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you were visiting and you happened to bump into each 
other. 
You actually went to see him while he was an 
inmate in jail? 
A. 
Right, yes. 
Q• 
Okay. So when we're talking about the 
101 
criminal 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: 
I don't know the full definition 
of really what happened there. 
I know that it was 
something to do with solicitation of prostitution. 
That's all I read. 
BY MR. EDWARDS: 
Q. 
Okay. 
Were you aware that the allegations 
revolved around underage girls or girls under the age of 
18? 
MR. CRITTON: Form. 
THE WITNESS: 
I was aware it revolved around 
it, yes. 
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BY MR. EDWARDS: 
Q. 
Who first made you aware of that? 
102 
A. 
The newspaper. 
Q. 
Were you ever questioned by the police? 
A. 
I don't know who questioned me, actually. 
I 
did have a questioning session, but I don't even 
remember who questioned me. 
Q. 
Where did that take place? 
A. 
I don't remember. 
Q. 
At your 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, I 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 Goldberger? 
A. 
Yes. 
Actually, I believe Dave Rogers did 
that. 
I wasn't in possession of those records. 
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103 
Q. 
And for the passenger manifest prior to 2005, 
how far do those passenger manifests go back in time? 
A. 
They should go back, I guess, to 1991 or 
whenever we started existence. 
Q. 
And did you turn them over from 1991 all the 
way through to 2005? 
A. 
I don't know. 
I didn't turn them in. 
Dave 
Rogers did. 
Q. 
Are you in possession of a copy of any of 
those materials? 
A. 
No. 
Q. 
I 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 airplane office, 
which I've given to Bruce, which is the current log. 
He 
is in possession of them now. 
I had possession of them. 
Q. 
Okay. 
What he's in possession of -- just so I 
know what documents are where, he's in possession of the 
passenger manifests from 2005 through the present? 
A. 
Correct. 
Q. 
If I want to obtain the passenger manifests 
from 1998 through 2005, that's something that I would 
request from whom? 
THE WITNESS: 
Help me out. That's --
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104 
MR. REINHART: If you know. 
THE WITNESS: 
I don't know who possesses them 
right now. 
They were turned into Jack Goldberger's 
office a year and a half or two years ago. 
BY MR. EDWARDS: 
Q. 
You started out by indicating that you sent 
these passenger manifests, or a copy thereof, to Darren 
Indyke or someone at NES, LLC; is that correct? 
A. 
Correct. 
Q. 
If I requested them from NES, LLC, that's 
somebody at some point in time was in possession of all 
the passenger manifests? 
A. 
Sure. 
Q. 
And NES, LLC's address is the one you gave me 
at 
A. 
I believe so. 
I don't know what address 
they're using for that. 
I know that --
Q. 
But Darren Indyke's the attorney that I would 
call --
A. 
Yes, sir. 
Q. 
-- and he could probably steer me in the right 
direction? 
A. 
Yes. 
MR. CRITTON: Form. 
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BY MR. EDWARDS: 
Q. 
Do you know 
A. 
Yes. 
Q. 
How do you know her? 
A. 
She was on the airplane. 
Q. 
How old is she? 
105 
A. 
I have no idea. 
Q. 
Age range? 
A. 
Twenty-eight. 
Q. 
Now? 
A. 
Yeah, 28, or maybe if not older now. 
She was 
probably 28 probably, I guess. She was somebody in her 
late 20s. 
Q. 
So we're talking about 2003? 
That's what I'm 
trying to understand. 
A. 
I'm guessing. 
Q. 
We're talking 2009 now. 
We're saying 28. 
By 
that do you mean in 2003 she was 23 or 24 years old? 
A. 
You're having me guess on her age. 
Q. 
Yeah. 
A. 
I mean, I can't be accurate. 
Q. 
Somebody between 18 and 25? 
MR. CRITTON: Form. 
BY MR. EDWARDS: 
Q. 
At the time you were seeing her back in --
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106 
A. 
If you want me to guess --
Q. 
No, I don't want you to guess. 
A. 
I don't know then. 
Q. 
Well, if I say between ten and fifty? 
A. 
That's a range. 
Q. 
If I say between ten and fifty, you're not 
guessing there anymore. 
You know she's in there, right? 
A. 
She's in the middle there, yeah. 
Q • 
Okay. 
How can we narrow that down? 
We're 
talking about somebody in her 20s? 
A. 
In her 20s. 
Q. 
At least that's what you believed? 
A. 
Yes. 
Q. 
All right. 
Is that somebody that you know to 
be associated or friendly with Ghislaine Maxwell? 
A. 
I don't know. 
Q. 
Do you know what her relationship was to 
Jeffrey Epstein or Ghislaine Maxwell? 
A. 
No. 
Q. 
Do you know where she is now? 
A. 
No idea. 
Q. 
When's the last time you talked to her? 
A. 
I don't know. 
What date do you have on there? 
Q. 
February 2003. 
A. 
So, probably that long ago. 
I may have said 
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107 
hello. 
Q. 
That's somebody who was on the airplane 
multiple times? 
A. 
More than once. 
I mean, I have no account for 
how many times. 
Q. 
Well, I've asked you about a bunch of names, 
most of which you don't really remember, but that's one 
name you do remember. 
A. 
Yeah, I remember the name, yeah. 
Q. 
Okay. 
And that's somebody who you actually --
you would remember the face too? 
A. 
I might remember Amy's face. 
Q. 
All right. 
Do you remember why she would have 
ever been on your airplane? 
A. 
No idea. 
Q. 
President Andres Postrana, at the time I guess 
that was the president of Colombia back in February --
sorry, March 20th of 2003. Do you know who that is? 
A. 
I don't remember him being on the airplane, 
but I know who that is. 
Q. 
Okay. 
He's on the airplane with Jeffrey 
Epstein, Ghislaine Maxwell, 
and Jean Luc 
Brunel? 
A. 
Where did we go? 
Q. 
I'll let you look at it. 
I'm talking about 
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108 
this line, PEI, left out of Palm Beach? 
A. 
Palm Beach to Nassau. 
I'm sorry, I don't 
remember that one. 
Q. 
When we're saying we're going down to Nassau, 
is that a place that you frequently went to with the 
airplane? 
A. 
No, not at all. 
Q. 
And is that a route that you would take for 
the ultimate destination to be Little St. James? 
A. 
No. 
Q. 
If the ultimate destination was Little 
St. James -- show me a flight where the ultimate 
destination was Little St. James. 
A. 
Yeah, right here. 
TIST, that's St. Thomas. 
O. 
Okay. So on that flight that you just pointed 
to, March 27th, 2003, we have Jeffrey Epstein, 
again, Brent Tyndall -- do you know 
who Brent Tyndall is? 
A. 
Yes. 
Q. 
And who is that? 
A. 
I believe he was the chef. 
Q. 
And 
(phonetic), is that 
somebody you know to be a model these days? 
A. 
I have no idea. 
Q. 
Do you remember that flight? 
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109 
A. 
No. 
Q. 
Do you remember Naomi Campbell, picking her up 
from St. Thomas along with Jean Luc Brunel? 
A. 
I remember her being on board. 
I don't 
remember the flight. 
Q. 
Do you know Joel Pashcow? 
A. 
Yes. 
Q. 
How do you know him? 
A. 
He was on the airplane. 
Q. 
And is that somebody you knew at one point in 
time to be a friend of Jeffrey Epstein's? 
A. 
He was on the airplane. 
I don't know what the 
relationship was. 
Q. 
Do you know what the relationship is today? 
A. 
No idea. 
Q. 
How about Todd Mister, do you know what that 
relationship is or was today? 
A. 
No. 
Q. 
Do you remember him? 
A. 
No. 
Q. 
Not at all? 
A. 
I mean, I know the name. 
I don't know. 
Q. 
Paula Epstein, do you know who that is? 
A. 
Yes. 
Q. 
Who is that? 
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A. 
That's Jeffrey's mom. 
Q. 
She's passed away? 
A. 
Yes. 
Q. 
At least that's your understanding, right? 
A. 
That's what I heard, yes. 
Q. 
Okay. 
, do you know her? 
A. 
I know the name. 
Q. 
Somebody who flew on the airplane with some 
110 
regularity? 
A. 
Yes. 
Q. 
And do you know her to be friends of Ghislaine 
Maxwell or 
or Jeffrey Epstein? 
MR. CRITTON: Form. 
THE WITNESS: 
I have no idea who she was 
friends with. 
BY MR. EDWARDS: 
Q. 
All right. 
Do you know what role she ever 
played, if she played one, in Jeffrey Epstein's life? 
A. 
No. 
Q. 
All right. 
Glenn Dubin, are you familiar with 
him? 
A. 
Yes. 
Q. 
How do you know Glenn Dubin? 
A. 
I met him on the airplane. 
Q. 
Outside of the airplane, have you ever seen 
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111 
him around Jeffrey Epstein? 
A. 
No. 
4• 
All right. 
A. 
No. 
O. 
, do you know that name? 
A. 
No. 
O. 
She was on several flights. 
You don't 
remember seeing her? 
A. 
No. 
Q. 
All right. 
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? 
A. 
Never heard the name, actually. 
Q. 
Really? 
A. 
No. 
Q. 
Larry Summers? 
A. 
I know the name. 
I don't remember flying him. 
Q. 
Have you ever talked to Joe Fontanela? 
A. 
Yes. 
Q. 
How do you know him? 
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112 
A. 
He usually drops Jeffrey off at the airport. 
Q. 
In fact, you've called him directly before, 
right? 
A. 
Yes. 
Q. 
You still have his number? 
A. 
I haven't -- yes, I think I still got it in my 
memory. 
Q. 
Okay. 
What is it? 
A. 
It's been a few years. 
. 
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, I don't. 
Q. 
Do 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? 
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113 
A. 
I don't know what his role is. 
Q. 
Have you ever worked for a company called Air 
Ghislaine? Do you know that company? 
A. 
Yes. 
Q. 
Do you know what that company does? 
A. 
No. 
Q. 
Have you ever been an employee of that 
company? 
A. 
No. 
Q. 
Do you know who runs that company? 
A. 
No. 
Q. 
Is Jeffrey Epstein associated with that 
company? 
A. 
I don't know. 
Q. 
How have you heard of that company? 
A. 
It's the company name that our registration 
for the helicopters is under, Air Ghislaine. 
Q. 
Is that somebody who's ever paid you, a 
company who's ever paid you? 
A. 
No. 
Q. 
Do you know Igor Zinoviev? 
A. 
Yes. 
Q. 
How do you know him? 
A. 
Met him on the airplane. 
Q. 
What is your understanding of his affiliation 
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114 
with Jeffrey Epstein? 
A. 
I don't know. 
He doesn't talk much. 
Q. 
Okay. 
And Sandy Berger, do you know who that 
is? 
A. 
I don't know. 
Q. 
Do you know any reason why you would have 
flown him on the airplane? 
A. 
I don't even know the name. 
Q. 
A. 
I know the name 
Q. 
Somebody who flew on the plane pretty 
regularly? 
A. 
I would have to look at the logs. 
I think 
we've had that name on several -- it's a common first 
name. 
I'm not familiar really on who that is. 
Q. 
What about 
, do you know who 
is? 
Is that a name you ever heard? 
A. 
Yes. 
Q. 
Works up in the New York office or something? 
A. 
Yes. 
Q. 
Have you ever spoken with 
personally? 
A. 
Yes. 
Q. 
Do you know what she does for Jeffrey Epstein, 
if anything? 
A. 
I don't know exactly what her role is. 
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115 
Q. 
Do you know -- did you tell me, do you know 
what Leslie Gruff does for Jeffrey Epstein? 
A. 
I don't know her exact title. 
Q. 
You talked to all of these individuals at some 
point in time, either on the phone or in person, right? 
A. 
Yes. 
Q. 
And you don't know whether they play a role in 
Jeffrey Epstein's life, or if they do, what they do? 
A. 
Exactly. 
Q. 
And how do you decide who you're going to call 
for what reason? 
A. 
For example? 
Can you be more specific? 
Q. 
If you're going to make a telephone call and 
you're going to talk to let's say Leslie Gruff, why 
would you choose to call her? 
A. 
I don't know. 
You're having me make the phone 
call. 
I don't know why I would call her. 
Q • 
Have you ever called her? 
A. 
I think, yes, I've called her, sure. 
Q. 
Why? 
What would be the reason that you would 
call her? 
Somebody told you to call her? 
Here, call 
this number? 
A. 
I may have called her maybe to find out if we 
had a departure time for any specific trip. 
I mean, 
that would be.. . 
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116 
Q. 
Okay. So you're calling her related to 
Jeffrey Epstein? 
A. 
Sure. 
Q. 
Okay. So you know that she plays some role in 
some aspect of Jeffrey Epstein's life, whatever that is? 
A. 
Right. 
Q. 
Okay. So when I'm asking these questions 
about these people, and I feel like I'm getting answers 
that I'm not really not sure that these people have any 
role in their life, that's not -- that's not completely 
accurate, right? 
MR. CRITTON: Form; argumentative. 
BY MR. EDWARDS: 
Q. 
I mean, you do know that these people are 
somehow involved with him, whether socially or 
business-wise or otherwise, and during the course of 
your years, you've made telephone calls on his behalf or 
to coordinate things with them right? 
A. 
Right. 
MR. CRITTON: Object to the form. 
You said 
'these people.' 
BY MR. EDWARDS: 
O. 
I'm talking about 
. 
That's 
somebody you called before, right? 
A. 
Sure. 
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Q. 
What would be a reason you called 
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, would 
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 call 
Ms. Maxwell, Ghislaine Maxwell? 
A. 
Same reason. 
Q. 
That's not somebody you call these days, 
though, right? 
A. 
I haven'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 a person to call related to your job? 
A. 
Just was no reason to. 
Q. 
Is that somebody who you think is still 
affiliated or associated with Jeffrey Epstein or his --
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whatever he does? 
A. 
I'd only can speculating. 
I don't know. 
Q. 
All right. 
Do you know the number 
MR. CRITTON: Could you say it slowly. III? 
MR. EDWARDS: 
. 
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 them later. 
BY MR. EDWARDS: 
Q. 
Do you know that number? 
A. 
Yes. 
Q. 
What is that number? 
A. 
That's my cell phone. 
Q. 
Okay. 
Is that still your cell phone? 
A. 
Yes, sir. 
Q. 
All right. 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 5th, 2005. Do you remember making this telephone 
call? 
And just for the record, this looks like a 
message that's being taken relative to a phone call that 
you made. 
MR. REINHART: 
So the question is does he 
remember making the phone call? 
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BY MR. EDWARDS: 
Q. 
Do you remember making that phone call after 
reading the message? 
A. 
Let me look 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 to drop off foam and 
papers." 
I don't know. 
MR. EDWARDS: 
BY 
119 
Q. 
That doesn't mean anything to you? 
A. 
That doesn't -- I mean, you're talking four 
years ago. 
I can't answer that accurately. 
I mean.. . 
MR. REINHART: 
So the answer is you don't 
recall? 
THE WITNESS: 
Yeah, I don't recall. 
BY MR. EDWARDS: 
Q. 
If you don't remember, that's fine. 
(Plaintiff's Exhibit Nos. 2 AND 3 were marked 
for identification.) 
BY MR. EDWARDS: 
Q. 
So I'll show you Exhibit 3, the same type of 
document, and I can make the representation that this 
was message pads provided by the state attorney's office 
relative to the criminal investigation revolving around 
3527-003 
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
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Larry Visoski 
October 15, 2009 
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120 
Jeffrey Epstein. So that's how I have these documents. 
I'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. 
I mean, "Tom from Midnight Express is at 
convention center with new boat. 
They are two parts 
of" -- I mean 
Q. 
But as Jeffrey Epstein's pilot, why would you 
be leaving such a message about Tom from Midnight 
Express relative to boats and a boat show? 
A. 
I help out with boat purchases or, you know, 
anything to do with, you know, that moves. So I mean, 
3527-003 
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