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

ert 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 Page 7 of 7

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

ert 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 Page 8 of 8

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

m Robert C. Josefsberg [email protected] Adam D. Horowitz [email protected] Stuart S. Mermelstein [email protected] William J. Berger [email protected] 8 EFTA00222396

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

m Horowitz Bradley J. Edwards Epstein Matter — Cross Notice of Alfredo Rodriguez Deposition Joint-privilege 02209-02210 07/01/2009 Bert Patton William J. Berger Epstein v. State of Florida — Emergency petition for Writ of Certiorari; Emergency motion to review denial of stay Joint-privilege 02215-02217

y calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02971 10/14/2009 Jacquie Johnson Bradley Edwards Larry Visoski depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr

4 EFTA00310171 Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Visoski depo irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07595-07604 05/20

ot reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01930 09/05/2009 Bradley J. Edwards William J. Berger Client info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide

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

m Horowitz Bradley J. Edwards Epstein Matter — Cross Notice of Alfredo Rodriguez Deposition Joint-privilege 02209-02210 07/01/2009 Bert Patton William J. Berger Epstein v. State of Florida — Emergency petition for Writ of Certiorari; Emergency motion to review denial of stay Joint-privilege 02215-02217

y calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02971 10/14/2009 Jacquie Johnson Bradley Edwards Larry Visoski depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr

24 EFTA00602958 Privilege Log— Dated 2-23-2011 Farmer, Jaffe, Weissine. Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Visoski depo irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07595-07604 05/20

ot reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01930 09/05/2009 Bradley J. Edwards William J. Berger Client info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide

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

dence, Incorporated. Would the attorneys please announce their appearances for the record. MR. WILLITS: Richard Willits, representing MR. BERGER: William J. Berger, representing M., M. and Jane Doc number two. MR. MERMELSTEIN: Stuart Mennetstein of Mermelstein and Horowitz. representing Jane Does numbers two