Epstein Secrets

[email protected], to: Sigrid S. McCawley, Esq., Boies Schiller & Flexner, LLP, 401 E. Las Olas Blvd, Suite 1200, Ft. Lauderdal

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

true and correct copy of an article by Sharon Churcher entitled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill Clinton,” DAILY MAIL, dated March 5, 2011. 4. Attached as Exhibit C is a true and correct copy of a statement on behalf of Ms. Maxwell dated March 9, 2011.

laration of Laura A. Menninger in Support of Defendant’s Motion for Summary Judgment via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 [email protected] [email protected] Bradley J. Edwards FARMER, JAFFE, WEISSIN

bought her. out’ SHARE THIS RELATED ARTICLES ARTICLE FBI to reopen case = Epstein’s Girl Friday http:/Awww.dailym ail.co.uk/news/article- 1363452/Bill-Clinton- 15-year-old-masseuse-|-met-twice-claims-Epsteins-girl.htm! 1/31 HOUSE_OVERSIGHT_014669 --- PAGE BREAK --- Case 1:15-cv-07433-RWS Document 539-2 Fi

, foreign presidents, and world leaders are highly relevant and admissible (Motion in Limine 1) ..00...0.. eee eceeeeeeeeeeeeeeteeneene 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion in Limine 2)..... 8 FOIA responses and related materials are admissible (Motion in Limine 3)......

. eee eceeeeeeeeeeeeeeteeneene 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion

rved this Defendant’s Response in Opposition to Plaintiff's Omnibus Motion In Limine via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 [email protected] [email protected] Bradley J. Edwards FARMER, JAFFE, WEISSIN