gov.uscourts.nysd.447706.1328.14.pdf

Case 1:15-cv-07433-LAP Document 1328-14 Filed 01/05/24 Page 1 of 7 EXHIBIT 13 (Filed Under Seal) Case 1:15-cv-07433-LAP Document 1328-14 Filed 01/05/24 Page 2 of 7 Confidential Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 3, 2016 9:07 a.m. C O N F I D E N T I A L Deposition of DAVID RODGERS, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-14 Filed 01/05/24 Page 3 of 7 Confidential Page 18 1 DAVID RODGERS 2 flyer person, then you would reduce it to an 3 initial? 4 MR. PAGLIUCA: Object to form and 5 foundation. 6 MR. REINHART: You can answer the 7 question. 8 You can answer the question, if you can 9 answer the question. You are allowed to answer 10 the question, if you understand the question. 11 BY MR. EDWARDS: 12 Q. I'm trying to understand your testimony. 13 Is it, if you came to know that person -- 14 A. Uh-huh. 15 Q. -- as a frequent flyer passenger, you 16 would begin to reduce that person's name to an 17 initial at some point? 18 MR. PAGLIUCA: Same objection. 19 THE WITNESS: Well, we don't really have a 20 frequent flyer program that we do, so to speak. 21 A lot of times I would do it because if you 22 would write out everybody's name there is not 23 enough space, you know, to get everybody's name 24 in that little square there. 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-14 Filed 01/05/24 Page 4 of 7 Confidential Page 34 1 DAVID RODGERS 2 Q. -- is that right? 3 And is that -- is Ghislaine Maxwell 4 somebody that through the years 1995 through 2013 5 was somebody who flew very frequently? 6 A. What were the years again? 7 Q. The years of this book, 1995 -- 8 A. I wouldn't say through 2013. But, yes, 9 '95 through 2000 sometime. Probably, I would have 10 to go back and -- well, you can see in there. 11 Q. We will get to it. 12 A. There will be a point where you don't see 13 her much. But to say it went through 2013 would not 14 be accurate. 15 Q. Let's do it this way: The person that you 16 have reflected on numerous notations -- 17 A. Yes. 18 Q. -- through here as GM -- 19 A. Yes. 20 Q. -- just by the initials, are we able to 21 safely know that that is Ghislaine Maxwell? 22 A. Yes. 23 MR. PAGLIUCA: Object to form and 24 foundation. 25 MR. EDWARDS: Court reporter, did you get MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-14 Filed 01/05/24 Page 5 of 7 Confidential Page 35 1 DAVID RODGERS 2 the answer? 3 THE REPORTER: Yes. The answer came 4 before the objection. 5 BY MR. EDWARDS: 6 Q. So on the next flight, the next day, from 7 Palm Beach to SAF. Is SAF Santa Fe? 8 A. Yes. 9 Q. And it indicates JE and GM. 10 Are we able to then know that those 11 passengers on that flight were Jeffrey Epstein and 12 Ghislaine Maxwell? 13 A. Yes. 14 MR. PAGLIUCA: Object to form and 15 foundation. 16 BY MR. EDWARDS: 17 Q. And where would you land at SAF? Is that 18 an airport? 19 A. It is an airport. 20 Q. Is it a private airport? 21 A. No. It's -- airlines go in there. 22 Q. Did Jeffrey Epstein also have a landing 23 strip at his property in New Mexico? 24 A. He did at one time. 25 Q. What would that -- do you remember what MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-14 Filed 01/05/24 Page 6 of 7 Confidential Page 36 1 DAVID RODGERS 2 that code would be? 3 A. I don't believe there was a code. 4 Q. All right. Were there times that you 5 landed either the Gulfstream or the Boeing -- 6 A. No. 7 Q. No. 8 MR. REINHART: Let him finish the question 9 before you answer. 10 THE WITNESS: Oh, I'm sorry. 11 BY MR. EDWARDS: 12 Q. Sure. We are doing fine so far. But the 13 court reporter is taking down all of our questions 14 and all of our answers. We are communicating well. 15 A. Okay. 16 Q. But when I go to read this back, we may 17 not get that. 18 A. Okay. Go ahead. 19 Q. So were there times where you landed one 20 of Jeffrey Epstein's planes on his private landing 21 strip at the New Mexico property? 22 A. Yes. But not the Gulfstream and not the 23 Boeing. 24 Q. What plane did you land on his property? 25 A. The Cessna 421. And probably a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-14 Filed 01/05/24 Page 7 of 7 Confidential Page 216 1 DAVID RODGERS 2 A. I don't recall if he did nor or not. 3 Q. Okay. And do you know, does anybody have 4 a transcript of that deposition, to your knowledge? 5 A. I don't. 6 MR. PAGLIUCA: That is all of the 7 questions I have. 8 THE WITNESS: Okay. 9 MR. EDWARDS: What exhibit are we on? 10 MR. REINHART: 8 was the last exhibit. 11 MR. EDWARDS: I want to show the witness 12 what I pulled off the Internet. I want to ask, 13 is that the plane? The answer may very well be 14 no. 15 MR. PAGLIUCA: The exact plane? 16 MR. EDWARDS: Yeah, the exact plane. 17 (The referred-to document was marked by 18 the court reporter for Identification as 19 Deposition Exhibit 9.) 20 MR. REINHART: You mean based on the 21 serial number? 22 MR. EDWARDS: Or there are some pictures 23 from the inside of it, too. 24 MR. REINHART: The plane, you mean the 25 Boeing or -- we have talked about a couple of MAGNA9 LEGAL SERVICES