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Case 1:20-cr-00330-PAE Document600_ Filed 02/11/22 Page 31 of 37 A. Flight Records — Passenger Manifests and Shoppers Travel Records Exactly when the accusers traveled across state lines and when the instances of illegal sexual activity took place were critical issues at trial. Not only were these dates relevant for the jury to assess the accuracy of the witness’ recollections of events that had occurred over 20 years ago, but they were also important because the accusers needed to be younger than 17 years old for the sexual activity to be illegal under New York law. Contemporaneous flight records would have offered the best possible evidence to show exactly when accusers traveled. The only such records admitted at trial were the flight logs kept by David Rodgers, which were incomplete and often identified passengers simply by their first names or generic identifiers like “1 female” or “1 male.” Rodgers and Larry Visoski testified that the passenger manifests also contained information about the names of the passengers on the flights. Tr. 1819; 171-73. Because of the passage of time, however, the flight manifests did not go back to the time period charged in the Indictment. Of particular interest were entries in Rodgers’ flight logs which showed that someone with Jane’s true first name was a passenger on two flights when Jane was 16 years old — one to New York on November 11, 1996, and another to Santa Fe, New Mexico on May 9, 1997. However, because only the first name was listed, the flight logs did not conclusively establish that it was Jane on those flights. Had the passenger manifests been available, the defense could have used them to challenge whether Jane was on those flights as well as the accuracy of Jane’s recollection of events. Similarly, Cimberly Espinosa testified that Epstein often had his assistants buy commercial plane tickets for people and that they used a travel service called Shoppers Travel to book them. Tr. 2349. Annie Farmer testified that Epstein bought her a commercial ticket to fly to New Mexico in the spring of 1996, which was the trip where she claimed she was given a 26 DOJ-OGR-00008955