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[an error occurred while processing this directive]	Email this case summary Printer friendly page  Documents related to: ALEXANDER et al. v. FBI, et. al. Civil Action No. 96-2123. Judicial Watch is representing the plaintiffs in a class-action suit filed by White House employees of the Bush and Reagan administrations whose FBI files were wrongly accessed by the Clinton White House. The White House and FBI are being sued under the federal Privacy Act, while the individual defendants B Bernard Nussbaum, Craig Livingstone, Anthony Marceca and Hillary Clinton B are being sued for common-law tort of invasion of privacy. Deposition of MARI LYNNE ANDERSON - Thursday, May 7, 1998, Washington, D.C. PLAINTIFFS' MOTION TO COMPEL FURTHER TESTIMONY AND FURTHER PRODUCTION OF DOCUMENTS FROM KENNETH BACON AND FOR SANCTIONS - The release and misuse of over 900 FBI files is only part of a pattern of privacy violations by the Clinton Administration and its allies and agents. Letter to David Kendall regarding possibile deposition of Hillary Clinton 10/15/97. - I am writing to inquire about the availability of Hillary Rodham Clinton for deposition in the above captioned matter... Deposition of Jane Sherburne - Deposition taken in Filegate lawsuit (June 21, 1999) PLAINTIFFS' MOTION TO COMPEL FURTHER PRODUCTION OF DOCUMENTS FROM THE U.S. DEPARTMENT OF DEFENSE AND FOR SANCTIONS - The release and misuse of over 900 FBI files is only part of a pattern of privacy violations by the Clinton Administration and its allies and agents. No one is immune; whether it is Plaintiffs, Kenneth Starr, public interest groups, journalists, or even judges who make rulings against, or even criticize, the Administration... Deposition of LARRY POTTS - Tuesday, August 18, 1998, Washington, D.C. PLAINTIFFS' OPPOSITION TO MOTION OF LINDA R. TRIPP FOR A PROTECTIVE ORDER AND OBJECTION TO SUBPOENA - (Intro) Ms. Linda R. Tripp moves the court for a protective order and objects to Plaintiffs' subpoena regarding her upcoming, September 4, 1998 deposition. Although Plaintiffs agreed to postpone Mr. Tripp's deposition, first until after she had completed her grand jury testimony, then again to accommodate her schedule and the schedule of her counsel, she now objects to the timing of her deposition... Filegate deposition - Anthony Marceca (June 9, 1999) Plaintiffs' supplemental memorandum concerning substitution and class certification - Plaintiffs, by counsel and pursuant to the Court’s Memorandum Opinion and Order of April 21, 1999, respectfully submit this Supplemental Memorandum Concerning Substitution and Class Certification. Declaration of M. Dennis Sculimbrene - I, M. Dennis Sculimbrene, wish to make the following statement... Deposition of CLIFFORD H. BERNATH - Thursday, April 30, 1998, Washington, D.C. SECOND DECLARATION OF SHERYL L. HALL - Sworn Declaration By Former White House Computer Specialist, Sheryl L. Hall, as presented to Judge Royce Lamberth Deposition of HAROLD ICKES - Thursday, May 21, 1998, Washington, D.C. Filegate deposition - Deborah Gorham (June 3, 1999) PLAINTIFFS' MOTION TO COMPEL FURTHER TESTIMONY AND FURTHER PRODUCTION OF DOCUMENTS FROM HAROLD ICKES, FOR APPOINTMENT OF A SPECIAL MASTER, FOR CRIMINAL CONTEMPT AND PERJURY PROCEEDINGS, AND FOR SANCTIONS, INCLUDING ATTORNEYS FEES AND COSTS - Plaintiffs' counsel deposed Harold Ickes for less than six hours on May 21, 1998, wherein Ickes said he "does not remember" or "I don't recall" or similar statements of memory loss, approximately 84 times, an average of once every four minutes... Filegate deposition - Craig Livingstone AM (May 26, 1999) PLAINTIFFS' MOTION FOR LEAVE TO FILE SUPPLEMENT; SUPPLEMENT TO OPPOSITION TO MOTION OF LINDA R. TRIPP FOR A PROTECTIVE: ORDER AND OBJECTION TO SUBPOENA - (Intro) After initially having to ask the Court to order the U.S. Marshal's Office to serve D. Craig Livingstone with a summons and complaint, Plaintiffs have been attempting to obtain a full production of documents from Mr. Livingstone for more than seven months... Exhibits cited in Plaintiffs' supplemental memorandum concerning substitution and class certification - Library of exhibits used in the Filegate case. PLAINTIFFS’ MOTION FOR LEAVE TO SUPPLEMENT PENDING MOTION REGARDING DEPOSITION OF BETSY POND AND SUPPLEMENT THERETO - Plaintiffs’ motion and reply briefs set forth their concerns about the deposition testimony of Betsy Pond, and propose certain remedial measures designed to maximize the chances for candid, truthful, and relevant testimony from her. As the Court knows, Linda Tripp recently testified that it was Betsy Pond who told her that she was inputting data from FBI files onto a computer in the White House Counsel’s Office. Ms. Tripp also testified . . . EXHIBIT TO PLAINTIFFS' MOTION FOR LEAVE TO FILE SUPPLEMENT; SUPPLEMENT TO OPPOSITION TO MOTION OF LINDA R. TRIPP FOR A PROTECTIVE ORDER AND OBJECTION TO SUBPOENA - CERTIFICATE OF SERVICE List of deceased persons reportedly associated with the Clinton Administration - (left on Linda Tripp's chair by Monica Lewinsky, according to Tripp). To view this document, you must have the (FREE) Adobe Acrobat Reader. MEMORANDUM AND ORDER - This matter comes before the Court on Plaintiffs' Motion to Compel Re-Designation of Witness Concerning "WHODB" Under Fed. R. Civ. P. 30(b)(6) and for Attorneys' Fees and Costs FILEGATE: Declaration of Gary W. Aldrich - I, Gary W. Aldrich, wish to make the following statement... MOTION TO COMPEL DOCUMENTS AND FURTHER DEPOSITION TESTIMONY FROM LANNY J. DAVIS AND FOR SANCTIONS - On July 30, 1998, Plaintiffs deposed Mr. Lanny Davis, Esq., a figure central to the Filegate scandal and essential to Plaintiffs' discovery efforts. Mr. Davis testified during his deposition that he was hired by Clinton White House Counsel's office and worked closely with that office during his tenure as Special Counsel to the President... Filegate deposition - Kenneth Bacon (May 24, 1999) PLAINTIFFS' MOTION FOR LEAVE TO FILE SURREPLY; SURREPLY TO UNITED STATES' MOTION FOR LIMITED INTERVENTION AND TO STAY SUBPOENA ISSUED TO LINDA R. TRIPP - (Intro) Yesterday, September 2, 1998, Plaintiffs asked Mr. Zaccagnini to fax them a copy of any motion that he might file on behalf of Ms. Tripp concerning her upcoming, September 4, 1998 deposition. First, Mr. Zaccagnini agreed, but late yesterday evening imposed a condition that he would not fax Plaintiffs Ms. Tripp's motion unless Plaintiffs provided him with a copy of their opposition to the independent counsel staff's motion to intervene and for a stay of Ms. Tripp's deposition... NEW -- RealVideo Clips of William Kennedy deposition - Selected video excerpts of former White House staffer William Kennedy's deposition. Hillary Clinton goes under oath in Filegate with sworn declaration - See the actual declaration issued from the First Lady in the $90 Million Filegate Lawsuit (07/14/99) DECLARATION OF HOWARD SPARKS - Sworn statement from a current network specialist with the White House's Office of Administration regarding the storage and handling of e-mail within the Office of the Vice President Deposition of ELEANOR STACY PARKER - Wednesday, March 18, 1998, Washington, D.C. MOTION FOR EMERGENCY ORDER COMPELLING THE DEPOSITION OF GEORGE STEPHANOPOULOS - (Intro) Defendant Executive Office of the President's ("the White House"), and its allies', obvious threat to use the "Ellen Rometsch" strategy of blackmailing individuals by disseminating information from government files was first revealed in a February 8, 1998 nationally televised interview of George Stephanopoulos ("Stephanopoulos"), a former advisor of the White House... PLAINTIFFS' MOTION FOR LEAVE TO SUPPLEMENT MOTION TO DEPOSE DEFENDANT HILLARY RODHAM CLINTON - Although Plaintiffs have already provided substantial, compelling evidence demonstrating that Hillary Rodham Clinton was the mastermind of Filegate, new information revealed further supports this. PLAINTIFFS’ INITIAL LEGAL MEMORANDUM IN SUPPORT OF FINDINGS OF FACT - As filed in the U.S. District Court for the District of Columbia Depositions of LINDA TRIPP - December 14, 1998, January 6, 1999, January 13, 1999, January 22, 1999, Washington, D.C. MEMORANDUM AND ORDER - This matter comes before the court on Motion for Reconsideration filed by counsel for James Carville. Upon consideration of the submissions of the parties and the relevant law, the motion for reconsideration is DENIED. Filegate deposition - Betsy Pond (May 27, 1999) Deposition of PAUL E. BEGALA - Friday, March 15, 1998, Washington, D.C. Filegate deposition - Bernard Nussbaum (June 4, 1999) PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT HILLARY RODHAM CLINTON - Plaintiffs, Cara Leslie Alexander, David Lee Black, Marjorie A. Bridgman, and Joseph N. Cate, by counsel and pursuant to Rule 34 of the Federal Rules of Civil Procedure, hereby request that Defendant Hillary Rodham Clinton produce the originals of documents described below within thirty (30) days of service of this notice... RealVideo Clips of Linda Tripp depositions - Selected video excerpts of Linda Tripp's deposition. PLAINTIFFS' OPPOSITION TO EXECUTIVE OFFICE OF THE PRESIDENT'S MOTION FOR JUDGMENT ON THE PLEADINGS - (Intro) In a June 12, 1997 Memorandum Opinion, the Court denied a motion to dismiss filed by Defendant Executive Office of the President ("EOP") in which EOP claimed that the White House Office of Personnel Security ("OPS") and the White House Office of Records Management ("ORM") -- the two (2) entities which unlawfully obtained and maintained FBI background investigation files on over 900 former Reagan and Bush Administration appointees and employees... Filegate deposition - Clifford Bernath (June 10, 1999) RealVideo Clips of 02/20/99 George Stephanopoulos deposition - The walk-out series: selected video excerpts of Stephanopoulos walking out or attempting to walk-out during deposition (four instances in less than an hour and one-half. Declaration of Billy Ray Dale - I, Billy Ray Dale, wish to make the following statement... Court Orders E-Mail Search In Filegate Case - See The Court Order As Filed By Judge Royce C. Lamberth PLAINTIFFS’ PROPOSED FINDINGS OF FACT - As filed in the U.S. District Court for the District of Columbia MEMORANDUM AND ORDER - This matter comes before the Court on Plaintiffs’ Motion [363] to Compel Further Testimony and Further Production of Documents from Kenneth Bacon and for Sanctions. Upon consideration of plaintiffs’ motion, Bacon’s and the U.S. Department of Defense’s oppositions, and plaintiffs’ replies thereto, the court will GRANT IN PART AND DENY IN PART plaintiffs’ motion, as discussed and ordered below. Deposition of THOMAS D. JANENDA - Thursday, April 16, 1998, Washington, D.C. Filegate: Did they have your file? - The list of FBI files taken by the Clinton White House (as published by The Washington Times) MEMORANDUM AND ORDER - This matter comes before the Court on Plaintiffs’ Motion [362] to Compel Further Production of Documents from the U.S. Department of Defense and for Sanctions and Department of Defense’s Motion [N/D] to File Supplemental Declaration of Eleanor Hill Ex Parte and Under Seal. Upon consideration of these motions, oppositions, and replies thereto, and after an in camera review of all documents for which the Department of Defense claims a privilege, the court will GRANT IN PART AND DENY IN PART plaintiffs’ motion [362] to compel and GRANT Department of Defense’s Motion [N/D] to File Supplemental Declaration of Eleanor Hill Ex Parte and Under Seal, as discussed and ordered below. FILEGATE: Declaration of Sherry Rowlands - I, Sherry Rowlands, wish to make the following statement... Declaration of Christopher B. Emery - - I, Christopher B. Emery, wish to make the following statement... Attachment: Itemized List of Harold Ickes’ Claims of Memory Loss - from deposition; (questions are paraphrased) 84 Examples. Deposition of WILLIAM H. KENNEDY, III - - October 15th, 1998, Little Rock, Arkansas. PLAINTIFFS' MOTION FOR LEAVE TO FILE SURREPLY; SURREPLY TO UNITED STATES' MOTION FOR LIMITED INTERVENTION AND TO STAY SUBPOENA ISSUED TO LINDA R. TRIPP - Plaintiffs, by counsel, respectfully request leave to file this brief surreply to the Motion of the United States for Limited Intervention and to Stay Subpoena Issued to Linda R. Tripp... Deposition of LANNY J. DAVIS - July 30, 1998, Washington, D.C. Deposition of THOMAS F. McLARTY III - Wednesday, August 5, 1998, Washington, D.C. Filegate deposition - Craig Livingstone (August 18, 1999) Deposition of GEORGE STEPHANOPOULOS - Monday, March 9, 1998, Washington, D.C. Deposition of TERRY F. LENZNER - March 13, 1998, Washington, D.C. Deposition of KENNETH BACON - Friday, March 15, 1998, Washington, D.C. PLAINTIFFS' OPPOSITION TO UNITED STATES' MOTION FOR LIMITED INTERVENTION AND TO STAY SUBPOENA ISSUED TO LINDA R. TRIPP - (Intro) At its heart, the independent counsel staff's motion is flawed factually, legally and procedurally. For instance, in summarizing the factual underpinning of its request, the independent counsel staff incorrectly states " . . . plaintiffs' actions reveal that Ms. Tripp is not a central witness to their case." See Motion at 9. Nothing could be further from the truth, and for this reason alone the motion must fail... Deposition of JAMES CARVILLE - Monday, March 16, 1998, Washington, D.C. Filegate deposition - Craig Livingstone (June 8, 1999) JUDGE LAMBERTH'S ORDERS REGARDING E-MAIL MATTER - See The Actual Court Order Filegate deposition - Terry Good (June 1, 1999) MEMORANDUM AND ORDER - This matter came before the court for a status conference on December 19, 1997. Upon consideration of the submissions of the parties, oral arguments, and the relevant law, it is hereby ORDERED that the motions to strike plaintiffs' motions to compel submitted by defendants Anthony Marceca, Craig Livingstone, Hillary Rodham Clinton, the Executive Office of the President ("EOP"), and the Federal Bureau of Investigation ("FBI") are hereby GRANTED... PLAINTIFF'S MOTION FOR LEAVE TO SUPPLEMENT THE RECORD - As filed with Judge Royce Lamberth PLAINTIFFS' MOTION TO COMPEL FURTHER DEPOSITION TESTIMONY OF TERRY W. GOOD AND FOR SANCTIONS - On June 30, 1998 and July 2, 1998, Plaintiffs deposed Mr. Terry W. Good, Director of the Office of Records Management ("ORM") in the Clinton White House. At his deposition, Mr. Good provided important evidence that revealed a wholesale disregard for The Privacy Act by the Clinton White House... Filegate deposition - Craig Livingstone PM (May 26, 1999) Congressional Report on E-Mail Scandal – Generated by Judicial Watch - Where the report mentions the ‘Alexander Case’, the report is referring to Judicial Watch’s on-going Filegate lawsuit (click on the appropriate link within the page) PLAINTIFFS’ PROPOSED FINDINGS OF FACT - As filed in the U.S. District Court for the District of Columbia PLAINTIFFS’ INITIAL LEGAL MEMORANDUM IN SUPPORT OF FINDINGS OF FACT - As filed in the U.S. District Court for the District of Columbia PLAINTIFFS’ REQUEST FOR A STATUS CONFERENCE - Plaintiffs hereby respectfully request that a status conference be held in the above-captioned matter at the earliest practicable date. (requires Adobe Acrobat Reader) PLAINTIFFS’ RENEWED MOTION FOR LEAVE TO DEPOSE HILLARY RODHAM CLINTON - Motion filed by Judicial Watch (requires Adobe Acrobat Reader) Top of Page	Sign up to receive Tom Fitton's Weekly News Updates Email your friends about Judicial Watch Make a tax-deductible contribution Read more about Judicial Watch's current litigation Read our regular press releases