E. Condensed Transcript

-4 E. Condensed Transcript IN THE CIRCUIT COURT OF THE 15Th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Case No. 502008CA028051 XXXXMB AD DEPOSITION OF LARRY EUGENE MORRISON TAKEN ON BEHALF OF THE PLAINTIFF VOLUME I Pages 1 to 200 October 6, 2009 10:55 a.m. Jennifer DiLorenzo, court reporter S ESQUIRE • Al tas4trOblioCeropOn> Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com CONFIDENTIAL 3501.150-002 Page 1 of 92 EFTA_00068793 EFTA01247021 • • • CONFIDENTIAL 3501.150-002 Page 2 of 92 EFTA_00068794 EFTA01247022 Larry Eugene Morrison - Volume I October 6, 2009 • • 1 211 TUR CIRCUIT COURT OP TER 15111 JWICJAL CIRCUIT IX AMU FOR PALM SEAM COUNTY. FLORIDA 2 3 APPEARANCE OF COUNSEL On WWI of the Defendant MAKE I Pages I to 200 3 ATTERBURY. GOLDBERGER a WEISS BY: JACK MAN GOLDBERGER. ESO . 4 250 Ausbaban Avenue Suite 1400 s . FL 33401 Plaintiff, 6 Case No. 502000C11024051 On bead of the DeiceOwe by 1444410TIE: /0703111 AD JEFFREY EPS/811I. BURMAN. CRITTON. LUTTER & COLEMAN Defendant. 9 BY: MICHAEL J. PIKE. E90.. SIS N. Reeler Drive 10 Suite 400 IMPOSITION OP .F133101 LARRY Puma Pomace 11 TAKEN ON OEMAL7 Of THE PLAINTIFF October 6. 2009 12 10,55 4.e. . 2:20 .n. 13 On behalf of the Aeneas: 14 LAW OFFICE OF BRUCE E. REINHART IS BY: BRUCE E. REINHART, ESO.. One Gavle» Center 16 250 S. AUSIrtien Avenue Jennifer Ditonne°. court reporter 17 Suite 1400 acn, FL 33401 10 19 20 21 22 23 24 25 2 4 A COUNSEL 1 INDEX OF EXAMINATION On beret dew Plante I40114STEIN. feet OT 6 ADLER 2 BY: BRADLEY J. EDWARDS LSO 3 WITNESS: 4 and MICHAEL HEELER. ESO . 4 LARRY EUGENE MORRISON 401 East Las am Elooleverd Page Sum IMO B. FL 33394 6 DIRECT EXAMINATION By Mr. Edwards *5 7 a On WW1 cpt Mew% a CROSS-EXAMINATION By Ms. Ezell *190 9 9 CROSS-EXAMINATION MERUELSTEIN 6 HOSIOVATZ. By Mr. Wilds 0195 10 BY: JESSICA D. ARBOUR. ATTORNEYAT.LAW, 10 11 18205 Biscayne Boulevere See 2216 CROSS-EXAMINATION 11 By Mr. Pike *196 12 FURTHER REDIRECT EXAMINATION 13 By Mr. Edwards 8199 14 On bete d ef 13 leNecee: 14 15 14 POOHURST ORSECK PA BY: KATHERNE.A. &ELL ATTORNEY-AT.LAW. 15 16 INDEX TO EXHIBITS 25W. Page« Seem 1 17 Ptautfts 19 :9 18 E.101bIt Description Page On Whaled tpe by IMPIzewle 19 1 Twenty-four pages of 'LIEGE. Inc.. 20 Passenger Manifest' ii198 LAW OFFICE OF ROMP) WIWTS. PA. 20 21 BY: IIICHANDWLUTS. ESC.. 2290 ICIP•Avenue H. 21 21 se. 404 22 33631 21 24 24 (Plaintiff's Composite 1 was attached to flic original transcript and codes of the transcript.) 25 25 • ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.corn 3501.150-002 Page 3 of 92 EFTA_00068795 EFTA01247023 Larry Eugene Morrison - Volume I October 6, 2009 • 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 5 Deposition of LARRY EUGENE MORRISON October 6, 2009 THE REPORTER: Do you swear the testimony you're about to give will be the truth, the whole truth. and nothing but the truth so help you God? THE WITNESS: So help me God. LARRY EUGENE MORRISON, having been first duly sworn, was examined and testified as follows: DIRECT EXAMINATION BY MR. EDWARDS: O. Tell us your name. A. Larry Morrison. O. And. Larry. where aro you employed right now? A. For JEGE. O. What's JEGE mean? A. Its the aviation flight department for Mr. Epstein. and my primary job * Dankjold Reed Aviation. MR. REINHART: Spell A A. D-A-N-KJ-O-L-D. and then the second word is Reed, R-E-E-D, Aviation. Its a corporate flight 7 1 You know, it was a business decision made somewhere. 2 O. What does the company do? 3 A. What? The company? It's just a holding 4 company. I think, for the aircraft. It's not -- I 5 don't believe ft to be a money making company or a 6 real corporation. 7 O. You're saying 'for the aircraft.* I'm 8 interpreting that to mean you're talking about one 9 aircraft. 10 A. Correct. 11 O. Does that mean there's one or there's more 12 than one? 13 A. There's more. Ho owns more than one, but 14 just one is JEGE or -- 15 O. And the aircraft that he owns, how many of 16 those do you either service ancifor ride on? A. I used to. I haven't been -- Actually, I 18 stepped back from being physically Involved, just 19 now I lust do paperwork - and it was February of 20 2007. So I haven't actualy physically been on the 21 airplanes other than I will lake the Boeing for 22 maintenance. 23 O. Since it seems like we've kind of skipped 24 ahead from 2001 to 2007, am I right that your first 25 involvement with Jeffrey Epstein of any way, shape, or 6 1 department. 2 O. What do you dote him? 3 A. Director of Maintenance. 4 O. Okay, so you maintain his planes .- 5 A. Correct. 6 O. should something go wrong? 7 A. Correct. Yes. Yep. O. Do you also-- 9 A. For maintenance. 10 O. Do you also fly on his planes? 11 A. On Mr. Epstein's? 12 a Yes. 13 A. I used to. I was a flight engineer -- 14 O. Okay. What.. 15 A. on his 727. 16 O. When you list your company - JEGE? 17 A. Yes. Yeah, it's just initials. It's an 18 ISC or heeding company. 19 O. How long has that holding company been around. 20 If you taw? 21 A. Since -- I think it was developed when I 22 came with the airplane • 2001. 23 O. Whose idea was it for that to come about - was 24 it yours? Was it his? 25 A. On, no, no, somewhere -- It wasn't mine. 8 1 form was 2001? 2 A. That's Correct, yeah. 3 O. You didn't meet him before that. 4 A. I had met him. He was a -- He was an 5 associate of my previous boss. 6 Q. Who's that? 7 A. Mr. Wexner. 8 O. Leslie Wexner? 9 A. Yes. 10 O. How do you know Leslie Wexner? 11 A. I woiked for Limited Stores for 12 years. 12 O. Doing what? 13 A. Essentially the same thing - aircraft 14 maintenance for their corporate flight department and 15 flight engineering on the 727. 16 Q. How many aircraft did Leslie Wexner have? 17 A. Well none that I know that he had 18 personally, but the corporation had - the flight 19 department operated • we had three Gulfstreams, two 20 Hawkers, and a 727. 21 O. What was the name of his corporation that 22 maintained the aircraft? 23 A. For Limited Stores? 24 O. Yes. 25 A. It was just It was called Limited - 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Ofas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutions.com • • • 3501.150-002 Page 4 of 92 EFTA_00068796 EFTA01247024 Larry Eugene Morrison - Volume I October 6, 2009 • • 9 1 Limited Flight Department. 2 O. And do you know him personally then - Leslie 3 Wexner? 4 A. Yeah. I had met him. of course, you know. I met him. I used to do aircraft completions for 6 him, so which would involve personal meetings. 7 O. When did you first meet Leslie Wexner? A. 1988 was when I hired on, so I don't 9 remember the month. 10 O. How did you gel that fob? 11 A. Through word of mouth and, you know. I 12 worked • I lived in - been in aviation for years in 13 Columbus. 14 O. Well, I mean. Leslie Wexners an important 15 person, right? I mean, he -- 16 A. Correct. 17 MR. GOLDBERGER: Form. 18 BY MR. EDWARDS: 19 O. He's somebody who owns my understanding - 20 Limited, Victoria's Secret? 21 A. Well, he doesn't own them. He's Chairman. 22 you know. 23 O. Chairman of -- 24 A. Yeah. He doesn't personally own it. Its 25 a publicly held company. 2 3 4 5 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 11 O. Yes. A. Aircraft technician. O. Which entails what? A. Maintenance of any or all of the aircraft operated by the flight department and some flight mechanic duties. O. What kind or airplanes? A. Gulfstreams, Hawkers. O. How big is the Gulfstrearn? A. Fifteen passenger - 15 to 17. (Mr. Goldberger exited.) BY MR. EDWARDS: O. What did Wexner use the Gullstream for? A. They were division airplanes, mostly. O. And the other airplane you named • what did he use that for? A. Same, same. O. Any idea why he had two planes? A. Well, I mean, yeah, we used them - they're a tool. It wasn't tam. II was a large Fortune 500 company. They use them as tools to You know, Limited has control over 60 percent of their manufacturing processes, plus, you know, what, 1200 stores, or whatever, throughout all their divisions. I mean, when you say *Limited.' its not 1 2 3 4 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 10 O. Where were you prior to any involvement with Leslie Wexner? A. I worked for Red Roof Inn True Sports Flight Department. O. How did that position lead you to Leslie Wexner? A. Well, it was always known that Limited Flight Department was one of the best jobs in Columbus and, actually, several other people that were already there knew me from previous jobs and education - we went through aircraft mechanic, or A&P school, together - so when the position became available they pointed to me and - absolutely. It was a fine organization. O. So did Mr. Wexner approach you or did you apply to him or how did that work? A. Oh, no, no, no. It's -- No. He wouldn't be involved in that type of activity. You apply to H.R, and you interview with the Director of Operations or the Chief Pilot. You know. he w0ukInt O. So you start with Wexner in 1988. A. Yes. O. What do you do for him then? A. What ced I do for him? 12 1 just Limited, its Victoria's Secret and it was 2 Express and Lemers and Henn Bendel's and all of 3 that back then. so. I mean -- 4 O. So - sA. we moved a lot of passengers to keep 6 those stores for the retail business. 7 O. And by 'passengers,' do you also mean clie-is of his? 9 A. That I don't know. No. Mostly we lust 10 dealt with upper echelon, you know, people in the 11 retail businesses from -- 12 O. Such as whom? 13 (Mr. Goldberger entered.) 14 A. Can't even remember names, but it would be 15 We would take buyers to Europe in the spring and 16 fall. They would buy samples and bring them back to 17 analyze for marketing. We would hire -- We would — 18 Division heads, when they would do store shops and. 19 Real Estate, we take Real Estate out when they were 20 looking for new real estate. 21 O. While you were working back in BI3- Well, 22 how long overall did you work with Leslie Wexner and/or 21 his companies? 24 A. Well, '88 through when I came hero in 25 January of '01. • 0 ESQUJ.0.4E .1 CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-002 Page 5 of 92 EFTA_00068797 EFTA01247025 Larry Eugene Morrison - Volume I October 6, 2009 13 1 O. Why the change? 2 A. It offered an opportunity -- Well, one was 3 I enjoyed flying - and the 727 was being replaced by 4 a BBJ, which is a two-man airplane. not a three-man 5 airplane three-pilot airplane - and it gave me the 6 opportunity to become a Director of Maintenance. and 7 it was a challenge. You know, bringing upstarting 8 an airliner on a private ticket or a VIP ticket is 9 really challenging, and I enjoy the challenge of 10 world% arid developing the program and stud. 11 O. Well, my understanding. Leslie Wexner Is 12 generally - he's in Ohio. tight? 13 A. No, he's got other places. I mean -- No. 14 he's like anyone, he's - in hiS Category - he's got 15 multiple homes and — 16 O. Well, when you would maintain his aircraft, 17 would that be in Ohio -- 18 A. Yes. We were based -- 19 O. or elsewhere? 20 A. We were based at Lane Aviation. 21 MR. REINHART: HOld on one second. You 22 have to let him finish asking the question 23 before you answer. 24 THE WITNESS: Okay. I'm sorry. 25 BY MR. EDWARDS: 15 I aircraft. I mean, whatever a takes to keep a 2 corporate flight department operating. 3 O. Did you know back then of his relationship. it 4 any. with Jeffrey Epstein? k Not immediately. no. 6 O. When is the first time that you know of a 7 reputation or a relationship between Wexner and Epstein' e A. Would have had to probably be around maybe 9 '98,'99. 10 O. How do you become aware that they know ono 11 another? 12 A. Because Jeffrey. every one That's when 13 I became a flight engineer on the Boeing. and every 14 once in a while Jeffrey would ride on the Boeing. 15 that's all • that's all I knew. 16 O. How ckd 4 come about that he would nde on 17 Wexners Boeing? le A. They were business associates, I think. 19 O. As far as you knOw, they were business 20 associates. 21 A. Right. 22 O. Did you understand the business retationsh -p 23 between the two? 21 A. Web, I believe it's pubic knowledge 25 that, I think, Jeffrey managed Mr. some of Mr. 14 1 O. I'm sorry, have you ever had your deposition 2 taken before? 3 A. No. 4 O. You definitely never had your deposition taken before while somebody else is trying to eat at the same 6 time they're trying to ask the questions - that's very 7 bizarre. 8 A. Yes. yes. 9 O. I meant to do this before I got here. But, 10 regardless. Ill wail until you finish your answer before 11 I ask my next question; you do the same thing. 'Uh.huh' 12 or •uh-uh,' they kind of look the same on the record, so 13 try to give us a'yes' or to' or something we 14 understand. 15 A. Alright. 16 O. II I ask a question that was a bad question or 17 something you don't understand ive asked bad questions 18 before • say. 'I don't get it' I'll ask a better 19 question. 20 A. Okay. 21 O. You were working with Leslie Wexner. You got 22 the job there starting in 1988. On a day-to-day basis. 23 what would you be doing? 21 A. Maintenance, aircraft maintenance, 25 tracking of aircraft maintenance. cleaning of 16 1 Wexnees funds. 2 O. Is that something that Mr. Wexner told you? 3 A. No. 4 O. Is that something that somebody of Mr. 5 Wexner's organization would have told you? 6 A. No. 7 O. Is that something that Jeffrey Epstein told a you? 9 A. No. 10 O. Is that just reading articles that speculate 11 as to the business relationship between the two or do you 12 got something more for me? 13 A. No, it's just it's speculation and, you 14 know, what I've read. you know. 15 O. I mean, like you say, to me ifs common 16 knowledge -- 17 A. Right. 18 O. But irs only because of what I've road. I 19 don't have a specific person that I could cite to to say 20 that do you? 21 A. Right. No, just - just periodicals. 22 O. What's your understanding of the persona 23 relationship, if any, between Wexner and Epstein' 24 MR. GOLDBERGER: Form. 25 A. Don't know. 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com • • • 3501.150-002 Page 6 of 92 EFrA_00068798 EFTA01247026 -19 Larry Eugene Morrison - Volume I October 6, 2009 • • 17 1 O. Did you ever know of a time -- And I may be 2 asking a question that would just be completely outside 3 of your knowledge. so lot me back up. 4 Have you ever stayed at Leslie Wexner's house? A. No. 6 O. Do you know where his house is? 7 A. Yes. 8 Q. Do you know what the address is in Ohio? 9 A. ND. I just know the City. 10 O. Do you know who he lives with? 11 A. Yes. 12 O. Who is that? 13 A. His wife and Children. 14 O. What's his wile's namo? 15 A. Abigail. 16 O. Abigail Wexner. and he has three or four 17 daughters. ngM? 18 A. No. He's got a son. M . and two 19 daughters. I think. 20 O. A son and two daughters. 21 A. I don't know. See, that was back in 2001. 22 I don't know what they have - it they have more kids 23 now. 24 O. Okay. Did you ever hew any information that 25 he was homosexual? 19 1 O. Have you spoken personally with Mr. Wexner? 2 A. On bus:Mess issues, yes. 3 O. Business Issues related to your work on his 4 airplanes? A. Correct. 6 O. Have you spoken to him on any other Issues 7 that don't involve business relationships with his e airplanes? 9 A. No. 10 O. Because you're hired basically for that 11 purpose. so that's kind of how you deal with him. 12 A. Yeah. Ifs I'm an employee and he's my 13 employer and I only deal with him, you know. en 14 issues that involve maintenance. 15 O. I think I probably knOw the answer to the next 16 question, but just in case I don't, do you knOw any of 17 his personal friends people that he would hang out with l8 on a social level - being Mr. Wexner? 19 A. Through my business ties, yes. yes 20 O. Who's that? 21 A. I'm hying to remember - You have to 22 remember its been several years. 23 O. Right. 24 A. He was friends with the Tuckermans. 25 O. What's Mr. Tuckerman or Ms. Tuckennan's names? 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 18 A. No. O. Being Mr. Wexner. A. No. O. My Indication to you that he may be homosexual or bisexual? A. Absolutely not. O. Have you heard any Information that he and Mr. Epstein were involved sexually with one another? A. Oh. no. no. O. Would that surprise you? A. Absolutely. O. And Mars only because you know him and you know Mr. Wexner and you don't see the two together. A. Correct. MR. GOLDBERGER: Form. A. Weil — A. Go ahead. MR. REINHART: If you need to answer, answer the question. A. Yeah. No. I saw him with Sharon, which was his previous girlfriend before he met Abigail. O. Right. A. No. There was never any hint or anything Mat I would even conceive that. 20 1 A. Ms. - I cant. I always addressed them 2 by their proper name. 3 O. Do you know what they do? 4 A. They owned an optical company - opticians. s They were high school friends from Mr. Wieners high 6 school days. 7 O. In Ohio or New York? 8 A. He went to high school in Bexley. 9 O. Bexley. Ohio. 10 HaS he ever discussed with you how 11 longstanding the relationship is between himself and Mr. 112 Epstein? 3 MR. GOLDBERGER: Form. 14 A. I don't understand. Can you rephrase il? 15 O. Wet you know that at some point in time 16 You started working with him in 1988. The first time. 17 according to my notes. that you became aware Mat he was 18 friends or acquaintances with Mr. Epstein was V8 - 19 almost ten years later. 20 A. Right. 21 O. After you became aware that Mere was that 22 relationship. whether business or otherwise, did he ever 23 speak to you about how long he had known Mr. Epstein? 24 A. Oh. no. no. 25 O. So as far as you were concerned. 1998. when • 0 ESQUIRE Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutiOnS.COrn 3501.150-002 Page 7 of 92 CONFIDENTIAL EFrA_00068799 EFTA01247027 Larry Eugene Morrison - Volume I October 6, 2009 21 1 you found out there was a relationship with Epstein. it 2 could have very well started then. 3 A. Yes. 4 O. Aside from aircraft technician and taking care 5 of Mr. Wexner's aircraft back in the '80s and. I guess. 6 early '90s, did you have any other personal involvement 7 with him? 8 A. Just on aircraft completions. 9 O. And when you would speak with him, would that 10 be over the telephone, at the airport, at his private -- 11 A. It would usually be al the corporate 12 office. 13 O. Al the corporate office? 14 A. At he corporate office. 15 O. Can you tell me the address for his corporate 16 CAM? 17 A. No, I can't 18 O. If I requested that from your attorney, would 19 you be able to got that information? 20 A. Well, I mean, I imagine it's public 21 knowledge • wherever - it's at the Limited. 22 O. And that's where you would meet him • at the 23 Limited? 24 A. Yeah. 25 O. And how often was • you know, I know that 23 1 O. Who were some of the pilots? 2 A. Tim Staley. Jim Taylor. They've had some 3 tumover too. I don't know who all is still there 4 because retail is down. 5 O. Was Larry Visoski a pilot used by Leslie 6 Wexner at any time? 7 A No. 8 O. How about David Rodgers? 9 A. No. 10 O. Are those names you're familiar with? 11 A. Yes. 12 O. Those are names you're familiar with how? 13 A. I flew with them when I was flying for Mr. 14 Epstein. 15 O. So there's no real, other than yourself -- 16 Well, tell me if I'm wrong: I understand that you did 17 some work for Mr. Wexner related to his aircraft and you 18 did some work for Mr. Epstein. which we haven't yet got 19 to. but you did some work for him too. Are there any 20 other people that have that type of relationship with 21 both pathos? 22 A. No. I'm sorry, resay that. 23 O. Okay. You've already told us that you were 24 the aircraft technician for Mr. Wexner. 25 A. One of them. One of several, yes. 22 1 we're talking about 15. 20 years ago - how often was Mr. 2 Wexner personally al that location at the Limited 3 offices? 4 A. I have no idea. O. But any time you needed to talk to him. that's 6 where he would be? 7 A. Yeah, and I usually went to Charlie 8 Hinson. 9 O. Who's Charlie Hinson? 10 A. He was the president of the stores. He 11 basically was my go-between for these aircraft 12 completions for the design. 13 O. And you mentioned the Gullstream as an 14 aircraft Did you also serve as a technician for other 15 aircrefts that were owned by Mr. Wexner? 16 A. Right but not Mr. Wexner. They're owned 17 or operated by Limited Stores. 18 O. Limited Stores? 19 A. Right. Yes. 20 O. What did you do for them? 21 A. Same maintenance. 22 O. Did you ever fly in them? 23 A. On the Gullstreams in the early days we 24 used flight mechanics, especially on international 25 flights. 24 1 O. One of them. Then you also have knowledge 2 about Mi. Epstein and some relationship with Mr. Epstein. 3 A. Correct. 4 O. Are there any other pilots. aircraft 5 technicians, people like that that you know of to have a 6 relationship with both Mr. Wexner and Epstein? 7 A. No. no. 8 O. Do you knew how Mr. Wexner met Mr. Epstein? 9 A. No. 10 O. How long - if you started in 1988 how long 11 did you slay with Mr. Wexner and/or The Limited? 12 A. January of YR. 13 O. Why did you stop? 14 A. Because what we were talking before, you 15 know, I wanted to continue flying. They bought a 16 BBJ. which is a two-pilot aircraft, and I wanted to 17 continue flying. Mr. Epstein bought the 727 and 18 offered me a position to continue flying and, you 19 know, basically sot up the airplane for his flight 20 department because they hadn't had any previous large 21 aircraft experience. 22 O. I missed something. It wasn't your fault, it 23 was mine. 24 The Gulfstream that you were talking about. 25 did you used to fly that as well as being a flight ESQUIREO nrtfaaa CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquIresolutIons.com • • • 3501.150-002 Page 8 of 92 EFTA_00068800 EFTA01247028 Larry Eugene Morrison - Volume I October 6, 2009 • • 25 1 technician? 2 A. No, no. 3 O. Okay. 4 A. You don't have to have a flight a • pilots certificate to be a professional flight 6 engineer. I've got a turbo a (fight engineer turbo 7 jet rating, but you don't have to have a commercial 8 ticket as long as you • the FAA recognizes your heavy 9 aircraft maintenance experience. 10 O. So you're saying that if the FM recognizes 11 your heavy maintenance experience, I'm assuming that 12 means that you understand the ins and outs of airplanes 13 and you can work on them. 14 A. On heavy high performance aircraft, yes. 15 O. Then you can also fly them? 16 A. Sideways as a flight engineer. 17 O. Explain. 3.43 A. On the older generation airliners there 19 was three pilots - there's a captain, a first 20 officer, and then the flight engineer is the 21 gentleman that sits sideways and maintains all the 22 systems. 23 O. When you say. "sits sideways: okay, I have 24 a — 25 A. Literally, you're physically sideways in 27 1 O. Do you know why Epstein chose to buy that 2 particular 727 rather than one of the other million 727s 3 that are made? 4 MR. GOLDBERGER: Form. 5 A. Because it was probably the finest one out 6 the 7 O. Why? 8 A. -- in all honesty. It's got a fully Paged 9 STC interior with EMS cockpt. and Limited's 10 reputation on the way that we maintained our aircraft 11 - Its the best one out there. 12 O. Describe for me the interior • I'm not talking 13 about the Epstein days, we're talking about the Wexner 14 days describe for me the interior of the aircraft, and 15 keep in mind that I've only been on a commercial aircraft 16 where you donl see the pilots. there's a door, and then 17 everybody, you know, there's just a bunch of seats where 18 everybody sits there. 19 A. Correct. Right. 20 The aircraft You enter the airplane, 21 it's got forward air slays. which most 727's don't, 22 so you enter the forward door on the left-hand side. 23 the forward entryway vestibule, and there's a door on 24 the left, which leads to the cockpit, and then 25 there's a door on the right which leads aft to the 26 1 the cockpit 2 O. So you're not looking at the people that were 3 flying on the plane and you're not looking at the pilots. 4 yottre actually literally sitting sideways. S A. I sit sideways at a panel, yes. 6 O. What's your job? 7 A. Maintain all the aircraft systems - the • hydraulffs, fuel management, pressurization. 9 environmental controls. 10 O. That's not done by the pilots. 11 A. Now. 12 O. But if you've done that long enough and FAA is 13 aware of your credentials in that respect, then you also 14 could be credentlaled to be a pilot as well? 15 A. Well, sure, yeah, yeah. If that's a 16 career choice you wish to take. 17 O. And was that? 18 A. No, no. I was perfectly satisfied with my 19 position as a flight engineer and Director of 20 Maintenance. 21 O. What year did you say Epstein bought the 727 22 that was once owned by Wexner? 23 A. I don't know when the actual transition 24 took place, but when I came - shortly around the 25 period that I came on board In . January of bl. 28 1 forward salon. 2 O. What's the forward salon? Sorry. 3 A. Forward seating area. 4 O. And is it set up basically the way that I'm 5 picking it - in that there are 25 or 26 rows and they're 6 numbered A through E? 1 A. No. no. its a corporate configuration. 8 O. Which means nothing to me, so help me. 9 A. Picture a 600-mile an hour Winnebago. I 10 mean, its got conference tables and divans and large 11 first class seating. 12 O. Any various dividers throughout -- 13 A. Yes. 14 O. -- to where there's a VIP room in the back or 15 anything like that? 16 A. It's compartmentized (sic), yes. 17 O. In what way? Descnbe it as specifically as 18 you can. 19 A. There's a forward salon, a mid galley 20 the galley's in the mid - an aft • an aft salon, 21 which is and then the aft stale room. 22 O. Who designed that plane? 23 A. I can't remember who the actual designer 24 was. It was a Page interior, though. Page Avjet did 25 the installation. • 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com 3501.150-00i Page 9 of 92 EFFA_00068801 EFTA01247029 Larry Eugene Morrison - Volume I October 6, 2009 29 1 0. Who directed the design ot that plane? 2 A. It would have been Mr. Wexner. I mean, it 3 was -- The layout has not changed. 4 0. The layout has not changed; when you say 5 that, you mean 'from the time that I first got in it and 6 I was under the guise of 'under the employment of 7 Wexner to the time I've been on it since with Epstein. Es the configuration is the same' 9 A. Essentially, yes. We removed one chair 10 and one small table that was an annoyance and that's 11 it, but it's identical to what The Limited used. 12 0. Are there any blocked off areas to where if 13 you're standing in the middle of the plane you can't see 14 certain areas of the plane" 15 A. There are pocket bulkheads. Yeah. there's 16 dividers between the sections. 17 O. How big aro these dividers and where are they? 18 A. Well, there's a divider - the forward 19 door, I told you, on the salon, then there's a pocket 20 door on the forward side of the galley, a pocket door 21 on the aft side of the galley, there's a pocket door 22 between the aft salon and the office, and then 23 there's another pocket door between the office and 24 Me state room. 25 0. Have you been on other 7275 before that are 2 3 4 5 6 9 to 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 31 because obviously there's a lot - there's not that many -- A. Privately owned 7275. but this is As a matter of fact The Limilects current BBJ has a very similar floor plan. 0. As Trump's? A. No, as the as our 727. 0. Who's 'our'? A. Mr. Epstein's. They didn't change a lot. It's - O. Well, I thought that you had told me that the 727 that was once owned by Wexner is the 727 that's owned by Epstein. A. It is, but what I'm saying is even their current airplane has the same layout - the BBJ. They put the same floor plane in the more modern airplane 0. Well, they dam have 10 put it there. It was already there. nght? A. No, no. no. When you buy these aircraft - even a Gullstream when you buy them its just a green hull, there's nothing in them, and you can customize your interior. 0. I'm sony, we're miscanmunicating so.n8l to and I m sure its on me. MR. GOLDBERGER: Yes. it is 1 3 4 5 6 9 10 11. 12 13 14 15 16 17 16 19 20 21 22 23 24 25 30 commercial airliners privately owned? A. Yes, yes. O. Have you noticed similar configurations to where there aro this many dividing doors or is this one that has more so than you've seen in the past? A. No. no, this is pretty atypical (sic). O. It's pretty atypical? A. It's typical. 0. It's pretty typical? A. Yes. yes. 0. So what other airplanes - 727s, or other major airplanes - have you been on that have these types of dividers? A. Trump. 0. Trump's airplane? A Yes. 0. Why were you on Trump's airplane? A. Well, I know the crew and, you know, this Is a small-knit community. There's not very many of them out there, so everybody in this world knows one another to help one another out as far as — 0. By 'there' -- A. information -wise and stuff. Q. By hhere aren't that many of these people out there' you don't mean there's not that many people • 3 2 MR. EDWARDS: And l-m taking the blame for rght away. 3 MR. REINHART: Take that. Ed. 4 MR. EDWARDS: Alright 5 BY MR. EDWARDS: 6 0. My understanding - and please correct me when 7 I'm wrong. because I knew I am - Wexner has this 727 and 8 he designs it in a certain way. 9 A. Uti-huh. OA. YAnd ee.then you come to work for Epstein-. 11 12 who buys the same 727. Your testimony, as 13 I'm understanding It, Is: It's basically the same 800r 14 plan as Wexners floor plan. To me, it should be the 15 exact same because he bought the same plane. 16 A. No. he -- You're misunderstanding. 17 0. I figured. 18 A What I was stating is You were I was 19 answering the question in regards to, 'Is this 20 unusual to have thiS many compartments and closed 21 doors and bulkheads and things?' 22 What I was trying to state was: NO, its 23 not unusual - because The Limited even Mod the 24 Floor plan so wee in their old airplane that they 25 sold to Mr. Epstein. They duplicated it in their new ESQUIRE Oa Altandwrall•Canpa CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com • • • 3501.150-002 Page 10 of 92 EFTA_00068802 EFTA01247030 Larry Eugene Morrison - Volume I October 6, 2009 • • 33 1 airplane - see what I'm saying? That's all I was -- 2 O. So they didn't keep the floor plan. They 3 actually took it out and they restructured the floor plan 4 to basically match that old floor plan. 5 A. Well. no. When you -• When you buy a 6 Boeing business jet — 7 Cy Yes. A. it comes with nothing inside. It's a 9 tube. Nothing's in there. You design • have 10 designers design your interior and then a fabricator 11 or a facility such as Page Avjet to install this 12 Interior. 13 O. Right. 14 A. What I was just trying to state was that 15 The Limited liked their old floor plan in the old 16 airplane so well - it worked so well for them - that 17 they duplicated it and had that same interior 18 installed in the new aircraft • same floor plan 19 installed on the new plan. 20 O. So Epstein didn1 buy the exact same plane. 21 He bought the same type of plane. 22 A. Well, more modem. He bought a 737. 23 right. 24 O. Got it. 25 A. Right. 35 1 had a very identical or very like floor plan 2 installed in the new airplane. 3 O. Coln 4 A. Okay? Sorry, it's a strange business. 5 It's — 6 O. Tell me if I'm right: Mr. Wexner had a plane 7 that had a floor plan that apparently appealed to Mr. 8 Epstein, so Mr. Epstein bought that plane. 9 A. Correct. 10 O. Mr. Wexner also liked that plane that he had 11 just sold to Mr. Epstein, so he built in a floor plan 12 very similar to the one he just sold to Mr. Epstein 13 A. In his new aircraft. 14 O. Brand new plane. 15 A. Correct. 16 O. Got it. We're on the same page now. 17 A. Alright. 18 O. Took us a while to get there. 19 A. Yeah, sorry. 20 O. I think it was my fault, honestly, but 21 alright? 22 A. It's an unusual process it you haven't 23 been around corporate airplanes. 24 O. I didn't realize that Mr. Wexner had a new 25 plane. 1 2 3 4 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 34 MR. REINHART: Hold on. BY MR. EDWARDS: 0. Totally understand now. MR. REINHART: Can you clarify - Mr. Epstein or Mr. Wexner? BY MR. EDWARDS: O. Mr. Epstein bought not Mr. Wexner's plane. A. No. O. He bought the same type of plane that Mr. Wexner had and modeled the floor plan -- A. No. O. -- the same way that Mr. Wexner had it. A. That is not correct. O. He bought, actually. Mr. Epstein -- MR. REINHART: Hold on. Distinguish -- Use names so we're very clear when you're talking about Mr. Epstein and Mr. Wexner. okay? A. Mr. Epstein bought Mr. Wexner's 727. O. Okay. A. The actual airplane - bought it from him. Q. Which has a floor plan already in it. A. That we just discussed. O. Alright. The floor plan's in the plane. A. Right. Mr. Wexner replaced the airplane that Mr. Epstein bought with a new airplane and he 36 1 A. Yes. 2 O. Thars where I had a problem. 3 How many times have you been on Mr. Wexner's 4 airplane? 5 A. The new? 6 MR. REINHART: Clarify which one you're 7 talking abaft. 8 BY MR. EDWARDS: 9 O. Before you ever met Mr. Epstein. 10 A. I can't say. I mean. over the years? 11 O. Numerous times? 12 A. Oh, I was his flight engineer. You mean 13 when I was still employed by him? 14 O. Yes. 15 A. Yes. I was the flight engineer. I 16 don't -- 17 O. So as a flight engineer, every time the plane 18 leaves the ground, do you leave the ground with it? 19 A. No. We had another engineer also. 20 O. So what percentage of times do you leave the 21 ground in the airplane when the plane leaves the ground? 22 A. For who? 23 O. For Mr. Wexner. 24 A. Probably one-third of the time. because I 25 was also the lead technician, so 1 had • 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutIons.com 3501.150-002 Page 11 of 92 EFTA_00068803 EFTA01247031 Larry Eugene Morrison - Volume I October 6, 2009 37 1 responsibilities in the hangar. whereas the other 2 engineer was a full time engineer 3 O. And given the partitions that you've descnbed 4 in this airplane, are you able to see what's going on 5 behind the doors of the various partitions of the 6 airplane? 7 A. If the doors aro open or closed? 8 O. Closed. 9 A. No. 10 O. Do you have any idea what's taking place in 11 there? 12 A. No. 13 MR. GOLDBERGER: Form. 14 8Y MR. EDWARDS: 15 O. When you're on the plane with Mr. Wexner. was 16 there a time that he had Well, let me put it this way: 17 When anybody is a passenger on any of these private 18 planes, should there be logs of the names of the 19 passengers on the planes? 20 A. Not required, no. 21 O. Are you ever specifically instructed not to 22 record the names? 23 A. That wasn't part of my duties. That 24 wasn't an engineers task, but -- 25 O. Do you --3 9 1 A. There is normally a passenger manifest. yes. 3 O. Who creates the manifest? 4 A. Probably dispatch. 5 O. Dispatch? 6 A. At Limited. 7 O. Do you know who that is? 8 MR. REINHART: Can you give a time frame? 9 Do you mean currently or back when he worked 10 mere? It MR. EDWARDS: I'm talking about back when 12 he worked there. 13 BY MR. EDWARDS: 14 O. Do you know who that was at dispatch? is A. That would have been Diane Williams. 16 0. Who does Diane Williams work for? 17 A. Limited Flight Department. 18 O. Who does she report to? 19 A. Tim Staley. 20 0. Who's Tim Staley? 21 A. Director of Operations. 22 O. For who? 23 A. Limited Flight Department. 24 O. What does he then do with that Information? 25 A. I don't know. I don't know. 2 38 1 A. — no. not that I'm aware of. 2 O. Who is assigned the duty of reporting the 3 names of the people who are going to be transported on 4 the airplanes? 5 MR. GOLDBERGER: Form. 6 A. Captain. 7 O. So have you ever been privy to conversations 8 where the captain is told by Mr. Wexner to record all of 9 the names of the people that are going to be on the 10 airplane' 11 A. Can't say. 12 O. Sometimes? 13 A. I can't You know, I can't say. I can't 14 remember what our policies were at the time. 15 O. I'm not asking policies. I'm asking: Have 16 you ever been around when the plot was being instructed 17 by Mr. Wexner • back in the late '80s, early '90s - to 18 make sure that you record who's on this aircraft? 19 A. I never heard Mr. Wexner address that, no. 20 O. I moan. God forbid the airplane crashes, you 21 would tike to know who's the on the airplane, right? 22 MR. GOLDBERGER: Form. 23 A: Yes. 24 O. Is there any way to determine who's on each 25 particular night in case anything happens? 40 O. Have you ever talked to Tim Staley? 2 A. From Yes, yes. 3 O. And what do you talk to him about? 4 A. Oh, we're - we're friends. We worked 5 together for years. I mean, I haven't talked to him 6 since the holidays. 7 O. Do you know where he is now? a A. To the best of my knowledge, stilt 9 Director of Operations at Limited. 10 0. Do you have a number for him? 11 A. Yes. 12 0. Can I have the number, please? 13 A. It's 14 0. Is that a work number? 15 A. That's the Flight Department. 16 O. That's the best number to reach him at? 1? A. Yes. 18 0. If I'm going to call him, that's the number I 19 call? 20 A. Correct. 21 0. And was he always in charge of flight 22 directions? 23 A. No. he was previously Chief Pilot. 24 G. He was previously Chief Pilot for Limited? 25 A. Same, yes. 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 wvatesquIresolutions.com • • • 3501.150-002 Page 12 of 92 EFEk_00068804 EFTA01247032 Larry Eugene Morrison - Volume I October 6, 2009 • • 41 1 0. And he was promoted, I suppose, to Flight 2 Director? 3 A. Director of Operations. It's the 4 department crew. Most small departments don't have S &rectors until they start to grow. 6 Cr. And when he was Chief Pilot were you 7 affiliated with the Wexner organization? 8 A. Yes, I was a maintenance technician. 9 O. And when you say somebody keeps flight logs. 10 Is it always Tim -- is his name Tim Staley? 11 A. Yes. 12 O. — Is It always Tm Staley who does that? 13 0. No. I don't knOw where they go. honestly. 14 and the system may have changed. 15 O. Okay. Are you -- 26 A. I've been gone since -- 17 O. Are you aware of any FAA policies to where 18 they need to know who's on the aircraft whenever It talks 19 off? 20 A. Not under Part 91 Operations, there is 21 not. 22 O. Part what? 23 A. Pan 91. 24 O. What does Part 91 say, as far as you know? 25 A. It's basically souls on board when you 43 1 international. The only time we do international 2 would be for Customs and Immigration. 3 O. So if its an international flight -- 4 A. For Customs and Immigration • for coming 5 and leaving the country. 6 O. then they require that names of 7 individuals — 8 A. It would be names, passports, that kind of 9 stuff • normal. 10 O. Did you ever do any international flights t.1 while employed by The Limited, Victoria's Secret, the 12 whole Wexner group? 13 A. Yes. 14 O. How many? 15 A. No way of knowing. I mean. rm • can't 16 say. It's, like I say, years. but 17 O. What years would you done its? 18 A. Started flying as a flight mechanic in 19 '89, and then started flying the Boeing in '99, so • 20 to '01, so '89 to '01, basically. 21 (Mr. Goldberger exited.) 22 BY MR. EDWARDS: 23 O. SO '89 to '01, if I wanted all of the flight 24 logs, who would I request those from - Tim Staley? 25 A. Don't know. I don't know who -- 1 2 3 4 5 6 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 42 file a flight plan - that's the only thing you're required to do. When you file your flight plan you file souls on board. O. What does that mean, 'souls on board'? A. In other words, living bodies on board. In other words, if you have • so if there's an accident and you have four and you're transporting a cadaver, that they go to the accident scene and don't find five bodies - think there were live fatalities. 0. So it's your understanding from what you need to report are, 'I have five people on board.' A. Correct, and that's for the flight plan. O. So there's no reason to say that, 'I have Joe Schmo on board? A. Not under Part 91, no. 0. That's doing something over and above. A. That's correct. O. You are aware, though, that there are certain flight plans where they actually name individuals that are on the airplane? MR. GOLDBERGER: Form. A. No. 0. I mean, you've seen that belore. MR. GOLDBERGER: Form. A, No, nOl on NO plans, no - unless it's 44 1 O. What does Tim Staley do alter he maintains 2 these records? 3 A. I don't know. 4 O. He's never told you what he does? 5 A. No. 6 O. Certainly theyre kept on file somewhere, 7 right? 6 A. I would assume. 9 O. What's the name of the company that owns the 10 airplanes? I know its affiliated with Wexner and all 11 that, but what's the name of the company? 12 A. Well, there were several companies. I 13 mean, the way corporate aviation fkght departments 14 are set up. [helm under holdings companies. 15 O. I'll go with al of them. 16 A. Well. I don't know. They change. They 17 change sometimes by the year, sometimes -- I have no 18 Idea what they're under now. 19 O. What were they under backln'88 A. It was like -- 21 O. to the best of your memory? 22 A. They change. I mean, every time we got a 23 new aircraft, or whatever. they changed. They were 24 kke Northeast Holding, Southwest Holding, LLC • 25 Wilmington, Delaware, companies, which is standard • ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutlons.com 3501.150-002 Page 13 of 92 EFT,C00068805 EFTA01247033 Larry Eugene Morrison - Volume I October 6, 2009 45 1 for these, you know. 2 O. Did Leslie Wexner ever tell you that he 3 allowed Jeffrey Epstein to serve in some sort of 4 capacity, representative capacity, for any of these 5 companies? 6 A. No. He would never say that to me anyways. no. 0. What's the first time you ever saw Jeffrey 9 Epstein? to A. Can't say. I'm not sure. 11 O. I think you saw him before you started working 12 for him or with him? 13 A. Oh. yeah, that's -- Where I first saw him 14 was when I flew him on The Limited 727. 15 0. What year do you think that was? 16 A. It would have had to have been 17 0. Talking late '80s. early '90s? 18 A. Late '90s. 19 O. Late '90s? 20 A. Yeah, probably - mid to late '90s. 21 0. Well, I mean, it you're taken over with 22 Jeffrey Epstein In, what, 2001 - 23 A. Correct. 24 0. - then you're talking late '90s is the first 25 time you see him? 47 A. They were -- They were generated, but I 2 don't know, you know, why - what the particular 1 reasoning was fork. 4 0. Do you know it Terry (gc) Staley would have 5 been the one to forward those flight logs to the FAA? 6 A. No, no, no. I -• They wore all lust tor 7 business use • not forwarded to the FAA. 8 0. Okay. How -- 9 A. The FAA doesn't care about flight logs. 10 0. How OW the FAA monitor when trial piano took 11 off? 12 A. Flight plans. 11 0. And wash your understanding that when the 14 plane took off, the FAA was unaware as to who was ever on is it? 16 A. Pretty much, yeah. They don't care about 17 names. When you file flight plate watt the flight 18 service station or via electronically, all they care 19 about is souls on board, contact information. flight 20 routing, things like that. 21 0. Are there time limits as to when the plane is 22 allowed to take off? 23 A. Yeah. usually -- From what point? What do 24 you mean? Time of the day or - 25 0. Yeah. yeah. time of the day. I understand 46 1 A. Well, and I don't know exactly. I 2 can't really say, really. 3 0. t won't hold you to N. his what 4 is. 4 Mid to late '90s, it I wanted the flight logs that have him on it, On the airplane, who would I 6 Subpoena to get those records? 7 A. I have no Idea. 0. Are they turned into the FAA, to the best of 9 your knowledge? 10 A. No, the FM doesn't require them. 11 0. So FM does not get the flight -- Well. what's 12 the point of even keeping these? 13 A. Sometimes I think the IRS I mean, this 14 is on assumption, rm not even sure, but mostly for 15 like IRS tracking ford you have people that have 16 dual homes, dual statehoods. or whatever. 17 (Mr. Goldberger entered.) le MR. GOLDBERGER: Can we take a time outs 19 (Shan break.) 20 (Mr. Pike appeared via telephone to 21 replace Mr. Goldberger.) 22 BY MR. EDWARDS: 23 0. FAA flight logs - do you know why they're 24 generated, how they're generated, 4 they were generated 25 back in the Wexner days? 1 2 3 4 S 6 8 9 10 11. 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 48 that there's some time where if it's too tate they can't take off, right? A. Only where there's a curfew on the airport - not all airports, no. No. airplanes can fly any time unless that airport has a noise curlew or something, yeah. 0. Did you ever know of Wexner's plane to take off after ten o'clock p.m.? A. Yes. Yeah. 0. Were you ever on that plane when it did? A. Probably. yeah, yeah. O. Were you ever on that plane when there were gds on the plane? A. Describe -- Define 'girls.' On the Wexner airplane? 0. Yes. A. There would be ladies and his daughters. I mean-- 0. Other than family members. A. There would be business associates. If you're taring young women, yes, business associates from the **visions. 0. Have you ever been on the plane when there were girlfriends of Leslie Wexner? A. Only when Abigail • before his • became 0 ESQUIRE CONFIDENTIAL Toll Free: Facsimile: Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com • • • 3501.150-002 Page 14 of 92 EFTA_00068806 EFTA01247034 Larry Eugene Morrison - Volume I October 6, 2009 • • 49 1 his bride. yes. 2 O. How about after -- 3 A. I moan 4 O. she became his -- 5 A. it was Abigail. She was the only 6 girlfriend. 7 O. How about after Abigail? e A. No. 9 O. Have you ever soon sox or sex-related 10 instances occur on Leslie Wexner's airplane? 11 A. Absolutely not. We didn't even have 12 playing cards. He looked at the aircraft as a 13 business - a flying business office. 14 O. When you say 'playing cards' what do you 15 mean? 16 A. Playing. you know. to -- 17 O. Oh, playing cards. 18 A. Yes, playing cards. 19 O. So every time that you were on Leslie Wexner's 20 airplane, it was used strictly for business? 21 A. Well, I don't know if it was used strictly 22 for business, but there was no. you know, it was -- I 23 don't know what the purpose of the actual trip was. 24 but never saw, you know, anything. you know. 25 O. Was there over a time when you were --5 1 1 O. Yes, with you on it. 2 A. I can't — I canl say. 3 O. Well, where do you remember going in it? 4 A. Well, we would normally go to London, 5 Milan. Fans. I mean, mostly fashion areas and 6 business business areas. O. When you say 'fashion areas,' what do you 8 mean? 9 A. Well, retail. I mean, you know. design 10 for clothing and stuff like that. 11 O. What was the purpose? 12 A. I'm sure it was business. I have no Idea 13 what the actual purpose was. I don't — 14 O. Did you get off the plane? 15 A. Well. of course. 16 O. What did you do there? 17 A. Go to a hotel, eat dinner, wait to find 18 out when you're going to the next place. 19 O. Were you ever on an international flight on 20 one of Mr. Wexner's planes that Jeffrey Epstein was also 21 on? 22 A. I can't say. I can't remember. 23 O. maybe/ 24 A. Possibly. 25 Cl. Do you remember any specific places that 50 1 MR. REINHART: Hold on. Were you 2 finished? 3 BY MR. EDWARDS: 4 O. I thought you wore finished. 5 A. Yeah. I don't tmderstand. I don't 6 understand that question. 7 O. I'm going to clarify. Wore there ever times 8 when you were on the plane and either Leslie Wexn