DOJ-OGR-00019059.pdf

Case 1:20-cr-00330-PAE Document 755 Filed 08/10/22 Page 197 of 262 1908 LC8VMAX6 Rodgers - cross 1 right? 2 A. That is correct. 3 Q. And you remember they were in August, except for that one time in July, right? 4 time in July, right? 5 A. Correct. 6 Q. Now, you don't have any independent recollection of these flights, right? 7 flights, right? 8 A. No. 9 Q. Okay. So the way you were able to be so confident in the number of flights and the timing of the flights is because you 10 were able to review your flight records, your flight logbook, right? 11 right? 12 A. That is correct. 13 Q. So you had your memory refreshed by looking at your flight logbook, and that's why you were able to say confidently what you said about the flights for Interlochen, right? 14 logbook, and that's why you were able to say confidently what you said about the flights for Interlochen, right? 15 A. That is correct. 16 Q. So it's not as if you have a separate memory for each of those flights; correct? 17 A. No, I do not. 18 Q. And that's true of really all the flights we're talking about here; you don't have an independent recollection of each and every one of these flights, right? 19 and every one of these flights, right? 20 A. That's correct, I do not. 21 Q. So we're working off your refreshed recollection from your SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019059