DS9 Document EFTA01247021

-4 E. Condensed Transcript IN THE CIRCUIT COURT OF THE 15Th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Case No. 502008CA028051 XXXXMB AD DEPOSITION OF LARRY EUGENE MORRISON TAKEN ON BEHALF OF THE PLAINTIFF VOLUME I Pages 1 to 200 October 6, 2009 10:55 a.m. Jennifer DiLorenzo, court reporter S ESQUIRE • Al tas4trOblioCeropOn> Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com CONFIDENTIAL 3501.150-002 Page 1 of 92 EFTA_00068793 EFTA01247021 • • • CONFIDENTIAL 3501.150-002 Page 2 of 92 EFTA_00068794 EFTA01247022 Larry Eugene Morrison - Volume I October 6, 2009 • • 1 211 TUR CIRCUIT COURT OP TER 15111 JWICJAL CIRCUIT IX AMU FOR PALM SEAM COUNTY. FLORIDA 2 3 APPEARANCE OF COUNSEL On WWI of the Defendant MAKE I Pages I to 200 3 ATTERBURY. GOLDBERGER a WEISS BY: JACK MAN GOLDBERGER. ESO . 4 250 Ausbaban Avenue Suite 1400 s . FL 33401 Plaintiff, 6 Case No. 502000C11024051 On bead of the DeiceOwe by 1444410TIE: /0703111 AD JEFFREY EPS/811I. BURMAN. CRITTON. LUTTER & COLEMAN Defendant. 9 BY: MICHAEL J. PIKE. E90.. SIS N. Reeler Drive 10 Suite 400 IMPOSITION OP .F133101 LARRY Puma Pomace 11 TAKEN ON OEMAL7 Of THE PLAINTIFF October 6. 2009 12 10,55 4.e. . 2:20 .n. 13 On behalf of the Aeneas: 14 LAW OFFICE OF BRUCE E. REINHART IS BY: BRUCE E. REINHART, ESO.. One Gavle» Center 16 250 S. AUSIrtien Avenue Jennifer Ditonne°. court reporter 17 Suite 1400 acn, FL 33401 10 19 20 21 22 23 24 25 2 4 A COUNSEL 1 INDEX OF EXAMINATION On beret dew Plante I40114STEIN. feet OT 6 ADLER 2 BY: BRADLEY J. EDWARDS LSO 3 WITNESS: 4 and MICHAEL HEELER. ESO . 4 LARRY EUGENE MORRISON 401 East Las am Elooleverd Page Sum IMO B. FL 33394 6 DIRECT EXAMINATION By Mr. Edwards *5 7 a On WW1 cpt Mew% a CROSS-EXAMINATION By Ms. Ezell *190 9 9 CROSS-EXAMINATION MERUELSTEIN 6 HOSIOVATZ. By Mr. Wilds 0195 10 BY: JESSICA D. ARBOUR. ATTORNEYAT.LAW, 10 11 18205 Biscayne Boulevere See 2216 CROSS-EXAMINATION 11 By Mr. Pike *196 12 FURTHER REDIRECT EXAMINATION 13 By Mr. Edwards 8199 14 On bete d ef 13 leNecee: 14 15 14 POOHURST ORSECK PA BY: KATHERNE.A. &ELL ATTORNEY-AT.LAW. 15 16 INDEX TO EXHIBITS 25W. Page« Seem 1 17 Ptautfts 19 :9 18 E.101bIt Description Page On Whaled tpe by IMPIzewle 19 1 Twenty-four pages of 'LIEGE. Inc.. 20 Passenger Manifest' ii198 LAW OFFICE OF ROMP) WIWTS. PA. 20 21 BY: IIICHANDWLUTS. ESC.. 2290 ICIP•Avenue H. 21 21 se. 404 22 33631 21 24 24 (Plaintiff's Composite 1 was attached to flic original transcript and codes of the transcript.) 25 25 • ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.corn 3501.150-002 Page 3 of 92 EFTA_00068795 EFTA01247023 Larry Eugene Morrison - Volume I October 6, 2009 • 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 5 Deposition of LARRY EUGENE MORRISON October 6, 2009 THE REPORTER: Do you swear the testimony you're about to give will be the truth, the whole truth. and nothing but the truth so help you God? THE WITNESS: So help me God. LARRY EUGENE MORRISON, having been first duly sworn, was examined and testified as follows: DIRECT EXAMINATION BY MR. EDWARDS: O. Tell us your name. A. Larry Morrison. O. And. Larry. where aro you employed right now? A. For JEGE. O. What's JEGE mean? A. Its the aviation flight department for Mr. Epstein. and my primary job * Dankjold Reed Aviation. MR. REINHART: Spell A A. D-A-N-KJ-O-L-D. and then the second word is Reed, R-E-E-D, Aviation. Its a corporate flight 7 1 You know, it was a business decision made somewhere. 2 O. What does the company do? 3 A. What? The company? It's just a holding 4 company. I think, for the aircraft. It's not -- I 5 don't believe ft to be a money making company or a 6 real corporation. 7 O. You're saying 'for the aircraft.* I'm 8 interpreting that to mean you're talking about one 9 aircraft. 10 A. Correct. 11 O. Does that mean there's one or there's more 12 than one? 13 A. There's more. Ho owns more than one, but 14 just one is JEGE or -- 15 O. And the aircraft that he owns, how many of 16 those do you either service ancifor ride on? A. I used to. I haven't been -- Actually, I 18 stepped back from being physically Involved, just 19 now I lust do paperwork - and it was February of 20 2007. So I haven't actualy physically been on the 21 airplanes other than I will lake the Boeing for 22 maintenance. 23 O. Since it seems like we've kind of skipped 24 ahead from 2001 to 2007, am I right that your first 25 involvement with Jeffrey Epstein of any way, shape, or 6 1 department. 2 O. What do you dote him? 3 A. Director of Maintenance. 4 O. Okay, so you maintain his planes .- 5 A. Correct. 6 O. should something go wrong? 7 A. Correct. Yes. Yep. O. Do you also -- 9 A. For maintenance. 10 O. Do you also fly on his planes? 11 A. On Mr. Epstein's? 12 a Yes. 13 A. I used to. I was a flight engineer -- 14 O. Okay. What.. 15 A. on his 727. 16 O. When you list your company - JEGE? 17 A. Yes. Yeah, it's just initials. It's an 18 ISC or heeding company. 19 O. How long has that holding company been around. 20 If you taw? 21 A. Since -- I think it was developed when I 22 came with the airplane • 2001. 23 O. Whose idea was it for that to come about - was 24 it yours? Was it his? 25 A. On, no, no, somewhere -- It wasn't mine. 8 1 form was 2001? 2 A. That's Correct, yeah. 3 O. You didn't meet him before that. 4 A. I had met him. He was a -- He was an 5 associate of my previous boss. 6 Q. Who's that? 7 A. Mr. Wexner. 8 O. Leslie Wexner? 9 A. Yes. 10 O. How do you know Leslie Wexner? 11 A. I woiked for Limited Stores for 12 years. 12 O. Doing what? 13 A. Essentially the same thing - aircraft 14 maintenance for their corporate flight department and 15 flight engineering on the 727. 16 Q. How many aircraft did Leslie Wexner have? 17 A. Well none that I know that he had 18 personally, but the corporation had - the flight 19 department operated • we had three Gulfstreams, two 20 Hawkers, and a 727. 21 O. What was the name of his corporation that 22 maintained the aircraft? 23 A. For Limited Stores? 24 O. Yes. 25 A. It was just It was called Limited - 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Ofas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutions.com • • • 3501.150-002 Page 4 of 92 EFTA_00068796 EFTA01247024 Larry Eugene Morrison - Volume I October 6, 2009 • • 9 1 Limited Flight Department. 2 O. And do you know him personally then - Leslie 3 Wexner? 4 A. Yeah. I had met him. of course, you know. I met him. I used to do aircraft completions for 6 him, so which would involve personal meetings. 7 O. When did you first meet Leslie Wexner? A. 1988 was when I hired on, so I don't 9 remember the month. 10 O. How did you gel that fob? 11 A. Through word of mouth and, you know. I 12 worked • I lived in - been in aviation for years in 13 Columbus. 14 O. Well, I mean. Leslie Wexners an important 15 person, right? I mean, he -- 16 A. Correct. 17 MR. GOLDBERGER: Form. 18 BY MR. EDWARDS: 19 O. He's somebody who owns my understanding - 20 Limited, Victoria's Secret? 21 A. Well, he doesn't own them. He's Chairman. 22 you know. 23 O. Chairman of -- 24 A. Yeah. He doesn't personally own it. Its 25 a publicly held company. 2 3 4 5 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 11 O. Yes. A. Aircraft technician. O. Which entails what? A. Maintenance of any or all of the aircraft operated by the flight department and some flight mechanic duties. O. What kind or airplanes? A. Gulfstreams, Hawkers. O. How big is the Gulfstrearn? A. Fifteen passenger - 15 to 17. (Mr. Goldberger exited.) BY MR. EDWARDS: O. What did Wexner use the Gullstream for? A. They were division airplanes, mostly. O. And the other airplane you named • what did he use that for? A. Same, same. O. Any idea why he had two planes? A. Well, I mean, yeah, we used them - they're a tool. It wasn't tam. II was a large Fortune 500 company. They use them as tools to You know, Limited has control over 60 percent of their manufacturing processes, plus, you know, what, 1200 stores, or whatever, throughout all their divisions. I mean, when you say *Limited.' its not 1 2 3 4 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 10 O. Where were you prior to any involvement with Leslie Wexner? A. I worked for Red Roof Inn True Sports Flight Department. O. How did that position lead you to Leslie Wexner? A. Well, it was always known that Limited Flight Department was one of the best jobs in Columbus and, actually, several other people that were already there knew me from previous jobs and education - we went through aircraft mechanic, or A&P school, together - so when the position became available they pointed to me and - absolutely. It was a fine organization. O. So did Mr. Wexner approach you or did you apply to him or how did that work? A. Oh, no, no, no. It's -- No. He wouldn't be involved in that type of activity. You apply to H.R, and you interview with the Director of Operations or the Chief Pilot. You know. he w0ukInt O. So you start with Wexner in 1988. A. Yes. O. What do you do for him then? A. What ced I do for him? 12 1 just Limited, its Victoria's Secret and it was 2 Express and Lemers and Henn Bendel's and all of 3 that back then. so. I mean -- 4 O. So - s A. we moved a lot of passengers to keep 6 those stores for the retail business. 7 O. And by 'passengers,' do you also mean clie-is of his? 9 A. That I don't know. No. Mostly we lust 10 dealt with upper echelon, you know, people in the 11 retail businesses from -- 12 O. Such as whom? 13 (Mr. Goldberger entered.) 14 A. Can't even remember names, but it would be 15 We would take buyers to Europe in the spring and 16 fall. They would buy samples and bring them back to 17 analyze for marketing. We would hire -- We would — 18 Division heads, when they would do store shops and. 19 Real Estate, we take Real Estate out when they were 20 looking for new real estate. 21 O. While you were working back in BI3- Well, 22 how long overall did you work with Leslie Wexner and/or 21 his companies? 24 A. Well, '88 through when I came hero in 25 January of '01. • 0 ESQUJ.0.4E .1 CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 Page 5 of 92 EFTA_00068797 EFTA01247025 Larry Eugene Morrison - Volume I October 6, 2009 13 1 O. Why the change? 2 A. It offered an opportunity -- Well, one was 3 I enjoyed flying - and the 727 was being replaced by 4 a BBJ, which is a two-man airplane. not a three-man 5 airplane three-pilot airplane - and it gave me the 6 opportunity to become a Director of Maintenance. and 7 it was a challenge. You know, bringing upstarting 8 an airliner on a private ticket or a VIP ticket is 9 really challenging, and I enjoy the challenge of 10 world% arid developing the program and stud. 11 O. Well, my understanding. Leslie Wexner Is 12 generally - he's in Ohio. tight? 13 A. No, he's got other places. I mean -- No. 14 he's like anyone, he's - in hiS Category - he's got 15 multiple homes and — 16 O. Well, when you would maintain his aircraft, 17 would that be in Ohio -- 18 A. Yes. We were based -- 19 O. or elsewhere? 20 A. We were based at Lane Aviation. 21 MR. REINHART: HOld on one second. You 22 have to let him finish asking the question 23 before you answer. 24 THE WITNESS: Okay. I'm sorry. 25 BY MR. EDWARDS: 15 I aircraft. I mean, whatever a takes to keep a 2 corporate flight department operating. 3 O. Did you know back then of his relationship. it 4 any. with Jeffrey Epstein? k Not immediately. no. 6 O. When is the first time that you know of a 7 reputation or a relationship between Wexner and Epstein' e A. Would have had to probably be around maybe 9 '98,'99. 10 O. How do you become aware that they know ono 11 another? 12 A. Because Jeffrey. every one That's when 13 I became a flight engineer on the Boeing. and every 14 once in a while Jeffrey would ride on the Boeing. 15 that's all • that's all I knew. 16 O. How ckd 4 come about that he would nde on 17 Wexners Boeing? le A. They were business associates, I think. 19 O. As far as you knOw, they were business 20 associates. 21 A. Right. 22 O. Did you understand the business retationsh-p 23 between the two? 21 A. Web, I believe it's pubic knowledge 25 that, I think, Jeffrey managed Mr. some of Mr. 14 1 O. I'm sorry, have you ever had your deposition 2 taken before? 3 A. No. 4 O. You definitely never had your deposition taken before while somebody else is trying to eat at the same 6 time they're trying to ask the questions - that's very 7 bizarre. 8 A. Yes. yes. 9 O. I meant to do this before I got here. But, 10 regardless. Ill wail until you finish your answer before 11 I ask my next question; you do the same thing. 'Uh.huh' 12 or •uh-uh,' they kind of look the same on the record, so 13 try to give us a'yes' or to' or something we 14 understand. 15 A. Alright. 16 O. II I ask a question that was a bad question or 17 something you don't understand ive asked bad questions 18 before • say. 'I don't get it' I'll ask a better 19 question. 20 A. Okay. 21 O. You were working with Leslie Wexner. You got 22 the job there starting in 1988. On a day-to-day basis. 23 what would you be doing? 21 A. Maintenance, aircraft maintenance, 25 tracking of aircraft maintenance. cleaning of 16 1 Wexnees funds. 2 O. Is that something that Mr. Wexner told you? 3 A. No. 4 O. Is that something that somebody of Mr. 5 Wexner's organization would have told you? 6 A. No. 7 O. Is that something that Jeffrey Epstein told a you? 9 A. No. 10 O. Is that just reading articles that speculate 11 as to the business relationship between the two or do you 12 got something more for me? 13 A. No, it's just it's speculation and, you 14 know, what I've read. you know. 15 O. I mean, like you say, to me ifs common 16 knowledge -- 17 A. Right. 18 O. But irs only because of what I've road. I 19 don't have a specific person that I could cite to to say 20 that do you? 21 A. Right. No, just - just periodicals. 22 O. What's your understanding of the persona 23 relationship, if any, between Wexner and Epstein' 24 MR. GOLDBERGER: Form. 25 A. Don't know. 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com • • • 3501.150-002 Page 6 of 92 EFrA_00068798 EFTA01247026 -19 Larry Eugene Morrison - Volume I October 6, 2009 • • 17 1 O. Did you ever know of a time -- And I may be 2 asking a question that would just be completely outside 3 of your knowledge. so lot me back up. 4 Have you ever stayed at Leslie Wexner's house? A. No. 6 O. Do you know where his house is? 7 A. Yes. 8 Q. Do you know what the address is in Ohio? 9 A. ND. I just know the City. 10 O. Do you know who he lives with? 11 A. Yes. 12 O. Who is that? 13 A. His wife and Children. 14 O. What's his wile's namo? 15 A. Abigail. 16 O. Abigail Wexner. and he has three or four 17 daughters. ngM? 18 A. No. He's got a son. M . and two 19 daughters. I think. 20 O. A son and two daughters. 21 A. I don't know. See, that was back in 2001. 22 I don't know what they have - it they have more kids 23 now. 24 O. Okay. Did you ever hew any information that 25 he was homosexual? 19 1 O. Have you spoken personally with Mr. Wexner? 2 A. On bus:Mess issues, yes. 3 O. Business Issues related to your work on his 4 airplanes? A. Correct. 6 O. Have you spoken to him on any other Issues 7 that don't involve business relationships with his e airplanes? 9 A. No. 10 O. Because you're hired basically for that 11 purpose. so that's kind of how you deal with him. 12 A. Yeah. Ifs I'm an employee and he's my 13 employer and I only deal with him, you know. en 14 issues that involve maintenance. 15 O. I think I probably knOw the answer to the next 16 question, but just in case I don't, do you knOw any of 17 his personal friends people that he would hang out with l8 on a social level - being Mr. Wexner? 19 A. Through my business ties, yes. yes 20 O. Who's that? 21 A. I'm hying to remember - You have to 22 remember its been several years. 23 O. Right. 24 A. He was friends with the Tuckermans. 25 O. What's Mr. Tuckerman or Ms. Tuckennan's names? 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 18 A. No. O. Being Mr. Wexner. A. No. O. My Indication to you that he may be homosexual or bisexual? A. Absolutely not. O. Have you heard any Information that he and Mr. Epstein were involved sexually with one another? A. Oh. no. no. O. Would that surprise you? A. Absolutely. O. And Mars only because you know him and you know Mr. Wexner and you don't see the two together. A. Correct. MR. GOLDBERGER: Form. A. Weil — A. Go ahead. MR. REINHART: If you need to answer, answer the question. A. Yeah. No. I saw him with Sharon, which was his previous girlfriend before he met Abigail. O. Right. A. No. There was never any hint or anything Mat I would even conceive that. 20 1 A. Ms. - I cant. I always addressed them 2 by their proper name. 3 O. Do you know what they do? 4 A. They owned an optical company - opticians. s They were high school friends from Mr. Wieners high 6 school days. 7 O. In Ohio or New York? 8 A. He went to high school in Bexley. 9 O. Bexley. Ohio. 10 HaS he ever discussed with you how 11 longstanding the relationship is between himself and Mr. 112 Epstein? 3 MR. GOLDBERGER: Form. 14 A. I don't understand. Can you rephrase il? 15 O. Wet you know that at some point in time 16 You started working with him in 1988. The first time. 17 according to my notes. that you became aware Mat he was 18 friends or acquaintances with Mr. Epstein was V8 - 19 almost ten years later. 20 A. Right. 21 O. After you became aware that Mere was that 22 relationship. whether business or otherwise, did he ever 23 speak to you about how long he had known Mr. Epstein? 24 A. Oh. no. no. 25 O. So as far as you were concerned. 1998. when • 0 ESQUIRE Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutiOnS.COrn 3501.150-002 Page 7 of 92 CONFIDENTIAL EFrA_00068799 EFTA01247027 Larry Eugene Morrison - Volume I October 6, 2009 21 1 you found out there was a relationship with Epstein. it 2 could have very well started then. 3 A. Yes. 4 O. Aside from aircraft technician and taking care 5 of Mr. Wexner's aircraft back in the '80s and. I guess. 6 early '90s, did you have any other personal involvement 7 with him? 8 A. Just on aircraft completions. 9 O. And when you would speak with him, would that 10 be over the telephone, at the airport, at his private -- 11 A. It would usually be al the corporate 12 office. 13 O. Al the corporate office? 14 A. At he corporate office. 15 O. Can you tell me the address for his corporate 16 CAM? 17 A. No, I can't 18 O. If I requested that from your attorney, would 19 you be able to got that information? 20 A. Well, I mean, I imagine it's public 21 knowledge • wherever - it's at the Limited. 22 O. And that's where you would meet him • at the 23 Limited? 24 A. Yeah. 25 O. And how often was • you know, I know that 23 1 O. Who were some of the pilots? 2 A. Tim Staley. Jim Taylor. They've had some 3 tumover too. I don't know who all is still there 4 because retail is down. 5 O. Was Larry Visoski a pilot used by Leslie 6 Wexner at any time? 7 A No. 8 O. How about David Rodgers? 9 A. No. 10 O. Are those names you're familiar with? 11 A. Yes. 12 O. Those are names you're familiar with how? 13 A. I flew with them when I was flying for Mr. 14 Epstein. 15 O. So there's no real, other than yourself -- 16 Well, tell me if I'm wrong: I understand that you did 17 some work for Mr. Wexner related to his aircraft and you 18 did some work for Mr. Epstein. which we haven't yet got 19 to. but you did some work for him too. Are there any 20 other people that have that type of relationship with 21 both pathos? 22 A. No. I'm sorry, resay that. 23 O. Okay. You've already told us that you were 24 the aircraft technician for Mr. Wexner. 25 A. One of them. One of several, yes. 22 1 we're talking about 15. 20 years ago - how often was Mr. 2 Wexner personally al that location at the Limited 3 offices? 4 A. I have no idea. O. But any time you needed to talk to him. that's 6 where he would be? 7 A. Yeah, and I usually went to Charlie 8 Hinson. 9 O. Who's Charlie Hinson? 10 A. He was the president of the stores. He 11 basically was my go-between for these aircraft 12 completions for the design. 13 O. And you mentioned the Gullstream as an 14 aircraft Did you also serve as a technician for other 15 aircrefts that were owned by Mr. Wexner? 16 A. Right but not Mr. Wexner. They're owned 17 or operated by Limited Stores. 18 O. Limited Stores? 19 A. Right. Yes. 20 O. What did you do for them? 21 A. Same maintenance. 22 O. Did you ever fly in them? 23 A. On the Gullstreams in the early days we 24 used flight mechanics, especially on international 25 flights. 24 1 O. One of them. Then you also have knowledge 2 about Mi. Epstein and some relationship with Mr. Epstein. 3 A. Correct. 4 O. Are there any other pilots. aircraft 5 technicians, people like that that you know of to have a 6 relationship with both Mr. Wexner and Epstein? 7 A. No. no. 8 O. Do you knew how Mr. Wexner met Mr. Epstein? 9 A. No. 10 O. How long - if you started in 1988 how long 11 did you slay with Mr. Wexner and/or The Limited? 12 A. January of YR. 13 O. Why did you stop? 14 A. Because what we were talking before, you 15 know, I wanted to continue flying. They bought a 16 BBJ. which is a two-pilot aircraft, and I wanted to 17 continue flying. Mr. Epstein bought the 727 and 18 offered me a position to continue flying and, you 19 know, basically sot up the airplane for his flight 20 department because they hadn't had any previous large 21 aircraft experience. 22 O. I missed something. It wasn't your fault, it 23 was mine. 24 The Gulfstream that you were talking about. 25 did you used to fly that as well as being a flight ESQUIRE O n rtfaaa CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com • • • 3501.150-002 Page 8 of 92 EFTA_00068800 EFTA01247028 Larry Eugene Morrison - Volume I October 6, 2009 • • 25 1 technician? 2 A. No, no. 3 O. Okay. 4 A. You don't have to have a flight a • pilots certificate to be a professional flight 6 engineer. I've got a turbo a (fight engineer turbo 7 jet rating, but you don't have to have a commercial 8 ticket as long as you • the FAA recognizes your heavy 9 aircraft maintenance experience. 10 O. So you're saying that if the FM recognizes 11 your heavy maintenance experience, I'm assuming that 12 means that you understand the ins and outs of airplanes 13 and you can work on them. 14 A. On heavy high performance aircraft, yes. 15 O. Then you can also fly them? 16 A. Sideways as a flight engineer. 17 O. Explain. 3.43 A. On the older generation airliners there 19 was three pilots - there's a captain, a first 20 officer, and then the flight engineer is the 21 gentleman that sits sideways and maintains all the 22 systems. 23 O. When you say. "sits sideways: okay, I have 24 a — 25 A. Literally, you're physically sideways in 27 1 O. Do you know why Epstein chose to buy that 2 particular 727 rather than one of the other million 727s 3 that are made? 4 MR. GOLDBERGER: Form. 5 A. Because it was probably the finest one out 6 the 7 O. Why? 8 A. -- in all honesty. It's got a fully Paged 9 STC interior with EMS cockpt. and Limited's 10 reputation on the way that we maintained our aircraft 11 - Its the best one out there. 12 O. Describe for me the interior • I'm not talking 13 about the Epstein days, we're talking about the Wexner 14 days describe for me the interior of the aircraft, and 15 keep in mind that I've only been on a commercial aircraft 16 where you donl see the pilots. there's a door, and then 17 everybody, you know, there's just a bunch of seats where 18 everybody sits there. 19 A. Correct. Right. 20 The aircraft You enter the airplane, 21 it's got forward air slays. which most 727's don't, 22 so you enter the forward door on the left-hand side. 23 the forward entryway vestibule, and there's a door on 24 the left, which leads to the cockpit, and then 25 there's a door on the right which leads aft to the 26 1 the cockpit 2 O. So you're not looking at the people that were 3 flying on the plane and you're not looking at the pilots. 4 yottre actually literally sitting sideways. S A. I sit sideways at a panel, yes. 6 O. What's your job? 7 A. Maintain all the aircraft systems - the • hydraulffs, fuel management, pressurization. 9 environmental controls. 10 O. That's not done by the pilots. 11 A. Now. 12 O. But if you've done that long enough and FAA is 13 aware of your credentials in that respect, then you also 14 could be credentlaled to be a pilot as well? 15 A. Well, sure, yeah, yeah. If that's a 16 career choice you wish to take. 17 O. And was that? 18 A. No, no. I was perfectly satisfied with my 19 position as a flight engineer and Director of 20 Maintenance. 21 O. What year did you say Epstein bought the 727 22 that was once owned by Wexner? 23 A. I don't know when the actual transition 24 took place, but when I came - shortly around the 25 period that I came on board In . January of bl. 28 1 forward salon. 2 O. What's the forward salon? Sorry. 3 A. Forward seating area. 4 O. And is it set up basically the way that I'm 5 picking it - in that there are 25 or 26 rows and they're 6 numbered A through E? 1 A. No. no. its a corporate configuration. 8 O. Which means nothing to me, so help me. 9 A. Picture a 600-mile an hour Winnebago. I 10 mean, its got conference tables and divans and large 11 first class seating. 12 O. Any various dividers throughout -- 13 A. Yes. 14 O. -- to where there's a VIP room in the back or 15 anything like that? 16 A. It's compartmentized (sic), yes. 17 O. In what way? Descnbe it as specifically as 18 you can. 19 A. There's a forward salon, a mid galley 20 the galley's in the mid - an aft • an aft salon, 21 which is and then the aft stale room. 22 O. Who designed that plane? 23 A. I can't remember who the actual designer 24 was. It was a Page interior, though. Page Avjet did 25 the installation. • 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-00i Page 9 of 92 EFFA_00068801 EFTA01247029 Larry Eugene Morrison - Volume I October 6, 2009 29 1 0. Who directed the design ot that plane? 2 A. It would have been Mr. Wexner. I mean, it 3 was -- The layout has not changed. 4 0. The layout has not changed; when you say 5 that, you mean 'from the time that I first got in it and 6 I was under the guise of 'under the employment of 7 Wexner to the time I've been on it since with Epstein. Es the configuration is the same' 9 A. Essentially, yes. We removed one chair 10 and one small table that was an annoyance and that's 11 it, but it's identical to what The Limited used. 12 0. Are there any blocked off areas to where if 13 you're standing in the middle of the plane you can't see 14 certain areas of the plane" 15 A. There are pocket bulkheads. Yeah. there's 16 dividers between the sections. 17 O. How big aro these dividers and where are they? 18 A. Well, there's a divider - the forward 19 door, I told you, on the salon, then there's a pocket 20 door on the forward side of the galley, a pocket door 21 on the aft side of the galley, there's a pocket door 22 between the aft salon and the office, and then 23 there's another pocket door between the office and 24 Me state room. 25 0. Have you been on other 7275 before that are 2 3 4 5 6 9 to 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 31 because obviously there's a lot - there's not that many -- A. Privately owned 7275. but this is As a matter of fact The Limilects current BBJ has a very similar floor plan. 0. As Trump's? A. No, as the as our 727. 0. Who's 'our'? A. Mr. Epstein's. They didn't change a lot. It's - O. Well, I thought that you had told me that the 727 that was once owned by Wexner is the 727 that's owned by Epstein. A. It is, but what I'm saying is even their current airplane has the same layout - the BBJ. They put the same floor plane in the more modern airplane 0. Well, they dam have 10 put it there. It was already there. nght? A. No, no. no. When you buy these aircraft - even a Gullstream when you buy them its just a green hull, there's nothing in them, and you can customize your interior. 0. I'm sony, we're miscanmunicating so.n8l to and I m sure its on me. MR. GOLDBERGER: Yes. it is 1 3 4 5 6 9 10 11. 12 13 14 15 16 17 16 19 20 21 22 23 24 25 30 commercial airliners privately owned? A. Yes, yes. O. Have you noticed similar configurations to where there aro this many dividing doors or is this one that has more so than you've seen in the past? A. No. no, this is pretty atypical (sic). O. It's pretty atypical? A. It's typical. 0. It's pretty typical? A. Yes. yes. 0. So what other airplanes - 727s, or other major airplanes - have you been on that have these types of dividers? A. Trump. 0. Trump's airplane? A Yes. 0. Why were you on Trump's airplane? A. Well, I know the crew and, you know, this Is a small-knit community. There's not very many of them out there, so everybody in this world knows one another to help one another out as far as — 0. By 'there' -- A. information-wise and stuff. Q. By hhere aren't that many of these people out there' you don't mean there's not that many people • 3 2 MR. EDWARDS: And l -m taking the blame for rght away. 3 MR. REINHART: Take that. Ed. 4 MR. EDWARDS: Alright 5 BY MR. EDWARDS: 6 0. My understanding - and please correct me when 7 I'm wrong. because I knew I am - Wexner has this 727 and 8 he designs it in a certain way. 9 A. Uti-huh. OA. YAnd ee.then you come to work for Epstein-. 11 12 who buys the same 727. Your testimony, as 13 I'm understanding It, Is: It's basically the same 800r 14 plan as Wexners floor plan. To me, it should be the 15 exact same because he bought the same plane. 16 A. No. he -- You're misunderstanding. 17 0. I figured. 18 A What I was stating is You were I was 19 answering the question in regards to, 'Is this 20 unusual to have thiS many compartments and closed 21 doors and bulkheads and things?' 22 What I was trying to state was: NO, its 23 not unusual - because The Limited even Mod the 24 Floor plan so wee in their old airplane that they 25 sold to Mr. Epstein. They duplicated it in their new ESQUIRE Oa Altandwrall•Canpa CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com • • • 3501.150-002 Page 10 of 92 EFTA_00068802 EFTA01247030 Larry Eugene Morrison - Volume I October 6, 2009 • • 33 1 airplane - see what I'm saying? That's all I was -- 2 O. So they didn't keep the floor plan. They 3 actually took it out and they restructured the floor plan 4 to basically match that old floor plan. 5 A. Well. no. When you -• When you buy a 6 Boeing business jet — 7 Cy Yes. A. it comes with nothing inside. It's a 9 tube. Nothing's in there. You design • have 10 designers design your interior and then a fabricator 11 or a facility such as Page Avjet to install this 12 Interior. 13 O. Right. 14 A. What I was just trying to state was that 15 The Limited liked their old floor plan in the old 16 airplane so well - it worked so well for them - that 17 they duplicated it and had that same interior 18 installed in the new aircraft • same floor plan 19 installed on the new plan. 20 O. So Epstein didn1 buy the exact same plane. 21 He bought the same type of plane. 22 A. Well, more modem. He bought a 737. 23 right. 24 O. Got it. 25 A. Right. 35 1 had a very identical or very like floor plan 2 installed in the new airplane. 3 O. Coln 4 A. Okay? Sorry, it's a strange business. 5 It's — 6 O. Tell me if I'm right: Mr. Wexner had a plane 7 that had a floor plan that apparently appealed to Mr. 8 Epstein, so Mr. Epstein bought that plane. 9 A. Correct. 10 O. Mr. Wexner also liked that plane that he had 11 just sold to Mr. Epstein, so he built in a floor plan 12 very similar to the one he just sold to Mr. Epstein 13 A. In his new aircraft. 14 O. Brand new plane. 15 A. Correct. 16 O. Got it. We're on the same page now. 17 A. Alright. 18 O. Took us a while to get there. 19 A. Yeah, sorry. 20 O. I think it was my fault, honestly, but 21 alright? 22 A. It's an unusual process it you haven't 23 been around corporate airplanes. 24 O. I didn't realize that Mr. Wexner had a new 25 plane. 1 2 3 4 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 34 MR. REINHART: Hold on. BY MR. EDWARDS: 0. Totally understand now. MR. REINHART: Can you clarify - Mr. Epstein or Mr. Wexner? BY MR. EDWARDS: O. Mr. Epstein bought not Mr. Wexner's plane. A. No. O. He bought the same type of plane that Mr. Wexner had and modeled the floor plan -- A. No. O. -- the same way that Mr. Wexner had it. A. That is not correct. O. He bought, actually. Mr. Epstein -- MR. REINHART: Hold on. Distinguish -- Use names so we're very clear when you're talking about Mr. Epstein and Mr. Wexner. okay? A. Mr. Epstein bought Mr. Wexner's 727. O. Okay. A. The actual airplane - bought it from him. Q. Which has a floor plan already in it. A. That we just discussed. O. Alright. The floor plan's in the plane. A. Right. Mr. Wexner replaced the airplane that Mr. Epstein bought with a new airplane and he 36 1 A. Yes. 2 O. Thars where I had a problem. 3 How many times have you been on Mr. Wexner's 4 airplane? 5 A. The new? 6 MR. REINHART: Clarify which one you're 7 talking abaft. 8 BY MR. EDWARDS: 9 O. Before you ever met Mr. Epstein. 10 A. I can't say. I mean. over the years? 11 O. Numerous times? 12 A. Oh, I was his flight engineer. You mean 13 when I was still employed by him? 14 O. Yes. 15 A. Yes. I was the flight engineer. I 16 don't -- 17 O. So as a flight engineer, every time the plane 18 leaves the ground, do you leave the ground with it? 19 A. No. We had another engineer also. 20 O. So what percentage of times do you leave the 21 ground in the airplane when the plane leaves the ground? 22 A. For who? 23 O. For Mr. Wexner. 24 A. Probably one-third of the time. because I 25 was also the lead technician, so 1 had • 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutIons.com 3501.150-002 Page 11 of 92 EFTA_00068803 EFTA01247031 Larry Eugene Morrison - Volume I October 6, 2009 37 1 responsibilities in the hangar. whereas the other 2 engineer was a full time engineer 3 O. And given the partitions that you've descnbed 4 in this airplane, are you able to see what's going on 5 behind the doors of the various partitions of the 6 airplane? 7 A. If the doors aro open or closed? 8 O. Closed. 9 A. No. 10 O. Do you have any idea what's taking place in 11 there? 12 A. No. 13 MR. GOLDBERGER: Form. 14 8Y MR. EDWARDS: 15 O. When you're on the plane with Mr. Wexner. was 16 there a time that he had Well, let me put it this way: 17 When anybody is a passenger on any of these private 18 planes, should there be logs of the names of the 19 passengers on the planes? 20 A. Not required, no. 21 O. Are you ever specifically instructed not to 22 record the names? 23 A. That wasn't part of my duties. That 24 wasn't an engineers task, but -- 25 O. Do you -- 3 9 1 A. There is normally a passenger manifest. yes. 3 O. Who creates the manifest? 4 A. Probably dispatch. 5 O. Dispatch? 6 A. At Limited. 7 O. Do you know who that is? 8 MR. REINHART: Can you give a time frame? 9 Do you mean currently or back when he worked 10 mere? It MR. EDWARDS: I'm talking about back when 12 he worked there. 13 BY MR. EDWARDS: 14 O. Do you know who that was at dispatch? is A. That would have been Diane Williams. 16 0. Who does Diane Williams work for? 17 A. Limited Flight Department. 18 O. Who does she report to? 19 A. Tim Staley. 20 0. Who's Tim Staley? 21 A. Director of Operations. 22 O. For who? 23 A. Limited Flight Department. 24 O. What does he then do with that Information? 25 A. I don't know. I don't know. 2 38 1 A. — no. not that I'm aware of. 2 O. Who is assigned the duty of reporting the 3 names of the people who are going to be transported on 4 the airplanes? 5 MR. GOLDBERGER: Form. 6 A. Captain. 7 O. So have you ever been privy to conversations 8 where the captain is told by Mr. Wexner to record all of 9 the names of the people that are going to be on the 10 airplane' 11 A. Can't say. 12 O. Sometimes? 13 A. I can't You know, I can't say. I can't 14 remember what our policies were at the time. 15 O. I'm not asking policies. I'm asking: Have 16 you ever been around when the plot was being instructed 17 by Mr. Wexner • back in the late '80s, early '90s - to 18 make sure that you record who's on this aircraft? 19 A. I never heard Mr. Wexner address that, no. 20 O. I moan. God forbid the airplane crashes, you 21 would tike to know who's the on the airplane, right? 22 MR. GOLDBERGER: Form. 23 A: Yes. 24 O. Is there any way to determine who's on each 25 particular night in case anything happens? 40 O. Have you ever talked to Tim Staley? 2 A. From Yes, yes. 3 O. And what do you talk to him about? 4 A. Oh, we're - we're friends. We worked 5 together for years. I mean, I haven't talked to him 6 since the holidays. 7 O. Do you know where he is now? a A. To the best of my knowledge, stilt 9 Director of Operations at Limited. 10 0. Do you have a number for him? 11 A. Yes. 12 0. Can I have the number, please? 13 A. It's 14 0. Is that a work number? 15 A. That's the Flight Department. 16 O. That's the best number to reach him at? 1? A. Yes. 18 0. If I'm going to call him, that's the number I 19 call? 20 A. Correct. 21 0. And was he always in charge of flight 22 directions? 23 A. No. he was previously Chief Pilot. 24 G. He was previously Chief Pilot for Limited? 25 A. Same, yes. 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 wvatesquIresolutions.com • • • 3501.150-002 Page 12 of 92 EFEk_00068804 EFTA01247032 Larry Eugene Morrison - Volume I October 6, 2009 • • 41 1 0. And he was promoted, I suppose, to Flight 2 Director? 3 A. Director of Operations. It's the 4 department crew. Most small departments don't have S &rectors until they start to grow. 6 Cr. And when he was Chief Pilot were you 7 affiliated with the Wexner organization? 8 A. Yes, I was a maintenance technician. 9 O. And when you say somebody keeps flight logs. 10 Is it always Tim -- is his name Tim Staley? 11 A. Yes. 12 O. — Is It always Tm Staley who does that? 13 0. No. I don't knOw where they go. honestly. 14 and the system may have changed. 15 O. Okay. Are you -- 26 A. I've been gone since -- 17 O. Are you aware of any FAA policies to where 18 they need to know who's on the aircraft whenever It talks 19 off? 20 A. Not under Part 91 Operations, there is 21 not. 22 O. Part what? 23 A. Pan 91. 24 O. What does Part 91 say, as far as you know? 25 A. It's basically souls on board when you 43 1 international. The only time we do international 2 would be for Customs and Immigration. 3 O. So if its an international flight -- 4 A. For Customs and Immigration • for coming 5 and leaving the country. 6 O. then they require that names of 7 individuals — 8 A. It would be names, passports, that kind of 9 stuff • normal. 10 O. Did you ever do any international flights t.1 while employed by The Limited, Victoria's Secret, the 12 whole Wexner group? 13 A. Yes. 14 O. How many? 15 A. No way of knowing. I mean. rm • can't 16 say. It's, like I say, years. but 17 O. What years would you done its? 18 A. Started flying as a flight mechanic in 19 '89, and then started flying the Boeing in '99, so • 20 to '01, so '89 to '01, basically. 21 (Mr. Goldberger exited.) 22 BY MR. EDWARDS: 23 O. SO '89 to '01, if I wanted all of the flight 24 logs, who would I request those from - Tim Staley? 25 A. Don't know. I don't know who -- 1 2 3 4 5 6 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 42 file a flight plan - that's the only thing you're required to do. When you file your flight plan you file souls on board. O. What does that mean, 'souls on board'? A. In other words, living bodies on board. In other words, if you have • so if there's an accident and you have four and you're transporting a cadaver, that they go to the accident scene and don't find five bodies - think there were live fatalities. 0. So it's your understanding from what you need to report are, 'I have five people on board.' A. Correct, and that's for the flight plan. O. So there's no reason to say that, 'I have Joe Schmo on board? A. Not under Part 91, no. 0. That's doing something over and above. A. That's correct. O. You are aware, though, that there are certain flight plans where they actually name individuals that are on the airplane? MR. GOLDBERGER: Form. A. No. 0. I mean, you've seen that belore. MR. GOLDBERGER: Form. A, No, nOl on NO plans, no - unless it's 44 1 O. What does Tim Staley do alter he maintains 2 these records? 3 A. I don't know. 4 O. He's never told you what he does? 5 A. No. 6 O. Certainly theyre kept on file somewhere, 7 right? 6 A. I would assume. 9 O. What's the name of the company that owns the 10 airplanes? I know its affiliated with Wexner and all 11 that, but what's the name of the company? 12 A. Well, there were several companies. I 13 mean, the way corporate aviation fkght departments 14 are set up. [helm under holdings companies. 15 O. I'll go with al of them. 16 A. Well. I don't know. They change. They 17 change sometimes by the year, sometimes -- I have no 18 Idea what they're under now. 19 O. What were they under backln'88 A. It was like -- 21 O. to the best of your memory? 22 A. They change. I mean, every time we got a 23 new aircraft, or whatever. they changed. They were 24 kke Northeast Holding, Southwest Holding, LLC • 25 Wilmington, Delaware, companies, which is standard • ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutlons.com 3501.150-002 Page 13 of 92 EFT,C00068805 EFTA01247033 Larry Eugene Morrison - Volume I October 6, 2009 45 1 for these, you know. 2 O. Did Leslie Wexner ever tell you that he 3 allowed Jeffrey Epstein to serve in some sort of 4 capacity, representative capacity, for any of these 5 companies? 6 A. No. He would never say that to me anyways. no. 0. What's the first time you ever saw Jeffrey 9 Epstein? to A. Can't say. I'm not sure. 11 O. I think you saw him before you started working 12 for him or with him? 13 A. Oh. yeah, that's -- Where I first saw him 14 was when I flew him on The Limited 727. 15 0. What year do you think that was? 16 A. It would have had to have been 17 0. Talking late '80s. early '90s? 18 A. Late '90s. 19 O. Late '90s? 20 A. Yeah, probably - mid to late '90s. 21 0. Well, I mean, it you're taken over with 22 Jeffrey Epstein In, what, 2001 - 23 A. Correct. 24 0. - then you're talking late '90s is the first 25 time you see him? 47 A. They were -- They were generated, but I 2 don't know, you know, why - what the particular 1 reasoning was fork. 4 0. Do you know it Terry (gc) Staley would have 5 been the one to forward those flight logs to the FAA? 6 A. No, no, no. I -• They wore all lust tor 7 business use • not forwarded to the FAA. 8 0. Okay. How -- 9 A. The FAA doesn't care about flight logs. 10 0. How OW the FAA monitor when trial piano took 11 off? 12 A. Flight plans. 11 0. And wash your understanding that when the 14 plane took off, the FAA was unaware as to who was ever on is it? 16 A. Pretty much, yeah. They don't care about 17 names. When you file flight plate watt the flight 18 service station or via electronically, all they care 19 about is souls on board, contact information. flight 20 routing, things like that. 21 0. Are there time limits as to when the plane is 22 allowed to take off? 23 A. Yeah. usually -- From what point? What do 24 you mean? Time of the day or - 25 0. Yeah. yeah. time of the day. I understand 46 1 A. Well, and I don't know exactly. I 2 can't really say, really. 3 0. t won't hold you to N. his what 4 is. 4 Mid to late '90s, it I wanted the flight logs that have him on it, On the airplane, who would I 6 Subpoena to get those records? 7 A. I have no Idea. 0. Are they turned into the FAA, to the best of 9 your knowledge? 10 A. No, the FM doesn't require them. 11 0. So FM does not get the flight -- Well. what's 12 the point of even keeping these? 13 A. Sometimes I think the IRS I mean, this 14 is on assumption, rm not even sure, but mostly for 15 like IRS tracking ford you have people that have 16 dual homes, dual statehoods. or whatever. 17 (Mr. Goldberger entered.) le MR. GOLDBERGER: Can we take a time outs 19 (Shan break.) 20 (Mr. Pike appeared via telephone to 21 replace Mr. Goldberger.) 22 BY MR. EDWARDS: 23 0. FAA flight logs - do you know why they're 24 generated, how they're generated, 4 they were generated 25 back in the Wexner days? 1 2 3 4 S 6 8 9 10 11. 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 48 that there's some time where if it's too tate they can't take off, right? A. Only where there's a curfew on the airport - not all airports, no. No. airplanes can fly any time unless that airport has a noise curlew or something, yeah. 0. Did you ever know of Wexner's plane to take off after ten o'clock p.m.? A. Yes. Yeah. 0. Were you ever on that plane when it did? A. Probably. yeah, yeah. O. Were you ever on that plane when there were gds on the plane? A. Describe -- Define 'girls.' On the Wexner airplane? 0. Yes. A. There would be ladies and his daughters. I mean -- 0. Other than family members. A. There would be business associates. If you're taring young women, yes, business associates from the **visions. 0. Have you ever been on the plane when there were girlfriends of Leslie Wexner? A. Only when Abigail • before his • became 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com • • • 3501.150-002 Page 14 of 92 EFTA_00068806 EFTA01247034 Larry Eugene Morrison - Volume I October 6, 2009 • • 49 1 his bride. yes. 2 O. How about after -- 3 A. I moan 4 O. she became his -- 5 A. it was Abigail. She was the only 6 girlfriend. 7 O. How about after Abigail? e A. No. 9 O. Have you ever soon sox or sex-related 10 instances occur on Leslie Wexner's airplane? 11 A. Absolutely not. We didn't even have 12 playing cards. He looked at the aircraft as a 13 business - a flying business office. 14 O. When you say 'playing cards' what do you 15 mean? 16 A. Playing. you know. to -- 17 O. Oh, playing cards. 18 A. Yes, playing cards. 19 O. So every time that you were on Leslie Wexner's 20 airplane, it was used strictly for business? 21 A. Well, I don't know if it was used strictly 22 for business, but there was no. you know, it was -- I 23 don't know what the purpose of the actual trip was. 24 but never saw, you know, anything. you know. 25 O. Was there over a time when you were -- 5 1 1 O. Yes, with you on it. 2 A. I can't — I canl say. 3 O. Well, where do you remember going in it? 4 A. Well, we would normally go to London, 5 Milan. Fans. I mean, mostly fashion areas and 6 business business areas. O. When you say 'fashion areas,' what do you 8 mean? 9 A. Well, retail. I mean, you know. design 10 for clothing and stuff like that. 11 O. What was the purpose? 12 A. I'm sure it was business. I have no Idea 13 what the actual purpose was. I don't — 14 O. Did you get off the plane? 15 A. Well. of course. 16 O. What did you do there? 17 A. Go to a hotel, eat dinner, wait to find 18 out when you're going to the next place. 19 O. Were you ever on an international flight on 20 one of Mr. Wexner's planes that Jeffrey Epstein was also 21 on? 22 A. I can't say. I can't remember. 23 O. maybe/ 24 A. Possibly. 25 Cl. Do you remember any specific places that 50 1 MR. REINHART: Hold on. Were you 2 finished? 3 BY MR. EDWARDS: 4 O. I thought you wore finished. 5 A. Yeah. I don't tmderstand. I don't 6 understand that question. 7 O. I'm going to clarify. Wore there ever times 8 when you were on the plane and either Leslie Wexner 9 ancVor other individuals went behind these various areas 10 that you could not see into? 11 A. Yes. Yeah. 12 O. Do you know what they were doing in there? 13 A. Probably sleeping. He would go to bed at 14 night on the long trips, okay. 15 O. Arty time that more than one person went in one 16 of these areas that you would not be able to see into? 17 A. Not that I'm aware of, but my exposure to 18 back Mere is not that. you know, is limited. 19 O. How many times did you see Jeffrey Epstein 20 ride that plane with Leslie Wexner? 21 A. Not many, but I can't say exact. 22 O. How many international flights do you remember 23 that plane taking? 24 A. Remember .- The airplane itself taking 25 international? 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 52 Jeffrey Epstein went while on that plane outside the United States? A. I can't remember. No, no. Like I say. I can't even remember it we took f for sure. O. My time that you remember Jeffrey Epstein being on the airplane, do you also remember Moro being girls on the airplane along with Mr. Epstein? A. I can't I can't say. I can't remember. O. When's the first time you remember seeing Jeffrey Epstein? A. Wel, like I say. I don't even remember the year. I can't oven pinpoint down to the year. It was after • some time after I started flying the 727. because that's the only exposure. O. Okay. I'm not going to ask you at all during this deposition to guess. I thought at some point in time you told me you remember seeing Jeffrey Epstein. right? A. Yes. O. In fact, you work for him now. A. Yes. O. So at some point in time you saw him and you saw him for the first time. A. Correct. O. When's the first time you remember Wang horn? ESQUIRE •• Alezbuk•Gall•Camn CONFIDENTIAL Toll Free: Suite 1300 51S East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com 3501.150-002 Page 15 of 92 EFT/C00068807 EFTA01247035 Larry Eugene Morrison - Volume I October 6, 2009 53 It may not be the first time you saw him. When's the 2 first time you remember seeing him? 3 A. '99, somewhere in that area. 4 0. Alright. In '99 were you working for Leslie 5 Wexner or were you working for Jeffrey Epstein? 6 A. Leslie Wexner. 7 Q. And do you remember the context in which you 8 saw Jeffrey Epstein? 9 A. II was a flight. 10 O. What did Leslie Wexner ever tell you in terms 11 of who Jeffrey Epstein was? 12 A. Never told me anything who Jeffrey Epstein 13 was. 14 0. Did you ever ask? 15 A. No. 16 0. Did you ever ask back in 1999 when you saw 17 this guy,1 wonder what he does•? 18 A. No. 19 0. Not even curious? 20 A. No. Its not my place. I don't -- I 21 don't need to know or want to know what people's 22 associations are. 23 0. Next lime you saw Jeffrey Epstein was when? 24 A. I can't say for sure. 25 0. Have you seen Jeffrey Epstein at Leslie 55 1 Jeffrey Epstein helped to - I think, what you said was - 2 manage Leslie Wexner's money? 3 A. Some of his accounts, yes. I guess. 4 0. Why do you think that? 5 A. From what I've read in periodicals and 6 magazines. 7 0. You've read in what periodicals and magazines? 8 A. I think it was, what, Vanity Fair there 9 was an article a couple years back, three or 10 lour years back, and a New York magazine as I 11 mentioned. 12 0. Why did you read the article? 13 A. Well, obviously it was dealing with the 14 gentleman that I was working for, so out of 15 curiosity, you know. 16 0. Right. because people tend to be curious -- 17 A. Right. 18 0. right? But when I lust asked you who 19 Jeffrey Epstein was and the relationship, you said, 1 20 have no idea: implying that you weren't curious. But at 21 some point in time you got curious as to who this person 22 is, right? 23 A. Who Jeffrey Epstein is? 24 0. Yes. 25 A. Well, yeah, when you're working for him 54 1 Wexner's house? 2 A. No. 3 0. Never? 4 A. Never. I've never 5 0. Have you ever - 6 A. •• been to Wexner's house. 7 0. You've never been there? A. No. 9 0. Have you ever known of Leslie Wexner or heard 10 of Leslie Wexner having minor girls or minor boys at his 11 house? 12 A. Oh, no. 13 0. Have you ever heard of Jeff -- 14 MR. REINHART: I assume, other than his 15 children. 16 MR. EDWARDS: Oh. of course. 17 A. Yeah. No • his children. I'm sorry. 18 Thank you. 19 0. Have you ever known of Jeffrey Epstein to take 20 underage girls to Leslie Wexner's house? 21 A. No. 22 0. Do you know how it is that Jeffrey Epstein and 23 Leslie Wexner met each other? 24 A. No. 25 0. You mentioned earlier that you believed that 56 1 and he's in a magazine, you're going to road the 2 article. 3 0. Okay, so at some point in time, bird you Google 4 Jeffrey Epstein? 5 A. No, no. 6 0. Have you read the articles about Jeffrey 7 Epstein? a A. Lately? 9 0. Yes. 10 A. Oh, of course, yes, in the newspapers. 11 0. And you're aware of why your deposition's 12 being taken today. 23 A. Yes, of course. 14 0. And it has something to do not with a case 15 with Leslie Wexner, but a case involving Jeffrey Epstein 16 A. Coned. Yes. el course. 17 0. When you got this deposition subpoena, did you 18 by any chance try to look up some information on Jeffrey 19 Epstein - who this guy Is? 20 A. No, no. I mean 21 0. Is there anything -- 22 MR. REINHART: Hold on 23 finished? 24 0. Okay. Go ahead. 25 A. No. I moan, other than every once in a Were you 0 ESQVJE.E, CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutlons.com • • • 3501.150-002 Page 16 of 92 EFTA_OD°688D8 EFTA01247036 Larry Eugene Morrison - Volume I October 6, 2009 • • 57 1 whole get a Google alert just following the case 2 • just out of interest • because he's still my 3 employer, you know, and you don't want to be 4 blind-sided, but other than that, no -- 5 0. When you - 6 A. I never looked onto his financial 7 background or anytting look that. I don't know if a you can. 9 0. When you say a *Googie alert; that's 10 something that you actually go out of your way and set up 11 on Google, right? 12 A. Yeah. 13 O. When did you do that? 14 A. A year ago or so. 15 0. Why did you do it? 16 A. Because Ern not around Mr. Wexner - or Mr. 17 Epstein anymore. I duet 18 0. Well, he was in jail -- 19 MR. REINHART: Hold on. Were you Finished 20 with your answer? 21 A. I haven't been a kill time employee with 22 Mr. Wexner since -- 23 MR. REINHART: Epstein. 24 BY MR. EDWARDS: 25 0. Epstein or Wexner? 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 59 0. When you say last pace; how often are you flying? A. Every week • sometimes two, three times a week. 0. And Mat's by the time that you're working for Jeffrey Epstein? A. Yes, yes. 0. Because back in the Leslie Wexner days you weren't flying every day. A. No, no, no, because there was another engineer, no. 0. Right. A. I had about one-third of the flights. 0. So from 1988, when you start working with Leslie Wexner. through S9 or so, you're not flying all the time, right? A. No. Oh, no, no. Actually. In 88, I was. you know, I was • my primary duties were in the hangar - maintenance. O. Did you enjoy doing that? A. The maintenance part of it? 0. Yes. A. Oh, yeah, that's my background. that's my forte. O. Is that something that you've gone back to? 1 2 3 4 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 58 A. I'm soriy Mr. Epstein. since February of 2007. 0. Well, a lot of that has to do with him being incarcerated -- A. No, no. 0. -- for a year, right? MR. PIKE: Form. A. No, it was because I wanted to make a job -a career change. 0. Why? A. Because I got tired of flying, being on the road. wanted to be home. 0. Did it bother you that your boss, back in 2007, was under investigation? A. Of course. 0. Is that part of the mason why maybe you wanted to make a career change? A. No, no. The reason was the amount of flying that I had been doing and the overnights. and when something's no longer fun, it's time to find something else to do. 0. Why wasn't it fun anymore? A. It's a very fast pace. I wanted to spend time at home. I wanted to get back into strictly maintenance. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • O. Did Leslie Wexner and/or Mr. Epstein help you to get that job? A. No, no lies whatsoever. 0. So who introduces you to Jeffrey Epstein? Probably it would have been Larry. The first actual formal introduction? 0. Right. A. Probably would have been Larry Visoski. I knew Larry and Dave when they flew for Glimcher Corporation. 0. Tell me a little bit about that. Larry Visoski • how do you know him? A. He's the Chief Pilot for Jeffrey and hired me. 0. Well, he's the Chief Pilot now -- • 0 ESQUABT CONFIDENTIAL Toll Free: Faalmile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 wvnv.esquIresolutions.com 3501.150-002 Page 17 of 92 EFrA_00068809 EFTA01247037 Larry Eugene Morrison - Volume I October 6, 2009 61 1 K Right. 2 O. -- for Jeffrey Epstein. 3 A. Right. 4 O. When is the first time you met Larry Visoski? A- It was before he worked for Jeffrey. He 6 and Dave were flying for a gentleman - Glimcher 7 Corporation. 8 O. Flying for who? 9 A. Glimcher Corporation. so O. How do you spell that? 11 A. G-L-I-M-C-H-E-R, I think. They were -- 12 They had an airplane based to Lane Aviation in 13 Columbus with us. 14 O. And David Rodgers? 15 A. Yes. 16 O. How did you know David Rodgers? 17 A. Same, from They were in the same hangar 10 we were in. 19 O. Are you from here? 20 A. No. 21 O. Where are you from? 22 A. Columbus. Ohio. 23 O. So you're from Columbus. Ohio. and that's also 24 a place where Leslie Wexner Ines. 25 A. Yes. 63 1 O. How did you loam of Leslie Wexner? 2 A. Oh, I mean, he's very well-known in 3 Columbus, because, you know• billionaires in central 4 Ohio, aren't, you know O. Aren't a dime a 0020n, tight? 6 A. Exactly. and small guy that made it big, 7 you know, because that's where the name Limited • so a hearsay is - the name Limited came from he started 9 with limited resources. 10 O. So did you know him before he was married to 11 Abigail? 12 A. Yes. 13 O. And did you know him to date exclusively women 14 peer to that? 15 A. The only -- I knew that he was dating IC Sharon. 17 O. Right. 18 A. I never flew Sharon. but he dated Sharon 19 for a long time, and then there was. you know, they 20 broke up and then he started dating Abigail. 21 O. And have you heard any rumors about him dating 22 men as well? 23 A. No, no. 24 O. First time that you're healing about it is me 2s telling you that, right? 62 1 O. So that was at least convenient for you? 2 A. Oh, eah. No, it was Yeah. 3 6 7 9 10 11 12 3.3 14 15 16 17 18 19 20 21 22 23 24 25 O. As your first job that you had, was that with Leslie Wexner? A. Oh, no. I started working for Ohio State University O. And then where? A. -- in their flight department. Went from Ohio State University to get a shoe stint, a contract maintenance for a - a contract for NASA at Langley researcher, and then that was under the direction • that was contracted under OSU's umbrella for airport research. They had an Aviation Research Department. Then after that went to Red Roof Inns • maintenance technician for Red Roof Inns. O. What was It - Gregory Finns? A. No, Red Roof Inns. O. Red Roof Inns. A. True Sports Racing. It was Budweiser racing • Indy car team and Red Roof Inns. the motel Main. Then from there I went to The Limited stores. 1 2 1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 64 A. Yeah. O. So back to Lany Visosld • you don't know him while you're employed with Leslie Wexner. A. Yes. O. Youth? A. Yeah. O. How do you meet him? A. Met him because their aircraft was in our hangar. The Glimcher aircraft was based in our hangar and got to know him that way. O. Glimcher is a company owned by whom? A. I donl know if it's public or not. It was a mall development company not associated with Limited. O. So what's the conversation between you and Larry Visoski? Obviously you all end up working for Epstein, so try to lead me through that. A. Well, I think -- I mean, we got to know -- I mean, you're neighbors in a hangar environment, so you have discussions. Larry was the mechanic. He was also pilot/mechanic on the Hawker for Glimcher, and you kind of form a relationship and a rapport, and then. I believe, Glimcher sold their airplane. I don't know how Dave and Larry ended up with Jeffrey, I 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 vnirw.esgulresolutions.com • • • 3501.150-002 Page 18 of 92 EFTA_00068810 EFTA01247038 Larry Eugene Morrison - Volume I October 6, 2009 • • 65 1 don't know how they found that job, but they started 2 working for Jeffrey then, but they still -- 3 O. Did you ask them? 4 A. No, I don't think -- I've never asked 5 them, 'How -- 6 O. Did Jeff rey -- 7 A. -- did you meet them?' 8 O. have a plane in the same hangar? 9 MR. REINHART: Hold on. Let him finish 10 his answer. 11 MR. EDWARDS: I'm sorry. I thought you 12 were finished. 13 MR. PIKE: This is Michael Pike. Let him 14 finish his question because, keep in mind • you 15 finish your question, let him finish his answer 16 - keep in mind. I'm on the phone, so I'm having 17 a hard time hearing his response in the 18 background. 19 MR. EDWARDS: You're actually on the other 20 end 04 the table. Do you want us to fry to move 21 the phone closer? 22 MR. PIKE: Yes, that would be good. 23 MR. EDWARDS: I'll do that for you, man. 24 I'm sorry, I really did forget that you were 25 here. 1 2 3 I 12 13 10 15 16 17 18 19 20 21 22 23 24 25 6.7 help them with the airplane, get, you know, become a (light engineer Director of Maintenance - on it O. But the hangar we're talking about is in Ohio. A. Yeah, Lane Aviation. O. You would see them brisirially on a dayto-day basis because the aircraft that you were a technician for -- A. Right. O. was very close in proximity to the aircraft that they were piloting. A. Yes. O. They approach you at some point in time and say what specifically? A. I can't remember the specific conversations, but it was like, you know, asked me if I would be interested in, if Jeffrey bought the 727 66 • MR. PIKE: Not a problem. I've objected 2 to form a couple el tines. I'm not Quito sure 3 If that was even hoard, but that's neither here 4 nor there. 5 MR. EDWARDS: We'll say the last ten 6 questions you objected to form. I got you. 7 What was my last question, Pike? You • don't oven remember. 9 MR. REINHART: You asked Mn conversations 10 he had with Larry Visoski and Dave Rodgers about 11 how they come came to work for Epstein. 12 MR. EDWARD$: Good. 13 A. I really never queried them on now they 14 come to work for Jeffrey. I think Dave was hired 15 first and he brought - this is all speculation - and, 16 I think, he brought Larry on board. 17 O. So as far as you know, however you know. David 18 Rodgers was the first Epstein contact and then Larry 19 Visoski rode a In. 20 A. The way I understand, yeah. 21 O. How did you become involved in the 22 three•person train to Epstein? 23 A. When it became apparent that Jeffrey, or 24 Mr. Epstein. was going to buy the 727, Larry 25 approached me. that if I would want to, you know, 68 1 being. you know, the fight engineer and help them, 2 you know, get the flight department Ong. and I told 3 them I would. 4 O. And why rid you say *yes' considering that you 5 had a bees in Leslie Wexner who was seemingly pretty good 6 to you for the last ten years? A. Oh. he's excellent a O. Yes. 9 A. No, fine might department and Mr. Wexner to as fine person. 11 O. Right. 12 A. The reason being is, you know. I already 11 stated this I think twice before, was that I wanted 14 to be able to continue to fly arid that would give me 15 the opportunity to continue to ay as a flight 16 engineer and the challenge of starting this airplane. 17 O. Right. I didn't ignore you. I heard you say 18 that, but then I also heard you say he brought a brand 19 new plane. 20 A. It was only a two-man airplane -- 21 O. So then he would have -- 22 A. - and the modem aircraft could only have 23 hvO plus, right. 24 O. Got you. I underworld. 25 So they approach you with tris prospect of the • CO ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 Page 19 of 92 EFIA_00068811 EFTA01247039 Larry Eugene Morrison - Volume I October 6, 2009 69 1 two of them - Dave Rodgers and Larry Visoski - becoming 2 the pilots for the 727 -- 3 A. Correct. 4 0. -- that Epstein's buying and, 'Hey, would you 5 like to be apart ol it?' 6 A. Right. 7 0. I mean, Mars the gist of it. A. Correct, that would be the gist ol 9 0. And your response was? 10 A. Yes, I would • you know, if it came to be, 11 I would consider it. ObviOuSly, you knOw, salary had 12 to come in and everything else, but I said, 'Yeah. I 13 would be interested in it.' 14 O. What's to next conversation that you had and 15 with whom? 16 A. I don't know. There were several 17 conversations, but they were all with Dave and Larry 18 both, you know, calling back and forth, but. 19 0. About what? Was it about salary, about the 20 position? 21 A. Salary, what the benefits wore, you know. 22 stuff like that. No. the position was pretty much 33 defined. I mean, it's the eight engineer, Director 24 ol Maintenance position. 25 O. And this brings us up in our timeline to 2001, 71 A. I don't know. I don't know. 2 0. I mean, how did she get on his private 3 airplane? I would imagine strangers don't just walk on, 4 light? s A. Yeah, but I don't know. I don't know what 6 people's associations are together when, you know. • 0. Okay. a A. I don't know if it's business association. 9 social associations. or what. 10 O. How many times II MR. PIKE: Let me object to the form of 12 that question. 13 MR. EDWARDS: Okay. Noted. 14 BY MR. EDWARDS: 15 0. How many times was she on that airplane when 16 it was owned by Leslie Wexner? 17 A. Not many, but I can't give you an exact. 18 0. Was she ever naked on the airplane? 19 A. Not that I'm aware of. 20 0. I mean. that's something that you would 21 probably remember, right? 22 A. Well -- 23 MR. PIKE: Form. 24 A. Yeah. I mean -- 25 0. I'm not really trying to be funny, but I would 70 1 you think? 2 A. Correct, that's when I hired on and 3 actually moved to Florida was January 2001. 4 0. Prbor to 2001, had you heard the name • Ghislaine Maxwell? 6 A. Yes. 7 0. How would you have heard Chislaine Maxwell? ▪ A. She had been a passenger on the 727 once 9 or lvace. 10 0. The 727, I mean? 11 A. When It was under Limited. 12 0. Yeah, yeah, that's the point I'm trying to 13 make. I mean, this could get confusing on the record. 14 It's not confusing to me. Gut on the record it could be 15 because the 727 was Wexner's, then it was Epstein, so 16 you're talking about -- 17 A. When it was under Mr. Wexner's control. 18 0. What year do you think that was? 19 A. It would have been in the late '90s. 20 Again, like I say, when - probably some time around 21 the time - you know, had to be late ^90s -- 22 0. Did she 23 A. - maybe 2000. 24 0. Did she seem like a friend of Leslie Wexner's 25 to you? 72 1 assume I would remember e. 2 A. Not that rm aware et 3 0. Do you remember her bringing other gins on 4 the airplane with her? • A. No. 6 0. You remember her getting on Me airplane ? alone? B A. I can't say for sure. 9 0. Alright. Maybe this will log your •• 10 A. I mean. she was never µst atone-alone. 11 Like the only passenger or. 12 0. Yes. 13 A. No. no. always with when other people 14 were on board. Is 0. And you lust can't remember whether she 16 bought on board with her a male or a female: is what 17 you're saying. right? 18 A. No. I mean -- Restate the question. How 19 cid you 20 0. Sony. 21 A. Define 'alone.• 22 0. I don't mean, you know. n there's 15 21 passengers and she gets on. I'm saying: Do you remember 24 her getting on and being accompanied by • either they 25 took the same car to the airport, they walked the runway ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresdutions.corn • • • 3501.150-002 Page 20 of 92 EFTA_00068812 EFTA01247040 Larry Eugene Morrison - Volume I October 6, 2009 • • 73 1 up to the airport? Do you remember her being with 2 somebody else? 3 A. If it would have boon, would have been Mr. 4 Epstein. never •• 5 0. How many times do you think Mr. Epstein was on 6 that airplane? 7 A. I can't say for sure • not that many. 8 0. Less than live? 9 A. That I saw him, yes. probably. 10 0. And how many times of al -- 11 MR. REINHART: Can !just chanty? You 12 mean dung the tune Mr. Wexner owned the 13 plane MR. EDWARDS: Right, right. nght. 15 MR. REINHART: -- since Mr. Epstein bought 16 the plane. 17 BY MR. EDWARDS: 18 0. Alright. We're not up to the point, we're 19 about to bo, but we're not ho to the point yet where Mr. 20 Epstein takes control, so. 21 A. I mean, you have to understand. Mr. • 22 during this time period. Mr. Epstein had his other • 23 he already owned his other airplane. 24 Q. How did you know that? 25 A. Well, because that's what Larry and Dave 75 1 A. Maybe mid-'90, early '90. 2 0. We're talking -- 3 A. He didn't have that plane very long. 4 0. Between '90 and '93. you're saying. 5 A. Probably, yes. 6 0. And between '90 and '93, if we use those 7 years. you're laminar with the name 'Jeffrey Epstein? 8 A. Not until later when he bought the 9 Gultstream in - later when he was, you know, like I 10 said, late '90, probably. 11 0. But you're aware that David Rodgers and 12 Visoski are flying an airplane between '90 and '93 that's 13 owned by somebody. 14 A. Correct. Yeah. 15 0. But you don't know the name of the person -- 16 A. Correct. Right. 17 0. — that is the owner. We're good. We're on 18 the same page. 19 '88, you start working for Leslie Wexner. 20 A. Right. 21 0. And the first time Epstein is on Leslie 22 Wexner's airplane is approximately when? 23 MR. REINHART: It's asked and answered 24 BY MR. EDWARDS: 25 0. That you remember. 74 1 were flying - the Gulfstream. 2 O. But this is something you found out 3 afterwards. 4 A. No, no. I knew that they had gotten a job 5 with him and they were flying the Guestream. 6 0. Alright. Let me clarify this real cwickty. 7 You got the job in 1988 with Wexner. 8 A. Right. 9 0. Right. Larry Visoski and David Rodgers are 10 flying a plane that is presumably owned by Jeffrey 11 Epstein and/or one of his corporations. 12 A. Not at first. 13 O At some point in time. 14 A. Correct. 15 O. And what point in time do you become aware 16 that that's happening? 17 A. I can't remember exactly when they bought 18 the Gultstream. They actually had a Hawker for a 19 short period. I don't know when that was. 20 0. Was that also owned by Jell rey Epstein? 21 A. For a very short period, and he traded it. 22 O. The first Epstein plane that you're aware of 23 Is that Visoski and Rodgers are on -- 24 A. Was a Hawker. 25 D. was approximately what year? 76 MR. REINHART: Asked and answered. 2 A. I cant — The only tine I would remember 3 • we've already answered thd several times - was in 4 the late '90s when I was actually on the airplane. I 5 have no idea if he was on previous times without me 6 there. 7 O. And when he is on the airplane, is ho on the 8 airplane with young girls? 9 MR. REINHART: Its also been asked and 10 answered. it A. No. 12 0. New we're back to Ghistaine Maxwell, and I 13 believe your answer - which led me back to these 14 questions that I had previously asked. 'Was Ghislaine 15 Maxwell on the airplane that Wexner owned that you know 16 of?' • and I think your answer was. 'With Epstein? 17 MR. PIKE: Form. 18 A. I wood I would say if she was on 19 there, it would be with him. I never knew I would 20 not think that she would fly on it without him. 21 0. Do you specifically remember her on the 22 airplane with him? 23 A. Caret say - I can't. 24 0. On any of these flights that Jeffrey Epstein 25 and/or Maxwell was on. din thoy fly internationally? ESQUIRE as Meander Odle Conga, CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresoludons.com 3501.150-002 Page 21 of 92 EFTA_00068813 EFTA01247041 Larry Eugene Morrison - Volume I October 6, 2009 77 1 A. I know I Drought her back one time from 2 England, I believe - I remember that from London. 3 O. Brought Maxwell back from London. and was she 4 alone then? 5 A. I can't I can't say. I cant remember. 6 O. I thought you said that if she was on the 7 plane it wouldn't have been alone. A. More than likely she would have been with 9 Jeffrey. 10 O. So do you think that you brought Maxwell and 11 Jeffrey together back from London? 12 A. More than likely, but I can't say for 13 sure. I can't remember if he was on that flight. 14 O. To the best of your recollection right now, as 15 we sit hero, Is that Maxwell was on the plane and Epstein 16 may or may not have been? 17 A. Correct. That's correct. 18 O. What year are we talking about and whose 19 airplane are we talking about? 20 A. That would have been when the 727 was 23. still Limited - or Wexner. 22 O. And that would have been around what year? 23 A. 2000, maybe. 24 O. 2000? 25 A. '99. something like that. 79 the Court to be well aware that not 8t of my 2 form objections are coming through the 3 telephone. 4 MR. EDWARDS Mike. how about this, of all 5 of the people involved. I think that you know 6 you can trust me here. If you say when wo read 7 this back that you wanted a form objection. III B put 6 on the record right now you get n - how 9 about that? 10 MR. PIKE: Not a problem. 11 BY MR. EDWARDS: 12 O Alright. Have you ever looked at any of the 13 information from Customs and Immigration related to 14 flight logs? 15 A. No. 16 O. If Customs and Immigration is the right agency 17 to take control Of MOSe documents, who is it that 18 generates the documents in terms of personnel riding upon 19 this airplane/ 20 A. Captain 21 O. Who was the captain or who were the captains 22 that you are aware of and try to give me years, it many 23 of them changed. to the best of your knowledge for 24 Leslie Wexner? 25 A Primarily it would have been Tim Staley, 78 1 O. So this is almost into the transition -- 2 A. No, I'm sorry. 3 O. - into it. 4 A. Let me think on the dates. 5 O. Okay. 6 A. Yeah, I can't - I can't remember. 7 Q. Late '905 or 2000? 8 A. Late '90s. 9 O. Who has the flight logs from late '90s? 10 A. I don't know. 11 O. But that's something that the FAA would have, 12 right? 13 A. NO. 14 MR. PIKE: Form. 15 BY MR. EDWARDS: 16 O. Flying Internationally? 17 A. I don't know if the FM gets that. It 18 would more • most hkety be Customs and Immigration. 1.9 MR. PIKE: Are you guys getting my form 20 objections? 21 MR. EDWARDS: Yes. We got you. 22 MR. PIKE: Thank you. Brad. I just want 23 on the record that not all of my form objections 24 are coming through, so if we have an issue with 25 this deposition - I am on the phone - and I want 80 1 Jim Taylor, Rob Imlay. 2 O. Rob? 3 A. Imlay. I.M.L-A-Y, Bill Hammond. 4 0. Bill Hammond? 5 A. Uh-huh. 6 O. Bill Hammond later becomes affiliated with Mr. 7 Epstein too, right? a A. Correct. 9 O. We're going to get to that. 10 Have you ever been a captain? 11 A. No. 12 a And when you say that it's not necessary - 13 unless you're flying internationally, I know - but its 14 not necessary to maintain a passenger manifest that 15 delineates the exact name, where are you getting that 16 information from? 17 A. I know it's not required by the FARs. te O. Kow do you know that? 19 A. Because you can read the FARs. Part 91, 20 FAR 91, Operations. 21 O. What's -FAR' stand for? 22 A. Federal Aviation Regulations. 23 O. And what would be the reason not to put the 24 whole name of the person on the airplane? 25 A. I don't know. I -- I don't know. 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 vnwtesquiresolutions.com • • • 3501.150-002 Page 22 of 92 EFTA_00068814 EFTA01247042 Larry Eugene Morrison - Volume I October 6, 2009 • • Si 1 O. Because Later I'm going to show you some 2 lists. and certain people are listed by full name and 3 others are listed generically • any idea why that would 4 happen? 5 A. Unless they just don't know who it Is. you 6 know, just a guess. I mean, you know, you don't want 7 to query somebody and give them the third degree If it's just a guest of the boss that's, you know, 9 riding along or something. 10 O. Well, she asked you your name before your 11 deposition and you didn't consider that the third degree 12 by any means. right? 13 A. Right. but -- 14 MR. PIKE: Objection to form. 15 A. Bill you're approaching your employer's 16 guest. It would be like walking into his house and 17 asking him, 'Who's sitting at the dining room table?' 18 • In a way. See what I'm saying/ It's just -- You 19 have to maintain .- 20 O. But •• 21 A. -- the employee/employer relationship. 22 O. No, no, no. I guess what I'm saying is: if 23 one of these people is Mohammed Aga, you would like to 24 know O. probably. 25 A. Well, yes. 83 1 A. It would be obvious that these aro 2 associates of some form, that they're not, you know, 3 strangers trying to board the airplane. 4 O. So let's go back to that conversation that you have in the Ohio hangar, or whatever it is, with David 6 Rodgers and Larry Visoski when they talked to you for the 7 first time about possibly switching over to Mr. Epstein. 8 A. Ubhuh. 9 O. How does that conversation really go about/ le MR. PIKE: Form. 11 A. I don't understand. What do you mean. 12 'How &law about?' 13 O. Did you approach them and say. 'Hey, are you 14 going to stay here forever with this airplaner or 'Do is you have another lob for me?' or what? 16 A. I think it was just, you know. I believe 17 Larry approached me. I can't remember. It was that 18 long ago, but - 19 O. What does Larry Say to you? 20 A. I can't remember the exact conversation. 21 O. I mean, was he not happy where he was? 22 A. Who, Larry? 23 O. Yes. 24 A. Never said he wasn't. 25 O. How did you know Larry? 82 1 MR. PIKE: Form. 2 A. Yes, yes. 3 Q. So any reason why a captain trying to secure 4 the airplane and the people aboard wouldn't take that S extra step and try to figure out who's exactly on his 6 airplane? 7 A. Well. when it's • the normal passenger loads are live to ten people, at the very most, and 9 they're all with the owner and accompanying the owner 10 and some of the regular passengers, you know; the 11 likelihood that Mohammed Atta is going to sneak in 12 there and board his plane and ride along is - you 13 know. 14 O. He's willing to play those odds, okay. 15 A. Well, I'm not saying that he's playing 16 odds. I'm just stating that the only reason I can 17 think — I don't know. I've never filled those out. 18 The only reason I can think is he just didn't have 19 the name and didn't want to intrude and ask. 20 O. If you were a captain, would you ask who was 21 on your airplane? 22 A. Not if the situation was that it was 23 controlled by the owner and I knew who the - you 24 know. 25 O. Okay. 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 84 A. What are you talking about? Why would he not be happy where he was? I don't understand. O. Well, he's working for some other corporation that's not non-Epstein owned. A. Oh, that previous corporation sold the airplane. O. Oh, they did? A. Yeah. He had no choice. They were out of work. O. So Larry and David were about to be out of work. A. Yes. O. So they said, 'Hey. we found a new lob and its with this guy Jeffrey Epstein and he's buying that plane. Do you want to be involved?' A. No, no. There was another airplane in between • two other airplanes. There was a long time between - and I don't know the exact dates and I don't know that I even do know the dates • but there was a time between when they left Glimcher before Jeffrey got involved with the 727. O. So they leave Glimoher? A. Yes. O. Then what happens? A. They somehow - I don't know how • hired on • ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 vnvw.esguiresolutions.com 3501.150-002 Page 23 of 92 EFEA_00068815 EFTA01247043 Larry Eugene Morrison - Volume I October 6, 2009 85 1 with Jeffrey. 2 O. They hired on with Jeffrey to pilot the 727? 3 A. No. He had two other airplanes prior to 4 that. He had a Hawker that he had for a very short 5 period and then he bought - traded it or sold it. I 6 donl know what he did with it. but then he got the Gulfstream. 8 0. So Larry Visoski and David Rodgers were pilots 9 for Jeffrey Epstein when he had the Hawker also? 10 A. Yes. 11 0. And what year are we talking about there? 12 A. I have no idea. 13 0. Well, If you sign on with him in 91. it's 14 before that year. right? 15 A. No, no, I signed in '01 • January '01. 16 0. '01. 17 A. I don't know how long they flew for 18 Glimcher before that airplane went away and how quick 19 they gel on with Jeffrey. I don't know. Somewhere 20 between '88 and 2001, they -- 21 0. During -- 22 A. — left Glimcher and — 23 0. During '88 and 01, do you remain in contact 24 with Larry Visoski and David Rodgers? 25 A. On and off. They eventually moved, you 87 1 0. Before your conversation with them about 2 becoming Involved with Jeffrey Epstein. 3 A. Yes. 4 0. How? • A. Like we discussed. We've been through 6 this already. When they wore at Glimcher they had an 7 airplane in the hangar. We would see them • sporadically and we would talk. 9 0. I'm sorry, bad question. I don't mean on a 10 business relationship. On a social relationship, did you 11 hang out with them -- 12 A. Oh, no. 13 0. outside of this? 14 A. No, no. 15 0. I apologize. 16 So • and I only asked that question because 17 some years later then you're in contact with them and 18 they asked you to become involved with Jeff Epstein. 19 A. Uh-huh. 20 0. But that is because of a business relationship 21 solely that you had with them -- 22 A. Oh, yeah. 23 0. years before? 24 A. I didn't know them personally. 25 MR. PIKE: Form. 86 1 know, to - moved away from Columbus when they hired 2 on with Jeffrey, so they weren't in the hangar every 3 day. 4 0. Where did 'hey go - do you know? 5 A. I Think Dave went to New York and Larry 6 went back to South Florida. 7 0. Do you know why? A. Well, because I think Jeffrey gave them 9 the choice of living where they would like. I 10 believe. I mean, that's -- 11 0. That's what they've said. 12 A. That's what they've said. 13 0. Okay, and Larry chose South Florida, David 14 Rodgers chose New York? 15 A. Right. 16 0. And Epstein had a place for them both wherever 17 they wanted to go? 18 A. Well, they owned their own Acmes or 19 something. I don't know what their living 20 arrangements were. 21 0. Did you know Larry Rodgers or David Visoski 22 before this? 23 A. Before? 24 MR. PIKE: Form. 25 BY MR. EDWARDS: 88 1 BY MR. EDWARDS: 2 0. Okay. Alright. So in 2001. is that the year 3 that you get a telephone call from one or two of these 4 people? 5 MR. PIKE: Form. 6 A. It would be either late 2000 or earty 7 2001. I don't These transactions don't happen 8 overnight -- 9 0. Yeah. 10 A. — buying an airplane. So it could have 11 happened in, you know, November or started talking in 12 November, like, 'Well, you know, would you be 13 interested if Jeffrey gets the airplane or buys the 14 airplane?' you know. to when I actually hired on. 15 0. Did you ever talk to Ghislaine Maxwell • ever? 16 A. After I had hired on, yes. 17 0. After you hired on with Epstein. 18 A. Yes. 19 0. Well go up to her. 20 So when is it that you hired on with Jeffrey 21 Epstein? 22 A. I think I began in January of 01. 23 O. In January of '01, do you stars getting a 24 paycheck from Jeffrey Epstein? 25 A. Yes. 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.00m • • • 3501.150-002 Page 24 of 92 EFTA_00068816 EFTA01247044 Larry Eugene Morrison - Volume I October 6, 2009 • 89 1 O. And Is it paid from one of his companies or 2 from Jeffrey Epstein specifically? 3 A. No, no • JEGE. 4 O. JEGE. What is your understanding as to what that is? 6 A. It's just initials. It's a name. I don't have any idea what it stands for, but I'd ask that a 8 million times. 9 O. Its a company that owns something, right? 10 A. I don't know -- 11 MR. PIKE: Form. 12 A. -- if it even owns anything. I don't know 13 what type of company it is. I don't know if It's 14 just a Wilmington. Delaware, company. 15 O. What's the bank account that it was written 16 on? 17 A. I can't remember. I mean. I know I'd read 18 • I'd see 'JEGE` on it, that's all. 19 O. A New Mexico bank, New York bank. Florida 20 bank? 21 A. I have no idea because its direct 22 deposit. All I would do is just see if the amount's 23 right. I don't -- I have no idea. I would have 24 no Idea. 25 O. What was your communication - direct 91 I perform. 2 O. On what planes? 3 A. Just the Guff - just the Boeing. 4 O. Just the Boeing? 5 A. Uh-huh. 6 O. Over the years. did you become aware that he 7 owned other aircraft? a A. I knew that he still had that. 9 MR. PIKE: Form. 10 A. He still had the Guffstream. 11 O. At the time back in 2001 - and we're going to 12 walk through some of his enplanes • he owned the Boeing 13 727, right? 14 A. Correct. 15 O. And what other airplanes did he own at that 16 time when you signed on with him in 2001? I7 A. The Gulfstream. le O. Guitsteam is what? 19 A 28. 20 O. Do you know who the pilot was for that plane? 21 A. Dave and Larry, I mean, its always. 22 O. Was it atways Dave and tarty no matter what 23 plane was being taken out? 24 A. Unless somebody was on vacation or in 25 school and they used contract people. 90 1 communication with Jeffrey Epstein that results in your 2 employment with JEGE? 3 MR. PIKE: Form. 4 A. A conversation result in my -- Essentially 5 Larry hired me. I mean, it wasn't - It wasn't 6 didn't realty -- I may have had one phone 7 conversation with Jeffrey prior to actually being B hired and the next time I saw Jeffrey was when I was 9 in Florida with the airplane. 10 O. What did Jeffrey ask you in that one phone 11 conversation? 12 A. I think he asked me what my current salary 13 was, or something along that line, you know. 14 O. Did he ask you what you were looking for in 15 terms of salary? 16 A. Yes. 17 O. What dkl you toff him? 18 A. I told him to basically I forget how it 19 went exactly. It ended up being like $117,000, 20 something like that. 21 O. $117.000 a year? 22 A. Yeah. 23 O. And what wore your duties? 24 A. Basically - flight engineer, obviously. 25 but all line maintenance and scheduled maintenance to 92 1 O. What was the purpose behind having multiple 2 planes - used one for the purpose, one for another do 3 you know? 4 A. I never could figure that out. 5 O. Really? 6 A. Yeah. 7 O. No rhyme or reason why he took one this way Ei and one that way? 9 A. No. He was • pretty much once the Boeing 10 got on line. Now, you know, the Boeing goes down for 11 heavy maintenance. It used to go annually. now It 12 goes down DI-annually, but • so he would utilize that 13 airplane while it was out of service, you know, for 14 maintenance, which sometimes would be four, five 15 weeks at a time, so. 16 O. And in those cases, then he would use the 17 Guffstream 2B? la A. Yes. 19 O. Have you been on both planes? 20 A. Yes. 21 O. We're still talking about 2001. Is that the 22 first time that you're on the 727? 23 A. Firs! time I was on the 727? Wail. I 24 don't know what you mean. 25 O. After Epstein owns it. • 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 Page 25 of 92 EFTA_00068817 EFTA01247045 Larry Eugene Morrison - Volume I October 6, 2009 93 1 A. Yes. 2 O. And do you remember where you went? 3 A. Very first tlight, no, because we didn't 4 fly it immediately. We upgraded some avionics and 5 did modifications. 6 O. What modifications did he want to that plane? 7 A. Just changed the carpet and some fabrics, e upgraded the radar, upgraded the navigation - the 9 flight manifest systems. 10 0. Did he change the interior at all? 11 A. No. We removed that one small table and 12 chair - that's it, but we did not really change what 13 you would consider the floor plan. 14 0. Now, try to give me a visual appreciation of IS the inside of the plane. II I'm looking out the cockpit 16 back towards the back of the plane: what am I going to 17 see? 18 A. A door. 19 O That's it? 20 A. That's it. yeah. 21 a Just an empty room with a door? 22 A. No, no. The door's always closed. If the 23 door's open you will see the forward salon, and in 24 the forward salon there is a conference table, a 25 high/low table, some divans, and some single seats. 95 1 A. Cant remember the first flight. Like I 2 say, it was down tor a while probably • I think it 3 was - had to take at least three to tour months maybe 4 to get it -- s 0. And did you know of him flying on the airplane 6 with gins accompanying him? 7 MR. PIKE: Form. A. I don't -- 9 O. Back in 2001. 10 A. With girls accompanying him? 17 0. Yes. 12 A. Yes. 13 O. Where would he pick the girls up from? 14 MR. PIKE Form. 15 A. I don't know. They would arrive with him. 16 you know, out of Palm Beach or out of New York. I 17 don't even remember where we went the first time. The first flight was probably New York, I think. 19 O. Is it a private airport in New York where you 20 would usually pull into or a commercial airport? 21 A. I think the first time we started going up 22 there. I think, we were using White Plains, which is 23 • actually, it's not a private airport. They all 24 have some commercial service. It would have been 25 White Plains, I believe, then later we started using 94 1 0. What's behind that? 2 A. The galley. 3 0. The what? 4 A. The kitchen - galley. • 0. Okay. 6 A. Behind that is the aft salon, which is 7 just two round divans. ▪ O. And? 9 A. Alter that is the office, which is a 10 consists of a credenza and a desk, or divan and a 11. desk and chairs. 12 0. How many of these areas can you close off or 13 partition? 14 MR. PIKE: Form. Is A. Each one. And after that there's the 16 state room. 17 O. And in the state room how big is the slate 18 room? 19 A. Consists of a queen size bed and two 20 single seats. 21 CI Have you ever been back in the state room? 22 A. Oh, yes. Yeah. 23 0. When's the first time you flew on the airplane 24 with Jeffrey Epstein back in 21101, after he acquired the 25 727? 96 7 Kennedy, and the service was so terrible in Kennedy 2 and so expensive we went to Newark. 3 O. When you would fly into White Plains or to 4 Kennedy or Newark, would you always get off of the 5 airplane or would you sometimes stay on and wait for 6 passengerslo board? 7 A. I don't understand. a 0. Well, when you stop an airplane 9 A. Right. 10 0. -- sometimes you get off the airplane and you 11 go either through a. you know, through the airport or you 12 go somewhere else, or your option is to stay on the 13 airplane and not get off and wait for other people to get 14 on before you take oft. 15 A. Oh, no. 16 MR. REINHART: rm sorry, can wo clarity 17 the 'you'? Do you mean thin personally or the 18 people who were passengers on the plane that he 19 was flying? 2o 0. I'm talking about you personally. 21 A. Oh. no, it was rare that we ever did a 22 through flight. Wo would normally go Irom Point A to 23 Point B, and that was the destination. 24 O. I assume when he buys the plane initially it 25 was in Ohio. right? • ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Otas Boulevard Fort Lauderdale, FL 33301 www.esquiresoluticns.com • • • 3501.150-002 Page 26 of 92 EFTA _00068818 EFTA01247046 Larry Eugene Morrison - Volume I October 6, 2009 • • 97 1 A. Well, yeah, but -- 2 O. Then you fly to Florida. 3 A. Well, we crewed it to Florida and then it 4 sal at a facility in Florida during negotiations, so • it didn't go directly from Ohio. 6 O. In 2001, when there's still negotiations, 7 where in Florida is the airplane? • A. Lake City • Timco. Lake City. 9 O. During the negotiations, does it ever take ott 10 or is it grounded? 11 A. No, no, it's grounded, because on a Part 12 91 deviation it has to be under a specific 13 maintenance program, so when it left The Limited. it 14 left that maintenance program, and I had to 15 transition it to the new program. 16 O. This is still sometime in 2001, right? 17 A. Earty, yes, yes. 18 O. And then it passes all inspections, I'm 19 assuming? 20 A. Right, right. 21 O. Then you take it to what airport to where 22 it — 23 A. PB1. 24 O. PRI? 25 A. Here in West Palm. 1 2 3 4 S 6 7 B 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 99 O. Who's on the airplane? A. Well, obviously it would be Jeffrey. O. Right. A. I can't remember who all went. O. Who were the pilots? A. I can't remember that either. O. Larry? A. No. MR. REINHART: Hold on. A. II would have been myself, for sure - because I was the only one with experience on the airplane myself, Dave, I believe, would have been captain because ho had been schooled, but I can't remember if Larry took first flight or nol. I think he was still in training. O. Where did you go? A. I can't remember. MR. PIKE: Form. A. I can't remember it It was New York or I would imagine it would be New York, but I can't remember. O. When you say you would imagine New York. I'm getting the impression that many of the flights went to and from New York. A. Yeah, primarily. 98 1 O. While ifs at PB1 airport, does it take off 2 from there? 3 A. No, not for -- 'Mars when we were doing 4 the modifications and upgrades. We were doing the S avionics. 6 O. How long did that take? 7 A. I don't remember the exact time - maybe B three to four months. 9 O. Who does it with you? A. Jet Aviation. Jet aviation did the 11 avionics and soft goods. 12 O. And when you say the *soft goods.* what do you 13 mean by that? 14 A. Carpet. fabrics. loather, you know, 15 different things like that. 16 O. When's the first time it takes off then on a 17 real flight - some time m 2001, but mid-year or 18 something? 19 A. Probably midyear, maybe a little earlier 20 than mid-year. 21 O. We're talking about Juno of 2001? 22 A. Right. 23 O. Arid where do you go? 24 A. Can't remember. i cani remember for 2S Mb. 100 1 O. Soil - 2 A. And -- 3 O. So any time you're having to guess where it's 4 going, you're saying New York because that's the primary 5 place it's gong. 6 A. Correct. I would have remembered -- I 7 I know I didn't get — I had heard about St. Thomas. but I hadn't been there right away. I didn't get to 9 go to St. Thomas for a while. 10 O. Thars later on in the story. 11 A. Yes. 12 O. Well get there. 13 So you go to Now York. Does he tell you the 14 purpose behind going to New York? 15 A. No. 16 O. Prior to this trip to New York, have you had a 17 personal conversation with Jeffrey Epstein? 18 A. No. 19 MR. PIKE: Form. 20 BY MR. EDWARDS: 21 O. Never? 22 A. Not personal 23 business-related. 24 O. Okay. but -- 25 A. 1 mean, it was about the interior work or Everything is ESQUIRE *0 Aleasolet Gallo Capin Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 Page 27 of 92 CONFIDENTIAL EFTA_00068819 EFTA01247047 Larry Eugene Morrison - Volume I October 6, 2009 101 1 the avionics going in. but never personal. 2 O. But, I mean. you've been hired by him -- 3 A. Right. 4 O. -- you agreed on a salary. he's going to pay 5 you the salary, but other than that, and what maintenance 6 may be required -- 7 A. Correct. - on the airplane, nothing else? 9 A. He's a very -- His conversations are 10 usually very shod. He doesn't, you know, take much 11 tine. 12 O. When you would have conversations with him. 13 would they to over the telephone or would they be in 14 person? 15 A. It could be In both. II he was in Florida 16 and I wanted to actually show him a labric or a 17 sample for the airplane or he wanted to view how it 18 was coming, but oftentimes it would be via telephone 19 from New York. 20 O. When it would be in person. would you see him 21 surrounded by or be accompanied by a girl or girls? 22 MR. PIKE: Form. 23 A. At times, yeah. 24 O. Would any of those girls be Ghislaine Maxwell? 25 A. Al times, yes. 103 I know, business relationship too. 2 O. Did you know who Ghislaine Maxwell was? 3 A. Not right away, no, no. 4 O. Nol right away? 5 A. Right. 6 O. At some point in time you were curious enough 7 to make an attempt to find out. B A. No, l 9 MR. PIKE: Form. to A. -- heard about her and there was a book up 11 In New York In the apartment that we stayed In that 12 was -- You know, you're sitting there with nothing to 13 do. I read that. 14 O. Do you remember the name of the book? 15 A. It was just 'Maxwell: 16 O. Have anything to do with her father? 17 A. Yeah, it was about him, that's what it was 18 about. I mostly just flipped through locking at 19 pictures, boats, and airplanes and stuff. 20 O. Back in 2001, the first time you had a real 21 conversation with Ghlstalne Maxwell .- 22 MR. PIKE: Form. 23 A. Yes. 24 O. - what did that conversation Consist of, it 25 you remember? 102 1 O. Would any ol those girls look extremely young 2 lo you? 3 MR. PIKE: Form. 4 A. Not - Not that I thought. 5 O. Not back in 2001, we're talking about? 6 A. Right, right. 7 O. NO. What would Ghislaine Maxwell say to you, it 9 anything? 10 MR. PIKE: Form. 11 A. She'd Mostly small talk, just She 12 kind of did the business management pad of it as far 13 as, you know, arranging cell phone - I was having 14 coil phone problems with the company cell phone. she 15 would handle things like that, but she would have 16 minor inputs on the interior work. 17 O. What was your understanding back in 2001 still 18 of the relationship between GIs:Vain° Maxwell and Jeffrey 19 Epstein? 20 MR. PIKE: Form. 21 A. I really didn't understand it. I thought 22 it was personal - personal and business. 23 O. When you say "personal: did you mink it was 24 sexual? 25 A. I thought maybe they were dating and. you 104 1 A I think it was concerning getting a cell 2 phone and a pager • that's it. 3 O. Did it have anything to do with underage 4 girls? s A. Absolutely not, no. no. 6 O. That's not something she ever shared with you? 7 A. No, no. O. Did Jeffrey Epstein ever share with you that 9 he wanted underage girls -- 10 A. No. 11 O. —in any way? 12 A. No. 13 MR. PIKE: Form. 14 BY MR. EDWARDS: 15 O. I mean, certainly I'm not saying something to 16 you that's an absolute shocker right now -- 17 A. Right. 16 O. — considering the newspaper articles. 19 A. Right, but l know -- You have lo 20 understand, every conversation I had was pretty much 21 business, just to deal with the airplanes. You know, 22 I'm an employee/employer relationship. 23 O. I just don't want you to think I'm just asking 24 random off the wall questions -- 25 A. Right. 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutIons.coM • • • 3501.150-002 Page 28 of 92 EFTA_00068820 EFTA01247048 Larry Eugene Morrison - Volume I October 6, 2009 • • 105 1 O. that have nothing to do with anything. 2 A. I understand. 3 O. 2001. you start working for him, and that June 4 or so is the first fight, and you believe its to New 5 York. 6 A. Cared. 7 O. Do you remember the purpose behind the flight? A. No, did not know the purpose. 9 O. Did you get off the airplane in New York? 10 A. Yes, yes. 11 O. Where did you go? 12 A. Probably to - into the city, into the 13 city, and he has an apartment building up there that 14 we would stay in in the city. 15 O. Is it paid for by Jeffrey Epstein? 16 A. What? 17 MR. PIKE: Form. 18 BY MR. EDWARDS: 19 O. The apartment. 20 A. Well, he -- Its I think it's in the 21 building he owns. I mean. I just -- I don't know. 22 Q. Do you remember the address? 23 A. El m 24 O. right? 25 A. Right. 107 1 building. I've been to the building. The building is 2 huge. 3 A. I don't know. I don't know if he owns the 4 building or just - or how many units he's got. Maybe • ten, because I think some of the employees up there 6 live in them. • O. Do you remember who some of the other 8 employees are that live in that building? 9 A. Well, I think Darren used to five in il. 10 Darien Indyke. 11 Q. Darren Indyke, right. 12 What abou 13 A. lived in there. 14 O. What abou 15 A. I don't know lived in there or 16 not. 17 O. You know who that is, though. 18 A. Right, right. Actually, she was just kind 19 01 coming into the picture when I was • about the 20 time when I was leaving. 21 O. What about Ghislaine Maxwell? 22 A. No, no, she didn't live there. 23 O. What about Jean Luc Brunel? 24 A. No. 25 O. How about Did Mark Epstein ever indicate to do you remember her? 1 2 3 4 5 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 106 O. Did he ever mention a brother that he may have to you? A. I met his brother, I think, once. O. What's his name? A. I can't remember. O. Mark? A. I remember meeting. O. Mark Epstein strike — A. Honestly. I can't say for sure. O. And how do you know that Jeffrey Epstein owns the apartment building A. Larry told me. I mean, it was just kind of known. O. Larry told you — A. Yeah. O. - a Jeffrey tad you? A. Oh, no, not Jeffrey, no. Larry. I wouldn't have asked Jeffrey. O. How many of those apartments up there in New York is it your understanding that Jeffrey owns? MR. REINHART: I'm sorry, are you asking how many units are in the building or how many buildings? BY MR. EDWARDS: O. No. how many units that Jeffrey owns in the 108 I you that he had any ownership in any d that? 2 A. Oh, no. I only saw him one time on a 3 short flight. I don't even know where we - we were 4 probably taking him to and he was lust • Jeffrey S introduced him as his brother and it was very short, 6 you know. just, 'Oh, hi. How are you?*, and he went 7 in the back. 8 O. Do you know anything about the guy? 9 A. Uh'uh. 10 O. Nothing? 11 A. Nothing. 12 O. So in 2001, there's a flight up there at sane 13 appointment in time, and you get off and you stay at one 14 of the apartment buildings ate 15 A. Right. right. 16 O. And did you meet any of the neighbor's of the 17 apartments that are also owned by Jeffrey Epstein? le A. No. no. because when we're there its 19 usually just for a night or something and then, you 20 know, we're either airlining home or going on. 21 O. How did you know Darren Indyke? 22 A. He's our -- He's our business attorney for 23 JEGE. 24 O. Do you remember any of the other tenants of 25 the apartments at other than Darren • ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, Fi. 33301 www.eSeuiresolutions.com 3501.150-002 Page 29 of 92 EFTA_013068821 EFTA01247049 Larry Eugene Morrison - Volume I October 6, 2009 109 1 maym and ==? 2 A. Not that I remeMbef, no. 3 O How about Leslie Groff? 4 A. I don t think Leske rived there. O. Do you remember that name? 6 A. Yet She's Mr. Epsteins secretary. 7 O. What ab0ut 8 A. no. I dont think so. 9 O. Jell Fuller/ 10 A. I dont know Jeff Fuller. I doll even 11 know Jeff Fuller. 12 O. Do you know the name Jean Luc Brunet? 13 A. Yes. 14 O. How do you know that name? 15 A. He's been He was a paSsenger cn a few 16 of our eights. 17 O. Do you know why? 18 A I think he was I deal know for sure. 19 He's In a mode/no business with Mr. Epstein, I 20 believe. 21 0. MC27 Do you know that name - MC2 Modeling 22 Agency used to be Karin Modeling Agency, now it's MC2? 23 A. No. 24 O. Hew do you know about his and Mr. EpsteMS 25 modeling agency? How do you know that? 111 I of the MC2 shoots? 2 A. t never heard There was one incident •• 3 The only thing I remember about it is they were on a 4 shoot - and ire not hinny. but Jeff but d is in a s way • they were in a mow home on location at the 6 shoot. and they started to drive off and one ol the 7 models asked to use the resin:CM and they told her a which door it was and she went out the side door, so 9 grabbed the wrong door, but that's actually the only 1 o thing that sticks in mind - was that one. 11 0. Have you ever done any research on Jean Luc 12 Brunel? 13 A. No. 14 0. Do you have any idea that he's known 15 throughout Europe as somebody who has sex with underage 16 girls? 17 A. No. 18 0 You didn't know Mal until right now? 19 A. Correct. 20 O. That's Something that you're learning as a 21 surprise to you 22 A. Yes. 21 O. So-- somebody you never hoard 24 Or 25 A. II sounds famkar. I'm trying to place 110 1 A. Just every once in a while he VMuld Say 2 something about, you know, one 01 the model shoots or 3 something. We normally had hen on - we would take 4 ten back and forth to Paris. 5 O. Where some of their models come from? 6 A. I don't know. 7 O. Did you ever bring some of the Paris models I back? 9 A. Not that I'm aware ol, no 10 MR. PIKE: Form. 11 BY MR. EDWARDS: 12 O. So he would go to Pans on the airplane. Jean 13 Luc, would you drop him off there or would you pick 14 people up and bring Mem back? 15 A. If I remember, normally we were brining 16 Jean Luc from Paris to New York. ill remember. 17 O. And when you say that the modeling agency - 1$ obviously that, you know, between him and Mr. Epstein • 19 is that something that Mr. Epstein would talk 10 you 20 about or is that something that Jean Luc would talk to 21 you about or you would just overhear the two? 22 A. Overhear the two, or Jean Luc may say 13 someMing about one of the shoots or something, just 24 in general conversation. 25 O. And what would Jeffreys comment be about some 2 1 4 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 112 her. I don't know if she works in the office or -- O. Or worked in the office? A. Worked in the office, yeah. I very rarely went to the office. I mean - O. - how do you know her? A. From the flights - being on the airplane. O. How many times was she on the airplane? A. Quite a few. Almost every. O. Mars your understanding as to what she did for Mr. Epstein', A. • I O. Did Mr. Epstein ever once mention to you that he likes massages? MR. PIKE: Form. A. No. he never mentioned that to me. O. That's not something that you ever heard of. right? A. Well, I -- O. I mean, outside of the articles that you've read. A. Right. No. but he never came up to me and said. 1 like massages.' ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.00m • • • 3501.150-002 Page 30 of 92 EFTA_00068822 EFTA01247050 Larry Eugene Morrison - Volume I October 6, 2009 • • 113 1 O. And did - did you hear her 2 organizing, scheduling, talking to people about either 3 what she may call 'work" or 'massages' for Epstein? 4 A. No, no, I dont MR. PIKE: Form. 6 BY MR. EDWARDS: O. What types of conversation, if you can 8 remember anything, did you ever overhear 9 talking about? 10 A. It would be mostly like transportation 11 arrangements - car needs. 12 O. Car needs for who? 13 A. Well, making sure that the driver in New 14 York was meeting the airplane at the proper time, 15 stuff like that, or if they had an unusual large 16 amount of baggage, to make sure that another car was 17 hired to come pick this up. things like that 18 logistic-type stuff. 19 O. We're still talking about a time period back 20 in right. vi these 21 A. No. M. I donl remember coming 22 into the picture until later. 23 O. Later inMsomething? 24 A. No. she wasn't around at first. 25 O. Alright. 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 115 always sat it by his office in the back. O. Always had a computer? A. No, no, it's just a large briefcase. O. Did you ever know his e-mail? A. Yeah, I had it I can't remember what it was and I don't think it's even current - but when I would have to send him e-mails about the interior or maintenance issues. It was jeprojects, or something like that, at -- I don't know if it was at Yahoo or gmail. I don't think it was gmall. O. You think it was jeprojects? A. I believe so, but I can't remember what service. O. At gmail.com or something? A. Or something like that or Yahoo or something. O. How about Ms. Maxwell? A. It was I think. O. Do you know rf that's still current? A. No, I don't. O. How about A. I had it at one time and I know she changed it and I don't know what it is. I can't remember what It was, actualty. O. Do you know where she is 114 1 A. No. I don't remember when oxactly 2 but she 3 O. Who was mak, arrangements for meetings 4 and such prior to Ms. 5 A. Ms. Maxwell. 6 O. -- that you remember? 7 So Maxwell was the. for all intents and 9 A. existed? purposes, the before 10 O. Maxwell making you ever 11 arrangements for massages or for girls or anything else? 12 A. No. 13 MR. PIKE: Form. 14 BY MR. EDWARDS: 15 O. Where were the conversations • whether it was 16 travel or whatever else - that was occuning between 17 Maxwell and/or MIIM? Where were they taking 18 place - on the airplane, some office? 19 A. Yeah. No, no. usualy in the cockpit, you 20 know, prior to departure, en route slating, 'We've 21 got this many cars and rye Contacted' or tan you 22 call such and such to have this brought cut?' 23 O. Did you ever see Epstein work a lot? 24 MR. PIKE: Form. 25 A. He always had a briefcase with him and he 1 2 3 4 6 7 9 10 11 12 13 la IS 16 17 18 19 20 21 22 23 24 25 116 right now? A. No. O. Do you know it she's intentionally on the lam to try to avoid being deposed in this case? A. No. MR. PIKE: Form. A. No idea. I haven't had any contact with M I since I slopped flying. O. You say that was just coming in the picture is the words that you used. What did you mean by this? A. Wet I mean she was just I'm trying to remember when I first started seeing her on the airplane. I can't remember the exact date. O. When did you stop flying? A In February of '07. O. February '07? A. Yep. Toll Free: Facsimile: • 0 ESQUIRE CONFIDENTIAL Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esqulresolutlons.com 3501.150-002 Page 31 of 92 EFFA_00068823 EFTA01247051 Larry Eugene Morrison - Volume I October 6, 2009 1 1 7 1 I 4 I 6 country. 7 0. Were you ever told that Mr. Epstei J U 13 0. Did you ever see him and her sexually involved 14 en the airplane or otherwise? 15 A- No. 16 O. Did you ever see Epstein involved sexually 17 with anybody on the airplane? 18 A. No. 19 O. Did you ever see the airplane used for sexual 20 purposes? 21 A. No. 22 MR. PIKE: Form. 23 BY MR. EDWARDS: 24 O. It it had happened - considering the various 25 areas that were cordoned oft or blocked off would that 0. Do you know where she came from? A. Just what rye read in the paper I'm sorry. I daft remember the 119 1 A. No. 2 O. in the back of the airplane. 3 A. No. 4 O. So anything could go on. You would have no 5 idea. 6 MR. PIKE: Form. 7 BY MR. EDWARDS: 8 O. You could sit here and testify truthfully, 9 have no clue what's going on back there.' 10 A. That's correct. That's correct. 11 O. Darren Indyke - what's your understanding as 12 to his involvement with Mr. Epstein? 13 A. An attorney forme company. 14 O. Ever met Alan Dershowitz? 15 A I think Yes. 16 O. How did you meet him? 17 A. Alan Dershowitz. I don't know if it was 18 Mr. Goldberger or Alan Dershowitz. We brought some 19 attorneys down •- 20 O. Why? 21 A. -- to Florida one time. 22 0. Why? 23 A. For Mr. Epstein. It was right before i 24 finished flying. For Mr. Epstein to make an 25 appearance at the courthouse or a meeting or 118 1 have even been something that you could have seen? 2 A. No, no, if it was • if the doors were 3 closed, no. 4 0. So there's a back room that you've described 5 that has a bed in it, and if that door's closed you don't 6 know what's going on behind dosed doors, right? 7 A. ?bars correct. 8 MR. PIKE: Form. 9 BY MR. EDWARDS: 10 O. Do you remember a time Epstein was back in 11 that back room with other people? 12 MR. PIKE: Form. 13 A. No. 14 O. Are you saying it never happened while you 15 were on the airplane? 16 A. I really have no idea of knowing because, 17 one, we never go back there unless we're invited 18 back. 19 O. Okay. 20 A. And the forward door • the very forward 21 salon door is dosed, so we never even normally go 22 into that -- 23 O. SO you don't really know -- 24 A. -- without permission. 25 O. You don't really know what happens -- 120 1 something, and we brought some attorneys with him. 2 O. And were you aware then of the allegations 3 against Mr. Epstein? 4 A. They were starting to brew, yes. 5 O Were you still actively working on his payroll 6 at the time when the investigation was going on? 7 A. Yes, when it lust started. 0. And did that impact you in any way as to 9 whether or not you wanted to be affiliated with this 10 person? 11 A. Subconsciously, it may have. And it 12 wasn't because of this person, but as a business 13 decision, if, you know, an airplane's not needed and 14 I don't fly, I could be out of work. But, no. the 15 primary reason was the fact that I did want to get 16 off the road and back home. 17 O. U U I 22 O. I'm assuming you're aware of the 'actual 23 allegations in these complaints? 24 A. Yes, yes. 25 O. And you are aware that there are hundreds of S ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esgulresolutIons.com • • • 3501.150-002 Page 32 of 92 EFTA_00068824 EFTA01247052 Larry Eugene Morrison - Volume I October 6, 2009 • • 121 1 girls who are underage who claim to have had sex with Mc 2 Epstein as well as Ms. Maxwell at various times? 3 MR. PIKE: Form. 4 A. l was only aware of —first time was 5 made aware of it, ol the number of people, was when 6 they served me the subpoena. The deputies or 7 retired 8 O. Yes. 9 A. private eyes told me that. That was 10 the first I had heard a number. 11 O. Were you completely oblivious that this was 12 going on? And by 'this' I mean Epstein and/or Ghislaine 13 Maned endlor recruiting 12, 13: 14, 14 1S-year-old girls to his house for sex? 15 A. Absolutely I was oblivious to X 16 MR. PIKE: Form. 17 BY MR. EDWARDS: 18 O. If young girls were on an airplane that you 19 were on • considering mat we've now established how the 20 airplanes set up and you're kind of cordoned elf is a 21 possible that underage girls would have been on the 22 airplane and you just wouldn't have known about it? 23 MR. PIKE: Form. 24 A. No, no. I mean, people don't board the 25 airplane with - you know, and then just say. 'Close 123 1 O. Okay. I'll ask it a different way. 2 A. Because we have had -- You know, he's got 3 a goddaughter and godson that were young. I mean. 4 O. Okay. Over the years -- 5 A. I mean, I don't know what the purpose -- 6 O. Right. I totally understand what you're ? saying. 8 Over the years. when you were on Jeffrey 9 Epstein's airplane, were you aware between 2001 and 10 wherever you stopped, 2007 -- 11 A. Seven. 12 O. -- were you aware of girls that appeared very 13 underage on the airplane? 14 A. No. 15 MR. PIKE: Form. 16 BY MR. EDWARDS: 17 O. I'm not saying what was happening on the 18 airplane. I'm just saying, were you aware of it? 19 A. No. not • unless they were there, like I 2o said, his goddaughter at the time. One time • a 21 couple times we flew her with her mom and dad where I 22 don't even know their age. 23 MR. PIKE: Again, 1000. asked and 24 answered. 25 A. Six or seven. But, no, I was not aware of 122 1 the door, we're going.- You know, you see who boards 2 tho airplane. 3 O. So if there wore flight records that show 4 underage gins on the airplane, you would know about it? MR. PIKE: Form. 6 A. Not necessarily. 7 O. Well, how not? MR. REINHAF17: I'm sorry. 9 A. Well how do you -- 10 MR. REINHART: When you say 'them,' do you 11 mean he would know about the records or he would 12 know about the girls allegedly on the plane? 13 BY MR. EDWARDS: 14 Q. You would know about the underage girls on the 15 airplane if they wore on there. 16 MR. PIKE: Form. 17 A. How do you -- How would I know that 18 they're underage. though? 19 O. Well, you would only know that they look 20 extremely young, right? 21 A. But -- 22 MR. PIKE: Form. 23 A. -- what is the intent of them? I mean, 24 are they guests or are they friends of his associates 25 or -- 124 1 anybody that was obviously, blatantly underage. 2 O. Any famous people that you can tell me that 3 were on the airplane? 4 A. President Clinton - Ex-President Clinton. 5 O. Were you on the airplane -- 6 A. Yes. 7 O. -- when he was on it? A. Yes. 9 O. How many times? 10 A. Two trips. I mean, two extended trips. 11 O. Where did it go? 12 A. The first one - or the first one was Asia. 13 O. What purpose? 14 A. I forget what the purpose was on that one. 15 O. Was Jeffrey Epstein on the airplane as well? 16 A. Yes, yes. 17 O. Who else was on the airplane then? 18 A. I don't remember on that one. It was 19 primarily him and his su rt staff. 20 a Was 21 A. Probably, yes, probably. 22 O. When's the next time President Clinton was on 23 his airplane? 24 A. I dent remember the date, but we did a 25 Africa trip, an AIDS awareness tour. We did like ten • 0 ESQUIRE Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresofutions.com 3501.150-002 Page 33 of 92 CONFIDENTIAL EFTA_00068825 EFTA01247053 Larry Eugene Morrison - Volume I October 6, 2009 125 1 countries in 12 days. 2 O. Is that a time Chris Tucker -- 3 A. Yes. 4 O. and Kevin Spacey were also on it? A. Yes. 6 O. In addition to the people that we've named. 7 wore there females on that airplane? A. Yes. 9 O. And who were the females that were on the 10 airplane? 11 A. Can't remember. Ms. Maxwell, I can 12 remember, and a oouple others, and there's - Mr. 13 Clinton had - a couple of his support staff were 14 women also. 15 O. Where wore you sitting during these trips? 16 A. Up front in the - my station. 17 O. Could you see what they were clang where you 10 wore? 19 A. No, no. 20 O. Could you tell If there was any sex going on 21 on the airplane while you were on it? 22 A. No. 23 MR. PIKE: Form. 24 BY MR. EDWARDS: 25 O. Do you know of any underage girls being on 1 2 7 1 MR. EDWARDS: No. I mean, unless 2 everybody wants to lake a lunch break. 3 Everybody's shaking their heads, so, no, I'm 4 going to take a bathroom break. and its going 5 to be a fast one. 6 MR. PIKE: Okay. 7 BY MR. EDWARDS: O. In 2001, when you're on this flight to New 9 York and then during that year we talked a little bit 10 about it, is Larry Visoski and David Rodgers also on some 11 of these flights? 12 A. Most, yes. 13 O. If somebody's going to keep passenger logs. 14 who's gang to write down the names of the people? Is 15 that going to be you or is that somebody else's 16 responsibility? 1? A. Whoever is captain. 18 O. So normally its Visoski or David Rodgers? 19 A. Correct. 20 O. Who do you turn these logs into? 21 MR. PIKE: Form. 22 A. I don't know. I don't know where they go. 23 O. You don't know the purpose behind keeping them 24 or anything? 25 A. No. 1 2 3 4 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 126 that airplane or would you have been able to tell? A. No. MR. REINHART: Im sorry -- MR. PIKE: Asked and answered. MR. REINHART: -- are you limiting it to that trip? BY MR. EDWARDS: O. To that trip. A. No, I'm not aware of it. O. II you had been aware of underage girls being transported on the airplane for the purposes of sex. would you have said something to somebody? A. Yes. MR. PIKE: Form. MR. EDWARDS: Do you mind l we take a five-minute break? I just have to run to the bathroom. MR. PIKE: Actually, Brad. can you hear me? MR. EDWARDS: Yes. MR. PIKE: How much longer do you anticipate going with this witness? MR. EDWARDS: Hour, maybe a little longer. MR. PIKE: Well, are you going to take a lunch break or what? 9 10 11 12 13 14 15 16 1? 18 19 20 21 22 23 24 25 128 1 O. As far as you're concerned, you don't even 2 need to keep them. 3 A. Correct. Yeah. 4 O. As just due diligence - going above and 5 beyond? 6 A. Correct. 7 O. Today you have an attorney sitting right next 8 to you, right? A. Correct. O. Is that somebody that you've known tor a long time? A. No. O. You're paying for an attorney to sit here with you? A. O. A. O. No. Who's paying for your attorney? Mr. Epstein. Are you worded that you're criminally involved here or something? Is that why you need an attorney? A. No. I don't even know anything about this process, that's -- O. Oh. okay. A. I'm just You know. O. How did you know that you were S ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com • • • 3501.150-002 Page 34 of 92 EFFA_00068826 EFTA01247054 Larry Eugene Morrison - Volume I October 6, 2009 • • 129 1 MR. PIKE: Brad. Brad. Brad. 2 O. - going to get an attorney - 3 MR. REINHART: Brad, hold on. 4 MR. PIKE: Whoa. Whoa. Stop. 5 MR. EDWARDS: I'm listening. 6 MR. PIKE: Brad. 7 MR. EDWARDS: Go. 8 MR. PIKE: You are not allowing the 9 witness to finish his statements throughout this 10 entire depo. Please. I'm on the phone. You 11 start your question before the witness is 12 finished. I'm sorry for raising my voice, but 13 you must allow the witness to finish his answer. 14 please. 15 MR. EDWARDS: You got it. 16 THE WITNESS: What was your question now? 17 I forgot. 1a MR. EDWARDS: I'm sitting here looking at 19 the witness and have a feeling we're going to be 20 sitting here for 30 minutes, but I will do that 21 for you, Mr. Pike. 22 MR. PIKE: Alright. 23 THE WITNESS: What was the question again, 24 please? 25 MR. EDWARDS: Can I ask the question again 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 131 1 this case against Mr. Epstein? 2 MR. REINHART: Let me ask him not to 3 answer that. 4 MR. PIKE: Form. MR. REINHART: It's privileged. MR. EDWARDS: It's privileged between Mr. Epstein and you, but is it privileged between the two of you? MR. REINHART: Between Mr. Mornson and me. BY MR. EDWARDS: O. Is it your understanding that he represents you or he represents Mr. Epstein? A. He represents me. O. Okay. Do you think that you've done anything wrong criminally? A. No. Q. Do you think that you're being sued civilly? A. No. O. And you have no reason to be sued civilly, right? A Correct. O. Did you talk to Mr. Epstein prior to taking your deposition today? A. Oh, no. I haven't talked to him in wel 130 1 or wait? IN wait for you. 2 MR. PIKE: If I'm ready. 3 MR. EDWARDS: I already asked the 4 question, so we're waiting. 5 MR. REINHART: I think the witness asked 6 you to repeat the question. 7 MR. EDWARDS: Are you good? Alright. 8 BY MR. EDWARDS: 9 O. Who hired your attorney? 10 A. Mr. Epstein. 11 O. And do you have any idea why, if you're a 12 witness In a case • no problems criminally - why you 13 personally have an attorney paid for by Mr. Epstein to 14 sit here with you? 15 MR. PIKE: Form. 16 A. No, I don't. 17 O. Do you want an attorney to sit here with you 18 while I ask you questions? 19 MR. PIKE: Form. 20 A. I don't know what the proper protocol is. 21 O. Okay. 22 A. I have very limited exposure to anything 23 like this. 24 O. Hoiv did this come about to where you have an 25 attorney as a witness - completely innocent witness in 132 1 over a year-and-a-half, maybe two years, and that was 2 just a 'hello' because I'm at the airplane one day. 3 O. So how is it you know that Mr. Epstein paid 4 for your attorney? 5 MR. REINHART: Its privileged. 6 MR. EDWARDS: Okay. That answers my 7 question. 8 BY MR. EDWARDS: 9 O. Have you ever met Donald Trump? 10 A. Yes. 11 Q. How? 12 A. He was He boarded the airplane one day 13 when ours was on the ramp. 14 O. And did you talk to him? 15 A. Just he introduced himself and I 16 introduced myself. 17 O. And did he talk to Mr. Epstein? 18 A. No. Mr. Epstein wasn't present. I was 19 doing maintenance. 20 O. And did he fly on the plane? 21 A. No. 22 O. Not that time? 23 A. Never. 24 O. You think he never flew on the plane? 25 A. On our airplane? • ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Ofas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 Page 35 of 92 EFTA_00068827 EFTA01247055 Larry Eugene Morrison - Volume I October 6, 2009 :33 1 O. Yes. 2 A. No. 3 O. So If somebody has given testimony other than 4 that, you would say that person is mistaken or lying? 5 MR. PIKE: Form. 6 A. Donald Trump was never on the airplane 7 when I was on the airplane. O. Is it your understanding that Donald Trump is 9 friends with Mr. Epstein? 10 A. From what I've road • Or associates. I 11 don't know how that circle works. 12 O. What's your understanding as to who Mr. 13 Epstein's real friends aro? 14 A. I really don't 'mow. I don't I don't 15 know. It's It's not lee the Wexners whore. you 16 know, they were high school associates. you know. 17 grooving up. 18 O. Do you know what Mr. Epstein did prier 10 19 managing the money for Mr. Wexner? 20 A. Just that he was a Wall Street broker or 21 somebody, you know. 22 O. Also from reading? 23 A. Yes, yes. 24 O. Do you know any personal knowledge as to what 25 Mr. Epstein has told you about how he made money? 1 2 3 4 5 6 7 a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 :35 A. I have no idea I don't know. O. When you say that -was lust comet in the icture. what's your understanding as to who is relative to Mr. Epstein? A I dont know. I dont understand. I don't know. I didn't know if maybe she was like an exchange .• Jeffrey always appeared to be very involved in education and phaanthr0PY. I didn't know if she was an exchange-type student or something or what. I dont know. O. When you say he appeared to be *involved what do you mean? A. Educational things, foundations, science foundations, and things. O. Speaking of - the Florida Science Foundation is a place where. when he was on work release. he spent a IN of time there. you're aware of that? A. That's what I've heard, yeah. O. What does that place do? A. I have no idea. O. Does it do anything? A. I dont know. I don't know anything about it. O. Certainly you've read certain newspaper articles about the allegations. Polide MOM 134 1 A. He's never -- 2 MR. PIKE: I'm going 10 move to strike any 3 responses relative to what the witness has 4 learned from reading. 5 BY MR. EDWARDS: 6 O. And so that is why I asked the question: Has 7 Mr. Epstein told you? Which would have nothing to do s with reading. 9 A. No. 10 O. How many conversations have you personally had 11 with Mr. Epstein? 12 A. No personal conversations - all business. 13 O. Have you witnessed AncEpstoinvath any VS 14 that look to be under the aged 18? 15 A. No. 16 O. Have you witnessed Mr. Epstein with 17 younglooking girls that appear to be in their twenties? 18 MR. PIKE: Form. 19 A. Yes, 20 O. On how many Oteasions? 21 A. Probably several. 22 O. And how did that come about? 23 A. I mean, they show up and ride on the 24 airplane, you know. 25 O. And who are they, if you know? 1 2 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 136 otherwise, the allegations that occurred or have been alleged to have occurred at his Palm Beach mansion. Correct? A. Uh'huh. O. Correct? A. Correct. O. Given the nature of those allegations, would you leave with Mr. Epstein alone? MR. PIKE: Form. Move to strike. A. Yes. O. You would? A. (Witness nods head.) O. And why? A. Because I don't fear that he would try anything with He showed -- When I worked for him he showed me respect. He never -- I never -- He never showed me disrespect. He would ask how the family Is. I mean, not on a personal level, but an employer/employee. O. Right. Okay. A. He never showed me any reason not to trust hirn. O. Bul you're not a 13-year NO girl, so. A. No. but, like I say, he never showed me 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.corn • • • 3501.150-002 Page 36 of 92 EFTA_00068828 EFTA01247056 Larry Eugene Morrison - Volume I October 6, 2009 • • 137 1 any reason not to trust. 2 O. So maybe that's the reason why there were 3 hundreds of victims, right? 4 A. I don't know that there were. 5 O. So is it surprising to read the things that 6 you read about what was going on at his house? 7 A. Yes. MR. PIKE: Form. Move to strike. 9 BY MR. EDWARDS: 10 O. I'm going to ask you about -- I'm going to 11 mark them all In fact, I'm going to show them to your 12 attorney first because I'm going to mark them as a 13 composite - just to save time. 14 MR. REINHART: For the record, you've 15 handed me a stack of passenger manifests? 16 MR. EDWARDS: Yes. You can count them if 17 you want, doesn't matter to me, and we'll just 18 mark them as a composite • go through each one 19 of them. 20 MR. REINHART: If you're going to go 21 through each one of them, I don't need to count 22 them. Youll make a record on that. 23 MR. EDWARDS: Fine. I'm going to mark 24 these as Composite Exhibit I, and we'll count 25 them at the end. 139 1 know her if I saw her. 2 O. What did she do? 3 A. I don't know. I don't know. • O. Would it surprise you if she was in charge of 5 scheduling for the minors to come over to the house to 6 sexually gratify Mr. Epstein? 7 MR. PIKE: Form. A. Yeah, that would surprise me, yes. 9 O. Okay. She didn't do that while you were on 10 the airplane, right? 11 A. No, no. 12 O. Was Mr. Epstein on the airplane? 13 MR. PIKE: Form. When? 14 A. Yes. 15 O. And if it happened. it happened al a portion 16 of the airplane where you couldn't see it because you 17 were partitioned off? 18 A. What happened? 19 MR. REINHART: I'm sorry, can we just get 20 a timeframe? 21 MR. PIKE: Form. 22 MR. REINHART: Are we talking about this 23 MONT 24 MR. EDWARDS: Yes, we're talking about 25 that flight. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 26 17 28 19 20 21 22 23 24 25 138 (Defendants Composite I was marked for identification.) BY MR. EDWARDS: O. The first one's datec il. Can you tell me what we're looking at there? Just remember. I'm about as familiar ynth that type of sluff as a three year old. so help me out. A. Passenger manifest just showing basicely dale, time oft time on, the trip number of the year. I guess it would be - that seems high for the year - but trip number - that must be for the total • destination or departure point • destination. O. The trip number says. 'Sit.' What does that mean? A. Thai must be I don't know where they start that. That must have been total since he staned the airplane. That's way too many for the year. Obviously it's already - it's January. so it must have been total flights. O. Who's on that airplane? A. Nautical miles. statute miles, fuel burned, poundage. anal .1 O. DO you know A. I — I think I know het I think I would 140 1 BY MR. EDWARDS: 2 O. It anything happened on the airplane. it would 3 have been in a position where you couldn't see it anyway 4 A. That's correct. 5 O. Okay. 6 A. That's correct. 7 O. So you're nil saying it did happen or it didn't happen, you just Couldn't see past a certain 9 point. 10 A. Correct, and I don't know what you're 11 referring to as it . anyways. 12 O. 'It' is whatever sexual involvement there was. 13 A. Oh. Like you say, we can't see anything 14 back there anyhow because the doors are closed. 15 O. Did Mr. Epstein instruct you as to whether or 16 not to knock or just walk back there or never walk back 17 there or what was the instruction? 18 A. No. There was never actually a formal 19 instruction. Its proper protocol for any of these 20 gentlemen, or individuals that own these aircraft, 21 that that's their private zone. that you don't come 22 back unless you're needed, and then you can -- You 23 know, but it's not forebode, it's just proper. 24 O. You mentioned President Clinton on the plane. 25 How many girls were on the plane at the same time when • 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com 3501.150-002 Page 37 of 92 EFTA_00068829 EFTA01247057 Larry Eugene Morrison - Volume I October 6, 2009 141 1 President Clinton was on the plane? 2 MR. REINHART: Asked and answered. 3 A. Yeah, I don't remember for sure. There 4 was probably maybe live, if that, and Oral's 5 0. What were they -- 6 A. What? 7 0. Go ahead. A. Like I say, it was Ms. Maxwell, 9 maybe two others, one other. and then I think Mr. 10 Clinton had two ladies in his entourage - support 11 staff. 12 0. What age group are we talking about with the 13 ladies that were on the airplane? 14 MR. PIKE: Form. 15 A. Mid-twenties to forties. maybe. I mean. I 16 don't know exactly. 17 0. I mean. you know what a 13 or 14-year-old girl 18 looks like -- 19 A. Yes. 20 O. -- right? 21 A. Yes. 22 O. Most people do. 23 A. Yes. 24 O. You wouldn't mistake a 13 or 14 or 15 year old 25 fora 20 year old. 143 1 you familiar with a flight where Prince Andrew was on the 2 airplane? 3 A. I don't know if I remember him being on 4 the airplane or not. I know that he has been on the 5 airplane or one of the airplanes. I can't say for 6 sure. 7 0. Have you met him before? A. I can't remember. honestly. I know. 9 0. Can't remember meeting Prince Andrew? 1 o A. I know. I know. I *MI even know who 11 he was when I first heard the name, sorry. But, no, 12 I can't remember for sure, I'm sorry. 13 0. Theta like if E.T. walked on the airplane and 14 I don't know. 15 A. I know. Well -- 16 0. MOVIE III let you slide on that one. You 17 know who Prince Andrew is now. 18 A. Okay. Don't paint me as stupid. One of 19 Lady WS sons. right? 20 0. I mean, you know what he looks like now 21 A. You know, honestly. I don't know if I 22 could point him out to you, I'm sorry. 23 0. Alright. 24 A. Its Just 25 0. Well forget him. 142 A. No, no. 2 MR. PIKE: Fenn. 3 BY MR. EDWARDS: 4 0. So you're sure that the people that were on 5 the airplane - they were above the age of 18? 6 A. I believe s0. 7 0. Because you, in your experience. as well as the experience of most people your age, would know -- 9 A. Right. 10 0. - what a 14 or 15 year old looks like. 11 A. Right. 12 0. I'm going to go through the next flight log. 13 You tell me what we're looking at here. Who's on the 14 airplane? 15 A. That was a deadhead. Nobody's on it. 16 0. Why were the names crossed out? 17 A. Because there was no passengers. This was 18 - engin was West Palm Beach - West Palm Beach. What 19 date is Mis? 1/20/04? It was probably a test 20 flight. 21 0. Okay. 22 A. It was a training flight -- 23 0. Okay. 24 A. -- for Bill. 25 0. The next one -- Well, before I ask this: Were 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 18 19 20 21 22 23 24 25 144 A. I'm smart in some things. 0. Wel forget him. We'll forget him. Don't worry about it. What's this? What are we looking at? MR. REINHART: For the record, you handed him a manifest dated is that correct? THE WITNESS: January -- Yes. Correct. Palm Beach to Kennedy, same thing, fuel bums, loads. destination, time off, time on. Next, it was trip 312. Jeffrey is on it, M. David Mullen, M. Todd Myster (sic). and passenger, passenger. BY MR. EDWARDS: 0. Do you know Todd Meister? A. Ho's a friend of his, I believe. 0. Fathers Bob Meister? Do you know the names? A. No, I don't know that. 0. How do you know Todd Moister? A. I've rust heard the name. 0. From who? A. Larry Visoski. 0. Larry Visoski knows these people? A. I think Todd Meister has an airplane. or something like that. He's talked to their flight 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com • • • 3501.150-002 Page 38 of 92 EFTA_00068830 EFTA01247058 Larry Eugene Morrison - Volume I October 6, 2009 • • 145 1 crew. 2 0. For the most part, when you mention these 3 people's names. you mention them as if they're lust 4 passengers on the airplane and this is their world - s you're passing through, you don't know them. 6 A. Right. 7 0. But Visoski - would you say that he has a closer relationship with Epstein to where he might know 9 some of these people? 10 MR. PIKE: Form. 11 A. That could be an accurate • yeah. I mean, 12 he's been with Jeffrey longer. I mean -- 13 0. I mean, do you know that Visoski has a car 14 that is registered In Jeffrey Epstein's name? You don't 15 have anything like that, do you? 16 A. No. I did not. 17 0. Were you aware of that? 10 A. No. 19 0. Does Mr. Visoski tell you how far he goes back 20 with Jeffrey Epstein? 21 A. No, just. I mean, when he hired him. 22 whenever that was after Glimoher - that's all I know. 23 0. Do you know anything about Visoski's private 24 life? 25 A. A little bit. He's married and 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 O. A. 0. A. 0. A. 147 Well, do you know whose handwriting that is? No. no. I don't. It may be Larry's. Similar handwriting - Wait a minute. - as those - Let's see the one with the training because there's a different pilot on there. 0. Right. One where there Is nobody on it. right? A. This is Bilrs I can't - TNs is Bill's writing. I think he was having him fill out the paperwork. 0. Bill Hammond? A. Yeah, this was his training flight. 0. The first one is Visoski? A. Maybe. I can't say for sure. I really can't say for sure. 0. And this is? A. I don't know if that's the same handwriting or not. 0. Well, is there any indication up here that would tell us whose harxlwming rt is? David Rodgers and Larry Visoski -- A. No, because this is -- a are the pilots. 146 1 daughters. I mean -- 2 O. Then I wont go Into the rest of his private 3 life. 4 When it says. '1 pay, I pay: what does that S mean? 6 A. Ws TAX: P•A-X is short for 7 'passenger: It's a Met O. Okay. Look, this is somebody that is listing 9 names of people on an airplane. Theyre going out of 10 their way 11 A. Flight. 12 0. and then all of a sudden on No. 8 and 9 13 they say. 'one passenger: Is this person just getting 14 lazy or is there a reason why there's no name? 15 A. Like I say, just getting lazy and then 16 didn't know who the passenger was. 17 0. Well, they obviously didn't know who Todd 16 Meister was either • they wrote his name all wrong. 19 A. They did? 20 MR. PIKE: Form. 21 BY MR. EDWARDS: 22 O. Well, 'Meister' is not spelled like that, so 23 how did -- 24 A. I didn't -- I didn't know that. I don't 25 know how he -- How does he spell II? 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 148 A. Yeah, but they don't indicate - they don't indicate who's captain that day. You know. I'm not a handwriting expert. I can't really Honestly. I can't tell you for sure whose handwriting a was. 0. Let's keep Wis one out. and toll me If this is -- I'm going to hand MR. REINHART: MR, EDWARDS: MR. REINHART: Yes. BY MR. EDWARDS: O. so two days later where is this airplane going? A. From Kennedy to Palm Beach. 0. And so this Is Palm Beach to Kennedy - A. Yep. 0. in his exhibit. The next one is Kennedy to Pon Beach. A. Correct. 0. They come back. Where do they stay • do you know? A. What do you mean? 0. Well, they get off on theM they stay somewhere until they come back on the I. Do you know where they stay? MR. REINHART: Can we clarify who %hey ESQUIRE AtensinO•11•Caspay CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutionS.00m 3501.150-002 Page 39 of 92 EFTA_00068831 EFTA01247059 Larry Eugene Morrison - Volume I October 6, 2009 1 2 3 4 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 149 is? BY MR. EDWARDS: O. I guess it is: David Mullen. M MEM Tod Myster (sic). 1 pax, another pax. and Jeffrey Epstein - and there's a crossed out 'Ghislaine Maxwell? so I'm assuming she didn't go. A. Correct. I have no hoe where they stayed. I assume Jeffrey would stay in his home. M would stay in her apartment. As for an the others, I have no idea. O. Have you ever been to Jeffrey Epstein's home in New York? A. Just in the lower level of the entryway. O. Why did you go? A. To pick up bags for the trip to go to the airport and load them. Q. Was there anybody else there with him? A. I don't know with him. I never saw him him. We saw the guy that ran the house Q. Who's that - Joe-Joe? A. Joe-Joe would be there -- O. What's Joe-Joe's name? A. Joe-Joe, that's all] know, and then there's the actual house manager. Joe-Joe is more of 151 O. The next one is Palm Beach 2 to where? 3 A. St. Thomas. 4 O. To St. Thomas. 5 A. Right. 6 Q. And he has and M I and Jeffrey. 7 A. Right. 8 O. Does he loll you what happens in St. Thomas? 9 What he does there? 10 A. No, no. 11 O. Ever heard that he imports underage gins from 12 Brazil to his — 11 MR, PIKE: Form. 14 O. - Island in St. Thomas? 15 MR. PIKE: Form. 16 A. No, no. never heard that. 17 O. What does he tell you about his Island In St 18 Thomas? 19 A. Not a lot. I mean, he would sometimes 20 talk about construction stuff or I would hear him • 21 overhear him and Larry talk about the helicopter pad 22 that they're putting in, little stuff like that - all 23 COOstruCliOn. 24 O. Did he tell you two or three times a day, that 25 he sexually abuses girls between 12 and 15 years old? 150 1 a dnver, and then there's the house manager - 2 forget his name. 3 But, yeah. we would meet -- There's an 4 office in the lower level that the bags would be at. 5 and we would put them in the back of the van, haul 6 them to the airport. 7 O. Who's David Mullen? a A I don't know. I heard of il. It sounds 9 familiar. I can't remember who he is. 10 O. Somebody that lives in New York, Palm Beach? 11 A. I don't know. I don't know. 12 O. I'm trying to keep them in order. 13 So taming bad( - you know. it looks Ike they 14 take to JFK: David Mullen, Tod Myster (sic), some 15 passe era unnamed - they come back with only 16 and any idea why? 1/ MR. PIKE: Form. 18 A. No, but, I mean, ifs not unusual for 19 these guys to, you know, take somebody • lel somebody 20 have a free ride to New York il they know them. they 21 aro acquaintances, need a lift. I mean, that's not 22 unusual. 23 O. How's that come about - do you know? 24 A. No. I don't - phone conversations, 25 cosklail parties. I don't know. 152 1 A. No. 2 MR. PIKE: Form. 3 BY MR. EDWARDS: 4 O. Not something he ever mentions. 5 A. No, no. 6 MR. PIKE: Form. 7 BY MR. EDWARDS: 8 O. The next - who's on the passenger 9 list? 10 A. Jeffrey, M. MI, Jean Luc, David 11 Mullen, female, female, female. 12 O. Any idea why they would list -female, female, 13 female' without listing the names? 14 A. No, just the same as -- The only idea I 15 would have would be the same reasoning for the - 16 previously when they listed them as just 'PAX' - that 17 they didn't have any idea who they were, what their 18 name was. 19 O. I mean, certainly that's -- 20 A. I don't know whose handwriting that Is. 21 O. You're guessing, though, right? 22 A. Yeah. No, I'm guessing. I have no idea. 23 O. Another guess would be they're 12 years old 24 and you can't put them on it. 25 MR. PIKE: Form. 0 ESQVIEE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutions.00m • • • 3501.150-002 Page 40 of 92 EFTA_00068832 EFTA01247060 Larry Eugene Morrison - Volume I October 6, 2009 • • 1 2 3 4 5 6 7 9 10 11 12 13 14 15 26 17 18 19 20 21 22 23 24 25 153 A. I wouldn't say that. I don't know that. O. Have you ever been on an airplane where you looked at this and you thought, -Hey, that's kind of strange that they wouldn't list them by name. They're talking about it generically: Female, female, female'? A. But they also -- MR. PIKE: Form. A. on another one: PAX, PAX, PAX. O. You never thought that was odd either? A. No. I never actually even really paid attention to this paperwork. I don't see this. MS. EZELL: Brad, excuse me • this is Kathy Ezell - is there a date on that manifest you're showing? MR. EDWARDS: It's-. MS. EZELL: Thanks. MR. EDWARDS: Is that your 12-year old client listed as No. 6? MR. PIKE: Form. Move to strike. MS. EZELL: No, but -- MR. EDWARDS: Okay, sorry, somebody eleet. MS. EZELL: Okay. Thanks. BY M DS: O. whop on them? 155 1 what n says 2 A. It's •• I think it's aM. 3 Q. Alright Can you tell us who's on that 4 airplane? 5 A Jeffrey, looks like M, - is that 6 Jean Luc? O Yeah. a A. That's Jean Luc. I think. and 9 10 O. Jean Luc is another one who travels Quite 11 frequently. Why, if you know. does he travel quite 12 Irequentkr on these airplanes to and from New York with 13 Jeffrey Epstein - any idea? la A. My only assumption was business, and 15 that's just an assumption. 16 O. What kirKI of business do you know of that they 17 have in common? 18 A. I was under the impression a modeling 19 business. 20 O. Other than the modeling agency, %Mat other 21 business do they engage in together. if you know? 22 A. I don't know. 23 O. Arid has Jeffrey Epstein ever talked to you 24 or loud enough to which you could hear him discussing the 25 modeling agency? 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 154 A. Ja i n ME. David Mullen, Jensen, O. Do you lawny who Jansen is? A. No. O. David Mullen travels a lot. Do you have any idea whet his relationship is with Mr. Epstein? A. I don't even know who David Mullen really is O. Have you ever seen him? A. I might be able to place him if I saw a picture of him. O. I mean, obviously you're on the airplane with him a lot. A. Yeah, so. I mean, obviously I would recognize him if I saw a picture. O. Do you know if he travels with anybody else on this? A. Unless It's that one name I don't recognize - that Jansen. or whatever. O. But Jansen's not somebody you know? A. No. no. O. I can't read that date • maybe you can. I got a bad fax copy. A. MaybeMl. O. That's Michael Pike not wanting me to know 156 1 MR. PIKE: Form. 2 A. No, just that the only conversation he 3 ever - I remember - was the one that he the one 4 aboul the girl opening the wrong door on the motor 5 home. 6 O. Was he happy or sad about the modeling agency/ 7 A. No. he was happy she wasn't injured. but 8 he was kind of making light of what a silly thing to 9 do, you know. 10 O. Do you know if Jean Luc is the one procuring II the models or IS Jeffrey procuring the models? 12 A. I don't know. 13 MR. PIKE: Form. 14 BY MR, EDWARDS: 15 O. You never investigated into how this modeling 16 agency is defog or anything else? 17 A. No. no interest 18 O. You try to stay completely out of it? 19 A. No interest. 20 O. Especially in light 01 the recent things 21 youve read. 22 A. I mean, I ain't have any interest in it 23 before all the recent things. 24 O I'm going to slop this one because it talks 25 about very similar people that you've already read. • 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutionS.com 3501.150-002 Page 41 of 92 EFFA_00068833 EFTA01247061 Larry Eugene Morrison - Volume I October 6, 2009 1 2 3 4 $ 7 8 9 10 11 12 13 14 15 16 17 3.8 19 20 11 22 23 24 25 157 A. Okay. O. No different names. MR. REINHART: Can we just get the date on the record? BY MR. EDWARDS: O. Well, actually, we don't have to skip it. that's the date. right? A. Right. O. And it says: Ghislaine Maxwell — A. Okay. and (81c); is that right? A. That's what it says. O. Is that a typical crew that you would see on the plane? A. What year is this? In .? O. Yes. A. Yes, but towards the end there, I think the last year, l only saw Ms. Maxwell once. O. Do you know of any falling out of sorts that Ohislaine Maxwell and Epstein had? A. Well, no. I think they still I think she still has a lot of association, or whatever. O. Do you think they are still a couple? A. I don't know that they ever were. I never 159 1 Stanleys are. 2 O. Ever heard of them? 3 A. No. 4 O. As far as you're concerned, they're some 5 islanders or something, right? I mean - A. Well, they might be mean MR. PIKE: Form. 8 A -- there's a tot of wealthy people down 9 there. They might have been friends or associates 10 that needed a lift back stateside. 11 O. Fair enough. 12 What's the next one? 13 A. Teterboro to PIK 14 O. And who's on it? 15 A. Jeffrey. =, and M. 16 MR. REINHART: Can we gel a date for the 17 record? 16 THE WITNESS: 19 BY MR. EDWARDS: 20 O. II seems like =and travel a lot 21 with Jeffrey. Is it ever your understanding that Jeffrey 22 Epstein had a sexual relationship with either of them? 23 A. That is not my understanding, no. 24 O. Do you know of having a boyfriend 25 ever? 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 11 22 23 24 25 158 did figure out the relationship, other than I assumed they were a couple and she was a business assistant - associate, but that was all assumption. O. Did you ever know of Jeffrey Epstein to have a girlfriend, per se? A. If it would have been, it would have been Ms. Maxwell. O. Other than Ms. Maxwell, could you identity any other female that appeared to be in a intimate relationship with Jeffrey Epstein? A. Not really, not that I - not that I could say it was a relationship, no. O. I'm going to show you another one. I don't know these people. Tell me who they are. It looks like you're on the airplane -- MR. REINHART: Can we et a -- O. -- and the date A. Right. O. It's going -- A. I don't know who the Stanleys are. O. And it's going from the island. A. To -- O. Palm Beach. A. Palm Beach. I don't know who the 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 18 19 20 21 22 23 24 25 160 A. I heard that she has a boyfriend. O. And what's his name? A. And this is just hearsay. I don't know. O. I'm interested in hearsay. A. I heard that she's dating somebody - that's all. O. °atm whom? A. O. phonetic)? A. I don't know his last name. O. How long has she been dating him? A. I don't know. This is just Larry, you know, every once in a while asks. you know, 'What's going on?' 'Who's' -• You know, I don't know. O. Where Wes aye? O. And is somebody who you heard of through Larry \kiosk'? A. Yes. yes. O. And SpeCifiCalty what did Larry Visoski say about A. He thought that they were dating he and - and this is all hearsay. O. Since when? 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esgulresolutions.com • • • 3501.150-002 Page 42 of 92 EFTA_00068834 EFTA01247062 Larry Eugene Morrison - Volume I October 6, 2009 • • 161 1 A. This is I don't remember. Some 2 time within • maybe within the year. I don't know. 3 I don't know. 4 O So its your understanding then (Mt 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 somebody named' fair presumption that nearby as well. MR. PIKE: Form. A. I mean, that's not necessarily so. I mean, in this day and age when you can get back and forth to New York via airlines, or anywhere; I mean, at times. yes, that would be a fair assumption, but not continuously., O. And what was the context in which the conversation came up where Larry Visoski says. • who you have very little knowledge. I mean, I don't want to say 'very little knowledge" you obviously have seen her several times -- A. Yes. 24 A. Right, right. 25 O. Othefwise, how would that come about? and he is dating • that It would also be a would be somewhere 163 2 O. And what else does he tell you? I mean, there 3 are other changes other than. 'Hey, dating A. A couple of the - couple of long time P800 03 were laid off. O. A. O. A. 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 21 25 And other changes to the island. You know, I can't remember all the names. I believe Adam, who was the chef, at the island left. MR. PIKE: Hello? BY MR. EDWARDS: O. Adam's the chef at the island? A. Yes. O. And why did he leave? A. I don/ - O. Epstein's not around to cook for? 162 1 A. I don't remember how it came about. 2 actually. I think I just - several months ago I 3 asked what people were doing since, you know, there's 4 been a lot of changes in staff since the boss was, 5 you know, detained. There's been a lot of layoffs 6 and stuff. The conversation was he was updating me 7 as to who's still around, who's been laid off, you 8 know. who's not with the company anymore. who's not 9 with, you know, at certain houses. xo Q. When you say 'the boss' has been 'detained.' 11 the boss obviously Is Jeffrey Epstein? 12 A. Detect. Yes. 13 O. And you're having a conversation then with 14 Larry Visoski about the changes that necessarily are 15 made -- 16 A. Right. 17 O. because the boss is — 10 A. Well -- 19 O. •• either incarcerated or under house arrest. 20 or whatever. 21 A. And the economy and everything, I mean. 22 O. In the course of that he tells u something 23 about. "Wel, is dating 24 A. Yeah, or - f think he said somelhin about 25 one of Jeffrey - 164 1 A. Yeah. It may have been a layoff kind of 2 thing • and the economy too. I mean, everybody's 3 affected. 4 Q. Whirs your understanding abotl l 6 A. Just that they were laid off. I don't 7 know the exact reasoning that they were laid off. a O. And before we go back to this: Have you ever 9 been to that Zono Ranch — to A. Yes. 11 O. in New Mexico? 12 A. Yes. 11 O. How many times? 14 A. Several. 15 O. Why? 16 A. Because when we take them out there it was 17 too far to airline home. so we'd stay - stay at the 33 ranch. 19 O. And what was he there to do? 20 A. I have no idea. 21 O. Wee, you were al the ranch. right? 22 A. Yeah, but ifs a big complex. There's 23 The main house is literally probably 3 or 4 miles 24 from where we eta 25 O. Was there also? EN? • 0 ESQ.vjem Toll Free: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esguiresolutIons.com 3501.150-002 Page 43 of 92 CONFIDENTIAL EFTA_00068835 EFTA01247063 Larry Eugene Morrison - Volume I October 6, 2009 165 1 A. I'm sure at times, yes, yes. 2 0. Well. I mean. usually he goos with his 3 A. The normal -- 4 0. -- his ` h i s Ghistaine. 5 A. Yeah, his normal entourage. or whatever it 6 Is. 7 0. And was somebody there to schedule his people to come over and see him on a daily basis? 9 A. I don't know. I don't know how that 10 worked. 11 0. He's - 12 A. Like I say, he's up at the main house. 13 Once we were at the ranch there's really no contact. 14 0. Yeah, but I'm familiar with where this ranch 15 is. and it's kind of in the middle of nowhere, right? 16 A. Yeah. 17 0. And, you know, so when people come to or from 18 the ranch. I mean. you can't help but almost be familiar 19 that somebody's coming, right? 30 A. Well - 21 MR. PIKE: Form. 22 A. •• I mean, you would see a car drive by or 23 something or a truck. There's always a lot of 24 activity. constriction, and everything else going on. 25 Where we stayed at Ranch Central, the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 24 25 167 Mexico ranch? A. Oh, no. no. 0. You don't remember that? A. No. 0. Could it have happened? A. It could have. O. But you just don't remember seeing that. A. No, I don't ever remember seeing that. 0. Have you ever met Governor Bill Richardson? A. I saw him. He was -- 0. How did you see him? A. He was at Ranch Central. He had been invited for dinner, or something, at the main house and they were corning down to get him. 0. He was invited to the Zono Ranch. I can it that because that's apparently what Mr. Epstein's named a right? A. Yes. O. So Bill Richardson came to the Zone Ranch for what? A. I It was a dinner meeting or something, don't know. A. I think Mr. Richardson used to own the properly the ranch was built on. or something. I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 166 small, little - basically like little hotel rooms where we stayed. you know, it was on a busy road because there was always like a lot of construction stuff arid the ranch hands and everything up and down. 0. Did you see girls going to visit him there? A. Yes. 0. How often would girls go to visit him there? A. I don't know. 0. Oid these A. Not that often. 0. Did these seem like girls local to Now Mexico or had they just flown in on an airplane. landed a helicopter on the property? A. Oh, I don't know. I never -- MR. PIKE: Form. A. I never saw them up close. I mean O. Did they come in taxicabs? MR. PIKE: Form. A. I can't remember that • don't think so. 0. You don't ever think a girl came in a taxicab to the New Mexico ranch? A. I don't ever remember seeing a taxicab on the ranch. 0. Do you remember seeing girls two or three limes a day going to visit him while he was at the New 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 168 don't know. 0. Did you stay for the dinner? A. Oh, no. no. I was down at Ranch Central and he was jusl there while they were going to escort him up to the main house. 0. So Bill Richardson was where Epstein was where the dinner was. A. Yes, yes. 0. And you were not there. A. Of course not. 0. Who else besides Bill Richardson was there? A. I have no idea. 0. Any knowledge of Bill Richardson being involved with any of the gals that would have been brought to the house? A. Oh, no, no, not that I have. 0. Not that I know of. A. Not that I know, no. 0. Because you were in such a place that you never would have known anyway, right? A. That's correct, yeah. 0. What's your understanding as to Bill Richardseres connection to Mr. Epstein? A. I thought he was always just kind of politics. I believe • I heard at one time. I don't ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 wvootesquIresolutions.coM • • • 3501.150-002 Page 44 of 92 EFTA_00068836 EFTA01247064 Larry Eugene Morrison - Volume I October 6, 2009 • • 169 1 know for a tact - I thought that part of the property 2 the Zorro was built on was owned by Bill Richardson. 3 He sold it to Jeffrey. 4 O. Ever known Bill Richardson to be on Epstein's 5 airplane? 6 A. No, not the Boeing. 7 O. Any plane. 8 A. I don't know that. 9 O. Was he ever on a plane that you were on? 10 A. No, not that I remember, not that I 11 remember. I remember -- I believe the only time I 12 met him was one time al Ranch Central. 13 O. Ever hear of a trust - Zorro Trust? 14 A. No. 15 O. Are you familiar with some of Epstein's 16 COrnpanies? 17 MR. PIKE: Form. 18 A. No. I mean, other than JEGE and Hyperion 19 and Air Ghislaine. 20 O. What's Air Ghislaine? 21 A. That's the helicopters that's what 22 they're under. 23 O. He named it after Ghislaine Maxwell? 24 A. Apparently so. I would assume so. 25 O. Well. I mean, I'm not trying to be difficult 171 1 O. You've never heard that? 2 A. No. no. 3 O. Have you ever boon privy to any conversations 4 between Bill Richardson and Jeff Epstein? 5 A. No. 6 O. So you don't know what they were really 7 talking about. a A. No. No idea. 9 O. At the time when Bill Richardson was running 10 for president is that around the time when you remember I him being at Zone Ranch? 12 A. Before. before. What year did he run for 13 president? 14 O. 2007. 15 A. It had to have been well before because I 16 quit flying in February of '07. so. 17 O. Epstein ever tell you what his relationship is 18 with Bill RIChar0SOn7 19 A. No. 20 O. When you were at the ranch. did you over 21 notice underage girls al the ranch? 22 A. No. 23 MR. PIKE: Form. 24 BY MR. EDWARDS: 25 O. Anybody ever told you that that ranch is used 170 1 with you. 2 A. No, I wouldn't -- 3 O. I'm assuming you're not trying with me either. 4 A. No. I would assume so. I mean, that's an 5 unusual name. 6 O. Do you know Prince Andrew to be friends with 7 Jeffrey Epstein? 8 MR. PIKE: Form. 9 A. No, I don't know that — I don't know what 10 the tie Is. Like I say, I didn't know even know who 11 Prince Andrew is when I first heard of it. I would 12 have thought it would have been more of a tie with 13 Ms. Maxwell. 14 O. Right. Do you know of Ms. Maxwell bringing 15 the two. that being Prince Andrew, together with Mr. 16 Epstein? 17 MR. PIKE: Form. 18 A. That Oeuld be. yes. yep. 19 O. And at the time when Bill Richardson had this 20 meeting at Epstein's house. do you remember Glistaine 21 Maxwell also being there? 22 A. Can't say for sure. Can't say for sure. 23 O. Have you heard of Jeffrey Epstein winning the 24 lottery in New Mexico? 25 A. No. 2 1 4 6 8 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 24 25 172 to transport girls through Mexico to the ranch? A. No. MR. PIKE: Form. BY MR. EDWARDS: O. The next exhibit that I'm going to show you - which is all part of Composite Exhibit 1 - is a fight is that right? A. Yes. O. Who's on that? Nobody. That's a test flight? A. That's a test flight round robin. k's Only 17 minute. O A. PBI to Kennedy with Jeffrey, O. Do you know what his relationship is with /NS? A. No. O. Do you know what she does for him? A. No. only Isn't that the one that you told me you just mentioned earlier? I have no idea what her relationshp O. Has he ever told you what any of his employees actually do for him • why ho employs so many people to do so many different things - has he told you that? MR. PIKE: Form. • 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 WWW.esquiresolutions.com 3501.150-002 Page 45 of 92 EFTA_00068837 EFTA01247065 Larry Eugene Morrison - Volume I October 6, 2009 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 173 A. No, no. I mean, you know, who runs each house and who the driver is. stuff like that. No. he would never mention that. 0. Has he ever told you what running a house entails? A. No, no. 0. Has he ever told you that there's an extra pan of running the house that ensures that underage girls are going to be there for him every day? A. No. MR. PIKE: Form. BY MR. EDWARDS: O. That's not something you ever heard. A. No. 0. Ilight log who's on it? A. Jeffrey, Ghislaine Maxwell. David Mullen. 0. David Mullen - once again, we don't know who this guy is, do you? A. And I don't know. Honestly, I can't -- 0. Do you know where he lives? A. No. 0. Did you ever go visit Jeffrey Epstein while he was in jail? A. No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 17$ 0. And despite pleading guilty to procuring underage girls for the purposes of sex, you still feel comfortable leaving a 13. 14, 151rear-old girl around him? MR. PIKE: Form. Move to stoke. A. Yes. I meanlares. I don't know how he behaves around anybody else. I just know that the reseed that he showed me, I feel safe with my daughter. 0. And have you read in detail the reports as to what happened at his house with the girls? A. Only — MR. PIKE: Form. A. -- what's been in the newspapers and published. 0. If you read and hear testimony given • well, I can tell you now - testimony has been oven in ths case that what happens is: A 13 or 14 year old is led upstairs by herself, told to get naked, he lays down on his back, there is a oriel massage before he turns over. exposes himself erect. masturbates while he tells this 13 or 14 year old to pinch his nipples as hard as she can while he inserts his fingers into their vagina and ejaculates all over them before saying, *Take your money and leave.' 1 2 3 4 5 6 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 174 0. Why not? A. There was no purpose to it. There was no need to. 0. He's your boss for a long time, right? A. Yeah. O. Was he good to you? A. Yes. O. Did you support him? A. Yes. O. You supported him while he was in jail? A. I was -- Yes. I mean. 0. Did the allegations bother you? A. Yes. MR. PIKE: Form. BY MR. EDWARDS: 0. Somebody that you still support despite the allegations? MR. PIKE: Form. A. Yes, yes. 0. You realize that he did plead guilty to the Offenses as well, right? A. That's what I read. MR. PIKE: Form. Move to strike. That's not the fads. BY MR. EDWARDS: 176 1 MR. PIKE: Form. Move to strike. 2 8Y MR. EDWARDS: 3 0. Okay? Then, 'You can continue to come back 4 for $200 every time or every girl you bring me within 5 your age group and I get to do this again. I pay you 5200 6 per person.' If that is the testimony -- 7 MR. PIKE: Form. 0. — that what happens behind closed doors with 9 him, do you still feel comfortable leaving a 13 or 14 10 year old in a room with Jeffrey Epstein? 11 MR. PIKE: Form. 12 A. If that, in fact, is what actually 13 happened. no. 14 0. I'll show you the next flight I is 15 Here. just so these are In order, I'll - 16 A. Okay. 17 0. Who's on that airplane? 18 A. Jeffrey, and 19 0. Seem to be people that he travels with 20 frequently. 21 A. Yes, normal - his normal entourage. 22 0. Have you read recently the agreement that was 23 entitled the 'Non-Prosecution Agreement'? 24 A. No. All I read was what was in the paper. 25 0. The 'Non-Prosecution Agreement' was an ESQUIRE O CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, Fl 33301 www.esquiresolutIons.corn • • • • 3501.150-002 Page 46 of 92 EFTA_00068838 EFTA01247066 Larry Eugene Morrison - Volume I October 6, 2009 • • 177 1 agreement between Epstein and the government where the 2 government agreed. 'We're not going to prosecute you for 3 only the sex crimes we know about: and in that they also 4 agree not to prosecute Jeffrey Epstein. IM= 5 In of IM 6 A. Okay. 7 0. as his co-conspirators. Do you know any of the acts that M, 9 or have done in an attempt to get Jeffrey Easton 10 young girls to molest? 11 A. Only what I've read in the paper. 12 MR. PIKE: Move to strike. 13 BY MR. EDWARDS: 14 0. Again, Jeffrey Epstein, Ghislaine Maxwell. and 15 who's that? 16 MR. REINHART: Can we get a date, please? 17 BY MR. EDWARDS: 15 0. Sony, the date is_. On this night 19 log, who are the names? 20 A. Ohislaine -Jeffrey. Ghislaine Maxwell 21 22 0. Do you know Ghislaine Maxwell on a social 23 level or only from hem? 24 A. No. just professional. 25 0. Do you know whether she is straight or and MM. 179 1 0. This is the first time we've seen 2 mentioned on any flight logs. right? 3 A. Right. 4 Q. Do you find it at all peculiar that 5 is listed but certain other people who may or may not be 6 of age are listed generically - one female. Why would 7 they go out of their way to list MR. PIKE: Form. 9 A. I don't know. Maybe she was already an 10 employee or something. I don't know. 11 Q. If she's an employee at the time, then that 12 would be a good explanation, right? 13 A. Right. I don't know. 14 0. If she's not an employee, then is there any 15 explanation? 16 MR. PIKE: Form. 17 A. Unless No. I don't know. I don't le know. Maybe &9 asked her. That looks like Bel's 19 writing there when he was captain. 20 0. We'll move to 21 A. Okay. 22 0. Who's listed? 23 A. Actually. this wasn't even my flight. 24 This is: Jeffrey. female, female 25 • PEN to Kennedy. 1 2 3 4 6 7 a to 11 • 13 14 • 16 17 le 39 10 21 22 23 24 178 bisexual? Do you know of any of hot girlfriends? A. 'do not know that 0. Are you aware that Ghislaine Maxwell, in sworn testimony and in complaints. has been alleged to have used vibrators. dildos. and have sex with these underage girls as well? A. I dont -- MR. PIKE: Form. A. I was not aware of that. 0. Do you know who s? A. I think IM used to be her VIII 0. Used to be Ghislaine Maxwell' A. I batiste so, yeah, because 0. Do you know if is underage or if she is of age at the time that this happened - at the time they list her name? A. Ofi, I dont know for sure. but. I mean. she when I ff it is the I remember. she was older. I mean, I cant even guess her age, mid-twenbes. tate twenties. I mean. 0. Okay. Do you -- A II it's the I remember. 180 1 0. Mars not your flight? 2 A. No. George Diaz is one of the few 3 engineers I used as a relief. See his name wntlon 4 in up there? 5 0. Yes, but it has your name written under it 6 right? 7 A. Well. yeah, because these are preprinted a forms. They neglected to scratch my name out. 9 0. Any idea why now they're going to list 'one 10 female, one female'? That doesn't seem to be protocol 11 hero. does it? 12 A. I don't -- Yeah. I have no idea. I don't 13 have an answer for that, I really don't. 14 0. Certanly, if you're able to get Ss to 15 tee you her name. it doesn't take much effort to get two 16 other people to tell you their name. right? 17 A. Like I say, the only thing I can thnk ol le VIII■an employee by twat time, that they knew 19 her. I don't know. 20 0. Did it ever at any point in time cross your 21 mind that there may be something illegal going on here - 22 ever? 23 MS. EZELL: Form. 24 MR. PIKE: Form. 25 A. Define Mere.' • ESQUIRE Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com 3501.150-002 Page 47 of 92 CONFIDENTIAL EFTA_00068839 EFTA01247067 Larry Eugene Morrison - Volume I October 6, 2009 1 2 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 181 D. Here when you're traveling on the airplane with these various girls and they're listed as 'one female' - generically listed - anything ever cross your mind, 'maybe something's not exactly kosher? A. No. MR. PIKE: Form, asked and answered several times. BY MR. EDWARDS: O. Who's that? The date is A. Jeffrey, Ghislaine, and O. Let's see,MI and `both look like nobody's on thorn, so show them to you together. A. There might be remarks here: 'Maintenance test flight' out of Lake City. Florida. We were coming out of maintenance: 'No passengers, maintenance, relocation for the engineer repair.' O. Okay. who's on it? A. Jeffrey, , David Mullen. Min 0. Last one. A. a8/8Mr David Mullen. Mark Zeff -- O. Do you know who Mark Zeff Is? A. No - Daniell, Doug Shuttle, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 la 19 20 21 22 23 24 25 183 A. I can't -- I can't say for sure. I mean, we used to carry a massage table on the airplane. I never saw one used. I don1 know for sure. O. Are you being paid to be here today? A. No, no. I mean, I'm on salary. I mean -- O. Right. A. -- because of • for the maintenance. but. no. O. Are you going to ask Jeffrey Epstein at some point in time, 'Why you hired an attorney to sit hero with me?' A. No. MR. PIKE: Form. A. I would never — I would not approach Jeffrey for that. O. Do you have any idea why Jeffrey Epstein might want an attorney to sit here for you? MR. PIKE: Form. A. No. I mean, maybe -- I dont know. O. Do you think that the attorney silting here is for the purpose so that you don't say anything to incriminate Jeffrey Epstein? A. No, no. I was told strictly that he was here upon my behalf. O. Do you know of any crimes, personally, that 1 2 3 4 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1.82 O. Do you know who Daniell and aro? A. I think. I remember • sounds familiar. O. How did she look? A. I cant remember. I just -- O. Overage, underage? MR. PIKE: Form. A. I never saw any that I saw that looked to me underage. O. Have you ever been to Jeffrey Epstein's house - his Palm Beach house? A. Yes. G. You stayed for an emirs day? A. No, no. 0. No? A. It would be like an hour at the most waiting to talk to him for a minute. No. O. Let me ask it this way: Has he ever told you that he's infatuated with massages? A. No, he's never told me that. MR. PIKE: Form. BY MR. EDWARDS: O. Have you ever known him to get a professional massage anywhere you go? A. Yea I believe so. O. Where? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 la 19 20 21 22 23 24 25 184 you witnessed Jeffrey Epstein committing? A. No. O. Would you -- A. No. O. -- go back - considering what you've read and what you may or may not believe - would you go back to working for Jeffrey Epstein? MR. PIKE: Form. A I can't say. I still work for him on a maintenance - to maintain the airplanes and stuff like that. so. O. You're on his payroll? A. Salaried, yes. O. Do you know who else is on his payroll? A. Well, Dave and Larry. O. Certainly. if I want to know more about his private life - do you know who's at his house? A. No. O. Do you know who his housekeeper is? A. No. O. Do you know who his architect is? A. No. no. O. Does Larry visit him at his house? A. I would assure so. O. Why do you say you would assume so? That 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esguiresolutions.com • • • 3501.150-002 Page 48 of 92 EFFA_00068840 EFTA01247068 Larry Eugene Morrison - Volume I October 6, 2009 • • 185 1 means he told you something, right? 2 A. Well, he handles Jeffrey does a lot of 3 • he likes high-end stereo equipment and video 4 equipment, and Larry is an expert at audio and video 5 installations and stuff. 6 0. How about David Rodgers - ever at his house? 7 A. Probably, but more like on the grounds of 8 me, you know. 9 0. My other famous people that you met through 10 Jeff Epstein? 11 A. On the airplane? 12 O. Yes. 13 A. Walter Cronkite. 14 0. Oh, yeah? 15 A. He was very nice. Yeah. He was very 16 feeble, but he was very nice. We had to carry him 17 down the steps. 18 0. Where did that flight go to? 19 A. New York to St. Thomas. He's an avid 20 sailor. He loves to sail or loved to sail. 21 0. what's the magician's name - David 22 Copperfield? 23 A. No, I don't think I was on that. I don't 24 think I flew that. I heard that we had flown him. I 25 can't say for sure. I would remember that. I would 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 187 A. Yes, I guess. Yeah. I don't know exactly. 0. Have you ever heard of sounds familiar, but I don't know -- 0. Model? New York? A. No, I can't say that I have. 0. A. Can't say that I have. 0. Glenn Dubin? A. Glenn Dubin, yes. 0. How do you know him? A. I think he's a money or finance manager of some form - associate of Jeffrey or Ghislaine's or both. 0. And where does he live? A. I think he lives in California, I believe. 0. What do you know about him? A. Well, he's • just all I just told you. I think he's - he's an options writer or something like - not an options writer, hedge funds or something like that. He's in money. Its -- He's got an airplane. I think he's got a quarter share or part of an airplane. 0. DO you know anybody that owns any property A. 186 1 remember B. I have never met David Copperfield, but 2 I heard that we had. Naomi Campbell - flew her a 3 couple tines. 4 0. What do you understand Naomi Campbell and 5 Jeffrey Epstein's relationship to be? 6 A. I don't. I assume it was modeling. I 7 don't know. It was like two trips. 8 0. Jeffrey Epstein ever tea you how long he was 9 in the modeling industry? 10 A. Never discussed it. 11 0. So the first you know of is whatever 12 involvement he's in with Jean Luc Brunel. 13 A. Right. 14 0. That's the first time -- 15 A. Yes. 16 0. -- you've never known him lo be in modeling. 17 A. Correct, that I was awaro of. And, 18 actually, nobody ever told me that but picking up 19 bits of conversation like such as the one about the 20 motor home door. 21 0. What exactly did he say about the motor home 22 door that led you to know that Epstein and modeling is -- 23 A. They were al - on location for a modeling 24 shoot and they had a motor home. 25 0. They meaning Jeffrey Epstein and somebody. 188 1 with Epstein? 2 A No. 3 0. What other properties does Jeffrey Epstein 4 own? I know we talked about the Zero Ranch. the place 5 in New York, you talked about an island, West Palm Beach. 6 A. That's all that I'm aware ol. 7 0. How about Paris? A. I don't know that he owns them. That's 9 whore he goes for homes. 10 0. Ever go to Pahs with him? 11 A. He does have an apartment in Para. I 12 don't know • however that works out it irs a lease 13 or own or what. 14 0. Who are the house managers of the various 15 places that he owns? 16 MR. PIKE: Form. 17 A. I don't know anymore. There has been so 18 much shake up. you know. 19 0. Well. who were they? Do you know the 20 Freidman out in California? Do you know Eve am 21 Patrick? 22 A. No. 23 0. Alfredo Rodrigue?? 24 A. No. 25 0. Alright • 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esqulresolutlons.com 3501.150-002 Page 49 of 92 EFTA 00068841 EFTA01247069 Larry Eugene Morrison - Volume I October 6, 2009 189 1 A. No, those are all I know. 2 0. You tell me. Who do you know? 3 A. God. I can't think. It's been so long 4 ago. 5 O. Other than Joe-Joe. 6 A. Well, Joe•Joe doesn't • he's just a driver 7 for New York - he and his wife. I could remember 8 them it I saw their names. I would know which house 9 they were associated with. I'm terrible with names 10 anymore, unfortunately. The couple that's now at the 11 ranch or was at the ranch is at the island helping 12 manage as an intern. 13 O. Who's that? 14 A. Honestly, I can't remember their names. 15 It you were to give me a name, I could attach it to 16 each house. 17 0. I wish I could. 18 A. Yeah, tm son , I can't. It's 19 O. Do you know 20 A. No. sounds familiar. I don't 21 know. 22 O. Something to do with the modeling agency? 23 A. Can't say for sure - can't say. 24 O. How about Kalib Shalom? 25 A. No, never heard of that one. 1 2 3 4 6 7 a 9 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 191 0. Do you remember a young woman name. who flew frequently with Jeffrey Epstein? A. No, I don't recall 0. You mentioned a A. A` yes. I remember the name-. 0. Can you describe-'? A. No, I'm sorry. I cant. I just recognize the name - or the sound of the name. 0. Do you have any recollection as to what period of time -flew with Mr. Epstein? A. It was on one of those Passenger Manifests. I thought I only saw it one time. MR. REINHART: Kathy - this is Bruce • the passenger manifest that had that name on it was dated MS. EZELL: So al of those that Brad went over were '04 and '06. I believe. MR. REINHART: Correct, BY MS. EZELL: 0. Let's see, did you ever fly Mr. Epstein to St. Louis? A. No. 0. Did you ever fly him to San Francisco? A. No. 0. What about France? 190 1 MR. EDWARDS: Let me look over my notes 2 real fast. Anybody else going to have some 3 questions so I can look over my notes and maybe 4 ask a ample more? 5 MR. PIKE: Brad, when I get a chance to 6 cross, I definitely will have some questions for 7 the witness. a MR. EDWARDS: Okay. Any other plaintiff 9 attorneys? Kathy? I think Kathy quit on us - 1 co must have been loo boring. Anybody else? 11 Hold on Miko. Give me one minute and then 12 I think you can shoot. 13 MS. EZELL: Brad? 14 MR. EDWARDS: Yes? 15 MS. EZELL: I'm sorry, its Kathy. I 16 dolt realize my mute was on. I do have a few 17 questions. 18 MR. EDWARDS: Okay. Go ahead. 19 CROSS-EXAMINATION 20 BY MS. EZELL: 21 0. Mr. Morrison • forgive me, I didn't write it 22 down - when did you begin working for Mr. Epstein? 23 A. January 2001. 24 0. Do you remember a young woman named .? 25 A. No, I'm sorry, I can't - I don't. 192 1 A. Yes. Paris. 2 0. And Spain? A. No, nope. 4 la Carmel? 5 A. Cannel? 6 MR. REINHART: California, Kathy? 7 MS. EZELL Yes a A. No, we wouldn't have Was that Monterey 9 area? 10 MR. REINHART: Yes. 11 A. Yes. 12 0. Monterey you did. Okay. 13 Do you remember a woman named= who would 14 accompany Bair* (sic) Maxwell? 15 A. Yes. I remember = I believe srie was 16 17 0. And what was her function? 18 A. To the best of My knowledge, 20 0. Did there came a point in time where Ms. 21 Maxwell flaw her Own plane? 22 A. No. 23 0. Did there come a lime that you became aware 24 that she and Jeffrey Epstein were flying asParaiohl 25 A. Yes. -or— ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com • • • 3501.150-002 Page 50 of 92 EFTA_00068842 EFTA01247070 Larry Eugene Morrison - Volume I October 6, 2009 • • 193 1 0. And whose plane would she fly on on those 2 occasions? 3 A. I don't know. There was -- She had a 4 fractional - of a flight options. She had some 5 flight options. When you said Can I ask — 6 0. Yes. 7 A. when you stated. 'Did she fly her own 8 planer, did you mean as a pilot? 9 O. Yes. yes. 10 A. No, no. I stand with, no. 11 0. Did you ever know her to fly a helicopter? 12 A. Yes. 13 0. And when was that? 14 A. Several times. I don't remember exactly 15 when she got her initial rating. Can't remember 16 exactly when she got her initial rating. It was 17 before - I think before - maybe around 2000, 2001. I 18 don't know that for a fact. 19 O. Among the various pilots that you have worked 20 with for Jeffrey Epstein, do you know of any who has a 21 house on the Zorro Ranch property? 22 A. Yes. 23 0. And who IS that? 24 A. LanyVisoski. 25 0. And do you know if he was given that house by 195 1 A. I can't say that I have, no. I can't say 2 that I did. 3 0. Do you remember flying three young girls back 4 to France after Mr. Epstein's birthday party? A. No, no, I can't say that I do. and I 6 didn't remember what birthday - that there was a big 7 birthday party. 0. Okay. Well, forget the party part. 9 A. Okay. 10 0. Were you aware that Mr. Brunel flew in three 11 12-year-old girls for Mr. Epstein's pleasure on his 12 birthday? 13 A. No. I was not aware of that, no. 14 0. And you have no recollection of having young 15 women that young on flights that you were flying on? 16 A. That's correct. 17 MR. PIKE: Form. te BY MS. EZELL: 19 0. I don't have any other questions. Thank you. 20 A. Thank you. 21 MR. EDWARDS: Mice. I don't really think 22 anybody— I'm Sony. 23 CROSS-EXAMINATION 24 BY MR. WILLITS: 25 0. Richard Willits here. I just have one 194 1 Jeffrey Epstein? 2 A. I do not know. 3 0. Were you ever given any properties by Mr. 4 Epstein? 5 A. No. 6 0. You said that you did know Mr. Jean Luc 7 Brunel? 8 A. Yes. I knew of him - and it was as an 9 acquaintance • as a passenger. 10 O. Did you fly him to and from Paris? 11 A. Yes. 12 0. Do you ever remember flying three girls from 13 Paris for Mr. Brunel -- 14 MR. PIKE: Form. 15 O. -- to be guests of Mr. Epstein? 16 MR. PIKE: Form. 17 A. I can't say that I remember that exactly, 18 no, and I didn't know who • whose guests they were 19 for who. 20 O. Do you remember flying three young girls to 21 Mr. Epstein's birthday party? 22 MR. PIKE: Form. 23 A. I don't -- 24 O. I'm Sorry, I meant from France. 25 MR. PIKE: Form. 196 1 question. sir. I didn't catch the complete and full 2 spading of your name. 3 A. My name? 4 0. Yes. sir . the witness? 5 A. Its Larry - Lana. Aktia. Romeo. Romeo. Yankee and last name is Morrison - Mike, Oscar, Romeo. Romeo. India. Sierra. Oscar Nowomber. MR. WILUTS: Thank you, at. 9 MR. EDWARDS: Mike, shoot. to MR. PIKE: Thank you. Thank you. 11 CROSS-EXAMINATION 12 BY MR. PIKE: 13 0. Mr. Morrison. my name is Michael Piko. I 14 represent Jeffrey Epstein. I5 A. It 16 0. I'm going to ask you a couple of questions. 17 If you do not hear me, please ask me to repeat the 18 question - as In on a telephone and by virtue of be,ng 19 on the telephone. I've noticed that there's some lag time 20 between some answers and responses. 21 MR. PIKE: So, l3rad, Interrupt me, if I'm 22 talking over the witness as well. 23 BY MR. PIKE: 24 a Mr. Morrison. Mr. Edwards was talking to you 25 about your knowledge and information regarding passengers 6 7 • 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutlons.com 3501.150-002 Page 51 of 92 EFTA_00068843 EFTA01247071 Larry Eugene Morrison - Volume I October 6, 2009 197 1 on Mr. Epstein's plane from January 1, 2001, up until the 2 time you stopped flying. Do you recall some of those 3 questions? 4 A. Yes. 5 0. With regard to the female passengers that Mr. 6 Edwards discussed with you. do you recall n any of them 7 ever left the plane in a scared manner? A. No. no. 9 O. Did any of those girls over appear to be 10 disheveled to you in any way? 11 A. No. 12 0. Did any of these girls that were on the plane 13 ever claim to be battered or sexually assaulted? 14 A. Not to me, no. 15 0. Did any of these women appear to be in shock 16 to you? 17 A. No. 18 MR. EDWARDS: Object to the form. 19 BY MR. PIKE: 20 O. Were any OI these women ever crying as they 21 exiled the plane when you were the plot? 22 A. No, not that I saw. 23 0. Did any of these women appear to be injured as 24 they exited the plane when you were a pilot? 25 A. No, net that I saw. 199 1 first. 2 MR. PIKE: I have no further questions. 3 MR. EDWARDS: I have a couple more • just 4 follow-up • from what Kathy asked. 5 REDIRECT EXAMINATION 6 BY MR. EDWARDS: 7 0. Did any of the people • along Mike Pike's e lines - did any of the girls on the airplane tell you 9 that he pled guilty to two felonies in court? 10 MR. PIKE: Form. 11 A. No, I haven't • I have not spoken to Mr. 12 Epstein. I don't believe -- 13 0. No. no. I think the question was: Did any of 14 the girls tell you that Mr. Epstein pled guilty in court? 15 A. Which girls? 16 0. Any of the girls on the airplane that we're 17 talking about. 18 A. No. I don't think -- Actually. I don't 19 know when he pied because I think I was - stopped 20 flying by then. 21 0. So there were a lot of things that happened on 22 the airplane that the girls didn't necessarily tell you 23 about. right? 24 MR. PIKE: Form. 25 A. That I wasn't — Like I say, going back to 1 2 4 6 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 198 0. Did any of these women ever tell you, as the captain of the plane, that they were forced to do something against their will white a passenger on the plane? MR. EDWARDS: Object to the form. A. I was Actually. to correct the question. I guess I was not captain - I was flight engineer but, no. 0. Did they ever tell you that they had been forced to do anything inappropriate? A. No. O. Did they ever tell you that they had been assaulted in any way? A. No. O. Did they ever tell you that they had been kieppropriately touched in any way? A. No. MR. EDWARDS: Form. BY MR. PIKE: 0. Did they ever tell you or did you ever hear of anyone Claiming that they had been sexually assaulted. battered, or raped while on the plane? MR. EDWARDS: Form. A. No. MR. REINHART: Give him a chance to object 1 2 3 4 6 7 e 10 11 12 13 14 15 16 17 18 19 20 21 22 24 25 200 • there was not even an opportunity or window for that question. because I believe it was after February of '07. 0. That's true. Did any of the girls on the airplane tell you about things that happened on the airplane that he later pled guilty to? MR. PIKE: Form. A. No. 0. Did any of the girls on the airplane really talk to you? A. No. 0. Okay. so all of this is kind of say. Akight. Got it. would accompany Ms. Maxwell. When you say •would n her; what did you mean about that? A. . Actually. I don't -- I didn't see very many times. I don't know when she stopped wonting there, but she would Yeah, I just She would be on trips with her -- 0. And did you — A. (Please continue to Volume II.) ESQUIRE asalemderCla•Cespeay CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com • • • 3501.150-002 Page 52 of 92 EFTA_00068844 EFTA01247072 • • CONFIDENTIAL j 3501.150-002 Page 53 of 92 EFTA_00068845 EFTA01247073 • • CONFIDENTIAL 3501.150-002 Page 54 of 92 EFTA 00068846 EFTA01247074 Larry Eugene Morrison - Volume I October 6, 2009 • • • 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 Page 55 of 92 EFTA_00068847 EFTA01247075 Larry Eugene Morrison - Volume I October 6, 2009 S ESQUIRE CONFIDENTIAL Toll Free Facsimile Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esdulresolutions.com • 3501.150-002 Page 56 of 92 EFTA_00068848 EFTA01247076 Larry Eugene Morrison - Volume I October 6, 2009 • • • ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 Page 57 of 92 EFTA_00068849 EFTA01247077 Larry Eugene Morrison - 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