Epstein Secrets

ntered on FLSD Docket 03/24/2015 Page 8 of 34 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CAC

non-privileged documents currently in his possession, custody or control. 11. | Copies of any and all documents tending to establish that President Clinton has never visited Jeffrey Epstein’s island, Little Saint James, as described in paragraph 8 of the sworn Declaration of Alan M. Dershowitz. RESPONSE

f any and all documents tending to establish that President Clinton has never visited Jeffrey Epstein’s island, Littl

ocuments currently in his possession, custody or control. 16. Copies of any and all documents reflecting that Jane Doe #3 has alleged that President Bill Clinton had sex or engaged in any inappropriate contact with her on the Island owned by Jeffrey Epstein. RESPONSE: Subject to and without waiving the Gener

ing # 37357304 E-Filed 02/03/2016 12:44:44 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CAC

at Roberts made false statements in a publicly filed affidavit about being present at a private island in the US Virgin Islands when former President Clinton was there. Indeed, former FBI Director Louis Freeh determined based on the response of the federal government to a FOIA request that the absence of r

ivate island in the US Virgin Islands when former President Clinton was there. Indeed, former FBI Director Louis Free

R. Civ. P. 1.280(c). Defendant’s overly broad subpoena to non- party, Jane Doe No. 3, goes so far as to seek documents relating to former President, Bill Clinton and former Vice President, Al Gore, which, even if such documents existed, would be absolutely irrelevant to the Florida Defamation Action. See Toled

dually, and L.M., individually, Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.:

me what the names of the people are that you remember that you consider to be famous people. V: Ok, there was Naomi Campbell, Heidi Klum, there was Bill Clinton. There was Al (?) Gore, there was a whole bunch of models, I wouldn’t really honestly be able to give their names. There was Matt Groning the produce

fortable in responding to, then don’t hesitate to tell me that. Do you have any recollection of Jeffrey Epstein’s specifically telling you that “Bill Clinton owes me favors”? Vv: Yes. I do. It was a laugh though. He would laugh it off. You know, I remember asking Jeffrey what’s Bill Clinton doing here kin

_OVERSIGHT_017489 --- PAGE BREAK --- Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA GENERAL JURIS

aying to the investors -- ] recall having a conversation prior to the investors coming in with Russ Adler and Russ had told me that Epstein had flown Bill Clinton on his plane, had flown Prince Andrew on his plane. And ] don't remember whether that was on any of the flight manifests or not, but ] left that to

ince Andrew flew on 11 Mr, Epstein’ s plane. 12 Q. And is it your testimony today that you fi3 never looked at the manifest to see whether Bill 14 — Clinton or Prince Andrew's name were really on the f15 manifest that you were going to use to pitch the [16 investors? 17 A. It was my understanding they did