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title: "DOJ Epstein Files, Data Set 9 (EFTA00159483)"
source: "DOJ Epstein Files, Data Set 9"
sourceUrl: "https://huggingface.co/datasets/ishumilin/epstein-files-ocr-complete"
date: "2026-01-01"
category: "DOJ Data Set"
eftaNumber: "EFTA00159483"
ocrPages: 0
ocrChars: 227829
ocrElapsed: 0.0
parseTier: "external"
engine: "ishumilin OCR pipeline (engine undisclosed; CC0 mirror)"
externalSource: "ishumilin-ocr-complete"
externalLicense: "CC0-1.0"
externalCredit: "ishumilin/epstein-files-ocr-complete (Hugging Face)"
externalUrl: "https://huggingface.co/datasets/ishumilin/epstein-files-ocr-complete"
---
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 502008CA028051XXXXMB AD
Plaintiff,
-vs-
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF LARRY VISOSKI
Thursday, October 15, 2009
10:18 - 3:37 p.m.
515 N. Flagler Drive
Suite P200
West Palm Beach, Florida 33401
Reported By:
Wendy Beath Anderson, RPR, CRR, FPR
Notary Public, State of Florida
Esquire Deposition Services
West Palm Beach Office Job #127542
3527-003
Page 1 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009676
EFTA00159483
Larry Visoski
October 15, 2009
APPEARANCES:
On behalf of the Plaintiff:
BRADLEY J. EDWARDS, ESQUIRE
ROTHSTEIN, ROSENFELDT, ADLER
401 East Las Olas Boulevard
Suite 1650
Fort Lauderdale, Florida 33394
On behalf of the Defendant:
ROBERT D. CRITTON, JR., ESQUIRE
BURMAN, CRITTON & LUTTIER
303 Banyan Boulevard, Suite 400
West Palm Beach, Florida 33401
On behalf of the Witness:
BRUCE REINHART, ESQUIRE
250 South Australian Avenue
Suite 1400
West Palm Beach, Florida 33401
ALSO PRESENT:
CARA L. HOLMES, ESQUIRE
1220 N.W. 157th Avenue
Pembroke Pines, Florida 33028
ADAM D. HOROWITZ, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
18205 Biscayne Boulevard, Suite 2218
Miami, Florida 33160
RICHARD H. WILLITS, ESQUIRE (VIA TELEPHONE)
RICHARD H. WILLITS, P.A.
2290 10th Avenue North, Suite 404
Lake Worth, Florida 33461
3527-003
Page 2 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009677
EFTA00159484
Larry Visoski
October 15, 2009
<table><thead><tr><th>WITNESS:</th><th>DIRECT</th><th>CROSS</th><th>REDIRECT</th><th>RECROSS</th></tr></thead><tbody><tr><td colspan="5">LARRY VISOSKI</td></tr><tr><td>BY MR. EDWARDS:</td><td colspan="4">6</td></tr><tr><td>BY MR. CRITTON:</td><td></td><td colspan="3">214</td></tr><tr><td>BY MR. EDWARDS:</td><td></td><td></td><td colspan="2">220</td></tr><tr><td>BY MR. CRITTON:</td><td></td><td></td><td></td><td>221</td></tr><tr><td></td><td>- - -</td><td></td><td></td><td></td></tr><tr><td></td><td>E X H I B I T S</td><td></td><td></td><td></td></tr><tr><td></td><td>- - -</td><td></td><td></td><td></td></tr><tr><td>NUMBER</td><td colspan="3">DESCRIPTION</td><td>PAGE</td></tr><tr><td>PLAINTIFF'S EX. 1</td><td colspan="4">FLIGHT LOG BOOK<br>(MARKED IN PREVIOUS DEPO)</td></tr><tr><td>PLAINTIFF'S EX. 2</td><td colspan="3">MESSAGE PAD</td><td>119</td></tr><tr><td>PLAINTIFF'S EX. 3</td><td colspan="3">MESSAGE PAD</td><td>119</td></tr><tr><td>PLAINTIFF'S EX. 4</td><td colspan="3">COMPLAINT</td><td>139</td></tr><tr><td>PLAINTIFF'S EX. 5</td><td colspan="3">INMATE VISITOR LOG</td><td>161</td></tr></tbody></table>
3527-003
Page 3 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009678
EFTA00159485
Larry Visoski
October 15, 2009
Deposition taken before Wendy Beath Anderson, Certified Realtime Reporter and Notary Public in and for the State of Florida at Large, in the above cause.
MR. EDWARDS: We're going to put something on the record about -- well, we'll do it this way --
MR. REINHART: Do it at the end, after we get him -- whatever you want. It's your show.
MR. EDWARDS: Okay. There were -- I don't even think Mr. Willits is aware of this. There was a subpoena duces tecum for this witness, as well as the previous witness, which was another pilot, Dave Rogers, and that duces tecum was to bring the flight logs related from 1998 through 2005. What was produced at the previous deposition were flight logs from 2002 through 2005, and now Mr. Reinhart has agreed to produce the remainder of the flight logs requested, those going from 1998 through 2002.
MR. REINHART: Correct. They're pilot logs, not flight logs. There are other records we indicated are corporate records, and with those you have to deal with Mr. Critton.
MR. CRITTON: However, with the proviso, too,
3527-003
Page 4 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009679
EFTA00159486
Larry Visoski
October 15, 2009
that we're going to work out that these records are to be used within the confines of this litigation and not to be spread to the press or anyone else, because they do contain confidential information as to who may have been on the plane and other records of Mr. Rogers, which but for the subpoena would have been only available to the FAA or some other law enforcement agencies.
MR. EDWARDS: Okay. Is that all you want to put on?
MR. CRITTON: Yes.
MR. EDWARDS: I'm not saying I necessarily agree or disagree with you. That's something that we'll deal with some other day.
MR. CRITTON: Bruce, you'd better produce these records, but there has to be some sort of understanding before --
MR. REINHART: Correct.
MR. EDWARDS: I won't do anything until you file whatever you -- until we work whatever it is out in court. I'll say that on the record, that I'm not doing anything with the records outside of my office until some judge deals with it.
MR. REINHART: And for the record, I'll adopt what Mr. Critton said on this one limited occasion.
3527-003
Page 5 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009680
EFTA00159487
Larry Visoski
October 15, 2009
MR. EDWARDS: All right.
Thereupon,
(LARRY VISOSKI)
having been first duly sworn or affirmed, was examined and testified as follows:
THE WITNESS: Yes, I do.
DIRECT EXAMINATION
BY MR. EDWARDS:
Q. Can you tell us your name for the record.
A. Lawrence Visoski, Jr.
Q. And Mr. Visoski, have you ever had your deposition taken before?
A. No.
Q. Okay. Here's the process: I'm going to ask you questions. You're going to give us answers. Try to give us answers that we all understand and that the court reporter can take down, such as yes, no, or some other verbal answer that we can understand. It's easy when we get in a casual conversation to nod or shake your head, and the court reporter is not writing pictures or anything else.
A. I understand.
Q. The other thing is, and I've been accused of this in other depositions -- I don't know if it's true or not -- but I need to wait until you finish answering
3527-003
Page 6 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009681
EFTA00159488
Larry Visoski
October 15, 2009
the question and you need to wait until I finish asking the question.
A. So you're not allowed to interrupt me?
Q. And you're not allowed to interrupt me.
A. Like I just did?
Q. Right.
MR. CRITTON: Cara just snickered when you said you've been accused because she recognizes it's true.
MR. EDWARDS: I don't know what the meaning of her snickering was.
BY MR. EDWARDS:
Q. But for what it's worth, if you don't understand the question or I've asked a bad question, I don't want you to guess. Give me the best answer to the best of your knowledge and if you need me to rephrase it, I will.
A. Okay.
Q. Okay. Tell me your current address.
A.
Q. How long have you lived there?
A. Approximately nine years.
Q. Okay. Who do you live there with?
A.
3527-003
Page 7 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009682
EFTA00159489
Larry Visoski
October 15, 2009
```markdown
Q. Who's your employer right now?
A. NES, LLC.
Q. How long has NES, LLC been your employer?
A. I'm guessing. I'd say back 1991. I have to do the math, but 17, 18 years.
Q. Has that been your only employer since 1991?
A. Yes.
Q. And has that been your only source of income since 1991?
A. Yes.
Q. And what is NES, LLC?
A. I don't really know. I mean, it's the company that my check comes from.
Q. What do you do for NES, LLC that results in them paying you?
A. I am chief pilot for the aircraft and
```
3527-003
Page 8 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009683
EFTA00159490
Larry Visoski
October 15, 2009
Q. And do you have a specific boss or somebody you answer to at NES, LLC?
A. Several people would call to schedule flights from the office, being it either Mr. Epstein or, you know, I would just get a phone call and they would schedule a trip.
Q. Okay. Aside from Mr. Epstein, who else would there be that would call to schedule flights?
A. Leslie.
Q. Leslie who?
A. Leslie Gruff.
Q. When's the last time you talked to Leslie Gruff?
A. Probably two weeks ago, three weeks ago.
Q. And where is she currently?
A. I believe in New York, is where I spoke to her on the phone last.
Q. What's the telephone number you call to reach Leslie Gruff?
A. [Blank space].
Q. And what address is Leslie Gruff at?
A. Do you mean where the office is located?
Q. Correct.
A. [Blank space].
3527-003
Page 9 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009684
EFTA00159491
October 15, 2009
Larry Visoski
Q. And it's my understanding from other depositions that there are also apartments in that building?
A. Yes.
Q. And Mr. Epstein either owns or leases or rents certain of those apartments. Is that your understanding?
MR. CRITTON: Form; speculation.
THE WITNESS: I'm only speculating. I don't -- to my understanding, I don't know.
BY MR. EDWARDS:
Q. Do you know other people that live in that building?
A. Well, it would be myself, Dave Rogers -- well, when you say "live," explain.
Q. When you're saying yourself and Dave Rogers --
A. See, we don't live there. I mean, we have -- we would stay there when we would have a trip.
Q. Okay. When you would fly up to New York and land in New York, the place where you would stay, is that ?
A. Yes, that's correct.
Q. That's also a location you've indicated in this deposition that is the office for NES, LLC?
A. Yes.
3527-003
Page 10 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009685
EFTA00159492
Larry Visoski
October 15, 2009
3527-003
Page 11 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009686
EFTA00159493
Larry Visoski
October 15, 2009
A. I only assume she lives there. I don't know for a fact. I'm trying to be honest and factual for you. So I couldn't honestly say if I knew she lived there or not.
Q. Where do you think lives?
A. I would think she lives there.
Q. You don't have a better location?
A. I don't have another location.
Q. Anybody else?
A. Not to my knowledge. I mean, I'd only be guessing that people live in that building that -- you know, I don't have any facts to prove that they actually live there. I mean, I don't think you want me to guess.
Q. Well, NES, LLC, would you say that the owner or controller of that company is Jeffrey Epstein?
MR. CRITTON: Form.
THE WITNESS: I don't know that for a fact.
BY MR. EDWARDS:
Q. Jeffrey Epstein is somebody you've indicated that you've worked for for 17 or 18 years, right?
A. Yes.
Q. And over the 17 or 18 years you've become personally close with him as well, correct?
MR. CRITTON: Form.
THE WITNESS: I don't understand how you mean
3527-003
Page 12 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009687
EFTA00159494
Larry Visoski
October 15, 2009
"close." Define that.
BY MR. EDWARDS:
Q. Well, more so than just a pilot that takes him from Point A to Point B?
A. That is my job.
Q. Right. But you know him on a personal level and that you've had personal conversations that don't necessarily deal with flying from Point A to Point B; isn't that right?
MR. CRITTON: Form.
THE WITNESS: More specific, meaning we talk about cars. I mean, does that make you a personal friends?
BY MR. EDWARDS:
Q. Have you ever gone to his house to eat?
A. No.
Q. Have you been to his New York home?
A. Yes.
Q. How many occasions have you been to his New York home?
MR. CRITTON: Object to form.
THE WITNESS: We normally pick up luggage in the lobby, so it would probably be quite often. Any time we depart out of New York, we stop by the house and pick up luggage and head to the aircraft.
3527-003
Page 13 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009688
EFTA00159495
Larry Visoski
October 15, 2009
BY MR. EDWARDS:
Q. Other than picking up luggage, have you been to his home to visit or socialize with him?
A. Not to socialize, no.
Q. Have you been to his Palm Beach home?
A. To?
Q. To Mr. Epstein's Palm Beach house?
A. Right.
Q. Have you been there?
A. Yes.
Q. Have you been inside?
A. Yes.
Q. And how many occasions have you been inside that home?
A. The same, as far as picking up luggage, and that would be on a regular basis, you know, for a departure. We wouldn't always go to the house to pick up luggage, but it made it easier for loading the aircraft, getting it done prior to departure.
Q. Is that the only reason that you have ever gone to the Palm Beach home over the last 18 years, is to pick up luggage?
A. No.
Q. What other reasons have you gone there?
A. I've set up several home theater equipments,
3527-003
Page 14 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009689
EFTA00159496
Larry Visoski
October 15, 2009
you know, televisions and such.
Q. Is that another hobby or job or something of yours?
A. Both.
Q. Does he pay you for that?
A. Not any more than my salary.
Q. What's your current salary?
A. At this time, 180,000.
Q. And what are you paid $180,000 to do?
A. To manage his aircraft.
Q. What does that entail?
A. Scheduling maintenance. Anything that has to do with any flight, whether it be weather, flight planning, time and distance to and from a location, any logistics involved in running an operation that has aircraft.
Q. In addition to the 180,000, does he give you bonuses as well?
A. There have been Christmas bonuses.
Q. Over the years, you mean, there have been Christmas bonuses?
A. Yes.
Q. Is 180,000 the most he's ever paid you?
A. No.
Q. All right. Were you making -- when was the
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last time that you were making an amount different than 180,000?
A. Last year.
Q. That would be 2008?
A. That would be correct. Yeah, we all took a salary cut, I don't know the exact date. It might have been 2008, last year. It was last Christmas we all took a 10 percent salary cut.
Q. Do you know why?
A. Economic reasons.
Q. And who told you that you were going to have to take the salary cut?
A. Darren Indyke.
Q. And did you ask for an explanation?
A. He explained it was due to economic reasons throughout the country.
Q. Okay. So in 2008, how much was -- were you being paid by NES, LLC?
A. 200,000.
Q. And is 200,000 the most that you've ever made from NES, LLC?
A. Yes, sir.
Q. And on top of that $200,000, did you get a bonus that year as well?
MR. REINHART: Which year are you talking
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about?
MR. EDWARDS: 2008.
THE WITNESS: That year, I think we skipped Christmas bonuses that year. The last bonus might have been 2007.
BY MR. EDWARDS:
Q. If you ever got a bonus from Mr. Epstein -- and I'm only deriving this from you using the term "Christmas bonus."
A. Holiday bonus.
Q. -- am I correct to assume -- sorry. Am I correct to assume that if you got a bonus, there was only one and it was at the end of the year, around the holidays?
A. Yes.
Q. Okay. And how much was the 2007 holiday bonus?
A. I'd have to ask my wife, to be honest. I haven't seen my paycheck in 27 years, so I believe it was $10,000.
Q. And in 2007 you also made $200,000?
A. Yes.
Q. Okay.
A. With a question mark. I'm trying to be as accurate as I can, but yes.
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Q. Something pretty close to that?
A. Yes, sir.
Q. Okay. So with the bonus it was 210,000, roughly?
A. Right.
Q. Okay. And how long were you making that salary?
A. Probably -- he was very religious about giving annual increases, so I would probably say 2006, you know, it was -- we would get increment -- increases of five or $10,000 each year. So I would say 2006. So it graduated, you know, progressive.
Q. Okay. Do you remember the progression if we start at 1991? Do you remember roughly what the progression was up through 2007/2008, when you were making $200,000?
A. No, I wouldn't know the progression.
Q. Okay. Do you remember what you were making from -- and was NES, LLC the company paying you back in 1991?
A. I don't know. I don't remember. Let me say it that way. I don't remember.
Q. Okay. When -- how long do you remember NES, LLC being the payer of your check?
A. Personally, two years, because I've never seen
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my paycheck. So I don't even know what's written on the top of it.
Q. That would be something that only your wife would see, I'm assuming?
A. You're right, since she probably wouldn't know the answer either, because she's looking at the right column and not the top column.
Q. Right. When is the first time that you had heard the name NES, LLC, that company?
A. Five, six years, and even questioned what it stood for. And I think to this day I couldn't answer that honestly, what it stands for.
Q. Okay. But it's your understanding that the NES, LLC is paying you for the work that you do as a pilot or maintain the planes for Jeffrey Epstein?
A. To my understanding, yes.
Q. And back in 1991, do you know if it was a different company that was paying you or if it was Jeffrey Epstein directly paying you?
A. I don't remember. I mean, I don't.
Q. Okay. Throughout your career with -- as a pilot for Jeffrey Epstein, since 1991, has there ever been a time when you believe you were paid directly from Jeffrey Epstein personally versus some company?
A. Not to my knowledge, no.
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Q. Okay. So whether it was NES, LLC or some other company, it was all of a sudden a company name, to the best of your knowledge?
A. Exactly, yes.
Q. And back in 1991, do you remember approximately how much you were being paid that year?
A. Fifty-five or 60,000, is maybe what I started.
Q. Okay.
A. You're going back a long ways.
Q. Yes.
A. I'm trying.
Q. Your relationship goes back that far. That's why I chose that year.
A. Right.
Q. Okay. Did you get bonuses even back that far?
A. Yes, sir.
Q. And do you remember what your bonuses were approximately?
A. 5,000. I mean, that was kind of the -- the starting point.
Q. Okay. In addition to monitary bonuses, were there ever gifts or any other type of compensation that NES, LLC or Jeffrey Epstein provided you?
A. Yes.
Q. And is that over the span of the 18 years?
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A. Yes.
Q. Okay. Tell me what some of those items are.
A. I remember one specifically was a pool heater.
Q. Excuse me?
A. A pool heater.
Q. When was that?
A. 1995-ish.
Q. Okay. Why did you get that?
A. I had built a pool and I didn't have a heater and he kind of laughed at me saying, "How can you have a pool without a heater?" So he says, "You ought to get a heater."
Q. Where were you when you had that conversation?
A. In the airplane.
Q. How did he know that you had built a pool?
A. Just in general conversation.
Q. You were having a conversation with Jeffrey Epstein?
A. Yes.
Q. And this is something that was happening on the airplane, this conversation?
A. During the flight. Yeah, it would have been like on cruise or something.
Q. Okay. When you say "during the flight," does that --
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A. Again, you're going back a long ways.
Q. I understand. We're talking about 1995 right now.
A. Yes.
Q. You're having a conversation with Jeffrey Epstein. Who is flying the airplane?
A. The auto pilot and there's two crew.
Q. Okay. So are you back in the back portion or is he up in the cockpit?
A. Up in the cockpit.
Q. Okay. Jeffrey Epstein sometimes comes up there?
A. Just, yeah, in between the two pilot seats.
Q. All right. Is that something that was typical, to have conversations like that?
A. Mm-hmm.
Q. Yes?
A. Yes. No nodding.
Q. And would those conversations be directed mainly with you or with the other pilots as well?
A. Mainly with me.
Q. I mean, you've kind of been described as the main guy or the main pilot. Wouldn't you consider that pretty much your role, right?
A. Well, that's chief pilot.
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Q. But more so than that, if there's going to be a casual conversation about a pool or a pool heater or whatever, it's going to be with you most likely if he's going to be talking to pilots, right?
MR. CRITTON: Form.
THE WITNESS: Right.
BY MR. EDWARDS:
Q. Okay. And you feel like over the years your relationship with Jeffrey Epstein has been pretty good?
A. Yes.
Q. And you have been closer to him over the years as you've grown to know him?
MR. CRITTON: Form.
THE WITNESS: The same throughout the same year. We never got any closer than 1991 than I am with him now. I'm very professional at what I do and know the line between being professional and thinking you're somebody's buddy.
BY MR. EDWARDS:
Q. Okay. So that's not something that you think you are? You don't think you're his buddy?
A. No, sir.
Q. Do you consider yourself his friend?
A. I believe so.
Q. Do you think he considers you his friend?
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A. I think so.
Q. All right. What makes you think that?
MR. CRITTON: Speculation.
THE WITNESS: He's always been kind and respectful.
BY MR. EDWARDS:
Q. Ever invited you to dinner?
A. No, sir.
Q. Have you ever associated or socialized with him during the day at any of his homes?
A. Only during a business reason.
Q. Okay. What are the other -- are the places that you believe that Mr. Epstein owns? I know we've talked about this Manhattan -- the Manhattan house.
I've read the articles about it, the Palm Beach mansion.
But what other places are you familiar with that Mr. Epstein owns?
MR. CRITTON: Form; predicate, speculation.
THE WITNESS: To answer it honestly, I don't know specifically that he owns any of the residences, to be honest. I would only assume that he owns. So if you want me to answer honestly, I don't know that he owns any of the other.
BY MR. EDWARDS:
Q. Okay. Well, what would be the basis for your
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assumption that he owns the home in Palm Beach?
A. He goes there, but I don't assume -- you don't have to own a house to go to it.
Q. And not only does he go there, you're aware that he spends the night there; he resides there sometimes, correct?
A. Yes.
Q. When he's in Palm Beach, that's where he --
A. He sleeps.
Q. -- sleeps? Right. When he's in New York, do you know where he sleeps?
A. No.
Q. But you've been to a particular house in New York that's a very large house that we've all read about that you picked up luggage at, right?
A. Yes, sir.
MR. CRITTON: Form.
BY MR. EDWARDS:
Q. And that home, do you know that -- I know that you're saying that you haven't done a public record search to make sure that Jeffrey Epstein owns it.
A. Yeah.
Q. But you assume that he does?
A. Assuming.
Q. That's where he sleeps when he's in New York?
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MR. CRITTON: Form.
THE WITNESS: I assume.
BY MR. EDWARDS:
Q. That's where his luggage is when you pick it up?
A. Doesn't mean he owns it.
Q. Right. But that's where it is?
A. Yes, sir.
Q. Do you know of anybody else who owns that home in New York?
A. No.
Q. Okay. Have you been to his ranch in New Mexico?
A. Yes.
MR. CRITTON: Form.
BY MR. EDWARDS:
Q. How many times have you been to his ranch in New Mexico?
MR. CRITTON: Form; predicate.
THE WITNESS: A guesstimate, fifty times, only due to the fact that we would fly there.
BY MR. EDWARDS:
Q. And where would you land?
A. Depending upon the aircraft, either Albuquerque or Santa Fe.
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Q. Are those private airports?
A. Public.
Q. Public, okay. Are there any private landing places where you would land any airplanes in New Mexico?
A. There are.
Q. That you have landed --
A. That I have.
Q. -- his airplane?
A. Yes.
Q. Where?
A. We have a 4500-foot strip on the ranch.
Q. When you say "we," yourself and somebody?
A. The company.
Q. What company?
A. Well, I should say -- I see where you're going with that. The ranch owns -- whoever owns the ranch. The ranch has a runway on it.
Q. Okay. And you've landed an airplane on that runway?
A. That ranch, yes.
Q. How many times do you think you've landed there?
A. Ten.
Q. All right. And have you been inside his ranch?
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A. Yes.
MR. CRITTON: Form to the last question.
MR. REINHART: Can you clarify, the physical ranch or the residences or the structures on the ranch?
MR. EDWARDS: I don't have a good visual appreciation for it.
BY MR. EDWARDS:
Q. Why don't you describe it in your words what this ranch that we are talking about looks like. And I've heard it referred to as the Zorro Ranch. Have you heard that?
A. I've heard that.
Q. That's the ranch we're all familiar with, we're talking about where the runway is and everything else?
A. Yes.
Q. Describe it in your own words, the landscaping of this ranch. What do we have on it?
A. There is a house up on the hill, a large house.
Q. How big?
A. Big. I've read 40,000 square feet in the paper.
Q. Have you been to it?
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A. Yes.
Q. Does that seem like it's feasible, approximately 40,000 --
A. I think so, yes.
Q. What else do we have on it?
A. There is a compound that has kind of motel room type -- they call it bunkhouse.
Q. Where's the bunkhouse located?
A. At the entrance to the ranch.
Q. Okay. And what is that primarily used for?
A. For the people that work on the ranch, they reside there. It's also a place where anybody that traveled on the airplane would stay. It's kind of like, you know, a hotel room.
Q. And how far is that from the first house that you described, the 40,000 square foot house?
A. It's probably 4 miles.
Q. Okay. So the Zorro Ranch is a rather large area of property?
A. Yes.
Q. And how many times -- I know we just talked about how many times you've been in the house, but how many times have you been on that ranch in New Mexico, the Zorro Ranch?
A. Thirty to fifty times over the years. That's
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a guesstimate.
Q. Is that over -- when was the first time that you went to that ranch?
A. A guess, I don't know when it was, actually, our first trip, but 1995/'94.
Q. Okay. And do you believe Jeffrey Epstein and/or a corporation owned or controlled by him to be the sole owner of that ranch?
A. I don't know any of those details.
Q. Have you ever talked to Jeffrey Epstein about who owns that ranch?
A. No.
Q. Do you know of anybody else who may own that ranch?
A. Not to my knowledge.
Q. Other than Jeffrey Epstein, do you know of anybody else who regularly stays there when they're in New Mexico?
A. Not to my knowledge.
Q. Does Jeffrey Epstein stay there when you're in New Mexico?
A. He has.
Q. And he has a key to the place?
A. I don't know if there's a key.
Q. One way or another, he gets in, right?
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A. Yes, sir.
Q. And he sleeps there?
A. Yes.
Q. Okay.
A. I assume he does.
Q. You assume he sleeps?
A. I do. I think.
Q. Okay.
MR. CRITTON: This is really --
BY MR. EDWARDS:
Q. Other than the pool heater in 1995, have you ever received any other gifts on top of the compensation from Mr. Epstein?
A. I did get land on the ranch to build a house.
Q. What do you mean you got land on the ranch?
A. He deeded me land to build a home.
Q. When was that?
A. Ten years ago at least.
Q. Do you know if he's ever deeded anyone else in this world land on the ranch to build a home?
A. Not to my knowledge.
Q. Why did he do that?
A. We would vacation out there and my wife fell in love with New Mexico and we were looking for property.
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Q. And did you talk to him about that?
A. Yes. He knew I -- he was aware I was looking for a home and he says, "Well, I have so much land, I could give you a spot to build a home on." So I built a house.
Q. So how long has a home actually been on that property?
A. Nine years.
Q. And that's a home that you own?
A. Yes, sir.
Q. And that's a home that was -- when I say "you own it," is there a mortgage on it or did he give it to you free and clear?
A. No, no, I paid for the house. I made payments on it.
Q. All right. So what did he actually give you?
A. 40-acres of land.
Q. That you did not have to pay for?
A. You know, I'd have to go back and look. I think it was -- I had to pay something for it. I don't remember.
Q. How often have you visited that piece -- that home that you own?
A. My wife would spend summers out there with the kids.
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Q. Okay. But that's on the Zorro Ranch?
A. Yes.
Q. So in addition to the 50 or so times you've been to the Zorro Ranch, you've been to your property that's on the Zorro Ranch?
A. Yes, which over the years, it's once-a-year visits. So I mean, it is included in the 50 times that I've been there.
Q. Okay. And did you have a conversation with him that led to him giving you or gifting you 40-acres of land?
A. We talked about it because he knew I was looking for a home out there.
Q. Okay. In gifting you that land, did you consider yourself at that point in time to be more than just his pilot, as more of a friend?
A. No. You're using the word "gifting." I paid for the land. I don't recall what it was. But you use the word "friend." I don't know that a -- sure, he was a friend. I mean...
Q. Well, did he give Dave Rogers any land out on the New Mexico ranch?
A. No.
Q. Okay. When you say you paid for it, I thought that I asked that question, "Did you pay for the
33
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40-acres?" I thought your answer was, "I don't know, I'd have to go back and look."
Are you saying now that you did pay for that land?
A. I don't remember. If there was a sum of money, it was just for, you know, the legal purpose of a transfer of ownership of the land.
Q. Okay. If it was a substantial amount of money, that's something that you would have remembered?
A. Oh, exactly. No, it was not a substantial amount.
Q. Okay. Do you remember approximately how much money you had to give Jeffrey Epstein for that land?
A. I would only be guessing. It might have been five dollars. To my knowledge, I don't remember.
Q. Okay. So when I'm saying he gave you the land, he may have actually given you the land?
A. Sure.
Q. Okay. And to the best of your knowledge, he's never given anyone else land out there?
A. Not to my knowledge.
MR. CRITTON: Form.
BY MR. EDWARDS:
Q. All right. How big is this house that you built on the ranch?
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35
A. 1800 square feet.
Q. Were you ever at that house at the same time when he's at his house that's on that Zorro Ranch?
A. Yes.
when he's at his house that's on that Zorro Ranch?
A. Yes.
Q. All right. We started back in 1991 with you making around $55,000 a year and that has progressed over time to a point where in 2007 you were making $200,000 a year. I don't want to go through every single year; that would take a really long time. But the progression, was that on a yearly basis normally or after two years or three years?
A. Yearly basis.
Q. Okay. And would that normally be in increments of?
A. $5,000.
Q. Okay. You've talked about a couple other gifts that have been given to you from Jeffrey Epstein over the years; one is a pool heater in 1995 and now some 40 acres of land on his New Mexico ranch. Any other gifts you can think about?
A. No other gifts.
Q. Okay. I don't want to split hairs with you. You obviously thought about that answer before giving it. What other items are you thinking about that he's given to you or cut you a discount on or otherwise that
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you feel was compensation for you working for him?
A. I drive a company car. I mean...
Q. Okay. What kind of car?
A. A Hummer.
Q. You say "a company car." That's owned by NES, LLC?
A. No, I think the registration has Zorro Development on it.
Q. What is Zorro Development?
A. I believe that's the ranch, or at least it has the name of the ranch. I don't know what the entity is.
Q. And it's your understanding that that's a company vehicle?
A. Yes.
Q. And where is that vehicle primarily garaged?
A. At my home.
Q. In or in the Zorro Ranch?
A. No, here in .
Q. All right. And is there only one company vehicle that you're issued?
A. Yes, sir.
Q. And is that something that was -- that you did not have to pay for?
A. No, it's just something I drive. I mean, it's not titled to me or anything like that. It's just a car
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that I drive.
Q. All right. You've worked for him for 18 years. I don't even know how long the Hummer would last, but presumably, that's not the car you've had over the entire 18 years. Have you always had a company car?
A. No, I haven't, no.
Q. When did you get the Hummer?
A. Probably three years ago.
Q. Do any other members of Mr. Epstein's piloting team have company cars?
A. No.
Q. Only you?
A. Yes.
Q. And do you know how that decision was made to get you a company vehicle?
A. No.
Q. What do you use that vehicle for?
A. To and from the airport.
Q. All right. Do you use it for personal reasons also?
A. I guess, yes.
Q. I mean, that's your primary vehicle?
A. Yes, or I drive my wife's car.
Q. Which is?
A. Type of car?
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Q. Yes.
A. A Mercedes.
Q. And is that something that was also a gift from Mr. Epstein?
A. No, sir.
Q. What type of Mercedes is that?
A. A ML 430, ten years old.
Q. All right. Are there any other items -- company car, the land in New Mexico, the pool heater -- any other items that Mr. Epstein has given you over time as compensation or reward or anything else?
A. No, sir.
Q. And your only income is from Mr. Epstein or his companies?
A. Correct.
Q. Okay. And it's been that way since 1991?
A. Yes.
Q. How did you meet Mr. Epstein or become involved with him in 1991?
A. We heard at the airport that Mr. Epstein was purchasing an airplane when Dave Rogers and myself were living in Columbus, and we had the opportunity to interview with him, and we did and got the job.
Q. And this is before he owned the airplane?
A. Yes.
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Q. And which airplane was that?
A. The Hawker.
Q. Does he still have the Hawker?
A. No.
Q. How long did he have that plane?
A. Five years, guesstimate; four or five years.
Q. So sometime in the mid '90s?
A. Yes.
Q. Did you keep any type of logs or documentation as to who would have been flying on that airplane if you transported any individuals?
A. The same logs as you possess now are the flight logs.
Q. Okay.
A. That's the standard for the industry.
Q. So that's something that you kept, or that Dave Rogers kept?
A. Dave Rogers.
Q. Okay. If there are any documents out there with names of passengers on any of the flights involving planes owned or controlled by Jeffrey Epstein and/or his companies, those would be documents in the possession of Dave Rogers and not yourself?
A. Oh, the corporation actually, they belong to.
Q. Okay.
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MR. REINHART: That was a compound question.
You might want to split it in half.
MR. EDWARDS: Okay.
BY MR. EDWARDS:
Q. What documents do you believe exist that indicate names of individuals that have been passengers on Mr. Epstein's airplanes?
MR. REINHART: Are we going back all the way from '91 to the present?
MR. EDWARDS: Sure.
THE WITNESS: You're talking about the Hawker?
BY MR. EDWARDS:
Q. Any airplanes. What documents would there be?
A. There would be the same: Flight logs and passenger manifests would exist.
Q. And are either of those required?
A. The flight log is required for the aircraft to track times and landings.
Q. And in the flight log, is it required that you designate the names of the passengers?
A. No.
Q. That's just something that Dave Rogers did on his own?
A. Everybody does that. It's more for Internal Revenue.
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Q. Okay. If something happens, they know who is on the plane?
A. Exactly, weight and balance.
Q. Have you ever kept any flight logs that have names of people on the airplane?
A. When you say "kept," I have filled out flight logs or the passenger manifest, yes.
Q. By "kept" I meant maintained to where they're in your possession either on paper or computer?
A. We keep --
MR. REINHART: Can you differentiate a flight log from the pilot's log that we showed you earlier?
MR. EDWARDS: Okay.
BY MR. EDWARDS:
Q. I'm talking about -- I don't know that it's called a flight log, a pilot's log or any kind of log.
A. They are different, yes.
Q. Yeah. I'm asking about, have you kept or do you have any documentation that would indicate the names of passengers that have flown on any of Jeffrey Epstein's planes?
A. No.
Q. Either in the form of paper or on a computer?
A. No.
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Q. Makes that easy.
A. Okay.
Q. In 1991, were you the chief pilot?
A. No.
Q. Somebody else was the chief pilot?
A. Yes.
Q. Who's that?
A. Dave Rogers.
Q. All right. At what point in time did you become chief pilot and switched with Dave Rogers?
A. Six years ago; five, six years ago.
Q. Why?
A. Professionalism, technique.
Q. What do you mean by that?
A. The way Dave would operate an aircraft, Jeffrey knew the difference when I was flying and when Dave was flying.
Q. How do you know he knew the difference?
A. Just --
Q. He told you?
A. Yes. He knew the difference that if he never came up front, he knew who was flying, who landed.
Q. And what was the conversation that he had with you that resulted in you becoming chief pilot, switching positions with Dave Rogers?
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A. Jeffrey would always critique Dave's flying capabilities, and I tried to help Dave and explain to him what Jeffrey likes and doesn't like. And Jeffrey's also conveyed these likes and dislikes. And Dave maintained continuing with certain piloting techniques that were just not comfortable to passengers. And this went on through the years, and Jeffrey just got tired of it one day.
Q. What specifically were Jeffrey Epstein's likes and dislikes with respect to the flight of the plane?
MR. CRITTON: Let me put in a form here. But I don't know what this has to do with anything in this case.
MR. EDWARDS: I understand that, Bob.
MR. CRITTON: I want to use this for some other depositions where we -- we've gone beyond the scope.
THE WITNESS: The case in point, the last straw was there was a technique called quiet flying where you would retard the throttles well short of the runway and pretty much glide the airplane in. Well, if you don't do that correctly, you have to spool the engines up just prior to touching down that -- because you're losing air speed and it's an uncomfortable sound and feeling for the passengers
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thinking that you're not going to make the runway.
And it was a continuous practice of Dave doing that to be neighbor friendly as opposed to being passenger-comfort friendly.
BY MR. EDWARDS:
Q. Okay.
A. Hence, the transfer of power.
Q. Has he ever discussed with you where he wants you to be, whether that is "stay in the cockpit when I have people on the airplane," or don't intermingle with the passengers or anything else?
A. He's never stated that to us.
MR. REINHART: Could you clarify which "he" you're talking about?
MR. EDWARDS: I'm talking about Jeffrey Epstein.
MR. REINHART: Okay.
BY MR. EDWARDS:
Q. You understood that?
A. Yes.
Q. It's my understanding that in the -- well, tell me other than the Hawker, what other airplanes have you flown for Jeffrey Epstein?
A. A Gulfstream.
Q. Does he still have that plane?
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A. Yes, sir.
Q. How big of a plane is that?
A. Large corporate jet.
Q. How long has he had it?
A. Fourteen years; 13, 14 years.
Q. And other than the Gulfstream, what other airplanes does he have?
A. When you say "he," obviously, these are company-owned --
Q. Jeffrey Epstein or his companies.
A. A Boeing 727.
Q. Well, I know that's a very large airplane. I think that's been described by other people, so I'm not going to have you do that. But there's partitions in that airplane -- in the back rooms of that airplane, right?
A. Yes.
Q. Several different partitions to where if the pilot comes out of the cockpit, you don't necessarily see all the passengers?
A. Yes.
Q. That's true?
A. Yes.
Q. Okay.
MR. REINHART: Keep your voice up so she can
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hear you.
THE WITNESS: Oh.
MR. REINHART: And so Mr. Willits can hear you.
BY MR. EDWARDS:
Q. Other than the Gulfstream and the Boeing and the Hawker, what other airplanes has Jeffrey Epstein owned over the years?
A. That is it.
Q. And currently still owns -- or the companies associated with him own the Gulfstream and the Boeing?
A. Yes.
Q. And in the past two years, have you flown those two airplanes?
A. Just for routine flights to keep them loose or, you know -- you know what I mean.
Q. Have those two airplanes been flown by anyone else in the last two years?
A. No.
Q. Have those two airplanes been flown in the last two years for any reason other than routine maintenance-type flights?
A. We've had one -- two flights I think in the past two years.
Q. And what were the purposes of those flights
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and who was on the flights?
A. One flight I believe we went to Sebring and another flight we went to Nassau, Bahamas.
Q. And who did you go to Nassau, Bahamas with?
A. I'd have to look at the flight log, but I think it was [black text], I believe. I think that was the three passengers, to the best of my knowledge.
Q. And it's my understanding that little St. James is an island that Jeffrey Epstein owns or controls?
MR. CRITTON: Form.
THE WITNESS: I don't know that he owns it.
BY MR. EDWARDS:
Q. Has he ever been to an island called Little St. James?
A. Yes.
Q. And have you been there with Jeffrey Epstein?
A. I've been there when he was there.
Q. Have you flown on an airplane with him to that destination?
A. No.
Q. All right. When you say you've been there when he was there, how did that come about?
A. We flew into St. Thomas and then we flew to
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Little St. James in a helicopter.
Q. And do you fly the helicopter as well?
A. Yes.
Q. How many helicopters are owned or controlled by Jeffrey Epstein and/or corporations associated with him?
MR. CRITTON: Form.
THE WITNESS: At this time, one.
BY MR. EDWARDS:
Q. And has that helicopter been flown in the last two years?
A. Just for routine maintenance.
Q. And when you and -- let's say when and flew to Nassau, do you know the purpose of that trip?
A. No.
Q. How long did you stay?
A. Five hours.
Q. Did you pick anybody up there?
A. No. Meaning passengers?
Q. Yes.
A. No.
Q. What happened? You landed the airplane and then what?
A. The passengers left. Dave and I went and had
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lunch. The passengers showed up and we came back.
Q. Have you ever stayed at the home that is on Little St. James?
A. No.
Q. Have you known Jeffrey Epstein to stay at that home?
A. I don't know that for a fact.
Q. Okay. Do you believe that he is the owner or controller or has some interest in the home or the island of Little St. James?
MR. CRITTON: Form.
THE WITNESS: I have no knowledge of that being a fact.
BY MR. EDWARDS:
Q. And you have no belief that that is a fact?
A. Exactly.
Q. When you say you've been there when he was there, how many times has that occurred?
A. Estimating, a hundred times.
Q. Okay.
A. Trying to give an honest answer.
Q. Okay. And in the approximate -- I'm not going to hold you to a hundred times, but in the approximately hundred times --
A. Sure.
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Q. -- for what period of time are we talking about?
A. During what period of time?
Q. Right.
A. Let's see, when did all this happen? What, 2007? So eight years prior to whenever he stopped flying. So...
Q. '98/'99?
A. Yeah, I guess, yes.
Q. I mean, that sounds like a right --
A. Sounds about right, yeah. Don't hold me to it again.
Q. All right.
A. You're going back a long way.
Q. So from approximately the '98/'99 time frame when Jeffrey Epstein would fly to Little St. James, would you be the pilot?
A. Yes.
Q. Okay. And you say that you've been there -- I thought that you just told me that you've been there the same time he was there, but then I thought the subsequent question was well, were you on the flight with him, and I thought your answer was no. Maybe I misunderstood that.
A. No, you said the question "Have you ever flown
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to his island?" We never landed on his island. We landed in St. Thomas.
Q. Got it.
A. I was just trying to be exact.
Q. Thank you.
A. It's a small island.
Q. Okay. So how is it that when Mr. Epstein wants to go to Little St. James, what is the path that you take to get actually to the island of Little St. James?
A. I don't understand the question.
Q. Well, you just told me you fly the airplane to St. Thomas?
A. Right.
Q. And then what?
A. Then sometimes I would go get the helicopter or he could also take a boat to the island. But normally the helicopter's located on St. Thomas. I'd fire up the helicopter, come pick him up, drop him at the island and I come back to St. Thomas.
Q. And when he stays on St. James, you drop him off on St. James. I suppose you're going to tell me you don't know if he stays there or not?
A. Exactly.
Q. But do you stay --
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A. I don't. I mean --
Q. Well, he either stays there or someone else picks him up in a helicopter or he swims away?
A. Correct.
Q. Okay. You stay on St. Thomas?
A. Yes.
Q. Okay. Is there a place that you've stayed on St. James, ever?
A. No, I've never.
Q. So in the hundred or more times that you've been to the island, is it my understanding that each of those times you've been there to drop off Jeffrey Epstein and/or any passengers and you've immediately left and gone to St. Thomas?
A. Yes, sir.
Q. You never been inside that home that's located on St. James?
A. Yes, I've been inside the home.
Q. How many times have you been inside the home?
A. I mean, ten, fifteen times.
Q. And for what occasion?
A. I've set up the theater system that's in the living room.
Q. Okay.
A. So it would be there to work to hook up a TV
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or a stereo.
Q. And do you know Les Wexler?
A. No, I don't.
Q. Have you ever met him before?
A. I have met him.
Q. Do you know of any relationship between Les Wexler and Jeffrey Epstein?
A. I don't know what -- to what extent they have a relationship, no.
Q. Do you know if they know one another?
A. I don't know that for a fact. They talk to one another, so I would assume. But I don't know to --
Q. How do you know they talk to one another?
A. I've seen them speak to one another at the foot of the airplane.
Q. All right. Have you ever flown the airplane -- any of the airplanes with Les Wexler as a passenger?
A. No.
Q. Have you ever flown the airplanes with ___ as a passenger?
A. Yes.
Q. And do you know ___?
A. Yes.
Q. And for how long have you known ___?
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A. I'm guessing, six years. I mean, don't hold me to it. I'm not the greatest on length of times, but six, seven years, I think.
Q. How did you meet her?
A. I guess I was introduced. She was on a flight of ours.
Q. You were introduced to her by whom?
A. She may have introduced herself. I mean, you're going back a ways. I don't know the official introduction, how it went.
Q. And to your knowledge, what is her -- is she associated or affiliated in some way with Jeffrey Epstein?
MR. CRITTON: Form.
THE WITNESS: I would assume so. I don't know to what level or what actually her job description is.
BY MR. EDWARDS:
Q. All right. Well, how many flights have you flown where she and Jeffrey Epstein have been passengers together on one of the airplanes that we've been discussing?
A. I'd only be guessing again.
Q. We're talking hundreds of flights, though?
A. Sure, sure, a lot of flights.
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Q. It seems to be -- I mean, you seem like somebody who has common sense. It seems like somebody that knows Jeffrey Epstein?
MR. CRITTON: Form.
BY MR. EDWARDS:
Q. Correct, ?
A. Yes.
Q. All right. And do you believe that there is a business relationship there or a personal relationship there, from your observations?
A. I'd only be speculating. When they get on the airplane, my focus is forward and flying safely. So I don't -- you know, I'd only be guessing at either one of those two.
Q. Okay. Have you ever socialized with
?
A. No.
Q. Other than speaking with her on the airplane, have you spoken with her elsewhere?
A. Over the phone, in passing, I mean, walking down the street in New York. I mean, yes.
Q. Why would you call or why would she call you?
A. She would call me to schedule the aircraft for a departure.
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Q. And have you ever called her?
A. Yes.
Q. When's the last time you talked to me?
A. A week ago.
Q. What was the occasion?
A. We were discussing carpet for one of the aircraft.
Q. And where was she when you were talking with her?
A. I don't know. It was over the phone.
Q. Did she call you or you call her?
A. No, I called her on her cell.
Q. Okay. And that's a New York number?
A. I don't know. It's on speed dial.
Q. Do you have your phone with you?
A. Yes.
Q. Could you tell me what that number is?
A. Sure.
Q. Thanks.
A. Sure. (___).
Q. Which airplane were you discussing carpeting for?
A. Was actually -- actually, it was for the helicopter. Now that I'm thinking about it, the
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helicopter.
Q. In the last two years, did you tell me the helicopter has flown?
A. Yes.
Q. And where to?
A. I have flown the helicopter to Fort Lauderdale on several occasions for maintenance. I've flown it to Miami. And I try to fly the helicopter at least every two weeks just either by myself to run it up to its -- it's important that it keeps moving.
Q. Other than maintenance-type flights, have you flown the helicopter in the last couple of years?
A. Yes.
Q. And who was on the helicopter?
A. I flew to Miami with Mr. Epstein.
Q. When was that?
A. It was a couple weeks ago or a month ago, I think.
Q. For what?
A. Sorry?
Q. For what occasion?
A. I think he had a meeting with his attorneys in Miami.
Q. Today is October the 15th. Is this during the month of October that you had this flight in the
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helicopter with Mr. Epstein?
A. I'd have to look at the book to be exact for you.
Q. Okay. But it's either the end of September or the beginning of October?
A. Yeah.
Q. How do you know that he was meeting with his attorneys?
A. I believe that he had mentioned that he was meeting his attorneys.
Q. Did he tell you why?
A. No.
Q. Why did he tell you he was meeting with his attorneys? Did you ask him?
A. No.
Q. Okay. That's just something that he said to you in conversation?
A. Yes, sir.
Q. Was there anyone else on the airplane besides you and Mr. Epstein?
A. Yes.
Q. Who was that?
A. □□.
Q. □□ who?
A. □□ □□.
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Q. How long have you known?
A. I don't know, five years. A guess again, four, five years.
Q. Do you know what her relationship is, if any, with Jeffrey Epstein?
A. I do not know.
Q. Do you know if she knows Jeffrey Epstein?
A. I would assume so. They talk. I would imagine she knows him.
Q. And how many times has she been on the airplane or the helicopter on flights at the same time as a passenger with Jeffrey Epstein?
A. Many. I'd have to look at the logs.
Q. Hundreds of times?
MR. CRITTON: Form.
THE WITNESS: Sure.
BY MR. EDWARDS:
Q. If you were going to, as somebody who has been Jeffrey Epstein's pilot for 18 years, tell me today who the five closest people are to Jeffrey Epstein, would be one of them?
MR. CRITTON: Form.
THE WITNESS: I'd only be guessing and speculating. I have no idea.
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BY MR. EDWARDS:
Q. Okay. Well, as his pilot and the person who travels with Jeffrey Epstein on the majority of his flights, who are the people who travel most frequently with Jeffrey Epstein?
MR. REINHART: Can we get a time period?
BY MR. EDWARDS:
Q. In the last ten years, which people travel most frequently with him?
A. I'd have to look at the flight logs to give you an accurate answer.
Q. You can't give me one single name of somebody who you would say is a frequent flyer?
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Q. What's your understanding between the relationship of Ghislaine Maxwell and Jeffrey Epstein?
A. I don't really know.
Q. All right. So when you say you're guessing that and know or are associated with Jeffrey Epstein, that guess is being made on the -- with the observation that they have been frequent flyers with Jeffrey Epstein on more than hundreds of flights on his private plane?
A. Yes, that's what I'm basing it on.
Q. And do you know where is staying these days?
A. No.
Q. Do you know what car she's driving these days?
A. No, I don't.
Q. Okay. Do you know if she's living with Jeffrey Epstein these days?
A. I don't know that.
Q. Do you know how met Jeffrey Epstein?
A. I don't.
Q. Were you on an international flight bringing her into the country from some other country at any time?
A. I don't know.
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MR. REINHART: Can we clarify? You mean with Mr. Epstein or --
MR. EDWARDS: No.
BY MR. EDWARDS:
Q. Did you ever bring from some foreign country into the United States?
A. I'd have to look at the log books, honestly.
Q. That's not something you remember?
A. No. I mean, she -- I think she's been on Europe trips with us, and I think she's returned from Europe with us, but I could not say that honestly.
Q. On this recent helicopter flight with and Jeffrey Epstein, did you talk with them during that flight?
A. No.
Q. Where did the flight go from? And obviously, it landed in Miami, but where did you leave from?
A. West Palm Beach.
Q. And did and Jeffrey Epstein arrive together?
A. You know, I don't remember. I was out at the helicopter and I think they both started walking up. So I don't know if they came separately or not. I was already at the helicopter.
Q. How long is that flight from Palm Beach to
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Miami?
A. Twenty-five minutes.
Q. And did they talk to one another during that flight?
A. No.
Q. They were both completely silent during that flight?
A. Yes.
Q. Okay. Is that typical when they are on flights together, especially with the helicopter, where you're in pretty close quarters, that they would abstain from speaking to one another?
MR. CRITTON: Form.
THE WITNESS: Yeah, it would be typical. It's very noisy and communicating in a helicopter is, you know, not that comfortable.
BY MR. EDWARDS:
Q. Over the last five or six years that you have known or been familiar with, have you heard her and Jeffrey Epstein conversing with one another?
A. I've heard them conversing, but if you ask me what they had said, I could say it -- I wouldn't even know what they had said to each other. I've seen them talking to each other.
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he is fascinated or infatuated or appreciates or loves or likes massages?
A. I have no knowledge of that.
Q. All right. How about Ghislaine Maxwell, has she ever talked to you about massage therapy or have you ever overheard her talking about that?
A. No.
Q. You certainly read the papers over the last couple of years, correct?
A. Not on my top ten list. I mean, I've read a couple articles, but I'm not one to focus on that so much as some people would.
Q. Okay. When the investigation about Jeffrey Epstein came about, the criminal investigation -- you're aware that's what I'm talking about, right?
A. That was last year?
Q. Well, it was a couple years ago.
A. Right, okay.
Q. Did you speak with Jeffrey Epstein about that investigation?
A. No.
Q. Were you told not to speak with him about that investigation?
A. I think we knew ourselves that we weren't -- it wouldn't be proper to even bring it up.
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Q. All right. When you read in the newspapers the allegations that Mr. Epstein was involved with numerous underage girls for sexual reasons, were you surprised?
A. I didn't believe it.
Q. Do you believe it today?
A. I don't believe it.
Q. You don't believe that Jeffrey Epstein was involved with underage girls in a sexual way?
MR. CRITTON: Form.
THE WITNESS: You're asking for my opinion, and I don't think my opinion is relevant in that matter.
BY MR. EDWARDS:
Q. I think it's relevant. Can you just tell me whether today you believe that Jeffrey Epstein has engaged in sex with underage girls?
MR. CRITTON: Form; speculation, irrelevant, always.
THE WITNESS: It's irrelevant.
BY MR. EDWARDS:
Q. I need an answer.
A. I don't believe he had sex with underage women.
Q. Or engaged in any sexual acts with underage
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women?
MR. CRITTON: Form.
THE WITNESS: No.
BY MR. EDWARDS:
Q. You think that this is just a story that a bunch of underage women have made up?
A. Speculation.
MR. CRITTON: Objection. Now it's argumentative. Who gives a darn what he thinks one way or another? If he has personal knowledge --
MR. EDWARDS: You're objecting to the form?
MR. CRITTON: It's argumentative.
MR. EDWARDS: You're objecting to the form?
MR. CRITTON: Yes.
MR. EDWARDS: Okay.
BY MR. EDWARDS:
Q. Is that something that you believe that a bunch of women -- some of which know each other, some don't, some of which have been on the airplane and some which haven't -- made this up, that Jeffrey Epstein engaged in some sexual conduct with them?
MR. CRITTON: Form.
THE WITNESS: What I believe doesn't matter in this case, does it?
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MR. EDWARDS: Is there a privilege that we're asserting?
MR. REINHART: No, it's irrelevant. It's harassment and not likely to lead to discoverable evidence.
MR. EDWARDS: I'm going to put on the record right now that it is -- we are allowed discovery into a RICO count. We are also allowed discovery into the intent of Mr. Epstein in developing a criminal enterprise designed to sexually exploit and sexually abuse underage girls. We believe that in doing so, he associated intentionally with people of similar beliefs that sex with underage girls is okay, and that there have been many discussions with this witness, as well as many other witnesses with -- to insure his protection from law enforcement that they not answer these specific questions. And thus, the opinions and beliefs of all of these witnesses that we are
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alleging associated with this criminal enterprise are certainly reasonably calculated to lead to the discovery of admissible evidence. And if you're still instructing the witness, based on that proffer, not to answer any of these questions, I'm going to continue to ask the questions and you can instruct him not to answer and we can go to the Court.
MR. REINHART: My response is to his opinion whether people making allegations in this case are colluding or making up a story is irrelevant to what you just said. So I am going to instruct him not to answer any question that goes to his opinion of someone else's motivation or the truth of facts to which he has no knowledge.
So yes, I'm instructing him not to answer.
MR. CRITTON: Let me add in my part, is that I think -- you're certainly not only capable to ask questions with regard to what his personal knowledge is, and if he knows something or he has reasonable basis for it; certainly you are entitled to that information. I think you've asked those questions and he's given you straightforward answers as to what he knew or what he didn't know under those circumstances. And as to what his
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thoughts are on something which he has no factual basis or even an assumption to know one way or another is irrelevant. That's ultimately for a fact-finder in this case.
While it's interesting, it's argumentative and I don't think he's -- I mean, do it on a question-by-question basis. If he has knowledge, that's great, but to argue your case with this witness or any other witness doesn't serve a purpose and I think is, you know -- I think it's not a good use of our time, I'll put it that way. But you know, you can go ahead and ask.
MR. EDWARDS: I can ask the question and if the witness is being instructed not to answer, we'll let a judge decide whether he needs to answer the question and whether it's discoverable or not.
MR. REINHART: Absolutely. Make your record.
BY MR. EDWARDS:
Q. Do you have any reason to believe that Jeffrey Epstein engaged in sexual activity with underage women?
A. I have no reason to believe.
Q. Okay. So as you sit here today, based on your 18 years of knowledge, experience and observation of Jeffrey Epstein, is it your belief that he has not had sex or engaged in sexual activity with underage women?
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A. It's an opinion, and I believe that he has not.
Q. Okay. Isn't it true that at some point in time you learned that Jeffrey Epstein has -- strike that.
MR. CRITTON: When you ultimately get to a good place to break, will you let us know?
MR. EDWARDS: Let's break now.
(A break was had at 11:28 a.m.)
BY MR. EDWARDS:
Q. All right. Eighteen years of being a pilot for Jeffrey Epstein and in terms of being able to name somebody that you would say you've observed with Jeffrey Epstein and would classify that person as Jeffrey Epstein's friend, can you name anybody?
A. ✖️, ✖️; just people that we see routinely on the airplane.
Q. That's people you see routinely in the last five to ten years, right?
A. Yes.
Q. Prior to that time, anybody that you've noticed as Jeffrey Epstein's friend may be Ghislaine Maxwell?
A. What time frame?
Q. Is that a person that at some point in time
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you would classify as Jeffrey Epstein's friend?
A. I would classify it. I don't know if it's true.
Q. But that's only because they were on the airplane together?
A. Yes.
Q. Do you know what Jeffrey Epstein does for a living in your 18 years of observing and talking with Jeffrey Epstein?
A. No.
Q. No idea?
A. No.
Q. Ever asked him?
A. No, actually.
Q. Ever been curious?
A. Sure.
Q. Ever done anything to satisfy that curiosity?
A. If you mean Google it, not really, actually.
I mean, I really have not.
Q. Okay. So in 18 years of traveling and being the pilot and driving -- and taking this person, Jeffrey Epstein, from one property in New York to New Mexico and Florida and around the world, you have no idea what he does in terms of how he makes money?
A. No, sir.
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Q. I was produced this flight log -- tell me if I'm using the wrong term. What is this called, this book that I've been provided by Dave Rogers?
A. I've never seen that book.
Q. I'll let you see it. I don't know that it was always in a book, so maybe that's why you haven't seen it. Tell me what we're looking at.
A. Well, judging with the name at the bottom, I believe this is Dave's flight log, log book.
Q. I didn't know if it was called a flight log.
A. Pilot log book, how's that? That's the appropriate name.
Q. It was marked as Composite Exhibit 1 in Roger's deposition, as indicated by the exhibit sticker. We'll mark it the same in your deposition as well.
MR. CRITTON: Why don't you refer to it as his?
MR. EDWARDS: Fine.
BY MR. EDWARDS:
Q. It's the pilot log book of Dave Rogers?
A. Yes.
Q. And the years provided in this book are 2002 through 2005; I can represent that to you. I'm going to ask you about certain people that David Rogers wrote down as being on the airplane and I want to ask you if
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you know who they are. This person right here is.
It seems like she flew on numerous flights. Do you know who that is?
A. No. I heard the name, but I don't know who that is.
Q. All right. Is that somebody that you remember seeing on any of the flights that you were on?
A. What year are we talking about here? I don't remember.
Q. Well, this is January 2002. You'd probably know how to read this book a little bit better than me, so I don't know.
A. He keeps his a lot more current, so I know the name. If she walked in here right now, I would probably look right through her, to be honest.
Q. Do you know what affiliation or relationship she had with Jeffrey Epstein?
A. No.
Q. Okay. There are various -- each row I'm told by David Rogers is a different flight and it indicates where it takes off from and where it lands, et cetera. There's a lot of other information, especially over on this side of the page that I'm not familiar with, nor do I need to be.
A. Right.
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Q. But it's evident that the plane is being used, at least for this time period, January of 2002 through 2005, on a fairly regular basis. I mean, we're looking at January 6th, 11th, 13th, 13th, 14th, right?
A. Uh-huh.
Q. I mean, is that something that you would say accurately reflects the amount of use of Jeffrey Epstein's planes?
A. Yes.
Q. So he travels quite frequently?
A. Yes.
Q. And he travels with many different people, right?
MR. CRITTON: Form.
THE WITNESS: Yes.
MR. CRITTON: Can I ask one question? I was wondering what happened, who has possession of now what's the original Exhibit No. 1 of Mr. Rogers' deposition? Did you retain it?
MR. REINHART: The actual book itself?
MR. EDWARDS: The court reporter took it, right?
MR. CRITTON: The one marked as an exhibit, did you keep that?
MR. REINHART: This is it.
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MR. EDWARDS: This is it?
MR. CRITTON: Who took it from the deposition the other day?
MR. EDWARDS: I have this one right now.
MR. REINHART: That's the only copy?
MR. EDWARDS: Okay.
MR. CRITTON: So you took the original?
MR. EDWARDS: Apparently. It has the original sticker.
MR. CRITTON: When I say "the original," the original copy. Would you have someone recreate what you've got and send it to us so we have it?
MR. EDWARDS: Sure. In fact, why don't I wait until I get the whole thing and I'll copy all the pages and send it to you instead of piecemeal.
MR. HOROWITZ: You mean before the transcript comes?
MR. EDWARDS: We can copy it.
MR. CRITTON: If you give it to me, I'll copy it and send it back to you.
MR. REINHART: I have a copy. It just doesn't have the exhibit sticker on.
MR. EDWARDS: That's what was told to me the other day, that's why I took it.
MR. CRITTON: I want something -- I just don't
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want to -- if you give me a copy, I'll put a sticker on it.
MR. REINHART: Or just copy the page that has the exhibit sticker on it.
MR. CRITTON: Sorry.
BY MR. EDWARDS:
Q. Like on this flight, we have "JE." I'm assuming that's Jeffrey Epstein, correct?
A. Yes, I'll assume.
Q. "GM," Ghislaine Maxwell, right?
A. Yes.
Q. "■," ■?
A. I would assume.
Q. I mean -- okay. And then this name, do you recognize that person, ■?
A. Never heard it.
Q. And then ■?
A. Yes.
Q. You've heard that name?
A. I've heard the name.
Q. Not sure who that is, though?
A. No.
Q. There's only one, two, three, four, five, six people on that flight?
A. Uh-huh.
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78
Q. That's pretty typical of the amount of passengers that you would have on a flight?
A. It varied, sure.
Q. Okay. But it varied between -- if we look a few lines down, Jeffrey Epstein and Ghislaine Maxwell were the only two passengers. Certainly there were flights like that as well, right?
A. Mm-hmm.
Q. And so it varied from having one or two people to six or seven people, right?
A. Yes.
Q. What's the most people that you remember traveling on any of Jeffrey Epstein's airplanes?
A. Twenty-five.
Q. Okay. That would be a rarity, wouldn't you say?
A. Oh, yeah.
Q. Because I've looked through this log. I haven't seen any place where there were 25, but there are lines that have maybe eight or nine people listed.
A. Right.
Q. Let's see. There's a flight from January 15th -- sorry, January 17th, January 20th and January 22nd of 2002 that all had [blank]. That doesn't serve to refresh your recollection as to who
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that is, does it?
A. No.
Q. Okay. Do you know what the purpose of her being on the airplane flight along with Jeffrey Epstein, Ghislaine Maxwell and would be?
A. No.
Q. Okay. Do you know how it comes about that gets on that flight? How does she even know there's a flight available?
A. I don't know.
Q. All right. Well, let's go down to somebody that we may all know a little bit better. February 9th, 2002, there's a flight that has Bill Clinton, four Secret Service agents and then instead of listing names or initials or anything else, it's just listed as two males, one female, Jeffrey Epstein, Ghislaine Maxwell, and I forget who Dave Rogers told me "AP" is. Do you remember who that is?
A. No.
Q. Okay. Either way, how is it that someone like Bill Clinton gets on a Jeffrey Epstein flight?
MR. CRITTON: Form.
THE WITNESS: I don't know.
BY MR. EDWARDS:
Q. Do you know before the flight takes off that
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Bill Clinton's going to be a passenger on the flight?
A. Yes.
Q. And how do you know? How do you get that information?
A. The day before I'd get a phone call from, say, saying we're leaving tomorrow going to wherever, and sometimes she'll say who's going, sometimes she won't. On a case where President Clinton would be on board, we would put a little extra catering on board or do that little extra TLC to the aircraft.
Q. If it's leaving -- this says it's leaving from MIA and where is it landing?
A. HPN I believe is White Plains.
Q. Okay. Do you remember that flight?
A. I remember being on it.
Q. Well, I mean, if you look through here, obviously you had Bill Clinton on the airplane ten or twenty times, right?
A. Yeah. He's my main focus. I remember him being on the aircraft, sure.
Q. Do you remember him being on the airplane with younger girls?
MR. CRITTON: Form.
THE WITNESS: No.
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BY MR. EDWARDS:
Q. Okay. Do you know what his relationship was with Jeffrey Epstein?
A. No.
Q. Do you know if they were friends?
A. Assuming.
Q. But you're assuming why? Just because he's on his plane?
A. Yeah.
Q. Okay. So you assume that the people that are listed on here are friends of Jeffrey Epstein's and that's why they are riding on his plane?
A. I'm speculating.
Q. I'm just not familiar with the -- because I've never been on a private flight -- with the manner in which you go about getting on one of these flights. I mean, you have to, I guess, know that Jeffrey Epstein has a plane, that it's going from a destination that you are at and want to go to, and that it's available and those kind of things. Can you tell me, enlighten me --
A. Well, it's not publicly offered, no. It would be no different than you jumping in your car and knowing you're going to the mall. I mean, it's not public information, you know, where planes are coming to and from, and you don't put your name out there to get
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onboard a flight.
Q. Does Jeffrey Epstein charge these people as passengers?
A. I don't know.
Q. Okay. Are these people such as Bill Clinton, does that mean that Bill Clinton called or somebody affiliated with Jeffrey Epstein to get on the plane or that Jeffrey Epstein called Bill Clinton and asked do you want a ride?
MR. CRITTON: Form; predicate.
THE WITNESS: I have no idea.
BY MR. EDWARDS:
Q. No idea?
A. No idea whatsoever.
Q. Joe Pagano, do you know who that is?
A. Yes.
Q. What's his relationship with Jeffrey Epstein, or what was it back in February -- sorry, March 17th of 2002, when he and and Jeffrey Epstein and Todd and one female were on this flight?
A. I don't know to what extent or what his relationship is. He just was a passenger on the airplane.
Q. Okay. And the next day -- sorry, two days later on the 19th of March, Bill Clinton flies again,
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this time with Doug Band, three Secret Service agents, Jeffrey Epstein, Ghislaine Maxwell and **S**. Do you remember that flight?
A. Where did we go?
Q. Starts in JFK.
A. Right.
Q. Where is that?
MR. CRITTON: Do you have a date?
MR. EDWARDS: March 19th, 2002.
THE WITNESS: EGGW I believe is Luton,
England.
BY MR. EDWARDS:
Q. Okay. Do you remember flying to England?
A. I do remember flying to England. I just don't remember that trip. What airplane were we in? We were in the Boeing.
Q. Do you remember the purpose of the trip?
A. No.
Q. Do you know who Doug Band is?
A. I heard he's Clinton's, how would you say, assistant. I mean, I've seen that in the newspaper, seen it on CNN.
Q. Okay. Did you ever hear that Doug Band and Ghislaine Maxwell were together, even for a day or a night?
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A. No.
Q. Did you ever hear that Doug Band and Ghislaine Maxwell were the people attributed to introducing Bill Clinton and Jeffrey Epstein?
MR. CRITTON: Form.
THE WITNESS: I don't know.
BY MR. EDWARDS:
Q. All right. There's another flight here on January -- I can't read this upside down. Maybe it says May --
A. Looks like.
Q. -- 22nd, 2002. Again, with President Bill Clinton, ___, ___. Can you tell me who ___ and ___ are?
A. I don't remember.
Q. Would you know them if you saw them?
A. Probably not because the names don't even ring a bell.
Q. All right. And then there are plenty of flights, many of flights where Jeffrey Epstein, Ghislaine Maxwell and ___ are the primary passengers, or at least are some of the passengers on the flights, correct?
A. Mm-hmm, yes.
Q. And still, as you sit here, you being the
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pilot of these flights, you're not sure what their relationship is or whether any of them were socially connected in any real way?
MR. CRITTON: Form.
THE WITNESS: No. When you're flying the airplane, there's a lot more going on than passengers' relations.
BY MR. EDWARDS:
Q. All right. You remember this person, are you familiar with her at all?
A. I remember the name, that's it.
Q. What do you think her relationship is to Jeffrey Epstein?
A. No idea.
MR. CRITTON: What date are you on, Brad?
MR. EDWARDS: Oh, sorry. I am at June 21st, 2002.
BY MR. EDWARDS:
Q. That's not somebody that you specifically remember?
A. Mm-mm, no.
Q. No? Is that somebody that you think was a regular flyer for any period of time in Jeffrey Epstein's life?
A. Not a regular.
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Q. Okay. Jean Luc Brunel, is that a name that you know?
A. Yes.
Q. How do you know that name?
A. Only because it's a unique name and his attire is very unique. So you remember certain things. So I know he who that is.
Q. Do you know what he does?
A. No.
Q. Do you know his association with Jeffrey Epstein, if any?
A. No, I don't know what the relationship is.
Q. Have you ever heard of him owning or running or managing a modeling company?
A. I have seen that in the paper a few years back.
Q. Okay. Other than seeing it in the paper, have you ever talked to Jean Luc Brunel or Jeffrey Epstein about owning or running or managing a modeling company?
A. No.
Q. Do you know if Jeffrey Epstein's affiliated with the modeling company that's owned, run or managed by Jean Luc Brunel?
A. No, I have no idea.
Q. And seeing that this is a flight now, that
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we're referring to the same flight on June 21st of 2002, that includes Jean Luc Brunel, Jeffrey Epstein, Ghislaine Maxwell, those are the passengers of this flight, does that serve to jog your memory as to who is?
A. No. I mean, you see how frequently we fly. I mean, it's -- the passengers in the back are so far removed from an operation of commanding an airplane like that, it's nothing that sticks in your head.
Q. And you as the pilot, is there any way that you would know what's going on in the back of the airplane?
A. No. My concerns are all on the cockpit.
MR. CRITTON: Brad, the last one that you mentioned, was that the same date, June 21st, '02?
MR. EDWARDS: Yes.
BY MR. EDWARDS:
Q. There's another name here that I was going to ask you do you know. June 23rd, 2002, are you familiar with that name?
A. No.
Q. Also on the same flight with Jean Luc Brunel. That doesn't help to jog your memory either, right?
A. No.
Q. That's somebody that you remember as a
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frequent passenger?
A. Who are you referring to?
Q. ?
A. No.
Q. Dr. Jarecki, is that somebody that you remember flying?
A. I know the name. He may have been on the airplane once or twice. I'm guessing only.
Q. Do you remember meeting him?
A. Yes, I have met him.
Q. Do you remember his purpose for being on the airplane?
A. No, sir.
Q. Amanda Venaro, do you remember her purpose for being on the airplane?
A. No.
MR. REINHART: Can we get a date?
MR. EDWARDS: I was asking him if he remembered Amanda Venaro. I wasn't referring to a specific flight.
BY MR. EDWARDS:
Q. You don't remember her being on the flight?
A. I don't remember the name.
Q. Me showing you the flight isn't going to jog the memory?
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A. No. The name that would launch it first --
MR. CRITTON: Could I ask you a question? You have the original exhibit marked at the deposition. It looks like it's been highlighted.
MR. EDWARDS: I highlighted it.
MR. CRITTON: Oh, okay. So you've highlighted the original exhibit that's marked for the deposition? I just want the record to reflect that.
MR. EDWARDS: Yeah.
MR. CRITTON: Okay. Thank you.
MR. EDWARDS: At the time I highlighted it I didn't realize I was holding on to the original exhibit. I didn't realize that until you just pointed that out.
MR. CRITTON: I've noticed that.
MR. EDWARDS: So now when I give it to you, I'm giving you my work product as well. I don't see how this works against you, but anyway.
BY MR. EDWARDS:
Q. Melissa Stall, is that a name that you remember?
A. No.
Q. Okay. And then Jean Luc Brunel is somebody who I noticed flew relatively frequently, so is that why
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you -- that name jogs your memory a little better than some of these other people?
A. He dresses uniquely.
Q. In what way?
A. Just loud clothes, so something that you would remember, that's all.
Q. Do you know his role in Jeffrey's life?
A. No.
Q. Ever heard that he is affiliated with Jeffrey Epstein because they both have a sexual attraction to underage girls?
MR. CRITTON: Form.
THE WITNESS: You're making an assumption on that.
BY MR. EDWARDS:
Q. Have you ever heard that?
MR. REINHART: He's asked you if you ever heard that.
BY MR. EDWARDS:
Q. If your answer is no, it's no.
A. I'm sorry, I thought you said they did. No, I have not.
Q. Okay. I keep highlighting this name,
just because it looks like somebody that's regularly flying on the airplane. But the more that you
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see her name, that doesn't change your opinion as to whether or not you remember her or what --
A. I remember the name, you know, that's all.
Q. Do you remember about what age she was when she was flying on the airplane?
A. No.
Q. This could be somebody who is 50 years old or ten years old, for all you know?
MR. CRITTON: Form.
THE WITNESS: Yes.
BY MR. EDWARDS:
Q. Okay.
A. I mean, I would only be guessing at an age.
Q. Yeah, but I mean, you don't remember her at all. So you don't --
A. I remember the name, exactly.
Q. Other than the name?
A. Right, yes, sir.
Q. But you can't even come close to putting a face with that name?
A. I mean, no. I mean, if you said draw her picture with -- I couldn't come close to even getting it.
Q. Okay. You remember this flight where President Clinton, Kevin Spacey and Chris Tucker,
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Jeffrey Epstein, Ghislaine Maxwell?
A. Yes.
Q. From JFK to what is this, LPAZ?
A. LPAZ, that is --
Q. South Africa or something?
A. No, it's the Azores Islands, Santa Maria.
Q. Do you know the purpose of that trip?
A. That was a fuel stop.
Q. Okay. And do you know why Chris Tucker and Kevin Spacey were on that airplane?
A. No.
Q. Did you talk to them?
A. They came up in the cockpit and said hello. So they conversed, nothing more.
Q. Another name that is on here a few times, I'm specifically referring right now to the dates of September 23rd and 24th of 2002, is Ron Burkle. Do you know who that is, Ron Burkle?
A. I know what that is, yes. I didn't realize he was on our airplane.
Q. Right now that is the first time that you remember Ron Burkle being on your airplane?
A. Yeah.
Q. You don't know the purpose for him being on that airplane?
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A. No. Granted, I'm seeing this for the first time, so I'm trying to --
Q. Let me ask you that. Because this was given to me at a deposition of Dave Rogers, who I understand was the chief pilot for Mr. Epstein, and now you're the cheap pilot, but you always kind of worked in tandem, correct?
A. Sure; we complemented each other.
Q. And you both worked for the same company that flies Jeffrey Epstein's airplanes, right?
A. Yes.
Q. So I was of the presumption, which may have been -- I may have been misled here, or I may have, you know, misunderstood the purpose behind this book or how it was created. I thought that you had probably seen this before at some point in time?
A. Oh, no.
Q. Did you know that Dave Rogers was keeping this book?
A. No. I know he keeps a pilot log book.
Q. Okay. But you didn't know he was keeping the names of the people who were on the airplane?
A. No. It's not required, so I mean, it's...
Q. So today is the first time that you are learning that the names of the people that are on the
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airplane was kept by Dave Rogers?
A. Yes, in his log book.
Q. Okay. And it's my understanding when you fly back into the country through Customs, you have to report the people that are on the airplane, right?
A. Yes.
Q. And who would create that document or call that information into Customs?
A. Whoever the captain was for the day.
Q. At times would that be you?
A. Yes.
Q. Okay. And at times when you would come into the country with passengers -- well, not at times. Didn't you also have to report their date of birth?
A. Sure.
Q. At times weren't there also people that you would bring in from other countries into the United States that were under the age of 18?
A. Yes.
Q. And at some times those were flights that included Jean Luc Brunel and girls that were under the age of 18, right?
MR. CRITTON: Form.
THE WITNESS: I don't remember those flights.
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BY MR. EDWARDS:
Q. Okay. You don't remember which flights it would have been where there would have been girls under the age of 18?
MR. CRITTON: Form.
THE WITNESS: Well, I would have to look at the flight logs.
BY MR. EDWARDS:
Q. It's not illegal to have somebody under the age of 18 on a flight anyway, right?
A. No, not at all.
Q. Were you ever aware that you, as pilot, were transporting girls under the age of 18 who were supposed to be models?
MR. CRITTON: Form.
THE WITNESS: I had no knowledge.
BY MR. EDWARDS:
Q. Okay. You never knew who the people on the airplane were, what their purpose was, their role with Jeffrey Epstein or Jean Luc Brunel?
A. No.
Q. All right. Do you know [___]?
A. No, I don't remember that name.
Q. [___]?
A. I remember the name.
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Q. She flew frequently at least for a period of time. Do you remember that?
A. Yes.
Q. Is that somebody that you thought was familiar with the modeling industry or related to the modeling industry?
A. No.
Q. Okay. And these people, did Jeffrey Epstein ever tell you how he was associated with any of them?
A. No.
Q. Did you ever wonder how he was associated with any of them?
A. No, never interested.
Q. And on several of these -- on most of these, the names or initials of the people that are on the flight are listed. Do you know on the occasions where it lists generically two females or three females or six females, do you know why that was done?
A. Just because we didn't know our -- the person's name. We tried to do the best we could to keep the records.
Q. When you say "we tried to do the best that we could" --
A. Dave and I.
Q. Okay. But the first time that you learned
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that he kept anybody's names was today, right?
A. Well, I didn't know he kept them in his log book. We would fill out the passenger manifest as we're -- having passengers' names in your pilot log book, he's probably the only person in the world that does that.
Q. Okay.
A. So when you were mentioning putting the names down, when you said female or male, you know, I was referring to the passenger manifest.
Q. For each of these same flights, then, that we're referring to out of this log book that was marked as Composite Exhibit 1 in Dave Rogers' deposition, am I understanding you correctly, then, there would also be a passenger manifest for each of these flights?
A. Yes.
Q. Now, where would I find the passenger manifest? Who keeps that documentation?
A. Corporate -- our corporate office.
Q. Which is whom?
A. Up in New York, Darren Indyke.
Q. At what corporation is that, though?
A. NES, LLC, I guess.
MR. REINHART: Do you know for sure?
THE WITNESS: I don't know for sure. I mean,
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when you say -- we would just send them up to New York.
BY MR. EDWARDS:
Q. Did you ever keep a copy of them?
A. No.
Q. Why did you keep a passenger manifest?
A. Just for tracking of -- to have the times on there for --
MR. REINHART: Can I confer with him on one thing before you ask a question?
MR. EDWARDS: Yeah, yeah.
(Off the record discussion.)
MR. REINHART: Mr. Edwards, let him amend his prior answer. I think he misunderstood the question.
MR. EDWARDS: I don't know what question we're amounting the answer to.
MR. REINHART: Let me clarify this way: As the passenger manifests, they are corporate documents of either JEGE or Hyperion Air, whatever company owns the plane. Mr. Visoski has physical custody of them. He retains them but they're not his documents. They're the corporate documents. So they're not in New York.
THE WITNESS: Those are the ones that I have
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at the airport office that I had turned into counsel that has the passenger names on them.
BY MR. EDWARDS:
Q. Okay.
A. It's called a passenger manifest.
Q. Okay.
MR. REINHART: Right.
## BY MR. EDWARDS:
Q. The passenger manifest, just so I understand exactly what that is, tell me. Tell me in your own words.
A. It's departure time, the city, the landing time exactly and the passengers that would have been on that flight.
Q. And at times on that passenger manifest would you list also generically female or male?
A. Yes. That was the document I was referring to stating that if we didn't know a person, we did not go out of our way to find out a name. We just put in to account for how many people were on the aircraft at that time.
Q. Who is currently in the custody or control -- sorry. Who currently maintains or has possession of the passenger manifest from 1998 through the present, through today for those airplanes that you flew related
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to Jeffrey Epstein?
A. I currently have, which counsel has now, 2005, I believe, until the present time. And the records previous to that I believe were turned into counsel with the previous investigation with Jack Goldberger's office, I believe. I believe they maintain those records.
Q. When you say "turned into counsel," there are a lot of counsel involved here.
A. Jack Goldberger's office, I believe.
Q. When you say "the previous investigation," you're talking about the criminal investigation?
A. Exactly, yes, sir.
Q. And you're aware in that criminal investigation, obviously, that Jeffrey Epstein pled guilty to certain charges, correct?
A. From what I read, yes.
Q. Well, you did visit him in jail, right?
A. Yes. We didn't talk about that.
Q. Okay. You know in order to go to jail, though, you have to be convicted of some crime, right?
MR. CRITTON: Form; argumentative.
THE WITNESS: Yes.
BY MR. EDWARDS:
Q. It wasn't like he was visiting the jail and
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you were visiting and you happened to bump into each other. You actually went to see him while he was an inmate in jail?
A. Right, yes.
Q. Okay. So when we're talking about the criminal investigation, we're talking about the criminal investigation revolving around the allegations of Jeffrey Epstein engaging in sex acts with minors?
MR. CRITTON: Form.
BY MR. EDWARDS:
Q. That's the criminal investigation you're talking about, right?
MR. CRITTON: Form.
THE WITNESS: I don't know the full definition of really what happened there. I know that it was something to do with solicitation of prostitution.
That's all I read.
BY MR. EDWARDS:
Q. Okay. Were you aware that the allegations revolved around underage girls or girls under the age of 18?
MR. CRITTON: Form.
THE WITNESS: I was aware it revolved around it, yes.
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BY MR. EDWARDS:
Q. Who first made you aware of that?
A. The newspaper.
Q. Were you ever questioned by the police?
A. I don't know who questioned me, actually. I did have a questioning session, but I don't even remember who questioned me.
Q. Where did that take place?
A. I don't remember.
Q. At your house?
A. No. I'm thinking it was Jack Goldberger's office, or it may have been downtown at the Palm Beach County Courthouse or something in that area there.
Q. Okay. So it either happened at an attorney's office that represented --
A. Exactly, yeah, I think so.
Q. -- Jeffrey Epstein or the other side?
A. Yeah.
Q. And during that questioning, is that when you turned over the passenger manifest from prior to 2005?
A. Yes.
Q. And you turned those manifests directly over to Jack Goldberger?
A. Yes. Actually, I believe Dave Rogers did that. I wasn't in possession of those records.
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Q. And for the passenger manifest prior to 2005, how far do those passenger manifests go back in time?
A. They should go back, I guess, to 1991 or whenever we started existence.
Q. And did you turn them over from 1991 all the way through to 2005?
A. I don't know. I didn't turn them in. Dave Rogers did.
Q. Are you in possession of a copy of any of those materials?
A. No.
Q. I thought that, you know, ten minutes ago when we were talking about this you said you had them back at an office or --
A. That was the office, the airplane office, which I've given to Bruce, which is the current log. He is in possession of them now. I had possession of them.
Q. Okay. What he's in possession of -- just so I know what documents are where, he's in possession of the passenger manifests from 2005 through the present?
A. Correct.
Q. If I want to obtain the passenger manifests from 1998 through 2005, that's something that I would request from whom?
THE WITNESS: Help me out. That's --
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MR. REINHART: If you know.
THE WITNESS: I don't know who possesses them right now. They were turned into Jack Goldberger's office a year and a half or two years ago.
BY MR. EDWARDS:
Q. You started out by indicating that you sent these passenger manifests, or a copy thereof, to Darren Indyke or someone at NES, LLC; is that correct?
A. Correct.
Q. If I requested them from NES, LLC, that's somebody at some point in time was in possession of all the passenger manifests?
A. Sure.
Q. And NES, LLC's address is the one you gave me at ?
A. I believe so. I don't know what address they're using for that. I know that --
Q. But Darren Indyke's the attorney that I would call --
A. Yes, sir.
Q. -- and he could probably steer me in the right direction?
A. Yes.
MR. CRITTON: Form.
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BY MR. EDWARDS:
Q. Do you know **[**?**
A. Yes.
Q. How do you know her?
A. She was on the airplane.
Q. How old is she?
A. I have no idea.
Q. Age range?
A. Twenty-eight.
Q. Now?
A. Yeah, 28, or maybe if not older now. She was probably 28 probably, I guess. She was somebody in her late 20s.
Q. So we're talking about 2003? That's what I'm trying to understand.
A. I'm guessing.
Q. We're talking 2009 now. We're saying 28. By that do you mean in 2003 she was 23 or 24 years old?
A. You're having me guess on her age.
Q. Yeah.
A. I mean, I can't be accurate.
Q. Somebody between 18 and 25?
MR. CRITTON: Form.
BY MR. EDWARDS:
Q. At the time you were seeing her back in --
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A. If you want me to guess --
Q. No, I don't want you to guess.
A. I don't know then.
Q. Well, if I say between ten and fifty?
A. That's a range.
Q. If I say between ten and fifty, you're not guessing there anymore. You know she's in there, right?
A. She's in the middle there, yeah.
Q. Okay. How can we narrow that down? We're talking about somebody in her 20s?
A. In her 20s.
Q. At least that's what you believed?
A. Yes.
Q. All right. Is that somebody that you know to be associated or friendly with Ghislaine Maxwell?
A. I don't know.
Q. Do you know what her relationship was to Jeffrey Epstein or Ghislaine Maxwell?
A. No.
Q. Do you know where she is now?
A. No idea.
Q. When's the last time you talked to her?
A. I don't know. What date do you have on there?
Q. February 2003.
A. So, probably that long ago. I may have said
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hello.
Q. That's somebody who was on the airplane multiple times?
A. More than once. I mean, I have no account for how many times.
Q. Well, I've asked you about a bunch of names, most of which you don't really remember, but that's one name you do remember.
A. Yeah, I remember the name, yeah.
Q. Okay. And that's somebody who you actually -- you would remember the face too?
A. I might remember Amy's face.
Q. All right. Do you remember why she would have ever been on your airplane?
A. No idea.
Q. President Andres Postrana, at the time I guess that was the president of Colombia back in February -- sorry, March 20th of 2003. Do you know who that is?
A. I don't remember him being on the airplane, but I know who that is.
Q. Okay. He's on the airplane with Jeffrey Epstein, Ghislaine Maxwell, and Jean Luc Brunel?
A. Where did we go?
Q. I'll let you look at it. I'm talking about
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A. Palm Beach to Nassau. I'm sorry, I don't remember that one.
Q. When we're saying we're going down to Nassau, is that a place that you frequently went to with the airplane?
Q. And is that a route that you would take for the ultimate destination to be Little St. James?
A. No.
Q. If the ultimate destination was Little St. James -- show me a flight where the ultimate destination was Little St. James.
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A. No.
Q. Do you remember Naomi Campbell, picking her up from St. Thomas along with Jean Luc Brunel?
A. I remember her being on board. I don't remember the flight.
Q. Do you know Joel Pashcow?
A. Yes.
Q. How do you know him?
A. He was on the airplane.
Q. And is that somebody you knew at one point in time to be a friend of Jeffrey Epstein's?
A. He was on the airplane. I don't know what the relationship was.
Q. Do you know what the relationship is today?
A. No idea.
Q. How about Todd Mister, do you know what that relationship is or was today?
A. No.
Q. Do you remember him?
A. No.
Q. Not at all?
A. I mean, I know the name. I don't know.
Q. Paula Epstein, do you know who that is?
A. Yes.
Q. Who is that?
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A. That's Jeffrey's mom.
Q. She's passed away?
A. Yes.
Q. At least that's your understanding, right?
A. That's what I heard, yes.
Q. Okay. **do you know her?**
A. **I know the name.**
Q. Somebody who flew on the airplane with some regularity?
A. Yes.
Q. And do you know her to be friends of Ghislaine Maxwell or **or Jeffrey Epstein?**
MR. CRITTON: Form.
THE WITNESS: I have no idea who she was friends with.
BY MR. EDWARDS:
Q. All right. Do you know what role she ever played, if she played one, in Jeffrey Epstein's life?
A. No.
Q. All right. Glenn Dubin, are you familiar with him?
A. Yes.
Q. How do you know Glenn Dubin?
A. I met him on the airplane.
Q. Outside of the airplane, have you ever seen
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him around Jeffrey Epstein?
A. No.
Q. All right.
A. No.
Q. **,, do you know that name?**
A. No.
Q. She was on several flights. You don't remember seeing her?
A. No.
Q. All right. And how about Alan Dershowitz, I'm sure you know who that is?
A. Sure. He's famous.
Q. What was your understanding of Alan Dershowitz's relationship with Jeffrey Epstein?
A. Never talked about it.
Q. Forrest Sawyer, do you know why he was on your airplane?
A. Never heard the name, actually.
Q. Really?
A. No.
Q. Larry Summers?
A. I know the name. I don't remember flying him.
Q. Have you ever talked to Joe Fontanela?
A. Yes.
Q. How do you know him?
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A. He usually drops Jeffrey off at the airport.
Q. In fact, you've called him directly before, right?
A. Yes.
Q. You still have his number?
A. I haven't -- yes, I think I still got it in my memory.
Q. Okay. What is it?
A. It's been a few years. It’s kind of an easy one.
MR. CRITTON: 917 is the first --
THE WITNESS: Yes.
MR. CRITTON: Who was this for?
MR. REINHART: Joe, Joe Fontanela.
MR. EDWARDS: Fontanela.
BY MR. EDWARDS:
Q. Do you know his address, where he resides?
A. No, I don't.
Q. Do you know if he -- what his role is in Jeffrey Epstein's life?
A. Not really. He just -- he drove the car.
Q. He drove what car?
A. The car up in New York.
Q. Okay. Do you know if he's a housekeeper up at that house up in New York?
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A. I don't know what his role is.
Q. Have you ever worked for a company called Air Ghislaine? Do you know that company?
A. Yes.
Q. Do you know what that company does?
A. No.
Q. Have you ever been an employee of that company?
A. No.
Q. Do you know who runs that company?
A. No.
Q. Is Jeffrey Epstein associated with that company?
A. I don't know.
Q. How have you heard of that company?
A. It's the company name that our registration for the helicopters is under, Air Ghislaine.
Q. Is that somebody who's ever paid you, a company who's ever paid you?
A. No.
Q. Do you know Igor Zinoviev?
A. Yes.
Q. How do you know him?
A. Met him on the airplane.
Q. What is your understanding of his affiliation
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Q. Do you know -- did you tell me, do you know what Leslie Gruff does for Jeffrey Epstein?
A. I don't know her exact title.
Q. You talked to all of these individuals at some point in time, either on the phone or in person, right?
A. Yes.
Q. And you don't know whether they play a role in Jeffrey Epstein's life, or if they do, what they do?
A. Exactly.
Q. And how do you decide who you're going to call for what reason?
A. For example? Can you be more specific?
Q. If you're going to make a telephone call and you're going to talk to let's say Leslie Gruff, why would you choose to call her?
A. I don't know. You're having me make the phone call. I don't know why I would call her.
Q. Have you ever called her?
A. I think, yes, I've called her, sure.
Q. Why? What would be the reason that you would call her? Somebody told you to call her? Here, call this number?
A. I may have called her maybe to find out if we had a departure time for any specific trip. I mean, that would be...
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Q. Okay. So you're calling her related to Jeffrey Epstein?
A. Sure.
Q. Okay. So you know that she plays some role in some aspect of Jeffrey Epstein's life, whatever that is?
A. Right.
Q. Okay. So when I'm asking these questions about these people, and I feel like I'm getting answers that I'm not really not sure that these people have any role in their life, that's not -- that's not completely accurate, right?
MR. CRITTON: Form; argumentative.
BY MR. EDWARDS:
Q. I mean, you do know that these people are somehow involved with him, whether socially or business-wise or otherwise, and during the course of your years, you've made telephone calls on his behalf or to coordinate things with them right?
A. Right.
MR. CRITTON: Object to the form. You said "these people."
BY MR. EDWARDS:
Q. I'm talking about . That's somebody you called before, right?
A. Sure.
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Q. What would be a reason you called
MR. CRITTON: Object to form. Probably the same reasons he said two hours ago, for scheduling purposes. But you've covered that. Go ahead and answer it again.
THE WITNESS: For scheduling purposes, would be my only reason to call her.
BY MR. EDWARDS:
Q. That's funny that you used the exact same words that Mr. Critton wants you to use.
MR. CRITTON: It's what he said two hours ago.
BY MR. EDWARDS:
Q. What would be the reason why you would call Ms. Maxwell, Ghislaine Maxwell?
A. Same reason.
Q. That's not somebody you call these days, though, right?
A. I haven't seen her in some time.
Q. What made you stop calling Ghislaine Maxwell where you thought at one point in time you thought she was a person to call related to your job?
A. Just was no reason to.
Q. Is that somebody who you think is still affiliated or associated with Jeffrey Epstein or his --
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whatever he does?
A. I'd only can speculating. I don't know.
Q. All right. Do you know the number
MR. CRITTON: Could you say it slowly. 🗣️?
MR. EDWARDS: Thank you. And just in case you didn't get it, I'm going to mark these as an exhibit so that we can read them later.
BY MR. EDWARDS:
Q. Do you know that number?
A. Yes.
Q. What is that number?
A. That's my cell phone.
Q. Okay. Is that still your cell phone?
A. Yes, sir.
Q. All right. I'm going to show you two documents here or pieces of paper. We'll mark them as Exhibit 2 and Exhibit 3. The first one is dated March 5th, 2005. Do you remember making this telephone call? And just for the record, this looks like a message that's being taken relative to a phone call that you made.
MR. REINHART: So the question is does he remember making the phone call?
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BY MR. EDWARDS:
Q. Do you remember making that phone call after reading the message?
A. Let me look at the date here. Okay. March.
MR. REINHART: The question is, do you remember making the call?
THE WITNESS: Okay, let me. "Person for the car will be here in 15 minutes to drop off foam and papers." I don't know.
BY MR. EDWARDS:
Q. That doesn't mean anything to you?
A. That doesn't -- I mean, you're talking four years ago. I can't answer that accurately. I mean...
MR. REINHART: So the answer is you don't recall?
THE WITNESS: Yeah, I don't recall.
BY MR. EDWARDS:
Q. If you don't remember, that's fine.
(Plaintiff's Exhibit Nos. 2 AND 3 were marked for identification.)
BY MR. EDWARDS:
Q. So I'll show you Exhibit 3, the same type of document, and I can make the representation that this was message pads provided by the state attorney's office relative to the criminal investigation revolving around
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Jeffrey Epstein. So that's how I have these documents.
I'm not trying to pull out old documents.
MR. CRITTON: What's the date?
MR. EDWARDS: March 19th.
MR. REINHART: The question is, do you remember the call?
THE WITNESS: "Tom from Midnight Express is at" -- help me out -- "convention center with new boat. They are two points -- two parts of this."
BY MR. EDWARDS:
Q. "Show"?
A. "Show up the water" --
MR. REINHART: "On the water."
THE WITNESS: "On the water and at the center."
BY MR. EDWARDS:
Q. Do you remember making that call?
A. No. I mean, "Tom from Midnight Express is at convention center with new boat. They are two parts of" -- I mean --
Q. But as Jeffrey Epstein's pilot, why would you be leaving such a message about Tom from Midnight Express relative to boats and a boat show?
A. I help out with boat purchases or, you know, anything to do with, you know, that moves. So I mean,
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Q. Okay. When you say "you help out with boat purchases," what do you mean?
A. Give my opinion, whether or not whether to buy a certain boat. It's just a hobby. I have knowledge on boats. Not only just airplanes but, you know.
Q. You give your opinion to whom?
A. To Jeffrey.
Q. Okay. And Jeffrey Epstein obviously, at least in your mind, you believe he wants your opinion?
A. Yes.
Q. Okay. So boats is another thing that the two of you have discussed?
A. Yes.
Q. All right. And so this a conversation or at least some evidence that a conversation existed between yourself and Jeffrey Epstein relative to a boat or a boat show?
A. Correct.
Q. Do you remember having that conversation?
A. We've had many conversations about boats and different boat shows. If you're referring to this one in '05, I don't recall this one.
Q. Okay. So aside from being a pilot -- which throughout this entire deposition I believe your
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testimony has been, you know, you're just the pilot for him -- it looks like there's some other role that you're playing here in his life. I'm not suggesting that you are or you are not. I'm just saying from the appearance of this, it looks that way. Is there anything else that you want to tell me or that you want to clarify in terms of the role that you play in Jeffrey Epstein's life outside of being just his pilot?
MR. REINHART: Let me object to form. He also told you he installs the audio and video equipment before.
MR. EDWARDS: Correct.
THE WITNESS: I have an interest in boats. You know, with the island, I don't think I bought any boats, you know, for the company, but he appreciates my opinion on boat purchases.
BY MR. EDWARDS:
Q. Okay.
A. Having the knowledge of aviation and things that move quite fast. So I have consulted with him on boat items.
Q. How many boat purchases are you aware of Jeffrey Epstein making in the time period that you've known him?
A. Two or three.
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Q. And has he consulted with you on each of those purchases?
A. Not every one of them, no.
Q. Does he own any boats now that you're aware of?
A. I don't know if he owns them or not.
Q. Okay. Do you know of any boats that he controls or maintains?
A. Himself or?
Q. How about this -- I'll ask you this way. I don't want to split hairs with you here: I know we've been talking about corporations and things like that.
A. Yes he.
Q. Do you know of any boats that he is the person with the most control over?
A. Yes.
Q. Okay. Where would those boats be located and what kind of boat are we talking about?
A. St. Thomas is the location. It would be a 34-foot inflatable boat. I know that one specifically.
Q. Okay. Do you know when he made that purchase?
A. Eight years ago, seven years ago. It was a while ago.
Q. Is that something you had had input in?
A. Not on that one specifically, no.
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Q. Is there any other boat that you know of Jeffrey Epstein being the primary user of or the primary controller of?
A. I mean, there's boats in St. Thomas. I mean, it's not part of my job, you know, what goes on with the boats or who controlled them. It's more of an opinion of what horsepower should be on the back of the boat, hull designs. It's out of my area.
Q. But your sole responsibility or your sole obligation that you have ever had with Jeffrey Epstein relative to boats is just giving some opinions about the boat?
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Q. In the 18 years and all the travels you had with him, do you know anything about Jeffrey Epstein's sex life?
A. No.
Q. Do you know who he has sex with?
A. No.
Q. Do you know if he has sex with anybody?
A. I don't know.
Q. Do you know if he's ever had sex on the airplane while you've been piloting it?
A. I have no idea.
Q. That's something that you just wouldn't know because you're up in the cockpit?
A. That is correct.
THE WITNESS: Could I take a two-minute bathroom break just to lose my coffee?
MR. EDWARDS: Sure.
(A break was had at 12:35 p.m.)
BY MR. EDWARDS:
Q. All right. We're back on the record. Over the years you've indicated that the -- any gifts or other items or things given to you by Jeffrey Epstein exclusively are the pool heater, the 40-acres of land and the --
A. Use of a company --
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Q. -- and the use of a company car?
A. Yes.
Q. That's it?
A. (Nodding.)
Q. Okay.
A. Yes, I'm sorry, yes.
Q. And the flight to Miami that was recently taken, other than Jeffrey Epstein and , was there anybody else on that flight?
A. No.
Q. How long -- did you also fly them back from Miami to Palm Beach?
A. No. He drove back.
Q. When you say "he drove back," who drove back?
A. Well, I assume he drove back. I did not fly him back.
Q. When's the next time you saw him again?
A. I would only be guessing. A week later, I mean.
Q. Okay. And was that in Palm Beach County when you saw him the next time?
A. Yes, sir.
Q. Do you know of him leaving Palm Beach County in the last two years on any other occasion?
A. No.
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Q. Did he ever fly anywhere else with you either by helicopter or airplane in the last two years?
A. We flew one time to the Sikorsky plant.
Q. What's the Sikorsky plant?
A. That's where they build the Sikorsky helicopters. It's in Palm Beach County.
Q. And when was that?
A. Probably a month ago, I'm guessing.
Q. For what purpose?
A. They gave us a tour at a facility.
Q. Who's they?
A. Sikorsky.
Q. And who requested the tour of the facility?
A. They offered it to our flight department.
Q. And who went?
A. Jeffrey, myself, and Igor.
Q. And if I wanted documentation of either of those trips, the trip to Miami or the trip to the Sikorsky plant, who would have that documentation?
A. I would.
Q. So I could request it from your attorney to get it from you?
MR. REINHART: Let me just check.
(Off the record discussion.)
MR. REINHART: Okay. He has custody of it,
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but they're corporate documents. So you'd have to request it from Mr. Critton, who I understand represents all the corporations.
THE WITNESS: Yes.
BY MR. EDWARDS:
Q. What's the corporation that the document was prepared for?
A. Meaning who -- what, like Air Ghislaine, the owner of the helicopter? Yes, Air Ghislaine.
Q. Air Ghislaine?
A. That's the helicopter.
Q. And the name Ghislaine is obviously not that typical of a name. Is that reference or related to Ghislaine Maxwell?
A. I would assume. I have no knowledge.
Q. Nobody's ever told you that?
A. Nobody's brought it up.
Q. Okay. And how long were you at the Sikorsky facility?
A. Three hours, four hours.
Q. And what time of day was this?
A. Nine in the morning. Nine, I think, and we returned at one, something like that.
Q. And was the purpose to buy or purchase anything?
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A. They have a new helicopter being developed there, so they're trying to look for investors in it. So they were just kind of pushing their product.
Q. Do you know what Jeffrey Epstein does for a living for business today, these days?
A. No.
Q. Do you know or have you ever been to the Florida Science Foundation?
A. Yes, sir.
Q. And do you know what the Florida Science Foundation does?
A. Not exactly.
Q. Well, generally?
A. No, I don't. I mean, really, I don't.
Q. Okay. Is it your understanding that Jeffrey Epstein is somehow affiliated with the Florida Science Foundation?
A. It's my understanding that, yes.
Q. I mean, did you just by happenstance stumble into the Florida Science Foundation, or was it related to your relationship with Jeffrey Epstein?
A. I've heard that's where his office was. I mean, I have no other --
Q. Why did you go there?
A. Talk about airplanes.
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Q. Talk to who?
A. Jeffrey.
Q. Jeffrey just happened to be at the Florida Science Foundation?
A. Yes.
Q. How did you know that he was going to be at the Florida Science Foundation?
A. He called me and told me.
Q. And he said come to the Florida Science Foundation to talk to me about what?
A. Maintenance on the airplanes, upcoming. It's an ongoing.
Q. And did he have an office there?
A. Yes.
Q. So this is -- when you walked in, this is the place that's right next to Jack Goldberger's office?
MR. CRITTON: Form.
THE WITNESS: Yes.
BY MR. EDWARDS:
Q. And you walk in and there's a reception desk right there?
A. Yes.
Q. Is that where you talked or did you talk somewhere behind that reception desk?
A. Behind the reception area.
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Q. Back in his office?
A. Yes, sir.
Q. What was that conversation?
A. Give me a time frame. I mean, I've been there several times.
Q. Okay. How many times do you think you've been to the Florida Science Foundation?
A. Twenty, thirty. I mean...
Q. Well, the Florida Science Foundation's only been around since late 2007; is that right?
MR. CRITTON: Form.
BY MR. EDWARDS:
Q. Something around that?
A. I don't know exactly.
Q. All right. So in the last 20 years -- in the last couple of years you've been there 20 or 30 times, approximately?
A. Yes, sir.
Q. And during those times when you've been there, without having to go through each conversation, did you ever talk to him about the fact that he was on probation or that he was --
A. No.
Q. -- any part of the criminal investigation?
A. No, not at all.
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Q. What was the purpose of the conversation?
A. We were sometimes talking about TVs, you know, the latest plasma that's out there, LCD, you know, setting up a stereo systems, you know, in the Palm Beach house. That's usually the main thrust of our conversations these days.
Q. How would you know to go to the Florida Science Foundation on each of those occasions? Would he just call you?
A. Yeah, he would call me and say come on by or I got a brochure on a new Samsung.
Q. With each time you were at the Florida Science Foundation, how long would you stay typically?
A. Ten, fifteen minutes. Not much more than that.
Q. You would go there for ten or fifteen minutes, have a conversation about a TV and leave?
A. Yes, sir.
Q. Why couldn't you have that conversation over the phone? What was it about?
MR. CRITTON: Form.
THE WITNESS: If it was pertaining to a TV and I'd have a brochure, a picture of the TV -- one particular TV we looked at it was the size of a -- like five foot diagonal, so I had a photo of myself
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standing next to it or the salesperson. So I mean, there's a reason to visually show him something reference to that.
BY MR. EDWARDS:
Q. Did you ever communicate with Jeffrey Epstein -- you can send him an e-mail, right? You could have done that?
A. Yes.
Q. To send him the picture or something like that, that was an option?
A. Right.
Q. And what's Jeffrey Epstein's e-mail address that you use?
A. I have to do it on my computer, you know, with -- I have to type in the prompts for it because it's a long e-mail address.
Q. Okay. How long have you e-mail corresponded with Jeffrey Epstein?
A. Probably two years. A year to two years. I mean, it's fairly -- something we just started doing. I mean, we'd never done that in the past.
Q. Well, in the past he was in jail or have some restrictions?
A. The restrictions, yes.
Q. So you you'd see him on the airplane
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frequently?
A. Exactly.
Q. So when you didn't see him on the airplane frequently, then some of your correspondence was by e-mail, other times by telephone?
A. Mm-hmm.
Q. And other times in person?
A. Yes.
Q. And what was your e-mail -- what was the substance of the e-mail correspondence that you would have with Jeffrey Epstein?
A. It would have to be related. I mean, you have to give me a topic. I mean, whether it be a car --
Q. Never about the criminal investigation?
A. Oh, no, no, never.
Q. Do you know what his intention is or his plans are for when he is off probation?
A. No idea.
Q. Or off community control?
A. I have no idea.
Q. Has he ever indicated to you he wants you to fly him to some other location outside the United States to live permanently?
A. Oh, no.
Q. Have you ever flown to his place in Paris?
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A. We've landed in Paris.
Q. You're aware that he has some control over another piece of property over there?
A. I know we've picked up luggage at a residence. I don't know to what extent his ownership is, if any.
Q. All right.
A. Right.
Q. And are you aware that he has some employees that listen to what he says that work in that house?
MR. CRITTON: Form.
THE WITNESS: In Paris, yes, there is one person there.
BY MR. EDWARDS:
Q. What's his name?
A. Voltzan. Because I always thought there was nobody there.
Q. Vultzan Cauldron (phonetic)?
A. I don't know exactly. I would have to look it up.
Q. Have you talked to him before?
A. No.
Q. When you've been in Paris --
A. You're not going to ask why?
Q. Well, I'm assuming he doesn't speak English.
A. There you go, okay.
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Q. So I thought there was no need for that?
A. Okay. I just wanted to see.
Q. Where do you stay when Jeffrey Epstein is in Paris?
A. A hotel.
Q. Okay. And in New Mexico, when you land there, you stay on the ranch somewhere, but at your place?
A. I stay at my place.
Q. And in New York, you have an apartment that he sets you up at, right, the 301?
A. Yes, I have a place I could stay.
Q. And in St. Thomas?
A. Hotel.
Q. And in Paris you stay at a home?
A. (Nodding.)
Q. Are there any other properties such as what we were talking about today -- I'm not saying Jeffrey Epstein is the sole owner or direct owner, but any other properties that you're familiar with that Jeffrey Epstein is -- has direct access to and at least it gives the appearance to you that he is the owner or controller of that property?
MR. CRITTON: Form.
THE WITNESS: Name the list that you've stated.
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BY MR. EDWARDS:
Q. The Manhattan house.
A. Yes.
Q. Mansion or whatever we want to call it, the Zorro Ranch, the island of St. James, the Palm Beach house.
A. Mm-hmm.
Q. And the Paris place.
A. That's all I'm aware of.
Q. And have you ever at any of those five places hung around him and stayed around him for -- during the daytime for the course of an entire day?
A. No.
Q. All right. So do you know what he does during his days while he's there?
A. No.
Q. Are you aware of a list of underage girls that is kept to come over and service him each of those days?
MR. CRITTON: Form.
THE WITNESS: Absolutely not.
BY MR. EDWARDS:
Q. I'm the first person to ever even imply that to you, right?
A. A list, yes, you are.
Q. Okay. Have you ever been made aware that
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keeps a list of underage girls to service Jeffrey Epstein for sexual purposes?
A. I am not aware of them.
MR. CRITTON: Form to the last question.
BY MR. EDWARDS:
Q. Have you ever been made aware that Ghislaine Maxwell keeps a list of girls in the nearby areas of each of -- at Jeffrey Epstein's residences to service him sexually?
A. No.
MR. CRITTON: Form.
BY MR. EDWARDS:
Q. Okay. Have you ever read some of the complaints that have been filed against him in the various courts, whether state court or federal court, against Jeffrey Epstein?
A. No, I have not.
Q. All right. So this Jane Doe 102 versus Jeffrey Epstein, you're not familiar with who that person is?
A. No idea.
Q. Okay. I'm going to mark Jane Doe, one of the 22, versus Epstein as Exhibit No. 4 to this deposition.
(Plaintiff's Exhibit No. 4 was marked for identification.)
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BY MR. EDWARDS:
Q. And ask you about some of the allegations in here and see if you know anything about them. It indicates he owns a flight of aircraft that includes a Gulfstream, a helicopter, and a Boeing 727. True?
MR. CRITTON: What's the question?
THE WITNESS: Please repeat.
BY MR. EDWARDS:
Q. Are you aware of him owning a Gulfstream IV aircraft, a helicopter and a Boeing 727? I think we talked about it, right?
A. Right.
Q. Okay. And it indicates a fleet of motor vehicles?
MR. CRITTON: Wait a minute. He said right, is that we talked about it, as distinct from him knowing one way or another.
THE WITNESS: What's the question?
BY MR. EDWARDS:
Q. Do you know that he owns those things?
A. I do not know that he owns them.
Q. Do you believe that he owns those things?
MR. CRITTON: Form.
THE WITNESS: I would be guessing, so...
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BY MR. EDWARDS:
Q. What does the company NES, LLC, do to your knowledge?
A. I have no idea.
Q. How does that company generate profit, if you know?
A. I have no idea.
Q. That's the company that pays your paycheck, but you have absolutely no clue what they do to generate money?
A. No, sir.
Q. If anything?
A. Correct.
Q. Have you ever heard that that company generates money through sex trafficking of young girls?
MR. CRITTON: Form.
THE WITNESS: Absolutely not.
BY MR. EDWARDS:
Q. Never, okay. Have you ever heard that Jeffrey Epstein has a sexual preference for underage girls?
Other than what you've read in the newspaper, have you heard that from any other individuals before?
A. No.
Q. Ever heard that he has had sex or sexual relationships with many minor girls, some as young as 12
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years old?
MR. CRITTON: Form.
THE WITNESS: No.
BY MR. EDWARDS:
Q. Never?
A. Never.
Q. Have you ever seen any photographs in any of his homes depicting young-looking girls engaging in sex acts?
A. No.
Q. Or reading directly from the complaint, "engaged in lewd acts"?
A. No, absolutely not.
Q. Have you looked around the walls of his various homes when you're in there picking up luggage?
A. I mean, not any more than I walked in here and not looking at the walls over there, I couldn't tell you what those are; so nothing specific.
Q. Sometimes we're talking about a 50,000 square foot house?
A. Exactly.
Q. In Manhattan?
A. It's pretty big.
Q. Okay. Have you ever looked at any of his computers for any reason?
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A. No.
Q. I know that you helped set up some of the --
A. Computers are not my expertise.
Q. All right. Have you ever been told that
Mr. Epstein committed sex acts against underage girls on a literal daily basis, that's what he does?
A. I've never been told that.
Q. Have you ever read the complaints against him that indicate that's what he does on a daily basis?
MR. CRITTON: Form.
THE WITNESS: No.
BY MR. EDWARDS:
Q. So in your mind, you never believed that you were transporting around somebody whose sole goal in life is to get -- have sex with little girls?
MR. CRITTON: Form.
THE WITNESS: I never believed that, no.
BY MR. EDWARDS:
Q. Okay. Have you ever been told that he conspired with others, including assistants and/or his drivers and/or pilots and his friend Ghislaine Maxwell, to further these sex acts and to avoid police detection?
MR. CRITTON: Form.
BY MR. EDWARDS:
Q. Have you ever -- anybody ever questioned you
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about that?
MR. REINHART: Hold on. The question is have you ever been told that fact that he just read to you?
BY MR. EDWARDS:
Q. Right.
A. I have never been told that fact.
Q. Has anybody ever questioned you about your possible involvement with helping to facilitate Mr. Epstein have sex with underage girls?
A. No.
Q. When you were questioned by either the police or the -- whoever the investigative resource that was being used at the time?
A. Right.
Q. Do you remember who that person was that was questioning you?
A. No, I don't remember.
Q. I know you don't know the location where it was, but do you remember who they were affiliated with?
A. No.
Q. Was it only one time?
A. Yes.
Q. Did you also have to testify before a grand jury proceeding?
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A. No, I did not.
Q. Have you ever known Mr. Epstein to get a massage while on an airplane?
PHONE ATTORNEY: This is everybody in Boone, Charles and the witness is here and the court reporter and the videographer.
MR. EDWARDS: Fantastic, but I think that you may have the wrong room.
PHONE ATTORNEY: I was told to ask for 856.
MR. EDWARDS: Let's go off the record.
(Off the record discussion.)
BY MR. EDWARDS:
Q. All right. In the complaint, I'm going to tell you what it alleges and I'm going to ask if this helps to refresh your recollection about any of Jeffrey Epstein's activities. The defendant, Jeffrey Epstein, transported the plaintiff to another state in order to engage in sex acts with her. And this occurred when she was merely 15 years old.
Do you remember transporting somebody that looked like they were 15 years old on your airplane?
A. No, sir.
Q. You never remember taking a 15-year-old, or somebody that looks around that approximate age, on your airplane?
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A. Can you be more specific?
Q. Well, I know that you've indicated earlier in the deposition that you remember some girls under the age of 18 on the airplane. And so let me ask, before I get back into this, whether all those individuals you were talking about were accompanied by a parent or some of those people were on the airplane for some other purpose, modeling, or you don't know why they were there? I'm going to let you elaborate on who these people are that you believe may have been under the age of 18 and why you think they were on the airplane?
MR. CRITTON: Form.
THE WITNESS: We've had younger people on the airplane that have been, you know, with their family members, like you said. I don't remember transporting anybody that was of questionable age. I'm not -- I'd only be guessing at somebody's age if I didn't ID them at the foot of the airplane.
So I can't guess to their age.
BY MR. EDWARDS:
Q. All right. "Mr. Epstein used his private jet to transport the minor plaintiff to Manhattan where he provided her spending money and accommodations with him at his mansion."
Do you have any idea who that might be
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referring to?
MR. CRITTON: Form.
THE WITNESS: No, sir.
BY MR. EDWARDS:
Q. And you don't remember being a pilot of an airplane where he was transporting a 15-year-old to Manhattan from Miami or Palm Beach?
A. No. I'd be guessing at somebody's age and I can't guess.
Q. "Defendant transported plaintiff in his private jet to locations that included Palm Beach, New York City, Santa Fe, Los Angeles, San Francisco, St. Louis."
Do you remember ever piloting his airplane to those destinations that I just mentioned?
MR. REINHART: Can we break them down?
Objection; compound.
MR. EDWARDS: Okay.
BY MR. EDWARDS:
Q. Have you ever flown his airplane to Palm Beach?
A. Yes, sir.
Q. Okay. Have you ever flown it to New York City?
A. Yes.
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Q. To Santa Fe?
A. Yes.
Q. To Los Angeles?
A. Yes.
Q. To San Francisco?
A. Yes.
Q. To St. Louis?
A. Yes.
Q. All right. Continuing to international destinations, including Europe, have you ever flown it to Europe?
A. Yes.
Q. The Caribbean?
A. Yes.
Q. And Africa?
A. Yes.
Q. On those flights to those various places, is it your -- to the best of your knowledge, you were unaware of Jeffrey Epstein engaging in sex with underage girls on his airplane?
MR. CRITTON: Form.
THE WITNESS: I have no knowledge of any of that.
BY MR. EDWARDS:
Q. "He provided accommodations with him in order
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to have her available to him at all times whenever he wanted, including while transporting the minor plaintiff on his private jet."
That's something that you had no knowledge of?
A. (Witness shakes head.)
Q. You have to a yes or no.
A. I'm sorry, no.
Q. "Each time they would travel to one of these destinations, the same pattern of sexual abuse would occur, often with a vast array of aspiring models, actresses, celebrities, and/or other females, including minors from all over the world."
Again, that's something you have no personal knowledge of?
A. No.
Q. Has anybody ever indicated that if you did have personal knowledge of some of these things, then you could also have been implicated in some form of a crime? Has any law enforcement or anybody ever indicated that to you?
A. No.
Q. Okay. Is that something you've ever worried about?
A. No.
Q. All right. "Upon information and belief,
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defendant transported minor girls from Turkey." Did you ever leave in one of his airplanes out of Turkey?
A. I'd have to look at the records. I don't recall Turkey.
Q. Do you ever remember taking any minor girls out of Turkey?
A. No, I don't remember.
Q. What records would you have to look at to see if you took people out or left out of Turkey?
A. I'd have to look at the flight logs, but I personally don't remember flying into Turkey.
Q. And would the flight logs coming into the United States from Turkey indicate the names of the people on the plane?
A. They might.
Q. Okay. Where would I get those particular flight logs that would have that information?
A. Depended upon what year you're talking.
Q. We're talking in this particular complaint between 1998 and 2002.
A. I'm not -- I don't possess those passenger manifests.
Q. Do you know who would possess those?
A. That would be I guess --
MR. REINHART: Do you know who has them today?
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THE WITNESS: I do not know who has them today.
BY MR. EDWARDS:
Q. Who did you give them to?
A. Actually, I didn't give them to anybody. Dave Rogers was in possession of those logs. So I don't know where they are right now.
Q. You're still thinking that the best evidence of that, any flight that may have left out of Turkey, would be in the flight logs that's marked as Composite Exhibit 1, or are we talking about the manifests that we've been referring to?
A. I don't know how accurate that log book is or even how accurate the passenger manifest is.
Q. Okay. So there may be no actual documentation indicating a flight leaving out of Turkey when, in fact, a flight may have left out of Turkey?
A. Correct.
Q. Okay. The Czech Republic is the next place listed. Is that a place you've flown to or from in a Jeffrey Epstein airplane?
A. More specific, could you name the city?
Q. I can't name the city, at least the complaint doesn't name the city. But I've been to the Czech Republic before. Anywhere within that country, have you
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ever flown to or from in a Jeffrey Epstein airplane?
A. We have flown to Prague.
Q. Okay. Have you picked people up in Prague and flown out of Prague?
A. I don't remember.
Q. I'm not saying no, you didn't, but --
A. Best of my knowledge.
Q. -- you don't remember?
A. Exactly. Best of my knowledge, I don't remember.
Q. Do you remember the reason for going to Turkey or to Prague?
A. No.
Q. This also says Asia. Have you ever flown to or from Asia with Jeffrey Epstein?
A. Yes.
Q. Or on a Jeffrey Epstein airplane?
A. Yes.
Q. Do you know the purpose of those flights to and from Asia?
A. No.
Q. Did it ever occur to you that maybe it was to pick up minor girls for him to have sex with on the back of the airplane?
MR. CRITTON: Form.
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THE WITNESS: Never occurred to me.
BY MR. EDWARDS:
Q. Did you ever hear that he maintained some of these underage girls as sex slaves --
A. Never heard of such a thing.
Q. -- from the age of 12 through the age of 16?
MR. CRITTON: Form.
THE WITNESS: No knowledge of that.
BY MR. EDWARDS:
Q. Ever picked up girls that looked young, many of whom who spoke no English? Do you ever remember that?
A. Zero, do not.
Q. All right. The complaint goes on to say, "Plaintiff was required to be sexually exploited by defendant's adult male peers, including royalty." So I'm going to talk, do you have any familiarity with Prince Andrew?
A. I know who he is.
Q. Was he ever on the airplane?
A. He may have been on the airplane.
Q. Do you remember him on the airplane with young girls?
A. No, I do not.
Q. Do you remember Jeffrey Epstein flying in to
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meet with Prince Andrew?
A. I don't remember. I know that happened, but I couldn't be accurate.
Q. Has Prince Andrew ever been on the airplane at the same time as a young girl, to the best of your memory and knowledge?
A. To the best of my knowledge, no.
Q. This also says politicians, talking about local or U.S. politicians. Do you remember certain politicians being on the airplane?
A. No -- I mean yes, I do.
Q. What politicians would that be?
A. President Clinton.
Q. Okay. Who else?
A. Former president of Israel -- help me out with the name, Barak?
Q. Ehud Barak?
A. Yes, those are the two that I remember.
Q. How many times was Ehud Barak on the airplane that you piloted for Mr. Epstein?
A. Maybe once.
Q. And where did that flight pick up and where did it go to, to the best of your memory?
A. Best of my memory, it was Palm Beach to Teterboro.
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Q. Where is Teterboro?
A. In New Jersey.
Q. And what was the purpose of that flight, do you know?
A. I don't know.
Q. Was Jeffrey Epstein on the flight?
A. I'd have to look at the flight logs to guarantee.
Q. Anything about that flight stick out in your mind?
A. None.
Q. Such as a fine needing to be paid because it left after 10:00 p.m.?
A. For that was the flight, yes.
Q. You remember that?
A. It's coming back to me.
Q. And do you remember young girls being on that flight?
A. No.
Q. All right.
A. I remember the fine.
Q. Do you remember who paid the fine?
MR. CRITTON: Hold on. Let me object to form of the question. "Do you remember" it suggests that there were. So form, predicate.
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BY MR. EDWARDS:
Q. Okay. Do you remember who else was on that flight that left after 10 p.m.?
A. No, I do not.
Q. Do you remember why it left after 10 p.m.?
A. No, I do not.
Q. Do you remember Jeffrey Epstein instructing you to wait until after 10 p.m. to leave?
A. No.
Q. Would you have listened to him if he had told you -- if he had instructed you to do that?
A. I don't understand the question.
Q. Well, if he told you wait until after 10 p.m., I realize there's going to be a fine, but wait until after 10 p.m. to leave, intentionally leaving after 10 p.m., do you remember that instruction ever --
A. No, I don't remember that instruction.
Q. Okay.
A. I mean, it just happened to be departing after 10 and there is a penalty for leaving after 10 for noise. So there was no intention to...
Q. All right. This also talks about this particular person 15 years old being sexually exploited by businessmen and/or other professional or personal acquaintances. Are you aware of other personal or
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professional acquaintances of Jeffrey Epstein also sexually abusing or exploiting little kids or underage girls on your airplane?
MR. CRITTON: Form.
THE WITNESS: No.
BY MR. EDWARDS:
Q. If you had been aware that Mr. Epstein was -- and by this -- this is more in the form of a hypothetical, and that I'm not going to suggest to you it's a fact that he was. But if you had been aware that every single day Jeffrey Epstein's goal was to locate underage girls for the purposes of sex, and either have sex with them on the airplane or at some other designation that you were destination that you were traveling him to, would you have continued to pilot those planes?
MR. CRITTON: Form.
THE WITNESS: You said it was hypothetical?
BY MR. EDWARDS:
Q. Right, it is a hypothetical.
A. Why would I want to answer that? Because you're being hypothetical. I mean, it would obviously be wrong.
Q. Sure. Well, a hypothetical question is a legal question that I'm allowed to ask.
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A. Okay.
Q. And I'm just asking you if you did have knowledge that Jeffrey Epstein was having sex with little girls either on the plane or at a place that you were taking him to or from on a daily basis, that's what he did, would you have continued to be his pilot?
MR. CRITTON: Let me object. Object to the form. It's argumentative. It has no more value than assuming he was chopping up bodies or anybody was chopping up bodies in the plane you're flying. What difference does it make? Form.
MR. EDWARDS: What difference does it make in a case about him having sex with little girls? I'm not going to argue with you about it. You've stated your objection.
MR. CRITTON: Exactly. It's an argumentative question.
MR. EDWARDS: I'm not going to argue with you about it.
MR. CRITTON: You're arguing with him about now.
MR. EDWARDS: No, I'm asking him the hypothetical.
BY MR. EDWARDS:
Q. Can you answer that? Would you have continued
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to be a pilot for somebody who's traveling to and from destinations with the goal of having sex with underage girls?
MR. CRITTON: Form.
THE WITNESS: It could be any person. It doesn't have to be Jeffrey Epstein, then, right?
BY MR. EDWARDS:
Q. True.
A. No, I wouldn't pilot an airplane if there was wrongdoing going on.
Q. That you knew about?
A. That I knew you about, sure.
Q. Me reading this complaint to you, is this the first time you've heard these allegations --
A. Yes.
Q. -- against Mr. Epstein?
A. Yes.
Q. It goes on to say, "On one of Epstein's birthdays, a friend of Epstein sent him three 12-year-old girls from France who spoke no English for the purpose of -- for defendant to sexually exploit and abuse. After doing so, they were sent back to France the next day."
Are you familiar with that occasion?
MR. CRITTON: Form.
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THE WITNESS: Never heard of such a thing.
BY MR. EDWARDS:
Q. Do you know of any friends that he has in France that would send him birthday -- a birthday present?
A. No.
Q. Do you know of him receiving any birthday gifts or birthday people from anyone?
A. Never.
Q. This particular person that filed this complaint, Jane Doe 102, indicates "Defendant and Ghislaine Maxwell acknowledged and celebrated plaintiff's 16th birthday."
Do you remember them celebrating somebody who you flew on the airplane's 16th birthday?
A. I don't recall.
Q. Any of this jog your memory as to who is?
A. No.
Q. "From the age of 15, plaintiff" -- this Jane Doe 102 -- "was sexually exploited and abused by defendant on a daily basis and often multiple times each day."
So going back, was there ever a day where you were with Jeffrey Epstein where you could observe him
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and during an entire day?
MR. CRITTON: Form.
THE WITNESS: I don't remember
so I couldn't answer the question.
BY MR. EDWARDS:
Q. "In September 2002, Defendant Epstein purchased a commercial round-trip airline ticket and provided a passport, U.S. currency and accommodations for plaintiff to fly to Thailand."
Do you remember him doing that for anybody around that time period?
A. No, sir.
MR. CRITTON: What was the date?
MR. EDWARDS: September 2002.
MR. CRITTON: Okay, thanks.
MR. EDWARDS: I have here -- and this is actually my only copy, so I don't mind marking it as a composite exhibit, but we'll either have to copy this while thing or we'll have an agreement of counsel. It's the visitor inmate log from when Mr. Epstein was in jail in Palm Beach.
MR. CRITTON: Well, before we get started, it is now 1:15. We started at 10:00.
MR. EDWARDS: We didn't really start at 10:00.
MR. CRITTON: Shortly thereafter. I was here
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pretty much after 10. But we've been here since
10:00. I want to take a lunch break.
MR. EDWARDS: Let's do it.
MR. CRITTON: For an hour?
MR. EDWARDS: Sure.
(A break was had at 1:15 p.m.)
BY MR. EDWARDS:
Q. All right. I looked through the inmate log of the visitors who visited Jeffrey Epstein and your name appears one, two, three, four, five, six, seven, eight times.
A. Okay.
Q. Seem to be accurate in terms of how many times you went to visit him?
A. I thought six, but yes, that's...
Q. I'll let you review the records and tell me if you dispute any of that record. And I'll go ahead and mark that as Composite Exhibit 5.
(Plaintiff's Exhibit No. 5 was marked for identification.)
MR. REINHART: It's two pages.
MR. EDWARDS: Two pages.
MR. REINHART: Okay.
BY MR. EDWARDS:
Q. Seem accurate?
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A. Yes.
Q. Okay. Jeffrey Epstein's plea, I believe, was June 30th, 2008. I think that's when he was taken in custody from there. Your first visit is July 3rd, 2008. And the other name on that visit is Igor Zinoviev. Did you go with Igor to visit Jeffrey Epstein?
A. Yes.
Q. Why did you go with Igor?
A. It just happened he wanted to see us both at the same time. There was no apparent reason.
Q. How did you know that Jeffrey wanted to see you?
A. I don't recall who called and told me that he wanted to see me. I couldn't give you an accurate name, whether it was, you know, his attorney, Darren. And actually, I would put a lot weight to I think it was Darren, his attorney.
Q. That would have made a phone call to you that said --
A. Yeah, to go.
Q. And what did you talk about with Jeffrey Epstein four days after he pled guilty to offenses that landed him in jail?
A. I think the first visit was how disappointed or how scared he was, you know, being inside there. We
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just talked about general happenings that go on in there.
Q. What did he say?
A. It's terrible; it's cold; he can't sleep.
They wake him up every two hours. You know, just items like that, uncomfortable things. We talked about the airplanes a great deal. You know, we got major maintenance on the big airplane, so we discussed that a little bit. And then it was really just how uncomfortable he was there.
Q. How long did you visit with him on that first visit, July 3rd?
A. I think we stayed the full hour.
Q. All right. Is that what the time allotment was?
A. I believe it is, yeah. I don't think you could leave early, or I'm not aware that you could leave early, until later on we found out you could stay for five minutes or longer. But I don't think any of us knew that was -- once you got in there, you stayed there for the hour.
Q. Okay. So you talked to him for an hour and for the most part it was just about the conditions and his disappointment with the conditions?
A. Sure, yeah, absolutely.
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Q. And did Igor talk to him as well?
A. Briefly. I mean, not that much. You're going back a little ways again to remember exactly what was discussed. You know, he asked how his family was doing. I guess Igor's got a son, I think he asked how his son was doing. You know, just general questions like that.
Q. Did you ride to the jail that day with Igor?
A. I believe we did. I believe I met Igor probably at Jeffrey's house and picked him up, or if not, we may have met at the airport and drove together. But we did drive together on that occasion.
Q. In what vehicle did you drive?
A. The Hummer.
Q. That's the vehicle you described earlier as the company vehicle?
A. Yes, sir.
Q. Is that a vehicle paid for by Jeffrey Epstein?
A. Meaning?
Q. Well, is that a vehicle paid for by you?
A. What do you mean "paid for"?
Q. Did you purchase the vehicle with your money?
A. I didn't purchase that one, no.
Q. Do you know if it was purchased by Jeffrey Epstein or a corporation of Jeffrey Epstein's?
A. Probably a corporation.
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MR. CRITTON: Form; move to strike. Sounds like a guess.
BY MR. EDWARDS:
Q. To the best of your knowledge, that's how most of the items that you've discussed -- that being the Boeing and the Gulfstream -- they were usually held in corporate names, to your knowledge?
A. To my knowledge, exactly, yes.
Q. And so when you're saying the -- when you're talking about the Hummer vehicle and you're stating that it's likely a corporate entity, is that just something that you're guessing about, or do you have knowledge?
A. No, I'm just guessing.
Q. Okay.
A. I have no proof --
Q. -- of ownership of who it's registered to or anything like that?
A. Exactly.
Q. Is it registered to you?
A. No, no.
Q. So it's registered to somebody other than you?
A. Exactly.
Q. Okay.
A. I just drive it, I guess.
Q. Okay. So on July 5th, 2008, you go back to
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see him in jail again, and again, Igor Zinoviev is listed as a visitor. Did you go with him together on that occasion?
A. I didn't even realize it was two days after the first visit.
Q. Well, I mean, you see where this is going?
A. Yeah, I do. It gets further apart, yeah.
Q. Do you remember what the discussion was on 7/5/08?
A. No, because it's probably similar to the first one. I mean, we talked -- actually, one of the visits we talked about fishing and just trying to -- you know, we were talking about things that would just occupy his mind with intelligent conversation that he probably wasn't getting there. So for that hour of the day, I tried to give my best of intelligent conversation to him.
Q. Okay. On his visitor log you were the first one to go visit him. Did you know that?
A. I did not know that. I wasn't aware of that.
MR. CRITTON: Let me just object to form to the last question.
BY MR. EDWARDS:
Q. Well, at least if these records are accurate, which are the records that were provided to us by the
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facility that was holding Jeffrey Epstein, they're accurate, your name is the first one listed on the top of the sheet?
A. Right. There may have been earlier dates. I have no idea.
Q. Well, you know, the first date that he could have been in there it looks like was 7/1/08 and then, you know, so I guess somebody could have seen him 7/1 or 7/2, but those records were never provided to us. You see we were provided a whole big stack.
A. I understand.
Q. The next date I'm going to talk to you about is 7/12/08.
A. Uh-huh.
Q. It looks, again, like it's yourself and Igor Zinoviev?
A. Mm-hmm.
Q. And that's something we talked about in this deposition. I'm going to ask you again, I don't know that you elaborated last time, what is your understanding of his relationship with Jeffrey Epstein? Is that a friend of his?
A. I don't know his job description. I mean, he's somebody that's around a lot, but I don't know his exact job description. His English is, to say, not
167
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100 percent, so conversation with somebody that doesn't fully understand you, you know, you get lost in translation a little bit. So I don't --
Q. So on these three visits to the jail, the first three that we're talking about that we've talked about so far, each of those times you traveled to and from the jail with Igor?
A. Mm-hmm.
Q. Yes?
A. Yes, yes.
Q. And each of those time, is it fair to say you had some form of communication either on the way to the jail or --
A. Sure.
Q. -- to the jail?
A. Yeah.
Q. Since you're going to see an inmate in the jail, is it a safe assumption a portion of that conversation was about the person that you're going to see and possibly the crime that was committed?
A. Yes, that would be a good assumption.
Q. Okay. And what was the form -- what was the substance of that conversation that you can remember related to Jeffrey Epstein and the location you were going to visit him?
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A. I think Igor and I discussed on trying to be upbeat and not look at the position that he's in sitting across the table from us, to be upbeat and uplift his spirits.
Q. Did you and Igor discuss whether or not you were going to talk to him about his plea of guilty or the fact that he's not registered as a sex offender?
A. No.
Q. Or whether you were going to stay away from those topics?
MR. CRITTON: Form.
THE WITNESS: We never -- we don't discuss that amongst ourselves and/or with Jeffrey in any way, form.
BY MR. EDWARDS:
Q. Okay. But that's not -- I realize you didn't discuss that. You've told me that.
A. Right, but we didn't discuss that even prior to going in, as you asked.
Q. Okay. So your discussion was mainly hey, let's be upbeat?
A. Yes.
Q. And that was to, in essence, maintain his spirits or raise his spirits?
A. Exactly.
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Q. Okay. And you were doing that as a friend of his, not just his pilot, right?
A. I felt honored that he asked me to come and give support like that, because prior to him going away, it was known to us that there was going to be no visitors, because I had offered to him that I would be happy to come and visit him if he deemed it necessary, and he says no, I'm not going to have anybody.
Q. So --
A. I guess it was so bad there, that he may have changed his mind and wanted to have some visitors.
Q. When did you have this conversation with him where he indicated he was not going to have visitors while he was in jail?
A. I don't exactly remember. It may have been on the trip heading to Palm Beach, the last flight.
Q. From his island, from St. Thomas I guess it would be from?
A. I forgot where it started from. It might have been New York or the island, one of the two. I don't remember the last flight.
Q. And I mean, did at least the fact come up that hey, this a person who you're -- is going to be in jail for some time?
A. Mm-hmm, yes.
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Q. And in the course of that conversation, again, the allegations and the unusual I'll call it case against him, that didn't come up between you and Mr. Epstein?
A. I never talked about it with him.
Q. And at that point in time, what were you aware of in terms of the number of girls that he was alleged to have had sexual -- some sort of sexual relationship with him at his Palm Beach house?
A. What was the question? How many girls?
Q. Yeah, how many girls were you --
A. Aware of?
Q. -- aware of?
A. None. I wasn't aware of any, to be honest.
Q. The next visit is on 7/17/08 and it's Igor Zinoviev and somebody named Jean Rene and then yourself. Do you know who Jean Rene is?
A. No.
Q. Do you think that that visit, that you visited him at the same time that Jean Rene visited?
MR. CRITTON: What's the date?
MR. EDWARDS: It's 7/17/08.
THE WITNESS: No, I don't know a Jean Rene, unless somebody came after. I mean, I don't -- I don't know a Jean Rene.
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BY MR. EDWARDS:
Q. Okay. And then before you visited him again, the visitors are listed as or?
A. Mm-hmm.
Q. Mainly those two individuals. And they list as addresses, as their residence?
A. Uh-huh.
Q. Given your previous testimony, does that surprise you that they list those -- that address as their residence?
MR. CRITTON: Form.
THE WITNESS: I've seen them there, so I mean, I'm not surprised.
BY MR. EDWARDS:
Q. Okay. Did you know that they were visiting him in jail?
A. No, I didn't know who was scheduled to see him or whatever.
Q. Did Jeffrey talk to you at any point in time about or?
A. No, not at all.
MR. REINHART: Can we get a time frame for that? Ever?
MR. EDWARDS: Oh, no, well, I was talking --
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don't remember which one it was. It was either the 9 or the 16, and then the other one I met everybody there.
So I can't be accurate on which time we all drove together.
Q. How did you coordinate driving together?
A. I don't exactly remember now. I mean, I think and I may have conversed on the phone and said do you want to meet at Jeffrey's house and we all drive together? Does it make sense to get together and drive one car.
Q. Is that jail visit the result of Jeffrey Epstein requesting your presence there, or is that the result of you wanting to go see him as a friend in jail?
A. A combination of both. I'm sure if I said, Hey, I'd like to come to jail and visit you, that he would either say yea or nay.
Q. Okay. And you said at least on one of those occasions you rode to and from the jail with and ?
A. Yes.
Q. And during any of -- obviously, when you're in the car together -- well, who's driving the car?
A. I was driving, I believe.
Q. And that's the Hummer again?
A. Actually, I think we take one of the suburbans
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at the house.
Q. Those are cars that Jeffrey Epstein owns, to your knowledge?
A. I don't know who owns them.
Q. What cars are there that -- I know with this case we're dealing with a lot of corporations and it's not like asking me, Hey, what car do you own? But what cars are you aware that are -- that you believe are used primarily by Jeffrey Epstein?
A. Used primarily by Jeffrey Epstein, a Mercedes S500 sedan. I don't remember the year on that one.
Q. Okay.
A. There's a Cadillac Escalade.
Q. Okay.
A. Those are his two main cars that he would be driven in or --
Q. What are the other cars that you regularly see parked at his Palm Beach mansion, if there are any?
A. It would be a whole array. Half the time the parking lot is full because of construction workers, yards keepers.
Q. Okay. Fair enough. What vehicle does drive or drive when they're down here, if you know?
A. I mean, anybody has a choice to pick out a car
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or whatever there. I've seen driving a Mercedes convertible.
Q. Is that different than the Mercedes S500 sedan?
A. Yes, I think it's different.
Q. When you say they have basically a choice of cars to drive --
A. Well, there's cars in the lot there.
Q. Obviously, they can't get in one of the construction workers' cars?
A. No.
MR. REINHART: Let him finish his question.
BY MR. EDWARDS:
Q. So that's kind of what I'm getting at. What other cars do you think that Jeffrey Epstein has -- whether it's titled, I don't know --
A. Right.
Q. -- but he is the person in control of that vehicle?
A. Right.
Q. What other vehicles do you think he's controlling in Palm Beach?
A. In Palm Beach?
Q. We've named the Mercedes S500 sedan, Cadillac Escalade?
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A. Right.
Q. And I've identified a Mercedes convertible?
A. Right.
Q. In addition to that, are there any others that you're aware of?
A. That he's in control of?
Q. Yes.
A. No.
Q. And does the conversation come up between and yourself about the reason why Jeffrey Epstein is in jail?
MR. REINHART: Can we get a time frame?
MR. EDWARDS: At any time.
BY MR. EDWARDS:
Q. At any time have you ever had that exact conversation ever come up?
A. No, we didn't talk about that among ourselves really.
Q. And have you ever been told that provides the role of a sex slave to Jeffrey Epstein? That's just her role in life?
MR. CRITTON: Form.
MR. REINHART: That's just have you been told that.
THE WITNESS: No.
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BY MR. EDWARDS:
Q. Have you been led to believe that by anybody?
A. No.
MR. CRITTON: Form.
BY MR. EDWARDS:
Q. Do you have any -- based on your observations, do you have any other opinion as to what role she plays in Jeffrey Epstein's life, if any?
A. I don't have an opinion on what the role is.
Q. Do you agree with the criminal statutes that are in place to protect young children from sexual predators? Do you agree with those statutes?
MR. CRITTON: Form.
MR. REINHART: I'm going to direct him not to answer the question. It's irrelevant and it's not likely to lead to discoverable evidence what his opinion is on a law that's been passed by the legislature of Florida.
MR. EDWARDS: Just so the record is clear, I don't know that we did this last time, but it's been alleged in the complaint -- it has been alleged in several complaints that Jeffrey Epstein particularly prays on vulnerable disadvantaged females, underage females, and that in order to gain access to the multitude of underage females,
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he utilizes various people, schedulers, pilots, handlers and other associates and co-conspirators that have a similar mentality; that is, people that do not agree with laws related to sex abuse and abuse of children. And that's why this line of questioning regarding whether or not this witness has a motive or a bias or was involved in conversations related to his motive or bias, to continue to work for Jeffrey Epstein or believed the same beliefs of Jeffrey Epstein, is at least reasonably calculated to the lead the discovery of admissible evidence, and that is the argument at least along those lines being made to the judge regarding these questions.
MR. CRITTON: Can we talk for just one minute? Because maybe -- can I talk with -- well, I know I can talk with Bruce. Let's just take a break.
(A break was had at 2:45 p.m.)
MR. EDWARDS: We're back on the record. Do you have the same position?
MR. REINHART: Let me say this: He previously said he would have never allowed anything on the plane to be done illegally. If you want to ask if he agrees with the law applied by the legislature -- do you agree the law passed by the
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state of Florida should be complied with?
THE WITNESS: I don't know what the law is.
BY MR. EDWARDS:
Q. Okay. The laws in place to protect children under the age of 18 from being sexually touched, fondled, molested by people over the age of 24, do you agree with those laws?
A. Yes.
Q. And you agree that persons who commit a violation of those laws should be prosecuted?
A. Persons that do that.
MR. CRITTON: Form.
BY MR. EDWARDS:
Q. Yes, persons that do that.
A. Persons that do that, absolutely.
Q. And if you were to receive confirmed -- what you would perceive as confirmed information that Jeffrey Epstein was one of those persons, would you continue to be employed by or alongside of Jeffrey Epstein?
MR. CRITTON: Form; speculation.
THE WITNESS: You're assuming that there's guilt.
BY MR. EDWARDS:
Q. No. I'm saying, hypothetically, if you were convinced that Jeffrey Epstein was guilty of those acts
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which he pled guilty to --
MR. CRITTON: Form.
MR. REINHART: Can we -- for purposes of your hypothetical, what facts do you want him to assume are true? You said the facts to which he pled guilty, but the witness already said he doesn't know what he pled guilty to. He knows the charge he doesn't know the facts.
BY MR. EDWARDS:
Q. Solicitation of prostitution of a minor, somebody under the age of 18.
MR. EDWARDS: That's the charge, right, solicitation of prostitution of a minor?
MR. CRITTON: No. I think you've got it wrong. I'll object to the form.
MR. EDWARDS: Okay.
BY MR. EDWARDS:
Q. Then we'll handle the question this way: If you were to believe based on information and evidence that Mr. Epstein engaged in sex or some form of sex acts with people of the age range of 12, 13, 14, 15 years old, would you continue your employment with Mr. Epstein?
MR. CRITTON: Form; speculation.
THE WITNESS: I would certainly be speculating
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and I have to discuss it with my wife long and hard. I don't think I could give you a correct and honest answer at this time.
BY MR. EDWARDS:
Q. Okay. Given the allegations that have been made in this case, is this something that you have discussed with anyone other than your attorney?
A. No, not really. Only from the fact that they're allegations and there's still a lot more work, I'm sure, to be discovered.
MR. CRITTON: Let me put on there, for the -- if this deposition is not typed -- and we request it -- I'd like at least this portion where Mr. Edwards' last question back about five pages worth, so just if you could mark it from this page back about five pages.
If nobody requests the deposition, I'd just like those five pages.
MR. EDWARDS: I'm going to request the deposition, so...
MR. CRITTON: Okay. We'll mark this then, so you could tell me where it is, approximately.
BY MR. EDWARDS:
Q. Is there a reason why you have not discussed with Jeffrey Epstein the allegations that have been made
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against him and the allegations contained within many of these civil complaints on behalf of girls who were under the age of 18? Is there any reason why you haven't discussed that?
MR. REINHART: If that's based on conversations you had with your lawyer, then don't disclose what you and your lawyer talked about.
BY MR. EDWARDS:
Q. Correct.
A. I have not spoken to Jeffrey about any of this, and it was my understanding that is illegal to have conversation about this. So I've never presented any questions to him reference this case or any others.
Q. It was your understanding that it was illegal to talk to Jeffrey Epstein about the allegations made against Jeffrey Epstein?
A. Yes, or anything to do with the case. That's why we never discussed any portions of it.
Q. Okay. So --
A. I may be wrong in that assumption, but I don't --
Q. So the reason why you haven't discussed this with Jeffrey Epstein is you believed it was illegal?
A. Correct, yes.
Q. Who led you to believe that it was illegal?
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MR. REINHART: Again, if it was a discussion you had with any lawyer, then you can just give a name, don't give a discussion of the conversation you had.
THE WITNESS: It was my own assumption. I mean, just basic criminal knowledge of knowing you're not supposed to -- you know, if somebody's in trial or in a deposition or whatever, I don't -- I didn't think it was appropriate to discuss the matter with them.
BY MR. EDWARDS:
Q. Okay. So the next two visits and I think the last two visits we'll talk about are on 9/6/2008.
Actually, it looks like you visited him twice in one day; is that right?
A. I don't think that's possible. I mean, that will show how accurate the court record is. There's no way.
Q. You wouldn't have visited him twice in one day?
A. No. I think there's only one visitation per day.
Q. Okay. And it looks like the same visitors each time, except that it says for period three and then the next one's for period four. So there are two
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different periods. Was there ever a time when they allowed you to stay for more than an hour?
A. No, not to my knowledge.
Q. Okay. So again, it's **and**,
**same questions:** Did you ever ask them their involvement with Jeffrey Epstein?
A. Absolutely not.
Q. And again, what was the discussion with Jeffrey Epstein along with and
## ```markdown
?
A. On the last visits, it was mainly airplane stuff and later on in the visitations, we were advised that you could leave early, so I would only stay for maybe 30 minutes and then, you know, Jeffrey would continue his conversations with them and then I would just wait outside.
Q. Okay.
A. So I would do my business with him talking about airplanes or whatever I had coming up and then exit.
Q. And then why did you stop visiting him in jail after that September 6th, 2008, visit?
A. I was never called back to visit.
Q. Okay. Well, shortly after that then he was on work release?
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A. Well, that's true.
Q. Right?
A. Yeah.
Q. So the next times you would have gone to see him would have been at the Florida Science Foundation, where we talked about earlier?
A. I've seen him there, yes.
Q. Okay. And in fact, I think you said you saw him 20 or 30 times --
A. Sure.
Q. -- over the last two years, last year and a half or so?
A. Yes.
Q. And how long would you stay each time at the Florida Science Foundation and talk to him?
A. Like my original answer, ten, fifteen minutes.
Q. Okay. And how frequently would you talk to Jeffrey Epstein while he was at the Florida Science Foundation?
MR. REINHART: I'm sorry, you're talking in person or all conversations? Because he testified he had phone conversations and personal visits.
BY MR. EDWARDS:
Q. I was actually talking about phone conversations. So when you would call him on the
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telephone, how frequently would you talk to him?
A. How frequently during a given week?
Q. Yeah.
A. More specific?
Q. Sure.
A. Depends upon what's going on that week.
Q. I mean, is it somebody you would talk to him every day?
A. No.
Q. All right. Well, at that point in time, he's going from the jail to the Florida Science Foundation and back, and if you're not going to see him in person, and you're not corresponding by e-mail, then would you correspond by telephone, that either being you call him or he called you?
A. Yes.
Q. And, you know, in any given week, what was the typical week like? I mean --
A. How many times?
Q. Yes.
A. Maybe once in a week, sometimes twice in a day. I mean, it would vary. There was no routine.
Q. And what would the conversation be?
A. Mostly we discussed audio and video, TVs, home theaters. It's a niche of his and we're constantly
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looking at new items that are out there, you know,
what's the biggest LCD flat screen out there.
Q. Okay. And since he's been out of jail and on community control or house arrest or whatever it is,
where he's located at his home now, have you visited him at his home?
A. I have been to the home. I haven't visited,
but I have had work to do there.
Q. And have you called him on the telephone there?
A. Once I think I've called the house. Normally he calls me because it's usually he needs me to do something.
Q. And what have those conversations been about since he's been out of jail?
A. Let's put a stereo in the gym, let's put a TV in the living room, let's put a bigger stereo in the gym, let's put a bigger, bigger stereo in the gym, let's go redo what we've done. It's always audio. He's a very audio file person.
Q. Do you know of any other modifications that he's made to the house at 358 El Brillo since the time that he went into jail?
MR. CRITTON: Form; predicate.
THE WITNESS: Meaning? Be more specific.
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BY MR. EDWARDS:
Q. Structural modifications, architectural modifications?
A. Starting what date?
Q. June 30th, 2008.
MR. REINHART: I think the question on the table was have you observed any structural changes to the house at El Brillo since Mr. Epstein went to jail?
THE WITNESS: Structural changes?
BY MR. EDWARDS:
Q. Structural, architectural, anything like that, changes to the house, to the interior of the house since he went to jail?
A. No. I mean, if you could be more specific. I mean, you're talking furniture or?
Q. I've never been in the house, so I can't be much more specific. Have you noticed any changes from before he went to jail to after he went to jail, the inside of the house, that you could be specific about?
A. No, I can't be specific.
MR. REINHART: Can I talk to Mr. Visoski for a second?
MR. EDWARDS: Sure.
(Off the record discussion.)
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MR. REINHART: I think Mr. Visoski can expand on his previous answer. Why don't you expand.
THE WITNESS: Can we go back to that one?
BY MR. EDWARDS:
Q. Sure. The question dealt with the structural architectural changes you're aware of.
A. There has been a kitchen extension, but when you asked the question, I was unaware of when that actually took place. So to be accurately answering your question, I know there's been a kitchen extension. I don't exactly know when that transpired, but...
Q. How do you know about the extension? How do you know this happened?
A. I knew what the kitchen looked like before and after the extension and I don't -- I thought it was during the hurricane season when they actually did that extension.
Q. Who made you aware of it?
A. Nobody. I just walked in the kitchen and noticed a bigger room than what it was.
Q. All right. Do you know who Martin Nowack is?
A. No.
Q. Do you ever remember him being on your airplane, or that name of somebody being on your airplane?
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A. No, I don't. It's not my airplane.
Q. We still don't know whose airplane it is yet. The time when you took Mr. Epstein to Miami in the last month, do you know which attorney he was going to see?
A. No, I do not.
Q. And do you know whether it was related to civil cases or criminal cases or anything else?
A. No idea.
Q. Do you know where the location was in Miami that he was going to?
A. No, I do not.
Q. Other than yourself visiting Mr. Epstein at the Florida Science Foundation, are you aware of any other visitors, people that visited him?
A. No, I'm not. Just whoever was there during my visit.
Q. Okay. Are you aware of a corporation named the Zorro Trust?
A. I've heard the name.
Q. And is that something that you've heard relative to your involvement with Jeffrey Epstein?
A. Yes. I mean, I don't even remember where I heard Zorro Trust. I have no definition of it, but I know the name is out there.
Q. Okay. Is that a company that you believe is
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affiliated or related to Jeffrey Epstein in some way?
A. I have no definition. I don't know who it is.
Q. Do you know how you heard about it?
A. I don't remember. That's going back in the early days of when Zorro existed.
Q. Who was at the Florida Science Foundation when you would meet with Jeffrey Epstein on these meetings?
A. would be there.
Q. Anybody else?
A. Story would be there on occasion. That's pretty much it.
Q. And would they be in the same room with yourself and Jeffrey Epstein when you had conversations with him?
A. No, not really. Not particularly.
Q. They would just be at the location?
A. Sure, yes.
Q. Anybody else that worked there or was affiliated with the Florida Science Foundation that you know of?
A. Not to my knowledge. I mean, I do my business and get in and get out.
Q. Can anybody other than Jeffrey Epstein have an office at the Florida Science Foundation?
A. Not that I know of.
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Q. All right. And were you deeded the property that we spoke about earlier on the New Mexico ranch? Is that deeded to you?
A. Yes.
Q. And has it been since back in, I think you said 1998 or 1999 or whenever it was?
A. Yes.
Q. Okay. And do you know -- and did you build a house on it then?
A. Yes, I did.
Q. Okay. And that's a property that I think you said you have a mortgage on it, that's a property that you pay -- you mortgaged that property?
A. Yes, sir.
Q. All right. And as well, the home you own here, you have a mortgage on that property as well?
A. That is correct.
Q. All right. Are you familiar with a vehicle, a Chevy Suburban 1500, year 1999?
A. Do you have a color?
Q. No. I can tell you the plate. I could tell you the VIN. Chevy Suburban -- Chevy Suburban 1500, registered to Larry Visoski?
A. That would be mine. That's a white one, then.
Q. Okay. When did you get it?
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A. I'm guessing. It was probably two years old when I got it. Maybe '99. Maybe '01, '02.
Q. Something you still drive?
A. Occasionally. It's kind of a beat up car now, so it's kind of a knock around.
Q. Best of your knowledge, it stays parked at your house?
A. Recently it's been in Jeffrey's driveway, but...
Q. Why?
A. Just for an extra car to use.
Q. For Jeffrey to use?
A. No. I mean, for anybody that would come to the house to help out. Igor I think has driven the car before.
Q. How did it come about that you began to park the Chevy Suburban, the 1999 car that we're talking about, at Jeffrey's house?
A. When there was more activity here in West Palm Beach. We were never usually coming here that often, and now with all this going on, with Jeffrey being in town longer, we needed more cars and transportation. So my car was just sitting in the driveway at home while I was driving the Hummer. So I decided to let them use the Hummer at the house.
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Q. Well, we've just described this wide array of cars that Jeffrey had for people to use --
A. Well, you said for him to use.
MR. CRITTON: Hold it.
BY MR. EDWARDS:
Q. Is there a reason why?
MR. CRITTON: Wait. You guys are both talking over one another. You need to let him wait and finish his question because if I want to assert an objection, neither one of you gives me a chance, which may be the plan. Form.
MR. EDWARDS: Yeah, we have a conspiracy against you.
MR. CRITTON: I knew it. I'll take that as an admission.
BY MR. EDWARDS:
Q. Is there any reason -- did Jeffrey say that he wanted that vehicle to use or to be parked at his house?
A. No.
Q. Then how did it come about that you started parking that vehicle at his home?
A. I think the origination of that came when I started using the Hummer, that the Suburban was parked in my driveway and I wanted to get it out of my driveway as an eyesore. So hence, I decided to let people at the
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house drive it as a grocery shopping car or something, or just as extra transportation.
Q. Okay. But when you go to park the car at somebody else's house, you have to let them know, Hey, I'm giving you the keys?
A. Mm-hmm.
Q. Who did you give the keys to?
A. I don't know if I gave the keys to anybody. I may have just left them on the counter there and told Yanush this is an extra car if you guys needed it to run around because it was an eyesore at my driveway.
Q. Are you familiar with a Mercedes-Benz SUV 1999?
A. Say that again.
Q. Mercedes SUV, 1999 registered in your name?
A. Yes.
Q. And what car is that?
A. That's my car -- my wife's car.
Q. Does that stay at your house?
A. Yes.
Q. And that's the car that's parked at your house now?
A. Yes.
Q. Are you familiar with a Land Rover, Range Rover Sport 2008?
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A. Yes.
Q. Registered in your name?
A. Yes.
Q. And whose car is that?
A. That's another extra car for the household to use at Jeffrey's house.
Q. And when was that car purchased?
A. Last year.
Q. And who purchased that car?
A. It was purchased in my name.
Q. By whom? Who purchased the car in your name?
A. Well, I put the car in my name, but the funds came from -- they were wired to my account from New York.
Q. From whom, though? A mysterious source just sent funds? We know that didn't happen, so I'm just trying to elaborate here.
A. Jeffrey had paid for the car.
Q. Okay. And why did Jeffrey pay for a car and put it in your name?
A. I don't know.
Q. I mean, you had to agree for this to happen. So what was the conversation between you and Jeffrey that resulted in Jeffrey paying for a Land Rover, a 2008 Land Rover and putting it in your name?
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A. I don't recall exactly how the conversation came about. He just says we want to buy an '08 Land Rover and put it in my name. So we did. I didn't ask any further questions.
Q. Did this conversation happen when he was in jail or after he was out?
A. Meaning out on house arrest?
Q. Right.
A. When you say "out" I think of the Science Foundation. On work release, so you have to be more specific.
Q. You tell me what happened, when the conversation happened relative to where Jeffrey was at the time.
A. I'd only be guessing again. I would say this probably happened a year ago, maybe less than a year ago. I'd have to look. I don't remember exactly the --
Q. So it was either at a time when he's at the Florida Science Foundation or possibly on house arrest?
A. It was -- no, it was definitely before house arrest. It was probably during the time of the Florida Science Foundation, to be accurate.
Q. Okay. Are you aware --
A. About eight or nine months ago.
Q. Okay. Are you aware of a Mercedes-Benz CLK
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2005 registered in your name?
A. Yes.
Q. And whose car is that?
A. That car also is a Palm Beach house car to be used at the house.
Q. What does that mean, "a Palm Beach house car"?
A. It's a car that we park in Jeffrey's driveway for people to use. Anybody that comes to the house can select a car to go anywhere. I mean, run errands, go shopping, do whatever they need to do. And that was purchased the same way. It was in my name.
A. They were wired to my account. I don't know exactly what account they came from.
Q. And the funds came from Jeffrey Epstein?
Q. Again, that's a conversation that has to take place before -- that you have to agree to put a car in your name?
A. Yes, yes.
Q. And is that a conversation between yourself and Jeffrey Epstein that takes place?
A. Yes.
Q. And what is the substance of that conversation that results in a Mercedes-Benz 2005 being placed in your name?
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in Palm Beach.
Q. But why put it in your name?
A. I don't know.
Q. You didn't ask any questions about that?
A. No, I didn't.
Q. Okay. Are you aware of a Jaguar X-Type 2005 registered in your name?
A. I forgot about that one, yes.
Q. Whose car is that?
A. That's a Palm Beach car.
Q. What do you mean "a Palm Beach car"?
A. It's the Palm Beach house car, another run around for people to use.
Q. And again, that's a conversation that has to take place that results in a car being placed -- registered in your name?
A. Yes.
Q. Okay. Now we're talking about several cars here?
A. Yes.
Q. That are all being placed in your name?
A. Yes.
Q. You never at any time ask any questions to Jeffrey Epstein why are you placing these cars in my name?
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A. I did not.
Q. So your suspicions were never -- your curiosity was never piqued at all as to why these cars are being placed in your name?
A. My curiosity was piqued.
Q. You never asked him the question, you just agreed to do it?
A. That's correct.
Q. That goes for the Jaguar X-Type?
A. Yes.
Q. Are you familiar with a motorcycle, Big Dog Chopper Motorcycle, 2003?
A. That is mine.
Q. Yours?
A. Yes.
Q. Registered in your name for a good purpose, right?
A. Yes, it is.
Q. At your house?
A. Yes.
Q. You use it?
A. Absolutely.
Q. All right. Ford F-250, 2008, registered in your name, are you familiar with that?
A. It's not registered in my name.
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Q. Okay. So if that's registered in your name, that would be a shock to you? That would be a surprise to you?
A. Yes, it would be.
Q. There should be no documentation from you where you would be the registered owner of the Ford F-250?
A. What year?
Q. 2008.
A. I remember buying that car. I just -- that shouldn't be in my name.
Q. What do you mean you remember buying that car?
A. I do a lot -- I do all the car purchases for Mr. Epstein. I'm a car fanatic, so for years I've been the car-shopper. I'm the car fanatic.
Q. Okay. But these cars aren't classic vehicles. These are vehicles that are not being refurbished or anything, they're being driven around town?
A. No, but they're fun. The new Range Rover is a nice car.
Q. This Ford F250, that's a car also that's Palm Beach -- as you would say a Palm Beach car?
A. No.
Q. That's a car that stays at your house?
A. No.
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Q. Who drives that car, Ford F-250?
A. That was shipped to St. Thomas.
Q. For who to use and for what purpose?
A. Well, that car should have been put under LSJ, LLC.
Q. What's LSJ, LLC?
A. Little St. James.
Q. And that's a corporation?
A. Yes.
Q. Your understanding is that's a corporation affiliated with Jeffrey Epstein?
A. I know it's a corporation. I don't know its affiliation to Jeffrey.
Q. At this point in time, the way that this car comes about is through a conversation with yourself and Jeffrey Epstein?
A. Yes, yes.
Q. So to make some representation that this -- that this corporation LSJ, LLC, you're not sure if that has any affiliation with Jeffrey Epstein?
A. I don't have any facts to tie the two together.
Q. Common sense would dictate?
A. Yes.
Q. Okay.
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MR. CRITTON: Form.
BY MR. EDWARDS:
Q. Again, that's not a car that you use, the Ford F-250?
A. No, it's not even here.
Q. And when you say on St. Thomas, is it on actual St. Thomas, or is it on Little St. James?
A. No, it's on St. Thomas. It's a work vehicle.
Q. For whom?
A. For the workers, for the island.
MR. REINHART: Be careful to answer his question. I think his question is, is it on St. Thomas or Little St. James island? Where physically is the car, if you know.
THE WITNESS: I don't know for a fact.
BY MR. EDWARDS:
Q. It's your understanding it's on St. Thomas?
A. Yes.
Q. And when you say "the workers," what's going on on St. Thomas to where there's workers that need an F-250?
A. Just moving sand. I don't know the exact detail for it.
Q. What were you told about the need for this car to be on St. Thomas?
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A. They need a work truck.
Q. To do what?
A. I don't know what the detail or the -- you know, what the job detail was for the truck. They just needed a work truck.
Q. So Jeffrey Epstein tells you they need a work truck on St. Thomas and that's the only description that you're given?
A. Yes, to go purchase and get the best deal I can on a pickup truck, and that's what I did and for some reason it got put in my name.
(Off the record discussion.)
BY MR. EDWARDS:
Q. Whose money was used to purchase the truck. You say you purchased the truck. I want the record to be clear whether you're purchasing it with your money?
A. No, this was wire-transferred. It was a -- I don't remember how that -- I think it was a wire transfer or a check was FedExed from the New York office to pay for that. That should not be in my name, is what I'm getting at. I'll certainly change that, but I thought you were --
Q. I understand that.
A. No, I'm being -- yeah, I didn't.
MR. REINHART: There's no question.
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BY MR. EDWARDS:
Q. 34-foot JVC Powerboat, 2000, owner LSJ, LLC, registered to Larry Visoski. Do you know that?
A. Yes.
Q. You knew that that boat was registered in your name?
A. It's registered to LSJ. It's Jeffrey's boat that we keep here in West Palm Beach.
Q. And do you keep it at your home?
A. No.
Q. Do you know that the registration is to your home?
A. It's used in my home address, yes.
Q. Why was that done?
A. We were eventually going to ship it out to St. Thomas for it to live, but since Jeffrey's here, we're keeping it in Florida, and when we ship the boat over, we will change title to the Little St. James address.
Q. What do you mean "since Jeffrey's here we're keeping it in Florida"? What does Jeffrey being here have to do with keeping a boat that's registered in your name and to your address --
A. Well, I have access to use the boat, you know, here in Florida, but it's Jeffrey's boat.
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Q. Okay. And by "Jeffrey's boat," it was purchased with Jeffrey's money?
A. That is correct.
Q. Do you know how much that cost?
A. I think it was 60,000.
Q. Do you know how much the Ford F-250 cost?
A. Twenty-five, I'm guessing, ballpark.
Q. Do you know how much the Jaguar X-Type cost?
A. 11,000.
Q. Do you know how much the Mercedes-Benz CLK cost?
A. 35,000.
Q. Do you know how much the Land Rover cost?
A. 68,000.
Q. Do you know how much the Mercedes-Benz SUV cost, that's yours, right? The Chevy Suburban is yours as well?
A. Yes, I remember how much those cost too.
Q. Is there another boat, 35-foot Donzi powerboat, 1999?
A. That's the one I thought you were talking about originally.
Q. That's the same boat?
A. That's the same boat.
Q. Is there any other boat that's registered in
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your name?
A. No.
Q. Did you know that in -- let me ask you this:
Do you have a 2003 Ferrari F75-M?
A. No.
Q. Any reason why the car is registered in your name and the asking price is $159,000 being sold in New York?
A. That car is not registered in my name.
Q. If it's registered --
A. The ad is in my name.
Q. Why is the ad in your name?
A. Because I was trying to sell it.
Q. Why were you trying to sell it?
A. It was Jeffrey's car and we didn't want it anymore.
Q. Why would he put his pilot in charge of selling his Ferrari?
A. Because I bought it.
Q. How much did you buy it for?
A. 179,000. Now, when I say "I bought it," it was his money. I was the one that negotiated it, to be clear. It was his car for use in New York.
Q. Are you aware of the Zorro Trust winning an 85 million-dollar Power Ball lottery in 2008?
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A. No.
MR. CRITTON: Say that again.
MR. EDWARDS: The Zorro Trust winning an 85 million-dollar -- claiming the ticket for 85 million-dollar Power Ball ticket in 2008.
THE WITNESS: No.
BY MR. EDWARDS:
Q. Have you ever listed your employer as Ghislaine Air in making political contributions?
A. I may have.
Q. Did you know that you had made political contributions --
A. Yes, I have.
Q. -- listing your --
A. I needed a company name for that event, and I had put Air Ghislaine.
Q. And NES, LLC wouldn't do?
A. I didn't think of it at the time.
Q. Did somebody tell you to use Air Ghislaine rather than the company that has been paying you?
A. No.
Q. You just chose to use an employer that isn't actually your employer, nor have they ever been?
A. I represent Air Ghislaine, JEGE and Hyperion as chief pilot, so I consider those really the companies
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that I work for and never really associated myself with NES, LLC as my realistic employer. So when I go to a convention, an aviation convention, and somebody says who do you work for, I use the name JEGE because that's the name of the Boeing company.
Q. But when I sit here and ask you who you work for, you give me a different answer.
A. You're asking for the absolute correct answer, which is where my paycheck comes from, which is NES, LLC. I probably have used that twice in 17 or 18 years as my employer.
Q. Do you know [ ]?
A. I know the name, yes.
Q. How do you know her?
A. I've seen her on the airplane a couple times.
Q. Somebody that you know to be involved romantically or sexually with Jeffrey Epstein at any time?
A. I don't know that.
Q. Are there any other cars, vehicles, items, other things that are registered in your name that are actually Jeffrey Epstein's?
A. No. You've actually covered them all and actually shed light on some that I did not realize, like that Ford.
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MR. REINHART: Mr. Edwards, he needs to expand upon one earlier answer he gave when you asked him if he knew anybody else who worked at the Florida Science Foundation.
BY MR. EDWARDS:
Q. Okay.
A. My wife worked there. When you used the words "worked there" -- or not referring to her as a past tense, but she worked there when it first opened answering the phones.
Q. What's your wife's name?
A. Eileen.
Q. How does she spell that?
A. E-I-L-E-E-N.
Q. Same last name as you?
A. Yes.
Q. How long did she work there?
A. A month, maybe.
Q. And she was answering the phones for the Florida Science Foundation?
A. Yes.
Q. Do you have a good relationship with your wife?
A. I think so.
Q. You still don't know what the Florida Science
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Foundation does?
A. No, because she doesn't.
Q. She doesn't know what it does either?
A. We never talked about it.
Q. You never talked to your wife about what she did?
A. No.
MR. CRITTON: He knew she was answering phones.
BY MR. EDWARDS:
Q. Do you know of any other employees, friends, agents, relatives of Jeffrey Epstein who he places his property in their names, registers them in his names or anybody else?
A. Not to my knowledge. I don't know.
Q. To your knowledge, you're the only person?
A. I'm the only one I'm aware of.
Q. And with respect to minor girls being on the airplane, that being under the age of 18, how many times would you say that you have flown girls into the country, into the United States where you have given a date of birth to Customs of somebody on the airplane that is under the age of 18?
A. I'd have to look at flight records to verify or give you a correct answer. I don't know any to my
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knowledge at this point.
Q. What flight records would you have to look at?
A. The passenger manifests.
Q. Passenger manifests would have the date of birth on it?
A. No. It would have a name, but I don't have --
Q. But at some point in time you remember people, minor date of births, coming into the country and that being turned over to Customs?
MR. CRITTON: Form.
THE WITNESS: I don't remember anybody transporting on the airplane from the country back into the U.S. that was a minor, to my knowledge.
BY MR. EDWARDS:
Q. Okay. Within the country, minors flying --
A. I don't know.
Q. -- on a plane?
A. I don't know dates of birth.
Q. And any people that you knew to be minors on the airplane, were they always accompanied by parents or were there minors on the airplane that you're aware of that were not accompanied by parents?
A. I didn't know either way. I mean, people would get on the airplane and get off the airplane. I could tell you there were times people would get on that
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I didn't even know were on the airplane. Our focus is up front.
Q. Was there a massage table on the airplane?
A. Which aircraft?
Q. On any of them?
A. The Boeing used to have a table on there, but it stayed in the same spot and appeared to be never used.
Q. Okay. So to the best of your knowledge, you have no knowledge of that massage table on the airplane ever being used?
A. Correct.
MR. EDWARDS: I don't have anything else.
CROSS (LARRY VISOSKI)
BY MR. CRITTON:
Q. Mr. Visoski, I have just a few questions. You were just asked about a massage table on the -- any of Mr. Epstein's airplanes and you said there was a massage table on the Boeing?
A. Yes.
Q. Okay. Was there always a massage table on the Boeing or just for a period of time?
A. Just for a period of time.
Q. All right. And who's responsible for cleaning up the airplane after Mr. Epstein and/or the guests
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leave?
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A. Us as the crew.
Q. Okay. So if a massage table had ever been used, it would have been you and the crew who would have been responsible for either taking towels or doing something with the massage table?
A. Absolutely.
Q. And if I understood your testimony, you never saw a circumstance where it appeared to you that the massage table had been used in any manner; is that correct?
A. That is correct. It stayed in the same location since the day it was put on there.
Q. You were asked a bunch -- a number of questions about Mr. Epstein, I'll use this --
Mr. Epstein is the person who directed you generally unless one of -- someone else who worked on his behalf called you and asked you to, say, set up a time to leave or pick up luggage, et cetera. My question to you is this: Have you flown in the past for other private individuals like Mr. Epstein, i.e., as distinct from a commercial?
A. Yes, I have.
Q. And approximately have you flown for four, five, six other private individuals over the years?
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A. Three. I had a short career as far as transferring of owners.
Q. In terms of transferring to the other owners, separate and apart from Mr. Epstein, again, every individual is different, but was your relationship really any different with any of those other individuals? That is, you were in essence -- you were hired to perform a specific task: Fly an airplane to get from Point A to Point B and get the people there safely?
A. My first job, corporate-wise, was for an owner in Miami and I was hired as a pilot, but yet, I would go to his house and maintain a boat that was in the back of his house above and beyond my call of duty because I had an interest in boats. It's just something I like to do. But I always treated Mr. Epstein like any of the other prior clients that I had as owners. I knew that I was not afraid to work for a living, and they understood that.
Q. And it sounds like at least the first owner that you worked for asked you to do similar things that you've done for Mr. Epstein, such as take care of a boat or purchase a boat or maintain the boat?
A. Sure, absolutely.
Q. So your relationship with Mr. Epstein with
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regard to if you bought boats or you bought cars on his behalf, that's very similar to your prior experience with working with another private individual?
A. That is correct.
Q. In terms of the records, the manner in which you flew the plane or -- I don't want to say flew the plane, but in which you operated and maintained the plane for Mr. Epstein are substantially the same you've done with other private individuals?
A. Right, exactly the same. We wouldn't treat Mr. Epstein any different than any prior -- previous jobs that I had. It's the same routine we carry over and that's why we're good at what we do. We take care of the airplanes to the best of our ability.
Q. Is your focus as the pilot, as the captain of both of the airplanes when you took over that responsibility a number of years ago, is it your obligation to get the passengers there safely -- onboard and safely to the destination and then return?
A. Yes, that was always job number one.
Q. And most of us have had I'd say a much more substantial experience in flying commercial planes and I rarely see -- in fact, I can't remember the last time particularly after 2001 I saw the pilots coming back into the cabin shaking hands and helping distribute the
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snacks or liquids. Maybe I'm not on the same flights that some of the other lawyers here are, but I assume you fly commercial from time to time?
A. Sure.
Q. Do you ever see the pilots interacting with the people who are in the back of the airplane?
A. No, not at all. They stay at their station up front.
Q. You got -- as the captain of the planes, when you're flying, you have substantial responsibilities not only to the people on the plane, but as well to the air space which you're flying?
A. Yes.
Q. Okay. By the way, we've been here about -- for about an hour and ten -- we started about ten. It's now 3:30. Did you ever hear the name L.M.? Has Mr. Edwards ever asked you one question about [blank]?
MR. EDWARDS: Is the question have you ever heard of her or did I ask any questions about her, or did you ask both questions and give the same answer?
MR. CRITTON: I'll break them down.
MR. EDWARDS: It doesn't matter to me.
BY MR. CRITTON:
Q. Did you ever meet an individual by the name of
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A. No, I have not.
Q. Did Mr. Edwards, in approximately four hours, little over four hours of questioning, ever ask you one question about that you can recall?
A. Not that I recall.
Q. Have you ever heard the name ? Did you ever know someone named ?
A. Never heard that name.
Q. In approximately four-and-a-half hours of questioning by Mr. Edwards, did he ever ask you about ?
A. No, he did not.
Q. In approximately the -- are you familiar with an individual by the name of Jane Doe( )?
A. I never heard that name.
Q. In approximately four-and-a-half hours of questioning by Mr. Edwards, did he ever ask you questions about Jane Doe( )?
A. No, he did not.
MR. CRITTON: That's all I have.
MR. EDWARDS: I only have two questions based on what your testimony just was to Mr. Critton.
3527-003
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009894
EFTA00159701
Larry Visoski
October 15, 2009
REDIRECT (LARRY VISOSKI)
BY MR. EDWARDS:
Q. You said you had three other people that you've flown for?
A. Three other previous jobs. I'm trying to be as accurate.
Q. Those are private individuals?
A. That is correct.
Q. And who are those people?
A. Herb Glimpsure in Columbus, Ohio, and Edward Seltzer in Miami. And then the other was Tom Boyd, and that was more of a Learjet charter, but he was the owner of five Learjets. Those are my only three jobs in my life.
Q. Also wealthy individuals?
A. Big time.
Q. And did you know what they did for a living?
A. Those I did, yes.
Q. And did you ever go visit any of those people in jail?
MR. CRITTON: Form.
THE WITNESS: I know my first individual had trouble with the law after I had left. I don't remember what it was pertaining to; but no, I never visited any of them in jail, no, sir.
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EFTA_00009895
EFTA00159702
Larry Visoski
October 15, 2009
BY MR. EDWARDS:
Q. Even the one who had trouble with the law, you didn't go visit him in jail?
A. No, I did not.
Q. And did any of them put vehicles or other boats or anything else in your name?
A. No.
Q. Okay. Any of those people ever deed any property or acres or anything like that to you?
A. No.
Q. Did any of those people ever hire your wife for employment?
A. No.
Q. And your attorney, is that your attorney paid for by you, or is this somebody that's hired by Jeffrey Epstein?
A. It is somebody that is hired by Jeffrey Epstein.
MR. EDWARDS: Okay.
MR. CRITTON: One follow-up to your question.
RECROSS (LARRY VISOSKI)
BY MR. CRITTON:
Q. With regard to the private individuals that you worked for prior to Mr. Epstein, what was the longest period of time that you worked for those?
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EFTA_00009896
EFTA00159703
Larry Visoski
October 15, 2009
A. The longest period of time was five years and the shortest being two years.
MR. CRITTON: Thank you.
MR. EDWARDS: We'll order.
MR. REINHART: We'll read.
MR. CRITTON: We'll take a copy, front page, mini with index.
(Witness excused.)
(Deposition was concluded at 3:37 p.m.)
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17
EFTA_00009897
EFTA00159704
October 15, 2009
Larry Visoski
CERTIFICATE OF OATH
THE STATE OF FLORIDA
COUNTY OF PALM BEACH
I, the undersigned authority, certify that LARRY VISOSKI personally appeared before me and was duly sworn on the 15th day of October, 2009.
Dated this 22nd day of October, 2009.
Wendy Beath Anderson, RPR, CRR, FPR
Notary Public State of Florida
My Commission Expires: 9/20/2013
My Commission No.: DD 906647
Job #127542
3527-003
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EFTA_00009898
EFTA00159705
Larry Visoski
October 15, 2009
CERTIFICATE
THE STATE OF FLORIDA
COUNTY OF PALM BEACH
I, Wendy Beath Anderson, Certified Realtime Reporter and Notary Public in and for the State of Florida at large, do hereby certify that I was authorized to and did report said deposition in stenotype; and that the foregoing pages are a true and correct transcription of my shorthand notes of said deposition.
I further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out.
I further certify that I am not attorney or counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party connected with the action, nor am I financially interested in the action.
The foregoing certification of this transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter.
Dated this 22nd day of October, 2009.
___
Wendy Beath Anderson, RPR, CRR, FPR
Job #127542
3527-003
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EFTA_00009899
EFTA00159706
Larry Visoski
October 15, 2009
DATE: October 22, 2009
TO: LARRY VISOSKI Job #127542
c/o Robert D. Critton, Jr.
via transcript
IN RE: vs. Epstein
Please take notice that on Thursday, the 15th of October, 2009, you gave your deposition in the above-referred matter. At that time, you did not waive signature. It is now necessary that you sign your deposition.
As previously agreed to, the transcript will be furnished to you through your counsel. Please read the following instructions carefully:
At the end of the transcript you will find an errata sheet. As you read your deposition, any changes or corrections that you wish to make should be noted on the errata sheet, citing page and line number of said change. DO NOT write on the transcript itself. Once you have read the transcript and noted any changes, be sure to sign and date the errata sheet and return these pages to me.
If you do not read and sign the deposition within a reasonable time (i.e., 30 days unless otherwise directed) the original, which has already been forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish to waive your signature, sign your name in the blank at the bottom of this letter and return it to us.
Very truly yours,
Wendy Beath Anderson, RPR, CRR, FPR
ESQUIRE DEPOSITION SERVICES, INC.
515 North Flagler Drive, P-200
West Palm Beach, Florida 33401
I do hereby waive my signature.
LARRY VISOSKI
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EFTA_00009900
EFTA00159707
Larry Visoski
October 15, 2009
CERTIFICATE
THE STATE OF FLORIDA
COUNTY OF PALM BEACH
I hereby certify that I have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed.
Dated this ___ day of ___, 2009.
LARRY VISOSKI
Job #127542
3527-003
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EFTA_00009901
EFTA00159708
Larry Visoski
October 15, 2009
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EFTA_00009902
EFTA00159709
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