On the next page or two it goes on to say that whole story is probably fictitious and Bill was likely never there.

Edit: Found it (sorry for the fomatting)

Former FBI Director Louis Freeh submitted a report wherein he concluded that 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.” Menninger Decl., Ex. C. Further, if any Secret Service agents had accompanied Clinton to that location, “they would have been required to make and file shift logs, travel vouchers, and related documentation relating to the visit,” and there was a “total absence” of any such documentation. Id. Remarkably, Plaintiff now even denies telling Churcher that she ever witnessed Ms. Maxwell flying President Clinton or his Secret Service anywhere, or joking with Clinton about “what a good job she did.” Menninger Decl., Ex. D. Plaintiff’s counsel remarkably instructed Plaintiff not to answer any additional questions about the other things Sharon Churcher inaccurately reported. Id. Lending even more incredulity to Plaintiff’s story, Ms. Maxwell only received her pilot’s license in mid-1999 casting insurmountable doubt that a recently retired president and his staff would be permitted to fly with her at the helm. With the record thus, Plaintiff’s claims about Clinton’s presence on the Island and the fully concocted story about the dinner party that occurred thereon totally debunked by the former head of the FBI and with Plaintiff now disclaiming she ever witnessed the Secret Service or Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 11 of 32 9 President Clinton being flown in a helicopter by Ghislaine Maxwell, the relevance of any testimony he might add (i.e., confirm that he was, as Louis Freeh determined, never on the Island) is non-existent. The only purpose for seeking this deposition is for the calculated media strategy that Plaintiff and her publicity-seeking attorneys have devised. Plaintiff failed to disclose President Clinton as a witness until June 1, failed to notice his deposition, failed to diligently pursue a subpoena on him and he has no relevant testimony to offer. Accordingly, Plaintiff’s leave to modify the scheduling order to permit his deposition should be denied