EFTA01110271

Larry Eugene Morrison - Volume I 
October 6, 2009 
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Jennif er Ditorenref , court reporter 
3 
1 
APPEARANCE OF COUNSEL 
2 
On tense of IM Defendant 
3 
ATTERBURY.GOLC6ERGER & WEISS 
BY: JACK ALAN GOLDBERGER. ESO.. 
4 
250 Australlen Avenue 
Slate 1400 
s 
Watt Palm Bach FL 33101 
6 
7 
On behalf of the Defendant by telephone 
BURMAN, CRITTOR LUTTIER & COLEMAN 
9 
BY: Maimi J. PIKE. ESO.. 
515 N. Realer Drive 
10 
Stale 400 
13 
FL 33401 
12 
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On behalf of the sstness: 
LAW OFFICE OF BRUCE E RBA/HART 
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BY: BRUCE E. REINHART, ESQ., 
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16 
250 S. tentralan Avenue 
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INDEX OF EXAMINATION 
WITNESS: 
UM ," EUGENE MORRISON 
Page 
DIRECT EXAMINATION 
By Mr. Edwards 
*5 
CROSS-EXAMINATION 
6 
By Me. Ezell 
9 
CROSS-EXAMINATION 
By Mr. Willits 
10 
CROSS-EXAMINATION 
11 
By Mr. Pew 
*196 
12 
FURTHER REDIRECT EXAMINATION 
By Mr. Edwards 
#199 
13 
14 
6190 
1195 
L 
16 
INDEX TO EXHIBITS 
Plaintiff's 
1a 
Exhibit Description 
Page 
19 
1 
Twenty-four pages of 'JEGE, Inc., 
Passenger Manifest." 
#138 
20 
21 
22 
23 
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(Plaintiffs Composite 1 was attached to the 
original transcript and copies of the transcript.) 
25 
EFTA01110271

Larry Eugene Morrison - Volume I 
October 6, 2009 
5 
1 
Deposition of LARRY EUGENE MORRISON 
2 
October 6.2009 
3 
4 
THE REPORTER: Do you swear the testimony 
S 
you're about to give will be the truth, the 
6 
whole truth, and nothing but the truth so help 
7 
you God? 
8 
THE WITNESS: So help me God. 
9 
--
10 
LARRY EUGENE MORRISON, having been first 
11 
duly swam, was examined and testified as 
12 
follows: 
13 
DIRECT EXAMINATION 
14 
BY MR. EDWARDS: 
is 
O. Tell us your name. 
16 
A. Larry Morrison. 
17 
Q. And. Larry, where are you employed right now? 
18 
A. For JEGE. 
19 
Q. What's JEGE mean? 
20 
A. It's the aviation flight department for 
21 
Mr. Epstein, and my primary Job Is Danklold Reed 
22 
Aviation. 
23 
MR. REINHART: Spell It. 
24 
A. D-A-N-K-J-O-L-D, and then the second word 
25 
le Reed, R-E-E-D, Aviation. Ws 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 fink, for the aircraft. Its not -- I 
5 
don't bSeve It to be a money making company or a 
6 
real corporation. 
7 
O. You're song `for the aircraft? rm 
a 
Interpreting that to mean you're talking about on, 
9 
aircraft. 
10 
A. Correct. 
11 
Q. 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 
Just one is JEGE or --
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 paperwodt - 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 
Q. Since it seems tike we've kind of skipped 
24 
ahead from 2001 to 2007, am I right that your first 
2s 
involvement with Jeffrey Epstein of any way, shape, a 
6 
1 
department. 
2 
Q. What do you do for him? 
2 
A. Director of Maintenance. 
4 
O. Okay, so you maintain his planes —
5 
A. Correct. 
6 
Q. 
— should something go wrong? 
7 
A. Correct. Yes. Yep. 
O. Do you also --
9 
A. For maintenance. 
10 
O. Do you also fly on his planes? 
11 
A. On 1W. 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 
Q. When you fist your company - JEGE? 
17 
A. Yes. Yeah. it's 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 he? 
25 
A. Oh, no, no, somewhere - It wasn't mine. 
8 
1 
form was 2001? 
2 
A. That's correct, yeah. 
3 
Q. You didn't meet him before that. 
4 
A. I had met him He was a — He was an 
5 
associate of my previous bees. 
6 
O. Who's that? 
7 
A Mr. Wexner. 
O. Leslie Wexner? 
9 
A. Yes. 
10 
Q. How do you know Leslie Wexner? 
11 
A. I worked for Limited Stores for 12 years. 
12 
O. Doing what? 
13 
A. Essentially the sane thing - aircraft 
14 
maintenance for their corporate flight department and 
15 
flight engineering on the 727. 
16 
O. How many aircraft did Leslie Wexner have? 
17 
A. Weil, none that I know that he had 
18 
personally, but the corporation had - the fight 
19 
department operated - we had three Gulfstreams, two 
20 
Hawkers, and a 727. 
Q. What was the name of his corporation that 
22 
maintained the aircraft? 
23 
A. For Limited Stores? 
24 
Q. Yes. 
25 
A. It was just — It was called Limited - 
EFTA01110272

Larry Eugene Morrison - Volume I 
October 6, 2009 
9 
1 
Limited Flight Department. 
2 
Q. And do you know him personally then Leslie 
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 Leslie Wexner? 
a 
A. 1988 was when I hired on, so I don't 
9 
remember the month. 
10 
Q. 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 
Q. Wee I mean, Leslie Wexners an important 
15 
person. right? I mean. he —
16 
A. Correct 
17 
MR. GOLDBERGER: Form. 
18 
BY MR. EDWARDS: 
19 
Q. 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 
Q. Chairman of — 
24 
A. Yeah. He doesn't personally own .1. It's 
25 
a publicly held company. 
1 
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3 
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11 
Q. Yes. 
A. Aircraft technician. 
Q. Which entails what? 
A. Maintenance of any or all of the aircraft 
operated by the flight department and some flight 
mechanic duties. 
Q. What kind of airplanes? 
A. Gulfstreams, Hawkers. 
Q. How big is the Gulfstream? 
A. Fifteen passenger -15 to 17. 
(Mr. Goldberger (tilted.) 
BY MR. EDWARDS: 
Q. What did Wexner use the Gulfstream for? 
A. They were division airplanes, mostly. 
Q And the other airplane you named - what did he 
use that for? 
A. Same. same. 
Q. Any idea why he had two planes? 
A. Well, I mean, yeah, we used them - Mafia 
a loot h wasn't him. It was a large Fortune 500 
company. They use them as tools to — You know, 
Lhnited has control over 60 percent of their 
manufacturing processes, plus, you know, what.1200 
stores, or whatever, throughout all their divisions. 
I mean, when you say 'limited' ire not 
10 
1 
Q. Where were you prior to any involvement with 
2 
Leslie Wexner? 
3 
A. I worked for Red Roof Inn True Sports 
4 
Flight Department. 
5 
Q. How did that position lead you to Leslie 
6 
Wexner? 
7 
A. Well, it was always known that Limited 
8 
Right 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 AS
12 
school. together - so when the position became 
13 
available they pointed to me and - absolutely. It 
14 
was a fine organization. 
15 
Q. So did I.Y. 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 
0. So you start with Wexner in 1988. 
23 
A. Yes. 
24 
O. What do you do for Nm then? 
25 
A What did l do for Nm? 
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12 
just Limited, ifs Victoria's Secret and it was 
Express and Lemers and Henri Benders and all of 
that back then, so. I mean —
Q. So — 
A. 
— we moved a lot of passengers to keep 
those stores for the retail business. 
Q. And by 'passengers." do you also mean clients 
of his? 
A. That I don't know. No. Mostly we just 
dealt with upper echelon, you know, people in the 
retail businesses from —
Q. Such as whom? 
(Mr. Goldberger entered.) 
A. Can't even remember names, but it would be 
-- We would take buyers to Europe in the spring and 
fall. They would buy samples and piing them back to 
analyze for marketing. We would hire — We would — 
Division heads, when they would do store shops and, 
Real Estate, we take Real Estate out when they were 
looking for new real estate. 
Q. While you were working back in '88 — Well, 
how long overall did you work with Leslie Wexner and/or 
his companies? 
• 
Wen.738 through when I came here in 
January of '01. 
EFTA01110273

Larry Eugene Morrison - Volume 
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-pth3t airplane - and It gave me the 
6 
opportunity to become a Director of Maintenance. and 
7 
it was a chaflenge. You know, bringing - upstarting 
8 
an airliner on a private ticket or a VIP ticket is 
9 
really challenging. and I enjoy the challenge of 
10 
waking and developing the program and stuff. 
11 
O. Well my understanding. Leslie 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 
Q. 
Wee, when you would maintain his aircraft, 
17 
would that be in Ohio —
18 
A. Yes. We were based -
19 
Q. 
or elsewhere? 
20 
A. We were based at Lane Aviation. 
21 
MR. REINHART: Hold on one second. You 
23 
have to let him finish asking the question 
23 
before you answer. 
24 
THE WITNESS: Okay. rm sorry. 
as 
BY MR. EDWARDS: 
15 
1 
aircraft. I mean, whatever It takes to keep a 
2 
corporate flight department operating. 
3 
Q. Did you know back then of his relationship, if 
4 
any, with Jeffrey Epstein? 
5 
A. Not Immediately, no. 
6 
Q. When is the first time that you knew of a 
7 
regulation or a relationship between Wexner and Epstear 
A. Would have had to probably be around maybe 
9 
'98. 199. 
10 
Q. 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 Ina while Jeffrey would ride on the Boeing. 
15 
that's al that's al l knew. 
16 
Q. How did it come about that he would ride on 
17 
Wexner's Boeing? 
18 
A. They were business associates. I think. 
19 
Q. As far as you know, they were business 
20 
associates. 
21 
A. Right. 
22 
Q. DM you understand the business relationship 
23 
between the two? 
24 
A. Well, I believe it's pubic knowledge 
25 
that, I think, Jeffrey managed Mr. - some of Mr 
14 
Q. I'm sorry, have you ever had your deposition 
2 
taken before? 
3 
A. No. 
4 
Q. You definitely never had your deposition taken 
5 
before while somebody else is trying to eat at the same 
C 
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, II wait until you finish your answer before 
11 
I ask my next question: you do the same thing. 'U .-huh' 
12 
or -uh•eh," 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 
Q. If I ask a question that was a bad question or 
17 
something you don't understand - I've asked bad questions 
18 
before - say., don't get it." 171 ask a better 
19 
question. 
20 
A. Okay. 
21 
Q. You were working with Lee 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 
Q. Is that something that Mr. Wexner told you? 
3 
A. No. 
4 
Q. Is that something that somebody of Mr. 
5 
Wexner's organization would have told you? 
6 
A. No. 
7 
a 
Is that something that Jeffrey Epstein told 
8 
you? 
9 
A. No. 
10 
Q. 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 
Q. I mean, like you say, to me Ifs common 
16 
knowledge —
17 
A. Right. 
18 
Q. But it's only because of vital 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. 
as 
A. Don't know. 
EFTA01110274

Larry Eugene Morrison - Volume I 
October 6, 2009 
17 
Q. Did you ever know of a time — And I maybe 
2 
asking a question that would just be completely outside 
3 
of your knowledge. so let me back up. 
4 
Have you ever stayed at Leslie Wexners house? 
5 
A. No. 
6 
Q. Do you know where his house is? 
7 
A. Yes. 
0. Do you know what the address is in Ohio? 
9 
A. No, I just know the city. 
10 
Q. Do you know who he lives with? 
11 
A. Yes. 
12 
Q. Who is that? 
13 
A. His wife and children. 
14 
Q. What's his wife's name? 
15 
A. Abigail. 
16 
Q. Abigail Wexner, and he has three or tour 
17 
daughters, right? 
18 
A. No. He's got a son, Harry, and two 
19 
daughters, I think. 
20 
Q. A son and two daughters. 
21 
A. I don't know. See, that was back in 2001. 
22 
I don't know what they have - II they have more kids 
23 
24 
0. Okay. Did you ever hew any information that 
25 
he was homosexual? 
19 
1 
0. Have you spoken personally with sic. Wexner? 
2 
A. On business issues, yes. 
3 
Q. Business issues related to your work on his 
4 
airplanes? 
A. Correct. 
6 
O. Have you spoken to him on any ether issues 
7 
that don't involve business relationships with his 
airplanes? 
9 
A. No. 
10 
0. Because you're hired basically for that 
11 
purpose. so that's kind of how you deal wqh him. 
12 
A Yeah. Ws rm an employee and he's my 
13 
employer and I only deal with rim, you know, on 
14 
Issues that Involve maintenance. 
15 
0. I think I probably know the answer to the nod 
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. 
70 
O. Who's that? 
21 
A. rm trying to remember — You have to 
72 
remember it's been several years. 
23 
0. right. 
24 
A. He was Mends with the Tuckermans. 
25 
a 
What's Mr. Tuckerman or Ms. *Nachman's naives? 
18 
1 
A. No. 
2 
0. Being Mr. Wexner. 
3 
A. No. 
4 
Q. Any indication to you that he may be 
s 
homosexual or bisexual? 
6 
A. Absolutely not 
7 
Q. Have you heard any information that he and Mr. 
8 
Epstein were Involved sexually with one another? 
9 
A. Oh, no, no. 
10 
0. Would that surprise you? 
11 
A. Absolutely. 
12 
0. And that's only because you know him and you 
13 
know Mr. Wexner and you don't see the two together. 
14 
A. Correct. 
is 
MR. GOLDBERGER: Finn. 
16 
A. Wel — 
17 
0. He —
le 
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 girlMend before he met Abigail. 
23 
0. Right. 
24 
A. No. There was never any hint or anything 
25 
that I would even conceive that. 
20 
A. Ms. — I cant I akvays addressed them 
2 
by their proper name. 
3 
0. Cope know what they do? 
4 
A. They owned an optical company - opticians. 
5 
They were high school friends from Mr. Wexreesh oh 
6 
school days. 
7 
0. 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 reptvase it? 
15 
Q. Wel. 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 
Mends or acquaintances with Mr. Epstein was '98 -
19 
almost ten years later. 
20 
A. Right. 
21 
Q. 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 know, Mr. Epstein? 
24 
A. Oh, no. no. 
25 
Q. So as far as you were concerned, 1998. when 
EFTA01110275

Larry Eugene Morrison - Volume I 
October 6, 2009 
21. 
1 
you found out there was a relationship with Epstein, it 
2 
could have very well started then. 
3 
A. Yes. 
4 
Q. Aside from aircraft technician and taking care 
of Pitt Wexner's aircraft back in the '80s and, I guess, 
6 
early '90s. did you have any other personal involvement 
7 
wilt) him? 
8 
A. Just on aircraft completions. 
9 
Q. 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 at the corporate 
12 
office. 
13 
Q. At the corporate office? 
14 
A. At the corporate office. 
15 
Q. Can you tell me the address for his corporate 
16 
office? 
17 
A. No, I cant 
18 
Q. If I requested that from your attorney. would 
19 
you be able to get that information? 
20 
A. Weal mean, I imagine it's public 
21 
knowledge - wherever - it's at the Limited. 
22 
Q. And Mars where you would meet him - at the 
23 
United? 
24 
A. Yeah. 
25 
Q. And how Often was - you know, I know that 
23 
1 
O. Who were some of the pilots? 
2 
A Tim 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 Visosid a pilot used by Leslie 
6 
Warner at any time? 
7 
A. No. 
a 
Q. How about David Rodgers? 
9 
A. No. 
10 
Q. Are those names you're familiar with? 
11 
A. Yes. 
12 
O. Those are names you're familiar with how? 
13 
A. I flew with them when 1 was flying for Mr. 
14 
Epstein. 
15 
Q. So there's no real, other than yourself --
16 
Well, tell me if I'm wrong: I understand that you did 
17 
some work for Mr. Weiner related to his aircraft and you 
18 
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 
Q. Okay. You've already told us that you were 
24 
the aircraft technician for Mr. Werner. 
25 
A. One of them. One of several, yes. 
22 
1 
we're talking about 15, 20 years ago • how often was Mr. 
2 
Wexner personally at that location at the Limited 
3 
offices? 
4 
A. I have no idea. 
5 
Q. 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 
Q. Who's Charlie Hinson? 
10 
A. He was the president of the stores. He 
11 
basically was my go-between for these aircraft 
12 
completions for the design. 
13 
O. And you mentioned the Gulfstream 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 
Q. Limited Stores? 
19 
A. Right. Yes. 
20 
Q. What did you do for them? 
21 
A. Same - maintenance. 
22 
Q. Did you ever fly in them? 
23 
A. On the Gulfstreams in the early days we 
24 
used flight mechanics, especially on international 
25 
flights. 
24 
1 
Q. 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? 
7 
A. No, no. 
8 
Q. Do you know how Mr. Weimer met Mr. Epstein,
9 
A. No. 
10 
Q. 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 
Q. Why did you stop? 
14 
A. Because what we were taking 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 set up the airplane for his flight 
20 
department because they hadn't had any previous large 
21 
aircraft experience. 
22 
Q. I missed something. It wasn't your fault, it
23 
was ITWOO. 
24 
The Gulfstream that you were taking about, 
25 
did you used to fly that as well as being a light 
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Larry Eugene Morrison - Volume 
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1 
technician? 
2 
A. No, no. 
3 
Q. Okay. 
4 
A. You don't have to have a flight - a 
5 
pilots certificate to be a professional flight 
6 
()Vow. I've got a turbo - a flight engineer turbo 
7 
jet rating, but you don't have to have a commercial 
ticket as long as you - the FAA recognizes your heavy 
9 
aircraft maintenance experience. 
10 
Q. So you're saying that if the FM recognizes 
11 
your heavy maintenance experience, I'm assuming that 
12 
means that you understand the ins and outs of airplanes 
13 
and you can work on them. 
14 
A. On heavy high performance aircraft, yes. 
15 
0. Then you can also fly them? 
16 
A. Sideways as a flight engineer. 
17 
Q. Explain. 
18 
A. On the older generation airliners there 
19 
was three pilots - there's a captain, a first 
20 
officer, and then the flight engineer is the 
21 
gentleman that sits sideways and maintains all the 
22 
systems. 
23 
Q. When you say. 'sits sideways? okay, I have 
24 
a —
25 
A. Literally, you're physically sideways in 
27 
1 
Q. Do you know why Epstein chose to buy that 
2 
particular 727 rather than one of the other mum 727s 
3 
that are made? 
4 
MR. GOLDBERGER: Form. 
5 
A. Because It was probably the finest one out 
6 
there --
7 
Q. Why? 
A. -- in as honesty. Its got a fully Paged 
9 
SIC 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 
Q. Describe for me the interior - 
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 just a bunch of seats where 
18 
everybody sits there. 
19 
A. Correct. Right. 
20 
The aircraft — You enter the airplane, 
21 
It's got forward air stays, which most 727's don't, 
21 
so you enter the forward door on the left-hand side, 
23 
the forward entnAvay 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 at 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 
Q. What's your job? 
7 
A. Maintain all the aircraft systems - the 
8 
hydraulics, fuel management, pressurization, 
9 
environmental controls. 
10 
Q. That's not done by the pflotS. 
11 
A. No, no. 
12 
0. But if you've done that long enough and FAA is 
13 
aware d 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 
Q. And was that? 
18 
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 Caine on board in '01, January of '01. 
28 
1 
forward salon. 
2 
Q. What's the forward salon? Sorry. 
3 
A Forward seating area. 
4 
O. And is it set up basically the way that I'm 
5 
picking ft - in that there are 25 or 26 rows and theyre 
6 
numbered A through E? 
7 
A. No, no, it's a corporate configuration. 
a 
Q. 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 
Q. Any various dividers throughout —
13 
A. Yes. 
14 
Q. 
— to where there's a VIP room in the back or 
15 
anything like that? 
16 
A. ft's compartmentized (sic), yes. 
17 
Q. In what way? Describe it as specifically as 
18 
you can. 
19 
A. There's a forward salon, a mid galley -
20 
the galays in the mld - an aft - an aft salon, 
21 
which is - and then the aft state room. 
22 
Q. 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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Larry Eugene Morrison - Volume : 
October 6, 2009 
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1 
Q. Who directed the design of that plane? 
2 
A. It would have been Mr. Wexner. I mean, It 
3 
was — The layout has not changed. 
4 
O. 'The layout has not changed' when you say 
5 
that, you mean 'from the time that I first got in it and 
6 
I was under the guise or - "under the employment of 
7 
Wexner to the time I've been on it since with Epstein, 
the oon5guratlon 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 Its identical to what The Limited used. 
12 
Q. Are there any blocked off areas to where if 
13 
you're standing in the middle of the plane you can't see 
14 
certain areas of the plane? 
15 
A. There are pocket bulkheads. Yeah, there's 
16 
dividers between the seat:Ina. 
17 
Q. How big are these cflviders and where aro they? 
18 
A. Well, there's a divider - the forward 
19 
door, I told 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 
31 
1 
because obviously there's a lot - there's not that 
2 
3 
A Privately owned 727s, but this is — As a 
4 
matter of fact. The Limited's current BBJ has a very 
5 
similar floor plan. 
6 
O. As Trump's? 
7 
A. No, as the -as ow 727. 
Q. Who's "our? 
9 
A. Mr. Epstein's. They didn't change a lot. 
10 
It's — 
11 
O. Well, I thought that you had told me that the 
12 
727 that was once owned by Wexner is the 727 that's armed 
13 
by Epstein. 
14 
A. It is, but what I'm saying Is even their 
15 
current airplane has the same layout - the BBJ. They 
16 
put the same floor plane in the more modern airplane 
17 
O. Well, they Mat have to put n there. It 
18 
was already there, right? 
19 
A No, no, no. When you buy these aircraft -
20 
oven a Gulfstream Mien you buy them it's just a 
21 
green hull, there's nothing in them, and you can 
22 
customize your Interior. 
23 
O. rm soy, we're miscommunicallrg somewhere. 
24 
and I'm sure its on me. 
25 
MR. GOLDBERGER: Yes, It is. 
30 
1 
commercial airliners privately owned? 
2 
A. Yes. yes. 
3 
Q. Have you noticed similar configurations to 
4 
where there are this many divicfrig doors or is this one 
S 
that has more so than you've seen In the past? 
6 
A. No, no, this Is pretty atypical (sic). 
7 
Q. It's pretty atypical? 
$ 
A. It's typical. 
9 
O. It's pretty typical? 
10 
A. Yes, yes. 
11 
Q. So what other airplanes - 727s, or other Maier 
12 
airplanes - have you been on that have these types of 
13 
dividers? 
14 
A. Trump. 
15 
Q. Trump's airplane? 
16 
A. Yes. 
17 
O. Why were you on Trump's airplane? 
18 
A. Weil, I know the crew and, you know, this 
19 
is a small-knit community. There's not very many of 
20 
them out there, so everybody in this world knows one 
21 
another to help one another out as far as —
22 
Q. By "there" — 
23 
A. 
— b its motiun-wise and stuff. 
24 
Q By 'there aren't that many of these people out 
25 
there; you don't mean there's not that many people - 
3 2 
1 
MR. EDWARDS: And I'm taking the dame for 
2 
it - right away. 
3 
MR. REINHART: Take that. Ed. 
4 
MR. EDWARDS: Alright. 
5 
BY MR. EDWARDS: 
6 
O. My understanding - and piano correct me when 
7 
Mt wrong, because I know I am - Wexner has this 727 and 
8 
he designs it in a certain way. 
9 
A. Uh-huh. 
10 
Q. And then you come to work for Epstein —
11 
A. 
Yes. 
12 
Q. 
— vitro buys the same 727. Your testimony. as 
13 
I'm understanding it, is: It's basicaly the same floor 
14 
plan as Wexners Poor plan. To me, it should be the 
15 
exact same because he bought the same plane. 
16 
A. No, he — You're misunderstanding. 
17 
O. I figured. 
is 
A. 
VVhat I was stating is — You were — Ines 
19 
answering the question in regards to. "Is this 
30 
unusual to have this many compartments and closed 
21 
doors and bulkheads and things?' 
22 
What I was trying to state was: No, ins 
23 
not unusual - because The Limited even Sited Ihe 
24 
floor plan solemn in their old airplane that they 
25 
sold to Mr. Epstein. They duplicated it in their new 
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Larry Eugene Morrison - Volume I 
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33 
I 
airplane - see what I'm saying? That's all l was —
2 
Q. 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. 
5 
A. Well, no. When you -- When you buy a 
6 
Boeing business jet --
7 
Q. Yes. 
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 instal this 
12 
interior. 
13 
Q. 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 
113 
installed in the new aircraft - same floor plan 
19 
installed on the new plan. 
20 
Q. 
So Epstein didn't buy the exact same plane. 
21 
He bought the same type of plane. 
22 
A. 
Well, more modern. He bought a 737, 
23 
right. 
24 
Q. 
Got it. 
25 
A. Right 
35 
1 
had a very identical or very like floor plan 
2 
installed in the new airplane. 
3 
O. 
Got it. 
4 
A. Okay? Sony, ifs a strange business. 
It's — 
a 
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 
Q. 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 h. We're on the same page now. 
17 
A. Alright 
18 
O. Took us a while to get there. 
19 
A. Yeah, sorry. 
20 
Q. I think it was my fault, honestly, but 
21 
alright? 
22 
A. It's en unusual process if you haven't 
23 
been around corporate airplanes. 
24 
Q. I didn't realize that Mr. Wexner had a new 
25 
plane. 
34 
1 
MR. REINHART: Hold on. 
2 
BY MR. EDWARDS: 
3 
Q. 
Totally understand now. 
4 
MR. REINHART: Can you clarify - Mr. 
5 
Epstein or Mr. Weiner? 
6 
BY MR. EDWARDS: 
7 
O. Mr. Epstein bought not Mr. Wexner's plane. 
B 
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. 
3.4 
Q. He bought, actually, Mr. Epstein —
is 
MR. REINHART: Hold on. Distinguish --
16 
Use names so we're very dear when you're 
17 
talking about Mr. Epstein and NV. Wexner. okay? 
IS 
A. Mr. Epstein bought Mr. Wexner's 727. 
19 
Q. Okay. 
20 
A. 
The actual airplane - bought It from him. 
23. 
Q. Which has a floor plan already in it. 
22 
A. That we just discussed. 
23 
Q. Might. 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 
Q. That's where I had a problem. 
3 
How many times have you been on Mr. Wexner's 
4 
opine 
5 
A. The new? 
6 
MR. REINHART: Clarify which one you're 
7 
talking about. 
8 
BY MR. EDWARDS: 
9 
Q. Before you ever met Mr. Epstein. 
10 
A. I can't say. I mean, over the years? 
11 
Q. Numerous times? 
12 
A. Oh, I was his tight engineer. You mean 
13 
when I was still employed by him? 
14 
Q. Yes. 
15 
A. Yes. I was the flight engineer. I 
16 
don't --
17 
O. So as a flight engineer, every tine 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 tee,hniclan, so I had 
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Larry Eugene Morrison - Volume I 
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37 
1 
responsibilities in the hangar, whereas the other 
2 
engineer was a full time engineer. 
a 
Q. And given the partitions that you've described 
4 
in this airplane, are you able to see what's going on 
5 
behind the doors of the various partitions of the 
6 
airplane? 
7 
A. If the doors are open or dosed? 
Q. Closed. 
9 
A. No. 
to 
Q. Do you have any idea what's taking place in 
11 
there? 
12 
A. No. 
13 
MR. GOLDBERGER: Forrn. 
14 
BY MR. EDWARDS: 
15 
0. When you're on the plane with Mr. Wexner, was 
16 
there a time that he had — Well, let me put it this way: 
17 
When anybody is a passenger on any of these private 
1 e 
planes, should there be logs of the names of the 
19 
passengers on the planes? 
20 
A. Not required, no. 
21 
Q. Are you ever specifically Instructed not to 
22 
record the names? 
23 
A, That wasn't part of my duries. That 
24 
wasn't an engineers task, but --
25 
Q. Do you — 
1 
2 
3 
4 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
39 
A. There is normally a passenger manifest 
yet 
Q. Who creates the manifest? 
A. Probably dispatch. 
Q. Dispatch? 
A. At Limited. 
Q. DO you know who that Is? 
MR. REINHART: Can you give a time frame? 
Do you mean currently or back when he worked 
there? 
MR. EDWARDS: I'm talking about back when 
he worked there. 
BY MR. EDWARDS: 
0. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
0. 
A. 
Q. 
A. 
Do you know who that was at dispatch? 
That would have been Diane Williams. 
Who does Diane Williams work for? 
Limited Flight Department. 
Who does she report to? 
Tim Staley. 
Who's Tim Staley? 
Director of Operations. 
For who? 
Limited Fight Department. 
What does he then do with that information? 
I don't know. I don't know. 
38 
1 
A. 
— no. not that I'm aware of. 
2 
Q. Who is assigned the duty of reporting the 
3 
names of the people Mx, are going to be transported CO 
4 
the airpianes? 
MR. GOLDBERGER: Form. 
A. Captain. 
7 
Q. So have you ever been privy to conversations 
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 
10 
airplane? 
11 
A. Can't say. 
12 
Q. Sometimes? 
13 
A. I cant — You know, I cant say. I cant 
14 
remember what our policies were at the time. 
15 
0. I'm not asking policies. I'm asking: Have 
16 
you ever been around when the plot was being instructed 
17 
by Mr. Wexner - back in the late '80s, early 50s - to 
14 
make sure that you record who's on this aircraft? 
19 
A. I never heard Mr. Wexner address that, no. 
20 
Q. I mean. God forbid the airplane crashes, you 
21 
would We to know who's the on the airplane, right? 
22 
MR. GOLDBERGER: Form. 
23 
A. Yes. 
24 
Q. Is there any way to determine who's on each 
25 
particular flight In case anytNng happens? 
40 
1 
Q. Have you ever talked to Tim Staley? 
2 
A. From — Yes, yes. 
3 
Q. 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 
Q. Do you have a number for him? 
11 
A. Yes. 
12 
Q. Can I have the number, please? 
13 
A. 
14 
Q. Is 
..la— sicrumber? 
15 
A. That's the Flight Department. 
16 
Q. That's the best number to reach him at? 
17 
A. Yes. 
18 
Q. If I'm going to can him, that's the number I 
19 
call? 
20 
A. Correct. 
21 
Q. And was he always in charge of flight 
22 
directions? 
23 
A. No. ho was previously Chief Pilot. 
24 
Q. He was previously Chief Pilot for Limited? 
25 
A. Same, yes. 
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Larry Eugene Morrison - Volume I 
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1 
Q. And he was promoted. I suppose, to Flight 
2 
Director? 
3 
A. Director of Operations. Ifs the 
4 
department crew. Most small departments don't have 
directors until they start to grow. 
6 
Q. And when he was Chief Piot were you 
7 
affiliated with the Wexner organization? 
B 
A. Yes, I was a maintenance technician. 
9 
O. And when you say somebody keeps flight logs. 
10 
is it aNrays Ten— is his name Tim Staley? 
11 
A, Yes. 
12 
Q. - 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 clanged. 
15 
O. Okay. Are you — 
16 
A. I've been gone since —
17 
Q. Are you aware of any FM policies to where 
18 
they need to know who's on the aircraft whenever it talks 
19 
off? 
20 
A. Not under Part 97 0porations, there is 
21 
not 
22 
Q. Part what? 
23 
A. Part 91. 
24 
Q. What does Pan 91 say, as far as you know,/ 
25 
A. It's basically souls on board when you 
43 
I 
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 coining 
5 
and leaving the country. 
6 
Q. 
— then they require that names of 
7 
individualS — 
a 
A. It would be names, passports, that kind of 
9 
stuff - normal. 
10 
Q. Did you ever do any international flights 
11 
white employed by The Limited, Victoria's Secret, the 
12 
whole Wexner group? 
13 
A. Yes. 
14 
Q. How many? 
15 
A No way of knowing. I mean, fm can't 
16 
say. It's, like I say, years, but. 
17 
Q. What years would you done it? 
18 
A. Started Eying as a flight mechanic in 
19 
'89, and then started flying the Boeing In '99, so -
20 
to '01, so '89 tool, basically. 
21 
(hat Goldberger exited.) 
22 
BY MR. EDWARDS: 
23 
Q. S0'89 to '01, if I wanted all of the flight 
24 
logs, who would I request those from - Tim Staley? 
25 
A. Dent know. I don't know who — 
42 
1 
Ilea flight plan - that's the only thing you're 
2 
required to do. When you fie your• flight plan you 
3 
file souks on board. 
4 
Q. What does that mean, "souls on board? 
5 
A. In other words, living bodies on board. 
6 
In other words, If you have - so it there's an 
7 
accident and you have four and you're transporting a 
8 
cadaver, that they go to the accident scene and don't 
9 
find five bodies - think there were five falsities. 
10 
Q. So it's your understanding from what you need 
11 
by report are, "I have five people on board? 
12 
A Correct, and that's for the flight plan. 
13 
Q. So there's no reason to say that, have Joe 
14 
Scfimo on board." 
15 
A. Not under Part 91, no. 
16 
Q. That's doing something over and above. 
17 
A. That's correct. 
18 
Q. You are aware. though, that there are certain 
19 
fright plans where they actually name individuals that 
20 
are on the airplane? 
21 
MR. GOLDBERGER Form. 
22 
A. No. 
23 
Q. I mean, syttve seen that before. 
24 
MR. GOLDBERGER: En 
25 
A. No, not on flight plans, no - unless it's 
44 
1 
Q. 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 
Q. Certainly they're kept on file somewhere. 
7 
170 0
a 
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. Wet there were several companies. I 
13 
mean, the way corporate aviation flight departments 
14 
are sot up, they're under holdings companies. 
15 
O. I'll go with all of them. 
16 
A. Weil, I daft 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 - 
al 
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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Larry Eugene Morrison - Volume I 
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45 
for these, you know. 
2 
Q. Did Leslie Werner ever tell you that he 
3 
allowed Jeffrey Epstein to serve in some sod 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 
Q. What's the first time you ever saw Jeffrey 
9 
Efletein? 
10 
A. Can't say. I'm not sure. 
11 
O. 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 
Q. What year do you think that was? 
16 
A. tt would have had to have been —
17 
O. Talking late '80s, early '90s? 
18 
A. Late '90s. 
19 
Q. Late '90s? 
20 
A. Yeah, probably - mid to late Tres. 
23. 
Q 
Well, I mean, if you're taken over with 
22 
Jeffrey Epstein in, what, 2001 —
23 
A. Correct. 
24 
O. 
then you're talking late '90s is the first 
25 
time you see him? 
47 
1 
A. They were — They were generated, bull 
2 
don't know, you know, why- what the particular 
3 
reasoning was for it 
4 
Q. 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 FM. 
0. Okay. Now — 
9 
A. The FM doesn't care about flight logs. 
10 
Q. How did the FM monk.: when that plane took 
11 
off? 
12 
A. Flight plans. 
13 
Q. And was it your understanding that when the 
14 
plane took off, the FAA was unaware as to who was ever on 
15 
It? 
1.6 
A. Pretty much, yeah. They deal tare about 
17 
names. When you Be flight plans with the flight 
18 
service station or via electronically, all they care 
19 
about Is souls on board, contact Info-math:a, flight 
20 
routing. things kke that. 
21 
Q. Are there time limits as to when the plane is 
22 
allotted to take off? 
23 
A Yeah, usualy — From what point? What do 
24 
you mean? Time of the day or — 
25 
Q. Yeah, yeah. time of the day. 1 understand 
46 
A. Well, mid — I don't know exactly. I 
2 
can't realty say, really. 
3 
Q. I won't hold you to It It Is what it Is. 
4 
Mid to late '90s, if I wanted the Muhl logs 
5 
that have him on iit on the airplane, who would I 
6 
subpoena to got those records? 
7 
A. I have no idea. 
8 
Q. Are they turned into the FAA, to the best of 
9 
your knowledge? 
10 
A. No, the FM doesn't require them. 
11 
Q. So FAA does not get the flight — Wei, YAM'S 
12 
the point of even keeping these? 
13 
A Sometimes I think the IRS — I mean. this 
14 
is on assumption, I'm not even sure, but mostly for 
15 
Ike IRS tracking for if you have people that have 
16 
dual homes, dual statehoods, or whatever. 
17 
(Mr. Goldberger entered.) 
18 
MR. GOLDBERGER: Can we take a time out? 
19 
(Short break.) 
20 
(Mr. Pike appeared via telephone to 
21 
replace Mr. Goldberger.) 
22 
BY MR. EDWARDS: 
23 
Q. FAA flight logs- do you know why they're 
24 
generated, how they're generated, if they were generated 
25 
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 ail airports, no. No, airplanes can fly any 
5 
time unless that airport has a noise curfew or 
6 
something, yeah. 
7 
Q. Did you ever know of Wexner's plane to take 
8 
off after ten o'clock p.m.? 
9 
A. Yes. Yeah. 
10 
O. Were you ever on that plane when it did? 
11 
A. Probably, yeah, yeah. 
12 
Q. Were you ever on that plane when there were 
/3 
girls on the plane? 
14 
A. Describe 
Define *girls' On the Wexner 
15 
airplane? 
16 
Q. Yes. 
17 
A. 
There would be ladies and his daughters. 
18 
I mean —
19 
Q. 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 
Q. Have you ever been on the plane when there 
24 
were girlfriends of Leslie Wexner? 
25 
A 
Only when Abigail - before his - became 
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I 
his bride, yes. 
2 
Q. How about after - 
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 
Q. Have you ever seen sex or sex-related 
10 
instances occur on Leslie 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 Leslie Wexnees 
20 
airplane. it was used strictly for business? 
23. 
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 
Q. Was there ever a time when you were — 
51 
1 
O. Yes, with you on it. 
2 
A. I can't — I can't say. 
3 
O. Wet whore do you remember going in it? 
4 
A. Well, we would normally go to London. 
5 
Mien, Paris. I mean, mostly fashion areas and 
6 
business - business areas. 
7 
Q. When you say "fashion areas," what do you 
8 
mean? 
9 
A. Well, retail. I mean, you know, design 
10 
for clothing and stuff like that. 
it 
Q. What was the purpose? 
12 
A. rm sure it was business. I have no idea 
13 
what the actual purpose was. I don't —
14 
O. Did you get off the plane? 
IS 
A. Well, of course. 
16 
O. What did you do there? 
17 
A. Go to a hotel, eat dinner, wait to find 
18 
out when you're going to the next place. 
19 
O. Were you ever on an international flight o. 
20 
one of Ph. Wexner's planes that Jeffrey Epstein was also 
21. 
On? 
A. I cant say. I cant remember. 
23 
O. Maybe? 
24 
A. Possioly. 
25 
Q. 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. 
A. Yeah, I don't understand. I don't 
6 
understand that question. 
7 
O. 
turn going to clarify. Were there ever times 
8 
when you were on the plane and either Leslie 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 
le 
night on the long trips, okay. 
15 
Q. My time that more than one person went 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 Leslie Wexner? 
21 
A. Not many, but I can't sayexact 
22 
O. How many International flights do you remember 
23 
that plane taking? 
24 
A. Remember -- The airplane Itself taking 
25 
Internabonar? 
52 
1 
Jeffrey Epstein went what on that plane outside the 
2 
United States? 
3 
A. I can't remember. No, no. Like I say. I 
can't oven remember if we took it for sure. 
5 
Q. Any time that you remember Jeffrey Epstein 
6 
being on the airplane, do you also remember there being 
7 
girls on the airplane along with Mr. Epstein? 
A. I can't — I can't say. I cant remember. 
9 
Q. When's the first time you remember seeing 
10 
Jeffrey Epstein? 
11 
A. Wet Ilke I say, I dont even remember 
12 
the year. I can't even pinpoint down to the year. 
13 
It was after - some tine after I started flying the 
14 
727, because that's the only exposure. 
15 
O. Okay. rm not going to ask you at al during 
16 
this deposition to guess. I thought at sane point in 
17 
time you told me you remember seeing Jeffrey Epstein. 
1$ 
right? 
19 
A. Yes. 
20 
Q. In fact, you work for him now. 
21 
A. Yes. 
22 
Q. So at some point In time you saw him and you 
23 
saw him for the first time. 
24 
A. Correct. 
25 
O. When's the first time you remember seeing him? 
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1 
It may not be the first fine you saw him. When's the 
2 
Mgt time you remember seeing him? 
3 
A. '99, somewhere in that area. 
4 
Q. Alright in '99 were you working for Leslie 
5 
Wexner or were you working for Jeffrey Epstein? 
6 
A. Leslie Wexner. 
7 
Q. And do you remember the context in which you 
saw Jeffrey Epstein? 
9 
A. It was a ffight. 
10 
Q. What did Leslie Wexner ever tell you in terms 
11 
of who Jeffrey Epstein was? 
12 
A. Never told me anything who Jeffrey Epstein 
13 
was. 
14 
Q. Did you ever ask? 
15 
A. No. 
16 
Q. Did you ever ask back in 1999 when you saw 
17 
this guy, '1 wonder what he doer? 
18 
A. No. 
19 
Q. Not even curious? 
20 
A. No. It's not my place. I don't — I 
21 
don't need to know or want to know what people's 
22 
associations are. 
23 
Q. Next time you saw Jeffrey Epstein was when? 
24 
A. I can't say for sure. 
25 
O. Have you seen Jeffrey Epstein at Leslie 
55 
1 
Jeffrey Epstein helped to - I think, what you said was -
2 
manage Lest* Wexner's money? 
3 
A. Some of his accounts, yes. I guess. 
4 
O. Why do you think that? 
A. From what I've read in periodicals and 
6 
magazines. 
7 
Q. You've read in what periodicals and magazines? 
A. I think it was, what, Vanity Fair Mere 
9 
was an article a couple years back, three or 
10 
four years back, and a New York magazine as I 
11 
mentioned. 
12 
Q. Why did you read the article? 
13 
A. Well, obviously it was dealing with the 
14 
gentleman that I was working for, so out of 
15 
curiosity, you know. 
16 
O. Right, because people lend to be curious -
17 
A. Right 
18 
Q. 
— right? But when I just 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 
Q. Yes. 
25 
A. Well, yeah, when you're working for him 
54 
Wexner's house? 
2 
A. No. 
3 
Q. Never? 
4 
A. Never. I've never 
a 
Have you ever — 
6 
A. 
— been to Wexner's house. 
7 
O. You've never been there? 
8 
A. No. 
9 
O. Have you ever known of Leslie Wexner or heard 
10 
of Leslie Weimer having minor girls or minor boys at his 
11 
house? 
13 
A. Oh, no. 
13 
Q. 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. 
18 
Thank you. 
19 
Q. Have you ever known of Jeffrey Epstein to take 
30 
underage girls to Leslie Wexner's house? 
21 
A. No. 
22 
Q. Do you know how it is that Jeffrey Epstein and 
33 
Leslie Wexner met each other? 
24 
A. No. 
25 
Q. You mentioned eerier that you believed that 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
12 
23 
24 
25 
56 
and he's In a magazine, you're going to read the 
article. 
Q. Okay, so at some point In time, did you Googic 
Jeffrey Epstein? 
A. No. no. 
Q. Have you read the articles about Jeffrey 
Epstein? 
A. Lately? 
Q. Yes. 
A. Oh, of course, yes, in the newspapers. 
O. And you're aware of why your deposition's 
being taken today. 
A. Yes. of course. 
Q. And it has something to do not with a case 
with Leslie Wexner, but a case involvkig Jeffrey Epstein. 
A. Correct. Yes, of course. 
Q. When you got this deposition subpoena, did you 
by any chance try to look up some information on Jeffrey 
Epstein - who this guy Is? 
A. No, no. I mean --
Ct. Is there anything --
MR. REINHART: Hold on. Were you 
finished? 
Q. Okay. Go ahead. 
A. No. I mean, other than every once in a 
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1 
whie YR get a Google alert just following the case 
2 
- just out of interest - because he's still my 
3 
employer, you know, and you dont want to be 
4 
blind-sided, but other than that, no — 
O. When you - 
6 
A. 
— I never looked into his financial 
7 
background or anything look that. I don't know if 
a 
you can. 
9 
Q. When you say a *Goo& alert; that's 
10 
something that you actually go out of your way and set up 
11 
on Goode, right? 
12 
A. Yeah. 
13 
0. When dld you do that? 
14 
A. A year ago or so. 
15 
D. Why did you do it? 
16 
A. Because I'm net around W. Wexner - or Mr. 
17 
Epstein anymore. I don't --
18 
O. Well, he was In jail —
19 
MR. REINHART: Hold on. Were you finished 
20 
with your answer? 
21 
A. I haven't been a full line employee with 
22 
Mr. Wexner since — 
23 
MR. REINHART: Epstein. 
24 
BY MR. EDWARDS: 
25 
O. Epstein or Wexner? 
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 
59 
O. When you say 'fast pace?' how often are you 
flying? 
A. Every week - sometimes two, three times a 
week. 
Q. And that's by the time that you're working for 
Jeffrey Epstein? 
A. Yes. yes. 
O. Because back in the Leslie Wexner days you 
weren't flying every day. 
A. No, no, no, because there was another 
engineer, no. 
O. Right 
A. I had about one-third of the flights. 
Q. So from 1988, when you start working with 
Leslie Wexner, through '89 or so, you're not flying all 
the time, right? 
A. No. Oh, no, no. Actually, in138. I was. 
you know, I was - my primary duties were in the 
hangar - maintenance. 
Q. Did you enjoy doing that? 
A. The maintenance part of it? 
Q. Yes. 
A. Oh, yeah. that's my background, that's my 
forte. 
Q. Is that something that you've gone back to? 
58 
1 
A. I'm sorry — Mr. Epstein. since February 
2 
ci 2007. 
3 
Q. Well, a lot of that has to do with him being 
4 
Incarcerated --
5 
A. No, no. 
6 
Q. 
— 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 
Q. Did it bother you that your boss, back in 
14 
2007, was under investigation? 
15 
A. Of course. 
16 
Q. 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 
flying that I had been doing and the overnights, and 
20 
when something's no longer fun, It's time to find 
21 
something else to do. 
22 
Q. 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. 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
34 
25 
A. 
Q. 
A. 
Q. 
A. 
D. 
60 
Yes. 
When did you go back to that? 
February of '07. 
Who are you doing that for? 
Dankjold Reed Aviation. 
Say it again. 
A. Dankjold Reed Aviation. 
Q. How did you get that job? 
A. Applied for It and knew the previous 
Director of Maintenance, who was retiring. 
Q. Did Leslie Wexner and/or Mr. Epstein help you 
to get that job? 
A. No, no ties whatsoever. 
O. So who Introduces you to Jeffrey Epstein,
A. Probably it would have been Larry. The 
first actual formal introduction? 
Q. Right. 
A. Probably would have been Larry Visosk; I 
knew Larry and Dave when they flew for Giirrichei 
corporation. 
Q. Tell me a lithe bit about that. Larry 
Vlsosid - how do you know him? 
A. He's the Chief Pilot for Jeffrey and hired 
me. 
Q. Well, he's the Chief Pilot now - 
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Larry 
Eugene Morrison - Volume 
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6, 2009 
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1 
A. Right 
2 
Q. 
— for Jeffrey Epstein. 
3 
A. Right 
4 
Q. 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. 
Q. Flying for who? 
9 
A. Gilmcher Corporation. 
10 
Q. How do you spell that? 
11 
A. 
I think. They were -
12 
They had an airplane based at Lane Aviation in 
13 
Columbus with us. 
14 
Q. 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 
Q. Are you from here? 
20 
A. No. 
21 
Q. Where are you from? 
22 
A. Columbus. Ohio. 
23 
O. So you're from Columbus, Ohio, and that's also 
24 
a place where Leslie Wexner lives. 
25 
A. Yes. 
63 
Q. How did you learn of Leslie Wexner? 
2 
A. Oh, I mean, he's very well-known in 
3 
Columbus, because, you know. bilionaires in central 
4 
OW, aren't, you know - 
O. Aren't a dine a dozen, right? 
6 
A. Exactly, and small guy that made it big, 
7 
you know, because that's where the name Limited - so 
e 
hearsay is - the name limited came from he started 
9 
with united resources. 
10 
O. So did you know him before he was married to 
11 
Abigail? 
12 
A. Yes. 
13 
Q. And did you know him to date exclusively women 
14 
prier to that? 
15 
A. The only— I knew that he was dating 
16 
Sharon. 
17 
Q. 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. 
22 
Q. And have you heard any rumors about him dating 
22 
men as well? 
23 
A. No, no. 
24 
O. First time that you're heating about it is me 
25 
telling you that, right? 
62 
1 
Q. So that was at least convenient for you? 
2 
A. Oh, yeah. No, it was 
Yeah. 
3 
Q. Did you go to college in Ohio as well? 
4 
A. Yes. Columbus State for my Aviation 
5 
degree. 
6 
Q. As your first Job that you had, was that with 
7 
Leslie Werner? 
8 
A. Oh, no. I started working for Ohio State 
9 
University —
10 
Q. 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 oars umbrella for airport research. They had 
17 
an Aviation Research Department. Then after that 
Is 
went to Red Roof Inns - maintenance technician for 
19 
Red Roof Inns. 
20 
Q. What was it -Gregory Finns? 
21 
A. No, Red Roof Inns. 
22 
Q. 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 10 The Limited stores. 
64 
1 
A. Yeah. 
2 
Q. So back to Larry Vsosld - you don know him 
3 
while you're employed with Leslie Wexner. 
4 
A. Yes. 
5 
O. You do? 
6 
A. Yeah. 
7 
O. How do you meet tin? 
a 
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 
Q. Glimcher is a company owned by whom? 
12 
A. I don't know if ifs public or not. It 
13 
was a mall development company not associated with 
14 
Limited. 
15 
Q. So what's the conversation between you and 
16 
Larry Vtsoski? Obviously you all end up working for 
17 
Epstein, so try to lead me through that. 
18 
A Wel, I think —1 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 
plioUrnechanic on the Hawker for Glimcher, and you 
23 
kind of form a relationship and a rapport, and then, 
24 
I believe, anther sold their airplane. I don't 
25 
lawn Wm 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 
5 
them, "How — 
6 
O. Dld Jeffrey --
7 
A. 
— did you meet them?" 
8 
Q. 
— 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, rm on the phone, so I'm having 
17 
a hard time hearing 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: 19 do that for you, man. 
24 
rm 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 IL 
3 
O. So is Larry also an Ohio person? 
4 
A. Welt he wasn't — I think he was bom arid 
5 
raised in South Florida and then he was in Ohio for 
6 
that job. He eyed 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 
10 
mean, I don't know if It was a suburb, but they lived 
11 
In central Oleo. 
12 
Q. 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 
Q. 
— was very close in proximity to the aircraft 
19 
that they were piloting. 
20 
A. Yes. 
21 
Q. They approach you at sane 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 f1 
25 
I would be interested in, if Jeffrey bought the 727 
66 
MR. PIKE: Not a problem. I've objected 
2 
to form a couple of runes. I'm not quite sure 
3 
If that was even heard, but that's neither here 
4 
nor there. 
MR. EDWARDS: Wee say the last ten 
questions you objected to form. I got you. 
7 
What was my last question. Pike? You 
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 n you know, however you know, David 
18 
Rodgers was the first Epstein contact and then Larry 
19 
Visoskl rode it In. 
20 
A. The way I understand, yeah. 
21 
Q. 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 
I 
being, you know, the flight engineer and help them, 
2 
you know, get the flight department going, and I told 
3 
them I would. 
4 
O. And wily did you say "yes" considering that you 
5 
had a boss in Leslie Wexner wto vas seemingly pretty good 
6 
to you fox the last ten years? 
7 
A. Oh, he's excellent.
O. Yes. 
9 
A 
No, fine flight department and Mr. Wexner 
10 
is a line person. 
11 
Q. Right 
1.2 
A. The reason being is. you know. I already 
13 
staled this I think twice before, was that I wanted 
14 
to be abbe to continue to fly and that would give me 
15 
the opportunity to continue to fly as a flight 
16 
engineer and the challenge of starting this airplane. 
O. Right. I didn't Ignore you. I heard you say 
18 
that. but then I also heard you say he brought a brand 
19 
new plane. 
20 
A. It was ally a two-man airplane --
21 
O. So then he woukl have *-
22 
A. 
— and the modem aircraft could only have 
23 
two pilots, right 
24 
O. Got you. I understand. 
So they approach you with this prospect of the 
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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 geniis?" 
6 
A. Right. 
7 
Q. I mean, that's the gist of it. 
8 
A. Correct, that would be the gist of it. 
9 
Q. And your response was? 
10 
A. Yes, I would - you know, d 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 V 
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 wore all with Dave and Larry 
18 
both, you know, calling back and forth, but. 
19 
Q. 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 the brings us up in cur timeline to 2001, 
1 
2 
3 
4 
5 
6 
7 
a 
10 
11 
12 
13 
14
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
71 
A. I don't know. I don't know. 
Q. I mean, how did she gel on he private 
airplane? I would imagine strangers don't Just walk on. 
right? 
A. 
Yeah, but I don't know. I don't know what 
people's associations are together when, you know. 
O. Okay. 
A I don't know If it's business association, 
social associations, or what. 
Q. How many tinges --
MR. PIKE: Lot me object to the form of 
that question. 
MR. EDWARDS: Okay. Noted. 
BY MR. EDWARDS: 
Q. Now many times was she on that airplane when 
It was owned by Leslie Weimer? 
A. Not many. but I can't give you an exact. 
Q. Was she ever naked on the airplane? 
A. Not lhat I'm aware of. 
Q. I mean, that's something that you would 
probably remember, right? 
A. Well — 
MR. PIKE: Form. 
A. Yeah. I mean —
Q. rm not really trying to be funny. but I would 
70 
1 
you think? 
2 
A. Correct, that's when I hired on and 
3 
actually moved to Florida was January 2001. 
4 
Q. Prior to 2001, had you heard the name 
S 
Ghistalne Maxima? 
6 
A. Yes. 
7 
Q. How would you have heard Ghislaine Maxwell? 
8 
A. She had been a passenger on the 727 once 
9 
or twice. 
10 
O. The 727, I mean? 
11 
A. When It was under Limited. 
12 
Q. 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 k 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 
Q. What year do you think that was? 
19 
A. It would have been In the late '90s. 
20 
Again, lice I say, when - probably some time around 
21 
the time - you know, had to be late '90s —
22 
Q. Did she — 
23 
A. 
— maybe 2000. 
24 
Q. Did she seem kke a friend of Leslie 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 gins on 
4 
the airplane with he? 
5 
A No. 
6 
a 
You remember her getting on the airplane 
7 
alone? 
A. I can't say for sure. 
9 
O. Alright Maybe this will jog your —
10 
A. I mean, she was never just alone-alone. 
11 
like the only passenger or 
12 
O. Yes. 
13 
A. No, no, always with - when other people 
14 
wars on board. 
15 
O. And you just can't remember whether she 
16 
brought on board with her a male oaten:ale; is what 
17 
you're saying, right? 
18 
A. No. I mean — Restate the question. How 
19 
did you - 
20 
O. Sony 
21 
A. Derma *alone." 
22 
O. I don't mean, you know. If there's 15 
23 
passengers and she gets on. rm mom: Do you remember 
24 
her getting on and being accompanied by- either they 
25 
look the same car to the airport, they walked the runway 
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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 
Q. How many times do you think Mt. Epstein was on 
6 
that airplane? 
7 
A. I can't say for sure - not that many. 
8 
Q. Less than five? 
9 
A. That I saw him, yes, probably. 
10 
0. 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. EDWARDS: Right, right, right. 
25 
MR. REINHART: — since Mr. Epstein bought 
16 
the plane. 
17 
BY MR. EDWARDS: 
18 
Q. 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 Urns period. Mr. Epstein had his other -
23 
he already owned his other airplane. 
24 
Q. How did you know that? 
25 
A. Wall, because that's what Larry and Dave 
1 
A. 
2 
Q. 
3 
A. 
4 
Q. 
5 
A. 
6 
0. 
7 
years, 
8 
A. 
75 
Maybe mid-'90, early '90. 
We're talking — 
He didn't have that plane very long. 
Between '90 and '93. you're saying. 
Probably, yes. 
And between '90 and '93, if we use those 
you're familiar with the name "Jeffrey Epstein." 
Not until later when ho bought the 
9 
Guffstream In - later when he was, you know, like I 
10 
said, late '90. probably. 
11 
0. But you're aware that David Rodgers and 
12 
\floosie' are flying an airplane between '90 and '93 that's 
13 
owned by somebody. 
14 
A. Correct. Yeah. 
15 
Q. But you don't know the name of the person --
16 
A. Correct. Right. 
17 
0. - that is the owner. We're good. We're on 
18 
the same page. 
19 
'88, you start working for Leslie Wexner. 
20 
A. Right. 
21 
0. And the first time Epstein is on Leslie 
22 
Wexnees airplane is approximately when? 
23 
MR. REINHART: It's asked and answered. 
24 
BY MR. EDWARDS: 
25 
0. That you remember. 
74 
1 
were flying - the Gulfstream. 
2 
Q. 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 Gulfstream. 
6 
Q. Alright. Let me clarify this real quickly. 
7 
You got the job in 1988 with Wexner. 
A. Right. 
9 
Q. 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. Not at first. 
13 
Q. At some point in time. 
14 
A. Correct. 
15 
Q. And what point in time do you become aware 
16 
that that's happening? 
17 
A. I can't remember exactly when they bought 
18 
the Gtdfstream. They actually had a Hawker for a 
19 
short period. I don't know when that was. 
20 
Q. Was that also owned by Jeffrey Epstein? 
21 
A. Fora very shed period, and he traded it. 
22 
Q. The first Epstein plane that you're aware of 
23 
is that Visoski and Rodgers are on -
24 
A. Was a Hawker. 
25 
Q. -- was approximately what year? 
76 
MR. REINHART: Asked and answered. 
2 
A. I can't — The only time I would remember 
- 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 it he vas on previous times Without me 
6 
there. 
7 
Q. And when he is on the airplane. is he on the 
airplane with young girls? 
9 
MR. REINHART: It's also been asked and 
10 
answered. 
11 
A. No. 
12 
Q. Now we're back to Ghislaine Maxwell. and I 
13 
beieve your answer - with led me back to these 
14 
questions that I had previously asked, 'Was ChIstene 
15 
Maxwell on the airplane that Wexner owned that you know 
16 
of? - and I think your answer was, 'With Epstein' 
17 
MR. PIKE: Form. 
18 
A. !would — I would say if she eras on 
19 
there, It would be with him. I never knew — I would 
10 
not think that she would fly on It without hirn. 
21 
a 
Do you specifically remember her on the 
22 
airplane with him? 
23 
A. Can't say - I can't. 
24 
Q. On any or these flights that Jeffrey Epstein 
as 
and/or Mansell was on. did they fly internationally? 
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Larry Eugene Morrison - Volume I 
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77 
A. I know I brought her back one time from 
2 
England. I believe - I remember that - from London. 
3 
O. Brought Maxwell back from London, and was she 
4 
alone then? 
5 
A. I cant I can't say. I can't remember. 
6 
Q. I thought you said that if she was on the 
• 
plane it wouldn't have been alone. 
• 
A. More than likely she would have been with 
9 
Jeffrey. 
10 
Q. So do you think that you brought Maxwell and 
11 
Jeffrey together back from London? 
12 
A. More than ikety, but I cant say for 
13 
sure. I can't remember If he was on that flight. 
14 
Q. 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? 
11 
A. Correct. That's correct. 
18 
Q. What year are we taking about and whose 
19 
airplane are we taking about? 
20 
A. That would have been when the 727 was 
21 
Sti Limited - or Wexner. 
22 
Q. And that would have been around what year? 
23 
A. 2000, maybe. 
24 
Q. 2000? 
25 
A, '99, something Ike that. 
79 
1 
the Court lo be well aware that not all of my 
2 
form objections are coming through the 
3 
telephone. 
4 
MR. EDWARDS: Mike. how about this, of al: 
5 
of the people Involved, I think that you know 
6 
you can trust me here: If you say when we read 
7 
this back that you wanted a form objection. I'll 
a 
put it on the record right now you get - how 
9 
about that? 
to 
MR. PIKE: Not a problem. 
Lt. 
BY MR. EDWARDS: 
12 
Q. Alright. Have you ever looked at any of the 
13 
information from Customs and linrrigratIon related to 
la 
fright logs? 
15 
A. No. 
16 
Q. 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 upor 
19 
this airplane? 
20 
A. Captain. 
21 
Q. Who was the captain or who were the captains 
22 
that you are revere of - and try to give me years, If many 
23 
of them changed, to the best of your knonledOe - for 
24 
Leslie Wexner? 
25 
A. Primarily it would have been Tim Staley. 
78 
1 
Q. So this is almost into the transition 
2 
A. No, rm sorry. 
3 
Q. —hie It. 
4 
A. Let me think on the dates. 
5 
Q. Okay. 
6 
A. 
Yeah, I can't - I can't remember. 
7 
Q. Late '90s or 2000? 
S 
A. Late '90s. 
9 
O. Who has the flight logs from late Ws? 
10 
A. I don't know. 
11 
Q. But that's something that the FAA would have, 
12 
right? 
13 
A. No. 
14 
MR. PIKE: Form. 
15 
BY MR. EDWARDS: 
16 
Q. Flying internationally? 
17 
A. 'don't know if the FAA gets that. It 
18 
would more - most likely be Customs and Immigration. 
19 
MR. PIKE Are you guys getting my form 
20 
objections? 
21 
MR. EDWARDS: Yes. We got you. 
22 
MR. PIKE: Thank you. Brad, I Just want 
23 
on the record that not all of my form objections 
24 
are coming through, so if we have an issue with 
25 
this deposition - lam on the phone - and I went 
80 
1 
Jim Taylor, Rob Imlay. 
2 
Q. Rob? 
3 
A. Imlay, I-M-L-A-Y, 841 Hammond. 
4 
Q. Bill Hammond? 
A. Uh-huh. 
6 
Q. Bill Hammond tats becomes affiliated with Mr. 
7 
Epstein too, right? 
8 
A. Correct. 
9 
Q. We're going to get to that. 
10 
Have you ever been a captain? 
11 
A. No. 
12 
Q. And when you say that Ws not necessary -
13 
unless you're flying internationaRy, 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 
Q. Howdo you know that? 
19 
A. Because you can read the Mats, Part 91, 
20 
FAR 91, Operations. 
21 
Q. What's "FAR" stand for? 
22 
A. Federal Aviation Regulations. 
23 
Q. 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 prow. 
EFTA01110290