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• 
• 
73 
1 
up to the airport? Do you remember her being with 
2 
somebody else? 
3 
A. If it would have boon, would have been Mr. 
4 
Epstein. never •• 
5 
0. How many times do you think Mr. Epstein was on 
6 
that airplane? 
7 
A. I can't say for sure • not that many. 
8 
0. Less than live? 
9 
A. That I saw him, yes. probably. 
10 
0. And how many times of al --
11 
MR. REINHART: Can !just chanty? You 
12 
mean dung the tune Mr. Wexner owned the 
13 
plane 
MR. EDWARDS: Right, right. nght. 
15 
MR. REINHART: -- since Mr. Epstein bought 
16 
the plane. 
17 
BY MR. EDWARDS: 
18 
0. Alright. We're not up to the point, we're 
19 
about to bo, but we're not ho to the point yet where Mr. 
20 
Epstein takes control, so. 
21 
A. I mean, you have to understand. Mr. • 
22 
during this time period. Mr. Epstein had his other • 
23 
he already owned his other airplane. 
24 
Q. How did you know that? 
25 
A. 
Well, because that's what Larry and Dave 
75 
1 
A. Maybe mid-'90, early '90. 
2 
0. We're talking --
3 
A. He didn't have that plane very long. 
4 
0. Between '90 and '93. you're saying. 
5 
A. Probably, yes. 
6 
0. And between '90 and '93, if we use those 
7 
years. you're laminar with the name 'Jeffrey Epstein? 
8 
A. Not until later when he bought the 
9 
Gultstream in - later when he was, you know, like I 
10 
said, late '90, probably. 
11 
0. But you're aware that David Rodgers and 
12 
Visoski are flying an airplane between '90 and '93 that's 
13 
owned by somebody. 
14 
A. Correct. Yeah. 
15 
0. But you don't know the name of the person --
16 
A. Correct. Right. 
17 
0. 
— that is the owner. We're good. We're on 
18 
the same page. 
19 
'88, you start working for Leslie Wexner. 
20 
A. Right. 
21 
0. And the first time Epstein is on Leslie 
22 
Wexner's airplane is approximately when? 
23 
MR. REINHART: It's asked and answered 
24 
BY MR. EDWARDS: 
25 
0. That you remember. 
74 
1 
were flying - the Gulfstream. 
2 
O. But this is something you found out 
3 
afterwards. 
4 
A. No, no. I knew that they had gotten a job 
5 
with him and they were flying the Guestream. 
6 
0. Alright. Let me clarify this real cwickty. 
7 
You got the job in 1988 with Wexner. 
8 
A. Right. 
9 
0. Right. Larry Visoski and David Rodgers are 
10 
flying a plane that is presumably owned by Jeffrey 
11 
Epstein and/or one of his corporations. 
12 
A. Not at first. 
13 
O 
At some point in time. 
14 
A. Correct. 
15 
O. And what point in time do you become aware 
16 
that that's happening? 
17 
A. I can't remember exactly when they bought 
18 
the Gultstream. They actually had a Hawker for a 
19 
short period. I don't know when that was. 
20 
0. Was that also owned by Jell rey Epstein? 
21 
A. For a very short period, and he traded it. 
22 
O. The first Epstein plane that you're aware of 
23 
Is that Visoski and Rodgers are on --
24 
A. Was a Hawker. 
25 
D. 
was approximately what year? 
76 
MR. REINHART: Asked and answered. 
2 
A. I cant — The only tine I would remember 
3 
• we've already answered thd several times - was in 
4 
the late '90s when I was actually on the airplane. I 
5 
have no idea if he was on previous times without me 
6 
there. 
7 
O. And when he is on the airplane, is ho on the 
8 
airplane with young girls? 
9 
MR. REINHART: Its also been asked and 
10 
answered. 
it 
A. No. 
12 
0. New we're back to Ghistaine Maxwell, and I 
13 
believe your answer - which led me back to these 
14 
questions that I had previously asked. 'Was Ghislaine 
15 
Maxwell on the airplane that Wexner owned that you know 
16 
of?' • and I think your answer was. 'With Epstein? 
17 
MR. PIKE: Form. 
18 
A. I wood I would say if she was on 
19 
there, it would be with him. I never knew I would 
20 
not think that she would fly on it without him. 
21 
0. Do you specifically remember her on the 
22 
airplane with him? 
23 
A. Caret say - I can't. 
24 
0. On any of these flights that Jeffrey Epstein 
25 
and/or Maxwell was on. din thoy fly internationally? 
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77 
1 
A. I know I Drought her back one time from 
2 
England, I believe - I remember that from London. 
3 
O. Brought Maxwell back from London. and was she 
4 
alone then? 
5 
A. I can't 
I can't say. I cant remember. 
6 
O. I thought you said that if she was on the 
7 
plane it wouldn't have been alone. 
A. More than likely she would have been with 
9 
Jeffrey. 
10 
O. So do you think that you brought Maxwell and 
11 
Jeffrey together back from London? 
12 
A. More than likely, but I can't say for 
13 
sure. I can't remember if he was on that flight. 
14 
O. To the best of your recollection right now, as 
15 
we sit hero, Is that Maxwell was on the plane and Epstein 
16 
may or may not have been? 
17 
A. Correct. That's correct. 
18 
O. What year are we talking about and whose 
19 
airplane are we talking about? 
20 
A. 
That would have been when the 727 was 
23. 
still Limited - or Wexner. 
22 
O. And that would have been around what year? 
23 
A. 2000, maybe. 
24 
O. 2000? 
25 
A. '99. something like that. 
79 
the Court to be well aware that not 8t of my 
2 
form objections are coming through the 
3 
telephone. 
4 
MR. EDWARDS Mike. how about this, of all 
5 
of the people involved. I think that you know 
6 
you can trust me here. If you say when wo read 
7 
this back that you wanted a form objection. III 
B 
put 6 on the record right now you get n - how 
9 
about that? 
10 
MR. PIKE: Not a problem. 
11 
BY MR. EDWARDS: 
12 
O 
Alright. Have you ever looked at any of the 
13 
information from Customs and Immigration related to 
14 
flight logs? 
15 
A. No. 
16 
O. If Customs and Immigration is the right agency 
17 
to take control Of MOSe documents, who is it that 
18 
generates the documents in terms of personnel riding upon 
19 
this airplane/ 
20 
A. Captain
21 
O. Who was the captain or who were the captains 
22 
that you are aware of and try to give me years, it many 
23 
of them changed. to the best of your knowledge for 
24 
Leslie Wexner? 
25 
A 
Primarily it would have been Tim Staley, 
78 
1 
O. So this is almost into the transition --
2 
A. No, I'm sorry. 
3 
O. 
- into it. 
4 
A. Let me think on the dates. 
5 
O. Okay. 
6 
A. 
Yeah, I can't - I can't remember. 
7 
Q. Late '905 or 2000? 
8 
A. Late '90s. 
9 
O. 
Who has the flight logs from late '90s? 
10 
A. I don't know. 
11 
O. But that's something that the FAA would have, 
12 
right? 
13 
A. NO. 
14 
MR. PIKE: Form. 
15 
BY MR. EDWARDS: 
16 
O. Flying Internationally? 
17 
A. I don't know if the FM gets that. It 
18 
would more • most hkety be Customs and Immigration. 
1.9 
MR. PIKE: Are you guys getting my form 
20 
objections? 
21 
MR. EDWARDS: Yes. We got you. 
22 
MR. PIKE: Thank you. Brad. I just want 
23 
on the record that not all of my form objections 
24 
are coming through, so if we have an issue with 
25 
this deposition - I am on the phone - and I want 
80 
1 
Jim Taylor, Rob Imlay. 
2 
O. Rob? 
3 
A. Imlay. I.M.L-A-Y, Bill Hammond. 
4 
0. Bill Hammond? 
5 
A. Uh-huh. 
6 
O. Bill Hammond later becomes affiliated with Mr. 
7 
Epstein too, right? 
a 
A. Correct. 
9 
O. We're going to get to that. 
10 
Have you ever been a captain? 
11 
A. No. 
12 
a 
And when you say that it's not necessary -
13 
unless you're flying internationally, I know - but its 
14 
not necessary to maintain a passenger manifest that 
15 
delineates the exact name, where are you getting that 
16 
information from? 
17 
A. I know it's not required by the FARs. 
te 
O. Kow do you know that? 
19 
A. Because you can read the FARs. Part 91, 
20 
FAR 91, Operations. 
21 
O. 
What's -FAR' stand for? 
22 
A. Federal Aviation Regulations. 
23 
O. 
And what would be the reason not to put the 
24 
whole name of the person on the airplane? 
25 
A. I don't know. I -- I don't know. 
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Si 
1 
O. Because Later I'm going to show you some 
2 
lists. and certain people are listed by full name and 
3 
others are listed generically • any idea why that would 
4 
happen? 
5 
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 
O. Well, she asked you your name before your 
11 
deposition and you didn't consider that the third degree 
12 
by any means. right? 
13 
A. Right. but --
14 
MR. PIKE: Objection to form. 
15 
A. Bill you're approaching your employer's 
16 
guest. It would be like walking into his house and 
17 
asking him, 'Who's sitting at the dining room table?' 
18 
• In a way. See what I'm saying/ It's just -- You 
19 
have to maintain .-
20 
O. But •• 
21 
A. -- the employee/employer relationship. 
22 
O. No, no, no. I guess what I'm saying is: if 
23 
one of these people is Mohammed Aga, you would like to 
24 
know O. probably. 
25 
A. Well, yes. 
83 
1 
A. It would be obvious that these aro 
2 
associates of some form, that they're not, you know, 
3 
strangers trying to board the airplane. 
4 
O. So let's go back to that conversation that you 
have in the Ohio 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. 
8 
A. Ubhuh. 
9 
O. How does that conversation really go about/ 
le 
MR. PIKE: Form. 
11 
A. I don't understand. What do you mean. 
12 
'How &law about?' 
13 
O. Did you approach them and say. 'Hey, are you 
14 
going to stay here forever with this airplaner or 'Do 
is 
you have another lob for me?' or what? 
16 
A. I think it was just, you know. I believe 
17 
Larry approached me. I can't remember. It was that 
18 
long ago, but - 
19 
O. What does Larry Say to you? 
20 
A. I can't remember the exact conversation. 
21 
O. I mean, was he not happy where he was? 
22 
A. Who, Larry? 
23 
O. Yes. 
24 
A. Never said he wasn't. 
25 
O. How did you know Larry? 
82 
1 
MR. PIKE: Form. 
2 
A. Yes, yes. 
3 
Q. So any reason why a captain trying to secure 
4 
the airplane and the people aboard wouldn't take that 
S 
extra step and try to figure out who's exactly on his 
6 
airplane? 
7 
A. Well. when it's • the normal passenger 
loads are live to ten people, at 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 Atta is going to sneak in 
12 
there and board his plane and ride along is - you 
13 
know. 
14 
O. He's willing to play those odds, okay. 
15 
A. Well, I'm not saying that he's playing 
16 
odds. I'm just stating that the only reason I can 
17 
think — I don't know. I've never filled those out. 
18 
The only reason I can think is he just didn't have 
19 
the name and didn't want to intrude and ask. 
20 
O. 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 who the - you 
24 
know. 
25 
O. Okay. 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
84 
A. 
What are you talking about? Why would he 
not be happy where he was? I don't understand. 
O. Well, he's working for some other corporation 
that's not non-Epstein owned. 
A. Oh, that previous corporation sold the 
airplane. 
O. Oh, they did? 
A. 
Yeah. He had no choice. They were out of 
work. 
O. So Larry and David were about to be out of 
work. 
A. 
Yes. 
O. So they said, 'Hey. we found a new lob and 
its with this guy Jeffrey Epstein and he's buying that 
plane. Do you want to be involved?' 
A. No, no. There was another airplane in 
between • two other airplanes. There was a long time 
between - and I don't know the exact dates and I 
don't know that I even do know the dates • but there 
was a time between when they left Glimcher before 
Jeffrey got involved with the 727. 
O. So they leave Glimoher? 
A. 
Yes. 
O. 
Then what happens? 
A. 
They somehow - I don't know how • hired on 
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85 
1 
with Jeffrey. 
2 
O. 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 
donl know what he did with it. but then he got the 
Gulfstream. 
8 
0. So Larry Visoski and David Rodgers were pilots 
9 
for Jeffrey Epstein when he had the Hawker also? 
10 
A. 
Yes. 
11 
0. And what year are we talking about there? 
12 
A. I have no idea. 
13 
0. Well, If you sign on with him in 91. it's 
14 
before that year. right? 
15 
A. No, no, I signed in '01 • January '01. 
16 
0. '01. 
17 
A. I don't know how long they flew for 
18 
Glimcher before that airplane went away and how quick 
19 
they gel on with Jeffrey. I don't know. Somewhere 
20 
between '88 and 2001, they --
21 
0. During --
22 
A. 
— left Glimcher and —
23 
0. During '88 and 01, do you remain in contact 
24 
with Larry Visoski and David Rodgers? 
25 
A. On and off. They eventually moved, you 
87 
1 
0. Before your conversation with them about 
2 
becoming Involved with Jeffrey Epstein. 
3 
A. Yes. 
4 
0. How? 
• 
A. Like we discussed. We've been through 
6 
this already. When they wore at Glimcher they had an 
7 
airplane in the hangar. We would see them 
• 
sporadically and we would talk. 
9 
0. I'm sorry, bad question. I don't mean on a 
10 
business relationship. On a social relationship, did you 
11 
hang out with them --
12 
A. Oh, no. 
13 
0. 
outside of this? 
14 
A. No, no. 
15 
0. I apologize. 
16 
So • and I only asked that question because 
17 
some years later then you're in contact with them and 
18 
they asked you to become involved with Jeff Epstein. 
19 
A. Uh-huh. 
20 
0. But that is because of a business relationship 
21 
solely that you had with them --
22 
A. Oh, yeah. 
23 
0. 
years before? 
24 
A. I didn't know them personally. 
25 
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 
0. Where did 'hey go - do you know? 
5 
A. I Think Dave went to New York and Larry 
6 
went back to South Florida. 
7 
0. Do you know why? 
A. Well, because I think Jeffrey gave them 
9 
the choice of living where they would like. I 
10 
believe. I mean, that's --
11 
0. That's what they've said. 
12 
A. That's what they've said. 
13 
0. Okay, and Larry chose South Florida, David 
14 
Rodgers chose New York? 
15 
A. Right. 
16 
0. And Epstein had a place for them both wherever 
17 
they wanted to go? 
18 
A. Well, they owned their own Acmes or 
19 
something. I don't know what their living 
20 
arrangements were. 
21 
0. Did you know Larry Rodgers or David Visoski 
22 
before this? 
23 
A. Before? 
24 
MR. PIKE: Form. 
25 
BY MR. EDWARDS: 
88 
1 
BY MR. EDWARDS: 
2 
0. Okay. Alright. So in 2001. is that the year 
3 
that you get a telephone call from one or two of these 
4 
people? 
5 
MR. PIKE: Form. 
6 
A. It would be either late 2000 or earty 
7 
2001. I don't 
These transactions don't happen 
8 
overnight --
9 
0. Yeah. 
10 
A. 
— buying an airplane. So it could have 
11 
happened in, you know, November or started talking in 
12 
November, like, 'Well, you know, would you be 
13 
interested if Jeffrey gets the airplane or buys the 
14 
airplane?' you know. to when I actually hired on. 
15 
0. Did you ever talk to Ghislaine Maxwell • ever? 
16 
A. 
After I had hired on, yes. 
17 
0. After you hired on with Epstein. 
18 
A. 
Yes. 
19 
0. Well go up to her. 
20 
So when is it that you hired on with Jeffrey 
21 
Epstein? 
22 
A. I think I began in January of 01. 
23 
O. In January of '01, do you stars getting a 
24 
paycheck from Jeffrey Epstein? 
25 
A. 
Yes. 
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89 
1 
O. 
And Is it paid from one of his companies or 
2 
from Jeffrey Epstein specifically? 
3 
A. 
No, no • JEGE. 
4 
O. JEGE. What is your understanding as to what 
that is? 
6 
A. It's just initials. It's a name. I don't 
have any idea what it stands for, but I'd ask that a 
8 
million times. 
9 
O. Its 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 
O. What's the bank account that it was written 
16 
on? 
17 
A. I can't remember. I mean. I know I'd read 
18 
• I'd see 'JEGE` on it, that's all. 
19 
O. A New Mexico bank, New York bank. Florida 
20 
bank? 
21 
A. I have no idea because its direct 
22 
deposit. All I would do is just see if the amount's 
23 
right. I don't -- I have no idea. I would 
have 
24 
no Idea. 
25 
O. What was your communication - direct 
91 
I 
perform. 
2 
O. On what planes? 
3 
A. Just the Guff - just the Boeing. 
4 
O. Just the Boeing? 
5 
A. Uh-huh. 
6 
O. Over the years. did you become aware that he 
7 
owned other aircraft? 
a 
A. I knew that he still had that. 
9 
MR. PIKE: Form. 
10 
A. He still had the Guffstream. 
11 
O. At the time back in 2001 - and we're going to 
12 
walk through some of his enplanes • he owned the Boeing 
13 
727, right? 
14 
A. Correct. 
15 
O. 
And what other airplanes did he own at that 
16 
time when you signed on with him in 2001? 
I7 
A. 
The Gulfstream. 
le 
O. Guitsteam is what? 
19 
A 28. 
20 
O. Do you know who the pilot was for that plane? 
21 
A. Dave and Larry, I mean, its always. 
22 
O. Was it atways Dave and tarty 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 me. I mean, it wasn't - It wasn't 
6 
didn't realty -- I may have had one phone 
7 
conversation with Jeffrey prior to actually being 
B 
hired and the next time I saw Jeffrey was when I was 
9 
in Florida with the airplane. 
10 
O. 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 
O. Did he ask you what you were looking for in 
15 
terms of salary? 
16 
A. 
Yes. 
17 
O. What dkl you toff 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 
O. $117.000 a year? 
22 
A. Yeah. 
23 
O. And what wore your duties? 
24 
A. Basically - flight engineer, obviously. 
25 
but all line maintenance and scheduled maintenance to 
92 
1 
O. 
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 
O. Really? 
6 
A. Yeah. 
7 
O. No rhyme or reason why he took one this way 
Ei 
and one that way? 
9 
A. No. He was • pretty much once the Boeing 
10 
got on line. Now, you know, the Boeing goes down for 
11 
heavy maintenance. It used to go annually. now It 
12 
goes down DI-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 
O. 
And in those cases, then he would use the 
17 
Guffstream 2B? 
la 
A. Yes. 
19 
O. Have you been on both planes? 
20 
A. 
Yes. 
21 
O. We're still talking about 2001. Is that the 
22 
first time that you're on the 727? 
23 
A. Firs! time I was on the 727? Wail. I 
24 
don't know what you mean. 
25 
O. After Epstein owns it. 
• 
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1 
A. Yes. 
2 
O. And do you remember where you went? 
3 
A. 
Very first tlight, no, because we didn't 
4 
fly it immediately. We upgraded some avionics and 
5 
did modifications. 
6 
O. What modifications did he want to that plane? 
7 
A. Just changed the carpet and some fabrics, 
e 
upgraded the radar, upgraded the navigation - the 
9 
flight manifest systems. 
10 
0. Did he change the interior at all? 
11 
A. No. We removed that one small table and 
12 
chair - that's it, but we did not really change what 
13 
you would consider the floor plan. 
14 
0. Now, try to give me a visual appreciation of 
IS 
the inside of the plane. II 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 
O 
That's it? 
20 
A. That's it. yeah. 
21 
a 
Just an empty room with a door? 
22 
A. No, no. The door's always closed. 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. Cant remember the first flight. Like I 
2 
say, it was down tor a while probably • I think it 
3 
was - had to take at least three to tour months maybe 
4 
to get it --
s 
0. And did you know of him flying on the airplane 
6 
with gins accompanying him? 
7 
MR. PIKE: Form. 
A. I don't --
9 
O. Back in 2001. 
10 
A. With girls accompanying him? 
17 
0. 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 first time. 
The first flight was probably New York, I think. 
19 
O. Is it a private airport in New York where you 
20 
would usually pull into or a commercial airport? 
21 
A. I think 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 all 
24 
have some commercial service. It would have been 
25 
White Plains, I believe, then later we started using 
94 
1 
0. What's behind that? 
2 
A. 
The galley. 
3 
0. The what? 
4 
A. The kitchen - galley. 
• 
0. Okay. 
6 
A. Behind that is the aft salon, which is 
7 
just two round divans. 
▪ 
O. 
And? 
9 
A. 
Alter that is the office, which is a 
10 
consists of a credenza and a desk, or divan and a 
11. 
desk and chairs. 
12 
0. How many of these areas can you close off or 
13 
partition? 
14 
MR. PIKE: Form. 
Is 
A. 
Each one. And after that there's the 
16 
state room. 
17 
O. 
And in the state room how big is the slate 
18 
room? 
19 
A. 
Consists of a queen size bed and two 
20 
single seats. 
21 
CI Have you ever been back in the state room? 
22 
A. Oh, yes. Yeah. 
23 
0. When's the first time you flew on the airplane 
24 
with Jeffrey Epstein back in 21101, after he acquired the 
25 
727? 
96 
7 
Kennedy, and the service was so terrible in Kennedy 
2 
and so expensive we went to Newark. 
3 
O. 
When you would fly into White Plains or to 
4 
Kennedy or Newark, would you always get off of the 
5 
airplane or would you sometimes stay on and wait for 
6 
passengerslo board? 
7 
A. 
I don't understand. 
a 
0. Well, when you stop an airplane 
9 
A. 
Right. 
10 
0. -- 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 oft. 
15 
A. Oh, no. 
16 
MR. REINHART: rm sorry, can wo clarity 
17 
the 'you'? Do you mean thin personally or the 
18 
people who were passengers on the plane that he 
19 
was flying? 
2o 
0. I'm talking about you personally. 
21 
A. 
Oh. no, it was rare that we ever did a 
22 
through flight. Wo would normally go Irom Point A to 
23 
Point B, and that was the destination. 
24 
O. 
I assume when he buys the plane initially it 
25 
was in Ohio. right? 
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1 
A. Well, yeah, but --
2 
O. Then you fly to Florida. 
3 
A. Well, we crewed it to Florida and then it 
4 
sal at a facility in Florida during negotiations, so 
• 
it didn't go directly from Ohio. 
6 
O. In 2001, when there's still negotiations, 
7 
where in Florida is the airplane? 
• 
A. Lake City • Timco. Lake City. 
9 
O. During the negotiations, does it ever take ott 
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. 
Earty, 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. 
PB1. 
24 
O. PRI? 
25 
A. Here in West Palm. 
1 
2 
3 
4 
S 
6 
7 
B 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
99 
O. Who's on the airplane? 
A. Well, obviously it would be Jeffrey. 
O. Right. 
A. I can't remember who all went. 
O. 
Who were the pilots? 
A. I can't remember that either. 
O. Larry? 
A. No. 
MR. REINHART: Hold on. 
A. II would have been myself, for sure -
because I was the only one with experience on the 
airplane myself, Dave, I believe, would have been 
captain because ho had been schooled, but I can't 
remember if Larry took first flight or nol. I think 
he was still in training. 
O. Where did you go? 
A. I can't remember. 
MR. PIKE: Form. 
A. I can't remember it It was New York or 
I would imagine it would be New York, but I can't 
remember. 
O. When you say you would imagine New York. I'm 
getting the impression that many of the flights went to 
and from New York. 
A. 
Yeah, primarily. 
98 
1 
O. While ifs at PB1 airport, does it take off 
2 
from there? 
3 
A. No, not for -- 'Mars when we were doing 
4 
the modifications and upgrades. We were doing the 
S 
avionics. 
6 
O. How long did that take? 
7 
A. I don't remember the exact time - maybe 
B 
three to four months. 
9 
O. Who does it with you? 
A. Jet Aviation. Jet aviation did the 
11 
avionics and soft goods. 
12 
O. And when you say the *soft goods.* what do you 
13 
mean by that? 
14 
A. Carpet. fabrics. loather, 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 m 2001, but mid-year or 
18 
something? 
19 
A. Probably midyear, maybe a little earlier 
20 
than mid-year. 
21 
O. We're talking about Juno of 2001? 
22 
A. Right. 
23 
O. Arid where do you go? 
24 
A. Can't remember. i cani remember for 
2S 
Mb. 
100 
1 
O. Soil -
2
A. And --
3 
O. So any time you're having to guess where it's 
4 
going, you're saying New York because that's the primary 
5 
place it's gong. 
6 
A. Correct. I would have remembered -- I 
7 
I know I didn't get — I had heard about St. Thomas. 
but I hadn't been there right away. I didn't get to 
9 
go to St. Thomas for a while. 
10 
O. Thars later on in the story. 
11 
A. 
Yes. 
12 
O. Well get there. 
13 
So you go to Now York. Does he tell you the 
14 
purpose behind going to New York? 
15 
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 
23 
business-related. 
24 
O. Okay. but --
25 
A. 1 mean, it was about the interior work or 
Everything is 
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1 
the avionics going in. but never personal. 
2 
O. But, I mean. you've been hired by him --
3 
A. Right. 
4 
O. -- you agreed on a salary. he's going to pay 
5 
you the salary, but other than that, and what maintenance 
6 
may be required --
7 
A. Correct. 
- on the airplane, nothing else? 
9 
A. He's a very -- His conversations are 
10 
usually very shod. He doesn't, you know, take much 
11 
tine. 
12 
O. When you would have conversations with him. 
13 
would they to over the telephone or would they be in 
14 
person? 
15 
A. It could be In both. II he was in Florida 
16 
and I wanted to actually show him a labric or a 
17 
sample for the airplane or he wanted to view how it 
18 
was coming, but oftentimes it would be via telephone 
19 
from New York. 
20 
O. When it would be in 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 Ghislaine Maxwell? 
25 
A. Al times, yes. 
103 
I 
know, business relationship too. 
2 
O. Did you know who Ghislaine Maxwell was? 
3 
A. Not right away, no, no. 
4 
O. Nol right away? 
5 
A. Right. 
6 
O. At some point in time you were curious enough 
7 
to make an attempt to find out. 
B 
A. No, l 
9 
MR. PIKE: Form. 
to 
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 just 'Maxwell: 
16 
O. 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 locking at 
19 
pictures, boats, and airplanes and stuff. 
20 
O. Back in 2001, the first time you had a real 
21 
conversation with Ghlstalne Maxwell .-
22 
MR. PIKE: Form. 
23 
A. 
Yes. 
24 
O. - what did that conversation Consist of, it 
25 
you remember? 
102 
1 
O. Would any ol those girls look extremely young 
2 
lo you? 
3 
MR. PIKE: Form. 
4 
A. Not - Not that I thought. 
5 
O. Not back in 2001, we're talking about? 
6 
A. Right, right. 
7 
O. 
NO. 
What would Ghislaine Maxwell say to you, it 
9 
anything? 
10 
MR. PIKE: Form. 
11 
A. She'd 
Mostly small talk, just 
She 
12 
kind of did the business management pad of it as far 
13 
as, you know, arranging cell phone - I was having 
14 
coil phone problems with the company cell phone. she 
15 
would handle things like that, but she would have 
16 
minor inputs on the interior work. 
17 
O. What was your understanding back in 2001 still 
18 
of the relationship between GIs:Vain° 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 mink it was 
24 
sexual? 
25 
A. I thought maybe they were dating and. you 
104 
1 
A I think it was concerning getting a cell 
2 
phone and a pager • that's it. 
3 
O. Did it have anything to do with underage 
4 
girls? 
s 
A. 
Absolutely not, no. no. 
6 
O. 
That's not something she ever shared with you? 
7 
A. No, no. 
O. Did Jeffrey Epstein ever share with you that 
9 
he wanted underage girls --
10 
A. No. 
11 
O. 
—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. 
16 
O. 
— considering the newspaper articles. 
19 
A. Right, but l know -- You have lo 
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 wall questions --
25 
A. Right. 
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• 
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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 June 
4 
or so is the first fight, and you believe its to New 
5 
York. 
6 
A. Cared. 
7 
O. Do you remember the purpose behind the flight? 
A. No, did not know the purpose. 
9 
O. Did you get off the airplane in New York? 
10 
A. 
Yes, yes. 
11 
O. Where did you go? 
12 
A. Probably to - into the city, into the 
13 
city, and he has an apartment building up there that 
14 
we would stay in in the city. 
15 
O. Is it paid for by Jeffrey Epstein? 
16 
A. 
What? 
17 
MR. PIKE: Form. 
18 
BY MR. EDWARDS: 
19 
O. The apartment. 
20 
A. Well, he -- Its 
I think it's in the 
21 
building he owns. I mean. I just -- I don't know. 
22 
Q. Do you remember the address? 
23 
A. El
m
24 
O. 
right? 
25 
A. Right. 
107 
1 
building. I've been to the building. The building is 
2 
huge. 
3 
A. 
I don't know. I don't know if he owns the 
4 
building or just - or how many units he's got. Maybe 
• 
ten, because I think some of the employees up there 
6 
live in them. 
• 
O. Do you remember who some of the other 
8 
employees are that live in that building? 
9 
A. 
Well, I think Darren used to five in il. 
10 
Darien Indyke. 
11 
Q. Darren Indyke, right. 
12 
What abou 
13 
A. 
lived in there. 
14 
O. 
What abou 
15 
A. I don't know 
lived in there or 
16 
not. 
17 
O. 
You know who that is, though. 
18 
A. Right, right. Actually, she was just kind 
19 
01 coming into the picture when I was • about the 
20 
time when I was leaving. 
21 
O. 
What about Ghislaine Maxwell? 
22 
A. No, no, she didn't live there. 
23 
O. What about Jean Luc Brunel? 
24 
A. No. 
25 
O. How about Did Mark Epstein ever indicate to 
do you remember her? 
1 
2 
3 
4 
5 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
106 
O. Did he ever mention a brother that he may have 
to you? 
A. I met his brother, I think, once. 
O. What's his name? 
A. I can't remember. 
O. Mark? 
A. I remember meeting. 
O. Mark Epstein strike — 
A. Honestly. I can't say for sure. 
O. And how do you know that Jeffrey Epstein owns 
the apartment building 
A. Larry told me. I mean, it was just kind 
of known. 
O. Larry told you —
A. 
Yeah. 
O. - a Jeffrey tad you? 
A. Oh, no, not Jeffrey, no. Larry. I 
wouldn't have asked Jeffrey. 
O. How many of those apartments up there in New 
York is it your understanding that Jeffrey owns? 
MR. REINHART: I'm sorry, are you asking 
how many units are in the building or how many 
buildings? 
BY MR. EDWARDS: 
O. No. how many units that Jeffrey owns in the 
108 
I 
you that he had any ownership in any d 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 lust • Jeffrey 
S 
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. Uh'uh. 
10 
O. Nothing? 
11 
A. 
Nothing. 
12 
O. So in 2001, there's a flight up there at sane 
13 
appointment in time, and you get off and you stay at one 
14 
of the apartment buildings ate 
15 
A. Right. right. 
16 
O. 
And did you meet any of the neighbor's of the 
17 
apartments that are also owned by Jeffrey Epstein? 
le 
A. No. no. because when we're there its 
19 
usually just for a night or something and then, you 
20 
know, we're either airlining 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 
O. Do you remember any 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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109 
1 
maym and ==? 
2 
A. Not that I remeMbef, no. 
3 
O 
How about Leslie Groff? 
4 
A. 
I don t think Leske rived there. 
O. Do you remember that name? 
6 
A. Yet She's Mr. Epsteins secretary. 
7 
O. What ab0ut 
8 
A. 
no. I dont think so. 
9 
O. Jell Fuller/ 
10 
A. 
I dont know Jeff Fuller. I doll even 
11 
know Jeff Fuller. 
12 
O. Do you know the name Jean Luc Brunet? 
13 
A. Yes. 
14 
O. How do you know that name? 
15 
A. He's been He was a paSsenger cn a few 
16 
of our eights. 
17 
O. Do you know why? 
18 
A 
I think he was 
I deal know for sure. 
19 
He's In a mode/no business with Mr. Epstein, I 
20 
believe. 
21 
0. MC27 Do you know that name - MC2 Modeling 
22 
Agency used to be Karin Modeling Agency, now it's MC2? 
23 
A. No. 
24 
O. 
Hew do you know about his and Mr. EpsteMS 
25 
modeling agency? How do you know that? 
111 
I 
of the MC2 shoots? 
2 
A. 
t never heard 
There was one incident •• 
3 
The only thing I remember about it is they were on a 
4 
shoot - and ire not hinny. but Jeff but d is in a 
s 
way • they were in a mow home on location at the 
6 
shoot. and they started to drive off and one ol the 
7 
models asked to use the resin:CM and they told her 
a 
which door it was and she went out the side door, so 
9 
grabbed the wrong door, but that's actually the only 
1 o 
thing that sticks in mind - was that one. 
11 
0. Have you ever done any research on Jean Luc 
12 
Brunel? 
13 
A. 
No. 
14 
0. Do you have any idea that he's known 
15 
throughout Europe as somebody who has sex with underage 
16 
girls? 
17 
A. No. 
18 
0 
You didn't know Mal until right now? 
19 
A. Correct. 
20 
O. That's Something that you're learning as a 
21 
surprise to you 
22 
A. 
Yes. 
21 
O. So-- 
somebody you never hoard 
24 
Or 
25 
A. II sounds famkar. I'm trying to place 
110 
1 
A. 
Just every once in a while he VMuld Say 
2 
something about, you know, one 01 the model shoots or 
3 
something. We normally had hen on - we would take 
4 
ten back and forth to Paris. 
5 
O. 
Where some of their models come from? 
6 
A. I don't know. 
7 
O. Did you ever bring some of the Paris models 
I 
back? 
9 
A. Not that I'm aware ol, no 
10 
MR. PIKE: Form. 
11 
BY MR. EDWARDS: 
12 
O. 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 Mem back? 
15 
A. 
If I remember, normally we were brining 
16 
Jean Luc from Paris to New York. ill remember. 
17 
O. 
And when you say that the modeling agency -
1$ 
obviously that, you know, between him and Mr. Epstein • 
19 
is that something that Mr. Epstein would talk 10 you 
20 
about or is that something that Jean Luc would talk to 
21 
you about or you would just overhear the two? 
22 
A. Overhear the two, or Jean Luc may say 
13 
someMing about one of the shoots or something, just 
24 
in general conversation. 
25 
O. And what would Jeffreys comment be about some 
2 
1 
4 
6 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
112 
her. I don't know if she works in the office or --
O. Or worked in the office? 
A. 
Worked in the office, yeah. I very rarely 
went to the office. I mean -
O. 
- how do you know her? 
A. 
From the flights - being on the airplane. 
O. How many times was she on the airplane? 
A. 
Quite a few. Almost every. 
O. Mars your understanding as to what she did 
for Mr. Epstein',
A. • 
I 
O. Did Mr. Epstein ever once mention to you that 
he likes massages? 
MR. PIKE: Form. 
A. No. he never mentioned that to me. 
O. 
That's not something that you ever heard of. 
right? 
A. 
Well, I --
O. 
I mean, outside of the articles that you've 
read. 
A. 
Right. No. but he never came up to me and 
said. 1 like massages.' 
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113 
1 
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 dont 
MR. PIKE: Form. 
6 
BY MR. EDWARDS: 
O. What types of conversation, if you can 
8 
remember anything, did you ever overhear 
9 
talking about? 
10 
A. It would be mostly like transportation 
11 
arrangements - car needs. 
12 
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 
stuff 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 
O. We're still talking about a time period back 
20 
in 
right. vi these 
21 
A. No. M. 
I donl remember 
coming 
22 
into the picture until later. 
23 
O. Later inMsomething? 
24 
A. No. she wasn't around at first. 
25 
O. Alright. 
1 
2 
3 
4 
5 
6 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
115 
always sat it by his office in the back. 
O. Always had a computer? 
A. No, no, it's just a large briefcase. 
O. Did you ever know his e-mail? 
A. 
Yeah, I had it 
I can't remember what it 
was and I don't think it's even current - but when I 
would have to send him e-mails about the interior or 
maintenance issues. It was jeprojects, or something 
like that, at -- I don't know if it was at Yahoo or 
gmail. I don't think it was gmall. 
O. 
You think it was jeprojects? 
A. I believe so, but I can't remember what 
service. 
O. At gmail.com or something? 
A. Or something like that or Yahoo or 
something. 
O. How about Ms. Maxwell? 
A. It was 
I think.
O. Do you know rf that's still current? 
A. No, I don't. 
O. How about 
A. I had it at one time and I know she 
changed it and I don't know what it is. I can't 
remember what It was, actualty. 
O. Do you know 
where she is 
114 
1 
A. No. I don't remember when oxactly 
2 
but she 
3
O. Who was mak, 
arrangements for meetings 
4 
and such prior to Ms. 
5 
A. Ms. Maxwell. 
6 
O. -- that you remember? 
7 
So Maxwell was the. for all intents and 
9 
A. 
existed?
purposes, the 
before 
10 
O. 
Maxwell making 
you ever 
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 occuning between 
17 
Maxwell and/or MIIM? 
Where were they taking 
18 
place - on the airplane, some office? 
19 
A. 
Yeah. No, no. usualy in the cockpit, you 
20 
know, prior to departure, en route slating, 'We've 
21 
got this many cars and rye Contacted' or tan you 
22 
call such and such to have this brought cut?' 
23 
O. Did you ever see Epstein work a lot? 
24 
MR. PIKE: Form. 
25 
A. He always had a briefcase with him and he 
1 
2 
3 
4 
6 
7 
9 
10 
11 
12 
13 
la 
IS 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
116 
right now? 
A. No. 
O. Do you know it she's intentionally on the lam 
to try to avoid being deposed in this case? 
A. No. 
MR. PIKE: Form. 
A. No idea. I haven't had any contact with 
M
I
 
since I slopped flying. 
O. You say that 
was just coming in the 
picture is the words that you used. What did you mean 
by this? 
A. Wet I mean she was just 
I'm trying to 
remember when I first started seeing her on the 
airplane.  
I can't remember the exact date. 
O. When did you stop flying? 
A In February of '07. 
O. February '07? 
A. 
Yep. 
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1 
I 
4 
I 
6 
country. 
7 
0. Were you ever told that Mr. Epstei 
J 
U 
13 
0. Did you ever see him and her sexually involved 
14 
en the airplane or otherwise? 
15 
A- No. 
16 
O. Did you ever see Epstein involved sexually 
17 
with anybody on the airplane? 
18 
A. No. 
19 
O. Did you ever see the airplane used for sexual 
20 
purposes? 
21 
A. No. 
22 
MR. PIKE: Form. 
23 
BY MR. EDWARDS: 
24 
O. It it had happened - considering the various 
25 
areas that were cordoned oft or blocked off would that 
0. Do you know where she came from? 
A. Just what rye read in the paper 
I'm sorry. I daft remember the 
119 
1 
A. No. 
2 
O. 
in the back of the airplane. 
3 
A. No. 
4 
O. So anything could go on. You would have no 
5 
idea. 
6 
MR. PIKE: Form. 
7 
BY MR. EDWARDS: 
8 
O. 
You could sit here and testify truthfully, 
9 
have no clue what's going on back there.' 
10 
A. 
That's correct. That's correct. 
11 
O. Darren Indyke - what's your understanding as 
12 
to his involvement with Mr. Epstein? 
13 
A. 
An attorney forme company. 
14 
O. Ever met Alan Dershowitz? 
15 
A 
I think 
Yes. 
16 
O. How did you meet him? 
17 
A. 
Alan Dershowitz. I don't know if it was 
18 
Mr. Goldberger or Alan Dershowitz. We brought some 
19 
attorneys down •-
20 
O. 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 dosed doors, right? 
7 
A. ?bars correct. 
8 
MR. PIKE: Form. 
9 
BY MR. EDWARDS: 
10 
O. Do you remember a time Epstein was back in 
11 
that back room with other people? 
12 
MR. PIKE: Form. 
13 
A. No. 
14 
O. 
Are you saying it never happened while you 
15 
were on the airplane? 
16 
A. I really have no idea of knowing because, 
17 
one, we never go back there unless we're invited 
18 
back. 
19 
O. Okay. 
20 
A. 
And the forward door • the very forward 
21 
salon door is dosed, so we never even normally go 
22 
into that --
23 
O. SO you don't really know --
24 
A. -- without permission. 
25 
O. You don't really know what happens --
120 
1 
something, and we brought some attorneys with him. 
2 
O. 
And were you aware then of the allegations 
3 
against Mr. Epstein? 
4 
A. They were starting to brew, yes. 
5 
O Were you still actively working on his payroll 
6 
at the time when the investigation was going on? 
7 
A. 
Yes, when it lust started. 
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. Subconsciously, 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 did want to get 
16 
off the road and back home. 
17 
O. 
U 
U 
I 
22 
O. I'm assuming you're aware of the 'actual 
23 
allegations in these complaints? 
24 
A. Yes, yes. 
25 
O. And you are aware that there are hundreds of 
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1 
girls who are underage who claim to have had sex with Mc 
2 
Epstein as well as Ms. Maxwell at various times? 
3 
MR. PIKE: Form. 
4 
A. l was only aware of —first time was 
5 
made aware of it, ol the number of people, was when 
6 
they served me the subpoena. The deputies or 
7 
retired 
8 
O. 
Yes. 
9 
A. 
private eyes told me that. That was 
10 
the first I had heard a number. 
11 
O. Were you completely oblivious that this was 
12 
going on? And by 'this' I mean Epstein and/or Ghislaine 
13 
Maned endlor 
recruiting 12, 13: 14, 
14 
1S-year-old girls to his house for sex? 
15 
A. Absolutely I was oblivious to X 
16 
MR. PIKE: Form. 
17 
BY MR. EDWARDS: 
18 
O. If young girls were on an airplane that you 
19 
were on • considering mat we've now established how the 
20 
airplanes set up and you're kind of cordoned elf is a 
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 
O. 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 
O. Right. I totally understand what you're 
? 
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 -- 
11 
A. 
Seven. 
12 
O. 
-- 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 
O. I'm not saying what was happening on the 
18 
airplane. I'm just saying, were you aware of it? 
19 
A. No. not • unless they were there, like I 
2o 
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, 1000. asked and 
24 
answered. 
25 
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 
tho airplane. 
3 
O. So if there wore flight records that show 
4 
underage gins on the airplane, you would know about it? 
MR. PIKE: Form. 
6 
A. Not necessarily. 
7 
O. Well, how not? 
MR. REINHAF17: 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 or 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 wore on there. 
16 
MR. PIKE: Form. 
17 
A. How do you -- How would I know that 
18 
they're underage. though? 
19 
O. 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 --
124 
1 
anybody that was obviously, blatantly underage. 
2 
O. Any 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. 
Yes. 
9 
O. How many times? 
10 
A. 
Two trips. I mean, two extended trips. 
11 
O. Where did it go? 
12 
A. The first one - or the first one was Asia. 
13 
O. What purpose? 
14 
A. I forget what the purpose was on that one. 
15 
O. 
Was Jeffrey Epstein on the airplane as well? 
16 
A. 
Yes, yes. 
17 
O. 
Who else was on the airplane then? 
18 
A. I don't remember on that one. It was 
19 
primarily him and his su 
rt staff. 
20 
a 
Was 
21 
A. Probably, yes, probably. 
22 
O. 
When's the next time President Clinton was on 
23 
his airplane? 
24 
A. I dent 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 
O. Is that a time Chris Tucker --
3 
A. 
Yes. 
4 
O. 
and Kevin Spacey were also on it? 
A. 
Yes. 
6 
O. In addition to the people that we've named. 
7 
wore 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 oouple others, and there's - Mr. 
13 
Clinton had - a couple of his support staff were 
14 
women also. 
15 
O. Where wore you sitting during these trips? 
16 
A. Up front in the - my station. 
17 
O. Could you see what they were clang where you 
10 
wore? 
19 
A. No, no. 
20 
O. Could you tell If there was any sex going on 
21 
on the airplane while 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 
1 2 7 
1 
MR. EDWARDS: No. I mean, unless 
2 
everybody wants to lake a lunch break. 
3 
Everybody's shaking their heads, so, no, I'm 
4 
going to take a bathroom break. and its going 
5 
to be a fast one. 
6 
MR. 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 
O. If somebody's going to keep passenger logs. 
14 
who's gang to write down the names of the people? Is 
15 
that going to be you or is that somebody else's 
16 
responsibility? 
1? 
A. Whoever is captain. 
18 
O. So normally its Visoski or David Rodgers? 
19 
A. Correct. 
20 
O. Who do you turn these logs into? 
21 
MR. PIKE: Form. 
22 
A. I don't know. I don't know where they go. 
23 
O. You don't know the purpose behind keeping them 
24 
or anything? 
25 
A. No. 
1 
2 
3 
4 
5 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
126 
that airplane or would you have been able to tell? 
A. No. 
MR. REINHART: Im sorry --
MR. PIKE: Asked and answered. 
MR. REINHART: -- are you limiting it to 
that trip? 
BY MR. EDWARDS: 
O. To that trip. 
A. No, I'm not aware of it. 
O. II you had been aware of underage girls being 
transported on the airplane for the purposes of sex. 
would you have said something to somebody? 
A. 
Yes. 
MR. PIKE: Form. 
MR. EDWARDS: Do you mind l we take a 
five-minute break? I just have to run to the 
bathroom. 
MR. PIKE: Actually, Brad. can you hear 
me? 
MR. EDWARDS: Yes. 
MR. PIKE: How much longer do you 
anticipate going with this witness? 
MR. EDWARDS: Hour, maybe a little longer. 
MR. PIKE: Well, are you going to take a 
lunch break or what? 
9 
10 
11 
12 
13 
14 
15 
16 
1? 
18 
19 
20 
21 
22 
23 
24 
25 
128 
1 
O. 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 
O. Today you have an attorney sitting right next 
8 
to you, right? 
A. Correct. 
O. Is that somebody that you've known tor a long 
time? 
A. No. 
O. You're paying for an attorney to sit here with 
you? 
A. 
O. 
A. 
O. 
No. 
Who's paying for your attorney? 
Mr. Epstein. 
Are you worded that you're criminally 
involved here or something? Is that why you need an 
attorney? 
A. No. I don't even know anything about this 
process, that's --
O. Oh. okay. 
A. I'm just 
You know. 
O. How did you know that you were 
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129 
1 
MR. PIKE: Brad. Brad. Brad. 
2 
O. - going to get an attorney -
3 
MR. REINHART: Brad, hold on. 
4 
MR. PIKE: Whoa. Whoa. Stop. 
5 
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. I'm on the phone. You 
11 
start your question before the witness is 
12 
finished. I'm sorry for raising my voice, 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? 
17 
I forgot. 
1a 
MR. EDWARDS: I'm 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. Pike. 
22 
MR. PIKE: Alright. 
23 
THE WITNESS: What was the question again, 
24 
please? 
25 
MR. EDWARDS: Can I ask the question again 
5 
6 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
131 
1 
this case against Mr. Epstein? 
2 
MR. REINHART: Let me ask him not to 
3 
answer that. 
4 
MR. PIKE: Form. 
MR. REINHART: It's privileged. 
MR. EDWARDS: It's privileged between Mr. 
Epstein and you, but is it privileged between 
the two of you? 
MR. REINHART: Between Mr. Mornson and 
me. 
BY MR. EDWARDS: 
O. Is it your understanding that he represents 
you or he represents Mr. Epstein? 
A. He represents me. 
O. Okay. Do you think that you've done anything 
wrong criminally? 
A. No. 
Q. Do you think that you're being sued civilly? 
A. No. 
O. And you have no reason to be sued civilly, 
right? 
A Correct. 
O. Did you talk to Mr. Epstein prior to taking 
your deposition today? 
A. Oh, no. I haven't talked to him in wel 
130 
1 
or wait? IN wait for you. 
2 
MR. PIKE: If I'm ready. 
3 
MR. EDWARDS: I already asked the 
4 
question, so we're waiting. 
5 
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 
O. 
Who hired your attorney? 
10 
A. Mr. Epstein. 
11 
O. 
And do you have any idea why, if 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 
O. 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 
O. Okay. 
22 
A. I have very limited exposure to anything 
23 
like this. 
24 
O. Hoiv 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 
O. So how is it you know that Mr. Epstein paid 
4 
for your attorney? 
5 
MR. REINHART: Its privileged. 
6 
MR. EDWARDS: Okay. That answers my 
7 
question. 
8 
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. 
14 
O. And did you talk to him? 
15 
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 
O. 
And did he fly on the plane? 
21 
A. No. 
22 
O. 
Not that time? 
23 
A. 
Never. 
24 
O. 
You think he never flew on the plane? 
25 
A. On our airplane? 
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:33 
1 
O. Yes. 
2 
A. No. 
3 
O. So If somebody has given testimony other than 
4 
that, you would say that person is mistaken or lying? 
5 
MR. PIKE: Form. 
6 
A. Donald Trump was never on the airplane 
7 
when I was on the airplane. 
O. Is it your understanding that Donald Trump is 
9 
friends with Mr. Epstein? 
10 
A. From what I've road • Or associates. I 
11 
don't know how that circle works. 
12 
O. What's your understanding as to who Mr. 
13 
Epstein's real friends aro? 
14 
A. I really don't 'mow. I don't 
I don't 
15 
know. It's 
It's not lee the Wexners whore. you 
16 
know, they were high school associates. you know. 
17 
grooving up. 
18 
O. Do you know what Mr. Epstein did prier 10 
19 
managing the money for Mr. Wexner? 
20 
A. 
Just that he was a Wall Street broker or 
21 
somebody, you know. 
22 
O. 
Also from reading? 
23 
A. 
Yes, yes. 
24 
O. Do you know any personal knowledge as to what 
25 
Mr. Epstein has told you about how he made money? 
1 
2 
3 
4 
5 
6 
7 
a 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
:35 
A. 
I have no idea I don't know. 
O. When you say that -was 
lust 
comet in the icture. what's your understanding as to 
who 
is relative to Mr. Epstein? 
A I dont know. I dont understand. I 
don't know. I didn't know if maybe she was like an 
exchange .• Jeffrey always appeared to be very 
involved in education and phaanthr0PY. I didn't 
know if she was an exchange-type student or something 
or what. I dont know. 
O. When you say he appeared to be *involved 
what do you mean? 
A. Educational things, foundations, science 
foundations, and things. 
O. Speaking of - the Florida Science Foundation 
is a place where. when he was on work release. he spent a 
IN of time there. you're aware of that? 
A. 
That's what I've heard, yeah. 
O. What does that place do? 
A. I have no idea. 
O. Does it do anything? 
A. I dont know. I don't know anything about 
it. 
O. Certainly you've read certain newspaper 
articles about the allegations. Polide MOM 
134 
1 
A. He's never --
2 
MR. PIKE: I'm going 10 move to strike any 
3 
responses relative to what the witness has 
4 
learned from reading. 
5 
BY MR. EDWARDS: 
6 
O. And so that is why I asked the question: Has 
7 
Mr. Epstein told you? Which would have nothing to do 
s 
with reading. 
9 
A. No. 
10 
O. How many conversations have you personally had 
11 
with Mr. Epstein? 
12 
A. No personal conversations - all business. 
13 
O. Have you witnessed AncEpstoinvath any VS 
14 
that look to be under the aged 18? 
15 
A. No. 
16 
O. Have you witnessed Mr. Epstein with 
17 
younglooking girls that appear to be in their twenties? 
18 
MR. PIKE: Form. 
19 
A. Yes, 
20 
O. On how many Oteasions? 
21 
A. Probably several. 
22 
O. And how did that come about? 
23 
A. I mean, they show up and ride on the 
24 
airplane, you know. 
25 
O. And who are they, if you know? 
1 
2 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
136 
otherwise, the allegations that occurred or have been 
alleged to have occurred at his Palm Beach mansion. 
Correct? 
A. Uh'huh. 
O. Correct? 
A. Correct. 
O. Given the nature of those allegations, would 
you leave 
with Mr.
Epstein alone? 
MR. PIKE: Form. Move to strike. 
A. 
Yes. 
O. 
You would? 
A. (Witness nods head.) 
O. And why? 
A. Because I don't fear that he would try 
anything with 
He showed -- When I 
worked for him he showed me respect. He never -- I 
never -- He never showed me disrespect. He would ask 
how the family Is. I mean, not on a personal level, 
but an employer/employee. 
O. Right. Okay. 
A. He never showed me any reason not to trust 
hirn. 
O. Bul you're not a 13-year NO girl, so. 
A. No. but, like I say, he never showed me 
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1 
any reason not to trust. 
2 
O. So maybe that's the reason why there were 
3 
hundreds of victims, right? 
4 
A. I don't know that there were. 
5 
O. So is it surprising to read the things that 
6 
you read about what was going on at his house? 
7 
A. Yes. 
MR. PIKE: Form. Move to strike. 
9 
BY MR. EDWARDS: 
10 
O. I'm going to ask you about -- I'm going to 
11 
mark them all In fact, I'm going to show them to your 
12 
attorney first because I'm going to mark them as a 
13 
composite - just to 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 we'll just 
18 
mark them as a composite • go through each one 
19 
of them. 
20 
MR. REINHART: If you're going to go 
21 
through each one of them, I don't need to count 
22 
them. Youll make a record on that. 
23 
MR. EDWARDS: Fine. I'm going to mark 
24 
these as Composite Exhibit I, 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. 
• 
O. 
Would it surprise you if she was in charge of 
5 
scheduling for the minors to come over to the house to 
6 
sexually gratify Mr. Epstein? 
7 
MR. PIKE: Form. 
A. 
Yeah, that would surprise me, yes. 
9 
O. Okay. She didn't do that while you were on 
10 
the airplane, 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 al a portion 
16 
of the airplane where you couldn't see it because you 
17 
were partitioned off? 
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 
MONT 
24 
MR. EDWARDS: Yes, we're talking about 
25 
that flight. 
1 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
26 
17 
28 
19 
20 
21 
22 
23 
24 
25 
138 
(Defendants Composite I was marked for 
identification.) 
BY MR. EDWARDS: 
O. 
The first one's datec
il. Can you tell 
me what we're looking at there? Just remember. I'm about 
as familiar ynth that type of sluff as a three year old. 
so help me out. 
A. Passenger manifest just showing basicely 
dale, time oft time on, the trip number of the year. 
I guess it would be - that seems high for the year -
but trip number - that must be for the total • 
destination or departure point • destination. 
O. The trip number says. 'Sit.' What does that 
mean? 
A. Thai must be I don't know where they 
start that. That must have been total since he 
staned the airplane. That's way too many for the 
year. Obviously it's already - it's January. so it 
must have been total flights. 
O. Who's on that airplane? 
A. Nautical miles. statute miles, fuel 
burned, poundage. 
anal
.1 
O. DO you know 
A. I — I think I know het I think I would 
140 
1 
BY MR. EDWARDS: 
2 
O. It 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 nil saying it did happen or it 
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 
referring to as it . anyways. 
12 
O. 'It' is whatever sexual involvement there was. 
13 
A. Oh. Like you say, we can't see anything 
14 
back there anyhow because the doors are closed. 
15 
O. Did Mr. Epstein instruct you as to whether or 
16 
not to knock or just walk back there or never walk back 
17 
there or what was the instruction? 
18 
A. No. There was never actually a formal 
19 
instruction. Its 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 it's not forebode, it's just proper. 
24 
O. You mentioned President Clinton on the plane. 
25 
How many girls were on the plane at 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 live, if that, and Oral's 
5 
0. What were they --
6 
A. What? 
7 
0. Go ahead. 
A. Like I say, it was Ms. Maxwell, 
9 
maybe two others, one other. and then I think Mr. 
10 
Clinton had two ladies in his entourage - support 
11 
staff. 
12 
0. 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 
0. I mean. you know what a 13 or 14-year-old girl 
18 
looks like --
19 
A. 
Yes. 
20 
O. 
-- right? 
21 
A. Yes. 
22 
O. Most people do. 
23 
A. Yes. 
24 
O. You wouldn't mistake a 13 or 14 or 15 year old 
25 
fora 20 year old. 
143 
1 
you familiar with a flight where Prince Andrew was on the 
2 
airplane? 
3 
A. I don't 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 the airplanes. I 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? 
1 o 
A. 
I know. I know. I *MI even know who 
11 
he was when I first heard the name, sorry. But, no, 
12 
I can't remember for sure, I'm sorry. 
13 
0. Theta like if E.T. walked on the airplane and 
14 
I don't know. 
15 
A. 
I know. Well --
16 
0. MOVIE III let you slide on that one. You 
17 
know who Prince Andrew is now. 
18 
A. Okay. Don't paint me as stupid. One of 
19 
Lady WS sons. right? 
20 
0. I mean, you know what he looks like now 
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. Its Just 
25 
0. Well forget him. 
142 
A. No, no. 
2 
MR. PIKE: Fenn. 
3 
BY MR. EDWARDS: 
4 
0. So you're sure that the people that were on 
5 
the airplane - they were above the age of 18? 
6 
A. I believe s0. 
7 
0. Because you, in your experience. as well as 
the experience of most people your age, would know --
9 
A. Right. 
10 
0. - what a 14 or 15 year old looks like. 
11 
A. Right. 
12 
0. I'm going to go through the next flight log. 
13 
You tell me what we're looking at here. Who's on the 
14 
airplane? 
15 
A. That was a deadhead. Nobody's on it. 
16 
0. Why were the names crossed out? 
17 
A. Because there was no passengers. This was 
18 
- engin was West Palm Beach - West Palm Beach. What 
19 
date is Mis? 1/20/04? It was probably a test 
20 
flight. 
21 
0. Okay. 
22 
A. It was a training flight --
23 
0. Okay. 
24 
A. -- for Bill. 
25 
0. The next one -- Well, before I ask this: Were 
1 
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144 
A. I'm smart in some things. 
0. Wel forget him. We'll forget him. Don't 
worry about it. 
What's this? What are we looking at? 
MR. REINHART: For the record, you handed 
him a manifest dated 
is that 
correct? 
THE WITNESS: January -- Yes. Correct. 
Palm Beach to Kennedy, same thing, fuel 
bums, loads. destination, time off, time on.
Next, it was trip 312. Jeffrey is on it, M. 
David Mullen, M. 
Todd Myster (sic). 
and passenger, passenger. 
BY MR. EDWARDS: 
0. Do you know Todd Meister? 
A. Ho's a friend of his, I believe. 
0. Fathers Bob Meister? Do you know the names? 
A. No, I don't know that. 
0. How do you know Todd Moister? 
A. I've rust heard the name. 
0. From who? 
A. Larry Visoski. 
0. Larry Visoski knows these people? 
A. 
I think Todd Meister has an airplane. or 
something like that. He's talked to their flight 
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145 
1 
crew. 
2 
0. For the most part, when you mention these 
3 
people's names. you mention them as if they're lust 
4 
passengers on the airplane and this is their world -
s 
you're passing through, you don't know them. 
6 
A. Right. 
7 
0. But Visoski - 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 
0. I mean, do you know that Visoski 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 
0. Were you aware of that? 
10 
A. No. 
19 
0. Does Mr. Visoski tell 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 Glimoher - that's all I know. 
23 
0. Do you know anything about Visoski's private 
24 
life? 
25 
A. A little bit. He's married and 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
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12 
13 
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15 
16 
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O. 
A. 
0. 
A. 
0. 
A. 
147 
Well, do you know whose handwriting that is? 
No. no. I don't. It may be Larry's. 
Similar handwriting -
Wait a minute. 
- as those -
Let's see the one with the training 
because there's a different pilot on there. 
0. Right. One where there Is nobody on it. 
right? 
A. This is Bilrs I can't - TNs is 
Bill's writing. I think he was having him fill out 
the paperwork. 
0. Bill Hammond? 
A. 
Yeah, this was his training flight. 
0. The first one is Visoski? 
A. Maybe. I can't say for sure. I really 
can't say for sure. 
0. And this is? 
A. I don't know if that's the same 
handwriting or not. 
0. Well, is there any indication up here that 
would tell us whose harxlwming rt is? David Rodgers and 
Larry Visoski --
A. No, because this is --
a 
are the pilots. 
146 
1 
daughters. I mean --
2 
O. 
Then I wont go Into the rest of his private 
3 
life. 
4 
When it says. '1 pay, I pay: what does that 
S 
mean? 
6 
A. 
Ws TAX: P•A-X is short for 
7 
'passenger: It's a Met 
O. Okay. Look, this is somebody that is listing 
9 
names of people on an airplane. Theyre going out of 
10 
their way 
11 
A. Flight. 
12 
0. 
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 
0. Well, they obviously didn't know who Todd 
16 
Meister was either • they wrote his name all wrong. 
19 
A. 
They did? 
20 
MR. PIKE: Form. 
21 
BY MR. EDWARDS: 
22 
O. 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 II? 
2 
3 
4 
5 
6 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
148 
A. 
Yeah, but they don't indicate - they don't 
indicate who's captain that day. You know. I'm not a 
handwriting expert. I can't really Honestly. I 
can't tell you for sure whose handwriting a was. 
0. Let's keep Wis one out. and toll me If this 
is -- I'm going to hand 
MR. REINHART: 
MR, EDWARDS: 
MR. REINHART: Yes. 
BY MR. EDWARDS: 
O. 
so two days later where 
is this airplane going? 
A. From Kennedy to Palm Beach. 
0. And so this Is Palm Beach to Kennedy - 
A. Yep. 
0. 
in his exhibit. The next one is Kennedy 
to Pon Beach. 
A. Correct. 
0. They come back. Where do they stay • do you 
know? 
A. What do you mean? 
0. Well, they get off on theM they stay 
somewhere until they come back on the I. 
Do you know 
where they stay? 
MR. REINHART: Can we clarify who %hey 
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149 
is? 
BY MR. EDWARDS: 
O. I guess it is: David Mullen. M 
MEM 
Tod Myster (sic). 1 pax, another pax. 
and Jeffrey Epstein - and there's a crossed 
out 'Ghislaine Maxwell? so I'm assuming she didn't go. 
A. Correct. 
I have no hoe where they stayed. I 
assume Jeffrey would stay in his home. M 
would 
stay in her apartment. As for an the others, I have 
no idea. 
O. Have you ever been to Jeffrey Epstein's home 
in New York? 
A. Just in the lower level of the entryway. 
O. Why did you go? 
A. To pick up bags for the trip to go to the 
airport and load them. 
Q. Was there anybody else there with him? 
A. I don't know with him. I never saw him 
him. We saw the guy that ran the house 
Q. Who's that - Joe-Joe? 
A. Joe-Joe would be there --
O. What's Joe-Joe's name? 
A. Joe-Joe, that's all] know, and then 
there's the actual house manager. Joe-Joe is more of 
151 
O. The next one is 
Palm Beach 
2 
to where? 
3 
A. St. Thomas. 
4 
O. To St. Thomas. 
5 
A. Right. 
6 
Q. And he has 
and 
M
I
 
and Jeffrey. 
7 
A. Right. 
8 
O. Does he loll you what happens in St. Thomas? 
9 
What he does there? 
10 
A. No, no. 
11 
O. Ever heard that he imports underage gins from 
12 
Brazil to his — 
11 
MR, PIKE: Form. 
14 
O. - Island in St. Thomas? 
15 
MR. PIKE: Form. 
16 
A. No, no. never heard that. 
17 
O. 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 
COOstruCliOn. 
24 
O. Did he tell you two or three times a day, that 
25 
he sexually abuses girls between 12 and 15 years old? 
150 
1 
a dnver, and then there's the house manager -
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 the airport. 
7 
O. Who's David Mullen? 
a 
A 
I don't know. I heard of il. It sounds 
9 
familiar. I can't remember who he is. 
10 
O. Somebody that lives in New York, Palm Beach? 
11 
A. I don't know. I don't know. 
12 
O. I'm trying to keep them in order. 
13 
So taming bad( - you know. it looks Ike they 
14 
take to JFK: David Mullen, Tod Myster (sic), some 
15 
passe era unnamed - they come back with only 
16 
and 
any idea why? 
1/ 
MR. PIKE: Form. 
18 
A. No, but, I mean, ifs not unusual for 
19 
these guys to, you know, take somebody • lel somebody 
20 
have a free ride to New York il they know them. they 
21 
aro acquaintances, need a lift. I mean, that's not 
22 
unusual. 
23 
O. How's that come about - do you know? 
24 
A. No. I don't - phone conversations, 
25 
cosklail parties. I don't know. 
152 
1 
A. 
No. 
2 
MR. PIKE: Form. 
3 
BY MR. EDWARDS: 
4 
O. 
Not something he ever mentions. 
5 
A. No, no. 
6 
MR. PIKE: Form. 
7 
BY MR. EDWARDS: 
8 
O. 
The next 
- who's on the passenger 
9 
list? 
10 
A. Jeffrey, M. 
MI, Jean Luc, David 
11 
Mullen, female, female, female. 
12 
O. 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 
O. I mean, certainly that's --
20 
A. I don't know whose handwriting that Is. 
21 
O. You're guessing, though, right? 
22 
A. 
Yeah. No, I'm guessing. I have no idea. 
23 
O. Another guess would be they're 12 years old 
24 
and you can't put them on it. 
25 
MR. PIKE: Form. 
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