PLAINTIFF'S RENEWED REQUEST TO CONTINUE THE DEPOSITION

OF JOHN HUANG

Plaintiff, Judicial Watch, Inc., by counsel, hereby respectfully requests that this Court authorize Plaintiff to Continue the Deposition of John Huang. As grounds therefore, Plaintiff states as follows:

MEMORANDUM OF LAW

On October 29, 1996, Plaintiff took the deposition of John Huang. Plaintiff has since sought to continue the deposition of Mr. Huang, but through Orders dated October 30, 1996 and October 31, 1996 respectively, this Court suspended the deposition of Mr. Huang until further notice.

Plaintiff subsequently requested leave of the Court to resume the deposition of Mr. Huang, in light of its discovery that, among other things, Mr. Huang kept diaries which were discovered after his deposition. These desk diaries detail his activities at the Commerce Department, and once Mr. Huang is questioned about them, will likely lead to the discovery of relevant documents in this FOIA suit. To date, no action has been taken on Plaintiff's request. (See Transcript of Status Conference dated June 27, 1997, at 21-23 and Plaintiff's Summary and Supplemental Report Following Status Conference of June 27, 1997.)

Plaintiff recently became aware that Mr. Huang received limited immunity from Ken Starr in his investigation of Webster Hubbell and the "Whitewater" matter, and indeed has testified before a grand jury to this effect. (See Collective Exhibit 1 -- "Clinton Team Accepts Offer to Query Starr," Washington Post, Wednesday, November 18, 1998 and "Huang Got Immunity in Hubbell Probe," (AP) Wednesday, November 11, 1998.) In addition, while Mr. Huang may be called to testify before the House Judiciary Committee about possible "hush money" payments to Mr. Hubbell, there is no indication that the Committee intends to question Mr. Huang about his activities at the Clinton Commerce Department. Since Mr. Huang is now obviously available to testify, the time is ripe to bring him back for further questioning in the above-captioned matter. Accordingly, Plaintiff respectfully requests that it be allowed to continue the deposition of John Huang at the earliest practicable date.

Respectfully submitted,

________________________

Larry Klayman, Esq.

D.C. Bar No. 334581

JUDICIAL WATCH, INC.

501 School Street, SW

Suite 725

Washington, DC 20024

(202) 646-5172

Attorneys for Plaintiff

LOCAL RULE 108(m) CERTIFICATE OF COUNSEL

On November 18, 1998, I called Marina Braswell, Esq., counsel for Defendant United States Department of Commerce to determine Defendant's position on Plaintiff's Renewed Request to Continue the Deposition of John Huang. Ms. Braswell did not return Plaintiff's call. Since Defendant has opposed similar motions in the past, Plaintiff assumes that Defendant opposes this motion.

_____________________

Larry Klayman, Esq.

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

Civil Action No.

95-0133 (RCL) (D.D.C.)

__________________________________________

JUDICIAL WATCH, INC.,

Plaintiff,

v.

UNITED STATES DEPARTMENT OF

COMMERCE

Defendant.

__________________________________________

[PROPOSED] ORDER

Upon consideration of "Plaintiff's Renewed Request to Continue the Deposition of John Huang," any opposition thereto, and the entire record herein, it is hereby ORDERED that:

Plaintiff shall be allowed to take further deposition testimony from John Huang.

SO ORDERED: ___________________________

Hon. Royce C. Lamberth

United States District Judge for the Date: District of Columbia

Copies to:

Larry Klayman, Esq.

JUDICIAL WATCH, INC.

501 School Street, SW

Suite 725

Washington, DC 20024

Marina Braswell, Esq.

Assistant United States Attorney

Judiciary Center Building

555 Fourth St., NW

Room 10-832

Washington, DC 20001

CERTIFICATE OF SERVICE

I hereby certify that on November 18, 1998, a true copy of the foregoing, PLAINTIFF'S RENEWED REQUEST TO CONTINUE THE DEPOSITION OF JOHN HUANG and [Proposed] Order, was served by facsimile and first class mail, postage prepaid, on the following:

Marina Braswell, Esq.

Assistant United States Attorney

Judiciary Center Building

555 Fourth St., NW

Room 10-832

Washington, DC 20001

___________________

Jason Aldrich