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FBI VOL00009

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Larry Eugene Morrison - Volume I 
October 6, 2009 
81 
1 
Q. Because later I'm going to show you some 
2 
lists, and certain people are listed by full name and 
3 
doers ere listed generically • any Idea why that would 
4 
happen? 
A. Unless they just don't know who it Is, you 
6 
know, just a guess. I mean, you know, you don't want 
7 
to query somebody and give them the third degree if 
It's just a guest of the boss that's, you know, 
9 
riding along or something. 
10 
Q. Well, she asked you your name before your 
It 
deposition and you didn't consider that the third degree 
12 
by any means. right? 
13 
A. Right, but —
le 
MR. PIKE: Objection to form. 
15 
A. But you're approaching your employer's 
16 
guest. It would be like walking Into his house and 
17 
salting him, 'Who's siding at the dining room table?" 
18 
- in a way. See what I'm saying? It's just — You 
19 
have to maintain 
20 
0. But — 
21 
A. 
— the employee/employer relationship. 
22 
Q. No, no, no. I guess what I'm saying is: If 
23 
one of these people is Mohammed Ma. you would like to 
24 
know it, probably. 
25 
A. Well, yes. 
83 
1 
A. It would be obvious that these are 
2 
associates of some form, that they're not, you know, 
3 
strangers trying to board the airplane. 
4 
Q. So let's go back to that conversation that you 
s 
have In the Oh lo hangar. or whatever it is, with David 
6 
Rodgers and Larry Visoski when they talked to you for the 
7 
first time about possibly switching over to Mr. Epstein. 
A. Uh•huh. 
9 
0. How does that conversation really go about? 
to 
MR. PIKE: Form. 
11 
A. I don't understand. What do you mean, 
12 
"How (*Ingo about? 
13 
0. Did you approach them and say, "Hey, are you 
14 
going to stay here (OMAN with this airplane? or "DO 
15 
you have another job for me? or what? 
16 
A. I think it was just, you know, I believe 
17 
Larry approached me. I can't remember. II was that 
18 
long ago. but — 
le 
Q. What does Larry say to you? 
20 
A. I can't remember the exact conversation. 
21 
Q. I mean, was he not happy where he was? 
22 
A. Who, Larry? 
23 
Q. Yes. 
24 
A. Never said he wasn't. 
25 
0. How did you know Larry? 
82 
1 
MR. PIKE: Form. 
2 
A. Yes, yet 
3 
Q. So any reason why a captain trying to secure 
4 
the airplane and the people aboard wouldn't take that 
5 
extra step and try to figure out who's exactly on his 
6 
airplane? 
A. Well, when it's - the normal passenger 
8 
loads are five to ten people, al the very most, and 
9 
they're all with the owner and accompanying the owner 
10 
and some of the regular passengers, you know; the 
11 
likelihood that Mohammed Ma is going to sneak in 
12 
there and board his plane and ride along is - you 
13 
know. 
14 
0. He's willing to play those odds, okay. 
15 
A. Well, I'm not saying that he's playing 
16 
odds. rm just stating that the only reason I can 
17 
think — I don't know. hie never filed those out. 
is 
The only reason I can think is he just didn't have 
19 
the name and didn't want to intrude and ask. 
20 
a 
If you were a captain, would you ask who was 
21 
on your airplane? 
22 
A. Not if the situation was that It was 
23 
controlled by the owner and I knew wto the - you 
24 
know. 
25 
Q. Okay. 
84 
1 
A. What are you talking about? Why would he 
2 
not be happy where he was? I don't triderstand. 
3 
0. Well, he's working for some other corporation 
4 
that's not non-Epstein owned. 
5 
A. Oh, that previous corporation sold the 
6 
airplane. 
7 
0. Oh, they thd? 
8 
A. Yeah. He had no choice. They were out of 
9 
wak. 
10 
Q So Larry and David were about to be out of 
11 
work. 
12 
A. Yes. 
13 
Q. So they said, 1-ley, we found a new job and 
14 
it's with this guy Jeffrey Epstein and he's buying that 
15 
plane. Do you want to be Involved?" 
16 
A. No, no. There was another airplane in 
17 
between - two other airplanes. There was a long time 
18 
between - and I don't know the exact dates and I 
19 
don't know that I even do know the dates - but there 
20 
was a time between when they left Gunther before 
21 
Jeffrey got involved with the 727. 
22 
Q. So they leave Glimcher? 
23 
A. Yes. 
24 
0. Then what happens? 
25 
A. They somehow - I don't know how - hired on 
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Larry Eugene Morrison - Volume I 
October 6, 2009 
85 
1 
with Jeffrey. 
2 
Q. They hired on with Jeffrey to pilot the 727? 
3 
A. No. He had two other airplanes prior to 
4 
that He had a Hawker that he had for a very short 
5 
period and then he bought - traded It or sold It. I 
6 
don't know what he did with it but then he got the 
7 
Guffstream. 
0 
Q. So Larry Visoski and David Rodgers were pilots 
9 
for Jeffrey Epstein when he had the Hawker also? 
10 
A. Yes. 
11 
O. And what year are we talking about there? 
12 
A. I have no idea. 
13 
Q. Well, if you sign on with him in '91. ifs 
14 
before that year, right? 
15 
A. No, no, I signed in '01 - January '01. 
16 
O. '01. 
17 
A. I don't know how long they flew for 
18 
Clincher before that airplane went away and how quick 
19 
they got on with Jeffrey. I don't know. Somewhere 
20 
between '88 and 2001. they —
21 
Q. During — 
23 
A. 
— left GlImther and —
23 
Q. During '88 and '01, do you remain in contact 
24 
with Lacy Visoski and David Rodgers? 
25 
A. On and off. They eventually moved, you 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
35 
87 
O. Before your conversation with them abe. • 
becoming involved with Jeffrey Epstein. 
A. Yes. 
O. How? 
A. Like we discussed. We've been through 
this already. When they were at Oftener they had an 
airplane in the hangar. We would see them 
sporadically and we would talk. 
O. I'm sorry. bad question. I don't mean on a 
business relationship. On a social relationship, did yot., 
hang out with them 
A. Oh, no. 
O. 
outside of this? 
A. No, no. 
Q. I apologize. 
So - and I only asked that question because 
some years later then you're in contact with them and 
they asked you to become involved with Jeff Epstein. 
A. Uh-huh. 
Q. But that is because of a business relationship 
solely that you had with them --
A. Oh, yeah. 
Q. 
— years before? 
A. I didn't know them personally. 
MR. PIKE: Form. 
86 
1 
know, to - moved away from Columbus when they hired 
2 
on with Jeffrey, so they weren't in the hangar every 
3 
day. 
4 
a. Where did they go- do you know? 
5 
A I think Dave went to New York and Larry 
6 
went back to South Florida. 
7 
Q. Do you know why? 
8 
A. Well, because I think Jeffrey gave them 
9 
the choice of flying where they would like, I 
10 
beEeve. I mean, that's — 
11 
Q. Thais what they've said. 
1.2 
A There what they've saki. 
13 
Q. Okay, and Larry chose South Florida, David 
14 
Rodgers those New York? 
15 
A. Right 
16 
Q. And Epstein had a place for them both wherever 
17 
they wanted to go? 
18 
A. Well, they owned their oven homes or 
19 
something. I don't know what their living 
20 
arrangements were. 
21 
Q. Did you know Larry Rodgers or David Visoski 
22 
before this? 
23 
A. Before? 
24 
MR. F1KE: Form. 
25 
BY MR. EDWARDS: 
1 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
88 
BY MR. EDWARDS; 
O. Okay. Alight So in 2001, is that the year 
that you get a telephone call from one or two of these 
people? 
MR. PIKE: Form. 
A It would be either late 2000 or early 
2001. I don't — These transactions don't happen 
overnight --
O. Yeah. 
• 
— buying an airplane. So it could have 
happened in, you know, November or started talking in 
November, late, "Well, you know, would you be 
Interested if Jeffrey gets the airplane or buys the 
airplane?" you know, to when I actually hired on. 
O. Did you ever talk to Ghistaine Maxwell - ever? 
A. After I had hired on, yes. 
O. After you hired on with Epstein. 
A. Yes. 
O. Wel go up to her. 
So when is it that you hired on with Jeffrey 
Epstein? 
A. I think I began in January of '01. 
O. In January of '01, do you start getting a 
paycheck from Jeffrey Epstein? 
A Yes. 
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Larry Eugene Morrison - Volume I 
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1 
Q. And is it paid from one of his companies or 
2 
from Jeffrey Epstein specifically? 
3 
A No, no - JEGE. 
4 
Q. JEGE. What is your understanding as to what 
5 
that Is? 
6 
A. It's just initials. It's a name. I don't 
7 
have any idea what it stands for, but rd ask that a 
B 
million times. 
9 
Q. 
ICs a company that owns something, right? 
10 
A. I don't know — 
11 
MR. PIKE: Form. 
12 
A. 
— if it even owns anything. I don't know 
13 
what type of company it is. I don't know If — It's 
14 
Just a Wilmington. Delaware. Company. 
15 
Q. What's the bank actors* that it was written 
16 
on? 
17 
A I can't remember. I mean, I know rd read 
18 
- rd See aJEGEn on it, that's all. 
19 
Q. A New Mexico bank, New York bank, Florida 
20 
bank? 
21 
A I have no idea because it's direct 
22 
deposit. All I would do is Just see if the ainaunte 
23 
right I don't — I have no idea. I would — I have 
24 
no idea. 
25 
Q. What was your communication - direct 
91 
1 
perform 
2 
Q. On what planes? 
3 
A. Just the Gulf - just the Boeing. 
4 
Q. Just the Boeing? 
5 
A. Uh-huh. 
6 
Q. Over the years. did you become aware that ho 
7 
owned other aircraft? 
A. I knew that he stil had that. 
9 
MR. PEE: Form. 
10 
A. He still had the Gulfstream. 
11 
Q. At the time back in 2001 and we're going to 
12 
walk through some of his airplanes • he owned the Boernr. 
13 
727, right? 
14 
A. Cared. 
is 
O. And what other airplanes did he own at that 
16 
time when you signed on with hlin in 2001? 
17 
A. The Guifstream. 
18 
O. Gulfstream is what? 
19 
A. 28. 
20 
Q. Do you know who the pilot was for that plane? 
21 
A_ 
Dave and Larry, I mean, it's always. 
22 
Q. Was K always Dave and tarry no matter what 
23 
plane was being taken out? 
24 
A. Unless somebody was on vacation or in 
25 
school and they used contract people. 
90 
1 
communication with Jeffrey Epstein that results in your 
2 
employment with JEGE? 
3 
MR. PIKE: Form. 
4 
A. A conversation result in my — Essentially 
5 
Larry hired rne. I mean, it wasn't - It wasn't — I 
6 
didn't really — I may have had one phone 
7 
conversation with Jeffrey prior to actually being 
8 
hired and the next time I saw Jeffrey was when I was 
9 
In Florida with the airplane. 
10 
Q. What did Jeffrey ask you in that one phone 
11 
conversation? 
12 
A. I think he asked me what my current salary 
13 
was, or something along that line, you know. 
14 
0. Did he ask you what you were looking for In 
15 
terms of Salary? 
16 
A. Yes. 
17 
Q. What did you tell him? 
18 
A. I told him to basically — I forget how it 
19 
went exactly. It ended up being like $117,000. 
20 
something like that. 
21 
Q. $117,000 a year? 
22 
A. Yeah. 
23 
O. And what were your duties? 
24 
A. Basically - flight engineer, obviously, 
25 
but all line maintenance and scheduled maintenance to 
92 
1 
Q. What was the purpose behind having multiple 
2 
planes - used one for the purpose, one for another - do 
3 
you know? 
4 
A. I never could figure that out. 
5 
Q. Really? 
6 
A. 
Yeah. 
7 
Q. No rhyme or reason why he took one this way 
8 
and one that way? 
9 
A. No. He was - pretty mudi once the Boeing 
10 
got on fine. Now, you know, the Boeing goes down for 
11 
heavy maintenance. It used to go annually, now It 
12 
goes down bi-annually, but - so he would utilize that 
13 
airplane while it was out of service, you know, for 
14 
maintenance. which sometimes would be four, five 
15 
weeks at a time, so. 
16 
Q. And in those cases, then he would use the 
17 
Gulfstream 29? 
1$ 
A. Yes. 
19 
Q. Have you been on both planes? 
20 
A. Yes. 
21 
Q. We're still talking about 2001. Is that the 
22 
first time that you're on the 727? 
23 
A. First time l was on the 727? Wait. I 
24 
don't know what you mean. 
25 
Q. After Epstein owns N. 
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Larry Eugene Morrison - Volume I 
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1 
A. 
Yes. 
2 
Q. And do you remember where you went? 
3 
A. Very first flight, no, because we didn't 
4 
fly it imrnedetely. We upgraded some avionics and 
s 
did modifications. 
6 
O. What modifications did he want to that plane? 
7 
A. Just changed the carpet and some fabrics, 
8 
upgraded the radar, upgraded the navigation - the 
9 
flight manifest systems. 
10 
Q. Did he change the interior at all? 
11 
A. No. We removed that one smell table and 
12 
chair - that's it, but we did not really change what 
13 
you would consider the ROCK plan. 
14 
0. Now, try to give me a visual appreciation of 
15 
the inside of the plane. If I'm looking out the cockpit 
16 
back towards the back of the plane; what am I going to 
17 
see? 
18 
A. A door. 
19 
Q. That's it? 
20 
A. That's it, yeah. 
21 
Q. Just an empty room with a door? 
22 
A. No, no. The door's always dosed. If the 
23 
door's open you will see the forward salon, and in 
24 
the forward salon there is a conference table, a 
25 
high/low table, some divans, and some single seats. 
95 
1 
A. Can't remember the first flight. Like 
2 
say, It was down fora white - probably - I tNnk if 
3 
was • had to take at least three to fotr months maybe 
4 
to get it — 
Q. And dud you know of him flying on the airplane 
6 
with girls accompanying him? 
7 
MR. PIKE: Form. 
a 
A. I don't --
9 
0. Back in 2001. 
10 
A. With gids accompanying him? 
11 
Q. Yes. 
12 
A. Yes. 
13 
O. Where would he pick the girls up from? 
14 
MR. PIKE: Form. 
15 
A. I don't know. They would arrive with him, 
16 
you know, out of Palm Beach or out of New York. I 
17 
don't even remember where we went the frst time. 
18 
The first flight was probably New York I think. 
19 
O. 
IS it a private airport in New York where you 
2o 
would usually pull into or a commercial airport? 
21 
A. I thirk the first time we started going up 
22 
there, I think, we were using White Plains, which Is 
23 
- actually, It's not a private airport. They ail 
24 
have some commercial service. It would have been 
25 
White Plains. I believe, then later we started using 
94 
1 
O. What's behind that? 
2 
A. The galley. 
3 
O. 
The what? 
A. 
The kitchen - galley. 
5 
O. Okay. 
6 
A. Behind that is the aft salon, which is 
7 
just two round divans. 
Q. And? 
9 
A. After that is the office. which Is a • 
10 
consists of a credenza and a desk, or divan and a 
11 
desk and chairs. 
12 
O. How many of these areas can you close off or 
13 
partition? 
14 
MR. PIKE: Form. 
15 
A. Each one. And after that there's the 
16 
state room. 
17 
Q. And in the state roorn • how big is the state 
18 
room? 
19 
A. Consists of a queen size bed and two 
z o 
single seats. 
21 
Q. Have you ever been back in the state room? 
22 
A. Oh. yes. Yeah. 
23 
O. 
When's the first time you flew on the airplane 
24 
with Jeffrey Epstein back in 2001, after he acquired the 
25 
727? 
96 
I 
Kennedy, and the service was so terrible in Kennedy 
2 
and so expensive we went to Newark. 
3 
Q. When you would fly Into White Plains or lo 
4 
Kennedy or Newark, would you always get off of the 
5 
airplane or would you sometimes stay on and watt for 
passengers to board? 
7 
A. I don't understand. 
8 
Q. Well, when you stop an airplane --
9 
A, Right. 
10 
O. 
— sometimes you get off the airplane and you 
11 
go either through a, you know, through the airport or you 
12 
go somewhere else, or your option Is to stay on the 
13 
airplane and not get off and wait for other people to get 
14 
on before you take off. 
15 
A. Oh, no. 
16 
MR. REINHART: I'm sorry, can we clarify 
17 
the "you"? Do you mean him personally or the 
18 
people who were passengers on the plane that he 
19 
was flying? 
20 
O. I'm talking about you personalty. 
21 
A. Oh, no, it was rare that we ever did a 
22 
through flight We would normally go from Point A to 
23 
Point B, and that was the destination. 
24 
Q. I assume when he teys the plane initially it 
25 
was In Ohlo, right? 
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1 
A. Well, yeah, but --
2 
Q. Then you fly to Florida. 
3 
A. Well, we crewed it to Florida and then it 
4 
sat at a facility in Florida during negotiations, so 
5 
it cidn't go directly from Ohio. 
6 
O. In 2001, when there's still negotiations. 
7 
where in Florida is the airplane? 
8 
A. Lake City - Timco, Lake City. 
9 
O. During the negotiations, does it ever take off 
10 
or is it grounded? 
11 
A. No, no, It's grounded, because on a Part 
12 
91 deviation it has to be under a specific 
13 
maintenance program, so when it left The Limited, it 
14 
left that maintenance program, and I had to 
15 
transition it to the new program. 
16 
O. This is still sometime in 2001, right? 
17 
A. Early, yes, yes. 
18 
O. And then it passes all inspections, I'm 
19 
assuming? 
20 
A. Right, right. 
21 
O. Then you take it to what airport to where 
22 
It — 
23 
A. PSI. 
24 
Q. PBS? 
z5 
A. Here In West Palm. 
99 
1 
O. Who's on the airplane? 
2 
A. Well, obviously It would be Jeffrey. 
3 
O. Right. 
4 
A. I can't remember who all went. 
O. Who were the pilots? 
6 
A. I can't remember that either. 
7 
a 
Larry? 
A. No. 
9 
MR. REINHART: Hold on. 
10 
A It would have been myself, for sure - 
it 
because I was the only one with experience on the 
12 
airplane - myself, Dave. I believe, would have been 
13 
captain because he had been schooled, but I can't 
14 
remember if Larry took first flight a not. I think 
is 
he was still In training. 
16 
O. Where did you go? 
17 
A. I cant remember. 
Is 
MR. PIKE: Form 
19 
A. I can't remember If it was New York or --
20 
I would imagine it would be New York. but I can't 
21 
remember. 
22 
O. When you say you would Imagine New York, I'm 
23 
getfing the impression that many of the flights went to 
24 
and from New York. 
25 
A. Yeah, pdmarlty. 
98 
1 
O. While it's at PBI airport, does it take off 
2 
from there? 
3 
A. No, not for — That's when we were doing 
4 
the modifications and upgrades. We were doing the 
avionIcs. 
6 
O. How long dkl that take? 
7 
A. I don't remember the exact time - maybe 
a 
three to four months. 
9 
O. Who does It with you? 
10 
A. Jet Aviation. Jet aviation did the 
ii 
avionics and soft goods. 
12 
Q. And when you say the "soft goods," what do you 
13 
mean by that? 
14 
A. Carpet, fabrics, leather, you know, 
15 
different things like that. 
16 
O. When's the first time It takes off then on a 
17 
real flight - some time In 2001, but mid-year or 
1e 
something? 
19 
A. Probably mid-year, maybe a little earlier 
20 
than mid-year. 
21 
O. We're talking about June of 2001? 
22 
A. Right. 
23 
O. And where do you go? 
24 
A. Can't remember. I can't remember for 
25 
sure. 
100 
1 
O. Solt — 
a 
A. And —
3 
O. So any time you're having to guess where it's 
4 
gang, you're saying New York because that's the primary 
5 
place It's going. 
6 
A. Correct. I would have remembered — I --
7 
I know I didn't get — I had heard about St. Thomas. 
a 
but I hadn't been there right away. I didn't get to 
9 
go to SL Thomas for a while. 
10 
O. Thars later on in the story. 
11 
A. Yes. 
12 
O. We'll get there. 
13 
So you go to New York. Does he tell you the 
14 
purpose behind going to New York? 
is 
A. No. 
16 
O. Prior to this trip to New York, have you had a 
17 
personal conversation with Jeffrey Epstein? 
18 
A. No. 
19 
MR. PIKE: Form. 
20 
BY MR. EDWARDS: 
21 
O. Never? 
22 
A. Not personal. Everything Is 
23 
business-related. 
24 
O. Okay. but — 
A. I mean, It was about the intedcv work or 
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Larry Eugene Morrison - Volume
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1 
the avionics going in, but never personal. 
2 
a 
But, I mean, you've been hired by him —
3 
A. Right. 
4 
a 
- you agreed on a scary, he's going to pay 
5 
you the salary, but other than that, and what maintenance 
6 
may be required --
7 
A. Correct. 
a 
Q. 
on the airplane, nothing else? 
9 
A. He's a very -- His conversations are 
10 
usually very short. He doesn't, you know, take much 
11 
Urns. 
12 
Q. When you would have conversations with him. 
13 
would they be over the telephone or would they be in 
14 
person? 
15 
A. It could ben both. If he was in Florida 
16 
and I wanted to actually show him a fabric or a 
17 
sample for the airplane or he wanted to view how it 
18 
was coming, but oftentimes it would be via telephone 
1.9 
from New York. 
20 
O. When it would ben person, would you see him 
21 
surrounded by or be accompanied by a girl or girls? 
22 
MR. PIKE: Form. 
23 
A. At times. yeah. 
24 
O. Would any of those girls be GNslaine Maxwell? 
25 
A. At times, yes. 
103 
1 
know, business relationship too. 
2 
Q. Did you know who Ghistaine Maxwell was? 
3 
A. Not right away, no, no. 
4 
Q. Not right away? 
5 
A. Right 
6 
O. At some point in time you were curious enough 
7 
to make an attempt to find out. 
A. No, I --
9 
MR. PIKE: Form. 
10 
A. 
— heard about her and there was a book up 
11 
In New York In the apartment that we stayed in that 
12 
was — You know. you're sitting there with nothing to 
13 
do, I read that. 
14 
O. Do you remember the name of the book? 
15 
A. It was jusrMaxwell.' 
16 
Q. Have anything to do with her father? 
17 
A. Yeah, It was about him, that's what it was 
18 
about. I mostly just flipped through looking at 
19 
pictures, boats, and airplanes and stuff. 
20 
O. Back in 20O1, the first time you had a real 
21 
conversation with Ghislaine Maxwell —
32 
MR. PIKE: Form. 
23 
A. Yes. 
24 
Q. 
— what did that conveMation consist of, if 
25 
you remember? 
102 
1 
O. Would any of thoso girls look extremely young 
2 
to you? 
3 
MR. PIKE: Form. 
4 
A. Not — Not that I thought. 
Q. Not back in 2001, were taking about? 
6 
A. Right, right 
7 
Q. No. 
What would Ghistaine Maxwell say to you, if 
anything? 
10 
MR. PIKE: Form. 
11 
A. She'd — Mostly small talk. just — She 
12 
kind of did the business management part of it as far 
13 
as, you know, arranging cell phone - I was having 
14 
cell phone problems with the company cell phone, she 
15 
would handle things Ike that. but she would have 
16 
minor Inputs on the interior work. 
17 
O. What was your understanding back In 2001 sill 
18 
of the relationship between Ghislaine Maxwell and Jeffrey 
19 
Epstein? 
20 
MR. PIKE: Form. 
21 
A. I really didn't understand it. I thought 
22 
It was personal - personal and business. 
23 
O. When you say 'personal,' did you think it was 
24 
sexual? 
25 
A. I thought maybe they were dating and, you 
104 
1 
A. I think it was concerning getting a cc 
2 
phone and a pager - that's it. 
3 
Q. Did It have anything to do with underage 
4 
girls? 
5 
A. Absolutely not, no, no. 
6 
Q. That's not something she ever shared with you' 
7 
A. No, no. 
8 
Q. Oki Jeffrey Epstein ever share with you that 
9 
he wanted underage girt —
10 
A. No. 
11. 
Q. 
—In any way? 
12 
A. No. 
13 
MR. PIKE: Form. 
14 
BY MR. EDWARDS: 
15 
O. I mean, certainly I'm not saying something to 
16 
you that's an absolute shocker right now —
17 
A. Right. 
10 
O. - considering the newspaper articles. 
19 
A. Right, but I know — You have to 
20 
understand, every conversation I had was pretty much 
21 
business, just to deal with the airplanes. You know, 
22 
I'm an employee/employer relationship. 
23 
O. I just don't want you to think I'm just asking 
24 
random off the wal questions —
25 
A. Right. 
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Larry Eugene Morrison - Volume I 
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105 
1 
O. 
— that have nothing to do with anything. 
2 
A. I understand. 
3 
O. 2001, you start working for him, and that Juno 
4 
or so is the first flight, and you believe its to New 
S 
York. 
6 
A. Correct. 
7 
O. Do you remember the purpose behind the flight? 
A. No, did not know the purpose. 
O. Did you get off the airplane in New York? 
10 
A Yes. yes. 
11 
O. Where dld you go? 
12 
A. Probably to- into the d4,. into the 
13 
city, and he has an apartment building up there that 
14 
we would stay in In the dty. 
15 
O. Is it paid for by Jeffrey Epstein? 
16 
A. What? 
17 
MR. PIKE: Form. 
18 
BY MR. EDWARDS: 
19 
Q. The apartment. 
20 
A. Well, he -- ICS -- I think it's in the 
21 
building he owns. I mean, I just — I don't know. 
22 
O. Do 
remember the address? 
23 
A. 
24 
Q. 
, right? 
25 
A. Right 
107 
1 
building. rve been to the building. The building is 
2 
huge. 
3 
A. I don't know. I don't know if ho owns the 
4 
budding or just - or how many units he's got Maybe 
5 
ten, because I think some of the employees up there 
6 
live in them. 
7 
Q. Do you remember who some of the other 
employees are that live in that building? 
9 
A. Well, I think Darren used to live in it, 
:o 
Darren Indyke. 
1 
Q. Darren In 
r ht. 
12
What about 
do you remember her? 
I 
13 
A. 
I
M
 
lived inn
14 
O. What about 
15 
A. I don't know if 
Eyed in there or 
16 
net 
17 
O. You know who that is. though. 
18 
A. Right, right Actually, she was Just kind 
19 
of coming Into the picture when I was - about the 
20 
time when I was leaving. 
21 
Q. What about Ghistaine Maxwell? 
22 
A. No, no, she didn't live there. 
23 
O. What about Jean Luc Brunel? 
24 
A No. 
25 
G. How about Did Mark Epstein ever indicate to 
106 
1 
O. Did he ever mention a brother that he may have 
2 
to yOU? 
3 
A. I met his brother, I think, once. 
4 
O. What's his name? 
A. I cant remember. 
6 
Q. Mark? 
7 
A. I remember meeting. 
8 
Q. Mark Epstein strike —
9 
A. Honestly, I can't say for sure. 
10 
O. And how do you know that Jeffrey Epstein owns 
11 
the apartment budding at 
12 
A. Larry told me. I mean, It was just kind 
13 
of known. 
14 
G. Lany told you —
15 
A. Yeah. 
16 
Q. 
— or Jeffrey told you? 
17 
A. Oh, no, not Jeffrey, no. Larry. I 
le 
wouldn't have asked Jeffrey. 
19 
O. How many of those apartments up there In New 
20 
York is it your understanding that Jeffrey owns? 
21 
MR. REINHART: I'm sorry, are you asking 
22 
how many units are in the building or how many 
23 
buildings? 
24 
BY MR. EDWARDS: 
25 
O. No, how many units that Jeffrey owns in the 
108 
1 
you that he had any ownership in any of that? 
2 
A. Oh, no. I only saw him one time on a 
3 
short flight. I don't even know where we - we were 
4 
probably taking him to and he was just - Jeffrey 
5 
introduced him as his brother and it was very short, 
6 
you know, Just, "Oh, hi. How are you?", and he went 
7 
in the back. 
8 
O. Do you know anything about the guy? 
9 
A. Ini-uh. 
10 
Q. Nothing? 
11 
A. Nothing. 
12 
Q. So in 2001. there's a flight up there at some 
13 
appointment in time, and you 
toff and 
stay at one 
14 
of the apartment buildings at 
15 
A. Right, right. 
16 
Q. And did you meet any of the neighbors of the 
17 
apartments that are also owned by Jeffrey Epstein? 
18 
A. No, no, because when we're there Ifs 
19 
usually just for a night or something and then. you 
20 
know, we're either airtining home or going on, 
21 
O. How did you know Darren Indyke? 
22 
A. He's our — He's our business attorney for 
23 
JEGE. 
24 
Q. Do you renwrirbur an of the other tenants of 
25 
the apartments at 
other than Darren 
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Larry Eugene Morrison - Volume I 
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1 
109 
Indyke and MOM? 
2 
A. Not that I remember, no. 
3 
0. How about Leslie Groff? 
4 
A. I don't think Leslie lived there. 
5 
Q. Do you remember that name? 
6 
A. Yes. She's Mr. Epsteires secretary. 
7 
Q. What about 
A. 
no, I don't think so. 
9 
Q. Jeff Fuller? 
to 
A. I dont know Jeff Fuller. I don't even 
11 
know Jeff Fuller. 
12 
0. Do you know the name Jean Luc Brunel? 
13 
A. Yes. 
14 
0. How do you know that name? 
25 
A. He% been— He was a passenger on a few 
16 
of our flights. 
17 
0. Do you know why? 
18 
A. I Mink he was — I don't know for sure. 
19 
He's In a modeling business with Mr. Epstein, I 
20 
believe. 
21 
Q. MC2? Do you know that name - MC2 Modeling 
22 
Agency - used to be Karin Modeling Agency, now its MC2? 
23 
A. No. 
24 
a 
How do you know about his and Mr. Epstein's 
n 
modeling agency? How do you know that? 
1 
2 
3 
4 
5 
6 
7 
B
10 
11 
12 
13 
1.4 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
111 
of the MC2 shoots? 
A. I never heard — There was one Incident —
The only thing I remember about it is they were on a 
shoot and it's not funny. but Jeff - but it is in a 
way- they were In a motor home on location at the 
shod, and they started to drive off and one of the 
models asked to use the restroom and they told her 
which door it was and she went out the side door. so 
grabbed the wrong door, but that's actually the only 
thing that sticks in mind - was that one. 
O. Have you ever done any research on Jean Luc 
Bruner? 
A. No. 
O. Do you have any idea that ho's known 
throughout Europe as somebody who has sex with urde race 
girls? 
A. No. 
Q. You didn't know that at right now? 
A. Coned. 
0. That's something that you're !earring as a 
surpise to you. 
A. Yes. 
0. So-- 
somebody you never heard 
of? 
A. It sounds familiar I'm eying to place 
110 
1 
A. Just even/ once in e while he would say 
2 
something about, you 'mow, one of the model sheets a 
3 
something. We normally had him on - we would take 
4 
him badt and forth to Paris. 
Q. Where some of their models come from? 
6 
A. I don't know. 
7 
0. Did you ever bring some of the Paris models 
a 
back? 
9 
A. Not that I'm aware of. no. 
10 
MR. PIKE: Form. 
11 
BY MR EDWARDS: 
12 
0. So he would go to Pans on the airplane. Jean 
13 
Luc, would you drop him off there or would you pick 
14 
people up and bring them back? 
15 
A. If I remember. normally we were bringing 
16 
Jean Luc from Pais to New York. if I remember. 
17 
G. And when you say that the modeling agency • 
113 
obvious!), that. you know, between him and Mr. Epstein -
19 
is that something that Mr. Epstein would talk to you 
20 
about or is that something that Joan Luc would talk to 
21 
you about or you would just overhear the two? 
22 
A. Overhear the two. or Jean Luc may say 
23 
something about one of the shoots or something, just 
24 
in general conversation. 
2s 
Q. And what would Jeffrey's comment be about some 
112 
1 
her. I don't know if she works in the office or --
2 
Q. Or waked in the office? 
3 
A. Worked In the office, yeah. I very rarely 
4 
went to the office. I mean —
5
0. 
- how do you know her? 
6 
A. From the flights - being on the airplane. 
7 
Q. How many times was she on the airplane? 
8 
A. Quite a few. Almost every. 
9 
0. What's your understanding as to what she did 
10 
for Mr. Epstein? 
Ll 
A. Like a personal assistant 
12 
0. Personal assistant doing what? 
13 
A. Arrangements, meetings, berthing like, I 
14 
guess, personal affairs, you know. 
15 
Q. Did Mr. Epstein ever once mention to you that 
16 
he likes massages? 
17 
MR. PIKE: Form. 
18 
A. No, he never mentioned that to me. 
19 
Q. That's not something that you ever heard ol. 
20 
right? 
21 
A. Well, I --
22 
Q. I mean, outside of the articles that you've 
23 
read. 
24 
A. Right. No, but he never came up to me and 
25 
said," hke massages? 
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Larry Eugene Morrison - Volume I 
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113 
t. 
O. And did 
- did you hear her 
2 
organizing, scheduling, talking to people about either 
3 
what she may call "work" or 'Massages' for Epstein? 
4 
A. No, no, I don't. 
5 
MR. PIKE: Form. 
6 
BY MR. EDWARDS: 
7 
Q. What types of conversation. if you can 
8 
remember anything, did you ever overhear -
9 
talking about? 
10 
A. It would be mosey like transportation 
11 
arrangements - car needs. 
1.2 
O. Car needs for who? 
13 
A. Well. making sure that the driver in New 
14 
York was meeting the airplane at the proper time, 
15 
sluff like that, or if they had an unusual large 
16 
amount of baggage, to make sure that another car was 
17 
hired to come pick this up, things like that -
18 
logistic-type stuff. 
19 
Q. We're still talking about a time period back 
zo 
In 2001. right, In these -
21 
A. No. 
- I don't remember 
comirg 
22 
Ink) the picture until later. 
23 
O. Later in 2000-something? 
24 
A. No, she wasn't around at first. 
25 
O. Alright 
114 
A. No. I don't remember when exactly= 
2 
but she - 
3 
Q. Who was maki
 arrangements for meetings 
4 
and such prior to Ms. 
5 
A. Ms. Maxwell. 
6 
Q. 
— that you remember? 
7 
So Maxwell was the, for all intents and 
a 
purposes, the 
before 
existed? 
9 
A. For aN Intents and purposes, yes. 
10 
Q. And cfid you ever hear of Ms. Maxwell making 
11 
arrangements for massages or for girls or anything else? 
12 
A. No. 
13 
MR. PIKE: Form. 
14 
BY MR. EDWARDS: 
15 
O. Where were the conversations - whether it was 
16 
travel or whatever else - that was occurring between 
17 
Maxwell and/or 
? Where were they taking 
18 
place - on the airplane, some office? 
19 
A. Yeah. No, no, usually in the cockpit, you 
20 
know, prior to departure, en route staling, "We've 
21 
got this many cars and !Ye contacted" or Tan you 
22 
ea such and such to have this brought out? 
23 
Q. Did you ever see Epstein work a lot? 
24 
MR. PIKE: Form. 
25 
A. He always had a briefcase with him and he 
115 
1 
always sat it by his office in the back. 
2 
Q. Always had a computer? 
3 
A. No, no, it's just a large briefcase. 
4 
Q. Did you ever know his e-mail? 
5 
A. Yeah, I had It - I can't remember what it 
6 
was and I don't think ifs even current - but when I 
7 
would have to send him e-mails about the interior or 
El 
maintenance Issues. It was jeprojects, or something 
9 
like that, at — 'don't know if it was at Yahoo or 
10 
gmail. I don't think it was gmail. 
11 
Q. You think it was jeprojects? 
12 
A. I believe so, but I can't remember what 
13 
seMce. 
14 
O. At gmall.com or something? 
15 
A. Or something like that or Yahoo or 
16 
something. 
17 
Q. How about Ms. Maxwell? 
18 
A. It was g - gMaxl@mindspring.com, I think. 
19 
Q. Do you know if that's still current? 
20 
A. No, I don't. 
21 
Q. How about =1=7 
22 
A. I had it at one time and I know she 
23 
changed it and I don't know what it is. 1 can't 
24 
remember what it was. actual) . 
25 
O. Do you know
 
-where 
where she is 
116 
1 
right now? 
2 
A. No. 
3 
O. Do you know if she's intentionally on the lam 
4 
Why to avoid being deposed in this case? 
5 
A. No. 
6 
MR. PIKE: Form. 
7 
A. No idea. I haven't had any contact with 
8 
MI 
since I stoppeda. 
9 
O. You say that 
waS Just COMing in the 
10 
picture - is the words that you used. What did you mean 
11 
by this? 
12 
A. Well, I mean she was Just — I'm hying to 
13 
remember when I first started seeing her on the 
14 
airplane. I think It was not too long before I quit 
15 
tying. I can't remember the exact dale. 
16 
Q. When did you stop flying? 
1.7 
A. In February of '07. 
IS 
Q. February '07? 
19 
A. Yep. 
20 
Q. And you don't think you saw her on the 
21 
airplane until before that? 
22 
A. No, I'm saying she was only coming into 
23 
the picture like maybe six months before that or so 
24 
or -1 don't know for sure. 
25 
Q. You don't remember seeing her On the airplane 
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Larry Eugene Morrison - Volume I 
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117 
1 
in 2001, 200Z 2003? 
2 
A Ott, no, not that early. 
3 
Q. Do you know where she came from? 
4 
A. Just what I've read In the paper - an 
5 
eastern country. I'm sorry, I don't remember the 
6 
coutry. 
7 
0. Were you ever told that Mr. Epstein bought her 
8 
from her famitywOen she was 14 years old to come over to 
9 
be his Yugoslavian sex slave - is that something that you 
10 
ever heard? 
11 
A. No. I did read something like that in the 
12 
paper, but, no. never heard of that. 
13 
a 
Did you ever see him and her sexually involved 
14 
on the airplane or othenwse? 
15 
A No. 
14 
Q. Did you ever see Epstein involved sexually 
17 
with anybody on the airplane? 
18 
A. No. 
19 
0. Did you ever see the airplane used for sexual 
20 
purposes? 
21 
A. No. 
22 
MR. PIKE: Form. 
23 
BY MR. EDWARDS: 
24 
0. tf it had happened - considering the various 
25 
areas that were cordoned off or blocked off - would that 
119 
1 
A. No. 
2 
0. - in the back of the airplane. 
3 
A. No. 
4 
Q. So anything could go on. You would have no 
s 
idea. 
6 
MR. PIKE: Form. 
7 
BY MR. EDWARDS: 
Q. You could sit here end testify truthfully. 1 
9 
have no clue what's going on back there." 
10 
A. That's correct. That's correct 
11. 
0. Darren Indyke -what's your understanding no 
12 
to his involvement with Mr. Epstein? 
13 
A An attorney for the company. 
14 
0. Ever met Nan Dershowitz? 
15 
A. I think — Yes. 
16 
0. How dkl you meet him? 
17 
A. Nan Dershowitz. I don't know if it was 
18 
Mr. Goldberger or Nan Dershowitz. We brought some 
19 
attorneys down —
20 
0. Why? 
21 
A. 
— to Florida one time. 
22 
0. Why? 
23 
A. For Mr. Epstein. It was right before I 
24 
finished flying. For Mr. Epstein to make an 
25 
appearance at the courthouse or a meeting or 
118 
1 
have even been something that you could have seen? 
2 
A. No, no, if it was - if the doors were 
3 
closed, no. 
4 
0. So there's a back room that you've described 
5 
that has a bed In it, and If that door's closed you don't 
6 
know what's going on behind closed doors. right? 
7 
A. That's correct. 
8 
MR. PIKE: Form. 
9 
BY MR. EDWARDS: 
10 
0. Do you remember a time Epstein was back in 
11 
that back room with other people? 
12 
MR. PIKE: Form. 
13 
A. NO. 
14 
Q. Are you saying it never happened while you 
15 
were on the airplane? 
16 
A 'really have no idea of knowing because, 
17 
one, we never go back there unless we're invited 
is 
back. 
19 
Q. Okay. 
20 
A. And the forward door - the very forward 
21 
salon door is closed, so we never even normally go 
22 
Into that •• 
13 
Q. So you don't really know --
24 
A. 
— without pertrission. 
25 
Q. You don't really know whet happens --
120 
1 
something, and we brought some attorneys with him. 
2 
0. And were you aware then of the allegations 
3 
against Mr. Epstein? 
4 
A. They wore starting to brew, yes. 
5 
Q. Were you still actively working on his payroll 
6 
at the time when the investigation was going on? 
7 
A. Yes, when it just started. 
8 
0. And did that Impact you In any way as to 
9 
whether or not you wanted to be affiliated with this 
10 
person? 
11 
A Subconsckausly, It may have. And it 
12 
wasn't because of this person, but as a business 
13 
decision, if, you know, an airplane's not needed and 
14 
I don't fly, I could be out of work. But, no, the 
15 
primary reason was the fact that I (lid want to get 
16 
off the road and back home. 
17 
0. Do you have children? 
18 
A Yes. 
19 
Q. How old? 
20 
A. A daughter 28, son 24, and a daughter 17 -
21 
all with the same bride - 31 years. 
22 
Q. I'm assuming you're aware or the factual 
23 
allegations in these complaints? 
24 
A Yes, yes. 
25 
Q. And you are aware that there are hundreds of 
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Larry Eugene Morrison - Volume I 
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121 
2 
girls who are underage who claim to have had sex with Mr. 
2 
Epstein as well as Ms. Maxwell at various times? 
3 
MR. PIKE: Form. 
4 
A. I was only aware of —First time I was 
s 
made aware of it, of the number of people, was when 
6 
they served me the subpoena. The deputies or 
7 
retired —
a 
Q. Yes. 
9 
A 
— private eyes told me that. That was 
10 
the &stilled heard a number. 
11 
Q. Were you completely oblivious that this was 
12 
going on? And by IliIC I ntean Epstein and/or Ghistalne 
13 
Maxwell andla 
recruiting 12. 13. 14. 
14 
15wew-old gels to Ns house for sex? 
15 
A. Absokrtely I was oblivious to it. 
16 
MR. PIKE: Form. 
1.7 
BY MR. EDWARDS: 
18 
Q. If young gds were on an airplane that yOu 
19 
were on - consider:iv that we've now established how the 
20 
airplane's set up and you're kind of cordoned off - is It 
21 
possible that underage girls would have been on the 
22 
airplane and you just wouldn't have known about It? 
23 
MR. PIKE: Form. 
24 
A. No, no. I mean, people don't board the 
25 
airplane with - you know, and then just say, "Close 
123 
1 
Q. Okay. I'll ask it a different way. 
2 
A. Because we have had -- You know, he's got 
3 
a goddaughter and godson that were young. I mean. 
4 
O. Okay. Over the years --
5 
A. I mean, I don't know what the purpose --
6 
Q. Right I totally understand what you're 
7 
saying. 
8 
Over the years, when you were on Jeffrey 
9 
Epstein's airplane, were you aware between 2001 and 
10 
wherever you stopped. 2007 —
ii 
A. Seven. 
12 
Q. 
— were you aware of girls that appeared very 
13 
underage on the airplane? 
14 
A. No, 
15 
MR. PIKE: Form. 
16 
BY MR. EDWARDS: 
17 
Q. rm not saying what was happening on the 
Is 
airplane. I'm just saying, were you aware of it? 
19 
A. No, not - unless they were there, like I 
30 
said, his goddaughter at the time. One time - a 
21 
couple times we flew her with her mom and dad where I 
22 
don't even know their age. 
23 
MR. PIKE: Again, form, asked and 
24 
answered. 
2s 
A. Six or seven. But, no, I was not aware of 
122 
1 
the door, we're going." You know, you see who boards 
2 
the airplane. 
3 
Q. So if there were flight records that show 
4 
underage girls on the airplane, you would know about it? 
5 
MR. PIKE: Form. 
6 
A. Not necessarily 
7 
Q. Well, how not? 
MR. REINHART: I'm sorry. 
9 
A. Well, how do you — 
10 
MR. REINHART: When you say "them? do you 
11 
mean he would know about the records a he would 
12 
know about the girls allegedly on the plane? 
13 
BY MR. EDWARDS: 
14 
Q. You would know about the underage girls on the 
15 
airplane if they were on there. 
16 
MR. PIKE: Form. 
17 
A. How do you -- How would I know that 
18 
they're underage. though? 
19 
Q. Well, you would only know that they look 
20 
extremely young, right? 
21 
A. But — 
22 
MR. PIKE: Form. 
23 
A. 
— what is the Intent of them? I mean, 
24 
are they guests or are they friends of his associates 
25 
or — 
1 2 4 
1 
anybody that was obviously, blatantly underage. 
2 
Q. My famous people that you can tell me that 
3 
were on the airplane? 
4 
A. President Clinton - Ex-President Clinton.
5 
O. Were you on the airplane —
6 
A. Yes. 
7 
O. 
— when he was on it? 
a 
A. Yes. 
9 
O. How many times? 
10 
A. Two trips. I mean, two extended kips. 
11 
Q. Where did it go? 
12 
A. The first one - or the first one was Asia. 
13 
Q. What purpose? 
14 
A. I forget what the purpose was on that one. 
15 
Q. Was Jeffrey Epstein on the airplane as well? 
16 
A. Yes, yes. 
17 
Q. Who else was on the airplane then? 
18 
A. I don't remember on that one. It was 
19 
primarily him and his support staff. 
20 
Q. Was 
21 
A. Probably, yes, probably. 
22 
O. When's the next time President Clinton was on 
23 
his airplane? 
24 
A. I don't remember the date, but we did a 
25 
Africa trip, an AIDS awareness tour. We did like ten 
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1 
countries in 12 days. 
2 
Q. Is that a time Chris -fucker 
3 
A. 
Yes. 
4 
O. 
— and Kevin Spacey were also on it? 
5 
A. 
Yes. 
6 
Q. In addition to the people that we've named, 
7 
were there females on that airplane? 
A. 
Yes. 
9 
O. 
And who were the females that were on the 
10 
airplane? 
11 
A. 
Can't remember. Ms. Maxwell,-, I can 
12 
remember, and a couple others, and there's - Me. 
13 
Canton had - a couple of his support staff we 
14 
women also. 
15 
O. Where were you sitting during these trips? 
16 
A. Up front In the my station. 
17 
O. 
Could you see what they were doing where you 
18 
were? 
19 
A. No, no. 
20 
O. Could you tell if there was any sex going on 
21 
on the airplane welds you were on it? 
22 
A. No. 
23 
MR. PIKE: Form. 
24 
BY MR. EDWARDS: 
25 
O. Do you know of any underage girls being on 
127 
1 
MR. EDWARDS: No. I mean, unless 
2 
everybody wants to take a lunch break. 
3 
Everybody's shaking their heads, so. no, I'm 
4 
going to take a bathroom break, and k's going 
to be a fast one. 
6 
IF. PIKE: Okay. 
7 
BY MR. EDWARDS: 
O. In 2001. when you're on this flight to New 
9 
York and then during that year we talked a little bit 
10 
about it, is Larry Visoski and David Rodgers also on some 
11 
of these flights? 
12 
A. Most, yes. 
13 
0. If somebody's going to keep passenger logs, 
14 
whale going to write down the names of the people? Is 
15 
that going to be you or is that somebody else's 
16 
responsbeity? 
17 
A. Whoever is captain. 
18 
0. So normally It's Visoski or David Rodgers? 
19 
A. Correct. 
20 
Q. Who do you turn these logs into? 
31 
MR. PIKE: Form. 
22 
A, I don't know. I don't know where they go. 
23 
Q. You don't know the purpose behind keeping them 
24 
or anything? 
25 
A. No. 
126 
1 
that airplane or would you have been able to ter 
2 
A. No. 
3 
MR. REINHART: I'm Sony 
4 
MR. PIKE: Asked and answered. 
MR. REINHART: — are you limiting it to 
6 
that trip? 
7 
BY MR. EDWARDS: 
8 
O. To that trip. 
9 
A. No, rm not aware of it. 
10 
Q. If you had been aware of underage girls being 
11 
transported on the airplane for the purposes of sex, 
12 
would you have said something to somebody? 
13 
A. Yes. 
14 
MR. PIKE: Form. 
15 
MR. EDWARDS: Do you mind if we take a 
16 
five-minute break? I just have to run to the 
17 
bathroom. 
18 
MR. PIKE: Actually, Brad, Can you hear 
1.9 
me? 
20 
MR. EDWARDS: Yes. 
21 
MR. PIKE: How much longer do you 
22 
anticipate going with this witness? 
23 
MR. EDWARDS: Hour, maybe a Me longer. 
24 
MR. PIKE: Weir, are you going to take a 
25 
lunch break or what? 
128 
1 
Q. As far as you're concerned, you don't even 
2 
need to keep them. 
3 
A. Correct. Yeah. 
4 
O. As just due diligence - going above and 
5 
beyond? 
6 
A. Correct. 
7 
Q. Today you have an attomey sitting right next 
8 
to you, right? 
9 
A. Correct. 
10 
Q. Is that somebody that you've known for a long 
11 
lime? 
12 
A. No. 
13 
Q. You're paying for an attorney to sit here with 
14 
you? 
15 
A. No. 
16 
Q. Who's paying for your attorney? 
17 
A. Mr. Epstein. 
18 
O. Are you worried that you're criminally 
19 
involved here or something? Is that why you need an 
20 
attorney? 
21 
A. No. I don't even know anything about this 
22 
process, that's 
23 
0. Oh, okay. 
24 
A. rm just — You know. 
25 
Q. How did you know that you were - 
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1 
MR. PIKE Brad. Brad. Brad. 
2 
Q. 
— going to get an attorney — 
MR. REINHART: Brad, hold on. 
MR. PIKE: Whoa. Whoa. SW. 
s 
MR. EDWARDS: I'm listening. 
6 
MR. PIKE Brad. 
7 
MR. EDWARDS: Go. 
8 
MR. PIKE: You are not allowing the 
9 
witness to finish his statements throughout this 
10 
entire depo. Please. rm on the phone. You 
11 
start your question before the witness is 
12 
finished. rm sorry for raising my vice. but 
13 
you must allow the witness to finish his answer. 
14 
please. 
15 
MR. EDWARDS: You got it. 
16 
THE WITNESS: What was your question now? 
L7 
I forgot. 
18 
MR. EDWARDS: rm sitting here looking at 
19 
the witness and have a feeling we're going to be 
20 
sitting here for 30 minutes, but I will do that 
21 
for you, Mr. Pice. 
22 
MR. PIKE: Alright. 
23 
THE WITNESS: What was the question again, 
24 
please? 
25 
MR. EDWARDS: Can I ask the question again 
131 
1 
this case against Mr. Epstein? 
2 
MR. REINHART: Let me ask him not to 
3 
answer that. 
4 
MR. PIKE: Form. 
5 
MR. REINHART: It's privileged. 
6 
MR. EDWARDS: It's privileged between Mr. 
7 
Epstein and you, but is it privileged between 
a 
the two of you? 
9 
MR. REINHART: Between Mr. Morrison and 
10 
me. 
11 
BY MR. EDWARDS: 
12 
Q. Is it your understanding that he represents 
13 
you or he represents W. Epstein? 
14 
A. He represents me. 
15 
0. Okay. Do you think that you've done anything 
16 
wrong crkninally? 
17 
A. No. 
18 
Q. Do you think that you're being sued civilly? 
19 
A. No. 
20 
0. And you have no reason to be sued civilly, 
21 
22 
A. Correct. 
23 
0. Did you talk to Mr. Epstein prior to taking 
24 
your deposition today? 
25 
A. Oh, no. I haven't talked to him In well 
130 
1 
or wait? III wait for you. 
2 
MR. PIKE: If I'm ready. 
3 
MR. EDWARDS: I already asked the 
4 
question. so we're walling. 
MR. REINHART: I think the witness asked 
6 
you to repeat the question. 
7 
MR. EDWARDS: Are you good? Alright. 
8 
BY MR. EDWARDS: 
9 
Q. Who hired your attorney? 
10 
A. Mr. Epstein. 
11 
Q. And do you have any Idea why, it you're a 
12 
witness in a case - no problems criminally - why you 
13 
personally have an attorney paid for by Mr. Epstein to 
14 
sit here with you? 
15 
MR. PIKE: Form. 
16 
A. No, I don't 
17 
Q. 
Do you want an attorney to sit here with you 
18 
while I ask you questions? 
19 
MR. PIKE: Form. 
20 
A. I don't know what the proper protocol is. 
21 
Q. Okay. 
22 
A. I have very limited exposure to anything 
23 
like this. 
24 
Q. How did this come about to where you have an 
25 
attorney as a witness - completely Innocent witness - in 
132 
1 
over a year-and-a-half, maybe two years, and that was 
2 
Just a "hello- because I'm at the airplane one day. 
3 
Q. So how Is it you know that Mr. Epstein paid 
4 
for your attorney? 
5 
MR. REINHART: It's privieged. 
6 
MR. EDWARDS: Okay. That answers my 
7 
question. 
s 
BY MR. EDWARDS: 
9 
O. Have you ever met Donald Trump? 
10 
A. Yes. 
11 
Q. How? 
12 
A. 
He was -- He boarded the airplane one day 
13 
when ours was on the ramp. 
Q. And did you talk to him? 
is 
A. Just he introduced himself and I 
16 
introduced myself. 
17 
O. And did he talk to Mr. Epstein? 
18 
A. 
No. Mr. Epstein wasn't present. I was 
19 
doing maintenance. 
20 
Q. And did he fly on the plane? 
A. 
No. 
22 
Q. Not that time? 
23 
A. Never. 
24 
Q. You think he never flew on the plane? 
25 
A. On our akplane? 
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1 
O. Yes. 
2 
A. No. 
3 
Q. So if somebody has given testimony other than 
4 
that, you would say that person is mistaken or lying? 
5 
MR. PIKE: Form. 
A. Donald Trump was never on the airplane 
7 
when I was on the airplane. 
8 
Q. Is it your understanding that Donald Trump Is 
9 
friends with k6. Epstein? 
10 
A. From what I've read - or associates. I 
11 
don't know how that cirde works. 
12 
O. What's your understanding as to who Mr. 
13 
Epstein's real friends are? 
14 
A. I really don't know, I don't — I don't 
15 
know. It's — It's not like the Wexners where, you 
16 
know, they were high school associates, you know, 
17 
graving up. 
18 
Q. Do you know what Mr. Epstein did prior to 
19 
managing the money for Mr. Wexner? 
20 
A. Just that he was a Wall Street broker or 
21 
somebody, you know. 
22 
Q. Also from reading? 
23 
A. Yes, was. 
20 
Q. Do you know any personal knowledge as to wha 
25 
Mr. Epstein has told you about how he made money? 
135 
1 
A. I have no idea. I don't knout 
2 
O. When you say that 
was lust 
3 
in the picture, %thee your understanding as to 
4 
votxr 
is relative to Mr. Epstein? 
A. I dont know. I don't understand. I 
6 
daft lea 
I didn't know if maybe she was like an 
7 
exchange — Jeffrey always appeared to be very 
Involved In education and philanthropy. I didn't 
9 
know If she was an exchangetype student or soniu l ring 
10 
or what I don't know. 
11 
Q. When you say ho appeared to be "involved in," 
12 
what do you mean? 
13 
A. Educational things, foundations, sdence 
14 
foundations, and things. 
15 
Q. Speaking at - the Florida Science Foundation 
16 
Is a place where, when he was on work release, he spent a 
17 
kg of time there, you're aware of that? 
18 
A. That's what rve heard, yeah. 
19 
0. What does that place do? 
20 
A. I have no idea. 
21 
Q. Does k do anything? 
22 
A. I don't know. I don't know anything about 
23 
it. 
24 
25 
Q Certainly you've read certain newspaper 
articles about the allegations, police reports, 
134 
1 
A. He's never -
2 
MR. PIKE: I'm going to move to strike any 
3 
responses relative to what the witness has 
4 
learned from reading. 
5 
BY MR. EDWARDS: 
6 
0. And so that Is wily I asked the question: Has 
7 
Mr. Epstein told you? Which would have nothing to do 
s 
with reading. 
9 
A. No. 
10 
Q. How many conversations have you personally hat 
11 
with Mr. Epstein? 
12 
A. No personal conversations - all business. 
13 
Q. Have you witnessed Mr. Epstein with any girls 
14 
that look to be under the age of 18? 
15 
A. No. 
16 
Q. Have you witnessed Mr. Epstein with 
17 
young-looking girls that appear to be In their twenties? 
is 
MR. PIKE: Form. 
19 
A. Yes. 
20 
O. On how many occasions? 
21 
A. Probably several. 
22 
Q. And how did that come about? 
23 
A. I mean, they show up and ride on the 
24 
akplane, you know. 
25 
Q. And who we they, if you know? 
136 
1 
otherwise, the allegations that occurred or have been 
2 
alleged to have occurred at his Palen Beach mansion, 
3 
correct? 
4 
A. Uh-huh. 
5 
Q. Correct? 
6 
A. Correct. 
7 
O. Given the nature of those allegations, would 
8 
you leave your daughter of 17, 16, 15 years old with Mr. 
9 
Epstein alone? 
10 
MR, PIKE: Form. Move to strike. 
11 
A. Yes. 
12 
Q. You would? 
13 
A. witness nods head.) 
14 
0. And why? 
15 
A. Because I don't fear that he would try 
16 
anything with my daughter. He showed — When I 
17 
worked for him he showed me respect. He never — I 
1 8 
never — He never showed me disrespect. He would ask 
19 
how the family is. I mean, not on a personal level, 
20 
but an employer/employee. 
21 
Q. Right. Okay. 
22 
A. lie never showed me any reason not to trust 
23 
him. 
24 
Q. But you're not a 13-year old girl, so. 
25 
A. No, but, like I say, he never showed me 
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1 
any reason not to trust. 
2 
Q. So maybe that's the reason why there were 
3 
hundreds of victims, right? 
4 
A. I don't know that there were. 
Q. So Is it surprising to read the things that 
6 
you read about what was going on at his house? 
7 
A. Yes. 
a 
MR. PIKE: Form. Move to strike. 
9 
BY MR. EDWARDS: 
10 
Q. I'm going to ask you about — rm going to 
11 
mark them al -- In fact, rm going to show them to your 
12 
attorney first because rm going to mark them as a 
13 
comp05103 - just 10 save time. 
14 
MR. REINHART: For the record, you've 
15 
handed me a stack of passenger manifests? 
16 
MR. EDWARDS: Yes. You can count them if 
17 
you want, doesn't matter to me, and well just 
18 
mark them as a composite - go through each one 
19 
of therm 
20 
MR. REINHART: If you're going to go 
21 
through each one of them, I don't need to count 
22 
them You'll make a record on that 
23 
MR, EDWARDS: Fine. fm going to mark 
24 
these as Composite Exit bit 1, and we'll count 
25 
them at the end. 
139 
1 
know her if I saw her. 
2 
O. What did she do? 
3 
A. I don't know. I don't know. 
4 
O. Would it surprise you if she was in charge of 
s 
scheduling for the minors to come over to the house to 
6 
sexually gratify Mr. Epstein? 
7 
MR. PIKE: Form. 
a 
A. Yeah, that would surprise me, yes. 
9 
O. Okay. She didn't do that while you were on 
10 
the airpiane, right? 
11 
A. No, no. 
12 
O. Was Mr. Epstein on the airplane? 
13 
MR. PIKE: Form. When? 
14 
A. 
Yes. 
15 
O. And if it happened, it happened at a portion 
16 
of the airplane where you couldn't see it because you 
17 
were partitioned of% 
18 
A. What happened? 
19 
MR. REINHART: I'm sorry, can we just get 
20 
a timeframe? 
21 
MR. PIKE: Form. 
22 
MR. REINHART: Are we talking about this 
23 
flight? 
24 
MR. EDWARDS: Yes, we're talking about 
25 
that flight. 
138 
1 
(Defendants Composite 1 VAS marked for 
2 
identification.) 
3 
BY MR. EDWARDS: 
4 
Q. The first one's dated 1114(2004. Can you tell 
5 
me what we're looker° at there? Just remember, nn about 
6 
as familiar with that type of stuff as a three year old. 
7 
SO help me out. 
8 
A 
Passenger mandest just showing basically 
9 
date, time off. time on, the trip number or the year. 
10 
I guess it would be - that seems high for the year - 
11 
but trip number - that must be for the total • 
12 
destination or departure point - destination. 
13 
O. The trip number says. "311." What does that 
14 
mean? 
16 
A. That must be — I dent know where they 
16 
start that. That must have been total since he 
17 
started the airplane. That's wry too many for the 
2e 
year. Obviously it's already - it's January. so it 
19 
must have been total flights. 
20 
Q. Who's on that airplane? 
21 
A. Nautical miles, statute rates, fuel 
22 
burned. pounda 
23 
24 
Q. Do you know 
25 
A. I — I rink I know her. I think I v.culd 
140 
1 
BY MR. EDWARDS: 
2 
O. If anything happened on the airplane. it would 
3 
have been In a position where you couldn't see It anyway. 
4 
A. That's correct. 
5 
O. Okay. 
6 
A. That's correct. 
7 
O. So you're not saying it did happen or it 
a 
didn't happen, you just couldn't see past a certain 
9 
point. 
10 
A. Correct, and I don't know what you're 
11 
tarring to as "it" anyways. 
12 
O. it - is whatever sexual involvement there was. 
13 
A. Oh. Lice you say, we can't see anything 
14 
back there anyhow because the doors are closed. 
15 
Q. Did Mr. Epstein instruct you as to whether or 
16 
not to knock or just wak back there or never walk back 
17 
there or what was the Instruction? 
18 
A. No. There was never actually a formal 
19 
Instruction. It's proper protocol for any of these 
20 
gentlemen, or individuals that own these aircraft, 
21 
that that's their private zone, that you don't Come 
22 
back unless you're needed, and then you can -- You 
23 
know, but Its not forebode, it's just proper. 
24 
O. You mentioned President Clinton on the ptane. 
25 
How many girls were on the plane al the same time when 
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1 
President Clinton was on the plane? 
2 
MR. REINHART: Asked and answered. 
3 
A, 
Yeah, I don't remember for sure. There 
4 
was probably maybe five, if that, and that's —
5 
Q. 
What were they 
6 
A. What? 
7 
Q. Go ahead. 
8 
A. Like I say, it was Ms. Maxwell. M, 
9 
maybe two others, one other, and then I think Mr. 
10 
Clinton had two ladles in his entourage - support 
11 
staff. 
12 
Q. 
What age group are we talking about with the 
13 
ladies that were on the airplane? 
14 
MR. PIKE: Form. 
15 
A. Mid-twenties to forties, maybe. I mean, I 
16 
don't know exactly. 
17 
Q. I Mean, you know what a 13 or 14-year-old girl 
is 
looks like --
19 
A. 
Yes. 
20 
Q. 
- right? 
21 
A. Yes. 
22 
Q. Most people do. 
23 
A. 
Yes. 
24 
Q. You woukIn't mistake a 13 or 14 or 15 year old 
25 
fora 20 year old. 
143 
1 
you fernier with a fight where Prince Andrew was on the 
2 
airplane? 
3 
A. I dont know if I remember him being on 
4 
the airplane or not. I know that he has been on the 
5 
airplane or one of rite akplanes. 'can't say for 
6 
sure. 
7 
0. Have you met him before? 
A. I can't remember, honestly. I know. 
9 
0. Can't remember meeting Prince Andrew? 
10 
A. I know. I know. I didn't even know who 
11 
he was when I first heard the name, sony. But, no. 
12 
I can't remember for sure. I'm sorry. 
13 
Q. That's like if E.T. walked on the airplane and 
14 
I don't know. 
15 
A. I know. Well —
le 
Q. Alright. Fillet you slide on that one. You 
17 
know who Prince Andrew is now. 
18 
A Okay. Don't paid me as stupid. One of 
19 
Lady DI's sons. right? 
20 
Q. 
I mean, you know what he looks like new. 
21 
A. You know, honestly, I don't know if I 
22 
could point him out to you, I'm sorry. 
23 
0. Alright. 
24 
A. It's Just — 
25 
Q. Well forget him. 
142 
1 
A. No. no. 
2 
MR. PIKE: Form. 
3 
BY MR. EDWARDS: 
4 
0. So you're sure that the people that were on 
5 
the airplane - they were above the age o118? 
6 
A. I believe so. 
7 
0. Because you, in your experience. as well as 
8 
the experience of most people your age. would know —
9 
A. Right. 
10 
Q. 
— what a 14 or 15 year old looks like. 
11 
A. Right. 
12 
Q. I'm going to go through the next fright log. 
13 
You tel me what we're looking at here. Who's on the 
14 
airplane? 
15 
A. That was a deadhead. Nobody's on it. 
16 
Q. Why were the names crossed out? 
17 
A. Because there was no passengers. This was 
18 
. origin was West Palm Beach - West Palm Beath. What 
19 
date is thiST 1/20104? ft was probably a test 
20 
flight. 
21 
Q. 
Okay. 
22 
A. It was a training flight —
33 
0. Okay. 
24 
k 
—for Bill. 
25 
0. 
The next one — Well, before I ask this: Were 
144 
A. rm smart In some things. 
2 
0. Well forget him. Well forget him. Don't 
3 
worry about It. 
4 
What's this? What are we looking at? 
5 
MR. REINHART: For the record, you handed 
6 
him a manifest dated January 17, 2005; is that 
7 
correct? 
THE WITNESS: January — Yes. Correct. 
9 
Palm Beach to Kennedy, same thing, fuel 
10 
burns, loads, destination, time off, time on. 
11 
Next, It was ki 312. •Ls 
on It= 
David Mullen, 
, Todd Myster (sic), 
13 
and passenger, passenger. 
14 
BY MR. EDWARDS: 
15 
Q. Do you know Todd Meister? 
16 
A. He's a friend of his, I believe. 
17 
Q. Father's Bob Meister? Do you know the names? 
18 
A. No, I don't know that 
19 
0. How do you know Todd Meister? 
20 
A. Ne Mg heard the name. 
21 
0. From who? 
22 
A. Larry Vtsoski. 
23 
Q. Larry Visoski knows these people? 
24 
A. !think Todd Meister has an airplane. or
25 
something like that He's talked to their flight 
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1 
crew. 
2 
D. For the most part, when you mention these 
3 
people's names, you mention them as if they're just 
4 
passengers on the airplane and this is their world -
5 
you're passing through, you don't know them. 
6 
A. Right. 
7 
Q. But Visosld - would you say that he has a 
closer relationship with Epstein to where he might know 
9 
some of these people? 
10 
MR. PIKE: Form. 
11 
A. That could be an accurate - yeah. I mean, 
12 
he's been with Jeffrey longer. I mean --
13 
Q. I mean, do you know that Viso:ski has a car 
14 
that Is registered in Jeffrey Epstein's name? You don't 
15 
have anything like that, do you? 
16 
A. No, I did not. 
17 
Q. Were you aware of that? 
18 
A. No. 
19 
Q. Does Mr. Vlsoski tel you how far he goes back 
20 
with Jeffrey Epstein? 
21 
A. No, just, I mean, when he hired him, 
22 
whenever that was after Glimcher - that's al I know. 
23 
Q. Do you know anything about Visoskrs private 
24 
life? 
25 
A. A little bit. He's married and - 
147 
1 
Q. Well, do you know whose handwriting that is? 
2 
A. No, no, I don't. It may be Larry's. 
3 
O. Similar handwriting 
4 
A. Walt a minute. 
5 
O. - as those --
6 
A. Let's see the one with the training -
7 
because there's a different pilot on there. 
8 
O. Right. One where there Is nobody on it, 
9 
rIgM? 
10 
A. This is Bitrs — I can't — This is 
11 
Bits writing. I think he was having him f2I out 
12 
the paperwork. 
13 
Q. Bill Hammond? 
14 
A. Yeah, this was his training flight. 
15 
Q. The first one is Visoski? 
16 
A. Maybe. I can't say fa sure. I really 
17 
cant say for sure. 
18 
Q. And this Is? 
19 
A. I don't know if that's the same 
20 
handwriting or not. 
21 
Q. Well, is there any indication up here that 
22 
would tell us whose handwriting it is? David Rodgers and 
23 
Larry Visoski —
24 
A. No, because this is --
25 
Q. 
— are the plots. 
146 
1 
daughters. I mean --
2 
Q. Then I won't go into the rest of his private 
3 
Me. 
4 
When it says, '1 pay, 1 pay? what does that 
mean? 
6 
A. h's TAX? P-A-X is short for 
7 
"passenger? It's a brief. 
8 
O. Okay. Look, this is somebody that is listing 
9 
names of people on an airplane. They're going out Of 
10 
their way 
11 
A. Right 
12 
Q. -- and then all of a sudden on No. 8 and 9 
13 
they say, 'one passenger.* Is this person just getting 
14 
lazy or is there a reason why there's no name? 
15 
A. Like I say, just getting lazy and then 
16 
didn't know who the passenger was. 
17 
Q. Well, they obviously didn't know who Todd 
18 
Meister was either - they wrote his name all wrong. 
19 
A. They did? 
20 
MR. PIKE: Form. 
21 
BY MR EDWARDS: 
22 
Q. Well, "Meister" is not spelled like that. SO 
23 
how did --
24 
A. I didn't - I didn't know that. I don't 
25 
know how he— How does he spell it? 
2 
3 
4 
6 
7 
148 
A. Yeah, but they don't indicate - they don't 
indicate who's captain that day. You know, rm not a 
handwriting expert I can't realty — Honestly, I 
cant tel you for sure whose handreidn0 it was. 
Q. Let's keep this one out. and tell me if Cis 
Is — rm going to hand you January 19, 2005 — 
Mt REINHART: January 17. 
a 
MR. EDWARDS: 2005? 
9 
M. REINHART: Yee. 
10 
BY M. EDWARDS: 
11 
O. —Januar/11, 2006, so two days biter -where 
12 
Is this airplane going? 
13 
A. From Kennedy to Palm Beach. 
14 
Q. And so this is Palm Beach to Kennedy -
15 
A 
Yep. 
16 
Q. - In iris exhibit The next one is Kennedy 
17 
to Palm Beach. 
18 
A. Correct. 
19 
Q. They come back. Where do they stay-do you 
20 
Nitre 
21 
A. Whatdo you mean? 
22 
Q Well, they set oft on the 17th, they stay 
23 
liCenWebere until they come back on the 19th. Do you know 
24 
vAse Vey stay? 
25 
MR. REINHART: Can we clarify who -they 
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149 
is? 
2 
BY MR. EDWARD$: 
3 
0. I uess it Is: David Mullen. 
4 
Tod Myster (sic). I pax. another pax, 
5 
and Jeffrey Epstein - and there's a crossed 
6 
out "Ghislaine Maxwell' so I'm assuming she didn't go. 
7 
A. Correct. 
8 
I have no Idea where they stayed. I 
9 
assume Jeffrey would stay In his home. 
would 
10 
stay in her apartment. As for al the others, I have 
11 
no Idea. 
12 
Q. Have you ever been to Jeffrey Epstein's home 
13 
in New Yak? 
14 
A. .kist in the lower level of the entryway. 
15 
Q. Why did you go? 
16 
A. To pick up bags for the trip to go to the 
17 
airport and load them. 
18 
0. Was there anybody else there with him? 
19 
A. I don't know with him. I never saw him 
20 
him. We saw the guy that ran the house. 
21 
Q. Who's that - Joe-Joe? 
22 
A. Joe-Joe would be there —
23 
0. What's Joe-Joe's name? 
24 
A. Joe-Joe, that's alit know, and then 
25 
there's the actual house manager. Joe-Joe is more of 
151 
1 
0. The next cue Is January 27. 2005. Palm Beach 
2 
to where? 
3 
A. St. Thomas. 
4 
Q. To St Thomas. 
5 
A. Right. 
6 
Q. And he has 
and 
and Jeffrey. 
7 
A. Right. 
8 
Q. Does he tell you what happens in St. Thomas? 
9 
What he does there? 
to 
A. No, no. 
Q. Ever heard that he imports underage girls from 
12 
Brazil to his —
13 
MR. PIKE: Form. 
14 
0. 
— island in St. Thomas? 
15 
MR. PIKE: Form. 
16 
A. No, no, never heard that. 
17 
0. What does he tell you about his island in St. 
18 
Thomas? 
19 
A. Not a lot. I mean, he would sometimes 
20 
talk about construction stuff or I would hear him -
21 
overhear him and Larry talk about the helicopter pad 
22 
that they're putting In, little stuff like that - all 
23 
construction. 
24 
0. Did he left you two or three times a day, that 
25 
he sexually abuses girls between 12 and 15 years old? 
150 
1 
a driver, and then there's the house manager - I 
2 
forget his name. 
3 
But, yeah, we would meet — There's an 
4 
office In the lower level that the bags would be at 
5 
and we would put them in the back of the van, haul 
6 
them to Me airport. 
7 
Q. Who's David Mullen? 
A. I don't know. I heard of It. It sounds 
9 
familiar. I can't remember who he Is. 
10 
Q. Somebody that eves in New York, Palm Beach? 
11 
A. I don't know. I don't know. 
12 
Q. rm trying to keep them In order. 
13 
So coming back - you know, it looks like they 
14 
take to JFK: David Mullen, Tod Myster (sic). sons 
IS 
assE
rs unnamed - they come back with only.. 
16 
and 
- any idea why? 
17 
MR. PIKE: Form. 
18 
A. No. butt mean, it's not unusual for 
19 
these guys to, you know, take somebody - let somebody 
20 
have a free ride to New York it they know them, they 
21 
are acquaintances, need a tilt, I mean, that's not 
22 
unusual. 
23 
Q. How's that come about - do you know? 
24 
A. No, I don't - phone conversations, 
25 
cocktail parties. I don't know. 
152 
A. No. 
2 
MR. PIKE: Form. 
3 
BY MR. EDWARDS: 
4 
Q. Not something he ever mentions. 
5 
A. NO, no. 
6 
MR. PIKE: row'''. 
7 
BY MR. EDWARDS: 
O. The next - 2/3/05 - who's on the passenger 
9 
list? 
10 
A. Jeffrey, M.= 
Jean Luc, David 
1.1 
Mullen. female, female, female. 
12 
Q. Any idea why they would list "female, female, 
13 
female: without listing the names? 
14 
A. No, just the same as — The only idea I 
15 
would have would be the same reasoning for the -
16 
previously when they listed them aS just 'PAX - that 
17 
they didn't have any Idea who they were, what their 
18 
name was. 
19 
Q. I mean, certainly that's -
20 
A. I don't know whose handwriting that is. 
21 
Q. You're guessing, though, right? 
22 
A. Yeah. No, I'm guessing. I have no Idea. 
23 
Q. Another guess would be there 12 years old 
24 
and you can't put them on it. 
25 
MR. PIKE: Form. 
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153 
1 
A. I wouldn't say that. I don't know that. 
2 
Q. Have you ever been on an airplane where you 
3 
looked at this and you thought, "Hey, that's kind of 
4 
strange that they wouldn't list them by name. They're 
5 
talking about it generically: Female, female, female"? 
6 
A. But they also — 
7 
MR. PIKE: Form. 
A. 
another one: PAX, PAX, PAX 
9 
Q. You never thought that was odd either? 
1 o 
A. No. I never actually even really paid 
11 
attention to this paperwork. I don't see this. 
12 
MS. EZELL: Brad, excuse me - this is 
13 
Kathy Ezell - is there a date on that manifest 
14 
you're showing? 
is 
MR. EDWARDS: Its 2f3/C6. 
16 
MS. EZELL: Thanks. 
17 
MR. EDWARDS: Is that your 12-year old 
18 
client listed as NO. 6? 
19 
MR. PIKE: Form. Move to strike. 
20 
MS. EZELL: No, but —
21
MR. EDWARDS: Okay, sorry, somebody 
22 
else's. 
23 
MS. EZELL: Okay. Thanks. 
24 
BY MR. EDWARDS: 
25 
Q. 2t7/05 - who's on there? 
155 
what it says. 
2 
A. It's — I think it's a 2 - 2/10. 
0. Alright. Can you toll us who on that 
airplane? 
A. Jeffrey, looks like 
=
 
-
 
is that 
Jean Luc? 
7 
Q. Yeah. 
A. That's Jean Luc, I think, and 
9 
(sic). 
to 
Q. Jean Luc is another one who travels quite 
11 
frequently. Why, if you know, does he travel quite 
12 
frequently on these airplanes to and from New York with 
13 
Jeffrey Epstein - any idea? 
14 
A. My only assumption was business, and 
15 
that's just an assumption. 
16 
0. What kind of business do you know of that they 
17 
have in common? 
1 a 
A. I was under the impression a modeling 
19 
business. 
20 
0. Other than the modeling agency. what other 
21 
business do they engage in together, if you knoW 
22 
A. I don't know. 
23 
0. And has Jeffrey Epstein ever talked to you -
24 
a lard enough to whIch you could hear him discussing the 
25 
modeling agency? 
3 
4 
5 
6 
154 
1 
A. Jan 
=, 
David Mullen, 
2 
Jansen. 
3 
0. Do you know who Jansen is? 
4 
A. No. 
5 
Q. David Mullen travels a lot. Do you have any 
6 
idea what his relationship is with Mr. Epstein? 
7 
A. I don't even know who David Mullen really 
8 
is. 
9 
0. Have you ever seen him? 
10 
A. I might be able to piste him if I saw a 
II 
picture of him. 
12 
Q. I mean, obviously you're on the airplane with 
13 
him a lot. 
14 
A. Yeah, so, I mean, obviously I would 
15 
recognize him if I saw a picture. 
16 
0. Do you know if he travels with anybody else on 
17 
this? 
18 
A. Unless it's that one name I don't 
19 
recognize - that Jansen, or whatever. 
20 
0. But Jansen's not somebody you know? 
21 
A. No. no. 
22 
0. I can't read that date - maybe you can. I got 
23 
a bed fax copy. 
24 
A. Maybe 2-2/10. 
25 
0. That's Michael Pike not wanting me to know 
156 
1 
MR. PIKE: Form. 
2 
A. No, just that the only conversation he 
3 
ever - I remember - was the one that he - the one 
4 
about the girl opening the wrong door on the motor 
5 
home. 
6 
a 
Was he happy or sad about the modeling agent, 
7 
A. No, he was happy she wasn't injured, but 
8 
he was kind of making light of what a silty thing to 
9 
do. you know. 
10 
0. Do you know If Jean Luc is theme procuring 
11 
the models or is Jeffrey procuring the models? 
12 
A. I don't know. 
13 
MR. PIKE: Form. 
14 
BY MR. EDWARDS: 
is 
0. You never investigated into how this modeling 
16 
agency is doing or anything else? 
17 
A. No, no interest. 
18 
0. You by to stay completely out of it? 
19 
A. Nokia:est_ 
20 
0. Especially in light of the recent things 
21 
you've read. 
22 
A. I mean, I didn't have any interest In It 
23 
before all the recent things. 
24 
Q. rin going to skip this one because it talks 
25 
about very similar people that you've already read. 
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157 
1 
A. Okay. 
2 
Q. No different names. 
3 
MR. REINHART: Can we just get the date on 
4 
the record? 
s 
BY MR. EDWARDS: 
6 
O. Weil, actually, we don't have to skip it. 
7 
2/15/05 - that's the date, right? 
8 
A. Right. 
9 
Q. And it says: Ghislaine Maxwell —
10 
A. Oki .= 
11 
Q. —S 
and 
12 
(sic); is that right? 
13 
A. That's what it says. 
14 
Q. Is that a typical crew that you would see on 
15 
the plane? 
16 
A. What year is this? In '05? 
17 
O. 
Yes. 
18 
A. Yes, but towards the end there, I think 
19 
the last year. I only saw Ms. Maxwell once. 
20 
Q. Do you know at any falling out of sorts that 
21 
Gltislaine Maxwel and Epstein had? 
22 
A. Well, no. I think they still - I think 
23 
she still has a lot of association, or whatever. 
24 
Q. Do you think they are still a couple? 
25 
A. I don't know that they ever were. I never 
159 
1 
Stanleys are. 
2 
Q. Ever heard of them? 
3 
A. No. 
4 
O. As far as you're concerned, they're some 
islanders or something, right? I mean —
6 
A. Well, they might be — I mean — 
MR. PIKE: Form. 
a 
A. -- there's a lot of wealthy people down 
9 
there. They might have been friends or associate 
10 
that needed a lift back stateside. 
it 
O. Fair enough. 
12 
What's the next one? 
13 
A. Teterboro to PBI. 
14 
O. And who's on it? 
15 
A. Jeffrey, 
s
 
and-. 
16 
MR. REINHART: Can we get a date for the 
17 
record? 
18 
THE WITNESS: 2/24. 
19 
BY MR. EDWARDS: 
20 
O. It seems like 
and 
travel a lot 
21 
with Jeffrey. Is It ever your understanding that Jeffrey 
22 
Epstein had a sexual relationship with either of them? 
23 
A. That is not my understa 
• , no. 
24 
O. Do you know of 
having a boyfriend 
25 
ever? 
158 
1 
did figure out the relationship, other than I assumed 
2 
they were a couple and she was a business assistant -
3 
associate, but that was all assumption. 
4 
Q. Did you ever know of Jeffrey Epstein to have a 
5 
girlfriend, per se? 
6 
A. If it would have been, It would have been 
7 
Ms. Maxwell. 
8 
Q. Other than Ms. Maxwell, could you identify any 
9 
other female that appeared to be in a intimate 
10 
relationship with Jeffrey Epstein? 
11 
A. Not really, not that I - not that I cask! 
12 
say it was a relationship, no. 
13 
Q. I'm going to show you another one. I don't 
14 
know these people. Tell me who they are. It lodes lie 
15 
you're on the airplane —
16 
MR. REINHART: Can we get a —
17 
Q. -- and the date Is 2/21/05. 
18 
A. Right. 
19 
O. Which is ten days after the previous. It's 
20 
going — 
21 
A. I don't know who the Stanleys are. 
22 
Q. And it's going from the island. 
23 
A. To - 
24 
Q. Palm Beach. 
25 
A. -- Palm Beach. I don't know who the 
160 
1 
A. I heard that she has a boyfriend. 
2 
O. And what's his name? 
3 
A. And this is just hearsay. I don't know. 
4 
O. I'm interested in hearsay. 
5 
A. I heard that she's dating somebody -
6 
that's all. 
Q. Dating whom? 
8 
A. A guy — Somebody by the name of Story. 
9 
Q. Story Cowells (phonetic)? 
10 
A. I don't know his last name. 
11 
Q. How king has she been dating him? 
12 
A. I don't know. This is just Larry, you 
13 
know, every once in a while asks, you know, 'What's 
14 
gokya onT 'Whole -- You know, I dont know. 
15 
Q. Where does Story live? 
16 
A. I think he's down here. I think he's one 
17 
of Mr. Epstein's legal team or something or —
18 
Q. And Story is somebody who you heard of through 
19 
Larry Visoski? 
20 
A. Yes, yes. 
21. 
Q. And specifically what did Larry Visoski say 
22 
about Story? 
23 
A He thought that they were dating - he and 
24 
MI- 
and this is ad hearsay. 
25 
O. Since when? 
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