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years old? 
MR. CRITTON: Form. 
THE WITNESS: No. 
BY MR. EDWARDS: 
O. 
Never? 
A. 
Never. 
Q. 
Have you ever seen any photographs in any of 
his homes depicting young-looking girls engaging in sex 
acts? 
A. 
No. 
Q. 
Or reading directly from the complaint, 
"engaged in lewd acts"? 
A. 
No, absolutely not. 
Q. 
Have you looked around the walls of his 
various homes when you're in there picking up luggage? 
A. 
I mean, not any more than I walked in here and 
not looking at the walls over there, I couldn't tell you 
what those are; so nothing specific. 
Q. 
Sometimes we're talking about a 50,000 square 
:Mot house? 
A. 
Exactly. 
Q. 
In Manhattan? 
A. 
It's pretty big. 
Q. 
Okay. 
Have you ever looked at any of his 
computers for any reason? 
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A. 
No. 
Q. 
I know that you helped set up some of the --
142 
A. 
Computers are not my expertise. 
Q. 
All right. 
Have you ever been told that 
Mr. Epstein committed sex acts against underage girls on 
a literal daily basis, that's what he does? 
A. 
I've never been told that. 
Q. 
Have you ever read the complaints against him 
that indicate that's what he does on a daily basis? 
MR. CRITTON: 
Form. 
THE WITNESS: 
No. 
BY MR. EDWARDS: 
Q. 
So in your mind, you never believed that you 
were transporting around somebody whose sole goal in 
life is to get -- have sex with little girls? 
MR. CRITTON: 
Form. 
THE WITNESS: 
I never believed that, no. 
BY MR. EDWARDS: 
Q. 
Okay. 
Have you ever been told that he 
conspired with others, including assistants and/or his 
drivers and/or pilots and his friend Ghislaine Maxwell, 
to further these sex acts and to avoid police detection? 
MR. CRITTON: 
Form. 
BY MR. EDWARDS: 
Q. 
Have you ever -- anybody ever questioned you 
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about that? 
MR. REINHART: 
Hold on. 
The question is have 
you ever been told that fact that he just read to 
you? 
BY MR. EDWARDS: 
Q. 
Right. 
A. 
I have never been told that fact. 
Q. 
Has anybody ever questioned you about your 
possible involvement with helping to facilitate 
Mr. Epstein have sex with underage girls? 
A. 
No. 
Q. 
When you were questioned by either the police 
or the -- whoever the investigative resource that was 
being used at the time? 
A. 
Right. 
Q. 
Do you remember who that person was that was 
questioning you? 
A. 
No, I don't remember. 
Q. 
I know you don't know the location where it 
was, but do you remember who they were affiliated with? 
A. 
No. 
Q. 
Was it only one time? 
A. 
Yes. 
Q. 
Did you also have to testify before a grand 
jury proceeding? 
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A. 
No, I did not. 
Q. 
Have you ever known Mr. Epstein to get a 
massage while on an airplane? 
PHONE ATTORNEY: This is everybody in Boone, 
Charles and the witness is here and the court 
reporter and the videographer. 
MR. EDWARDS: Fantastic, but I think that you 
may have the wrong room. 
PHONE ATTORNEY: 
I was told to ask for 856. 
MR. EDWARDS: 
Let's go off the record. 
(Off the record discussion.) 
BY MR. EDWARDS: 
Q. 
All right. 
In the complaint, I'm going to 
tell you what it alleges and I'm going to ask if this 
helps to refresh your recollection about any of Jeffrey 
Epstein's activities. The defendant, Jeffrey Epstein, 
transported the plaintiff to another state in order to 
engage in sex acts with her. 
And this occurred when she 
was merely 15 years old. 
Do you remember transporting somebody that 
looked like they were 15 years old on your airplane? 
A. 
No, sir. 
Q. 
You never remember taking a 15-year-old, or 
somebody that looks around that approximate age, on your 
airplane? 
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A. 
Can you be more specific? 
Q. 
Well, I know that you've indicated earlier in 
the deposition that you remember some girls under the 
age of 18 on the airplane. 
And so let me ask, before I 
get back into this, whether all those individuals you 
were talking about were accompanied by a parent or some 
of those people were on the airplane for some other 
purpose, modeling, or you don't know why they were 
there? 
I'm going to let you elaborate on who these 
people are that you believe may have been under the age 
of 18 and why you think they were on the airplane? 
MR. CRITTON: Form. 
THE WITNESS: 
We've had younger people on the 
airplane that have been, you know, with their 
family members, like you said. I don't remember 
transporting anybody that was of questionable age. 
I'm not -- I'd only be guessing at somebody's age 
if I didn't ID them at the foot of the airplane. 
So I can't guess to their age. 
BY MR. EDWARDS: 
Q. 
All right. 'Mr. Epstein used his private jet 
to transport the minor plaintiff to Manhattan where he 
provided her spending money and accommodations with him 
at his mansion." 
Do you have any idea who that might be 
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referring to? 
MR. CRITTON: Form. 
THE WITNESS: 
No, sir. 
BY MR. EDWARDS: 
Q. 
And you don't remember being a pilot of an 
airplane where he was transporting a 15-year-old to 
Manhattan from Miami or Palm Beach? 
A. 
No. 
I'd be guessing at somebody's age and I 
can't guess. 
Q. 
"Defendant transported plaintiff in his 
private jet to locations that included Palm Beach, New 
York City, Santa Fe, Los Angeles, San Francisco, 
St. Louis." 
Do you remember ever piloting his airplane to 
those destinations that I just mentioned? 
MR. REINHART: Can we break them down? 
Objection; compound. 
MR. EDWARDS: Okay. 
BY MR. EDWARDS: 
Q. 
Have you ever flown his airplane to Palm 
Beach? 
A. 
Yes, sir. 
Q. 
Okay. 
Have you ever flown it to New York 
City? 
A. 
Yes. 
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Q. 
To Santa Fe? 
A. 
Yes. 
Q. 
To Los Angeles? 
A. 
Yes. 
Q. 
To San Francisco? 
A. 
Yes. 
Q. 
To St. Louis? 
A. 
Yes. 
Q. 
All right. Continuing to international 
destinations, including Europe, have you ever flown it 
to Europe? 
A. 
Yes. 
Q. 
The Caribbean? 
A. 
Yes. 
Q. 
And Africa? 
A. 
Yes. 
Q. 
On those flights to those various places, is 
it your -- to the best of your knowledge, you were 
unaware of Jeffrey Epstein engaging in sex with underage 
girls on his airplane? 
MR. CRITTON: Form. 
THE WITNESS: 
I have no knowledge of any of 
that. 
BY MR. EDWARDS: 
Q. 
"He provided accommodations with him in order 
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to have her available to him at all times whenever he 
wanted, including while transporting the minor plaintiff 
on his private jet.• 
That's something that you had no knowledge of? 
A. 
(Witness shakes head.) 
Q. 
You have to a yes or no. 
A. 
I'm sorry, no. 
Q. 
"Each time they would travel to one of these 
destinations, the same pattern of sexual abuse would 
occur, often with a vast array of aspiring models, 
actresses, celebrities, and/or other females, including 
minors from all over the world." 
Again, that's something you have no personal 
knowledge of? 
A. 
No. 
Q. 
Has anybody ever indicated that if you did 
have personal knowledge of some of these things, then 
you could also have been implicated in some form of a 
crime? 
Has any law enforcement or anybody ever 
indicated that to you? 
A. 
No. 
Q. 
Okay. 
Is that something you've ever worried 
about? 
A. 
No. 
Q. 
All right. "Upon information and belief, 
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defendant transported minor girls from Turkey." Did you 
ever leave in one of his airplanes out of Turkey? 
A. 
I'd have to look at the records. 
I don't 
recall Turkey. 
O. 
Do you ever remember taking any minor girls 
out of Turkey? 
A. 
No, I don't remember. 
Q. 
What records would you have to look at to see 
if you took people out or left out of Turkey? 
A. 
I'd have to look at the flight logs, but I 
personally don't remember flying into Turkey. 
Q. 
And would the flight logs coming into the 
United States from Turkey indicate the names of the 
people on the plane? 
A. 
They might. 
Q. 
Okay. 
Where would I get those particular 
flight logs that would have that information? 
A. 
Depended upon what year you're talking. 
Q. 
We're talking in this particular complaint 
between 1998 and 2002. 
A. 
I'm not -- I don't possess those passenger 
manifests. 
Q. 
Do you know who would possess those? 
A. 
That would be I guess --
MR. REINHART: 
Do you know who has them today? 
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THE WITNESS: 
I do not know who has them 
today. 
BY MR. EDWARDS: 
Q. 
Who did you give them to? 
A. 
Actually, I didn't give them to anybody. Dave 
Rogers was in possession of those logs. So I don't know 
where they are right now. 
Q. 
You're still thinking that the best evidence 
of that, any flight that may have left out of Turkey, 
would be in the flight logs that's marked as Composite 
Exhibit 1, or are we talking about the manifests that 
we've been referring to? 
A. 
I don't know how accurate that log book is or 
even how accurate the passenger manifest is. 
Q. 
Okay. So there may be no actual documentation 
indicating a flight leaving out of Turkey when, in fact, 
a flight may have left out of Turkey? 
A. 
Correct. 
Q. 
Okay. 
The Czech Republic is the next place 
listed. Is that a place you've flown to or from in a 
Jeffrey Epstein airplane? 
A. 
More specific, could you name the city? 
Q. 
I can't name the city, at least the complaint 
doesn't name the city. But I've been to the Czech 
Republic before. Anywhere within that country, have you 
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ever flown to or from in a Jeffrey Epstein airplane? 
A. 
We have flown to Prague. 
Q. 
Okay. 
Have you picked people up in Prague and 
flown out of Prague? 
A. 
I don't remember. 
Q. 
I'm not saying no, you didn't, but --
A. 
Best of my knowledge. 
Q. 
-- you don't remember? 
A. 
Exactly. Best of my knowledge, I don't 
remember. 
Q. 
Do you remember the reason for going to Turkey 
or to Prague? 
A. 
No. 
Q. 
This also says Asia. 
Have you ever flown to 
or from Asia with Jeffrey Epstein? 
A. 
Yes. 
Q. 
Or on a Jeffrey Epstein airplane? 
A. 
Yes. 
Q. 
Do you know the purpose of those flights to 
and from Asia? 
A. 
No. 
Q. 
Did it ever occur to you that maybe it was to 
pick up minor girls for him to have sex with on the back 
of the airplane? 
MR. CRITTON: Form. 
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THE WITNESS: 
Never occurred to me. 
BY MR. EDWARDS: 
Q. 
Did you ever hear that he maintained some of 
these underage girls as sex slaves --
A. 
Never heard of such a thing. 
Q. 
-- from the age of 12 through the age of 16? 
MR. CRITTON: Form. 
THE WITNESS: 
No knowledge of that. 
BY MR. EDWARDS: 
Q. 
Ever picked up girls that looked young, many 
of whom who spoke no English? 
Do you ever remember 
that? 
A. 
Zero, do not. 
Q. 
All right. 
The complaint goes on to say, 
"Plaintiff was required to be sexually exploited by 
defendant's adult male peers, including royalty." So 
I'm going to talk, do you have any familiarity with 
Prince Andrew? 
A. 
I know who he is. 
Q. 
Was he ever on the airplane? 
A. 
He may have been on the airplane. 
Q. 
Do you remember him on the airplane with young 
girls? 
A. 
No, I do not. 
Q. 
Do you remember Jeffrey Epstein flying in to 
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meet with Prince Andrew? 
A. 
I don't remember. 
I know that happened, but I 
couldn't be accurate. 
Q. 
Has Prince Andrew ever been on the airplane at 
the same time as a young girl, to the best of your 
memory and knowledge? 
A. 
To the best of my knowledge, no. 
Q. 
This also says politicians, talking about 
local or U.S. politicians. Do you remember certain 
politicians being on the airplane? 
A. 
No -- I mean yes, I do. 
Q. 
What politicians would that be? 
A. 
President Clinton. 
Q. 
Okay. 
Who else? 
A. 
Former president of Israel -- help me out with 
the name, Barak? 
Q. 
Ehud Barak? 
A. 
Yes, those are the two that I remember. 
Q. 
How many times was Ehud Barak on the airplane 
that you piloted for Mr. Epstein? 
A. 
Maybe once. 
Q. 
And where did that flight pick up and where 
did it go to, to the best of your memory? 
A. 
Best of my memory, it was Palm Beach to 
Teterboro. 
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Q. 
Where is Teterboro? 
A. 
In New Jersey. 
Q. 
And what was the purpose of that flight, do 
you know? 
A. 
I don't know. 
Q. 
Was Jeffrey Epstein on the flight? 
A. 
I'd have to look at the flight logs to 
guarantee. 
Q. 
Anything about that flight stick out in your 
mind? 
A. 
None. 
Q • 
Such as a fine needing to be paid because it 
left after 10:00 p.m.? 
A. 
For that was the flight, yes. 
Q. 
You remember that? 
A. 
It's coming back to me. 
Q. 
And do you remember young girls being on that 
flight? 
A. 
No. 
Q. 
All right. 
A. 
I remember the fine. 
Q. 
Do you remember who paid the fine? 
MR. CRITTON: Hold on. 
Let me object to form 
of the question. 'Do you remember' it suggests 
that there were. So form, predicate. 
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BY MR. EDWARDS: 
Q. 
Okay. Do you remember who else was on that 
flight that left after 10 p.m.? 
A. 
No, I do not. 
0. 
Do you remember why it left after 10 p.m.? 
A. 
No, I do not. 
Q. 
Do you remember Jeffrey Epstein instructing 
you to wait until after 10 p.m. to leave? 
A. 
No. 
Q. 
Would you have listened to him if he had told 
you -- if he had instructed you to do that? 
A. 
I don't understand the question. 
Q. 
Well, if he told you wait until after 10 p.m., 
I realize there's going to be a fine, but wait until 
after 10 p.m. to leave, intentionally leaving 
after 10 p.m., do you remember that instruction ever --
A. 
No, I don't remember that instruction. 
Q. 
Okay. 
A. 
I mean, it just happened to be departing 
after 10 and there is a penalty for leaving after 10 for 
noise. So there was no intention to.. . 
Q. 
All right. This also talks about this 
particular person 15 years old being sexually exploited 
by businessmen and/or other professional or personal 
acquaintances. 
Are you aware of other personal or 
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professional acquaintances of Jeffrey Epstein also 
sexually abusing or exploiting little kids or underage 
girls on your airplane? 
MR. CRITTON: 
Form. 
THE WITNESS: 
No. 
BY MR. EDWARDS: 
Q. 
If you had been aware that Mr. Epstein was --
and by this -- this is more in the form of a 
hypothetical, and that I'm not going to suggest to you 
it's a fact that he was. 
But if you had been aware that 
every single day Jeffrey Epstein's goal was to locate 
underage girls for the purposes of sex, and either have 
sex with them on the airplane or at some other 
designation that you were destination that you were 
traveling him to, would you have continued to pilot 
those planes? 
MR. CRITTON: 
Form. 
THE WITNESS: 
You said it was hypothetical? 
BY MR. EDWARDS: 
Q. 
Right, it is a hypothetical. 
A. 
Why would I want to answer that? 
Because 
you're being hypothetical. 
I mean, it would obviously 
be wrong. 
Q. 
Sure. 
Well, a hypothetical question is a 
legal question that I'm allowed to ask. 
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A. 
Okay. 
Q. 
And I'm just asking you if you did have 
knowledge that Jeffrey Epstein was having sex with 
little girls either on the plane or at a place that you 
were taking him to or from on a daily basis, that's what 
he did, would you have continued to be his pilot? 
MR. CRITTON: 
Let me object. Object to the 
form. It's argumentative. It has no more value 
than assuming he was chopping up bodies or anybody 
was chopping up bodies in the plane you're flying. 
What difference does it make? Form. 
MR. EDWARDS: 
What difference does it make in 
a case about him having sex with little girls? I'm 
not going to argue with you about it. 
You've 
stated your objection. 
MR. CRITTON: Exactly. It's an argumentative 
question. 
MR. EDWARDS: I'm not going to argue with you 
about it. 
MR. CRITTON: 
You're arguing with him about 
now. 
MR. EDWARDS: No, I'm asking him the 
hypothetical. 
BY MR. EDWARDS: 
Q. 
Can you answer that? 
Would you have continued 
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to be a pilot for somebody who's traveling to and from 
destinations with the goal of having sex with underage 
girls? 
MR. CRITTON: Form. 
THE WITNESS: 
It could be any person. 
It 
doesn't have to be Jeffrey Epstein, then, right? 
BY MR. EDWARDS: 
Q • 
True. 
A. 
No, I wouldn't pilot an airplane if there was 
wrongdoing going on. 
Q. 
That you knew about? 
A. 
That I knew you about, sure. 
Q. 
Me reading this complaint to you, is this the 
first time you've heard these allegations --
A. 
Yes. 
Q. 
-- against Mr. Epstein? 
A. 
Yes. 
Q. 
It goes on to say, "On one of Epstein's 
birthdays, a friend of Epstein sent him three 
12-year-old girls from France who spoke no English for 
the purpose of -- for defendant to sexually exploit and 
abuse. 
After doing so, they were sent back to France 
the next day." 
Are you familiar with that occasion? 
MR. CRITTON: Form. 
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THE WITNESS: 
Never heard of such a thing. 
BY MR. EDWARDS: 
Q. 
Do you know of any friends that he has in 
France that would send him birthday -- a birthday 
present? 
A. 
No. 
Q. 
Do you know of him receiving any birthday 
159 
gifts or birthday people from anyone? 
A. 
Never. 
Q. 
This particular person that filed this 
complaint, Jane Doe 102, indicates "Defendant and 
Ghislaine Maxwell acknowledged and celebrated 
plaintiff's 16th birthday." 
Do you remember them celebrating somebody who 
you flew on the airplane's 16th birthday? 
A. 
I don't recall. 
Q. 
Any of this jog your memory as to who 
is? 
A. 
No. 
Q. 
"From the age of 15, plaintiff" -- this Jane 
Doe 102 -- "was sexually exploited and abused by 
defendant on a daily basis and often multiple times each 
day." 
So going back, was there ever a day where you 
were with Jeffrey Epstein where you could observe him 
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and 
during an entire day? 
MR. CRITTON: 
Form. 
THE WITNESS: 
I don't remember 
, so I couldn't answer the question. 
BY MR. EDWARDS: 
Q. 
"In September 2002, Defendant Epstein 
purchased a commercial round-trip airline ticket and 
provided a passport, U.S. currency and accommodations 
for plaintiff to fly to Thailand." 
Do you remember him doing that for anybody 
around that time period? 
A. 
No, sir. 
MR. CRITTON: 
What was the date? 
MR. EDWARDS: 
September 2002. 
MR. CRITTON: 
Okay, thanks. 
MR. EDWARDS: 
I have here -- and this is 
actually my only copy, so I don't mind marking it 
as a composite exhibit, but we'll either have to 
copy this while thing or we'll have an agreement of 
counsel. 
It's the visitor inmate log from when 
Mr. Epstein was in jail in Palm Beach. 
MR. CRITTON: 
Well, before we get started, it 
is now 1:15. 
We started at 10:00. 
MR. EDWARDS: 
We didn't really start at 10:00. 
MR. CRITTON: 
Shortly thereafter. 
I was here 
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