RE: David Rodgers Subpoena
We attach flight logs for David Rodgers, dated between January 23, 2006 and September 19, 2013. We understand that these records will be kept confidential, pursuant to Fed. R. Crim. P. 6(e).
As discussed on the phone last week, we are in the process of obtaining and reviewing additional materials and anticipate making further productions to you on a rolling basis.
Best regards,
Brendan F. Quigley
Brendan F. Quigley
Partner
Baker Botts L.L.P.
brendan.quigley@bakerbot .com
T +1.212.408.2520
F +1.212.259.2520
M +1.917.885.8069
30 Rockefeller Plaza
New York, NY 10112
We attach additional flight logs for David Rodgers, reflecting flights between 1991 and January 2006. Again, we ask that these records be kept confidential.
EFTA00074327
Best regards,
Brendan
Hi Brendan,
Thanks very much. In terms of next steps, we would appreciate the opportunity to meet with your client for an interview. I think we've discussed this before, but in general we continue to view your client as a witness, and we would expect the interview would largely focus on the flight records you've produced. We don't anticipate that we would need to speak with your client for much longer than an hour or so, in case that helps give a sense of what we have in mind. I think you mentioned that your client is based in Florida, so we're happy to discuss arranging logistics to work out something convenient for you and your client.
Please let us know if a call would be useful to discuss further, and thanks again for sending records earlier today.
Best,
Hi Brendan,
Following up on our conversation from two weeks ago, I wanted to check to see if you have any updates on when we might be able to schedule an interview with your client.
Thanks,
Hi Brendan,
Our team has blocked off time to meet with your client on February 7th, along the lines we discussed. I wanted to check in with you to see if the issues you had raised regarding the estate had been resolved. If so, please let us know and we can move forward with travel arrangements.
Thanks,
We're still working through the issues I mentioned on the phone. We had hoped to have those resolved by now, but they haven't been. Would it be possible to move the meeting to 2/21?
Hi Brendan— I'm free from 2pm onwards tomorrow, if that works for a call. We are available on 2/14, but let's discuss.
Sent from my iPhone
Thanks for talking before.
Here is Mr. Rodgers info for travel purposes
David Neville Rodgers
Lake Worth, FL 33467-7729
Sure, that works. Just let me know what time, and I'll meet you here.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
How long do you guys anticipate going on Friday? I had something unrelated come up in the early afternoon. If you think we're going to go for more than a couple of hours, I'm happy to start earlier than 10.
Brendan F. Quigley
M+1.917.885.8069
We'd like to go through a good chunk of the records on Friday, so it would probably be best to block off 3 hours just in case. Would going until 1pm work for you, or would you rather start earlier?
Thanks,
Maurene
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
