Maxwell keeps a list of girls in the nearby areas of 7 A. I have no Idea.
8 each of -- at Jeffrey Epstein's residences to service O. Thars the company that pays your paycheck.
9 him sexually? 9 but you have absolutely no clue what they do to generate
xo A. No. 2o money?
11 MR. CRITTON: Form. 11 A. No, sir.
12 BY MR. EDWARDS: 12 0. If anything?
13 0. Okay. Have you ever read some of the 13 A. Correct.
14 complaints that have been filed against him in the 14 O. Have you ever heard that that company
15 various courts, whether state court or federal court. 15 generates money through sex trafficking of young girt
16 against Jeffrey Epstein? 16 MR. CROTON: Form.
17 A. No, I have not. 17 THE WITNESS: Absolutely not.
28 0. All right. So this Jane Doo 102 versus 18 BY MR. EDWARDS:
19 Jeffrey Epstein. you're not familiar with who that 19 O. Never, okay. Have you ever heard that Jeffrey
20 person Is? 20 Epstein has a sexual preference for underage grls?
21 A. No idea. 21 Other than what you've read in the newspaper, have you
22 O. Okay. I'm going to mark Jane Doe, one of the 22 heard that from any other individuals before?
23 22, versus Epstein as Exhibit No. 4 to this deposition. 23 A. No.
24 (Plaintiffs Exhibit No. 4 was marked for 24 0. Ever heard that he has had sex or sexual
25 identification.) 25 relationships with many minor gals, some as young as 12
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143. 143
1 years old? I about that?
2 MR. CRITTON: Form. 2 MR. REINHART: Hold on. The question is have
3 THE WITNESS: No. 3 you ever been told that fad that he just read to
4 BY MR. EDWARDS: 4 YOU?
5 Q. Never? 5 BY MR. EDWARDS:
6 A. Never. 6 0. RIgN.
7 0. Have you ever seen any photographs in any of 7 A. I have never been told that fact.
8 his homes depicting young-I0Cking girls engaging in sex a 0. Has anybody ever questioned you about your
9 acts? 9 possible involvement with helping to facilitate
10 A. No. 10 Mr. Epstein have sex with underage girls?
11 0. Or reading directly from the complaint, 11 A. No.
12 •engaged in lewd acts"? 12 0. When you were questioned by either the police
13 A. No, absolutely not. 13 or the -- whoever the investigative resource that was
14 0. Have you looked around the walls of his 14 being used at the time?
15 various homes when you're In there picking up luggage? 15 A. Right.
16 A. I mean, not arty more than I walked in here and 16 0. Do you remember who that person was that was
17 not looking at the waits over there, I couldn't tell you 17 questioning you?
Is what those are: so nothing specific. 18 A. No, I don't remember.
19 0. Sometimes we're talking about a 50,000 square 19 Q. I know you don't know the location where it
20 loot house? 20 was, but do you remember who they were affiliated with?
21 A. Exactly. 21 A. No.
22 0. In Manhattan? 22 0. Was it only one tkne?
23 A. It's pretty dg. 2.3 A. Yes.
24 0. Okay. Have you ever looked at any of his 24 0. Did you also have to testify before a grand
25 computers for any reason? 25 jury proceeding?
142 144
A. No. 1 A. No, I did not.
O. I know that you helped set up some of the -- 2 0. Have you ever known Mr. Epstein to got a
A. Computers are not my expertise. 3 massage whde on an airplane?
Q. All right. Have you ever boon told that 4 PHONE ATTORNEY: This is everybody in Boone,
Mt Epstein committed sex acts against underage girls on 5 Charles and the witness is here and the court
a literal deity basis, that's what he does? 6 reporter and the videographer.
7 A. rye never been told that. 7 MR. EDWARDS: Fantastic, but I think that you
8 Q. Have you ever read the complaints against hirn may have the wrong room.
9 that Indicate that's what he does on a daily basis? PHONE ATTORNEY: I was told to ask for 856.
10 MR. CRITTON: Form. 10 MR. EDWARDS: Let's go off the record.
11 THE WITNESS: No. 11 (Off the record discussion.)
12 BY MR. EDWARDS: 12 BY MR. EDWARDS:
13 0. So in your mind, you never believed that you 13 0. All right. In the complaint. I'm going to
14 were transporting around somebody whose sole goal Et 14 tell you what it aleges and rm gong to ask if this
15 He is to get -- have sex with time girls? 15 helps to refresh your recollection about any of Jeffrey
16 MR. CRRTON: Form. 16 Epstein's activities. The defendant. Jeffrey Epstein,
17 THE WITNESS: I never believed that, no. 17 transported the plaintiff to another state in order to
18 BY MR. EDWARDS: 10 engage in sex acts with her. And this occurred when sno
19 Q. Okay. Have you ever been told that he 19 was merely 15 years old.
20 conspired with others, including assistants andtor his 20 Do you remember transporting somebody that
21 drivels andMi pilots and his friend Ohislaine Maxwell, 21 looked like they were 15 years old on your airplane?
22 to further these sex acts and to avoid police detection? 22 A. No, sir.
23 MR. CRITTON: Form. 23 0. You never remember taking a 15-year-old, or
24 BY MR. EDWARDS: 24 somebody that looks around that approximate age, on you-
25 0. Have you ever — anybody ever questioned you 25 airplane?
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145 3.47
A. Can you be more specific? 1 O. To Santa Fe?
Q. Wel, I know that you've Indicated earlier in 2 A. Yes.
the deposition that you remember some gins under the 3 O. To Los Angeles?
age of 18 on the airplane. And so let me aSk. before I 4 A. Yes.
get back into this. whether al those indMduais you 5 O. To San Francisco?
were talking about wore accompanied by a parent or some 6 A. Yes.
of those people were on the airplane for some other 7 O. To St. Louis?
purpose, modeling, or you don't know wtly they were a A. Yes.
there? I'm going to let you elaborate on who thee* 9 Q. An right. Continuing to IMemational
10 people are that you beams may have been wider the age 10 destinations, including Europe, have you ever flown it
11 of 18 and why you think they were on the airplane? 11 to Europe?
12 MR. CRITTON: Form_ 12 A. Yes.
13 THE WITNESS: We've had younger people on the 13 Q. The Caribbean?
14 airplane that have been, you know, with their 14 A. Yes.
15 family members, like you said. I dont remember 15 O. And Atka?
16 transporting anybody that was of questionable age. 16 A. Yes.
12 I'm not rd orty be guessing at sornebodys age 17 O. On those Nights to those various places, is
16 if l didn't ID them at the foot of the airplane. 18 k your — to the best of your knowledge. you were
19 So I can't guess to their age. 19 unaware of Jeffrey Epstein engaging in sex with underage
2o BY MR. EDWARDS: 20 girls on his airplane?
21 Q. All tight. 'Mr. Epstein used his private jet 21 MR. CRI170N: Form.
22 10 transport the male( plainllIto Manhattan where he 22 THE WITNESS: I have no knowledge of any of
provided her spending money and aCeOrnrnodations with AIM 23 that.
2s at his mansion.' 24 BY MR. EDWARDS:
25 Co you have any idea who that might be 25 O. 'He provided accommodations with him I order
3.46 148
1 referring to? 1 to have her available to him at all times whenever he
2 MR. CRITTON: Form. 2 wanted, including while transporting the minor plaintiff
3 THE WITNESS: No, sir. 3 on his private }et.°
4 BY MR. EDWARDS: 4 ?bars someiting that you had no knowledge of?
5 Q. And you dont remember being a pilot of an 5 A. (Witness shakes head.)
6 airplane where he was transporting a 15-year-old to 6 O. You have to a yes or no.
7 Manhattan from Miami or Palm Beach? A. I'm sorry, no.
A. No. I'd be guessing at somebody's age and I Q. 'Each time they would travel to one of these
9 can't guess. 9 destinations, the same pattern of sexual abuse would
10 O. 'Defendant transported plaintiff in his 10 occur, often with a vast array of aspiring models,
11 private jet to locations that included Palm Beach, New 11 actresses, celebrities, and/or other females, including
12 York City, Santa Fe, Los Angeles, San Francisco, 12 minors from all over the world.'
13 St. Louis.' 13 Again, that's something you have no persona,
14 Do you remember ever piloting his airplane to 14 knowledge of?
15 those destinations that I just mentioned? 15 A. No.
16 MR. REINHAFtT: Can we break them down? 16 O. Has anybody ever indicated that it you did
17 ObjectIon: compound. 17 have personal knowledge of some of these things, then
IS MR. EDWARDS: Okay. 19 you could also have been implicated in some form of a
19 BY MR. EDWARDS: 19 aims? Has any law enforcement or anybody ever
20 Q. Have you ever flown his airplane to Palm 20 indicated that to you?
21 Beach? 21 A. No.
22 A. Yes, sir. 22 O. Okay. Is that something you've ever worried
23 O. Okay. Have you ever flown It to New York 23 about?
24 ay? 24 A. NO.
25 A. Yes. 25 Q. All right. 'Upon information and belief,
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I defendant transported minor gins from Turkey.- Did you 1 ever flown to or from in a Jeffrey Epstein airplane?
2 ever leave in one of his airplanes out of Turkey? 2 A. We have flown to Prague.
A. I'd have to look at the records. I don't 3 O. Okay. Have you picked people up in Prague and
recall Turkey. 4 flown out of Prague?
Q. Do you ever remember taking any minor girls 5 A. I don't remember.
e out of Turkey? 6 0. I'm not saying no. you didn't, but
7 A. No. I don't remember. 7 A. Best of my knowledge.
8 Q. What records would you have to look at to see 0. you don't remember?
9 N you took people out or left out of Turkey? 9 A. Exactly. Best of my knowledge, I don't
10 A. I'd have to took at the flight logs, but I 10 remember.
11 personally don't remember flying into Turkey. 11 Q. Do you remember the reason for going to Turku)
12 O. And would the flight loge coming into the 12 or to Prague?
13 United States from Turkey indicate the names of the 13 A. No.
14 people on the plane? 14 D. This also says Asia. Have you ever flown
15 A. They might 15 or from Asia with Jeffrey Epstein?
16 O. Okay. Where would I get those particular 16 A. Yes.
17 ffight logs that would have that 17 0. Or on a Jaffrey Epstein airplane?
18 A. Depended upon what year you're taking. 38 A. Yes.
19 0. We're talking in this particular complaint 19 a Do you know the purpose of those flights to
20 between 1998 and 2002. 20 and from Asia?
21 A. I'm not -- I don't possess those passenger 21 A. No.
22 manifests. 22 O. Did it ever occur to you that maybe H was to
23 O. Do you know who would possess those? 23 pick up minor Os for him to have sex with on the back
24 A. That would be I guess .- 24 of the airplane?
25 MR. REINHART: Do you know who has them today? 25 MR. CRITTON: Form.
150 152
THE WITNESS: I do not know who has them 1 THE WITNESS Never occurred to me.
today. 2 BY MR. EDWARDS:
3 BY MR. EDWARDS: 3 0. Did you ever hear that he maintained some of
0. Who did you give thorn to? 4 these underage girls as Sox slaves --
A. Actually, I didn't give them to anybody. Dave 5 A. Never heard of such a thing.
Rogers was in possession of those logs. So I don't know 6 0. -- from the age of 12 through the age of 16?
7 where they are right now. 7 MR. CRITTON: Form.
8 0. You're still thinking that the best evidence 8 THE WITNESS: No knowledge of that.
9 of that, any flight that may have left out of Turkey, 9 BY MR. EDWARDS:
10 would be in the flight logs that's marked as Composite 10 0. Ever picked up cps that looked young, many
11 Exhibit 1, or are we talking about the manifests that 11 of whom who spoke no English? Do you ever remember
12 we've been referring to? 12 that?
13 A. I don't know how accurate that log book is or 13 A. Zero. do not.
14 even how accurate the passenger manifest is. 14 0. All right. The complaint goes on to say,
15 0. Okay. So there may be no actual documentation is 'Ptarnillf was required to be sexually exploited by
16 indicating a flight leaving out of Turkey when. in fact• 16 defendant's adult male peers. including royalty.° St
17 a flight may have left out of Turkey? 17 rm going to talk, do you have any familiarity with
1e A. Correct. 18 Prince Andrew?
19 Q. Okay. The Czech Republic is the next place 19 A. I know who he is.
20 listed. Is that a place you've flown to or nom in a O. Was he ever on the airplane?
21 Jeffrey Epstein airplane? 71 A. He may have boon on the airplane.
22 A. More specific, could you name the city? 22 Q. Do you remember him on the airplane with young
23 0. I Can't name the city, al least the complaint 23 girls?
24 doesn't name the city. But I've been to the Czech 24 A. No.1do not.
25 Republic before. Anywhere within that country, have you 25 0. Do you remember Jeffrey Epstein flying in tc.
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153 155
meet with Prince Andrew? 1 BY MR. EDWARDS:
A. I dent remember. I know that happened, but I 2 0. Okay. Do you remember who else was on that
couldn't be accurate. 3 flight that left after 10 p.m.?
0. Has Prince Andrew ever been on the airplane at 4 A. No. I do not.
the same bore as a young girl, to the best of your 5 Q. Do you remember why it left after 10 p.m.?
memory and knowledge? 6 A. No, I do not.
A. To the best of my knowledge. no. 7 Q. Do you remember Jeffrey Epstein instructing
0. This also says politicians. taking about a you to wait until after 10 p.m. to leave?
9 local or U.S. politicians. Do you remember certain A. No.
le politicians being on the airplane? 10 Q. Would you have listened to him if he had told
11 A. No — I mean yes, I do. 11 you -- if he had instructed you to do that?
12 0. What politicians would that be? 12 A. I don't understand the question.
13 A. President Clinton. 13 0. Well, it he told you wait until after 10 p.m..
14 0. Okay. Who else? 14 I realize there's going to be a fine, but wait until
15 A. Former president of Israel help me out with 15 after 10 p.m. to leave, intentionally leaving
16 the name. Barak? 16 after 10 p.m., do you remember that instruction ever --
27 Q. Ehud Barak? 17 A. No, I donl remember that Instruction.
28 A. Yes, those are the two that I remember. 18 0. Okay.
19 Q. How many times was Ehud Barak on the airplane 19 A. I mean, it just happened to be departing
20 that you piloted for Mr. Epstein? 20 after 10 and there is a penalty for leaving after 10 for
21 A. Maybe once. 21 noise. So there was no intention to...
22 Q. And where did that flight pick up arid where 22 0. Al right. This also talks about this
23 did it go to. to the best of your memory? 23 particular person 15 years old being sexually exploited
24 A. Best of my memory, it was Palm Beach to 24 by businessmen and/or other professional or personal
25 Teterboro. 25 acquaintances. Are you aware of other personal or
154 156
Q. Where is Teterboro? 1 professional acquaintances of Jeffrey Epstein also
A. In New Jersey. 2 sexually abusing or exploiting little kids or underage
Q. And what was the purpose of that flight, do 3 girls on your airplane?
4 you know? 4 MR. CRITTON: Form.
A. I don't know. 5 THE WITNESS: No.
0. Was Jeffrey Epstein on the flight? 6 BY MR. EDWARDS:
A. I'd have to look at the flight logs to 7 0. If you had been aware that Mr. Epstein was --
guarantee. 8 and by this -- this is more in the form of a
9 Q. Anything about that flight stick out In your hypothetical, and that I'm not going to suggest to you
10 mind? 10 ire a fact that he was. But if you had been aware that
11 A. None. 11 every single day Jeffrey Epstein's goal was to locate
12 0. Such as a fine needing to be paid because It 12 underage girls for the purposes of sex, and enter have
13 left after 10:00 p.m.? 13 sex with them on the airplane or at some other
14 A. For that was the fight, yes. 14 designation that you were destination that you were
15 Q. You remember that? 15 traveling him to, would you have continued to pilot
16 A. les coming back to me. 16 those planes?
17 0. And do you remember young girls being on that 17 MR. CRITTON: Form.
18 flight? 18 THE WITNESS: You said It was hypothetical?
19 A. No. 19 BY MR. EDWARDS:
20 Q. AA right. 20 0. Right, It is a hypothetical.
21 A. I remember the tine. 21 A. Why would I want to answer that? Because
22 Q. Do you remember who paid the fine? 22 you're being hypothetical. I mean, it would obviously
23 MR. CRITTON: Hold on. Let me object to tan 23 be wrong.
24 of the question. To you remember it suggests 24 Q. Sure. Well, a hypothetical question is a
25 that there were. So form, predicate. 25 legal question that I'm allowed to ask.
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1 A. Okay. 1 THE WITNESS: Never heard of such a thing.
2 O. And I'm just asking you if you did have 2 BY MR. EDWARDS:
3 knowledge that Jeffrey Epstein was having sex with 3 Q. Do you know of any friends that he has in
4 little girls either on the plane or at a place that you 4 France that would send him birthday -- a birthday
5 were taking him to or from on a daily basis, that's what 5 present?
6 he did, would you have continued to be his pilot? 6 A. No.
MR. CRITTON: Let me object. Object to the 7 0. Do you know of him receiving any birthday
a form. Its argumentative. It has no more value 8 gifts or birthday people from anyone?
9 than assuming ho was chopping up bodies or anybody 9 A. Never.
to was chopping up bodies in the plane you're flying. 10 0. This particular person that filed this
11 What difference does il make? Form. 11 complaint, Jane Doe 102, indicates 'Defendant and
12 MR. EDWARDS: What difference does it make in 12 Ghislaine Maxwell acknowledged and celebrated
13 a case about him having sex with little girls? I'm 13 plaintNf's 16th birthday."
14 not going to argue with you about it. You've 14 Do you remember them celebrating somebody who
15 stated your objection. Is you flew on the airplane's 16th birthday?
16 MR. CRITTON: Exactly. tt's an argumentative 16 A. I don't recall.
17 question. 17 0. Any of this jog your memory as to who
18 MR. EDWARDS: I'm not going to argue with you 18 is?
19 about IL 19 A. No.
20 MR. CRITTON: You're arguing with him about 20 0. "From the age of 15, plaintiff' -- this Jane
21 now. 21 Doe 102 —'was sexually exploited and abused by
22 MR. EDWARDS: No. I'm asking him the 22 defendant on a daily basis and often multiple times each
23 hypothetical. 23 day.'
24 BY MR. EDWARDS: 24 So going back, was there ever a day where you
25 Q. Can you answer that? Would you have continued 25 were with Jeffrey Epstein where you could observe him
158 160
1 to be a pilot for somebody who's traveling to and Irom 1 and during an entire day?
2 destinations with the goal of having sex with underage 2 MR. CRITTON: Form.
3 girls? 3 THE WITNESS: I don't remember
4 MR. CRITTON: Form. 4 IMS so I couldn't answer the question.
5 THE WITNESS: It could be any person. It 5 BY MR. EDWARDS:
6 doesn't have to be Jeffrey Epstein, then, right? 6 0. "In September 2002, Defendant Epstein
7 BY MR. EDWARDS: purchased a commercial round-trip airline ticket and
8 0. True. s provided a passport, U.S. currency and accommodations
9 A. No, I wouldn't pilot an airplane If there was 9 for plaintiff to fly to Thailand.'
10 wrongdoing going on. 10 Do you remember him doing that for anybody
11 0. That you knew about? 11 around that time period?
12 A. That I knew you about, sure. 12 A. No, sir.
13 0. Me reading this complaint to you, is this the 13 MR. CRITTON: What was the date?
14 first time you've heard these allegations — 14 MR. EDWARDS: September 2002.
15 A. Yes. Is MR. CRITTON: Okay, thanks.
16 Q. — against Mr. Epstein? 16 MR. EDWARDS: I have here and this is
17 A. Yes. 17 actually my only copy, so I don't mind marking it
18 0. It goes on to say, 'On one of Epsteln's 18 as a composite exhibit, but well either have to
19 birthdays, a friend of Epstein sent him three 19 copy this while thing or well have an agreement of
20 12-year-old girls from France who spoke no English for 20 counsel. It's the visitor ElMale log from when
21 the purpose of -- for defendant to sexually exploit and 21 Mr. Epstein was in jail in Palm Beach.
22 abuse. After doing so, they were sent back to France 22 MR. CRITTON: Well, before we get started, it
23 the next day.' 23 IS now 1:15. We started al 10:00.
24 Are you familiar with that occasion? 24 MR. EDWARDS: We didn't really start at 10:0D
25 MR. CRITTON: Form. 25 MR. CRITTON: Shortly thereafter. I was hem
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1 pretty much after 10. But we've been hero since 1 just talked about general happenings that go on in
2 10:00. I want to take a lunch break. 2 there.
3 MR. EDWARDS: Let's do It. 3 O. What did he say?
4 MR. CRITTON: For an hour? 4 A. It's terrible: it's cold: he can't sleep.
s MR. EDWARDS: Sure. 5 They wake him up every two hours. You know, just items
6 (A break was had at 1:15p.m.) 6 like that, uncomfortable things. We talked about the
BY MR. EDWARDS: 7 airplanes a great deal. You know, we got major
O. Ail fight. I looked through the inmate log of 8 maintenance on the big airplane, so we discussed that a
9 the visitors who visited Jeffrey Epstein and your name 9 little bit. And then it was realty just how
10 appears one, two, three. tour, five, six, seven, eight 10 uncomfortable he was there.
11 times. 11 O. How long did you visit with him on that first
12 A. Okay. 12 visit, July 3rd?
13 O. Seem to be accurate in terms of how many times 13 A. I think we stayed the full hour.
14 you wen! to visit him? 14 O. All right. Is that what the time allotment
15 A. I thought six, but yes, theta.. 15 was?
16 O. I'll let you review the records and tell me if 16 A. I believe it is, yeah. 1 don't think you
17 you dispute any of that record. And I'll go ahead and 17 could leave earty, or rm not aware that you could lea've
18 mark that as Composite Exhibit 5. 18 early, until later on we found out you could stay for
19 (Plaintiffs Exhbit No. 5 was marked for 19 five minutes or longer. But I don't think any of us
20 Identification.) 20 knew that was - once you got in there, you stayed there
21 MR. REINHART: It's two pages. 21 for the hour.
22 MR. EDWARDS: Two pages. 22 O. Okay. So you talked to him for an hour and
23 MR. REINHART: Okay. 23 for the most part it was just about the conditions and
24 BY MR. EDWARDS: 24 his disappointment with the conditions?
25 O. Seen accurate? 25 A. Sure, yeah, absolutely.
162 164
1 A. Yes. 2 O. And did Igor talk to him as welt?
2 O. Okay. Jeffrey Epstein's plea. I believe, was 2 A. Briefly. I mean, not that much. You're going
3 June 30th, 2008. I Mink that's when he was taken in 3 back a tittle ways again to remember exactly what was
4 custody from them. Your first visit Is July 3rd, 2008. 4 discussed. You know, he asked how his family was doing.
5 And the other name on that visit is Igor Zinoviev. Did 5 I guess Igor& got a son. I think he asked how his son
6 you go with Igor to visit Jeffrey Epstein? 6 was doing. You know, just general questions like that
7 A. Yes. O. Did you Ode to the jail that day with Igor?
8 O. Why did you go with Igor? 8 A. I believe we did. I believe I met Igor
9 A. It just happened he wanted to see us both at 9 probably at Jeffreys house and picked him up, or if
10 the same time. There was no apparent reason. 10 not, we may have met at the airport and drove together.
11 O. How did you know that Jeffrey wanted to see 11 But we did drive together on that occasion.
12 you? 12 O. In what vehicle dId you dnve?
13 A. I don't recall who called and told me that he 13 A. The Hummer.
14 wanted to see me. I couldn't give you an accurate name, 14 Q. That's the vehicle you described earlier as
15 whether II was, you know, his attorney, Darren. And 15 the company vehicle?
16 actually, I would put a lot weight to I think it was 16 A. Yes, sir.
17 Darren. his attorney. 17 O. Is that a vehicle paid for by Jeffrey Epstein?
18 O. That would have made a phone cal to you that is A. Meaning?
19 said - 19 a Wet is that a vehicle pail for by you?
20 A. Yeah, to go. 20 A. What do you mean 'paid for"?
21 O. And what rid you talk about with Jeffrey 21 O. Did you purchase the vehicle with your money?
22 Epstein four days after he pled guilty to offenses that 22 A. I didn't purchase that one, no.
23 landed him n jai? 23 O. Do you know II it was purchased by Jeffrey
24 A. I think the first visit was how (*appointed 24 Epstein or a corporation of Jeffrey Epstein's?
25 or how scared he was, you know, being inside there. we 25 A. Probabty a corporation.
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MR. CRITTON: Form; move to share. Sounds 1 facility that was holding Jeffrey Epstein, they're
2 like a guess. 2 accurate, your name is the first one listed on the top
3 BY MR. EDWARDS: 3 of the sheer
4 0. To the best of your knowledge, that's how most 4 A. Right. There may have been earlier dates. I
5 of the items that you've discussed -- that being the 5 have no idea.
6 Seeing and the Oullstream -- they were usually held In 6 0. Well, you know, the first date that he could
7 corporate names, to your knowledge? 7 have been in there it looks like was 7/1/08 and then,
a A. To my knowledge, exactly, yes. 8 you know, so I guess somebody could have seen him 7/1 or
9 0. And so when you're saying the -- when you're 9 7/2, but those records were never provided to us. You
10 talking about the Hummer vehicle and you're stating that 10 see we were provided a whole big stack.
13 its likely a corporate entity, is that just something 11 A. I understand.
12 that you're guessing about, or do you have knowledge? 22 O. The next date rm going to talk to you about
13 A. No, I'm just guessing. 13 is 7/12008.
14 0. Okay. 14 A. Uh-huh.
15 A. I have no proof 25 0. It looks, again. Ito it's yourself and Igor
36 0. -• Olownership of who as registered to or 16 Zmoviev?
17 anything like that? 17 A. Mmhmm.
18 A. Exactly. 18 0. And that's something we talked about in this
19 Q. IS it registered to you? 19 deposition. I'm going b ask you again. I don't know
20 A. No. no. 20 that you elaborated last time, what le your
21 0. So it's registered to somebody other than you? 21 understanding of his relationship with Jeffrey Epstein",
22 A. Exactly. 22 Is that a Mend of his?
23 0. Okay. 23 A. I don't know Ms lob Oescrotion. I mean.
24 A. I just drive It, I guess. 24 he's somebody that's around a lot. but i don't know his
25 0. Okay. So on July 5th, 2008, you go back to 25 exact gob description. His English is, to say, not
166 168
I see him In jail again, and again. Igor Zinoviev is 1 100 percent, so conversation with somebody that doesn't
2 listed as a visitor. Did you go with him together on 2 fully understand you, you know, you get lost in
I that occasion? 3 translation a little bit. So I don't --
A. I didn't even realize it was two days after 4 0. So on these three visits to the jail, the
E.. the first visit. s first three that we're talking about that we've talked
6 Q. Well, I mean, you see where this is going? 6 about so far. each of those times you traveled to arc
A. Yeah, I do. It gets further apart, yeah. 7 from the jail with Igor?
O. Do you remember what the discussion was on 8 A. Mm-hmm.
9 7/5/08? 9 Q. Yes?
10 A. No, because it's probably similar to the first 10 A. Yes, yes.
11 one. I mean, we talked — actually, one of the visits 11 0. And each of those time, is it fair to say you
12 we talked about fishing and just hying to — you know, 12 had some kxm d communication either on the way to the
13 we were talking about things that would just occupy his 13 jail or —
14 mind with intelligent conversation that he probably 14 A. Sure.
15 wasn't getting there. So for that hour of the day, I 15 0. to the jail?
16 tried to give my best of intelligent conversation to 16 A. Yeah.
17 him. 17 0. Since you're going to see an inmate in the
18 0. Okay. On his visitor log you were the first 18 jail, is it a safe assumption a portion of that
19 one to go visit him. Did you know that? 19 conversation was about the person that you're going to
20 A. I did not know that. I wasn't aware of that. 20 see and possibly the crime that was committed?
21 MR. CRITTON: Let me just object to form to 21 A. Yes, that would be a good assumption.
22 the last question. 22 0. Okay. And what was the form what was the
23 BY MR. EDWARDS: 23 substance of that conversation that you can remember
24 Q. Weil, at least if these records are accurate, 24 related to Jeffrey Epstein and the location you were
25 which are the records that were provided to us by the 25 going to visit him?
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A. I think Igor and I discussed on trying to be 1 a And in the course of that conversance. again.
2 upbeat and not look at the position that he's in sitting 2 the allegations and the unusual call it case
across the table from us, to be upbeat and uplift his 3 against him. that didn't come up between you and
spirits. 4 Mt Epstein'
Q. Did you and Igor discuss whether or not you A. I never talked about it with him.
6 were going to talk to him about his plea of guilty a 4 O. And at that point In time, what were you aware
7 the fact that he's not registered as a sex offender? 7 of in terms of the number of girls that he was alleged
6 A. No. 8 to have had sexual some sort of sexual retanorehe
9 0. Or whether you were going to stay away from , with him at his Palm Beach house?
10 those topics? 10 A. What was the question? How many girls?
11 MR. CRITTON: Form. 11 O. Yeah, how many girls were you —
12 THE WITNESS: We never we don't discuss 12 A. Aware of?
13 that amongst ourselves and/or with Jeffrey in any 13 0. -- aware of?
14 way, loan. 14 A. None. I wasn't aware of any, to be honest.
15 BY MR. EDWARDS: 15 O. The next eat is on 7/17/08 and Ws Igor
16 0. Okay. But that's not — I realize you didn't 16 Znoviev and somebody named Jean Rene and then yourself.
17 discuss that. You've told me that. 17 Do you know who Jean Rene Is?
18 A. Right, but we didn't discuss that oven prior 18 A. No.
19 to going in, as you asked. 19 0. Do you think that that visit. that you visited
20 0. Okay. So your discussion was mainly hey, 20 hkn at the same time that Jean Rene visited?
21 let's be upbeat? 21 MR. CARTON: What's the date?
22 A. Yes. 22 MR. EDWARDS: It's 7/17108.
23 0. And that was to, in essence, maintain his 23 THE WITNESS: No. I don't know a Joan Rene,
24 spirits or raise his spirits? 24 unless somebody came after. I mean, I don't -- I
25 A. Exactly. 25 don't know a Jean Rene.
170 172
1 0. Okay. And you were doing that as a friend of 1 BY MR. EDWARDS:
2 his, not just his pilot, right? 2 O. Okay. And then before you visited him again,
A. I felt honored that he asked me to come and 3 the visitors are listed as or
4 give support like that. because prior to him going away, 4 IOW
it was known to us that there was going to be no 5 A. Mm-hmm.
6 visitors, because I had offered to him that I would be 6 0. Manly those two individuals. And they list
7 happy to come and visit him if he deemed It necessary, 7 as addresses, as their residence?
8 and he says no. I'm not going to have anybody. 8 A. Uh-huh.
9 O. So 9 0. Given your previous testimony, does that
10 A. I guess it was so bad there, that he may have 10 surprise you that they list those that address as
11 changed his mind and wanted to have some visitors. 11 their residence?
12 Q. When did you have this conversation with him 12 MR. CRITTON: Form.
13 where he indicated he was not going to have visitors 13 THE WITNESS: I've seen them there, so I mean.
14 while he was in jail? 14 I'm not surprised.
15 A. I don't exactly remember. It may have been on 15 BY MR. EDWARDS:
16 the trip heading to Palm Beach, the last flight. 16 0. Okay. Did you know that they were visiting
17 Q. From his island, from St. Thomas I guess It 17 Nth In jail?
18 would be from? 18 A. No, I di&'t know who was scheduled to see him
19 A. 'forgot where it started from. It might have 19 or whatever.
20 been New York or the island, one of the two. I don't 20 0. Did Jeffrey talk to you at any point in time
21 remember the last flight. 21 about
22 O. And I mean, old at least the fact come up that 22 A. No. not at all.
23 hey, this a glamors who you're — Is going to be in hill 23 MR. REINHART: Can we get a time frame for
24 for some time? 34 that? Ever?
25 A Mm-timm, yes. 25 MR. EDWARDS: Oh, no, well, I was talking -
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1 I'm sorry. 1 at the house.
2 BY MR. EDWARDS: 2 O. Those are cars that Jeffrey Epstein owns, to
3 O. I was taking right now about in the 3 your knowledge?
4 conversations that you had with him that we've discussed 4 A. I don't know who owns them.
5 with you and him in the jail faC' . Did he discuss 5 O. What cars are there that -- I know with this
6 with yeti or 6 case we're dealing with a lot of corporations and Its
7 A. No. no. 7 not like asking me, Hey, what car do you own? But what
8 0. Did he talk to you about whether or not you 8 cars are you aware that are -- that you believe are used
9 should talk to anybody about his criminal investigatkit 9 prImanly by Jeffrey Ereteln?
10 or possible litigation? 10 A. Used primarily by Jeffrey Epstein, a Mercedes
11 A. No, not at aft 11 S500 sedan. I don't remember the year on that one.
12 O. The next time you see him b on August 8th, 12 O. Okay.
13 2008, at the jail. In that occasion It mentions as his 13 A. There's a Cadliao Escalade.
14 visitors that day and 14 O. Okay.
35 Larry %/Gosh'. Did you go to the jail with and 15 A. Those are his two main cars that he would be
16 IM that time? 16 driven in or --
17 A. No. Who was on there? Which one are you 1? O. What are the other cars that you reguiarty see
18 referring to? 10 parked at his Palm Beach mansion, if there are any?
19 O. The next one, I tried to highhght them just 19 A. It would be a whole array. Half the time the
20 so that — 20 parking lot is full because of construction workers.
21 A. Right, that one. 21 yards keepers.
22 MR. REINHART: 8/9. 22 O. Okay. Fair enough. What vehicle does
23 BY MR. EDWARDS: 21 drive or-drive when they're down
24 0. 8/9i08? 24 here, you known
25 A. One of those two we all drove together. I 25 A. I mean, anybody has a choice to pick out a car
174 176
1 don't remember which one it was. II was ether the 8 or 1 or whatever there. I've seen driving a Mercedes
2 the 16. and then the other ono I met everybody there. 2 convertible.
3 So I can't be accurate on which erne we all drove 3 O. Is that different than the Mercedes $500
4 together. 4 sedan?
5 O. How did you coordinate driving together? 5 A. Yes. I think it's different.
6 A. I don't exactly remember now. I mean, I think 6 O. When you say they have basically a choice of
7 -and I may have conversed on the phone and said do 7 cars to drive -
a you want to meet at Jeffreys house and we all drive $ A. Well, there's cars in the lot there.
9 together? Does a make sense to get together and drive 9 O. Obviously, they can't get in one of the
10 one car. 10 construction workers' cars?
11 O. Is that jail visit the result ol Jeffrey 11 A. No.
12 Epstein requesting your presence Mere, Of rs that the 12 MR. REINHART: Let him finish his question.
13 result of you wanting to go see him as a friend in jail? 13 BY MR. EDWARDS:
14 A. A combination of both. I'm sure if I said, 14 O. So that's kind of what I'm getting at. What
15 Hey, rd like to come to jail and veil you, that ho IS other cars do you think that Jeffrey Epstein has --
16 would either say yea or nay. 16 whether it's titled. I don't know -
17 O. Okay. And you saki at least on one of those 17 0. Right.
18 occasions you rode to and Irom the lad with =and 18 O. but he is the person In control of that
19 19 vehicle?
20 A. Yes. 20 A. Right.
21. O. And during any of obviously, when you're in 21 O. What other vehicles do you think he's
22 the car together — well, who's driving the car? 22 controlling in Palm Beach?
23 A. I was driving, I believe. 23 A. In Palm Beach?
24 O. And that's the Hummer again? 24 O. We've named the Mercedes S500 sedan, Cadillac
25 A. Actually, I think we take one of the suburbans 25 Escalade?
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1 A. Right. he utilizes various people, schedulers, pilots.
2 0. And Eve identified a Mercedes convertible? 2 handlers and other associates and co-conspirators
3 A. Right. 3 that have a similar mentality: that is, people that
4 0. In addition to that. are there any others that 4 do not agree with laws related to sex abuse and
• you're aware of? 5 abuse of children. And that's why this line of
6 A. That he's in control of? 6 questioning regarding whether or not this witness
7 Q. Yes. 7 has a motive or a bias or was involved in
• A. No. 8 conversations related to his motive or bias, to
9 0. And does the conversation come up between 9 continue to work for Jeffrey Epstein or believed
10 Mi ancin and yourself about the reason why 10 the same beliefs of Jeffrey Epstein, is at least
11 Jeffrey Epstein is In jail? 11 reasonably calculated to the lead the discovery of
12 MR. REINHART: Can we get a time frame? 12 admissible evidence, and that Is the argument at
13 MR. EDWARDS: At any time. 13 least along those fines being made to the judge
14 BY MR. EDWARDS: 14 regarding these questions.
15 0. At any time have you ever had that exact 15 MR. CRITTON: Can we talk for just one minulo'l
16 conversation ever come up? 16 Because maybe — can I talk with — well, I know
17 A. No. we didn't talk about that among ourselves 17 can talk with Bruce. Let's Just take a break.
143 really. 18 (A break was had al 2:45 p.m.)
19 Q. And have you ever been told that= 19 MR. EDWARDS: We're be* on the record. Do
20 provides the role of a sex slave to Jeffrey 20 you have the same position?
21 Epstein? That's just her role in life? 21 MR. REINHART: Let me say this: He previously
22 MR. CARTON: Form. 22 said he would have never allowed anything on the
23 MR. REINHART: That's just have you been told 23 plane to be done elegaRy. II you want to ask If
24 that. 24 he agrees with the law applied by the
25 THE WITNESS: No. 25 legislature — do you agree the law passed by the
178 180
1 BY MR. EDWARDS: state of Florida should be complied with?
2 0. Have you been led to believe that by anybody? 2 THE WITNESS: I don't know what the law is.
A. No. 3 BY MR. EDWARDS:
a MR. CRITTON: Form. 4 0. Okay. The laws In place to protect children
5 BY MR. EDWARDS: 5 under the age of 18 from being sexually touched,
6 Q. Do you have any — based on your observations, 6 fondled, molested by people over the age of 24, do you
7 do you have any other opinion as to what rote she plays 7 agree with those laws?
Es in Jeffrey Epstein's life, if any? 8 A. Yes.
9 A. I don't have an opinion on what the role is. 9 0. And you agree that persons who commit a
10 0. Do you agree with the criminal statutes that 10 violation of those laws should be prosecuted?
11 are in place to protect young children from sexual 11 A. Persons that do that.
12 predators? Do you agree with those statutes? 12 MR. CRITTON: Form.
13 MR. CRITTON: Form. 13 BY MR. EDWARDS:
14 MR. REINHART: IM going to direct him not to 14 0. Yes, persons that do that.
15 answer the question. Its irrelevant and it's not 15 A. Persons that do that, absolutes/.
16 likely to lead to discoverable evidence what his 16 0. And if you were to receive confirmed what
1? opinion is on a law Chars been passed by the 17 you would perceive as confirmed information that Jeffrey
18 legislature of Florida. 18 Epstein was one of those persona, would you continue to
19 MR, EDWARDS: Just so the record is dear, I 19 be erriployed by or alongside of Jeffrey Epstein?
20 don't know that we did this last time, but It's 20 MR. CRITTON: Form; speculation.
21 been alleged in the complaint k has been 21 THE WITNESS: You're pawning that there's
22 alleged in several complaints that Jeffrey Epstein 22 gut
23 panicularly prays on vulnerable disadvantaged 23 BY MR. EDWARDS:
24 females, underage females, and that in order to 24 0. No. I'm saying, hypothetically, if you were
25 gain access to the multitude of underage females, 25 convinced that Jeffrey Epstein was guilty of those acts
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which he pled guilty to 1 against him and the allegations contained within many of
2 MR. CRITTON: Form. 2 these civil complaints on behalf of girls who were under
3 MR. REINHART: Can we -- for purposes of your 3 the age of 18? Is there any reason why you haven't
4 hypothetical, what facts do you want him to assume 4 discussed that?
5 are true? You said the facts to which he pled 5 MR. REINHART; If that's based on
6 guilty, but the witness already said he doesn't 6 conversations you had with your lawyer, then don't
know what he pled guilty to. He imows the charge 7 disclose what you and your lawyer talked about
8 he doesn't know the facts. 8 BY MR. EDWARDS:
9 BY MR. EDWARDS: 9 0. Correct.
10 Q. Solicitation of prostitution of a minor, 10 A. I have not spoken to Jeffrey about any of
11 somebody under the age of 18. 11 this, and it was my understanding that is illegal to
12 MR. EDWARDS: That's the charge, right. 12 have conversation about this. So I've never presented
13 solicitation of prostitution of a minor? 13 any questions to him reference this case or any others.
14 MR. CRITTON: No. I think you've got it 14 0. It was your understanding that it was illegal
15 wrong. III object to the form. 15 to talk to Jeffrey Epstein about the allegations made
16 MR. EDWARDS: Okay. 16 against Jeffrey Epstein?
17 BY MR. EDWARDS: 17 A. Yes, or anything to do with the case. That's
18 O. Then well handle the question this way: If 18 why we never discussed any portions of it.
19 you were to believe based on informati0n and evidence 19 Q. Okay. So --
20 that Mr. Epstein engaged in sex or some form of sex acts 20 A. I may be wrong In that assumption, but I
21 with people of the age range of 12, 13, 14. 15 years 21 don't --
22 old, would you continue your employment with 22 Q. So the reason why you haven't discussed this
23 Mr. Epstein? 23 with Jeffrey Epstein is you believed it was illegal?
24 MR. CRITTON: Form; speculation. 24 A. Correct, yes.
25 THE WITNESS: I would certainly be speculating 25 Q. Who led you to believe that it was illegal?
182 184
1 and I have to dleCuss ft with my wife long and 1 MR. REINHART: Again, if it was a discussion
2 hard. I don't think I could give you a correct and 2 you had with any lawyer, then you can just give a
3 honest answer at this tine. 3 name, don't give a discussion of the conversation
4 BY MR. EDWARDS: 4 you had.
5 0. Okay. Given the allegations that have been 5 THE WITNESS: It was my own assumption. I
6 made in this case, is this something that you have mean, just basic criminal knowledge of knowing
7 discussed with anyone other than your attorney? 7 you're not supposed to -- you know, it somebody's
8 A. No. not really. Only from the fact that 8 in trial or in a deposition or whatever, I don't --
9 drey're allegations and there's still a lot more work, 9 I didn't think it was appropriate to discuss the
10 rm sure, to be discovered. 10 matter with them.
11 MR. CRITTON: Let me put on there, for the — 11 BY MR. EDWARDS:
12 If this deposition is not typed -- and we request 12 Q. Okay. So the next two visits and I think the
13 it -- rd like at least this portion where 13 last two visits we'll talk about are on 9/6/2008.
14 Mr. Edwards' last question back about five pages 14 Actually, it looks like you visited him twice in one
15 worth, so just if you could mark it from ells 15 day; is that right?
16 page back about five pages. 16 A. I don't think that's possible. I mean, that
17 If nobody requests the deposition, rd just 17 will show how accurate the court record is. There's no
18 like those five pages. 18 way.
19 MR. EDWARDS: I'm going to request the 19 Q. You wouldn't have visited him twice in one
20 deposition, so... 20 day?
21 MR. CRITTON: Okay. We'll mark this then, so 21 A. No. I think there's only one visitation per
22 you could tell me where it is. approximately. 22 day.
23 BY MR. EDWARDS: 23 0. Okay. And It looks like the same visitors
24 0. Is there a reason why you have not discussed 24 each time, except that it says for period three and then
25 with Jeffrey Epstein the allegations that have been made 25 the next one's for period four. So there are two
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different periods. Was there over a time when they telephone, how frequently would you talk to him?
2 allowed you to stay for more than an hour? 2 A. How frequently during a given week?
3 A. No, not to my knowledge. 3 0. Yeah.
4 0. Okay. So again, it's and 4 A. More specific?
5 same questions: Did you ever ask them their 5 0. Sure.
6 involvement with Jeffrey Epstein? 5 A. Depends upon what's going on that week.
7 A. Absolutely not. 7 0. I mean. is it somebody you would talk to him
8 0. And again, what was the discussion with 8 everyday?
9 Jeffrey Epstein along with and 9 A. No.
10 10 0. All right. Welt at that point in lime, he's
11 A On the last visits, it was mainly airplane 11 going from the jail to the Florida Science Foundation
12 stuff and later on in the visitations, we were advised 12 and back, and It you're not going to see him In person,
13 that you could leave early, so I would only stay for 13 and you're not corresponding by e-mail, then would you
14 maybe 30 minutes and then, you know, Jeffrey would Is correspond by telephone, that either being you call him
15 continue his conversations with them and then I would 15 or he called you?
16 just wait outside. 16 A. Yes.
17 0. Okay. 17 0. And, you know, in any oven week, what was the
10 A. So I would do my business with him talking 1$ typical week like? I mean .-
19 about airplanes or whatever I had coming up and then 19 A. Flow many times?
20 exit. 20 0. Yes.
21 0. And then why did you slop visiting him in jail 21 A. Maybe once in a week, sometimes twite in a
22 after that September 6th, 2008, visit? 22 day. I mean, it would vary. There was no routine.
23 A. I was never called back to visit. 23 0. And what would the conversation be?
24 0. Okay. Well, shortly after that then he was on 24 ik Mostly we discussed audio and video, TVs, home
25 work release? 25 theaters. Its a niche of his and we're constantly
186 188
A. Well, that's true. 1 looking at new items that are out there, you know.
0. Right? 2 what's the biggest LCD flat screen out there.
A. Yeah. 3 Q. Okay. And since he's been out of jail and on
0. So the next times you would have gone to see community control or house arrest or whatever it is,
him would have been at the Florida Science Foundation, 5 where he's located at his home now, have you visited him
where we talked about earlier? 6 at his home?
A. I've seen him there, yes. 7 A. I have been to the home. I haven't visited,
0. Okay. And in fact. I think you said you saw but I have had work to do there.
9 Nm 20 or 30 limes -- 9 0. And have you called him on the telephone
10 A. Sure. lo there?
11 0. over the last two years, last year and a 3.1 A. Once I think I've called the house. Normally
12 half or so? 12 he calls me because its usually he needs me to do
13 A. Yes. 13 something.
14 0. And how long would you stay each time at the 14 0. And what have those conversations been about
3.5 Florida Science Foundation and talc to him? is since he's been out of jail?
16 A. Like my original answer. ten, fifteen minutes. 16 A. Let's put a stereo in the gym, lees put a TV
17 0. Okay. And how frequently would you talk to 17 In the living room, let's put a bigger stereo in the
18 Jeffrey Epstein while he was at the Florida Science is gym. let's put a bigger, bigger stereo in the gym, let
19 Foundation? 19 go redo what we've done. It's always audio. He's a
20 MR. REINHART: I'm sony, you're talking in 20 very audio file person.
21 person or al conversations? Because ho testified 21 0. Do you know of any other modifications that
22 he had phone conversations and personal visits. 22 he's made to the house at 358 El Bello since the time
23 BY MR. EDWARDS: 23 that he went into jail?
24 0. I was actually taking about phone 24 MR. CRM-ON: Form; predicate.
25 conversations. So when you would call him on the 25 THE WITNESS: Meaning? Be more specific.
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BY MR. EDWARDS: 1 A. No, I don't. Ifs not my airplane.
Q. Structural modifications, architectural 2 Q. We still don't know whose airplane it is yet.
modifications? 3 The tine when you took Mr. Epstein to Miami in the last
A. Starting what date? 4 month, do you know which attorney ho was going to sect?
O. June 30th, 2008. 5 A. No, I do not.
MR. REINHART: I think the question on the 6 0. And do you know whether it was related to
table was have you observed any structural changes 7 civil cases or criminal cases or anything else?
a to the house at El Brillo since Mr. Epstein went to a A. No idea.
9 jai? 9 Q. Do you know where the location was in Miami
10 THE WITNESS: Structural changes? 10 that he was going to?
11 8Y MR. EDWARDS: 11 A. No, I do not
12 0. Structural, architectural, anything like that, 12 Q. Other than yourself visiting Mr. Epstein at
13 changeS to the house. to the interior of the house since 13 the Florida Science Foundation, are you aware of any
14 he went to Jail? 14 other visitors, people that visited him?
15 A. No. I mean, it you could be more specIfc. I Is A. No, I'm not. Just whoever was there during my
16 mean. you're talking furniture or? 16 visit.
17 Q. I've never been In the house, so I can't be 17 O. Okay. Are you aware of a corporation named
18 much more specific. Have you noticed any changes from Is the Zoao Trust?
19 before he went to jail to after he went to jail, the 19 A. rve heard the name.
20 Inside of the house, that you could be specific about? 20 Q. And Is that something that you've heard
21 A. No, I can't be specific. 21 relative to your invoNement with Jeffrey Epstein?
22 MR. REINHART: Can I talk to Mr. Visoski for a 22 A. Yes. I mean, I don't even remember where I
23 second? 23 heard Zorro Trust. I have no definition of it, but I
24 MR. EDWARDS: Sure. 24 know the name is out there.
25 (Off the record itscussion.) 25 0. Okay. Is that a company that you believe is
190 192
MR. REINHART: I think Mr. Visoski can expand affiliated or restated to Jeffrey Epstein in some way?
on his previous answer. Why don't you expand. 2 A. I have no definition. I don't know who it is.
THE WITNESS: Can we go baCk to that one? 3 0. Do you know how you heard about it?
BY MR. EDWARDS: 4 A. I don't remember. That's going back in the
0. Sure. The question dealt with the structural 5 early days of when Zorro existed.
architectural changes you're aware of. 6 0. Who was at the Florida Science Foundation when
A. There has been a kitchen extension, but when 7 you would meet with Jeffrey Epstein on these meetings?
:-: you asked the question, I was unaware of when that 8 A. would be there.
9 actually took place. So to be accurately answering your 9 0. Anybody else?
10 question, I know there's been a kitchen extension. I 20 A. Story would be there on occasion. That's
11 don't exactly know when that transpired, but... 11 pretty much it.
12 0. How do you know about the extension? How do 12 Q. And would they be in the same room with
13 you know this happened? 23 yourself and Jeffrey Epstein when you had conversations
14 A. I knew what the kitchen looked like before and 14 with hcm?
15 after the extension and I don't I thought it was 15 A. No, not really. Not particularly.
16 during the hurricane season when they actually did that 16 0. They would just be at the location?
17 extertskm. 17 A. Sure, yes.
18 0. Who made you aware of it? 18 O. Anybody else that worked there or was
19 A. Nobody. I just walked in the kitchen and 19 affiliated wet, the Ronda Science Foundation that you
20 noticed a bigger room than what it was. 20 know of?
22 Q. All right. Do you know who Marlin Nowack is? 21 A. Not to my knowledge. I mean, I do my business
22 A. No. 22 and get in and get out
23 Q. Do you ever remember him being on your 23 Q. Can anybody other than Jeffrey Epstein have an
24 airplane, or that name of somebody being on your 24 office at the Florida Science Foundation?
25 airplane? 25 A. Not that I know of.
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193 195
1 0. All right. And were you deeded the properly 1 0. Well, we've just described this wide array of
2 that we spoke about earlier on the New Mode° ranch? Is 2 cars that Jeffrey had for people to use --
3 that deeded to you? 3 A. Well you sakl for him to use.
4 A. Yes. 4 MR. CRITTON: Hold it.
Q. And has It been since back in, I think you 5 BY MR. EDWARDS:
6 said 1998 or 1999 or whenever it was? 6 Q. Is there a reason why?
7 A. Yes. MR. CRITTON: Wait. You guys are both talking
0. Okay. And do you know — and did you build a 8 over one another. You need to let him wait and
9 house on it then? 9 finish his question because If I want to assert an
10 A. Yes, I did. 10 objection. neither one of you gives me a chance.
11 0. Okay. And that's a property that I think you 11 which may be the plan. Form.
12 said you have a mortgage on It. that's a property that 12 MR. EDWARDS: Yeah, we have a conspiracy
13 you pay -- you mortgaged that property? 13 against you.
14 A. Yes. sir. 14 MR. CRITTON: I knew it. I'll take that as an
Is 0. All right. And as well, the home you own 15 admission.
16 here, you have a mortgage on that properly as well? 16 BY MR. EDWARDS:
17 A. That Is correct. 17 0. Is there any reason did Jeffrey say that he
18 0. Alt right. Are you familiar with a vehicle. a 1e wanted that vehicle to use or to bo parked at his house?
19 Chevy Suburban 1503. year 1999? 19 A. No.
20 A. Do you have a color? 20 0. Then how did it come about that you started
21 0. No. I can tell you the ;Ate. I could tell 21 parking that vehicle at his home?
22 you the VIN. Chevy Suburban -- Chevy Suburban 1500, 22 A. I think the origination of that came when I
23 registered to Larry Vlsoski? 23 started using the Hummer, that the Suburban was parked
24 A. That would be mine. That's a while one, then. 24 in my driveway and I wanted to get it out of my driveway
25 0. Okay. When did you get it? 25 as an eyesore. So hence, I decided to let people at the
194 196
A. rm guessing. It was probably two years old 1 house drive it as a grocery shopping car or something,
when I got it. Maybe '99. Maybe '01.'02. 2 or just as extra transportation.
0. Something you still drive? 3 0. Okay. But when you go to park the car at
A. Occasionally. Its kind of a beat up car now, 4 somebody else's house, you have to let them know. Hey,
c so it's kind of a knock around. 5 rm giving you the keys?
5 0. Best of your knowledge, it stays parked at 6 A. Mm-hmm.
your house? 7 O. Who did you give the keys to?
A. Recently irs been in Jeffrey's driveway, 8 A. I don't know ill gave the keys to anybody.
9 9 may have just left them on the counter there and told
1G 0. Why? to Yanush this is an extra car if you guys needed it to run
11 A. Just for an extra car to use. 11 around because it was an eyesore at my driveway.
12 0. For Jeffrey to use? 12 0. Are you familiar with a Mercedes-Benz SIN
13 A. No. I mean, for anybody that would come to 13 1999?
14 the house to help out. Igor I think has driven the car 14 A. Say that again.
IS before. 15 0. Mercedes SUV, 1999 registered in your name?
16 0. How did it come about that you began to park 16 A. Yes.
17 the Chevy Suburban, the 1999 car that we're talking 17 0. And what car is that?
18 about, at Jeffrey's house? 18 A. There my car my wife's car.
19 A. When there was more activity here in West Palm 19 0. Does that stay al your house?
20 Beach. We were never usually coming here that often, 20 A. Yes.
21 and now with atilt*, going on, with Jeffrey being in 21 O. And that's the car that's parked at your hot's..
22 town longer, we needed more cars and transportation. So 22 now?
23 my car was lust sitting In the driveway at home while I 23 A. Yes.
24 was driving the Hummer. So I decided to let them use 24 0. Are you familiar with a Land Rover, Range
25 the Hummer at the house. 25 Rover Sport 2008?
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1 A. Yes. 1 2005 registered in your name?
2 Q. Registered in your name? 2 A. Yes.
3 A. Yes. 3 0. And whose car is that?
4 0. And whose car is that? 4 A. That car also is a Palm Beach house car to be
5 A. That's another extra car for the household to 5 used at the house.
6 use at Jeffrey's house. 6 0. What does that mean, 'a Palm Beach house car?
7 0. And when was that car purchased? 7 A. It's a car that we park in Jeffrey's driveway
8 A. Last year. 8 for people to use. Anybody that comes to the house can
9 0. And who purchased that car? 9 selectee/it to go anywhere. I mean, run errands, go
10 A. tt was purchased in my name. 10 shopping, do whatever they need to do. And that was
11 a By whom? Who purchased the car in your name? 11 purchased the same way. It was in my name.
32 A. Well. I put the car In my name, but the lands 12 0. And the funds came from Jeffrey Epstein?
31 came from they were wired to my account from New 13 A. They were wired to my account. I don't know
14 York. 14 exactly what account they came from.
15 O. From whom, though? A mysterious source Just 15 0. Again, that's a conversation that has to take
16 sent funds? We know that didn't happen, so Prn just 16 place before — that you have to agree to put a car in
17 trying t0 elaborate here. 17 your name?
18 A. Jeffrey had paid for the car. 1e A. Yes, yes.
19 O. Okay. And why did Jeffrey pay fora car and 19 0. And is that a conversation between yourself
20 put It In your name? 20 and Jeffrey Epstein that takes place?
21 A. I don't know. 21 A. Yes.
22 0. I mean, you had to agree for this to happen. 22 0. And what is the substance of that conversation
23 So what was the conversation between you and Jeffrey 21 that results in a Mercedes-Benz 2005 being placed in
24 that resulted in Jeffrey paying for a Land Rover, a 2008 24 your name?
25 Land Rover and putting It in your name? 25 A. He just said we need a fun car for the house
198 200
A. I don't recall exactly how the conversation 1 It Palm Beach.
came about. He just says we want to buy an '08 Land 2 0. But why put it in your name?
3 Rover and put it in my name. So we did. I didn't ask 3 A. I don't knOW.
4 any further questions. 4 O. You didn't ask any questions about that?
0. Did this conversation happen when he was in A. No. I didn't.
jail or after he was out? 6 0. Okay. Are you aware of a Jaguar X-Type 2005
A. Meaning out on house arrest? 7 registered in your name?
a 0. Right. A. I forgot about that one, yes.
9 A. When you say flout' I think of the Science 9 0. Whose car is that?
o Foundation. On work release, so you have to be more 10 A. That's a Palm Beach car.
11 specific. 11 0. What do you mean 'a Palm Beach car"?
12 0. You tell me what happened, when the 12 A. It's the Palm Beach house car, another run
13 conversation happened relative to whore Jeffrey was at 23 around for people to use.
14 the time. 14 0. And again, that's a conversation that has to
15 A. I'd only be guessing again. I would say this 15 take place that results In a car being placed --
16 probably happened a year ago, maybe loss than a year 16 registered in your name?
17 ago. rd have to look. I don't remember exactly the 17 A. Yes.
19 0. So It was either at a time when he's at the 18 0. Okay. Now we're talking about several cars
19 Florida Science Foundation or possibly on house arrest? 19 here?
20 A. It was - no, it was definitely before house 20 A. Yes.
21 arrest. It was probably during the time of the Florida 21 0. That are all being placed in your name?
22 Science Foundation, to be accurate. 22 A. Yes.
23 0. Okay. Are you aware 23 0. You never at any time ask any questions to
24 A. About eight or nine months ago. 24 Jeffrey Epstein why are you placing these cars in my
25 0. Okay. Are you aware of a Mercedes-Benz CLK 25 name?
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A. I did not. 1 0. Who drives that car, Ford F-250?
Q. So your suspicions were never -- your 2 A. That was shipped to St. Thomas.
3 curiosity was never piqued at all as to why these cars 3 0. For who to use and for what purpose?
we being placed In your name? 4 A. Wel, that car should have been put under LSJ,
5 A. My curiosity was piqued. 5 Lie.
Q. You never asked him the question, you just 6 0. What's LSJ, LLC?
agreed to do it? 7 A. Little St. James.
8 A. That's correct. Q. And that's a corporation?
9 0. That goes for the Jaguar X-Type? 9 A. Yes.
10 A. Yes. 10 0. Your understanding is that's a corporation
11 Q. Are you familiar with a motorcycle, Big Dog 11 affiliated with Jeffrey Epstein?
12 Chopper Motorcycle. 2003? 12 A. I know It's a corporation. I don't know its
13 A. That is mine. 13 affiliation to Jeffrey.
14 0. Yours? 14 0. At this point in time, the way that this car
15 A. Yes. 15 comes about Is through a conversation with yourself and
16 Q. Registered in your name for a good purpose, 16 Jeffrey Epstein?
17 right? 17 A. Yes, yes.
18 A. Yos, It is. le 0. So to make some representation that this • •
19 Q. At your house? 19 that this corporation LSJ, LLC, you're not sure if char
20 A. Yes. 20 has any affiliation with Jeffrey Epstein?
21 0. You use it? 21 A. I don't have any facts to lie the two
22 A. Absolutely. 22 together.
23 Q. Al right. Ford F-250, 2008. registered in 23 0. Common sense would dictate?
24 your name, are you familiar with that? 24 A. Yes.
25 A. It's not registered in my name. 25 0. Okay.
202 204
Q. Okay. So if that's registered in your name, 1 MR. CRITION: Form.
that would be a shock to you? That would be a surprise 2 BY MR. EDWARDS:
to you? 3 0. Again, that's not a car that you use. the Ford
A. Yes. it would be. 4 F-250?
0. There should be no documentation from you 5 A. No, it's not even here.
where you would be the registered owner of the Ford 6 0. And when you say on St. Thomas, is it on
F-250? 7 actual St. Thomas, or Is It on Little St. James?
A. What year? a A. No, it's on St. Thomas. ft's a work vehicle.
9 0. 2006. 9 0. For whom?
10 A. I remember buying that car. I just - that 10 A. For the workers, for the island.
11 shouldn't be in my name. 11 MR. REINHAFIT: Be careful to answer his
12 0. What do you mean you remember buying that car? 12 question. I think his question is. is it on
13 A. I do a lot -- !do all the car purchases for 13 St. Thomas or Little SI. James island? Where
14 Mr. Epstein. I'm a car fanatic, so for years I've been 14 physically is the car, if you know.
is the car-shopper. I'm the car fanatic. 15 THE WITNESS: I don't know for a tact.
16 0. Okay. But these cars aren't classic vehicles. 16 BY MR. EDWARDS:
17 These are vehicles that are not being refurbished or 17 0. It's your understanding it's on St. Thomas?
18 anything, they're being driven wound town? 18 A. Yes.
19 A. No. but theyre fun. The new Range Rover is a 19 0. And when you say "the workers; what's going
20 nice car. 20 on on St. Thomas to where there's workers that need an
21 O. This Ford F250, that's a car also that's Palm 21 F-250?
22 Beach as you would say a Palm Beach car? 22 A. Just moving sand. I don't know the exact
23 A No. 23 detail for it.
24 0. That's a car that stays at your house? 24 0. What were you told about the need for this car
25 A No. 25 to be on St. Thomas?
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A. They need a work truck. 1 O. Okay. And by *Jeffreys boat; It was
O. To do what? 2 purchased with Jeffrey's money?
3 A. I don't know what the detail or the - you 3 A. That is correct.
4 know, what the job detail was for the truck. They just 4 O. Do you know how much that cost?
5 needed a work truck A. I think it was 60.000.
6 Q. So Jeffrey Epstein tells you they need a work 6 O. Do you know how much the Ford F-250 cost?
truck on St. Thomas and that's the only description that 7 A. Twenty-five, lYn guessing. ballpark.
s you're given? a O. Do you know how much the Jaguar X-Type cost?
9 A. Yes, to go purchase and get the best deaf I 9 A. 11,000.
10 can on a pickup truck, and that's what I did and for 10 O. Do you know how much the Mercedes-Benz CLK
11 some reason it got put in my name. 11 cod?
12 (Off the record discussion ) 12 A. 36.000.
23 BY MR. EDWARDS: 13 O. Do you know how much the Land Rover cost?
14 O. Whose money was used to purchase the truck. 14 A. 68,000.
15 You say you purchased the truck. I want the record to 15 O. Do you know how much tho Mercedes-Benz SIN
16 be clear whether yd.:Ye purchasing it with your money? 16 cost, that's yours. right? The Chevy Suburban is yours
17 A. No, this was wire-transferred. it was a I 17 as well?
18 don't remember how that - I think it was a wire is A. Yes, I remember how much those cost too.
19 transfer or a check was FedExed from the New York office 19 O. IS there another boat, 35•foot Donzl
2o to pay for that. Thal should not be in my name, Is what 20 powerboat, 1999?
21 rm getting at. certainly change that, but I 21 A. That's the one I thought you were talking
22 thought you were •• 22 about originally.
23 O. I understand that. 23 Q. That's the same boat?
24 A. No, rim being — yeah, I didn't. 24 A. That's the same boat.
25 MR. REINHART: There's no question. 25 O. Is there any other boat Mars registered in
206 208
1 BY MR. EDWARD$: 1 your name?
2 O. 34-foot JVC Powerboat, 2000, owner LSJ, LLC, 2 A. No.
3 registered to Larry Visosid. Do you know that? 3 Q. Did you know that in let me ask you this:
4 A. Yea 4 Do you have a 2003 Ferrari F75-M?
Q. You knew that that boat was registered in your 5 A. No.
6 name? 6 O. Any reason why the car is registered in your
7 A. It's registered to LSJ. It's Jeffreys boat 7 name and the asking price Is $159,000 being sold in Now
8 that we keep here in West Palm Beach. 8 York?
9 O. And do you keep It at your home? 9 A. That car is not registered in my name.
10 A. No. 10 O. If It's registered —
11 O. Do you know that the registration is 10 your 11 A. The ad is in my name.
12 home? 12 O. Why is the ad in your name?
13 A. It's used in my home address, yes. 13 A. Because I was trying to sell it.
14 Q. Why was that done? 14 O. Why were you trying to sell it?
15 A. We were eventually going to shlp it out to IS A. It was Jeffrey's car and we didn't want t:
16 St. Thomas for it to live, but Since Jeffreys here, 16 anymore.
17 we're keeping it in Florida• and when we ship the boat 17 O. Why wouki he put his pilot in charge of
is over, we will change title to the Little St. James 18 selling his Ferrari?
19 address. 19 A. Because I bought it.
20 O. What do you mean 'since Jeffrey's here we're 20 O. How much did you buy it for?
21 keeping it in Florida'? What does Jeffrey being here 21 A. 179.000. Now, when I say 'I bought le 4
22 have to do with keeping a boat that's registered in your 22 was his money. I was the one that negotiated it, to be
23 name and to your address -- 23 dear. It was his car for use in New York.
24 A. Well. I have access to use the boat, you know, 24 Q. Are you aware of the Zorro Trust winning an
25 here in Florida, but it's Jeffrey's boat 25 85 mitiondollar Power Bab lottery in 2008?
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A. No. 1 MR. REINHART: Mr. Edwards. ho needs to expand
MR. CRITTON: Say that again. 2 upon one earlier answer he gave when you asked him
MR. EDWARDS: The Zorro Trust winning an 3 II he knew anybody else who worked at the Florida
• 85 million-dollar claiming the ticket for ♦ Science Foundation.
85 million-dollar Power Ball ticket in 2008. 5 BY MR. EDWARDS:
THE WITNESS: No. 6 0. Okay.
BY MR. EDWARDS: 7 A. My Wife worked there. When you used the words
2 Q. Have you ever listed your employer as 8 'worked there* - or not referring to her as a past
9 Ghlslalne Air In making political contributions? 9 tense, but she worked there when it first opened
10 A. I may have. 10 answering the phones.
11 O. Did you know that you had made political 11 0. What's your wife's name?
12 contributions -- 12 A. Eileen.
13 A. Yes, I have. 13 0. How does she spell that?
14 0. -- listing your - 14 A. E-I-L-E-E-N.
is A. I needed a company name for that event, and I IS 0. Same last name as you?
16 had put Air Ghislaine. 16 A. Yes.
17 0. And NES, LLC wouldn't do? 17 Q. How long did she work there?
18 A. I didn't think of it at the time. 18 A. A month. maybe.
19 0. Did Somebody tell you to use Air Ghislaine 19 0. And she was answering the phones for the
20 rather than the company that has been paying you? 20 Florida Science Foundation?
21 A. No. 21 A. Yes.
22 0. You Just chose to use an employer that Isn't 22 Q. Do you have a good relationship with your
23 actually your employer, nor have they ever been? 23 wife?
24 A. I represent Air Ghislaine, JEGE and Hyperion 24 A. I think so
25 as chef pilot, so I consider those really the companies 25 0. You still don't know what tic Fiorida Sc ercc
210 212
that I work for and never really associated myself with 1 Foundation does?
NES. LLC as my realistic employer. So when I go to a 2 A. No, because she doesn't.
convention, an aviation convention, and somebody says 3 0. She doesn't know what it does either'
4 who do you work for, I use the name JEGE because that's 4 A. We never talked about it
the name of the Boeing company. 5 0. You never talked to your wife about what st),
0. But when I sit here and ask you who you work 6 did?
for, you give me a different answer. 7 A. No.
A. You're asking for the absolute correct answer. 8 MR. CRITTON: He knew she was answerirt:
9 which is where my paycheck comes from, which Is NES, 9 phones.
10 LLC. I probably have used that twice in 17 or 18 years 10 BY MR. EDWARDS:
11 as my employer. 11 O. Do you know of any other employees, trends,
12 0. Do you know ? 12 agents, relatives of Jeffrey Epstein who he places his
13 A. I know the name, yes. 13 property in their names, registers them In his names or
14 O. How do you know her? 14 anybody else?
15 A. I've seen her on the airplane a couple times. 35 A. Not to my knowledge. I don't know.
16 0. Somebody that you know to be involved 16 0. To your knowledge. you're the only person?
17 romantically or sexually with Jeffrey Epstein at any 17 A. I'm the only one I'm aware of.
is time? 18 0. And with respect to minor girls being on the
19 A. I don't know that. 19 airplane, that being under the age of 18, how many times
20 O. Are there any other cars, vehicles, items. 20 would you say that you have flown girls into the
21 ocher things that are registered in your name that are 21 country, Into the United States where you have given a
22 actually Jeffrey Epstein's? 22 date of birth to Customs of somebody on the airplane
23 A. No. You've actually covered them all and 23 that Is under the age of 18?
24 actuay shed light on some that I did not realize, like 24 A. I'd have to look at fright records to verify
25 that Ford. 25 or give you a correct answer. I don't know any to my
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213 215
knowledge at this point. 1 leave?
O. What Wight records would you have to look at? 2 A. Us as the crew.
A. The passenger manifests. 3 O. Okay. So if a massage table had ever been
0. Passenger manifests would have the date of 4 used, it would have been you and the crew who would have
birth on it? 5 been responsible for either taking towels or doing
A. No. It would have a name, but I don't have -- 6 something with the massage table?
0. But at some point in time you remember people, A. Absokitety.
minor date of births, coming Into the country and that 8 O. And if I understood your testimony, you never
9 being turned Over to Customs? 9 saw a circumstance rebate it appeared to you that the
10 MR. CRITTON: Form. 10 massage table had been used in any manner; is that
11 THE WITNESS: I don't remember anybody 11 correct?
12 transporting on the airplane from the country back 12 A. mat is correct. It stayed in the same
13 into the U.S. that was a minor, to my knowledge. 13 location since the day it was put on there.
14 BY MR. EDWARDS: 14 O. You were asked a bunch -- a number of
15 O. Okay. Within the country. minors flying - as questions about Mr. Epstein, Ill use this --
la A. I don't know. 16 Mr. Epstein is the person who (erected you generally
17 O. -- on a plane? 17 unless one of -• someone else who worked on his behalf
18 A. I don't know dates of birth. as called you and asked you to, say. set up a tine to leave
19 O. And any people that you knew to be minors on 19 or pick up luggage, et cetera. My question to you is
20 me airplane, were they always accompanied by parents or 20 this: Have you flown in the past for other private
21 were there minors on the airplane that you're aware of 21 individuals Ike Mr. Epstein. i.e., as distinct from a
22 that were not accompanied by parents? 22 cornraerclar?
23 A. I didn't know either way. I mean, people 23 A. Yes. I have.
24 would get on the airplane and get off the airplane. I 24 O. And approximately have you Down for four,
25 could tell you there were times people would get on that 25 eve, six other private exhviduals over the years?
214 216
I (AIM even know were on the airplane. Our focus Is 1 A. Three. I had a short career as far as
2 up front. 2 transferring of owners.
O. Was there a massage table on the airplane? 3 O. In terms of transferring to the other owners,
4 A. Which aircraft? 4 separate and apart from Mr. Epstein, again, every
0. On any of them? individual is different, but was your relationship
6 A. The Boeing used to have a table on there. but 6 realty any different with any of those other
7 it stayed in the same spot and appeared to be never 7 individuals? That Is, you were in essence you were
B used a hired to perform a specific task: Fly an airplane to
9 O. Okay. So to the best of your knowledge, you 9 get from Point A to Pomt B and get the people there
10 have no knowledge of that massage table on the airplane to safely?
11 ever being used? 11 A. My first job, corporate-wise, was for an owner
12 A. Correct. 12 in Miami and I was hired as a pilot, but yet. I would go
13 MR. EDWARDS: I don't have anything else. 23 to his house and maintain a boat that was in the back of
14 CROSS (LARRY VISOSKI) 14 his house above and beyond my call of duty because I had
15 BY MR. CRT ON: 15 an interest in boats. Ws just something I like to do.
16 0. Mr. Visoski. I have just a few questions. You 16 But I always treated Mr. Epstein site any of the other
17 were just asked about a massage table on the — any of 17 prior orients that I had as owners. I knew that I was
le Mr. Epateiris airplanes and you said there was a massage 16 not afraid to work for a living, and they understood
19 table on the Boeing? 19 that.
20 A. Yes. 20 O. And it sounds like at least the tat owner
21 0. Okay. Was there always a massage table on the 21 that you worked for asked you to do eirnilar things that
22 Boeing or just for a period of time? 22 you've done for Mr. Epstein, such as take care of a boat
23 A. Just fora period of time. 23 or purchase a boat a maintain the boat?
24 O. All right. And who's responebie for cleaning 24 A. Sum, absolutely.
25 up the airplane after Mr. Epstein andfor the guests 25 a So your relational* with Mr. Epstein with
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. regard to if you bought boats or you bought cars on his 1
2 behalf. that's very similar to your prior experience 2 A. No. I have not
with working with another private individual? 3 O. Did Mr. Edwards, in approximately four hours,
A. That Is correct. 4 little over lour hours of questioning, ever ask you one
O. In terms of the records, the manner in which 5 question about. that you can recall?
you flew the plane or — I don't want to say flew the 6 A. Not that I recall.
plane, but in which you operated and maintained the O. Have you ever heard the name Did you
3 plane for Mr. Epstein are substantialy the same you've 8 ever know someone named M.?
9 done with other private individuals? 9 A. Never heard that name.
10 A. Right, exactly the same. We wouldn't treat 10 O. In approximately four-and-a-half hours of
11 Mr. Epstein any different than any prior — previous 11 questioning by Mr. Edwards, did he ever ask you about
12 jobs that I had. It's the same routine we carry over 12
13 and that's why we're good at what we do. We take care 13 A. No, he did not.
14 of the airplanes to the best of our ability. 14 O. In approximately the are you familiar with
15 O. Is your focus as the pilot, as the captain of 15 an Individual by the name of Jane Doe..)?
16 both of the airplanes when you took over that 16 A. I never heard that name.
17 responsibility a number of years age Is it your 17 O. In approximately four-and-a-half hours of
18 obligation to get the passengers there safely -- onboard 18 questioning by Mr. Edwards, did he ever ask you
19 and safely to the destination and then return? 19 questions about Jane Doll)?
20 A. Yes that was always job number one. 20 A. No, he cad net
21 O. And most of us have had I'd say a much more 21 MR. CRITTON: That's all I have.
22 substantial experience in flying commercial planes and I 22 MR. EDWARDS: I only have two questions based
23 rarely see in fact, I cant remember the last time 23 on what your testimony just was to Mr. Craton.
24 particularly after 2001 I saw the pilots coming back 24
25 into the cabin shaking hands and helping distnbute the 25
218 220
1 snacks or liquids. Maybe I'm not on the same flights 1 REDIRECT (LARRY VISOSKI)
2 that some of the other lawyers here are, but I assume 2 BY MR. EDWARDS:
you fly commercial from time to time? 3 O. You said you had three other people that
A. Sure. 4 you've flown for?
O. Do you ever see the pilots interacting with A. Three other previous jobs. Pin trying to be
it. the people who are in the back of the airplane? 6 as accurate.
A. No, not at all. They stay at their station up 7 O. Those are private individuals?
P. front. a A. That is correct.
9 O. You got -- as the captain of the planes, when 9 Q. And who are those people?
10 you're flying, you have substantial responsibilities not 10 A. Herb Glimpsure In Columbus. Ohio. and Edward
11 only to the people on the plane, but as well to the air 11 Seltzer in Miami. And then the other was Tom Boyd. and
12 space which you're flying? 12 that was more of a Learjet charter, but he was the owner
13 A. Yes. 13 of five Leanets. Those are my only three jobs in my
14 O. Okay. By the way, we've been here about — 14 life.
15 for about an hour and ten we started about ten. It's 15 O. Also wealthy individuals?
16 now 3:30. Did you ever hear the name II.? Has 16 A. Big time.
17 Mr. Edwards ever asked you one question about..? 17 O. And did you know what they did for a living?
18 MR. EDWARDS: Is the question have you ever 15 A. Those I 6:4 yes.
19 heard of her or did I ask any questions about her, 19 O. And did you ever go visit any of those people
20 or did you ask both questions and give the same 20 in jail?
21 answer? 21 MR. CRITTON: Form.
22 MR. CRITTON: 111 break them down. 22 THE WITNESS: I Mow my first Individual had
23 MR. EDWARDS: It doesn't matter to me. 23 trouble with the taw after I had left !don't
24 BY MR. CRITTON: 24 remember what It was pertaining to; but no. I never
25 O. Did you ever meet an individual by the name of 25 visited any el them in jail, no. sir.
Toll Free: 866.709.8777
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ESQUIRE 4440 PGA Boulevard
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EFTA01110381
Larry Visoski October 15, 2009
221 223
BY MR. EDWARDS: 1 CERTIFICATE OF OATH
2 O. Even the one who had trouble with the law, you 2 THE STATE OF FLORIDA
I didn't go visit him In jail? 3 COUNTY OF PALM BEACH
4
A. No. I did not.
5 O. And did any of them put vehicles or other 6 I, the undersigned authority, certify that
boats or anythkig else In your name? 7 LARRY VISOSKI personally appeared before me and was duly
A. No. sworn on the 15th day of October. 2009.
O. Okay. Any of those people ever deed any 9
9 property or acres or anything kke that to you? 10 Dated tree 22nd day of October, 2009.
10 A. No. 11
11 O. Did any of those people ever hire your wife 12
13
12 for employment?
14
13 A. No.
14 O. And your attorney, is that your attorney paid 15
15 for by you, or is this somebody that's hired by Jeffrey Wendy Beath Anderson, APR, CRR. FPH
16 Epstein? 26 Notary Public State of Florida
17 A. It is somebody that is hired by Jeffrey My Commission Expires: 9/202013
18 Epstein. 17 My Commission No.: DD 906647
19 MR. EDWARDS: Okay. 18 Job 0127542
20 16
MR. CRITTON: One follow-up to your question.
20
21 RECROSS (LARRY VISOSKI) 21
22 BY MR. CRITTON: 22
23 O. With regard to the private Individuals that 23
24 you worked for prior to Mr. Epstein. what was the 24
25 lOngest period of time that you worked for those? 25
222 224
1 A. The longest period of time was five years and 1 CERTIFICATE
2 THE STATE OF FLORIDA
2 the shortest being two years. 1 COUNTY OF PALM BEACH
3 MR. CRITTON: Thank you. 4
I. Wendy irreaih Anderson. Certified RealSrur
MR. EDWARDS: Well order. Reporter and Notary Public in and lot the State ot
MR. REINHART: Well read. 6 Matta at large, do hereby eerily that I was
authorized lo and did report said deposition in
6 MR. CRITTON: Well take a copy, front page. • stenotype: and that the foregoing pages area true and
mini with Index. 00110011 transcription of my shorthand notes of said
a • depo900n.
(Witness excused.) 9 I further codify that said deposition was
9 (Deposition was concluded at 3:37 p.m.) taken at the re and place hereinabove set forth and
10 10 mat the taking of said deposition was commenced and
completed as hereinabove set ouL
11 11
12 I Wilber codify that I am not elomey or
12 Counsel of any of the parties. nor am I a relative or
13 employee of any attorney or counsel of party COntlt;c1,
14 13 alh Use action, nor am I financially interested in the
action.
15 14
16 The foregoing cerelicalion of this transcript
13 does not apply to any reproduction of the same by any
17 means unless under the (Erect control andfw direction
18 14 of the candying reporter
17 Dated this 22nd day of October, 2009.
19 14
20 19
20
21 21
22 Wendy Beath Anderson. RPR, CPR FPR
22
23 Job 8127542
24 23
24
25 25
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE as Mucosa. Gallo Catirom$
4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutIons.com
EFTA01110382
Larry Visoski October 15, 2009
225 227
DATE: Oalobar 22.2409 ERRATA SHEET
TO: LARRY VISOSIg Job 8121542 2 P4 RE:. VS. EPSTEIN CR. TM
ego Robert D. Cnnon. Jr.
sansolpt 3 IMPOSTOR OF, LARRY vISOSK1
IN RE: w_ Epees 4 TAKEN:10.15 09 JOB NO.: 127502
Please tete notoe that on Tursday. the 15th 5 DO NOT WRITE ON TRANSCRIPT • ENTER CHANGES HERE
Ce October. 2009. you gave your decoaten n the 4 PAGES UREA CHANGE REASON
atereederred mall At tat limo, you rid soh moue
signalize. It K nOW necessary mat you age you 7
depositort
As Newt* agreed io. IM panacea' we
be furnished to you hough your counsel. Please road B
de Cloning Instructions weNtly.
At Me end ot ma Wrealpi NY we trd an
10 errata sheet AS No read your deposition. any oranges 9
of cotreteons Met you wised make shoed be noted or 10
11 me errata sheet tang page and lire net& a said
&dna. CO NOT erne on to tramoryt Nell Once 11
11 you have read me transcript and noted any changes, be 12
we to sign and date the errata sheet and return mesa 13
I) page* to me.
If you do not road and sm. Me depose:on 1.4
If mein a mesonatte tie be_ 30 days unless Wen*e LS
drooled) the viral. which roe ;Wady bean &warned 16
15 to me ordering altoirey, way be tied with me Ced DI
the Cast If you win to WOW yotr signaturo. sign 1?
16 yaw name In ne blank at 'he bollom of to killer end 16 Please WNW me aired signed errata sheet to Ills
Mann it bus.
11 cake so that copies may be distr.:Mod to al panics
Very nuty yours. 19
18 Urtior penalty of piwOry. I declare that I hays read rry
19 20 depaatiOn and Mal m true and correct subject SO
Wendy Beath Anders* RPR. CRFL FPR any changes in bins or substance entered here.
20 ESOUIRE DEPOSITICN SERVICES. INC. 21
515 North Rag* Dem. Ft200
21 Wets Palw Boats Florid* 33401 22 DATE:
22 I do hoteby new my Dreamt 23
21 24 SIGNATURE OF DEPONENT:
24 LARRY vISOSKI
25 23
226
1 CERTIFICATE
2
3 THE STATE OF FLORIDA
4 COUNTY OF PALM BEACH
I hereby certify that I have read the
6 foregoing deposition by me given, and that the
7 statements contained herein we true and cooed to the
8 best of my knowledge and belief, WAR the exception of
9 any corrections or notations made on the errata sheet.
10 done was executed.
11
12 Dated this day of
13 2009.
14
15
16
17
18
19 LARRY VISOSKI
20 Job #127542
21
22
23
24
25
0 Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE AltuadalettIOGSPARY
4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
EFTA01110383