15 H3VOGIU1 ih says we've looked and we can't find these records that you've 2 requested. 3 Now, it doesn't address the fact that the government 4 only typically retains records for a few years when they were 5 requesting records from 15 years ago, so it doesn't have the 6 indicia of trustworthiness to be able to say that this is 7 actually the fact because, of course, as we know, the 8 government regularly has to get rid of records. 9 So to use this letter to say, 'Ah-hah, he was never on 10 the island,' when we never got to examine him under oath and 1a say, 'You traveled with him a bunch. Did you also go to the 12 island? My client says she met you there.' We didn't get to 13 ask those questions, so we're in a situation now where that 14 letter coming in would be highly prejudicial because the jury 15 will wonder, well, what does he have to say about this? And we 16 haven't been in a position to be able to do that. de So your Honor, for all those reasons we believe that 18 Mr. Freeh should be excluded, the FOIA letter should not come igs) into evidence, and again, we believe that the issue of 20 Mr. Clinton should not be an issue relevant to this trial. 21 Next, your Honor, they also seek to include 22 statements, hearsay statements and newspaper articles about 23 Prince Andrew, and it's actually not his denial, as I 24 understand it, Buckingham Palace's denial of the allegation of 25 my client. But again, Prince Andrew is not on the witness SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011318