WILLIAMS & CONNOLLY LLP
Hon. James Comer
Hon. Robert Garcia November 3, 2025 Page 2

compel Attorney General Bondi to release what you have stated is a large trove of unseen files, which the public to date is still waiting to see released.

Your October 22 letter does not provide a persuasive rationale for why deposing the Clintons is required to fulfill the mandate of your investigation, particularly when what little information they have may be efficiently obtained in writing.

You state that your investigation into the “mismanagement” of the Epstein and Maxwell investigations and prosecutions requires the depositions of three individuals: former President Clinton, former Secretary of State Clinton, and former Attorney General William Barr – who was serving in the first Trump Administration when Jeffrey Epstein committed suicide in federal custody. Compounding this inexplicable choice of deponents, you also have chosen not to depose the dozens of individuals whose links to Mr. Epstein have been publicly documented.

My clients have been private citizens for the last 24 and 12 years, respectively. President Clinton’s term ended six (6) years before allegations surfaced against Mr. Epstein. Former Secretary of State Clinton’s position was in no way related to law enforcement and is completely afield of any aspect of the Epstein matter. While neither of my clients have anything to offer for the stated purposes of the Committee’s investigation, subpoenaing former Secretary Clinton is on its face both purposeless and harassing. I set forth in my October 6 letter the facts that she did not know Epstein, did not travel with him, and had no dealings with him. Indeed, when I met with your staff to learn your basis for including former Secretary Clinton, none was given beyond wanting to ask if she had ever spoken with her husband about this matter. Setting aside the plainly relevant consideration of marital privilege, this is an entirely pretextual basis for compelling former Secretary Clinton to appear personally in this matter.

It is incumbent on the Committee to address the most basic questions regarding the basis for singling out the Clintons, particularly when there is no obvious or apparent rationale for it, given the mandate of the Committee’s investigation. Your October 22 letter does not provide such a justification. And your previous statements, belied by the facts, that President Clinton is a “prime suspect” (for something) because of visits to Epstein’s island betokens bias, not fairness. You said, on August 11:

“Everybody in America wants to know what went on in Epstein Island, and we’ve all heard reports that Bill Clinton was a frequent visitor there, so he’s a prime suspect to be deposed by the House Oversight Committee.”

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Regrettably, such statements are not the words of an impartial and dispassionate factfinder. In fact, President Clinton has never visited Epstein’s island. He has repeatedly stated that, the Secret Service has corroborated that denial, Ghislaine Maxwell’s recent testimony to Deputy Attorney General Blanche reconfirmed this, as did the late Virginia Roberts Giuffre in her

Fields, “Comer: Bill Clinton ‘Prime Suspect’ in Epstein Investigation,” The Hill (Aug. 12, 2025).