EFTA01112265

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 nol 
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 oaat 
is the focus of this defamation action. Defendant suggests that 
'ust 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, 
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. 
7 
EFTA01112285

EXHIBIT B 
EFTA01112286

Professor Alan Dershowitz 
Harvard Law School 
1575 Massachusetts Avenue 
Hauser Hall 518 
Cambridge, MA 02138 
Hon. Louis J. Freeh 
January 22, 2016 
RE: FOIA Request 
Dear Professor Dershowitz: 
As you know, on April 6, 2015, a request was made to the United States Secret Service under the federal 
Freedom of Information Act (FOIA; 5 U.S.C. Sec. 552), relating to the period 1/01/01 to 1/1/03, for "any 
and all shift logs, travel records, itineraries, reports and other records for USSS personnel traveling with 
former President Bill Clinton to Little St. James Island and the US Virgin Islands" (Attachment A). 
The basis of the above-described FOIA request was a claim b 
in court papers filed in 
early 2015 in Florida federal court, that she and former President 
inton were on Little St. James Island 
at the same time during the 1/01/01 to 1/1/03 period. 
As set forth in a January 16, 2016 letter from Kim E. Campbell, United States Secret service Special 
Agent In Charge, Freedom of Information Act and Privacy Act Officer, the "USSS has conducted a 
reasonable search for responsive records. It appears, from a review of USSS main indices, that there are 
no records pertaining to your request that are referenced in these indices" (Attachment B). 
I therefore conclude from this response that former President Clinton did not in fact travel to, nor was he 
present on, Little St. James Island between January 1, 2001 and January 1, 2003. 
Based upon my experience and knowledge of the duties, protocols and operations of USSS Protective 
Details, the Special Agents accompany and escort former President Clinton 24 hours per day, and would 
have certainly went with him to Little St. James Island during the period at issue. If the Agents had 
accompanied the former President to that location, they would had been required to make and file shift 
logs, travel vouchers and related documentation relating to the visit. 
The total absence of any such records and documentation, in my opinion, strongly establishes that former 
President Clinton was not present on Little St. James Island during the period at issue. 
Best Regards, 
Louie Freeh 
EFTA01112287

DEPARTMENT OF HOMELAND SECURITY 
UNITED STATES SECRET SERVICE 
WASHINGTON. D.C. 20223 
Freedom of Information Act and Privacy Act Branch 
Conununications Center 
245 Murray Lane, SW, Building T-5 
Washington, D.C. 20223 
Date: 
9ilic 
Patti Bescript 
3711 Kennett Pike, Suite 130 
Wilmington, DE 19807 
File Number: 20150826 
Dear Requester: 
This is the final response to your Freedom of Information Act/Privacy Acts (FOIA/PA) request 
originally received by the United States Secret Service (USSS) on April 16, 2015, for information 
pertaining to any and all shift logs, travel records, itineraries, reports, and other records for USSS 
personnel traveling with former President Bill Clinton to Little St. James Island and the US Virgin 
Islands. 
In response to your request, the USSS has conducted a reasonable search for responsive records. It 
appears, from a review of USSS main indices, that there are no records pertaining to your request 
that are referenced in these indices. Enclosed is a copy of your original request. 
Alternatively, if you deem our decision an adverse determination, you may exercise your appeal 
rights. Should you wish to file an administrative appeal, your appeal should be made in writing and 
received within sixty (60) days of the date of this letter, by writing to: Freedom of Information 
Appeal, Deputy Director, U.S. Secret Service, Communications Center, 245 Murray Lane, S.W., 
Building T-5, Washington, D.C. 20223. If you choose to file an administrative appeal, please 
explain the basis of your appeal and reference the case number listed above. 
If u have anquestions or would like to discuss this matter, please contact this office at 
FOIA File No. 20150826 is assigned to your request. Please refer to this file 
number in all future communication with this office. 
Sincerely, 
a: f ir aobi44----
S 
al Agent In Charge 
Freedom of Information Act & Privacy Act Officer 
Enclosure: Copy of Original Request 
EFTA01112288

Patti Bescript 
3711 Kennett Pike 
Suite 130 
Wilmington, DE 19807 
302 824 7144 
April 6, 2015 
Delores Barber 
Deputy Chief FOR Officer, Director, Disclosure & FOIA, The Privacy Office 
Department of Homeland Security 
Headquarters & Privacy Office 
Building 410 - STOP-0655 
245 Murray Drive, SW 
Washington, DC 20528-0655 
FOIA REQUEST 
Dear FOR Officer: 
Pursuant to the federal Freedom of Information Act, 5 U.S.C. § 552, I request access to 
and copies of For the period 1/1/01 to 1/1/03, any and all shift logs, travel records, 
itineraries, reports, and other records for USSS personnel traveling with former President 
Bill Clinton to Little St lames Island and the US Virgin Islands. 
Lagree to pay reasonable duplication fees for the processing of this request. 
If my request is denied m whole or part, I ask that you justify all deletions by reference to 
specific exemptions of the act I will also expect you to release all segregable portions of 
otherwise exempt material I, of course, reserve the right to appeal your decision to 
withhold any information or to deny a waiver of fees. 
I look forward to your reply within 20 business days, as the statute requires. 
Than/ 1$ you for your assistance 
Si7c ely, 
(
Ur
Patti Bescript 
EFTA01112289