Epstein Secrets

ssell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone

the bait. “‘I’d have been about 17 at the time,’ [Jane Doe #3] says. ‘I flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill [Clinton] in a huge black helicopter that Jeffrey had bought her. She’d always wanted to fly and Jeffrey paid for her to take lessons, and I remember she was

AK --- Case 9:08-cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 10 of 19 detail about her fictional meeting with former President Clinton, providing an elaborate description about how Mr. Clinton and his secret service detail somehow allowed Ghislaine Maxwell, then a novice helicopter p

9 detail about her fictional meeting with former President Clinton, providing an elaborate description about how Mr.

ell Pro Hac Vice S.J. Quinney College of Law at the University of Utah" 332 S. 1400 E. Salt Lake City, UT 84112 Telep

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

ce Motion Pending S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112

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

e hearing. None did. Cassell, a law professor at the University of Utah, shrugged off the government's new claims, call-

neth Starr, whose investigation led to President Bill Clinton's im- peachment, contacted high-level to convict

Starr, whose investigation led to President Bill Clinton's im- peachment, contacted high-level to convict