Larry Eugene Morrison - Volume I

Larry Eugene Morrison - Volume I October 6, 2009 IN THE CIRCUIT CURT Ot mix 15Th JUDICIAL CIRCUIT :N AND POR PALM $111101 COUMTV, acistus VOUR4R 1 92906 1 to 200 Plairkt1ff, Case Up. 50200$CA024051 ELMS AD JIVVAIT OPOIZIK, Mismiseat • DaPCSITICSI OP LARRY ~OS taitRISC44 Tiara Ott «ALF OP Ma PLUIPTIFF October 6, 1009 10;55 a.m. 2:20 p.a. 515 N. Plogler Drive West Palm Beach. PL. 13401-4321 Jennif er Ditorenref , court reporter 3 1 APPEARANCE OF COUNSEL 2 On tense of IM Defendant 3 ATTERBURY.GOLC6ERGER & WEISS BY: JACK ALAN GOLDBERGER. ESO.. 4 250 Australlen Avenue Slate 1400 s Watt Palm Bach FL 33101 6 7 On behalf of the Defendant by telephone BURMAN, CRITTOR LUTTIER & COLEMAN 9 BY: Maimi J. PIKE. ESO.. 515 N. Realer Drive 10 Stale 400 13 FL 33401 12 13 14 On behalf of the sstness: LAW OFFICE OF BRUCE E RBA/HART Is BY: BRUCE E. REINHART, ESQ., Ono Cheripla Center 16 250 S. tentralan Avenue Suite 1400 17 F < 1 10 19 20 21 22 23 24 25 2 APPFARaNCES OF COUNSEL 2 On NMI ot ihe Pa tI LAI.: BOTNSTEIN, ROSENFELDT1 ADLER DY BRACA.EYJ EDWARD& ESO 4 and L14CKAEL WHEELER En. 401 East Las an 13001evard S åM1650 Fo1 LavarOcto FL 13194 9 10 Il 12 13 14 15 16 La 16 ia 20 21 22 23 24 25 On Napa« Plal1N14 Jan Doe 2 Ilaotga 5: WRIMSTEIN HOROWITZ PA BY: JFccY•AO.ARBOL1RAl Nfri2NY4VNULW. 13205 Fkstayne ~lewd Sole 2210 On MIME ce ~Sib Jane Doe 101 aria 102 at ~O« ~mum« °RUCK P A sY: KAINERINE W. EZELL, ATTORNEY-ANUPN 25W. Fis,er Steel °et:eh:1o~ PeINXICINA. by telepaon0 LAW OFF« OF RICHARD %SLUTS. PA BY: FtCHARO %SLUTS. ESQ. 2210 101, Mega N. Stim 404 33451 1 2 3 4 5 6 4 INDEX OF EXAMINATION WITNESS: UM ," EUGENE MORRISON Page DIRECT EXAMINATION By Mr. Edwards *5 CROSS-EXAMINATION 6 By Me. Ezell 9 CROSS-EXAMINATION By Mr. Willits 10 CROSS-EXAMINATION 11 By Mr. Pew *196 12 FURTHER REDIRECT EXAMINATION By Mr. Edwards #199 13 14 6190 1195 L 16 INDEX TO EXHIBITS Plaintiff's 1a Exhibit Description Page 19 1 Twenty-four pages of 'JEGE, Inc., Passenger Manifest." #138 20 21 22 23 24 (Plaintiffs Composite 1 was attached to the original transcript and copies of the transcript.) 25 EFTA01110271 Larry Eugene Morrison - Volume I October 6, 2009 5 1 Deposition of LARRY EUGENE MORRISON 2 October 6.2009 3 4 THE REPORTER: Do you swear the testimony S you're about to give will be the truth, the 6 whole truth, and nothing but the truth so help 7 you God? 8 THE WITNESS: So help me God. 9 -- 10 LARRY EUGENE MORRISON, having been first 11 duly swam, was examined and testified as 12 follows: 13 DIRECT EXAMINATION 14 BY MR. EDWARDS: is O. Tell us your name. 16 A. Larry Morrison. 17 Q. And. Larry, where are you employed right now? 18 A. For JEGE. 19 Q. What's JEGE mean? 20 A. It's the aviation flight department for 21 Mr. Epstein, and my primary Job Is Danklold Reed 22 Aviation. 23 MR. REINHART: Spell It. 24 A. D-A-N-K-J-O-L-D, and then the second word 25 le Reed, R-E-E-D, Aviation. Ws a corporate flight 7 1 You know, it was a business decision made somewhere. 2 O. What does the company do? 3 A. What? The company? It's Just a holding 4 company, I fink, for the aircraft. Its not -- I 5 don't bSeve It to be a money making company or a 6 real corporation. 7 O. You're song `for the aircraft? rm a Interpreting that to mean you're talking about on, 9 aircraft. 10 A. Correct. 11 Q. Does that mean there's one or there's more 12 than one? 13 A. There's more. He owns more than one, but 14 Just one is JEGE or -- 15 O. And the aircraft that he owns, how many of 16 those do you either service and/or ride on? 17 A. I used to. I haven't been — Actually. I 18 stepped back from being physically Involved, Just - 19 now I Just do paperwodt - and It was February of 20 2007. SO I haven't actually physically been on the 21 airplanes other than I will take the Boeing for 22 maintenance. 23 Q. Since it seems tike we've kind of skipped 24 ahead from 2001 to 2007, am I right that your first 2s involvement with Jeffrey Epstein of any way, shape, a 6 1 department. 2 Q. What do you do for him? 2 A. Director of Maintenance. 4 O. Okay, so you maintain his planes — 5 A. Correct. 6 Q. — should something go wrong? 7 A. Correct. Yes. Yep. O. Do you also -- 9 A. For maintenance. 10 O. Do you also fly on his planes? 11 A. On 1W. Epstein's? 12 O. Yes. 13 A. I used to. I was a flight engineer 14 O. Okay. What — 15 A — on his 727. 16 Q. When you fist your company - JEGE? 17 A. Yes. Yeah. it's just initials. It's an 18 LLC or holding company. 19 O. How long has that holding company been around, 20 If you know? 21 A. Since I think it was developed when I 22 came with the airplane - 2001. 23 O. Whose Idea was it for that to come about-was 24 it yours? Was It he? 25 A. Oh, no, no, somewhere - It wasn't mine. 8 1 form was 2001? 2 A. That's correct, yeah. 3 Q. You didn't meet him before that. 4 A. I had met him He was a — He was an 5 associate of my previous bees. 6 O. Who's that? 7 A Mr. Wexner. O. Leslie Wexner? 9 A. Yes. 10 Q. How do you know Leslie Wexner? 11 A. I worked for Limited Stores for 12 years. 12 O. Doing what? 13 A. Essentially the sane thing - aircraft 14 maintenance for their corporate flight department and 15 flight engineering on the 727. 16 O. How many aircraft did Leslie Wexner have? 17 A. Weil, none that I know that he had 18 personally, but the corporation had - the fight 19 department operated - we had three Gulfstreams, two 20 Hawkers, and a 727. Q. What was the name of his corporation that 22 maintained the aircraft? 23 A. For Limited Stores? 24 Q. Yes. 25 A. It was just — It was called Limited - EFTA01110272 Larry Eugene Morrison - Volume I October 6, 2009 9 1 Limited Flight Department. 2 Q. And do you know him personally then Leslie 3 Wexner? 4 A. Yeah, I had met him, of course, you know. 5 I met him. I used to do aircraft completions for 6 him, so which would involve personal meetings. 7 O. When did you first meet Leslie Wexner? a A. 1988 was when I hired on, so I don't 9 remember the month. 10 Q. How did you get that job? 11 A. Through word of mouth and, you know, I 12 worked - I lived in - been in aviation for years in 13 Columbus. 14 Q. Wee I mean, Leslie Wexners an important 15 person. right? I mean. he — 16 A. Correct 17 MR. GOLDBERGER: Form. 18 BY MR. EDWARDS: 19 Q. He's somebody who owns my understanding - 20 Limited, Victoria's Secret? 21 A. Well, he doesn't own them. He's Chairman. 22 you know. 23 Q. Chairman of — 24 A. Yeah. He doesn't personally own .1. It's 25 a publicly held company. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 11 Q. Yes. A. Aircraft technician. Q. Which entails what? A. Maintenance of any or all of the aircraft operated by the flight department and some flight mechanic duties. Q. What kind of airplanes? A. Gulfstreams, Hawkers. Q. How big is the Gulfstream? A. Fifteen passenger -15 to 17. (Mr. Goldberger (tilted.) BY MR. EDWARDS: Q. What did Wexner use the Gulfstream for? A. They were division airplanes, mostly. Q And the other airplane you named - what did he use that for? A. Same. same. Q. Any idea why he had two planes? A. Well, I mean, yeah, we used them - Mafia a loot h wasn't him. It was a large Fortune 500 company. They use them as tools to — You know, Lhnited has control over 60 percent of their manufacturing processes, plus, you know, what.1200 stores, or whatever, throughout all their divisions. I mean, when you say 'limited' ire not 10 1 Q. Where were you prior to any involvement with 2 Leslie Wexner? 3 A. I worked for Red Roof Inn True Sports 4 Flight Department. 5 Q. How did that position lead you to Leslie 6 Wexner? 7 A. Well, it was always known that Limited 8 Right Department was one of the best jobs in 9 Columbus and, actually, several other people that 10 were already there knew me from previous jobs and 11 education - we went through aircraft mechanic, or AS 12 school. together - so when the position became 13 available they pointed to me and - absolutely. It 14 was a fine organization. 15 Q. So did I.Y. Wexner approach you or did you 16 apply to him or how did that work? 17 A. Oh, no, no, no. It's -- No. He wouldn't 18 be involved in that type of activity. You apply to 19 H.R. and you interview with the Director of 20 Operations or the Chief Pilot. You know, he 21 wouldn't. 22 0. So you start with Wexner in 1988. 23 A. Yes. 24 O. What do you do for Nm then? 25 A What did l do for Nm? 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 12 just Limited, ifs Victoria's Secret and it was Express and Lemers and Henri Benders and all of that back then, so. I mean — Q. So — A. — we moved a lot of passengers to keep those stores for the retail business. Q. And by 'passengers." do you also mean clients of his? A. That I don't know. No. Mostly we just dealt with upper echelon, you know, people in the retail businesses from — Q. Such as whom? (Mr. Goldberger entered.) A. Can't even remember names, but it would be -- We would take buyers to Europe in the spring and fall. They would buy samples and piing them back to analyze for marketing. We would hire — We would — Division heads, when they would do store shops and, Real Estate, we take Real Estate out when they were looking for new real estate. Q. While you were working back in '88 — Well, how long overall did you work with Leslie Wexner and/or his companies? • Wen.738 through when I came here in January of '01. EFTA01110273 Larry Eugene Morrison - Volume October 6, 2009 13 1 O. Why the change? 2 A. It offered an opportunity — Well, one was 3 I enjoyed flying - and the 727 was being replaced by 4 a BBJ, which is a two-man airplane, not a three-man 5 airplane - three-pth3t airplane - and It gave me the 6 opportunity to become a Director of Maintenance. and 7 it was a chaflenge. You know, bringing - upstarting 8 an airliner on a private ticket or a VIP ticket is 9 really challenging. and I enjoy the challenge of 10 waking and developing the program and stuff. 11 O. Well my understanding. Leslie Wexner is 12 generally - he's in Ohio, right? 13 A. No, he's got other places. I mean — No, 14 he's like anyone, he's - in his category • he's got 15 multiple homes and — 16 Q. Wee, when you would maintain his aircraft, 17 would that be in Ohio — 18 A. Yes. We were based - 19 Q. or elsewhere? 20 A. We were based at Lane Aviation. 21 MR. REINHART: Hold on one second. You 23 have to let him finish asking the question 23 before you answer. 24 THE WITNESS: Okay. rm sorry. as BY MR. EDWARDS: 15 1 aircraft. I mean, whatever It takes to keep a 2 corporate flight department operating. 3 Q. Did you know back then of his relationship, if 4 any, with Jeffrey Epstein? 5 A. Not Immediately, no. 6 Q. When is the first time that you knew of a 7 regulation or a relationship between Wexner and Epstear A. Would have had to probably be around maybe 9 '98. 199. 10 Q. How do you become aware that they know one 11 another? 12 A. Because Jeffrey. every one — That's when 13 I became a flight engineer on the Boeing, and every 14 once Ina while Jeffrey would ride on the Boeing. 15 that's al that's al l knew. 16 Q. How did it come about that he would ride on 17 Wexner's Boeing? 18 A. They were business associates. I think. 19 Q. As far as you know, they were business 20 associates. 21 A. Right. 22 Q. DM you understand the business relationship 23 between the two? 24 A. Well, I believe it's pubic knowledge 25 that, I think, Jeffrey managed Mr. - some of Mr 14 Q. I'm sorry, have you ever had your deposition 2 taken before? 3 A. No. 4 Q. You definitely never had your deposition taken 5 before while somebody else is trying to eat at the same C time they're trying to ask the questions - that's very 7 bizarre. A. Yes, yes. 9 O. I meant to do this before I got here. But, 10 regardless, II wait until you finish your answer before 11 I ask my next question: you do the same thing. 'U .-huh' 12 or -uh•eh," they kind of look the same on the record. so 13 try to give us a "yes" or *no- or something we 14 understand. 15 A. Alright. 16 Q. If I ask a question that was a bad question or 17 something you don't understand - I've asked bad questions 18 before - say., don't get it." 171 ask a better 19 question. 20 A. Okay. 21 Q. You were working with Lee Wexner. You got 22 the job there starting in 1988. On a day-to-day basis, 23 what would you be doing? 24 A. Maintenance, aircraft maintenance, 25 tracking of aircraft maintenance, cleaning of 16 1 Wexner's funds. 2 Q. Is that something that Mr. Wexner told you? 3 A. No. 4 Q. Is that something that somebody of Mr. 5 Wexner's organization would have told you? 6 A. No. 7 a Is that something that Jeffrey Epstein told 8 you? 9 A. No. 10 Q. Is that just reading articles that speculate 11 as to the business relationship between the two or do you 12 got something more for me? 13 A. No, it's Just - It's speculation and, you 14 know, what I've read, you know. 15 Q. I mean, like you say, to me Ifs common 16 knowledge — 17 A. Right. 18 Q. But it's only because of vital I've read. I 19 don't have a specific person that I could cite to to say 20 that, do you? 21 A. Right. No, Just- just periodicals. 22 O. What's your understanding of the personal 23 relationship, if any. between Wexner and Epstein? 24 MR. GOLDBERGER: Form. as A. Don't know. EFTA01110274 Larry Eugene Morrison - Volume I October 6, 2009 17 Q. Did you ever know of a time — And I maybe 2 asking a question that would just be completely outside 3 of your knowledge. so let me back up. 4 Have you ever stayed at Leslie Wexners house? 5 A. No. 6 Q. Do you know where his house is? 7 A. Yes. 0. Do you know what the address is in Ohio? 9 A. No, I just know the city. 10 Q. Do you know who he lives with? 11 A. Yes. 12 Q. Who is that? 13 A. His wife and children. 14 Q. What's his wife's name? 15 A. Abigail. 16 Q. Abigail Wexner, and he has three or tour 17 daughters, right? 18 A. No. He's got a son, Harry, and two 19 daughters, I think. 20 Q. A son and two daughters. 21 A. I don't know. See, that was back in 2001. 22 I don't know what they have - II they have more kids 23 24 0. Okay. Did you ever hew any information that 25 he was homosexual? 19 1 0. Have you spoken personally with sic. Wexner? 2 A. On business issues, yes. 3 Q. Business issues related to your work on his 4 airplanes? A. Correct. 6 O. Have you spoken to him on any ether issues 7 that don't involve business relationships with his airplanes? 9 A. No. 10 0. Because you're hired basically for that 11 purpose. so that's kind of how you deal wqh him. 12 A Yeah. Ws rm an employee and he's my 13 employer and I only deal with rim, you know, on 14 Issues that Involve maintenance. 15 0. I think I probably know the answer to the nod 16 question. but just in case I dont, do you know any of 17 his personal friends people that he would hang out with 18 on a social level - being Mr. Wexner? 19 A. Through my business ties, yes, yes. 70 O. Who's that? 21 A. rm trying to remember — You have to 72 remember it's been several years. 23 0. right. 24 A. He was Mends with the Tuckermans. 25 a What's Mr. Tuckerman or Ms. *Nachman's naives? 18 1 A. No. 2 0. Being Mr. Wexner. 3 A. No. 4 Q. Any indication to you that he may be s homosexual or bisexual? 6 A. Absolutely not 7 Q. Have you heard any information that he and Mr. 8 Epstein were Involved sexually with one another? 9 A. Oh, no, no. 10 0. Would that surprise you? 11 A. Absolutely. 12 0. And that's only because you know him and you 13 know Mr. Wexner and you don't see the two together. 14 A. Correct. is MR. GOLDBERGER: Finn. 16 A. Wel — 17 0. He — le A. Go ahead. 19 MR. REINHART: If you need to answer. 20 answer the question. 21 A. Yeah. No. I saw him with Sharon, which 22 was his previous girlMend before he met Abigail. 23 0. Right. 24 A. No. There was never any hint or anything 25 that I would even conceive that. 20 A. Ms. — I cant I akvays addressed them 2 by their proper name. 3 0. Cope know what they do? 4 A. They owned an optical company - opticians. 5 They were high school friends from Mr. Wexreesh oh 6 school days. 7 0. In Ohio or New York? a A. He went to high school in Bexley. 9 O. Bexley. Ohio. 10 Has he ever discussed with you how 11 longstanding the relationship Is between himself and Mr. 12 Epstein? 13 MR. GOLDBERGER: Form. 14 A. I don't understand. Can you reptvase it? 15 Q. Wel. you know that at some point In time - 16 You started working with him in 1988. The first time, 17 according to my notes. that you became aware that he was 18 Mends or acquaintances with Mr. Epstein was '98 - 19 almost ten years later. 20 A. Right. 21 Q. After you became aware that there was that 22 relationship, whether business or otherwise, did he ever 23 speak to you about how long he had know, Mr. Epstein? 24 A. Oh, no. no. 25 Q. So as far as you were concerned, 1998. when EFTA01110275 Larry Eugene Morrison - Volume I October 6, 2009 21. 1 you found out there was a relationship with Epstein, it 2 could have very well started then. 3 A. Yes. 4 Q. Aside from aircraft technician and taking care of Pitt Wexner's aircraft back in the '80s and, I guess, 6 early '90s. did you have any other personal involvement 7 wilt) him? 8 A. Just on aircraft completions. 9 Q. And when you would speak with him, would that 10 be over the telephone, at the airport, at his private -- 11 A. It would usually be at the corporate 12 office. 13 Q. At the corporate office? 14 A. At the corporate office. 15 Q. Can you tell me the address for his corporate 16 office? 17 A. No, I cant 18 Q. If I requested that from your attorney. would 19 you be able to get that information? 20 A. Weal mean, I imagine it's public 21 knowledge - wherever - it's at the Limited. 22 Q. And Mars where you would meet him - at the 23 United? 24 A. Yeah. 25 Q. And how Often was - you know, I know that 23 1 O. Who were some of the pilots? 2 A Tim Staley, Jim Taylor. They've had some 3 turnover too. I don't know who all is still there 4 because retail is down. 5 O. Was Larry Visosid a pilot used by Leslie 6 Warner at any time? 7 A. No. a Q. How about David Rodgers? 9 A. No. 10 Q. Are those names you're familiar with? 11 A. Yes. 12 O. Those are names you're familiar with how? 13 A. I flew with them when 1 was flying for Mr. 14 Epstein. 15 Q. So there's no real, other than yourself -- 16 Well, tell me if I'm wrong: I understand that you did 17 some work for Mr. Weiner related to his aircraft and you 18 did some work for Mr. Epstein, which we haven't yet got 19 to, but you did some work for him too. Are there any 20 other people that have that type of relationship with 21 both parties? 22 A. No. I'm sorry, resay that. 23 Q. Okay. You've already told us that you were 24 the aircraft technician for Mr. Werner. 25 A. One of them. One of several, yes. 22 1 we're talking about 15, 20 years ago • how often was Mr. 2 Wexner personally at that location at the Limited 3 offices? 4 A. I have no idea. 5 Q. But any time you needed to talk to him, that's 6 where he would be? 7 A. Yeah, and I usually went to Charlie 8 Hinson. 9 Q. Who's Charlie Hinson? 10 A. He was the president of the stores. He 11 basically was my go-between for these aircraft 12 completions for the design. 13 O. And you mentioned the Gulfstream as an 14 aircraft Did you also serve as a technician for other 15 aircrafts that were owned by Mr. Wexner? 16 A. Right but not Mr. Wexner. They're owned 17 or operated by Limited Stores. 18 Q. Limited Stores? 19 A. Right. Yes. 20 Q. What did you do for them? 21 A. Same - maintenance. 22 Q. Did you ever fly in them? 23 A. On the Gulfstreams in the early days we 24 used flight mechanics, especially on international 25 flights. 24 1 Q. One of them. Then you also have knowledge 2 about Mr. Epstein and some relationship with Mr. Epstein 3 A. Correct. 4 O. Are there any other pilots. aircraft 5 technicians, people like that that you know of to have a 6 relationship with both Mr. Wexner and Epstein? 7 A. No, no. 8 Q. Do you know how Mr. Weimer met Mr. Epstein, 9 A. No. 10 Q. How long - if you started in 1988 - how long 11 did you stay with Mr. Wexner and/or The Limited? 12 A. January of '01. 13 Q. Why did you stop? 14 A. Because what we were taking before, you 15 know, I wanted to continue flying. They bought a 16 BBJ, which is a two-pilot aircraft, and I wanted to 17 continue flying. Mr. Epstein bought the 727 and 18 offered me a position to continue flying and, you 19 know, basically set up the airplane for his flight 20 department because they hadn't had any previous large 21 aircraft experience. 22 Q. I missed something. It wasn't your fault, it 23 was ITWOO. 24 The Gulfstream that you were taking about, 25 did you used to fly that as well as being a light EFTA01110276 Larry Eugene Morrison - Volume October 6, 2009 25 1 technician? 2 A. No, no. 3 Q. Okay. 4 A. You don't have to have a flight - a 5 pilots certificate to be a professional flight 6 ()Vow. I've got a turbo - a flight engineer turbo 7 jet rating, but you don't have to have a commercial ticket as long as you - the FAA recognizes your heavy 9 aircraft maintenance experience. 10 Q. So you're saying that if the FM recognizes 11 your heavy maintenance experience, I'm assuming that 12 means that you understand the ins and outs of airplanes 13 and you can work on them. 14 A. On heavy high performance aircraft, yes. 15 0. Then you can also fly them? 16 A. Sideways as a flight engineer. 17 Q. Explain. 18 A. On the older generation airliners there 19 was three pilots - there's a captain, a first 20 officer, and then the flight engineer is the 21 gentleman that sits sideways and maintains all the 22 systems. 23 Q. When you say. 'sits sideways? okay, I have 24 a — 25 A. Literally, you're physically sideways in 27 1 Q. Do you know why Epstein chose to buy that 2 particular 727 rather than one of the other mum 727s 3 that are made? 4 MR. GOLDBERGER: Form. 5 A. Because It was probably the finest one out 6 there -- 7 Q. Why? A. -- in as honesty. Its got a fully Paged 9 SIC interior with EFTS cockpit, and Limited's 10 reputation on the way that we maintained our aircraft 11 - It's the best one out there. 12 Q. Describe for me the interior - not talking 13 about the Epstein days, we're talking about the Wexner 14 days - describe for me the interior of the aircraft, and 15 keep in mind that I've only been on a commercial aircraft 16 where you don't see the pilots, there's a door, and then 17 everybody, you know, there's just a bunch of seats where 18 everybody sits there. 19 A. Correct. Right. 20 The aircraft — You enter the airplane, 21 It's got forward air stays, which most 727's don't, 21 so you enter the forward door on the left-hand side, 23 the forward entnAvay vestibule, and there's a door on 24 the left, which leads to the cockpit, and then 25 there's a door on the right which leads aft to the 26 1 the cockpit 2 0. So you're not Looking at the people that were 3 flying on the plane and you're not looking at the pilots, 4 you're actually literally sitting sideways. 5 A. I sit sideways at a panel, yes. 6 Q. What's your job? 7 A. Maintain all the aircraft systems - the 8 hydraulics, fuel management, pressurization, 9 environmental controls. 10 Q. That's not done by the pflotS. 11 A. No, no. 12 0. But if you've done that long enough and FAA is 13 aware d your credentials in that respect, then you also 14 could be credentialed to be a pilot as well? 15 A. Well. sure, yeah, yeah. if that's a 16 career choice you wish to take. 17 Q. And was that? 18 A. No, no. I was perfectly satisfied with my 19 position as a flight engineer and Director of 20 Maintenance. 21 0. What year did you say Epstein bought the 727 22 that was once owned by Wexner? 23 A. I don't know when the actual transition 24 took place, but when I came - shortly around the 25 period that I Caine on board in '01, January of '01. 28 1 forward salon. 2 Q. What's the forward salon? Sorry. 3 A Forward seating area. 4 O. And is it set up basically the way that I'm 5 picking ft - in that there are 25 or 26 rows and theyre 6 numbered A through E? 7 A. No, no, it's a corporate configuration. a Q. Which means nothing to me, so help me. 9 A. Picture a 600-mile an hour Winnebago. I 10 mean, it's got conference tables and divans and large 11 first class seating. 12 Q. Any various dividers throughout — 13 A. Yes. 14 Q. — to where there's a VIP room in the back or 15 anything like that? 16 A. ft's compartmentized (sic), yes. 17 Q. In what way? Describe it as specifically as 18 you can. 19 A. There's a forward salon, a mid galley - 20 the galays in the mld - an aft - an aft salon, 21 which is - and then the aft state room. 22 Q. Who designed that plane? 23 A. I can't remember who the actual designer 24 was. it was a Page interior, though. Page Avjet did 25 the installation. EFTA01110277 Larry Eugene Morrison - Volume : October 6, 2009 29 1 Q. Who directed the design of that plane? 2 A. It would have been Mr. Wexner. I mean, It 3 was — The layout has not changed. 4 O. 'The layout has not changed' when you say 5 that, you mean 'from the time that I first got in it and 6 I was under the guise or - "under the employment of 7 Wexner to the time I've been on it since with Epstein, the oon5guratlon is the same." 9 A. Essentially. yes. We removed one chair 10 and one small table that was an annoyance and that's 11 It. but Its identical to what The Limited used. 12 Q. Are there any blocked off areas to where if 13 you're standing in the middle of the plane you can't see 14 certain areas of the plane? 15 A. There are pocket bulkheads. Yeah, there's 16 dividers between the seat:Ina. 17 Q. How big are these cflviders and where aro they? 18 A. Well, there's a divider - the forward 19 door, I told you, on the salon, then there's a pocket 20 door on the forward side of the galley. a pocket door 21 on the aft side of the galley, there's a pocket door 22 between the aft salon and the office, and then 23 there's another pocket door between the office and 24 the state room. 25 O. Have you been on other 727s before that are 31 1 because obviously there's a lot - there's not that 2 3 A Privately owned 727s, but this is — As a 4 matter of fact. The Limited's current BBJ has a very 5 similar floor plan. 6 O. As Trump's? 7 A. No, as the -as ow 727. Q. Who's "our? 9 A. Mr. Epstein's. They didn't change a lot. 10 It's — 11 O. Well, I thought that you had told me that the 12 727 that was once owned by Wexner is the 727 that's armed 13 by Epstein. 14 A. It is, but what I'm saying Is even their 15 current airplane has the same layout - the BBJ. They 16 put the same floor plane in the more modern airplane 17 O. Well, they Mat have to put n there. It 18 was already there, right? 19 A No, no, no. When you buy these aircraft - 20 oven a Gulfstream Mien you buy them it's just a 21 green hull, there's nothing in them, and you can 22 customize your Interior. 23 O. rm soy, we're miscommunicallrg somewhere. 24 and I'm sure its on me. 25 MR. GOLDBERGER: Yes, It is. 30 1 commercial airliners privately owned? 2 A. Yes. yes. 3 Q. Have you noticed similar configurations to 4 where there are this many divicfrig doors or is this one S that has more so than you've seen In the past? 6 A. No, no, this Is pretty atypical (sic). 7 Q. It's pretty atypical? $ A. It's typical. 9 O. It's pretty typical? 10 A. Yes, yes. 11 Q. So what other airplanes - 727s, or other Maier 12 airplanes - have you been on that have these types of 13 dividers? 14 A. Trump. 15 Q. Trump's airplane? 16 A. Yes. 17 O. Why were you on Trump's airplane? 18 A. Weil, I know the crew and, you know, this 19 is a small-knit community. There's not very many of 20 them out there, so everybody in this world knows one 21 another to help one another out as far as — 22 Q. By "there" — 23 A. — b its motiun-wise and stuff. 24 Q By 'there aren't that many of these people out 25 there; you don't mean there's not that many people - 3 2 1 MR. EDWARDS: And I'm taking the dame for 2 it - right away. 3 MR. REINHART: Take that. Ed. 4 MR. EDWARDS: Alright. 5 BY MR. EDWARDS: 6 O. My understanding - and piano correct me when 7 Mt wrong, because I know I am - Wexner has this 727 and 8 he designs it in a certain way. 9 A. Uh-huh. 10 Q. And then you come to work for Epstein — 11 A. Yes. 12 Q. — vitro buys the same 727. Your testimony. as 13 I'm understanding it, is: It's basicaly the same floor 14 plan as Wexners Poor plan. To me, it should be the 15 exact same because he bought the same plane. 16 A. No, he — You're misunderstanding. 17 O. I figured. is A. VVhat I was stating is — You were — Ines 19 answering the question in regards to. "Is this 30 unusual to have this many compartments and closed 21 doors and bulkheads and things?' 22 What I was trying to state was: No, ins 23 not unusual - because The Limited even Sited Ihe 24 floor plan solemn in their old airplane that they 25 sold to Mr. Epstein. They duplicated it in their new EFTA01110278 Larry Eugene Morrison - Volume I October 6, 2009 33 I airplane - see what I'm saying? That's all l was — 2 Q. So they didn't keep the floor plan. They 3 actually took it out and they restructured the floor plan 4 to basically match that old floor plan. 5 A. Well, no. When you -- When you buy a 6 Boeing business jet -- 7 Q. Yes. A. — It comes with nothing inside. It's a 9 tube. Nothing's in there. You design - have 10 designers design your interior and then a fabricator 11 or a facility such as Page Avjet to instal this 12 interior. 13 Q. Right 14 A. What I was Just trying to state was that 15 The Limited liked their old floor plan in the old 16 airplane so well - it worked so well for them - that 17 they duplicated it and had that same interior 113 installed in the new aircraft - same floor plan 19 installed on the new plan. 20 Q. So Epstein didn't buy the exact same plane. 21 He bought the same type of plane. 22 A. Well, more modern. He bought a 737, 23 right. 24 Q. Got it. 25 A. Right 35 1 had a very identical or very like floor plan 2 installed in the new airplane. 3 O. Got it. 4 A. Okay? Sony, ifs a strange business. It's — a O. Tell me if I'm right: Mr. Wexner had a plane 7 that had a floor plan that apparently appealed to Mr. 8 Epstein. so Mr. Epstein bought that plane. 9 A. Correct. 10 Q. Mr. Wexner also liked that plane that he had 11 Just sold to Mr. Epstein, so he built in a floor plan 12 very similar to the one he just sold to Mr. Epstein. 13 A. In his new aircraft. 14 O. Brand new plane. 15 A. Correct. 16 O. Got h. We're on the same page now. 17 A. Alright 18 O. Took us a while to get there. 19 A. Yeah, sorry. 20 Q. I think it was my fault, honestly, but 21 alright? 22 A. It's en unusual process if you haven't 23 been around corporate airplanes. 24 Q. I didn't realize that Mr. Wexner had a new 25 plane. 34 1 MR. REINHART: Hold on. 2 BY MR. EDWARDS: 3 Q. Totally understand now. 4 MR. REINHART: Can you clarify - Mr. 5 Epstein or Mr. Weiner? 6 BY MR. EDWARDS: 7 O. Mr. Epstein bought not Mr. Wexner's plane. B A. No. 9 O. He bought the same type of plane that Mr. 10 Wexner had and modeled the floor plan — 11 A. No. 12 O. -- the same way that Mr. Wexner had it, 13 A. That is not correct. 3.4 Q. He bought, actually, Mr. Epstein — is MR. REINHART: Hold on. Distinguish -- 16 Use names so we're very dear when you're 17 talking about Mr. Epstein and NV. Wexner. okay? IS A. Mr. Epstein bought Mr. Wexner's 727. 19 Q. Okay. 20 A. The actual airplane - bought It from him. 23. Q. Which has a floor plan already in it. 22 A. That we just discussed. 23 Q. Might. The floor plan's in the plane. 24 A Right. Mr. Wexner replaced the airplane 25 that Mr. Epstein bought with a new airplane and he 36 1 A. Yes. 2 Q. That's where I had a problem. 3 How many times have you been on Mr. Wexner's 4 opine 5 A. The new? 6 MR. REINHART: Clarify which one you're 7 talking about. 8 BY MR. EDWARDS: 9 Q. Before you ever met Mr. Epstein. 10 A. I can't say. I mean, over the years? 11 Q. Numerous times? 12 A. Oh, I was his tight engineer. You mean 13 when I was still employed by him? 14 Q. Yes. 15 A. Yes. I was the flight engineer. I 16 don't -- 17 O. So as a flight engineer, every tine the plane 18 leaves the ground, do you leave the ground with it? 19 A. No. We had another engineer also. 20 O. So what percentage of times do you leave the 21 ground in the airplane when the plane leaves the ground? 22 A. For who? 23 O. For Mr. Wexner. 24 A. Probably one-third of the time, because I 25 was also the lead tee,hniclan, so I had EFTA01110279 Larry Eugene Morrison - Volume I October 6, 2009 37 1 responsibilities in the hangar, whereas the other 2 engineer was a full time engineer. a Q. And given the partitions that you've described 4 in this airplane, are you able to see what's going on 5 behind the doors of the various partitions of the 6 airplane? 7 A. If the doors are open or dosed? Q. Closed. 9 A. No. to Q. Do you have any idea what's taking place in 11 there? 12 A. No. 13 MR. GOLDBERGER: Forrn. 14 BY MR. EDWARDS: 15 0. When you're on the plane with Mr. Wexner, was 16 there a time that he had — Well, let me put it this way: 17 When anybody is a passenger on any of these private 1 e planes, should there be logs of the names of the 19 passengers on the planes? 20 A. Not required, no. 21 Q. Are you ever specifically Instructed not to 22 record the names? 23 A, That wasn't part of my duries. That 24 wasn't an engineers task, but -- 25 Q. Do you — 1 2 3 4 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 39 A. There is normally a passenger manifest yet Q. Who creates the manifest? A. Probably dispatch. Q. Dispatch? A. At Limited. Q. DO you know who that Is? MR. REINHART: Can you give a time frame? Do you mean currently or back when he worked there? MR. EDWARDS: I'm talking about back when he worked there. BY MR. EDWARDS: 0. A. Q. A. Q. A. Q. A. 0. A. Q. A. Do you know who that was at dispatch? That would have been Diane Williams. Who does Diane Williams work for? Limited Flight Department. Who does she report to? Tim Staley. Who's Tim Staley? Director of Operations. For who? Limited Fight Department. What does he then do with that information? I don't know. I don't know. 38 1 A. — no. not that I'm aware of. 2 Q. Who is assigned the duty of reporting the 3 names of the people Mx, are going to be transported CO 4 the airpianes? MR. GOLDBERGER: Form. A. Captain. 7 Q. So have you ever been privy to conversations where the captain is told by Mr. Wexner to record all of 9 the names of the people that are going to be on the 10 airplane? 11 A. Can't say. 12 Q. Sometimes? 13 A. I cant — You know, I cant say. I cant 14 remember what our policies were at the time. 15 0. I'm not asking policies. I'm asking: Have 16 you ever been around when the plot was being instructed 17 by Mr. Wexner - back in the late '80s, early 50s - to 14 make sure that you record who's on this aircraft? 19 A. I never heard Mr. Wexner address that, no. 20 Q. I mean. God forbid the airplane crashes, you 21 would We to know who's the on the airplane, right? 22 MR. GOLDBERGER: Form. 23 A. Yes. 24 Q. Is there any way to determine who's on each 25 particular flight In case anytNng happens? 40 1 Q. Have you ever talked to Tim Staley? 2 A. From — Yes, yes. 3 Q. And what do you talk to him about? 4 A. Oh, we're - we're friends. We worked 5 together for years. I mean, I haven't talked to him 6 since the holidays. 7 Q. Do you know where he is now? 8 A. To the best of my knowledge, still 9 Director of Operations at Limited. 10 Q. Do you have a number for him? 11 A. Yes. 12 Q. Can I have the number, please? 13 A. 14 Q. Is ..la— sicrumber? 15 A. That's the Flight Department. 16 Q. That's the best number to reach him at? 17 A. Yes. 18 Q. If I'm going to can him, that's the number I 19 call? 20 A. Correct. 21 Q. And was he always in charge of flight 22 directions? 23 A. No. ho was previously Chief Pilot. 24 Q. He was previously Chief Pilot for Limited? 25 A. Same, yes. EFTA01110280 Larry Eugene Morrison - Volume I October 6, 2009 41 1 Q. And he was promoted. I suppose, to Flight 2 Director? 3 A. Director of Operations. Ifs the 4 department crew. Most small departments don't have directors until they start to grow. 6 Q. And when he was Chief Piot were you 7 affiliated with the Wexner organization? B A. Yes, I was a maintenance technician. 9 O. And when you say somebody keeps flight logs. 10 is it aNrays Ten— is his name Tim Staley? 11 A, Yes. 12 Q. - is it always Tim Staley who does that? 13 A. No. I don't know where they go. honestly, 14 and the system may have clanged. 15 O. Okay. Are you — 16 A. I've been gone since — 17 Q. Are you aware of any FM policies to where 18 they need to know who's on the aircraft whenever it talks 19 off? 20 A. Not under Part 97 0porations, there is 21 not 22 Q. Part what? 23 A. Part 91. 24 Q. What does Pan 91 say, as far as you know,/ 25 A. It's basically souls on board when you 43 I international. The only time we do international 2 would be for Customs and Immigration. 3 O. So if it's an International flight -- 4 A. For Customs and Immigration - for coining 5 and leaving the country. 6 Q. — then they require that names of 7 individualS — a A. It would be names, passports, that kind of 9 stuff - normal. 10 Q. Did you ever do any international flights 11 white employed by The Limited, Victoria's Secret, the 12 whole Wexner group? 13 A. Yes. 14 Q. How many? 15 A No way of knowing. I mean, fm can't 16 say. It's, like I say, years, but. 17 Q. What years would you done it? 18 A. Started Eying as a flight mechanic in 19 '89, and then started flying the Boeing In '99, so - 20 to '01, so '89 tool, basically. 21 (hat Goldberger exited.) 22 BY MR. EDWARDS: 23 Q. S0'89 to '01, if I wanted all of the flight 24 logs, who would I request those from - Tim Staley? 25 A. Dent know. I don't know who — 42 1 Ilea flight plan - that's the only thing you're 2 required to do. When you fie your• flight plan you 3 file souks on board. 4 Q. What does that mean, "souls on board? 5 A. In other words, living bodies on board. 6 In other words, If you have - so it there's an 7 accident and you have four and you're transporting a 8 cadaver, that they go to the accident scene and don't 9 find five bodies - think there were five falsities. 10 Q. So it's your understanding from what you need 11 by report are, "I have five people on board? 12 A Correct, and that's for the flight plan. 13 Q. So there's no reason to say that, have Joe 14 Scfimo on board." 15 A. Not under Part 91, no. 16 Q. That's doing something over and above. 17 A. That's correct. 18 Q. You are aware. though, that there are certain 19 fright plans where they actually name individuals that 20 are on the airplane? 21 MR. GOLDBERGER Form. 22 A. No. 23 Q. I mean, syttve seen that before. 24 MR. GOLDBERGER: En 25 A. No, not on flight plans, no - unless it's 44 1 Q. What does Tim Staley do after he maintains 2 these records? 3 A. I don't know. 4 O. He's never told you what he does? 5 A. No. 6 Q. Certainly they're kept on file somewhere. 7 170 0 a A. I would assume. 9 O. What's the name of the company that owns the 10 airplanes? I know it's affiliated with Wexner and all 11 that, but what's the name of the company? 12 A. Wet there were several companies. I 13 mean, the way corporate aviation flight departments 14 are sot up, they're under holdings companies. 15 O. I'll go with all of them. 16 A. Weil, I daft know. They change. They 17 change sometimes by the year, sometimes I have no 18 idea what they're under now. 19 Q. What were they under back in '88 — 20 A. It was like - al Q. - to the best of your memory? 22 A. They change. I mean, every time we got a 23 new aircraft, or whatever, they changed. They were 24 like Northeast Holding, Southwest Holding, LLC - 25 Wilmington, Delaware. companies, which Is standard EFTA01110281 Larry Eugene Morrison - Volume I October 6, 2009 45 for these, you know. 2 Q. Did Leslie Werner ever tell you that he 3 allowed Jeffrey Epstein to serve in some sod of 4 capacity, representative capacity, for any of these 5 companies? 6 A. No. He would never say that to me 7 anYwaYs• no. 8 Q. What's the first time you ever saw Jeffrey 9 Efletein? 10 A. Can't say. I'm not sure. 11 O. I think you saw him before you started working 12 for him or with him? 13 A Oh, yeah. that's Where I first saw him 14 was when I flew him on The Limited 727. 15 Q. What year do you think that was? 16 A. tt would have had to have been — 17 O. Talking late '80s, early '90s? 18 A. Late '90s. 19 Q. Late '90s? 20 A. Yeah, probably - mid to late Tres. 23. Q Well, I mean, if you're taken over with 22 Jeffrey Epstein in, what, 2001 — 23 A. Correct. 24 O. then you're talking late '90s is the first 25 time you see him? 47 1 A. They were — They were generated, bull 2 don't know, you know, why- what the particular 3 reasoning was for it 4 Q. Do you know if Terry (sic) Staley would have 5 been the one to forward those flight logs to the FAA? 6 A. No, no. no. I They were all just for 7 business use - not forwarded to the FM. 0. Okay. Now — 9 A. The FM doesn't care about flight logs. 10 Q. How did the FM monk.: when that plane took 11 off? 12 A. Flight plans. 13 Q. And was it your understanding that when the 14 plane took off, the FAA was unaware as to who was ever on 15 It? 1.6 A. Pretty much, yeah. They deal tare about 17 names. When you Be flight plans with the flight 18 service station or via electronically, all they care 19 about Is souls on board, contact Info-math:a, flight 20 routing. things kke that. 21 Q. Are there time limits as to when the plane is 22 allotted to take off? 23 A Yeah, usualy — From what point? What do 24 you mean? Time of the day or — 25 Q. Yeah, yeah. time of the day. 1 understand 46 A. Well, mid — I don't know exactly. I 2 can't realty say, really. 3 Q. I won't hold you to It It Is what it Is. 4 Mid to late '90s, if I wanted the Muhl logs 5 that have him on iit on the airplane, who would I 6 subpoena to got those records? 7 A. I have no idea. 8 Q. Are they turned into the FAA, to the best of 9 your knowledge? 10 A. No, the FM doesn't require them. 11 Q. So FAA does not get the flight — Wei, YAM'S 12 the point of even keeping these? 13 A Sometimes I think the IRS — I mean. this 14 is on assumption, I'm not even sure, but mostly for 15 Ike IRS tracking for if you have people that have 16 dual homes, dual statehoods, or whatever. 17 (Mr. Goldberger entered.) 18 MR. GOLDBERGER: Can we take a time out? 19 (Short break.) 20 (Mr. Pike appeared via telephone to 21 replace Mr. Goldberger.) 22 BY MR. EDWARDS: 23 Q. FAA flight logs- do you know why they're 24 generated, how they're generated, if they were generated 25 back In the Wexner days? 48 1 that there's some time where If it's too late they can't 2 take off. right? 3 A. Only where there's a curfew on the airport 4 - not ail airports, no. No, airplanes can fly any 5 time unless that airport has a noise curfew or 6 something, yeah. 7 Q. Did you ever know of Wexner's plane to take 8 off after ten o'clock p.m.? 9 A. Yes. Yeah. 10 O. Were you ever on that plane when it did? 11 A. Probably, yeah, yeah. 12 Q. Were you ever on that plane when there were /3 girls on the plane? 14 A. Describe Define *girls' On the Wexner 15 airplane? 16 Q. Yes. 17 A. There would be ladies and his daughters. 18 I mean — 19 Q. Other than family members. 20 A. There would be business associates. If 21 you're talking young women, yes, business associates 22 from the divisions. 23 Q. Have you ever been on the plane when there 24 were girlfriends of Leslie Wexner? 25 A Only when Abigail - before his - became EFTA01110282 Larry Eugene Morrison - Volume I October 6, 2009 49 I his bride, yes. 2 Q. How about after - 3 A. I mean - 4 O. — she became his — 5 A. — It was Abigail. She was the only 6 girlfriend. 7 O. How about after Abigail? 8 A. No. 9 Q. Have you ever seen sex or sex-related 10 instances occur on Leslie Wexner's airplane? 11 A. Absolutely not. We didn't even have 12 playing cards. He looked at the aircraft as a 13 business - a flying business office. 14 O. When you say *playing cards," what do you 15 mean? 16 A. Playing, you know, to — 17 O. Oh, playing cards. 18 A. Yes. playing cards. 19 O. So every time that you were on Leslie Wexnees 20 airplane. it was used strictly for business? 23. A. Well. I don't know if it was used strictly 22 for business, but there was no, you know, it was -- I 23 don't know what the purpose of the actual trip was, 24 but never saw, you know, anything, you know. 25 Q. Was there ever a time when you were — 51 1 O. Yes, with you on it. 2 A. I can't — I can't say. 3 O. Wet whore do you remember going in it? 4 A. Well, we would normally go to London. 5 Mien, Paris. I mean, mostly fashion areas and 6 business - business areas. 7 Q. When you say "fashion areas," what do you 8 mean? 9 A. Well, retail. I mean, you know, design 10 for clothing and stuff like that. it Q. What was the purpose? 12 A. rm sure it was business. I have no idea 13 what the actual purpose was. I don't — 14 O. Did you get off the plane? IS A. Well, of course. 16 O. What did you do there? 17 A. Go to a hotel, eat dinner, wait to find 18 out when you're going to the next place. 19 O. Were you ever on an international flight o. 20 one of Ph. Wexner's planes that Jeffrey Epstein was also 21. On? A. I cant say. I cant remember. 23 O. Maybe? 24 A. Possioly. 25 Q. Do you remember any specific places that 50 1 MR. REINHART: Hold on. Were you 2 finished? 3 BY MR. EDWARDS: 4 O. I thought you were finished. A. Yeah, I don't understand. I don't 6 understand that question. 7 O. turn going to clarify. Were there ever times 8 when you were on the plane and either Leslie Wexner 9 and/or other Individuals went behind these various areas 10 that you could not see into? 11 A. Yes. Yeah. 12 O. Do you know what they were doing in there? 13 A. Probably sleeping. He would go to bed at le night on the long trips, okay. 15 Q. My time that more than one person went in one 16 of these areas that you would not be able to see into? 17 A. Not that I'm aware of, but my exposure to 18 back there is not that, you know. is limited. 19 O. How many times did you see Jeffrey Epstein 20 ride that plane with Leslie Wexner? 21 A. Not many, but I can't sayexact 22 O. How many International flights do you remember 23 that plane taking? 24 A. Remember -- The airplane Itself taking 25 Internabonar? 52 1 Jeffrey Epstein went what on that plane outside the 2 United States? 3 A. I can't remember. No, no. Like I say. I can't oven remember if we took it for sure. 5 Q. Any time that you remember Jeffrey Epstein 6 being on the airplane, do you also remember there being 7 girls on the airplane along with Mr. Epstein? A. I can't — I can't say. I cant remember. 9 Q. When's the first time you remember seeing 10 Jeffrey Epstein? 11 A. Wet Ilke I say, I dont even remember 12 the year. I can't even pinpoint down to the year. 13 It was after - some tine after I started flying the 14 727, because that's the only exposure. 15 O. Okay. rm not going to ask you at al during 16 this deposition to guess. I thought at sane point in 17 time you told me you remember seeing Jeffrey Epstein. 1$ right? 19 A. Yes. 20 Q. In fact, you work for him now. 21 A. Yes. 22 Q. So at some point In time you saw him and you 23 saw him for the first time. 24 A. Correct. 25 O. When's the first time you remember seeing him? EFTA01110283 Larry Eugene Morrison - Volume I October 6, 2009 53 1 It may not be the first fine you saw him. When's the 2 Mgt time you remember seeing him? 3 A. '99, somewhere in that area. 4 Q. Alright in '99 were you working for Leslie 5 Wexner or were you working for Jeffrey Epstein? 6 A. Leslie Wexner. 7 Q. And do you remember the context in which you saw Jeffrey Epstein? 9 A. It was a ffight. 10 Q. What did Leslie Wexner ever tell you in terms 11 of who Jeffrey Epstein was? 12 A. Never told me anything who Jeffrey Epstein 13 was. 14 Q. Did you ever ask? 15 A. No. 16 Q. Did you ever ask back in 1999 when you saw 17 this guy, '1 wonder what he doer? 18 A. No. 19 Q. Not even curious? 20 A. No. It's not my place. I don't — I 21 don't need to know or want to know what people's 22 associations are. 23 Q. Next time you saw Jeffrey Epstein was when? 24 A. I can't say for sure. 25 O. Have you seen Jeffrey Epstein at Leslie 55 1 Jeffrey Epstein helped to - I think, what you said was - 2 manage Lest* Wexner's money? 3 A. Some of his accounts, yes. I guess. 4 O. Why do you think that? A. From what I've read in periodicals and 6 magazines. 7 Q. You've read in what periodicals and magazines? A. I think it was, what, Vanity Fair Mere 9 was an article a couple years back, three or 10 four years back, and a New York magazine as I 11 mentioned. 12 Q. Why did you read the article? 13 A. Well, obviously it was dealing with the 14 gentleman that I was working for, so out of 15 curiosity, you know. 16 O. Right, because people lend to be curious - 17 A. Right 18 Q. — right? But when I just asked you who 19 Jeffrey Epstein was and the relationship, you said, I 20 have no idea; implying that you weren't curious. But at 21 some point in time you got curious as to who this person 22 is, right? 23 A. Who Jeffrey Epstein is? 24 Q. Yes. 25 A. Well, yeah, when you're working for him 54 Wexner's house? 2 A. No. 3 Q. Never? 4 A. Never. I've never a Have you ever — 6 A. — been to Wexner's house. 7 O. You've never been there? 8 A. No. 9 O. Have you ever known of Leslie Wexner or heard 10 of Leslie Weimer having minor girls or minor boys at his 11 house? 13 A. Oh, no. 13 Q. Have you ever heard of Jeff -- 14 MR. REINHART: I assume, other than his 15 children. 16 MR. EDWARDS: Oh, of course. 17 A, Yeah. No - his children. I'm sorry. 18 Thank you. 19 Q. Have you ever known of Jeffrey Epstein to take 30 underage girls to Leslie Wexner's house? 21 A. No. 22 Q. Do you know how it is that Jeffrey Epstein and 33 Leslie Wexner met each other? 24 A. No. 25 Q. You mentioned eerier that you believed that 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 12 23 24 25 56 and he's In a magazine, you're going to read the article. Q. Okay, so at some point In time, did you Googic Jeffrey Epstein? A. No. no. Q. Have you read the articles about Jeffrey Epstein? A. Lately? Q. Yes. A. Oh, of course, yes, in the newspapers. O. And you're aware of why your deposition's being taken today. A. Yes. of course. Q. And it has something to do not with a case with Leslie Wexner, but a case involvkig Jeffrey Epstein. A. Correct. Yes, of course. Q. When you got this deposition subpoena, did you by any chance try to look up some information on Jeffrey Epstein - who this guy Is? A. No, no. I mean -- Ct. Is there anything -- MR. REINHART: Hold on. Were you finished? Q. Okay. Go ahead. A. No. I mean, other than every once in a EFTA01110284 Larry Eugene Morrison - Volume I October 6, 2009 57 1 whie YR get a Google alert just following the case 2 - just out of interest - because he's still my 3 employer, you know, and you dont want to be 4 blind-sided, but other than that, no — O. When you - 6 A. — I never looked into his financial 7 background or anything look that. I don't know if a you can. 9 Q. When you say a *Goo& alert; that's 10 something that you actually go out of your way and set up 11 on Goode, right? 12 A. Yeah. 13 0. When dld you do that? 14 A. A year ago or so. 15 D. Why did you do it? 16 A. Because I'm net around W. Wexner - or Mr. 17 Epstein anymore. I don't -- 18 O. Well, he was In jail — 19 MR. REINHART: Hold on. Were you finished 20 with your answer? 21 A. I haven't been a full line employee with 22 Mr. Wexner since — 23 MR. REINHART: Epstein. 24 BY MR. EDWARDS: 25 O. Epstein or Wexner? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 59 O. When you say 'fast pace?' how often are you flying? A. Every week - sometimes two, three times a week. Q. And that's by the time that you're working for Jeffrey Epstein? A. Yes. yes. O. Because back in the Leslie Wexner days you weren't flying every day. A. No, no, no, because there was another engineer, no. O. Right A. I had about one-third of the flights. Q. So from 1988, when you start working with Leslie Wexner, through '89 or so, you're not flying all the time, right? A. No. Oh, no, no. Actually, in138. I was. you know, I was - my primary duties were in the hangar - maintenance. Q. Did you enjoy doing that? A. The maintenance part of it? Q. Yes. A. Oh, yeah. that's my background, that's my forte. Q. Is that something that you've gone back to? 58 1 A. I'm sorry — Mr. Epstein. since February 2 ci 2007. 3 Q. Well, a lot of that has to do with him being 4 Incarcerated -- 5 A. No, no. 6 Q. — for a year, right? 7 MR. PIKE: Form. 8 A. No, it was because I wanted to make a job 9 - a career change. 10 Q. Why? 11 A. Because I got tired of flying, being on 12 the road, wanted to be home. 13 Q. Did it bother you that your boss, back in 14 2007, was under investigation? 15 A. Of course. 16 Q. Is that part of the reason why maybe you 17 wanted to make a career change? 18 A. No, no. The reason was the amount of 19 flying that I had been doing and the overnights, and 20 when something's no longer fun, It's time to find 21 something else to do. 22 Q. Why wasn't it fun anymore? 23 A. It's a very fast pace. I wanted to spend 24 time at home. I wanted to get back into strictly 25 maintenance. 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 34 25 A. Q. A. Q. A. D. 60 Yes. When did you go back to that? February of '07. Who are you doing that for? Dankjold Reed Aviation. Say it again. A. Dankjold Reed Aviation. Q. How did you get that job? A. Applied for It and knew the previous Director of Maintenance, who was retiring. Q. Did Leslie Wexner and/or Mr. Epstein help you to get that job? A. No, no ties whatsoever. O. So who Introduces you to Jeffrey Epstein, A. Probably it would have been Larry. The first actual formal introduction? Q. Right. A. Probably would have been Larry Visosk; I knew Larry and Dave when they flew for Giirrichei corporation. Q. Tell me a lithe bit about that. Larry Vlsosid - how do you know him? A. He's the Chief Pilot for Jeffrey and hired me. Q. Well, he's the Chief Pilot now - EFTA01110285 Larry Eugene Morrison - Volume October 6, 2009 61 1 A. Right 2 Q. — for Jeffrey Epstein. 3 A. Right 4 Q. When Is the first time you met Larry Visoski? 5 A. It was before he worked for Jeffrey. He 6 and Dave were flying for a gentleman - Glimcher 7 Corporation. Q. Flying for who? 9 A. Gilmcher Corporation. 10 Q. How do you spell that? 11 A. I think. They were - 12 They had an airplane based at Lane Aviation in 13 Columbus with us. 14 Q. And David Rodgers? 15 A. Yes. 16 O. How did you know David Rodgers? 17 A. Same, from They were in the same hangar 18 we were In. 19 Q. Are you from here? 20 A. No. 21 Q. Where are you from? 22 A. Columbus. Ohio. 23 O. So you're from Columbus, Ohio, and that's also 24 a place where Leslie Wexner lives. 25 A. Yes. 63 Q. How did you learn of Leslie Wexner? 2 A. Oh, I mean, he's very well-known in 3 Columbus, because, you know. bilionaires in central 4 OW, aren't, you know - O. Aren't a dine a dozen, right? 6 A. Exactly, and small guy that made it big, 7 you know, because that's where the name Limited - so e hearsay is - the name limited came from he started 9 with united resources. 10 O. So did you know him before he was married to 11 Abigail? 12 A. Yes. 13 Q. And did you know him to date exclusively women 14 prier to that? 15 A. The only— I knew that he was dating 16 Sharon. 17 Q. Right 18 A. I never flew Sharon, but he dated Sharon 19 for a long time, and then there was, you know, they 20 broke up and then he started dating Abigail. 22 Q. And have you heard any rumors about him dating 22 men as well? 23 A. No, no. 24 O. First time that you're heating about it is me 25 telling you that, right? 62 1 Q. So that was at least convenient for you? 2 A. Oh, yeah. No, it was Yeah. 3 Q. Did you go to college in Ohio as well? 4 A. Yes. Columbus State for my Aviation 5 degree. 6 Q. As your first Job that you had, was that with 7 Leslie Werner? 8 A. Oh, no. I started working for Ohio State 9 University — 10 Q. And then where? 11 A. — in their flight department. 12 Went from Ohio State University to get a 13 short stint, a contract maintenance for a - a 14 contract for NASA at Langley - researcher, and then 15 that was under the direction - that was contracted 16 under oars umbrella for airport research. They had 17 an Aviation Research Department. Then after that Is went to Red Roof Inns - maintenance technician for 19 Red Roof Inns. 20 Q. What was it -Gregory Finns? 21 A. No, Red Roof Inns. 22 Q. Red Roof Inns. 23 A. True Sports Racing. It was Budweiser 24 racing - Indy car team and Red Roof Inns, the motel 25 chain. Then from there I went 10 The Limited stores. 64 1 A. Yeah. 2 Q. So back to Larry Vsosld - you don know him 3 while you're employed with Leslie Wexner. 4 A. Yes. 5 O. You do? 6 A. Yeah. 7 O. How do you meet tin? a A. Met him because their aircraft was In our 9 hangar. The Glimcher aircraft was based in our 10 hangar and got to know him that way. 11 Q. Glimcher is a company owned by whom? 12 A. I don't know if ifs public or not. It 13 was a mall development company not associated with 14 Limited. 15 Q. So what's the conversation between you and 16 Larry Vtsoski? Obviously you all end up working for 17 Epstein, so try to lead me through that. 18 A Wel, I think —1 mean, we got to know -- 19 I mean, you're neighbors in a hangar environment, so 20 you have discussions. 21 Larry was the mechanic. He was also 22 plioUrnechanic on the Hawker for Glimcher, and you 23 kind of form a relationship and a rapport, and then, 24 I believe, anther sold their airplane. I don't 25 lawn Wm Dave and Larry ended up with Jeffrey. I EFTA01110286 Larry Eugene Morrison - Volume I October 6, 2009 65 1 don't know how they found that job, but they started 2 working for Jeffrey then, but they still - 3 O. Did you ask them? 4 A. No, I don't think -- I've never asked 5 them, "How — 6 O. Dld Jeffrey -- 7 A. — did you meet them?" 8 Q. — have a plane in the same hangar? 9 MR. REINHART: Hold on. Let him finish 10 his answer. 11 MR. EDWARDS: I'm sorry. I thought you 12 were finished. 13 MR. PIKE: This is Michael Pike. Let him 14 finish his question because, keep In mind - you 15 finish your question, let him finish his answer 16 - keep In mind, rm on the phone, so I'm having 17 a hard time hearing his response in the 18 background. 19 MR. EDWARDS: You're actually on the other 20 end of the table. Do you want us to try to move 21 the phone closer? 22 MR. PIKE: Yes, that would be good. 23 MR. EDWARDS: 19 do that for you, man. 24 rm sorry. I really did forget that you were 25 here. 67 1 help them with the airplane, get, you know. become a 2 flight engineer - Director of Maintenance - on IL 3 O. So is Larry also an Ohio person? 4 A. Welt he wasn't — I think he was bom arid 5 raised in South Florida and then he was in Ohio for 6 that job. He eyed there for a short period, yeah. 7 for Glimcher. 8 O. And then David Rodgers also? 9 A. They both lived in Columbus, yeah. I 10 mean, I don't know if It was a suburb, but they lived 11 In central Oleo. 12 Q. But the hangar we're talking about is in Ohio. 13 A. Yeah, Lane Aviation. 14 O. You would see them basically on a day-to-day 15 basis because the aircraft that you were a technician 16 fOr — 17 A. Right. 18 Q. — was very close in proximity to the aircraft 19 that they were piloting. 20 A. Yes. 21 Q. They approach you at sane point in time and 22 say what specifically? 23 A. I can't remember the specific 24 conversations, but it was like, you know, asked me f1 25 I would be interested in, if Jeffrey bought the 727 66 MR. PIKE: Not a problem. I've objected 2 to form a couple of runes. I'm not quite sure 3 If that was even heard, but that's neither here 4 nor there. MR. EDWARDS: Wee say the last ten questions you objected to form. I got you. 7 What was my last question. Pike? You don't even remember. 9 MR. REINHART: You asked him conversations 10 he had with Larry Visoski and Dave Rodgers about 11 how they come came to work for Epstein. 12 MR. EDWARDS: Good. 13 A. I really never queried them on how they 14 come to work for Jeffrey. I think Dave was hired 15 first and he brought - this is all speculation - and, 16 I think. he brought Larry on board. 17 O. So as far n you know, however you know, David 18 Rodgers was the first Epstein contact and then Larry 19 Visoskl rode it In. 20 A. The way I understand, yeah. 21 Q. How did you become involved in the 22 three-person train to Epstein? 23 A. When It became apparent that Jeffrey, or 24 Mr. Epstein, was going to buy the 727, Larry 25 approached me, that If I would want to, you know, 68 I being, you know, the flight engineer and help them, 2 you know, get the flight department going, and I told 3 them I would. 4 O. And wily did you say "yes" considering that you 5 had a boss in Leslie Wexner wto vas seemingly pretty good 6 to you fox the last ten years? 7 A. Oh, he's excellent. O. Yes. 9 A No, fine flight department and Mr. Wexner 10 is a line person. 11 Q. Right 1.2 A. The reason being is. you know. I already 13 staled this I think twice before, was that I wanted 14 to be abbe to continue to fly and that would give me 15 the opportunity to continue to fly as a flight 16 engineer and the challenge of starting this airplane. O. Right. I didn't Ignore you. I heard you say 18 that. but then I also heard you say he brought a brand 19 new plane. 20 A. It was ally a two-man airplane -- 21 O. So then he woukl have *- 22 A. — and the modem aircraft could only have 23 two pilots, right 24 O. Got you. I understand. So they approach you with this prospect of the EFTA01110287 Larry Eugene Morrison - Volume I October 6, 2009 69 1 two of them - Dave Rodgers and Larry Visoski - becoming 2 the pilots for the 727 — 3 A. Correct. 4 O. -- that Epstein's buying and. *Hey, would you s like to be a geniis?" 6 A. Right. 7 Q. I mean, that's the gist of it. 8 A. Correct, that would be the gist of it. 9 Q. And your response was? 10 A. Yes, I would - you know, d it came to be, 11 I would consider it. Obviously, you know. salary had 12 to come in and everything else. but I said. 'Yeah, I 13 would be Interested in V 14 O. What's the next conversation that you had and 15 with whom? 16 A. I don't know. There were several 17 conversations, but they wore all with Dave and Larry 18 both, you know, calling back and forth, but. 19 Q. About what? Was it about salary, about the 20 position? 21 A. Salary, what the benefits were. you know. 22 stuff like that. No, the position was pretty much 23 defined. I mean, it's the flight engineer. Director 24 of Maintenance position. 25 O. And the brings us up in cur timeline to 2001, 1 2 3 4 5 6 7 a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 71 A. I don't know. I don't know. Q. I mean, how did she gel on he private airplane? I would imagine strangers don't Just walk on. right? A. Yeah, but I don't know. I don't know what people's associations are together when, you know. O. Okay. A I don't know If it's business association, social associations, or what. Q. How many tinges -- MR. PIKE: Lot me object to the form of that question. MR. EDWARDS: Okay. Noted. BY MR. EDWARDS: Q. Now many times was she on that airplane when It was owned by Leslie Weimer? A. Not many. but I can't give you an exact. Q. Was she ever naked on the airplane? A. Not lhat I'm aware of. Q. I mean, that's something that you would probably remember, right? A. Well — MR. PIKE: Form. A. Yeah. I mean — Q. rm not really trying to be funny. but I would 70 1 you think? 2 A. Correct, that's when I hired on and 3 actually moved to Florida was January 2001. 4 Q. Prior to 2001, had you heard the name S Ghistalne Maxima? 6 A. Yes. 7 Q. How would you have heard Ghislaine Maxwell? 8 A. She had been a passenger on the 727 once 9 or twice. 10 O. The 727, I mean? 11 A. When It was under Limited. 12 Q. Yeah, yeah, that's the point I'm trying to 13 make. I mean, this could get confusing on the record. 14 It's not confusing to me, but on the record k could be 15 because the 727 was Wexner's, then it was Epstein, so 16 you're talking about — 17 A. When It was under Mr. Wexner's control. 18 Q. What year do you think that was? 19 A. It would have been In the late '90s. 20 Again, lice I say, when - probably some time around 21 the time - you know, had to be late '90s — 22 Q. Did she — 23 A. — maybe 2000. 24 Q. Did she seem kke a friend of Leslie Wexner's 25 to you? 72 1 assume I would remember it. 2 A. Not that I'M aware of. 3 O. Do you remember her bringing other gins on 4 the airplane with he? 5 A No. 6 a You remember her getting on the airplane 7 alone? A. I can't say for sure. 9 O. Alright Maybe this will jog your — 10 A. I mean, she was never just alone-alone. 11 like the only passenger or 12 O. Yes. 13 A. No, no, always with - when other people 14 wars on board. 15 O. And you just can't remember whether she 16 brought on board with her a male oaten:ale; is what 17 you're saying, right? 18 A. No. I mean — Restate the question. How 19 did you - 20 O. Sony 21 A. Derma *alone." 22 O. I don't mean, you know. If there's 15 23 passengers and she gets on. rm mom: Do you remember 24 her getting on and being accompanied by- either they 25 look the same car to the airport, they walked the runway EFTA01110288 Larry Eugene Morrison - Volume I October 6, 2009 73 1 up to the airport? Do you remember her being with 2 somebody else? 3 A. If it would have been. would have been Mr. 4 Epstein. never -- 5 Q. How many times do you think Mt. Epstein was on 6 that airplane? 7 A. I can't say for sure - not that many. 8 Q. Less than five? 9 A. That I saw him, yes, probably. 10 0. And how many times of all-- 11 MR. REINHART: Can I just clarify? You 12 mean during the time Mr. Wexner owned the 13 plane -- 14 MR. EDWARDS: Right, right, right. 25 MR. REINHART: — since Mr. Epstein bought 16 the plane. 17 BY MR. EDWARDS: 18 Q. Alright. We're not up to the point, we're 19 about to be. but we're not up to the point yet where Mr. 20 Epstein takes control, so. 21 A. I mean. you have to understand. Mr. - 22 during this Urns period. Mr. Epstein had his other - 23 he already owned his other airplane. 24 Q. How did you know that? 25 A. Wall, because that's what Larry and Dave 1 A. 2 Q. 3 A. 4 Q. 5 A. 6 0. 7 years, 8 A. 75 Maybe mid-'90, early '90. We're talking — He didn't have that plane very long. Between '90 and '93. you're saying. Probably, yes. And between '90 and '93, if we use those you're familiar with the name "Jeffrey Epstein." Not until later when ho bought the 9 Guffstream In - later when he was, you know, like I 10 said, late '90. probably. 11 0. But you're aware that David Rodgers and 12 \floosie' are flying an airplane between '90 and '93 that's 13 owned by somebody. 14 A. Correct. Yeah. 15 Q. But you don't know the name of the person -- 16 A. Correct. Right. 17 0. - that is the owner. We're good. We're on 18 the same page. 19 '88, you start working for Leslie Wexner. 20 A. Right. 21 0. And the first time Epstein is on Leslie 22 Wexnees airplane is approximately when? 23 MR. REINHART: It's asked and answered. 24 BY MR. EDWARDS: 25 0. That you remember. 74 1 were flying - the Gulfstream. 2 Q. But this is something you found out 3 afterwards. 4 A, No, no. I knew that they had gotten a job 5 with him and they were flying the Gulfstream. 6 Q. Alright. Let me clarify this real quickly. 7 You got the job in 1988 with Wexner. A. Right. 9 Q. Right. Larry Visoski and David Rodgers are 10 flying a plane that Is presumably owned by Jeffrey 11 Epstein and/or One of his corporations. 12 A. Not at first. 13 Q. At some point in time. 14 A. Correct. 15 Q. And what point in time do you become aware 16 that that's happening? 17 A. I can't remember exactly when they bought 18 the Gtdfstream. They actually had a Hawker for a 19 short period. I don't know when that was. 20 Q. Was that also owned by Jeffrey Epstein? 21 A. Fora very shed period, and he traded it. 22 Q. The first Epstein plane that you're aware of 23 is that Visoski and Rodgers are on - 24 A. Was a Hawker. 25 Q. -- was approximately what year? 76 MR. REINHART: Asked and answered. 2 A. I can't — The only time I would remember - we've already answered this several times - was in 4 the late '90s when I was actually on the airplane. I 5 have no idea it he vas on previous times Without me 6 there. 7 Q. And when he is on the airplane. is he on the airplane with young girls? 9 MR. REINHART: It's also been asked and 10 answered. 11 A. No. 12 Q. Now we're back to Ghislaine Maxwell. and I 13 beieve your answer - with led me back to these 14 questions that I had previously asked, 'Was ChIstene 15 Maxwell on the airplane that Wexner owned that you know 16 of? - and I think your answer was, 'With Epstein' 17 MR. PIKE: Form. 18 A. !would — I would say if she eras on 19 there, It would be with him. I never knew — I would 10 not think that she would fly on It without hirn. 21 a Do you specifically remember her on the 22 airplane with him? 23 A. Can't say - I can't. 24 Q. On any or these flights that Jeffrey Epstein as and/or Mansell was on. did they fly internationally? EFTA01110289 Larry Eugene Morrison - Volume I October 6, 2009 77 A. I know I brought her back one time from 2 England. I believe - I remember that - from London. 3 O. Brought Maxwell back from London, and was she 4 alone then? 5 A. I cant I can't say. I can't remember. 6 Q. I thought you said that if she was on the • plane it wouldn't have been alone. • A. More than likely she would have been with 9 Jeffrey. 10 Q. So do you think that you brought Maxwell and 11 Jeffrey together back from London? 12 A. More than ikety, but I cant say for 13 sure. I can't remember If he was on that flight. 14 Q. To the best of your recollection right now, as 15 we sit here, is that Maxwell was on the plane and Epstein 16 may or may not have been? 11 A. Correct. That's correct. 18 Q. What year are we taking about and whose 19 airplane are we taking about? 20 A. That would have been when the 727 was 21 Sti Limited - or Wexner. 22 Q. And that would have been around what year? 23 A. 2000, maybe. 24 Q. 2000? 25 A, '99, something Ike that. 79 1 the Court lo be well aware that not all of my 2 form objections are coming through the 3 telephone. 4 MR. EDWARDS: Mike. how about this, of al: 5 of the people Involved, I think that you know 6 you can trust me here: If you say when we read 7 this back that you wanted a form objection. I'll a put it on the record right now you get - how 9 about that? to MR. PIKE: Not a problem. Lt. BY MR. EDWARDS: 12 Q. Alright. Have you ever looked at any of the 13 information from Customs and linrrigratIon related to la fright logs? 15 A. No. 16 Q. If Customs and Immigration is the right agency 17 to take control of these documents, who is it that 18 generates the documents In terms of personnel riding upor 19 this airplane? 20 A. Captain. 21 Q. Who was the captain or who were the captains 22 that you are revere of - and try to give me years, If many 23 of them changed, to the best of your knonledOe - for 24 Leslie Wexner? 25 A. Primarily it would have been Tim Staley. 78 1 Q. So this is almost into the transition 2 A. No, rm sorry. 3 Q. —hie It. 4 A. Let me think on the dates. 5 Q. Okay. 6 A. Yeah, I can't - I can't remember. 7 Q. Late '90s or 2000? S A. Late '90s. 9 O. Who has the flight logs from late Ws? 10 A. I don't know. 11 Q. But that's something that the FAA would have, 12 right? 13 A. No. 14 MR. PIKE: Form. 15 BY MR. EDWARDS: 16 Q. Flying internationally? 17 A. 'don't know if the FAA gets that. It 18 would more - most likely be Customs and Immigration. 19 MR. PIKE Are you guys getting my form 20 objections? 21 MR. EDWARDS: Yes. We got you. 22 MR. PIKE: Thank you. Brad, I Just want 23 on the record that not all of my form objections 24 are coming through, so if we have an issue with 25 this deposition - lam on the phone - and I went 80 1 Jim Taylor, Rob Imlay. 2 Q. Rob? 3 A. Imlay, I-M-L-A-Y, 841 Hammond. 4 Q. Bill Hammond? A. Uh-huh. 6 Q. Bill Hammond tats becomes affiliated with Mr. 7 Epstein too, right? 8 A. Correct. 9 Q. We're going to get to that. 10 Have you ever been a captain? 11 A. No. 12 Q. And when you say that Ws not necessary - 13 unless you're flying internationaRy, I know - but it's 14 not necessary to maintain a passenger manifest that 15 delineates the exact name, where are you getting that 16 information from? 17 A. I know it's not required by the FARs. 18 Q. Howdo you know that? 19 A. Because you can read the Mats, Part 91, 20 FAR 91, Operations. 21 Q. What's "FAR" stand for? 22 A. Federal Aviation Regulations. 23 Q. And what would be the reason not to put the 24 whole name of the person on the airplane? 25 A. I don't know. I— I don't prow. EFTA01110290 Larry Eugene Morrison - Volume I October 6, 2009 81 1 Q. Because later I'm going to show you some 2 lists, and certain people are listed by full name and 3 doers ere listed generically • any Idea why that would 4 happen? A. Unless they just don't know who it Is, you 6 know, just a guess. I mean, you know, you don't want 7 to query somebody and give them the third degree if It's just a guest of the boss that's, you know, 9 riding along or something. 10 Q. Well, she asked you your name before your It deposition and you didn't consider that the third degree 12 by any means. right? 13 A. Right, but — le MR. PIKE: Objection to form. 15 A. But you're approaching your employer's 16 guest. It would be like walking Into his house and 17 salting him, 'Who's siding at the dining room table?" 18 - in a way. See what I'm saying? It's just — You 19 have to maintain 20 0. But — 21 A. — the employee/employer relationship. 22 Q. No, no, no. I guess what I'm saying is: If 23 one of these people is Mohammed Ma. you would like to 24 know it, probably. 25 A. Well, yes. 83 1 A. It would be obvious that these are 2 associates of some form, that they're not, you know, 3 strangers trying to board the airplane. 4 Q. So let's go back to that conversation that you s have In the Oh lo hangar. or whatever it is, with David 6 Rodgers and Larry Visoski when they talked to you for the 7 first time about possibly switching over to Mr. Epstein. A. Uh•huh. 9 0. How does that conversation really go about? to MR. PIKE: Form. 11 A. I don't understand. What do you mean, 12 "How (*Ingo about? 13 0. Did you approach them and say, "Hey, are you 14 going to stay here (OMAN with this airplane? or "DO 15 you have another job for me? or what? 16 A. I think it was just, you know, I believe 17 Larry approached me. I can't remember. II was that 18 long ago. but — le Q. What does Larry say to you? 20 A. I can't remember the exact conversation. 21 Q. I mean, was he not happy where he was? 22 A. Who, Larry? 23 Q. Yes. 24 A. Never said he wasn't. 25 0. How did you know Larry? 82 1 MR. PIKE: Form. 2 A. Yes, yet 3 Q. So any reason why a captain trying to secure 4 the airplane and the people aboard wouldn't take that 5 extra step and try to figure out who's exactly on his 6 airplane? A. Well, when it's - the normal passenger 8 loads are five to ten people, al the very most, and 9 they're all with the owner and accompanying the owner 10 and some of the regular passengers, you know; the 11 likelihood that Mohammed Ma is going to sneak in 12 there and board his plane and ride along is - you 13 know. 14 0. He's willing to play those odds, okay. 15 A. Well, I'm not saying that he's playing 16 odds. rm just stating that the only reason I can 17 think — I don't know. hie never filed those out. is The only reason I can think is he just didn't have 19 the name and didn't want to intrude and ask. 20 a If you were a captain, would you ask who was 21 on your airplane? 22 A. Not if the situation was that It was 23 controlled by the owner and I knew wto the - you 24 know. 25 Q. Okay. 84 1 A. What are you talking about? Why would he 2 not be happy where he was? I don't triderstand. 3 0. Well, he's working for some other corporation 4 that's not non-Epstein owned. 5 A. Oh, that previous corporation sold the 6 airplane. 7 0. Oh, they thd? 8 A. Yeah. He had no choice. They were out of 9 wak. 10 Q So Larry and David were about to be out of 11 work. 12 A. Yes. 13 Q. So they said, 1-ley, we found a new job and 14 it's with this guy Jeffrey Epstein and he's buying that 15 plane. Do you want to be Involved?" 16 A. No, no. There was another airplane in 17 between - two other airplanes. There was a long time 18 between - and I don't know the exact dates and I 19 don't know that I even do know the dates - but there 20 was a time between when they left Gunther before 21 Jeffrey got involved with the 727. 22 Q. So they leave Glimcher? 23 A. Yes. 24 0. Then what happens? 25 A. They somehow - I don't know how - hired on EFTA01110291 Larry Eugene Morrison - Volume I October 6, 2009 85 1 with Jeffrey. 2 Q. They hired on with Jeffrey to pilot the 727? 3 A. No. He had two other airplanes prior to 4 that He had a Hawker that he had for a very short 5 period and then he bought - traded It or sold It. I 6 don't know what he did with it but then he got the 7 Guffstream. 0 Q. So Larry Visoski and David Rodgers were pilots 9 for Jeffrey Epstein when he had the Hawker also? 10 A. Yes. 11 O. And what year are we talking about there? 12 A. I have no idea. 13 Q. Well, if you sign on with him in '91. ifs 14 before that year, right? 15 A. No, no, I signed in '01 - January '01. 16 O. '01. 17 A. I don't know how long they flew for 18 Clincher before that airplane went away and how quick 19 they got on with Jeffrey. I don't know. Somewhere 20 between '88 and 2001. they — 21 Q. During — 23 A. — left GlImther and — 23 Q. During '88 and '01, do you remain in contact 24 with Lacy Visoski and David Rodgers? 25 A. On and off. They eventually moved, you 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 35 87 O. Before your conversation with them abe. • becoming involved with Jeffrey Epstein. A. Yes. O. How? A. Like we discussed. We've been through this already. When they were at Oftener they had an airplane in the hangar. We would see them sporadically and we would talk. O. I'm sorry. bad question. I don't mean on a business relationship. On a social relationship, did yot., hang out with them A. Oh, no. O. outside of this? A. No, no. Q. I apologize. So - and I only asked that question because some years later then you're in contact with them and they asked you to become involved with Jeff Epstein. A. Uh-huh. Q. But that is because of a business relationship solely that you had with them -- A. Oh, yeah. Q. — years before? A. I didn't know them personally. MR. PIKE: Form. 86 1 know, to - moved away from Columbus when they hired 2 on with Jeffrey, so they weren't in the hangar every 3 day. 4 a. Where did they go- do you know? 5 A I think Dave went to New York and Larry 6 went back to South Florida. 7 Q. Do you know why? 8 A. Well, because I think Jeffrey gave them 9 the choice of flying where they would like, I 10 beEeve. I mean, that's — 11 Q. Thais what they've said. 1.2 A There what they've saki. 13 Q. Okay, and Larry chose South Florida, David 14 Rodgers those New York? 15 A. Right 16 Q. And Epstein had a place for them both wherever 17 they wanted to go? 18 A. Well, they owned their oven homes or 19 something. I don't know what their living 20 arrangements were. 21 Q. Did you know Larry Rodgers or David Visoski 22 before this? 23 A. Before? 24 MR. F1KE: Form. 25 BY MR. EDWARDS: 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 88 BY MR. EDWARDS; O. Okay. Alight So in 2001, is that the year that you get a telephone call from one or two of these people? MR. PIKE: Form. A It would be either late 2000 or early 2001. I don't — These transactions don't happen overnight -- O. Yeah. • — buying an airplane. So it could have happened in, you know, November or started talking in November, late, "Well, you know, would you be Interested if Jeffrey gets the airplane or buys the airplane?" you know, to when I actually hired on. O. Did you ever talk to Ghistaine Maxwell - ever? A. After I had hired on, yes. O. After you hired on with Epstein. A. Yes. O. Wel go up to her. So when is it that you hired on with Jeffrey Epstein? A. I think I began in January of '01. O. In January of '01, do you start getting a paycheck from Jeffrey Epstein? A Yes. EFTA01110292 Larry Eugene Morrison - Volume I October 6, 2009 89 1 Q. And is it paid from one of his companies or 2 from Jeffrey Epstein specifically? 3 A No, no - JEGE. 4 Q. JEGE. What is your understanding as to what 5 that Is? 6 A. It's just initials. It's a name. I don't 7 have any idea what it stands for, but rd ask that a B million times. 9 Q. ICs a company that owns something, right? 10 A. I don't know — 11 MR. PIKE: Form. 12 A. — if it even owns anything. I don't know 13 what type of company it is. I don't know If — It's 14 Just a Wilmington. Delaware. Company. 15 Q. What's the bank actors* that it was written 16 on? 17 A I can't remember. I mean, I know rd read 18 - rd See aJEGEn on it, that's all. 19 Q. A New Mexico bank, New York bank, Florida 20 bank? 21 A I have no idea because it's direct 22 deposit. All I would do is Just see if the ainaunte 23 right I don't — I have no idea. I would — I have 24 no idea. 25 Q. What was your communication - direct 91 1 perform 2 Q. On what planes? 3 A. Just the Gulf - just the Boeing. 4 Q. Just the Boeing? 5 A. Uh-huh. 6 Q. Over the years. did you become aware that ho 7 owned other aircraft? A. I knew that he stil had that. 9 MR. PEE: Form. 10 A. He still had the Gulfstream. 11 Q. At the time back in 2001 and we're going to 12 walk through some of his airplanes • he owned the Boernr. 13 727, right? 14 A. Cared. is O. And what other airplanes did he own at that 16 time when you signed on with hlin in 2001? 17 A. The Guifstream. 18 O. Gulfstream is what? 19 A. 28. 20 Q. Do you know who the pilot was for that plane? 21 A_ Dave and Larry, I mean, it's always. 22 Q. Was K always Dave and tarry no matter what 23 plane was being taken out? 24 A. Unless somebody was on vacation or in 25 school and they used contract people. 90 1 communication with Jeffrey Epstein that results in your 2 employment with JEGE? 3 MR. PIKE: Form. 4 A. A conversation result in my — Essentially 5 Larry hired rne. I mean, it wasn't - It wasn't — I 6 didn't really — I may have had one phone 7 conversation with Jeffrey prior to actually being 8 hired and the next time I saw Jeffrey was when I was 9 In Florida with the airplane. 10 Q. What did Jeffrey ask you in that one phone 11 conversation? 12 A. I think he asked me what my current salary 13 was, or something along that line, you know. 14 0. Did he ask you what you were looking for In 15 terms of Salary? 16 A. Yes. 17 Q. What did you tell him? 18 A. I told him to basically — I forget how it 19 went exactly. It ended up being like $117,000. 20 something like that. 21 Q. $117,000 a year? 22 A. Yeah. 23 O. And what were your duties? 24 A. Basically - flight engineer, obviously, 25 but all line maintenance and scheduled maintenance to 92 1 Q. What was the purpose behind having multiple 2 planes - used one for the purpose, one for another - do 3 you know? 4 A. I never could figure that out. 5 Q. Really? 6 A. Yeah. 7 Q. No rhyme or reason why he took one this way 8 and one that way? 9 A. No. He was - pretty mudi once the Boeing 10 got on fine. Now, you know, the Boeing goes down for 11 heavy maintenance. It used to go annually, now It 12 goes down bi-annually, but - so he would utilize that 13 airplane while it was out of service, you know, for 14 maintenance. which sometimes would be four, five 15 weeks at a time, so. 16 Q. And in those cases, then he would use the 17 Gulfstream 29? 1$ A. Yes. 19 Q. Have you been on both planes? 20 A. Yes. 21 Q. We're still talking about 2001. Is that the 22 first time that you're on the 727? 23 A. First time l was on the 727? Wait. I 24 don't know what you mean. 25 Q. After Epstein owns N. EFTA01110293 Larry Eugene Morrison - Volume I October 6, 2009 93 1 A. Yes. 2 Q. And do you remember where you went? 3 A. Very first flight, no, because we didn't 4 fly it imrnedetely. We upgraded some avionics and s did modifications. 6 O. What modifications did he want to that plane? 7 A. Just changed the carpet and some fabrics, 8 upgraded the radar, upgraded the navigation - the 9 flight manifest systems. 10 Q. Did he change the interior at all? 11 A. No. We removed that one smell table and 12 chair - that's it, but we did not really change what 13 you would consider the ROCK plan. 14 0. Now, try to give me a visual appreciation of 15 the inside of the plane. If I'm looking out the cockpit 16 back towards the back of the plane; what am I going to 17 see? 18 A. A door. 19 Q. That's it? 20 A. That's it, yeah. 21 Q. Just an empty room with a door? 22 A. No, no. The door's always dosed. If the 23 door's open you will see the forward salon, and in 24 the forward salon there is a conference table, a 25 high/low table, some divans, and some single seats. 95 1 A. Can't remember the first flight. Like 2 say, It was down fora white - probably - I tNnk if 3 was • had to take at least three to fotr months maybe 4 to get it — Q. And dud you know of him flying on the airplane 6 with girls accompanying him? 7 MR. PIKE: Form. a A. I don't -- 9 0. Back in 2001. 10 A. With gids accompanying him? 11 Q. Yes. 12 A. Yes. 13 O. Where would he pick the girls up from? 14 MR. PIKE: Form. 15 A. I don't know. They would arrive with him, 16 you know, out of Palm Beach or out of New York. I 17 don't even remember where we went the frst time. 18 The first flight was probably New York I think. 19 O. IS it a private airport in New York where you 2o would usually pull into or a commercial airport? 21 A. I thirk the first time we started going up 22 there, I think, we were using White Plains, which Is 23 - actually, It's not a private airport. They ail 24 have some commercial service. It would have been 25 White Plains. I believe, then later we started using 94 1 O. What's behind that? 2 A. The galley. 3 O. The what? A. The kitchen - galley. 5 O. Okay. 6 A. Behind that is the aft salon, which is 7 just two round divans. Q. And? 9 A. After that is the office. which Is a • 10 consists of a credenza and a desk, or divan and a 11 desk and chairs. 12 O. How many of these areas can you close off or 13 partition? 14 MR. PIKE: Form. 15 A. Each one. And after that there's the 16 state room. 17 Q. And in the state roorn • how big is the state 18 room? 19 A. Consists of a queen size bed and two z o single seats. 21 Q. Have you ever been back in the state room? 22 A. Oh. yes. Yeah. 23 O. When's the first time you flew on the airplane 24 with Jeffrey Epstein back in 2001, after he acquired the 25 727? 96 I Kennedy, and the service was so terrible in Kennedy 2 and so expensive we went to Newark. 3 Q. When you would fly Into White Plains or lo 4 Kennedy or Newark, would you always get off of the 5 airplane or would you sometimes stay on and watt for passengers to board? 7 A. I don't understand. 8 Q. Well, when you stop an airplane -- 9 A, Right. 10 O. — sometimes you get off the airplane and you 11 go either through a, you know, through the airport or you 12 go somewhere else, or your option Is to stay on the 13 airplane and not get off and wait for other people to get 14 on before you take off. 15 A. Oh, no. 16 MR. REINHART: I'm sorry, can we clarify 17 the "you"? Do you mean him personally or the 18 people who were passengers on the plane that he 19 was flying? 20 O. I'm talking about you personalty. 21 A. Oh, no, it was rare that we ever did a 22 through flight We would normally go from Point A to 23 Point B, and that was the destination. 24 Q. I assume when he teys the plane initially it 25 was In Ohlo, right? EFTA01110294 Larry Eugene Morrison - Volume I October 6, 2009 97 1 A. Well, yeah, but -- 2 Q. Then you fly to Florida. 3 A. Well, we crewed it to Florida and then it 4 sat at a facility in Florida during negotiations, so 5 it cidn't go directly from Ohio. 6 O. In 2001, when there's still negotiations. 7 where in Florida is the airplane? 8 A. Lake City - Timco, Lake City. 9 O. During the negotiations, does it ever take off 10 or is it grounded? 11 A. No, no, It's grounded, because on a Part 12 91 deviation it has to be under a specific 13 maintenance program, so when it left The Limited, it 14 left that maintenance program, and I had to 15 transition it to the new program. 16 O. This is still sometime in 2001, right? 17 A. Early, yes, yes. 18 O. And then it passes all inspections, I'm 19 assuming? 20 A. Right, right. 21 O. Then you take it to what airport to where 22 It — 23 A. PSI. 24 Q. PBS? z5 A. Here In West Palm. 99 1 O. Who's on the airplane? 2 A. Well, obviously It would be Jeffrey. 3 O. Right. 4 A. I can't remember who all went. O. Who were the pilots? 6 A. I can't remember that either. 7 a Larry? A. No. 9 MR. REINHART: Hold on. 10 A It would have been myself, for sure - it because I was the only one with experience on the 12 airplane - myself, Dave. I believe, would have been 13 captain because he had been schooled, but I can't 14 remember if Larry took first flight a not. I think is he was still In training. 16 O. Where did you go? 17 A. I cant remember. Is MR. PIKE: Form 19 A. I can't remember If it was New York or -- 20 I would imagine it would be New York. but I can't 21 remember. 22 O. When you say you would Imagine New York, I'm 23 getfing the impression that many of the flights went to 24 and from New York. 25 A. Yeah, pdmarlty. 98 1 O. While it's at PBI airport, does it take off 2 from there? 3 A. No, not for — That's when we were doing 4 the modifications and upgrades. We were doing the avionIcs. 6 O. How long dkl that take? 7 A. I don't remember the exact time - maybe a three to four months. 9 O. Who does It with you? 10 A. Jet Aviation. Jet aviation did the ii avionics and soft goods. 12 Q. And when you say the "soft goods," what do you 13 mean by that? 14 A. Carpet, fabrics, leather, you know, 15 different things like that. 16 O. When's the first time It takes off then on a 17 real flight - some time In 2001, but mid-year or 1e something? 19 A. Probably mid-year, maybe a little earlier 20 than mid-year. 21 O. We're talking about June of 2001? 22 A. Right. 23 O. And where do you go? 24 A. Can't remember. I can't remember for 25 sure. 100 1 O. Solt — a A. And — 3 O. So any time you're having to guess where it's 4 gang, you're saying New York because that's the primary 5 place It's going. 6 A. Correct. I would have remembered — I -- 7 I know I didn't get — I had heard about St. Thomas. a but I hadn't been there right away. I didn't get to 9 go to SL Thomas for a while. 10 O. Thars later on in the story. 11 A. Yes. 12 O. We'll get there. 13 So you go to New York. Does he tell you the 14 purpose behind going to New York? is A. No. 16 O. Prior to this trip to New York, have you had a 17 personal conversation with Jeffrey Epstein? 18 A. No. 19 MR. PIKE: Form. 20 BY MR. EDWARDS: 21 O. Never? 22 A. Not personal. Everything Is 23 business-related. 24 O. Okay. but — A. I mean, It was about the intedcv work or EFTA01110295 Larry Eugene Morrison - Volume October 6, 2009 101 1 the avionics going in, but never personal. 2 a But, I mean, you've been hired by him — 3 A. Right. 4 a - you agreed on a scary, he's going to pay 5 you the salary, but other than that, and what maintenance 6 may be required -- 7 A. Correct. a Q. on the airplane, nothing else? 9 A. He's a very -- His conversations are 10 usually very short. He doesn't, you know, take much 11 Urns. 12 Q. When you would have conversations with him. 13 would they be over the telephone or would they be in 14 person? 15 A. It could ben both. If he was in Florida 16 and I wanted to actually show him a fabric or a 17 sample for the airplane or he wanted to view how it 18 was coming, but oftentimes it would be via telephone 1.9 from New York. 20 O. When it would ben person, would you see him 21 surrounded by or be accompanied by a girl or girls? 22 MR. PIKE: Form. 23 A. At times. yeah. 24 O. Would any of those girls be GNslaine Maxwell? 25 A. At times, yes. 103 1 know, business relationship too. 2 Q. Did you know who Ghistaine Maxwell was? 3 A. Not right away, no, no. 4 Q. Not right away? 5 A. Right 6 O. At some point in time you were curious enough 7 to make an attempt to find out. A. No, I -- 9 MR. PIKE: Form. 10 A. — heard about her and there was a book up 11 In New York In the apartment that we stayed in that 12 was — You know. you're sitting there with nothing to 13 do, I read that. 14 O. Do you remember the name of the book? 15 A. It was jusrMaxwell.' 16 Q. Have anything to do with her father? 17 A. Yeah, It was about him, that's what it was 18 about. I mostly just flipped through looking at 19 pictures, boats, and airplanes and stuff. 20 O. Back in 20O1, the first time you had a real 21 conversation with Ghislaine Maxwell — 32 MR. PIKE: Form. 23 A. Yes. 24 Q. — what did that conveMation consist of, if 25 you remember? 102 1 O. Would any of thoso girls look extremely young 2 to you? 3 MR. PIKE: Form. 4 A. Not — Not that I thought. Q. Not back in 2001, were taking about? 6 A. Right, right 7 Q. No. What would Ghistaine Maxwell say to you, if anything? 10 MR. PIKE: Form. 11 A. She'd — Mostly small talk. just — She 12 kind of did the business management part of it as far 13 as, you know, arranging cell phone - I was having 14 cell phone problems with the company cell phone, she 15 would handle things Ike that. but she would have 16 minor Inputs on the interior work. 17 O. What was your understanding back In 2001 sill 18 of the relationship between Ghislaine Maxwell and Jeffrey 19 Epstein? 20 MR. PIKE: Form. 21 A. I really didn't understand it. I thought 22 It was personal - personal and business. 23 O. When you say 'personal,' did you think it was 24 sexual? 25 A. I thought maybe they were dating and, you 104 1 A. I think it was concerning getting a cc 2 phone and a pager - that's it. 3 Q. Did It have anything to do with underage 4 girls? 5 A. Absolutely not, no, no. 6 Q. That's not something she ever shared with you' 7 A. No, no. 8 Q. Oki Jeffrey Epstein ever share with you that 9 he wanted underage girt — 10 A. No. 11. Q. —In any way? 12 A. No. 13 MR. PIKE: Form. 14 BY MR. EDWARDS: 15 O. I mean, certainly I'm not saying something to 16 you that's an absolute shocker right now — 17 A. Right. 10 O. - considering the newspaper articles. 19 A. Right, but I know — You have to 20 understand, every conversation I had was pretty much 21 business, just to deal with the airplanes. You know, 22 I'm an employee/employer relationship. 23 O. I just don't want you to think I'm just asking 24 random off the wal questions — 25 A. Right. EFTA01110296 Larry Eugene Morrison - Volume I October 6, 2009 105 1 O. — that have nothing to do with anything. 2 A. I understand. 3 O. 2001, you start working for him, and that Juno 4 or so is the first flight, and you believe its to New S York. 6 A. Correct. 7 O. Do you remember the purpose behind the flight? A. No, did not know the purpose. O. Did you get off the airplane in New York? 10 A Yes. yes. 11 O. Where dld you go? 12 A. Probably to- into the d4,. into the 13 city, and he has an apartment building up there that 14 we would stay in In the dty. 15 O. Is it paid for by Jeffrey Epstein? 16 A. What? 17 MR. PIKE: Form. 18 BY MR. EDWARDS: 19 Q. The apartment. 20 A. Well, he -- ICS -- I think it's in the 21 building he owns. I mean, I just — I don't know. 22 O. Do remember the address? 23 A. 24 Q. , right? 25 A. Right 107 1 building. rve been to the building. The building is 2 huge. 3 A. I don't know. I don't know if ho owns the 4 budding or just - or how many units he's got Maybe 5 ten, because I think some of the employees up there 6 live in them. 7 Q. Do you remember who some of the other employees are that live in that building? 9 A. Well, I think Darren used to live in it, :o Darren Indyke. 1 Q. Darren In r ht. 12 What about do you remember her? I 13 A. I M lived inn 14 O. What about 15 A. I don't know if Eyed in there or 16 net 17 O. You know who that is. though. 18 A. Right, right Actually, she was Just kind 19 of coming Into the picture when I was - about the 20 time when I was leaving. 21 Q. What about Ghistaine Maxwell? 22 A. No, no, she didn't live there. 23 O. What about Jean Luc Brunel? 24 A No. 25 G. How about Did Mark Epstein ever indicate to 106 1 O. Did he ever mention a brother that he may have 2 to yOU? 3 A. I met his brother, I think, once. 4 O. What's his name? A. I cant remember. 6 Q. Mark? 7 A. I remember meeting. 8 Q. Mark Epstein strike — 9 A. Honestly, I can't say for sure. 10 O. And how do you know that Jeffrey Epstein owns 11 the apartment budding at 12 A. Larry told me. I mean, It was just kind 13 of known. 14 G. Lany told you — 15 A. Yeah. 16 Q. — or Jeffrey told you? 17 A. Oh, no, not Jeffrey, no. Larry. I le wouldn't have asked Jeffrey. 19 O. How many of those apartments up there In New 20 York is it your understanding that Jeffrey owns? 21 MR. REINHART: I'm sorry, are you asking 22 how many units are in the building or how many 23 buildings? 24 BY MR. EDWARDS: 25 O. No, how many units that Jeffrey owns in the 108 1 you that he had any ownership in any of that? 2 A. Oh, no. I only saw him one time on a 3 short flight. I don't even know where we - we were 4 probably taking him to and he was just - Jeffrey 5 introduced him as his brother and it was very short, 6 you know, Just, "Oh, hi. How are you?", and he went 7 in the back. 8 O. Do you know anything about the guy? 9 A. Ini-uh. 10 Q. Nothing? 11 A. Nothing. 12 Q. So in 2001. there's a flight up there at some 13 appointment in time, and you toff and stay at one 14 of the apartment buildings at 15 A. Right, right. 16 Q. And did you meet any of the neighbors of the 17 apartments that are also owned by Jeffrey Epstein? 18 A. No, no, because when we're there Ifs 19 usually just for a night or something and then. you 20 know, we're either airtining home or going on, 21 O. How did you know Darren Indyke? 22 A. He's our — He's our business attorney for 23 JEGE. 24 Q. Do you renwrirbur an of the other tenants of 25 the apartments at other than Darren EFTA01110297 Larry Eugene Morrison - Volume I October 6, 2009 1 109 Indyke and MOM? 2 A. Not that I remember, no. 3 0. How about Leslie Groff? 4 A. I don't think Leslie lived there. 5 Q. Do you remember that name? 6 A. Yes. She's Mr. Epsteires secretary. 7 Q. What about A. no, I don't think so. 9 Q. Jeff Fuller? to A. I dont know Jeff Fuller. I don't even 11 know Jeff Fuller. 12 0. Do you know the name Jean Luc Brunel? 13 A. Yes. 14 0. How do you know that name? 25 A. He% been— He was a passenger on a few 16 of our flights. 17 0. Do you know why? 18 A. I Mink he was — I don't know for sure. 19 He's In a modeling business with Mr. Epstein, I 20 believe. 21 Q. MC2? Do you know that name - MC2 Modeling 22 Agency - used to be Karin Modeling Agency, now its MC2? 23 A. No. 24 a How do you know about his and Mr. Epstein's n modeling agency? How do you know that? 1 2 3 4 5 6 7 B 10 11 12 13 1.4 15 16 17 18 19 20 21 22 23 24 25 111 of the MC2 shoots? A. I never heard — There was one Incident — The only thing I remember about it is they were on a shoot and it's not funny. but Jeff - but it is in a way- they were In a motor home on location at the shod, and they started to drive off and one of the models asked to use the restroom and they told her which door it was and she went out the side door. so grabbed the wrong door, but that's actually the only thing that sticks in mind - was that one. O. Have you ever done any research on Jean Luc Bruner? A. No. O. Do you have any idea that ho's known throughout Europe as somebody who has sex with urde race girls? A. No. Q. You didn't know that at right now? A. Coned. 0. That's something that you're !earring as a surpise to you. A. Yes. 0. So-- somebody you never heard of? A. It sounds familiar I'm eying to place 110 1 A. Just even/ once in e while he would say 2 something about, you 'mow, one of the model sheets a 3 something. We normally had him on - we would take 4 him badt and forth to Paris. Q. Where some of their models come from? 6 A. I don't know. 7 0. Did you ever bring some of the Paris models a back? 9 A. Not that I'm aware of. no. 10 MR. PIKE: Form. 11 BY MR EDWARDS: 12 0. So he would go to Pans on the airplane. Jean 13 Luc, would you drop him off there or would you pick 14 people up and bring them back? 15 A. If I remember. normally we were bringing 16 Jean Luc from Pais to New York. if I remember. 17 G. And when you say that the modeling agency • 113 obvious!), that. you know, between him and Mr. Epstein - 19 is that something that Mr. Epstein would talk to you 20 about or is that something that Joan Luc would talk to 21 you about or you would just overhear the two? 22 A. Overhear the two. or Jean Luc may say 23 something about one of the shoots or something, just 24 in general conversation. 2s Q. And what would Jeffrey's comment be about some 112 1 her. I don't know if she works in the office or -- 2 Q. Or waked in the office? 3 A. Worked In the office, yeah. I very rarely 4 went to the office. I mean — 5 0. - how do you know her? 6 A. From the flights - being on the airplane. 7 Q. How many times was she on the airplane? 8 A. Quite a few. Almost every. 9 0. What's your understanding as to what she did 10 for Mr. Epstein? Ll A. Like a personal assistant 12 0. Personal assistant doing what? 13 A. Arrangements, meetings, berthing like, I 14 guess, personal affairs, you know. 15 Q. Did Mr. Epstein ever once mention to you that 16 he likes massages? 17 MR. PIKE: Form. 18 A. No, he never mentioned that to me. 19 Q. That's not something that you ever heard ol. 20 right? 21 A. Well, I -- 22 Q. I mean, outside of the articles that you've 23 read. 24 A. Right. No, but he never came up to me and 25 said," hke massages? EFTA01110298 Larry Eugene Morrison - Volume I October 6, 2009 113 t. O. And did - did you hear her 2 organizing, scheduling, talking to people about either 3 what she may call "work" or 'Massages' for Epstein? 4 A. No, no, I don't. 5 MR. PIKE: Form. 6 BY MR. EDWARDS: 7 Q. What types of conversation. if you can 8 remember anything, did you ever overhear - 9 talking about? 10 A. It would be mosey like transportation 11 arrangements - car needs. 1.2 O. Car needs for who? 13 A. Well. making sure that the driver in New 14 York was meeting the airplane at the proper time, 15 sluff like that, or if they had an unusual large 16 amount of baggage, to make sure that another car was 17 hired to come pick this up, things like that - 18 logistic-type stuff. 19 Q. We're still talking about a time period back zo In 2001. right, In these - 21 A. No. - I don't remember comirg 22 Ink) the picture until later. 23 O. Later in 2000-something? 24 A. No, she wasn't around at first. 25 O. Alright 114 A. No. I don't remember when exactly= 2 but she - 3 Q. Who was maki arrangements for meetings 4 and such prior to Ms. 5 A. Ms. Maxwell. 6 Q. — that you remember? 7 So Maxwell was the, for all intents and a purposes, the before existed? 9 A. For aN Intents and purposes, yes. 10 Q. And cfid you ever hear of Ms. Maxwell making 11 arrangements for massages or for girls or anything else? 12 A. No. 13 MR. PIKE: Form. 14 BY MR. EDWARDS: 15 O. Where were the conversations - whether it was 16 travel or whatever else - that was occurring between 17 Maxwell and/or ? Where were they taking 18 place - on the airplane, some office? 19 A. Yeah. No, no, usually in the cockpit, you 20 know, prior to departure, en route staling, "We've 21 got this many cars and !Ye contacted" or Tan you 22 ea such and such to have this brought out? 23 Q. Did you ever see Epstein work a lot? 24 MR. PIKE: Form. 25 A. He always had a briefcase with him and he 115 1 always sat it by his office in the back. 2 Q. Always had a computer? 3 A. No, no, it's just a large briefcase. 4 Q. Did you ever know his e-mail? 5 A. Yeah, I had It - I can't remember what it 6 was and I don't think ifs even current - but when I 7 would have to send him e-mails about the interior or El maintenance Issues. It was jeprojects, or something 9 like that, at — 'don't know if it was at Yahoo or 10 gmail. I don't think it was gmail. 11 Q. You think it was jeprojects? 12 A. I believe so, but I can't remember what 13 seMce. 14 O. At gmall.com or something? 15 A. Or something like that or Yahoo or 16 something. 17 Q. How about Ms. Maxwell? 18 A. It was g - [email protected], I think. 19 Q. Do you know if that's still current? 20 A. No, I don't. 21 Q. How about =1=7 22 A. I had it at one time and I know she 23 changed it and I don't know what it is. 1 can't 24 remember what it was. actual) . 25 O. Do you know -where where she is 116 1 right now? 2 A. No. 3 O. Do you know if she's intentionally on the lam 4 Why to avoid being deposed in this case? 5 A. No. 6 MR. PIKE: Form. 7 A. No idea. I haven't had any contact with 8 MI since I stoppeda. 9 O. You say that waS Just COMing in the 10 picture - is the words that you used. What did you mean 11 by this? 12 A. Well, I mean she was Just — I'm hying to 13 remember when I first started seeing her on the 14 airplane. I think It was not too long before I quit 15 tying. I can't remember the exact dale. 16 Q. When did you stop flying? 1.7 A. In February of '07. IS Q. February '07? 19 A. Yep. 20 Q. And you don't think you saw her on the 21 airplane until before that? 22 A. No, I'm saying she was only coming into 23 the picture like maybe six months before that or so 24 or -1 don't know for sure. 25 Q. You don't remember seeing her On the airplane EFTA01110299 Larry Eugene Morrison - Volume I October 6, 2009 117 1 in 2001, 200Z 2003? 2 A Ott, no, not that early. 3 Q. Do you know where she came from? 4 A. Just what I've read In the paper - an 5 eastern country. I'm sorry, I don't remember the 6 coutry. 7 0. Were you ever told that Mr. Epstein bought her 8 from her famitywOen she was 14 years old to come over to 9 be his Yugoslavian sex slave - is that something that you 10 ever heard? 11 A. No. I did read something like that in the 12 paper, but, no. never heard of that. 13 a Did you ever see him and her sexually involved 14 on the airplane or othenwse? 15 A No. 14 Q. Did you ever see Epstein involved sexually 17 with anybody on the airplane? 18 A. No. 19 0. Did you ever see the airplane used for sexual 20 purposes? 21 A. No. 22 MR. PIKE: Form. 23 BY MR. EDWARDS: 24 0. tf it had happened - considering the various 25 areas that were cordoned off or blocked off - would that 119 1 A. No. 2 0. - in the back of the airplane. 3 A. No. 4 Q. So anything could go on. You would have no s idea. 6 MR. PIKE: Form. 7 BY MR. EDWARDS: Q. You could sit here end testify truthfully. 1 9 have no clue what's going on back there." 10 A. That's correct. That's correct 11. 0. Darren Indyke -what's your understanding no 12 to his involvement with Mr. Epstein? 13 A An attorney for the company. 14 0. Ever met Nan Dershowitz? 15 A. I think — Yes. 16 0. How dkl you meet him? 17 A. Nan Dershowitz. I don't know if it was 18 Mr. Goldberger or Nan Dershowitz. We brought some 19 attorneys down — 20 0. Why? 21 A. — to Florida one time. 22 0. Why? 23 A. For Mr. Epstein. It was right before I 24 finished flying. For Mr. Epstein to make an 25 appearance at the courthouse or a meeting or 118 1 have even been something that you could have seen? 2 A. No, no, if it was - if the doors were 3 closed, no. 4 0. So there's a back room that you've described 5 that has a bed In it, and If that door's closed you don't 6 know what's going on behind closed doors. right? 7 A. That's correct. 8 MR. PIKE: Form. 9 BY MR. EDWARDS: 10 0. Do you remember a time Epstein was back in 11 that back room with other people? 12 MR. PIKE: Form. 13 A. NO. 14 Q. Are you saying it never happened while you 15 were on the airplane? 16 A 'really have no idea of knowing because, 17 one, we never go back there unless we're invited is back. 19 Q. Okay. 20 A. And the forward door - the very forward 21 salon door is closed, so we never even normally go 22 Into that •• 13 Q. So you don't really know -- 24 A. — without pertrission. 25 Q. You don't really know whet happens -- 120 1 something, and we brought some attorneys with him. 2 0. And were you aware then of the allegations 3 against Mr. Epstein? 4 A. They wore starting to brew, yes. 5 Q. Were you still actively working on his payroll 6 at the time when the investigation was going on? 7 A. Yes, when it just started. 8 0. And did that Impact you In any way as to 9 whether or not you wanted to be affiliated with this 10 person? 11 A Subconsckausly, It may have. And it 12 wasn't because of this person, but as a business 13 decision, if, you know, an airplane's not needed and 14 I don't fly, I could be out of work. But, no, the 15 primary reason was the fact that I (lid want to get 16 off the road and back home. 17 0. Do you have children? 18 A Yes. 19 Q. How old? 20 A. A daughter 28, son 24, and a daughter 17 - 21 all with the same bride - 31 years. 22 Q. I'm assuming you're aware or the factual 23 allegations in these complaints? 24 A Yes, yes. 25 Q. And you are aware that there are hundreds of EFTA01110300 Larry Eugene Morrison - Volume I October 6, 2009 121 2 girls who are underage who claim to have had sex with Mr. 2 Epstein as well as Ms. Maxwell at various times? 3 MR. PIKE: Form. 4 A. I was only aware of —First time I was s made aware of it, of the number of people, was when 6 they served me the subpoena. The deputies or 7 retired — a Q. Yes. 9 A — private eyes told me that. That was 10 the &stilled heard a number. 11 Q. Were you completely oblivious that this was 12 going on? And by IliIC I ntean Epstein and/or Ghistalne 13 Maxwell andla recruiting 12. 13. 14. 14 15wew-old gels to Ns house for sex? 15 A. Absokrtely I was oblivious to it. 16 MR. PIKE: Form. 1.7 BY MR. EDWARDS: 18 Q. If young gds were on an airplane that yOu 19 were on - consider:iv that we've now established how the 20 airplane's set up and you're kind of cordoned off - is It 21 possible that underage girls would have been on the 22 airplane and you just wouldn't have known about It? 23 MR. PIKE: Form. 24 A. No, no. I mean, people don't board the 25 airplane with - you know, and then just say, "Close 123 1 Q. Okay. I'll ask it a different way. 2 A. Because we have had -- You know, he's got 3 a goddaughter and godson that were young. I mean. 4 O. Okay. Over the years -- 5 A. I mean, I don't know what the purpose -- 6 Q. Right I totally understand what you're 7 saying. 8 Over the years, when you were on Jeffrey 9 Epstein's airplane, were you aware between 2001 and 10 wherever you stopped. 2007 — ii A. Seven. 12 Q. — were you aware of girls that appeared very 13 underage on the airplane? 14 A. No, 15 MR. PIKE: Form. 16 BY MR. EDWARDS: 17 Q. rm not saying what was happening on the Is airplane. I'm just saying, were you aware of it? 19 A. No, not - unless they were there, like I 30 said, his goddaughter at the time. One time - a 21 couple times we flew her with her mom and dad where I 22 don't even know their age. 23 MR. PIKE: Again, form, asked and 24 answered. 2s A. Six or seven. But, no, I was not aware of 122 1 the door, we're going." You know, you see who boards 2 the airplane. 3 Q. So if there were flight records that show 4 underage girls on the airplane, you would know about it? 5 MR. PIKE: Form. 6 A. Not necessarily 7 Q. Well, how not? MR. REINHART: I'm sorry. 9 A. Well, how do you — 10 MR. REINHART: When you say "them? do you 11 mean he would know about the records a he would 12 know about the girls allegedly on the plane? 13 BY MR. EDWARDS: 14 Q. You would know about the underage girls on the 15 airplane if they were on there. 16 MR. PIKE: Form. 17 A. How do you -- How would I know that 18 they're underage. though? 19 Q. Well, you would only know that they look 20 extremely young, right? 21 A. But — 22 MR. PIKE: Form. 23 A. — what is the Intent of them? I mean, 24 are they guests or are they friends of his associates 25 or — 1 2 4 1 anybody that was obviously, blatantly underage. 2 Q. My famous people that you can tell me that 3 were on the airplane? 4 A. President Clinton - Ex-President Clinton. 5 O. Were you on the airplane — 6 A. Yes. 7 O. — when he was on it? a A. Yes. 9 O. How many times? 10 A. Two trips. I mean, two extended kips. 11 Q. Where did it go? 12 A. The first one - or the first one was Asia. 13 Q. What purpose? 14 A. I forget what the purpose was on that one. 15 Q. Was Jeffrey Epstein on the airplane as well? 16 A. Yes, yes. 17 Q. Who else was on the airplane then? 18 A. I don't remember on that one. It was 19 primarily him and his support staff. 20 Q. Was 21 A. Probably, yes, probably. 22 O. When's the next time President Clinton was on 23 his airplane? 24 A. I don't remember the date, but we did a 25 Africa trip, an AIDS awareness tour. We did like ten EFTA01110301 Larry Eugene Morrison - Volume I October 6, 2009 125 1 countries in 12 days. 2 Q. Is that a time Chris -fucker 3 A. Yes. 4 O. — and Kevin Spacey were also on it? 5 A. Yes. 6 Q. In addition to the people that we've named, 7 were there females on that airplane? A. Yes. 9 O. And who were the females that were on the 10 airplane? 11 A. Can't remember. Ms. Maxwell,-, I can 12 remember, and a couple others, and there's - Me. 13 Canton had - a couple of his support staff we 14 women also. 15 O. Where were you sitting during these trips? 16 A. Up front In the my station. 17 O. Could you see what they were doing where you 18 were? 19 A. No, no. 20 O. Could you tell if there was any sex going on 21 on the airplane welds you were on it? 22 A. No. 23 MR. PIKE: Form. 24 BY MR. EDWARDS: 25 O. Do you know of any underage girls being on 127 1 MR. EDWARDS: No. I mean, unless 2 everybody wants to take a lunch break. 3 Everybody's shaking their heads, so. no, I'm 4 going to take a bathroom break, and k's going to be a fast one. 6 IF. PIKE: Okay. 7 BY MR. EDWARDS: O. In 2001. when you're on this flight to New 9 York and then during that year we talked a little bit 10 about it, is Larry Visoski and David Rodgers also on some 11 of these flights? 12 A. Most, yes. 13 0. If somebody's going to keep passenger logs, 14 whale going to write down the names of the people? Is 15 that going to be you or is that somebody else's 16 responsbeity? 17 A. Whoever is captain. 18 0. So normally It's Visoski or David Rodgers? 19 A. Correct. 20 Q. Who do you turn these logs into? 31 MR. PIKE: Form. 22 A, I don't know. I don't know where they go. 23 Q. You don't know the purpose behind keeping them 24 or anything? 25 A. No. 126 1 that airplane or would you have been able to ter 2 A. No. 3 MR. REINHART: I'm Sony 4 MR. PIKE: Asked and answered. MR. REINHART: — are you limiting it to 6 that trip? 7 BY MR. EDWARDS: 8 O. To that trip. 9 A. No, rm not aware of it. 10 Q. If you had been aware of underage girls being 11 transported on the airplane for the purposes of sex, 12 would you have said something to somebody? 13 A. Yes. 14 MR. PIKE: Form. 15 MR. EDWARDS: Do you mind if we take a 16 five-minute break? I just have to run to the 17 bathroom. 18 MR. PIKE: Actually, Brad, Can you hear 1.9 me? 20 MR. EDWARDS: Yes. 21 MR. PIKE: How much longer do you 22 anticipate going with this witness? 23 MR. EDWARDS: Hour, maybe a Me longer. 24 MR. PIKE: Weir, are you going to take a 25 lunch break or what? 128 1 Q. As far as you're concerned, you don't even 2 need to keep them. 3 A. Correct. Yeah. 4 O. As just due diligence - going above and 5 beyond? 6 A. Correct. 7 Q. Today you have an attomey sitting right next 8 to you, right? 9 A. Correct. 10 Q. Is that somebody that you've known for a long 11 lime? 12 A. No. 13 Q. You're paying for an attorney to sit here with 14 you? 15 A. No. 16 Q. Who's paying for your attorney? 17 A. Mr. Epstein. 18 O. Are you worried that you're criminally 19 involved here or something? Is that why you need an 20 attorney? 21 A. No. I don't even know anything about this 22 process, that's 23 0. Oh, okay. 24 A. rm just — You know. 25 Q. How did you know that you were - EFTA01110302 Larry Eugene Morrison - Volume October 6, 2009 129 1 MR. PIKE Brad. Brad. Brad. 2 Q. — going to get an attorney — MR. REINHART: Brad, hold on. MR. PIKE: Whoa. Whoa. SW. s MR. EDWARDS: I'm listening. 6 MR. PIKE Brad. 7 MR. EDWARDS: Go. 8 MR. PIKE: You are not allowing the 9 witness to finish his statements throughout this 10 entire depo. Please. rm on the phone. You 11 start your question before the witness is 12 finished. rm sorry for raising my vice. but 13 you must allow the witness to finish his answer. 14 please. 15 MR. EDWARDS: You got it. 16 THE WITNESS: What was your question now? L7 I forgot. 18 MR. EDWARDS: rm sitting here looking at 19 the witness and have a feeling we're going to be 20 sitting here for 30 minutes, but I will do that 21 for you, Mr. Pice. 22 MR. PIKE: Alright. 23 THE WITNESS: What was the question again, 24 please? 25 MR. EDWARDS: Can I ask the question again 131 1 this case against Mr. Epstein? 2 MR. REINHART: Let me ask him not to 3 answer that. 4 MR. PIKE: Form. 5 MR. REINHART: It's privileged. 6 MR. EDWARDS: It's privileged between Mr. 7 Epstein and you, but is it privileged between a the two of you? 9 MR. REINHART: Between Mr. Morrison and 10 me. 11 BY MR. EDWARDS: 12 Q. Is it your understanding that he represents 13 you or he represents W. Epstein? 14 A. He represents me. 15 0. Okay. Do you think that you've done anything 16 wrong crkninally? 17 A. No. 18 Q. Do you think that you're being sued civilly? 19 A. No. 20 0. And you have no reason to be sued civilly, 21 22 A. Correct. 23 0. Did you talk to Mr. Epstein prior to taking 24 your deposition today? 25 A. Oh, no. I haven't talked to him In well 130 1 or wait? III wait for you. 2 MR. PIKE: If I'm ready. 3 MR. EDWARDS: I already asked the 4 question. so we're walling. MR. REINHART: I think the witness asked 6 you to repeat the question. 7 MR. EDWARDS: Are you good? Alright. 8 BY MR. EDWARDS: 9 Q. Who hired your attorney? 10 A. Mr. Epstein. 11 Q. And do you have any Idea why, it you're a 12 witness in a case - no problems criminally - why you 13 personally have an attorney paid for by Mr. Epstein to 14 sit here with you? 15 MR. PIKE: Form. 16 A. No, I don't 17 Q. Do you want an attorney to sit here with you 18 while I ask you questions? 19 MR. PIKE: Form. 20 A. I don't know what the proper protocol is. 21 Q. Okay. 22 A. I have very limited exposure to anything 23 like this. 24 Q. How did this come about to where you have an 25 attorney as a witness - completely Innocent witness - in 132 1 over a year-and-a-half, maybe two years, and that was 2 Just a "hello- because I'm at the airplane one day. 3 Q. So how Is it you know that Mr. Epstein paid 4 for your attorney? 5 MR. REINHART: It's privieged. 6 MR. EDWARDS: Okay. That answers my 7 question. s BY MR. EDWARDS: 9 O. Have you ever met Donald Trump? 10 A. Yes. 11 Q. How? 12 A. He was -- He boarded the airplane one day 13 when ours was on the ramp. Q. And did you talk to him? is A. Just he introduced himself and I 16 introduced myself. 17 O. And did he talk to Mr. Epstein? 18 A. No. Mr. Epstein wasn't present. I was 19 doing maintenance. 20 Q. And did he fly on the plane? A. No. 22 Q. Not that time? 23 A. Never. 24 Q. You think he never flew on the plane? 25 A. On our akplane? EFTA01110303 Larry Eugene Morrison - Volume I October 6, 2009 133 1 O. Yes. 2 A. No. 3 Q. So if somebody has given testimony other than 4 that, you would say that person is mistaken or lying? 5 MR. PIKE: Form. A. Donald Trump was never on the airplane 7 when I was on the airplane. 8 Q. Is it your understanding that Donald Trump Is 9 friends with k6. Epstein? 10 A. From what I've read - or associates. I 11 don't know how that cirde works. 12 O. What's your understanding as to who Mr. 13 Epstein's real friends are? 14 A. I really don't know, I don't — I don't 15 know. It's — It's not like the Wexners where, you 16 know, they were high school associates, you know, 17 graving up. 18 Q. Do you know what Mr. Epstein did prior to 19 managing the money for Mr. Wexner? 20 A. Just that he was a Wall Street broker or 21 somebody, you know. 22 Q. Also from reading? 23 A. Yes, was. 20 Q. Do you know any personal knowledge as to wha 25 Mr. Epstein has told you about how he made money? 135 1 A. I have no idea. I don't knout 2 O. When you say that was lust 3 in the picture, %thee your understanding as to 4 votxr is relative to Mr. Epstein? A. I dont know. I don't understand. I 6 daft lea I didn't know if maybe she was like an 7 exchange — Jeffrey always appeared to be very Involved In education and philanthropy. I didn't 9 know If she was an exchangetype student or soniu l ring 10 or what I don't know. 11 Q. When you say ho appeared to be "involved in," 12 what do you mean? 13 A. Educational things, foundations, sdence 14 foundations, and things. 15 Q. Speaking at - the Florida Science Foundation 16 Is a place where, when he was on work release, he spent a 17 kg of time there, you're aware of that? 18 A. That's what rve heard, yeah. 19 0. What does that place do? 20 A. I have no idea. 21 Q. Does k do anything? 22 A. I don't know. I don't know anything about 23 it. 24 25 Q Certainly you've read certain newspaper articles about the allegations, police reports, 134 1 A. He's never - 2 MR. PIKE: I'm going to move to strike any 3 responses relative to what the witness has 4 learned from reading. 5 BY MR. EDWARDS: 6 0. And so that Is wily I asked the question: Has 7 Mr. Epstein told you? Which would have nothing to do s with reading. 9 A. No. 10 Q. How many conversations have you personally hat 11 with Mr. Epstein? 12 A. No personal conversations - all business. 13 Q. Have you witnessed Mr. Epstein with any girls 14 that look to be under the age of 18? 15 A. No. 16 Q. Have you witnessed Mr. Epstein with 17 young-looking girls that appear to be In their twenties? is MR. PIKE: Form. 19 A. Yes. 20 O. On how many occasions? 21 A. Probably several. 22 Q. And how did that come about? 23 A. I mean, they show up and ride on the 24 akplane, you know. 25 Q. And who we they, if you know? 136 1 otherwise, the allegations that occurred or have been 2 alleged to have occurred at his Palen Beach mansion, 3 correct? 4 A. Uh-huh. 5 Q. Correct? 6 A. Correct. 7 O. Given the nature of those allegations, would 8 you leave your daughter of 17, 16, 15 years old with Mr. 9 Epstein alone? 10 MR, PIKE: Form. Move to strike. 11 A. Yes. 12 Q. You would? 13 A. witness nods head.) 14 0. And why? 15 A. Because I don't fear that he would try 16 anything with my daughter. He showed — When I 17 worked for him he showed me respect. He never — I 1 8 never — He never showed me disrespect. He would ask 19 how the family is. I mean, not on a personal level, 20 but an employer/employee. 21 Q. Right. Okay. 22 A. lie never showed me any reason not to trust 23 him. 24 Q. But you're not a 13-year old girl, so. 25 A. No, but, like I say, he never showed me EFTA01110304 Larry Eugene Morrison - Volume I October 6, 2009 137 1 any reason not to trust. 2 Q. So maybe that's the reason why there were 3 hundreds of victims, right? 4 A. I don't know that there were. Q. So Is it surprising to read the things that 6 you read about what was going on at his house? 7 A. Yes. a MR. PIKE: Form. Move to strike. 9 BY MR. EDWARDS: 10 Q. I'm going to ask you about — rm going to 11 mark them al -- In fact, rm going to show them to your 12 attorney first because rm going to mark them as a 13 comp05103 - just 10 save time. 14 MR. REINHART: For the record, you've 15 handed me a stack of passenger manifests? 16 MR. EDWARDS: Yes. You can count them if 17 you want, doesn't matter to me, and well just 18 mark them as a composite - go through each one 19 of therm 20 MR. REINHART: If you're going to go 21 through each one of them, I don't need to count 22 them You'll make a record on that 23 MR, EDWARDS: Fine. fm going to mark 24 these as Composite Exit bit 1, and we'll count 25 them at the end. 139 1 know her if I saw her. 2 O. What did she do? 3 A. I don't know. I don't know. 4 O. Would it surprise you if she was in charge of s scheduling for the minors to come over to the house to 6 sexually gratify Mr. Epstein? 7 MR. PIKE: Form. a A. Yeah, that would surprise me, yes. 9 O. Okay. She didn't do that while you were on 10 the airpiane, right? 11 A. No, no. 12 O. Was Mr. Epstein on the airplane? 13 MR. PIKE: Form. When? 14 A. Yes. 15 O. And if it happened, it happened at a portion 16 of the airplane where you couldn't see it because you 17 were partitioned of% 18 A. What happened? 19 MR. REINHART: I'm sorry, can we just get 20 a timeframe? 21 MR. PIKE: Form. 22 MR. REINHART: Are we talking about this 23 flight? 24 MR. EDWARDS: Yes, we're talking about 25 that flight. 138 1 (Defendants Composite 1 VAS marked for 2 identification.) 3 BY MR. EDWARDS: 4 Q. The first one's dated 1114(2004. Can you tell 5 me what we're looker° at there? Just remember, nn about 6 as familiar with that type of stuff as a three year old. 7 SO help me out. 8 A Passenger mandest just showing basically 9 date, time off. time on, the trip number or the year. 10 I guess it would be - that seems high for the year - 11 but trip number - that must be for the total • 12 destination or departure point - destination. 13 O. The trip number says. "311." What does that 14 mean? 16 A. That must be — I dent know where they 16 start that. That must have been total since he 17 started the airplane. That's wry too many for the 2e year. Obviously it's already - it's January. so it 19 must have been total flights. 20 Q. Who's on that airplane? 21 A. Nautical miles, statute rates, fuel 22 burned. pounda 23 24 Q. Do you know 25 A. I — I rink I know her. I think I v.culd 140 1 BY MR. EDWARDS: 2 O. If anything happened on the airplane. it would 3 have been In a position where you couldn't see It anyway. 4 A. That's correct. 5 O. Okay. 6 A. That's correct. 7 O. So you're not saying it did happen or it a didn't happen, you just couldn't see past a certain 9 point. 10 A. Correct, and I don't know what you're 11 tarring to as "it" anyways. 12 O. it - is whatever sexual involvement there was. 13 A. Oh. Lice you say, we can't see anything 14 back there anyhow because the doors are closed. 15 Q. Did Mr. Epstein instruct you as to whether or 16 not to knock or just wak back there or never walk back 17 there or what was the Instruction? 18 A. No. There was never actually a formal 19 Instruction. It's proper protocol for any of these 20 gentlemen, or individuals that own these aircraft, 21 that that's their private zone, that you don't Come 22 back unless you're needed, and then you can -- You 23 know, but Its not forebode, it's just proper. 24 O. You mentioned President Clinton on the ptane. 25 How many girls were on the plane al the same time when EFTA01110305 Larry Eugene Morrison - Volume I October 6, 2009 141 1 President Clinton was on the plane? 2 MR. REINHART: Asked and answered. 3 A, Yeah, I don't remember for sure. There 4 was probably maybe five, if that, and that's — 5 Q. What were they 6 A. What? 7 Q. Go ahead. 8 A. Like I say, it was Ms. Maxwell. M, 9 maybe two others, one other, and then I think Mr. 10 Clinton had two ladles in his entourage - support 11 staff. 12 Q. What age group are we talking about with the 13 ladies that were on the airplane? 14 MR. PIKE: Form. 15 A. Mid-twenties to forties, maybe. I mean, I 16 don't know exactly. 17 Q. I Mean, you know what a 13 or 14-year-old girl is looks like -- 19 A. Yes. 20 Q. - right? 21 A. Yes. 22 Q. Most people do. 23 A. Yes. 24 Q. You woukIn't mistake a 13 or 14 or 15 year old 25 fora 20 year old. 143 1 you fernier with a fight where Prince Andrew was on the 2 airplane? 3 A. I dont know if I remember him being on 4 the airplane or not. I know that he has been on the 5 airplane or one of rite akplanes. 'can't say for 6 sure. 7 0. Have you met him before? A. I can't remember, honestly. I know. 9 0. Can't remember meeting Prince Andrew? 10 A. I know. I know. I didn't even know who 11 he was when I first heard the name, sony. But, no. 12 I can't remember for sure. I'm sorry. 13 Q. That's like if E.T. walked on the airplane and 14 I don't know. 15 A. I know. Well — le Q. Alright. Fillet you slide on that one. You 17 know who Prince Andrew is now. 18 A Okay. Don't paid me as stupid. One of 19 Lady DI's sons. right? 20 Q. I mean, you know what he looks like new. 21 A. You know, honestly, I don't know if I 22 could point him out to you, I'm sorry. 23 0. Alright. 24 A. It's Just — 25 Q. Well forget him. 142 1 A. No. no. 2 MR. PIKE: Form. 3 BY MR. EDWARDS: 4 0. So you're sure that the people that were on 5 the airplane - they were above the age o118? 6 A. I believe so. 7 0. Because you, in your experience. as well as 8 the experience of most people your age. would know — 9 A. Right. 10 Q. — what a 14 or 15 year old looks like. 11 A. Right. 12 Q. I'm going to go through the next fright log. 13 You tel me what we're looking at here. Who's on the 14 airplane? 15 A. That was a deadhead. Nobody's on it. 16 Q. Why were the names crossed out? 17 A. Because there was no passengers. This was 18 . origin was West Palm Beach - West Palm Beath. What 19 date is thiST 1/20104? ft was probably a test 20 flight. 21 Q. Okay. 22 A. It was a training flight — 33 0. Okay. 24 k —for Bill. 25 0. The next one — Well, before I ask this: Were 144 A. rm smart In some things. 2 0. Well forget him. Well forget him. Don't 3 worry about It. 4 What's this? What are we looking at? 5 MR. REINHART: For the record, you handed 6 him a manifest dated January 17, 2005; is that 7 correct? THE WITNESS: January — Yes. Correct. 9 Palm Beach to Kennedy, same thing, fuel 10 burns, loads, destination, time off, time on. 11 Next, It was ki 312. •Ls on It= David Mullen, , Todd Myster (sic), 13 and passenger, passenger. 14 BY MR. EDWARDS: 15 Q. Do you know Todd Meister? 16 A. He's a friend of his, I believe. 17 Q. Father's Bob Meister? Do you know the names? 18 A. No, I don't know that 19 0. How do you know Todd Meister? 20 A. Ne Mg heard the name. 21 0. From who? 22 A. Larry Vtsoski. 23 Q. Larry Visoski knows these people? 24 A. !think Todd Meister has an airplane. or 25 something like that He's talked to their flight EFTA01110306 Larry Eugene Morrison - Volume I October 6, 2009 145 1 crew. 2 D. For the most part, when you mention these 3 people's names, you mention them as if they're just 4 passengers on the airplane and this is their world - 5 you're passing through, you don't know them. 6 A. Right. 7 Q. But Visosld - would you say that he has a closer relationship with Epstein to where he might know 9 some of these people? 10 MR. PIKE: Form. 11 A. That could be an accurate - yeah. I mean, 12 he's been with Jeffrey longer. I mean -- 13 Q. I mean, do you know that Viso:ski has a car 14 that Is registered in Jeffrey Epstein's name? You don't 15 have anything like that, do you? 16 A. No, I did not. 17 Q. Were you aware of that? 18 A. No. 19 Q. Does Mr. Vlsoski tel you how far he goes back 20 with Jeffrey Epstein? 21 A. No, just, I mean, when he hired him, 22 whenever that was after Glimcher - that's al I know. 23 Q. Do you know anything about Visoskrs private 24 life? 25 A. A little bit. He's married and - 147 1 Q. Well, do you know whose handwriting that is? 2 A. No, no, I don't. It may be Larry's. 3 O. Similar handwriting 4 A. Walt a minute. 5 O. - as those -- 6 A. Let's see the one with the training - 7 because there's a different pilot on there. 8 O. Right. One where there Is nobody on it, 9 rIgM? 10 A. This is Bitrs — I can't — This is 11 Bits writing. I think he was having him f2I out 12 the paperwork. 13 Q. Bill Hammond? 14 A. Yeah, this was his training flight. 15 Q. The first one is Visoski? 16 A. Maybe. I can't say fa sure. I really 17 cant say for sure. 18 Q. And this Is? 19 A. I don't know if that's the same 20 handwriting or not. 21 Q. Well, is there any indication up here that 22 would tell us whose handwriting it is? David Rodgers and 23 Larry Visoski — 24 A. No, because this is -- 25 Q. — are the plots. 146 1 daughters. I mean -- 2 Q. Then I won't go into the rest of his private 3 Me. 4 When it says, '1 pay, 1 pay? what does that mean? 6 A. h's TAX? P-A-X is short for 7 "passenger? It's a brief. 8 O. Okay. Look, this is somebody that is listing 9 names of people on an airplane. They're going out Of 10 their way 11 A. Right 12 Q. -- and then all of a sudden on No. 8 and 9 13 they say, 'one passenger.* Is this person just getting 14 lazy or is there a reason why there's no name? 15 A. Like I say, just getting lazy and then 16 didn't know who the passenger was. 17 Q. Well, they obviously didn't know who Todd 18 Meister was either - they wrote his name all wrong. 19 A. They did? 20 MR. PIKE: Form. 21 BY MR EDWARDS: 22 Q. Well, "Meister" is not spelled like that. SO 23 how did -- 24 A. I didn't - I didn't know that. I don't 25 know how he— How does he spell it? 2 3 4 6 7 148 A. Yeah, but they don't indicate - they don't indicate who's captain that day. You know, rm not a handwriting expert I can't realty — Honestly, I cant tel you for sure whose handreidn0 it was. Q. Let's keep this one out. and tell me if Cis Is — rm going to hand you January 19, 2005 — Mt REINHART: January 17. a MR. EDWARDS: 2005? 9 M. REINHART: Yee. 10 BY M. EDWARDS: 11 O. —Januar/11, 2006, so two days biter -where 12 Is this airplane going? 13 A. From Kennedy to Palm Beach. 14 Q. And so this is Palm Beach to Kennedy - 15 A Yep. 16 Q. - In iris exhibit The next one is Kennedy 17 to Palm Beach. 18 A. Correct. 19 Q. They come back. Where do they stay-do you 20 Nitre 21 A. Whatdo you mean? 22 Q Well, they set oft on the 17th, they stay 23 liCenWebere until they come back on the 19th. Do you know 24 vAse Vey stay? 25 MR. REINHART: Can we clarify who -they EFTA01110307 Larry Eugene Morrison - Volume I October 6, 2009 149 is? 2 BY MR. EDWARD$: 3 0. I uess it Is: David Mullen. 4 Tod Myster (sic). I pax. another pax, 5 and Jeffrey Epstein - and there's a crossed 6 out "Ghislaine Maxwell' so I'm assuming she didn't go. 7 A. Correct. 8 I have no Idea where they stayed. I 9 assume Jeffrey would stay In his home. would 10 stay in her apartment. As for al the others, I have 11 no Idea. 12 Q. Have you ever been to Jeffrey Epstein's home 13 in New Yak? 14 A. .kist in the lower level of the entryway. 15 Q. Why did you go? 16 A. To pick up bags for the trip to go to the 17 airport and load them. 18 0. Was there anybody else there with him? 19 A. I don't know with him. I never saw him 20 him. We saw the guy that ran the house. 21 Q. Who's that - Joe-Joe? 22 A. Joe-Joe would be there — 23 0. What's Joe-Joe's name? 24 A. Joe-Joe, that's alit know, and then 25 there's the actual house manager. Joe-Joe is more of 151 1 0. The next cue Is January 27. 2005. Palm Beach 2 to where? 3 A. St. Thomas. 4 Q. To St Thomas. 5 A. Right. 6 Q. And he has and and Jeffrey. 7 A. Right. 8 Q. Does he tell you what happens in St. Thomas? 9 What he does there? to A. No, no. Q. Ever heard that he imports underage girls from 12 Brazil to his — 13 MR. PIKE: Form. 14 0. — island in St. Thomas? 15 MR. PIKE: Form. 16 A. No, no, never heard that. 17 0. What does he tell you about his island in St. 18 Thomas? 19 A. Not a lot. I mean, he would sometimes 20 talk about construction stuff or I would hear him - 21 overhear him and Larry talk about the helicopter pad 22 that they're putting In, little stuff like that - all 23 construction. 24 0. Did he left you two or three times a day, that 25 he sexually abuses girls between 12 and 15 years old? 150 1 a driver, and then there's the house manager - I 2 forget his name. 3 But, yeah, we would meet — There's an 4 office In the lower level that the bags would be at 5 and we would put them in the back of the van, haul 6 them to Me airport. 7 Q. Who's David Mullen? A. I don't know. I heard of It. It sounds 9 familiar. I can't remember who he Is. 10 Q. Somebody that eves in New York, Palm Beach? 11 A. I don't know. I don't know. 12 Q. rm trying to keep them In order. 13 So coming back - you know, it looks like they 14 take to JFK: David Mullen, Tod Myster (sic). sons IS assE rs unnamed - they come back with only.. 16 and - any idea why? 17 MR. PIKE: Form. 18 A. No. butt mean, it's not unusual for 19 these guys to, you know, take somebody - let somebody 20 have a free ride to New York it they know them, they 21 are acquaintances, need a tilt, I mean, that's not 22 unusual. 23 Q. How's that come about - do you know? 24 A. No, I don't - phone conversations, 25 cocktail parties. I don't know. 152 A. No. 2 MR. PIKE: Form. 3 BY MR. EDWARDS: 4 Q. Not something he ever mentions. 5 A. NO, no. 6 MR. PIKE: row'''. 7 BY MR. EDWARDS: O. The next - 2/3/05 - who's on the passenger 9 list? 10 A. Jeffrey, M.= Jean Luc, David 1.1 Mullen. female, female, female. 12 Q. Any idea why they would list "female, female, 13 female: without listing the names? 14 A. No, just the same as — The only idea I 15 would have would be the same reasoning for the - 16 previously when they listed them aS just 'PAX - that 17 they didn't have any Idea who they were, what their 18 name was. 19 Q. I mean, certainly that's - 20 A. I don't know whose handwriting that is. 21 Q. You're guessing, though, right? 22 A. Yeah. No, I'm guessing. I have no Idea. 23 Q. Another guess would be there 12 years old 24 and you can't put them on it. 25 MR. PIKE: Form. EFTA01110308 Larry Eugene Morrison - Volume I October 6, 2009 153 1 A. I wouldn't say that. I don't know that. 2 Q. Have you ever been on an airplane where you 3 looked at this and you thought, "Hey, that's kind of 4 strange that they wouldn't list them by name. They're 5 talking about it generically: Female, female, female"? 6 A. But they also — 7 MR. PIKE: Form. A. another one: PAX, PAX, PAX 9 Q. You never thought that was odd either? 1 o A. No. I never actually even really paid 11 attention to this paperwork. I don't see this. 12 MS. EZELL: Brad, excuse me - this is 13 Kathy Ezell - is there a date on that manifest 14 you're showing? is MR. EDWARDS: Its 2f3/C6. 16 MS. EZELL: Thanks. 17 MR. EDWARDS: Is that your 12-year old 18 client listed as NO. 6? 19 MR. PIKE: Form. Move to strike. 20 MS. EZELL: No, but — 21 MR. EDWARDS: Okay, sorry, somebody 22 else's. 23 MS. EZELL: Okay. Thanks. 24 BY MR. EDWARDS: 25 Q. 2t7/05 - who's on there? 155 what it says. 2 A. It's — I think it's a 2 - 2/10. 0. Alright. Can you toll us who on that airplane? A. Jeffrey, looks like = - is that Jean Luc? 7 Q. Yeah. A. That's Jean Luc, I think, and 9 (sic). to Q. Jean Luc is another one who travels quite 11 frequently. Why, if you know, does he travel quite 12 frequently on these airplanes to and from New York with 13 Jeffrey Epstein - any idea? 14 A. My only assumption was business, and 15 that's just an assumption. 16 0. What kind of business do you know of that they 17 have in common? 1 a A. I was under the impression a modeling 19 business. 20 0. Other than the modeling agency. what other 21 business do they engage in together, if you knoW 22 A. I don't know. 23 0. And has Jeffrey Epstein ever talked to you - 24 a lard enough to whIch you could hear him discussing the 25 modeling agency? 3 4 5 6 154 1 A. Jan =, David Mullen, 2 Jansen. 3 0. Do you know who Jansen is? 4 A. No. 5 Q. David Mullen travels a lot. Do you have any 6 idea what his relationship is with Mr. Epstein? 7 A. I don't even know who David Mullen really 8 is. 9 0. Have you ever seen him? 10 A. I might be able to piste him if I saw a II picture of him. 12 Q. I mean, obviously you're on the airplane with 13 him a lot. 14 A. Yeah, so, I mean, obviously I would 15 recognize him if I saw a picture. 16 0. Do you know if he travels with anybody else on 17 this? 18 A. Unless it's that one name I don't 19 recognize - that Jansen, or whatever. 20 0. But Jansen's not somebody you know? 21 A. No. no. 22 0. I can't read that date - maybe you can. I got 23 a bed fax copy. 24 A. Maybe 2-2/10. 25 0. That's Michael Pike not wanting me to know 156 1 MR. PIKE: Form. 2 A. No, just that the only conversation he 3 ever - I remember - was the one that he - the one 4 about the girl opening the wrong door on the motor 5 home. 6 a Was he happy or sad about the modeling agent, 7 A. No, he was happy she wasn't injured, but 8 he was kind of making light of what a silty thing to 9 do. you know. 10 0. Do you know If Jean Luc is theme procuring 11 the models or is Jeffrey procuring the models? 12 A. I don't know. 13 MR. PIKE: Form. 14 BY MR. EDWARDS: is 0. You never investigated into how this modeling 16 agency is doing or anything else? 17 A. No, no interest. 18 0. You by to stay completely out of it? 19 A. Nokia:est_ 20 0. Especially in light of the recent things 21 you've read. 22 A. I mean, I didn't have any interest In It 23 before all the recent things. 24 Q. rin going to skip this one because it talks 25 about very similar people that you've already read. EFTA01110309 Larry Eugene Morrison - Volume I October 6, 2009 157 1 A. Okay. 2 Q. No different names. 3 MR. REINHART: Can we just get the date on 4 the record? s BY MR. EDWARDS: 6 O. Weil, actually, we don't have to skip it. 7 2/15/05 - that's the date, right? 8 A. Right. 9 Q. And it says: Ghislaine Maxwell — 10 A. Oki .= 11 Q. —S and 12 (sic); is that right? 13 A. That's what it says. 14 Q. Is that a typical crew that you would see on 15 the plane? 16 A. What year is this? In '05? 17 O. Yes. 18 A. Yes, but towards the end there, I think 19 the last year. I only saw Ms. Maxwell once. 20 Q. Do you know at any falling out of sorts that 21 Gltislaine Maxwel and Epstein had? 22 A. Well, no. I think they still - I think 23 she still has a lot of association, or whatever. 24 Q. Do you think they are still a couple? 25 A. I don't know that they ever were. I never 159 1 Stanleys are. 2 Q. Ever heard of them? 3 A. No. 4 O. As far as you're concerned, they're some islanders or something, right? I mean — 6 A. Well, they might be — I mean — MR. PIKE: Form. a A. -- there's a lot of wealthy people down 9 there. They might have been friends or associate 10 that needed a lift back stateside. it O. Fair enough. 12 What's the next one? 13 A. Teterboro to PBI. 14 O. And who's on it? 15 A. Jeffrey, s and-. 16 MR. REINHART: Can we get a date for the 17 record? 18 THE WITNESS: 2/24. 19 BY MR. EDWARDS: 20 O. It seems like and travel a lot 21 with Jeffrey. Is It ever your understanding that Jeffrey 22 Epstein had a sexual relationship with either of them? 23 A. That is not my understa • , no. 24 O. Do you know of having a boyfriend 25 ever? 158 1 did figure out the relationship, other than I assumed 2 they were a couple and she was a business assistant - 3 associate, but that was all assumption. 4 Q. Did you ever know of Jeffrey Epstein to have a 5 girlfriend, per se? 6 A. If it would have been, It would have been 7 Ms. Maxwell. 8 Q. Other than Ms. Maxwell, could you identify any 9 other female that appeared to be in a intimate 10 relationship with Jeffrey Epstein? 11 A. Not really, not that I - not that I cask! 12 say it was a relationship, no. 13 Q. I'm going to show you another one. I don't 14 know these people. Tell me who they are. It lodes lie 15 you're on the airplane — 16 MR. REINHART: Can we get a — 17 Q. -- and the date Is 2/21/05. 18 A. Right. 19 O. Which is ten days after the previous. It's 20 going — 21 A. I don't know who the Stanleys are. 22 Q. And it's going from the island. 23 A. To - 24 Q. Palm Beach. 25 A. -- Palm Beach. I don't know who the 160 1 A. I heard that she has a boyfriend. 2 O. And what's his name? 3 A. And this is just hearsay. I don't know. 4 O. I'm interested in hearsay. 5 A. I heard that she's dating somebody - 6 that's all. Q. Dating whom? 8 A. A guy — Somebody by the name of Story. 9 Q. Story Cowells (phonetic)? 10 A. I don't know his last name. 11 Q. How king has she been dating him? 12 A. I don't know. This is just Larry, you 13 know, every once in a while asks, you know, 'What's 14 gokya onT 'Whole -- You know, I dont know. 15 Q. Where does Story live? 16 A. I think he's down here. I think he's one 17 of Mr. Epstein's legal team or something or — 18 Q. And Story is somebody who you heard of through 19 Larry Visoski? 20 A. Yes, yes. 21. Q. And specifically what did Larry Visoski say 22 about Story? 23 A He thought that they were dating - he and 24 MI- and this is ad hearsay. 25 O. Since when? EFTA01110310 Larry Eugene Morrison - Volume I October 6, 2009 161 1 A. This is all — I don't remember. Some 2 time within - maybe within the year. I don't know. 3 I don't know. 4 Q. So it's your understanding then that if Story 5 Is In West Palm Beach or in the area, and he is dating 6 somebody named ," that it would also be a 7 fair presumption that would be somewhere 8 nearby as welt MR. PIKE: Form. LO A. I mean, that's not necessarily so. I 11 mean, in this day and age when you can get back and 12 forth to New York via airlines. or anywhere: I mean, 13 at times, yes, that would be a fair assumption, but 14 not continuously. IS Q. And what was the context in which the 16 conversation came up where Larry Visoski says, "MI 17 Ms • who you have very title knowledge. I mean, I 18 don't want to say 'very little knowledge" - you obviously 19 have seen her several tmes 20 A. Yes. 21 Q. — SIM is dating this person and his 22 name Is Story"? Obviously that's a strange name, so 23 that's something you would probably remember. 24 A. Right, right 25 a Otherwise. how would that come about? 163 1 attorney. 2 Q And what else does he tell you? I mean, there 3 are other changes other than. "Hey, Story's dating 4 le" A_ A couple of the - couple of long time 6 people at the ranch were laid off. 7 Q. Such as who? a A. Oh, God - Mike and Deidra. 9 Q. Mike and Deidra? 10 A Yeah. 11 Q. And those are people that run the Zorro 12 Ranch - 13 A They don't run it. 14 0. — in New Mexico? 15 A. They work there, yeah. And other changes 16 to the island. You know, I can't remember all the 17 names. I believe Adam, who was the chef, at the 18 island left. 19 MR. PIKE: Hello? 20 BY MR. EDWARDS: 21 Q. Adam's the chef at the island? 22 A. Yes. 23 Q. And why did he leave? 24 A. I don't — 25 0. Epstein's not around to cook for? 162 1 A. I don't remember how It came about 2 actually. I think I just - several months ago I 3 asked what people were doing since, you know, there's 4 been a lot of changes in staff since the boss was. 5 you know, detained. There's been a lot of layoffs 6 and stuff. The conversation was he was updating me 7 as to who's still around, who's been laid off, you a know, who's not with the company anymore, who's not with, you know, at certain houses. 10 0. When you say "the boss" has been 'detained," 11 the boss obviously is Jeffrey Epstein? 12 A. Correct. Yes. 13 Q. And you're having a conversation then with 14 Larry Visoskl about the changes that necessarily are 15 made - 16 A. Right. 17 0. -- because the boss Is — 18 A. Well — le 0. — either incarcerated or under house arrest, 20 or. whatever. 21 A. And the economy and everything, I mean. 22 0. In the course of that he tells something 23 about. 'Well. Story Is dating ." 24 A. Yeah, or - I think he said something about 25 one of Jeffrey - the paralegal or something, the 164 1 A Yeah. It may have been a layoff kind of 2 thing - and the economy too. Imam everybody's 3 affected. 4 O. What's your understanding about hike and 5 Deidra? 6 A. Just that they were laid off. I don't 7 know the exact reasoning that they were laid off. a Q. And before we go back to this: Have you ever 9 been to that Zolfo Ranch — 10 A. Yes. 11 Q. — In New Mexico? 12 A. Yes. 13 Q. How many times? 14 A. Several. 15 0. Why? 16 A. Because when we take them out there it was 17 too far to airline home, so we'd stay - stay at the 18 ranch. 19 Q. And what was he there to do? 20 A they° no idea. 21 Q. Wei. you were at the ranch, right? 22 A. Yeah, but Ws a big complex. There's — 23 The main house is literally probably 3 or 4 miles 24 from where we ay. 25 0. Was there also? EFTA01110311 Larry Eugene Morrison - Volume I October 6, 2009 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 165 A. I'm sum at times, yes, yes. Q. Well, I mean, usually he goes with his -- A. The normal 0. — his M. his Ghislaine. A. Yeah, his normal entourage, or whatever A Is. Q. And was somebody there to schedule his people to come over and see him on a daily basis? A. I don't know. I don't know how that waked. Q. He's — A. Like I say, he's up at the main house. Once we were at the ranch there's really no contact. Q. Yeah, but I'm familiar with where this ranch Is, and ifs kind of in the middle of nowhere, right? A. Yeah. Q. And. you know, so when people come to or from the ranch, I mean, you can't help but almost be familiar that somebody's coming. right? A. Well — MR. PIKE: Form. A. — I mean, you would see a car drive by or something or a truck. There's always a lot of activity, construction, and everything else going on. Where we stayed at Ranch Central, the 167 1 Mexico ranch? 2 A. Oh, no. no. 3 0. You don't remember that? 4 A. NO. Q. Could II have happened? 6 A. It could have. 7 0. But you just don't remember seeing that. 8 A. No, I don't ever remember seeing that. 9 0. Have you ever met Governor Bill Richardson? 10 A. I saw him. He was — 11 0. How did you see him? 12 A. He was at Ranch Central. He had been 13 invited for dinner, or something, at the main house to and they were coining down to pet him. 15 0. He was invited to the Zorro Ranch. I call it 16 that because that's apparently what Mr. Epstein's named 17 It, right? 18 A. Yes. 19 Q. So Bel Richardson came to the Zorro Ranch for 20 what? 21. A. I — It was a dinner meeting or something, 22 I don't blow. 23 0 Do 24 AL I think Mr. Richardson used to own the 25 property the ranch was built on, or something. I 166 I small, little - basically like little hotel rooms 2 where we stayed, you know, it was on a busy road 3 because there was always like a lot of construction 4 stuff and the ranch hands and everything up and down. 5 Q. Did you see gals going to visit him there? 6 A. Yes. 7 0. How often would girls go to visit him there? A. I don't know. 9 0. Did these — lo A. Not that often. 11 Q. Did these seem like girls local to New Mexico 12 or had they just flown In on an airplane. landed a 13 helicopter on the property? 14 A. Oh, I don't know. I never — is MR. PIKE: Form. 16 A. I never saw them up close. I mean — 17 Q. Did they come in taxicabs? is MR. PIKE: Form. 19 A. I can't remember that - don't think so. 20 Q. You don't ever think a girl came in a taxicab 21 to the New Mexico ranch? 22 A. I don't ever remember seeing a taxicab on 23 the ranch. 24 Q. Do you remember seeing girls two or three 25 times a day going to visit hkn while he was at the New 168 1 don't know. 2 Q. Did you stay for the driner? 3 A. Oh, no, no. I was down at Ranch Central 4 and he was just there while they were going to escort 5 him up b the main house. 6 0. So all Richardson was where Epstein was where 7 the dinner was. A. Yea. yea. 9 Q. And you were not there. 10 A. Of course not. 11 Q. Who else besides Bill Richardson was there? 12 A. I have no idea. 13 Q. Any knowledge of Bit Richardson being 14 Involved with any or the girls that would have been 16 brought to the house? 16 A. Oh, no, no, not that I have. 17 0. Not that I know c4. is A. Not that I know, no. 19 0. Because you were In such a place that you 20 never would have known anyway. right? 21 A That's correct, yeah. 22 0. What's your understanding as to Bill 23 Richardson's connection to Mr. Epstein? 24 A. I thotapt he was always just kind of '5 politics. I believe - I heard at one time, I don't EFTA01110312 Larry Eugene Morrison - Volume I October 6, 2009 169 1 know for -I thought that pad of the property 2 the Zorro was built on was owned by Bill Richardson. 3 lie sold it to Jeffrey. 4 Q. Ever known sa Richardson to be on Epstein's 5 airplane? 6 A. No, not the Boeing. 7 Q. Any plane. 8 A. I don't know that. 9 Q. Was he ever on a plane that you were on? 10 A No, not that I rumember, not that I 13. remember. I remember — I believe the only time I 12 met him was one time at Ranch Central. 13 Q. Ever hear of a trust - Zorro Trust? 14 A. No. 15 O. Are you farriliar with some of Epstein's 16 companieS? 17 MR. PIKE: Form. is A. No. I mean, other than JEGE and Hyperion 19 and Air Ghlslalne. 20 Q. What's Air Ghistaine? 21 A. That's the helicopters - that's what 22 they're under. 23 Q. He named it after Ghislaine Maxwell? 24 A. Apparently so. I would assume so. 25 Q. Wen, I mean, I'm not trying to be difficult 171 1 Q. You've never heard that? 2 A. No, no. 3 Q. Have you ever been privy to any conversations 4 between Bill Richardson and Jeff Epstein? 5 A. No. 6 Q. So you don't know what they were really 7 talking about. 8 A. No. No Idea. 9 Q. At the time when Bill Richardson was running 1 o for president - is that around the time when you rernembe 11 him being at Zorro Ranch? 12 A. Before, before. What year did he run for 13 president? 14 Q. 2007. 15 A. It had to have been well before because I 16 quit flying in February of O7, so. 17 O. Epstein ever tel you what his relationship is 18 with Bill Richardson? 19 A. No. 20 O. When you were at the ranch, did you ever 21 notice underage carts at the ranch? 22 A. No. 23 MR. PIKE: Form. 24 BY MR. EDWARDS: Q. Anybody ever told you that that ranch is used 170 1 with you. 2 A. No, I wouldn't -- 3 Q. rm assuming you're not trying with me either. 4 A. No. I would assume so. I mean, that's an 5 unusual name. 6 Q. Do you know Prince Andrew to be friends with 7 Jeffrey Epstein? M. PIKE: Form. 9 A. No, I don't know that I don't know what 10 the tie is. Like I say. I didn't know even know who 13. Prince Andrew is when I first heard of it. I would 12 have thought It would have been more of a be with 13 Ms. Maxwell. 14 Q. Right. Do you know of Ms. Maxwell bringing 15 the two, that being Prince Andrew. together with Mr. 16 Epstein? 17 MR. PIKE: Form. 18 A. That could be, yes, yep. 19 Q. And at the time when Bill Richardson had this 20 meeting at Epstein's house, do you remember Ghislaine 21 Isitaxwea also being there? 22 A. Can't say for sure. Can't say for sure. 23 O. Have you heard of Jeffrey Epstein winning the 24 lottery in New Mexico? 25 A. No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 172 to transport girls through Mexico to the ranch? A. No. MR. PIKE: Form. BY MR. EDWARDS: O. The next exhibit that rm going to show you - which Is all pot of Composite Exhibit 1 - is a !kohl log 2/24105; is that right? A. Yes. O. Who's on that? Nobody. That's a test flight? A. That's a test flight round robin. It's only 17 minutes. O. 3/1/05. A. 3/1/05 is FBI to Kennedy with Jeffrey, sus O. Do you know what his relationship is with 1= 7 A. No. Q. Do you know what she does for him? A. No, only — lsnl that the one that you told me - you just mentioned sadist? I have no Idea what her relationship is. Q. Has he ever told you what any of his employees actually do for him - why he employs so many people to do so many different things - has he told you that? k4R. PIKE: Form. EFTA01110313 Larry Eugene Morrison - Volume I October 6, 2009 173 1 A. No, no. I mean, you know. who runs each 2 house and who the driver is. stuff We that. No, he 3 would never mention that. 4 Q. Has he ever told you what ruming a house 5 entails? 6 A. No, no. 7 O. Has he ever toed you that there% an extra 8 pert of running the house that ensures that underage girb are going to be there for him every day? 10 A. No. 11 MR. PIKE: Form. 12 BY MR. EDWARDS: 13 0. That's not something you ever heard. 14 A. No. 15 0. 3/4/2005 f6ght bg - who's on it? 16 A. Jef . i Ghislaine Maxwell, David Mullen, 17 18 19 20 21 22 23 24 25 0. David Mullen - once again, we don't know who this guy is, do you? A. And I don't know. Honestly, I can't - Q. Do you know where he lives? A. No. Q. Did you ever go visit Jeffrey Epstein while he was in jail? A. No. 1 3 4 5 7 8 9 10 11 12 13 1.1 15 16 17 18 19 20 21 22 23 24 25 175 0. And despite pleading guilty to procuring underage girls for the purposes of sex, you shit feel comfortable leaving a 13. 14. 15-year-old girl around him? MR. PIKE: Form. Move to strike. A. Yes, I moan, with my daughter, yes. I don't know how he behaves around anybody else. I Just know that the respect that he showed me, I feel safe with my daughter. 0. And have you read in detai the reports as io what happened at his house with the gins? A. Only — MR. PIKE: Form. A. -- what's bean in the newspapers and pubashed. Q. if you read and hear testimony Oren - well, I can toll you now - testimony has been Oren In this case that what happens is: A13 or 14 year old is led upstairs by herself, told to get naked, he lays down on his back, there is a brief massage before he turns over. exposes himself erect, masturbates whhe he tells this 13 or 14 year old to pinch his nipples as hard as she can while he inserts his fingers into their vagina and ejaculates al over them before saying, 'Take your money and leave." 174 1 0. Why not? 2 A. There was no purpose to it. There was no 3 need to. 4 0. Ho's your boss for a long time, right? 5 A. Yeah. 6 Q. Was he good to you? 7 A. Yes. 8 Q. Did you support him? 9 A. Yes. 10 0. You supported him while he was in jail? 13. A. I was — Yes, I mean. 12 Q. Did the allegations bother you? 13 A. Yes. 14 MR. PIKE: Form. 15 BY MR. EDWARDS: 16 Q. Somebody that you still support despite the 17 allegations? 18 MR. PIKE: Form. 19 A. Yes, yes. 20 Q. You realize that he did plead guilty to the 21 offenses as well, right? 22 A. That's what I read. 23 MR. PIKE: Form. Move to strike. That's 24 not the facts. 25 BY MR. EDWARDS: 176 MR. PIKE Form. Move to 2 BY MR. EDWARDS: 3 O. Okay? Then, "You can continue to come back 4 for 5200 every time or every girl you bring me within 5 year age group and I get to do this again. I pay you S20'I 6 per person." If that Is the testimony -- 7 MR. PIKE: Form. 8 Q. - that what happens behind dosed doors with 9 Nm, do you still feel oomfodable leaving a 13 or 14 10 year old in a room with Jeffrey Epstein? 11 MR. PIKE: Form. 12 A. If that, In fad, Is what actually 13 happened, no. 14 Q. t1l snow you the new flight log Is 3/EV05. is Hot just so these are in order, Ill • 318/05. 16 A. Okay. 17 Q. Who's on that aae? A. - Jeffrey. M. and 19 Q. Seem to be people that he travels with 20 frequently. 21 A. Yes, normal - his normal entourage. 22 Q. Have you read recently the agreement that was 23 entitled the 'Non-Prosecution Agreement" 24 A. No. All I read was what was in the paper. 25 O. The 'Non-Prosecution Agreement' was an EFTA01110314 Larry Eugene Morrison - Volume I October 6, 2009 1 2 3 4 5 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 177 agreement between Epstein and the government where the govetnrnent weed, 'We're not going to prosecute you for only the sex crimes we Mow about.' and n that they also agree not to prosecute Jeffrey Epstein, Min M t or A. Okay. O. — as his coconspirators. Do you knots any of the acts that M, or have done in an attempt to get Jeffrey Epstein young gids to molest? A Only what I've read in the paper. MR. PIKE: Move to seam. BY MR. EDWARDS: O. Again. Jeffrey Epstein, Chistaine Mamma, and who's that? MR. REINHART: Can we get a date, please? BY MR. EDWARDS: Q. Sorry, the date is 3/18/05. On this flight log, who are the names? A. ChIslarne - Jeffrey, Chastens Maxwell, and O. Do you know Chislaine Maxwell on a social level or only from Minn? A No, just professional. Q. Do you know whether she is straight or 179 1 O. This is the first time we've seen 2 mentioned on any flight logs. right? 3 A. Right. 4 O. Do you find it at all peculiar that 5 Is listed but certain other people who may or may not be 6 of ago am listed generically-one female. Why would 7 they go out of their way to list la a MR. PIKE: Form. 9 A. I don't know. Maybe she was already an 10 employee or something. I don't know. 11 O. If she's an employee at the time, then that 12 would be a good explanation, right? 13 A. Right. I don't know. 14 O. If she's not an employee, then is there any 15 explanation? 16 MR. PIKE: Form. 17 A. Unless No. I don't know. I don't 18 know. Maybe Big asked her. That looks like Bill's 19 %wiling there when he was captain. 20 O. We'll move to 3/22/05. 21 A. Okay. 12 a. Who's listed? 24 This Is: Jeffrey, =, female, A. Actually, this wasn't even al ir. ten 1 e 23 25 - PSI to Kennedy. 178 bisexual? Do you know of any of her girlfriends? 2 A. I do not know that. 3 Q. Are you aware that Gastaine Maxwell. In swam 4 testimony and in complaints, has been alleged to have 5 used vibrators, dildos, and have sex with these underage 6 gins as well? A. I don't MR. PIKE: Form. 9 A. I was not aware of that. 10 O. Do you know who is? 11 A. I think = used to be her assistant at 12 her home. 13 Q. Used to be Ghislaine Maxwell's assistant? 14 A I belive so, yeah, because "IM/' an 15 unusual name. 16 O. Do you know if is underage or if she is 17 of age at the time that this happened - at the time they 18 list her name? 19 A. Oh. I don't know for sure, but, I mean, 20 the - when I - if it Is the I remember, 21 she was older. I mean, I cant even guess her age. 22 mid-twenties, late twenties. I mean. 23 O. Okay. Dan - 24 A. If it's the= I remember. it was her 25 assistant at the house. 180 1 O. That's not your flight? 2 A. No. George Diaz is one of the few 3 engineers I used as a relief. See his name written 4 In up there? 5 O. Yes, but it has your name written under it 6 right? 7 A. Well, yeah. because these are pre-printed 8 forms. They neglected to scratch my name out. 9 O. Any Idea why now they're going to list "one 10 female, one female? That doesn't seem to be protocci 11 here. does it? 12 A. I don't Yeah, I have no idea. I don't 13 have an answer for that. I really don't 14 O. Certainly, if you're able to gel to 15 leg you her name. it doesn't take much effort to get Iwo 16 other people to tell you their name, right? 17 A. Like I say, the only thing I can think of 18 IS d an employee by that time, that they knew 19 her. I don't/31OW. 20 O. Did it ever at any point in time cross your 21 mind that there may be something illegal going on here - 22 ever? 23 MS. EZELL: Form. 24 MR. PIKE: Form. 25 A. Define "hem." EFTA01110315 Larry Eugene Morrison - Volume I October 6, 2009 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 181 Q. Here when youYe traveling on the airplane with these various girls and they're listed as "one female" - generically listed - anything ever cross your mind, "maybe something's not exactly kosher"? A. No. MR. PIKE: Form, asked and answered several times. BY MR. EDWARDS: Q. Who's that? The date is 3/31/05. A. Jeffrey, Ghistaine, and M . O . Let's see, 10/15 and 10/17, both look like nobody's on them, so ill show them to you together. A. There might be remarks here: "Maintenance test flight out of Lake City, Florida. We were coming out of maintenance: "No passengers, maIntenance, relocation for the engineer repair? Q. Okay. 4/6/05 - who's on it? A. Jeffrey, David Mullen, Q. Last One. A. Jeffrey - 6/8/05 David Mullen, Mark Zeff •- Q. Do you know who Mark Zeff is? A. No Daniell, Doug Shuttle, M. 182 1 O. Do you know who Daniell and are? 2 A. I think I remember - sounds familiar. a Q. How did she look? 4 A. I can't remember. I just — O. Overage, underage? 6 MR. PIKE: Form. 7 A. !never saw any that I saw that looked to 8 me underage. 9 O. Have you ever been to Jeffrey Epsteln's house 10 - his Palm Beach house? 11 A. Yes. 12 O. You stayed for an entire day? 13 A. No, no. 14 Q. No? 15 A. It would be like an hour at the most 16 waiting to talk to him for a minute. No. 17 Q. Let me ask it this way: Has he ever told you 18 that he's infatuated with massages? 19 A. No, he's never told me that. 20 MR. PIKE: Form. 21 BY MR. EDWARDS: 22 Q. Have you ever known him to get a professional 23 massage anywhere you go? 24 A. Yeah, I believe so. 25 Q. Where? 183 1 A. I can't I can't say for sure. I mean, 2 we used to carry a massage table on the airplane. 1 3 never saw one used. I don't know for sure. 4 O. Are you being paid to be here today? 5 A. No, no. I mean, I'm on salary. I mean — 6 O. Right 7 A. -because of- for the maintenance, but, 8 no. 9 Q. Are you going to ask Jeffrey Epstein at some 10 point in lime, "Why you tired an attorney to sit here 11 with mer 12 A. No. 13 MR. PIKE: Form. 14 A. I would never I would not approach 15 Jeffrey for that. 16 O. Do you have any idea why Jeffrey Epstein might 17 want an attorney to sit here for you? 18 MR. PIKE: Form. 19 A. No. I mean, maybe — I don't know. 20 O. Do you think that the attorney sitting here is 21 for the purpose so that you don't say anything to 22 Incriminate Jeffrey Epstein? 23 A. No, no. I was told strictly that he was 24 here upon my betel!. 2s O. Do you know of any alines, personalty, that 184 1 you witnessed Jeffrey Epstein committing? 2 A. No. 3 Q. Would you -- 4 A. No. 5 O. — go baCk - considering what you've read and 6 what you may or may not believe - woukl you go back to 7 working for Jeffrey Epstein? 8 MR. PIKE: Form. 9 A. I can1 say. I still work for him on a 10 maintenance - to maintain the airplanes and stuff 11 like that, so. 12 Q. You're on his payroll? 13 A. Salaried, yes. 14 O. Do you know who else Is on his payroll? 15 A. Well, Dave and Larry. 16 Q. Certainly, if I want to know more about his 17 private life - do you know who's at his house? 18 A. No. 19 Q. Do you know who his housekeeper Is? 20 A. No. 21 Q. Do you know who his architect is? 22 A. No, no. 23 O. Does Larry visit him at his house? 24 A. I would assume so. 25 O. Why do you say you would assume so? Thal EFTA01110316 Larry Eugene Morrison - Volume I October 6, 2009 185 1 means he kid you something, right? 2 A. Well, he handles — Jeffrey does a lot of 3 - he likes high-end stereo equipment and video 4 equipment, and Larry is an expert at audio and video s installations and stuff. 6 O. How about David Rodgers - ever at his house? 7 A. Probably, but more like on the grounds of 8 me, you know. 9 Q. Any other famous people that you met through 10 Jeff Epstein? 11 A. On the airplane? 12 Q. Yes. 13 A. Walter Cronkite. 14 O. Oh, yeah? 25 A. He vas very nice. Yeah. He vas very 16 feeble, but he was very nice. We had to carry him 17 down the steps. 18 0. Where did that flight go to? 19 A. New York to SL Thomas. He's an avid 20 saior. He loves to sail or loved to sea. 21 Q. What's the magician's name - David 22 Copperfield? 23 A. No, I don't think I was on that. I don't 24 think I flew that. I heard that we had flown him. I 25 Can't say for sure. I would remember that. I would 187 1 A. Yes, I guess. Yeah. I don't know 2 exactly. 4 soun 3 Q. Have ever heard of A. ds familiar, but I don't 5 know — 6 Q. Model? New York? 7 A. No, t can't say that I have. 8 Q. 9 A. Can't say that I have. 10 Q. Glenn Dubin? 11 A. Glenn Dubin, yes. 12 0. How do you know him? 13 A. I think he's a money or finance manager of 14 some form - associate of Jeffrey or Ghislaine's or 15 both. 16 Q. And where does he live? 17 A. I think he lives in California, I believe. 18 Q. What do you know about him? 19 A. Well, he's- Just alit Just told you. I 20 think he's - he's an options writer or something like 21 - not an options yeller, hedge funds or something 22 like that. He's In money. It's -- He's got an 23 airplane. I think he's got a quarter share or part 24 of an airplane. 25 Q. Do you know anybody that owns any property 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 186 remember it. I have never met David Copperfield, but I heard that we had. Naomi Campbell - flew her a couple times. Q. What do you understand Naomi Campbell and Jeffrey Epstein's relationship to be? A. I don't. I assume It was modeling. I don't know. It was like two trips. Q. Jeffrey Epstein ever tell you how long he was in the modeling Industry? A. Never discussed it. Q. So the first you know of Is whatever involvement he's in with Jean Luc Brunel. A. Right. O. That's the first lime — A. Yes. Q. - you've never known him to be In mocking. A. Correct, that I was aware of. And, actually, nobody ever told me that but picking up bits of conversation like such as the one about the motor home door. Q. What exactly did he say about the motor home door that led you to know that Epstein and modeling Is — A. They were at - on location for a modeling shoot and they had a motor home. Q. 'They meaning Jeffrey Epstein and somebody. 188 1 with Epstein? 2 A. No. 3 O. What other properties does Jeffrey Epstein 4 own? I known tared about the Zeno Ranch, the place 5 in New York, you talked about an island, West Palm Seac^ 6 A. That's all that rm aware of. 7 Q. How about Paris? 8 A. I don't know that he ovals them. That's 9 where he goes for homes 10 Q. Ever go to Paris with him? 11 A. He does have an apartment in Pans. I 12 daft know - however that works out. if it's a lease 13 organ or what. 14 Q. Who are the house managers of the various 15 places that he owns? 16 MR. PIKE: Form. 12 A. I don't know anymore. There has been so 1e much shake up. you know. 19 Q. Well, who were they? Do you knoll the 20 Freldmons out in Cakifornia? Do you know Eve and 21 Patrick? 22 A. No. 23 a. Alfredo Rodriguez? 24 A. No. 25 O. Alright EFTA01110317 Larry Eugene Morrison - Volume I October 6, 2009 189 1 A. No, those are all I know. 2 0. You tell me. Who do you know? 3 A. God, I can't think. It's been so long 4 ago. 5 0. Other than Joe-Joe. 6 A. Well. Joe-Joe doesn't - he's just a driver 7 for New York - he and his wife. I could remember 8 them If I saw their names. I would know which house 9 they were associated with. I'm terrible with names 10 anymore, unfortunately. The couple that's now at the 11 ranch or was at the ranch is at the Island helping 12 manage as an intern. 13 O. Who's that? 14 A. Honestly, I can't remember their names. 15 If you were to give me a name, I David attach it to 16 each house. 17 0. I wish I could. 18 A. Yeah, I'm so . I can't. Ifsjust- 19 Q. Do you know 20 A. No. sounds familiar. I don't 21 know. 22 a Something to do with the modeling agency? 23 A. Can't say for sure -cant say. 24 a How about Kalib Shalom? 25 A. No, never heard of that one. 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 191 0. Do you remember a young woman name. whc flew frequently with Jeffrey Epstein? A. No, I don't recall a V. 0. You mentioned a M? A. AM. yes. I remember the name M. 0. Can you describe-? A. No, I'm sorry, I cant I just recognize the name - or the sound of the name. 0. Do you have any recollection as to what period of time MI flew with Mr. Epstein? A. It was on one of those Passenger Manifests. I thought I only saw it one time. MR. REINHART: Kathy - this is Bruce - the passenger manifest that had that name on It was dated June 8, 2005. MS. EZELL: So all of those that Brad went over were134 and '05. I believe. MR. REINHART: Correct. BY MS. EZELL: Q. Let's see, did you ever fly Mr. Epstein to SL Louis? A. No. 0. Did you ever fly him to San Francisco? A. No. 0. What about France? 190 1 MR. EDWARDS: Let me look over my noise 2 real fast. Anybody else going to have some 3 questions so I can look over my notes and maybe 4 ask a couple more? MR. F1KE: Brad. when I get a chance to C cross, I definitely will have some questions for 7 the witness. 8 MR. EDWARDS: Okay. Any other plaintiff 9 attorneys? Kathy? I think Kathy quit on us - 10 must have been too boring. Anybody else? 11 Hold on Mike. Give me one minute and then 12 I think you can shod. 13 MS. EZELL: Brad? 14 MR. EDWARDS: Yes? ts MS. EZELL: rm sorry. it's Kathy. I 16 didn't realize my mute was on. I do have a few 17 questions. 18 MR. EDWARDS: Okay. Go ahead. 19 CROSS-EXAMINATION 20 BY MS. EZELL: 21 0. Mr. Morrison - forgive me. I didn't write it 22 down - when did you begin working for Mr. Epstein? 23 A. January 2001. 24 0. Do you ran fiber a young woman name 25 A. No, frn sorry, I can't - I dart. 2 3 4 5 6 a 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q. A. 0. A. area? 192 Yes, Paris. Md Spain? No. nope. Carmel? Carmel? MR. REINHART: California, Kathy? MS. EZELL: Yes. No, we wouldn't have — Was that Monterey MR. REINHART: Yes. A. Yes. 0. Monterey you did, okay. Do you remember a woman named - who wo..4 accompany Elaine (sic) fAinweil? A Yes, I remember I Save she was Brttish or — O. Md Slat was her functon7 A. To the best of my knowledge she was Ms. Maxwell's assistant. 0. Did there come a point in lime where Ms. Maxwell flew her own plane? A. No. 0. Did there come a time that you became aware that she and Jeffrey Epstein were %Mg separately? A. Yes. EFTA01110318 Larry Eugene Morrison - Volume I October 6, 2009 193 1 Q. And whose plane would she fly on on those 2 occasions? 3 A. I don't know. There was - She had a 4 fractional - of a flight options. She had some 5 flight options. When you said - Can I ask - 6 Q. Yes. 7 A. - when you stated, 'Did she fly her own 8 planer. did you mean as a pikit? 9 a Yes. yes. 10 A. No, no. I stand with, no. 11 O. Did you ever know her to fly a helicopter? 12 A. Yes. 13 Q. And when was that? 14 A, Several times. I don't remember exactly 15 when she got her initial rating. Can't remember 16 exactly when she got her Initial rating. It was 17 before - I think before - maybe around 2000. 2001. I 18 don't know that fora fact. 19 a Among the various pilots that you have worked 20 with for Jeffrey Epstein. do you know of any who has a 21 house on the Zorro Ranch property? 22 A. Yes. 23 Q. And who is that? 24 A. !any Visoskl. 25 Q. And do you know If he was given that house by 195 1 A. I can't say that I have, no. I can't say 2 that I did. 3 O. Do you remember flying three young girls back 4 to France after Mr. Epstein's birthday party? A. No, no, I can't say that I do, and I 6 didn't remember what birthday - that there was a big 7 birthday party. 8 Q. Okay. Well, forget the party part. 9 A. Okay. 10 Q. Were you aware that Mr. Brunel flew in three 11 12-year-old girls for Mr. Epstein's pleasure on his 12 birthday? 13 A. No, I was not aware of that, no. 14 O. And you have no recollection of having young 15 women that young on Sghts that you were flying on? 16 A. That's correct. 17 MR. PIKE: Form. 18 BY MS. EZELL: 19 Q. I don't have any other questions. Thank you. 20 A. Thank you. 23. MR. EDWARDS: Mike. I don't really think 22 anybody - I'm sorry. 23 CROSS-EXAMINATION 24 BY MR WILLITS: 25 O. Richard Willits here. I just have one 194 1 Jeffrey Epeteln? 2 A. I do net know. 3 O. Were you ever given any properties by Mr. 4 Epstein? 5 A. No. 6 O. You said that you did know Mr. Jean Luc 7 Brunel? 8 A Yes. I knew of him - and it was as an 9 acquaintance - as a passenger. 10 D. Did you fly him to and from Paris? 11 A. Yes. 12 Q. Do you ever remember flying three girls from 13 Paris for rile. Brunel — 14 MR. PIKE: Form. 15 O. — to be guests of Mr. Epstein? 16 MR. PIKE: Form. 17 A. I can't say that I remember that exactly, 18 no. and I didn't ;mow who - whose guests they were 19 for who. 20 Q. Do you remember flying three young girls to 21 Mr. Epstein's birthday party? 22 MR. PIKE: Form. 23 A. I dealt — 24 Q. fm sony. I meant from France. 25 MR. PIKE: Form. 196 question, sir. I didn't catch the complete and full 2 spelEng of your name. 3 A. My name? 4 O. Yes, sir - the witness? A. Its Larry- Lima. Alpha. Romeo, Romeo. 6 Yankee • and last neme Is Morrison - Oscar, 7 Romeo. Romeo, Ina., Sierra, Oscar, November. a Mt WILLITS: Thank you. sir. 9 We. EDWARDS: Mike, shoot. 10 Mt PIKE: Thank you. Thank you. 11 CROSS-EXAMINATION 12 BY MR. PIKE: 13 Q. W. Morrison, my name is Michael Pike. I 14 represent Jeffrey Epstein. 15 A. Hi. 16 Q. rm going to ask you a couple of questions. 17 If you do not hear me, please ask me to repeal the is question - as ha on a telephone - and by virtue of being 19 on the telephone, I've noticed that there's some lag time 20 bellween some answers and responses. 21 tat PIKE: So, Brad, interrupt me. if I'm 22 talking over the witness as well. 23 BY MR. PIKE 24 Q. Mr. Morrison. Mr. Edwards was taking to ym. 25 about your knowledge and information regarding passengers EFTA01110319 Larry Eugene Morrison - Volume I October 6, 2009 197 1 on Mr. Epstein's plane from January 1, 2001. up until the 2 time you slopped flying. Do you recall some of those 3 questions? 4 A. Yes. 5 Q. With regard to the female passengers that Mr. 6 Edwards discussed with you, do you recall if any of them 7 ever left the plane in a scared manner? A. No, no. 9 Q. Did any of these girls ever appear to be 10 disheveled to you in any way? 11 A. No. 12 Q. Did any of these girls that were on the plane 13 ever claim to be battered or sexually assaulted? 14 A. Not to me, no. is Q. Did any of these women appear to be in shock 16 lo you? 17 A. No. 18 MR. EDWARDS: Object to the form. 19 BY MR. PIKE: 20 O. Were any of these women ever crying as they 21 exited the plane when you %sere the pilot? 22 A, No, not that I saw. 23 Q. Did any of these women appear to be injured as 24 they exited the plane when you were a pilot? 25 A, No, not that I saw. 199 1 first 2 MR. PIKE: I have no further questions. 3 MR. EDWARDS: I have a couple more -just 4 follow-up- from what Kathy asked. REDIRECT EXAMINATION 6 BY MR. EDWARDS: 7 Q. Did any of the people - along Mike Pike's a lines - did any of the girls on the airplane tea you 9 that he pied guilty to two felonies in court? 10 MR. PIKE: Form. 11 A. No, I haven't - I have not spoken to Mr. 12 Epstein. I don't believe — 13 Q. No, no. Mink the question was: Did any of 14 the girls tell you that M. Epstein pled guilty in court? 15 A. Which girls? 16 Q. Any of the girls on the airplane that we're 17 talking about. 18 A. No, I don't think — Actually, I don't 19 know when he pled because I think I was - slopped 20 flying Python. 21 Q. So there were a lot of things that happened on 22 the airplane that the girls didn't necessarily tell you 23 about, right? 24 MR. PIKE: Form. 25 A. That I wasn't — Like I say, going back to 198 1 Q. Did any of these women ever tell you, as the 2 captain of the plane, that they were forced to do 3 something against their will while a passenger on the 4 plane? MR. EDWARDS: Object to the form. 6 A. I was -- Actually, to correct the 7 question, I guess I was not captain - I was flight 8 engineer - but, no. 9 Q. Did they ever tail you that they had been 1.0 forced to do anything inappropriate? 11 A. No. 12 Q. Did they ever tell you that they had been 13 assaulted in any way? 14 A. No. 15 Q. Did they ever tell you that they had been 16 Inappropriately touched in any way? 17 A. No. 18 MR. EDWARDS: Form. 19 BY MR. PIKE: 20 Q. Did they ever tell you or did you ever hear of 21 anyone claiming that they had been sexually assaulted, 22 battered, or raped while on the plane? 23 MR. EDWARDS: Form. 24 A. No. 25 MR. REINHART: Give him a chance to object 200 t. - there was not even an opportunity Or window rrr '3 that question, because I believe it was after February of '07. 4 O. That's true. 5 Did any of the girls on the airplane tell you 6 about things that happened on the *plane that he later 7 pled guilty to? 8 MR. PIKE: Form. 9 A. No. 10 O. Did any of the girls on the airplane really 11 talk to you? 12 A. No. 13 Q. Okay, seal of this is kind of silly. 14 Alright. Got it. 15 would accompany Ms. Maxwell. When you 16 sayNomad accompany her," what did you mean about that? 17 A. She was like her assistant. Actually. I 18 don't— I didn't see very many firnes. I daft 19 know when she stopped working there, but she would -- 20 Yeah, I just — She would be on trips with her -- 21 O. And dd you — 23 A. — and. I think. handle her logistics 23 issues and stuff rike that. 24 (Please continue to Volume II.) 25 EFTA01110320 Larry Eugene Morrison - Volume II October 2, 2009 201 IN TEC CIRCUIT CART OF THE 15113 01.1DICIAL CIRCUIT DI MAD FOR MLR WO( COLIIITY, FLORIDA VOLSCI IT Pagel 201 to 211 1 1 Plaintiff, 1 1 JRPPREY EPSTEIN. /Case Ifo. 502001CA0213051 IXICO2S AD Der teAant / CEPOSITiON OF LARRY ZOOM MORRISON TAKEN ON BEHALF OP THE PLAINTIFF October 6, 2000 515 H. Fleglex Drive Rost Pala Beach, FL 33401-4321 Jeoelfer Dilorente, court reporter 203 1 APPEARANCE OF COUNSEL 2 On behalf of the Defendant by telephone: 3 BURMAN, CRITTON, LUTTIER & COLEMAN BY: MICHAEL J. PIKE, ESO.. 4 515 N. Sevier Drive Suite 400 act% FL 33401 6 7 8 On behalf of the witness: 9 LAW OFFICE OF BRUCE E. REINHART BY: BRUCE E. REINHART, ESQ., 10 One Cleatlake Center 250 S. Australian Avenue 11 Suite 1400 12 13 14 15 16 17 18 19 20 21 22 23 24 2S 1 2 3 1 S 7 9 10 12 13 24 15 16 27 2$ 10 20 21 23 21 24 25 202 APPEARNIZES CC COUNSEL On Seal cite Pear L1.4 ROTHSTEN. ROSENFELOT & ADLER BRADLEYJ. EVNARDS. ESO and MICHAEL WHEELER ESQ.. 401 East Las Ols FOlievald 1603 FL 31394 On WS of Rotas Jsne Doe 2 though It liERVELSTEN 8 HOROWITZ. PA BY: JESSICA D. ARBOUR. ATTORNEY-AY-LAW. 18205 escape Scueverd SUM 2214 On Detail al MM., Ana Ds 101 and 102 by k1ephrol: PCOHURSTORSECK PA BY: KAINERSIEW.E2ELL ATTORNEY-AT-LAW. 25 W. F192W Wee On Wad of In. Parr! C by lelegyne. LAW OFFICE Of RICHARD WILLITS, PA. BY/ RICHARD MUT& E . 2290 101hAsnue Ste 404 Lake Watt A. 3:3461 aim 1 2 3 4 204 INDEX OF EXAMINATION WITNESS: LARRY EUGENE MORRISON Page 6 REDIRECT EXAMINATION By Mr. Edwards #205 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX TO EXHIBITS (NO EXHIBITS) EFTA01110321 Larry Eugene Morrison - Volume II October 2, 2009 205 1 The Redirect Examination by Mr. Edwards continued from 2 Volume I as follows: 3 Q. Do you even know what 'work' would mean for 4 Ms. Maxwell? MR. PIKE: Form. 6 A. No. I could not define her job 7 description. 8 Q. I mean. would it surprise you if she was Ms. 9 Maxwell's lesbian sex slave? to MR. PIKE: Form. 11 A. That would surprise me. 12 Q. Okay. Be surprised. 13 DM you have to sign a confidentiality 14 agreement at any point in time to work for Ms. Maxwell 15 andfor Jeffrey Epstein? 16 A. I may have when I first hired on - 17 standard protocol. I don't-- I can't remember for 18 sure. I may have. 19 Q. Do you have a copy of that confidentiality 20 agreement? 21 A. Oh, I doubt it. It's been so long. I 22 doubt it. 23 Q. Were you allowed to keep a copy of d or did 24 theykmpit? 25 A. Honestly, I cannot remember. 207 1 A. No, no. I don't remember going places anc 2 bringing people back that we didn't have. you know. 3 that was with us originally, you know. 4 Q. But considering how you were somewhat cadonen from the rest of the plane, would you always knew if you 6 brought somebody back? 7 MR. PIKE: Form. 8 A. I can't say a hundred percent of the time, 9 but most, yes. You — Because, you know, you've got 10 additional baggage. I was always downstairs loading t 1 bags while the passenger was boarckng. but. 12 O. So if there were three gins that boarded an t 3 airplane, came back with Jean Luc Brunel and Jeffrey 14 Epstein, from your testimony, you either dd not see them 15 or k happened to be a Hight that you Just weren't on. 16 A. Well, I was - more than Nicety I was on 17 the flight. but I can't remember that exact passenger 18 Configuration — 19 Q. Okay. 20 A. — as far as number of passengers. 21 MR. EDWARDS: AkIght. I don't have 22 anything else. tiniest anybody else does, rm 23 sure there's going to be an instruction to read 24 or verve. 25 MR. REINHART: Hell read. 206 1 O. How do you know Larry Visoski has a place at 2 the Zone Ranch? 3 A. Because I visited it when we're out there. 4 It's where he stays when we stay down at Ranch s Central. 6 O. Did he toll you what he did to get that ranch? 7 A. No. Q. I mean, he certainly didn't say he paid for It 9 himself, did he? 10 A. Well, no. I didn't ask. I would assume 11 that I would assume IL 12 Q. When you say you flew Jean Luc Brunel b and 13 from Parts, was that in the company of Jeffrey Epstein? 14 A. Oh, yeah. I never -- Boeing never went 15 anywhere without Jeffrey. 16 Q. I know you said you don't remember three girls 17 coming back. Are you saying that didn't happen or you 18 just dent remember it? 19 A. I don't remember that 20 Q. So whether it happened or whether it did not 21 happen. you have no knowledge of if? 22 A. I can't remember that, no, I do not. 23 Q. Do you remember going to foreign countries and 24 bringing back any gitts? 25 MR. PIKE: Form. 1 2 3 4 5 6 8 9 10 12. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 208 MR. EDWARDS: He'll read. (The deposition concluded at 2:20 p.m.) EFTA01110322 Larry Eugene Morrison - Volume II October 2, 2009 209 211 1 CERTIFICATE OF OATH 1 CORRECTION SHEET 2 2 RE: Lta ye NOW ESMerin Case No. 1302038CA020051 3 3 Deposer) of. LARRY EUGENE MORRISON 4 4 2120.1 October 6, 2009 $ PAGE NO. WE NO. CCOREOTCN CR CHANG,- 6 STATE OF FLORIDA ) 6 COUNTY OF BROWARD ) 7 9 10 I, the understood authority, certify that 11 LARRY EUGENE MORRISON persor.afty appeared before me 9 13 6930 Wats Ally sworn. 10 13 14 11 15 WITNESS my hand and Oda& seal this 12 16 10th day of October. 2005. 13 17 18 la 15 EW —pwiaitperfay. I dociare Omit** ie 19 try dweller' arel SWIM true antIterreet 8113903 20 16 to tery changes in lamer substance entered lore 17 21 JENNIFER D. DILORENZO Strad 0* day of 2009 Notary Public • State of Florida /6 19 22 My Commission No. DD 747526 LARRY EUGENE MORMON. Deporent Expires: March 7, 2012 20 21 21 22 29 23 20 35 as 210 1 REPORTER'S DEPOSITION CERTIFICATE 2 STATE OF FLORIDA ) 3 COUNTY OF BROWARD) 4 5 I, JENNIFER D. DiLORENZO, Shorthand Reporter, certify that I was authorized to and did stenographically report the deposition of LARRY EUGENE 8 MORRISON; that a review of the transcript was 9 requested; and that the transcript Is a true and 10 complete record of my stenographic notes. 11 I further certify that t am not a 12 relative, employee, attorney, or counsel of any of the 13 parties, nor am I a relative or employee of any of the 14 parties' attorney or counsel connected with the 15 action, nor am I financialy interested in the action. 16 17 Dated this 10th day of October, 2009. 18 19 20 21 22 JENNIFER D. DiLORENZO, Shorthand Reporter. 13 24 2S EFTA01110323 Larry Eugene Morrison - Volume II October 2, 2009 Page 1 broward 209:8 court 201:1,22 examination 204:1 instruction 207:23 A action 210:15,15 210:3 critton 203:3 204:6 205:1 interested 210:15 ad 201:7 brace 203:9,9 exhibits 204:13,15 additional 207:10 brucereinbartlaw D expires 209:22 J adler 202:3 203:12 dated 210:17 ezell 202:16 Jane 202:8,14 agreement 205:14 brune1206:12 day 209:16210:17 jarbour 202:12 F 205:20 207:13 211:17 Jean 206:12 207:13 airplane 207:13 burman 203:3 dd 209:22 far 207:20 Jeffrey 201:8 allowed 205:23 declare 211:15 fmancially 210:15 205:15 206:13,15 C alright 207:21 defendant 201:9 first 205:16 207:13211:2 cant 205:17 206:22 anybody 207:22 203:2 11201:16 202:5,11 I 201:22 aol 202:23 207:8,17 define 205:6 202:17,22 203:5 209:21 210:5,22 appearance 203:1 case 201:7 211:2 deponent 211:19 203:11 202:10 appearances 202:1 center 203:10 deposition 201:12 Hagler 201:16 job 205:6 appeared 209:11 central 206:5 208:3 210:1,7 202:16 203:4 judida1201:1 arbour 202:10 certainly 206:8 211:3,15 flew 206:12 K assume 206:10,11 certificate 209:1 description 205:7 flight 207:15,17 attorney 210:12,14 210:1 didnt 206:8,10,17 florida 201:1 209:6 202:16 attomeyatlaw certify 209:10 207:2 209:21 210:2 keep 205:23,24 202:10,16 210:6,11 dilorenzo 201:22 follows 205:2 knell 202:18 australian 203:10 change 211:4 209:21210:5,22 foreign 206:23 know 205:3 206:1 authority 209:10 changes 211:16 doe 202:8,14 form 205:5,10 206:16207:2,3,5 authorized 210:6 circuit 201:1,1 dont 205:17 206:16 206:25207:7 207:9 avenue 202:21 clearlake 203:10 206:18,19207:1 211:16 knowledge 206:21 203:10 coleman 203:3 207:21 fort 202:5 L com 202:6,7,12,18 doubt 205:21,22 further 210:11 B 202:23 203:6,12 downstairs 207:10 lake 202:22 back 206:17,24 coming 206:17 drive 201:16 203:4 G Tarry 201:13 204:4 girls 206:16,24 207:2,6,13 commission 209:22 duly 209:12 206:1 209:11 baggage 207:10 company 206:13 207:12 210:7 211:3,19 E bags 207:11 complete 210:10 going 206:23 207:1 las 202:4 east 202:4 bclelaw 203:6 concluded 208:3 207:23 lauderdale 202:5 beach 201:1,16 confidentiality edwards 202:3 law 202:20 203:9 II 203:5,11 205:13,19 204:6 205:1 lawyerwillits bedwards 202:6 configuration 207:21 208:1 band 209:15 202:23 behalf 201:14 207:18 either 207:14 happen 206:17,21 lesbian 205:9 202:2,8,14,19 connected 210:14 employee 210:12 happened 206:20 line 211:4 203:2,8 considering 207:4 210:13 207:15 loading 207:10 bisatyne 202:10 continued 205:1 entered 211:16 hell 207:25 208:1 long 205:21 boarded 207:12 copy 205:19,23 epstein 201:8 hi, ed 205:16 I uc 206:12 207:13 boarding 207:11 cordoned 207:4 205:15 206:13 ii on estly 205:25 'tattier 203:3 boeing 206:14 correct211:15 207:14 211:2 burowitz 202:9 M boulevard 202:4,10 bradley 202:3 breinhart 203:12 bringing 206:24 207:2 correction 211:1,4 counsel 202:1 203:1 210:12,14 countries 206:23 county 201:1209:8 esq 202:3,4,21 203:3,9 engem 201:13 204:4 209:11 210:7 211:3,19 li ti ndred 207:8 march 209:22 maxwell 205:4,14 maxwelb 205:9 mean 205:3,8 206:8 202:9 1 11201:2 im 207:22 index 204:1,13 brought 207:6 210:3 exact 207:17 mermelstein EFTA01110324 Larry Eugene Morrison - Volume II October 2, 2009 Page 2 miami 202:11,17 michae1202:4 203:3 morrison 201:13 204:4 209:11 210:8 211:3,19 mpike 203:6 mwheeler 202:7 plaindff 201:6,14 202:2,19 plaintiffs 202:8,14 plane 207:5 podhurst 202:15,18 point 205:14 protocol 205:17 public 209:21 slave 205:9 somebody 207:6 somewhat 207:4 standard 205:17 state 209:6,21 210:2 stay 206:4 stays 206:4 stenographic 210:10 west 201:16203:5 203:11 wheeler 202:4 winds 202:20,21 witness 203:8 204:3 209:15 work 205:3,14 worth 202:22 33160202:11 33394202:5 33401203:5,11 334014321 201:16 33461202:22 4 400 203:4 401 202:4 404 202:22 N 0 X never 206:14,14 stenographically xxxxmb 201:7 R 5 notary 209:21 210:7 ranch 206:2,4,6 Y 502008ca028051 notes 210:10 number 207:20 read 207:23,25 street 202:16 subject 211:15 yeah 206:14 201:7 211:2 208:1 211:15 youve 207:9 515 201:16 203:4 0 record 210:10 substance 211:16 suite 202:5,11,22 5612026360203:12 oath 209:1 Z redirect 204:6 203:4,11 5615827600 202:23 zorro 206:2 october 201:15 205:1 sure 205:18 207:23 5618422820203:5 209:16210:17 reinhart 203:9,9 surprise 205:8,11 0 6 211:3 office 202:20 203:9 official 209:15 205:21206:14 207:25 relative 210:12,13 remember 205:17 surprised 205:12 sworn 209:12 6201:15 211:3 1 101202:14 7 ' oh 205:25 206:16,18 T 102202:14 7209:22 taken 201:14 211:3 telephone 202:14 okay 205:12 207:19 olas 202:4 206:19,22,23 207:1,17 10th 202:21 209:16 210:17 747526 209:22 originally 207:3 orseck 202:15 report 210:7 reporter 201:22 210:6,22 202:19 203:2 tell 206:6 1400 203:11 15th 201:1 8 8 202:8 P reporters 210:1 testimony 207:14 them 207:23 1650 202:5 18205 202:10 9 9545223456202:6 page 204:5 211:4 requested 210:9 three 206:16 pages 201:2 rest 207:5 207:12 2 paid 206:8 review 210:8 time 205:14 207:8 2 202:8 208:3 palm 201:1,16 richard 202:20,21 transcript 210:8,9 20208:3 203:5,11 rosenfeldt 202:3 true 210:9211:15 2009 201:15 209:16 parts 206:13 rothstein 202:3 210:17 211:3,17 U parties 210:13,14 rralaw 202:6,7 201 201:2 undersigned passenger 207:11 2012 209:22 207:17 passengers 207:20 penalties 211:15 S 209:10 205 204:6 211201:2 2218202:11 saying 206:17 seal 209:15 V people 207:2 percent 207:8 see 207:14 sex 205:9 visited 206:3 visosld 206:1 2290 202:21 25 202:16 perjury 211:15 personally 209:11 sexabuseattorney 202:12 volume 201:2205:2 vs 201:7 211:2 20203:10 pi ke 203:3 205:5,10 206:25 207:7 place 206:1 places 207:1 sheet 211:1 shorthand 210:5,22 sign 205:13 signed 211:17 3 W 3053582800202:17 3059312200202:12 33130202:17 waive 207:24 went 206:14 EFTA01110325