Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV-80119-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant Related cases THIRD PARTY WITNESS IGOR ZINOVIEWS MOTION FOR PROTECTIVE ORDER AND INCORPORATED MEMORANDUM OF LA Third Paiiy Witness Igor Zinoviews Mr Zinoview by and through his undersigned attorney moves this Court pursuant to Fed Civ for a protective order regarding his deposition and as grounds therefore would state As reflected on the affidavit of Igor Zinoview attached as Exhibit A he works for Defendant Jeffrey Epstein Mr Epstein as a driver and bodyguard He did not know Mr Epstein before November of He first became employed by Mr Epstein in November of Additionally Mr Zinoview would testify as set forth on his affidavit that at no time has he discussed with Mr Epstein any issues involving Mr Epsteins criminal case nor any of the cases or issues involved with civil plaintiffs Case Document Entered on FLSD Docket Page of In many of the depositions counsel for L.M and E.W has asked them as witnesses to assume ce1iain facts about which they have no knowledge and he then asks their opinions about certain facts See Exhibit Epsteins Motion for Protective Order to Prohibit Inappropriate Deposition Questions There is no information which Mr Zinoview has relating to the facts and circumstances surrounding any of the pending civil cases in that none of their allegations directed to Mr Epstein extend beyond September of Therefore whatever information Mr Zinoview may have postdates that time Regarding the scope of discovery Judge Linnea Johnson noted in her October Omnibus Order DE while the scope of discovery is broad it is not without limits Washington Brown Williamson Tobacco F.2d 11th Cir Cou1is have long held that while the standard of relevancy in discovery is a liberal one it is not so liberal as to allow a party to roam in the shadow zones of relevancy and to explore matter sic which does not presently appear ge1ane on the theory that it might conceivably become so Food Lion Inc United Food Commercial Workers Intern Union F.3d C.A D.C string cite omitted Rule Federal Rules of Civil Procedure provides that a party or any person from whomn discovery is sought may move for a protective order in the court where the action is pending The court may for good cause issue an order to protect a party or person from annoyance embarrassment oppression or undue burden or expense including one or more of the following A forbidding the disclosure or discovery Case Document Entered on FLSD Docket Page of As set forth in his affidavit Mr Zinoview cannot possibly have any knowledge or information that is presently germane to this action Accordingly the Court should enter a protective order prohibiting his deposition WHEREFORE third paity witness moves this comt for a protective order pursuant to Rule Federal Rules of Civil Procedure that his deposition not take place or the questioning be limited By JACK ALAN GOLDBERGER ESQ Florida Bar No jagesg bellsouth.net Rule Certification I hereby certify that counsel for the movant has conferred or attempted to confer with opposing counsel in a good faith effort to resolve the discovery issues prior to the filing of this motion for protective order but has been unable to do so Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF I also ce1tify that the foregoing document is being served this day on aII counsel of record identified on the following Service List in the manner specified by CM/ECF on this_ day of November Respectfully submitted By JACK ALAN GOLDBERGER ESQ Florida Bar No i agesg bellsouth.net Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax Counsel/or Defendant Jeffrey Epstein Case Document Entered on FLSD Docket Page of Certificate of Service Jane Doe No Jeffrey Epstein Case No 08-CV-80119-MARRA/JOHNSON Stuart Mermelstein Esq Brad Edwards Esq Adam Horowitz Esq Rothstein Rosenfeldt Adler Mermelstein Horowitz P.A East Las Olas Boulevard Biscayne Boulevard Suite Suite Fort Lauderdale FL Miami FL Phone Fax Fax bedwards rra-law.com ssm sexabuseattorney.com Counsel for Plaintiff in Related Case Wo ahorO vitz sexabuseattorney.com Counsel/or Plaintiffs In related Cases Nos II Richard Horace Willits Esq Richard Willits P.A th Avenue North Suite Lake Worth FL Fax Counsel for Plaintiff in Related Case No reelrhw hotmail.com Jack Scarola Esq Jack Hill Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL Fax jg searcylaw.com ph searcylaw.com Counsel.for Plaintiff C.MA Bruce Reinhart Esq Bruce Reinhaii P.A AustraHan Avenue Suite West Palm Beach FL Paul Cassell Esq Pro Hae Vice South Room Salt Lake City UT Fax cassellp la.w utah ed Co-counsel for Plaintiff Jane Doe Isidro Garcia Esq Garcia Law Firm P.A Datum Street Suite West Palm Beach FL isidrogarcia bellsouth.net Counsel for Plaintiff in Related Case No Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Fax ri osefs berg podhurst.com kezell podhurst.com Counsel for Plaintiffs in Related Cases Nos and Jack Alan Goldberger Esq Case Document Entered on FLSD Docket Page of Fax brucereinhartlaw.com Counsel/or Defendant Sarah Kellen Theodore Leopold Esq Spencer Kuvin Esq Leopold Kuvin P.A PGA Blvd Suite Palm Beach Gardens FL Fax sk lvin leopoldkuvin.com Counsel for Plaint in Related Case No Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Fax iagesq bellsouth.net Counsel for Defendant Jeffrey Epstein Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CV-80119-MARRA-JOHNSON JANE DOE NO Plaintiff JEFFREY EPSTEIN Defendant Related Cases I AFFIDAVIT OF IGOR ZINOVIEV STATE OF FLORIDA SS COUNTY OF PALM BEACH BEFORE ME the undersigned authority personally appeared Igor Z_inoviev having personal lmowledge and being duly sworn deposes and says My name is Igor Zinoview I began working for Mr Epstein in November of I did not know him until I began working for him I have never discussed nor has he ever attempted to discuss with me any facts or infonnation relating to any legal matters in which he is involved I work for Mr Epstein as his driver bodyguard and trainer Case Document Entered on FLSD Docket Page of Page FURTHER THE AFFIANT Case Document Entered on FLSD Docket Page of L.M Plaintiff IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO AB JEFFREY EPSTEIN Defendant EPSTEINS MOTION FOR PROTECTIVE ORDER TO PROHIBIT INAPPROPRIATE DEPOSITION QUESTIONS Defendant JEFFREY EPSTEIN Epstein pursuant to Rule Florida Rules of Civil Procedure moves for a protective order to prohibit argumentative harassing and inappropriate questions in depositions and states At numerous depositions Plaintiffs counsel has repeatedly asked argumentative and harassing questions that are irrelevant and not reasonably calculated to lead to the discovery of admissible evidence In particular Plc;iintiffs counsel has asked questions that improperly sought to illicit lay opinions from fact witnesses asked questions regarding witnesses feelings towards Mr Epstein and their beliefs regarding media reports of this case asked whether they would leave their children with Mr Epstein and asked whether they would go back to work for Mr Epstein assuming the media reports were accurate among other things These questions and the responses thereto will never be admissible They are argumentative irrelevant and seek speculative answers and inadmissible lay opinions EXHIBIT Case Document Entered on FLSD Docket Page of LM Egstein Case No Epsteins Motion for Protective Order to Prohibit Inappropriate Deposition Questions Page of For example in the deposition of Larry Visoski one of Mr Epsteins pilots Plaintiffs counsel asked the following questions seeking to obtain Mr Visoskis beliefs and opinions on Plaintiffs allegations All right When you read in the newspapers the allegations that Mr Epstein was involved with numerous underage girls for sexual reasons were you surprised A I didnt believe it Do you believe it today A I dont believe it You dont believe that Jeffrey Epstein was involved with underage girls in a sexual way MR CRITTON Form THE WITNESS Youre asking for my opinion and I dont think my opinion is relevant in that matter BY MR EDWARDS I think its relevant Can you just tell me whether today you believe that Jeffrey Epstein has engag.ed in sex with underage girls MR CRITTON Form speculation irrelevant always THE WITNESS Its irrelevant BY MR EDWARDS I need an answer A I dont believe he had sex with underage women Or engaged in any sexual acts with underage women MR CRITTON Form Case Document Entered on FLSD Docket Page of LM Epstein Case No Epsteins Motion for Protective Order to Prohibit Inappropriate Deposition Questions Page of THE WITNESS No BY MR EDWARDS You think that this ls just a story that a bunch of underage women have made up A Speculatlon Then well handle the question this way If you were to believe based on information and evidence that Mr Epstein engaged in sex or some form of sex acts with people of the age range of years old would you continue your employment with Mr Epstein MR CRITTON Form speculation THE WITNESS I would certainly be speculating and I have to discuss it with my wife long and hard I dont think I could give you a correct and honest answer at this time See Excerpts of Deposition of Larry Visokski at attached as composite Exhibit A Other examples of similar improper questions are included in Exhibit A Not only do these questions seek improper lay opinions Plaintiffs counsel asked Mr Visoski his belief as to the truth of hearsay newspaper articles The foregoing questions are obviously irrelevant argumentative and not reasonably calculated to lead to the discovery of admissible evidence Moreover whether Mr Visoski would continue working for Mr Epstein if Plaintiffs allegations are true has absolutely no relevance to any claim or defense in this case The questions are simply improper and meant to harass and embarrass the Case Document Entered on FLSD Docket Page of LM Epstein Case No Epsteins Motion for Protective Order to Prohibit Inappropriate Deposition Questions Page of witness Mr Visoski was questioned for over four hou.s and much of the time was wasted on irrelevant and harassing questions Plaintiffs counsel asked similar questions at the deposition of Larry Eugene Morrison another one of Mr Epsteins pilots Certainly youve read certain newspaper articles about the allegations police reports otherwise the allegations that occurred or have been alleged to have occurred at his Palm Beach mansion correct A Uh-huh Correct A Correct Given the nature of those allegations would you leave your daughter of years old with Mr Epstein alone MR PIKE Form Move to strike A Yes And despite pleading guilty to procuring underage girls for the purposes of sex you still feel comfortable leaving a 15-year-old girl around him MR PIKE Form Move to strike A Yes I mean with my daughter yes I dont know how he behaves around anybody else I just know that the respect that he showed me I feel safe with my daughter And have you read in detail the reports as to what happened at his house with the girls Case Document Entered on FLSD Docket Page of LM Epstein Case No Epsteins Motion for Protective Order to Prohibit Inappropriate Deposition Questions Page of A Only MR PIKE Form A whats been in the newspapers and published If you read and hear testimony given well I can tell you now testimony has been given in this case that what happens is A or year old is led upstairs by herself told to get naked he lays down on his back there is a brief massage before he turns over exposes himself erect masturbates while he tells this or year old to pinch his nipples as hard as she can while he inserts his fingers into their vagina and ejaculates all over them before saying Take your money and leave MR PIKE Form Move to strike BY MR EDWARDS Okay Then You can continue to come back for every time or every girl you bring me within your age group and I get to do this again I pay you per person If that is the testimony MR PIKE Form that what happens behind closed doors with him do you still feel comfortable leaving a or year old in a room with Jeffrey Epstein MR PIKE Form A If that in fact is what actually happened no Would you go back considering what youve read and what you may or may not believe would you go back to working for Jeffrey Epstein MR PIKE Form A I cant say I still work for him on a maintenance to Case Document Entered on FLSD Docket Page of LM Epstein Case No Epsteins Motion for Protective Order to Prohibit Inappropriate Deposition Questions Page of9 maintain the airplanes and stuff like that so Excerpts of Deposition of Larry Eugene Morrison at attached as composite Exhibit Again whether Mr Morrison would work for Mr Epstein considering what he has read and what he may or may not believe i.e considering hearsay media accounts and inadmissible lay opinion has no bearing on the instant case ln addition questions regarding whether Mr Morrison would leave his children alone with Mr Epstein could have only been meant to harass and embarrass Mr Morrison Nevertheless Mr Morrison testified that he would leave his children with Mr Epstein As Plaintiffs counsel was obviously not happy with the answer to this question he proceeded to press Mr Morrison with inflammatory statements until he got the answer he wanted Plaintiffs counsel has also asked the same improper line of questions in other witnesses depositions The above-cited questions exceed the bounds of permissible discovery they have absolutely no relevance to this case Accordingly the Court should enter a protective order prohibiting such questions and should sanction Plaintiffs counsel if such inappropriate questions are asked at future depositions Regarding the scope of discovery Judge Linnea Johnson noted in her October Omnibus Order while the scope of discovery is broad lt is not The Omnibus Order DE was entered in the federal companion case Jane Doe No Epstein Case No MARRNJOH NSON in the U.S District Court Southern District of Florida Case Document Entered on FLSD Docket Page of LM Epstein Case No Epsteins Motion for Protective Order to Prohibit Inappropriate Deposition Questions Page of without limits Washington Brown Williamson Tobacco F.2d 11th Cir Courts have long held that while the standard of relevancy in discovery is a liberal one it is not so liberal as to allow a party to roam in the shadow zones of relevancy and to explore matter sic which does not presently appear germane on the theory that it might conceivably become so Food Lion Inc United Food Commercial Workers Intern Union F.3d C.A D.C string cite omitted also Capco Properties LLC Monterry Gardens of Pinecrest Condo So 2d Fla 3d DCA holding that discovery in civil cases must be relevant to the subject matter of the case and must be admissible or reasonably calculated to lead to admissible evidence Morton Plant Hospital Assn lnc Shahbas So 2d Fla 2d DCA holding that discovery should be denied when it has been established that the information requested is neither relevant to any pending claim or defense nor will it lead to the discovery of admissible evidence citing Tanchel Shoemaker So 2d Fla 5th DCA As illustrated above the questions are simply not germane to any pending claim or defense nor will they lead to the discovery of admissible evidence Whether Mr Visoski believes or disbelieves the media accounts of this case or whether Mr Morrison would leave his children with Mr Epstein is not relevant and cannot conceivably lead to the discovery of admissible evidence The Court should curtail these inappropriate lines of questions and enter a protective order prohibiting them Rule Florida Rules of Civil Procedure provides the Court with Case Document Entered on FLSD Docket Page of LM Epstein Case No XMBAB Epsteins Motion for Protective Order to Prohibit Inappropriate Deposition Questions Page of the power to make any order to protect a party or person from annoyance embarrassment oppression or undue burden or expense that justice requires including that certain matter not be inquired into or that the scope of the discovery be limited to certain matters Accordingly Epstein requests the Court enter a protective order prohibiting Plaintiffs counsel from asking witnesses questions regarding opinions and beliefs regarding media articles and the allegations in this case and whether they would leave their children with Epstein or questions of a similar nature and limiting the scope to the witnesses personal knowledge regarding matters relevant to the claims and defenses in this case See Shahbas So 2d at WHEREFORE Defendant JEFFREY EPSTEIN respectfully requests the Court enter a protective order prohibiting Plaintiffs counsel from asking witnesses questions regarding opinions and beliefs regarding media articles and the allegations in this case and whether they would leave their children with Epstein or questions of a similar nature and limiting the scope to the witnesses personal knowledge regarding matters relevant to the claims and defenses in this case and grant any additional relief the Court deems just and proper Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S Mail to the following addressees on this 3rd day of November Brad Edwards Esq Rothstein Rosenfeldt Adler East Las Olas Boulevard Suite Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite Case Document Entered on FLSD Docket Page of LM Epstein Case No Epsteins Motion for Protective Order to Prohibit lnapproprlale Deposition Questions Page of Fort Lauderdale FL Phone Fax Counsel for Plaintiff Jay Howell Esq Jay Howell Associates P.A Cesery Boulevard Suite Jacksonville FL Phone Fax Co-counsel for Plaintiff West Palm Beach FL Fax Co-Counsel for Defendant Jeffrey Epstein BURMAN CRITTON LUTTIER COLEMAN LLP Banyan Blvd Suite West Palm Be FL By __ Critton Jr orida Bar Michael Pike Florida Bar Counsel for Defendant Jeffrey Epstein Case Document Entered on FLSD Docket Page of Larry Visoski ll l3 l7 zq IN Tile ClRCUlT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO AD L,H Pltlintiff vs JllfFREY EPSTEIH De fend.int DEPOSl TION Of LARRY VISOSKI Thursday October p.m Fla9let Drive Suite West Pall Beach Florida Reported By We:ndy Beath Anderson RPR CRR FPR Notary lblic State of Florida squire Deposition Sc1 267vices West Po.l1n Bench Of ice Job APPEARANCES On behalf of the Plaintiff BRADLEY EDWARDS ESQUIRE ROTHSTEIN ROSENFELDT ADLER East Las Olas Boulevard Suite Fort Lauderdale Florida On behalf of the Defendant ROBERT CRITTON JR ESQUIRE BURMAN CRITTON LUTTIER Banyan Boulevard Suite West Palm Beach Florida On behalf of the Witness BRUCE REINHART ESQUIRE South Australlan Avenue Suile West Palm Beach Florida ALSO PRESENT CARA HOLMES ESQUIRE N.W Avenue Pembroke Pines Florida ADAM HOROWITZ ESQUIRE MERMELSTEIN HOROWITZ P.A Biscayne Boulevard Suite Miami Florida RICHARD WILLITS ESQUIRE VIA TELEPHONE RICHARD WILLITS P.A Avenue North Suite Lake Worth Florida INDEX October WITNESS DIRECT CROSS REDIRECT RECROSS LARRY VISOSKI BY MR EDWARDS BY MR CRITTON BY MR EDWARDS BY MR CRITTON l7 EXHIBITS NUMBER DESCRIPTION PAGE PLAINTIFFS EX FLIGHT I.OG BOOK MARKED IN PREVIOUS DEPO PLAINTIFFS EX PLAINTIFFS EX PLAINTIFFS EX PLAINTIFFS EX MESSAGE PAD MESSAGE PAD COMPLAINT INMATE VISITOR LOG PROCEEDINGS Deposition taken before Wendy Beath Anderson Certified Rea!tirne Reporter and Notary Public in and for the State of Florida at Large In the above cause MR EDWARDS Were going to put something on the record about well well do It this way MR REINHART Do it at the end after we get him whatever you want Its your show MR EDWARDS Okay There were dont even think Mr Willits is aware of this There was a subpoena duces tecum for this witness as well as the previous witness which was another pilot Dave Rogers and that duces teoum was to bring the flight logs related from through What was produced at the previous deposition were flight logs from through ancl now Mr Reinhart has agreed to produce the remainder of the flight logs requested those going from t11rough MR REINHART Correct Theyre pilot logs not night 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 Case Document Entered on FLSD Docket Page of I I I I I I I i i October women MR CRITTON Form THE WITNESS No BY MR EDWARDS You think that this Is Just a story tl1at a bunch of underage women have made up A Speculation MR CRITTON Objection Now its Q3 All right When you read in the newspapers the allegations that Mr Epstein was involved with numerous underage girls for sexual reasons were you surprised A I didnt believe it Do you believe it today A I dont believe it You dont believe that Jeffrey Epstein was involved with underage girls in a sexual way MR CRITTON Form THE WITNESS Youre asking for my opinion and I dont think my opinion relevant in that matter BY MR EDWARDS I think its relevant Can you just tell rne whether today you believe that Jeffrey Epstein has engaged in sex with underage girls MR CRITTON Form speculation Irrelevant always THE WITNESS Its irrelevant BY MR EDWARDS I need an answer A I dont believe he had sex with underage women Or engaged in any sexual acts with underage argumentative Who gives a darn what he thinks one way or another If he has personal nowledge MR EDWARDS Youre objecting to the form MR CRITTON Its argumentative MR EDWARDS Youre objecting to the form MR CRITTON Yes MR EDWARDS Okay BY MR EDWARDS Is that something that you believe that a b1.1nch of women some of which know each other some dont some of which have been on the airplane and some which haven made this up that Jeffrey Epstein engaged In some sexual conduct with them MR CRITTON Form THE WITNESS What I believe doesnt matter in this case does it BY MR EDWARDS I need an answer Do you believe it Do you believe these girls made this up MR CRITTON Form MR REINHART Im going to instruct him not to answer Move on MR EDWARDS Is there a privilege that were asserting MR REINHART No Its irrelevant Its harassment and not likely to lead to discoverable evidence MR EDWARDS Im going 267to--put on the record right now that it is we are allowed discovery into a RICO count We are also allowed discovery into the intent of Mr Epstein In developing a criminal enterprise designed to sexually exploit and sexually abuse underage girls We believe that in doing so he associated intentionally with people of similar beliefs that sex with underage girls is okay and that there have been rnany discussions with this witness as well as many other witnesses with to Ins lire his protection from law enforcement that they not answer these specific questions And thus the opinions and beliefs of all of these witnesses that we are Case Document Entered on FLSD Docket Page of Larry Visoski October alleging associated with this criminal enterprise A Its an opinion and I believe that he has are certainly reasonably calculated to lead to the not discove1y of admissible evidence And If youre Okay Isnt It true that at some point in still instructing the witness based on that lime you learned that Jeffrey Epstein has strike proffer not lo answer any of these questions Im that going to continue to ask the questions and you can MR CRITTON When you ultimately get lo a instruct him not to answer and we can go to the good place to break Vllill you let us know Court MR EDWARDS Lets break now MR REINHART My response is to his opinion A break was had at a.m whether people making allegations in this case are BY MR EDWARDS colluding or making up a story is irrelevant to All right Eighteen years of being a pilot what you just said So I am going to instruct him for Jeffrey Epstein and in terms of being able to name not to answer any question that goes to his opinion somebody that you would say youve observed with Jeffrey of someone elses motivation or the truth of facts Epstein and would classify that person as Jeffrey to which he has no knowledge Epsteins friend can you name anybody So yes Im instructing him not to answer A Nadia Sarah Just people that we see MR CRIHON Let me add in rny part Is that I routinely on the airplane think youre certainly not only capable to ask ll1ats people you see routinely In the last questions with regard to what his personal five to ten years right knowledge is and if he knows something or he has A Yes reasonable basis for it certainly you are entitled Prior to that time anybody that youve to that information I think youve asked those noticed as Jeffrey Epsteins friend may be Ghislaine questions and hes given you straightforward Maxwell answers as to what he knew or what he didnt know A What time frame under those circumstances And as to what his Is that a person that at some point In time thoughts are on something which he has no factual you would classify as Jeffrey Epsteins friend basis or even an assumption to know one way or A I would classify it I dont know If its another is irrelevant Thats ultimately for a true fact-finder in his case But thats only because they were on the While its interesting its argumentative and airplane together I dont think hes I mean do ii on a A Yes question-by-question basis if he has knowledge Do you know what Jeffrey Epstein does for a thats great but to argue your case with this living In your years of observing and talking with witness or any other witness doesnt serve a Jeffrey Epstein purpose and I think is you now I think its A No not a good use of our time Ill put ii hat way No Idea But you know yoti can go ahead and ask A No MR EDWARDS I can ask he question and if Ever asked him he witness is being instructed not to answer A No actually well let a judge decide whether he needs to answe Ever been curious the question and whether its discoverable or not A Sure MR REINHART Absolutely Make your record Ever done anything lo satisfy that curiosity BY MR EDWARDS A lfyot.l rnean Google II not really actually Do you have any reason to believe 1at Jeffrey I mean I really have not Epstein engaged in sexual activity with underage women Okay So In years of traveling and being A I have no reason to believe the pilol and driving and taking this person Jeffrey Okay So as you sit here today based on your Epstein from one property in New York to New Mexico and years of knowledge experience and observation of Florida and around the world you have no Idea what he Jeffrey Epstein is it your belief that he has not had does in terms of how he makes money sex or engaged in sexual activity with underage women A No sir Case Document Entered on FLSD Docket Page of MR CRITTON Form THE WITNESS No BY MR EDWARDS If you had been aware that Mr Epstein was and by this his is more ln the form of a hypothetical and that Im not going.to suggest to yol,J Its a fact that he was Bti if you had been aware that every single day Jeffrey Epsteins goal was to locate underage girls for 1he purposes of sex and either have sex with them on the airplane or at some other designation that you were destination that you were traveling him to would you have continued to pilot hose planes i MR CRITTON Form THE WITNESS You said It was hypothetical BY MR EDWARDS Right it is a hypothetical A Why would I want to answer that Because i2 youre being hypothetical I mean it would obviously be wrong Sure Well a hypothetical question i,s a legal question that Im allowed to as Case Document Entered on FLSD Docket Page of Larry Visosk:i i A i And Im just asking you if you did have tt knowledge that Jeffrey Epstein.was having sex will liltle girls either on the plane or al a place that you i were laking him to or from on a daily basis thals what he did would you have continued to be his pilot MR CRITTON Let me object Object lo he form Its argumentalive It has no more value than assuming he was chopping up bodies or anybod was chopping up bodies in the plane youre flying What difference does i make Form MR EDWARDS Whal difierence does it make in a case about him having sex wi little girls Im not going to argue with you about it Youve staled your objection MR CRITTON Exactly Its an argumentallve question MR EDWARDS Im not going lo argue with you i abo MR CRITTON Youre arguing with him about now MR EDWARDS No Im asking him the I i hypothetical i BY MR EDWARDS I Can you answer hat Would you have continued I to be a lot for somebody whos traveling to and from destinations with the goal of having sex with underage girls MR CRITTON Form THE WITNESS It could be any person It doesnt have to be Jeffrey Epstein then right BY MR EDWARDS True A No wouldnt pilot an airplane if there was wrongdoing going on That you knew about A That I knew you about sure Me reading this complaint to you Is this the first time youve heard these allegations A Yes against Mr Epstein A Yes Case Document Entered on FLSD Docket Page of Larry Visoski which he pied guilty lo MR CRITTON Form MR REINHART Can we for purposes of your hypothe lcal wha facts do you want him lo assume are true You said he facts to which he pied guilty but the witness already said he doesnt know what he pied guflty to He knows the charge he doesnt know the facts BY MR EDWARDS Solicitation of prostitution of a minor somebody under the age of MR EDWARDS Thats the charge right soliclta lon of prostitution of a minor MR CRITTON No I think youve got ii wrong Ill object to the form MR EDWARDS Okay BY MR EDWARDS Then well handle the question this way If you were to believe based on information and evidence that Mr Epstein engaged in sex or some form of sex act with people of the age range of years old would you continue your employment with Mr Epstein MR CRITTON Form speculation THE WITNESS I would certainly be speculating and I have to discuss it with my wife long and hard I dont think I could give you a correct and honest answer at this time BY MR EDWARDS Okay Given the allegations that have been made in this case is this something that you have discussed with anyone other than your attorney A No not really Only from the fact that theyre allegations and theres still a lot more work Im sure to be discovered MR CRITTON Let me put on there for the lf this deposition ls not typed and We request ii Id like at least this portion where Mr Edwards last question back about five pages worth so Just if you could mark it from this page back about five pages If nobody requests the deposilion Id just like those five pages MR EDWARDS Im going to request the deposition so MR CRITTON Okay Well mark this then so you could tell me where It Is approximately BY MR EDWARDS Is there a reason why you have not discussed with Jeffrey Epstein the allegations that have been Case Document Entered on FLSD Docket Page of Larry Eugene Morrison Volume I 2J zq ZS JN THE CIRCUIT COU OF THE l51H JUDICIAL CIRCUIT IN AND FOR PALM BJ::ACll COUNTY fLORIDI VOWME Pages to l,.H Plaintiff vs Ca.se No XMB ID JtFFREY EPSTEIN Defendant DEPOSIfION OF LARRY EUGENE MORRISON Tl EN Oil OF.HALF OF THE PLI INTHf Octobe a.m p.m IL Flagler Drive West Palm Beach fL Jennifer Dil,orenzo court reporter APPEARANCES OF COUNSEL On behalf of the Plalnliff L.M ROTI-lSTEtN ROSENFELDT ADLER BY BRADLEY EDWARDS ESQ and MICHAEL WHEELER ESQ East Las Olas Boulevard Suite Fort Laudordale FL bedwards rra-law.com mwheeler rra-taw.com On bohalf of Plaintiffs Jane Doe through MERMELSTEIN HOROWITZ P.A BY JESSICA ARBOUR ATTORNEY Biscayne Boulevard Suite Miami FL arbour soxabuseatlorney.corn On behalf of Plalntfs Jane Doo and by telephone PODHURST ORSECI P.A BY ATHERINEW EZELL ATTORNEY-AT-LAW Flaglor Street Miami Fl kezell podhurst.com On behalfofUl PlainliffC.M.A by telephone LAW OFFICE OF RICHARD WU.LITS P.A BY RICHARD WILLITS ESQ 10lh Avenue Suite Lako Worth FL lawyerwlils aol.com October APPEARANCE OF COUNSEL On behalf of the Defendant ATTERBURY GOLDBERGER WEISS BY JACK ALAN GOLDBERGER ESQ Australian Avenue Suite West Palm Beach FL goldberger agwpa.com On behalf of he Defendant by telephone BURMAN CRITTON LUTTIER COLEMAN BY MICHAEL PIKE ESQ Flaglir Drive Suite West Palm Beach FL ll mpike bclclaw.com On behaff of the witness LAW OFFICE OF BRUCE REINHART BY BRUCE REINHART ESQ One Cleartake Center Australian Avenue Suite West Palrn Beach Fl BReinhart BruceREinhariLaw.com INDEX OF EXAMINATION WITNESS LARRY EUGENE MORRISON DIRECT EXAMINATION By Mr Edwards Page CROSS-EXAMINATION By Ms Ezell CROSS-EXAMINATION By Mr Willits CROSS-EXAMINATION By Mr Pike FURTHER REDIRECT EXAMINATION By Mr Edwards INDEX TO EXHIBITS Plaintiffs Exhibit Description Page Twenty-four pages of JEGE Inc Passenger Manifest Plaintiffs Composite was attached to the original transcript and copies of the transcript Case Document Entered on FLSD Docket Page of October A I have no Idea I don know When you say that Nadia Marcinkova was just coming in the picture INhats your understanding as to who Nadia Marclnkova is relative to Mr Epstein A dont know I dont understand I dont know I didnt know If maybe she was like an exchange Jeffrey always appeared lo be very involved in educallon and phllanthropy I didnt know If she was an exchange-type student or something or v.11at I dont know When you say he appeared to be Involved In whal do you mean A Educa1lonal things foundations science foundations and things Speaking of he Florida Science Foundation ls a place here when he was on work release he spent a lot of time here youre aware of that A Thats v.11at Ive heard yeah What does that place do A I have no idea Does it do anything A I dont know dont know anything about ii Certainly youve read certain newspaper articles about the allegations police reports otherwise the allegations that occurred or have been alleged to have occurred at his Palm Beach mansion correct A Uh-huh Correct A Correct Given the nature of those allega!ions would you leave your daughter of years old with Mr Epstein alone MR PIKE Form Move to strike A Yes a You would A Witness nods head And why A Because I dont fear that he would try anything with my daughter He showed When I worked for him he showed me respect He never I never He never showed me disrespect He would ask how the famlly is I mean not on a personal level bt1t an employer/employee Righi Okay A He never showed me any reason not to trust him a But youre not a 13-year old girl so A No but like say he never showed me Case Document Entered on FLSD Docket Page of October And despite pleading guilty to procuring underage girls for the purposes of sex you still feel comfortable leaving a 15-year-old girl around him MR Pll Form Move to strike A Yes I mean with my daughter yes dont know how he behaves around anybody else just know that the respect hat he showed me feel safe with my dat1ghter And have you read ln detail the reports as lo what happened at his house with the girls A Only MR PIKE Form A whats been in tile newspapers and published If you read and hear testimony given well I can tell you now testimony has been given in this case that what happens Is A or year old is led upstairs by herself told to gel naked he lays down on his back there is a brief massage before he over exposes himself erect masturbates while he tells his or year old lo pinch his nipples as hard as she can while he Inserts his fingers into their vagina and ejaculates all over them before saying Take your money and leave MR PIKE Form Move to strike BY MR EDWARDS Okay Then You can continue to come back for every time or every girl you bring me within your age group and I get to do this again I pay you per person lf that is the testimony MR PIKE Form a that what happens behind closed doors with him do you still feel comfortable leaving a or year old in a room with Jeffrey Epstein MR PIKE Form A If that in fact is what actually happened no Case Document Entered on FLSD Docket Page of you witnessed Jeffrey Epstein committing A No Would you A No go back considering what youve read and what you may or may not believe would you go back to working for Jeffrey Epstein MR PIKE Form A I cant say I still work for him on a maintenance lo maintain the airplanes and stuff like that so Youre on his payroll A Salaried yes Do you know who else ls on his payroll A Well Dave and Larry Certainly If I want to know more about his private life do you know whos at his house A No Po you know who his housekeeper Is A No Do you know who his architect is A No no Does Larry visit him at his house A I would assume so Why do you say you would assume so That
