giuffre-maxwell
gov.uscourts.nysd.447706.1327.18
5 pg
…dubin*
35) eva*
36) glen*
37) brunel*
38) jean*
39) luc*
40) nadia*
41) marcinko*
42) *copter*
43) chopper*
44) pilot*
45) manifest*
46) log*
47) flight*
48) passport*
52) state* /3 attorney*
53) ross*
54) gow*
55) acuity*
56)…
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.447706.45.0
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.447706.1218.49
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.447706.1343.1
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.447706.1137.12_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…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
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.447706.55.21
69 pg
…payroll of the gardeners, 6 Florida.
7 scheduling staff and security, food, coordinating 7 Q. Fisher Island?
8 activities with the chef, and pilots, etc. 8 A. Yeah.
9 Q. I'm sorry, what was the last one? 9 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 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.447706.1327.28
38 pg
…talk to Nadia? 22 and foundation.
23 A. No. 23 A. I don't understand the question,
24 Q. Is she a pilot? 24 what did you mean bring?
25 A. I have no idea. 25 Q. Did you ever…
giuffre-maxwell
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
1320-30
27 pg
…Video,
1320-30 Filed Inc. Page 13 of 27
01/03/24
1 We've had lots of bonfires there.
2 Q Did you ever ride in a helicopter with
3 Ghislaine Maxwell acting as pilot of the helicopter?
4 …
giuffre-maxwell
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.447706.773.4
5 pg
…and
illusionist David Copperfield, there’s only one other politician. That’s ex-New Ex-President Bill Clinton
Mexico Governor and Clinton Administration Secretary of Energy Bill
Richardson.
The affidavit says Epstein’s personal pilot, Larry Morrison, testified in a…
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