Document request seeks evidence that President Clinton never set foot on Jeffrey Epstein’s island

Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 21 of 34 RESPONSE: Defendant objects to this Document Request to the extent that Plaintiffs seek to alter or shift any burdens of proof as a matter of law in this action. Subject to and without waiving the foregoing specific objections and General Objections, Defendant responds that he will produce all responsive, non-privileged documents currently in his possession, custody or control. 10. | Copies of any and all documents supporting the allegation that “Jane Doe #3 is a serial liar” as described in paragraph 8 of the sworn Declaration of Alan M. Dershowitz. RESPONSE: Subject to and without waiving the General Objections, Defendant responds that he will produce all responsive, 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: 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, | have been advised that Secret Service records would confirm that President Clinton has never set foot on that island.” (Emphasis added). Subject to and without waiving the foregoing specific objections and the General Objections, Defendant responds that he has no responsive, non- privileged documents. HOUSE_OVERSIGHT_014104