From the Affidavit:

They would also have learned, if they did not already know, that Jane Doe #3 is a serial liar, whose uncorrobrated word should never be credited. She has claimed to have been with former President Clinton on Mr. Epstein’s island. She has provided specific and detailed information about Mr. Clinton’s activities on the island. Yet, on information and belief, I have been advised that Secret Service records would confirm that President Clinton has never set foot on that island. It has also been reported that she told her father that she met Queen Elizabeth. On information and belief, a check of the records of Buckingham Palace would disclose that Jane Doe #3 lied to her father about such a visit.

On information and belief, she has also told lies about many world leaders. Finally, on information and belief, the State Attorney in Palm Beach County dropped a case that she sought to bring based on an assessment by the investigating detective regarding the “victim’s lack of credibility.” A copy of the letter reflecting this decision was forwarded to central records. Her lawyers knew or should have known about her history of lying and her utter lack of credibility before filing an allegedly privileged legal statement that asserts false and defamatory information about a fellow lawyer based on her word alone.

They placed it in a legal proceeding, in a public filing, in bad faith in an effort to have the media report it, while they attempt to hide behind claims of litigatio