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Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 17 of 26 IV. Witnesses Whose Memories Have Failed or Corrupted. Many potential witnesses have been contacted in relation to this matter and other related litigations. Significant numbers of potential witnesses no longer remember when events may have occurred, who was present, and do not have documents to refresh their memories. One example of the pervasive and prejudicial memory loss relates to the identity of passengers on Mr. Epstein’s planes. Dave Rodgers was one of Mr. Epstein’s pilots beginning in 1991. Mr. Rodgers kept flight logs, produced in civil litigation and subsequently released or leaked to the media. The logs contain the dates, locations of travel, and a rudimentary list of passengers, often identified only by gender, initials, or one name. Mr. Rodgers destroyed records prior to 1994. According to Mr. Rodgers, without his logs he is unable to recall who was on a particular flight. Ex. C at 211-212. And, even with the logs he cannot identify many of the passengers. “Maria” may or may not be a witness in this matter. /d. at 41. Where the logbook describes “one or two” females, Mr. Rodgers has no memory of who those people were. /d. at 44-45. Referring to a flight involving “Nadia,” Mr. Rodgers testified “I’m not sure what Nadia that would be.” Jd. 58. The widespread dissemination of the flightlogs combined with the vague passenger descriptions has allowed any female who might have been under the age of 18 between 1994-2013 to claim that they were on the flight and a victim of Epstein. V. Lost or Destroyed Records. Because of the delay in this prosecution, Ms. Maxwell does not have records including but not limited to the following: 1. Her own: e Phone records from 1994-1997; e Emails from 1994-1997; {2 DOJ-OGR-00002520