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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?
904-680-1238 Fax Co-counsel for Plaintiff West Palm Beach, FL 33401-5012 Fax: 561-835-8691 ~ Co-Counsel for Defendant Jeffrey Epstein BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Blvd., Suite 400 West Palm Be , FL 33401 (561) 842- (561) 84 By: __;,,_,___,~:1---___:...p_ .. '1-:-q_}-__ R e . Critton, Jr. ~(
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
Pike ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 303 Banyan Blvd., Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/253-0164 Fax (Counsel/or Defendant Jeffrey Epstein) 7 Case 9:08
. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Palm Beach,
behalf of the Plaintiff: ROBERT D. CRITTON, JR., ESQUIRE BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Palm Beach, F
or by Epstein were all taking the Fifth (like Epstein) rather than provide information in discovery. For example, I was given reason to believe that Larry Visoski, Larry Harrison, David Rogers, Louella Rabuyo, ME, Ghislaine Maxwell, Mark Epstein, and Janusz Banasiak all had lawyers paid for by Epstein. Because
Page: HOUSE_OVERSIGHT_013469 →xample, I was given reason to believe that Larry Visoski, Larry Harrison, David Rogers, Louella Rabuyo, ME
Page: HOUSE_OVERSIGHT_013469 →Entities connected to both Larry Visoski and Burman Critton Luttier & Coleman LLP

Jeffrey Epstein
PERSON
David Rodgers
PERSON
Ghislaine Maxwell
PERSON
FedEx
ORGANIZATION
Sarah Kellen
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSONJack Goldberger
PERSON
Donald Trump
PERSON
Alfredo Rodriguez
PERSON
Alan Dershowitz
PERSON
Zorro
LOCATION
Palm Beach
LOCATIONNadia Marcinkova
PERSONJane Doe
PERSONMaria Farmer
PERSON
United States
LOCATION
Juan Alessi
PERSON