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+IN IHE CIRCUII COURI OF THE
+FIFTEENTH JUDICIAL
+IN AND FOR PALM BEACH
+COUNTY, FLORIDA
+CASE NO. 502008CA028051XXXXMB
+A D
+CIRCUIT
+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
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+APPEARANCES:
+On behalf of the Plaintiff:
+BRADLEY J. EDWARDS,
+ESQUIRE
+ROTHSTEIN, ROSENFELDI, ADLER
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, Florida 33394
+On behalf of the Defendant:
+ROBERT D. CRITION, JR., ESQUIRE
+BURMAN, CRITION & 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. i
+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
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+
+Larry Visoski
+October 15, 2009
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+IND
+EX
+-
+DIRECT
+-
+CROSS
+WIINESS:
+LARRY VISOSKI
+BY MR. EDWARDS:
+BY MR. CRITION:
+BY MR. EDWARDS:
+BY MR. CRITTON:
+REDIRECT
+RECROSS
+6
+214
+220
+221
+NUMBER
+PLAINTIFF'S EX. 1
+PLAINTIFF'S EX. 2
+PLAINTIFF'S EX. 3
+PLAINTIFF'S EX. 4
+PLAINTIFF'S EX. 5
+EXHIBI I S
+-
+-
+-
+DESCRIPTION
+FLIGHT LOG BOOK
+(MARKED IN PREVIOUS DEPO)
+MESSAGE PAD
+MESSAGE PAD
+COMPLAINT
+INMATE VISITOR LOG
+PAGE
+119
+119
+139
+161
+3527-003
+Page 3 of 227
+SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
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+Larry Visoski
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+PROCEEDINGS
+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. Ihere was
+a subpoena duces tecum for this witness, as well
+as
+the previous witness, which
+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. CRITION:
+However, with the proviso, too,
+3527-003
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+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. CRITION: Yes.
+MR. EDWARDS: I'm not saying I necessarily
+agree or disagree with you.
+Ihat's something that
+we'll deal with some other day.
+MR. CRIIION: Bruce, you'd better produce
+these records, but there has to be some sort of
+understanding before --
+MR. REINHARI: 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.
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+MR. EDWARDS: A11 right.
+Thereupon,
+(LARRY VISOSKI)
+having been first duly sworn of affirmed,
+was
+examined
+and testified as follows:
+THE WIINESS: Yes, I do.
+DIRECT EXAMINATION
+BY MR. EDWARDS:
+0.
+Can you tell us your name for the record.
+A.
+Lawrence Visoski, JI.
+O. And MI. Visoski, have you ever had your
+deposition taken before?
+A.
+No.
+Okay.
+Here's the process: I'm going to ask
+you questions.
+You're going to give us
+answers. Try
+to
+give
+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.
+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
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+the question and you need to wait until I finish asking
+the question.
+A.
+So you're not allowed to interrupt me?
+And you're not allowed to interrupt me.
+A.
+Like I just did?
+Right.
+MR. CRITION: 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
+it, I will.
+if
+you
+need me to rephrase
+A. Okay.
+okay.
+Tell me your
+current address.
+A.
+22
+23
+24
+25
+A.
+How long have you
+lived
+there?
+Approximately nine years.
+okay.
+Who
+do you live
+there with?
+A.
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+A.
+A.
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+A.
+Who's your employer right now?
+NES, LIC.
+How long has NES, LIC been your employer?
+A. I'm guessing. I'd say back 1991. I have to
+do the math, but 17, 18 years.
+Has that been your
+only employer since 1991?
+A. Yes.
+Q. And has that been your only source of income
+since 1991?
+A.
+Yes.
+And what is NES, LIC?
+A. I don't really know. I mean, it's the company
+that my check comes from.
+What do you do for NES, LIC that results in
+them paying you?
+A .
+I am chief
+Pilot for the airciaft and
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+helicopters.
+And do you have a specific boss or somebody
+you answer to at NES, LIC?
+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.
+0.
+Okay.
+Aside from Mr. Epstein, who else would
+there be that would call to schedule flights?
+A.
+Leslie.
+A.
+Leslie who?
+Leslie Gruff.
+When's the last time you talked to Leslie
+Gruff?
+A.
+Probably two weeks ago, three weeks ago.
+And where is she currently?
+I believe in New York, is where I spoke to her
+A.
+on the phone last.
+What"s the telephone number you call to reach
+leslie Gruff?
+A.
+e.
+A.
+2.
+A.
+And what address is Leslie Gruff at?
+Do you mean where the office
+is located?
+Correct.
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+And it's my understanding from other
+depositions that there are also apartments in that
+building?
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+A.
+Yes.
+Q. And Mr. Epstein either owns of leases or rents
+certain of those apartments. Is that your
+understanding?
+MR. CRITION: Form; speculation.
+THE WITNESS: I'm
+only speculating.
+I
+don't -- to my understanding, I don't know.
+BY MR. EDWARDS:
+Do you know other people that live in that
+building?
+A.
+Well, it would be myself, Dave Rogers -- well,
+when you say "live," explain.
+0.
+When you're saying yourself and Dave Rogers
+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.
+That's
+also
+a location you've indicated in
+this deposition that is the office for NES, LLC?
+A .
+Yes.
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+What floor or suite number is NES, LLC in?
+phone number where I call. So I don't know for a fact
+if NES, LIC has an office there.
+Q. And what suite number, then, would Leslie
+Gruff sit in to answer that telephone number at
+?
+A.
+I think it's
+And when you stay at
+what suite number or what apartment number do you stay
+in?
+A.
+And how about Dave
+Rogers, where does he stay?
+A. I'm guessing, because
+it's been
+some
+time
+since we've been there, 10B, but don't quote
+me on it.
+0.
+Who are the other
+people in that building that
+you know to stay there on a regular -- fairly regular
+basis?
+A.
+I've seen people in the elevator that, you
+know, have been on the airplane.
+Case
+in point, maybe
+• but I don't know
+for a
+fact that she lives
+there,
+or anybody else for
+that
+matter.
+okay.
+When you say you've
+seen
+on the elevator
+- —
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+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.
+Where do you think
+lives?
+A.
+I would think she lives there.
+You don't have a better location?
+A.
+I don't have another location.
+0.
+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.
+Wel1, NES, LUC, would
+you say that the owner
+or controller
+of that company
+i g
+Jeffrey Epstein?
+MR. CRITION: Form.
+THE WIINESS: I don't know that for a fact.
+BY MR. EDWARDS:
+0. Jeffrey Epstein is somebody you've
+indicated
+that you've worked for for 17 or 18 years, right?
+A.
+Yes.
+And over the 17 or 18 years you've become
+personally close with him as
+well, correct?
+MR. CRITION:
+Form.
+THE WITNESS:
+I don't understand how you mean
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+"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 WIINESS: 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.
+2.
+A.
+Yes.
+Have you been to his New York home?
+How many occasions have you been to his New
+York home?
+MR. CRITION: Object to form.
+THE WIINESS: 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.
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+BY MR. EDWARDS:
+O. Other than picking up luggage, have you been
+to his home to visit or socialize with him?
+A.
+Not to socialize, no.
+0.
+A.
+e.
+A.
+Have you been to his Palm Beach home?
+Io?
+Io MI. Epstein's Palm Beach house?
+Right.
+Have you been there?
+A.
+0.
+Yes.
+Have you been inside?
+A.
+Yes.
+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.
+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.
+0.
+A .
+NO.
+What other reasons
+have you gone there?
+I've set up several home theater equipments,
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+you know, televisions and such.
+Is that another hobby or job or something
+of
+yours?
+A.
+A.
+A.
+A.
+0.
+A.
+Both.
+Does he pay you for that?
+Not any more than my salary.
+What's your current salary?
+At this time, 180,000.
+And what are you paid
+Io manage his aircraft.
+What does that entail?
+Scheduling maintenance.
+$180,000 to do?
+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.
+Over the years, you mean, there have been
+Christmas bonuses?
+A.
+Yes.
+0.
+Is 180,000 the most he's ever paid you?
+A.
+No.
+0.
+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.
+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 200B, last year. It was last Christmas we all took
+a 10 percent salary cut.
+0.
+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.
+And did you ask for an explanation?
+A.
+He explained it was due to economic reasons
+throughout the country.
+0.
+Okay. So in 2008, how much was
+-- were you
+being paid by NES, LLC?
+A.
+200,000.
+And is 200,000 the most that you've ever made
+frOm NES, LIC?
+A .
+Yes, sir.
+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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+23
+24
+25
+about?
+MR. EDWARDS: 2008.
+THE WIINESS: That year, I think we skipped
+Christmas bonuses that year. Ihe last bonus might
+have been 2007.
+BY MR. EDWARDS:
+2.
+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.
+-- 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.
+Okay. And how much was the 2007 holiday
+bonus?
+A.
+I'd have to ask my wife, to be honest.
+haven't seen my paycheck in 27 years,
+so I believe it
+was $10,000.
+And in 2007 you also made $200,000?
+A.
+0.
+Yes.
+Okay.
+A .
+With a question mark.
+I'm trying to
+be
+as
+accurate as I can, but yes.
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+A.
+Something pretty close to that?
+Yes, sir.
+Okay. So with the bonus it was 210,000,
+roughly?
+A.
+Right.
+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.
+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?
+No, I wouldn't know the progression.
+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.
+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.
+0.
+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.
+Okay. But it's your understanding that the
+NES, LIC is paying you for the work that you
+do
+as
+a
+pilot or
+maintain the planes for Jeffrey Epstein?
+A.
+To my understanding, yes.
+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?
+I don't remember.
+I mean,
+I don't.
+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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+Okay.
+So whether it was NES, LUC or some
+other company, it was all of a sudden a company name,
+the best of your knowledge?
+A.
+Exactly, yes.
+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.
+Okay.
+A.
+You're
+going back
+a long ways.
+Yes.
+A.
+I'm trying.
+Your relationship goes back that far. That's
+why I chose that year.
+A.
+Right.
+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.
+Okay.
+In addition to monitary bonuses, were
+there ever gifts or any other type of compensation that
+NES, LIC or Jeffrey Epstein provided you?
+A.
+Yes.
+And is that over the span of the
+18 years?
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+A.
+Yes.
+Okay.
+Tell me what some of those items are.
+A.
+I remember one specifically was a pool heater.
+Excuse me?
+A.
+A pool heater.
+When was that?
+A.
+1995-ish.
+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."
+A.
+0.
+A.
+Where were you when you had that conversation?
+In the airplane.
+How did he know that you had built a pool?
+Just in general conversation.
+You were having a conversation with Jeffrey
+Epstein?
+A.
+Yes.
+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.
+okay.
+When you say
+"during the flight,"
+does
+that --
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+A.
+Again, you're going back a long ways.
+I understand. We're talking about 1995 right
+now.
+A.
+Yes.
+You're having a conversation with Jeffrey
+Epstein. Who is flying the airplane?
+A.
+The auto pilot and there's two crew.
+Okay. So are you back in the back portion or
+is he up in the cockpit?
+A.
+0.
+there?
+Up in the cockpit.
+Okay. Jeffrey Epstein sometimes comes up
+A.
+A.
+Just, yeah, in between the two pilot seats.
+All right. Is that something
+that was
+typical, to have conversations like that?
+Mm-hmm.
+Yes?
+A.
+Yes. No nodding.
+0.
+And would those conversations be directed
+mainly with you or with the other pilots as well?
+A.
+Mainly with me.
+e. I mean, you've kind
+of been
+described
+as the
+main guy of the main pilot.
+Wouldn't you consider that
+pretty much your role, right?
+A .
+Well, that's chief pilot.
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+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. CRITION: Form.
+THE WIINESS: Right.
+BY MR. EDWARDS:
+Okay.
+And you feel like over the years your
+relationship with Jeffrey Epstein has been pretty good?
+A.
+Yes.
+And you have been closer to him over the years
+as you've grown to know him?
+MR. CRITION: Form.
+THE WIINESS: 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:
+okay.
+So that's not something that you think
+you are? You don't think you're his buddy?
+A.
+No, siI.
+Do you
+consider
+yourself his friend?
+A .
+I believe 50-
+0.
+Do you think he considers you his friend?
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+A.
+I think so.
+All right. What makes you think that?
+MR. CRITION: Speculation.
+THE WIINESS: He's always been kind and
+respectful.
+BY MR. EDWARDS:
+Ever invited you to dinner?
+A.
+No, sit.
+Have you ever associated or socialized with
+him during the day at any of his homes?
+A.
+Only during a business reason.
+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. CRITION: Form; predicate, speculation.
+THE WITNESS: Io 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
+апу
+of the
+other.
+BY MR. EDWARDS:
+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.
+0.
+And not onty doos he go thered out!
+sometimes, correct?
+A.
+Yes.
+When he's in Palm Beach, that's where he --
+A.
+He sleeps.
+-- sleeps?
+Right.
+When he's in New York, do
+you know where he sleeps?
+A .
+No.
+O. 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. CRITION: 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.
+But you assume that he does?
+A.
+Assuming.
+That's where he sleeps when he's in New York?
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+MR. CRIIION: Form.
+THE WITNESS: I assume.
+BY MR. EDWARDS:
+Q. Ihat's where his luggage is when you pick it
+up?
+A.
+Doesn't mean he owns it.
+Right. But that's where it is?
+A.
+Yes, sir.
+Do you know of anybody else who owns that home
+in New York?
+A.
+No.
+okay.
+Have you been to his ranch in New
+Mexico?
+A.
+Yes.
+BY MR. EDWARDS:
+New Mexico?
+MR. CRITION: Form.
+Q. How many times have you been to his ranch in
+MR. CRIIION: Form; predicate.
+THE WIINESS: A guesstimate, fifty times, only
+due to the fact that we would fly there.
+BY MR. EDWARDS:
+And where would you land?
+A.
+Depending upon the aircraft,
+either
+Albuquerque of
+Santa
+Fe.
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+Are those private airports?
+Public.
+Q. Public, okay. Are there any private landing
+places where you would land any airplanes in New Mexico?
+A.
+There are.
+A.
+That you have landed --
+That I have.
+-- his airplane?
+0.
+A.
+Yes.
+A.
+Where?
+We have a 4500-foot strip on the ranch.
+When you say "we," yourself and somebody?
+A.
+The company.
+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.
+Okay. And you've landed an airplane on that
+runway?
+A.
+there?
+A.
+That ranch, yes.
+How many times do you think you've landed
+Ten.
+All right.
+And have you been
+inside
+his
+ranch?
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+A.
+Yes.
+MR. CRIIION: Form to the last question.
+MR. REINHARI: Can you clarify, the physical
+ranch of the residences
+or the structures on the
+ranch?
+MR. EDWARDS: I don't have a good visual
+appreciation for it.
+BY MR. EDWARDS:
+l. Why don't you describe it in your words what
+this ranch that we are talking about 100ks like. And
+I've heard it referred to as the Zorro Ranch. Have you
+heard that?
+A.
+I've heard that.
+Q. Ihat'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.
+A.
+How big?
+Big.
+I've
+read 40,000 square feet in the
+paper.
+Have you been to it?
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+A.
+Yes.
+Does that seem like it's feasible,
+approximately 40,000 --
+A .
+I think so, yes.
+What else do we have on it?
+A .
+There is a compound that has kind of motel
+IOOm
+type
+-- they call it bunkhouse.
+Where's the bunkhouse located?
+A.
+At the
+entrance to
+the ranch.
+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.
+And how far is that from the first house that
+you described, the 40,000 square foot house?
+A .
+It's probably 4 miles.
+Okay. So the Zorro Ranch is a rather large
+area of property?
+A.
+Yes.
+O. 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
+that ranch
+in New Mexico,
+the
+ZorIo Ranch?
+A .
+Thirty to fifty times over the years.
+That's
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+21
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+a guesstimate.
+0.
+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.
+0.
+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.
+Have you ever talked
+to Jeffrey Epstein about
+who owns that ranch?
+A.
+No.
+Do you know of anybody else who may own that
+ranch?
+A.
+Not to my knowledge.
+0.
+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.
+And he has
+a key to the place?
+A. I don't know if there's a key.
+One way or another, he gets in, right?
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+A.
+Yes, siI.
+And he sleeps there?
+A.
+Yes.
+okay.
+A.
+I assume he does.
+You assume he sleeps?
+A.
+I do.
+I think.
+0.
+okay.
+MR. CRITION: This
+is really --
+BY MR. EDWARDS:
+O. Other than the pool heater in 1995, have you
+ever received any other gifts on top of the compensation
+from MI. Epstein?
+A.
+I did get land on the ranch to build a house.
+0.
+What do you mean you got land on the ranch?
+A.
+He deeded me land to build a home.
+When was that?
+A.
+Ten years ago at least.
+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.
+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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+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+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.
+So how long has a home actually been on that
+property?
+A.
+Nine years.
+And that's a home that you own?
+A.
+Yes, siI.
+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.
+A.
+A.
+All right.
+So what did he actually give you?
+40-acres of land.
+That you did not have to pay for?
+You know, I'd have to go back and 100k. I
+think it was -- I had to pay something for it. I don't
+remember.
+How often have you visited that piece
+--that
+home that you own?
+A.
+My wife would spend
+summeIs
+out there
+with the
+kids.
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+24
+25
+Okay. But that's on the Zorro Ranch?
+A.
+Yes.
+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 ZorIo 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.
+0.
+Okay. And did you have
+a conversation with
+him that led to him giving you or gifting you 40-acies
+of land?
+A.
+We talked about it because he knew I was
+looking for a home out there.
+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
+foI 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...
+0.
+Well, did he give Dave Rogers
+any land out on
+the New Mexico ranch?
+A.
+No.
+0.
+okay.
+When you say you paid for it, I thought
+that I asked that question, "Did you pay for the
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+40-acres?" I thought your answer was, "I don't know,
+I'd have to go back and 1o0k."
+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.
+0.
+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.
+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.
+Okay. So when
+I'm
+saying he gave you the
+land, he may have actually given you the land?
+A.
+Sure.
+Okay. And to the best of your knowledge, he's
+never given anyone else land
+out there?
+A.
+Not to my knowledge.
+MR. CRITION: Form.
+BY MR. EDWARDS:
+0 .
+All right.
+How big is
+this house that you
+built on the ranch?
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+A.
+1800 square feet.
+Were you ever at that house at the same time
+when he's at his house that's
+on that Zorio Ranch?
+A.
+Yes.
+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
+really long time. But
+the progression, was
+that
+a yearly basis normally or
+after two years or three years?
+A.
+Yearly basis.
+Okay. And would that normally be in
+increments of?
+A.
+$5,000.
+0.
+Okay.
+You've talked about a couple other
+gifts that have been given to you from Jeffrey Epstein
+over the years; one is a p00l 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.
+0.
+Okay. I don't want to split hairs with 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 of otherwise that
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+you feel was compensation for you working for him?
+I drive a company car. I mean...
+Okay. What kind of car?
+A .
+A Hummer.
+You say "a company car." Ihat's owned by NES,
+LIC?
+A.
+No, I think the registration has Zorro
+Development on it.
+0.
+What is Zorro Development?
+A.
+I believe
+that's the ranch, of at least it has
+the name of the ranch. I don't know what the entity is.
+And it's your understanding that that's a
+company vehicle?
+A.
+Yes.
+0.
+And where is that vehicle primarily garaged?
+A.
+At my home.
+In
+or in the Zorro Ranch?
+A.
+No, here in
+All right. And is there only one company
+vehicle that you're issued?
+A.
+Yes, sir.
+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.
+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.
+When did you get the Hummer?
+Probably three years ago.
+Do any
+other members of Mr. Epstein's Piloting
+team have company cars?
+A.
+No.
+Only you?
+A.
+Yes.
+And do you know how that decision was made to
+get you a company vehicle?
+A.
+No.
+What do you use that vehicle for?
+A.
+To and from the airport.
+All right. Do you use it for personal reasons
+also?
+A.
+A.
+A .
+I guess, yes.
+I mean, that's your primary vehicle?
+Yes, of I drive my wife's car.
+Which is?
+Type of car?
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+Yes.
+A. A Mercedes.
+Q. And is that something that was
+also
+gift
+from Mr. Epstein?
+A.
+No, siI.
+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 of reward of anything else?
+A.
+No, siI.
+0.
+And
+your only income is from Mr. Epstein or
+his companies?
+A.
+Correct.
+Okay.
+And
+it's been that way since 1991?
+A.
+Yes.
+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.
+And this is before he owned the airplane?
+A .
+Yes.
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+And which airplane was that?
+A.
+The Hawker.
+Does he still have the Hawker?
+A.
+No.
+How long did he have that plane?
+A.
+Five years, guesstimate; foul or five years.
+So sometime in the mid '90s?
+A.
+Yes.
+Did you keep any type of logs
+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 1ogs.
+Okay.
+A .
+That's the standard for the industry.
+0.
+So that's something that you kept, or that
+Dave Rogers kept?
+A.
+Dave Rogers.
+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.
+okay.
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+MR. REINHARI: 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 MI. Epstein's airplanes?
+MR. REINHART: Are we going back all the way
+from "91 to the present?
+MR. EDWARDS: Sure.
+THE WIINESS: You're talking about the Hawker?
+BY MR. EDWARDS:
+O. Any airplanes. What documents would there be?
+A.
+There would be the same: Flight logs and
+passenger manifests would exist.
+0.
+And are either of those required?
+A. The flight log is required for the aircraft to
+track times and landings.
+And in the flight log, is it required that you
+designate the names of the passengers?
+A.
+No.
+That's just something that Dave Rogers did on
+his own?
+A.
+Revenue.
+Everybody does that.
+It's more
+for Internal
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+0-
+okay.
+If something happens, they know who is
+on the plane?
+A.
+Exactly, weight and balance.
+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 oI the passenger manifest, yes.
+By "kept" I meant maintained to where they're
+in your possession either on paper or computer?
+A.
+We keep
+- -
+MR. REINHARI: Can you differentiate a flight
+1og 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.
+Either in the form
+of paper
+OI ON
+a
+computer?
+A.
+No.
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+Makes that easy.
+A.
+okay.
+In 1991, were you
+the chief pilot?
+A.
+No.
+Somebody else was the chief pilot?
+A.
+Yes.
+Who's that?
+A.
+Dave Rogers.
+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.
+Why?
+A.
+Professionalism, technique.
+What do you mean by that?
+A. Ihe way Dave would operate
+an aircraft,
+JeffIey knew the difference
+when I was flying and when
+Dave was flying.
+How do you know he knew the difference?
+A.
+Just --
+He told you?
+A.
+Yes. He knew the difference that if he never
+came up front, he knew who
+was
+flying, who landed.
+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.
+O. What specifically were Jeffrey Epstein's likes
+and dislikes with respect to the flight of the plane?
+MR. CRIIION: 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. CRITION: I want
+to use
+this
+for
+some
+other depositions where we
+-- we've gone beyond
+the
+scope.
+THE WIINESS: 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:
+Okay.
+A.
+Hence, the transfer of power.
+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. REINHARI: Could you clarify which "he"
+you're talking about?
+MR. EDWARDS: I'm
+talking
+about Jeffrey
+Epstein.
+MR. REINHARI: Okay.
+BY MR. EDWARDS:
+0 .
+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.
+Does he still have that plane?
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+A.
+e.
+A.
+e.
+A.
+Yes, sir.
+How big of a plane is that?
+Large corporate jet.
+How long has he had it?
+Fourteen years; 13, 14 years.
+0.
+And other than the Gulfstream, what other
+airplanes does he have?
+When you say "he," obviously, these
+are
+company-owned
+--
+Jeffrey Epstein
+or his companies.
+A.
+A Boeing 727.
+0.
+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.
+0.
+Several different partitions to where if the
+pilot comes out of the cockpit, you don't necessarily
+see all the passengers?
+A.
+Yes.
+That's true?
+A.
+Yes.
+0.
+Okay.
+MR. REINHART:
+Keep your voice up so
+she can
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+hear you.
+THE WIINESS:
+oh.
+MR. REINHARI: And
+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.
+And currently still
+owns -- of the companies
+associated with him own the Gulfstream and the Boeing?
+A.
+Yes.
+And in the past two years, have you flown
+those two airplanes?
+A. Just for routine flights to
+keep them loose
+OI, you know -- you know what I mean.
+O. Have those two airplanes been flown by anyone
+else in the last two years?
+A. No.
+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.
+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
+| I believe. I think
+that was the three passengers, to the best of my
+knowledge.
+2.
+And it's my understanding that little
+St. James is an island that Jeffrey Epstein owns of
+controls?
+8
+9
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+MR. CRITION: Form.
+THE WIINESS: 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.
+And have you been there with Jeffrey Epstein?
+A.
+I've been there when he was there.
+Have you flown on
+airplane with him to that
+destination?
+A.
+No.
+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.
+And do you fly the helicopter
+as well?
+A. Yes.
+How many helicopters are owned or controlled
+by Jeffrey Epstein and/or corporations associated with
+him?
+MR. CRITION: Form.
+THE WIINESS: At this time, one.
+BY MR. EDWARDS:
+And has that helicopter been flown in the last
+two years?
+A.
+Just for routine maintenance.
+And when you and -- let's say when
+and
+• flew to Nassau, do
+of that trip?
+and
+you know
+the purpose
+A.
+A.
+A.
+A.
+No.
+How long did you stay?
+Five hours.
+Did you pick anybody up there?
+No.
+Meaning passengers?
+Yes.
+No.
+What happened?
+You landed the airplane and
+then what?
+A .
+The passengers left.
+Dave and I went and had
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+lunch. Ihe passengers showed up and we came back.
+Q. Have you ever stayed at the home that is on
+Little St. James?
+A.
+No.
+Have you known Jeffrey Epstein to stay at that
+home?
+A.
+I don't know that for a fact.
+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. CRITION: 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.
+When you say you've been there when he was
+there, how many times has that occurred?
+A.
+Estimating,
+a hundred times.
+okay.
+A.
+Irying to give an honest answer.
+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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+-- for what period of time are we talking
+about?
+A.
+A.
+2007?
+flying.
+A.
+During what period
+of time?
+Right.
+Let's see, when did all this happen? What,
+So eight years prior to whenever he stopped
+so...
+'98/'99?
+Yeah, I guess, yes.
+I mean, that sounds like a right
+1- -
+Sounds about right, yeah. Don't hold me to it
+A.
+again.
+0.
+A.
+All right.
+You're going back
+a long way.
+So from approximately the '98/'99 time frame
+when Jeffrey Epstein would fly to Little St. James,
+would you be the pilot?
+A .
+Yes.
+Okay. And you say that you've been there -- I
+thought that you just told
+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.
+Got it.
+A.
+I was just trying to be
+exact.
+Thank you.
+A.
+It's a small island.
+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.
+0.
+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.
+0.
+And when he stays
+О П
+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
+0I
+not?
+A.
+Exactly.
+But do you stay --
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+October 15, 2009
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+A.
+I don't. I mean --
+Well, he either stays there or someone else
+picks him up in a helicopter or he swims away?
+A.
+Correct.
+Okay. You stay on St. Thomas?
+A.
+Yes.
+okay.
+Is there a place that you've stayed on
+St. James, ever?
+A.
+No, I've never.
+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,
+siI.
+You never been
+inside that home that's located
+on St. James?
+A.
+Yes, I've been inside the home.
+How many times have you been inside the home?
+A.
+I mean, ten, fifteen times.
+And for what occasion?
+A .
+I've set up the theater
+system
+that's in the
+living room.
+0.
+okay.
+A .
+So it would be there to work to hook up a TV
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+October 15, 2009
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+or a stereo.
+And do you know les Wexler?
+A.
+No, I don't.
+Have you ever met him before?
+A.
+I have met him.
+0.
+Wexler and Jeffrey Epstein?
+Do you know of any relationship between Les
+I don't know what -- to what extent they have
+a relationship, no.
+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 --
+How do you know they talk to one another?
+A. I've seen them speak to one
+another at the
+foot of the airplane.
+0.
+All right. Have you ever flown the
+airplane -- any of the airplanes with les Wexler as a
+passenger?
+A. No.
+Have you ever flown the airplanes with
+as a passenger?
+A.
+Yes.
+0.
+And do you know
+?
+A.
+Yes.
+0.
+And for how
+long have you known
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+October 15, 2009
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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.
+How did you meet her?
+A.
+I guess I was introduced.
+She was
+on a flight
+0 f l
+OUIS.
+You
+were introduced to her by whom?
+A.
+She
+may have introduced
+herself.
+I mean,
+you're
+going
+back a
+ways.
+1
+don't know
+the official
+introduction, how it went.
+And to your knowledge, what is her -- is she
+associated of affiliated in some way with Jeffrey
+Epstein?
+MR. CRITION: Form.
+THE WIINESS: 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.
+A .
+I'd only be guessing
+again.
+We're talking hundreds of flights, though?
+Sure, sure, a lot of flights.
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+It seems to be -- I mean, you seem like
+somebody who has common sense.
+It seems like somebody
+that knows Jeffrey Epstein?
+MR. CRITION: Form.
+BY MR. EDWARDS:
+Correct,
+A.
+Yes.
+Q. All right. And do you believe that there is a
+business relationship there
+oI 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.
+Okay.
+Have you ever
+socialized with
+17
+18
+19
+20
+21
+22
+23
+24
+25
+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.
+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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+A.
+And have you ever called her?
+Yes.
+When's the last time you talked to
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+A week ago.
+What was the occasion?
+We were discussing carpet for one of the
+A.
+aircraft.
+And where was she when you were talking with
+her?
+A.
+A.
+A.
+A.
+A.
+A.
+I don't know. It was over the phone.
+Did she call you or you call her?
+No, I called her on her cell.
+Okay. And that's a New York number?
+I don't know. It's on speed dial.
+Do you have your phone with you?
+Yes.
+Could you tell me what that number is?
+Sure.
+Thanks.
+Sure.
+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.
+0.
+In the last two years,
+did you tell me the
+helicopter has flown?
+A.
+Yes.
+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
+its --
+it's important that it keeps moving.
+0. Other than maintenance-type flights, have you
+flown the helicopter in the last couple of years?
+A.
+Yes.
+And who was on the helicopter?
+A.
+I flew to Miami with Mr. Epstein.
+When was that?
+A.
+It was a couple weeks ago or a month ago, I
+think.
+A.
+For what?
+Sorry?
+For what occasion?
+I think he had a meeting with his attorneys in
+Miami.
+A.
+0 .
+Today is October the 15th.
+Is this during
+the
+month of October that you had this flight in the
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+21
+22
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+24
+25
+helicopter with Mr. Epstein?
+A.
+I'd have to look at the book to be exact for
+you.
+Okay. But it's either the end
+of September or
+the beginning of October?
+A.
+Yeah.
+How do you know that he was meeting with his
+attorneys?
+A.
+I believe that he
+had mentioned that he was
+meeting his attorneys.
+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.
+Okay. That's just something that he
+said
+to
+you in conversation?
+A.
+Yes, sir.
+Was there anyone else on the airplane besides
+you and Mr. Epstein?
+A.
+Yes.
+Who was that?
+A.
+A.
+who?
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+October 15, 2009
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+2
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+11
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+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+How long have you known
+?
+A. I don't know, five years.
+A guess
+again,
+four, five years.
+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.
+0.
+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.
+Hundreds of times?
+MR. CRITION: Form.
+THE WIINESS: 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. CRITION:
+Form.
+THE WITNESS:
+I'd only be guessing
+and
+speculating.
+I have
+no idea.
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+October 15, 2009
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+8
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+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. EDWARDS:
+O. 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?
+A.
+I'd have to look at the logs.
+MR. REINHARI: Can we get a time period?
+BY MR. EDWARDS:
+O. 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.
+You can't give me one single name of
+somebody
+who you would say is a frequent flyer?
+A.
+A.
+e.
+A.
+Yes.
+Anybody else?
+A.
+e.
+A.
+0.
+A.
+Yeah.
+Okay. Anybody else?
+Just mainly those
+two.
+How
+about
+Ghislaine Maxwell?
+Not for some time.
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+October 15, 2009
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+8
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+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+0-
+What's your understanding between the
+relationship of Ghislaine Maxwell and Jeffrey Epstein?
+A.
+I don't really know.
+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.
+And do you know where
+i s
+staying these days?
+A.
+No.
+Do you know what car she's driving these days?
+A.
+NO:
+I don't.
+Okay.
+Do you know if she's living with
+Jeffrey Epstein these days?
+A.
+I don't know that.
+Do you know how
+met Jeffrey
+Epstein?
+A.
+I don't.
+Were you on an international flight bringing
+her into the country from some
+other countiy at
+any
+time?
+A .
+I don't know.
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+October 15, 2009
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+2
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+8
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+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. REINHARI: 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 1o0k at the log books, honestly.
+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.
+0 -
+on this recent helicopter flight with
+and Jeffrey Epstein, did you talk with them
+during that flight?
+A.
+NO.
+0. 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.
+How long is that flight from Palm Beach to
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+October 15, 2009
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+11
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+14
+15
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+17
+18
+19
+20
+21
+22
+23
+24
+25
+Miami?
+A.
+e.
+flight?
+A.
+Iwenty-five minutes.
+And did they talk to one another during that
+No.
+They were both completely silent during that
+flight?
+A.
+Yes.
+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. CRITION: Form.
+THE WIINESS: Yeah, it would be typical. It's
+very noisy and communicating
+in a helicopter is,
+you know,
+not that comfortable.
+BY MR. EDWARDS:
+0.
+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
+SECU
+them
+talking to each other.
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+October 15, 2009
+64
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+2
+3
+4
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+0-
+But you don't remember a single specific
+conversation between
+Jeffrey Epstein and
+?
+A.
+An honest answer, no.
+Okay.
+And the same for
+seen or
+-- have you seen Jeffrey Epstein speak with
+have you
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+I've seen him speak with her, yes.
+Can you
+tell me a single specific conversation
+that you have
+overheard between Jeffrey Epstein and
+?
+A.
+One thing that comes to mind would be make
+sure we have Oreo cookies on the airplane. It would be
+something completely nonchalant.
+0.
+Okay.
+And do you know or have reason to know
+of any employment relationship between
+and
+Jeffrey Epstein?
+A. I have no knowledge of any of that.
+Do you know if
+works for Jeffrey
+Epstein?
+A.
+I do not know.
+Do you know
+if
+schedules massages
+foI
+Jeffrey Epstein?
+A.
+I have no idea.
+Has Jeffrey Epstein ever
+indicated
+to you that
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+8
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+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+he is fascinated or infatuated or appreciates or loves
+or likes massages?
+A. I have no knowledge of that.
+0.
+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.
+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.
+0.
+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?
+Well, it was a couple years ago.
+A.
+Right, okay.
+Q. Did you speak with Jeffrey Epstein about that
+investigation?
+A.
+No.
+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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+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.
+0.
+Do you believe it today?
+A.
+I don't believe it.
+You don't believe that Jeffrey Epstein was
+involved with underage girls
+in
+sexual way?
+MR. CRITION: FoIm.
+THE WIINESS: You're
+asking for my opinion,
+and I don't think my opinion is relevant in that
+matter.
+BY MR. EDWARDS:
+l. 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. CRIIION: Form; speculation, irrelevant,
+always.
+THE WITNESS: It's irrelevant.
+BY MR. EDWARDS:
+I need an answer.
+A.
+I don't believe he had sex with underage
+women.
+Or engaged
+in any sexual acts with underage
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+women?
+MR. CRITION: Form.
+THE WITNESS: No.
+BY MR. EDWARDS:
+O. You think that this is just a
+story that a
+bunch of underage women have made up?
+A .
+Speculation.
+MR. CRITION: 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. CRIIION: It's argumentative.
+MR. EDWARDS:
+You're
+objecting to the form?
+MR. CRITION:
+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. CRIIION:
+Form.
+THE WITNESS:
+What I believe doesn't
+matter
+in
+this case, does
+it?
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+BY MR. EDWARDS:
+Q. I need an answer. Do you believe it? Do you
+believe these girls made this up?
+MR. CRIIION: Form.
+MR. REINHARI: I'm going to instruct him not
+to answer. Move on.
+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
+fIOm 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
+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. CRITION: 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 of
+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
+needs
+to answer
+the question and
+whether it's discoverable or not.
+MR. REINHARI: Absolutely. Make your record.
+BY MR. EDWARDS:
+0. Do you have any reason to believe that Jeffrey
+Epstein engaged
+in sexual activity with underage women?
+A.
+I have
+no reason to believe.
+Okay. i
+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.
+Okay. Isn't it true that at some point in
+time you learned that Jeffrey Epstein has
+-- strike
+that.
+MR. CRITION: 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:
+All right. Eighteen years of being a pilot
+foI 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 .
+i just people that we see
+routinely on the airplane.
+O. That's people you see routinely in the last
+five to ten years, right?
+A.
+Yes.
+O. Prior to that time, anybody that you've
+noticed
+as Jeffrey Epstein's friend may be Ghislaine
+Maxwell?
+A.
+What time frame?
+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.
+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.
+No idea?
+A.
+No.
+0.
+Ever asked him?
+A.
+NO:
+actually.
+0.
+Ever been curious?
+A.
+Sure.
+Ever done anything to satisfy that curiosity?
+A.
+If you mean Google it, not really, actually.
+I mean, I really have not.
+Okay.
+So in 18
+years of traveling and being
+the pilot
+and driving -- and
+taking this person, Jeffrey
+Epstein, from
+one
+property
+і п
+New
+York to
+New Mexico
+and
+Florida
+and
+around
+the
+world, you
+have
+idea what
+he
+does in terms of how
+he makes
+money?
+A .
+No, siI.
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+I was produced this flight 1og -- tell me if
+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.
+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,
+believe this is Dave's flight 1og, 1og book.
+I didn't know if it was
+called a flight 1og.
+A.
+Pilot log book, how's that? That's the
+appropriate name.
+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. CRITION: Why don't you refer to it as
+his?
+MR. EDWARDS: Fine.
+BY MR. EDWARDS:
+It's the pilot log book of Dave Rogers?
+A.
+Yes.
+And the years provided in this book are 2002
+through 2005;
+I can represent that to you.
+I'm going
+ask you about certain people that David Rogers wrote
+down as being on the airplane and I want to ask you if
+to
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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.
+8
+9
+10
+11
+12
+13
+14
+15
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+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.
+0.
+Do you know what
+affiliation or
+relationship
+she had with Jeffrey Epstein?
+A.
+NO.
+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
+this
+side
+of the page that
+I'm not familiar with,
+NOI
+do
+I need to be.
+A .
+Right.
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+17
+18
+19
+20
+21
+22
+23
+24
+25
+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, I1th, 13th, 13th, 14th, right?
+A.
+Uh-huh.
+O. I mean, is that something that you would say
+accurately reflects the amount of
+use
+of Jeffrey
+Epstein's planes?
+A.
+Yes.
+So he travels quite frequently?
+A.
+Yes.
+And he travels with many different people,
+right?
+MR. CRIIION: Form.
+THE WITNESS: Yes.
+MR. CRITION: 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. REINHARI: The actual book itself?
+MR. EDWARDS: The court reporter took it,
+right?
+MR. CRITION: The one marked as
+did
+you keep
+that?
+MR. REINHARI: This is it.
+an exhibit,
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+24
+25
+MR. EDWARDS: This is it?
+MR. CRITION: Who took it from the deposition
+the other day?
+MR. EDWARDS: I have this one right now.
+MR. REINHARI: That's the only copy?
+MR. EDWARDS: Okay.
+MR. CRITION: So you took the original?
+MR. EDWARDS: Apparently. It has the original
+sticker.
+MR. CRITION: 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. HOROWIIZ: You mean
+before the transcript
+comes?
+MR. EDWARDS: We can copy it.
+MR. CRITION: 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
+оП.
+MR. EDWARDS: That's what was told to me
+the
+other day, that's why I took it.
+MR. CRITION: 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: Of just copy the page that has
+the exhibit sticker on it.
+MR. CRIIION: Sorry.
+BY MR. EDWARDS:
+Like on this flight, we have "JE."
+I'm
+assuming that's Jeffrey Epstein, correct?
+A. Yes, I'll assume.
+"GM, " Ghislaine Maxwell, right?
+A.
+Yes.
+"D."
+A.
+I would
+assume.
+0.
+I mean -- okay.
+And
+then this name,
+do you
+recognize that person,
+?
+A.
+Never heard
+it.
+And then
+A.
+Yes.
+0.
+You've heard that name?
+A.
+I've heard the name.
+Not sure who that is, though?
+A.
+No.
+0.
+There's only one,
+two,
+three,
+four, five,
+six
+people on that flight?
+A.
+Uh-huh.
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+That's pretty typical of the amount of
+passengers that you would have on a flight?
+A .
+It varied, sure.
+okay, Jove de varted beaveen
+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.
+And so
+it varied from having one
+or two people
+to six or seven people, right?
+A.
+Yes.
+What's the most people that you remember
+traveling on any of Jeffrey Epstein's airplanes?
+A.
+Iwenty-five.
+Okay.
+That would be a rarity, wouldn't you
+say?
+A.
+oh, yeah.
+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.
+0.
+Let's see.
+There's a flight from
+January 15th -- sorry, January 17th, January
+20th
+and
+January 22nd of 2002 that all had
+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
+I would be?
+A.
+No.
+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.
+Okay. Either way, how is it that someone like
+Bill Clinton gets on
+a Jeffrey Epstein flight?
+MR. CRITION: Form.
+THE WITNESS:
+I don't know.
+BY MR. EDWARDS:
+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
+OI
+do that little extra ILC to the aircraft.
+0.
+If it's leaving -- this says it's leaving from
+MIA and where is it landing?
+A.
+HPN I believe is White Plains.
+Okay.
+Do you remember that flight?
+A .
+I remember being on it.
+0.
+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.
+0.
+Do you remember him being on the airplane with
+younger girls?
+MR. CRITION:
+Form.
+THE
+WITNESS:
+No.
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+BY MR. EDWARDS:
+2. Okay. Do you know what his relationship was
+with Jeffrey Epstein?
+A.
+No.
+Q. Do you know if they were friends?
+Assuming.
+But you're assuming why? Just because he's on
+his plane?
+A.
+Yeah.
+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.
+I'm just not familiar with the -- because I've
+never been
+0 П
+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.
+Does Jeffrey Epstein charge these people as
+passengers?
+A.
+I don't know.
+0. Okay. Are these people such as Bill Clinton,
+does that mean that Bill Clinton called
+somebody affiliated with Jeffrey Epstein to get on the
+plane of that Jeffrey Epstein called Bill Clinton and
+asked do you want a ride?
+MR. CRITION: Form; predicate.
+THE WIINESS: I have no idea.
+BY MR. EDWARDS:
+No idea?
+A.
+No idea whatsoever.
+Joe Pagano, do you know who that is?
+A.
+Yes.
+0.
+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.
+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
+you remember that flight?
+A.
+Where did we go?
+Do
+Starts in JFK.
+A.
+Right.
+Where is that?
+MR. CRITION: Do you have a date?
+MR. EDWARDS: March 19th, 2002.
+THE WIINESS: EGGW I believe
+is luton,
+England.
+BY MR. EDWARDS:
+0.
+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.
+Do you remember the purpose of the trip?
+A.
+No.
+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.
+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. CRITION: Form.
+THE WITNESS: I don't know.
+BY MR. EDWARDS:
+All right. There's another flight here on
+January -- I can't read this upside down. Maybe it says
+May --
+A.
+Looks like.
+-- 22nd, 2002.
+Again, with President Bill
+Can you tell me who
+Clinton,
+and
+A.
+are?
+I don't remember.
+Would you know
+them if you saw them?
+Probably not because the names don't
+even ring
+A.
+a bell.
+All right. And then there are plenty of
+flights, many of flights where|
+Jeffrey Epstein,
+Ghislaine Maxwell and
+I are the primary
+passengers, or at least are
+some of the
+passengers
+the flights, correct?
+A.
+Mm-hmm, yes.
+0 -
+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. CRITION: Form.
+THE WITNESS: No. When you're flying the
+airplane, there's a lot more going on than
+passengers' relations.
+BY MR. EDWARDS:
+0.
+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
+JeffIey Epstein?
+A.
+No idea.
+MR. CRITION: What date are you on, Brad?
+MR. EDWARDS: Oh, sorIy. I am
+at June 21st,
+2002.
+BY MR. EDWARDS:
+That"s not somebody that you specifically
+remember?
+A.
+Mm-mm, no.
+Q. No?
+regular flyer for any period
+Epstein's life?
+A .
+Not a regular.
+Is that somebody that you think was a
+of time in Jeffrey
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+Okay.
+Jean Luc Brunel, is that a name that
+you know?
+A.
+Yes.
+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.
+Do you know what he does?
+A.
+No.
+Do you know his association with Jeffrey
+Epstein, if any?
+A.
+No, I don't know what the relationship is.
+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.
+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.
+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.
+And seeing that this is a flight now,
+that
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+October 15, 2009
+87
+we'Ie referring to the same flight on June 21st of 2002,
+that includes
+Jean Luc Brunel,
+Epstein, Ghislaine Maxwell,
+• Jeffrey
+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.
+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.
+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. CRITION: Brad, the
+last one that you
+mentioned, was that the
+same
+date, June 21st, '02?
+MR. EDWARDS: Yes.
+BY MR. EDWARDS:
+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.
+That's
+somebody that you remember as
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+frequent passenger?
+A.
+Who are you referring to?
+?
+A.
+No.
+Dr. Jarecki, is that somebody that you
+remember flying?
+A.
+airplane
+I know the name.
+He may have been on the
+once of twice. I'm guessing only.
+0.
+Do you remember meeting him?
+A.
+Yes, I have met him.
+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. REINHARI: 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:
+0.
+You don't remember her being on the flight?
+A.
+I don't remember the name.
+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. CRITION: 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. CRIIION: Oh, okay. So you've highlighted
+the original exhibit that's marked for the
+deposition? I just want the record to reflect
+that.
+7
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+MR. EDWARDS: Yeah.
+MR. CRIIION: 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. CRITION: 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
+remember?
+A.
+No.
+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.
+In what way?
+A.
+Just loud clothes, so something that you would
+remember, that's all.
+Do you know his role in Jeffrey's life?
+A.
+No.
+Ever heard that he is affiliated with Jeffrey
+Epstein because they both have a sexual attraction to
+underage girls?
+MR. CRIIION: Form.
+THE WIINESS: You're making an assumption on
+that.
+BY MR. EDWARDS:
+0. Have you ever heard that?
+MR. REINHARI: He's asked you if you ever
+heard that.
+BY MR. EDWARDS:
+If your answer is no, it's no.
+I'm sorry, I thought you said they did. No, I
+have not.
+Okay.
+I keep highlighting this name,
+M, 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.
+Do you remember about what age she was when
+she was flying on the airplane?
+A.
+No.
+This could be somebody who is 50 years old or
+ten years old, for all you know?
+MR. CRITION: Form.
+THE WIINESS: Yes.
+BY MR. EDWARDS:
+0.
+Okay.
+A.
+I mean, I would only be guessing at an age.
+Yeah, but I mean, you don't remember her
+at
+all.
+So you don't --
+A.
+I remember the name, exactly.
+Other than the name?
+A.
+Right, yes, sir.
+0.
+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
+even getting
+it.
+Okay.
+You remember this flight where
+President Clinton, Kevin Spacey and Chris Tucker,
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+Jeffrey Epstein, Ghislaine Maxwell?
+A .
+Yes.
+From JFK to what is this, LPAZ?
+A.
+IPAD, that is --
+South Africa or something?
+A.
+No, it's the Azores Islands, Santa Maria.
+Do you know the purpose
+of that trip?
+A.
+That was a fuel stop.
+Okay. And do you know why Chris Tucker and
+Kevin Spacey
+were on that airplane?
+A.
+No.
+Q. Did you talk to them?
+A. Ihey came up in the cockpit and said hello.
+So they conversed, nothing more.
+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.
+0.
+Right now that is the first time that you
+remember Ron Burkle being on your airplane?
+A.
+Yeah.
+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 --
+0.
+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.
+0.
+And you both worked
+for
+the same company that
+flies Jeffrey Epstein's airplanes, right?
+A.
+Yes.
+O. So I was of the presumption, which may have
+been -- I may have been misled here, of 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.
+0.
+Did you know that Dave Rogers was keeping this
+book?
+A.
+No.
+I know he keeps a pilot log book.
+0.
+Okay. But you
+didn't know he was keeping
+the
+names of
+the people who were
+on the airplane?
+A.
+NO.
+It'g not required, so I mean, it's...
+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.
+0.
+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.
+O. And who would create that document of call
+that information into Customs?
+A.
+Whoever the captain was for the day.
+At times would that be you?
+A.
+Yes.
+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.
+0.
+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. CRIIION:
+Form.
+THE WIINESS:
+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. CRITION: Form.
+THE WIINESS: Well, I would have to 1o0k at
+the flight logs.
+BY MR. EDWARDS:
+It's not illegal to have somebody under the
+age of 18 on a flight anyway, right?
+A.
+No, not at all.
+Were you ever aware that you, as pilot, were
+transporting girls under the age of 18 who were supposed
+to be models?
+MR. CRIIION: Form.
+THE WIINESS: 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.
+All right. Do you know
+A.
+No, I don't remember that name.
+A .
+I remember the name.
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+She flew frequently at least for a period of
+time.
+Do you remember that?
+A .
+Yes.
+Is that somebody that you thought was familiar
+with the modeling industry of related to the modeling
+industry?
+A.
+NO.
+0.
+Okay. And these people, did Jeffrey Epstein
+ever tell you how he was associated with any of them?
+A.
+No.
+0.
+Did you ever wonder how he was associated with
+any of them?
+A.
+No, never interested.
+0.
+And
+on several
+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.
+When you say "we
+tried
+to do the best that we
+could-
+A.
+Dave and I.
+okay.
+But the first time that you
+learned
+3527-003
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+Larry Visoski
+October 15, 2009
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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.
+okay.
+A.
+So when you were
+mentioning putting the names
+down, when you
+said female
+0I
+male, you know, I was
+referring to the passenger
+manifest.
+For each of these same flights, then, that
+we'le referring to out of this 10g 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.
+Now, where would I find the passenger
+manifest? Who keeps that documentation?
+A.
+Corporate -- our corporate office.
+Which is whom?
+A.
+Up in New York,
+DarIen Indyke.
+0.
+At what corporation
+is that, though?
+A.
+NES, LIC, I guess.
+MR. REINHARI: Do you know
+for sure?
+THE WITNESS: I don't know for sure.
+I mean,
+3527-003
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+when you say -- we would just send them up to New
+YOIk.
+BY MR. EDWARDS:
+Did you ever keep a copy of them?
+A.
+No.
+Why did you keep a passenger manifest?
+A.
+Just for tracking
+of -- to have the times on
+there for --
+MR. REINHARI: Can I confer with him on one
+thing before you ask a question?
+MR. EDWARDS: Yeah, yeah.
+(Off the record discussion.)
+MR. REINHARI: 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. REINHARI: 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
+3527-003
+Page 98 of 227
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+Larry Visoski
+October 15, 2009
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+at the airport office that I had turned into
+counsel that has the passenger names
+BY MR. EDWARDS:
+okay.
+them.
+A.
+It's called a passenger manifest.
+okay.
+MR. REINHARI: Right.
+BY MR. EDWARDS:
+O. The passenger manifest, just so
+I understand
+exactly what that is, tell
+me. Tell me in your
+words.
+own
+A .
+It's departure time, the city, the landing
+time exactly and the passengers that would have been on
+that flight.
+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.
+Who is currently in the
+custody or
+control --
+SOIIY.
+Who
+currently maintains
+or has possession of
+the
+passenger manifest from 1998 through the present,
+through today
+foI those airplanes that you flew related
+3527-003
+Page 99 of 227
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+Larry Visoski
+October 15, 2009
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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.
+0.
+a lot of
+A .
+When you say "turned into counsel, " there
+a re
+counsel involved
+here.
+Jack Goldberger's
+office, I believe.
+When you say "the
+previous investigation,"
+you're talking about the criminal investigation?
+A.
+Exactly, yes, siI.
+And
+you're
+aware
+in that criminal
+investigation, obviously,
+that
+Jeffrey Epstein pled
+guilty to certain
+charges, correct?
+A.
+From what I read, yes.
+Well, you did visit him in jail, right?
+A.
+Yes.
+We didn't talk about that.
+Okay.
+You know
+in order to go
+to jail,
+though, you have to be convicted of somel
+crime, right?
+MR. CRITION: Form; argumentative.
+THE WITNESS:
+Yes.
+BY MR. EDWARDS:
+0 .
+It wasn't like he was visiting the jail
+and
+3527-003
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+October 15, 2009
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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.
+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. CRITION: Form.
+BY MR. EDWARDS:
+0.
+That's the criminal investigation you're
+talking about, right?
+MR. CRITION: 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. CRIIION:
+THE WITNESS:
+itr
+yes.
+Form.
+I was aware it revolved
+around
+3527-003
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+Larry Visoski
+October 15, 2009
+102
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+BY MR. EDWARDS:
+0.
+A.
+Who first made you aware of that?
+The newspaper.
+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.
+0.
+A.
+Where did that take place?
+I don't remember.
+At your house?
+No. I'm thinking it was Jack Goldberger's
+office, of it may have been downtown at the Palm Beach
+County
+Courthouse
+or something
+in that area there.
+Okay.
+So it either happened at an attorney's
+office
+that represented --
+A .
+Exactly, yeah, I think so.
+-- Jeffrey Epstein or the other side?
+A.
+Yeah.
+And during that questioning, is that when you
+turned over the passenger manifest from prior to 2005?
+A .
+Yes.
+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.
+3527-003
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+October 15, 2009
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+17
+18
+19
+20
+21
+22
+23
+24
+25
+0.
+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.
+0.
+And did you turn them over from 1991 all the
+way through to 2005?
+I don't know. I didn't turn them in. Dave
+Rogers did.
+0.
+Are you in possession
+of a copy of any of
+those materials?
+A.
+No.
+0. I thought that, you know, ten minutes ago when
+we were talking about this you said you had them back at
+an office
+0I--
+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.
+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 l
+present?
+A .
+Correct.
+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 --
+3527-003
+Page 103 of 227
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+October 15, 2009
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+MR. REINHARI: If you know.
+THE WIINESS: 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, of a copy thereof, to Darren
+Indyke or someone at NES,
+LIC; is that correct?
+A.
+Correct.
+If I requested them from NES, ILC, that's
+somebody at some point in time was in possession of all
+the passenger manifests?
+A.
+Sure.
+And NES, LIC'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 --
+But Darren Indyke's the attorney that I would
+call --
+A.
+Yes, siI.
+-- and he could probably steer me in the right
+direction?
+A.
+Yes.
+MR.
+CRITION:
+Form.
+3527-003
+Page 104 of 227
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+October 15, 2009
+105
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+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. EDWARDS:
+Do you know
+A.
+Yes.
+How do you know her?
+A.
+She was on the airplane.
+How old is she?
+A.
+I have no idea.
+Age range?
+A.
+Iwenty-eight.
+Now?
+A.
+Yeah, 28, or maybe if not older now. She was
+probably 28 probably, I guess.
+She was somebody in her
+late 20s.
+0.
+So we're talking about 2003? That's what I'm
+trying to understand.
+A .
+I'm guessing.
+0.
+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.
+Yeah.
+A.
+I mean, I can't be accurate.
+Somebody between 18 and 25?
+MR. CRITION:
+Form.
+BY MR. EDWARDS:
+At the time you were seeing
+her back
+in --
+3527-003
+Page 105 of 227
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+Larry Visoski
+October 15, 2009
+106
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+2
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+5
+6
+7
+8
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+10
+11
+12
+13
+14
+15
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+17
+18
+19
+20
+21
+22
+23
+24
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+A.
+If you want me to guess --
+No, I don't want you to guess.
+A.
+I don't know then.
+Well, if I say between ten and fifty?
+A.
+That's a range.
+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.
+Okay.
+How
+can
+we
+naIIow that down?
+We're
+talking about somebody in her 20s?
+A.
+In her 20s.
+At least that's what you believed?
+A.
+Yes.
+A11
+right.
+Is that somebody that you know to
+be associated oI friendly with Ghislaine Maxwell?
+A.
+I don't know.
+Do you know what her relationship was to
+Jeffrey Epstein or Ghislaine Maxwell?
+A.
+No.
+Do you know where she is now?
+A.
+No idea.
+When's the last time you talked to her?
+A.
+I don't know.
+What date do you have on there?
+February 2003.
+A.
+So, probably that long ago.
+I may
+have
+said
+3527-003
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+October 15, 2009
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+21
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+hello.
+That's somebody who was on the airplane
+multiple times?
+A. More than once.
+I mean, I have no account for
+how many times.
+0. 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.
+Okay. And that's somebody who you actually --
+you would remember the face too?
+A. I might remember Amy's face.
+O. All right. Do you remember why she would have
+ever been on your airplane?
+A .
+No idea.
+0.
+President Andres
+Postiana, at the time I guess
+that was the president of Colombia back in February --
+SOrIy, 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.
+Okay. He's on
+the airplane with Jeffrey
+Ghislaine Maxwell,
+and Jean Luc
+Epstein,
+Brunel?
+A.
+Where did we go?
+I'll let you look at it.
+I'm talking about
+3527-003
+Page 107 of 227
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+October 15, 2009
+108
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+17
+18
+19
+20
+21
+22
+23
+24
+25
+this line, PBI, left out of Palm Beach?
+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?
+A.
+No, not at all.
+Q. And is that a route that you would take for
+the ultimate destination to
+be Little St. James?
+A.
+No.
+If the ultimate destination was Little
+St. James -- show me a flight where the ultimate
+destination was little St. James.
+A.
+Yeah, right here.
+TIST, that's St. Thomas.
+0.
+okay.
+So on that flight that you just pointed
+to, March 27th, 2003, we have Jeffrey Epstein, I
+again, Brent Iyndall -- do you know
+who Brent Tyndall is?
+A .
+Yes.
+And who is that?
+A. I believe he was
+the
+chef.
+0. And
+(phonetic),
+i g
+that
+somebody you know to be a
+model
+these days?
+A.
+I have no idea.
+Do you remember that flight?
+3527-003
+Page 108 of 227
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+October 15, 2009
+109
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+2
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+18
+19
+20
+21
+22
+23
+24
+25
+A.
+No.
+Do you remember Naomi Campbell, picking
+her up
+from St. Ihomas along with Jean Luc Brunel?
+A. I remember her being on board. I don't
+remember the flight.
+0.
+Do you know Joel Pashcow?
+A.
+Yes.
+0.
+A.
+How do you know him?
+He was on the airplane.
+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.
+Do you know what the relationship is today?
+A.
+No idea.
+0.
+How about Todd Mister, do you know what that
+relationship is or was today?
+A.
+No.
+Do you remember him?
+A.
+No.
+Not at all?
+A.
+I mean, I know the name. I don't know.
+Paula Epstein, do you know who that
+is?
+A.
+Yes.
+Who is that?
+3527-003
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+October 15, 2009
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+2
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+8
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+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+A.
+A.
+That's Jeffrey's mom.
+She's passed away?
+Yes.
+At least that's your understanding, right?
+That's what I heard, yes.
+Okay.
+• do you know her?
+• I know the name.
+Somebody who flew on the airplane with some
+A.
+0.
+regularity?
+A.
+Yes.
+Maxwell or
+Q. And do you know her to be friends of Ghislaine
+oI Jeffrey Epstein?
+MR. CRITION: Form.
+THE WITNESS: I have no idea who she was
+friends with.
+BY MR. EDWARDS:
+Q. All right. Do you know what Iole she ever
+played, if she played one, in Jeffrey Epstein's life?
+A.
+No.
+All fight. Glenn Dubin, are you familiar with
+him?
+A.
+A .
+Yes.
+How do you know Glenn Dubin?
+I met him on the
+airplane.
+Outside of
+the airplane, have you ever seen
+3527-003
+Page 110 of 227
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+October 15, 2009
+111
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+2
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+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+him around Jeffrey Epstein?
+A.
+No.
+All right.
+A.
+No.
+• do you know that name?
+A.
+No.
+She was on several flights.
+You don't
+remember seeing her?
+A.
+No.
+All fight. And how about Alan Dershowitz,
+I'm
+sure you know who that is?
+A.
+Sure. He's famous.
+What was your understanding of Alan
+Dershowitz's relationship with
+Jeffrey Epstein?
+A.
+Never talked about it.
+Forrest Sawyer, do you know why he was
+on your
+airplane?
+A.
+A.
+A.
+A.
+Never heard the name, actually.
+Really?
+No.
+LaIry Summers?
+I know the name. I don't remember flying him.
+Have you ever talked
+to Joe Fontanela?
+Yes.
+How do you
+know him?
+3527-003
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+October 15, 2009
+112
+1
+2
+3
+4
+5
+6
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+8
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+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+He usually drops Jeffrey off at the airport.
+In fact, you've called him directly before,
+right?
+A.
+A.
+memory.
+Yes.
+You still have his number?
+I haven't -- yes, I think I still got it in my
+Okay. What is it?
+A.
+It's been a few years.
+It's
+kind of an easy one.
+MR. CRITION: 917 is the first --
+THE WIINESS: Yes.
+MR. CRIIION: Who was this for?
+MR. REINHARI: Joe, Joe Fontanela.
+MR. EDWARDS: Fontanela.
+BY MR. EDWARDS:
+2. Do you know his address, where he resides?
+A. No, I don't.
+Do you know if he -- what his role is in
+Jeffrey Epstein's life?
+A.
+Not really. He just -- he drove the car.
+He drove what car?
+A.
+The car up in New YoIk.
+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.
+Have you ever worked for a company called Air
+Ghislaine? Do you know that company?
+A.
+e.
+A.
+Yes.
+Do you know what that company does?
+No.
+Have you ever been an employee of that
+company?
+A.
+No.
+Do you know who runs that company?
+A.
+0.
+company?
+A.
+No.
+Is Jeffrey Epstein associated with that
+I don't know.
+How have you heard
+of that company?
+A. It's the company name that our registration
+for the helicopters is under, Air Ghislaine.
+0.
+Is that somebody who's ever paid you, a
+company who's ever paid you?
+A.
+NO.
+Do you know Igor Zinoviev?
+A.
+0.
+Yes.
+How do you know him?
+A.
+0.
+Met him on the airplane.
+What is your understanding of his affiliation
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+with Jeffrey Epstein?
+A.
+I don't know. He doesn't talk much.
+Okay. And Sandy Berger, do you know who that
+is?
+A.
+I don't know.
+Do you know any reason why you would have
+flown him on the airplane?
+A.
+I don't even know the name.
+e.
+A.
+I know the name
+Q. Somebody who flew on the plane pretty
+regularly?
+A. I would have to look at the logs. I think
+we've had that name on several -- it's a common first
+name. I'm not familiar really on who that is.
+0. What about
+do you know who
+is?
+Is that a name you ever heard?
+A.
+Yes.
+Works up in the New York office or something?
+A.
+Yes.
+Have you ever spoken with
+personally?
+A.
+Yes.
+Do you know what
+she does for Jeffrey Epstein,
+if anything?
+A .
+I don't know exactly what her role is.
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+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.
+You talked to all of these individuals at some
+point in time,
+either on the phone or in person, right?
+A.
+Yes.
+And you don't know whether they play a role in
+JeffIey Epstein's life, of if they do, what they do?
+A.
+Exactly.
+And how do you decide who you're going to call
+for what reason?
+A.
+For example? Can you be more specific?
+0.
+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.
+Have you ever called her?
+A. I think, yes, I've called her, sure.
+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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+Okay.
+So you're calling her related to
+Jeffrey Epstein?
+A.
+Sure.
+Okay.
+So you know that she plays some role in
+some
+aspect of Jeffrey Epstein's life, whatever that is?
+A.
+Right.
+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. CRITION: Form; argumentative.
+BY MR. EDWARDS:
+I mean, you do know that these people are
+somehow involved with him, whether socially or
+business-wise oI 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. CRITION: Object to the form. You said
+"these people."
+BY MR. EDWARDS:
+I'm talking
+about
+That's
+somebody
+you called before,
+right?
+A .
+Sure.
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+What would be a reason you called
+?
+MR. CRIIION: 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:
+That's funny that you used the
+exact same
+words that Mr. Critton wants you to use.
+MR. CRITION: It's what he said two hours ago.
+BY MR. EDWARDS:
+•. 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?
+I haven't seen her in some time.
+O. 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.
+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.
+All right. Do you know
+the number
+MR. CRITION: 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:
+Do you know that number?
+A .
+Yes.
+0 -
+What is that number?
+A.
+That's my cell phone.
+Okay. Is that still your cell phone?
+A .
+Yes, sir.
+O. All right.
+I'm going
+to show you two
+documents here of 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
+remember
+making
+the phone call?
+is does he
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+BY MR. EDWARDS:
+reading the message?
+A.
+Q. Do you remember making that phone call after
+Let me look at the date here. Okay. March.
+MR. REINHARI: The question is, do you
+remember making the call?
+THE WITNESS: Okay, let me.
+"Person for the
+cal will be here in 15 minutes to drop off foam and
+papers." I don't know.
+BY MR. EDWARDS:
+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. REINHARI:
+So the answer is you don't
+recall?
+THE WIINESS: Yeah, I don't recall.
+BY MR. EDWARDS:
+If you don't remember, that's fine.
+(Plaintiff's Exhibit Nos. 2 AND 3 were marked
+for identification.)
+BY MR. EDWARDS:
+0.
+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. CRIIION: What's the date?
+MR. EDWARDS: March 19th.
+MR. REINHARI: The question is, do you
+remember the call?
+THE WIINESS: "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:
+"Show"?
+A.
+"Show up the water" --
+MR. REINHARI: "On the water."
+THE WIINESS:
+"On the water
+and at the
+center."
+BY MR. EDWARDS:
+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
+--
+0.
+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 of, you know,
+anything to do with, you know, that moves.
+So
+I mean,
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+I...
+0.
+Okay.
+When you say "you help out with boat
+purchases,"
+what
+do you mean?
+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.
+You give your opinion to whom?
+A.
+Io Jeffrey.
+Okay. And
+Jeffrey Epstein obviously, at least
+in your mind, you believe he wants your opinion?
+A.
+Yes.
+0 -
+Okay.
+So boats is
+another thing that the two
+of you have discussed?
+A.
+Yes.
+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.
+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.
+0.
+okay.
+So aside from being a pilot -- which
+throughout this entire deposition I believe your
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+October 15, 2009
+122
+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 of 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. REINHARI: Let me object to form. He also
+told you he installs the audio and video equipment
+before.
+MR. EDWARDS: Correct.
+THE WIINESS: 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
+BY MR. EDWARDS:
+on boat purchases.
+Q. okay.
+A. Having the knowledge of aviation and things
+that move quite fast. So I
+have consulted with him on
+boat items.
+How many boat purchases
+are you aware of
+Jeffrey Epstein making in the
+time period that you've
+known him?
+A .
+Two of
+three.
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+And has he consulted with you on each of those
+purchases?
+A.
+Not every one of them, no.
+Does he own any boats now that you're
+aware
+of?
+A.
+I don't know if he owns them or not.
+Okay. Do you know of any boats that he
+controls or maintains?
+A.
+Himself or?
+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.
+Do you know of any boats that he is the person
+with the most
+control
+over?
+A.
+Yes.
+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.
+0.
+Okay. Do you know
+when
+he made
+that purchase?
+A.
+Eight years ago, seven
+years
+ago. It was
+a
+while ago.
+A .
+Is that something you had had input in?
+Not on that one specifically, no.
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+0.
+Is there any other boat that you know of
+Jeffrey Epstein being the primary
+user of of 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 of 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.
+But your sole responsibility of your sole
+obligation that you have
+ever
+had
+with Jeffiey Epstein
+relative to boats is just giving
+some opinions about the
+boat?
+Mm-hmm.
+Is that yes?
+A.
+Yes, yes.
+Okay. All right.
+Has he ever
+given you his
+opinions about boats?
+A.
+Sure.
+We've discussed it back and forth.
+Other than boat conversations, have you ever
+talked other conversations,
+such
+as --
+A.
+Cars.
+Okay. How about such
+as -- have
+you ever
+known Jeffrey
+Epstein
+have a girlfriend, somebody
+you
+consider a girlfriend?
+A .
+No.
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+O. In the 18 years and all the travels you had
+with him, do you know anything about Jeffrey Epstein's
+sex life?
+A.
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
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+No.
+Do you know who he has sex with?
+A.
+No.
+e.
+A.
+Do you know if he has sex with anybody?
+I don't know.
+Do you know if he's ever had sex on the
+airplane while you've been piloting it?
+A. I have no idea.
+O. Ihat'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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+24
+25
+-- and the use of a company car?
+A.
+e.
+A.
+Yes.
+That's it?
+A.
+(Nodding.)
+Okay.
+Yes, I'm sorIy, yes.
+And the flight to Miami that was
+recently
+taken, other than Jeffrey Epstein and
+was there anybody else on that flight?
+A.
+No.
+How long -- did you also fly them back from
+Miami to Palm Beach?
+A.
+No. He drove back.
+0.
+A.
+him back.
+When you say "he drove back," who drove back?
+Well, I assume he drove back. I did not fly
+0.
+When's the next time you saw him again?
+A .
+I would only be guessing. A week later, I
+mean.
+Okay. And was that in Palm Beach County when
+you saw him the next time?
+A.
+Yes, sir.
+0.
+Do you know
+of him leaving
+Palm Beach County
+in the last two years
+any other occasion?
+A .
+No.
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+0.
+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.
+What's the Sikorsky plant?
+A.
+That's where they build the Sikorsky
+helicopters. It's in Palm Beach County.
+And when was that?
+A.
+Probably a month ago, I'm guessing.
+For what purpose?
+A.
+They gave us a tour at
+a facility.
+e.
+Who's they?
+A.
+Sikorsky.
+And who requested the tour of the facility?
+A.
+They offered it to
+our flight department.
+And who went?
+A.
+Jeffrey, myself,
+and Igor.
+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.
+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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+October 15, 2009
+128
+but they're corporate documents.
+So you'd have to
+request it from Mr. Critton, who I understand
+represents all the corporations.
+THE WIINESS: Yes.
+BY MR. EDWARDS:
+0.
+What's the corporation that the document was
+prepared for?
+A.
+Meaning who -- what, like Air Ghislaine, the
+owner of the helicopter?
+Yes, Ail Ghislaine.
+Air Ghislaine?
+A.
+0.
+That's the helicopter.
+And the name Ghislaine is obviously not that
+typical of a name. Is that reference or related to
+Ghislaine Maxwell?
+A.
+e.
+A.
+0.
+facility?
+I would assume.
+I have
+no knowledge.
+Nobody's ever told you that?
+Nobody's brought it up.
+Okay. And how long were you at the Sikorsky
+A.
+Three hours, four hours.
+And what time of day
+was this?
+0.
+A.
+Nine in the morning. Nine, I think, and we
+returned at one,
+something
+like that.
+And
+the
+PUIPOse
+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.
+Do you know what Jeffrey Epstein does for a
+living for business today, these days?
+A.
+No.
+Do you know of have you ever been to the
+Florida Science Foundation?
+A.
+Yes, sir.
+And do you know what the Florida Science
+Foundation does?
+A.
+Not exactly.
+A .
+Well, generally?
+NO:
+I don't.
+I mean,
+really, I don't.
+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, of 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 --
+0 -
+Why did you go there?
+A .
+Talk about airplanes.
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+Talk to who?
+A.
+Jeffrey.
+Jeffrey just happened
+to be
+at i
+the Florida
+Science Foundation?
+A.
+Yes.
+0.
+How did you know that he was going to be at
+the Florida Science Foundation?
+A.
+He called me and told me.
+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.
+And did he have an office there?
+A.
+Yes.
+So this is -- when you walked in, this is the
+place that's right next to Jack Goldberger's office?
+MR. CRIIION: Form.
+THE WIINESS: Yes.
+BY MR. EDWARDS:
+And you walk in and there's a reception desk
+right there?
+A.
+Yes.
+0.
+Is that where you talked or did you talk
+somewhere behind that reception desk?
+A .
+Behind the reception area.
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+Back in his office?
+A.
+Yes, sir.
+What was that conversation?
+A.
+Give me a time frame. I mean,
+I've been there
+several times.
+Okay. How many times do you think you've been
+to the Florida Science Foundation?
+A .
+Iwenty, thirty. I mean...
+Q. Well, the Florida
+Science Foundation's
+only
+been around since late 2007; is that right?
+MR. CRITION: Form.
+BY MR. EDWARDS:
+Something around that?
+A.
+I don't know exactly.
+All right. So in
+the last 20 years -- in the
+last couple of years you've
+• been there
+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
+probation
+or that he was --
+A.
+No.
+0.
+-- any part of the criminal
+investigation?
+A .
+No, not at
+all.
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+What was the purpose of the conversation?
+A.
+We were sometimes talking about IVs, 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.
+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
+oI
+got a brochure on a new Samsung-
+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.
+0.
+You would go there for ten or fifteen minutes,
+have a conversation about a TV and leave?
+A.
+Yes, sir.
+0. Why couldn't you have that conversation over
+the phone? What was it about?
+MR. CRITION: Form.
+THE WITNESS:
+If it was
+pertaining to a TV and
+I'd have a brochure, a picture of the IV -- one
+particular IV 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 of the salesperson. So I mean,
+there's a reason to visually show him something
+reference to that.
+BY MR. EDWARDS:
+0. Did you ever communicate with Jeffrey
+Epstein -- you can send him an e-mail, right? You could
+have done that?
+A.
+Yes.
+Io 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?
+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.
+0.
+Okay. How long have you e-mail corresponded
+with Jeffrey Epstein?
+A.
+Probably two years. A year to two years.
+mean, it's fairly -- something we just started doing.
+I
+mean, we'd never done that in the past.
+0.
+Well, in the past he was in jail or have some
+restrictions?
+A.
+The
+restrictions, yes.
+So you you'd see him on the airplane
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+frequently?
+A.
+Exactly.
+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.
+And other times in person?
+A.
+Yes.
+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 --
+Never about the criminal investigation?
+A.
+oh,
+по, по,
+never.
+0.
+Do you know
+what his
+intention is
+or his plans
+are for when he is off probation?
+A .
+No idea.
+Or off community control?
+A. I have
+no idea.
+0. Has
+• her
+ever indicated to you he wants you to
+fly him
+some
+other
+location outside the United States
+to live permanently?
+A.
+oh,
+ПО.
+0 .
+Have you ever flown to his place
+in Paris?
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+A.
+We've landed in Paris.
+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.
+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. CRITION: FoIm.
+THE WIINESS: In Paris, yes, there is one
+person there.
+BY MR. EDWARDS:
+What's his name?
+A.
+Voltzan.
+Because
+I always thought there was
+nobody there.
+Vultzan Cauldron (phonetic)?
+A. I don't know exactly. I would have to 10ok it
+up.
+A.
+A.
+A.
+Have you talked to him before?
+No.
+When you've been in Paris --
+You're
+not going
+to ask why?
+Well, I'm assuming
+he doesn't
+speak English.
+There you go, okay.
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+So I thought there was no need for that?
+A.
+e.
+Paris?
+Okay. I just wanted to see.
+Where do you stay when Jeffrey Epstein
+is
+in
+A .
+A hotel.
+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.
+And in New York, you have an apartment that he
+sets you up at, fight, the 301?
+A.
+Yes, I have a place I could stay.
+0 -
+And in St. Thomas?
+A.
+Hotel.
+And in Paris you stay at a home?
+A.
+(Nodding.)
+O. 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. CRITION:
+Form.
+THE
+WITNESS: Name the
+list that you've
+stated.
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+21
+22
+23
+24
+25
+BY MR. EDWARDS:
+9. The Manhattan house.
+A.
+Yes.
+O. Mansion or whatever we want to call it, the
+ZorIo Ranch, the island of St. James, the Palm Beach
+house.
+A.
+Mm-hmm.
+And the Paris place.
+A.
+Ihat"s all I'm aware of.
+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.
+O. 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. CRITION: Form.
+THE WIINESS: Absolutely not.
+BY MR. EDWARDS:
+I'm the first person to ever even imply that
+to you, right?
+A.
+A list, yes, you are.
+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. CRIIION: Form to the last question.
+BY MR. EDWARDS:
+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. CRIIION: Form.
+BY MR. EDWARDS:
+Okay. Have you ever read some of the
+complaints that have been filed against him in the
+various courts, whether state court
+against Jeffrey Epstein?
+federal court,
+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.
+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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+21
+22
+23
+24
+25
+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. CRIIION: What's the question?
+THE WITNESS: Please repeat.
+BY MR. EDWARDS:
+O. 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.
+okay.
+And it indicates a fleet of motor
+vehicles?
+MR. CRITION: Wait a minute. He said right,
+is that we talked about it, as distinct from him
+knowing one way of another.
+THE WIINESS: What's the question?
+BY MR. EDWARDS:
+e.
+A.
+Do you know that he owns those things?
+I do not know that he owns them.
+Do you believe that he owns those things?
+MR. CRIIION: Form.
+THE
+WITNESS: I would be guessing, so...
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+24
+25
+BY MR. EDWARDS:
+knowledge?
+Q. What does the company NES, LIC, do
+to your
+A. I have no idea.
+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, siI.
+If anything?
+A .
+Correct.
+Have you ever heard that that company
+generates money through sex trafficking
+of young
+girls?
+MR. CRITION: 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.
+Ever heard
+that he has had sex or sexual
+relationships with many minor girls, some as young as 12
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+25
+years old?
+MR. CRITION: Form.
+THE WITNESS: No.
+BY MR. EDWARDS:
+Never?
+A.
+Never.
+Have you ever seen any photographs in any of
+his homes depicting young-looking
+girls engaging in sex
+acts?
+A.
+No.
+Or reading directly from the complaint,
+"engaged in lewd acts"?
+A.
+No, absolutely not.
+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.
+Sometimes we're talking about a 50,000 square
+foot house?
+A.
+Exactly.
+In Manhattan?
+A.
+It's pretty big.
+okay.
+Have you ever
+looked
+at any
+of his
+computers
+foI
+any reason?
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+A.
+No.
+I know that you helped set up some of the --
+A.
+Computers are not my expertise.
+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.
+Have you ever read the complaints against him
+that indicate that'g
+what he
+does
+on a daily basis?
+MR. CRITION: Form.
+THE WIINESS: No.
+BY MR. EDWARDS:
+O. 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. CRITION: Form.
+THE WIINESS: 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. CRITION:
+Form.
+BY MR. EDWARDS:
+0 .
+Have you ever -- anybody ever
+questioned you
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+October 15, 2009
+143
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+about that?
+MR. REINHARI: Hold on. The question is have
+you ever been told that fact that he just read to
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
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+you?
+BY MR. EDWARDS:
+Right.
+0.
+A.
+I have never been told that fact.
+Has anybody ever questioned you about your
+possible involvement with helping to facilitate
+MI. Epstein have sex with underage girls?
+A.
+No.
+0.
+When you were questioned by either the police
+or the -- whoever the investigative resource that was
+being used at the time?
+A. Right.
+0. Do you remember who that person
+was
+that was
+questioning you?
+A.
+0.
+A.
+e.
+A.
+Yes.
+0.
+jury
+proceeding?
+No, I don't remember.
+I know you don't know the location where it
+was, but do you remember who they were affiliated with?
+No.
+Was it only one
+time?
+Did you
+also have
+testify before
+grand
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+25
+A.
+No, I did not.
+2. 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 ATIORNEY: I was told to ask for 856.
+MR. EDWARDS: Let's go off the
+record.
+(Off the record discussion.)
+BY MR. EDWARDS:
+O. 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, siI.
+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?
+0.
+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
+50 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. CRIIION: Form.
+THE WIINESS: 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:
+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?
+BY MR. EDWARDS:
+MR. CRITION: Form.
+THE WIINESS: No, sir.
+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.
+"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:
+Have you ever flown his airplane to Palm
+Beach?
+A.
+0.
+Yes, sir.
+Okay.
+Have you ever flown it to New York
+City?
+A .
+Yes.
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+A.
+A.
+A.
+A.
+To Santa Fe?
+Yes.
+To Los Angeles?
+Yes.
+To San Francisco?
+Yes.
+To St. Louis?
+Yes.
+All right. Continuing
+to
+destinations, including Europe,
+have you
+to Europe?
+A.
+international
+ever flown it
+Yes.
+The Caribbean?
+A.
+Yes.
+And Africa?
+A.
+Yes.
+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. CRITION:
+Form.
+THE WITNESS:
+I have no knowledge of
+any of
+that.
+BY MR. EDWARDS:
+0 .
+"He provided accommodations with
+him in order
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+24
+25
+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.)
+You have to a yes or no.
+A.
+I'm soIIy, no.
+"Each time they would travel to one of these
+destinations, the same pattern of sexual abuse would
+OCCUI,
+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.
+0.
+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.
+Okay. Is that something you've ever worried
+about?
+A.
+NO.
+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 1o0k 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.
+0.
+What records would you have to look at to see
+if you took people out of left out of Turkey?
+A.
+I'd have to 100k at the flight logs, but I
+personally don't remember flying into Turkey.
+And would the flight logs coming
+into the
+United States from Turkey
+indicate the names
+of the
+people on the
+plane?
+A .
+They might.
+Okay. Where would I get those
+particular
+flight logs that would have
+that information?
+A .
+Depended upon what year you're talking.
+0.
+We're talking in this
+particular complaint
+between 1998 and 2002.
+A.
+I'm not -- I don't possess those
+passenger
+manifests.
+A.
+Do you know who
+would possess
+those?
+That would be I guess
+MR. REINHARI: Do you know who has them today?
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+THE WITNESS: I do not know who has them
+today.
+BY MR. EDWARDS:
+0. 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.
+0.
+You'le 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 1og
+book is or
+even
+how accurate the passenger manifest is.
+Okay.
+So there
+may be no actual documentation
+indicating a flight leaving
+out of Turkey when, in fact,
+flight may have left out of Turkey?
+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?
+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
+3527-003
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+ever flown to or from in a Jeffrey Epstein airplane?
+A .
+We have flown to Prague.
+0.
+Okay. Have you picked people up in Prague and
+flown out
+of Prague?
+A.
+I don't remember.
+I'm not saying no, you didn't, but --
+A.
+Best of my knowledge.
+-- you don't remember?
+Exactly.
+Best of my knowledge, I don't
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+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
+OI from Asia with Jeffrey Epstein?
+A.
+Yes.
+Or on a Jeffrey Epstein airplane?
+A.
+Yes.
+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. CRITION:
+FOIM.
+3527-003
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+17
+18
+19
+20
+21
+22
+23
+24
+25
+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.
+-- from the age of 12 through the age of 16?
+MR. CRITION: Form.
+THE WITNESS: No knowledge of that.
+BY MR. EDWARDS:
+Ever picked up girls that looked young,
+many
+of whom who spoke no English? Do you ever remember
+that?
+A.
+Zero, do not.
+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.
+Was he ever on
+the
+airplane?
+A.
+He may have been
+on the
+airplane.
+Do you
+remember him
+on the airplane with young
+girls?
+A .
+No, I do not.
+Do you remember Jeffrey Epstein flying
+in to
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+25
+meet with Prince Andrew?
+A. I don't remember. I know that happened, but I
+couldn't be accurate.
+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.
+Io the best of my knowledge, no.
+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.
+0 -
+What politicians would that be?
+A.
+President Clinton.
+Okay.
+Who else?
+A.
+Former president
+of Israel
+-- help
+out with
+the name,
+Barak?
+Ehud Barak?
+A.
+Yes, those are the two that I remember.
+How many times was Ehud Barak on the airplane
+that you piloted for Mr. Epstein?
+A.
+Maybe once.
+And where did that flight pick up and where
+did it go to, to the best
+of
+your memory?
+Best of my memory, it was Palm Beach
+to
+A.
+Teterboro.
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+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+e.
+you know?
+A.
+Where is Ieterboro?
+In New Jersey.
+And what was the purpose of that
+flight, do
+I don't know.
+Was Jeffrey Epstein on the flight?
+I'd have to look at the flight logs to
+A.
+guarantee.
+Anything about that flight stick out in your
+mind?
+A.
+None.
+0.
+Such as a fine needing to be paid because it
+left after 10:00 p.m.?
+A.
+For that was the flight, yes.
+e.
+You remember that?
+A.
+It's coming back to me.
+And do you remember young girls being on that
+flight?
+A.
+A.
+e.
+No.
+All right.
+I remember the fine.
+Do you remember who paid the fine?
+MR. CRITION: 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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+19
+20
+21
+22
+23
+24
+25
+BY MR. EDWARDS:
+0. okay.
+Do you remember who else was
+on that
+flight that left after 10 p.m.?
+A.
+No, I do not.
+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.
+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.
+O. 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.
+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 of
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+16
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+19
+20
+21
+22
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+24
+25
+professional acquaintances of Jeffrey Epstein also
+sexually abusing or exploiting little kids or
+underage
+girls on your airplane?
+MR. CRITION: Form.
+THE WIINESS: No.
+BY MR. EDWARDS:
+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. CRITION:
+Form.
+THE WITNESS: You said it was hypothetical?
+BY MR. EDWARDS:
+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.
+Sure.
+Well, a hypothetical question is a
+legal question that I'm allowed to ask.
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+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Okay.
+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. CRITION: 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. CRITION: Exactly. It's an argumentative
+question.
+MR. EDWARDS: I'm not going to argue with you
+about it.
+MR. CRIIION: You're arguing with him about
+now.
+MR. EDWARDS: No, I'm asking him the
+hypothetical.
+BY MR. EDWARDS:
+0 .
+Can you answer that?
+Would you have continued
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+17
+18
+19
+20
+21
+22
+23
+24
+25
+to be a pilot for somebody who's traveling to and from
+destinations
+with the goal of having sex with underage
+girls?
+MR. CRITION: Form.
+THE WIINESS: It could be any person. It
+doesn't have to be Jeffrey Epstein, then, right?
+BY MR. EDWARDS:
+True.
+A.
+No, I wouldn't pilot an
+airplane
+if there was
+wrongdoing going on.
+That you knew about?
+A.
+That I knew you about, sure.
+Me reading this complaint to you, is this the
+first time you've heard these allegations --
+A.
+Yes.
+-- against Mr. Epstein?
+A.
+Yes.
+0.
+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. CRIIION:
+Form.
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+14
+15
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+17
+18
+19
+20
+21
+22
+23
+24
+25
+THE WIINESS: 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.
+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.
+O. Any of this jog your memory as to who
+i s?
+A.
+No.
+"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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+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+and
+during an entire day?
+MR. CRITION: Form.
+THE WIINESS: I don't remember
+1. 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. CRITION: What was the date?
+MR. EDWARDS: September 2002.
+MR. CRITION: 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. CRITION: 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. CRITION: 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. CRIIION: 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
+times.
+one, two, three, four,
+five, six, seven, eight
+A.
+Okay.
+Seem to be accurate in terms of how many times
+you went to visit him?
+A.
+I thought six, but yes,
+that's...
+0.
+I'll let you review the records and tell me if
+you dispute any of that record. And I'11 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:
+Iwo pages.
+MR. REINHART: Okay.
+BY MR. EDWARDS:
+0 .
+Seem accurate?
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+A.
+Yes.
+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.
+Why did you go with Igor?
+A.
+It just happened
+he
+wanted to see us both at
+the same time.
+There was
+apparent reason.
+0.
+How did you know that Jeffrey wanted to see
+you?
+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.
+0.
+That would have made a phone call to you that
+said --
+A.
+Yeah, to go.
+O. 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.
+0.
+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
+maintenance
+a great deal. You know, we got major
+on the big
+airplane,
+so we discussed that a
+little
+bit.
+And then
+it was
+really just how
+uncomfortable he was there.
+How long did you visit with him on that first
+visit, July 3rd?
+A.
+I think we stayed the full hour.
+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.
+0.
+Okay. So you talked to him for an hour and
+foI
+the most part it was just about the conditions and
+his disappointment with the conditions?
+A .
+Sure, yeah, absolutely.
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+And did Igor talk to him as well?
+A.
+back a little ways again
+Briefly. I mean, not that much. You're going
+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.
+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.
+O. In what vehicle did you drive?
+A. The Hummer.
+Q. That's the vehicle you described earlier as
+the
+company vehicle?
+A.
+Yes, sir.
+Is that a vehicle paid for by Jeffrey Epstein?
+A .
+Meaning?
+Well, is that a vehicle paid for by you?
+A .
+What do you mean "paid for"?
+Did you purchase
+the
+vehicle with your money?
+A.
+I didn't purchase
+that
+one, по.
+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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+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. CRITION: Form; move to strike. Sounds
+like a guess.
+BY MR. EDWARDS:
+Q. Io 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.
+Io my knowledge,
+exactly, yes.
+e.
+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.
+Okay.
+A.
+I have no proof --
+0.
+-- of ownership
+of who it's
+registered
+to
+anything like that?
+A.
+Exactly.
+Is it registered to you?
+A.
+No, no.
+So it's registered to somebody other than you?
+A.
+Exactly.
+Okay.
+A.
+I just drive it, I guess.
+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.
+A.
+Well, I mean, you see where this is going?
+Yeah, I do. It gets further apart, yeah.
+Do you remember what the discussion was on
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
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+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.
+0. 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. CRITION: Let me just object to form to
+the last question.
+BY MR. EDWARDS:
+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.
+O. Well, you know, the first date that he could
+have been in there it 100ks like was T/1/08 and then,
+you know,
+so I guess
+somebody could have seen him T/1 or
+7/2, but
+those
+records were
+never provided to us. You
+see we were provided
+a whole big
+stack.
+A.
+I understand.
+O. The next date I'm going to talk to you about
+is T/12/08.
+A.
+Uh-huh.
+0.
+It 1ooks, again, like it's yourself and Igor
+Zinoviev?
+A.
+Mm-hmm.
+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
+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
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+100 percent, so conversation with somebody that doesn't
+fully understand you, you know, you get lost in
+translation
+little bit. So I don't --
+O. 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.
+Yes?
+A.
+Yes, yes.
+0.
+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.
+-- to
+the jail?
+A.
+Yeah.
+O. 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.
+0.
+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.
+Or whether you were going to stay away from
+those topics?
+MR. CRITION: Form.
+THE WIINESS: We never -- we don't discuss
+that amongst ourselves and/or with Jeffrey in any
+way, form.
+BY MR. EDWARDS:
+O. 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.
+Okay.
+So your discussion was mainly hey,
+let's be upbeat?
+A.
+Yes.
+And that was to,
+in
+essence, maintain his
+spirits or raise his
+spirits?
+A .
+Exactly.
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+18
+19
+20
+21
+22
+23
+24
+25
+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.
+0.
+So --
+A.
+I guess it was
+bad there, that he may have
+changed his mind and wanted
+to have some visitors.
+9 -
+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
+the trip heading to Palm Beach, the last flight.
+0.
+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.
+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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+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?
+Yeah, how many girls were you --
+A.
+Aware of?
+0.
+-- aware of?
+A.
+None. I wasn't aware of any, to be honest.
+The next visit is on J/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. CRITION: 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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+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. EDWARDS:
+Q. Okay. And then before you visited him again,
+the visitors are listed as
+OI
+A.
+Mm-hmm.
+0. Mainly those two individuals. And they list
+as addresses,
+as their residence?
+A.
+Uh-huh.
+Given your previous
+testimony, does that
+surprise you that they list those
+-- that address as
+their residence?
+MR. CRITION: Form.
+THE WIINESS: I've seen them there,
+50 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.
+Did Jeffrey talk to you at any point in time
+about
+?
+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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+17
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+19
+20
+21
+22
+23
+24
+25
+I'm sorry.
+BY MR. EDWARDS:
+Q. I was talking right now about in the
+conversations that you had with him that we've discussed
+with you and him in the jail facility. Did he discuss
+with you
+A.
+No, no.
+Q. Did he talk to you about whether or not you
+should talk to anybody about his
+criminal
+investigation
+OI possible litigation?
+A.
+No, not at all.
+O. The next time you see him is on August 9th,
+2008, at the jail. In that occasion it mentions as his
+visitors that day|
+and
+Larry Viso i. Did you go
+to
+the jail with
+and
+that time?
+A. No. Who was on there?
+Which one are you
+referring to?
+The next one, I tried to highlight them just
+so that --
+A.
+Right, that one.
+MR. REINHARI: 8/9.
+BY MR. EDWARDS:
+8/9/08?
+A.
+One of
+those two we all drove together.
+I
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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.
+0.
+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.
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+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.
+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.
+And that's the Hummer again?
+A.
+Actually, I think we take one of the suburbans
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+at the house.
+Those
+are cars that Jeffrey Epstein owns, to
+your knowledge?
+A.
+I don't know who owns them.
+0.
+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
+S50D sedan. I don't remember the year on that one.
+Okay.
+A.
+There's a Cadillac Escalade.
+Okay.
+A.
+Those
+are his two
+main cars that he would be
+driven in or --
+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.
+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
+convertible.
+0.
+sedan?
+A.
+driving a Mercedes
+Is that different than the Mercedes S500
+Yes, I think it's different.
+When you say they have basically a choice of
+cars to drive --
+A.
+Well, there's cars in the lot there.
+Obviously, they can't get
+in
+one
+of the
+construction workers' cars?
+A.
+No.
+MR. REINHARI: Let him finish his question.
+BY MR. EDWARDS:
+O. 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.
+0.
+vehicle?
+-- but he is the person in control of that
+A.
+Right.
+O. What other vehicles do you think he's
+controlling in Palm Beach?
+A.
+In Palm Beach?
+We've
+named
+the Mercedes S500
+sedan,
+Cadillac
+0.
+Escalade?
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+A.
+Right.
+And I've identified a Mercedes convertible?
+A.
+Right.
+you're aware of?
+In addition to that, are there any others that
+A.
+That he's in control of?
+Yes.
+No.
+A.
+And does the conversation come up between
+and
+and yourself about the reason why
+Jeffrey Epstein is in jail?
+MR. REINHARI: 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.
+Epstein?
+And have you ever been told that
+provides the role of a sex slave to Jeffrey
+That's just her role in life?
+MR. CRITION: Form.
+MR. REINHARI: 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.
+BY MR. EDWARDS:
+MR. CRITION: Form.
+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.
+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. CRITION: Form.
+MR. REINHARI: 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 of 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
+oI 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. CRITION: Can
+we talk for just one minute?
+Because maybe -- can I talk with -- well, I know I
+can talk with Bruce. Let'g 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 WIINESS: 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.
+And you agree that persons who commit a
+violation of those laws should be prosecuted?
+A.
+Persons that do that.
+MR. CRITION: Form.
+BY MR. EDWARDS:
+Yes, persons that do that.
+A.
+Persons that do that, absolutely.
+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. CRITION: Form; speculation.
+THE WIINESS: You're assuming
+that there's
+guilt.
+BY MR. EDWARDS:
+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. CRITION: Form.
+MR. REINHARI: 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:
+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. CRITION: No.
+I think you've got it
+wrong. I'll object to the form.
+MR. EDWARDS: Okay.
+BY MR. EDWARDS:
+O. Then we'll handle the question this way: If
+you were to believe based on information and evidence
+that Mr. Epstein engaged
+sex
+or some foIm
+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.
+CRITION:
+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:
+0. 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. CRITION: Let me put on there, for the --
+if this deposition is not typed -- and we request
+it -- l'd like at least this
+portion where
+MI. 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. CRITION: okay.
+We'll mark this then, so
+you could
+tell
+me where it is, approximately.
+BY MR. EDWARDS:
+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. REINHARI: 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:
+0.
+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.
+It was your understanding that it was illegal
+to talk to Jeffrey Epstein
+about the allegations made
+against Jeffrey Epstein?
+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
+--
+So the reason why you haven't discussed this
+with Jeffrey Epstein is you
+believed it was illegal?
+A.
+Correct, yes.
+Who led you to believe that it was illegal?
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+MR. REINHARI: 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 WIINESS: 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 100ks 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.
+You wouldn't have visited him twice in one
+day?
+A.
+No. I think there's only one visitation per
+day.
+Okay.
+And it 1o0ks 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.
+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
+7
+8
+9
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+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.
+Okay.
+A.
+So I would do my business with him talking
+about airplanes or whatever I had coming up and then
+exit.
+O. And then why did you stop visiting him in jail
+after that September 6th, 2008, visit?
+A.
+I was never
+called
+back to visit.
+okay.
+Well, shortly after that then
+work release?
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+A.
+A.
+Well, that's true.
+Right?
+Yeah.
+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.
+Okay. And in fact, I think you said you saw
+him 20 or 30 times --
+A.
+Sure.
+-- over the last two years, last year and a
+half or so?
+A.
+Yes.
+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.
+Okay. And how frequently would you talk to
+Jeffrey Epstein while he was
+at the Florida Science
+Foundation?
+MR. REINHARI: I'm
+SOIIy, you're talking in
+person or all conversations?
+Because he testified
+he had phone conversations and personal visits.
+BY MR. EDWARDS:
+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?
+Yeah.
+A.
+More specific?
+Sure.
+A.
+Depends upon what's going on that week.
+I mean, is it somebody you would talk to him
+every day?
+A.
+No.
+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.
+And, you know, in any given week, what was the
+typical week like? I mean --
+A.
+How many times?
+Yes.
+A .
+Maybe once in a
+week, sometimes twice in a
+day. I mean, it would vary.
+There
+was
+routine.
+And what would the conversation be?
+A.
+Mostly we discussed audio and video, IVs, 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.
+Okay. And since he's been out of jail and on
+community control of 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.
+0.
+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.
+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 IV
+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.
+0.
+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. CRITION:
+Form; predicate.
+THE WITNESS:
+Meaning?
+Be more specific.
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+BY MR. EDWARDS:
+modifications?
+2. Structural modifications,
+architectural
+A.
+e.
+Starting what date?
+June 30th, 2008.
+MR. REINHARI: 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 WIINESS: Structural changes?
+BY MR. EDWARDS:
+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.
+mean, you're talking
+furniture or?
+0.
+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. REINHARI: Can
+I talk to Mr. Visoski for a
+second?
+MR.
+EDWARDS:
+Sure.
+(Off the record discussion.)
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+MR. REINHARI: 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:
+0. 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...
+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.
+Who made you aware of it?
+A. Nobody. I just walked in the kitchen and
+noticed a bigger
+room than what it was.
+All right. Do you know who Martin Nowack is?
+A.
+No.
+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.
+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.
+O. And do you know whether it was related to
+civil cases or criminal cases or anything else?
+A.
+No idea.
+Do you know where the location was in Miami
+that he was going to?
+A.
+No, I do not.
+0 -
+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.
+Okay. Are you aware of a corporation named
+the ZorIo Trust?
+A.
+I've heard the name.
+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
+heard Zorro Trust. I have
+definition
+of it, but I
+know the name is out there.
+okay.
+Is that a company that you believe is
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+October 15, 2009
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+affiliated or related to Jeffrey Epstein in some way?
+A.
+A.
+I have no definition. I don't know who it is.
+Do you know how you heard about it?
+I don't remember. That's going back in the
+early days of when Zorro existed.
+Who was at the Florida Science Foundation when
+you would meet with Jeffrey Epstein on these meetings?
+A.
+would be there.
+A.
+Anybody else?
+Story would be there
+On
+occasion. That's
+pretty much it.
+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.
+They would just be at the location?
+A.
+Sure, yes.
+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.
+Can anybody
+other than
+Jeffrey Epstein have
+a n
+office at the
+Florida Science Foundation?
+A .
+Not that I know of.
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+October 15, 2009
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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.
+Okay. And do you know -- and did you build a
+house on it then?
+A.
+Yes, I did.
+0.
+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,
+siI.
+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.
+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.
+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...
+Why?
+A.
+Just for an extra car to use.
+0 -
+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.
+0.
+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
+caIs
+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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+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. CRIIION: Hold it.
+BY MR. EDWARDS:
+Is there a reason why?
+MR. CRITION: 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. CRITION:
+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 of to be parked at his house?
+A.
+NO.
+0. 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.
+O. 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.
+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
+IUN
+around because it was an eyesore at my driveway.
+Are you familiar with a Mercedes-Benz SUV
+8
+9
+10
+11
+12
+13
+14
+15
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+25
+1999?
+A.
+A.
+A.
+A.
+Say that again.
+Mercedes SUV, 1999 registered in your name?
+Yes.
+And what car is that?
+That's my car - - my wife's car.
+Does that stay at your house?
+Yes.
+And that's the car that's parked at your house
+now?
+A.
+Yes.
+Are you familiar with a Land Rover,
+Range
+Rover Sport 20083
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+October 15, 2009
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+A.
+Yes.
+Registered in your name?
+A.
+Yes.
+And whose car is that?
+A.
+That's another extra car for the household to
+use
+at Jeffrey"s house.
+And when was that car purchased?
+A. Last year.
+And who purchased that car?
+A.
+It was purchased
+in my name.
+0.
+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.
+0.
+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.
+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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+October 15, 2009
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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.
+Did this conversation happen when he was in
+jail or after he was out?
+A.
+Meaning out on house arrest?
+Right.
+A.
+When you say "out" I think of the Science
+Foundation.
+On work release, so you have to be
+more
+specific.
+0 -
+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 --
+So it was either at a time when he's at the
+Florida Science Foundation of
+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.
+Okay.
+Are you
+aware
+--
+A.
+About eight or nine months ago.
+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.
+O. What does that mean, "a Palm Beach house car"?
+A.
+It's i
+a car that we park in Jeffrey's driveway
+for people to
+Anybody that
+comes to the house can
+select
+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.
+Q. And the funds came
+fIOm Jeffrey Epstein?
+A. Ihey were wired to
+my
+account. I don't know
+exactly what account they
+came
+from.
+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.
+0.
+And what is the
+substance
+of that conversation
+that results
+in a Mercedes-Benz
+2005 being
+placed
+in
+your name?
+A .
+He just
+said we need a fun car
+for the house
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+24
+25
+in Palm Beach.
+But why put it in your
+name?
+A.
+R.
+A.
+I don't know.
+You didn't ask any questions about that?
+No, I didn't.
+Okay. Are you aware of a Jaguar X-Type 2005
+registered in your name?
+A.
+I forgot about that one, yes.
+Whose car is that?
+A.
+0.
+That's a Palm Beach
+car.
+What do you mean "a Palm Beach car"?
+A.
+It's the Palm Beach house car, another Iun
+around for people to use.
+O. And again, that's a conversation that has to
+take place that results in a car being placed --
+registered in your name?
+A.
+Yes.
+okay.
+Now we're talking about several cars
+here?
+A.
+R.
+Yes.
+Ihat are all being placed in your name?
+A.
+Yes.
+0.
+You never at any time ask any questions to
+Jeffrey
+Epstein
+why
+are you placing
+these cars in my
+name?
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+24
+25
+A.
+I did not.
+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.
+You never asked him the question, you just
+agreed to do it?
+A.
+Ihat's correct.
+That goes for the Jaguar X-Type?
+A.
+Yes.
+Are you familiar with a motorcycle,
+Big Dog
+Chopper Motorcycle, 2003?
+A.
+That is mine.
+e.
+YouIs?
+A.
+Yes.
+e.
+Registered in your name for
+a
+good purpose,
+right?
+A.
+e.
+A.
+A.
+Yes, it is.
+At your house?
+Yes.
+You use it?
+Absolutely.
+All right.
+Ford F-250, 2008, registered
+in
+youI name, are you familiar with that?
+A.
+It's not registered in my name.
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+October 15, 2009
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+24
+25
+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.
+0. There should be no documentation from you
+where you would be the registered owner of the Ford
+E -250?
+A.
+What year?
+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
+MI.
+Epstein. I'm a car fanatic,
+for years I've been
+the
+car-shopper. I'm the
+Cal
+fanatic.
+Okay. But these
+caI s
+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.
+0.
+This Ford F250, that's
+a car also that's Palm
+Beach -- as you would
+say
+a Palm
+Beach car?
+A.
+No.
+0.
+That's a car
+that
+stays
+at your
+house?
+A.
+No.
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+October 15, 2009
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+14
+15
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+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+A.
+Who drives that car, Ford E-250?
+That was shipped to St. Thomas.
+For who to use and for what purpose?
+Well, that car should have been put under ISJ,
+LIC.
+What's ISJ, LIC?
+A.
+Little St. James.
+And that's a corporation?
+A.
+Yes.
+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.
+At this point in time, the way that this car
+comes about is through a conversation with yourself and
+Jeffrey Epstein?
+A .
+Yes, yes.
+So to make some representation that this --
+that this corporation LSJ, IIC, you're not sure if that
+has any affiliation with Jeffrey Epstein?
+A.
+I don't have any facts to tie the two
+together.
+A.
+Common
+Yes.
+Okay.
+sense
+would
+dictate?
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+11
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+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. EDWARDS:
+MR. CRITION: Form.
+Again, that's not
+a
+car
+that you use, the Ford
+E-250?
+A.
+No, it's not even here.
+Q. And when you say on St. Thomas, is it on
+actual St. Ihomas, or is it on Little St. James?
+A.
+No, it's on St. Thomas. It's a work vehicle.
+For whom?
+A.
+For the workers, for the island.
+MR. REINHARI: Be careful to answer his
+question. I think his question is, is it on
+St. Ihomas of Little St. James island? Where
+physically is the car,
+if you know.
+THE WIINESS: I don't know for a fact.
+BY MR. EDWARDS:
+Q. It's your understanding it's on St. Ihomas?
+A. Yes.
+And when you say "the workers," what's going
+on on St. Thomas to where there's workers that need an
+E-250?
+A.
+Just moving sand. I don't know the exact
+detail for it.
+0 .
+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.
+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.
+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:
+0.
+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
+I understand that.
+A.
+NO:
+I'm being -- yeah, I didn't.
+MR. REINHARI: There's no question.
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+13
+14
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+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. EDWARDS:
+Q. 34-f00t JVC Powerboat, 2000, owner LSJ, LIC,
+registered to larry Visoski. Do you know that?
+A.
+Yes.
+You knew that that boat was registered in your
+name?
+A.
+It's registered to ISJ. It's Jeffrey's boat
+that we keep here in West Palm Beach.
+And do you keep it at your home?
+A.
+No.
+Do you know that the registration is to your
+home?
+A.
+It's used in my home address, yes.
+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.
+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.
+3527-003
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+October 15, 2009
+207
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+0.
+Okay. And by "Jeffrey's boat, " it was
+purchased with Jeffrey's money?
+A.
+That is correct.
+A.
+A.
+A.
+Do you know how much that cost?
+I think it was 60,000.
+Do you know how much the Ford F-250 cost?
+Iwenty-five, I'm guessing, ballpark.
+Do you know how much the Jaguar X-Type cost?
+11,000.
+Do you know how much the Mercedes-Benz CLK
+8
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+cost?
+A.
+35,000.
+Do you know how much the Land Rover cost?
+A.
+68,000.
+Do you know how much the Mercedes-Benz SUV
+cost, that's yours, right? The Chevy Suburban is yours
+as well?
+A.
+0.
+powerboat, 1999?
+A.
+about originally.
+Yes, I remember how much those cost too.
+Is there another boat, 35-foot Donzi
+That's the one I thought you were talking
+0.
+That's the same boat?
+A.
+0.
+That's the same
+boat.
+Is there any other boat that's registered
+in
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+October 15, 2009
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+your name?
+A. No.
+Did you know that in
+-- let me ask you this:
+Do you have a 2003 Ferrari F75-M?
+A.
+No.
+0.
+York?
+Any reason why the car is registered in your
+name and the asking price is $159,000 being sold in New
+A.
+A.
+That car is not registered in my name.
+If it's registered
+--
+The ad is in my name.
+Why is the ad in your name?
+Because I was trying to sell it.
+Why were you trying to sell it?
+It was Jeffrey's car
+and we didn't want it
+A.
+0.
+A.
+anymore.
+0.
+Why would he put his pilot in charge of
+selling his Ferrari?
+A.
+Because I bought it.
+0.
+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.
+Are you aware of the Zorro Trust winning
+B5 million-dollar Power Ball lottery in 2008?
+3527-003
+Page 208 of 227
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+October 15, 2009
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+A.
+No.
+MR. CRITION: Say that again.
+MR. EDWARDS: The Zorro Irust winning an
+85 million-dollar -- claiming the ticket for
+85 million-dollar Power Ball ticket in 2008.
+THE WITNESS: No.
+BY MR. EDWARDS:
+0.
+Have you ever listed your employer as
+Ghislaine Air in making political contributions?
+A.
+I may have.
+•. Did you know that you had made political
+contributions --
+A.
+Yes, I have.
+-- listing your --
+A .
+I needed a
+company name for that event, and I
+had put Air Ghislaine.
+Q. And NES, LIC wouldn't do?
+A. I didn't think of it at the time.
+Did somebody tell you to use Air Ghislaine
+rather than the company that has been paying you?
+A.
+No.
+You just chose to use an employer that isn't
+actually your employer, not have they ever been?
+A.
+I represent Air Ghislaine, JEGE and Hyperion
+as chief Pilot, so I consider those really the companies
+3527-003
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+October 15, 2009
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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
+foI, 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,
+LIC. I probably
+have used
+that
+twice in 17 or 18 years
+as my employer.
+Do you know
+A.
+I know the name, yes.
+How
+do you know
+her?
+A .
+I've
+seen her on the
+airplane a couple times.
+0.
+Somebody that you know to be involved
+romantically or sexually with Jeffrey Epstein at any
+time?
+A. I don't know that.
+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.
+3527-003
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+Larry Visoski
+October 15, 2009
+211
+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.
+What's your wife's name?
+A.
+Eileen.
+How does she spell that?
+A.
+E - I-L-E-E-N.
+Same last name as you?
+A.
+Yes.
+How long did she work there?
+A.
+A month, maybe.
+And she was answering the phones for the
+Florida Science Foundation?
+A.
+Yes.
+Do you have a good
+relationship with your
+wife?
+A.
+I think so.
+You still don't know what the Florida
+Science
+3527-003
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+Larry Visoski
+October 15, 2009
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+Foundation does?
+A.
+No, because she doesn't.
+She doesn't know what it does either?
+A.
+We never talked about it.
+You never talked to your wife about what she
+did?
+A.
+No.
+MR. CRITION: He knew she was
+answering
+phones.
+BY MR. EDWARDS:
+0.
+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.
+0.
+To your knowledge, you're the only person?
+A.
+I'm the only one I'm aware of.
+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
+3527-003
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+Larry Visoski
+October 15, 2009
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+25
+knowledge at this point.
+What flight records would you have to look at?
+A.
+The passenger manifests.
+Passenger manifests would have the date of
+birth on it?
+A.
+No. It would have a name, but I don't have --
+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. CRITION: Form.
+THE WIINESS: 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:
+0.
+Okay.
+Within the country,
+minors flying
+A. I don't know.
+O. - on a plane?
+A .
+I don't know dates of birth.
+0.
+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.
+could tell you there were times people would get on that
+3527-003
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+October 15, 2009
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+I didn't even know were on the airplane.
+Our focus is
+up front.
+Was there a massage table on the airplane?
+A.
+Which aircraft?
+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.
+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. CRITION:
+0.
+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.
+Okay.
+Was there always a massage table on the
+Boeing or just for a period
+of time?
+A.
+Just for a period
+of time.
+All right.
+And who's responsible for cleaning
+up the airplane after Mr. Epstein
+and/or the guests
+3527-003
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+Larry Visoski
+October 15, 2009
+215
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+leave?
+A.
+Us as the crew.
+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?
+Absolutely.
+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.
+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
+commercial?
+A .
+Yes:
+I have.
+And approximately have you flown
+for four,
+five, six other private individuals over the years?
+3527-003
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+October 15, 2009
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+24
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+A.
+Ihree. I had a short career as far as
+transferring of owners.
+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: Ely 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.
+And it sounds like at least the first owner
+that you worked for asked
+you to do similar things that
+you've done
+fOI MI. Epstein, such
+as take
+care of a boat
+or purchase
+a boat
+maintain the boat?
+A.
+Sure,
+absolutely.
+So your relationship with Mr.
+Epstein with
+3527-003
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+October 15, 2009
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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.
+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.
+0.
+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.
+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
+3527-003
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+October 15, 2009
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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.
+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. i
+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.
+0.
+Okay. By the way, we've been here about --
+fOI
+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|
+1.?
+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. CRITION: I'll break them
+down.
+MR. EDWARDS: It doesn't matter
+to
+me.
+BY MR. CRITION:
+Did i
+you ever meet
+an
+individual by the name of
+3527-003
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+October 15, 2009
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+2
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+5
+?
+A.
+No, I have not.
+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.
+Have you ever heard the name
+Did you
+ever know someone named |
+?
+A.
+Never heard
+that name.
+0.
+In approximately four-and-a-half hours of
+questioning by Mr. Edwards, did he ever ask you about
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
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+A.
+No, he did not.
+In approximately the -- are you familiar with
+an
+individual by the
+name of
+Jane
+Doe (
+)?
+A .
+I never heard that name.
+O. 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. CRIIION: Ihat's all I have.
+MR. EDWARDS: I only have two questions based
+what your testimony just was
+to MI. Critton.
+3527-003
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+October 15, 2009
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+REDIRECT (LARRY VISOSKI)
+BY MR. EDWARDS:
+you've flown for?
+Q. You said you had three other people that
+A.
+Ihree other previous jobs. I'm trying to be
+a s
+accurate.
+Those are private individuals?
+A. That is correct.
+And who are those people?
+A.
+Herb Glimpsure in Columbus,
+Ohio, and Edward
+Seltzer in Miami. And then the other was Iom 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.
+A.
+A.
+Also wealthy individuals?
+Big time.
+And did you know what they did for a living?
+Those I did, yes.
+And did you ever go visit any of those people
+in jail?
+MR. CRITION: Form.
+THE WIINESS: 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.
+3527-003
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+October 15, 2009
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+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. EDWARDS:
+O. Even the one who had trouble with the law, you
+didn't go visit him in jail?
+A.
+No, I did not.
+And did any of them put vehicles or other
+boats of anything else in your name?
+A.
+No.
+0.
+Okay. Any of those people ever deed any
+property or acres
+or anything like that to you?
+A.
+No.
+Did any of those people
+ever hire your wife
+for employment?
+A.
+No.
+Q. And your attorney, is that your attorney paid
+foI 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. CRITION: One follow-up to your question.
+RECROSS (LARRY VISOSKI)
+BY MR. CRIIION:
+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?
+3527-003
+Page 221 of 227
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+October 15, 2009
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+The longest period of time was five years and
+the shortest being two years.
+MR. CRITION: Thank you.
+MR. EDWARDS: We'll order.
+MR. REINHARI: We'll read.
+MR. CRITION: 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
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+
+Larry Visoski
+October 15, 2009
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+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
+Page 223 of 227
+SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
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+EFTA00159705
+
+Larry Visoski
+October 15, 2009
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+CERTIFICATE
+THE STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I, Wendy Beath Anderson, Certified Realtime
+Reporter and Notary Public in
+for the
+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
+OI 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
+Page 224 of 227
+SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
+EFTA_00009899
+EFTA00159706
+
+Larry Visoski
+October 15, 2009
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+DATE:
+TO:
+IN RE:
+October 22, 2009
+LARRY VISOSKI
+#127542
+c/o Robert
+D. Critton,
+via transcript
+JI.
+vs. Epstein
+Please take notice that on Ihursday, the 15th
+of October, 2009, you gave your deposition in the
+above-referred matter.
+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
+corrections that you
+should be noted
+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,
+SULE
+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,
+ESQUIRE DEPOSITION SERVICES, INC.
+515 North Flagler Drive, P-200
+West Palm Beach, Florida 33401
+I do hereby waive
+my
+signature.
+FPR
+LARRY
+VISOSKI
+3527-003
+Page 225 of 227
+SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
+EFTA_00009900
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+
+Larry Visoski
+October 15, 2009
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+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
+2009.
+LARRY VISOSKI
+Job #127542
+3527-003
+Page 226 of 227
+SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
+EFTA_00009901
+EFTA00159708
+
+Larry Visoski
+October 15, 2009
+227
+1
+ERRA I A
+SHEET
+IN RE:
+VS. EPSTEIN
+CR: WMB
+DEPOSITION
+OF: LARRY VISOSKI
+TAKEN: 10.15.09
+JOB NO.:
+127542
+DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE
+PAGE # LINE #
+CHANGE
+REASON
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+Please forward the original signed errata sheet to this
+office so that copies may be distributed
+to all
+parties.
+19
+20
+Under penalty of perjury, I declare that I have
+read my
+deposition
+and
+that it is true and
+correct subject
+to
+any
+changes
+in
+form
+substance entered
+here.
+21
+22
+23
+24
+25
+DATE:
+SIGNATURE OF DEPONENT:
+3527-003
+Page 227 of 227
+SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
+EFTA_00009902
+EFTA00159709
\ No newline at end of file