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Flight Logs (11,800 documents)
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 134 of 179
Page 133
Flight logs.
Any other documents?
No.
Q. What did Ms. McCawley or Mr. Edwards or
any of the other lawyers say to you
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 27 of 179
Page 26
with me. Ghislaine was there. Jeffrey. And there
were two other women that I don't recall their
names.
Q. Did you travel
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 17 of 179
Page 16
(The referred-to document was marked by
the court reporter for Identification as
Sjoberg Exhibit 3.)
BY MS. McCAWLEY:
Q.
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 4 of 179
IN D1
Examination by Ms. McCawley
Examination by Ms. Menninger
Further Examination by Ms. McCawley
Further Examination by Ms. M
Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 19 of 28
victims of Jeffrey Epstein’s abuse. He has made public statements about the fact that after he
started the investigation into the
Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 16 of 28
4. Maria Alessi (3 % hours). Ms. Alessi’s deposition is scheduled for June 1,
2016, in Florida. She was, with her husband, househo
Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 6 of 28
L FACTUAL BACKGROUND
The Court is aware of the scope of this case from earlier pleadings and numerous
hearings. Initially, Ms. Giu
Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 11 of 28
Whether Defendant knew that the flight logs produced by Dave Rogers (one of Epstein’s
pilots) were accurate. Jd. at 128-29.
Wheth
Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 10 of 28
Whether Defendant knew what Ms. Giuffre was required to wear while providing
massages to Epstein. Id. at 68-69.
Whether Defendant
Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 3 of 12
Giuffre’s counsel contacted counsel for Epstein to seek agreement that he would accept service
of the subpoena in this matter. See M
Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 3 of 10
Defendant even testified that she did not recall having Ms. Giuffre at her London
townhome with Prince Andrew. Defendant stuck to th
Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 2 of 10
Ms. Giuffre intends to strongly disprove Defendant’s false assertions and to demonstrate that
Defendant recruited Ms. Giuffre to be
Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 52 of 56
Page 117
G Maxwell - Confidential
asked Virginia Roberts or whatever she is
called now to have sex with anybody.
Q. Did you ever p
Case 18-2868, Document 287, 08/09/2019, 2628251, Page64 of 76
where plaintiff had ceased being an adulterer but had
“unabashedly committed adultery” for thirteen of seventeen
years). Finally, there a
Case 18-2868, Document 287, 08/09/2019, 2628251, Page41 of 76
For substantially all of thirteen months of the twenty-two month
period from November 2000 to September 2002, Epstein was
traveling outsi
Case 18-2868, Document 287, 08/09/2019, 2628251, Page34 of 76
Survivors Charter School. Survivor’s Charter School was an
alternative school designed to assist students who had been
unsuccessful at mo
Case 18-2868, Document 287, 08/09/2019, 2628251, Page40 of 76
the police to report that her former landlord had left her
belongings by the roadside and had lit her mattress on fire.
Again, Giuffre me
Case 18-2868, Document 287, 08/09/2019, 2628251, Page42 of 76
Giuffre has further noted that her passport
application, travel records, and witness testimony demonstrate
flight logs are incomplete, th
Case 18-2868, Document 287, 08/09/2019, 2628251, Page14 of 76
e Sex Slave books Epstein ordered from
Amazon.com at GIUFFRE006581.
e The folder Maxwell sent to Thailand with
Giuffre bearing Maxwell’s
Case 18-2868, Document 284, 08/09/2019, 2628244, Page27 of 38
had lit her mattress on fire. Ex.AA. Again, plaintiff met and spoke with the law enforcement
officers but did not complain that she was t
Case 18-2868, Document 284, 08/09/2019, 2628244, Page23 of 38
offers none. The flight logs (which show trips in early 2001) do not contradict the
evidence because they are during the period of time
Case 18-2868, Document 283, 08/09/2019, 2628241, Page616 of 883
Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 20
Time: 8:47:53 Incident Report rogram: CMS301L
Case No. .-. . : 1-05-000368 (Continu
Frame JON ete te Te BER BSc Ses UEGOBOI BEBE A?. Bhgesss of 883
From: Jenna
Sent: Fri 2/25/2011 10:12:25 PM
Importance: Normal
Subject: RE: Re:
Received: Fri 2/25/2011 10:12:25 PM
The flight logs
Case 18-2868, Document 283, 08/09/2019, 2628241, Page294 of 883
Confidential
DAVID RODGERS
Okay.
That leaves out of Palm Beach?
Okay.
Where do you go on that?
Teterboro.
And who are your passengers?
Case 18-2868, Document 283, 08/09/2019, 2628241, Page283 of 883
Confidential
Page 129
DAVID RODGERS
A. To get from the island by boat, to get
to -- there's land there and take a car, it is
probabl
Case 18-2868, Document 283, 08/09/2019, 2628241, Page260 of 883
Confidential
DAVID RODGERS
Yes.
Why was that?
Because the N908JE went to the Boeing.
was going to be on the Boeing now.
Q. And the new
Case 18-2868, Document 283, 08/09/2019, 2628241, Page257 of 883
Confidential
DAVID RODGERS
Boeing?
A. Yes.
Q. The Boeing, was that previously owned by
The Limited or Les Wexner?
A. I'm not sure
Case 18-2868, Document 283, 08/09/2019, 2628241, Page250 of 883
Confidential
DAVID RODGERS
9:00, so it is 20 to 11:00 here.
BY MR. EDWARDS:
Q. So I want to go to page 41, and down to
December 9th. S
Case 18-2868, Document 283, 08/09/2019, 2628241, Page172 of 883
G Maxwell - Confidential
her but you would have to ask Jeffrey what he
brought her on the trip for.
Q. But she would travel with him w
Case 18-2868, Document 283, 08/09/2019, 2628241, Page171 of 883
G Maxwell - Confidential
building that you would have seen when you
were on the trip in Europe?
MR. PAGLIUCA: Objection to the
form and
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 18-2868, Document 283, 08/09/2019, 2628241, Page91 of 883
Agren Blando Court Reporting & Video, Inc.
Q More than 20?
A I would s
Case 18-2868, Document 281, 08/09/2019, 2628234, Page64 of 66
67. Epstein and Maxwell turned the massage into a sexual encounter. See McCawley
Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199
Case 18-2868, Document 282, 08/09/2019, 2628236, Page5d of 8
(GIUFFRE004721).
40. Attached hereto as Sealed Exhibit 38 is a true and correct copy of Judith
Lightfoot Psychological Records (GIUFFRE00
Case 18-2868, Document 281, 08/09/2019, 2628234, Page49 of 66
(Teteboro, NJ). Four days later, on July 11, 2001, Ms. Giuffre, Epstein and Maxwell continue on
(#1526) to CPS (Cahokia-St. Louis, Illino
Case 18-2868, Document 281, 08/09/2019, 2628234, Page45 of 66
Islands) four days later on January 30, 2001. See McCawley Dec. at Exhibit 15, Rodger’s Dep.
Ex. 1 at GIUFFRE007096; Rodger’s Dep. Tr. a
Case 18-2868, Document 281, 08/09/2019, 2628234, Page42 of 66
about every other crime regardless of the relevance to the crime to which the police responded
and regardless to the threat to herself sh
Case 18-2868, Document 281, 08/09/2019, 2628234, Page43 of 66
Defendant and Epstein is insufficient. Ms. Giuffre incorporates additional details contained in
Response #38 and #46 herein.
Ms. Giuffre
Case 18-2868, Document 281, 08/09/2019, 2628234, Page35 of 66
See McCawley Dec. at Exhibit 27, GM_00893.
Ms. Giuffre’s obvious gap in her school attendance, her presence verified by Epstein’s
pilot
Case 18-2868, Document 281, 08/09/2019, 2628234, Page44 of 66
Maxwell to TIST (U.S. Virgin Islands); however, there is no flight records of Ms. Giuffre’s
return to Palm Beach. See McCawley Dec. at Ex
Case 18-2868, Document 281, 08/09/2019, 2628234, Page9 of 66
e See McCawley Dec. at Exhibit 39, the Palm Beach Police Report showing that Epstein
used women and girls to collect underage girls for hi
Case 18-2868, Document 281, 08/09/2019, 2628234, Page19 of 66
e See McCawley Dec. at Exhibit 39, the Palm Beach Police Report showing that Epstein
used women and girls to collect underage girls for h
Case 18-2868, Document 280, 08/09/2019, 2628232, Page72 of 74
but not here. See Merriam-Webster (11" ed. 2006) (defining “madam” as “the female head of a
house of prostitution”).
Once again, Defenda
Case 18-2868, Document 280, 08/09/2019, 2628232, Page20 of 74
A. Ms. Maxwell, Mr. Epstein and their friends, because their friend relay to other friends
they knew a massage therapist and they would
Case 18-2868, Document 280, 08/09/2019, 2628232, Page11 of 74
protected by federal and state laws. The fact remains that Defendant recruited Ms. Giuffre while
she was a minor child for sexual purpose
Case 18-2868, Document 280, 08/09/2019, 2628232, Page18 of 74
THE WITNESS: Ms. Maxwell, during her research, was found to be Epstein’s long-time
friend. During the interviews, Ms. Maxwell was involve
Case 18-2868, Document 280, 08/09/2019, 2628232, Page12 of 74
together. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 103:4-9 (“Q. After that day, do you
recall that she started coming to the ho
Case 18-2868, Document 280, 08/09/2019, 2628232, Page3 of 74
B. Documentary Evidence also Shows that Defendant Trafficked Ms. Giuffre and
Procured her for Sex with Convicted Pedophile Jeffrey Epstein
Case 18-2868, Document 280, 08/09/2019, 2628232, Page2 of 74
TABLE OF CONTENTS
I. PRELIMINARY STATEMENT 000... ccceccesceeeeseseseeecsesceececsesseesscseeesaesesesevaeseeesaeaaeeees
IL. UNDISPUTED
Case 18-2868, Document 278, 08/09/2019, 2628230, Page454 of 648
Confidential
Page 103
DAVID RODGERS
A. Yes.
Q. The Boeing, was that previously owned by
The Limited or Les Wexner?
A. I'm not sure
Case 18-2868, Document 278, 08/09/2019, 2628230, Page451 of 648
Confidential
DAVID RODGERS
To the Boeing, correct.
Okay.
So if we go back to this first
next column says, "From CMH."
A. Yes.
And w