Epstein Secrets

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?

enzo, court reporter 2 APPEARANCES OF COUNSEL On behalf of the Plalnliff L.M.: ROTI-lSTEtN, ROSENFELDT & ADLER BY: BRADLEY J, EDWARDS, ESQ. and MICHAEL WHEELER, ESQ., 401 East Las Olas Boulevard Suite 1650 Fort Laudordale, FL 33394 954-522•3456 [email protected] [email protected] On bohalf of Pl

pencer Kuvin Bradley Edwards RE:Meeting w.Stanely Arkin Joint W/P Priv. 11585-11586 10/14/2009 Adam Horowitz Bradley Edwards RE:Epstein;Larry Visoski confirmed Joint W/P Priv. 11675-11676 10/29/2009 Stuart Mermelstein Bradley Edwards RE:Leslie Wexner attorney info Joint W/P Priv. 3 EFTA00

/14/2009 Jacquie Johnson Adam Horowitz Depo of Larry Visoski Joint W/P Priv. 04640-04641 10/14/2009 Bradley

levant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01296 10/02/2009 Mike Fisten Michael Wheeler Subpoena of Detective Recarey W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evi

pencer Kuvin Bradley Edwards RE:Meeting w.Stanely Arkin Joint W/P Priv. 11585.11586 10/14/2009 Adam Horowitz Bradley Edwards RE:Epstein;Larry Visoski confirmed Joint W/P Priv. 11675-11676 10/29/2009 Stuart Mermelstein Bradley Edwards RE:Leslie Wexner attorney info Joint W/P Priv. 3 EFTA00

/14/2009 Jacquie Johnson Adam Horowitz Depo of Larry Visoski Joint W/P Priv. 04640-04641 10/14/2009 Bradley

levant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01296 10/02/2009 Mike Fisten Michael Wheeler Subpoena of Detective Recarey W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evi