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pretty much after 10. 
But we've been here since 
10:00. 
I 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. 
All right. 
I 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. 
Q. 
Seem to be accurate in terms of how many times 
you went to visit him? 
A. 
I thought six, but yes, that's.. . 
Q. 
I'll let 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. 
(Plaintiff's Exhibit No. 5 was marked for 
identification.) 
MR. REINHART: It's two pages. 
MR. EDWARDS: Two pages. 
MR. REINHART: Okay. 
BY MR. EDWARDS: 
Q. 
Seem accurate? 
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A. 
Yes. 
Q. 
162 
Okay. 
Jeffrey Epstein's plea, I believe, was 
June 30th, 2008. 
I 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 2inoviev. 
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. 
you? 
How did you know that Jeffrey wanted to see 
A. 
I don't recall who called and told me that he 
wanted to see me. 
I couldn't give you an accurate name, 
whether it was, you know, his attorney, Darren. 
And 
actually, I would put a lot weight to I think it was 
Darren, his attorney 
said 
Q. 
That would have made a phone call to you that 
A. 
Yeah, to 
Q. 
go. 
And what did you talk about with Jeffrey 
Epstein four days after he pled guilty to offenses that 
landed him in jail? 
A. 
I think the first visit was how disappointed 
or how scared he was, you know, being inside there. 
We 
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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 items 
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 long did you visit with him on that first 
visit, July 3rd? 
A. 
I think we stayed the full hour. 
was? 
Q. 
All right. Is that what the time allotment 
A. 
I believe it is, yeah. 
I don't think you 
could leave early, or I'm not aware that you could leave 
early, until later on we found out you could stay for 
five minutes or longer. But I 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. 
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Q. 
And did Igor talk to him as well? 
A. 
Briefly. 
I 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, I 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. 
I believe we did. 
I believe I 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 vehicle did you drive? 
A. 
The Hummer. 
Q. 
That's the vehicle you described earlier as 
the company vehicle? 
A. 
Yes, sir. 
Q. 
Is that a vehicle paid for by Jeffrey Epstein? 
A. 
Meaning? 
Q. 
Well, is that a vehicle paid for by you? 
A. 
What do you mean "paid for"? 
Q. 
Did you purchase the vehicle with your money? 
A. 
I 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 a corporation. 
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MR. CRITTON: Form; move to strike. Sounds 
like a guess. 
BY MR. EDWARDS: 
Q. 
To the best of your knowledge, that's how most 
of the items that you've discussed -- that being the 
Boeing and the Gulfstream -- they were usually held in 
corporate names, to your knowledge? 
A. 
To my knowledge, exactly, yes. 
Q. 
And so when you're saying the -- when you're 
calking about the Hummer vehicle and you're stating that 
it's likely a corporate entity, is that just something 
that you're guessing about, or do you have knowledge? 
A. 
No, I'm just guessing. 
Q. 
Okay. 
A. 
I have no proof --
Q. 
-- of ownership of who it's registered to or 
anything like that? 
A. 
Exactly. 
Q. 
Is it registered to you? 
A. 
No, no. 
Q. 
So it's registered to somebody other than you? 
A. 
Exactly. 
Q. 
Okay. 
A. 
I just drive it, I guess. 
Q. 
Okay. So on July 5th, 2008, you go back to 
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see him in jail again, and again, Igor Zinoviev is 
listed as a visitor. 
Did you go with him together on 
that occasion? 
A. 
I didn't even realize it was two days after 
the first visit. 
Q. 
Well, I mean, you see where this is going? 
A. 
Yeah, I do. 
It gets further apart, yeah. 
Q. 
Do you remember what the discussion was on 
7/5/DS? 
A. 
No, because it's probably similar to the first 
one. 
I mean, we talked -- actually, one of the visits 
we talked about fishing and just trying to -- you know, 
we were talking about things that would just occupy his 
mind with intelligent conversation that he probably 
wasn't getting there. 
So for that hour of the day, I 
tried to give my best of intelligent conversation to 
him. 
Q. 
Okay. 
On his visitor log you were the first 
one to go visit him. 
Did you know that? 
A. 
I did not know that. 
I wasn't aware of that. 
MR. CRITTON: Let me just object to form to 
the last question. 
BY MR. EDWARDS: 
Q. 
Well, at least if these records are accurate, 
which are the records that were provided to us by the 
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facility that was holding Jeffrey Epstein, they're 
accurate, your name is the first one listed on the top 
of the sheet? 
A. 
Right. 
There may have been earlier dates. 
I 
have no idea. 
Q. 
Well, you know, the first date that he could 
have been in there it looks like was 7/1/08 and then, 
you know, so I guess somebody could have seen him 7/1 or 
1/2, but those records were never provided to us. 
You 
see we were provided a whole big stack. 
A. 
I understand. 
Q. 
The next date I'm going to talk to you about 
is 7/12/08. 
A. 
Uh-huh. 
O. 
It looks, again, like it's yourself and Igor 
Zinoviev? 
A. 
Mm-hmm. 
Q. 
And that's something we talked about in this 
deposition. 
I'm going to ask you again, I don't know 
that you elaborated last time, what is your 
understanding of his relationship with Jeffrey Epstein? 
Is that a friend of his? 
A. 
I don't know his job description. 
I mean, 
he's somebody that's around a lot, but I don't know his 
exact job description. 
His English is, to say, not 
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100 percent, so conversation with somebody that doesn't 
fully understand you, you know, you get lost in 
translation a little bit. 
So I don't 
Q. 
So on these three visits to the jail, the 
first three that we're talking about that we've talked 
about so far, each of those times you traveled to and 
from the jail with Igor? 
A. 
Mm-hmm. 
Q. 
Yes? 
A. 
Yes, yes. 
Q. 
And each of those time, is it fair to say you 
had some form of communication either on the way to the 
jail or 
A. 
Sure. 
Q. 
-- to the jail? 
A. 
Yeah. 
Q. 
Since you're going to see an inmate in the 
jail, is it a safe assumption a portion of that 
conversation was about the person that you're going to 
see and possibly the crime that was committed? 
A. 
Yes, that would be a good assumption. 
Q. 
Okay. 
And what was the form -- what was the 
substance of that conversation that you can remember 
related to Jeffrey Epstein and the location you were 
going to visit him? 
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A. 
I think Igor and I discussed on trying to be 
upbeat and not look at the position that he's in sitting 
across the table from us, to be upbeat and uplift his 
spirits. 
Q. 
Did you and Igor discuss whether or not you 
were going to talk to him about his plea of guilty or 
the fact that he's not registered as a sex offender? 
A. 
No. 
Q. 
Or whether you were going to stay away from 
those topics? 
MR. CRITTON: Form. 
THE WITNESS: 
We never -- we don't discuss 
that amongst ourselves and/or with Jeffrey in any 
way, form. 
BY MR. EDWARDS: 
Q. 
Okay. But that's not -- I realize you didn't 
discuss that. You've told me that. 
A. 
Right, but we didn't discuss that even prior 
to going in, as you asked. 
Q. 
Okay. So your discussion was mainly hey, 
let's be upbeat? 
A. 
Yes. 
Q. 
And that was to, in essence, maintain his 
spirits or raise his spirits? 
A. 
Exactly. 
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Q. 
Okay. 
And you were doing that as a friend of 
his, not just his pilot, right? 
A. 
I felt honored that he asked me to come and 
give support like that, because prior to him going away, 
it was known to us that there was going to be no 
visitors, because I had offered to him that I would be 
happy to come and visit him if he deemed it necessary, 
and he says no, I'm not going to have anybody. 
Q. 
So --
A. 
I guess it was so bad there, that he may have 
changed his mind and wanted to have some visitors. 
Q. 
When did you have this conversation with him 
where he indicated he was not going to have visitors 
while he was in jail? 
A. 
I don't exactly remember. 
It may have been on 
the trip heading to Palm Beach, the last flight. 
Q. 
From his island, from St. Thomas I guess it 
would be from? 
A. 
I forgot where it started from. 
It might have 
been New York or the island, one of the two. 
I don't 
remember the last flight. 
Q. 
And I mean, did at least the fact come up that 
hey, this a person who you're 
is going to be in jail 
for some time? 
A. 
Mm-hmm, yes. 
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Q. 
And in the course of that conversation, again, 
the allegations and the unusual I'll call it case 
against him, that didn't come up between you and 
Mr. Epstein? 
A. 
I never talked about it with him. 
Q. 
And at that point in time, what were you aware 
of in terms of the number of girls that he was alleged 
to have had sexual 
some sort of sexual relationship 
with him at his Palm Beach house? 
A. 
What was the question? 
How many girls? 
Q. 
Yeah, how many girls were you --
A. 
Aware of? 
Q. 
-- aware of? 
A. 
None. 
I wasn't aware of any, to be honest. 
O. 
The next visit is on 7/17/08 and it's Igor 
Zinoviev and somebody named Jean Rene and then yourself. 
Do you know who Jean Rene is? 
A. 
No. 
Q. 
Do you think that that visit, that you visited 
him at the same time that Jean Rene visited? 
MR. CRITTON: 
What's the date? 
MR. EDWARDS: It's 7/17/08. 
THE WITNESS: No, I don't know a Jean Rene, 
unless somebody came after. 
I mean, I don't -- I 
don't know a Jean Rene. 
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BY MR. EDWARDS: 
Q. 
Okay. 
And then before you visited him again, 
the visitors are listed as 
or 
A. 
Mm-hmm. 
Q. 
Mainly those two individuals. 
And they list 
as addresses, 
A. 
Uh-huh. 
as their residence? 
Q. 
Given your previous testimony, does that 
surprise you that they list those 
that address as 
their residence? 
MR. CRITTON: Form. 
THE WITNESS: I've seen them there, so I mean, 
I'm not surprised. 
BY MR. EDWARDS: 
Q. 
Okay. Did you know that they were visiting 
him in jail? 
A. 
No, I didn't know who was scheduled to see him 
or whatever. 
Q. 
Did Jeffrey talk to you at any point in time 
about 
or 
A. 
No, not at all. 
MR. REINHART: Can we get a time frame for 
that? Ever? 
MR. EDWARDS: Oh, no, well, I was talking --
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I'm sorry. 
BY MR. EDWARDS: 
Q. 
I was talking right now about in the 
conversations that you had with him that we've discussed 
with you and him in the jail facility. Did he discuss 
with you 
A. 
No, no. 
Q• 
or 
Did he talk to you about whether or not you 
should talk to anybody about his criminal investigation 
or possible litigation? 
A. 
No, not at all. 
Q. 
The next time you see him is on August 9th, 
2008, at the jail. 
In that occasion it mentions as his 
visitors that day 
and 
Larry Visolli. 
Did you go to the jail with 
and 
that time? 
A. 
No. 
Who was on there? 
Which one are you 
referring to? 
Q. 
The next one, I tried to highlight them just 
that 
A. 
Right, that one. 
MR. REINHART: 8/9. 
BY MR. EDWARDS: 
Q. 
8/9/08? 
A. 
One of those two we all drove together. 
I 
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don't remember which one it was. 
It was either the 9 or 
the 16, and then the other one I met everybody there. 
So I can't be accurate on which time we all drove 
together. 
Q. 
How did you coordinate driving together? 
A. 
I don't exactly remember now. 
I mean, I think 
and I may have conversed on the phone and said do 
you want to meet at Jeffrey's house and we all drive 
together? Does it make sense to get together and drive 
one car. 
Q. 
Is that jail visit the result of Jeffrey 
Epstein requesting your presence there, or is that the 
result of you wanting to go see him as a friend in jail? 
A. 
A combination of both. I'm sure if I said, 
Hey, I'd like to come to jail and visit you, that he 
would either say yea or nay. 
Q. 
Okay. 
And you said at least on one of those 
occasions you rode to and from the jail with 
and 
A. 
Yes. 
Q. 
And during any of 
obviously, when you're in 
the car together -- well, who's driving the car? 
A. 
I was driving, I believe. 
Q • 
And that's the Hummer again? 
A. 
Actually, I think we take one of the suburbans 
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at the house. 
Q. 
Those are cars that Jeffrey Epstein owns, to 
your knowledge? 
A. 
I don't know who owns them. 
Q. 
What cars are there that -- I know with this 
175 
case we're dealing with a lot of corporations and it's 
not like asking me, Hey, what car do you own? 
But what 
cars are you aware that are -- that you believe are used 
primarily by Jeffrey Epstein? 
A. 
Used primarily by Jeffrey Epstein, a Mercedes 
S500 sedan. 
I don't remember the year on that one. 
Q. 
Okay. 
A. 
There's a Cadillac Escalade. 
Q. 
Okay. 
A. 
Those are his two main cars that he would be 
driven in 
Q. 
What are the other cars that you regularly see 
parked at his Palm Beach mansion, if there are any? 
A. 
It would be a whole array. Half the time the 
parking lot is full because of construction workers, 
yards keepers. 
Q. 
Okay. Fair enough. 
What vehicle does 
drive or 
drive when they're down 
here, if you know? 
A. 
I mean, anybody has a choice to pick out a car 
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or whatever there. I've seen 
driving a Mercedes 
convertible. 
Q. 
Is that different than the Mercedes S500 
sedan? 
A. 
Yes, I think it's different. 
Q. 
When you say they have basically a choice of 
cars to drive --
A. 
Well, there's cars in the lot there. 
Q. 
Obviously, they can't get in one of the 
construction workers' cars? 
A. 
No. 
MR. REINHART: 
Let him finish his question. 
BY MR. EDWARDS: 
Q. 
So that's kind of what I'm getting at. What 
other cars do you think that Jeffrey Epstein has --
whether it's titled, I don't know --
A. 
Right. 
Q. 
but he is the person in control of that 
vehicle? 
A. 
Right. 
Q. 
What other vehicles do you think he's 
controlling in Palm Beach? 
A. 
In Palm Beach? 
Q. 
We've named the Mercedes S500 sedan, Cadillac 
Escalade? 
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A. 
Right. 
Q. 
And I've identified a Mercedes convertible? 
A. 
Right. 
Q. 
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 
and 
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. 
At any 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 
provides the role of a 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. 
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BY MR. EDWARDS: 
Q. 
Have you been led to believe that by anybody? 
A. 
No. 
MR. CRITTON: 
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. 
I 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. 
It's irrelevant and it's not 
likely to lead to discoverable evidence what his 
opinion is on a law that's been passed by the 
legislature 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 multitude of underage females, 
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he utilizes various people, 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 
questioning 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 least 
reasonably calculated to the lead 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 I talk with -- well, I know I 
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 previously 
said he would have never allowed anything on the 
plane to be done illegally. 
If you want to ask if 
he agrees with the law applied by the 
legislature -- do you agree the law passed by the 
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state of Florida should be complied with? 
THE WITNESS: 
I don't know what the law is. 
BY MR. EDWARDS: 
Q. 
Okay. 
The laws in place to protect children 
under the age of 18 from being sexually touched, 
fondled, molested by people over the age of 24, do you 
agree with those laws? 
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; speculation. 
THE WITNESS: You're assuming that there's 
quilt. 
BY MR. EDWARDS: 
Q. 
No. I'm saying, hypothetically, if you were 
convinced that Jeffrey Epstein was guilty of those acts 
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