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?

Palm Beach, Florida 33401 ALSO PRESENT: CARA L. HOLMES, ESQUIRE 1220 N.W. 157th Avenue Pembroke Pines, Florida 33026 ADAM D. HOROWITZ, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 1 B205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 RICHARD H. WILLITS, ESQUIRE (VIA TELEPHONE) RICHARD H. WILLITS, P.A. 2290 10\h

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

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 Rosenfeldt Adler 18 401 Eas

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

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 Adler 18 401 East Las Olas Bou

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

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.com ahorowitz@sexabuseattorne