EFTA01247021.pdf

-4 Condensed Transcript

IN THE CIRCUIT COURT OF THE 15Th JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY, FLORIDA


E.
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.




Jennifer DiLorenzo, court reporter




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• 211 TUR CIRCUIT COURT OP TER 15111 JWICJAL CIRCUIT IX
AMU FOR PALM SEAM COUNTY. FLORIDA
MAKE I Pages I to 200
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APPEARANCE OF COUNSEL
On WWI of the Defendant
ATTERBURY. GOLDBERGER a WEISS
BY: JACK MAN GOLDBERGER. ESO .
250 Ausbaban Avenue
Suite 1400
s . FL 33401
Plaintiff, 6
Case No. 502000C11024051
/0703111 AD On bead of the DeiceOwe by 1444410TIE:
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
Suite 1400
Jennifer Ditonne°. court reporter 17 acn, FL 33401

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A
On beret dew Plante
I40114STEIN. feet
BY: BRADLEY J. EDWARDS LSO
and MICHAEL HEELER. ESO .
401 East Las am Elooleverd
COUNSEL
OT 6 ADLER
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WITNESS:
INDEX OF EXAMINATION


LARRY EUGENE MORRISON
Page
Sum IMO 6 DIRECT EXAMINATION
B. FL 33394
By Mr. Edwards *5
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CROSS-EXAMINATION
a *190
On WW1 cpt Mew% a By Ms. Ezell
9 9 CROSS-EXAMINATION
MERUELSTEIN 6 HOSIOVATZ. By Mr. Wilds 0195
10 BY: JESSICA D. ARBOUR. ATTORNEYAT.LAW, 10
18205 Biscayne Boulevere CROSS-EXAMINATION
11 See 2216
11 By Mr. Pike *196
12 FURTHER REDIRECT EXAMINATION
By Mr. Edwards 8199
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14 On bete d 13
ef 14
leNecee:
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POOHURST ORSECK PA 15
14 BY: KATHERNE.A. &ELL ATTORNEY-AT.LAW.
25W. Page« Seem 16 INDEX TO EXHIBITS
1 17
Ptautfts
19 18 E.101bIt Description Page
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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.. 21
2290 ICIP•Avenue H.
21 se. 404 22
33631 21
24 (Plaintiff's Composite 1 was attached to flic
24 original transcript and codes 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
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5 you're about to give will be the truth, the 5 don't believe ft 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 saying 'for the aircraft.* I'm
THE WITNESS: So help me God. 8 interpreting that to mean you're talking about one
9 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. Ho owns more than one, but
14 BY MR. EDWARDS: 14 just one is JEGE or --
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 ancifor ride on?
17 O. And. Larry. where aro you employed right now? 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 lust do paperwork - and it was February of
20 A. Its the aviation flight department for 20 2007. So I haven't actualy physically been on the
21 Mr. Epstein. and my primary job * Dankjold Reed 21 airplanes other than I will lake the Boeing for
22 Aviation. 22 maintenance.
23 MR. REINHART: Spell A 23 O. Since it seems like we've kind of skipped
24 A. D-A-N-KJ-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 dote 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 Q. Who's that?
7 A. Correct. Yes. Yep. 7 A. Mr. Wexner.
O. Do you also -- 8 O. Leslie Wexner?
9 A. For maintenance. 9 A. Yes.
10 O. Do you also fly on his planes? 10 O. How do you know Leslie Wexner?
11 A. On Mr. Epstein's? 11 A. I woiked for Limited Stores for 12 years.
12 a 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 Q. How many aircraft did Leslie Wexner have?
17 A. Yes. Yeah, it's just initials. It's an 17 A. Well none that I know that he had
18 ISC or heeding 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 taw? 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. On, 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 - Leslie
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
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? O. What kind or airplanes?
A. 1988 was when I hired on, so I don't A. Gulfstreams, Hawkers.
9 remember the month. 9 O. How big is the Gulfstrearn?
10 O. How did you gel that fob? 10 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 Gullstream for?
14 O. Well, I mean. Leslie Wexners an important 14 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 tam. II 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 personally own it. Its 24 stores, or whatever, throughout all their divisions.
25 a publicly held company. 25 I mean, when you say *Limited.' its not

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O. Where were you prior to any involvement with
Leslie Wexner?
A. I worked for Red Roof Inn True Sports
Flight Department.
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just Limited, its Victoria's Secret and it was
Express and Lemers and Henn Bendel's and all of
that back then. so. I mean --
O. So -
5 O. How did that position lead you to Leslie s A. we moved a lot of passengers to keep
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 clie-is
8 Flight Department was one of the best jobs in of his?
Columbus and, actually, several other people that 9 A. That I don't know. No. Mostly we lust
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 fine organization. 14 A. Can't even remember names, but it would be
15 O. So did Mr. 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 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 w0ukInt 21 O. While you were working back in BI3- Well,
22 O. So you start with Wexner in 1988. 22 how long overall did you work with Leslie Wexner and/or
23 A. Yes. 21 his companies?
24 O. What do you do for him then? 24 A. Well, '88 through when I came hero in
25 A. What ced 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 a takes to keep a
corporate flight department operating.
O. Did you know back then of his relationship. it
any. with Jeffrey Epstein?
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5 airplane three-pilot airplane - and it gave me the k Not immediately. no.
6 opportunity to become a Director of Maintenance. and 6 O. When is the first time that you know of a
7 it was a challenge. You know, bringing upstarting 7 reputation or a relationship between Wexner and Epstein'
8 an airliner on a private ticket or a VIP ticket is e A. Would have had to probably be around maybe
9 really challenging, and I enjoy the challenge of 9 '98,'99.
10 world% arid developing the program and stud. 10 O. How do you become aware that they know ono
11 O. Well, my understanding. Leslie Wexner Is 11 another?
12 generally - he's in Ohio. tight? 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 ckd 4 come about that he would nde on
17 would that be in Ohio -- 17 Wexners Boeing?
18 A. Yes. We were based -- le 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 retationsh-p
23 before you answer. 23 between the two?
24 THE WITNESS: Okay. I'm sorry. 21 A. Web, I believe it's pubic 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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Wexnees funds.
O. Is that something that Mr. Wexner told you?
A. No.
O. Is that something that somebody of Mr.
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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
8 A. Yes. yes. a 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 to' 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 ifs common
16 O. II I ask a question that was a bad question or 16 knowledge --
17 something you don't understand ive asked bad questions 17 A. Right.
18 before • say. 'I don't get it' I'll ask a better 18 O. But irs only because of what I've road. 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 Leslie 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 persona
23 what would you be doing? 23 relationship, if any, between Wexner and Epstein'
21 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 lot me back up.
Have you ever stayed at Leslie Wexner's house?
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O. Have you spoken personally with Mr. Wexner?
A. On bus:Mess issues, yes.
O. Business Issues related to your work on his
airplanes?
A. No. 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 Q. Do you know what the address is in Ohio? e airplanes?
9 A. ND. I just know the City. 9 A. No.
10 O. Do you know who he lives with? 10 O. Because you're hired 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. en
14 O. What's his wile's namo? 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 don't, do you knOw any of
17 daughters. ngM? 17 his personal friends people that he would hang out with
18 A. No. He's got a son. and two l8 on a social level - being Mr. Wexner?
M
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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 hying to remember - You have to
22 I don't know what they have - it they have more kids 22 remember its been several years.
23 now. 23 O. Right.
24 O. Okay. Did you ever hew any information that 24 A. He was friends with the Tuckermans.
25 he was homosexual? 25 O. What's Mr. Tuckerman or Ms. Tuckennan's names?

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A. No.
O. Being Mr. Wexner.
A. No.
O. My Indication to you that he may be
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A. Ms. - I cant. 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? s They were high school friends from Mr. Wieners high
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? 8 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 Mars only because you know him and you 1
12 Epstein?
13 know Mr. Wexner and you don't see the two together. 3 MR. GOLDBERGER: Form.
14 A. Correct. 14 A. I don't understand. Can you rephrase il?
15 MR. GOLDBERGER: Form. 15 O. Wet you know that at some point in time
16 A. Weil — 16 You started working with him in 1988. The first time.
17 17 according to my notes. that you became aware Mat he was
18 A. Go ahead. 18 friends or acquaintances with Mr. Epstein was V8 -
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 Mere 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 Mat 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. Tim Staley. Jim Taylor. They've had some
tumover 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 '80s and. I guess. 5 O. Was Larry Visoski a pilot used by Leslie
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. 8 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 are 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 he 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 CAM? 16 Well, tell me if I'm wrong: I understand that you did
17 A. No, I can't 17 some work for Mr. Wexner related to his aircraft and you
18 O. 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 got 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 pathos?
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.

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we're talking about 15. 20 years ago - how often was Mr.
Wexner personally al that location at the Limited
offices?
A. I have no idea.
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O. One of them. Then you also have knowledge
about Mi. Epstein and some relationship with Mr. Epstein.
A. Correct.
O. Are there any other pilots. aircraft
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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 7 A. No. no.
8 Hinson. 8 O. Do you knew 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 10 O. How long - if you started in 1988 how long
11 basically was my go-between for these aircraft 11 did you slay with Mr. Wexner and/or The Limited?
12 completions for the design. 12 A. January of YR.
13 O. And you mentioned the Gullstream as an 13 O. Why did you stop?
14 aircraft Did you also serve as a tech