Epstein Secrets

en think Mr. Willits is aware of this. There was a subpoena duces tecum for this witness, as well as the previous witness, which was another pilot, Dave Rogers, and that duces tecum was to bring the flight logs related from 1998 through 2005. What was produced at the previous deposition were flight logs f

spread to the press or anyone else, because they do contain confidential information as to who may have been on the plane and other records of Mr. Rogers, which but for the subpoena would have been only available to the FAA or some other law enforcement agencies. MR. EDWARDS: Okay. Is that all you

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 3527-003 Page 73 of 227 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and

an Avenue Suite 1400 West Palm Beach, Florida 33401 ALSO PRESENT: CARA L. HOLMES, ESQUIRE 1220 N.W. 157th Avenue Pembroke Pines, Florida 33028 ADAM D. HOROWITZ, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 RICHARD H. WILLITS, ESQUIRE (VIA TELEPHONE) RICH

/0 Lg_S PASSENGERS Arrival Time Pilots: Dave Rodgers, Larry Vbeskl Plight Engineer: Larry Morrison

JEGE, INC. PASSENGER MANIFEST Registration Number N988JE Type: Tonal DATE: d- -3 2005 FROM Ttr in /0 Lg_S PASSENGERS Arrival Time Pilots: Dave Rodgers, Larry Vbeskl Plight Engineer: Larry Morrison cm* TO 70 ‘. -1- ;b6,--C; ) =Mr 3 /42 4. Coe 5. t,/b Mucieza 7. 8. 1-..44.14) ?

S & LEHRMAN P L ■ EXHIBIT DESCRIPTION PAGE PLAINTIFF'S EX. 1 PHOTO 16 0 On behal of Jane s I through t 1 ) PLAINTIFF'S EX. 2 JEGE, INC., 24 ADAM D. HOROWITZ. ESQUIRE PASSENGER MANIFEST W1TZ. P A 16 PLAINTIFFS EX. 3 HYPERION AIR, INC., 15 PASSENGER MANIFEST ■ PLAINTIFF'S EX. 6 PHOTO 63 I PLAINTI

nk Mr. Willits is aware of this. There was a subpoena duces tecum for this witness, as well as the previous witness, which was another pilot, Dave Rogers, and that duces teoum was to bring the flight logs related from 1998 through 2005. What was produced at the previous deposition were flight logs f

of 26 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. 401 East Las Olas Boulevard 18205 Biscayne Boulevard Suite 1650 Suite 2218 Fort

rt in discussing how a court is to analyze the application of the privilege stated- ... It is for the court to say whether his silence is justified, Rogers v. United States, 1951, 340 U.S. 367, 71 S.Ct. 438, and to require him to answer if 'it clearly appears to the court that he is mistaken.' Temple v

EREBY CERTIFY that a true copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 25th day of March, 2009. Adam D. Horowitz, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected]

t in discussing how a court is to analyze the application of the privilege stated - ... It is for the court to say whether his silence is justified, Rogers v. United States, 1951, 340 U.S. 367, 71 S.Ct. 438, and to require him to answer if 'it clearly appears to the court that he is mistaken.' Temple v

EREBY CERTIFY that a true copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 25th day of March, 2009. Adam D. Horowitz, Esq. Jack Alan Goldberger Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 34 of 37 Jane Doe No. 2 v. Epstein Pa

in discussing how a court is to analyze the application of the privilege stated — ... It is for the court to say whether his silence is justified, Rogers v. United States 1951, 340 U.S. 367, 71 S.Ct. 438, and to require him to answer if 'it clearly appears to the court that he is mistaken.' Temple v.

EREBY CERTIFY that a true copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 25th day of March, 2009. Adam D. Horowitz, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ahorowitzehermanlaw.com

in discussing how a court is to analyze the application of the privilege stated — ... It is for the court to say whether his silence is justified, Rogers v. United States 1951, 340 U.S. 367, 71 S.Ct. 438, and to require him to answer if 'it clearly appears to the court that he is mistaken.' Temple v.

EREBY CERTIFY that a true copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 25th day of March, 2009. Adam D. Horowitz, Esq. Jack Alan Goldberger Stuart S. Mermelstein Es• Atterbu Goldberger & Weiss P.A. Counsel for Plaintiff Jane Doe #2 ounse or 'e en ant Je rey

's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed but the others were.) Our understanding is that his representation of

1 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, 12 UNITED STATES DISTRICT JUDGE APPEARANCES: 13 14 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 15 18205 Biscayne Boulevard Miami, FL 33160 305.931.2200 16 For Jane Doe 17 BRADLEY J. EDWARDS, ESQ. Rothstein

's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed but the others were.) Our understanding is that his representation of

1 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, 12 UNITED STATES DISTRICT JUDGE APPEARANCES: 13 14 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 15 18205 Biscayne Boulevard Miami, FL 33160 16 For Jane Doe 17 BRADLEY J. EDWARDS, ESQ. Rothstein Rosenfeldt Ad