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

aw.com 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] Richard Horace Willits [email protected] Robert C. Josefsberg rjosefsberg@po

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?

ite 400 West Palm Be , FL 33401 (561) 842- (561) 84 By: __;,,_,___,~:1---___:...p_ .. '1-:-q_}-__ R e . Critton, Jr. ~( F orida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) Case 9:08-cv-80119-KAM Document 402 Entered on FLSD Docket 11/09/2009 Page 17

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.,

No. 5020006020051 On behalf of the Defendant by telephone: IX/WM AD JRFPRRY DITHER. e BURMAN. CRITTON. LUTTIER & COLEMAN Defendant . I 9 BY: MICHAEL J. PIKE. ESO.. 515 N. Fla or Drtve DEPOSITION OF 10 Suito 400 lm ad,. FL 33401 LARRY MAUNA NORAISON 11 TAKEN On SHALT OF INA PLAINTIFF October 4. 20

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

aw.com 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] Case 9:08-cv-80119-KAM Document 357 Entered on FLSD Docket 10/16/2009 Page 7 of 8

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

Y EPSTEIN, respectfully requests the Court deny Jane Doe's Motion (DE #486) and grant any additional relief the Court deems just and proper. By: s/Michael J. Pike ROBERT D. CRITTON, JR., ESQ. Florida Bar #224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERTIFY that a true

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

[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 EFTA00222395 Case 9:08-cv-80119-KAM Document 357 Entered on FLSD Docket 10/16/2009 Pa

derage minor female despite the age? 18 MR. YAREMA: Object to the form. 18 MR. YAREMA: Object to the fonn. 19 A Fifth. 19 A Filth. 20 Q Mr. Visoski testified that you took a 20 Q What is the youngest female you have 21 helicopter flight within the last year with 21 witnessed or observed Jef

NG, EDWARDS, FISTOS & LEHRMAN BY: BRADLEY EDWARDS, ESQ. ON BEHALF OF THE DEFENDANT JEFFREY EPSTEIN: BURMAN, CRITTON, LUTTIER & COLEMAN, LLP BY: MICHAEL J. PIKE, ESQ. ON BEHALF OF OTHER PLAINTIFFS IN RELATED CASES: MERMELSTEIN & HOROWITZ, P.A. 305.931.2200 [email protected] BY: STUART S. MERMELSTE

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

xample, I was given reason to believe that Larry Visoski, Larry Harrison, David Rogers, Louella Rabuyo, ME

Plaintiff's position is that the parties have already complied with the mediation requirements. By: s/Robert D. Critton, Jr. Robert D, Critton, Jr. Michael J. Pike Attorneys for Defendant Epstein HOUSE_OVERSIGHT_013478 --- PAGE BREAK --- Case 9:08-cv-80893-KAM Document 168 Entered on FLSD Docket 06/28/2010 Pa