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stricken in relevant part from the record by the federal court, but Roberts’s counsel filed publicly
a pleading in this case contesting Defendant’s assertion that her statements in the media
regarding meeting former President Clinton were untrue. A copy of the public affidavit filed in
the CVRA Action and the excerpted portion of the pleading filed in this action are attached
hereto as composite Exhibit A.
Because former President Clinton did not leave office until January of 2001, and Roberts
has repeatedly stated in publicly filed affidavits that she “escaped” from Epstein while in
Thailand in September of 2002, the alleged meeting with former President Clinton must have
taken place between January of 2001 and September of 2002. As explained in the letter attached
as Exhibit B, former FBI Director Louis Freeh made a request pursuant to the Freedom of
Information Act for documents from the Secret Service regarding Secret Service personnel
travelling with former President Clinton to Epstein’s private island and the US Virgin Islands.
Based on the response by the federal government to this request, and his knowledge of the duties,
protocols and operations of security provided to a former President, Mr. Freeh opines in the
attached letter that the absence of such records “strongly establishes that former President
Clinton was not present on Little St. James Island during the period at issue.” If Mr. Freeh’s
opinion is correct, then Roberts’s publicly filed affidavits in which she stated that she met
President Clinton on the island during that period are obviously false. Dershowitz intends to
bring this public information to the attention of the appropriate authorities.
Separate from the public information, Dershowitz also believes that Roberts gave false
testimony at her deposition. The relevant testimony, which Dershowitz intends to provide to the
appropriate authorities, is being filed under seal contemporaneously with this motion. In an
abundance of caution, Dershowitz and his counsel do not want to disclose this non-public
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