• L.M., Condensed Transcript

• ,I • • L.M., Condensed Transcript IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Case No. 502008CA028051 XXXXMB AD DEPOSITION OF LARRY EUGENE MORRISON TAKEN ON BEHALF OF THE PLAINTIFF VOLUME I Pages 1 to 200 October 6, 2009 10:55 a.m. 515 N. Flagler Drive West Palm Beach, FL 33401-4321 court reporter 0 ESQUIRE Toll Free: Facsimile: IMMIIM www.esquIresolutionS.com EFTA00181380 • • • EFTA00181381 Larry Eugene Morrison - Volume I October 6, 2009 • • 1 IN /NS CIRCUIT COURT Of TAR 15Th JUDICIAL CIRCUIT IN AND PM PAIN BRACH COUNTY. FLORIDA VOLONE I Pages 1 to 200 2 3 3 APPEARANCE OF COUNSEL On behalf of the Defendant ATTEFOURY. GOLDBERGER A WEISS BY: JACK ALAN GOLDBERGER. ESO.. 4 250 Australian Avenue Suite 1400 5 act. FL 33401 Plaintiff. I 6 /Case No. 5020006020051 On behalf of the Defendant by telephone: IX/WM AD JRFPRRY DITHER. e BURMAN. CRITTON. LUTTIER & COLEMAN Defendant . I 9 BY: MICHAEL J. PIKE. ESO.. 515 N. Fla or Drtve DEPOSITION OF 10 Suito 400 lm ad,. FL 33401 LARRY MAUNA NORAISON 11 TAKEN On SHALT OF INA PLAINTIFF October 4. 2009 12 10/59 a.m. - 2/20 p.m. 13 On behalf of the witness: 515 X. ?kegler Drive Nest Palm Beach, FL 13401.4121 14 LAW OFFICE OF BRUCE E. REINHART 15 BY: BRUCE E. REINHART. ESO.. One Clearleke Cantor 16 250 S. Australian Avenue Suite 1400 court reporter 17 &ch. FL 33401 16 19 20 21 22 23 24 25 2 4 1 APPEARANCES OF COUNSEL 1 INDEX OF EXAMINATION e I On banal a the Flambe L.M.. ROTHSTEIN. 110SENFELDT a ADLER 2 BY: BRADLEY J. EDWARDS. ESO. 3 WITNESS: 4 111X1MICHAEL WHEELER. ESO.. 4 LARRY EUGENE MORRISON 401 East Las OHS 130.40Velt1 5 Page S41[91650 ran Lo, ie. FL 31394 6 DIRECT EXAMINATION By Mr. Edwards #5 7 CROSS-EXAMINATION On betel d Planter Jane Doe 2 through s By Ms. Ezell *190 T mERUELSTE1N 6 HOROWITZ. PA 9 CROSS-EXAMINATION By Mr. Willits #195 10 BY: JESSICA D. ARBOUR. ATTORMEY.AT4AW. 11) 11 19205 Beware Boulevard Suite 2218 CROSS-EXAMINATION Men. 1-1. 33160 11 By Mr. Pike N196 12 12 FURTHER REDIRECT EXAMINATION By Mr. Edwards #199 li On Denali of mantes Jane Doe 101 aro 102 by 13 telephone: 14 15 PODHURST ORSECK PA 15 16 BY: KATHERINE W. EZELL. ATTORNEY.ATiLAW. 25 W. Ragier Street 16 INDEX TO EXHIBITS 17 17 Plaintiffs IS 18 Exhibit Desolation Page On banal of me Plartlf C.MA by telapheac 19 1 Twenty-four pages of 'JEGE. Inc.. 20 Passenger Manifest.' *138 LAW OFFICE OF RICHARD WILLITS. PA 20 St BY: RICHARD WILLITS. ESO.. 21 2290101h Avenue N. 21 Suite 404 22 Laks Worm 33481 23 21 25 24 (Plaintiffs Composite 1 was attached to the original transcript and copies of the transcript.) 25 25 • ESQUIRE TN' Free: Facsimile: EM www.esquIresolutions.com EFTA00181382 Larry Eugene Morrison - Volume I October 6, 2009 1 2 3 4 5 6 7 8 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 whale truth. and nothing but the truth so help you God? THE WITNESS: So help me God. ------- LARRY EUGENE MORRISON, having been first duly sworn, was examined and testified as follows: DIRECT EXAMINATION BY MR. EDWARDS: O. Tell us your name. A. Larry Morrison. O. And, Larry, where are you employed right now? A. For JEGE. O. What's JEGE mean? A. It's the aviation flight department for Mr. Epstein, and my primary job is Dankjold Reed Aviation. MR. REINHART: Spell it. A. D-A-N-K-J-O-L-D, and then the second word is Reed, R-E-E-D. Aviation. Its a corporate flight 7 1 You know. it was a business decision made somewhere. 2 O. What does the company do? 3 A. What? The company? It's just a holding 4 company, I think, for the aircraft. It's not -- I 5 don't believe it to be a money making company or a 6 real corporation. 7 O. You're saying 'tor the aircraft* I'm 8 interpreting that to mean you're talking about one 9 aircraft. 10 A. Correct. 11 O. Does that mean there's one or there's more 12 than one? 13 A. There's more. He owns more than one, but 14 justoneis JEGE Of -- 15 O. And the aircraft that he owns, how many of 16 those do you either service and/or ride on? 17 A. I used to. I haven't been — Actually, I 18 stepped back from being physically involved, just • 19 now I just do paperwork • and it was February of 20 2007. So I haven't actually physically been on the 21 airplanes other than I will take the Boeing for 22 maintenance. 23 O. Since it seems like we've kind of skipped 24 ahead from 2001 to 2007, am I right that your first 25 involvement with Jeffrey Epstein of any way, shape, or 6 1 department. 2 O. What do you do for him? 3 A. Director of Maintenance. 4 O. Okay, so you maintain his planes -- 5 A. Correct. 6 O. should something go wrong? 7 A. Correct. Yes. Yep. 8 O. Do you also — 9A. For maintenance. 10 O. Do you also fly on his planes? 11 A. On Mr. Epstein's? 12 O. Yes. 13 A. I used to. I was a flight engineer -- 14 O. Okay. What -- 15 A. -- on his 727. 16 O. When you list your company - JEGE? 1? A. Yes. Yeah, ifs just initials. It's an 18 LLC or holding company. 19 O. How long has that holding company been around, 20 if you know? 21 A. Since — I think it was developed when I 22 came with the airplane • 2001. 23 O. Whose idea was it for that to come about • was 24 it yours? Was it his? 25 A. Oh, no. no, somewhere -- It wasn't mine. 8 1 form was 2001? 2 A. That's correct, yeah. 3 O. You didn't meet him before that. 4 A. I had met him. He was a -- He was an 5 associate of my previous boss. 6 O. Who's that? 7 A. Mr. Wexner. 8 O. -Wexner? 9 A. Yes. 10 O. How do you know Wexner? 11 A. I worked for Limited Stores for 12 years. 12 O. Doing what? 13 A. Essentially the same thing - aircraft 14 maintenance for their corporate flight department and 15 flight engineering on the 727. 16 O. How many aircraft did Wexner have? 17 A. Well, none that I know that he had 18 personally, but the corporation had - the flight 19 department operated - we had three Gulfstreams, two 20 Hawkers, and a 727. 21 O. What was the name Of his Corporation that 22 maintained the aircraft? 23 A. For Limited Stores? 24 O. Yes. 25 A. It was just -- It was called Limited - Toll Free: Facsimile: ESQUIRE www.esquireSOlutiOnS.COm • • • EFTA00181383 . Larry Eugene Morrison - Volume I October 6, 2009 • • 9 1 Limited Flight Department. 2 O. And do you know him personally then -- 3 Wexner? 4 A. Yeah, I had met him, of course, you know. 5 I met him. I used to do aircraft completions for 6 him, so which would involve personal meetings. 7 O. When did you first meet Wexner? 8 A. 1988 was when I hired on, so I don't 9 remember the month. 10 O. How did you get that job? 11 A. Through word of mouth and, you know. I 12 worked - I lived in - been in aviation for years in 13 Columbus. 14 O. Well, I mean, I= Wexner's an important 15 person, right? I mean, he -- 16 A. Correct 17 MR. GOLDBERGER: Form. 18 BY MR. EDWARDS: 19 O. He's somebody who owns - my understanding - 20 Limited, Victoria's Secret? 21 A. Well, he doesn't own them. He's Chairman. 22 you know. 23 O. Chairman of -- 24 A. Yeah. He doesn't personalty own it. It's 25 a publicly held company. 11 1 O. Yes. 2 A. Aircraft technician. 3 O. Which entails what? 4 A. Maintenance of any or all of the aircraft 5 operated by the flight department and some flight 6 mechanic duties. 7 O. What kind of airplanes? 8 A. Gulf streams, Hawkers. 9 O. How big is the Gulfstream? to A. Fifteen passenger - 15 to 17. 11 (Mr. Goldberger exited.) 12 BY MR. EDWARDS: 13 O. What did Wexner use the Gulfstream for? la A. They were division airplanes. mostly. 15 O. And the other airplane you named - what did he 16 use that for? 17 A. Same, same. 18 O. Any idea why he had two planes? 19 A. Well, I mean, yeah, we used them - they're 20 a tool. It wasn't him. It was a large Fortune 500 21 company. They use them as tools to -- You know, 22 Limited has control over 60 percent of their 23 manufacturing processes. plus, you know, what, 1200 24 stores, or whatever, throughout all their divisions. 25 I mean, when you say "Limited,* it's not 10 1 O. Where were you prior to any involvement with 2 MI Wexner? 3 A. I worked for Red Roof Inn True Sports 4 Flight Department. 5 O. How did that position lead you to 6 Wexner? 7 A. Well, it was always known that Limited 8 Flight Department was one of the best jobs in 9 Columbus and, actually, several other people that 10 were already there knew me from previous jobs and 11 education - we went through aircraft mechanic, or A&P 12 school, together - so when the position became 13 available they pointed to me and - absolutely. It 14 was a line organization. 15 O. So did Mr. Wexner approach you or did you 16 apply to him or how did that work? 17 A. Oh, no, no, no. It's -- No. He wouldn't 18 be involved in that type of activity. You apply to 19 H.R. and you interview with the Director of 20 Operations or the Chief Pilot. You know, he 21 wouldn't. 22 O. So you start with Wexner in 1988. 23 A. Yes. 24 O. What do you do for him then? 25 A. What did I do for him? 12 1 just Limited, d's Victoria's Secret and it was 2 Express and Lemers and Henri Benders and all of 3 that back then, so, I mean -- 4 O.50— A. -- we moved a lot of passengers to keep 6 those stores for the retail business. 7 O. And by *passengers.' do you also mean clients 8 of his? 9 A. That I don't know. No. Mostly we just 10 dealt with upper echelon, you know, people in the 11 retail businesses from -- 12 O. Such as whom? 13 (Mr. Goldberger entered.) 14 A. Can't even remember names, but it would be is -- We would take buyers to Europe in the spring and 16 fall. They would buy samples and bring them back to 17 analyze for marketing. We would hire -- We would- 18 Division heads, when they would do store shops and, 19 Real Estate, we take Real Estate out when they were 20 looking for new real estate. 21 O. While you were working back in '88 -- Well, 22 how long overall did you work with Wexner and/or 23 his companies? 24 A. Well, '88 through when I camp hero in 25 January of '01. • 0 ESQUIRE Toll Free: Facsimile: www.esquiresolutIons.com EFTA00181384 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 - upstaging 8 an airliner on a private ticket or a VIP ticket is 9 really challenging, and I enjoy the challenge of 10 working and developing the program and stuff. 11 O. Well, my understanding, Wexner is 12 generally - he's in Ohio, right? 13 A. No, he's got other places. I mean -- No, 14 he's like anyone, he's - in his category - he's got 15 multiple homes and -- 16 O. Well, when you would maintain his aircraft, 17 would that be in Ohio -- 18 A. Yes. We were based -- 19 O. Or elsewhere? 20 A. We were based at Lane Aviation. 21 MR. REINHART: Hold on one second. You 22 have to let him finish asking the question 23 before you answer. 24 THE WITNESS: Okay. I'm sorry. 25 BY MR. EDWARDS: 15 1 aircraft. I mean, whatever it takes to keep a 2 corporate flight department operating. 3 O. Did you know back then of his relationship, if 4 any, with Jeffrey Epstein? 5 A. Not immediately, no. 6 O. When is the first time that you knew of a 7 reputation or a relationship between Wexner and Epstein? a A. Would have had to probably be around maybe 9 '98, 99. 10 O. How do you become aware that they know one 11 another? 12 A. Because Jeffrey. every one That's when 13 I became a flight engineer on the Boeing. and every 14 once in a while Jeffrey would ride on the Boeing, 15 that's all • that's all I knew. 16 O. How did it come about that he would ride on 17 Wexner's Boeing? 18 A. They were business associates, I think. 19 O. As far as you know, they were business 20 associates. 21 A. Right. 22 O. Did you understand the business relationship 21 between the two? 24 A. Welk I believe it's public knowledge 25 that, I think, Jeffrey managed Mr. • some of Mr. 14 1 O. I'm sorry, have you ever had your deposition 2 taken before? 3 A. No. 4 O. You definitely never had your deposition taken 5 before while somebody else is trying to eat at the same 6 time they're trying to ask the questions that's very 7 bizarre. A. Yes, yes. 9 O. I meant to do this before I got here. But. 10 regardless. Ill wail until you finish your answer before 11 I ask my next question; you do the same thing. 'Uh-huh' 12 or 'uh-uh.' they kind of look the same on the record. so 13 try to give us a 'yes' or 'no' or something we 14 understand. 15 A. Alright. 16 O. II I ask a question that was a bad question or 19 something you don't understand - I've asked bad questions 18 before • say, I don't gel it? I'll ask a better 19 question. 20 A. Okay. 21 O. You were working with = Wexner. You got 22 the job there starting in 1988. On a day-to-day basis, 23 what would you be doing? 24 A. Maintenance, aircraft maintenance, 25 tracking of aircraft maintenance. cleaning of 16 1 Wexner's funds. 2 O. Is that something that Mr. Wexner told you? 3 A. No. 4 O. Is that something that somebody of Mr. 5 Wexner's organization would have told you? 6 A. No. 7 O. Is that something that Jeffrey Epstein told 8 you? 9 A. No. 10 O. Is that just reading articles that speculate 11 as to the business relationship between the two or do you 12 got something more for me? 13 A. No, it's just • it's speculation and, you 14 know, what I've read. you know. 15 O. I mean, like you say, to me it's common 16 knowledge -- 17 A. Right. 18 O. But It's only because of what I've read. I 19 don't have a specific person that I could cite to to say 20 that, do you? 21 A. Right. No, just - just periodicals. 22 O. What's your understanding of the personal 23 relationship, if any, between Wexner and Epstein? 24 MR. GOLDBERGER: Form. 25 A. Don't know. 0 ESQUIRE •5 AlcutadaCsIl•Campay Toll Free: Facsimile: ES www.esquiresolutions.com • • • EFTA00181385 Larry Eugene Morrison - Volume I October 6, 2009 - tt • • • 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 17 O. Did you ever know of a time -- And I may be asking a question that would just be completely outside of your knowledge, so let me back up. Have you ever stayed at Wexner's house? A. No. O. Do you know where his house is? A. Yes. O. Do you know what the address is in Ohio? A. No. I just know the city. 0. Do you know who he lives with? A. Yes. O. Who is that? A. His wife and children. 0. What's his wiles name? A. Abigail. O. Abigail Wexner, and he has three or four daughters, right? A. No. Has got a son. Harry. and two daughters. I think. O. A son and two daughters. A. I don't know. See. that was back in 2001. I don't know what they have - if they have more kids O. Okay. Did you ever hear any Information that he was homosexual? 19 1 O. Have you spoken personally with Mr. Wexner? 2 A- On business issues, yes. 3 O. Business issues related to your work on Ns 4 airplanes? 5 A. Correct. 6 O. Have you spoken to him on any other issues 7 that don't involve business relationships with his a airplanes? 9 A. No. 10 O. Because you're Nred basically for that 11 purpose, so that's kind of how you deal with him. 12 A. Yeah. Ifs I'm an employee and he's my 13 employer and I only deal with him. you know. on 14 issues that Involve maintenance. 15 O. I think I probably know the answer to the next 16 question, but just in case I dont do you know any of 17 his personal friends • people that he would hang out with 18 on a social level - being Mr. Wexner? 19 A. Through my business ties, yes, yes. 20 O. Who's that? 21 A. I'm trying to remember -- You have to 22 remember ifs been several years. 23 O. Right. 24 A. He was friends with the Tuckennans. 25 O. What's Mr. Tuckerman or Ms. Tuckerman's names? 18 1 A. No. 2 O. Being Mr. Wexner. 3 A. No. 4 O. Any indication to you that he may be 5 homosexual or bisexual? 6 A. Absolutely not. 7 O. Have you heard any information that he and Mr. 8 Epstein were involved sexually with one another? 9 A. Oh, no. no. 10 O. Would that surprise you? 11 A. Absolutely. 12 O. And Mats only because you know him and you 13 know Mr. Wexner and you don't see the Iwo together. 14 A. Correct. 15 MR. GOLDBERGER: Form. 16 A. Welt- 17 O. He -- 18 A. Go ahead. 19 MR. REINHART: If you need to answer. 20 answer the question. 21 A. Yeah. No. I saw him with Sharon. which 22 was his previous girlfriend before he met Abigail. 23 O. Right. 24 A. No. There was never any hint or anything 25 that I would even conceive that. 20 1 A. Ms. -- I caret I always addressed them 2 by their proper name. 3 O. Do you know what they do? 4 A. They owned an optical company - opticians. They were high school friends from Mr. Wexner's high 6 school days. 7 O. In Ohio or New York? a A. He went to high school in Bexley. 9 O. Bexley. Ohio. 10 Has he ever discussed with you how 11 longstanding the relationship is between himself and Mr. 12 Epstein? 13 MR. GOLDBERGER: Form. 14 A. I don't understand. Can you rephrase it? 15 O. Well, you know that at some point in time - 16 You started working with him in 1988. The first time. 17 according to my notes. that you became aware that he was 18 friends or acquaintances with Mr. Epstein was '98 - 19 almost ten years later. 20 A. Right. 21 O. After you became aware that there was that 22 relationship, whether business or otherwise, did he ever 23 speak to you about how long he had known Mr. Epstein? 24 A. Oh, no, no. 25 O. So as far as you were concerned, 1998, when ESQUIRE nAltssada Gallo C•sit007 Toll Free: Facsimile: WM. www.esquiresolutIons.com EFTA00181386 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 '805 and, I guess. 6 early '90s, did you have any other personal involvement '7 with him? 8 A. Just on aircraft completions. 9 O. And when you would speak with him, would that 10 be over the telephone. at the airport. at his private -- 11 A. It would usually be al the corporate 12 office. 13 O. Al the corporate office? 14 A. At the corporate office. 15 O. Can you tell me the address for his corporate 16 office? 17 A. No, I can't. 18 O. If I requested that from your attorney, would 19 you be able to get that information? 20 A. Well, I mean. I imagine it's public 21 knowledge • wherever • it's at the Limited. 22 O. And that's where you would meet him • at the 23 Limited? 24 A. Yeah. 25 O. And how often was • you know, I know that 23 1 O. Who were some of the pilots? 2 A. Tun Staley. Jim Taylor. They've had some 3 turnover too. I don't know who all is still there 4 because retail is down. 5 O. Was Larry Visoski a pilot used by MI 6 Wexner at any time? 7 A. No. O. How about David Rodgers? 9 A. No. 10 O. Are those names you're familiar with? 11 A. Yes. 12 O. Those we names you're familiar with how? 13 A. I flew with them when I was flying for Mr. 14 Epstein. 15 O. So there's no real, other than yourself 16 Welt, tell me if I'm wrong: I understand that you did 11 some work for Mr. Wexner related to his aircraft and you Is did some work for Mr. Epstein, which we haven't yet got 19 to, but you did some work for him too. Are there any 20 other people that have that type of relationship with 21 both parties? 22 A. No. I'm sorry, resay that. 23 O. Okay. You've already told us that you were 24 the aircraft technician for Mr. Wexner. 25 A. One of them. One of several, yes. 22 1 we're talking about 15, 2O years ago - how often was Mr. 2 Wexner personally at that location at the Limited 3 offices? 4 A. I have no idea. S O. But any time you needed to talk to him. that's 6 where he would be? 7 A. Yeah, and I usually went to Charlie 8 Hinson. 9 O. Who's Charlie Hinson? 10 A. He was the president of the stores. He 11 basically was my gobehveen for these aircraft 12 completions for the design. 13 O. And you mentioned the Gullstream as an 14 aircraft. Did you also serve as a technician for other 15 aircrafts that were owned by Mr. Wexner? 16 A. Right, but not Mr. Wexner. They're owned 17 or operated by Limited Stores. 18 O. Limited Stores? 19 A. Right. Yes. 20 O. What did you do for them? 21 A. Same • maintenance. 22 O. Did you ever fly in them? 23 A. On the Guff streams in the early days we 24 used flight mechanics, especially on international 25 flights. 24 1 O. One of them. Then you also have knowledge 2 about Mr. Epstein and some relationship with Mr. Epstein. 3 A. Correct. 4 O. Are there any other pilots, aircraft 5 technicians, people like that that you know of to have a 6 relationship with both Mr. Wexner and Epstein? A. No, no. 8 O. Do you know how Mr. Wexner met Mr. Epstein? 9 A. No. to O. How long - if you started in 1988 • how long 11 did you stay with Mr. Wexner and/or The Limited? 12 A. January of '01. 13 O. Why did you stop? 14 A. Because what we were talking before, you 15 know, I wanted to continue flying. They bought a 16 BBJ. which is a two-pilot aircraft, and I wanted to 17 continue flying. Mr. Epstein bought the 727 and 18 offered me a position to continue flying and. you 19 know, basically sot up the airplane for his flight 20 department because they hadn't had any previous large 21 aircraft experience. 22 O. I missed something. It wasn't your fault, it 23 was mine. 24 The Gulf stream that you were talking about. 25 did you used to fly that as well as being a flight S ESQUIRE Alemadet 0•11•Canspny Toll Free: Facsimile: www.esquiresolutions.com • • • EFTA00181387 Larry Eugene Morrison - Volume I October 6, 2009 • • 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 25 technician? A. No, no. O. Okay. A. You don't have to have a flight - a pilot's certificate to be a professional flight engineer. I've got a turbo - a flight engineer turbo jet rating, but you don't have to have a commercial ticket as long as you - the FAA recognizes your heavy aircraft maintenance experience. 0. So you're saying that if the FAA recognizes your heavy maintenance experience, I'm assuming that means that you understand the ins and outs of airplanes and you can work on them. A. On heavy high performance aircraft, yes. 0. Then you can also fly them? A. Sideways as a flight engineer. 0. Explain. A. On the older generation airliners there was three pilots • there's a captain, a first officer, and then the flight engineer is the gentleman that sits sideways and maintains all the systems. 0. When you say, sits sideways: okay, I have A. Literally, you're physically sideways in 27 1 0. Do you know why Epstein those to buy that 2 particular 727 rather than one of the other million 727s 3 that are made? 4 MR. GOLDBERGER: Form. 5 A. Because it was probably the finest one out 6 there •- 7 0. Why? 8 A. -- In all honesty. It's got a fully Paged 9 STC interior with EFTS cockpit, and Limited's 10 reputation on the way that we maintained our aircraft 11 • it's the best one out there. 12 0. Describe for me the interior • I'm not talking 13 about the Epstein days, we're talking about the Wexner 14 days - describe for me the interior of the aircraft, and 15 keep in mind that I've only been on a commercial aircraft 16 where you don't see the pilots. there's a door, and then 17 everybody, you know, there's rust a bunch of seats where 18 everybody sits there. 19 A. Correct. Right. 20 The aircraft You enter the airplane. 21 ifs got forward air stays, which most 72Ts don't, 22 so you enter the forward door on the left-hand side, 23 the forward entryway vestibule, and there's a door on 24 the left, which leads to the cockpit, and then 25 there's a door on the right which leads aft to the 26 1 the cockpit. 2 0. So you're not looking al the people that were 3 flying on the plane and you're not looking at the pilots, 4 you're actually literally sitting sideways. 5 A. I sit sideways at a panel, yes. 6 0. What's your job? 7 A. Maintain all the aircraft systems - the 8 hydraulics, fuel management, pressurization. 9 environmental controls. 10 0. That's not done by the pilots. 11 A. No, no. 12 O. But if you've done that long enough and FAA is 13 aware of your credentials in that respect, then you also 14 could be credentialed to be a pilot as well? 15 A. Well, sure, yeah, yeah. If that's a 16 career choice you wish to take. 17 0. And was that? A. No, no. I was perfectly satisfied with my 19 position as a flight engineer and Director of 20 Maintenance. 21 0. What year did you say Epstein bought the 727 22 that was once owned by Wexner? 23 A. I don't know when the actual transition 24 took place, but when I came - shortly around the 25 period that I came on board in 'et January of '01. 28 1 forward salon. 2 0. What's the forward salon? Sorry. 3 A. Forward seating area. 4 0. And is it set up basically the way that I'm 5 picking it - in that there are 25 or 26 rows and they're 6 numbered A through E? 7 A. No, no, it's a corporate configuration. 8 O. Which means nothing to me, so help me. 9 A. Picture a 600-mile an hour Winnebago. I 10 mean, it's got conference tables and divans and large 11 first class seating. 12 0. Any various dividers throughout -- 13 A. Yes. 14 0. to where there's a VIP room in the back or 15 anything like that? 16 A. It's compartmentized (sic), yes. 17 0. In what way? Describe it as specifically as 18 you can. 19 A. There's a forward salon, a mid galley - 20 the galley's in the mid - an aft • an aft salon, 21 which is • and then the aft slate room. 22 0. Who designed that plane? 23 A. I can't remember who the actual designer 24 was. It was a Page interior, though. Page Avjet did 25 the installation. • ESQUIRE as AI nailerGslisteisay Toll Free: Facsimile: www.esquiresolutionS.Com EFTA00181388 Larry Eugene Morrison - Volume I October 6, 2009 29 O. Who directed the design of that plane? 2 A. It would have been Mr. Wexner. I mean, it was •• The layout has not changed. 4 O. 'The layout has not changed," when you say that, you mean 'from the time that I first got in it and () I was under the guise of -'under 'under the employment of Wexner to the time I've been on it since with Epstein, a the configuration is the same.' 9 A. Essentially, yes. We removed one chair 10 and one small table that was an annoyance and that's 11 it, but it's identical to what The Limited used. 12 O. Are there any blocked ott areas to where if 13 you're standing in the middle of the plane you cant see 14 certain areas of the plane? 15 A. There are pocket bulkheads. Yeah, there's 16 dividers between the sections. 17 O. How big aro these dividers and where are they? 18 A. Well, there's a divider - the forward 19 door, I you, on the salon, then there's a pocket 20 door on the forward side of the galley, a pocket door 21 on the aft side of the galley, there's a pocket door 22 between the aft salon and the office, and then 23 there's another pocket door between the office and 24 the state room. 25 O. Have you been on other 727s before that are 1 2 4 5 6 7 8 9 10 11 12 13 14 IS 36 17 18 19 20 21 22 23 24 25 31 because obviously there's a lot - there's not that A. Privately owned 727s, but this is As a matter of fact. The UmIted's current 88..i nis a very similar floor plan. O. As Trump's? A. No. as the - as our 727. O. Who's 'our? A. Mr. Epstein's. They didn't change a lot. It's - O. Well, I thought that you had told me that the 727 that was once owned by Wexner is the 727 that's owned by Epstein. A. It is. but what I'm saying is even their current airplane has the same layout - the 86J. They put the same floor plane in the more modern airplane. O. Well, they didn't have to put it there. It was already there. right? A. No. no, no. When you buy these aircraft - even a Gulfstream - when you buy them it's just a green hull, there's nothing in them, and you can customize your interior. O. I'm sorry, we're miscommunicating somewhere, and I'm sure it's on me. MR. GOLDBERGER: Yes. it is. 1 2 3 4 5 6 7 a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 30 commercial airliners privately owned? A. Yes, yes. O. Have you noticed similar configurations to where there are this many dividing doors or is this one that has more so than you've seen in the past? A. No, no, this is pretty atypical (sic). O. It's pretty atypical? A. It's typical. O. It's pretty typical? A. Yes, yes. O. So what other airplanes - 727s, or other major airplanes - have you been on that have theSe types of dividers? A. Trump. O. Trump's airplane? A. Yes. O. Why were you on Trump's airplane? A. Well, I know the crew and, you know, this Is a small-knit community. There's not very many of them out there, so everybody in this world knows one another to help one another out as far as -- O. By 'there' -- A. -- information -wise and stuff. O. By 'there aren't that many of these people out there," you don't mean there's not that many people - 32 1 MR. EDWARDS: And I'm taking the blame for 2 it - right away. 3 MR. REtNHART: Take that Ed. 4 MR. EDWARDS: Alright 5 BY MR. EDWARDS: 6 O. My understanding • and please correct me when 7 I'm wrong, because I know I am - Wexner has this 727 and 8 he designs it in a certain way. 9 A. Uh-huh. 10 O. And then you come to work for Epstein 11 A. Yes. 12 O. -- who buys the same 727. Your testimony, as 13 I'm understanding It. is: It's basically the same floor 14 plan as Wexner's floor plan. To me, it should be the 15 exact same because he bought the same plane. 16 A. No. he -- You're misunderstanding. 17 I figured. IS What I was stating is You were I was 19 answering the question in regards to, "Is this 20 unusual to have this many compartments and closed 21 doors and bulkheads and things?' 22 What I was trying to state was: No, it's 23 not unusual - because The Limited even liked the 24 floor plan so well in their old airplane that they 25 sold to Mr. Epstein. They duplicated it In their new Q. A. S ESQUIRE Toll Free: Facsimile: warn • • • EFTA00181389 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. A. Well, no. When you -- When you buy a 6 Boeing business jet — 7 O. Yes. 8 A. -- it comes with nothing inside. It's a 9 tube. Nothing's in there. You design - have 10 designers design your interior and then a fabricator 11 or a facility such as Page Avjet to install this 12 interior. 13 O. Right. 14 A. What I was just trying to state was that 15 The Limited liked their old floor plan in the old 16 airplane so well - it worked so well for them - that 17 they duplicated It and had that same interior 18 installed in the new aircraft - same floor plan 19 installed on the new plan. 20 O. So Epstein didn't buy the exact same plane. 21 He bought the same type of plane. 22 A. Well, more modem. He bought a 737, 23 right. 24 O. Got it. 25 A. Right. 35 1 had a very identical or very like floor plan 2 installed in the new airplane. 3 Q. Got it. 4 Okay? Sony, it's a strange business. 5 It's 6 O. Tell me if I'm right: Mr. Wexner had a plane 7 that had a floor plan that apparently appealed to Mr. 8 Epstein, so Mr. Epstein bought that plane. 9 A. Correct. 10 O. Mr. Wexner also liked that plane that he had 11 just sold to Mr. Epstein, so he built in a floor plan 12 very similar to the one he just sold to Mr. Epstein. 13 A. In his new aircraft. 14 O. Brand new plane. 15 A. Correct. 16 O. Got it. We're on the same page now. 17 A. Alright. 18 O. Took us a while to get there. 19 A. Yeah, sorry. 20 O. I think it was my fault, honestly, but 21 alright? 22 A. It's an unusual process if you haven't 23 been around corporate airplanes. 24 O. I didn't realize that Mr. Wexner had a new 25 plane. 34 1 MR. REINHART: Hold on. 2 BY MR. EDWARDS: 3 O. Totally understand now. 4 MR. REINHART: Can you clarify - Mr. Epstein or Mr. Wexner? 6 BY MR. EDWARDS: 7 O. Mr. Epstein bought not Mr. Wexner's plane. 8 A. No. 9 O. He bought the same type of plane that Mr. 10 Wexner had and modeled the floor plan -- 11 A. No. 12 O. -- the same way that Mr. Wexner had it. 13 A. That is not correct. 14 O. He bought, actually, Mr. Epstein -- 15 MR. REINHART: Hold on. Distinguish - 16 Use names so we're very clear when you're 17 talking about Mr. Epstein and Mr. Wexner, okay? 18 A. Mr. Epstein bought Mr. Wexner's 727. 19 O. Okay. 20 A. The actual airplane - bought it from him. 21 O. Which has a floor plan already in it. 22 A. That we just discussed. 23 O. Alright. The floor plan's in the plane. 24 A. Right. Mr. Wexner replaced the airplane 25 that Mr. Epstein bought with a new airplane and he 36 1 A. Yes. 2 O. That's where I had a problem. 3 How many times have you been on Mr. Wexner's 4 airplane? A. The new? 6 MR. REINHART: Clarify which one you're 7 talking about. 8 BY MR. EDWARDS: 9 O. Before you ever met Mr. Epstein. 10 A. I can't say. I mean, over the years? 11 O. Numerous times? 12 A. Oh, I was his flight engineer. You mean 13 when I was still employed by him? 14 O. Yes. 15 A. Yes. I was the flight engineer. I 16 don't-- 17 O. So as a flight engineer, every time the plane 18 leaves the ground, do you leave the ground with it? 19 A. No. We had another engineer also. 20 O. So what percentage of times do you leave the 21 ground in the airplane when the plane leaves the ground? 22 A. For who? 23 O. For Mr. Wexner. 24 A. Probably one-third of the time, because I 25 was also the lead technician, so I had • ESQUIRE Toll Free: Facsimile: www.esquiresolutions.com EFTA00181390 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 described 4 in this airplane, are you able to see what's going on s behind the doors of the various partitions of the 6 airplane? 7 A, If the doors are open or dosed? a O. Closed. 9 A. No. 10 O. Do you have any idea what's taking place in 11 there? 12 A. No. 13 MR. GOLDBERGER: Form. 14 BY MR. EDWARDS: 15 O. When you're on the plane with Mr. Wexner. was 16 there a time that he had — Wet let me put it this way: 17 When anybody is a passenger on any of these private 18 planes. should there be logs of the names of the 19 passengers on the planes? 20 A. Not required, no. 21 O. Are you ever specifically instructed not to 22 record the names? 23 A. That wasn't part of my duties. That 24 wasn't an engineer's task, but - 25 O. Do you — 3 9 1 A. There is normally a passenger manifest, 2 yes. 3 Q. Who creates the manifest? 4 A. Probably dispatch. 5 Q. Dispatch? 6 A. At Limited. 7 O. Do you know who that is? 8 MR. REINHART: Can you give a time frame? 9 Do you mean currently or back when he worked 10 there? 11 MR. EDWARDS: I'm talking about back when 12 he worked there. 13 BY MR. EDWARDS: 14 O. Do you know who that was at dispatch? is A. That would have been Diane Williams. 16 O. Who does Diane Williams work tor? 17 A. Limited Flight Department. 18 O. Who does she report to? 19 A. Tim Staley. 20 O. Who's Tim Staley? 21 A. Director of Operations. 22 O. For who? 23 A. Limited Flight Department. 24 O. What does he then do with that information? 25 A. I don't know. I don't know. 38 1 A. no, not that rm aware of. 2 O. Who is assigned the duty of reporting the 3 names of the people who are going to be transported on 4 the airplanes? MR. GOLDBERGER: Form. 6 A. Captain. 7 Q. So have you ever been privy to conversations 8 where the captain is told by Mr. Wexner to record all of 9 the names of the people that are going to be on the 2o airplane? 11 A. Can't say. 12 Q. Sometimes? 13 A. I can't - You know. I can't say. I can't 14 remember what our policies were at the time. 15 O. I'm not asking policies. I'm asking: Have 16 you ever been around when the pilot was being instructed 17 by Mr. Wexner • back in the late 80s, early '90s - to 18 make sine that you record who's on this aircraft? 19 A. I never heard Mr. Wexner address that, no. 20 O. I mean, God forbid the airplane crashes, you 21 would like to know who's the on the airplane, right? 22 MR. GOLDBERGER: Form. 23 A. Yes. 24 O. Is there any way to determine who's on each 25 particular flight in case anything happens? 40 1 O. Have you ever talked to Tim Staley? 2 A. From -- Yes, yes. 3 O. And what do you talk to him about? 4 A. Oh. we're - we're friends. We worked 5 together for years. I mean, I haven't talked to him 6 since the holidays. 7 Q. DO you know where he is now? 8 A. To the best of my knowledge, still 9 Director of Operations at Limited. 10 O. Do you have a number for him? 11 A. Yes. 12 O. Can I have the number, please? 13 A. It's 14 O. Is that a work number? 15 A. That's the Flight Department. 16 Q. That's the best number to reach him at? 17 A. Yes. 18 O. If I'm going to call him, that's the number I 19 call? 20 A. Correct. 21 O. And was he always in charge of flight 22 directions? 23 A. No, he was previously Chief Pilot. 24 O. He was previously Chief Pilot for Limited? 25 A. Same, yes. ESQUIRE Toll Free: Facsimile: www.esquiresolutions.com • • • EFTA00181391 Larry Eugene Morrison - Volume I October 6, 2009 • • 41 1 O. And he was promoted, I suppose. to Flight 2 Director? 3 A. Director of Operations. It's the 4 department crew. Most small departments don't have 5 directors until they start to grow. 6 Q. And when he was Chief Pilot were you 7 affiliated with the Wexner organization? 8 A. Yes, I was a maintenance technician. 9 Q. And when you say somebody keeps flight logs. 10 is it always Tim - is his name Tim Staley? 11 A. Yes. 12 O. is it always Tim Staley who does that? 13 A. No. I don't know where they go. honestly, 14 and the system may have changed. 15 Q. Okay. Are you 16 A. I've been gone since -- 17 O. Are you aware of any FAA policies to where 18 they need to know who's on the aircraft whenever it talks 19 off? 20 A. Not under Pad 91 Operations, there is 21 not. 22 O. Part what? 23 A. Part 91. 24 O. What does Pad 91 say as far as you know? 25 A. It's basically souls on board when you 43 1 international. The only time we do international 2 would be for Customs and Immigration. 3 O. So if it's an international flight -- 4 A. For Customs and Immigration • for coming 5 and leaving the country. 6 O. - then they require that names of 7 individuals -- 8 A. It would be names, passports, that kind of 9 stuff • normal. 10 O. Did you ever do any international flights 11 while employed by The Limited, Victoria's Secret, the 12 whole Wexner group? 13 A. Yes. 14 O. How many? 15 A. No way of knowing. I mean, I'm - can't 16 say. It's, like I Say, years, but. 17 Q. What years would you done it? 18 A. Started flying as a flight mechanic in 19 '89, and then started flying the Boeing in '99, so - 20 to '01, 80'89 to '01, haSirally. 21 (Mr. Goldberger exited.) 22 BY MR. EDWARDS: 23 O. So '89 to '01. if I wanted all of the flight 24 logs, who would I request those from - Tim Staley? 25 A. Don't know. I don't know who -- 42 1 file a flight plan - that's the only thing you're 2 required to do. When you file your flight plan you 3 file souls on board. 4 O. What does that mean, "souls on board'? 5 A. In other words, living bodies on board. 6 In other words, if you have - so if there's an 7 accident and you have lour and you're transporting a e cadaver, that they go to the accident scene and don't 9 find five bodies • think there were five fatalities. 10 Q. So it's your understanding from what you need 11 to report are, 'I have five people on board.' 12 A. Correct, and that's for the flight plan. 13 O. So there's no reason to say that, 1 have Joe 14 Schmo on board.' 15 A. Not under Part 91, no. 16 O. That's doing something over and above. 17 A. That's correct. 18 O. You are aware, though, that there are certain 19 flight plans where they actually name individuals that 20 are on the airplane? 21 MR. GOLDBERGER: Form, 22 A. No. 23 O. I mean, you've seen that before. 24 MR. GOLDBERGER: Form. 25 A. No, not on flight plans, no - unless it's 44 1 O. What does Tim Staley do after he maintains 2 these records? 3 A. I don't know. 4 O. He's never told you what he does? 5 A. No. 6 Certainly they're kept on file somewhere. right? 8 A. I would assume. 9 O. What's the name of the company that owns the 10 airplanes? I know it's affiliated with Wexner and all 11 that. but what's the name of the company? 12 A. Well, there were several companies. I 13 mean, the way corporate aviation flight departments 14 are set up. they're under holdings companies. 15 O. Ill go with all of them. 16 A. Well, I don't know. They change. They 17 change sometimes by the year, sometimes -- I have no 18 idea what they're under now. 19 Q. What were they under back in '88 -- 20 A. It was like - 21 Q. -- to the best of your memory? 22 A. They change. I mean, every time we got a 23 new aircraft. or whatever, they changed. They were 24 like Northeast Holding, Southwest Holding. LLC • 25 Wilmington, Delaware, companies, which is standard • ESQUIRE Toll Free: Facsimile: EFTA00181392 Larry Eugene Morrison - Volume I October 6, 2009 45 1 for these, you know. 2 Q. Did Wexner ever tell you that he 3 allOwed Jeffrey Epstein to serve in some sort of 4 capacity, representative capacity, for any of these 5 companies? 6 A. No. He would never say that to me 7 anyways, no. 8 O. What's the first time you ever saw Jeffrey 9 Epstein? 10 A. Can't say. I'm not sure. 11 Q. I think you saw him before you started working 12 for him or with him? 13 A. Oh, yeah. that's -- Where I first saw him 14 was when I flew him on The Limited 727. 15 0. What year do you think that was? 16 A. It would have had to have been -- 17 0. Talking late '80s, early '90s? 18 A. Late '90s. 19 0. Late '90s? 20 A. Yeah, probably • mid to late190s. 21 0. Well, I mean, if you're taken over with 22 Jeffrey Epstein in. what, 2001 — 23 A. Correct. 24 0. — then you're talking late '90s is the first 25 time you see him? 47 1 A. They were -- They were generated, but I 2 don't know, you know, why - what the particular 3 reasoning was for it. 4 0. Do you know if Terry (sic) Staley would have 5 been the one to forward those flight logs to the FAA? 6 A. No. no. no. I -- They were all just for 7 business use - not forwarded to the FAA. 8 0. Okay. How - 9 A. The FM doesn't care about flight logs. to O. How did the FM monitor when that plane took 11 off? 12 A. Flight plans. 13 O. And was It your understanding that when the 14 plane took oft, the FAA was unaware as to who was ever on 15 it? 16 A. Pretty much, yeah. They don't care about 17 names. When you file flight plans with the flight 18 service station or via electronically. all they care 19 about is souls on board, contact information, flight 20 routing, things like that. 21 O. Are there time limits as to when the plane is 22 allowed to take off? 23 A. Yeah. usually From what point? What do 24 you mean? Time of the day or -- 25 0. Yeah. yeah, time of the day. I understand 1 2 3 4 5 6 7 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 24 25 46 A. Well, mid -- I don't know exactly. I can't realty say, really. 0. I won't hold you to it. It is what e is. Mid to late '90s. if I wanted the flight logs that have him on it, on the airplane, who would I subpoena to get those records? A. I have no Idea. 0. Are they turned into the FAA. to the best of your knowledge? A. No. the FAA doesn't require them. 0. So FM does not get the flight -- Well, what's the point of even keeping these? A. Sometimes I think the IRS I mean, this is on assumption, I'm not even sure, but mostly for like IRS tracking for if you have people that have dual homes, dual statehoods. or whatever. (Mr. Goldberger entered.) MR. GOLDBERGER: Can we take a time out? (Short break.) (Mr. Pike appeared via telephone to replace Mr. Goldberger.) BY MR. EDWARDS: 0. FM flight logs • do you know why theyre generated, how they're generated, if they were generated back in the Wexner days? 48 1 that there's some time where if it's too late they can't 2 take off, right? 3 A. Only where there's a curfew on the airport 4 - not all airports, no. No, airplanes can fly any 5 time unless that airport has a noise curfew or 6 something, yeah. 7 0. Did you ever know of Wexner's plane to take 8 off after ten o'clock p.m.? 9 A. Yes. Yeah. 10 0. Were you ever an that plane when it did? 11 A. Probably, yeah, yeah. 12 0. Were you ever on that plane when there were 13 girls on the plane? 14 A. Describe Define 'girls.' On the Wexner 15 airplane? 16 0. Yes. 17 A. There would be ladies and his daughters. 18 I mean -- 19 O. Other than family members. 20 A. There would be business associates. If 21 you're talking young women, yes, business associates 22 from the divisions. 23 0. Have you ever been on the plane when there 24 were girlfriends of Wexner? 25 A. Only when Abigail - before his - became 0 ESQUIRE a Altman Coll•Compaar Toll Free: Facsimile: www.esquIresolutIons.00m • • • EFTA00181393 Larry Eugene Morrison - Volume I October 6, 2009 • • 49 1 his bride, yes. 2 O. How about attar .- 3 A. I mean -- 4 O. -- she became his -- 5 A. it was Abigail. She was the only 6 girlfriend. 7 O. How about after Abigail? 8 A. No. 9 O. Have you ever seen sex or sex-related 10 instances occur on MI Wexner's airplane? 11 A. Absolutely not. We didn't even have 12 playing cards. He looked at the aircraft as a 13 business - a flying business office. 14 O. When you say 'playing cards: what do you 15 mean? 16 A. Playing, you know, to -- 17 O. Oh. playing cards. 18 A. Yes, playing cards. 19 O. So every time that you were on Wexner's 20 airplane, it was used strictly for business? 21 A. Well, I don't know if it was used strictly 22 for business, but there was no, you know, it was — I 23 don't know what the purpose of the actual trip was, 24 but never saw, you know, anything, you know. 25 O. Was there ever a time when you were --1 2 3 4 5 6 7 a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 51 O. Yes, with you on it. A. I can't I can't say. O. Well, where do you remember going in it? A. Well, we would normally go to London, Milan. Paris. I mean, mostly fashion areas and business - business areas. O. When you say 'fashion areas,' what do you mean? A. Well, retail. I mean, you know, design for clothing and stuff like that. O. What was the purpose? A. I'm sure it was business. I have no idea what the actual purpose was. I don't — O. Did you get off the plane? A. Well, of course. O. What did you do there? A. Go to a hotel, eat dinner, wait to find out when you're going to the next place. O. Were you ever on an international flight on one of Mr. Wexner's planes that Jeffrey Epstein was also on? A. I can't say. I can't remember. O. Maybe? A. Possibly. O. Do you remember any specific places that 50 1 MR. REINHART: Hold on. Were you 2 finished? 3 BY MR. EDWARDS: 4 O. I thought you were finished. 5 A. Yeah, I don't understand. I don't 6 understand that question. 7 O. I'm going to clarify. Were there ever times 8 when you were on the plane and either MI Wexner 9 and/or other individuals went behind these various areas 10 that you could not see into? 11 A. Yes. Yeah. 12 O. Do you know what they were doing in there? 13 A. Probably sleeping. He would go to bed at 14 night on the long trips, okay. 15 O. Any time that more than one person wont in one 16 of these areas that you would not be able to see into? 17 A. Not that I'm aware of, but my exposure to 18 back there is not that, you know, is limited. 19 O. How many times did you see Jeffrey Epstein 20 ride that plane with Wexner? 21 A. Not many, but I can't say exact. 22 O. How many international flights do you remember 23 that plane taking? 24 A. Remember -- The airplane itself taking 25 international? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 52 Jeffrey Epstein went while on that plane outside the United States? A. I can't remember. No, no. Like I say. I can't even remember if we took it for sure. O. Any time that you remember Jeffrey Epstein being on the airplane, do you also remember there being gins on the airplane along with Mr. Epstein? A. I can't -- I can't say. I can't remember. O. When's the first time you remember seeing Jeffrey Epstein? A. Well, like I say, I don't even remember the year. I can't even pinpoint down to the year.