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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 pled 
guilty, but the witness already said he doesn't 
know what he pled guilty to. 
He knows the charge 
he doesn't know the facts. 
BY MR. EDWARDS: 
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. 
I think you've got it 
wrong. 
I'll object to the form. 
MR. EDWARDS: Okay. 
BY MR. EDWARDS: 
Q. 
Then we'll 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; speculation. 
THE WITNESS: 
I would certainly be speculating 
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and I have to discuss it with my wife long and 
hard. 
I don't think I could give you a correct and 
honest answer at this time. 
BY MR. EDWARDS: 
O. 
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 it from this 
page back about five pages. 
If nobody requests the deposition, I'd just 
like those five pages. 
MR. EDWARDS: 
I'm going to request the 
deposition, so.. . 
MR. CRITTON: 
Okay. 
We'll mark this then, so 
you could tell me where it is, approximately. 
BY MR. EDWARDS: 
Q. 
Is there a reason why you have not discussed 
with Jeffrey Epstein the allegations that have been made 
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against him and the allegations contained within many of 
these civil complaints on behalf of girls who were under 
the age of 18? 
Is there any reason why you haven't 
discussed that? 
MR. REINHART: 
If that's based on 
conversations you had with your lawyer, then don't 
disclose what you and your lawyer talked about. 
BY MR. EDWARDS: 
Q. 
Correct. 
A. 
I have not spoken to Jeffrey about any of 
this, and it was my understanding that is illegal to 
have conversation about this. So I've never presented 
any questions to him reference this case or any others. 
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 I 
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 to believe that it was illegal? 
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MR. REINHART: Again, if it was a discussion 
you had with any lawyer, then you can just give a 
name, don't give a discussion of the conversation 
you had. 
THE WITNESS: It was my own assumption. 
mean, just basic criminal knowledge of knowing 
you're not supposed to -- you know, if somebody's 
in trial or in a deposition or whatever, I don't --
I didn't think it was appropriate to discuss the 
matter with them. 
BY MR. EDWARDS: 
Q. 
Okay. So the next two visits and I think the 
last two visits we'll talk about are on 9/6/2008. 
Actually, it looks like you visited him twice in one 
day; is that right? 
A. 
I don't think that's possible. 
I mean, that 
will show how accurate the court record is. There's no 
way. 
Q. 
You wouldn't have visited him twice in one 
day? 
A. 
No. 
I think there's only one visitation per 
day. 
Q. 
Okay. 
And it looks like the same visitors 
each time, except that it says for period three and then 
the next one's for period four. So there are two 
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different periods. 
Was there ever a time when they 
185 
allowed you to stay for more than an hour? 
A. 
No, not to my knowledge. 
Q. 
Okay. So again, it's 
and 
, same questions: Did you ever ask them their 
involvement with Jeffrey Epstein? 
A. 
Absolutely not. 
Q. 
And again, what was the discussion with 
Jeffrey Epstein along with 
and 
A. 
On the last visits, it was mainly airplane 
stuff and later on in the visitations, we were advised 
that you could leave early, so I would only stay for 
maybe 30 minutes and then, you know, Jeffrey would 
continue his conversations with them and then I would 
just wait outside. 
Q. 
Okay. 
A. 
So I would do my business with him talking 
about airplanes or whatever I had coming up and then 
exit. 
Q. 
And then why did you stop visiting him in jail 
after that September 6th, 2008, visit? 
A. 
I was never called back to visit. 
Q. 
Okay. 
Well, shortly after that then he was on 
work release? 
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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. 
I'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 Florida Science 
Foundation? 
MR. REINHART: 
I'm sorry, you're talking in 
person or all conversations? Because he testified 
he had phone conversations and personal visits. 
BY MR. EDWARDS: 
Q. 
I was actually talking about phone 
conversations. So when you would call him on the 
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telephone, how frequently would you talk to him? 
A. 
How frequently during a given week? 
O. 
Yeah. 
A. 
More specific? 
D. 
Sure. 
A. 
Depends upon what's going on that week. 
O. 
I mean, is it somebody you would talk to him 
every day? 
A. 
No. 
O. 
All right. Well, at that point in time, he's 
going from the jail to the Florida Science Foundation 
and back, and if you're not going to see him in person, 
and you're not corresponding by e-mail, then would you 
correspond by telephone, that either being you call him 
or he called you? 
A. 
Yes. 
O. 
And, you know, in any given week, what was the 
typical week like? 
I mean --
A. 
How many times? 
O. 
Yes. 
A. 
Maybe once in a week, sometimes twice in a 
day. 
I mean, it would vary. 
There was no routine. 
O. 
And what would the conversation be? 
A. 
Mostly we discussed audio and video, TVs, home 
theaters. 
It's a niche of his and we're constantly 
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looking at new items that are out there, you know, 
what's the biggest LCD flat screen out there. 
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 him 
at his home? 
A. 
I have been to the home. 
I haven't visited, 
but I have had work to do there. 
Q. 
And have you called him on the telephone 
there? 
A. 
Once I think I've called the house. Normally 
he calls me because it's usually he needs me to do 
something. 
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 living room, let's put a bigger stereo in the 
gym, let's put a bigger, bigger stereo in the gym, let's 
go redo what we've done. It's always audio. He's a 
very audio file person. 
Q. 
Do you know of any other modifications that 
he's made to the house at 358 El Brillo since the time 
that he went into jail? 
MR. CRITTON: Form; predicate. 
THE WITNESS: Meaning? 
Be more specific. 
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BY MR. EDWARDS: 
Q. 
Structural modifications, architectural 
modifications? 
A. 
Starting what date? 
Q. 
June 30th, 2008. 
MR. REINHART: 
I think the question on the 
table was have you observed any structural changes 
to the house at El Brillo since Mr. Epstein went to 
jail? 
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THE WITNESS: Structural changes? 
BY MR. EDWARDS: 
Q. 
Structural, architectural, anything like that, 
changes to the house, to the interior of the house since 
he went to jail? 
A. 
No. 
I mean, if you could be more specific. 
mean, you're talking furniture or? 
Q. 
I've never been in the house, so I can't be 
much more specific. Have you noticed any changes from 
before he went to jail to after he went to jail, the 
inside of the house, that you could be specific about? 
A. 
No, I can't be specific. 
MR. REINHART: Can I talk to Mr. Visoski for a 
second? 
MR. EDWARDS: Sure. 
(Off the record discussion.) 
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MR. REINHART: 
I think Mr. Visoski can expand 
on his previous answer. 
Why don't you expand. 
THE WITNESS: 
Can we go back to that one? 
BY MR. EDWARDS: 
Q. 
Sure. 
The question dealt with the structural 
architectural changes you're aware of. 
A. 
There has been a kitchen extension, but when 
you asked the question, I was unaware of when that 
actually took place. So to be accurately answering your 
question, I know there's been a kitchen extension. 
don't exactly know when that transpired, but... 
Q. 
How do you know about the extension? 
How do 
you know this happened? 
A. 
I knew what the kitchen looked like before and 
after the extension and I don't -- I thought it was 
during the hurricane season when they actually did that 
extension. 
Q. 
Who made you aware of it? 
A. 
Nobody. 
I just walked in the kitchen and 
noticed a bigger room than what it was. 
Q. 
All right. 
Do you know who Martin Nowack is? 
A. 
No. 
Q. 
Do you ever remember him being on your 
airplane, or that name of somebody being on your 
airplane? 
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A. 
No, I don't. It's not my airplane. 
Q. 
We still don't know whose airplane it is yet. 
The time when you took Mr. Epstein to Miami in the last 
month, do you know which attorney he was going to see? 
A. 
No, I do not. 
Q. 
And do you know whether it was related to 
civil cases or criminal cases or anything else? 
A. 
No idea. 
Q. 
Do you know where the location was in Miami 
that he was going to? 
A. 
No, I do not. 
Q. 
Other than yourself visiting Mr. Epstein at 
the Florida Science Foundation, are you aware of any 
other visitors, people that visited him? 
A. 
No, I'm not. 
Just whoever was there during my 
visit. 
Q. 
Okay. 
Are you aware of a corporation named 
the Zorro Trust? 
A. 
I've heard the name. 
Q. 
And is that something that you've heard 
relative to your involvement with Jeffrey Epstein? 
A. 
Yes. 
I mean, I don't even remember where I 
heard Zorro Trust. 
I have no definition of it, but I 
know the name is out there. 
Q. 
Okay. 
Is that a company that you believe is 
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affiliated or related to Jeffrey Epstein in some way? 
A. 
I have no definition. 
I don't know who it is. 
Q. 
Do you know how you heard about it? 
A. 
I don't remember. That's going back in the 
early days of when Zorro existed. 
Q. 
Who was at the Florida Science Foundation when 
you would meet with Jeffrey Epstein on these meetings? 
A. 
would be there. 
Q. 
Anybody else? 
A. 
Story would be there on occasion. That's 
pretty much it. 
Q. 
And would they be in the same room with 
yourself and Jeffrey Epstein when you had conversations 
with him? 
A. 
No, not really. Not particularly. 
Q. 
They would just be at the location? 
A. 
Sure, yes. 
Q. 
Anybody else that worked there or was 
affiliated with the Florida Science Foundation that you 
know of? 
A. 
Not to my knowledge. 
I mean, I do my business 
and get in and get out. 
Q. 
Can anybody other than Jeffrey Epstein have an 
office at the Florida Science Foundation? 
A. 
Not that I know of. 
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O. 
All right. 
And were you deeded the property 
that we spoke about earlier on the New Mexico ranch? 
Is 
that deeded to you? 
A. 
Yes. 
O. 
And has it been since back in, I think you 
said 1998 or 1999 or whenever it was? 
A. 
Yes. 
Q. 
Okay. 
And do you know -- and did you build a 
house on it then? 
A. 
Yes, I did. 
Q. 
Okay. 
And that's a property that I think you 
said you have a mortgage on it, that's a property that 
you pay 
mortgaged that property? 
A. 
Yes, sir. 
Q. 
All right. 
And as well, the home you own 
here, you have a mortgage on that property as well? 
A. 
That is correct. 
Q. 
All right. 
Are you familiar with a vehicle, a 
Chevy Suburban 1500, year 1999? 
A. 
Do you have a color? 
Q. 
No. 
I can tell you the plate. 
I could tell 
you the VIN. Chevy Suburban -- Chevy Suburban 1500, 
registered to Larry Visoski? 
A. 
That would be mine. That's a white one, then. 
Q. 
Okay. 
When did you get it? 
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A. 
I'm guessing. 
It was probably two years old 
when I got it. Maybe '99. Maybe '01, '02. 
Q. 
Something you still drive? 
A. 
Occasionally. It's kind of a beat up car now, 
so it's kind of a knock around. 
Q. 
Best of your knowledge, it stays parked at 
your house? 
A. 
Recently it's been in Jeffrey's driveway, 
but.. . 
Q. 
Why? 
A. 
Just for an extra car to use. 
Q. 
For Jeffrey to use? 
A. 
No. 
I mean, for anybody that would come to 
the house to help out. Igor I think has driven the car 
before. 
Q. 
How did it come about that you began to park 
the Chevy Suburban, the 1999 car that we're talking 
about, at Jeffrey's house? 
A. 
When there was more activity here in West Palm 
Beach. 
We were never usually coming here that often, 
and now with all this going on, with Jeffrey being in 
town longer, we needed more cars and transportation. So 
my car was just sitting in the driveway at home while I 
was driving the Hummer. 
So I decided to let them use 
the Hummer at the house. 
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Q. 
Well, we've just described this wide array of 
cars that Jeffrey had for people to use --
A. 
Well, you said for him to use. 
MR. CRITTON: Hold it. 
BY MR. EDWARDS: 
Q. 
Is there a reason why? 
MR. CRITTON: Wait. 
You guys are both talking 
over one another. 
You need to let him wait and 
finish his question because if I want to assert an 
objection, neither one of you gives me a chance, 
which may be the plan. Form. 
MR. EDWARDS: 
Yeah, we have a conspiracy 
against you. 
MR. CRITTON: 
I knew it. 
I'll take that as an 
admission. 
BY MR. EDWARDS: 
Q. 
Is there any reason -- did Jeffrey say that he 
wanted that vehicle to use or to be parked at his house? 
A. 
No. 
Q. 
Then how did it come about that you started 
parking that vehicle at his home? 
A. 
I think the origination of that came when I 
started using the Hummer, that the Suburban was parked 
in my driveway and I wanted to get it out of my driveway 
as an eyesore. So hence, I decided to let people at the 
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house drive it as a grocery shopping car or something, 
or just as extra transportation. 
Q. 
Okay. But when you go to park the car at 
somebody else's house, you have to let them know, Hey, 
I'm giving you the keys? 
A. 
Mm-hmm. 
Q. 
Who did you give the keys to? 
A. 
I don't know if I gave the keys to anybody. 
I 
may have just left them on the counter there and told 
Yanush this is an extra car if you guys needed it to run 
around because it was an eyesore at my driveway. 
Q. 
Are you familiar with a Mercedes-Benz SUV 
1999? 
now? 
A. 
Say that again. 
Q. 
Mercedes SUV, 1999 registered in your name? 
A. 
Yes. 
Q. 
And what car is that? 
A. 
That's my car -- my wife's car. 
Q. 
Does that stay at your house? 
A. 
Yes. 
Q. 
And that's the car that's parked at your house 
A. 
Yes. 
Q • 
Are you familiar with a Land Rover, Range 
Rover Sport 2008? 
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A. 
Yes. 
Q. 
Registered in your name? 
A. 
Yes. 
Q. 
And whose car is that? 
A. 
That's another extra car for the household to 
use at Jeffrey's house. 
Q. 
And when was that car purchased? 
A. 
Last year. 
Q. 
And who purchased that car? 
A. 
It was purchased in my name. 
Q. 
By whom? 
Who purchased the car in your name? 
A. 
Well, I put the car in my name, but the funds 
came from -- they were wired to my account from New 
York. 
Q • 
From whom, though? 
A mysterious source just 
sent funds? 
We know that didn't happen, so I'm just 
trying to elaborate here. 
A. 
Jeffrey had paid for the car. 
Q. 
Okay. 
And why did Jeffrey pay for a car and 
put it in your name? 
A. 
I don't know. 
Q. 
I mean, you had to agree for this to happen. 
So what was the conversation between you and Jeffrey 
that resulted in Jeffrey paying for a Land Rover, a 2008 
Land Rover and putting it in your name? 
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A. 
I don't recall exactly how the conversation 
came about. 
He just says we want to buy an '08 Land 
Rover and put it in my name. So we did. 
I didn't ask 
any further questions. 
Q. 
Did this conversation happen when he was in 
jail or after he was out? 
A. 
Meaning out on house arrest? 
Q. 
Right. 
A. 
When you say "out" I think of the Science 
Foundation. 
On work release, so you have to be more 
specific. 
Q. 
You tell me what happened, when the 
conversation happened relative to where Jeffrey was at 
the time. 
A. 
I'd only be guessing again. 
I would say this 
probably happened a year ago, maybe less than a year 
ago. 
I'd have to look. 
I don't remember exactly the --
Q. 
So it was either at a time when he's at the 
Florida Science Foundation or possibly on house arrest? 
A. 
It was -- no, it was definitely before house 
arrest. 
It was probably during the time of the Florida 
Science Foundation, to be accurate. 
Q. 
Okay. 
Are you aware --
A. 
About eight or nine months ago. 
Q. 
Okay. 
Are you aware of a Mercedes-Benz CLK 
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2005 registered in your name? 
A. 
Yes. 
Q. 
And whose car is that? 
A. 
That car also is a Palm Beach house car to be 
used at the house. 
Q. 
What does that mean, 'a Palm Beach house car'? 
A. 
It's a car that we park in Jeffrey's driveway 
for people to use. 
Anybody that comes to the house can 
select a car to go anywhere. 
I mean, run errands, go 
shopping, do whatever they need to do. 
And that was 
purchased the same way. 
It was in my name. 
Q. 
And the funds came from Jeffrey Epstein? 
A. 
They were wired to my account. 
I don't know 
exactly what account they came from. 
O. 
Again, that's a conversation that has to take 
place before -- that you have to agree to put a car in 
your name? 
A. 
Yes, yes. 
Q. 
And is that a conversation between yourself 
and Jeffrey Epstein that takes place? 
A. 
Yes. 
Q. 
And what is the substance of that conversation 
that results in a Mercedes-Benz 2005 being placed in 
your name? 
A. 
He just said we need a fun car for the house 
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in Palm Beach. 
Q • 
But why put it in your name? 
A. 
I don't know. 
Q. 
You didn't ask any questions about that? 
200 
A. 
No, I didn't. 
Q. 
Okay. 
Are you aware of a Jaguar X-Type 2005 
registered in your name? 
A. 
I forgot about that one, yes. 
Q. 
Whose car is that? 
A. 
That's a Palm Beach car. 
Q. 
What do you mean "a Palm Beach car"? 
A. 
It's the Palm Beach house car, another run 
around for people to use. 
Q. 
And again, that's a conversation that has to 
take place that results in a car being placed --
registered in your name? 
A. 
Yes. 
Q. 
here? 
Okay. 
Now we're talking about several cars 
A. 
Yes. 
Q. 
That are all being placed in your name? 
A. 
Yes. 
Q. 
You never at any time ask any questions to 
Jeffrey Epstein why are you placing these cars in my 
name? 
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