UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

IDENTIFIED IN DECLARATION OF SONYA STEWART

Plaintiff, Judicial Watch, Inc., by undersigned counsel, hereby respectfully moves this honorable Court for leave to depose certain individuals referred to in the attached Declaration of Sonya Stewart. The grounds for this motion are set forth below.

MEMORANDUM OF LAW

Plaintiff moves to depose or redepose the following individuals for the reasons set forth in the attached Declaration of Sonya Stewart. Exhibit 1.

1. Cheryl Mills

2. Melissa Moss

3. Johnnie Frazier

4. George Grafeld

5. Lyne-Marie Griffin

6. Jose Ceballos

7. Twanna Smith

8. Brenda Dolan

9. Bobbie Parsons

10. Barbara Fredericks

11. Judith Means

12. Sue Esserman

13. Frank DeGeorge

14. W. Scott Gould

15. Robert L. Mallett

16. William M. Daley

17. John Ost

18. Doris Matsui

19. Bruce Lindsey

As set forth in the Declaration of Sonya Stewart, formerly head of the Commerce Department FOIA operation, an obstruction of justice has been underway - as this Court implied in its orders of December 22, 1998 - to coverup the illegal sale of seats on Clinton-Gore Commerce Department trade missions, and related illegal matters. Ms. Stewart's declaration blows the lid off of this coverup, and affirmatively shows that the so-called second search of the Clinton-Gore Commerce Department to allegedly produce all relevant materials required in response to Judicial Watch's FOIA requests is a sham. Ms. Stewart's declaration also conclusively supports the prior testimony of Nolanda Hill, who implicated Hillary Clinton and other high White House and Democratic National Committee officials in the illegal scheme to sell seats on trade missions for political contributions.

Plaintiff respectfully requests leave to depose the individuals set forth in Ms. Stewart's declaration in furtherance of the Court's orders of December 22, 1998, which instructed Plaintiff to undertake discovery to not only identify unproduced documents, but to ascertain the facts behind the pattern of gross misconduct ruled upon by the Court, and, specifically, to determine what occurred and who was responsible.

Currently outstanding is a motion by the Clinton-Gore Commerce Department to stay discovery. See Defendant's Motions for Summary Judgment and to Terminate Discovery, filed on March 10, 2000, and Plaintiff's Opposition to Defendant's Motion to Terminate Discovery, filed on April 10, 2000. Plaintiff respectfully requests that the Court dispose of this motion at this time in order to allow full discovery to proceed.

Additionally, Ms. Stewart fears for her personal safety and livelihood as a result of coming forward to this Court. Accordingly, Plaintiff respectfully requests that the Court admonish the Department of Commerce and its employees and agents, including but not limited to the Clinton-Gore White House and the Administration as a whole, from any additional retaliation or intimidation of Ms. Stewart.

WHEREFORE, for all of the above reasons, Plaintiff respectfully requests that the Court dispose of Defendant's Motion to Terminate Discovery and order full discovery to proceed immediately, that Plaintiff be granted leave to depose the above-named individuals, and that the Clinton Administration cease and desist and refrain from threatening Ms. Stewart.

Respectfully submitted,

JUDICIAL WATCH, INC.

______________________________

Larry Klayman, Esq.

DC Bar No. 334581

______________________________

Paul J. Orfanedes, Esq.

DC Bar No. 4429716

501 School Street, S.W., Suite 725

Washington, D.C. 20024

202-646-5172

Attorneys for Plaintiff

On July 10, 2000, Plaintiff's counsel contacted Marina U. Braswell, Esq., counsel for Defendant United States Department of Commerce, by telephone, to inquire whether her client would consent to the relief requested herein. Ms. Braswell advised that she reserves taking a position until she has reviewed the motion and supporting declaration.

______________________________

Larry Klayman, Esq.

Upon consideration of Plaintiff's Motion For Leave to Depose Persons Identified in Declaration of Sonya Stewart, and the entire record herein, it is hereby

ORDERED:

1. Plaintiff's motion is hereby granted.

2 Defendant's Motion to Terminate Discovery is DENIED.

3. Plaintiff shall be allowed to proceed with discovery and to depose or redepose the individuals listed below:

1. Cheryl Mills

2. Melissa Moss

3. Johnnie Frazier

4. George Grafeld

5. Lyne-Marie Griffin

6. Jose Ceballos

7. Twanna Smith

8. Brenda Dolan

9. Bobbie Parsons

10. Barbara Fredericks

11. Judith Means

12. Sue Esserman

13. Frank DeGeorge

14. W. Scott Gould

15. Robert L. Mallett

16. William M. Daley

17. John Ost

18. Doris Matsui

19. Bruce Lindsey

SO ORDERED.

______________________________

The Honorable Royce C. Lamberth

United States District Judge

Copies to:

Larry Klayman, Esq.

Paul J. Orfanedes, Esq.

JUDICIAL WATCH, INC.

501 School Street, S.W., Suite 725

Washington, DC 20024

Marina U. Braswell, Esq.

Assistant United States Attorney

Judiciary Center Building

555 Fourth Street, N.W.

Room 4237

Washington, DC 20001

CERTIFICATE OF SERVICE

I hereby certify that on July 10, 2000, a true and correct copy of the foregoing Plaintiff's Motion For Leave to Take Limited E-Mail Discovery Concerning The White House was served via first class U.S. Mail, upon the following:

Marina U. Braswell, Esq.

Assistant United States Attorney

Judiciary Center Building

555 Fourth Street, N.W.

Room 4237

Washington, DC 20001

______________________________

Jason Aldrich