EFTA01247021

-4 Condensed Transcript IN THE CIRCUIT COURT OF THE 15Th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA E. Plaintiff, vs. Case No. 502008CA028051 XXXXMB AD JEFFREY EPSTEIN, Defendant. DEPOSITION OF LARRY EUGENE MORRISON TAKEN ON BEHALF OF THE PLAINTIFF VOLUME I Pages 1 to 200 October 6, 2009 10:55 a.m. Jennifer DiLorenzo, court reporter Toll Free: Facsimile: S Suite 1300 515 East Las Olas Boulevard ESQUIRE • Al tas4trOblioCeropOn> Fort Lauderdale, FL 33301 www.esquiresolutions.com CONFIDENTIAL 3501.150-002 Page 1 of 92 EFTA_00068793 EFTA01247021 • • • 3501.150-002 CONFIDENTIAL Page 2 of 92 EFTA_00068794 EFTA01247022 Larry Eugene Morrison - Volume I October 6, 2009 1 3 • 211 TUR CIRCUIT COURT OP TER 15111 JWICJAL CIRCUIT IX AMU FOR PALM SEAM COUNTY. FLORIDA MAKE I Pages I to 200 2 3 4 APPEARANCE OF COUNSEL On WWI of the Defendant ATTERBURY. GOLDBERGER a WEISS BY: JACK MAN GOLDBERGER. ESO . 250 Ausbaban Avenue Suite 1400 s . FL 33401 Plaintiff, 6 Case No. 502000C11024051 /0703111 AD On bead of the DeiceOwe by 1444410TIE: JEFFREY EPS/811I. BURMAN. CRITTON. LUTTER & COLEMAN Defendant. 9 BY: MICHAEL J. PIKE. E90.. SIS N. Reeler Drive 10 Suite 400 IMPOSITION OP .F133101 LARRY Puma Pomace 11 TAKEN ON OEMAL7 Of THE PLAINTIFF October 6. 2009 12 10,55 4.e. . 2:20 .n. 13 On behalf of the Aeneas: 14 LAW OFFICE OF BRUCE E. REINHART IS BY: BRUCE E. REINHART, ESO.. One Gavle» Center 16 250 S. AUSIrtien Avenue Suite 1400 Jennifer Ditonne°. court reporter 17 acn, FL 33401 10 19 20 21 22 23 24 25 2 4 • 4 A On beret dew Plante I40114STEIN. feet COUNSEL OT 6 ADLER BY: BRADLEY J. EDWARDS LSO and MICHAEL HEELER. ESO . 401 East Las am Elooleverd 1 2 3 4 WITNESS: INDEX OF EXAMINATION LARRY EUGENE MORRISON Page Sum IMO 6 DIRECT EXAMINATION B. FL 33394 By Mr. Edwards *5 7 CROSS-EXAMINATION a *190 On WW1 cpt Mew% a By Ms. Ezell 9 9 CROSS-EXAMINATION MERUELSTEIN 6 HOSIOVATZ. By Mr. Wilds 0195 10 BY: JESSICA D. ARBOUR. ATTORNEYAT.LAW, 10 18205 Biscayne Boulevere CROSS-EXAMINATION 11 See 2216 11 By Mr. Pike *196 12 FURTHER REDIRECT EXAMINATION By Mr. Edwards 8199 13 14 On bete d 13 ef 14 leNecee: 15 POOHURST ORSECK PA 15 14 BY: KATHERNE.A. &ELL ATTORNEY-AT.LAW. 25W. Page« Seem 16 INDEX TO EXHIBITS 1 17 Ptautfts 19 18 E.101bIt Description Page :9 On Whaled tpe by IMPIzewle 19 1 Twenty-four pages of 'LIEGE. Inc.. 20 Passenger Manifest' ii198 LAW OFFICE OF ROMP) WIWTS. PA. 20 21 BY: IIICHANDWLUTS. ESC.. 21 2290 ICIP•Avenue H. 21 se. 404 22 33631 21 24 (Plaintiff's Composite 1 was attached to flic 24 original transcript and codes of the transcript.) 25 25 • Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.corn 3501.150-002 CONFIDENTIAL Page 3 of 92 EFTA_00068795 EFTA01247023 Larry Eugene Morrison - Volume I October 6, 2009 • 5 7 2 3 4 Deposition of LARRY EUGENE MORRISON October 6, 2009 THE REPORTER: Do you swear the testimony 1 2 3 4 You know, it was a business decision made somewhere. O. What does the company do? A. What? The company? It's just a holding company. I think, for the aircraft. It's not -- I • 5 you're about to give will be the truth, the 5 don't believe ft to be a money making company or a 6 whole truth. and nothing but the truth so help 6 real corporation. 7 you God? 7 O. You're saying 'for the aircraft.* I'm THE WITNESS: So help me God. 8 interpreting that to mean you're talking about one 9 9 aircraft. 10 LARRY EUGENE MORRISON, having been first 10 A. Correct. 11 duly sworn, was examined and testified as 11 O. Does that mean there's one or there's more 12 follows: 12 than one? 13 DIRECT EXAMINATION 13 A. There's more. Ho owns more than one, but 14 BY MR. EDWARDS: 14 just one is JEGE or -- 15 O. Tell us your name. 15 O. And the aircraft that he owns, how many of 16 A. Larry Morrison. 16 those do you either service ancifor ride on? 17 O. And. Larry. where aro you employed right now? A. I used to. I haven't been -- Actually, I 18 A. For JEGE. 18 stepped back from being physically Involved, just 19 O. What's JEGE mean? 19 now I lust do paperwork - and it was February of 20 A. Its the aviation flight department for 20 2007. So I haven't actualy physically been on the 21 Mr. Epstein. and my primary job * Dankjold Reed 21 airplanes other than I will lake the Boeing for 22 Aviation. 22 maintenance. 23 MR. REINHART: Spell A 23 O. Since it seems like we've kind of skipped 24 A. D-A-N-KJ-O-L-D. and then the second word 24 ahead from 2001 to 2007, am I right that your first 25 is Reed, R-E-E-D, Aviation. Its a corporate flight 25 involvement with Jeffrey Epstein of any way, shape, or 6 8 1 2 3 4 department. O. What do you dote him? A. Director of Maintenance. O. Okay, so you maintain his planes .- 1 2 3 4 form was 2001? A. That's Correct, yeah. O. You didn't meet him before that. A. I had met him. He was a -- He was an • 5 A. Correct. 5 associate of my previous boss. 6 O. should something go wrong? 6 Q. Who's that? 7 A. Correct. Yes. Yep. 7 A. Mr. Wexner. O. Do you also -- 8 O. Leslie Wexner? 9 A. For maintenance. 9 A. Yes. 10 O. Do you also fly on his planes? 10 O. How do you know Leslie Wexner? 11 A. On Mr. Epstein's? 11 A. I woiked for Limited Stores for 12 years. 12 a Yes. 12 O. Doing what? 13 A. I used to. I was a flight engineer -- 13 A. Essentially the same thing - aircraft 14 O. Okay. What.. 14 maintenance for their corporate flight department and 15 A. on his 727. 15 flight engineering on the 727. 16 O. When you list your company - JEGE? 16 Q. How many aircraft did Leslie Wexner have? 17 A. Yes. Yeah, it's just initials. It's an 17 A. Well none that I know that he had 18 ISC or heeding company. 18 personally, but the corporation had - the flight 19 O. How long has that holding company been around. 19 department operated • we had three Gulfstreams, two 20 If you taw? 20 Hawkers, and a 727. 21 A. Since -- I think it was developed when I 21 O. What was the name of his corporation that 22 came with the airplane • 2001. 22 maintained the aircraft? 23 O. Whose idea was it for that to come about - was 23 A. For Limited Stores? 24 it yours? Was it his? 24 O. Yes. 25 A. On, no, no, somewhere -- It wasn't mine. 25 A. It was just It was called Limited - 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Ofas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutions.com 3501.150-002 CONFIDENTIAL Page 4 of 92 EFTA_00068796 EFTA01247024 Larry Eugene Morrison - Volume I October 6, 2009 9 11 • 1 2 3 4 Limited Flight Department. O. And do you know him personally then - Leslie Wexner? A. Yeah. I had met him. of course, you know. 2 3 4 O. Yes. A. Aircraft technician. O. Which entails what? A. Maintenance of any or all of the aircraft I met him. I used to do aircraft completions for 5 operated by the flight department and some flight 6 him, so which would involve personal meetings. 6 mechanic duties. 7 O. When did you first meet Leslie Wexner? O. What kind or airplanes? A. 1988 was when I hired on, so I don't A. Gulfstreams, Hawkers. 9 remember the month. 9 O. How big is the Gulfstrearn? 10 O. How did you gel that fob? 10 A. Fifteen passenger - 15 to 17. 11 A. Through word of mouth and, you know. I 11 (Mr. Goldberger exited.) 12 worked • I lived in - been in aviation for years in 12 BY MR. EDWARDS: 13 Columbus. 13 O. What did Wexner use the Gullstream for? 14 O. Well, I mean. Leslie Wexners an important 14 A. They were division airplanes, mostly. 15 person, right? I mean, he -- 15 O. And the other airplane you named • what did he 16 A. Correct. 16 use that for? 17 MR. GOLDBERGER: Form. 17 A. Same, same. 18 BY MR. EDWARDS: 18 O. Any idea why he had two planes? 19 O. He's somebody who owns my understanding - 19 A. Well, I mean, yeah, we used them - they're 20 Limited, Victoria's Secret? 20 a tool. It wasn't tam. II was a large Fortune 500 21 A. Well, he doesn't own them. He's Chairman. 21 company. They use them as tools to You know, 22 you know. 22 Limited has control over 60 percent of their 23 O. Chairman of -- 23 manufacturing processes, plus, you know, what, 1200 24 A. Yeah. He doesn't personally own it. Its 24 stores, or whatever, throughout all their divisions. 25 a publicly held company. 25 I mean, when you say *Limited.' its not 10 12 • 1 2 3 4 O. Where were you prior to any involvement with Leslie Wexner? A. I worked for Red Roof Inn True Sports Flight Department. 1 2 3 4 just Limited, its Victoria's Secret and it was Express and Lemers and Henn Bendel's and all of that back then. so. I mean -- O. So - 5 O. How did that position lead you to Leslie s A. we moved a lot of passengers to keep Wexner? 6 those stores for the retail business. 7 A. Well, it was always known that Limited 7 O. And by 'passengers,' do you also mean clie-is 8 Flight Department was one of the best jobs in of his? Columbus and, actually, several other people that 9 A. That I don't know. No. Mostly we lust 10 were already there knew me from previous jobs and 10 dealt with upper echelon, you know, people in the 11 education - we went through aircraft mechanic, or A&P 11 retail businesses from -- 12 school, together - so when the position became 12 O. Such as whom? 13 available they pointed to me and - absolutely. It 13 (Mr. Goldberger entered.) 14 was a fine organization. 14 A. Can't even remember names, but it would be 15 O. So did Mr. Wexner approach you or did you 15 We would take buyers to Europe in the spring and 16 apply to him or how did that work? 16 fall. They would buy samples and bring them back to 17 A. Oh, no, no, no. It's -- No. He wouldn't 17 analyze for marketing. We would hire -- We would — 18 be involved in that type of activity. You apply to 18 Division heads, when they would do store shops and. 19 H.R, and you interview with the Director of 19 Real Estate, we take Real Estate out when they were 20 Operations or the Chief Pilot. You know. he 20 looking for new real estate. 21 w0ukInt 21 O. While you were working back in BI3- Well, 22 O. So you start with Wexner in 1988. 22 how long overall did you work with Leslie Wexner and/or 23 A. Yes. 21 his companies? 24 O. What do you do for him then? 24 A. Well, '88 through when I came hero in 25 A. What ced I do for him? 25 January of '01. • 0 Toll Free: Facsimile: Suite 1300 ESQUJ.0.4E.1 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com CONFIDENTIAL 3501.150-002 Page 5 of 92 EFTA_00068797 EFTA01247025 Larry Eugene Morrison - Volume I October 6, 2009 13 15 1 2 3 4 O. Why the change? A. It offered an opportunity -- Well, one was I enjoyed flying - and the 727 was being replaced by a BBJ, which is a two-man airplane. not a three-man I 2 3 4 aircraft. I mean, whatever a takes to keep a corporate flight department operating. O. Did you know back then of his relationship. it any. with Jeffrey Epstein? • 5 airplane three-pilot airplane - and it gave me the k Not immediately. no. 6 opportunity to become a Director of Maintenance. and 6 O. When is the first time that you know of a 7 it was a challenge. You know, bringing upstarting 7 reputation or a relationship between Wexner and Epstein' 8 an airliner on a private ticket or a VIP ticket is e A. Would have had to probably be around maybe 9 really challenging, and I enjoy the challenge of 9 '98,'99. 10 world% arid developing the program and stud. 10 O. How do you become aware that they know ono 11 O. Well, my understanding. Leslie Wexner Is 11 another? 12 generally - he's in Ohio. tight? 12 A. Because Jeffrey. every one That's when 13 A. No, he's got other places. I mean -- No. 13 I became a flight engineer on the Boeing. and every 14 he's like anyone, he's - in hiS Category - he's got 14 once in a while Jeffrey would ride on the Boeing. 15 multiple homes and — 15 that's all • that's all I knew. 16 O. Well, when you would maintain his aircraft, 16 O. How ckd 4 come about that he would nde on 17 would that be in Ohio -- 17 Wexners Boeing? 18 A. Yes. We were based -- le A. They were business associates, I think. 19 O. or elsewhere? 19 O. As far as you knOw, they were business 20 A. We were based at Lane Aviation. 20 associates. 21 MR. REINHART: HOld on one second. You 21 A. Right. 22 have to let him finish asking the question 22 O. Did you understand the business retationsh-p 23 before you answer. 23 between the two? 24 THE WITNESS: Okay. I'm sorry. 21 A. Web, I believe it's pubic knowledge 25 BY MR. EDWARDS: 25 that, I think, Jeffrey managed Mr. some of Mr. 14 16 1 2 3 4 O. I'm sorry, have you ever had your deposition taken before? A. No. O. You definitely never had your deposition taken 1 2 3 4 Wexnees funds. O. Is that something that Mr. Wexner told you? A. No. O. Is that something that somebody of Mr. • before while somebody else is trying to eat at the same 5 Wexner's organization would have told you? 6 time they're trying to ask the questions - that's very 6 A. No. 7 bizarre. 7 O. Is that something that Jeffrey Epstein told 8 A. Yes. yes. a you? 9 O. I meant to do this before I got here. But, 9 A. No. 10 regardless. Ill wail until you finish your answer before 10 O. Is that just reading articles that speculate 11 I ask my next question; you do the same thing. 'Uh.huh' 11 as to the business relationship between the two or do you 12 or •uh-uh,' they kind of look the same on the record, so 12 got something more for me? 13 try to give us a'yes' or to' or something we 13 A. No, it's just it's speculation and, you 14 understand. 14 know, what I've read. you know. 15 A. Alright. 15 O. I mean, like you say, to me ifs common 16 O. II I ask a question that was a bad question or 16 knowledge -- 17 something you don't understand ive asked bad questions 17 A. Right. 18 before • say. 'I don't get it' I'll ask a better 18 O. But irs only because of what I've road. I 19 question. 19 don't have a specific person that I could cite to to say 20 A. Okay. 20 that do you? 21 O. You were working with Leslie Wexner. You got 21 A. Right. No, just - just periodicals. 22 the job there starting in 1988. On a day-to-day basis. 22 O. What's your understanding of the persona 23 what would you be doing? 23 relationship, if any, between Wexner and Epstein' 21 A. Maintenance, aircraft maintenance, 24 MR. GOLDBERGER: Form. 25 tracking of aircraft maintenance. cleaning of 25 A. Don't know. 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com 3501.150-002 CONFIDENTIAL Page 6 of 92 EFrA_00068798 EFTA01247026 Larry Eugene Morrison - Volume I October 6, 2009 -19 17 19 • 1 2 3 4 O. Did you ever know of a time -- And I may be asking a question that would just be completely outside of your knowledge. so lot me back up. Have you ever stayed at Leslie Wexner's house? 1 2 3 4 O. Have you spoken personally with Mr. Wexner? A. On bus:Mess issues, yes. O. Business Issues related to your work on his airplanes? A. No. A. Correct. 6 O. Do you know where his house is? 6 O. Have you spoken to him on any other Issues 7 A. Yes. 7 that don't involve business relationships with his 8 Q. Do you know what the address is in Ohio? e airplanes? 9 A. ND. I just know the City. 9 A. No. 10 O. Do you know who he lives with? 10 O. Because you're hired basically for that 11 A. Yes. 11 purpose. so that's kind of how you deal with him. 12 O. Who is that? 12 A. Yeah. Ifs I'm an employee and he's my 13 A. His wife and Children. 13 employer and I only deal with him, you know. en 14 O. What's his wile's namo? 14 issues that involve maintenance. 15 A. Abigail. 15 O. I think I probably knOw the answer to the next 16 O. Abigail Wexner. and he has three or four 16 question, but just in case I don't, do you knOw any of 17 daughters. ngM? 17 his personal friends people that he would hang out with 18 A. No. He's got a son. M . and two l8 on a social level - being Mr. Wexner? 19 daughters. I think. 19 A. Through my business ties, yes. yes 20 O. A son and two daughters. 20 O. Who's that? 21 A. I don't know. See, that was back in 2001. 21 A. I'm hying to remember - You have to 22 I don't know what they have - it they have more kids 22 remember its been several years. 23 now. 23 O. Right. 24 O. Okay. Did you ever hew any information that 24 A. He was friends with the Tuckermans. 25 he was homosexual? 25 O. What's Mr. Tuckerman or Ms. Tuckennan's names? 18 20 • 1 2 3 4 A. No. O. Being Mr. Wexner. A. No. O. My Indication to you that he may be 1 2 3 4 A. Ms. - I cant. I always addressed them by their proper name. O. Do you know what they do? A. They owned an optical company - opticians. 5 homosexual or bisexual? s They were high school friends from Mr. Wieners high A. Absolutely not. 6 school days. 7 O. Have you heard any Information that he and Mr. 7 O. In Ohio or New York? 8 Epstein were involved sexually with one another? 8 A. He went to high school in Bexley. 9 A. Oh. no. no. 9 O. Bexley. Ohio. 10 O. Would that surprise you? 10 HaS he ever discussed with you how 11 A. Absolutely. 11 longstanding the relationship is between himself and Mr. 12 O. And Mars only because you know him and you 12 Epstein? 13 know Mr. Wexner and you don't see the two together. 3 MR. GOLDBERGER: Form. 14 A. Correct. 14 A. I don't understand. Can you rephrase il? 15 MR. GOLDBERGER: Form. 15 O. Wet you know that at some point in time 16 A. Weil — 16 You started working with him in 1988. The first time. 17 17 according to my notes. that you became aware Mat he was 18 A. Go ahead. 18 friends or acquaintances with Mr. Epstein was V8 - 19 MR. REINHART: If you need to answer, 19 almost ten years later. 20 answer the question. 20 A. Right. 21 A. Yeah. No. I saw him with Sharon, which 21 O. After you became aware that Mere was that 22 was his previous girlfriend before he met Abigail. 22 relationship. whether business or otherwise, did he ever 23 O. Right. 23 speak to you about how long he had known Mr. Epstein? 24 A. No. There was never any hint or anything 24 A. Oh. no. no. 25 Mat I would even conceive that. 25 O. So as far as you were concerned. 1998. when Toll Free: • 0 Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutiOnS.COrn 3501.150-002 CONFIDENTIAL Page 7 of 92 EFrA_00068799 EFTA01247027 Larry Eugene Morrison - Volume I October 6, 2009 21 23 1 2 3 4 you found out there was a relationship with Epstein. it could have very well started then. A. Yes. O. Aside from aircraft technician and taking care 1 2 3 4 O. Who were some of the pilots? A. Tim Staley. Jim Taylor. They've had some tumover too. I don't know who all is still there because retail is down. • 5 of Mr. Wexner's aircraft back in the '80s and. I guess. 5 O. Was Larry Visoski a pilot used by Leslie 6 early '90s, did you have any other personal involvement 6 Wexner at any time? 7 with him? 7 A No. 8 A. Just on aircraft completions. 8 O. How about David Rodgers? 9 O. And when you would speak with him, would that 9 A. No. 10 be over the telephone, at the airport, at his private -- 10 O. Are those names you're familiar with? 11 A. It would usually be al the corporate 11 A. Yes. 12 office. 12 O. Those are names you're familiar with how? 13 O. Al the corporate office? 13 A. I flew with them when I was flying for Mr. 14 A. At he corporate office. 14 Epstein. 15 O. Can you tell me the address for his corporate 15 O. So there's no real, other than yourself -- 16 CAM? 16 Well, tell me if I'm wrong: I understand that you did 17 A. No, I can't 17 some work for Mr. Wexner related to his aircraft and you 18 O. If I requested that from your attorney, would 18 did some work for Mr. Epstein. which we haven't yet got 19 you be able to got that information? 19 to. but you did some work for him too. Are there any 20 A. Well, I mean, I imagine it's public 20 other people that have that type of relationship with 21 knowledge • wherever - it's at the Limited. 21 both pathos? 22 O. And that's where you would meet him • at the 22 A. No. I'm sorry, resay that. 23 Limited? 23 O. Okay. You've already told us that you were 24 A. Yeah. 24 the aircraft technician for Mr. Wexner. 25 O. And how often was • you know, I know that 25 A. One of them. One of several, yes. 22 24 1 2 3 4 we're talking about 15. 20 years ago - how often was Mr. Wexner personally al that location at the Limited offices? A. I have no idea. 1 2 3 4 O. One of them. Then you also have knowledge about Mi. Epstein and some relationship with Mr. Epstein. A. Correct. O. Are there any other pilots. aircraft • O. But any time you needed to talk to him. that's 5 technicians, people like that that you know of to have a 6 where he would be? 6 relationship with both Mr. Wexner and Epstein? 7 A. Yeah, and I usually went to Charlie 7 A. No. no. 8 Hinson. 8 O. Do you knew how Mr. Wexner met Mr. Epstein? 9 O. Who's Charlie Hinson? 9 A. No. 10 A. He was the president of the stores. He 10 O. How long - if you started in 1988 how long 11 basically was my go-between for these aircraft 11 did you slay with Mr. Wexner and/or The Limited? 12 completions for the design. 12 A. January of YR. 13 O. And you mentioned the Gullstream as an 13 O. Why did you stop? 14 aircraft Did you also serve as a technician for other 14 A. Because what we were talking before, you 15 aircrefts that were owned by Mr. Wexner? 15 know, I wanted to continue flying. They bought a 16 A. Right but not Mr. Wexner. They're owned 16 BBJ. which is a two-pilot aircraft, and I wanted to 17 or operated by Limited Stores. 17 continue flying. Mr. Epstein bought the 727 and 18 O. Limited Stores? 18 offered me a position to continue flying and, you 19 A. Right. Yes. 19 know, basically sot up the airplane for his flight 20 O. What did you do for them? 20 department because they hadn't had any previous large 21 A. Same maintenance. 21 aircraft experience. 22 O. Did you ever fly in them? 22 O. I missed something. It wasn't your fault, it 23 A. On the Gullstreams in the early days we 23 was mine. 24 used flight mechanics, especially on international 24 The Gulfstream that you were talking about. 25 flights. 25 did you used to fly that as well as being a flight O Toll Free: Facsimile: Suite 1300 • n ESQUIRE rtfaaa 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com 3501.150-002 CONFIDENTIAL Page 8 of 92 EFTA_00068800 EFTA01247028 Larry Eugene Morrison - Volume I October 6, 2009 25 27 • 1 2 3 4 technician? A. No, no. O. Okay. A. You don't have to have a flight a 1 2 3 4 O. Do you know why Epstein chose to buy that particular 727 rather than one of the other million 727s that are made? MR. GOLDBERGER: Form. • pilots certificate to be a professional flight 5 A. Because it was probably the finest one out 6 engineer. I've got a turbo a (fight engineer turbo 6 the 7 jet rating, but you don't have to have a commercial 7 O. Why? 8 ticket as long as you • the FAA recognizes your heavy 8 A. -- in all honesty. It's got a fully Paged 9 aircraft maintenance experience. 9 STC interior with EMS cockpt. and Limited's 10 O. So you're saying that if the FM recognizes 10 reputation on the way that we maintained our aircraft 11 your heavy maintenance experience, I'm assuming that 11 - Its the best one out there. 12 means that you understand the ins and outs of airplanes 12 O. Describe for me the interior • I'm not talking 13 and you can work on them. 13 about the Epstein days, we're talking about the Wexner 14 A. On heavy high performance aircraft, yes. 14 days describe for me the interior of the aircraft, and 15 O. Then you can also fly them? 15 keep in mind that I've only been on a commercial aircraft 16 A. Sideways as a flight engineer. 16 where you donl see the pilots. there's a door, and then 17 O. Explain. 17 everybody, you know, there's just a bunch of seats where 3.43 A. On the older generation airliners there 18 everybody sits there. 19 was three pilots - there's a captain, a first 19 A. Correct. Right. 20 officer, and then the flight engineer is the 20 The aircraft You enter the airplane, 21 gentleman that sits sideways and maintains all the 21 it's got forward air slays. which most 727's don't, 22 systems. 22 so you enter the forward door on the left-hand side. 23 O. When you say. "sits sideways: okay, I have 23 the forward entryway vestibule, and there's a door on 24 a— 24 the left, which leads to the cockpit, and then 25 A. Literally, you're physically sideways in 25 there's a door on the right which leads aft to the 26 28 • 1 2 3 4 the cockpit O. So you're not looking at the people that were flying on the plane and you're not looking at the pilots. yottre actually literally sitting sideways. 1 2 3 4 forward salon. O. What's the forward salon? Sorry. A. Forward seating area. O. And is it set up basically the way that I'm S A. I sit sideways at a panel, yes. 5 picking it - in that there are 25 or 26 rows and they're 6 O. What's your job? 6 numbered A through E? 7 A. Maintain all the aircraft systems - the 1 A. No. no. its a corporate configuration. • hydraulffs, fuel management, pressurization. 8 O. Which means nothing to me, so help me. 9 environmental controls. 9 A. Picture a 600-mile an hour Winnebago. I 10 O. That's not done by the pilots. 10 mean, its got conference tables and divans and large 11 A. Now. 11 first class seating. 12 O. But if you've done that long enough and FAA is 12 O. Any various dividers throughout -- 13 aware of your credentials in that respect, then you also 13 A. Yes. 14 could be credentlaled to be a pilot as well? 14 O. -- to where there's a VIP room in the back or 15 A. Well, sure, yeah, yeah. If that's a 15 anything like that? 16 career choice you wish to take. 16 A. It's compartmentized (sic), yes. 17 O. And was that? 17 O. In what way? Descnbe it as specifically as 18 A. No, no. I was perfectly satisfied with my 18 you can. 19 position as a flight engineer and Director of 19 A. There's a forward salon, a mid galley 20 Maintenance. 20 the galley's in the mid - an aft • an aft salon, 21 O. What year did you say Epstein bought the 727 21 which is and then the aft stale room. 22 that was once owned by Wexner? 22 O. Who designed that plane? 23 A. I don't know when the actual transition 23 A. I can't remember who the actual designer 24 took place, but when I came - shortly around the 24 was. It was a Page interior, though. Page Avjet did 25 period that I came on board In . January of bl. 25 the installation. Toll Free: • 0 Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-00i CONFIDENTIAL Page 9 of92 EFFA_00068801 EFTA01247029 Larry Eugene Morrison - Volume I October 6, 2009 29 31 1 2 3 4 0. Who directed the design ot that plane? A. It would have been Mr. Wexner. I mean, it was -- The layout has not changed. 0. The layout has not changed; when you say 2 3 4 because obviously there's a lot - there's not that many -- A. Privately owned 7275. but this is As a matter of fact The Limilects current BBJ has a very • 5 that, you mean 'from the time that I first got in it and 5 similar floor plan. 6 I was under the guise of 'under the employment of 6 0. As Trump's? 7 Wexner to the time I've been on it since with Epstein. A. No, as the as our 727. Es the configuration is the same' 0. Who's 'our'? 9 A. Essentially, yes. We removed one chair 9 A. Mr. Epstein's. They didn't change a lot. 10 and one small table that was an annoyance and that's to It's - 11 it, but it's identical to what The Limited used. 11 O. Well, I thought that you had told me that the 12 0. Are there any blocked off areas to where if 12 727 that was once owned by Wexner is the 727 that's owned 13 you're standing in the middle of the plane you can't see 13 by Epstein. 14 certain areas of the plane" 14 A. It is, but what I'm saying is even their 15 A. There are pocket bulkheads. Yeah. there's 15 current airplane has the same layout - the BBJ. They 16 dividers between the sections. 16 put the same floor plane in the more modern airplane 17 O. How big aro these dividers and where are they? 17 0. Well, they dam have 10 put it there. It 18 A. Well, there's a divider - the forward 18 was already there. nght? 19 door, I told you, on the salon, then there's a pocket 19 A. No, no. no. When you buy these aircraft - 20 door on the forward side of the galley, a pocket door 20 even a Gullstream when you buy them its just a 21 on the aft side of the galley, there's a pocket door 21 green hull, there's nothing in them, and you can 22 between the aft salon and the office, and then 22 customize your interior. 23 there's another pocket door between the office and 23 0. I'm sony, we're miscanmunicating so.n8l to 24 Me state room. 24 and I m sure its on me. 25 0. Have you been on other 7275 before that are 25 MR. GOLDBERGER: Yes. it is 30 32 1 3 4 commercial airliners privately owned? A. Yes, yes. O. Have you noticed similar configurations to where there aro this many dividing doors or is this one 3 4 MR. EDWARDS: And l -m taking the blame for rght away. MR. REINHART: Take that. Ed. MR. EDWARDS: Alright • 5 that has more so than you've seen in the past? 5 BY MR. EDWARDS: 6 A. No. no, this is pretty atypical (sic). 6 0. My understanding - and please correct me when O. It's pretty atypical? 7 I'm wrong. because I knew I am - Wexner has this 727 and A. It's typical. 8 he designs it in a certain way. 9 0. It's pretty typical? 9 A. Uti-huh. 10 A. Yes. yes. O A . YAnd ee.then you come to work for Epstein-. 11. 0. So what other airplanes - 727s, or other major 11 12 airplanes - have you been on that have these types of 12 who buys the same 727. Your testimony, as 13 dividers? 13 I'm understanding It, Is: It's basically the same 800r 14 A. Trump. 14 plan as Wexners floor plan. To me, it should be the 15 0. Trump's airplane? 15 exact same because he bought the same plane. 16 A Yes. 16 A. No. he -- You're misunderstanding. 17 0. Why were you on Trump's airplane? 17 0. I figured. 16 A. Well, I know the crew and, you know, this 18 A What I was stating is You were I was 19 Is a small-knit community. There's not very many of 19 answering the question in regards to, 'Is this 20 them out there, so everybody in this world knows one 20 unusual to have thiS many compartments and closed 21 another to help one another out as far as — 21 doors and bulkheads and things?' 22 0. By 'there' -- 22 What I was trying to state was: NO, its 23 A. information-wise and stuff. 23 not unusual - because The Limited even Mod the 24 Q. By hhere aren't that many of these people out 24 Floor plan so wee in their old airplane that they 25 there' you don't mean there's not that many people • 25 sold to Mr. Epstein. They duplicated it in their new Toll Free: Facsimile: Suite 1300 • ESQUIRE Oa Altandwrall•Canpa 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 10 of 92 EFTA_00068802 EFTA01247030 Larry Eugene Morrison - Volume I October 6, 2009 33 35 • 1 2 3 4 airplane - see what I'm saying? That's all I was -- O. So they didn't keep the floor plan. They actually took it out and they restructured the floor plan to basically match that old floor plan. 1 2 3 4 had a very identical or very like floor plan installed in the new airplane. O. Coln Sorry, it's a strange business. 5 A. Well. no. When you -• When you buy a 5 It's — A. Okay? 6 Boeing business jet — 6 O. Tell me if I'm right: Mr. Wexner had a plane 7 Cy Yes. 7 that had a floor plan that apparently appealed to Mr. A. it comes with nothing inside. It's a 8 Epstein, so Mr. Epstein bought that plane. 9 tube. Nothing's in there. You design • have 9 A. Correct. 10 designers design your interior and then a fabricator 10 O. Mr. Wexner also liked that plane that he had 11 or a facility such as Page Avjet to install this 11 just sold to Mr. Epstein, so he built in a floor plan 12 Interior. 12 very similar to the one he just sold to Mr. Epstein 13 O. Right. 13 A. In his new aircraft. 14 A. What I was just trying to state was that 14 O. Brand new plane. 15 The Limited liked their old floor plan in the old 15 A. Correct. 16 airplane so well - it worked so well for them - that 16 O. Got it. We're on the same page now. 17 they duplicated it and had that same interior 17 A. Alright. 18 installed in the new aircraft • same floor plan 18 O. Took us a while to get there. 19 installed on the new plan. 19 A. Yeah, sorry. 20 O. So Epstein didn1buy the exact same plane. 20 O. I think it was my fault, honestly, but 21 He bought the same type of plane. 21 alright? 22 A. Well, more modem. He bought a 737. 22 A. It's an unusual process it you haven't 23 right. 23 been around corporate airplanes. 24 O. Got it. 24 O. I didn't realize that Mr. Wexner had a new 25 A. Right. 25 plane. 34 36 • 1 2 3 4 MR. REINHART: Hold on. BY MR. EDWARDS: 0. Totally understand now. MR. REINHART: Can you clarify - Mr. 1 2 3 4 A. Yes. O. Thars where I had a problem. How many times have you been on Mr. Wexner's airplane? Epstein or Mr. Wexner? 5 A. The new? 6 BY MR. EDWARDS: 6 MR. REINHART: Clarify which one you're 7 O. Mr. Epstein bought not Mr. Wexner's plane. 7 talking abaft. 8 A. No. 8 BY MR. EDWARDS: O. He bought the same type of plane that Mr. 9 O. Before you ever met Mr. Epstein. 10 Wexner had and modeled the floor plan -- 10 A. I can't say. I mean. over the years? 11 A. No. 11 O. Numerous times? 12 O. -- the same way that Mr. Wexner had it. 12 A. Oh, I was his flight engineer. You mean 13 A. That is not correct. 13 when I was still employed by him? 14 O. He bought, actually. Mr. Epstein -- 14 O. Yes. 15 MR. REINHART: Hold on. Distinguish -- 15 A. Yes. I was the flight engineer. I 16 Use names so we're very clear when you're 16 don't -- 17 talking about Mr. Epstein and Mr. Wexner. okay? 17 O. So as a flight engineer, every time the plane 18 A. Mr. Epstein bought Mr. Wexner's 727. 18 leaves the ground, do you leave the ground with it? 19 O. Okay. 19 A. No. We had another engineer also. 20 A. The actual airplane - bought it from him. 20 O. So what percentage of times do you leave the 21 Q. Which has a floor plan already in it. 21 ground in the airplane when the plane leaves the ground? 22 A. That we just discussed. 22 A. For who? 23 O. Alright. The floor plan's in the plane. 23 O. For Mr. Wexner. 24 A. Right. Mr. Wexner replaced the airplane 24 A. Probably one-third of the time. because I 25 that Mr. Epstein bought with a new airplane and he 25 was also the lead technician, so 1 had • 0 Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutIons.com 3501.150-002 CONFIDENTIAL Page 11 of 92 EFTA_00068803 EFTA01247031 Larry Eugene Morrison - Volume I October 6, 2009 37 39 1 2 3 4 responsibilities in the hangar. whereas the other engineer was a full time engineer O. And given the partitions that you've descnbed in this airplane, are you able to see what's going on 1 2 3 4 A. There is normally a passenger manifest. yes. O. A. Who creates the manifest? Probably dispatch. • 5 behind the doors of the various partitions of the 5 O. Dispatch? 6 airplane? 6 A. At Limited. 7 A. If the doors aro open or closed? 7 O. Do you know who that is? 8 O. Closed. 8 MR. REINHART: Can you give a time frame? 9 A. No. 9 Do you mean currently or back when he worked 10 O. Do you have any idea what's taking place in 10 mere? 11 there? It MR. EDWARDS: I'm talking about back when 12 A. No. 12 he worked there. 13 MR. GOLDBERGER: Form. 13 BY MR. EDWARDS: 14 8Y MR. EDWARDS: 14 O. Do you know who that was at dispatch? 15 O. When you're on the plane with Mr. Wexner. was is A. That would have been Diane Williams. 16 there a time that he had Well, let me put it this way: 16 0. Who does Diane Williams work for? 17 When anybody is a passenger on any of these private 17 A. Limited Flight Department. 18 planes, should there be logs of the names of the 18 O. Who does she report to? 19 passengers on the planes? 19 A. Tim Staley. 20 A. Not required, no. 20 0. Who's Tim Staley? 21 O. Are you ever specifically instructed not to 21 A. Director of Operations. 22 record the names? 22 O. For who? 23 A. That wasn't part of my duties. That 23 A. Limited Flight Department. 24 wasn't an engineers task, but -- 24 O. What does he then do with that Information? 25 O. Do you -- 25 A. I don't know. I don't know. 38 40 1 2 3 A. — no. not that I'm aware of. O. Who is assigned the duty of reporting the names of the people who are going to be transported on 2 3 O. Have you ever talked to Tim Staley? A. From Yes, yes. O. And what do you talk to him about? • 4 the airplanes? 4 A. Oh, we're - we're friends. We worked 5 MR. GOLDBERGER: Form. 5 together for years. I mean, I haven't talked to him 6 A. Captain. 6 since the holidays. 7 O. So have you ever been privy to conversations 7 O. Do you know where he is now? 8 where the captain is told by Mr. Wexner to record all of a A. To the best of my knowledge, stilt 9 the names of the people that are going to be on the 9 Director of Operations at Limited. 10 airplane' 10 0. Do you have a number for him? 11 A. Can't say. 11 A. Yes. 12 O. Sometimes? 12 0. Can I have the number, please? 13 A. I can't You know, I can't say. I can't 13 A. It's 14 remember what our policies were at the time. 14 0. Is that a work number? 15 O. I'm not asking policies. I'm asking: Have 15 A. That's the Flight Department. 16 you ever been around when the plot was being instructed 16 O. That's the best number to reach him at? 17 by Mr. Wexner • back in the late '80s, early '90s - to 1? A. Yes. 18 make sure that you record who's on this aircraft? 18 0. If I'm going to call him, that's the number I 19 A. I never heard Mr. Wexner address that, no. 19 call? 20 O. I moan. God forbid the airplane crashes, you 20 A. Correct. 21 would tike to know who's the on the airplane, right? 21 0. And was he always in charge of flight 22 MR. GOLDBERGER: Form. 22 directions? 23 A: Yes. 23 A. No. he was previously Chief Pilot. 24 O. Is there any way to determine who's on each 24 G. He was previously Chief Pilot for Limited? 25 particular night in case anything happens? 25 A. Same, yes. 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 wvatesquIresolutions.com 3501.150-002 CONFIDENTIAL Page 12 of92 EFEk_00068804 EFTA01247032 Larry Eugene Morrison - Volume I October 6, 2009 41 43 • 1 2 3 4 0. And he was promoted, I suppose, to Flight Director? A. Director of Operations. It's the department crew. Most small departments don't have 1 2 3 4 international. The only time we do international would be for Customs and Immigration. O. So if its an international flight -- A. For Customs and Immigration • for coming S &rectors until they start to grow. 5 and leaving the country. 6 Cr. And when he was Chief Pilot were you 6 O. then they require that names of 7 affiliated with the Wexner organization? 7 individuals — 8 A. Yes, I was a maintenance technician. 8 A. It would be names, passports, that kind of 9 O. And when you say somebody keeps flight logs. 9 stuff • normal. 10 Is it always Tim -- is his name Tim Staley? 10 O. Did you ever do any international flights 11 A. Yes. t.1 while employed by The Limited, Victoria's Secret, the 12 O. — Is It always Tm Staley who does that? 12 whole Wexner group? 13 0. No. I don't knOw where they go. honestly. 13 A. Yes. 14 and the system may have changed. 14 O. How many? 15 O. Okay. Are you -- 15 A. No way of knowing. I mean. rm • can't 26 A. I've been gone since -- 16 say. It's, like I say, years. but 17 O. Are you aware of any FAA policies to where 17 O. What years would you done its? 18 they need to know who's on the aircraft whenever It talks 18 A. Started flying as a flight mechanic in 19 off? 19 '89, and then started flying the Boeing in '99, so • 20 A. Not under Part 91 Operations, there is 20 to '01, so '89 to '01, basically. 21 not. 21 (Mr. Goldberger exited.) 22 O. Part what? 22 BY MR. EDWARDS: 23 A. Pan 91. 23 O. SO '89 to '01, if I wanted all of the flight 24 O. What does Part 91 say, as far as you know? 24 logs, who would I request those from - Tim Staley? 25 A. It's basically souls on board when you 25 A. Don't know. I don't know who -- 42 44 • 1 2 3 4 file a flight plan - that's the only thing you're required to do. When you file your flight plan you file souls on board. O. What does that mean, 'souls on board'? 1 2 3 O. What does Tim Staley do alter he maintains these records? A. I don't know. 4 O. He's never told you what he does? 5 A. In other words, living bodies on board. 5 A. No. 6 In other words, if you have • so if there's an 6 O. Certainly theyre kept on file somewhere, accident and you have four and you're transporting a 7 right? a cadaver, that they go to the accident scene and don't 6 A. I would assume. 9 find five bodies - think there were live fatalities. 9 O. What's the name of the company that owns the 10 0. So it's your understanding from what you need 10 airplanes? I know its affiliated with Wexner and all 11 to report are, 'I have five people on board.' 11 that, but what's the name of the company? 12 A. Correct, and that's for the flight plan. 12 A. Well, there were several companies. I 13 O. So there's no reason to say that, 'I have Joe 13 mean, the way corporate aviation fkght departments 14 Schmo on board? 14 are set up. [helm under holdings companies. 15 A. Not under Part 91, no. 15 O. I'll go with al of them. 16 0. That's doing something over and above. 16 A. Well. I don't know. They change. They 17 A. That's correct. 17 change sometimes by the year, sometimes -- I have no 18 O. You are aware, though, that there are certain 18 Idea what they're under now. 19 flight plans where they actually name individuals that 19 O. What were they under backln'88 20 are on the airplane? A. It was like -- 21 MR. GOLDBERGER: Form. 21 O. to the best of your memory? 22 A. No. 22 A. They change. I mean, every time we got a 23 0. I mean, you've seen that belore. 23 new aircraft, or whatever. they changed. They were 24 MR. GOLDBERGER: Form. 24 kke Northeast Holding, Southwest Holding, LLC • 25 A, No, nOl on NO plans, no - unless it's 25 Wilmington, Delaware, companies, which is standard • Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutlons.com CONFIDENTIAL 3501.150-002 Page 13 of 92 EFT,C00068805 EFTA01247033 Larry Eugene Morrison - Volume I October 6, 2009 45 47 1 2 3 4 for these, you know. O. Did Leslie Wexner ever tell you that he allowed Jeffrey Epstein to serve in some sort of capacity, representative capacity, for any of these 2 1 4 A. They were -- They were generated, but I don't know, you know, why - what the particular reasoning was fork. Do you know it Terry (gc) Staley would have 0. • 5 companies? 5 been the one to forward those flight logs to the FAA? 6 A. No. He would never say that to me 6 A. No, no, no. I -• They wore all lust tor anyways. no. 7 business use • not forwarded to the FAA. 0. What's the first time you ever saw Jeffrey 8 0. Okay. How -- 9 Epstein? 9 A. The FAA doesn't care about flight logs. to A. Can't say. I'm not sure. 10 0. How OW the FAA monitor when trial piano took 11 O. I think you saw him before you started working 11 off? 12 for him or with him? 12 A. Flight plans. 13 A. Oh. yeah, that's -- Where I first saw him 11 0. And wash your understanding that when the 14 was when I flew him on The Limited 727. 14 plane took off, the FAA was unaware as to who was ever on 15 0. What year do you think that was? is it? 16 A. It would have had to have been 16 A. Pretty much, yeah. They don't care about 17 0. Talking late '80s. early '90s? 17 names. When you file flight plate watt the flight 18 A. Late '90s. 18 service station or via electronically, all they care 19 O. Late '90s? 19 about is souls on board, contact information. flight 20 A. Yeah, probably - mid to late '90s. 20 routing, things like that. 21 0. Well, I mean, it you're taken over with 21 0. Are there time limits as to when the plane is 22 Jeffrey Epstein In, what, 2001 - 22 allowed to take off? 23 A. Correct. 23 A. Yeah. usually -- From what point? What do 24 0. - then you're talking late '90s is the first 24 you mean? Time of the day or - 25 time you see him? 25 0. Yeah. yeah. time of the day. I understand 46 48 1 2 3 4 A. Well, and I don't know exactly. I can't really say, really. 0. t won't hold you to N. his what 4 is. Mid to late '90s, it I wanted the flight logs 1 2 4 3 that there's some time where if it's too tate they can't take off, right? A. Only where there's a curfew on the airport - not all airports, no. No. airplanes can fly any • that have him on it, On the airplane, who would I S time unless that airport has a noise curlew or 6 Subpoena to get those records? 6 something, yeah. 7 A. I have no Idea. 0. Did you ever know of Wexner's plane to take 0. Are they turned into the FAA, to the best of 8 off after ten o'clock p.m.? 9 your knowledge? 9 A. Yes. Yeah. 10 A. No, the FM doesn't require them. 10 0. Were you ever on that plane when it did? 11 0. So FM does not get the flight -- Well. what's 11. A. Probably. yeah, yeah. 12 the point of even keeping these? 12 O. Were you ever on that plane when there were 13 A. Sometimes I think the IRS I mean, this 13 gds on the plane? 14 is on assumption, rm not even sure, but mostly for 14 A. Describe -- Define 'girls.' On the Wexner 15 like IRS tracking ford you have people that have 15 airplane? 16 dual homes, dual statehoods. or whatever. 16 0. Yes. 17 (Mr. Goldberger entered.) 17 A. There would be ladies and his daughters. le MR. GOLDBERGER: Can we take a time outs 18 I mean -- 19 (Shan break.) 19 0. Other than family members. 20 (Mr. Pike appeared via telephone to 20 A. There would be business associates. If 21 replace Mr. Goldberger.) 21. you're taring young women, yes, business associates 22 BY MR. EDWARDS: 22 from the **visions. 23 0. FAA flight logs - do you know why they're 23 0. Have you ever been on the plane when there 24 generated, how they're generated, 4 they were generated 24 were girlfriends of Leslie Wexner? 25 back in the Wexner days? 25 A. Only when Abigail • before his • became 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 14 of 92 EFTA_00068806 EFTA01247034 Larry Eugene Morrison - Volume I October 6, 2009 49 51 • 1 2 3 4 his bride. yes. O. How about after -- A. I moan O. she became his -- 1 2 3 4 O. Yes, with you on it. A. I can't — I canl say. O. Well, where do you remember going in it? A. Well, we would normally go to London, 5 A. it was Abigail. She was the only 5 Milan. Fans. I mean, mostly fashion areas and 6 girlfriend. 6 business business areas. 7 O. How about after Abigail? O. When you say 'fashion areas,' what do you e A. No. 8 mean? 9 O. Have you ever soon sox or sex-related 9 A. Well, retail. I mean, you know. design 10 instances occur on Leslie Wexner's airplane? 10 for clothing and stuff like that. 11 A. Absolutely not. We didn't even have 11 O. What was the purpose? 12 playing cards. He looked at the aircraft as a 12 A. I'm sure it was business. I have no Idea 13 business - a flying business office. 13 what the actual purpose was. I don't — 14 O. When you say 'playing cards' what do you 14 O. Did you get off the plane? 15 mean? 15 A. Well. of course. 16 A. Playing. you know. to -- 16 O. What did you do there? 17 O. Oh, playing cards. 17 A. Go to a hotel, eat dinner, wait to find 18 A. Yes, playing cards. 18 out when you're going to the next place. 19 O. So every time that you were on Leslie Wexner's 19 O. Were you ever on an international flight on 20 airplane, it was used strictly for business? 20 one of Mr. Wexner's planes that Jeffrey Epstein was also 21 A. Well, I don't know if it was used strictly 21 on? 22 for business, but there was no. you know, it was -- I 22 A. I can't say. I can't remember. 23 don't know what the purpose of the actual trip was. 23 O. maybe/ 24 but never saw, you know, anything. you know. 24 A. Possibly. 25 O. Was there over a time when you were -- 25 Cl. Do you remember any specific places that 50 52 • 1 2 3 4 MR. REINHART: Hold on. Were you finished? BY MR. EDWARDS: O. I thought you wore finished. 1 2 3 4 Jeffrey Epstein went while on that plane outside the United States? A. I can't remember. No, no. Like I say. I can't even remember it we took f for sure. 5 A. Yeah. I don't tmderstand. I don't 5 O. My time that you remember Jeffrey Epstein 6 understand that question. 6 being on the airplane, do you also remember Moro being 7 O. I'm going to clarify. Wore there ever times 7 girls on the airplane along with Mr. Epstein? 8 when you were on the plane and either Leslie Wexner 8 A. I can't I can't say. I can't remember. 9 ancVor other individuals went behind these various areas 9 O. When's the first time you remember seeing 10 that you could not see into? 10 Jeffrey Epstein? 11 A. Yes. Yeah. 11 A. Wel, like I say. I don't even remember 12 O. Do you know what they were doing in there? 12 the year. I can't oven pinpoint down to the year. 13 A. Probably sleeping. He would go to bed at 13 It was after • some time after I started flying the 14 night on the long trips, okay. 14 727. because that's the only exposure. 15 O. Arty time that more than one person went in one 15 O. Okay. I'm not going to ask you at all during 16 of these areas that you would not be able to see into? 16 this deposition to guess. I thought at some point in 17 A. Not that I'm aware of, but my exposure to 17 time you told me you remember seeing Jeffrey Epstein. 18 back Mere is not that. you know, is limited. 18 right? 19 O. How many times did you see Jeffrey Epstein 19 A. Yes. 20 ride that plane with Leslie Wexner? 20 O. In fact, you work for him now. 21 A. Not many, but I can't say exact. 21 A. Yes. 22 O. How many international flights do you remember 22 O. So at some point in time you saw him and you 23 that plane taking? 23 saw him for the first time. 24 A. Remember .- The airplane itself taking 24 A. Correct. 25 international? 25 O. When's the first time you remember Wang horn? Toll Free: Suite 1300 ESQUIRE •• Alezbuk•Gall•Camn 51S East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com CONFIDENTIAL 3501.150-002 Page 15 of 92 EFT/C00068807 EFTA01247035 Larry Eugene Morrison - Volume I October 6, 2009 53 55 2 3 4 It may not be the first time you saw him. When's the first time you remember seeing him? A. '99, somewhere in that area. 0. Alright. In '99 were you working for Leslie 1 2 3 4 Jeffrey Epstein helped to - I think, what you said was - manage Leslie Wexner's money? A. Some of his accounts, yes. I guess. 0. Why do you think that? • 5 Wexner or were you working for Jeffrey Epstein? 5 A. From what I've read in periodicals and 6 A. Leslie Wexner. 6 magazines. 7 Q. And do you remember the context in which you 7 0. You've read in what periodicals and magazines? 8 saw Jeffrey Epstein? 8 A. I think it was, what, Vanity Fair there 9 A. II was a flight. 9 was an article a couple years back, three or 10 O. What did Leslie Wexner ever tell you in terms 10 lour years back, and a New York magazine as I 11 of who Jeffrey Epstein was? 11 mentioned. 12 A. Never told me anything who Jeffrey Epstein 12 0. Why did you read the article? 13 was. 13 A. Well, obviously it was dealing with the 14 0. Did you ever ask? 14 gentleman that I was working for, so out of 15 A. No. 15 curiosity, you know. 16 0. Did you ever ask back in 1999 when you saw 16 0. Right. because people tend to be curious -- 17 this guy,1 wonder what he does•? 17 A. Right. 18 A. No. 18 0. right? But when I lust asked you who 19 0. Not even curious? 19 Jeffrey Epstein was and the relationship, you said, 1 20 A. No. Its not my place. I don't -- I 20 have no idea: implying that you weren't curious. But at 21 don't need to know or want to know what people's 21 some point in time you got curious as to who this person 22 associations are. 22 is, right? 23 0. Next lime you saw Jeffrey Epstein was when? 23 A. Who Jeffrey Epstein is? 24 A. I can't say for sure. 24 0. Yes. 25 0. Have you seen Jeffrey Epstein at Leslie 25 A. Well, yeah, when you're working for him 54 56 1 2 3 4 Wexner's house? A. No. 0. Never? A. Never. I've never 1 2 3 4 and he's in a magazine, you're going to road the article. 0. Okay, so at some point in time, bird you Google Jeffrey Epstein? • 5 0. Have you ever - 5 A. No, no. 6 A. •• been to Wexner's house. 6 0. Have you read the articles about Jeffrey 7 0. You've never been there? 7 Epstein? A. No. a A. Lately? 9 0. Have you ever known of Leslie Wexner or heard 9 0. Yes. 10 of Leslie Wexner having minor girls or minor boys at his 10 A. Oh, of course, yes, in the newspapers. 11 house? 11 0. And you're aware of why your deposition's 12 A. Oh, no. 12 being taken today. 13 0. Have you ever heard of Jeff -- 23 A. Yes, of course. 14 MR. REINHART: I assume, other than his 14 0. And it has something to do not with a case 15 children. 15 with Leslie Wexner, but a case involving Jeffrey Epstein 16 MR. EDWARDS: Oh. of course. 16 A. Coned. Yes. el course. 17 A. Yeah. No • his children. I'm sorry. 17 0. When you got this deposition subpoena, did you 18 Thank you. 18 by any chance try to look up some information on Jeffrey 19 0. Have you ever known of Jeffrey Epstein to take 19 Epstein - who this guy Is? 20 underage girls to Leslie Wexner's house? 20 A. No, no. I mean 21 A. No. 21 0. Is there anything -- 22 0. Do you know how it is that Jeffrey Epstein and 22 MR. REINHART: Hold on Were you 23 Leslie Wexner met each other? 23 finished? 24 A. No. 24 0. Okay. Go ahead. 25 0. You mentioned earlier that you believed that 25 A. No. I moan, other than every once in a 0 Toll Free: Facsimile: Suite 1300 • ESQVJE.E, 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutlons.com 3501.150-002 CONFIDENTIAL Page 16 of92 EFTA_OD°688D8 EFTA01247036 Larry Eugene Morrison - Volume I October 6, 2009 57 59 • 1 2 3 4 whole get a Google alert just following the case • just out of interest • because he's still my employer, you know, and you don't want to be blind-sided, but other than that, no -- 1 2 3 4 0. When you say last pace; how often are you flying? A. Every week • sometimes two, three times a week. 5 0. When you - 5 0. And Mat's by the time that you're working for 6 A. I never looked onto his financial 6 Jeffrey Epstein? 7 background or anytting look that. I don't know if 7 A. Yes, yes. a you can. 0. Because back in the Leslie Wexner days you 9 0. When you say a *Googie alert; that's 9 weren't flying every day. 10 something that you actually go out of your way and set up 10 A. No, no, no, because there was another 11 on Google, right? 11 engineer, no. 12 A. Yeah. 12 0. Right. 13 O. When did you do that? 13 A. I had about one-third of the flights. 14 A. A year ago or so. 14 0. So from 1988, when you start working with 15 0. Why did you do it? 15 Leslie Wexner. through S9 or so, you're not flying all 16 A. Because Ern not around Mr. Wexner - or Mr. 16 the time, right? 17 Epstein anymore. I duet 17 A. No. Oh, no, no. Actually. In 88, I was. 18 0. Well, he was in jail -- 18 you know, I was • my primary duties were in the 19 MR. REINHART: Hold on. Were you Finished 19 hangar - maintenance. 20 with your answer? 20 O. Did you enjoy doing that? 21 A. I haven't been a kill time employee with 21 A. The maintenance part of it? 22 Mr. Wexner since -- 22 0. Yes. 23 MR. REINHART: Epstein. 23 A. Oh, yeah, that's my background. that's my 24 BY MR. EDWARDS: 24 forte. 25 0. Epstein or Wexner? 25 O. Is that something that you've gone back to? 58 • • 1 2 3 4 A. I'm soriy Mr. Epstein. since February of 2007. 0. Well, a lot of that has to do with him being incarcerated -- 1 2 3 4 A. No, no. 5 6 0. -- for a year, right? 6 7 MR. PIKE: Form. 7 a A. No, it was because I wanted to make a job 9 -a career change. 9 10 0. Why? 10 11 A. Because I got tired of flying, being on 11 O. Did Leslie Wexner and/or Mr. Epstein help you 12 the road. wanted to be home. 12 to get that job? 13 0. Did it bother you that your boss, back in 13 A. No, no lies whatsoever. 14 2007, was under investigation? 14 0. So who introduces you to Jeffrey Epstein? 15 A. Of course. 15 Probably it would have been Larry. The 16 0. Is that part of the mason why maybe you 16 first actual formal introduction? 17 wanted to make a career change? 17 0. Right. 18 A. No, no. The reason was the amount of 18 A. Probably would have been Larry Visoski. I 19 flying that I had been doing and the overnights. and 19 knew Larry and Dave when they flew for Glimcher 20 when something's no longer fun, it's time to find 20 Corporation. 21 something else to do. 21 0. Tell me a little bit about that. Larry 22 0. Why wasn't it fun anymore? 22 Visoski • how do you know him? 23 A. It's a very fast pace. I wanted to spend 23 A. He's the Chief Pilot for Jeffrey and hired 24 time at home. I wanted to get back into strictly 24 me. 25 maintenance. 25 0. Well, he's the Chief Pilot now -- • 0 Toll Free: Faalmile: Suite 1300 ESQUABT 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 wvnv.esquIresolutions.com 3501.150-002 CONFIDENTIAL Page 17 of 92 EFrA_00068809 EFTA01247037 Larry Eugene Morrison - Volume I October 6, 2009 61 63 1 2 3 4 K Right. O. -- for Jeffrey Epstein. A. Right. O. When is the first time you met Larry Visoski? 1 2 3 4 O. How did you loam of Leslie Wexner? A. Oh, I mean, he's very well-known in Columbus, because, you know• billionaires in central Ohio, aren't, you know • A- It was before he worked for Jeffrey. He O. Aren't a dime a 0020n, tight? 6 and Dave were flying for a gentleman - Glimcher 6 A. Exactly. and small guy that made it big, 7 Corporation. 7 you know, because that's where the name Limited • so 8 O. Flying for who? a hearsay is - the name Limited came from he started 9 A. Glimcher Corporation. 9 with limited resources. so O. How do you spell that? 10 O. So did you know him before he was married to 11 A. G-L-I-M-C-H-E-R, I think. They were -- 11 Abigail? 12 They had an airplane based to Lane Aviation in 12 A. Yes. 13 Columbus with us. 13 O. And did you know him to date exclusively women 14 O. And David Rodgers? 14 peer to that? 15 A. Yes. 15 A. The only -- I knew that he was dating 16 O. How did you know David Rodgers? IC Sharon. 17 A. Same, from They were in the same hangar 17 O. Right. 10 we were in. 18 A. I never flew Sharon. but he dated Sharon 19 O. Are you from here? 19 for a long time, and then there was. you know, they 20 A. No. 20 broke up and then he started dating Abigail. 21 O. Where are you from? 21 O. And have you heard any rumors about him dating 22 A. Columbus. Ohio. 22 men as well? 23 O. So you're from Columbus. Ohio. and that's also 23 A. No, no. 24 a place where Leslie Wexner Ines. 24 O. First time that you're healing about it is me 25 A. Yes. 2s telling you that, right? 62 64 1 2 3 O. So that was at least convenient for you? A. Oh, eah. No, it was Yeah. 1 2 1 4 A. Yeah. O. So back to Lany Visosld • you don't know him while you're employed with Leslie Wexner. A. Yes. • 5 O. Youth? 6 O. As your first job that you had, was that with 6 A. Yeah. 7 Leslie Wexner? 7 O. How do you meet him? A. Oh, no. I started working for Ohio State 8 A. Met him because their aircraft was in our 9 University 9 hangar. The Glimcher aircraft was based in our 10 O. And then where? 10 hangar and got to know him that way. 11 A. -- in their flight department. 11 O. Glimcher is a company owned by whom? 12 Went from Ohio State University to get a 12 A. I donl know if it's public or not. It 3.3 shoe stint, a contract maintenance for a - a 13 was a mall development company not associated with 14 contract for NASA at Langley researcher, and then 14 Limited. 15 that was under the direction • that was contracted 15 O. So what's the conversation between you and 16 under OSU's umbrella for airport research. They had 16 Larry Visoski? Obviously you all end up working for 17 an Aviation Research Department. Then after that 17 Epstein, so try to lead me through that. 18 went to Red Roof Inns • maintenance technician for 18 A. Well, I think -- I mean, we got to know -- 19 Red Roof Inns. 19 I mean, you're neighbors in a hangar environment, so 20 O. What was It - Gregory Finns? 20 you have discussions. 21 A. No, Red Roof Inns. 21 Larry was the mechanic. He was also 22 O. Red Roof Inns. 22 pilot/mechanic on the Hawker for Glimcher, and you 23 A. True Sports Racing. It was Budweiser 23 kind of form a relationship and a rapport, and then. 24 racing • Indy car team and Red Roof Inns. the motel 24 I believe, Glimcher sold their airplane. I don't 25 Main. Then from there I went to The Limited stores. 25 know how Dave and Larry ended up with Jeffrey, I 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 vnirw.esgulresolutions.com 3501.150-002 CONFIDENTIAL Page 18 of 92 EFTA_00068810 EFTA01247038 Larry Eugene Morrison - Volume I October 6, 2009 65 6.7 • 1 2 3 4 don't know how they found that job, but they started working for Jeffrey then, but they still -- O. Did you ask them? A. No, I don't think -- I've never asked 1 2 3 I help them with the airplane, get, you know, become a (light engineer Director of Maintenance - on it 5 them, 'How -- 6 O. Did Jeffrey -- 7 A. -- did you meet them?' 8 O. have a plane in the same hangar? 9 MR. REINHART: Hold on. Let him finish 10 his answer. 11 MR. EDWARDS: I'm sorry. I thought you 12 were finished. 12 O. But the hangar we're talking about is in Ohio. 13 MR. PIKE: This is Michael Pike. Let him 13 A. Yeah, Lane Aviation. 14 finish his question because, keep in mind • you 10 O. You would see them brisirially on a dayto-day 15 finish your question, let him finish his answer 15 basis because the aircraft that you were a technician 16 - keep in mind. I'm on the phone, so I'm having 16 for -- 17 a hard time hearing his response in the 17 A. Right. 18 background. 18 O. was very close in proximity to the aircraft 19 MR. EDWARDS: You're actually on the other 19 that they were piloting. 20 end 04 the table. Do you want us to fry to move 20 A. Yes. 21 the phone closer? 21 O. They approach you at some point in time and 22 MR. PIKE: Yes, that would be good. 22 say what specifically? 23 MR. EDWARDS: I'll do that for you, man. 23 A. I can't remember the specific 24 I'm sorry, I really did forget that you were 24 conversations, but it was like, you know, asked me if 25 here. 25 I would be interested in, if Jeffrey bought the 727 66 68 • • 2 3 4 MR. PIKE: Not a problem. I've objected to form a couple el tines. I'm not Quito sure If that was even hoard, but that's neither here nor there. 1 2 3 4 being. you know, the fight engineer and help them, you know, get the flight department Ong. and I told them I would. O. And why rid you say *yes' considering that you 5 MR. EDWARDS: We'll say the last ten 5 had a bees in Leslie Wexner who was seemingly pretty good 6 questions you objected to form. I got you. 6 to you for the last ten years? 7 What was my last question, Pike? You A. Oh. he's excellent • don't oven remember. a O. Yes. 9 MR. REINHART: You asked Mn conversations 9 A. No, fine might department and Mr. Wexner 10 he had with Larry Visoski and Dave Rodgers about to as fine person. 11 how they come came to work for Epstein. 11 O. Right. 12 MR. EDWARD$: Good. 12 A. The reason being is, you know. I already 13 A. I really never queried them on now they 11 stated this I think twice before, was that I wanted 14 come to work for Jeffrey. I think Dave was hired 14 to be able to continue to fly arid that would give me 15 first and he brought - this is all speculation - and, 15 the opportunity to continue to ay as a flight 16 I think, he brought Larry on board. 16 engineer and the challenge of starting this airplane. 17 O. So as far as you know, however you know. David 17 O. Right. I didn't ignore you. I heard you say 18 Rodgers was the first Epstein contact and then Larry 18 that, but then I also heard you say he brought a brand 19 Visoski rode a In. 19 new plane. 20 A. The way I understand, yeah. 20 A. It was only a two-man airplane -- 21 O. How did you become involved in the 21 O. So then he would have -- 22 three•person train to Epstein? 22 A. - and the modem aircraft could only have 23 A. When it became apparent that Jeffrey, or 23 hvO plus, right. 24 Mr. Epstein. was going to buy the 727, Larry 24 O. Got you. I underworld. 25 approached me. that if I would want to, you know, 25 So they approach you with tris prospect of the • CO Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 19 of 92 EFIA_00068811 EFTA01247039 Larry Eugene Morrison - Volume I October 6, 2009 69 71 1 2 3 4 two of them - Dave Rodgers and Larry Visoski - becoming the pilots for the 727 -- A. Correct. 0. -- that Epstein's buying and, 'Hey, would you 2 3 4 A. I don't know. I don't know. 0. I mean, how did she get on his private airplane? I would imagine strangers don't just walk on, light? • 5 like to be apart ol it?' s A. Yeah, but I don't know. I don't know what 6 A. Right. 6 people's associations are together when, you know. 7 0. I mean, Mars the gist of it. • 0. Okay. A. Correct, that would be the gist ol a A. I don't know if it's business association. 9 0. And your response was? 9 social associations. or what. 10 A. Yes, I would • you know, if it came to be, 10 O. How many times 11 I would consider it. ObviOuSly, you knOw, salary had II MR. PIKE: Let me object to the form of 12 to come in and everything else, but I said, 'Yeah. I 12 that question. 13 would be interested in it.' 13 MR. EDWARDS: Okay. Noted. 14 O. What's to next conversation that you had and 14 BY MR. EDWARDS: 15 with whom? 15 0. How many times was she on that airplane when 16 A. I don't know. There were several 16 it was owned by Leslie Wexner? 17 conversations, but they were all with Dave and Larry 17 A. Not many, but I can't give you an exact. 18 both, you know, calling back and forth, but. 18 0. Was she ever naked on the airplane? 19 0. About what? Was it about salary, about the 19 A. Not that I'm aware of. 20 position? 20 0. I mean. that's something that you would 21 A. Salary, what the benefits wore, you know. 21 probably remember, right? 22 stuff like that. No. the position was pretty much 22 A. Well -- 33 defined. I mean, it's the eight engineer, Director 23 MR. PIKE: Form. 24 ol Maintenance position. 24 A. Yeah. I mean -- 25 O. And this brings us up in our timeline to 2001, 25 0. I'm not really trying to be funny, but I would 70 72 1 2 3 4 you think? A. Correct, that's when I hired on and actually moved to Florida was January 2001. 0. Prbor to 2001, had you heard the name 1 2 3 4 assume I would remember e. A. Not that rm aware et 0. Do you remember her bringing other gins on the airplane with her? • • Ghislaine Maxwell? • A. No. 6 A. Yes. 6 0. You remember her getting on Me airplane 7 0. How would you have heard Chislaine Maxwell? ? alone? ▪ A. She had been a passenger on the 727 once B A. I can't say for sure. 9 or lvace. 9 0. Alright. Maybe this will log your •• 10 0. The 727, I mean? 10 A. I mean. she was never µst atone-alone. 11 A. When It was under Limited. 11 Like the only passenger or. 12 0. Yeah, yeah, that's the point I'm trying to 12 0. Yes. 13 make. I mean, this could get confusing on the record. 13 A. No. no. always with when other people 14 It's not confusing to me. Gut on the record it could be 14 were on board. 15 because the 727 was Wexner's, then it was Epstein, so Is 0. And you lust can't remember whether she 16 you're talking about -- 16 bought on board with her a male or a female: is what 17 A. When it was under Mr. Wexner's control. 17 you're saying. right? 18 0. What year do you think that was? 18 A. No. I mean -- Restate the question. How 19 A. It would have been in the late '90s. 19 cid you 20 Again, like I say, when - probably some time around 20 0. Sony. 21 the time - you know, had to be late ^90s -- 21 A. Define 'alone.• 22 0. Did she 22 0. I don't mean, you know. n there's 15 23 A. - maybe 2000. 21 passengers and she gets on. I'm saying: Do you remember 24 0. Did she seem like a friend of Leslie Wexner's 24 her getting on and being accompanied by • either they 25 to you? 25 took the same car to the airport, they walked the runway Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresdutions.corn 3501.150-002 CONFIDENTIAL Page 20 of 92 EFTA_00068812 EFTA01247040 Larry Eugene Morrison - Volume I October 6, 2009 73 75 • 1 2 3 4 up to the airport? Do you remember her being with somebody else? A. If it would have boon, would have been Mr. Epstein. never •• 1 2 3 4 A. Maybe mid-'90, early '90. 0. We're talking -- A. He didn't have that plane very long. 0. Between '90 and '93. you're saying. 5 0. How many times do you think Mr. Epstein was on 5 A. Probably, yes. 6 that airplane? 6 0. And between '90 and '93, if we use those 7 A. I can't say for sure • not that many. 7 years. you're laminar with the name 'Jeffrey Epstein? 8 0. Less than live? 8 A. Not until later when he bought the 9 A. That I saw him, yes. probably. 9 Gultstream in - later when he was, you know, like I 10 0. And how many times of al -- 10 said, late '90, probably. 11 MR. REINHART: Can !just chanty? You 11 0. But you're aware that David Rodgers and 12 mean dung the tune Mr. Wexner owned the 12 Visoski are flying an airplane between '90 and '93 that's 13 plane 13 owned by somebody. MR. EDWARDS: Right, right. nght. 14 A. Correct. Yeah. 15 MR. REINHART: -- since Mr. Epstein bought 15 0. But you don't know the name of the person -- 16 the plane. 16 A. Correct. Right. 17 BY MR. EDWARDS: 17 0. — that is the owner. We're good. We're on 18 0. Alright. We're not up to the point, we're 18 the same page. 19 about to bo, but we're not ho to the point yet where Mr. 19 '88, you start working for Leslie Wexner. 20 Epstein takes control, so. 20 A. Right. 21 A. I mean, you have to understand. Mr. • 21 0. And the first time Epstein is on Leslie 22 during this time period. Mr. Epstein had his other • 22 Wexner's airplane is approximately when? 23 he already owned his other airplane. 23 MR. REINHART: It's asked and answered 24 Q. How did you know that? 24 BY MR. EDWARDS: 25 A. Well, because that's what Larry and Dave 25 0. That you remember. 74 76 • 1 2 3 4 were flying - the Gulfstream. O. But this is something you found out afterwards. A. No, no. I knew that they had gotten a job 2 3 4 MR. REINHART: Asked and answered. A. I cant — The only tine I would remember • we've already answered thd several times - was in the late '90s when I was actually on the airplane. I 5 with him and they were flying the Guestream. 5 have no idea if he was on previous times without me 6 0. Alright. Let me clarify this real cwickty. 6 there. 7 You got the job in 1988 with Wexner. 7 O. And when he is on the airplane, is ho on the 8 A. Right. 8 airplane with young girls? 9 0. Right. Larry Visoski and David Rodgers are 9 MR. REINHART: Its also been asked and 10 flying a plane that is presumably owned by Jeffrey 10 answered. 11 Epstein and/or one of his corporations. it A. No. 12 A. Not at first. 12 0. New we're back to Ghistaine Maxwell, and I 13 O At some point in time. 13 believe your answer - which led me back to these 14 A. Correct. 14 questions that I had previously asked. 'Was Ghislaine 15 O. And what point in time do you become aware 15 Maxwell on the airplane that Wexner owned that you know 16 that that's happening? 16 of?' • and I think your answer was. 'With Epstein? 17 A. I can't remember exactly when they bought 17 MR. PIKE: Form. 18 the Gultstream. They actually had a Hawker for a 18 A. I wood I would say if she was on 19 short period. I don't know when that was. 19 there, it would be with him. I never knew I would 20 0. Was that also owned by Jellrey Epstein? 20 not think that she would fly on it without him. 21 A. For a very short period, and he traded it. 21 0. Do you specifically remember her on the 22 O. The first Epstein plane that you're aware of 22 airplane with him? 23 Is that Visoski and Rodgers are on -- 23 A. Caret say - I can't. 24 A. Was a Hawker. 24 0. On any of these flights that Jeffrey Epstein 25 D. was approximately what year? 25 and/or Maxwell was on. din thoy fly internationally? Toll Free: Facsimile: Suite 1300 ESQUIRE as Meander Odle Conga, 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresoludons.com 3501.150-002 CONFIDENTIAL Page 21 of 92 EFTA_00068813 EFTA01247041 Larry Eugene Morrison - Volume I October 6, 2009 77 79 1 2 3 4 A. I know I Drought her back one time from England, I believe - I remember that from London. O. Brought Maxwell back from London. and was she alone then? 2 3 4 the Court to be well aware that not 8t of my form objections are coming through the telephone. MR. EDWARDS Mike. how about this, of all • 5 A. I can't I can't say. I cant remember. 5 of the people involved. I think that you know 6 O. I thought you said that if she was on the 6 you can trust me here. If you say when wo read 7 plane it wouldn't have been alone. 7 this back that you wanted a form objection. III A. More than likely she would have been with B put 6 on the record right now you get n - how 9 Jeffrey. 9 about that? 10 O. So do you think that you brought Maxwell and 10 MR. PIKE: Not a problem. 11 Jeffrey together back from London? 11 BY MR. EDWARDS: 12 A. More than likely, but I can't say for 12 O Alright. Have you ever looked at any of the 13 sure. I can't remember if he was on that flight. 13 information from Customs and Immigration related to 14 O. To the best of your recollection right now, as 14 flight logs? 15 we sit hero, Is that Maxwell was on the plane and Epstein 15 A. No. 16 may or may not have been? 16 O. If Customs and Immigration is the right agency 17 A. Correct. That's correct. 17 to take control Of MOSe documents, who is it that 18 O. What year are we talking about and whose 18 generates the documents in terms of personnel riding upon 19 airplane are we talking about? 19 this airplane/ 20 A. That would have been when the 727 was 20 A. Captain 23. still Limited - or Wexner. 21 O. Who was the captain or who were the captains 22 O. And that would have been around what year? 22 that you are aware of and try to give me years, it many 23 A. 2000, maybe. 23 of them changed. to the best of your knowledge for 24 O. 2000? 24 Leslie Wexner? 25 A. '99. something like that. 25 A Primarily it would have been Tim Staley, 78 80 1 2 3 4 O. A. O. A. So this is almost into the transition -- No, I'm sorry. - into it. Let me think on the dates. 1 2 4 3 Jim Taylor, Rob Imlay. O. Rob? A. Imlay. I.M.L-A-Y, Bill Hammond. 0. Bill Hammond? • 5 O. Okay. 5 A. Uh-huh. 6 A. Yeah, I can't - I can't remember. 6 O. Bill Hammond later becomes affiliated with Mr. 7 Q. Late '905 or 2000? 7 Epstein too, right? 8 A. Late '90s. a A. Correct. 9 O. Who has the flight logs from late '90s? 9 O. We're going to get to that. 10 A. I don't know. 10 Have you ever been a captain? 11 O. But that's something that the FAA would have, 11 A. No. 12 right? 12 a And when you say that it's not necessary - 13 A. NO. 13 unless you're flying internationally, I know - but its 14 MR. PIKE: Form. 14 not necessary to maintain a passenger manifest that 15 BY MR. EDWARDS: 15 delineates the exact name, where are you getting that 16 O. Flying Internationally? 16 information from? 17 A. I don't know if the FM gets that. It 17 A. I know it's not required by the FARs. 18 would more • most hkety be Customs and Immigration. te O. Kow do you know that? 1.9 MR. PIKE: Are you guys getting my form 19 A. Because you can read the FARs. Part 91, 20 objections? 20 FAR 91, Operations. 21 MR. EDWARDS: Yes. We got you. 21 O. What's -FAR' stand for? 22 MR. PIKE: Thank you. Brad. I just want 22 A. Federal Aviation Regulations. 23 on the record that not all of my form objections 23 O. And what would be the reason not to put the 24 are coming through, so if we have an issue with 24 whole name of the person on the airplane? 25 this deposition - I am on the phone - and I want 25 A. I don't know. I -- I don't know. 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 vnwtesquiresolutions.com 3501.150-002 CONFIDENTIAL Page 22 of 92 EFTA_00068814 EFTA01247042 Larry Eugene Morrison - Volume I October 6, 2009 Si 83 • 1 2 3 4 O. Because Later I'm going to show you some lists. and certain people are listed by full name and others are listed generically • any idea why that would happen? 1 2 3 4 A. It would be obvious that these aro associates of some form, that they're not, you know, strangers trying to board the airplane. O. So let's go back to that conversation that you 5 A. Unless they just don't know who it Is. you have in the Ohio hangar, or whatever it is, with David 6 know, just a guess. I mean, you know, you don't want 6 Rodgers and Larry Visoski when they talked to you for the 7 to query somebody and give them the third degree If 7 first time about possibly switching over to Mr. Epstein. it's just a guest of the boss that's, you know, 8 A. Ubhuh. 9 riding along or something. 9 O. How does that conversation really go about/ 10 O. Well, she asked you your name before your le MR. PIKE: Form. 11 deposition and you didn't consider that the third degree 11 A. I don't understand. What do you mean. 12 by any means. right? 12 'How &law about?' 13 A. Right. but -- 13 O. Did you approach them and say. 'Hey, are you 14 MR. PIKE: Objection to form. 14 going to stay here forever with this airplaner or 'Do 15 A. Bill you're approaching your employer's is you have another lob for me?' or what? 16 guest. It would be like walking into his house and 16 A. I think it was just, you know. I believe 17 asking him, 'Who's sitting at the dining room table?' 17 Larry approached me. I can't remember. It was that 18 • In a way. See what I'm saying/ It's just -- You 18 long ago, but - 19 have to maintain .- 19 O. What does Larry Say to you? 20 O. But •• 20 A. I can't remember the exact conversation. 21 A. -- the employee/employer relationship. 21 O. I mean, was he not happy where he was? 22 O. No, no, no. I guess what I'm saying is: if 22 A. Who, Larry? 23 one of these people is Mohammed Aga, you would like to 23 O. Yes. 24 know O. probably. 24 A. Never said he wasn't. 25 A. Well, yes. 25 O. How did you know Larry? 82 84 • 1 2 3 4 MR. PIKE: Form. A. Yes, yes. Q. So any reason why a captain trying to secure the airplane and the people aboard wouldn't take that 2 3 4 A. What are you talking about? Why would he not be happy where he was? I don't understand. O. Well, he's working for some other corporation that's not non-Epstein owned. S extra step and try to figure out who's exactly on his 5 A. Oh, that previous corporation sold the 6 airplane? 6 airplane. 7 A. Well. when it's • the normal passenger 7 O. Oh, they did? loads are live to ten people, at the very most, and A. Yeah. He had no choice. They were out of 9 they're all with the owner and accompanying the owner 9 work. 10 and some of the regular passengers, you know; the 10 O. So Larry and David were about to be out of 11 likelihood that Mohammed Atta is going to sneak in 11 work. 12 there and board his plane and ride along is - you 12 A. Yes. 13 know. 13 O. So they said, 'Hey. we found a new lob and 14 O. He's willing to play those odds, okay. 14 its with this guy Jeffrey Epstein and he's buying that 15 A. Well, I'm not saying that he's playing 15 plane. Do you want to be involved?' 16 odds. I'm just stating that the only reason I can 16 A. No, no. There was another airplane in 17 think — I don't know. I've never filled those out. 17 between • two other airplanes. There was a long time 18 The only reason I can think is he just didn't have 18 between - and I don't know the exact dates and I 19 the name and didn't want to intrude and ask. 19 don't know that I even do know the dates • but there 20 O. If you were a captain, would you ask who was 20 was a time between when they left Glimcher before 21 on your airplane? 21 Jeffrey got involved with the 727. 22 A. Not if the situation was that it was 22 O. So they leave Glimoher? 23 controlled by the owner and I knew who the - you 23 A. Yes. 24 know. 24 O. Then what happens? 25 O. Okay. 25 A. They somehow - I don't know how • hired on • Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 vnvw.esguiresolutions.com 3501.150-002 CONFIDENTIAL Page 23 of 92 EFEA_00068815 EFTA01247043 Larry Eugene Morrison - Volume I October 6, 2009 85 87 1 2 3 4 with Jeffrey. O. They hired on with Jeffrey to pilot the 727? A. No. He had two other airplanes prior to that. He had a Hawker that he had for a very short 1 2 3 4 0. Before your conversation with them about becoming Involved with Jeffrey Epstein. A. Yes. 0. How? • 5 period and then he bought - traded it or sold it. I • A. Like we discussed. We've been through 6 donl know what he did with it. but then he got the 6 this already. When they wore at Glimcher they had an Gulfstream. 7 airplane in the hangar. We would see them 8 0. So Larry Visoski and David Rodgers were pilots • sporadically and we would talk. 9 for Jeffrey Epstein when he had the Hawker also? 9 0. I'm sorry, bad question. I don't mean on a 10 A. Yes. 10 business relationship. On a social relationship, did you 11 0. And what year are we talking about there? 11 hang out with them -- 12 A. I have no idea. 12 A. Oh, no. 13 0. Well, If you sign on with him in 91. it's 13 0. outside of this? 14 before that year. right? 14 A. No, no. 15 A. No, no, I signed in '01 • January '01. 15 0. I apologize. 16 0. '01. 16 So • and I only asked that question because 17 A. I don't know how long they flew for 17 some years later then you're in contact with them and 18 Glimcher before that airplane went away and how quick 18 they asked you to become involved with Jeff Epstein. 19 they gel on with Jeffrey. I don't know. Somewhere 19 A. Uh-huh. 20 between '88 and 2001, they -- 20 0. But that is because of a business relationship 21 0. During -- 21 solely that you had with them -- 22 A. — left Glimcher and — 22 A. Oh, yeah. 23 0. During '88 and 01, do you remain in contact 23 0. years before? 24 with Larry Visoski and David Rodgers? 24 A. I didn't know them personally. 25 A. On and off. They eventually moved, you 25 MR. PIKE: Form. 86 88 1 2 3 4 know, to - moved away from Columbus when they hired on with Jeffrey, so they weren't in the hangar every day. 0. Where did 'hey go - do you know? 1 2 3 4 BY MR. EDWARDS: 0. Okay. Alright. So in 2001. is that the year that you get a telephone call from one or two of these people? • 5 A. I Think Dave went to New York and Larry 5 MR. PIKE: Form. 6 went back to South Florida. 6 A. It would be either late 2000 or earty 7 0. Do you know why? 7 2001. I don't These transactions don't happen A. Well, because I think Jeffrey gave them 8 overnight -- 9 the choice of living where they would like. I 9 0. Yeah. 10 believe. I mean, that's -- 10 A. — buying an airplane. So it could have 11 0. That's what they've said. 11 happened in, you know, November or started talking in 12 A. That's what they've said. 12 November, like, 'Well, you know, would you be 13 0. Okay, and Larry chose South Florida, David 13 interested if Jeffrey gets the airplane or buys the 14 Rodgers chose New York? 14 airplane?' you know. to when I actually hired on. 15 A. Right. 15 0. Did you ever talk to Ghislaine Maxwell • ever? 16 0. And Epstein had a place for them both wherever 16 A. After I had hired on, yes. 17 they wanted to go? 17 0. After you hired on with Epstein. 18 A. Well, they owned their own Acmes or 18 A. Yes. 19 something. I don't know what their living 19 0. Well go up to her. 20 arrangements were. 20 So when is it that you hired on with Jeffrey 21 0. Did you know Larry Rodgers or David Visoski 21 Epstein? 22 before this? 22 A. I think I began in January of 01. 23 A. Before? 23 O. In January of '01, do you stars getting a 24 MR. PIKE: Form. 24 paycheck from Jeffrey Epstein? 25 BY MR. EDWARDS: 25 A. Yes. 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.00m 3501.150-002 CONFIDENTIAL Page 24 of 92 EFTA_00068816 EFTA01247044 Larry Eugene Morrison - Volume I October 6, 2009 89 91 • 1 2 3 4 O. And Is it paid from one of his companies or from Jeffrey Epstein specifically? A. No, no • JEGE. O. JEGE. What is your understanding as to what I 2 4 3 perform. O. On what planes? A. Just the Guff - just the Boeing. O. Just the Boeing? that is? 5 A. Uh-huh. 6 A. It's just initials. It's a name. I don't 6 O. Over the years. did you become aware that he have any idea what it stands for, but I'd ask that a 7 owned other aircraft? 8 million times. a A. I knew that he still had that. 9 O. Its a company that owns something, right? 9 MR. PIKE: Form. 10 A. I don't know -- 10 A. He still had the Guffstream. 11 MR. PIKE: Form. 11 O. At the time back in 2001 - and we're going to 12 A. -- if it even owns anything. I don't know 12 walk through some of his enplanes • he owned the Boeing 13 what type of company it is. I don't know if It's 13 727, right? 14 just a Wilmington. Delaware, company. 14 A. Correct. 15 O. What's the bank account that it was written 15 O. And what other airplanes did he own at that 16 on? 16 time when you signed on with him in 2001? 17 A. I can't remember. I mean. I know I'd read I7 A. The Gulfstream. 18 • I'd see 'JEGE` on it, that's all. le O. Guitsteam is what? 19 O. A New Mexico bank, New York bank. Florida 19 A 28. 20 bank? 20 O. Do you know who the pilot was for that plane? 21 A. I have no idea because its direct 21 A. Dave and Larry, I mean, its always. 22 deposit. All I would do is just see if the amount's 22 O. Was it atways Dave and tarty no matter what 23 right. I don't -- I have no idea. I would have 23 plane was being taken out? 24 no Idea. 24 A. Unless somebody was on vacation or in 25 O. What was your communication - direct 25 school and they used contract people. 90 92 1 communication with Jeffrey Epstein that results in your 1 O. What was the purpose behind having multiple 2 employment with JEGE? 2 planes - used one for the purpose, one for another do 3 MR. PIKE: Form. 3 you know? 4 A. A conversation result in my -- Essentially 4 A. I never could figure that out. 5 Larry hired me. I mean, it wasn't - It wasn't 5 O. Really? 6 didn't realty -- I may have had one phone 6 A. Yeah. 7 conversation with Jeffrey prior to actually being 7 O. No rhyme or reason why he took one this way B hired and the next time I saw Jeffrey was when I was Ei and one that way? 9 in Florida with the airplane. 9 A. No. He was • pretty much once the Boeing 10 O. What did Jeffrey ask you in that one phone 10 got on line. Now, you know, the Boeing goes down for 11 conversation? 11 heavy maintenance. It used to go annually. now It 12 A. I think he asked me what my current salary 12 goes down DI-annually, but • so he would utilize that 13 was, or something along that line, you know. 13 airplane while it was out of service, you know, for 14 O. Did he ask you what you were looking for in 14 maintenance, which sometimes would be four, five 15 terms of salary? 15 weeks at a time, so. 16 A. Yes. 16 O. And in those cases, then he would use the 17 O. What dkl you toff him? 17 Guffstream 2B? 18 A. I told him to basically I forget how it la A. Yes. 19 went exactly. It ended up being like $117,000, 19 O. Have you been on both planes? 20 something like that. 20 A. Yes. 21 O. $117.000 a year? 21 O. We're still talking about 2001. Is that the 22 A. Yeah. 22 first time that you're on the 727? 23 O. And what wore your duties? 23 A. Firs! time I was on the 727? Wail. I 24 A. Basically - flight engineer, obviously. 24 don't know what you mean. 25 but all line maintenance and scheduled maintenance to 25 O. After Epstein owns it. • 0 Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 25 of 92 EFTA_00068817 EFTA01247045 Larry Eugene Morrison - Volume I October 6, 2009 93 95 1 2 3 4 A. Yes. O. And do you remember where you went? A. Very first tlight, no, because we didn't fly it immediately. We upgraded some avionics and 1 2 3 4 A. Cant remember the first flight. Like I say, it was down tor a while probably • I think it was - had to take at least three to tour months maybe to get it -- • 5 did modifications. s 0. And did you know of him flying on the airplane 6 O. What modifications did he want to that plane? 6 with gins accompanying him? 7 A. Just changed the carpet and some fabrics, 7 MR. PIKE: Form. e upgraded the radar, upgraded the navigation - the A. I don't -- 9 flight manifest systems. 9 O. Back in 2001. 10 0. Did he change the interior at all? 10 A. With girls accompanying him? 11 A. No. We removed that one small table and 17 0. Yes. 12 chair - that's it, but we did not really change what 12 A. Yes. 13 you would consider the floor plan. 13 O. Where would he pick the girls up from? 14 0. Now, try to give me a visual appreciation of 14 MR. PIKE Form. IS the inside of the plane. II I'm looking out the cockpit 15 A. I don't know. They would arrive with him. 16 back towards the back of the plane: what am I going to 16 you know, out of Palm Beach or out of New York. I 17 see? 17 don't even remember where we went the first time. 18 A. A door. The first flight was probably New York, I think. 19 O That's it? 19 O. Is it a private airport in New York where you 20 A. That's it. yeah. 20 would usually pull into or a commercial airport? 21 a Just an empty room with a door? 21 A. I think the first time we started going up 22 A. No, no. The door's always closed. If the 22 there. I think, we were using White Plains, which is 23 door's open you will see the forward salon, and in 23 • actually, it's not a private airport. They all 24 the forward salon there is a conference table, a 24 have some commercial service. It would have been 25 high/low table, some divans, and some single seats. 25 White Plains, I believe, then later we started using 94 96 1 2 3 4 0. What's behind that? A. The galley. 0. The what? A. The kitchen - galley. 2 4 7 3 Kennedy, and the service was so terrible in Kennedy and so expensive we went to Newark. O. When you would fly into White Plains or to Kennedy or Newark, would you always get off of the • • 0. Okay. 5 airplane or would you sometimes stay on and wait for 6 A. Behind that is the aft salon, which is 6 passengerslo board? 7 just two round divans. 7 A. I don't understand. ▪ O. And? a 0. Well, when you stop an airplane 9 A. Alter that is the office, which is a 9 A. Right. 10 consists of a credenza and a desk, or divan and a 10 0. -- sometimes you get off the airplane and you 11. desk and chairs. 11 go either through a. you know, through the airport or you 12 0. How many of these areas can you close off or 12 go somewhere else, or your option is to stay on the 13 partition? 13 airplane and not get off and wait for other people to get 14 MR. PIKE: Form. 14 on before you take oft. Is A. Each one. And after that there's the 15 A. Oh, no. 16 state room. 16 MR. REINHART: rm sorry, can wo clarity 17 O. And in the state room how big is the slate 17 the 'you'? Do you mean thin personally or the 18 room? 18 people who were passengers on the plane that he 19 A. Consists of a queen size bed and two 19 was flying? 20 single seats. 2o 0. I'm talking about you personally. 21 CI Have you ever been back in the state room? 21 A. Oh. no, it was rare that we ever did a 22 A. Oh, yes. Yeah. 22 through flight. Wo would normally go Irom Point A to 23 0. When's the first time you flew on the airplane 23 Point B, and that was the destination. 24 with Jeffrey Epstein back in 21101, after he acquired the 24 O. I assume when he buys the plane initially it 25 727? 25 was in Ohio. right? • Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Otas Boulevard Fort Lauderdale, FL 33301 www.esquiresoluticns.com 3501.150-002 CONFIDENTIAL Page 26 of 92 EFTA_00068818 EFTA01247046 Larry Eugene Morrison - Volume I October 6, 2009 97 99 • 1 2 3 4 A. Well, yeah, but -- O. Then you fly to Florida. A. Well, we crewed it to Florida and then it sal at a facility in Florida during negotiations, so 1 2 3 4 O. A. O. A. Who's on the airplane? Well, obviously it would be Jeffrey. Right. I can't remember who all went. • it didn't go directly from Ohio. S O. Who were the pilots? 6 O. In 2001, when there's still negotiations, 6 A. I can't remember that either. 7 where in Florida is the airplane? 7 O. Larry? • A. Lake City • Timco. Lake City. B A. No. 9 O. During the negotiations, does it ever take ott MR. REINHART: Hold on. 10 or is it grounded? 10 A. II would have been myself, for sure - 11 A. No, no, it's grounded, because on a Part 11 because I was the only one with experience on the 12 91 deviation it has to be under a specific 12 airplane myself, Dave, I believe, would have been 13 maintenance program, so when it left The Limited. it 13 captain because ho had been schooled, but I can't 14 left that maintenance program, and I had to 14 remember if Larry took first flight or nol. I think 15 transition it to the new program. 15 he was still in training. 16 O. This is still sometime in 2001, right? 16 O. Where did you go? 17 A. Earty, yes, yes. 17 A. I can't remember. 18 O. And then it passes all inspections, I'm 18 MR. PIKE: Form. 19 assuming? 19 A. I can't remember it It was New York or 20 A. Right, right. 20 I would imagine it would be New York, but I can't 21 O. Then you take it to what airport to where 21 remember. 22 it — 22 O. When you say you would imagine New York. I'm 23 A. PB1. 23 getting the impression that many of the flights went to 24 O. PRI? 24 and from New York. 25 A. Here in West Palm. 25 A. Yeah, primarily. 98 100 • 1 2 3 4 O. While ifs at PB1 airport, does it take off from there? A. No, not for -- 'Mars when we were doing the modifications and upgrades. We were doing the 1 2 3 4 O. Soil - A. And -- O. So any time you're having to guess where it's going, you're saying New York because that's the primary S avionics. 5 place it's gong. 6 O. How long did that take? 6 A. Correct. I would have remembered -- I 7 A. I don't remember the exact time - maybe 7 I know I didn't get — I had heard about St. Thomas. B three to four months. but I hadn't been there right away. I didn't get to 9 O. Who does it with you? 9 go to St. Thomas for a while. A. Jet Aviation. Jet aviation did the 10 O. Thars later on in the story. 11 avionics and soft goods. 11 A. Yes. 12 O. And when you say the *soft goods.* what do you 12 O. Well get there. 13 mean by that? 13 So you go to Now York. Does he tell you the 14 A. Carpet. fabrics. loather, you know, 14 purpose behind going to New York? 15 different things like that. 15 A. No. 16 O. When's the first time it takes off then on a 16 O. Prior to this trip to New York, have you had a 17 real flight - some time m 2001, but mid-year or 17 personal conversation with Jeffrey Epstein? 18 something? 18 A. No. 19 A. Probably midyear, maybe a little earlier 19 MR. PIKE: Form. 20 than mid-year. 20 BY MR. EDWARDS: 21 O. We're talking about Juno of 2001? 21 O. Never? 22 A. Right. 22 A. Not personal Everything is 23 O. Arid where do you go? 23 business-related. 24 A. Can't remember. i cani remember for 24 O. Okay. but -- 2S Mb. 25 A. 1 mean, it was about the interior work or Toll Free: Facsimile: Suite 1300 ESQUIRE *0 Aleasolet Gallo Capin 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 27 of 92 EFTA_00068819 EFTA01247047 Larry Eugene Morrison - Volume I October 6, 2009 101 103 1 2 3 4 the avionics going in. but never personal. O. But, I mean. you've been hired by him -- A. Right. O. -- you agreed on a salary. he's going to pay I 2 3 4 know, business relationship too. O. Did you know who Ghislaine Maxwell was? A. Not right away, no, no. O. Nol right away? • 5 you the salary, but other than that, and what maintenance 5 A. Right. 6 may be required -- 6 O. At some point in time you were curious enough 7 A. Correct. 7 to make an attempt to find out. - on the airplane, nothing else? B A. No, l 9 A. He's a very -- His conversations are 9 MR. PIKE: Form. 10 usually very shod. He doesn't, you know, take much to A. -- heard about her and there was a book up 11 tine. 11 In New York In the apartment that we stayed In that 12 O. When you would have conversations with him. 12 was -- You know, you're sitting there with nothing to 13 would they to over the telephone or would they be in 13 do. I read that. 14 person? 14 O. Do you remember the name of the book? 15 A. It could be In both. II he was in Florida 15 A. It was just 'Maxwell: 16 and I wanted to actually show him a labric or a 16 O. Have anything to do with her father? 17 sample for the airplane or he wanted to view how it 17 A. Yeah, it was about him, that's what it was 18 was coming, but oftentimes it would be via telephone 18 about. I mostly just flipped through locking at 19 from New York. 19 pictures, boats, and airplanes and stuff. 20 O. When it would be in person. would you see him 20 O. Back in 2001, the first time you had a real 21 surrounded by or be accompanied by a girl or girls? 21 conversation with Ghlstalne Maxwell .- 22 MR. PIKE: Form. 22 MR. PIKE: Form. 23 A. At times, yeah. 23 A. Yes. 24 O. Would any of those girls be Ghislaine Maxwell? 24 O. - what did that conversation Consist of, it 25 A. Al times, yes. 25 you remember? 102 104 1 2 3 4 O. Would any ol those girls look extremely young lo you? MR. PIKE: Form. A. Not - Not that I thought. 1 2 3 4 A I think it was concerning getting a cell phone and a pager • that's it. O. Did it have anything to do with underage girls? • 5 O. Not back in 2001, we're talking about? s A. Absolutely not, no. no. 6 A. Right, right. 6 O. That's not something she ever shared with you? 7 O. NO. 7 A. No, no. What would Ghislaine Maxwell say to you, it O. Did Jeffrey Epstein ever share with you that 9 anything? 9 he wanted underage girls -- 10 MR. PIKE: Form. 10 A. No. 11 A. She'd Mostly small talk, just She 11 O. —in any way? 12 kind of did the business management pad of it as far 12 A. No. 13 as, you know, arranging cell phone - I was having 13 MR. PIKE: Form. 14 coil phone problems with the company cell phone. she 14 BY MR. EDWARDS: 15 would handle things like that, but she would have 15 O. I mean, certainly I'm not saying something to 16 minor inputs on the interior work. 16 you that's an absolute shocker right now -- 17 O. What was your understanding back in 2001 still 17 A. Right. 18 of the relationship between GIs:Vain° Maxwell and Jeffrey 16 O. — considering the newspaper articles. 19 Epstein? 19 A. Right, but l know -- You have lo 20 MR. PIKE: Form. 20 understand, every conversation I had was pretty much 21 A. I really didn't understand it. I thought 21 business, just to deal with the airplanes. You know, 22 it was personal - personal and business. 22 I'm an employee/employer relationship. 23 O. When you say "personal: did you mink it was 23 O. I just don't want you to think I'm just asking 24 sexual? 24 random off the wall questions -- 25 A. I thought maybe they were dating and. you 25 A. Right. 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutIons.coM 3501.150-002 CONFIDENTIAL Page 28 of 92 EFTA_00068820 EFTA01247048 Larry Eugene Morrison - Volume I October 6, 2009 105 107 • 1 2 3 4 O. that have nothing to do with anything. A. I understand. O. 2001. you start working for him, and that June or so is the first fight, and you believe its to New 1 2 3 4 building. I've been to the building. The building is huge. A. I don't know. I don't know if he owns the building or just - or how many units he's got. Maybe 5 York. • ten, because I think some of the employees up there 6 A. Cared. 6 live in them. 7 O. Do you remember the purpose behind the flight? • O. Do you remember who some of the other A. No, did not know the purpose. 8 employees are that live in that building? 9 O. Did you get off the airplane in New York? 9 A. Well, I think Darren used to five in il. 10 A. Yes, yes. 10 Darien Indyke. 11 O. Where did you go? 11 Q. Darren Indyke, right. 12 A. Probably to - into the city, into the 12 What abou do you remember her? 13 city, and he has an apartment building up there that 13 A. lived in there. 14 we would stay in in the city. 14 O. What abou 15 O. Is it paid for by Jeffrey Epstein? 15 A. I don't know lived in there or 16 A. What? 16 not. 17 MR. PIKE: Form. 17 O. You know who that is, though. 18 BY MR. EDWARDS: 18 A. Right, right. Actually, she was just kind 19 O. The apartment. 19 01 coming into the picture when I was • about the 20 A. Well, he -- Its I think it's in the 20 time when I was leaving. 21 building he owns. I mean. I just -- I don't know. 21 O. What about Ghislaine Maxwell? 22 Q. Do you remember the address? 22 A. No, no, she didn't live there. 23 A. El m 23 O. What about Jean Luc Brunel? 24 O. right? 24 A. No. 25 A. Right. 25 O. How about Did Mark Epstein ever indicate to 106 108 • 1 2 3 4 O. Did he ever mention a brother that he may have to you? A. I met his brother, I think, once. O. What's his name? I 2 3 4 you that he had any ownership in any d that? A. Oh, no. I only saw him one time on a short flight. I don't even know where we - we were probably taking him to and he was lust • Jeffrey 5 A. I can't remember. S introduced him as his brother and it was very short, O. Mark? 6 you know. just, 'Oh, hi. How are you?*, and he went 7 A. I remember meeting. 7 in the back. a O. Mark Epstein strike — 8 O. Do you know anything about the guy? 9 A. Honestly. I can't say for sure. 9 A. Uh'uh. 10 O. And how do you know that Jeffrey Epstein owns 10 O. Nothing? 11 the apartment building 11 A. Nothing. 12 A. Larry told me. I mean, it was just kind 12 O. So in 2001, there's a flight up there at sane 13 of known. 13 appointment in time, and you get off and you stay at one 14 O. Larry told you — 14 of the apartment buildings ate 15 A. Yeah. 15 A. Right. right. 16 O. - a Jeffrey tad you? 16 O. And did you meet any of the neighbor's of the 17 A. Oh, no, not Jeffrey, no. Larry. I 17 apartments that are also owned by Jeffrey Epstein? 18 wouldn't have asked Jeffrey. le A. No. no. because when we're there its 19 O. How many of those apartments up there in New 19 usually just for a night or something and then, you 20 York is it your understanding that Jeffrey owns? 20 know, we're either airlining home or going on. 21 MR. REINHART: I'm sorry, are you asking 21 O. How did you know Darren Indyke? 22 how many units are in the building or how many 22 A. He's our -- He's our business attorney for 23 buildings? 23 JEGE. 24 BY MR. EDWARDS: 24 O. Do you remember any of the other tenants of 25 O. No. how many units that Jeffrey owns in the 25 the apartments at other than Darren • Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, Fi. 33301 www.eSeuiresolutions.com 3501.150-002 CONFIDENTIAL Page 29 of 92 EFTA_013068821 EFTA01247049 Larry Eugene Morrison - Volume I October 6, 2009 109 111 1 2 3 4 maym and ==? A. O A. Not that I remeMbef, no. How about Leslie Groff? I don t think Leske rived there. I 2 3 4 of the MC2 shoots? A. t never heard There was one incident •• The only thing I remember about it is they were on a shoot - and ire not hinny. but Jeff but d is in a • O. Do you remember that name? s way • they were in a mow home on location at the 6 A. Yet She's Mr. Epsteins secretary. 6 shoot. and they started to drive off and one ol the 7 O. What ab0ut 7 models asked to use the resin:CM and they told her 8 A. no. I dont think so. a which door it was and she went out the side door, so 9 O. Jell Fuller/ 9 grabbed the wrong door, but that's actually the only 10 A. I dont know Jeff Fuller. I doll even 1o thing that sticks in mind - was that one. 11 know Jeff Fuller. 11 0. Have you ever done any research on Jean Luc 12 O. Do you know the name Jean Luc Brunet? 12 Brunel? 13 A. Yes. 13 A. No. 14 O. How do you know that name? 14 0. Do you have any idea that he's known 15 A. He's been He was a paSsenger cn a few 15 throughout Europe as somebody who has sex with underage 16 of our eights. 16 girls? 17 O. Do you know why? 17 A. No. 18 A I think he was I deal know for sure. 18 0 You didn't know Mal until right now? 19 He's In a mode/no business with Mr. Epstein, I 19 A. Correct. 20 believe. 20 O. That's Something that you're learning as a 21 0. MC27 Do you know that name - MC2 Modeling 21 surprise to you 22 Agency used to be Karin Modeling Agency, now it's MC2? 22 A. Yes. 23 A. No. 21 O. So-- somebody you never hoard 24 O. Hew do you know about his and Mr. EpsteMS 24 Or 25 modeling agency? How do you know that? 25 A. II sounds famkar. I'm trying to place 110 112 1 2 3 4 A. Just every once in a while he VMuld Say something about, you know, one 01 the model shoots or something. We normally had hen on - we would take ten back and forth to Paris. 2 1 4 her. I don't know if she works in the office or -- O. A. Or worked in the office? Worked in the office, yeah. I very rarely went to the office. I mean - • 5 O. Where some of their models come from? O. - how do you know her? 6 A. I don't know. 6 A. From the flights - being on the airplane. 7 O. Did you ever bring some of the Paris models 7 O. How many times was she on the airplane? I back? a A. Quite a few. Almost every. 9 A. Not that I'm aware ol, no 9 O. Mars your understanding as to what she did 10 MR. PIKE: Form. 10 for Mr. Epstein', 11 BY MR. EDWARDS: 11 A. 12 13 O. So he would go to Pans on the airplane. Jean 12 • Luc, would you drop him off there or would you pick 13 I 14 people up and bring Mem back? 14 15 A. If I remember, normally we were brining 15 O. Did Mr. Epstein ever once mention to you that 16 Jean Luc from Paris to New York. ill remember. 16 he likes massages? 17 O. And when you say that the modeling agency - 17 MR. PIKE: Form. 1$ obviously that, you know, between him and Mr. Epstein • 18 A. No. he never mentioned that to me. 19 is that something that Mr. Epstein would talk 10 you 19 O. That's not something that you ever heard of. 20 about or is that something that Jean Luc would talk to 20 right? 21 you about or you would just overhear the two? 21 A. Well, I -- 22 A. Overhear the two, or Jean Luc may say 22 O. I mean, outside of the articles that you've 13 someMing about one of the shoots or something, just 23 read. 24 in general conversation. 24 A. Right. No. but he never came up to me and 25 O. And what would Jeffreys comment be about some 25 said. 1 like massages.' Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.00m 3501.150-002 CONFIDENTIAL Page 30 of 92 EFTA_00068822 EFTA01247050 Larry Eugene Morrison - Volume I October 6, 2009 113 115 • 1 2 3 4 O. And did - did you hear her organizing, scheduling, talking to people about either what she may call 'work" or 'massages' for Epstein? A. No, no, I dont 1 2 3 4 always sat it by his office in the back. O. Always had a computer? A. No, no, it's just a large briefcase. O. Did you ever know his e-mail? MR. PIKE: Form. 5 A. Yeah, I had it I can't remember what it 6 BY MR. EDWARDS: 6 was and I don't think it's even current - but when I O. What types of conversation, if you can 7 would have to send him e-mails about the interior or 8 remember anything, did you ever overhear a maintenance issues. It was jeprojects, or something 9 talking about? 9 like that, at -- I don't know if it was at Yahoo or 10 A. It would be mostly like transportation 10 gmail. I don't think it was gmall. 11 arrangements - car needs. 11 O. You think it was jeprojects? 12 O. Car needs for who? 12 A. I believe so, but I can't remember what 13 A. Well, making sure that the driver in New 13 service. 14 York was meeting the airplane at the proper time, 14 O. At gmail.com or something? 15 stuff like that, or if they had an unusual large 15 A. Or something like that or Yahoo or 16 amount of baggage, to make sure that another car was 16 something. 17 hired to come pick this up. things like that 17 O. How about Ms. Maxwell? 18 logistic-type stuff. 18 A. It was I think. 19 O. We're still talking about a time period back 19 O. Do you know rf that's still current? 20 in right. vi these 20 A. No, I don't. 21 A. No. M. I donl remember coming 21 O. How about 22 into the picture until later. 22 A. I had it at one time and I know she 23 O. Later inMsomething? 23 changed it and I don't know what it is. I can't 24 A. No. she wasn't around at first. 24 remember what It was, actualty. 25 O. Alright. 25 O. Do you know where she is 114 116 • 1 2 3 4 A. No. I don't remember when oxactly but she O. Who was mak, and such prior to Ms. arrangements for meetings 1 2 3 4 right now? A. No. O. Do you know it she's intentionally on the lam to try to avoid being deposed in this case? 5 A. Ms. Maxwell. A. No. 6 O. -- that you remember? 6 MR. PIKE: Form. 7 So Maxwell was the. for all intents and 7 A. No idea. I haven't had any contact with purposes, the before MI since I slopped flying. 9 A. existed? 9 O. You say that was just coming in the 10 O. you ever Maxwell making 10 picture is the words that you used. What did you mean 11 arrangements for massages or for girls or anything else? 11 by this? 12 A. No. 12 A. Wet I mean she was just I'm trying to 13 MR. PIKE: Form. 13 remember when I first started seeing her on the 14 BY MR. EDWARDS: la airplane. 15 O. Where were the conversations • whether it was IS I can't remember the exact date. 16 travel or whatever else - that was occuning between 16 O. When did you stop flying? 17 Maxwell and/or MIIM? Where were they taking 17 A In February of '07. 18 place - on the airplane, some office? 18 O. February '07? 19 A. Yeah. No, no. usualy in the cockpit, you 19 A. Yep. 20 know, prior to departure, en route slating, 'We've 20 21 got this many cars and rye Contacted' or tan you 21 22 call such and such to have this brought cut?' 22 23 O. Did you ever see Epstein work a lot? 23 24 MR. PIKE: Form. 24 25 A. He always had a briefcase with him and he 25 • 0 Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esqulresolutlons.com 3501.150-002 CONFIDENTIAL Page 31 of 92 EFFA_00068823 EFTA01247051 Larry Eugene Morrison - Volume I October 6, 2009 117 119 1 I 4 0. Do you know where she came from? A. Just what rye read in the paper 1 2 3 4 A. No. O. A. No. in the back of the airplane. O. So anything could go on. You would have no • I I'm sorry. I daft remember the 5 idea. 6 country. 6 MR. PIKE: Form. 7 0. Were you ever told that Mr. Epstei 7 BY MR. EDWARDS: 8 O. You could sit here and testify truthfully, 9 have no clue what's going on back there.' J 10 A. That's correct. That's correct. U 11 O. Darren Indyke - what's your understanding as 12 to his involvement with Mr. Epstein? 13 0. Did you ever see him and her sexually involved 13 A. An attorney forme company. 14 en the airplane or otherwise? 14 O. Ever met Alan Dershowitz? 15 A- No. 15 A I think Yes. 16 O. Did you ever see Epstein involved sexually 16 O. How did you meet him? 17 with anybody on the airplane? 17 A. Alan Dershowitz. I don't know if it was 18 A. No. 18 Mr. Goldberger or Alan Dershowitz. We brought some 19 O. Did you ever see the airplane used for sexual 19 attorneys down •- 20 purposes? 20 O. Why? 21 A. No. 21 A. -- to Florida one time. 22 MR. PIKE: Form. 22 0. Why? 23 BY MR. EDWARDS: 23 A. For Mr. Epstein. It was right before i 24 O. It it had happened - considering the various 24 finished flying. For Mr. Epstein to make an 25 areas that were cordoned oft or blocked off would that 25 appearance at the courthouse or a meeting or 118 120 1 2 3 4 have even been something that you could have seen? A. No, no, if it was • if the doors were closed, no. 1 2 3 4 something, and we brought some attorneys with him. O. And were you aware then of the allegations against Mr. Epstein? • 0. So there's a back room that you've described A. They were starting to brew, yes. 5 that has a bed in it, and if that door's closed you don't 5 O Were you still actively working on his payroll 6 know what's going on behind dosed doors, right? 6 at the time when the investigation was going on? 7 A. ?bars correct. 7 A. Yes, when it lust started. 8 MR. PIKE: Form. 0. And did that impact you in any way as to 9 BY MR. EDWARDS: 9 whether or not you wanted to be affiliated with this 10 O. Do you remember a time Epstein was back in 10 person? 11 that back room with other people? 11 A. Subconsciously, it may have. And it 12 MR. PIKE: Form. 12 wasn't because of this person, but as a business 13 A. No. 13 decision, if, you know, an airplane's not needed and 14 O. Are you saying it never happened while you 14 I don't fly, I could be out of work. But, no. the 15 were on the airplane? 15 primary reason was the fact that I did want to get 16 A. I really have no idea of knowing because, 16 off the road and back home. 17 one, we never go back there unless we're invited 17 O. 18 back. U 19 O. Okay. U 20 A. And the forward door • the very forward 21 salon door is dosed, so we never even normally go I 22 into that -- 22 O. I'm assuming you're aware of the 'actual 23 O. SO you don't really know -- 23 allegations in these complaints? 24 A. -- without permission. 24 A. Yes, yes. 25 O. You don't really know what happens -- 25 O. And you are aware that there are hundreds of S Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esgulresolutIons.com 3501.150-002 CONFIDENTIAL Page 32 of 92 EFTA_00068824 EFTA01247052 Larry Eugene Morrison - Volume I October 6, 2009 121 123 • 1 2 3 4 girls who are underage who claim to have had sex with Mc Epstein as well as Ms. Maxwell at various times? MR. PIKE: Form. A. l was only aware of —first time was 1 2 3 4 O. Okay. I'll ask it a different way. A. Because we have had -- You know, he's got a goddaughter and godson that were young. I mean. O. Okay. Over the years -- 5 made aware of it, ol the number of people, was when 5 A. I mean, I don't know what the purpose -- 6 they served me the subpoena. The deputies or 6 O. Right. I totally understand what you're 7 retired ? saying. 8 O. Yes. 8 Over the years. when you were on Jeffrey 9 A. private eyes told me that. That was 9 Epstein's airplane, were you aware between 2001 and 10 the first I had heard a number. 10 wherever you stopped, 2007 -- 11 O. Were you completely oblivious that this was 11 A. Seven. 12 going on? And by 'this' I mean Epstein and/or Ghislaine 12 O. -- were you aware of girls that appeared very 13 Maned endlor recruiting 12, 13: 14, 13 underage on the airplane? 14 1S-year-old girls to his house for sex? 14 A. No. 15 A. Absolutely I was oblivious to X 15 MR. PIKE: Form. 16 MR. PIKE: Form. 16 BY MR. EDWARDS: 17 BY MR. EDWARDS: 17 O. I'm not saying what was happening on the 18 O. If young girls were on an airplane that you 18 airplane. I'm just saying, were you aware of it? 19 were on • considering mat we've now established how the 19 A. No. not • unless they were there, like I 20 airplanes set up and you're kind of cordoned elf is a 2o said, his goddaughter at the time. One time • a 21 possible that underage girls would have been on the 21 couple times we flew her with her mom and dad where I 22 airplane and you just wouldn't have known about it? 22 don't even know their age. 23 MR. PIKE: Form. 23 MR. PIKE: Again, 1000. asked and 24 A. No, no. I mean, people don't board the 24 answered. 25 airplane with - you know, and then just say. 'Close 25 A. Six or seven. But, no, I was not aware of 122 124 • 1 2 3 4 the door, we're going.- You know, you see who boards tho airplane. O. So if there wore flight records that show underage gins on the airplane, you would know about it? 1 2 3 4 anybody that was obviously, blatantly underage. O. Any famous people that you can tell me that were on the airplane? A. President Clinton - Ex-President Clinton. MR. PIKE: Form. 5 O. Were you on the airplane -- 6 A. Not necessarily. 6 A. Yes. 7 O. Well, how not? 7 O. -- when he was on it? MR. REINHAF17: I'm sorry. A. Yes. 9 A. Well how do you -- 9 O. How many times? 10 MR. REINHART: When you say 'them,' do you 10 A. Two trips. I mean, two extended trips. 11 mean he would know about the records or he would 11 O. Where did it go? 12 know about the girls allegedly on the plane? 12 A. The first one - or the first one was Asia. 13 BY MR. EDWARDS: 13 O. What purpose? 14 Q. You would know about the underage girls on the 14 A. I forget what the purpose was on that one. 15 airplane if they wore on there. 15 O. Was Jeffrey Epstein on the airplane as well? 16 MR. PIKE: Form. 16 A. Yes, yes. 17 A. How do you -- How would I know that 17 O. Who else was on the airplane then? 18 they're underage. though? 18 A. I don't remember on that one. It was 19 O. Well, you would only know that they look 19 primarily him and his su rt staff. 20 extremely young, right? 20 a Was 21 A. But -- 21 A. Probably, yes, probably. 22 MR. PIKE: Form. 22 O. When's the next time President Clinton was on 23 A. -- what is the intent of them? I mean, 23 his airplane? 24 are they guests or are they friends of his associates 24 A. I dent remember the date, but we did a 25 or -- 25 Africa trip, an AIDS awareness tour. We did like ten • 0 Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresofutions.com 3501.150-002 CONFIDENTIAL Page 33 of 92 EFTA_00068825 EFTA01247053 Larry Eugene Morrison - Volume I October 6, 2009 125 127 1 2 3 4 countries in 12 days. O. Is that a time Chris Tucker -- A. Yes. O. and Kevin Spacey were also on it? 1 2 3 4 MR. EDWARDS: No. I mean, unless everybody wants to lake a lunch break. Everybody's shaking their heads, so, no, I'm going to take a bathroom break. and its going • A. Yes. 5 to be a fast one. 6 O. In addition to the people that we've named. 6 MR. PIKE: Okay. 7 wore there females on that airplane? 7 BY MR. EDWARDS: A. Yes. O. In 2001, when you're on this flight to New 9 O. And who were the females that were on the 9 York and then during that year we talked a little bit 10 airplane? 10 about it, is Larry Visoski and David Rodgers also on some 11 A. Can't remember. Ms. Maxwell, I can 11 of these flights? 12 remember, and a oouple others, and there's - Mr. 12 A. Most, yes. 13 Clinton had - a couple of his support staff were 13 O. If somebody's going to keep passenger logs. 14 women also. 14 who's gang to write down the names of the people? Is 15 O. Where wore you sitting during these trips? 15 that going to be you or is that somebody else's 16 A. Up front in the - my station. 16 responsibility? 17 O. Could you see what they were clang where you 1? A. Whoever is captain. 10 wore? 18 O. So normally its Visoski or David Rodgers? 19 A. No, no. 19 A. Correct. 20 O. Could you tell If there was any sex going on 20 O. Who do you turn these logs into? 21 on the airplane while you were on it? 21 MR. PIKE: Form. 22 A. No. 22 A. I don't know. I don't know where they go. 23 MR. PIKE: Form. 23 O. You don't know the purpose behind keeping them 24 BY MR. EDWARDS: 24 or anything? 25 O. Do you know of any underage girls being on 25 A. No. 126 128 1 2 3 4 that airplane or would you have been able to tell? A. No. MR. REINHART: Im sorry -- MR. PIKE: Asked and answered. 1 2 3 4 O. As far as you're concerned, you don't even need to keep them. A. Correct. Yeah. O. As just due diligence - going above and • 5 MR. REINHART: -- are you limiting it to 5 beyond? that trip? 6 A. Correct. 7 BY MR. EDWARDS: 7 O. Today you have an attorney sitting right next 8 O. To that trip. 8 to you, right? A. No, I'm not aware of it. 9 A. Correct. 10 O. II you had been aware of underage girls being 10 O. Is that somebody that you've known tor a long 11 transported on the airplane for the purposes of sex. 11 time? 12 would you have said something to somebody? 12 A. No. 13 A. Yes. 13 O. You're paying for an attorney to sit here with 14 MR. PIKE: Form. 14 you? 15 MR. EDWARDS: Do you mind l we take a 15 A. No. 16 five-minute break? I just have to run to the 16 O. Who's paying for your attorney? 17 bathroom. 1? A. Mr. Epstein. 18 MR. PIKE: Actually, Brad. can you hear 18 O. Are you worded that you're criminally 19 me? 19 involved here or something? Is that why you need an 20 MR. EDWARDS: Yes. 20 attorney? 21 MR. PIKE: How much longer do you 21 A. No. I don't even know anything about this 22 anticipate going with this witness? 22 process, that's -- 23 MR. EDWARDS: Hour, maybe a little longer. 23 O. Oh. okay. 24 MR. PIKE: Well, are you going to take a 24 A. I'm just You know. 25 lunch break or what? 25 O. How did you know that you were S Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 34 of 92 EFFA_00068826 EFTA01247054 Larry Eugene Morrison - Volume I October 6, 2009 129 131 • 1 2 3 4 O. MR. PIKE: Brad. Brad. Brad. - going to get an attorney - MR. REINHART: Brad, hold on. MR. PIKE: Whoa. Whoa. Stop. 1 2 3 4 this case against Mr. Epstein? MR. REINHART: Let me ask him not to answer that. MR. PIKE: Form. 5 MR. EDWARDS: I'm listening. 5 MR. REINHART: It's privileged. 6 MR. PIKE: Brad. 6 MR. EDWARDS: It's privileged between Mr. 7 MR. EDWARDS: Go. Epstein and you, but is it privileged between 8 MR. PIKE: You are not allowing the 8 the two of you? 9 witness to finish his statements throughout this 9 MR. REINHART: Between Mr. Mornson and 10 entire depo. Please. I'm on the phone. You 10 me. 11 start your question before the witness is 11 BY MR. EDWARDS: 12 finished. I'm sorry for raising my voice, but 12 O. Is it your understanding that he represents 13 you must allow the witness to finish his answer. 13 you or he represents Mr. Epstein? 14 please. 14 A. He represents me. 15 MR. EDWARDS: You got it. 15 O. Okay. Do you think that you've done anything 16 THE WITNESS: What was your question now? 16 wrong criminally? 17 I forgot. 17 A. No. 1a MR. EDWARDS: I'm sitting here looking at 18 Q. Do you think that you're being sued civilly? 19 the witness and have a feeling we're going to be 19 A. No. 20 sitting here for 30 minutes, but I will do that 20 O. And you have no reason to be sued civilly, 21 for you, Mr. Pike. 21 right? 22 MR. PIKE: Alright. 22 A Correct. 23 THE WITNESS: What was the question again, 23 O. Did you talk to Mr. Epstein prior to taking 24 please? 24 your deposition today? 25 MR. EDWARDS: Can I ask the question again 25 A. Oh, no. I haven't talked to him in wel 130 132 • 1 2 3 4 or wait? IN wait for you. MR. PIKE: If I'm ready. MR. EDWARDS: I already asked the question, so we're waiting. 1 2 3 4 over a year-and-a-half, maybe two years, and that was just a 'hello' because I'm at the airplane one day. O. So how is it you know that Mr. Epstein paid for your attorney? 5 MR. REINHART: I think the witness asked 5 MR. REINHART: Its privileged. 6 you to repeat the question. 6 MR. EDWARDS: Okay. That answers my 7 MR. EDWARDS: Are you good? Alright. 7 question. 8 BY MR. EDWARDS: 8 BY MR. EDWARDS: 9 O. Who hired your attorney? 9 O. Have you ever met Donald Trump? 10 A. Mr. Epstein. 10 A. Yes. 11 O. And do you have any idea why, if you're a 11 Q. How? 12 witness In a case • no problems criminally - why you 12 A. He was He boarded the airplane one day 13 personally have an attorney paid for by Mr. Epstein to 13 when ours was on the ramp. 14 sit here with you? 14 O. And did you talk to him? 15 MR. PIKE: Form. 15 A. Just he introduced himself and I 16 A. No, I don't. 16 introduced myself. 17 O. Do you want an attorney to sit here with you 17 O. And did he talk to Mr. Epstein? 18 while I ask you questions? 18 A. No. Mr. Epstein wasn't present. I was 19 MR. PIKE: Form. 19 doing maintenance. 20 A. I don't know what the proper protocol is. 20 O. And did he fly on the plane? 21 O. Okay. 21 A. No. 22 A. I have very limited exposure to anything 22 O. Not that time? 23 like this. 23 A. Never. 24 O. Hoiv did this come about to where you have an 24 O. You think he never flew on the plane? 25 attorney as a witness - completely innocent witness in 25 A. On our airplane? Toll Free: • Facsimile: Suite 1300 ESQUIRE 515 East Las Ofas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 35 of 92 EFTA_00068827 EFTA01247055 Larry Eugene Morrison - Volume I October 6, 2009 :33 :35 1 2 3 4 O. Yes. A. No. O. So If somebody has given testimony other than that, you would say that person is mistaken or lying? 1 2 3 4 A. I have no idea I don't know. O. When you say that -was comet in the icture. what's your understanding as to who is relative to Mr. Epstein? lust • 5 MR. PIKE: Form. 5 A I dont know. I dont understand. I 6 A. Donald Trump was never on the airplane 6 don't know. I didn't know if maybe she was like an 7 when I was on the airplane. 7 exchange .• Jeffrey always appeared to be very O. Is it your understanding that Donald Trump is a involved in education and phaanthr0PY. I didn't 9 friends with Mr. Epstein? know if she was an exchange-type student or something 10 A. From what I've road • Or associates. I 10 or what. I dont know. 11 don't know how that circle works. 11 O. When you say he appeared to be *involved 12 O. What's your understanding as to who Mr. 12 what do you mean? 13 Epstein's real friends aro? 13 A. Educational things, foundations, science 14 A. I really don't 'mow. I don't I don't 14 foundations, and things. 15 know. It's It's not lee the Wexners whore. you 15 O. Speaking of - the Florida Science Foundation 16 know, they were high school associates. you know. 16 is a place where. when he was on work release. he spent a 17 grooving up. 17 IN of time there. you're aware of that? 18 O. Do you know what Mr. Epstein did prier 10 18 A. That's what I've heard, yeah. 19 managing the money for Mr. Wexner? 19 O. What does that place do? 20 A. Just that he was a Wall Street broker or 20 A. I have no idea. 21 somebody, you know. 21 O. Does it do anything? 22 O. Also from reading? 22 A. I dont know. I don't know anything about 23 A. Yes, yes. 23 it. 24 O. Do you know any personal knowledge as to what 24 O. Certainly you've read certain newspaper 25 Mr. Epstein has told you about how he made money? 25 articles about the allegations. Polide MOM 134 136 1 2 3 4 A. He's never -- MR. PIKE: I'm going 10 move to strike any responses relative to what the witness has learned from reading. 1 2 4 otherwise, the allegations that occurred or have been alleged to have occurred at his Palm Beach mansion. Correct? A. Uh'huh. • 5 BY MR. EDWARDS: 5 O. Correct? 6 O. And so that is why I asked the question: Has 6 A. Correct. 7 Mr. Epstein told you? Which would have nothing to do 7 O. Given the nature of those allegations, would s with reading. 8 you leave with Mr. 9 A. No. 9 Epstein alone? 10 O. How many conversations have you personally had 10 MR. PIKE: Form. Move to strike. 11 with Mr. Epstein? 11 A. Yes. 12 A. No personal conversations - all business. 12 O. You would? 13 O. Have you witnessed AncEpstoinvath any VS 13 A. (Witness nods head.) 14 that look to be under the aged 18? 14 O. And why? 15 A. No. 15 A. Because I don't fear that he would try 16 O. Have you witnessed Mr. Epstein with 16 anything with He showed -- When I 17 younglooking girls that appear to be in their twenties? 17 worked for him he showed me respect. He never -- I 18 MR. PIKE: Form. 18 never -- He never showed me disrespect. He would ask 19 A. Yes, 19 how the family Is. I mean, not on a personal level, 20 O. On how many Oteasions? 20 but an employer/employee. 21 A. Probably several. 21 O. Right. Okay. 22 O. And how did that come about? 22 A. He never showed me any reason not to trust 23 A. I mean, they show up and ride on the 23 hirn. 24 airplane, you know. 24 O. Bul you're not a 13-year NO girl, so. 25 O. And who are they, if you know? 25 A. No. but, like I say, he never showed me 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.corn 3501.150-002 CONFIDENTIAL Page 36 of 92 EFTA_00068828 EFTA01247056 Larry Eugene Morrison - Volume I October 6, 2009 137 139 • 1 2 3 4 any reason not to trust. O. So maybe that's the reason why there were hundreds of victims, right? A. I don't know that there were. 1 2 3 • know her if I saw her. O. What did she do? A. I don't know. I don't know. O. Would it surprise you if she was in charge of 5 O. So is it surprising to read the things that 5 scheduling for the minors to come over to the house to 6 you read about what was going on at his house? 6 sexually gratify Mr. Epstein? 7 A. Yes. 7 MR. PIKE: Form. MR. PIKE: Form. Move to strike. A. Yeah, that would surprise me, yes. 9 BY MR. EDWARDS: 9 O. Okay. She didn't do that while you were on 10 O. I'm going to ask you about -- I'm going to 10 the airplane, right? 11 mark them all In fact, I'm going to show them to your 11 A. No, no. 12 attorney first because I'm going to mark them as a 12 O. Was Mr. Epstein on the airplane? 13 composite - just to save time. 13 MR. PIKE: Form. When? 14 MR. REINHART: For the record, you've 14 A. Yes. 15 handed me a stack of passenger manifests? 15 O. And if it happened. it happened al a portion 16 MR. EDWARDS: Yes. You can count them if 16 of the airplane where you couldn't see it because you 17 you want, doesn't matter to me, and we'll just 17 were partitioned off? 18 mark them as a composite • go through each one 18 A. What happened? 19 of them. 19 MR. REINHART: I'm sorry, can we just get 20 MR. REINHART: If you're going to go 20 a timeframe? 21 through each one of them, I don't need to count 21 MR. PIKE: Form. 22 them. Youll make a record on that. 22 MR. REINHART: Are we talking about this 23 MR. EDWARDS: Fine. I'm going to mark 23 MONT 24 these as Composite Exhibit I, and we'll count 24 MR. EDWARDS: Yes, we're talking about 25 them at the end. 25 that flight. 138 140 • 1 2 3 4 (Defendants Composite I was marked for identification.) BY MR. EDWARDS: O. The first one's datec il. Can you tell 1 2 3 4 BY MR. EDWARDS: O. It anything happened on the airplane. it would have been in a position where you couldn't see it anyway A. That's correct. 5 me what we're looking at there? Just remember. I'm about 5 O. Okay. 6 as familiar ynth that type of sluff as a three year old. 6 A. That's correct. 7 so help me out. 7 O. So you're nil saying it did happen or it A. Passenger manifest just showing basicely didn't happen, you just Couldn't see past a certain 9 dale, time oft time on, the trip number of the year. 9 point. 10 I guess it would be - that seems high for the year - 10 A. Correct, and I don't know what you're 11 but trip number - that must be for the total • 11 referring to as it . anyways. 12 destination or departure point • destination. 12 O. 'It' is whatever sexual involvement there was. 13 O. The trip number says. 'Sit.' What does that 13 A. Oh. Like you say, we can't see anything 14 mean? 14 back there anyhow because the doors are closed. 15 A. Thai must be I don't know where they 15 O. Did Mr. Epstein instruct you as to whether or 26 start that. That must have been total since he 16 not to knock or just walk back there or never walk back 17 staned the airplane. That's way too many for the 17 there or what was the instruction? 28 year. Obviously it's already - it's January. so it 18 A. No. There was never actually a formal 19 must have been total flights. 19 instruction. Its proper protocol for any of these 20 O. Who's on that airplane? 20 gentlemen, or individuals that own these aircraft, 21 A. Nautical miles. statute miles, fuel 21 that that's their private zone. that you don't come 22 burned, poundage. 22 back unless you're needed, and then you can -- You 23 anal .1 23 know, but it's not forebode, it's just proper. 24 O. DO you know 24 O. You mentioned President Clinton on the plane. 25 A. I — I think I know het I think I would 25 How many girls were on the plane at the same time when • 0 Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com 3501.150-002 CONFIDENTIAL Page 37 of 92 EFTA_00068829 EFTA01247057 Larry Eugene Morrison - Volume I October 6, 2009 141 143 1 2 3 4 President Clinton was on the plane? MR. REINHART: Asked and answered. A. Yeah, I don't remember for sure. There was probably maybe live, if that, and Oral's 1 2 3 4 you familiar with a flight where Prince Andrew was on the airplane? A. I don't know if I remember him being on the airplane or not. I know that he has been on the • 5 0. What were they -- 5 airplane or one of the airplanes. I can't say for 6 A. What? 6 sure. 7 0. Go ahead. 7 0. Have you met him before? A. Like I say, it was Ms. Maxwell, A. I can't remember. honestly. I know. 9 maybe two others, one other. and then I think Mr. 9 0. Can't remember meeting Prince Andrew? 10 Clinton had two ladies in his entourage - support 1o A. I know. I know. I *MI even know who 11 staff. 11 he was when I first heard the name, sorry. But, no, 12 0. What age group are we talking about with the 12 I can't remember for sure, I'm sorry. 13 ladies that were on the airplane? 13 0. Theta like if E.T. walked on the airplane and 14 MR. PIKE: Form. 14 I don't know. 15 A. Mid-twenties to forties. maybe. I mean. I 15 A. I know. Well -- 16 don't know exactly. 16 0. MOVIE III let you slide on that one. You 17 0. I mean. you know what a 13 or 14-year-old girl 17 know who Prince Andrew is now. 18 looks like -- 18 A. Okay. Don't paint me as stupid. One of 19 A. Yes. 19 Lady WS sons. right? 20 O. -- right? 20 0. I mean, you know what he looks like now 21 A. Yes. 21 A. You know, honestly. I don't know if I 22 O. Most people do. 22 could point him out to you, I'm sorry. 23 A. Yes. 23 0. Alright. 24 O. You wouldn't mistake a 13 or 14 or 15 year old 24 A. Its Just 25 fora 20 year old. 25 0. Well forget him. 142 144 2 3 4 A. No, no. MR. PIKE: Fenn. BY MR. EDWARDS: 0. So you're sure that the people that were on 1 2 3 4 A. I'm smart in some things. 0. Wel forget him. We'll forget him. Don't worry about it. What's this? What are we looking at? • 5 the airplane - they were above the age of 18? 5 MR. REINHART: For the record, you handed 6 A. I believe s0. 6 him a manifest dated is that 7 0. Because you, in your experience. as well as 7 correct? the experience of most people your age, would know -- THE WITNESS: January -- Yes. Correct. 9 A. Right. 9 Palm Beach to Kennedy, same thing, fuel 10 0. - what a 14 or 15 year old looks like. 10 bums, loads. destination, time off, time on. 11 A. Right. 11 Next, it was trip 312. Jeffrey is on it, M. 12 0. I'm going to go through the next flight log. 12 David Mullen, M. Todd Myster (sic). 13 You tell me what we're looking at here. Who's on the 13 and passenger, passenger. 14 airplane? 14 BY MR. EDWARDS: 15 A. That was a deadhead. Nobody's on it. 15 0. Do you know Todd Meister? 16 0. Why were the names crossed out? 16 A. Ho's a friend of his, I believe. 17 A. Because there was no passengers. This was 0. Fathers Bob Meister? Do you know the names? 18 - engin was West Palm Beach - West Palm Beach. What 18 A. No, I don't know that. 19 date is Mis? 1/20/04? It was probably a test 19 0. How do you know Todd Moister? 20 flight. 20 A. I've rust heard the name. 21 0. Okay. 21 0. From who? 22 A. It was a training flight -- 22 A. Larry Visoski. 23 0. Okay. 23 0. Larry Visoski knows these people? 24 A. -- for Bill. 24 A. I think Todd Meister has an airplane. or 25 0. The next one -- Well, before I ask this: Were 25 something like that. He's talked to their flight 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 38 of 92 EFTA_00068830 EFTA01247058 Larry Eugene Morrison - Volume I October 6, 2009 145 147 O. • 1 2 3 4 crew. 0. For the most part, when you mention these people's names. you mention them as if they're lust passengers on the airplane and this is their world - 1 2 3 4 Well, do you know whose handwriting that is? A. No. no. I don't. It may be Larry's. 0. Similar handwriting - A. Wait a minute. s you're passing through, you don't know them. 5 0. - as those - 6 A. Right. 6 A. Let's see the one with the training 7 0. But Visoski - would you say that he has a 7 because there's a different pilot on there. closer relationship with Epstein to where he might know 8 0. Right. One where there Is nobody on it. 9 some of these people? 9 right? 10 MR. PIKE: Form. 10 A. This is Bilrs I can't - TNs is 11 A. That could be an accurate • yeah. I mean, 11 Bill's writing. I think he was having him fill out 12 he's been with Jeffrey longer. I mean -- 12 the paperwork. 13 0. I mean, do you know that Visoski has a car 13 0. Bill Hammond? 14 that is registered In Jeffrey Epstein's name? You don't 14 A. Yeah, this was his training flight. 15 have anything like that, do you? 15 0. The first one is Visoski? 16 A. No. I did not. 16 A. Maybe. I can't say for sure. I really 17 0. Were you aware of that? 17 can't say for sure. 10 A. No. 18 0. And this is? 19 0. Does Mr. Visoski tell you how far he goes back 19 A. I don't know if that's the same 20 with Jeffrey Epstein? 20 handwriting or not. 21 A. No, just. I mean, when he hired him. 21 0. Well, is there any indication up here that 22 whenever that was after Glimoher - that's all I know. 22 would tell us whose harxlwming rt is? David Rodgers and 23 0. Do you know anything about Visoski's private 23 Larry Visoski -- 24 life? 24 A. No, because this is -- 25 A. A little bit. He's married and 25 a are the pilots. 146 148 • 1 2 3 4 daughters. I mean -- O. Then I wont go Into the rest of his private life. When it says. '1 pay, I pay: what does that 2 3 4 A. Yeah, but they don't indicate - they don't indicate who's captain that day. You know. I'm not a handwriting expert. I can't really Honestly. I can't tell you for sure whose handwriting a was. S mean? 5 0. Let's keep Wis one out. and toll me If this 6 A. Ws TAX: P•A-X is short for 6 is -- I'm going to hand 7 'passenger: It's a Met MR. REINHART: O. Okay. Look, this is somebody that is listing 8 MR, EDWARDS: 9 names of people on an airplane. Theyre going out of 9 MR. REINHART: Yes. 10 their way 10 BY MR. EDWARDS: 11 A. Flight. 11 O. so two days later where 12 0. and then all of a sudden on No. 8 and 9 12 is this airplane going? 13 they say. 'one passenger: Is this person just getting 13 A. From Kennedy to Palm Beach. 14 lazy or is there a reason why there's no name? 14 0. And so this Is Palm Beach to Kennedy - 15 A. Like I say, just getting lazy and then 15 A. Yep. 16 didn't know who the passenger was. 16 0. in his exhibit. The next one is Kennedy 17 0. Well, they obviously didn't know who Todd 17 to Pon Beach. 16 Meister was either • they wrote his name all wrong. 18 A. Correct. 19 A. They did? 19 0. They come back. Where do they stay • do you 20 MR. PIKE: Form. 20 know? 21 BY MR. EDWARDS: 21 A. What do you mean? 22 O. Well, 'Meister' is not spelled like that, so 22 0. Well, they get off on theM they stay 23 how did -- 23 somewhere until they come back on the I. Do you know 24 A. I didn't -- I didn't know that. I don't 24 where they stay? 25 know how he -- How does he spell II? 25 MR. REINHART: Can we clarify who %hey Toll Free: Facsimile: Suite 1300 ESQUIRE AtensinO•11•Caspay 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutionS.00m 3501.150-002 CONFIDENTIAL Page 39 of 92 EFTA_00068831 EFTA01247059 Larry Eugene Morrison - Volume I October 6, 2009 149 151 1 2 3 is? BY MR. EDWARDS: O. I guess it is: David Mullen. M 2 3 O. The next one is to where? A. St. Thomas. Palm Beach • 4 6 ME Tod Myster (sic). 1 pax, another pax. Mand Jeffrey Epstein - and there's a crossed out 'Ghislaine Maxwell? so I'm assuming she didn't go. 4 5 6 O. To St. Thomas. A. Right. Q. And he has and MI and Jeffrey. 7 A. Correct. 7 A. Right. 8 I have no hoe where they stayed. I 8 O. Does he loll you what happens in St. Thomas? assume Jeffrey would stay in his home. M would 9 What he does there? 10 stay in her apartment. As for an the others, I have 10 A. No, no. 11 no idea. 11 O. Ever heard that he imports underage gins from 12 O. Have you ever been to Jeffrey Epstein's home 12 Brazil to his — 13 in New York? 11 MR, PIKE: Form. 14 A. Just in the lower level of the entryway. 14 O. - Island in St. Thomas? 15 O. Why did you go? 15 MR. PIKE: Form. 16 A. To pick up bags for the trip to go to the 16 A. No, no. never heard that. 17 airport and load them. 17 O. What does he tell you about his Island In St 18 Q. Was there anybody else there with him? 18 Thomas? 19 A. I don't know with him. I never saw him 19 A. Not a lot. I mean, he would sometimes 20 him. We saw the guy that ran the house 20 talk about construction stuff or I would hear him • 21 Q. Who's that - Joe-Joe? 21 overhear him and Larry talk about the helicopter pad 22 A. Joe-Joe would be there -- 22 that they're putting in, little stuff like that - all 23 O. What's Joe-Joe's name? 23 COOstruCliOn. 24 A. Joe-Joe, that's all] know, and then 24 O. Did he tell you two or three times a day, that 25 there's the actual house manager. Joe-Joe is more of 25 he sexually abuses girls between 12 and 15 years old? 150 152 1 2 3 a dnver, and then there's the house manager - forget his name. But, yeah. we would meet -- There's an 1 2 3 A. No. MR. PIKE: Form. BY MR. EDWARDS: • 4 office in the lower level that the bags would be at. 4 O. Not something he ever mentions. 5 and we would put them in the back of the van, haul 5 A. No, no. 6 them to the airport. 6 MR. PIKE: Form. 7 O. Who's David Mullen? 7 BY MR. EDWARDS: a A I don't know. I heard of il. It sounds 8 O. The next - who's on the passenger 9 familiar. I can't remember who he is. 9 list? 10 O. Somebody that lives in New York, Palm Beach? 10 A. Jeffrey, M. MI, Jean Luc, David 11 A. I don't know. I don't know. 11 Mullen, female, female, female. 12 O. I'm trying to keep them in order. 12 O. Any idea why they would list -female, female, 13 So taming bad( - you know. it looks Ike they 13 female' without listing the names? 14 take to JFK: David Mullen, Tod Myster (sic), some 14 A. No, just the same as -- The only idea I 15 passe era unnamed - they come back with only 15 would have would be the same reasoning for the - 16 and any idea why? 16 previously when they listed them as just 'PAX' - that 1/ MR. PIKE: Form. 17 they didn't have any idea who they were, what their 18 A. No, but, I mean, ifs not unusual for 18 name was. 19 these guys to, you know, take somebody • lel somebody 19 O. I mean, certainly that's -- 20 have a free ride to New York il they know them. they 20 A. I don't know whose handwriting that Is. 21 aro acquaintances, need a lift. I mean, that's not 21 O. You're guessing, though, right? 22 unusual. 22 A. Yeah. No, I'm guessing. I have no idea. 23 O. How's that come about - do you know? 23 O. Another guess would be they're 12 years old 24 A. No. I don't - phone conversations, 24 and you can't put them on it. 25 cosklail parties. I don't know. 25 MR. PIKE: Form. 0 Toll Free: Facsimile: Suite 1300 • ESQVIEE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutions.00m 3501.150-002 CONFIDENTIAL Page 40 of 92 EFTA_00068832 EFTA01247060 Larry Eugene Morrison - Volume I October 6, 2009 153 155 • 1 A. I wouldn't say that. I don't know that. 1 what n says 2 O. Have you ever been on an airplane where you 2 A. It's •• I think it's aM. 3 looked at this and you thought, -Hey, that's kind of 3 Q. Alright Can you tell us who's on that 4 strange that they wouldn't list them by name. They're 4 airplane? 5 talking about it generically: Female, female, female'? 5 A Jeffrey, looks like M, - is that 6 A. But they also -- 6 Jean Luc? 7 MR. PIKE: Form. O Yeah. A. on another one: PAX, PAX, PAX. a A. That's Jean Luc. I think. and 9 O. You never thought that was odd either? 9 10 A. No. I never actually even really paid 10 O. Jean Luc is another one who travels Quite 11 attention to this paperwork. I don't see this. 11 frequently. Why, if you know. does he travel quite 12 MS. EZELL: Brad, excuse me • this is 12 Irequentkr on these airplanes to and from New York with 13 Kathy Ezell - is there a date on that manifest 13 Jeffrey Epstein - any idea? 14 you're showing? la A. My only assumption was business, and 15 MR. EDWARDS: It's-. 15 that's just an assumption. 26 MS. EZELL: Thanks. 16 O. What kirKI of business do you know of that they 17 MR. EDWARDS: Is that your 12-year old 17 have in common? 18 client listed as No. 6? 18 A. I was under the impression a modeling 19 MR. PIKE: Form. Move to strike. 19 business. 20 MS. EZELL: No, but -- 20 O. Other than the modeling agency, %Mat other 21 MR. EDWARDS: Okay, sorry, somebody 21 business do they engage in together. if you know? 22 eleet. 22 A. I don't know. 23 MS. EZELL: Okay. Thanks. 23 O. Arid has Jeffrey Epstein ever talked to you 24 BY M DS: 24 or loud enough to which you could hear him discussing the 25 O. whop on them? 25 modeling agency? 154 156 • 1 2 3 4 A. Ja i n Jensen, ME. David Mullen, O. Do you lawny who Jansen is? A. No. 1 2 3 4 MR. PIKE: Form. A. No, just that the only conversation he ever - I remember - was the one that he the one aboul the girl opening the wrong door on the motor 5 O. David Mullen travels a lot. Do you have any 5 home. 6 idea whet his relationship is with Mr. Epstein? 6 O. Was he happy or sad about the modeling agency/ 7 A. I don't even know who David Mullen really 7 A. No. he was happy she wasn't injured. but is 8 he was kind of making light of what a silly thing to 9 O. Have you ever seen him? 9 do, you know. 10 A. I might be able to place him if I saw a 10 O. Do you know if Jean Luc is the one procuring 11 picture of him. II the models or IS Jeffrey procuring the models? 12 O. I mean, obviously you're on the airplane with 12 A. I don't know. 13 him a lot. 13 MR. PIKE: Form. 14 A. Yeah, so. I mean, obviously I would 14 BY MR, EDWARDS: 15 recognize him if I saw a picture. 15 O. You never investigated into how this modeling 16 O. Do you know if he travels with anybody else on 16 agency is defog or anything else? 17 this? 17 A. No. no interest 18 A. Unless It's that one name I don't 18 O. You try to stay completely out of it? 19 recognize - that Jansen. or whatever. 19 A. No interest. 20 O. But Jansen's not somebody you know? 20 O. Especially in light 01 the recent things 21 A. No. no. 21 youve read. 22 O. I can't read that date • maybe you can. I got 22 A. I mean, I ain't have any interest in it 23 a bad fax copy. 23 before all the recent things. 24 A. MaybeMl. 24 O I'm going to slop this one because it talks 25 O. That's Michael Pike not wanting me to know 25 about very similar people that you've already read. • 0 Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutionS.com 3501.150-002 CONFIDENTIAL Page 41 of 92 EFFA_00068833 EFTA01247061 Larry Eugene Morrison - Volume I October 6, 2009 157 159 1 2 3 4 A. O. Okay. No different names. MR. REINHART: Can we just get the date on the record? 1 2 3 4 Stanleys are. O. Ever heard of them? A. No. O. As far as you're concerned, they're some • $ BY MR. EDWARDS: 5 islanders or something, right? I mean - O. Well, actually, we don't have to skip it. A. Well, they might be mean 7 that's the date. right? MR. PIKE: Form. 8 A. Right. 8 A -- there's a tot of wealthy people down 9 O. And it says: Ghislaine Maxwell — 9 there. They might have been friends or associates 10 A. Okay. 10 that needed a lift back stateside. 11 and 11 O. Fair enough. 12 (81c); is that right? 12 What's the next one? 13 A. That's what it says. 13 A. Teterboro to PIK 14 O. Is that a typical crew that you would see on 14 O. And who's on it? 15 the plane? 15 A. Jeffrey. =, and M. 16 A. What year is this? In .? 16 MR. REINHART: Can we gel a date for the 17 O. Yes. 17 record? 3.8 A. Yes, but towards the end there, I think 16 THE WITNESS: 19 the last year, l only saw Ms. Maxwell once. 19 BY MR. EDWARDS: 20 O. Do you know of any falling out of sorts that 20 O. II seems like =and travel a lot 11 Ohislaine Maxwell and Epstein had? 21 with Jeffrey. Is it ever your understanding that Jeffrey 22 A. Well, no. I think they still I think 22 Epstein had a sexual relationship with either of them? 23 she still has a lot of association, or whatever. 23 A. That is not my understanding, no. 24 O. Do you think they are still a couple? 24 O. Do you know of having a boyfriend 25 A. I don't know that they ever were. I never 25 ever? 158 160 1 2 3 4 did figure out the relationship, other than I assumed they were a couple and she was a business assistant - associate, but that was all assumption. O. Did you ever know of Jeffrey Epstein to have a 1 2 3 4 A. I heard that she has a boyfriend. O. And what's his name? A. And this is just hearsay. I don't know. O. I'm interested in hearsay. • girlfriend, per se? 5 A. I heard that she's dating somebody - 6 A. If it would have been, it would have been that's all. 7 Ms. Maxwell. 7 O. °atm whom? 8 O. Other than Ms. Maxwell, could you identity any 8 A. 9 other female that appeared to be in a intimate 9 O. phonetic)? 10 relationship with Jeffrey Epstein? 10 A. I don't know his last name. 11 A. Not really, not that I - not that I could 11 O. How long has she been dating him? 12 say it was a relationship, no. 12 A. I don't know. This is just Larry, you 13 O. I'm going to show you another one. I don't 13 know, every once in a while asks. you know, 'What's 14 know these people. Tell me who they are. It looks like 14 going on?' 'Who's' -• You know, I don't know. 15 you're on the airplane -- 15 O. Where Wes aye? 16 MR. REINHART: Can we et a -- 16 17 O. -- and the date 18 A. Right. 18 O. And is somebody who you heard of through 19 O. It's 19 Larry \kiosk'? 20 going -- 20 A. Yes. yes. 11 A. I don't know who the Stanleys are. 21 O. And SpeCifiCalty what did Larry Visoski say 22 O. And it's going from the island. 22 about 23 A. To -- 23 A. He thought that they were dating he and 24 O. Palm Beach. 24 - and this is all hearsay. 25 A. Palm Beach. I don't know who the 25 O. Since when? 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esgulresolutions.com 3501.150-002 CONFIDENTIAL Page 42 of 92 EFTA_00068834 EFTA01247062 Larry Eugene Morrison - Volume I October 6, 2009 161 163 • 1 2 3 4 A. This is I don't remember. Some time within • maybe within the year. I don't know. I don't know. O So its your understanding then (Mt 2 3 4 O. And what else does he tell you? I mean, there are other changes other than. 'Hey, dating and he is dating 5 A. A couple of the - couple of long time 6 somebody named' • that It would also be a 6 P800 03 were laid off. 7 fair presumption that would be somewhere 7 O. nearby as well. a A. 9 MR. PIKE: Form. 9 O. 10 A. I mean, that's not necessarily so. I 10 A. 11 mean, in this day and age when you can get back and 11 12 forth to New York via airlines, or anywhere; I mean, 12 13 at times. yes, that would be a fair assumption, but 13 14 not continuously., 14 15 O. And what was the context in which the 15 And other changes 16 conversation came up where Larry Visoski says. 16 to the island. You know, I can't remember all the 17 • who you have very little knowledge. I mean, I 17 names. I believe Adam, who was the chef, at the 18 don't want to say 'very little knowledge" you obviously 18 island left. 19 have seen her several times -- 19 MR. PIKE: Hello? 20 A. Yes. 20 BY MR. EDWARDS: 21 21 O. Adam's the chef at the island? 22 22 A. Yes. 23 O. And why did he leave? 24 A. Right, right. 21 A. I don/ - 25 O. Othefwise, how would that come about? 25 O. Epstein's not around to cook for? 162 164 • 1 2 3 4 A. I don't remember how it came about. actually. I think I just - several months ago I asked what people were doing since, you know, there's been a lot of changes in staff since the boss was, 1 2 3 4 A. Yeah. It may have been a layoff kind of thing • and the economy too. I mean, everybody's affected. Q. Whirs your understanding abotl l 5 you know, detained. There's been a lot of layoffs EN? 6 and stuff. The conversation was he was updating me 6 A. Just that they were laid off. I don't 7 as to who's still around, who's been laid off, you 7 know the exact reasoning that they were laid off. 8 know. who's not with the company anymore. who's not a O. And before we go back to this: Have you ever 9 with, you know, at certain houses. 9 been to that Zono Ranch — xo Q. When you say 'the boss' has been 'detained.' to A. Yes. 11 the boss obviously Is Jeffrey Epstein? 11 O. in New Mexico? 12 A. Detect. Yes. 12 A. Yes. 13 O. And you're having a conversation then with 11 O. How many times? 14 Larry Visoski about the changes that necessarily are 14 A. Several. 15 made -- 15 O. Why? 16 A. Right. 16 A. Because when we take them out there it was 17 O. because the boss is — 17 too far to airline home. so we'd stay - stay at the 10 A. Well -- 33 ranch. 19 O. •• either incarcerated or under house arrest. 19 O. And what was he there to do? 20 or whatever. 20 A. I have no idea. 21 A. And the economy and everything, I mean. 21 O. Wee, you were al the ranch. right? 22 O. In the course of that he tells u something 22 A. Yeah, but ifs a big complex. There's 23 about. "Wel, is dating 23 The main house is literally probably 3 or 4 miles 24 A. Yeah, or - f think he said somelhin about 24 from where we eta 25 one of Jeffrey - 25 O. Was there also? Toll Free: • 0 Suite 1300 ESQ.vjem 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esguiresolutIons.com 3501.150-002 CONFIDENTIAL Page 43 of 92 EFTA_00068835 EFTA01247063 Larry Eugene Morrison - Volume I October 6, 2009 165 167 1 2 3 4 A. I'm sure at times, yes, yes. 0. Well. I mean. usually he goos with his A. The normal -- 0. -- his `his Ghistaine. 1 2 3 4 Mexico ranch? A. Oh, no. no. 0. You don't remember that? A. No. • 5 A. Yeah, his normal entourage. or whatever it 5 0. Could it have happened? 6 Is. 6 A. It could have. 7 0. And was somebody there to schedule his people 7 O. But you just don't remember seeing that. to come over and see him on a daily basis? 8 A. No, I don't ever remember seeing that. 9 A. I don't know. I don't know how that 9 0. Have you ever met Governor Bill Richardson? 10 worked. 10 A. I saw him. He was -- 11 0. He's - 11 0. How did you see him? 12 A. Like I say, he's up at the main house. 12 A. He was at Ranch Central. He had been 13 Once we were at the ranch there's really no contact. 13 invited for dinner, or something, at the main house 14 0. Yeah, but I'm familiar with where this ranch 14 and they were corning down to get him. 15 is. and it's kind of in the middle of nowhere, right? IS 0. He was invited to the Zono Ranch. I can it 16 A. Yeah. 16 that because that's apparently what Mr. Epstein's named 17 0. And, you know, so when people come to or from 17 a right? 18 the ranch. I mean. you can't help but almost be familiar 18 A. Yes. 19 that somebody's coming, right? 19 O. So Bill Richardson came to the Zone Ranch for 30 A. Well - 20 what? 21 MR. PIKE: Form. 21 A. I It was a dinner meeting or something, 22 A. •• I mean, you would see a car drive by or 22 don't know. 23 something or a truck. There's always a lot of 23 24 activity. constriction, and everything else going on. 24 A. I think Mr. Richardson used to own the 25 Where we stayed at Ranch Central, the 25 properly the ranch was built on. or something. I 166 168 1 2 3 4 small, little - basically like little hotel rooms where we stayed. you know, it was on a busy road because there was always like a lot of construction stuff arid the ranch hands and everything up and down. 1 2 3 4 don't know. 0. Did you stay for the dinner? A. Oh, no. no. I was down at Ranch Central and he was jusl there while they were going to escort • 5 0. Did you see girls going to visit him there? 5 him up to the main house. 6 A. Yes. 6 0. So Bill Richardson was where Epstein was where 7 0. How often would girls go to visit him there? 7 the dinner was. 8 A. I don't know. a A. Yes, yes. 9 0. Oid these 9 0. And you were not there. 10 A. Not that often. 10 A. Of course not. 11 0. Did these seem like girls local to Now Mexico 11 0. Who else besides Bill Richardson was there? 12 or had they just flown in on an airplane. landed a 12 A. I have no idea. 13 helicopter on the property? 13 0. Any knowledge of Bill Richardson being 14 A. Oh, I don't know. I never -- 14 involved with any of the gals that would have been 15 MR. PIKE: Form. 15 brought to the house? 16 A. I never saw them up close. I mean 16 A. Oh, no, no, not that I have. 17 O. Did they come in taxicabs? 17 0. Not that I know of. 18 MR. PIKE: Form. 18 A. Not that I know, no. 19 A. I can't remember that • don't think so. 19 0. Because you were in such a place that you 20 0. You don't ever think a girl came in a taxicab 20 never would have known anyway, right? 21 to the New Mexico ranch? 21 A. That's correct, yeah. 22 A. I don't ever remember seeing a taxicab on 22 0. What's your understanding as to Bill 23 the ranch. 23 Richardseres connection to Mr. Epstein? 24 0. Do you remember seeing girls two or three 24 A. I thought he was always just kind of 25 limes a day going to visit him while he was at the New 25 politics. I believe • I heard at one time. I don't Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 wvootesquIresolutions.coM 3501.150-002 CONFIDENTIAL Page 44 of 92 EFTA_00068836 EFTA01247064 Larry Eugene Morrison - Volume I October 6, 2009 169 171 • 1 2 3 4 know for a tact - I thought that part of the property the Zorro was built on was owned by Bill Richardson. He sold it to Jeffrey. O. Ever known Bill Richardson to be on Epstein's 1 2 3 4 O. You've never heard that? A. No. no. O. Have you ever boon privy to any conversations between Bill Richardson and Jeff Epstein? 5 airplane? 5 A. No. 6 A. No, not the Boeing. 6 O. So you don't know what they were really 7 O. Any plane. 7 talking about. 8 A. I don't know that. a A. No. No idea. 9 O. Was he ever on a plane that you were on? 9 O. At the time when Bill Richardson was running 10 A. No, not that I remember, not that I 10 for president is that around the time when you remember 11 remember. I remember -- I believe the only time I I him being at Zone Ranch? 12 met him was one time al Ranch Central. 12 A. Before. before. What year did he run for 13 O. Ever hear of a trust - Zorro Trust? 13 president? 14 A. No. 14 O. 2007. 15 O. Are you familiar with some of Epstein's 15 A. It had to have been well before because I 16 COrnpanies? 16 quit flying in February of '07. so. 17 MR. PIKE: Form. 17 O. Epstein ever tell you what his relationship is 18 A. No. I mean, other than JEGE and Hyperion 18 with Bill RIChar0SOn7 19 and Air Ghislaine. 19 A. No. 20 O. What's Air Ghislaine? 20 O. When you were at the ranch. did you over 21 A. That's the helicopters that's what 21 notice underage girls al the ranch? 22 they're under. 22 A. No. 23 O. He named it after Ghislaine Maxwell? 23 MR. PIKE: Form. 24 A. Apparently so. I would assume so. 24 BY MR. EDWARDS: 25 O. Well. I mean, I'm not trying to be difficult 25 O. Anybody ever told you that that ranch is used 170 172 • 1 2 3 4 with you. A. No, I wouldn't -- O. I'm assuming you're not trying with me either. A. No. I would assume so. I mean, that's an 2 1 4 to transport girls through Mexico to the ranch? A. No. MR. PIKE: Form. BY MR. EDWARDS: 5 unusual name. O. The next exhibit that I'm going to show you - 6 O. Do you know Prince Andrew to be friends with 6 which is all part of Composite Exhibit 1 - is a fight 7 Jeffrey Epstein? is that right? 8 MR. PIKE: Form. 8 A. Yes. 9 A. No, I don't know that — I don't know what 9 O. Who's on that? Nobody. That's a test flight? 10 the tie Is. Like I say, I didn't know even know who 10 A. That's a test flight round robin. k's 11 Prince Andrew is when I first heard of it. I would 11 Only 17 minute. 12 have thought it would have been more of a tie with 12 O 13 Ms. Maxwell. 13 A. PBI to Kennedy with Jeffrey, 14 O. Right. Do you know of Ms. Maxwell bringing 14 15 the two. that being Prince Andrew, together with Mr. IS O. Do you know what his relationship is with 16 Epstein? 16 /NS? 17 MR. PIKE: Form. 17 A. No. 18 A. That Oeuld be. yes. yep. 18 O. Do you know what she does for him? 19 O. And at the time when Bill Richardson had this 19 A. No. only Isn't that the one that you 20 meeting at Epstein's house. do you remember Glistaine 20 told me you just mentioned earlier? I have no idea 21 Maxwell also being there? 21 what her relationshp 22 A. Can't say for sure. Can't say for sure. 22 O. Has he ever told you what any of his employees 23 O. Have you heard of Jeffrey Epstein winning the 23 actually do for him • why ho employs so many people to do 24 lottery in New Mexico? 24 so many different things - has he told you that? 25 A. No. 25 MR. PIKE: Form. • 0 Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 WWW.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 45 of 92 EFTA_00068837 EFTA01247065 Larry Eugene Morrison - Volume I October 6, 2009 173 17$ 1 2 3 4 A. No, no. I mean, you know, who runs each house and who the driver is. stuff like that. No. he would never mention that. 0. Has he ever told you what running a house 1 2 3 4 0. And despite pleading guilty to procuring underage girls for the purposes of sex, you still feel comfortable leaving a 13. 14, 151rear-old girl around him? • 5 entails? 5 MR. PIKE: Form. Move to stoke. 6 A. No, no. 6 A. Yes. I meanlares. I 7 0. Has he ever told you that there's an extra 7 don't know how he behaves around anybody else. I pan of running the house that ensures that underage 8 just know that the reseed that he showed me, I feel 9 girls are going to be there for him every day? 9 safe with my daughter. 10 A. No. 10 0. And have you read in detail the reports as to 11 MR. PIKE: Form. 11 what happened at his house with the girls? 12 BY MR. EDWARDS: 12 A. Only — 13 O. That's not something you ever heard. 13 MR. PIKE: Form. 14 A. No. 14 A. -- what's been in the newspapers and 15 0. Ilight log who's on it? 15 published. 16 A. Jeffrey, Ghislaine Maxwell. David Mullen. 16 0. If you read and hear testimony given • well, I 17 17 can tell you now - testimony has been oven in ths case 18 0. David Mullen - once again, we don't know who 18 that what happens is: A 13 or 14 year old is led 19 this guy is, do you? 19 upstairs by herself, told to get naked, he lays down on 20 A. And I don't know. Honestly, I can't -- 20 his back, there is a oriel massage before he turns over. 21 0. Do you know where he lives? 21 exposes himself erect. masturbates while he tells this 13 22 A. No. 22 or 14 year old to pinch his nipples as hard as she can 23 0. Did you ever go visit Jeffrey Epstein while he 23 while he inserts his fingers into their vagina and 24 was in jail? 24 ejaculates all over them before saying, *Take your money 25 A. No. 25 and leave.' 174 176 1 2 3 4 0. Why not? A. There was no purpose to it. There was no need to. 1 2 3 4 MR. PIKE: Form. Move to strike. 8Y MR. EDWARDS: 0. Okay? Then, 'You can continue to come back for $200 every time or every girl you bring me within • 0. He's your boss for a long time, right? 5 A. Yeah. 5 your age group and I get to do this again. I pay you 5200 6 O. Was he good to you? 6 per person.' If that is the testimony -- A. Yes. 7 MR. PIKE: Form. a O. Did you support him? 0. — that what happens behind closed doors with 9 A. Yes. 9 him, do you still feel comfortable leaving a 13 or 14 10 O. You supported him while he was in jail? 10 year old in a room with Jeffrey Epstein? 11 A. I was -- Yes. I mean. 11 MR. PIKE: Form. 12 0. Did the allegations bother you? 12 A. If that, in fact, is what actually 13 A. Yes. 13 happened. no. 14 MR. PIKE: Form. 14 0. I'll show you the next flight I is 15 BY MR. EDWARDS: 15 Here. just so these are In order, I'll - 16 0. Somebody that you still support despite the 16 A. Okay. 17 allegations? 17 0. Who's on that airplane? 18 MR. PIKE: Form. 18 A. Jeffrey, and 19 A. Yes, yes. 19 0. Seem to be people that he travels with 20 0. You realize that he did plead guilty to the 20 frequently. 21 Offenses as well, right? 21 A. Yes, normal - his normal entourage. 22 A. That's what I read. 22 0. Have you read recently the agreement that was 23 MR. PIKE: Form. Move to strike. That's 23 entitled the 'Non-Prosecution Agreement'? 24 not the fads. 24 A. No. All I read was what was in the paper. 25 BY MR. EDWARDS: 25 0. The 'Non-Prosecution Agreement' was an O Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, Fl 33301 www.esquiresolutIons.corn • 3501.150-002 CONFIDENTIAL Page 46 of 92 EFTA_00068838 EFTA01247066 Larry Eugene Morrison - Volume I October 6, 2009 177 179 • 1 2 3 4 agreement between Epstein and the government where the government agreed. 'We're not going to prosecute you for only the sex crimes we know about: and in that they also agree not to prosecute Jeffrey Epstein. IM= 1 2 3 4 0. This is the first time we've seen mentioned on any flight logs. right? A. Right. Q. Do you find it at all peculiar that 5 In of IM 5 is listed but certain other people who may or may not be 6 A. Okay. 6 of age are listed generically - one female. Why would 7 0. as his co-conspirators. 7 they go out of their way to list Do you know any of the acts that M, MR. PIKE: Form. 9 or have done in an attempt to get Jeffrey Easton 9 A. I don't know. Maybe she was already an 10 young girls to molest? 10 employee or something. I don't know. 11 A. Only what I've read in the paper. 11 Q. If she's an employee at the time, then that 12 MR. PIKE: Move to strike. 12 would be a good explanation, right? 13 BY MR. EDWARDS: 13 A. Right. I don't know. 14 0. Again, Jeffrey Epstein, Ghislaine Maxwell. and 14 0. If she's not an employee, then is there any 15 who's that? 15 explanation? 16 MR. REINHART: Can we get a date, please? 16 MR. PIKE: Form. 17 BY MR. EDWARDS: 17 A. Unless No. I don't know. I don't 15 0. Sony, the date is_. On this night le know. Maybe &9 asked her. That looks like Bel's 19 log, who are the names? 19 writing there when he was captain. 20 A. Ohislaine -Jeffrey. Ghislaine Maxwell 20 0. We'll move to 21 andMM. 21 A. Okay. 22 0. Do you know Ghislaine Maxwell on a social 22 0. Who's listed? 23 level or only from hem? 23 A. Actually. this wasn't even my flight. 24 A. No. just professional. 24 This is: Jeffrey. female, female 25 0. Do you know whether she is straight or 25 • PEN to Kennedy. 178 180 • 1 2 3 4 bisexual? Do you know of any of hot girlfriends? A. 'do not know that 0. Are you aware that Ghislaine Maxwell, in sworn testimony and in complaints. has been alleged to have 1 2 3 4 0. Mars not your flight? A. No. George Diaz is one of the few engineers I used as a relief. See his name wntlon in up there? used vibrators. dildos. and have sex with these underage 5 0. Yes, but it has your name written under it 6 girls as well? 6 right? 7 A. I dont -- 7 A. Well. yeah, because these are preprinted a MR. PIKE: Form. a forms. They neglected to scratch my name out. A. I was not aware of that. 9 0. Any idea why now they're going to list 'one to 0. Do you know who s? 10 female, one female'? That doesn't seem to be protocol 11 A. I think IM used to be her 11 hero. does it? • VIII 12 A. I don't -- Yeah. I have no idea. I don't 13 0. Used to be Ghislaine Maxwell' 13 have an answer for that, I really don't. 14 A. I batiste so, yeah, because 14 0. Certanly, if you're able to get Ss to • 15 tee you her name. it doesn't take much effort to get two 16 0. Do you know if is underage or if she is 16 other people to tell you their name. right? 17 of age at the time that this happened - at the time they 17 A. Like I say, the only thing I can thnk ol le list her name? le VIII■an employee by twat time, that they knew 39 A. Ofi, I dont know for sure. but. I mean. 19 her. I don't know. 10 she when I ff it is the I remember. 20 0. Did it ever at any point in time cross your 21 she was older. I mean, I cant even guess her age, 21 mind that there may be something illegal going on here - 22 mid-twenbes. tate twenties. I mean. 22 ever? 23 0. Okay. Do you -- 23 MS. EZELL: Form. 24 A II it's the I remember. 24 MR. PIKE: Form. 25 A. Define Mere.' Toll Free: • Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com 3501.150-002 CONFIDENTIAL Page 47 of 92 EFTA_00068839 EFTA01247067 Larry Eugene Morrison - Volume I October 6, 2009 181 183 1 2 4 D. Here when you're traveling on the airplane with these various girls and they're listed as 'one female' - generically listed - anything ever cross your mind, 'maybe something's not exactly kosher? 1 2 3 4 A. I can't -- I can't say for sure. I mean, we used to carry a massage table on the airplane. I never saw one used. I don1 know for sure. O. Are you being paid to be here today? • 5 A. No. 5 A. No, no. I mean, I'm on salary. I mean -- 6 MR. PIKE: Form, asked and answered 6 O. Right. 7 several times. 7 A. -- because of • for the maintenance. but. BY MR. EDWARDS: 8 no. 9 O. Who's that? The date is 9 O. Are you going to ask Jeffrey Epstein at some 10 A. Jeffrey, Ghislaine, and 10 point in time, 'Why you hired an attorney to sit hero 11 O. Let's see,MI and `both look like 11 with me?' 12 nobody's on thorn, so show them to you together. 12 A. No. 13 A. There might be remarks here: 'Maintenance 13 MR. PIKE: Form. 14 test flight' out of Lake City. Florida. 14 A. I would never — I would not approach 15 We were coming out of maintenance: 'No 15 Jeffrey for that. 16 passengers, maintenance, relocation for the engineer 16 O. Do you have any idea why Jeffrey Epstein might 17 repair.' 17 want an attorney to sit here for you? 18 O. Okay. who's on it? la MR. PIKE: Form. 19 A. Jeffrey, , David Mullen. 19 A. No. I mean, maybe -- I dont know. 20 Min 20 O. Do you think that the attorney silting here is 21 0. Last one. 21 for the purpose so that you don't say anything to 22 A. a8/8Mr David 22 incriminate Jeffrey Epstein? 23 Mullen. Mark Zeff -- 23 A. No, no. I was told strictly that he was 24 O. Do you know who Mark Zeff Is? 24 here upon my behalf. 25 A. No - Daniell, Doug Shuttle, 25 O. Do you know of any crimes, personally, that 1.82 184 1 2 3 4 O. Do you know who Daniell and aro? A. I think. I remember • sounds familiar. O. How did she look? A. I cant remember. I just -- 1 4 2 3 you witnessed Jeffrey Epstein committing? A. No. O. Would you -- A. No. • O. Overage, underage? 5 O. -- go back - considering what you've read and 6 MR. PIKE: Form. 6 what you may or may not believe - would you go back to 7 A. I never saw any that I saw that looked to 7 working for Jeffrey Epstein? 8 me underage. 8 MR. PIKE: Form. O. Have you ever been to Jeffrey Epstein's house 9 A I can't say. I still work for him on a 10 - his Palm Beach house? 10 maintenance - to maintain the airplanes and stuff 11 A. Yes. 11 like that. so. 12 G. You stayed for an emirs day? 12 O. You're on his payroll? 13 A. No, no. 13 A. Salaried, yes. 14 0. No? 14 O. Do you know who else is on his payroll? 15 A. It would be like an hour at the most 15 A. Well, Dave and Larry. 16 waiting to talk to him for a minute. No. 16 O. Certainly. if I want to know more about his 17 O. Let me ask it this way: Has he ever told you 17 private life - do you know who's at his house? 18 that he's infatuated with massages? la A. No. 19 A. No, he's never told me that. 19 O. Do you know who his housekeeper is? 20 MR. PIKE: Form. 20 A. No. 21 BY MR. EDWARDS: 21 O. Do you know who his architect is? 22 O. Have you ever known him to get a professional 22 A. No. no. 23 massage anywhere you go? 23 O. Does Larry visit him at his house? 24 A. Yea I believe so. 24 A. I would assure so. 25 O. Where? 25 O. Why do you say you would assume so? That 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esguiresolutions.com 3501.150-002 CONFIDENTIAL Page 48 of 92 EFFA_00068840 EFTA01247068 Larry Eugene Morrison - Volume I October 6, 2009 185 187 • 1 2 3 4 means he told you something, right? A. Well, he handles Jeffrey does a lot of • he likes high-end stereo equipment and video equipment, and Larry is an expert at audio and video 2 3 4 A. Yes, I guess. Yeah. I don't know exactly. 0. Have you ever heard of A. sounds familiar, but I don't 5 installations and stuff. 5 know -- 6 0. How about David Rodgers - ever at his house? 6 0. Model? New York? 7 A. Probably, but more like on the grounds of 7 A. No, I can't say that I have. 8 me, you know. 8 0. 9 0. My other famous people that you met through 9 A. Can't say that I have. 10 Jeff Epstein? 10 0. Glenn Dubin? 11 A. On the airplane? 11 A. Glenn Dubin, yes. 12 O. Yes. 12 0. How do you know him? 13 A. Walter Cronkite. 13 A. I think he's a money or finance manager of 14 0. Oh, yeah? 14 some form - associate of Jeffrey or Ghislaine's or 15 A. He was very nice. Yeah. He was very 15 both. 16 feeble, but he was very nice. We had to carry him 16 0. And where does he live? 17 down the steps. 17 A. I think he lives in California, I believe. 18 0. Where did that flight go to? 18 0. What do you know about him? 19 A. New York to St. Thomas. He's an avid 19 A. Well, he's • just all I just told you. I 20 sailor. He loves to sail or loved to sail. 20 think he's - he's an options writer or something like 21 0. what's the magician's name - David 21 - not an options writer, hedge funds or something 22 Copperfield? 22 like that. He's in money. Its -- He's got an 23 A. No, I don't think I was on that. I don't 23 airplane. I think he's got a quarter share or part 24 think I flew that. I heard that we had flown him. I 24 of an airplane. 25 can't say for sure. I would remember that. I would 25 0. DO you know anybody that owns any property 186 188 • 1 2 3 4 remember B. I have never met David Copperfield, but I heard that we had. Naomi Campbell - flew her a couple tines. 0. What do you understand Naomi Campbell and 1 2 3 4 with Epstein? A No. 0. What other properties does Jeffrey Epstein own? I know we talked about the Zero Ranch. the place 5 Jeffrey Epstein's relationship to be? 5 in New York, you talked about an island, West Palm Beach. 6 A. I don't. I assume it was modeling. I 6 A. That's all that I'm aware ol. 7 don't know. It was like two trips. 7 0. How about Paris? 8 0. Jeffrey Epstein ever tea you how long he was A. I don't know that he owns them. That's 9 in the modeling industry? 9 whore he goes for homes. 10 A. Never discussed it. 10 0. Ever go to Pahs with him? 11 0. So the first you know of is whatever 11 A. He does have an apartment in Para. I 12 involvement he's in with Jean Luc Brunel. 12 don't know • however that works out it irs a lease 13 A. Right. 13 or own or what. 14 0. That's the first time -- 14 0. Who are the house managers of the various 15 A. Yes. 15 places that he owns? 16 0. -- you've never known him lo be in modeling. 16 MR. PIKE: Form. 17 A. Correct, that I was awaro of. And, 17 A. I don't know anymore. There has been so 18 actually, nobody ever told me that but picking up 18 much shake up. you know. 19 bits of conversation like such as the one about the 19 0. Well. who were they? Do you know the 20 motor home door. 20 Freidman out in California? Do you know Eve am 21 0. What exactly did he say about the motor home 21 Patrick? 22 door that led you to know that Epstein and modeling is -- 22 A. No. 23 A. They were al - on location for a modeling 23 0. Alfredo Rodrigue?? 24 shoot and they had a motor home. 24 A. No. 25 0. They meaning Jeffrey Epstein and somebody. 25 0. Alright • 0 Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esqulresolutlons.com 3501.150-002 CONFIDENTIAL Page 49 of 92 EFTA 00068841 EFTA01247069 Larry Eugene Morrison - Volume I October 6, 2009 189 191 • 1 A. No, those are all I know. 1 0. Do you remember a young woman name. who 2 0. You tell me. Who do you know? 2 flew frequently with Jeffrey Epstein? 3 A. God. I can't think. It's been so long 3 A. No, I don't recall 4 ago. 4 0. You mentioned a 5 O. Other than Joe-Joe. A. A` yes. I remember the name-. 6 A. Well, Joe•Joe doesn't • he's just a driver 6 0. Can you describe-'? 7 for New York - he and his wife. I could remember 7 A. No, I'm sorry. I cant. I just recognize 8 them it I saw their names. I would know which house a the name - or the sound of the name. 9 they were associated with. I'm terrible with names 9 0. Do you have any recollection as to what period 10 anymore, unfortunately. The couple that's now at the 10 of time -flew with Mr. Epstein? 11 ranch or was at the ranch is at the island helping 11. A. It was on one of those Passenger 12 manage as an intern. 12 Manifests. I thought I only saw it one time. 13 O. Who's that? 13 MR. REINHART: Kathy - this is Bruce • the 14 A. Honestly, I can't remember their names. 14 passenger manifest that had that name on it was 15 It you were to give me a name, I could attach it to 15 dated 16 each house. 16 MS. EZELL: So al of those that Brad went 17 0. I wish I could. 17 over were '04 and '06. I believe. 18 A. Yeah, tm son , I can't. It's 18 MR. REINHART: Correct, 19 O. Do you know 19 BY MS. EZELL: 20 A. No. sounds familiar. I don't 20 0. Let's see, did you ever fly Mr. Epstein to St. 21 know. 21 Louis? 22 O. Something to do with the modeling agency? 22 A. No. 23 A. Can't say for sure - can't say. 23 0. Did you ever fly him to San Francisco? 24 O. How about Kalib Shalom? 24 A. No. 25 A. No, never heard of that one. 25 0. What about France? 190 192 1 2 4 3 MR. EDWARDS: Let me look over my notes real fast. Anybody else going to have some questions so I can look over my notes and maybe ask a ample more? 1 2 4 A. 0. A. la Yes. Paris. And Spain? No, nope. Carmel? • 5 MR. PIKE: Brad, when I get a chance to 5 A. Cannel? 6 cross, I definitely will have some questions for 6 MR. REINHART: California, Kathy? 7 the witness. 7 MS. EZELL Yes a MR. EDWARDS: Okay. Any other plaintiff a A. No, we wouldn't have Was that Monterey 9 attorneys? Kathy? I think Kathy quit on us - 9 area? 1co must have been loo boring. Anybody else? 10 MR. REINHART: Yes. 11 Hold on Miko. Give me one minute and then 11 A. Yes. 12 I think you can shoot. 12 0. Monterey you did. Okay. 13 MS. EZELL: Brad? 13 Do you remember a woman named= who would 14 MR. EDWARDS: Yes? 14 accompany Bair* (sic) Maxwell? 15 MS. EZELL: I'm sorry, its Kathy. I 15 A. Yes. I remember = I believe srie was 16 dolt realize my mute was on. I do have a few 16 -or— 17 questions. 17 0. And what was her function? 18 MR. EDWARDS: Okay. Go ahead. 18 A. To the best of My knowledge, 19 CROSS-EXAMINATION 20 BY MS. EZELL: 20 0. Did there came a point in time where Ms. 21 0. Mr. Morrison • forgive me, I didn't write it 21 Maxwell flaw her Own plane? 22 down - when did you begin working for Mr. Epstein? 22 A. No. 23 A. January 2001. 23 0. Did there come a lime that you became aware 24 0. Do you remember a young woman named .? 24 that she and Jeffrey Epstein were flying asParaiohl 25 A. No, I'm sorry, I can't - I don't. 25 A. Yes. Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com 3501.150-002 CONFIDENTIAL Page 50 of 92 EFTA_00068842 EFTA01247070 Larry Eugene Morrison - Volume I October 6, 2009 193 195 • 1 2 3 4 0. And whose plane would she fly on on those occasions? A. I don't know. There was -- She had a fractional - of a flight options. She had some 1 2 3 4 A. I can't say that I have, no. I can't say that I did. 0. Do you remember flying three young girls back to France after Mr. Epstein's birthday party? 5 flight options. When you said Can I ask — A. No, no, I can't say that I do. and I 6 0. Yes. 6 didn't remember what birthday - that there was a big 7 A. when you stated. 'Did she fly her own 7 birthday party. 8 planer, did you mean as a pilot? 0. Okay. Well, forget the party part. 9 O. Yes. yes. 9 A. Okay. 10 A. No, no. I stand with, no. 10 0. Were you aware that Mr. Brunel flew in three 11 0. Did you ever know her to fly a helicopter? 11 12-year-old girls for Mr. Epstein's pleasure on his 12 A. Yes. 12 birthday? 13 0. And when was that? 13 A. No. I was not aware of that, no. 14 A. Several times. I don't remember exactly 14 0. And you have no recollection of having young 15 when she got her initial rating. Can't remember 15 women that young on flights that you were flying on? 16 exactly when she got her initial rating. It was 16 A. That's correct. 17 before - I think before - maybe around 2000, 2001. I 17 MR. PIKE: Form. 18 don't know that for a fact. te BY MS. EZELL: 19 O. Among the various pilots that you have worked 19 0. I don't have any other questions. Thank you. 20 with for Jeffrey Epstein, do you know of any who has a 20 A. Thank you. 21 house on the Zorro Ranch property? 21 MR. EDWARDS: Mice. I don't really think 22 A. Yes. 22 anybody— I'm Sony. 23 0. And who IS that? 23 CROSS-EXAMINATION 24 A. LanyVisoski. 24 BY MR. WILLITS: 25 0. And do you know if he was given that house by 25 0. Richard Willits here. I just have one 194 196 • 1 2 3 4 Jeffrey Epstein? A. I do not know. 0. Were you ever given any properties by Mr. Epstein? 1 2 3 4 question. sir. I didn't catch the complete and full spading of your name. A. My name? 0. Yes. sir . the witness? 5 A. No. 5 A. Its Larry - Lana. Aktia. Romeo. Romeo. 6 0. You said that you did know Mr. Jean Luc 6 Yankee and last name is Morrison - Mike, Oscar, 7 Brunel? 7 Romeo. Romeo. India. Sierra. Oscar Nowomber. 8 A. Yes. I knew of him - and it was as an MR. WILUTS: Thank you, at. 9 acquaintance • as a passenger. 9 MR. EDWARDS: Mike, shoot. 10 O. Did you fly him to and from Paris? to MR. PIKE: Thank you. Thank you. 11 A. Yes. 11 CROSS-EXAMINATION 12 0. Do you ever remember flying three girls from 12 BY MR. PIKE: 13 Paris for Mr. Brunel -- 13 0. Mr. Morrison. my name is Michael Piko. I 14 MR. PIKE: Form. 14 represent Jeffrey Epstein. 15 O. -- to be guests of Mr. Epstein? I5 A. It 16 MR. PIKE: Form. 16 0. I'm going to ask you a couple of questions. 17 A. I can't say that I remember that exactly, 17 If you do not hear me, please ask me to repeat the 18 no, and I didn't know who • whose guests they were 18 question - as In on a telephone and by virtue of be,ng 19 for who. 19 on the telephone. I've noticed that there's some lag time 20 O. Do you remember flying three young girls to 20 between some answers and responses. 21 Mr. Epstein's birthday party? 21 MR. PIKE: So, l3rad, Interrupt me, if I'm 22 MR. PIKE: Form. 22 talking over the witness as well. 23 A. I don't -- 23 BY MR. PIKE: 24 O. I'm Sorry, I meant from France. 24 a Mr. Morrison. Mr. Edwards was talking to you 25 MR. PIKE: Form. 25 about your knowledge and information regarding passengers • 0 Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutlons.com 3501.150-002 CONFIDENTIAL Page 51 of 92 EFTA_00068843 EFTA01247071 Larry Eugene Morrison - Volume I October 6, 2009 197 199 1 2 3 4 on Mr. Epstein's plane from January 1, 2001, up until the time you stopped flying. Do you recall some of those questions? A. Yes. 2 3 4 1 first. MR. PIKE: I have no further questions. MR. EDWARDS: I have a couple more • just follow-up • from what Kathy asked. • 5 0. With regard to the female passengers that Mr. 5 REDIRECT EXAMINATION 6 Edwards discussed with you. do you recall n any of them 6 BY MR. EDWARDS: 7 ever left the plane in a scared manner? 7 0. Did any of the people • along Mike Pike's A. No. no. e lines - did any of the girls on the airplane tell you 9 O. Did any of those girls over appear to be 9 that he pled guilty to two felonies in court? 10 disheveled to you in any way? 10 MR. PIKE: Form. 11 A. No. 11 A. No, I haven't • I have not spoken to Mr. 12 0. Did any of these girls that were on the plane 12 Epstein. I don't believe -- 13 ever claim to be battered or sexually assaulted? 13 0. No. no. I think the question was: Did any of 14 A. Not to me, no. 14 the girls tell you that Mr. Epstein pled guilty in court? 15 0. Did any of these women appear to be in shock 15 A. Which girls? 16 to you? 16 0. Any of the girls on the airplane that we're 17 A. No. 17 talking about. 18 MR. EDWARDS: Object to the form. 18 A. No. I don't think -- Actually. I don't 19 BY MR. PIKE: 19 know when he pied because I think I was - stopped 20 O. Were any OI these women ever crying as they 20 flying by then. 21 exiled the plane when you were the plot? 21 0. So there were a lot of things that happened on 22 A. No, not that I saw. 22 the airplane that the girls didn't necessarily tell you 23 0. Did any of these women appear to be injured as 23 about. right? 24 they exited the plane when you were a pilot? 24 MR. PIKE: Form. 25 A. No, net that I saw. 25 A. That I wasn't — Like I say, going back to 198 200 1 2 4 0. Did any of these women ever tell you, as the captain of the plane, that they were forced to do something against their will white a passenger on the plane? 1 2 3 4 • there was not even an opportunity or window for that question. because I believe it was after February of '07. 0. That's true. • MR. EDWARDS: Object to the form. Did any of the girls on the airplane tell you 6 A. I was Actually. to correct the 6 about things that happened on the airplane that he later question. I guess I was not captain - I was flight 7 pled guilty to? 8 engineer but, no. e MR. PIKE: Form. 0. Did they ever tell you that they had been A. No. 10 forced to do anything inappropriate? 10 0. Did any of the girls on the airplane really 11 A. No. 11 talk to you? 12 O. Did they ever tell you that they had been 12 A. No. 13 assaulted in any way? 13 0. Okay. so all of this is kind of say. 14 A. No. 14 Akight. Got it. 15 O. Did they ever tell you that they had been 15 would accompany Ms. Maxwell. When you 16 kieppropriately touched in any way? 16 say •would n her; what did you mean about that? 17 A. No. 17 A. . Actually. I 18 MR. EDWARDS: Form. 18 don't -- I didn't see very many times. I don't 19 BY MR. PIKE: 19 know when she stopped wonting there, but she would 20 0. Did they ever tell you or did you ever hear of 20 Yeah, I just She would be on trips with her -- 21 anyone Claiming that they had been sexually assaulted. 21 0. And did you — 22 battered, or raped while on the plane? 22 A. 23 MR. EDWARDS: Form. 24 A. No. 24 (Please continue to Volume II.) 25 MR. REINHART: Give him a chance to object 25 Toll Free: Facsimile: Suite 1300 • ESQUIRE asalemderCla•Cespeay 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 52 of 92 EFTA_00068844 EFTA01247072 • • j 3501.150-002 CONFIDENTIAL Page 53 of 92 EFTA_00068845 EFTA01247073 • • 3501.150-002 CONFIDENTIAL Page 54 of 92 EFTA 00068846 EFTA01247074 Larry Eugene Morrison - Volume I October 6, 2009 • • • 0 Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 55 of 92 EFTA_00068847 EFTA01247075 Larry Eugene Morrison - Volume I October 6, 2009 S Toll Free Facsimile Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esdulresolutions.com 3501.150-002 CONFIDENTIAL Page 56 of 92 EFTA_00068848 EFTA01247076 Larry Eugene Morrison - Volume I October 6, 2009 • • • Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 57 of 92 EFTA_00068849 EFTA01247077 Larry Eugene Morrison - Volume I October 6, 2009 Toll Free: Facsimile: Suite 1300 • ESQUIRE Oalloteepaa, 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresoiutions.corn 3501.150-002 CONFIDENTIAL Page 58 of 92 EFTA_00068850 EFTA01247078 Larry Eugene Morrison - Volume I October 6, 2009 • • • Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutIons.com 3501.150-002 CONFIDENTIAL Page 59 of 92 EFTA 00068851 EFTA01247079 Larry Eugene Morrison - Volume I October 6, 2009 0 ESQUIRE Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 • a Myatt Calle Conga, wwwiesquIresolutions.com 3501.150-002 CONFIDENTIAL Page 60 of 92 EFTA 00068852 EFTA01247080 • Larry Eugene Morrison - Volume I October 6, 2009 • • • 0 Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 61 of 92 EFTA_00068853 EFTA01247081 Larry Eugene Morrison - Volume I October 6, 2009 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutions.com 3501.150-002 CONFIDENTIAL Page 62 of 92 EFTA_00068854 EFTA01247082 Larry Eugene Morrison - Volume October 6, 2009 n Cs • • Toll Free: • 0 Facsimile: Suite 1300 ESQtiIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 vormesouiresolutions.com 3501.150-002 CONFIDENTIAL Page 63 of 92 EFTA_00068855 EFTA01247083 Larry Eugene Morrison - Volume I October 6, 2009 • Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 64 of 92 EFTA_00068856 EFTA01247084 Larry Eugene Morrison - Volume I October 6, 2009 • • • Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 65 of 92 EFTA_00068857 EFTA01247085 Larry Eugene Morrison - Volume I October 6, 2009 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutIons.com 3501.150-002 CONFIDENTIAL Page 66 of 92 EFTA_00068858 EFTA01247086 Larry Eugene Morrison - Volume I October 6, 2009 • • • 0 Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutlonS.com 3501.150-002 CONFIDENTIAL Page 67 of 92 EFTA_00068859 EFTA01247087 Larry Eugene Morrison - Volume I October 6, 2009 ' Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.corn 3501.150-002 CONFIDENTIAL Page 68 of 92 EFTA 00068860 EFTA01247088 Larry Eugene Morrison - Volume I October 6, 2009 • • Toll Free: • CIO Facsimile: Suite 1300 ESQUIRE es Aleaasee arey 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www,esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 69 of 92 EFTA 00068861 EFTA01247089 Larry Eugene Morrison - Volume I October 6, 2009 ' ' I • Toll Free Facsimile Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esoulresolutions.com 3501.150-002 CONFIDENTIAL Page 70 of 92 EFTA_00068862 EFTA01247090 Larry Eugene Morrison - Volume I October 6, 2009 • • Toll Free: • Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.corn 3501.150-002 CONFIDENTIAL Page 71 of 92 EFTA_00068863 EFTA01247091 Larry Eugene Morrison - Volume I October 6, 2009 " 218 S Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 72 of 92 EFTA_00068864 EFTA01247092 Larry Eugene Morrison - Volume I October 6, 2009 219 • • Toll Free: Facsimile: Suite 1300 ESQUIRE se AtetatinGslACempsay 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 73 of 92 EFTA_00068865 EFTA01247093 Larry Eugene Morrison - Volume I October 6, 2009 ' ' 220 0 Ton Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.corn 3501.150-002 CONFIDENTIAL Page 74 of 92 EFTA_00068866 EFTA01247094 Larry Eugene Morrison - Volume I October 6, 2009 221 • • • Toll Free: Facsimile: ESQUIRE Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com CONFIDENTIAL 3501.150-002 Page 75 of 92 EFTA_00068867 EFTA01247095 Larry Eugene Morrison - Volume I October 6, 2009 *. S Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, Fl 33301 www.esquiresolutIons.com 3501.150-002 CONFIDENTIAL Page 76 of 92 EFTA 00068868 EFTA01247096 Larry Eugene Morrison - Volume i October 6, 2009 • • • Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 77 of 92 EFTA_00068869 EFTA01247097 Larry Eugene Morrison - Volume I October 6, 20a9 • 224 O Toll Free: Facsimile: Suite 1300 • ESQUIRE .WIeCwMY 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esouiresolutIons.com 3501.150-002 CONFIDENTIAL Page 78 of 92 EFTA_00068870 EFTA01247098 Larry Eugene Morrison - Volume I October 6, 2009 225 • • Toll Free: • Facsimile: Suite 1300 ESQUIRE 515 East Las Ofas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.corn 3501.150-002 CONFIDENTIAL Page 79 of 92 EFTA 00068871 EFTA01247099 Larry Eugene Morrison - Volume I October 6, 20a9 " • 226 0 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 80 of 92 EFTA_00068872 EFTA01247100 Larry Eugene Morrison - Volume I October 6, 2009 227 • • • Toll Free: Facsimile: ESQUIRE Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com CONFIDENTIAL 3501.150-002 Page 81 of 92 EFTA_00068873 EFTA01247101 Larry Eugene Morrison - Volume I October 6, 2009 " • 228 Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 82 of 92 EFTA_00068874 EFTA01247102 Larry Eugene Morrison - Volume I October 6, 2009 • • • Toll Free; Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 83 of 92 EFTA_00O68875 EFTA01247103 Larry Eugene Morrison - Volume I October 6, 2009" ' Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 84 of 92 EFTA_00068876 EFTA01247104 • • . Larry Eugene Morrison - Volume I October 6, 2009 • • • Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 85 of 92 EFTA_00068877 EFTA01247105 Larry Eugene Morrison - Volume I October 6, 2009" ' S Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutions.com 3501.150-002 CONFIDENTIAL Page 86 of 92 EFTA_00068878 EFTA01247106 • • I Larry Eugene Morrison - Volume I October 6, 2009 • • • Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 vnvw.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 87 of 92 EFTA_00068879 EFTA01247107 Larry Eugene Morrison - Volume I October 6, 2009" ' Toll Free: Facsimile: Suite 1300 • ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 88 of 92 EFTA_00068880 EFTA01247108 Larry Eugene Morrison - Volume I October 6, 2009 • • • Toll Free: Facsimile: Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 89 of 92 EFTA 00068881 EFTA01247109 Larry Eugene Morrison - Volume I October 6, 2009" ' Toll Free: Facsimile: 0 Suite 1300 ESQUIRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 90 of 92 EFTA_00068882 EFTA01247110 • 4 , Larry Eugene Morrison - Volume I October 6, 2009 • • Toll Free: • Facsimile: Suite 1300 ESQUIRE as Almada O•11•Crapasy 515 East Las Olas Boulevard FOR Lauderdale, FL 33301 www.esquIresolutIons.com 3501.150-002 CONFIDENTIAL Page 91 of 92 EFTA_00068883 EFTA01247111 Larry Eugene Morrison - Volume I October 6, 2009'.' * Co Toll Free Facsimile • ESQUIRE Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 CONFIDENTIAL Page 92 of 92 EFTA_00068884 EFTA01247112