76 H3VOGIU1 ih "Based on my experience, knowledge, and duties of these 2 protocols in the USS Protective Details of Special Agents, a 3 company escorting Mr. Clinton" -- so he is relying on his 4 expertise as a former FBI head in order to opine on whether or 5 not these records are correct, your Honor. 6 They disclosed him as a lay witness in this case, not 7 an aS an expert witness. We went through a series -- as you 8 know your Honor, you've seen all the expert depositions in this 9 case that we've had. They say, "Well, you could have deposed 10 him as a lay witness." apa: Your Honor, will remember, we were very limited. We 12 were limited to ten depos. We had to beg, borrow, and steal to 13 get a few more, and we had to be very careful in who we picked 14 and chose with respect to establishing our claims. If we had 15 known, of course, that Mr. Freeh was going to be put on the 16 stand as an expert in this case, we, of course, would have de sought his deposition through the expert process. 18 So, your Honor, I think those documents speak for 19 themselves. They're very clear, that's GMO0O526, where he's 20 giving that clear opinion. The letter is sent to 21 Mr. Dershowitz and he signs it, and then it has the relevant 22 attachments. So, your Honor, we firmly believe that that 23 should be kept out of evidence because he was not disclosed 24 properly as an expert in this case. 25 The other thing I want to point your attention to is SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011379