giuffre-maxwell
gov.uscourts.nysd.447706.1202.9
5 pg
…!*
9) virginia*
10) jenna*
11) jena*
12) genna*
22) massage*
23) masseur*
24) therapist*
26) mindspring*
42) *copter*
43) chopper*
44) pilot*
45) manifest*
46) log*
47) flight*
48) passport*
52) state* /3 attorney*
1
57) al!n*
58) all…
giuffre-maxwell
gov.uscourts.nysd.447706.110.0
7 pg
…Court for the Southern District of New York (“SDNY”), titled, M10-
468- In re Pilot Project Regarding Case Management Techniques for Complex Civil Cases in
the Southern District of New York. Pl’s Motion at 9. On the other hand…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…2015) ....................................9, 10
Statutes
Federal Rule of Civil Procedure 26 .................................................................................................8
Other
In re: Pilot Project Regarding Case Management Techniques for Complex
Civil Cases in the Southern District of New York, M10-468 …
giuffre-maxwell
gov.uscourts.nysd.447706.121.0
10 pg
…Standing Order M10-468, In re: Pilot Project Regarding Case Management
Techniques for Complex Civil Cases in the Southern District of New York, requires a Joint E-
1
Case 1:15-cv-07433-LAP Document 121 Filed 04/25…
giuffre-maxwell
gov.uscourts.nysd.447706.13.0
1 pg
…order to the defendant(s) on or before the completion of discovery. The
parties are advised that this Court is participating in a Pilot Program for initial
discovery protocols for employment cases alleging adverse action. See www.fjc.gov.
3…
giuffre-maxwell
gov.uscourts.nysd.447706.45.0
17 pg
…2
Meeker v. Life Care Ctrs. of Am., No. 14-CV-02101-WYD- NYW, 2015 WL 4400533 .............. 4
Parsons v. Jefferson-Pilot Corp., 141 F.R.D. 408, 412 (M.D.N.C. 1992) ..................................... 5
Piacenti v. Gen. Motors Corp…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Id. But
Plaintiff has asserted that she spent time with President Clinton on the island of Little St. James,
US Virgin Islands and that she flew there with the President in a helicopter piloted by Ms.
-
Maxwell. In one article…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…Johanna Sjoberg
(a former Epstein employee), Juan Alessi (a former Epstein employee), and David Rodgers4
(former Epstein Pilot). She further seeks to depose Maria Alessi and Jo Fontanella (former
Epstein household employees), as well as Dana Burns and Emmy Taylor…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…Decl., Ex. I. Moreover, the notion that the Secret Service would allow a former
president to be flown by an amateur pilot is ridiculous on its face.
55. In that same Daily Mail article, Ms. Giuffre claimed “that Mr. Clinton…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…Therefore, Ms. Giuffre is now required to take the deposition of pilot Dave
Rodgers to authenticate his pilot logs and the identity of the individuals on various flights.
In addition, as the Court knows, this case involves allegations that Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
…Q. Alone.
23 A. Right.
24 Q. With a pilot?
25 A. Right.
Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 26 of 26
Page 334
1 JOSEPH RECAREY - CONFIDENTIAL
2 BY MS. SCHULTZ…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.2
13 pg
…2016
Page 4 of 12
41) marcinko*
42) *copter*
43) chopper*
44) pilot*
45) manifest*
46) log*
47) flight*
48) passport*
49) terramar*
50) southern* w/3 district*
51) palm* w/3 beach*
52) state* /3 attorney*
53) ross*
54…
giuffre-maxwell
gov.uscourts.nysd.447706.1343.1
23 pg
…22 of 23
Page 410
1 G Maxwell - Confidential
2 Q. Were there other flights that you
3 recall flying on with Jeffrey Epstein that
4 were on flights that -- where Dave Rogers was
5 not the pilot?
6 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…Therefore, Ms. Giuffre is now required to take the deposition of pilot Dave
Rodgers to authenticate his pilot logs and the identity of the individuals on various flights.
In addition, as the Court knows, this case involves allegations that Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…1570 and 1589 (Epstein’s pilot testified
that the passenger listed on his flight log bearing the initials – GM – was in fact Ghislaine
Maxwell and Rodgers was the pilot on at least 23 of the flights in which Defendant flew…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.12
179 pg
…the two pages right now I may refer you to. The
12 document itself is 000721 through 789.
13 And these are flight logs from pilot David
14 Rogers that have been produced in this case.
15 MS. MENNINGER: Objection…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.11_3
23 pg
…20 Page 22 of 23
Page 410
1 G Maxwell - Confidential
2 Q. Were there other flights that you
3 recall flying on with Jeffrey Epstein that
4 were on flights that -- where was
5 not the pilot?
6 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.5
56 pg
…I hired pool people, I
14 hired pilots, I hired all sorts of people.
15 In the course and a very small part
16 of my job was from from time to time to find
17 adult professional massage therapists…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…a well-known Prime Minister, and other
world leaders," according to the court filing.
While none of the power players are named, Epstein's private plane pilot, Larry V1Soski, identified
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…Therefore, Ms. Giuffre is now required to take the deposition of pilot Dave
Rodgers to authenticate his pilot logs and the identity of the individuals on various flights.
In addition, as the Court knows, this case involves allegations that Ms…
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