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id.

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15 H3VOGIU1

says we've looked and we can't find these records that you've requested.

Now, it doesn't address the fact that the government only typically retains records for a few years when they were requesting records from 15 years ago, so it doesn't have the

indicia of trustworthiness to be able to say that this is

actually the fact because, of course, as we know, the government regularly has to get rid of records.

So to use this letter to say, 'Ah-hah, he was never on

the island,' when we never got to examine him under oath and say, ‘You traveled with him a bunch. Did you also go to the island? My client says she met you there." We didn't get to

ask those questions, so we're in a situation now where that letter coming in would be highly prejudicial because the jury

will wonder, well, what does he have to say about this? And we

haven't been in a position to be able to do that.

So your Honor, for all those reasons we believe that

Mr. Freeh should b xcluded, the FOIA letter should not come into evidence, and again, we believe that the issue of

Mr. Clinton should not be an issue relevant to this trial.

Next, your Honor, they also seek to include statements, hearsay statements and newspaper articles about

Prince Andrew, and it's actually not his denial, as I

understand it, Buckingham Palace's denial of the allegation of

my client. But again, Prince Andrew is not on the witness

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

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