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Judicial Watch • Motion to Reopen Huma Abedin 01363

Motion to Reopen Huma Abedin 01363

Motion to Reopen Huma Abedin 01363

Page 1: Motion to Reopen Huma Abedin 01363

Category:Clintons

Number of Pages:105

Date Created:March 12, 2015

Date Uploaded to the Library:March 12, 2015

Tags:Clinton Emails, Huma, Abedin, Hillary Clinton, State Department, EPA


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Case 1:13-cv-01363-EGS Document Filed 03/12/15 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
Plaintiff,
U.S. DEPARTMENT STATE,
Defendant.
Civil Action No. 13-cv-1363 (EGS)
JUDICIAL WATCH MOTION
FOR RELIEF AND REQUEST FOR HEARING
Plaintiff Judicial Watch, Inc. Judicial Watch counsel, respectfully moves pursuant Rule 60(b)(3) the Federal Rules Civil Procedure for relief from the March 14, 2014
stipulation dismissal and reopen this matter for further, appropriate proceedings. This motion timely because being filed within year the stipulation dismissal. Sack Central
Intelligence Agency, No. 12-cv-00244, 2014 U.S. Dist. LEXIS 93529, *58 (D.D.C. July 10,
2014). Undersigned counsel for Judicial Watch conferred with counsel for Defendant U.S.
Department State State Department Department who stated that the Department
does not oppose reopening the case this particular circumstance, but does oppose the specific
relief sought, and will filing response detailing its position. addition, pursuant LCvR
7(f), Judicial Watch requests oral hearing this motion. grounds therefor, Judicial Watch
states follows:
Case 1:13-cv-01363-EGS Document Filed 03/12/15 Page
MEMORANDUM LAW
Introduction. about March 2015, the New York Times reported that Hillary Clinton used
least one non- state.gov email account conduct official government business while serving
U.S. Secretary State. also was reported that Secretary Clinton stored these records
email server her home Chappaqua, New York, sometime 2014 unilaterally determined
which these emails were official government records, and only returned approximately 55,000
pages these records the State Department December 2014. Senior State Department
officials, including Secretary Clinton deputy chief staff, Huma Abedin, also reportedly used
non- state.gov email accounts conduct official government business. Such emails are
quintessential agency records subject the Freedom Information Act FOIA and the State
Department failure retain and records-manage these quintessential agency records directly
impacts the Department response FOIA requests.
Judicial Watch submits FOIA requests the State Department regularly, and the March 2015 report was the first time Judicial Watch learned that the Department responses
Judicial Watch requests may have been compromised. Because the FOIA request issue
this litigation included communications Secretary Clinton and Ms. Abedin, Judicial Watch
seeks reopen this litigation remedy the Department failure retain, records-manage, and
search for these records. The State Department should required search the 55,000 pages
emails returned Secretary Clinton, conduct additional, broader searches for responsive records
that may not have been captured earlier searches, and otherwise remedy any spoliation.
-2-
Case 1:13-cv-01363-EGS Document Filed 03/12/15 Page
II.
Factual and Procedural Background.
Ms. Huma Abedin served senior aide Secretary Clinton during her entire tenure
secretary. Ms. Abedin was Deputy Chief Staff for Operations the Immediate Office the
Secretary from January 22, 2009 June 2012. June 2012, Ms. Abedin became senior
advisor the same office. this position, Ms. Abedin was classified special government
employee, who was authorized represent individual clients and engage outside employment.
Ms. Abedin held this position until February 15, 2013, when then-Senator John Kerry became
Secretary State. May 21, 2013, Judicial Watch submitted FOIA request the State Department
seeking records about Ms. Abedin classification special government employee.
Specifically, Judicial Watch sought copies the following agency records:
Any and all SF-50 (Notification Personnel Action) forms
for Ms. Huma Abedin;
Any and all contracts (including, but not limited to,
personal service contracts) between the Department
State and Ms. Huma Abedin; and
Any and all records regarding, concerning, related the
authorization Ms. Huma Abedin represent individual
clients and/or otherwise engage outside employment
while employed and/or engaged contractual
arrangement with the Department State.
See Complaint, ECF Document No. (filed Sept. 10, 2013) Item the request clearly
implicated email communications not only Ms. Abedin, but also Secretary Clinton.
When the State Department failed provide final determination the request within
the statutory timeframe, Judicial Watch filed suit. See Joint Statement Regarding Briefing
Schedule, ECF Document No. (filed Dec. 27, 2013) The State Department answered,
-3-
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and, December 27, 2013, the parties filed joint meet and confer statement. Id. the joint
statement, the State Department represented that was processing Judicial Watch FOIA
request and that would complete its processing the request February 14, 2014. Id. letter dated February 12, 2014, the State Department represented Judicial Watch
that had completed processing the request. February 12, 2014 Letter from Sheryl Walter
Sean Dunagan.1 Specifically, the State Department represented that had completed searches the following records systems:
The Central Foreign Policy Records;
The Bureau Human Resources;
The Office the Executive Secretariat; and
The Office Legal Advisor.
Id. Approximately pages responsive records were produced. Id.
Based the State Department representation that had searched these record systems
and particular the Office the Executive Secretariat where records Secretary Clinton and
Ms. Abedin were most likely found Judicial Watch did not challenge the Department
final determination. Relying the State Department representations about its search, Judicial
Watch agreed stipulated dismissal March 14, 2014. See Stipulation Dismissal with
Prejudice, ECF Document No. (filed Mar. 14, 2014)
III.
Argument.
Pursuant Rule 60(b)(3), party may seek relief from judgment, order proceeding
for fraud (whether previously called intrinsic extrinsic), misrepresentation, misconduct opposing party. Fed. Civ. 60(b)(3). obtain relief, the moving party must establish
The letter attached Exhibit this motion.
-4-
Case 1:13-cv-01363-EGS Document Filed 03/12/15 Page
fraud, misrepresentation, misconduct clear and convincing evidence, well resulting
prejudice. Sack, 2014 U.S. Dist. LEXIS *59. noted above, the State Department represented that searched the Office the
Executive Secretariat response Judicial Watch May 21, 2013 request. The Office the
Executive Secretariat maintains centralized records the Secretary State and certain other
high-ranking Department officials. See Declaration Celeste Houser-Jackson, submitted
support the U.S. Department State Motion for Summary Judgment Anderson U.S.
Department State, Case No. 09-cv-00569 (D.D.C. Mar. 26, 2009) 12; see also Declaration John Hackett,3 submitted support the U.S. Department State Motion for Summary
Judgment Brien U.S. Department State, Case No. 14-cv-00119 (D.D.C. Jan. 30, 2014) (The Office the Executive Secretariat generally responsible for coordinating search
responses for the Office the Secretary State, the Office the Deputy Secretary State, the
Office the Under Secretary for Political Affairs, the Office Policy Planning, and the
Counselor the Department. addition, the Office the Executive Secretariat generally
conducts searches email accounts certain officials and employees the Immediate Office the Secretary. Id. 48. search the Office the Executive Secretariat, therefore,
includes search emails received sent officials employees the Immediate Office
the Secretary, which would include Secretary Clinton and Ms. Abedin. now clear that Secretary Clinton emails were not searched for records responsive
Judicial Watch FOIA request. Secretary Clinton used least one non- state.gov email
address conduct official State Department business. See Michael Schmidt, Hillary Clinton
The declaration attached Exhibit this motion.
The declaration attached Exhibit this motion.
-5-
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Used Personal Email Account State Dept., Possibly Breaking Rules, The New York Times
(Mar. 2015) (available http://www.nytimes.com/2015/03/03/us/politics/hillary-clintons-useof-private-email-at-state-department-raises-flags.html). While the State Department may now
have access many 55,000 pages Secretary Clinton emails, these emails were not
readily accessible for review the Department until least December 2014. Id. was only
two months ago that Mrs. Clinton advisors reviewed tens thousands pages her
personal emails and decided which ones turn over the State Department. also has been reported that other State Department officials employees, including
Ms. Abedin, may have used email addresses other than their assigned state.gov email
addresses conduct official State Department business. See e.g., Amy Chozick and Steve Eder,
Membership Clinton Email Domain Remembered Mark Status, The New York
Times (Mar. 2015) (available http://www.nytimes.com/2015/03/05/us/politics/
membership-in-clintons-email-domain-is-remembered-as-a-mark-of-status.html). the extent
that other officials employees the Immediate Office the Secretary, including Ms. Abedin,
used non- state.gov email addresses conduct official government business, those emails also
obviously would not have been searched response Judicial Watch request.
The State Department had obligation under the Federal Records Act properly
preserve, maintain, and make available for retrieval records its official functions.4 fact,
the obligation the head every federal agency so. See, e.g., American Friends Service
Committee Webster, 720 F.2d 29, (D.C. Cir. 1983). Each head agency develop program for records management, including provisions for cooperation with the Archivist,
Since 1995, this obligation has applied emails. See FAM 443.1(a) (Emails must
properly stored and preserved, available for retrieval and subject appropriate approved
disposition schedules.
-6-
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applying standards, procedures, and techniques. Id. (quoting U.S.C. 3102(2)). Secretary
Clinton plainly violated her own legal obligations. Doing was misconduct.
Moreover, the State Department cannot claim was unaware the Secretary failure
properly store and records-manage email. Not only should knowledge this failure imputed the State Department through Secretary Clinton, but any State Department employee who sent received email from Secretary Clinton which presumably would have included high
level officials must have known that they were communicating with the Secretary through
non- state.gov email address. incomprehensible that the State Department did not know,
when completed its search for records responsive Judicial Watch request February
2014, that records the Office the Executive Secretariat did not include emails Secretary
Clinton and other officials and employees the Department using non- state-gov email
addresses. the extent that Secretary Clinton used her non- state.gov email address
communicate with State Department employees who used state.gov email addresses,
consequence that these other, unknown employees emails may have been properly stored and
records-managed.5 These emails would not necessarily captured search the Office
the Executive Secretariat. The State Department would have conduct agency wide searches similar assertion was criticized recently FOIA litigation regarding the email
former Environmental Protection Agency Administrator Lisa Jackson: When [the requestor]
confronted Jackson with evidence that she did, least one occasion, use her personal email
account and Blackberry conduct government business without forwarding the message
her secondary EPA account Jackson responded that there was need because the
email included other [EPA] government accounts recipients, and thus would preserved. course, carving exceptions into standard practice slippery slope. Landmark Legal
Foundation Environmental Protection Agency, Case No. 12-1726, 2015 U.S. Dist. LEXIS
24620, **33-34 (D.D.C. Mar. 2015). This case more egregious than Landmark Legal
Foundation because Secretary Clinton exclusively used her non- state.gov account.
-7-
Case 1:13-cv-01363-EGS Document Filed 03/12/15 Page
respond properly any records request, which the Department did not here. Obviously,
such searches also would not capture email sent outside the Department.
Because Judicial Watch sought records concerning Ms. Abedin, senior aide the
Secretary, reasonable conclude that emails sent received Secretary Clinton exist that
may responsive Judicial Watch request. Moreover, more than reasonable conclude
that Ms. Abedin sent received emails related her change employment. The State
Department plainly did not conduct search for the requested records, using methods which can reasonably expected produce the information requested. Nation Magazine United
States Customs Service, F.3d 885, 890 (D.C. Cir. 1995). Despite knowing that the emails
Secretary Clinton, and likely the emails Ms. Abedin and other high level officials, were not
searched, the State Department represented Judicial Watch that the records the Executive
Secretariat had been searched. point did the State Department inform Judicial Watch that
the Secretary emails and the emails Ms. Abedin and other high level officials could not
searched. These were misrepresentations.
Judicial Watch relied upon the State Department misrepresentation that conducted
search the Office the Executive Secretariat. was lead believe that the State
Department search was proper. now knows was not. Had Judicial Watch known that the
State Department search excluded Secretary Clinton emails and the emails Ms. Abedin and
other high level officials, Judicial Watch would not have stipulated the dismissal this case that time.
-8-
Case 1:13-cv-01363-EGS Document Filed 03/12/15 Page
Judicial Watch has plainly been prejudiced. Obviously, proper search was not
conducted, and any spoliation responsive documents prejudicial.6 Landmark Legal
Foundation, 2015 U.S. Dist. LEXIS **18-20. Judicial Watch also prejudiced because,
this case not reopened, will required re-submit and (most likely) re-litigate the same
FOIA request force the State Department search for and produce records that should have
been searched for and produced previously. minimum, the State Department should
required search the 55,000 pages emails recently received from Secretary Clinton for
information responsive Judicial Watch FOIA request. The State Department should also
required conduct additional, broader searches beyond the Office the Executive Secretariat
and other previously searched record systems for responsive emails that may have been sent
received Secretary Clinton, Ms. Abedin, and other officials who did not use state.gov email
accounts and may not have been captured the previous searches. Finally, the State
Department should required undertake efforts remedy any spoliation, submit declarations
describing its further efforts locate and produce responsive records, and submit any other,
additional relief deemed appropriate.
IV.
Conclusion.
For the above reasons, Judicial Watch respectfully requests that the Court relieve Judicial
Watch from the March 14, 2014 stipulation dismissal and reopen this matter for further,
appropriate proceedings.
With regard any possible spoliation, time the essence. Secretary Clinton has
indicated that she has chosen not preserve all her emails sent received her through the
email address that she used exclusively conduct official State Department business. See Glenn
Thrush and Josh Gerstein, Hillary meets the press: Clinton said she had used personal email
account the State Department for convenience, Politico (Mar. 10, 2015) (available
http://www.politico.com/story/2015/03/hillary-clinton-address-email-controversy-115903.html).
-9-
Case 1:13-cv-01363-EGS Document Filed 03/12/15 Page
Dated: March 12, 2015
Respectfully submitted,
/s/ Michael Bekesha
Michael Bekesha (D.C. Bar No. 995749)
JUDICIAL WATCH, INC.
425 Third Street S.W., Suite 800
Washington, 20024
(202) 646-5172
Counsel for Plaintiff Judicial Watch, Inc.
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Case 1:13-cv-01363-EGS Document 14-2 Filed 02/06/15 Page
1:14-cv-00119-TSC
13-3
03/12/15
Case 1:13-cv-01363-EGS Document 14-2 Filed 02/06/15 Page
1:14-cv-00119-TSC
13-3
03/12/15
Case 1:13-cv-01363-EGS Document 14-2 Filed 02/06/15 Page
1:14-cv-00119-TSC
13-3
03/12/15
Case 1:13-cv-01363-EGS Document 14-2 Filed 02/06/15 Page
1:14-cv-00119-TSC
13-3
03/12/15