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• IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY, FLORIDA
L.M.,
Plaintiff,
vs. Case No. 502008CA028051
XXXXMB AD
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
LARRY EUGENE MORRISON
TAKEN ON BEHALF OF THE PLAINTIFF
VOLUME I
Pages 1 to 200
October 6, 2009
10:55 a.m.
515 N. Flagler Drive
West Palm Beach, FL 33401-4321
court reporter
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EFTA00181381
Larry Eugene Morrison - Volume I October 6, 2009
1 3
• IN /NS CIRCUIT COURT Of TAR 15Th JUDICIAL CIRCUIT IN
AND PM PAIN BRACH COUNTY. FLORIDA
VOLONE I Pages 1 to 200
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APPEARANCE OF COUNSEL
On behalf of the Defendant
ATTEFOURY. GOLDBERGER A WEISS
BY: JACK ALAN GOLDBERGER. ESO..
250 Australian Avenue
Suite 1400
5 act. FL 33401
Plaintiff. I 6
/Case No. 5020006020051
IX/WM AD On behalf of the Defendant by telephone:
JRFPRRY DITHER. e
BURMAN. CRITTON. LUTTIER & COLEMAN
Defendant . I 9 BY: MICHAEL J. PIKE. ESO..
515 N. Fla or Drtve
10 Suito 400
DEPOSITION OF lm ad,. FL 33401
LARRY MAUNA NORAISON 11
TAKEN On SHALT OF INA PLAINTIFF
October 4. 2009 12
10/59 a.m. - 2/20 p.m. 13
On behalf of the witness:
515 X. ?kegler Drive
Nest Palm Beach, FL 13401.4121 14
LAW OFFICE OF BRUCE E. REINHART
15 BY: BRUCE E. REINHART. ESO..
One Clearleke Cantor
16 250 S. Australian Avenue
Suite 1400
court reporter 17 &ch. FL 33401
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APPEARANCES OF COUNSEL
On banal a the Flambe L.M..
ROTHSTEIN. 110SENFELDT a ADLER
BY: BRADLEY J. EDWARDS. ESO.
111X1MICHAEL WHEELER. ESO..
401 East Las OHS 130.40Velt1
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WITNESS:
INDEX OF EXAMINATION
LARRY EUGENE MORRISON
Page
S41[91650 6 DIRECT EXAMINATION
ran Lo, ie. FL 31394
By Mr. Edwards #5
7
CROSS-EXAMINATION
s By Ms. Ezell *190
On betel d Planter Jane Doe 2 through
T 9 CROSS-EXAMINATION
mERUELSTE1N 6 HOROWITZ. PA By Mr. Willits #195
10 BY: JESSICA D. ARBOUR. ATTORMEY.AT4AW. 11)
19205 Beware Boulevard
11 Suite 2218 CROSS-EXAMINATION
Men. 1-1. 33160 11 By Mr. Pike N196
12 12 FURTHER REDIRECT EXAMINATION
By Mr. Edwards #199
li On Denali of mantes Jane Doe 101 aro 102 by 13
telephone: 14
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PODHURST ORSECK PA 15
16 BY: KATHERINE W. EZELL. ATTORNEY.ATiLAW.
25 W. Ragier Street 16 INDEX TO EXHIBITS
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Plaintiffs
IS Page
18 Exhibit Desolation
On banal of me Plartlf C.MA by telapheac 19 1 Twenty-four pages of 'JEGE. Inc..
20 Passenger Manifest.' *138
LAW OFFICE OF RICHARD WILLITS. PA 20
St BY: RICHARD WILLITS. ESO.. 21
2290101h Avenue N.
21 Suite 404 22
Laks Worm 33481 23
21 24 (Plaintiffs Composite 1 was attached to the
25 original transcript and copies of the transcript.)
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Larry Eugene Morrison - Volume I October 6, 2009
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Deposition of LARRY EUGENE MORRISON
October 6. 2009
THE REPORTER: Do you swear the testimony
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You know. it was a business decision made somewhere.
O. What does the company do?
A. What? The company? It's just a holding
company, I think, for the aircraft. It's not -- I
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5 you're about to give will be the truth, the 5 don't believe it to be a money making company or a
6 whale truth. and nothing but the truth so help 6 real corporation.
7 you God? 7 O. You're saying 'tor the aircraft* I'm
8 THE WITNESS: So help me God. 8 interpreting that to mean you're talking about one
------- 9 aircraft.
10 LARRY EUGENE MORRISON, having been first 10 A. Correct.
11. duly sworn, was examined and testified as 11 O. 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 justoneis JEGE Of --
15 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 O. 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 O. What's JEGE mean? 19 now I just do paperwork • 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 Dankjold Reed 21 airplanes other than I will take the Boeing for
22 Aviation. 22 maintenance.
23 MR. REINHART: Spell it. 23 O. Since it seems like 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 is Reed, R-E-E-D. Aviation. Its a corporate flight 25 involvement with Jeffrey Epstein of any way, shape, or
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department.
O. What do you do for him?
A. Director of Maintenance.
O. Okay, so you maintain his planes --
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form was 2001?
A. That's correct, yeah.
O. You didn't meet him before that.
A. I had met him. He was a -- He was an
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5 A. Correct. 5 associate of my previous boss.
6 O. should something go wrong? 6 O. Who's that?
7 A. Correct. Yes. Yep. 7 A. Mr. Wexner.
8 O. Do you also — 8 O. -Wexner?
9 A. For maintenance. 9 A. Yes.
10 O. Do you also fly on his planes? 10 O. How do you know Wexner?
11 A. On Mr. 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 same 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 O. When you list your company - JEGE? 16 O. How many aircraft did Wexner have?
1? A. Yes. Yeah, ifs just initials. It's an 17 A. Well, none that I know that he had
18 LLC or holding company. 18 personally, but the corporation had - the flight
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 21 O. 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 his? 24 O. Yes.
25 A. Oh, no. no, somewhere -- It wasn't mine. 25 A. It was just -- It was called Limited -
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Larry Eugene Morrison - Volume I October 6, 2009
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Limited Flight Department.
O. And do you know him personally then --
Wexner?
A. Yeah, I had met him, of course, you know.
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O. Yes.
A. Aircraft technician.
O. Which entails what?
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 Wexner? 7 O. What kind of airplanes?
8 A. 1988 was when I hired on, so I don't 8 A. Gulfstreams, Hawkers.
9 remember the month. 9 O. How big is the Gulfstream?
10 O. How did you get that job? to A. Fifteen passenger - 15 to 17.
11 A. Through word of mouth and, you know. I 11 (Mr. Goldberger exited.)
12 worked - I lived in - been in aviation for years in 12 BY MR. EDWARDS:
13 Columbus. 13 O. What did Wexner use the Gulfstream for?
14 O. Well, I mean, I= Wexner's an important la A. They were division airplanes. mostly.
15 person, right? I mean, he -- 15 O. 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 O. Any idea why he had two planes?
19 O. He's somebody who owns - my understanding - 19 A. Well, I mean, yeah, we used them - they're
20 Limited, Victoria's Secret? 20 a tool. It 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 Limited has control over 60 percent of their
23 O. Chairman of -- 23 manufacturing processes. plus, you know, what, 1200
24 A. Yeah. He doesn't personalty own it. It's 24 stores, or whatever, throughout all their divisions.
25 a publicly held company. 25 I mean, when you say "Limited,* it's not
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O. Where were you prior to any involvement with
MI Wexner?
A. I worked for Red Roof Inn True Sports
Flight Department.
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just Limited, d's Victoria's Secret and it was
Express and Lemers and Henri Benders and all of
that back then, so, I mean --
O. 50 —
5 O. How did that position lead you to 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 7 O. And by *passengers.' do you also mean clients
8 Flight 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 A&P 11 retail businesses from --
12 school, together - so when the position became 12 O. Such as whom?
13 available they pointed to me and - absolutely. It 13 (Mr. Goldberger entered.)
14 was a line organization. 14 A. Can't even remember names, but it would be
15 O. So did Mr. Wexner approach you or did you is -- 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 bring 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 O. While you were working back in '88 -- Well,
22 O. So you start with Wexner in 1988. 22 how long overall did you work with Wexner and/or
23 A. Yes. 23 his companies?
24 O. What do you do for him then? 24 A. Well, '88 through when I camp hero in
25 A. What did I do for him? 25 January of '01.
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O. Why the change?
A. It offered an opportunity -- Well, one was
I enjoyed flying • and the 727 was being replaced by
a BBJ, which is a two•man airplane, not a three-man
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aircraft. I mean, whatever it takes to keep a
corporate flight department operating.
O. Did you know back then of his relationship, if
any, with Jeffrey Epstein?
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5 airplane - three-pilot airplane - and it gave me the 5 A. Not immediately, no.
6 opportunity to become a Director of Maintenance, and 6 O. When is the first time that you knew of a
7 it was a challenge. You know, bringing - upstaging 7 reputation or a relationship between Wexner and Epstein?
8 an airliner on a private ticket or a VIP ticket is a A. Would have had to probably be around maybe
9 really challenging, and I enjoy the challenge of 9 '98, 99.
10 working and developing the program and stuff. 10 O. How do you become aware that they know one
11 O. Well, my understanding, 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 in a while Jeffrey would ride on the Boeing,
15 multiple homes and -- 15 that's all • that's all I knew.
16 O. Well, when you would maintain his aircraft, 16 O. 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 O. Or elsewhere? 19 O. 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.
22 have to let him finish asking the question 22 O. Did you understand the business relationship
23 before you answer. 21 between the two?
24 THE WITNESS: Okay. I'm sorry. 24 A. Welk I believe it's public knowledge
25 BY MR. EDWARDS: 25 that, I think, Jeffrey managed Mr. • some of Mr.
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O. I'm sorry, have you ever had your deposition
taken before?
A. No.
O. You definitely never had your deposition taken
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Wexner's funds.
O. Is that something that Mr. Wexner told you?
A. No.
O. Is that something that somebody of Mr.
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5 before while somebody else is trying to eat at the same 5 Wexner's organization would have told you?
6 time they're trying to ask the questions that's very 6 A. No.
7 bizarre. 7 O. 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. Ill wail until you finish your answer before 10 O. Is that just reading articles that speculate
11 I ask my next question; you do the same thing. 'Uh-huh' 11 as to the business relationship between the two or do you
12 or 'uh-uh.' 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 O. I mean, like you say, to me it's common
16 O. II I ask a question that was a bad question or 16 knowledge --
19 something you don't understand - I've asked bad questions 17 A. Right.
18 before • say, I don't gel it? I'll ask a better 18 O. But It's only because of what 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 O. You were working with = 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 25 A. Don't know.
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O. Did you ever know of a time -- And I may be
asking a question that would just be completely outside
of your knowledge, so let me back up.
Have you ever stayed at Wexner's house?
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O. Have you spoken personally with Mr. Wexner?
A- On business issues, yes.
O. Business issues related to your work on Ns
airplanes?
5 A. No. 5 A. Correct.
6 O. Do you know where his house is? 6 O. Have you spoken to him on any other issues
7 A. Yes. 7 that don't involve business relationships with his
8 O. Do you know what the address is in Ohio? a airplanes?
9 A. No. I just know the city. 9 A. No.
10 0. Do you know who he lives with? 10 O. Because you're Nred basically for that
11 A. Yes. 11 purpose, so that's kind of how you deal with him.
12 O. Who is that? 12 A. Yeah. Ifs I'm an employee and he's my
13 A. His wife and children. 13 employer and I only deal with him. you know. on
14 0. What's his wiles name? 14 issues that Involve maintenance.
15 A. Abigail. 15 O. I think I probably know the answer to the next
16 O. Abigail Wexner, and he has three or four 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. Has 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 O. A son and two daughters. 20 O. Who's that?
21 A. I don't know. See. that was back in 2001. 21 A. I'm trying to remember -- You have to
22 I don't know what they have - if they have more kids 22 remember ifs been several years.
23 23 O. Right.
24 O. Okay. Did you ever hear any Information that 24 A. He was friends with the Tuckennans.
25 he was homosexual? 25 O. What's Mr. Tuckerman or Ms. Tuckerman's names?
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A. No.
O. Being Mr. Wexner.
A. No.
O. Any indication to you that he may be
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A. Ms. -- I caret I always addressed them
by their proper name.
O. Do you know what they do?
A. They owned an optical company - opticians.
5 homosexual or bisexual? They were high school friends from Mr. Wexner's high
6 A. Absolutely not. 6 school days.
7 O. Have you heard any information that he and Mr. 7 O. 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 O. 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 O. And Mats only because you know him and you 12 Epstein?
13 know Mr. Wexner and you don't see the Iwo together. 13 MR. GOLDBERGER: Form.
14 A. Correct. 14 A. I don't understand. Can you rephrase it?
15 MR. GOLDBERGER: Form. 15 O. Well, you know that at some point in time -
16 A. Welt - 16 You started working with him in 1988. The first time.
17 O. He -- 17 according to my notes. that you became aware that he was
18 A. Go ahead. 18 friends 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 O. After you became aware that there was that
22 was his previous girlfriend before he met Abigail. 22 relationship, whether business or otherwise, did he ever
23 O. Right. 23 speak to you about how long he had known 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 O. So as far as you were concerned, 1998, when
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Larry Eugene Morrison - Volume I October 6, 2009
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you found out there was a relationship with Epstein. it
could have very well started then.
A. Yes.
O. Aside from aircraft technician and taking care
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O. Who were some of the pilots?
A. Tun Staley. Jim Taylor. They've had some
turnover too. I don't know who all is still there
because retail is down.
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5 of Mr. Wexner's aircraft back in the '805 and, I guess. 5 O. Was Larry Visoski a pilot used by MI
6 early '90s, did you have any other personal involvement 6 Wexner at any time?
'7 with him? 7 A. No.
8 A. Just on aircraft completions. O. How about David Rodgers?
9 O. And when you would speak with him, would that 9 A. No.
10 be over the telephone. at the airport. at his private -- 10 O. Are those names you're familiar with?
11 A. It would usually be al the corporate 11 A. Yes.
12 office. 12 O. Those we names you're familiar with how?
13 O. Al the corporate office? 13 A. I flew with them when I was flying for Mr.
14 A. At the corporate office. 14 Epstein.
15 O. Can you tell me the address for his corporate 15 O. So there's no real, other than yourself
16 office? 16 Welt, tell me if I'm wrong: I understand that you did
17 A. No, I can't. 11 some work for Mr. Wexner related to his aircraft and you
18 O. If I requested that from your attorney, would Is 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. Well, I 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 O. And that's where you would meet him • at the 22 A. No. I'm sorry, resay that.
23 Limited? 23 O. Okay. You've already told us that you were
24 A. Yeah. 24 the aircraft technician for Mr. Wexner.
25 O. And how often was • you know, I know that 25 A. One of them. One of several, yes.
22 24
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we're talking about 15, 2O years ago - how often was Mr.
Wexner personally at that location at the Limited
offices?
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O. One of them. Then you also have knowledge
about Mr. Epstein and some relationship with Mr. Epstein.
A. Correct.
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4 A. I have no idea. 4 O. Are there any other pilots, aircraft
S O. 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 A. No, no.
8 Hinson. 8 O. Do you know how Mr. Wexner met Mr. Epstein?
9 O. Who's Charlie Hinson? 9 A. No.
10 A. He was the president of the stores. He to O. How long - if you started in 1988 • how long
11 basically was my gobehveen 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 Gullstream as an 13 O. Why did you stop?
14 aircraft. Did you also serve as a technician for other 14 A. Because what we were talking 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 O. Limited Stores? 18 offered me a position to continue flying and. you
19 A. Right. Yes. 19 know, basically sot up the airplane for his flight
20 O. What did you do for them? 20 department because they hadn't had any previous large
21 A. Same • maintenance. 21 aircraft experience.
22 O. Did you ever fly in them? 22 O. I missed something. It wasn't your fault, it
23 A. On the Guffstreams in the early days we 23 was mine.
24 used flight mechanics, especially on international 24 The Gulfstream that you were talking about.
25 flights. 25 did you used to fly that as well as being a flight
S
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technician?
A. No, no.
O. Okay.
A. You don't have to have a flight - a
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0. Do you know why Epstein those to buy that
particular 727 rather than one of the other million 727s
that are made?
MR. GOLDBERGER: Form.
5 pilot's certificate to be a professional flight 5 A. Because it was probably the finest one out
6 engineer. I've got a turbo - a flight engineer turbo 6 there •-
7 jet rating, but you don't have to have a commercial 7 0. Why?
B ticket as long as you - the FAA recognizes your heavy 8 A. -- In all honesty. It's got a fully Paged
9 aircraft maintenance experience. 9 STC interior with EFTS cockpit, and Limited's
10 0. So you're saying that if the FAA recognizes
• IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY, FLORIDA
L.M.,
Plaintiff,
vs. Case No. 502008CA028051
XXXXMB AD
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
LARRY EUGENE MORRISON
TAKEN ON BEHALF OF THE PLAINTIFF
VOLUME I
Pages 1 to 200
October 6, 2009
10:55 a.m.
515 N. Flagler Drive
West Palm Beach, FL 33401-4321
court reporter
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EFTA00181381
Larry Eugene Morrison - Volume I October 6, 2009
1 3
• IN /NS CIRCUIT COURT Of TAR 15Th JUDICIAL CIRCUIT IN
AND PM PAIN BRACH COUNTY. FLORIDA
VOLONE I Pages 1 to 200
2
3
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APPEARANCE OF COUNSEL
On behalf of the Defendant
ATTEFOURY. GOLDBERGER A WEISS
BY: JACK ALAN GOLDBERGER. ESO..
250 Australian Avenue
Suite 1400
5 act. FL 33401
Plaintiff. I 6
/Case No. 5020006020051
IX/WM AD On behalf of the Defendant by telephone:
JRFPRRY DITHER. e
BURMAN. CRITTON. LUTTIER & COLEMAN
Defendant . I 9 BY: MICHAEL J. PIKE. ESO..
515 N. Fla or Drtve
10 Suito 400
DEPOSITION OF lm ad,. FL 33401
LARRY MAUNA NORAISON 11
TAKEN On SHALT OF INA PLAINTIFF
October 4. 2009 12
10/59 a.m. - 2/20 p.m. 13
On behalf of the witness:
515 X. ?kegler Drive
Nest Palm Beach, FL 13401.4121 14
LAW OFFICE OF BRUCE E. REINHART
15 BY: BRUCE E. REINHART. ESO..
One Clearleke Cantor
16 250 S. Australian Avenue
Suite 1400
court reporter 17 &ch. FL 33401
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APPEARANCES OF COUNSEL
On banal a the Flambe L.M..
ROTHSTEIN. 110SENFELDT a ADLER
BY: BRADLEY J. EDWARDS. ESO.
111X1MICHAEL WHEELER. ESO..
401 East Las OHS 130.40Velt1
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WITNESS:
INDEX OF EXAMINATION
LARRY EUGENE MORRISON
Page
S41[91650 6 DIRECT EXAMINATION
ran Lo, ie. FL 31394
By Mr. Edwards #5
7
CROSS-EXAMINATION
s By Ms. Ezell *190
On betel d Planter Jane Doe 2 through
T 9 CROSS-EXAMINATION
mERUELSTE1N 6 HOROWITZ. PA By Mr. Willits #195
10 BY: JESSICA D. ARBOUR. ATTORMEY.AT4AW. 11)
19205 Beware Boulevard
11 Suite 2218 CROSS-EXAMINATION
Men. 1-1. 33160 11 By Mr. Pike N196
12 12 FURTHER REDIRECT EXAMINATION
By Mr. Edwards #199
li On Denali of mantes Jane Doe 101 aro 102 by 13
telephone: 14
15
PODHURST ORSECK PA 15
16 BY: KATHERINE W. EZELL. ATTORNEY.ATiLAW.
25 W. Ragier Street 16 INDEX TO EXHIBITS
17 17
Plaintiffs
IS Page
18 Exhibit Desolation
On banal of me Plartlf C.MA by telapheac 19 1 Twenty-four pages of 'JEGE. Inc..
20 Passenger Manifest.' *138
LAW OFFICE OF RICHARD WILLITS. PA 20
St BY: RICHARD WILLITS. ESO.. 21
2290101h Avenue N.
21 Suite 404 22
Laks Worm 33481 23
21 24 (Plaintiffs Composite 1 was attached to the
25 original transcript and copies of the transcript.)
25 25
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Deposition of LARRY EUGENE MORRISON
October 6. 2009
THE REPORTER: Do you swear the testimony
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You know. it was a business decision made somewhere.
O. What does the company do?
A. What? The company? It's just a holding
company, I think, for the aircraft. It's not -- I
•
5 you're about to give will be the truth, the 5 don't believe it to be a money making company or a
6 whale truth. and nothing but the truth so help 6 real corporation.
7 you God? 7 O. You're saying 'tor the aircraft* I'm
8 THE WITNESS: So help me God. 8 interpreting that to mean you're talking about one
------- 9 aircraft.
10 LARRY EUGENE MORRISON, having been first 10 A. Correct.
11. duly sworn, was examined and testified as 11 O. 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 justoneis JEGE Of --
15 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 O. 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 O. What's JEGE mean? 19 now I just do paperwork • 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 Dankjold Reed 21 airplanes other than I will take the Boeing for
22 Aviation. 22 maintenance.
23 MR. REINHART: Spell it. 23 O. Since it seems like 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 is Reed, R-E-E-D. Aviation. Its a corporate flight 25 involvement with Jeffrey Epstein of any way, shape, or
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department.
O. What do you do for him?
A. Director of Maintenance.
O. Okay, so you maintain his planes --
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form was 2001?
A. That's correct, yeah.
O. You didn't meet him before that.
A. I had met him. He was a -- He was an
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5 A. Correct. 5 associate of my previous boss.
6 O. should something go wrong? 6 O. Who's that?
7 A. Correct. Yes. Yep. 7 A. Mr. Wexner.
8 O. Do you also — 8 O. -Wexner?
9 A. For maintenance. 9 A. Yes.
10 O. Do you also fly on his planes? 10 O. How do you know Wexner?
11 A. On Mr. 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 same 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 O. When you list your company - JEGE? 16 O. How many aircraft did Wexner have?
1? A. Yes. Yeah, ifs just initials. It's an 17 A. Well, none that I know that he had
18 LLC or holding company. 18 personally, but the corporation had - the flight
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 21 O. 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 his? 24 O. Yes.
25 A. Oh, no. no, somewhere -- It wasn't mine. 25 A. It was just -- It was called Limited -
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Limited Flight Department.
O. And do you know him personally then --
Wexner?
A. Yeah, I had met him, of course, you know.
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O. Yes.
A. Aircraft technician.
O. Which entails what?
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 Wexner? 7 O. What kind of airplanes?
8 A. 1988 was when I hired on, so I don't 8 A. Gulfstreams, Hawkers.
9 remember the month. 9 O. How big is the Gulfstream?
10 O. How did you get that job? to A. Fifteen passenger - 15 to 17.
11 A. Through word of mouth and, you know. I 11 (Mr. Goldberger exited.)
12 worked - I lived in - been in aviation for years in 12 BY MR. EDWARDS:
13 Columbus. 13 O. What did Wexner use the Gulfstream for?
14 O. Well, I mean, I= Wexner's an important la A. They were division airplanes. mostly.
15 person, right? I mean, he -- 15 O. 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 O. Any idea why he had two planes?
19 O. He's somebody who owns - my understanding - 19 A. Well, I mean, yeah, we used them - they're
20 Limited, Victoria's Secret? 20 a tool. It 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 Limited has control over 60 percent of their
23 O. Chairman of -- 23 manufacturing processes. plus, you know, what, 1200
24 A. Yeah. He doesn't personalty own it. It's 24 stores, or whatever, throughout all their divisions.
25 a publicly held company. 25 I mean, when you say "Limited,* it's not
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O. Where were you prior to any involvement with
MI Wexner?
A. I worked for Red Roof Inn True Sports
Flight Department.
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just Limited, d's Victoria's Secret and it was
Express and Lemers and Henri Benders and all of
that back then, so, I mean --
O. 50 —
5 O. How did that position lead you to 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 7 O. And by *passengers.' do you also mean clients
8 Flight 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 A&P 11 retail businesses from --
12 school, together - so when the position became 12 O. Such as whom?
13 available they pointed to me and - absolutely. It 13 (Mr. Goldberger entered.)
14 was a line organization. 14 A. Can't even remember names, but it would be
15 O. So did Mr. Wexner approach you or did you is -- 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 bring 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 O. While you were working back in '88 -- Well,
22 O. So you start with Wexner in 1988. 22 how long overall did you work with Wexner and/or
23 A. Yes. 23 his companies?
24 O. What do you do for him then? 24 A. Well, '88 through when I camp hero in
25 A. What did I do for him? 25 January of '01.
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O. Why the change?
A. It offered an opportunity -- Well, one was
I enjoyed flying • and the 727 was being replaced by
a BBJ, which is a two•man airplane, not a three-man
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aircraft. I mean, whatever it takes to keep a
corporate flight department operating.
O. Did you know back then of his relationship, if
any, with Jeffrey Epstein?
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5 airplane - three-pilot airplane - and it gave me the 5 A. Not immediately, no.
6 opportunity to become a Director of Maintenance, and 6 O. When is the first time that you knew of a
7 it was a challenge. You know, bringing - upstaging 7 reputation or a relationship between Wexner and Epstein?
8 an airliner on a private ticket or a VIP ticket is a A. Would have had to probably be around maybe
9 really challenging, and I enjoy the challenge of 9 '98, 99.
10 working and developing the program and stuff. 10 O. How do you become aware that they know one
11 O. Well, my understanding, 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 in a while Jeffrey would ride on the Boeing,
15 multiple homes and -- 15 that's all • that's all I knew.
16 O. Well, when you would maintain his aircraft, 16 O. 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 O. Or elsewhere? 19 O. 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.
22 have to let him finish asking the question 22 O. Did you understand the business relationship
23 before you answer. 21 between the two?
24 THE WITNESS: Okay. I'm sorry. 24 A. Welk I believe it's public knowledge
25 BY MR. EDWARDS: 25 that, I think, Jeffrey managed Mr. • some of Mr.
14 16
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O. I'm sorry, have you ever had your deposition
taken before?
A. No.
O. You definitely never had your deposition taken
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Wexner's funds.
O. Is that something that Mr. Wexner told you?
A. No.
O. Is that something that somebody of Mr.
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5 before while somebody else is trying to eat at the same 5 Wexner's organization would have told you?
6 time they're trying to ask the questions that's very 6 A. No.
7 bizarre. 7 O. 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. Ill wail until you finish your answer before 10 O. Is that just reading articles that speculate
11 I ask my next question; you do the same thing. 'Uh-huh' 11 as to the business relationship between the two or do you
12 or 'uh-uh.' 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 O. I mean, like you say, to me it's common
16 O. II I ask a question that was a bad question or 16 knowledge --
19 something you don't understand - I've asked bad questions 17 A. Right.
18 before • say, I don't gel it? I'll ask a better 18 O. But It's only because of what 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 O. You were working with = 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 25 A. Don't know.
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O. Did you ever know of a time -- And I may be
asking a question that would just be completely outside
of your knowledge, so let me back up.
Have you ever stayed at Wexner's house?
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O. Have you spoken personally with Mr. Wexner?
A- On business issues, yes.
O. Business issues related to your work on Ns
airplanes?
5 A. No. 5 A. Correct.
6 O. Do you know where his house is? 6 O. Have you spoken to him on any other issues
7 A. Yes. 7 that don't involve business relationships with his
8 O. Do you know what the address is in Ohio? a airplanes?
9 A. No. I just know the city. 9 A. No.
10 0. Do you know who he lives with? 10 O. Because you're Nred basically for that
11 A. Yes. 11 purpose, so that's kind of how you deal with him.
12 O. Who is that? 12 A. Yeah. Ifs I'm an employee and he's my
13 A. His wife and children. 13 employer and I only deal with him. you know. on
14 0. What's his wiles name? 14 issues that Involve maintenance.
15 A. Abigail. 15 O. I think I probably know the answer to the next
16 O. Abigail Wexner, and he has three or four 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. Has 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 O. A son and two daughters. 20 O. Who's that?
21 A. I don't know. See. that was back in 2001. 21 A. I'm trying to remember -- You have to
22 I don't know what they have - if they have more kids 22 remember ifs been several years.
23 23 O. Right.
24 O. Okay. Did you ever hear any Information that 24 A. He was friends with the Tuckennans.
25 he was homosexual? 25 O. What's Mr. Tuckerman or Ms. Tuckerman's names?
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A. No.
O. Being Mr. Wexner.
A. No.
O. Any indication to you that he may be
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A. Ms. -- I caret I always addressed them
by their proper name.
O. Do you know what they do?
A. They owned an optical company - opticians.
5 homosexual or bisexual? They were high school friends from Mr. Wexner's high
6 A. Absolutely not. 6 school days.
7 O. Have you heard any information that he and Mr. 7 O. 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 O. 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 O. And Mats only because you know him and you 12 Epstein?
13 know Mr. Wexner and you don't see the Iwo together. 13 MR. GOLDBERGER: Form.
14 A. Correct. 14 A. I don't understand. Can you rephrase it?
15 MR. GOLDBERGER: Form. 15 O. Well, you know that at some point in time -
16 A. Welt - 16 You started working with him in 1988. The first time.
17 O. He -- 17 according to my notes. that you became aware that he was
18 A. Go ahead. 18 friends 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 O. After you became aware that there was that
22 was his previous girlfriend before he met Abigail. 22 relationship, whether business or otherwise, did he ever
23 O. Right. 23 speak to you about how long he had known 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 O. So as far as you were concerned, 1998, when
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you found out there was a relationship with Epstein. it
could have very well started then.
A. Yes.
O. Aside from aircraft technician and taking care
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O. Who were some of the pilots?
A. Tun Staley. Jim Taylor. They've had some
turnover too. I don't know who all is still there
because retail is down.
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5 of Mr. Wexner's aircraft back in the '805 and, I guess. 5 O. Was Larry Visoski a pilot used by MI
6 early '90s, did you have any other personal involvement 6 Wexner at any time?
'7 with him? 7 A. No.
8 A. Just on aircraft completions. O. How about David Rodgers?
9 O. And when you would speak with him, would that 9 A. No.
10 be over the telephone. at the airport. at his private -- 10 O. Are those names you're familiar with?
11 A. It would usually be al the corporate 11 A. Yes.
12 office. 12 O. Those we names you're familiar with how?
13 O. Al the corporate office? 13 A. I flew with them when I was flying for Mr.
14 A. At the corporate office. 14 Epstein.
15 O. Can you tell me the address for his corporate 15 O. So there's no real, other than yourself
16 office? 16 Welt, tell me if I'm wrong: I understand that you did
17 A. No, I can't. 11 some work for Mr. Wexner related to his aircraft and you
18 O. If I requested that from your attorney, would Is 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. Well, I 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 O. And that's where you would meet him • at the 22 A. No. I'm sorry, resay that.
23 Limited? 23 O. Okay. You've already told us that you were
24 A. Yeah. 24 the aircraft technician for Mr. Wexner.
25 O. And how often was • you know, I know that 25 A. One of them. One of several, yes.
22 24
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we're talking about 15, 2O years ago - how often was Mr.
Wexner personally at that location at the Limited
offices?
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O. One of them. Then you also have knowledge
about Mr. Epstein and some relationship with Mr. Epstein.
A. Correct.
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4 A. I have no idea. 4 O. Are there any other pilots, aircraft
S O. 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 A. No, no.
8 Hinson. 8 O. Do you know how Mr. Wexner met Mr. Epstein?
9 O. Who's Charlie Hinson? 9 A. No.
10 A. He was the president of the stores. He to O. How long - if you started in 1988 • how long
11 basically was my gobehveen 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 Gullstream as an 13 O. Why did you stop?
14 aircraft. Did you also serve as a technician for other 14 A. Because what we were talking 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 O. Limited Stores? 18 offered me a position to continue flying and. you
19 A. Right. Yes. 19 know, basically sot up the airplane for his flight
20 O. What did you do for them? 20 department because they hadn't had any previous large
21 A. Same • maintenance. 21 aircraft experience.
22 O. Did you ever fly in them? 22 O. I missed something. It wasn't your fault, it
23 A. On the Guffstreams in the early days we 23 was mine.
24 used flight mechanics, especially on international 24 The Gulfstream that you were talking about.
25 flights. 25 did you used to fly that as well as being a flight
S
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technician?
A. No, no.
O. Okay.
A. You don't have to have a flight - a
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0. Do you know why Epstein those to buy that
particular 727 rather than one of the other million 727s
that are made?
MR. GOLDBERGER: Form.
5 pilot's certificate to be a professional flight 5 A. Because it was probably the finest one out
6 engineer. I've got a turbo - a flight engineer turbo 6 there •-
7 jet rating, but you don't have to have a commercial 7 0. Why?
B ticket as long as you - the FAA recognizes your heavy 8 A. -- In all honesty. It's got a fully Paged
9 aircraft maintenance experience. 9 STC interior with EFTS cockpit, and Limited's
10 0. So you're saying that if the FAA recognizes