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1.75 MB
Extraction Summary
7
People
3
Organizations
1
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal motion / court filing (page 4)
File Size:
1.75 MB
Summary
This document is a legal filing (page 4) arguing that Defendant Alan Dershowitz must produce witnesses, including Jeffrey Epstein and Ghislaine Maxwell, if he wishes to pursue issues regarding Bill Clinton's travel. It highlights that Dershowitz invoked attorney-client privilege during his January 2016 deposition when asked if Virginia Roberts was lying about Clinton socializing with Epstein. It also notes Epstein's refusal to be deposed despite court orders.
People (7)
| Name | Role | Context |
|---|---|---|
| Bill Clinton | Former President |
Traveled on Epstein's plane; alleged to have visited the island; subject of deposition questioning regarding socializ...
|
| Jeffrey Epstein | Financier / Client |
Owner of private plane; client of Dershowitz; party to joint defense agreement; avoiding deposition despite court order.
|
| Alan Dershowitz | Defendant / Attorney |
Being deposed; claims Epstein is his client; party to joint defense agreement.
|
| Ghislaine Maxwell | Associate |
Witness alleged to be present on island; party to joint defense agreement with Dershowitz.
|
| Virginia Roberts | Plaintiff / Accuser |
Mentioned in deposition question regarding her truthfulness about Clinton and Epstein socializing.
|
| Mr. Edwards | Counsel |
Lawyer present at deposition asking questions.
|
| Mr. Cassell | Counsel |
Lawyer present at deposition asking questions (likely Paul Cassell).
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| C.I.A. |
Cited in legal precedent (Wilbur v. C.I.A.).
|
|
| House Oversight Committee |
Source of the document (footer).
|
|
| The Court |
The body ruling on the motion and ordering depositions.
|
Timeline (2 events)
Unknown (Relevant time period)
Alleged visit by Bill Clinton to Epstein's island
The island
Locations (1)
| Location | Context |
|---|---|
|
Location where Clinton was alleged to have visited.
|
Relationships (3)
Dershowitz claims Epstein is still his client; they have a joint defense agreement.
Dershowitz testified he is party to a joint defense agreement with her.
Flight records show they traveled together; Roberts alleged they socialized.
Key Quotes (4)
"public flight records from Jeffrey Epstein’s private plane show that President Clinton traveled with Jeffrey Epstein on multiple occasions."Source
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Quote #1
"Mr. Epstein has taken extreme measures to avoid being deposed in this case despite being ordered to deposition by this Court."Source
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Quote #2
"“Was Virginia Roberts lying when she said Jeffrey Epstein socialized with Bill Clinton during the relevant time period?”"Source
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Quote #3
"Before Defendant Dershowitz could answer, Mr. Dershowitz’s legal counsel interposed an attorney-client privilege objection."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,289 characters)
whether other responsive records may exist, but whether the search was adequate.”); Wilbur v.
C.I.A., 355 F.3d 675, 678 (D.C. 2004) (court explaining that “the agency’s failure to turn up a
particular document, or mere speculation that as yet uncovered documents might exist, does not
undermine the determination that the agency conducted an adequate search for the requested
records.”). Moreover, when dealing with a former President’s security detail travel, there are a
number of reasons why the government may not disclose those records.
C.I.A., 355 F.3d 675, 678 (D.C. 2004) (court explaining that “the agency’s failure to turn up a
particular document, or mere speculation that as yet uncovered documents might exist, does not
undermine the determination that the agency conducted an adequate search for the requested
records.”). Moreover, when dealing with a former President’s security detail travel, there are a
number of reasons why the government may not disclose those records.
As explained above, public flight records from Jeffrey Epstein’s private plane show that
President Clinton traveled with Jeffrey Epstein on multiple occasions. Nevertheless, if Defendant
Dershowitz wants to pursue this issue before the Court, then he needs to produce for deposition
testimony in this case and the proposed criminal investigation, the other witnesses that were
present on the island at the time former President Clinton was alleged to have visited, including
his client Jeffrey Epstein, and Ghislaine Maxwell, to whom he has testified he is party to a joint
defense agreement. It is worth noting on that point, that despite Mr. Epstein’s counsel’s
attendance at depositions in this case, and Defendant Dershowitz’s claim that Mr. Epstein is still
his client, Mr. Epstein has taken extreme measures to avoid being deposed in this case despite
being ordered to deposition by this Court.
President Clinton traveled with Jeffrey Epstein on multiple occasions. Nevertheless, if Defendant
Dershowitz wants to pursue this issue before the Court, then he needs to produce for deposition
testimony in this case and the proposed criminal investigation, the other witnesses that were
present on the island at the time former President Clinton was alleged to have visited, including
his client Jeffrey Epstein, and Ghislaine Maxwell, to whom he has testified he is party to a joint
defense agreement. It is worth noting on that point, that despite Mr. Epstein’s counsel’s
attendance at depositions in this case, and Defendant Dershowitz’s claim that Mr. Epstein is still
his client, Mr. Epstein has taken extreme measures to avoid being deposed in this case despite
being ordered to deposition by this Court.
Indeed, it is also noteworthy that during Defendant Dershowitz’s recent deposition,
counsel for Mr. Edwards and Mr. Cassell asked Defendant Dershowitz the following question:
“Was Virginia Roberts lying when she said Jeffrey Epstein socialized with Bill Clinton during the
relevant time period?” Depo Tr. Of Alan Dershowitz, Vol. 4, January 12, 2016 at 511. Before
Defendant Dershowitz could answer, Mr. Dershowitz’s legal counsel interposed an attorney-client
privilege objection. Id. Perhaps Mr. Epstein’s defense counsel can provide to the Court an
appropriate privilege log regarding that objection – and all the communications between Mr.
Epstein and Defendant Dershowitz that would have been revealed in answer to that question – so
that the Court will have the benefit of a full record in ruling on this motion.
4
counsel for Mr. Edwards and Mr. Cassell asked Defendant Dershowitz the following question:
“Was Virginia Roberts lying when she said Jeffrey Epstein socialized with Bill Clinton during the
relevant time period?” Depo Tr. Of Alan Dershowitz, Vol. 4, January 12, 2016 at 511. Before
Defendant Dershowitz could answer, Mr. Dershowitz’s legal counsel interposed an attorney-client
privilege objection. Id. Perhaps Mr. Epstein’s defense counsel can provide to the Court an
appropriate privilege log regarding that objection – and all the communications between Mr.
Epstein and Defendant Dershowitz that would have been revealed in answer to that question – so
that the Court will have the benefit of a full record in ruling on this motion.
4
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