UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE
No. 20 Civ. 484 (JGK) (DCF)
Plaintiff,
v.
DARREN INDYKE, et al.,
Defendants.
DECLARATION OF
declares under penalty of perjury pursuant to 28 U.S.C. §
1746 as follows:
I. I submit this declaration in response to a subpoena dated June 10, 2020, from the
plaintiff in this action, directing me to produce documents and appear for a deposition. I
understand this declaration is being submitted in lieu of appearing for a deposition.
2. Beginning in 1991, I worked as a pilot for Mr. Jeffrey Epstein ("Epstein") and
Epstein-affiliated entities.
3. Through flying for Mr. Epstein, I met Ms. . I do not recall when or
where specifically I met Ms. for the first time, or the first flight she was on, but it was
likely in the mid to late 1990s.
4. I have attached as Exhibit A my flight logs from the time period between January
1, 1994 and December 31, 1997. I made these records at or near the time of the flights reflected
therein, they reflect my knowledge at that time, and it was my practice to regularly make such
records during the 1994-1997 time period. With respect to the names in the "Remarks,
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Procedures, Maneuvers, Endorsements" column, my general practice during this time was to use
this column to record the number of passengers on the plane. If I knew the passenger's name or
had learned that name during the course of the trip, my general practice was to record that name.
If I did not know or learn the name, I would write down a generic description, for example,
"Baby," "Nanny," "1 Male," "1 Female."
5. The first time the name M' appears in my flight logs between January 1,
1994 and December 31, 1997 is on November 11, 1996. This entry reflects that a no
last name, was on a flight on that date from West Palm Beach, Florida, to Teterboro Airport in
New Jersey.
6. also appears in an entry on May 9, 1997. This entry reflects that a
`=' no last name, was on a flight on that date from Teterboro Airport to Santa Fe, New
Mexico.
7. I have no specific recollection of either of these flights, which occurred over 23
years ago. In addition to Ms. =, I recall one other individual with the first name `="
who flew on Mr. Esptein's planes, although my recollection is that this other a did not
begin flying until the early 2000s.
8. I declare under penalty of perjury that the foregoing is true and correct to the best
of my recollection.
Executed on July )1 , 2020
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