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Larry Eugene Morrison - Volume I October 6, 2009 • • 73 1 up to the airport? Do you remember her being with 2 somebody else? 3 A. If it would have been, would have been Mr. 4 Epstein. never -- 5 O. How many times do you think Mr. Epstein was on 6 that airplane? 7 A. I can't say for sure - not that many. 8 O. Less than live? 9 A. That I saw him, yes, probably. 10 O. And how many times of all - 11 MR. REINHART: Can I just clarify? You 12 mean during the time Mr. Wexner owned the 13 plane -- 14 MR. EDWARD$: Right, right, right. 15 MR. REINHART: — since Mr. Epstein bought 16 the plane. 17 BY MR. EDWARDS: 18 O. Alright. We're not up to the point. we're 19 about to be. but we're not up to the point yet where Mr. 20 Epstein takes control, so. 21 A. I mean, you have to understand, Mr. - 22 during this time period. Mr. Epstein had his other • 23 he already owned his other airplane. 24 O. How did you know that? 25 A. Well, because that's what Larry and Dave 75 1 A. Maybe mid-'90, early '90. 2 O. We're talking -- 3 A. He didn't have that plane very long. 4 O. Between '90 and '93. you're saying. 5 A. Probably, yes. 6 O. And between '90 and '93, if we use those 7 years, you're familiar with the name 'Jeffrey Epstein' A. Not until later when he bought the 9 Gullstream in - later when he was, you know, like I 10 said, late '90, probably. 11 O. But you're aware that David Rodgers and 12 Visoski are flying an airplane between '90 and '93 that's 13 owned by somebody. 14 A. Correct. Yeah. 15 O. But you don't know the name of the person -- 16 A. Correct. Right. 17 O. -- that is the owner. We're good. We're on le the same page. 19 '88. you start working for Wexner. 20 A. Right. 21 O. And the first time Epstein is on 22 Wexner's airplane is approximately when? 23 MR. REINHART: It's asked and answered. 24 BY MR. EDWARDS: 25 O. That you remember. 74 1 were flying - the Gulfstream. 2 O. But this is something you found out 3 afterwards. 4 A. No. no. I knew that they had gotten a job 5 with him and they were flying the Guffstream. 6 O. Alright. Let me clarify this real quickly. 7 You got the job in 1988 with Wexner. A. Right. 9 O. Right. Larry Visoski and David Rodgers are 10 flying a plane that is presumably owned by Jeffrey 11 Epstein and/or one of his corporations. 12 A. N0t at first. 13 O. At some point in lime. 14 A. Correct. 15 O. And what point in time do you become aware 16 that that'8 happening? 17 A. I can't remember exactly when they bought 18 the Gulfstream. They actually had a Hawker for a 19 shod period. I don't know when that was. 20 O. Was that also owned by Jeffrey Epstein? 21 A. Fora very short period, and he traded it. 22 O. The first Epstein plane that you're aware of 23 is that Visoski and Rodgers are on -- 24 A. Was a Hawker. 25 O. -- was approximately what year? 76 1 MR. REINHART: Asked and answered. 2 A. I can't - The only time I would remember 3 - we've already answered this several times - was in 4 the late '90s when I was actually on the airplane. I 5 have no idea if he was on previous times without me 6 there. 7 O. And when he is on the airplane. is he on the 8 airplane with young girls? 9 MR. REINHART: it's also been asked and 10 answered. 11 A. No. 12 O. Now we're back to Ghislaine Maxwell, and I 13 believe your answer - which led me back to these 14 questions that I had previously asked. 'Was Ghislaine 15 Maxwell on the airplane that Wexner owned that you know 16 of?' • and I think your answer was. 'With Epsten." 17 MR. PIKE: Form. 18 A. I would - I would say if she was on 19 there, it would be with him. I never knew - I would 20 not think that she would fly on it without Mm. 21 O. Do you specifically remember her on the 22 airplane with him? 23 A. Can't say - I can't. 24 O. On any of these flights that Jeffrey Epstein 25 and/or Maxwell was on, did they fly internationally? • 0 ESQUIRE Toll Free: Facsimile: www.esquiresoiutions.corn EFTA00181400
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Larry Eugene Morrison - Volume I October 6, 2009 77 1 A. I know I brought her back one tine from 2 England. I believe • I remember that • from London. 3 Q. Brought Maxwell back from London. and was she 4 alone then? 5 A. I can't -- I can't say. I can't remember. 6 O. I thought you said that if she was on the 7 plane it wouldn't have been alone. 8 A. More than likely she would have been with 9 Jeffrey. 10 0. So do you think that you brought Maxwell and 11 Jeffrey together back from London? 12 A. More than likely, but I can't say for 13 sure. I can't remember if he was on that flight. 14 O. To the best of your recollection right now, as 15 we sit here, is that Maxwell was on the plane and Epstein 16 may or may not have been? 17 A. Correct. That's correct. 18 Q. What year are we taking about and whose 19 airplane are we talking about? 20 A. That would have been when the 727 was 21 still Limited - or Wexner. 22 Q. And that would have been around what year? 23 A. 2000. maybe. 24 0. 2000? 25 A. '99, something like that. 79 1 the Court to be well aware that not all of my form objections are corning through the 3 telephone. 4 MR. EDWARDS: Mike. how about this, of all 5 of the people involved, I think that you know 6 you can trust me here: II you say when wo read 7 this back that you wanted a form objection, I'll 8 put it on the record right now you get it • how 9 about that? to MR. PIKE: Not a problem. 11 BY MR. EDWARDS, 12 0. Alright Have you ever looked at any of the 13 information from Customs and Immigration related to 14 flight logs? 15 A. No, 16 0. If Customs and Immigration Is the right agency 17 to take control of these documents, who is it that 18 generates the documents in terms of personnel riding upon 19 this airplane? 20 A. Captain. 21 O. Who was the captain or who were the Captains 22 that you are aware of - and try to give me years, it many 23 of them changed. to the best of your knowledge • for 24 Wexner? 25 A. Primarily it would have been Tim Staley, 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 0. A. Q. A. Q. A. Q. A. 0. A. 0. right? A. No. MR. PIKE: Form. BY MR. EDWARD$: 0. Flying internationally? A. I don't know if the FAA gets that. It would more - most kkely be Customs and Immigration. MR. PIKE: Are you guys getting my form objections? MR. EDWARDS: Yes. We got you. MR. PIKE: Thank you. Brad. I just want on the record that nol all of my form objections are coming through. so if we have an issue with this deposition - I am on the phone • and I want 78 So this is almost into the transition - No, I'm sorry. - into it. Let me think on the dates. Okay. Yeah, I can't- I can't remember. Late '90s or 2000? Late '90s. Who has the flight logs from late '90s? I don't know. But that's something that the FAA would have, 80 1 Jim Taylor, Rob Imlay. 2 0. Rob? 3 A. Imlay, tat-LA-Y. Bill Hammond. 4 0. Bill Hammond? 5 A. Uh•huh. 6 0. Bill Hammond later becomes affiliated with Mr. 7 Epstein too, right? 8 A. Correct. 9 0. We're going to get to that. 10 Have you ever been a captain? 11 A. No. 12 0. And when you say that it's not necessary - 13 unless you're flying internationally, I know • but it's 14 not necessary to maintain a passenger manifest that 15 delineates the exact name, where are you getting that 16 information from? 17 A. I know it's not required by the FARs. 18 0. How do you know that? 19 A. Because you can read the FARs, Part 91, 20 FAR 91, Operations. 21 0. What's TAW stand for? 22 A. Federal Aviation Regulations. 23 0. And what would be the reason not to put the 24 whole name of the person on the airplane? 25 A. I don't know. I — I don't know. ESQUIRE •Pa la an Gallo Cala, Toll Free: Facsimile: N S www.eSquIreSOluti0nS.00M • • • EFTA00181401
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Larry Eugene Morrison - Volume I October 6, 2009 • • 81 1 O. Because later I'm going to show you some 2 lists, and certain people are listed by full name and 3 others are listed generically - any idea why that would 4 happen? 5 A. Unless they just don't know who it is. you 6 know, just a guess. I mean, you know, you don't want 7 to query somebody and give them the third degree if 8 it's just a guest of the boss that's, you know. 9 tiding along or something. 10 O. Well, she asked you your name before your 11 deposition and you didn't consider that the third degree 12 by any means, right? 13 A. Right, but 14 MR. PIKE: Objection to form. 15 A. But you're approaching your employers 16 guest. It would be like walking into his house and 17 asking him, "Who's sitting at the dining room table?' is - in a way. See what I'm saying? It's just You 19 have to maintain -- 20 O. But -- 21 A. — the employee/employer relationship. 22 O. No, no, no. I guess what I'm saying is: If 23 one of these people is Mohammed Ana, you would like to 24 know it, probably. 25 A. Well, yes. 83 1 A. It would be obvious that these are 2 associates of some form, that they're not, you know, 3 strangers trying to board the airplane. 4 O. So let's go back to that conversation that you 5 have in the Ohio hangar, or whatever it is, with David 6 Rodgers and Larry Visoski when they talked to you for the 7 first time about possibly switching over to Mr. Epstein. 8 A. Uhhuh. 9 O. How does that conversation really go about? 10 MR. PIKE: Form. 11 A. I don't understand. What do you mean, 12 'How did it go about" 13 O. Did you approach them and say, 'Hey, are you 14 going to stay here forever with this airplane? or 'Do 15 you have another job for me? or what? 16 A. I think it was just, you know. I believe 17 Larry approached me. I can't remember. It was that 18 long ago, but 19 O. What does Larry say to you? 20 A. I can't remember the exact conversation. 21 O. 1 mean, was he not happy where he was? 22 A. Who, Larry? 23 O. Yes. 24 A. Never said he wasn't. 25 O. How did you know Larry? 82 1 MR. PIKE: Form. 2 A. Yes, yes. 3 O. So any reason why a captain trying to secure 4 the airplane and the people aboard wouldn't take that 5 extra step and try to figure out who's exactly on his 6 airplane? 7 A. Well, when it's - the normal passenger 8 loads are five to ten people, at the very most, and 9 they're all with the owner and accompanying the owner 10 and some of the regular passengers, you know: the 11 likelihood that Mohammed Atta is going to sneak in 12 there and board his plane and ride along is - you 13 know. 14 O. He's willing to play those odds, okay. 15 A. Well, I'm not saying that he's playing 16 odds. I'm just stating that the only reason I can 17 think — I don't know. I've never filled those out. 18 The only reason I can think is he just didn't have 19 the name and didn't want to intrude and ask. 20 O. If you were a captain, would you ask who was 21 on your airplane? 22 A. Not if the situation was that it was 23 controlled by the owner and I knew who the - you 24 know. 25 O. Okay. 84 1 A. What are you talking about? Why would he 2 not be happy where he was? I don't understand. 3 O. Well, he's working for some other corporation 4 that's not non-Epstein owned. A. Oh, 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 buying that 15 plane. Do you want to be involved?' 16 A. No, no. There was another airplane in 17 between - Iwo other airplanes. There was a long time 18 between - and I don't know the exact dates and I 19 don't know that I even do know the dates - but there 20 was a time between when they left Glimcher before 21 Jeffrey got involved with the 727. 22 O. So they leave Glimcher? 23 A. Yes. 24 O. Then what happens*? 25 A. They somehow - I don't know how • hired on • 0 ESQUIl ea, Toll Free: Facsimile: www.esquiresolutions. corn EFTA00181402
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Larry Eugene Morrison - Volume I October 6, 2009 85 1 with Jeffrey. 2 O. They hired on with Jeffrey to pilot the 727? 3 A. No. He had two other airplanes prior to 4 that. He had a Hawker that ho had for a very short period and then he bought - traded it or sold it. I 6 don't know what he did with it, but then he got the 7 Gulfstream. 8 O. So Larry Visoski and David Rodgers were pilots 9 for Jeffrey Epstein when he had the Hawker also? 10 A. Yes. 11. O. And what year are we talking about there? 12 A. I have no idea. 13 O. Well, if you sign on with him in '91. it's 14 before that year. right? 15 A. No, no, I signed in '01 - January '01. 16 O. '01. 17 A. I don't know how long they flew for 18 Glimcher before that airplane went away and how quick 19 they got on with Jeffrey. I don't know. Somewhere 20 between '88 and 2001, they -- 21 O. During -- 22 A. -- left Glimcher and -- 23 O. During '88 and '01. do you remain in contact 24 with Larry Visoskl and David Rodgers? 25 A. On and off. They eventually moved, you 87 1 O. Before your conversation with them about 2 becoming involved with Jeffrey Epstein. 3 A. Yes. 4 O. How? A. Like we discussed. We've been through 6 this already. When they were at Glimcher they had an 7 airplane in the hangar. We would see them 8 sporadically and we would talk. 9 O. I'm sorry, bad question. I don't mean on a 10 business relationship. On a social relationship, did you 11 hang out with them -- 12 A. Oh, no. 13 O. -• outside of this? 14 A. No. no. 15 O. I apologize. 16 So • and I only asked that question because 17 some years tater then you're in contact with them and 18 they asked you to become involved with Jeff Epstein. 19 A. Uh-huh. 20 O. But that is because of a business relationship 21 solely that you had with them -- 22 A. Oh, yeah. 23 O. years before? 24 A. I didn't know them personally. 25 MR. PIKE: Form. 86 1 know, to • moved away from Columbus when they hired 2 on with Jeffrey, so they weren't in the hangar every 3 day. 4 O. Where did they go - do you know? A. I think Dave went to New York and Larry 6 went back to South Florida. 7 O. Do you know why? 8 A. Well, because I think Jeffrey gave them 9 the choice of living where they would like, I 10 believe. I mean, that's -- 11 O. That's what they've said. 12 A. That's what they've said. 13 O. Okay, and Larry chose South Florida, David 14 Rodgers chose New York? 15 A. Right. 16 O. And Epstein had a place for them both wherever 17 they wanted to go? 16 A. Well, they owned their own homes or 19 something. I don't know what their living 20 arrangements were. 21 O. Did you know Larry Rodgers or David Visoski 22 before this? 23 A. Before? 24 MR. PIKE: Form. 25 BY MR. EDWARDS: 88 1 BY MR. EDWARDS: 2 O. Okay. Alright. So in 2001, is that the year 3 that you get a telephone call from one or two of these 4 people? 5 MR. PIKE: Form. 6 A. It would be either late 2000 or early 7 2001. I don't -- These transactions don't happen 8 overnight -- 9 O. Yeah. 10 A. -- buying an airplane. So it could have 11 happened in, you know, November or started talking in 12 November, like, 'Well, you know, would you be 13 interested if Jeffrey gets the airplane or buys the 14 airplane?' you know, to when I actually hired on. 15 O. Did you ever talk to Ghislaine Maxwell - ever? 16 A. After I had hired on. yes. 17 O. After you hired on with Epstein. Is A. Yes. 19 O. We'll go up to her. 20 So when Is it that you hired on with Jeffrey Epstein? 22 A. I think I began in January of '01. 23 O. In January of 431. do you start getting a 24 paycheck from Jeffrey Epstein? 25 A. Yes. ESQUIRE Toll Free: Facsimile: I la www.esquIreso utions.com • • • EFTA00181403
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Larry Eugene Morrison - Volume I October 6, 2009 • • 89 O. And is it paid from one of his companies or 2 from Jeffrey Epstein specifically? 3 A. No, no - JEGE. 4 O. JEGE. What is your understanding as to what 5 that is? 6 A. It's just initials. It's a name. I don't ▪ have any idea what it stands for, but I'd ask that a • million times. 9 O. Irs a company that owns something, right? 10 A. I don't know -- 11 MR. PIKE: Form. 12 A. — Nit even owns anything. I don't know 13 what type of company it is. I don't know if It's 14 just a Wilmington, Delaware, company. 15 O. What's the bank account that it was written 16 on? 17 A. I can't remember. I mean. I know I'd read 18 - I'd see 'JEGE' on it, that's all. 19 O. A New Mexico bank, New York bank. Florida 20 bank? 21 A. I have no idea because it's direct 22 deposit. All I would do is just see if the amount's 23 right. I don't -- I have no idea. I would -- I have 24 no idea. 25 Q. What was your communication - direct 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 91 perform. O. On what planes? A. Just the Gulf - just the Boeing. O. Just the Booing? A. Uh-huh. O. Over the years, did you become aware that he owned other aircraft? A. I knew that he still had that. MR. PIKE: Form. A. He still had the Gulfstream. O. At the time back in 2001 - and we're going to walk through some of his airplanes - he owned the Boeing 727, right? A. Coned. O. And what other airplanes did he own at that lime when you signed on with him in 200t? A. The Gulfstream. O. Gulfstream is what? A. 2B. O. Do you know who the pilot was for that plane? A. Dave and Larry, I mean, it's always. O. Was it always Dave and Larry no matter what plane was being taken out? A. Unless somebody was on vacation or in school and they used contract people. 90 1 communication with Jeffrey Epstein that results in your 2 employment with JEGE? 3 MR. PIKE: Form. 4 A. A conversation result in my Essentially 5 Larry hired me. I mean, it wasn't - it wasn't -- 6 dkIn't really — I may have had one phone 7 conversation with Jeffrey prior to actually being 8 hired and the next time I saw Jeffrey was when I was 9 in Florida with the airplane. 10 O. What did Jeffrey ask you in that one phone 11 conversation? 12 A. I think he asked me what my current salary 13 was, or something along that line, you know. 14 O. Did he ask you what you were looking for in 15 terms of salary? 16 A. Yes. 17 O. What did you tell him? le A. I told him to basically .- I forget how it 19 went exactly. It ended up being like $117,000, 20 something like that. 21 O. $117.000 a year? 22 A. Yeah. 23 O. And what were your duties? 24 A. Basically • flight engineer, obviously, 25 but all line maintenance and scheduled maintenance to 92 1 O. What was the purpose behind having multiple 2 planes - used one for the purpose. one for another - do 3 you know? 4 A. I never could figure that out. 5 O. Really? 6 A. Yeah. 7 O. No rhyme or reason why he took one this way e and one that way? 9 A. No. He was • pretty much once the Boeing 10 got on line. Now, you know, the Boeing goes down for 11 heavy maintenance. It used to go annually, now It 12 goes down biannually. but - so he would utilize that 13 airplane while it was out of service, you know, for 14 maintenance, which sometimes would be lour, five 15 weeks at a time, so. 16 O. And in those cases, then he would use the 17 Gulfstream 2B? 18 A. Yes. 19 O. Have you been on both planes? 20 A Yes. 21 O. Were still talking about 2001. Is that the 22 first time that you're on the 727? 23 A. First time I was on the 727? Walt. I 24 don't know what you mean. 25 O. After Epstein owns it. • ESQUIRE Toll Free: Facsimile: EFTA00181404
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Larry Eugene Morrison - Volume I October 6, 2009 93 A. Yes. 2 0. And do you remember where you went? 3 A. Very first flight, no, because we didn't 4 fly it immediately. We upgraded some avionics and 5 did modifications. 6 0. What modifications did he want to that plane? 7 A. Just changed the carpet and some fabrics, a upgraded the radar, upgraded the navigation - the 9 flight manifest systems. 10 0. Did he change the interior at all? 11 A. No. We removed that one small table and 12 chair - that's it, but we did not really change what 13 you would consider the floor plan. 14 0. Now, try to give me a visual appreciation of 15 the inside of the plane. If I'm looking out the cockpit 16 back towards the back of the plane; what am I going to 17 see? 18 A. A door. 19 Q. That's it? 20 A. That's it, yeah. 21 0. Just an empty room with a door? 22 A. No, no. The doors always closed. If the 23 door's open you will see the forward salon, and in 24 the forward salon there Is a conference table, a 25 high/low table, some divans, and some single seats. 95 1 A. Can't remember the first eight. Like I 2 say. it was down fora while - probably - I think it 3 was - had to take at least three to four months maybe 4 to get it- s 0. And did you know of him flying on the aftplane 6 with girls accompanying him? 7 MR. PIKE: Form. A. I don't — 9 0. Back in 2001. 10 A. With girls accompanying him? 11 0. Yes. 12 A. Yes. 13 0. Where would he pick the girls up from? 14 MR. PIKE: Form. 15 A. $ don't know. They would arrive with him. 16 you know, out of Palm Beach or out of New York. I 17 don't even remember where we went the first time. 18 The first flight was probably New York, I think. 19 Q. Is it a private airport in New York where you 20 would usually pull into or a commercial airport? 21 A. I think the first time we started going up 22 there. I think, we were using White Plains, which is 23 - actually, it's not a private airport. They all 24 have some commercial service. It would have been 25 White Plains, I believe, then later we staled using 94 1 Q. What's behind that? 2 A. The galley. 3 0. The what? 4 A. The kitchen - galley. 5 0. Okay. 6 A. Behind that Is the aft salon. which is AIM two round divans. 0. And? 9 A. After that is the office, which is a - 10 Consists of a credenza and a desk, or divan and a 11 desk and chairs. 12 0. How many of these areas can you close of or 13 plant:In? 14 MR. PIKE: Form. 15 A. Each one. And after that there's the 16 state room. 17 0. And in the state morn - how big is the state 111 room? 19 A. Consists of a queen size bed and two 20 single seats. 21 O. Have you ever been back in the state room? 22 A. Oh. yes. Yeah. 23 0. When's the first time you flew on the airplane 24 with Jeffrey Epstein back in 2001, after he acquired the 25 727? 96 Kennedy, and the service was so terrible in Kennedy 2 and so expensive we went to Newark. 3 0. When you would fly into White Plains or to 4 Kennedy or Newark. would you always got of of the 5 airplane or would you sometimes stay on and wait for 6 passengers to board? A. I don't understand. 0. Well. when you stop an airplane -- 9 A. Right. 10 0. — sometimes you get off the airplane and you 11 go either through a. you know, through the airport or you 12 go somewhere else, or your option is to stay on the 13 airplane and not get off and wait for other people to get 14 on before you take of. 15 A. Oh, no. 16 MR. REINHART: I'm sorry, can we clarify 17 the -you'? Do you mean him personally or the le people who were passengers on the plane that ho 19 was flying? 20 0. I'm talking about you personally. 21 A. Oh, no, it was rare that we ever did a 22 through flight. Wo would normally go from Point A to 23 Point B. and that was the destination. 24 O. I assume when he buys the plane initially it 25 was in Ohio, right? ESQUIRE Toll Free: Facsimile: I MMEI www.esquiresolutions.com • • • EFTA00181405
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Larry Eugene Morrison - Volume I October 6, 2009 • • 97 1 A. Well, yeah, but -- 2 Q. Then you fly to Florida. 3 A. Well, we crewed it to Florida and then it 4 sat at a facility in Florida during negotiations, so 5 it didn't go directly from Ohio. 6 O. In 2001, when there's still negotiations. 7 where in Florida is the airplane? 8 A. Lake City - Timco, Lake City. 9 0. During the negotiations, does it ever take off 10 or is it grounded? 11 A. No. no, its grounded, because on a Part 12 91 deviation it has to be under a specific 13 maintenance program, so when it left The Limited, it 14 left that maintenance program, and I had to 15 transition it to the new program. 16 O. This is still sometime in 2001, right? 17 A. Early, yes, yes. 18 O. And then it passes all inspections, I'm 19 assuming? 20 A. Right, right. 21 Q. Then you take it to what airport to where 22 it -- 23 A. PBI. 24 Q. FBI? 25 A. Here in West Palm. 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 99 O. Who's on the airplane? A. Wel, obviously it would be Jeffrey. O. Right. A. I can't remember who all went. O. Who were the pilots? A. I can't remember that either. O. Larry? A. No. MR. REINHART: Hold on. A. It would have been myself, for sure - because I was the only one with experience on the airplane - myself. Dave, I believe, would have been captain because he had been schooled, but I can't remember if Larry took first flight or not. I think he was still in training. O. Where did you go? A. I can't remember. MR. PIKE: Form. A. I can't remember if it was New York or I would imagine it would be New York, but I can't remember. O. When you say you would imagine New York, I'm getting the impression that many of the flights went to and from New York. A. Yeah, primarily. 98 1 O. While it's at PBI airport, does it take off 2 from there? 3 A. No, not for — That's when we were doing 4 the modifications and upgrades. We were doing the 5 avionics. 6 O. How long did that take? 7 A. I don't remember the exact time • maybe 8 three to four months. 9 O. Who does it with you? 10 A. Jet Aviation. Jet aviation did the 11 avionics and soft goods. 12 O. And when you say the 'soft goods; what do you 13 mean by that? 14 A. Carpet, fabrics, leather, you know, 15 different things like that. 16 O. When's the first time it takes off then on a 17 real flight - some time in 2001, but mid-year or 18 something? 19 A. Probably mid•year, maybe a little earlier 20 than mid-year. 21 O. We're talking about June of 2001? 22 A. Right. 23 O. And where do you go? 24 A. Can't remember. I can't remember for 25 sure. 100 1 O. So if - 2 A. And -- 3 O. So any time you're having to guess where it's 4 going, you're saying New York because that's the primary 5 place it's going. 6 A. Correct. I would have remembered — I -- 7 I know I didn't get — I had heard about St. Thomas, 8 but I hadn't been there right away. I didn't get to 9 go to St. Thomas for a while. 10 O. That's later on in the story. 11 A. Yes. 12 O. We'll get there. 13 So you go to New York. Does he tell you the 14 purpose behind going to New York? 25 A. No. 16 O. Prior to this trip to New York, have you had a 17 personal conversation with Jeffrey Epstein? 1,3 A. No. 19 MR. PIKE: Form. 20 BY MR. EDWARDS: 21 O. Never? 22 A. Not personal. Everything is 23 business-related. 24 O. Okay. but -- 25 A. I mean, it was about the interior work or • 0 ESQUIRE Toll Free: Facsimile: www.esguiresolutions.com EFTA00181406
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Larry Eugene Morrison - Volume I October 6, 2009 101 1 the avionics going in, but never personal. 2 0. But, I mean, you've been hired by him -- 3 A. Right. 4 0. — you agreed on a salary, he's going to pay s you the salary, but other than that, and what maintenance 6 may be required -- 7 A. Correct. 8 Q. on the airplane, nothing else? 9 A. He's a very -- His conversations are 10 usually very short. He doesn't, you know, lake much 11 time. 12 0. When you would have conversations with him, 13 would they be over the telephone or would they be in 14 person? 15 A. It could be in both. If he was in Florida 16 and I wanted to actually show him a fabric or a 17 sample for the airplane or he wanted to view how it 18 was coming, but oftentimes it would be via telephone 19 from New York. 20 0. When it would be in person, would you see him 21 surrounded by or be accompanied by a girl or girls? 22 MR. PIKE: Form. 23 A. At times, yeah. 24 Q. Would any of those girls be Ghislaine Maxwell? 25 A. At times, yes. 103 1 know, business relationship too. 2 0. Did you know who Ghislaine Maxwell was? 3 A. Not right away, no. no. 4 0. Not right away? 5 A. Right. 6 0. At some point in time you were curious enough 7 to make an attempt to find out. A. No, I 9 MR. PIKE: Form. 10 A. -- heard about her and there was a book up 11 in New York in the apartment that we stayed in that 12 was -- You know, you're sitting there with nothing to 13 do, I read that. 14 0. Do you remember the name of the book? 15 A. It was just -Maxwell.' 16 0. Have anything to do with her father? 17 A. Yeah, it was about him, that's what it was is about. I mostly just flipped through looking at 19 pictures, boats, and airplanes and stuff. 20 0. Back in 2001. the first time you had a real 21 conversation with Ghislaine Maxwell -- 22 MR. PIKE: Form. 23 A. Yes. 24 0. — what old that conversation consist of, if 25 you remember? 102 1 Q. Would any of those girls look extremety young 2 to you? 3 MR. PIKE: Form. 4 A. Not — Not that I thought. 0. Not back in 2001. we're talking about? 6 A. Right, right. 7 0. No. What would Ghislaine Maxwell say to you, if 9 anything? 10 MR. PIKE: Form. 11 A. She'd Mostly small talk, just She 12 kind of rid the business management pan of it as far 13 as, you know, arranging cell phone - I was having 14 cell phone problems with the company cell phone, she 15 would handle things like that, but she would have 16 minor inputs on the interior work. 17 0. What was your understanding back in 2001 still 18 of the relationship between Ghislaine Maxwell and Jeffrey 19 Epstein? 20 MR. PIKE: Form. 21 A. I really didn't understand it. I thought 22 it was personal - personal and business. 23 0. When you say 'personal; did you think it was 24 sexual? 25 A. I thought maybe they were dating and. you 104 1 A. I think it was concerning getting a cell 2 phone and a pager - that's it. 3 0. Did it have anything to do with underage 4 girls? s A. Absolutely not, no, no. 6 0. That's not something the ever shared with you? 7 A. No. no. 0. Did Jeffrey Epstein ever share with you that 9 he wanted underage girls -- to A. No. 11 0. — in any way? 12 A. No. 13 MR. PIKE: Form. 14 BY MR. EDWARDS: is 0. I mean, certainly I'm not saying something to 16 you that's an absolute shocker right now -- 17 A. Right. 18 0. considering the newspaper articles. 19 A. Right, but I know -- You have to 20 understand, every conversation I had was pretty much 21 business, just to deal with the airplanes. You know, 22 I'm an employee/employer relationship. 23 0. I just don't want you to think I'm just asking 24 random off the wall questions 25 A. Right. 0 ESQUIRE *landau Gale Canny Toll Free: Facsimile: www.esquiresolutions.com • • • EFTA00181407
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Larry Eugene Morrison - Volume I October 6, 2009 • • 105 1 O. that have nothing to do with anything. 2 A. I understand. 3 O. 2001. you start working for him, and that June 4 or so is the first flight, and you believe it's to New 5 York. 6 A. Correct. 7 O. Do you remember the purpose behind the flight? 8 A. No, did not know the purpose. 9 O. Did you get off the airplane in New York? to A. Yes, yes. 11 O. Where did you go? 12 A. Probably to - into the city, into the 13 city, and he has an apartment building up there that 14 we would stay in in the city. 15 O. Is it paid for by Jeffrey Epstein? 16 A. What? 17 MR. PIKE: Form. 18 BY MR. EDWARDS: 19 O. The apartment. 20 A. Well, he -- It's -- I think it's in the 21 building he owns. I mean, I just — I don't know. 22 O. Do you remember the address? 23 A. 301 East 66. 24 O. 301 East 66 Street, right? 25 A. Right. 107 1 building. I've been to the buiking. The building is 2 huge. 3 A. I don't know. I don't know if he owns the 4 building or just • or how many units he's got. Maybe 5 ten, because I think some of the employees up there 6 live in them. 7 O. Do you remember who some of the other 8 employees are that live in that building? 9 A. Well, I think Darren used to live in it, 10 Darren Indyke. 11 O. Darren Indyke, right. 12 What about. do you remember her? 13 A. lived in there. 14 O. What abOulMINIEll 15 A. I don't know in lived in there or 16 not. 17 O. You know who that is. though. Is A. Right, right. Actually, she was just kind 19 of corning into the picture when I was - about the 20 time when I was leaving. 21 O. What about Ghislaine Maxwell? 22 A. No. no, she didn't live there. 23 O. What about Joan Luc Brunel? 24 A. No. 25 O. How about: Did Mark Epstein ever indicate to 106 1 O. Did he ever mention a brother that he may have 2 to you? 3 A. I met his brother, I think, once. 4 O. What's his name? 5 A. I can't remember. 6 O. Mark? 7 A. I remember meeting. 8 O. Mark Epstein strike •• 9 A. Honestly. I can't say for sure. to O. And how do you know that Jeffrey Epstein owns 11 the apartment building at 301 East 66 Street? 12 A. Larry told me. I mean, it was just kind 13 of known. 14 O. Larry told you -- 15 A. Yeah. 16 O. — or Jeffrey told you? 17 A. Oh, no, not Jeffrey. no. Larry. I is wouldn't have asked Jeffrey. 19 O. How many of those apartments up there In New 20 York is it your understanding that Jeffrey owns? 21 MR. REINHART: I'm sorry, are you asking 22 how many units are in the building or how many 23 buildings? 24 BY MR. EDWARDS: 25 O. No, how many units that Jeffrey owns in the 108 1 you that he had any ownership in any of that? 2 A. Oh, no. I only saw him one time on a 3 short flight. I don't even know where we - we were 4 probably taking him to and he was just - Jeffrey 5 introduced him as his brother and it was very short, 6 you know, just, 'Oft, hi. How are your, and he went 7 in the back. 8 O. Do you know anything about the guy? 9 A. Uh-uh. 10 O. Nothing? 11 A. Nothing. 12 O. So in 2001, there's a flight up there at some 13 appointment in time, and you get off and you stay at one 14 of the apartment buildings at East 66 Street. 15 A. Right, right. 16 O. And did you meet any of the neighbors of the 17 apartments that are also owned by Jeffrey Epstein? 18 A. No, no, because when we're there it's 19 usually just for a night or something and then, you 20 know, we're either airkning home or going on. 21 O. How did you know Darren Indyke? 22 A. He's our •- He's our business attorney for 23 JEGE. 24 O. Do you remember any of the other tenants of 25 the apartments allIMIMIllother than Darren • 0 ESQUIRE Toll Free: Facsimile: EFTA00181408
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Larry Eugene Morrison - Volume I October 6, 2009 109 Indyke and A Not that I remember, no. Q How about IMM? A. I don't think lived there. 5 O. Do you remember that name? 6 A. Yes. 7 Q. What about Cecelia Stein? 8 A. Cecelia Stein. no. I don't think so. 9 O. Jeff Fuller? 10 A. I don't know Jeff Fuller. I don't even 11 know Jeff Fuller. 12 O. Do you know the name Jean Luc Brunel? 13 A. Yes. 14 O. How do you know that name? 15 A. Ho's been He was a passenger on a few 16 of our flights. 17 Q. Do you know why? 18 A. 1 think he was -- I don't know for surd. 19 He's in a modeling business with Mr. Epstein, I 20 believe. 21 Q. MC2? Do you know that name - MC2 Modeling 22 Agency - used to be Karin Modeling Agency, now its MC2? 23 A. No. 24 O. How do you know about his and Mr. Epstein's 25 modeling agency? How do you know that? 111 1 of the MC2 shoots? 2 A. I never heard •• There was one incident -- 1 The only thing I remember about it is they were on a 4 shoot - and ifs not funny, but Jeff - but it is in a s way - they were in a motor home on location at the 6 shoot, and they started to drive off and one of the 7 models asked to use the restroom and they told her B which door it was and she went out the side door, so 9 grabbed the wrong door, but that's actually the only 10 thing that sticks in mind was that ono. 11 Q. Have you ever done any research on Jean Luc 12 Brunel? 13 A. No. 14 Q. Do you have any idea that he's known is throughout Europe as somebody who has sex with underage 16 girls/ 17 A. No. la O You dint know that until right now? 19 A. Correct. 20 O. That's something that you're teaming as a 21 surprise to you. 22 A. Yes. 23 Q. So Cecelia Stein - somebody you never heard 24 Or 25 A. It sounds familiar. I'm trying to place 110 1 A. Just every once in a while he would say 2 something about, you know, one of the model shoots or 3 something. We normally had him on • we would take 4 him back and forth to Paris. 5 O. Where some of their models come Irom? 6 A. I don't know. 7 O. Did you ever bring some of the Pans models a back? 9 A. Not that I'm aware of, no. 10 MR. PIKE: Form. 11 BY MR. EDWARDS: 12 O. So he would go to Paris on the airplane, Jean 13 Luc, would you drop him off there or would you pick 14 people up and bring them back? 15 A. If I remember, normally we were bringing 16 Jean Luc from Paris to New York, if I remember. 17 O. And when you say that the modeling agency - 18 obviously that, you know, between him and Mr. Epstein • 19 is that something that Mr. Epstein would talk to you 20 about or is that something that Joan Luc would talk to 21 you about or you would just overhear the two? 22 A. Overhear the two, or Jean Luc may say 23 something about ono of the shoots or something, just 24 in general conversation. 25 O. And what would Jeffrey's comment be about some 112 1 her. I don't know it she works in the office or — 2 O. Or worked in the office? 3 A. Worked in the office, yeah. I very rarely 4 went to the office. I mean - 5 O. 6 A. 7 O. 8 A. 9 O. 10 11 A. 12 13 14 15 O. Did Mr. Epstein ever once mention to you that 16 he likes massages? 17 MR, PIKE: Form. 18 A. No, he never mentioned that to me. 19 O. That's not something that you ever heard of, 20 right? 21 A. Well, I -- 22 O. 1 mean, outside of the articles that you've 23 read. 24 A. Right. No, but he never came up to me and 25 said, 'I like massages.' - how do you know her? From the flights • being on the airplane. How many times was she on the airplane/ Quite a few. Almost every. 0 ESQUIRE Toll Free: Facsimile: www.esquIresolutIons.com • • • EFTA00181409
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Larry Eugene Morrison - Volume I October 6, 2009 • • 113 1 O. And did 2 3 what she may call 'work" Of *massages" for Epstein? 4 A. No, no, I don't. 5 MR. PIKE: Form. 6 BY MR. EDWARD$: 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 O. We're still talking about a time period back in 2001, right, in these -- A. No. IM - I don't remember- coming into the picture until later. O. Later in 2000-something? A. No, she wasn't around at first. O. Alright. 114 1 A. No. I don't remember when exactly -- 2 but she -- 3 O. Who was making the arrangements for meetings 4 and such prix. -- 5 A. Ms. Maxwell. 6 O. - that you remember? 7 So Maxwell was Ihe, for all intents and 8 purposes 9 A. For all intents and purposes, yes. 10 O. And did you ever hear of Ms. Maxwell making II arrangements for massages or for girls or anything else? 12 A. No. 13 MR. PIKE: Form. 14 BY MR. EDWARDS: 15 O. Where were the conversations - whether it was 16 travel or whatever else - that was occurring between 17 Maxwell and/or-? Where were they taking 18 place - on the airplane, some office? 19 A. Yeah. No, no. usually in the cockpit, you 20 know, prior to departure, en route stating, 'We've 21 got this many cars and I've contacted' or "Can you 22 call such and such to have this brought out?' 23 O. Did you ever see Epstein work a lot? 24 MR. PIKE: Form. 25 A. He always had a briefcase with him and he 115 1 always sat it by his office in the back. 2 O. Always had a computer? 3 A. No, no, it's just a large briefcase. 4 O. Did you ever know his email? 5 A. Yeah, I had it I can't remember what it 6 was and I don't think it's even current - but when I 7 would have to send him e-mails about the interior or 8 maintenance issues. It was jeprojects, or something 9 like that, at -- I don't know if it was at Yahoo or 10 gmail. I don't think it was gmail. 11 O. You think it was jeprojects? 12 A. I believe so, but I can't remember what 13 service. 14 O. At gmail.com or something? 15 A. Or something like that or Yahoo or 16 something. 17 O. How about Ms. Maxwell? 18 A. It was I think. 19 O. Do you know if that's still current? 20 A. No, I don't. 21 O. How about 22 A. I had it at one time and I know she 23 changed it and I don't know what it is. I can't 24 remember what it was, actually. 25 O. Do you know =El • where she is 116 1 right now? 2 A. No. 3 O. Do you know if she's intentionally on the lam 4 to try to avoid being deposed in this case? A. No. 6 MR. PIKE: Form. 7 A. No idea. I haven't had any contact with 8 MI since I stopped flying. 9 O. You say that =was just coming in the 10 picture - is the words that you used. What did you mean 11 by this? 12 A. Well, I mean she was just — I'm trying to 13 remember when I first started seeing her on the 14 airplane. I think it was not too long before I quit 15 flying. I can't remember the exact date. 16 O. When did you stop flying? 17 A. In February of '07. 18 O. February '07? 19 A. Yep. 20 O. And you don, think you saw her on the 21 airplane until before that? 22 A. No, rm saying she was only coming into 23 the picture like maybe six months before that or so 24 or I donl know for sure. 25 O. You don't remember seeing her on the airplane • 0 ESQUIRE Toll Free: Facsimile: www.esquIreso utIons.com EFTA00181410
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Larry Eugene Morrison - Volume I October 6, 2009 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 117 in 2031, 2002,2003? A. Oh, no. not that early. O. Do you know where she came from? A. Just what I've read in the paper - an eastern country. I'm sorry. I don't remember the country. O. Were you ever told that Mr. Epstein is that something that you ever heard? A. No. I did read something like that in the paper, but, no, never heard of that. O. Did you over see him and her sexually involved on the airplane or otherwise? A. No. O. Did you ever see Epstein involved sexually with anybody on the airplane? A. No. O. Did you ever see the airplane used for sexual purposes? A. No. MR. PIKE: Form. BY MR. EDWARDS: O. If it had happened - considering the various areas that were cordoned off or blocked off - would that 119 1 A. No. 2 O. — in the back of the airplane. 3 A. No. 4 O. So anything could go on. You would have no 5 idea. 6 MR. PIKE: Form. 7 BY MR. EDWARDS: 8 O. You could sit here and testify truthfully, 9 have no clue what's going on back them.' to A. That's correct. That's correct. 11 O. Darren Indyke - what's your understanding as 12 to his involvement with Mr. Epstein? 13 A. An attorney for the company. 14 O. Ever met Alan Dershowitz? 15 A. I think Yes. 16 O. How did you meet him? 17 A. Alan Dershowitz. I don't know if it was 18 Mr. Goldberger or Alan Dershowitz. We brought some 19 attorneys down -- 20 O. Why? 21 A. -- to Florida one time. 22 O. Why? 23 A. For Mr. Epstein. It was right before I 24 finished 'tying. For Mr. Epstein to make an 25 appearance at the courthouse or a meeting or 118 1 have even been something that you could have seen? 2 A. No, no, if it was - if the doors were 3 closed, no. 4 O. So there's a back room that you've described 5 that has a bed in it, and if that doors closed you don't 6 know what's going on behind closed doors. right? 7 A. That's correct. a MR. PIKE: Form. 9 BY MR. EDWARDS: 10 O. Do you remember a time Epstein was back in 11 that back room with other people? 12 MR. PIKE: Form. 13 A. No. 14 O. Are you saying it never happened while you 15 were on the airplane? 16 A. I really have no idea of knowing because, 17 one, we never go back there unless we're invited 18 back. 19 O. Okay. 20 A. And the forward door - the very forward 21 salon door is closed, so we never even normally go 22 8110 that - 23 O. So you don't really know -- 24 A. -- without permission. 25 Q. You don't really know what happens -- 120 1 something, and we brought some attorneys with him. 2 O. And were you aware then of the allegations 3 against Mr. Epstein? 4 A. They were starting to brew, yes. 5 O. Were you still actively working on his payroll 6 at the time when the investigation was going on? 7 A. Yes, when it just started. 8 Q. And did that impact you in any way as to 9 whether or not you wanted to be affiliated with this 10 person? 11 A. Subconsciously, it may have. And it 12 wasn't because of this person, but as a business 13 decision, if, you know, an airplane's not needed and 14 I don't fly, I could be out of work. But, no, the 15 Oman/ reason was the fact that I did want to get 16 off the road and back home. 17 O. Do you have children? 18 A. Yes. 19 O. How old? 20 A. A daughter 28, son 24, and a daughter 17 - 21 all with the same bride - 31 years. 22 Q. I'm assuming you're aware of the factual 23 allegations in these Complaints? 24 A. Yes, yes. 25 O. And you are aware that there are hundreds of Toll Free: Facsimile: ESQUIRE www.esgulresolutIons.com • • • EFTA00181411
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Larry Eugene Morrison - Volume I October 6, 2009 • • 121 1 girls who are underage who claim to have had sex with Mr. 2 Epstein as well as Ms. Maxwell at various times? 3 MR. PIKE: Form. 4 A. I was only aware of — First time I was s made aware of it, of the number of people, was when 6 they served me the subpoena. The deputies or 7 retired O. Yes. 9 A. -- private eyes told me that. That was 10 the first I had heard a number. 11 O. Were you completely oblivious that this was 12 going on? And by •this' I mean Epstein and/or Ghislaine 13 Maxwell and/or recruiting 12, 13, 14. 14 15-year-old girls to his house for sex? 15 A. Absolutely I was oblivious to it. 16 MR. PIKE: Form. 17 BY MR. EDWARDS: 18 O. If young girls were on an airplane that you 19 were on - considering that we've now established how the 20 airplanes set up and you're kind of cordoned off - is it 21 possible that underage girls would have been on the 22 airplane and you just wouldn't have known about it? 23 MR. PIKE: Form. 24 A. No. no. I mean, people don't board the 25 airplane with • you know, and then Just say, 'Close 123 1 O. Okay. I'll ask it a different way. 2 A. Because we have had -- You know. he's got 3 a goddaughter and godson that were young, I mean. 4 O. Okay. Over the years -- 5 A. I mean, I don't know what Me purpose -- 6 O. Right. I totally understand what you're 7 saying. 8 Over the years. when you were on Jeffrey 9 Epstein's airplane, were you aware between 2001 and 10 wherever you stopped. 2007 -- 11 A. Seven. 12 O. •- were you aware of girls that appeared very 13 underage on the airplane? la A. No. is MR. PIKE: Form. 16 BY MR. EDWARDS: 17 Q. I'm not saying what was happening on the 18 airplane. I'm just saying, were you aware of it? 19 A. No. not • unless they were there, like I 20 said, his goddaughter at the time. One time - a 21 couple times wo flew her with her mom and dad where I 22 don't even know their age. 23 MR. PIKE: Again, form, asked and 24 answered. 25 A. Six or seven. But, no, I was not aware of 1 2 3 4 5 6 7 9 10 1.1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 122 the door, we're going." You know, you see who boards the airplane. Q. So if there were flight records that show underage girls on the airplane, you would know about it? MR. PIKE: Form. A. Not necessarily. O. Well, how not? MR. REINHART: I'm sorry. A. Wel, how do you -- MR. REINHART: When you say "them," do you mean he would know about the records or he would know about the girls allegedly on the plane? BY MR. EDWARDS: O. You would know about the underage girls on the airplane if they wore on there. MR. PIKE: Form. A. How do you How would I know that they're underage, though? O. Welt, you would only know that they look extremely young, right? A. But -- MR. PIKE: Form. A. — what is the intent of them? I mean, are they guests or are they friends of his associates 124 anybody that was obviously, blatantly underage. 2 O. Any famous people that you can tell me that 3 were on the airplane? 4 A. President Clinton - Ex-President Clinton. 5 O. Were you on the airplane 6 A. Yes. 7 O. -- when he was on it? 8 A. Yes. 9 O. Hew many limes? 10 A. Two trips. I mean, two extended trips. 11 O. Where did it go? 12 A. The first one - or the first one was Asia. 13 O. What purpose? 14 A. I forget what the purpose was on that one. 15 O. Was Jeffrey Epstein on the airplane as well? 16 A. Yes, yes. 17 O. Who else was on the airplane then? 18 A. I don't remember on that one. It was 19 primarily him and his support staff. 20 O. Was 21 A. Probably, yes, probably. 22 O. When's the next time President Clinton was on 23 his airplane? 24 A. I don't remember the date, but we did a 25 Africa trip, an AIDS awareness tour. We did like ten • ESQUIRE Toll Free: Facsimile: www.esquiresoluttons.com EFTA00181412
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Larry Eugene Morrison - Volume I October 6, 2009 125 1 countries in 12 days. 2 O. Is that a time Chris Tucker •- 3 A. Yes. 4 O. and Kevin Spacey were also on it? 5 A. Yes. 6 O. In addition to the people that we've named. 7 were there females on that airplane? A. Yes. 9 O. And who were the females that wore on the 10 airplane? 11 A. Can't remember. Ms. Maxwell. =, I can 12 remember, and a couple others, and there's - Mr. 13 Clinton had - a couple of his support staff were 14 women also. 15 Q. Where were you sitting during these trips? 16 A. Up front in the • my station. 17 O. Could you see what they were doing where you 18 were? 19 A. No, no. 20 O. Could you tell if there was any sex going on 21 on the airplane while you were on it? 22 A. No. 23 MR. PIKE: Form. 24 BY MR. EDWARD$: 25 O. Do you know of any underage girls being on 127 1 MR. EDWARDS: No. I mean, unless 2 everybody wants to take a lunch break. 3 Everybody's shaking their heads, so, no, I'm 4 going to take a bathroom break, and it's going 5 to be a fast one. 6 MR. PIKE: Okay. 7 BY MR. EDWARDS: O. In 2001, when you're on this flight to New 9 York and then during that year we talked a little bit 10 about it, is Larry Visoski and David Rodgers also on some 11 of these flights? 12 A. Most, yes. 13 O. If somebodys going to keep passenger logs, 14 who's going to write down the names of the people? Is 15 that going to be you o is that somebody else's 16 responsibility? 17 A. Whoever is captain. 18 O. So normally it's Visoski or David Rodgers? 19 A. Correct. 20 O. Who do you turn these logs into? 21 MR. PIKE: Form. 22 A. I don't know. I don't know where they go. 23 O. You don't know the purpose behind keeping them 24 or anything? 25 A. No. 126 1 that airplane or would you have been able to tell? 2 A. No. 3 MR. REINHART: I'm sorry MR. PIKE: Asked and answered. 5 MR. REINHART: -- are you limiting it to 6 that trip? 7 BY MR. EDWARDS: 8 O. To that trip. 9 A. No, I'm not aware of it. 10 O. If you had been aware of underage girls being 11 transported on the airplane for the purposes of sex, 12 would you have said something to somebody? 13 A. Yes. 14 MR. PIKE: Form. 15 MR. EDWARDS: Do you mind if we take a 16 five-minute break? I just have to run to the 17 bathroom. 18 MR. PIKE: Actually, Brad, can you hear 19 me? 20 MR. EDWARDS: Yes. 21 MR. PIKE: How much longer do you 22 anticipate going with this witness? 23 MR. EDWARDS: Hour, maybe a little longer. 24 MR. PIKE: Welt, are you going to take a 25 lunch break or what? 126 1 Q. As far as you're concerned, you don't even 2 need to keep them. 3 A. Correct. Yeah. 4 Q. As just due diligence - going above and 5 beyond? 6 A. Correct. 7 Q. Today you have an attorney sitting right next 8 to you. right? 9 A. Correct. 10 Q. Is that somebody that you've known for a long 11 time? 12 A. No. 13 Q. You're paying for an attorney to sit here with 14 you? 15 A. No. 16 Q. Who's paying for your attorney? 17 A. Mr. Epstein. 18 O. Are you worried that you're criminally 19 involved here or something? Is that why you need an 20 attorney? 21 A. No. I don't even know anything about this 22 process, that's -- 23 O. Oh, okay. 24 A. IM just -- You know. 25 O. How did you know that you were -- Toll Free: Facsimile: ESQVffig www.esquiresolutions.com • • • EFTA00181413
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Larry Eugene Morrison - Volume I October 6, 2009 • • 129 1 MR. PIKE: Brad. Brad. Brad. 2 O. - going to get an attorney 3 MR. REINHART: Brad, hold on. 4 MR. PIKE: Whoa. Whoa. Stop. 5 MR. EDWARDS: I'm listening. 6 MR. PIKE: Brad. 7 MR. EDWARDS: Go. 8 MR. PIKE: You are not allowing the 9 witness to finish his statements throughout this 10 entire depo. Please. I'm on the phone. You 11 start your question before the witness is 12 finished. I'm sony for raising my voice, but 13 you must allow the witness to finish his answer, 14 please. 15 MR. EDWARDS: You got it. 16 THE WITNESS: What was your question now? 17 Iforgot. 18 MR. EDWARDS: I'm sitting here looking at 19 the witness and have a feeling we're going to be 20 sitting here for 30 minutes, but I will do that 21 for you, Mr. Pike. 22 MR. PIKE: Alright. 23 THE WITNESS: What was the question again, 24 please? 25 MR. EDWARDS: Can I ask the question again 131 1 this case against Mr. Epstein? 2 MR. REINHART: Let me ask him not to 3 answer that. 4 MR. PIKE: Form. 5 MR. REINHART: It's privileged. 6 MR. EDWARDS: It's privileged between Mr. 7 Epstein and you, but is it privileged between 8 the two Of you? 9 MR. REINHART: Between Mr. Morrison and 10 me. 11 BY MR. EDWARDS: 12 O. Is it your understanding that he represents 13 you or he represents Mr. Epstein? 14 A. He represents me. 15 O. Okay. Do you think that you've done anything 16 wrong criminally? 17 A. No. 18 O. Do you think that you're being sued civilly? 19 A. No. 20 O. And you have no reason to be sued civilly, 21 right? 22 A. Correct. 23 O. Did you talk to Mr. Epstein prior to taking 24 your deposition today? 25 A. Oh, no. I haven't talked to him in well 130 1 or wait? I'll wait for you. 2 MR. PIKE: If I'm ready. 3 MR. EDWARDS: I already asked the 4 question, so we're waiting. MR. REINHART: I think the witness asked 6 you to repeat the question. 7 MR. EDWARDS: Are you good? Alright. 8 BY MR. EDWARDS: 9 O. Who hired your attorney? 10 A. Mr. Epstein. 11 O. And do you have any idea why, If you're a 12 witness in a case - no problems criminally - why you 13 personally have an attorney paid for by Mr. Epstein to 14 sit here with you? 15 MR. PIKE: Form. 16 A. No, I don't. 17 O. Do you want an attorney to sit here with you 18 while I ask you questions? 19 MR. PIKE: Form. 20 A. I don't know what the proper protocol is. 21 O. Okay. 22 A. I have very limited exposure to anything 23 like this. 24 O. How did this come about to where you have an 25 attorney as a witness - completely innocent witness - in 132 1 over a year-and-a-half, maybe two years, and that was 2 just a "hello' because I'm at the airplane one day. 3 O. So how is it you know that Mr. Epstein paid 4 for your attorney? MR. REINHART: It's privileged. 6 MR. EDWARDS: Okay. That answers my 7 question. 8 BY MR. EDWARDS: 9 O. Have you ever met Donald Trump? 10 A. Yes. 11 O. How? 12 A. He was He boarded the airplane one day 13 when ours was on the ramp. 14 O. And did you talk to him? 15 A. Just he introduced himself and I 16 introduced myself. 17 O. And did he talk to Mr. Epstein? 18 A. No. Mr. Epstein wasn't present. I was 19 doing maintenance. 20 O. And did he fly on the plane? 21 A. No. 22 O. Not that time? 23 A. Never. 24 O. You think he never flew on the plane? 25 A. On our airplane? ESQUIRE •n Al RA bit I 0•1:• (wens/ Toll Free: Facsimile: www.esquiresolutIons.com EFTA00181414
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Larry Eugene Morrison - Volume I October 6, 2009 133 1 O. Yes. 2 A. No. 3 O. So if somebody has given testimony other than 4 that, you would say that person is mistaken or lying? 5 MR. PIKE: Form. 6 A. Donald Trump was never on the airplane 7 when I was on the airplane. O. Is it your understanding that Donald Trump is 9 friends with Mr. Epstein? 10 A. From what I've read - or associates. I 11 don't know how that circle works. 12 0. What's your understanding as to who Mr. 13 Epstein's real friends are? 14 A. I really don't know. I don't I don't 15 know. It's It's not like the Wexners where, you 16 know, they were high school associates, you know. 17 growing up. le O. Do you know what Mr. Epstein did prior to 19 managing the money for Mr. Wexner? 20 A. Just that he was a Wall Street broker or 21 somebody, you know. 22 O. Also from reading? 23 A. Yes, yes. 24 O. Do you know any personal knowledge as to what 25 Mr. Epstein has told you about how he made money? 135 A. I have no idea I don't know. O. When you say that was just 3 mini in the picture. what's your understanding as to 4 who is relative to Mr. Epstein? 5 A. I don't know. I don't understand. I 6 don't know. I didn't know if maybe she was lace an 7 exchange -- Jeffrey always appeared to be very involved in education and philanthropy. I didn't 9 know if she was an exchangeiypo student or something 10 or what. I don't know. 11 O. When you say he appeared to be 'involved in,' 12 what do you mean? 13 A. Educational things. foundations, science 14 foundations. and things. 15 O. Speaking of • the Florida Science Foundation 16 is a place where. Mien he was on work release. he spent a 17 lot of time there, you're aware of that? 18 A. That's what I've heard, yeah. 19 O. What does that place do? zo A. I have no idea. 21 O. Does it do anything? 22 A I don't know. I don't know anything about 23 it. 24 O. Certainty you've read certain newspaper 25 articles about the allegations. police reports. 134 1 A. He's never - 2 MR. PIKE: I'm going to move to strike any 3 responses relative to what the witness haS 4 learned from reading. BY MR. EDWARD$: 6 O. And so that is why I asked the question Has 7 Mr. Epstein told you? Which would have nothing to do 8 with reading. 9 A. No. 10 O. How many conversations have you personalty had 11 with Mr. Epstein? 12 A. No personal conversations - all business. 13 O. Have you witnessed Mr. Epstein with any girls 14 that look to be under the age of 18? 15 A. No. 16 O. Have you witnessed Mr. Epstein with 17 young-looking girls that appear to be in their twenties? 18 MR. PIKE: Form. 19 A. Yes. 20 O. On how many occasions? 21 A. Probably several. 22 O. And how did that come about? 23 A. I mean, they show up and ride on the 24 airplane, you know. 25 O. And whO are they, if you know? 136 1 otherwise, the allegations that occurred or have been 2 alleged to have occurred al his Palm Beach mansion. 3 Correct? 4 A. Uh•huh. 5 O. Correct? 6 A. Coned. 7 O. Given the nature of those allegations, would 8 you leave your daughter of 17, 16, 15 years old with Mr. 9 Epstein alone? 10 MR. PIKE: Form. Move to strike. 11 A. Yes. 12 O. You would? 13 A. (Witness nods head.) 14 O. And why? 15 A. Because I don't fear that he would try 16 anything with my daughter. He showed — When I 17 worked for him he showed me respect. He never -- I 18 never He never showed me disrespect. He would ask 19 how the family is. I mean. not on a personal level, 20 but an employer/employee. 21 O. Right. Okay. 22 A. He never showed me any reason not to trust 23 him. 24 O. But you're not a 13-year old girl, so. 25 A. No. but, like I say, he never showed me ESQUIRE Toll Free: Facsimile: www.esguireso utions.com • • • EFTA00181415
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Larry Eugene Morrison - Volume I October 6, 2009 • • 137 1 any reason not to trust. 2 O. So maybe that's the reason why there were 3 hundreds of victims, right? 4 A. I don't know that there were. 5 O. So is it surprising to read the things that 6 you read about what was going on at his house? 7 A. Yes. 8 MR. PIKE: Form. Move to strike. 9 BY MR. EDWARDS: 10 O. I'm going to ask you about I'm going to 11 mark them all -- In fact, I'm going to show them to your 12 attorney first because I'm going to mark them as a 13 composite • just to save time. 14 MR. REINHART: For the record• you've 15 handed me a stack of passenger manifests? 16 MR. EDWARDS: Yes. You can count them if 17 you want. doesn't matter to me. and we'll just 18 mark them as a composite • go through each one 19 of them. 20 MR. REINHART: If you're going to go 21 through each one of them, I don't need to count 22 them. You'll make a record on that. 23 MR. EDWARDS: Fine. I'm going to mark 24 these as Composite Exhibit 1, and we'll count 25 them at the end. 139 1 know her if I saw her. 2 O. What did she do? 3 A. I don't know. I don't know. 4 O. Would it surprise you if she was in charge of 5 scheduling for the minors to come over to the house to 6 sexually gratify Mr. Epstein? 7 MR. PIKE: Form. A. Yeah, that would surprise me, yes. 9 O. Okay. She didn't do that while you were on 10 the airplane, right? 11 A. Wi no. 12 O. Was Mr. Epstein on the airplane? 13 MR. PIKE: Form. When? 14 A. Yes. 15 O. And if it happened, it happened at a portion 16 of the airplane where you couldn't see it because you 17 were partitioned off? 18 A. What happened? 19 MR. REINHART: I'm sorry, can we just get 20 a timeframe? 21 MR. PIKE: Form. 22 MR. REINHART: Are we talking about this 23 flight? 24 MR. EDWARDS: Yes, we're talking about 25 that flight. 138 1 (Defendant's Composite I was marked for 2 klentificatIon.) 3 BY MR. EDWARDS: 4 O. The first one's dated 1/14/2004. Can you tell 5 me what we're looking at there? Just remember. I'm about 6 as familiar with that type of stuff as a three year old, 7 so help me out. 8 A. Passenger manifest just showing basically 9 date, time off, time on, the trip number of the year. 10 I guess It would be • that seems high for the year - 11 but trip number - that must be for the total • 12 destination or departure point - destination. 13 O. The trip number says. '311.' What does that 14 mean? 15 A. That must be -- I don't know where they 16 start that. That must have been total since he 17 started the airplane. That's way too many for the 18 year. Obviously it's already - it's January, so it 19 must have been total flights. 20 O. Who's on that airplane? 21 A. Nautical miles, statute miles. fuel 22 burned, poundage. 23 and 24 O Do you know 25 A. I -- I think I know her. I think I would 140 1 BY MR. EDWARDS: 2 O. If anything happened on the airplane, it would 3 have been in a position where you couldn't see it anyway. 4 A. That's correct. 5 O. Okay. 6 A. That's correct. 7 O. So you're not saying it did happen or it 8 didn't happen, you just couldn't see past a certain 9 point. 10 A. Correct, and I don't know what you're 11 referring to as 'it' anyways. 12 O. 'It' is whatever sexual involvement there was. 13 A. Oh. Like you say, we can't see anything 14 back there anyhow because the doors are closed. 15 O. Did Mr. Epstein instruct you as to whether or 16 not to knock or just walk back there or never walk back 17 there or what was the instruction? 18 A. No. There was never actually a formal 19 instruction. It's proper protocol for any of these 20 gentlemen, or individuals that own these aircraft, 21 that that's their private zone, that you don't come 22 back unless you're needed, and then you can -- You 23 know, but it's not forebode. it's just proper. 24 O. You mentioned President Clinton on Me plane. 25 How many girls were on the plane al the same time when • ESQUIRE Toll Free: Facsimile: www.esquiresolutions.com EFTA00181416
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Larry Eugene Morrison - Volume I October 6, 2009 141 1 President Clinton was on the plane? 2 MR. REINHART: Asked and answered. 3 A. Yeah, I don't remember for sure. There 4 was probably maybe five, if that, and that's O. What were they -- 6 A. What? 7 O. Go ahead. 8 A. Like I say, it was Ms. Maxwell, 9 maybe two others, one other, and then I think Mr. 10 Clinton had two ladies in his entourage - support 11 staff. 12 O. What age group are we talking about with the 13 ladies that were on the airplane? 14 MR. PIKE: Form. 15 A. Mid-twenties to forties, maybe. I mean, I 16 don't know exactly. 17 O. I mean, you know what a 13 or 14-year-old girl 18 looks like -- 19 A. Yes. 20 O. — right? 21 A. Yes. 22 O. Most people do. 23 A. Yes. 24 O. You wouldn't mistake a 13 or 14 or 15 year old 25 fora 20yearold. 143 1 you familiar with a flight where Prince Andrew was on the 2 airplane? 3 A. I don't know if I remember him being on 4 the airplane or not. I know that he has been on the 5 airplane or one of the airplanes. I can't say for 6 sure. 7 O. Have you met him before? 8 A. I can't remember, honestly. I know. 9 O. Can't remember meeting Prince Andrew? 10 A. I know. I know. I didn't even know who 11 he was when 1 first heard the name, sorry. But, no. 12 I can't remember for sure, I'm sorry. 13 O. That's like if E.T. walked on the airplane and 14 I don't know. 15 A. I know. Well 16 O. Alright. I'll let you slide on that one. You 17 know who Prince Andrew is now. 18 A. Okay. Don't paint me as stupid. One of 19 Lady Di's sons, right? 20 O. I mean, you know what he looks like now. 21 A. You know, honestly, I don't know if I 22 could point him out to you, I'm sorry. 23 O. Alright. 24 A. It's just -- 25 O. We'll forget him. 142 1 A. No, no. 2 MR. PIKE: Form. 3 BY MR. EDWARDS: 4 O. So you're sure that the people that were on the airplane • they were above the ago of 18? 6 A. I believe so. 7 O. Because you, in your experience. as well as 8 the experience of most people your age, would know — 9 A. Right. 10 O. - what a 14 or 15 year old looks like. 11 A. Right. 22 O. I'm going to go through the next flight log. 13 You tell me what we're looking at here. Who's on the 14 airplane? 15 A. That was a deadhead. Nobody's on rt. 16 O. Why were the names crossed out? 17 A. Because there was no passengers. This was 18 - origin was West Palm Beach - West Palm Beach. What 19 date is this? 1/20/04? It was probably a test 20 flight. 21 O. Okay. 22 A. It was a training flight 23 O. Okay. 24 A. -- for Bill. 25 O. The next one -- Well, before I ask this Were 144 1 A. I'm smart in some things. 2 O. Well forget him. We'll forget him. Don't 3 worry about it. 4 What's this? What are we looking at? 5 MR. REINHART: For the record, you handed 6 him a manifest dated January 17. 2005; is that 7 correct? 8 THE WITNESS: January — Yes. Correct. 9 Palm Beach to Kennedy. same thing, fuel 10 bums, loads. destination, time off, time on. 11 Next, it was hip 312. Jeffrey is on it, a, 12 David Mullen, Todd Myster (sic), 13 and passenger, passenger. 14 8Y MR. EDWARDS: 15 O. Do you know Todd Meister? 16 A. He's a friend of his. I believe. 17 O. Fathers Bob Meister? Do you know the names? 18 A. No, I don't know that. 19 O. How do you know Todd Meister? 20 A. I've just heard the name. 21 O. From who? 22 A. Larry Visoski. 23 O. Larry Visoski knows these people? 24 A. I think Todd Meister has an airplane, or 25 something like that. He's talked to their flight Toll Free: Facsimile: ESQUIRE www eyiuresclutions (1011 • • • EFTA00181417
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Larry Eugene Morrison - Volume I October 6, 2009 • • 145 1 crew. 2 a For the most part. when you mention these 3 people's names, you mention them as if they're just 4 passengers on tho airplane and this is their world • 5 you're passing through, you don't know them. 6 A. Right. 7 O. But Visoski would you say that he has a 8 closer relationship with Epstein to where he might know 9 some of these people? 10 MR. PIKE: Form. 11 A. That could be an accurate - yeah. I mean, 12 he's been with Jeffrey longer. I mean -- 13 0. I mean, do you know that Visoski has a car 14 that is registered In Jeffrey Epstein's name? You don't 15 have anything like that, do you? 16 A. No, I did not. 17 0. Were you aware of that? 18 A. No. 19 0. Does Mr. Visoski tell you how far he goes back 20 with Jeffrey Epstein? 21 A. No, just, I mean, when he hired him, 22 whenever that was after Glimcher - that's all I know. 23 0. Do you know anything about Visoski's private 24 life? 25 A. A little bit. He's married and - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 147 Q. Well, do you know whose handwriting that is? A. No. no, I don't. It may be Larry's. 0. Similar handwriting — A. Wait a minute. 0. — as those — A. Let's see the one with the training • because there's a different pilot on there. 0. Right. One where there is nobody on it. right? A. This is Bill's -- I can't -- This is Bill's writing. I think he was having him fill out the paperwork. 0. Bill Hammond? A. Yeah, this was his training flight. 0. The first one is Visoski? A. Maybe. I can't say for sure. I really can't say for sure. 0. And this is? A. I don't know if that's the same handwriting or not. Q. Well, is there any indication up here that would tell us whose handwriting it is? David Rodgers and Larry Visoski -- A. No, because this is O. are the pilots. 146 1 daughters. I mean -- 2 0. Then I won't go into the rest of his private 3 life. 4 When it says, • 1 pay. I pay.' what does that 5 mean? 6 A. It's 'PAX? P-A-X is short for 7 'passenger.' It's a brief. 0. Okay. Look, this is somebody that is listing 9 names of people on an airplane. They're going out of 10 their way -- 11 A. Right. 12 0. — and then all of a sudden on No. 8 and 9 13 they say, 'one passenger.' Is this person just getting 14 lazy Or is there a reason why there's no name? 15 A. Like I say, just getting lazy and then 16 didn't know who the passenger was. 17 0. Well, they obviously didn't know who Todd 18 Meister was either - they wrote his name all wrong. 19 A. They did? 20 MR. PIKE: Form. 21 BY MR. EDWARDS: 22 0. Well, 'Meister is not spelled like that, so 23 how did -- 24 A. I didn't -- I didn't know that. I don't 25 know how he How does he spell it? 148 1 A. Yeah, but they don't indicate - they don't 2 indicate who's captain that day. You know, I'm not a 3 handwriting expert. I can't really -- Honestly, I 4 can't tell you for sure whose handwriting it was. 5 0. Let's keep this one out, and tell me if this 6 is -- I'm going to hand you January 19.2005 7 MR. REINHART: January 17. 8 MR. EDWARDS: 2005? 9 MR. REINHART: Yes. 10 BY MR. EDWARDS: 11 0. — January 17, 2005, so two days later • whore 12 is this airplane going? 13 A. From Kennedy to Palm Beach. 14 0. And so Ibis is Palm Beach to Kennedy -- 15 A. Yap. 16 0. -- in this exhibit. The next one is Kennedy 17 to Palm Beach. 18 A. Correct. 19 0. They come back Where do they stay - do you 20 know? 21 A_ What do you mean? 22 0. Well, they get off on the 17th, they stay 23 somewhere until they come back on the 19th. Do you 'mow 24 where they stay? 25 MR. REINHART: Can we clarify who 'they' ESQUIRE Almadei G•Ile Cann Toll Free: Facsimile: E M www.esquIresolutions.com EFTA00181418
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Larry Eugene Morrison - Volume I October 6, 2009 149 1 Is? 2 BY MR. EDWARDS: 3 Q. I guess it is- David Mullen, a , Tod Myster (Sc). I pax, another pax. 5 and Jeffrey Epstein - and there's a crossed 6 out thislarne Maxwell: so I'm assuming she didn't go. A. Coned. 8 I have no idea where they stayed. I 9 assume Jeffrey would stay in his home. would 10 stay in her apartment. As for all the others, I have 11 no idea. 12 O. Have you ever been to Jeffrey Epstein's home 13 in New York? 14 A. Just in the lower level of the entryway. 15 O. Why did you go? 16 A. To pick up bags for the trip to go to the 17 airport and load them. Is Q. Was there anybody else there with him? 19 A. I don't know with him. I never saw him 20 him. We saw the guy that ran the house. 21 O. Who's that - Joe-Joe? 22 A. Joe-Joe would be there - 23 O. What's Joe-Joe's name? 24 A. Joe-Joe. that's aril know, and then 25 there's the actual house manager. Joe•Joe is more of 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 151 O. The next one is January 27. 2005. Palm Beach to where? A. St. Thomas. O. To St. Thomas. A. Right. O. And he has and and Jeffrey. A. Right. O. Does he tell you what happens in St. Thomas? What he does there? A. No. no. O. Ever heard that he imports underage girls from Brazil to his MR. PIKE: Form. O. -- Island In St. Thomas? MR. PIKE: Form. A. No. no, never heard that. O. What does he tell you about his island in St. Thomas? A. Not a lot. I mean, he would sometimes talk about construction stuff or I would hear him - overhear him and Larry talk about the helicopter pad that they're putting in, little stuff like that - all construction. O. Did he tell you two or three times a day, that he sexually abuses girls between 12 and 15 years old? 150 1 a driver, and then there's the house manager - I 2 forget his name. 3 But, yeah, we would meet -- There's an 4 office in tho lower level that the bags would be at. 5 and we would put them in the back of the van, haul 6 them to the airport. 7 O. Who's David Mullen? 8 A. I don't know. I heard of it. It sounds 9 familiar. I can't remember who he is. 10 O. Somebody that lives in New York, Palm Beach? 11 A. I don't know. I don't know. 12 O. I'm trying to keep them in order. 13 So coming back - you know, it looks like they 14 take to JFK: David Mullen, Tod Myster (sic), some 15 passengers unnamed - they come back with only M. M. and - any idea why? 17 MR. PIKE: Form. 18 A. No, but: I mean, it's not unusual for 19 these guys to, you know, take somebody - let somebody 20 have a free ride to New York if they know them, they 21 are acquaintances, need a lift. I mean, that's not 22 unusual. 23 O. How's that come about - do you know? 24 A. No, I don't - phone conversations, 25 cocktail parties. I don't know. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 152 A. No. MR. PIKE: Form. BY MR. EDWARDS: O. Not something he ever mentions. A. No, no. MR. PIKE: Form. BY MR. EDWARDS: O. The next - 2/3/05 - who's on the passenger list? A. Jeffrey, Jean Luc, David Mullen, female, female, female. O. Any idea why they would list lemale, female, female: without listing the names? A. No, just the same as -- The only idea I would have would be the same reasoning for the - previously when they listed them as just TAX* - that they didn't have any idea who they were, what their name was. O. I mean, certainly that's -- A. I don't know whose handwriting that Is. O. You're guessing, though, right? A. Yeah. No, I'm guessing. I have no idea. O. Another guess would be they're 12 years old and you can't put them on it. MR. PIKE: Form. 0 ESQUIRE "....... Toll Free: Facsimile: www.esquireso utions.com • • • EFTA00181419