Larry Eugene Morrison - Volume I October 6, 2009

Larry Eugene Morrison - Volume I October 6, 2009 IN THE CIRCUIT CURT Ot mix 15Th JUDICIAL CIRCUIT :N AND POR PALM $111101 COUMTV, acistus VOUR4R 1 92906 1 to 200 Plairkt1ff, Case Up. 50200$CA024051 ELMS AD JIVVAIT OPOIZIK, Mismiseat • DaPCSITICSI OP LARRY ~OS taitRISC44 Tiara Ott «ALF OP Ma PLUIPTIFF October 6, 1009 10;55 a.m. 2:20 p.a. 515 N. Plogler Drive West Palm Beach. PL. 13401-4321 Jennif er Ditorenref , court reporter 3 1 APPEARANCE OF COUNSEL 2 On tense of IM Defendant 3 ATTERBURY.GOLC6ERGER & WEISS BY: JACK ALAN GOLDBERGER. ESO.. 4 250 Australlen Avenue Slate 1400 s Watt Palm Bach FL 33101 6 7 On behalf of the Defendant by telephone BURMAN, CRITTOR LUTTIER & COLEMAN 9 BY: Maimi J. PIKE. ESO.. 515 N. Realer Drive 10 Stale 400 13 FL 33401 12 13 14 On behalf of the sstness: LAW OFFICE OF BRUCE E RBA/HART Is BY: BRUCE E. REINHART, ESQ., Ono Cheripla Center 16 250 S. tentralan Avenue Suite 1400 17 F < 1 10 19 20 21 22 23 24 25 2 APPFARaNCES OF COUNSEL 2 On NMI ot ihe Pa tI LAI.: BOTNSTEIN, ROSENFELDT1 ADLER DY BRACA.EYJ EDWARD& ESO 4 and L14CKAEL WHEELER En. 401 East Las an 13001evard S åM1650 Fo1 LavarOcto FL 13194 9 10 Il 12 13 14 15 16 La 16 ia 20 21 22 23 24 25 On Napa« Plal1N14 Jan Doe 2 Ilaotga 5: WRIMSTEIN HOROWITZ PA BY: JFccY•AO.ARBOL1RAl Nfri2NY4VNULW. 13205 Fkstayne ~lewd Sole 2210 On MIME ce ~Sib Jane Doe 101 aria 102 at ~O« ~mum« °RUCK P A sY: KAINERINE W. EZELL, ATTORNEY-ANUPN 25W. Fis,er Steel °et:eh:1o~ PeINXICINA. by telepaon0 LAW OFF« OF RICHARD %SLUTS. PA BY: FtCHARO %SLUTS. ESQ. 2210 101, Mega N. Stim 404 33451 1 2 3 4 5 6 4 INDEX OF EXAMINATION WITNESS: UM," EUGENE MORRISON Page DIRECT EXAMINATION By Mr. Edwards *5 CROSS-EXAMINATION 6 By Me. Ezell 9 CROSS-EXAMINATION By Mr. Willits 10 CROSS-EXAMINATION 11 By Mr. Pew *196 12 FURTHER REDIRECT EXAMINATION By Mr. Edwards #199 13 14 6190 1195 L 16 INDEX TO EXHIBITS Plaintiff's 1a Exhibit Description Page 19 1 Twenty-four pages of 'JEGE, Inc., Passenger Manifest." #138 20 21 22 23 24 (Plaintiffs Composite 1 was attached to the original transcript and copies of the transcript.) 25 EFTA01110271 Larry Eugene Morrison - Volume I October 6, 2009 5 1 Deposition of LARRY EUGENE MORRISON 2 October 6.2009 3 4 THE REPORTER: Do you swear the testimony S you're about to give will be the truth, the 6 whole truth, and nothing but the truth so help 7 you God? 8 THE WITNESS: So help me God. 9 -- 10 LARRY EUGENE MORRISON, having been first 11 duly swam, was examined and testified as 12 follows: 13 DIRECT EXAMINATION 14 BY MR. EDWARDS: is O. Tell us your name. 16 A. Larry Morrison. 17 Q. And. Larry, where are you employed right now? 18 A. For JEGE. 19 Q. What's JEGE mean? 20 A. It's the aviation flight department for 21 Mr. Epstein, and my primary Job Is Danklold Reed 22 Aviation. 23 MR. REINHART: Spell It. 24 A. D-A-N-K-J-O-L-D, and then the second word 25 le Reed, R-E-E-D, Aviation. Ws a corporate flight 7 1 You know, it was a business decision made somewhere. 2 O. What does the company do? 3 A. What? The company? It's Just a holding 4 company, I fink, for the aircraft. Its not -- I 5 don't bSeve It to be a money making company or a 6 real corporation. 7 O. You're song `for the aircraft? rm a Interpreting that to mean you're talking about on, 9 aircraft. 10 A. Correct. 11 Q. Does that mean there's one or there's more 12 than one? 13 A. There's more. He owns more than one, but 14 Just one is JEGE or -- 15 O. And the aircraft that he owns, how many of 16 those do you either service and/or ride on? 17 A. I used to. I haven't been — Actually. I 18 stepped back from being physically Involved, Just - 19 now I Just do paperwodt - and It was February of 20 2007. SO I haven't actually physically been on the 21 airplanes other than I will take the Boeing for 22 maintenance. 23 Q. Since it seems tike we've kind of skipped 24 ahead from 2001 to 2007, am I right that your first 2s involvement with Jeffrey Epstein of any way, shape, a 6 1 department. 2 Q. What do you do for him? 2 A. Director of Maintenance. 4 O. Okay, so you maintain his planes — 5 A. Correct. 6 Q. — should something go wrong? 7 A. Correct. Yes. Yep. O. Do you also -- 9 A. For maintenance. 10 O. Do you also fly on his planes? 11 A. On 1W. Epstein's? 12 O. Yes. 13 A. I used to. I was a flight engineer 14 O. Okay. What — 15 A — on his 727. 16 Q. When you fist your company - JEGE? 17 A. Yes. Yeah. it's just initials. It's an 18 LLC or holding company. 19 O. How long has that holding company been around, 20 If you know? 21 A. Since I think it was developed when I 22 came with the airplane - 2001. 23 O. Whose Idea was it for that to come about-was 24 it yours? Was It he? 25 A. Oh, no, no, somewhere - It wasn't mine. 8 1 form was 2001? 2 A. That's correct, yeah. 3 Q. You didn't meet him before that. 4 A. I had met him He was a — He was an 5 associate of my previous bees. 6 O. Who's that? 7 A Mr. Wexner. O. Leslie Wexner? 9 A. Yes. 10 Q. How do you know Leslie Wexner? 11 A. I worked for Limited Stores for 12 years. 12 O. Doing what? 13 A. Essentially the sane thing - aircraft 14 maintenance for their corporate flight department and 15 flight engineering on the 727. 16 O. How many aircraft did Leslie Wexner have? 17 A. Weil, none that I know that he had 18 personally, but the corporation had - the fight 19 department operated - we had three Gulfstreams, two 20 Hawkers, and a 727. Q. What was the name of his corporation that 22 maintained the aircraft? 23 A. For Limited Stores? 24 Q. Yes. 25 A. It was just — It was called Limited - EFTA01110272 Larry Eugene Morrison - Volume I October 6, 2009 9 1 Limited Flight Department. 2 Q. And do you know him personally then Leslie 3 Wexner? 4 A. Yeah, I had met him, of course, you know. 5 I met him. I used to do aircraft completions for 6 him, so which would involve personal meetings. 7 O. When did you first meet Leslie Wexner? a A. 1988 was when I hired on, so I don't 9 remember the month. 10 Q. How did you get that job? 11 A. Through word of mouth and, you know, I 12 worked - I lived in - been in aviation for years in 13 Columbus. 14 Q. Wee I mean, Leslie Wexners an important 15 person. right? I mean. he — 16 A. Correct 17 MR. GOLDBERGER: Form. 18 BY MR. EDWARDS: 19 Q. He's somebody who owns my understanding - 20 Limited, Victoria's Secret? 21 A. Well, he doesn't own them. He's Chairman. 22 you know. 23 Q. Chairman of — 24 A. Yeah. He doesn't personally own .1. It's 25 a publicly held company. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 11 Q. Yes. A. Aircraft technician. Q. Which entails what? A. Maintenance of any or all of the aircraft operated by the flight department and some flight mechanic duties. Q. What kind of airplanes? A. Gulfstreams, Hawkers. Q. How big is the Gulfstream? A. Fifteen passenger -15 to 17. (Mr. Goldberger (tilted.) BY MR. EDWARDS: Q. What did Wexner use the Gulfstream for? A. They were division airplanes, mostly. Q And the other airplane you named - what did he use that for? A. Same. same. Q. Any idea why he had two planes? A. Well, I mean, yeah, we used them - Mafia a loot h wasn't him. It was a large Fortune 500 company. They use them as tools to — You know, Lhnited has control over 60 percent of their manufacturing processes, plus, you know, what.1200 stores, or whatever, throughout all their divisions. I mean, when you say 'limited' ire not 10 1 Q. Where were you prior to any involvement with 2 Leslie Wexner? 3 A. I worked for Red Roof Inn True Sports 4 Flight Department. 5 Q. How did that position lead you to Leslie 6 Wexner? 7 A. Well, it was always known that Limited 8 Right Department was one of the best jobs in 9 Columbus and, actually, several other people that 10 were already there knew me from previous jobs and 11 education - we went through aircraft mechanic, or AS 12 school. together - so when the position became 13 available they pointed to me and - absolutely. It 14 was a fine organization. 15 Q. So did I.Y. Wexner approach you or did you 16 apply to him or how did that work? 17 A. Oh, no, no, no. It's -- No. He wouldn't 18 be involved in that type of activity. You apply to 19 H.R. and you interview with the Director of 20 Operations or the Chief Pilot. You know, he 21 wouldn't. 22 0. So you start with Wexner in 1988. 23 A. Yes. 24 O. What do you do for Nm then? 25 A What did l do for Nm? 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 12 just Limited, ifs Victoria's Secret and it was Express and Lemers and Henri Benders and all of that back then, so. I mean — Q. So — A. — we moved a lot of passengers to keep those stores for the retail business. Q. And by 'passengers." do you also mean clients of his? A. That I don't know. No. Mostly we just dealt with upper echelon, you know, people in the retail businesses from — Q. Such as whom? (Mr. Goldberger entered.) A. Can't even remember names, but it would be -- We would take buyers to Europe in the spring and fall. They would buy samples and piing them back to analyze for marketing. We would hire — We would — Division heads, when they would do store shops and, Real Estate, we take Real Estate out when they were looking for new real estate. Q. While you were working back in '88 — Well, how long overall did you work with Leslie Wexner and/or his companies? • Wen.738 through when I came here in January of '01. EFTA01110273 Larry Eugene Morrison - Volume October 6, 2009 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-pth3t airplane - and It gave me the 6 opportunity to become a Director of Maintenance. and 7 it was a chaflenge. You know, bringing - upstarting 8 an airliner on a private ticket or a VIP ticket is 9 really challenging. and I enjoy the challenge of 10 waking and developing the program and stuff. 11 O. Well my understanding. Leslie Wexner is 12 generally - he's in Ohio, right? 13 A. No, he's got other places. I mean — No, 14 he's like anyone, he's - in his category • he's got 15 multiple homes and — 16 Q. Wee, when you would maintain his aircraft, 17 would that be in Ohio — 18 A. Yes. We were based- 19 Q. or elsewhere? 20 A. We were based at Lane Aviation. 21 MR. REINHART: Hold on one second. You 23 have to let him finish asking the question 23 before you answer. 24 THE WITNESS: Okay. rm sorry. as BY MR. EDWARDS: 15 1 aircraft. I mean, whatever It takes to keep a 2 corporate flight department operating. 3 Q. Did you know back then of his relationship, if 4 any, with Jeffrey Epstein? 5 A. Not Immediately, no. 6 Q. When is the first time that you knew of a 7 regulation or a relationship between Wexner and Epstear A. Would have had to probably be around maybe 9 '98.199. 10 Q. How do you become aware that they know one 11 another? 12 A. Because Jeffrey. every one — That's when 13 I became a flight engineer on the Boeing, and every 14 once Ina while Jeffrey would ride on the Boeing. 15 that's al that's al l knew. 16 Q. How did it come about that he would ride on 17 Wexner's Boeing? 18 A. They were business associates. I think. 19 Q. As far as you know, they were business 20 associates. 21 A. Right. 22 Q. DM you understand the business relationship 23 between the two? 24 A. Well, I believe it's pubic knowledge 25 that, I think, Jeffrey managed Mr. - some of Mr 14 Q. I'm sorry, have you ever had your deposition 2 taken before? 3 A. No. 4 Q. You definitely never had your deposition taken 5 before while somebody else is trying to eat at the same C time they're trying to ask the questions - that's very 7 bizarre. A. Yes, yes. 9 O. I meant to do this before I got here. But, 10 regardless, II wait until you finish your answer before 11 I ask my next question: you do the same thing. 'U .-huh' 12 or -uh•eh," they kind of look the same on the record. so 13 try to give us a "yes" or *no- or something we 14 understand. 15 A. Alright. 16 Q. If I ask a question that was a bad question or 17 something you don't understand - I've asked bad questions 18 before - say., don't get it." 171 ask a better 19 question. 20 A. Okay. 21 Q. You were working with Lee Wexner. You got 22 the job there starting in 1988. On a day-to-day basis, 23 what would you be doing? 24 A. Maintenance, aircraft maintenance, 25 tracking of aircraft maintenance, cleaning of 16 1 Wexner's funds. 2 Q. Is that something that Mr. Wexner told you? 3 A. No. 4 Q. Is that something that somebody of Mr. 5 Wexner's organization would have told you? 6 A. No. 7 a Is that something that Jeffrey Epstein told 8 you? 9 A. No. 10 Q. Is that just reading articles that speculate 11 as to the business relationship between the two or do you 12 got something more for me? 13 A. No, it's Just - It's speculation and, you 14 know, what I've read, you know. 15 Q. I mean, like you say, to me Ifs common 16 knowledge — 17 A. Right. 18 Q. But it's only because of vital I've read. I 19 don't have a specific person that I could cite to to say 20 that, do you? 21 A. Right. No, Just- just periodicals. 22 O. What's your understanding of the personal 23 relationship, if any. between Wexner and Epstein? 24 MR. GOLDBERGER: Form. as A. Don't know. EFTA01110274 Larry Eugene Morrison - Volume I October 6, 2009 17 Q. Did you ever know of a time — And I maybe 2 asking a question that would just be completely outside 3 of your knowledge. so let me back up. 4 Have you ever stayed at Leslie Wexners house? 5 A. No. 6 Q. Do you know where his house is? 7 A. Yes. 0. Do you know what the address is in Ohio? 9 A. No, I just know the city. 10 Q. Do you know who he lives with? 11 A. Yes. 12 Q. Who is that? 13 A. His wife and children. 14 Q. What's his wife's name? 15 A. Abigail. 16 Q. Abigail Wexner, and he has three or tour 17 daughters, right? 18 A. No. He's got a son, Harry, and two 19 daughters, I think. 20 Q. A son and two daughters. 21 A. I don't know. See, that was back in 2001. 22 I don't know what they have - II they have more kids 23 24 0. Okay. Did you ever hew any information that 25 he was homosexual? 19 1 0. Have you spoken personally with sic. Wexner? 2 A. On business issues, yes. 3 Q. Business issues related to your work on his 4 airplanes? A. Correct. 6 O. Have you spoken to him on any ether issues 7 that don't involve business relationships with his airplanes? 9 A. No. 10 0. Because you're hired basically for that 11 purpose. so that's kind of how you deal wqh him. 12 A Yeah. Ws rm an employee and he's my 13 employer and I only deal with rim, you know, on 14 Issues that Involve maintenance. 15 0. I think I probably know the answer to the nod 16 question. but just in case I dont, do you know any of 17 his personal friends people that he would hang out with 18 on a social level - being Mr. Wexner? 19 A. Through my business ties, yes, yes. 70 O. Who's that? 21 A. rm trying to remember — You have to 72 remember it's been several years. 23 0. right. 24 A. He was Mends with the Tuckermans. 25 a What's Mr. Tuckerman or Ms. *Nachman's naives? 18 1 A. No. 2 0. Being Mr. Wexner. 3 A. No. 4 Q. Any indication to you that he may be s homosexual or bisexual? 6 A. Absolutely not 7 Q. Have you heard any information that he and Mr. 8 Epstein were Involved sexually with one another? 9 A. Oh, no, no. 10 0. Would that surprise you? 11 A. Absolutely. 12 0. And that's only because you know him and you 13 know Mr. Wexner and you don't see the two together. 14 A. Correct. is MR. GOLDBERGER: Finn. 16 A. Wel — 17 0. He— le A. Go ahead. 19 MR. REINHART: If you need to answer. 20 answer the question. 21 A. Yeah. No. I saw him with Sharon, which 22 was his previous girlMend before he met Abigail. 23 0. Right. 24 A. No. There was never any hint or anything 25 that I would even conceive that. 20 A. Ms. — I cant I akvays addressed them 2 by their proper name. 3 0. Cope know what they do? 4 A. They owned an optical company - opticians. 5 They were high school friends from Mr. Wexreesh oh 6 school days. 7 0. In Ohio or New York? a A. He went to high school in Bexley. 9 O. Bexley. Ohio. 10 Has he ever discussed with you how 11 longstanding the relationship Is between himself and Mr. 12 Epstein? 13 MR. GOLDBERGER: Form. 14 A. I don't understand. Can you reptvase it? 15 Q. Wel. you know that at some point In time - 16 You started working with him in 1988. The first time, 17 according to my notes. that you became aware that he was 18 Mends or acquaintances with Mr. Epstein was '98 - 19 almost ten years later. 20 A. Right. 21 Q. After you became aware that there was that 22 relationship, whether business or otherwise, did he ever 23 speak to you about how long he had know, Mr. Epstein? 24 A. Oh, no. no. 25 Q. So as far as you were concerned, 1998. when EFTA01110275 Larry Eugene Morrison - Volume I October 6, 2009 21. 1 you found out there was a relationship with Epstein, it 2 could have very well started then. 3 A. Yes. 4 Q. Aside from aircraft technician and taking care of Pitt Wexner's aircraft back in the '80s and, I guess, 6 early '90s. did you have any other personal involvement 7 wilt) him? 8 A. Just on aircraft completions. 9 Q. And when you would speak with him, would that 10 be over the telephone, at the airport, at his private -- 11 A. It would usually be at the corporate 12 office. 13 Q. At the corporate office? 14 A. At the corporate office. 15 Q. Can you tell me the address for his corporate 16 office? 17 A. No, I cant 18 Q. If I requested that from your attorney. would 19 you be able to get that information? 20 A. Weal mean, I imagine it's public 21 knowledge - wherever - it's at the Limited. 22 Q. And Mars where you would meet him - at the 23 United? 24 A. Yeah. 25 Q. And how Often was - you know, I know that 23 1 O. Who were some of the pilots? 2 A Tim Staley, Jim Taylor. They've had some 3 turnover too. I don't know who all is still there 4 because retail is down. 5 O. Was Larry Visosid a pilot used by Leslie 6 Warner at any time? 7 A. No. a Q. How about David Rodgers? 9 A. No. 10 Q. Are those names you're familiar with? 11 A. Yes. 12 O. Those are names you're familiar with how? 13 A. I flew with them when 1 was flying for Mr. 14 Epstein. 15 Q. So there's no real, other than yourself -- 16 Well, tell me if I'm wrong: I understand that you did 17 some work for Mr. Weiner related to his aircraft and you 18 did some work for Mr. Epstein, which we haven't yet got 19 to, but you did some work for him too. Are there any 20 other people that have that type of relationship with 21 both parties? 22 A. No. I'm sorry, resay that. 23 Q. Okay. You've already told us that you were 24 the aircraft technician for Mr. Werner. 25 A. One of them. One of several, yes. 22 1 we're talking about 15, 20 years ago • how often was Mr. 2 Wexner personally at that location at the Limited 3 offices? 4 A. I have no idea. 5 Q. But any time you needed to talk to him, that's 6 where he would be? 7 A. Yeah, and I usually went to Charlie 8 Hinson. 9 Q. Who's Charlie Hinson? 10 A. He was the president of the stores. He 11 basically was my go-between for these aircraft 12 completions for the design. 13 O. And you mentioned the Gulfstream as an 14 aircraft Did you also serve as a technician for other 15 aircrafts that were owned by Mr. Wexner? 16 A. Right but not Mr. Wexner. They're owned 17 or operated by Limited Stores. 18 Q. Limited Stores? 19 A. Right. Yes. 20 Q. What did you do for them? 21 A. Same - maintenance. 22 Q. Did you ever fly in them? 23 A. On the Gulfstreams in the early days we 24 used flight mechanics, especially on international 25 flights. 24 1 Q. One of them. Then you also have knowledge 2 about Mr. Epstein and some relationship with Mr. Epstein 3 A. Correct. 4 O. Are there any other pilots. aircraft 5 technicians, people like that that you know of to have a 6 relationship with both Mr. Wexner and Epstein? 7 A. No, no. 8 Q. Do you know how Mr. Weimer met Mr. Epstein, 9 A. No. 10 Q. How long - if you started in 1988 - how long 11 did you stay with Mr. Wexner and/or The Limited? 12 A. January of '01. 13 Q. Why did you stop? 14 A. Because what we were taking before, you 15 know, I wanted to continue flying. They bought a 16 BBJ, which is a two-pilot aircraft, and I wanted to 17 continue flying. Mr. Epstein bought the 727 and 18 offered me a position to continue flying and, you 19 know, basically set up the airplane for his flight 20 department because they hadn't had any previous large 21 aircraft experience. 22 Q. I missed something. It wasn't your fault, it 23 was ITWOO. 24 The Gulfstream that you were taking about, 25 did you used to fly that as well as being a light EFTA01110276 Larry Eugene Morrison - Volume October 6, 2009 25 1 technician? 2 A. No, no. 3 Q. Okay. 4 A. You don't have to have a flight - a 5 pilots certificate to be a professional flight 6 ()Vow. I've got a turbo - a flight engineer turbo 7 jet rating, but you don't have to have a commercial ticket as long as you - the FAA recognizes your heavy 9 aircraft maintenance experience. 10 Q. So you're saying that if the FM recognizes 11 your heavy maintenance experience, I'm assuming that 12 means that you understand the ins and outs of airplanes 13 and you can work on them. 14 A. On heavy high performance aircraft, yes. 15 0. Then you can also fly them? 16 A. Sideways as a flight engineer. 17 Q. Explain. 18 A. On the older generation airliners there 19 was three pilots - there's a captain, a first 20 officer, and then the flight engineer is the 21 gentleman that sits sideways and maintains all the 22 systems. 23 Q. When you say. 'sits sideways? okay, I have 24 a — 25 A. Literally, you're physically sideways in 27 1 Q. Do you know why Epstein chose to buy that 2 particular 727 rather than one of the other mum 727s 3 that are made? 4 MR. GOLDBERGER: Form. 5 A. Because It was probably the finest one out 6 there -- 7 Q. Why? A. -- in as honesty. Its got a fully Paged 9 SIC interior with EFTS cockpit, and Limited's 10 reputation on the way that we maintained our aircraft 11 - It's the best one out there. 12 Q. Describe for me the interior - not talking 13 about the Epstein days, we're talking about the Wexner 14 days - describe for me the interior of the aircraft, and 15 keep in mind that I've only been on a commercial aircraft 16 where you don't see the pilots, there's a door, and then 17 everybody, you know, there's just a bunch of seats where 18 everybody sits there. 19 A. Correct. Right. 20 The aircraft — You enter the airplane, 21 It's got forward air stays, which most 727's don't, 21 so you enter the forward door on the left-hand side, 23 the forward entnAvay vestibule, and there's a door on 24 the left, which leads to the cockpit, and then 25 there's a door on the right which leads aft to the 26 1 the cockpit 2 0. So you're not Looking at the people that were 3 flying on the plane and you're not looking at the pilots, 4 you're actually literally sitting sideways. 5 A. I sit sideways at a panel, yes. 6 Q. What's your job? 7 A. Maintain all the aircraft systems - the 8 hydraulics, fuel management, pressurization, 9 environmental controls. 10 Q. That's not done by the pflotS. 11 A. No, no. 12 0. But if you've done that long enough and FAA is 13 aware d your credentials in that respect, then you also 14 could be credentialed to be a pilot as well? 15 A. Well. sure, yeah, yeah. if that's a 16 career choice you wish to take. 17 Q. And was that? 18 A. No, no. I was perfectly satisfied with my 19 position as a flight engineer and Director of 20 Maintenance. 21 0. What year did you say Epstein bought the 727 22 that was once owned by Wexner? 23 A. I don't know when the actual transition 24 took place, but when I came - shortly around the 25 period that I Caine on board in '01, January of '01. 28 1 forward salon. 2 Q. What's the forward salon? Sorry. 3 A Forward seating area. 4 O. And is it set up basically the way that I'm 5 picking ft - in that there are 25 or 26 rows and theyre 6 numbered A through E? 7 A. No, no, it's a corporate configuration. a Q. Which means nothing to me, so help me. 9 A. Picture a 600-mile an hour Winnebago. I 10 mean, it's got conference tables and divans and large 11 first class seating. 12 Q. Any various dividers throughout — 13 A. Yes. 14 Q. — to where there's a VIP room in the back or 15 anything like that? 16 A. ft's compartmentized (sic), yes. 17 Q. In what way? Describe it as specifically as 18 you can. 19 A. There's a forward salon, a mid galley - 20 the galays in the mld - an aft - an aft salon, 21 which is - and then the aft state room. 22 Q. Who designed that plane? 23 A. I can't remember who the actual designer 24 was. it was a Page interior, though. Page Avjet did 25 the installation. EFTA01110277 Larry Eugene Morrison - Volume : October 6, 2009 29 1 Q. Who directed the design of that plane? 2 A. It would have been Mr. Wexner. I mean, It 3 was — The layout has not changed. 4 O. 'The layout has not changed' when you say 5 that, you mean 'from the time that I first got in it and 6 I was under the guise or - "under the employment of 7 Wexner to the time I've been on it since with Epstein, the oon5guratlon is the same." 9 A. Essentially. yes. We removed one chair 10 and one small table that was an annoyance and that's 11 It. but Its identical to what The Limited used. 12 Q. Are there any blocked off areas to where if 13 you're standing in the middle of the plane you can't see 14 certain areas of the plane? 15 A. There are pocket bulkheads. Yeah, there's 16 dividers between the seat:Ina. 17 Q. How big are these cflviders and where aro they? 18 A. Well, there's a divider - the forward 19 door, I told you, on the salon, then there's a pocket 20 door on the forward side of the galley. a pocket door 21 on the aft side of the galley, there's a pocket door 22 between the aft salon and the office, and then 23 there's another pocket door between the office and 24 the state room. 25 O. Have you been on other 727s before that are 31 1 because obviously there's a lot - there's not that 2 3 A Privately owned 727s, but this is — As a 4 matter of fact. The Limited's current BBJ has a very 5 similar floor plan. 6 O. As Trump's? 7 A. No, as the-as ow 727. Q. Who's "our? 9 A. Mr. Epstein's. They didn't change a lot. 10 It's — 11 O. Well, I thought that you had told me that the 12 727 that was once owned by Wexner is the 727 that's armed 13 by Epstein. 14 A. It is, but what I'm saying Is even their 15 current airplane has the same layout - the BBJ. They 16 put the same floor plane in the more modern airplane 17 O. Well, they Mat have to put n there. It 18 was already there, right? 19 A No, no, no. When you buy these aircraft - 20 oven a Gulfstream Mien you buy them it's just a 21 green hull, there's nothing in them, and you can 22 customize your Interior. 23 O. rm soy, we're miscommunicallrg somewhere. 24 and I'm sure its on me. 25 MR. GOLDBERGER: Yes, It is. 30 1 commercial airliners privately owned? 2 A. Yes. yes. 3 Q. Have you noticed similar configurations to 4 where there are this many divicfrig doors or is this one S that has more so than you've seen In the past? 6 A. No, no, this Is pretty atypical (sic). 7 Q. It's pretty atypical? $ A. It's typical. 9 O. It's pretty typical? 10 A. Yes, yes. 11 Q. So what other airplanes - 727s, or other Maier 12 airplanes - have you been on that have these types of 13 dividers? 14 A. Trump. 15 Q. Trump's airplane? 16 A. Yes. 17 O. Why were you on Trump's airplane? 18 A. Weil, I know the crew and, you know, this 19 is a small-knit community. There's not very many of 20 them out there, so everybody in this world knows one 21 another to help one another out as far as — 22 Q. By "there" — 23 A. — b its motiun-wise and stuff. 24 Q By 'there aren't that many of these people out 25 there; you don't mean there's not that many people - 3 2 1 MR. EDWARDS: And I'm taking the dame for 2 it - right away. 3 MR. REINHART: Take that. Ed. 4 MR. EDWARDS: Alright. 5 BY MR. EDWARDS: 6 O. My understanding - and piano correct me when 7 Mt wrong, because I know I am - Wexner has this 727 and 8 he designs it in a certain way. 9 A. Uh-huh. 10 Q. And then you come to work for Epstein — 11 A. Yes. 12 Q. — vitro buys the same 727. Your testimony. as 13 I'm understanding it, is: It's basicaly the same floor 14 plan as Wexners Poor plan. To me, it should be the 15 exact same because he bought the same plane. 16 A. No, he — You're misunderstanding. 17 O. I figured. is A. VVhat I was stating is — You were — Ines 19 answering the question in regards to. "Is this 30 unusual to have this many compartments and closed 21 doors and bulkheads and things?' 22 What I was trying to state was: No, ins 23 not unusual - because The Limited even Sited Ihe 24 floor plan solemn in their old airplane that they 25 sold to Mr. Epstein. They duplicated it in their new EFTA01110278 Larry Eugene Morrison - Volume I October 6, 2009 33 I airplane - see what I'm saying? That's all l was — 2 Q. So they didn't keep the floor plan. They 3 actually took it out and they restructured the floor plan 4 to basically match that old floor plan. 5 A. Well, no. When you -- When you buy a 6 Boeing business jet -- 7 Q. Yes. A. — It comes with nothing inside. It's a 9 tube. Nothing's in there. You design - have 10 designers design your interior and then a fabricator 11 or a facility such as Page Avjet to instal this 12 interior. 13 Q. Right 14 A. What I was Just trying to state was that 15 The Limited liked their old floor plan in the old 16 airplane so well - it worked so well for them - that 17 they duplicated it and had that same interior 113 installed in the new aircraft - same floor plan 19 installed on the new plan. 20 Q. So Epstein didn't buy the exact same plane. 21 He bought the same type of plane. 22 A. Well, more modern. He bought a 737, 23 right. 24 Q. Got it. 25 A. Right 35 1 had a very identical or very like floor plan 2 installed in the new airplane. 3 O. Got it. 4 A. Okay? Sony, ifs a strange business. It's — a O. Tell me if I'm right: Mr. Wexner had a plane 7 that had a floor plan that apparently appealed to Mr. 8 Epstein. so Mr. Epstein bought that plane. 9 A. Correct. 10 Q. Mr. Wexner also liked that plane that he had 11 Just sold to Mr. Epstein, so he built in a floor plan 12 very similar to the one he just sold to Mr. Epstein. 13 A. In his new aircraft. 14 O. Brand new plane. 15 A. Correct. 16 O. Got h. We're on the same page now. 17 A. Alright 18 O. Took us a while to get there. 19 A. Yeah, sorry. 20 Q. I think it was my fault, honestly, but 21 alright? 22 A. It's en unusual process if you haven't 23 been around corporate airplanes. 24 Q. I didn't realize that Mr. Wexner had a new 25 plane. 34 1 MR. REINHART: Hold on. 2 BY MR. EDWARDS: 3 Q. Totally understand now. 4 MR. REINHART: Can you clarify - Mr. 5 Epstein or Mr. Weiner? 6 BY MR. EDWARDS: 7 O. Mr. Epstein bought not Mr. Wexner's plane. B A. No. 9 O. He bought the same type of plane that Mr. 10 Wexner had and modeled the floor plan — 11 A. No. 12 O. -- the same way that Mr. Wexner had it, 13 A. That is not correct. 3.4 Q. He bought, actually, Mr. Epstein— is MR. REINHART: Hold on. Distinguish -- 16 Use names so we're very dear when you're 17 talking about Mr. Epstein and NV. Wexner. okay? IS A. Mr. Epstein bought Mr. Wexner's 727. 19 Q. Okay. 20 A. The actual airplane - bought It from him. 23. Q. Which has a floor plan already in it. 22 A. That we just discussed. 23 Q. Might. The floor plan's in the plane. 24 A Right. Mr. Wexner replaced the airplane 25 that Mr. Epstein bought with a new airplane and he 36 1 A. Yes. 2 Q. That's where I had a problem. 3 How many times have you been on Mr. Wexner's 4 opine 5 A. The new? 6 MR. REINHART: Clarify which one you're 7 talking about. 8 BY MR. EDWARDS: 9 Q. Before you ever met Mr. Epstein. 10 A. I can't say. I mean, over the years? 11 Q. Numerous times? 12 A. Oh, I was his tight engineer. You mean 13 when I was still employed by him? 14 Q. Yes. 15 A. Yes. I was the flight engineer. I 16 don't -- 17 O. So as a flight engineer, every tine the plane 18 leaves the ground, do you leave the ground with it? 19 A. No. We had another engineer also. 20 O. So what percentage of times do you leave the 21 ground in the airplane when the plane leaves the ground? 22 A. For who? 23 O. For Mr. Wexner. 24 A. Probably one-third of the time, because I 25 was also the lead tee,hniclan, so I had EFTA01110279 Larry Eugene Morrison - Volume I October 6, 2009 37 1 responsibilities in the hangar, whereas the other 2 engineer was a full time engineer. a Q. And given the partitions that you've described 4 in this airplane, are you able to see what's going on 5 behind the doors of the various partitions of the 6 airplane? 7 A. If the doors are open or dosed? Q. Closed. 9 A. No. to Q. Do you have any idea what's taking place in 11 there? 12 A. No. 13 MR. GOLDBERGER: Forrn. 14 BY MR. EDWARDS: 15 0. When you're on the plane with Mr. Wexner, was 16 there a time that he had — Well, let me put it this way: 17 When anybody is a passenger on any of these private 1 e planes, should there be logs of the names of the 19 passengers on the planes? 20 A. Not required, no. 21 Q. Are you ever specifically Instructed not to 22 record the names? 23 A, That wasn't part of my duries. That 24 wasn't an engineers task, but -- 25 Q. Do you — 1 2 3 4 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 39 A. There is normally a passenger manifest yet Q. Who creates the manifest? A. Probably dispatch. Q. Dispatch? A. At Limited. Q. DO you know who that Is? MR. REINHART: Can you give a time frame? Do you mean currently or back when he worked there? MR. EDWARDS: I'm talking about back when he worked there. BY MR. EDWARDS: 0. A. Q. A. Q. A. Q. A. 0. A. Q. A. Do you know who that was at dispatch? That would have been Diane Williams. Who does Diane Williams work for? Limited Flight Department. Who does she report to? Tim Staley. Who's Tim Staley? Director of Operations. For who? Limited Fight Department. What does he then do with that information? I don't know. I don't know. 38 1 A. — no. not that I'm aware of. 2 Q. Who is assigned the duty of reporting the 3 names of the people Mx, are going to be transported CO 4 the airpianes? MR. GOLDBERGER: Form. A. Captain. 7 Q. So have you ever been privy to conversations where the captain is told by Mr. Wexner to record all of 9 the names of the people that are going to be on the 10 airplane? 11 A. Can't say. 12 Q. Sometimes? 13 A. I cant — You know, I cant say. I cant 14 remember what our policies were at the time. 15 0. I'm not asking policies. I'm asking: Have 16 you ever been around when the plot was being instructed 17 by Mr. Wexner - back in the late '80s, early 50s - to 14 make sure that you record who's on this aircraft? 19 A. I never heard Mr. Wexner address that, no. 20 Q. I mean. God forbid the airplane crashes, you 21 would We to know who's the on the airplane, right? 22 MR. GOLDBERGER: Form. 23 A. Yes. 24 Q. Is there any way to determine who's on each 25 particular flight In case anytNng happens? 40 1 Q. Have you ever talked to Tim Staley? 2 A. From — Yes, yes. 3 Q. And what do you talk to him about? 4 A. Oh, we're - we're friends. We worked 5 together for years. I mean, I haven't talked to him 6 since the holidays. 7 Q. Do you know where he is now? 8 A. To the best of my knowledge, still 9 Director of Operations at Limited. 10 Q. Do you have a number for him? 11 A. Yes. 12 Q. Can I have the number, please? 13 A. 14 Q. Is ..la—sicrumber? 15 A. That's the Flight Department. 16 Q. That's the best number to reach him at? 17 A. Yes. 18 Q. If I'm going to can him, that's the number I 19 call? 20 A. Correct. 21 Q. And was he always in charge of flight 22 directions? 23 A. No. ho was previously Chief Pilot. 24 Q. He was previously Chief Pilot for Limited? 25 A. Same, yes. EFTA01110280 Larry Eugene Morrison - Volume I October 6, 2009 41 1 Q. And he was promoted. I suppose, to Flight 2 Director? 3 A. Director of Operations. Ifs the 4 department crew. Most small departments don't have directors until they start to grow. 6 Q. And when he was Chief Piot were you 7 affiliated with the Wexner organization? B A. Yes, I was a maintenance technician. 9 O. And when you say somebody keeps flight logs. 10 is it aNrays Ten— is his name Tim Staley? 11 A, Yes. 12 Q. - is it always Tim Staley who does that? 13 A. No. I don't know where they go. honestly, 14 and the system may have clanged. 15 O. Okay. Are you — 16 A. I've been gone since — 17 Q. Are you aware of any FM policies to where 18 they need to know who's on the aircraft whenever it talks 19 off? 20 A. Not under Part 97 0porations, there is 21 not 22 Q. Part what? 23 A. Part 91. 24 Q. What does Pan 91 say, as far as you know,/ 25 A. It's basically souls on board when you 43 I international. The only time we do international 2 would be for Customs and Immigration. 3 O. So if it's an International flight -- 4 A. For Customs and Immigration - for coining 5 and leaving the country. 6 Q. — then they require that names of 7 individualS — a A. It would be names, passports, that kind of 9 stuff - normal. 10 Q. Did you ever do any international flights 11 white employed by The Limited, Victoria's Secret, the 12 whole Wexner group? 13 A. Yes. 14 Q. How many? 15 A No way of knowing. I mean, fm can't 16 say. It's, like I say, years, but. 17 Q. What years would you done it? 18 A. Started Eying as a flight mechanic in 19 '89, and then started flying the Boeing In '99, so - 20 to '01, so '89 tool, basically. 21 (hat Goldberger exited.) 22 BY MR. EDWARDS: 23 Q. S0'89 to '01, if I wanted all of the flight 24 logs, who would I request those from - Tim Staley? 25 A. Dent know. I don't know who — 42 1 Ilea flight plan - that's the only thing you're 2 required to do. When you fie your• flight plan you 3 file souks on board. 4 Q. What does that mean, "souls on board? 5 A. In other words, living bodies on board. 6 In other words, If you have - so it there's an 7 accident and you have four and you're transporting a 8 cadaver, that they go to the accident scene and don't 9 find five bodies - think there were five falsities. 10 Q. So it's your understanding from what you need 11 by report are, "I have five people on board? 12 A Correct, and that's for the flight plan. 13 Q. So there's no reason to say that, have Joe 14 Scfimo on board." 15 A. Not under Part 91, no. 16 Q. That's doing something over and above. 17 A. That's correct. 18 Q. You are aware. though, that there are certain 19 fright plans where they actually name individuals that 20 are on the airplane? 21 MR. GOLDBERGER Form. 22 A. No. 23 Q. I mean, syttve seen that before. 24 MR. GOLDBERGER: En 25 A. No, not on flight plans, no - unless it's 44 1 Q. What does Tim Staley do after he maintains 2 these records? 3 A. I don't know. 4 O. He's never told you what he does? 5 A. No. 6 Q. Certainly they're kept on file somewhere. 7 1700 a A. I would assume. 9 O. What's the name of the company that owns the 10 airplanes? I know it's affiliated with Wexner and all 11 that, but what's the name of the company? 12 A. Wet there were several companies. I 13 mean, the way corporate aviation flight departments 14 are sot up, they're under holdings companies. 15 O. I'll go with all of them. 16 A. Weil, I daft know. They change. They 17 change sometimes by the year, sometimes I have no 18 idea what they're under now. 19 Q. What were they under back in '88 — 20 A. It was like - al Q. - to the best of your memory? 22 A. They change. I mean, every time we got a 23 new aircraft, or whatever, they changed. They were 24 like Northeast Holding, Southwest Holding, LLC - 25 Wilmington, Delaware. companies, which Is standard EFTA01110281 Larry Eugene Morrison - Volume I October 6, 2009 45 for these, you know. 2 Q. Did Leslie Werner ever tell you that he 3 allowed Jeffrey Epstein to serve in some sod of 4 capacity, representative capacity, for any of these 5 companies? 6 A. No. He would never say that to me 7 anYwaYs• no. 8 Q. What's the first time you ever saw Jeffrey 9 Efletein? 10 A. Can't say. I'm not sure. 11 O. I think you saw him before you started working 12 for him or with him? 13 A Oh, yeah. that's Where I first saw him 14 was when I flew him on The Limited 727. 15 Q. What year do you think that was? 16 A. tt would have had to have been — 17 O. Talking late '80s, early '90s? 18 A. Late '90s. 19 Q. Late '90s? 20 A. Yeah, probably - mid to late Tres. 23. Q Well, I mean, if you're taken over with 22 Jeffrey Epstein in, what, 2001 — 23 A. Correct. 24 O. then you're talking late '90s is the first 25 time you see him? 47 1 A. They were — They were generated, bull 2 don't know, you know, why- what the particular 3 reasoning was for it 4 Q. Do you know if Terry (sic) Staley would have 5 been the one to forward those flight logs to the FAA? 6 A. No, no. no. I They were all just for 7 business use - not forwarded to the FM. 0. Okay. Now — 9 A. The FM doesn't care about flight logs. 10 Q. How did the FM monk.: when that plane took 11 off? 12 A. Flight plans. 13 Q. And was it your understanding that when the 14 plane took off, the FAA was unaware as to who was ever on 15 It? 1.6 A. Pretty much, yeah. They deal tare about 17 names. When you Be flight plans with the flight 18 service station or via electronically, all they care 19 about Is souls on board, contact Info-math:a, flight 20 routing. things kke that. 21 Q. Are there time limits as to when the plane is 22 allotted to take off? 23 A Yeah, usualy — From what point? What do 24 you mean? Time of the day or — 25 Q. Yeah, yeah. time of the day. 1 understand 46 A. Well, mid — I don't know exactly. I 2 can't realty say, really. 3 Q. I won't hold you to It It Is what it Is. 4 Mid to late '90s, if I wanted the Muhl logs 5 that have him on iit on the airplane, who would I 6 subpoena to got those records? 7 A. I have no idea. 8 Q. Are they turned into the FAA, to the best of 9 your knowledge? 10 A. No, the FM doesn't require them. 11 Q. So FAA does not get the flight — Wei, YAM'S 12 the point of even keeping these? 13 A Sometimes I think the IRS — I mean. this 14 is on assumption, I'm not even sure, but mostly for 15 Ike IRS tracking for if you have people that have 16 dual homes, dual statehoods, or whatever. 17 (Mr. Goldberger entered.) 18 MR. GOLDBERGER: Can we take a time out? 19 (Short break.) 20 (Mr. Pike appeared via telephone to 21 replace Mr. Goldberger.) 22 BY MR. EDWARDS: 23 Q. FAA flight logs- do you know why they're 24 generated, how they're generated, if they were generated 25 back In the Wexner days? 48 1 that there's some time where If it's too late they can't 2 take off. right? 3 A. Only where there's a curfew on the airport 4 - not ail airports, no. No, airplanes can fly any 5 time unless that airport has a noise curfew or 6 something, yeah. 7 Q. Did you ever know of Wexner's plane to take 8 off after ten o'clock p.m.? 9 A. Yes. Yeah. 10 O. Were you ever on that plane when it did? 11 A. Probably, yeah, yeah. 12 Q. Were you ever on that plane when there were /3 girls on the plane? 14 A. Describe Define *girls' On the Wexner 15 airplane? 16 Q. Yes. 17 A. There would be ladies and his daughters. 18 I mean — 19 Q. Other than family members. 20 A. There would be business associates. If 21 you're talking young women, yes, business associates 22 from the divisions. 23 Q. Have you ever been on the plane when there 24 were girlfriends of Leslie Wexner? 25 A Only when Abigail - before his - became EFTA01110282 Larry Eugene Morrison - Volume I October 6, 2009 49 I his bride, yes. 2 Q. How about after - 3 A. I mean - 4 O. — she became his — 5 A. — It was Abigail. She was the only 6 girlfriend. 7 O. How about after Abigail? 8 A. No. 9 Q. Have you ever seen sex or sex-related 10 instances occur on Leslie Wexner's airplane? 11 A. Absolutely not. We didn't even have 12 playing cards. He looked at the aircraft as a 13 business - a flying business office. 14 O. When you say *playing cards," what do you 15 mean? 16 A. Playing, you know, to — 17 O. Oh, playing cards. 18 A. Yes. playing cards. 19 O. So every time that you were on Leslie Wexnees 20 airplane. it was used strictly for business? 23. A. Well. I don't know if it was used strictly 22 for business, but there was no, you know, it was -- I 23 don't know what the purpose of the actual trip was, 24 but never saw, you know, anything, you know. 25 Q. Was there ever a time when you were — 51 1 O. Yes, with you on it. 2 A. I can't — I can't say. 3 O. Wet whore do you remember going in it? 4 A. Well, we would normally go to London. 5 Mien, Paris. I mean, mostly fashion areas and 6 business - business areas. 7 Q. When you say "fashion areas," what do you 8 mean? 9 A. Well, retail. I mean, you know, design 10 for clothing and stuff like that. it Q. What was the purpose? 12 A. rm sure it was business. I have no idea 13 what the actual purpose was. I don't — 14 O. Did you get off the plane? IS A. Well, of course. 16 O. What did you do there? 17 A. Go to a hotel, eat dinner, wait to find 18 out when you're going to the next place. 19 O. Were you ever on an international flight o. 20 one of Ph. Wexner's planes that Jeffrey Epstein was also 21. On? A. I cant say. I cant remember. 23 O. Maybe? 24 A. Possioly. 25 Q. Do you remember any specific places that 50 1 MR. REINHART: Hold on. Were you 2 finished? 3 BY MR. EDWARDS: 4 O. I thought you were finished. A. Yeah, I don't understand. I don't 6 understand that question. 7 O. turn going to clarify. Were there ever times 8 when you were on the plane and either Leslie Wexner 9 and/or other Individuals went behind these various areas 10 that you could not see into? 11 A. Yes. Yeah. 12 O. Do you know what they were doing in there? 13 A. Probably sleeping. He would go to bed at le night on the long trips, okay. 15 Q. My time that more than one person went in one 16 of these areas that you would not be able to see into? 17 A. Not that I'm aware of, but my exposure to 18 back there is not that, you know. is limited. 19 O. How many times did you see Jeffrey Epstein 20 ride that plane with Leslie Wexner? 21 A. Not many, but I can't sayexact 22 O. How many International flights do you remember 23 that plane taking? 24 A. Remember -- The airplane Itself taking 25 Internabonar? 52 1 Jeffrey Epstein went what on that plane outside the 2 United States? 3 A. I can't remember. No, no. Like I say. I can't oven remember if we took it for sure. 5 Q. Any time that you remember Jeffrey Epstein 6 being on the airplane, do you also remember there being 7 girls on the airplane along with Mr. Epstein? A. I can't — I can't say. I cant remember. 9 Q. When's the first time you remember seeing 10 Jeffrey Epstein? 11 A. Wet Ilke I say, I dont even remember 12 the year. I can't even pinpoint down to the year. 13 It was after - some tine after I started flying the 14 727, because that's the only exposure. 15 O. Okay. rm not going to ask you at al during 16 this deposition to guess. I thought at sane point in 17 time you told me you remember seeing Jeffrey Epstein. 1$ right? 19 A. Yes. 20 Q. In fact, you work for him now. 21 A. Yes. 22 Q. So at some point In time you saw him and you 23 saw him for the first time. 24 A. Correct. 25 O. When's the first time you remember seeing him? EFTA01110283 Larry Eugene Morrison - Volume I October 6, 2009 53 1 It may not be the first fine you saw him. When's the 2 Mgt time you remember seeing him? 3 A. '99, somewhere in that area. 4 Q. Alright in '99 were you working for Leslie 5 Wexner or were you working for Jeffrey Epstein? 6 A. Leslie Wexner. 7 Q. And do you remember the context in which you saw Jeffrey Epstein? 9 A. It was a ffight. 10 Q. What did Leslie Wexner ever tell you in terms 11 of who Jeffrey Epstein was? 12 A. Never told me anything who Jeffrey Epstein 13 was. 14 Q. Did you ever ask? 15 A. No. 16 Q. Did you ever ask back in 1999 when you saw 17 this guy, '1 wonder what he doer? 18 A. No. 19 Q. Not even curious? 20 A. No. It's not my place. I don't — I 21 don't need to know or want to know what people's 22 associations are. 23 Q. Next time you saw Jeffrey Epstein was when? 24 A. I can't say for sure. 25 O. Have you seen Jeffrey Epstein at Leslie 55 1 Jeffrey Epstein helped to - I think, what you said was - 2 manage Lest* Wexner's money? 3 A. Some of his accounts, yes. I guess. 4 O. Why do you think that? A. From what I've read in periodicals and 6 magazines. 7 Q. You've read in what periodicals an