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

Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Isidro Manual Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected]

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?

Lake Worth, FL 3 3461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424

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

Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Isidro Manual Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected]

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

Jack Alan Goldberger, Esq. Jaoldberaeraaawna.com Robert D. Critton, Esq. [email protected] Isidro Manual Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected] 7 EF

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

depos Joint-privilege 06706-06708 10/14/2009 Bradley J. Edwards Kikka M. Claudio Igor Zinoview depo Joint-privilege 06715-06719 10/09/2009 Jack P. Hill Bradley J. Edwards Igor Zinoview depo Joint-privilege 06729-06735 10/13/2009 Bradley J. Edwards Jack P. Hill Igor Zinoview depo Joint-privi

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

depos Joint-privilege 06706-06708 10/14/2009 Bradley J. Edwards Kikka M. Claudio Igor Zinoview depo Joint-privilege 06715-06719 10/09/2009 Jack P. Hill Bradley J. Edwards Igor Zinoview depo Joint-privilege 06729-06735 10/13/2009 Bradley J. Edwards Jack P. Hill Igor Zinoview depo Joint-privi