Allegations of Clinton's Travel on Epstein Plane and Potential Undisclosed Deposition Evidence

whether other responsive records may exist, but whether the search was adequate.”); Wilbur v. CLA., 355 F.3d 675, 678 (D.C. 2004) (court explaining that “the agency’s failure to turn up a particular document, or mere speculation that as yet uncovered documents might exist, does not undermine the determination that the agency conducted an adequate search for the requested records.”). Moreover, when dealing with a former President’s security detail travel, there are a number of reasons why the government may not disclose those records. As explained above, public flight records from Jeffrey Epstein’s private plane show that President Clinton traveled with Jeffrey Epstein on multiple occasions. Nevertheless, if Defendant Dershowitz wants to pursue this issue before the Court, then he needs to produce for deposition testimony in this case and the proposed criminal investigation, the other witnesses that were present on the island at the time former President Clinton was alleged to have visited, including his client Jeffrey Epstein, and Ghislaine Maxwell, to whom he has testified he is party to a joint defense agreement. It is worth noting on that point, that despite Mr. Epstein’s counsel’s attendance at depositions in this case, and Defendant Dershowitz’s claim that Mr. Epstein is still his client, Mr. Epstein has taken extreme measures to avoid being deposed in this case despite being ordered to deposition by this Court. Indeed, it is also noteworthy that during Defendant Dershowitz’s recent deposition, counsel for Mr. Edwards and Mr. Cassell asked Defendant Dershowitz the following question: “Was [REDACTED] lying when she said Jeffrey Epstein socialized with Bill Clinton during the relevant time period?” Depo Tr. Of Alan Dershowitz, Vol. 4, January 12, 2016 at 511. Before Defendant Dershowitz could answer, Mr. Dershowitz’s legal counsel interposed an attorney-client privilege objection. /d. Perhaps Mr. Epstein’s defense counsel can provide to the Court an appropriate privilege log regarding that objection — and all the communications between Mr. Epstein and Defendant Dershowitz that would have been revealed in answer to that question — so that the Court will have the benefit of a full record in ruling on this motion. 4 HOUSE_OVERSIGHT_015653