Case 9:09-cv-80802-KAM

Document 16

Entered on FLSD Docket 11/09/2009

Page 1 of 26

# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

# CASE NO.: 08-CIV-80119-MARRA/JOHNSON

5

JANE DOE NO. 2,

Plaintiff,
VS.

JEFFREY EPSTEIN,

Defendant.

Related cases:
08-80232, 08-08380, 08-80381, 08-80994,
08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092

## THIRD PARTY WITNESS, IGOR ZINOVIEW'S,
MOTION FOR PROTECTIVE ORDER AND
INCORPORATED MEMORANDUM OF LA,v

Third Paiiy Witness, Igor Zinoview's, ("Mr. Zinoview") by and through his undersigned attorney, moves this Court pursuant to Fed. R. Civ. P. 26(c) for a protective order regarding his deposition and as grounds therefore would state:

1. As reflected on the affidavit of Igor Zinoview, attached as Exhibit A, he works for Defendant, Jeffrey Epstein ("Mr. Epstein") as a driver and bodyguard. He did not know Mr. Epstein before November of 2005. He first became employed by Mr. Epstein in November of 2005.

2. Additionally, Mr. Zinoview would testify as set forth on his affidavit, that at no time has he discussed with Mr. Epstein any issues involving Mr. Epstein's criminal case nor any of the cases or issues involved with civil plaintiffs.

1

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3. In many of the depositions, counsel for L.M. and E.W., has asked them as witnesses to assume ce1iain facts about which they have no knowledge, and he then asks their opinions about certain facts. See Exhibit B ~Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions.

4. There is no information which Mr. Zinoview has relating to the facts and circumstances surrounding any of the pending civil cases, in that none of their allegations directed to Mr. Epstein extend beyond September of 2005. Therefore whatever information Mr. Zinoview may have, postdates that time.

5. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). . .. Cou1is have long held that ' [ w]hile the standard of relevancy [in discovery] is a liberal one, it is not so liberal as to allow a party to roam in the shadow zones of relevancy and to explore matter (sic) which does not presently appear ge1111ane on the theory that it might conceivably become so.' Food Lion, Inc. v. United Food & Commercial Workers Intern. Union, 103 F.3d 1007, 1012-13 (C.A. D.C. 1997) (string cite omitted)."

6. Rule 26(c), Federal Rules of Civil Procedure, provides that, "[a] party or any person from whomn discovery is sought may move for a protective order in the court where the action is pending.... The court may, for good cause, issue an order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including one or more of the following: (A) forbidding the disclosure or discovery;".

2

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Page 3 of 26

7. As set forth in his affidavit, Mr. Zinoview cannot possibly have any knowledge or information that is presently germane to this action. Accordingly, the Court should enter a protective order prohibiting his deposition.

WHEREFORE, third~paity witness moves this comt for a protective order pursuant to Rule 26(c), Federal Rules of Civil Procedure, that his deposition not take place or the questioning be limited.

By: ________
JACK ALAN GOLDBERGER ESQ.
Florida Bar No. 262013
jagesg@bellsouth.net

## Rule 7.1 Certification

I hereby certify that counsel for the movant has conferred or attempted to confer with opposing counsel in a good faith effort to resolve the discovery issues prior to the filing of this motion for protective order but has been unable to do so.

## Certificate of Service

I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also ce1tify that the foregoing document is being served this day on aII counsel of record identified on the following Service List in the manner specified by CM/ECF on this_ day of November, 2009

Respectfully submitted,

By:
JACK ALAN GOLDBERGER ESQ.
Florida Bar No. 262013
jagesq@bellsouth.net
Atterbury Goldberger & Weiss, P.A,
250 Australian Avenue South
Suite 1400
West Palm Beach, FL 33401-5012
561-659-8300
Fax: 561-835-8691
(Counsel for Defendant Jeffrey Epstein)

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# Certificate of Service

# Jane Doe No. 2 v. Jeffrey Epstein

## Case No. 08-CV-80119-MARRA/JOHNSON

<table><tr><th>Stuart  S.  Mermelstein,  Esq. </th><th>Brad  Edwards,  Esq. </th></tr><tr><td>Adam  D.  Horowitz,  Esq. </td><td>Rothstein Rosenfeldt Adler </td></tr><tr><td>Mermelstein &amp; Horowitz,  P.A. </td><td>401  East  Las  Olas  Boulevard </td></tr><tr><td>18205  Biscayne Boulevard</td><td>Suite  1650 </td></tr><tr><td>Suite  2218 </td><td>Fort Lauderdale, FL  33301 </td></tr><tr><td>Miami,  FL  33160 </td><td>Phone:  954-522-3456 </td></tr><tr><td>305-931-2200 </td><td>Fax:  954-527-8663 </td></tr><tr><td>Fax:  305-931-0877 </td><td>bedwards@,rra-law.com </td></tr><tr><td>ssm@sexabuseattorney.com </td><td>Counsel for Plaintiff in  Related Case Wo. </td></tr><tr><td>ahorO\vitz@sexabuseattorney.com </td><td>08-80893 </td></tr><tr><td>Counsel for Plaintiffs</td><td></td></tr><tr><td>In  related Cases Nos.  08-80069, 08-80 II  9, </td><td>Paul G. Cassell, Esq.</td></tr><tr><td>08-80232, 08-80380, 08-80381, 08-80993,</td><td>Pro Hac Vice</td></tr><tr><td>08-80994</td><td>332  South  1400  E,  Room  101 
Salt Lake City, UT 84112</td></tr><tr><td>Richard Horace Willits, Esq.</td><td>801-585-5202</td></tr><tr><td>Richard H. Willits, P.A.</td><td>801-585-6833  Fax </td></tr><tr><td>2290 10th Avenue North</td><td>cassellp@law.utah.edu</td></tr><tr><td>Suite 404</td><td>Co-counsel  forPlaintiff Jane Doe</td></tr><tr><td>Lake  Worth,  FL  3  3461 </td><td></td></tr><tr><td>561-582-7600</td><td>Isidro M. Garcia, Esq.</td></tr><tr><td>Fax:  561-588-8819 </td><td>Garcia Law Firm, P.A.</td></tr><tr><td>Counsel for Plaintiff in  Related Case No. </td><td>224  Datum  Street,  Suite  900 </td></tr><tr><td>08-80811</td><td>West  Palm  Beach,  FL  33401 </td></tr><tr><td>reelrhw@hotmail.com</td><td>561-832-7732
561-832-7137 F</td></tr><tr><td>Jack Scarola, Esq.</td><td>isidrogarcia@bellsouth.net</td></tr><tr><td>Jack P. Hill, Esq.</td><td>Counsel for Plaintiff in  Related Case No. </td></tr><tr><td>Searcy  Denney  Scarola Barnhart &amp; Shipley,</td><td>08-80469 </td></tr><tr><td>P.A.</td><td></td></tr><tr><td>2139  Palm  Beach  Lakes  Boulevard </td><td>Robert C. Josefsberg, Esq.</td></tr><tr><td>West  Palm  Beach,  FL  33409 </td><td>Katherine W. Ezell, Esq.</td></tr><tr><td>561-686-6300</td><td>Podhurst Orseck, P.A.</td></tr><tr><td>Fax:  561-383-9424 </td><td>25  WestFlagler Street)  Suite  800 </td></tr><tr><td>jsx@searcylaw.com</td><td>Miami, FL 33130</td></tr><tr><td>iph@searcylaw.com</td><td>305 358-2800</td></tr><tr><td>Counsel for Plaintiff, C.M.A.</td><td>Fax: 305 358-2382
riosefsberg@podhurst.com</td></tr><tr><td>Bruce Reinhart, Esq.</td><td>kezell@podhurst.com</td></tr><tr><td>Bruce E. Reinhart, P.A.</td><td>Counsel for Plaintiffs in Related Cases</td></tr><tr><td>250 S. Australian Avenue</td><td>Nos. 09-80591 and 09-80656</td></tr><tr><td>Suite 1400</td><td></td></tr><tr><td>West Palm Beach, FL 33401</td><td>Jack Alan Goldberger, Esq.</td></tr></table>

4

Case 9:09-cv-80802-KAM

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Entered on FLSD Docket 11/09/2009

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561-202-6360
Fax: 561-828-0983
ecf@brucereinhartlaw.com
Counsel for Defendant Sarah Kellen

Theodore J. Leopold, Esq.
Spencer T, Kuvin, Esq,
Leopold, Kuvin, P.A.
2925 PGA Blvd,, Suite 200
Palm Beach Gardens, FL 33410
561-684-6500 
Fax: 561-515-2610
sk\,lvin@leopoldkuvin.com 
Counsel for Plaint(.[( in Related Case No.
08-08804

Atterbury Goldberger & Weiss, P.A.
250 Australian A venue South
Suite 1400
West Palm Beach, FL 33401-5012
561-659-8300 
Fax: 561-835-8691
iagesq@bellsouth.net 
Counsel for Defendant Jeffrey Epstein

5

Case 9:09-cv-80802-KAM

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# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

# CASE  NO.:  08-CV-80119-MARRA-JOHNSON

JANE DOE NO. 2,

V.

Plaintiff,

JEFFREY EPSTEIN,
Defendant.

Related Cases:
08-80232, 08-80380, 08-80381, 08-80994,
08-80993, 08-80811, 08-80893, 09-80469,
09-80581, 09-80656, 09-80802, 09-81092.

## AFFIDAVIT OF IGOR ZINOVIEV

STATE OF FLORIDA ) SS COUNTY OF PALM BEACH )

BEFORE ME, the undersigned authority, personally appeared Igor Z_inoviev having personal lmowledge and being duly sworn, deposes and says:

	1. My name is Igor Zinoview.

	2. I began working for Mr. Epstein in November of 2005.

	3. I did not know him until I began working for him.

4. I have never discussed nor has he ever attempted to discuss with me any facts or infonnation relating to any legal matters in which he is involved.

	5. I work for Mr. Epstein as his driver, bodyguard and trainer.

EXHIBIT A

Case 9:09-cv-80802-KAM

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Page 2

# FURTHER THE AFFIANT SAYETH NAUGHT.

Igor Zinoviev

## STATE OF FLORIDA
COUNTY OF PALM BEACH

I hereby Certify that on this day, before me, an officer duly authorized to administer oaths and take acknowledgments, personally appeared Igor Zinoviev known to me to be the person described in and who executed the foregoing Affidavit, who acknowledged before me that he/she executed the same, that I relied upon the following form of identification of the above named person: Ejor Zinoview , and that an oath was/was not taken.

WITNESS my hand and official seal in the County and State last aforesaid this day of Nov., 2009.

RYL NOTARY HONEY
STATE My Comm. Expires May 28, 2010 No. DD519867 PUBLIC OF ORIDA

<signature>
PRINT NAME: (SEAL)
NOTARY PUBLIC/STATE OF FLORIDA
COMMISSION NO.: <empty>
MY COMMISSION EXPIRES:

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 8 of 26

IN THE COURT OF THE FIFTEENTH

JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA

CASE NO. 502008CA028051XXXXMB AB

L.M.,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.

EPSTEIN'S MOTION FOR PROTECTIVE ORDER TO

# PROHIBIT INAPPROPRIATE DEPOSITION QUESTIONS

Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Rule 1.280(c), Florida Rules of Civil Procedure, moves for a protective order to prohibit argumentative, harassing and inappropriate questions in depositions, and states:

1. At numerous depositions, Plaintiff's counsel has repeatedly asked

argumentative and harassing questions that are irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.

2, In particular, Plaintiff's counsel has asked questions that improperly sought to illicit lay opinions from fact witnesses, asked questions regarding witnesses' feelings towards Mr. Epstein and their beliefs regarding media reports of this case, asked whether they would leave their children with Mr. Epstein and asked whether they would go back to work for Mr. Epstein assuming the media reports were accurate, among other things. These questions and the responses thereto will never be admissible. They are argumentative, irrelevant and seek speculative answers and inadmissible lay opinions.

EXHIBIT B

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 9 of 26

LM v. Epstein

Case No. 502008CA028051XXXXMBAB

Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions

Page 2 of 9 Page 2 of 9

3. For example, in the deposition of Larry Visoski, one of Mr. Epstein's pilots, Plaintiff's counsel asked the following questions seeking to obtain Mr. Visoski's beliefs and opinions on Plaintiff's allegations:

Q. All right. When you read in the newspapers the allegations that Mr. Epstein was involved with numerous underage girls for sexual reasons, were you surprised?

A. I didn't believe it.

Q. Do you believe it today?

A. I don't believe it.

Q. You don't believe that Jeffrey Epstein was involved with underage girls in a sexual way?

MR. CRITTON: Form.

THE WITNESS: You're asking for my opinion, and I don't think my opinion is relevant in that matter.

BY MR. EDWARDS:

Q. I think it's relevant. Can you just tell me whether today you believe that Jeffrey Epstein has engaged in sex with underage girls?

MR. CRITTON: Form; speculation, irrelevant, always.

THE WITNESS: It's irrelevant.

BY MR. EDWARDS:

Q. I need an answer.

A. I don't believe he had sex with underage women.

Q. Or engaged in any·sexual acts with underage women?

MR.  CRITTON: Form.

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 10 of 26

LM v. Epstein

Case No. 502008CA028051XXXXMBAB

Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions

Page 3 of 9

THE WITNESS: No.

BY MR. EDWARDS:

Q. You think that this ls just a story that a bunch of underage women have made up?

A. Speculation.

****

Q. Then we'll handle the question this way: If you were to believe based on information and evidence that Mr. Epstein engaged in sex or some form of sex acts with people of the age range of 12, 13, 14, 15 years old, would you continue your employment with Mr. Epstein?

MR.  CRITTON: Form; speculation.

THE WITNESS: I would certainly be speculating

and I have to discuss it with my wife long and hard. I don't think I could give you a correct and honest answer at this time.

See Excerpts of Deposition of Larry Visokski at 66-67; 181-82 (attached as

composite Exhibit A). Other examples of similar improper questions are included in ExhibitA.

4. Not only do these questions seek improper lay opinions, Plaintiff's counsel

asked Mr. Visoski his belief as to the truth of hearsay newspaper articles. The foregoing questions are obviously irrelevant, argumentative and not reasonably calculated to lead to the discovery of admissible evidence.

5. Moreover, whether Mr. Visoski would continue working for Mr. Epstein if

Plaintiff's allegations are true has absolutely no relevance to any claim or defense in this case. The questions are simply improper and meant to harass and embarrass the

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 11 of 26

LM v. Epstein Case No. 502008CA028051XXXXMBAB Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions Page 4 of 9

witness.

6. Mr. Visoski was questioned for over four hours and much of the time was wasted on irrelevant and harassing questions.

7. Plaintiff's counsel asked similar questions at the deposition of Larry

Eugene Morrison, another one of Mr. Epstein's pilots:

Q. Certainly you've read certain newspaper articles about

the allegations, police reports, otherwise, the allegations that occurred or have been alleged to have occurred at his Palm Beach mansion, correct?

A.  Uh-huh.

Q. Correct?

A. Correct.

Q. Given the nature of those allegations, would you leave

your daughter of 17, 16, 15 years old with Mr. Epstein alone?

MR. PIKE: Form. Move to strike.

A. Yes.

Q. And despite pleading guilty to procuring underage girls

for the purposes of sex, you still feel comfortable leaving a 13, 14, 15-year-old girl around him?

MR. PIKE: Form. Move to strike.

A. Yes. I mean, with my daughter, yes. I don't know how

he behaves around anybody else. I just know that the respect that he showed me, I feel safe with my daughter.

Q. And have you read in detail the reports as to what

happened at his  house with the girls?

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 12 of 26

LM v. Epstein

Case No. 502008CA028051XXXXMBAB

Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions

Page 5 of 9

A. Only -

MR.  PIKE:  Form.

A. -- what's been in the newspapers and published.

Q. If you read and hear testimony given - well, I can tell you now testimony has been given in this case that what w happens is: A 13 or 14 year old is led upstairs by herself, told to get naked, he lays down on his back, there is a brief massage before he turns over, exposes himself erect, masturbates while he tells this 13 or 14 year old to pinch his nipples as hard as she can while he inserts his fingers into their vagina and ejaculates all over them before saying, "Take your money and leave."

MR. PIKE: Form. Move to strike.

BY MR. EDWARDS:

Q. Okay? Then, 11 You can continue to come back for $200

every time or every girl you bring me within your age group and I get to do this again, I pay you $200 per person." If that is the testimony --

MR.  PIKE:  Form.

Q. -- that what happens behind closed doors with him, do

you still feel comfortable leaving a 13 or 14 year old in a room with Jeffrey Epstein?

MR.  PIKE: Form.

A. If that, in fact, is what actually happened, no.

*  * * *

Q. [Would you] go back - considering what you've read and

what you may or may not believe - would you go back to working for Jeffrey Epstein?

MR.  PIKE: Form.

A. I can't say. I still work for him on a maintenance - to

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 13 of 26

LM  v.  Epstein

Case No. 502008CA028051XXXXMBAB

Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions

Page 6 of 9

maintain the airplanes and stuff like that, so.

§ee Excerpts of Deposition of Larry Eugene Morrison at 135-36; 175-76; 184

(attached  as  composite  Exhibit  B).

8. Again, whether Mr. Morrison would work for Mr. Epstein "considering what [he has] read and what [he] may or may not believe" (i.e. considering hearsay media accounts and inadmissible lay opinion) has no bearing on the instant case.

9. In addition, questions regarding whether Mr. Morrison would leave his children alone with Mr. Epstein could have only been meant to harass and embarrass Mr. Morrison. Nevertheless, Mr. Morrison testified that he would leave his children with Mr. Epstein. As Plaintiff's counsel was obviously not happy with the answer to this question, he proceeded to press Mr. Morrison with inflammatory statements until he got the answer he wanted.

10. Plaintiff's counsel has also asked the same improper line of questions in

- other witnesses' depositions.

11. The above-cited questions exceed the bounds of permissible discovery;

- they have absolutely no relevance to this case. Accordingly, the Court should enter a protective order prohibiting such questions and should sanction Plaintiff's counsel if such inappropriate questions are asked at future depositions.

12. Regarding the scope of discovery, Judge Linnea Johnson noted in her

- October 28, 2009 Omnibus Order, 1 "[w]hile the scope of discovery is broad, lt is not

1 The Omnibus Order (DE #377) was entered in the federal companion case Jane Doe No. 2v. Epstein,

Case No. 08-CIV-80119 MARRNJOH NSON in the U.S. District Court, Southern District of Florida.

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 14 of 26

LM v. Epstein

Case No. 502008CA028051XXXXMBAB

Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions

Page 7 of 9

without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). ... Courts have long held that '[w]hile the standard of relevancy [in discovery] is a liberal one, it is not so liberal as to allow a party to roam in the shadow zones of relevancy and to explore matter (sic) which does not presently appear germane on the theory that it might conceivably become so.' Food Lion, Inc. v. United Food & Commercial Workers Intern. Union, 103 F.3d 1007, 1012-13 (C.A. D.C. 1997) (string cite omitted)." See also Capco Properties, LLC v. Monterry Gardens of Pinecrest Condo., 982 So. 2d 1211, (Fla. 3d DCA 2008) (holding that discovery in civil cases must be relevant to the subject matter of the case and must be admissible or reasonably calculated to lead to admissible evidence); Morton Plant Hospital Ass'n, Inc. v. Shahbas, 960 So. 2d 820, 824 (Fla. 2d DCA 2007) (holding that "discovery should be denied when it has been established that the information requested is neither relevant to any pending claim or defense nor will it lead to the discovery of admissible evidence," citing Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)).

13. As illustrated above, the questions are simply not germane to any pending '--..

claim or defense nor will they lead to the discovery of admissible evidence. Whether Mr. Visoski believes or disbelieves the media accounts of this case, or whether Mr. Morrison would leave his children with Mr. Epstein is not relevant and cannot conceivably lead to the discovery of admissible evidence.

14. The Court should curtail these inappropriate lines of questions and enter a

protective order prohibiting them.

15. Rule 1.280(c), Florida Rules of Civil Procedure, provides the Court with

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 15 of 26

LM v. Epstein

Case No. 502008CA028051XXXXMBAB

Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions

Page 8 of 9

the power to "make any order to protect a party or person from annoyance,

embarrassment, oppression or undue burden or expense that justice requires including ... (4) that certain matter not be inquired into, or that the scope of the discovery be limited to certain matters."

16. Accordingly, Epstein requests the Court enter a protective order prohibiting Plaintiff's counsel from asking witnesses' questions regarding opinions and beliefs regarding media articles and the allegations in this case and whether they would leave their children with Epstein or questions of a similar nature, and limiting the scope to the witnesses personal knowledge regarding matters relevant to the claims and defenses in this case. See Shahbas, 960 So. 2d at 824.

WHEREFORE, Defendant, JEFFREY EPSTEIN, respectfully requests the Court

enter a protective order prohibiting Plaintiffs counsel from asking witnesses' questions regarding opinions and beliefs regarding media articles and the allegations in this case and whether they would leave their children with Epstein or questions of a similar nature, and limiting the scope to the witnesses personal knowledge regarding matters relevant to the claims and defenses in this case and grant any additional relief the Court deems just and proper.

## Certificate of Service

I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S.

Mail to the following addressees on this 3rd day of November, 2009:

| Brad Edwards, Esq.          | Jack Alan Goldberger, Esq.         |
|-|-|
| Rothstein Rosenfeldt Adler  | Atterbury Goldberger & Weiss, P.A. |
| 401 East Las Olas Boulevard | 250 Australian Avenue South        |
| Suite 1650                  | Suite 1400                         |

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 16 of 26

LM v. Epstein

Case No. 502008CA028051XXXXMBAB

Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions

Page 9 of 9

| Fort Lauderdale, FL 33301   | West Palm Beach, FL 33401-5012           |
|-|-|
| 954-522-3456 Phone          | Fax: 561-835-8691                        |
| 954-527-8663 Fax            | Co-Counsel for Defendant Jeffrey Epstein |
| Counsel for Plaintiff       |                                          |

Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesery Boulevard
Suite 250
Jacksonville, FL 32211
904-680-1234 Phone
904-680-1238 Fax
Co-counsel for Plaintiff

BURMAN, CRITTTON, LUTTIER & COLEMAN, LLP
303 Banyan Blvd., Suite 400
West Palm Beach, FL 33401
(561) 842-2820
(561) 844-6929 Fax

By: <signature> 12492
Robert D. Critton, Jr.
for Florida Bar #224162
Michael J. Pike
Florida Bar #617296
(Counsel for Defendant Jeffrey Epstein)

[ ]

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 17 of 26

Larry  Visoski

October 15, 2009

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 502008CA028051XXXXMB AD

L.M.,

Plaintiff,
-v5-

JEFFREY EPSTEIN,

Defendant.

DEPOSITION OF LARRY VISOSKI

Thursday, October 15, 2009
10:18 3:37 p.m.

515 N. Flagler Drive
Suite P200
West Palm Beach, Florida 33401

Reported By:
Wendy Beath Anderson, RPR, CRR, FPR
Notary Public, State of Florida
Esquire Deposition Services
West Palm Beach Office Job #127542

1

6
7
8

9

10
11
12

13

14
15
Soro a 222 222 2222
16

17
18

19

20

21

23
24
25

## 2

APPEARANCES:
On behalf of the Plaintiff:
BRADLEY J. EDWARDS, ESQUIRE
ROTHSTEIN, ROSENFELDT. ADLER
401 East Las Olas Boulevard
Suite 1650
Fort Lauderdale, Florida 33394

On behalf of the Defendant:
ROBERT D. CRITTON, JR., ESQUIRE
BURMAN, CRITTON & LUTTIER
303 Banyan Boulevard, Suite 400
West Palm Beach, Florida 33401

On behalf of the Witness:
BRUCE REINHART, ESQUIRE
250 South Australian Avenue
Suite 1400
West Palm Beach, Florida 33401

ALSO PRESENT:
CARA L. HOLMES, ESQUIRE
1220 N.W. 157th Avenue
Pembroke Pines, Florida 33028
ADAM D. HOROWITZ, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
18205 Biscayne Boulevard, Suite 2218
Miami, Florida 33160

RICHARD H. WILLITS, ESQUIRE (VIA TELEPHONE)
RICHARD H. WILLITS, P.A.
2290 10th Avenue North, Suite 404
Lake Worth, Florida 33461

## 3

1

2

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23 22222

24

25

INDEX

WITNESS: DIRECT CROSS REDIRECT RECROSS

LARRY VISOSKI

BY  MR.  EDWARDS: 6
6
8  BY  MR.  CRITTON:  214 
214
BY  MR.  EDWARDS:  220  220
9  BY  MR.  CRITTON:  221 
221

EXHIBITS

NUMBER DESCRIPTION PAGE
PLAINTIFF'S EX. 1 FLIGHT LOG BOOK
(MARKED IN PREVIOUS DEPO)

PLAINTIFF'S EX. 2 MESSAGE PAD 119
PLAINTIFF'S EX. 3 MESSAGE PAD 119
PLAINTIFF'S EX. 4 COMPLAINT 139
PLAINTIFF'S EX. 5 INMATE VISITOR LOG 161

## 4

1

2

3

4

5

6

7

8

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PROCEEDINGS Deposition taken before. Wendy Beath Anderson, Certified Rea!tirne Reporter and Notary Public in and for the State ofFlorida at Large, In the above cause. MR. EDWARDS: We're going to put something on the record about·- well, we'll do It thisway - MR. REINHART: Do itat the end, after we get him - whatever you want. It's your show. MR. EDWARDS: Okay. There were --1 don't eventhink Mr. Willits is aware of this. There was a subpoena duces tecum forthis witness, as well as the previous witness, which was another pilot, Dave Rogers, and that duces teoum was to bring the flight logs related from 1998through 2005. What was produced at the previous deposition were flight logs from 2002 through 2005, ancl now Mr. Reinhart has agreed to produce the remainder of the flight logs requested, those going from 1998t11rough 2002. MR. REINHART; Correct. They're pilot logs, notnight logs. There are other records we indicated are corporate records, and with those you have to deal with Mr. Critton. MR. CRITTON: However, with the proviso, too,

DEFENDANT'S
EXHIBIT

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 18 of 26

October 15, 2009

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## 66

Q. All right. When you read in the newspapers the allegations that Mr. Epstein was involved with numerous underage girls for sexual reasons, were you surprised? A. I didn't believe it. Q. Do you believe it today? A. I don't believe it. Q. You don't believe that Jeffrey Epstein was involved with underage girls in a sexual way? MR. CRITTON: Form. THE WITNESS: You're asking for my opinion, and I don't think my opinion is relevant in that matter. BY MR. EDWARDS: Q. I think it's relevant. Can you just tell me whether today you believe that Jeffrey Epstein has engaged in sex with underage girls? MR. CRITTON: Form; speculation, irrelevant, always. THE WITNESS: It's irrelevant. BY MR. EDWARDS: Q. I need an answer. A. I don't believe he had sex with underage women. Q. Or engaged in any sexual acts with underage

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women? MR. CRITTON: Form. THE WITNESS: No. BY MR. EDWARDS: Q. You think that this is just a story that a bunch of underage women have made up? A. Speculation. MR. CRITTON: Objection. Now it's argumentative. Who gives a darn what he thinks one way or another? If he has personal knowledge - MR. EDWARDS: You're objecting to the form? MR. CRITTON: It's argumentative. MR. EDWARDS: You're objecting to the form? MR. CRITTON: Yes. MR. EDWARDS: Okay. BY MR. EDWARDS: Q. Is that something that you believe that a bunch of women -- some of which know each other, some 19 don't, some of which have been on the airplane and some which haven't made this up, that Jeffrey Epstein engaged in some sexual conduct with them? MR. CRITTON: Form. THE WITNESS: What I believe doesn't matter in this case, does it?

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BY MR. EDWARDS: Q. I need an answer. Do you believe it? Do you believe these girls made this up? MR. CRITTON: Form. MR. REINHART: I'm going to instruct him not to answer. Move on. MR. EDWARDS: Is there a privilege that we're asserting? MR. REINHART: No, It's irrelevant. It's harassment and not likely to lead to discoverable evidence. 'MR. EDWARDS: I'm going·to--put on the record right now that it is -- we are allowed discovery into a RICO count. We are also allowed discovery into the intent ofMr. Epstein In developing a criminal enterprise designed to sexually exploit and sexually abuse underage girls. We believe that in doing so, he associated intentionally with people of similar beliefs that sex with underage girls is okay, and that there have been rnany discussions with this witness, as well as many other witnesses with -- to Ins lire his protection from law enforcement that they not answer these specific questions. And thus, the opinions and beliefs of all of these witnesses that we are

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 19 of 26

Larry Visoski October 15, 2009

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thoughts are on something which he has no factual basis or even an assumption to know one way or another is irrelevant. That's ultimately for a fact-finder in this case. While it's interesting, it's argumentative and I don't think he's -- I mean, do it on a question-by-question basis. If he has knowledge, that's great, but to argue your case with this witness or any other witness doesn't serve a purpose and I think is, you know -- I think it's not a good use of our time, I'll put it that way. But you know, you can go ahead and ask. MR. EDWARDS: I can ask the question and if the witness is being instructed not to answer, we'll let a judge decide whether he needs to answer the question and whether it's discoverable or not. MR. REINHART: Absolutely. Make your record. BY MR. EDWARDS: Q. Do you have any reason to believe that Jeffrey Epstein engaged in sexual activity with underage women? A. I have no reason to believe. Q. Okay. So as you sit here today, based on your 18 years of knowledge, experience and observation of Jeffrey Epstein, is it your belief that he has not had sex or engaged in sexual activity with underage women?

alleging associated with this criminal enterprise are certainly reasonably calculated to lead to the discovery of admissible evidence. And if you're still instructing the witness, based on that proffer, not to answer any of these questions, I'm going to continue to ask the questions and you can instruct him not to answer and we can go to the Court. MR. REINHART: My response is to his opinion whether people making allegations in this case are colluding or making up a story is irrelevant to what you just said. So I am going to instruct him not to answer any question that goes to his opinion of someone else's motivation or the truth of facts to which he has no knowledge. So yes, I'm instructing him not to answer. MR. CRITTON: Let me add in my part, is that I think you're certainly not only capable to ask questions with regard to what his personal knowledge is, and if he knows something or he has reasonable basis for it; certainly you are entitled to that information. I think you've asked those questions and he's given you straightforward answers as to what he knew or what he didn't know under those circumstances. And as to what his

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A. It's an opinion, and I believe that he has not. Q. Okay. Isn't it true that at some point in lime you leamed that Jeffrey Epstein has -- strike that. MR. CRITTON: When you ultimately get to a good place to break, will you let us know? MR. EDWARDS: Let's break now. (A break was had at 11:28 a.m.) BY MR. EDWARDS: Q. All right. Eighteen years of being a pilot for Jeffrey Epstein and in terms of being able to name somebody that you would say you've observed with Jeffrey Epstein and would classify that person as Jeffrey Epstein's friend, can you name anybody? A. Nadia, Sarah; just people that we see routinely on the airplane. Q. That's people you see routinely in the last five to ten years, right? A. Yes. Q. Prior to that time, anybody that you've noticed as Jeffrey Epstein's friend may be Ghislaine Maxwell? A. What time frame? Q. Is that a person that at some point in time

72 you would classify as Jeffrey Epstein's friend? A. I would classify it. I don't know If it's true. Q. But that's only because they were on the airplane together? A. Yes. Q. Do you know what Jeffrey Epstein does for a living in your 18 years of observing and talking with Jeffrey Epstein? A. No. Q. No idea? A. No. Q. Ever asked him? A. No, actually. Q. Ever been curious? A. Sure. Q. Ever done anything to satisfy that curiosity? A. If you mean Google it, not really, actually. I mean, I really have not. Q. Okay. So in 18 years of traveling and being the pilot and driving -- and taking this person, Jeffrey Epstein, from one property in New York to New Mexico and Florida and around the world, you have no idea what he does in terms of how he makes money? A. No, sir.

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 20 of 26

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## 156

|                                                                                                                                                                                                                                                                                                                                                       |
|-|
|                                                                                                                                                                                                                                                                                                                                                       |
| S                                                                                                                                                                                                                                                                                                                                                     |
| MR. CRITTON: Form.                                                                                                                                                                                                                                                                                                                                    |
| THE WITNESS: No.                                                                                                                                                                                                                                                                                                                                      |
| BY MR. EDWARDS:                                                                                                                                                                                                                                                                                                                                       |
| Q. If you had been aware that Mr. Epstein was --<br />and by this this is more in the form of a                                                                                                                                                                                                                                                       |
| hypothetical, and that I'm not going.to suggest to you                                                                                                                                                                                                                                                                                                |
| It's a fact that he was. But if you had been aware that<br />every single day Jeffrey Epstein's goal was to locate<br />underage girls for the purposes of sex, and either have<br />sex with them on the airplane or at some other<br />designation that you were destination that you were<br />traveling him to, would you have continued to pilot |
| those planes?                                                                                                                                                                                                                                                                                                                                         |
| MR. CRITTON: Form.                                                                                                                                                                                                                                                                                                                                    |
| THE WITNESS: You said it was hypothetical?                                                                                                                                                                                                                                                                                                            |
| BY MR. EDWARDS:                                                                                                                                                                                                                                                                                                                                       |
| Q. Right, it is a hypothetical.                                                                                                                                                                                                                                                                                                                       |
| A. Why would I want to answer that? Because                                                                                                                                                                                                                                                                                                           |
| you're being hypothetical. I mean, it would obviously                                                                                                                                                                                                                                                                                                 |
| be wrong.                                                                                                                                                                                                                                                                                                                                             |
| Q. Sure. Well, a hypothetical question is a                                                                                                                                                                                                                                                                                                           |
| legal question that I'm allowed to ask.                                                                                                                                                                                                                                                                                                               |

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 21 of 26

Larry Visoski

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## 157

A. Okay. Q. And I'm just asking you if you did have knowledge that Jeffrey Epstein was having sex with little girls either on the plane or at a place that you were taking him to or from on a daily basis, that's what he did, would you have continued to be his pilot? MR. CRITTON: Let me object. Object to the form. It's argumentative. It has no more value than assuming he was chopping up bodies or anybody was chopping up bodies in the plane you're flying. What difference does it make? Form. MR. EDWARDS: What difference does it make in a case about him having sex with little girls? I'm not going to argue with you about it. You've stated your objection. MR. CRITTON: Exactly. It's an argumentative question. MR. EDWARDS: I'm not going to argue with you about it. MR. CRITTON: You're arguing with him about now. MR. EDWARDS: No, I'm asking him the hypothetical. BY MR. EDWARDS: Q. Can you answer that? Would you have continued]

## 158

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to be a pilot for somebody who's traveling to and from destinations with the goal of having sex with underage girls? MR. CRITTON: Form. THE WITNESS: It could be any person. It doesn't have to be Jeffrey Epstein, then, right? BY MR. EDWARDS: Q. True. A. No, I wouldn't pilot an airplane if there was wrongdoing going on. Q. That you knew about? A. That I knew you about, sure. Q. Me reading this complaint to you, is this the first time you've heard these allegations -- A. Yes. Q. against Mr. Epstein? A. Yes.

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 22 of 26

Larry  Visoski

## 181

which he pled guilty to -- MR. CRITTON: Form. MR. REINHART: Can we for purposes of your hypothetical, what facts do you want him to assume are true? You said the facts to which he pled guilty, but the witness already said he doesn't know what he pled guilty to. He knows the charge he doesn't know the facts. . BY MR. EDWARDS: Q. Solicitation of prostitution of a minor, somebody under the age of 18. MR. EDWARDS: That's the charge, right, solicitation of prostitution of a minor? MR. CRITTON: No. I think you've got it wrong. I'll object to the form. MR. EDWARDS: Okay. BY MR. EDWARDS: Q. Then we'll handle the question this way: If you were to believe based on information and evidence that Mr. Epstein engaged in sex or some form of sex act with people of the age range of 12, 13, 14, 15 years old, would you continue your employment with Mr. Epstein? MR. CRITTON: Form; speculation. THE WITNESS: I would certainly be speculating

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## 182'

and I have to discuss it with my wife long and hard. I don't think I could give you a correct and honest answer at this time. BY MR. EDWARDS: Q. Okay. Given the allegations that have been made in this case, is this something that you have discussed with anyone other than your attorney? A. No, not really. Only from the fact that they're allegations and there's still a lot more work, I'm sure, to be discovered. MR. CRITTON: Let me put on there, for the -- If this deposition is not typed - and we request it I'd like at least this portion where Mr. Edwards' last question back about five pages worth, so just if you could mark it from this page back about five pages. If nobody requests the deposition, I'd just like those five pages. MR. EDWARDS: I'm going to request the deposition, so... MR. CRITTON: Okay. We'll mark this then, so you could tell me where it is, approximately. BY MR. EDWARDS: Q. Is there a reason why you have not discussed with Jeffrey Epstein the allegations that have been m

[ ]

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 23 of 26

# Larry Eugene Morrison - Volume I

October 6, 2009

1

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY, FLORIDA

VOLUME I Pages 1 to 200

L.M.,

Plaintiff,

vs. Case No. 502000CA028051
XXXXMB AD
JEFFREY EPSTEIN,

Defendant.

DEPOSITION OF
LARRY EUGENE MORRISON
TAKEN ON BEHALF OF THE PLAINTIFF
October 6, 2009
10:55 a.m. 2:20 p.m.

515 N. Flagler Drive
West Palm Beach, FL 33401-4321

Jennifer DiLorenzo, court reporter

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## 2

APPEARANCES OF COUNSEL
On behalf of the Plaintiff L.M.:
ROTHSTEIN, ROSENFELDT & ADLER
BY: BRADLEY J. EDWARDS, ESQ.
and MICHAEL WHEELER, ESQ.,
401 East Las Olas Boulevard
Suite 1650
Fort Lauderdale, FL 33394
954-522-3456
bedwards@rra-law.com
mwheeler@rra-law.com

On behalf of Plaintiffs Jane Doe 2 through 8:

MERMELSTEIN & HOROWITZ, P.A.
BY: JESSICA D, ARBOUR, ATTORNEY-AT-LAW,
18205 Biscayne Boulevard
Suite 2218
Miami, FL 33160
305-931-2200
Jarbour@sexabuseallomey.com

On behalf of Plaintiffs Jane Doe 101 and 102 by
telephone:

PODHURST ORSECK, P.A.
BY: KATHERINE W. EZELL, ATTORNEY-AT-LAW,
25 W. Flagler Street
Miami, FL 33130
305-358-2800
kezell@podhurst.com

On behalf of the Plaintiff C.M.A. by telephone:

LAW OFFICE OF RICHARD WILLITS, P.A.
BY: RICHARD WILLITS, ESQ.,
2290 10th Avenue N.
Suite 404
Lake Worth, FL 33461
561-582-7600
lawyerwillits@aol.com

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202 22 22222 2

APPEARANCE OF COUNSEL
On behalf of the Defendant:
ATTERBURY, GOLDBERGER & WEISS
BY: JACK ALAN GOLDBERGER, ESQ.,
250 Australian Avenue
Suite 1400
West Palm Beach, FL 33401
561-659-8300
jgoldberger@agwpa.com

On behalf of the Defendant by telephone:

BURMAN, CRITTON, LUTTIER & COLEMAN
BY: MICHAEL J. PIKE, ESQ.,
515 N. Flagler Drive
Suite 400
West Palm Beach, FL 33401
561-842-2820
mpike@bclclaw.com

On behalf of the witness:

LAW OFFICE OF BRUCE E. REINHART
BY: BRUCE E. REINHART, ESQ.,
One Clearlake Center
250 S. Australian Avenue
Suite 1400
West Palm Beach, FL 33401
561-202-6360
BReinhart@Bruce REinhartLaw.com

4

INDEX OF EXAMINATION

WITNESS:
LARRY EUGENE MORRISON
Page
DIRECT EXAMINATION
By Mr. Edwards #5

CROSS-EXAMINATION
By Ms. Ezell #190
CROSS-EXAMINATION
By Mr. Willits #195

CROSS-EXAMINATION
By Mr. Pike #196
FURTHER REDIRECT EXAMINATION
By Mr. Edwards #199

INDEX TO EXHIBITS

Plaintiff's
Exhibit Description Page
1 Twenty-four pages of "JEGE, Inc.,
Passenger Manifest." #138

(Plaintiff's Composite 1 was attached to the
original transcript and copies of the transcript.)

ALL-STATE LEGAL® DEFENDANT'S EXHIBIT B

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 24 of 26

October 6, 2009

## 135

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A. I have no idea. I don't know. Q. When you say that Nadia Marcinkova was just coming in the picture, what's your understanding as to who Nadia Marcinkova is relative to Mr. Epstein? A. I don't know. I don't understand. I don't know. I didn't know if maybe she was like an exchange -- Jeffrey always appeared to be very involved in education and philanthropy. I didn't know if she was an exchange-type student or something or what. I don't know. Q. When you say he appeared to be "Involved in," what do you mean? A. Educational things, foundations, science foundations, and things. Q. Speaking of the Florida Science Foundation is a place where, when he was on work release, he spent a lot of time there, you're aware of that? A. That's what I've heard, yeah. Q. What does that place do? A. I have no idea. Q. Does it do anything? A. I don't know. I don't know anything about it. Q. Certainly you've read certain newspaper articles about the allegations, police reports,

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## 136

otherwise, the allegations that occurred or have been
alleged to have occurred at his Palm Beach mansion,
correct?
A. Uh-huh.
Q. Correct?
A. Correct.
Q. Given the nature of those allegations, would
you leave your daughter of 17, 16, 15 years old with Mr.
Epstein alone?
MR. PIKE: Form. Move to strike.
A. Yes.
Q. You would?
A. (Witness nods head.)
Q. And why?
A. Because I don't fear that he would try
anything with my daughter. He showed -- When !
worked for him he showed me respect. He never - I
never -- He never showed me disrespect. He would ask
how the family is. I mean, not on a personal level,
but an employer/employee.
Q. Right. Okay.
A. He never showed me any reason not to trust
him.
Q. But you're not a 13-year old girl, so.
A. No, but, like I say, he never showed me

Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 25 of 26

October 6, 2009

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Q. And despite pleading guilty to procuring underage girls for the purposes of sex, you still feel comfortable leaving a 13, 14, 15-year-old girl around him? MR. PIKE: Form. Move to strike, A. Yes. I mean, with my daughter, yes. I don't know how he behaves around anybody else, ! just know that the respect that he showed me, i feel safe with my daughter. Q. And have you read in detail the reports as to what happened at his house with the girls? A. Only - MR. PIKE: Form. A. what's been in the newspapers and published. Q. If you read and hear testimony given - well, I can tell you now - testimony has been given in this case that what happens is: A 13 or 14 year old is led upstairs by herself, told to get naked, he lays down on his back, there is a brief massage before he turns over, exposes himself erect, masturbates while he tells this 13 or 14 year old to pinch his nipples as hard as she can while he inserts his fingers into their vagina and ejaculates all over them before saying, "Take your money and leave."

## 176

"

MR. PIKE: Form. Move to strike. BY MR. EDWARDS: Q. Okay? Then, "You can continue to come back for $200 every time or every girl you bring me within your age group and I get to do this again, I pay you $200 per person." If that is the testimony -- MR. PIKE: Form. Q. that what happens behind closed doors with him, do you still feel comfortable leaving a 13 or 14 year old in a room with Jeffrey Epstein? . MR. PIKE: Form. A. If that, in fact, is what actually happened, no.

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Case 9:09-cv-80802-KAM Document 16 Entered on FLSD Docket 11/09/2009 Page 26 of 26

## 184

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| you witnessed Jeffrey Epstein committing?                                                                       |
|-|
| A. No.                                                                                                          |
| Q. Would you -                                                                                                  |
| A. No.                                                                                                          |
| Q. -- go back - considering what you've read and                                                                |
| what you may or may not believe - would you go back to<br />working for Jeffrey Epstein?<br />MR. PIKE: Form.   |
| A. I can't say. I still work for him on a<br />maintenance - to maintain the airplanes and stuff<br />that, so. |
| Q. You're on his payroll?                                                                                       |
| A. Salaried, yes.                                                                                               |
| Q. Do you know who else is on his payroll?                                                                      |
| A. Well, Dave and Larry,                                                                                        |
| Q. Certainly, if I want to know more about his                                                                  |
| private life - do you know who's at his house?                                                                  |
| A. No.                                                                                                          |
| Q. Do you know who his housekeeper is?                                                                          |
| A. No,                                                                                                          |
| Q. Do you know who his architect is?                                                                            |
| A. No, no.                                                                                                      |
| Q. Does Larry visit him at his house?                                                                           |
| A. I would assume so.                                                                                           |
| Q. Why do you say you would assume so? That                                                                     |
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