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-MARRA
## EXHIBIT A-2
(2 of 3)
Larry Visoski October 15, 2009
MR. Ma This is it?
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MR. CRITTON: Who took it from the deposition the other day?
MR. IIIIIIII Ihave this one right now.
MR. REINHART: That's the only copy?
MR. =IS Okay.
MR. CRITTON: So you took the original?
MR. IMIIII Apparently. It has the original sticker.
MR. CRITTON: When I say "the original," the original copy. Would you have someone recreate what you've got and send it to us so we have it?
MR. : Sure. In fact, why don't I wait until I get the whole thing and I'll copy all the pages and send it to you instead of piecemeal.
MR. HOROWITZ: You mean before the transcript comes?
MR. : We can copy it.
MR. CRITTON: If you give it to me, I'll copy it and send it back to you.
MR. REINHART: I have acopy. It just doesn't have the exhibit sticker on.
MR. : That's what was told to me the other day, that's why I took it.
MR. CRITTON: I want something -- I just don't
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1 2 want to -- if you give me a copy, I'll put a sticker on it.
3 4 MR. REINHART: Or just copy the page that has the exhibit sticker on it.
5 MR. CRITTON: Sorry.
6 BY
7 8 Q. Like on this flight, we have "JE." I'm assuming that's Jeffrey Epstein, correct?
9 A. Yes, I'll assume.
10 Q. "GM," Ghislaine Maxwell, right?
11 A. Yes.
12 Q. "SK,"
13 A. I would assume.
14 15 Q. I mean -- okay. And then this name, do you recognize that person, Alexia?
16 A. Never heard it.
17 Q. And then
18 A. Yes.
19 Q. You've heard that name?
20 A. I've heard the name.
21 Q. Not sure who that is, though?
22 A. No.
23 24 Q. There's only one, two, three, four, five, six people on that flight?
25 A. Uh-huh.
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1 2 Q. That's pretty typical of the amount of passengers that you would have on aflight?
3 A. It varied, sure.
4 5 6 7 Q. Okay. But it varied between -- if we look a few lines down, Jeffrey Epstein and Ghislaine Maxwell were the only two passengers. Certainly there were flights like that as well, right?
8 A. Mm-hmm.
9 10 Q. And so it varied from having one or two people to six or seven people, right?
11 A. Yes.
12 13 Q. What's the most people that you remember traveling on any of Jeffrey Epstein's airplanes?
14 A. Twenty-five.
15 16 Q. Okay. That would be ararity, wouldn't you say?
17 A. yeah.
18 19 20 Q. Because I've looked through this log. I haven't seen any place where there were 25, but there are lines that have maybe eight or nine people listed.
21 A. Right.
22 23 24 25 Q. Let's see. There's aflight from January 15th -- sorry, January 17th, January 20th and January 22nd of 2002 that all had . That doesn't serve to refresh your recollection as to who
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1 that is, does it?
2 A. No.
3 4 5 Q. Okay. Do you know what the purpose of her being on the airplane flight along with Jeffrey Epstein, Ghislaine Maxwell and IIIIIIIIIIII would be?
6 A. No.
7 8 9 Q. Okay. Do you know how it comes about that gets on that flight? How does she even know there's a flight available?
10 A. I don't know.
11 12 13 14 15 16 17 18 Q. All right. Well, let's go down to somebody that we may all know alittle bit better. February 9th, 2002, there's a flight that has Bill Clinton, four Secret Service agents and then instead of listing names or initials or anything else, it's just listed as two males, one female, Jeffrey Epstein, Ghislaine Maxwell, and I forget who Dave Rogers told me "AP" is. Do you remember who that is?
19 A. No.
20 21 Q. Okay. Either way, how is it that someone like Bill Clinton gets on aJeffrey Epstein flight?
22 MR. CRITTON: Form.
23 THE WITNESS: I don't know.
24 BY MR.
25 Q. Do you know before the flight takes off that
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1 Bill Clinton's going to be a passenger on the flight?
2 A. Yes.
3 4 Q. And how do you know? How do you get that information?
5 6 7 8 9 10 A. The day before I'd get a phone call from, say, Sarah saying we're leaving tomorrow going to wherever, and sometimes she'll say who's going, sometimes she won't. On a case where President Clinton would be on board, we would put a little extra catering on board or do that little extra TLC to the aircraft.
11 12 Q. If it's leaving -- this says it's leaving from MIA and where is it landing?
13 A. HPN I believe is IIIII Plains.
14 Q. Okay. Do you remember that flight?
15 A. I remember being on it.
16 17 18 Q. Well, I mean, if you look through here, obviously you had Bill Clinton on the airplane ten or twenty times, right?
19 20 A. Yeah. He's my main focus. I remember him being on the aircraft, sure.
21 22 Q. Do you remember him being on the airplane with younger girls?
23
24
25
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MR. CRITTON: Form.
THE WITNESS: No.
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1 BY MR.
2 3 Q. Okay. Do you know what his relationship was with Jeffrey Epstein?
4 A. No.
5 Q. Do you know if they were friends?
6 A. Assuming.
7 8 Q. But you're assuming why? Just because he's on his plane?
9 A. Yeah.
10 11 12 Q. Okay. So you assume that the people that are listed on here are friends of Jeffrey Epstein's and that's why they are riding on his plane?
13 A. I'm speculating.
14 15 16 17 18 19 20 Q. I'm just not familiar with the -- because I've never been on aprivate flight -- with the manner in which you go about getting on one of these flights. I mean, you have to, I guess, know that Jeffrey Epstein has a plane, that it's going from adestination that you are at and want to go to, and that it's available and those kind of things. Can you tell me, enlighten me --
21 22 23 24 25 A. Well, it's not publicly offered, no. It would be no different than you jumping in your car and knowing you're going to the mall. I mean, it's not public information, you know, where planes are coming to and from, and you don't put your name out there to get
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1 onboard a flight.
2 3 Q. Does Jeffrey Epstein charge these people as passengers?
4 A. I don't know.
5 6 7 8 9 Q. Okay. Are these people such as Bill Clinton, does that mean that Bill Clinton called or somebody affiliated with Jeffrey Epstein to get on the plane or that Jeffrey Epstein called Bill Clinton and asked do you want a ride?
10 MR. CRITTON: Form; predicate.
11 THE WITNESS: I have no idea.
12 BY MR.
13 Q. No idea?
14 A. No idea whatsoever.
15 Q. Joe Pagano, do you know who that is?
16 A. Yes.
17 18 19 20 Q. What's his relationship with Jeffrey Epstein, or what was it back in February -- sorry, March 17th of 2002, when he and and Jeffrey Epstein and Todd and one female were on this flight?
21 22 23 A. I don't know to what extent or what his relationship is. He just was a passenger on the airplane.
24 25 Q. Okay. And the next day -- sorry, two days later on the 19th of March, Bill Clinton flies again,
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1 2 3 this time with Doug Band, three Secret Service agents, Jeffrey Epstein, Ghislaine Maxwell and Do you remember that flight?
4 A. Where did we go?
5 Q. Starts in JFK.
6 A. Right.
7 Q. Where is that?
8 MR. CRITTON: Do you have adate?
9 MR. : March 19th, 2002.
10 11 THE WITNESS: EGGW I believe is Luton, England.
12 BY MR.
13 Q. Okay. Do you remember flying to England?
14 15 16 A. I do remember flying to England. I just don't remember that trip. What airplane were we in? We were in the Boeing.
17 Q. Do you remember the purpose of the trip?
18 A. No.
19 Q. Do you know who Doug Band is?
20 21 22 A. I heard he's Clinton's, how would you say, assistant. I mean, I've seen that in the newspaper, seen it on CNN.
23 24 25 Q. Okay. Did you ever hear that Doug Band and Ghislaine Maxwell were together, even for aday or a night?
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1 A. No.
2 3 4 Q. Did you ever hear that Doug Band and Ghislaine Maxwell were the people attributed to introducing Bill Clinton and Jeffrey Epstein?
5 MR. CRITTON: Form.
6 THE WITNESS: I don't know.
7 BY MR.
8 9 10 Q. All right. There's another flight here on January -- I can't read this upside down. Maybe it says May --
11 A. Looks like.
12 13 14 Q. -- 22nd, 2002. Again, with President Bill Clinton, Janice, Jessica. Can you tell me who Janice and Jessica are?
15 A. I don't remember.
16 Q. Would you know them if you saw them?
17 18 A. Probably not because the names don't even ring a bell.
19 20 21 22 23 Q. All right. And then there are plenty of flights, many of flights where Jeffrey Epstein, Ghislaine Maxwell and are the primary passengers, or at least are some of the passengers on the flights, correct?
24 A. Mm-hmm, yes.
25 Q. And still, as you sit here, you being the
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1 2 3 pilot of these flights, you're not sure what their relationship is or whether any of them were socially connected in any real way?
4 MR. CRITTON: Form.
5 6 7 THE WITNESS: No. When you're flying the airplane, there's a lot more going on than passengers' relations.
8 MR. BY
9 Q. All right. You remember this person,
10 are you familiar with her at all?
11 A. I remember the name, that's it.
12 13 Q. What do you think her relationship is to Jeffrey Epstein?
14 A. No idea.
15 MR. CRITTON: What date are you on, Brad?
16 MR. II, sorry. I am at June 21st,
17 2002.
18 BY MR.
19 20 Q. That's not somebody that you specifically remember?
21 A. Mm-mm, no.
22 23 24 Q. No? Is that somebody that you think was a regular flyer for any period of time in Jeffrey Epstein's life?
25 A. Not aregular.
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1 2 3 4 5 we're referring to the same flight on June 21st of 2002, that includes Jean Luc Brunel, Jeffrey Epstein, Ghislaine Maxwell, , those are the passengers of this flight, does that serve to jog your memory as to who is?
6 7 8 9 A. No. I mean, you see how frequently we fly. I mean, it's -- the passengers in the back are so far removed from an operation of commanding an airplane like that, it's nothing that sticks in your head.
10 11 12 Q. ' And you as the pilot, is there any way that you would know what's going on in the back of the airplane?
13 A. No. My concerns are all on the cockpit.
14 15 MR. CRITTON: Brad, the last one that you mentioned, was that the same date, June 21st, '02?
16 MR. : Yes.
17 BY MR.
18 19 20 Q. ask you do you know. June 23rd, 2002, are you familiar with that name? There's another name here that I was going to
21 A. No.
22 23 Q. Also on the same flight with Jean Luc Brunel. That doesn't help to jog your memory either, right?
24 A. No.
25 Q. That's somebody that you remember as a
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1 frequent passenger?
2 eferring to?
3 Q. MS'
4 A. No.
6 Q. Dr. Jarecklaillinilielalltdy that you remember flying?
7 8 A. I know the name. He may have been on the airplane once or twice. I'm guessing only.
9 Q. Do you remember meeting him?
10 A. Yes, I have met him.
11 12 Q. Do you remember his purpose for being on the airplane?
13 A. No, sir.
14 15 Q. Amanda Venaro, do you remember her purpose for being on the airplane?
16 A. No.
17 MR. REINHART: Can we get a date?
18 19 20 MR. I was asking him if he remembered Amanda Venaro. I wasn't referring to a specific flight.
21 BY MR.
22 Q. You don't remember her being on the flight?
23 A. I don't remember the name.
24 25 Q. Me showing you the flight isn't going to jog the memory?
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1 A. No. The name that would launch it first --
2 3 4 MR. CRITTON: Could I ask you b quesbion? You have the original exhibit marked at the deposition. It looks like it's been highlighted.
5 MR. EDNARDS: Phighlfhted it.
6 7 8 9 MR. CRITTON: III, okay. So you've highlighted the original exhibit that's marked for the deposition? I just want the record to reflect that.
10 Yeah.
11 MR. CRITTON: Okay. Thank you.
12 13 14 15 MR. At the time Ihighlighted it I didn't realize I was holding on to the original exhibit. I didn't realize that until you just pointed that out.
16 MR. CRITTON: I've noticed that.
17 18 19 MR. IIIIIII: So now when I give it to you, I'm giving you my work product as well. I don't see how this works against you, but anyway.
20 BY MR.
21 22 Q. MEW is that aname that you remember?
23 Aprewmg%V. No.
24 25 Q. Okay. And then Jean Luc Brunel is soltteboW4ro who I noticed flew relatively frequently, so is that why
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1 2 you -- that name jogs your memory a little better than some of these other people?
3 A. He dresses uniquely.
4 Q. In what way?
5 6 A. Just loud clothes, so something that you would remember, that's all.
7 Q. Do you know his role in Jeffrey's life?
8 A. No.
9 10 11 Q. Ever heard that he is affiliated with Jeffrey Epstein because they both have asexual attraction to underage girls?
12 MR. CRITTON: Form.
13 14 THE WITNESS: You're making an assumption on that.
15 BY MR.
16 Q. Have you ever heard that?
17 18 MR. REINHART: He's asked you if you ever heard that.
19 BY MR.
20 Q. If your answer is no, it's no.
21 22 A. I'm sorry, I thought did. No, I have not.
23 Q. Okay. I keep highlighting this name,
24 25 just because it looks like somebody that's regularly flying on the airplane. But the more that you
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1 2 see her name, that doesn't change your opinion as to whether or not you remember her or what --
3 A. I remember the name, you know, that's all.
4 5 Q. Do you remember about what age she was when she was flying on the airplane?
6 A. No.
7 8 Q. This could be somebody who is 50 years old or ten years old, for all you know?
9 MR. CRITTON: Form.
10 THE WITNESS: Yes.
11 BY MR.
12 Q. Okay.
13 A. I mean, I would only be guessing at an age.
14 15 Q. Yeah, but I mean, you don't remember her at all. So you don't --
16 A. I remember the name, exactly.
17 Q. Other than the name?
18 A. Right, yes, sir.
19 20 Q. But you can't even come close to putting a face with that name?
21 22 23 A. •I meank mo. !I mean, if you said draw her picture with -- I couldn't come close to even getting it.
24 25 Q. Okay. You remember this flight where President Clinton, Kevin Spacey and Chris Tucker,
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1 Jeffrey Epstein, Ghislaine Maxwell?
2 A. Yes.
3 Q. From JFK to what is this, LPAZ?
4 A. LPAZ, that is --
5 Q. South Africa or something?
6 A. No, it's the Azores Islands, Santa Maria.
7 Q. Do you know the purpose of that trip?
8 A. That was a fuel stop.
9 10 Q. Okay. And do you know why Chris Tucker and Kevin Spacey were on that airplane?
11 A. No.
12 Q. Did you talk to them?
13 14 A. They came up in the cockpit and said hello. So they conversed, nothing more.
15 16 17 18 Q. Another name that is on here a few times, I'm specifically referring right now to the dates of September 23rd and 24th of 2002, is Ron Burkle. Do you know who that is, Ron Burkle?
19 20 A. I know what that is, yes. I didn't realize he was on our airplane.
21 22 Q. Right now that is the first' time that you remember Ron Burkle being on your airplane?
23 A. Yeah.
24 25 Q. You don't know the purpose for him being on that airplane?
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1 2 A. No. Granted, I'm seeing this for the first time, so I'm trying to --
3 4 5 6 7 Q. Let me ask you that. Because this was given to me at a deposition of Dave Rogers, who I understand was the chief pilot for Mr. Epstein, and now you're the cheap pilot, but you always kind of worked in tandem, correct?
8 A. Sure; we complemented each other.
9 10 Q. And you both worked for the same company that flies Jeffrey Epstein's airplanes, right?
11 A. Yes.
12 13 14 15 16 Q. So I was of the presumption, which may have been -- I may have been misled here, or I may have, you know, misunderstood the purpose behind this book or how it was created. I thought that you had probably seen this before at some point in time?
17 A. no.
18 19 Q• book? Did you know that Dave Rogers was keeping this
20 A. No. I know he keeps a pilot log book.
21 22 Q. Okay. But you didn't know he was keeping the names of the people who were on the airplane?
23 A. No. It's not required, so I mean, it's...
24 25 Q. So today is the first time that you are learning that the names of the people that are on the
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1 airplane was kept by Dave Rogers?
2 A. Yes, in his log book.
3 4 5 Q. Okay. And it's my understanding when you fly back into the country through Customs, you have to report the people that are on the airplane, right?
6 A. Yes.
7 8 Q. And who would create that document or call that information into Customs?
9 A. Whoever the captain was for the day.
10 Q. At times would that be you?
11 A. Yes.
12 13 14 Q. Okay. And at times when you would come into the country with passengers -- well, not at times. Didn't you also have to report their date of birth?
15 A. Sure.
16 17 18 Q. At times weren't there also people that you would bring in from other countries into the United States that were under the age of 18?
19 A. Yes.
20 21 22 Q. And at some times those were flights that included Jean Luc Brunel and girls that were under the age of 18, right?
23
24
25
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MR. CRITTON: Form.
THE WITNESS: I don't remember those flights.
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1 BY MR.S
2 3 4 Q. Okay. You don't remember which flights it would have been where there would have been girls under the age of 18?
5 MR. CRITTON: Form.
6 7 THE WITNESS: Well, I would have to look at the flight logs.
8 BY MR.
9 10 Q. It's not illegal to have somebody under the age of 18 on a flight anyway, right?
11 A. No, not at all.
12 13 14 Q. Were you ever aware that you, as pilot, were transporting girls under the age of 18 who were supposed to be models?
15 MR. CRITTON: Form.
16 THE WITNESS: I had no knowledge.
17 BY MR.
18 19 20 Q. Okay. You never knew who the people on the airplane were, what their purpose was, their role with Jeffrey Epstein or Jean Luc Brunel?
21 A. No.
22 Q. All right. Do you know
23 A. No, I don't remember that name.
24 Q.
25 A. I remember the name.
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1 2 Q. She flew frequently at least for aperiod of time. Do you remember that?
3 A. Yes.
4 5 6 Q. Is that somebody that you thought was familiar with the modeling industry or related to the modeling industry?
7 A. No.
8 9 Q. Okay. And these people, did Jeffrey Epstein ever tell you how he was associated with any of them?
10 A. No.
11 12 Q. Did you ever wonder how he was associated with any of them?
13 A. No, never interested.
14 15 16 17 18 Q. And on several of these -- on most of these, the names or initials of the people that are on the flight are listed. Do you know on the occasions where it lists generically two females or three females or six females, do you know why that was done?
19 20 21 A. Just because we didn't know our the person's name. We tried to do the best we could to keep the records.
22 23 Q. When you say "we tried to do the best that we could" --
24 A. Dave and I.
25 Q. Okay. But the first time that you learned
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1 that he kept anybody's names was today, right?
2 3 4 5 6 A. Well, I didn't know he kept them in his log book. We would fill out the passenger manifest as we're -- having passengers' names in your pilot log book, he's probably the only person in the world that does that.
7 Q. Okay.
8 9 10 A. So when you were mentioning putting the names down, when you said female or male, you know, I was referring to the passenger manifest.
11 12 13 14 15 Q. For each of these same flights, then, that we're referring to out of this log book that was marked as Composite Exhibit 1 in Dave Rogers' deposition, am I understanding you correctly, then, there would also be a passenger manifest for each of these flights?
16 A. Yes.
17 18 Q. Now, where would I find the passenger manifest? Who keeps that documentation?
19 A. Corporate -- our corporate office.
20 Q. Which is whom?
21 A. Up in New York, Darren Indyke.
22 Q. At what corporation is that, though?
23 A. NES, LLC, I guess.
24 MR. REINHART: Do you know for sure?
25 THE WITNESS: I don't know for sure. I mean,
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1 2 when you say we would just send them up to New York.
3 BY MR.
4 Q. Did you ever keep acopy of them?
5 A. No.
6 Q. Why did you keep apassenger manifest?
7 8 A. Just for tracking of -- to have the times on there for --
9 10 MR. REINHART: Can I confer with him on one thing before you ask aquestion?
11 MR. : Yeah, yeah.
12 (Off the record discussion.)
13 14 15 MR. REINHART: Mr. , let him amend his prior answer. I think he misunderstood the question.
16 17 MR. : I don't know what question we're amounting the answer to.
18 19 20 21 22 23 24 MR. REINHART: Let me clarify this way: As the passenger manifests, they are corporate documents of either JEGE or Hyperion Air, whatever company owns the plane. Mr. Visoski has physical custody of them. He retains them but they're not his documents. They're the corporate documents. So they're not in New York.
25 THE WITNESS: Those are the ones that I have
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1 2 at the airport office that I had turned into counsel that has the passenger names on them.
3 BY MR. a
4 Q. Okay.
5 A. It's called apassenger manifest.
6 Q. Okay.
7 MR. REINHART: Right.
8 BY MR.'S
9 10 11 Q. The passenger manifest, just so I understand exactly what that is, tell me. Tell me in your own words.
12 13 14 A. It's departure time, the city, the landing time exactly and the passengers that would have been on that flight.
15 16 Q. And at times on that passenger manifest would you list also generically female or male?
17 18 19 20 21 A. Yes. That was the document I was referring to stating that if we didn't know aperson, we did not go out of our way to find out a name. We just put in to account for how many people were on the aircraft at that time.
22 23 24 25 Q. Who is currently in the custody or control sorry. Who currently maintains or has possession of the passenger manifest from 1998 through the present, through today for those airplanes that you flew related
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1 to Jeffrey Epstein?
2 3 4 5 6 7 A. I currently have, which counsel has now, 2005, Ibelieve, until the present time. And the records previous to that I believe were turned into counsel with the previous investigation with Jack Goldberger's office, I believe. I believe they maintain those records.
8 9 Q. When you say "turned into counsel," there are alot of counsel involved here.
10 A. Jack Goldberger's office, I believe.
11 12 Q. When you say "the previous investigation," you're talking about the criminal investigation?
13 A. Exactly, yes, sir.
14 15 16 Q. And you're aware in that criminal investigation, obviously, that Jeffrey Epstein pled guilty to certain charges, correct?
17 A. From what I read, yes.
18 Q. Well, you did visit him in jail, right?
19 A. Yes. We didn't talk about that.
20 21 Q. Okay. You know in order to go to jail, though, you have to be convicted of some crime, right?
22
23
24 BY MR. :
25 Q. It wasn't like he was visiting the jail and
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THE WITNESS: Yes.
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6 Q. Okay. So when we're talking about the criminal investigation, we're talking about the criminal investigation revolving around the allegations of Jeffrey Epstein engaging in sex acts with minors?
9 MR. CRITTON: Form.
10 BY MR.
11 12 Q. talking That's the criminal investigation you're about, right?
13 MR. CRITTON: Form.
14 15 16 THE WITNESS: I don't know the full definition of really what happened there. I know that it was something to do with solicitation of prostitution.
17 That's all I read.
18 BY MR.
19 20 21 Q. Okay. Were you aware that the allegations revolved around underage girls or girls under the age of 18?
22 MR. CRITTON: Form.
23 24 THE WITNESS: I was aware it revolved around it, yes.
25
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you were visiting and you happened to bump into each other. You actually went to see him while he was an inmate in jail?
A. Right, yes.
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1 BY MR. 1IIIII/
2 Q. Who first made you aware of that?
3 A. The newspaper.
4 Q. Were you ever questioned by the police?
5 6 7 A. I don't know who questioned me, actually. I did have a questioning session, but I don't even remember who questioned me.
8 Q. Where did that take place?
9 A. I don't remember.
10 Q. At your house?
11 12 13 A. No. I'm thinking it was Jack Goldberger's office, or it may have been downtown at the Palm Beach County Courthouse or something in that area there.
14 15 Q. Okay. So it either happened at an attorney's office that represented --
16 A. Exactly, yeah, I think so.
17 Q. -- Jeffrey Epstein or the other side?
18 A. Yeah.
19 20 Q. And during that questioning, is that when you turned over the passenger manifest from prior to 2005?
21 A. Yes.
22 23 Q. And you turned those manifests directly over to Jack Goldberger?
24 25 A. Yes. Actually, I believe Dave Rogers did that. I wasn't in possession of those records.
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1 2 Q. And for the passenger manifest prior to 2005, how far do those passenger manifests go back in time?
3 4 A. They should go back, I guess, to 1991 or whenever we started existence.
6 Q. And did you turn them over from 1991 all the way through to 2005?
7 8 A. I don't know. I didn't turn them in. Dave Rogers did.
9 10 Q. Are you in possession of a copy of any of those materials?
11 A. No.
12 13 14 Q. I thought that, you know, ten minutes ago when we were talking about this you said you had them back at an office or --
15 16 17 A. That was the office, the airplane office, which I've given to Bruce, which is the current log. He is in possession of them now. I had possession of them.
18 19 20 Q. Okay. What he's in possession of -- just so I know what documents are where, he's in possession of the passenger manifests from 2005 through the present?
21 A. Correct.
22 23 24 Q. If I want to obtain the passenger manifests from 1998 through 2005, that's something that I would request from whom?
25 THE WITNESS: Help me out. That's --
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BY MR. 104
MR. REINHART: If you know.
THE WITNESS: I don't know who possesses them right now. They were turned into Jack Goldberger's office ayear and ahalf or two years ago.
Q. You started out by indicating that you sent these passenger manifests, or a copy thereof, to Darren Indyke or someone at NES, LLC; is that correct?
A. Correct.
Q. If I requested them from NES, LLC, that's somebody at some point in time was in possession of all the passenger manifests?
A. Sure.
Q. And NES, LLC's address is the one you gave me at 301 East 66th Street?
A. I believe so. I don't know what address they're using for that. I know that --
Q. But Darren Indyke's the attorney that I would call --
A. Yes, sir.
Q. -- and he could probably steer me in the right direction?
A. Yes.
MR. CRITTON: Form.
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1 BY MR.
2 Q. Do you know Amy Taylor?
3 A. Yes.
4 Q. How do you know her?
5 A. She was on the airplane.
6 Q. How old is she?
7 A. I have no idea.
8 Q. Age range?
9 A. Twenty-eight.
10 Q. Now?
11 12 13 A. Yeah, 28, or maybe if not older now. She was probably 28 probably, I guess. She was somebody in her late 20s.
14 15 Q. So we're talking about 2003? That's what I'm trying to understand.
16 A. I'm guessing.
17 18 Q. We're talking 2009 now. We're saying 28. By that do you mean in 2003 she was 23 or 24 years old?
19 A. You're having me guess on her age.
20 Q. Yeah.
21 A. I mean, I can't be accurate.
22 Q. Somebody between 18 and 25?
23 MR. CRITTON: Form.
24 BY MR.
25 Q. At the time you were seeing her back in --
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1 A. If you want me to guess --
2 Q. No, I don't want you to guess.
3 A. I don't know then.
4 Q. Well, if I say between ten and fifty?
5 A. That's arange.
6 7 Q. If I say between ten and fifty, you're not guessing there anymore. You know she's in there, right?
8 A. She's in the middle there, yeah.
9 10 Q. Okay. How can we narrow that down? We're talking about somebody in her 20s?
11 A. In her 20s.
12 Q. At least that's what you believed?
13 A. Yes.
14 15 Q. All right. Is that somebody that you know to be associated or friendly with Ghislaine Maxwell?
16 A. I don't know.
17 18 Q. Do you know what her relationship was to Jeffrey Epstein or Ghislaine Maxwell?
19 A. No.
20 Q. Do you know where she is now?
21 A. No idea.
22 Q. When's the last time you talked to her?
23 A. I don't know. What date do you have on there?
24 Q. February 2003.
25 A. So, probably that long ago. I may have said
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1 hello.
2 3 Q. That's somebody who was on the airplane multiple times?
4 5 A. More than once. I mean, I have no account for how many times.
6 7 8 Q. Well, I've asked you about abunch of names, most of which you don't really remember, but that's one name you do remember.
9 A. Yeah, I remember the name, yeah.
10 11 Q. Okay. And that's somebody who you actually - you would remember the face too?
12 A. I might remember Amy's face.
13 14 Q. All right. Do you remember why she would have ever been on your airplane?
15 A. No idea.
16 17 18 Q. President Andres Postrana, at the time I guess that was the president of Colombia back in February - sorry, March 20th of 2003. Do you know who that is?
19 20 A. I don't remember him being on the airplane, but I know who that is.
21 22 23 Q. Okay. He's on the airplane with Jeffrey Epstein, Ghislaine Maxwell, and Jean Luc Brunel?
24 A. Where did we go?
25 Q. I'll let you look at it. I'm talking about
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1 this line, PBI, left out of Palm Beach?
2 3 A. Palm Beach to Nassau. I'm sorry, I don't remember that one.
4 5 6 Q. When we're saying we're going down to Nassau, is that a place that you frequently went to with the airplane?
7 A. No, not at all.
8 9 Q. And is that aroute that you would take for the ultimate destination to be Little St. James?
10 A. No.
11 12 13 Q. If the ultimate destination was Little St. James -- show me aflight where the ultimate destination was Little St. James.
14 A. Yeah, right here. TIST, that's St.
15 16 17 18 Q. Okay. So on that flight that you just pointed to, March 27th, 2003, we have Jeffrey Epstein, again, Brent Tyndall -- do you know who Brent Tyndall is?
19 A. Yes.
20 Q. And who is that?
21 A. I believe he was the chef.
22 23 Q. And Magale Blanchen (phonetic), is that somebody you know to be a model these days?
24 A. I have no idea.
25 Q. Do you remember that flight?
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1 A. No.
2 3 Q. Do you remember Naomi allia picking her up from St. OEMalong with Jean Luc Brunel?
4 5 A. I remember her being on board. I don't remember the flight.
6 Q. Do you know Joel Pashcow?
7 A. Yes.
8 Q. How do you know him?
9 A. He was on the airplane.
10 11 Q. And is that somebody you knew at one point in time to be a friend of Jeffrey Epstein's?
12 13 A. He was on the airplane. I don't know what the relationship was.
14 Q. Do you know what the relationship is today?
15 A. No idea.
16 17 Q. How about Todd Mister, do you know what that relationship is or was today?
18 A. No.
19 Q. Do you remember him?
20 A. No.
21 Q. Not at all?
22 A. I mean, I know the name. I don't know.
23 Q. Paula Epstein, do you know who that is?
24 A. Yes.
25 Q. Who is that?
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1 A. That's Jeffrey's mom.
2 Q. She's passed away?
3 A. Yes.
4 Q. At least that's your understanding, right?
5 A. That's what I heard, yes.
6 Q. Okay. Tila, do you know her?
7 A. Tila n, I know the name.
8 9 Q. Somebody who flew on the airplane with some regularity?
10 A. Yes.
11 12 Q. And do you know her to be friends of Ghislaine Maxwell or or Jeffrey Epstein?
13 MR. CRITTON: Form.
14 15 THE WITNESS: I have no idea who she was friends with.
16 BY MR. :
17 18 Q. All right. Do you know what role she ever played, if she played one, in Jeffrey Epstein's life?
19 A. No.
20 21 Q. All right. Glenn, are you familiar with him?
22 A. Yes.
23 Q. How do you know Glenn ?
24 A. I met him on the airplane.
25 Q. Outside of the airplane, have you ever seen
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1 him around Jeffrey Epstein?
2 A. No.
3 Q. All right.
4 A. No.
5 Q. do you know that name?
6 A. No.
7 8 Q. She was on several flights. You don't remember seeing her?
9 A. No.
10 11 Q. All right. And how about Alan Dershowitz, I'm sure you know who that is?
12 A. Sure. He's famous.
13 14 Q. What was your understanding of Alan Dershowitz's relationship with Jeffrey Epstein?
15 A. Never talked about it.
16 17 Q. Forrest Sawyer, do you know why he was on your airplane?
18 A. Never heard the name, actually.
19 Q. Really?
20 A. No.
21 Q. Larry Summers?
22 A. I know the name. I don't remember flying him.
23 Q. Have you ever talked to Joe Fontanela?
24 A. Yes.
25 Q. How do you know him?
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1 A. He usually drops Jeffrey off at the airport.
2 3 Q. In fact, you've called him directly before, right?
4 A. Yes.
5 Q. You still have his number?
6 7 A. I haven't -- yes, I think I still got it in my memory.
8 Q. Okay. What is it?
9 10 A. It's been a few years. (917)945-7500. It's kind of an easy one.
11 MR. CRITTON: 917 is the first
12 THE WITNESS: Yes.
13 MR. CRITTON: Who was this for?
14 MR. REINHART: Joe, Joe Fontanela.
15 MR. : Fontanela.
16 BY MR.
17 Q. Do you know his address, where he resides?
18 A. No, I don't.
19 20 Q. Do you know if he what his role is in Jeffrey Epstein's life?
21 A. Not really. He just he drove the car.
22 Q. He drove what car?
23 A. The car up in New York.
24 25 Q. Okay. Do you know if he's a housekeeper up at that house up in New York?
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3. A. I don't know what his role is.
2 3 Q. Have you ever worked for a company called Air Ghislaine? Do you know that company?
4 A. Yes.
5 Q. Do you know what that company does?
6 A. No.
7 8 Q. Have you ever been an employee of that company?
9 A. No.
10 Q. Do you know who runs that company?
11 A. No.
12 13 Q. Is Jeffrey Epstein associated with that company?
14 A. I don't know.
15 Q. How have you heard of that company?
16 17 A. It's the company name that our registration for the helicopters is under, Air Ghislaine.
18 19 Q. Is that somebody who's ever paid you, a company who's ever paid you?
20 A. No.
21 Q. Do you know Igor Zinoviev?
22 A. Yes.
23 Q. How do you know him?
24 A. Met him on the airplane.
25 Q. What is your understanding of his affiliation
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1 with Jeffrey Epstein?
2 A. I don't know. He doesn't talk much.
3 4 Q. is? Okay. And Sandy Berger, do you know who that
5 A. I don't know.
6 7 Q. Do you know any reason why you would have flown him on the airplane?
8 A. I don't even know the name.
9 Q. Adrianna Muchinska?
10 A. I know the name Adrianna.
11 12 Q. Somebody who flew on the plane pretty regularly?
13 14 15 A. I would have to look at the logs. I think we've had that name on several -- it's acommon first name. I'm not familiar really on who that is.
16 17 Q. What about Bella, do you know who Bella is? Is that aname you ever heard?
18 A. Yes.
19 Q. Works up in the New York office or something?
20 A. Yes.
21 Q. Have you ever spoken with Bella personally?
22 A. Yes.
23 24 Q. Do you know what she does for Jeffrey Epstein, if anything?
25 A. I don't know exactly what her role is.
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1 2 Q. Do you know -- did you tell me, do you know what Leslie Gruff does for Jeffrey Epstein?
3 A. I don't know her exact title.
4 5 Q. You talked to all of these individuals at some point in time, either on the phone or in person, right?
6 A. Yes.
7 8 Q. And you don't know whether they play a role in Jeffrey Epstein's life, or if they do, what they do?
9 A. Exactly.
10 11 Q. And how do you decide who you're going to call for what reason?
12 A. For example? Can you be more specific?
13 14 15 Q. If you're going to make atelephone call and you're going to talk to let's say Leslie Gruff, why would you choose to call her?
16 17 A. I don't know. You're having me make the phone call. I don't know why I would call her.
18 Q. Have you ever called her?
19 A. I think, yes, I've called her, sure.
20 21 22 Q. Why? What would be the reason that you would call her? Somebody told you to call her? Here, call this number?
23 24 25 A. I may have called her maybe to find out if we had a departure time for any specific trip. Imean, that would be...
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1 2 Q. Okay. So you're calling her related to Jeffrey Epstein?
3 A. Sure.
4 5 Q. Okay. So you know that she plays some role in some aspect of Jeffrey Epstein's life, whatever that is?
6 A. Right.
7 8 9 10 11 Q. Okay. So when I'm asking these questions about these people, and I feel like I'm getting answers that I'm not really not sure that these people have any role in their life, that's not that's not completely accurate, right?
12 MR. CRITTON: Form; argumentative.
13 BY MR.
14 15 16 17 18 Q. I mean, you do know that somehow involved with him, whether these people are socially or business-wise or otherwise, and during the course of your years, you've made telephone calls on his behalf or to coordinate things with them right?
19 A. Right.
20 21 MR. CRITTON: Object to the form. You said "these people."
22 BY MR.
23 24 Q. I'm talking about . That's somebody you called before, right?
25 A. Sure.
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1 Q. What would be a reason you called
2
3 4 5 6 MR. CRITTON: Object to form. Probably the same reasons he said two hours ago, for scheduling purposes. But you've covered that. Go ahead and answer it again.
7 8 THE WITNESS: For scheduling purposes, would be my only reason to call her.
9 BY MR.
10 11 Q. That's funny that you used the exact same words that Mr. Critton wants you to use.
12 MR. CRITTON: It's what he said two hours ago.
13 BY MR.
14 15 Q. What would be the reason why you would call Ms. Maxwell, Ghislaine Maxwell?
16 A. Same reason.
17 18 Q. That's not somebody you call these days, though, right?
19 A. I haven't seen her in some time.
20 21 22 Q. What made you stop calling Ghislaine Maxwell where you thought at one point in time you thought she was a person to call related to your job?
23 A. Just was no reason to.
24 25 Q. Is that somebody who you think is still affiliated or associated with Jeffrey Epstein or his --
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1 whatever he does?
2 A. I'd only can speculating. I don't know.
3 Q• All right. Do you know the number
4 (917)868-6145?
5 MR. CRITTON: Could you say it slowly. 917?
6 7 8 MR. MEM 868-6145. Thank you. And just in case you didn't get it, I'm going to mark these as an exhibit so that we can read them later.
9 BY MR.
10 Q. Do you know that number?
11 A. Yes.
12 Q. What is that number?
13 A. That's my cell phone.
14 Q. Okay. Is that still your cell phone?
15 A. Yes, sir.
16 17 18 19 20 21 22 Q. All right. I'm going to show you two documents here or pieces of paper. We'll mark them as Exhibit 2 and Exhibit 3. The first one is dated March 5th, 2005. Do you remember making this telephone call? And just for the record, this looks like a message that's being taken relative to aphone call that you made.
23 24 MR. REINHART: So the question is does he remember making the phone call?
25
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3 Q. Do you remember making that phone call after reading the message?
6 MR. REINHART: The question is, do you remember making the call?
8 9 THE WITNESS: Okay, let me. "Person for the car will be here in 15 minutes to drop off foam and papers." I don't know.
10 BY MR.
11 Q. That doesn't mean anything to you?
12 13 A. That doesn't -- I mean, you're talking four years ago. I can't answer that accurately. I mean...
14 15 MR. REINHART: So the answer is you don't recall?
16 THE WITNESS: Yeah, I don't recall.
17 BY MR.
18 Q. If you don't remember, that's fine.
19 20 (Plaintiff's Exhibit Nos. 2 AND 3 were marked for identification.)
21 BY MR.
22 23 24 25 Q. So I'll show you Exhibit 3, the same type of document, and I can make the representation that this was message pads provided by the state attorney's office relative to the criminal investigation revolving around
BY MR. a:
A. Let me look at the date here. Okay. March.
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1 2 Jeffrey Epstein. So that's how I have these documents. I'm not trying to pull out old documents.
3 MR. CRITTON: What's the date?
4 MR. IIIIIIIII March 19th.
5 6 MR. REINHART: The question is, do you remember the call?
7 8 9 THE WITNESS: "Tom from Midnight Express is at" -- help me out -- "convention center with new boat. They are two points -- two parts of this."
10 MR' BY
11 Q. "Show"?
12 A. "Show up the water" --
13 MR. REINHART: "On the water."
14 15 THE WITNESS: "On the water and at the center."
16 BY MR.
17 Q. Do you remember making that call?
18 19 20 A. No. I mean, "Tom from Midnight Express is at convention center with new boat. They are two parts of" -- I mean --
21 22 23 Q. But as Jeffrey Epstein's pilot, why would you be leaving such a message about Tom from Midnight Express relative to boats and aboat show?
24 25 A. I help out with boat purchases or, you know, anything to do with, you know, that moves. So I mean,
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1
2 3 Q. Okay. When you say "you help out with boat purchases," what do you mean?
4 5 6 A. Give my opinion, whether or not whether to buy acertain boat. It's just a hobby. I have knowledge on boats. Not only just airplanes but, you know.
7 Q. You give your opinion to whom?
8 A. To Jeffrey.
9 10 Q. Okay. And Jeffrey Epstein obviously, at least in your mind, you believe he wants your opinion?
11 A. Yes.
12 13 Q. Okay. So boats is another thing that the two of you have discussed?
14 A. Yes.
15 16 17 18 Q. All right. And so this aconversation or at least some evidence that aconversation existed between yourself and Jeffrey Epstein relative to aboat or a boat show?
19 A. Correct.
20 Q. Do you remember having that conversation?
21 22 23 A. We've had many conversations about boats and different boat shows. If you're referring to this one in '05, I don't recall this one.
24 25 Q. Okay. So aside from being a pilot -- which throughout this entire deposition I believe your
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testimony has been, you know, you're just the pilot for him -- it looks like there's some other role that you're playing here in his life. I'm not suggesting that you are or you are not. I'm just saying from the appearance of this, it looks that way. Is there anything else that you want to tell me or that you want to clarify in terms of the role that you play in Jeffrey Epstein's life outside of being just his pilot?
MR. REINHART: Let me object to form. He also told you he installs the audio and video equipment before.
MR. Correct.
THE WITNESS: I have an interest in boats. You know, with the island, I don't think I bought any boats, you know, for the company, but he appreciates my opinion on boat purchases.
BY MR.
Q. Okay.
A. Having the knowledge of aviation and things that move quite fast. So I have consulted with him on boat items.
Q. How many boat purchases are you aware of Jeffrey Epstein making in the time period that you've known him?
A. Two or three.
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1 2 Q. And has he consulted with you on each of those purchases?
3 A. Not every one of them, no.
4 5 Q. Does he own any boats now that you're aware of?
6 A. I don't know if he owns them or not.
7 8 Q• Okay. Do you know of any boats that he controls or maintains?
9 A. Himself or?
10 11 12 Q. How about this -- i'll ask you this way. 1 don't want to split hairs with you here: I know we've been talking about corporations and things like that.
13 A. Yes he.
14 15 Q. Do you know of any boats that he is the person with the most control over?
16 A. Yes.
17 18 Q. Okay. Where would those boats be located and what kind of boat are we talking about?
19 20 A. St. is the location. It would be a 34-foot inflatable boat. I know that one specifically.
21 Q. Okay. Do you know when he made that purchase?
22 23 A. Eight years ago, seven years ago. It was a while ago.
24 Q. Is that something you had had input in?
25 A. Not on that one specifically, no.
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1 2 3 Q. Is there any other boat that you know of Jeffrey Epstein being the primary user of or the primary controller of?
4 5 6 7 8 A. I mean, there's boats in St. IIMII. I mean, it's not part of my job, you know, what goes on with the boats or who controlled them. It's more of an opinion of what horsepower should be on the back of the boat, hull designs. It's out of my area.
9 10 11 12 Q. But your sole responsibility or your sole obligation that you have ever had with Jeffrey Epstein relative to boats is just giving some opinions about the boat?
13 A. Mm-hmm.
14 Q. Is that yes?
15 A. Yes, yes.
16 17 Q. Okay. All right. Has he ever given you his opinions about boats?
18 A. Sure. We've discussed it back and forth.
19 20 Q. Other than boat conversations, have you ever talked other conversations, such as
21 A. Cars.
22 23 24 Q. Okay. How about such as -- have you ever known Jeffrey Epstein to have agirlfriend, somebody you consider a girlfriend?
25 A. No.
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1 2 3 Q. In the 18 years and all the travels you had with him, do you know anything about Jeffrey Epstein's sex life?
4 A. No.
5 Q. Do you know who he has sex with?
6 A. No.
7 Q. Do you know if he has sex with anybody?
8 A. I don't know.
9 10 Q. Do you know if he's ever had sex on the airplane while you've been piloting it?
11 A. I have no idea.
12 13 Q. That's something that you just wouldn't know because you're up in the cockpit?
14 A. That is correct.
15 16 THE WITNESS: Could I take a two-minute bathroom break just to lose my coffee?
17 MR. S Sure.
18 (A break was had at 12:35 p.m.)
19 BY MR.
20 21 22 23 24 Q. All right. We're back on the record. Over the years you've indicated that the -- any gifts or other items or things given to you by Jeffrey Epstein exclusively are the pool heater, the 40-acres of land and the --
25 A. Use of a company --
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1 Q. -- and the use of a company car?
2 A. Yes.
3 Q. That's it?
4 A. (Nodding.)
5 Q. Okay.
6 A. Yes, I'm sorry, yes.
7 8 9 Q. And the flight to Miami that was recently taken, other than Jeffrey Epstein and was there anybody else on that flight?
10 A. No.
11 12 Q. How long -- did you also fly them back from Miami to Palm Beach?
13 A. No. He drove back.
14 Q. When you say "he drove back," who drove back?
15 16 A. Well, I assume he drove back. I did not fly him back.
17 Q. When's the next time you saw him again?
18 19 A. I would only be guessing. A week later, I mean.
20 21 Q. Okay. And was that in Palm Beach County when you saw him the next time?
22 A. Yes, sir.
23 24 Q. Do you know of him leaving Palm Beach County in the last two years on any other occasion?
25 A. No.
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1 2 Q. Did he ever fly anywhere else with you either by helicopter or airplane in the last two years?
3 A. We flew one time to the Sikorsky plant.
4 Q. What's the Sikorsky plant?
5 6 A. That's where they build the Sikorsky helicopters. It's in Palm Beach County.
7 Q. And when was that?
8 A. Probably a month ago, I'm guessing.
9 Q. For what purpose?
10 A. They gave us a tour at a facility.
11 Q. Who's they?
12 A. Sikorsky.
13 Q. And who requested the tour of the facility?
14 A. They offered it to our flight department.
15 Q. And who went?
16 A. Jeffrey, myself, Nadia and Igor.
17 18 19 Q. And if I wanted documentation of either of those trips, the trip to Miami or the trip to the Sikorsky plant, who would have that documentation?
20 A. I would.
21 22 Q. So I could request it from your attorney to get it from you?
23 MR. REINHART: Let me just check.
24 (Off the record discussion.)
25 MR. REINHART: Okay. He has custody of it,
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1 2 3 but they're corporate documents. So you'd have to request it from Mr. Critton, who I understand represents all the corporations.
4 THE WITNESS: Yes.
5 BY MR.
6 7 Q. What's the corporation that the document was prepared for?
8 9 A. Meaning who -- what, like Air Ghislaine, the owner of the helicopter? Yes, Air Ghislaine.
10 Q. Air Ghislaine?
11 A. That's the helicopter.
12 13 14 Q. And the name Ghislaine is obviously not that typical of a name. Is that reference or related to Ghislaine Maxwell?
15 A. I would assume. I have no knowledge.
16 Q. Nobody's ever told you that?
17 A. Nobody's brought it up.
18 19 Q. Okay. And how long were you at the Sikorsky facility?
20 A. Three hours, four hours.
21 Q. And what time of day was this?
22 23 A. Nine in the morning. Nine, I think, and we returned at one, something like that.
24 25 Q. And was the purpose to buy or purchase anything?
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1 2 3 A. They have anew helicopter being developed there, so they're trying to look for investors in it. So they were just kind of pushing their product.
4 5 Q. Do you know what Jeffrey Epstein does for a living for business today, these days?
6 A. No.
7 8 Q. Do you know or have you ever been to the Florida Science Foundation?
9 A. Yes, sir.
10 11 Q. And do you know what the Florida Science Foundation does?
12 A. Not exactly.
13 Q. Well, generally?
14 A. No, I don't. I mean, really, I don't.
15 16 17 Q. Okay. Is it your understanding that Jeffrey Epstein is somehow affiliated with the Florida Science Foundation?
18 A. It's my understanding that, yes.
19 20 21 Q. I mean, did you just by happenstance stumble into the Florida Science Foundation, or was it related to your relationship with Jeffrey Epstein?
22 23 A. I've heard that's where his office was. I mean, I have no other --
24 Q. Why did you go there?
25 A. Talk about airplanes.
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1 Q. Talk to who?
2 A. Jeffrey.
3 4 Q. Jeffrey just happened to be at the Florida Science Foundation?
5 A. Yes.
6 7 Q. How did you know that he was going to be at the Florida Science Foundation?
8 A. He called me and told me.
9 10 Q. And he said come to the Florida Science Foundation to talk to me about what?
11 12 A. Maintenance on the airplanes, upcoming. It's an ongoing.
13 Q. And did he have an office there?
14 A. Yes.
15 16 Q. So this is -- when you walked in, this is the place that's right next to Jack Goldberger's office?
17 MR. CRITTON: Form.
18 THE WITNESS: Yes.
19 BY MR.
20 21 Q. And you walk in and there's areception desk right there?
22 A. Yes.
23 24 Q. Is that where you talked or did you talk somewhere behind that reception desk?
25 A. Behind the reception area.
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1 Q. Back in his office?
2 A. Yes, sir.
3 Q. What was that conversation?
4 S A. Give me atime frame. I mean, I've been there several times.
6 7 Q. Okay. How many times do you think you've been to the Florida Science Foundation?
8 A. Twenty, thirty. Imean...
9 10 Q. Well, the Florida Science Foundation's only been around since late 2007; is that right?
11 MR. CRITTON: Form.
12 BY MR.
13 Q. Something around that?
14 A. I don't know exactly.
15 16 17 Q. All right. So in the last 20 years -- in the last couple of years you've been there 20 or 30 times, approximately?
18 A. Yes, sir.
19 20 21 22 Q. And during those times when you've been there, without having to go through each conversation, did you ever talk to him about the fact that he was on probation or that he was
23 A. No.
24 Q. -- any part of the criminal investigation?
25 A. No, not at all.
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1 Q. What was the purpose of the conversation?
2 3 4 5 6 A. We were sometimes talking about TVs, you know, the latest plasma that's out there, LCD, you know, setting up a stereo systems, you know, in the Palm Beach house. That's usually the main thrust of our conversations these days.
7 8 9 Q. How would you know to go to the Florida Science Foundation on each of those occasions? Would he just call you?
10 11 A. Yeah, he would call me and say come on by or I got a brochure on a new Samsung.
12 13 Q. With each time you were at the Florida Science Foundation, how long would you stay typically?
14 15 A. Ten, fifteen minutes. Not much more than that.
16 17 Q. You would go there for ten or fifteen minutes, have a conversation about aTV and leave?
18 A. Yes, sir.
19 20 Q. Why couldn't you have that conversation over the phone? What was it about?
21 MR. CRITTON: Form.
22 23 24 25 THE WITNESS: If it was pertaining to a TV and I'd have a brochure, a picture of the TV -- one particular TV we looked at it was the size of a like five foot diagonal, so I had aphoto of myself
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standing next to it or the salesperson. So I mean, there's a reason to visually show him something reference to that.
6 Q. Did you ever communicate with Jeffrey Epstein -- you can send him an e-mail, right? You could have done that?
9 10 Q. To send him the picture or something like that, that was an option?
11 A. Right.
12 13 Q. And what's Jeffrey Epstein's e-mail address that you use?
14 15 16 A. I have to do it on my computer, you know, with -- I have to type in the prompts for it because it's a long e-mail address.
17 18 Q. Okay. How long have you e-mail corresponded with Jeffrey Epstein?
19 20 21 A. Probably two years. A year to two years. I mean, it's fairly -- something we just started doing. I mean, we'd never done that in the past.
22 23 Q. Well, in the past he was in jail or have some restrictions?
24 A. The restrictions, yes.
25 Q. So you you'd see him on the airplane
BY MR. MM
A. Yes.
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1 frequently?
2 A. Exactly.
3 4 5 Q. So when you didn't see him on the airplane frequently, then some of your correspondence was by e-mail, other times by telephone?
6 A. Mm-hmm.
7 Q. And other times in person?
8 A. Yes.
9 10 11 Q. And what was your e-mail -- what was the substance of the e-mail correspondence that you would have with Jeffrey Epstein?
12 13 A. It would have to be related. I mean, you have to give me a topic. I mean, whether it be a car --
14 Q. Never about the criminal investigation?
15 A. III, no, no, never.
16 17 Q. Do you know what his intention is or his plans are for when he is off probation?
18 A. No idea.
19 Q. Or off community control?
20 A. I have no idea.
21 22 23 Q. Has he ever indicated to you he wants you to fly him to some other location outside the United States to live permanently?
24 A. II, no.
25 Q. Have you ever flown to his place in Paris?
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1 A. We've landed in Paris.
2 3 Q. You're aware that he has some control over another piece of property over there?
4 5 A. I know we've picked up luggage at aresidence. Idon't know to what extent his ownership is, if any.
6 Q. All right.
7 A. Right.
8 9 Q. And are you aware that he has some employees that listen to what he says that work in that house?
10 MR. CRITTON: Form.
11 12 THE WITNESS: In Paris, yes, there is one person there.
13 BY MR.
14 Q. What's his name?
15 16 A. Voltzan. Because I always thought there was nobody there.
17 Q. Vultzan Cauldron (phonetic)?
18 19 A. I don't know exactly. I would have to look it up.
20 Q. Have you talked to him before?
21 A. No.
22 Q. When you've been in Paris --
23 A. You're not going to ask why?
24 Q. Well, I'm assuming he doesn't speak English.
25 A. There you go, okay.
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1 Q. So I thought there was no need for that?
2 A. Okay. I just wanted to see.
3 4 Q. Where do you stay when Jeffrey Epstein is in Paris?
5 A. A hotel.
6 7 Q. Okay. And in New Mexico, when you land there, you stay on the ranch somewhere, but at your place?
8 A. I stay at my place.
9 10 Q. And in New York, you have an apartment that he sets you up at, right, the 301?
11 A. Yes, I have a place I could stay.
12 Q. And in St.
13 A. Hotel.
14 Q. And in Paris you stay at a home?
15 A. (Nodding.)
16 17 18 19 20 21 22 Q. Are there any other properties such as what we were talking about today -- I'm not saying Jeffrey Epstein is the sole owner or direct owner, but any other properties that you're familiar with that Jeffrey Epstein is -- has direct access to and at least it gives the appearance to you that he is the owner or controller of that property?
23
24 25 THE WITNESS: Name the list that you've stated.
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MR. CRITTON: Form.
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1 BY MR•
2 Q. The Manhattan house.
3 A. Yes.
4 5 6 Q. Mansion or whatever we want to call it, the Zorro Ranch, the island of St. James, the Palm Beach house.
7 A. Mm-hmm.
a Q. And the Paris place.
9 A. That's all I'm aware of.
10 11 12 Q. And have you ever at any of those five places hung around him and stayed around him for during the daytime for the course of an entire day?
13 A. No.
14 15 Q. All right. So do you know what he does during his days while he's there?
16 A. No.
17 18 Q. Are you aware of a list of underage girls that is kept to come over and service him each of those days?
19
20
21 BY MR.
22 23 Q. I'm the first person to ever even imply that to you, right?
24 A. A list, yes, you are.
25 Q. Okay. Have you ever been made aware that
137
MR. CRITTON: Form.
THE WITNESS: Absolutely not.
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1 2 keeps a list of underage girls to service Jeffrey Epstein for sexual purposes?
3 A. I am not aware of them.
4 MR. CRITTON: Form to the last question.
5 BY MR.
6 7 8 9 Q. Have you ever been made aware that Ghislaine Maxwell keeps a list of girls in the nearby areas of each of -- at Jeffrey Epstein's residences to service him sexually?
10 A. No.
11 MR. CRITTON: Form.
12 BY MR.
13 14 15 16 Q. Okay. Have you ever read some of the complaints that have been filed against him in the various courts, whether state court or federal court, against Jeffrey Epstein?
17 A. No, I have not.
18 19 20 Q. All right. So this Jane Doe 102 versus Jeffrey Epstein, you're not familiar with who that person is?
21 A. No idea.
22 23 Q. Okay. I'm going to mark Jane Doe, one of the 22, versus Epstein as Exhibit No. 4 to this deposition.
24 25 (Plaintiff's Exhibit No. 4 was marked for identification.)
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1 BY MR. IIIIIII
2 3 4 5 Q. And ask you about some of the allegations in here and see if you know anything about them. It indicates he owns aflight of aircraft that includes a Gulfstream, a helicopter, and aBoeing 727. True?
6 MR. CRITTON: What's the question?
7 THE WITNESS: Please repeat.
8 BY MR. MEN
9 10 11 Q. Are you aware of him owning a Gulfstream IV aircraft, a helicopter and aBoeing 727? I think we talked about it, right?
12 A. Right.
13 14 Q. Okay. And it indicates afleet of motor vehicles?
15 16 17 MR. CRITTON: Wait aminute. He said right, is that we talked about it, as distinct from him knowing one way or another.
18 THE WITNESS: What's the question?
19 BY MR. :
20 Q. Do you know that he owns those things?
21 A. I do not know that he owns them.
22 Q. Do you believe that he owns those things?
23 MR. CRITTON: Form.
24 THE WITNESS: I would be guessing, so...
25
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1 BY MR.IIIIIII:
2 3 Q. What does the company NES, LLC, do to your knowledge?
4 A. I have no idea.
5 6 Q. How does that company generate profit, if you know?
7 A. I have no idea.
8 9 10 Q. but you have absolutely no clue what they do to generate money? That's the company that pays your paycheck,
11 A. No, sir.
12 Q. If anything?
13 A. Correct.
14 15 Q. Have you ever heard that that company generates money through sex trafficking of young girls?
16 MR. CRITTON: Form.
17 THE WITNESS: Absolutely not.
18 BY MR. :
19 20 21 22 Q. Never, okay. Have you ever heard that Jeffrey Epstein has a sexual preference for underage girls? Other than what you've read in the newspaper, have you heard that from any other individuals before?
23 A. No.
24 25 Q. Ever heard that he has had sex or sexual relationships with many minor girls, some as young as 12
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1 years old?
2 MR. CRITTON: Form.
3 THE WITNESS: No.
4 BY MR.S
5 Q. Never?
6 A. Never.
7 8 9 Q. Have you ever seen any photographs in any of his homes depicting young-looking girls engaging in sex acts?
10 A. No.
11 12 Q. Or reading directly from the complaint, "engaged in lewd acts"?
13 A. No, absolutely not.
14 15 Q. Have you looked around the walls of his various homes when you're in there picking up luggage?
16 17 18 A. I mean, not any more than I walked in here and not looking at the walls over there, I couldn't tell you what those are; so nothing specific.
19 20 Q. Sometimes we're talking about a50,000 square foot house?
21 A. Exactly.
22 Q. In Manhattan?
23 A. It's pretty big.
24 25 Q. Okay. Have you ever looked at any of his computers for any reason?
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1 A. No.
2 Q. I know that you helped set up some of the
3 A. Computers are not my expertise.
4 5 6 Q. All right. Have you ever been told that Mr. Epstein committed sex acts against underage girls on aliteral daily basis, that's what he does?
7 A. I've never been told that.
B 9 Q. Have you ever read the complaints against him that indicate that's what he does on adaily basis?
10 MR. CRITTON: Form.
11 THE WITNESS: No.
12 BY MR.
13 14 15 Q. So in your mind, you never believed that you were transporting around somebody whose sole goal in life is to get -- have sex with little girls?
16 MR. CRITTON: Form.
17 THE WITNESS: i never believed that, no.
18 BY MR.
19 20 21 22 Q. Okay. Have you ever been told that he conspired with others, including assistants and/or his drivers and/or pilots and his friend Ghislaine Maxwell, to further these sex acts and to avoid police detection?
23 MR. CRITTON: Form.
24 BY MR. :
25 Q. Have you ever -- anybody ever questioned you
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3 MR. REINHART: Hold on. The question is have you ever been told that fact that he just read to you?
5 BY MR.
6 Q. Right.
8 9 10 Q. Has anybody ever questioned you about your possible involvement with helping to facilitate Mr. Epstein have sex with underage girls?
11 A. No.
12 13 14 Q. When you were questioned by either the police or the -- whoever the investigative resource that was being used at the time?
15 A. Right.
16 17 Q. Do you remember who that person was that was questioning you?
18 A. No, I don't remember.
19 20 Q. I know you don't know the location where it was, but do you remember who they were affiliated with?
21 A. No.
22 Q. Was it only one time?
23 A. Yes.
24 25 Q. Did you also have to testify before a grand jury proceeding?
about that?
A. I have never been told that fact.
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1 A. No, I did not.
2 3 Q. Have you ever known Mr. Epstein to get a massage while on an airplane?
4 5 6 PHONE ATTORNEY: This is everybody in Boone, Charles and the witness is here and the court reporter and the videographer.
7 8 MR. : Fantastic, but I think that you may have the wrong room.
9 PHONE ATTORNEY: I was told to ask for 856.
10 11 MR. : Let's go off the record. (Off the record discussion.)
12 BY MR. •
13 14 15 16 17 18 19 Q. All right. In the complaint, I'm going to tell you what it alleges and I'm going to ask if this helps to refresh your recollection about any of Jeffrey Epstein's activities. The defendant, Jeffrey Epstein, transported the plaintiff to another state in order to engage in sex acts with her. And this occurred when she was merely 15 years old.
20 21 Do you remember transporting somebody that looked like they were 15 years old on your airplane?
22 A. No, sir.
23 24 25 Q. You never remember taking a 15-year-old, or somebody that looks around that approximate age, on your airplane?
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6 8 9 10 11 Q. Well, I know that you've indicated earlier in the deposition that you remember some girls under the age of 18 on the airplane. And so let me ask, before I get back into this, whether all those individuals you were talking about were accompanied by a parent or some of those people were on the airplane for some other purpose, modeling, or you don't know why they were there? I'm going to let you elaborate on who these people are that you believe may have been under the age of 18 and why you think they were on the airplane?
12 MR. CRITTON: Form.
13 14 15 16 17 18 19 THE WITNESS: We've had younger people on the airplane that have been, you know, with their family members, like you said. I don't remember transporting anybody that was of questionable age. I'm not -- I'd only be guessing at somebody's age if I didn't ID them at the foot of the airplane. So I can't guess to their age.
20 BY MR. :
21 22 23 24 Q. All right. "Mr. Epstein used his private jet to transport the minor plaintiff to Manhattan where he provided her spending money and accommodations with him at his mansion."
25 Do you have any idea who that might be
A. Can you be more specific?
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1 referring to?
2
3
4 BY MR. MM.
5 6 7 Q. And you don't remember being a pilot of an airplane where he was transporting a 15-year-old to Manhattan from Miami or Palm Beach?
8 9 A. No. I'd be guessing at somebody's age and I can't guess.
10 11 12 13 Q. "Defendant transported plaintiff in his private jet to locations that included Palm Beach, New York City, Santa Fe, Los Angeles, San Francisco, St. Louis."
14 15 Do you remember ever piloting his airplane to those destinations that I just mentioned?
16 MR. REINHART: Can we break them down?
17 Objection; compound.
18 MR. : Okay.
19 BY MR.
20 21 Q. Beach? Have you ever flown his airplane to Palm
22 A. Yes, sir.
23 24 Q. Okay. Have you ever flown it to New York City?
25 A. Yes.
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THE WITNESS: No, sir.
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1 Q. To Santa Fe?
2 A. Yes.
3 Q. To Los Angeles?
4 A. Yes.
5 Q. To San Francisco?
6 A. Yes.
7 Q. To St. Louis?
8 A. Yes.
9 10 11 Q. All right. Continuing to international destinations, including Europe, have you ever flown it to Europe?
12 A. Yes.
13 Q. The Caribbean?
14 A. Yes.
15 Q. And Africa?
16 A. Yes.
17 18 19 20 Q. On those flights to those various places, is it your -- to the best of your knowledge, you were unaware of Jeffrey Epstein engaging in sex with underage girls on his airplane?
21
22 23 THE WITNESS: I have no knowledge of any of that.
24 BY MR.
25 Q. "He provided accommodations with him in order
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1 2 3 to have her available to him at all times whenever he wanted, including while transporting the minor plaintiff on his private jet."
4 That's something that you had no knowledge of?
5 A. (Witness shakes head.)
6 Q. You have to a yes or no.
7 A. I'm sorry, no.
8 9 10 11 12 Q. "Each time they would travel to one of these destinations, the same pattern of sexual abuse would occur, often with a vast array of aspiring models, actresses, celebrities, and/or other females, including minors from all over the world."
13 14 Again, that's something you have no personal knowledge of?
15 A. No.
16 17 18 19 20 Q. Has anybody ever indicated that if you did have personal knowledge of some of these things, then you could also have been implicated in some form of a crime? Has any law enforcement or anybody ever indicated that to you?
21 A. No.
22 23 Q. Okay. Is that something you've ever worried about?
24 A. No.
25 Q. All right. "Upon information and belief,
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10 11 A. I'd have to look at the flight logs, but I personally don't remember flying into Turkey.
12 13 14 Q. And would the flight logs coming into the United States from Turkey indicate the names of the people on the plane?
15 A. They might.
16 17 Q. Okay. Where would I get those particular flight logs that would have that information?
18 A. Depended upon what year you're talking.
19 20 Q. We're talking in this particular complaint between 1998 and 2002.
21 22 A. I'm not -- I don't possess those passenger manifests.
23 Q. Do you know who would possess those?
24 A. That would be I guess
25 MR. REINHART: Do you know who has them today?
149
defendant transported minor girls from Turkey." Did you ever leave in one of his airplanes out of Turkey?
A. I'd have to look at the records. I don't recall Turkey.
Q. Do you ever remember taking any minor girls out of Turkey?
A. No, I don't remember.
Q. What records would you have to look at to see if you took people out or left out of Turkey?
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1 2 THE WITNESS: I do not know who has them today.
3 BY MR.
4 Q. Who did you give them to?
5 6 7 A. Actually, I didn't give them to anybody. Dave Rogers was in possession of those logs. So I don't know where they are right now.
8 9 10 11 12 Q. You're still thinking that the best evidence of that, any flight that may have left out of Turkey, would be in the flight logs that's marked as Composite Exhibit 1, or are we talking about the manifests that we've been referring to?
13 14 A. I don't know how accurate that log book is or even how accurate the passenger manifest is.
15 16 17 Q. Okay. So there may be no actual documentation indicating a flight leaving out of Turkey when, in fact, aflight may have left out of Turkey?
18 A. Correct.
19 20 21 Q. Okay. The Czech Republic is the next place listed. Is that aplace you've flown to or from in a Jeffrey Epstein airplane?
22 A. More specific, could you name the city?
23 24 25 Q. I can't name the city, at least the complaint doesn't name the city. But I've been to the Czech Republic before. Anywhere within that country, have you
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