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?

Counsel/or Plaintiffs In related Cases Nos. 08-80069, 08-80 II 9, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 3 3461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811

way - MR. REINHART: Do it at the end, after we get him - whatever you want. It's your show. MR. EDWARDS: Okay. There were --1 don't even think Mr. Willits is aware of this. There was a subpoena duces tecum for this witness, as well as the previous witness, which was another pilot, Dave Rogers, and th

n first duly sworn, was examined and testified as follows: DIRECT EXAMINATION BY MR. EDWARDS: O. Tell us your name. A. Larry Morrison. O. And, Larry, where are you employed right now? A. For JEGE. O. What's JEGE mean? A. It's the aviation flight department for Mr. Epstein, and my primary job i

24 racing - Indy car team and Red Roof Inns, the motel 25 chain. Then from there I went to The Limited stores. 64 1 A. Yeah. 2 O. So back to Larry Visoski - you don't know him 3 while you're employed with Wexner. 4 A. Yes. 5 O. You do? 6 A. Yeah. 7 O. How do you meet him? 8 A. Met him becau

have been Larry Visoski. I 19 knew Larry and Dave when they flew for Glimcher 20 Corporation. 21 0. Tell me a little bit about that. Larry 22 Visoski - how do you know him? 23 A. He's the Chief Pilot for Jeffrey and hired 24 me. 25 0. Well, he's the Chief Pilot now -- ESQUIRE .A““& AU“fl.,

#5 7 CROSS-EXAMINATION On betel d Planter Jane Doe 2 through s By Ms. Ezell *190 T mERUELSTE1N 6 HOROWITZ. PA 9 CROSS-EXAMINATION By Mr. Willits #195 10 BY: JESSICA D. ARBOUR. ATTORMEY.AT4AW. 11) 11 19205 Beware Boulevard Suite 2218 CROSS-EXAMINATION Men. 1-1. 33160 11 By Mr. Pike

hen's 52:9,25 53:1 94:23 98:16 124:22 White 95:22,25 96:3 Whoa 129:4,4 wife 17:13 189:7 wife's 17:14 Williams 39:15,16 willing 82:14 Willits 2:20,21 4:9 195:24,25 196:8 Wilmington 44:25 89:14 window 200:1 Winnebago 28:9 winning 170:23 wish 26:16 189:17 witness 3:13 4:3 5:8

TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50200BCA028051XXXXMB AD Plaintiff, JEFFREY EPSTEIN, Defendant. DEPOSITION OF LARRY VISOSKI Thursday, October 15, 2009 10:18 - 3:37 p.m. 515 N. Flagler Drive Suite P200 West Palm Beach, Florida 33401 Reported By: Wendy Beath Anderson, R

EFTA00159484 Larry Visoski October 15, 2009 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 WITNESS: LARRY VISOSKI BY MR. EDWARDS: BY MR. CRITTON: BY MR. EDWARDS: BY MR. CRITTON: I NDEX DIRECT CROSS 6 214 EXH IB ITS REDIRECT RECROSS 220 221

xamined and testified as follows: THE WITNESS: Yes, I do. DIRECT EXAMINATION BY MR. EDWARDS: Q. Can you tell us your name for the record. A. Lawrence Visoski, Jr. Q. And Mr. Visoski, have you ever had your deposition taken before? A. No. Q. Okay. Here's the process: I'm going to ask you questions.

THE WITNESS: Yes, I do. DIRECT EXAMINATION BY MR. EDWARDS: Q. Can you tell us your name for the record. A. Lawrence Visoski, Jr. Q. And Mr. Visoski, have you ever had your deposition taken before? A. No. Q. Okay. Here's the process: I'm going to ask you questions. You're going to give us a

way -- MR. REINHART: Do it at the end, after we get him -- whatever you want. It's your show MR. EDWARDS: Okay. There were don't even think Mr. Willits is aware of this. There was a subpoena duces tecum for this witness, as well as the previous witness, which was another pilot, Dave Rogers, and th

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

[email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected] Richard Horace Willits [email protected] Robert C. Josefsberg [email protected] Adam D. Horowitz [email protected] Stuart S. Mermelstei

N INVESTIGATION TIMELINE Date To From Re: Exhibit # 11/13/2006 Subpoena to Bill Hammond (pilot) (return date 12/1/06) 11/13/2006 Subpoena to Larry Visoski (pilot)(retum date 12/1/06) 11/13/2006 Subpoena to Janusz Banasiak (property manager)(return date 12/1/06) 11/13/2006 Subpoena to Adriana Mucinsk

turn date 12/1/06) 11/13/2006 Subpoena to Larry Visoski (pilot)(retum date 12/1/06) 11/13/2006 Subpoena

Kuyrkendall, Richards Sloman Email regarding proposed response to Goldberger R - 7/10/2008 Victim Notification letters to Individuals #3 (via Richard H. Willits), #8 (via Jeffrey Herman), ##17 (via Theodore J. Leopold), #25 (via Jeffrey Herman), #26 (via Jeffrey Herman), #37 (via Michael E. Dutko), and #44

sta and instructions to direct question to Marie Villafafia and Karen Atkinson 4/8/2008 Sigal Mandelker Starr Letter - 4 pages (CEOS) 4/9/2008 Willits Villafafia Letter in response to 3/28/08 letter from Willits B • 12 4/21/2008 4/21/2008-5/9/2008 Emails between Marie Villafatia, Jeff Sloman, K

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

RCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE COURT: Good morning. 13 MR. WILLITS: Good morning, Your Honor. Richard 14 Willits, here on behalf of the plaintifflila. 15 THE COURT: Good morning. 16 MS. EZELL: Good morning, Your Honor. I'm Katherine 17 Ezell from Podhurst O

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

bcIclaw.com 7 EFTA00222395 Case 9:08-cv-80119-KAM Document 357 Entered on FLSD Docket 10/16/2009 Page 8 of 8 CASE NO: 08-CV-80119-MARRA/JOHNSON Richard Horace Willits lawyerswillits@aolcom Robert C. Josefsberg [email protected] Adam D. Horowitz [email protected] Stuart S. Mermelstein ssm@

Motion Terminate Depo 10/13/2009 150 Rntd Re-Notice of Taking Deposition David Hart Rogers 10/13/2009 151 Rntd Re-Notice of Taking Deposition Larry Visoski 10/13/2009 152 Noh Notice of Hearing None 10/13/2009 153 Mot Motion For Protective Order 10/14/2009 154 Nof Notice of Filing None 10/15/2009

9 151 Rntd Re-Notice of Taking Deposition Larry Visoski 10/13/2009 152 Noh Notice of Hearing None 10/

/2009 Status Date: 04/20/2009 Back to Too Participants Litigant Cma, Plaintiff Epstein, Jeffrey Defendant Kellen. Sarah Defendant Attorney Willits. Richard H 2290 10th Ave N Suite 404 Lake Worth FL 33461 Back to Top Additional Counsel No Information is Available for this case Back to Too

N INVESTIGATION TIMELINE Date To From Re: Exhibit # 11/13/2006 Subpoena to Bill Hammond (pilot) (return date 12/1/06) 11/13/2006 Subpoena to Larry Visoski (pilot)(return date 12/1/06) 11/13/2006 Subpoena to Janusz Banasiak (property manager)(retum date 12/1/06) 11/13/2006 Subpoena to Adriana Mucinsk

turn date 12/1/06) 11/13/2006 Subpoena to Larry Visoski (pilot)(return date 12/1/06) 11/13/2006 Subpoen

ie Villafaila regarding victim representation and filing suit against Epstein in state court 13-42 4/9/2008 Mai is Villafana letter to Richard II. Willits (formatting problem) 13-43 6/18/2008 Marie Villalana handwritten notes re calls with Brad Ed wards and Roy Black B-44 6/23/2008 John Roth letter