EFTA00159483.pdf
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 50200BCA028051XXXXMB AD
Plaintiff,
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF LARRY VISOSKI
Thursday, October 15, 2009
10:18 - 3:37 p.m.
515 N. Flagler Drive
Suite P200
West Palm Beach, Florida 33401
Reported By:
Wendy Beath Anderson, RPR, CRR, FPR
Notary Public, State of Florida
Esquire Deposition Services
West Palm Beach Office Job 8127542
3527-003
Page 1 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009676
EFTA00159483
Larry Visoski October 15, 2009
2
1 APPEARANCES:
2 On behalf of the Plaintiff:
3 BRADLEY J. EDWARDS, ESQUIRE
ROTHSTEIN, ROSENFELDT, ADLER
4 401 East Las Olas Boulevard
Suite 1650
5 Fort Lauderdale, Florida 33394
6
7 On behalf of the Defendant:
8 ROBERT D. CRITTON, JR., ESQUIRE
BURMAN, CRITTON & LUTTIER
9 303 Banyan Boulevard, Suite 400
West Palm Beach, Florida 33401
10
11 On behalf of the Witness:
12 BRUCE REINHART, ESQUIRE
250 South Australian Avenue
13 Suite 1400
West Palm Beach, Florida 33401
14
15 ALSO PRESENT:
16 CARA L. HOLMES, ESQUIRE
1220 N.W. 157th Avenue
17 Pembroke Pines, Florida 33028
18 ADAM D. HOROWITZ, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
19 18205 Biscayne Boulevard, Suite 2218
Miami, Florida 33160
20
RICHARD H. WILLITS, ESQUIRE (VIA TELEPHONE)
21 RICHARD H. WILLITS, P.A.
2290 10th Avenue North, Suite 404
22 Lake Worth, Florida 33461
23
24
25
3527-003
Page 2 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009677
EFTA00159484
Larry Visoski October 15, 2009
3
1
2 I NDEX
3
4
5 WITNESS: DIRECT CROSS REDIRECT RECROSS
6
LARRY VISOSKI
7
BY MR. EDWARDS: 6
8 BY MR. CRITTON: 214
BY MR. EDWARDS: 220
9 BY MR. CRITTON: 221
10
11
12
13 EXH IB ITS
14
15
16 NUMBER DESCRIPTION PAGE
17 PLAINTIFF'S EX. 1 FLIGHT LOG BOOK
(MARKED IN PREVIOUS DEPO)
18
19 PLAINTIFF'S EX. 2 MESSAGE PAD 119
PLAINTIFF'S EX. 3 MESSAGE PAD 119
20 PLAINTIFF'S EX. 4 COMPLAINT 139
PLAINTIFF'S EX. 5 INMATE VISITOR LOG 161
21
22
23
24
25
3527-003
Page 3 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00009678
EFTA00159485
Larry Visoski October 15, 2009
4
1 PROCEED I NGS
2
3 Deposition taken before Wendy Beath Anderson,
4 Certified Realtime Reporter and Notary Public in and for
5 the State of Florida at Large, in the above cause.
6 - - -
7 MR. EDWARDS: We're going to put something on
8 the record about -- well, we'll do it this way --
9 MR. REINHART: Do it at the end, after we get
10 him -- whatever you want. It's your show
11 MR. EDWARDS: Okay. There were don't
12 even think Mr. Willits is aware of this. There was
13 a subpoena duces tecum for this witness, as well as
14 the previous witness, which was another pilot, Dave
15 Rogers, and that duces tecum was to bring the
16 flight logs related from 1998 through 2005. What
17 was produced at the previous deposition were flight
18 logs from 2002 through 2005, and now Mr. Reinhart
19 has agreed to produce the remainder of the flight
20 logs requested, those going from 1998 through 2002.
21 MR. REINHART: Correct. They're pilot logs,
22 not flight logs. There are other records we
23 indicated are corporate records, and with those you
24 have to deal with Mr. Critton.
25 MR. CRITTON: However, with the proviso, too,
3527-003
Page 4 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009679
EFTA00159486
Larry Visoski October 15, 2009
5
1 that we're going to work out that these records are
2 to be used within the confines of this litigation
3 and not to be spread to the press or anyone else,
4 because they do contain confidential information as
5 to who may have been on the plane and other records
6 of Mr. Rogers, which but for the subpoena would
7 have been only available to the FAA or some other
8 law enforcement agencies.
9 MR. EDWARDS: Okay. Is that all you want to
10 put on?
11 MR. CRITTON: Yes.
12 MR. EDWARDS: I'm not saying I necessarily
13 agree or disagree with you. That's something that
14 we'll deal with some other day.
15 MR. CRITTON: Bruce, you'd better produce
16 these records, but there has to be some sort of
17 understanding before --
18 MR. REINHART: Correct.
19 MR. EDWARDS: I won't do anything until you
20 file whatever you until we work whatever it is
21 out in court. I'll say that on the record, that
22 I'm not doing anything with the records outside of
23 my office until some judge deals with it.
24 MR. REINHART: And for the record, I'll adopt
25 what Mr. Critton said on this one limited occasion.
3527-003
Page 5 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009680
EFTA00159487
Larry Visoski October 15, 2009
6
1 MR. EDWARDS: All right.
2 Thereupon,
3 (LARRY VISOSKI)
4 having been first duly sworn or affirmed, was examined
5 and testified as follows:
6 THE WITNESS: Yes, I do.
7 DIRECT EXAMINATION
8 BY MR. EDWARDS:
9 Q. Can you tell us your name for the record.
10 A. Lawrence Visoski, Jr.
11 Q. And Mr. Visoski, have you ever had your
12 deposition taken before?
13 A. No.
14 Q. Okay. Here's the process: I'm going to ask
15 you questions. You're going to give us answers. Try to
16 give us answers that we all understand and that the
17 court reporter can take down, such as yes, no, or some
18 other verbal answer that we can understand. It's easy
19 when we get in a casual conversation to nod or shake
20 your head, and the court reporter is not writing
21 pictures or anything else.
22 A. I understand.
23 Q. The other thing is, and I've been accused of
24 this in other depositions -- I don't know if it's true
25 or not -- but I need to wait until you finish answering
3527-003
Page 6 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_0000968I
EFTA00159488
Larry Visoski October 15, 2009
7
1 the question and you need to wait until I finish asking
2 the question.
3 A. So you're not allowed to interrupt me?
4 Q. And you're not allowed to interrupt me.
5 A. Like I just did?
6 Q. Right.
7 MR. CRITTON: Cara just snickered when you
8 said you've been accused because she recognizes
9 it's true.
10 MR. EDWARDS: I don't know what the meaning of
11 her snickering was.
12 BY MR. EDWARDS:
13 Q. But for what it's worth, if you don't
14 understand the question or I've asked a bad question, I
15 don't want you to guess. Give me the best answer to the
16 best of your knowledge and if you need me to rephrase
17 it, I will.
18 A. Okay.
19 Q. Okay. Tell me your current address.
20 A.
22 Q. How long have you lived there?
23 A. Approximately nine years.
24 Q. Okay. Who do you live there with?
25 A.
3527-003
Page 7 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_UXX0682
EFTA00159489
Larry Visoski October 15, 2009
8
1 Q.
2 A.
3
4
S
10 Q• Who's your employer right now?
11 A. NES, LLC.
12 Q. How long has NES, LLC been your employer?
13 A. I'm guessing. I'd say back 1991. I have to
14 do the math, but 17, 18 years.
15 Q. Has that been your only employer since 1991?
16 A. Yes.
17 Q. And has that been your only source of income
18 since 1991?
19 A. Yes.
20 Q. And what is NES, LLC?
21 A. I don't really know. I mean, it's the company
22 that my check comes from.
23 Q. What do you do for NES, LLC that results in
24 them paying you?
25 A. I am chief pilot for the aircraft and
3527-003
Page 8 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00009683
EFTA00159490
Larry Visoski October 15, 2009
9
1 helicopters.
2 Q. And do you have a specific boss or somebody
3 you answer to at NES, LLC?
4 A. Several people would call to schedule flights
5 from the office, being it either Mr. Epstein or, you
6 <now, I would just get a phone call and they would
schedule a trip.
8 Q. Okay. Aside from Mr. Epstein, who else would
9 there be that would call to schedule flights?
10 A. Leslie.
11 Q. Leslie who?
12 A. Leslie Gruff.
13 Q. When's the last time you talked to Leslie
14 Gruff?
15 A. Probably two weeks ago, three weeks ago.
16 Q. And where is she currently?
17 A. I believe in New York, is where I spoke to her
18 on the phone last.
19 Q. What's the telephone number you call to reach
20 Leslie Gruff?
21 A.
22 Q. And what address is Leslie Gruff at?
23 A. Do you mean where the office is located?
24 Q. Correct.
25 A.
3527-003
Page 9 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009684
EFTA00159491
Larry Visoski October 15, 2009
10
1 Q. And it's my understanding from other
2 depositions that there are also apartments in that
building?
4 A. Yes.
5 Q. And Mr. Epstein either owns or leases or rents
6 certain of those apartments. Is that your
7 understanding?
MR. CRITTON: Form; speculation.
9 THE WITNESS: I'm only speculating. I
10 don't -- to my understanding, I don't know.
11 BY MR. EDWARDS:
12 Q. Do you know other people that live in that
13 building?
14 A. Well, it would be myself, Dave Rogers -- well,
15 when you say "live,' explain.
16 Q. When you're saying yourself and Dave Rogers --
17 A. See, we don't live there. I mean, we have --
18 we would stay there when we would have a trip.
19 Q. Okay. When you would fly up to New York and
20 land in New York, the place where you would stay, is
21 that
22 A. Yes, that's correct.
23 Q. That's also a location you've indicated in
24 this deposition that is the office for NES, LLC?
25 A. Yes.
3527-003
Page 10 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTASO009685
EFTA00159492
Larry Visoski October 15, 2009
11
1 Q. What floor or suite number is NES, LLC in?
2 A. I believe -- well, I don't know that NES, LLC
3 has an office there. I know that's where Leslie has the
4 phone number where I call. So I don't know for a fact
S If NES, LLC has an office there.
6 Q. And what suite number, then, would Leslie
:ruff sit in to answer that telephone number at
8
9 A. I think it's III.
10 Q. And when you stay at
11 what suite number or what apartment number do you stay
12 in?
13 A.
14 Q. And how about Dave Rogers, where does he stay?
15 A. I'm guessing, because it's been some time
16 since we've been there, 10B, but don't quote me on it.
17 Q. Who are the other people in that building that
18 you know to stay there on a regular -- fairly regular
19 basis?
20 A. I've seen people in the elevator that, you
21 know, have been on the airplane. Case in point, maybe
22 -• but I don't know for a fact that she lives
23 there, or anybody else for that matter.
24 Q. Okay. When you say you've seen
25 on the elevator --
3527-003
Page II of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009686
EFTA00159493
Larry Visoski October 15, 2009
12
1 A. I only assume she lives there. I don't know
2 .or a fact. I'm trying to be honest and factual for
3 So I couldn't honestly say if I knew she lived
4 - here or not.
5 O. Where do you think lives?
6 A. I would think she lives there.
7 Q. You don't have a better location?
8 A. I don't have another location.
9 Q. Anybody else?
10 A. Not to my knowledge. I mean, I'd only be
11 guessing that people live in that building that -- you
12 know, I don't have any facts to prove that they actually
13 live there. I mean, I don't think you want me to guess.
14 Q. Well, NES, LLC, would you say that the owner
15 or controller of that company is Jeffrey Epstein?
16 MR. CRITTON: Form.
17 THE WITNESS: I don't know that for a fact.
18 BY MR. EDWARDS:
19 Q. Jeffrey Epstein is somebody you've indicated
20 that you've worked for for 17 or 18 years, right?
21 A. Yes.
22 Q. And over the 17 or 18 years you've become
23 personally close with him as well, correct?
24 MR. CRITTON: Form.
25 THE WITNESS: I don't understand how you mean
3527-003
Page 12 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009687
EFTA00159494
Larry Visoski October 15, 2009
13
1 •close." Define that.
2 BY MR. EDWARDS:
3 Q. Well, more so than just a pilot that takes him
4 from Point A to Point B?
A. That is my job.
6 Q. Right. But you know him on a personal level
7 and that you've had personal conversations that don't
8 necessarily deal with flying from Point A to Point B;
9 isn't that right?
10 MR. CRITTON: Form.
11 THE WITNESS: More specific, meaning we talk
12 about cars. I mean, does that make you a personal
13 friends?
14 BY MR. EDWARDS:
15 Q. Have you ever gone to his house to eat?
16 A. No.
17 Q. Have you been to his New York home?
18 A. Yes.
19 Q. How many occasions have you been to his New
20 York home?
21 MR. CRITTON: Object to form.
22 THE WITNESS: We normally pick up luggage in
23 the lobby, so it would probably be quite often.
24 Any time we depart out of New York, we stop by the
25 house and pick up luggage and head to the aircraft.
3527-003
Page 13 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00009688
EFTA00159495
Larry Visoski October 15, 2009
14
1 BY MR. EDWARDS:
2 Q. Other than picking up luggage, have you been
3 to his home to visit or socialize with him?
4 A. Not to socialize, no.
5 Q. Have you been to his Palm Beach home?
6 A. To?
7 Q. To Mr. Epstein's Palm Beach house?
8 A. Right.
9 Q. Have you been there?
10 A. Yes.
11 Q. Have you been inside?
12 A. Yes.
13 Q. And how many occasions have you been inside
14 that home?
15 A. The same, as far as picking up luggage, and
16 that would be on a regular basis, you know, for a
17 Aeparture. We wouldn't always go to the house to pick
18 up luggage, but it made it easier for loading the
19 aircraft, getting it done prior to departure.
20 Q. Is that the only reason that you have ever
21 gone to the Palm Beach home over the last 18 years, is
22 to pick up luggage?
23 A. No.
24 Q. What other reasons have you gone there?
25 A. I've set up several home theater equipments,
3527-003
Page 14 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009689
EFTA00159496
Larry Visoski October 15, 2009
15
you know, televisions and such.
2 Q. Is that another hobby or job or something of
3 yours?
4 A. Both.
5 Q. Does he pay you for that?
6 A. Not any more than my salary.
7 Q. What's your current salary?
8 A. At this time, 180,000.
9 Q. And what are you paid $180,000 to do?
10 A. To manage his aircraft.
11 Q. What does that entail?
12 A. Scheduling maintenance. Anything that has to
13 do with any flight, whether it be weather, flight
14 planning, time and distance to and from a location, any
15 logistics involved in running an operation that has
16 aircraft.
17 Q. In addition to the 180,000, does he give you
18 bonuses as well?
19 A. There have been Christmas bonuses.
20 Q. Over the years, you mean, there have been
21 Christmas bonuses?
22 A. Yes.
23 Q. Is 180,000 the most he's ever paid you?
24 A. No.
25 Q. All right. Were you making -- when was the
3527-003
Page 15 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009690
EFTA00159497
Larry Visoski October 15, 2009
16
1 last time that you were making an amount different than
2 180,000?
3 A. Last year.
4 Q. That would be 2008?
5 A. That would be correct. Yeah, we all took a
6 salary cut, I don't know the exact date. It might have
7 been 2008, last year. It was last Christmas we all took
a 10 percent salary cut.
9 Q. Do you know why?
10 A. Economic reasons.
11 Q. And who told you that you were going to have
12 to take the salary cut?
13 A. Darren Indyke.
14 Q. And did you ask for an explanation?
15 A. He explained it was due to economic reasons
16 throughout the country.
17 Q. Okay. So in 2008, how much was -- were you
18 being paid by NES, LLC?
19 A. 200,000.
20 Q. And is 200,000 the most that you've ever made
21 from NES, LLC?
22 A. Yes, sir.
23 Q. And on top of that $200,000, did you get a
24 bonus that year as well?
25 MR. REINHART: Which year are you talking
3527-003
Page 16 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009691
EFTA00159498
Larry Visoski October 15, 2009
17
1 about?
2 MR. EDWARDS: 2008.
3 THE WITNESS: That year, I think we skipped
4 Christmas bonuses that year. The last bonus might
5 have been 2007.
6 BY MR. EDWARDS:
7 Q. If you ever got a bonus from Mr. Epstein
8 and I'm only deriving this from you using the term
9 "Christmas bonus."
10 A. Holiday bonus.
11 Q. -- am I correct to assume sorry. Am I
12 correct to assume that if you got a bonus, there was
13 only one and it was at the end of the year, around the
14 holidays?
15 A. Yes.
16 Q. Okay. And how much was the 2007 holiday
17 bonus?
18 A. I'd have to ask my wife, to be honest. I
19 haven't seen my paycheck in 27 years, so I believe it
20 was $10,000.
21 Q. And in 2007 you also made $200,000?
22 A. Yes.
23 Q. Okay.
24 A. With a question mark. I'm trying to be as
25 accurate as I can, but yes.
3527-003
Page 17 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00009692
EFTA00159499
Larry Visoski October 15, 2009
18
1 Q. Something pretty close to that?
2 A. Yes, sir.
3 Q. Okay. So with the bonus it was 210,000,
4 roughly?
5 A. Right.
6 Q. Okay. And how long were you making that
7 salary?
8 A. Probably -- he was very religious about giving
9 annual increases, so I would probably say 2006, you
10 know, it was -- we would get increment -- increases of
11 five or $10,000 each year. So I would say 2006. So it
12 graduated, you know, progressive.
13 Q. Okay. Do you remember the progression if we
14 start at 1991? Do you remember roughly what the
15 progression was up through 2007/2008, when you were
16 making $200,000?
17 A. No, I wouldn't know the progression.
18 Q. Okay. Do you remember what you were making
19 from and was NES, LLC the company paying you back in
20 1991?
21 A. I don't know. I don't remember. Let me say
22 it that way. I don't remember.
23 Q. Okay. When -- how long do you remember NES,
24 LLC being the payer of your check?
25 A. Personally, two years, because I've never seen
3527-003
Page 18 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00009693
EFTA00159500
Larry Visoski October 15, 2009
19
1 my paycheck. So I don't even know what's written on the
2 top of it.
3 Q. That would be something that only your wife
4 would see, I'm assuming?
5 A. You're right, since she probably wouldn't know
6 the answer either, because she's looking at the right
7 column and not the top column.
8 Q. Right. When is the first time that you had
9 heard the name NES, LLC, that company?
10 A. Five, six years, and even questioned what it
11 stood for. And I think to this day I couldn't answer
12 that honestly, what it stands for.
13 Q. Okay. But it's your understanding that the
14 NES, LLC is paying you for the work that you do as a
15 pilot or maintain the planes for Jeffrey Epstein?
16 A. To my understanding, yes.
17 Q. And back in 1991, do you know if it was a
18 different company that was paying you or if it was
19 Jeffrey Epstein directly paying you?
20 A. I don't remember. I mean, I don't.
21 Q. Okay. Throughout your career with -- as a
22 pilot for Jeffrey Epstein, since 1991, has there ever
23 been a time when you believe you were paid directly from
24 Jeffrey Epstein personally versus some company?
25 A. Not to my knowledge, no.
3527-003
Page 19 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009694
EFTA00159501
Larry Visoski October 15, 2009
20
1 Q. Okay. So whether it was NES, LLC or some
2 other company, it was all of a sudden a company name, to
3 the best of your knowledge?
4 A. Exactly, yes.
5 Q. And back in 1991, do you remember
6 approximately how much you were being paid that year?
7 A. Fifty-five or 60,000, is maybe what I started.
8 Q. Okay.
9 A. You're going back a long ways.
10 Q. Yes.
11 A. I'm trying.
12 Q. Your relationship goes back that far. That's
13 why I chose that year.
14 A. Right.
15 Q• Okay. Did you get bonuses even back that far?
16 A. Yes, sir.
17 Q. And do you remember what your bonuses were
18 approximately?
19 A. 5,000. I mean, that was kind of the -- the
20 starting point.
21 Q. Okay. In addition to monitary bonuses, were
22 - here ever gifts or any other type of compensation that
23 NES, LLC or Jeffrey Epstein provided you?
24 A. Yes.
25 Q. And is that over the span of the 18 years?
3527-003
Page 20 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009695
EFTA00159502
Larry Visoski October 15, 2009
21
1 A. Yes.
2 Q. Okay. Tell me what some of those items are.
3 A. I remember one specifically was a pool heater.
4 Q. Excuse me?
5 A. A pool heater.
6 Q. When was that?
7 A. 1995-ish.
8 Q. Okay. Why did you get that?
9 A. I had built a pool and I didn't have a heater
10 and he kind of laughed at me saying, "How can you have a
11 pool without a heater?" So he says, "You ought to get a
12 heater.•
13 Q. Where were you when you had that conversation?
14 A. In the airplane.
15 O. How did he know that you had built a pool?
16 A. Just in general conversation.
17 Q. You were having a conversation with Jeffrey
18 Epstein?
19 A. Yes.
20 Q. And this is something that was happening on
21 the airplane, this conversation?
22 A. During the flight. Yeah, it would have been
23 like on cruise or something.
24 Q. Okay. When you say •during the flight," does
25 that --
3527-003
Page 21 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009696
EFTA00159503
Larry Visoski October 15, 2009
22
1 A. Again, you're going back a long ways.
2 Q. I understand. We're talking about 1995 right
3 now.
4 A. Yes.
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 50200BCA028051XXXXMB AD
Plaintiff,
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF LARRY VISOSKI
Thursday, October 15, 2009
10:18 - 3:37 p.m.
515 N. Flagler Drive
Suite P200
West Palm Beach, Florida 33401
Reported By:
Wendy Beath Anderson, RPR, CRR, FPR
Notary Public, State of Florida
Esquire Deposition Services
West Palm Beach Office Job 8127542
3527-003
Page 1 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009676
EFTA00159483
Larry Visoski October 15, 2009
2
1 APPEARANCES:
2 On behalf of the Plaintiff:
3 BRADLEY J. EDWARDS, ESQUIRE
ROTHSTEIN, ROSENFELDT, ADLER
4 401 East Las Olas Boulevard
Suite 1650
5 Fort Lauderdale, Florida 33394
6
7 On behalf of the Defendant:
8 ROBERT D. CRITTON, JR., ESQUIRE
BURMAN, CRITTON & LUTTIER
9 303 Banyan Boulevard, Suite 400
West Palm Beach, Florida 33401
10
11 On behalf of the Witness:
12 BRUCE REINHART, ESQUIRE
250 South Australian Avenue
13 Suite 1400
West Palm Beach, Florida 33401
14
15 ALSO PRESENT:
16 CARA L. HOLMES, ESQUIRE
1220 N.W. 157th Avenue
17 Pembroke Pines, Florida 33028
18 ADAM D. HOROWITZ, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
19 18205 Biscayne Boulevard, Suite 2218
Miami, Florida 33160
20
RICHARD H. WILLITS, ESQUIRE (VIA TELEPHONE)
21 RICHARD H. WILLITS, P.A.
2290 10th Avenue North, Suite 404
22 Lake Worth, Florida 33461
23
24
25
3527-003
Page 2 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009677
EFTA00159484
Larry Visoski October 15, 2009
3
1
2 I NDEX
3
4
5 WITNESS: DIRECT CROSS REDIRECT RECROSS
6
LARRY VISOSKI
7
BY MR. EDWARDS: 6
8 BY MR. CRITTON: 214
BY MR. EDWARDS: 220
9 BY MR. CRITTON: 221
10
11
12
13 EXH IB ITS
14
15
16 NUMBER DESCRIPTION PAGE
17 PLAINTIFF'S EX. 1 FLIGHT LOG BOOK
(MARKED IN PREVIOUS DEPO)
18
19 PLAINTIFF'S EX. 2 MESSAGE PAD 119
PLAINTIFF'S EX. 3 MESSAGE PAD 119
20 PLAINTIFF'S EX. 4 COMPLAINT 139
PLAINTIFF'S EX. 5 INMATE VISITOR LOG 161
21
22
23
24
25
3527-003
Page 3 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00009678
EFTA00159485
Larry Visoski October 15, 2009
4
1 PROCEED I NGS
2
3 Deposition taken before Wendy Beath Anderson,
4 Certified Realtime Reporter and Notary Public in and for
5 the State of Florida at Large, in the above cause.
6 - - -
7 MR. EDWARDS: We're going to put something on
8 the record about -- well, we'll do it this way --
9 MR. REINHART: Do it at the end, after we get
10 him -- whatever you want. It's your show
11 MR. EDWARDS: Okay. There were don't
12 even think Mr. Willits is aware of this. There was
13 a subpoena duces tecum for this witness, as well as
14 the previous witness, which was another pilot, Dave
15 Rogers, and that duces tecum was to bring the
16 flight logs related from 1998 through 2005. What
17 was produced at the previous deposition were flight
18 logs from 2002 through 2005, and now Mr. Reinhart
19 has agreed to produce the remainder of the flight
20 logs requested, those going from 1998 through 2002.
21 MR. REINHART: Correct. They're pilot logs,
22 not flight logs. There are other records we
23 indicated are corporate records, and with those you
24 have to deal with Mr. Critton.
25 MR. CRITTON: However, with the proviso, too,
3527-003
Page 4 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009679
EFTA00159486
Larry Visoski October 15, 2009
5
1 that we're going to work out that these records are
2 to be used within the confines of this litigation
3 and not to be spread to the press or anyone else,
4 because they do contain confidential information as
5 to who may have been on the plane and other records
6 of Mr. Rogers, which but for the subpoena would
7 have been only available to the FAA or some other
8 law enforcement agencies.
9 MR. EDWARDS: Okay. Is that all you want to
10 put on?
11 MR. CRITTON: Yes.
12 MR. EDWARDS: I'm not saying I necessarily
13 agree or disagree with you. That's something that
14 we'll deal with some other day.
15 MR. CRITTON: Bruce, you'd better produce
16 these records, but there has to be some sort of
17 understanding before --
18 MR. REINHART: Correct.
19 MR. EDWARDS: I won't do anything until you
20 file whatever you until we work whatever it is
21 out in court. I'll say that on the record, that
22 I'm not doing anything with the records outside of
23 my office until some judge deals with it.
24 MR. REINHART: And for the record, I'll adopt
25 what Mr. Critton said on this one limited occasion.
3527-003
Page 5 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009680
EFTA00159487
Larry Visoski October 15, 2009
6
1 MR. EDWARDS: All right.
2 Thereupon,
3 (LARRY VISOSKI)
4 having been first duly sworn or affirmed, was examined
5 and testified as follows:
6 THE WITNESS: Yes, I do.
7 DIRECT EXAMINATION
8 BY MR. EDWARDS:
9 Q. Can you tell us your name for the record.
10 A. Lawrence Visoski, Jr.
11 Q. And Mr. Visoski, have you ever had your
12 deposition taken before?
13 A. No.
14 Q. Okay. Here's the process: I'm going to ask
15 you questions. You're going to give us answers. Try to
16 give us answers that we all understand and that the
17 court reporter can take down, such as yes, no, or some
18 other verbal answer that we can understand. It's easy
19 when we get in a casual conversation to nod or shake
20 your head, and the court reporter is not writing
21 pictures or anything else.
22 A. I understand.
23 Q. The other thing is, and I've been accused of
24 this in other depositions -- I don't know if it's true
25 or not -- but I need to wait until you finish answering
3527-003
Page 6 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_0000968I
EFTA00159488
Larry Visoski October 15, 2009
7
1 the question and you need to wait until I finish asking
2 the question.
3 A. So you're not allowed to interrupt me?
4 Q. And you're not allowed to interrupt me.
5 A. Like I just did?
6 Q. Right.
7 MR. CRITTON: Cara just snickered when you
8 said you've been accused because she recognizes
9 it's true.
10 MR. EDWARDS: I don't know what the meaning of
11 her snickering was.
12 BY MR. EDWARDS:
13 Q. But for what it's worth, if you don't
14 understand the question or I've asked a bad question, I
15 don't want you to guess. Give me the best answer to the
16 best of your knowledge and if you need me to rephrase
17 it, I will.
18 A. Okay.
19 Q. Okay. Tell me your current address.
20 A.
22 Q. How long have you lived there?
23 A. Approximately nine years.
24 Q. Okay. Who do you live there with?
25 A.
3527-003
Page 7 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_UXX0682
EFTA00159489
Larry Visoski October 15, 2009
8
1 Q.
2 A.
3
4
S
10 Q• Who's your employer right now?
11 A. NES, LLC.
12 Q. How long has NES, LLC been your employer?
13 A. I'm guessing. I'd say back 1991. I have to
14 do the math, but 17, 18 years.
15 Q. Has that been your only employer since 1991?
16 A. Yes.
17 Q. And has that been your only source of income
18 since 1991?
19 A. Yes.
20 Q. And what is NES, LLC?
21 A. I don't really know. I mean, it's the company
22 that my check comes from.
23 Q. What do you do for NES, LLC that results in
24 them paying you?
25 A. I am chief pilot for the aircraft and
3527-003
Page 8 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00009683
EFTA00159490
Larry Visoski October 15, 2009
9
1 helicopters.
2 Q. And do you have a specific boss or somebody
3 you answer to at NES, LLC?
4 A. Several people would call to schedule flights
5 from the office, being it either Mr. Epstein or, you
6 <now, I would just get a phone call and they would
schedule a trip.
8 Q. Okay. Aside from Mr. Epstein, who else would
9 there be that would call to schedule flights?
10 A. Leslie.
11 Q. Leslie who?
12 A. Leslie Gruff.
13 Q. When's the last time you talked to Leslie
14 Gruff?
15 A. Probably two weeks ago, three weeks ago.
16 Q. And where is she currently?
17 A. I believe in New York, is where I spoke to her
18 on the phone last.
19 Q. What's the telephone number you call to reach
20 Leslie Gruff?
21 A.
22 Q. And what address is Leslie Gruff at?
23 A. Do you mean where the office is located?
24 Q. Correct.
25 A.
3527-003
Page 9 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009684
EFTA00159491
Larry Visoski October 15, 2009
10
1 Q. And it's my understanding from other
2 depositions that there are also apartments in that
building?
4 A. Yes.
5 Q. And Mr. Epstein either owns or leases or rents
6 certain of those apartments. Is that your
7 understanding?
MR. CRITTON: Form; speculation.
9 THE WITNESS: I'm only speculating. I
10 don't -- to my understanding, I don't know.
11 BY MR. EDWARDS:
12 Q. Do you know other people that live in that
13 building?
14 A. Well, it would be myself, Dave Rogers -- well,
15 when you say "live,' explain.
16 Q. When you're saying yourself and Dave Rogers --
17 A. See, we don't live there. I mean, we have --
18 we would stay there when we would have a trip.
19 Q. Okay. When you would fly up to New York and
20 land in New York, the place where you would stay, is
21 that
22 A. Yes, that's correct.
23 Q. That's also a location you've indicated in
24 this deposition that is the office for NES, LLC?
25 A. Yes.
3527-003
Page 10 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTASO009685
EFTA00159492
Larry Visoski October 15, 2009
11
1 Q. What floor or suite number is NES, LLC in?
2 A. I believe -- well, I don't know that NES, LLC
3 has an office there. I know that's where Leslie has the
4 phone number where I call. So I don't know for a fact
S If NES, LLC has an office there.
6 Q. And what suite number, then, would Leslie
:ruff sit in to answer that telephone number at
8
9 A. I think it's III.
10 Q. And when you stay at
11 what suite number or what apartment number do you stay
12 in?
13 A.
14 Q. And how about Dave Rogers, where does he stay?
15 A. I'm guessing, because it's been some time
16 since we've been there, 10B, but don't quote me on it.
17 Q. Who are the other people in that building that
18 you know to stay there on a regular -- fairly regular
19 basis?
20 A. I've seen people in the elevator that, you
21 know, have been on the airplane. Case in point, maybe
22 -• but I don't know for a fact that she lives
23 there, or anybody else for that matter.
24 Q. Okay. When you say you've seen
25 on the elevator --
3527-003
Page II of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009686
EFTA00159493
Larry Visoski October 15, 2009
12
1 A. I only assume she lives there. I don't know
2 .or a fact. I'm trying to be honest and factual for
3 So I couldn't honestly say if I knew she lived
4 - here or not.
5 O. Where do you think lives?
6 A. I would think she lives there.
7 Q. You don't have a better location?
8 A. I don't have another location.
9 Q. Anybody else?
10 A. Not to my knowledge. I mean, I'd only be
11 guessing that people live in that building that -- you
12 know, I don't have any facts to prove that they actually
13 live there. I mean, I don't think you want me to guess.
14 Q. Well, NES, LLC, would you say that the owner
15 or controller of that company is Jeffrey Epstein?
16 MR. CRITTON: Form.
17 THE WITNESS: I don't know that for a fact.
18 BY MR. EDWARDS:
19 Q. Jeffrey Epstein is somebody you've indicated
20 that you've worked for for 17 or 18 years, right?
21 A. Yes.
22 Q. And over the 17 or 18 years you've become
23 personally close with him as well, correct?
24 MR. CRITTON: Form.
25 THE WITNESS: I don't understand how you mean
3527-003
Page 12 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009687
EFTA00159494
Larry Visoski October 15, 2009
13
1 •close." Define that.
2 BY MR. EDWARDS:
3 Q. Well, more so than just a pilot that takes him
4 from Point A to Point B?
A. That is my job.
6 Q. Right. But you know him on a personal level
7 and that you've had personal conversations that don't
8 necessarily deal with flying from Point A to Point B;
9 isn't that right?
10 MR. CRITTON: Form.
11 THE WITNESS: More specific, meaning we talk
12 about cars. I mean, does that make you a personal
13 friends?
14 BY MR. EDWARDS:
15 Q. Have you ever gone to his house to eat?
16 A. No.
17 Q. Have you been to his New York home?
18 A. Yes.
19 Q. How many occasions have you been to his New
20 York home?
21 MR. CRITTON: Object to form.
22 THE WITNESS: We normally pick up luggage in
23 the lobby, so it would probably be quite often.
24 Any time we depart out of New York, we stop by the
25 house and pick up luggage and head to the aircraft.
3527-003
Page 13 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00009688
EFTA00159495
Larry Visoski October 15, 2009
14
1 BY MR. EDWARDS:
2 Q. Other than picking up luggage, have you been
3 to his home to visit or socialize with him?
4 A. Not to socialize, no.
5 Q. Have you been to his Palm Beach home?
6 A. To?
7 Q. To Mr. Epstein's Palm Beach house?
8 A. Right.
9 Q. Have you been there?
10 A. Yes.
11 Q. Have you been inside?
12 A. Yes.
13 Q. And how many occasions have you been inside
14 that home?
15 A. The same, as far as picking up luggage, and
16 that would be on a regular basis, you know, for a
17 Aeparture. We wouldn't always go to the house to pick
18 up luggage, but it made it easier for loading the
19 aircraft, getting it done prior to departure.
20 Q. Is that the only reason that you have ever
21 gone to the Palm Beach home over the last 18 years, is
22 to pick up luggage?
23 A. No.
24 Q. What other reasons have you gone there?
25 A. I've set up several home theater equipments,
3527-003
Page 14 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009689
EFTA00159496
Larry Visoski October 15, 2009
15
you know, televisions and such.
2 Q. Is that another hobby or job or something of
3 yours?
4 A. Both.
5 Q. Does he pay you for that?
6 A. Not any more than my salary.
7 Q. What's your current salary?
8 A. At this time, 180,000.
9 Q. And what are you paid $180,000 to do?
10 A. To manage his aircraft.
11 Q. What does that entail?
12 A. Scheduling maintenance. Anything that has to
13 do with any flight, whether it be weather, flight
14 planning, time and distance to and from a location, any
15 logistics involved in running an operation that has
16 aircraft.
17 Q. In addition to the 180,000, does he give you
18 bonuses as well?
19 A. There have been Christmas bonuses.
20 Q. Over the years, you mean, there have been
21 Christmas bonuses?
22 A. Yes.
23 Q. Is 180,000 the most he's ever paid you?
24 A. No.
25 Q. All right. Were you making -- when was the
3527-003
Page 15 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009690
EFTA00159497
Larry Visoski October 15, 2009
16
1 last time that you were making an amount different than
2 180,000?
3 A. Last year.
4 Q. That would be 2008?
5 A. That would be correct. Yeah, we all took a
6 salary cut, I don't know the exact date. It might have
7 been 2008, last year. It was last Christmas we all took
a 10 percent salary cut.
9 Q. Do you know why?
10 A. Economic reasons.
11 Q. And who told you that you were going to have
12 to take the salary cut?
13 A. Darren Indyke.
14 Q. And did you ask for an explanation?
15 A. He explained it was due to economic reasons
16 throughout the country.
17 Q. Okay. So in 2008, how much was -- were you
18 being paid by NES, LLC?
19 A. 200,000.
20 Q. And is 200,000 the most that you've ever made
21 from NES, LLC?
22 A. Yes, sir.
23 Q. And on top of that $200,000, did you get a
24 bonus that year as well?
25 MR. REINHART: Which year are you talking
3527-003
Page 16 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009691
EFTA00159498
Larry Visoski October 15, 2009
17
1 about?
2 MR. EDWARDS: 2008.
3 THE WITNESS: That year, I think we skipped
4 Christmas bonuses that year. The last bonus might
5 have been 2007.
6 BY MR. EDWARDS:
7 Q. If you ever got a bonus from Mr. Epstein
8 and I'm only deriving this from you using the term
9 "Christmas bonus."
10 A. Holiday bonus.
11 Q. -- am I correct to assume sorry. Am I
12 correct to assume that if you got a bonus, there was
13 only one and it was at the end of the year, around the
14 holidays?
15 A. Yes.
16 Q. Okay. And how much was the 2007 holiday
17 bonus?
18 A. I'd have to ask my wife, to be honest. I
19 haven't seen my paycheck in 27 years, so I believe it
20 was $10,000.
21 Q. And in 2007 you also made $200,000?
22 A. Yes.
23 Q. Okay.
24 A. With a question mark. I'm trying to be as
25 accurate as I can, but yes.
3527-003
Page 17 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00009692
EFTA00159499
Larry Visoski October 15, 2009
18
1 Q. Something pretty close to that?
2 A. Yes, sir.
3 Q. Okay. So with the bonus it was 210,000,
4 roughly?
5 A. Right.
6 Q. Okay. And how long were you making that
7 salary?
8 A. Probably -- he was very religious about giving
9 annual increases, so I would probably say 2006, you
10 know, it was -- we would get increment -- increases of
11 five or $10,000 each year. So I would say 2006. So it
12 graduated, you know, progressive.
13 Q. Okay. Do you remember the progression if we
14 start at 1991? Do you remember roughly what the
15 progression was up through 2007/2008, when you were
16 making $200,000?
17 A. No, I wouldn't know the progression.
18 Q. Okay. Do you remember what you were making
19 from and was NES, LLC the company paying you back in
20 1991?
21 A. I don't know. I don't remember. Let me say
22 it that way. I don't remember.
23 Q. Okay. When -- how long do you remember NES,
24 LLC being the payer of your check?
25 A. Personally, two years, because I've never seen
3527-003
Page 18 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00009693
EFTA00159500
Larry Visoski October 15, 2009
19
1 my paycheck. So I don't even know what's written on the
2 top of it.
3 Q. That would be something that only your wife
4 would see, I'm assuming?
5 A. You're right, since she probably wouldn't know
6 the answer either, because she's looking at the right
7 column and not the top column.
8 Q. Right. When is the first time that you had
9 heard the name NES, LLC, that company?
10 A. Five, six years, and even questioned what it
11 stood for. And I think to this day I couldn't answer
12 that honestly, what it stands for.
13 Q. Okay. But it's your understanding that the
14 NES, LLC is paying you for the work that you do as a
15 pilot or maintain the planes for Jeffrey Epstein?
16 A. To my understanding, yes.
17 Q. And back in 1991, do you know if it was a
18 different company that was paying you or if it was
19 Jeffrey Epstein directly paying you?
20 A. I don't remember. I mean, I don't.
21 Q. Okay. Throughout your career with -- as a
22 pilot for Jeffrey Epstein, since 1991, has there ever
23 been a time when you believe you were paid directly from
24 Jeffrey Epstein personally versus some company?
25 A. Not to my knowledge, no.
3527-003
Page 19 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009694
EFTA00159501
Larry Visoski October 15, 2009
20
1 Q. Okay. So whether it was NES, LLC or some
2 other company, it was all of a sudden a company name, to
3 the best of your knowledge?
4 A. Exactly, yes.
5 Q. And back in 1991, do you remember
6 approximately how much you were being paid that year?
7 A. Fifty-five or 60,000, is maybe what I started.
8 Q. Okay.
9 A. You're going back a long ways.
10 Q. Yes.
11 A. I'm trying.
12 Q. Your relationship goes back that far. That's
13 why I chose that year.
14 A. Right.
15 Q• Okay. Did you get bonuses even back that far?
16 A. Yes, sir.
17 Q. And do you remember what your bonuses were
18 approximately?
19 A. 5,000. I mean, that was kind of the -- the
20 starting point.
21 Q. Okay. In addition to monitary bonuses, were
22 - here ever gifts or any other type of compensation that
23 NES, LLC or Jeffrey Epstein provided you?
24 A. Yes.
25 Q. And is that over the span of the 18 years?
3527-003
Page 20 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009695
EFTA00159502
Larry Visoski October 15, 2009
21
1 A. Yes.
2 Q. Okay. Tell me what some of those items are.
3 A. I remember one specifically was a pool heater.
4 Q. Excuse me?
5 A. A pool heater.
6 Q. When was that?
7 A. 1995-ish.
8 Q. Okay. Why did you get that?
9 A. I had built a pool and I didn't have a heater
10 and he kind of laughed at me saying, "How can you have a
11 pool without a heater?" So he says, "You ought to get a
12 heater.•
13 Q. Where were you when you had that conversation?
14 A. In the airplane.
15 O. How did he know that you had built a pool?
16 A. Just in general conversation.
17 Q. You were having a conversation with Jeffrey
18 Epstein?
19 A. Yes.
20 Q. And this is something that was happening on
21 the airplane, this conversation?
22 A. During the flight. Yeah, it would have been
23 like on cruise or something.
24 Q. Okay. When you say •during the flight," does
25 that --
3527-003
Page 21 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009696
EFTA00159503
Larry Visoski October 15, 2009
22
1 A. Again, you're going back a long ways.
2 Q. I understand. We're talking about 1995 right
3 now.
4 A. Yes.