Line of Investigation 04: The Travel Records Gap
Executive Summary
The SDNY investigation issued 22 grand jury subpoenas to 9 airline and travel entities between January 23-27, 2020, seeking passenger, payment, and loyalty records for Ghislaine Maxwell (and redacted additional individuals). Despite this broad canvass, the actual travel intelligence yield was minimal: of 1,374 total travel-related production pages, 85% (1,167 pages) came from Epstein's own pilots — records already in the government's possession via separate subpoenas. Only 55 pages came from commercial airline responses. More critically, the investigation never subpoenaed the infrastructure of Epstein's actual travel network: no FBO logs, no FAA flight plans, no CBP arrival/departure records, no charter companies. The subpoenas targeted commercial airline records, but Epstein's travel network was built primarily on private aviation — an infrastructure that was not subpoenaed.
1. The Subpoena Batch: January 23-27, 2020
All 22 airline/travel subpoenas were issued within a 4-day window, 6 months after Epstein's death and during the Maxwell investigation phase.
Commercial Airlines Subpoenaed
| Target | Subpoena Count | EFTA References | Date |
| -------- | --------------- | ----------------- | ------ |
Multiple EFTA numbers for the same target reflect duplicate copies stored across datasets (DS1/DS5/DS8/DS9), not separate subpoenas.
Rider Language
All airline subpoenas use an identical template:
"Please provide any and all records, including but not limited to passenger, payment, membership or loyalty, or any other records, for each of the below-listed individuals, for the following periods:
- January 1, 1994, through December 31, 1998, and
- July 1, 2019, through the date of service"
The named individual is Ghislaine Maxwell, a/k/a Ghislaine Borgerson (DOB 12/25/1961). Some subpoenas include additional redacted names. The expanded American Airlines subpoena (EFTA01660689) also names Nadia Bjorlin and Annie Farmer.
The Expedia subpoenas use a simpler formulation: "any and all records reflecting any information regarding any flight purchased, booked, and/or taken by" Maxwell — with no date range specified.
Statutes Cited
- Airline subpoenas: 18 U.S.C. sections 1591 (sex trafficking), 1594(c) (conspiracy), 2422(b) (coercion/enticement), 371 (general conspiracy)
- Expedia subpoenas: 18 U.S.C. section 2423(a) (transportation of minors) — a different and more specific statute
This statutory split suggests prosecutors were using the Expedia subpoenas to build a transportation-of-minors theory distinct from the broader conspiracy charges.
2. What Was Produced
Production Index Summary
The Maxwell case discovery index (from EFTA00040593 / EFTA00099135) lists these travel-related productions:
| SDNY Bates Range | Pages | Source | Content |
| ----------------- | ------- | -------- | --------- |
| SDNY_GM_00005532-00005676 | 145 | David Rodgers (pilot) | Flight manifests 1991-2013 |
| SDNY_GM_00010462-00011483 | 1,022 | Lawrence Visoski (pilot) | Flight manifest records |
| SDNY_GM_00000718-00000833 | 116 | Government (USCIS/CBP) | Immigration/travel records |
| SDNY_GM_00000977-00001012 | 36 | American Airlines | Airline records |
| SDNY_GM_00006061-00006079 | 19 | Shoppers Travel | Travel records |
| SDNY_GM_00006080-00006096 | 17 | Southwest Airlines | Airline records |
| SDNY_GM_00008138-00008146 | 9 | United Airlines | Airline records |
| SDNY_GM_00004650-00004655 | 6 | Delta Airlines | Airline records |
| SDNY_GM_00000963-00000964 | 2 | Airline Reporting Corp. | ARC records |
| SDNY_GM_00000965-00000965 | 1 | Alaska Airlines | Airline records |
| SDNY_GM_00004657-00004657 | 1 | Expedia | "No records found" letter |
The 85/15 Problem
1,167 pages (85%) of travel production came from Epstein's own pilots — David Rodgers and Lawrence Visoski — via a separate grand jury subpoena to Visoski (
EFTA00100372, July 9, 2019). These are the well-known "Lolita Express" flight logs that had already become publicly significant. They are internal records from Epstein's own operation, not independent third-party verification.
Only 55 pages came from actual commercial airline responses: American (36), United (9), Delta (6), ARC (2), Alaska (1), Expedia (1 — a "no records found" letter).
The 116-page immigration/travel record set came from the government's own agencies (USCIS/CBP), not from the subpoenaed airlines.
Airline Response Detail
| Airline | Pages Returned | Assessment |
| --------- | --------------- | ------------ |
| American Airlines | 36 | Largest commercial response |
| Shoppers Travel | 19 | Not subpoenaed in PQG (may have been separate or voluntary) |
| Southwest Airlines | 17 | Responded despite PQG showing "no matched returns" |
| United Airlines | 9 | Responded |
| Delta Airlines | 6 | Responded despite PQG showing "no matched returns" |
| ARC | 2 | Extremely thin for a 1994-2020 request to the industry clearinghouse |
| Expedia | 1 | Explicit "no records found" response |
Note: The PQG's automated matching failed to link Delta and Southwest to their production returns, marking them as "UNKNOWN" fulfillment. The production index confirms both airlines did respond — Delta with 6 pages (SDNY_GM_00004650-55) and Southwest with 17 pages (SDNY_GM_00006080-96).
3. The Expedia Contradiction
Expedia formally responded on March 17, 2020, at EFTA01265456:
"We have conducted a reasonable and diligent search for records that are responsive using the identifying information in your Subpoena and were unable to locate any responsive records within our control or in our possession."
However, seized American Express records tell a different story:
- Maxwell's AMEX (EFTA01704293, p.48): Shows "EXPEDIA SVC/DLVRY FE800-397-3342 WA" charges, including EasyJet Berlin-to-Paris bookings
- Epstein's AMEX (EFTA01703216, p.68): Shows "EXPEDIA SVC/DLVRY FE800-397-3342 WA" charges, including Continental Airlines tickets
Expedia's "no records found" response stands in direct tension with credit card evidence showing Expedia transactions on accounts linked to both Epstein and Maxwell. The subpoenas may have been searched under identifiers that did not match how the bookings were originally made (e.g., a different email address, phone number, or payment method). Alternatively, Expedia's record retention policies may not have extended back to the transaction dates. The five separate subpoenas sent to Expedia — including one routed through their registered agent with Maxwell's SSN and DOB — suggest prosecutors anticipated difficulty and escalated their demands.
4. The Visoski Subpoena: What Was Actually Demanded
The most substantive travel subpoena was directed not at airlines but at Epstein's chief pilot, Lawrence Visoski (EFTA00100372, July 9, 2019):
"Please produce any and all records, documents, instructions, memoranda, and papers in your care, custody, possession, or control, relating to airplanes owned, maintained, or controlled by Jeffrey Epstein, or any corporate entities associated with Jeffrey Epstein. Records should include, but not be limited to, the following:
- Any and all flight records; and
- Any and all flight manifests, or other documents reflecting flight passengers."
Statutes: 18 U.S.C. sections 1591, 2421, 2422, 2423, 371.
This subpoena yielded 1,022 pages — the largest single travel production. However, these are Epstein's own internal records. Visoski was Epstein's employee. The records reflect what Epstein's operation chose to document, not independent verification of who traveled where and when.
As noted elsewhere in these dossiers, a separate investigation found that pilot David Rodgers "would NOT go back to add in that passenger's name on prior flight logs" — meaning the logs are known to be incomplete by design, with passengers routinely omitted.
5. The Passport Subpoena
A separate subpoena went to the U.S. Department of State (EFTA00087001):
"All passport applications for the time period 1994 to the present"
for listed individuals (names redacted). The PQG shows zero returns linked to this subpoena. The State Department's response, if any, is not traceable in the production index under its original subpoena reference.
6. The June 2021 Outlier
One travel subpoena falls outside the January 2020 batch entirely. American Airlines received a separate grand jury subpoena dated June 29, 2021 (EFTA01660693):
"Please provide any and all records for booking reservations regarding upcoming inbound and outbound flights for the following individual:
Jesus Concepcion, DOB: 05/08/1973"
This subpoena cites USAO No. 2018R00463 and was signed by AUSA Camille L. Fletcher, referencing the NY Child Exploitation/Human Trafficking Task Force. It represents a different investigative thread — focused on a specific individual, seeking future travel (not historical records), and issued 18 months after the main airline batch.
7. What Was Never Subpoenaed
The travel subpoena record does not include several categories of records that would bear on private aviation travel patterns.
Private Aviation Infrastructure
Epstein's travel network was built on private aviation, not commercial airlines. He owned or controlled multiple aircraft (Boeing 727-200, Gulfstream G2B, Gulfstream IV, Bell 430 helicopter) and operated through Fixed Base Operators (FBOs) at airports including:
- Palm Beach International (FL)
- Cyril E. King (St. Thomas, USVI)
No subpoenas were issued to any FBO, charter company, or private aviation service provider in the corpus. FBOs maintain passenger manifests, fuel records, hangar logs, and catering orders. These record categories are not represented in the subpoena corpus.
Federal Records Never Demanded
| Record Type | Agency | What It Would Show | Subpoenaed? |
| ------------ | -------- | ------------------- | ------------- |
| FAA flight plans | FAA | Every private flight's origin, destination, route, tail number | No |
| CBP I-94 records | CBP | International arrivals/departures for named individuals | No |
| Customs declarations | CBP | What was declared on USVI/international arrivals | No |
| TSA screening records | TSA | Commercial boarding records | No |
| Tail number query (N-numbers) | FAA | All flights by specific aircraft registration | No |
The absence of subpoenas does not indicate these records were not obtained through other means (e.g., informal cooperation, internal government channels, or civil litigation discovery).
The government sourced 116 pages of immigration/travel records from its own agencies (USCIS/CBP) for the Maxwell prosecution, but these were obtained through internal channels, not grand jury subpoenas. No systematic canvass of federal aviation records appears in the subpoena corpus.
Private Charter Companies
No subpoenas were issued to NetJets, Flexjet, VistaJet, or any other private charter or fractional ownership company, despite Maxwell's documented commercial travel during the period she was evading law enforcement (July 2019 - July 2020).
8. Fulfillment Analysis
PQG Clause-Level Assessment
The PQG identified only 3 clauses across all 257 subpoenas with data_class='travel':
| "Any and all flight records" | Visoski subpoena (EFTA00100372) | UNFULFILLED |
| "Any and all flight manifests, or other documents reflecting flight passengers" | Visoski subpoena | UNFULFILLED |
| "All passport applications for the time period 1994 to the present" | State Dept. subpoena (EFTA00087001) | UNKNOWN |
Fulfillment rate for travel data class: 0.0% — the lowest of any data class alongside
identification (also 0.0%).
This metric is largely a classifier artifact: the PQG's automated classifier tagged most airline subpoena clauses as personnel or bank_records rather than travel because the rider text requests "passenger, payment, membership or loyalty" records. The semantic content is travel-related, but the keyword classifier was distracted by financial terminology. When assessed at the category level (all airline/travel subpoenas), the corrected fulfillment rate is 77.1% — though this reflects keyword hits against production index cover letters, not verified delivery of actual travel data.
Comparative Data Class Fulfillment
| Data Class | Clauses | Fulfilled | Rate |
| ----------- | --------- | ----------- | ------ |
| bank_records | 1,870 | 989 | 52.9% |
9. Investigative Gaps Identified
The PQG flagged 8 travel-related investigative gaps:
HIGH Severity (Unfulfilled Demands)
Note: As documented above, the production index shows both Delta (6 pages) and Southwest (17 pages) did respond. The PQG matching algorithm failed to link these returns to their originating subpoenas. These are database-matching artifacts, not actual investigative gaps.
MODERATE Severity (Partial Responses)
- United Airlines: 2 clauses fulfilled, 1 unfulfilled (missing
bank_records class)
- American Airlines: 7 clauses fulfilled, 1 unfulfilled (missing
phone_records class)
10. Structural Observations
The investigation subpoenaed commercial airlines for a suspect who primarily used private aircraft. Ghislaine Maxwell's travel with Epstein was overwhelmingly on his private fleet — the 727 ("Lolita Express"), Gulfstream jets, and helicopter. Commercial airline records would capture only a fraction of her actual travel pattern.
The date ranges reflect the prosecution's charging focus. The subpoenas asked for 1994-1998 and July-January 2020, skipping the entire period 1999-2019. The first range covers the original trafficking period charged in the Maxwell indictment. The second covers Maxwell's post-Epstein-death movements while evading arrest. Prosecutors may have obtained 1999-2019 records through separate channels not reflected in this corpus.
The Airline Reporting Corporation was the most strategically important target yet produced only 2 pages. ARC processes ticket transactions across all airlines and travel agencies. A robust ARC response would have provided a single-source overview of all commercial ticket purchases. Two pages for a 26-year request window suggests either Maxwell did not fly commercially under her own name, or ARC's response was incomplete.
The Shoppers Travel production (19 pages) was not preceded by any subpoena in the PQG corpus. This travel agency either received a separate subpoena not captured in the EFTA corpus, or produced records voluntarily in response to informal government contact.
No follow-up subpoenas were issued after the January 2020 batch, despite the minimal returns. The Jesus Concepcion subpoena (June 2021) represents a different investigative thread, not a follow-up on the Maxwell travel canvass.
11. Date Range Anomaly
The airline subpoenas' two date windows — January 1, 1994 to December 31, 1998 and July 1, 2019 to January 23, 2020 — create a deliberate 20-year gap. This gap encompasses:
- Maxwell's documented extensive travel with Epstein (1999-2005)
- The Florida investigation period (2005-2008)
- The NPA period (2008-2019)
- Maxwell's post-conviction travel with and on behalf of Epstein (2008-2019)
The first window (1994-1998) aligns with Counts One and Two of the Maxwell indictment (conspiracy to entice/transport minors). The second window (July-January 2020) targets Maxwell's movements during the period she was believed to be evading law enforcement.
The absence of the 1999-2019 period from the airline subpoenas does not necessarily indicate an investigative oversight. Prosecutors may have obtained travel records for those years through other means (e.g., direct cooperation from airlines without formal subpoenas, or internal government records). However, no such alternative source is documented in the production corpus.
Verification Instructions
All EFTA citations link to the DOJ's public release at justice.gov. To verify any finding:
Click the EFTA hyperlink to access the source document
Production index entries are at EFTA00040593 (Maxwell case discovery index)
Expedia "no records" letter is at EFTA01265456
Credit card records showing Expedia charges: EFTA01704293 (Maxwell AMEX) and EFTA01703216 (Epstein AMEX)
Visoski subpoena rider: EFTA00100372, page 2
This dossier is part of the Prosecutorial Query Graph Lines of Investigation series. See 00_INDEX.md for methodology and the complete list of dossiers.