EFTA01247021

-4 
E. 
Condensed Transcript 
IN THE CIRCUIT COURT OF THE 15Th JUDICIAL CIRCUIT IN 
AND FOR PALM BEACH COUNTY, FLORIDA 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
Case No. 502008CA028051 
XXXXMB AD 
DEPOSITION OF 
LARRY EUGENE MORRISON 
TAKEN ON BEHALF OF THE PLAINTIFF 
VOLUME I 
Pages 1 to 200 
October 6, 2009 
10:55 a.m. 
Jennifer DiLorenzo, court reporter 
S 
ESQUIRE 
• Al tas4trOblioCeropOn> 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquiresolutions.com 
CONFIDENTIAL 
3501.150-002 
Page 1 of 92 
EFTA_00068793 
EFTA01247021

• 
• 
• 
CONFIDENTIAL 
3501.150-002 
Page 2 of 92 
EFTA_00068794 
EFTA01247022

Larry Eugene Morrison - Volume I 
October 6, 2009 
• 
• 
1 
211 TUR CIRCUIT COURT OP TER 15111 JWICJAL CIRCUIT IX 
AMU FOR PALM SEAM COUNTY. FLORIDA 
2 
3 
APPEARANCE OF COUNSEL 
On WWI of the Defendant 
MAKE I 
Pages I to 200 
3 
ATTERBURY. GOLDBERGER a WEISS 
BY: JACK MAN GOLDBERGER. ESO . 
4 
250 Ausbaban Avenue 
Suite 1400 
s 
. FL 33401 
Plaintiff, 
6 
Case No. 502000C11024051 
On bead of the DeiceOwe by 1444410TIE: 
/0703111 AD 
JEFFREY EPS/811I. 
BURMAN. CRITTON. LUTTER & COLEMAN 
Defendant. 
9 
BY: MICHAEL J. PIKE. E90.. 
SIS N. Reeler Drive 
10 
Suite 400 
IMPOSITION OP 
.F133101 
LARRY Puma Pomace 
11 
TAKEN ON OEMAL7 Of THE PLAINTIFF 
October 6. 2009 
12 
10,55 4.e. . 2:20 .n. 
13 
On behalf of the Aeneas: 
14 
LAW OFFICE OF BRUCE E. REINHART 
IS 
BY: BRUCE E. REINHART, ESO.. 
One Gavle» Center 
16 
250 S. AUSIrtien Avenue 
Jennifer Ditonne°. court reporter 
17 
Suite 1400 
acn, FL 33401 
10 
19 
20 
21 
22 
23 
24 
25 
2 
4 
A 
COUNSEL 
1 
INDEX OF EXAMINATION 
On beret dew Plante 
I40114STEIN. feet 
OT 6 ADLER 
2 
BY: BRADLEY J. EDWARDS LSO 
3 
WITNESS: 
4 
and MICHAEL HEELER. ESO . 
4 
LARRY EUGENE MORRISON 
401 East Las am Elooleverd 
Page 
Sum IMO 
B. FL 33394 
6 
DIRECT EXAMINATION 
By Mr. Edwards 
*5 
7 
a 
On WW1 cpt Mew% 
a 
CROSS-EXAMINATION 
By Ms. Ezell 
*190 
9 
9 
CROSS-EXAMINATION 
MERUELSTEIN 6 HOSIOVATZ. 
By Mr. Wilds 
0195 
10 
BY: JESSICA D. ARBOUR. ATTORNEYAT.LAW, 
10 
11 
18205 Biscayne Boulevere 
See 2216 
CROSS-EXAMINATION 
11 
By Mr. Pike 
*196 
12 
FURTHER REDIRECT EXAMINATION 
13 
By Mr. Edwards 
8199 
14 
On bete d 
ef 
13 
leNecee: 
14 
15 
14 
POOHURST ORSECK PA 
BY: KATHERNE.A. &ELL ATTORNEY-AT.LAW. 
15 
16 
INDEX TO EXHIBITS 
25W. Page« Seem 
1 
17 
Ptautfts 
19 
:9 
18 
E.101bIt 
Description 
Page 
On Whaled tpe 
by IMPIzewle 
19 
1 
Twenty-four pages of 'LIEGE. Inc.. 
20 
Passenger Manifest' 
ii198 
LAW OFFICE OF ROMP) WIWTS. PA. 
20 
21 
BY: IIICHANDWLUTS. ESC.. 
2290 ICIP•Avenue H. 
21 
21 
se. 404 
22 
33631 
21 
24 
24 
(Plaintiff's Composite 1 was attached to flic 
original transcript and codes of the transcript.) 
25 
25 
• 
ESQUIRE 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquIresolutIons.corn 
3501.150-002 
Page 3 of 92 
EFTA_00068795 
EFTA01247023

Larry Eugene Morrison - Volume I 
October 6, 2009 
• 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
5 
Deposition of LARRY EUGENE MORRISON 
October 6, 2009 
THE REPORTER: Do you swear the testimony 
you're about to give will be the truth, the 
whole truth. and nothing but the truth so help 
you God? 
THE WITNESS: So help me God. 
LARRY EUGENE MORRISON, having been first 
duly sworn, was examined and testified as 
follows: 
DIRECT EXAMINATION 
BY MR. EDWARDS: 
O. Tell us your name. 
A. Larry Morrison. 
O. And. Larry. where aro you employed right now? 
A. For JEGE. 
O. What's JEGE mean? 
A. Its the aviation flight department for 
Mr. Epstein. and my primary job * Dankjold Reed 
Aviation. 
MR. REINHART: Spell A 
A. D-A-N-KJ-O-L-D. and then the second word 
is Reed, R-E-E-D, Aviation. Its a corporate flight 
7 
1 
You know, it was a business decision made somewhere. 
2 
O. What does the company do? 
3 
A. What? The company? It's just a holding 
4 
company. I think, for the aircraft. It's not -- I 
5 
don't believe ft to be a money making company or a 
6 
real corporation. 
7 
O. You're saying 'for the aircraft.* I'm 
8 
interpreting that to mean you're talking about one 
9 
aircraft. 
10 
A. Correct. 
11 
O. Does that mean there's one or there's more 
12 
than one? 
13 
A. There's more. Ho 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 ancifor ride on? 
A. I used to. I haven't been -- Actually, I 
18 
stepped back from being physically Involved, just
19 
now I lust do paperwork - and it was February of 
20 
2007. So I haven't actualy physically been on the 
21 
airplanes other than I will lake the Boeing for 
22 
maintenance. 
23 
O. 
Since it seems like we've kind of skipped 
24 
ahead from 2001 to 2007, am I right that your first 
25 
involvement with Jeffrey Epstein of any way, shape, or 
6 
1 
department. 
2 
O. What do you dote him? 
3 
A. Director of Maintenance. 
4 
O. Okay, so you maintain his planes .-
5 
A. Correct. 
6 
O. 
should something go wrong? 
7 
A. Correct. Yes. Yep. 
O. Do you also --
9 
A. For maintenance. 
10 
O. Do you also fly on his planes? 
11 
A. On Mr. Epstein's? 
12 
a 
Yes. 
13 
A. I used to. I was a flight engineer --
14 
O. Okay. What.. 
15 
A. 
on his 727. 
16 
O. When you list your company - JEGE? 
17 
A. Yes. Yeah, it's just initials. It's an 
18 
ISC or heeding company. 
19 
O. How long has that holding company been around. 
20 
If you taw? 
21 
A. Since -- I think it was developed when I 
22 
came with the airplane • 2001. 
23 
O. Whose idea was it for that to come about - was 
24 
it yours? Was it his? 
25 
A. On, no, no, somewhere -- It wasn't mine. 
8 
1 
form was 2001? 
2 
A. 
That's Correct, yeah. 
3 
O. 
You didn't meet him before that. 
4 
A. I had met him. He was a -- He was an 
5 
associate of my previous boss. 
6 
Q. 
Who's that? 
7 
A. Mr. Wexner. 
8 
O. Leslie Wexner? 
9 
A. 
Yes. 
10 
O. How do you know Leslie Wexner? 
11 
A. I woiked for Limited Stores for 12 years. 
12 
O. Doing what? 
13 
A. Essentially the same thing - aircraft 
14 
maintenance for their corporate flight department and 
15 
flight engineering on the 727. 
16 
Q. How many aircraft did Leslie Wexner have? 
17 
A. Well none that I know that he had 
18 
personally, but the corporation had - the flight 
19 
department operated • we had three Gulfstreams, two 
20 
Hawkers, and a 727. 
21 
O. What was the name of his corporation that 
22 
maintained the aircraft? 
23 
A. For Limited Stores? 
24 
O. 
Yes. 
25 
A. It was just 
It was called Limited - 
0 
ESQUIRE 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Ofas Boulevard 
Fort Lauderdale, FL 33301 
www.esquIresolutions.com 
• 
• 
• 
3501.150-002 
Page 4 of 92 
EFTA_00068796 
EFTA01247024

Larry Eugene Morrison - Volume I 
October 6, 2009 
• 
• 
9 
1 
Limited Flight Department. 
2 
O. And do you know him personally then - Leslie 
3 
Wexner? 
4 
A. Yeah. I had met him. of course, you know. 
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. 1988 was when I hired on, so I don't 
9 
remember the month. 
10 
O. How did you gel that fob? 
11 
A. Through word of mouth and, you know. I 
12 
worked • I lived in - been in aviation for years in 
13 
Columbus. 
14 
O. Well, I mean. Leslie Wexners an important 
15 
person, right? I mean, he --
16 
A. Correct. 
17 
MR. GOLDBERGER: Form. 
18 
BY MR. EDWARDS: 
19 
O. He's somebody who owns my understanding -
20 
Limited, Victoria's Secret? 
21 
A. Well, he doesn't own them. He's Chairman. 
22 
you know. 
23 
O. Chairman of --
24 
A. Yeah. He doesn't personally own it. Its 
25 
a publicly held company. 
2 
3 
4 
5 
6 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
11 
O. Yes. 
A. Aircraft technician. 
O. Which entails what? 
A. Maintenance of any or all of the aircraft 
operated by the flight department and some flight 
mechanic duties. 
O. What kind or airplanes? 
A. Gulfstreams, Hawkers. 
O. How big is the Gulfstrearn? 
A. Fifteen passenger - 15 to 17. 
(Mr. Goldberger exited.) 
BY MR. EDWARDS: 
O. What did Wexner use the Gullstream for? 
A. They were division airplanes, mostly. 
O. 
And the other airplane you named • what did he 
use that for? 
A. 
Same, same. 
O. Any idea why he had two planes? 
A. Well, I mean, yeah, we used them - they're 
a tool. It wasn't tam. II was a large Fortune 500 
company. They use them as tools to 
You know, 
Limited 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.' its not 
1 
2 
3 
4 
5 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
10 
O. Where were you prior to any involvement with 
Leslie Wexner? 
A. I worked for Red Roof Inn True Sports 
Flight Department. 
O. 
How did that position lead you to Leslie 
Wexner? 
A. 
Well, it was always known that Limited 
Flight Department was one of the best jobs in 
Columbus and, actually, several other people that 
were already there knew me from previous jobs and 
education - we went through aircraft mechanic, or A&P 
school, together - so when the position became 
available they pointed to me and - absolutely. It 
was a fine organization. 
O. So did Mr. Wexner approach you or did you 
apply to him or how did that work? 
A. Oh, no, no, no. It's -- No. He wouldn't 
be involved in that type of activity. You apply to 
H.R, and you interview with the Director of 
Operations or the Chief Pilot. You know. he 
w0ukInt 
O. So you start with Wexner in 1988. 
A. Yes. 
O. What do you do for him then? 
A. What ced I do for him? 
12 
1 
just Limited, its Victoria's Secret and it was 
2 
Express and Lemers and Henn Bendel's and all of 
3 
that back then. so. I mean --
4 
O. So -
s
A. 
we moved a lot of passengers to keep 
6 
those stores for the retail business. 
7 
O. And by 'passengers,' do you also mean clie-is 
of his? 
9 
A. That I don't know. No. Mostly we lust 
10 
dealt with upper echelon, you know, people in the 
11 
retail businesses from --
12 
O. Such as whom? 
13 
(Mr. Goldberger entered.) 
14 
A. Can't even remember names, but it would be 
15 
We would take buyers to Europe in the spring and 
16 
fall. They would buy samples and bring them back to 
17 
analyze for marketing. We would hire -- We would —
18 
Division heads, when they would do store shops and. 
19 
Real Estate, we take Real Estate out when they were 
20 
looking for new real estate. 
21 
O. While you were working back in BI3- Well, 
22 
how long overall did you work with Leslie Wexner and/or 
21 
his companies? 
24 
A. Well, '88 through when I came hero in 
25 
January of '01. 
• 
0 
ESQUJ.0.4E .1
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquiresolutions.com 
3501.150-002 
Page 5 of 92 
EFTA_00068797 
EFTA01247025

Larry Eugene Morrison - Volume I 
October 6, 2009 
13 
1 
O. 
Why the change? 
2 
A. It offered an opportunity -- Well, one was 
3 
I enjoyed flying - and the 727 was being replaced by 
4 
a BBJ, which is a two-man airplane. not a three-man 
5 
airplane three-pilot airplane - and it gave me the 
6 
opportunity to become a Director of Maintenance. and 
7 
it was a challenge. You know, bringing upstarting 
8 
an airliner on a private ticket or a VIP ticket is 
9 
really challenging, and I enjoy the challenge of 
10 
world% arid developing the program and stud. 
11 
O. Well, my understanding. Leslie Wexner Is 
12 
generally - he's in Ohio. tight? 
13 
A. No, he's got other places. I mean -- No. 
14 
he's like anyone, he's - in hiS Category - he's got 
15 
multiple homes and —
16 
O. Well, when you would maintain his aircraft, 
17 
would that be in Ohio --
18 
A. 
Yes. We were based --
19 
O. 
or elsewhere? 
20 
A. We were based at Lane Aviation. 
21 
MR. REINHART: HOld on one second. You 
22 
have to let him finish asking the question 
23 
before you answer. 
24 
THE WITNESS: Okay. I'm sorry. 
25 
BY MR. EDWARDS: 
15 
I 
aircraft. I mean, whatever a takes to keep a 
2 
corporate flight department operating. 
3 
O. Did you know back then of his relationship. it 
4 
any. with Jeffrey Epstein? 
k 
Not immediately. no. 
6 
O. When is the first time that you know of a 
7 
reputation or a relationship between Wexner and Epstein' 
e 
A. Would have had to probably be around maybe 
9 
'98,'99. 
10 
O. How do you become aware that they know ono 
11 
another? 
12 
A. Because Jeffrey. every one 
That's when 
13 
I became a flight engineer on the Boeing. and every 
14 
once in a while Jeffrey would ride on the Boeing. 
15 
that's all • that's all I knew. 
16 
O. How ckd 4 come about that he would nde on 
17 
Wexners Boeing? 
le 
A. 
They were business associates, I think. 
19 
O. As far as you knOw, they were business 
20 
associates. 
21 
A. Right. 
22 
O. Did you understand the business retationsh-p 
23 
between the two? 
21 
A. 
Web, I believe it's pubic knowledge 
25 
that, I think, Jeffrey managed Mr. some of Mr. 
14 
1 
O. I'm sorry, have you ever had your deposition 
2 
taken before? 
3 
A. No. 
4 
O. You definitely never had your deposition taken 
before while somebody else is trying to eat at the same 
6 
time they're trying to ask the questions - that's very 
7 
bizarre. 
8 
A. 
Yes. yes. 
9 
O. I meant to do this before I got here. But, 
10 
regardless. Ill wail until you finish your answer before 
11 
I ask my next question; you do the same thing. 'Uh.huh' 
12 
or •uh-uh,' they kind of look the same on the record, so 
13 
try to give us a'yes' or to' or something we 
14 
understand. 
15 
A. Alright. 
16 
O. II I ask a question that was a bad question or 
17 
something you don't understand ive asked bad questions 
18 
before • say. 'I don't get it' I'll ask a better 
19 
question. 
20 
A. Okay. 
21 
O. You were working with Leslie Wexner. You got 
22 
the job there starting in 1988. On a day-to-day basis. 
23 
what would you be doing? 
21 
A. 
Maintenance, aircraft maintenance, 
25 
tracking of aircraft maintenance. cleaning of 
16 
1 
Wexnees funds. 
2 
O. Is that something that Mr. Wexner told you? 
3 
A. No. 
4 
O. Is that something that somebody of Mr. 
5 
Wexner's organization would have told you? 
6 
A. No. 
7 
O. Is that something that Jeffrey Epstein told 
a 
you? 
9 
A. No. 
10 
O. Is that just reading articles that speculate 
11 
as to the business relationship between the two or do you 
12 
got something more for me? 
13 
A. No, it's just it's speculation and, you 
14 
know, what I've read. you know. 
15 
O. I mean, like you say, to me ifs common 
16 
knowledge --
17 
A. Right. 
18 
O. But irs only because of what I've road. 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 persona 
23 
relationship, if any, between Wexner and Epstein' 
24 
MR. GOLDBERGER: Form. 
25 
A. Don't know. 
0 
ESQUIRE 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquIresolutIons.com 
• 
• 
• 
3501.150-002 
Page 6 of 92 
EFrA_00068798 
EFTA01247026

-19 
Larry Eugene Morrison - Volume I 
October 6, 2009 
• 
• 
17 
1 
O. Did you ever know of a time -- And I may be 
2 
asking a question that would just be completely outside 
3 
of your knowledge. so lot me back up. 
4 
Have you ever stayed at Leslie Wexner's house? 
A. No. 
6 
O. Do you know where his house is? 
7 
A. Yes. 
8 
Q. Do you know what the address is in Ohio? 
9 
A. ND. I just know the City. 
10 
O. Do you know who he lives with? 
11 
A. Yes. 
12 
O. Who is that? 
13 
A. His wife and Children. 
14 
O. What's his wile's namo? 
15 
A. Abigail. 
16 
O. Abigail Wexner. and he has three or four 
17 
daughters. ngM? 
18 
A. No. He's got a son. 
M
 
.
 
and two 
19 
daughters. I think. 
20 
O. 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 - it they have more kids 
23 
now. 
24 
O. Okay. Did you ever hew any information that 
25 
he was homosexual? 
19 
1 
O. Have you spoken personally with Mr. Wexner? 
2 
A. On bus:Mess issues, yes. 
3 
O. Business Issues related to your work on his 
4 
airplanes? 
A. Correct. 
6 
O. Have you spoken to him on any other Issues 
7 
that don't involve business relationships with his 
e 
airplanes? 
9 
A. 
No. 
10 
O. 
Because you're hired basically for that 
11 
purpose. so that's kind of how you deal with him. 
12 
A. 
Yeah. Ifs I'm an employee and he's my 
13 
employer and I only deal with him, you know. en 
14 
issues that involve maintenance. 
15 
O. I think I probably knOw the answer to the next 
16 
question, but just in case I don't, do you knOw any of 
17 
his personal friends people that he would hang out with 
l8 
on a social level - being Mr. Wexner? 
19 
A. Through my business ties, yes. yes 
20 
O. Who's that? 
21 
A. I'm hying to remember - You have to 
22 
remember its been several years. 
23 
O. Right. 
24 
A. He was friends with the Tuckermans. 
25 
O. What's Mr. Tuckerman or Ms. Tuckennan's names? 
1 
2 
3 
4 
5 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
18 
A. No. 
O. Being Mr. Wexner. 
A. No. 
O. My Indication to you that he may be 
homosexual or bisexual? 
A. Absolutely not. 
O. Have you heard any Information that he and Mr. 
Epstein were involved sexually with one another? 
A. Oh. no. no. 
O. Would that surprise you? 
A. Absolutely. 
O. And Mars only because you know him and you 
know Mr. Wexner and you don't see the two together. 
A. Correct. 
MR. GOLDBERGER: Form. 
A. Weil — 
A. Go ahead. 
MR. REINHART: If you need to answer, 
answer the question. 
A. 
Yeah. No. I saw him with Sharon, which 
was his previous girlfriend before he met Abigail. 
O. Right. 
A. No. There was never any hint or anything 
Mat I would even conceive that. 
20 
1 
A. Ms. - I cant. I always addressed them 
2 
by their proper name. 
3 
O. Do you know what they do? 
4 
A. 
They owned an optical company - opticians. 
s 
They were high school friends from Mr. Wieners high 
6 
school days. 
7 
O. In Ohio or New York? 
8 
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? 
3 
MR. GOLDBERGER: Form. 
14 
A. I don't understand. Can you rephrase il? 
15 
O. Wet 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 Mat he was 
18 
friends or acquaintances with Mr. Epstein was V8 -
19 
almost ten years later. 
20 
A. Right. 
21 
O. 
After you became aware that Mere was that 
22 
relationship. whether business or otherwise, did he ever 
23 
speak to you about how long he had known Mr. Epstein? 
24 
A. Oh. no. no. 
25 
O. So as far as you were concerned. 1998. when 
• 
0 
ESQUIRE 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquiresolutiOnS.COrn 
3501.150-002 
Page 7 of 92 
CONFIDENTIAL 
EFrA_00068799 
EFTA01247027

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 
O. Aside from aircraft technician and taking care 
5 
of Mr. Wexner's aircraft back in the '80s and. I guess. 
6 
early '90s, did you have any other personal involvement 
7 
with him? 
8 
A. 
Just on aircraft completions. 
9 
O. And when you would speak with him, would that 
10 
be over the telephone, at the airport, at his private --
11 
A. It would usually be al the corporate 
12 
office. 
13 
O. Al the corporate office? 
14 
A. At he corporate office. 
15 
O. Can you tell me the address for his corporate 
16 
CAM? 
17 
A. No, I can't 
18 
O. If I requested that from your attorney, would 
19 
you be able to got that information? 
20 
A. 
Well, I mean, I imagine it's public 
21 
knowledge • wherever - it's at the Limited. 
22 
O. And that's where you would meet him • at the 
23 
Limited? 
24 
A. 
Yeah. 
25 
O. And how often was • you know, I know that 
23 
1 
O. Who were some of the pilots? 
2 
A. 
Tim Staley. Jim Taylor. They've had some 
3 
tumover too. I don't know who all is still there 
4 
because retail is down. 
5 
O. 
Was Larry Visoski a pilot used by Leslie 
6 
Wexner at any time? 
7 
A No. 
8 
O. How about David Rodgers? 
9 
A. No. 
10 
O. 
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 I was flying for Mr. 
14 
Epstein. 
15 
O. 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. Wexner 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 pathos? 
22 
A. No. I'm sorry, resay that. 
23 
O. Okay. You've already told us that you were 
24 
the aircraft technician for Mr. Wexner. 
25 
A. One of them. One of several, yes. 
22 
1 
we're talking about 15. 20 years ago - how often was Mr. 
2 
Wexner personally al that location at the Limited 
3 
offices? 
4 
A. I have no idea. 
O. But any time you needed to talk to him. that's 
6 
where he would be? 
7 
A. 
Yeah, and I usually went to Charlie 
8 
Hinson. 
9 
O. 
Who's Charlie Hinson? 
10 
A. He was the president of the stores. He 
11 
basically was my go-between for these aircraft 
12 
completions for the design. 
13 
O. And you mentioned the Gullstream as an 
14 
aircraft Did you also serve as a technician for other 
15 
aircrefts that were owned by Mr. Wexner? 
16 
A. Right but not Mr. Wexner. They're owned 
17 
or operated by Limited Stores. 
18 
O. Limited Stores? 
19 
A. 
Right. Yes. 
20 
O. What did you do for them? 
21 
A. Same maintenance. 
22 
O. Did you ever fly in them? 
23 
A. On the Gullstreams in the early days we 
24 
used flight mechanics, especially on international 
25 
flights. 
24 
1 
O. One of them. Then you also have knowledge 
2 
about Mi. 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 
O. Do you knew how Mr. Wexner met Mr. Epstein? 
9 
A. No. 
10 
O. How long - if you started in 1988 how long 
11 
did you slay with Mr. Wexner and/or The Limited? 
12 
A. January of YR. 
13 
O. Why did you stop? 
14 
A. Because what we were talking before, you 
15 
know, I wanted to continue flying. They bought a 
16 
BBJ. which is a two-pilot aircraft, and I wanted to 
17 
continue flying. Mr. Epstein bought the 727 and 
18 
offered me a position to continue flying and, you 
19 
know, basically sot up the airplane for his flight 
20 
department because they hadn't had any previous large 
21 
aircraft experience. 
22 
O. I missed something. It wasn't your fault, it 
23 
was mine. 
24 
The Gulfstream that you were talking about. 
25 
did you used to fly that as well as being a flight 
ESQUIRE
O
n
rtfaaa 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquIresolutIons.com 
• 
• 
• 
3501.150-002 
Page 8 of 92 
EFTA_00068800 
EFTA01247028

Larry Eugene Morrison - Volume I 
October 6, 2009 
• 
• 
25 
1 
technician? 
2 
A. No, no. 
3 
O. Okay. 
4 
A. You don't have to have a flight a 
• 
pilots certificate to be a professional flight 
6 
engineer. I've got a turbo a (fight engineer turbo 
7 
jet rating, but you don't have to have a commercial 
8 
ticket as long as you • the FAA recognizes your heavy 
9 
aircraft maintenance experience. 
10 
O. 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 
O. Then you can also fly them? 
16 
A. Sideways as a flight engineer. 
17 
O. Explain. 
3.43 
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 
O. When you say. "sits sideways: okay, I have 
24 
a — 
25 
A. Literally, you're physically sideways in 
27 
1 
O. Do you know why Epstein chose to buy that 
2 
particular 727 rather than one of the other million 727s 
3 
that are made? 
4 
MR. GOLDBERGER: Form. 
5 
A. Because it was probably the finest one out 
6 
the 
7 
O. Why? 
8 
A. -- in all honesty. It's got a fully Paged 
9 
STC interior with EMS cockpt. and Limited's 
10 
reputation on the way that we maintained our aircraft 
11 
- Its the best one out there. 
12 
O. Describe for me the interior • I'm not talking 
13 
about the Epstein days, we're talking about the Wexner 
14 
days describe for me the interior of the aircraft, and 
15 
keep in mind that I've only been on a commercial aircraft 
16 
where you donl 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 slays. which most 727's don't, 
22 
so you enter the forward door on the left-hand side. 
23 
the forward entryway vestibule, and there's a door on 
24 
the left, which leads to the cockpit, and then 
25 
there's a door on the right which leads aft to the 
26 
1 
the cockpit 
2 
O. So you're not looking at the people that were 
3 
flying on the plane and you're not looking at the pilots. 
4 
yottre actually literally sitting sideways. 
S 
A. I sit sideways at a panel, yes. 
6 
O. What's your job? 
7 
A. Maintain all the aircraft systems - the 
• 
hydraulffs, fuel management, pressurization. 
9 
environmental controls. 
10 
O. That's not done by the pilots. 
11 
A. Now. 
12 
O. But if you've done that long enough and FAA is 
13 
aware of your credentials in that respect, then you also 
14 
could be credentlaled to be a pilot as well? 
15 
A. Well, sure, yeah, yeah. If that's a 
16 
career choice you wish to take. 
17 
O. 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 
O. What year did you say Epstein bought the 727 
22 
that was once owned by Wexner? 
23 
A. I don't know when the actual transition 
24 
took place, but when I came - shortly around the 
25 
period that I came on board In 
. January of bl. 
28 
1 
forward salon. 
2 
O. 
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 it - in that there are 25 or 26 rows and they're 
6 
numbered A through E? 
1 
A. No. no. its a corporate configuration. 
8 
O. Which means nothing to me, so help me. 
9 
A. Picture a 600-mile an hour Winnebago. I 
10 
mean, its got conference tables and divans and large 
11 
first class seating. 
12 
O. Any various dividers throughout --
13 
A. 
Yes. 
14 
O. 
-- to where there's a VIP room in the back or 
15 
anything like that? 
16 
A. It's compartmentized (sic), yes. 
17 
O. In what way? Descnbe it as specifically as 
18 
you can. 
19 
A. 
There's a forward salon, a mid galley 
20 
the galley's in the mid - an aft • an aft salon, 
21 
which is and then the aft stale room. 
22 
O. 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. 
• 
0 
ESQUIRE 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquiresolutions.com 
3501.150-00i 
Page 9 of 92 
EFFA_00068801 
EFTA01247029

Larry Eugene Morrison - Volume I 
October 6, 2009 
29 
1 
0. Who directed the design ot that plane? 
2 
A. It would have been Mr. Wexner. I mean, it 
3 
was -- The layout has not changed. 
4 
0. 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 of 'under the employment of 
7 
Wexner to the time I've been on it since with Epstein. 
Es 
the configuration is the same' 
9 
A. Essentially, yes. We removed one chair 
10 
and one small table that was an annoyance and that's 
11 
it, but it's identical to what The Limited used. 
12 
0. 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 sections. 
17 
O. How big aro these dividers and where are 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 
Me state room. 
25 
0. Have you been on other 7275 before that are 
2 
3 
4 
5 
6 
9 
to 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
31 
because obviously there's a lot - there's not that 
many --
A. Privately owned 7275. but this is 
As a 
matter of fact The Limilects current BBJ has a very 
similar floor plan. 
0. As Trump's? 
A. No, as the as our 727. 
0. Who's 'our'? 
A. 
Mr. Epstein's. They didn't change a lot. 
It's -
O. 
Well, I thought that you had told me that the 
727 that was once owned by Wexner is the 727 that's owned 
by Epstein. 
A. It is, but what I'm saying is even their 
current airplane has the same layout - the BBJ. They 
put the same floor plane in the more modern airplane 
0. Well, they dam have 10 put it there. It 
was already there. nght? 
A. No, no. no. When you buy these aircraft -
even a Gullstream when you buy them its just a 
green hull, there's nothing in them, and you can 
customize your interior. 
0. I'm sony, we're miscanmunicating so.n8l to 
and I m sure its on me. 
MR. GOLDBERGER: Yes. it is 
1 
3 
4 
5 
6 
9 
10 
11. 
12 
13 
14 
15 
16 
17 
16 
19 
20 
21 
22 
23 
24 
25 
30 
commercial airliners privately owned? 
A. 
Yes, yes. 
O. 
Have you noticed similar configurations to 
where there aro this many dividing doors or is this one 
that has more so than you've seen in the past? 
A. No. no, this is pretty atypical (sic). 
O. It's pretty atypical? 
A. It's typical. 
0. It's pretty typical? 
A. Yes. yes. 
0. So what other airplanes - 727s, or other major 
airplanes - have you been on that have these types of 
dividers? 
A. 
Trump. 
0. Trump's airplane? 
A 
Yes. 
0. Why were you on Trump's airplane? 
A. 
Well, I know the crew and, you know, this 
Is a small-knit community. There's not very many of 
them out there, so everybody in this world knows one 
another to help one another out as far as —
0. By 'there' --
A. 
information-wise and stuff. 
Q. By hhere aren't that many of these people out 
there' you don't mean there's not that many people • 
3 2 
MR. EDWARDS: And l -m taking the blame for 
rght away. 
3 
MR. REINHART: Take that. Ed. 
4 
MR. EDWARDS: Alright 
5 
BY MR. EDWARDS: 
6 
0. My understanding - and please correct me when 
7 
I'm wrong. because I knew I am - Wexner has this 727 and 
8 
he designs it in a certain way. 
9 
A. Uti-huh. 
OA. 
YAnd 
ee.then you come to work for Epstein-. 
11 
12 
who buys the same 727. Your testimony, as 
13 
I'm understanding It, Is: It's basically the same 800r 
14 
plan as Wexners floor plan. To me, it should be the 
15 
exact same because he bought the same plane. 
16 
A. No. he -- You're misunderstanding. 
17 
0. I figured. 
18 
A 
What I was stating is 
You were 
I was 
19 
answering the question in regards to, 'Is this 
20 
unusual to have thiS many compartments and closed 
21 
doors and bulkheads and things?' 
22 
What I was trying to state was: NO, its 
23 
not unusual - because The Limited even Mod the 
24 
Floor plan so wee in their old airplane that they 
25 
sold to Mr. Epstein. They duplicated it in their new 
ESQUIRE 
Oa Altandwrall•Canpa 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquiresolutions.com 
• 
• 
• 
3501.150-002 
Page 10 of 92 
EFTA_00068802 
EFTA01247030

Larry Eugene Morrison - Volume I 
October 6, 2009 
• 
• 
33 
1 
airplane - see what I'm saying? That's all I was --
2 
O. 
So they didn't keep the floor plan. They 
3 
actually took it out and they restructured the floor plan 
4 
to basically match that old floor plan. 
5 
A. Well. no. When you -• When you buy a 
6 
Boeing business jet —
7 
Cy 
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 install this 
12 
Interior. 
13 
O. 
Right. 
14 
A. What I was just trying to state was that 
15 
The Limited liked their old floor plan in the old 
16 
airplane so well - it worked so well for them - that 
17 
they duplicated it and had that same interior 
18 
installed in the new aircraft • same floor plan 
19 
installed on the new plan. 
20 
O. So Epstein didn1 buy the exact same plane. 
21 
He bought the same type of plane. 
22 
A. 
Well, more modem. He bought a 737. 
23 
right. 
24 
O. Got it. 
25 
A. Right. 
35 
1 
had a very identical or very like floor plan 
2 
installed in the new airplane. 
3 
O. Coln 
4 
A. 
Okay? 
Sorry, it's a strange business. 
5 
It's — 
6 
O. Tell me if I'm right: Mr. Wexner had a plane 
7 
that had a floor plan that apparently appealed to Mr. 
8 
Epstein, so Mr. Epstein bought that plane. 
9 
A. Correct. 
10 
O. 
Mr. Wexner also liked that plane that he had 
11 
just sold to Mr. Epstein, so he built in a floor plan 
12 
very similar to the one he just sold to Mr. Epstein 
13 
A. In his new aircraft. 
14 
O. 
Brand new plane. 
15 
A. 
Correct. 
16 
O. 
Got it. We're on the same page now. 
17 
A. 
Alright. 
18 
O. Took us a while to get there. 
19 
A. Yeah, sorry. 
20 
O. I think it was my fault, honestly, but 
21 
alright? 
22 
A. It's an unusual process it you haven't 
23 
been around corporate airplanes. 
24 
O. 
I didn't realize that Mr. Wexner had a new 
25 
plane. 
1 
2 
3 
4 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
34 
MR. REINHART: Hold on. 
BY MR. EDWARDS: 
0. Totally understand now. 
MR. REINHART: Can you clarify - Mr. 
Epstein or Mr. Wexner? 
BY MR. EDWARDS: 
O. Mr. Epstein bought not Mr. Wexner's plane. 
A. No. 
O. He bought the same type of plane that Mr. 
Wexner had and modeled the floor plan --
A. No. 
O. -- the same way that Mr. Wexner had it. 
A. That is not correct. 
O. He bought, actually. Mr. Epstein --
MR. REINHART: Hold on. Distinguish --
Use names so we're very clear when you're 
talking about Mr. Epstein and Mr. Wexner. okay? 
A. Mr. Epstein bought Mr. Wexner's 727. 
O. Okay. 
A. The actual airplane - bought it from him. 
Q. Which has a floor plan already in it. 
A. That we just discussed. 
O. Alright. The floor plan's in the plane. 
A. Right. Mr. Wexner replaced the airplane 
that Mr. Epstein bought with a new airplane and he 
36 
1 
A. Yes. 
2 
O. Thars where I had a problem. 
3 
How many times have you been on Mr. Wexner's 
4 
airplane? 
5 
A. The new? 
6 
MR. REINHART: Clarify which one you're 
7 
talking abaft. 
8 
BY MR. EDWARDS: 
9 
O. Before you ever met Mr. Epstein. 
10 
A. I can't say. I mean. over the years? 
11 
O. Numerous times? 
12 
A. Oh, I was his flight engineer. You mean 
13 
when I was still employed by him? 
14 
O. 
Yes. 
15 
A. 
Yes. I was the flight engineer. I 
16 
don't --
17 
O. So as a flight engineer, every time the plane 
18 
leaves the ground, do you leave the ground with it? 
19 
A. No. We had another engineer also. 
20 
O. So what percentage of times do you leave the 
21 
ground in the airplane when the plane leaves the ground? 
22 
A. For who? 
23 
O. For Mr. Wexner. 
24 
A. Probably one-third of the time. because I 
25 
was also the lead technician, so 1 had 
• 
0 
ESQUIRE 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquiresolutIons.com 
3501.150-002 
Page 11 of 92 
EFTA_00068803 
EFTA01247031

Larry Eugene Morrison - Volume I 
October 6, 2009 
37 
1 
responsibilities in the hangar. whereas the other 
2 
engineer was a full time engineer 
3 
O. And given the partitions that you've descnbed 
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 aro open or closed? 
8 
O. Closed. 
9 
A. No. 
10 
O. Do you have any idea what's taking place in 
11 
there? 
12 
A. No. 
13 
MR. GOLDBERGER: Form. 
14 
8Y MR. EDWARDS: 
15 
O. 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 
18 
planes, should there be logs of the names of the 
19 
passengers on the planes? 
20 
A. Not required, no. 
21 
O. Are you ever specifically instructed not to 
22 
record the names? 
23 
A. That wasn't part of my duties. That 
24 
wasn't an engineers task, but --
25 
O. Do you --
3 9 
1 
A. There is normally a passenger manifest. 
yes. 
3 
O. Who creates the manifest? 
4 
A. Probably dispatch. 
5 
O. Dispatch? 
6 
A. At Limited. 
7 
O. Do you know who that is? 
8 
MR. REINHART: Can you give a time frame? 
9 
Do you mean currently or back when he worked 
10 
mere? 
It 
MR. EDWARDS: I'm talking about back when 
12 
he worked there. 
13 
BY MR. EDWARDS: 
14 
O. Do you know who that was at dispatch? 
is 
A. That would have been Diane Williams. 
16 
0. Who does Diane Williams work for? 
17 
A. Limited Flight Department. 
18 
O. Who does she report to? 
19 
A. Tim Staley. 
20 
0. Who's Tim Staley? 
21 
A. Director of Operations. 
22 
O. For who? 
23 
A. Limited Flight Department. 
24 
O. What does he then do with that Information? 
25 
A. I don't know. I don't know. 
2 
38 
1 
A. 
— no. not that I'm aware of. 
2 
O. Who is assigned the duty of reporting the 
3 
names of the people who are going to be transported on 
4 
the airplanes? 
5 
MR. GOLDBERGER: Form. 
6 
A. Captain. 
7 
O. So have you ever been privy to conversations 
8 
where the captain is told by Mr. Wexner to record all of 
9 
the names of the people that are going to be on the 
10 
airplane' 
11 
A. Can't say.
12 
O. Sometimes? 
13 
A. I can't 
You know, I can't say. I can't 
14 
remember what our policies were at the time. 
15 
O. I'm not asking policies. I'm asking: Have 
16 
you ever been around when the plot was being instructed 
17 
by Mr. Wexner • back in the late '80s, early '90s - to 
18 
make sure that you record who's on this aircraft? 
19 
A. I never heard Mr. Wexner address that, no. 
20 
O. I moan. God forbid the airplane crashes, you 
21 
would tike to know who's the on the airplane, right? 
22 
MR. GOLDBERGER: Form. 
23 
A: 
Yes. 
24 
O. Is there any way to determine who's on each 
25 
particular night in case anything happens? 
40 
O. 
Have you ever talked to Tim Staley? 
2 
A. 
From 
Yes, yes. 
3 
O. 
And what do you talk to him about? 
4 
A. 
Oh, we're - we're friends. We worked 
5 
together for years. I mean, I haven't talked to him 
6 
since the holidays. 
7 
O. Do you know where he is now? 
a 
A. 
To the best of my knowledge, stilt 
9 
Director of Operations at Limited. 
10 
0. Do you have a number for him? 
11 
A. Yes. 
12 
0. Can I have the number, please? 
13 
A. It's 
14 
0. Is that a work number? 
15 
A. That's the Flight Department. 
16 
O. That's the best number to reach him at? 
1? 
A. 
Yes. 
18 
0. If I'm going to call him, that's the number I 
19 
call? 
20 
A. Correct. 
21 
0. And was he always in charge of flight 
22 
directions? 
23 
A. No. he was previously Chief Pilot. 
24 
G. He was previously Chief Pilot for Limited? 
25 
A. 
Same, yes. 
0 
ESQUIRE 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
wvatesquIresolutions.com 
• 
• 
• 
3501.150-002 
Page 12 of 92 
EFEk_00068804 
EFTA01247032

Larry Eugene Morrison - Volume I 
October 6, 2009 
• 
• 
41 
1 
0. And he was promoted, I suppose, to Flight 
2 
Director? 
3 
A. Director of Operations. It's the 
4 
department crew. Most small departments don't have 
S 
&rectors until they start to grow. 
6 
Cr. 
And when he was Chief Pilot were you 
7 
affiliated with the Wexner organization? 
8 
A. Yes, I was a maintenance technician. 
9 
O. And when you say somebody keeps flight logs. 
10 
Is it always Tim -- is his name Tim Staley? 
11 
A. 
Yes. 
12 
O. 
— Is It always Tm Staley who does that? 
13 
0. No. I don't knOw where they go. honestly. 
14 
and the system may have changed. 
15 
O. Okay. Are you --
26 
A. I've been gone since --
17 
O. Are you aware of any FAA policies to where 
18 
they need to know who's on the aircraft whenever It talks 
19 
off? 
20 
A. Not under Part 91 Operations, there is 
21 
not. 
22 
O. Part what? 
23 
A. Pan 91. 
24 
O. What does Part 91 say, as far as you know? 
25 
A. It's basically souls on board when you 
43 
1 
international. The only time we do international 
2 
would be for Customs and Immigration. 
3 
O. So if its an international flight --
4 
A. 
For Customs and Immigration • for coming 
5 
and leaving the country. 
6 
O. 
then they require that names of 
7 
individuals —
8 
A. It would be names, passports, that kind of 
9 
stuff • normal. 
10 
O. Did you ever do any international flights 
t.1 
while employed by The Limited, Victoria's Secret, the 
12 
whole Wexner group? 
13 
A. 
Yes. 
14 
O. How many? 
15 
A. No way of knowing. I mean. rm • can't 
16 
say. It's, like I say, years. but 
17 
O. What years would you done its? 
18 
A. Started flying as a flight mechanic in 
19 
'89, and then started flying the Boeing in '99, so • 
20 
to '01, so '89 to '01, basically. 
21 
(Mr. Goldberger exited.) 
22 
BY MR. EDWARDS: 
23 
O. 
SO '89 to '01, if I wanted all of the flight 
24 
logs, who would I request those from - Tim Staley? 
25 
A. Don't know. I don't know who --
1 
2 
3 
4 
5 
6 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
42 
file a flight plan - that's the only thing you're 
required to do. When you file your flight plan you 
file souls on board. 
O. What does that mean, 'souls on board'? 
A. 
In other words, living bodies on board. 
In other words, if you have • so if there's an 
accident and you have four and you're transporting a 
cadaver, that they go to the accident scene and don't 
find five bodies - think there were live fatalities. 
0. So it's your understanding from what you need 
to report are, 'I have five people on board.' 
A. Correct, and that's for the flight plan. 
O. So there's no reason to say that, 'I have Joe 
Schmo on board? 
A. Not under Part 91, no. 
0. That's doing something over and above. 
A. 
That's correct. 
O. 
You are aware, though, that there are certain 
flight plans where they actually name individuals that 
are on the airplane? 
MR. GOLDBERGER: Form. 
A. No. 
0. I mean, you've seen that belore. 
MR. GOLDBERGER: Form. 
A, No, nOl on NO plans, no - unless it's 
44 
1 
O. What does Tim Staley do alter 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 
O. Certainly theyre kept on file somewhere, 
7 
right? 
6 
A. I would assume. 
9 
O. What's the name of the company that owns the 
10 
airplanes? I know its affiliated with Wexner and all 
11 
that, but what's the name of the company? 
12 
A. Well, there were several companies. I 
13 
mean, the way corporate aviation fkght departments 
14 
are set up. [helm under holdings companies. 
15 
O. I'll go with al of them. 
16 
A. Well. I don't know. They change. They 
17 
change sometimes by the year, sometimes -- I have no 
18 
Idea what they're under now. 
19 
O. What were they under backln'88 
A. It was like --
21 
O. 
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 
kke Northeast Holding, Southwest Holding, LLC • 
25 
Wilmington, Delaware, companies, which is standard 
• 
ESQUIRE 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquiresolutlons.com 
3501.150-002 
Page 13 of 92 
EFT,C00068805 
EFTA01247033

Larry Eugene Morrison - Volume I 
October 6, 2009 
45 
1 
for these, you know. 
2 
O. Did Leslie Wexner ever tell you that he 
3 
allowed Jeffrey Epstein to serve in some sort of 
4 
capacity, representative capacity, for any of these 
5 
companies? 
6 
A. No. He would never say that to me 
anyways. no. 
0. 
What's the first time you ever saw Jeffrey 
9 
Epstein? 
to 
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 
0. What year do you think that was? 
16 
A. It would have had to have been 
17 
0. Talking late '80s. early '90s? 
18 
A. Late '90s. 
19 
O. Late '90s? 
20 
A. 
Yeah, probably - mid to late '90s. 
21 
0. Well, I mean, it you're taken over with 
22 
Jeffrey Epstein In, what, 2001 -
23 
A. Correct. 
24 
0. 
- then you're talking late '90s is the first 
25 
time you see him? 
47 
A. 
They were -- They were generated, but I 
2 
don't know, you know, why - what the particular 
1 
reasoning was fork. 
4 
0. Do you know it Terry (gc) Staley would have 
5 
been the one to forward those flight logs to the FAA? 
6 
A. No, no, no. I -• They wore all lust tor 
7 
business use • not forwarded to the FAA. 
8 
0. Okay. How --
9 
A. The FAA doesn't care about flight logs. 
10 
0. How OW the FAA monitor when trial piano took 
11 
off? 
12 
A. 
Flight plans. 
11 
0. And wash your understanding that when the 
14 
plane took off, the FAA was unaware as to who was ever on 
is 
it? 
16 
A. 
Pretty much, yeah. They don't care about 
17 
names. When you file flight plate watt the flight 
18 
service station or via electronically, all they care 
19 
about is souls on board, contact information. flight 
20 
routing, things like that. 
21 
0. Are there time limits as to when the plane is 
22 
allowed to take off? 
23 
A. 
Yeah. usually -- From what point? What do 
24 
you mean? Time of the day or - 
25 
0. Yeah. yeah. time of the day. I understand 
46 
1 
A. 
Well, and 
I don't know exactly. I 
2 
can't really say, really. 
3 
0. t won't hold you to N. his what 4 is. 
4 
Mid to late '90s, it I wanted the flight logs 
that have him on it, On the airplane, who would I 
6 
Subpoena to get those records? 
7 
A. 
I have no Idea. 
0. Are they turned into the FAA, to the best of 
9 
your knowledge? 
10 
A. No, the FM doesn't require them. 
11 
0. So FM does not get the flight -- Well. what's 
12 
the point of even keeping these? 
13 
A. 
Sometimes I think the IRS 
I mean, this 
14 
is on assumption, rm not even sure, but mostly for 
15 
like IRS tracking ford you have people that have 
16 
dual homes, dual statehoods. or whatever. 
17 
(Mr. Goldberger entered.) 
le 
MR. GOLDBERGER: Can we take a time outs 
19 
(Shan break.) 
20 
(Mr. Pike appeared via telephone to 
21 
replace Mr. Goldberger.) 
22 
BY MR. EDWARDS: 
23 
0. FAA flight logs - do you know why they're 
24 
generated, how they're generated, 4 they were generated 
25 
back in the Wexner days? 
1 
2 
3 
4 
S 
6 
8 
9 
10 
11. 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21. 
22 
23 
24 
25 
48 
that there's some time where if it's too tate they can't 
take off, right? 
A. Only where there's a curfew on the airport 
- not all airports, no. No. airplanes can fly any 
time unless that airport has a noise curlew or 
something, yeah. 
0. Did you ever know of Wexner's plane to take 
off after ten o'clock p.m.? 
A. 
Yes. Yeah. 
0. Were you ever on that plane when it did? 
A. 
Probably. yeah, yeah. 
O. 
Were you ever on that plane when there were 
gds on the plane? 
A. 
Describe -- Define 'girls.' On the Wexner 
airplane? 
0. 
Yes. 
A. 
There would be ladies and his daughters. 
I mean --
0. Other than family members. 
A. 
There would be business associates. If 
you're taring young women, yes, business associates 
from the **visions. 
0. Have you ever been on the plane when there 
were girlfriends of Leslie Wexner? 
A. Only when Abigail • before his • became 
0 
ESQUIRE 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquiresolutions.com 
• 
• 
• 
3501.150-002 
Page 14 of 92 
EFTA_00068806 
EFTA01247034

Larry Eugene Morrison - Volume I 
October 6, 2009 
• 
• 
49 
1 
his bride. yes. 
2 
O. How about after --
3 
A. I moan 
4 
O. 
she became his --
5 
A. 
it was Abigail. She was the only 
6 
girlfriend. 
7 
O. How about after Abigail? 
e 
A. No. 
9 
O. Have you ever soon sox 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 Wexner's 
20 
airplane, it was used strictly for business? 
21 
A. Well, I don't know if it was used strictly 
22 
for business, but there was no. you know, it was -- I 
23 
don't know what the purpose of the actual trip was. 
24 
but never saw, you know, anything. you know. 
25 
O. Was there over a time when you were --
5 1 
1 
O. 
Yes, with you on it. 
2 
A. 
I can't — I canl say. 
3 
O. 
Well, where do you remember going in it? 
4 
A. Well, we would normally go to London, 
5 
Milan. Fans. I mean, mostly fashion areas and 
6 
business business areas. 
O. 
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. 
11 
O. 
What was the purpose? 
12 
A. I'm 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? 
15 
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 on 
20 
one of Mr. Wexner's planes that Jeffrey Epstein was also 
21 
on? 
22 
A. 
I can't say. I can't remember. 
23 
O. maybe/ 
24 
A. 
Possibly. 
25 
Cl. 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 wore finished. 
5 
A. 
Yeah. I don't tmderstand. I don't 
6 
understand that question. 
7 
O. I'm going to clarify. Wore there ever times 
8 
when you were on the plane and either Leslie Wexner 
9 
ancVor other individuals went behind these various areas 
10 
that you could not see into? 
11 
A. Yes. Yeah. 
12 
O. Do you know what they were doing in there? 
13 
A. Probably sleeping. He would go to bed at 
14 
night on the long trips, okay. 
15 
O. Arty 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 Mere 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 say exact. 
22 
O. How many international flights do you remember 
23 
that plane taking? 
24 
A. Remember .- The airplane itself taking 
25 
international? 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
52 
Jeffrey Epstein went while on that plane outside the 
United States? 
A. I can't remember. No, no. Like I say. I 
can't even remember it we took f for sure. 
O. My time that you remember Jeffrey Epstein 
being on the airplane, do you also remember Moro being 
girls on the airplane along with Mr. Epstein? 
A. 
I can't 
I can't say. I can't remember. 
O. When's the first time you remember seeing 
Jeffrey Epstein? 
A. Wel, like I say. I don't even remember 
the year. I can't oven pinpoint down to the year. 
It was after • some time after I started flying the 
727. because that's the only exposure. 
O. Okay. I'm not going to ask you at all during 
this deposition to guess. I thought at some point in 
time you told me you remember seeing Jeffrey Epstein. 
right? 
A. 
Yes. 
O. In fact, you work for him now. 
A. 
Yes. 
O. So at some point in time you saw him and you 
saw him for the first time. 
A. Correct. 
O. 
When's the first time you remember Wang horn? 
ESQUIRE 
•• Alezbuk•Gall•Camn 
CONFIDENTIAL 
Toll Free: 
Suite 1300 
51S East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquIresolutIons.com 
3501.150-002 
Page 15 of 92 
EFT/C00068807 
EFTA01247035

Larry Eugene Morrison - Volume I 
October 6, 2009 
53 
It may not be the first time you saw him. When's the 
2 
first time you remember seeing him? 
3 
A. '99, somewhere in that area. 
4 
0. 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 
8 
saw Jeffrey Epstein? 
9 
A. II was a flight. 
10 
O. 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 
0. Did you ever ask? 
15 
A. No. 
16 
0. Did you ever ask back in 1999 when you saw 
17 
this guy,1 wonder what he does•? 
18 
A. No. 
19 
0. Not even curious? 
20 
A. No. Its not my place. I don't -- I 
21 
don't need to know or want to know what people's 
22 
associations are. 
23 
0. Next lime you saw Jeffrey Epstein was when? 
24 
A. I can't say for sure. 
25 
0. Have you seen Jeffrey Epstein at Leslie 
55 
1 
Jeffrey Epstein helped to - I think, what you said was -
2 
manage Leslie Wexner's money? 
3 
A. Some of his accounts, yes. I guess. 
4 
0. Why do you think that? 
5 
A. From what I've read in periodicals and 
6 
magazines. 
7 
0. You've read in what periodicals and magazines? 
8 
A. I think it was, what, Vanity Fair there 
9 
was an article a couple years back, three or 
10 
lour years back, and a New York magazine as I 
11 
mentioned. 
12 
0. 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 
0. Right. because people tend to be curious --
17 
A. Right. 
18 
0. 
right? But when I lust asked you who 
19 
Jeffrey Epstein was and the relationship, you said, 1 
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 
0. Yes. 
25 
A. Well, yeah, when you're working for him 
54 
1 
Wexner's house? 
2 
A. No. 
3 
0. Never? 
4 
A. Never. I've never 
5 
0. Have you ever -
6 
A. •• been to Wexner's house. 
7 
0. You've never been there? 
A. No. 
9 
0. Have you ever known of Leslie Wexner or heard 
10 
of Leslie Wexner having minor girls or minor boys at his 
11 
house? 
12 
A. Oh, no. 
13 
0. 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 
0. Have you ever known of Jeffrey Epstein to take 
20 
underage girls to Leslie Wexner's house? 
21 
A. No. 
22 
0. Do you know how it is that Jeffrey Epstein and 
23 
Leslie Wexner met each other? 
24 
A. No. 
25 
0. You mentioned earlier that you believed that 
56 
1 
and he's in a magazine, you're going to road the 
2 
article. 
3 
0. Okay, so at some point in time, bird you Google 
4 
Jeffrey Epstein? 
5 
A. No, no. 
6 
0. Have you read the articles about Jeffrey 
7 
Epstein? 
a 
A. Lately? 
9 
0. Yes. 
10 
A. Oh, of course, yes, in the newspapers. 
11 
0. And you're aware of why your deposition's 
12 
being taken today. 
23 
A. 
Yes, of course. 
14 
0. And it has something to do not with a case 
15 
with Leslie Wexner, but a case involving Jeffrey Epstein 
16 
A. Coned. Yes. el course. 
17 
0. When you got this deposition subpoena, did you 
18 
by any chance try to look up some information on Jeffrey 
19 
Epstein - who this guy Is? 
20 
A. No, no. I mean 
21 
0. Is there anything --
22 
MR. REINHART: Hold on 
23 
finished? 
24 
0. Okay. Go ahead. 
25 
A. No. I moan, other than every once in a 
Were you 
0 
ESQVJE.E, 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquiresolutlons.com 
• 
• 
• 
3501.150-002 
Page 16 of 92 
EFTA_OD°688D8 
EFTA01247036

Larry Eugene Morrison - Volume I 
October 6, 2009 
• 
• 
57 
1 
whole 
get a Google alert just following the case 
2 
• just out of interest • because he's still my 
3 
employer, you know, and you don't want to be 
4 
blind-sided, but other than that, no --
5 
0. When you -
6 
A. 
I never looked onto his financial 
7 
background or anytting look that. I don't know if 
a 
you can. 
9 
0. When you say a *Googie alert; that's 
10 
something that you actually go out of your way and set up 
11 
on Google, right? 
12 
A. 
Yeah. 
13 
O. When did you do that? 
14 
A. A year ago or so. 
15 
0. Why did you do it? 
16 
A. Because Ern not around Mr. Wexner - or Mr. 
17 
Epstein anymore. I duet 
18 
0. Well, he was in jail --
19 
MR. REINHART: Hold on. Were you Finished 
20 
with your answer? 
21 
A. I haven't been a kill time employee with 
22 
Mr. Wexner since --
23 
MR. REINHART: Epstein. 
24 
BY MR. EDWARDS: 
25 
0. Epstein or Wexner? 
1 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
59 
0. When you say last pace; how often are you 
flying? 
A. Every week • sometimes two, three times a 
week. 
0. And Mat's by the time that you're working for 
Jeffrey Epstein? 
A. Yes, yes. 
0. Because back in the Leslie Wexner days you 
weren't flying every day. 
A. No, no, no, because there was another 
engineer, no. 
0. Right. 
A. I had about one-third of the flights. 
0. So from 1988, when you start working with 
Leslie Wexner. through S9 or so, you're not flying all 
the time, right? 
A. 
No. Oh, no, no. Actually. In 88, I was. 
you know, I was • my primary duties were in the 
hangar - maintenance. 
O. Did you enjoy doing that? 
A. The maintenance part of it? 
0. Yes. 
A. Oh, yeah, that's my background. that's my 
forte. 
O. Is that something that you've gone back to? 
1 
2 
3 
4 
6 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
58 
A. I'm soriy 
Mr. Epstein. since February 
of 2007. 
0. Well, a lot of that has to do with him being 
incarcerated --
A. No, no. 
0. -- for a year, right? 
MR. PIKE: Form. 
A. 
No, it was because I wanted to make a job 
-a career change. 
0. Why? 
A. Because I got tired of flying, being on 
the road. wanted to be home. 
0. Did it bother you that your boss, back in 
2007, was under investigation? 
A. Of course. 
0. Is that part of the mason why maybe you 
wanted to make a career change? 
A. 
No, no. The reason was the amount of 
flying that I had been doing and the overnights. and 
when something's no longer fun, it's time to find 
something else to do. 
0. Why wasn't it fun anymore? 
A. It's a very fast pace. I wanted to spend 
time at home. I wanted to get back into strictly 
maintenance. 
1 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
• 
O. Did Leslie Wexner and/or Mr. Epstein help you 
to get that job? 
A. No, no lies whatsoever. 
0. So who introduces you to Jeffrey Epstein? 
Probably it would have been Larry. The 
first actual formal introduction? 
0. Right. 
A. Probably would have been Larry Visoski. I 
knew Larry and Dave when they flew for Glimcher 
Corporation. 
0. Tell me a little bit about that. Larry 
Visoski • how do you know him? 
A. He's the Chief Pilot for Jeffrey and hired 
me. 
0. Well, he's the Chief Pilot now --
• 
0 
ESQUABT 
CONFIDENTIAL 
Toll Free: 
Faalmile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
wvnv.esquIresolutions.com 
3501.150-002 
Page 17 of 92 
EFrA_00068809 
EFTA01247037

Larry Eugene Morrison - Volume I 
October 6, 2009 
61 
1 
K Right. 
2 
O. -- for Jeffrey Epstein. 
3 
A. Right. 
4 
O. When is the first time you met Larry Visoski? 
A- It was before he worked for Jeffrey. He 
6 
and Dave were flying for a gentleman - Glimcher 
7 
Corporation. 
8 
O. Flying for who? 
9 
A. Glimcher Corporation. 
so 
O. How do you spell that? 
11 
A. G-L-I-M-C-H-E-R, I think. They were --
12 
They had an airplane based to Lane Aviation in 
13 
Columbus with us. 
14 
O. And David Rodgers? 
15 
A. Yes. 
16 
O. How did you know David Rodgers? 
17 
A. Same, from 
They were in the same hangar 
10 
we were in. 
19 
O. Are you from here? 
20 
A. No. 
21 
O. Where are you from? 
22 
A. Columbus. Ohio. 
23 
O. So you're from Columbus. Ohio. and that's also 
24 
a place where Leslie Wexner Ines. 
25 
A. Yes. 
63 
1 
O. How did you loam of Leslie Wexner? 
2 
A. Oh, I mean, he's very well-known in 
3 
Columbus, because, you know• billionaires in central 
4 
Ohio, aren't, you know 
O. Aren't a dime a 0020n, tight? 
6 
A. Exactly. and small guy that made it big, 
7 
you know, because that's where the name Limited • so 
a 
hearsay is - the name Limited came from he started 
9 
with limited resources. 
10 
O. So did you know him before he was married to 
11 
Abigail? 
12 
A. 
Yes. 
13 
O. And did you know him to date exclusively women 
14 
peer to that? 
15 
A. The only -- I knew that he was dating 
IC 
Sharon. 
17 
O. Right. 
18 
A. I never flew Sharon. but he dated Sharon 
19 
for a long time, and then there was. you know, they 
20 
broke up and then he started dating Abigail. 
21 
O. And have you heard any rumors about him dating 
22 
men as well? 
23 
A. No, no. 
24 
O. First time that you're healing about it is me 
2s 
telling you that, right? 
62 
1 
O. So that was at least convenient for you? 
2 
A. Oh, eah. No, it was 
Yeah. 
3 
6 
7 
9 
10 
11 
12 
3.3 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
O. As your first job that you had, was that with 
Leslie Wexner? 
A. Oh, no. I started working for Ohio State 
University 
O. 
And then where? 
A. -- in their flight department. 
Went from Ohio State University to get a 
shoe stint, a contract maintenance for a - a 
contract for NASA at Langley researcher, and then 
that was under the direction • that was contracted 
under OSU's umbrella for airport research. They had 
an Aviation Research Department. Then after that 
went to Red Roof Inns • maintenance technician for 
Red Roof Inns. 
O. What was It - Gregory Finns? 
A. No, Red Roof Inns. 
O. Red Roof Inns. 
A. True Sports Racing. It was Budweiser 
racing • Indy car team and Red Roof Inns. the motel 
Main. Then from there I went to The Limited stores. 
1 
2 
1 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
64 
A. Yeah. 
O. So back to Lany Visosld • you don't know him 
while you're employed with Leslie Wexner. 
A. 
Yes. 
O. Youth? 
A. Yeah. 
O. How do you meet him? 
A. Met him because their aircraft was in our 
hangar. The Glimcher aircraft was based in our 
hangar and got to know him that way. 
O. Glimcher is a company owned by whom? 
A. I donl know if it's public or not. It 
was a mall development company not associated with 
Limited. 
O. So what's the conversation between you and 
Larry Visoski? Obviously you all end up working for 
Epstein, so try to lead me through that. 
A. Well, I think -- I mean, we got to know --
I mean, you're neighbors in a hangar environment, so 
you have discussions. 
Larry was the mechanic. He was also 
pilot/mechanic on the Hawker for Glimcher, and you 
kind of form a relationship and a rapport, and then. 
I believe, Glimcher sold their airplane. I don't 
know how Dave and Larry ended up with Jeffrey, I 
0 
ESQUIRE 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
vnirw.esgulresolutions.com 
• 
• 
• 
3501.150-002 
Page 18 of 92 
EFTA_00068810 
EFTA01247038

Larry Eugene Morrison - Volume I 
October 6, 2009 
• 
• 
65 
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. Did Jeff rey --
7 
A. -- did you meet them?' 
8 
O. 
have a plane in the same hangar? 
9 
MR. REINHART: Hold on. Let him finish 
10 
his answer. 
11 
MR. EDWARDS: I'm sorry. I thought you 
12 
were finished. 
13 
MR. PIKE: This is Michael Pike. Let him 
14 
finish his question because, keep in mind • you 
15 
finish your question, let him finish his answer 
16 
- keep in mind. I'm on the phone, so I'm having 
17 
a hard time hearing his response in the 
18 
background. 
19 
MR. EDWARDS: You're actually on the other 
20 
end 04 the table. Do you want us to fry to move 
21 
the phone closer? 
22 
MR. PIKE: Yes, that would be good. 
23 
MR. EDWARDS: I'll do that for you, man. 
24 
I'm sorry, I really did forget that you were 
25 
here. 
1 
2 
3 
I 
12 
13 
10 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
6.7 
help them with the airplane, get, you know, become a 
(light engineer Director of Maintenance - on it 
O. But the hangar we're talking about is in Ohio. 
A. 
Yeah, Lane Aviation. 
O. 
You would see them brisirially on a dayto-day 
basis because the aircraft that you were a technician 
for --
A. 
Right. 
O. 
was very close in proximity to the aircraft 
that they were piloting. 
A. 
Yes. 
O. 
They approach you at some point in time and 
say what specifically? 
A. I can't remember the specific 
conversations, but it was like, you know, asked me if 
I would be interested in, if Jeffrey bought the 727 
66 
• 
MR. PIKE: Not a problem. I've objected 
2 
to form a couple el tines. I'm not Quito sure 
3 
If that was even hoard, but that's neither here 
4 
nor there. 
5 
MR. EDWARDS: We'll say the last ten 
6 
questions you objected to form. I got you. 
7 
What was my last question, Pike? You 
• 
don't oven remember. 
9 
MR. REINHART: You asked Mn conversations 
10 
he had with Larry Visoski and Dave Rodgers about 
11 
how they come came to work for Epstein. 
12 
MR. EDWARD$: Good. 
13 
A. I really never queried them on now they 
14 
come to work for Jeffrey. I think Dave was hired 
15 
first and he brought - this is all speculation - and, 
16 
I think, he brought Larry on board. 
17 
O. So as far as you know, however you know. David 
18 
Rodgers was the first Epstein contact and then Larry 
19 
Visoski rode a In. 
20 
A. The way I understand, yeah. 
21 
O. How did you become involved in the 
22 
three•person train to Epstein? 
23 
A. When it became apparent that Jeffrey, or 
24 
Mr. Epstein. was going to buy the 727, Larry 
25 
approached me. that if I would want to, you know, 
68 
1 
being. you know, the fight engineer and help them, 
2 
you know, get the flight department Ong. and I told 
3 
them I would. 
4 
O. And why rid you say *yes' considering that you 
5 
had a bees in Leslie Wexner who was seemingly pretty good 
6 
to you for the last ten years? 
A. Oh. he's excellent 
a 
O. Yes. 
9 
A. No, fine might department and Mr. Wexner 
to 
as fine person. 
11 
O. Right. 
12 
A. The reason being is, you know. I already 
11 
stated this I think twice before, was that I wanted 
14 
to be able to continue to fly arid that would give me 
15 
the opportunity to continue to ay as a flight 
16 
engineer and the challenge of starting this airplane. 
17 
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 only a two-man airplane --
21 
O. So then he would have --
22 
A. - and the modem aircraft could only have 
23 
hvO plus, right. 
24 
O. Got you. I underworld. 
25 
So they approach you with tris prospect of the 
• 
CO 
ESQUIRE 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquiresolutions.com 
3501.150-002 
Page 19 of 92 
EFIA_00068811 
EFTA01247039

Larry Eugene Morrison - Volume I 
October 6, 2009 
69 
1 
two of them - Dave Rodgers and Larry Visoski - becoming 
2 
the pilots for the 727 --
3 
A. Correct. 
4 
0. -- that Epstein's buying and, 'Hey, would you 
5 
like to be apart ol it?' 
6 
A. Right. 
7 
0. I mean, Mars the gist of it. 
A. Correct, that would be the gist ol 
9 
0. And your response was? 
10 
A. 
Yes, I would • you know, if it came to be, 
11 
I would consider it. ObviOuSly, you knOw, salary had 
12 
to come in and everything else, but I said, 'Yeah. I 
13 
would be interested in it.' 
14 
O. What's to next conversation that you had and 
15 
with whom? 
16 
A. 
I don't know. There were several 
17 
conversations, but they were all with Dave and Larry 
18 
both, you know, calling back and forth, but. 
19 
0. About what? Was it about salary, about the 
20 
position? 
21 
A. Salary, what the benefits wore, you know. 
22 
stuff like that. No. the position was pretty much 
33 
defined. I mean, it's the eight engineer, Director 
24 
ol Maintenance position. 
25 
O. And this brings us up in our timeline to 2001, 
71 
A. I don't know. I don't know. 
2 
0. I mean, how did she get on his private 
3 
airplane? I would imagine strangers don't just walk on, 
4 
light? 
s 
A. Yeah, but I don't know. I don't know what 
6 
people's associations are together when, you know. 
• 
0. Okay. 
a 
A. 
I don't know if it's business association. 
9 
social associations. or what. 
10 
O. How many times
II 
MR. PIKE: Let me object to the form of 
12 
that question. 
13 
MR. EDWARDS: Okay. Noted. 
14 
BY MR. EDWARDS: 
15 
0. How many times was she on that airplane when 
16 
it was owned by Leslie Wexner? 
17 
A. Not many, but I can't give you an exact. 
18 
0. Was she ever naked on the airplane? 
19 
A. Not that I'm aware of. 
20 
0. I mean. that's something that you would 
21 
probably remember, right? 
22 
A. Well --
23 
MR. PIKE: Form. 
24 
A. 
Yeah. I mean --
25 
0. I'm 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 
0. Prbor to 2001, had you heard the name 
• 
Ghislaine Maxwell? 
6 
A. 
Yes. 
7 
0. How would you have heard Chislaine Maxwell? 
▪ 
A. 
She had been a passenger on the 727 once 
9 
or lvace. 
10 
0. The 727, I mean? 
11 
A. 
When It was under Limited. 
12 
0. 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. Gut on the record it could be 
15 
because the 727 was Wexner's, then it was Epstein, so 
16 
you're talking about --
17 
A. 
When it was under Mr. Wexner's control. 
18 
0. What year do you think that was? 
19 
A. 
It would have been in the late '90s. 
20 
Again, like I say, when - probably some time around 
21 
the time - you know, had to be late ^90s --
22 
0. Did she 
23 
A. 
- maybe 2000. 
24 
0. Did she seem like a friend of Leslie Wexner's 
25 
to you? 
72 
1 
assume I would remember e. 
2 
A. Not that rm aware et 
3 
0. Do you remember her bringing other gins on 
4 
the airplane with her? 
• 
A. No. 
6 
0. You remember her getting on Me airplane 
? 
alone? 
B 
A. I can't say for sure. 
9 
0. Alright. Maybe this will log your •• 
10 
A. I mean. she was never µst atone-alone. 
11 
Like the only passenger or. 
12 
0. Yes. 
13 
A. No. no. always with when other people 
14 
were on board. 
Is 
0. And you lust can't remember whether she 
16 
bought on board with her a male or a female: is what 
17 
you're saying. right? 
18 
A. No. I mean -- Restate the question. How 
19 
cid you 
20 
0. Sony. 
21 
A. 
Define 'alone.•
22 
0. I don't mean, you know. n there's 15 
21 
passengers and she gets on. I'm saying: Do you remember 
24 
her getting on and being accompanied by • either they 
25 
took the same car to the airport, they walked the runway 
ESQUIRE 
CONFIDENTIAL 
Toll Free: 
Facsimile: 
Suite 1300 
515 East Las Olas Boulevard 
Fort Lauderdale, FL 33301 
www.esquIresdutions.corn 
• 
• 
• 
3501.150-002 
Page 20 of 92 
EFTA_00068812 
EFTA01247040