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Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 23 of 34 14. Copies of any and all documents evidencing that the attorneys for the Jane Does acted “in bad faith in an effort to have the media report it” as described in paragraph 9 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. 15. Copies of any and all documents reflecting that Jane Doe #3 has charged President Bill Clinton with having sex with her on Jeffrey Epstein’s Little Saint James Island. 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. 16. Copies of any and all documents reflecting that Jane Doe #3 has alleged that President Bill Clinton had sex or engaged in any inappropriate contact with her on the Island owned by Jeffrey Epstein. 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. 17. Copies of all pages of Passports held by you at any time during the past 12 years. RESPONSE: Defendant objects to this Document Request as seeking sensitive personal information and documents that are not relevant to the subject matter of the pending action. HOUSE_OVERSIGHT_014106