PLAINTIFF JANE DOES MOTION FOR LEAVE TO PROVIDE RECENTLY-OBTAINED DEPOSITION TESTIMONY AND AFFIDAVIT DEMONSTRATING FRAUDULENT TRANSFERS BY EPSTEIN IN SUPPORT OF MOTION FOR APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN AND INCORPORATED SUPPORTING MEMORANDUM¶
CASE NO: 08-CV-80119-MARRAa¶
¶
EXHIBIT A-1 (1 of 4)¶
Certified Copy¶
IN THE CIRCUIT COURT OF THE k.11.1LENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA¶
L.M.,¶
Plaintiff,¶
CASE NO. -vs- 502008CA028051 XXXXMB AD¶
JEFFREY EPSTEIN,¶
Defendant.¶
DEPOSITION OF¶
LARRY VLSOSKI¶
October 15, 2009 10:18 p.m.¶
515 N. Flagler Drive Suite P200 West Palm Beach, Florida¶
Reported By: Wendy Beath¶
¶
ESQUIRE Altastdit Calle Compaq¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXXMB AD¶
L.M.,¶
Plaintiff,¶
-vs-¶
JEFFREY EPSTEIN,¶
Defendant.¶
DEPOSITION OF LARRY VISOSKI¶
Thursday, October 15, 2009 10:18 - 3:37 p.m.¶
515 N. Flagler Drive Suite P200 West Palm Beach, Florida 33401¶
Reported By:¶
Wendy Beath, RPR, CRR, FPR Notary Public, State of Florida Esquire Deposition Services West Palm Beach Office Job #127542¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 2 3¶
4¶
9¶
10 11 12¶
13¶
14 15 16¶
17 18¶
19¶
20¶
21¶
2¶
APPEARANCES:¶
On behalf of the Plaintiff:¶
J. INIIIII ESQUIRE ROTHSTEIN, ROSENFELDT, ADLER 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, Florida 33394¶
On behalf of the Defendant:¶
ROBERT D. CRITTON, JR., ESQUIRE BURMAN, CRITTON & LUTTIER 303 Banyan Boulevard, Suite 400 West Palm Beach, Florida 33401¶
On behalf of the Witness:¶
BRUCE REINHART, ESQUIRE 250 South Australian Avenue Suite 1400 West Palm Beach, Florida 33401¶
ALSO PRESENT:¶
CARA L. UIRE¶
ADAM D. HOROWITZ, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160¶
RICHARD H. WILLITS, ESQUIRE (VIA TELEPHONE) RICHARD H. WILLITS, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461¶
¶
ESQUIRE ."".._¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
WITNESS: DIRECT CROSS REDIRECT RECROSS¶
LARRY VISOSKI¶
BY MR. 6¶
BY MR. CRITTON:¶
BY MR. 220¶
BY MR. CRITTON: 221¶
3¶
INDEX¶
214¶
EXHIBITS¶
NUMBER DESCRIPTION PAGE¶
PLAINTIFF'S EX. 1 FLIGHT LOG BOOK (MARKED IN PREVIOUS DEPO)¶
PLAINTIFF'S EX. 2 MESSAGE PAD 119¶
PLAINTIFF'S EX. 3 MESSAGE PAD 119¶
PLAINTIFF'S EX. 4 COMPLAINT 139¶
PLAINTIFF'S EX. 5 INMATE VISITOR LOG 161¶
¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1¶
2¶
3¶
4¶
5¶
6¶
7¶
8¶
9¶
10¶
11¶
12¶
13¶
14¶
15¶
16¶
17¶
18¶
19¶
20¶
21¶
22¶
23¶
24¶
25¶
4¶
PROCEEDINGS¶
Deposition taken before Wendy Beath Certified Realtime Reporter and Notary Public in and for the State of Florida at Large, in the above cause.¶
MR. We're going to put something on the record about -- well, we'll do it this way --¶
MR. REINHART: Do it at the end, after we get him -- whatever you want. It's your show.¶
MR. : Okay. There were -- I don't even think Mr. Willits is aware of this. There was asubpoena duces tecum for this witness, as well as the previous witness, which was another pilot, Dave Rogers, and that duces tecum was to bring the flight logs related from 1998 through 2005. What was produced at the previous deposition were flight logs from 2002 through 2005, and now Mr. Reinhart has agreed to produce the remainder of the flight logs requested, those going from 1998 through 2002.¶
MR. REINHART: Correct. They're pilot logs, not flight logs. There are other records we indicated are corporate records, and with those you have to deal with Mr. Critton.¶
MR. CRITTON: However, with the proviso, too,¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 2 3 4 5 6 7 8 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.¶
9 10 MR. : Okay. Is that all you want to put on?¶
11 MR. CRITTON: Yes.¶
12 13 14 MR. : I'm not saying I necessarily agree or disagree with you. That's something that we'll deal with some other day.¶
15 16 17 MR. CRITTON: Bruce, you'd better produce these records, but there has to be some sort of understanding before¶
18 MR. REINHART: Correct.¶
19 20 21 22 23 MR. : I won't do anything until you file whatever you -- until we work whatever it is out in court. I'll say that on the record, that I'm not doing anything with the records outside of my office until some judge deals with it.¶
24 25 MR. REINHART: And for the record, I'll adopt what Mr. Critton said on this one limited occasion.¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1¶
2¶
3¶
4¶
5 6¶
7¶
8¶
9¶
10¶
11¶
12¶
13¶
14¶
15¶
16¶
17¶
18¶
19¶
20¶
21¶
22¶
23¶
24¶
25¶
6¶
MR. : All right.¶
Thereupon,¶
(LARRY VISOSKI)¶
having been first duly sworn or affirmed, was examined and testified as follows:¶
THE WITNESS: Yes, i do.¶
DIRECT EXAMINATION¶
BY MR. -:¶
Q. Can you tell us your name for the record.¶
A. Visoski, Jr.¶
Q. And Mr. Visoski, have you ever had your deposition taken before?¶
A. No.¶
Q. Okay. Here's the process: I'm going to ask you questions. You're going to give us answers. Try to give us answers that we all understand and that the court reporter can take down, such as yes, no, or some other verbal answer that we can understand. It's easy when we get in acasual conversation to nod or shake your head, and the court reporter is not writing pictures or anything else.¶
A. I understand.¶
Q. The other thing is, and I've been accused of this in other depositions -- I don't know if it's true or not -- but I need to wait until you finish answering¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
2 the question and you need to wait until I finish asking the question.¶
3 A. So you're not allowed to interrupt me?¶
4 Q. And you're not allowed to interrupt me.¶
6 Q. Right.¶
8 9 MR. CRITTON: Cara just snickered when you said you've been accused because she recognizes it's true.¶
10 11 MR. : I don't know what the meaning of her snickering was.¶
12 BY MR.¶
13 14 15 16 17 Q. But for what it's worth, if you don't understand the question or I've asked a bad question, I don't want you to guess. Give me the best answer to the best of your knowledge and if you need me to rephrase it, I will.¶
18 A. Okay.¶
19 Q. Okay. Tell me your current address.¶
20 21 A. Riviera Beach, Florida 33404.¶
22 Q. How long have you lived there?¶
23 A. Approximately nine years.¶
24 Q. Okay. Who do you live there with?¶
25 A. My wife and one child at this time.¶
A. Like I just did?¶
¶
ESQUIRE Ainsadu Gasle Cospaar¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 Q. All right. How many children do you have?¶
2 A. Two.¶
3 Q. How old are they?¶
4 A. Fifteen and eighteen.¶
5 6 Q. And is the 18-year-old, is not living with you?¶
7 A. She's off in school.¶
8 Q. Okay. What school is that?¶
9 A. Syracuse.¶
10 Q. Who's your employer right now?¶
11 A. NES, LLC.¶
12 Q. How long has NES, LLC been your employer?¶
13 14 A. I'm guessing. I'd say back 1991. I have to do the math, but 17, 18 years.¶
15 Q. Has that been your only employer since 1991?¶
16 A. Yes.¶
17 18 Q. And has that been your only source of income since 1991?¶
19 A. Yes.¶
20 Q. And what is NES, LLC?¶
21 22 A. I don't really know. I mean, it's the company that my check comes from.¶
23 24 Q. What do you do for NES, LLC that results in them paying you?¶
25 A. I am chief pilot for the aircraft and¶
¶
8¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 helicopters.¶
2 3 Q. And do you have a specific boss or somebody you answer to at NES, LLC?¶
4 5 6 7 A. Several people would call to schedule flights from the office, being it either Mr. Epstein or, you know, I would just get a phone call and they would schedule a trip.¶
8 9 Q. Okay. Aside from Mr. Epstein, who else would there be that would call to schedule flights?¶
10 A. Leslie.¶
11 Q. Leslie who?¶
12 A. Leslie Gruff.¶
13 14 Q. When's the last time you talked to Leslie Gruff?¶
15 A. Probably two weeks ago, three weeks ago.¶
16 Q. And where is she currently?¶
17 18 A. I believe in New York, is where I spoke to her on the phone last.¶
19 20 Q. What's the telephone number you call to reach Leslie Gruff?¶
21 A. (212)750-9895.¶
22 Q. And what address is Leslie Gruff at?¶
23 A. Do you mean where the office is located?¶
24 Q. Correct.¶
25 A. 301 East 66th Street.¶
¶
ESQ1)Ingc.¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 2 3 Q. And it's my understanding from other depositions that there are also apartments in that 301 East 66th Street building?¶
4 A. Yes.¶
5 6 7 Q. And Mr. Epstein either owns or leases or rents certain of those apartments. Is that your understanding?¶
8 MR. CRITTON: Form; speculation.¶
9 10 THE WITNESS: I'm only speculating. I don't -- to my understanding, I don't know.¶
11 BY MR.¶
12 13 Q. Do you know other people that live in that building?¶
14 15 A. Well, it would be myself, Dave Rogers -- well, when you say "live," explain.¶
16 Q. When you're saying yourself and Dave Rogers --¶
17 18 A. See, we don't live there. I mean, we have - we would stay there when we would have atrip.¶
19 20 21 Q. Okay. When you would fly up to New York and land in New York, the place where you would stay, is that 301 East 66th Street?¶
22 A. Yes, that's correct.¶
23 24 Q. That's also a location you've indicated in this deposition that is the office for NES, LLC?¶
25 A. Yes.¶
10¶
¶
ESQUIRE nm..t ","¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 Q. What floor or suite number is NES, LLC in?¶
2 3 4 5 A. I believe -- well, I don't know that NES, LLC has an office there. I know that's where Leslie has the phone number where I call. So I don't know for a fact if NES, LLC has an office there.¶
6 7 8 Q. And what suite number, then, would Leslie Gruff sit in to answer that telephone number at 750-9895?¶
9 A. I think it's 10F.¶
10 11 12 Q. And when you stay at 301 East 66th Street, what suite number or what apartment number do you stay in?¶
13 A. 12C.¶
14 Q. And how about Dave Rogers, where does he stay?¶
15 16 A. I'm guessing, because it's been some time since we've been there, 10B, but don't quote me on it.¶
17 18 19 Q. Who are the other people in that building that you know to stay there on a regular -- fairly regular basis?¶
20 21 22 23 A. I've seen people in the elevator that, you know, have been on the airplane. Case in point, maybe, but I don't know for a fact that she lives there, or anybody else for that matter.¶
24 25 Q. Okay. When you say you've seen on the elevator --¶
11¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 2 3 4 A. I only assume she lives there. I don't know for a fact. I'm trying to be honest and factual for you. So I couldn't honestly say if I knew she lived there or not.¶
5 Q. Where do you think lives?¶
6 A. I would think she lives there.¶
7 Q. You don't have abetter location?¶
8 A. I don't have another location.¶
9 Q. Anybody else?¶
10 11 12 13 A. Not to my knowledge. Imean, I'd only be guessing that people live in that building that -- you know, I don't have any facts to prove that they actually live there. I mean, I don't think you want me to guess.¶
14 15 Q. Well, NES, LLC, would you say that the owner or controller of that company is Jeffrey Epstein?¶
16¶
17¶
18 BY MR. :¶
19 20 Q. Jeffrey Epstein is somebody you've indicated that you've worked for for 17 or 18 years, right?¶
21 A. Yes.¶
22 23 Q. And over the 17 or 18 years you've become personally close with him as well, correct?¶
24¶
25¶
12¶
MR. CRITTON: Form.¶
THE WITNESS: I don't know that for afact.¶
MR. CRITTON: Form.¶
THE WITNESS: I don't understand how you mean¶
¶
ESQUIRE •C Al•••04.• Odle COMPIZY¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 "close." Define that.¶
2 BY MR. a¶
3 4 Q. Well, more so than just a pilot that takes him from Point A to Point B?¶
5 A. That is my job.¶
6 7 8 9 Q. Right. But you know him on a personal level and that you've had personal conversations that don't necessarily deal with flying from Point A to Point B; isn't that right?¶
10 MR. CRITTON: Form.¶
11 12 13 THE WITNESS: More specific, meaning we talk about cars. I mean, does that make you a personal friends?¶
14 BY MR.¶
15 Q. Have you ever gone to his house to eat?¶
16 A. No.¶
17 Q. Have you been to his New York home?¶
18 A. Yes.¶
19 20 Q. How many occasions have you been to his New York home?¶
21 MR. CRITTON: Object to form.¶
22 23 THE WITNESS: We normally pick up luggage in the lobby, so it would probably be quite often.¶
24 25 Any time we depart out of New York, we stop by the house and pick up luggage and head to the aircraft.¶
13¶
¶
ESQUIRE ia Menai, Golle Coen.,¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 BY MR.¶
2 3 Q. Other than picking up luggage, have you been to his home to visit or socialize with him?¶
4 A. Not to socialize, no.¶
5 Q. Have you been to his Palm Beach home?¶
6 A. To?¶
7 Q. To Mr. Epstein's Palm Beach house?¶
8 A. Right.¶
9 Q. Have you been there?¶
10 A. Yes.¶
11 Q. Have you been inside?¶
12 A. Yes.¶
13 14 Q. And how many occasions have you been inside that home?¶
15 16 17 18 19 A. The same, as far as picking up luggage, and that would be on aregular basis, you know, for a departure. We wouldn't always go to the house to pick up luggage, but it made it easier for loading the aircraft, getting it done prior to departure.¶
20 21 22 Q. Is that the only reason that you have ever gone to the Palm Beach home over the last 18 years, is to pick up luggage?¶
23 A. No.¶
24 Q. What other reasons have you gone there?¶
25 A. I've set up several home theater equipments,¶
¶
14¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 you know, televisions and such.¶
2 3 Q. Is that another hobby or job or something of yours?¶
4 A. Both.¶
5 Q. Does he pay you for that?¶
6 A. Not any more than my salary.¶
7 Q. What's your current salary?¶
8 A. At this time, 180,000.¶
9 Q. And what are you paid $180,000 to do?¶
10 A. To manage his aircraft.¶
11 Q. What does that entail?¶
12 13 14 15 16 A. Scheduling maintenance. Anything that has to do with any flight, whether it be weather, flight planning, time and distance to and from alocation, any logistics involved in running an operation that has aircraft.¶
17 18 Q. In addition to the 180,000, does he give you bonuses as well?¶
19 A. There have been Christmas bonuses.¶
20 21 Q. Over the years, you mean, there have been Christmas bonuses?¶
22 A. Yes.¶
23 Q. Is 180,000 the most he's ever paid you?¶
24 A. No.¶
25 Q. All right. Were you making -- when was the¶
15¶
¶
ESQUIRE aa .:..,m.. c.. Com WI¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 2 last time that you were making an amount different than 180,000?¶
3 A. Last year.¶
4 Q. That would be 2008?¶
5 6 7 8 A. That would be correct. Yeah, we all took a salary cut, I don't know the exact date. It might have been 2008, last year. It was last Christmas we all took a10 percent salary cut.¶
9 Q. Do you know why?¶
10 A. Economic reasons.¶
11 12 Q. And who told you that you were going to have to take the salary cut?¶
13 A. Darren Indyke.¶
14 Q. And did you ask for an explanation?¶
15 16 A. He explained it was due to economic reasons throughout the country.¶
17 18 Q. Okay. So in 2008, how much was -- were you being paid by NES, LLC?¶
19 A. 200,000.¶
20 21 Q. And is 200,000 the most that you've ever made from NES, LLC?¶
22 A. Yes, sir.¶
23 24 Q. And on top of that $200,000, did you get a bonus that year as well?¶
25 MR. REINHART: Which year are you talking¶
¶
16¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 about?¶
2 2008.¶
3 4 5 THE WITNESS: That year, I think we skipped Christmas bonuses that year. The last bonus might have been 2007.¶
6 BY MR. =In¶
7 8 9 Q. If you ever got a bonus from Mr. Epstein and I'm only deriving this from you using the term "Christmas bonus."¶
10 A. Holiday bonus.¶
11 12 13 14 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?¶
15 A. Yes.¶
16 17 Q. Okay. And how much was the 2007 holiday bonus?¶
18 19 20 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 $10,000.¶
21 Q. And in 2007 you also made $200,000?¶
22 A. Yes.¶
23 Q. Okay.¶
24 25 A. With aquestion mark. I'm trying to be as accurate as I can, but yes.¶
¶
ESQ•A:san1J1BC. ,¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutIons.com¶
1 Q. Something pretty close to that?¶
2 A. Yes, sir.¶
3 4 Q. Okay. So with the bonus it was 210,000, roughly?¶
5 A. Right.¶
6 7 Q. Okay. And how long were you making that salary?¶
8 9 10 11 12 A. Probably -- he was very religious about giving annual increases, so I would probably say 2006, you know, it was -- we would get increment -- increases of five or $10,000 each year. So I would say 2006. So it graduated, you know, progressive.¶
13 14 15 16 Q. Okay. Do you remember the progression if we start at 1991? Do you remember roughly what the progression was up through 2007/2008, when you were making $200,000?¶
17 A. No, I wouldn't know the progression.¶
18 19 20 Q. Okay. Do you remember what you were making from -- and was NES, LLC the company paying you back in 1991?¶
21 22 A. I don't know. I don't remember. Let me say it that way. I don't remember.¶
23 24 Q. Okay. When -- how long do you remember NES, LLC being the payer of your check?¶
25 A. Personally, two years, because I've never seen¶
¶
18¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 2 my paycheck. So I don't even know what's written on the top of it.¶
3 4 Q. That would be something that only your wife would see, I'm assuming?¶
5 6 7 A. You're right, since she probably wouldn't know the answer either, because she's looking at the right column and not the top column.¶
8 9 Q. Right. When is the first time that you had heard the name NES, LLC, that company?¶
10 11 12 A. Five, six years, and even questioned what it stood for. And I think to this day I couldn't answer that honestly, what it stands for.¶
13 14 15 Q. Okay. But it's your understanding that the NES, LLC is paying you for the work that you do as a pilot or maintain the planes for Jeffrey Epstein?¶
16 A. To my understanding, yes.¶
17 18 19 Q. And back in 1991, do you know if it was a different company that was paying you or if it was Jeffrey Epstein directly paying you?¶
20 A. I don't remember. I mean, I don't.¶
21 22 23 24 Q. Okay. Throughout your career with -- as a pilot for Jeffrey Epstein, since 1991, has there ever been a time when you believe you were paid directly from Jeffrey Epstein personally versus some company?¶
25 A. Not to my knowledge, no.¶
¶
ESQUIRE vv Atatand,r Gage Campasy¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com¶
1 2 3 Q. Okay. So whether it was NES, LLC or some other company, it was all of asudden acompany name, to the best of your knowledge?¶
4 A. Exactly, yes.¶
5 6 Q. And back in 1991, do you remember approximately how much you were being paid that year?¶
7 A. Fifty-five or 60,000, is maybe what I started.¶
8 Q. Okay.¶
9 A. You're going back along ways.¶
10 Q. Yes.¶
11 A. I'm trying.¶
12 13 Q. Your relationship goes back that far. That's why I chose that year.¶
14 A. Right.¶
15 Q. Okay. Did you get bonuses even back that far?¶
16 A. Yes, sir.¶
17 18 Q. And do you remember what your bonuses were approximately?¶
19 20 A. 5,000. I mean, that was kind of the -- the starting point.¶
21 22 23 Q. Okay. In addition to monitary bonuses, were there ever gifts or any other type of compensation that NES, LLC or Jeffrey Epstein provided you?¶
24 A. Yes.¶
25 Q. And is that over the span of the 18 years?¶
20¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
A. Yes.¶
5 A. A pool heater.¶
6 Q. When was that?¶
8 Q. Okay. Why did you get that?¶
10 11 12 A. I had built apool and I didn't have aheater and he kind of laughed at me saying, "How can you have a pool without a heater?" So he says, "You ought to get a heater."¶
13 Q. Where were you when you had that conversation?¶
14 A. In the airplane.¶
15 Q. How did he know that you had built apool?¶
16 A. Just in general conversation.¶
17 18 Q. You were having a conversation with Jeffrey Epstein?¶
19 A. Yes.¶
20 21 Q. And this is something that was happening on the airplane, this conversation?¶
22 23 A. During the flight. Yeah, it would have been like on cruise or something.¶
24 25 Q. that Okay. When you say "during the flight," does¶
¶
Q. Okay. Tell me what some of those items are.¶
A. I remember one specifically was apool heater.¶
Q. Excuse me?¶
A. 1995-ish.¶
ESQUIRE "mm...."...""¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com¶
1 A. Again, you're going back along ways.¶
2 3 Q. I understand. We're talking about 1995 right now.¶
4 A. Yes.¶
5 6 Q. You're having a conversation with Jeffrey Epstein. Who is flying the airplane?¶
7 A. The auto pilot and there's two crew.¶
8 9 Q. Okay. So are you back in the back portion or is he up in the cockpit?¶
10 A. Up in the cockpit.¶
11 12 Q. Okay. Jeffrey Epstein sometimes comes up there?¶
13 A. Just, yeah, in between the two pilot seats.¶
14 15 Q. All right. Is that something that was typical, to have conversations like that?¶
16 A. Mm-hmm.¶
17 Q. Yes?¶
18 A. Yes. No nodding.¶
19 20 Q. And would those conversations be directed mainly with you or with the other pilots as well?¶
21 A. Mainly with me.¶
22 23 24 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?¶
25 A. Well, that's chief pilot.¶
¶
22¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
6 THE WITNESS: Right.¶
8 9 Q. Okay. And you feel like over the years your relationship with Jeffrey Epstein has been pretty good?¶
10 A. Yes.¶
11 12 Q. And you have been closer to him over the years as you've grown to know him?¶
13 MR. CRITTON: Form.¶
14 15 16 17 18 THE WITNESS: The same throughout the same year. We never got any closer than 1991 than I am with him now. I'm very professional.at what I do and know the line between being professional and thinking you're somebody's buddy.¶
19 BY MR.¶
20 21 Q. Okay. So that's not something that you think you are? You don't think you're his buddy?¶
22 A. No, sir.¶
23 Q. Do you consider yourself his friend?¶
24 A. I believe so.¶
25 Q. Do you think he considers you his friend?¶
¶
Q. But more so than that, if there's going to be a casual conversation about a pool or a pool heater or whatever, it's going to be with you most likely if he's going to be talking to pilots, right?¶
MR. CRITTON: Form.¶
BY MR.¶
ESQUIBE,¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 A. I think so.¶
2 Q. All right. What makes you think that?¶
3 MR. CRITTON: Speculation.¶
4 5 THE WITNESS: He's always been kind and respectful.¶
6 BY MR.¶
7 Q. Ever invited you to dinner?¶
8 A. No, sir.¶
9 10 Q. Have you ever associated or socialized with him during the day at any of his homes?¶
11 A. Only during a business reason.¶
12 13 14 Q. Okay. What are the other -- are the places that you believe that Mr. Epstein owns? I know we've talked about this Manhattan -- the Manhattan house.¶
15 I've read the articles about it, the Palm Beach mansion.¶
16 17 But what other places are you familiar with that Mr. Epstein owns?¶
18 MR. CRITTON: Form; predicate, speculation.¶
19 20 21 22 23 THE WITNESS: To answer it honestly, I don't know specifically that he owns any of the residences, to be honest. I would only assume that he owns. So if you want me to answer honestly, I don't know that he owns any of the other.¶
24 BY MR.¶
25 Q. Okay. Well, what would be the basis for your¶
¶
24¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
3 A. He goes there, but I don't assume -- you don't have to own ahouse to go to it.¶
5 6 Q. And not only does he go there, you're aware that he spends the night there; he resides there sometimes, correct?¶
8 Q. When he's in Palm Beach, that's where he --¶
10 11 Q. -- sleeps? Right. When he's in New York, do you know where he sleeps?¶
12 A. No.¶
13 14 15 Q. But you've been to aparticular house in New York that's avery large house that we've all read about that you picked up luggage at, right?¶
16 A. Yes, sir.¶
17 MR. CRITTON: Form.¶
18 BY MR.¶
19 20 21 Q. And that home, do you know that -- I know that you're saying that you haven't done apublic record search to make sure that Jeffrey Epstein owns it.¶
22 A. Yeah.¶
23 Q. But you assume that he does?¶
24 A. Assuming.¶
25 Q. That's where he sleeps when he's in New York?¶
assumption that he owns the home in Palm Beach?¶
A. Yes.¶
A. He sleeps.¶
¶
EsQuejseBE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1¶
2¶
3¶
4¶
5¶
6¶
7¶
8¶
9¶
10¶
11¶
12¶
13¶
14¶
15¶
16¶
17¶
18¶
19¶
20¶
21¶
22¶
23¶
24¶
25¶
26¶
MR. CRITTON: Form.¶
THE WITNESS: I assume.¶
BY MR.¶
Q. That's where his luggage is when you pick it up?¶
A. Doesn't mean he owns it.¶
Q. Right. But that's where it is?¶
A. Yes, sir.¶
Q. Do you know of anybody else who owns that home in New York?¶
A. No.¶
Q. Okay. Have you been to his ranch in New Mexico?¶
A. Yes.¶
MR. CRITTON: Form.¶
BY MR.¶
Q. 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.¶
Q. And where would you land?¶
A. Depending upon the aircraft, either Albuquerque or Santa Fe.¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
2 A. Public.¶
3 Q. Public, okay. Are there any private landing places where you would land any airplanes in New Mexico?¶
6 Q. That you have landed --¶
8 Q. -- his airplane?¶
9 A. Yes.¶
10 Q. Where?¶
11 A. We have a 4500-foot strip on the ranch.¶
12 Q. When you say "we," yourself and somebody?¶
13 A. The company.¶
14 Q. What company?¶
15 16 A. Well, I should say -- I see where you're going with that. The ranch owns -- whoever owns the ranch.¶
17 The ranch has a runway on it.¶
18 19 Q. Okay. And you've landed an airplane on that runway?¶
20 A. That ranch, yes.¶
21 22 Q. How many times do you think you've landed there?¶
23 A. Ten.¶
24 25 Q. ranch? All right. And have you been inside his¶
¶
Q. Are those private airports?¶
A. There are.¶
A. That I have.¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com¶
1 A. Yes.¶
2 MR. CRITTON: Form to the last question.¶
3 4 5 MR. REINHART: Can you clarify, the physical ranch or the residences or the structures on the ranch?¶
6 7 MR. al I don't have a good visual appreciation for it.¶
8 BY MR.¶
9 10 11 12 Q. Why don't you describe it in your words what this ranch that we are talking about looks like. And I've heard it referred to as the Zorro Ranch. Have you heard that?¶
13 A. I've heard that.¶
14 15 16 Q. That's the ranch we're all familiar with, we're talking about where the runway is and everything else?¶
17 A. Yes.¶
18 19 Q. Describe it in your own words, the landscaping of this ranch. What do we have on it?¶
20 21 A. There is ahouse up on the, alarge house.¶
22 Q. How big?¶
23 24 A. Big. I've read 40,000 square feet in the paper.¶
25 Q. Have you been to it?¶
28¶
¶
ESQUIRE AN[•Nlr 01110 COaryal¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
2 Q. Does that seem like it's feasible, approximately 40,000 --¶
5 Q. What else do we have on it?¶
6 A. There is a compound that has kind of motel room type -- they call it bunkhouse.¶
10 Q. Okay. And what is that primarily used for?¶
11 12 13 14 A. For the people that work on the ranch, they reside there. It's also aplace where anybody that traveled on the airplane would stay. It's kind of like, you know, a hotel room.¶
15 16 Q. And how far is that from the first house that you described, the 40,000 square foot house?¶
17 A. It's probably 4 miles.¶
18 19 Q. Okay. So the Zorro Ranch is arather large area of property?¶
20 A. Yes.¶
21 22 23 24 Q. And how many times -- I know we just talked about how many times you've been in the house, but how many times have you been on that ranch in New Mexico, the Zorro Ranch?¶
25 A. Thirty to fifty times over the years. That's¶
A. Yes.¶
A. I think so, yes.¶
Q. Where's the bunkhouse located?¶
A. At the entrance to the ranch.¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 aguesstimate.¶
2 3 Q. Is that over -- when was the first time that you went to that ranch?¶
4 5 A. A guess, I don't know when it was, actually, our first trip, but 1995/'94.¶
6 7 8 Q. Okay. And do you believe Jeffrey Epstein and/or a corporation owned or controlled by him to be the sole owner of that ranch?¶
9 A. I don't know any of those details.¶
10 11 Q. Have you ever talked to Jeffrey Epstein about who owns that ranch?¶
12 A. No.¶
13 14 Q. Do you know of anybody else who may own that ranch?¶
15 A. Not to my knowledge.¶
16 17 18 Q. Other than Jeffrey Epstein, do you know of anybody else who regularly stays there when they're in New Mexico?¶
19 A. Not to my knowledge.¶
20 21 Q. Does Jeffrey Epstein stay there when you're in 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 akey.¶
25 Q. One way or another, he gets in, right?¶
30¶
¶
ESQUIRE "......"..¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
6 Q. You assume he sleeps?¶
8 Q. Okay.¶
9 MR. CRITTON: This is really¶
10 BY MR.¶
11 12 13 Q. Other than the pool heater in 1995, have you ever received any other gifts on top of the compensation 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?¶
18 A. Ten years ago at least.¶
19 20 Q. Do you know if he's ever deeded anyone else in this world land on the ranch to build a home?¶
21 A. Not to my knowledge.¶
22 Q. Why did he do that?¶
23 24 25 A. We would vacation out there and my wife fell in love with New Mexico and we were looking for property.¶
A. Yes, sir.¶
Q. And he sleeps there?¶
A. Yes.¶
Q. Okay.¶
A. I assume he does.¶
A. I do. I think.¶
ESQUIRE¶
¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 Q. And did you talk to him about that?¶
2 3 4 5 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 give you a spot to build ahome on." So I built a house.¶
6 7 Q. So how long has ahome actually been on that property?¶
8 A. Nine years.¶
9 Q. And that's a home that you own?¶
10 A. Yes, sir.¶
11 12 13 Q. And that's a home that was -- when I say "you own it," is there amortgage on it or did he give it to you free and clear?¶
14 15 A. No, no, I paid for the house. I made payments on it.¶
16 Q. All right. So what did he actually give you?¶
17 A. 40-acres of land.¶
18 Q. That you did not have to pay for?¶
19 20 21 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.¶
22 23 Q. How often have you visited that piece that home that you own?¶
24 25 A. My wife would spend summers out there with the kids.¶
32¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 Q. Okay. But that's on the Zorro Ranch?¶
2 A. Yes.¶
3 4 5 Q. So in addition to the 50 or so times you've been to the Zorro Ranch, you've been to your property that's on the Zorro Ranch?¶
6 7 8 A. Yes, which over the years, it's once-a-year visits. So I mean, it is included in the 50 times that I've been there.¶
9 10 11 Q. Okay. And did you have aconversation with him that led to him giving you or gifting you 40-acres of land?¶
12 13 A. We talked about it because he knew I was looking for a home out there.¶
14 15 16 Q. Okay. In gifting you that land, did you consider yourself at that point in time to be more than just his pilot, as more of afriend?¶
17 18 19 20 A. No. You're using the word "gifting." I paid for the land. I don't recall what it was. But you use the word "friend." I don't know that a-- sure, he was afriend. I mean...¶
21 22 Q. Well, did he give Dave Rogers any land out on the New Mexico ranch?¶
23 A. No.¶
24 25 Q. Okay. When you say you paid for it, I thought that I asked that question, "Did you pay for the¶
¶
ESQUIRE ea Aland.: OMIO COMPU7¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 2 40-acres?" I thought your answer was, "I don't know, I'd have to go back and look."¶
3 4 Are you saying now that you did pay for that land?¶
5 6 7 A. I don't remember. If there was a sum of money, it was just for, you know, the legal purpose of a transfer of ownership of the land.¶
8 9 Q. Okay. If it was asubstantial amount of money, that's something that you would have remembered?¶
10 11 A. exactly. No, it was not asubstantial amount.¶
12 13 Q. Okay. Do you remember approximately how much money you had to give Jeffrey Epstein for that land?¶
14 15 A. I would only be guessing. It might have been five dollars. To my knowledge, I don't remember.¶
16 17 Q. Okay. So when I'm saying he gave you the land, he may have actually given you the land?¶
18 A. Sure.¶
19 20 Q. Okay. And to the best of your knowledge, he's never given anyone else land out there?¶
21 A. Not to my knowledge.¶
22 MR. CRITTON: Form.¶
23 BY MR.¶
24 25 Q. All right. How big is this house that you built on the ranch?¶
34¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
2 Q. Were you ever at that house at the same time when he's at his house that's on that Zorro Ranch?¶
10 11 Q. All right. We started back in 1991 with you making around $55,000 ayear and that has progressed over time to a point where in 2007 you were making $200,000 ayear. I don't want to go through every single year; that would take a really long time. But the progression, was that on ayearly basis normally or after two years or three years?¶
12 A. Yearly basis.¶
13 14 Q. Okay. And would that normally be in increments of?¶
15 A. $5,000.¶
16 17 18 19 20 Q. Okay. You've talked about acouple other gifts that have been given to you from Jeffrey Epstein over the years; one is apool heater in 1995 and now some 40 acres of land on his New Mexico ranch. Any other gifts you can think about?¶
21 A. No other gifts.¶
22 23 24 25 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 adiscount on or otherwise that¶
¶
A. 1800 square feet.¶
A. Yes.¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 you feel was compensation for you working for him?¶
2 A. I drive acompany car. I mean...¶
3 Q. Okay. What kind of car?¶
4 A. A Hummer.¶
5 6 Q. You say "a company car." That's owned by NES, LLC?¶
7 8 A. No, I think the registration has Zorro Development on it.¶
9 Q. What is Zorro Development?¶
10 11 A. I believe that's the ranch, or at least it has the name of the ranch. I don't know what the entity is.¶
12 13 Q. And it's your understanding that that's a company vehicle?¶
14 A. Yes.¶
15 Q. And where is that vehicle primarily garaged?¶
16 A. At my home.¶
17 Q. In West Palm Beach or in the Zorro Ranch?¶
18 A. No, here in West Palm Beach.¶
19 20 Q. All right. And is there only one company vehicle that you're issued?¶
21 A. Yes, sir.¶
22 23 Q. And is that something that was that you did not have to pay for?¶
24 25 A. No, it's just something I drive. I mean, it's not titled to me or anything like that. It's just acar¶
¶
36¶
ESQUIRE .M"Co n¶
Toll Free: 866.709.8777 Facsimile: 661.394.2621¶
3 Q. All right. You've worked for him for 18 years. I don't even know how long the Hummer would last, but presumably, that's not the car you've had over the entire 18 years. Have you always had a company car?¶
6 A. No, I haven't, no.¶
9 10 Q. Do any other members of Mr. Epstein's piloting team have company cars?¶
11 A. No.¶
12 Q. Only you?¶
13 A. Yes.¶
14 15 Q. And do you know how that decision was made to get you a company vehicle?¶
16 A. No.¶
17 Q. What do you use that vehicle for?¶
18 A. To and from the airport.¶
19 20 also? Q. All right. Do you use it for personal reasons¶
21 A. I guess, yes.¶
22 Q. I mean, that's your primary vehicle?¶
23 A. Yes, or I drive my wife's car.¶
24 Q. Which is?¶
25 A. Type of car?¶
that I drive.¶
Q. When did you get the Hummer?¶
A. Probably three years ago.¶
¶
ESQUIRE to Almada Galls CompstT¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 Q. Yes.¶
2 A. A Mercedes.¶
3 4 Q. And is that something that was also agift from Mr. Epstein?¶
5 A. No, sir.¶
6 Q. What type of Mercedes is that?¶
7 A. A ML 430, ten years old.¶
8 9 10 11 Q. All right. Are there any other items - company car, the land in New Mexico, the pool heater any other items that Mr. Epstein has given you over time as compensation or reward or anything else?¶
12 A. No, sir.¶
13 14 Q. And your only income is from Mr. Epstein or his companies?¶
15 A. Correct.¶
16 Q. Okay. And it's been that way since 1991?¶
17 A. Yes.¶
18 19 Q. How did you meet Mr. Epstein or become involved with him in 1991?¶
20 21 22 23 A. We heard at the airport that Mr. Epstein was purchasing an airplane when Dave Rogers and myself were living in Columbus, and we had the opportunity to interview with him, and we did and got the job.¶
24 Q. And this is before he owned the airplane?¶
25 A. Yes.¶
¶
38¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
2 A. The Hawker.¶
6 A. Five years, guesstimate; four or five years.¶
8 A. Yes.¶
9 10 11 Q. Did you keep any type of logs or documentation as to who would have been flying on that airplane if you transported any individuals?¶
12 13 A. The same logs as you possess now are the flight logs.¶
14 Q. Okay.¶
15 A. That's the standard for the industry.¶
16 17 Q. So that's something that you kept, or that Dave Rogers kept?¶
18 A. Dave Rogers.¶
19 20 21 22 23 Q. 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?¶
24 A. the corporation actually, they belong to.¶
25 Q. Okay.¶
Q. And which airplane was that?¶
Q. Does he still have the Hawker?¶
A. No.¶
Q. How long did he have that plane?¶
Q. So sometime in the mid '905?¶
¶
ESQVIcalA3m,¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1¶
2¶
3¶
4¶
5¶
6¶
7¶
8¶
9¶
10¶
11¶
12¶
13¶
14¶
15¶
16¶
17¶
18¶
19¶
20¶
21¶
22¶
23¶
24¶
25¶
BY MR. 40¶
MR. REINHART: That was acompound question.¶
You might want to split it in half.¶
MR. OEM Okay.¶
Q. What documents do you believe exist that indicate names of individuals that have been passengers on Mr. Epstein's airplanes?¶
MR. REINHART: Are we going back all the way from '91 to the present?¶
MR. : Sure.¶
THE WITNESS: You're talking about the Hawker?¶
BY MR.¶
Q. Any airplanes. What documents would there be?¶
A. There would be the same: Flight logs and passenger manifests would exist.¶
Q. And are either of those required?¶
A. The flight log is required for the aircraft to track times and landings.¶
Q. And in the flight log, is it required that you designate the names of the passengers?¶
A. No.¶
Q. That's just something that Dave Rogers did on his own?¶
A. Everybody does that. It's more for Internal Revenue.¶
¶
ESQUIRE aaaaaa Calle Cenasy¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
3 A. Exactly, weight and balance.¶
5 Q. Have you ever kept any flight logs that have names of people on the airplane?¶
6 A. When you say "kept," I have filled out flight logs or the passenger manifest, yes.¶
8 Q. By "kept" I meant maintained to where they're in your possession either on paper or computer?¶
10 A. We keep --¶
11 12 13 MR. REINHART: Can you differentiate a flight log from the pilot's log that we showed you earlier?¶
14 MR. : Okay.¶
15 BY MR.¶
16 17 Q. I'm talking about -- I don't know that it's called a flight log, a pilot's log or any kind of log.¶
18 A. They are different, yes.¶
19 20 21 22 Q. Yeah. I'm asking about, have you kept or do you have any documentation that would indicate the names of passengers that have flown on any of Jeffrey Epstein's planes?¶
23 A. No.¶
24 Q. Either in the form of paper or on a computer?¶
25 A. No.¶
Q. Okay. If something happens, they know who is on the plane?¶
¶
ESQUIRE ."m...."¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com¶
1 Q. Makes that easy.¶
2 A. Okay.¶
3 Q. In 1991, were you the chief pilot?¶
4 A. No.¶
5 Q. Somebody else was the chief pilot?¶
6 A. Yes.¶
7 Q. Who's that?¶
8 A. Dave Rogers.¶
9 10 Q. All right. At what point in time did you become chief pilot and switched with Dave Rogers?¶
11 A. Six years ago; five, six years ago.¶
12 Q. Why?¶
13 A. Professionalism, technique.¶
14 Q. What do you mean by that?¶
15 16 17 A. The way Dave would operate an aircraft, Jeffrey knew the difference when I was flying and when Dave was flying.¶
18 Q. How do you know he knew the difference?¶
19 A. Just --¶
20 Q. He told you?¶
21 22 A. Yes. He knew the difference that if he never came up front, he knew who was flying, who landed.¶
23 24 25 Q. And what was the conversation that he had with you that resulted in you becoming chief pilot, switching positions with Dave Rogers?¶
¶
42¶
ESQUIRE ati aleaavin Gallo Cc asp•ey¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
2 A. Jeffrey would always critique Dave's flying capabilities, and I tried to help Dave and explain to him what Jeffrey likes and doesn't like. And Jeffrey's also conveyed these likes and dislikes. And Dave maintained continuing with certain piloting techniques that were just not comfortable to passengers. And this went on through the years, and Jeffrey just got tired of it one day.¶
10 Q. What specifically were Jeffrey Epstein's likes and dislikes with respect to the flight of the plane?¶
11 12 13 MR. CRITTON: Let me put in aform here. But Idon't know what this has to do with anything in this case.¶
14 MR. : I understand that, Bob.¶
15 16 17 MR. CRITTON: I want to use this for some other depositions where we we've gone beyond the scope.¶
18 19 20 21 22 23 24 25 THE WITNESS: The case in point, the last straw was there was atechnique called quiet flying where you would retard the throttles well short of the runway and pretty much glide the airplane in. Well, if you don't do that correctly, you have to spool the engines up just prior to touching down that -- because you're losing air speed and it's an uncomfortable sound and feeling for the passengers¶
¶
ESQUIRE c.ib¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1¶
2¶
3¶
4¶
5¶
6¶
7¶
8¶
10¶
11¶
12¶
13¶
14¶
15¶
16¶
17¶
18¶
19¶
20¶
21¶
22¶
23¶
24¶
25¶
BY MR. 44¶
thinking that you're not going to make the runway.¶
And it was a continuous practice of Dave doing that to be neighbor friendly as opposed to being passenger-comfort friendly.¶
Q. Okay.¶
A. Hence, the transfer of power.¶
Q. Has he ever discussed with you where he wants you to be, whether that is "stay in the cockpit when I have people on the airplane," or don't intermingle with the passengers or anything else?¶
A. He's never stated that to us.¶
MR. REINHART: Could you clarify which "he" you're talking about?¶
MR. I'm talking about Jeffrey Epstein.¶
MR. REINHART: Okay.¶
BY MR.¶
Q. You understood that?¶
A. Yes.¶
Q. It's my understanding that in the -- well, tell me other than the Hawker, what other airplanes have you flown for Jeffrey Epstein?¶
A. A Gulfstream.¶
Q. Does he still have that plane?¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
¶
1¶
2¶
3¶
4¶
5¶
6¶
7¶
8¶
9¶
10¶
11¶
12¶
13¶
14¶
15¶
16¶
17¶
18¶
19¶
20¶
21¶
22¶
23¶
24¶
25¶
46¶
hear you.¶
THE WITNESS: Ili.¶
MR. REINHART: And so Mr. Willits can hear you.¶
BY MR. :¶
Q. Other than the Gulfstream and the Boeing and the Hawker, what other airplanes has Jeffrey Epstein owned over the years?¶
A. That is it.¶
Q. And currently still owns or the companies associated with him own the Gulfstream and the Boeing?¶
A. Yes.¶
Q. And in the past two years, have you flown those two airplanes?¶
A. Just for routine flights to keep them loose or, you know -- you know what I mean.¶
Q. Have those two airplanes been flown by anyone else in the last two years?¶
A. No.¶
Q. Have those two airplanes been flown in the last two years for any reason other than routine maintenance-type flights?¶
A. We've had one -- two flights I think in the past two years.¶
Q. And what were the purposes of those flights¶
¶
ESQUIRE ....,..""¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 and who was on the flights?¶
2 3 A. One flight I believe we went to Sebring and another flight we went to Nassau, Bahamas.¶
4 Q. And who did you go to Nassau, Bahamas with?¶
5 6 7 8 A. I'd have to look at the flight log, but I think it was Sarah, Story and Nadia, I believe. I think that was the three passengers, to the best of my knowledge.¶
9 10 11 Q. And it's my understanding that little St. James is an island that Jeffrey Epstein owns or controls?¶
12 MR. CRITTON: Form.¶
13 THE WITNESS: I don't know that he owns it.¶
14 BY MR.¶
15 16 Q. Has he ever been to an island called Little St. James?¶
17 A. Yes.¶
18 Q. And have you been there with Jeffrey Epstein?¶
19 A. I've been there when he was there.¶
20 21 Q. Have you flown on an airplane with him to that destination?¶
22 A. No.¶
23 24 Q. All right. When you say you've been there when he was there, how did that come about?¶
25 A. We flew into St. and then we flew to¶
¶
ESQUIRE sz AlessaDtle OzIto Gans!¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1¶
2¶
3¶
4¶
5¶
6¶
7¶
8¶
9¶
10¶
11¶
12¶
13¶
14¶
15¶
16¶
17¶
18¶
19¶
20¶
21¶
22¶
23¶
24¶
25¶
48¶
Little St. James in ahelicopter.¶
Q. And do you fly the helicopter as well?¶
A. Yes.¶
Q. How many helicopters are owned or controlled by Jeffrey Epstein and/or corporations associated with him?¶
MR. CRITTON: Form.¶
THE WITNESS: At this time, one.¶
BY MR.¶
Q. And has that helicopter been flown in the last two years?¶
A. Just for routine maintenance.¶
Q. And when you and -- let's say when and Story Cowells and Nadia flew to Nassau, do you know the purpose of that trip?¶
A. No.¶
Q. How long did you stay?¶
A. Five hours.¶
Q. Did you pick anybody up there?¶
A. No. Meaning passengers?¶
Q. Yes.¶
A. No.¶
Q. What happened? You landed the airplane and then what?¶
A. The passengers left. Dave and I went and had¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 lunch. The passengers showed up and we came back.¶
2 3 Q. Have you ever stayed at the home that is on Little St. James?¶
4 A. No.¶
5 6 Q. Have you known Jeffrey Epstein to stay at that home?¶
7 A. I don't know that for a fact.¶
8 9 10 Q • Okay. Do you believe that he is the owner or controller or has some interest in the home or the island of Little St. James?¶
11 MR. CRITTON: Form.¶
12 13 THE WITNESS: I have no knowledge of that being a fact.¶
14 BY MR.¶
15 Q. And you have no belief that that is afact?¶
16 A. Exactly.¶
17 18 Q. When you say you've been there when he was there, how many times has that occurred?¶
19 A. Estimating, a hundred times.¶
20 Q. Okay.¶
21 A. Trying to give an honest answer.¶
22 23 24 Q. Okay. And in the approximate -- I'm not going to hold you to ahundred times, but in the approximately hundred times --¶
25 A. Sure.¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 2 Q. -- for what period of time are we talking about?¶
3 A. During what period of time?¶
4 Q. Right.¶
5 6 7 A. Let's see, when did all this happen? What, 2007? So eight years prior to whenever he stopped flying. So...¶
8 Q. '98/'99?¶
9 A. Yeah, I guess, yes.¶
10 Q. I mean, that sounds like aright¶
11 12 A. Sounds about right, yeah. Don't hold me to it again.¶
13 Q. All right.¶
14 A. You're going back along way.¶
15 16 17 Q. So from approximately the '98/'99 time frame when Jeffrey Epstein would fly to Little St. James, would you be the pilot?¶
18 A. Yes.¶
19 20 21 22 23 24 Q. Okay. And you say that you've been there -- I thought that you just told me that you've been there the same time he was there, but then I thought the subsequent question was well, were you on the flight with him, and I thought your answer was no. Maybe I misunderstood that.¶
25 A. No, you said the question "Have you ever flown¶
50¶
¶
ESQUIRE am....m"n¶
Toil Free: 866.709.8777 Facsimile: 561.394.2621¶
1 2 to his island?" We never landed on his island. We landed in¶
3 Q. Got it.¶
4 A. I was just trying to be exact.¶
5 Q. Thank you.¶
6 A. It's a small island.¶
7 8 9 10 Q. Okay. So how is it that when Mr. Epstein wants to go to Little St. James, what is the path that you take to get actually to the island of Little St. James?¶
11 A. I don't understand the question.¶
12 13 Q. Well, you just told me you fly the airplane to St.¶
14 A. Right.¶
15 Q. And then what?¶
16 17 18 19 20 A. Then sometimes I would go get the helicopter or he could also take aboat to the island. But normally the helicopter's located on St. I'd fire up the helicopter, come pick him up, drop him at the island and I come back to St.¶
21 22 23 Q. And when he stays on St. James, you drop him off on St. James. I suppose you're going to tell me you don't know if he stays there or not?¶
24 A. Exactly.¶
25 Q. But do you stay --¶
51¶
¶
ESQVLism¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 A. I don't. I mean --¶
2 3 Q. Well, he either stays there or someone else picks him up in a helicopter or he swims away?¶
4 A. Correct.¶
5 Q. Okay. You stay on St.¶
6 A. Yes.¶
7 8 Q. Okay. Is there a place that you've stayed on St. James, ever?¶
9 A. No, I've never.¶
10 11 12 13 14 Q. So in the hundred or more times that you've been to the island, is it my understanding that each of those times you've been there to drop off Jeffrey Epstein and/or any passengers and you've immediately left and gone to St.¶
15 A. Yes, sir.¶
16 17 Q. You never been inside that home that's located on St. James?¶
18 A. Yes, I've been inside the home.¶
19 Q. How many times have you been inside the home?¶
20 A. I mean, ten, fifteen times.¶
21 Q. And for what occasion?¶
22 23 A. I've set up the theater system that's in the living room.¶
24 Q. Okay.¶
25 A. So it would be there to work to hook up a TV¶
Larry Visoski October 15, 2009¶
52¶
¶
ESQUIRE •a AlentarOalle Cespiay¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 or a stereo.¶
2 Q. And do you know Les Wexler?¶
3 A. No, I don't.¶
4 Q. Have you ever met him before?¶
5 A. I have met him.¶
6 7 Q. Do you know of any relationship between Les Wexler and Jeffrey Epstein?¶
8 9 A. I don't know what -- to what extent they have arelationship, no.¶
10 Q. Do you know if they know one another?¶
11 12 A. I don't know that for afact. They talk to one another, so I would assume. But I don't know to --¶
13 Q. How do you know they talk to one another?¶
14 15 A. I've seen them speak to one another at the foot of the airplane.¶
16 17 18 Q. All right. Have you ever flown the airplane -- any of the airplanes with Les Wexler as a passenger?¶
19 A. No.¶
20 21 Q. Have you ever flown the airplanes with III'. as a passenger?¶
22 A. Yes.¶
23 Q. And do you know¶
24 A. Yes.¶
25 Q. And for how long have you known¶
53¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 2 3 A. I'm guessing, six years. I mean, don't hold me to it. I'm not the greatest on length of times, but six, seven years, I think.¶
4 Q. How did you meet her?¶
5 6 A. I guess I was introduced. She was on aflight of ours.¶
7 Q. You were introduced to her by whom?¶
8 9 10 A. She may have introduced herself. I mean, you're going back aways. I don't know the official introduction, how it went.¶
11 12 13 Q. And to your knowledge, what is her -- is she associated or affiliated in some way with Jeffrey Epstein?¶
14 MR. CRITTON: Form.¶
15 16 17 THE WITNESS: I would assume so. I don't know to what level or what actually her job description is.¶
18 BY MR. :¶
19 20 21 22 Q. All right. Well, how many flights have you flown where she and Jeffrey Epstein have been passengers together on one of the airplanes that we've been discussing?¶
23 A. I'd only be guessing again.¶
24 Q. We're talking hundreds of flights, though?¶
25 A. Sure, sure, a lot of flights.¶
¶
Larry Visoski October 15, 2009¶
54¶
ESQUIRE ao AllitillOg GillOCOMMY¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶
1 2 3 Q. It seems to be -- I mean, you seem like somebody who has common sense. It seems like somebody that knows Jeffrey Epstein?¶
4 MR. CRITTON: Form.¶
5 BY MR. a¶
6 Q. Correct,¶
7 A. Yes.¶
8 9 10 Q. All right. And do you believe that there is a business relationship there or apersonal relationship there, from your observations?¶
11 12 13 14 A. I'd only be speculating. When they get on the airplane, my focus is forward and flying safely. So I don't -- you know, I'd only be guessing at either one of those two.¶
15 16 Q. Okay. Have you ever socialized with p¶
17 A. No.¶
18 19 Q. Other than speaking with her on the airplane, have you spoken with her elsewhere?¶
20 21 A. Over the phone, in passing, Imean, walking down the street in New York. I mean, yes.¶
22 23 Q. Why would you call or why would she call you?¶
24 25 A. She would call me to schedule the aircraft for adeparture.¶
¶
55¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com¶
1 Q. And have you ever called her?¶
2 A. Yes.¶
3 4 Q. When's the last time you talked to Ma Si?¶
5 A. A week ago.¶
6 Q. What was the occasion?¶
7 8 A. We were discussing carpet for one of the aircraft.¶
9 10 Q. And where was she when you were talking with her?¶
11 A. I don't know. It was over the phone.¶
12 Q. Did 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 Q. Could you tell me what that number is?¶
19 A. Sure.¶
20 Q. Thanks.¶
21 A. Sure. (917)855-3363.¶
22 23 Q. Which airplane were you discussing carpeting for?¶
24 25 A. Was actually -- actually, it was for the helicopter. Now that I'm thinking about it, the¶
Larry Visoski October 15, 2009¶
56¶
¶
ESQUIRE¶
Toll Free: 866.709.8777 Facsimile: 561.394.2621¶