49 H3VOGIU1 ih Jeffrey Epstein and Virginia Roberts. 2 Plaintiff's counsel has said statements made in the 3 newspaper articles are hearsay. That is often true, but when 4 it's plaintiff's statement in a news article, it's calleda 5 party admission. 6 Plaintiff complains that she didn't have the 7 opportunity to depose President Clinton. Your Honor, 8 plaintiff's counsel sought to depose President Clinton in their 9 reply brief at the end of June, 2016, about a week before 10 discovery was to close. They didn't even mention it in their 1a opening brief, they raised it in docket number 211. 12 In that request, which I didn't have an opportunity to 13 object to because it came in reply, she said she wanted to 14 depose him to, "establish his close personal relationship with 15 Epstein", she said nothing about wanting to see whether he had 16 been on the island, whether he flew in a helicopter, or de anything like that. 18 With regard to Louie Freeh, your Honor, we disclosed 19 him as a witness in our Rule 26 disclosures last March -- 20 excuse me -- February of 2016. Plaintiff made no effort to try 21 to depose him, made no effort to find out his basis of 22 knowledge. We produced in discovery his report in which he 23 submitted a FOIA request. 24 Yesterday, you will recall Ms. McCawley testifying 25 about how she, herself, issued a FOIA request and got in SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011352