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1.43 MB

Extraction Summary

4
People
3
Organizations
1
Locations
1
Events
2
Relationships
2
Quotes

Document Information

Type: Court filing (response to request for production)
File Size: 1.43 MB
Summary

This document is page 21 of a legal response entered on March 24, 2015, in the Florida Southern District Court. The Defendant (referencing Alan Dershowitz) agrees to produce documents supporting the claim that 'Jane Doe #3 is a serial liar.' However, regarding the request for documents proving President Clinton never visited Little Saint James, the Defendant objects, clarifying that his declaration relied on information regarding Secret Service records, and states he personally has no responsive documents to produce on that matter.

People (4)

Name Role Context
Alan M. Dershowitz Defendant/Declarant
Author of the sworn declaration referenced in requests 10 and 11; the responding party.
Jane Doe #3 Plaintiff/Subject
Subject of an allegation described as a 'serial liar' in Dershowitz's declaration.
President Clinton Subject of Inquiry
Subject of a document request regarding whether he visited Epstein's island.
Jeffrey Epstein Associate
Owner of Little Saint James island.

Organizations (3)

Name Type Context
Secret Service
Agency whose records are cited by Dershowitz as proof regarding Clinton's travel.
FLSD
Florida Southern District Court (mentioned in header).
House Oversight
Committee referenced in the footer stamp.

Timeline (1 events)

Unknown
Alleged visit by President Clinton to Little Saint James (denied in the text).
Little Saint James

Locations (1)

Location Context
Jeffrey Epstein's island, the location Clinton is alleged to have visited or not visited.

Relationships (2)

Alan M. Dershowitz Adversarial Jane Doe #3
Dershowitz alleges she is a 'serial liar' in his declaration.
Alan M. Dershowitz Professional/Defense President Clinton
Dershowitz cites Secret Service records to defend Clinton against allegations of visiting Epstein's island.

Key Quotes (2)

"“Jane Doe #3 is a serial liar”"
Source
HOUSE_OVERSIGHT_014104.jpg
Quote #1
"“on information and belief, I have been advised that Secret Service records would confirm that President Clinton has never set foot on that island.”"
Source
HOUSE_OVERSIGHT_014104.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (1,580 characters)

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, I 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 General Objections, Defendant responds that he has no responsive, non-privileged documents.
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