Condensed Transcript

Condensed Transcript IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff, CASE NO. -vs- 502008CA028051 X.XXXMB AD JEFFREY EPSTEIN, Defendant. DEPOSITION OF LARRY VISOSKI October 15, 2009 10:18 p.m. 515 N. Flagler Drive Suite P200 West Palm Beach, Florida Reported By: Wendy Beath Anderson ESQUIRE a* Alexarter Gallo Coop or Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110326 Larry ViSOSki October 15, 2009 I P4 114£ CIRCUIT COURT OP TIM TIPTIMITE J-3DICIAL CIKUIT IN MD IOR MLR REACH 010.TY, PLOPZDA CASE MO. 5020010101POSIx110111 AD Plaintiff. JeFTISC nmxx. Defendant. 1 2 3 4 5 6 7 3 • . - INDEX • • • WITNESS: DIRECT CROSS REDIRECT RECROSS LARRY VLSOSK1 BY MR. EDWARDS: 6 MOOStt10N OP LAY vilest! rIturenay, October 15. 3004 a BY MR. CRITTON: 214 BY MR. EDWARDS: 220 toils - 1:11 pa. 9 BY MR. CRITTON: 221 10 511 N. Plagler Drive Suite Me 11 Neer MIN. Satoh, florid.. 1)401 12 • • • 13 EXHIBITS 1141p9ftej Sy, 14 • • - Wendy death Anderson, RPR, CRR. PPR votary Public, State Of Plorida 15 ,racialre Direesttlen Ninglowil 16 NUMBER DESCRIPTION PAGE int pale brad, Office Jeb 113)541 17 PLAINTIFFS EX. 1 FLIGHT LOG BOOT( (MARKED IN PREVIOUS DEPO) 28 19 PLAINTIFFS EX. 2 MESSAGE PAD 119 PLAINTIFF'S EX. 3 MESSAGE PAD 119 20 PLAINTIFF'S EX. 4 COMPLAINT 139 PLAINTIFF'S EX. 5 INMATE VISITOR LOG 161 21 22 23 24 25 2 4 APPEARANCES: 1 PROCEEDINGS On behalf of the Plaintiff: BRADLEY J. EDWARDS. ESQUIRE 2 ... T ADLER 3 Deposition taken before Wendy Beath Anderson. 4 Certified Rash' rne Reporter and Notary Pudic in and for 5 the State of Florida at Large. in the above cause. 6 --- On behalf of the Defendant: ROBERT D. CRITTON, JR., ESQUIRE 7 MR. EDWARDS: We're going to put something on ITT 8 the record about -- well, we'll do it this way - 9 MR. REINHART: Do it at the end, alter we get 10 10 him -- whatever you want. It's your show. 12 12 On behalf of die Witness: 11 12 MR. EDWARDS: Okay. There were -- I don't think Mr. Welds Is aware this. There 13 14 1111= 13 14 oven of was a subpoena duces team for this witness, as well as the previous witness, which was another pilot. Dave as ALSO PRESENT: is Rogers. and that duces tocurn was to bring the 16 MES E UtRE 16 flight logs related from 1998 through 2005. What 17 27 was produced at the previous deposition were flight is TIME i R WITZ PA. 1$ logs from 2002 through 2005, and now Mr. Reinhart 19 19 has agreed to produce the remainder of the flight 20 20 logs requested, those going from 1998 through 2002. RICHARD H. WILLITS. ESQUIRE (VIA TELEPHONE) 21 MR. REINHART: Correct. They're pilot logs, 22 A P.A. 22 not night logs. There are other records we 22 23 Indicated are corporate records, and with those you 23 24 have to deal with Mr. Critton. 24 25 25 MR. CRITTON: However, with the proviso, too, ESQUIRE Oalloo ComPal Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beath Gardens, FL 33410 vnvw.esquiresolutlons.com EFTA01110327 Larry Visoski October 15, 2009 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 5 that we're going to work out that these records are to be used within the confines of this litigation and not to be spread to the press or anyone else. because they do contain confidential information as to who may have been on the plane and other records of Mr. Rogers, which but for the subpoena would have been only available to the FAA or some other law enforcement agencies. MR. EDWARDS: Okay. Is that all you want to put on? MR. CRITTON: Yes. MR. EDWARDS: I'm not saying I necessarily agree or disagree with you. Thais something that well deal with some other day. MR. CRITTON: Bruce, you'd better produce these records, but there has to be some sort of understanding before - MR. REINHART: Correct. MR. EDWARDS: I won't do anything until you file whatever you - until we work whatever it is out in court. ill say that on the record, that I'm not doing anything with the records outside of my office until some Judge deals with It. MR. REINHART: And for the record, I'll adopt what Mr. Craton said on this one limited occasion. 7 1 the question and you need to wait until I finish asking 2 the question. 3 A. So yotfre not allowed to interrupt me? 4 O. And you're not allowed to interrupt me. 5 A. Like I just did? 6 O. Right. 7 MR. CRITTON: Cara just snickered when you a said yotfve been accused because she recognizes 9 irs true. 13 MR. EDWARDS: I don't know what the meaning of 11 her snickering was. 12 BY MR. EDWARDS: 13 Q. But for what ifs worth, if you don't 14 understand the question or I've asked a bad question, I 15 don't want you to guess. Give me the best answer to the 16 best of your knowledge and if you need me to rephrase 17 rt. I wilt 18 A. Okay. 19 O. Okay. Tell me your current address. 20 A U 22 23 24 25 Q. How long have you lived there? A. Approximately nine years. Q. Okay. Who do you live there with? A. My wife and one chid al this tine. 6 MR. EDWARDS: Al right. 2 Thereupon. (LARRY VISOSKI) 4 having been first duly sworn or affirmed, was examined 5 and testified as follows: THE WITNESS: Yes, I do. DIRECT EXAMINATION 8 BY MR. EDWARDS: 9 Q. Can you tell us your name for the record 10 A. Lawrence Visoski, Jr. 11 Q. And Mr. Visoski, have you ever had your 12 deposition taken before? 13 A. No. 14 O. Okay. Here's the process: I'm going to ask 15 you questions. You're going to give us answers. Try to 16 give us answers that we all understand and that the 17 court reporter can take down, such as yes, no. or some 18 other verbal answer that we can understand. It's easy 19 when we get in a casual conversation to nod or shake 20 your head, and the court reporter is not writing 21 pictures or anything else. 22 A. I understand. 23 O. The other thing is, and I've been accused of 24 this In other depositions -- I donl know if it's true 25 or not -- but I need to wait until you finish answering 8 1 O. All right. How many children do you have? 2 A. Two. 3 Q. How old are they? 4 A. Fifteen and eighteen. 5 Q. And is the 18-year-old, is not living with 6 you? 7 A. She's off in school. a Q. Okay. What school Is that? 9 A. Syracuse. 10 Q. Who's your employer right now? 11 A. NES, LLC. 12 Q. How long has NES, LLC been your employer? 13 A. I'm guessing. I'd say back 1991. I have to 14 do the math, but 17, 18 years. 15 O. Has that been your only employer since 1991? 16 A. Yes. 17 O. And has that been your only source of income 18 since 1991? 19 A. Yes. 20 Q. And what is NES, LLC? 21 A. I don't really know. I mean, rt's the company 22 that my check comes from. 23 Q. What do you do for NES, Lie that results in 24 them paying you? 25 A. I am chief pilot for the aircraft and ESQUIRE .m Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 irnvw.esquiresolutIons.coM EFTA01110328 Larry Visoski October 15, 2009 9 . helktopters. 0. And do you have a specific boss or somebody you answer to at NES, LLC? A. Several people would call to schedule flights from the office, being it either Mr. Epstein or, you know. I would lust get a phone call and they would schedule a trip. Q. Okay. Aside from Mr. Epstein, who else would 9 there be that would call to schedule flights? 10 A Leslie. 11 0. Leslie who? 12 A. Leslie Gruff. 13 Q. When's the last time you talked to Leslie 14 Gruff? 15 A. Probably two weeks ago, three weeks ago. 16 Q. And where is she currently? 17 A. I believe in New York, is where I spoke to her 18 on the phone last. 19 Q. What's the telephone number you call to reach 20 Leslie Gruff? 21 A. 22 Q. And what address is Leslie Gruff at? 23 A. Do you mean where the office Is located? 24 0. Correct 25 A. 11 1 O What floor or suite number is NES. LLC In? 2 A. I believe — well, I don't know that NES, LLC A has an office there. I know that's where Leslie has the 4 phone number where I call So I don't know for a fact 5 rf NES. LLC has an office there. 6 O. And whet suite number, then, would Leslie 7 Gruff sit in to answer that telephone number at 9 10 11 13 13 14 15 16 17 18 19 20 21 22 23 24 25 MIM A. I think It's 10F. Q. And when you stay a what suite number or what apartment number do you stay in? A. 12C. 0. And how about Dave Rogers, where does he stay? A. I'm guessing, because it's been some time since we've been there, 108, but don't quote me on 0. Who are the other people in that building that you know to stay there on a reguku — fairly regular basis? A. the seen people in the elevator that. you know, have been on the airplane. Case in point. maybe but I dorYt know totaled that she Wes there, or anybody else for that matter. 0. Okay. When you say you've mein.. on the elevator 10 1 0. And It's my understanding from other 2 depositions that there are also apartments In trial. building? 4 A. Yes. 5 Q. And Mr. Epstein either owns or leases or rents 6 certain of those apartments. Is that your 7 understanding? a MR. CROTON: Form; speculation. 9 THE WITNESS: I'm only speculating. I 10 don't -- to my understanding, I don't know. 11 BY MR. EDWARDS: 12 0. Do you know other people that live in that 13 building? 14 A. Well, it would be myself. Dave Rogers - wet 35 when you say "live,' explain. 16 0. When you're saying yourself and Dave Rogers - 17 A. See, we don't live there. I mean, we have -- 18 we would stay there when we would have a trip. 19 Q. Okay. When you would fly up to New York and 20 land in New Yogic, the place where you would stay, is 21 the 22 A. Yes, that's corned. 23 0. That's also a location you've indicated in 24 this deposition that Is the office for NES, LLC? 25 A. Yes. 12 A. I only assume she Wes there. I don't know 2 for a fact. rm hying to be honest and factual for 3 you. So I couldn't honestly say if I knew she lived 4 there or not 5 0. Where do you thine Wes? 6 A. I would think she lives there. 0. You don't have a bettor location? 8 A. I don't have another location. 9 0. Anybody else? 2o A. Not to my knowledge. I mean, I'd only be 11 guessing that people We in that builckng that -- you 12 know, I don't have any facts to prove that they actually 13 live there. I mean, I don't think you want me to guess. 0. Well, NES, LLC, would you say that the owner 15 or controller of that company Is Jeffrey Epstein? 16 MR. CRITTON: Form. 17 THE WITNESS: I don't know that for a tact. 1e BY MR. EDWARDS: 19 0. Jeffrey Epstein is somebody you've Indicated 20 that you've worked for for 17 or 18 years, right? 21 A, Yes. 22 0. And over the 17 or 18 years you've become 23 personally close with him as wee, correct? 24 MR. CRITTON: Form. 25 THE WITNESS I Oaf* understand how you mean ESQUIRE •• SOM.!. Oal *U./al Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esqulresolutlons.com EFTA01110329 Larry Visoski October 15, 2009 13 1 'dose.' Define that. 2 BY MR. EDWARDS: 3 a Wel, rpm so than just a pilot that takes him 4 from Point A to Point B? 5 A. That is my job. 6 O. Right. But you know him on a personal level 7 and that you've had personal conversations that don't 8 necessarily deal with flying from Point A to Point B; 9 isn't that right? 10 MR. CRITTON: Form. 11 THE WITNESS: More specific, meaning we talk 12 about cars. I mean, does that make you a personal 13 friends? 14 BY MR. EDWARDS: 15 O. Have you ever gone to his house to eat? 16 A. No. 17 O. Have you been to his New York home? 18 A. Yes. 19 O. How many occasions have you been to his New 20 York home? 21 MR. CRITTON: Object to form. 22 THE WITNESS: We normally pick up luggage In 23 the lobby, so it would probably be quite often. 24 Any time we depart out of New York, we stop by the 2S house and pick up luggage and head to the aircraft. is 1 you know. televisions and such. 2 O. Is that another hobby or job or something of 3 yours? 4 A. Both. 5 O. Does he pay you for that? 6 A. Not any more than my salary. 7 O. What's your current salary? A. At this time, 180,000. 9 O. And what aro you paid $180,000 to do? 10 A. To manage his aircraft. 11 O. What does that entail? 12 A. Schedufing maintenance. Anything that has to 13 do with any flight, whether it be weather, flight 14 planning, time and distance to and from a location, any 15 logistics involved In running an operation that has 16 aircraft. 17 O. In addition to the 180,000, does he give yc. 1$ bonuses as welt? 19 A. There have been Christmas bonuses. 20 O. Over the years, you mean, there have been 21 Christmas bonuses? 22 A. Yes. 23 O. Is 180,000 the most he's ever paid you? 24 A. No. 25 O. All right Were you making when was the 14 BY MR. EDWARDS: 2 O. Other than picking up luggage, have you been 3 to his home to visit or socialize with him? 4 A. Not to socialize, no. s a Have you been to his Palm Beach home? A. To? O. To Mr. Epstoin's Palm Beach house? 8 A. Right. 9 O. Have you been there? 10 A. Yes. 11 O. Have you been inside? 12 A. Yes. 13 O. And how many occasions have you been inside 14 that home? 15 A. The same, as far as picking up luggage, and 16 that would be on a regular basis, you know, for a 17 departure. We wouldn't always go to the house to pick 18 up luggage, but it made it easier for loading the 19 aircraft getting it done prior to departure. 20 Q. Is that the only reason that you have ever 22 gone to the Palm Beach home over the last 18 years. is 22 to pick up luggage? 23 A. No. 24 Q. What other reasons have you gone there? 25 A I've set up several home theater equipments. 16 1 last time that you were making an amount different than 2 180,000? 3 A. Last year. 4 O. That would be 2008? A. That would be correct. Yeah, we all took a 6 salary cut, I don't know the exact date. It might have 7 been 2008, last year. It was last Christmas wo all took 8 a 10 percent salary cut. 9 Q. Do you know why? 10 A. Economic reasons. 11 O. And who told you that you were going to have 12 to take the salary cut? 13 A. Darren Indyke. 14 Q. And did you ask for an explanation? 15 A. lie explained it was due to economic reasons 16 throughout the country. 17 O. Okay. So In 2008, how much was -- were you 18 being paid by NES, LLC? 19 A. 200.000. 20 O. And is 200,000 the most that you've ever made 21 from NES, LLC? 22 A. Yes. sir. 23 O. And on top of that $200,000, did you get a 24 bonus that year as well? 25 MR. REINHART: Which year are you bildng ESQUIRE Toll Free: 866.709.8277 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 veew.esquiresolutions.com EFTA01110330 Larry Visoski October 15, 2009 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 17 about? MR. EDWARDS: 2008. THE WITNESS: That year, I think we skipped Christmas bonuses that year. The last bonus might have been 2007. BY MR. EDWARDS: Q. If you ever got a bonus from Mr. Epstein — and I'm only deriving this from you using the term 'Christmas bonus' A. Holiday bonus. Q. -- am I correct to assume sorry. Am I correct to assume that if you got a bonus, there was only one and it was at the end of the year, around the holidays? A. Yes. Q. Okay. And how much was the 2007 holiday bonus? A. I'd have to ask my wife. to be honest. I haven't seen my paycheck in 27 years. so I believe it was 310.000. Q. And in 2007 you also made $200,000? A. Yes. Q. Okay. A. With a question mark. I'm trying to be as accurate as I can, but yes. 19 1 my paycheck. So I don't even know what's written on the 2 lop of it. 3 0. That would be something that only your wife 4 would see. I'm assuming? 5 A. You're right, since she probably wouldn't know 6 the answer either, because she's looking et the right 7 column and not the top column. a 0. Right. When is the first time that you had 9 heard the name NES, LLC, that company? 10 A. Fwe. Six years, and even questioned what'd 11 stood for. And I think to this day I couldn't answer 12 that honestly, what It stands for. 13 0. Okay. But it's your understanding that the 14 NES, LLC is paying you for the work that you do as a 15 pilot or maintain the planes for Jeffrey Epstein? 16 A. To my understanding, yes. 17 a And back In 1991. do you know If It was a 18 dffereert company that was paying you or if it was 19 Jeffrey Epstein directly paying you? 30 A. I don't remember. I mean, I don't 21 0. Okay. Throughout your career with -- as a 22 pilot laJeffrey Epstein, since 1991, has there ever 23 been a time when you believe you we paid directly from 24 Jeffrey Epstein personally versus some company? 25 A. Not to my kncrertedge, no. 18 0. Something pretty close to mat? A. Yes, sir. 0. Okay. So with the bonus it was 210,000. roughly? 5 A. Right. 0. Okay. And how long were you making that salary? A. Probably -- he was very religious about giving 9 annual increases. so I would probably say 2006, you 10 know. It was -- we would get Increment increases of 11 five or $10,000 each year. So I would say 2006. So it 12 graduated. you know, progressive. 13 0. Okay. Do you remember the progression if we 14 start at 1991? Do you remember roughly what the 15 progression was up through 2007/2008, when you were 16 making $200,000? 17 A. No, I wouldn't know the progression. 15 0. Okay. Do you remember what you were making 19 from -- and was NES, LLC the company paying you back in 20 1991? 21 A. I don't know. I don't remember. Let me say 22 it that way. I don't remember. 23 O. Okay. When how long do you remember NES, 24 LW being the payer of your check? 25 A. Personally, two years. because I've never seen 20 0. Okay. So whether s was NES. LLC or some 2 other company, it was all of a sudden a company name, to 3 the best of your linoviedge? 4 A. Exactly, yes. 5 0. And back in 1991, do you remember 6 approximately how much you were being paid that year? 7 A. Fifty-live or 80.000. is maybe what I started. 8 0. Okay. A. You're going back a long ways. 10 0. Yes. 11 A. I'm trying. 13 0. Your relationship goes back that far. There 13 why I those that year. 14 A. Right. 15 0. Okay. Did you get bonuses even back that far? 16 A. Yes, sir. 17 0. And do you remember what your bonuses were as approiknately? 19 A. 5,000. I mean. that was laird of the — the 20 starting point. 21 0. Okay. In addition to moneary bonuses. were 22 there ever gifts or any other type of compensation that 21 NES, LLC or Jeffrey Epstein provided you? 24 A. Yes. 25 0. And is that over the span of the 18 years? ESQUIRE a* A nat. Gall* Ceasan Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.coM EFTA01110331 Larry Visoski October 15, 2009 21 A. Yes. O. Okay. Ten me what some of those items are. A. I remember one specifically was a pool heater. Q. Excuse me? A. A pool heater. Q. When was that? 1995-ish. Q. Okay. Why did you get that? 9 A. I had built a pool and I didn't have a heater 10 and he kind of laughed at me saying, 'How can you have a 11 pool without a heater?' So he says, 'You ought to get a 12 heater." 13 Q. Where were you when you had that conversation? 14 A. In the airplane. 15 O. How ofd he know that you had bunt a pool? 16 A. Just in general conversation, 17 O. You were having a conversation with Jeffrey 18 Epeteli? 19 A. Yes. 20 O. And this is something that was happening on 21 the airplane, this conversation? 22 A. Dung the flight Yeah, It would have been 23 We on cruise or something. 24 Q. Okay. When you say during the flight,' does 2s that — 2 3 1 Q. But more so than that, if there's going to bo 2 a casual conversation about a peel or a pool heater or 3 whatever, Ws going to be with you most likely if he's 4 going to be talking to pilots, right? 5 MR. CRITTON: Form. 6 THE WITNESS: Right. 7 BY MR. EDWARDS: O. Okay. And you feel like over the years yoke 9 relationship with Jeffrey Epstein has boon pretty good? 10 A. Yes. 11 O. And you have been closer to him over the years 12 as you've grown to know him? 13 MR. CRRTON: Form. 14 THE WITNESS: The same throughout the same 15 year. We never got any closer than 1991 than I am 16 wilt him now. I'm very professional at what I do 17 and know the line between being professional and 18 thinking you're somebody's buddy. 19 BY MR. EDWARDS: 20 O. Okay. So thars not something that you think 21 you are? You don't think you're his buddy? 22 A. No, sir. 23 O. Do you consider yourself his friend? 24 A. I believe so. 25 Q. Do you think he considers you his friend? 2 5 6 7 8 9 10 11 12 13 14 15 16 1? 18 19 20 21 22 23 24 25 22 A. Again, you're going back a long ways. O. I understand. We're larking about 1995 right now. A. Yes. O. You're having a conversation with Jeffrey Epstein. Who is flying the airplane? A. The auto pilot and there's two crew. O. Okay. So are you back in the back portion or Is he up In the cockpit? A. Up in the cockpit. O. Okay. Jeffrey Epstein sometimes comes up there? A. Just, yeah, in between the two pilot seats. Q. All right. Is that something that was typical, to have conversations like that? A. Mm-hmm. O. Yes? A. Yes. No nodding. O. And woukl those conversations be directed mainly with you or with the other pilots as well? A. Mainly with me. Q. I mean, you've kind of been described as the main guy or the main pilot. Wouldn't you consider that pretty much your role, right? A. Well, that's chief pia 24 1 A. I think so. 2 O. All right. What makes you think that? 3 MR. CARTON: Speculation. 4 THE WITNESS, He's always been kind and 5 respectful. 6 BY MR. EDWARDS: O. Ever invited you to dinner? A. No, sir. 9 Q. Have you ever associated or socialized with t 0 him during the day at any of his homes? 11 A. Only during a business reason. 12 O. Okay. What are the other are the places 13 that you believe that Mr. Epstein owns? I know we've 14 talked about this Manhattan -- the Manhattan house. IS I've read the altos about it, the Palm Beach mansion. 16 But what other places are you familiar with that 17 Mr. Epstein owns? 18 MR. CRITTON: Form; predicate, speculation. 19 THE WITNESS: To answer it honestly. I don't 20 know specifically that he owns any of the 21 residences, to be honest. I would only assume that 22 he owns. So if you want me to answer honestly. I 23 don't know that he owns any of the other. 24 BY MR. EDWARDS: 25 Q. Okay. Well, what would be the basis for your ESQUIRE nA""...“_." Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Ft. 33410 www.esquiresolutlons.com EFTA01110332 Larry Visoski October 15, 2009 25 assumption that he owns the home in Pakn Beach? 2 A. He goes there, but I don't assume -- you don't a have to own a house to go to it. Q. And not only does he go there, you're aware that he spends the night there: he resides there 6 sometimes, correct? A. Yes. 5 0. When he's in Palm Beach, Mat's where he — 9 A. He sloops. 10 0. sleeps? Right. When he's in New York, do 11 you know where he sleeps? 12 A. No. 13 Q. But you've been to a particular house in New 14 York that's a very large house that we've all read about 15 that you picked up luggage at, right? 16 A. Yes, sir. 17 MR. CRITTON: Form. 18 BY MR. EDWARDS: 19 0. And that home, do you know that — I know that 20 you're saying that you haven't done a public record 21 search to make sure that Jeffrey Epstein owns it. 22 A. Yeah. 23 0. But you assume that he does? 24 A. Assuming. 25 0. That's where he sleeps when he's in New York? 1 2 3 5 6 7 9 10 11. 12 13 14 15 16 17 16 19 20 21 22 23 24 25 27 O. Am those private airports? A. Public. O. Public, okay. Are there any private landing places where you would land any airplanes in New Mexico? A. There are. 0. That you have landed A. That I have. 0. - his airplane? A. Yes. 0. Where? A. We have a 4500-foot strip on the ranch. 0. When you say 'we.' yourself and somebody' A. The company. Q. What company? A. Well. I should say I see where you're going waft that. The ranch owns — whoever owns the ranch. The ranch has a runway on it. Q. Okay. And you've landed an airplane on that noway? A. That ranch. yes. Q. How many times do you think you've landed there? A. Ten. Q. All right. And have you been inside his ranch? 26 MR. CRITTON: Form. 2 THE WITNESS: I assume. 3 BY MR. EDWARDS: 4 0. That's where his luggage is when you pick it 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 up? A. Doesn't mean he owns It. 0. Right. But that's where it is? A. Yes, sir. 0. Do you know of anybody else who owns that home in New York? A. No. 0. Okay. Have you been to his ranch in New Mexico? A. Yes. MR. CFUTTON: Form. BY MR. EDWARDS: 0. How many times have you been to his ranch in New Mexico? MR. CRITTON: Form: predicate. THE WITNESS: A guesstimate. fifty times, only due to the fact that we would fly there. BY MR. EDWARDS: 0. And where would you land? A. Depending upon the aircraft, either Albuquerque or Santa Fe. 28 1 A. Yes. 2 MR. CRITTON: Form to the last question. 3 MR. REINHART: Can you clarify, the physical 4 ranch or the residences or the structures on the 5 ranch? 6 MR. EDWARDS: I don't have a good visual 7 appreciation for it. 8 BY MR. EDWARDS: 9 Q. Why don't you describe it in your words what 10 this ranch Mal We are talking about looks like. And 11 I've heard it referred to as the Zorro Ranch. Have you 12 heard that? 13 A. I've heard that. 14 0. That's the ranch we're all familiar with, 15 we're talking about where the runway is and everything 16 else? 17 A. Yes. 18 0. Describe it in your own words, the landscaping 19 of this ranch. What do we have on it? 20 A. There is a house up on the hal, a large 21 house. 22 O. How big? 23 A. Big. I've read 40,000 square feet In the 24 paper. 25 O. Have you been to it? ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutions.corn EFTA01110333 Larry Visoski October 15, 2009 29 1 A. Yes. 2 Q. Does that seem like it's feasible, 3 approximately 40,000 -- 4 A. I think so. yes. 5 Q. What else do we have on it? 6 A. There Is a compound that hes kind of motel 7 room type -- they call it bunkhouse. 8 0. Where's the bunkhouse located? 9 A. At the entrance to the ranch. 10 0. Okay. And what Is that primarily used for? 11 A. For the people that work on the ranch, they 12 reside there. It's also a place where anybody that 13 traveled on the airplane would stay. It's lTd of Eke, 14 you know, a hotel room. 15 0. And how far is that from the first house that 16 you deserted, the 40.000 square foot house? 17 A. Its probably 4 miles. is Q. Okay. So the Zone Ranch is a rather large 19 area of property? 20 A. Yes. 21 0. And how many times I know we just talked 22 about how many times you've been In the house, but how 23 many times have you been on that ranch in New Mexico, 24 the Zorro Ranch? 2s A. Thirty to fifty times over the years. mars 31 1 A. Yes. sir. 2 Q. And he sleeps there? 3 A. 4 Q. A. 6 0. 7 A. 8 Q. 9 MR. CRI1TON: This Is really -- 10 BY MR. EDWARDS: 11 0. Other than the pool heater in 1995. have you 12 ever received any other gifts on top of the compensation 13 from Mr. Epstein? 14 A. I did get land on the ranch to build a house. 15 Q. What do you mean you got land on the ranch? 16 A. He deeded me land to build a home. 17 Q. When was that? 1$ A. Ten years ago at least 19 Q. Do you know 4 he's ever deeded anyone else in 20 this world land on the ranch to bultd a home? 21 A. Not to my knowledge. 22 0. Why did he do that? 23 A. We would vacation out there and my wife Ion 24 In love with New Mexico and we were looking for 25 property. Yes. Okay. I assume he does. You assume he sleeps? I do. I think. Okay. 30 1 a guesstimate. 0. Is that over when was the first time that you went to that ranch? A. A guess, I don't know when it was. actually, E.. our first trip, but 1995/94. Q. Okay. And do you believe Jeffrey Epstein 7 and/or a corporation owned or controlled by him to be 8 the sole owner of that ranch? 9 A. I don't know any of those details. 10 Q. Have you ever talked to Jeffrey Epstein about 11 who owns that ranch? 12 A. No. 13 0. Do you know of anybody else who may own that 14 ranch? 15 A. Not to my knowledge. 16 Q. Other than Jeffrey Epstein, do you know of 17 anybody else who regularly stays there when they're in 18 New Mexico? 19 A. Not to my knowledge. o Q. Does Jeffrey Epstein stay there when you're In 21 New Mexico? 22 A. He has. 23 Q. And he has a key to the place? 24 A. I don't know if there's a key. 25 Q. One way or another, he gets in, right? 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 32 0. And did you talk to him about that? A. Yes. He knew I •• he was aware I was looking for a home and he says, 'Well, I have so much land. I could (PO you a spot to build a home on.' So I built a house. 0. So how long has a home actually been on that ProPeffn A. Nine years. Q. And !hats a home that you own? A. Yes. sir. O. And that's a home that was when I say 'you own it" Is there a mortgage on it or did he give 4 to you free and clear? A. No, no, I paid for the house. I made payments on it. 0. All right. So what did he actually give you? A. 4O-acres of land. 0. That you did not have to pay for? A. You know. I'd have to go back and look I think it was — I had to pay something for it I don't remember. Q. How often have you visited that piece — that home that you own? A. My wife would spend summers out there with the kids. ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutions.com EFTA01110334 Larry Visoski October 15, 2009 33 Q. Okay. But that's on the Zorro Ranch? 2 A. Yes. 3 Q. So in addition to the 50 or so times you've 4 been to the Zono Ranch, you've been to your property that's on the Zorro Ranch? 6 A. Yes, which over the years, Ws once-a•year 7 vISIta. So I mean, it is included in the 50 times that 8 I've been there. 9 0. Okay. And cad you have a conversation with 10 htrn that led to him giving you or gifting you 40-acres 11 of land? 12 A. We talked about it because he knew I was 13 looking fora home out there. 14 Q. Okay. In gifting you that land, did you 15 consider yourself at that point in time to be more than 16 just his pilot, as more of a friend? 17 A. No. You're using the word *gifting.' I paid 18 for the land. I don't recall what it was. But you use 19 ttre word 'friend.' I don't know that a -- sure• he was 20 a friend. I mean... 21 0. Well, did he give Dave Rogers any land out on 22 the New Mexico ranch? 23 A. No. 24 0. Okay. When you say you paid for it, I thought 25 that I asked that question, "Did you pay for the 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 35 A. 1800 square feet. 0. Were you ever at that house at the same time when he's at his house that's on that Zorro Ranch? A. Yet O. All right. We started back in 1991 with you making around $55,000 a year and that has progressed over tine to a point where in 2007 you were making $200,000 a year. I don't want to go through every single year; that would take a really long time. But the progression, was that on a yearly basis normally or after two years or three years? A. Yearly basis. 0. Okay. And would that normally be in increments of? A. $5,000. 0. Okay. You've talked about a couple other gas that have been given to you from Jeffrey Epstein over the years: one is a pool heater in 1995 and now some 40 acres of land on his New Mexico ranch. Any other gifts you can think about? A. No other gifts. Q. Okay. I don't want to split hairs with you. You obviously thought about that answer before giving it. What other Items are you thinking about that he's given to you or cut you a discount on or otherwise that 34 40•acres?" I thought your answer was, don't know, rd have to go back and look.' 3 Are you saying now that you did pay for that land? A. I don't remember. If there was a sum of 6 mOney, It was just for, you know. the legal purpose of a transfer of ownership of the lend. 0. Okay. If 4 was a substantial amount of 9 money, that's something that you would have remembered? 10 A. Oh, exactly. No. It was not a substantial 11 amount. 12 Q. Okay. Do you remember approximately how much 13 money you had to give Jeffrey Epstein for that land? 14 A. I would only be guessing. ft might have been 15 five defiers. To my knowledge, 1 don't remember. 16 0. Okay. So when I'm saying he gave you the 17 land, he may have actually given you the land? to A. Sure. 19 0. Okay. And to the best of your knowledge. he's 20 never given anyone else land out there? 21 A. Not to my knovrtadgo. 22 MR. CRITTON: Form. 23 BY MR. EDWARDS: 24 0. All right. How big is this house that you 25 built on the ranch? 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 36 you feel was compensation for you working for him? A. I drive a company car. I mean... O. Okay. What kind of car? A. A Hummer. 0. You say 'a company car." That's owned by NES, LLC? A. No, I think the registration has Zorro Development on it. 0. What is Zorro Development? A. I believe that's the ranch, or et least it has the name of the ranch. I don't know what the entity Is 0. And It's your understanding that that's a company vehicle? A. Yes. 0. And where Is that vehicle primarily garaged' A. At my bane. Q. In West Palm Beach or in the Zorro Ranch? A. No, here in West Palm Beach. Q. All right. And is there only one company vehicle that you're issued? A. Yes, sir. O. And is that something that was that you did net have to pay for? A. No. it's just something I drive. I mean, it's not titled to me or anything like that. It's just a car ESQUIRE Toll Free: 866.709.8177 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110335 Larry Visoski October 15, 2009 37 1 that I drive. 2 0. All right You've worked ter him for 18 1 years. I don't even know how long the Hummer would 4 last, but presumably, that's not the car you've had over 5 the entire 18 years. Have you allays had a company car? A. No, I haven't, no. 0. When did you get the Hummer? 8 A. Probably three years ago. 9 0. Do any other members of Mr. Epstein's piloting 10 team have company cars? 13 A. No. 12 0. Only you? 13 A. Yes. 14 0. And do you know how that decision was made to 15 get you a company vehicle? 16 A. No. 17 0. What do you use that vehicle for? 18 A. To and from the airport. 19 0. AU nght. Do you use it for personal reasons 20 also? 21 A. I guess. yea. 22 0. I mean, that's your primary vehicle? 23 A. Yes. or I drive my wife's car. 24 0. Which Is? 25 A. Type of car? 1 2 3 4 5 6 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 39 0. And which airplane was that? A. The Hawker. 0. Does he stilt have the Hawker? A. No. 0. How long did he have that plane? 0. Flve years. guesstimate: four or Ilve years. 0. So sometime in the mid '90s? A. Yes. 0. Did you keep any type of logs or documentation as to who would have been flying on that airplane if you transported any individuals? A. The same logs as you possess now are the Nght logs. 0. Okay. A. That's the standard for the industry. Q. So that's something that you kept, or that Dave Rogers kept? A. Dave Rogers. 0. Okay. If there are any documents out there with names of passengers on any of the flights involving planes owned or controlled by Jeffrey Epstein and/or his companies, those would be documents in the possession of Dave Rogers and not yourself? A. Oh, the corporation actuay, they belong to. Q. Okay. 38 1 O. Yes. 2 A. A Mercedes. 3 0. Ands that something that was also a gift 4 from Mr. Epstein? 5 A. No, sir. 6 0. What type of Mercedes Is that? 7 A. AML 430, ten years old. O. MI right. Are there any other items — 9 company car, the land In New Mexico, the pool healer — 30 any other items that Mr. Epstein has given you over time 11 as compensation or reward or anything else? 12 A. No. sir. 13 0. And your only income is from Mr. Epstein or 14 his companies? 19 A. Correct. 16 0. Okay. And It's been that way since 1991? 17 A. Yes. 18 0. How did you meet Mr. Epstein or became 19 involved with him in 1991? 20 A. We heard at the airport that Mr. Epstein was 21 purchasing an airplane when Dave Rogers and myself were 22 living in Columbus, and we had the opportunity to 23 interview with him, and we did and got the job. 24 O. And this is before he owned the airplane? 25 A. Yes. 40 1 MR. REINHART: That was a compound question. 2 You might want to split it In half. 3 MR. EDWARDS: Okay. 4 BY MR. EDWARDS: S Q. What documents do you believe exist that 6 indicate names of individuals that have been passengers 7 on Mr. Epstein's airplanes? MR. REINHART: Are we going back all the way 9 from '91 to the present? 10 MR. EDWARDS: Sire. 11 THE WITNESS: You're talking about the Hawker? 12 BY MR. EDWARDS: 13 0. Any airplanes. What documents would there bo? 14 A. There would be the same: Right logs and 15 passenger manifests would exist. 16 0. And are either of those required? 17 A. The flight log is required for the aircraft to 18 track times and landings. 19 0. And In the flight log. is it required that you 20 designate the names of the passengers? 21 A. No. 22 0. That's just something that Dave Rogers did on 23 his own? 24 A. Everybody does that. ICs more for Internal 25 Revenue. ESQUIRE Toll Free: 866.709.8777 FaalmIte: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutlons.com EFTA01110336 Larry Visoski October 15, 2009 41. 1 0. Okay. If something happens, they know who is 2 on the plane? 3 A. Exactly, weight and balance. 4 0. Have you ever kept any flight logs that have 5 names of people on the airplane? 6 A. When you say 'kept? I have filkxl out flight 7 logs or the passenger manifest, yes. 8 0. By 'kept' I meant maintained to where they're f/ in your possession either on paper or computer? 10 A. We keep -- 11 MR. REINHART: Can you differentiate a flight 12 log from the plot's log that we showed you 13 earlier? 14 MR. EDWARDS: Okay. 15 BY MR. EDWARDS: 16 0. I'm talking about -- I dont know that Ws 17 called a flight log. a pilot's log or any kind of fog. 18 A. They are different. yea. 19 0. Yeah. I'm asking about, have you kept or do 20 you have any documentation that would indicate the names 21 of passengers that have flown on any of Jeffrey 22 Epstan's planes? 23 A. No. 24 0. Either in the form of paper or on a computer? 25 A. No. 43 1 A. Jeffrey would always critique Dave's flying 2 capabeities, and I tried to help Dave and explain to 3 him what Jeffrey likes and doesn't like. And Jeffrey's 4 also conveyed these likes and dislikes. And Dave maintained continuing with certain piloting techniques 6 that were just not comfortable to passengers. And this 7 went on through the years. and Jeffrey just got tired of it one day. 9 0. What specifically were Jeffrey Epstein's likes 10 and dislikes with respect to the flight of the plane? 11 MR. CRITTON: Let me put in a form here. But 12 I don't know what this has to do with anything in 13 this case. 14 MR. EDWARDS: I understand that, Bob. 15 MR. CRITTON: I want to use this for some 16 other depositions where we -- we've gone beyond the 17 wope. 18 THE WITNESS: The case In point, the last 19 straw was there was a technique called quiet flying 20 where you would retard the throttles well short of 21 the runway and pretty much glide the airplane in 22 Well, if you don't do that correctly, you have to 23 spool the engines up just prior to touching down 24 that -- because you're losing air speed and it's an 25 uncomfortable sound and feeling for the passengers 42 1 0. Makes that easy. 2 A. Okay. 3 0. In 1991, were you the chief 0100 4 A. No. 5 0. Somebody else was the chief pilot? 6 A. Yes. 7 Q. Who's that? 8 A. Dave Rogers. 9 0. All right. At what point in time did you 10 become chief pilot and switched with Dave Rogers? 11 A. Six years ago; five, six years ago. 12 0. Why? 13 A. Professionalism, technique. 14 0. What do you mean by that? 15 A. The way Dave would operate an aircraft. 16 Jeffrey knew the difference when I was flying and when 17 Dave was flying. 18 0. How do you know he knew the difference? 19 A. Just -- 20 0. He told you? 21 A. Yes. He knew the difference that if ho never 22 came up front, he knew who was flying, who landed. 23 0. And what was the conversation that he had with 24 you that resulted in you becoming chief plot, switching 25 positions with Dave Rogers? 44 1 thinking that you're not going to make the runway. 2 And it was a continuous practice of Dave doing that 3 to be neighbor friendly as opposed to being 4 passenger-comfort friendly. 5 BY MR. EDWARDS: 6 0. Okay. 7 A. Hence, the transfer of power. 8 0. Has he ever discussed with you where he wants 9 you to be, whether that is -stay in the cockpit when I 10 have people on the airplane," or don't intermingle with 11 the passengers or anything else? 12 A. He's never stated that to us. 13 MR. REINHART: Could you clarify which "h0 14 you're talking about? 15 MR. EDWARDS: I'm talking about Jeffrey 16 Epstein. 17 MR. REINHART: ()Say. 18 BY MR. EDWARDS: 19 Q. You understood that? 20 A. Yes. 21 0. It's my understanding that in the -- wall 22 tell me other than the Hawker, what other airplanes have 23 you flown for Jeffrey Epstein? 24 A. A Gulfstream. 25 0. Does he still have that plane? ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutiOnS.COM EFTA01110337 Larry Visoski October 15, 2009 45 A. Yes, sir. O. How bier:deplane is that? A. Large corporate Jet. O. How long has he had it? A. Fourteen years; 13.14 years. O. And other than the Gulf stream, what other airplanes does he have? A. When you say she; obviously. these are company-owned -- O. Jeffrey Epstein or his companies. A. A Boeing 727. 22 O. Wee, I know that's a very large airplane. I 13 think that's been described by other people, so I'm not 14 going to have you do that But there's partitions In 15 that airplane in the back rooms of that airplane. 16 right? 17 A. Yes. Is O. Several different partitions to where if the 19 pilot comes out of the cockpit, you don't necessarily 20 see ell the passengers? 21 A. Yes 22 O. Thars true? 23 A. Yes. 24 O. Okay. 25 MR. REINHART: Keep your voice up so she can 1 2 3 4 6 7 a 9 10 12 21 13 14 15 16 17 3.0 19 20 21 22 23 24 25 47 and who was on the flights? A. One flight I believe we went to Sebring and another flight we went to Nassau, Bahamas. O. And who did you go to Nassau, Bahamas with? A. I'd have to look at the flight log, but I think It wa I behave. I think that was the three passengers. to the best of my knowledge. O. And ills my understanding that little St. James is an island that Jeffrey Epstein owns or controls? MR. CRITTON: Fenn. THE WITNESS: I don't know that he owns it. BY MR. EDWARDS: O. Has he ever been to an island called Little St. James? A. Yes. O. And have you been there with Jeffrey Epstein? A. I've been there when he was there. O. Have you flown on an airplane with him to that destination? A. No. O. AP right. When you say you've been there when he was there, how did that come about? A. We flew into St Thomas and then we flew to 46 hear you. THE WITNESS: Oh. MR. REINHART: And so Mr. Willits can hear you. BY MR. EDWARDS: O. Other than the Gulfstream and the Boerig and the Hawker, what other airplanes has Jeffrey Epstein owned over the years? A. Thetis& I 0 O. And currently still owns or the companies 11 associated with him own the Gultstream and the Boeing? 12 A. Yes. 13 O. And in the past two years, have you flown 14 those two airplanes? 15 A. Just for routine flights to keep them loose 16 or, you know you know what I mean. 17 O. Have those two airplanes been flown by anyone 113 else in the last two years? 19 A. No. 20 O. Have those two airplanes been flown In the 21 last two years for any reason other than routine 22 maintenance-type flights? 23 A. We've had one two flights I think in the 24 past two years. 25 O. And what were the purposes of those flights 48 1 Little St. James In a helicopter. 2 O. And do you fly the helicopter as well? 3 A. Yes. 4 O. How many helicopters are owned or controlled 5 by Jeffrey Epstein and/or corporations associated with 6 him? 7 MR. CRITTON: Form. THE WITNESS: At this time. one. 9 BY MR. EDWARDS: 10 O. And has that helicopter been flown in the last 11 two years? 12 A. Just for routine maintenance. 13 Q. And when you and let's say when 14 ME and Story Cowells and flew torsau. do 15 you know the purpose of that trip? 16 A. No. 3.7 O. How long did you Way? 18 A. Five hours. 19 O. Did you pick anybody up there? 20 A. No. Meaning passengers? 21 a Yes. 22 A. NO. 23 O. What happened? You landed the airplane and 24 then what? 25 A. The passengers left. Dave and I went and had ESQUIRE as Al *Wet OWle Coay.n, Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110338 Larry Visoski October 15, 2009 49 lunch. The passengers showed up and we came back. 2 0. Have you ever stayed at the home that is on Uttle St. James? A. No. 5 a Have you known Jeffrey Epstein to stay at that 6 home? A. I don't know that fora fact. a 0. Okay. Do you believe that he is the owner or 9 controller or has some interest in the home or the 10 island of Utile St. James? 11 MR. CRITTON: Form. 12 THE WITNESS: I have no knowledge of that 13 being a fact. 14 BY MR. EDWARDS: 15 0. And you have no belief that that is a fact? 16 A. Exactly. 17 0. When you say you've been there when he was 18 there, how many times has that occurred? 19 A. Estimating, a hundred times. 20 0. Okay. 21 A. Trying to give an honest answer. 22 0. Okay. And in the approximate rm not going 23 to hold you to a hundred times• but in the approximately 24 hundred times — 25 A. Sure. 51 I to his Island? We never landed on Ns Island. We 2 landed In St. Thomas. 3 0. Got it. 4 A. I was just trying to be exact. 5 0. Thank you. 6 A. It's a small island. 7 0. Okay. So how is it that when Mr. Epstein 8 wants to go to Little St. James. what is the path that 9 you take to got actually to the island of Little 10 St. James? 11 A. I don't understand the question. 12 0. Well, you just told me you fly the airplane to 13 St. Thomas? 14 A. Right. 15 0. And then what? 16 A. Then sometimes I would go get the helicopter 17 or he could also take a boat to the island. But 18 normally the helicopters located on St. Thomas. rd 19 fire up the helicopter, come pick him up, drop him at 20 the Island and I come back to St. Thomas. 21 0. And when he stays on St. James. you drop Nth 22 of on St. James. I suppose you're going to tell me you 23 don't know if he slays there or not? 24 A. Exactly. 25 0. But do you stay 50 0. for what period of lime are we talking 2 about? A. During what period of time? Q. Right. A. Let's see, when did all this happen? What, 6 2007? So eight years prior to whenever he stopped flying. So... 8 Q. W99? 9 A. Yeah, I guess. yes. 10 0. I mean, that sounds lace a right 11 A. Sounds about right, yeah. Don't hold me to it 12 again. 13 0. All right. 14 A. You're going beck a long way. 15 0. So from approximately the 198/99 time frame 16 when Jeffrey Epstein would fly to Little St. James, 17 would you be the pilot? 18 A. Yes. 19 Q. Okay. And you say that you've been there — I 20 thought that you Just told me that you've been there the 21 same time he was there. but then I thought the 22 subsequent question was well, were you on the flight 23 with him, and I thought your answer was no. Maybe I 24 misunderstood that. 25 A. No, you said the question "Have you ever flown 52 A. I don't. I mean .- 2 0. Well, he either stays there or someone else 1 picks him up in a helicopter or he swims away? 4 A. Coned. 5 0. Okay. You stay on St. Thomas? 6 A. Yes. 0. Okay. Is there a place that you've stayed on 8 61. James. even 9 A. No, rve never. 10 0. So in the hundred or more times that you've 11 been to the island, Is it my understandng that each of 12 those times you've been there to drop of Jeffrey 13 Epstein and'or any passengers and you've immediately 14 left and gone to St. Thomas? 15 A. Yes, sir. 16 Q. You never been inside that home that's located 17 an SL James? Is A. Yes, I've been inside the NOM/ 19 0. How many times have you been inside the home? 20 A. I mean, ten, fifteen times. 21 Q. And for what occasion? 22 A. I've set up the theater system that's in the 23 living room. 24 0. Okay. 25 A. So it would be there to work to hook up a TV ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Fl. 33410 www.esquiresolutIons.com EFTA01110339 Larry Visoski October 15, 2009 53 1 or a stereo. 2 Q. And do you knew Les Wexler? 3 A. No, I don't. 4 Q. Have you ever met him before? 5 A. I have met him. 6 Q. Do you know of any relationship between Los 7 Wexler and Jeffrey Epstein? 8 A. I don't know what — to what extent they have 9 a relationship, no. 10 Q. Do you know if they know one another? 11 A. I don't know that for a fact. They talk to 12 one another, so I would assume. But I don't know to — 13 Q. How do you know they talk to one another? 14 A. I've seen them speak to one another at the 15 foot of the airplane. 16 Q. All right. Have you ever flown the 17 airplane any of the airplanes with Les Wexler as a 18 passenger? 19 A. No. 20 Q. Have you ever flown the airplanes will 21 Ma as a passenger? 22 A. Yes. 23 Q. And do you knottla 24 A. Yes. 25 Q. And for how long have you knowrar 54 55 1 Q. It seems b be I mean, you seem Ike 2 somebody Mite has common sense. It seems like somebody 3 that knows Jenny Epstein? 4 MR. CARTON: Form. BY MR. EDWARDS: 0. Correa..? 7 A. Yes. Q. All right. And do you believe that there is a 9 business relationship there or a personal relationship 10 there, from your observations? 11 A. rd only be speculating. When they get on the 12 airplane. my focus is forward and flying safety. So I 13 don't — you know. I'd only be guessing at either one of 14 those Iv o. 15 0. Okay. Have you ever socialized wit.. 16 17 16 19 20 21 22 23 24 25 MR' A. No. Q. Other than speaking with her on the airplane, have you spoken with her eisewhere? A. Over the phone, in passing. I mean, walking down the street In New York. I mean, yes. Q. Why would you cal or why would she cal you? A. She would call me to schedule the aircraft for a departure. A. I'm guessing, six years. I mean, don't hold 2 me to it. I'm not the greatest on length of times, but 3 six, seven years, I think. 4 0. Flow did you moot her? A. I guess I was introduced. She was on a Bight 6 of ours. 0. You were introduced to her by whom? A. She may have introduced herself. I mean, 9 you're going back a ways. I don't know the official 10 introduction, how it went. 11 Q. And to your knowledge, what is her is she 12 associated or affiliated in some way with Jeffrey 13 Epstein? 14 MR. CRITTON: Form. 15 THE WITNESS: I would assume so. I don't know 16 to what level or what actually her job description 17 Is. MI BY MR. EDWARDS: 19 Q. All right. Well, how many flights have you 20 flown where she and Jeffrey Epstein have been passengers 21 together on one of the airplanes that we've been 22 &cussing? 23 A. I'd only bo guessing again. 24 O. We're talking hundreds of flights, though? 25 A. Sure. sure, a lot of Illshts. 56 1 Q. And have you ever called her? 2 A. Yes. 3 Q. When's the last time you talked W=1 4 Mi? 5 A. A week ago. 6 Q. What was the occasion? 7 A. We were discussing carpet for one of the 8 aircraft. 9 Q. And where was she when you were talking with 10 her? 11 A. I don't know. tt was over the phone. 12 Q. Dld she call you or you call her? 13 A. No, I called her on her cell. 14 Q. Okay. And that's a New York number? 15 A. I don't know. It's on speed dial. 16 Q. Do you have your phone with you? 17 A. Yes. 18 O. Could you tel me what that number is? 19 A. SUre. 20 0. Thanks. 21 A. Sure. 22 Q. WNch airplane were you discussing carpeting 23 for? 24 A. Was actually -- actually. It was for the 25 helicopter. Now that I'm thinking about ft. the ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Fl. 33410 www.esquiresolutlons.com EFTA01110340 Larry Visoski October 15, 2009 57 t helicopter. 2 Q. In the last two years, did you tell me the 3 helicopter has flown? A. Yes. 5 O. And where to? 6 A. I have flown the helicopter to Fort Lauderdale on several occasions for maintenance. rve flown it to s Miami. And I try to fly the helicopter at least every 9 two weeks Just either by myself to run it up to its — 10 it's Important that it keeps moving. 11 O. Other than maintenance-type flights, have you 12 flown the helicopter in the last couple of years? 13 A. Yes. 14 O. And who was on the helicopter? 15 A. I flew to Miami with Mr. Epstein. 16 0. When was that? 17 A. It was a couple weeks ago or a month ago, I 15 think. 19 O. For what? 20 A. Sony? 21 O. For what occasion? 22 A. I think he had a meeting with his attorneys in 23 Miami. 24 0. Today is October the 15th. Is this during the 25 month of October that you had this flight in the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Ia 19 20 21 22 23 24 25 59 O. How long have you known A. I don't know, five years. A guess again. four, five years. O. Do you know what her relationship is, if any. with Jeffrey Epstein? A. I do not know. O. Do you 'mow if she knows Jeffrey Epstein? A. I would assume so. They tare_ I would imagine she knows him. O. And how many times has she been on the arplane or the helicopter on flights at the same time as a passenger with Jeffrey Epstein? A. Many. I'd have to look at the logs. O. Hundreds of times? MR. CRITTON: Form. THE WITNESS: Sure. BY MR. EDWARDS: O. If you were going to, as somebody who has been Jeffrey Epstein's pilot for 18 years, tell me today who the five closest people are to Jeffrey Epstein, would IMbe one of them? MR. CRITTON: Form. THE WITNESS, I'd only be guessing and speculating. I have no idea. 58 1 helicopter with Mr. Epstein? 2 A. I'd have to look at the book to be exact for 3 you. 4 Q. Okay. But it's either the end of September or 5 the beginning of October? 6 A. Yeah. 7 O. How do you know that ho was meeting with his 8 attorneys? 9 A. I believe that he had mentioned that he was 10 meeting his attorneys. 11 Q. Did he tell you why? 12 A. No. 13 Q. Why did he tell you he was meeting with his 14 attorneys? Did you ask him? 35 A. No. 16 O. Okay. That's just something that he said to 17 you in conversation? A. Yes. sir. 19 Q. Was there anyone else on the airplane besides 20 you and Mr. Epstein? 21 A. Yes. 22 O. Who was that? 23 A. 24 O. who? 25 A. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 1e 19 20 21 22 23 24 25 60 BY MR. EDWARDS: O. Okay. Well, as his pilot and the person who travels with Jeffrey Epstein on the majority of his flights, who are the people who travel most frequently with Jeffrey Epstein? A. I'd have to look at the logs. MR. REINHART: Can we get a time period? BY MR. EDWARDS: O. In the last ten years, which people travel most frequently with him? A. I'd have to look at the flight logs to give you an accurate answer. O. You can't give me one single name of somebody who you would say is a frequent flyer? A. O. A. Yes. O. else? O. A. Yeah. O. Okay. Anybody else? A. Just mainly those two. Q. How about Ghislaine Maxwell? A. Not for some time. ESQUIRE *a Al ,404,1 G.i:41Cu pbliy Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, R. 33410 www.esquiresolutions.com EFTA01110341 Larry Visoski October 15, 2009 61 1 0. What's your understanding between the 2 relationship of Sillslathe Maxwell and Jeffrey Epstein? 3 A. I don't really know. 4 0. AM right. So when oi ly say you're guessing the a know or are 6 associated with Jeffrey Epstein, that guess Is being 7 made on the with the observation that they have been 8 frequent flyers with Jeffrey Epstein on more than 9 hundreds of flights on his private plane? 10 A. Yes, that's what I'm b • it on. 11 Q. And do you know whet Is 12 staying these days? 13 A. No. 14 0. Do you know what car she's driving these days? 15 A. No. I don't. 16 0. Okay. Do you know if she's Wing with 17 Jeffrey Epstein these days? 18 A. I don't know that. 19 Q. Do you 3310W howe met Jeffrey 20 Epstein? 21 A. I don't. 22 0. Were you on an international flight bringing 23 her into the country horn some other country at any 24 time? 25 A. I don't know. 63 I Miami? 2 A. Twenty-five minutes. 3 0. And did they talk to one another during that 4 tier? 5 A. No. 6 0. They were both completely silent during that 7 flight? 8 A. Yes. 9 0. Okay. Is that typical when they are on 10 flights together. especially with the helicopter, whore 11 you're in pretty close quarters, that they would ahciain 12 from speaking to one another? 13 MR. CRITTON: Form. 14 THE WITNESS: Yeah, it would be typical. Irs 15 very noisy and communicating in a hohcopter is. 16 you know, not that comfortable. 17 BY MR. EDWARDS: 18 0. Over the last five or• • have 19 known or been familiar with have you 30 heard her and Jeffrey Epstein conversing with one 21 another? 22 A. I've heard them conversing, but if you ask me 23 what they had said, I could say it -- I wouldn't even 24 know what they had said to each other. I've seen them 25 talking to each other. 62 MR. REINHART: Can we clarify? You mean with Mr. Epstein or 3 MR. EDWARDS: No. 4 BY MR. EDWARDS: 0. Did you ever bring from some foreign country into the United States? A. I'd have to look at the log books, honestly. 8 0. That's not something you remember? 9 A. No. I mean, she I think she's been on 10 Europe trips with us. and I think she's returned from 11 Europe with us, but I could not say that hones . 12 0. On this recent helicopter flight with 13 and Jeffrey Epstein, did you talk with them 14 during that flight? Is A. No. 16 0. Where rid the flight go from? And obviously, 17 it landed In Mlaml, but where did you leave from? 18 A. West Palm Beach. 19 0. And did= and Jeffrey Epstein arrive 20 together? 21 A. You know, I don't remember. I was out at the 22 helicopter and I think they both started walking up. So 23 I don't know if they came separately or not. I was 24 already at the heloopter. 25 Q. How long is that flight from Palm Beach to 64 1 Q. But you don't remember a single lit 2 conversation between Jeffrey Epstein and= 3 4 A. An honest answer, no. 5 0. Okay. And the same for have you 6 seen or have you seen Jell rey Epstein speak with IIIIIIk 7 8 A. hoe seen him speak with her, yes. 9 Q. Can you tell me a single specific conversation 10 that ve overheard between Jeffrey Epstein and 11 12 A. One thing that comes to mind would be make 13 sure we have Oreo cookies on the airplane. II would be 14 something completely nonchalant. 15 0. Okay. And do you know or have 16 of any employment relationship between 17 Jeffrey Epstein? 16 A. I have no kno 0 of n of that. 19 Q. Do you know if works for Jeffrey 20 Epstein? 21 A. I do not know. 22 Q. Do you know it schedules massages 23 for Jeffrey Epstein? 24 A. I have no idea. 25 0. Has Jeffrey Epstein ever indicated to you that ESQUIRE as Al LaMarO.110 CostiaRY Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110342 Larry Visoski October 15, 2009 65 1 he is fascinated or infatuated or appreciates or loves 2 or likes massages? 3 A. I have no knowledge of that. 4 0. All right. How about ObisSeine Maxwell, has 5 she ever talked to you about massage therapy or have you 6 ever overheard her talking about that? 7 A. No. 0. You certainly read the papers over the last 9 couple of years, correct? 10 A. Not on my top ten list. I mean. I've read a 11 couple articles, but I'm not one to focus on that so 12 much as some people would. 13 0. Okay. When the h I1Esiigation about Jeffrey 14 Epstein came about, the criminal investigation you're 15 aware that's what I'm talking about. right? 16 A. That was last year? 17 0. Welk it was a couple years ago. 18 A. Right, okay. 19 O. Did you speak with Jeffrey Epstein about that 20 investigation? 21 A. No. 22 O. Were you told not to speak with him about that 23 investigation? 24 A. I think we knew ourselves that we weren't -- 25 It wouldn't be proper to even bring it up. 2 3 4 5 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 67 women? MR. CRITTON: Form. THE WITNESS: No. BY MR. EDWARD$: 0. You think that this is just a story that a bunch of underage women hove made up? A. Speculation. MR. CRITTON: Objection. Nov Ws argumentative. Who gives a dam what he thinks cue way or another? If he has personal knowledge — MR. EDWARDS: You're objecting to the form? MR. CRTITON: It's argumentative. MR. EDWARDS: You're objecting to the form' MR. CRITTON: Yes. MR. EDWARDS: Okay. BY MR. EDWARDS: 0. Is that something that you believe that a bunch of women some of which know each other, some don't, some of which have been on the airplane and some which haven't -- made this up, that Jeffrey Epstein engaged in some sexual conduct with them? MR. CRITTON: Form. THE WITNESS: What I believe doesn't matter in this case, does It? 66 0. All right. When you read In the newspapers 2 the allegations that Mr. Epstein was involved with 3 numerous underage girls for sexual reasons, were you 4 surprised? A. I didn't believe it. 6 Q. Do you believe d today? A. I don't believe it. 0. You don't believe that Jeffrey Epstein was 9 Involved with underage girls in a sexual way? 10 MR. CRITTON: Form. 11 THE WITNESS: You're asking for my opinion, 12 and I don't think my opinion Is relevant In that 13 matter. 14 BY MR. EDWARDS: 15 O. I think it's relevant. Can you just tell me 16 whether today you believe that Jeffrey Epstein has 17 engaged In sex with underage girls? 18 MR. CRITTON: Form; speculation. irrelevant, 19 always. 20 THE WETNESS: Ifs Irrelevant. 21 BY MR. EDWARDS: 22 Q. I need an answer. 23 A. I don't believe he had sex with underage 24 women. 25 Q. Or engaged in any swami acts with underage 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 68 BY MR. EDWARDS: 0. I need an answer. Do you believe It? Do you believe these girls made this up? MR. CRITTON: Form. MR. REINHART: I'm going to instruct him not to answer. Move on. MR. EDWARDS: Is there a privilege that we're asserting? MR. REINHART: No, It's irrelevant It's harassment and not likely to lead to discoverable evidence. MR. EDWARDS: I'm going to put on the record right now that it is -- we are allowed discovery into a RICO count. We are also allowed discovery Into the intent of Mr. Epstein in developing a criminal enterprise designed to sexually exploit and sexually abuse underage girls. We believe that In doing so, he associated intentionally with people of similar beliefs that sex with underage girls Is okay, and that there have been many discussions with this witness, as won as many other witnesses with - to insure his protection from law enforcement that they not answer these specific questions. And thus, the opinions and beliefs of all of these witnesses that we are ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com EFTA01110343 Larry Visoski October 15, 2009 69 alleging associated with this criminal enterprise 2 are certainty reasonably calculated to lead to the 3 discovery of admissible evidence. And if you're 4 still instructing the witness, based on that • proffer, not to answer any of these questions, inn 6 going to continue to ask the questions and you can 7 instruct him not to answer and we can go to the Court. 9 MR. REINHART: My response is to his opinion 10 whether people making allegations in this case are 11 Whiting or making up a story is Irrelevant to 12 what you just said. So I am going to instruct hkn 13 not to answer any question that goes to his opinion 14 of someone else's motivation or the truth of facts 15 to which he has no knowledge. 16 So yes, fin instructing him not to answer. 17 MR. CRITTON: Let me add in my part. Is that I 18 think -- you're certainly not only capable to ask 19 questions with regard to what his personal 20 knowledge Is, and if he knows something or he has 21 reasonable basis for it certainly you are entitled 22 to that Information. I think you've asked those 23 questions and he's given you straightforward 24 answers as to what he knew or what he didn't know 25 under those circumstances. And as to what his 71 1 A. It's an opinion, and I behave that he has 2 not. 3 0. Okay. Isn't It true that at some point in 4 time you learned that Jeffrey Epstein has strike that. 6 MR. CRITTON: When you ultimately get to a 7 good place to break, wit you let us know? a MR. EDWARDS: Lefs break now. 9 (A break was had at 11:28 a.m.) so BY MR. EDWARDS: 11 0. All right. Eighteen years of being a pilot 12 for Jeffrey Epstein and in terms of being able to name 13 somebody that you would say youVe observed with Jeffrey 14 Epstein and would classify that person as Jeffrey 15 Epstein's friend, can you name anybody? 16 A. I-' just people that we see 17 routinely on the airplane. 0. mars people you see routinely in the last 19 five to ten years, right? 20 A. Yes. 21 0. Prior to that time, anybody that you've 22 noticed as Jeffrey Epstein's friend may be Ghistaine 23 Maxwell? 24 A. What time frame? 25 O. Is that a person that at some point in time 70 thoughts are on something which he has no factual basis or even an assumption to know one way or another is irrelevant That's ultimately for a • fact-finder in this case. 5 While it's interesting, it's argumentative and • I don't think he's •-1 mean, do it on a + question-by-question basis. If he has knowledge. 3 thafs great, but to argue your case with this 9 witness or any other witness doesn't servo a 10 purpose and I think is, you know — I think ifs 11 not a good use of our time, Ill put it that way. 12 But you know, you can go ahead and ask. 13 MR. EDWARDS: I can ask the question and if 14 the witness is being instructed not to answer, 15 wallet a judge decide whether he needs to answer 16 the question and whether it's discoverable or not. 17 MR. REINHART: Absolutely. Make your record. 10 BY MR. EDWARDS: 19 0. Do you have any reason to bebeve that Jeffrey 20 Epstein engaged in sexual activity with underage women? 21 A. I have no reason to believe. 22 0. Okay. So as you sit here today, based on your 23 18 years of knowledge, experience and observation of 24 Jeffrey Epstein, is it your belief that he has not had 25 sex or engaged in sexual activity with underage women? 72 1 you would classify as Jeffrey Epstein's friend? 2 A. I would dassify it. I don't know if it's 3 true. 4 O. But that's only because they were on iho s airplane together? 6 A. Yes. 7 0. Do you know whet Jeffrey Epstein dons for a 8 frying in your 18 years of observing and talking with 9 Jeffrey Epstein? 10 A. No. 11 0. No idea? 12 A. No. 13 0, Ever asked him? 11 A. No, actuary. 15 0. Ever boon curious? 16 A. Sure. 17 0. Ever done anything to satisfy that curiosity? le A. If you moan Googlo it, not realty, actually. 19 I mean. I realty have not. 20 0. Okay. So in 18 years of traveling and being 21 the pilot and driving — and taking this person, Jeffrey 22 Epstein. from one property in New York to New Mexico and 23 Florida and around the world, you have no idea what he 24 does in terms of how he makes money? 25 A. No, sir. ESQUIRE •• Ale •••4 et Ohl,. (4.1.• I Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com EFTA01110344 Larry Visoski October 15, 2009 73 0. I was produced this flight log tell me if Fin using the wrong term. What is this called, this book that I've been provided by Dave Rogers? A. I've never seen that book. O. I'll you see it. I don't know that It was r. always In a book, so maybe that's why you haven't seen it. Tel me what we're looking at. A. Wee, Judging with the name at the bottom, I 9 believe this Is Dave's flight log, log book. 10 0. I didn't know if it was called a flight log. 11 A. Pilot log book, law's that? That's the 12 appropriate name. 13 0. It was marked as Composite Exhbit 1 14 Roasts deposition. SS Indicated by the exhibit sticker. 15 Wel mark it the same in your deposition as well. 16 MR. CRITTON: Why don't you refer to it as 17 his? 18 MR. EDWARDS: Fine. 19 BY MR. EDWARDS: 20 0. ITS the pilot log book of Dave Rogers? 21 A. Yes. 22 0. And the years provided in this book are 2002 23 through 2005; I can represent that to you. I'm going to 24 ask you about certain people that David Rogers wrote 25 down as being on the airplane and I want to ask you if 1 2 3 4 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 75 0. But it's evident that the plane is being used, at least for this tine period. January ol 2002 through 2005, on a fairly regular basis. I mean. we're looking at January 6th, 1 tth, 130, 13th, 14th, right? A. Uti-huh. 0. I mean, Is that something that you would say accurately reflects the amount of use of Jeffrey Epsten's planes? A. Yes. 0. So he travels quite frequently? A. Yes. O. And he travels with many different people. 4 87 MR. CRITTON: Form. THE WITNESS: Yee MR. CRITTON: Can I ask one question? I was wondering what happened, who has possession of now what's the original Exhibit No. 1 of Mr. Rogers' deposition? Did you retain it? MR. REINHART: The actual book Itself? MR. EDWARDS: The court reporter took it. right? MR. CRITTON: The one marked as an exhibit. did you keep that? MR. REINHART: This is it. 74 you know who they are. This person right here et 2 It seems hke she flew on numerous frights. Do 3 you know whO that is? A. No. I heard the name, but I don't know who that is. 6 Q. All right. Is that somebody that you remember 7 seeing on any of the flights that you were on? A. What year are we talking about here? I don't 9 remember. to O. Well, this is January 2002. You'd probably 11 know how to read this book a little bit better than me, 12 so I don't know. 13 A. He keeps his a lot more current, so I know the 14 name. If she walked in here right now, I would probably 15 look right through her, to be honest. 16 O. Do you know what affiliation or relationship 17 she had with Jeffrey Epstein? 18 A. No. 19 0. Okay. There are various — each row I'm told 20 by David Rogers is a different flight and it indicates 21 where it takes off from and where it lands, et cetera. 22 There's a lot of other information, especially over on 23 this Side of the page that I'm not familiar with, nor do 24 I need to be. 25 A. Right. 1 2 3 4 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 76 MR. EDWARDS: This Is it? MR. CRITTON: Who took it horn the deposition the other day? MR. EDWARDS: I have this one right now. MR. REINHART: That's the only copy? MR. EDWARDS: Okay. MR. CRITTON: So you took the original? MR. EDWARDS: Apparently. It has the original sticker. MR. CRITTON. When I say "the original,* the original copy. Would you have someone recreate what you've got and send It to us so we have It? MR. EDWARDS: Sure. In fact, why don't I wait until I get the whole thing and I'll copy all the pages and send It to you Instead of piecemeal. MR. HOROWITZ: You mean before the transcript comes? MR. EDWARDS: We can copy it. MR. CRITTON: If you give it to me. It copy it and send It back to you. MR. REINHART: I have a copy. It Just doesn't have the exhbit sticker on. MR. EDWARDS: That's what was told to me the other day, that's why I took it. MR. CRITTON: I want something — I Just don't ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Ft. 33410 www.esquiresolutlons.com EFTA01110345 Larry Visoski October 15, 2009 77 want to — If you give me a copy. put a I 79 that es, door it? sticker on it. 2 A. NO. MR. REINHART: Or Just copy the page that haS 3 O. Okay. Do you know what the purpose of her the exNblt sticker on it. 4 being on the airplane tight along with Jeffrey Epstein. MR. CRITTON: Sony. 5 GNstaine Maxwell aricillIMI would be? BY MR. EDWARD$: 6 A. No. 0. Like On thiS flight, we have 'JE.` I'm assuming that's Jeffrey Epstein, correct? 7 Q. Okay. Do you know how it comes about that Milleets on that flight? How does she even know 9 A. Yes, I'll assume. 9 there's a flight available? 10 Q. 'GM, Ghislaine Maxwell, right? 10 A. I don't know. 11 A. Yes. 11 0. All right. Well, let's go down to somebody 12 Q. 12 that we may all know a little bit better. Febniary 13 A. I would assume. 13 2002, there's a flight that has Bill Clinton, tour 14 0. I mean - okay. And then this name, do you 14 Secret SenAce agents and then instead of listing names 15 recognize that person? 15 or initials or anything also, ifs just listed as two 16 A. Never heard it. 16 males, one female, Jeffrey Epstein, Ghislaine Maxwe 17 0. And therm? 17 and d forget veto Dave Rogers told me ■' 18 A. Yes. 16 I. Do you remember who that is? 19 O. You've heard that name? 19 A No. 20 A. I've heard the name. 20 0. Okay. Either way, how ht It that someone like 21 0. Not sure who that is, though? 21 Bill Calton gets on a Jeffrey Epstein light? 22 A. No. 22 MR. CRITTON: Form. 23 Q. There's only one, two, throe, four, five. six 23 THE WITNESS: I don't know, 24 people on that fight? 24 BY MR. EDWARDS: 25 A. Uh-huh. 25 0. Do you know before the fight takes off that 78 80 1 0. That's pretty typical of the amount of Bill Clinton's going to be a passenger on the flight? 2 passengers that you would have on a fight? 2 A. Yes. A. It varied, sure. 3 Q. And how do you know? How do you get that 4 0. Okay. But it varied between — If we look a 4 information? S few lines down, Jeffrey Epstein and Ghislaine Maxwell 5 A. The day before I'd get a phone call from, say. 6 were the only two passengers. Certainly there were flights like that as well, right? 6 a saying we're leaving tomorrow going to wherever, and sometimes she'll say who's going, sometimes she a A. Mm-hmm. 8 wont On a case where President Clinton would be on 9 0. And so it varied from having one or two people 9 board, we would put a lithe extra catering on board or 10 to six or seven people, right? 10 do that little extra TLC to the aircraft. 11 A. Yes. 11 0. If it's leaving — this says its leaving from 12 0. What's the most people that you remember 12 MIA and where sit landing? 13 traveling on any of Jeffrey Epstein's airplanes? 13 A. HPN I believe is White Plains. 14 A. Twenty-five. 14 Q. Okay. Do you remember that flight? 15 Q. Okay. That would be a rarity, wouldn't you 15 A. I remember being on It. 16 say? 16 0. Well. I mean, if you look through here. 17 A. Oh, yeah. 17 obviously you had BA Clinton on the airplane ten or IS 0. Because I've looked through this log. I 18 twenty times. right? 19 haven't seen any place where there were 25. but there 19 A. Yeah. He's my main focus I remember him being on the aircraft, sure. 20 are lines that have maybe eight or nine people listed. 20 21 A. Right. 21 0. Do you remember him being on the airplane with 22 0. Let's see. There's a fright from 22 younger girls? 23 January 15th sorry, January 17th, January 20th and 23 MR. CRITTON: Form. 24 January 22nd of 2002 that all That 24 THE WITNESS: No. 25 defiant serve to refresh your recollection as to who 25 ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutions.com EFTA01110346 Larry Visoski October 15, 2009 81 1 BY MR. EDWARDS: 2 O. Okay. Do you know what his relationship was 3 with Jeffrey Epstein? 4 A. No. 5 O. Do you know if they were friends? 6 A. Assuming. 7 O. But you're assuming why? Just because he's on 8 his plane? 9 A. Yeah. 10 O. Okay. So you assume that the people that are 11 listed on here are friends of Jeffrey Epsten's and 12 that's why they are riding on his plane? 13 A. I'm speculating. 14 0. I'm Just not familiar with the -- because rye 15 never been on a private flight with the manner in 16 which you go about getting on one of these flights. I 17 mean, you have to, I guess, know that Jeffrey Epstein 18 has a plane, that it's going from a destination that you 19 are at and want to go to, and that it's avelable and 20 those kind of things. Can you tell me, enlighten me -- 21 A. Weil, it's not publicly offered, no. it would 22 be no different than you limping In your car and knowing 23 you're going to the mall. I moan, It's not public 24 information, you know, where planes are coming to and 25 from, and you don't put your name out there to get 83 1 this time with Doug Band, three Secret , 2 Jeffrey Epstein, Ghislaine Maxwell Do 3 you remember that flight? 4 A. Where did we go? 5 0. Starts In JFK. 6 A. Flight. O. Where is that? 8 MR. CARTON: Do you have a date? 9 MR. EDWARDS: March 18th. 2002. 10 THE WITNESS: EGGW I believe is Luton, 11 England. 12 BY MR. EDWARDS: 13 0. Okay. Do you remember flying to England? 14 A. I do remember flying to England. I just don't 15 remember that trip. What airplane were we In? We were 16 in the Boeing. 17 O. Do you remember the purpose of the trip? 18 A. No. 19 O. Do you know who Doug Band is? 20 A. I heard he's Clinton's, how would you say, 21 assistant. I mean, I've seen that in the newspaper. 22 seen a on CNN. 23 O. Okay. Did you ever hoar that Doug Band and 24 Ghlslane Maxwell were together. even for a day or a 25 night? 82 onboard a flight. 0. Does Jeffrey Epstein charge these people as 3 passengers? 4 A. I don't know. O. Okay. Are these people such as Bill Clinton. 6 does that mean that &a Clinton called or somebody affiliated with Jeffrey Epstein to get on the 8 plane or that Jeffrey Epstein called Bill Clinton and 9 asked do you want a ride? c MR. CRITTON: Form; predicate. 11 THE WITNESS: I have no idea. 12 BY MR. EDWARDS: 13 O. No idea? 14 A. No idea whatsoever. 15 O. Joe Pagano, do you know who that is? 16 A. Yes. 17 O. What's his relationship with Jeffrey Epstein, 18 or what was it back in Febnia sorry, March 17th of 19 2002, when he and and Jeffrey Epstein and 20 Todd and one female were on this flight? 21 A. I don't know to what extent or what his 22 relationship is. He Just was a passenger on the 23 airplane. 24 0. Okay. And the next day sorry, two days 25 later on the 19th of March, Bill Clinton flies again, 84 1 A. No. 2 a Did you ever hear that Doug Band and Ghislaine 3 Maxwell were the people attributed to introducing ea 4 Clinton and Jeffrey Epstein? 5 MR. CRITTON: Form. 6 THE WITNESS: I don't know. 7 BY MR. EDWARDS: O. All right. There's another flight here on 9 January I can/ read this upside down. Maybe it says 10 May — 11 A. Looks like. 12 0. -. 22nd, 2002 Again, with President BS 13 Clin . Can you tell me who 14 and are? 15 A. I don't remember. 16 0. Would you know them if you saw them? 17 A. Probably not because the names don't even ring 18 a boll. 19 O. All right. And then there are plenty of 20 flights. many of eights vA 1 Epstein, 21 Ghlslaine Maxwell and are the primary 22 passengers. or at least are some of the passengers on 23 the flights, correct? 24 A. Mrn-timm. yes. 25 0. And still, as you sit here, you being the ESQUIRE Tell Free: 866.709.8777 FacslMile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 iinvw.e5guiresolutions.com EFTA01110347 Larry Visoski October 15, 2009 85 1 pilot of these flights, you're not sure what their 2 relationship is or whether any of them were socially 3 connected in any real way? 4 MR. CRITTON: Form. 5 THE WITNESS: No. When you're flying the 6 airplane, there's a lot more going on than 7 passengers' relations. 8 BY MR. EDWARDS: 9 O. All right. You remember this person.l. 10 OM are you familiar with her at all? 11 A. I remember the name, that's it. 12 O. What do you think her relationship is to 13 Jeffrey Epstein? 14 A. No idea. 15 MR. CARTON: What date are you on. Brad? 16 MR. EDWARDS: Oh, sorry. I am at June 21st, 17 2002. 18 BY MR. EDWARDS: 19 Q. Tilers not somebody that you specifically 20 remember? 21 A. Mm-mm, no. 22 Q. No? Is that somebody that you think was a 23 regular flyer for any period of time in Jeffrey 24 Epstein's life? 25 A. Not a regular. 87 1 we're referring to the same flight on June 21st of 2002, 2 that includes Jean Luc Brunel, Jeffrey 3 Epstein. Chelan° MeueveliMillit, Mose are the 4 passengers of the flight, does that serve to jog your 5 memory as to wt as is? A. No. I mean, you see how frequently wo fly. I 7 mean. it's the passengers in the back are so far 8 removed from an operation of commanding an airplane like 9 that, Its nothing that sticks 11 your head. 10 O. And you as the pilot, is there any way that 11 you would know what's going on In the back of the 12 airplane? 13 AL No. My concerns are all on the optical!. 14 MR. CRITTON: Brad, the last one that you mentioned, was that the same date. June 21st. '02? 16 MR. EDWARDS: Yes. 17 BY MR. EDWARDS: 18 O. There's another name here that I was going to 19 ask you do you know. June 23rd. 2002. 20 are you familiar with that name? 21 A. No. 22 O. Also on the same flight with Jean Luc Brunel. 23 That doesn't help to jog your memory either, right? 24 A. No. 25 O. That's somebody that you remember as a 86 O. Okay. Jean Luc Brunel, is that a name that 2 you know? 3 A. Yes. 4 O. Now do you know that name? 5 A Orly because it's a unique name and his attire 6 79 very unique. So you remember certain things. So I 7 know he who that Is. 8 Q. Do you know what he does? 9 A. No. 10 O. Do you know his association with Jeffrey 11 Epstein, if any? 17 A. No, I don't know what the relationship Is. 13 O. Nave you ever heard of him owning or running 14 or managing a modeling company? 15 A. I have seen that in the paper a taw years 16 back. 17 O. Okay. Other than seeing it in the Pats, have 18 you ever talked to Jean Luc Brunel or Jeffrey Epstein 19 about owning or running or managng a modeling company? 20 A. No. 21 O. Do you know if Jeffrey Epstein's affiliated 22 with the modeling company that's owned. run or managed 23 by Jean Luc Brunel? 24 A. No, I have no idea. 25 a And seeing that this is a flight now, that 1 2 3 4 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 88 frequent passenger? A. Who are you referring to? O. =NM ? A. No. Q. Dr...larecki, is that somebody that you remember frying? A. I know the name. He may have been on the airplane once or twice. I'm guessing only. Q. Do you remember meeting him? A. Yes. I have met him. O. Do you remember his purpose for being on the airplane? A. No, Sir. O. Amanda Venaro, do you remember her purpose tot being on the airplane? A. No. MR. REINHART: Can we get a date? MR. EDWARDS: I was asking him if he remembered Amanda Venom. I wasn't referring to a specific night. BY MR. EDWARDS: O. You dent remember her being on the flight? A. I don't remember the name. O. Me showing you the flight isn't going to jog the memory? ESQUIRE •• AP 4444 ci Gavle Company Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Fl. 33410 www.esquIresolutIons.com EFTA01110348 Larry Visoski October 15, 2009 2 3 89 A. No. The name that would launch it first MR. CRITTON: Could I ask you a question? You have the original exhibit marked at the deposition. It looks like it's been highlighted. MR. EDWARDS: I highlighted it. 1 2 3 4 5 91 see her name, that doesn't change your opinion as to whether or not you remember her or what -- A. I remember the name, you know, that's all. 0. Do you remember about what age she was when the was flying on the airplane? 6 MR. CRITTON: Oh. okay. So you've highlighted 6 A. No. 7 the original exhibit that's marked for the 7 0. This could be somebody who is 50 years old or a deposition? I just want the record to reflect ten years old, for all you know? 9 that. MR. CRITTON: Form. 10 MR. EDWARDS: Yeah. 10 THE WITNESS: Yes. 11 MR. CRITTON: Okay. Thank you. 11 BY MR. EDWARDS: 12 MR. EDWARDS: At the time I highlighted It I 12 0. Okay. 13 didn't realize I was holcing on to the original 13 A. I mean, I would only be guessing at an age. 14 exhibit. I didn't realize that until you just 14 Q. Yeah, but I mean• you don't remember her at 15 pointed that out. 15 all. So you don't -- 16 MR. CRITTON: I've noticed that. 16 A. I remember the name, exactly. 17 MR. EDWARDS: So now when I give it to you, 17 0. Other than the name? 18 I'm giving you my work product as wet. I don't 18 A. Right. yes, sir. 19 see how this works against you, but anyway. 19 0. But you can't even come close to putting a 30 BY MR. EDWARDS: 30 face with that name? 21 0. Melissa Stall. is that a name that you 21 A. I mean, no. I mean, it you said draw her 22 remember? 22 picture with I couldn't come close to even getting 23 A. No. 23 s. 24 0. Okay. And then Jean Luc Brunel is Somebody 24 Q. Okay. You remember this flight where 25 who I noticed flew relatively frequently, so is that why 25 President Clinton, Kevin Spacey and Chris Tucker, 90 92 1 you -- that name jogs your memory a little better than 1 Jeffrey Epstein. Ghislaine Maxwell? 2 some of these other people? 2 A. Yes. A. He dresses uniquely. 3 Q. From JFK to what is this, LPAZ? 4 0. In what way? 4 A. LPAZ, that Is A. Just loud clothes, so something that you would 5 0. South Attica or something? 6 remember, that's all. 6 A. No, it's the Azores Islands, Santa Maria. 7 0. Do you know his role in Jeffrey's ide? 7 0. Do you know the purpose of that trip? 8 A. No. a A. That was a fuel stop. 9 Q. Ever heard that he is affiliated with Jeffrey 9 0. Okay. And do you know why Chris Tucker and 10 Epstein because they both have a sexual attraction to 10 Kevin Spacey were on that airplane? 11 underage girls? 11 A. No. 12 MR. CRITTON: Form. 12 0. Did you talk to them? 13 THE WITNESS: You're making an assumption on 13 A. They came up in the cockpit and said hello. 14 that_ 14 So they conversed, nothing more. 15 BY MR. EDWARDS: 15 0. Another name that is on here a few times, I'm 16 Q. Have you ever heard that? 16 specifically referring right now to the dates of 17 MR. REINHART: He's asked you if you ever 17 September 23rd and 24th of 2002, is Ron liturkle. Do you 18 heard that. 18 know who that Is Ron Buride? 19 BY MR. EDWARDS: 19 A. I know what that is, yes. I didn't realize he 20 0. It your answer is no, It's no. 20 was on our airplane. 21 A. I'm sorry, I thought you said they did. No. I 21 0. Right now that is the first time that you 22 have not. 22 remember Ron Burkle being on your airplane? 23 0. Okay. I keep highighting this name, 23 A. Yeah. 24 MB just because it looks like somebody that's 24 0. You don't know the purpose fix him being on 25 regularly flying on the airplane. But Me more that you 25 that airplane? ESQUIRE •• C•Olo CaaNAY Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Ft. 33410 www.esquiresolutIons.com EFTA01110349 Larry Visoski October 15, 2009 93 A. No. Granted, I'M seeing this for the first 2. time, so I'm trying to — 0. Let me ask you that. Because this was given to me at a deposition of Dave Rogers. who I understand 5 was the chief pilot for Mr. Epstein. and now y0ute the cheap pilot. but you always kind of worked in tandem, 7 correct? A. Sure; we complemented each other. 9 0. And you both worked for the same company that 10 fries Jeffrey Epstein's airplanes, right? 11 A. Yes. 12 0. So I was of the presumption, which may have 13 been - I may have been misled here, or I may have, you 14 know, misunderstood the purpose behind this book or how 15 it was created. I thought that you had probably seen 16 this before at some point in time? 17 A. Oh, no. 18 0. Dld you know that Dave Rogers was keeping this 19 book? 20 A. No. I know he keeps a Piet log book. 21 0. Okay. But you didn't know he was keeping the 22 names of the people who were on the airplane? 23 A. No. Its not required. so I mean, it's.. 24 0. So today is the first time that you are 25 teaming that the names of the people that we on the 1 2 3 4 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 95 BY MR. EDWARDS: 0. Okay. You don't remember which tights it would have been where there would have been girls under the age of 18? MR. CRITTON: THE WITNESS: Wel, I would have to look at the fright logs. BY MR. EDWARDS: 0. Irs not illegal to have somebody under the age of 18 on a flight anyway, right? A. No, not at all. 0. Were you ever aware that you, as plot, wore transporthig girls under the age of 18 who were supposed to be models? MR. CRITTON: Form. THE WITNESS: I had no knowledge. BY MR. EDWARDS: 0. Okay. You never knew who the people on th,_ airplane were, what their purpose was, their role with Jeffrey Epstein or Jean Luc Brunel? A. No. Q. All right. Do you knot I? A. No, I dont remember that name. Q. A. I remember the name. 94 1 airplane was kept by Dave Rogers? A. Yes, in his log book. 0. Okay. And it's my understanding when you fly back into the country through Customs. you have to report the people that are on the airplane, right? A. Yes. 0. And who would create that document or call a that information into Customs? A. Whoever the captain was for the day. 0. At times would that be you? 11 A. Yes. 12 0. Okay. And at times when you would come into 13 the country with passengers — well, not at times. 14 Didn't you else have to report their date of birth? 15 A. Sure. 16 0. At tines weren't there also people that you 17 would bring in from other countries into the United 18 States that were under the age of 18? 19 A. Yes. 20 0. And at some times those were flights that 21 Included Jean Luc Brunel and girls that were under the 22 age 0118, right? 23 MR. CRITTON: Form. 24 THE WITNESS: I don't remember those flights. 25 4 96 1 0. She flew frequently at least for a period of 2 lime. Do you remember that? 3 A. Yes. 4 0. Is that somebody that you thought was familiar 5 with the modeling industry or related to the modeling 6 industry? 7 A. No. 0. Okay. And these people, did Jeffrey Epstein 9 ever tell you how he was associated with any of them? 10 A. No. 11 0. Did you ever wonder how he was associated with 12 any of thorn? 13 A. No. never interested. 14 Q. And on several of these on most of these, 15 the names or Initials of the people that are on the 16 flight are listed. Do you know on the occasions where 17 it lists generically two females or three females or six 18 females, do you know why that was done? 19 A. Just because we didn't know our the 20 person's name. We hied to do the best we could to keep 21 the records. 22 0. When you say 'we tried to do the best that we 23 could 24 A. Dave and I. 25 0. Okay. But the first time that you learned ESQUIRE .. A Inman, (.110 Coa•Noy Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquireSolUtions.coM EFTA01110350 Larry Visoski October 15, 2009 97 1 that he kept anybody's names was today, right? 2 A. Well, I didn't know he kept them in his log book. We would fill out the passenger manifest as 4 we're — having passengers' names in your pilot log 5 book, he's probably the only person in the world that 6 does that. 0. Okay. 8 A. So when you were mentioning putting the names 9 down, when you said female or mate, you know, I was 10 referring to the passenger manifest. 11 0. For each of these same flights, then, that 12 we're referring to out of this log book that was marked 13 as Composite Exhibit 1 in Dave Rogers' deposition, am I 14 understanding you correctly, then, there would also be a 15 passenger manifest for each of these flights? 16 A. Yes. 17 0. Now, where would I find the passenger 18 manifest? Who keeps that documentation? 19 A. Corporate -- our corporate office. 20 Q. Which is whom? 21 A. Up in New York, Darren Indyke. 22 0. At what corporation is that, though? 23 A. NES, LW. I guess. 24 MR. REINHART; Do you know for sure? 25 THE WITNESS: I don't know for sure. I moan, 99 1 at the airport office that I had turned Into 2 counsel that has the passenger names on them. 3 BY MR. EDWARDS: 4 0. Okay. • A. It's called a passenger manifest. 6 0. Okay. 7 MR. REINHART: Right. • BY MR. EDWARD$: 9 0. The passenger manifest, just so I understand 10 exactly what that is. ten me. Tell me in your own 11 words. 12 A. It's departure time, the city, the landing 13 time exactly and the passengers that would have been on 14 that flight. 25 0. And at times on that passenger manliest would 16 you IS also generically female or male? 17 A. Yes. That was the document I was referring to 18 staling that if we didn't know a person, we did not go 19 out of our way to find out a name. We just put in to 20 account for how many people were on the aircraft at that 21 time. 22 0. Who is currently in the custody or control -- 23 sorry. Who currently maintains or has possession of the 24 passenger manifest from 1998 through the present, 25 through today for those airplanes that you flew related 98 1 when you say -- we would just send them up to New 2 York. 3 BY MR. EDWARDS: • Q. Did you ever keep a copy of them? A. No. 6 0. Why did you keep a passenger manifest? 7 A. Just for tracking of to have the times on s there for -- 9 MR. REINHART: Can I confer with him on one 10 thing before you ask a question? 11 MR. EDWARDS: Yeah, yeah. 12 (Off the record discussion.) 13 MR. REINHART: Mr. Edwards. let him amend his 14 prior answer. I think he misunderstood the 15 question 16 MR. EDWARDS: I don't know what question we're 17 amounting the answer to. 10 MR. REINHART.. Lot me clarity this way: As 19 the passenger manifests, they are corporate 20 documents of either JEGE or Hyperion Air, whatever 21 company owns the plane. Mr. Visoski has physical 22 custody of them. He retains them but they're not 23 his documents. They're the corporate documents. 24 So they're not in New York. 25 THE WITNESS: Those are the ones that I have 100 1 to Jeffrey Epstein? 2 A. I currently have, which counsel has now. 2005, 3 I believe, until the present time. And the records 4 previous to that I believe were turned into counsel with 5 the previous investigation with Jack Goldbergers 6 office, I believe. I believe they maintain those 7 records, 8 Q. When you Say "turned into counsel." there are 9 a lot of counsel involved here. to A. Jack Goldberger's office. I believe. 11 0. When you say "the previous investigation,' 12 you're talking about the criminal investigation? 13 A. Exactly, yes, sir. 14 0. And you're aware in that criminal is investigation, obviously, that Jeffrey Epstein pled 16 guilty to certain charges, correct? 17 A. From what I read. yes. 18 O. Well, you did visit him In jail, right? 19 A. Yes. We didn't talk about that. 20 0. Okay. You knew In order to go to jail. 21 though, you have to be convicted of some crime, right? 22 MR. CRITTON: Form; argumentative. 23 THE WITNESS: Yes. 24 BY MR. EDWARDS: 25 Q. It wasn't ►ke he was visiting the Jail and ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 vinvw.esquiresolutions.com EFTA01110351 Larry Visoski October 15, 2009 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 101 you were visiting and you happened to bump into each other. You actually went to see him while he was an inmate In Jail? A. Right, yes. O. Okay. So when were talking about the criminal investigation, were talking about the criminal investigation revolving around the allegations of Jeffrey Epstein engaging in sex acts with minors? MR. CRITTON: Form. BY MR. EDWARDS: O. That's the criminal investigation you're talking about, right? MR. CRITTON: Form. THE WITNESS: I don't know the full definition of really what happened there. I know that it was something to do with solicitation of prostitution. That's al I road. BY MR. EDWARDS: O. Okay. Were you aware that the allegations revolved around underage girls or gins under the ago of 18? MR. CRITTON: Form. THE WITNESS: I was aware it revolved around it, yes, 103 Q. And for the passenger manifest prior to 2005. 2 how far do those passenger manifests go back In time? 3 A. They should go back. I guess. to 1991 or 4 whenever we started existence. 5 Q. And did you turn them over from 1991 all the 6 way through to 2O05? 7 A. I deal know. I didn't tum them in. Dave 8 Rogers did. 9 O. Are you in possession of a copy of any of 10 those materials? 11 A. No. 12 O. I thought that, you know, ten minutes ago when 13 we were taking about this you said you had them back at 14 an once or -• 15 A. That was the office, the airplane office. 16 which I've given to Bruce, which is the current log. He 17 is in possession of them now. I had possession of them. 18 O. Okay. What he's in possession of --just so I 19 know what documents are where, he's in possession of the 20 passenger manifests from 2005 through the present? 21 A. Correct. 22 Q. It I want to obtain the passenger manifests 23 from 1998 through 2005. Mars something that 1 woulc 24 request from whom? 25 THE WITNESS: Help me out. That's -- 1 0 2 I BY MR. EDWARDS: O. Who first made you aware of that? A. The newspaper. O. Wore you ever questioned by the police? A. I don't know who questioned me, actualy. I 6 did have a questioning session, but I don't even 7 remember who questioned me. 8 O. Where did that take place? A. I don't remember. 10 O. At your house? 11 A. No. I'm thinking it was Jack Goldberger's 12 office, or n may have been downtown al the Pen Beach 13 County Courthouse or something in that area there. 14 O. Okay. So it either happened at an attorneys 15 office that represented -- 16 A. Exactly, yeah, I think so. 17 O. — Jeffrey Epstein or the other side? 18 A. Yeah. 19 Q. And during that questioning, is that when you 20 turned over the passenger manifest from prior to 2006? 21 A. Yes. 22 O. And you turned those manifests directly over 23 to Jack Goldberger? 24 A. Yes. Actually. I bees Dave Rogers did 25 that. I wasn't in possession of those records. I 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 104 MR. REINHART: If you know. THE WITNESS: I don't know who possesses them right now. They were turned into Jack Goldberger's office a year and a half or two years ago. BY MR. EDWARDS: Q. You started out by indicating that you sent these passenger mardests, or a copy thereof, to Darren Indyke or someone at NES. LLC; is that correct? A. Correct. O. If I requested them from NES, LLC, that's somebody at some point in time was in possession of all the passenger manifests? A. Sure. O. And NES, LLCS address is the one you gave me a. A. I believe so. I don't know what address they're using for that. I know that -- O. But Darren Indyke's the attorney that I would call — A. Yes, sir. O. - and he could probably steer me m the right clrection? A. Yes. MR. CRITTON: Form. ESQUIRE os Al ortat O.2lo Coseany Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 vnvw.esquiresolutlons.com EFTA01110352 Larry Visoski October 15, 2009 105 BY MR. EDWARDS: 0. Do you know Amy Taylor? A. Yes. 4 a How do you know her? A. She was on the airplane. 0. How old is she? A. I have no idea. 0. Age range? 9 A. Twenly-eight. 10 0. NoW? 11 A. Yeah, 28, or maybe if not older now. She was 12 probably 28 probably. I guess. She was somebody in her 13 late 20s. 14 0. So we're talking about 2003? There what I'm 15 trying to understand. 16 A. I'm guessing. 17 0. We're talking 2009 now. We're saying 28. By 18 that do you mean in 2003 she was 23 or 24 years old? 19 A. You're having me guess on her age. 20 Q. Yeah. 21 A. I mean. I can't be accurate. 22 0. Somebody between 18 and 25? 23 MR. CRITTON: Fonn. 24 BY MR. EDWARDS: 25 0. At the erne you were seeing her back in •- 107 1 hello. 2 Q. That's somebody who was on the airplane 3 multiple times? 4 A. More than once. I mean. I have no account for 5 how many times. 6 0. Well, I've asked you about a bunch of names, 7 most of which you don't really remember. but that's one 8 name you do remember. 9 A. Yeah, I remember the name, yeah. 10 0. Okay. And that's somebody who you actually -- 11 you would remember the face too? 12 A. I might remember Amy's face. 13 Q. A8 right. Do you remember why she would have 14 ever been on your airplane? 15 A. No idea. 16 Q. President Andres Postrana, at the time I guess 17 That was the president of Colombia back m February 18 sorry, March 200 of 2003. Do you know who that is? 19 A. I don't remember him being on the airplane, 20 but I know who that Is. 21 0. Okay. He's on the airplane with Jeffrey 22 Epstein, Ghislaine Maxwell, IMMIand Jean Luc 23 Brunel? 24 A. Where hid we go? 25 Q. Fillet you look at it. I'm talking about 106 A. II you want me to guess •- 0. No. I don't want you to guess. A. I don't 'mow then. 0. Wet. if I say between ten and fifty? A. That's a range. Q. If I say between ten and fifty, you're not 7 guessing there anymore. You know she's in there, right? a A. She's in the middle there, yeah. 9 0. Okay. How can we narrow that down? We're 10 talking about somebody in her 20s? 11 A. In her 20s. 12 0. At least that's what you believed? 13 A. Yes. 14 Q. All right. Is that somebody that you know to 15 be associated or friendly with Ghislaine Maxwell? 16 A. I don't know. 17 Q. Do you know what her relationship was to 18 Jeffrey Epstein or Ghislaine Maxwelr? 19 A. No. 20 0. Do you know where she is now? 21 A. No idea. 22 Q. When's the last time you talked to her? 23 A I don't know. What date do you have on there? 24 0. February 2003. 25 A. So, probably that long ago. I may have sald 108 1 this line, PSI, left out of Palm Beach? 2 A. Palm Beach to Nassau. I'm sorry. I don't 3 remember Mat one. 4 0. When we're saying we're going down to Nassau, 5 is that a place that you frequently went to with the 6 airplane? 7 A. No, not at all. 8 0. And is that a route that you would take for 9 the ultimate destination to be Little St. James? 10 A. No. 11 Q. If the ultimate destination was Little 12 St. James show me a flight where the ultimate 13 destination was Little St. James. 14 A. Yeah, right here. TIST, Mat's St. Thomas. 15 Q. Okay. So on that flight that you just pointed 16 to, March 27th, 2003, we have Jeffrey Epstein, ME 17 MI --again, Brent Tyndall - do you k^oti, 18 who Brent Tyndall Is? 19 A. Yes. 20 0. And who is that? 21 A. I believe he was the chef. 22 0. And (phonetic), is that 23 somebody you know to be a model these days? 24 A. I have no idea. 25 0. Do you remember that flight? ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esqulresolutIons.com EFTA01110353 Larry Visoski October 15, 2009 109 1 A. No. 2 Q. Do you remember Naomi Campbell, picking her up 3 from St. Thomas along with Jean Luc Brunel? 4 A. I remember her being on board. I don't 5 remember the flight. 6 0. Do you know Joel Pashcow? 7 A. Yes. 8 0. How do you know him? 9 A. He was on the airplane. 10 0. And is that somebody you knew at one point in 11 time to be a friend of Jeffrey Epstein's? 12 A. He was on the airplane. I don't know what the 13 relationship was. 14 0. Do you know what the relationship Is today? 15 A. No idea. 16 Q. How about Todd Mister, do you know what that 17 relationship Is or was today? 18 A. No. 19 Q. Do you remember him? 20 A. No. 21 Q. Not at all? 22 A. I mean, I know the name. I don't know. 23 0. Paula Epstein, do you know who that is? 24 A. Yes. 25 0. Who Is that? 111 1 film wound Jeffrey Epstein? 2 A. No. 3 0. All right. 4 A. No. 5 Q. do you know that name? 6 A. No. 7 Q. She was on several flights. You don't remember seeing her? 9 A. No. 10 0. All right. And how about Alan DershmWtz, I'm 11 sure you know wto that is? 12 A. Sure. He's famous. 13 0. What was your understanding of Alan 14 Dershowites relationship with Jeffrey Epstein? 15 A. Never talked about A. 16 0. Forrest Sawyer. do you know why he was on your 17 airplane? 18 A. Never heard the name, actually. 19 0. Really? 20 A. No. 21 0. Larry Summers? 22 A. I know the name. I don't remember flying him 23 0. Have you ever talked to Joe Fontanela? 24 A. Yes. 25 0. How do you know him? 110 1 A. That's Jeffreys morn. 2 0. She's passed away? 3 A. Yes. 4 0. At least that's your understanding, right? 5 A. That's what I heard, yes. 6 0. Oka . do you know her? 7 A. , I know the name. 8 O. Somebody who flew on the airplane with some 9 regularity? 10 A. Yes. 11 0. And do u know her to be friends of Ghislaine 12 Maxwell or or Jeffrey Epstein? 13 MR. CRITTON: Form. 14 THE WITNESS: I have no idea who she was 15 friends with. 16 BY MR. EDWARDS: 17 Q. All right. Do you know what rote she ever 18 played, if she played one, In Jeffrey Epstein's life? 19 A. No. 20 O. All right. Glenn Dubin, are you familiar with 21 Mm? 22 A. Yes. 23 0. How do you know Glenn Dubin? 24 A. I met him on the airplane. 25 Q. Outside of the airplane, have you ever seen 112 1 A. He usually drops Jeffrey off at the airport. 2 0. In fact, you've called him directly before, 3 right? 4 A. Yes. 5 0. You still have his number? 6 A. I haven't — yes. I think I still got it in my 7 memory. 8 Q. Okay. What is it? 9 A. It's been a few years. 10 kind of an easy one. 11 MR. CRITTON: 917 is the first -- 12 THE WITNESS: Yes. 13 MR. CRITTON: Who was this for? 14 MR. REINHART: Joe, Joe Fontanela. 15 MR. EDWARDS: Fontanela. 16 BY MR. EDWARDS: 17 Q. Do you know his address, where he resides? 18 A. No, I don't. 19 0. Do you know if he — what his role is in 20 Jeffrey Epstein's life? 21 A. Not really. He just •. ho drove the car. 22 Q. He drove what car? 23 A. The car up In Now York. 24 Q. Okay. Do you know if he's a housekeeper up at 25 that house up in New VOW? 0 ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutlons.com EFTA01110354 Larry Visoski October 15, 2009 113 A. I don't know what his role Is. Q. Have you ever worked fora company caked Air 3 Ghislalne? Do you know that company? A. Yes. 5 Q. Do you know what that company does? A. No. Q. Have you ever been an employee of that company? 9 A. No. 10 Q. Do you know who runs that company? 11 A. No. 12 O. IS Jeffrey Epstein associated with that 13 COmpany? 14 A. I don't know. 15 O. How have you heard of that company? 16 A. It's the company name that our registration 17 for the helicopters is under, Air Ghislatne. 18 O. Is that somebody who's ever paid you, a 19 company who's ever paid you? 20 A. No. 21 O. Do you know Igor Zinoviev? 22 A. Yes. 23 O. How do you know him? 24 A. Met him on the airplane. 25 O. What is your understanding of his allikelion 115 1 O. Do you know did you tell me, do you knov 2 what Leslie Gruff does for Jeffrey Epstein? 3 A. I don't know her exact tine. 4 O. You talked to all of these individuals at some 5 point in time, either on the phone or in person, right? 6 A. Yes. 7 Q. And you don't 'mow whether they playa role in 8 Jeffrey Epstein's life, or if they do, what they do? 9 A. Exactly. 10 Q. And how do you decide who you're going to call 11 for what reason? 12 A. For example? Can you be more specific? 13 O. If you're going to make a telephone call and 14 you're going to talk to let's say Leslie Gruff, why 15 would you choose to call her? 16 A. I don't know. You're having me make the phone 17 call. I don't know why I would call her. 18 O. Have you ever called her? 19 A. I think, yes, I've called her, sure. 20 O. Why? What would be the reason that you would 21 call her? Somebody told you to call her? Here. Carl 22 this number? 23 A. I may have called her maybe to find out if w,. 24 had a departure time for any specific trip. I mean, 25 that would be... 1 2 3 4 5 6 $ 9 10 11 12 13 19 15 16 37 18 19 20 21 22 23 24 25 114 with Jeffrey Epstein? A. I don't know. He doesn't talk much. O. Okay. And Sandy Berger, do you know who that le? A. I don't know. O. Do you know any reason why you would have trim him on the airplane? A. I don't even know the name. O. A. I know the name O. Somebody who flew on the plane pretty regularly? A. I would have to look at the logs. I think we've had that name on several -- it's a common first name. I'm not familiar really on who that is. Q. What about Bella, do you know who Bella is? Is that a name you ever heard? A. Yes. Q. Works up in the New York office or something? A. Yes. O. Have you ever spoken with Bella personally? A. Yes. O. Do you know what she does for Jeffrey Epstein, N anything? A. I don't know exactly what her role is. 116 1 O. Okay. So you're calling her related to 2 Jeffrey Epstein? 3 A. Sum. 4 O. Okay. So you know that she plays some role in some aspect of Jeffrey Epstein's life, whatever that is? 6 A. Right. 7 O. Okay. So when I'm asking these questions about those people, and I feel like I'm getting answers 9 that I'm not *fly not sure that these people have any 10 role in their life, that's not that's not completely 11 accurate, right? 12 MR. CRITTON: Form; argumentative. 13 BY MR. EDWARDS: 14 Q. I mean, you do know that these people are 15 somehow Involved with him, whether socially or 16 business-wise or otherwise, and during the course of 17 your years, you've made telephone calls on his behalf or 15 to coordinate things with them right? 19 A. Right. 20 MR. CRITTON: Object to the form. You said 21 'these people." 22 BY MR. EDWARDS: 21 O. I'm talking about That's 24 somebody you called before, right? 25 A Sure. ESQUIRE . AlgiaaJoi .lv WY Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110355 Larry Visoski October 15, 2009 117 O. What would be a reason you called 2 3 MR. CRITTON: Object to form. Probably the • same reasons he said two hours ago, for scheduling 5 purposes. But you've covered that. Go ahead and • answer it again. • THE WITNESS: For scheduling purposes, would 8 be my only reason to call her. 9 BY MR. EDWARDS: 10 0. That's funny that you used the exact same 11 words that Mr. Clifton wants you to use. 12 MR. CRITTON: It's what he said two hours ago. 13 BY MR. EDWARDS: 14 O. What would be the reason why you would call 15 Ms. Maxwell, Ghislaine Maxwell? 16 A. Same reason. 17 0. That's not somebody you call these days, 18 though, right? 19 A. I haven't seen her in some time. 20 0. What made you stop calling Ghislaine Maxwell 21 where you thought at one point in time you thought she 22 was a person to call related to your job? 23 A. Just was no reason to. 24 0. Is that somebody who you think is still 25 affiliated or associated with Jeffrey Epstein or -- 119 1 BY MR. EDWARDS: 2 0. Do you remember making that phone call after 3 reading the message? 4 A. Let me look al the date here. Okay. March. 5 MR. REINHART: The question is, do you 6 remember making the call? 7 THE WITNESS: Okay, let me. "Person for the 8 car will be here in 15 minutes to drop off foam and 9 Panora.' I don't know. 10 BY MR. EDWARDS: 11 0. That doesn't mean anything to you? 12 A. That doesn't — I mean, you're talking four 13 years ago. I can't answer that accurately. I mean... 14 MR. REINHART: So the answer is you don't 15 recall? 16 THE WITNESS: Yeah, I don't recall 17 BY MR. EDWARDS: 18 O. If you don't remember, that's fine. 19 (Plaintiffs Exhibit Nos. 2 AND 3 were marked 20 kw Identification.) 21 BY MR. EDWARDS: 22 0. So Ill show you Exhibit 3, the same type of 23 document, and I can make the representation that It 24 was message pads provided by the state attorney's office 25 relative to the criminal investigation revolving around 118 whatever he does? A. I'd only can speculating. I don't know. C All nit. Do you know the number MR. CRITTON: Could it slowly. E tt MR. EDWARDS: Thank you. And just in case you didn't get it, rm going to mark those as an exhibit so that we can read them later. 9 BY MR. EDWARDS: 10 O. Do you know that number? 11 A. Yes. 12 O. What Is that number? 13 A. That's my cell phone 14 O. Okay. Is that still your cell phone? 15 A. Yes, sir. 16 O. All right. rm going to show you two 17 documents here or pieces of paper. Well mark them as is Exhibit 2 and Exhibit 3. The nun coo re dated 19 March 5th, 2005. Do you remember making this telephone 20 call? And just for the record, this looks like a x message that's being taken relative to a phone can that 22 you made. 23 MR. REINHART: So the question Is does he 24 remember making the phone call, 25 120 1 Jeffrey Epstein. So that's how I have these documents. 2 I'm not trying to pull out old documents. 3 MR. CRITTON: What's the date? 4 MR. EDWARDS: March 19th. 5 MR. REINHART: The question is, do you 6 remember the call! 7 THE WITNESS: Toni from Midnight Express is at' help me out — 'convention center with new 9 boat. They are two points — two parts of this." 10 BY MR. EDWARDS: 11 0. "Show"? 12 A. "Show up the water" -- 13 MR. REINHART: "On the water." 14 THE WITNESS: "On the water and at the 15 center.' 16 BY MR. EDWARDS: 17 O. Do you remember making that call? 18 A. No. I mean, Torn from Midnight Express is at 19 convention center with new boat. They are two parts 20 of' I mean 21 0. But as Jeffrey Epstein's Met. why would you 22 be leaving such a message about Tom from Midnight 23 Express relative to boats and a boat show? 24 A. I help out with boat purchases or, you know, 25 anything to do with, you know, that moves. So I mean, ESQUIRE Alandet Gala COSAP•41 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresoludons.com EFTA01110356 Larry Visoski October 15, 2009 121 Q. Okay. When you say "you help out with boat purchases,' what do you mean? A. Stye my opinion, whether or not whether to buy a certain boat. h's just a hobby. I have knowledge on boats. Not only just airplanes but, you know, O. You give your opinion to whom? A. To Jeffrey. 9 0. Okay. And Jeffrey Epstein obviously, at least 10 in your mind, you believe he wants your opinion? 11 A. Yes. 12 0. Okay. So boats Is another thing that Its two 13 of you have discussed? 14 A. Yes. IS Q. All right. And so this a conversation or at 16 least some evidence that a conversation existed between 17 yourself and Jeffrey Epstein relative to a boat or a 18 boat show? 19 A Correct. 20 Q. Do you remember having that conversation? 21 A. We've had many conversations about boats acid 22 different boat stows. If you're referring to this one 23 in '05, I don't recall this one. 24 0. Okay. So aside from being a pilot — which 25 throughout this entire deposition I believe your 123 1 0. And has he consulted with you on each of the 2 purchases? 3 A. Not every one of them, no. 4 Q. Does he own any boats now that you're awnr, 5 of? 6 A. I don't know if he owns them or not. 7 Q. Okay. Do you know of any boats that he controls or maintains? 9 A. Himself or? io 0. How about this III ask you this way. 11 don't want to split hairs with you here: I know we ve 12 been talking about corporations and things iike that. 13 A. Yes he. 14 Q. Do you know of any boats that he is the person 15 with the most control over? 16 A. Yes. 17 0. Okay. Where would those boats be located tini Is what lend of boat are we talking about? 19 A St. Thomas is the location. II would be a 20 34-foot Inflatable boat. I know that one specificaly. 21 Q. Okay. Do you know when he made that purchase^ 22 A Eight years ago, seven years ago. It was a 23 while ago. 24 Q. Is that smelting you had had input in" 25 A. Not on that one specifically, no. 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 122 testimony has been, you know, you're just the pilot for him -- it looks like there's some other rote that you're playing here in his life. I'm not suggesting that you aro or you are not. I'm Just saying from the appearance of this, it looks that way. Is there anything else that you want to tel me or that you want to clarify in terms of the role that you play in Jeffrey Epstein's life outside of being just his pilot? MR. REINHART: Let me object to form. He also told you he installs the audio and video equipment before. MR. EDWARDS: Co rrn.t. THE WITNESS: I have an interest in boats. You know, with the island, I don't Mirth I bought any boats, you know, for the company, but he appreciates my opinion on boat purchases. BY MR. EDWARDS: O. Okay. A. Having the knowledge of aviation and things that move quite fast. So I have consulted with him on boat items. Q. How many boat purchases are you aware of Jeffrey Epstein making In the time period that you've known him? A. Two or three. 124 Q. Is there any ether boat that you know of 2 Jeffrey Epstein being the primary user of or the primary 3 controller of? 4 A. I mean, there's boats in St. Thomas. I mean. 5 it's not pan of my job, you know, what goes on with tne 6 boats or who controlled them. It's more of an opinion 7 of what horsepower should bo on the back of the boat, 8 hull designs. It's out of my area. 9 Q. But your sole responsibility or your sole 10 obligation that you have ever had with Jeffrey Epstein 11 relative to boats is just giving some opinions about the 12 boat? 23 A. Mm-hmm. 14 Q. Is that yes? 15 A. Yes, yes. 16 Q. Okay. Al right. Has he ever gWen you his 17 opinions about boats? 18 A. Sure. We'vo discussed it back and forth. 19 Q. Other than boat conversations, have you ever 20 talked other conversations. such as 21 A. Cars. 22 0. Okay. How about such as -- have you ever 23 known Jeffrey Epstein to have a girlfriend, somebody you 24 consider a girlfriend? 25 A. No. ESQUIRE fl Ai 4444444 GWOCO.n.Y Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beads Gardens, FL 33410 vnvw.esquiresolutions.com EFTA01110357 Larry Visoski October 15, 2009 125 1 Q. In the 18 years and all the travels you had 2 with torn, do you know anything about Jeffrey Epstein's 3 sex life? 4 A. No. 5 Q. Do you know who he has Sex with? 6 A. No. 7 Q. Do you know if he has sex with anybody? 8 A. I don't know. 9 Q. Do you know If he's ever had sex on the 10 airplane while you've been piloting it? 11 A. I have no idea. 12 Q. That's something that you just wouldn't know 13 because you're up in the cockpit? 14 A. That is correct. 15 THE WETNESS: Could I take a two-minute 16 bathroom break just to lose my coffee? 17 MR. EDWARDS: Sure. 18 (A break was had at 1235 p.m.) 19 BY MR. EDWARDS: 20 0. All right. We're back on the record. Over 21 the years you've indicated that the any gifts or 22 other items or things given to you by Jeffrey Epstein 23 exclusively are the pool heater, the 40-acres of land 24 and the -- 25 A Use of a company -- 1 27 1 0. Did he ever fly anywhere else with you 2 by helicopter or airplane in the last two years? 3 A. We flew one time to the Sikorsky plant. 4 0. What's the Sikorsky plant? 5 A. That's where they build the Sikorsky 6 helicopters. It's in Palm Beath County. 7 Q. And when was that? 8 A. Probably a month ago. I'm guessing. 9 0. For what purpose? 10 A. They gave us a tour at a facility. 11 Q. Who's they? 12 A. Sikorsky. 13 Q. And who requested the tour of the facility? 14 A. They offered it to our flight department. 15 a And who went? 16 A. Jeffrey, myself, and Igor. 17 Q. And if I wanted documentation of either of 18 those trips, the trip to Miami or the trip to the 19 Sikorsky plant, who would have that documentation? 20 A. I would. 21 Q. So I could request it from your attorney to 22 get it from you? 23 MR. REINHART: Let me Just check. 24 (Off the record discussion.) 25 MR. REINHART: Okay. He has custody of it, either 126 Q. -- and the use of a company car? 2 A. Yes. 3 0. That's it? 4 A. (Nodding.) 5 Q. Okay. 6 A. Yes, sorry, yes. 7 0. And the flight to Miami that was recent 6 taken, other than Jeffrey Epstein and 9 was there anybody else on that night? 10 A No. 11 0. How long -- did you also fly them back from 12 Miami to Palm Beach? 13 A No. He drove back. 14 0. When you say "he drove back" who drove back? 15 A. Well, I assume he drove back I did not fly 16 him back. 1.7 Q. When's the next time you saw him again? la A_ I would only be guessing. A week later, I 19 mean. 20 Q. Okay. And was that in Palm Beach County when 21 you saw him the next lime/ 22 A. Yes, sir. 23 Q. Do you know of him leaving Palm Beach County 24 in the last two years on any other occasion? 25 A. No. 128 1 but they're corporate documents. So you'd have to 2 request it from Mr. Critton, who I understand 3 represents all the corporations. 4 THE WITNESS: Yes. BY MR. EDWARDS: 6 Q. What's the corporation that the document was 7 prepared for? A. Meaning who — what, lace Air Ghislaine, the 9 owner of the helicopter? Yes, Air GhlSlaine. 10 Q. Air Ghislaine? 11 A. That's the helicopter. 12 Q. And the name Ghislaine is obviously not that 13 typical of a name. Is that reference or related to 14 Ghistaine Maxwell? 15 A. I would assume. I have no knowledge. 16 Q. Nobody's ever told you that? 17 A. Nobodys brought it up. 18 Q. Okay. And how long were you at the Sikorsky 19 facility? 20 A. Three hours, four hours. 21 Q. And what time of day was this? 22 A. Nine in the morning. Nine, I think, and we 23 returned at one, something like that. 24 Q. And was the purpose to buy or purchase 25 anything? 0 ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Fl. 33410 www.esquiresolutlons.com EFTA01110358 Larry Visoski October 15, 2009 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 129 A. They have a new helicopter being developed there, so there trying to look for investors in it. So they were Just kind of pushing their product. O. Do you know what Jeffrey Epstein does for a living for business today, these days? A. No. Q. Do you know or have you ever been to the Florida Science Foundation? A. Yes, sir. 0. And do you know what the Florida Science Foundation does? A. Not exactly. Q. Well, generally? A. No, I don't. I mean, really, I don't 0. Okay. Is it your understanding that Jeffrey Epstein is somehow affiliated with the Florida Science Foundation? A. It's my understanckng that, yes. 0. I mean, did you just by happenstance stumble into the Florida Science Foundation, or was it related to your relationship with Jeffrey Epstein? A. rye heard that's where his office was. I mean, I have no other -- 0. Why did you go there? A. Talk about airplanes. 131 0. Back in his office? 2 A. Yes. sir. 3 0. What was that conversation? 4 A. Give me a time frame. I mean. I've been them 5 several times. 6 0. Okay. How many times do you think you've beer 7 to the Florida Science Foundation? A. Twenty, thirty. I mean... 9 Q. Well. the Florida Science Foundation's only 10 been around since late 2007; is that right? 11 MR. CRITTON: Form. 12 BY MR. EDWARDS: 13 0. Something around that? 14 A. I don't know exactly. 15 O. NI right. So In the last 2O years in the 16 last couple of years you've been there 20 or 30 times, 17 approximately? 18 A. Yee sir. 19 0. And during those tines when you've been there, 20 without having to go through each conversation, did you 21 ever talk to him about the fact that he was on probation 22 or that he was -- 23 A. No. 24 0. -• any part of the criminal investigation? 25 A. No, not at all. 130 0. Talk to who? 2 A. Jeffrey. 3 O. Jeffrey just happened to be at the Florida .1 Science Foundation? A. Yes. 0. How did you know that he was going to be at the Florida Science Foundation? 8 A. He called me and told me. 9 0. And he said come to the %Title Science 1 0 Foundation to talk to me about what? 11 A. Maintenance on the airplanes, upcoming. It's 12 an ongoing. 13 0. And did he have an office there? 14 A. Yes. 15 0. So this is when you walked in. this is the 16 place that's right next to Jack Goldberger's office? 17 MR. CRITTON: Form. 18 THE WITNESS: Yes. 19 BY MR. EDWARDS: 20 Q. And you walk in and there's a reception desk 21 right there? 22 A. Yes. 21 0. Is that where you talked or did you talk 24 somewhere behind that reception desk? 25 A. Behind the reception area. 1 2 1 4 6 7 9 10 11 12 1.3 14 15 16 17 18 19 20 21 22 23 24 25 132 0. What was the purpose of the conversation? A. We were sometimes talking about TVs, you know, the latest plasma that's out there, LCD, you know, setting up a stereo systems, you know, In the Palm Beach house. Thars usually the main thrust of our conversations these days. O. How woukl you know to go to the Florida Science Foundation on each of those occasions? Would he just cal you? A. Yeah, he would call me and say come on by or I got a brochure on a new Samsung. O. With each time you were at the Florida Science Foundation, how long would you stay typicaly? A. Ten, fifteen minutes. Not much more than mat. 0. You would go there for ten or fifteen minUteS, have a conversation about a n.f and leave? A. Yes, sir. 0. Why coukkrt you have that conversation over the ptione? What was it about? MR. CRITTON: Form. THE WITNESS: It it was pertaining to a TV and I'd have a brochure, a picture ol the TV one particular TV we looked at it was the size of a - like five foot diagonal, so 1 had a photo of myself ESQUIRE Ale•ndtiOilloGnipi9v Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beath Gardens, Fl. 33410 www.esquiresolutions.com EFTA01110359 Larry Visoski October 15, 2009 133 1 standing next to it or the salesperson. So I moan, 2 there's a reason to visually show him something 3 reference to that. 4 BY MR. EDWARDS: O. Did you ever communicate with Jeffrey 6 Epstein -- you can send him an e-mail, right? You could have done that? a A. Yes. 9 O. To send him the picture or something Ike 10 that, that was an option? 11 A. Right. 12 O. And what's Jeffrey Epstein's e-mail address 13 that you use? 14 A. I have to do it on my computer, you know, 15 with — I have to type in the prompts for it because 16 it's a long e-mail address. 17 O. Okay. How long have you e-mail corresponded 18 with Jeffrey Epstein? 19 A. Probably two years. A year to tyro years. I 20 mean, les fairly - something we just started doing. I 21 mean. we'd never done that in the past. 22 O. Wei, in the past he was In jail or have some 23 restrictions? 24 A. The restrictions, yes. 25 O. So you you'd see tem on the airplane 135 1 A. We've landed in Parts. 2 O. You're aware that he has some control over 3 another piece of property over there? 4 A. I know we've picked up luggage at a residence. 5 I don't know to what extent his ownership is, if any. 6 O. All right. A. Right. 8 O. And are you aware that he has some employees 9 that listen to what he says that work in that house? 10 MR. CRITTON: Form. 11 THE WITNESS: In Paris, yes, there is one 12 person there. 13 BY MR. EDWARDS: 14 O. What's his name? 15 A. Voltzan. Because I always thought there was 16 nobody there. 17 O. Vuttzan Cauldron (phonetic)? 18 A. I don't know exactly. I would have to look It 19 up. 20 O. Have you talked to him before? 21 A. No. 22 O. When you've been in Paris -- 23 A. You're not going to ask why? 24 O. Well, I'm assuming he doesn't speak English. 25 A. There you go. okay. 134 1 frequently? 2 A. Exactly. 3 O. So when you didn't see him on the airplane 4 frequently, then some of your correspondence was by 5 e-mail, other times by telephone? 6 A. Mm-hrnm. 7 O. And other times in person? A. Yes- 9 O. And what was your e-mail — what was the 10 substance of the e'mall correspondence that you would 11 have with Jeffrey Epstein? 12 A. It would have to be related. I mean, you have 13 to give me a topic. I mean, whether it be a car 14 O. Never about the criminal Investigation? 15 A. Oh, no, no, never. 16 O. Do you know what his intention is or his plans 17 are for when he is off probation? 18 A. No idea. 19 Q. Or off community control? 20 A. I have no Idea. 21 O. Has ho ever indicated to you he wants you to 22 fly him to some other location outside the United States 23 to live permanently? 24 A. Oh. no. 25 O. Have you ever flown to his place in Parts? 136 1 O. So I thought there was no need tor that? 2 A. Okay. I just wanted to see. 3 O. Where do you stay when Jeffrey Epstein Is in 4 Pans? 5 A. A hetet 6 Q. Okay. And in New Mexico, when you land there. 7 you stay on the ranch somewhere. but at your place? 8 A. I stay at my place. 9 O. And In New York, you have an apartment that he 10 sets you up at, right. the 301? 11 A. Yes. I have a oleos I could stay. 12 O. And In St. Thomas? 13 A. Hotel. 14 O. And in Paris you stay at a home? 15 A. (Nodding.) 16 O. Are there any other properties such as what we 17 were talking about today — I'm not saying Jeffrey 18 Epstein Is the sole owner or direct owner, but any other 19 properties that you're familiar with that Jeffrey 20 Epstein is - has direct a ss to and at least it gives 21 the appearance to you that he is the owner or controller 22 of that property? 23 MR. CRITTON: Form. 24 THE WITNESS: Name the list that you've 25 stated. ESQUIRE •• Mcm.4c, & C•14•; Toll free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Ft. 33410 www.esquiresolutIons.com EFTA01110360 Larry Visoski October 15, 2009 137 1 BY MR. EDWARDS: 2 O. The Manhattan house. 3 A. Yes. 4 0. Mansion or whatever we want to call it, the 5 Zorro Ranch, the island of St. James. the Palm Beach 6 house. 7 A. Mm-hinm. 8 O. And the Paris place. 9 A. There all I'm SWAM of. 10 O. And have you ever at any of those five places 11 hung around him and stayed around him for -- during the 12 daytime for the course of an entire day? 13 A. No. 14 O. Afl right. So do you know what he does during 15 his days while he's there? 16 A. No. 17 O. Are you aware of a list of underage guts that 18 is kept to come over and service him each of those days? 19 MR. CRITTON: Form. 20 THE WITNESS: Absolutely not. 21 BY MR. EDWARDS: 22 0. I'm the fast person to ever even imply that 23 to you, right? 24 A. A list, yes, you are. 25 0. Okay. Have you ever been made aware that 1 2 1 4 5 a 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 139 BY MR. EDWARDS: Q. And ask you about some of the allegations in here and see if you know anything about them. It indicates he owns a flight of aircraft that includes a Guffstream, a helicopter, and a Boeing 727. True? MR. CRITTON: What's the question? THE WITNESS: Please repeat. BY MR. EDWARDS: O. Are you aware of him owning a Gulfstream IV aircraft, a helicopter and a Boeing 727? I think we talked about it, right? A. Right. 0. Okay. And it indicates a fleet of motor vehicles? MR. CRITTON: Wait a minute. He said right, is that we talked about it, as distinct from him knowing one way or another. THE WITNESS: What's the question? BY MR. EDWARDS: 0. Do you know that he owns those things? A. I do not know that he owns them. O. Do you believe that he owns those things? MR. CRITTON, Form. THE WITNESS: I would be guessing, so. 138 keeps a list of underage girls to service 2 Jeffrey Epstein for sexual purposes? 3 A. I am not aware of them. MR. CRITTON: Form to the last question. 5 BY MR. EDWARDS: Q. Have you ever been made aware that Ghistaine Maxwell keeps a list of girls in the nearby areas of 8 each of -- at Jeffrey Epstein's residences to service 9 him sexually? xo A. No. 11 MR. CRITTON: Form. 12 BY MR. EDWARDS: 13 0. Okay. Have you ever read some of the 14 complaints that have been filed against him in the 15 various courts, whether state court or federal court. 16 against Jeffrey Epstein? 17 A. No, I have not. 28 0. All right. So this Jane Doo 102 versus 19 Jeffrey Epstein. you're not familiar with who that 20 person Is? 21 A. No idea. 22 O. Okay. I'm going to mark Jane Doe, one of the 23 22, versus Epstein as Exhibit No. 4 to this deposition. 24 (Plaintiffs Exhibit No. 4 was marked for 25 identification.) 140 1 BY MR. EDWARDS: 2 Q. What does the company NES. LLC, do to your 3 knowledge? 4 A. I have no idea. 5 O. How does that company generate profit. if you 6 know? 7 A. I have no Idea. O. Thars the company that pays your paycheck. 9 but you have absolutely no clue what they do to generate 2o money? 11 A. No, sir. 12 0. If anything? 13 A. Correct. 14 O. Have you ever heard that that company 15 generates money through sex trafficking of young girt 16 MR. CROTON: Form. 17 THE WITNESS: Absolutely not. 18 BY MR. EDWARDS: 19 O. Never, okay. Have you ever heard that Jeffrey 20 Epstein has a sexual preference for underage grls? 21 Other than what you've read in the newspaper, have you 22 heard that from any other individuals before? 23 A. No. 24 0. Ever heard that he has had sex or sexual 25 relationships with many minor gals, some as young as 12 ESQUIRE as Almada Gala Ciapiny Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutions.00m EFTA01110361 Larry Visoski October 15, 2009 143. 1 years old? 2 MR. CRITTON: Form. 3 THE WITNESS: No. 4 BY MR. EDWARDS: 5 Q. Never? 6 A. Never. 7 0. Have you ever seen any photographs in any of 8 his homes depicting young-I0Cking girls engaging in sex 9 acts? 10 A. No. 11 0. Or reading directly from the complaint, 12 •engaged in lewd acts"? 13 A. No, absolutely not. 14 0. Have you looked around the walls of his 15 various homes when you're In there picking up luggage? 16 A. I mean, not arty more than I walked in here and 17 not looking at the waits over there, I couldn't tell you Is what those are: so nothing specific. 19 0. Sometimes we're talking about a 50,000 square 20 loot house? 21 A. Exactly. 22 0. In Manhattan? 23 A. It's pretty dg. 24 0. Okay. Have you ever looked at any of his 25 computers for any reason? 143 I about that? 2 MR. REINHART: Hold on. The question is have 3 you ever been told that fad that he just read to 4 YOU? 5 BY MR. EDWARDS: 6 0. RIgN. 7 A. I have never been told that fact. a 0. Has anybody ever questioned you about your 9 possible involvement with helping to facilitate 10 Mr. Epstein have sex with underage girls? 11 A. No. 12 0. When you were questioned by either the police 13 or the -- whoever the investigative resource that was 14 being used at the time? 15 A. Right. 16 0. Do you remember who that person was that was 17 questioning you? 18 A. No, I don't remember. 19 Q. I know you don't know the location where it 20 was, but do you remember who they were affiliated with? 21 A. No. 22 0. Was it only one tkne? 2.3 A. Yes. 24 0. Did you also have to testify before a grand 25 jury proceeding? 142 A. No. O. I know that you helped set up some of the -- A. Computers are not my expertise. Q. All right. Have you ever boon told that Mt Epstein committed sex acts against underage girls on a literal deity basis, that's what he does? 7 A. rye never been told that. 8 Q. Have you ever read the complaints against hirn 9 that Indicate that's what he does on a daily basis? 10 MR. CRITTON: Form. 11 THE WITNESS: No. 12 BY MR. EDWARDS: 13 0. So in your mind, you never believed that you 14 were transporting around somebody whose sole goal Et 15 He is to get -- have sex with time girls? 16 MR. CRRTON: Form. 17 THE WITNESS: I never believed that, no. 18 BY MR. EDWARDS: 19 Q. Okay. Have you ever been told that he 20 conspired with others, including assistants andtor his 21 drivels andMi pilots and his friend Ohislaine Maxwell, 22 to further these sex acts and to avoid police detection? 23 MR. CRITTON: Form. 24 BY MR. EDWARDS: 25 0. Have you ever — anybody ever questioned you 144 1 A. No, I did not. 2 0. Have you ever known Mr. Epstein to got a 3 massage whde on an airplane? 4 PHONE ATTORNEY: This is everybody in Boone, 5 Charles and the witness is here and the court 6 reporter and the videographer. 7 MR. EDWARDS: Fantastic, but I think that you may have the wrong room. PHONE ATTORNEY: I was told to ask for 856. 10 MR. EDWARDS: Let's go off the record. 11 (Off the record discussion.) 12 BY MR. EDWARDS: 13 0. All right. In the complaint. I'm going to 14 tell you what it aleges and rm gong to ask if this 15 helps to refresh your recollection about any of Jeffrey 16 Epstein's activities. The defendant. Jeffrey Epstein, 17 transported the plaintiff to another state in order to 10 engage in sex acts with her. And this occurred when sno 19 was merely 15 years old. 20 Do you remember transporting somebody that 21 looked like they were 15 years old on your airplane? 22 A. No, sir. 23 0. You never remember taking a 15-year-old, or 24 somebody that looks around that approximate age, on you- 25 airplane? ESQUIRE ea A It taadel 6.11. Coo#40/ Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110362 Larry Visoski October 15, 2009 10 11 12 13 14 15 16 12 16 19 2o 21 22 2s 25 145 A. Can you be more specific? Q. Wel, I know that you've Indicated earlier in the deposition that you remember some gins under the age of 18 on the airplane. And so let me aSk. before I get back into this. whether al those indMduais you were talking about wore accompanied by a parent or some of those people were on the airplane for some other purpose, modeling, or you don't know wtly they were there? I'm going to let you elaborate on who thee* people are that you beams may have been wider the age of 18 and why you think they were on the airplane? MR. CRITTON: Form_ THE WITNESS: We've had younger people on the airplane that have been, you know, with their family members, like you said. I dont remember transporting anybody that was of questionable age. I'm not rd orty be guessing at sornebodys age if l didn't ID them at the foot of the airplane. So I can't guess to their age. BY MR. EDWARDS: Q. All tight. 'Mr. Epstein used his private jet 10 transport the male( plainllIto Manhattan where he provided her spending money and aCeOrnrnodations with AIM at his mansion.' Co you have any idea who that might be 3.47 1 O. To Santa Fe? 2 A. Yes. 3 O. To Los Angeles? 4 A. Yes. 5 O. To San Francisco? 6 A. Yes. 7 O. To St. Louis? a A. Yes. 9 Q. An right. Continuing to IMemational 10 destinations, including Europe, have you ever flown it 11 to Europe? 12 A. Yes. 13 Q. The Caribbean? 14 A. Yes. 15 O. And Atka? 16 A. Yes. 17 O. On those Nights to those various places, is 18 k your — to the best of your knowledge. you were 19 unaware of Jeffrey Epstein engaging in sex with underage 20 girls on his airplane? 21 MR. CRI170N: Form. 22 THE WITNESS: I have no knowledge of any of 23 that. 24 BY MR. EDWARDS: 25 O. 'He provided accommodations with him 3.46 1 referring to? 2 MR. CRITTON: Form. 3 THE WITNESS: No, sir. 4 BY MR. EDWARDS: 5 Q. And you dont remember being a pilot of an 6 airplane where he was transporting a 15-year-old to 7 Manhattan from Miami or Palm Beach? A. No. I'd be guessing at somebody's age and I 9 can't guess. 10 O. 'Defendant transported plaintiff in his 11 private jet to locations that included Palm Beach, New 12 York City, Santa Fe, Los Angeles, San Francisco, 13 St. Louis.' 14 Do you remember ever piloting his airplane to 15 those destinations that I just mentioned? 16 MR. REINHAFtT: Can we break them down? 17 ObjectIon: compound. IS MR. EDWARDS: Okay. 19 BY MR. EDWARDS: 20 Q. Have you ever flown his airplane to Palm 21 Beach? 22 A. Yes, sir. 23 O. Okay. Have you ever flown It to New York 24 ay? 25 A. Yes. 148 I order 1 to have her available to him at all times whenever he 2 wanted, including while transporting the minor plaintiff 3 on his private }et .° 4 ?bars someiting that you had no knowledge of? 5 A. (Witness shakes head.) 6 O. You have to a yes or no. A. I'm sorry, no. Q. 'Each time they would travel to one of these 9 destinations, the same pattern of sexual abuse would 10 occur, often with a vast array of aspiring models, 11 actresses, celebrities, and/or other females, including 12 minors from all over the world.' 13 Again, that's something you have no persona, 14 knowledge of? 15 A. No. 16 O. Has anybody ever indicated that it you did 17 have personal knowledge of some of these things, then 19 you could also have been implicated in some form of a 19 aims? Has any law enforcement or anybody ever 20 indicated that to you? 21 A. No. 22 O. Okay. Is that something you've ever worried 23 about? 24 A. NO. 25 Q. All right. 'Upon information and belief, ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esguiresolutIons.com EFTA01110363 Larry Visoski October 15, 2009 149 I defendant transported minor gins from Turkey.- Did you 2 ever leave in one of his airplanes out of Turkey? A. I'd have to look at the records. I don't recall Turkey. Q. Do you ever remember taking any minor girls e out of Turkey? 7 A. No. I don't remember. 8 Q. What records would you have to look at to see 9 N you took people out or left out of Turkey? 10 A. I'd have to took at the flight logs, but I 11 personally don't remember flying into Turkey. 12 O. And would the flight loge coming into the 13 United States from Turkey indicate the names of the 14 people on the plane? 15 A. They might 16 O. Okay. Where would I get those particular 17 ffight logs that would have that 18 A. Depended upon what year you're taking. 19 0. We're talking in this particular complaint 20 between 1998 and 2002. 21 A. I'm not -- I don't possess those passenger 22 manifests. 23 O. Do you know who would possess those? 24 A. That would be I guess .- 25 MR. REINHART: Do you know who has them today? 151 1 ever flown to or from in a Jeffrey Epstein airplane? 2 A. We have flown to Prague. 3 O. Okay. Have you picked people up in Prague and 4 flown out of Prague? 5 A. I don't remember. 6 0. I'm not saying no. you didn't, but 7 A. Best of my knowledge. 0. you don't remember? 9 A. Exactly. Best of my knowledge, I don't 10 remember. 11 Q. Do you remember the reason for going to Turku) 12 or to Prague? 13 A. No. 14 D. This also says Asia. Have you ever flown 15 or from Asia with Jeffrey Epstein? 16 A. Yes. 17 0. Or on a Jaffrey Epstein airplane? 38 A. Yes. 19 a Do you know the purpose of those flights to 20 and from Asia? 21 A. No. 22 O. Did it ever occur to you that maybe H was to 23 pick up minor Os for him to have sex with on the back 24 of the airplane? 25 MR. CRITTON: Form. 150 THE WITNESS: I do not know who has them today. 3 BY MR. EDWARDS: 0. Who did you give thorn to? A. Actually, I didn't give them to anybody. Dave Rogers was in possession of those logs. So I don't know 7 where they are right now. 8 0. You're still thinking that the best evidence 9 of that, any flight that may have left out of Turkey, 10 would be in the flight logs that's marked as Composite 11 Exhibit 1, or are we talking about the manifests that 12 we've been referring to? 13 A. I don't know how accurate that log book is or 14 even how accurate the passenger manifest is. 15 0. Okay. So there may be no actual documentation 16 indicating a flight leaving out of Turkey when. in fact• 17 a flight may have left out of Turkey? 1e A. Correct. 19 Q. Okay. The Czech Republic is the next place 20 listed. Is that a place you've flown to or nom in a 21 Jeffrey Epstein airplane? 22 A. More specific, could you name the city? 23 0. I Can't name the city, al least the complaint 24 doesn't name the city. But I've been to the Czech 25 Republic before. Anywhere within that country, have you 152 1 THE WITNESS Never occurred to me. 2 BY MR. EDWARDS: 3 0. Did you ever hear that he maintained some of 4 these underage girls as Sox slaves -- 5 A. Never heard of such a thing. 6 0. -- from the age of 12 through the age of 16? 7 MR. CRITTON: Form. 8 THE WITNESS: No knowledge of that. 9 BY MR. EDWARDS: 10 0. Ever picked up cps that looked young, many 11 of whom who spoke no English? Do you ever remember 12 that? 13 A. Zero. do not. 14 0. All right. The complaint goes on to say, is 'Ptarnillf was required to be sexually exploited by 16 defendant's adult male peers. including royalty.° St 17 rm going to talk, do you have any familiarity with 18 Prince Andrew? 19 A. I know who he is. O. Was he ever on the airplane? 71 A. He may have boon on the airplane. 22 Q. Do you remember him on the airplane with young 23 girls? 24 A. No.1 do not. 25 0. Do you remember Jeffrey Epstein flying in tc. ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutions.com EFTA01110364 Larry Visoski October 15, 2009 153 meet with Prince Andrew? A. I dent remember. I know that happened, but I couldn't be accurate. 0. Has Prince Andrew ever been on the airplane at the same bore as a young girl, to the best of your memory and knowledge? A. To the best of my knowledge. no. 0. This also says politicians. taking about 9 local or U.S. politicians. Do you remember certain le politicians being on the airplane? 11 A. No — I mean yes, I do. 12 0. What politicians would that be? 13 A. President Clinton. 14 0. Okay. Who else? 15 A. Former president of Israel help me out with 16 the name. Barak? 27 Q. Ehud Barak? 28 A. Yes, those are the two that I remember. 19 Q. How many times was Ehud Barak on the airplane 20 that you piloted for Mr. Epstein? 21 A. Maybe once. 22 Q. And where did that flight pick up arid where 23 did it go to. to the best of your memory? 24 A. Best of my memory, it was Palm Beach to 25 Teterboro. 1 2 3 4 5 6 7 a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 155 BY MR. EDWARDS: 0. Okay. Do you remember who else was on that flight that left after 10 p.m.? A. No. I do not. Q. Do you remember why it left after 10 p.m.? A. No, I do not. Q. Do you remember Jeffrey Epstein instructing you to wait until after 10 p.m. to leave? A. No. Q. Would you have listened to him if he had told you -- if he had instructed you to do that? A. I don't understand the question. 0. Well, it he told you wait until after 10 p.m.. I realize there's going to be a fine, but wait until after 10 p.m. to leave, intentionally leaving after 10 p.m., do you remember that instruction ever -- A. No, I donl remember that Instruction. 0. Okay. A. I mean, it just happened to be departing after 10 and there is a penalty for leaving after 10 for noise. So there was no intention to... 0. Al right. This also talks about this particular person 15 years old being sexually exploited by businessmen and/or other professional or personal acquaintances. Are you aware of other personal or 154 Q. Where is Teterboro? A. In New Jersey. Q. And what was the purpose of that flight, do 4 you know? A. I don't know. 0. Was Jeffrey Epstein on the flight? A. I'd have to look at the flight logs to guarantee. 9 Q. Anything about that flight stick out In your 10 mind? 11 A. None. 12 0. Such as a fine needing to be paid because It 13 left after 10:00 p.m.? 14 A. For that was the fight, yes. 15 Q. You remember that? 16 A. les coming back to me. 17 0. And do you remember young girls being on that 18 flight? 19 A. No. 20 Q. AA right. 21 A. I remember the tine. 22 Q. Do you remember who paid the fine? 23 MR. CRITTON: Hold on. Let me object to tan 24 of the question. To you remember it suggests 25 that there were. So form, predicate. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 156 professional acquaintances of Jeffrey Epstein also sexually abusing or exploiting little kids or underage girls on your airplane? MR. CRITTON: Form. THE WITNESS: No. BY MR. EDWARDS: 0. If you had been aware that Mr. Epstein was -- and by this -- this is more in the form of a hypothetical, and that I'm not going to suggest to you ire a fact that he was. But if you had been aware that every single day Jeffrey Epstein's goal was to locate underage girls for the purposes of sex, and enter have sex with them on the airplane or at some other designation that you were destination that you were traveling him to, would you have continued to pilot those planes? MR. CRITTON: Form. THE WITNESS: You said It was hypothetical? BY MR. EDWARDS: 0. Right, It is a hypothetical. A. Why would I want to answer that? Because you're being hypothetical. I mean, it would obviously be wrong. Q. Sure. Well, a hypothetical question is a legal question that I'm allowed to ask. ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 binvw.esquiresolutions.com EFTA01110365 Larry Visoski October 15, 2009 157 1 A. Okay. 2 O. And I'm just asking you if you did have 3 knowledge that Jeffrey Epstein was having sex with 4 little girls either on the plane or at a place that you 5 were taking him to or from on a daily basis, that's what 6 he did, would you have continued to be his pilot? MR. CRITTON: Let me object. Object to the a form. Its argumentative. It has no more value 9 than assuming ho was chopping up bodies or anybody to was chopping up bodies in the plane you're flying. 11 What difference does il make? Form. 12 MR. EDWARDS: What difference does it make in 13 a case about him having sex with little girls? I'm 14 not going to argue with you about it. You've 15 stated your objection. 16 MR. CRITTON: Exactly. tt's an argumentative 17 question. 18 MR. EDWARDS: I'm not going to argue with you 19 about IL 20 MR. CRITTON: You're arguing with him about 21 now. 22 MR. EDWARDS: No. I'm asking him the 23 hypothetical. 24 BY MR. EDWARDS: 25 Q. Can you answer that? Would you have continued 159 1 THE WITNESS: Never heard of such a thing. 2 BY MR. EDWARDS: 3 Q. Do you know of any friends that he has in 4 France that would send him birthday -- a birthday 5 present? 6 A. No. 7 0. Do you know of him receiving any birthday 8 gifts or birthday people from anyone? 9 A. Never. 10 0. This particular person that filed this 11 complaint, Jane Doe 102, indicates 'Defendant and 12 Ghislaine Maxwell acknowledged and celebrated 13 plaintNf's 16th birthday." 14 Do you remember them celebrating somebody who Is you flew on the airplane's 16th birthday? 16 A. I don't recall. 17 0. Any of this jog your memory as to who 18 is? 19 A. No. 20 0. "From the age of 15, plaintiff' -- this Jane 21 Doe 102 —'was sexually exploited and abused by 22 defendant on a daily basis and often multiple times each 23 day.' 24 So going back, was there ever a day where you 25 were with Jeffrey Epstein where you could observe him 158 1 to be a pilot for somebody who's traveling to and Irom 2 destinations with the goal of having sex with underage 3 girls? 4 MR. CRITTON: Form. 5 THE WITNESS: It could be any person. It 6 doesn't have to be Jeffrey Epstein, then, right? 7 BY MR. EDWARDS: 8 0. True. 9 A. No, I wouldn't pilot an airplane If there was 10 wrongdoing going on. 11 0. That you knew about? 12 A. That I knew you about, sure. 13 0. Me reading this complaint to you, is this the 14 first time you've heard these allegations — 15 A. Yes. 16 Q. — against Mr. Epstein? 17 A. Yes. 18 0. It goes on to say, 'On one of Epsteln's 19 birthdays, a friend of Epstein sent him three 20 12-year-old girls from France who spoke no English for 21 the purpose of -- for defendant to sexually exploit and 22 abuse. After doing so, they were sent back to France 23 the next day.' 24 Are you familiar with that occasion? 25 MR. CRITTON: Form. 160 1 and during an entire day? 2 MR. CRITTON: Form. 3 THE WITNESS: I don't remember 4 IMS so I couldn't answer the question. 5 BY MR. EDWARDS: 6 0. "In September 2002, Defendant Epstein purchased a commercial round-trip airline ticket and s provided a passport, U.S. currency and accommodations 9 for plaintiff to fly to Thailand.' 10 Do you remember him doing that for anybody 11 around that time period? 12 A. No, sir. 13 MR. CRITTON: What was the date? 14 MR. EDWARDS: September 2002. Is MR. CRITTON: Okay, thanks. 16 MR. EDWARDS: I have here and this is 17 actually my only copy, so I don't mind marking it 18 as a composite exhibit, but well either have to 19 copy this while thing or well have an agreement of 20 counsel. It's the visitor ElMale log from when 21 Mr. Epstein was in jail in Palm Beach. 22 MR. CRITTON: Well, before we get started, it 23 IS now 1:15. We started al 10:00. 24 MR. EDWARDS: We didn't really start at 10:0D 25 MR. CRITTON: Shortly thereafter. I was hem ESQUIRE nAhrndn4dOl..”DY Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esqulresdutlons.com EFTA01110366 Larry Visoski October 15, 2009 161 1 pretty much after 10. But we've been hero since 2 10:00. I want to take a lunch break. 3 MR. EDWARDS: Let's do It. 4 MR. CRITTON: For an hour? s MR. EDWARDS: Sure. 6 (A break was had at 1:15p.m.) BY MR. EDWARDS: O. Ail fight. I looked through the inmate log of 9 the visitors who visited Jeffrey Epstein and your name 10 appears one, two, three. tour, five, six, seven, eight 11 times. 12 A. Okay. 13 O. Seem to be accurate in terms of how many times 14 you wen! to visit him? 15 A. I thought six, but yes, theta.. 16 O. I'll let you review the records and tell me if 17 you dispute any of that record. And I'll go ahead and 18 mark that as Composite Exhibit 5. 19 (Plaintiffs Exhbit No. 5 was marked for 20 Identification.) 21 MR. REINHART: It's two pages. 22 MR. EDWARDS: Two pages. 23 MR. REINHART: Okay. 24 BY MR. EDWARDS: 25 O. Seen accurate? 163 1 just talked about general happenings that go on in 2 there. 3 O. What did he say? 4 A. It's terrible: it's cold: he can't sleep. 5 They wake him up every two hours. You know, just items 6 like that, uncomfortable things. We talked about the 7 airplanes a great deal. You know, we got major 8 maintenance on the big airplane, so we discussed that a 9 little bit. And then it was realty just how 10 uncomfortable he was there. 11 O. How long did you visit with him on that first 12 visit, July 3rd? 13 A. I think we stayed the full hour. 14 O. All right. Is that what the time allotment 15 was? 16 A. I believe it is, yeah. 1 don't think you 17 could leave earty, or rm not aware that you could lea've 18 early, until later on we found out you could stay for 19 five minutes or longer. But I don't think any of us 20 knew that was - once you got in there, you stayed there 21 for the hour. 22 O. Okay. So you talked to him for an hour and 23 for the most part it was just about the conditions and 24 his disappointment with the conditions? 25 A. Sure, yeah, absolutely. 162 1 A. Yes. 2 O. Okay. Jeffrey Epstein's plea. I believe, was 3 June 30th, 2008. I Mink that's when he was taken in 4 custody from them. Your first visit Is July 3rd, 2008. 5 And the other name on that visit is Igor Zinoviev. Did 6 you go with Igor to visit Jeffrey Epstein? 7 A. Yes. 8 O. Why did you go with Igor? 9 A. It just happened he wanted to see us both at 10 the same time. There was no apparent reason. 11 O. How did you know that Jeffrey wanted to see 12 you? 13 A. I don't recall who called and told me that he 14 wanted to see me. I couldn't give you an accurate name, 15 whether II was, you know, his attorney, Darren. And 16 actually, I would put a lot weight to I think it was 17 Darren. his attorney. 18 O. That would have made a phone cal to you that 19 said - 20 A. Yeah, to go. 21 O. And what rid you talk about with Jeffrey 22 Epstein four days after he pled guilty to offenses that 23 landed him n jai? 24 A. I think the first visit was how (*appointed 25 or how scared he was, you know, being inside there. we 164 2 O. And did Igor talk to him as welt? 2 A. Briefly. I mean, not that much. You're going 3 back a tittle ways again to remember exactly what was 4 discussed. You know, he asked how his family was doing. 5 I guess Igor& got a son. I think he asked how his son 6 was doing. You know, just general questions like that O. Did you Ode to the jail that day with Igor? 8 A. I believe we did. I believe I met Igor 9 probably at Jeffreys house and picked him up, or if 10 not, we may have met at the airport and drove together. 11 But we did drive together on that occasion. 12 O. In what vehicle dId you dnve? 13 A. The Hummer. 14 Q. That's the vehicle you described earlier as 15 the company vehicle? 16 A. Yes, sir. 17 O. Is that a vehicle paid for by Jeffrey Epstein? is A. Meaning? 19 a Wet is that a vehicle pail for by you? 20 A. What do you mean 'paid for"? 21 O. Did you purchase the vehicle with your money? 22 A. I didn't purchase that one, no. 23 O. Do you know II it was purchased by Jeffrey 24 Epstein or a corporation of Jeffrey Epstein's? 25 A. Probabty a corporation. ESQUIRE AlenaJoi .U. tr pan) Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Ft. 33410 www.esquiresdutlons.com EFTA01110367 Larry Visoski October 15, 2009 165 MR. CRITTON: Form; move to share. Sounds 2 like a guess. 3 BY MR. EDWARDS: 4 0. To the best of your knowledge, that's how most 5 of the items that you've discussed -- that being the 6 Seeing and the Oullstream -- they were usually held In 7 corporate names, to your knowledge? a A. To my knowledge, exactly, yes. 9 0. And so when you're saying the -- when you're 10 talking about the Hummer vehicle and you're stating that 13 its likely a corporate entity, is that just something 12 that you're guessing about, or do you have knowledge? 13 A. No, I'm just guessing. 14 0. Okay. 15 A. I have no proof 36 0. -• Olownership of who as registered to or 17 anything like that? 18 A. Exactly. 19 Q. IS it registered to you? 20 A. No. no. 21 0. So it's registered to somebody other than you? 22 A. Exactly. 23 0. Okay. 24 A. I just drive It, I guess. 25 0. Okay. So on July 5th, 2008, you go back to 1 2 3 4 5 6 7 8 9 10 11 22 13 14 25 16 17 18 19 20 21 22 23 24 25 167 facility that was holding Jeffrey Epstein, they're accurate, your name is the first one listed on the top of the sheer A. Right. There may have been earlier dates. I have no idea. 0. Well, you know, the first date that he could have been in there it looks like was 7/1/08 and then, you know, so I guess somebody could have seen him 7/1 or 7/2, but those records were never provided to us. You see we were provided a whole big stack. A. I understand. O. The next date rm going to talk to you about is 7/12008. A. Uh-huh. 0. It looks, again. Ito it's yourself and Igor Zmoviev? A. Mmhmm. 0. And that's something we talked about in this deposition. I'm going b ask you again. I don't know that you elaborated last time, what le your understanding of his relationship with Jeffrey Epstein", Is that a Mend of his? A. I don't know Ms lob Oescrotion. I mean. he's somebody that's around a lot. but i don't know his exact gob description. His English is, to say, not 166 I see him In jail again, and again. Igor Zinoviev is 2 listed as a visitor. Did you go with him together on I that occasion? A. I didn't even realize it was two days after E.. the first visit. 6 Q. Well, I mean, you see where this is going? A. Yeah, I do. It gets further apart, yeah. O. Do you remember what the discussion was on 9 7/5/08? 10 A. No, because it's probably similar to the first 11 one. I mean, we talked — actually, one of the visits 12 we talked about fishing and just hying to — you know, 13 we were talking about things that would just occupy his 14 mind with intelligent conversation that he probably 15 wasn't getting there. So for that hour of the day, I 16 tried to give my best of intelligent conversation to 17 him. 18 0. Okay. On his visitor log you were the first 19 one to go visit him. Did you know that? 20 A. I did not know that. I wasn't aware of that. 21 MR. CRITTON: Let me just object to form to 22 the last question. 23 BY MR. EDWARDS: 24 Q. Weil, at least if these records are accurate, 25 which are the records that were provided to us by the 168 1 100 percent, so conversation with somebody that doesn't 2 fully understand you, you know, you get lost in 3 translation a little bit. So I don't -- 4 0. So on these three visits to the jail, the s first three that we're talking about that we've talked 6 about so far. each of those times you traveled to arc 7 from the jail with Igor? 8 A. Mm-hmm. 9 Q. Yes? 10 A. Yes, yes. 11 0. And each of those time, is it fair to say you 12 had some kxm d communication either on the way to the 13 jail or — 14 A. Sure. 15 0. to the jail? 16 A. Yeah. 17 0. Since you're going to see an inmate in the 18 jail, is it a safe assumption a portion of that 19 conversation was about the person that you're going to 20 see and possibly the crime that was committed? 21 A. Yes, that would be a good assumption. 22 0. Okay. And what was the form what was the 23 substance of that conversation that you can remember 24 related to Jeffrey Epstein and the location you were 25 going to visit him? ESQUIRE • • A Feta240 (.110 CO.HOY Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110368 Larry Visoski October 15, 2009 169 A. I think Igor and I discussed on trying to be 2 upbeat and not look at the position that he's in sitting across the table from us, to be upbeat and uplift his spirits. Q. Did you and Igor discuss whether or not you 6 were going to talk to him about his plea of guilty a 7 the fact that he's not registered as a sex offender? 6 A. No. 9 0. Or whether you were going to stay away from 10 those topics? 11 MR. CRITTON: Form. 12 THE WITNESS: We never we don't discuss 13 that amongst ourselves and/or with Jeffrey in any 14 way, loan. 15 BY MR. EDWARDS: 16 0. Okay. But that's not — I realize you didn't 17 discuss that. You've told me that. 18 A. Right, but we didn't discuss that oven prior 19 to going in, as you asked. 20 0. Okay. So your discussion was mainly hey, 21 let's be upbeat? 22 A. Yes. 23 0. And that was to, in essence, maintain his 24 spirits or raise his spirits? 25 A. Exactly. 171 1 a And in the course of that conversance. again. 2 the allegations and the unusual call it case 3 against him. that didn't come up between you and 4 Mt Epstein' A. I never talked about it with him. 4 O. And at that point In time, what were you aware 7 of in terms of the number of girls that he was alleged 8 to have had sexual some sort of sexual retanorehe , with him at his Palm Beach house? 10 A. What was the question? How many girls? 11 O. Yeah, how many girls were you — 12 A. Aware of? 13 0. -- aware of? 14 A. None. I wasn't aware of any, to be honest. 15 O. The next eat is on 7/17/08 and Ws Igor 16 Znoviev and somebody named Jean Rene and then yourself. 17 Do you know who Jean Rene Is? 18 A. No. 19 0. Do you think that that visit. that you visited 20 hkn at the same time that Jean Rene visited? 21 MR. CARTON: What's the date? 22 MR. EDWARDS: It's 7/17108. 23 THE WITNESS: No. I don't know a Joan Rene, 24 unless somebody came after. I mean, I don't -- I 25 don't know a Jean Rene. 170 1 0. Okay. And you were doing that as a friend of 2 his, not just his pilot, right? A. I felt honored that he asked me to come and 4 give support like that. because prior to him going away, it was known to us that there was going to be no 6 visitors, because I had offered to him that I would be 7 happy to come and visit him if he deemed It necessary, 8 and he says no. I'm not going to have anybody. 9 O. So 1 0 A. I guess it was so bad there, that he may have 11 changed his mind and wanted to have some visitors. 12 Q. When did you have this conversation with him 13 where he indicated he was not going to have visitors 14 while he was in jail? 15 A. I don't exactly remember. It may have been on 16 the trip heading to Palm Beach, the last flight. 17 Q. From his island, from St. Thomas I guess It 18 would be from? 19 A. 'forgot where it started from. It might have 20 been New York or the island, one of the two. I don't 21 remember the last flight. 22 O. And I mean, old at least the fact come up that 23 hey, this a glamors who you're — Is going to be in hill 24 for some time? 25 A Mm-timm, yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 34 25 172 BY MR. EDWARDS: O. Okay. And then before you visited him again, the visitors are listed as or IOW A. Mm-hmm. 0. Manly those two individuals. And they list as addresses, as their residence? A. Uh-huh. 0. Given your previous testimony, does that surprise you that they list those that address as their residence? MR. CRITTON: Form. THE WITNESS: I've seen them there, so I mean. I'm not surprised. BY MR. EDWARDS: 0. Okay. Did you know that they were visiting Nth In jail? A. No, I di&'t know who was scheduled to see him or whatever. 0. Did Jeffrey talk to you at any point in time about A. No. not at all. MR. REINHART: Can we get a time frame for that? Ever? MR. EDWARDS: Oh, no, well, I was talking - ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110369 Larry Visoski October 15, 2009 273 1 I'm sorry. 2 BY MR. EDWARDS: 3 O. I was taking right now about in the 4 conversations that you had with him that we've discussed 5 with you and him in the jail faC' . Did he discuss 6 with yeti or 7 A. No. no. 8 0. Did he talk to you about whether or not you 9 should talk to anybody about his criminal investigatkit 10 or possible litigation? 11 A. No, not at aft 12 O. The next time you see him b on August 8th, 13 2008, at the jail. In that occasion It mentions as his 14 visitors that day and 35 Larry %/Gosh'. Did you go to the jail with and 16 IM that time? 17 A. No. Who was on there? Which one are you 18 referring to? 19 O. The next one, I tried to highhght them just 20 so that — 21 A. Right, that one. 22 MR. REINHART: 8/9. 23 BY MR. EDWARDS: 24 0. 8/9i08? 25 A. One of those two we all drove together. I 176 1 at the house. 2 O. Those are cars that Jeffrey Epstein owns, to 3 your knowledge? 4 A. I don't know who owns them. 5 O. What cars are there that -- I know with this 6 case we're dealing with a lot of corporations and Its 7 not like asking me, Hey, what car do you own? But what 8 cars are you aware that are -- that you believe are used 9 prImanly by Jeffrey Ereteln? 10 A. Used primarily by Jeffrey Epstein, a Mercedes 11 S500 sedan. I don't remember the year on that one. 12 O. Okay. 13 A. There's a Cadliao Escalade. 14 O. Okay. 15 A. Those are his two main cars that he would be 16 driven in or -- 1? O. What are the other cars that you reguiarty see 10 parked at his Palm Beach mansion, if there are any? 19 A. It would be a whole array. Half the time the 20 parking lot is full because of construction workers. 21 yards keepers. 22 O. Okay. Fair enough. What vehicle does 21 drive or-drive when they're down 24 here, you known 25 A. I mean, anybody has a choice to pick out a car 174 1 don't remember which one it was. II was ether the 8 or 2 the 16. and then the other ono I met everybody there. 3 So I can't be accurate on which erne we all drove 4 together. 5 O. How did you coordinate driving together? 6 A. I don't exactly remember now. I mean, I think 7 -and I may have conversed on the phone and said do a you want to meet at Jeffreys house and we all drive 9 together? Does a make sense to get together and drive 10 one car. 11 O. Is that jail visit the result ol Jeffrey 12 Epstein requesting your presence Mere, Of rs that the 13 result of you wanting to go see him as a friend in jail? 14 A. A combination of both. I'm sure if I said, 15 Hey, rd like to come to jail and veil you, that ho 16 would either say yea or nay. 17 O. Okay. And you saki at least on one of those 18 occasions you rode to and Irom the lad with =and 19 20 A. Yes. 21. O. And during any of obviously, when you're in 22 the car together — well, who's driving the car? 23 A. I was driving, I believe. 24 O. And that's the Hummer again? 25 A. Actually, I think we take one of the suburbans 1 2 3 4 5 6 7 $ 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 24 25 176 or whatever there. I've seen driving a Mercedes convertible. O. Is that different than the Mercedes $500 sedan? A. Yes. I think it's different. O. When you say they have basically a choice of cars to drive - A. Well, there's cars in the lot there. O. Obviously, they can't get in one of the construction workers' cars? A. No. MR. REINHART: Let him finish his question. BY MR. EDWARDS: O. So that's kind of what I'm getting at. What other cars do you think that Jeffrey Epstein has -- whether it's titled. I don't know - 0. Right. O. but he is the person In control of that vehicle? A. Right. O. What other vehicles do you think he's controlling in Palm Beach? A. In Palm Beach? O. We've named the Mercedes S500 sedan, Cadillac Escalade? ESQUIRE gra manic. 010, Coars•r Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Fl. 33410 www.esquiresolutions.com EFTA01110370 Larry Visoski October 15, 2009 177 1 A. Right. 2 0. And Eve identified a Mercedes convertible? 3 A. Right. 4 0. In addition to that. are there any others that • you're aware of? 6 A. That he's in control of? 7 Q. Yes. • A. No. 9 0. And does the conversation come up between 10 Mi ancin and yourself about the reason why 11 Jeffrey Epstein is In jail? 12 MR. REINHART: Can we get a time frame? 13 MR. EDWARDS: At any time. 14 BY MR. EDWARDS: 15 0. At any time have you ever had that exact 16 conversation ever come up? 17 A. No. we didn't talk about that among ourselves 143 really. 19 Q. And have you ever been told that= 20 provides the role of a sex slave to Jeffrey 21 Epstein? That's just her role in life? 22 MR. CARTON: Form. 23 MR. REINHART: That's just have you been told 24 that. 25 THE WITNESS: No. 179 he utilizes various people, schedulers, pilots. 2 handlers and other associates and co-conspirators 3 that have a similar mentality: that is, people that 4 do not agree with laws related to sex abuse and 5 abuse of children. And that's why this line of 6 questioning regarding whether or not this witness 7 has a motive or a bias or was involved in 8 conversations related to his motive or bias, to 9 continue to work for Jeffrey Epstein or believed 10 the same beliefs of Jeffrey Epstein, is at least 11 reasonably calculated to the lead the discovery of 12 admissible evidence, and that Is the argument at 13 least along those fines being made to the judge 14 regarding these questions. 15 MR. CRITTON: Can we talk for just one minulo'l 16 Because maybe — can I talk with — well, I know 17 can talk with Bruce. Let's Just take a break. 18 (A break was had al 2:45 p.m.) 19 MR. EDWARDS: We're be* on the record. Do 20 you have the same position? 21 MR. REINHART: Let me say this: He previously 22 said he would have never allowed anything on the 23 plane to be done elegaRy. II you want to ask If 24 he agrees with the law applied by the 25 legislature — do you agree the law passed by the 178 1 BY MR. EDWARDS: 2 0. Have you been led to believe that by anybody? A. No. a MR. CRITTON: Form. 5 BY MR. EDWARDS: 6 Q. Do you have any — based on your observations, 7 do you have any other opinion as to what rote she plays Es in Jeffrey Epstein's life, if any? 9 A. I don't have an opinion on what the role is. 10 0. Do you agree with the criminal statutes that 11 are in place to protect young children from sexual 12 predators? Do you agree with those statutes? 13 MR. CRITTON: Form. 14 MR. REINHART: IM going to direct him not to 15 answer the question. Its irrelevant and it's not 16 likely to lead to discoverable evidence what his 1? opinion is on a law Chars been passed by the 18 legislature of Florida. 19 MR, EDWARDS: Just so the record is dear, I 20 don't know that we did this last time, but It's 21 been alleged in the complaint k has been 22 alleged in several complaints that Jeffrey Epstein 23 panicularly prays on vulnerable disadvantaged 24 females, underage females, and that in order to 25 gain access to the multitude of underage females, 180 state of Florida should be complied with? 2 THE WITNESS: I don't know what the law is. 3 BY MR. EDWARDS: 4 0. Okay. The laws In place to protect children 5 under the age of 18 from being sexually touched, 6 fondled, molested by people over the age of 24, do you 7 agree with those laws? 8 A. Yes. 9 0. And you agree that persons who commit a 10 violation of those laws should be prosecuted? 11 A. Persons that do that. 12 MR. CRITTON: Form. 13 BY MR. EDWARDS: 14 0. Yes, persons that do that. 15 A. Persons that do that, absolutes/. 16 0. And if you were to receive confirmed what 17 you would perceive as confirmed information that Jeffrey 18 Epstein was one of those persona, would you continue to 19 be erriployed by or alongside of Jeffrey Epstein? 20 MR. CRITTON: Form; speculation. 21 THE WITNESS: You're pawning that there's 22 gut 23 BY MR. EDWARDS: 24 0. No. I'm saying, hypothetically, if you were 25 convinced that Jeffrey Epstein was guilty of those acts ESQUIRE .. A traten Gan* Cana) Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, R. 33410 www.esquiresolutions.com EFTA01110371 Larry Visoski October 15, 2009 181 which he pled guilty to 2 MR. CRITTON: Form. 3 MR. REINHART: Can we -- for purposes of your 4 hypothetical, what facts do you want him to assume 5 are true? You said the facts to which he pled 6 guilty, but the witness already said he doesn't know what he pled guilty to. He imows the charge 8 he doesn't know the facts. 9 BY MR. EDWARDS: 10 Q. Solicitation of prostitution of a minor, 11 somebody under the age of 18. 12 MR. EDWARDS: That's the charge, right. 13 solicitation of prostitution of a minor? 14 MR. CRITTON: No. I think you've got it 15 wrong. III object to the form. 16 MR. EDWARDS: Okay. 17 BY MR. EDWARDS: 18 O. Then well handle the question this way: If 19 you were to believe based on informati0n and evidence 20 that Mr. Epstein engaged in sex or some form of sex acts 21 with people of the age range of 12, 13, 14. 15 years 22 old, would you continue your employment with 23 Mr. Epstein? 24 MR. CRITTON: Form; speculation. 25 THE WITNESS: I would certainly be speculating 183 1 against him and the allegations contained within many of 2 these civil complaints on behalf of girls who were under 3 the age of 18? Is there any reason why you haven't 4 discussed that? 5 MR. REINHART; If that's based on 6 conversations you had with your lawyer, then don't 7 disclose what you and your lawyer talked about 8 BY MR. EDWARDS: 9 0. Correct. 10 A. I have not spoken to Jeffrey about any of 11 this, and it was my understanding that is illegal to 12 have conversation about this. So I've never presented 13 any questions to him reference this case or any others. 14 0. It was your understanding that it was illegal 15 to talk to Jeffrey Epstein about the allegations made 16 against Jeffrey Epstein? 17 A. Yes, or anything to do with the case. That's 18 why we never discussed any portions of it. 19 Q. Okay. So -- 20 A. I may be wrong In that assumption, but I 21 don't -- 22 Q. So the reason why you haven't discussed this 23 with Jeffrey Epstein is you believed it was illegal? 24 A. Correct, yes. 25 Q. Who led you to believe that it was illegal? 182 1 and I have to dleCuss ft with my wife long and 2 hard. I don't think I could give you a correct and 3 honest answer at this tine. 4 BY MR. EDWARDS: 5 0. Okay. Given the allegations that have been 6 made in this case, is this something that you have 7 discussed with anyone other than your attorney? 8 A. No. not really. Only from the fact that 9 drey're allegations and there's still a lot more work, 10 rm sure, to be discovered. 11 MR. CRITTON: Let me put on there, for the — 12 If this deposition is not typed -- and we request 13 it -- rd like at least this portion where 14 Mr. Edwards' last question back about five pages 15 worth, so just if you could mark it from ells 16 page back about five pages. 17 If nobody requests the deposition, rd just 18 like those five pages. 19 MR. EDWARDS: I'm going to request the 20 deposition, so... 21 MR. CRITTON: Okay. We'll mark this then, so 22 you could tell me where it is. approximately. 23 BY MR. EDWARDS: 24 0. Is there a reason why you have not discussed 25 with Jeffrey Epstein the allegations that have been made 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 184 MR. REINHART: Again, if it was a discussion you had with any lawyer, then you can just give a name, don't give a discussion of the conversation you had. THE WITNESS: It was my own assumption. I mean, just basic criminal knowledge of knowing you're not supposed to -- you know, it somebody's in trial or in a deposition or whatever, I don't -- I didn't think it was appropriate to discuss the matter with them. BY MR. EDWARDS: Q. Okay. So the next two visits and I think the last two visits we'll talk about are on 9/6/2008. Actually, it looks like you visited him twice in one day; is that right? A. I don't think that's possible. I mean, that will show how accurate the court record is. There's no way. Q. You wouldn't have visited him twice in one day? A. No. I think there's only one visitation per day. 0. Okay. And It looks like the same visitors each time, except that it says for period three and then the next one's for period four. So there are two 0 ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110372 Larry Visoski October 15, 2009 5 6 7 8 9 10 11 12 13 14 15 16 17 10 19 20 21 22 23 24 25 185 different periods. Was there over a time when they 2 allowed you to stay for more than an hour? 3 A. No, not to my knowledge. 4 0. Okay. So again, it's and same questions: Did you ever ask them their involvement with Jeffrey Epstein? A. Absolutely not. 0. And again, what was the discussion with Jeffrey Epstein along with and A On the last visits, it was mainly airplane stuff and later on in the visitations, we were advised that you could leave early, so I would only stay for maybe 30 minutes and then, you know, Jeffrey would continue his conversations with them and then I would just wait outside. 0. Okay. A. So I would do my business with him talking about airplanes or whatever I had coming up and then exit. 0. And then why did you slop visiting him in jail after that September 6th, 2008, visit? A. I was never called back to visit. 0. Okay. Well, shortly after that then he was on work release? 187 telephone, how frequently would you talk to him? 2 A. How frequently during a given week? 3 0. Yeah. 4 A. More specific? 5 0. Sure. 5 A. Depends upon what's going on that week. 7 0. I mean. is it somebody you would talk to him 8 everyday? 9 A. No. 10 0. All right. Welt at that point in lime, he's 11 going from the jail to the Florida Science Foundation 12 and back, and It you're not going to see him In person, 13 and you're not corresponding by e-mail, then would you Is correspond by telephone, that either being you call him 15 or he called you? 16 A. Yes. 17 0. And, you know, in any oven week, what was the 1$ typical week like? I mean .- 19 A. Flow many times? 20 0. Yes. 21 A. Maybe once in a week, sometimes twite in a 22 day. I mean, it would vary. There was no routine. 23 0. And what would the conversation be? 24 ik Mostly we discussed audio and video, TVs, home 25 theaters. Its a niche of his and we're constantly 186 A. Well, that's true. 0. Right? A. Yeah. 0. So the next times you would have gone to see him would have been at the Florida Science Foundation, where we talked about earlier? A. I've seen him there, yes. 0. Okay. And in fact. I think you said you saw 9 Nm 20 or 30 limes -- 10 A. Sure. 11 0. over the last two years, last year and a 12 half or so? 13 A. Yes. 14 0. And how long would you stay each time at the 3.5 Florida Science Foundation and talc to him? 16 A. Like my original answer. ten, fifteen minutes. 17 0. Okay. And how frequently would you talk to 18 Jeffrey Epstein while he was at the Florida Science 19 Foundation? 20 MR. REINHART: I'm sony, you're talking in 21 person or al conversations? Because ho testified 22 he had phone conversations and personal visits. 23 BY MR. EDWARDS: 24 0. I was actually taking about phone 25 conversations. So when you would call him on the 188 1 looking at new items that are out there, you know. 2 what's the biggest LCD flat screen out there. 3 Q. Okay. And since he's been out of jail and on community control or house arrest or whatever it is, 5 where he's located at his home now, have you visited him 6 at his home? 7 A. I have been to the home. I haven't visited, but I have had work to do there. 9 0. And have you called him on the telephone lo there? 3.1 A. Once I think I've called the house. Normally 12 he calls me because its usually he needs me to do 13 something. 14 0. And what have those conversations been about is since he's been out of jail? 16 A. Let's put a stereo in the gym, lees put a TV 17 In the living room, let's put a bigger stereo in the is gym. let's put a bigger, bigger stereo in the gym, let 19 go redo what we've done. It's always audio. He's a 20 very audio file person. 21 0. Do you know of any other modifications that 22 he's made to the house at 358 El Bello since the time 23 that he went into jail? 24 MR. CRM-ON: Form; predicate. 25 THE WITNESS: Meaning? Be more specific. ESQUIRE anituada Odio Caspar Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110373 Larry Visoski October 15, 2009 189 BY MR. EDWARDS: Q. Structural modifications, architectural modifications? A. Starting what date? O. June 30th, 2008. MR. REINHART: I think the question on the table was have you observed any structural changes a to the house at El Brillo since Mr. Epstein went to 9 jai? 10 THE WITNESS: Structural changes? 11 8Y MR. EDWARDS: 12 0. Structural, architectural, anything like that, 13 changeS to the house. to the interior of the house since 14 he went to Jail? 15 A. No. I mean, it you could be more specIfc. I 16 mean. you're talking furniture or? 17 Q. I've never been In the house, so I can't be 18 much more specific. Have you noticed any changes from 19 before he went to jail to after he went to jail, the 20 Inside of the house, that you could be specific about? 21 A. No, I can't be specific. 22 MR. REINHART: Can I talk to Mr. Visoski for a 23 second? 24 MR. EDWARDS: Sure. 25 (Off the record itscussion.) 191 1 A. No, I don't. Ifs not my airplane. 2 Q. We still don't know whose airplane it is yet. 3 The tine when you took Mr. Epstein to Miami in the last 4 month, do you know which attorney ho was going to sect? 5 A. No, I do not. 6 0. And do you know whether it was related to 7 civil cases or criminal cases or anything else? a A. No idea. 9 Q. Do you know where the location was in Miami 10 that he was going to? 11 A. No, I do not 12 Q. Other than yourself visiting Mr. Epstein at 13 the Florida Science Foundation, are you aware of any 14 other visitors, people that visited him? Is A. No, I'm not. Just whoever was there during my 16 visit. 17 O. Okay. Are you aware of a corporation named Is the Zoao Trust? 19 A. rve heard the name. 20 Q. And Is that something that you've heard 21 relative to your invoNement with Jeffrey Epstein? 22 A. Yes. I mean, I don't even remember where I 23 heard Zorro Trust. I have no definition of it, but I 24 know the name is out there. 25 0. Okay. Is that a company that you believe is 190 MR. REINHART: I think Mr. Visoski can expand on his previous answer. Why don't you expand. THE WITNESS: Can we go baCk to that one? BY MR. EDWARDS: 0. Sure. The question dealt with the structural architectural changes you're aware of. A. There has been a kitchen extension, but when :-: you asked the question, I was unaware of when that 9 actually took place. So to be accurately answering your 10 question, I know there's been a kitchen extension. I 11 don't exactly know when that transpired, but... 12 0. How do you know about the extension? How do 13 you know this happened? 14 A. I knew what the kitchen looked like before and 15 after the extension and I don't I thought it was 16 during the hurricane season when they actually did that 17 extertskm. 18 0. Who made you aware of it? 19 A. Nobody. I just walked in the kitchen and 20 noticed a bigger room than what it was. 22 Q. All right. Do you know who Marlin Nowack is? 22 A. No. 23 Q. Do you ever remember him being on your 24 airplane, or that name of somebody being on your 25 airplane? 2 3 4 5 6 7 8 9 20 11 12 23 14 15 16 17 18 19 20 21 22 23 24 25 192 affiliated or restated to Jeffrey Epstein in some way? A. I have no definition. I don't know who it is. 0. Do you know how you heard about it? A. I don't remember. That's going back in the early days of when Zorro existed. 0. Who was at the Florida Science Foundation when you would meet with Jeffrey Epstein on these meetings? A. would be there. 0. Anybody else? A. Story would be there on occasion. That's pretty much it. Q. And would they be in the same room with yourself and Jeffrey Epstein when you had conversations with hcm? A. No, not really. Not particularly. 0. They would just be at the location? A. Sure, yes. O. Anybody else that worked there or was affiliated wet, the Ronda Science Foundation that you know of? A. Not to my knowledge. I mean, I do my business and get in and get out Q. Can anybody other than Jeffrey Epstein have an office at the Florida Science Foundation? A. Not that I know of. ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutions.com EFTA01110374 Larry Visoski October 15, 2009 193 1 0. All right. And were you deeded the properly 2 that we spoke about earlier on the New Mode° ranch? Is 3 that deeded to you? 4 A. Yes. Q. And has It been since back in, I think you 6 said 1998 or 1999 or whenever it was? 7 A. Yes. 0. Okay. And do you know — and did you build a 9 house on it then? 10 A. Yes, I did. 11 0. Okay. And that's a property that I think you 12 said you have a mortgage on It. that's a property that 13 you pay -- you mortgaged that property? 14 A. Yes. sir. Is 0. All right. And as well, the home you own 16 here, you have a mortgage on that properly as well? 17 A. That Is correct. 18 0. Alt right. Are you familiar with a vehicle. a 19 Chevy Suburban 1503. year 1999? 20 A. Do you have a color? 21 0. No. I can tell you the ;Ate. I could tell 22 you the VIN. Chevy Suburban -- Chevy Suburban 1500, 23 registered to Larry Vlsoski? 24 A. That would be mine. That's a while one, then. 25 0. Okay. When did you get it? 195 1 0. Well, we've just described this wide array of 2 cars that Jeffrey had for people to use -- 3 A. Well you sakl for him to use. 4 MR. CRITTON: Hold it. 5 BY MR. EDWARDS: 6 Q. Is there a reason why? MR. CRITTON: Wait. You guys are both talking 8 over one another. You need to let him wait and 9 finish his question because If I want to assert an 10 objection. neither one of you gives me a chance. 11 which may be the plan. Form. 12 MR. EDWARDS: Yeah, we have a conspiracy 13 against you. 14 MR. CRITTON: I knew it. I'll take that as an 15 admission. 16 BY MR. EDWARDS: 17 0. Is there any reason did Jeffrey say that he 1 e wanted that vehicle to use or to bo parked at his house? 19 A. No. 20 0. Then how did it come about that you started 21 parking that vehicle at his home? 22 A. I think the origination of that came when I 23 started using the Hummer, that the Suburban was parked 24 in my driveway and I wanted to get it out of my driveway 25 as an eyesore. So hence, I decided to let people at the c 5 9 1G 11 12 13 14 IS 16 17 18 19 20 21 22 23 24 25 194 A. rm guessing. It was probably two years old when I got it. Maybe '99. Maybe '01.'02. 0. Something you still drive? A. Occasionally. Its kind of a beat up car now, so it's kind of a knock around. 0. Best of your knowledge, it stays parked at your house? A. Recently irs been in Jeffrey's driveway, 0. Why? A. Just for an extra car to use. 0. For Jeffrey to use? A. No. I mean, for anybody that would come to the house to help out. Igor I think has driven the car before. 0. How did it come about that you began to park the Chevy Suburban, the 1999 car that we're talking about, at Jeffrey's house? A. When there was more activity here in West Palm Beach. We were never usually coming here that often, and now with atilt*, going on, with Jeffrey being in town longer, we needed more cars and transportation. So my car was lust sitting In the driveway at home while I was driving the Hummer. So I decided to let them use the Hummer at the house. 196 1 house drive it as a grocery shopping car or something, 2 or just as extra transportation. 3 0. Okay. But when you go to park the car at 4 somebody else's house, you have to let them know. Hey, 5 rm giving you the keys? 6 A. Mm-hmm. 7 O. Who did you give the keys to? 8 A. I don't know ill gave the keys to anybody. 9 may have just left them on the counter there and told to Yanush this is an extra car if you guys needed it to run 11 around because it was an eyesore at my driveway. 12 0. Are you familiar with a Mercedes-Benz SIN 13 1999? 14 A. Say that again. 15 0. Mercedes SUV, 1999 registered in your name? 16 A. Yes. 17 0. And what car is that? 18 A. There my car my wife's car. 19 0. Does that stay al your house? 20 A. Yes. 21 O. And that's the car that's parked at your hot's.. 22 now? 23 A. Yes. 24 0. Are you familiar with a Land Rover, Range 25 Rover Sport 2008? ESQUIRE ttlemidet Gale Cala A Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110375 Larry Visoski October 15, 2009 197 1 A. Yes. 2 Q. Registered in your name? 3 A. Yes. 4 0. And whose car is that? 5 A. That's another extra car for the household to 6 use at Jeffrey's house. 7 0. And when was that car purchased? 8 A. Last year. 9 0. And who purchased that car? 10 A. tt was purchased in my name. 11 a By whom? Who purchased the car in your name? 32 A. Well. I put the car In my name, but the lands 31 came from they were wired to my account from New 14 York. 15 O. From whom, though? A mysterious source Just 16 sent funds? We know that didn't happen, so Prn just 17 trying t0 elaborate here. 18 A. Jeffrey had paid for the car. 19 O. Okay. And why did Jeffrey pay fora car and 20 put It In your name? 21 A. I don't know. 22 0. I mean, you had to agree for this to happen. 23 So what was the conversation between you and Jeffrey 24 that resulted in Jeffrey paying for a Land Rover, a 2008 25 Land Rover and putting It in your name? 199 1 2005 registered in your name? 2 A. Yes. 3 0. And whose car is that? 4 A. That car also is a Palm Beach house car to be 5 used at the house. 6 0. What does that mean, 'a Palm Beach house car? 7 A. It's a car that we park in Jeffrey's driveway 8 for people to use. Anybody that comes to the house can 9 selectee/it to go anywhere. I mean, run errands, go 10 shopping, do whatever they need to do. And that was 11 purchased the same way. It was in my name. 12 0. And the funds came from Jeffrey Epstein? 13 A. They were wired to my account. I don't know 14 exactly what account they came from. 15 0. Again, that's a conversation that has to take 16 place before — that you have to agree to put a car in 17 your name? 1e A. Yes, yes. 19 0. And is that a conversation between yourself 20 and Jeffrey Epstein that takes place? 21 A. Yes. 22 0. And what is the substance of that conversation 21 that results in a Mercedes-Benz 2005 being placed in 24 your name? 25 A. He just said we need a fun car for the house 198 A. I don't recall exactly how the conversation came about. He just says we want to buy an '08 Land 3 Rover and put it in my name. So we did. I didn't ask 4 any further questions. 0. Did this conversation happen when he was in jail or after he was out? A. Meaning out on house arrest? a 0. Right. 9 A. When you say flout' I think of the Science o Foundation. On work release, so you have to be more 11 specific. 12 0. You tell me what happened, when the 13 conversation happened relative to whore Jeffrey was at 14 the time. 15 A. I'd only be guessing again. I would say this 16 probably happened a year ago, maybe loss than a year 17 ago. rd have to look. I don't remember exactly the 19 0. So It was either at a time when he's at the 19 Florida Science Foundation or possibly on house arrest? 20 A. It was - no, it was definitely before house 21 arrest. It was probably during the time of the Florida 22 Science Foundation, to be accurate. 23 0. Okay. Are you aware 24 A. About eight or nine months ago. 25 0. Okay. Are you aware of a Mercedes-Benz CLK 200 1 It Palm Beach. 2 0. But why put it in your name? 3 A. I don't knOW. 4 O. You didn't ask any questions about that? A. No. I didn't. 6 0. Okay. Are you aware of a Jaguar X-Type 2005 7 registered in your name? A. I forgot about that one, yes. 9 0. Whose car is that? 10 A. That's a Palm Beach car. 11 0. What do you mean 'a Palm Beach car"? 12 A. It's the Palm Beach house car, another run 23 around for people to use. 14 0. And again, that's a conversation that has to 15 take place that results In a car being placed -- 16 registered in your name? 17 A. Yes. 18 0. Okay. Now we're talking about several cars 19 here? 20 A. Yes. 21 0. That are all being placed in your name? 22 A. Yes. 23 0. You never at any time ask any questions to 24 Jeffrey Epstein why are you placing these cars in my 25 name? ESQUIRE an Alessade• CaloCapaRy Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Ft. 33410 www.esquIresoludons.com EFTA01110376 Larry Visoski October 15, 2009 3 5 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 201 A. I did not. Q. So your suspicions were never -- your curiosity was never piqued at all as to why these cars we being placed In your name? A. My curiosity was piqued. Q. You never asked him the question, you just agreed to do it? A. That's correct. 0. That goes for the Jaguar X-Type? A. Yes. Q. Are you familiar with a motorcycle, Big Dog Chopper Motorcycle. 2003? A. That is mine. 0. Yours? A. Yes. Q. Registered in your name for a good purpose, right? A. Yos, It is. Q. At your house? A. Yes. 0. You use it? A. Absolutely. Q. Al right. Ford F-250, 2008. registered in your name, are you familiar with that? A. It's not registered in my name. 1 0. 2 A. 3 0. 4 A. 5 Lie. 203 Who drives that car, Ford F-250? That was shipped to St. Thomas. For who to use and for what purpose? Wel, that car should have been put under LSJ, 6 0. What's LSJ, LLC? 7 A. Little St. James. Q. And that's a corporation? 9 A. Yes. 10 0. Your understanding is that's a corporation 11 affiliated with Jeffrey Epstein? 12 A. I know It's a corporation. I don't know its 13 affiliation to Jeffrey. 14 0. At this point in time, the way that this car 15 comes about Is through a conversation with yourself and 16 Jeffrey Epstein? 17 A. Yes, yes. le 0. So to make some representation that this • • 19 that this corporation LSJ, LLC, you're not sure if char 20 has any affiliation with Jeffrey Epstein? 21 A. I don't have any facts to lie the two 22 together. 23 0. Common sense would dictate? 24 A. Yes. 25 0. Okay. 202 Q. Okay. So if that's registered in your name, that would be a shock to you? That would be a surprise to you? A. Yes. it would be. 0. There should be no documentation from you where you would be the registered owner of the Ford F-250? A. What year? 9 0. 2006. 10 A. I remember buying that car. I just - that 11 shouldn't be in my name. 12 0. What do you mean you remember buying that car? 13 A. I do a lot -- !do all the car purchases for 14 Mr. Epstein. I'm a car fanatic, so for years I've been is the car-shopper. I'm the car fanatic. 16 0. Okay. But these cars aren't classic vehicles. 17 These are vehicles that are not being refurbished or 18 anything, they're being driven wound town? 19 A. No. but theyre fun. The new Range Rover is a 20 nice car. 21 O. This Ford F250, that's a car also that's Palm 22 Beach as you would say a Palm Beach car? 23 A No. 24 0. That's a car that stays at your house? 25 A No. 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 204 MR. CRITION: Form. BY MR. EDWARDS: 0. Again, that's not a car that you use. the Ford F-250? A. No, it's not even here. 0. And when you say on St. Thomas, is it on actual St. Thomas, or Is It on Little St. James? A. No, it's on St. Thomas. ft's a work vehicle. 0. For whom? A. For the workers, for the island. MR. REINHAFIT: Be careful to answer his question. I think his question is. is it on St. Thomas or Little SI. James island? Where physically is the car, if you know. THE WITNESS: I don't know for a tact. BY MR. EDWARDS: 0. It's your understanding it's on St. Thomas? A. Yes. 0. And when you say "the workers; what's going on on St. Thomas to where there's workers that need an F-250? A. Just moving sand. I don't know the exact detail for it. 0. What were you told about the need for this car to be on St. Thomas? C) ESQUIRE ad Maude/ Galls GOP.07 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110377 Larry Visoski October 15, 2009 205 A. They need a work truck. O. To do what? 3 A. I don't know what the detail or the - you 4 know, what the job detail was for the truck. They just 5 needed a work truck 6 Q. So Jeffrey Epstein tells you they need a work truck on St. Thomas and that's the only description that s you're given? 9 A. Yes, to go purchase and get the best deaf I 10 can on a pickup truck, and that's what I did and for 11 some reason it got put in my name. 12 (Off the record discussion ) 23 BY MR. EDWARDS: 14 O. Whose money was used to purchase the truck. 15 You say you purchased the truck. I want the record to 16 be clear whether yd.:Ye purchasing it with your money? 17 A. No, this was wire-transferred. it was a I 18 don't remember how that - I think it was a wire 19 transfer or a check was FedExed from the New York office 2o to pay for that. Thal should not be in my name, Is what 21 rm getting at. certainly change that, but I 22 thought you were •• 23 O. I understand that. 24 A. No, rim being — yeah, I didn't. 25 MR. REINHART: There's no question. 207 1 O. Okay. And by *Jeffreys boat; It was 2 purchased with Jeffrey's money? 3 A. That is correct. 4 O. A. 6 O. 7 A. a O. 9 A. 10 O. 11 cod? 12 A. 36.000. 13 O. Do you know how much the Land Rover cost? 14 A. 68,000. 15 O. Do you know how much tho Mercedes-Benz SIN 16 cost, that's yours. right? The Chevy Suburban is yours 17 as well? is A. Yes, I remember how much those cost too. 19 O. IS there another boat, 35•foot Donzl 20 powerboat, 1999? 21 A. That's the one I thought you were talking 22 about originally. 23 Q. That's the same boat? 24 A. That's the same boat. 25 O. Is there any other boat Mars registered in Do you know how much that cost? I think it was 60.000. Do you know how much the Ford F-250 cost? Twenty-five, lYn guessing. ballpark. Do you know how much the Jaguar X-Type cost? 11,000. Do you know how much the Mercedes-Benz CLK 206 1 BY MR. EDWARD$: 2 O. 34-foot JVC Powerboat, 2000, owner LSJ, LLC, 3 registered to Larry Visosid. Do you know that? 4 A. Yea Q. You knew that that boat was registered in your 6 name? 7 A. It's registered to LSJ. It's Jeffreys boat 8 that we keep here in West Palm Beach. 9 O. And do you keep It at your home? 10 A. No. 11 O. Do you know that the registration is 10 your 12 home? 13 A. It's used in my home address, yes. 14 Q. Why was that done? 15 A. We were eventually going to shlp it out to 16 St. Thomas for it to live, but Since Jeffreys here, 17 we're keeping it in Florida• and when we ship the boat is over, we will change title to the Little St. James 19 address. 20 O. What do you mean 'since Jeffrey's here we're 21 keeping it in Florida'? What does Jeffrey being here 22 have to do with keeping a boat that's registered in your 23 name and to your address -- 24 A. Well. I have access to use the boat, you know, 25 here in Florida, but it's Jeffrey's boat 1 2 3 4 5 6 7 8 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 24 25 208 your name? A. No. Q. Did you know that in let me ask you this: Do you have a 2003 Ferrari F75-M? A. No. O. Any reason why the car is registered in your name and the asking price Is $159,000 being sold in Now York? A. That car is not registered in my name. O. If It's registered — A. The ad is in my name. O. Why is the ad in your name? A. Because I was trying to sell it. O. Why were you trying to sell it? A. It was Jeffrey's car and we didn't want t: anymore. O. Why wouki he put his pilot in charge of selling his Ferrari? A. Because I bought it. O. How much did you buy it for? A. 179.000. Now, when I say 'I bought le 4 was his money. I was the one that negotiated it, to be dear. It was his car for use in New York. Q. Are you aware of the Zorro Trust winning an 85 mitiondollar Power Bab lottery in 2008? ESQUIRE aa Monate Coallo CalaY Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110378 Larry Visoski October 15, 2009 209 A. No. MR. CRITTON: Say that again. MR. EDWARDS: The Zorro Trust winning an • 85 million-dollar claiming the ticket for 85 million-dollar Power Ball ticket in 2008. THE WITNESS: No. BY MR. EDWARDS: 2 Q. Have you ever listed your employer as 9 Ghlslalne Air In making political contributions? 10 A. I may have. 11 O. Did you know that you had made political 12 contributions -- 13 A. Yes, I have. 14 0. -- listing your - is A. I needed a company name for that event, and I 16 had put Air Ghislaine. 17 0. And NES, LLC wouldn't do? 18 A. I didn't think of it at the time. 19 0. Did Somebody tell you to use Air Ghislaine 20 rather than the company that has been paying you? 21 A. No. 22 0. You Just chose to use an employer that Isn't 23 actually your employer, nor have they ever been? 24 A. I represent Air Ghislaine, JEGE and Hyperion 25 as chef pilot, so I consider those really the companies 211 1 MR. REINHART: Mr. Edwards. ho needs to expand 2 upon one earlier answer he gave when you asked him 3 II he knew anybody else who worked at the Florida ♦ Science Foundation. 5 BY MR. EDWARDS: 6 0. Okay. 7 A. My Wife worked there. When you used the words 8 'worked there* - or not referring to her as a past 9 tense, but she worked there when it first opened 10 answering the phones. 11 0. What's your wife's name? 12 A. Eileen. 13 0. How does she spell that? 14 A. E-I-L-E-E-N. IS 0. Same last name as you? 16 A. Yes. 17 Q. How long did she work there? 18 A. A month. maybe. 19 0. And she was answering the phones for the 20 Florida Science Foundation? 21 A. Yes. 22 Q. Do you have a good relationship with your 23 wife? 24 A. I think so 25 0. You still don't know what tic Fiorida Sc ercc 210 that I work for and never really associated myself with NES. LLC as my realistic employer. So when I go to a convention, an aviation convention, and somebody says 4 who do you work for, I use the name JEGE because that's the name of the Boeing company. 0. But when I sit here and ask you who you work for, you give me a different answer. A. You're asking for the absolute correct answer. 9 which is where my paycheck comes from, which Is NES, 10 LLC. I probably have used that twice in 17 or 18 years 11 as my employer. 12 0. Do you know ? 13 A. I know the name, yes. 14 O. How do you know her? 15 A. I've seen her on the airplane a couple times. 16 0. Somebody that you know to be involved 17 romantically or sexually with Jeffrey Epstein at any is time? 19 A. I don't know that. 20 O. Are there any other cars, vehicles, items. 21 ocher things that are registered in your name that are 22 actually Jeffrey Epstein's? 23 A. No. You've actually covered them all and 24 actuay shed light on some that I did not realize, like 25 that Ford. 212 1 Foundation does? 2 A. No, because she doesn't. 3 0. She doesn't know what it does either' 4 A. We never talked about it 5 0. You never talked to your wife about what st), 6 did? 7 A. No. 8 MR. CRITTON: He knew she was answerirt: 9 phones. 10 BY MR. EDWARDS: 11 O. Do you know of any other employees, trends, 12 agents, relatives of Jeffrey Epstein who he places his 13 property in their names, registers them In his names or 14 anybody else? 35 A. Not to my knowledge. I don't know. 16 0. To your knowledge. you're the only person? 17 A. I'm the only one I'm aware of. 18 0. And with respect to minor girls being on the 19 airplane, that being under the age of 18, how many times 20 would you say that you have flown girls into the 21 country, Into the United States where you have given a 22 date of birth to Customs of somebody on the airplane 23 that Is under the age of 18? 24 A. I'd have to look at fright records to verify 25 or give you a correct answer. I don't know any to my 0 ESQUIRE aM“astiC.liotomPV Toll Free: 866,709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 wwvv.esquiresolulions.00m EFTA01110379 Larry Visoski October 15, 2009 213 knowledge at this point. O. What Wight records would you have to look at? A. The passenger manifests. 0. Passenger manifests would have the date of birth on it? A. No. It would have a name, but I don't have -- 0. But at some point in time you remember people, minor date of births, coming Into the country and that 9 being turned Over to Customs? 10 MR. CRITTON: Form. 11 THE WITNESS: I don't remember anybody 12 transporting on the airplane from the country back 13 into the U.S. that was a minor, to my knowledge. 14 BY MR. EDWARDS: 15 O. Okay. Within the country. minors flying - la A. I don't know. 17 O. -- on a plane? 18 A. I don't know dates of birth. 19 O. And any people that you knew to be minors on 20 me airplane, were they always accompanied by parents or 21 were there minors on the airplane that you're aware of 22 that were not accompanied by parents? 23 A. I didn't know either way. I mean, people 24 would get on the airplane and get off the airplane. I 25 could tell you there were times people would get on that 215 1 leave? 2 A. Us as the crew. 3 O. Okay. So if a massage table had ever been 4 used, it would have been you and the crew who would have 5 been responsible for either taking towels or doing 6 something with the massage table? A. Absokitety. 8 O. And if I understood your testimony, you never 9 saw a circumstance rebate it appeared to you that the 10 massage table had been used in any manner; is that 11 correct? 12 A. mat is correct. It stayed in the same 13 location since the day it was put on there. 14 O. You were asked a bunch -- a number of as questions about Mr. Epstein, Ill use this -- 16 Mr. Epstein is the person who (erected you generally 17 unless one of -• someone else who worked on his behalf as called you and asked you to, say. set up a tine to leave 19 or pick up luggage, et cetera. My question to you is 20 this: Have you flown in the past for other private 21 individuals Ike Mr. Epstein. i.e., as distinct from a 22 cornraerclar? 23 A. Yes. I have. 24 O. And approximately have you Down for four, 25 eve, six other private exhviduals over the years? 214 I (AIM even know were on the airplane. Our focus Is 2 up front. O. Was there a massage table on the airplane? 4 A. Which aircraft? 0. On any of them? 6 A. The Boeing used to have a table on there. but 7 it stayed in the same spot and appeared to be never B used 9 O. Okay. So to the best of your knowledge, you 10 have no knowledge of that massage table on the airplane 11 ever being used? 12 A. Correct. 13 MR. EDWARDS: I don't have anything else. 14 CROSS (LARRY VISOSKI) 15 BY MR. CRT ON: 16 0. Mr. Visoski. I have just a few questions. You 17 were just asked about a massage table on the — any of le Mr. Epateiris airplanes and you said there was a massage 19 table on the Boeing? 20 A. Yes. 21 0. Okay. Was there always a massage table on the 22 Boeing or just for a period of time? 23 A. Just fora period of time. 24 O. All right. And who's responebie for cleaning 25 up the airplane after Mr. Epstein andfor the guests 216 1 A. Three. I had a short career as far as 2 transferring of owners. 3 O. In terms of transferring to the other owners, 4 separate and apart from Mr. Epstein, again, every individual is different, but was your relationship 6 realty any different with any of those other 7 individuals? That Is, you were in essence you were a hired to perform a specific task: Fly an airplane to 9 get from Point A to Pomt B and get the people there to safely? 11 A. My first job, corporate-wise, was for an owner 12 in Miami and I was hired as a pilot, but yet. I would go 23 to his house and maintain a boat that was in the back of 14 his house above and beyond my call of duty because I had 15 an interest in boats. Ws just something I like to do. 16 But I always treated Mr. Epstein site any of the other 17 prior orients that I had as owners. I knew that I was 16 not afraid to work for a living, and they understood 19 that. 20 O. And it sounds like at least the tat owner 21 that you worked for asked you to do eirnilar things that 22 you've done for Mr. Epstein, such as take care of a boat 23 or purchase a boat a maintain the boat? 24 A. Sum, absolutely. 25 a So your relational* with Mr. Epstein with ESQUIRE Al A444.40M Cann! Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110380 Larry Visoski October 15, 2009 217 . regard to if you bought boats or you bought cars on his 2 behalf. that's very similar to your prior experience with working with another private individual? A. That Is correct. O. In terms of the records, the manner in which you flew the plane or — I don't want to say flew the plane, but in which you operated and maintained the 3 plane for Mr. Epstein are substantialy the same you've 9 done with other private individuals? 10 A. Right, exactly the same. We wouldn't treat 11 Mr. Epstein any different than any prior — previous 12 jobs that I had. It's the same routine we carry over 13 and that's why we're good at what we do. We take care 14 of the airplanes to the best of our ability. 15 O. Is your focus as the pilot, as the captain of 16 both of the airplanes when you took over that 17 responsibility a number of years age Is it your 18 obligation to get the passengers there safely -- onboard 19 and safely to the destination and then return? 20 A. Yes that was always job number one. 21 O. And most of us have had I'd say a much more 22 substantial experience in flying commercial planes and I 23 rarely see in fact, I cant remember the last time 24 particularly after 2001 I saw the pilots coming back 25 into the cabin shaking hands and helping distnbute the 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 219 A. No. I have not O. Did Mr. Edwards, in approximately four hours, little over lour hours of questioning, ever ask you one question about. that you can recall? A. Not that I recall. O. Have you ever heard the name Did you ever know someone named M.? A. Never heard that name. O. In approximately four-and-a-half hours of questioning by Mr. Edwards, did he ever ask you about A. No, he did not. O. In approximately the are you familiar with an Individual by the name of Jane Doe..)? A. I never heard that name. O. In approximately four-and-a-half hours of questioning by Mr. Edwards, did he ever ask you questions about Jane Doll)? A. No, he cad net MR. CRITTON: That's all I have. MR. EDWARDS: I only have two questions based on what your testimony just was to Mr. Craton. 218 1 snacks or liquids. Maybe I'm not on the same flights 2 that some of the other lawyers here are, but I assume you fly commercial from time to time? A. Sure. O. Do you ever see the pilots interacting with it. the people who are in the back of the airplane? A. No, not at all. They stay at their station up P. front. 9 O. You got -- as the captain of the planes, when 10 you're flying, you have substantial responsibilities not 11 only to the people on the plane, but as well to the air 12 space which you're flying? 13 A. Yes. 14 O. Okay. By the way, we've been here about — 15 for about an hour and ten we started about ten. It's 16 now 3:30. Did you ever hear the name II.? Has 17 Mr. Edwards ever asked you one question about..? 18 MR. EDWARDS: Is the question have you ever 19 heard of her or did I ask any questions about her, 20 or did you ask both questions and give the same 21 answer? 22 MR. CRITTON: 111 break them down. 23 MR. EDWARDS: It doesn't matter to me. 24 BY MR. CRITTON: 25 O. Did you ever meet an individual by the name of 220 1 REDIRECT (LARRY VISOSKI) 2 BY MR. EDWARDS: 3 O. You said you had three other people that 4 you've flown for? A. Three other previous jobs. Pin trying to be 6 as accurate. 7 O. Those are private individuals? a A. That is correct. 9 Q. And who are those people? 10 A. Herb Glimpsure In Columbus. Ohio. and Edward 11 Seltzer in Miami. And then the other was Tom Boyd. and 12 that was more of a Learjet charter, but he was the owner 13 of five Leanets. Those are my only three jobs in my 14 life. 15 O. 16 A. 17 O. 15 A. 19 O. 20 in jail? 21 MR. CRITTON: Form. 22 THE WITNESS: I Mow my first Individual had 23 trouble with the taw after I had left !don't 24 remember what It was pertaining to; but no. I never 25 visited any el them in jail, no. sir. Also wealthy individuals? Big time. And did you know what they did for a living? Those I 6:4 yes. And did you ever go visit any of those people ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com EFTA01110381 Larry Visoski October 15, 2009 6 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 221 BY MR. EDWARDS: 2 O. Even the one who had trouble with the law, you I didn't go visit him In jail? A. No. I did not. 5 O. And did any of them put vehicles or other boats or anythkig else In your name? A. No. O. Okay. Any of those people ever deed any 9 property or acres or anything kke that to you? 10 A. No. 11 O. Did any of those people ever hire your wife 12 for employment? 13 A. No. 14 O. And your attorney, is that your attorney paid 15 for by you, or is this somebody that's hired by Jeffrey 16 Epstein? 17 A. It is somebody that is hired by Jeffrey 18 Epstein. 19 MR. EDWARDS: Okay. 20 MR. CRITTON: One follow-up to your question. 21 RECROSS (LARRY VISOSKI) 22 BY MR. CRITTON: 23 O. With regard to the private Individuals that 24 you worked for prior to Mr. Epstein. what was the 25 lOngest period of time that you worked for those? 1 2 3 4 6 7 9 10 11 12 13 14 15 Wendy Beath Anderson, APR, CRR. FPH 26 Notary Public State of Florida My Commission Expires: 9/202013 My Commission No.: DD 906647 Job 0127542 223 CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that LARRY VISOSKI personally appeared before me and was duly sworn on the 15th day of October. 2009. Dated tree 22nd day of October, 2009. 17 18 16 20 21 22 23 24 25 222 1 A. The longest period of time was five years and 2 the shortest being two years. 3 MR. CRITTON: Thank you. MR. EDWARDS: Well order. MR. REINHART: Well read. MR. CRITTON: Well take a copy, front page. mini with Index. (Witness excused.) (Deposition was concluded at 3:37 p.m.) 224 1 CERTIFICATE 2 THE STATE OF FLORIDA 1 COUNTY OF PALM BEACH 4 I. Wendy irreaih Anderson. Certified RealSrur Reporter and Notary Public in and lot the State ot 6 Matta at large, do hereby eerily that I was authorized lo and did report said deposition in • stenotype: and that the foregoing pages area true and 00110011 transcription of my shorthand notes of said • depo900n. 9 I further codify that said deposition was taken at the re and place hereinabove set forth and 10 mat the taking of said deposition was commenced and completed as hereinabove set ouL 11 I Wilber codify that I am not elomey or 12 Counsel of any of the parties. nor am I a relative or employee of any attorney or counsel of party COntlt;c1, 13 alh Use action, nor am I financially interested in the action. 14 The foregoing cerelicalion of this transcript 13 does not apply to any reproduction of the same by any means unless under the (Erect control andfw direction 14 of the candying reporter 17 Dated this 22nd day of October, 2009. 14 19 20 21 22 23 24 25 Wendy Beath Anderson. RPR, CPR FPR Job 8127542 ESQUIRE as Mucosa. Gallo Catirom$ Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com EFTA01110382 Larry Visoski October 15, 2009 10 11 11 I) If 15 16 11 18 19 20 21 22 21 24 25 225 DATE: Oalobar 22.2409 TO: LARRY VISOSIg Job 8121542 ego Robert D. Cnnon. Jr. sansolpt IN RE: w_ Epees Please tete notoe that on Tursday. the 15th Ce October. 2009. you gave your decoaten n the atereederred mall At tat limo, you rid soh moue signalize. It K nOW necessary mat you age you depositort As Newt* agreed io. IM panacea' we be furnished to you hough your counsel. Please road de Cloning Instructions weNtly. At Me end ot ma Wrealpi NY we trd an errata sheet AS No read your deposition. any oranges of cotreteons Met you wised make shoed be noted or me errata sheet tang page and lire net& a said &dna. CO NOT erne on to tramoryt Nell Once you have read me transcript and noted any changes, be we to sign and date the errata sheet and return mesa page* to me. If you do not road and sm. Me depose:on mein a mesonatte tie be_ 30 days unless Wen*e drooled) the viral. which roe ;Wady bean &warned to me ordering altoirey, way be tied with me Ced DI the Cast If you win to WOW yotr signaturo. sign yaw name In ne blank at 'he bollom of to killer end Mann it bus. Very nuty yours. Wendy Beath Anders* RPR. CRFL FPR ESOUIRE DEPOSITICN SERVICES. INC. 515 North Rag* Dem. Ft200 Wets Palw Boats Florid* 33401 I do hoteby new my Dreamt LARRY vISOSKI 227 ERRATA SHEET 2 P4 RE:. VS. EPSTEIN CR. TM 3 IMPOSTOR OF, LARRY vISOSK1 4 TAKEN:10.15 09 JOB NO.: 127502 5 DO NOT WRITE ON TRANSCRIPT • ENTER CHANGES HERE 4 PAGES UREA CHANGE REASON 7 B 9 10 11 12 13 1.4 LS 16 1? 16 Please WNW me aired signed errata sheet to Ills cake so that copies may be distr.:Mod to al panics 19 Urtior penalty of piwOry. I declare that I hays read rry 20 depaatiOn and Mal m true and correct subject SO any changes in bins or substance entered here. 21 22 DATE: 23 24 SIGNATURE OF DEPONENT: 23 226 1 CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH I hereby certify that I have read the 6 foregoing deposition by me given, and that the 7 statements contained herein we true and cooed to the 8 best of my knowledge and belief, WAR the exception of 9 any corrections or notations made on the errata sheet. 10 done was executed. 11 12 Dated this day of 13 2009. 14 15 16 17 18 19 LARRY VISOSKI 20 Job #127542 21 22 23 24 25 0 ESQUIRE AltuadalettIOGSPARY Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA01110383