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10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 49 H3VOGIU1 Jeffrey Epstein and Virginia Roberts. Plaintiff's counsel has said statements made in the newspaper articles are hearsay. That is often true, but when it's plaintiff's statement in a news article, it's calleda party admission. Plaintiff complains that she didn't have the opportunity to depose President Clinton. Your Honor, plaintiff's counsel sought to depose President Clinton in their reply brief at the end of June, 2016, about a week before discovery was to close. They didn't even mention it in their opening brief, they raised it in docket number 211. In that request, which I didn't have an opportunity to object to because it came in reply, she said she wanted to depose him to, "establish his close personal relationship with Epstein", she said nothing about wanting to s whether he had been on the island, whether he flew in a helicopter, or anything like that. With regard to Louie Freeh, your Honor, we disclosed him as a witness in our Rule 26 disclosures last March -- xcuse m February of 2016. Plaintiff made no effort to try to depose him, made no effort to find out his basis of knowledge. We produced in discovery his report in which he submitted a FOIA request. Yesterday, you will recall Ms. McCawley testifying about how she, herself, issued a FOIA request and got in SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011352