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know who all is still there 4 because retail is down. 5 O. Was Larry Visoski a pilot used by MI 6 Wexner at any time? 7 A. No. O. How about David Rodgers? 9 A. No. 10 O. Are those names you're familiar with? 11 A. Yes. 12 O. Those we names you're familiar with how? 13 A. I flew with them when
h, that previous corporation sold the 6 airplane. 7 O. Oh, they did? A. Yeah. He had no choice. They were out of 9 work. 10 O. So Larry and David were about to be out of 11 work. 12 A. Yes. 13 O. So they said, "Hey, we found a new job and 14 it's with this guy Jeffrey Epstein and he's b
and he brought • this is all speculation • and, 16 I think, he brought Larry on board. 17 O. So as far as you know, however you know, David 18 Rodgers was the first Epstein contact and then Larry 19 Visoski rode it in. 20 A. The way I understand. yeah. 21 O. How did you become Involved in the
#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
en 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 that duces tecum was to bring the flight logs related from 1998 through 2005. What was produced at the previous deposition were flight logs f
spread to the press or anyone else, because they do contain confidential information as to who may have been on the plane and other records of Mr. Rogers, which but for the subpoena would have been only available to the FAA or some other law enforcement agencies. MR. EDWARDS: Okay. Is that all you
Yes. Q. And the years provided in this book are 2002 through 2005; I can represent that to you. I'm going to ask you about certain people that David Rogers wrote down as being on the airplane and I want to ask you if 3527-003 Page 73 of 227 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and
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
nk 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 that duces teoum was to bring the flight logs related from 1998 through 2005. What was produced at the previous deposition were flight logs f
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
ate 8/18/06) 8/2/2006 Subpoena to David Neville Rodgers (return date 8/18/06) 8/2/2006 Subpoena to DTG
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
'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 representation of
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
in discussing how a court is to analyze the application of the privilege stated — ... It is for the court to say whether his silence is justified, Rogers v. United States, 1951, 340 U.S. 367, 71 S.Ct. 438, and to require him to answer if 'it clearly appears to the court that he is mistaken.' Temple v
a;KW M g 24 C.M.A. v. Epstein, et al. Page 15 day on all counsel of record identified on the following CM/ECF on this 24th day of March , 2009 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 Counsel for Plaintiff C.MA. Jack Scarola, Esq. Jack P. Hi
ate 8/18/06) 8/2/2006 Subpoena to David Neville Rodgers (return date 8/18/06) 8/2/2006 Subpoena to DTG
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
Entities connected to both David Rodgers and Richard Horace Willits

Jeffrey Epstein
PERSONLarry Visoski
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Paul Cassell
PERSONJane Doe
PERSONJack Patrick Hill
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Lesley Groff
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSONIsidro Manuel Garcia
PERSONRobert D. Critton
PERSONDarren Indyke
PERSONKatherine W. Ezell
PERSONRobert C. Josefsberg
PERSON
FedEx
ORGANIZATIONLeon Black
PERSONJack Scarola
PERSON