EFTA01110271.pdf

Larry Eugene Morrison - Volume I October 6, 2009 3 IN THE CIRCUIT CURT Ot mix 15Th JUDICIAL CIRCUIT :N 1 APPEARANCE OF COUNSEL AND POR PALM $111101 COUMTV, acistus 2 On tense of IM Defendant VOUR4R 1 92906 1 to 200 3 ATTERBURY.GOLC6ERGER & WEISS BY: JACK ALAN GOLDBERGER. ESO.. 4 250 Australlen Avenue Slate 1400 s Watt Palm Bach FL 33101 Plairkt1ff, 6 Case Up. 50200$CA024051 7 ELMS AD On behalf of the Defendant by telephone JIVVAIT OPOIZIK, BURMAN, CRITTOR LUTTIER & COLEMAN Mismiseat • 9 BY: Maimi J. PIKE. ESO.. 515 N. Realer Drive 10 Stale 400 DaPCSITICSI OP FL 33401 LARRY ~OS taitRISC44 13 Tiara Ott «ALF OP Ma PLUIPTIFF October 6, 1009 10;55 a.m. 2:20 p.a. 12 13 515 N. Plogler Drive On behalf of the sstness: West Palm Beach. PL. 13401-4321 14 LAW OFFICE OF BRUCE E RBA/HART Is BY: BRUCE E. REINHART, ESQ., Ono Cheripla Center 16 250 S. tentralan Avenue Jennif er Ditorenref, court reporter Suite 1400 17 F < 1 10 19 20 21 22 23 24 25 2 4 APPFARaNCES OF COUNSEL 1 INDEX OF EXAMINATION 2 On NMI ot ihe Pa tI LAI.: 2 BOTNSTEIN, ROSENFELDT1ADLER DY BRACA.EYJ EDWARD& ESO 3 WITNESS: 4 and L14CKAEL WHEELER En. 4 UM ," EUGENE MORRISON 401 East Las an 13001evard 5 Page S åM1650 6 DIRECT EXAMINATION Fo1LavarOcto FL 13194 By Mr. Edwards *5 CROSS-EXAMINATION On Napa«Plal1N14 Jan Doe 2 Ilaotga 5: 6 By Me. Ezell 6190 9 9 CROSS-EXAMINATION WRIMSTEIN HOROWITZ PA By Mr. Willits 1195 10 BY: JFccY•AO.ARBOL1RAl Nfri2NY4VNULW. 10 13205 Fkstayne ~lewd Il Sole 2210 CROSS-EXAMINATION 11 By Mr. Pew *196 12 12 FURTHER REDIRECT EXAMINATION 13 By Mr. Edwards #199 14 OnMIME ce~Sib Jane Doe 101 aria 102 at 13 ~O« 14 15 ~mum«°RUCK P A L 16 sY: KAINERINE W. EZELL, ATTORNEY-ANUPN 25W. Fis,er Steel 16 INDEX TO EXHIBITS La Plaintiff's 16 ia 1a Exhibit Description Page °et:eh:1o~PeINXICINA. by telepaon0 19 1 Twenty-four pages of 'JEGE, Inc., 20 Passenger Manifest." #138 LAW OFF« OF RICHARD %SLUTS. PA 20 21 BY: FtCHARO %SLUTS. ESQ. 2210 101,Mega N. 21 22 Stim 404 22 33451 23 23 24 (Plaintiffs Composite 1 was attached to the 24 original transcript and copies of the transcript.) 25 25 EFTA01110271 Larry Eugene Morrison - Volume I October 6, 2009 5 7 1 Deposition of LARRY EUGENE MORRISON 1 You know, it was a business decision made somewhere. 2 October 6.2009 2 O. What does the company do? 3 3 A. What? The company? It's Just a holding 4 THE REPORTER: Do you swear the testimony 4 company, I fink, for the aircraft. Its not -- I S you're about to give will be the truth, the 5 don't bSeve It to be a money making company or a 6 whole truth, and nothing but the truth so help 6 real corporation. 7 you God? 7 O. You're song `for the aircraft? rm 8 THE WITNESS: So help me God. a Interpreting that to mean you're talking about on, 9 -- 9 aircraft. 10 LARRY EUGENE MORRISON, having been first 10 A. Correct. 11 duly swam, was examined and testified as 11 Q. Does that mean there's one or there's more 12 follows: 12 than one? 13 DIRECT EXAMINATION 13 A. There's more. He owns more than one, but 14 BY MR. EDWARDS: 14 Just one is JEGE or -- is O. Tell us your name. 15 O. And the aircraft that he owns, how many of 16 A. Larry Morrison. 16 those do you either service and/or ride on? 17 Q. And. Larry, where are you employed right now? 17 A. I used to. I haven't been — Actually. I 18 A. For JEGE. 18 stepped back from being physically Involved, Just - 19 Q. What's JEGE mean? 19 now I Just do paperwodt - and It was February of 20 A. It's the aviation flight department for 20 2007. SO I haven't actually physically been on the 21 Mr. Epstein, and my primary Job Is Danklold Reed 21 airplanes other than I will take the Boeing for 22 Aviation. 22 maintenance. 23 MR. REINHART: Spell It. 23 Q. Since it seems tike we've kind of skipped 24 A. D-A-N-K-J-O-L-D, and then the second word 24 ahead from 2001 to 2007, am I right that your first 25 le Reed, R-E-E-D, Aviation. Ws a corporate flight 2s involvement with Jeffrey Epstein of any way, shape, a 6 8 1 department. 1 form was 2001? 2 Q. What do you do for him? 2 A. That's correct, yeah. 2 A. Director of Maintenance. 3 Q. You didn't meet him before that. 4 O. Okay, so you maintain his planes — 4 A. I had met him He was a — He was an 5 A. Correct. 5 associate of my previous bees. 6 Q. — should something go wrong? 6 O. Who's that? 7 A. Correct. Yes. Yep. 7 A Mr. Wexner. O. Do you also -- O. Leslie Wexner? 9 A. For maintenance. 9 A. Yes. 10 O. Do you also fly on his planes? 10 Q. How do you know Leslie Wexner? 11 A. On 1W. Epstein's? 11 A. I worked for Limited Stores for 12 years. 12 O. Yes. 12 O. Doing what? 13 A. I used to. I was a flight engineer 13 A. Essentially the sane thing - aircraft 14 O. Okay. What — 14 maintenance for their corporate flight department and 15 A — on his 727. 15 flight engineering on the 727. 16 Q. When you fist your company - JEGE? 16 O. How many aircraft did Leslie Wexner have? 17 A. Yes. Yeah. it's just initials. It's an 17 A. Weil, none that I know that he had 18 LLC or holding company. 18 personally, but the corporation had - the fight 19 O. How long has that holding company been around, 19 department operated - we had three Gulfstreams, two 20 If you know? 20 Hawkers, and a 727. 21 A. Since I think it was developed when I Q. What was the name of his corporation that 22 came with the airplane - 2001. 22 maintained the aircraft? 23 O. Whose Idea was it for that to come about -was 23 A. For Limited Stores? 24 it yours? Was It he? 24 Q. Yes. 25 A. Oh, no, no, somewhere - It wasn't mine. 25 A. It was just — It was called Limited - EFTA01110272 Larry Eugene Morrison - Volume I October 6, 2009 9 11 1 Limited Flight Department. 1 Q. Yes. 2 Q. And do you know him personally then Leslie 2 A. Aircraft technician. 3 Wexner? 3 Q. Which entails what? 4 A. Yeah, I had met him, of course, you know. 4 A. Maintenance of any or all of the aircraft 5 I met him. I used to do aircraft completions for 5 operated by the flight department and some flight 6 him, so which would involve personal meetings. 6 mechanic duties. 7 O. When did you first meet Leslie Wexner? 7 Q. What kind of airplanes? a A. 1988 was when I hired on, so I don't A. Gulfstreams, Hawkers. 9 remember the month. 9 Q. How big is the Gulfstream? 10 Q. How did you get that job? 10 A. Fifteen passenger -15 to 17. 11 A. Through word of mouth and, you know, I 11 (Mr. Goldberger (tilted.) 12 worked - I lived in - been in aviation for years in 12 BY MR. EDWARDS: 13 Columbus. 13 Q. What did Wexner use the Gulfstream for? 14 Q. Wee I mean, Leslie Wexners an important 14 A. They were division airplanes, mostly. 15 person. right? I mean. he — 15 Q And the other airplane you named - what did he 16 A. Correct 16 use that for? 17 MR. GOLDBERGER: Form. 17 A. Same. same. 18 BY MR. EDWARDS: 18 Q. Any idea why he had two planes? 19 Q. He's somebody who owns my understanding - 19 A. Well, I mean, yeah, we used them - Mafia 20 Limited, Victoria's Secret? 20 a loot h wasn't him. It was a large Fortune 500 21 A. Well, he doesn't own them. He's Chairman. 21 company. They use them as tools to — You know, 22 you know. 22 Lhnited has control over 60 percent of their 23 Q. Chairman of — 23 manufacturing processes, plus, you know, what.1200 24 A. Yeah. He doesn't personally own .1. It's 24 stores, or whatever, throughout all their divisions. 25 a publicly held company. 25 I mean, when you say 'limited' ire not 10 12 1 Q. Where were you prior to any involvement with 1 just Limited, ifs Victoria's Secret and it was 2 Leslie Wexner? 2 Express and Lemers and Henri Benders and all of 3 A. I worked for Red Roof Inn True Sports 3 that back then, so. I mean — 4 Flight Department. 4 Q. So — 5 Q. How did that position lead you to Leslie 5 A. — we moved a lot of passengers to keep 6 Wexner? 6 those stores for the retail business. 7 A. Well, it was always known that Limited Q. And by 'passengers." do you also mean clients 8 Right Department was one of the best jobs in 8 of his? 9 Columbus and, actually, several other people that 9 A. That I don't know. No. Mostly we just 10 were already there knew me from previous jobs and 10 dealt with upper echelon, you know, people in the 11 education - we went through aircraft mechanic, or AS 11 retail businesses from — 12 school. together - so when the position became 12 Q. Such as whom? 13 available they pointed to me and - absolutely. It 13 (Mr. Goldberger entered.) 14 was a fine organization. 14 A. Can't even remember names, but it would be 15 Q. So did I.Y. Wexner approach you or did you 15 -- We would take buyers to Europe in the spring and 16 apply to him or how did that work? 16 fall. They would buy samples and piing them back to 17 A. Oh, no, no, no. It's -- No. He wouldn't 17 analyze for marketing. We would hire — We would — 18 be involved in that type of activity. You apply to 18 Division heads, when they would do store shops and, 19 H.R. and you interview with the Director of 19 Real Estate, we take Real Estate out when they were 20 Operations or the Chief Pilot. You know, he 20 looking for new real estate. 21 wouldn't. 21 Q. While you were working back in '88 — Well, 22 0. So you start with Wexner in 1988. 22 how long overall did you work with Leslie Wexner and/or 23 A. Yes. 23 his companies? 24 O. What do you do for Nm then? 24 • Wen.738 through when I came here in 25 A What did l do for Nm? 25 January of '01. EFTA01110273 Larry Eugene Morrison - Volume October 6, 2009 13 15 1 O. Why the change? 1 aircraft. I mean, whatever It takes to keep a 2 A. It offered an opportunity — Well, one was 2 corporate flight department operating. 3 I enjoyed flying - and the 727 was being replaced by 3 Q. Did you know back then of his relationship, if 4 a BBJ, which is a two-man airplane, not a three-man 4 any, with Jeffrey Epstein? 5 airplane - three-pth3t airplane - and It gave me the 5 A. Not Immediately, no. 6 opportunity to become a Director of Maintenance. and 6 Q. When is the first time that you knew of a 7 it was a chaflenge. You know, bringing - upstarting 7 regulation or a relationship between Wexner and Epstear 8 an airliner on a private ticket or a VIP ticket is A. Would have had to probably be around maybe 9 really challenging. and I enjoy the challenge of 9 '98. 199. 10 waking and developing the program and stuff. 10 Q. How do you become aware that they know one 11 O. Well my understanding. Leslie Wexner is 11 another? 12 generally - he's in Ohio, right? 12 A. Because Jeffrey. every one — That's when 13 A. No, he's got other places. I mean — No, 13 I became a flight engineer on the Boeing, and every 14 he's like anyone, he's - in his category • he's got 14 once Ina while Jeffrey would ride on the Boeing. 15 multiple homes and — 15 that's al that's al l knew. 16 Q. Wee, when you would maintain his aircraft, 16 Q. How did it come about that he would ride on 17 would that be in Ohio — 17 Wexner's Boeing? 18 A. Yes. We were based - 18 A. They were business associates. I think. 19 Q. or elsewhere? 19 Q. As far as you know, they were business 20 A. We were based at Lane Aviation. 20 associates. 21 MR. REINHART: Hold on one second. You 21 A. Right. 23 have to let him finish asking the question 22 Q. DM you understand the business relationship 23 before you answer. 23 between the two? 24 THE WITNESS: Okay. rm sorry. 24 A. Well, I believe it's pubic knowledge as BY MR. EDWARDS: 25 that, I think, Jeffrey managed Mr. - some of Mr 14 16 Q. I'm sorry, have you ever had your deposition 1 Wexner's funds. 2 taken before? 2 Q. Is that something that Mr. Wexner told you? 3 A. No. 3 A. No. 4 Q. You definitely never had your deposition taken 4 Q. Is that something that somebody of Mr. 5 before while somebody else is trying to eat at the same 5 Wexner's organization would have told you? C time they're trying to ask the questions - that's very 6 A. No. 7 bizarre. 7 a Is that something that Jeffrey Epstein told A. Yes, yes. 8 you? 9 O. I meant to do this before I got here. But, 9 A. No. 10 regardless, II wait until you finish your answer before 10 Q. Is that just reading articles that speculate 11 I ask my next question: you do the same thing. 'U .-huh' 11 as to the business relationship between the two or do you 12 or -uh•eh," they kind of look the same on the record. so 12 got something more for me? 13 try to give us a "yes" or *no- or something we 13 A. No, it's Just - It's speculation and, you 14 understand. 14 know, what I've read, you know. 15 A. Alright. 15 Q. I mean, like you say, to me Ifs common 16 Q. If I ask a question that was a bad question or 16 knowledge — 17 something you don't understand - I've asked bad questions 17 A. Right. 18 before - say., don't get it." 171 ask a better 18 Q. But it's only because of vital I've read. I 19 question. 19 don't have a specific person that I could cite to to say 20 A. Okay. 20 that, do you? 21 Q. You were working with Lee Wexner. You got 21 A. Right. No, Just- just periodicals. 22 the job there starting in 1988. On a day-to-day basis, 22 O. What's your understanding of the personal 23 what would you be doing? 23 relationship, if any. between Wexner and Epstein? 24 A. Maintenance, aircraft maintenance, 24 MR. GOLDBERGER: Form. 25 tracking of aircraft maintenance, cleaning of as A. Don't know. EFTA01110274 Larry Eugene Morrison - Volume I October 6, 2009 17 19 Q. Did you ever know of a time — And I maybe 1 0. Have you spoken personally with sic. Wexner? 2 asking a question that would just be completely outside 2 A. On business issues, yes. 3 of your knowledge. so let me back up. 3 Q. Business issues related to your work on his 4 Have you ever stayed at Leslie Wexners house? 4 airplanes? 5 A. No. A. Correct. 6 Q. Do you know where his house is? 6 O. Have you spoken to him on any ether issues 7 A. Yes. 7 that don't involve business relationships with his 0. Do you know what the address is in Ohio? airplanes? 9 A. No, I just know the city. 9 A. No. 10 Q. Do you know who he lives with? 10 0. Because you're hired basically for that 11 A. Yes. 11 purpose. so that's kind of how you deal wqh him. 12 Q. Who is that? 12 A Yeah. Ws rm an employee and he's my 13 A. His wife and children. 13 employer and I only deal with rim, you know, on 14 Q. What's his wife's name? 14 Issues that Involve maintenance. 15 A. Abigail. 15 0. I think I probably know the answer to the nod 16 Q. Abigail Wexner, and he has three or tour 16 question. but just in case I dont, do you know any of 17 daughters, right? 17 his personal friends people that he would hang out with 18 A. No. He's got a son, Harry, and two 18 on a social level - being Mr. Wexner? 19 daughters, I think. 19 A. Through my business ties, yes, yes. 20 Q. A son and two daughters. 70 O. Who's that? 21 A. I don't know. See, that was back in 2001. 21 A. rm trying to remember — You have to 22 I don't know what they have - II they have more kids 72 remember it's been several years. 23 23 0. right. 24 0. Okay. Did you ever hew any information that 24 A. He was Mends with the Tuckermans. 25 he was homosexual? 25 a What's Mr. Tuckerman or Ms. *Nachman's naives? 18 20 1 A. No. A. Ms. — I cant I akvays addressed them 2 0. Being Mr. Wexner. 2 by their proper name. 3 A. No. 3 0. Cope know what they do? 4 Q. Any indication to you that he may be 4 A. They owned an optical company - opticians. s homosexual or bisexual? 5 They were high school friends from Mr. Wexreesh oh 6 A. Absolutely not 6 school days. 7 Q. Have you heard any information that he and Mr. 7 0. In Ohio or New York? 8 Epstein were Involved sexually with one another? a A. He went to high school in Bexley. 9 A. Oh, no, no. 9 O. Bexley. Ohio. 10 0. Would that surprise you? 10 Has he ever discussed with you how 11 A. Absolutely. 11 longstanding the relationship Is between himself and Mr. 12 0. And that's only because you know him and you 12 Epstein? 13 know Mr. Wexner and you don't see the two together. 13 MR. GOLDBERGER: Form. 14 A. Correct. 14 A. I don't understand. Can you reptvase it? is MR. GOLDBERGER: Finn. 15 Q. Wel. you know that at some point In time - 16 A. Wel — 16 You started working with him in 1988. The first time, 17 0. He — 17 according to my notes. that you became aware that he was le A. Go ahead. 18 Mends or acquaintances with Mr. Epstein was '98 - 19 MR. REINHART: If you need to answer. 19 almost ten years later. 20 answer the question. 20 A. Right. 21 A. Yeah. No. I saw him with Sharon, which 21 Q. After you became aware that there was that 22 was his previous girlMend before he met Abigail. 22 relationship, whether business or otherwise, did he ever 23 0. Right. 23 speak to you about how long he had know, Mr. Epstein? 24 A. No. There was never any hint or anything 24 A. Oh, no. no. 25 that I would even conceive that. 25 Q. So as far as you were concerned, 1998. when EFTA01110275 Larry Eugene Morrison - Volume I October 6, 2009 21. 23 1 you found out there was a relationship with Epstein, it 1 O. Who were some of the pilots? 2 could have very well started then. 2 A Tim Staley, Jim Taylor. They've had some 3 A. Yes. 3 turnover too. I don't know who all is still there 4 Q. Aside from aircraft technician and taking care 4 because retail is down. of Pitt Wexner's aircraft back in the '80s and, I guess, 5 O. Was Larry Visosid a pilot used by Leslie 6 early '90s. did you have any other personal involvement 6 Warner at any time? 7 wilt) him? 7 A. No. 8 A. Just on aircraft completions. a Q. How about David Rodgers? 9 Q. And when you would speak with him, would that 9 A. No. 10 be over the telephone, at the airport, at his private -- 10 Q. Are those names you're familiar with? 11 A. It would usually be at the corporate 11 A. Yes. 12 office. 12 O. Those are names you're familiar with how? 13 Q. At the corporate office? 13 A. I flew with them when 1 was flying for Mr. 14 A. At the corporate office. 14 Epstein. 15 Q. Can you tell me the address for his corporate 15 Q. So there's no real, other than yourself -- 16 office? 16 Well, tell me if I'm wrong: I understand that you did 17 A. No, I cant 17 some work for Mr. Weiner related to his aircraft and you 18 Q. If I requested that from your attorney. would 18 did some work for Mr. Epstein, which we haven't yet got 19 you be able to get that information? 19 to, but you did some work for him too. Are there any 20 A. Weal mean, I imagine it's public 20 other people that have that type of relationship with 21 knowledge - wherever - it's at the Limited. 21 both parties? 22 Q. And Mars where you would meet him - at the 22 A. No. I'm sorry, resay that. 23 United? 23 Q. Okay. You've already told us that you were 24 A. Yeah. 24 the aircraft technician for Mr. Werner. 25 Q. And how Often was - you know, I know that 25 A. One of them. One of several, yes. 22 24 1 we're talking about 15, 20 years ago • how often was Mr. 1 Q. One of them. Then you also have knowledge 2 Wexner personally at that location at the Limited 2 about Mr. Epstein and some relationship with Mr. Epstein 3 offices? 3 A. Correct. 4 A. I have no idea. 4 O. Are there any other pilots. aircraft 5 Q. But any time you needed to talk to him, that's 5 technicians, people like that that you know of to have a 6 where he would be? 6 relationship with both Mr. Wexner and Epstein? 7 A. Yeah, and I usually went to Charlie 7 A. No, no. 8 Hinson. 8 Q. Do you know how Mr. Weimer met Mr. Epstein, 9 Q. Who's Charlie Hinson? 9 A. No. 10 A. He was the president of the stores. He 10 Q. How long - if you started in 1988 - how long 11 basically was my go-between for these aircraft 11 did you stay with Mr. Wexner and/or The Limited? 12 completions for the design. 12 A. January of '01. 13 O. And you mentioned the Gulfstream as an 13 Q. Why did you stop? 14 aircraft Did you also serve as a technician for other 14 A. Because what we were taking before, you 15 aircrafts that were owned by Mr. Wexner? 15 know, I wanted to continue flying. They bought a 16 A. Right but not Mr. Wexner. They're owned 16 BBJ, which is a two-pilot aircraft, and I wanted to 17 or operated by Limited Stores. 17 continue flying. Mr. Epstein bought the 727 and 18 Q. Limited Stores? 18 offered me a position to continue flying and, you 19 A. Right. Yes. 19 know, basically set up the airplane for his flight 20 Q. What did you do for them? 20 department because they hadn't had any previous large 21 A. Same - maintenance. 21 aircraft experience. 22 Q. Did you ever fly in them? 22 Q. I missed something. It wasn't your fault, it 23 A. On the Gulfstreams in the early days we 23 was ITWOO. 24 used flight mechanics, especially on international 24 The Gulfstream that you were taking about, 25 flights. 25 did you used to fly that as well as being a light EFTA01110276 Larry Eugene Morrison - Volume October 6, 2009 25 27 1 technician? 1 Q. Do you know why Epstein chose to buy that 2 A. No, no. 2 particular 727 rather than one of the other mum 727s 3 Q. Okay. 3 that are made? 4 A. You don't have to have a flight - a 4 MR. GOLDBERGER: Form. 5 pilots certificate to be a professional flight 5 A. Because It was probably the finest one out 6 ()Vow. I've got a turbo - a flight engineer turbo 6 there -- 7 jet rating, but you don't have to have a commercial 7 Q. Why? ticket as long as you - the FAA recognizes your heavy A. -- in as honesty. Its got a fully Paged 9 aircraft maintenance experience. 9 SIC interior with EFTS cockpit, and Limited's 10 Q. So you're saying that if the FM recognizes 10 reputation on the way that we maintained our aircraft 11 your heavy maintenance experience, I'm assuming that 11 - It's the best one out there. 12 means that you understand the ins and outs of airplanes 12 Q. Describe for me the interior - not talking 13 and you can work on them. 13 about the Epstein days, we're talking about the Wexner 14 A. On heavy high performance aircraft, yes. 14 days - describe for me the interior of the aircraft, and 15 0. Then you can also fly them? 15 keep in mind that I've only been on a commercial aircraft 16 A. Sideways as a flight engineer. 16 where you don't see the pilots, there's a door, and then 17 Q. Explain. 17 everybody, you know, there's just a bunch of seats where 18 A. On the older generation airliners there 18 everybody sits there. 19 was three pilots - there's a captain, a first 19 A. Correct. Right. 20 officer, and then the flight engineer is the 20 The aircraft — You enter the airplane, 21 gentleman that sits sideways and maintains all the 21 It's got forward air stays, which most 727's don't, 22 systems. 21 so you enter the forward door on the left-hand side, 23 Q. When you say. 'sits sideways? okay, I have 23 the forward entnAvay vestibule, and there's a door on 24 a— 24 the left, which leads to the cockpit, and then 25 A. Literally, you're physically sideways in 25 there's a door on the right which leads aft to the 26 28 1 the cockpit 1 forward salon. 2 0. So you're not Looking at the people that were 2 Q. What's the forward salon? Sorry. 3 flying on the plane and you're not looking at the pilots, 3 A Forward seating area. 4 you're actually literally sitting sideways. 4 O. And is it set up basically the way that I'm 5 A. I sit sideways at a panel, yes. 5 picking ft - in that there are 25 or 26 rows and theyre 6 Q. What's your job? 6 numbered A through E? 7 A. Maintain all the aircraft systems - the 7 A. No, no, it's a corporate configuration. 8 hydraulics, fuel management, pressurization, a Q. Which means nothing to me, so help me. 9 environmental controls. 9 A. Picture a 600-mile an hour Winnebago. I 10 Q. That's not done by the pflotS. 10 mean, it's got conference tables and divans and large 11 A. No, no. 11 first class seating. 12 0. But if you've done that long enough and FAA is 12 Q. Any various dividers throughout — 13 aware d your credentials in that respect, then you also 13 A. Yes. 14 could be credentialed to be a pilot as well? 14 Q. — to where there's a VIP room in the back or 15 A. Well. sure, yeah, yeah. if that's a 15 anything like that? 16 career choice you wish to take. 16 A. ft's compartmentized (sic), yes. 17 Q. And was that? 17 Q. In what way? Describe it as specifically as 18 A. No, no. I was perfectly satisfied with my 18 you can. 19 position as a flight engineer and Director of 19 A. There's a forward salon, a mid galley - 20 Maintenance. 20 the galays in the mld - an aft - an aft salon, 21 0. What year did you say Epstein bought the 727 21 which is - and then the aft state room. 22 that was once owned by Wexner? 22 Q. Who designed that plane? 23 A. I don't know when the actual transition 23 A. I can't remember who the actual designer 24 took place, but when I came - shortly around the 24 was. it was a Page interior, though. Page Avjet did 25 period that I Caine on board in '01, January of '01. 25 the installation. EFTA01110277 Larry Eugene Morrison - Volume : October 6, 2009 29 31 1 Q. Who directed the design of that plane? 1 because obviously there's a lot - there's not that 2 A. It would have been Mr. Wexner. I mean, It 2 3 was — The layout has not changed. 3 A Privately owned 727s, but this is — As a 4 O. 'The layout has not changed' when you say 4 matter of fact. The Limited's current BBJ has a very 5 that, you mean 'from the time that I first got in it and 5 similar floor plan. 6 I was under the guise or - "under the employment of 6 O. As Trump's? 7 Wexner to the time I've been on it since with Epstein, 7 A. No, as the -as ow 727. the oon5guratlon is the same." Q. Who's "our? 9 A. Essentially. yes. We removed one chair 9 A. Mr. Epstein's. They didn't change a lot. 10 and one small table that was an annoyance and that's 10 It's — 11 It. but Its identical to what The Limited used. 11 O. Well, I thought that you had told me that the 12 Q. Are there any blocked off areas to where if 12 727 that was once owned by Wexner is the 727 that's armed 13 you're standing in the middle of the plane you can't see 13 by Epstein. 14 certain areas of the plane? 14 A. It is, but what I'm saying Is even their 15 A. There are pocket bulkheads. Yeah, there's 15 current airplane has the same layout - the BBJ. They 16 dividers between the seat:Ina. 16 put the same floor plane in the more modern airplane 17 Q. How big are these cflviders and where aro they? 17 O. Well, they Mat have to put n there. It 18 A. Well, there's a divider - the forward 18 was already there, right? 19 door, I told you, on the salon, then there's a pocket 19 A No, no, no. When you buy these aircraft - 20 door on the forward side of the galley. a pocket door 20 oven a Gulfstream Mien you buy them it's just a 21 on the aft side of the galley, there's a pocket door 21 green hull, there's nothing in them, and you can 22 between the aft salon and the office, and then 22 customize your Interior. 23 there's another pocket door between the office and 23 O. rm soy, we're miscommunicallrg somewhere. 24 the state room. 24 and I'm sure its on me. 25 O. Have you been on other 727s before that are 25 MR. GOLDBERGER: Yes, It is. 30 32 1 commercial airliners privately owned? 1 MR. EDWARDS: And I'm taking the dame for 2 A. Yes. yes. 2 it - right away. 3 Q. Have you noticed similar configurations to 3 MR. REINHART: Take that. Ed. 4 where there are this many divicfrig doors or is this one 4 MR. EDWARDS: Alright. S that has more so than you've seen In the past? 5 BY MR. EDWARDS: 6 A. No, no, this Is pretty atypical (sic). 6 O. My understanding - and piano correct me when 7 Q. It's pretty atypical? 7 Mt wrong, because I know I am - Wexner has this 727 and $ A. It's typical. 8 he designs it in a certain way. 9 O. It's pretty typical? 9 A. Uh-huh. 10 A. Yes, yes. 10 Q. And then you come to work for Epstein — 11 Q. So what other airplanes - 727s, or other Maier 11 A. Yes. 12 airplanes - have you been on that have these types of 12 Q. — vitro buys the same 727. Your testimony. as 13 dividers? 13 I'm understanding it, is: It's basicaly the same floor 14 A. Trump. 14 plan as Wexners Poor plan. To me, it should be the 15 Q. Trump's airplane? 15 exact same because he bought the same plane. 16 A. Yes. 16 A. No, he — You're misunderstanding. 17 O. Why were you on Trump's airplane? 17 O. I figured. 18 A. Weil, I know the crew and, you know, this is A. VVhat I was stating is — You were — Ines 19 is a small-knit community. There's not very many of 19 answering the question in regards to. "Is this 20 them out there, so everybody in this world knows one 30 unusual to have this many compartments and closed 21 another to help one another out as far as — 21 doors and bulkheads and things?' 22 Q. By "there" — 22 What I was trying to state was: No, ins 23 A. — b its motiun-wise and stuff. 23 not unusual - because The Limited even Sited Ihe 24 Q By 'there aren't that many of these people out 24 floor plan solemn in their old airplane that they 25 there; you don't mean there's not that many people - 25 sold to Mr. Epstein. They duplicated it in their new EFTA01110278 Larry Eugene Morrison - Volume I October 6, 2009 33 35 I airplane - see what I'm saying? That's all l was — 1 had a very identical or very like floor plan 2 Q. So they didn't keep the floor plan. They 2 installed in the new airplane. 3 actually took it out and they restructured the floor plan 3 O. Got it. 4 to basically match that old floor plan. 4 A. Okay? Sony, ifs a strange business. 5 A. Well, no. When you -- When you buy a It's — 6 Boeing business jet -- a O. Tell me if I'm right: Mr. Wexner had a plane 7 Q. Yes. 7 that had a floor plan that apparently appealed to Mr. A. — It comes with nothing inside. It's a 8 Epstein. so Mr. Epstein bought that plane. 9 tube. Nothing's in there. You design - have 9 A. Correct. 10 designers design your interior and then a fabricator 10 Q. Mr. Wexner also liked that plane that he had 11 or a facility such as Page Avjet to instal this 11 Just sold to Mr. Epstein, so he built in a floor plan 12 interior. 12 very similar to the one he just sold to Mr. Epstein. 13 Q. Right 13 A. In his new aircraft. 14 A. What I was Just trying to state was that 14 O. Brand new plane. 15 The Limited liked their old floor plan in the old 15 A. Correct. 16 airplane so well - it worked so well for them - that 16 O. Got h. We're on the same page now. 17 they duplicated it and had that same interior 17 A. Alright 113 installed in the new aircraft - same floor plan 18 O. Took us a while to get there. 19 installed on the new plan. 19 A. Yeah, sorry. 20 Q. So Epstein didn't buy the exact same plane. 20 Q. I think it was my fault, honestly, but 21 He bought the same type of plane. 21 alright? 22 A. Well, more modern. He bo