HOUSE_OVERSIGHT_011379

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Based on my experience, knowledge, and duties of these

protocols in the USS Protective Details of Special Agents, a

company escorting Mr. Clinton" so he is relying on his

expertise as a former FBI head in order to opine on whether or not these records are correct, your Honor.

They disclosed him as a lay witness in this case, not an aS an expert witness. We went through a series -- as you

know your Honor, you've seen all the expert depositions in this

case that we've had. They say, "Well, you could have deposed

him as a lay witness."

Your Honor, will remember, we were very limited. We

were limited to ten depos. We had to beg, borrow, and steal to

get a few more, and we had to be very careful in who we picked

and chose with respect to establishing our claims. If we had

known, of course, that Mr. Freeh was going to be put on the

stand as an expert in this case, we, of course, would have

sought his deposition through the expert process. So, your Honor, I think those documents speak for

themselves. They're very clear, that's GMO0O526, where he's

giving that clear opinion. The letter is sent to

Mr. Dershowitz and he signs it, and then it has the relevant

attachments. So, your Honor, we firmly believe that that

should be kept out of evidence because he was not disclosed properly as an expert in this case.

The other thing I want to point your attention to is

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

HOUSE_OVERSIGHT_011379