EFTA01110326

Condensed Transcript 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
Plaintiff, 
CASE NO. 
-vs- 
502008CA028051 
X.XXXMB AD 
JEFFREY EPSTEIN, 
Defendant. 
DEPOSITION OF 
LARRY VISOSKI 
October 15, 2009 
10:18 p.m. 
515 N. Flagler Drive 
Suite P200 
West Palm Beach, Florida 
Reported By: Wendy Beath Anderson 
ESQUIRE 
a* Alexarter Gallo Coop or 
Toll Free: 866.709.8777 
Facsimile: 561.394.2621 
Suite 600 
4440 PGA Boulevard 
Palm Beach Gardens, FL 33410 
www.esquiresolutions.com 
EFTA01110326

Larry ViSOSki 
October 15, 2009 
I P4 114£ CIRCUIT COURT OP TIM TIPTIMITE J-3DICIAL CIKUIT 
IN MD IOR MLR REACH 010.TY, PLOPZDA 
CASE MO. 5020010101POSIx110111 AD 
Plaintiff. 
JeFTISC nmxx. 
Defendant. 
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• . -
INDEX 
• • • 
WITNESS: 
DIRECT CROSS REDIRECT RECROSS 
LARRY VLSOSK1 
BY MR. EDWARDS: 
6 
MOOStt10N OP LAY vilest! 
rIturenay, October 15. 3004 
a 
BY MR. CRITTON: 
214 
BY MR. EDWARDS: 
220 
toils - 1:11 pa. 
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BY MR. CRITTON: 
221 
10 
511 N. Plagler Drive 
Suite Me 
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Neer MIN. Satoh, florid.. 1)401 
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• • • 
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EXHIBITS 
1141p9ftej Sy, 
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• • -
Wendy death Anderson, RPR, CRR. PPR 
votary Public, State Of Plorida 
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,racialre Direesttlen Ninglowil 
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NUMBER 
DESCRIPTION 
PAGE 
int pale brad, Office 
Jeb 113)541 
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PLAINTIFFS EX. 1 
FLIGHT LOG BOOT( 
(MARKED IN PREVIOUS DEPO) 
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PLAINTIFFS EX. 2 
MESSAGE PAD 
119 
PLAINTIFF'S EX. 3 
MESSAGE PAD 
119 
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PLAINTIFF'S EX. 4 
COMPLAINT 
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PLAINTIFF'S EX. 5 
INMATE VISITOR LOG 
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APPEARANCES: 
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PROCEEDINGS 
On behalf of the Plaintiff: 
BRADLEY J. EDWARDS. ESQUIRE 
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... 
T ADLER 
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Deposition taken before Wendy Beath Anderson. 
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Certified Rash' rne Reporter and Notary Pudic in and for 
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the State of Florida at Large. in the above cause. 
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--- 
On behalf of the Defendant: 
ROBERT D. CRITTON, JR., ESQUIRE 
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MR. EDWARDS: We're going to put something on 
ITT 
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the record about -- well, we'll do it this way - 
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MR. REINHART: Do it at the end, alter we get 
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him -- whatever you want. It's your show. 
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On behalf of die Witness: 
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MR. EDWARDS: Okay. There were -- I don't 
think Mr. Welds Is aware 
this. There 
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1111= 
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oven 
of 
was 
a subpoena duces team for this witness, as well as 
the previous witness, which was another pilot. Dave 
as 
ALSO PRESENT: 
is 
Rogers. and that duces tocurn was to bring the 
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MES E 
UtRE 
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flight logs related from 1998 through 2005. What 
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was produced at the previous deposition were flight 
is 
TIME 
i 
R WITZ PA. 
1$ 
logs from 2002 through 2005, and now Mr. Reinhart 
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has agreed to produce the remainder of the flight 
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logs requested, those going from 1998 through 2002. 
RICHARD H. WILLITS. ESQUIRE (VIA TELEPHONE) 
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MR. REINHART: Correct. They're pilot logs, 
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A 
P.A. 
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not night logs. There are other records we 
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Indicated are corporate records, and with those you 
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have to deal with Mr. Critton. 
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MR. CRITTON: However, with the proviso, too, 
ESQUIRE 
Oalloo ComPal 
Toll Free: 866.709.8777 
Facsimile: 561.394.2621 
Suite 600 
4440 PGA Boulevard 
Palm Beath Gardens, FL 33410 
vnvw.esquiresolutlons.com 
EFTA01110327

Larry Visoski 
October 15, 2009 
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that we're going to work out that these records are 
to be used within the confines of this litigation 
and not to be spread to the press or anyone else. 
because they do contain confidential information as 
to who may have been on the plane and other records 
of Mr. Rogers, which but for the subpoena would 
have been only available to the FAA or some other 
law enforcement agencies. 
MR. EDWARDS: Okay. Is that all you want to 
put on? 
MR. CRITTON: Yes. 
MR. EDWARDS: I'm not saying I necessarily 
agree or disagree with you. Thais something that 
well deal with some other day. 
MR. CRITTON: Bruce, you'd better produce 
these records, but there has to be some sort of 
understanding before -
MR. REINHART: Correct. 
MR. EDWARDS: I won't do anything until you 
file whatever you - until we work whatever it is 
out in court. ill say that on the record, that 
I'm not doing anything with the records outside of 
my office until some Judge deals with It. 
MR. REINHART: And for the record, I'll adopt 
what Mr. Craton said on this one limited occasion. 
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the question and you need to wait until I finish asking 
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the question. 
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A. So yotfre not allowed to interrupt me? 
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O. And you're not allowed to interrupt me. 
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A. Like I just did? 
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O. Right. 
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MR. CRITTON: Cara just snickered when you 
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said yotfve been accused because she recognizes 
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irs true. 
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MR. EDWARDS: I don't know what the meaning of 
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her snickering was. 
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BY MR. EDWARDS: 
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Q. But for what ifs worth, if you don't 
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understand the question or I've asked a bad question, I 
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don't want you to guess. Give me the best answer to the 
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best of your knowledge and if you need me to rephrase 
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rt. I wilt 
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A. Okay. 
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O. Okay. Tell me your current address. 
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A 
U 
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Q. How long have you lived there? 
A. Approximately nine years. 
Q. Okay. Who do you live there with? 
A. My wife and one chid al this tine. 
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MR. EDWARDS: Al right. 
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Thereupon. 
(LARRY VISOSKI) 
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having been first duly sworn or affirmed, was examined 
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and testified as follows: 
THE WITNESS: Yes, I do. 
DIRECT EXAMINATION 
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BY MR. EDWARDS: 
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Q. Can you tell us your name for the record 
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A. Lawrence Visoski, Jr. 
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Q. And Mr. Visoski, have you ever had your 
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deposition taken before? 
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A. No. 
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O. Okay. Here's the process: I'm going to ask 
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you questions. You're going to give us answers. Try to 
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give us answers that we all understand and that the 
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court reporter can take down, such as yes, no. or some 
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other verbal answer that we can understand. It's easy 
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when we get in a casual conversation to nod or shake 
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your head, and the court reporter is not writing 
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pictures or anything else. 
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A. I understand. 
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O. The other thing is, and I've been accused of 
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this In other depositions -- I donl know if it's true 
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or not -- but I need to wait until you finish answering 
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O. All right. How many children do you have? 
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A. Two. 
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Q. How old are they? 
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A. Fifteen and eighteen. 
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Q. And is the 18-year-old, is not living with 
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you? 
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A. She's off in school. 
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Q. Okay. What school Is that? 
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A. Syracuse. 
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Q. Who's your employer right now? 
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A. NES, LLC. 
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Q. How long has NES, LLC been your employer? 
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A. I'm guessing. I'd say back 1991. I have to 
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do the math, but 17, 18 years. 
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O. Has that been your only employer since 1991? 
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A. Yes. 
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O. And has that been your only source of income 
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since 1991? 
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A. Yes. 
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Q. And what is NES, LLC? 
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A. I don't really know. I mean, rt's the company 
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that my check comes from. 
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Q. What do you do for NES, Lie that results in 
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them paying you? 
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A. I am chief pilot for the aircraft and 
ESQUIRE 
.m 
Toll Free: 866.709.8777 
Facsimile: 561.394.2621 
Suite 600 
4440 PGA Boulevard 
Palm Beach Gardens, FL 33410 
irnvw.esquiresolutIons.coM 
EFTA01110328

Larry Visoski 
October 15, 2009 
9 
. 
helktopters. 
0. And do you have a specific boss or somebody 
you answer to at NES, LLC? 
A. Several people would call to schedule flights 
from the office, being it either Mr. Epstein or, you 
know. I would lust get a phone call and they would 
schedule a trip. 
Q. Okay. Aside from Mr. Epstein, who else would 
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there be that would call to schedule flights? 
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A Leslie. 
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0. Leslie who? 
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A. Leslie Gruff. 
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Q. When's the last time you talked to Leslie 
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Gruff? 
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A. Probably two weeks ago, three weeks ago. 
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Q. And where is she currently? 
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A. I believe in New York, is where I spoke to her 
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on the phone last. 
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Q. What's the telephone number you call to reach 
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Leslie Gruff? 
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A. 
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Q. And what address is Leslie Gruff at? 
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A. Do you mean where the office Is located? 
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0. Correct 
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A. 
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O What floor or suite number is NES. LLC In? 
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A. I believe — well, I don't know that NES, LLC 
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has an office there. I know that's where Leslie has the 
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phone number where I call So I don't know for a fact 
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rf NES. LLC has an office there. 
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O. And whet suite number, then, would Leslie 
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Gruff sit in to answer that telephone number at 
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MIM 
A. I think It's 10F. 
Q. And when you stay a 
what suite number or what apartment number do you stay 
in? 
A. 12C. 
0. And how about Dave Rogers, where does he stay? 
A. I'm guessing, because it's been some time 
since we've been there, 108, but don't quote me on 
0. Who are the other people in that building that 
you know to stay there on a reguku — fairly regular 
basis? 
A. the seen people in the elevator that. you 
know, have been on the airplane. Case in point. maybe 
but I dorYt know totaled that she Wes 
there, or anybody else for that matter. 
0. Okay. When you say you've mein.. 
on the elevator 
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0. And It's my understanding from other 
2 
depositions that there are also apartments In trial. 
building? 
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A. Yes. 
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Q. And Mr. Epstein either owns or leases or rents 
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certain of those apartments. Is that your 
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understanding? 
a 
MR. CROTON: Form; speculation. 
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THE WITNESS: I'm only speculating. I 
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don't -- to my understanding, I don't know. 
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BY MR. EDWARDS: 
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0. Do you know other people that live in that 
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building? 
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A. Well, it would be myself. Dave Rogers - wet 
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when you say "live,' explain. 
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0. When you're saying yourself and Dave Rogers -
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A. See, we don't live there. I mean, we have --
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we would stay there when we would have a trip. 
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Q. Okay. When you would fly up to New York and 
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land in New Yogic, the place where you would stay, is 
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the 
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A. Yes, that's corned. 
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0. That's also a location you've indicated in 
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this deposition that Is the office for NES, LLC? 
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A. Yes. 
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A. I only assume she Wes there. I don't know 
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for a fact. rm hying to be honest and factual for 
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you. So I couldn't honestly say if I knew she lived 
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there or not 
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0. Where do you thine 
Wes? 
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A. I would think she lives there. 
0. You don't have a bettor location? 
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A. I don't have another location. 
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0. Anybody else? 
2o 
A. Not to my knowledge. I mean, I'd only be 
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guessing that people We in that builckng that -- you 
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know, I don't have any facts to prove that they actually 
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live there. I mean, I don't think you want me to guess. 
0. Well, NES, LLC, would you say that the owner 
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or controller of that company Is Jeffrey Epstein? 
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MR. CRITTON: Form. 
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THE WITNESS: I don't know that for a tact. 
1e 
BY MR. EDWARDS: 
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0. Jeffrey Epstein is somebody you've Indicated 
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that you've worked for for 17 or 18 years, right? 
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A, Yes. 
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0. And over the 17 or 18 years you've become 
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personally close with him as wee, correct? 
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MR. CRITTON: Form. 
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THE WITNESS I Oaf* understand how you mean 
ESQUIRE 
•• SOM.!. Oal *U./al 
Toll Free: 866.709.8777 
Facsimile: 561.394.2621 
Suite 600 
4440 PGA Boulevard 
Palm Beach Gardens, FL 33410 
www.esqulresolutlons.com 
EFTA01110329

Larry Visoski 
October 15, 2009 
13 
1 
'dose.' Define that. 
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BY MR. EDWARDS: 
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a 
Wel, rpm so than just a pilot that takes him 
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from Point A to Point B? 
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A. That is my job. 
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O. Right. But you know him on a personal level 
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and that you've had personal conversations that don't 
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necessarily deal with flying from Point A to Point B; 
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isn't that right? 
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MR. CRITTON: Form. 
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THE WITNESS: More specific, meaning we talk 
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about cars. I mean, does that make you a personal 
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friends? 
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BY MR. EDWARDS: 
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O. Have you ever gone to his house to eat? 
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A. No. 
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O. Have you been to his New York home? 
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A. Yes. 
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O. How many occasions have you been to his New 
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York home? 
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MR. CRITTON: Object to form. 
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THE WITNESS: We normally pick up luggage In 
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the lobby, so it would probably be quite often. 
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Any time we depart out of New York, we stop by the 
2S 
house and pick up luggage and head to the aircraft. 
is 
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you know. televisions and such. 
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O. Is that another hobby or job or something of 
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yours? 
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A. Both. 
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O. Does he pay you for that? 
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A. Not any more than my salary. 
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O. What's your current salary? 
A. At this time, 180,000. 
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O. And what aro you paid $180,000 to do? 
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A. To manage his aircraft. 
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O. What does that entail? 
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A. Schedufing maintenance. Anything that has to 
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do with any flight, whether it be weather, flight 
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planning, time and distance to and from a location, any 
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logistics involved In running an operation that has 
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aircraft. 
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O. In addition to the 180,000, does he give yc. 
1$ 
bonuses as welt? 
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A. There have been Christmas bonuses. 
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O. Over the years, you mean, there have been 
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Christmas bonuses? 
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A. Yes. 
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O. Is 180,000 the most he's ever paid you? 
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A. No. 
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O. All right Were you making 
when was the 
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BY MR. EDWARDS: 
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O. Other than picking up luggage, have you been 
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to his home to visit or socialize with him? 
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A. Not to socialize, no. 
s 
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Have you been to his Palm Beach home? 
A. To? 
O. To Mr. Epstoin's Palm Beach house? 
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A. Right. 
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O. Have you been there? 
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A. Yes. 
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O. Have you been inside? 
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A. Yes. 
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O. And how many occasions have you been inside 
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that home? 
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A. The same, as far as picking up luggage, and 
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that would be on a regular basis, you know, for a 
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departure. We wouldn't always go to the house to pick 
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up luggage, but it made it easier for loading the 
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aircraft getting it done prior to departure. 
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Q. Is that the only reason that you have ever 
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gone to the Palm Beach home over the last 18 years. is 
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to pick up luggage? 
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A. No. 
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Q. What other reasons have you gone there? 
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A I've set up several home theater equipments. 
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last time that you were making an amount different than 
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180,000? 
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A. Last year. 
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O. That would be 2008? 
A. That would be correct. Yeah, we all took a 
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salary cut, I don't know the exact date. It might have 
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been 2008, last year. It was last Christmas wo all took 
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a 10 percent salary cut. 
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Q. Do you know why? 
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A. Economic reasons. 
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O. And who told you that you were going to have 
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to take the salary cut? 
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A. Darren Indyke. 
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Q. And did you ask for an explanation? 
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A. lie explained it was due to economic reasons 
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throughout the country. 
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O. Okay. So In 2008, how much was -- were you 
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being paid by NES, LLC? 
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A. 200.000. 
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O. And is 200,000 the most that you've ever made 
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from NES, LLC? 
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A. Yes. sir. 
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O. And on top of that $200,000, did you get a 
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bonus that year as well? 
25 
MR. REINHART: Which year are you bildng 
ESQUIRE 
Toll Free: 866.709.8277 
Facsimile: 561.394.2621 
Suite 600 
4440 PGA Boulevard 
Palm Beach Gardens, FL 33410 
veew.esquiresolutions.com 
EFTA01110330

Larry Visoski 
October 15, 2009 
9 
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about? 
MR. EDWARDS: 2008. 
THE WITNESS: That year, I think we skipped 
Christmas bonuses that year. The last bonus might 
have been 2007. 
BY MR. EDWARDS: 
Q. If you ever got a bonus from Mr. Epstein —
and I'm only deriving this from you using the term 
'Christmas bonus' 
A. Holiday bonus. 
Q. -- am I correct to assume 
sorry. Am I 
correct to assume that if you got a bonus, there was 
only one and it was at the end of the year, around the 
holidays? 
A. Yes. 
Q. Okay. And how much was the 2007 holiday 
bonus? 
A. I'd have to ask my wife. to be honest. I 
haven't seen my paycheck in 27 years. so I believe it 
was 310.000. 
Q. And in 2007 you also made $200,000? 
A. Yes. 
Q. Okay. 
A. With a question mark. I'm trying to be as 
accurate as I can, but yes. 
19 
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my paycheck. So I don't even know what's written on the 
2 
lop of it. 
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0. That would be something that only your wife 
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would see. I'm assuming? 
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A. You're right, since she probably wouldn't know 
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the answer either, because she's looking et the right 
7 
column and not the top column. 
a 
0. Right. When is the first time that you had 
9 
heard the name NES, LLC, that company? 
10 
A. Fwe. Six years, and even questioned what'd 
11 
stood for. And I think to this day I couldn't answer 
12 
that honestly, what It stands for. 
13 
0. Okay. But it's your understanding that the 
14 
NES, LLC is paying you for the work that you do as a 
15 
pilot or maintain the planes for Jeffrey Epstein? 
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A. To my understanding, yes. 
17 
a 
And back In 1991. do you know If It was a 
18 
dffereert company that was paying you or if it was 
19 
Jeffrey Epstein directly paying you? 
30 
A. I don't remember. I mean, I don't
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0. Okay. Throughout your career with -- as a 
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pilot laJeffrey Epstein, since 1991, has there ever 
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been a time when you believe you we paid directly from 
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Jeffrey Epstein personally versus some company? 
25 
A. Not to my kncrertedge, no. 
18 
0. Something pretty close to mat? 
A. Yes, sir. 
0. Okay. So with the bonus it was 210,000. 
roughly? 
5 
A. Right. 
0. Okay. And how long were you making that 
salary? 
A. Probably -- he was very religious about giving 
9 
annual increases. so I would probably say 2006, you 
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know. It was -- we would get Increment 
increases of 
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five or $10,000 each year. So I would say 2006. So it 
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graduated. you know, progressive. 
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0. Okay. Do you remember the progression if we 
14 
start at 1991? Do you remember roughly what the 
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progression was up through 2007/2008, when you were 
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making $200,000? 
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A. No, I wouldn't know the progression. 
15 
0. Okay. Do you remember what you were making 
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from -- and was NES, LLC the company paying you back in 
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1991? 
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A. I don't know. I don't remember. Let me say 
22 
it that way. I don't remember. 
23 
O. Okay. When how long do you remember NES, 
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LW being the payer of your check? 
25 
A. Personally, two years. because I've never seen 
20 
0. Okay. So whether s was NES. LLC or some 
2 
other company, it was all of a sudden a company name, to 
3 
the best of your linoviedge? 
4 
A. Exactly, yes. 
5 
0. And back in 1991, do you remember 
6 
approximately how much you were being paid that year? 
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A. Fifty-live or 80.000. is maybe what I started. 
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0. Okay. 
A. You're going back a long ways. 
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0. Yes. 
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A. I'm trying. 
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0. Your relationship goes back that far. There 
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why I those that year. 
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A. Right. 
15 
0. Okay. Did you get bonuses even back that far? 
16 
A. Yes, sir. 
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0. And do you remember what your bonuses were 
as 
approiknately? 
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A. 5,000. I mean. that was laird of the — the 
20 
starting point. 
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0. Okay. In addition to moneary bonuses. were 
22 
there ever gifts or any other type of compensation that 
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NES, LLC or Jeffrey Epstein provided you? 
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A. Yes. 
25 
0. And is that over the span of the 18 years? 
ESQUIRE 
a* A nat. 
Gall* Ceasan 
Toll Free: 866.709.8777 
Facsimile: 561.394.2621 
Suite 600 
4440 PGA Boulevard 
Palm Beach Gardens, FL 33410 
www.esquiresolutIons.coM 
EFTA01110331

Larry Visoski 
October 15, 2009 
21 
A. Yes. 
O. Okay. Ten me what some of those items are. 
A. I remember one specifically was a pool heater. 
Q. Excuse me? 
A. A pool heater. 
Q. When was that? 
1995-ish. 
Q. Okay. Why did you get that? 
9 
A. I had built a pool and I didn't have a heater 
10 
and he kind of laughed at me saying, 'How can you have a 
11 
pool without a heater?' So he says, 'You ought to get a 
12 
heater." 
13 
Q. Where were you when you had that conversation? 
14 
A. In the airplane. 
15 
O. How ofd he know that you had bunt a pool? 
16 
A. Just in general conversation, 
17 
O. You were having a conversation with Jeffrey 
18 
Epeteli? 
19 
A. Yes. 
20 
O. And this is something that was happening on 
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the airplane, this conversation? 
22 
A. Dung the flight Yeah, It would have been 
23 
We on cruise or something. 
24 
Q. Okay. When you say during the flight,' does 
2s 
that — 
2 3 
1 
Q. But more so than that, if there's going to bo 
2 
a casual conversation about a peel or a pool heater or 
3 
whatever, Ws going to be with you most likely if he's 
4 
going to be talking to pilots, right? 
5 
MR. CRITTON: Form. 
6 
THE WITNESS: Right. 
7 
BY MR. EDWARDS: 
O. Okay. And you feel like over the years yoke 
9 
relationship with Jeffrey Epstein has boon pretty good? 
10 
A. Yes. 
11 
O. And you have been closer to him over the years 
12 
as you've grown to know him? 
13 
MR. CRRTON: Form. 
14 
THE WITNESS: The same throughout the same 
15 
year. We never got any closer than 1991 than I am 
16 
wilt him now. I'm very professional at what I do 
17 
and know the line between being professional and 
18 
thinking you're somebody's buddy. 
19 
BY MR. EDWARDS: 
20 
O. Okay. So thars not something that you think 
21 
you are? You don't think you're his buddy? 
22 
A. No, sir. 
23 
O. Do you consider yourself his friend? 
24 
A. I believe so. 
25 
Q. Do you think he considers you his friend? 
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1? 
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22 
A. Again, you're going back a long ways. 
O. I understand. We're larking about 1995 right 
now. 
A. Yes. 
O. You're having a conversation with Jeffrey 
Epstein. Who is flying the airplane? 
A. The auto pilot and there's two crew. 
O. Okay. So are you back in the back portion or 
Is he up In the cockpit? 
A. Up in the cockpit. 
O. Okay. Jeffrey Epstein sometimes comes up 
there? 
A. Just, yeah, in between the two pilot seats. 
Q. All right. Is that something that was 
typical, to have conversations like that? 
A. Mm-hmm. 
O. Yes? 
A. Yes. No nodding. 
O. And woukl those conversations be directed 
mainly with you or with the other pilots as well? 
A. Mainly with me. 
Q. I mean, you've kind of been described as the 
main guy or the main pilot. Wouldn't you consider that 
pretty much your role, right? 
A. Well, that's chief pia 
24 
1 
A. I think so. 
2 
O. All right. What makes you think that? 
3 
MR. CARTON: Speculation. 
4 
THE WITNESS, He's always been kind and 
5 
respectful. 
6 
BY MR. EDWARDS: 
O. Ever invited you to dinner? 
A. No, sir. 
9 
Q. Have you ever associated or socialized with 
t 0 
him during the day at any of his homes? 
11 
A. Only during a business reason. 
12 
O. Okay. What are the other 
are the places 
13 
that you believe that Mr. Epstein owns? I know we've 
14 
talked about this Manhattan -- the Manhattan house. 
IS 
I've read the altos about it, the Palm Beach mansion. 
16 
But what other places are you familiar with that 
17 
Mr. Epstein owns? 
18 
MR. CRITTON: Form; predicate, speculation. 
19 
THE WITNESS: To answer it honestly. I don't 
20 
know specifically that he owns any of the 
21 
residences, to be honest. I would only assume that 
22 
he owns. So if you want me to answer honestly. I 
23 
don't know that he owns any of the other. 
24 
BY MR. EDWARDS: 
25 
Q. Okay. Well, what would be the basis for your 
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25 
assumption that he owns the home in Pakn Beach? 
2 
A. He goes there, but I don't assume -- you don't 
a 
have to own a house to go to it. 
Q. And not only does he go there, you're aware 
that he spends the night there: he resides there 
6 
sometimes, correct? 
A. Yes. 
5 
0. When he's in Palm Beach, Mat's where he —
9 
A. He sloops. 
10 
0. 
sleeps? Right. When he's in New York, do 
11 
you know where he sleeps? 
12 
A. No. 
13 
Q. But you've been to a particular house in New 
14 
York that's a very large house that we've all read about 
15 
that you picked up luggage at, right? 
16 
A. Yes, sir. 
17 
MR. CRITTON: Form. 
18 
BY MR. EDWARDS: 
19 
0. And that home, do you know that — I know that 
20 
you're saying that you haven't done a public record 
21 
search to make sure that Jeffrey Epstein owns it. 
22 
A. Yeah. 
23 
0. But you assume that he does? 
24 
A. Assuming. 
25 
0. That's where he sleeps when he's in New York? 
1 
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11. 
12 
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15 
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O. Am those private airports? 
A. Public. 
O. Public, okay. Are there any private landing 
places where you would land any airplanes in New Mexico? 
A. There are. 
0. That you have landed 
A. That I have. 
0. - his airplane? 
A. Yes. 
0. Where? 
A. We have a 4500-foot strip on the ranch. 
0. When you say 'we.' yourself and somebody' 
A. The company. 
Q. What company? 
A. Well. I should say I see where you're going 
waft that. The ranch owns — whoever owns the ranch. 
The ranch has a runway on it. 
Q. Okay. And you've landed an airplane on that 
noway? 
A. That ranch. yes. 
Q. How many times do you think you've landed 
there? 
A. Ten. 
Q. All right. And have you been inside his 
ranch? 
26 
MR. CRITTON: Form. 
2 
THE WITNESS: I assume. 
3 
BY MR. EDWARDS: 
4 
0. That's where his luggage is when you pick it 
6 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
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25 
up? 
A. Doesn't mean he owns It. 
0. Right. But that's where it is? 
A. Yes, sir. 
0. Do you know of anybody else who owns that home 
in New York? 
A. No. 
0. Okay. Have you been to his ranch in New 
Mexico? 
A. Yes. 
MR. CFUTTON: Form. 
BY MR. EDWARDS: 
0. How many times have you been to his ranch in 
New Mexico? 
MR. CRITTON: Form: predicate. 
THE WITNESS: A guesstimate. fifty times, only 
due to the fact that we would fly there. 
BY MR. EDWARDS: 
0. And where would you land? 
A. Depending upon the aircraft, either 
Albuquerque or Santa Fe. 
28 
1 
A. Yes. 
2 
MR. CRITTON: Form to the last question. 
3 
MR. REINHART: Can you clarify, the physical 
4 
ranch or the residences or the structures on the 
5 
ranch? 
6 
MR. EDWARDS: I don't have a good visual 
7 
appreciation for it. 
8 
BY MR. EDWARDS: 
9 
Q. Why don't you describe it in your words what 
10 
this ranch Mal We are talking about looks like. And 
11 
I've heard it referred to as the Zorro Ranch. Have you 
12 
heard that? 
13 
A. I've heard that. 
14 
0. That's the ranch we're all familiar with, 
15 
we're talking about where the runway is and everything 
16 
else? 
17 
A. Yes. 
18 
0. Describe it in your own words, the landscaping 
19 
of this ranch. What do we have on it? 
20 
A. There is a house up on the hal, a large 
21 
house. 
22 
O. How big? 
23 
A. Big. I've read 40,000 square feet In the 
24 
paper. 
25 
O. Have you been to it? 
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October 15, 2009 
29 
1 
A. Yes. 
2 
Q. Does that seem like it's feasible, 
3 
approximately 40,000 --
4 
A. I think so. yes. 
5 
Q. What else do we have on it? 
6 
A. There Is a compound that hes kind of motel 
7 
room type -- they call it bunkhouse. 
8 
0. Where's the bunkhouse located? 
9 
A. At the entrance to the ranch. 
10 
0. Okay. And what Is that primarily used for? 
11 
A. For the people that work on the ranch, they 
12 
reside there. It's also a place where anybody that 
13 
traveled on the airplane would stay. It's lTd of Eke, 
14 
you know, a hotel room. 
15 
0. And how far is that from the first house that 
16 
you deserted, the 40.000 square foot house? 
17 
A. Its probably 4 miles. 
is 
Q. Okay. So the Zone Ranch is a rather large 
19 
area of property? 
20 
A. Yes. 
21 
0. And how many times 
I know we just talked 
22 
about how many times you've been In the house, but how 
23 
many times have you been on that ranch in New Mexico, 
24 
the Zorro Ranch? 
2s 
A. Thirty to fifty times over the years. mars 
31 
1 
A. Yes. sir. 
2 
Q. And he sleeps there? 
3 
A. 
4 
Q. 
A. 
6 
0. 
7 
A. 
8 
Q. 
9 
MR. CRI1TON: This Is really --
10 
BY MR. EDWARDS: 
11 
0. Other than the pool heater in 1995. have you 
12 
ever received any other gifts on top of the compensation 
13 
from Mr. Epstein? 
14 
A. I did get land on the ranch to build a house. 
15 
Q. What do you mean you got land on the ranch? 
16 
A. He deeded me land to build a home. 
17 
Q. When was that? 
1$ 
A. Ten years ago at least 
19 
Q. Do you know 4 he's ever deeded anyone else in 
20 
this world land on the ranch to bultd a home? 
21 
A. Not to my knowledge. 
22 
0. Why did he do that? 
23 
A. We would vacation out there and my wife Ion 
24 
In love with New Mexico and we were looking for 
25 
property. 
Yes. 
Okay. 
I assume he does. 
You assume he sleeps? 
I do. I think. 
Okay. 
30 
1 
a guesstimate. 
0. Is that over 
when was the first time that 
you went to that ranch? 
A. A guess, I don't know when it was. actually, 
E.. 
our first trip, but 1995/94. 
Q. Okay. And do you believe Jeffrey Epstein 
7 
and/or a corporation owned or controlled by him to be 
8 
the sole owner of that ranch? 
9 
A. I don't know any of those details. 
10 
Q. Have you ever talked to Jeffrey Epstein about 
11 
who owns that ranch? 
12 
A. No. 
13 
0. Do you know of anybody else who may own that 
14 
ranch? 
15 
A. Not to my knowledge. 
16 
Q. Other than Jeffrey Epstein, do you know of 
17 
anybody else who regularly stays there when they're in 
18 
New Mexico? 
19 
A. Not to my knowledge. 
o 
Q. Does Jeffrey Epstein stay there when you're In 
21 
New Mexico? 
22 
A. He has. 
23 
Q. And he has a key to the place? 
24 
A. I don't know if there's a key. 
25 
Q. One way or another, he gets in, right? 
2 
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32 
0. And did you talk to him about that? 
A. Yes. He knew I •• he was aware I was looking 
for a home and he says, 'Well, I have so much land. I 
could (PO you a spot to build a home on.' So I built a 
house. 
0. So how long has a home actually been on that 
ProPeffn 
A. Nine years. 
Q. And !hats a home that you own? 
A. Yes. sir. 
O. And that's a home that was 
when I say 'you 
own it" Is there a mortgage on it or did he give 4 to 
you free and clear? 
A. No, no, I paid for the house. I made payments 
on it. 
0. All right. So what did he actually give you? 
A. 4O-acres of land. 
0. That you did not have to pay for? 
A. You know. I'd have to go back and look I 
think it was — I had to pay something for it I don't 
remember. 
Q. How often have you visited that piece — that 
home that you own? 
A. My wife would spend summers out there with the 
kids. 
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Larry Visoski 
October 
15, 
2009 
33 
Q. Okay. But that's on the Zorro Ranch? 
2 
A. Yes. 
3 
Q. So in addition to the 50 or so times you've 
4 
been to the Zono Ranch, you've been to your property 
that's on the Zorro Ranch? 
6 
A. Yes, which over the years, Ws once-a•year 
7 
vISIta. So I mean, it is included in the 50 times that 
8 
I've been there. 
9 
0. Okay. And cad you have a conversation with 
10 
htrn that led to him giving you or gifting you 40-acres 
11 
of land? 
12 
A. We talked about it because he knew I was 
13 
looking fora home out there. 
14 
Q. Okay. In gifting you that land, did you 
15 
consider yourself at that point in time to be more than 
16 
just his pilot, as more of a friend? 
17 
A. No. You're using the word *gifting.' I paid 
18 
for the land. I don't recall what it was. But you use 
19 
ttre word 'friend.' I don't know that a -- sure• he was 
20 
a friend. I mean... 
21 
0. Well, did he give Dave Rogers any land out on 
22 
the New Mexico ranch? 
23 
A. No. 
24 
0. Okay. When you say you paid for it, I thought 
25 
that I asked that question, "Did you pay for the 
1 
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a 
9 
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35 
A. 1800 square feet. 
0. Were you ever at that house at the same time 
when he's at his house that's on that Zorro Ranch? 
A. Yet 
O. All right. We started back in 1991 with you 
making around $55,000 a year and that has progressed 
over tine to a point where in 2007 you were making 
$200,000 a year. I don't want to go through every 
single year; that would take a really long time. But 
the progression, was that on a yearly basis normally or 
after two years or three years? 
A. Yearly basis. 
0. Okay. And would that normally be in 
increments of? 
A. $5,000. 
0. Okay. You've talked about a couple other 
gas that have been given to you from Jeffrey Epstein 
over the years: one is a pool heater in 1995 and now 
some 40 acres of land on his New Mexico ranch. Any 
other gifts you can think about? 
A. No other gifts. 
Q. Okay. I don't want to split hairs with you. 
You obviously thought about that answer before giving 
it. What other Items are you thinking about that he's 
given to you or cut you a discount on or otherwise that 
34 
40•acres?" I thought your answer was, don't know, 
rd have to go back and look.' 
3 
Are you saying now that you did pay for that 
land? 
A. I don't remember. If there was a sum of 
6 
mOney, It was just for, you know. the legal purpose of a 
transfer of ownership of the lend. 
0. Okay. If 4 was a substantial amount of 
9 
money, that's something that you would have remembered? 
10 
A. Oh, exactly. No. It was not a substantial 
11 
amount. 
12 
Q. Okay. Do you remember approximately how much 
13 
money you had to give Jeffrey Epstein for that land? 
14 
A. I would only be guessing. ft might have been 
15 
five defiers. To my knowledge, 1 don't remember. 
16 
0. Okay. So when I'm saying he gave you the 
17 
land, he may have actually given you the land? 
to 
A. Sure. 
19 
0. Okay. And to the best of your knowledge. he's 
20 
never given anyone else land out there? 
21 
A. Not to my knovrtadgo. 
22 
MR. CRITTON: Form. 
23 
BY MR. EDWARDS: 
24 
0. All right. How big is this house that you 
25 
built on the ranch? 
1 
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5 
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7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
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23 
24 
25 
36 
you feel was compensation for you working for him? 
A. I drive a company car. I mean... 
O. Okay. What kind of car? 
A. A Hummer. 
0. You say 'a company car." That's owned by NES, 
LLC? 
A. No, I think the registration has Zorro 
Development on it. 
0. What is Zorro Development? 
A. I believe that's the ranch, or et least it has 
the name of the ranch. I don't know what the entity Is 
0. And It's your understanding that that's a 
company vehicle? 
A. Yes. 
0. And where Is that vehicle primarily garaged' 
A. At my bane. 
Q. In West Palm Beach or in the Zorro Ranch? 
A. No, here in West Palm Beach. 
Q. All right. And is there only one company 
vehicle that you're issued? 
A. Yes, sir. 
O. And is that something that was 
that you did 
net have to pay for? 
A. No. it's just something I drive. I mean, it's 
not titled to me or anything like that. It's just a car 
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Larry Visoski 
October 15, 2009 
37 
1 
that I drive. 
2 
0. All right You've worked ter him for 18 
1 
years. I don't even know how long the Hummer would 
4 
last, but presumably, that's not the car you've had over 
5 
the entire 18 years. Have you allays had a company car? 
A. No, I haven't, no. 
0. When did you get the Hummer? 
8 
A. Probably three years ago. 
9 
0. Do any other members of Mr. Epstein's piloting 
10 
team have company cars? 
13 
A. No. 
12 
0. Only you? 
13 
A. Yes. 
14 
0. And do you know how that decision was made to 
15 
get you a company vehicle? 
16 
A. No. 
17 
0. What do you use that vehicle for? 
18 
A. To and from the airport. 
19 
0. AU nght. Do you use it for personal reasons 
20 
also? 
21 
A. I guess. yea. 
22 
0. I mean, that's your primary vehicle? 
23 
A. Yes. or I drive my wife's car. 
24 
0. Which Is? 
25 
A. Type of car? 
1 
2 
3 
4 
5 
6 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
39 
0. And which airplane was that? 
A. The Hawker. 
0. Does he stilt have the Hawker? 
A. No. 
0. How long did he have that plane? 
0. Flve years. guesstimate: four or Ilve years. 
0. So sometime in the mid '90s? 
A. Yes. 
0. Did you keep any type of logs or documentation 
as to who would have been flying on that airplane if you 
transported any individuals? 
A. The same logs as you possess now are the 
Nght logs. 
0. Okay. 
A. That's the standard for the industry. 
Q. So that's something that you kept, or that 
Dave Rogers kept? 
A. Dave Rogers. 
0. Okay. If there are any documents out there 
with names of passengers on any of the flights involving 
planes owned or controlled by Jeffrey Epstein and/or his 
companies, those would be documents in the possession of 
Dave Rogers and not yourself? 
A. Oh, the corporation actuay, they belong to. 
Q. Okay. 
38 
1 
O. Yes. 
2 
A. A Mercedes. 
3 
0. Ands that something that was also a gift 
4 
from Mr. Epstein? 
5 
A. No, sir. 
6 
0. What type of Mercedes Is that? 
7 
A. AML 430, ten years old. 
O. MI right. Are there any other items —
9 
company car, the land In New Mexico, the pool healer —
30 
any other items that Mr. Epstein has given you over time 
11 
as compensation or reward or anything else? 
12 
A. No. sir. 
13 
0. And your only income is from Mr. Epstein or 
14 
his companies? 
19 
A. Correct. 
16 
0. Okay. And It's been that way since 1991? 
17 
A. Yes. 
18 
0. How did you meet Mr. Epstein or became 
19 
involved with him in 1991? 
20 
A. We heard at the airport that Mr. Epstein was 
21 
purchasing an airplane when Dave Rogers and myself were 
22 
living in Columbus, and we had the opportunity to 
23 
interview with him, and we did and got the job. 
24 
O. And this is before he owned the airplane? 
25 
A. Yes. 
40 
1 
MR. REINHART: That was a compound question. 
2 
You might want to split it In half. 
3 
MR. EDWARDS: Okay. 
4 
BY MR. EDWARDS: 
S 
Q. What documents do you believe exist that 
6 
indicate names of individuals that have been passengers 
7 
on Mr. Epstein's airplanes? 
MR. REINHART: Are we going back all the way 
9 
from '91 to the present? 
10 
MR. EDWARDS: Sire. 
11 
THE WITNESS: You're talking about the Hawker? 
12 
BY MR. EDWARDS: 
13 
0. Any airplanes. What documents would there bo? 
14 
A. There would be the same: Right logs and 
15 
passenger manifests would exist. 
16 
0. And are either of those required? 
17 
A. The flight log is required for the aircraft to 
18 
track times and landings. 
19 
0. And In the flight log. is it required that you 
20 
designate the names of the passengers? 
21 
A. No. 
22 
0. That's just something that Dave Rogers did on 
23 
his own? 
24 
A. Everybody does that. ICs more for Internal 
25 
Revenue. 
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October 15, 2009 
41. 
1 
0. Okay. If something happens, they know who is 
2 
on the plane? 
3 
A. Exactly, weight and balance. 
4 
0. Have you ever kept any flight logs that have 
5 
names of people on the airplane? 
6 
A. When you say 'kept? I have filkxl out flight 
7 
logs or the passenger manifest, yes. 
8 
0. By 'kept' I meant maintained to where they're 
f/ 
in your possession either on paper or computer? 
10 
A. We keep --
11 
MR. REINHART: Can you differentiate a flight 
12 
log from the plot's log that we showed you 
13 
earlier? 
14 
MR. EDWARDS: Okay. 
15 
BY MR. EDWARDS: 
16 
0. I'm talking about -- I dont know that Ws 
17 
called a flight log. a pilot's log or any kind of fog. 
18 
A. They are different. yea. 
19 
0. Yeah. I'm asking about, have you kept or do 
20 
you have any documentation that would indicate the names 
21 
of passengers that have flown on any of Jeffrey 
22 
Epstan's planes? 
23 
A. No. 
24 
0. Either in the form of paper or on a computer? 
25 
A. No. 
43 
1 
A. Jeffrey would always critique Dave's flying 
2 
capabeities, and I tried to help Dave and explain to 
3 
him what Jeffrey likes and doesn't like. And Jeffrey's 
4 
also conveyed these likes and dislikes. And Dave 
maintained continuing with certain piloting techniques 
6 
that were just not comfortable to passengers. And this 
7 
went on through the years. and Jeffrey just got tired of 
it one day. 
9 
0. What specifically were Jeffrey Epstein's likes 
10 
and dislikes with respect to the flight of the plane? 
11 
MR. CRITTON: Let me put in a form here. But 
12 
I don't know what this has to do with anything in 
13 
this case. 
14 
MR. EDWARDS: I understand that, Bob. 
15 
MR. CRITTON: I want to use this for some 
16 
other depositions where we -- we've gone beyond the 
17 
wope. 
18 
THE WITNESS: The case In point, the last 
19 
straw was there was a technique called quiet flying 
20 
where you would retard the throttles well short of 
21 
the runway and pretty much glide the airplane in 
22 
Well, if you don't do that correctly, you have to 
23 
spool the engines up just prior to touching down 
24 
that -- because you're losing air speed and it's an 
25 
uncomfortable sound and feeling for the passengers 
42 
1 
0. Makes that easy. 
2 
A. Okay. 
3 
0. In 1991, were you the chief 0100 
4 
A. No. 
5 
0. Somebody else was the chief pilot? 
6 
A. Yes. 
7 
Q. Who's that? 
8 
A. Dave Rogers. 
9 
0. All right. At what point in time did you 
10 
become chief pilot and switched with Dave Rogers? 
11 
A. Six years ago; five, six years ago. 
12 
0. Why? 
13 
A. Professionalism, technique. 
14 
0. What do you mean by that? 
15 
A. The way Dave would operate an aircraft. 
16 
Jeffrey knew the difference when I was flying and when 
17 
Dave was flying. 
18 
0. How do you know he knew the difference? 
19 
A. Just --
20 
0. He told you? 
21 
A. Yes. He knew the difference that if ho never 
22 
came up front, he knew who was flying, who landed. 
23 
0. And what was the conversation that he had with 
24 
you that resulted in you becoming chief plot, switching 
25 
positions with Dave Rogers? 
44 
1 
thinking that you're not going to make the runway. 
2 
And it was a continuous practice of Dave doing that 
3 
to be neighbor friendly as opposed to being 
4 
passenger-comfort friendly. 
5 
BY MR. EDWARDS: 
6 
0. Okay. 
7 
A. Hence, the transfer of power. 
8 
0. Has he ever discussed with you where he wants 
9 
you to be, whether that is -stay in the cockpit when I 
10 
have people on the airplane," or don't intermingle with 
11 
the passengers or anything else? 
12 
A. He's never stated that to us. 
13 
MR. REINHART: Could you clarify which "h0 
14 
you're talking about? 
15 
MR. EDWARDS: I'm talking about Jeffrey 
16 
Epstein. 
17 
MR. REINHART: ()Say. 
18 
BY MR. EDWARDS: 
19 
Q. You understood that? 
20 
A. Yes. 
21 
0. It's my understanding that in the -- wall 
22 
tell me other than the Hawker, what other airplanes have 
23 
you flown for Jeffrey Epstein? 
24 
A. A Gulfstream. 
25 
0. Does he still have that plane? 
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Larry Visoski 
October 15, 2009 
45 
A. Yes, sir. 
O. How bier:deplane is that? 
A. Large corporate Jet. 
O. How long has he had it? 
A. Fourteen years; 13.14 years. 
O. And other than the Gulf stream, what other 
airplanes does he have? 
A. When you say she; obviously. these are 
company-owned --
O. Jeffrey Epstein or his companies. 
A. A Boeing 727. 
22 
O. Wee, I know that's a very large airplane. I 
13 
think that's been described by other people, so I'm not 
14 
going to have you do that But there's partitions In 
15 
that airplane in the back rooms of that airplane. 
16 
right? 
17 
A. Yes. 
Is 
O. Several different partitions to where if the 
19 
pilot comes out of the cockpit, you don't necessarily 
20 
see ell the passengers? 
21 
A. Yes 
22 
O. Thars true? 
23 
A. Yes. 
24 
O. Okay. 
25 
MR. REINHART: Keep your voice up so she can 
1 
2 
3 
4 
6 
7 
a 
9 
10 
12 
21 
13 
14 
15 
16 
17 
3.0 
19 
20 
21 
22 
23 
24 
25 
47 
and who was on the flights? 
A. One flight I believe we went to Sebring and 
another flight we went to Nassau, Bahamas. 
O. And who did you go to Nassau, Bahamas with? 
A. I'd have to look at the flight log, but I 
think It wa
I behave. I think 
that was the three passengers. to the best of my 
knowledge. 
O. And ills my understanding that little 
St. James is an island that Jeffrey Epstein owns or 
controls? 
MR. CRITTON: Fenn. 
THE WITNESS: I don't know that he owns it. 
BY MR. EDWARDS: 
O. Has he ever been to an island called Little 
St. James? 
A. Yes. 
O. And have you been there with Jeffrey Epstein? 
A. I've been there when he was there. 
O. Have you flown on an airplane with him to that 
destination? 
A. No. 
O. AP right. When you say you've been there 
when he was there, how did that come about? 
A. We flew into St Thomas and then we flew to 
46 
hear you. 
THE WITNESS: Oh. 
MR. REINHART: And so Mr. Willits can hear 
you. 
BY MR. EDWARDS: 
O. Other than the Gulfstream and the Boerig and 
the Hawker, what other airplanes has Jeffrey Epstein 
owned over the years? 
A. Thetis& 
I 0 
O. And currently still owns or the companies 
11 
associated with him own the Gultstream and the Boeing? 
12 
A. Yes. 
13 
O. And in the past two years, have you flown 
14 
those two airplanes? 
15 
A. Just for routine flights to keep them loose 
16 
or, you know 
you know what I mean. 
17 
O. Have those two airplanes been flown by anyone 
113 
else in the last two years? 
19 
A. No. 
20 
O. Have those two airplanes been flown In the 
21 
last two years for any reason other than routine 
22 
maintenance-type flights? 
23 
A. We've had one 
two flights I think in the 
24 
past two years. 
25 
O. And what were the purposes of those flights 
48 
1 
Little St. James In a helicopter. 
2 
O. And do you fly the helicopter as well? 
3 
A. Yes. 
4 
O. How many helicopters are owned or controlled 
5 
by Jeffrey Epstein and/or corporations associated with 
6 
him? 
7 
MR. CRITTON: Form. 
THE WITNESS: At this time. one. 
9 
BY MR. EDWARDS: 
10 
O. And has that helicopter been flown in the last 
11 
two years? 
12 
A. Just for routine maintenance. 
13 
Q. And when you and let's say when 
14 
ME and Story Cowells and
 flew torsau. do 
15 
you know the purpose of that trip? 
16 
A. No. 
3.7 
O. How long did you Way? 
18 
A. Five hours. 
19 
O. Did you pick anybody up there? 
20 
A. No. Meaning passengers? 
21 
a 
Yes. 
22 
A. NO. 
23 
O. What happened? You landed the airplane and 
24 
then what? 
25 
A. The passengers left. Dave and I went and had 
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Larry Visoski 
October 15, 2009 
49 
lunch. The passengers showed up and we came back. 
2 
0. Have you ever stayed at the home that is on 
Uttle St. James? 
A. No. 
5 
a 
Have you known Jeffrey Epstein to stay at that 
6 
home? 
A. I don't know that fora fact. 
a 
0. Okay. Do you believe that he is the owner or 
9 
controller or has some interest in the home or the 
10 
island of Utile St. James? 
11 
MR. CRITTON: Form. 
12 
THE WITNESS: I have no knowledge of that 
13 
being a fact. 
14 
BY MR. EDWARDS: 
15 
0. And you have no belief that that is a fact? 
16 
A. Exactly. 
17 
0. When you say you've been there when he was 
18 
there, how many times has that occurred? 
19 
A. Estimating, a hundred times. 
20 
0. Okay. 
21 
A. Trying to give an honest answer. 
22 
0. Okay. And in the approximate 
rm not going 
23 
to hold you to a hundred times• but in the approximately 
24 
hundred times —
25 
A. Sure. 
51 
I 
to his Island? We never landed on Ns Island. We 
2 
landed In St. Thomas. 
3 
0. Got it. 
4 
A. I was just trying to be exact. 
5 
0. Thank you. 
6 
A. It's a small island. 
7 
0. Okay. So how is it that when Mr. Epstein 
8 
wants to go to Little St. James. what is the path that 
9 
you take to got actually to the island of Little 
10 
St. James? 
11 
A. I don't understand the question. 
12 
0. Well, you just told me you fly the airplane to 
13 
St. Thomas? 
14 
A. Right. 
15 
0. And then what? 
16 
A. Then sometimes I would go get the helicopter 
17 
or he could also take a boat to the island. But 
18 
normally the helicopters located on St. Thomas. rd 
19 
fire up the helicopter, come pick him up, drop him at 
20 
the Island and I come back to St. Thomas. 
21 
0. And when he stays on St. James. you drop Nth 
22 
of on St. James. I suppose you're going to tell me you 
23 
don't know if he slays there or not? 
24 
A. Exactly. 
25 
0. But do you stay 
50 
0. 
for what period of lime are we talking 
2 
about? 
A. During what period of time? 
Q. Right. 
A. Let's see, when did all this happen? What, 
6 
2007? So eight years prior to whenever he stopped 
flying. So... 
8 
Q. W99? 
9 
A. Yeah, I guess. yes. 
10 
0. I mean, that sounds lace a right 
11 
A. Sounds about right, yeah. Don't hold me to it 
12 
again. 
13 
0. All right. 
14 
A. You're going beck a long way. 
15 
0. So from approximately the 198/99 time frame 
16 
when Jeffrey Epstein would fly to Little St. James, 
17 
would you be the pilot? 
18 
A. Yes. 
19 
Q. Okay. And you say that you've been there — I 
20 
thought that you Just told me that you've been there the 
21 
same time he was there. but then I thought the 
22 
subsequent question was well, were you on the flight 
23 
with him, and I thought your answer was no. Maybe I 
24 
misunderstood that. 
25 
A. No, you said the question "Have you ever flown 
52 
A. I don't. I mean .-
2 
0. Well, he either stays there or someone else 
1 
picks him up in a helicopter or he swims away? 
4 
A. Coned. 
5 
0. Okay. You stay on St. Thomas? 
6 
A. Yes. 
0. Okay. Is there a place that you've stayed on 
8 
61. James. even 
9 
A. No, rve never. 
10 
0. So in the hundred or more times that you've 
11 
been to the island, Is it my understandng that each of 
12 
those times you've been there to drop of Jeffrey 
13 
Epstein and'or any passengers and you've immediately 
14 
left and gone to St. Thomas? 
15 
A. Yes, sir. 
16 
Q. You never been inside that home that's located 
17 
an SL James? 
Is 
A. Yes, I've been inside the NOM/ 
19 
0. How many times have you been inside the home? 
20 
A. I mean, ten, fifteen times. 
21 
Q. And for what occasion? 
22 
A. I've set up the theater system that's in the 
23 
living room. 
24 
0. Okay. 
25 
A. So it would be there to work to hook up a TV 
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Larry Visoski 
October 15, 2009 
53 
1 
or a stereo. 
2 
Q. And do you knew Les Wexler? 
3 
A. No, I don't. 
4 
Q. Have you ever met him before? 
5 
A. I have met him. 
6 
Q. Do you know of any relationship between Los 
7 
Wexler and Jeffrey Epstein? 
8 
A. I don't know what — to what extent they have 
9 
a relationship, no. 
10 
Q. Do you know if they know one another? 
11 
A. I don't know that for a fact. They talk to 
12 
one another, so I would assume. But I don't know to —
13 
Q. How do you know they talk to one another? 
14 
A. I've seen them speak to one another at the 
15 
foot of the airplane. 
16 
Q. All right. Have you ever flown the 
17 
airplane 
any of the airplanes with Les Wexler as a 
18 
passenger? 
19 
A. No. 
20 
Q. Have you ever flown the airplanes will
21 Ma 
as a passenger? 
22 
A. Yes. 
23 
Q. And do you knottla 
24 
A. Yes. 
25 
Q. And for how long have you knowrar 
54 
55 
1 
Q. It seems b be I mean, you seem Ike 
2 
somebody Mite has common sense. It seems like somebody 
3 
that knows Jenny Epstein? 
4 
MR. CARTON: Form. 
BY MR. EDWARDS: 
0. Correa..? 
7 
A. Yes. 
Q. All right. And do you believe that there is a 
9 
business relationship there or a personal relationship 
10 
there, from your observations? 
11 
A. rd only be speculating. When they get on the 
12 
airplane. my focus is forward and flying safety. So I 
13 
don't — you know. I'd only be guessing at either one of 
14 
those Iv o. 
15 
0. Okay. Have you ever socialized wit.. 
16 
17 
16 
19 
20 
21 
22 
23 
24 
25 
MR' 
A. No. 
Q. Other than speaking with her on the airplane, 
have you spoken with her eisewhere? 
A. Over the phone, in passing. I mean, walking 
down the street In New York. I mean, yes. 
Q. Why would you cal
 or why would 
she cal you? 
A. She would call me to schedule the aircraft for 
a departure. 
A. I'm guessing, six years. I mean, don't hold 
2 
me to it. I'm not the greatest on length of times, but 
3 
six, seven years, I think. 
4 
0. Flow did you moot her? 
A. I guess I was introduced. She was on a Bight 
6 
of ours. 
0. You were introduced to her by whom? 
A. She may have introduced herself. I mean, 
9 
you're going back a ways. I don't know the official 
10 
introduction, how it went. 
11 
Q. And to your knowledge, what is her is she 
12 
associated or affiliated in some way with Jeffrey 
13 
Epstein? 
14 
MR. CRITTON: Form. 
15 
THE WITNESS: I would assume so. I don't know 
16 
to what level or what actually her job description 
17 
Is. 
MI 
BY MR. EDWARDS: 
19 
Q. All right. Well, how many flights have you 
20 
flown where she and Jeffrey Epstein have been passengers 
21 
together on one of the airplanes that we've been 
22 
&cussing? 
23 
A. I'd only bo guessing again. 
24 
O. We're talking hundreds of flights, though? 
25 
A. Sure. sure, a lot of Illshts. 
56 
1 
Q. And have you ever called her? 
2 
A. Yes. 
3 
Q. When's the last time you talked W=1 
4 
Mi? 
5 
A. A week ago. 
6 
Q. What was the occasion? 
7 
A. We were discussing carpet for one of the 
8 
aircraft. 
9 
Q. And where was she when you were talking with 
10 
her? 
11 
A. I don't know. tt was over the phone. 
12 
Q. Dld she call you or you call her? 
13 
A. No, I called her on her cell. 
14 
Q. Okay. And that's a New York number? 
15 
A. I don't know. It's on speed dial. 
16 
Q. Do you have your phone with you? 
17 
A. Yes. 
18 
O. Could you tel me what that number is? 
19 
A. SUre. 
20 
0. Thanks. 
21 
A. Sure. 
22 
Q. WNch airplane were you discussing carpeting 
23 
for? 
24 
A. Was actually -- actually. It was for the 
25 
helicopter. Now that I'm thinking about ft. the 
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Larry Visoski 
October 15, 2009 
57 
t 
helicopter. 
2 
Q. In the last two years, did you tell me the 
3 
helicopter has flown? 
A. Yes. 
5 
O. And where to? 
6 
A. I have flown the helicopter to Fort Lauderdale 
on several occasions for maintenance. rve flown it to 
s 
Miami. And I try to fly the helicopter at least every 
9 
two weeks Just either by myself to run it up to its —
10 
it's Important that it keeps moving. 
11 
O. Other than maintenance-type flights, have you 
12 
flown the helicopter in the last couple of years? 
13 
A. Yes. 
14 
O. And who was on the helicopter? 
15 
A. I flew to Miami with Mr. Epstein. 
16 
0. When was that? 
17 
A. It was a couple weeks ago or a month ago, I 
15 
think. 
19 
O. For what? 
20 
A. Sony? 
21 
O. For what occasion? 
22 
A. I think he had a meeting with his attorneys in 
23 
Miami. 
24 
0. Today is October the 15th. Is this during the 
25 
month of October that you had this flight in the 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
Ia 
19 
20 
21 
22 
23 
24 
25 
59 
O. How long have you known 
A. I don't know, five years. A guess again. 
four, five years. 
O. Do you know what her relationship is, if any. 
with Jeffrey Epstein? 
A. I do not know. 
O. Do you 'mow if she knows Jeffrey Epstein? 
A. I would assume so. They tare_ I would 
imagine she knows him. 
O. And how many times has she been on the 
arplane or the helicopter on flights at the same time 
as a passenger with Jeffrey Epstein? 
A. Many. I'd have to look at the logs. 
O. Hundreds of times? 
MR. CRITTON: Form. 
THE WITNESS: Sure. 
BY MR. EDWARDS: 
O. If you were going to, as somebody who has been 
Jeffrey Epstein's pilot for 18 years, tell me today who 
the five closest people are to Jeffrey Epstein, would 
IMbe one of them? 
MR. CRITTON: Form. 
THE WITNESS, I'd only be guessing and 
speculating. I have no idea. 
58 
1 
helicopter with Mr. Epstein? 
2 
A. I'd have to look at the book to be exact for 
3 
you. 
4 
Q. Okay. But it's either the end of September or 
5 
the beginning of October? 
6 
A. Yeah. 
7 
O. How do you know that ho was meeting with his 
8 
attorneys? 
9 
A. I believe that he had mentioned that he was 
10 
meeting his attorneys. 
11 
Q. Did he tell you why? 
12 
A. No. 
13 
Q. Why did he tell you he was meeting with his 
14 
attorneys? Did you ask him? 
35 
A. No. 
16 
O. Okay. That's just something that he said to 
17 
you in conversation? 
A. Yes. sir. 
19 
Q. Was there anyone else on the airplane besides 
20 
you and Mr. Epstein? 
21 
A. Yes. 
22 
O. Who was that? 
23 
A. 
24 
O. 
who? 
25 
A. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
1e 
19 
20 
21 
22 
23 
24 
25 
60 
BY MR. EDWARDS: 
O. Okay. Well, as his pilot and the person who 
travels with Jeffrey Epstein on the majority of his 
flights, who are the people who travel most frequently 
with Jeffrey Epstein? 
A. I'd have to look at the logs. 
MR. REINHART: Can we get a time period? 
BY MR. EDWARDS: 
O. In the last ten years, which people travel 
most frequently with him? 
A. I'd have to look at the flight logs to give 
you an accurate answer. 
O. You can't give me one single name of somebody 
who you would say is a frequent flyer? 
A. 
O. 
A. Yes. 
O. 
else? 
O. 
A. Yeah. 
O. Okay. Anybody else? 
A. Just mainly those two. 
Q. How about Ghislaine Maxwell? 
A. Not for some time. 
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October 15, 2009 
61 
1 
0. What's your understanding between the 
2 
relationship of Sillslathe Maxwell and Jeffrey Epstein? 
3 
A. I don't really know. 
4 
0. AM right. So when oi
ly
 say you're guessing 
the 
a 
know or are 
6 
associated with Jeffrey Epstein, that guess Is being 
7 
made on the 
with the observation that they have been 
8 
frequent flyers with Jeffrey Epstein on more than 
9 
hundreds of flights on his private plane? 
10 
A. Yes, that's what I'm b 
• 
it on. 
11 
Q. And do you know whet 
Is 
12 
staying these days? 
13 
A. No. 
14 
0. Do you know what car she's driving these days? 
15 
A. No. I don't. 
16 
0. Okay. Do you know if she's Wing with 
17 
Jeffrey Epstein these days? 
18 
A. I don't know that. 
19 
Q. Do you 3310W howe 
met Jeffrey 
20 
Epstein? 
21 
A. I don't. 
22 
0. Were you on an international flight bringing 
23 
her into the country horn some other country at any 
24 
time? 
25 
A. I don't know. 
63 
I 
Miami? 
2 
A. Twenty-five minutes. 
3 
0. And did they talk to one another during that 
4 
tier? 
5 
A. No. 
6 
0. They were both completely silent during that 
7 
flight? 
8 
A. Yes. 
9 
0. Okay. Is that typical when they are on 
10 
flights together. especially with the helicopter, whore 
11 
you're in pretty close quarters, that they would ahciain 
12 
from speaking to one another? 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: Yeah, it would be typical. Irs 
15 
very noisy and communicating in a hohcopter is. 
16 
you know, not that comfortable. 
17 
BY MR. EDWARDS: 
18 
0. Over the last five 
or•
• 
have 
19 
known or been familiar with 
have you 
30 
heard her and Jeffrey Epstein conversing with one 
21 
another? 
22 
A. I've heard them conversing, but if you ask me 
23 
what they had said, I could say it -- I wouldn't even 
24 
know what they had said to each other. I've seen them 
25 
talking to each other. 
62 
MR. REINHART: Can we clarify? You mean with 
Mr. Epstein or
3 
MR. EDWARDS: No. 
4 
BY MR. EDWARDS: 
0. Did you ever bring 
from some 
foreign country into the United States? 
A. I'd have to look at the log books, honestly. 
8 
0. That's not something you remember? 
9 
A. No. I mean, she I think she's been on 
10 
Europe trips with us. and I think she's returned from 
11 
Europe with us, but I could not say that hones . 
12 
0. On this recent helicopter flight with
13 
and Jeffrey Epstein, did you talk with them 
14 
during that flight? 
Is 
A. No. 
16 
0. Where rid the flight go from? And obviously, 
17 
it landed In Mlaml, but where did you leave from? 
18 
A. West Palm Beach. 
19 
0. And did= 
and Jeffrey Epstein arrive 
20 
together? 
21 
A. You know, I don't remember. I was out at the 
22 
helicopter and I think they both started walking up. So 
23 
I don't know if they came separately or not. I was 
24 
already at the heloopter. 
25 
Q. How long is that flight from Palm Beach to 
64 
1 
Q. But you don't remember a single 
lit 
2 
conversation between Jeffrey Epstein and= 
3 
4 
A. An honest answer, no. 
5 
0. Okay. And the same for 
have you 
6 
seen or have you seen Jell rey Epstein speak with 
IIIIIIk 
7 
8 
A. hoe seen him speak with her, yes. 
9 
Q. Can you tell me a single specific conversation 
10 
that 
ve overheard between Jeffrey Epstein and 
11 
12 
A. One thing that comes to mind would be make 
13 
sure we have Oreo cookies on the airplane. II would be 
14 
something completely nonchalant. 
15 
0. Okay. And do you know or have 
16 
of any employment relationship between 
17 
Jeffrey Epstein? 
16 
A. I have no kno 
0 of n of that. 
19 
Q. Do you know if 
works for Jeffrey 
20 
Epstein? 
21 
A. I do not know. 
22 
Q. Do you know it 
schedules massages 
23 
for Jeffrey Epstein? 
24 
A. I have no idea. 
25 
0. Has Jeffrey Epstein ever indicated to you that 
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Larry Visoski 
October 15, 2009 
65 
1 
he is fascinated or infatuated or appreciates or loves 
2 
or likes massages? 
3 
A. I have no knowledge of that. 
4 
0. All right. How about ObisSeine Maxwell, has 
5 
she ever talked to you about massage therapy or have you 
6 
ever overheard her talking about that? 
7 
A. No. 
0. You certainly read the papers over the last 
9 
couple of years, correct? 
10 
A. Not on my top ten list. I mean. I've read a 
11 
couple articles, but I'm not one to focus on that so 
12 
much as some people would. 
13 
0. Okay. When the h I1Esiigation about Jeffrey 
14 
Epstein came about, the criminal investigation 
you're 
15 
aware that's what I'm talking about. right? 
16 
A. That was last year? 
17 
0. Welk it was a couple years ago. 
18 
A. Right, okay. 
19 
O. Did you speak with Jeffrey Epstein about that 
20 
investigation? 
21 
A. No. 
22 
O. Were you told not to speak with him about that 
23 
investigation? 
24 
A. I think we knew ourselves that we weren't --
25 
It wouldn't be proper to even bring it up. 
2 
3 
4 
5 
6 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
67 
women? 
MR. CRITTON: Form. 
THE WITNESS: No. 
BY MR. EDWARD$: 
0. You think that this is just a story that a 
bunch of underage women hove made up? 
A. Speculation. 
MR. CRITTON: Objection. Nov Ws 
argumentative. Who gives a dam what he thinks cue 
way or another? If he has personal knowledge —
MR. EDWARDS: You're objecting to the form? 
MR. CRTITON: It's argumentative. 
MR. EDWARDS: You're objecting to the form' 
MR. CRITTON: Yes. 
MR. EDWARDS: Okay. 
BY MR. EDWARDS: 
0. Is that something that you believe that a 
bunch of women 
some of which know each other, some 
don't, some of which have been on the airplane and some 
which haven't -- made this up, that Jeffrey Epstein 
engaged in some sexual conduct with them? 
MR. CRITTON: Form. 
THE WITNESS: What I believe doesn't matter in 
this case, does It? 
66 
0. All right. When you read In the newspapers 
2 
the allegations that Mr. Epstein was involved with 
3 
numerous underage girls for sexual reasons, were you 
4 
surprised? 
A. I didn't believe it. 
6 
Q. Do you believe d today? 
A. I don't believe it. 
0. You don't believe that Jeffrey Epstein was 
9 
Involved with underage girls in a sexual way? 
10 
MR. CRITTON: Form. 
11 
THE WITNESS: You're asking for my opinion, 
12 
and I don't think my opinion Is relevant In that 
13 
matter. 
14 
BY MR. EDWARDS: 
15 
O. I think it's relevant. Can you just tell me 
16 
whether today you believe that Jeffrey Epstein has 
17 
engaged In sex with underage girls? 
18 
MR. CRITTON: Form; speculation. irrelevant, 
19 
always. 
20 
THE WETNESS: Ifs Irrelevant. 
21 
BY MR. EDWARDS: 
22 
Q. I need an answer. 
23 
A. I don't believe he had sex with underage 
24 
women. 
25 
Q. Or engaged in any swami acts with underage 
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68 
BY MR. EDWARDS: 
0. I need an answer. Do you believe It? Do you 
believe these girls made this up? 
MR. CRITTON: Form. 
MR. REINHART: I'm going to instruct him not 
to answer. Move on. 
MR. EDWARDS: Is there a privilege that we're 
asserting? 
MR. REINHART: No, It's irrelevant It's 
harassment and not likely to lead to discoverable 
evidence. 
MR. EDWARDS: I'm going to put on the record 
right now that it is -- we are allowed discovery 
into a RICO count. We are also allowed discovery 
Into the intent of Mr. Epstein in developing a 
criminal enterprise designed to sexually exploit 
and sexually abuse underage girls. We believe that 
In doing so, he associated intentionally with 
people of similar beliefs that sex with underage 
girls Is okay, and that there have been many 
discussions with this witness, as won as many 
other witnesses with - to insure his protection 
from law enforcement that they not answer these 
specific questions. And thus, the opinions and 
beliefs of all of these witnesses that we are 
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Larry Visoski 
October 15, 2009 
69 
alleging associated with this criminal enterprise 
2 
are certainty reasonably calculated to lead to the 
3 
discovery of admissible evidence. And if you're 
4 
still instructing the witness, based on that 
• 
proffer, not to answer any of these questions, inn 
6 
going to continue to ask the questions and you can 
7 
instruct him not to answer and we can go to the 
Court. 
9 
MR. REINHART: My response is to his opinion 
10 
whether people making allegations in this case are 
11 
Whiting or making up a story is Irrelevant to 
12 
what you just said. So I am going to instruct hkn 
13 
not to answer any question that goes to his opinion 
14 
of someone else's motivation or the truth of facts 
15 
to which he has no knowledge. 
16 
So yes, fin instructing him not to answer. 
17 
MR. CRITTON: Let me add in my part. Is that I 
18 
think -- you're certainly not only capable to ask 
19 
questions with regard to what his personal 
20 
knowledge Is, and if he knows something or he has 
21 
reasonable basis for it certainly you are entitled 
22 
to that Information. I think you've asked those 
23 
questions and he's given you straightforward 
24 
answers as to what he knew or what he didn't know 
25 
under those circumstances. And as to what his 
71 
1 
A. It's an opinion, and I behave that he has 
2 
not. 
3 
0. Okay. Isn't It true that at some point in 
4 
time you learned that Jeffrey Epstein has strike 
that. 
6 
MR. CRITTON: When you ultimately get to a 
7 
good place to break, wit you let us know? 
a 
MR. EDWARDS: Lefs break now. 
9 
(A break was had at 11:28 a.m.) 
so 
BY MR. EDWARDS: 
11 
0. All right. Eighteen years of being a pilot 
12 
for Jeffrey Epstein and in terms of being able to name 
13 
somebody that you would say youVe observed with Jeffrey 
14 
Epstein and would classify that person as Jeffrey 
15 
Epstein's friend, can you name anybody? 
16 
A. I-' 
just people that we see 
17 
routinely on the airplane. 
0. mars people you see routinely in the last 
19 
five to ten years, right? 
20 
A. Yes. 
21 
0. Prior to that time, anybody that you've 
22 
noticed as Jeffrey Epstein's friend may be Ghistaine 
23 
Maxwell? 
24 
A. What time frame? 
25 
O. Is that a person that at some point in time 
70 
thoughts are on something which he has no factual 
basis or even an assumption to know one way or 
another is irrelevant That's ultimately for a 
• 
fact-finder in this case. 
5 
While it's interesting, it's argumentative and 
• 
I don't think he's •-1 mean, do it on a
+
question-by-question basis. If he has knowledge. 
3 
thafs great, but to argue your case with this 
9 
witness or any other witness doesn't servo a 
10 
purpose and I think is, you know — I think ifs 
11 
not a good use of our time, Ill put it that way. 
12 
But you know, you can go ahead and ask. 
13 
MR. EDWARDS: I can ask the question and if 
14 
the witness is being instructed not to answer, 
15 
wallet a judge decide whether he needs to answer 
16 
the question and whether it's discoverable or not. 
17 
MR. REINHART: Absolutely. Make your record. 
10 
BY MR. EDWARDS: 
19 
0. Do you have any reason to bebeve that Jeffrey 
20 
Epstein engaged in sexual activity with underage women? 
21 
A. I have no reason to believe. 
22 
0. Okay. So as you sit here today, based on your 
23 
18 years of knowledge, experience and observation of 
24 
Jeffrey Epstein, is it your belief that he has not had 
25 
sex or engaged in sexual activity with underage women? 
72 
1 
you would classify as Jeffrey Epstein's friend? 
2 
A. I would dassify it. I don't know if it's 
3 
true. 
4 
O. But that's only because they were on iho 
s 
airplane together? 
6 
A. Yes. 
7 
0. Do you know whet Jeffrey Epstein dons for a 
8 
frying in your 18 years of observing and talking with 
9 
Jeffrey Epstein? 
10 
A. No. 
11 
0. No idea? 
12 
A. No. 
13 
0, Ever asked him? 
11 
A. No, actuary. 
15 
0. Ever boon curious? 
16 
A. Sure. 
17 
0. Ever done anything to satisfy that curiosity? 
le 
A. If you moan Googlo it, not realty, actually. 
19 
I mean. I realty have not. 
20 
0. Okay. So in 18 years of traveling and being 
21 
the pilot and driving — and taking this person, Jeffrey 
22 
Epstein. from one property in New York to New Mexico and 
23 
Florida and around the world, you have no idea what he 
24 
does in terms of how he makes money? 
25 
A. No, sir. 
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Larry Visoski 
October 15, 2009 
73 
0. I was produced this flight log tell me if 
Fin using the wrong term. What is this called, this 
book that I've been provided by Dave Rogers? 
A. I've never seen that book. 
O. I'll
 you see it. I don't know that It was 
r. 
always In a book, so maybe that's why you haven't seen 
it. Tel me what we're looking at. 
A. Wee, Judging with the name at the bottom, I 
9 
believe this Is Dave's flight log, log book. 
10 
0. I didn't know if it was called a flight log. 
11 
A. Pilot log book, law's that? That's the 
12 
appropriate name. 
13 
0. It was marked as Composite Exhbit 1 
14 
Roasts deposition. SS Indicated by the exhibit sticker. 
15 
Wel mark it the same in your deposition as well. 
16 
MR. CRITTON: Why don't you refer to it as 
17 
his? 
18 
MR. EDWARDS: Fine. 
19 
BY MR. EDWARDS: 
20 
0. ITS the pilot log book of Dave Rogers? 
21 
A. Yes. 
22 
0. And the years provided in this book are 2002 
23 
through 2005; I can represent that to you. I'm going to 
24 
ask you about certain people that David Rogers wrote 
25 
down as being on the airplane and I want to ask you if 
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75 
0. But it's evident that the plane is being used, 
at least for this tine period. January ol 2002 through 
2005, on a fairly regular basis. I mean. we're looking 
at January 6th, 1 tth, 130, 13th, 14th, right? 
A. Uti-huh. 
0. I mean, Is that something that you would say 
accurately reflects the amount of use of Jeffrey 
Epsten's planes? 
A. Yes. 
0. So he travels quite frequently? 
A. Yes. 
O. And he travels with many different people. 
4 87
MR. CRITTON: Form. 
THE WITNESS: Yee 
MR. CRITTON: Can I ask one question? I was 
wondering what happened, who has possession of now 
what's the original Exhibit No. 1 of Mr. Rogers' 
deposition? Did you retain it? 
MR. REINHART: The actual book Itself? 
MR. EDWARDS: The court reporter took it. 
right? 
MR. CRITTON: The one marked as an exhibit. 
did you keep that? 
MR. REINHART: This is it. 
74 
you know who they are. This person right here et 
2 
It seems hke she flew on numerous frights. Do 
3 
you know whO that is? 
A. No. I heard the name, but I don't know who 
that is. 
6 
Q. All right. Is that somebody that you remember 
7 
seeing on any of the flights that you were on? 
A. What year are we talking about here? I don't 
9 
remember. 
to 
O. Well, this is January 2002. You'd probably 
11 
know how to read this book a little bit better than me, 
12 
so I don't know. 
13 
A. He keeps his a lot more current, so I know the 
14 
name. If she walked in here right now, I would probably 
15 
look right through her, to be honest. 
16 
O. Do you know what affiliation or relationship 
17 
she had with Jeffrey Epstein? 
18 
A. No. 
19 
0. Okay. There are various — each row I'm told 
20 
by David Rogers is a different flight and it indicates 
21 
where it takes off from and where it lands, et cetera. 
22 
There's a lot of other information, especially over on 
23 
this Side of the page that I'm not familiar with, nor do 
24 
I need to be. 
25 
A. Right. 
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76 
MR. EDWARDS: This Is it? 
MR. CRITTON: Who took it horn the deposition 
the other day? 
MR. EDWARDS: I have this one right now. 
MR. REINHART: That's the only copy? 
MR. EDWARDS: Okay. 
MR. CRITTON: So you took the original? 
MR. EDWARDS: Apparently. It has the original 
sticker. 
MR. CRITTON. When I say "the original,* the 
original copy. Would you have someone recreate 
what you've got and send It to us so we have It? 
MR. EDWARDS: Sure. In fact, why don't I wait 
until I get the whole thing and I'll copy all the 
pages and send It to you Instead of piecemeal. 
MR. HOROWITZ: You mean before the transcript 
comes? 
MR. EDWARDS: We can copy it. 
MR. CRITTON: If you give it to me. It copy 
it and send It back to you. 
MR. REINHART: I have a copy. It Just doesn't 
have the exhbit sticker on. 
MR. EDWARDS: That's what was told to me the 
other day, that's why I took it. 
MR. CRITTON: I want something — I Just don't 
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Facsimile: 561.394.2621 
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