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10 - - - EXHIBITS 11 12 NUMBER DESCRIPTION PAGE 13 DEPOSITION EX. 29 MESSAGE BOOKS 592 DEPOSITION EX. 30 HANDWRITTEN NOTE ON 617 14 JEFFREY E. EPSTEIN MEMO PAD 15 DEPOSITION EX. 31 HANDWRITTEN MESSAGE 622 16 17 18 19 20 21 22 23 24 25 1 counsel? 2 MS. ARBOUR: Form. 3 THE WITNESS
re talking about right before the recess, do you ever recall dicr-ncsions with the State Attorney's office about an offer that was extended to Mr. Epstein to plead guilty and receive a five-year period of probation for an aggravated assault charge? A. Yes. Q. And that was a subject of discussion bet
DEPOSITION EX. 30 HANDWRITTEN NOTE ON 617 14 JEFFREY E. EPSTEIN MEMO PAD 15 DEPOSITION EX. 31 HANDWR
DEPOSITION EX. 30 HANDWRITTEN NOTE ON 617 14 JEFFREY E. EPSTEIN MEMO PAD 15 DEPOSITION EX. 31 HANDWRI
ney's office about an offer that was extended to Mr. Epstein to plead guilty and receive a five-year period o
n to the 21. MS. ARBOUR: Can I just ask one more? Is that 22 State Attorney's office for a criminal prosecution? 22 all right? 23 A. No. 23 RECROSS (DETECTIVE JOE RECAREY) 24 Q. Do you know why? 24 BY MS. ARBOUR: 25 A. Prior to me getting into the case, there was 25 Q. Detective, during t
Q. Yeah. I'm asking about, have you kept or do you have any documentation that would indicate the names of passengers that have flown on any of Jeffrey Epstein's planes? A. No. Q. Either in the form of paper or on a computer? A. No. 3527-003 Page 41 of 227 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8,
have a specific boss or somebody you answer to at NES, LLC? A. Several people would call to schedule flights from the office, being it either Mr. Epstein or, you <now, I would just get a phone call and they would schedule a trip. Q. Okay. Aside from Mr. Epstein, who else would there be that would
ars ago; five, six years ago. Q. Why? A. Professionalism, technique. Q. What do you mean by that? A. The way Dave would operate an aircraft, Jeffrey knew the difference when I was flying and when Dave was flying. Q. How do you know he knew the difference? A. Just -- Q. He told you? A. Yes.
Y MR. EDWARDS: Q. Like on this flight, we have "JE." I'm assuming that's Jeffrey Epstein, correct?
chedule flights from the office, being it either Mr. Epstein or, you <now, I would just get a phone call and
25 WITNESS: LARRY VISOSKI BY MR. EDWARDS: BY MR. CRITTON: BY MR. EDWARDS: BY MR. CRITTON: I NDEX DIRECT CROSS 6 214 EXH IB ITS REDIRECT RECROSS 220 221 3 NUMBER DESCRIPTION PAGE PLAINTIFF'S EX. 1 FLIGHT LOG BOOK (MARKED IN PREVIOUS DEPO) PLAINTIFF'S EX. 2 MESSAGE PAD 119 PLAINTIF
I just -- that shouldn't be in my name. Q. What do you mean you remember buying that car? A. I do a lot -- I do all the car purchases for Mr. Epstein. I'm a car fanatic, so for years I've been the car-shopper. I'm the car fanatic. Q. Okay. But these cars aren't classic vehicles. These are vehi
any time? A. I don't know that. Q. Are there any other cars, vehicles, items, other things that are registered in your name that are actually Jeffrey Epstein's? A. No. You've actually covered them all and actually shed light on some that I did not realize, like that Ford. 3527-003 Page 210 of 227 SUB
. Q. Your understanding is that's a corporation affiliated with Jeffrey Epstein? A. I know it's a corporation. I don't know its affiliation to Jeffrey. Q. At this point in time, the way that this car comes about is through a conversation with yourself and Jeffrey Epstein? A. Yes, yes. Q. So
A. I do a lot -- I do all the car purchases for Mr. Epstein. I'm a car fanatic, so for years I've been the c
hired by Jeffrey Epstein? A. It is somebody that is hired by Jeffrey Epstein. MR. EDWARDS: Okay. MR. CRITTON: One follow-up to your question. RECROSS (LARRY VISOSKI) BY MR. CRITTON: Q. With regard to the private individuals that you worked for prior to Mr. Epstein, what was the longest period
fice in New 12 York. I don't know. 13 Q. Okay. Who was the author of that book, do 14 you know? 15 A. I don't know. 16 Q. I mean did Mr. Epstein write it himself? 17 A. I have no idea. 18 Q. Okay. 19 A. I don't know who made those things. 20 Q. Is this a manual that's universal for
Yes. 11 Q. Has he been to Palm Beach? 12 A. Yes. 13 Q. What was the occasion for him to come to 14 Palm Beach? 15 A. That they met with Jeffrey Epstein's office. 16 Q. Does Mr. Kahn handle business matters 17 outside the household to your knowledge? 18 A. I don't think so. 19 Q. You think he
This is a card that we get for the office. 10 Q. Just to get in and out of the garage? 11 A. Right. 12 Q. Or does it also give you access to Jeffrey 13 Epstein's office, that being the Florida Science 14 Foundation? 15 A. For the garage. 16 Q. For the garage. 17 A. There are keys for
know? 15 A. I don't know. 16 Q. I mean did Mr. Epstein write it himself? 17 A. I have no idea. 18 Q
and Ms. 6 A. Yes. 7 Q. Okay. And at least on a couple of 8 occasions you have seen there? 9 A. Right. 10 MR. EDWARDS: All right. 11 RECROSS (JANUSZ BANASIAK) 12 BY MR. MERMELSTEIN: 13 Q. I have just one follow-up question. What 14 is the reason that you come to the office on a 15
Do you understand the question? A Yes. • Okay. A If you'll show me a picture then. Q No, ma'am. What I'm asking you to do, as an employee of Jeffrey Epstein's for many many years, and for many many years these ladies, young ladies, these females would come to his house and give him massages, do you remem
s Stuart Mermelstein, I also represent some plaintiffs in these cases, and it is my turn to ask you some questions. We were talking about when Mr. Epstein was in jail, which was between June 30th of 2008 and July of 2009; correct? A Yes. Q Now, during that time you weal. Lu work your regular sche
intiff, vs. CASE No. 502008CA0280513OOOCMB AB JEFFREY EPSTEIN, Defendant. DEPOSITION OF VOLUME H Oc
k you some questions. We were talking about when Mr. Epstein was in jail, which was between June 30th of 2008
8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 - Volume II October 20, 2009 WITNESS: 134 INDEX DIRECT CROSS REDIRECT RECROSS BY MR. EDWARDS: 5 190 BY MR. MERMELSTEIN: 135 208 BY MR. HILL: 156 BY MR. CRITTON: 173 EXHIBITS NUMBER DESCRIPTION PAGE DEPENDANT'S EX
Entities connected to both Jeffrey Epstein and RECROSS
Larry Visoski
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONJanusz Banasiak
PERSONJane Doe
PERSON
Jean-Luc Brunel
PERSON
New York
LOCATION
Palm Beach
LOCATIONScott Rothstein
PERSONRobert D. Critton
PERSON
West Palm Beach
LOCATION
West Palm
LOCATION
Columbus
LOCATION
Adriana Ross
PERSONJANE DOE NO
PERSONMermelstein
PERSONBanyan Boulevard
ORGANIZATION