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.447706.1320.10
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.447706.1137.12_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.447706.1320.20
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 Jane Doe 2 and Emmy…
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
1320-20
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 Jane Doe 2 and Emmy…
giuffre-maxwell
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.447706.189.0
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.447706.42.0
7 pg
…665 (D. Kan. 1999) (holding that challenged discovery request was facially
overbroad due to its use of the “omnibus phrase ‘relating to’”); Parsons v. Jefferson-Pilot
Corp., 141 F.R.D. 408, 412 (M.D.N.C. 1992) (“[b]road…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
….." Id. But
Plaintiff has asse1ted that she spent time with on the island of Little St. James,
US Virgin Islands and that she flew there with the- - in a helicopter piloted by Ms.
Maxwell. In one article, authored by Sharon…
giuffre-maxwell
gov.uscourts.nysd.447706.172.0
28 pg
…28
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…
giuffre-maxwell
gov.uscourts.nysd.447706.755.0
75 pg
…DISTRICT REPORTERS, P.C.
(212) 805-0300
H39YGIUC
Case 1:15-cv-07433-LAP Document 755 Filed 03/20/17 Page 17 of 75 17
1 whatsoever of this flight.
2 So then we called the pilot, and the…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…with whom Defendant, Ghislaine Maxwell and
Jeffrey Epstein, have engaged in sexual activity.
71. All pilots, chauffeurs, chefs, and other employees of either Defendant Maxwell or
Jeffrey Epstein with knowledge of Defendant and Jeffrey Epstein’s inappropriate
conduct with underage…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…did she keep them in a notebook, did she keep them in
7 her computer?
8 And he said, answer: We used to have internal books
9 for pilots, masseuses, chefs, so they would have a -- she would
10 have…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…addresses (only of their counsel) as to just two, Jeffrey Epstein and Alan
Dershowitz. Plaintiff then also listed categories of witnesses such as “all other then-minor girls,
whose identities Plaintiff will attempt to determine” and “all pilots, chauffeurs, chefs…
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