10. Hs 12. 13, 14, 16. 17. 19. Jeffrey Epstein v. Bradiey J. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG Attachments to Statement of Undisputed Facts . Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564-67, 568) Deposition of L.M. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition of E.W. taken May 6, 2010 (115, 116, 255, 205, 215-216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Epstein taken April 14, 2010 Deposition of Jeffrey Epstein taken February 17, 2010 Deposition of Alfredo Rodriguez taken July 29, 2009 (242-44, 223-28, 230-31, 278-280) Deposition of Nadia Marcinkova taken April 13, 2010 (11) Deposition of Jeffrey Epstein dated March 8, 2010 Deposition of Jeffrey Epstein dated October 8, 2009 Deposition of Jeffrey Epstein dated May 1, 2009 Deposition of Jeffrey Epstein dated May 7, 2009 Deposition of Sarah Keflen dated March 24, 2010 . Deposition of Adriana Mucinska Ross dated March 15, 2010 Deposition of Janusz Bansiak taken February 16, 2010 (14, 154-160, 172-175) Deposition of Louella Rabuyo taken October 20, 2009 (9) . Deposition of Larry Eugene Morrison taken October 6, 2009 (102-103) Deposition of Alfredo Rodriguez taken August 7, 2009 (302-306, 348) 20. Deposition of Mark Epstein taken September 21, 2009 (48-50) 21. Deposition of Larry Visoski taken October 15, 2009 22. Deposition of Bradley J. Edwards taken March 23, 2010 (110-116) DEFENDANT BRADLEY J. EDWARDS’S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 22 Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 2009CA040800XXXXMB AG Complex Litigation, Fla.R.Civ.Pro. 1201 JEFFREY EPSTEIN, Plaintiff, ~vs~ VOLUME I OF IT SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M. individually, Defendants. VIDEOTAPED DEPOSITION OF BRADLEY J. EDWARDS, ESQUIRE Tuesday, March 23, 20016 : 10:00 - 5:07 p.m. : 2139 Palm Beach Lakes, Boulevard West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1333 (561) 832- 7500 PROSE COURT REPORTING AGENCY, INC. (561) 832- 7506 Page 110 L that you were aware of; that is, hard copies? 2 A. I don't know. 3 Q. Okay. Could have been more, could have 4 been less; you just don’t know? 5 A. Correct, 6 Q. If I understood your testimony, Wi Mr. Rothstein, Mr. Rosenfeldt, any other attorney or 8 investigator could have accessed those files 9 depending or where they were within the firm, true? 10 A. I am not sure exactly who could have accessed 121 it. You asked me if the attorneys could and the 12 attorneys had swipe cards for various locked areas. 13 Each attorney I believe had access to any area where 14 those files were located. I believe so. 15 Q. Okay. Well, during the time you were 16 there did an individual by the name of Ken Jenne 17 work there? 18 A. Yes. 19 Q. Okay. Did an individual by the name of 20 Mike Fisten work for the firm -— 21 A. Yes. 22 Q. -- for RRA? Were they employees of the 23 firm or were they independent contractors? 24 A. I don't know. 25 Oy Okay. During the time they were there, RRM TT TR TIS TT A IT RT NTT TT TO (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 111 | i did they also have swipe cards so that they could 2 access different areas in the firm? 3 A. I believe so. 4 Q. With regard to when you joined RRA, did 5 you ever have any further meetings with 6 Mr. Rothstein; that is, from the day you started at 7 RRA, did you ever meet Mr. Rothstein again? 8 A. By meet him again -- 9 Q. Did you ever have a meeting with him again 10 regarding your position in the firm? 1i A. No. 42 ee Okay. Did you ever meet with him and a 13 number of other individuals with regards to firm q 14 business? | 15 A. No. 16 Q. Firm cases? : 17 A. I don't believe so. 18 Q. Was Mr. Rothstein ever present in any : 19 meeting where any of your cases were discussed? Let 20 me strike that. Was Mr. Rothstein ever present : 21 wherein at any meeting where any of the cases 22 against Jeffrey Epstein were discussed? Don't tell 23 me content; just was he ever present. 24 A. How would I know that? I don't know. He 25 could, he could be in a meeting right now where the case (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 112 | 1 could be discussed for all I know. 2 °. I'm sorry. Obviously, where you, where 3 you were present. Where you ever present at a 4 meeting where Mr. Rothstein was also present where 5 the Epstein cases were discussed? E 6 A. No. : 7 Q. Did he ever call you to communicate with 8 you, call you either by phone, video conference, in 9 any fashion to discuss any act aspect of the cases 10 that you had against Jeffrey Epstein? il MR. SCAROLA: You can answer that. 12 THE WITNESS: He has communicated about 13 various, about legal issues related to the case 14 as well as commented about the case to me on : 15 very few occasions but I would say less than 16 three times. 17 BY MR. CRITTON: : 18 Q. During the time that you, from April of 19 ‘09 through late October of '09, correct? 20 A. In that time period, where, is that when 21 these -~ 22 On. Correct. 23 A. -- things happened? 24 oO. Well, that's the time you were there; ; 25 that's what I am asking. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 10 1. 12 13 14 15 16 17 18 19 20 21 22 23 24 (561) Page 113 f A. When I was there. Q. And do you, can you remember the date, any specific date that you spoke with him? A. No. Q. Do you remember any specific month that you would have had one of the -- well, what did you say something less than five conversations? I don't want to misquote you. A. I said less than three conversations. Os All right. So, something less then three conversations you had with Mr. Rothstein regarding Epstein cases, either legal issue or a comment, some comment about the case to you, correct? A. Yes. Q. All right. The first time that he ever spoke to you, did he call you or did you call him? A. I, I never called Scott Rothstein about anything. Oh, take that back, About anything related to Jeffrey Epstein. Q. The first conversation that you can recall where either a legal issue or a comment was made about Jeffrey Epstein by Mr. Rothstein to you, he obviously initiated the call? A. It wasn't a call. What was it? 832-7500 PROSE COURT REPORTING AGENCY, INC. (S61) 832-7506 11 12 13 14 15 16 17 18 19 20 21 22 23 (561) 832-7500 PROSE Page 114 ff A. A comment in passing. And I believe I was sitting at a table in BOVA when he walked over to my table and commented about Jeffrey Epstein. QO. Okay. Who were you there with at the time? A. T don't remember. 0. Were you with some friends? Were you with other lawyers? A. All right. I am jogging my memory. I, I have no idea. Q. What did he say? MR. SCAROLA: To the extent that you can answer that question without disclosing any mental impressions with regard to the lawsuit or any attorney-client privileged communications, you can answer. To the extent that it might invade either the work-product or attorney-client privilege, you should not respond. THE WITNESS: Can I talk to you? MR. SCAROLA: Sure. (A brief recess was held.) MR. SCAROLA: Are we on? THE VIDEOGRAPHER: Yeah. MR. SCAROLA: The record should reflect (561) 832-7506 REPORTING AGENCY, INC. couRT Page 115 | 1 that we have had an opportunity to consult and 2 I have advised Mr. Edwards that there is no 3 privilege protection for the particular 4 communications involved. 5 BY MR. CRITTON: 6 Oo What did he say? 7 A. He commented to me, I want you to get that 8 pedophile. 9 Q. And your response was what? 10 A. I didn't respond. 11 Ox All right. Second conversation that you 12 can remember, where were you? 13 A. I had just come out of the conference room on 14 the main floor after taking a deposition in another 15 case. And he walked by and said, did you get that F'ing 16 pedophile yet. 17 Q. And your response? : 18 A. Again. | 19 Q. No response. 20 A. Didn't respond. 21 Q. On the first occasion when he came over 22 and if I understand correctly, all he said was the i 23 comment that you referenced and then he left. You 24 didn't respond and then he just made the comment and ; 25 then left? : ) A (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 116 1 A. Right. He was walking by in his normal, loud, 2 ostentatious kind of way, greeting everybody in the 3 restaurant. Came over to my table and he feels, at 4 least my impression was obliged to say something to 5 everyone. And that's the comment he said to me. 6 And if youtve ever seen him, he is 7 basically always just skipping around and he hoped 8 on over somewhere else. So, yes, it was in, 9 literally in passing. 10 Q. Okay. How, how, how did he even know you LL had cases involving Mr. Epstein? 12 A. I don't know. : 13 Q. Because I think you testified earlier that 14 you had never discussed an Epstein case with : 15 Mr. Rothstein one-on-one, correct? 16 A. Absolutely, true. ; L7 Q. You never discussed an Epstein case or 18 either of your three clients with Mr. Rothstein even 19 with a group of people around, correct? | 20 A. Correct. 21 Q. All right. Do you remember a third 22 occasion that he spoke to you regarding Epstein : 23 related occasion, cases? 24 A. Anything else that he ever spoke with me about ! 25 related to Epstein related issues is attorney-client and i (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 TCM EIT DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 21 Larry Visoski October 15, 2009 ‘CTHE cIRcuET couke oF me serenity duotcraL cinciT | 1 wh ‘Te AND FOR PAIN BEACK COUNTY, (ASE NOS S02000CROZOOSIEIAEE AD 2 INDEX . Plaintiff, 5 WITNESS: DIRECT CROSS REDIRECT RECROSS ve a oeerReY EeSTEIS, LARRY VISOSKI Defendant. 7 BYMR. EDWARDS: 6 DEEGETTIGN OF CRAY VEGERT Gr EVAR CHITTON ae Thucgday, October 15, 7009 BY MR. EDWARDS: 200 . 3 BYMR. CRITTON: 224 518 NW, Flagler Orive 20. Suite £200 i Nest fale Beach, Florida 33401 42 aot 13 EXHIBITS Reported 3y: 14 Pes Hendy Death Anderson, RER, CRS, FPR worary Publics State of Florida 15, squire Deposition Services 16 NUMBER DESCRIPTION PAGE West Palm Seach Office Job #127542 STD BLAINTIEES OLA SLIGHT Ls BOOK (MARKED IN PREVIOUS DEPO} 18 19 PLAINTIFF'S EX. 2 MESSAGE PAD ne PLAINTIFF'S EX.3 MESSAGE PAD 119 20 PLAINTIFF'SEX.4 COMPLAINT 139 PLAINTIFF'S EX.S INMATEVISITORLOG 161 aL 22 23 24 25 —+ 2 4 1 APPEARANCES: 1 PROCEEDINGS 2 Onbehalf of the Piaintft: 2 ats 3 BRADLEY J, EDWARDS, ESQUIRE ROTHSTEIN, ROSENFELDT, ADLER 3 Deposition taken before Wendy Beath Anderson, 4 ee Olas Boulevard 4 Certified Realtime Reporter and Notary Public in and for s Fort Lauderdale, Florida 33394 5 the State of Florida at Large, in the above cause. 6 6 Bite 7 Onbehaif of the Defendant: . a ROBERT D. CRITTON, JR, ESQUIRE 7 MR. EDWARDS: We're going to put something on BURMAN, CRITTON 8 LUTTIER. 8 the record about -- well, we'll do it this way ~ 3 303 Banyan Boulevard, Suite : Wea vase tonch, Pon ano 9 MR. REINHART: Do it at the end, after we get 10 10 him -- whatever you want. {t's your show, 11 On behalf of the Witness: ; a 42” BRUCE REINHART, ESQUIRE i MR. EDWAROS: Okay. There were -- I dont 250 South Australian Avenue 12 even think Mr. Wilts is aware of this. There was 43 Suite 1400 13 a subpoena duces tecum for this witness, as well as Palm Beach, Florida 33401 ss aa Ween ei 14 the previous witness, which was another pifot, Dave 15 ALSO Miers secu: is Rogers, and that duces tecum was to bring the ae a 1 SLUNWT ETT Averes 16 _fiight logs related from 1998 through 2005, What 17 nnn is Dee SURE. aT was produced at the previous deposition were flight 18 Al HOROWITZ, ESQUI : NORE LATIN € HOROWITZ: PA: is logs from 2002 through 2008, and now Mr. Reinhart a9 18205 Biscayne Boulevard, Suite 2218 19 has agreed to produce the remainder of the flight os Miaml, Florida 33160 20 logs requested, those going from 1898 through 2002. RICHARD H. WILLITS, ESQUIRE (VIA TELEPHONE) 22 MR. REINHART: Correct. They're pilot fags, aa RICHARD H. WILLITS, PA. 22 not flight logs. There are other records we 2290 10th Avenue North, Suite 404 a 4 2 Lake Worth, Florida 33461 23 indicated are corporate records, and with those you 23 24 have to deal with Mr. Critton. a8 25 MR. CRITTON: However, with the proviso, too, Larry Visoski i 5 October 15, 2009 7 ide that we're going to work out that these records are 1 the question and you need to wait until | finish asking 2 to be used within the confines of this litigation 2 the question. 3 and not to be spread to the press or anyone else, 3 A. So you're not allowed to interrupt me? 4 because they de contain confidential information as 4 Q. And you're not allowed to interrupt me. 5 to who may have been on the plane and other records 5 A. Like | just did? 6 of Mr. Ragers, which but for the subpoena would 6 Q. Right. a have been only available to the FAA or some other 7 MR. CRITTON: Cara just snickered when you 8 law enforcement agencies. 8 said you've been accused because she recognizes. 9 MR. EDWARDS: Okay. Is that ail you want to 9 it's true. 16 put on? 10 MR. EDWARDS: | don't know what the meaning ag MR. CRITTON: Yes. 11 her snickering was. 12 MR. EDWARDS: I'm not saying | necessarily 12. BY MR. EDWARDS: 13 agree or disagree with you. That's something that 13 Q. But for what it's worth, if you don't 14 we'll deal with some other day. 14 — understand the question or I've asked a bad question, t 15 MR. CRITTON: Bruce, you'd betier produce 15 — don’t want you to guess. Give me the best answer to the 16 these records, but there has to be some sort of 16 best of your knowledge and if you need me to rephrase iy understanding before — 17 sit, | will, 18 MR. REINHART: Correct. 18 A. Okay. 19 MR. EDWARDS: | won't do anything until you 19 Q. Okay. Tell me your current address. 20 file whatever you -- until we work whatever it is 20 A. 1131 Pine Point Road, Riviera Beach, Florida 22 out in court, "i say that on the record, that 21 33404. 22 #m not doing anything with the records outside of 22 Q. How long have you lived there? 23 mny office until same judge deals with it. 23 A. Approximately nine years. 24 MR. REINHART: And for the record, Fl adopt 24 Q. Okay. Who do you five there with? 28 what Mr. Critton said on this one limited occasion. 25 A. My wife and one child at this time. 6 8 + MR. EDWARDS: Aili right. 1 Q. Allright. How many children do you have? 2 Thereupon, 2 A. Two. 3 {LARRY VISOSKI) 3 Q. How old are they? 4 having been first duly sworn or affirmed, was examined 4 A, Fifteen and eighteen. 5 and testified as follows: 5 Q. Andis the 18-year-old, is not living with 6 THE WITNESS: Yes, { do. 6 you? 7 DIRECT EXAMINATION T A. She's off in school. 8 BY MR. EDWARDS: 8 Q. Okay. What school is that? 9 Q. Gan you tell us your name for the record. 9 A. Syracuse. 10 A. Lawrence Visoski, Jr. 10 Q. Who's your employer right now? a Q. And Mr. Visoski, have you ever had your il A. NES, LLC. 12 deposition taken before? 12 Q. How lang has NES, LLC been your employer? 43 A. No. 13 A. I'm guessing. I'd say back 1991. I have to 14 Q. Okay. Here's the process: I'm going to ask 14 do the math, but 17, 18 years. 15 you questions. You're going to give us answers. Tryto{ 15 Q. Has that been your only employer since 19917 16 give us answers that we all understand and that the 16 A. Yes. 17 court reporter can take down, such as yes, no, or some} 17 Q. And has that been your only source of income 18 other verbal answer that we can understand. [t's easy 18 ~~ since 19917 19 when we get in a casual conversation to nod or shake 19 A. Yes. 20 your head, and the court reporter is not writing 20 Q. And what is NES, LLC? 21 pictures or anything else. 21 A. | don't really know. | mean, it's the company 22 A. lunderstand, 22 that my check comes from. 23 Q. The other thing is, and {ve been accused of 23 Q. What do you do for NES, LLC that results in 24 _ this in other depositions — i don't know ff it's true 24 — them paying you? 25 or not -- but ! need to wait until you finish answering 25 A. lam chief pilot for the aircraft and Larry Visoski October 15, 2009 9 ii 1 helicopters. 1 Q. What floor or suite number is NES, LLC in? 2 Q. And do you have a specific boss or somebody 2 A. Tbefieve -- well, | don't know that NES, LLC 3 you answer to at NES, LLC? 3 has an office there. { know that's where Leslie has the 4 A. Several people would call to schedule flights. 4 phone number where I call. So | don't know for a fact S from the office, being it either Mr. Epstein or, you Sif NES, LLC has an office there. 6 — know, | would just get a phone cail and they would 6 Q. And what suite number, then, would Leslie 7 ~~ schedule a trip. 7 Groff sit in to answer that telephone number at 8 Q. Okay. Aside from Mr. Epstein, who eise would 8 750-9895? 9 there be that would call to schedule flights? 9 A. think it's 10F. 10 A. Lesiie. 10 Q. And when you stay at 301 East 66th Street, il Q. Leslie who? 11 what suite number or what apartment number do you stay iz A. Leslie Gruff. 12 in? 13 Q. When's the last time you talked to Leslie 13 A. 120, 14° Graff? 14 Q. And how about Dave Rogers, where does he stay? 15 A. Probably two weeks ago, three weeks ago. 1s A. I'm guessing, because it's been some time 16 Q. And where is she currently? 16 since we've been there, 108, but dont quote me on it. 17 A. | believe in New York, is where 1 spoke to her i? Q. Who are the other peopte in that building that 18 on the phone last. 18 you know to stay there on a regular ~ fairly reguiar 19 Q. What's the telephone number you call to reach} 19 basis? 20 — Leslie Gruff? 20 A. lve seen people in the elevator that, you 21 A. {212}750-9895. 21 know, have been on the airplane. Case in point, maybe 22 Q. And what address is Leslie Gruff at? 22 Sarah Kellen, but | don't know for a fact that she fives 23 A. Do you mean where the office is located? 23 there, or anybody else for that matter. 24 Q. Correct. 24 Q. Okay. When you say you've seen Sarah Kellen 25 A. 301 East 66th Street. 25 — onthe elevator — 10 12 1 Q. And it's my understanding from other 1 A. Jonly assume she lives there. | don’t know 2 depositions that there are also apartments in that 301 2 fora fact. I'm trying to be honest and factual for 3 East 66th Street building? 3 you. So [ couldn't honestly say if 1 knew she lived 4 A. Yes, 4 there or not, 5 Q. And Mr. Epstein either owns or leases or rents 5 Q. Where do you think Sarah Kellen lives? 6 certain of those apartments. Is that your 6 A. {would think she lives there. 7 understanding? a Q. You don't have a better location? 8 MR. CRITTON: Form; specuiation. 8 A. I don't have another location. 9 THE WITNESS: I'm only specufating. | 9 Q. Anybody else? 10 don't ~ to my understanding, I don't know. 10 A. Not to my knowledge. | mean, I'd only be 11 BY MR. EDWARDS: 11 guessing that people live in that building that -- you 12 Q. Do you know other people that live in that 12 know, 1 don't have any facts to prove that they actually 13 building? 13 tive there. 1 mean, | don't think you want me to guess. 14 A. Well, it would be myself, Dave Rogers — well, 14 Q. Welt, NES, LLC, would you say that the owner 15 when you say “live,” explain. 15 or controller of that company is Jeffrey Epstein? 16 Q. When you're saying yourself and Dave Rogers; 16 MR. CRITTON: Form. v A. See, we don't live there. i mean, we have — 17 THE WITNESS: | don't know that for a fact. 8 we would stay there when we would have a trip. 18 BY MR, EDWARDS: 19 Q. Okay. When you would fly up to New York and j 19 Q. Jeffrey Epstein is somebody you've indicated 26 land in New York, the place where you would stay, is 20 that you've worked for for 17 or 18 years, right? 21 that 304 East 66th Street? 22 A. Yes. 22 A. Yes, that's correct. 22 Q. And over the 17 or 48 years you've become 23 Q. That's also a location you've indicated in 23 personally close with him as well, correct? 24 this deposition that is the office for NES, LLC? 24 MR. CRITTON: Form. 25 AL Yes. 25 THE WITNESS; | don't understand how you mean: Larry Visoski October 15, 2009 13 15 1 “close.” Define that. 1 you know, televisions and such. 2 BY MR. EDWARDS: 2 Q. fs that another hobby or job or something of 3 Q. Well, more so than just a pilot that takes him 3 yours? 4 — from Point A to Point B? 4 A. Both. s A. That is my job, 5 Q. Does he pay you for that? 6 Q. Right. But you know him on a personai level 6 A. Not any more than my salary. 7 and that you've had personal conversations that don't 7 Q. What's your current salary? 8 necessarily deal with flying from Point A to Point B; 8 A. Atthis time, 180,000. 9 isn't that right? 3 Q. And what are you paid $480,000 to do? 10 MR. CRITTON: Form. 10 A. To manage his aircraft. qi THE WITNESS: More specific, meaning we talk; 11 Q. What does that entail? 12 about cars. 1 mean, does that make you a personal; 12 A. Scheduling maintenance. Anything that has to 43 friends? 13 dowith any flight, whether it be weather, flight 14 BY MR. EDWARDS: 14 planning, time and distance to and from a location, any 15 Q. Have you ever gone to his house to eat? 15 logistics involved in running an operation that has 16 AL No. 16 aircraft. i? Q. Have you been to his New York home? 17 Q. In addition to the 180,000, does he give you 18 A. Yes. 18 bonuses as well? as Q. How many occasions have you been to hisNew; 19 A. There have been Christmas bonuses. 20 York home? 20 Q. Over the years, you mean, there have been 21 MR. GRITTON: Object te form. 21 Christmas bonuses? 22 THE WITNESS: We normally pick up luggage in} 22 A. Yes. 23 the lobby, so it would probably be quite often. 23 Q. 1s 180,000 the mast he's ever paid you? Any time we depart out of New York, we stop by the} 24 A. No. house and pick up luggage and head te the aircraft. | 25 Q. Allright. Were you making — when was the 14 16 1 BYMR. EDWARDS: 2 last time that you were making an amount different than 2 Q. Other than picking up luggage, have you been 2 180,000? 3 to his home to visit or socialize with him? 3 A. Last year. 4 A. Not to socialize, no. 4 Q. That would be 2008? 5 Q. Have you been to his Paim Beach home? 5 A. That would be correct. Yeah, we all took a 6 A. To? 6 salary cut, I don't know the exact date. It might have 7 Q. To Mr. Epstein's Palm Beach house? 7 been 2008, last year. It was last Christmas we all took 8 A. Right. 8 a 10 percent salary cut. 9 Q. Have you been there? 9 Q. Do you know why? 10 A. Yes. 10 A. Economic reasons. 1 Q. Have you been inside? ll Q. And who told you that you were going to have 12 A. Yes. 12 to take the salary cut? 13 Q. And how many occasions have you been inside} 13 A. Darren indyke. 14 that home? 14 Q. And did you ask for an explanation? as A. The same, as far as picking up luggage, and 15 A. He explained it was due to economic reasons 16 that would be on a regular basis, you know, for 2 16 throughout the country. 17 ~~ departure. We wouldn't always go to the house to pick 7 Q. Okay. So in 2008, how much was — were you 28 up luggage, but it made it easier for joading the 18 — being paid by NES, LLC? = 19 aircraft, getting it done prior to departure. ag A. 200,000. 26 Q. {s that the only reason that you have ever 20 Q. And is 200,000 the most that you've ever made 21 gone to the Palm Beach home over the last 18 years, is) 21 from NES, LLC? 22 to pick up luggage? 22 A. Yes, sir. 23 A. No. 23 Q. And on top of that $200,000, did you get a 24 Q. What other reasons have you gone there? 24 bonus that year as well? 25 A. I've set up several home theater equipments, 25 MR. REINHART: Which year are you talking Larry Visoski October 15, 2009 OMIA TEWNH aL 42 43 414 £5 16 a7 18 ig 20 2. 23 24 25 OMI H OB wNe 10 li 12 13 4 15 16 1? 18 19 20 21 22 23 24 17 19) about? 1 mypaycheck. So | don't even know what's written on the MR. EDWARDS: 2008. 2 topofit. THE WITNESS: That year, | think we skipped 3 Q. That would be something that only your wife Christmas bonuses that year. The last bonus right 4 would see, I'm assuming? have been 2007. 5 A. You're right, since she probably wouldn't know BY MR. EDWARDS: € the answer either, because she's looking at the right Q. If you ever got a bonus from Mr. Epstein ~ 7 goiumn and not the top column. and {'m only deriving this from you using the term 8 Q. Right. When is the first time that you had "Christmas bonus." 9 heard the name NES, LLC, that company? A. Holiday bonus. 10 A, Five, six years, and even questioned what it Q. ~am | correct to assume — sorry. Amt 11 stood for. And J think to this day | couldn't answer correct fo assume that if you got a bonus, there was. 12 that honestly, what it stands for. only one and it was at the end of the year, around the 13 Q. Okay. But it's your undersianding that the holidays? 14 — NES, LLC is paying you for the work that you do as a A Yes. 15 pilot or maintain the pianes for Jeffrey Epstein? Q. Okay. And how much was the 2007 holiday 16 A. Tomy understanding, yes. bonus? 17 Q. And back in 1991, do you know ifit was a A I'd have to ask my wife, to be honest. | 18 different company that was paying you or if it was. haven't seer my paycheck in 27 years, so | believe it 19 Jeffrey Epstein directly paying you? was $10,000. 20 A. fdon't remember. mean, | don't. Q. And in 2007 you also made $200,0007 21 Q. Okay. Throughout your career with — as a A. Yes. 22 pilot for Jeffrey Epstein, since 1991, has there ever Q. Okay. 23 been a time when you believe you were paid directly from A. With a question mark. I'm trying to be as 24 Jeffrey Epstein personally versus some company? accurate ag | can, but yes. 25 A. Not to my knowledge, no. 18 20 Q. Something pretty close to that? 1 Q. Okay. So whether it was NES, LLC or some A. Yes, sir. 2 — other company, it was all of a sudden a company name, to Q. Okay. So with the bonus it was 210,000, 3 the best of your knowledge? roughly? 4 A. Exactly. yes. A. Right. 5 Q. And back in 1991, do you remember Q. Okay. And how long were you making that 6 — approximately how much you were being paid that year? salary? ? A. Fifty-five or 60,000, is maybe what | started. A. Probably — he was very religious about giving 8 GQ. Okay. annual increases, so | would probably say 2006, you 9 A. You're going back a long ways. know, it was —- we would get increment ~ increases of 10 Q. Yes. five or $10,000 each year. So | would say 2006. So it a A. I'm trying. graduated, you know, progressive. 12 Q. Your relationship goes back that far. That's Q. Okay. Do you remember the progression if we 13 why I chose that year. start at 18917 Do you remember roughly what the 14 A. Right. progression was up through 2607/2008, when you were 15 Q. Okay. Did you get bonuses even back that far? making $200,0007 16 A. Yes, sir. A. No, | wouldn't know the progression, 47 Q. And do you remember what your bonuses were Q. Okay. Do you remember what you were making 18 — approximately? from -- and was NES, LLC the company paying you back in} 19 A. 5,000. | mean, that was kind of the — the 19917 20 starting point. A. Idon't know. | don't remember. Let me say 23 Q. Okay. In addition to monitary bonuses, were it that way. | don't remember. 22 there ever gifts or any other type of compensation that Q. Okay. When ~ how long do you remember NES, 23 NES, LLC or Jeffrey Epstein provided you? LLC being the payer of your check? 24 A. Yes, A. Personally, two years, because I've never seen 28 Q. And is that over the span of the 18 years? Larry Visoski weatinueune 21 Yes. Okay. Teit me what some of those items are. ji remember one specifically was a poo! heater. Excuse me? A pool heater. When was that? 1995-ish. Okay. Why did you get that? . | had built a pool and | didn’t have a heater and he kind of laughed at me saying, “How can you have a; pool without a heater?” So he says, "You ought to get a heater.” Q. Where were you when you had that conversation? A. Inthe airplane, Q. How did he know that you had built a pool? A, dust in general conversation. Q. You were having a conversation with Jeffrey Epstein? A. Yes. Q. And this is something that was happening on the airplane, this conversation? A. During the flight. Yeah, It would have been fike on cruise or something. Q. Okay. When you say “during the flight,” does that >prpraro>r 22 A. Again, you're going back a long ways. Q. understand. We're talking about 1995 right now. A. Yes. Q. You're having a conversation with Jeffray Epstein. Wha is flying the airplane? A. The auto pilot and there's two crew. Q. Okay. So are you back in the back portion or is he up in the cockpit? A. Upin the cockpit. Q. Okay. Jeffrey Epstein sometimes comes up there? A. Just, yeah, in between the two pilot seats. Q. Allright. Is that something that was typical, to have conversations like that? A. Mm-hmm. Q. Yes? A. Yes. No nodding. Q. And would those conversations be directed mainly with you or with the other pilots as well? A. Mainly with me. Q. | mean, you've kind of been described as the main guy or the main pilot. Wouldn't you consider that! pretty much your role, right? A. Well, that's chief pilot. 1 2 a 4 5 6 A 8 9 10 11 12 13 i4 is 16 aT 18 19 20 1 2 3 4 + 6 7 8 9 10 aL 12 13 14 is 16 17 18 19 20 21 22 23 24 25 October 15, 2009 23 Q. But more so than that, if there's going to be a casual conversation about a pool or a pool heater or whatever, it's going to be with you most likely if he's. going to be talking to pilots, right? MR. CRITTON: Form. THE WITNESS: Right. BY MR. EDWARDS: Q, Okay. And you feel like over the years your relationship with Jeffrey Epstein has been pretty good? A. Yes. Q. And you have been closer to him over the years| a8 you've grown to know him? MR. CRITTON: Form. THE WITNESS: The sams throughout the same| year. We never got any closer than 1991 than tam with him now. 'm very professionat at what t do and know the line between being professional and thinking you're somebody's buddy. BY MR. EDWARDS: Q. Okay. Se that’s not something that you think you are? You don't think you're his buddy? A. No, sir, Q. Do you consider yourself his friend? A. i believe so. Q. Do you think he considers you his friend? 24 A. I think so. Q. Allright. What makes you think that? MR. CRITTON: Speculation. THE WITNESS: He's always been kind and respectful. BY MR. EDWARDS: Q. Ever invited you to dinner? A. No, sir, Q. Have you ever associated or socialized with him during the day at any of his homes? A. Only during a business reason. Q. Okay. What are the other -- are the places that you believe that Mr. Epstein owns? | know we've talked about this Manhattan -— the Manhattan house. I've read the articles about it, the Paim Beach mansion. But what other places are you familtar with that Mr. Epstein owns? MR. CRITTON: Form; predicate, speculation. THE WITNESS: To answer it honestly, | don’t know specifically that he owns any of the residences, to be honest. | would only assume that he owns. So if you want me to answer honestly, F don't know that he owns any of the other. BY MR. EDWARDS: Q. Okay. Well, what would be the basis for your Larry Visoski October 15, 2009 25 27 1 assumption that he owns the home in Palm Beach? 1 Q. Are those private airports? 2 A. He goas there, but I don't assume -- you don't 2 A. Public. 3 have to own a house to go to it. 3 Q. Public, okay. Are there any private landing 4 Q. And not only does he go there, you're aware 4 places where you would land any airplanes in New Mexico4 5 that he spends the night there; he resides there s A. There are. 6 sometimes, correct? 6 Q. That you have landed -- 7 A. Yes. 7 A. That have, 8 Q. When he's in Palm Beach, that's where he -- 8 Q. ~ his airplane? 9 A. He sleeps. 9 A. Yes. 10 Q. - sleeps? Right. When he's in New York, do 10 Q. Where? 11 you know where he siseps? a2 A. We have a 4500-foot strip on the ranch. 12 A. No. 12 Q. When you say “we,” yourself and somebody? 13 Q. But you've been to a particular house in New 43 A. The company. 14 York that's a very large house that we've all read about 4 Q. What company? 15 that you picked up luggage at, right? 4s A. Well, { should say — t see where you're going 16 A. Yes, sir. 16 with that. The ranch owns — whoever owns the ranch, 17 MR. CRITTON: Form. 17 The ranch has a runway on it. 18 BY MR. EDWARDS: 18 Q. Okay. And you've landed an airplane on that 19 Q@. And that home, do you know that — | know that 19 runway? 20 you're saying that you haven't done a public record 26 A. That ranch, yes. 21° search to make sure that Jeffrey Epstein owns it. 21 Q. How many times do you think you've landed 22 A. Yeah. 22 there? 23 Q. But you assume that he does? 23 A. Ten. 24 A. Assuming. 24 Q. Allright, And have you been inside his as Q. That's where he sleeps when he's in New York?} 25 ranch? 26 28 1 MR. CRITTON: Form. L A. Yes. 2 THE WITNESS: | assume. 2 MR. CRITTON: Form to the last question. 3. BYMR. EDWARDS: 3 MR. REINHART: Can you clarify, the physical 4 Q. That's where his luggage is when you pick it 4 ranch or the residences or the structures on the Sup? a ranch? 6 A. Doesn't mean he owns it. 6 MR. EDWARDS: | don't have a good visual 7. Q. Right. But that's where it is? 7 appreciation for it. 8 A. Yes, sir. 8 BY MR. EDWARDS: ¥ Q. Do you know of anybody else who owns that hom 9 Q. Why don't you describe it in your words what 10 in New York? 10 this ranch that we are talking about looks like. And LL A. No. 11 Fve heard it referred to as the Zorro Ranch. Have you 12 Q. Okay. Have you been to his ranch in New 12 heard that? 13 Mexico? 13 A. [ve heard that. 14 A. Yes. 14 Q. That's the ranch we're ail familiar with, 15 MR. CRITTON: Form. 15 — we're talking about where the runway is and everything 16 BY MR. EDWARDS: 16 else? WwW Q. How many times have you been to his ranch in 17 A. Yes. 18 New Mexico? 18 Q. Describe it in your own words, the landscaping 1s MR. CRITTON: Form; predicate. 19 of this ranch. What do we have on it? 20 THE WITNESS: A guesstimate, fifty times, only 20 A. There is a house up on the hill, a large 2i due to the fact that we would fy there. 21 house. 22 BY MR. EDWARDS: 22 Q. How big? 23 Q. And where would you land? 23 A. Big. I've read 40,000 square feet in the 24 A. Depending upon the aircraft, ether 24 paper. 28 — Albuquerque or Santa Fe. 25 Q. Have you been to it? Larry Visoski 29 A. Yes, Q. Does that seem like it's feasible, approximately 40,000 -- A. | think $0, yes. Q. What else do we have on it? A. There is a compound that has kind of motel room type — they call it bunkhouse. Q. Where's the bunkhouse located? A. Atthe entrance to the ranch, Q. Okay. And what is that primarily used for? A. For the people that work on the ranch, they reside there. {t's alse a place where anybody that traveled on the airplane would stay. It's kind of like, you know, a hotel room. Q._ And how far is that from the first house that you described, the 40,000 square foot house? A. It's probably 4 miles. Q. Okay. So the Zorro Ranch is a rather jarge area of property? A. Yes. Q. And how many times ~ | know we just talked about how many times you've been in the house, but how} 22 Q. Why did he do that? many times have you been on that ranch in New Mexico, the Zorro Ranch? A. Thirty to fifty times over the years. That's 30 a quesstimate. Q. Is that over ~ when was the first time that you went to that ranch? A. A guess, | don’t know when it was, actually, our first trip, but 1995/94. Q. Okay. And do you believe Jeffrey Epstein and/or a corporation owned or controtled by him to be the sole owner of that ranch? A. I don't know any of those details. Q. Have you ever talked to Jeffrey Epstein about who owns that ranch? A. No. Q. Do you know of anybody else who may own thal] 13 you free and clear? ranch? A. Not to my knowledge. Q. Other than Jeffrey Epstein, do you know of anybody else who regularly stays there when they'te in New Mexico? A. Not to my knowledge. Q. Doas Jeffrey Epstein stay there when you're in New Mexico? A. He has. Q. And he has a key to the place? A. I don't know if there's a key. Q. One way or another, he gets in, right? October 15, 2009 31 A. Yes, sir. Q. And he sieeps there? A. Yes. Q. Okay. A. Lassume he does. Q. You assume he sleeps? A. Ido, I think, Q. Okay. MR. CRITTON: This is really 16 BY MR, EDWARDS: 11 Q. Other than the pool heater in 1995, have you 12 ever received any other gifts on top of the compensation’ 13. from Mr. Epstein? 14 A, did get land on the ranch to build a house. Sern Eewne 15 Q. What do you mean you got land on the ranch? 16 A. He deeded me land to build a home. 17 Q. When was that? 18 A, Ten years ago at least. 19 Q. Do you know if he's ever deeded anyone else in 20 this world land on the ranch to build a home? Zu A. Not to my knowledge. 23 A. We would vacation out there and my wife fell 24 in love with New Mexico and we were looking for property. 32 Q. And did you talk to him about that? A. Yes. He knew! -- he was aware | was looking for a home and he says, "Well, | have so much land, | could give you a spot to build a home on.” So | built a house. Q. So how long has a home actually been on that property? A, Nine years. Q. And that's a home that you own? 10 A. Yes, sir. 11 Q. And that's a home that was -- when | say “you 12 ownit,” is there a morigage on it or did he give it to COIR AWNE 14 A, No, no, | paid for the house. I made payments 15 onit. 16 Q. Albright. So what did he actually give you? 7 A. 40-acres of land. 18 Q. That you did not have to pay for? 19 A. You know, I'd have to go back and look. | 20 think itwas ~ | had to pay something for it. I don't 22 remember. 22 @. How often have you visited that piece — that 23 home that you own? 24 A, My wife would spend summers out there with the kids. Larry Visoski 24 25 wovnauaune 10 il 12 13 14 1s 16 17 18 19 20 an 22 23 24 25 October 15, 2009 33 Q. Okay. But that's on the Zorro Ranch? A. Yes. Q. So in addition to the 50 or so times you've been to the Zorro Ranch, you've been to your property that's on the Zorro Ranch? A. Yes, which over the years, its once-a-year visits. So | mean, it is included in the 50 times that I've been there. Q. Okay. And did you have a conversation with him that led to him giving you or gifting you 40-acres of land? A. We talked about it because he knew f was looking for a home out there. Q. Okay. in gifting you that land, did you consider yourself at that point in time to be more than just his pilot, as more af a friend? A. No. You're using the word "gifting." { paid for the land. | don't recall what it was. But you use the word “friend.” | don’t know that a — sure, he was a friend. | mean... Q. Well, did he give Dave Rogers any land out on the New Mexico ranch? A. No. Q. Okay. When you say you paid for it, | thought that { asked that question, "Did you pay for the 34 40-acres? ¢ thought your answer was, “I don't know, ¥'d have to go back and took." Are you saying now that you did pay for that land? A. {don’t remember. Hf there was a sum of money, it was just for, you know, the legal purpose of a transfer of ownership of the fand. Q. Okay. if twas 2 substantial amount of money, that's something that you would have remembered? ‘A. Oh, exactly. No, it was not a substantial amount. Q. Okay. Do you remember approximately how much money you had to give Jeffrey Epstein for that tand? A. i would only be guessing. it might have been five dollars. To my knowledge, | don't remember. Q. Okay. So when I'm saying he gave you the land, he may have actually given you the land? A. Sure. Q. Okay. And to the best of your knowledge, he's never given anyone else land out there? A. Notto my knowledge. MR. CRITTON: Form, BY MR. EDWARDS: Q. Allright. How big is this house that you built on the ranch? 35 A, 1800 square feet. Q. Were you ever at that house at the same time when he's at his house that's on that Zorro Ranch? A. Yes. Q. Allright. We started back in 1991 with you making around $55,000 a year and that has progresser over time to a point where in 2007 you were making $200,000 a year. | don’t want to go through every single year, that would take a really long time, But the progression, was that on a yearly basis normally or after two years or three years? A. Yearly basis. Q. Okay. And would that normally be in increments of? A. $5,000, Q, Okay. You've talked about a couple other gifts that have been given to you from Jeffrey Epstein over the years; one is 2 poo! heater in 1995 and now some 40 acres of land on his New Mexico ranch. Any other gifts you can think about? A. No other gifts. Q. Okay. | don't want to split hairs with you. You obviously thought about that answer before giving it. What other items are you thinking about that he's given to you or cut you a discount on or otherwise that 36 you feel was compensation for you working for him? A. Idrive a company car. | mean... Q. Okay. What kind of car? A. AHummer. Q. You say “a company car." That's owned by NES, LLC? A. No, | think the registration has Zorro Development on it. Q. What is Zorro Development? A. | believe that's the ranch, or at least it has the name of the ranch. | don't know what the entity is. Q. And it's your understanding that that's a company vehicle? Yes. And where is that vehicie primarily garaged? At my home. . In West Paim Beach or in the Zorro Ranch? .. No, here in West Palm Beach. . Albright. And is there onty one company vehicle that you're issued? A. Yes, sir. Q. And is that something that was — that you did not have to pay for? A. No, it's Just something | drive, | mean, it's not titled to me or anything like that. It's just a car OProror Larry Visoski October 15, 2009 37. 39 1 that I drive. 1 Q. And which airpiane was that? 2 Q. Allright. You've worked for him tor 18 2 A. The Hawker. 3 years. | don't even know how fong the Hummer would 3 Q. Does he still have the Hawker? 4 last, but presumably, that's not the car you've had over 4 A. No. 5 the entire 18 years. Have you always had a company car?} 5 How long did he have that plane? 6 A. No, (havent, no. 6 A. Five years, guesstimats; four or five years, 7 Q. When did you get the Hummer? 7 Q, So sometime in the mid ‘903? 8 A. Probably three years ago. 8 A. Yes. 3 Q. Do any other members of Mr. Epstein's piloting 9 Q. Did you keep any type of logs or documentetion 10 {eam have company cars? 10 as to who would have been flying on that airplane if you aL A. No. 11 vansported any individuals? 12 Q. Only you? 12 A, The same logs a6 you possess now are the 13 A. Yes, 13 flight logs. 14 Q. And do you know how that decision was made to 14 Q. Okay. 15 get you a company vehicte? is A. Thaf's the standard for the industry. 16 A. No. 46 Q. So that’s something that you kept, or that 17 Q. What do you use that vehicle for? 37 Dave Rogers kept? is A, To and frorn the airport. 18 A. Dave Rogers. 19 Q. Allright. Do you use it for personal reasons 19 Q. Okay. If there are any documents out there 20 also? 20 with names of passengers on any of the fights involving 24 A. fguess, yes. 21 planes owned or controlled by Jeffrey Epstein and/or his 22 Q. I mean, that's your primary vehicle? 22. companies, those would be documents in the possession of 23 A. Yes, or | drive my wife's car. 23 Dave Rogers and not yourself? 24 Q. Which is? 24 A. Oh, the corporation actualty, thay belong to. L 25 A. Type of car? 25 Q. Okay. 38 40 1 Q. Yes. 1 MR. REINHART: That was a compound question. 2 A. AMercedes. 2 You might want to split itin half. 3 Q. And is that something that was also a gift 3 MR. EDWARDS: Okay. 4 — from Mr. Epstein? 4 BY MR. EDWARDS: 5 A. No, sir. s Q. What documents do you believe exist that 6 Q. What type of Mercedes is that? 6 indicate names of individuals that have been passengers 7 A. AML 430, ten years ald. 7 on Mr. Epstein's airplanes? 8 Q. Albright. Are there any other items -- 8 MR. REINHART: Are we going back all the way 39 company cer, the land in New Mexico, the pool heater -- 9 from ‘91 to the present? 10 any other items that Mr. Epstein has given you over time 10 MR. EDWARDS: Sure. 11 aS compensation or reward or anything else? il THE WITNESS: You're talking about the Hawker? 12 A. No, sir. 12 BY MR. EDWARDS: 13 Q. And your only income is from Mr. Epstein or 13 Q. Any airplanes. What documents would there be? 14 his companies? 14 A. There would be the same: Flight logs and 4s A. Correct. 15 passenger manifests would exist, 16 Q. Okay. And it's been that way since 1991? 16 Q. And are either of those required? v7 A. Yes, sa A, The fight iog is required for the aircraft to 18 Q. How did you meet Mr. Epstein or become: 18 track times and landings. 13 — invoived with him in 1991? 12 Q. Ard in the flight log, is # required that you 20 A. We heard at the airport that Mr. Epstein was. 20 — designate the names of the passengers? 21° purchasing an airplane when Dave Rogers and myself wer¢ 21 A. No. 22 iiving in Columbus, and we had the opportunity to 22 Q, That's just something that Dave Rogers did on 23 interview with him, and we did and got the job. 23 his own? 24 Q. And this is before he owned the airplane? 24 A. Everybody does that. it's more for Internal 2s A. Yes. 25 Revenue. Larry Visoski October 15, 2009 Ai * Q. Okay. if something happens, they know who is 2 2 onthe plane? : 2 3 A. Exactly, weight and balance. 3 4 Q. Have you ever kept any flight lags that have 4 5 names of people on the airpiane? 5 6 A. When you say *kept,” | have filled out flight 6 7 togs or the passenger manifest, yes. 7 8 Q. By "kept" f meant maintained to where they're 8 9 in your possession either on paper or computer? 9 19 A. We keep - 10 11 MR. REINHART: Can you differentiate a flight 4 12 tog from the pilot's log that we showed you 12 13 earlier? 13 14 MR. EDWARDS: Okay. 14 15 BY MR. EDWARDS: is 16 Q._ I'm talking about -- ! don't know that it's 16 17 cated a flight log, 2 pliot’s tog or any kind of log. a7 ie A. They are different, yes. 18 19 Q. Yeah. I'm asking about, have you kept or do 19 20 you have any documentation that would indicate the names 20 21 of passengers that have flown on any of Jeffrey 24 22 Epstein's planes? 22 23 A. No. 23 24 Q. Either in the form of paper or on a computer? 24 25 A. No. 25 42 1 Q. Makes that easy. 1 2 A. Okay. 2 3 Q. In 1991, were you the chief pilot? 3 4 AL No. 4 5 Q. Somebody else was the chief pilot? 5 6 A. Yes. € 7 2. Who's that? 7 8 A. Dave Rogers. 8 9 Q. Allright. At what point in time did you s 10 become chief pilot and switched with Dave Rogers? 10 11 A. Six years ago; five, six years ago. uz 12 Q. Why? Fra 13 A. Professionalism, technique. 13 14 Q. What do you mean by that? 14 15 A. The way Dave would operate an aircraft, 15 16 Jeffrey knew the difference when | was flying and when} 16 17 Dave was flying. 17 18 Q. How do you know he knew the difference? 18 19 A. Just ~ 19 20 Q. He told you? 20 aL A. Yes. He knew the difference that if he never 21 22 came up front, he knew whe was flying, who landed. 22 23 Q. And what was the conversation that he had with} 23 24 you that resutted in you becoming chief pilot, switching | 24 25 positions with Dave Rogers? 25 43 A. Jeffrey would always critique Dave's flying capabilities, and | tried to help Dave and expiain to him what Jeffrey likes and doesn't like, And Jeffrey's aiso conveyed these likes and dislikes. And Dave maintained continuing with certain piloting techniques that were just not comfortable to passengers. And this ‘went on through the years, and Jeffrey just got tired of it one day. Q. What specifically were Jeffrey Epstein's tikes and dislikes with respect to the flight of the plane? MR. GRITTON: Let me put in a form here. But | don't know what this has to do with anything in this case, MR. EDWARDS: | understand that, Bob. MR. CRITTON: | want to use this for some ‘other depositions where we -- we've gone beyond the ‘scope. THE WITNESS: The case in point, the last straw was there was a technique called quiet flying where you would retard the throtiles well short of the runway and pretty much glide the aisplane in. Well, if you doen't do that correctly, you have to ‘spool the engines up just prior to touching down that — because you're losing air speed and it's an uncomfortable sound and feeling for the passengers 44 thinking that you're nat going to make the runway. And it was a continuous practice of Dave doing that to be neighbor friendly as opposed to being passenger-comfort friendly. BY MR. EDWARDS: Q. Okay. A. Hence, the transfer of power. Q. Has he ever discussed with you where he wants you to be, whether that is "stay in the cockpit when | have people on the airpiane,” or don't intermingle with the passengers or anything else? A. He's never stated that to us. MR. REINHART: Could you clarify which "he” you're talking about? MR. EDWARDS: I'm taiking about Jeffrey Epstein. MR, REINHART: Okay. BY MR. EDWARDS: Q. You understood that? A. Yes. Q, It's my understanding that in the -- well, teit me other than the Hawker, what other airplanes har you flown for Jeffrey Epstein? A. AGuifstream. Q. Does he still have that plane? Larry Visoski ee, October 15, 2009 45 47 1 A. Yes, sir. 1 and who was on the flights? 2 Q. How big of a plane is that? 2 A. One flight | believe we went to Sebring and 3 A. Large corporate jet. 3. another flight we went to Nassau, Bahamas. 4 Q. How long has he had it? 4 Q. And who did you go to Nassau, Bahamas with? 5 A, Fourteen years; 13, 14 years. 5 A. fd have to look at the flight log, but / 6 Q@. And other than the Gulfstream, what other 6 think it was Sarah, Story and Nadia, | believe. | think 7 airplanes does he have? 7 that was the three passengers, to the best of my a A. When you say "he," obviously, these are 8 knowledge. 9 company-owned — 2 Q. And it's my understanding that little 10 Q@. Jeffrey Epstein or his companies, 16 St. James is an istand that Jeffrey Epstein owns or a1 A. ABoeing 727. 11 controls? 12 Q. Weil, | know that's a very large airpiane, f 12 MR. CRITTON: Form. 13 _ think that's been described by other people, so fm not 13 THE WITNESS: 1 don't Know that he owns it. 14 going to have you do that. But there's partitions in 14 BY MR. EDWARDS: 15 that airplane ~ in the back rooms of that airplane, 15 Q. Has he ever been to an island called Little 16 right? 16 St. James? a7 A. Yes. 17 A. Yes. 18 Q. Several different partitions to where if the 18 Q. And have you been there with Jeffrey Epstein? 19 pilot comes out of the cockpit, you don't necessarily 19 A. I've been there when he was there. 20 see all the passengers? 20 Q. Have you flown on an airplane with him to that ay A Yes. 21 destination? 22 Q. That's true? 22 A. No. 23 A. Yes. 23 Q. Allright. When you say you've been there 24 Q. Okay. 24 when he was there, how did that come about? 25 MR. REINHART: Keep your voice up so she can} 25 A. We flew into St. Thomas and then we flew to 46 48 2 hear you. 1 Little St. James in a helicopter. 2 THE WITNESS: Oh. 2 Q. And do you fly the helicopter as well? 3 MR. REINHART: And so Mr. Willits can hear 3 A. Yes. 4 you, 4 Q, How many helicopters are owned or controlled 5 BY MR. EDWARDS: 5S by Jeffrey Epstein and/or corporations associated with 6 Q. Other than the Gulfstream and the Boeing and 6 him? . 7 the Hawker, what other airplanes has Jeffrey Epstein 7 MR. CRITTON: Form, 8 owned over the years? 8 THE WITNESS: Af this time, one. 9 A. That is it. 9 BY MR. EDWARDS: 10 . And currently still owns — or the companies 10 Q. And has that helicopter been flown in the last 11. associated with him own the Gulfstream and the Boeing?} 11 two years? 12 A. Yes. 12 A. Just for routine maintenance. 13 Q. And in the past two years, have you flown 13 Q. And when you and -- let's say when Sarah 14 those two airplanes? 14 Kellen and Story Cowells and Nadia flew to Nassau, do 15 A. Just for routine flights to keep them foose 15 you know the purpose of that trip? 16 or, you know ~ you know what mean. 16 A, No. a7 Q. Have those two airplanes been flown by anyone j 17 Q. How long did you stay? 18 else in the last two years? 18 A, Five hours. 19 A. No. 19 Q. Did you pick anybody up there? 20 Q. Have those two airpianes been flown in the 20 A, No, Meaning passengers? 21 —_Jast two years for any reason other than routine 22 Q. Yes. 22 maintenance-type flights? 22 A. No. 23 A. We've had one -- two flights | think in the 23 Q. What happened? You landed the airplane and 24 past two years. 24 then what? 25 Q, And what were the purposes of those flights. 25 A. The passengers left. Dave and ! went and had Larry Visoski October 15, 2009 49 51 1 lunch. The passengers showed up and we came back. 1 tohis island?” We never landed on his island. We 2 Q. Have you ever stayed at the home that is on 2 fanded in St. Thomas. 3 Little St. James? 3 Q. Got it. 4 A. No. 4 A. Swas just trying to be exact. 5 Q. Have you known Jeffrey Epstein to stay at that 5 Q, Thank you, 6 home? 6 A. It's a small island. ? A. | don't know that for @ fact. 7 Q. Okay. So how is it that when Mr. Epstein 8 Q. Okay. Do you believe that he is the owner or 8 wants to go to Little St. James, what is the path that 9 controller or has some interest in the home or the 9 you take to get actually to the isiand of Little 10 istand of Little St, James? 10 St. James? iL MR. CRITTON: Form. il A. [don't understand the question. 42 THE WITNESS: i have no knowledge of that 12 ©, Weil, you just told me you fly the airplane to 43 being a fact. 13 St. Thomas? 44 BY MR, EDWARDS: 14 A. Right. is @, And you have no belief that that is a fact? 15 Q. And then wrat? 16 A. Bxactly, 16 A. Then sometimes | would go get the helicopter a7 Q. When you say you've been there when he was 17 or he could also take a boat to the island. But 18 there, how many times has that occurred? 18 normally the helicopter's located on St. Thomas. I'd as A. Estimating, a hundred times. 19 fire up the helicopter, come pick him up, drop him at 20 Q. Okay. 20 the island and § come back to St. Thomas. 24 A. Trying to give an honest answer. 21 Q. And when he stays on St. James, you drop him 22 Q. Okay. And in the approximate --I'm not going | 22 — offon St. James. | suppose you're going to tell me you 23 to hold you to a hundred times, but in the approximately! 23 don't know if he stays there or not? 24 ‘hundred times — 24 A. Exactly. 25 A. Sure. 28 Q. But do you stay — 50 52 1 Q. — for what period of time are we taiking 1 A. [don't | mean ~ 2 about? 2 Q. Well, he either stays there or someone else 3 A. During what period of time? 3 picks him up in a helicopter or he swims away? 4 Q. Right. 4 A. Correct. 5 A. Let's see, when‘ did all this happen? What, 5 Q. Okay. You stay on St. Thomas? 6 20077 So eight years prior to whenever he stopped 6 A. Yes. 7 flying. So... 7 Q. Okay. Is there a place that you've stayed on 8 Q. ‘98°99? 8 St James, ever? 9 A. Yeah, I guess, yes. 9 A. No, I've never. 10 Q. imean, that sounds like a right - 10 Q. So in the hundred or more times that you've 11 A. Sounds about right, yeah. Don’t hold me to it 11 been to the island, is it my understanding that each of 12 again. 12 those times you've been there to drop off Jeffrey 13 Q. All right. 13 Epstein and/or any passengers and you've immediately 14 A. You're going back a jong way. 14 left. and gone to St. Thomas? 15 Q. So from approximately the ‘98/99 time frame is A. Yes, sir. 16 when Jeffrey Epstein would fly to Littie St. James, 16 Q, You never been inside that home that's located 17 would you be the pilot? 17 on St. James? 18 A. Yes. i8 A. Yes, I've been inside the home. 19 Q. Okay. And you say that you've been there ~| 19 Q. How many times have you been inside the home? 20 thought that you just told me that you've been there the; 20 A. i mean, ten, fifteen times. 21 same time he was there, but then | thought the 22 Q. And for what occasion? 22 subsequent question was weil, were you on the fight 22 A, ve set up the theater system that's in the 23 with him, and | thought your answer was no. Maybe | 23 living room. 24 misunderstood that. 24 Q. Okay. 26 A. No, you said the question "Have you ever flown | 25 A. So it would be there to work to hook up a TV Larry Visoski 53 ora stereo, Q. And do you know Les Wexler? A. No, I don't. Q. Have you ever met him before? A. Ihave met him. Q, Do you know of any relationship between Les Wexler and Jeffrey Epstein? A. | don't know what — to what extent they have a relationship, no, Q. Do you know if they know one another? A. | don't know that for a fact. They talk to one another, so would assume. But | don't know to -- Q. How do you know they taik to one another? A. I've seen them speak to one another at the foot of the airplane. Q. Allright. Have you ever flown the airplane — any of the airplanes with Les Wexler as @ passenger? A. Ne. Q. Have you ever flown the airpianes with Sarah Kellen as a passenger? A. Yes. Q, And do you know Sarah Kellen? A. Yes. Q. And for how tong have you known Sarah Kellen? 54 A. I'm guessing, six years. | mean, don't hold me to it. |'m not the greatest on length of times, but six, seven years, | think. Q. How did you meet her? A. {guess | was introduced. She was on a flight of ours. Q. You were introduced to her by whom? A. She may have introduced herself. { mean, you're going back a ways. | don't know the official introduction, how it went, Q. And to your knowledge, what is her is she associated or affiliated in some way with Jeffrey Epstein? MR. CRITTON; Form. THE WITNESS; | would assume so. | don’t know to what level or what actually her job description is. BY MR. EDWARDS: Q. Alltight. Well, how many flights have you flown where she and Jeffrey Epstein Rave been passengers together on one of the airplanes that we've been discussing? A. d only be guessing again. Q. We're talking hundreds of flights, though? A. Sure, sure, a lot of flights. wWeranuneune 28 ‘somebody who has common sense. It seems ike someb: that knows Jeffrey Epstein? BY MR. EDWARDS: business relationship thers or a personal relationship there, from your observations? airplane, my focus is forward and flying safely. So! don't-- you know, I'd only be guessing at either one of those two. Kellen? have you spoken with her elsewhere? down the street in New York. I mean. yes. she calf you? Kellen? air her s a departure. A Q. A. Q A a A Qa v2 A. Was actually — actually, it was for the helicopter. Now that I'm thinking about if, the October 15, 2009 55 Q. itseems to be — i mean, you seem like MR. CRITTON: Form. Q. Correct, Sarah Kallen? A Yes. Q. Allright. And do you believe that there is a A, [only be speculating. When they get on the . Okay. Have you ever socialized with Sarah A. No. Q, Other than speaking with her on the airplane, A. Over the phone, in passing, | mean, walking Q. Why would you calf Sarah Kellen or why would A, She would call me to schedule the aireratt for 56 Q. And have you ever called her? A. Yes. Q. When's the last time you talked to Sarah A. Aweek ago. Q. What was the occasion? A. We were discussing carpet for one of the craft. And where was she when you were talking with] don't know. It was over the phone. Did she cail you or you call her? No, i cafled her on her cell. Okay. And that's a New York number? i don't know. if's on speed dial. Do you have your phone with you? Yes. Could you tell me what that number is? Sure, Thanks. Sure. (917)855-3363. Which airplane were you discussing carpeting pPPrOrre Larry Visoski October 15, 2009 57 59 helicopter, 1 Q. How fong have you known Nadia Marcinkova? Q. In the last two years, did you tell me the 2 A. I don't know, five years. A guess again, helicopter has flown? 3 four, five years. A. Yes. 4 Q. Do you know what her relationship is, if any, Q. And where to? 5 with Jeffrey Epstein? A. | have flown the helicopter to Fort Lauderdale 6 A. Ido not know, on several occasions for maintenance. I've flown it to| of Q. Do you know if she knows Jeffrey Epstein? Miami. And | try to fly the helicopter at least every 8 A. would assume so. They talk. 1 would two weeks just either by myself to run it up to its 9 imagine she knows him. it's important that it keeps moving. 10 Q. And how many times has she been on the Q. Other than maintenance-type flights, have you; 11 airplane or the helicopter on fights at the same time flown the helicopter in the last couple of years? 12 as a passenger with Jeffrey Epstein? A Yes. 13 A. Many. I'd have to look at the fogs. Q. And who was on the helicopter? 14 Q, Hundreds of times? A. I flew to Miami with Mr. Epstein. 415 MR. CRITTON: Form, Q. When was that? 16 THE WITNESS: Sure. A, twas a couple weeks ago or a month ago, | 17 BY MR. EDWARDS: think. 18 Q. Ifyou were going to, as somebody who has beer} Q. For what? 18 Jeffrey Epstein's pilot for 18 years, tell me today who. A. Sorry? 20 the five closest people are to Jeffrey Epstein, would Q. For what occasion? 21 Nadia be one of them? A. | think he had a meeting with his attorneys in 22 MR. CRITTON: Form. Miami. 23 THE WITNESS: ''d only be guessing and Q. Teday is October the 15th. Is this during the 24 speculating. ! have no idea. month of October that you had this flight in the 25 58 60 helicopter with Mr. Epstein? 1 S8YMR. EDWARDS: A. I'd have to look at the book to be exact for 2 Q. Okay. Well, as his pilot and the person who you. 3 travels with Jeffrey Epstein on the majority of his Q. Okay. But it's either the end of Septernber or 4 flights, who are the people who travel most frequently the beginning of October? S with Jeffrey Epstein? A. Yeah. x 6 A. I'd have to look at the logs. Q. How do you know that he was meeting with his 7 MR. REINHART: Can we get a time period? attorneys? 8 BY MR. EDWARDS: A. believe that he had mentioned that he was. 9 Q. inthe last ten years, which people travel meeting his attomeys. 10 most frequently with him? Q. Did he tell you why? i A. ('d have to look at the flight jogs to give A. No. 12 you an accurate answer. Q. Why did he teil you he was meeting with his 13 Q. You can't give me one single name of somebody: attomeys? Did you ask him? 14 — who you would say is a frequent fiyer? A. No. é 5 A. Sarah. Q. Okay. That's just something that he said to 16 Q. Sarah Kellen? you in conversation? 7 A. Yes. A. Yes, sir. 18 Q. Anybody else? Q. Was there anyone else on the aimplane besides; 19 A. Nadia. you and Mr. Epstein? 20 Q. Nadia Marcinkova? A. Yes. 2h A. Yeah. Q. Who was that? 22 Q. Okay. Anybody else? A. Nadia. 23 A. Just mainly those two. Q. Nadia who? 24 Q. How about Ghislaine Maxwell? A. Nadia Marcinkova. 25 A. Not for some time, Larry Visoski October 15, 2009 OIA eune © 11 12 13 14 as 16 1? is a9 20 21 22. 23 24 Oey AGEwrHe 10 al 12 13 14 is. 16 7 18 19. 20 au 22 23 24 61 63 Q. What's your understanding between the 1 Miami? relationship of Ghislaine Maxwell and Jeffrey Epstein? 2 A. Twenty-five minutes. A. [don't really know. 3 Q. And did they taik to one another during that Q. Allright. So when you say you're guessing 4 flight? that Nadia Marcinkova and Sarah Kellen know or are $ A. No. associated with Jeffrey Epstein, that guess is being 6 Q. They were both compietely sitent during that made on the ~ with the observation that they have been: 7 flight? frequent flyers with Jeffrey Epstein on more than 8 A. Yes. hundreds of flights on his private plane? 9 Q. Okay. is that typical when they are on A. Yes, that's what I'm basing it on. 10 flights together, especially with the helicopter, where Q, And do you know where Nadia Marcinkova is 11 you're in pretty close quarters, that they would absiain staying these days? 12 from speaking to one another? A, No. 13 MR. CRITTON: Form. Q. Do you know what car she's driving these days?; 14 THE WITNESS: Yeah, it would be typical. It's A. No, fdon't, iS very noisy and communicating in a helicopter is, Q. Okay. Do you know if she's living with 16 you know, not that comfortable, Jeffrey Epstein these days? 17 BY MR. EDWARDS: A. I don't know that. 18 Q. Over the last five or six years that you have Q. Do you know how Nadia Marcinkova met Jeffrey, 19 — known or been familiar with Nadia Marcinkova, have yot Epstein? 20 heard her and Jeffrey Epstein conversing with one A. tdon't. 21 another? Q. Were you on an international flight bringing 22 A. Ive heard them conversing, but if you ask me her into the country from some other country at any 23 what they had said, I could say it~ | wouldn't even time? 24 know what they had said to each other. I've seen them A. | don't know. 25 _ talking to each other. 62 64 MR. REINHART: Can we clarify? You mean with x Q. But you don’t remember a single specific Mr. Epstein or -- 2 conversation between Jeffrey Epstein and Nadia MR. EDWARDS: No. 3° Marcinkova? BY MR, EDWARDS: 4 A. An honest answer, no. Q. Did you ever bring Nadia Marcinkova from some 5 Q. Okay. And the same for Sarah Kellen; have you foreign country into the United States? 6 seen or -- have you seen Jeffrey Epstein speak with A. I'd have to took at the log books, honestly. 7 Sarah Kellen? Q. That's not something you remember? 8 A. I've seen him speak with her, yes. A. No. Imean, she ~ | think she's been on 9 Q. Can you tell me a single specific conversation Europe trips with us, and | think she's returned from 10 that you have overheard between Jeffrey Epstein and Europe with us, but 1 could not say that honestly. 11 Sarah Kellen? Q, On this recent helicopter flight with Nadia 12 A, One thing that comes to mind would be make Marcinkova and Jeffrey Epstein, did you talk with them 13 sure we have Oreo cookies on the airplane. it would be during that flight? 14 something completely nonchalant. A. No. 15 @. Okay. And do you know or have reason to know Q. Where did the flight go from? And obviously, 16 — of any employment relationship between Sarah Kellen and it landed in Miami, but where did you leave from? 1? Jeffrey Epstein? A, West Palm Beach. 1 A. Shave no knowledge of any of that. Q. And did Nadia and Jeffrey Epstein arrive 19 GQ. Do you know if Sarah Kellen works for Jeffrey together? 20 Epstein? A. You know, I don't remember. | was out at the 23 A. Ido not know. helicopter and | think they both started walking up. So | 22 Q. Do you know if Sarah Kellen schedules massages | den’t know if they came separately of not. | was 23 Sor Jeffrey Epstein? already at the helicopter. 24 A. Thave no idea, Q. How long is that flight from Paim Beach to Q. Has Jeffrey Epstein ever indicated to you that Larry Visoski 65 he is fascinated or infatuated or appreciates or loves or likes massages? A. | have no knowledge of that. Q. Ali right. How about Ghislaine Maxwell, has she ever talked to you about massage therapy or have you: ever overheard her talking about that? A. No. Q. You certainly read the papers over the last couple of years, correct? A, Not on my top ten fist. 1 mean, I've read 2 couple articles, but I'm not one ta focus on that so much as some peopte would. Q. Okay. When the investigation about Jeffrey Epstein came about, the criminal investigation ~ youre aware that's what I'm talking about, right? A. Thatwas last year? Q. Well, it was a coupie years ago. A. Right, okay. Q, Did you speak with Jeffrey Epstein about that investigation? A. No. Q. Were you told not to speak with him about that investigation? A, | think we knew ourselves that we weren't — it wouldn't be proper to even bring it up. 66 Q. Allright. When you read in the newspapers the allegations that Mr. Epstein was involved with numerous underage girls for sexual reasons, were you} surprised? A. I didn't believe it. Q. Do you believe it today? A. t don't believe it. Q. You don't believe that Jeffrey Epstein was. invotved with underage girls in a sexual way? MR. CRITTON: Form. THE WITNESS: You're asking for my opinion, and | don’t think my opinion is relevant in that matter. BY MR. EOWARDS: Q. [think it's relevant. Can you just tell me whether today you believe that Jeffrey Epstein has engaged in sex with underage girls? MR. CRITTON: Form; speculation, irrelevant, always. THE WITNESS: It's irrefevant. BY MR. EDWARDS: Q. I need an answer. A. {don't believe he had sex with underage women, Q. Or engaged in any sexual acts with underage CRYHVSWNE October 15, 2009 oF women? MR. CRITTON: Form. THE WITNESS: No. BY MR. EDWARDS: Q. You think that this is just a story that a bunch of underage women have made up? A. Speculation. MR. CRITTON: Objection, Now its argumentative. Who gives a darn what he thinks one ‘way or another? If he has personal knowledge -~ MR. EDWARDS: You'te objecting to the form? MR. CRITTON: it's argumentative. MR, EOWARDS: You're objecting to the form? MR. CRITTON: Yes. MR. EDWARDS: Okay. BY MR. EDWARDS: Q. [s that something that you believe that a burch of women — some of which know each other, som don't, some of which have been on the airpfane and some which haven't — made this up, that Jeffrey Epstein engaged in some sexual conduct with them? MR. CRITTON: Form. THE WITNESS: What | believe doesn't matter in this case, does it? 68 BY MR. EDWARDS: Q |need an answer. Do you believe it? Do you ‘believe these girls made this up? MR. CRITTON: Form. MR. REINHART: I'm going to instruct him not to answer. Move on. MR. EDWARDS: Is there a privilege that we're asserting? MR. REINHART: No, it's irrelevant. It's harassment and not likely to lead to discoverable evidence. MR. EDWARDS: I'm going to put on the record right now that it is -- we are allowed discovery into. a RICO count. We are also allowed discovery into the intent of Mr. Epstein in developing a ctiminai enterprise designed to sexually expicit and sexually abuse underage girls. We believe that in doing so, he associated intentionally with people of similar beliefs that sex with underage girls is okay, and that there have been many discussions with this witness, as well as many other witnesses with -— to insure his protection from law enforcement that they not answer these specific questions. And thus, the opinions and beliefs of all of these witnesses that we are Larry Visoski 69 alleging associated with this criminal enterprise are certainly reasonably calculated to lead to the discovery of admissible evidence. And if you're still instructing the witness, based on that proffer, not to answer any of these questions, I'm going to continue to ask the questions and you can instruct him not to answer and we can go to the Court. MR. REINHART: My response is to his opinion whether people making allegations in this case are colluding or making up a story is irrelevant to what you just said. So | am going to instruct him not to answer any question that goes to his opinion of someone else's motivation or the truth of facts to which he has no knowledge. So yes, I'm instructing him not to answer. MR, CRITTON: Let me add in my part, is that | think -- you're certainly not only capable to ask questions with regard to what his personal knowledge is, and if he knows something or he has; reasonable basis for it; certainly you are entitled fo that information. | think you've asked those: questions and he’s given you straightforward answers as to what he knew or what he didn't kri under those circumstances, And as to what his 70 thoughts are on something which he has no factual basis or even an assumption to know one way or another is irrelevant. That's ultimately for a fact-finder in this case. ‘While it's interesting, it's argumentative and { don't think he's - 1 mean, do it on a question-by-question basis. if he has knowledge, that's great, but to argue your case with this witness or any other witness doesn't serve a purpose and | think is, you know — | think it's not a good use of our time, fil put it that way. But you know, you can go ahead and ask. MR. EDWARDS: | can ask the question and if the witness is being instructed not to answer, we'll let a judge decide whether he needs to answer the question and whether it's discoverable or not. MR. REINHART: Absolutely. Make your record. BY MR. EDWARDS: Q. Do you have any reason to believe that Jeffrey Epsiein engaged in sexual activity with underage women? A. thave no reason to befieve. Q. Okay. So as you sit here today, based on your 18 years of knowledge, experience and observation of Jeffrey Epstein, is it your belief that he has not hag sex or engaged in sexual activity with underage women? October 15, 2009 71 A. It's an opinion, and I believe that he has not. Q. Okay. Isn't it true that at some point in time you learned that Jeffrey Epstein has ~ strike that. MR. CRITTON: When you ultimately get to a good piace to break, will you let us know? MR. EDWARDS: Let's break now. (A break was had at 11:26 a.m.) BY MR. EDWARDS: Q. Allright. Eighteen years of being a pitot for Jeffrey Epstein and in terms of being able to name somebody that you would say you've observed with Jeffrey} Epstein and would classify that person as Jettrey Epstein's fiend, can you name anybody? A. Nadia, Sarah; just people that we see routinely on the airplane. Q. That's peopie you see routinely in the fast five to ten years, right? A. Yes. Q. Prior to that time, anybody that you've noticed as Jeffrey Epsiein's friend may be Ghislaine Maxwell? A. What time frame? Q. is that a person that at some point in time 72 you would classify as Jeffrey Epstein's friend? A. [would classify it. | don't know if it's true. Q. But that's only because they were on the airplane together? A. Yes. Q. Do you know what Jeffrey Epstein does for a Jiving in your 18 years of observing and talking with Jeffrey Epstein? A. No. Q. Noidea? A, No, |. Ever asked him? . No, actually. . Ever been curious? Sure. Ever done anything to satisfy that curiosity? .. if you mean Google it, not really, actually. I mean, | really have not, Q. Okay. So in 18 years of traveling and being the pitat and driving -- and taking this person, Jeffrey Epstein, from one property in New York to New Mexico ani Florida and around the world, you have no idea what he does in terms of how he makes money? A. No, sir. rPOPOPD Larry Visoski Coy Hee wne 10 12 13 14 15 16 Wy 18 is 20 22 22 23 24 25 OMAHHRYHE —-+> October 15, 2009 73 75 Q. twas produced this flight log - tell me if 1 Q. But it’s evident that the plane is being used, I'm using the wrong term. What is this called, this 2 at least for this time period, January of 2002 through book that I've bean provided by Dave Rogers? 3 2005, on a fairly regular basis. | mean, we're looking A. I've never seen that book. 4 at January 6th, 11th, 13th, 13th, 14th, right? Q. fillet you see it. I don't know that it was 5 A. Ub-huh. always in a book, 80 maybe that's why you haven't seen 6 Q. | mean, is that something that you would say it. Tell me what we're looking at, 7 accurately refiscts the amount of use of Jeffrey A. Well, judging with the name at the bottom, | 8 — Epstein’s pianes? believe this is Dave's flight log, log book. 9 A. Yes. Q. didn't know if it was called a flight og. 10 Q. So he travels quite frequently? A. Pilot log book, how's that? That's the al A. Yes. appropriate name. 12 Q. And he travels with many different people, Q. ttwas marked as Composite Exhibit 1 in 13 right? Roger's deposition, as indicated by the exhibit sticker. 14 MR. CRITTON; Form. We'll mark it the same in your deposition as weil, as ‘THE WITNESS: Yes. MR. CRITTON: Why don't you refer to it as 16 MR. CRITTON: Can 1 ask one question? | was. his? 17 wondering what happened, who has possession of now MR. EDWARDS: Fine. 18 what's the original Exhibit No. 1 of Mr. Rogers’ BY MR. EDWARDS: 49 deposition? Did you retain it? Q. ifs the pilot iag book of Dave Rogers? 20 MR. REINHART: The actual book itself? A. Yes. at MR. EDWARDS: The court reporter tock it, Q. And the years provided in this book are 2002 22 right? through 2005; | can represent that to you. I'm goingto j 23 MR. CRITTON: The one marked as an exhibit, ask you about certain people that David Rogers wrote 24 did you keep that? down as being on the airplane and I want to ask you if 25 MR. REINHART: This is it. 74 76 you know who they are. This person right here is Cindy: 1 MR. EDWARDS: This is it? Lopez. It seems like she flew on numerous flights. Do 2 MR. CRITTON: Whe took it from the deposition you know who that is? 3 the other day? A. No. [heard the name, but I don't know who 4 MR. EDWARDS: | have this one right now. that is. s MR. REINHART: That's the only copy? Q. Allright. Is that somebody that you remember 6 MR. EDWARDS: Okay. seeing on any of the flights that you were on? 7 MR. CRITTON: So you took the original? A. What year are we talking about here? I don't 8 MR. EDWARDS: Apparently. it has the original remember. 9 sticker. Q. Well, this is January 2002, You'd probably 10 MR. CRITTON: When I say “the original,” the know how to read this book a little bit better than me, 41 original copy. Would you have someone recreate 0 1 don't know. 12 what you've got and send it to us so we have It? A. He keeps his a lot more current, so | know the 13 MR. EDWARDS: Sure. In fact, why don't | wait name. If she waiked in here right now, | would probabl: 14 until 1 get the whole thing and I'l copy alt the look right through her, to be honest. 15 pages and send it to you instead of piecemeal. Q. Do you know what affiliation or relationship 16 MR. HOROWITZ: You mean before the transcript} she had with Jeffrey Epstein? 17 comes? A, No, 18 MR. EDWARDS: We can copy it. Q. Okay. There are various -- each row i'm told 19 MR. CRITTON: If you give it to me, Tit copy by David Rogers is a different flight and it indicates 20 it and send it back to you, where it takes off from and where it lands, et cetera. 22 MR. REINHART: f have a copy. It just doesn't There's a iot of other information, especially over on 22 have the exhibit sticker on. this side of the page that Pm not familiar with, nor do 23 MR. EDWARDS: That's what was told to me the (need te be. 24 other day, that’s why I took it. A. Right. 25 MR, CRITTON: FE want something — | just con't Larry Visoski oy 1 want to — if you give me a copy, I'll puta 1 2 sticker on it. 2 3 MR. REINHART: Or just copy the page that has} 3 A the exhibit sticker on it. 4 5 MR. CRITTON: Sorry. 5 6 BY MR. EDWARDS: 6 7 Q. Like on this flight, we have "JE." I'm 7 8 assuming that's Jeffrey Epstein, correct? 8 9 A. Yes, Mil assume. 3 10 Q. "GM," Ghislaine Maxwell, right? 10 iL A. Yes, al 42 Q. "SK," Sarah Kellen? 12 43 A. | wouid assume, 13 i4 Q, Imean-- okay. And then this name, do you 14 15 recognize that person, Alexia? 1s 16 A. Never heard it. 16 17 @. And then Cindy Lopez? 17 1s A. Yes, 18 19 Q. You've heard that name? 19 20 A. (Ve heard the name, 20 21 Q@. Not sure who that is, though? a1 22 A. No. 22 23 @. There's only one, two, three, four, five, six 23 24 people on that flight? 24 25 A. Ub-huh. 2s 78 2 Q_ That's pretty typical of the amount of x 2 passengers that you would have on a flight? 2 3 A. Itvaried, sure. 3 4 Q. Okay. But it varied between ~ if we look a 4 5 few lines down, Jeffrey Epstein and Ghislaine Maxwell) 5 6 were the only two passengers. Certainly there were 6 7 flights ike that as well, right? 7 8 A. Mm-hmm, 8 9 Q. And so it varied from having one or two people 2 10 to six or seven peaple, right? 10 qd A. Yes. il 12 Q. What's the most people that you remember 12 13 traveling on any of Jeffrey Epstein’s airpianes? pe 14 A. Twenty-five. 14 15 Q. Okay. That would be a rarity, wouidn't you 15 16 say? 16 17 A. Oh, yeah, 17 18 Q. Because I've looked through this log. | 18 12 haven't seen any place where there were 25, but there; 19 20 are lines that have maybe eight or nine peopie listed. | 20 21 A. Right 23 22 Q. Let's see. There's a fight from 22 23 © January 15th — sory, January 17th, January 20th and| 23 24 January 22nd of 2002 that all had Cindy Lopez. That 24 25 doesn't serve to refresh your recollection as to who 25 October 15, 2009 “79 that is, does it? A. No. Q. Okay. Do you know what the purpose of her being on the airplane flight aiong with Jeffrey Epstein, Ghislaine Maxweil and Sarah Kellen would be? A. No. Q. Okay. Do you know how it comes about that Cindy Lopez gets on that fight? How does she even know} there's a flight availabie? A. [don't know, Q. Allright. Well, let's go down io somebody that we may all know a little bit better, February oth, 2002, there's a flight that has Bill Clinton, four Secret Service agents and then instead of listing names oF initials or anything else, it's just listed as two males, one female, Jeffrey Epstein, Ghislaine Maxwell, ‘Sarah Kellen and | forget who Dave Rogers told me “AP™ is. Do you remember who that is? A, No. Q. Okay. Either way, how is It that someone like Bill Clinton gets on a Jeffrey Epstein flight? MR. CRITTON: Form. THE WITNESS: | don't know. BY MR. EDWARDS: Q. Do you know before the fight takes off that 80 Bill Clinton's going to be a passenger on the flight? A. Yes. Q. And how do you know? How do you get that information? A. The day before I'd get a phone cail from, say, Sarah saying we're leaving tomorrow going to wherever, and sometimes she'll say who's going, sometimes she won't. On a case where President Clinton wautd be on board, we would put a fittle extra catering on board or do that little extra TLC to the aircraft. Q.. Ifit's leaving ~ this says it's feaving from MIA and where is it landing? A, HPN | believe is White Plains. Q. Okay. Do you remember that flight? A. remember being on it. Q. Well, i mean, if you look through here, obviously you had Bill Clinton on the airpiane ten or twenty times, right? A. Yeah. He's my main focus. | remember him being on the aircraft, sure. Q. Bo you remember him being on the airplane with; younger girls? MR. CRITTON: Form. THE WITNESS: No. Larry Visoski October 15, 2009 8l 83 BY MR. EDWARDS: 1 this time with Doug Band, three Secret Service agents, Q. Okay. Do you know what his relationship was 2 Jeffrey Epstein, Ghislaine Maxwell and Sarah Kellen. Do with Jeffrey Epstein? 3 you remember that fight? A. No. 4 A. Where did we go? Q. Do you know if they were friends? 5 Q. Starts in JFK. A. Assuming. 6 A. Right. Q. Butyou're assuming why? Just because he's on 7 Q. Where is that? his plane? 8 MR. CRITTON: Do you have a date? A. Yeah. e MR. EDWARDS: March 49th, 2002. Q. Okay. So you assume that the people that are 10 THE WITNESS: EGGW | belleve is Luton, listed on here are friends of Jeffrey Epstein's and 11 ‘England. that's why they are riding on his plane? 12. BY MR. EDWARDS: A. I'm speculating. 13 Q. Okay. Do you remember fying to England? Q._ I'm just not familiar with the — because I've 14 A. {do remember flying to England. | just don’t never been on a private flight — with the manner in 15 remember that trip. What airplane were we in? We were which you go about getting on one of these flights. | 16 in the Boeing. mean, you have to, | guess, know that Jeffrey Epstein 7 Q. Do you remember the purpose of the trip? has 2 plane, thet it's going from 2 destination that you 13 A. No. are at and want to go to, and that it's available and ig Q, De you know who Doug Band is? those Kind of things. Can you teil me, enlighten me — 20 A. Sheard he's Clinton's, how would you say, A. Well, it's not publicly offered, no. It would 21 assistant. | mean, ve seen that in ihe newspaper, be no different than you jumping in your car and knowing, 22 — seen iton CNN. you're going to the mail. 1 mean, it's not public 23 Q. Okay. Did you ever hear that Doug Band and information, you know, where planes are comingtoand | 24 Ghislaine Maxwell were together, even for a day or 4 fram, and you don't put your name out there te get 25 __night? 82 84 onboard a flight. 1 A. No. Q. Does Jeffrey Epstein charge these people as 2 Q. Did you ever hear that Doug Band and Ghislaine passengers? 3 ‘Maxwell were the people attributed to introducing Bill A. | don't know. 4 — Clinton and Jeffrey Epstein? Q. Okay. Are these people such as Bill Clinton, 5 MR. CRITTON: Form. does that mean that Bill Clinton called Sarah Kellen or 6 THE WITNESS: 1 don't know. somebody affiliated with Jeffrey Epstein to get on the 7 BY MR. EDWARDS: plane or that Jeffrey Epstein called Bill Clinton and 8 Q. Allright. There's another flight here on asked do you want a ride? 9 January ~ | can't read this upside down. Maybe it says MR. CRITTON: Form; predicate. 10° May~ THE WITNESS: | have no idea. 11 A. Looks like. BY MR, EDWARDS: 12 Q, ~ 22nd, 2002, Again, with President Bill Q. No idea? 13 Clinton, Janice, Jessica. Can you teil me who Janice A. No idea whatsoever. 14 and Jessica are? Q. Joe Pagano, do you know who that is? 15 A. i don't remember. A. Yes, 16 Q. Would you know them if you saw them? Q. What's his relationship with Jeffrey Epstein, 17 A. Probably not because the names don't even ring or what was it back in February ~ sorry, March 17th of 18 abel. 2002, when he and Sarah Kellen and Jeffrey Epstein and} 19 Q. Allright. And then there are plenty of ‘Todd and one female were on this flight? 20 flights, many of flights where Jetfrey Epstein, A. {don't know to what extent or what his 21 Ghislaine Maxweil and Sarah Kellen are the primary relationship is. He Just was a passenger on the 22 passengers, or at least are some of the passengers on airplane. 23 the flights, correct? Q. Okay. And the next day -- sorry, two days 24 A, Mm-hmm, yes. Jater on the 19th of March, Bil Clinton flies again, 25 Q. And still, as you sit here, you being the Larry Visoski 85 1___ pilot of these flights, you're not sure what their 1 2 relationship is or whether any of them were socially 2 3 connected in any real way? 3 4 MR. CRITTON: Form. 4 5 THE WITNESS: No. When you're flying the 3 6 airplane, there's a lot more going on than 6 7 passengers’ relations. a 8 BY MR, EDWARDS: 8 9 Q. Allright. You remember this person, Virginia 9 10 Roberts, are you familiar with her at all? 16 ii A. remember the name, that's it un iz Q. What do you think her relationship is to 12 13 Jeffrey Epstein? 13 14 A. No idea. a4 is MR. CRITTON: What date are you on, Brad? is 16 MR. EDWARDS: Oh, sory. | am at June 21st, 16 17 2002. 17 18 BY MR. EDWARDS: 18 1g Q. That's not somebody that you specifically is 20 remember? 20 2h A Mm-mm, no. 22 22 Q. No? Is that somebody that you think was a 22 23 regular flyer for any period of time in Jeffrey 23 24 — Epstein's life? 24 25, A. Nota regular. 25 a 86 é 1 Q. Okay. Jean Luc Brunet. is that a name that 2 2 you know? 2 3 A. Yes. 3 4 Q. How do you know that name? 4 5 A. Only because It's 2 unique name and his attire 5 6 is very unique. So you remember certain things. So! 6 7 know he who that is. 1 8 Q. Do you know what he does? 8 9 A No. 9 10 Q. Do you know his association with Jeffrey 10 11 Epstein, if any? it 12 A. No, {don't know what the relationship is. 12 13 Q. Have you ever heard of him owning or running 13 14 ormanaging a modefing company? 14 15 A. | have seen that in the paper a few years 15 16 back. 16 v7 Q. Okay. Other than seeing it in the paper, have 17 18 — you ever talked fo Jean Luc Brunel or Jeffrey Epstein 18 19 about owning of running or managing a modeling company? } 19 20 A. No. 20 an Q. De you know if Jeffrey Epsteln's affiliated 21 22 with the modeling company that's owned, run or managed 22 23° by Jean Luc Brunet? 23 24 A. No, | have ne idea. 2a 28 Q. And sesing that this is a flight now, that 25 October 15, 2009 87 we're referring to the same flight on June 21st of 2002, that includes Jean Luc Brunel, Virginia Roberts, Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, those are the passengers of this flight, does that serve to jog your memory as to who Virginia Roberts is? A, No. i mean, you see how frequently we fly. 1 mesh, it's -- the passengers in the back are so far removed from an operation of commanding an airplane kd that, it's nothing that sticks in your head. Q, And you as the pilot, is there any way that you would know what's going on in the back of the airpiane? A. No. My concems are ait on the cockpit. MR, CRITTON: Brad, the last one that you mentioned, was that the same date, June 21st, 02? MR. EDWARDS: Yes. BY MR, EDWARDS: Q. There's another name here that | was going to ask you do you know. June 23rd, 2002, Jultana Barbosa, are you famitiar with that name? A. No. Q. Also on the same flight with Jean Luc Brunel. That doesn't help to jog your memory either, right? AL No. Q. That's somebody that you remember as 2 88 frequent passenger? A. Who are you referting to? Q. Juliana Barbesa? AL No. Q. Or. Jarecki, is that somebody that you remember flying? A. I know the name. He may have been on the airplane once or twice. I'm guessing only. Q. Do you remember meeting him? A, Yes, | have met him, Q. Do you remember his purpose for being on the airpiane? A. No, sir. Q. Amanda Venaro, do you remember her purpose for being on tke airplane? A. No. MR. REINHART: Can we get a date? MR. EDWARDS: | was asking him if he remembered Amanda Venaro, ? wasn't referring to 2 specific fight. BY MR. EDWARDS: Q. You don't remember her being on the fight? A. I don't remember the name. Q. Me showing you the flight isn't going to jog the memory? Larry Visoski October 15, 2009 CO BIMAHROYNE 89 A. No. The name that would launch it first -- MR. CRITTON; Could t ask you a question? You have the original exhibit marked at the deposition. It looks like it's been highlighted. MR. EDWARDS: | hightighted it MR. CRITTON: Oh, okay. So you've highlighted the original exhibit that's marked for the deposition? § just want the record to refiect that. MR. EDWARDS: Yeah. MR. CRITTON: Okay. Thank you. MR. EDWARDS: Ai the time | hightighted it didn't realize { was holding on to the original exhibit. | didn't reatize that until you just pointed that out. MR, CRITTON: I've noficed that. MR. EDWARDS: So now when | give it to you, {'m giving you my work product as well. i don't see how this works against you, but anyway. BY MR. EDWARDS: Q. Melissa Stall, is that a name that you remember? A. No. Q. Okay. And then Jean Luc Brunel is somebody who | noticed flew relatively frequently, so is that why 90 you — that name jogs your memory a little better than some of these other people? A. He dresses uniquely. Q. in what way? f A. Just loud clothes, so something that you would remember, that's all. Q. Do you know his role in Jeffrey's life? A. No. Q. Ever heard that he ia affiliated with Jeffrey Epstein because they both have a sexual attraction to underage giris? MR. CRITTON: Form. THE WITNESS: You're making an assumption on that. BY MR, EDWARDS: Q. Have you ever heard that? MR. REINHART: He's asked you if you ever heard that. BY MR. EDWARDS: Q. iFyour answer is no, it's no, A. I'm sorry, | thought you said they did, No, | have not. Q. Okay. [keep hightighting this name, Virginia Roberts, just because it looks like somebody that's reguiarly flying on the alrpiane. But the more that you 1 2 3 4 5 6 7 8 S 16 1L 12 13 14 15 16 i7 18 19 20 21 22 23 24 25 L 2 3 4 5 6 7 8 9 10 ii 12 13 14 is 16 17 18 19 20 aL 22 23 24 25 91 see her name, that doesn't change your opinion as to whether or not you remember her or what ~ A. remember the name, you know, that's all. Q. Do you remember about what age she was when} she was flying on the airplane? A. No. Q. This could be somebody who is 50 years old or ten years old, for ail you know? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. Okay. A. I mean, | would only be guessing at an age. Q. Yeah, but | mean, you don’t remember her at all. So you don't-- A. Eremember the name, exactly. Q. Other than the name? A, Right, yes, sir. Q. But you can’t even come ciose to putting a face with that name? A, fmean, no. i mean, if you said draw her picture with - { couldn't come close to even getting it. Q. Okay. You remember this fight where President Clinton, Kevin Spacey and Chris Tucker, 92 Jeffrey Epstein, Ghislaine Maxwell? Yes. . From JFK to what is this, LPAZ? LPAZ, that is — South Africa or something? No, it's the Azores Islands, Santa Maria. |. Do you know the purpose of that trip? That was a fuel stop. Okay. And do you know why Chris Tucker and Kevin Spacey were on that airplane? A, No. Q. Did you talk to them? A. They came up in the cockpit and said helio. So they conversed, nothing more. Q. Another name that is on here a few times, I'm specifically referring right now to the dates of September 23rd and 24th of 2002, is Ron Burkle. Do yo know who that is, Ron Burkle? A. {know what that is, yes. | didn't realize he was on our airplane. Q. Right now that is the first time that you remember Ron Burkle being on your airplane? A. Yeah. @. You don't know the purpose for him being on that airplane? propre ro, Larry Visoski COI AHSWHH 1 42 13 14 15 16 17 18 19 20 Qn 22 23 24 25 October 15, 2009 93 95 A. No. Granted, I'm seeing this for the first 2 BY MR. EDWARDS: time, so 'm trying to ~ 2 Q. Okay. You don't remember which flights it Q. Let me ask you that. Because this was given 3 would have been where there would have been girls under to me at a deposition of Dave Ragers, who | understand 4 ~~ the age of 187 was the chief pilot for Mr. Epstein, and now you're the 5 MR. CRITTON: Form. cheap pilot, but you always Kind of worked in tandem, 6 THE WITNESS: Weil, | would have to look at correct? 7 the fight logs. A. Sure; we complemented each other. 8 BY MR. EDWARDS: Q. And you both worked for the same company that 9 Q. It's not illegal to have somebody under the flies Jeffrey Epstein's airpianes, right? 10 age of 18 on a flight anyway, right? A. Yes. qi A. No, not at al. Q. Sol was of the presumption, which may have 12 Q. Were you ever aware that you, as pilot, were been — | may have been misled here, orl may have, you | 13 transporting giris under the age of 18 who were supposed knew, misunderstood the purpose behind this book ar h 14 tobe models? itwas created. f thought that you had probably seen 15 MR. CRITTON: Form. this before at some polnt in time? 16 THE WITNESS: | had no knowledge. A. Gh, no. 17 BY MR. EDWARDS: Q. Did you know that Dave Rogers was keeping this | 18 Q. Okay. You never knew who the peopie on the book? 19 —_alrplane were, what their purpose was, their role with A. No. iknow he keeps a pilot log book. 20 Jeffrey Epstein or Jean Luc Brunel? Q. Okay. But you didn't know he was keeping the 2i A, No. names of the people who were on the airplane? 22 Q. Alfright, Do you know Jutietle Bryant? A. No, It’s not required, so | mean, it's... 23 A. No, | don't remember that name. Q. So today is the first time that you are 24 Q. Andrea Metrovich? fearming that the names of the people that are on the 2s A. [remember the name. 94 96 airplane was kept by Dave Rogers? 1 Q. She flew frequently at least for a period of A. Yes, in his log book. 2 time. Do you remember that? Q. Okay. And it's my understanding when you fly 3 AL Yes. back into the country through Customs, you have to 4 Q. Is that somebody that you thought was farniliar report the people that are on the airplane, right? 5 — with the modeling industry or related to the modeling A. Yes. ° 6 industry? Q, And who would create that document or call 7 A. No. that information into Customs? 8 Q. Okay. And these people, did Jeffrey Epstein A. Whoever the captain was for the day. 9 ever tell you how he was associated with any of them? Q. Attimes would that be you? 10 A. No. A. Yes. 11 Q. Did you ever wonder how he was associated with Q. Okay, And at times when you would come into} 12 any of them? the country with passengers -- well, not at times. 13 A. No, never interested. Didn't you also have to report their date of birth? 4 Q. And on several of these - on most of these, A. Sure. 15 the names or initials of the people that are on the Q, At times weren't there also people that you 16 flight are listed. Do you know on the occasions where would bring in from other countries into the United 17 it lists generically twe females or three femates or six States that were under the age of 187 18 — fernales, do you know why that was done? A. Yes. 19 A. dust because we didn’t know our ~- the Q. And atsome times those were flights that 20 person's name. We tried to do the best we could to keep| included Jean Lue Brunel and girls that were under the) 21 the records, age of 18, right? 22 Q. When you say “we tried to do the best that we MR. GRITTON: Form. 23 could" ~ THE WITNESS: 1 don't remember those flights.; 24 A. Dave and |. 25 Q. Okay. But the first time that you feamed Larry Visoski 1 2 3 4 5 6 7 8 9 16 ai 12 13 14 15 16 i? 18 19 20 22 22 23 24 25 WOIH RW 10 12 13 14 15 16 17 18 19 20 aL 22 23 24 25 97 that he kept anybody's names was today, right? A. Well, 1 didn't know he kept them in his log book. We would fili out the passenger manifest as we're ~ having passengers’ names in your pilot tog book, he’s probably the only parson in the world that does that. Q. Okay. A. So when you were mentioning putting the names down, when you said female or male, you know, | was seferring to the passenger manifest. Q. For each of these same flights, then, that we're referring to out of this log book that was marked as Composite Exhibit 1 in Dave Rogers’ deposition, am 1 understanding you correctly, then, there would also be a passenger manifest for each of these flights? A. Yes, Q. Now, where would [ find the passenger manifest? Who keeps that documentation? Corporate — our corporate office. Which is whom? Up in New York, Darren indyke. At what corporation is that, though? NES, LLC, I guess. MR. REINHART: Do you know for sure? THE WITNESS: ! don't know for sure. | mean, 98 POPROP when you say — we would just send them up to New York. BY MR. EDWARDS: Q. Did you ever keep a copy of them? A. No. Q. Why did you keep a passenger manifest? A. Just for tracking of — to have the times on there for -~ MR. REINHART: Can | confer with him on one thing before you ask a question? MR. EDWARDS: Yeah, yeah. (Off the record discussion.) MR. REINHART: Mr. Edwards, let him amend his prior answer. | think he misunderstood the question. MR. EDWARDS: | don't know what question we're, amounting the answer to, MR. REINHART: Let me clarify this way: As. the passenger manifests, they are corporate documents of either JEGE or Hyperion Air, whatever company owns the plane. Mr. Visoski has physical custody of them. He retains them but they're not his dacumants. They're the corporate documents. So they're not in New York. THE WITNESS: Those are the ones that i have October 15, 2009 39 1 at the airport office that | had tumed into 2 counsel that has the passenger names on them. 3 BYMR. EDWARDS: 4 Q. Okay. 5 A. it's called a passenger manifest. 6 Q, Okay. 7 MR, REINHART: Right. 8 BYMR. EDWARDS: 9 Q, The passenger manifest, just so | understand 10 exactly what that is, tell me. Tell me in your own 11 words. 12 A, Its departure time, the city, the landing 13 time exactly and the passengers that would have been on 14 that flight, 15 Q. And at times on that passenger manifest would 16 — you list also generically female or male? 17 A. Yes. That was the document | was referring to 18 stafing that if we didn't know a parson, we did not go 19° out of cur way to find out a name. We just put in to 20 account for how many people were on the aircraft at that as time. 22 Q. Who is currently in the custody or controt ~ 23. sorry. Who currently maintains or has possession of the 24 passenger manifest from 1998 through the present, 25 through today for those airplanes that you flew related 100 1 to Jeffrey Epstein? 2 A. (currently have, which counsel has now, 2005, 3 Ebelieve, until the present time. And the records 4 previous to that | believe were turned into counsel with 5 the previous investigation with Jack Goldberger's 6 office, | believe. | believe they maintain those 7 records. 8 Q. When you say "turned into counsel," there are 9 alot of counsel invoived here. 10 A. Jack Goldberger's office, | believe. 11 Q. When you say “the previous investigation,” 12 you're talking about the criminal investigation? 13 A. Exactly, yes, sir. 14 Q. And you're aware in that criminal 15 investigation, obviously, that Jeffrey Epstein pied 16 — gulity to certain charges, correct? 17 A. From what | read, yes. 18 Q. Well, you did visit him in jail, right? 19 A. Yes. We didn't tak about that. 20 QQ. Okay. You know in order to go to fait, 21 — though, you have to be convicted of some crime, right? 22 MR. CRITTON: Form; argumentative. 23 THE WITNESS: Yes. 24 BY MR. EDWARDS: 2s Q. Itwasn't like he was visiting the jail and Larry Visoski 24 101 you were visiting and you happened to bump into each other. You actually went to see him while he was an inmate in jait? A, Right, yes. Q. Okay. So when we're talking about the criminat investigation, we're talking about the criminal investigation revolving around the allegations of Jeffrey Epstein engaging in sex acts with minors? MR, CRITTON: Form. BY MR. EDWARDS: Q. That's the criminal investigation you're talking about, right? MR. CRITTON: Form. THE WITNESS: 1 don’t know the fuil definition of really what happened there. 1 know that it was something to de with solicitation of prostitution. That's all i read. BY MR, EDWARDS: Q. Okay. Were you aware that the allegations tevolved around underage girts or girls under the age of 187 MR. CRITTON: Form. THE WITNESS: | was aware it revolved around it, yes. 102 BY MR. EDWARDS: Q. Who first made you aware of that? A. The newspaper. Q. Were you ever questioned by the police? A. {don't know who questioned me, actuaily. | did have a questioning session, but | don't even temember who questioned me. Q. Where did that take place? A. I don't remember. Q. Atyour house? A. No. I'm thinking it was Jack Goldberger's Office, or it may have been downtown at the Palm Beach: County Courthouse or something in that area there. Q. Okay. So it either happened at an attorney's office that represented — A. Exactly, yeah, | think so. Q. -- Jeffrey Epstein or the other side? A. Yeah. Q. And during that questioning, is that when you turned over the passenger manifest from prior to 2005? A. Yes. Q. And you turned those manifests directly over to Jack Geidberger? A. Yes. Actually, | believe Dave Rogers did that. I wasn't in possession of those records we oOIHMHHRUNne SIA RYNE October 15, 2009 303 Q. And for the passenger manifest prior to 2005, how far do those passenger manifests go back in time? A. They should go back, | guess, to 1991 or whenever we started existence. Q. And did you tum them over from 1991 ail the way through to 20057 A. idon't know. | didn't tum them in. Dave Rogers did. Q. Are you in possession of a copy of any of those materials? A. No. Q. | thought that, you know, ten minutes ago when we were talking about this you said you had them back at an office or —~ A. That was the office, the airpiane office, which Fve given to Bruce, which is the current log. He ig in possession of them now. | had possession of them. Q. Okay. What he's in possession of - just so know what documents are where, he's in possession of ihe: passenger manifests from 2005 through the present? A. Correct. Q. If want to obtain the passenger manifests from 1998 through 2008, that's something that | would request from whom? THE WITNESS: Help me out. That's -- 104 MR. REINHART: If you know. THE WITNESS: | don't know who possesses them right now. They were tumed into Jack Goldberger’s office a year and a half or two years ago. BY MR. EDWARDS: Q. You started out by indicating that you sent these passenger manifests, or a copy thereof, to Darren Indyke or someone at NES, LLC; is that correct? A. Correct. Q. iff requested them from NES, LLC, that's somebody at some point in time was in possession of ail the passenger manifests? A. Sure. Q. And NES, LLC's address is the one you gave me at 301 East 66th Street? A, [believe so, | don't know what address they're using for that. | know that — Q, But Darren indyke's the atfomey that ! would cali -—- A Yes, sir. Q. --and he could probably steer me in the right direction? A. Yes. MR. CRITTON: Form. Larry Visoski WOWARe wre 10 12 i3 14 is 16 7 16 19 20 21 22 23 28 25 October 15, 2009 105 107 BY MR. EDWARDS: 1 hello, Q. Do you know Amy Taylor? 2 Q. That's somebody who was on the airplane A. Yes, 3 multiple times? Q. How do you know her? 4 A. More than once. | mean, | have no account for A. She was on the airplane. Show many times. Q. How old is she? 6 Q. Well, I've asked you about a bunch of names, A. | have no idea. 7 most of which you don't really remember, but that's one Q. Age range? 8 name you do remember. A. Twenty-eight. 9 A. Yeah, | remember the name, yeah. Q. Now? 10 Q. Okay. And that’s somebody who you actually — A. Yeah, 28, or maybe if not older now. She was 11 -you would remember the face too? probably 28 probably, | guess. She was somebody in her| 12 A. I might remember Amy's face. late 208. 13 Q. Alfright. Do you remember why she would have Q. So we're tatking about 2003? That's what i'm 14 averbeen on your airplane? trying fo understand. is A. No idea. A. im guessing. 16 Q. President Andres Postrana, at the time | guess Q. We're talking 2009 new. We're saying 28. By 17 that was the president of Colombia back in February —~ that do you mean in 2003 she was 23 or 24 years old? 18 sorry, March 20th of 2003. Do you know who that is? A. You're having me guess on her age. is A. | don't remember him being on the airplane, Q. Yeah. 20 but | know who that is. A. \megan, | can't be accurate. 21 Q. Okay. He's on the airplane with Jeffrey Q. Somebody between 18 and 257 22 Epstein, Ghislaine Maxwell, Sarah Kellen and Jean Luc MR. CRITTON: Form. 23° Brunel? BY MR. EDWARDS: 24 A. Where did we go? Q. At the time you were seeing her back in — 25 Q. Milat you look at it. I'm talking about oon meee 106 108 A. Ifyou want me to guess — ‘1 this fine, PBI, left out of Palm Beach? Q. No, | don't want you to guess. 2 A. Paim Beach to Nassau. I'm sorry, | don't A. I don't know then. 3 remember that one. Q. Well, if | say between ten and fifty? 4 Q. When we're saying we're going down to Nassau, A. That's a range. 5 ig that a place that you frequently went to with the Q. If say between ten and fifty, you're not 6 airplane? guessing there anymore. You know she's in there, right? 7 A. No, not at all. A. She's in the middle there, yeah. 8 Q. And is that a route that you would take for Q. Okay. How can we narrow that down? We're 9 the ultimate destination to be Little St. James? taiking about somebody in her 208? 10 A. No. A. Inher 20s. 12 Q. Ifthe ultimate destination was Little Q. Atleast that's what you believed? 12 St. James ~ show me a flight where the ultimate A. Yes. 13 destination was Litile St. James. @. Altright. fs that somebody that you know to 4 A. Yeah, right here. TiST, that’s St. Thomas. be associated or friendly with Ghislaine Maxwell? is Q. Okay. So on that flight that you just pointed A. [don't know. 16 to, March 27th, 2003, we have Jeffrey Epstein, Sarah Q. Do you know what her relationship was to 17 Kellen, Cindy Lopez again, Brent Tyndall -- do you know; Jeffrey Epstein or Ghistaine Maxwell? 18 — who Brent Tyndall is? A. No. 19 A. Yes. Q. Doyou know where she is now? 20 Q. And who is that? A. No Idea. 22 A. lbetieve he was the chef. Q. When's the last time you talked to her? 22 Q. And Magale Blanchen (phonetic), is that A. idon't know, What date do you have on there? 23 somebody you know to be a made these days? Q. February 2003. 24 A, | have no idea, A. So, probably that long ago. | may have said 25 Q._ Do you remember that flight? Larry Visoski Lenten 109 L A. No. a 2 Q. Do you remember Naomi:Campbell, picking her upp 2 3 from St. Thomas along with Jean Luc Brunel? 3 4 A. | remember her being on board, | don't 4 5 remember the flight. 5 6 Q. Do you know Joel Pashicow? 6 7 A. Yes. z 8 Q. How do you know him? 8 9 A, He was on the airplane. 9 10 Q. And is that somebody you knew at one point in 10 11 time to be a friend of Jeffrey Epstein's? a2 12 A. He was on the airpiane. I don’t know what the 12 13 telationship was. 13 14 Q. Do you know what the relationship is today? 44 15 A. No idea. 4s 16 Q. How about Todd Mister, de you know what that 16 17 felationship is or was today? 17 18 A. No. 18 19 Q. Do you remember him? 19 20 A. No. 20 2a Q. Not at ail? 21 22 A. Imean, | know the name. | den't know. 22 23 Q. Paula Epstein, do you knew whe that is? 23 24 A. Yes. 24 25 Q. Who is that? 28 110 1 A. That's Jeffrey's mom. 1 2 Q. She's passed away? 2 3 A. Yes. 3 4 Q. Atleast that's your understanding, right? 4 5 A. That's what 1 heard, yes, 5 6 Q. Okay. Tila Davies, do you know her? 6 7 A. Tila Davies, | know the name. 7 8 Q. Somebody who flew an the airplane with some 8 9 regularity? 9 10 A. Yes. 10 LL Q. And do you know her to be friends of Ghislaine} 11 12 Maxwell or Nadia Marcinkova or Jeffrey Epstein? 12 13 MR, CRITTON: Form, 13 14 THE WITNESS; F have no idea who she was 14 15 friends with. 18 16 BY MR. EDWARDS: 16 17 Q. Allright. Do you know what role she ever l7 18 played, if she piayed one, in Jeffrey Epstein's life? 18 19 A. No. 19 20 Q. Allright. Glenn Dubin, are you familiar with 20 21 him? 21 22 A. Yes, 22 23 @. How do you know Gienn Dubin? 23 24 A. I met him on the airplane. 24 25 Q. Outside of the airplane, have you ever seen 25 October 15, 2009 121 him around Jeffrey Epstein? A. No. Q. Allright, A. No. Q, Alina Webber, do you know that name? A. No. Q. She was on several flights. You don’t remember seeing her? A. No. Q. Alldight. And how about Alan Dershowitz, I'm ‘sure you know who that is? A, Sure. He's famous. Q. What was your understanding of Alan Dershowitz's relationship with Jeffrey Epstein? A. Never talked about it Q. Forrest Sawyer, do you know why he was on your| airplane? Never heard the name, actually. Really? No. Larry Summers? Lknow the name. I don't remember flying him. Have you ever talked to Joe Fontaneta? Yes. How do you know him? 112 A. He usually drops Jeffrey off at the airport. Q. In fact, you've called him directly before, PP OPOrp> A. Yes. Q. You still have his number? A. Vhaven't - yes, | think | still got it in my memory. Q. Okay. What is it? A. It's been a few years. (917)945-7500. It's kind of an easy one. MR. CRITTON: 917 is the first — THE WITNESS: Yes. MR. CRITTON: Who was this for? MR. REINHART; Joe, Joe Fontanela, MR. EDWARDS: Fontanela. BY MR. EDWARDS: Q. Do you know his address, where he resides? A. No, don't Q. Bo you know if he -- what his role is in Jeffrey Epstein's life? A. Not really. He just — he drove the car. Q. He drove what car? A. The car up in New York. Q. Okay. Do you know if he's a housekeeper up at that house up in New York? Larry Visoski October 15, 2009 113 115 1 A. | don't know what his role is. 1 Q. Do you know -- did you teil me, do you know 2 Q. Have you ever worked for a company called aie 2 what Lestie Gruff does for Jeffrey Epstein? 3. Ghislaine? Do you know that company? 4 A. idon't know her exact title. 4 A Yes. 4 Q. You talked to all of these individuals at some 5 Q. Do you know what that cornpany does? 5 point in time, either on the phone or in person, right? 6 A No. 6 A. Yes. 7 Q. Have you ever been an employee of that 7 Q, And you don't know whether they play a role in 8 company? 8 Jeffrey Epstein's life, or if they do, what they do? 9 A. No. 8 A, Exactly. 10 Q. Do you know who runs that company? 10 Q, And how do you decide who you're going to cali iL A. No, 11 for what reason? 12 Q. Is Jeffrey Epstein associated with that 12 A. Forexample? Can you be more specific? 13. company? 13 Q. Ifyou're going to make a telephone cail and 14 A. | don't know. 14 you're going fo taik to let's say Leslie Gruff, why a5 Q. How have you heard of that company? 15 woukt you choose to calf her? 16 A. It's the company name that our registration 16 A. [don't know. You're having me make the phone 17 for the helicopters is under, Air Ghislaine. 17 afi. 1 don't know why | would caii her. 18 Q._\s that somebody who's ever paid you, & 18 Q. Have you ever called her? 19 company who's ever paid you? a9 A. Ethink, yes, I've called her, sure. 20 A. No, 20 Q. Why? What would be the reason that you would 24 Q. Do you know Igor Zinoviev? 21 cali her? Somebody toid you te calf her? Here, calt 22 A. Yes. 22 this number? 23 Q. How do you know him? 23 A. Smay have called her maybe to find out if we 24 A. Met him on the airplane. 24 had a departure time for any specific trip. | mean, 25 Q. What is your understanding of his affiliation 25 that would be... 114 116 1 with Jeffrey Epstein? 2% Q. Okay. So you're calling her related to 2 A. Idon’tknow. He doesn't talk much. 2 — Jeffrey Epstein? 3 Q. Okay. And Sandy Berger, do you know who that 3 A. Sure. 4 is? 4 Q. Okay. So you know that she plays some role in 5 A. [don't know. 5 some aspect of Jeffrey Epstein's life, whatever that is? 6 Q. Do you know any reason why you would have: 6 A. Right. 7 flown him on the airplane? an Q. Okay. So when I'm asking these questions a A. [don't even know the name, 8 about these people, and | feel like I'm getting answers 9 Q. Adrianna Muchinska? 9 that 'm not really not sure that these people have any 10 A. | know the name Adrianna. 10 role in their fife, that's not — that's not completely 12 Q. Somebody who fiew on the plane pretty 11 accurate, right? 12 regularly? 12 MR. CRITTON: Form; argumentative. 13 A. [would have to look at the fogs. | think 13. BY MR. EDWARDS: 14 ~~ we've had that name on several - it's a common first 14 Q. mean, you do know that these people are 15 name. I'm net famitiar really on who that is. 18 — semehow invoived with him, whether socially or 16 Q. What about Bella, do you know who Bella is? 16 —_ business-wise or otherwise, and during the course of 17 Is that a name you ever heard? 17 your years, you've made telephone caiis on his behalf or} 18 A. Yes. 18 to coordinate things with them right? 19 Q. Works up in the New York office or something? 19 A. Right. 20 A. Yes. 20 MR. CRITTON: Object to the form. You said 22 Q. Have you ever spoken with Bella personally? 21 “these peopie." 22 A. Yes. 22 BY MR. EDWARDS: 23 Q. Do you know what she does for Jeffrey Epstein, 23 Q. I'm talking about Sarah Kellen. That's 24 ~~ if anything? 24 — somebody you called before, right? 25 A. | don't know exactly what her role is. 2s A. Sure. Larry Visoski October 15, 2009 117 Q. What would be a reason you called Sarah Kellen? MR. CRITTON: Object to form. Probably the same reasons he said two hours ago, for scheduling; purposes, But you've covered that. Go ahead and answer it again. THE WITNESS: For scheduling purposes, woul be my only reason to call her. BY MR. EDWARDS: Q. That's funny that you used the exact same words that Mr. Critton wants you to use. MR. CRITTON: it's what he said two hours ago. BY MR. EDWARDS: Q. What would be the reason why you would cali Ms. Maxwell, Ghislaine Maxwell? A. Same reason. Q. That's not somebody you call these days, though, right? A. Ehaven't seen her in some time, Q. What made you stop calling Ghislaine Maxwell where you thought at one point in time you thought she was 2 person te call related to your job? A. Just was no reason to. Q. ts that somebody who you think is stil affiliated or associated with Jeffrey Epstein or his —" 118 whatever he does? A. 1'd only can speculating. | don't know. Q. Allright. De you know the number (917)868-6145? MR. CRITTON: Could you say it slowly. 9177 MR. EDWARDS: 868-6145. Thank you. And just in case you didn't get it, I'm going to mark these as an exhibit so that we can read thern later. BY MR. EDWARDS: Q. Do you know that number? A. Yes. Q. What ts that number? A. That's my cell phone. Q. Okay. Is that stil your cell phone? A. Yes, sir. Q. Allright. i'm going to show you two documents here or pieces of paper. We'll mark them as Exhibit 2 and Exhibit 3, The first one is dated March Sth, 2005. Deo you remember making this telephone call? And just for the record, this looks like 2 message that's being taken relative to a phone call that you made. MR. REINHART: Se the question is does he remember making tha phone call? OCAIHAeweNe 10 i 12 13 14 15 16 17 18 19 20 21 22 23 24 119 BY MR. EDWARDS: Q. Do you remember making that phone call after reading the message? A. Let me jook at the date here. Okay. March. MR. REINHART: The question is, do you remember making the call? THE WITNESS; Okay, let me. “Person for the car will be here in 15 minutes fo drop off foam and papers.” | don't know. BY MR. EDWARDS: Q. That doesn’t mean anything to you? A. That doesn't — { mean, you're talking four years ago. | can't answer that accurately. 1 mean... MR. REINHART: So the answer is you don't recall? THE WITNESS: Yeah, i don't recall. BY MR. EDWARDS: Q. ifyou don't remember, that’s fine. (Plaintiff's Exhibit Nos. 2 AND 3 were marked for identification.) BY MR. EDWARDS: Q. So I" show you Exhibit 3, the same type of document, and | can make the representation that this was message pads provided by the state attorney's office) relative to the criminal investigation revolving around 120 Jeffrey Epstein. So that's how | have these documents. t'm not trying to pull out old documents. MR. CRITTON: What's the date? MR. EDWARDS: March 19th. MR. REINHART: The question is, do you remember the call? ‘THE WITNESS: "Tom from Midnight Express is at” — help me out -- “convention center with new boat. They are two points ~- two parts of this." BY MR. EDWARDS: Q. “Show? A. “Show up the water" -- MR. REINHART: “On the water.” THE WITNESS: "On the water and at the center.” BY MR. EDWARDS: Q. Do you remember making that call? A. No. | mean, “Tom from Midnight Express is at convention center with sew boat. They are two parts of" -- | mean -- Q. Butas Jeffrey Epstein's pilot, why would you be feaving such a message about Tom from Midnight Express relative to boats and a boat show? A. |help out with boat purchases or, you know, anything te do with, you know, that moves. So! mean, Larry Visoski October 15, 2009 122 123 1 1 Q. And has he consulted with you on each of those 2 Q. Okay. When you say "you help out with boat 2 ~~ purchases? 3 purchases," what do you mean? 3 A. Not avery one of them, no. 4 A. Give my opinion, whether or not whether to buy 4 Q. Does he own any boats now that you're aware 5 acertain boat. It's just a hobby. | have knowledge on 5 of? 6 — boats. Not only just airplanes but, you know. 6 A. | don't know if he owns them or not. 7 Q. You give your opinion to whom? 7 Q. Okay. Do you know of any boats that he 8 A. To Jeffrey. & — controls or maintains? 9 Q. Okay. And Jeffrey Epstein obviously, at least 9 A. Himself or? 10 in your mind, you believe he wants your opinion? 10 Q. How about this — I'l ask you this way. 1 al A. Yes. 11 don't want to spiit hairs with you here: | know we've 12 Q. Okay. So boats is another thing that the two 12 been talking about corporations and things tike that. 13 of you have discussed? 13 A. Yes he. 4 A. Yes. 44 Q. Do you know of any boats that he is the person a5 Q. Allright. And so this a conversation or at 15 with the most controt over? 16 least some evidence that a conversation existed between} 16 A. Yes. 17 yourself and Jeffrey Epstein relative to a boat or a 17 Q. Okay. Where would those boats be located and 18 — boat show? 18 — what kind of boat are we talking about? 19 A. Correct. 19 A. St. Thomas is the location. Itwould be a 20 Q. Do you remember having that conversation? 20 34-foot inflatable boat. | know that one specifically. au A. We've had many conversations about boats and | 21 Q. Okay. Do you know when he made that purchase?| 22 different boat shows, If you're referring to this one 22 A. Bight years ago, seven years ago. itwas a 23 in 05, don't recall this one. 23 while ago. 24 Q. Okay. So aside from being a pilot ~ which 24 Q._ is that something you had had input in? 25 throughout this entire deposition | believe your 25 A. Not on that one specifically, no. i 122 124 1 testimony has been, you know, you're just the pilot for i Q. Is there any other boat that you know of 2 him ~ it looks like there's some other role that youre: 2. Jeffrey Epstein being the primary user of or the primary 3 playing here in his life. i'm not suggesting that you 3 controller of? 4 are or you are not. !'m just saying from the appearance! 4 A. | mean, there's boats in St. Thomas. | mean, 5 of this, it looks that way. 1s there anything else that 5 it's not part of my job, you know, what goes on with the 6 — you want to tell me or that you want to clarify in terms 6 boats or who controlled them. It's more of an opinion 7 of the role that you play in Jeffrey Epstein's life ‘7 ~~ of what horsepower should be on the back of the boat, 8 outside of being just his pilot? 8 — huli designs. it's out of my area. 9 MR. REINHART: Let me object to form. He also 9 Q. Sut your sole responsibility or your sole 10 told you he instails the audio and video equipment 10 obligation that you have ever had with Jeffrey Epstein 1 before. 11 relative to boats is just giving some opinions about the 12 MR. EDWARDS: Correct. 12 boat? 43 THE WITNESS: | have an interest in boats. 13 A, Mm-hmm. 14 You know, with the island, t don't think | bought 14 Q. Is that yes? a5: any boats, you know, for the company, but he 1s A. Yes, yes. 16 appreciates my opinion on boat purchases. 16 Q. Okay. All right. Has he ever given you his 17. BY MR, EDWARDS: 17 opinions about boats? 18 Q. Okay. 18 A. Sure. We've discussed it back and forth, a9 A, Having the knowledge of aviation and things 19 Q. Other than boat conversations, have you ever 20 that move quite fast. So 1 have consulted with him on 20 talked other conversations, such as ~ 21 boat items. 2h A. Cars. 22 Q. How many boat purchases are you aware of 22 Q. Okay. How about such as ~ have you ever 23. Jeffrey Epstein making in the time period that you've 23 known Jeffrey Epstein to have a girlfriend, somebody you 24 — known him? 24 consider a gittfriend? 25 A. Two or three. 25 A, No. Larry Visoski October 15, 2009 warner wone 125 127 Q. In the 18 years and ail the travels you had 1 Q. Did he ever fly anywhere else with you either with hirn, do you know anything about Jeffrey Epstein's; 2 by helicopter or airplane in the last two years? sex life? 2 A. We flew one time to the Sikorsky plant. A No. 4 Q. What's the Sikorsky plant? Q. Do you know who he has sex with? 5 A. That's where they build the Sikorsky A. No. 6 helicopters. It's in Palm Beach County, Q@. Do you know if he has sex with anybody? 7 Q. And when was that? A, | don't know. 8 A. Probably a month ago, I'm guessing. Q, Do you know if he's ever had sex on the 9 Q. For what purpose? airplane while you've been piloting it? 10 A. They gave us a tour at a facility. A. (have no idea. il Q. Who's they? Q. That's something that you just wouldn't know: 12 A. Sikorsky. because you're up In the cockpit? 13 Q. And who requested the tour of the facility? A, Thatis correct. 14 A. They offered it to our flight department. THE WITNESS: Couid | take a tvo-minute 15 Q. And who went? bathroom break just to tose my coffee? 16 A. Jeffrey, myself, Nadia and Igor. MR. EDWARDS: Sure. Vv Q. And if | wanted documentation of either of (A break was had at 12:36 p.m.) 18 those trips, the trip to Miami or the trip te the BY MR, EDWARDS: 19 Sikorsky plant, who would have that documentation? Q. Allright. We're back on the record. Over 20 A. Iwould. i the years you've indicated that the ~ any gifts or 21 Q. Sol could request it from your attorney to other items or things given to you by Jeffrey Epstein 22 getit from you? exclusively are the poot heater, the 40-acres of land 23 MR. REINHART: Let me just check. and the -- 24 {Off the record discussion.) A. Use of a company — 25 MR. REINHART: Okay. He has custody of it, 126 128 Q. ~and the use of a company car? a but they're corporate documents. So you'd have to A. Yes. 2 request it from Mr. Critton, who | understand Q. That's it? 3 represents all the corporations. A. {Nodding.) 4 THE WITNESS: Yes. Q. Okay. 5 BY MR. EDWARDS: 7 A. Yes, I'm sorry, yes. 6 Q. What's the corporation that the document was Q. And the flight to Miami that was recently 7 prepared for? taken, other than Jeffrey Epstein and Nadia Marcinkova, 8 A. Meaning who -- what, like Air Ghislaine, the was there anybody else on that flight? 9 owner of the helicopter? Yes, Air Ghislaine. A. No, 10 Q. Air Ghisiaine? Q. How long -- did you also fly them back from il A. That's the helicopter. Miami to Palm Beach? 12 Q. And the name Ghislaine is obviously not that A. No. He drove back. 13 typical of a name. Is that reference or related to Q. When you say “he drove back," who drove back?} 14 Ghislaine Maxwell? A. Weil, |assume he drove back. | did not fly 15 A. |would assume, 1 have no knowledge. him back. 16 @. Nobody's ever told you that? Q. When's the next time you saw him again? 17 A. Nobody's brought it up. A. twould only be guessing. A week tater, 1 18 Q. Okay. And how long were you at the Sikorsky mean. 19 facility? Q. Okay. And was that in Palm Beach County whenj 26 A. Three hours, four hours. you saw him the next time? 21 Q. And what time of day was this? A. Yes, sir. 22 A. Nine in the moming. Nine, t think, and we Q. De you know of him leaving Palm Beach County 23 returned at one, something like that. in the last two years on any other occasion? 24 Q. And was the purpose to buy or purchase A. No. 25 anything? Larry Visoski October 15, 2009 129 131 1 A. They have a new helicopter being developed 1 Q. Back in his office? 2 there, so they're trying to look for investors in it. 2 A. Yes, sir. 3 So they were just kind of pushing their product. 3 Q. What was that conversation? 4 Q. Do you know what Jeffrey Epstein does for a 4 A. Give me a time frame. i mean, I've been there 5 __ living for business today, these days? 5 several times. 6 A. No. 6 Q. Okay. How many fimes do you think you've been} 7 Q. Do you know ar have you ever been to the 7 tothe Florida Science Foundation? 8 Florida Science Foundation? 8 A. Twenty, thirty. | mean... 9 A. Yes, sir. 9 Q. Weil, the Florida Science Foundation's only 10 Q. And do you know what the Florida Science 10 been around since late 2007; is that right? 11 Foundation does? 11 MR. CRITTON: Form. 12 A. Not exactly. 12 BY MR. EDWARDS: i3 Q. Weill, generally? 13 Q. Something around that? 14 A. No, i don't. [ mean, really, i don’t, 14 A. idon't know exactly. 15 Q. Okay. fs it your understanding that Jeffrey is Q. Altright. So in the last 20 years ~ in the 16 — Epstein is somehow affiliated with the Florida Science} 16 — last couple of years you've been there 20 or 30 times, 17 Foundation? 17 approximately? 18 A. its my understanding that, yes. 18 A. Yes, sir. 19 Q. I mean, did you just by happenstance stumbie 13 Q. And during those times when you've been there, 20 _ into the Florida Science Foundation, or was it related 26 without having to go through each conversation, did you 21 to your relationship with Jeffrey Epstein? 21 ever talk to him about the fact that he was on probation 22 A. f've heard that's where his office was. | 22 orthat he was ~ 23° mean, { have no other -- 23 A, No. 24 Q. Why did you go there? 24 Q. any part of the criminal investigation? 25 A. Talk about airplanes. deli 25 A. No, not at all. 130 132 1 Q. Talk to who? 1 Q. What was the purpose of the conversation? 2 A. Jeffrey. 2 A. We were sometimes talking about TVs, you know, 3 Q. Jeffrey just happened to be at the Florida 3 the latest plasma that's out there, LCD, you know, 4 Science Foundation? 4 setting up a stereo systems, you know, in the Palm Beach 5 A. Yas. 5 house. That's usually the main thrust of our 6 Q. How did you know that he was gaing to be at 6 conversations these days. 7 the Florida Science Foundation? 7 Q. How wauid you know to go to the Florida 8 A. He called me and told me. 8 — Science Foundation on each of those occasions? Would he 9 Q. And he said come to the Florida Science 9 just cail you? 10 Foundation to talk to me about what? 10 A. Yeah, he would call me and say come on by or! iL A. Maintenance on the airplanes, upcoming. It's | 11 gota brochure on a new Samsung. 12. an ongoing. 12 Q. With each time you were at the Florida Science: 13 Q. And did he have an office there? 13 Foundation, how long would you stay typically? 14 A. Yes. 14 A. Ten, fifteen minutes, Not much more than 15 Q. So this is -- when you walked in, this is the 15 that. 16 place that's right next to Jack Goldberger's office? 16 Q. You would go there for fen or fifteen minutes, 7 MR. CRITTON: Form. 17 have a conversation about a TV and leave? 18 THE WITNESS: Yes. 18 A. Yes, sir, 19 8YMR. EDWARDS: 19 Q, Why couldn't you have that conversation over 20 Q. And you walk in and there's a reception desk 20 thephone? What was it about? 21 right there? 2h MR. CRITTON: Form. 22 A. Yes. 22 THE WITNESS: if il was pertaining toe TV and 23 Q. 1s that where you taiked or did you talk 23 I'd have a brochure, a picture of the TV -- one 24 somewhere behind that reception desk? 24 particular TV we looked at it was the size of a -- A. Behind the reception area. 25 like five foot diagonal, so ! had a photo of myself Larry Visoski October 15, 2009 133 135 1 standing next to it or the salesperson. Sof mean, i A. We've ianded in Paris. 2 there's a reason to visually show him something 2 Q. You're aware that he has some contro! over 3 reference to that. 3 another piece of property over there? 4 BY MR. EDWARDS: 4 A. know we've picked up luggage at 2 residence. 5 Q. Did you ever communicate with Jeffrey 5S — 1 don't know to what extent his ownership is, if any. 6 Epstein ~ you can send him an e-mail, right? You could 6 Q. All right. 7 have done that? 7 A. Right. 8 A. Yes. 8 Q. And are you aware that he has some employees 9 Q. To send him the picture or something like 9 that listen to what he says that work in that house? 10 that, that was an option? 10 MR. GRITTON: Form. aL A. Right. 1. THE WITNESS: in Paris, yes, there is one 412 Q. And what's Jeffrey Epstein's e-mail address 12 person there. 13 that you use? 13 BYMR. EDWARDS: 14 A. | have to do it on my computer, you know, 14 Q. What's his name? 15 with — I have to type in the prompts for it because 15 A. Volizan. Because | aways thought there was 16 ~~ it's a long e-mail address. 16 nobody thera. a7 @. Okay. How fong have you e-mail corresponded | 17 @. Vultzan Cauldron (phonetic)? 18 with Jeffrey Epstein? 18 A. I don't know exactly. 1 would have fo look it 19 A. Probably two years. A year to two years. | 19 up. 20 mean, it's fairly -- something we just started doing. | 20 Q. Have you talked to him before? 21 mean, we'd never done that in the past. 24 A. No. 22 Q. Well, in the past he was in jail or have some 22 Q. When you've been in Paris ~ 23 restrictions? 23 A. You're not going to ask why? 24 A. The restrictions, yes. 24 Q. Well, 'm assuming he doesn't speak English. 25 Q. Se you you'd see him on the airplane 25 A. There you go, okay. 134 136 1 frequently? z Q. Sol thought there was no need for that? 2 A. Exactly. 2 A. Okay. | Just wanted to see. 3 Q. So when you didn't see him on the airplane 3 Q. Where do you stay when Jeffrey Epstein is in 4 frequently, then some of your correspondence was by 4 Paris? 5 e-mail, other times by telephone? 5 A. Ahotel. 6 A. Mm-hmm. 6 Q. Okay, And in New Mexico, when you land there, 7 Q. And other times in person? 7 you stay on the ranch somewhere, but at your place? 8 A. Yes. 8 A. | stay at my piace. 9 Q. And what was your e-mail -- what was the 9 Q. And in New York, you have an apartment that he 10 substance of the e-mail correspondence that you would} 10 — sets you up at, right, the 301? 11 have with Jeffrey Epstein? li A. Yes, | have a place | could stay. 12 A. it would have to be related. | mean, you have 12 Q, And in St. Thomas? 13 to give me atopic. | mean, whether it be a car ~- 13 A, Hotel. 14 @_ Never about the criminal investigation? 14 Q. And in Paris you stay at a home? 15 A. Oh, no, no, never. 15 A, (Nodding.) 16 @. Do you know what his intention is or his plans 16 Q. Are there any other properties such as what we 17 are for when he is off probation? 17 were talking about today ~ I'm not saying Jeffrey 13 A, No idea. 18 Epstein is the sole owner or direct owner, but any other 19 Q. Or off community controi? 19 properties that you're familiar with that Jeffrey 20 A. 1 have no idea. 20 Epstein is — has direct access to and at least it gives 24a Q. Has he ever indicated to you he wants you to 21 the appearance to you that he is the owner or controller 22 fly him to some other location outside the United States; 22 — of that property? 23 to live permanently? 23 MR. CRITTON: Form. 24 A. Oh, no. 24 THE WITNESS: Name the list that you've Q. Have you ever flown to his place in Paris? 25 stated. Larry Visoski CRIA RW 137 BY MR. EDWARDS: Q. The Manhattan house. A. Yes. Q. Mansion or whatever we want to caif it, the Zorro Ranch, the island of St. James, the Paim Beach house. A, Mm-hmm. Q. And the Paris piace. A. That's alt 'm aware of. Q. And have you ever at eny of those five places hung around him and stayed around him for -- during the daytime for the course of an entire day? A. No, Q. Ali tight, So do you know what he does during his days while he's there? A. No. Q. Are you aware of a list of underage girts that is kept to come over and service him each of those days?) MR. GRITTON: Form. THE WITNESS: Absolutely not. BY MR. EDWARDS: Q. I'm the first person te ever even imply that te you, right? A. Alist, yes, you are. Q. Okay. Have you ever been made aware that 138 Sarah Kellen keeps a list of underage girls to service Jeffrey Epstein for sexual purposes? A. 1am not aware of them. MR. CRITTON: Form to the last question. BY MR. EDWARDS: Q. Have you ever been made aware that Ghislaine Maxwell keeps a list of girls in the nearby areas of each of - at Jeffrey Epstein's residences to service him sexually? A. No. MR, CRITTON: Form. BY MR. EDWARDS: Q. Okay. Have you ever read some of the compiaints that have been fited against him in the various courts, whether state court or federal court, against Jeffrey Epstein? A. No, Ehave not. Q. Ali right. So this Jane Doe 102 versus Jeffrey Epstein, you're not familiar with who that person is? A. No idea. Q. Okay. I'm going to mark Jane Doe, one of the 22, versus Epstein as Exhibit No. 4 to this deposition. (Plaintiff's Exhibit No. 4 was marked for identification.) October 15, 2009 139 BY MR. EDWARDS: Q. And ask you about some of the allegations in here and see if you know anything about them. It indicates he owns a flight of aircraft that includes a Gulfstream, a helicopter, and a Boeing 727, True? MR. CRITTON: What's the question? THE WITNESS: Piease repeat. BY MR. EDWARDS: Q. Are you aware of him owning a Gulfstream IV aircraft, a helicopter and a Boeing 7277 | think we talked about it, right? A. Right. Q. Okay. And it indicates a fleet of motor vehicies? MR. CRITTON: Wait a minute. He said right, is that we talked about it, as distinct from him knowing one way or another. THE WITNESS: What's the question? BY MR. EDWARDS: Q. Do you know that he owns those things? A. | do not know that he owns them. . Do you believe that he owns those things? MR. CRITTON: Form. THE WITNESS: ! would be guessing, so... 140 BY MR. EDWARDS: Q. What does the company NES, LLC, do to your knowledge? A. thave no idea. Q. How does that company generate profit, if you know? A. Vhave no idea. . Q. That's the company that pays your paycheck, but you have absolutely no clue what they do to generate money? A. No, sir. Q. tfanything? A. Correct. Q. Have you ever heard that that company generates money through sex trafficking of young girls? MR. CRITTON: Form. THE WITNESS: Absolutely not. BY MR. EDWARDS: Q. Never, okay. Have you ever heard that Jeffrey Epstein has a sexual preference for underage girls? Other than what you've read in the newspaper, have you heard that from any other individuals before? A. No. Q. Ever heard that he has had sex or sexual relationships with many minor gitls, some as young as 12 Larry Visoski October 15, 2009 COI TAHeYNe 10 il 12 £3 14 is 16 aad 18 19 29 21 23 24 25 wedanvewne 14. y 143 years old? 1 about that? MR. CRITTON: Form. 2 MR. REINHART: Hoid on. The question is have THE WITNESS: No. 3 you ever been told that fact that he just read to BY MR. EDWARDS: 4 you? Q. Never? 5 BY MR. EDWARDS: A. Never. 6 Q. Right. Q. Have you ever seen any photographs in any of 7 A, | have never been toid that fact. his homes depicting young-looking girls engaging insexj 8 Q. Has anybody ever questioned you about your acts? $ possible involvement with helping to facilitate A. No. 10 Mr. Epstein have sex with underage girls? Q. Or reading directly from the compiaint, qi A, No. “engaged in lewd acts"? 12 Q, When you were questioned by either the police A. No, absolutely not. 13 or the — whoever the investigative resource that was Q. Have you looked around the wails of his 14 being used at the time? various homes when you're in there picking up luggage?} 15 A. Right. A, |mean, not any more than | walked in here and 16 Q. Do you remember who that person was that was net looking at the wails over there, | couldn't tell you 1? questioning you? what those are; so nothing specific. 18 A, No, i don’t remember. Q. Sometimes we're talking about a 50,000 square 19 Q. 1 know you don't know the focation where it foot house? 20 was, but do you remember who they were affliated with? A. Exactly. 21 A. No. Q. In Manhattan? 22 Q. Was it only one time? A. It's pretty big. 23 AL Yes. Q. Okay. Have you ever looked at any of his 24 Q. Did you also have to testify before a grand computers for any reason? 25 — jury proceeding? 142 144 A. No. 1 A. No, | did not. Q. 1 know that you helped set up some of the ~ 2 Q. Have you ever known Mr. Epstein to get a A. Computers are nat my expertise. 3 massage while on an alpplane? Q. Ailright. Have you ever been told that 4 PHONE ATTORNEY: This is everybody in Boone, Mr. Epstein committed sex acts against underage girs on! $ Charles and the witness is here and the court a literal daily basis, that's what he does? € reporter and the videographer. A. I've never been toid that. 7 MR. EDWARDS: Fantastic, but I think that you Q. Have you ever read the complaints against him 8 may have the wrong room, that indicate that's what he does on a daily basis? 9 PHONE ATTORNEY, ‘I was told to ask for 856. MR. GRITTON: Form. 10 MR, EDWARDS: Let's go off the record. THE WITNESS: No. ii {Off the record discussion.) BY MR. EDWARDS: 12 BY MR. EDWARDS: Q. Soin your mind, you never believed that you 13 Q. Allright. In the complaint, fm going to were transporting around somebody whose sole goal in 14 elt you what it alleges and I'm going fo ask if this life is to get -- have sex with [ittie girls? 15 helps to refresh your recollection about any of Jeffrey MR. CRITTON: Form. 16 Epstein’s activities. The defendant, Jeffrey Epstein, THE WITNESS: | never believed that, no, 17 transported the plaintiff to another state in order to. BY MR, EDWARDS: 18 — engage in sex acts with her. And this accurred when she Q. Okay, Have you ever been totd that he 19 was merely 18 years old. conspired with others, including assistants and/or his 20 ‘Do you remember transporting somebody that drivers and/or pitots and his friend Ghisiaine Maxwel, 21 looked like they were 15 years old on your airplane? to further these sex acts and to avoid police detection? 22 A. No, sir MR. GRITTON: Form. 23 Q, You never remember taking a 15-year-old, or BY MR, EDWARDS: 24 — somebody that icoks around that approximate age, on your Q. Have you ever — anybody ever questioned you airplane? Larry Visoski October 15, 2009 145 147 A. Can you be more specific? 1 Q. To Santa Fe? Q. Well, | know that you've indicated earlier in 2 A. Yes, the deposition that you remember some girls under the 3 Q. ToLos Angeles? age of 18 on the airpiane. And so let me ask, before 4 A. Yes. get back into this, whether all those individuals you 5 Q. To San Francisco? were taiking about were accompanied by a parent or some 6 A. Yes. of those people were on the airplane for some other i Q. To St. Louis? purpose, modeling, or you don't knew why they were 8 A. Yes. there? ?'m going to let you elaborate on who these 9 Q. Allright. Continuing to internationat pecpie are that you befieve may have been under the age 10 destinations, including Europe, have you ever flown it of 18 and why you think they were on the airplane? 11 to Europe? MR. CRITTON: Form. 42 AL Yes. THE WITNESS: We've had younger people on the 13 Q. The Caribbean? airplane that have been, you know, with their 14 A. Yes. family members, like you said. 1 don't remember 15 Q. And Africa? transporting anybody that was of questionable age. 16 A. Yes. I'm not -- I'd only be guessing at somebody's age 17 Q. On those flights to those various places, is if | didn’t ID them at the foot of the airplane. 18 — ityour -- to the best of your knowledge, you were So | can't guess to their age. 19 unaware of Jeffrey Epstein engaging in sex with underag: BY MR. EDWARDS: 20 girls on his airplane? Q. Allright. “Mr. Epstein used his private jet 24 MR. CRITTON: Form, to transport the minor plaintiff to Manhattan where he 22 THE WITNESS: [have no knowledge of any of provided her spending money and accommodations with him} 23 that. at his mansion." 24 BY MR. EDWARDS: Do you have any idea who that might be 25 Q. "He provided accommodations with him in order 146 148 referring to? 1 to have her available to him at all times whenever he MR. CRITTON: Form. 2 wanted, including while transporting the minor plaintiff THE WITNESS: No, sir. 3 on his private jet.” BY MR. EDWARDS: 4 That's something that you had no knowledge of? Q. And you don’t remember being a pilot of an 5 A. (Witness shakes head.) airplane where he was transporting a 15-year-old to 6 Q. You have to a yes or no. Manhattan from Miami or Palm Beach? 7 A. I'm sorry, no. A. No. I'd be guessing at somebody's age and | 8 Q. "Each time they would travel to one of these can't guess. 9 destinations, the same pattarn of sexual abuse would Q. "Defendant transported plaintiff in his 10 occur, often with a vast array of aspiring models, private jet to locations that included Paim Beach, New} 11 actresses, celebrities, and/or other females, including York City, Santa Fe, Los Angeles, San Francisco, 12 minors from ail over the world.” St. Louis." 13 Again, that's something you have no personal Do you remember ever piloting his airpiane to 14 knowledge of? those destinations that | just mentioned? 15 A. No. MR. REINHART: Can we break them down? 16 Q. Has anybody ever indicated that if you did Objection; compound. 17 have personal knowledge of some of these things, then: MR. EDWARDS: Okay. 18 you could also have been implicated in some form of a BY MR, EDWARDS: 19 crime? Has any law enforcement or anybody ever Q. Have you ever flown his airplane to Palm 20 indicated that to you? Seach? 22 A. Ne. A. Yes, sit. 22 Q. Okay. 1s that something you've ever worried Q. Okay. Have you ever flown it to New York 23° about? Gity? 24 A. No. AL Yes. 25 Q. Allright. "Upon information and belief, Republic before. Anywhere within that country, have you 28 a Larry Visoski October 15, 2009 149 151 1 defendant transported minor girls from Turkey." Did you 1 ever flown to or from in a Jeffrey Epstein airplane? 2 ever leave in one of his airplanes out of Turkey? 2 A. We have flown to Prague. 3 A. I'd have to look at the records. | don't 3 Q. Okay. Have you picked people up in Prague and 4 recall Turkey. 4 flown out of Prague? 5 Q. Do you ever remember taking any minor girls 5 A. | don't remember. 6 — out of Turkey? 6 Q. Im not saying no, you didn't, but -- 7 A. No, 1 don't remember, 7 A. Best of my knowledge. 8 Q. What records would you have to jook at to see 8 Q. - you don't remember? 9 if you took people out or left out of Turkey? 9 A. Exactly. Best of my knowledge, i don't 10 A. I'd have to look at the flight fogs, but t 10 = remember. 11 personally don't remember flying into Turkey. 11 Q. Do you remember the reason for going to Turkey; 12 Q. And would the flight jogs coming into the 12. orto Prague? 13 United States from Turkey indicate the names of the 13 A. No. 14 people on the plane? ia Q. This also says Asia. Have you ever flown to 15 A. They might, 15 or from Asia with Jeffrey Epstein? 16 Q. Okay. Where would | get those particular 16 A. Yes. 17 flight fogs that would have that information? 17 Q. Orona Jeffrey Epstein airpiane?: 18 A. Depended upon what year you're talking. 18 A. Yes. 19 Q. We're talking in this particular complaint 29 Q. Do you know the purpose of those flights to 20 between 1998 and 2002, 20 and from Asia? 21 A. tm not — I don't possess those passenger 21 A, No. 22 manifests. 22 Q. Did it ever occur to you that maybe it was to 23 Q. De you know who would possess those? 23 pick up minor giris for him to have sex with on the back 24 A. That would be | guess -~ 24 of the airplane? 25 MR. REINHART: Do you know who has them tosey4 25 MR, CRITTON: Form. | 150 152 2 THE WITNESS: | do not know who has them 1 THE WITNESS: Never occurred to me. 2 today. 2 BYMR. EDWARDS: 3 BYMR. EDWARDS: 3 Q. Did you ever hear that he maintained some of 4 Q. Who did you give them to? 4 these underage girls as sex slaves — 8 A. Actually, | didn’t give them to anybody. Dave 5 A. Never heard of such a thing. 6 Rogers was in possession of those logs. Solden'tknow 6 Q. -- from the age of 12 through the age of 167 7 where they are right now. 2 MR. CRITTON: Form. 8 Q. You're still thinking that the best evidence 8 THE WITNESS: No knowledge of that. 9 of that, any flight that may have left out of Turkey, 9 8YMR. EDWARDS: 10 would be in the flight fogs that's marked as Composite 10 Q. Ever picked up gitls that looked young, many 11 ‘Exhibit 1, or are we talking about the manifests that 11 of whom who spoke no English? Do you ever remember 12 we've been referring to? 12 that? 13 A. _| don't know how accurate that og book is or 13 A. Zero, do not. 14 even how accurate the passenger manifest is. 14 Q. Allright. The compiaint goes on to say, 1s Q. Okay. So there may be no actual documentation; 15 “Plaintiff was required to be sexually exploited by 16 indicating a flight leaving out of Turkey when, in fact, 16 = defendant's adult male peers, including royalty.” So 17 a flight may have left out of Turkey? 17 Fm going to talk, do you have any familiarity with 18 A. Correct. 18 Prince Andrew? 13 Q. Okay. The Czech Republic is the next place 19 A. iknow who he is. 20 — fisted. Is that a place you've flown to or from ina 20 Q. Was he ever on the airplane? 21 Jeffrey Epstein airplane? 21 A. He may have been on the airplane. 22 A, More specific, could you name the city? 22 Q. Do you remember him on the airpfane with young 23 Q. | can't name the city, at feast the complaint 23 gits? 24 — doesn't name the city. But I've been to the Czech 24 A. No, } do not. 25 Do you remember Jeffrey Epstein flying in to Larry Visoski October 15, 2009 153 155 1 meet with Prince Andrew? 1 BY MR. EDWARDS: 2 A. | don't remember. | know that happened, but! 2 Q. Okay. Do you remember who else was on th 3 couldn't be accurate. 3 flight that left after 10 p.m.? 4 Q. Has Prince Andrew ever been on the airplane at 4 A, No, Ido not. 5 the same time as a young gitl, to the best of your 5 Q. Do you remember why it left after 10 p.m.? 6 memory and knowledge? 6 A. No, I do nat. 7 A. To the best of my knowledge, no. 7 Q. Do you remember Jeffrey Epstein instructing gs Q. This aiso says politicians, talking about 8 you to wait until after 10 p.m. to leave? 9 — focal or U.S. politicians. Do you remember certain 9 A. No. 10 politicians being on the airplane? 10 Q. Would you nave listened to him if he had told 4 A. No—1 mean yes, I do. 11 you ~ if he had instructed you to do that? 12 Q. What politicians would that be? 12 A. i don't understand the question. 13 A. President Clinton. 13 Q. Well, if he told you wait until after 10 p.m., 14 Q. Okay. Who else? 14 I realize there's going to be a fine, but wait untit 1s A. Former president of Israei -- help me out with 15 after 10 p.m. to leave, intentionally teaving 16 the name, Barak? 16 after 10 p.m., do you remember that instruction ever -~ WwW Q, Ehud Sarak? 17 A. No, I don't remember that instruction. 13 A. Yes, those are the bwo that | remember. 18 Q. Okay. 19 Q. How many times was Ehud Barak on the airplane) 19 A. {i mean, it just happened fo be departing 20 that you piloted for Mr. Epstein? 20 after 10 and there is a penalty for ieaving after 10 for 21 A, Maybe once. 21 noise. So there was no intention to... 22 Q. And where did that flight pick up and where 22 Q. Allright. This also talks about this 23 diditgo to, to the best of your memory? 23 particular person 15 years oki being sexually expioited 24 A. Best of my memory, it was Palm Beach to 24 by businessmen and/or other professional or personal 25 ‘Teterboro. 25 acquaintances. Are you aware of other personal or 154 156 a Q. Where fs Teterboro? 1 professional acquaintances of Jeffrey Epstein also 2 A. In New Jersey. 2 sexually abusing or exploiting tittle kids or underage 3 Q. And what was the purpose of that flight, do 3. girls on your airplane? 4 you know? 4 MR. CRITTON: Form. 5 A. i don't know. 5 THE WITNESS: No. 6 Q. Was Jeffrey Epstein on the flight? 6 BYMR. EDWARDS: x A. Id have to look at the flight logs to 7 Q. Ifyou had been aware that Mr. Epstein was — 8 guarantee. & and by this -- this Is more in the form of a 9 Q. Anything about that flight stick out in your 9 hypothetical, and that I'm not going to suggest to you 10s mind? 10 it's a fact that he was, But if you had been aware that a A. None. 11 every single day Jeffrey Epstein's goal was to locate 12 Q. Such as a fine needing to be paid because it 12 underage girls for the purposes of sex, and either have 13 left after 10:00 p.m.? 13 sex with them on the airplane or at some other 14 A. For that was the flight, yes. 14 — designation that you were destination that you were 1s Q. You remember that? 15 traveling him to, would you have continued to pilot 16 A. it's coming back to me. 16 = those planes? 17 Q. And do you remember young girls being on that} 17 MR. CRITTON: Form. 18 flight? i8 THE WITNESS: You said it was hypothetical? 13 A. No. 19 BY MR. EDWARDS: 20 Q. Ali right. 26 Q. Right, itis a hypothetical. a1 A. | remember the fine. 21 A. Why would | want to answer that? Because 22 Q. D0 you remember whe paid the fine? 22 you're being hypothetical. | mean, it would obviously 23 MR. CRITTON: Hold on. Let me object to form 23° be wrong. 24 of the question. "De you remember" it suggests 24 Q. Sure. Weil, a hypothetical question is a 25 that there were. Sa form, predicate. 25 legal question that I'm allowed to ask. Larry Visoski October 15, 2009 157 159 MR, CRITTON: Form. 1 A. Okay. L THE WITNESS: Never heard of such a thing. 2 Q. And ['m just asking you if you did have 2 BYMR. EDWARDS: 3 knowledge that Jeffrey Epstein was having sex with 3 Q. Do you know of any friends that he has in 4 _ Sittle girls either on the plane or at a piace that you 4 France that would send him birthday -- a birthday 5 — were taking him to or from an a daily basis, that's what 5 present? 6 he did, would you have continued to be his pilot? 6 A. No. a MR. CRITTON: Lat me object. Object to the 7 Q. Do you know of him receiving any birthday 8 form. it's argumentative. thes no more value 8 gifts or birthday people from anyone? 9 than assuming he was chopping up bodies or anybod) 8 A. Never. 10 was chopping up bodies in the plane you're flying, 10 Q. This particular person that filed this iL What difference does it make? Form. 11 complaint, Jane Doe 102, indicates "Defendant and 12 MR. EDWARDS: What difference does it make in 12. Ghislaine Maxwell acknowledged and celebrated 13 a case about him having sex with littie giris? I'm 13 plaintiffs 16th birthday.” 14 noi going to argue with you about it, You've 14 Do you remember them celebrating somebody who] 15 stated your objection. 15 you flew on the airplane's 16th birthday? 16 MR. CRITTON: Exactly. ifs an argumentative 16 A. don't recall. 17 question. 47 Q. Any of this jog your memory as to who Virginia 18 MR. EDWARDS: I'm not going to argue with you 18 Roberts is? 1g about it. a9 A. No. 20 MR. CRITTON: You're arguing with him about 20 Q. “From the age of 15, plaintiff" — this Jane 24 now, 21 Doe 102 ~ “was sexually exploited and abused by 22 MR. EDWARDS: No, I'm asking him the 22 — defendant on a daily basis and often multiple times each 23 hypothetical. 23 day? 24 BY MR. EDWARDS: 24 ‘So going back, was there ever a day where you Q. Can you answer that? Would you have continued} 25 were with Jeffrey Epstein where you could observe hint 158 160 1 te bea pilot for somebody who's traveling to and from 1 and Virginia Roberts during an entire day? 2 destinations with the goat of having sex with underage 2 MR. CRITTON: Form. 3 girls? 3 THE WITNESS: I don't remember Virginia 4 MR. CRITTON: Form. 4 Roberts, so | couldn't answer the question. 5 THE WITNESS: It could be any person. it S BY MR. EDWARDS: 6 doesn't have to be Jeffrey Epstein, then, right? 6 Q. "in September 2002, Defendant Epstein 7 BY MR. EDWARDS: 7 purchased a commercial round-trip airline ticket and 8 Q. True. 8 provided a passport, U.S. currency and accommodations| 9 A. No, | wouldn't pilot an airplane if there was 9 for plaintiff to fly to Thailand." 10 ~— wrengdoing going on. 10 Do you remember him doing that for anybody a1 Q. That you knew about? 11 around that time period? 12 A. Thai | knew you about, sure. 12 A. No, sir. 13 Q. Me reading this complaint to you, is this the 13 MR. CRITTON: What was the date? 14 first time you've heard these allegations -- 14 MR. EDWARDS: September 2002. 45 A Yes. 15 MR. CRITTON: Okay, thanks, 16 Q. -- against Mr. Epstein? 16 MR. EDWARDS; / have here — and this is 17 AL Yes. 17 actually my only copy, so | don't mind marking it 18 Q. It goes on to say, "On one of Epsisin's 18 as a composite exhibit, but we'll either have to 19 birthdays, a friend of Epstein sent him three 19 copy this while thing or we'll have an agreement of 20 12-year-old girls from France who spoke no English fon 20 counsel. It's the visitor inmate log from when 21 the purpose of — for defendant to sexually exploit and aa ‘Mr. Epstein was in jail in Palm Beach. 22 abuse. After deing so, they were sent back to France | 22 MR. CRITTON: Well, before we get started, it 23 the next day." 23 is now 1:15. We started at 10:00. 24 Are you famitiar with that occasion? 24 MR. EDWARDS: We didn't really start at 10:00. MR. CRITTON: Shortly thereafter. | was here Larry Visoski 161 pretty much after 10. But we've been here since 10:00. | want to take a lunch break. MR. EDWARDS: Let's do it, MR. CRITTON: For an hour? MR. EDWARDS: Sure. {A break was had at 1:15 p.m.) BY MR. EDWARDS: Q. Albright. | looked through the inmate log of the visitors who visited Jeffrey Epstein and your name appears one, two, three, four, five, six, seven, eight times. A. Okay. @. Seem to be accurate in terms of how many times. you went to visit him? A. thought six, but yes, that's... Q. |'llet you review the records and tell me if you dispute any of that record. And I'll go ahead and mark that as Composite Exhibit 5. {Piaintiff's Exhibit No. § was marked for identification.) MR. REINHART: It's two pages. MR. EDWARDS: Two pages, MR. REINHART: Okay. BY MR, EDWARDS: Q@. Seem accurate? 162 A. Yes. Q. Okay. Jeffrey Epstein's plea, | believe, was June 30th, 2008. | think that's when he was taken in custody from there. Your first visit is July 3rd, 2008. And the other name on that visit is Igor Zinoviev. Did you go with Igor to visit Jeffrey Epstein? A. Yes. Q. Why did you go with Igor? A. It just happened he wanted to see us both at the same time. There was no apparent reason. Q. How did you know that Jeffrey wanted to see you? A. [don't recall who called and told me that he wanted to see me. | couldn't give you an accurate name, whether it was, you know, his attorney, Darren. And actually, | would put a lot weight to | think it was Darren, his attorney. Q. That would have made 4 phone cail to you that said -~ A. Yeah, to go. Q. And what did you talk about with Jeffrey Epstein four days after he pled guilty to offenses that landed him in jait? A. [think the first visit was how disappointed or how scared he was, you know, being inside there. We: CRIHAHeYNHH October 15, 2003 163 just talked about general happenings that go on in there. Q. What did he say? A, it's terrible; it's cold; he can't sleep. They wake him up every two hours. You know, just item: like that, uncomfortable things. We talked about the airplanes a great deal. You know, we got major maintenance on the big airplane, so we discussed that a little bit, And then it was really just how uncomfortable he was there. Q. How jong did you visit with him on that first visit, July 3rd? A. [think we stayed the fuil hour. Q. Altright. Is that what the time aliofment was? A, tf believe itis, yeah, | don't think you could feave early, or 'm not aware that you could leave early, until later on we found out you could stay for five minutes or fonger. But | don't think any of us knew that was — once you got in there, you stayed there for the hour. Q. Okay. So you talked to him for an hour and for the most part it was just about the conditions and his disappointment with the conditions? A, Sure, yeah, absolutely. 164 Q. And did Igor talk to him as well? A. Briefly. | mean, not that much. You're going back a little ways again to remember exactly what was discussed. You know, he asked how his family was doing. i guess igor's got a son, | think he asked how his son was doing. You know, just general questions like that, Q. Did you ride to the jail that day with Igor? A. |} believe we did. | believe | met Igor probably at Jeffrey's house and picked him up, or if not, we may have met at the airport and drove together. But we did drive together on that occasion. Q. In what vehicte did you drive? A. The Hummer. Q. That's the vehicle you described eartier as the company vehicie? Yes, sir. . 1s that a vehicle paid for by Jeffrey Epstein? . Meaning? . Weil, is that a vehicle paid for by you? . What do you mean "paid for"? . Did you purchase the vehicle with your money? . didn't purchase that one, no. Q. Do you know If it was purchased by Jeffrey Epstein or a corporation of Jeffrey Epstein's? A. Probably 2 corporation. POPOPOP,R Larry Visoski October 15, 2009 165 167 1 MR. CRITTON: Form; move to strike. Sounds 1 facility that was holding Jeffrey Epstein, they're 2 like a guess. 2 ~~ accurate, your name is the first one listed on the top 3 BY MR. EDWARDS: 3 of the sheet? 4 Q. To the best of your knowledge, that’s how most 4 A. Right. There may have been eartier dates. | 5 of the items that you've discussed -- that being the 5 have no idea, 6 Boeing and the Gulfstream - they were usually held in 6 Q. Weil, you know, the first date that he could 7 corporate names, to your knowledge? 7 have been in there it looks like was 7/1/08 and then, 8 A. To my knowledge, exactly, yes. 8 you know, so | guess somebody could have seen him 7/1 or 9 Q. And so when you're saying the — when you're 9 7/2, but those records were never provided to us. You 10 talking about the Hummer vehicie and you're stating that; 10 see we were provided a whole big stack. 11 it’s fkely @ corporate entity, is that just something al A. tunderstand. 12 that you're guessing about, os de you have knowledge? 12 Q. The next date I'm going to talk to you about 13 A. No, fm just guessing. 13 Is 7/12/08. 14 Q. Okay. 14 A, Ub-huh, 15 A. Thave no proof ~ 15 Q. itooks, again, like i's yourself and Igor 16 Q. —of ownership of who it's registered to or 16 © Zinoviev? 17 anything like that? 17 A. Mathmm. 18 A. Exactly. 18 @. And that's something we talked about in this, 19 Q. Is it registered to you? 19 deposition. ['m going to ask you again, I don't know 20 A. No, no, 20 that you elaborated last time, what is your 21 Q. So it’s registered to somebody other than you? 21 understanding of his relationship with Jeffrey Epstein? 22 A, Exactly. 22 Is thata friend of his? 23 Q. Okay. 23 A. I don't know his job description. | mean, 24 A. [just drive it, Eguess. 24 he's somebody that's around a lot, but | don't know his I 25, Q. Okay. So on July Sth, 2008, you go back to. 25 exact job description. His English is, fo say, not 166 168 1 see him in jail again, and again, Igor Zinoviev is. 1 100 percent, so conversation with somebody that doesn't 2 listed as a visitor. Did you go with him together on 2 fuy understand you, you know, you get lost in 3 that occasion’? 3 translation a little bit. So | don’t ~ 4 A. tI didn’t even realize it was two days after 4 Q. So on these three visits to the jail, the 5 the first visit. 5 first three that we're talking about that we've talked 6 Q. Wel, 1 mean, you see where this is going? 6 about so far, each of those times you traveled to and 7 A. Yeah, 1 do. It gets further apart, yeah. 7 from the jail with Igor? 8 Q. Do you remember what the discussion was on 8 A. Me-hmm. 9 715108? 9 Q. Yes? 10 A. No, because it’s probably similar to the first 10 A. Yes, yes. 11 one. I mean, we talked — actually, one of the visits 11 Q. And each of those time, is it fair to say you 12 we talked about fishing and just trying to — you know, 12 had some form of communication either on the way to nd 13 we were talking about things that would just occupy his} 13 — Jait or — 14 mind with intelligent conversation that he probably 14 A. Sure. 15 wasn't getting there. So for that hour of the day, | 1s Q. --to the jail? 16 tried to give my best of intelligent conversation to 16 A. Yeah. 17 him. ay Q. Since you're going to see an inmate in the 18 Q. Okay. On his visitor log you were the first 18 jail, is it a safe assumption a portion of that 19 one te go visit him. Did you know that? 19 conversation was about the person that you're going to 20 A. | did not know that. 1 wasn’t aware of that. 20 see and possibly the crime that was committed? 21 MR. CRITTON: Let me just object to form to 22 A. Yes, that would be 2 good assumption. 22 the last question, 22 Q. Okay. And what was the form — whal was the 23 BY MR. EDWARDS: 23 substance of that conversation that you can remember 24 Q. Well, at least if these racords are accurate, 24 — zelaled to Jeffrey Epstein and the location you were 25 which are the records that were provided to us by the 25 going to visit him? Larry Visoski October 15, 2009 169 L171 L A. | think Igor and { discussed on trying to be 1 Q. And in the course of that conversation, again, 2 upbeat and not look at the position that he’s in sitting 2 the allegations and the unusual I'l cail it case 3 across the table from us, to be upbeat and uplift his 2 against him, that didn’t come up between you and 4 spirits. 4 Mr. Epstein? 5 Q. Did you and Igor discuss whether or not you 5 A. | never talked about it with him, 6 — were going to talk to him about his plea of guilty or 6 Q. And at that point in time, what were you aware 7 the fact that he’s not registered as a sex offender? 7 ofa terms of the number of girls that he was alleged 8 A. No. & — tohave had sexual — some sort of sexual relationship 9 Q. Orwhether you were going to stay away from 9 with him at his Palm Beach house? 10 those topics? 20 A. What was the question? How many girls? 11 MR. CRITTON: Form. uw Q. Yeah, how many girls were you — 12 THE WITNESS: We never -- we don't discuss 12 A. Aware of? 13 that amongst ourselves and/or with Jeffrey in any a3 Q, — aware of? 14 way, form. as A. None. Iwasn't aware of any, to be honest. 15 SY MR. EDWARDS: 1s Q. The next visit is on 7/17/08 and it's Igor 16 Q. Okay. But that's not -- | realize you didn't 16 — Zinoviev and somebody named Jean Rene and then yoursell 17 discuss that. You've told me that, 17 Do you know who Jean Rene is? 18 A. Right, but we didn't discuss that even prior 18 A. No. 19 te going in, as you asked. i? Q. Do you think that that visit, that you visited 20 Q. Okay. So your discussion was mainly hey, 20 him at the same time that Jean Rene visited? 21 let's be upbeat? a1 MR. CRITTON: What's the date? 22 A. Yes. 22 MR. EDWARDS: t's 7/47/08. 23 Q. And that was to, in essence, maintain his 23 THE WITNESS: No, f don't know a Jean Rene, 24 spirits or raise his spirits? 24 unless somebody came after. { mean, | don't ~t 25 A. Exactly. 25 don't know a Jean Rene. 170 172 L Q. Okay. And you were doing that as a friend of 1 =BYMR. EDWARDS: 2 his, not just his pilot, right? 2 Q. Okay. And then before you visited him again, 3 A. | felt honored that he asked me to come and 3 the visitors are listed as Nadia Marcinkova or Sarah 4 give support like that, because prior to him going away, 4 Kellen? 5S __ itwas known to us that there was going to be no 5 A. Mm-hmm. 6 visitors, because { had offered to him that t would be 6 Q. Mainly those two individuals. And they jist 7 happy to come and visit him if he deemed it necessary, 7 as addresses, 301 East 86th Street as their residence? 8 and he says no, i'm not going to have anybody, 8 A. Uh-huh. 9 Q. So- 9 Q. Given your previous testimony, does that 10 A. {guess it was so bad there, that he may have 10 surprise you that they list those -- that address as 11 changed his mind and wanted to have some visitors. 11 their residence? 12 Q. When did you have this conversation with him 12 MR. CRITTON: Form, 13. where he indicated he was not going to have visitors 13 THE WITNESS: I've seen them there, so i mean, 14 while he was in jail? 14 Fm not surprised. 15 A. {don't exactly remember. itmayhavebeenon ; 15 BY MR. EDWARDS: 16 the trip heading to Palm Beach, the last flight. 16 Q. Okay. Did you know that they were visiting 7 Q. From his isiand, from St. Thomas | guess it 17 him in jail? 18 would be from? 1e A. No, didn't know who was scheduled to see him 19 A. (forgot where it started from. f might have 19 orwhatever. 20 been New York or the isiand, one of the two. I don't 20 Q. Did Jeffrey talk to you at any point in time 21 remember the last flight. 21 about Nadia Marcinkova or Sarah Kellen? 22 Q. And I mean, did at least the fact come up that 22 A. No, not at all. 23 hey, this a person who you're — is going to be in jail 23 MR. REINHART: Can we get a time frame for 24 for some time? 24 that? Ever? A. Mm-hmm, yes. MR. EDWARDS: Oh, no, well, | was talking -- Larry Visoski 173 1 ('m sorry. 2 a 4 5 6 7 g 9 10 ii 12 43 4 1s 16 17 18 i3 20 21 22 23 24 26 weavauewne October 15, 2009 175 1 atthe house. BY MR. EDWARDS: 2 Q. Those are cars that Jeffrey Epstein owns, to Q. Iwas talking right now about in the 3 your knowledge? conversations that you had with him that we've discussed 4 A. | don't know who owns them. with you and him in the jail facility. Did he discuss 5 Q. What cars are there that -- | know with this with you Nadia Marcinkova or Sarah Kellen? 6 case we're dealing wilh a lot of corporations and it's A. No, no. 7 not like asking me, Hey, what car do you own? But what Q. Did he talk to you about whether or not you 8 cars are you aware that are -- that you believe are used should talk to anybody about his criminal investigation 3 primarily by Jeffrey Epstein? or possible litigation? 10 A, Used primarily by Jeffrey Epstein, a Mercedes A. No, not at ali. 11 $600 sedan. | don't remember the year on that one. Q. The next time you see him is on August 9th, 12 Q. Okay. 2008, at the jail. In that occasion it mentions as his 13 A. There's a Cadillac Escalade. visitors that day Nadia Marcinkova, Sarah Kellen and 14 Q. Okay. Larry Visoski. Did you go to the jail with Sarah and 45 A. Those are his two main cars that he would be Nadia that time? 16 driven in or — ‘A. No. Who was on there? Which one are you 7 Q. What are the other cars that you regularly see referring to? 18 parked at his Palm Beach mansion, if there are any? Q. The next one, | tried to highlight them just 19 A. ftwoutd be a whole array. Half the time the 80 that ~ 20 parking lot is full because of construction workers, A. Right, that one. 21 -yards Keepers. MR. REINHART: 8/9. 22 Q. Okay. Fair enough. What vehicle does Sarah BY MR. EDWARDS: 23 Kellen drive or Nadia Marcinkova drive when they're dow! Q. 8/9108? 24 here, ifyou know? A. One of those two we ail drove together. | 25 A. (mean, anybody has a choice to pick out a car 174 176 don't remember which one it was. It was either the 9 or 1 or whatever there. I've seen Nadia driving a Mercedes the 16, and then the other one } met everybody there, 2 convertible. So | can't be accurate on which time we al drove 3 Q. _[s that different than the Mercedes $500 together. 4 sedan? Q. How did you'coordinate driving together? 5 A. Yes, i think its different. A, | don't exactly remember now. [ mean, | think 6 Q. When you say they have basically a choice of Sarah and | may have conversed on the phone and said dq 7 oars to drive ~ you want to meet at Jeffrey's house and we ail drive gs A. Weil, there's cars in the lot there. together? Does it make sense to get together and drive 9 Q. Obviously, they can't get in one of the one car. 10 construction workers‘ cars? Q. |s that jail visit the result of Jeffrey al A, No. Epstein requesting your presence there, or is that the 12 MR. REINHART: Let him finish his question. result of you wanting to go see him as a friend in jait? 13. BYMR. EDWARDS: A. Acombination of both. i'm sure if | said, 14 Q. So that's kind of what I'm getting at. What Hey, I'd like to come to jali and visit you, that he 15 other cars do you think that Jeffrey Epstein has -- would either say yea or nay. 16 — whether it's titled, I don't know ~~ Q. Okay. And you said at least on one of those 17 A. Right. occasions you rode to and from the jail with Sarah and 18 Q. ~ but he Is the person in control of that Nadia? 19 vehicle? A. Yes. 20 A. Right. Q, And during any of ~ obviously, when you're in 21 Q. What other vehicies do you think he's the car together — well, who's driving the car? 22 controlling in Palm Beach? A. twas driving, | believe. 23 A. In Palm Beach? Q. And that's the Hummer again? 24 Q. We've named the Mercedes S500 sedan, Cadillat A. Actually, | think we take one of the suburbans 25 Escalade? Larry Visoski 177 _ Right. . And I've identified a Mercedes convertible? . Right. In addition to that, are there any others that you're aware of? A. That he's in control of? Q. Yes. A. No. Q. And does the conversation come up between Nadia and Sarah and yourself about the reason why Jeffrey Epstein is in jail? MR. REINHART: Can we get a time frame? MR. EDWARDS: At any time. BY MR. EDWARDS: Q. Atany time have you ever had that exact conversation ever come up? A. No, we didn't talk about that among ourselves really. Q. And have you ever been told that Nadia Marcinkova provides the role of @ sex slave to Jeffrey Epstein? That's just her role in life? MR. CRITTON: Form. MR. REINHART: That's just have you been told} that. THE WITNESS: No. 178 BY MR. EDWARDS: Q. Have you been led to belleve that by anybody? A. No. MR. GRITTON: Form. BY MR. EDWARDS: Q. Do you have any — based on your observations, do you have any other opinion as to what role she plays| in Jeffrey Epstein's life, if any? A. 1 don't have an opinion on what the role is. Q. Do you agree with the criminal statutes that are in place to protect young children from sexual predators? Do you agree with those statutes? MR. CRITTON: Form, MR. REINHART: I'm going to direct him not to answer the question. (t's irrelevant and it's not likely to lead to discoverable evidence what his opinion is on a iaw that's been passed by the legistature of Florida. MR. EDWARDS: Just so the record is clear, i don't know that we did this last time, but it's been alleged in the complaint -- it has been alleged in several complaints that Jeffrey Epstein particularly prays on vulnerable disadvantaged females, underage females, and that in order to gain access to the muttitude of underage females, October 15, 2009 179 he utilizes various paopie, schedulers, pilots, handlers and other associates and co-conspirators that have a similar mentality; that is, people that do not agree with laws related to sex abuse and abuse of children. And that's why this line of guestioning regarding whether or not this witness has a motive or a bias or was involved in conversations related to his motive or bias, to continue to work for Jeffrey Epstein or believed the same beliefs of Jeffrey Epstein, is at feast teasonably calculated to the iead the discovery of admissible evidence, and that is the argument at least along those lines being made to the judge regarding these questions. MR. CRITTON: Can we talk for just one minute?} Because maybe -- can | talk with — well, | know t can talk with Bruce. Let's just take a break. {A break was had at 2:45 p.m.) MR. EDWARDS: We're back on the record. Do you have the same position? MR. REINHART: Let me say this: He previoush said he would have never allowed anything on the plane to be done iegally. ff you want to ask if he agrees with the law applied by the legislature ~ do you agree the law passed by the 180 state of Florida should be compiled with? THE WITNESS: ! don't know what the law is. BY MR. EDWARDS: Q. Okay. The laws In piace to protect children under the age of 18 from baing sexually touched, fondled, molested by people over the age of 24, do you agree with those laves? A. Yes. Q. And you agree that persons who commit a violation of those laws should be prosecuted? A. Persons that do that. MR. CRITTON: Form, BY MR. EDWARDS; Q. Yes, persons that do that. A. Persons that do that, absolutely. Q. And if you were to receive confirmed ~ what you would perceive as confirmed information that Jeffrey Epstein was one of those persons, would you continue to be employed by or alongside of Jeffrey Epstein? MR. CRITTON: Form; specutation, THE WITNESS: You're assuming that there's guilt, BY MR. EDWARDS: Q. No. ?m saying, hypothetically, if you were convinced that Jeffrey Epstein was guilty of those acts Larry Visoski WOAH RW 181 which he pled guilty to — MR. CRITTON: Form. MR. REINHART: Can we -- for purposes of your hypothetical, what facts do you want him to assume are true? You said the facts to which he pied guilty, but the witness already said he doesn't know what he pied guilty to. He knows the charge he doesn't know the facts. BY MR, EDWARDS: Q. Solicitation of prostitution of a minor, somebody under the age of 18, MR. EDWARDS: That's the charge, right, Solicitation of prostitution of a minor? MR. CRITTON: No. | think you've got it wrong. I'll object io the form. MR. EDWARDS: Okay. BY MR. EDWARDS: Q. Then weil handle the question this way: if you were to believe based on information and evidence that Mr. Epstein engaged in sex or some form of sex acts with people of the age range of 12, 13, 14, 15 years old, would you continue your employment with Mr. Epstein? MR. CRITTON: Form; specutation, THE WITNESS: | wouid certainly be speculating 182 and | have to discuss it with my wife long and hard. i don't think | could give you a correct and honest answer at this time. BY MR. EDWARDS: Q. Okay. Given the allegations that have been made in this case, is this something that you have discussed with anyone other than your attorney? A, No, not really. Only from the fact that they're allegations and there's still a lot more work, I'm sure, to be discovered. MR. CRITTON: Let me put on there, for the — if this deposition is not typed -~ and we request it ~ I'd like at least this portion where Mr. Edwards’ last question back about five pages worth, so just if you could mark if from this page back about five pages. If nobody requests the deposition, I'd just like those five pages. MR. EDWARDS: I'm going to request the deposition, so... MR. CRITTON: Okay. We'll mark this then, so you could tell me where itis, approximately. BY MR. EDWARDS: Q. ts there a reason why you have not discussed with Jeffrey Epstein the allegations that have been made} DIATE one © 11 12 13 44 is 16 17 18 19 20 24 22 23 24 28 October 15, 2009 183 against him and the allegations contained within many of these civil complaints on behalf of girs who were under the age of 18? Is there any reason why you haven't discussed that? MR. REINHART: If that's based on conversations you had with your lawyer, then don't disciose what you and your lawyer taiked about. BY MR. EDWARDS: Q. Correct. A. thave not spoken to Jeffrey about any of this, and it was my understanding that is illegal to have conversation about this, So I've never presented any questions to him reference this case or any others, Q. it was your understanding that it was illegal to talk to Jeffrey Epstein about the allegations made against Jeffrey Epstein? A. Yes, or anything to do with the case. That's why we never discussed any portions of it. Q, Okay. So - A. i may be wrong in that assumption, but ! don't - Q. So the reason why you haven't discussed this with Jeffrey Epstein is you believed it was illegal? A. Correct, yes. Q. Who led you te believe that it was illegal? 184 MR. REINHART: Again, if it was a discussion you had with any lawyer, then you can just give a name, don't give a discussion of the conversation you had. THE WITNESS: |t was my own assumption. | mean, just basic criminal knowledge of knowing you're not supposed to --.you know, if somebody's in trial or in a deposition or whatever, | don't — 1 didn't think it was appropriate to discuss the maiter with them. BY MR. EDWARDS: Q, Okay. So the next two visits and | think the last two visits we'll talk about are on 9/6/2008. Actually, it looks like you visited him twice in one day; is that right? A. I don't think that's possibie. | mean, that will show how accurate the court record is. There's no! way. Q. You woukin't have visited him twice in one day? A. No. | think there's only one visitation per day. Q. Okay. And it looks like the same visitors éach time, except that it says for period three and then} the next one’s for period four. So there are two Larry Visoski COVA eR Whe 185 different periods. Was there ever a time when they allowed you to stay for more than an hour? A. No, not to my knowledge. Q. Okay. So again, it's Sarah Kellen and Nadia Marcinkova, same questions; Did you ever ask them theit involvernent with Jeffrey Epstein? A. Absolutely not. Q. And again, what was the discussion with Jeffrey Epstein along with Sarah Kellen and Nadia Marcinkova?: A. On the last visits, i was mainly airplane stuff and tater on in the visitations, we were advised that you could leave earty, so i would only stay for maybe 30 minutes and then, you know, Jeffrey would continue his conversations with them and then } would just wait outside. Q. Okay. A. So | would do my business with him tatking about airplanes or whatever | had coming up and then exit. Q. And then why did you stop visiting him in jait after that September Sth, 2008, visit? A. 1 was never called back to visit. Q. Okay. Well, shortly after that then he was on work release? 186 A. Well, that’s true. Q. Right? A, Yeah, Q. So the next times you would have gone to see him would have been at the Florida Science Foundation, where we talked about earlier? A. {ve seen him there, yes. Q. Okay. And in fact, I think you said you saw him 20 or 30 times — A. Sure. Q. - over the last two years, last year and a half or so? A. Yes. Q. And how long would you stay each time at the Florida Science Foundation and talk to him? A. Like my original answer, ten, fifteen minutes. Q. Okay. And how frequently would you talk to Jeffrey Epstein while he was at the Fiorida Science. Foundation? MR. REINHART: fm sorry, you're talking in person or all conversations? Because he testified he had phone conversations and personal visits. BY MR. EDWARDS: Q. | was actually talking about phone conversations. So when you would call him on the CMV AKRUDH 2009 October i5, 187 telephone, how frequently would you talk to him? How frequently during a given week? Yeah. More specific? Sure. Depends upon what's going on that week. . I mean, is it somebody you would talk to him every day? A. No. Q. Allright. Weil, at that point in time, he's going from the jaif fo the Florida Science Foundation and back, and if you're not going to see him in person, and you're not corresponding by e-mail, then would you correspond by telephone, that either being you caii him or he called you? A. Yes. Q. And, you know, in any given week, what was the typical week like? | mean ~ A. How many times? Q. Yes. A, Maybe once in a week, sometimes twice in a day. | mean, it would vary. There was no routine, Q. And what would the conversation be? A. Mosily we discussed audio and video, TVs, hom theaters. [t's a niche of his and we're constantly 188 looking at new items that are out there, you know, what's the biggest LCD flat screen out there. Q. Okay. And since he's been out of jail and on community control or house arrest or whatever it is, where he’s located at his home now, have you visited hi at his home? A. Ihave been to the home. | havent visited, but | have had work to de there. Q. And have you cailed him on the telephone thera? A. Once I think I've called the house. Normally he calls me because it's usually he needs me to do ‘something. Q. And what have those conversations been about since he's been out of jail? A. Let's put a stereo in the gym, let's put a TV in the fiving room, let's put a bigger stereo in the gym, let's put a bigger, bigger stereo in the gym, let's go redo what we've done. It's always audio. He's a very audio file person. Q. Do you know of any other modifications that he's made to the house at 358 E) Brillo since the tine that he went into jail? MR. CRITTON: Form; predicate. THE WITNESS: Meaning? Be more specific. >OPo>r Q Larry Visoski October 15, 2009 189 191 1 BY MR. EDWARDS: 1 A. No, I don't. It's not my airpiane. 2 Q. Structurai modifications, architectural 2 Q. We still don't know whose airpiane it is yet. 3 modifications? 3 The time when you took Mr. Epstein to Miami in the fast 4 A, Starting what date? 4 — month, do you know which altorney he was going to see? 5 Q. June 36th, 2008. 5 A. No, } do not, 6 MR. REINHART: | think the question on the 6 Q. And do you know whether it was related to 7 table was have you observed any structural changes 7 civil cases or criminal cases or anything else? 8 to the house at El Brillo since Mr. Epstein went to 8 A, No idea, 9 jail? 9 Q. Do you know where the location was in Miami 10 THE WITNESS: Structurai changes? 10 that he was going to? 11 BY MR. EDWARDS: ih A. No, ido not. 12 Q. Structural, architectural, anything like that, 12 Q. Other than yourself visiting Mr. Epstein at 13 changes to the house, to the interior of the house since 13 the Florida Science Foundation, are you aware of any 14 he went to jail? 14 other visitors, people that visited him? 18 A. No. I mean, ifyou could be more specific, £ 15 A. No, Pm not. Just whoever was there during my 16 — mean, you're talking furniture or? 16 visit, ‘ uy Q. I've never been in the house, so | can't be 17 Q. Okay. Are you aware of a corporation named 18 much more specific. Have you noticed any changes from} 18 the Zorro Trust? 19 before he went fo jail to afer he went to jail, the 19 A, I've heard the name, 20 inside of the house, that you could be specific about? 20 Q. Ard is that something that you've heard 2b A. No, | can't be specific. 21 relative te your involvement with Jeffrey Epstein? 22 MR. REINHART: Can | talk to Me. Visoski fora 22 A. Yes. | mean, { don't even remember where | 23 second? 23 heard Zorro Trust. | have no definition of it, but { 24 MR. EDWARDS: Sure. 24 know the name is out there. 25 (Off the record discussion } 25 Q. Okay. Is that a company that you balieve is 190 - 192 - MR. REINHART: | think Mr. Visoski can expand 1 affiliated or related to Jeffrey Epstein in some way? 2 on his previous answer. Why don't you expand, 2 A. [have no definition. | don’t know whe it is. 3 THE WITNESS: Can we go back to that one? 3 Q. Do you know how you heard about it? 4 BY MR. EDWARDS: 4 A. Idon'tremember. That's going back in the 5 Q. Sure. The question dealt with the structural 5 early days of when Zorro existed. 6 architectural changes you're aware of. 6 Q. Who was at the Florida Science Foundation when] 7 A. There has been a kitchen extension, but when 7 ~~ you would meet with Jeffrey Epstein on these meetings? 8 you asked the question, i was unaware of when that 8 A. Sarah would be there. 9 actually took place. So to be accurately answering you! 9 Q. Anybody elise? 10 question, | know there’s been a kitchen extension. f 10 A. Story would be there on occasion. That's 11 don't exactly know when that transpired, but... 11 pretty much it. 12 Q. How do you know about the extension? Howdoj 12 Q. And would they de in the same room with 13 you know this happened? 13 yourself and Jeffrey Epstein when you had conversations 14 A. Eknew what the kitchen fooked like before and 14 with him? 15 after the extension and [ don't ~ | thought it was 15 A. No, not really. Not particularly, 16 during the hurricane season when they actually did that; 16 Q. They wouid just be at the tocation?: 17 extension. 17 A. Sure, yes. 41s Q. Who made you aware of it? 18 Q. Anybody else that worked there or was 19 A. Nobody. | just walked in the kitchen and 19 affifiated with the Florida Science Foundation that you 20 noticed a bigger room than what it was. 20 know of? 21 Q. Allright. Do you know who Martin Nowack is? | 21 A, Notte my knowledge. | mean, | do my business 22 A. No. 22 and getin and get out. 23 Q. Do you ever remember him being on your 23 Q. Can anybody ather than Jeffrey Epstein have an 24 airplane, or that name of somebody being on your 24 office at the Florida Science Foundation? airplane? A. Not that | know of. Larry Visoski —— October 15, 2009 193 195 4 Q, Allright. And were you deeded the property 1 Q. Well, we've just described this wide array of 2 that we spoke about earlier on the New Mexico ranch? is 2 cars that Jeffrey had for people to use ~ 3 that deeded to you? 3 A. Well, you said for him to use. 4 A. Yes. 4 MR. CRITTON: Hold it. $ Q. And has it been since back in, I think you 5 BY MR. EDWARDS: 6 — said 1998 or 1999 or whenever it was? 6 Q. |s there a reason why? 7 A. Yes. 7 MR. CRITTON: Wait. You guys are both tafking a Q. Okay. And do you know — and did you build a 8 ‘over one another. You need to fet him wait and 9 house onit then? 9 finish his question because if | want to assert ar: 10 A. Yes, I did. 10 abjection, neither one of you gives me 4 chance, 11 Q. Okay. And that's a property that | think you ak which may be the plan. Form. 12 said you have a mortgage on it, that's a property that a2 MR. EDWARDS; Yeah, we have a conspiracy 13 you pay -- you mortgaged that property? 13 against you. 14 A, Yes, sir. a4 MR. CRITTON: | knew it. [ll take that as an 15 Q. Allright. And as well, the home you own 15 admission. 16 here, you have a mortgage on that property as weil? 16 BYMR. EDWARDS: 17 A. Thatis correct. i? Q. Is there any reason — did Jeffrey say that he 18 Q. Allright. Are you familiar with a vehicle, a 18 wanted that vehicte to use or to be parked at his house? 19 Chevy Suburban 1500, year 1999? 19 A. No. 20 A. Do you have a color? 20 Q. Then how did It come about that you started 21 Q. No. E can tell you the plate. | could tell 21 parking that vehicle at his home? 22 you the VIN. Chevy Suburban - Chevy Suburban 1500, 22 A. | think the origination of that came when 1 23 registered to Larry Visoski? 23 started using the Hummer, that the Suburban was parke: 24 A. That would be mine. That's a white one, then, 24 in my driveway and | wanted to get it out of my driveway 25 Q. Okay. When did you get it? 25 as an eyesore. So hence, | decided to let people at the 194 196 4 A. {mn guessing. It was probably two years old 1 house drive it as a grocery shapping car or something, 2 when tgotit. Maybe 99. Maybe '01, '02. 2 orjust as extra transportation, a Q. Something you still drive? 3 Q. Okay. But when you go te park the car at 4 A. Occasionally. Its kind of a beat up car now, 4 somebody else's house, you have to let them know, Hey, 5 soit's Kind of a knock around. 5 I'm giving you the keys? 6 Q. Best of your knowledge, it stays parked at 6 A. Mm-hmm. 7 your house? 7 Q. Who did you give the keys to? 8 A. Recently it's been in Jeffrey's driveway, 8 A. don't know if | gave the keys to anybody. 1 9 but... 9 may have just feft them on the counter there and told 10 Q. Why? 10 — Yanush this is an extra car if you guys needed it to run 11 A. Just for an extra car to use. 11. around because it was an eyesore at my drivaway. 42 Q. For Jeffrey to use? 12 Q. Are you familiar with a Mercedes-Benz SUV 13 A. No, Tmean, for anybody that would come to 13° 19997 14 the house to heip out. igor { think has driven the car 14 A. Say that again. 18 before. 15 Q. Mercedes SUV, 1999 registered in your name? 16 Q. How did it come about that you began to park 16 AL Yes. 17 __ the Chevy Suburban, the 1999 car that we're talking 17 Q. And what car is that? 18 about, at Jeffrey's house? 18 A. That's my car ~ my wife's car. 1s A. When there was more activity here in West Palm 19 Q. Does that stay at your house? 20 Beach. We were never usually coming here that often, 20 A. Yes. 22 and now with alf this going on, with Jeffrey being in zy Q. And that's the car that's parked at your house 22 town longer, we needed more cars and transportation. Sq 22 now? 22 my car was just sitting in the driveway at home while | 23 A. Yes, 24 was driving the Hummer. So | decided to let them use 24 Q. Are you familiar with a Land Rover, Range 25 the Hummer at the house. 25 Rover Sport 20087 Larry Visoski October 15, 2009 Oeranewne 10 il 12 13 14 > 16 a7 38 is 20 2u 22 23 24 1 2 3 4 = 6 1 8 9 10 11 12 13 14 is 16 17 138 13 20 21 22 23 24 25 Q. Okay. Are you aware of a Mercedes-Benz CLK 197 193 A. Yes. 1 2005 registered in your name? Q. Registered in your name? 2 A. Yes. A. Yes, 3 Q. And whose car Is that? Q. And whose car is that? 4 A. That car also is a Paim Beach house car to be A. That's another extra car for the household to 5 used at the house. use at Jeffrey's house, 6 Q, What does that mean, "a Palm Beach house car” Q. And when was that car purchased? 7 A, It's a car that we park in Jeffrey's driveway A. Last year. 8 for people to use. Anybody that comes to the house can Q. And who purchased that car? 3 select a car to go anywhere, | mean, run errands, go A. itwas purchased in my name. 10 shopping, do whatever they need to do. And that was. Q. By whom? Who purchased the car in yourname?? 11 purchased the same way. It was in my name. A. Well, | put the car in my name, but the funds 12 Q. And the funds came from Jeffrey Epstein? came -from -- they were wired to my account from New 13 A, They were wired to my account. | don't know York. 14 exactly whai account they came fram. Q. From whom, though? A mysterious source just 15 Q. Again, that's a conversation that has to take sent funds? We know that didn't happen, so I'm just 16 place before -- that you have to agree to put a car in trying to elaborate here. 17 your name? A. Jeffrey had paid for the car. 18 A. Yes, yes. Q. Okay. And why did Jeffrey pay for a car and 19 Q. Andis that a conversation between yourself put it in your name? 20 and Jeffrey Epstein that takes place? A. i don't know. 21 A. Yes. G. {mean, you had to agree for this te happen. 22 Q. And what is the substance of that conversation ‘So what was the conversation between you and Jeffrey | 23 that results ina Mercedes-Benz 2005 being placed in that resulted in Jeffrey paying for a Land Rover, a 2008 24 your name? 25 Land Rover and putting itin your name? 25___A._Hejust said we need a fun carforthe house | 198 200 A. I don't recall exactly how the conversation 1 in Palm Beach. came about. He just says we want to buy an ‘08 Land 2 Q. But why put itin your name? Rover and put it in my name. So we did. | didn't ask 3 A. I don’t know. any further questions. 4 Q. You didn't ask any questions about that? Q. Did this conversation happen when he was in 5 A. No, | didn't. jail or after he was out? 6 Q. Okay. Are you aware of a Jaguar X-Type 2005) A. Meaning out on house arrest? 7 registered in your name? Q, Right. 8 A. | forgot about that one, yes. A. When you say “out” | think of the Science 9 Q. Whose car is that? Foundation. On work release, so you have to be more. 10 A. That's a Palm Beach car. specific, il Q. What do you mean “a Palm Beach car"? Q. You tell me what happened, when the 12 A. It's the Palm Beach house car, another run conversation happened relative to where Jeffrey was at 13 around for people to use. the time. 14 Q. And again, that's a conversation that has to A. I'é only be guessing again. | would say this 15 take place that results in a car being placed — probably happened a year ago, maybe less than a year 16 registered in your name? ago. fd have to look. 1 don't remember exactly the —- 17 A. Yes. Q. So it was either at a time when he’s at the 18 Q. Okay. Now we're talking about several cars Florida Science Foundation or possibly on house arrest?] 19 here? A. Itwas — no, it was definitely before house 20 A Yes. arrest. itwas probably during the time of the Florida 24 Q. That are ail being placed In your name? Science Foundation, to be accurate. 22 A, Yes. Q. Okay. Are you aware -- 23 Q. You never at any time ask any questions to A. About eight or nine months ago. 24 Jeffrey Epstein why are you placing these cars in my name? Larry Visoski October 15, 2009 201 203 a A. Idid not, 1 Q. Who drives that car, Ford F-250? 2 Q. So your suspicions were never -- your 2 A, That was shipped to St. Thomas. 3 curiosity was never piqued at all as to why these cars} 3 Q. For who to use and for what purpose? 4 — are being placed in your name? 4 A. Well, that car should have been put under LSJ, s A. My curiosity was piqued. 5 tbe. 6 Q. You never asked him the question, you just 6 Q. What's LSJ, LLC? 7 ~~ agreed to do it? a A. Little St. James. 8 A. That's correct 8 Q. And that's a corporation? 9 Q. That goes for the Jaguar X-Type? 9 A. Yes. 10 A. Yes. 10 Q. Your understanding is that's a corporation 11 Q. Are you familiar with a motorcycle, Big Dog 11 affiliated with Jeffrey Epstein? 12 Chopper Motoreycie, 2003? 12 A. | know it's a corporation. | don't know its 13 A. That is mine. 13 affiliation to Jeffrey. 14 Q, Yours? i4 Q. At this point in time, the way that this car as A. Yes. 15 comes about is through a conversation with yourself and} 16 Q. Registered in your name for a good purpose, 16 Jeffrey Epstein? 17 tight? 17 A. Yes, yes. 18 A. Yes, itis. 18 Q. So fo make some representation that this — 49 Q. Atyour house? 19 that this corporation LSJ, LLC, you're not sure if that 20 A. Yes. 20 has any affiliation with Jeffrey Epstein? 21 Q. You use it? 2u A. I don't have any facts to tie the two. 22 A. Absolutely. 22 together. 23 Q. Allright. Ford F-250, 2008, registered in 23 Q, Common sense would dictate? 24 your name, are you familiar with that? 24 A. Yes, 25 A. it's not registered in my name. 28 Q. Okay. 202 204 1 Q. Okay. So if that's registered in your name, 1 MR. CRITTON: Form. 2 that would be a shock to you? That would be a surprise 2 BYMR. EDWARDS: 3 toyou? 3 Q. Again, that's not a car that you use, the Ford 4 A. Yes, itwould be. 4 F260? 5 Q. There should be ne documentation from you 5 A. No, it’s not even here. 6 — where you would be the registered owner of the Ford 6 Q. And when you say on St, Thomas, is iton 7 F260? 7 actual St. Thomas, oris it on Little St. James? 8 A. What year? 8 A. Na, it's on St. Thomas. it's a work vehicle. 9 Q. 2008. 9 Q. For whom? 10 A. | remember buying that car. | just -- that 10 A. For the workers, for the island. 11 shouldn't be in my name. 12 MR. REINHART: 8e careful to answer his 12 @. What do you mean you remember buying that car4 12 question, | think his question is, is it on 13 A. [do alot—ido all the car purchases for 13 ‘St. Thomas or Little St. James island? Where 14 ~~ Mr. Epstein. 1'm a car fanatic, so for years i've been 14 physically is the car, if you know. 15 the car-shopper. ['m the car fanatic. 15 THE WITNESS: f don’t know for a fact. 16 Q. Okay. But these cars aren't classic vehicles. 16 BYMR. EDWARDS: 17 ~—- These are vehicles that are not being refurbished or i? Q. It's your understanding it's on St. Thomas? 28 anything, they're being driven around town? 18 A. Yes. 19 A. No, but theyre fun. The new Range Rover is a 19 Q. And when you say “the workers," what's going 20 niece car. 20 — onon St. Thomas to where there's workers that need an au Q. This Ford F250, that's a car also that's Patm 21 F-2807 22 Beach — as you would say a Palm Beach car? 22 A. Just moving sand. | don't know the exact 23 A No. 23 detail for it. 24 Q. That's a car that stays at your house? 24 Q. What were you told about the need for this car 25 A. No. 25 tobe on St. Thomas? Larry Visoski October 15, 2009 205 | 207 1 A. They need a work truck. 1 Q. Okay. And by “Jeffrey's boat,” it was 2 Q. Todo what? 2 purchased with Jeffrey's money? 3 A. I don't know what the detail or the — you 3 A. That is correct. 4 know, what the job detail was for the truck. They just 4 Q. Do you know how much that cost? 5 needed a work truck. 5 A. {think it was 60,000. 6 Q. So Jeffrey Epstein tells you they need a work 6 Q. Do you know how much the Ford F-250 cost? 7 truck on St. Thomas and that's the only description that 7 A. Twenty-five, I'm guessing, batipark, 8 —-you'te given? 8 @. Do you mow how much the Jaguar X-Type cost’ 3 A. Yes, to go purchase and get the best deai | 9 A. 11,000. 10 can ona pickup truck, and that's what | did and for a9 Q. Do you know how much the Mercedes-Benz CLK] 11. some reason it got put in my name. iL cost? 12 (Of the record discussion.) 12 A. 35,000. 13° BYMR. EDWARDS: 13 Q. Do you know how much the Land Rover cost? 14 Q, Whose money was used to purchase the truck. 14 A. 68,000. 15 You say yots purchased the truck. | want the record to 15 Q. Do you know how much the Mercedes-Benz S| 16 be clear whether you're purchasing it with your money? 16 cost, that's yours, right? The Chevy Suburban is yours 17 A. No, this was wire-transferred. itwas a—! 17° aswell? 18 — don't remember how that -- | think it was a wire 18 A. Yes, ! remember how much those cost too. 49 transfer or a check was Fed&xed from the New York offieg 19 Q. is there another boat, 35-foot Donzi 20 te pay for that, That should not be in my name, is what 20 powerboat, 19997 21 7m getting at. [Ul certainly change that, but! 2. A. That's the one | thought you were talking 22 thought you were -- 22 about originally. 23 Q. | understand that. 23 Q. That's the same boat? 24 A, No, I'm being -- yeah, ! didn't. 24 A. That's the same boat, 25 MR. REINHART: There's no question. 25 Q. Is there any other boat that's registered in 206 208 4 BYMR. EDWARDS: 1 your name? 2 Q. 34-foot JVC Powerboat, 2000, owner LSJ, LLC. 2 A. No. 3 registered to Larry Visoski. Do you know that? 3 Q. Did you know that in -- let me ask you this: 4 A Yes. . 4 Do you have a 2003 Ferrari F75-M? 5 Q. You knew that that boat was registered in your 5 A. No. 6 neme? 6 Q. Any reason why the car is registered in your 7 A. Its registered to LSJ. It's Jeffrey's boat 7 name and the asking price is $189,000 being sold in New 8 that we keep here in West Palm Beach. 8 York? 9 Q. And do you keep it at your home? 9 A. That car is not registered in my name. 10 A. No. 10 Q. I fits registered - 12 Q. Do you know that the registration is to your 11 A, The ad is in my name. 12 home? 12 Q. Whyis the ad in your name? 43 A. {ts used in my home adress, yes. 13 A. Because | was trying to sell it. 14 Q. Why was that done? 44 Q. Why were you trying to sell it? is A. We were eventually going to ship it out to is A. twas Jeffrey's car and we didn't want 16 — St. Thomas for it to live, but since Jeffrey's here, 16 anymore. 17 we're keeping it in Florida, and when we ship the boat 17 Q. Why would he put his pilot in charge of 18 over, we will change title to the Little St. James 18 selling his Ferran? 19 address. 19 A, Because | bought it. 20 Q. Whatdo you mean “since Jeffrey's here we're | 20 Q. How much did you buy it for? 21 keeping it in Florida"? What does Jeffrey being here al A. 79,000, Now, wher] say "| bought it," it 22 have to do with keeping a boat that's registered in your; 22 was his money. | was the one that negotiated it, to be 23 name and to your address — 23 clear. twas his car for use in New York. 24 A. Welt, | have access to use the boat, you know, 24 Q. Are you aware of the Zorro Trust winning an. here in Florida, but it's Jeffrey's boat. 25 86 million-dollar Power Ball lottery in 2008? Larry Visoski OPRAH RWNe 209 . No. MR. GRITTON: Say that again. MR. EDWARDS: The Zorro Trust winning an 85 million-dollar — claiming the ticket for 85 miflion-dollar Power Bail ficket in 2008. THE WITNESS: No. BY MR. EDWARDS: Q. Have you ever listed your employer as Ghislaine Air in making political contriputions? A. Emay have. % Q. Did you know that you had made political contributions -- A. Yes, have. Q. -- fisting your ~ A. tneeded a company name for that event, and | had put Air Ghisiaine. Q. And NES, LLC wouldn't do? A. ‘didn't think of it at the time. Q. Did somebody tell you to use Air Ghisiaine rather than the company that has been paying you? A, No. Q. You just chose to use an empioyer that isn’t actually your employer, nor have they ever been? A. Irepresent Air Ghislaine, JEGE and Hyperion as chief pilot, so [ consider those reaily the companies 210 that | work for and never really associated myself with NES, LLC as my realistic employer. So when | go toa convention, an aviation convention, and somebody says. who do you work for, | use the name JEGE because that's, the name of the Boeing company. Q. But when | sit here and ask you who you work for, you give me a different answer. A. You're asking for the absolute correct answer, which ig where my paycheck comes from, which is NES, LLC. | probably have used that twice in 17 or 18 years as my employer. Q. Do you know Dana Burns? A. | know the name, yes. Q. How do you know her? A, I've seen her on the airplane a coupie times. Q. Somebody that you know to be involved romantically or sexually with Jeffrey Epstein at any time? A. | don’t know that, Q. Are there any other cars, vehicles, items, other things that are registered in your name that are actually Jeffrey Epstein's? A. No. You've actually covered them ail and actually shed light on some that i did not realize, tike that Ford. October 15, 2009 MR. REINHART: Mr. Edwards, he needs to expand upon one earlier answer he gave when you asked him if he knew anybody else who worked at the Florida Science Foundation. BY MR. EDWARDS: Q. Okey. A, My wife worked there, When you used the words "worked there” -- or not referring to her as a past tense, but she worked there when it first opened answering the phones, What's your wife's name? Eileen. How does she spell that? EA-L-EE-N, Same last name as you? Yes. How jong did she work there? A month, maybe. And she was answering the phones for the Flerida Scienca Foundation? A. Yes. Q. Do you have a good relationship with your wife? A. I think so. Q. You still don't know what the Florida Science 212 prprerpre Foundation does? . No, because she doesn't. . She doesn't know what it does either? . We never talked about it. . You never talked to your wife about what she . No. MR. CRITTON: He knew she was answering phones. BY MR. EDWARDS: Q. Do you know of any other empioyees, friends, agents, relatives of Jefirey Epstein who he places his property in their names, registers them in his names or anybody etse? A. Notto my knowledge. | don't know, Q. To your knowledge, you're the only person? A. ['m the onty one f'm aware of. Q. And with respect to minor gitls being on the airplane, that being under the age of 18, how many times would you say that you have flown giris into the country, into the United States where you have given a date of birth to Customs of somebody on the airplane that is under the age of 18? A, Td have to look at Right records to verify or give you a correct answer. I don't know any to my Larry Visoski October 15, 2009 213 1 knowledge at this point. 1 2 Q. What flight records would you have to look at? 2 3 A. The passenger manifests. 3 4 Q. Passenger manifests would have the date of 4 5 birth on it? 5 6 A. No. It would have a name, but | don't have -— 6 7 Q. But at some point in time you remember peopte, 7 8 minor date of births, coming inio the country and that 8 2 being tumed over to Customs? 9 ie MR. CRITTON: Form, 10 uz THE WITNESS; | don't remember anybody it 41z transporting on the alrpiane from the country back 12 13 Inte the U.S, that was a minor, to my knowledge, 13 14 BY MR, EDWARDS: 14 1s Q. Okay. Within the country, minors flying -- as 16 A. I don't know. 16 ay Q. -ona plane? a7 18 A, don't know dates of dirth. 18 is Q. And any people that you knew to be minors on 19 20 the airplane, were they always accompanied by parents or| 20 Zi were there minors on the airplane that you're aware of 2b 22 that were not accompanied by parents? 22 23 A. ‘didn't know either way. I mean, people 23 24 — would get on the airplane and get off the airplane. | 24 25 could telt you there were times people would get on that | 25 214 1 I didn’t even know were on the airplane. Cur focus is 1 2 upfront. 2 * Q. Was there a massage table on the airplane? 3 4 A. Which aircraft? 4 5 Q. On any of them? 5 6 A. The Boeing used to have a table on there, but 6 7 itstayed in the same spot and appeared to be never r 8 used. 8 9 Q. Okay. So to the best of your knowledge, you 9 10 have no knowledge of that massage tabie on the airplane} 10 11 ever being used? qi 12 A. Correct. 12 13 MR, EDWARDS: | don’t have anything else. 13 14 CROSS (LARRY VISOSKI) u 15 BY MR. CRITTON: 15 16 Q. Mr. Visoski, } have just a few questions. You 16 17 were just asked about a massage table on the — any of 7 28 = Mr, Epstein's airplanes and you said there was a massage 18 12 table on the Boeing? 19 20 A. Yes. 20 ai Q. Okay. Was there atways a massage table on the 21 22 Boeing or just for a period of time? 22 23 A. dust for a period of time. 23 24 Q. Alf right. And who's responsible for cleaning 24 25 up the aieplane after Mr. Epsiein and/or the guests 25 Ltt ret Poe anim jon anne nrunenntnrwrannarnnnnaen 215 leave? A. Us as the crew. Q. Okay. So if a massage tabie had ever been used, it would have been you and the crew who would have been responsible for either taking toweis or doing something with the massage table? A. Absotutaly. Q. And if | understood your testimony, you never ‘Saw a circumstance where it appeared to you that the massage table had been used in any manner; is that correct? A. Thatis correct. it stayed in the same location since the day it was put on there. Q. You were asked a bunch — a number of questions about Mr. Epstein, I'l use this — Mr. Epstein és the person who directed you generally urless one of — someone else who worked on his behalf calfed you and asked you to, say, set up a time to leave or pick up luggage, et cetara. My question to you is this: Have you flown in the past for other private individuals like Mr. Epstein, i.e., as distinct from a commercial? A. Yes, i have, Q. And approximately have you flown for four, ix other private individuals over the years? 216 A. Three. | had a short career as far as transferring of owners. Q. In temms of transferring to the other owners, ‘separate and apart from Mr. Epstein, again, every individual is different, but was your relationship really any differant with any of those other individuals? That is, you were in essence -- you were hired to perform a specific task: Fly an airplane to get from Point A to Point B and get the people there safely? A. My first job, corporate-wise, was for an owner in Miami and 1 was hired as a pilot, but yet, | would go to his house and maintain a boat that was in the back of his house above and beyond my cail of duty because | ad] an interest in boats. It's just something | like to do. But | always treated Mr. Epstein like any of the other ptior clients that | had as owners. 1 knew that | was not afraid to work for a living, and they understood that. Q. And it sounds like at least the first owner that you worked for asked you to do similar things that you've done for Mr. Epstein, such as take care of a boat ‘or purchase a boat or maintain the boat? A. Sure, absolutely. Q, So your relationship with Mr. Epstein with Larry Visoski October 15, 2009 COV AK RW il 12 13 14 4s 16 17 18 ig 20 22 2 23 24 25: 247 219 regard to if you bought boats or you bought cars on his 1 LM? behalf, that's very similar to your prior experience 2 A. No, i have not. with working with another private individual? 3 Q. Did Mr. Edwards, in approximately four hours, A. That is correct. 4 little over four hours of questioning, ever ask you one Q. In terms of the records, the manner in which 5 question about L.M. that you can recall? you flew the plane or — i don't want to say flew the 6 A. Not that f recail. plane, but in which you operated and maintained the 7 @. Have you ever heard the name E.W.? Did you plane for Mr. Epstein are substantially the same you've: $ ever know someone named E.W.?7 done with other private individuals? 9 A. Never heard that name. A. Right, exactly the same. We wouldn't treat 10 Q. In approximately four-and-a-half hours of Mr. Epstein any different than any prior — previous 11 questioning by Mr. Edwards, did he ever ask you about jobs that | had. It's the same routine we carry over 120 EW? and that's why we're good at what we do, We take care} 13 A. No, he did not. of the airpianes to the best of our ability. 14 Q. In approximately the — are you familiar with Q. Is your focus as the pilot, as the captain of 15 an individual by the name of Jane Doe(S.R.)? both of the airplanes when you took over that 16 A. [never heard that name. responsibitity a number of years ago, is it your 7 Q. in approximately four-and-a-half hours of obligation fo get the passengers there safely-- onboard | 18 questioning by Mr. Edwards, did he ever ask you and safely to the destination and then retum? 19 questions about Jane Doe(S.R.)? A. Yes, that was always job number one. 20 A. No, he did not, Q, And most of us have had I'd say a much more 21 MR. CRITTON: That's all ! have, substantial experience in fiying commercial planes and|; 22 MR. EDWARDS: | only have two questions ba: tarely see — in fact, | can't remember the last tine 23 ‘on what your testimony just was to Mr. Critton. particularly after 2001 | saw the pilots coming back 24 into the cabin shaking hands and helping distribute the | 25 218 220 $nacks of liquids. Maybe I'm not on the same flights i REDIRECT (LARRY VISOSKI} that some of the other lawyers here are, but | assume 2 BYMR. EDWARDS: you fly commercial from time to time? 3 Q. You said you had three other peopte that A. Sure. 4 you've flown for? Q. Do you ever see the pilots interacting with 5 A. Three other previous jobs. |'m trying to be. the peaple who are in the back of the airplane? 6 asaccurate. A. No, notatall. They stay at their station up 7 Q. Those are private individuals? front. 8 A, Thatis correct. Q. You got - as the captain of the planes, when. 9 Q. And who are those people? you're flying, you have substantial responsibilities not 10 A. Herb Glimpsure in Columbus, Ohio, and Edward only to the people on the plane, but as well to the air 11 Seltzer in Miami. And then the other was Tom Boyd, and space which you're flying? 12 that was more of a Learjet charter, but he was the owner A Yes. 13 of five Learjets. Those are my only three jobs in my Q. Okay. By the way, we've been here about -- 14 life. for about an hour and fen -- we started about ten. it's is Q. Also weaithy individuals? now 3:30. Did you ever hear the name L.M.? Has 16 A. Big time. Mr. Edwards ever asked you one question about L.M.7} 17 Q. And did you know what they did for a living? MR. EDWARDS: Is the question have you ever; 13 A. Those | did, yes. heard of her or did | ask any questions about her, 19 Q. And did you ever go visit any of those peopie or did you ask both questions and give the same 20 in jail? answer? 21 MR. GRITTON: Form, MR, CRITTON: I'll break them down. 22 THE WITNESS: | know my first individual had MR. EDWARDS: it doesn't matter to me. 23 trouble with the law after | had left. don’t BY MR. CRITTON: 24 remember what it was pertaining to; but no, | never Q. Did you ever meet an individual by the name of! 25 visited any of them in jail, no, sir. ee Larry Visoski October 15, 2009 224 BY MR. EDWARDS: Q. Even the one who had trouble with the law, you! didn't go visit him in jail? A. No, I did not, Q. And did any of them put vehicles or other boats or anything else in your name? A No. Q. Okay. Any of those people ever deed any property or acres or anything like that to you? A. No. Q. Did any of those people ever hire your wife for employment? A. No. Q. And your attorney, is that your attorney paid for by you, or is this somebody that's hired by Jeffrey Epstein? A. {tis somebody that is hired by Jeffrey Epstein. MR. EDWARDS: Okay. MR. GRITTON: One follow-up to your question. RECROSS (LARRY VISOSKI) BY MR. CRITTON: Q. With regard to the private individuals that you worked for prior to Mr. Epstein, what was the longest period of time that you worked for those? 222 A. The longest period of time was five years and the shortest being two years. MR. CRITTON: Thank you. MR. EDWARDS: Weill order. MR. REINHART: Weill read. MR. CRITTON: We'll take @ copy, front page, mini with index. (Witness excused.) (Deposition was concluded at 3:37 p.m.) 223 CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH |, the undersigned authority, certify that LARRY VISOSKI personally appeared before me and was dul sworn on the 15th day of October. 2009. Dated this 22nd day of October, 2009. Wendy Seath Anderson, RPR, CRR, FPR Notary Public State of Florida My Commission Expires: 9/20/2013 My Commission No.: DD 906647 Job #127542 224 CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH |, Wendy Beath Anderson, Certified Realtime ‘Reporter and Notary Public in and for the State of Florida at large, do hereby certify that | was authorized to and did report said deposition in stenctype; and that the foregoing pages are a true and correct transcription of my shorthand notes of said deposition. further certify that sald deposition was taken atthe time and piace hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove eet out, {further certify that | am not attorney or counsel of any of the parties, nor am | @ relative or employee of any attorney or counsel of party connected ‘with the action, nor am | financially Interested in the action, The foregoing cerfification of this transcript does not apply to any reproduction of the same by any means unless under the direct control andor direction of the certifying reporter. E Cated this 22nd day of October, 2009. Wendy Beath Anderson, RPR, GRR, FPR dob #127542 Larry Visoski a uwew 18 wh 12 13 14 18 26 Do 18 19 20 an 22 23 2a 25, 225 DATE: October 22, 2009 70; LARRY VISOSKI Job #127542 fo Robert D. Gritton, dr via transcript IN RE: LM. vs, Epstein Please take notice that on Thursday, the 15th ‘9f October, 2008, you gave your daposition in tha above-referred matter. At that time, you did not waive signature, tis now neoessary thet you sign your deposition, ‘As previously egreed to, the tanscrigt wilt be furnished to you fhrcugh your counsel, Please read the following instructions carsfully: ‘At the end of the transcript you will find an. errata sheet. As you read your deposition, arty changes of corrections that you wish to make should be noted on the errata sheet, citing page and line number of said change. 00 NOT write on the transcript itself. Once you have read the transcript and noted any changes, be sure to sigh and date the errata sheet and retum these pages to me. Ir you do not read and sign tne deposition within 2 reasonable time (Le., 30 days unless otherwise directed) the criginel, which has already been forwarded to the ordering attorney, may be filed with the Clerk of the Court. if you wish to waive your signature, sign your name in the blank at the bottom of this lefter and return itto us. Very tuly yours, ‘Wendy Beath Anderagn, RFR, CRR, FPR ESQUIRE DEPOSITION SERVICES, INC. 515 North Flagler Drive, P-200 ‘West Palm Beach, Florida $3401 | do hereby waive my signature. TARRY VISOSKT 10 ua 12 43 14 15 16 17 18 qs 20 an 22 23 24 2s 2009 October 15, 227 ERRATA SHEET IN RE: LW. VS. EPSTEIN. CR: WMB DEPOSITION OF: LARRY VISOSKI TAKEN: 10.15.08 JOB NO.: 127542 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE. PAGE # LINE CHANGE REASON Please forward the original signed errata sheet to this ‘office so that copies may be distributed to ail pasties. ‘Under penalty of perjury, | declare that i have read my cepostion and that tis tue and correct subject 0 ‘any changes in form or substance entered here. DATE: ‘SIGNATURE OF DEPONENT:, OVYnUeRWN 11 12 13 14 15 16 17 18 19 226 CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH \ hereby certify that | have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed. Dated this day of, 2009. LARRY VISOSKI dob #127542 DEFENDANT BRADLEY J. EDWARDS’S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 20 Certified Copy UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Plaintiff, Case No. 08-80893- CIV-MARRA/JOHNSON JEFFREY EPSTEIN, Defendant. DEPOSITION OF MARK EPSTEIN September 21, 2009 11:30 a.m. One Penn Plaza, New York, New York Jacklyn Lisi Toll Free: 800.211.3376 Facsimile; 954.331.4418 Suite 1300 S15 East Las Olas Boulevard I 4 S | | R k Fort Lauderdale, FL 33301 , www.esquiresolutions.com an Alexander Gatto Company Mark Epstein September 21, 2009" 48 M. Epstein Maxwell and knowing your brother, would that surprise you to hear that? MR. COHEN: Objection. A. I don't know Ghislaine Maxwell. TI mean I know her, but you can tell me anything, it's not going to surprise me. Q@. When you would see your brother and Ghislaine Maxwell, where would you be; at his house, at a function, out to dinner? A. Probably at his house more than anything. Which house would that be? More likely Florida. Do you know how he met her? No. Do you know where she is now? No. When is the last time you saw Ghislaine Maxwell? A. Probably around when my mother died, that's five and a half years ago. Q. Have you ever met Leslie Wexner? No. Have you ever met Donald Trump? ‘ Toll Free: 800.211.3376 <2 Facsimile: 954,331.4418 Suite 1300 E S Ul IRE 525 East Las Olas Boulevard Fort Lauderdale, FL 33301 an Alexander Gaile Company www,esquiresotutions.com Mark Epstein September 21, 2009 49 M. Epstein Yes. Was that through your brother? Yes. Where was that? We flew up on my brother's plane from together. Donald was on the plane. When? Somewhere between 5 and 10 years ago. So we are talking about -- Okay. It's either late '90's early 2000. Probably more like late '90's. Q. Was that the only time you've met Donald Trump? A. Q. brother's? Yes. Which plane was this of your A. Q. I don't remember. Was this one of the big planes, the 7272 A. No. It wasn't that one, no. Q. Okay. How many people were on this airplane? A. It was my brother, myself, Donald, othe pilot the co-pilot. I don't remember -- I Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 S | IRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 an Alexander Galle Company www.esqulresolutions.com Mark Epstein September 21, 50 M. Epstein don't remember if anybody else was on the plane, Q. What was the purpose of Donald Trump riding on your brother's airplane? A, You'll have to ask Donald. I think he wanted a ride back to New York. Q. What was your understanding of the relationship of Donald Trump and your brother? A. They were friends. Q. Do you know how they met? A. No. Q. When you say "friends," how frequently did they associate? A. I have no idea. Q. What was your understanding -- did you -- A. I had no understanding. They were friends. That was my understanding. Q. When they were in the airplane tegether, they talked as if they were friends? A. Yeah, I talked to him like he was my friend. I never met the guy. I ama friendly guy. Q. Were there girls on the plane? i Tolt Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300°~ ES UI I | ' 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 an Alexander Calta Company. www.esquiresolutions.com DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.;: 50 2009 CA 040800XXXXMBAG ATTACHMENT 19 ss, ~ BRONNRSSSGRRESNEScavauasune OBNAMAWNE FNUNNN Ree ee eee ee PAUSGNAPSGCHUAREOHES Page 299 A, Idon't remember, Ma'am. He came from 1 New Albany, Ohio. 2 Q. From New -- 3 A. New Albany, Ohio. 4 Q. New Albany, Ohio, Did he have his own 5 business? 6 A. No, he worked for Mr. Epstein, He will i. maintain ali the computers, 8 Q. Was he there everyday? 9 A. No, ma’am, 10 Q. Do you know whether at that time Mr. oey Epstein had an office in Paim Beach? 12 A. Not outside the house, no, 13 Q. Do you have any knowledge of whether or | 14 not the video equipment was -- and I don't know 45 the technical term, forgive me, but was it the 16 kind of equipment that would record for a certain 17 amount of time and then record over that film? i8 A. I don't know. 19 MR. CRITTON: Form. 20 BY MS. EZELL: 2i Q. You don't know? 22 A. No, ma'am, 23 MR. CRITTON: Just for clarification, I 24 may have misunderstood, but I thought he Page 300 said he didn’t even know the video equipment | 1 existed until he read the FBI report. 2 MS. EZELL: He said he didn't know that 3 it was upstairs and downstairs, I believe, 4 MR. CRITTON: I thought he said he didn’t 5 6 7 8 9 know that it even existed, MS. EZELL: I may be wrong. BY MS. EZELL: Q. Did you know it existed before you read the FBI report? 10 A. No, ma'am, il Q. I'm sorry, then I was wrong. 12 How did you know then that the young 13 technician from Ohio maintained the computers and | 14 the video equipment? 15 A, Because we used to request -- there were 16 always problems with the computers so he came to | 17 the house and he was the programmer. It was very | 18 sophisticated, MR. CRITTON: Form to the last question, move to strike the answer as nonresponsive, BY MS, EZELL: Q. How did you know then that he maintained the video equipment as weil? A. Because he was in charge of computers, Page 301 video, even phones, Q. Would he also repair the televisions if they needed work? A, No. Q. No. Did you have any kind of intercom system In the house? A. Yes, ma’am. Q. And what kind of system was that? A. Tt was standard office equipment, Lucid i Technologies maybe, but It was an Intercom like we ff using right now, MS. EZELL: Just let the record reflect that the witness pointed to the telephone on the tabie that has a speaker phone. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. And did you use that in your work? A. Yes, ma'am, Q. And what did you use it for? A. Mr, Epstein used to page me when he needed me. Q. Did you have one of those phones in the kitchen? A. Yes, ma'am. Q. And was there one out in the staff house Page 302 as well? A. Yes, ma'am. Q. Do you know where others were in the house? A. Probably have like 15 phones. We used to have three in the staff house, one in the cabana, two In the master bedroom, one in each room, kitchen, dining room, Mrs. Maxwell's office, the garage, Q. Where was Mrs. Maxwell's office? A. Under the stairs next to the kitchen. Q. Can you give me some idea of what size space that was? A. It was probably -- we change the floor, ‘Twelve by five, something like that. Q. And was the computer equipment in that space? A, Yes, ma'am. Q. Do you know whether Ms, Maxwell kept the names and telephone numbers of the giris who came} to do massages? A. Yes, ma'am. MR. CRITTON: Form. BY MS. EZELL: Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 1 names and phone numbers? 2 MR. CRITTON: Form, 3 THE WITNESS: Yes, ma'am, 4 BY MS, EZELL: 5 Q. Bo you know if she kept pictures of the 6 girls on the computer? 7 A. Yes, she did. 8 Q. And you know that as well because you 9 happen to see them? 10 A. Yes, ma'am. ul MR, CRITTON: Form to the last two 12 questions, 13) BY MS. EZELL; 14 Q. Were they similar to the pictures that 15 Ms, Kellen had on her computer? 16 MR. CRITTON: Form. i7 THE WITNESS: Yes, ma'am, 18 BY MS. EZELL: 19 Q. Did the pictures that they kept there 20 {ook like pictures that were posed? ai A. They were more casual. 22 Q. Did they took as though the person being 23 photographed knew that they were being 24 photographed? MR. CRITTON: Form. 1 THE WITNESS: No, ma'am. 2 BY MS. EZELL: 3 Q. And what can you tell me about that, what 4 lead you to draw that conclusion? 5 A. They were probably taken in parties in 6 big reception or banquet. 7 MR. CRITTON: Let me offer as a 8 suggestion, not that you have to accept or 9 that you would, you're using the term young 10 girls generically, he has probably seen li many, many young girls, there was no -- 12 you've used it interchangeably with just 13 young girls versus young girls who may have 14 come to -- purported to give a massage and, 15 therefore, that may be a different answer, 16 so that's part of my form objection. 17 MS. EZELL: Okay, thank you. 418 BY MS, EZELL: 20 she had a list of the girls and telephone numbers, 21 I think I asked about those girls that came to 22 give massages, but let me go back and just ask it 23 that way. 24 Did you notice that Ms. Kellen had a list 25 of the girls that came to give massages on her Page 304 19 Q. When 1 asked you about Ms. Kellen whether WONAUAUNE computer? MR, CRITTON: Form. THE WITNESS: Yes, ma'am, BY MS. EZELL: Q. And did she generaily have phone numbers for those girls? A. Yes, ma'am. Q. And were they generally pictures of the Girls? MR, CRITTON: Form. THE WITNESS: No, ma'am. BY MS. EZELL: Q. And did Ms. Maxwell have a list of the girls who came to give massages? MR. CRITTON: Form. THE WITNESS: Yes, ma'am, BY MS. EZELL: Q, Did she have telephone numbers generally? A. Yes, ma'am. MR. CRITTON: Form. BY MS. EZELL: Q. Were there pictures on her computer of the girls who came to give massages? MR. CRITTON: Form. BY MS. EZELL: Page 306 |{ Q. Ms. Maxwell I'm talking about, A. Yes, ma’am, Q. And were those pictures the more casual ones that you described when I asked whether or not the subject looked as though she knew she was being photographed? i MR. CRITTON: Form. THE WITNESS: I'm sorry, can you repeat? BY MS. EZELL: Q. Yeah. The pictures of the young girls | who came to the house to give massages that were #f on Ms, Maxwell's computer, did they appear to have jf been taken when the girls knew they were being photographed? MR, CRITTON: Form. THE WITNESS: I don't think they knew they were being photographed. BY MS, EZELL: Q. I believe you said they were more casual pictures, A. Yes, ma‘am, Q. Did you notice any nude photographs in those pictures? A. Yes, ma'am. Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NEGvenvauawne Page 347 F.E., and I think you told us that you had seen her, you recognized her photograph. A. Yes, I did. Q. On how many occasions did you ever see her at the Epstein home? A. More than three times. Q. More than three? A. Yes, sir. Q. That's as accurate as you can be? A. Yes, Q. More than three? A. More than three. Q. Whether it was four or five you don’t know, but more than three? A. More than three, sir, Q. In terms of F.E.'s age, did you ever ask her what her age was? A. No, sir. WON AUAWNHE Q. Did she appear to you to be someone at 19 least from seeing her and recalling her that she 20 appeared at least to you to be while a young woman | 21 appeared to be someone who was 18 or older? 22 A. No, sir. 23 Q. Okay. Well, did you ever say anything to the police or did you ever -- were you ever Page 348 concemed about that such that you told someone? A. No, sir. Q. Haven't you told the police, sir -- let me strike that, let me ask it this way. In your taped statement that you gave to the police did you not tell them that all of the girls appeared to you to be 18 or above? A. Sir, as far as when all these actions that were taking place I was under an environment that I thought I was going to be -- in other words, I was afraid of any reprisal Mr. Epstein li and Mrs. Maxwell if I say something that is any 12 idea of me because I have this confidentiality 13 agreement, What I saw that they were very young, but I cannot say that they were 18 and old. 15 Q. Right. Let me just take you back to my 16 question again and see if you can answer my 17 question. 18 MR. CRITTON: Could you please read it 19 back? 20 (Thereupon, a portion of the record was 21 read by the reporter.) 22 THE WITNESS: I think I told the police 23 Q. I'm sorry? A. Yes, I did, I told the police, Q. And at the time that you spoke with the police and gave them a statement, isn't ittrue, Mr. Rodriguez, that you were no longer employed by Mr. Epstein? A. Yes. Q. And you understood that you were required to tall the police officers the truth at that time? A. Yes, Q, And if f understood your testimony I believe from July 29th through today, you at no time asked any of these girls how old they were, True? A, No, Q. And as to whether the girls were under 18 or 18 or over 18, you really didn't know one way or the other at the time. Would that be a fair statement? A. Yes. MR, WILLITS: Object to the form of the question, BY MR. CRITTON: Q. On Exhibit 6 there is a person who's Page 350 covered, the lady that Ms. Ezell asked you about I belleve was on the right-hand side of the photograph. There is a young lady on the left-hand side with a black hat on. Do you recognize her at all? A. No, I don't recognize her. Q. Okay, Thank you. With regard to the photograph four that you saw that you think possibly might be A.H., I think you told us that you recall seeing that woman in the sauna at Mr. i Epstein's house on one occasion and she was naked. i A, Yes, Q. Was that near the end of your employment or the middie or the front end? A. Tsaw her on January 2005, sir, and I was terminated in March, so that was two months prior. Q. And did you ever tell anyone that you had seen her naked in the sauna? A. I told Loueila, Q. Okay. And what did Louella say? A. She was surprised, Q. Okay. Did you wake the young lady up in the sauna? A. No. Q. And do you know how old the young lady "21 (Pages 347 to 350) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 18 Original Transcript IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff, vs. Case No. 502008C.A028051 XXXXMB AD JEFFREY EPSTEIN, Defendant. DEPOSITION OF LARRY EUGENE MORRISON TAKEN ON BEHALF OF THE PLAINTIFF VOLUME I Pages 1 to 200 October 6, 2009 10:55 a.m. 515 N. Flagler Drive West Palm Beach, FL 33401-4321 Jennifer DiLorenzo, court reporter Toli Free: 800.211,3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard E Fort Lauderdale, FL 33301 www.esquiresolutions.com an Ale L Gallo Company © mo 10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Larry Eugene Morrison - Volume I October 6 ES l JIR E 515 East Las Olas Boulev! Fort Lauderdale, FL 3330 102 Q. Would any of those girls look extremely youn to you? MR. PIKE: Form. A. Not -- Not that I thought. 0; Not back in 2001, we're talking about? A. Right, right. Q. No. What would Ghislaine Maxwell say to you, if anything? MR. PIKE: Form. A. She'd -- Mostly small talk, just -- She kind of did the business management part of it as far. as, you know, arranging cell phone - I was having cell phone problems with the company cell phone, she would handie things like that, but she would have minor inputs on the interior work. Q. What was your understanding back in 2001 st of the relationship between Ghislaine Maxwell and Jeffrey 18 Epstein? ig MR. PIKE: Form. 20 A. I veally didn't understand it. I thought 21 it was personal - personal and business. 22 Q. When you say "personal," did you think it was 23 sexual? 24 A. I thought maybe they were dating and, you 25 Toll Free: 800.211.3: Facsimile: 954.331.4 suite L an Alexander Catto Company www.esquiresoiutions. Larry Eugene Morrison -~ Volume I October 6, 2009 if know, business relationship too. po po to make an A. A. in New York in the apartment that we stayed in that was -- You do, I read MgO” gee 2 103 Did you know who Ghislaine Maxwell was? Not right away, no, no. Not right away? Right. At some point in time you were curious enough attempt to find out. No, I -- MR. PIKE: Form. -- heard about her and there was a book up know, you're sitting there with nothing to that. Do you remember the name of the book? It was just "Maxwell." Have anything to do with her father? Yeah, it was about him, that's what it was about. I mostly just flipped through looking at pictures, boats, and airplanes and stuff. Q. Back in 2001, the first time you had a real conversation with Ghislaine Maxwell -- A. Q. MR. PIKE: Form. Yes. ~~ what did that conversation consist of, if you remember? 2) Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 | IRE 515 East Las Olas Boulevard Fort Lauderdate, FL 33301 ‘an Alexander Gaito Compsay. www.esquiresolutions.com DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et ai. Case No.: 56 2009 CA 040800XXXXMBAG ATTACHMENT 17 Certified Copy IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION Plaintiff, CASE No. 502008CA028051XXXXMB AB JEFFREY EPSTEIN, Defendant. DEPOSITION OF LOUELLA RABUYO VOLUME! October, 20, 2009 10:10 a.m. 515 N. Flagler Drive Suite 200-P West Palm Beach, Florida 33401 Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard E S I IRE Paim Beach Gardens, FL 33410 www.esquiresolutions.com sn Alexander Gallo Company ober 20, 2 Louella Rabuyo - Volume I October 20, 2009 nO, you 2 més, 6 her 8 ion, 4 that 6 to work -& on taken !1 sporter, ‘4 your 5 "ee: 866.709.87 ile: 561.394.26 Suite 6 140 PGA Boule’ ES 4440 PGA Boulevard Sardens, FL 330" = Palm Beach Gardens, FL 33410 quiresolutions.6° 9 head or shake your head, and she can't take that down. A All right. Q It's also very easy to say uh-huh or huh-uh, but it kind of looks the same on paper, so you can't do that either. I'm going to wait until you finish your answer, and you have to wait until I finish my question, because if we talk over one another, then the court reporter can't get it down. A Okay. Yes, sir. Q All right. So if you don't understand the question, tell me you don't understand and I'll try to ask a better question. A Yes. Q Okay. So you were hired in November of 2004 to be the housekeeper for Mr. Epstein? A Yes. Q And when you were hired, who exactly hired you, who -- let me strike that. When you were hired to be the housekeeper for Mr. Epstein, who did you interview with? A Me. Maxwell. Q Is that Ghislaine Maxwell or just Laine Maxwell? A Ghislaine Maxwell. Q And where did the interview take place? Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ‘sa Alocander Gailo Company www.esquiresolutions.com DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 16 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO:502008CA028051XXXXMB AB Plaintiff, ~vs~- JEFFREY EPSTEIN AND SARAH KELLEN, Defendants. DEPOSITION OF JANUSZ BANASIAK Tuesday, February 16, 2010 10:09 ~ 2:30 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1317 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-423-ae22-b5d3e7 182d1e (561) 832-7506 Page 14 ; 1 Q. Okay. So, I assume then that your wife [ 2 that you are separated from I guess at the time, she 3 didn't come down to Palm Beach? 4 A. No, no. 5 Q. And this is somebody who still lives 6 somewhere other than Florida? ‘t A. Correct. 8 QO. So, you came down in February 2005 and 9 began working. What did you, what did you first 10 start doing for Jeffrey Epstein? 11 A. First I doing? I don't remember nothing 12 special. 13 Q. Okay. Well, were you working -- I will 14 rephrase it. Were you working only for Jeffrey 15 Epstein or were you working also for Ghislaine 16 Maxwell, the other person who interviewed you, or 17 anybody else in the house? 18 A. I guess only for him because she was visiting 19 a few times house, but I am employed by him. 20 Q. Okay. What was your understanding at that 21 time as to the relationship between Ghislaine 22 Maxwell and Jeffrey Epstein? 23 A. They were like partners in business. 24 Q. Okay. What business was that, if you 25 know? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Etectronically signed by cynthia hopkins (607-051-976-2934} Etectronicaily signed by cynthia hopkins (601-051-976-2934) Etectronicaily signed by cynthia hopkins (601-051-976-2934) 2d73a91d-3eaa-42b3-ae22-bd3c7 182d 10 = WN ol 10 41 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 154 | A. No. MR. GOLDBERGER: Form. BY MR. EDWARDS: Q. And have you known, just based on your observations, Nadia to have girlfriends? And by girlfriends I mean girlfriends that she would be intimate with in addition to being the girlfriend of Jeffrey Epstein? A. No. Q. Do you know somebody by the name of Jean Luc Brunel? A. Yes. Q. How do you know him? A. He was in the house like, I guess, a few times. Q. When? A. When? Oi. When was the last time you saw him there? A. A week ago. Q. Today is, what, February 16th, and this is a Tuesday. So, when we are saying a week ago, are you saying it was last Tuesday, Wednesday, Thursday, Friday, do you remember? A. I don't remember the date but he stay maybe three days, I think, in the house. Electronically signed by cynthia hopkins (604-051-976-2034) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-bSd3c7 182d1e6 Page 155 ! 1 Q. So, if he arrived on Tuesday, he stayed 2 through Thursday or Friday and -- 3 A. Yes. 4 Q. Do you know what the occasion was for him 5 to come in town? 6 A. No. 7 Q. Where did he stay in the house last week? 8 A. One of the bedrooms upstairs. 9 Q. And was Mr. Epstein also staying in the 10 house? 11 A. Yes. 12 Q. All right. Did Mr. Brunel bring any 13 company with him? 14 A. No. 15 Q. It was him alone? 16 A. Yes. Cy Q. How did he get to the house? 18 A. I think he has been picked up by Igor at this point. Q. And where did he -- I assume he flew in from somewhere? A. Yes. Q. Picked up from the airport, safe assumption? He didn't just drive to the airport. (A discussion was held off the record.) (561) 832-7500 PROSE COURT REPORTING AGENCY, Electronicalty signed by cynthia hopkins (601-051-976-2934) Electronicatty signed by cynthia hopkins {601-051-976-2934) Electronically signed by cynthia hopkins {601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7 182d1e Inc. (561) 832-7506 Page 156 ; 1 BY MR. EDWARDS: 2 Q. So, do you know where it was that 3 Mr. Brunel flew in from? 4 A. No. 5 Q. Do you know where Mr. Brunel generally 6 lives? I mean is it New York, is it -~ a A. I know that he spends some time in Florida, in 8 Miami, but exactly where he is, I don't know. 9 Q. But obviously he wouldn't fly here to Palm 10 Beach from Miami, right, so he had to be coming from 11 somewhere else you would assume? £2 A. Yes, I assume. 13 Q. Were you told -- similar to the way that you have been describing throughout the deposition, you're told who is coming in town. Were you told he was going to be at the house? 17 A. Yeah. Usually he requires to be picked up, so I know that he is coming. Q. Okay. We'll go through some other instances where you had eccasion to pick him up or 21 break plans, but talking specifically about last 22 week: When were you first told that Mr. Brunel was going to be coming into town? 24 A. I think Igor toid me that he has to go and pick him up. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 20752a91d-3eaa-42h3-2e22-bid3e7182d Ie Page 157 E A: iO’ How did he -- 2 A. It was my day off, I guess, because usually I 3 am the one who pick up people. So, I guess it was my days off and Igor was working, so he went to pick him § up. 6 Q. Okay. It wouldn't be Story Cowles picking at him up? 8 A. No, 9 Q. So, to the best of your recollection Igor 10 picked up Jean Luc Brunel sometime last week from a the airport and took him to the house? 12 A. Right. 13 Ox Do you know what car he took to pick him 14 up? LS A. I think Cadillac Escalade. 16 Q. The black Escalade? 17 A. Yes. 18 Q. And what did Mr. Brunel and Mr. Epstein do 19 for the three day stay when Mr. Brunel was staying 20 at Mr. Epstein's house last week? 21 MR. GOLDBERGER: Form. 22 THE WITNESS: I don't know. 23 BY MR. EDWARDS: 24 oO; Did you interact, communicate with 25 Mr. Brunel? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-a0ez2-b6d3e7 182010 Page 158 } 1 A. Yes. 2 Q. And what did he say as to why he was here? S MR. GOLDBERGER: Form. 4 THE WITNESS: Good morning. How are you? 5 Exchange handshake. And I saw him in the 6 kitchen and he was cooking something and that's 7 te 8 BY MR. EDWARDS: 3 Q. When you say he was cooking something, he 10 was personally cooking? 11 A. Yes. 12 Q. All right. So, this is a house that he is 13 familiar enough with and he is a regular enough 14 guest that he makes himself at home? 15 A. Yes, 16 Q. Okay. And last week do you remember 17 anything in the three-day period that Mr. Brunel was 18 staying at the house that Mr. Brunel did from the 19 time he woke up to the time that he went to sleep? 20 MR. GOLDBERGER: Form. Zi. BY MR, EDWARDS: 22 Q. I mean did go to the movies? Did he go to 23 the beach? Did they just hang out around the house 24 and walk? 25 A. Yeah. I think he walked outside to the beach. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronicaily signed by cynthia hopkins (601-051-976-2934) 2d75a91d-Seaa-42b3-aeZ2-bSd3e7 182die Page 159 f 1 He was swimming in the pool, talking on the phone just 2 what I remember. 3 Q. Okay. During the three-day stay last 4 week, how often were -- I mean, I assuming that he 5 came in town to see Mr. Epstein; is that true? 6 A. Yes. ii. QO. And so the majority of his time during 8 that three days was spent hanging around with 9 Mr. Epstein? 10 A. Yes. 11 Q. All right. Did you see them talking with 12 one another? 13 A. Yes. 14 Q. Where were they talking with one another? 15 A. In the cabana, outside sitting next to the 16 pool. Ly Q. Ali right. And when you said that 18 Mr. Brunel walked to the beach, did Mr. Epstein walk 19 to the beach with him? 20 A. No. 2: Q. Mr. Brunel walked alone? 22 A. Yes. 23 Q. Who else was in the house last week while 24 Mr. Brunel was in the house? 25 A. Nadia, Sarah, and Story, I think. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (604-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d7$a91d-Jeaa-42h3-ae22-bSd3c7 182dte 1 Q. Sarah Kellen? 2 A. Yes. 3 Q. And Story Cowles? 4 A. Yes. 5 Q. Okay. Who else, Igor? 6 A. Igor. I guess that's it. 7 Q. Did you overhear any of the substance of 8 the conversations that Mr. Brunel was having with 9 Mr. Epstein? 10 A. No. 11 Q. All right. What is your understanding as 12 to the relationship between Mr. Brunel and 13 Mr. Epstein? 14 A. I guess they are friends. 15 Q. Okay. In addition to being friends -- 16 well, let me ask this question first: Do you know 17 when they became friends? 18 A. No. 19 Q. You don't know how long they have known 20 each other? 21 A. No. 22 Q. You don't know who introduced them? 23 A. No. 24 Q. They could have met since they were five 25 years old or they could have met five years ago for PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 (561) 832-7500 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42h3-2022-b5d3e7 182016 Page 172 } to Miami. Q. Okay. A. But how long he stay in Miami, how long he stays outside of Miami, I have no idea. Q. And when was that occasion where you know that. Jean Luc Brunel was in Miami or spending time in Miami? A. I think at one point I drove him to Miami. Q. And when was that? A. I think the time he was here in this month of January. I think I drove him back to Miami from, from the Palm Beach, Palm Beach house. Q. Okay. So, that time in January he flies into the Palm Beach airport from some undisclosed or unknown location, you take him to the Palm Beach house, right? A. Right. OQ. How long does he stay on that occasion? A. Maybe three days. Q. And during that three-day period were any other -- did any females accompany him to the Palm Beach house? A. No. I don't remember. I don't recall. Q. Well, maybe this will jog your memory: When you drove him to Miami, did you drive him (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (S61) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-302a-42b3-2022-b5d3c7 18201 A. Yes. 3 Q. ~~ or did you drive him with somebody 4 else? 5 A. Alone. 6 Q. Okay. And where did you take him to in ¥ Miami? 8 A. I don't know. He left -- he told me his car, 9 one of his friends somewhere in Miami Beach, so I 10 dropped him over there and he pick up his car over 11 there. 12 Q. And who is his friend, do you know? 13 A. I don't know. 14 Q. So, his car was in Miami? is A. Yes. 16 Q. What kind of car was that? 17 A. Mercedes. 18 Q. All right. And do you remember where it 19 was in Miami that his car was parked? 20 A. Some -- I don't remember the others, but 21 somewhere in Miami Beach. 22 Q. All right. At a condo, at an apartment, 23 on the side of the road, a house? 24 A. No. It was a private house. 25 Q. A private house on Miami Beach. Do you (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051 -976-2834) (561) 832-7506 2075a91d-3eaa~42h3-ae22-bSdse7182d1e 10 11 12 13 14 15 16 17 18 19: 20 21 22 23 24 25 (S61) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 174 know the name of the person that lived at that house? A. No. Q. All right. In talking about this person Jean Luc Brunel, would -- you said he came here last week. He came here in January. Stayed three or four days each time, two consecutive months. Since Mr. Epstein has been out on house arrest is Jean Luc Brunel one of the people that visits on a monthly basis? A. No. Q. Okay. A. There was no regular visit. It's just occasionally I would say. Q. Okay. So, prior to the January visit, when is the previous time that Jean Luc Brunel was at Mr. Epstein's house? A. I don't remember. I don't remember. Q. Is he one of the people who frequently calls Mr. Epstein? A. Yes. Q. And Mr. Epstein frequently calls him? A. I don't know. Q. Okay. Well, I guess you would only know the calls that come in and you take messages, right? Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601 -051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-Jeaa-42b3-ce22-b5d3¢7 18201 ¢ Page 175 A. Right. Q. How times would you estimate -- I know you told us two times in 2010. Let me ask it this way: In 2010 were there only those two occasions where Mr. Brunel was staying at Mr. Epstein's house in Palm Beach? A. Yes, as far as I remember. Q. Okay. How many occasions, in addition to those two, would you estimate that Mr. Brunel has stayed at the Palm Beach house since Mr. Epstein has been out on house arrest and also staying at that house? A. It's hard to tell. I would say maybe three times. Q. Three times in addition to the two times this year, five times total? A. No, three times total. Q. Okay. So, one time this month, one time last month, and then for the period of time from -- I don't remember when he was on house arrest, maybe July. So from July to December you think that there was only one other occasion when Mr. Brunel was at the house? A. You know, it's hard to remember but I think so. He was maybe totally three times for the last few (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-081-976-2934) Eiectronicaily signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaaAZh3-ae22-b5d3c7 182d1¢ DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-CV-80893-CIV-MARRA/ JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendants. DEPOSITION OF ADRIANA ROSS Volume 1 of 1 Pages 1 through 138 Videotaped Monday, March 15, 2010 10:13 a.m. - 12:42 p.m. U.S. Legal Support 515 Bast Las Olas Boulevard, 3rd Floor Fort Lauderdale, Florida 33301 Stenographically Reported By: Janet L. McKinney, RPR, FPR, CLR Registered Professional Reporter Florida Professional Reporter Certified LiveNote Reporter U.S. Legal Support (954) 463-2933 —-—— 2 4 APPEARANCES: Videotaped deposition taken before JANET L. ON BEHALF OF THE PLAINTIFF: : ‘ FARMER, JAFPE, WEISSING, EDWARDS, McKINNEY, Registered Professional Reporter, Florida EN Professional Reporter, Certified LiveNote Reporter and Suite 2 ic i i sie: baie aitaaes Notary Public in and for the State of Florida at Large ee 524.2820 tojustice.com oy BRADLEY EDWARDS, ESQ. (Whereupon, Witness’s Exhibit | was marked for ON BEHALF OF THE DEFENDANT JEFFREY EPSTEIN: identification.) BURMAN, CRITTON, LUTTIER & ‘COLEMAN, LLP 1 2 3 4 5 inthe above cause. 6 7 8 VIDEOGRAPHER: We are now on the video record, 9 T i i | i | { | Pp i i 303 Banyan Boulevard i ‘Today is Monday, the 15th day of March, 2010. The Tea a ea Haein 1 10 time is 9:13 a.m, (sic). We are kere at 515 East 361.842.2820 eee Las Olas Boulevard, 3rd Floor, Fort Lauderdale, Mpike@bclefaw.com i . i : BY: MICHAEL J. PIKE, ESQ. ' 12 Florida, for the purpose of taking the videotape ON BEHALF OF OTHER PLAINTIFFS IN RELATED CASES: , 3 deposition of Adriana Ross taken in Case Number MRSS TEN © HOROWTIZ, Eo [44 08-CIV-80893, Jane Doe v. Jefitey Epstein, et al. Suite 2218 j 4s The court reporter is Janet McKinney; the see one | 16 videographer is Sean McGuire, both of US. Legal Br STUARTS MERSCELSTEIN, ESQ. ju Support. i; 18 Will counsel and all present please introduce ON BEHALF OF THE WITNESS: i 2 } 19 yourself and the court reporter will swear the EABEN@ WOMEN PAT | 20 witness ai) socdcees toed Ate | 22 MR, EDWARDS: Brad Edwards. | represent the ‘Miami, Florida 33129 ; 22 plaintiff, Jane Doe also "Jane Doe"; EW, "EW", LM, BREE on Loge. an ce ase: jucigagiee 24 MR. MERMELSTEIN: Stuart Mennelstein. I US. Legal Support 125 int J 3| INDEX 1 MR. PIKE: Michael Pike on behalf of Jeffrey | 2 Epstein. ADRIANA ROSS Page | 3 MR. ROSS: And good morning, my name is Alan} . sh } 4 Ross. 1 represent the witness, Adriana Ross. Direct Examination By Mr. Edwards Tobe THE REPORTER: Would you raise your right Cross-Exemination By Mr. Mermeistein i i 6 hand, please. hee ra . An . oe ‘ i | 7 Do you solemnly swear or affirm the testimony eee eee et Be you're about to give will be the truth, and nothing Certificate of Oath 137 ! 9 but the truth, so help you God? Certificate of Reporter 138 | 10 ‘THE WITNESS: Ido. | a2 MR. ROSS: Sefore the deposition begins and in EXHIBITS ; 22 an effort to streamline the process of getting PLF'S a ; 13 through this deposition on behalf of the witness we Nos Desciiption Page 44 have had marked as Wimess Exhibit Number { an 1 Jane Doe 102 v, Jeffrey Epstein 33 ) 5 August 31, 2007 letter from the United States complaint | 16 Attorney's Office addressed to Miss Ross through 2A-2G Telephone messages 62 { 17 her then counsel, Bruce Lyons, which is called a 3 Handwritten notes 12 ; 18 target letter identifying her as a target of a 2H Telephone message 87 | 19 federal Grand Jury investigation in the Southern 4° Gawker.com photo with story 127 | 20 District of Flarida and outlining a number of baz offenses that were the subject matter of WITNESS'S j 22 investigation. No. Description Page | 23 As a result of that, it is anticipated that | 24 some of the questions that may be asked during the Target letter 4 | 25 course of this deposition she may invoke her Fifth 2 (Pages 2 to 5) U.S. Legal Support (954) 463-2933 ODIHRH AR WHE OW ONIHALWNH be ° PRR Pe RB Co2IAaORWRe ny 3 VNRNNN ae.aon-e i 6 8 Q. And whe are you married to? A. Duncan Ross. Q. Allright. And sometime after 2003 if understand you correctly you kept the name Mucinska. until you were able to formally change ft to Ross? A, Correct. Q. Okay. Were you married in this country? A. Correct. Q. When did you come to the United States? A. Fall of 2002. { do not recall exact month, Q. And why? A. Iwas invited by modeling agency on a business Q. What modeling agency? A. Elite Models, Q. And who was the connection at Elite Models that invited you? A. Actually it was my husband, I met him in Europe and at the time he -« he knew that agency and I was modeling in Burope and he showed my pictures and they invited me. Q. How long have you been modeling? A, Since about I was 16 years old. Q. Since 16, so mid-90's? Late 90's? A. Probably around '98, '99, I believe, Amendment privilege against self-incrimination, | 1 And in order to streamline this we've agreed prior t 2 to beginning this that she will simply answer"T. | 3 reflise to answer." The parties will understand and; 4 the record will reflect that she is invoking her i os Fifth Amendment privilege against | 6 self-incrimination. | 7 If there is some other privilege, {| 8 attorney-client privilege or some other objection | 9 that I may have to a question, I'll specifically | 10 state it. But her answer “l refuse to answer" will | 11 be on Fifth Amendment grounds if that's scent 12 to everyone, | a5 visa. MR. EDWARDS: It's acceptable. | 44 MR. MERMELSTEIN; It's acceptable, \ 15 MR. PIKE: Acceptable. } 16 MR. ROSS: Okay. Madam court reporter has \ 17 already marked the exhibit, and [ll leave that { 18 with her. , 19 MR. EDWARDS: Okay. 1 20 | a 22 | 2s i 24 | 25 | THEREUPON: lop t ADRIANA ROSS i 2 having been first duly sworn or affirmed, was examined} 3 and testified as follows: {4 DIRECT EXAMINATION 1 os BY MR. EDWARDS: ; 6 Q. Can you tell us your full — full name. | 7 A. Adriana Ross. 8 Q. Atsome point in time you were known as | 9 Adriana Mucinska; is that correct? i 10 A. Correct. joan Q. And when did that change? ; 12 A. Well, I got married and initially I stayed | 13 with my name and then -- because immigration kind of | 14 made a mistake of not changing my name when I first | 15 came to this country. And at some point when { was | 16 States? removing my conditional residency 1 made sure that this} 17 mistake is corrected. I do not recall exact time when {| 18 that happened. I 19 Q. When were you married? i 20 A, July 12th, 2003. i 21 model? Q. Okay. What's your date of birth? { 22 A. T of October 1983. 23 Q. 10/7/83? | 24 A. Yes. | 25 9 Q. Okay. And what agencies did you model for in Europe? A. Iwas with — in Poland I was with Ricardo Guy that eventually change the name to J and B Models. [ was also represented by Ricardo Guy in Milan. Then on my second trip to Milan an agency called Women. was then represented in Japan by agency -+ oh, that's ~- you just mean Europe or -- Q. Well, you can continue. A. Yeah, Iwas represented in Japan by agency Zucca. I was in South Korea, I do not recall the name of the agency. Iwas represented in Taiwan by Fashion Management. Q. Okay. And these were all agencies that you worked for or worked with prior to coming to the United] A. Notall of them. Some of them I worked — already been United States and traveling. Q, Okay. But sometime around 2002 you were invited by Elite Models to come to the United States to A. Correct. Q. Aud at the time — well, where are you from? A. I'm Polish. Q. Okay. So at the time you were a Polish 3 (Pages 6 to 3) U.S. Legal Support (954) 463-2933 wer HKAVewne 10 citizen? A. Yes. Q. Soin order to come to the United States you needed to get a work visa? A. was invited actually just to kind of get a feeling if I will be suitable. So I came on a business tourist visa which is, { believe, B1/B2, Q. Okay. And where did you first go when you came to the United States, what state? A. Florida. Q. And what city in Florida? A. Miami. Q. And what did you do for your two weeks when you first arrived in Miami, Florida? A, Ido not recalf. Q. Okay, But did you do any modeling? A. Well, like I would see some photographers, the agency would send me like on all calls to see photographers to kind of introduce me as a model. Q. And why did you make the decision to go with Elite Models in the United States when you already = modeling in — A. Unm-hum, Q. ~ Europe? A. Well, you know, just to expand it was - | | 1 | } | i i i : i | i i t | i i | | i i | i | | | 12 something that I did. And I decided to take a year off after I graduated from high school and -- you know, just to expand the modeting -- the modeling, possibilities, opportunities. Q. Where did you graduate from high school? A. In Warsaw, Poland. Q. What year? A, 2002, I believe. Q. And do you have any college? Have you gone to college after that? A. [have an associate degree from Miami Dade College ~ Miami Dade College, and Im pursuing a bachelor degree right now. Q. When did you get your associate's degree from Miausi Dade? A, 2008. Summer of 2008. Q. And you're pursuing a bachelor's degree right now? A, Yes. Q, From where? A. Florida International University. Q. In what? A. Accounting, Q. How long have you been in the accounting i | i i i i | | i | f | i | i | | i i | | i i i | t program? 2 2 3 4 a, 6 4 8 9 Cer naewne 1d ii 12 13 14 15 iy 18 i9 20 21 22 23 24 2s 12 A. Since fall 2008. Q. And when do you expect to graduate? A, Fall 2010. Q. Are you a fulltime student or part-time? A. I'ma full-time student at this time, ~ Q. When you first arrived in Miami, Florida in fall of 2002 did you decide during that two weeks that you were going to stay permanently? A. No. Q. Okay. Did you go back to Poland? A, Yes, [have. F have — I went back for ‘Christmas. Q. Okay. Poor question, Going back to 2002 I'm trying to just understand how it was that -- you came over here on a two-week business visa, buf eventually you ended up staying for a tonger period of time, correct? A. Right. Q. Okay. And how did that come about, just tell me? A. Well, I got romantically involved with my current husband and so when -- you know, we just started dating, we got engaged, and that's how, you know, our relation evolved -- evolved, and eventually, got marris a Q. Okay. And since coming to the United States have you always lived in Miami, Florida? A. No. hed Q. All right. Where else have you lived in the United States? A. New York. Q. Where in New York? A. Manhattan. Q. What was the address in Manhattan where you lived? MR. ROSS: I'm going to advise you to invoke privilege. A, [refuse to answer. Q. Okay, Have you - are you familiar with an address at 301 East 66th Street in New York? A. [refuse to answer. MR. PIKE: May we take a break for a second? May I speak with you? MR. ROSS: Sure. VIDEOGRAPHER: Off the record, 10:22 a.m. (Recess taken at 10:22 a.m.) (Deposition resumed at 10:23 am.) VIDEOGRAPHER; On the record, 10:23 am. MR. ROSS: Brad, let me just interrupt for a moment. 4 {Pages 10 to 13} U.S. Legal Support (954) 463-2933 — 14; 16 1 MR. EDWARDS: No problem. ; 2 A. I'msony, { don't understand your question, 2 MR. ROSS: Justto be sure, when the witness | 2 Q. How long did you live at the 1040 South Shore 3 answers "refuse to answer" to be clear the full | 3 Drive address that you moved into in the fall in 2002? 4 statement that she’s not saying for the sake of i 4 A, Well, since ~ since [ came | lived there, I 5 saving time is that she's invoking her Fifth | 5 elways stayed there whether being in Miami traveling 6 Amendment right against self-incrimination. Just. | 6 back and forth, and I live currently af this address. 7 to be clear. ed Q. Okay. What was the first time that you moved 8 MR. EDWARDS: That's what I've understood all | 8 from that address to live elsewhere? 9 along. | 9 A. Ido not recall, 10 MR. MERMELSTEIN: That's what [ understood. | 10 Q. Okay. I know that you told me you lived in a MR. ROSS: Okay, fine. Go ahead. | 21 New York City and we're not going to discuss ~ I'm 12 MR. EDWARDS: This is just forthe sake of | 12 assuming you're not going to answer a lot of questions 13 brevity — | 13 about New York City, but at what time period did you 14 MR. ROSS: Exactly, 14 move there? Was it right after you got here two weeks, us MR, EDWARDS: -- and Jet's move it on. | 15 year tater? I'm just trying te get a year as to when BY MR. EDWARDS: | 16 you moved to New York? Q. All right. So I'm going to ask the question i 17 MR. ROSS: I'm going to instruct you not fo again, [ don't remember whether you'd responded yet, 18 answer, but are you familiar with the address in Manhattan | 19 A. [refuse to answer, 301 East 66th Street in New York? i 20 Q. Okay. Do you know a guy by the name of Jean A. T refuse to answer. ban Luc Brunel? Q. Okay. How long did you live in well, what | 22 A. Lrefuse to answer. - nas the flest address that you lived in in Miami? } 23 Q. Where are your parents? ‘A, 1040 Sci Shore Drive, Miami Beach, Florida 2a A. They're in Warsawy, Poland, ida, | 2s Q. And sit in the United States balsa e eRe erin encanta 15} 1 Q. South Shore, Okay. | 1 have they come ta the United States? 2 A. Um-hum. 2 A. Yes, they have visited me. 3 Q. Haye you ever had your deposition taken fe 13 Q. Have they ever met Jeffrey Epstein? 4 before? i 4 A, [refuse to answer. 5 A. No. { 5 Q. Have they ever met Jean Luc Brunel? 6 Q Okay. You're doing very well so far, There's | 6 A, Lrefuse to answer. 7 geouple rules 1 didn't explain but mainly because = | 7 Q. Where are you carrently employed? 8 you're doing very well. I just have towaitfor youto | 8 A. [pursue — I go to school full-time, I do not 9 finish your answers you have to wait for metofinisk =| 9 work, 10 my question. We have one court reporter. She can only! 10 Q. Are you also still in the modeling business 14 take down one of us. Give us an answer that we all | 11 though? 12 understand, Nodding of the head or shaking thehead | 12 A. No, I'm not. 13 are easy to do and I get what you're saying, but she i 13 Q. And when was the last time you did any 14 doesn't. Ab-ha or un-ah are things thatare commonly | 14 modeling? 15 said. ‘They look the same on paper. | 15 A. it would be late spring, early summer of 2006 16 If Task a bad question which could happen,as = | 16 went on a trip to Taiwan. 17 already happened and probably witl again, just tell me | 17 Q. And why did you stop modeling at that time? 18 — "Iden't understand the question,” I'l ask it again — | 1. A. wanted ~ I always kind of knew that it's 1g A. Okay. | 19 something that fm going to be doing and I just decided 20 Q. —allright? | 20 to go and pursue a college degree. 21 And I'm assuming that's the address, 1040 ian Q. Okay. Is it something that you ever plan to 22 South Shore Drive, where yon began fivingin fallof { 22 go back to, modeling? 2320028 | 23 A. No. 24 A, Correct. | ss 4 Q. Are you inyolved at all with the modeling 25 Q. How Jong did you live at that address? 12 industry? 3 (Pages 14 to 17) U.S. Legal Support (954) 463-2933 20 1 A, No. 1 Q. And how did -- how did it come about that you 2 Q L mean, helping to recruit models, helping | 2 began working with Jeffrey Epstein? 3 others to reeruit models, anything like that? : 3 MR. PIKE: Form. 4 A. No. o 4 A, Lrefuse to answer. 5 Q. Do you ever ~ do you currently talk to 5 Q. What did Jeffrey Epstein pay you in salary? 6 Mr. Brunet? | 6 MR. PIKE: Form, 7 A. [refuse to answer. fog A. Erefuse to answer. 8 Q. When is the fast time that you talked to i 8 Q. What was the time period that you worked for 9 Jeffrey Epstein? | 9 him? 10 A. [refuse to answer. | 10 A. [refuse to answer. i Q. Do you know a woman by the name of Ghislaine | 11 Q. Why did you step working for him? 12 Maxwell? 12 MR. PIKE: Form. 13 A, Trefuse to answer. ; 13 A. Lrefuse to answer. 14 Q. Do you know someone by the name of Sarak | 14 Q. What initiatly were you hired to do? 18 Kellen? j 15 A. Lrefuse to answer, 16 A. [refuse to answer, | as MR. PIKE: Form. 17 Q. Do you know a person named Nadia Marcinkova?, 17 Q. Has Jeffrey Epstein ever paid you to stay 18 A. [refuse to answer. | 18 quiet or keep quiet about what went on in his house? 19 Q. Did Jeffrey Epstein have anything todo with =| 19 MR. PIKE: Form, 20 you moving to New York City? | 20 A. Trefluse to answer. au A. Lrefuse to answer. aa Q. Have you talked to Sarah Kellen or Nadia 22 Q. Did you ever ive ina place in New York City | 22 — Mareinkova abot the things that went on in Jeffrey 23 owned or controlled by Jeffrey Epstein? 1 23 Epstein's house? 24 A. Trefuse to answer. \ 24 MR. PIKE: Form. 25 ig agency MC 125 A, Trefuseto answer, et 191 au 1 Squared? ; 2 Q. Did you sign a confidentiality agreement with 2 A. [refuse fo answer, | 2 Jeffrey Epstein? 3 Q. Do you know of underage females being | 3 A, refuse to answer. 4 transported into this country to work for the modeling | 4 MR. PIKE: Form. S agency MC Squared? aes Q. Did that confidentiality agreement outline 6 A. Lrefuse to answer. | 6 what you should say to authorities should he be caught 7 Q. Do you know of those underage females being i 7 with underage females? a given work visas and staying at the 301 East 66th , 8 MR. PIKE: Fonn, 3 Street address? : i 9 A. Trefisse to answer. 10 A. [refxse to answer, | 10 Q. Is there another book or manual or written ii Q. Can you say whether you have observed | 11 memorialization of what you, as an employee of Jefire: 12 Mr. Brunel or Mr. Epstein engaging in sex with underage| 12 Epstein, should do if confronted by taw enforcement? 13 females? | 13 MR. PIKE: Form. 14 A. I refuse to answer. j 14 A. [refuse to answer. 15 Q. Do you know where Mr. Brunel lives? ; 15 Q. Are you invoking your Fifth Amendment right 16 A. Erefuse to answer. | 16 because you believe you could be prosecuted? uy Q. Isit true that Mr. Branel stays in the 301 {7 MR. ROSS: Invoke. 18 East 66th address frequently with underage femaies? 1g A. [refuse to answer. 19 A, refuse to answer. { 29 Q. Are you aise invoking because you're seared to 20 Q. Atwhat point were you hired to work for 20 testify against Jeffrey Epstein? 21 Mr. Epstein? , 22 MR. PIKE: Form. 22 MR, PIKE; Form. | 22 A. Lrefuse to answer. 23 MR. EDWARDS: You can still answer the | 23 Q. When did you first learn that Jeffrey Epstein 24 question. Mr, Pike is making a legal objection. i 24 had a sexual obsession for underage females? 25 A. I refuse to answer. | 25 A. [refuse to answer. 6 (Pages 18 to 21) U.S. Legal Support (954) 463-2933 wOInuhrwne 10 12 13 14 16 24 20 24 7 | MR. PIKE: Form, | 1 different than they are here, but are you familiar with Q. Isn't it true that you have seen Jeffrey rope the Florida Statutes that protect children against Epstein sexually interacting with females as young as | 3 —_sexual offenders or sexual predators? 12 years old? ia MR. ROSS: Invoke. A. [refuse to answer, i 5 A. Lrefuse to answer. MR. PIKE: Form, | 6 Q. Let me just read you the lewd or fascivious Q. Is it true that you have observed Jeffrey | 7 molestation statute and then I'm going to ask you some Epstein's sexual obsession to include the age range 12 i 8 questions about it, to17? | 9 It says: “A person whe intentionally touches MR. PIKE: Form. | 10 ima tewd or lascivious manner the breasts, genitals, A. Erefuse to answer. | 14 genital area or buttocks or the clothing covering them Q. Have you ever had sex with Jeffrey Epstein? | 12 ofa person less than 16 years of age or forces or A. lrefuse to answer. i 13 entices a person ander 16 years of age to so touch the MR. PIKE: Form, } 14 perpetrator, commits lewd or lascivious molestation, a Q. Have you ever been paid for sex with Jeffrey | 15 second degree felony.” Epstein? | 16 After hearing that statute isn't that MR. PIKE: Form, I i? something — isn't that a crime that you know A. [refuse to answer. i 18 Mr. Epstein to have committed on an everyday basis Q. Do you know if Nadia Marcinkova had sex with) 19 while you were working for him? Jeffrey Epstein when she was underage? | 20 MR. PIKE: Form. MR. PIKE: Form. | 22 A, Erefuse to answer, A. [refuse to answer. | 22 Q. And that’s a statute that he violated with Q. What have you been told about Jeffrey | 23 more than 100 underage females; is that true? Epsteia's sexual obsession with underage minor 24 MR. PIKE: Form children? 7 . {35 Set ate 2 23] 25 MR. PIKE: Form, it Q. When did you become aware that Mr. Epstein wa A. Trefuse to answer. ; 2 a child molester? Q. Isu'tit true that Jeffrey Epstein interacted =| 3 MR. PIKE: Form, sexually with underage minors on an everyday basis? i 4 A. refuse to answer. MR. PIKE: Form. foes Q. Have you ever seen him with a femafe under the A. [refuse to answer. | 6 age of 12? Q. And most of the time Mr. Epstein would he MR. PIKE: Form. interact with underage minors at least two times aday;| 8 A. [refuse to answer. is that true? los Q. Have you ever knowe Jeffrey Epstein to have MR. PIKE: Form. 10 sex with an adult? A. Trefuse to answer. a2 MR. PIKE: Form. Q. Can you expiain to the jury how Mr. Epstein | 12 A. frefuse to answer. Would access new underage minor females for sex every 13. Q. Does he — is he sexually attracted to adults? day? {14 MR. PIKE: Form. MR. PIKE: Form, i 18 A. [refuse to answer. A. Trefuse to answer. | 16 Q. When was the first time you learned of Q. How many assistants did Jeffrey Epstein hire | 7 Mr. Epstein getting a massage from an underage minor to bring him underage minor females for sex? | 18 female? A, Lrefuse to answer. | 19 MR. PIKE: Form, MR. PIKE: Form. 20 A. [refuse to answer, Q. Were you one of those assistants that helped =| 21 Q, Eveatize some of these questions may sound to bring him underage minor females? | 22 repetitive but during this case we've learned of key MR. PIKE: Form, \ 23 terms that different people on Mr. Epsicia's iet's say A. [refuse to answer, { 24 payroll or inner circte recognize or talk about, So Q. [know that the laws in Poland are probably i 25 when I talk about "massages", do you know what that Lace Rd 7 {Pages 22 to 25) U.S. Legal Support (954) 463-2933 Car nnr one 10 41 12 a3 14 41s 16 17 18 19 20 22 22 23 24 25 we eawanewne 16 a1 42 13 14 15 16 17 18 19 20 al 22. ae" 24 25 term means? MR. PIKE: Form. A. [refuse to answer. Q, isn’t "massage” the word chat was told by Jeffrey Epstein to all of his employees to refer to whatever acts he engages in with underage femates in his bedroom? MR. PIKE: Form, A. [refuse to answer. Q. Al this point — were you — were you ever in the bedroom witb him when he was engaging in sexual acts with underage females and calling them "massages"? MR. PIKE: Form. A. [refuse to answer, Q. Did you ever participate in any of the sexnal acts that Jeffrey Epstein was having with underage females? MR. PIKE: Form. A. [refuse to answer. Q. Now, just so that the record is clear there is not a single piece of evidence that ever indicates that you were involved with underage femates, I'm not even implying that and I realize that you invoking it may — may give the wrong light and that’s not— that’s not intention, ~ but were you ever aware of Nadia 27 Marcinkova participating in sex with underage femates?; A, Trefuse to answer, Q. Have you read the police reports related to the criminal investigation into Mr. Epstein? A. [refuse to answer. Q. And you're aware of this 87-page police report that details numerous females that indicate that they i : ' i i | | | } { | | were involved sexually with Mr. Epstein when they werd minors? A. [refuse to answer. MR. PIKE: Form. Q, Did anyone instruct you to use the code word "massage"? A. I refuse to answer. Q. And when referring to these underage minor females that would come over to Mr. Epstein's house did anybody also tell you to use the term "work"? A, [refuse to answer. MR. PIKE: Form, Q. Meaning whea somebody would call ta schedule one of these underage femaies for a massage isn't it ‘true that they would say "It's time to come to work” and schedule a specific appointment? MR. PIKE: Form. A. [refuse to answer. wOdIn He wone 25 es 28 Q. Is there a book or manual or is it written anywhere that the -- that sex with underage minors is to be referred to as a "massage"? A. Lrefuse to answer. MR. PIKE: Form, Q. Were there ever team meetings, for lack of a better word, where Jeffrey Epstein and possibly Ghislaine Maxwell, Sarah Kellen, yourself, would talk about this organization of obtaining underage girls for Jeffrey Epstein for sex? MR, PIKE: Form. A. Trefuse to answer. Q. What methods dees Jeffrey Epstein use to gain access to underage minor femates for sex? MR. PIKE: Form. A, Trefuse to answer. Q. What is your understanding of Jeffrey Epstein's involvement with the modeling industry? MR. PIKE: Form. A. Lrefuse to answer. Q. Have you ever medeted for MC Squared? MR. PIKE: Form. A. [refuse to answer. Q. Has Jeffrey Epstein ever promised you anything related to a modeling career? MR. PIKE: Form. A, [refuse to answer. Q. Have you ever tatked to Jean Luc Brunel about modeling? A. [refuse to answer. Q. Have you ever talked to Jean Lac Brunel about his desire to have sex with underage females? A. [refuse to answer. Q, Isn't it true that Jean Lac Brunel has been in trouble for years for having sex with underage minors in Europe? A. [refuse to answer, Q. Are you famitiar with The McIntyre Reports? A. Trefuse to answer. Q. Okay. Are you familiar with reports done on modeling agencies back in the 80's and 90's related to agency owners having sex with waderage minors? MR. ROSS: Answer the question. A. No, I'm not. Q. Okay. Did you ever hear of Jean Luc Brunel's reputation for having sex with underage girls? MR. ROSS: Invoke. A, [refuse to answer. Q. Do you know how Jean Luc Brunet knows Jeffrey] Epstein? 8 (Pages 26 to 29) U.S. Legal Support (954) 463-2933 30 L A. [refuse to answer. 2 MR. PHKE: Form, 3 Q. isn't their connection the obsession for 4 underage minor females? 5 MR. PIKE: Foon, 6 A. Trefuse to answer. 7 Q. Based on your observations of Jeffrey Epstein 8 would you categorize his obsession for underage minor 9 females as an addiction? 10 MR. PIKE: Form. 41 A. Lrefuse to answer. 12 Q. Isn't it true that Ghislaine Maxwell delivers 13 underage minor females to Jeffrey Epstein? 14 MR. PIKE: Form. 15 A. [refuse to answer. 16 Q. Have you ever had a sexual relationship with iy Ghislaine Maxwell? 18 A, Trefuse to answer. 19 Q. Do you know what Ghislaine Maxwell does in 20 general for Jeffrey Epstein? 2. MR. PIKE: Form, 22 A, Irefuse to answer. 23 Q. Have you seen photographs of underage minor 24 females in Jeffrey Epstein's patrol — controt or 1 MR, PIKE: Form. 2 A. Frefisse to answer. 3 Q. Were there surveillance cameras, hidden 4 surveillance cameras inside Jeffrey Epstein's home? 5 ‘MR, PIKE: Form. 6 A. Trefuse to answer. 7 Q. Did those surveillance cameras capture 8 underage minor females naked? 9 MR. PIKE: Form. 10 A. [refuse to answer, li Q, And didn't Jeffrey Epstein and Ghislaine 12 Maxwell watch those surreptitiously obtained videos of 13 underage minor femates? 14 MR. PIKE: Form. 15 A. T refuse to answer. 16 Q. And those videos and photographs of underage 18 im his house, right? 19 MR. PIKE: Form. 20 A. [refuse to answer. 24 Q. Have you seen those photographs and videos on 22 Jeffrey Epstein's computers? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. Who have you talked to related to the criminal 32 investigation into Jeffrey Epstein? A. Lrefusse to answer, MR. PIKE: Form MR. ROSS: In addition, attorney-client privilege. Q. And I certainly would ~ do not want to know anything you talked to your attorney about, [ apologize, A. (Nods.) Q. Why was it that you were named as 2 co-conspirator of Jeffrey Epstein's in the non-prosecution agreement? MR_ PIKE: Form. A, Lrefuse to answer. Q. Do you feel like a victim of Jeffrey Epstein's? MR. PIKE: Form. A. [refuse to answer. Q. Deo you feel like Jeffrey Epstein brainwashed you to some extent? MR. PIKE: Form. A. [refuse to answer. Q. De you feel any remorse for any rele that you may have played in having underage minor females at Jeffrey Epstein's house for him to molest then? 33 MR. PIKE: Form, A, refuse to answer, Q. Bave you known Ghislaine Maxwell and Jeffrey Epstein to keep sex slaves? A, Trefuse to answer. Q. De you know somebody named Virginia Roberts? A. [refuse to answer. Q. Have you met Virginia Roberts? A. Lrefase to answer. MR, EDWARDS: Allright Let me go ahead and mark a5 — as Plaintiffs Exhibit | a lawsuit that was filed by Bob Josefsberg on behalf of Jane Doe 102 v, Jeffrey Epstein just for the purposes of asking the witness some questions. MR. ROSS: I've seen it, (Whereupon, Plaintifts Exhibit 1 was marked for identification.) Q. Have you ever read the lawsuit Jane Doe 102 v. Jeffrey Epstein? A. Irefase to answer, Q. In the lawsuit it indicates the plaintiff was 15 years old when Ghislaine Maxwell and Jeffrey Epstein had a threesome with this underage minor female. Are you aware of that? ‘MR. PIKE: Form. 9 {Pages 36 to 33) U.S. Legal Support (954) 463-2933 COA R WHE 10 11 12 43 14 is. 16 Ww 18 19 20 21 22 23 24 25 —— scatterer becieeatate oe aes 34 T i A. [refuse to answer. i Q. And Jeffrey Epstein and/or Ghislaine Maxwell | obtained and purchased passports for 15-year-old Jane | Doe 102 to transport her to Paim Beach, New York City, Santa Fe, Los Angeles, San Francisco, St. Louis, as well as Europe, the Caribbean, and Africa; are you aware of that? A. Urefuse to answer, MR, PIKE: Form. Q. It's also alleged that Jeffrey Epstein in addition to molesting Jane Doe 102 along with Ghistaine' Maxwell forced her to have sex with other models, actresses, and celebrities? A, I refuse to answer, MR. PIKE: Form. Q. It also indicates that Jeffrey Epstein transported other minor girls from Turkey, the Czech Republic, Asia, and other countries, Are you aware of that? MR. PIKE: Form. A. [refuse to answer. Q. 1s Jeffrey Epstein involved in the international child sex trade? MR. PIKE: Form, A. Irefuuse to answer. Bene woarau 36 Q. Jane Doe 162 ultimately escaped from him and jeft to Australia, is that your understanding? A, refuse to answer. MR. PIKE: Form. Q. Have you ever spoken with Jane Doe 102? A. I refuse to answer. Q. On one of Epstein's birthdays a friend of Jeffrey Epstein sent to him 12 -- three 12-year-old girts from France who spoke no English for Epstein to sexualty exploit and abuse and after doing so he sent them back to France the next day. Are you familiar with that? MR, PIKE; Form. A, [refuse to answer, Q. Isn't that something that is fairly common for Mr. Epstein? A, [refuse fo answer, MR. PIKE: Form. Q. Whe are the friends that send to Jeffrey Epstein underage minor females for his birthday so that| he can abuse? A. [refuse to answer, MR. PIKE: Form. Q. Is one of those friends Jean Lue Brunel? A. refuge to answer. | Q. Is Jean Luc Bronel his partner in hat / international child sex (rade? | MR. PIKE: Form. | A. Lrefuse to answer. | Q. Are you aware that after - that Jeffrey | Epstein forced Jane Doe 102 to have sex with other | adult male peers ineluding royalty, politicians, | academicians, businessmen and/or other professional a 4 personal acquaintances of Jeffrey Epstein's? i MR. PIKE: Form. | A. [refuse to answer, Q. 1s that something that he did with girls other | than Jane Doe 102? i MR. PIKE: Form. | A. Lrefuse to answer, i Q. Aren't you familiar with Jeffrey Epstein's | practice of pimping out underage minor females to other| people that have the same sexual obsession with | underage minors? ' MR. PIKE: Form, | A. [refuse to answer. | Q. And doesn’t he benefit financially from that | sex trade? | MR. PIKE: Form. | A. [refuse to answer, j OR IHORWH io 11 12 13 14 15 16 1? 18 19 20 21 22 22. 24 25 37 Q, Have you ever met Prince Andrew? A, refuse to answer. Q. Has Prince Andrew been involved with underage) minor femates to your knowledge? A. Lrefuse to answer. Q. Have you ever met Alan Dershowitz? A. Irefuse to answer. Q. When Alan Dershowitz stays at Jeffrey Epstein's house isn't it true that he has been at the house when underage minor femaies have been in the bedroom with Joffrey Epstein? A. I refuse to answer. Q. Has ~ are you familiar with the media publication or online resource RadarOnline? A. Ltefuse to answer. Q. Is that something that you assisted Mr. Epstein with when he purchased RadarOnline? A. Trefuse to answer. Q. And do you know his business partner in that endeavor? A, [refuse to answer, Q. Isn't it alse true that he used RadarOnline as another way fo gain access to underage minor females for sex? MR. PIKE: Form. 10 (Pages 34 to 37) U.S. Legal Support (954) 463-2933 Pe POWAY AH H&S WNH BeBe Pee SOIAAHRHRYWN 20 ai 22 23 24 25 wo OIauewn ete 1d 12 13 14 15 16 17 18 1g 20 at 22 2 24 25 i A. [refuse to answer, | Q. Have you been to all of Jeffrey Epstein's | properties? | MR. PIKE: Form. ! A. Erefuse to answer. | Q. Certainly you've been to the property at 358 | E1 Brillo Way, correct? ' MR, PIKE: Form. \ A. [refuse to answer, i A. Trefuse to answer. | MR. PIKE: Form. { Q. And have you been to his island in—itwas |} Little St, James, I believe be calls it Little i St. Jeff's now? | MR. PIKE: Form. | A, [refuse to answer. i Q. And have you witnessed underage child sex | orgies on that istand? | MR. PIKE: Form, i A. Lrefuse to answer. | Q. Do you know a female named Jeletzia? | A. [refuse to answer. i Q. Do you know where Jeletzia lives these days? : A, Trefise to answer. ! Q. What is your understanding of Sarah Keen's | role in Jeffrey Epstein's life? | A. Lrefise to answer. I MR. PIKE: Form. / Q. Isn’'tit true that she gets paid just to bring | him underage minor females for sex? | MR. PIKE: Form. i A, Lrefuse to answer, | Q. And additionally, she schedules the | appointments for underage minor females for him to | molest? | A. Trefiase to answer, | MR. PIKE: Form, \ Q. You know Dana Burns? | A. Lrefuse to answer. i Q, Does she still work for Ghislaine Maxwell? | A, Lrefuse to answer. | Q. Was she an underage minor child victim of | Jeffrey Epstein's? | A. Lrefuse to answer. Q. Through discovery we've tatked to uumerous witnesses about, you kuow, Jeffrey Epstein and people that work for him. I don't know if you'll be able to answer any of these questions but i'll ask them anyway ‘one at a time. 23 24 25 Is Sarah Kellen somebody who travels with Jeffrey Epstein? MR. PIKE: Form, A. [refuse to answer. Q. And when Jeffrey Epstein is coming to town doesn't he call Sarah Kellen, his number one assistant? MR. PIKE: Form. A. [refuse to answer. Q, And at some point in time, if looks like in early 2005 ar tate 2004, you were also an assistant of Jeffrey Epstein's, correct? MR. PIKE: Form. A, Irefuuse to answer. Q. And how was it that you transitioned from being involved in modeling to being an employee of Jeffrey Epstein? MR, PIKE: Form. A. [refuse to answer. Q. Other than arranging for underage minor females to come to Jeffrey Epstein's house did you do anything else for Jeffrey Epstein? MR. PIKE: Form. A. I refuse to answer, Q. Did you ever fly on Jeffrey Epstein's A. [refuse to answer. Q. Did you witness Jeffrey Epstein abuse — sexually abusing underage minor females on his airplane? MR. PIKE: Foon. A. Trefuse to answer. Q. Did you know that it was illegal for Jeffrey Epstein to interact sexually with underage minor females? MR. PIKE: Form. A. Trefluse to answer. Q. Did you ever object to Jeffrey Epstein interacting sexually with underage minor females? MR, PIKE: Form. A, I refuse to answer, Q. Would Jeffrey Epstein get angry at you if you did not have an appointment set for him with an underage minor female? MR. PIKE: Formn. A, Lrefise to answer. Q. Has Jeffrey Epstein contacted yeu in the last year? A. Irefuse to answer. MR. PIKE: Form. Q. Has Sarah Kellen contacted you within the fast — 11 (Pages 38 to 41) U.S. Legal Support (954) 463-2933 COIHRY ROK 1 12 aa 14 is 16 17 18 19 20 aL 22 23 24 we Ovaeewne 10 li 12 i3 14 15 16 7 18 ig 20 2i 22 23 24 25 year? A, [refuse to answer. Q. Has anybody that is associated with Jeffrey Epstein's party contacted you in the last year? MR. PIKE: Form. A, Trefuse to answer. Q. By that I mean to include Ghislaine Maxwell, Lesley Groff, any of these people, have they contacted | you within the last year? MR. PIKE: Form. A. Frefuse to answer. Q. Are you familiar with the names of some of the underage minor females? A. Trefuse to answer. Q. Are you famitiar with LM? A. I refuse to answer. Q. Do you remember what LM looked fike? A. [refuse to answer. Q. Are you famifiar with EW? A. [refuse to answer. Q. De you remember what EW leoked like? A. [refuse to answer. Q. Are you familiar with Jane Doe? A, [refuse to answer. femaics that Jeffrey Epstein interacted with sexually during a time when you were working for him; isn'¢ that true? A, [refuse to answer. MR. PIKE: Form. Q. And LM was somebody that went ever to Jeffrey Epstein's house and was molested at a young age by him more than 106 times; is that true? MR. PIKE: Form. A. [refuse to answer, Q. And EW was also somebody who went over to Jeffrey Epstein's house when she was between 14 and 16 years old more than a hundred times; isn't that true? MR, PIKE: Form. A. refuse to answer, Q. And Jane Doe was somebody that went to Jeffrey Epstein's house more than 15 times to be molested by Jeffrey Epstein when she was 14 and 15 years old; is that true? MR. PIKE: Form. A. Trefuse to answer. Q, sit also true that LM brought to Jeffrey Epstein's house between 50 and 75 other underage minor, females for Jeffrey Epstein to molest? | OOIH Ye wWN NNNNNKRP EEE PP Pe ee Aewane seein oe wnro we OWaues wn 44 A, Lrefuse to answer, MR. ROSS: Form. Q. Are you aware of Jeffrey Epstein's for tack of a better word “ritual* with these underage minor females in his bedroom? MR. PIKE: Form. A. [refuse to answer. Q. Wouldn't it generally begin with Jeffrey Epstein placing a call to Sarak Kellen or yeurself and telling you that he's going to be in town at the Palm Beach mansion? MR. PIKE: Form. A. Trefuse to answer. Q. And then isn’t there a fist of underage minor females stored in the computer system? MR. PIKE: Form. A. Trefiuse to answer. Q. And that computer system is interconnected from his New York home, his New Mexico home, his island, his home in France, and West Palm Beach; is that correct? MR. PIKE: Form. A, [refuse to answer. Q. And have you seen that list of underage minor MR. PIKE: Form, A, [refuse to answer. Q. And isn't it true there are over a thousand girls at any given time between the age range of 12 and 17 all of which have been molested by Jeffrey Epstein? ‘MR. PIKE: Form. A. Trefuse to answer. Q. And when Mr. Epstein would call and tell you the time that he was going to be in town it would then be your job to get an underage minor female to his house and set a specific appointment for that persons is that correct? MR. PIKE: Form, A, refuse to answer. Q. And he would tell you the exact time of day that he wanted his two or three appointments to molest| underage minor females? MR. PIKE: Form, A. [refuse to answer. Q. And you would go into the computer system and call the person that he told yon he wanted to see for that day; is that correct? MR_ PIKE: Form. A, Lrefuse to answer. Q. And that may be Brittany or Tatum or Courtney] 12 (Pages 42 to 45) U.S. Legal Support (954) 463-2933 46 48 1 or somebody local that you would call on the telephone | 1 in time Jeffrey Epstein showed you exactly what hte does 2 amd tell them to come work at a specific time? | 2 with each of these girls in the bedroom, correct? 3 MR. PIKE: Form, | 3 MR. PIKE: Form. 4 A. [refuse to answer. | ¢ A. [refuse to answer. 5 Q. And didn't Mr. Epstein tell you that the way | 5 Q, So after about — he would order the underage 6 you need to tell these girls is that they are working | «=««6~——sminor female to begin massaging him, correct? a so that they do not feel chat they have the option to | 7 MR, PIKE: Form. 8 decline? ios A, Lrofuse to answer. 9 MR. PIKE: Form. | 9 Q. And then he would roll over and begin to 10 A. [refuse to answer. | 10 masturbate with his right hand, correct? qn Q. Tmean, the psychology of it all was explained =| 11 A. Lrefuse to answer. 12 im detail by Jeffrey Epstein; isn't that correct? ; 1 Q. And then he would begin also grabbing the 13 MR. PIKE: Form. | 13 breasts, buttocks, aud vagina area of these underage 14 A, [refuse to answer, | 24 minor fematks, correct? is Q, And once the girls were inside the bedroom ; a5: A. [refuse to answer, 16 Jeffrey Epstein said that he can take care of the rest, | 15 MR. PIKE: Form. 17 correct? a7 Q. And his ritual was so specific that with each 18 MR. PIKE: Form. | 18 of them he would demand that they pinch his nipples 1g A. [rofuse to answer. [19 very hard, right? 20 Q. And the underage minor female would show up att 20 MR. PIKE: Form. 21 the house and be greeted at the door by either , oak AL Lrefuge to answer. 22 yourself, the house manager, or Sarah Kellen, correct? | 22 Q. That's a fetish that you know that Jeffrey 23 MR. PIKE: Form, 23 Epstein has, right, he likes his nipples pinched very 24 A. Trefuse to answer. | 24 hara? 1¢ minor females including | 47) 1 my three clients, LM, EW, and Jane Doe youmet =| 1 A. Trefuse to answer, 2 personally, right? ; 2 Q. And as he's masturbating with one hand and has 3 A. Irefuse to answer, | 3 his other hand groping or inserting his fingers into 4 MR. PIKE: Form, {o4 the underage minor's vagina he's also telling them to 5 Q. And then you would lead thera upstairs to his | 5 pinch his nipples, correct? 6 bedroom and Leave him alone in the bedroom, leave my} 6 MR. PIKE: Form. 7 client alone in the bedroom? 17 A. [refuse to answer. 8 MR. PIKE: For. ; 8 Q. And this continues -— and sometimes this 9 A, [refuse to answer. | 9 escalates to him using vibrators, correct? 10 Q. Anditet’s take LM, and she went there many | 10 MR. PIKE: Form. 14 times between the ages of 13 and 16. Ifshe was taken | 11 A, [refisse to answer. 12 _up to his bedroom she would be feft atone in the 12 Q. And have you seen vibrators in the Paim Beach 13 bedroom until Jeffrey Epstein arrived, correct? | 13 mansion house? 14 MR. PIKE: Form. | 14 MR, PIKE: Form, 15 A. Trefuse to answer. | as A. Trefuse to answer, 16 Q. And Jeffrey Epstein would appear usually naked| 16 Q. And other times he orders Nadia Marcinkova to 17 and order for her to take her clothes off? | 17 partietpate in these encounters with underage miuor 18 A. Lrefuse to answer. | 18 females; is that correct? 19 MR. PIKE: Form. | ag A. [refuse to answer. 20 Q, And then Mr. Epstein would lay face down on ' 20 Q. Are you familiar with Nadia Mareinkova 21 the massage table would usually be the next step, | 21 strapping on dildos to have sex with these underage 22 correct? | 22 minor females? 23 MR. PIKE: Form. | 23 MR. PIKE: Form, 24 A. [refuse to answer. | 24 A. I refuse to answer. 25 Q, And you know this ritual because at some point 25 Q. And when Miss Marcinkova would have sex th 13 (Pages 46 to 49) U.S. Legal Support (954) 463-2933 CRA RAHRWNHE we ewtaoueuwne 10 12 12 13 14 is 16 17 18 19 20 22 22 2x 24 25 MR. PIKE: Form. 50} the underage minor females Jeffrey Epstein would watch) and continue €o ejac -- continue to masturbate, correct? MR. PIKE: Fonn. A, [refuse to answer. Q. Has he ever asked you to participate in these threesomes with underage minor females? A. Lrefuse to answer. MR. PIKE: Form, Q. Have you ever participated in sex with underage minor females at the direction of Jeffrey Epstein? MR. PIKE: Form. A. [refuse to answer. Q. The ~ this whole experience that fam explaining right now is identical every single time with these underage minor females; isn't that your understanding? MR, PIKE: Form. A. [refuse to answer. Q. And this whole experience is what he has taught you and the other employees to call a "massage", correct? MR. PIKE: Form. A, [refuse to answer, Q. And it always ends with bim ejaculating? | | | i i { | i i i A. [refuse to answer. MR, PIKE: Form. Q. And then he offers 200 to $300 cash to the underage minor female, correct? MR. PIKE: Form. A. Lrefise to answer. Q. And then he also gives them another — another option to make money whieh is each time you come to my ‘house and we engage in this sexual interaction I will give you $200, but each female you bring me like you, between the age range of 12 and 16, I will pay you $200 per person, MR. PIKE; Form. Q, Is that something you're familiar with? A. [refuse to answer. Q. And LM at that offer was one of the girls who brought him 75 plus underage minor females, correct? MR. PIKE: Form. A, Trefuse to answer, Q, And so he's basically created a pyramid of underage minor females where the computer system has a thousand of these femates ready to come over to work for him? ODIYAHRwWNHH COVA RW 10 11 12 13 14 15 16 17 18 19 20 22 22 23 24 25 52 A. [refuse to answer, Q. Do you know what Jeffrey Epstein does for a fiving? A. [refuse to answer, Q. Does he do anything aside from interacting sexually with underage minor females? MR. PIKE: Form. A. Lrefiuse to answer. Q. Do you know how it is that he made his money where he ts purported fo be a billionaire? A. Trefuse to answer. MR. PIKE: Form. Q. Do you know David Copperfield? A. [refuse to answer. Q. Is David Copperfield somebody that would come| info town and interact sexuaity with underage minor femates? A, [refuse to answer. Q. Do you know Martin Nowak? A. Trefuse to answer. Q. Is that also somebody that would interact sexually with underage minor females? A. Irefuseto answer,” Q. Do you know Leslie Wexner? A, [refuse to answer. 53 Q. Is that somebody you've met before? A. Trefuse to answer. Q. Has Mr. Epstein himself interacted sexually with Leslie Wexner? MR. PIKE: Form. A. [refuse to answer. Q. When Mr. Epstein was being investigated criminally how did you first learn about that? A. [refuse to answer. Q. Atsome point in time he was tipped off that his home — that a search warrant was going to be executed on his home, correct? MR. PIKE: Form. A, Trefiuse to answer. Q. And just a month before the execution of that search warrant -- less than a month before the execution of that search warrant he ordered you to de something with certain evidence, didn't he? MR. PIKE: Form. A. [refuse to answer, Q. In fact, there were at least three very key computers that contained a lot of the information that I've been asking you about. You're familiar with those computers that were in his house, correct? MR. PIKE: Form. 14 (Pages 50 to 53} U.S. Legal Support (954) 463-2933 COI HAY HW a1 12 13 14 15 2i 34 A. [refuse to answer. Q. And he ordered you to come over and take those computers out of his house, correct? e A, [refuse to answer. MR. PIKE: Form. Q. And you could basically take the tocat database that exposed this criminal enterprise that T've been talking about dealing with sex with underage minor vehicles -- underage minor females and you could take the evidence from his home, correct? MR. PIKE: Form. A. [refuse to answer. Q. And yea've seen the material that's on those computers, correct? MR, PIKE: Foem, A, [refuse to answer, Q. And if I were to look at those computers it would display exactly what I've been deseribing to you today, right? MR. PIKE: Form, A. [refuse to answer. Q. And you went to his house with a mate, correct? A. I refuse to answer. Q. There was one other guy with you that helped that assisted you to take these computers frou his home; is that right? MR. PIKE: Form A, [refuse to answer. Q. Where did you take those? A. Trefuse to answer. Q. Did you take those -- was it Bill Reilly that went to the home? A, [refuse to answer. Q. Do you know who Bill Reifly is? A. [refuse to answer. Q, He's one of the investigators hired by Roy Black to represent Jeffrey Epstein? A, Trefluse to answer. Q. Did you take those computers ever to your house? A, Trefuse to answer. Q. And I guess the house that I would be talking about is the 1640 South Shore Drive, have those computers ever been to that house? MR. PIKE: Form, A, [refuse to answer. Q. Were you nervous about the fact that you were | | | | | | | i | COIAH mM WNe 24 56 search warrant was imminent? A. [refuse to answer, Q. Did you ever question when you were directed to take these computers from his home? A. refuse to answer. Q. How much additional money or bonus were you paid to take the computers that we're talking about out| of Jeffrey Epstein’s house? MR. PIKE: Form, A. [refuse to answer. Q. Would those computers reveal criminal activity of only Jeffrey Epstein or of others? MR. PHKE: Form. A. Erefuse to answer. Q. Did you talk with Sarah Kelien about the criminal investigation into Jeffrey Epstein and others? A, Lrefuse to answer. Q. Well, at some point in time what's been marked as Defense Exhibit 1, you received a Grand Jury investigation target letter, correct? A. Irefuse to answer, Q. Welt, we have it right here. I'm familiar with it. I know you got the letter and 1 know that, you know, the substance of it you’re not going to tell 57 the search warrant was executed on his home back in October of 2005. So during those two years leading up to this target letter who did you talk to? A, [refuse to answer. Q. Did you-- MR. ROSS: And privilege. Attorney-client privilege. Q. Okay. In addition to your attorney did you taik to anybody else about the criminal investigation? A, I refuse to answer. Q. And Brace Lyons was your initial computer — computer -- was your initial attorney in this case, correct? MR. ROSS: You can answer yes or no. A. Yes. Q. Okay. And that was an attorney that was hired for you by Jeffrey Epstein? MR. ROSS: Invoke. A. Lrefuse to answer, Q. Someone that was paid for by Jeffrey Epsteia to represent you? MR. PIKE: Form, A. Trefluse to answer. Q. So once he hired you a criminal attorney then [25 _ taking these computers out ofthe homeata time whens] 25 itseemed like you did something wrong? 15 (Pages 54 to 57) U.S. Legal Support (954) 463-2933 \ MR. PIKE: Form. | A. refuse to answer. | Q. You hadn't actually gone into any relationship | with Jeffrey Epstein with the intent to commit crimes, did you? A, Lreflse to answer, Q. You didn't know that ke was a child molester when you first met him, did you? MR. PIKE: Form. A. Trefuuse to answer, Q. Were you impressed by his money and his lifestyle? A, frefuse to answer. Q. Did you think that he could get you further in fife if you would just listen to what he said? MR. PIKE: Form. A. [refuse to answer. Q. At this point in time you have no contact with him as a child molester, do you? MR. PIKE: Form. A. [refuse to answer. Q. Did Jeffrey Epstein assist in getting you a visa? A. [refuse to answer. Q. Has he done any favors for your family? A. [refiuse to answer, MR. PIKE: Form. Q. Is he paying for your college? A, [refuse to answer. MR. PIKE: Form. Q. Right now is he paying for your college? MR. ROSS: Invoke. A. [refiuse to answer. MR. PIKE: Form. Q. Did Jeffrey Epstein ever tall to you about the chances of him going to prison? A, Lrefuuse to answer. MR. PIKE; Form, Q. Did Jeffrey Epstein ever talk to you about what he intended his defenses to be to the criminal actions he committed against these underage minors? A, [refuse to answer. MR. PIKE: Form. Q. Did he tell you that he would spend as much money as possible to intimidate and harass these underage ntinor victims? A, Trefiuse to answer. MR PIKE: Form. Q. Did he teil you that he would destroy their 60 1 credibility? 2 A. Lrefuse to answer. 3 Q. Did he tell you that he could scare them to go 4 away? 5 A. Lrefuse to aaswer. 6 MR. PIKE; Fonn and forn to the last question. 7 MR. EDWARDS: All right. Let's see, what did 8 Isay, f said this was -- 7 9 MR. ROSS: 1. A 10 MR. EDWARDS: -- Plaintiff's 1 and we're going, 11 to write on the back of it and then -- okay, 12 Q. Jeffrey Epstein kept message pads near all of 13 his phones in his home, right? 14 MR. PIKE: Form. ais A. I refuse to answer. 16 Q. And those are message pads that have a carbon 17 copy back side to them, you're farailiar with them? 18 MR, PIKE: Form. 19 A. Trefuse to answer. 20 Q. And this is for anybody who takes a message al they write it down that somebody called, the reason for| 22 calling, the time that they called? 23 MR. PIKE: Form. 24 A. Erefuse to answer. Q. And many a times anytime that Jeffrey Epstein 61 1 was in town there were at least two scheduied = “raassages” for lack of a better word, with Jeffrey 3 Epstein and these underage minor females, correct? 4 A. [refuse to answer. 5 MR. PIKE: Form. 6 Q. And do you have the -- and there was a ¥ particular scheduling book that contained these 8 appointments with - between Jeffrey Epstein and 9 underage minor females, correct? 10 MR. PIKE: Form. 41 A. Trefuse to answer. 12 Q. And it was your primary responsibility to 13 assist Sarah Kellen in setting these appointments up, 14 right? 15 A. I refuse to answer. 16 MR. PIKE: Form. 17 Q. It took at least two or three full-time 18 employees to keep up with Jeffrey Epstein’s addiction 19 — tounderage minors, correct? 20 A. Trefise to answer. 21 MR. PIKE: Form. 22 Q. Lestey Groff did pretty much the same thing up| 23 in New York, right? 24 MR. PIKE: Form. 25 A. Irefuse to answer. 16 (Pages 58 to 61) U.S. Legal Support (954) 463-2933 wOwIanewne 62 Q. And you've familiar that there is this group of girls in New York that were summoned to his home for generally the exact same thing as the Palm Beach girls? A. | refluse to answer. Q. Allright. MR. PIKE: Form. Q. I'm going to show you an exhibit here, we'll mark it as — you know what, it's a buneh of message pads, I'm going to mark it as 2A, -B, -C, -D, whatever. So we'll say 2A. (Whereupon, Plaintiff's Exhibit 2A through 2. were marked for identification.) Q. Do you recognize it? A, Lrefuse (0 answer. Q. Okay. MR. PIKE; May I see that? MR, EDWARDS: Sure. Q. Do you recognize the handwriting on it? A. Lrefuse fo answer. Q. Ht indicates "Adriana hasn't confirmed Julie for 11 yet, so she is keeping Brittany on hold in case Tulie doesa't call back." What does that message mean? A. [refuse to answer. MR, PIKE: Form, Q. Sulie's an underage minor femate that Jeffrey Epstein was going fo molest at 11:00, correct? MR. PIKE: Form. A. [refuse to answer. Q. And if Julie wasn't available then you had another underage minor fervate named Brittany that could step in her place and fulfill that role for Jeffrey Epstein, correct? MR. PIKE: Form. A. Lrefuse to answer. | | | | i | | | { i } | | | | | | | | | | Q. All right. 2Bis another message pad and I'm going fo ~ we'll stop slipping the process of moving this on and I'ma assuming you're not going to be able to answer as to whether or not you -- you recognize that either, right? A. Frefuse to answer. Q. Okay. This is a message from 9/4/05, s0 September 4th, 2005, 7:25 p.m. saying "Adriana cancelled Julie. She would like to speak to you L believe about college," and a telephone number. And then a question from you, "Shaudd I schedule anyone else?" What did that message mean? MR PIKE: Form, A, Trefuse to answer. COIN ewne eC rmItIAvAHAeRwWwne 10 11 12 13 14 is 16 17 18 19 20 21 22 23 64 that he would promise these girls something in order to] get them to allow him to sexually abuse them? MR. PIKE: Form. A. [refuse to answer. Q. Because he certaialy did not want them to tell the police, correct? A. [refuse to answer. Q. And did you have many meetings about what to do if any of these girls told the police? A, Trefuse to answer. MR. PIKE: Form. Q. Was it always known that Jeffrey Epstein would hire everyone attorneys and tell everyone just met fo talk? MR, PIKE: Form, A. T refuse to answer. Q. And at the same time then he contd employ a bunch of investigators, dig up a bunch of dirt on these girls, and intimidate them and scare them to go away, correct? MR. PIKE: Form, A. [refuse to answer, Q. And Jeffrey Epstein doesn't like ~ he didn't fike any of these underage minor females, right? MR, PIKE: Form, 65 A. [refuse to answer. Q. In fact, it was the opposite, he liked to hurt them; isn't that true? MR, PIKE; Form. A. Trefuse to answer. Q. And after they came forward if they told the truth he was dead set on hurting them even more, correct? ‘MR, PIKE: Form. A, Lrefuse to answer. Q. And that's also a feeling that Ghislaine Maxwell shared as well, correct? A. [refuse to answer, Q. And that’s something that she also told yeu, “Don't worry. If we get caught we have it covered and we'll just attack these little girls," MR. PIKE: Form, A. refuse to answer. Q. Allright. There's another message from 9/10/05, "Adriana says Lauren confirmed for 4 p.m." Can you tell us what that message means? MR. PIKE: Form. A. I refuse to answer. Q. it’s another underage minor female that Jeffrey Epstein's going to molest at 4 p.m., correct? » a as 17 (Pages 62 to 65) U.S. Legal Support (954) 463-2933 66 A, [refuse to answer. Q. And when I say “nrolest", you know, he may say massage", [ mean, that's ~ that's something interchangeable, right? MR. PIKE: Form. A, Lrefuse to answer, Q. If's the routine that I described in detail that is identical with every single girl every single time, correct? A. Trefuse to answer. Q. And it's basically as far as be can get with this underage minor female without ker crying or screaming or running out of the house? MR, PIKE; Form. A. [refuse to answer, Q. Did you ever see any of the girls cry or scream or ran ont of the house? ‘MR. PIKE: Form. A. Trefuse to answer. Q. Did you have a personal relationship with any of these underage minor females? A, [refuse to answer. Q. There's another message here from 9/10/05, same day later in the day, 10 pm. saying “Julie will | be Brittany?" [ Do you know what that message means? MR. PIKE: Form. A. [refuse to answer. Q. What is this? ‘There's another message from 9/11/05 saying "I got a car for," and then the name is blotted out. The State Attorney's Office blotted the names of minors out| sometimes in their file, Sedo you do you know— | can you fill in that blank? | A. Erefuse to answer. | Q. Do you know if this was the car that he rented for Jane Doe 47 i A. [refuse to answer. i Q. All right. Or the car that he rented for AH? j A. Lrefuse to answer. MR. PIKE: Form. | Q. You're familiar with both of those people, ! right? ; A. Lrefuse to answer, ; Q. Infact, AH was somebody that was over at; Jeffrey Epstein’s house many times, correct? A. I refuse to answer, MR. PIKE: Form, Q. 9/5/2005. Message from Adriana saying "I left message for Ashley to confirm for 11 a.m. and Vanessa | | ' | i Ww OIA one oe a ) 10 a2 12 13 14 1s 16 a) 18 19 20 aL 22 23 24 25 68 for 4:36 p.m.” Do you remember leaving that message? A. Lrefuse to answer. Q. And this is ~ MR. PIKE: Form. Q. Ies his typical schedule where he schedules one underage minor female to molest in the moraing and one in the afternoon, correct? MR. PIKE: Form. A. Trefuse to answer, Q. Eimean, considering this is — have you ever worked anywhere else where there is somebody sexuaily| molesting anderage minor females on a daily basis tike this? MR. PIKE: Form, A. Trefiuse to answer, Q. At some point in time did you fell your parents that this was happening? MR. PIKE: Form. A. [refuse to answer, Q. Did you ever talk to anybody else in the house and say "Hey, look, this is aot right"? A. [refuse to answer. Q. Do you feel sorry for these girls? A. Trefuse to answer. Q. And you say you do or you do sot remember AH? A. [refuse to answer. Q. Okay. And do you know what happened up in the bedroom between AH as a minor and Jeffrey Epstein? MR. PIKE: Form. A. Lrefuse to answer, Q. Well, this is what she tells police: "She arrived at the house, went upstairs to the bedroom. She advised she immediately removed her clothing and Nadia Marcinkova and Epstein were already naked in the] bedroom, AH explained that Nadia Marcinkova and she had a sexual encounter that included kissing, touching, and oral sex. AH remembered that she climaxed and was removing herself from the massage table, Epstein then turned AH onto ber stomach on the massage fable and inserted his penis inte her vagina, AH stated Epstein began to pump his penis in her vagina. AH became upset! over this, She said her head was being held forcibly against the bed as he continued to pump inside her. She screamed 'No,' and Epstein stopped. He would normally pay ker $200, but for this ke apologized and paid her a thousand dollars for that visit.” Are you familiar with that encounter? A. [refuse to answer, MR. PIKE: Form. 18 (Pages 66 to 69) U.S. Legal Support (954) 463-2933 Q. Do you remember a time when AH asa 16-year-old I believe at this time left her house left the house visibly upset? MR. PIKE: Form. A. [refuse to answer, Q. She advised that ste was ripped and torn in her vagina area and had difficulty wathing to the car; do you remember that? MR. PIKE: Form. A. [refuse to answer, Q. These message pads were message pads that were taken from trash palls outside of Jeffrey Epstetn’s home and for the most ~ welt, there's so many messages here, but most of them are by somebody other than yourself. So my question is who are the other people that would take messages for Jeffrey Epstein for underage minor females to come to the house? MR, PIKE: Form. A, Trefiase to answer. Q. And the messages include CL, "Can I come work today?" What does “work" mean? A. [refuse to answer. MR, PIKE: Form. Jeffrey Epstein sexually molesting this person while she was underage; is that correct? A. Lrefuse to answer. MR. PIKE: Form. Q. And it was also pretty frequent that the girls would come in tandem, isn't that true, two at a time? MR. PIKE: Form. A. [refuse to answer. Q. And one being the girl that would bring the ‘new girl there, would wait downstairs while the new girl was upstairs getting molested but then getting paid? MR. PIKE: Form. A. [refuse to answer. Q. How did Jeffrey Epstein explain himself to you! as to why he did this? MR. PIKE: Form. A. Frefuse to answer. Q. Do you know when it is that he first became sexually obsessed with underage minor females? MR. PIKE: Asked and answered. A, Lrefuse to answer, MR. PIKE: Form. | Q. Did you know that he was a school teacher at i the Dalton School? | wow nnwe wre 25 72 A. [refuse to answer. Q. And at that point in time -- well, are you aware of him molesting underage minors while he was a teacher there? A, [refuse to answer. Q. There's another note that’s not a message pad which F guess I will — since it has your name on it will mark it as what are we on ~ 3 - wait, C~ MR. ROSS: 3. MR. EDWARDS: I messed up. MR. ROSS: 3. (Whereupon, Plaintiff's Exhibit 3 was marked for identification.) Q. Look at that while I fix what I've messed up over here. MR. ROSS: I'm going to show this to the witness, MR. EDWARDS: Yes. Yes. Q. Do you recognize that document? A. [refuse to answer. Q. There are a lot of different things on here that doa‘t necessarily relate to you. At least I can’t tell that they do. But it does indicate “Adriana’s parents are going to the embassy on the 23rd." Do you remember when that happened? 73 A. [refuse to answer. Q. Why did your parents go to the embassy? A, [refuse to answer. Q. More importantly why was Mr. Epstein concerned that your parents were going to the Embassy? MR. PIKB: Form. A. I refuse to answer. Q. Was — at that point in time was Mr. Epstein assisting your parents with anything? A. [refuse to answer, Q. Are your parents citizens of the United States? MR. ROSS: Form, A, Trefuse to answer. Q. Are you? A. No. Q. Has Mr. Epstein ever offered to get you a visa for the United States? A. Erefuse to answer. MR. PIKE: Form. Q. Do you know Raer Roshan? A. Trefuse to answer. Q. That was Jeffrey Epstein's partner in RadarOnline, correct? A, Trefuse to answer. 19 (Pages 70 to 73) U.S. Legal Support (954) 463-2933 ce ODIDRDeWNE RONRARE BPE EE RRR Ro GQekOESERSLVHIHAH RANE O Cert Hoewn er 10 12 13 14 15 16 417 13 19 20 21 22 23 24 25 74 Q. And if I showed you every single message pad here would you be able to answer any of the questions | about any of the messages that were left at Jeffrey Epstein's house? A, [refuse t answer. MR. EDWARDS: Okay. That saves us alot of time. MR. ROSS: It did. Q. Have you ever met Bill Clinton? A. refuse to answer. Q. Is Bill Clinton -- was Bill Clinton a friend of Jeffrey Epstein's? A. Lrefisse to answer. Q, {s Bill Clinton somebody who Jeffrey Epstein has ever procured underage minor femaies for? A, [refuse to answer. MR. PIKE: Form, Q. And just-- and just for, you know, the sake of what the evidence shows, there's no evidence that I have that indicates that that happened, but if yon were going to answer that question I'm willing to ask it. i i i i i | | j } Have you met him at Jeffrey Epstein's house in| Paim Beach County? MR, PIKE: Form. 75} | i | i | | i | | ! Q. You have flowa on Jeffrey Epstein's airplanes numerous times, correct? A. [refuse to answer. Q. As welt has Bill Clinton and you're aware of that, right? MR. PIKE: Form. A. [refuse to answer. Q. Have you ever seen the flight fogs from Jeffrey Epstein's airplanes? MR. PIKE: Form. A, Lrefise to answer. Q, And on many times it is Bil Clinton, Secret Service agents, Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, aud others. Have you — do you know about those flights? A. [refuse to answer. MR. PIKE: Form. Q. And have you ever witnessed sex on any of Jeffrey Epstein's flights? A. I refuse to answer. MR. PIKE: Form. Q. Do you know Emmy Taylor? A. [refuse to answer, Q. Is that somebody that is Ghislaine Maxwell's sex slave? 22 24 25 76 A. refuse to answer. Q. And isn’t it typical for Jeffrey Epstein to have a sex slave that flies with him on the airplane? A. I refuse to answer. MR, PIKE: Form, Q. And one of the qualifications is that the section slave be underage, correct? MR. PIKE: Form. A. [refuse to answer, Q. And if the sex slave is 15 years old isn't it your understanding and based on your observations that} he will even make them dress as if they’re Lk or 12? MR. PIKE, Form A, Trefuse to answer. MR, PIKE: Form. Q. Bo you know President Andres Pastrana? A, [refuse to answer. Q. Bo you know him as somebody who has had sex with underage minor females brought to him by Jeffrey Epstein? MR. PIKE: Form. A. I refuse to answer. Q. Have you ever heard of Ehud Burak? A. [refuse to answer. Q. Is that another person that Epstein — Jeffrey Epstein pracures underage minor females for? MR. PIKE: Form. A. [refuse to answer. Q. You've met Naomi Campbell I'm assuming? A. Lrefuse to answer. Q. Anytime separate and apart from any dealings with Jeffrey Epstein have yeu met her in the modeling] industry? That's a model, right? ‘MR. PIKE: Form. MR. ROSS: You can answer the question. A, No, Ihave aot. Q. Okay. Do you know Todd Meister? A, Lrefuse to answer, Q. Joel Pashcow? A. [refuse to answer. Q. You've been to their houses? A. Lrefuse to answer. Q. De you know Aline Weber? A. [refuse to answer. Q. Have you ever stayed at the 301 East 66th Street places with Aline Weber? MR. PIKE: Form. A. Trefuse to answer. Q. And typically aren't there at least 16 20 (Pages 74 to 77) U.S. Legal Support (954) 463-2933 COOIHRUHRWHH 10 12 43 14 18 16 17 18 wordranve wn underage minor females staying at those various condominiums located at 304 East 66th Street? A. [refuse to answer. Q. And those females get work visas to say that they're models, but actually they are prostituted out by Jeffrey Epstein and John Lac Brunel, correct? A, [refuse to answer. MR. PIKE: Form. Q. And various businessmen and politicians around | New York and Washington, D.C. go to those apartments! frequently to have sex with underage minors; is that | tenet | A, [refuse to answer. | Q. Do you remember a flight oa December 3rd, 2004: that you took with Jeffrey Epstein, Nadia Marcinkova, Sarah Kellen, and somebody with initials SH — i A. [refuse to answer. | Q. ~ from JFK to PBI? \ MR, PIKE: Form, | Q. Do you remember that? | A, Trefase to answer | Q. Who is SH? : A, [refuse to answer. ' 1 Q, Is that an underage minor? 713 Q. Do you remember a fight that you took December 27th with Nadia Marcinkova and Jeffrey Epstein? A. Lrefuse to answer. Q. What airport is this, TIST? A. Trefuse to answer. Q. De you know Doug Band? A. [refuse to answer. Q. Isn't that Bill Clinton's assistant? A, [refuse to answer. Q. You've been on the airplane with him before? A, Erefiise to answer. Q. Have you been on the airplane with Bill Clinton before? A. I refuse to answer. Q. Who is Tatiana? A. [refuse to answer. Q. That's somebody you've flown with on Jeffrey; Epstein's plane on numerous oceasions, correct? MR. PIKE: Form A. Trefisse to answer. Q. In fact, during the year 2005 you flew on Jeffrey Epstein's plane would you say more than 50 times? A. [refuse to answer. COOH TRWHe OC MRAIHRHRYWHE 1¢ ad. we: 13 14 as 16 17 19 20 aL 22 23 24 25 80 MR. PIKE: Form. Q. And you flew to his island, right? A. Erefuse to answer. MR, PIKE: Form, Q. You flew to New Mexico? A, [refuse to answer, MR, PIKE: Form, Q. You flew to New Jersey? MR. PIKE: Form. A. {refuse to answer. Q. Several of the flights are just yourself, Jeftrey Epstein, and Sarah Kellen, What did you do on] those flights? MR. PIKE: Form. A. [refuse to answer. Q. Who's Adam Perrylang? A. I refuse to answer. Q. Is that somebody that you were made to have sex with? A. [refuse to answer. Q. Did Joffrey Epstein ever make you have sex with any females? MR. PIKE: Form, A, Exefuse to answer, B81 friends? MR. PIKE: Form. A. [refuse to answer. Q. Who is Sandy Berger? A, [refuse to answer. Q. That's somebody else that was affiliated with Bill Clinton at one poiat in time, correct? A, Erefuse to answer. Q. A close friend of Jefttrey Epstein's? MR. PIKE: Form. A. [refuse to answer, Q. He called the house within three weeks of the search warrant being executed. Did he tip off Jeffre; Epstein? MR. PIKE: Form. A. [refuse to answer. Q. Is he somebody that's involved with underage minors? A. Trefuse to answer. Q. De you know Igor Zinoviev? A. refuse to answer, Q. Andrea Metrovich? A, Irefuse to answer. Q. Have you flown on the airplane with Alan Dershowitz before? 21 (Pages 78 to @1) U.S. Legal Support (954) 463-2933 82 MR, PIKE: Form. A. refuse to answer. Q, And Jean Luc Brunel is somebody who you have been on the airplane with several times, correct? A. Lrefuse to answer. MR. PIKE: Form, Q. And when Jean Luc Brunel is on this airplane there are underage minor -- minor females on the airplane with you, correct? MR. PIKB: Form. A. [refuse to answer. Q. Is there 2 back room to this airplane? Is there any sort of separation or is it all one big room? MR, PIKE: Form. A, Trefuse to answer. Q. So if Jeffrey Epstein and Jean Luc Brunel are engaged in sex acts with underage miners did you -~ A, [refuse ~ Q. Sorry ~did you observe any of those acts? A. [refuse to answer. MR. PIKE: Form. Q. And on aumerous of the flights the flight logs indicate someone's name then oftentimes initials, bat sometimes it would just say "three females", Do you A. Lrefuse to answer, MR. PIKE: Form. Q. Who's Claire Hazel? A, [refuse to answer, Q. Do you know JoJo and Lyan Fontanella? A. Erefuse to answer. Q. They're the house managers up at the mansion up in Manhattan, correct? MR. PIKE: Form. A, Lrefise to answer, Q. And they assist Mr. Epstein ia engaging in underage sex with minors in New York, correct? MR. PIKE: Foon. A. Trofuse to answer. Q. They also maintain a pretty close retationship with the police? A. Lrefuse to answer. Q. And that's a big component also, right, that Jeffrey Epstein has -- is friendly with the law enforcement, correct? MR. PIKE: Form. A, Erefuse to answer. Q. Like law enforcement would do favors for not only Jeffrey Epstein but his various assistants. If i you were speeding around the neighborhood they woalda't | OOIHRH® WN 10 11 12 13 14 45 16 17 18 19 20 21 22 23 24 WON UR Wn 10 lk 12 13 14 is 16 17 18 io 20 22 22 23 24 25 84 give you a ticket, correct? MR. PIKE: Form. A. [refuse to answer. Q. Was it ever your job to call the police departinent and ask if any police reports were on file or anybody complained about the activities at Jeffrey’ Epstein's house? MR. PIKE: Form, A. [refuse to answer. Q. Have you ever gone physically to the police department? A. [refuse to answer. Q. Was there a flight where you flew alone with Jean Luc Brunel? A. I refuse to answer. Q. Have you ever flown on the plane with Prince Andrew? MR. PIKE: Form. A, [refuse to answer. Q. Do you know Zinta Braukis? A. Erefuse to answer. Q. That's another model that Jeffrey Epstein knows, correct? A. Lrefixse to answer. 85 Q. Somebody that ite had engaged in sex with when she was underage? A, Irefuse to answer. Q. She actually got a modeling contract out of in? MR. PIKE: Form. A, Lrefuse to answer. Q. Why does Jean Luc Brunel and Jeffrey Epstein fly together so often? MR. PIKE: Form, A. Trefuse to answer. Q. And why does Ghislaine Maxwell also fly so often with Jeffrey Epstein and Jean Luc Brunel? A. Lrefase to answer. MR. PIKE: Form, Q. Isn't it true that all three of them are obsessed and addicted to sex with underage minors? MR. PIKE: Form. A. refuse to answer. MR. PIKE: Brad, how much longer do you have? MR. EDWARDS: How fong? You want to take a break? MR. PIKE: Yeah, MR. EDWARDS: Sure, It's going a fot faster than I thought it would. 22 {Pages 82 to 85) U.S. Legal Support (954) 463-2933 13 wavrnneone PEER Ee BON ro is 21 22 23 24 25 i VIDEOGRAPHER: Off the record, 11:33 am. 3 (Recess taken at 11:33 a.m.) | 2 (Deposition resumed at 11:43 a.m.) 1 3 VIDEOGRAPHER: On the record, 11:43 am. loa BY MR. EDWARDS: 5 Q, Allright. There's one more message that I ; 6 wanted to ask you about, As I mentioned, I'm not going! 7 to go through ail of the messages that [ have, but | 8 there's one from 9/4/2005, 9:08 a.m. from Adriana, "Is | 9 it okay for Tatum to stop by aud drop something?” | 10 A. [refuse to answer. ji MR. PIKE: Form, | a2 Q. So what were your hours working for Jeffrey | 13 Epstein? | 14 A. Lrefuse to answer. 1 15 Q. Imean, some of these messages are 9:00 in the 16 morning and others are as late as 8:30 or 9 at night, i 17 So what were your hours? | 1s A. Irefuse to answer. 19 Q. Another message from 9/4 also, same day, | 20 “Ashley," I think, “confirmed an 11 a.m., Vanessa isat | 21 4:30 p.m." | 22 MR. MERMELSTEIN: I think that's one you did. «| 23 MR. EDWARDS: Ob, yeah? Okay. | 24 Q. All right. Do you remember that message? } 25 87} A. [refuse to answer, | 1 MR. EDWARDS: Da you care how I attach it i 2 since it's « i 3 MR. ROSS: No. ; 4 MR, EDWARDS: I'l attach it as whatever it i, is. | 6 MR. ROSS: 4, | 4 MR. EDWARDS: 2-- well, [lljust go 2H since | 8 it's amessage, You don't have 2 problem with | 9 thar? 249 | 10 MR, ROSS: Whatever. Pu (Whereupon, Plaintiff's Exhibit 2H was marked 12 for identification.) | 43 Q. Do you still consider Jeffrey Epstein a | 44 friend? , as A, Trefuuse to answer. i 16 MR. PIKE: Form, {47 Q. Did you ever think of Jeffrey Epstein as a i 18 friend? p19 MR. PIKE: Fonn. 1 20 A, [refuse to answer, | al Q. Other than the people that I've mentioned | 22 of— you know, President Pastrana and Ehud Burak and) 23 Prince Andrew did you meet any other people of royalty, 24 being friends with Jeffrey Epstei | 2s 88 MR. PIKE: Form. A. I refuse to answer. Q. Can you tell us any of the other folks that Jeffrey Epstein would supply underage minor girls to? MR. PIKE: Form, A. Trefisse to answer. Q. Do you know a maa by the name of Glean Dubin? A. [refuse to answer. Q. Do you know his wife? A, refuse to answer. Q. His wife at some point in time was associated with Jeffrey Epstein; is that correct? A. [refuse to answer. Q. And her name's Eva Dubin; is that right? A. [refisse fo answer. Q. Either way, isn't it true that Jeffrey Epstein then started supplying anderage femates to Glenn Dubin? MR. PIKE: Form, A. [refuse to answer. Q. Do you know Johanna Sjoberg? A, Crefuse to answer. Q. Is that somebody who also worked for Jeffrey Epstein? A. [refuse to answer. MR. PIKE: Form. Q. Did Jeffrey Epstein ever get a legitimate massage from somebody that's a masseuse? MR. PIKE: Form, A, [refuse to answer. Q. The underage females that we've talked about particularly, LM, EW, and Jane Doe, those girls were not prostitutes, were they? A. Lrefase to answer. Q. These were just girls whe were in 8th, 9th, 10th grade in high school, right? A, Urefase to answer. Q. These were girls that you knew had never committed prostitution in the past, right? A. Erefuse to answer. Q. And that goes for all of these girls on the phone list of underage minors to call, these were not prostitutes, correct? A. Trefuse to answer. Q. You never called a prostitation or escort service for Jeffrey Epstein, did you? MR. PIKE: Form. A, [refuse to answer. Q. And as well you never called a legitimate massage parlor for Jeffrey Epstein, correct? refuse to answer. 23 (Pages 86 to 89) U.S. Legal Support (954) 463-2933 MR. PIKE: Form. Q. He devised this scheme of having underage minor girls bring him other underage minor girls so; that he could gain access to his target age group, 12 to 16 years old, correct? A, I refuse to answer. Q. Have you heard Jeffrey Epstein say "The younger the better?" A. [refuse to answer. | Q. And did Jeffrey Epstein tell you that it made him happy the younger the girl was? | A, [refuse to answer. MR. PIKE: Form. Q. The less developed the girl is the more excited Jeffrey Epstein gets; is that true? MR. PIKE: Form. A. [refuse fo answer, Q. Do you ever plan to talk to Jeffrey Epstein in | the future? A. Trefuse to answer. MR. PIKE: Form. Q. Would you ever work for bim again? A. Lrefuse to answer. Q. Why didn’t you stop working for him sooner? A, Trefuse to answer, MR. PIKE: Form. Q. Did you ~ well, you knew that it was illegal what he was doing at the time you were doing it, correct? A, [refuse to answer. Q. Did you know that you were part of a large child molestation ring? MR. PIKE: Form. A. [refuse to answer. Q, Did you ever tell aayone while you were working for hint that you wanted to stop? A, [refuse to answer. MR. PIKE: Form. Q. Did you continue working there because you were just scared to stop? A. Liefuse to answer. MR. PIKE: Form. your services for his child molestation ring? A. [refuse to answer. MR. PIKE: Form, Q. Did Jeffrey Epstein ever threaten you? A. Trefuse to answer. MR. PIKE: Form. Jeffrey Epstein might do to you if you quit performing, | | | | | 25 92 Q. Did Ghistaine Maxwell ever threaten you? A. Lrefiase to answer. Q. How was it decided who would call which girl? A. Erefuse to answer. Q. And by that, just so it’s clear, like I said, there's going to be many, many, many message pads, I have not counted them, but a lot created by either yourself or someone named Janusz Banaziak or Louclla Rabuyo, Alfredo Rodriguez, Nadia Marcinkova, Sarah Kellen, various people that we know to have been employed at Jeffrey Epstein’s home. And it seems that on one particular day Sarah may call several girls, you may call several girls, Nadia may call several girls. Whe is directing which — which of you, which of the assistants is going to call the underage minor to give them an appointment? A, Trefuse to answer, MR. PIKE: Form, Q. And what would happen on the occasions where Jeffrey Epstein says he's going to be in towa aud then he's ultimately not in towa but 2 girl shows ap anyway? MR. PIKE: Form. A. frefuse to answer. Q. Weren't you just toid just to pay her to keep her happy? 93 A. Exefuse to answer. Q. And isn't part of the whole scheme that these girls were typically told "Don't tell anybody what goe on inside this house,” right? MR. PIKE: Form. A. I refiuse to answer. Q. And did Jeffrey Epstein tell you that because these girls are young and they're poor and they're underprivileged type girls they're likely not geing to say anything anyway? Isn't that what he told you? MR. PIKE: Form. A. refuse to answer. Q. Did Ghistaine Maxwell talk to you about that as well? A. I refuse to answer. MR. PIXE: Form. Q. Have you seen Jeffrey Epstein angry? A. Trefuse to answer. Q. Isn't it true that he’s very nice and engaging as long as he gets his way and gets you te caoperate, right? A. Lrefuse to answer. Q. But if he doesn't get his way he gets very, very angry and mad and scary; isn’t that true? A. Lrefluse to answer. 24 (Pages 90 to 93) U.S. Legal Support (954) 463-2933" Pr 16 944 Q. And you've seen both sides of him, right? A. [refuse to answer. Q. In fact, you know of girls whe were £3 years old and cooperated with everything he said because they} felt they had no choice up in that bedroom, right? A, Trefuse to answer. MR. PIKE: Form. Q. And you also know girls who resisted and were yelled at and told to grab their money and get out of there, right? A. [refuse to answer. Q. Wouldn't you agree that that house upstairs can be somewhat confusing in how it's — how it's laid out? A, [refuse to answer, Q. Io fact, there's a stairwell that starts from the kitchen, there's a door and it almost blends in in the kitchen with the other closets, correct? A. [refuse to answer. MR. PIKE: Form, Q. But you open that door and there's a stairway i i | i | | | | t | i | | | | | j | i : | i : | \ | that Ovists it seems to the left and there's another door at the top of that stairway, right? A. [refuse to answer. And then when you exit that stairway you take 95 } | a right and you head towards a little hallway that eventually leads into Mr. Epstein's bedroom, right? A. [refuse to answer. Q. And if it’s your first time in that bedroom as a 14-year-old girl and you don't like what's happened | up there would you agree that it's a tough way to find | i \ | yous’ — a place to find your way out of? 1 MR. PIKE: Form. A, [refuse to answer. Q, Did Jeffrey — didn’t Jeffrey Epstein tell you that he would act as a father-type figure fo these giris? A, [refuse to answer. MR. PIKE: Form. Q, And he would propose that what they are doing! for him or with him despite the law is okay? A. Lrefuse to answer. MR. PIKE: Form. Q. And they could continue to make a lot of money! ‘if they would come over and be his sex victims, right? ; MR. PIKE: Form. A. [refuse to answer. Q. And you were aware when my client, LM, was pregnant at 16 years old that Jeffrey Epstein bought everything on her baby registry, right? | ; | i i ' { i 4 COA KRHRON HE 96 A. [refiuse to answer, MR. PIKE: Form. Q. Was it you or Sarah Keller that took ail of the gifts over to her home? MR. PIKE: Form, A. Trefuse to answer. Q. Tbelieve it was Sarah Kellen in a -- did Jeffrey Epstein own a Mercedes? MR. PIKE: Form. A, [refuse to answer. Q. And do you remember when Sarah Kellen loaded: up the Mercedes with all the baby gifts and took it to my client's trailer? A, [refiuse to answer, Q. And that was so that while LM -- that was to thank her while she was pregnant she continued to bring him 13-, 14-, and 15-ycar-old girls to molest, correct? MR. PIKE: Form. A, Erefuse to answer, Q, Because LM would no longer qualify as somebod: he'd be sexually interacting with as she was pregnant, correct? MR. PIKE: Form. A. Erefuse to answer. interacting sexually with Mr. Epstein are if you have tattoos, right? A. [refuse to answer. Q, If you're African-American or black? A, Trefuse to answer. Q. You've never known him to interact with an African-American or black girl, have you? A, [refuse to answer, Q. Ef you've been pregnant? A, Lrefuse to answer. Q. Or if you are pregnant, correct? A, I refuse to answer. Q, But certainly he was not above having a pregnant 16-year-old girl bringing him underage minor females, correct? A. Lrefuse to answer. Q. In fact -- MR. PIKE: Form. Q- favor in that be was giving her money for providing a was his belief that he was doing her a service, correct? MR. PIKE: Form. A. refuse to answer. Q. Is it Jeffrey Epstein's belief that he did these girts a favor? 25 (Pages 94 to 97) U.S. Legal Support (954) 463-2933 wot nnr Ne 25 A. Lrefuse to answer, Q. I mean, doesn't he think that these girls are lucky that be ever — that they ever — that he ever allowed them out of their trailer and into his mansion, correct? A. [refuse to answer. MR. PIKE: Form, Q. We've defined the molestation statute or at Jeast I read it to you earlier and now we've talked about this scheme of Jeffrey Epstein gaining access to this number of underage minor females. At the time when you were working for him did you recognize him ag a serial child molester? ! MR. PIKE: Form. j A. [refuse to answer, Q. Do you know of anybody that ever worked for him that quit working for him because of what he was doing? A. Lrefiuse to answer, MR. PIKE: Form. Q. Do you know Michael Friedman? A, Trefuse to answer. Q. Is that somebody you ever met there? A. [refuse to answer, bring underage minor fernates from? A. refuse to answer. Q. Do you know why he chooses the countries that! he chooses to import underage minor females from? A, [refuse to answer. MR. PIKE: Form. Q. Was Nadia -- do you know how old Nadia Mareinkova was when she came to this country? A, [refuse to answer. i Q. Have you had conversations with Nadia i Marcinkova about Jeffrey Epstein bringing her to this, country? | A. Erefuse to answer. | Q. She's been described by some as his | Yugoslavian lesbian sex slave. Is that something that | is an accurate description based on the observations | you have? | A. [refuse to answer. | MR. PIKE: Form, \ Q. Did you ever engage in any lesbian sex with | Nadia Marcinkova? | A, I refuse to answer. { Q. Has Sarah Kellen ever had sex with Jeffrey | Epstein? MR. PIKE: Form. 100 A. Lrefuse to answer, Q. Do you know how it is that Sarah Kellen met Jeffrey Epstein? A. Trefuse to answer, Q. Do you know Story Cowles? A, Trefuse to answer, Q. You know who Sergio Cordero is? A. [refuse to answer, Q. Well, that’s somebody who also assists Mr. Epstein in bringing him underage minor females for] sex, correct? A. Trefuse to answer. ‘MR, PIKE: Form. Q. And Khalid Monroe, you know who that is? A. [refuse to answer. Q, Also somebody that through MC Squared or some| affiliation with that modeling agency would help for Jeffrey Epstein to gain access to underage minor females for sex, correct? MR. PIKE: Form. A. [refuse to answer, Q. And do you know of trips that Mr. Cordero, Mr. Brunet, and Mr. Epstein took to Brazil specifically for the purposes of Mr, Epstein engaging in sex with 101 MR. PIKE: Form. A, Lrefuse to answer. Q. Are you -- you are aware that Jeffrey Epstein pled guilty to two felonies related to his sexual interactions, correct? A, I refuse to answer. Q. Okay. VIDEOGRAPHER: Excuse me, counsel. MR. ROSS: { object on privilege grounds -- attorney-client privitege grounds. MR. EDWARDS: Okay, fine, { was trying fo get ‘imo an area we may get answers. VIDEOGRAPHER: Coutd 1 just get you to put your phone on the table? I'm starting to get interference, MR. ROSS: The phone? VIDEOGRAPHER: Yes, sir. MR. EDWARDS: You got a secret phone? VIDEOGRAPHER: It's anytime it receives any kind of information. MR. ROSS: Oh, okay, yeah, it's VIDEOGRAPHER: It's not that it's ringing. MR. ROSS: Right. It's not doing it now. VIDEOGRAPHER: I apologize for the interruption. eee a cde 2 ce RE SE eee Re 26 (Pages 98 to 101) U.S. Legal Support (954) 463-2933 wwe Oo OInn T T | | | i } { i i i | | | | | | | i 4 | | | | i | | | 102 Q. Allright. Eask you that question because there was also something called a non-prosecution agreement. Are you familiar with that document? A, [refuse to answer, MR. ROSS: Attomey-client privilege. Q. And that is also a document that included your mame as a co-conspirator; are you familiar with that? A. [refuse to answer. MR. ROSS: Attorney-client privilege, Q. And that is because of your invelvement with caiting on the telephone auderage minors to bring them to Jeffrey Epstein’s house, correct? A. [refitse to answer. Q. Or for your involvement in scheduling appointments in Jeffrey Epstein's appointment book for underage minor —,underage minor females to be involve: with Jeffrey Epstein sexuaily, correct? MR. PIKE: Form. A. I refuse to answer. Q. It is certainly not because you sought out this child molestation ring in hopes of rising to the top, correct? MR, PIKE: Form. A. Lrefisse to answer. Q. Dida't you do everything that you did that 103 | anybody could ever say is illegal at the direction of Jeffrey Epstein? i A, [refuse to answer. | Q. And if it wasn't at the direction of Jeffrey i Epstein it was at the direction of Ghislaine Maxwell or | Sarah Kellen, correct? | MR. PIKE: Form. | A. Trefiase to answer. | Q. Imean, those things were not things that you | Jeffrey Epstein; isn't that right? | MR. PIKE: Form, | A, [refuse to answer. | Q. And you continued to do these things either | out of fear or because you were just impressed with | Jeftrey Epstein's lifestyte? | A, refuse to answer. { Q. Aren't you angry for him involving you in this | criminal activity? I A, [refuse to answer. | MR. PIKE: Form. Q. Do you ever intend in the future to talk about what he did aud what he involved you in? ' MR. PIKE: Form, | A. refuse to answer. i OO IAH RWHP 12 — 104 Q. Wouldn't you like to separate yourself being the person that you are from this person who brought you inte this mess? MR. PIKE: Form. A. Lrefuse to answer. Q. Is Jeffrey Epstein paying for your attorney now? MR, PIKE: Form, A. refuse to answer. MR. ROSS: Well, actually you can answer. A. No, my parents help me, Q. Are you aware of Jeffrey Epstein's closest friends now? A Erefluse to answer. MR, PIKE: Form, Q. Who are the people that you believe are Jeffrey Epstein's enemies? MR, PIKE: Form. A. Trefuse to answer. Q. Did you ever find out that Jeffrey Epstein and Ghislaine Maxwell had been targeting and preying upon underage females for sex for more than a decade? MR. PIKE. Form. A. Lrefuse to answer. you know? A, Lrefase to answer, MR. PIKE: Form, Q. Since being on house arrest has Jeffrey Epstein continued to engage in sex with underage minor| females? MR. PIKE: Form. A. [refluse to answer. Q. Knowing that his habit was more than ~ was at least two underage minor females for sex every single day do you believe that he stopped? MR. PIKE: Form, A. Trefuse to answer, Q. Isn’e it your belief that he will continae to do that once ail of these cases are over? A. Trefase to answer. MR. PIKE: Form, Q. Isn't it true that Jeffrey Epstein believes that he is entitled to have sex with whomever he wants including 12-, 13-, 14-year-old girls? MR. PIKE: Form, A. [refuse to answer, Q. Do you know whether he continues -- do you imow whether he intends to continue to moiest underag minors within the United States? 27 (Pages 102 to 105) U.S. Legal Support (954) 463-2933 we OIA He wR 10 12 13 14 as 16 17 18 19 20 aL 22 23 24 eeowd}x,HVewWNeH 10 12 13 14 15 16 7 18 19 20 2a 22 wa 24 25 MR. PIKE: Form, A. [refase to answer. Q. Do you know Mike Sanka? A, [refuse to answer. Q. That's somebody else that assisted Jeffrey Epstein in gaining access to underage minor females that were foreigners, correct? A. Trefuse to answer. MR. PIKE: Form. Q. He's atso involved in the modeting ageacy, too, correct? MR, PIKE: Form. A, Lrefase to answer, Q. That's a friend of or former friend of Jean Luc Brunel's? A. I refuse to answer, Q. How many times has Jean Lue Brunel shown up al Jeffrey Epstein's house with anderage minor females? MR. PIKE: Form. A, [refuse to answer. Q. And when that would happen isn't it true that they would have orgies with these underage minor females? MR, PIKE: Form, Q. What was done ~- or let me ask it a different way. Strike that. Where is the scheduling book for the massage appointments for Jeffrey Epstein? MR. PIKE: Form. A. [refuse to answer. Q. Is that something else that was removed from the home prior to the search warrant being executed? | I | | | | | A, refuse to answer. MR, PIKE: Form. i Q. Do you know how it is that -- well, did | Jeffrey Epstein ever tell you that because of the | people he knew he would not be going to prison for the | crimes that he committed? i A. Trefuse to answer. MR. PIKE: Form. Q. And is it your understanding that Ken Starr had played a major role in devising the non-prosecutio: agreemeut or having the government agree not to prosecute Jeffrey Epstein for his crimes against minors? A. I refuse to answer. MR. PIKE: Form, Q. Is it also your understanding that Bill Clinton played somewhat of a role in helping Jeffrey Ice ag pS te woot anue ene 24 108 Epstein out of the trouble that he would have been in related to his sexeat interactions with minor females? A. Lrefuse to answer. MR. PIKE: Form, Q. Did Jeffrey Epstein tell you that you need fo cooperate if you want the protection that me and my connections can give you for this activity? MR. PIKE: Form. A. Lrefuse to answer, Q. You admit that you called LM on the telephone for her to come to Jeffrey Epstein's house to be molested by Jeffrey Epstein when she was an underage: femaie? A. Lrefuse to answer. M&. PIKE: Form. Asked and answered twice. Q. Do you agree that you called EW ow the telephone for the purposes of her coming to Jeffrey Epstein's house for him to sexually molest her? MR. PIKE: Same objection. A. [refuse to answer. Q. And do you agree that you called Jane Doe and told her to come to your house to work, meaning for Jeffrey Epstein to sexually molest her? MR. PIKE: Asked and answered. Q. The first trial that is set in these cases is in July of this year. Do you intend to be in the local area? MR. ROSS: You can answer. A. Yes. Q. Okay. And what address will yeu be at? MR. ROSS: You can answer. A. 1040 South Shore Drive. Q. That's Miami? A. Miami Beach, Florida. Q. And the ZIP is? A, 33141. Q. And I presume that if [ needed to find you or locate you or anything else I could go through your attorney? A. Yes, Q. Okay. Who do you live at that address with? MR. ROSS: You can answer. A. With my husband and my mom-in-law and his sister as well. Q, And your husband's name is Duncan? A. Duncan Ross. Q. And your mother-in-law’s name? A. Monica Ross. Q. And who else lives at the house with you, I'm 28 (Pages 106 to 109) U.S. Legal Support (954) 463-2933 1 2 3. 4 5 6 T, 8 9 19 25 110 sorry? A. His sister. Q. And her name is? A. Stella Erin Ross. Q. And have you told Monica or Stella your involvement with Jeffrey Epstein? A. Lrefuase to answer. Q. Have you told your parents? A. [refuse to answer. Q. Are your parents in the country now? MR. ROSS: You can answer. A. No. Q. Do they have plans to come back? MR. ROSS: You can answer. A. They may visit, I'm not sure. Q. But on 2 permanent basis they're in Poland? A. Yes. Q. Okay. What's the address where they are in Poland? A. Kuznicy Kollatajowskia 33, Warsaw, Poland. Q. She's great, I’m sure she got that. A. Weuld you like me to spell it out? K-U-Z-I-N-C-Y, second word, K-O-L-L-A-T-A-J-O-W-S-K-LA, Warsaw, Poland 02495. MR. EDWARDS: One way fo never find a witn lil | | | | / | ; i i is just move to Poland. There's no way. | MR. ROSS: Couldn't get anyone to type the i subpoena. * { MR. EDWARDS: Right, exactly. Alf right, [ i don't have any other questions for you. Thank you. | ‘THE WITNESS: Thank you. | CROSS-EXAMINATION \ BY MR. MERMELSTEIN: | Q. Okay. Mrs. Ross, I have some questions for | you. Your husband, Duncan Ross, what does he do for a living? A. He'sa Ph.D. student, Q. And what is he a Ph.D. in? A, He works on bone marrow transplant immunology. Q. Sois he a medical doctor? A. He's scientist, He's working on his Ph.D. degree. Q. And which schoot is he working on his Ph.D. at? A. University of Miami. Q. And how long has he been doing that? A. I cannot recall when he started but we were already married. Maybe one or two years into my marriage. 1 do not recall the exact time. | | | | { ] | 1 | | | | t Q. And I believe you testified that you met him COI nUeune DREHER Ee PE Re PSWOYTAHERWNHERO 22 24 25 ni] in Europe, correct? A. Correct. Q. And did he have a different employment or profession then? A. Yes. Q, What was he doing then? A, Well, at that time he was serving in the entertainment business. He was DJing and -- yeah. ‘When I met hima he came to Europe for a DJ event, DJing} event, Q. And where was that in Europe? A. He went to Spain and then [ was in Monaco at the time and he knew the people that | was there with and we were introduced, That's where we miet. Q. And did he have connections to modeling in the United States? A. Yes. Q. And how did he have those connections? A. I'm ~ you know, F'm not sure. 1 don't know at this time, but he knew agencies here and he was doing, I believe, some photographic work as well himself. Q. Se he was a DJ and a professional photograph — photographer? A. Yes. You may say so, yes. Q. And 2 scientist as well? A. Yes. Q. Did he de work for particular modeling agencies in the United States? A. [mean, do you +I don't understand your question. Do you mean like -- Q. Well, did he perform work or services for particular modeling agencies in the United States? ‘A. Well, I believe he would hire models from. modeling agencies, yes. Q. He would hire models? A, Yes, for -- you know, that's how -- how it works. You hire a modet from a modeling agency fora particular job, a client that you may have. Q. So as a photographer he would hire models for] a particular modeling agency? MR. PIKE: Form. A. Yes. Q. And do you know which modeling agencies he typically worked with? A, Well, I presume Elite Models because, you know, he had connection and he invited me. I think just various Miami Beach - you know, Miami, South Beach modeling agencies. Q. Did he work for MC Squared? 29 (Pages 110 to 113) U.S. Legal Support {954) 463-2933 COIR HRWNE 10 ai 12 13 14 is 16 Weta eYOH ie a 12 13 14 15 16 17 18 1g 20 21 22 23 a4 14] 116 A, [refuse to answer, | 2 MR. PIKE: Form. Q. In 2004 and 2005 you were employed by Jeffrey | 2 A. 1 refuse to answer. Epstein, correct? 1 3 Q. And as young underage girls whe were MR. PIKE: Form, | 4 impressed, intimidated, and in awe of his wealth they A. refuse to answer. ' 5 would be unlikely to -- to complain fo authorities that Q. And as an employee of Jeffrey Epstein you were 6 he was engaging in sexual activity with them? under his instruction and supervision, correct? [oT A. [refuse to answer. MR. PIKE: Form. i 8 MR. PIKE: Form. A. [refuse to answer. i 9 Q. Okay. Did Jeffrey Epstein instruct you to MR. PIKE: Let's go off the record for a ; 10 call girls on the telephone to schedule appointments second. | 12 forthe to come to his Palm Beach house for massages| MR. MERMELSTEIN: Sure, | 12 which were, in faet, to be sexual activity? VIDEOGRAPHER: Off the record at 12:12pm. | 13 MR. PIKE: Form. (Discussion off the record.) ' 14 A. [refuse to answer. MR. MERMELSTEIN: Fil be briefon the general | 15 Q. Prior to May 2005 did you call Jane Doe 4 to questions, ; 16 schedule appointments for her to come to the Epstein VIDEOGRAPHER: On therecord, 12:14pm, | 17-—sthowse to engage in ~ to give Jeffrey Epstein a massage BY MR. MERMELSTEIN: | 18 which would, in fact, be sexual activity with Jeffrey Q. And as an employee of Jeffrey Epstein were you} 19 Epstein? also subject to the — to the instructions and } 20 MR. PIKE: Form. supervision of Ghislaine Maxwell? {an A. Lrefuse to answer. MR. PIKE: Form. | 22 Q. Okay. Prior te May 2005 while you were at the A. [refuse to answer. \ am. Epstein house in Palm Beach did you receive ealis from| Q, And as an employee of Jeffrey Epstein did you \ a4 Jane Doe 4 regarding the scheduling of an appointment} |_28__forlerto come tothe Epstein house to give Jeffrey _ | 11? primary assistant Sarah Kellen? i 1 Epstein a massage? MR. PIKE: Form. ; 2 MR. PIKE: Form, A. Lrefiuse to answer, {| 3 A. I refuse to answer. Q. Okay. Did Jeffrey Epstein tell you that — i 4 Q, When Jane Doc 7 ~ let me strike that. that he recruited from western Palm Beach County fo 5 Do you kuow Jane Doe 7? underage girls to come to his Palm Beach mansion for | 6 A. Irefuse to answer, sexual activity? | 4 Q. When Jane Doe 7 was a minor female did you MR PIKE: Form. | 8 call Jane Boe 7 to schedule appointments for her to A. f refuse to answer. 2 come to the Epstein house in Paim Beach to give Epstein Q. And did Jeffrey Epstein have a computer | 10 a massage? database at his Paim Beach mansion where he listed ik MR. PIKE: Form. underage high school girls in Paim Beach County and =| 12 A. [refuse to answer. their contact information so that he could have these i 13 Q. When Jane Doe 7 was a minor female did you underage minors come to his house for sexual activity? ! 14 receive calis from Jane Doe 7 while you were at the MR. PIKE: Form. | 15 Epstein house for her to come to the house by A. [refuse to answer, | 16 appointment and give Jeffrey Epstein a massage? Q. And did Jeffrey Epstein tell you that the [ou MR. PIKE: Form. reasom he brought in underage minors from western Paim, 18 A. [refuse to answer. Beach Couaty is because he anticipated they would be i 19 Q. The computer database that Jeffrey Epstein impressed, in awe, and intimidated by his wealth? 20 maintained girls from western Patm Beach County who MR, PIKE: Form, | 21 would come to the house in Palm Beach to give Epstein A. Erefuse to answer, | 22 massage, did that computer database include the name Q. And as young girls who were impressed and in | 23 and contact information for Jane Doe 2? awe and intimidated of his wealth they would do whathe| 24 MR. PIKE: Form. asked them to do? A. Lrefuse to answer. 30 (Pages 114 to 117) U.S. Legal Support (954) 463-2933 COI Te wnh 10 12 13 14 1S 16 3 18 19 20 21 22 23 24 25 CeIHORwWNe 10 42 13 14 15 16 17 18 15 20 22 22 23 24 25 118 Q. Do you know who Jane Doe 2 is? A. Irefuse to answer. Q. Do you know who Jane Doe 5 is? A. refuse fo answer. Q. Did the computer database that Epstein maintained on his computers in his home have the name and contact information for Jane Doe 5 so that Epstein | could contact her for — for massages in his Paim Beach} home? | MR. PIKE: Form. A. [refuse to answer. Q. Deo you know the name Jane Doe 6? A, F refuse to answer. Q, Did the computer database that Epstein mai ned in his home of underage girls who he would have come over for massages and sexual activity dtd that computer database include the name and contact information for Jane Doe 6? A. Trefuse to answer. Q. Do you know the name Jane Doe 3? | A. I refuse to answer. { Q. Did the computer database that Jeffrey Epstein | maintained in his home include the name and contact | information of Jane Doe 3 so that he could contact Jane Doe 3 to come massage which would become sexual activity? A, Trefuse to answer. Q. Did the computer database that Jeffrey Epstein maintained in his home include the name Jane Doe 4? MR. PIKE: Form. A. I refuse to answer. Q. Do you know Jane Doe 4? A. Lrefuse to answer. Q. Did the — did Jeffrey Epstein tell you that he maintained the contact information for Jane Doe 4 in his computer database in his home se that he could contact her to come to his Palm Beach mansion for massages? MR. PIKE: Form. A. [refuse to answer. Q. Did you know for a fact that the computer database included the name Jane Doe 4 so that Jeffrey Epstein could contact her and she would come to the Palm Beach mansion te give Jeffrey Epstein a massage? | MR. PIKE: Form, A. Lrefisse to answer, Q. Did you know that the computer database that Jeffrey Epstein maintained his home contained the nam and contact information of Jane Doe 7 A. refuse -- sorry. | | | t { | | i | | 4 | | | i : i i OC OYIHRH AWN HE 120 Q. I'm sorry -- so he would contact Jane Doe 7 and have her come to his house to give him a massage? A. Lrefuse to answer. Q. Are you aware that the computer database that Jeffrey Epstein maintained in his home contained the name Jane Doe 8 so that he could contact Jane Doe 8 and] have him come to the house in Palm Beach for purposes of giving hima a massage? MR. PIKE: Form. A. [refuse to answer. Q. You removed three computers from the Palm Beach house with another gentleman prior to the search warrant being issued by the Palm Beach police; isn't that correct? A. Freflase to answer, MR, PEKE: Form. Asked and answered. Q. And Jeffrey Epstein instructed you fo remove those computers; is that correct? MR. PIKE: Form, asked and answered. A. I refuse to answer, Q. And Jeffrey Epstein told you that the reason he was instructing you to remove the computers was to hide his sexual activities with underage minors from the authorities? 121 A. [refuse to answer, Q. As an employee of Jeffrey Epstein did you know Janusz Banaziak? A. [refuse to answer. MR. PIKE: Form. Q. Was Janusz Banaziak also auemployee of Jeffrey Epstein? MR. PIKE: Form. A. [refuse to answer. Q. When Janusz Banaziak testified that you and another gentleman removed the three compaters from Jeffrey Epstein's home he was telling the truth, correct? A. Trefiuse to answer. MR, PIKE: Form. Q. Did you observe Jeffrey Epstein persuading, inducing, or enticing underage girls to engage in sexual activities with him? A. [refuse to answer. Q. Did you~ strike that. Did you observe Jeffrey Epstein persuading, inducing, or enticing girls who came to his house for the purpose of giving him a massage fo engage in sexual activity with him? MR. PIKE: Form, 31 (Pages 118 to 121) U.S. Legal Support (954) 463-2933 122 | 124 i i A, [refuse to answer. bok A. [refuse to answer 2 Q. Did Jeffrey Epstein tell you that he induced, | 2 Q. Did Jeffrey Epstein admit to you on aumerous 3 persuaded, or enticed underage girls to engage in | 3 occasions when Jane Doe 4 was an underage minor that he 4 sexual activities with him when they came to his Palm 4 rabbed Jane Doe 4's vagina? 5 Beack mansion to give him 9 massage? | 5 A. [refuse to answer. 6 MR, PIKE: Form. ; ss MR. PIKE: Fertz. 7 A. Trefuse to answer. i 7 Q. Did Jeffrey Epstein admit to you that on 8 Q. Would you instruct ~ when you spoke to | 8 occasions prior to Jane Doe 4 turning the age of 18 you sp. | Bs 2 underage girls to schedule appointments for massage in| 9 that he performed oral sex on Jane Doe 4? 10 Epstein's home would you instract these girls to lie 16 MR. PIKE: Form. a1 about their ages and say they were 18 years old when i A. Lrefuse to answer. 12 —_-youknew that they were younger than 187 12 Q. Did Jeffrey Epstein admit to you that on 13 A, Lrefuse to answer. 13 numerons oceasions prior to Jane Doe 4 reaching the age a4 Q. Did Jeffrey Epstein instract you as to what to 14 of 18 he would place a vibrator oa Jane Dee 4's 24 numerous occasions when Jane Doe 4 was an underage 25 minor he touched and groped her buttocks? 24 occasions to contact Haley Robson for the purpose of 25 scheduling underage girts for appointments to come to | | | | as say to the girls who you contacted by telephone to make = 15 genitals? 16 appointmnents to schedule massages in Epstein’s home? i 16 MR. PIKE: Form. 17 A. Lrefisse to answer. | a7 A, [refuse to answer. 18 MR. PIKE: Form. | 18 Q. Did Jeffrey Epstein admit to you that prior to 19 Q. And would Jeffrey Epstein tell you to have the | 19 Jane Doe 4 becoming 18 years of age he would masturbate 20 girls who you contacted by the telephone to make | 20 inher presence? 21 appointments to come to the mansion to give Jeffrey | 21 A. [refuse to answer. 22 Epstein massages, that they should -- that these girls | 22 MR. PIKE: Form to the last question. 23. should lie about their ages to Jeffrey Epstein? | as MR, MERMELSTEIN: Hum? 24 MR, PIKE: Form, | 2g MR. PIKE: Form to the last question. 2 Ss A. Lrefuse to answer. | 25 Q., Did Jeffrey Epstein admit to you that prior te 123} 125 L Q. Prior to May 2005 are you aware that Jeffrey | yy Jane Doe 7 reaching the age of 18 years old he would 2 Epstein had numerous appointments with Jane Doe 4 for} 2 touch her breasts? 3 her to come to the mansion to come to give him a ; 3 MR. PIKE; Form. 4 massage? i 4 A. refuse to answer. 5 A. Lrefise to answer. } 5 Q. Did Jeffrey Epstein admit to you that prior to 6 MR, PIKE: Form. | 6 Jane Doe 7 reaching the age of 18 he would grope her — 7 Q. Prior to May 2005 are you aware that Jane Doc | 7 — grope Jane Doe 7's buttocks? 8 4 would come to the mansion fo give Jeffrey Epsteina | 8 MR. PIKE: Form. 9 massage on a frequent and regular basis? | 9 A. [refuse to answer. io A, Erefuse to answer. ' 10 Q. And did Jeffrey Epstein admit te you that 42 MR. PIKE: Form. | LL prior to Jane Doe 7 reaching the age of 18 he would rab 32 Q. Are you aware that prior to May 2005 Jeffrey | 12 Jane Doe 7's vagina? 13 Epstein engaged with - engaged in sexual activities = | 1 A, Lrefiuse to answer. 14 with Jane Doe 4 at the Palm Beach mansion 50 to a 14 MR. PIKE: Form, 15 hundred times? jus Q. Do you know who Haley Robson is? 16 A. [refuse to answer. ; 16 A. Lrefuse to answer. 17 MR. PIKE: Form. { 37 Q. Did Jeffrey Epstein instruct you to call Haley 18 Q. Did Jeffrey Epstein admit to you that on | 18 Robson on numerous occasions to recruit underage girls 19 _aamerous oceasions he ~ when Jane Doe 4 was an 1 19 te come to the Palm Beach Mansion to give Jeffrey 20 underage minor he touched her breasts? | 20 Epstein a massage? 21 MR, PIKE: Form. | 21 MR. PIKE: Form, 22 A, refuse to answer. 1 22 A. Lrefuse to answer. 23 Q. Did Jeffrey Epstein admit to you that on | 23 Q. Did Jeffrey Epstein instruct you on numerous ' | | i 32 (Pages 122 to 125) U.S. Legal Support (954) 463-2933 1 2 3 4 5 € 4 8 9 10 1 12 13 14 is 16 Ww 18 19 20 21 ae 23 a 12 13 14 1s 16 17 18 19 20 au 22 23 24 25 126| the Palm Beach mansion and give Jeffrey Epstein a massage? A. [refuse to answer. MR. PIKE: Form. Q, Did Jeffrey Epstein advise you that Hatey Robson was his contact in westera Palm Beach County high schools for the purpose of recruiting underage giris to come to the Paim Beach mansion where he woul then engage in sexual activity with them? | A. Frefirse to answer, | i ' | | i i | | | d MR, PIKE: Form, Q. Did Sarah Kellen instruct you on how to contact underage girls for the purpose of bringing them | to the Palm Beach mansion for massages and what to say to these young girls? MR. PIKE: Form. A. Erefuse to answer, Q. Did Sarah Kellen train you im how to contact girls and recruit them to come to the Palm Beach mansion and — and provide Jeffrey Epstein with massages? A. Lrefuse to answer. ! MR. PIKE: Form, | Q. Was one of your primary duties scheduling | i day, for Jeffrey 12 | | | | | | | I | { ay Epstein to have underage girls come to the mansion to give him a massage? MR. PIKE: Asked and answered, form. A. [refuse to answer, MR. MERMELSTEIN: Okay. That's all i have. MR. PIKE: C have no questions. MR. EDWARDS: [only have a couple. TH go ahead and mark this as Number 4, (Whereupon, Plaintiff's Exhibit 4 was marked for identification.) REDIRECT EXAMINATION BY MR, EDWARDS: Q. This photograph appears to be Jeffrey Epstein, yourself, and Maer Roshan in this photograph taken fro: an interuet newspaper. Can you tell me where that picture was taken? A, Trefuse to answer, MR. PIKE: May I see that, counsel? Q. Was this related — this event, was it related to MC Squared? _ A. Lrefuse to answer. Q, Allright What is —{ know that you told as that you're not employed now because you're in school. ‘What was your last empioyment? A. Lwas working at the focal CPA firm. pin Lana ia Pessoa sed eel thea bt hdc new ha Anda Godin aaa cia aciahaecon Aantal OOIHRHeWNHH Q. Excuse me? A. CPA firm. Q. Okay. What was the name of that CPA firm?| A. William Owens, CPA, P.A. Q. William Owens, And is that in Miami? A. Correct. Q, Where did you work prior to that? A. Tworked for maybe less than a month at a clothing store. Q. What clothing store? A. Club Monaco. Q. Where's that? A. South Beach. Q. Where in South Beach? A, It's on Collins Avenue and I believe maybe 6th and 8th, I'm not sure. Q. Okay. Why'd you leave there? A. The clothing store? Q. Correct, A. Because I got the accounting job. Q. And that's what you want to be you said? A. Yes, um-hum. Q. Okay. And I suppose that you left the accounting firm because you went to school to finish] your degree? A. Well, Iwas working part-time and going to school part-time and it just became too challenging. The accounting program is very demanding, so I wanted| 10 dedicate myself to study. Q. How long were you at this accounting firm Williams Owens ~ William Owens? A. Maybe two and a half years about maybe. Something like that. Q. Albright. So we're in ~ when was it that you left there? A. May of 2009. Q. Okay. May '09, so that brings us back to tafe 2006 or something when you started there? A. Yes. That would be about right, yes, Q. And then it was sometime earlier than that in 2006 when you were at the clothing store? A. Yes. Q. And you were there for about a month? A. About, yes. Q. Give or take— A. Yes. Q. —a week or so? ‘Where -- where did you work prior to the clothing store Ciub Monaco? A, Twas modeling. 33 (Pages 126 to 129) U.S. Legal Support (954) 463-2933 COrnuUe YOR ai 12 i3 14 as 16 17 18 19 20 24 22 wavaneune 10 aL 12 13 14 15 16 17 18 19 26 au 22 23 24 25 Q. And where were you modeling? A. In Miami. New York. Q. For what agency? A, In Miami | was with Elite Models. | was with Michele Pommier -- Q. Who's that? A. Michele Pommier Agency. Q. Okay. How do you spell the last name? A. P-O-M-M-I-B-R. And then «- Q. Okay. That was in Miami? A Yes. Q. And then what agency did you werk through in New York? A. iD Modeis. Q. Excuse me? A. D Models. Q. 1D? A. Yes. Q. Just in the letter I ~ A. Yes. Q. - letter D? And who was the person that got you hooked up at ED Models? A. My husband had that contact. A. Em trying to think, Ido not recall exact timeframe. Q. Allright. Well, if the clothing store was sometime Inte 2006 are we talking about earlier in the year 2006 when you were working with Elite in Miami and 0D Models in New York? MR. ROSS: I'm going to ask you to invoke. THE WITNESS. fm sorry? MR. ROSS: You should invoke with regard to this timeframe you're talking about now. MR, EDWARDS: Okay. A. Trefuse to answer. Q. Okay. Can you teil me about any job that you had medeling or otherwise prior to working at 1D Modeis or with Elite? A. Recall «« just name any — Q. Any -- what was your — what employment did you have just prior to working with Elite Models and ID Models? A, Lwas working as a model in Europe. 1 graduated from high schoo! in 2002 and I dedicated that ‘year to modeling and so I was modeling. Idid not have employment. Q. Allright. So just so I understand you were modeling im Kurope, you came over here in 2002. O2YKHH BH wWNHHE we aInnewnnm 132 A, Um-hum. Q. There's a period of time from 2002 through 2086 where -- you know, 2006 you start with [D Model and again with Elite. {know when you came over here in 2002 you were with Elite also, right? A, Tm sorry, you're confusing me with the timeframe, Q. I'm confusing myself, how about that. Let's start over. 2002 you come over to the United States, you're working at Elite? A. Yes, I've been invited by Elite. Q. Okay. And then if} understand you correctly over time you continue to work with or through Elite? A. Weil, I've been, you know, changing agencies throughout the period. Q. Okay. What are some of the other modeling agencies you have worked for or with? A. Trefuse to answer. Q. Okay. The only other names of modeling agencies that you can answer are ID Models and Elites that correct? THE WITNESS: Should 1? MR. ROSS: Well, she’s already answered also Michele Pommier. 133 MR. EDWARDS; But I thought that was somebody through Elite, like they're -- MR. ROSS: No, no, no, Michele Pommier is a ~~ MR. EDWARDS: Different, okay. Q. Allright, Is there anybody else that you're able to ~ to tell me where you worked? MR. ROSS: Invoke as to any further information. THE WITNESS: I'm sorry? MR, ROSS: Invoke your privilege. A. Lrefuse to answer any questions. MR. EDWARDS: All right. That's all E got. MR, MERMELSTEIN: Can 1 just follow up a couple? RECROSS-EXAMINATION BY MR. MERMELSTEIN: Q. In what has been marked as Exhibit 2C is a phone message from you to Adri ~ from you to Jeffrey Epstein dated September 10th, 2005 at 1:15 p.m. And the message that you left was “Lauren confirmed 4 p.m.”, is that correct? A. [refuse to answer. Q, Is the Lauren referred to in this message Lauren Murphy? MR. PIKE: Form. 34 (Pages 130 to 133) U.S. Legal Support (954) 463-2933 134} 136 A. Trefuse to answer. | and no word index. ‘4. 1 2 Q. And did you schedule Lauren i 2 MR. MERMELSTEIN: I'll take a copy with a 3 MR. PIKE: Form. be 3 mini. 4 Q. — Lauren Murphy to come tothe Palm Beach | 4 (The deposition was concluded at 12:42 p.m.) 5 mansion as an underage female to give Jeffrey Epstein | 5 (Reading and signing of the deposition was 6 massages? | 6 waived by the witness and all parties.) 7 MR. PIKE: Form. 7 8 A. trefuse answer. j 8 9 Q. Also what has been marked as Exhibit2Fisa | = 9 10 phone message from you to Jeffrey Epstein dated 10 11 September Lith, 2005 at 9:15 a.m, And the message was] 11 12 that you got a car for a particular person. De you | 12 13 recall that? ; 13 14 MR. PIKE: Form. } 14 15 A. Trefuse to answer, 135 16 Q. Is the car that you obtained on i 16 a7: September 11th, 26005 for Jane Doe 47 } 17 18 MR, PIKE: Form. | 18 19 A, Trefuse to answer. | 19 20 Q, And Jane Doe 4 is.a girl who had been coming | 20 21 to the Palm Beach mansion to give Jeffrey Epstein a | 21 22 massage and engage in sexuat activities with him fora | 22 23 substantial period of times is that correct? 1 23 24 A. Lrefuse to answer. | 24 25 Q. And also what has been marked as Exhibit 2H - | 25 ee 135! 1 actually — 1 CERTIFICATE OF OATH 2 MR_ EDWARDS: fs that G? | 2 STATE OF FLORIDA. 3 MR. MERMELSTEIN: Are they similar? | : COUNTY OF BROWARD 4 MR. EDWARDS: Yeah, I guess they blocked out | ; i Sanat MCintiog, Repisered Probiselinal 2 names on one of them and they didn’t on the other. | Reporter, Florida Professional Reporter, Certified 6 MR. MERMELSTEIN: Right. Okay. 1 7 LiveNote Reporter, Notary Public, State of Florida, 7 Q. And what bas been marked as Exhibit2G isa | 8 certify that ADRIANA ROSS personally appeared before mt 8 message from you to Jeffrey Epstein dated i 9 on March 15, 2010 and was duly swom. 9 September 3rd, 2005 at $:50 p.m. And the message you! 2 Signed this 21st day of March, 2010. 10 left is, quete, "I left message for Ashley to confirm ' ov 11 for 11:00 a.m, and Vanessa for 4:30 p.m." 3 =e 32 Did you, in fact, leave that message? Gant A, Lehn 4 > 413 MR. PIKE; Fon. | a4 ‘vanet L.. McKinney 14 A. Trefuse fo answer. ' Registered Professional Reporter 25 Q, And this message that you left confirmedan | 15 Se enit hath Roe 16 appointment for Jane Doe 4 for 4:30 p.m., correct? | 16 Notary Public, State of Florida uv ‘AL Tresess fo mimics, | Commission No.: DDSS2183 18 MR. MERMELSTEIN: Alt right. That's all 1 | W7 Expires: June 2, 2010 1g have. 1 is 20 MR. ROSS: Waive. | 19 21 MR, MERMELSTEIN: Allright. (20) 22 VIDEOGRAPHER: Off the record, 12:42pm. | : : 23 ‘THE REPORTER; Are you ordering? | oa 24 MR. EDWARDS: Yes. | 24 25 MR. PIKE: I want a copy, a mini, no ASCii, } 28 i. 35 (Pages 134 to 137) U.S. Legal Support (954) 463-2933 i7 138 | CERTIFICATE OF REPORTER | STATE OF FLORIDA COUNTY OF BROWARD I, Janet McKinney, Registered Professional Reporter, Florida Professional Reporter, Certified | LiveNote Reporter, certify that I was authorized to and | did stenographically report the deposition of ADRIANA. ROSS, pages | through 138; that a review of the transcript was not requested; and that the transcript is a true record of my stenographic notes. I further certify that I not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties’ attorneys or counsel connected with the action, nor am 1 financially interested in the action. Dated this 21st day of March, 2010, Gast Ae Janet L. McKinney, RPR, EER Registered Professional Reporter Florida Professional Reporter Certified LiveNote Reporter I I | | I { ! | i | | fe a U.S. Legal Support (954) 463-2933 36 (Page 138) 35:8 acceptable 6:12,14,15 6:16 access 23:13 28:14 37:23 90:4 98:10 100:18 106:6 accounting 11:23,24 128:20,24 129:3,5 accurate 99:16 acquainta... 35:9 act 95:11 action 138:15,16 actions 59:17 activities 84:6 120:23 121:18 122:4 123:13 134322 activity 56:11 103:19 108;7 115:7 115;14 116:6,12,18 118:16 Ligsi 121:24 126:9 actresses 34:13 acts 26:6,12,16 82:17,19 adam 80:16 addicted 85:17 addiction 30:9 61:18 addition 32:4 34:11 57:8 additional 56:6 additionally 39:9 address 13:9,15 14:19,23 15:21,25 16:3,6,8 19:9,18 109:6,17 110:18 addressed 5:16 admit 108:10 123:18,23 124:2,7,12 124:18,25 125:5,10 adri 133:18 adriana B21 3:332 4:13 5:4 7:2,8,10 62:20 63:18 65:20 67:24 86:9 137:8 13833 adrianas 72:23 adult 25:10 35:7 adults 25:13 advise 13:11 126:5 advised 69:9 70:6 affiliated 81:6 affiliation 100:17 affirm 5:7 affirmed 733 africa 34:6 africanam... 9734,7 afternoon 68:8 age 22:8 24:12 24:13 25:6 43:7 45:4 51:12 90:4 124:8,13,19 125:1,6,11 agencies 9:1,14 29:16 112:20 113:4,8,10 113:19,24 132:15,18 132:21 agency $:12,14,19 9:6,7,10,12 10:18 18:25 19:5 29:17 100:17 106:10 113:13,16 130:3,7,12 agents 75:13 ages 47:11 122:11 122:23 agree 94:12 95:6 107:19 108:16,21 agreed 6:2 agreement 21:1,5 32:12 102:3 107:19 ah 67:14,20 69:1,4,11 69:13,15,16 69:17 70:1 ahead 14:11 33:10 127:8 ahha 15:14 airplane 40:25 41:4 76:3 79:11 79:13 81:24 82:4,7,9,12 airplanes 75:1,9 airport 79:5 al 1:8 4:14 alan 2:24 §:3 37:6,8 81:24 alfredo 9239 aline U.S. Legal Support (954) 463-2933 1393 77:19,22 alleged 34:10 allow 64:2 allowed 98:4 amendment 6:1,6,12 14:6 21:15 ansel 2:20 andrea 81:22 andres 76:16 andrew 37:1,3 84:17 87:24 andrews 2:4 angeles 34:5 angry 41:16 93:17 93:24 103:18 answer 6:3,4,11,11 13:13,16 14:3,21 15:9,11 16:12,18,19 16:22 17:4 17:6 18:7 18:10,13,16 18:18,21,24 19:2,6,10 19:14,16,19 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lyons 5:17 57:11 | mad 93:24 madam 6:17 maer 127:14 maintain 83:15 maintained 117:20 118:6 118:15,23 119:4,10,23 120:5 major 107:18 making 19:24 male 35:7 54:22 man 88:7 management 9:13 manager 46:22 managers 83:7 manhattan 13:8,9 14:19 38:10 83:8 manner 24:10 mansion U.S. Legal Support (954) 463-2933 44:11 49:13 83:7 98:4 115:6,11 119:12,19 122:5,21 123:3,8,14 125:19 126:1,8,14 126:20 127:1 134:5 134:21 manual 21:10 28:1 march isi? 439 137:9,10 138:17 marcinkova 18:17 20:22 22:19 27:1 49:16,20,25 69:10,11 78:15 79:2 92:9 99:8 99:11,21 mark 33:11 62:8,9 72:8 127:8 marked 4:6 5:14 6:18 33:16 56:18 62:12 72:12 87:12 127:9 133:17 134:9,25 135:7 marriage 111:24 married 7:13,20 8:1 8:7 12:25 111:23 marrow 111:14 martin 52:19 massage 25:17 26:4 27:13,21 28:3 47:21 50:22 66:3 69:14,15 89:2,24 10733 116:17 117:1,10,16 117:22 119:1,19 120:2,8 121:23 122:5,9 123:4,9 125320 126:2 127:2 134:22 massages 25:25 26:12 61:2 116:11 118:8,16 119:13 122:16,22 126:14,21 134:6 massaging 48:6 masseuse 89:2 masturbate 48:10 50:2 124:19 masturbating 49:2 material 54:13 matter 5:21 maxwell 18:12 28:8 30:12,17,19 31:12 33:3 33:22 34:2 34:12 39:16 42:7 65:12 75:13 85:12 91:18 92:1 93:13 103:5 104:21 114:21 maxwells 75:24 mo 18:25 19:5 28:21 100:16 113:25 127:20 meguire 2:25 4:16 meintyre 29:13 mckinney 1:22 4:2,15 137:5,14 138:5,19 mean 9:8 18:2 42:7 46:11 62:23 63:22 66:3 68:11 70:22 86:16 98:2 103:9 113:5,6 meaning 27:20 108:22 means 26:1 65:21 67:1 70:25 media 37:13 medical 111:45 meet 87:24 meetings 28:6 64:8 meister 77:13 memoriali... 2u:11 mentioned 86:7 87:22 mercedes 96:8,12 mermelstein 2:15,18 3:4 3:5 4:24,24 6:15 14:10 66:23 1L11:8 114:12,15 114:18 124:23 127:5 133:13,16 135:3,6,18 135:21 136:2 mess 104:3 message 3:18 60:12 60:16,20 62:8,23 63:11,17,22 65:19,21 66:23 67:1 67:5,24,25 68:2 70:11 7O:1L 72:6 74:1 86:6 86:20,25 8739 92:6 133:18,20 133:23 134:10,11 135:8,9,10 135:12,15 messages 3:16 70:13 70:16,20 74:3 86:8 86:16 messed 72:10,14 met 8:18 17:3,5 3338 37:1,6 154 47:1 53:1 58:8 74:9 74322 7735 77:8 98:23 100:2 412:25 112:9,14 methods 28:13 metrovich 81:22 mexico 44319 80:5 miami 2:16,22 10:12,14 11:11,12,15 12:6 13:2 14:23,24,25 16:5 109:9 109:10 111:20 113:23,23 128:5 130:2 130:4,10 131:5 michael 2:12 5:1 98:21 michele 130:5,7 132:25 133:3 midg0s 8:24 mike 106:3 milan 9:5,6 mini 135:25 136:3 minor 22:24 23:13 23:18, 22 25:17 27:15 28:14 30:4 30:8,13,23 U.S. Legal Support (954) 463-2933 155 31:8,13,17 61:19 67:7 123:21 100:14 110:3 32:24 33:23] 72:3 78:11 130:4,14,16 | month 117:22 34:17 35:17 | 81:18 82:17 | 130:23,25 8:10 53:15 118:6,12,17 36:20 37:4 83:12 85:17 | 1341:6,14,18 | 53:16 128:8] 118:20,23 37:10, 23 89:16 131:19 129:18 119:4,17,23 39:6, 10,18 102:11 132:3,21 morning 120:6 128:3 40:19 41:3 105:25 molest 5:3 68:7 130:8 41:8,13,18 107221 32:25 39:11 86:17 131:16 42:13,25 115:14,18 43:25 45:16 | motherinlaws | named 43:24 44:4 420:23 63:2 65:25 | 109:23 18:17 32:10 44:14,24 mistake 66:2 68:7 move 33:6 38:22 45:10,17 7:15,18 96:17 14:15 16:14 63:6 92:8 46320,25 model 105:24 11i:1 names 48:6,14 9;1,21 10:19] 108:18,23 moved 42:12 67:7 49217, 22 77:9 $4:22 | molestation 16:3,7,16 88:14 $0:1,7,41 113313 24:7,14 91:7 | moving 132:20 O:17 51:5 131:20 91:20 98:8 | 18:20 63:12 135:5 51:18,22 modeled 102221 mpike naomi 52:6,16,22 28:21 molested 2:12 77:5 54:9,9 modeling 43:7,18 45:5 | mucinska near 59:22 61:3 | g:12,14,20 71:11 7:10 8:4 60:12 61:9 63:1,6 8:22 10:16 108:12 murphy necessarily 64:24 65:24 | 40:22 11:3 | molester 133224 13424 | 72:22 66:12,21 11:3.17:10 | 25:2 58:7,19 need 68:7,13 17:14,17,22 | 98:13 46:6 108:5 69:4 70:17 17:24 18:25 | molesting nadia needed 71:20 74:15 | 19:4 28:18 | 34:11 68:13 | 49:17 20:21 | 10:4 109:13 76:19 77:2 26:25 29:4 Wek 72:3 22:19 26:25 | neighborhood 7831, 24 29:16 40:15 | moment 49:16, 20 83:25 82:8,6 88:4) 77:8 85:4 | 13:25 69:10, 11 nervous aoe 100:17 mominlaw 78:15 79:2 | 55:24 decreas | tacts 209319 92:9,13 | never 9074 100101 coos monaco 99:7,7,10 | 89:12,19,23 c ; 413:3/8,10 | 112:12 99:21 97:6 110:25 teers 16 113:13,16 128:11 naked new 105:5, 10 Hise tered 129:24 31:8 47:16 | 13:6,7,15 Lee i222e2 monday 69:10 14:20 16:11 1S Sarees 130:1 1:17 4:9 name 16:13,16 lias | b2it24-22 | money $:3.7:7,14 18:20, 22 123:20,25 132:17,20 91:9 52:9 7:15 8:4 23:13 34:4 soa! sie! 56:6 58:11 9:4,11 44:19,19 minors Tne a eat. 59:21 94:9 | 16:20 18:11 | 61:23 62:2 2374,8 27:9 | grn0 oe 95:19 97:20] 18:14 67:6 71:10,10 pare 29:10 | 2g70 30'22 | monica 32:7 82:23 | 78:10 80:5 50619 seid | aes 109:24 110:5| 88:7 102:7 | 80:8 83:12 _ le 34:12 78:5 | monroe 109:21,23 130:2,13 49:4 59:17 113:9,11,15 131:6 U.S. Legal Support (954} 463-2933 156 newspaper 41:12 101:9 101:21 94:21 3:2,12,23 T2715 objection okay opportuni... | pages nice 6:9 19:24 6:17,20 7:22 | 11:4 1:14 138:9 93:19 108:19 8:7 9:1,14 opposite paid night observations 9:19,25 65:2 20:17 22:15 86:17 30:7 76:11 10;8,16 option 39:5 56:7 nipples 99:16 12:10,13,19 | 46:7 51:9 57:20 69:22 48:18,23 observe 13:1,14 oral 70:25 71:12 49:5 82:19 121:16 | 14:11,22 69:13 124:9 | palm nodding 121:21 15:1,6,19 order 2:11 34:4 15:12 observed 16:7,10,20 6:2 10:3 44:10,20 nods 19:11 22:7 17:21 29:15 | 47:17 48:5 49:12 62:3 32:9 obsessed ee eae 64:1 faces pets 7 7 = : ordered 26,11, Soe a ootet eee! 62:15 63:17 | 53:17 54:2 115:18 107118 «| 21:24 22:8 69:3 74:6 | ordering 116:11,23 11 22:24 30:3 T7313 86:10 | 435323 117:9,20,21 pric! 30:8 35:18 | 86:24 99:16 | Spaces 118:8,25 nee obtained 101:7,11,21 | gg.36 119:12,19 2:4 31:12 34:3 10936/17 organization | 120:7,11,13 notary 134:16 abOeee i 28:9 aa 4:4 137:7,16 | obtaining ee oot orgies iets 28:9 ‘ 38:19 106:22 note ; 127:5 128:3 ° 126:1,6,8 q2:6 occasions 128:17,23 outline 426:14,19 notes 79:19 92:19 129212 24:5 isac aod 3:17 136:41 | 123:19,24 130:8, 10,25 | ublining paper nowak 124:3,8,13 131:11,13 5:20 18:15 52:19 125:18,24 132:13,17 outside parants nunees, eer 132:20 10s12 16:23 68:18 4:13 5:14,20 | 7:23 57:2 133:4 135:6 | Owens 72:24 73:2 40:6 63:20 | offenders olas 128:4,5 73:5,9,11 98:11 127:8 | 24:3 1:18 4:11 129:6,6 104211 numbers offenses old owned 110:8, 10 4:25 S:2t 8:23 22:4 18:23 parlor numerous oreer 33:22 43:13 | owners 89:24 27:7 39:21 Si:17 43:19 76:10 | 29:17 part 75:2 79:19 | offered 80:5 94:4 3 916 93:2 $2:22 123:2 | 73:17 95:24 99:7 |—__*~____| participate 123:19,24 | offers 22:11 pad 26:15 49:17 124:2,13 51:4 125:1 63:11 72:6 50:6 125:18,23 office once W434 participated a 5:16 67:7 46:15 57:24 | pads 50:10 | Seeentines: 105:15 60:12, 16 participa... oath 82:23 online 62:9 70:11 27:1 3:7 13721 oh 37:14 70:11 92:6 | ei oular object 9:8 86:24 open page 61:7 92:12 U.S, Legal Support {954) 463-2933 157 113:3,8,14 112:13 60:13 31:19, 23 61:10,16,21 LV3316 perform photo 3233,43;179 61:24 62:6 134:12 113:7 3:19 32:21 33:1 62:16, 25 particularly | performed photograph 33:25 34:9 63:3,9,23 89:6 124:9 112:24 34:15,20,24 | 64:3,11,15 parties performing 127:13,14 35:3,10,14 64:21,25 6:4 136:6 91:19 photographer 35:20,24 65:34,9,47 138:13,14 period 112:24 36:4,13,18 63:22 66:5 partner 12:16 16:13 413:15 36:23 37:25 66:14,18 35:1 37:19 20:8 132:2 |photograp... 38:4,8,12 67:2,16,23 73:23 132:16 10:17,19 38:16,20 68:5,9,15 parttime 134323 photographic 39:4,7,13 68:19 69:5 12:4 129:1,2 | permanent 112:21 4033,7,12 69:25 70:4 party 10:16 photographs 40:17,22 70:9,18,24 42:4 pexmanently | 30:23 31:16 41:5,10,14 74:4,7,13 pashcow 12:8 31:21 41:19,24 FL:17, 21,23 77:15 perpetrator | physically ee i0 7336, 20 passports 24:14 84:10 aeesiaae a Ee 34:3 perrylang picture . o ene 44:12,16,22 | 75:21 76:5 pastrana 80:16 127:16 45:1,6,13 76:8,13,15 76:16 87:23 [person pictures 45118 33 16:21 25 pathtojus... | 18:17 24:9 8:20 eer Gaal g Os 2:6 24:12,13 piece 46318 23 7818.19. 218, :8, patrol 45:11,21 26:21 : : : 47:4,8,14 79:20 80:1 30:24 51:13 71:1 | pike 47319, 23 80:4,7,9,14 219, 24,759; pay 77:1 «104:2 2:12 5:1,1 2 ‘ 48:3,7,16 80:23 81:2 20:5 51:12 104:2 6:16 13:17 : : 48:20,25 81:10,15 69:21 92:24 | 130:22 19:22, 24 49:6,10,14 82:1,6,10 : 26,10, 21,6, paying Hotels 20:3, 6,12 49:23 50:4 | 62:14,21 59:4,7 104:6 | personal 20:16,19,24 | 59:9,13,19 83:2,9,13 payroll 3959 60220 21:4,8,13 50:24 51:3 | 83:21 84:2 25:24 personally 21:21 22:1 | 5136,14,19 | 84:8,18,25 pbi A122, 18738 22:6,10,14 | 51:25 52:7 | 95:6,10,15 78:18 persuaded 22:17,21 52:12 53:5 85:18, 20,23 peers 122:3 23:1,5,10 53:13,19,25 | 86:12 87:17 35:7 persuading 23:15, 20,23 :5,11,15 87:20 88:1 penis 121:16,21 24:20, 24 88:5,18,25 69:16,17 ph 25:3,7,11 89:3, 21 people 111:12,13,16 | 25:14,19 90:1,13,16 25:23 35:18 | 111:18 26:2,8,13 90:21 91:1 39:22 42:8 | phone 26:18 27:11 91:8,13,17 67:17 70:15 | 89:16 101:14 | 27:19,24 91:22,25 87:22,24 101:16,18 28:5,11,15 92:18, 22 92:10 133:18 28:19, 22 93:5,11,16 104:16 134:10 ete eae 94:7,20 107313 hones faa fee 60:23 61:5 95:8,14,18 = 31:1,5,9,14 f U.S. Legal Support (954) 463-2933 95:21 96:2 96:5,9,18 96:23 97:18 97:22 98:7 98:14,20 99:6,19,25 100:13,20 01:1 102:18,23 103:7,412,21 103:24 104:4,8,15 104:18,23 105:3,7,12 105:17,21 106:1,9,12 106:19,24 107:5,10,16 107:23 108:4,8,15 108:19,24 113:17 114:4,8,10 114:22 115:2,8,15 1i5:21 116:1,8,13 116:20 117:2,11,17 117:24 118:10 119:5,14,20 120:9,16,19 120:25 121:;5,8,15 221525 122:6,18,24 123:6,11,17 123:21 124:6,10,16 124:22,24 125:3,8,14 125;:21 126:4,11,16 126:23 127:3,6,18 133:25 134:3,7,14 134:18 139:13225: pimping 35:17 pinch 48:18 49:5 pinched 48:23 place 18:22 63:7 95:7 124:14 places 77:22 placing 44:9 plaintiff 1:6 2:2 4:22 33:21 plaintiffs 2:14 33:11 33:16 60:10 62:11 72:12 87:12 127:9 plan 17:21 90:18 plane 79:19,23 84:16 plans 110:13 played 32:24 107:18 107:25 please 4:18 5:6 pled 101:4 plis 3:11 ploy 63:25 plus 51:18 point 26:10 40:9 47:25 53:10 $6:18 58:18 68:17 72:2 73:8 81:7 88:11 poland 9:3 11:6 12:10 16:24 23325 110:16,19 110:20,24 L1l1:1 police 27:3,6 64:6 64:9 69:7 83:16 84:4 84:5,10 120:13 polish 9324,25 politicians 35:7 78:9 pommier 130:5,7,9 132325 133:3 poor 12:13 93:8 possession 30:25 possibili... 11:4 possible 59:21 possibly 28:7 practice 35:17 predators 24:3 pregnant 95:24 96:16 96:21 97:9 97:11,14 7:9,16 19:20 | Presence 124:20 present 2:25 4:18 president 76:16 87:23 presume 109:13 113:21 pretty 61:22 71:5 83:15 preying 104:21 primary 61:12 115:1 126:24 prince 37:1,3 84:16 87:24 prior 6:2 9:15 107:8 116:15,22 120:12 123:1,7,12 124:8,13,18 124:25 125:5,11 128:7 129:23 131:14,18 prison 59:12 107:13° privilege 6:1,6,8,9 13:12 32:5 57:6,7 101:9,10 102:5,9 133:10 probably 83:25 15:17 23:25 problem 14:1 87:9 process 158 §:12 63:12 procured 74315 procures 7732 profession 112:4 professionali 1:23,24 4:2 4:3 35:8 112:23 137:5,6,14 137:15 138:5,6,20 138:20 program 11:25 129:3 promise 64:1 promised 28:24 properties 38:3 property 38:6,10 propose 95:15 prosecute 107:20 prosecuted 21:16 prostituted 78:5 prostitutes 89:7,17 prostitution 89:13,19 protect 24:2 protection 108:6 provide 126:20 providing 97:20 psychology U.S. Legal Support (954) 463-2933 46:11 public 4:4 137:7,16 publication 37:14 pulis 70:12 pump 69:17,19 purchased 34:3 37:17 purported 52:10 purpose 4:12 121:23 125:24 126:7,13 purposes 33:13 100:24 108:17 120:7 pursue 17:8,20 pursuing 11:12,17 put 101:13 pyramid Sig21 Q qualifica... 76:6 qualify 96:20 question 6:10 12:13 14:17 15:10 15:16,18 16:1 19:24 29:18 56:3 60:6 63:21 70:15 74:21 77:11 102:1 113:6 4124:22,24 questions 5:24 16:12 24:8 25:21 33:14 39:24 74:2 41135 111:9 114:16 127:6 133:11 quiet 20:18,18 quit 91:19 98:17 quote 135:10 raben 2:21 rabuyo 92:9 xadaronline 37:14,17,22 73:24 raer 73:21 raise 5:5 range 22:8 45:4 §1:12 reaching 124:13 125:1 125:6,11 read 24:6 27:3 33:18 98:9 reading 136:5 ready 51:23 real 96:25 realize 25:21 26:23 xeason 159 60:21 115:18 120:21 recall 7:18 8:10 9:11 10:15 16:9 111:22 1i1:24 131:1,16 134:13 receive 116:23 117:14 received 56:19 receives 101:19 recess 13:21 86:2 recognize 25:24 62:13 62:18 63:14 72:19 98:12 record 4:8 6:5 13:20, 23 26:20 86:1 86:4 114:10 114:13,14 114:17 135:22 138:11 X@Crossex... 3:5 133:15 recruit 18:2,3 125:18 126:19 recruited 118:5 recruiting 126:7 redirect 3:4 127:11 refer 26:5 referred 28:3 133:23 referring 27:15 reflect 635 refuse 634,11 13:13 13:16 14:3 14321 16:19 16:22 17:4 17:6 18:7 18;10,13,16 18:18,21,24 19:2,6,10 19:14,16,19 3 20:4 710,13 2 20:15,20,25 21:3,9,14 21:18,22,25 22:5,11,13 22:18,22 27:5,10,14 27:18,25 28:4,12,16 28:20,23 29:2,5,8,12 29:14, 23 30:1,6,11 30:15,18, 22 31:2,6,10 31:15, 20,24 32:2,14,18 32:22 33:2 33:5,7,9,20 34:1,8,14 34:21,25 35:4,11,15 35:21, 25 36:3,6,14 | 38:25 39:3 36:17, 22,25 37:2,5,7,12 37:315,18,21 38:1,5,9,11 38:17,21,23 39:8,12,15 39:17,20 40:4,8,13 40:18,23 41:1,6,1i1 41:15,20,23 42:2,6,11 42:14,16,18 42:20,22,24 43:4,10,16 43:22 44:1 44:7,13,17 44323 45:2 45:7,14,19 45:24 46:4 46:10,14,19 46:24 47:3 47:9,15,18 47:24 48:4 48:8,11,15 48:21 49:1 49:;7,11,15 49:19,24 50:5,8,14 50:20,25 §1:2,7,16 51:20 52:1 52:4,8,11 52:14,18,20 §2:23,25 53:2,6,9,14 $3:20 54:1 54:4,12,16 $4:21,24 §5:5,7,10 $5:12,15,18 55223 5622 56:5,10,14 56:17,21 57:4,10,19 57:23 58:2 U.S. Legal Support (954) 463-2933 57: 58: 58: 59: 59: 60: 60: 61: Gl: 62: 62: 63: 64: e4; 65: 653 66: 66: 67: 67: 68: 68: 69: 70: 70: 7a: Fi: 72: 73: 73: 73: 743 74: Hoe TW: 76: 76: BAS. VT TT: 78: 221,23,25 :4,6,8,10 :12,15,17 121,25 73,6,10 :15,17,20 23 58:2 6,10,13 17,21,24 2,5,9,13 18,23 28 15 19,24 4,11,15 20,25 4,14,19 24 63:4 10,16,24 4,7,10 16,22 1,5,10 13, 18,23 1,6,10 15, 19,22 3,10,13 15,19, 22 3,10,16 20,23, 25 2,6,24 5,10,19 23 71:3 8,14,18 22 72:1 5,20 1,3,7,10 14,19,22 25 74:5 10,13,16 25 75:3 7,11,16 20,23 1,4,9,14 17,22, 24 4,6,14 16,18, 20 24 78:3 143,17 80:24 81:3 81:5,8,11 81:16,19,21 81:23 82:2 82:5,11,15 82:18,20 83:1,4,6,10 83:14,17,22 84:3,9,12 84:15,19,21 84:24 85:3 85:7,11,14 85:19 86:11 $6:15,19 87:31,16,21 88:2,6,8,10 88:13,15,19 88:21,24 89:4,8,11 89:14,18,22 89:25 90:6 90:9,12,17 90:20,23,25 91:5,9,12 91:16,21,24 92:2,4,17 92:23 93:1 93:6,12,15 93:18,22,25 94:2,6,11 94:15,19,24 95:3,9,13 95:17,22 96:1,6,10 96:14,19,24 97:3,5,8,10 97312,16,23 98:1,6,15 98:19,22,24 99:2,5,9,13 99318,22 100:1,4,6,8 100:12,15 100:21 101:2,6 102:4,8,13 102:19,24 103:3,8,13 103:17,20 103:25 104:5,9,14 104:19,24 105:2,8,13 105:16, 22 106:2,4,8 106:13,16 106:20,25 107:6,9,15 107:22 108:3,9,14 108:20,25 110:7,9 114:1,5,9 114:23 4115:3,9,16 115:22 116:2,7,14 116:21 117:33,6,12 117:18,25 118:2,4,41 118:13,19 118:21 119:2,6,8 119:15,21 119325 120:3,10,15 120:20 121:1,4,9 121:14,19 122:1,7,13 122:17,25 123:5,10,16 123:22 12431,5,11 124:17,21 4125:4,9,13 125: 134:1,8,145 134:19,24 135:14,17 regard 131:9 regarding i16:24 registered 1:23 4:2 137:5,14 138:5,20 registry 95:25 regular 123:9 126:25 reilly 55:8,11 relate 72:22 related 2:14 27:3 28:25 29:16 31:25 101:4 108:2 127:19,19 relation 12:24 relationship 30:16 58:3 66:20 83:15 relative 138:12,14 remember 14:18 42:17 42:21 68:2 69:1 70:1,8 72:25 78:14 78:20 79:1 86:25 96:11 remembered 69:13 remorse 32:23 remove 120:17,22 removed 160 69:9 107:7 120:11 121:11 removing 7:17 69:14 rented 67:11,14 repetitive 25:22 report 27:6 138:8 reported 1:21 reporter 1:23,24,25 3:8 4:2,3,3 4:15,19 5:5 6:17 15:10 135:23 137:6,6,7 137:14,15 137:15 138:1,6,6,7 138:20,20 138:21 reports 27:3 29:13 29:15 84:5 represent 4:21,25 5:4 55:14 57:21 represented 9:5,7,10,12 republic 34:18 reputation 29:21 requested 138:10 residency 7:17 resisted 94:8 resource 37:14 responded U.S. Legal Support (954) 463-2933 161 14:18 129:9,14 16:17 21:17 | 20:5 122316 responsib... 131:3,24 24:4 29:18 san 134:2 61:12 432:5 133:5 | 29:22 32:4 | 34:5 scheduled rest 133:12 33:15 44:2 | sandy 6l:i 46:16 135:6,18,21 } 57:6,14,18 | 81:4 schedules result xing 59:8 60:9 sanka 39:9 68:6 5:23 91:7,20 72:9,11,16 | 106:3 scheduling resumed 102221 73:13 74:8 | santa 61:7 102:14 13:22 86:3 ringing F711 87:4 | Bars 107:3 reveal 101:22 87:7,11 sarah 116:24 56:11 ripped 101:9,16,21 | ig:14 20:21 125325 review 70:6 101:23 26:8 39:1 126:24 138:9 rising 102:5,9 40:1,6 scheme ricardo 102:21 104:10 41:25 44:9 | 90:2 93:2 9:3,5 ritual 109:4,7,18 46:22 56:15 | 98:10 right 44:4 47:25 109:22,24 61:13 75:14 | school are 8:3 48:17 120:4,11,14) 79:16 80:12 | 11:2,5 17:8 41:13,17 robbins 411:2,9,10 ) 92:9,12 71:24, 25 12:18/13:4 | 2:20 131:7,9 96:3,7,11 89:10 14:6,17.. ~+—‘| roberts 132324 99:23 100:2] 111:18 15:20 16:14 | 33:6,8 133:3,7,10 | 403:6 115:1 | 115:12 21:15 31:18 | robson 135220 126:12,18 327:23 : 3 137:8 138:9 | saved i28:24 33:10 47:2 | 125:15,18,24 | our, 5 : 48:10,19,23 | 126:6 fee 31:17 12932 50:16 54:19 | rodriguez coy erie eee ts ae soa eae 2 saving 12627 60:13 61:14 | 32:23 39:2 ZOver ee. 14:5 scientist 61:23 62:5 63:7 107:18 | 9927 87:24 | saying 111:16 113:1 63:11,15 107:25