Epstein Secrets

TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50200BCA028051XXXXMB AD Plaintiff, JEFFREY EPSTEIN, Defendant. DEPOSITION OF LARRY VISOSKI Thursday, October 15, 2009 10:18 - 3:37 p.m. 515 N. Flagler Drive Suite P200 West Palm Beach, Florida 33401 Reported By: Wendy Beath Anderson, R

EFTA00159484 Larry Visoski October 15, 2009 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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

xamined and testified as follows: THE WITNESS: Yes, I do. DIRECT EXAMINATION BY MR. EDWARDS: Q. Can you tell us your name for the record. A. Lawrence Visoski, Jr. Q. And Mr. Visoski, have you ever had your deposition taken before? A. No. Q. Okay. Here's the process: I'm going to ask you questions.

THE WITNESS: Yes, I do. DIRECT EXAMINATION BY MR. EDWARDS: Q. Can you tell us your name for the record. A. Lawrence Visoski, Jr. Q. And Mr. Visoski, have you ever had your deposition taken before? A. No. Q. Okay. Here's the process: I'm going to ask you questions. You're going to give us a

an Avenue Suite 1400 West Palm Beach, Florida 33401 ALSO PRESENT: CARA L. HOLMES, ESQUIRE 1220 N.W. 157th Avenue Pembroke Pines, Florida 33028 ADAM D. HOROWITZ, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 RICHARD H. WILLITS, ESQUIRE (VIA TELEPHONE) RICH

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

w.com Paul G. Cassell [email protected] Richard 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-

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?

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 Biscayne Boulevard Suite 1650 Suite 2218 Fort

ented (Epst4in's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed but the others were.) Our understanding is that his repr

knowing 26:25 38:5 knowledge 5:13 13:11 known 21:4 32:14 knows 11:3 13:2 L lack 41:22 ladies 20:23 21:3,20 Lake 124 language 18:14 32:11 LARRY 2:21 44:21 Las 1:17 last 33:22 41:24 Lauderdale 1:18 2:16 law 7:1 27:24 28:9 lawsuit 25:18,19 lawsuits 30:17 lawyers 821 9:4,7 10:23,23 17:2

Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxbur

1 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, 12 UNITED STATES DISTRICT JUDGE APPEARANCES: 13 14 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 15 18205 Biscayne Boulevard Miami, FL 33160 305.931.2200 16 For Jane Doe 17 BRADLEY J. EDWARDS, ESQ. Rothstein

ented (Epstein's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed but the others were.) Our understanding is that his repr

. 17 MARTIN G. WEINBERG, ESQ. 18 20 Park Plaza Boston MA 02116 19 (Via telephone) 20 JAY LEFKOWITZ, ESQ. (via telephone) 21 REPORTED BY: LARRY HERB RPR-RMR-FCRR-AE 22 Official United States Court Reporter Federally Certified Realtime Reporter 23 400 North Miami Avenue, Room 8N09 Miami

Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxbur

1 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, 12 UNITED STATES DISTRICT JUDGE APPEARANCES: 13 14 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 15 18205 Biscayne Boulevard Miami, FL 33160 16 For Jane Doe 17 BRADLEY J. EDWARDS, ESQ. Rothstein Rosenfeldt Ad

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

CASE NO: 08-CV-80119-MARRA/JOHNSON 8 Richard 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-

ed in this and related cases and there has been numerous "fishing" expeditions. For example, counsel for Jane Doe deposed Larry Eugene Morrison and Larry Visoski, Epstein's pilots, for a combined total of approximately 8 hours without asking any questions related to his client. Instead the questions sought

Jane Doe deposed Larry Eugene Morrison and Larry Visoski, Epstein's pilots, for a combined total of approx

03/29/2010 Page 8 of 8 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ssm(al,sexabuseattorney.

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

/2009 Page 8 of 8 CASE NO: 08-CV-80119-MARRA/JOHNSON 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

form. A Fifth. Q Has Jeffrey Epstein instructed you to lie to his Probation Officer in any way? MR. YAREMA: Object to the form. A Fifth. Q Mr. Visoskl testified that you took a helicopter flight within the last year with Jeffrey Epstein to Miami. Do you remember that flight? MR. YAREMA: Object t

neys for Plaintiffs Jane Does, numbers 2 through 8 23 18205 Biscayne Boulevard Suite 2218 24 Miami, Florida 33160 Tel: (305) 931-2200 25 BY: ADAM D. HOROWITZ, ESQ. 16 17 18 19 20 21 22 23 24 25 5 1 THEREUPON, 2 3 being by Terri Becker lint duly sworn to tell 4 the whole truth, as hereinaf

derage minor female despite the age? 18 MR. YAREMA: Object to the form. 18 MR. YAREMA: Object to the fonn. 19 A Fifth. 19 A Filth. 20 Q Mr. Visoski testified that you took a 20 Q What is the youngest female you have 21 helicopter flight within the last year with 21 witnessed or observed Jef

S & LEHRMAN P L ■ EXHIBIT DESCRIPTION PAGE PLAINTIFF'S EX. 1 PHOTO 16 0 On behal of Jane s I through t 1 ) PLAINTIFF'S EX. 2 JEGE, INC., 24 ADAM D. HOROWITZ. ESQUIRE PASSENGER MANIFEST W1TZ. P A 16 PLAINTIFFS EX. 3 HYPERION AIR, INC., 15 PASSENGER MANIFEST ■ PLAINTIFF'S EX. 6 PHOTO 63 I PLAINTI