Epstein Secrets

RPORATED SUPPORTING MEMORANDUM Plaintiff, Jane Doe, hereby moves for leave to provide to the Court the recently- obtained deposition testimony of Larry Visoski (Exhibit A) and related affidavit of forensic accountant Ronald E. Wise (Exhibit B) in support of her pending Motion for Appointment of a Receiver

rge of Property of Epstein [DE 165]. These materials demonstrate that Epstein is engaging in fraudulent transfers, by hiding assets in the name of Visoski (his personal pilot). Because these materials are highly relevant to Jane Doe’s pending motion, the Court should grant Jane Doe leave to provide th

/2009 Page 2 of 7 CASE NO: 08-CV-80119-MARRA/JOHNSON 3 5. On October 15, 2009, Jane Doe’s counsel took the deposition of Larry Visoski, Epstein’s personal pilot. See Ex. A to this Motion. In the deposition, Visoski admitted many facts relevant to the fraudulent transfer iss

chard Horace Willits [email protected] Robert C. Josefsberg [email protected] Adam D. Horowitz [email protected] Stuart S. Mermelstein [email protected] William J. Berger [email protected] Case 9:08-cv-80119-KAM Document 386 Entered on FLSD Docket 10/30/2009

e to discuss it with my wife long and hard. I don't think I could give you a correct and honest answer at this time. See Excerpts of Deposition of Larry Visokski at 66-67; 181-82 (attached as composite Exhibit A). Other examples of similar improper questions are included in Exhibit A. 4. Not only do these

or example, in the deposition of Larry Visoski, one of Mr. Epstein's pilots, Plaintiff's counsel asked the following questions seeking to obtain Mr. Visoski's beliefs and opinions on Plaintiff's allegations: Q. All right. When you read in the newspapers the allegations that Mr. Epstein was involved

airplanes and stuff like that, so. Q. You're on his payroll? A. Salaried, yes. Q. Do you know who else ls on his payroll? A. Well, Dave and Larry. Q. Certainly, If I want to know more about his private life .. do you know who's at his house? A. No. 0. Po you know who his housekeeper Is?

402 Entered on FLSD Docket 11/09/2009 Page 4 of 26 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. 401 East Las Olas Boulevard 18205 Bisca

g her arguments regarding Epstein’s fraudulent concealment of his assets. Yesterday (October 15, 2009) counsel for Jane Doe took the deposition of Larry Visoski, who has been Jeffrey Epstein’s personal pilot for approximately 18 years, flying (for example) Epstein’s Boeing 727 jet. Visoski declared that, i

position of Larry Visoski, who has been Jeffrey Epstein’s personal pilot for approximately 18 years, flying (for example) Epstein’s Boeing 727 jet. Visoski declared that, in the last year, Epstein has transferred to him four very valuable cars and a boat and registered them in his (Visoski’s) name. A

chard Horace Willits [email protected] Robert C. Josefsberg [email protected] Adam D. Horowitz [email protected] Stuart S. Mermelstein [email protected] William J. Berger [email protected] Case 9:08-cv-80119-KAM Document 357 Entered on FLSD Docket 10/16/2009

ng her arguments regarding Epstein's fraudulent concealment of his assets. Yesterday (October 15, 2009) counsel for Jane Doe took the deposition of Larry Visoski, who has been Jeffrey Epstein's personal pilot for approximately 18 years, flying (for example) Epstein's Boeing 727 jet. Visoski declared that, in

eposition of Larry Visoski, who has been Jeffrey Epstein's personal pilot for approximately 18 years, flying (for example) Epstein's Boeing 727 jet. Visoski declared that, in the last year, Epstein has transferred to him four very valuable cars and a boat and registered them in his (Visoski's) name. A t

SON Richard Horace Willits lawyerswillits@aolcom Robert C. Josefsberg [email protected] Adam D. Horowitz [email protected] Stuart S. Mermelstein [email protected] William J. Berger [email protected] 8 EFTA00222396