July 30, 2021 David Rodgers prep VTC¶
Attorney Quigley¶
Prepared for trial testimony.¶
-
Currently retired, formerly worked as a pilot.
-
Employer from 1991 through 2019 was Jeffrey Epstein, though was paid by NES corp
- First 13 years, was chief pilot
○ Remainder was the captain and flight engineer¶
- First hired in approximately July 1991 by JE
○ DR was flying for a real estate developer in Columbus, Ohio, and aviation manager next door worked for Les Wexner and suggested DR might be interested in flying for Jeffrey because he was getting same airplane DR was flying.¶
o DR said he was interested, the aviation manager set up interview, DR met with Jeffrey, and was hired¶
- Job responsibilities as chief pilot:
○ Flying the plane¶
○ Budgeting to paying bills so we would know how much money we would need for the planes, bills for maintenance¶
○ Scheduling maintenance¶
○ Recording flight logs¶
- Responsibilities as captain and flight engineer:
○ Flying the plane¶
○ Captain responsible for booking rental cars for crew, hotels for crew, scheduling fueling¶
○ Flight engineer only needed on Boeing 727, maintains all systems¶
- During DR’s employment with JE, JE owned following:*
○ First a Hawker¶
O Then a gulfstream G2B¶
O Then a Cesta 421, used for short flights¶
○ Then a Boeing 727¶
○ Gulfstream 4¶
○ Gulfstream 550¶
○ Helicopters¶
- Between 1994 and 1999, most frequently flew the G2B
○ Corporate aircraft¶
○ Twin engine jet¶
○ International aircraft so could fly to Europe¶
○ Held about 12 seats¶
○ As first walk into cabin, left is cockpit, right is where passenger area is¶
3523-023¶
1¶
Page 1 of 7¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00009044¶
EFTA00159199¶
○ G2B had 4 seats up front, table, couch, further back was a divan that was a four-place couch, opposite that was club seating, then galley, then lavatory, then baggage¶
○ Door between pilots and passengers was always closed once in flight, so DR could not observe passengers during the flight¶
○ 99% of time, DR not able to see what passengers were doing¶
Between 2000 and 2005, most frequently flew the Boeing 727¶
○ Big airliner¶
O When enter to left, Cockpit, bathroom right in front¶
○ As make a right, first compartment was a lounge area with 3 divans seating four people, club seating for 2 people¶
○ Next compartment galley¶
○ Next compartment was a round room with circular couch¶
○ Next compartment an office¶
○ Next compartment was the bedroom¶
○ Next compartment was the rear lavatory and small baggage compartment¶
○ Door between pilots and passengers was always closed once in flight, so DR could not observe passengers during the flight. 2 doors to both cockpit and passenger compartment, always closed.¶
○ 99% of time, DR not able to see what passengers were doing¶
o One trip, pilots were able to nap because of the long flights, but DR only recalls that happening once¶
Flight schedule between 1994 and 2004¶
○ JE flew approximately 2 to 3 times per week¶
○ Not a set schedule, but fairly predictable¶
○ Typically Sunday leave PB to NY, there might be another flight somewhere else in the middle of the week, usually Thursday or Friday back to PB¶
o Usually, JE’s secretary would call pilots and tell pilots about the next trip when JE was in NY¶
Ocasionally JE himself would tell pilots about upcoming trip¶
O Ghislaine Maxwell would occasionally tell pilots about upcoming trip, most likely when traveling away from NY, especially internationally. She would do so either in person or on the phone. Eventually, may have emailed, but in 1990s and early 2000s was verbal. GM typically scheduled the flights she was on.¶
○ DR typically received between 24 and 36 hours notice before a flight¶
O DR informed JE, GM, and/or JE’s secretary of any issues with the planes¶
Other pilots¶
○ Larry Visoski¶
○ Larry Morrison as a flight engineer when got the Boeing 727¶
○ Bill Hammond as an extra pilot¶
Ocasionally hired contractors when someone was on vacation, but not fulltime employees¶
- GM
3523-023¶
2¶
Page 2 of 7¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00009045¶
EFTA00159200¶
○ DR believes GM was on one of the very first flights he flew for JE on July 26, 1991. DR understood that GM and JE were friends at that time, but he was not sure whether she was an employee for JE at that time¶
○ GM was attractive, ate pretty healthy; DR believes she was about 29 when DR first met her; her hair was black, always had short haircuts, very rarely down to shoulders¶
o At first, JE and GM’s relationship seemed to be romantic, but after a few years stopped seeming romantic, but they remained very close friends¶
○ GM hired employees and would staff the houses, managed the houses for JE¶
O Up until 2000, the majority of the time GM was on the flights¶
Somewhere after 2000, around 2003 or 2004, GM was not on that many flights¶
○ DR interacted with JE and GM when they would come up to the cockpit. Would also run into them in the office, saw them at the ranch bunk house on Zorro ranch, occasionally went to GM’s and JE’s residences to drop off items or pick up luggage¶
○ DR recalls GM having the following residences:¶
-
First time DR was ever at her place, probably 1991, was in a very big apartment on $60^{\text{th}}$ Street, but not there very long
-
After her father died in November 1991, GM moved to a very small apartment somewhere in midtown. DR remembers GM leaving for a couple weeks or so when her father tied, and he recalls telling her he was sorry for her loss when she returned, but otherwise they did not discuss her father’s death.
-
In approximately 1993 or 1994, GM moved to a larger apartment around 94th Street
-
In approximately the late 1990s, GM moved to a townhouse on $65^{\text{th}}$ Street, five or six stories
Other forms of transportation¶
o Typically in the 1990s, if JE were going to Europe, he would do the Concord to Europe and back instead of a private plane¶
○ JE did not fly the airlines very often, but might have flown them a few times, for example if the private plane was down for maintenance, which would usually be for about two weeks out of the year¶
○ GM told DR that she had a fractional jet deal and would fly on beach jets, and had that for about 3-5 years in or around the 1990s. So if JE went somewhere without GM, she would sometimes fly out on the jet to meet JE¶
Other passengers on JE planes¶
○ DR had very little contact with any passengers on JE’s planes¶
Most interaction DR would have would be if JE brought a new passenger up to the cockpit and ask to let the passenger sit on the jump seat for the takeoff, then typically would go to the back, or might do it for landing¶
O Secretary would sometimes tell DR how many passengers would be on a particular flight, might tell DR the names of new passengers¶
3¶
3523-023¶
Page 3 of 7¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00009046¶
EFTA00159201¶
Sometimes passengers would introduce themselves to DR on aircraft¶
○ DR would need the names of all passengers if it was an international flight¶
o DR came to recognize a lot of repeat passengers, but there were certainly flights when DR did not know the name of everyone on board.¶
- Records
○ Pilots for JE kept 2 sets of documents for each flight: passenger manifest and flight times; also had another record about maintenance¶
O. DR kept a logbook for each flight he personally piloted between 1991 and 2007. Logbook included the following information for each flight:¶
-
Date
-
Departure location
-
Arrival location
-
Flight number
-
Passengers names
-
Flight Time
O Logbook only included flights DR was on. DR was typically out for the following periods:¶
-
1 week for training every year, occasionally 2 weeks
-
Vacation about 3 weeks
-
So at least one month, could be more
When had an additional pilot, in 2005, would have been even less¶
DR confirmed that maintained logbook entries at or near time of each flight reflected in the book. DR made some entries a few days after the flight, but would copy information from the flight manifests, which he filled out at each flight, to fill in for those flights. Maintained records in course of regularly conducted activity as a pilot, and was a regular practice of that activity.¶
o If DR did not know the name of a passenger, he would note them in the logbook as “female” or “male.” Possible that there were passengers who flew on the plane whose name DR did not know at first but later learned. As a result, the first time a name appears in the logbook is not necessarily the first time that person flew on the plane.¶
- JE Residences
○ When flew to PBI, DR understood was because JE had a home in Palm Beach. DR been to JE’s PB residence multiples times a year during his employment, either to refurbish first aid kit or return something from the plane.¶
-
House man John Alessi would drop Jeffrey off at the PBI airport, pick him up at the PBI airport; John worked for JE for approximately 9 or 10 years; would also drop off passengers with JE at PBI
-
It was a 2-story house, maybe 8,000 or 9,000 square feet, on the intercoastal, had a swimming pool, had a pool house, and another quarters next to house for the staff
4¶
3523-023¶
Page 4 of 7¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00009047¶
EFTA00159202¶
-
Occasionally another passenger would meet separately at PBI
-
John would drive up to the plane when dropping off passengers at PBI.
When flew to TEB, DR understood was because JE had a home in New York.
DR been to JE’s NY residence multiple times, including to pick up luggage for a flight.
-
It was a very large townhouse, approximately 7 stories; door was very impressive at least 12 feet maybe 15 feet, then walk into a foyer, usually as far as pilots went, but also saw that there was a kitchen on the first floor, there was an elevator, to the right was a security place with video monitors, to the left an office (Ghislaine’s), also a big room maybe dining room
O When flew to SAF, DR understood was because JE had Zorro Ranch in New Mexico. DR stayed on Zorro ranch almost every time he flew to SAF.¶
-
Zorro was about 45 minutes away from the SAF airport.
-
Had at least 7500 acres, totaled 10,000 acres roughly because leased others from state.
-
Ranch central had bunk house where all the guests stayed with 5 bedrooms and a kitchen with a big living room area. There were also probably three houses and an office, a greenhouse, stables, two or three parking garages housing multiple cars or tractors, firehouse with firetruck at Ranch Central.
-
JE’s house was located three miles away from Ranch Central with big house. Also had a landing strip at the ranch, but only accommodated smaller aircraft. Landing strip halfway between house and Ranch Central. JE’s house was big house, though only had approximately 3 bedrooms, 2 story house, big basement, had one huge dining room that you could almost play basketball in, kitchen on first floor, smaller dining area for employees, movie theater room, don’t recall much about second floor.
O When flew to LFPB, DR understood was because JE had apartment in Paris. DR been to JE’s Paris apartment, but approximately less than 5 times total.¶
- Paris apartment was a very large apartment, at least 3,000 square feet, on the second story, near Arc de Triumph, was confusing and hard to find the exit
O When flew to TIST, DR understood was because JR had private island called Little St. James in USVI. DR been to private island more than a dozen times.¶
-
Island was approximately 75 acres, a lot of hills to it, no cars on the island, there were 4x4s to move around the island with, had a helipad on the island and would get there by helicopter.
-
JE’s house was broken into a standalone building for each room. Each bedroom was a standalone building, same for kitchen and gym.
-
Flights to TVC. DR recalled that JE flew to Traverse City, Michigan every August for years because he was visiting a music camp nearby. JE would stay at the camp for between one and three days each summer.
5¶
3523-023¶
Page 5 of 7¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00009048¶
EFTA00159203¶
o DR has been to the music camp once or twice before. DR remembers seeing a lodge there that JE had built called the Epstein lodge¶
O August 18, 1994 and August 20, 1994 flights reflect that JE arrived at TVC with passengers who did not depart with him. Instead, other passengers, including GM departed TVC with JE on 8/20/1994. Was fairly common for passengers to only join JE for one leg of a trip like that.¶
○ DR recalls that¶
-
DR recalls meeting in approximately plus or minus a year or two
-
DR recalls flying on the plane with JE and GM
-
DR estimates that flew on the plane at least five times, but could have been more than ten times
○ DR recalls flying on JE’s plane approximately 20 times¶
○ DR recalls meeting ■ in or about¶
○ DR recalls was¶
- DR stopped recording the names of passengers in his logbook in or about March 2007
○ Darren Indyke, JE’s attorney, told DR to stop recording the names of passengers on JE’s flights¶
3523-023¶
Page 6 of 7¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00009049¶
EFTA00159204¶
7¶
3523-023¶
Page 7 of 7¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00009050¶
EFTA00159205¶