EFTA00159197.pdf
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE
No. 20 Civ. 484 (JOK) (DCF)
Plaintiff,
v.
DARREN INDYKE, et al.,
Defendants.
DECLARATION OF DAVID RODGERS
DAVID RODGERS, declares under penalty of perjury pursuant to 28 U.S.C. §
1746 as follows:
1. I submit this declaration in response to a subpoena dated June 10, 2020, from the
plaintiff in this action, directing me to produce documents and appear for a deposition. I
understand this declaration is being submitted in lieu of appearing for a deposition.
2. Beginning in 1991,1 worked as a pilot for Mr. Jeffrey Epstein ("Epstein") and
Epstein-affiliated entities.
3. Through flying for Mr. Epstein, I met-I do not recall when or
where specifically I for the first time, or the first flight she was on, but it was
likely in the mid to late 1990s.
4. I have attached as Exhibit A my flight logs from the time period between
I made these records at or near the time of the flights reflected
therein, they reflect my knowledge at that time, and it was my practice to regularly make such
records during the 1994-1997 time period. With respect to the names in the "Remarks,
3523-021
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
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Procedures, Maneuvers, Endorsements" column, my general practice during this time was to use
this column to record the number of passengers on the plane. If I knew the passenger's name or
had teamed that name during the course of the trip, my general practice was to record that name.
If I did not know or learn the name, I would write down a generic description, for example,
"Baby," "Nanny," "I Male," "1 Female."
5. The first time the name appears in my flight logs between
This entry reflects that a no
last name, was on a flight on that date from
6. also appears in an entry oli This entry reflects that a
no last name, was on a flight on that date from
7. 1 have no specific recollection of either of these flights, which occurred over 23
years ago.
8. I declare under penalty of perjury that the foregoing is true and correct to the best
of my recollection.
Executed on July fl _, 2020
CSIC.C2I&Iti
David Rodgers t ia-
2
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
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SOUTHERN DISTRICT OF NEW YORK
JANE DOE
No. 20 Civ. 484 (JOK) (DCF)
Plaintiff,
v.
DARREN INDYKE, et al.,
Defendants.
DECLARATION OF DAVID RODGERS
DAVID RODGERS, declares under penalty of perjury pursuant to 28 U.S.C. §
1746 as follows:
1. I submit this declaration in response to a subpoena dated June 10, 2020, from the
plaintiff in this action, directing me to produce documents and appear for a deposition. I
understand this declaration is being submitted in lieu of appearing for a deposition.
2. Beginning in 1991,1 worked as a pilot for Mr. Jeffrey Epstein ("Epstein") and
Epstein-affiliated entities.
3. Through flying for Mr. Epstein, I met-I do not recall when or
where specifically I for the first time, or the first flight she was on, but it was
likely in the mid to late 1990s.
4. I have attached as Exhibit A my flight logs from the time period between
I made these records at or near the time of the flights reflected
therein, they reflect my knowledge at that time, and it was my practice to regularly make such
records during the 1994-1997 time period. With respect to the names in the "Remarks,
3523-021
Page 1 of 2
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009038
EFTA00159197
Procedures, Maneuvers, Endorsements" column, my general practice during this time was to use
this column to record the number of passengers on the plane. If I knew the passenger's name or
had teamed that name during the course of the trip, my general practice was to record that name.
If I did not know or learn the name, I would write down a generic description, for example,
"Baby," "Nanny," "I Male," "1 Female."
5. The first time the name appears in my flight logs between
This entry reflects that a no
last name, was on a flight on that date from
6. also appears in an entry oli This entry reflects that a
no last name, was on a flight on that date from
7. 1 have no specific recollection of either of these flights, which occurred over 23
years ago.
8. I declare under penalty of perjury that the foregoing is true and correct to the best
of my recollection.
Executed on July fl _, 2020
CSIC.C2I&Iti
David Rodgers t ia-
2
3523-021
Page 2 of 2
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009039
EFTA00159198