EFTA00181380

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L.M., 
Condensed Transcript 
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN 
AND FOR PALM BEACH COUNTY, FLORIDA 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
Case No. 502008CA028051 
XXXXMB AD 
DEPOSITION OF 
LARRY EUGENE MORRISON 
TAKEN ON BEHALF OF THE PLAINTIFF 
VOLUME I 
Pages 1 to 200 
October 6, 2009 
10:55 a.m. 
515 N. Flagler Drive 
West Palm Beach, FL 33401-4321 
court reporter 
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EFTA00181380

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EFTA00181381

Larry Eugene Morrison - Volume I 
October 6, 2009 
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1 
IN /NS CIRCUIT COURT Of TAR 15Th JUDICIAL CIRCUIT IN 
AND PM PAIN BRACH COUNTY. FLORIDA 
VOLONE I 
Pages 1 to 200 
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3 
3 
APPEARANCE OF COUNSEL 
On behalf of the Defendant 
ATTEFOURY. GOLDBERGER A WEISS 
BY: JACK ALAN GOLDBERGER. ESO.. 
4 
250 Australian Avenue 
Suite 1400 
5 
act. FL 33401 
Plaintiff. 
I 
6 
/Case 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. 2009 
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10/59 a.m. - 2/20 p.m. 
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On behalf of the witness: 
515 X. ?kegler Drive 
Nest Palm Beach, FL 13401.4121 
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LAW OFFICE OF BRUCE E. REINHART 
15 
BY: BRUCE E. REINHART. ESO.. 
One Clearleke Cantor 
16 
250 S. Australian Avenue 
Suite 1400 
court reporter 
17 
&ch. FL 33401 
16 
19 
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21 
22 
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25 
2 
4 
1 
APPEARANCES OF COUNSEL 
1 
INDEX OF EXAMINATION 
e 
I 
On banal a the Flambe L.M.. 
ROTHSTEIN. 110SENFELDT a ADLER 
2 
BY: BRADLEY J. EDWARDS. ESO. 
3 
WITNESS: 
4 
111X1MICHAEL WHEELER. ESO.. 
4 
LARRY EUGENE MORRISON 
401 East Las OHS 130.40Velt1 
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Page 
S41[91650 
ran Lo, 
ie. FL 31394 
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DIRECT EXAMINATION 
By Mr. Edwards 
#5 
7 
CROSS-EXAMINATION 
On betel d Planter Jane Doe 2 through 
s 
By Ms. Ezell 
*190 
T 
mERUELSTE1N 6 HOROWITZ. PA 
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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 
N196 
12 
12 
FURTHER REDIRECT EXAMINATION 
By Mr. Edwards 
#199 
li 
On Denali of mantes Jane Doe 101 aro 102 by 
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telephone: 
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15 
PODHURST ORSECK PA 
15 
16 
BY: KATHERINE W. EZELL. ATTORNEY.ATiLAW. 
25 W. Ragier Street 
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INDEX TO EXHIBITS 
17 
17 
Plaintiffs 
IS 
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Exhibit Desolation 
Page 
On banal of me Plartlf C.MA by telapheac 
19 
1 
Twenty-four pages of 'JEGE. Inc.. 
20 
Passenger Manifest.' 
*138 
LAW OFFICE OF RICHARD WILLITS. PA 
20 
St 
BY: RICHARD WILLITS. ESO.. 
21 
2290101h Avenue N. 
21 
Suite 404 
22 
Laks Worm 
33481 
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21 
25 
24 
(Plaintiffs Composite 1 was attached to the 
original transcript and copies of the transcript.) 
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EFTA00181382

Larry Eugene Morrison - Volume I 
October 6, 2009 
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Deposition of LARRY EUGENE MORRISON 
October 6. 2009 
THE REPORTER: Do you swear the testimony 
you're about to give will be the truth, the 
whale truth. and nothing but the truth so help 
you God? 
THE WITNESS: So help me God. 
-------
LARRY EUGENE MORRISON, having been 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 is Dankjold Reed 
Aviation. 
MR. REINHART: Spell it. 
A. D-A-N-K-J-O-L-D, and then the second word 
is Reed, R-E-E-D. Aviation. Its a corporate flight 
7 
1 
You know. it was a business decision made somewhere. 
2 
O. What does the company do? 
3 
A. What? The company? It's just a holding 
4 
company, I think, for the aircraft. It's not -- I 
5 
don't believe it to be a money making company or a 
6 
real corporation. 
7 
O. 
You're saying 'tor the aircraft* I'm 
8 
interpreting that to mean you're talking about one 
9 
aircraft. 
10 
A. Correct. 
11 
O. Does that mean there's one or there's more 
12 
than one? 
13 
A. There's more. He owns more than one, but 
14 
justoneis JEGE Of --
15 
O. And the aircraft that he owns, how many of 
16 
those do you either service and/or ride on? 
17 
A. I used to. I haven't been — Actually, I 
18 
stepped back from being physically involved, just • 
19 
now I just do paperwork • and it was February of 
20 
2007. So I haven't actually physically been on the 
21 
airplanes other than I will take the Boeing for 
22 
maintenance. 
23 
O. Since it seems like we've kind of skipped 
24 
ahead from 2001 to 2007, am I right that your first 
25 
involvement with Jeffrey Epstein of any way, shape, or 
6 
1 
department. 
2 
O. What do you do for him? 
3 
A. Director of Maintenance. 
4 
O. Okay, so you maintain his planes --
5 
A. Correct. 
6 
O. 
should something go wrong? 
7 
A. Correct. Yes. Yep. 
8 
O. Do you also —
9
A. For maintenance. 
10 
O. Do you also fly on his planes? 
11 
A. On Mr. Epstein's? 
12 
O. Yes. 
13 
A. I used to. I was a flight engineer --
14 
O. Okay. What --
15 
A. -- on his 727. 
16 
O. When you list your company - JEGE? 
1? 
A. Yes. Yeah, ifs just initials. It's an 
18 
LLC or holding company. 
19 
O. How long has that holding company been around, 
20 
if you know? 
21 
A. Since — I think it was developed when I 
22 
came with the airplane • 2001. 
23 
O. Whose idea was it for that to come about • was 
24 
it yours? Was it his? 
25 
A. Oh, no. no, somewhere -- It wasn't mine. 
8 
1 
form was 2001? 
2 
A. 
That's correct, yeah. 
3 
O. 
You didn't meet him before that. 
4 
A. I had met him. He was a -- He was an 
5 
associate of my previous boss. 
6 
O. 
Who's that? 
7 
A. Mr. Wexner. 
8 
O. -Wexner? 
9 
A. 
Yes. 
10 
O. How do you know 
Wexner? 
11 
A. I worked for Limited Stores for 12 years. 
12 
O. Doing what? 
13 
A. Essentially the same thing - aircraft 
14 
maintenance for their corporate flight department and 
15 
flight engineering on the 727. 
16 
O. How many aircraft did 
Wexner have? 
17 
A. 
Well, none that I know that he had 
18 
personally, but the corporation had - the flight 
19 
department operated - we had three Gulfstreams, two 
20 
Hawkers, and a 727. 
21 
O. What was the name Of his Corporation that 
22 
maintained the aircraft? 
23 
A. 
For Limited Stores? 
24 
O. 
Yes. 
25 
A. 
It was just -- It was called Limited - 
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EFTA00181383

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Larry Eugene Morrison - Volume I 
October 6, 2009 
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Limited Flight Department. 
2 
O. And do you know him personally then --
3 
Wexner? 
4 
A. Yeah, I had met him, of course, you know. 
5 
I met him. I used to do aircraft completions for 
6 
him, so which would involve personal meetings. 
7 
O. When did you first meet 
Wexner? 
8 
A. 1988 was when I hired on, so I don't 
9 
remember the month. 
10 
O. How did you get that job? 
11 
A. Through word of mouth and, you know. I 
12 
worked - I lived in - been in aviation for years in 
13 
Columbus. 
14 
O. Well, I mean, I= 
Wexner's an important 
15 
person, right? I mean, he --
16 
A. Correct 
17 
MR. GOLDBERGER: Form. 
18 
BY MR. EDWARDS: 
19 
O. He's somebody who owns - my understanding -
20 
Limited, Victoria's Secret? 
21 
A. 
Well, he doesn't own them. He's Chairman. 
22 
you know. 
23 
O. Chairman of --
24 
A. Yeah. He doesn't personalty own it. It's 
25 
a publicly held company. 
11 
1 
O. Yes. 
2 
A. Aircraft technician. 
3 
O. Which entails what? 
4 
A. Maintenance of any or all of the aircraft 
5 
operated by the flight department and some flight 
6 
mechanic duties. 
7 
O. What kind of airplanes? 
8 
A. Gulf streams, Hawkers. 
9 
O. How big is the Gulfstream? 
to 
A. Fifteen passenger - 15 to 17. 
11 
(Mr. Goldberger exited.) 
12 
BY MR. EDWARDS: 
13 
O. What did Wexner use the Gulfstream for? 
la 
A. They were division airplanes. mostly. 
15 
O. And the other airplane you named - what did he 
16 
use that for? 
17 
A. Same, same. 
18 
O. Any idea why he had two planes? 
19 
A. Well, I mean, yeah, we used them - they're 
20 
a tool. It wasn't him. It was a large Fortune 500 
21 
company. They use them as tools to -- You know, 
22 
Limited has control over 60 percent of their 
23 
manufacturing processes. plus, you know, what, 1200 
24 
stores, or whatever, throughout all their divisions. 
25 
I mean, when you say "Limited,* it's not 
10 
1 
O. Where were you prior to any involvement with 
2 
MI 
Wexner? 
3 
A. I worked for Red Roof Inn True Sports 
4 
Flight Department. 
5 
O. How did that position lead you to 
6 
Wexner? 
7 
A. 
Well, it was always known that Limited 
8 
Flight Department was one of the best jobs in 
9 
Columbus and, actually, several other people that 
10 
were already there knew me from previous jobs and 
11 
education - we went through aircraft mechanic, or A&P 
12 
school, together - so when the position became 
13 
available they pointed to me and - absolutely. It 
14 
was a line organization. 
15 
O. So did Mr. Wexner approach you or did you 
16 
apply to him or how did that work? 
17 
A. Oh, no, no, no. It's -- No. He wouldn't 
18 
be involved in that type of activity. You apply to 
19 
H.R. and you interview with the Director of 
20 
Operations or the Chief Pilot. You know, he 
21 
wouldn't. 
22 
O. So you start with Wexner in 1988. 
23 
A. 
Yes. 
24 
O. 
What do you do for him then? 
25 
A. What did I do for him? 
12 
1 
just Limited, d's Victoria's Secret and it was 
2 
Express and Lemers and Henri Benders and all of 
3 
that back then, so, I mean --
4 
O.
50 —
A. -- we moved a lot of passengers to keep 
6 
those stores for the retail business. 
7 
O. And by *passengers.' do you also mean clients 
8 
of his? 
9 
A. That I don't know. No. Mostly we just 
10 
dealt with upper echelon, you know, people in the 
11 
retail businesses from --
12 
O. Such as whom? 
13 
(Mr. Goldberger entered.) 
14 
A. Can't even remember names, but it would be 
is 
-- We would take buyers to Europe in the spring and 
16 
fall. They would buy samples and bring them back to 
17 
analyze for marketing. We would hire -- We would -
18 
Division heads, when they would do store shops and, 
19 
Real Estate, we take Real Estate out when they were 
20 
looking for new real estate. 
21 
O. While you were working back in '88 -- Well, 
22 
how long overall did you work with 
Wexner and/or 
23 
his companies? 
24 
A. 
Well, '88 through when I camp hero in 
25 
January of '01. 
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Larry Eugene Morrison - Volume I 
October 6, 2009 
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1 
O. 
Why the change? 
2 
A. It offered an opportunity -- Well, one was 
3 
I enjoyed flying • and the 727 was being replaced by 
4 
a BBJ, which is a two•man airplane, not a three-man 
5 
airplane - three-pilot airplane - and it gave me the 
6 
opportunity to become a Director of Maintenance, and 
7 
it was a challenge. You know, bringing - upstaging 
8 
an airliner on a private ticket or a VIP ticket is 
9 
really challenging, and I enjoy the challenge of 
10 
working and developing the program and stuff. 
11 
O. Well, my understanding, 
Wexner is 
12 
generally - he's in Ohio, right? 
13 
A. No, he's got other places. I mean -- No, 
14 
he's like anyone, he's - in his category - he's got 
15 
multiple homes and --
16 
O. 
Well, when you would maintain his aircraft, 
17 
would that be in Ohio --
18 
A. 
Yes. We were based --
19 
O. 
Or elsewhere? 
20 
A. We were based at Lane Aviation. 
21 
MR. REINHART: Hold on one second. You 
22 
have to let him finish asking the question 
23 
before you answer. 
24 
THE WITNESS: Okay. I'm sorry. 
25 
BY MR. EDWARDS: 
15 
1 
aircraft. I mean, whatever it takes to keep a 
2 
corporate flight department operating. 
3 
O. Did you know back then of his relationship, if 
4 
any, with Jeffrey Epstein? 
5 
A. Not immediately, no. 
6 
O. When is the first time that you knew of a 
7 
reputation or a relationship between Wexner and Epstein? 
a 
A. Would have had to probably be around maybe 
9 
'98, 99. 
10 
O. How do you become aware that they know one 
11 
another? 
12 
A. Because Jeffrey. every one 
That's when 
13 
I became a flight engineer on the Boeing. and every 
14 
once in a while Jeffrey would ride on the Boeing, 
15 
that's all • that's all I knew. 
16 
O. How did it come about that he would ride on 
17 
Wexner's Boeing? 
18 
A. They were business associates, I think. 
19 
O. 
As far as you know, they were business 
20 
associates. 
21 
A. Right. 
22 
O. Did you understand the business relationship 
21 
between the two? 
24 
A. Welk I believe it's public knowledge 
25 
that, I think, Jeffrey managed Mr. • some of Mr. 
14 
1 
O. I'm sorry, have you ever had your deposition 
2 
taken before? 
3 
A. No. 
4 
O. You definitely never had your deposition taken 
5 
before while somebody else is trying to eat at the same 
6 
time they're trying to ask the questions that's very 
7 
bizarre. 
A. Yes, yes. 
9 
O. I meant to do this before I got here. But. 
10 
regardless. Ill wail until you finish your answer before 
11 
I ask my next question; you do the same thing. 'Uh-huh' 
12 
or 'uh-uh.' they kind of look the same on the record. so 
13 
try to give us a 'yes' or 'no' or something we 
14 
understand. 
15 
A. Alright. 
16 
O. II I ask a question that was a bad question or 
19 
something you don't understand - I've asked bad questions 
18 
before • say, I don't gel it? I'll ask a better 
19 
question. 
20 
A. 
Okay. 
21 
O. 
You were working with = 
Wexner. You got 
22 
the job there starting in 1988. On a day-to-day basis, 
23 
what would you be doing? 
24 
A. Maintenance, aircraft maintenance, 
25 
tracking of aircraft maintenance. cleaning of 
16 
1 
Wexner's funds. 
2 
O. Is that something that Mr. Wexner told you? 
3 
A. No. 
4 
O. Is that something that somebody of Mr. 
5 
Wexner's organization would have told you? 
6 
A. 
No. 
7 
O. Is that something that Jeffrey Epstein told 
8 
you? 
9 
A. No. 
10 
O. Is that just reading articles that speculate 
11 
as to the business relationship between the two or do you 
12 
got something more for me? 
13 
A. No, it's just • it's speculation and, you 
14 
know, what I've read. you know. 
15 
O. I mean, like you say, to me it's common 
16 
knowledge --
17 
A. Right. 
18 
O. But It's only because of what I've read. I 
19 
don't have a specific person that I could cite to to say 
20 
that, do you? 
21 
A. Right. No, just - just periodicals. 
22 
O. What's your understanding of the personal 
23 
relationship, if any, between Wexner and Epstein? 
24 
MR. GOLDBERGER: Form. 
25 
A. Don't know. 
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October 6, 2009 
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O. Did you ever know of a time -- And I may be 
asking a question that would just be completely outside 
of your knowledge, so let me back up. 
Have you ever stayed at 
Wexner's house? 
A. No. 
O. Do you know where his house is? 
A. Yes. 
O. Do you know what the address is in Ohio? 
A. No. I just know the city. 
0. Do you know who he lives with? 
A. Yes. 
O. Who is that? 
A. His wife and children. 
0. What's his wiles name? 
A. Abigail. 
O. Abigail Wexner, and he has three or four 
daughters, right? 
A. No. Has got a son. Harry. and two 
daughters. I think. 
O. A son and two daughters. 
A. I don't know. See. that was back in 2001. 
I don't know what they have - if they have more kids 
O. Okay. Did you ever hear any Information that 
he was homosexual? 
19 
1 
O. Have you spoken personally with Mr. Wexner? 
2 
A- On business issues, yes. 
3 
O. Business issues related to your work on Ns 
4 
airplanes? 
5 
A. Correct. 
6 
O. Have you spoken to him on any other issues 
7 
that don't involve business relationships with his 
a 
airplanes? 
9 
A. No. 
10 
O. Because you're Nred basically for that 
11 
purpose, so that's kind of how you deal with him. 
12 
A. Yeah. Ifs I'm an employee and he's my 
13 
employer and I only deal with him. you know. on 
14 
issues that Involve maintenance. 
15 
O. I think I probably know the answer to the next 
16 
question, but just in case I dont do you know any of 
17 
his personal friends • people that he would hang out with 
18 
on a social level - being Mr. Wexner? 
19 
A. Through my business ties, yes, yes. 
20 
O. Who's that? 
21 
A. I'm trying to remember -- You have to 
22 
remember ifs been several years. 
23 
O. Right. 
24 
A. He was friends with the Tuckennans. 
25 
O. What's Mr. Tuckerman or Ms. Tuckerman's names? 
18 
1 
A. No. 
2 
O. Being Mr. Wexner. 
3 
A. No. 
4 
O. Any indication to you that he may be 
5 
homosexual or bisexual? 
6 
A. Absolutely not. 
7 
O. Have you heard any information that he and Mr. 
8 
Epstein were involved sexually with one another? 
9 
A. Oh, no. no. 
10 
O. Would that surprise you? 
11 
A. Absolutely. 
12 
O. And Mats only because you know him and you 
13 
know Mr. Wexner and you don't see the Iwo together. 
14 
A. Correct. 
15 
MR. GOLDBERGER: Form. 
16 
A. Welt -
17 
O. He --
18 
A. Go ahead. 
19 
MR. REINHART: If you need to answer. 
20 
answer the question. 
21 
A. Yeah. No. I saw him with Sharon. which 
22 
was his previous girlfriend before he met Abigail. 
23 
O. Right. 
24 
A. No. There was never any hint or anything 
25 
that I would even conceive that. 
20 
1 
A. Ms. -- I caret I always addressed them 
2 
by their proper name. 
3 
O. Do you know what they do? 
4 
A. They owned an optical company - opticians. 
They were high school friends from Mr. Wexner's high 
6 
school days. 
7 
O. In Ohio or New York? 
a 
A. He went to high school in Bexley. 
9 
O. Bexley. Ohio. 
10 
Has he ever discussed with you how 
11 
longstanding the relationship is between himself and Mr. 
12 
Epstein? 
13 
MR. GOLDBERGER: Form. 
14 
A. I don't understand. Can you rephrase it? 
15 
O. Well, you know that at some point in time -
16 
You started working with him in 1988. The first time. 
17 
according to my notes. that you became aware that he was 
18 
friends or acquaintances with Mr. Epstein was '98 -
19 
almost ten years later. 
20 
A. Right. 
21 
O. After you became aware that there was that 
22 
relationship, whether business or otherwise, did he ever 
23 
speak to you about how long he had known Mr. Epstein? 
24 
A. Oh, no, no. 
25 
O. So as far as you were concerned, 1998, when 
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1 
you found out there was a relationship with Epstein. it 
2 
could have very well started then. 
3 
A. Yes. 
4 
O. Aside from aircraft technician and taking care 
5 
of Mr. Wexner's aircraft back in the '805 and, I guess. 
6 
early '90s, did you have any other personal involvement 
'7 
with him? 
8 
A. Just on aircraft completions. 
9 
O. And when you would speak with him, would that 
10 
be over the telephone. at the airport. at his private --
11 
A. It would usually be al the corporate 
12 
office. 
13 
O. Al the corporate office? 
14 
A. 
At the corporate office. 
15 
O. Can you tell me the address for his corporate 
16 
office? 
17 
A. No, I can't. 
18 
O. If I requested that from your attorney, would 
19 
you be able to get that information? 
20 
A. Well, I mean. I imagine it's public 
21 
knowledge • wherever • it's at the Limited. 
22 
O. And that's where you would meet him • at the 
23 
Limited? 
24 
A. Yeah. 
25 
O. And how often was • you know, I know that 
23 
1 
O. Who were some of the pilots? 
2 
A. Tun Staley. Jim Taylor. They've had some 
3 
turnover too. I don't 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 I was flying for Mr. 
14 
Epstein. 
15 
O. So there's no real, other than yourself 
16 
Welt, tell me if I'm wrong: I understand that you did 
11 
some work for Mr. Wexner related to his aircraft and you 
Is 
did some work for Mr. Epstein, which we haven't yet got 
19 
to, but you did some work for him too. Are there any 
20 
other people that have that type of relationship with 
21 
both parties? 
22 
A. No. I'm sorry, resay that. 
23 
O. Okay. You've already told us that you were 
24 
the aircraft technician for Mr. Wexner. 
25 
A. One of them. One of several, yes. 
22 
1 
we're talking about 15, 2O years ago - how often was Mr. 
2 
Wexner personally at that location at the Limited 
3 
offices? 
4 
A. I have no idea. 
S 
O. 
But any time you needed to talk to him. that's 
6 
where he would be? 
7 
A. 
Yeah, and I usually went to Charlie 
8 
Hinson. 
9 
O. Who's Charlie Hinson? 
10 
A. He was the president of the stores. He 
11 
basically was my gobehveen for these aircraft 
12 
completions for the design. 
13 
O. And you mentioned the Gullstream as an 
14 
aircraft. Did you also serve as a technician for other 
15 
aircrafts that were owned by Mr. Wexner? 
16 
A. Right, but not Mr. Wexner. They're owned 
17 
or operated by Limited Stores. 
18 
O. Limited Stores? 
19 
A. Right. Yes. 
20 
O. What did you do for them? 
21 
A. Same • maintenance. 
22 
O. Did you ever fly in them? 
23 
A. On the Guff streams in the early days we 
24 
used flight mechanics, especially on international 
25 
flights. 
24 
1 
O. One of them. Then you also have knowledge 
2 
about Mr. Epstein and some relationship with Mr. Epstein. 
3 
A. Correct. 
4 
O. Are there any other pilots, aircraft 
5 
technicians, people like that that you know of to have a 
6 
relationship with both Mr. Wexner and Epstein? 
A. No, no. 
8 
O. Do you know how Mr. Wexner met Mr. Epstein? 
9 
A. No. 
to 
O. How long - if you started in 1988 • how long 
11 
did you stay with Mr. Wexner and/or The Limited? 
12 
A. January of '01. 
13 
O. Why did you stop? 
14 
A. Because what we were talking before, you 
15 
know, I wanted to continue flying. They bought a 
16 
BBJ. which is a two-pilot aircraft, and I wanted to 
17 
continue flying. Mr. Epstein bought the 727 and 
18 
offered me a position to continue flying and. you 
19 
know, basically sot up the airplane for his flight 
20 
department because they hadn't had any previous large 
21 
aircraft experience. 
22 
O. I missed something. It wasn't your fault, it 
23 
was mine. 
24 
The Gulf stream that you were talking about. 
25 
did you used to fly that as well as being a flight 
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technician? 
A. No, no. 
O. Okay. 
A. You don't have to have a flight - a 
pilot's certificate to be a professional flight 
engineer. I've got a turbo - a flight engineer turbo 
jet rating, but you don't have to have a commercial 
ticket as long as you - the FAA recognizes your heavy 
aircraft maintenance experience. 
0. So you're saying that if the FAA recognizes 
your heavy maintenance experience, I'm assuming that 
means that you understand the ins and outs of airplanes 
and you can work on them. 
A. On heavy high performance aircraft, yes. 
0. Then you can also fly them? 
A. 
Sideways as a flight engineer. 
0. Explain. 
A. On the older generation airliners there 
was three pilots • there's a captain, a first 
officer, and then the flight engineer is the 
gentleman that sits sideways and maintains all the 
systems. 
0. When you say, sits sideways: okay, I have 
A. Literally, you're physically sideways in 
27 
1 
0. Do you know why Epstein those to buy that 
2 
particular 727 rather than one of the other million 727s 
3 
that are made? 
4 
MR. GOLDBERGER: Form. 
5 
A. Because it was probably the finest one out 
6 
there •-
7 
0. Why? 
8 
A. -- In all honesty. It's got a fully Paged 
9 
STC interior with EFTS cockpit, and Limited's 
10 
reputation on the way that we maintained our aircraft 
11 
• it's the best one out there. 
12 
0. Describe for me the interior • I'm not talking 
13 
about the Epstein days, we're talking about the Wexner 
14 
days - describe for me the interior of the aircraft, and 
15 
keep in mind that I've only been on a commercial aircraft 
16 
where you don't see the pilots. there's a door, and then 
17 
everybody, you know, there's rust a bunch of seats where 
18 
everybody sits there. 
19 
A. Correct. Right. 
20 
The aircraft 
You enter the airplane. 
21 
ifs got forward air stays, which most 72Ts don't, 
22 
so you enter the forward door on the left-hand side, 
23 
the forward entryway vestibule, and there's a door on 
24 
the left, which leads to the cockpit, and then 
25 
there's a door on the right which leads aft to the 
26 
1 
the cockpit. 
2 
0. So you're not looking al the people that were 
3 
flying on the plane and you're not looking at the pilots, 
4 
you're actually literally sitting sideways. 
5 
A. I sit sideways at a panel, yes. 
6 
0. What's your job? 
7 
A. Maintain all the aircraft systems - the 
8 
hydraulics, fuel management, pressurization. 
9 
environmental controls. 
10 
0. That's not done by the pilots. 
11 
A. No, no. 
12 
O. But if you've done that long enough and FAA is 
13 
aware of your credentials in that respect, then you also 
14 
could be credentialed to be a pilot as well? 
15 
A. Well, sure, yeah, yeah. If that's a 
16 
career choice you wish to take. 
17 
0. And was that? 
A. No, no. I was perfectly satisfied with my 
19 
position as a flight engineer and Director of 
20 
Maintenance. 
21 
0. What year did you say Epstein bought the 727 
22 
that was once owned by Wexner? 
23 
A. I don't know when the actual transition 
24 
took place, but when I came - shortly around the 
25 
period that I came on board in 'et January of '01. 
28 
1 
forward salon. 
2 
0. What's the forward salon? Sorry. 
3 
A. Forward seating area. 
4 
0. And is it set up basically the way that I'm 
5 
picking it - in that there are 25 or 26 rows and they're 
6 
numbered A through E? 
7 
A. No, no, it's a corporate configuration. 
8 
O. Which means nothing to me, so help me. 
9 
A. Picture a 600-mile an hour Winnebago. I 
10 
mean, it's got conference tables and divans and large 
11 
first class seating. 
12 
0. Any various dividers throughout --
13 
A. 
Yes. 
14 
0. 
to where there's a VIP room in the back or 
15 
anything like that? 
16 
A. It's compartmentized (sic), yes. 
17 
0. In what way? Describe it as specifically as 
18 
you can. 
19 
A. There's a forward salon, a mid galley -
20 
the galley's in the mid - an aft • an aft salon, 
21 
which is • and then the aft slate room. 
22 
0. Who designed that plane? 
23 
A. I can't remember who the actual designer 
24 
was. It was a Page interior, though. Page Avjet did 
25 
the installation. 
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O. Who directed the design of that plane? 
2 
A. It would have been Mr. Wexner. I mean, it 
was •• The layout has not changed. 
4 
O. 'The layout has not changed," when you say 
that, you mean 'from the time that I first got in it and 
() 
I was under the guise of -'under 
'under the employment of 
Wexner to the time I've been on it since with Epstein, 
a 
the configuration is the same.' 
9 
A. Essentially, yes. We removed one chair 
10 
and one small table that was an annoyance and that's 
11 
it, but it's identical to what The Limited used. 
12 
O. Are there any blocked ott areas to where if 
13 
you're standing in the middle of the plane you cant see 
14 
certain areas of the plane? 
15 
A. There are pocket bulkheads. Yeah, there's 
16 
dividers between the sections. 
17 
O. How big aro these dividers and where are they? 
18 
A. Well, there's a divider - the forward 
19 
door, I
 you, on the salon, then there's a pocket 
20 
door on the forward side of the galley, a pocket door 
21 
on the aft side of the galley, there's a pocket door 
22 
between the aft salon and the office, and then 
23 
there's another pocket door between the office and 
24 
the state room. 
25 
O. Have you been on other 727s before that are 
1 
2 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
IS 
36 
17 
18 
19 
20 
21 
22 
23 
24 
25 
31 
because obviously there's a lot - there's not that 
A. Privately owned 727s, but this is 
As a 
matter of fact. The UmIted's current 88..i nis a very 
similar floor plan. 
O. As Trump's? 
A. No. as the - as our 727. 
O. Who's 'our? 
A. Mr. Epstein's. They didn't change a lot. 
It's -
O. Well, I thought that you had told me that the 
727 that was once owned by Wexner is the 727 that's owned 
by Epstein. 
A. It is. but what I'm saying is even their 
current airplane has the same layout - the 86J. They 
put the same floor plane in the more modern airplane. 
O. Well, they didn't have to put it there. It 
was already there. right? 
A. No. no, no. When you buy these aircraft -
even a Gulfstream - when you buy them it's just a 
green hull, there's nothing in them, and you can 
customize your interior. 
O. I'm sorry, we're miscommunicating somewhere, 
and I'm sure it's on me. 
MR. GOLDBERGER: Yes. it is. 
1 
2 
3 
4 
5 
6 
7 
a 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
30 
commercial airliners privately owned? 
A. 
Yes, yes. 
O. Have you noticed similar configurations to 
where there are this many dividing doors or is this one 
that has more so than you've seen in the past? 
A. No, no, this is pretty atypical (sic). 
O. It's pretty atypical? 
A. It's typical. 
O. It's pretty typical? 
A. 
Yes, yes. 
O. So what other airplanes - 727s, or other major 
airplanes - have you been on that have theSe types of 
dividers? 
A. Trump. 
O. Trump's airplane? 
A. Yes. 
O. Why were you on Trump's airplane? 
A. 
Well, I know the crew and, you know, this 
Is a small-knit community. There's not very many of 
them out there, so everybody in this world knows one 
another to help one another out as far as --
O. By 'there' --
A. -- information-wise and stuff. 
O. By 'there aren't that many of these people out 
there," you don't mean there's not that many people - 
32 
1 
MR. EDWARDS: And I'm taking the blame for 
2 
it - right away. 
3 
MR. REtNHART: Take that Ed. 
4 
MR. EDWARDS: Alright 
5 
BY MR. EDWARDS: 
6 
O. My understanding • and please correct me when 
7 
I'm wrong, because I know I am - Wexner has this 727 and 
8 
he designs it in a certain way. 
9 
A. Uh-huh. 
10 
O. And then you come to work for Epstein 
11 
A. Yes. 
12 
O. -- who buys the same 727. Your testimony, as 
13 
I'm understanding It. is: It's basically the same floor 
14 
plan as Wexner's floor plan. To me, it should be the 
15 
exact same because he bought the same plane. 
16 
A. No. he -- You're misunderstanding. 
17 
I figured. 
IS 
What I was stating is You were I was 
19 
answering the question in regards to, "Is this 
20 
unusual to have this many compartments and closed 
21 
doors and bulkheads and things?' 
22 
What I was trying to state was: No, it's 
23 
not unusual - because The Limited even liked the 
24 
floor plan so well in their old airplane that they 
25 
sold to Mr. Epstein. They duplicated it In their new 
Q. 
A. 
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1 
airplane - see what I'm saying? That's all I was 
2 
O. So they didn't keep the floor plan. They 
3 
actually took it out and they restructured the floor plan 
4 
to basically match that old floor plan. 
A. Well, no. When you -- When you buy a 
6 
Boeing business jet —
7 
O. Yes. 
8 
A. -- it comes with nothing inside. It's a 
9 
tube. Nothing's in there. You design - have 
10 
designers design your interior and then a fabricator 
11 
or a facility such as Page Avjet to install this 
12 
interior. 
13 
O. Right. 
14 
A. What I was just trying to state was that 
15 
The Limited liked their old floor plan in the old 
16 
airplane so well - it worked so well for them - that 
17 
they duplicated It and had that same interior 
18 
installed in the new aircraft - same floor plan 
19 
installed on the new plan. 
20 
O. So Epstein didn't buy the exact same plane. 
21 
He bought the same type of plane. 
22 
A. Well, more modem. He bought a 737, 
23 
right. 
24 
O. Got it. 
25 
A. Right. 
35 
1 
had a very identical or very like floor plan 
2 
installed in the new airplane. 
3 
Q. Got it. 
4 
Okay? Sony, it's a strange business. 
5 
It's 
6 
O. Tell me if I'm right: Mr. Wexner had a plane 
7 
that had a floor plan that apparently appealed to Mr. 
8 
Epstein, so Mr. Epstein bought that plane. 
9 
A. Correct. 
10 
O. Mr. Wexner also liked that plane that he had 
11 
just sold to Mr. Epstein, so he built in a floor plan 
12 
very similar to the one he just sold to Mr. Epstein. 
13 
A. In his new aircraft. 
14 
O. Brand new plane. 
15 
A. Correct. 
16 
O. Got it. We're on the same page now. 
17 
A. 
Alright. 
18 
O. Took us a while to get there. 
19 
A. 
Yeah, sorry. 
20 
O. I think it was my fault, honestly, but 
21 
alright? 
22 
A. It's an unusual process if you haven't 
23 
been around corporate airplanes. 
24 
O. I didn't realize that Mr. Wexner had a new 
25 
plane. 
34 
1 
MR. REINHART: Hold on. 
2 
BY MR. EDWARDS: 
3 
O. Totally understand now. 
4 
MR. REINHART: Can you clarify - Mr. 
Epstein or Mr. Wexner? 
6 
BY MR. EDWARDS: 
7 
O. Mr. Epstein bought not Mr. Wexner's plane. 
8 
A. No. 
9 
O. He bought the same type of plane that Mr. 
10 
Wexner had and modeled the floor plan --
11 
A. No. 
12 
O. -- the same way that Mr. Wexner had it. 
13 
A. That is not correct. 
14 
O. He bought, actually, Mr. Epstein --
15 
MR. REINHART: Hold on. Distinguish -
16 
Use names so we're very clear when you're 
17 
talking about Mr. Epstein and Mr. Wexner, okay? 
18 
A. Mr. Epstein bought Mr. Wexner's 727. 
19 
O. Okay. 
20 
A. The actual airplane - bought it from him. 
21 
O. Which has a floor plan already in it. 
22 
A. That we just discussed. 
23 
O. Alright. The floor plan's in the plane. 
24 
A. Right. Mr. Wexner replaced the airplane 
25 
that Mr. Epstein bought with a new airplane and he 
36 
1 
A. Yes. 
2 
O. That's where I had a problem. 
3 
How many times have you been on Mr. Wexner's 
4 
airplane? 
A. The new? 
6 
MR. REINHART: Clarify which one you're 
7 
talking about. 
8 
BY MR. EDWARDS: 
9 
O. Before you ever met Mr. Epstein. 
10 
A. I can't say. I mean, over the years? 
11 
O. Numerous times? 
12 
A. Oh, I was his flight engineer. You mean 
13 
when I was still employed by him? 
14 
O. Yes. 
15 
A. Yes. I was the flight engineer. I 
16 
don't --
17 
O. So as a flight engineer, every time the plane 
18 
leaves the ground, do you leave the ground with it? 
19 
A. No. We had another engineer also. 
20 
O. So what percentage of times do you leave the 
21 
ground in the airplane when the plane leaves the ground? 
22 
A. For who? 
23 
O. For Mr. Wexner. 
24 
A. Probably one-third of the time, because I 
25 
was also the lead technician, so I had 
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1 
responsibilities in the hangar, whereas the other 
2 
engineer was a full time engineer. 
3 
O. And given the partitions that you've described 
4 
in this airplane, are you able to see what's going on 
s 
behind the doors of the various partitions of the 
6 
airplane? 
7 
A, If the doors are open or dosed? 
a 
O. Closed. 
9 
A. No. 
10 
O. Do you have any idea what's taking place in 
11 
there? 
12 
A. No. 
13 
MR. GOLDBERGER: Form. 
14 
BY MR. EDWARDS: 
15 
O. When you're on the plane with Mr. Wexner. was 
16 
there a time that he had — Wet let me put it this way: 
17 
When anybody is a passenger on any of these private 
18 
planes. should there be logs of the names of the 
19 
passengers on the planes? 
20 
A. Not required, no. 
21 
O. Are you ever specifically instructed not to 
22 
record the names? 
23 
A. That wasn't part of my duties. That 
24 
wasn't an engineer's task, but -
25 
O. Do you — 
3 9 
1 
A. 
There is normally a passenger manifest, 
2 
yes. 
3 
Q. Who creates the manifest? 
4 
A. Probably dispatch. 
5 
Q. Dispatch? 
6 
A. 
At Limited. 
7 
O. Do you know who that is? 
8 
MR. REINHART: Can you give a time frame? 
9 
Do you mean currently or back when he worked 
10 
there? 
11 
MR. EDWARDS: I'm talking about back when 
12 
he worked there. 
13 
BY MR. EDWARDS: 
14 
O. Do you know who that was at dispatch? 
is 
A. 
That would have been Diane Williams. 
16 
O. Who does Diane Williams work tor? 
17 
A. Limited Flight Department. 
18 
O. Who does she report to? 
19 
A. Tim Staley. 
20 
O. 
Who's Tim Staley? 
21 
A. Director of Operations. 
22 
O. For who? 
23 
A. Limited Flight Department. 
24 
O. What does he then do with that information? 
25 
A. I don't know. I don't know. 
38 
1 
A. 
no, not that rm aware of. 
2 
O. Who is assigned the duty of reporting the 
3 
names of the people who are going to be transported on 
4 
the airplanes? 
MR. GOLDBERGER: Form. 
6 
A. Captain. 
7 
Q. So have you ever been privy to conversations 
8 
where the captain is told by Mr. Wexner to record all of 
9 
the names of the people that are going to be on the 
2o 
airplane? 
11 
A. Can't say. 
12 
Q. Sometimes? 
13 
A. I can't - You know. I can't say. I can't 
14 
remember what our policies were at the time. 
15 
O. I'm not asking policies. I'm asking: Have 
16 
you ever been around when the pilot was being instructed 
17 
by Mr. Wexner • back in the late 80s, early '90s - to 
18 
make sine that you record who's on this aircraft? 
19 
A. I never heard Mr. Wexner address that, no. 
20 
O. I mean, God forbid the airplane crashes, you 
21 
would like to know who's the on the airplane, right? 
22 
MR. GOLDBERGER: Form. 
23 
A. Yes. 
24 
O. Is there any way to determine who's on each 
25 
particular flight in case anything happens? 
40 
1 
O. Have you ever talked to Tim Staley? 
2 
A. 
From -- Yes, yes. 
3 
O. 
And what do you talk to him about? 
4 
A. 
Oh. we're - we're friends. We worked 
5 
together for years. I mean, I haven't talked to him 
6 
since the holidays. 
7 
Q. 
DO you know where he is now? 
8 
A. To the best of my knowledge, still 
9 
Director of Operations at Limited. 
10 
O. Do you have a number for him? 
11 
A. 
Yes. 
12 
O. Can I have the number, please? 
13 
A. It's 
14 
O. Is that a work number? 
15 
A. That's the Flight Department. 
16 
Q. 
That's the best number to reach him at? 
17 
A. 
Yes. 
18 
O. If I'm going to call him, that's the number I 
19 
call? 
20 
A. Correct. 
21 
O. And was he always in charge of flight 
22 
directions? 
23 
A. No, he was previously Chief Pilot. 
24 
O. He was previously Chief Pilot for Limited? 
25 
A. 
Same, yes. 
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41 
1 
O. 
And he was promoted, I suppose. to Flight 
2 
Director? 
3 
A. Director of Operations. It's the 
4 
department crew. Most small departments don't have 
5 
directors until they start to grow. 
6 
Q. And when he was Chief Pilot were you 
7 
affiliated with the Wexner organization? 
8 
A. 
Yes, I was a maintenance technician. 
9 
Q. 
And when you say somebody keeps flight logs. 
10 
is it always Tim - is his name Tim Staley? 
11 
A. 
Yes. 
12 
O. 
is it always Tim Staley who does that? 
13 
A. No. I don't know where they go. honestly, 
14 
and the system may have changed. 
15 
Q. Okay. Are you 
16 
A. I've been gone since --
17 
O. Are you aware of any FAA policies to where 
18 
they need to know who's on the aircraft whenever it talks 
19 
off? 
20 
A. Not under Pad 91 Operations, there is 
21 
not. 
22 
O. Part what? 
23 
A. Part 91. 
24 
O. What does Pad 91 say as far as you know? 
25 
A. It's basically souls on board when you 
43 
1 
international. The only time we do international 
2 
would be for Customs and Immigration. 
3 
O. So if it's an international flight --
4 
A. For Customs and Immigration • for coming 
5 
and leaving the country. 
6 
O. 
- then they require that names of 
7 
individuals --
8 
A. It would be names, passports, that kind of 
9 
stuff • normal. 
10 
O. Did you ever do any international flights 
11 
while employed by The Limited, Victoria's Secret, the 
12 
whole Wexner group? 
13 
A. 
Yes. 
14 
O. How many? 
15 
A. No way of knowing. I mean, I'm - can't 
16 
say. It's, like I Say, years, but. 
17 
Q. What years would you done it? 
18 
A. Started flying as a flight mechanic in 
19 
'89, and then started flying the Boeing in '99, so -
20 
to '01, 80'89 to '01, haSirally. 
21 
(Mr. Goldberger exited.) 
22 
BY MR. EDWARDS: 
23 
O. So '89 to '01. if I wanted all of the flight 
24 
logs, who would I request those from - Tim Staley? 
25 
A. Don't know. I don't know who --
42 
1 
file a flight plan - that's the only thing you're 
2 
required to do. When you file your flight plan you 
3 
file souls on board. 
4 
O. What does that mean, "souls on board'? 
5 
A. In other words, living bodies on board. 
6 
In other words, if you have - so if there's an 
7 
accident and you have lour and you're transporting a 
e 
cadaver, that they go to the accident scene and don't 
9 
find five bodies • think there were five fatalities. 
10 
Q. So it's your understanding from what you need 
11 
to report are, 'I have five people on board.' 
12 
A. Correct, and that's for the flight plan. 
13 
O. So there's no reason to say that, 1 have Joe 
14 
Schmo on board.' 
15 
A. Not under Part 91, no. 
16 
O. That's doing something over and above. 
17 
A. 
That's correct. 
18 
O. 
You are aware, though, that there are certain 
19 
flight plans where they actually name individuals that 
20 
are on the airplane? 
21 
MR. GOLDBERGER: Form, 
22 
A. 
No. 
23 
O. I mean, you've seen that before. 
24 
MR. GOLDBERGER: Form. 
25 
A. No, not on flight plans, no - unless it's 
44 
1 
O. What does Tim Staley do after he maintains 
2 
these records? 
3 
A. I don't know. 
4 
O. He's never told you what he does? 
5 
A. No. 
6
 
Certainly they're kept on file somewhere. 
right?
8 
A. I would assume. 
9 
O. What's the name of the company that owns the 
10 
airplanes? I know it's affiliated with Wexner and all 
11 
that. but what's the name of the company? 
12 
A. Well, there were several companies. I 
13 
mean, the way corporate aviation flight departments 
14 
are set up. they're under holdings companies. 
15 
O. Ill go with all of them. 
16 
A. Well, I don't know. They change. They 
17 
change sometimes by the year, sometimes -- I have no 
18 
idea what they're under now. 
19 
Q. What were they under back in '88 --
20 
A. It was like - 
21 
Q. -- to the best of your memory? 
22 
A. They change. I mean, every time we got a 
23 
new aircraft. or whatever, they changed. They were 
24 
like Northeast Holding, Southwest Holding. LLC • 
25 
Wilmington, Delaware, companies, which is standard 
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1 
for these, you know. 
2 
Q. Did 
Wexner ever tell you that he 
3 
allOwed Jeffrey Epstein to serve in some sort of 
4 
capacity, representative capacity, for any of these 
5 
companies? 
6 
A. No. He would never say that to me 
7 
anyways, no. 
8 
O. 
What's the first time you ever saw Jeffrey 
9 
Epstein? 
10 
A. Can't say. I'm not sure. 
11 
Q. 
I think you saw him before you started working 
12 
for him or with him? 
13 
A. Oh, yeah. that's -- Where I first saw him 
14 
was when I flew him on The Limited 727. 
15 
0. What year do you think that was? 
16 
A. It would have had to have been --
17 
0. Talking late '80s, early '90s? 
18 
A. Late '90s. 
19 
0. Late '90s? 
20 
A. 
Yeah, probably • mid to late 190s. 
21 
0. Well, I mean, if you're taken over with 
22 
Jeffrey Epstein in. what, 2001 —
23 
A. Correct. 
24 
0. 
— then you're talking late '90s is the first 
25 
time you see him? 
47 
1 
A. They were -- They were generated, but I 
2 
don't know, you know, why - what the particular 
3 
reasoning was for it. 
4 
0. Do you know if Terry (sic) Staley would have 
5 
been the one to forward those flight logs to the FAA? 
6 
A. No. no. no. I -- They were all just for 
7 
business use - not forwarded to the FAA. 
8 
0. Okay. How -
9 
A. The FM doesn't care about flight logs. 
to 
O. How did the FM monitor when that plane took 
11 
off? 
12 
A. Flight plans. 
13 
O. And was It your understanding that when the 
14 
plane took oft, the FAA was unaware as to who was ever on 
15 
it? 
16 
A. Pretty much, yeah. They don't care about 
17 
names. When you file flight plans with the flight 
18 
service station or via electronically. all they care 
19 
about is souls on board, contact information, flight 
20 
routing, things like that. 
21 
O. Are there time limits as to when the plane is 
22 
allowed to take off? 
23 
A. Yeah. usually 
From what point? What do 
24 
you mean? Time of the day or --
25 
0. Yeah. yeah, time of the day. I understand 
1 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
IS 
16 
17 
18 
19 
20 
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22 
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46 
A. Well, mid -- I don't know exactly. I 
can't realty say, really. 
0. I won't hold you to it. It is what e is. 
Mid to late '90s. if I wanted the flight logs 
that have him on it, on the airplane, who would I 
subpoena to get those records? 
A. I have no Idea. 
0. Are they turned into the FAA. to the best of 
your knowledge? 
A. No. the FAA doesn't require them. 
0. So FM does not get the flight -- Well, what's 
the point of even keeping these? 
A. Sometimes I think the IRS 
I mean, this 
is on assumption, I'm not even sure, but mostly for 
like IRS tracking for if you have people that have 
dual homes, dual statehoods. or whatever. 
(Mr. Goldberger entered.) 
MR. GOLDBERGER: Can we take a time out? 
(Short break.) 
(Mr. Pike appeared via telephone to 
replace Mr. Goldberger.) 
BY MR. EDWARDS: 
0. FM flight logs • do you know why theyre 
generated, how they're generated, if they were generated 
back in the Wexner days? 
48 
1 
that there's some time where if it's too late they can't 
2 
take off, right? 
3 
A. 
Only where there's a curfew on the airport 
4 
- not all airports, no. No, airplanes can fly any 
5 
time unless that airport has a noise curfew or 
6 
something, yeah. 
7 
0. Did you ever know of Wexner's plane to take 
8 
off after ten o'clock p.m.? 
9 
A. 
Yes. Yeah. 
10 
0. Were you ever an that plane when it did? 
11 
A. Probably, yeah, yeah. 
12 
0. Were you ever on that plane when there were 
13 
girls on the plane? 
14 
A. Describe 
Define 'girls.' On the Wexner 
15 
airplane? 
16 
0. Yes. 
17 
A. 
There would be ladies and his daughters. 
18 
I mean --
19 
O. 
Other than family members. 
20 
A. 
There would be business associates. If 
21 
you're talking young women, yes, business associates 
22 
from the divisions. 
23 
0. Have you ever been on the plane when there 
24 
were girlfriends of 
Wexner? 
25 
A. Only when Abigail - before his - became 
0 
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1 
his bride, yes. 
2 
O. How about attar .-
3 
A. I mean --
4 
O. -- she became his --
5 
A. 
it was Abigail. She was the only 
6 
girlfriend. 
7 
O. How about after Abigail? 
8 
A. No. 
9 
O. Have you ever seen sex or sex-related 
10 
instances occur on MI 
Wexner's airplane? 
11 
A. Absolutely not. We didn't even have 
12 
playing cards. He looked at the aircraft as a 
13 
business - a flying business office. 
14 
O. When you say 'playing cards: what do you 
15 
mean? 
16 
A. Playing, you know, to --
17 
O. Oh. playing cards. 
18 
A. Yes, playing cards. 
19 
O. So every time that you were on 
Wexner's 
20 
airplane, it was used strictly for business? 
21 
A. Well, I don't know if it was used strictly 
22 
for business, but there was no, you know, it was — I 
23 
don't know what the purpose of the actual trip was, 
24 
but never saw, you know, anything, you know. 
25 
O. Was there ever a time when you were --
1 
2 
3 
4 
5 
6 
7 
a 
10 
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12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
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51 
O. Yes, with you on it. 
A. I can't I can't say. 
O. Well, where do you remember going in it? 
A. Well, we would normally go to London, 
Milan. Paris. I mean, mostly fashion areas and 
business - business areas. 
O. When you say 'fashion areas,' what do you 
mean? 
A. Well, retail. I mean, you know, design 
for clothing and stuff like that. 
O. What was the purpose? 
A. I'm sure it was business. I have no idea 
what the actual purpose was. I don't — 
O. Did you get off the plane? 
A. Well, of course. 
O. What did you do there? 
A. Go to a hotel, eat dinner, wait to find 
out when you're going to the next place. 
O. Were you ever on an international flight on 
one of Mr. Wexner's planes that Jeffrey Epstein was also 
on? 
A. I can't say. I can't remember. 
O. Maybe? 
A. Possibly. 
O. Do you remember any specific places that 
50 
1 
MR. REINHART: Hold on. Were you 
2 
finished? 
3 
BY MR. EDWARDS: 
4 
O. I thought you were finished. 
5 
A. Yeah, I don't understand. I don't 
6 
understand that question. 
7 
O. I'm going to clarify. Were there ever times 
8 
when you were on the plane and either MI 
Wexner 
9 
and/or other individuals went behind these various areas 
10 
that you could not see into? 
11 
A. Yes. Yeah. 
12 
O. Do you know what they were doing in there? 
13 
A. Probably sleeping. He would go to bed at 
14 
night on the long trips, okay. 
15 
O. Any time that more than one person wont in one 
16 
of these areas that you would not be able to see into? 
17 
A. Not that I'm aware of, but my exposure to 
18 
back there is not that, you know, is limited. 
19 
O. How many times did you see Jeffrey Epstein 
20 
ride that plane with 
Wexner? 
21 
A. Not many, but I can't say exact. 
22 
O. How many international flights do you remember 
23 
that plane taking? 
24 
A. Remember -- The airplane itself taking 
25 
international? 
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 
52 
Jeffrey Epstein went while on that plane outside the 
United States? 
A. I can't remember. No, no. Like I say. I 
can't even remember if we took it for sure. 
O. Any time that you remember Jeffrey Epstein 
being on the airplane, do you also remember there being 
gins on the airplane along with Mr. Epstein? 
A. I can't -- I can't say. I can't remember. 
O. When's the first time you remember seeing 
Jeffrey Epstein? 
A. Well, like I say, I don't even remember 
the year. I can't even pinpoint down to the year. 
It was after - some time after I started flying the 
727, because that's the only exposure. 
O. Okay. I'm not going to ask you at all during 
this deposition to guess. I thought at some point in 
time you told me you remember seeing Jeffrey Epstein, 
right? 
A. 
Yes. 
O. In fact, you work for him now. 
A. Yes. 
O. So at some point in time you saw him and you 
saw him for the first time. 
A. Correct. 
O. When's the first lime you remember seeing him? 
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1 
It may not be the first time you saw him. When's the 
2 
first time you remember seeing him? 
3 
A. '99, somewhere in that area. 
4 
O. 
Alright. In '99 were you working tor -
5 
Wexner or were you working for Jeffrey Epstein? 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
16 
19 
20 
21 
22 
23 
24 
25 
A. 
Wexner. 
O. 
And do you remember the context in which you 
saw Jeffrey Epstein? 
A. It was a flight. 
O. 
What did 
I
=
 
Wexner ever tell you in terms 
of who Jeffrey Epstein was? 
A. Never told me anything who Jeffrey Epstein 
was. 
O. Did you ever ask? 
A. No. 
O. Did you ever ask back in 1999 when you saw 
this guy. 'I wonder what he does'? 
A. No. 
O. Not even curious? 
A. No. It's not my place. I don't 
I 
don't need to know or want to know what people's 
associations are. 
O. Next lime you saw Jeffrey Epstein was when? 
A. I can't say for sure. 
O. Have you seen Jeffrey Epstein at 
55 
I 
Jeffrey Epstein helped to - I think, what you said was • 
2 
manage MI 
Wexner's money? 
3 
A. Some of his accounts, yes, I guess. 
4 
O. Why do you think that? 
5 
A. From what I've read in periodicals and 
6 
magazines. 
7 
O. You've read in what periodicals and magazines? 
A. I think it was, what, Vanity Fair there 
9 
was an article a couple years back, three or 
10 
four years back, and a New York magazine as I 
11 
mentioned. 
12 
O. Why did you read the article? 
13 
A. Well, obviously it was dealing with the 
14 
gentleman that I was working tor. so out of 
15 
curiosity, you know. 
16 
O. Right, because people tend to be curious --
17 
A. Right. 
18 
O. 
right? But when I lust asked you who 
19 
Jeffrey Epstein was and the relationship, you said, 'I 
20 
have no idea,' implying that you weren't curious. But at 
21 
some point in time you got curious as to who this person 
22 
is, right? 
23 
A. Who Jeffrey Epstein is? 
24 
O. Yes. 
25 
A. Well, yeah, when you're working for him 
54 
1 
Wexners house? 
2 
A. No. 
3 
O. Never? 
4 
A. Never. I've never -
5 
O. Have you ever -
6 
A. 
been to Wexners house. 
7 
O. You've never been there? 
A. No. 
9 
O. Have you ever known of IM 
Wexner or heard 
10 
0l- 
Wexner having minor girls or minor boys at his 
11 
house? 
12 
A. Oh, no. 
13 
O. Have you ever heard of Jeff --
14 
MR. REINHART: I assume, other than his 
15 
children. 
16 
MR. EDWARDS: Oh. of course. 
17 
A. 
Yeah. No - his children. I'm sorry. 
Is 
Thank you. 
19 
O. Have you ever known of Jeffrey Epstein to take 
20 
underage girls to 
Wexner's house? 
21 
A. No. 
22 
O. Do you know how it is that Jeffrey Epstein and 
23 
Wexner not each other? 
24 
A. No. 
25 
O. You mentioned earlier that you believed that 
56 
1 
and he's in a magazine, you're going to read the 
2 
article. 
3 
O. Okay, so at some point in time, did you Google 
4 
Jeffrey Epstein? 
5 
A. No, no. 
6 
O. Have you read the articles about Jeffrey 
7 
Epstein? 
A. Lately? 
9 
O. Yes. 
10 
A. Oh, of course, yes, in the newspapers. 
11 
O. And you're aware of why your deposition's 
12 
being taken today. 
13 
A. 
Yes, of course. 
14 
O. And it has something to do not with a case 
15 
with 
Wexner, but a case involving Jeffrey Epstein. 
16 
A. Correct. Yes, of course. 
17 
O. When you got this deposition subpoena, did you 
16 
by any chance try to look up some information on Jeffrey 
19 
Epstein • who this guy is? 
20 
A. No, no. I mean —
21 
O. Is there anything 
22 
MR. REINHART: Hold on. Were you 
23 
finished? 
24 
O. Okay. Go ahead. 
25 
A. No. I mean, other than every once in a 
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1 
while I'll get a Google alert just following the case 
2 
- just out of interest - because he's still my 
3 
empioyer, you know, and you don't want to be 
4 
blind-sided, but other than that, no --
5 
0. When you - 
6 
A. -- I never looked into his financial 
7 
background or anything look that. I don't know if 
8 
you can. 
9 
0. When you say a toogle alert." that's 
10 
something that you actually go out of your way and set up 
11 
on Google, right? 
12 
A. 
Yeah. 
13 
0. When did you do that? 
14 
A. A year ago or so. 
15 
0. Why did you do it? 
16 
A. Because I'm not around Mr. Wexner - or Mr. 
17 
Epstein anymore. I don't --
18 
0. Wel, he was in jail --
19 
MR. REINHART: Hold on. Were you finished 
20 
with your answer? 
21 
A. I haven't been a full time employee with 
22 
Mr. Wexner since --
23 
MR. REINHART: Epstein. 
24 
By MR. EDWARDS: 
25 
0. Epstein or Wexner? 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
59 
0. When you say last pace' how often are you 
flying? 
A. Every week - sometimes two, three times a 
week. 
0. And that's by the time that you're working for 
Jeffrey Epstein? 
A. 
Yes, yes. 
0. Because back in the MI 
Wexner days you 
weren't flying every day. 
A. 
No, no, no, because there was another 
engineer, no. 
0. Right. 
A. I had about one-third of the flights. 
0. So from 1988. when you start working with 
Wexner, through '89 or so. you're not flying all 
the time, right? 
A. 
No. Oh, no, no. Actually, in '88, I was, 
you know, I was - my primary duties were in the 
hangar - maintenance. 
0. Did you enjoy doing that? 
A. The maintenance part of it? 
0. Yes. 
A. 
Oh, yeah, that's my background, that's my 
forte. 
0. Is that something that you've gone back to? 
58 
1 
A. I'm sorry -- Mr. Epstein. since February 
2 
of 2007. 
3 
0. Well, a lot of that has to do with him being 
4 
incarcerated --
5 
A. No. no. 
6 
0. -- for a year, right? 
7 
MR. PIKE: Form. 
8 
A. 
No, it was because I wanted to make a job 
9 
- a career change. 
10 
Q. 
Why? 
11 
A. Because I got tired of flying, being on 
12 
the road, wanted to be home. 
13 
O. 
Did it bother you that your boss, back in 
14 
2007, was under investigation? 
15 
A. 
Of course. 
16 
0. Is that part of the reason why maybe you 
17 
wanted to make a career change? 
18 
A. No, no. The reason was the amount of 
19 
(tying that I had been doing and the ovemights, and 
20 
when something's no longer fun, it's time to find 
21 
something else to do. 
22 
0. Why wasn't it fun anymore? 
23 
A. It's a very fast pace. I wanted to spend 
24 
time at home. I wanted to get back into strictly 
25 
maintenance. 
60 
1 
A. 
Yes. 
2 
0. When did you go back to that? 
3 
A. February ol 
4 
0. Who are you doing that for? 
A. Dankjold Reed Aviation. 
6 
0. Say it again. 
7 
A. 
Dankjold Reed Aviation. 
8 
0. How did you get that fob? 
9 
A. 
Applied for it and knew the previous 
10 
Director of Maintenance, who was retiring. 
11 
0. Did MI 
Wexner and/or Mr. Epstein help you 
12 
to get that job? 
13 
A. No, no ties whatsoever. 
14 
0. So who introduces you to Jeffrey Epstein? 
15 
A. Probably it would have been Lany. The 
16 
first actual formal introduction? 
17 
0. Right. 
18 
A. Probably would 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 -- 
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1 
A. Right. 
2 
O. 
for Jeffrey Epstein. 
3 
A. Right. 
4 
O. When Is the first time you met Larry Visoski? 
5 
A. It was before he worked for Jeffrey. He 
6 
and Dave were flying for a gentleman - Glimcher 
7 
Corporation. 
8 
O. Flying for who? 
9 
A. Glimcher Corporation. 
10 
O. How do you spell that? 
11 
A. G-L-I-M-C-H-E-R, I think. They were --
12 
They had an airplane based at Lane Aviation in 
13 
Columbus with us. 
14 
O. And David Rodgers? 
15 
A. Yes. 
16 
O. How did you know David Rodgers? 
17 
A. Same, from -- They were in the same hangar 
18 
we were in. 
19 
O. Are you from here? 
20 
A. No. 
21 
O. Where are you from? 
22 
A. Columbus. Ohio. 
23 
O. So you're from Columbus, Ohio, and that's also 
24 
a place where MI 
Wexner lives. 
25 
A. Yes. 
63 
1 
Q. How did you learn of 
Wexner? 
2 
A. Oh, I mean, he's very well-known m 
3 
Columbus, because, you know, billionaires in central 
4 
Ohio, aren't, you know --
5 
O. Aren't a dime a dozen, right? 
6 
A. 
Exactly, and small guy that made it big, 
7 
you know, because that's where the name Limited - so 
8 
hearsay is - the name Limited came from he started 
9 
with limited resources. 
10 
a So did you know him before he was maned to 
11 
Abigail? 
12 
A. 
Yes. 
13 
O. And did you know him to date exclusively women 
19 
priortoMM? 
15 
A. The only -- I knew that he was dating 
16 
Sharon. 
17 
O. Right. 
18 
A. I never flew Sharon, but he dated Sharon 
19 
for a long time, and then there was, you know, they 
20 
broke up and then he started dating Abigail. 
21 
O. And have you heard any rumors about him dating 
22 
men as well? 
23 
A. No, no. 
24 
O. First time that you're hearing about it is me 
25 
telling you that, right? 
62 
1 
O. So that was at least convenient for you? 
2 
A. Oh, yeah. No, it was -- Yeah. 
3 
O. Did you go to college in Ohio as well? 
4 
A. 
Yes. Columbus State for my Aviation 
s 
degree. 
6 
O. As your first job that you had, was that with 
7 
Wexner? 
a 
A. Oh, no. I started working for Ohio State 
9 
University --
10 
O. 
And then where? 
11 
A. -- in their flight department. 
12 
Went from Ohio State University to get a 
13 
short stint. a contract maintenance for a - a 
14 
contract for NASA at Langley - researcher, and then 
15 
that was under the direction - that was contracted 
16 
under OSU's umbrella for airport research. They had 
17 
an Aviation Research Department. Then after that 
18 
went to Red Roof Inns - maintenance technician for 
19 
Red Root Inns. 
20 
O. What was it - Gregory Finns? 
21 
A. No, Red Roof Inns. 
22 
O. Red Roof Inns. 
23 
A. 
True Sports Racing. It was Budweiser 
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 because their aircraft was in our 
9 
hangar. The Glimcher aircraft was based in our 
10 
hangar and got to know him that way. 
11 
O. Glimcher is a company owned by whom? 
12 
A. I don't know if it's public or not. It 
13 
was a mall development company not associated with 
14 
Limited. 
15 
O. So what's the conversation between you and 
16 
Larry Visoski? Obviously you all end up working for 
17 
Epstein, so try to lead me through that. 
18 
A. Well, I think 
I mean, we got to know --
19 
I mean, you're neighbors in a hangar environment, so 
20 
you have discussions. 
21 
Larry was the mechanic. He was also 
22 
pilot/mechanic on the Hawker for Clincher, and you 
23 
kind of form a relationship and a rapport, and then, 
24 
I believe, Clincher sold their airplane. I don't 
25 
know how Dave and Larry ended up with Jeffrey, I 
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1 
don't know how they found that job, but they started 
2 
working for Jeffrey then, but they still --
3 
O. Did you ask them? 
4 
A. 
No, I don't think -- I've never asked 
S 
them, *How —
6 
O. Did Jeffrey --
7 
A. 
-- did you meet them?' 
8 
O. -- have a plane in the same hangar? 
9 
MR. REINHART: Hold on. Let him finish 
10 
his answer. 
11 
MR. EDWARDS: I'm sorry. I thought you 
12 
were finished. 
13 
MR. PIKE: This is Michael Pike. Let him 
14 
finish his question because, keep in mind • you 
15 
finish your question, let him finish his answer 
16 
- keep in mind, I'm on the phone, so I'm having 
17 
a hard time heating his response in the 
18 
background. 
19 
MR. EDWARDS: You're actually on the other 
20 
end of the table. Do you want us to try to move 
21 
the phone closer? 
22 
MR. PIKE: Yes, that would be good. 
23 
MR. EDWARDS: I'll do that for you, man. 
24 
I'm sorry, I really did forget that you were 
25 
here. 
67 
1 
help them with the airplane, get, you know, become a 
2 
flight engineer • Director of Maintenance - on it. 
3 
O. SO is Larry also an Ohio person? 
4 
A. 
Well, he wasn't — I think he was born and 
5 
raised in South Florida and then he was in Ohio for 
6 
that job. He lived there for a short period, yeah, 
7 
for Glimcher. 
8 
O. 
And then David Rodgers also? 
9 
A. 
They both lived in Columbus. yeah. I 
1 o 
mean, I don't know if it was a suburb, but they lived 
11 
in central Ohio. 
12 
O. 
But the hangar we're talking about is in Ohio. 
13 
A. 
Yeah, Lane Aviation. 
14 
O. 
You would see them basically on a day-to-day 
15 
basis because the aircraft that you were a technician 
16 
for --
17 
A. 
Right. 
18 
O. -- was very close in proximity to the aircraft 
19 
that they were piloting. 
20 
A. 
Yes. 
21 
O. They approach you at some point in time and 
22 
say what specifically? 
23 
A. 
I can't remember the specific 
24 
conversations, but it was like, you know, asked me if 
25 
I would be interested in. if Jeffrey bought the 727 
66 
1 
MR. PIKE: Not a problem. I've objected 
2 
to form a couple of times. I'm not quite sure 
3 
If that was oven heard, but that's neither hero 
4 
nor there. 
5 
MR. EDWARDS: We'll say the last ten 
6 
questions you chiseled to form. I got you. 
7 
What was my last question, Pike? You 
8 
don't even remember. 
9 
MR. REINHART: You asked him conversations 
10 
he had with Larry Visoski and Dave Rodgers about 
11 
how they come came to work for Epstein. 
12 
MR. EDWARDS: Good. 
13 
A. 
I really never queried them on how they 
14 
come to work for Jeffrey. I think Dave was hired 
15 
first 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 
22 
three-person train to Epstein? 
23 
A. When it became apparent that Jeffrey, or 
24 
Mr. Epstein. was going to buy the 727. Larry 
25 
approached me. that if I would want to. you know, 
68 
1 
being. you know, the flight engineer and help them, 
2 
you know, gel the flight department going. and I told 
3 
them I would. 
4 
O. And why did you say 'yes' considering that you 
5 
had a boss in 
Wexner who was seemingly pretty good 
6 
to you for the last ten years? 
7 
A. Oh, he's excellent. 
8 
O. 
Yes. 
9 
A. No, fine flight department and Mr. Wexner 
10 
is a fine person. 
11 
O. Right. 
12 
A. The reason being is. you know, I already 
13 
stated this I think twice before, was that I wanted 
14 
to be able to continue to fly and that would give me 
15 
the opportunity lo continue to fry as a flight 
16 
engineer and the challenge of starting this airplane. 
17 
O. Right. I didn't ignore you. I heard you say 
is 
trial but then I also heard you say he brought a brand 
19 
new plane. 
20 
A. It was only a two-man airplane --
21 
O. So then he would have --
22 
A. 
and the modern aircraft could only have 
23 
two pilots, right. 
24 
O. Got you. I understand. 
25 
So they approach you with this prospect of the 
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1 
two of them - Dave Rodgers and Larry Visoski • becoming 
2 
the pilots for the 727 .-
3 
A. Correct 
4 
O. 
that Epstein's buying and, 'Hey. would you 
s 
like to be a pan of it?' 
6 
A. Right. 
7 
O. I mean, that's the gist of it. 
8 
A. Correct, that would be the gist of it. 
9 
O. And your response was? 
10 
A. Yes, I would • you know, n it came to be 
11 
I would consider it. Obviously, you know, salary had 
12 
to come in and everything else, but I said• *Yeah, I 
13 
would be interested in it? 
14 
O. What's the next conversation that you had and 
15 
with whom? 
16 
A. I don't know. There were several 
17 
conversations, but they were all with Dave and Larry 
18 
both, you know, calling back and forth, but. 
19 
O. About what? Was it about salary, about the 
20 
position? 
21 
A. Salary, what the benefits were, you know. 
22 
stuff like that. No. the position was pretty much 
23 
defined. I mean, it's the flight engineer. Director 
24 
of Maintenance position. 
25 
O. And this brings us up in our timeline to 2001, 
71 
1 
I don't know. I don't know. 
2 
O. I mean, how did she get on his private 
3 
airplane? I would imagine strangers don't Just walk on, 
4 
right? 
5 
A. Yeah, but I don't know. I don't know what 
6 
people's associations are together when, you know. 
7 
O. Okay. 
$ 
A. I don't know it it's business association, 
9 
social associations, or what. 
10 
O. How many times -
11 
MR. PIKE: Let me object to the form of 
12 
that question. 
13 
MR. EDWARDS: Okay. Noted. 
14 
BY MR. EDWARDS: 
15 
O. How many times was she on that airplane when 
16 
it was owned by 
Wexner? 
17 
A. Not many, but I can't give you an exact. 
18 
O. Was she ever naked on the airplane? 
19 
A. Not that I'm aware of. 
20 
O. I mean, that's something that you would 
21 
probably remember, right? 
22 
A. Well --
23 
MR. PIKE: Form. 
24 
A. Yeah. I mean --
25 
O. I'm not really trying to be funny, but I would 
A. 
70 
1 
you think? 
2 
A. Correct, that's when I hired on and 
3 
actually moved to Florida was January 2001. 
4 
O. Prior to 2001, had you heard the name 
5 
Ghlsiaine Maxwell? 
6 
A. Yes. 
7 
O. How would you have heard Ghislaine Maxwell? 
8 
A. She had been a passenger on the 727 once 
9 
Or tWiCe. 
10 
0. The 727. I mean? 
11 
A. When it was under Limited. 
12 
O. Yeah, yeah, that's the point I'm trying to 
13 
make. I mean, this could get confusing on the record. 
14 
It's not confusing to me. but on the record it could be 
15 
because the 727 was Wexner's, then it was Epstein, so 
16 
you're talking about --
17 
A. When it was under Mr. Wexner's control. 
18 
0. What year do you think that was? 
19 
A. It would have been in the late '90s. 
20 
Again, like I say, when - probably some time around 
21 
the time • you know, had to be late '90s --
22 
O. Did she --
23 
A. -- maybe 2000. 
24 
O. Did she seem like a friend of 
Wexner's 
25 
to you? 
72 
1 
assume I would remember it. 
2 
A. Not that I'm aware of. 
3 
O. Do you remember her bringing other gkls on 
4 
the airplane with her? 
• 
A. No. 
6 
O. You remember her getting on the airplar e 
7 
alone? 
• 
A. I can't say for sure. 
9 
O. Alright. Maybe this will jog your --
10 
A. I mean, the was never just alone-alone. 
11 
Like the only passenger or. 
12 
O. Yes. 
13 
A. No. no. always with - when other people 
14 
were on board. 
15 
O. And you just cant remember whether she 
16 
brought on board with her a male or a female: is what 
17 
you're saying, right? 
18 
A. No, I mean -- Restate the question. How 
19 
did you --
20 
O. Sony. 
21 
A. Delinealone? 
22 
O. I dont mean, you know, it there's 15 
23 
passengers and she gets on. I'm saying Do you remember 
24 
her getting on and being accompanied by • either they 
25 
took the same car to the airport, they walked the runway 
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