Plaintiffs, by counsel, respectfully submit this Motion for Leave to Supplement their Motion to Depose Defendant Hillary Rodham Clinton. As grounds therefor, Plaintiffs state as follows:

Although Plaintiffs have already provided substantial, compelling evidence demonstrating that Hillary Rodham Clinton was the mastermind of Filegate, ⁽¹⁾ new information revealed yesterday, November 29, 1999, further supports this. Last evening, NBC's Dateline broadcast that Mrs. Clinton "immediately went into battle mode" against Gennifer Flowers when she watched Ms. Flowers on television describing her relationship with Bill Clinton. See NBC News Transcripts, "Public Defender; Author Gail Sheehy on Life and Career of First Lady Hillary Rodham Clinton" (Nov. 29, 1999) at 1, attached as Exhibit 1. As part of this "battle mode," Mrs. Clinton "order[ed] up dirt on Gennifer Flowers," much the same way Plaintiffs allege she ordered up dirt on other perceived adversaries by planning and implementing Filegate. See id. (emphasis added).

A new biography on Mrs. Clinton by Gail Sheehy - who flew "knee to knee" with Mrs. Clinton during the 1992 presidential campaign (see id.) - further indicates that when Mrs. Clinton was asked at the time what she would have done if Gennifer Flowers had been standing in front of her, she stated she would have "crucified" her. See id. (emphasis added). This is the same Hillary Rodham Clinton that Ms. Sheehy says she still sees today (see id. at 2) - and the same Hillary Rodham Clinton that Plaintiffs have described to the Court.

Ms. Sheehy also states that Hillary Rodham Clinton "made the money . . . laid out the political strategy . . . [and] fought [her husband's] political battles." Id. at 3 (emphasis added). This comes as no surprise, and Plaintiffs have shown the Court how Mrs. Clinton went about fighting her husband's political battles and enemies - through ordering up and then using confidential information in their FBI files. Mrs. Clinton implemented her political espionage scheme by hiring trusted friends and cronies - such as Bernard Nussbaum, Vince Foster and William Kennedy - as well as "dirty tricks" operatives with histories of digging up "dirt" on perceived adversaries - such as David Craig Livingstone and Anthony Marceca - then placed these individuals in key positions where they would have access to FBI background investigation files.

This new evidence, in conjunction with that already on the record, not only warrants allowing Plaintiffs to depose Mrs. Clinton ⁽²⁾ forthwith, but it also mandates that Mrs. Clinton's summary

judgment motion be denied, even if consideration is not stayed pending the completion of full, general discovery.

Respectfully submitted,

JUDICIAL WATCH, INC.

_________________________

Larry Klayman, Esq.

DC Bar No. 334581

_________________________

Deborah E. Berliner

DC Bar No. 422238

501 School Street, SW, Suite 725

Washington, DC 20024

(202) 646-5172

Attorneys for Plaintiffs

On November 30, 1999, I contacted James J. Gilligan, Esq., counsel for Defendants Executive Office of the President and Federal Bureau of Investigation, and Paul B. Gaffney, Esq., counsel for Defendant Hillary Rodham Clinton, by telephone, to confer on this motion and inquire whether their clients would consent to the relief requested herein. Mr. Gilligan and Mr. Gaffney informed me that their clients would oppose this motion.

_____________________________

Deborah E. Berliner, Esq.

Upon consideration of PLAINTIFFS' MOTION FOR LEAVE TO SUPPLEMENT MOTION TO DEPOSE DEFENDANT HILLARY RODHAM CLINTON, any opposition thereto, and the entire record therein, it is hereby

ORDERED that:

1. Plaintiffs' motion is hereby granted.

2. Plaintiffs' Motion to Depose Defendant Hillary Rodham Clinton is hereby supplemented.

SO ORDERED.

DATE:____________________ ______________________________

The Honorable Royce C. Lamberth

United States District Judge

Copies to:

Attorneys for Plaintiffs:

Larry Klayman, Esq.

JUDICIAL WATCH, INC.

501 School Street, S.W.

Suite 725

Washington, DC 20024

Attorneys for Defendants Executive Office of the President and Federal Bureau of Investigation:

James J. Gilligan, Esq.

Elizabeth J. Shapiro, Esq.

U.S. DEPARTMENT OF JUSTICE

P.O. Box 883

Washington DC 20044

Attorneys for Defendant Hillary Rodham Clinton:

David E. Kendall, Esq.

Paul B. Gaffney, Esq.

WIILLIAMS & CONNOLLY

725 12th Street, N.W.

Washington, DC 20005

I hereby certify that on November 30, 1999 a true and correct copy of the foregoing PLAINTIFFS' MOTION FOR LEAVE TO SUPPLEMENT MOTION TO DEPOSE DEFENDANT HILLARY RODHAM CLINTON was served via first-class mail, postage prepaid, on the following:

Attorneys for Defendants Executive Office of the President and Federal Bureau of Investigation:

James J. Gilligan, Esq.

Elizabeth J. Shapiro, Esq.

U.S. DEPARTMENT OF JUSTICE

P.O. Box 883

Washington DC 20044

Attorneys for Defendant Hillary Rodham Clinton:

David E. Kendall, Esq.

Paul B. Gaffney, Esq.

WIILLIAMS & CONNOLLY

725 12th Street, N.W.

Washington, DC 20005

_________________________

Deborah E. Berliner

1. Much of this evidence was set forth for the Court in Plaintiffs' Motion for Leave to Depose Defendant Hillary Rodham Clinton (June 30, 1999), Plaintiffs' Supplemental Memorandum Concerning Substitution and Class Certification (Aug. 9, 1999), and Plaintiffs' reply briefs thereto, filed August 18, 1999 and November 9, 1999, respectively.

2. Plaintiffs will be moving to depose Ms. Sheehy, if the Court deems it necessary at this time to place her now public and uncontroverted statements about Mrs. Clinton's "dirt digging" modus operandi under oath.