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?

332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected]. utah. ed u Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm) P.A. 224 Datum Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Couns

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

e 8 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Coun

n. 40. List of properties and vehicles in Larry Visoski's name. This is so overbroad that Epstein cannot

y make a determination as to whether or not he seeks to exclude anything under this exhibit identification. 40. List of properties and vehicles in Larry Visoski's name. This is so overbroad that Epstein cannot possibly make a determination as to whether or not he seeks to exclude anything under this exhibit i

f the Federal Bureau of Investigations 16. Spencer Kuvin, Esquire 17. Theodore Leopold, Esquire 18. Rinaldo Rizzo 19. Adam Horowitz, Esquire 20. Isidro M. Garcia, Esquire 21. All of the Lawyers who Represented Victims of Jeffrey Epstein. This is so overbroad that Epstein cannot possibly make a determination

Subject to the assertions of privilege 77. La Visoski RIVIERA It! ACH, FL 33401 78. 79' C/O ATTORNE

ll also confirm the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. 23 Isidro M. Garcia, Esquire Garcia Law Firm, P.A. 224 Datum Street, Suite 900 West Palm Beach, FL, 33401 2-3 Expected to testify about the malicious prosecution ele