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Jeffrey Epstein. Defendant spends over five (5) pages discussing the federal action and eleven (11) of his subpoena Requests (Jane Doe Subpoena 1, 5, 6, 7, 8, 9, 12, 13, 14, 22 and 24; BSF Subpoena 3, 6, 7, 8, 9, 10, 12, 13, 14, 19 and 22) relate to the federal action or Jeffrey Epstein. For example, Request 24 seeks “All documents concerning, relating or referring to your assertion that you met former President Bill Clinton, former Vice President Al Gore and/or Mary Elizabeth “Tipper” Gore on Little Saint James Island in the U.S. Virgin Islands.” Defendant claims that this discovery would go to the issue of whether or not Giuffre is telling the truth about Defendant — but that effort at impeachment is clearly collateral at best and fails to address the central issue in this case. That issue is whether the Defendant had any basis to support his media assault against two lawyers claiming that they fabricated and then publicly filed false charges of criminal conduct on the part of the Defendant. It is the Defendant’s credibility and not the credibility of Giuffre that is the focus of this defamation action. Defendant suggests that Giuffre must be a liar because it would be unheard of for one of Epstein’s young girls to have met President Clinton. Quite the opposite is true. There are a number of accounts documenting Clinton’s regular visits with Epstein. For example, Chauntae Davies recently showed pictures on The Inside Edition program of her travels with other young women in the company of Bill Clinton and Jeffrey Epstein on Epstein’s plane. See Exhibit 4, ‘Lolita Express’ Masseuse Reveals Lurid Details from Jeffrey Epstein’s Private Plane For the Rich, Inside Edition, April 27, 2015. The Epstein flight logs also demonstrate that former President Bill Clinton traveled with Jeffrey Epstein and other young women. See Exhibit 5, The Gauker, January 22, 2015. All of that information, while no doubt interesting, is irrelevant to the defamation issue before this Court except to the extent it casts doubt on the Defendant’s own credibility. HOUSE_OVERSIGHT_010907