Defendant objects to document requests about alleged lies by Jane Doe #3 and a dropped Palm Beach State Attorney case

Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 22 of 34 12. Copies of any and all documents evidencing that Jane Doe #3 “has also told lies about many world leaders” as described in paragraph 8 of the sworn Declaration of Alan M. Dershowitz. RESPONSE: Defendant objects to this Document Request because it misstates paragraph 8 of the sworn Declaration of Alan M. Dershowitz, which expressly states that “on information and belief, [Jane Doe #3] has also told lies about many world leaders.” (Emphasis added). Defendant further objects to this Document Request because it seeks documents already in Plaintiffs’ possession and/or that are publicly available. Subject to and without waiving the foregoing specific objections and the General Objections, Defendant responds by reference to statements by Jane Doe #3 reflected in the media, which are equally available to Plaintiffs. 13. Copies of any and all documents evidencing that “the State Attorney in Palm Beach County dropped a case that she sought to bring based on an assessment by the investigating detective regarding the ‘victim’s lack of credibility’” including a copy of the letter reflecting this decision as described in paragraph 8 of the sworn Declaration of Alan M. Dershowitz. RESPONSE: Defendant objects to this Document Request because it misstates paragraph 8 of the sworn Declaration of Alan M. Dershowitz, which expressly states that “on information and belief, the State Attorney in Palm Beach County dropped a case that she sought to bring based on an assessment by the investigating detective regarding the ‘victim’s lack of credibility.’ A copy of the letter reflecting this decision was forwarded to central records.” (Emphasis added). Subject to and without waiving the foregoing specific objections and the General Objections, Defendant responds that he will produce all responsive, non-privileged documents currently in his possession, custody or control. HOUSE_OVERSIGHT_014105