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Q. 
What's your understanding between the 
relationship of Ghislaine Maxwell and Jeffrey Epstein? 
A. 
I don't really know. 
Q. 
All right. So when you say you're guessing 
that 
and 
know or are 
associated with Jeffrey Epstein, that guess is being 
made on the -- with the observation that they have been 
frequent flyers with Jeffrey Epstein on more than 
hundreds of flights on his private plane? 
A. 
Yes, that's what I'm basing it on. 
Q. 
And do you know where 
is 
staying these days? 
A. 
No. 
Q. 
Do you know what car she's driving these days? 
A. 
No, I don't. 
Q. 
Okay. Do you know if she's living with 
Jeffrey Epstein these days? 
A. 
I don't know that. 
Q. 
Do you know how 
met Jeffrey 
Epstein? 
A. 
I don't. 
Q. 
Were you on an international flight bringing 
her into the country from some other country at any 
time? 
A. 
I don't know. 
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MR. REINHART: Can we clarify? 
You mean with 
Mr. Epstein or --
MR. EDWARDS: No. 
BY MR. EDWARDS: 
0. 
Did you ever bring 
from some 
foreign country into the United States? 
A. 
I'd have to look at the log books, honestly. 
Q. 
That's not something you remember? 
A. 
No. 
I mean, she -- I think she's been on 
Europe trips with us, and I think she's returned from 
Europe with us, but I could not say that honestly. 
Q. 
On this recent helicopter flight with 
and Jeffrey Epstein, did you talk with them 
during that flight? 
A. 
No. 
Q. 
Where did the flight go from? 
And obviously, 
it landed in Miami, but where did you leave from? 
A. 
West Palm Beach. 
Q. 
And did 
and Jeffrey Epstein arrive 
together? 
A. 
You know, I don't remember. 
I was out at the 
helicopter and I think they both started walking up. So 
I don't know if they came separately or not. 
I was 
already at the helicopter. 
Q. 
How long is that flight from Palm Beach to 
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Miami? 
A. 
Twenty-five minutes. 
Q. 
And did they talk to one another during that 
flight? 
A. 
No. 
Q. 
They were both completely silent during that 
flight? 
A. 
Yes. 
Q. 
Okay. 
Is that typical when they are on 
flights together, especially with the helicopter, where 
you're in pretty close quarters, that they would abstain 
from speaking to one another? 
MR. CRITTON: Form. 
THE WITNESS: 
Yeah, it would be typical. It's 
very noisy and communicating in a helicopter is, 
you know, not that comfortable. 
BY MR. EDWARDS: 
Q. 
Over the last five or six years that you have 
known or been familiar with 
, have you 
heard her and Jeffrey Epstein conversing with one 
another? 
A. 
I've heard them conversing, but if you ask me 
what they had said, I could say it -- I wouldn't even 
know what they had said to each other. I've seen them 
talking to each other. 
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Q. 
But you don't remember a single specific 
conversation between Jeffrey Epstein and 
A. 
An honest answer, no. 
Q. 
Okay. 
And the same for 
; have you 
seen or 
have you seen Jeffrey Epstein speak with 
A. 
I've seen him speak with her, yes. 
Q. 
Can you tell me a single specific conversation 
that you have overheard between Jeffrey Epstein and 
A. 
One thing that comes to mind would be make 
sure we have Oreo cookies on the airplane. 
It would be 
something completely nonchalant. 
Q • 
Okay. 
And do you know or have reason to know 
of any employment relationship between 
and 
Jeffrey Epstein? 
A. 
I have no knowledge of any of that. 
Q. 
Do you know if 
works for Jeffrey 
Epstein? 
A. 
I do not know. 
Q. 
Do you know if 
schedules massages 
for Jeffrey Epstein? 
A. 
I have no idea. 
Q • 
Has Jeffrey Epstein ever indicated to you that 
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he is fascinated or infatuated or appreciates or loves 
or likes massages? 
A. 
I have no knowledge of that. 
Q. 
All right. 
How about Ghislaine Maxwell, has 
she ever talked to you about massage therapy or have you 
ever overheard her talking about that? 
A. 
No. 
Q. 
You certainly read the papers over the last 
couple of years, correct? 
A. 
Not on my top ten list. 
I mean, I've read a 
couple articles, but I'm not one to focus on that so 
much as some people would. 
Q. 
Okay. 
When the investigation about Jeffrey 
Epstein came about, the criminal investigation -- you're 
aware that's what I'm talking about, right? 
A. 
That was last year? 
Q. 
Well, it was a couple years ago. 
A. 
Right, okay. 
Q. 
Did you speak with Jeffrey Epstein about that 
investigation? 
A. 
No. 
Q. 
Were you told not to speak with him about that 
investigation? 
A. 
I think we knew ourselves that we weren't --
it wouldn't be proper to even bring it up. 
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Q. 
All right. 
When you read in the newspapers 
ehe allegations that Mr. Epstein was involved with 
numerous underage girls for sexual reasons, were you 
surprised? 
A. 
I didn't believe it. 
Q. 
Do you believe it today? 
66 
A. 
I don't believe it. 
Q. 
You don't believe that Jeffrey Epstein was 
involved with underage girls in a sexual way? 
MR. CRITTON: Form. 
THE WITNESS: 
You're asking for my opinion, 
and I don't think my opinion is relevant in that 
matter. 
BY MR. EDWARDS: 
Q. 
I think it's relevant. Can you just tell me 
whether today you believe that Jeffrey Epstein has 
engaged in sex with underage girls? 
MR. CRITTON: Form; speculation, irrelevant, 
always. 
THE WITNESS: It's irrelevant. 
BY MR. EDWARDS: 
Q. 
I need an answer. 
A. 
I don't believe he had sex with underage 
women. 
Q. 
Or engaged in any sexual acts with underage 
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women? 
MR. CRITTON: 
Form. 
THE WITNESS: 
No. 
BY MR. EDWARDS: 
Q. 
You think that this is just a story that a 
bunch of underage women have made up? 
A. 
Speculation. 
MR. CRITTON: 
Objection. 
Now it's 
argumentative. 
Who gives a darn what he thinks one 
way or another? 
If he has personal knowledge --
MR. EDWARDS: 
You're objecting to the form? 
MR. CRITTON: 
It's argumentative. 
MR. EDWARDS: 
You're objecting to the form? 
MR. CRITTON: 
Yes. 
MR. EDWARDS: 
Okay. 
BY MR. EDWARDS: 
Q. 
Is that something that you believe that a 
bunch of women -- some of which know each other, some 
don't, some of which have been on the airplane and some 
which haven't -- made this up, that Jeffrey Epstein 
engaged in some sexual conduct with them? 
MR. CRITTON: 
Form. 
THE WITNESS: 
What I believe doesn't matter in 
this case, does it? 
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BY MR. EDWARDS: 
Q. 
I need an answer. 
Do you believe it? 
Do you 
believe these girls made this up? 
MR. CRITTON: 
Form. 
MR. REINHART: 
I'm going to instruct him not 
to answer. 
Move on. 
MR. EDWARDS: 
Is there a privilege that we're 
asserting? 
MR. REINHART: 
No, it's irrelevant. 
It's 
harassment and not likely to lead to discoverable 
evidence. 
MR. EDWARDS: 
I'm going to put on the record 
right now that it is -- we are allowed discovery 
into a RICO count. 
We are also allowed discovery 
into the intent of Mr. Epstein in developing a 
criminal enterprise designed to sexually exploit 
and sexually abuse underage girls. 
We believe that 
in doing so, he associated intentionally with 
people of similar beliefs that sex with underage 
girls is okay, and that there have been many 
discussions with this witness, as well as many 
other witnesses with -- to insure his protection 
from law enforcement that they not answer these 
specific questions. 
And thus, the opinions and 
beliefs of all of these witnesses that we are 
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alleging associated with this criminal enterprise 
are certainly reasonably calculated to lead to the 
discovery of admissible evidence. And if you're 
still instructing the witness, based on that 
proffer, not to answer any of these questions, I'm 
going to continue to ask the questions and you can 
instruct him not to answer and we can go to the 
Court. 
MR. REINHART: 
My response is to his opinion 
whether people making allegations in this case are 
colluding or making up a story is irrelevant to 
what you just said. So I am going to instruct him 
not to answer any question that goes to his opinion 
of someone else's motivation or the truth of facts 
to which he has no knowledge. 
So yes, I'm instructing him not to answer. 
MR. CRITTON: 
Let me add in my part, is that I 
think -- you're certainly not only capable to ask 
questions with regard to what his personal 
knowledge is, and if he knows something or he has 
reasonable basis for it; certainly you are entitled 
to that information. 
I think you've asked those 
questions and he's given you straightforward 
answers as to what he knew or what he didn't know 
under those circumstances. And as to what his 
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thoughts are on something which he has no factual 
basis or even an assumption to know one way or 
another is irrelevant. That's ultimately for a 
fact-finder in this case. 
While it's interesting, it's argumentative and 
I don't think he's -- I mean, do it on a 
question-by-question basis. If he has knowledge, 
that's great, but to argue your case with this 
witness or any other witness doesn't serve a 
purpose and I think is, you know -- I think it's 
not a good use of our time, I'll put it that way. 
But you know, you can go ahead and ask. 
MR. EDWARDS: 
I can ask the question and if 
the witness is being instructed not to answer, 
we'll let a judge decide whether he needs to answer 
the question and whether it's discoverable or not. 
MR. REINHART: Absolutely. Make your record. 
BY MR. EDWARDS: 
Q. 
Do you have any reason to believe that Jeffrey 
Epstein engaged in sexual activity with underage women? 
A. 
I have no reason to believe. 
Q. 
Okay. So as you sit here today, based on your 
18 years of knowledge, experience and observation of 
Jeffrey Epstein, is it your belief that he has not had 
sex or engaged in sexual activity with underage women? 
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A. 
It's an opinion, and I believe that he has 
not. 
Q. 
Okay. 
Isn't it true that at some point in 
time you learned that Jeffrey Epstein has -- strike 
that. 
MR. CRITTON: 
When you ultimately get to a 
good place to break, will you let us know? 
MR. EDWARDS: 
Let's break now. 
(A break was had at 11:28 a.m.) 
BY MR. EDWARDS: 
Q. 
All right. Eighteen years of being a pilot 
for Jeffrey Epstein and in terms of being able to name 
somebody that you would say you've observed with Jeffrey 
Epstein and would classify that person as Jeffrey 
Epstein's friend, can you name anybody? 
A. 
; just people that we see 
routinely on the airplane. 
Q. 
That's people you see routinely in the last 
five to ten years, right? 
A. 
Yes. 
Q. 
Prior to that time, anybody that you've 
noticed as Jeffrey Epstein's friend may be Ghislaine 
Maxwell? 
A. 
What time frame? 
Q. 
Is that a person that at some point in time 
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would classify as Jeffrey Epstein's friend? 
2 
3 
4 
5 
A. 
I would classify it. 
I don't know if it's 
true. 
Q. 
But that's only because they were on the 
airplane together? 
6 I 
A. 
Yes. 
7I 
Q. 
Do you know what Jeffrey Epstein does for a 
8 
living in your 18 years of observing and talking with 
9 
Jeffrey Epstein? 
10 
A. 
No. 
11 
Q. 
No idea? 
12 
A. 
No. 
13 
Q. 
Ever asked him? 
14 
A. 
No, actually. 
15 
0. 
Ever been curious? 
16 
A. 
Sure. 
17 
Q. 
Ever done anything to satisfy that curiosity? 
18 
A. 
If you mean Google it, not really, actually. 
19 
I mean, I really have not. 
20 
Q. 
Okay. So in 18 years of traveling and being 
21 
the pilot and driving -- and taking this person, Jeffrey 
22 
Epstein, from one property in New York to New Mexico and 
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Florida and around the world, you have no idea what he 
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does in terms of how he makes money? 
25 
A. 
No, sir. 
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Q. 
I was produced this flight log -- tell me if 
I'm using the wrong term. What is this called, this 
book that I've been provided by Dave Rogers? 
A. 
I've never seen that book. 
Q. 
I'll let you see it. 
I don't know that it was 
always in a book, so maybe that's why you haven't seen 
it. 
Tell me what we're looking at. 
A. 
Well, judging with the name at the bottom, I 
believe this is Dave's flight log, log book. 
Q. 
I didn't know if it was called a flight log. 
A. 
Pilot log book, how's that? That's the 
appropriate name. 
Q. 
It was marked as Composite Exhibit 1 in 
Roger's deposition, as indicated by the exhibit sticker. 
We'll mark it the same in your deposition as well. 
MR. CRITTON: 
Why don't you refer to it as 
his? 
MR. EDWARDS: Fine. 
BY MR. EDWARDS: 
Q. 
It's the pilot log book of Dave Rogers? 
A. 
Yes. 
Q. 
And the years provided in this book are 2002 
through 2005; I can represent that to you. 
I'm going to 
ask you about certain people that David Rogers wrote 
down as being on the airplane and I want to ask you if 
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you know who they are. This person right here is 
It seems like she flew on numerous flights. Do 
you know who that is? 
A. 
No. 
I heard the name, but I don't know who 
that is. 
Q. 
All right. Is that somebody that you remember 
seeing on any of the flights that you were on? 
A. 
What year are we talking about here? 
I don't 
remember. 
Q. 
Well, this is January 2002. 
You'd probably 
know how to read this book a little bit better than me, 
so I don't know. 
A. 
He keeps his a lot more current, so I know the 
name. 
If she walked in here right now, I would probably 
look right through her, to be honest. 
Q. 
Do you know what affiliation or relationship 
she had with Jeffrey Epstein? 
A. 
No. 
Q. 
Okay. There are various -- each row I'm told 
by David Rogers is a different flight and it indicates 
where it takes off from and where it lands, et cetera. 
There's a lot of other information, especially over on 
this side of the page that I'm not familiar with, nor do 
I need to be. 
A. 
Right. 
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Q. 
But it's evident that the plane is being used, 
at least for this time period, January of 2002 through 
2005, on a fairly regular basis. 
I mean, we're looking 
at January 6th, 11th, 13th, 13th, 14th, right? 
A. 
Uh-huh. 
Q. 
I mean, is that something that you would say 
accurately reflects the amount of use of Jeffrey 
Epstein's planes? 
A. 
Yes. 
Q. 
So he travels quite frequently? 
A. 
Yes. 
Q. 
right? 
And he travels with many different people, 
MR. CRITTON: Form. 
THE WITNESS: 
Yes. 
MR. CRITTON: Can I ask one question? 
I was 
wondering what happened, who has possession of now 
what's the original Exhibit No. 1 of Mr. Rogers' 
deposition? 
Did you retain it? 
MR. REINHART: The actual book itself? 
MR. EDWARDS: The court reporter took it, 
right? 
MR. CRITTON: The one marked as an exhibit, 
did you keep that? 
MR. REINHART: This is it. 
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MR. EDWARDS: This is it? 
MR. CRITTON: 
Who took it from the deposition 
the other day? 
MR. EDWARDS: 
I have this one right now. 
MR. REINHART: That's the only copy? 
MR. EDWARDS: Okay. 
MR. CRITTON: So you took the original? 
MR. EDWARDS: Apparently. It has the original 
sticker. 
MR. CRITTON: 
When I say "the original," the 
original copy. Would you have someone recreate 
what you've got and send it to us so we have it? 
MR. EDWARDS: Sure. 
In fact, why don't I wait 
until I get the whole thing and I'll copy all the 
pages and send it to you instead of piecemeal. 
MR. HOROWITZ: 
You mean before the transcript 
comes? 
MR. EDWARDS: 
We can copy it. 
MR. CRITTON: If you give it to me, I'll copy 
it and send it back to you. 
MR. REINHART: 
I have a copy. 
It just doesn't 
have the exhibit sticker on. 
MR. EDWARDS: That's what was told to me the 
other day, that's why I took it. 
MR. CRITTON: 
I want something -- I just don't 
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want to -- if you give me a copy, I'll put a 
sticker on it. 
MR. REINHART: Or just copy the page that has 
the exhibit sticker on it. 
MR. CRITTON: Sorry. 
BY MR. EDWARDS: 
Q. 
Like on this flight, we have "JE." I'm 
assuming that's Jeffrey Epstein, correct? 
A. 
Yes, I'll assume. 
Q. 
"GM," Ghislaine Maxwell, right? 
A. 
Yes. 
Q. 
,
A. 
I would assume. 
Q. 
I mean -- okay. 
And then this name, do you 
recognize that person, 
A. 
Never heard it. 
Q. 
And then 
A. 
Yes. 
Q. 
You've heard that name? 
A. 
I've heard the name. 
Q. 
Not sure who that is, though? 
A. 
No. 
O. 
There's only one, two, three, four, five, six 
people on that flight? 
A. 
Uh-huh. 
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Q. 
That's pretty typical of the amount of 
passengers that you would have on a flight? 
A. 
It varied, sure. 
Q. 
Okay. 
But it varied between -- if we look a 
few lines down, Jeffrey Epstein and Ghislaine Maxwell 
were the only two passengers. Certainly there were 
flights like that as well, right? 
A. 
Mm-hmm. 
Q. 
And so it varied from having one or two people 
to six or seven people, right? 
A. 
Yes. 
Q. 
What's the most people that you remember 
traveling on any of Jeffrey Epstein's airplanes? 
A. 
Twenty-five. 
Q. 
Okay. 
That would be a rarity, wouldn't you 
say? 
A. 
Oh, yeah. 
Q. 
Because I've looked through this log. 
I 
haven't seen any place where there were 25, but there 
are lines that have maybe eight or nine people listed. 
A. 
Right. 
Q. 
Let's see. There's a flight from 
January 15th 
sorry, January 17th, January 20th and 
January 22nd of 2002 that all had 
. 
That 
doesn't serve to refresh your recollection as to who 
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that is, does it? 
A. 
No. 
Q. 
Okay. Do you know what the purpose of her 
79 
being on the airplane flight along with Jeffrey Epstein, 
Ghislaine Maxwell and 
would be? 
A. 
No. 
Q. 
Okay. Do you know how it comes about that 
gets on that flight? 
How does she even know 
there's a flight available? 
A. 
I don't know. 
Q. 
All right. Well, let's go down to somebody 
that we may all know a little bit better. February 9th, 
2002, there's a flight that has Bill Clinton, four 
Secret Service agents and then instead of listing names 
or initials or anything else, it's just listed as two 
males, one female, Jeffrey Epstein, Ghislaine Maxwell, 
and I forget who Dave Rogers told me "AP" 
is. Do you remember who that is? 
A. 
No. 
Q. 
Okay. Either way, how is it that someone like 
Bill Clinton gets on a Jeffrey Epstein flight? 
MR. CRITTON: Form. 
THE WITNESS: 
I don't know. 
BY MR. EDWARDS: 
Q. 
Do you know before the flight takes off that 
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Bill Clinton's going to be a passenger on the flight? 
A. 
Yes. 
Q. 
And how do you know? 
How do you get that 
information? 
A. 
The day before I'd get a phone call from, say, 
saying we're leaving tomorrow going to wherever, 
and sometimes she'll say who's going, sometimes she 
won't. 
On a case where President Clinton would be on 
board, we would put a little extra catering on board or 
do that little extra TLC to the aircraft. 
Q. 
If it's leaving -- this says it's leaving from 
MIA and where is it landing? 
A. 
HPN I believe is White Plains. 
Q. 
Okay. 
Do you remember that flight? 
A. 
I remember being on it. 
Q. 
Well, I mean, if you look through here, 
obviously you had Bill Clinton on the airplane ten or 
twenty times, right? 
A. 
Yeah. 
He's my main focus. 
I remember him 
being on the aircraft, sure. 
Q. 
Do you remember him being on the airplane with 
younger girls? 
MR. CRITTON: 
Form. 
THE WITNESS: 
No. 
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