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Judicial Watch • Judicial Watch v. IRS 01559 (Sworn Declarations)

Judicial Watch v. IRS 01559 (Sworn Declarations)

Judicial Watch v. IRS 01559 (Sworn Declarations)

Page 1: Judicial Watch v. IRS 01559 (Sworn Declarations)

Category:IRS Scandal

Number of Pages:24

Date Created:August 11, 2014

Date Uploaded to the Library:August 11, 2014

Tags:01559, IRS


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  • demand_answers

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THE UNITED STATES DISTRICT COURT FOR THE 
DTSTRlCT COLUMBIA 

JUDICIAL WATCH, INC.,  
Plaintiff,  Case No. 1:13-cv-1559-EGS-JMF  
INTERNAL REVENUE SERVICE,  
Defendant.  

DECLARATIONS 
The Internal Revenue Service, pursuant the Court's July 10, 2014, Minute Order, 
submits the following declarations: 	Declaration Aaron Signor, Information Technology Specialist (Customer Support) within the User and Network Services branch the Information Technology business unit the Internal Revenue Service; 	Declaration John Minsek, Senior Investigative Analyst the Technology Support Center within the Electronic Crimes unit the Criminal Investigative Division the Internal Revenue Service; 	Declaration Stephen Manning, Deputy Chief Information Officer for Strategy Modernization. Manning's declaration was previously submitted True the Vote, Inc. Internal Revenue Service, Civil Action No. 13-734-RBW (D.D.C.); 	Timothy Camus, Deputy Inspector General for Investigations for the Treasury 
Inspector General for Tax Administration; and 	Declaration Thomas Kane, Deputy Associate Chief Counsel for Procedure and Administration within the Office Chief Counsel for the Internal Revenue Service. 
Dated: gust 11, 2014 	Respectfully submitted, 
Isl Klimas GEOFFREY KLIMAS 
Counsel for the Internal Revenue Service 
Trial Attorney, Tax Division 
U.S. Department Justice 
Post Office Box 227 
Washington, 20044 
GJK Telephone: (202) 307-6346 Fax: (202) 514-6866 
geoffrey .klimas@usdoj.gov COUNSEL 
United States RONALD 

JR. 
CERTIFICATE SERVICE certify that August 11, 2014, electronically filed the foregoing DECLARATIONS 
with the Clerk the Court using the CM/ECF system, which shall send notification that filing all parties registered receive such notice, including plaintiff's colUlSel. 

/s/ Klimas GEOFFREY KLIMAS THE UNITED STATES DISTRICT COURT FOR THE 
DISTRICT COLUMBIA 

JUDICIAL WATCH, INC., Plaintiff, Case No. 1:13-cv-01559-EGS INTERNAL REVENUE SERVICE, 
Defendant. 
DECLARATION AARON SIGNOR Aaron Signor, pursuant the provisions U.S.C.  1746, declare and say: Information Technology Specialist (Customer Support) within the User and Network Services branch the Information Technology ("IT") business unit the Internal Revenue Service and have been employed that unit its predecessor units for more than years. job duties include responding information technology service requests from IRS employees experiencing problems with information technology equipment. provide both remote and inperson service employees, including diagnosing problems identified employees and making all necessary efforts resolve the problems and/or return the employees full functionality through repairs replacement equipment. estimate that typically respond between and services requests per day. The statements this declaration are made the best recollection. June 13, 2011, was assigned assist with service request reported the internal IRS service desk which indicated that the laptop computer assigned Lois Lerner was not operating properly. 
After contacting and speaking with assistant Ms. Lerner's office, reported the location Ms. Lerner's computer her office, and observed that the Lois Lerner's assigned laptop computer had video displayed either the external monitor built-in laptop screen. addition, found that the laptop would not boot even after multiple attempts, which indicated that time there was more serious problem with the computer that would require further troubleshooting. 
Given that this was the case, removed the computer from her office and took the on-site office for further diagnostic tests. the on-site office, examined the computer for signs physical damage and not recall seeing any. Next, attempted run diagnostic tool the BIOS the computer determine whether the subject hard drive was working. Ordinarily, this test would show progress percentage which would reach 100% completion and then the test would report that passed. 
Although made multiple attempts run the test, each time the test would freeze and fail complete. The failure this test confirmed that the hard drive was not working properly. 
Subsequently, made several attempts recover data from the subject hard drive using software tool called Guardian Edge. First. placed the Guardian Edge Access disc the laptop computer and attached the computer external hard drive that intended use copy data from the computer. The Access disc can 

used boot disc bypass computer's normal boot process and run reduced version Windows. Despite multiple attempts, was unable recover data from the computer using the Access CD. 
Next, attempted use the Guardian Edge Recovery de-crypt the data the subject hard drive. with the Access CD, placed the Recovery the laptop computer and booted the laptop using this CD. However, despite multiple attempts, this effort also failed before the decryption process reached 25% completion. 

10. 
Finally, removed the subject hard drive from the laptop computer and connected another known functioning laptop computer using external USB hard drive enclosure. Once was connected, attempted access the hard drive through the second computer's Windows file system. However, the drive letters for the subject hard drive would not appear disk management the second computer. This further indicated that the hard drive was not working. that point, had exhausted the diagnostic and data recovery tools that are available me. 

11. 
Following the above attempts, June 13, 2011 ordered new hard drive replace the subject drive Ms. Lerner's computer hard drive. June 14, 2011, installed new hard drive into Ms. Lerner's computer, and began the process installing software that new hard drive that the computer could returned Ms. Lerner operable condition. 

12. 
After determined that the subject hard drive was not working and that was unable recover data from it, labelled the subject hard drive and placed into file cabinet the on-site office. practice and the practice colleagues work group label non-working hard drives with the name the employee that the 
non-working hard drive had been assigned to. Usually, that labelling would accomplished either taping post-it note the hard drive writing directly onto 
the hard drive itself. 
13. Several weeks later, received communication from manager above 
me, Lillie Wilburn, who informed that another technician who had more experience 
with data recovery would touch with concerning the subject hard drive. had 
phone conversation with that technician, and that conversation told the technician 
the steps had taken attempt recover data from the subject hard drive. the best recollection, subsequently received pre-labeled box with foam padding for the 
hard drive. placed the subject hard drive the box, and placed the box the mail. 
After placed the hard drive the mail, had further involvement with 
any attempts recover data from the subject hard drive. declare under penalty perjury that the foregoing true and correct. 
Executed this 8/ti day August, 2014. 

Information Technology Specialist (Customer Support) 
Washington Deskside Group User Network Services Information Technology 
Internal Revenue Service Washington, THE UNITED STATES DISTRICT COURT FOR THE 
DISTRICT COLUMBIA 

JUDICIAL WATCH, INC.,  
Plaintiff,  Case No. 1:13-cv-01559-EGS  
INTERNAL REVENUE SERVICE,  
Defendant.  

DECLARATION JOHN MINSEK John Minsek, pursuant the provisions U.S.C.  1746, declare and 
say: Senior Investigative Analyst the Technology Support Center 
(TSC) within the Electronic Crimes unit the Criminal Investigation Division (CID) 
the Internal Revenue Service (IRS) and have been employed that role for more than years. have approximately years continuous experience working the 
field digital forensics and data recovery. July 2011, the request employees within the Modernization and 
Information Technology Services (MITS) unit the IRS, agreed attempt recover data from hard disk drive that had ceased operating properly and had been removed from the laptop assigned Lois Lerner (the subject hard drive). July 22, 2011, received the subject hard drive and connected the 
Ace Laboratories PC3000 UDMA (Ultra Direct Memory Access) diagnostic system, 

commonly known the "PC3000", using standard cable connections and proprietary hardware. the PC3000, none the requisite status registers where illuminated which indicated that the subject drive was not preparing itself accept commands and there were critical problems with the subject hard drive that could either mechanical electronic (or both) nature. After the unsuccessful attempt reading data using the PC3000, July 
22, 2011, retrieved hard drive (donor drive #1} from the CID TSC drive library that 
was the same make, model, controller version, country origin and contained the same firmware version the subject hard drive. July 22, 2011, removed the Printed Circuit Board Assembly (PCBA) 
from the subject hard drive and replaced with the PCBA from donor drive #1, but was unsuccessful using the PC3000 attempting get the subject drive come into state readiness accept commands, prerequisite allow read data from the subject drive. July 22, 2011, opened the subject hard drive the Class 100 
Laminar Flow Workstation and noticed well-defined concentric scoring around the 
center the top platter. Next, July 22, 2011, removed the Head Stack Assembly (HSA) from 
the subject device and replaced with the HSA from donor drive #1, and re-attached the original subject PCBA. This was unsuccessful getting the subject drive come into state readiness accept commands. prerequisite allow read the data the subject drive. 
10. Next, July 22, 2011, installed the PCBA from donor drive the subject drive while the HSA from donor drive was installed, but was again unsuccessful getting the subject drive come into state readiness accept commands, prerequisite allow read the data the subject drive. 
11. July 22, 2011, notified employees MITS unsuccessful efforts 
and requested they provide with another hard drive the same make, model, country origin, date code, and contained the same firmware the subject hard drive (donor drive #2). 
12. received donor drive from MITS August 2011, and repeated the 
steps described paragraphs 8-10 above using the PCBA and HSA from donor drive with the subject drive and was similarly unsuccessful causing the subject drive load the internal firmware subsystem, ready accept commands. 
13. Also August 2011, attempted use the Deepspar Disk lmager 
(DDI) perform "hot swap" procedure with donor #2. This method was employed attempt artificially cause the subject drive function state readiness which would have allowed read and make image backup the data that resided the subject hard disk drive platters. 
14. The "hot swap" method has the capability loading device's internal 
firmware subsystem from donor platters into PCBA Random Access Memory (volatile memory) and permitting the motor spin-down subsequently allow for swap the mechanical drive component containing the platters, all while maintaining power the PCBA. Specifically, the subject PCBA was used with donor drive platters and configure



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