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Judicial Watch • JW v DOJ Datto docs HRC emails transcript 02369

JW v DOJ Datto docs HRC emails transcript 02369

JW v DOJ Datto docs HRC emails transcript 02369

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THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH
vs.
U.S. DEPARTMENT JUSTICE
Defendant.
Plaintiff,
Docket No. 16-2369 RDM
Washington, D.C.
January 24, 2017
2:30 p.m.
TRANSCRIPT STATUS CONFERENCE
BEFORE THE HONORABLE SENIOR JUDGE RANDOLPH MOSS
UNITED STATES DISTRICT JUDGE
APPEARANCES:
For the Plaintiff:
Michael Bekesha, Esquire
JUDICIAL WATCH
426 Third Street, Suite 800
Washington, 20024
For the Defendant:
Cesar Lopez-Morales, Esquire
U.S. DEPARTMENT JUSTICE
Federal Program Branch Massachusetts Avenue,
Washington, 20530
Court Reporter:
Cathryn Jones, RPR
Official Court Reporter
Room 6521, U.S. District Court
333 Constitution Avenue, N.W.
Washington, D.C. 20001
Proceedings recorded machine shorthand, transcript
produced computer-aided transcription.
THE DEPUTY CLERK:
Civil Action 16-2369, Judicial
Watch versus the U.S. Department Justice.
please approach the podium and identify yourself for the
record.
MR. BEKESHA:
Counsel,
Good afternoon, your Honor.
Michael
Bekesha behalf Judicial Watch.
counsel table Tom Fenton, president Judicial Watch.
THE COURT:
Along with
Good afternoon, Mr. Bekesha.
MR. LOPEZ-MORALES:
Good afternoon, your Honor,
name Cesar Lopez-Morales behalf defendant, U.S.
Department Justice.
Marcy Berman also the U.S. Department Justice and
Christian Ellis the FBI.
THE COURT:
And with counsels table
Thank you. start with you.
from your prospective.
MR. BEKESHA: Mr. Bekesha, why dont
And just let know where things stand
Sure. you know the Judicial
Watch submitted FOIA request October. it.
retrieved, found Datto device which our understanding was one the devices that the FBI collected during its
investigation Secretary Clintons email usage.
second part the request for records related that
collection and related that device. had two parts
One was asking for all records that were discovered,
The answer has been filed. response from the
agency yet about there are any responsive records. say formal official response.
yesterday briefly about where the process is.
though probably make more sense for the governments
attorney explain what their position and then have
come back and talk about it.
THE COURT:
Okay.
Let
Counsel spoke looks
That sounds good.
Mr. Lopez-Morales.
MR. LOPEZ-MORALES: your Honor, opposing
counsel mentioned there are two parts the request that
was submitted Judicial Watch October.
position somewhat similar with respect each part even
though the source the location where the responsive
records are different with respect each part.
And our
With respect the first part, informed
opposing counsel yesterday that any responsive records
this part the request located the materials that
were transferred the Department State for processing
for FOIA purposes, and being governed the production
schedule agreed your case youre familiar Leopold
versus Department Justice.
are being processed pursuant your October 2016 order,
which Docket 26.
And that, those materials that any responsive records that first part the request are part those materials the Department
State has been processing them.
filed status report the beginning January, you may well aware the Leopold case forming the status that
production.
The Department Justice
And part those, part that production
there have been some records that could have been retrieved
from the Datto device which what plaintiff interested
in. dont have any numbers what has been released
already and what remaining, but what know that
anything that was recovered, retrieved from the Datto device the materials that were transferred the State
Department.
THE COURT:
Remind Leopold the State
Department then posting the materials that its releasing
response Leopolds request the Internet somehow
generally accessible?
MR. LOPEZ-MORALES:
Yes, your Honor, they are
being released the public the electronic FOIA library,
and not just Mr. Leopolds request but also the
hundreds requests that the State Department handling.
And thats how Judicial Watch would have access the
responsive records well.
THE COURT:
Okay.
Does that cover everything then one, everything well, you may not know this, but maybe
you do. requested number one?
Does the Leopold request encompass everything that
MR. LOPEZ-MORALES: not sure, your Honor.
But
what know that anything that would responsive the materials the State Department.
whether its responsive the Leopold request will
processed accordance with the processing schedule.
THE COURT:
Okay.
And regardless
Anything that responsive
question number one that not subject FOIA exemption
will posted the State Department public library,
electronic library?
MR. LOPEZ-MORALES:
THE COURT:
MR. LOPEZ-MORALES:
Exactly, yes, your Honor.
Request number two?
Request number two opposing
counsel very familiar heavily discussed and litigated
this issue before Judge Chutkan another lawsuit that was
filed Judicial Watch against the Department Justice.
That case number 16-2046.
told Judge Chutkan and Judge Chutkan agreed with us.
approved our processing schedule 500 pages per month
the Clinton investigative files.
And discussed then
She
What should emphasize about the second part
the request that any, the extent that there are any
responsive records that part the request which relates the FBIs efforts retrieving recovering
discovering the information the Datto device that
the FBIs possession, and that the FBIs investigative
file. the Clinton investigative file.
Chutkan that case Judicial Watch was requesting 302
forms.
communications between officials the FBI, between the FBI
and the White House, cetera.
The FBI has received hundreds requests for records
And informed Judge
They were also requesting correspondence and what said long before plaintiff filed
lawsuit and even before they filed this request the FBI had
already stated its commitment handle the requests that
was receiving and release all nonexempt portions the
Clinton investigative file.
several months.
2016.
order and our policy of, for complex FOIA requests.
continue process 500 pages month the Clinton
investigative file.
case. has been doing for
The last release was Friday, January 6th,
And the FBI will continue pursuant Judge Chutkans will
And thats what litigated that
And also forgot mention that the FBI has
received least nine requests for the whole Clinton
investigative file, and they were received long before
plaintiff had filed this request.
policy for complex requests and the first in, first out
policy have been processing the requests accordingly and accordance with our
the FBI has released all nonexempt portions that file goes that process.
THE COURT:
Are those also being processed some
publicly available
MR. LOPEZ-MORALES:
THE COURT:
MR. BEKESHA:
Yes, your Honor, yes.
Thank you.
Mr. Bekesha.
Thank you, your Honor.
Ill briefly
talk about the second part the request first.
first would disagree with the characterization that was
You know,
litigated before Judge Chutkan this idea 500 pages
month being produced.
had positions.
There was discussion. filed status report. each
There was status conference about it.
Judge Chutkan that time has agreed along
with the production schedule that the State Department,
that the Department Justice proposed, but wasnt
litigated.
reevaluate her decision that time depending how the
production goes. think Judge Chutkan its fair say may
What counsel also didnt say
THE COURT:
Before you move off that, are you
asking that anything different?
that Judge Chutkan and she changes the schedule there
that would affect
MR. BEKESHA:
here, your Honor. just leave asking for something different the Clinton investigative file
little over 10,000 pages.
pages month the Justice Department, the government has
said would between and months for all the material produced. records.
unlike the case that had front Judge Chutkan
where asked for types documents, Form 302s and
communications which may different, may difficult
separate out from the full 10,000 pages.
What weve asked for 500
What weve asked for very limited set
Records only about the Datto device.
And this instance all the material, the 10,000
pages are already posted, are already online not online
but electronic database. our proposal this case for the government first
part two search the word Datto the 10,000 pages, see
how many potentially responsive pages there are and then
can meet and confer and discuss production schedule. can key word searched. Datto only appears ten pages makes sense
for the agency review and produce those ten pages instead requiring wait months have entire
investigative file that then need through and
figure out where those ten instances are 10,000 plus
pages, those ten pages could withheld full and then not the 10,000 but parts the 10,000 pages, then
wouldnt even know where Datto appeared those records.
THE COURT:
What the relevance the Datto
device?
How that distinct from everything else?
MR. BEKESHA: when the FBI was conducting its
investigation they gathered several laptops, several
Blackberries from Secretary Clinton.
other devices from third parties, other former government
officials.
devices that they collected from company that had
contract with Secretary Clinton for, back information.
They also collected
These are, the Datto device one the
And were looking for the second part
records about what the FBI did with respect this specific
device.
file.
their database and lets see how many hits there are. were not talking about the entire investigative just want the government type Datto into
THE COURT:
Are you content live with that
the scope the search?
MR. BEKESHA:
Yes, your Honor. think its
fair interpretation, reasonable interpretation our
request without searching the word Datto would
difficult figure out whats responsive and whats not
quite honestly. relatively easy solution.
that counsel yesterday hoping that maybe they could have
conducted the search and provided with number. think that would fair. would suggested and proposed mean shows 10,000 pages then there
may problem.
But shows only ten times there
could easy solution this case.
THE COURT:
MR. BEKESHA:
Okay.
With respect the first part,
still dont know and asked this counsel yesterday,
where the materials from the Datto device exists the
materials transferred the FBI, sorry the State
Department.
State Department.
understanding that the State Department processing the believe the FBI transferred six disks the
And right now the Leopold case its
first disk.
And the question is, all the material from
the Datto device one the six disks?
out throughout the disks?
than just emails.
message, I-messages.
the Leopold case has only been emails, you know, want ensure all records are being looked and produced not
just emails the Leopold case. makes sense for the State Department continue
processing the case response Leopold well
another Judicial Watch case really depends where the
materials exists the materials transferred the State
Department. spread
Also our request asked for more asked for Blackberry messages, text
And date the material posted
You know, whether not
One last point note the State Department
theyre reviewing the materials transferred from the FBI may
determine some those records are not State Department
records. this case sued the Justice Department and not the
State Department.
records that may get lost because sued one agency and
they want another agency respond us.
And how that going dealt with because
And there seems potential for
THE COURT: does seem the Court unlikely
that just given the number lawsuits that have been
brought that some records are going get lost this
process because presumedly the State Department has requests
for everything.
Department has requests for everything covered your
requests.
Department does review that concludes its some the
records are, records third party agencies which case
assume they would handle that the way they that
they would then presumedly send that out the third party
agencies get the position the third party agency.
And understand from counsel the State
Its true that may turn out when the State
MR. BEKESHA:
Right.
The defendant this case
is, the agency the Justice Department.
plays out, wait months long its going
take process the six disks, and then what happens the
State Department transfers that material back the Justice
Department then review the records and see theyre
Justice Department records?
And how that mean just figuring out the
logistics that theres nothing place now ensure
that
THE COURT:
MR. BEKESHA: what are you proposing?
Well, think the first thing are
all the materials that were recovered from the Datto device one place.
disk. would helpful know are they one
Are they one database the FBI?
THE COURT:
You told that request one goes beyond
the Datto device; that right not?
MR. BEKESHA:
No, its everything, everything
the Datto device, that was found the Datto device.
that may included the material transferred from the
FBI the State Department.
Does the FBI have the Datto device materials all one
file?
where these records exists before can even try agree what makes sense and what fair production schedule may
be.
And
But all one disk? mean how is, think need know more about
THE COURT:
Let hear again from
Mr. Lopez-Morales.
MR. LOPEZ-MORALES:
Well, your Honor, first
all, did look where the sixth disks some the
potential responsive records would located. once again today Judicial Watch has taken the position
that took last week before Judge Chutkan and was
The problem
rejected.
litigation approach.
multitracking processing ***queues well first in,
first out policy.
which why Judge Chutkan rejected that approach, and just
because obviously Judicial Watch has right file
lawsuit with respect its FOIA requests, but has
wait its turn line.
And its this death thousand cuts piecemeal
The agency and FOIA guarantees
That what the agency has been doing
And we, the Department State with respect
the materials that were transferred there and the FBI with
respect the Clinton investigative file both agencies have
received hundreds requests for the same records.
just because Judicial Watch has the inclination the
resources file lawsuit does not merit preferential
treatment over all the other requestors.
And
There process place accordance with
your order the Leopold case.
Department State first identify which records are not
responsive the Leopold request.
you said anything that would processed third party
agency; and third, release Mr. Leopold the
public the Department State has been doing, anything
that responsive.
doing that not only with respect Mr. Leopolds request,
but anything that nonexempt that located the provides for the
Second, transfer
And the Department State has been
materials. what found would have either provide this
information the Court and opposing counsel, our
position still that Judicial Watch has wait line.
Judicial Watch did not request expedition the FOIA case,
and they have not identified any reasons why their requests
should prioritized over the hundreds other requestors.
With that being said, have identified that
the materials transferred the Department State
anything that was retrieved from the Datto device would disk one, which what your order the Leopold case
provided which currently being processed.
that the Department State will done the next couple months processing that disk and then they will proceed
disk four and five.
device, the Datto materials are disk one and disk five.
And think
And the information from the Datto Judicial Watch going get anything thats
not exempted that are Datto materials.
correct something for the record.
not limited emails.
emails and other records that were retrieved from the
server.
request, your Honor, which why Judge Chutkan approved the
FBIs proposed 500 page per month schedule.
And just want
The Leopold request
The Leopold request clearly asks for
And the same applies the second part the could run search the word Datto, but that
creates incentive which precisely what Judicial Watch
has been doing this instance filing another lawsuit
for records the Clinton investigative file.
continue allow Judicial Watch to,
process these requests and favor and reallocate resources
that are being used right now the agency process the
whole Clinton investigative file would have pull out
specific records requested Judicial Watch the recent
FOIA request, pull those records out, process them and pull will
them back the file.
And the extent, for example, with the second
part the request they are asking for records the FBIs
efforts retrieving the Datto material. the 302s forms the correspondence that were the
subject the requests the case before Judge Chutkan. then would have this messy situation which would
have different processing schedule.
out specific records.
create this distinction that opposing counsel mentioning types documents versus type content. would easier pull out specific types categories documents like the 302 forms and instead looking
throughout the entire file for references Datto.
That could well would have pull
And does not really make sense anything,
And Datto search along doesnt really mean that
were going get all the potential responsive records
that request. thats our position, your Honor.
THE COURT: you have any sense the quantity records subject the request number two that relate
the Datto device?
MR. LOPEZ-MORALES:
So, your Honor, did look, ran search and found documents throughout the
file and subfiles including the top secret file. documents that have the word Datto that could
under inclusive, over inclusive. have
Its unclear that these
records are the extent that theyre 302 forms, the
extent that theyre correspondence any other sorts
document.
THE COURT:
The plaintiffs indicated that they
would happy live search just for the word Datto, dont think would under inclusive.
MR. LOPEZ-MORALES:
Right. theyre happy
with that wouldnt under inclusive over inclusive
because they would stipulate the adequacy the search that instance.
just incentivize further lawsuits.
documents now.
would just very chaotic and inefficient process while
the agencies try figure out way allocate resources
effectively and handle this very equitable manner for
everyone.
Our concern, your Honor, that would
And could could then and on.
And that
THE COURT:
And dont adopt some process
expedite search for the Datto device how long would take
for the FBI respond Judicial Watchs request number
two?
MR. LOPEZ-MORALES: dont have that information,
your Honor, but you give minute can confer with
client.
THE COURT:
[Brief pause.]
Yes.
MR. LOPEZ-MORALES:
Thank you, your Honor.
the, think opposing counsel mentioned this.
would take months the pace 500 pages per
month for the entire Clinton investigative file.
plaintiff could look for the word Datto these documents
including the ones that have already been released the
public.
documents Leopold.
The process
And
And they could the FBI releases the
THE COURT:
Does Judicial Watch have one more
additional requests pending that are broader and more
encompassing? interferes with the process for someone able
serve broad request.
that wed like get sooner, lets another request
were going ask you get search for that.
weeks later they decide theres some subset want lets
What responding your comment that
And say well, theres some parts
And two another request now.
search for that way that just interferes with the
orderly production records.
Were going ask you question fact that what Judicial
Watch doing here?
the FBI and this just subset where theyre seeking
sort expedite some subset the documents?
Have they served broader request
MR. LOPEZ-MORALES:
Your Honor, dont have the
information that theyve searched broad request.
What
they have filed several small requests for substantive
documents despite the broad requests filed other groups individuals before Judicial Watch had filed request.
THE COURT:
Does Judicial Watch have other
requests that are pending right now that youre working on?
MR. LOPEZ-MORALES:
THE COURT: youd give one second.
Judicial Watch may more easily able answer that question.
MR. BEKESHA: dont know, your Honor. mean standing here today and this isnt were not here
trying harass the agency.
request, found out couldnt, werent going get
those records for months and now were filing more
target request.
the timing these requests, sent request for the 302s
and the communications after Director Comey announced during
Were not filing larger
That just didnt happen. you look
his testimony the, believe was House committee
that was going make all the 302s available
Congress.
because sounded though the FBI was processing the 302s
for release Congress, were going piggyback
the work they were already doing.
And sent request for 302s after that found out October weve come understand
theres this Datto device, were interested that sent request.
This isnt, this the second time that
counsel the past two weeks has talked about why,
suggesting reasons why Judicial Watch suing and other
requestors arent.
information.
trying abuse the system all.
Were just trying get the
Were not, this isnt, you know, were not
THE COURT:
The reason posed the question which
was not actually try get back question.
going asks there are other requests that the FBI
currently processing for Judicial Watch. more pressing and the concern about queue jumping.
And that there are third parties out there who are going
get their records less quickly result this someone the FBI has stop and its not matter someone the FBI just saying let push the button and well
generate this documents and hand them you.
What was
And you think this
Presumably someone has first layer review
for FOIA exemptions.
would need through and redact those.
then theres second level review.
talking about here something that would involve not
hour half hours work, but something that would
involve even though its documents, many hours work
for somebody which does create equity issue about whether
other peoples request get pushed back. there are 302s assuming there assume assume what were question really was Judicial Watch
position the FBI working another Judicial Watch
request this point say were happy put that request hold while you this one?
MR. BEKESHA: could be, but the FBI hasnt
identified any other Judicial Watch requests that would
interfering with them processing
THE COURT:
You would know more than they would
right now whether there are other Judicial Watch.
the lawyers handling this case may not handling the other
cases, you would know better than they would whether
there are other pending cases directed the FBI
Judicial Watch.
MR. BEKESHA: mean dont that off the top head. have several attorneys that handle different cases.
THE COURT:
Watch right here.
Youve got the president Judicial
MR. BEKESHA:
currently. do. just dont have list dont have list our current litigation.
THE COURT:
Let ask you the question then,
there are other requests would Judicial Watch prefer say
fine, you can put this hold while the FBI looks for
these?
MR. BEKESHA:
Potentially, your Honor, would would want the opportunity take look our requests
before made judgment, deciding, depending what our
other requests are thats pending with the FBI, where they
are any litigation process. may not make sense. theyre towards the end
Were here, finally heard that was
documents.
information.
information when first spoke your Honor.
mention it.
specifically the search had run that was willing
share this information.
Now counsel wasnt willing give out that asked yesterday about it. had the didnt came back up, wasnt until you asked
Its documents. understand that there may several layers
review and there may few documents thats required,
but dont know.
Some may two sentences long.
THE COURT: dont know what the documents are.
Thats the problem though because
for someone know someone going have drop doing
what theyre doing behalf some other FOIA requestor
and spend time going and figuring that out.
sort what urgent need more pressing need you have say lets get them all the room here together and
would have robust discussion Mr. Leopold and some
the other FOIA requestors were all the room here said
okay, lets decide who goes first.
The question assume probably would come away from that
with decision where just lets come order.
Because
assume the other FOIA requestors are going say
dont want have wait extra time get mine while
Judicial Watch jumps ahead the queue.
reason, some particular reason why its important here this case, some way that can done way
that doesnt unfairly penalize other FOIA requestors.
MR. BEKESHA: need some other
But this penalizing FOIA request send narrow request.
would have preferred send broad request for all
records.
THE COURT:
MR. BEKESHA:
What the agency wants they not sure thats true.
But thats how they are processing
it.
documents because they want all them instead the
narrow.
They want wait months for them review
THE COURT:
Put yourself the position because
know Judicial Watch this position.
position now where youve got other cases out there where
you have broader requests. this Court are going get other FOIA requestors who are
going coming and saying put aside Judicial Watchs
request because theirs broader than mine.
narrower, more targeted one, mine first and then turn
back Judicial Watchs.
know there could such series those things that your
broader request may get delayed substantially, because its
not just going one, but series people coming and
saying Ive got narrower one first.
MR. BEKESHA:
Put yourself
And then and the other judges
Mine
And fact did that you
But thats why they have the track,
the different tracks for complex and simple requests.
broad request are clearly complex because theyre lot more
records.
search which they have done.
documents.
are.
much time look, gather.
pages.
relatively short period time probably afternoon.
Here its simple request.
Its run key word
Theyve identified dont know how many pages those documents
Somebody can look them.
That wouldnt take that could total
And those pages could reviewed
THE COURT:
MR. BEKESHA:
thats not true. not sure thats true.
But the agency hasnt shown that
They havent shown
THE COURT: that the way works? that
they need and you file request and come here
and press that they then need and figure out how
much time its going take for them respond and
whats there, you know, out queue order then come
back and say well, actually this how many hours would
take because would take them lot hours
that.
MR. BEKESHA:
Well, think theres some
obligation their behalf process the requests
timely and efficient manner.
this case.
that are very complicated because its entire
investigative file.
records about one small issue, one discrete issues,
documents.
Theyre just not doing that
Theyre processing the entire file, 10,000 pages
All were asking for here for
Thats all were talking about, documents.
And what their response you have wait two
year and oh, Judicial Watch can search the records for the
key word themselves.
THE COURT:
Two things, one that not
sure theyre saying you need wait two years because its
produced the rolling basis.
your last document two years from now. probably suspect already available.
surprised its already available because theyve been
And may that you get
Your first document wouldnt
producing documents already.
MR. BEKESHA: minimum they should required identify that such records have been produced.
know
THE COURT: dont the library not searchable that
exist?
MR. BEKESHA:
Its not OCR, guess you
could scroll every page and read every page and look for
Datto.
Its not OCR-ed.
Its not electronically
searchable.
the FOIA requestor conduct their own FOIA search.
agency doesnt want it, Judicial Watch you ahead
and conduct your own searches.
and then can discuss couple years after were
done processing the whole file.
supposed work. mean theyre almost putting the obligation
The
Tell you find anything
This isnt how FOIA appreciate the fact that they have lot
FOIA requests for the Hillary Clinton investigative file,
but they havent identified that anybody else asking
specifically for the records are.
the whole file here.
documents reviewed and produced timely fashion.
Now can argue what timely fashion is, but think
would comfortable with three month period.
agency three months start processing the records, and
Were not asking for
Were just asking for these
Have the
they hit some snags because the records are more complicated
and need layers review can come back and can
talk about that.
But shouldnt have wait until the end the
entire production for the agency identify the pages.
Let know those pages and then talk about there are
any withholdings sorry, records.
withholdings the records brief the issue.
were talking
THE COURT: there are mean Judicial Watch prepared sort
live this your other cases then too other FOIA
requestors come that you dont have problem with the
Court putting aside the agency putting aside your
requests while they more narrower ones?
MR. BEKESHA: not sure the department has
identified stated specifically that they would have
stop producing other work.
THE COURT:
They would have slow down.
Theres
only many hours the day, right?
MR. BEKESHA: going take. mean were talking about
THE COURT:
tell you that.
Again, dont know how long this
Its not going take hour can
Its not going take three hours.
MR. BEKESHA: could though, your Honor,
dont know where these documents
THE COURT:
thats not reasonable presumption.
Its not going take three hours
MR. BEKESHA:
time.
But over reasonable period
Were asking for review documents month.
THE COURT: thats question for you,
Judicial Watch prepared for the Court enter order
saying that Judicial Watch concedes that other cases
which has brought request does not object its
request being delayed while more narrower searches are
conducted?
MR. BEKESHA:
Well, no, your Honor, because every
FOIA lawsuit different.
FBI where theyve been producing records for three years and
theres one month left production doesnt make sense
for the agency stop working the last month production
when they could just pick something else once that
production complete.
circumstance situation. have lawsuit against the
Everything very specific
Now understand and appreciate what the Courts
concerns are, but right now were just talking about this
one FOIA request.
records.
want to, the agency wants identify other FOIA lawsuits
that are preventing them from reviewing these records said Judicial Watch would happy take look and work
Were talking about one set
And you know the agency wants you know
something out think its our best interest.
THE COURT:
Let this let put the burden you start with because Judicial Watch has got lot
cases pending and lot FOIA requests pending.
and look and see what you have pending with the FBI, you
have anything pending with the FBI.
that where Judicial Watch going say you know what
were happy shift resources.
some resources away from this other request that have, back theres something
And you want take
and devote instead moving forward with the request
were discussing today, would request that you meet and
confer with Mr. Lopez-Morales and see the parties can
work out something, okay, that.
conference for six weeks from now just check just
see where were standing.
MR. BEKESHA:
And can set status can have status conference
lot shorter than that, your Honor.
two weeks time. the other requests and see theres any way.
still, you know, think that still doesnt address the
first part the FOIA request that deals with the second. can probably can back the office, can look
THE COURT:
Thats
The first part you got partial
answer which that sounds like good portion the
materials which being searched first.
that should done the next couple months. was told that
MR. BEKESHA:
Right, but still dont know the
extent how many records are disk five.
disk five. dont believe theres been assessment
disk five.
Wed just like more information about you know
are they going process disk one and then disk five?
disk five going the last one processed? dont know how the agency deciding when choose
process Judicial Watchs FOIA requests.
Total records
Again, seems though were almost being punished,
because take it, because use the laws that are
available make information available the public.
THE COURT: think that see here its not question the FBI seeking punish Judicial Watch.
think its question just making sure that all FOIA
requestors are treated fair way.
understand the FBI has limited resources for producing the
FOIA requests.
day perhaps for someone able through, find the
files, pull them, initial review them, and then second level review for, with respect exemptions and
then presumably, Ill set prepare log.
get that done day dont know.
Because
And although may just matter
Maybe you can
Some whove taken time away from records,
and the question just being fair everybody whose got
the requests pending the process.
MR. BEKESHA:
But the FBI isnt even processing
the first request the State Department is.
THE COURT: know, but the FBI has gone know
from own calendar theyve got overwhelming number
FOIA requests.
MR. BEKESHA:
But with respect the first part the request the FBI isnt doing any work the State
Department doing it.
THE COURT:
And are you asking then maybe
well, thought were talking about the second part, but
with respect the first part your request are you
asking that the State Department the FBI assessment disk five?
MR. BEKESHA: believe the FBI should
because theyre the agency that received the FOIA request.
Thats the agency sued. that the State Department is, that theyve referred the
material the State Department, and the State Department better position that assessment then the State
Department has and should required it.
Thats only because the FBI seems suggest the State
Department better position.
THE COURT:
However, the FBIs position
Lets see what Mr. Lopez-Morales says
about just the assessment youve described.
MR. BEKESHA:
Thank you, your Honor.
MR. LOPEZ-MORALES:
THE COURT:
[Brief pause.]
MR. LOPEZ-MORALES:
One second, your Honor.
Sure.
Well, your Honor, you want respond the volume the materials disk five,
right?
THE COURT:
The question where stand with
respect the assessment disk five. with the binding records are? know whats know what
percentage the records that the plaintiffs are seeking
are disk five?
have some sense whats there this point?
Are they equally disk five?
MR. LOPEZ-MORALES: you dont have the
information whats the volume disk five. were told cant provide percentage the number
responsive records plaintiffs request relation the
volume the disk.
number documents that could potentially responsive
disk five and could provide those. do, and have very rough estimates the
Your Honor, before just want mention
opposing counsel said that were withholding information the Court and Judicial Watch about the, whats the
number responsive records.
totally reasonable and think you articulated terms trying allocate resources effectively equitable
Our position think which
manner. that Judicial Watch not entitled know
this time accordance with the agencys complex processing
queue and first first out policy which has been validated number times the Circuit and the DDC.
Watch simply has wait its turn.
well, its documents want them now.
respect the State Department and the materials that were
transferred there.
Judicial
Its not matter
And same with
But with respect the total number responsive
records disk five, there are two data sets Datto
materials disk five that contain the first Datto set,
contains 1,741 documents, and the second Datto set contains
8,435, sorry retrieved documents.
sets Datto materials which are potentially responsive and
these are very rough estimates.
disk five.
this point. there are two data want emphasize that thats the information that can provide
And would just want emphasize again that
the words opposing counsel would penalizing other
requestors very narrow requests.
mean death thousand cuts and piecemeal litigation
approach, and that simply inconsistent with Circuits
decision Open America and even after the congressional
amendments the FOIA statute 1996.
THE COURT:
That exactly what know when the State Department likely have processed disk five?
MR. LOPEZ-MORALES: not personally familiar.
What know that said the next couple months
they will done processing disk one, and the next step
would process disk four and disk five.
State Department processing these documents this
time not familiar with the information where they stand
with respect the next two disks.
THE COURT:
And since the
And would the FBI open somewhere
along the lines what was suggesting negotiating
resolution with Judicial Watch way which third party
requestors wouldnt penalized, but might possible move Judicial Watchs request the FBI here the
queue through some negotiated agreement?
MR. LOPEZ-MORALES: think your Honor would
open hear what Judicial Watch has say least with
respect the second part the requests where FBI
involved, yes.
THE COURT:
MR. LOPEZ-MORALES:
THE COURT:
Okay.
Thank you.
Thank you, your Honor.
Mr. Bekesha, dont know you
wanted respond any that?
MR. BEKESHA:
THE COURT:
[Brief pause.]
May have moment, your Honor. course.
MR. BEKESHA:
Your Honor, the only concern
still have is, you know, the agency counsel said you know
the Circuit has come away you know Open America.
could ask for Open America stay this case they
dont think they have the capacity respond these FOIA
requests.
that they could seek and get approval this Court.
they dont believe they can properly search and respond
these FOIA requests then thats what they should but they
They havent done so.
They
Thats legal mechanism,
havent done so.
look what our other litigation is.
there much litigation against the FBI.
And again, will back and take
THE COURT: dont believe
Its not really much litigation
think its FOIA requests?
MR. BEKESHA: have FOIA requests that are
pending probably for want say almost ten years with the
FBI.
THE COURT:
MR. BEKESHA:
Right.
All suggesting
And mean have lot FOIA
requests, but you know, dont even know theyre
processing most our FOIA requests because dont,
one will talk until sue.
guess would have could print out list
all our FOIA requests the FBI for say the past ten years
that havent been responded to, and ask the FBI which ones
And mean one thing
are you actively responding to.
doesnt seem make sense either.
THE COURT: mean that, that mean
Why dont this, cant really,
dont have any know even less about this than all
you about what requests are pending and whats being
worked on. back and look what you have, have conversation with
Mr. Lopez-Morales see theres some accommodation that
can reached.
Why dont least give you the opportunity there cant well come back
couple weeks and talk about what then and under
those circumstances.
But think that sort more generally and
you probably gathered the Courts concern just making
sure were not giving preferences one FOIA requestor over
another with respect getting their responses and that
everyone treated equal fashion with respect the
expeditious handling. required. actually something thats very pressing you know where
theres some world event thats getting ready occur,
need this information with respect that world event.
Thats one matter.
There are times which expedition
And you were come and say here this
But would need have some reason think
well, should put aside sort the normal, treat everyone
alike standard and have different standard that would
apply here, you come back thats -MR. BEKESHA:
Sure, but there strong public
interest investigative materials.
THE COURT: know there is. think thats
probably what big portion what the FBIs backlog
about.
MR. BEKESHA: thats the case then the FBI
should follow what the State Department did which was add
additional people conducting the reviews.
THE COURT:
You know one the things not
sure that they can that right now, you know. some way bring people over detail, dont know.
MR. BEKESHA:
Maybe there mean what the State Department was
they didnt out and hire new people.
They brought people
over detail conduct reviews because they had numerous
court orders.
that the FBI hasnt sought Open America stay.
havent said that they cant process these FOIA requests.
Until they they have
Again, that would seem appropriate case
THE COURT:
MR. BEKESHA:
They
Did the State Department seek stay?
The State Department dont believe
sought stay.
They just start hiring more, they had people
detailed and they start reviewing records, and were able
review one point think was over 3,000 pages month.
The FBI only reviewing 500 pages month.
THE COURT: impression this there
separate conversation can take next.
its fairly substantial staff already the FBI that
reviewing FOIA requests.
recall that from other cases and having looked
declarations from the FBI with respect their mechanisms. hear you and understand your concern.
get the records and understand that you view this sort fairly targeted search they can respond quickly. impression could mistaken. seem
Everyone wants
Why dont see there way they can have
conversation with governments counsel.
something out.
would say Mr. Lopez-Morales, next time guess one question might have for you youre unable work something
out whether you have some sense how much time would
actually take the FBI review and produce these files.
Are were talking about something that is, you know, hour
which seems improbable something that more
substantial than that.
And not, can take next time.
Okay.
MR. BEKESHA:
THE COURT:
You can work
Anything further today?
No, your Honor.
Okay.
Ill set another status
conference about two weeks from now.
MR. BEKESHA:
THE COURT:
Thank you, your Honor.
Were done.
[Thereupon, the proceedings adjourned 3:21
p.m.]
CERTIFICATE Cathryn Jones, Official Court Reporter
for the United States District Court the District
Columbia, hereby certify that reported, machine
shorthand, the proceedings had and testimony adduced the
above case. further certify that the foregoing pages
constitute the official transcript said proceedings
transcribed from machine shorthand notes. witness whereof, have hereto subscribed
name, this the 6th day February, 2017.
/s/_Cathryn Jones
Cathryn Jones, RPR
Official Court Reporter
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19/24 20/6 21/14 21/19 21/21 21/22
22/23 23/18 23/18 24/16 24/16 25/1
25/22 26/25 27/4 31/18 32/6 32/12
32/13 33/6
does [11] 4/24 5/1 11/7 11/14 12/14
13/14 15/18 17/18 18/13 20/7 27/8
doesnt [6] 15/24 22/15 25/12 27/14
28/20 35/2
doing [12] 6/13 13/4 13/22 13/24 15/2
18/5 19/6 21/25 22/1 24/11 30/7 30/8
dont [36] 2/15 4/9 10/4 16/15 17/1
17/5 18/8 18/18 20/22 21/1 21/2 21/22
21/22 22/11 23/18 25/3 26/12 26/20
26/25 29/1 29/3 29/7 29/22 31/13
33/21 34/5 34/8 34/11 34/20 34/21
35/3 35/4 35/6 36/12 36/21 37/10
done [10] 14/13 22/14 23/17 25/15
28/25 29/22 33/4 34/6 34/10 37/25
down [1] 26/18
drop [1] 21/25
during [2] 2/22 18/25
equal [1] 35/16
equally [1] 31/11
equitable [2] 16/24 31/25
equity [1] 20/7
Esquire [2] 1/12 1/15
estimates [2] 31/17 32/15 [1] 6/8
even [9] 3/13 6/10 8/24 12/16 20/6
30/1 32/23 34/20 35/4
event [2] 35/20 35/21
every [3] 25/8 25/8 27/11
everybody [1] 29/24
everyone [4] 16/25 35/16 35/24 37/7
everything [9] 4/24 4/25 5/1 9/1 11/11
11/12 12/10 12/10 27/17
exactly [2] 5/12 32/20
example [1] 15/11
exempted [1] 14/18
exemption [1] 5/9
exemptions [2] 20/1 29/20
exist [1] 25/6
exists [3] 10/5 10/22 12/16
expedite [2] 17/2 18/7
expedition [2] 14/5 35/17
expeditious [1] 35/17
explain [1] 3/6
extent [5] 5/23 15/11 16/10 16/11 29/2
extra [1] 22/11
follow [1] 36/8
foregoing [1] 38/9
forgot [1] 6/20
Form [1] 8/7
formal [1] 3/3
former [1] 9/5
forming [1] 4/4
forms [4] 6/6 15/14 15/22 16/10
forward [1] 28/10
found [6] 2/21 12/11 14/2 16/6 18/21
19/7
four [2] 14/15 33/5
Friday [1] 6/14
front [1] 8/6
full [2] 8/9 8/22
further [3] 16/20 37/20 38/9
gather [1] 23/20
gathered [2] 9/3 35/13
generally [2] 4/17 35/12
generate [1] 19/24
get [20] 11/5 11/9 11/18 14/17 15/25
17/23 17/24 18/21 19/12 19/16 19/21
20/8 22/4 22/11 23/4 23/10 24/22
29/22 34/7 37/8
getting [2] 35/15 35/20
give [4] 17/6 18/15 21/14 35/6
given [1] 11/8
giving [1] 35/14
fact [3] 18/4 23/8 25/17 [12] 7/14 8/20 20/2 24/2 24/3 25/12
28/4 28/18 29/18 34/10 35/7 36/14
fair [6] 7/17 9/17 9/20 12/17 29/15
29/24
goes [4] 7/2 7/19 12/8 22/7
going [26] 11/2 11/9 11/21 14/17
fairly [2] 37/3 37/9
15/25 17/24 18/1 18/21 19/2 19/5
familiar [4] 3/21 5/15 33/2 33/7
19/17 19/20 21/25 22/2 22/10 23/4
fashion [3] 25/22 25/23 35/16
23/5 23/11 24/4 26/21 26/22 26/23
favor [1] 15/5
27/1 28/7 29/5 29/6
FBI [54]
gone [1] 30/3
FBIs [7] 5/25 6/2 6/2 14/24 15/12
30/16 36/5
good [5] 2/6 2/9 2/10 3/8 28/23
got [7] 20/24 23/2 23/12 28/3 28/22
February [1] 38/13
29/24 30/4
Federal [1] 1/16
governed [1] 3/20
Fenton [1] 2/8
each [3] 3/13 3/15 7/11
government [4] 8/2 8/13 9/5 9/12
few [1] 21/21
easier [1] 15/21
governments [2] 3/5 37/11
figure [4] 8/21 9/19 16/23 24/3
easily [1] 18/16
groups [1] 18/11
figuring [2] 11/25 22/2
easy [2] 9/21 10/1
file [26] 6/3 6/4 6/13 6/18 6/22 7/1 7/25 guarantees [1] 13/2 [1] 25/9
8/20 9/12 12/15 13/6 13/11 13/14 15/3 guess [3] 25/7 34/23 37/13
effectively [2] 16/24 31/25
15/7 15/10 15/23 16/7 16/7 17/13 24/2
efficient [1] 24/11
24/12 24/14 25/15 25/18 25/21
efforts [2] 5/25 15/13
had [12] 2/19 6/10 6/23 7/12 8/6 9/7
filed [10] 3/1 4/3 5/17 6/9 6/10 6/23
either [2] 14/2 35/2
18/12 21/15 21/18 36/15 36/22 38/7
7/11 18/10 18/11 18/12
electronic [3] 4/19 5/11 8/12
half [1] 20/5
files [3] 5/21 29/19 37/16
electronically [1] 25/9
hand [1] 19/24
filing [3] 15/2 18/20 18/22
Ellis [1] 2/14
handle [4] 6/11 11/16 16/24 20/23
finally [1] 21/13
else [3] 9/1 25/19 27/16
handling [4] 4/21 20/18 20/18 35/17
find [2] 25/13 29/18
email [1] 2/23
happen [1] 18/23
fine [1] 21/5
emails [5] 10/14 10/16 10/18 14/20
happens [1] 11/22
first [29] 3/16 3/25 6/24 6/24 7/8 7/9
14/21
8/13 10/3 10/10 12/4 12/21 13/3 13/4 happy [5] 16/14 16/16 20/11 27/25
emphasize [3] 5/22 32/15 32/18
28/8
13/18 19/25 21/16 22/7 23/7 23/12
encompass [1] 5/1
harass [1] 18/20
24/23 28/21 28/22 28/24 30/2 30/6
encompassing [1] 17/20
has [34] 3/1 4/2 4/9 6/3 6/13 6/20 7/1
30/11 32/3 32/3 32/11
end [2] 21/11 26/4
7/14 8/2 10/16 11/10 11/12 12/24 13/4
five [19] 14/15 14/16 29/2 29/3 29/4
ensure [2] 10/17 12/1
29/5 29/6 30/13 31/5 31/8 31/11 31/11 13/6 13/7 13/13 13/22 13/23 14/4 15/2
enter [1] 27/6
19/10 19/22 19/25 26/15 27/8 28/3
31/14 31/19 32/10 32/11 32/16 33/1
entire [7] 8/19 9/11 15/23 17/13 24/12
29/16 30/3 30/20 32/3 32/5 33/16 34/3
33/5
24/13 26/5
hasnt [3] 20/13 23/24 36/17
FOIA [42]
entitled [1] 32/1
indicated [1] 16/13
individuals [1] 18/12
have [72]
inefficient [1] 16/22
havent [6] 23/25 25/19 34/6 34/10
information [17] 6/1 9/8 14/3 14/15
34/25 36/18
17/5 18/9 19/13 21/15 21/16 21/19
having [1] 37/5
29/4 29/11 31/14 31/21 32/16 33/7 [6] 19/2 21/15 21/16 21/16 21/17
35/21
21/18
informed [2] 3/16 6/4
head [1] 20/22
initial [1] 29/19
hear [3] 12/19 33/16 37/7
instance [3] 8/10 15/2 16/19
heard [1] 21/13
instances [1] 8/21
heavily [1] 5/15
instead [4] 8/18 15/22 22/23 28/10
helpful [1] 12/6
interest [2] 28/1 36/3
her [1] 7/18
interested [2] 4/8 19/8
here [18] 7/25 18/5 18/19 18/19 20/4
interferes [2] 17/21 18/2
20/25 21/13 22/4 22/6 22/13 23/16
interfering [1] 20/15
24/2 24/14 25/21 29/12 33/13 35/18
Internet [1] 4/16
36/1
interpretation [2] 9/17 9/17
hereby [1] 38/6
investigation [2] 2/23 9/3
hereto [1] 38/12
investigative [16] 5/21 6/2 6/4 6/13
Hillary [1] 25/18
6/18 6/22 7/25 8/20 9/11 13/11 15/3
hire [1] 36/14
15/7 17/13 24/14 25/18 36/3
hiring [1] 36/22
involve [2] 20/4 20/6
his [1] 19/1
involved [1] 33/18
hit [1] 26/1 [149]
hits [1] 9/13
isnt [6] 18/19 19/9 19/13 25/15 30/1
hold [2] 20/12 21/5
30/7
honestly [1] 9/20
issue [4] 5/16 20/7 24/15 26/8
Honor [34] 2/6 2/10 3/10 4/18 5/3 5/12
issues [1] 24/15
7/5 7/7 7/25 9/16 12/21 14/23 16/1
16/5 16/19 17/6 17/10 18/8 18/18 21/7 [85]
its [36] 4/15 5/6 7/17 9/16 10/8 11/13
21/16 26/24 27/11 28/17 30/25 31/1
11/14 11/21 12/10 13/1 16/9 19/22
31/4 31/20 33/15 33/20 33/23 34/1
20/6 21/19 22/13 23/10 23/16 23/16
37/21 37/24
24/4 24/13 24/21 24/25 25/7 25/9 25/9
HONORABLE [1] 1/9
26/22 26/23 27/1 28/1 29/12 29/14
hoping [1] 9/22
32/5 32/6 34/13 34/14 37/3
hour [3] 20/5 26/22 37/17
its [7] 2/22 6/11 9/2 13/7 13/8 27/8
hours [7] 20/5 20/6 24/6 24/7 26/19
32/5
26/23 27/1
House [2] 6/8 19/1
how [18] 4/22 7/18 8/15 9/1 9/13 11/2
January [3] 1/5 4/3 6/14
11/20 12/15 17/2 22/21 23/18 24/3
Jones [4] 1/19 38/4 38/15 38/16
24/6 25/15 26/20 29/2 29/7 37/15
JUDGE [16] 1/9 1/10 5/16 5/19 5/19
However [1] 30/16
6/4 6/15 7/10 7/14 7/17 7/22 8/6 12/25
hundreds [4] 4/21 6/3 13/12 14/7
13/5 14/23 15/15
judges [1] 23/3
judgment [1] 21/9
Ill [3] 7/7 29/21 37/22
JUDICIAL [55] [13] 5/3 7/24 17/20 18/19 20/1
jumping [1] 19/19
22/20 23/23 24/20 26/15 30/9 33/6
jumps [1] 22/12
34/18 36/10
just [37] 2/16 4/20 7/21 9/12 10/14
Ive [1] 23/12
10/18 11/8 11/25 13/5 13/13 14/18
I-messages [1] 10/15
16/14 16/20 16/22 18/2 18/6 18/23
idea [1] 7/10
19/12 19/23 21/1 22/9 23/11 24/11
identified [6] 14/6 14/8 20/14 23/17
25/21 27/16 27/20 28/14 28/14 29/4
25/19 26/16
29/14 29/17 29/24 30/24 31/20 32/18
identify [5] 2/4 13/18 25/3 26/5 27/23
35/13 36/22
important [1] 22/13
JUSTICE [14] 1/5 1/15 2/3 2/12 2/13
impression [2] 37/1 37/2
3/22 4/2 5/17 7/16 8/2 11/3 11/20
improbable [1] 37/18
11/23 11/25
incentive [1] 15/1
incentivize [1] 16/20
inclination [1] 13/13
key [3] 8/12 23/16 24/19
included [1] 12/12
know [55]
including [2] 16/7 17/15
inclusive [5] 16/9 16/9 16/15 16/17
16/17
laptops [1] 9/3
inconsistent [1] 32/22
larger [1] 18/20
last [6] 6/14 10/24 12/25 24/23 27/15
29/6
later [1] 17/25
laws [1] 29/10
lawsuit [7] 5/16 6/10 13/7 13/14 15/2
27/12 27/12
lawsuits [3] 11/8 16/20 27/23
lawyers [1] 20/18
layer [1] 19/25
layers [2] 21/20 26/2
least [3] 6/21 33/16 35/6
leave [1] 7/21
left [1] 27/14
legal [1] 34/6
Leopold [17] 3/21 4/4 4/14 5/1 5/6
10/8 10/16 10/18 10/20 13/17 13/19
13/21 14/11 14/19 14/20 17/17 22/5
Leopolds [3] 4/16 4/20 13/24
less [2] 19/21 35/4
let [8] 2/16 3/2 12/19 19/23 21/3 26/6
28/2 28/2
lets [6] 17/23 17/25 22/4 22/7 22/9
30/23
lets [1] 9/13
level [2] 20/3 29/20
library [4] 4/19 5/10 5/11 25/5
like [4] 15/22 17/23 28/23 29/4
likely [1] 33/1
limited [3] 8/4 14/20 29/16
line [2] 13/8 14/4
lines [1] 33/10
list [3] 21/1 21/2 34/23
litigated [4] 5/15 6/18 7/10 7/17
litigation [7] 13/2 21/2 21/11 32/21
34/11 34/12 34/13
little [1] 8/1
live [3] 9/14 16/14 26/11
located [3] 3/18 12/23 13/25
location [1] 3/14
log [1] 29/21
logistics [1] 12/1
long [6] 6/9 6/22 11/21 17/2 21/23
26/20
look [13] 12/22 16/5 17/14 18/23 21/8
23/19 23/20 25/8 27/25 28/5 28/18
34/11 35/7
looked [2] 10/17 37/5
looking [2] 9/9 15/22
looks [2] 3/4 21/5
Lopez [8] 1/15 2/11 3/9 12/20 28/12
30/23 35/8 37/13
Lopez-Morales [6] 1/15 2/11 28/12
30/23 35/8 37/13
lost [2] 11/5 11/9
lot [7] 23/15 24/7 25/17 28/3 28/4
28/17 34/19
machine [3] 1/24 38/6 38/11
made [1] 21/9
make [7] 3/5 15/18 19/2 21/12 27/14
29/11 35/2
makes [3] 8/17 10/19 12/17
making [2] 29/14 35/13
manner [3] 16/24 24/11 32/1
many [7] 8/15 9/13 20/6 23/18 24/6
many... [2] 26/19 29/2
Marcy [1] 2/13
Massachusetts [1] 1/16
material [8] 8/3 8/10 10/11 10/15
11/23 12/12 15/13 30/18
materials [24] 3/18 3/22 4/1 4/12 4/15
5/5 10/5 10/6 10/22 10/22 10/25 12/5
12/14 13/10 14/1 14/9 14/16 14/18
28/24 31/5 32/7 32/11 32/14 36/3
matter [4] 19/22 29/17 32/5 35/22
may [21] 4/3 4/25 7/17 8/8 8/8 9/25
10/25 11/5 11/13 12/12 12/17 18/16
20/18 21/12 21/20 21/21 21/23 23/10
24/22 29/17 33/23
maybe [5] 4/25 9/22 29/21 30/9 36/11 [15] 2/7 2/12 2/16 3/3 3/6 4/14
12/19 17/6 18/15 19/23 21/3 22/10
28/2 28/2 31/4
mean [15] 9/24 11/25 12/15 15/24
18/18 20/17 25/10 26/8 26/21 32/21
34/19 34/22 35/1 35/2 36/13
mechanism [1] 34/6
mechanisms [1] 37/6
meet [2] 8/16 28/11
mention [3] 6/20 21/17 31/20
mentioned [2] 3/11 17/11
mentioning [1] 15/19
merit [1] 13/14
message [1] 10/15
messages [2] 10/14 10/15
messy [1] 15/16
Michael [2] 1/12 2/6
might [2] 33/12 37/14
mine [4] 22/11 23/6 23/6 23/7
minimum [1] 25/2
minute [1] 17/6
mistaken [1] 37/4
moment [1] 33/23
month [12] 5/20 6/17 7/11 8/2 14/24
17/13 25/24 27/4 27/14 27/15 36/24
36/25
months [11] 6/14 8/3 8/19 11/21 14/14
17/12 18/22 22/22 25/25 28/25 33/3
Morales [8] 1/15 2/11 3/9 12/20 28/12
30/23 35/8 37/13
more [19] 3/5 10/13 12/15 17/18 17/19
18/16 18/22 19/19 20/16 22/3 23/7
23/15 26/1 26/14 27/9 29/4 35/12
36/22 37/18
MOSS [1] 1/9
most [1] 34/21
move [2] 7/20 33/13
moving [1] 28/10 [9] 2/9 2/15 7/6 13/24 28/12 30/23
33/21 35/8 37/13
Mr. [5] 3/9 4/20 12/20 13/21 22/5
Mr. Leopold [2] 13/21 22/5
Mr. Leopolds [1] 4/20
Mr. Lopez-Morales [2] 3/9 12/20
much [5] 23/20 24/4 34/12 34/13
37/15
multitracking [1] 13/3 [13] 2/10 10/8 17/6 18/4 20/9 20/22
23/12 27/5 30/4 37/1 37/2 38/11 38/12
N.W [1] 1/20
name [2] 2/11 38/13
narrow [3] 22/17 22/24 32/20
narrower [4] 23/7 23/12 26/14 27/9
need [12] 8/20 12/15 20/2 22/3 22/3
22/12 24/2 24/3 24/21 26/2 35/21
35/23
negotiated [1] 33/14
negotiating [1] 33/10
new [1] 36/14
next [8] 14/13 28/25 33/3 33/4 33/8
37/2 37/12 37/13
nine [1] 6/21 [7] 1/4 3/1 3/3 12/10 27/11 34/21
37/21
nonexempt [3] 6/12 7/1 13/25
normal [1] 35/24
not [56]
note [1] 10/24
notes [1] 38/11
nothing [1] 12/1
now [18] 10/8 12/1 15/6 16/21 18/1
18/14 18/22 20/17 21/14 23/2 24/23
25/23 27/19 27/20 28/14 32/6 36/11
37/23
number [15] 5/2 5/9 5/13 5/14 5/18
9/23 11/8 16/3 17/3 30/4 31/15 31/18
31/23 32/4 32/9
numbers [1] 4/9
numerous [1] 36/15 [1] 1/16
object [1] 27/8
obligation [2] 24/10 25/10
obviously [1] 13/6
occur [1] 35/20
OCR [2] 25/7 25/9
OCR-ed [1] 25/9
October [4] 2/19 3/12 3/23 19/7
off [2] 7/20 20/22
office [1] 28/18
official [5] 1/19 3/3 38/4 38/10 38/16
officials [2] 6/7 9/6 [1] 24/18
okay [9] 3/8 4/24 5/8 10/2 22/7 28/13
33/19 37/20 37/22
once [2] 12/24 27/16
one [40]
ones [3] 17/15 26/14 34/25
online [2] 8/11 8/11
only [9] 8/5 8/17 9/25 10/16 13/24
26/19 30/21 34/1 36/25
open [6] 32/23 33/9 33/16 34/3 34/4
36/17
opportunity [2] 21/8 35/6
opposing [8] 3/10 3/17 5/14 14/3
15/19 17/11 31/21 32/19
order [7] 3/23 6/16 13/17 14/11 22/9
24/5 27/6
orderly [1] 18/3
orders [1] 36/16
other [35] 9/5 9/5 13/15 14/7 14/21
16/11 18/11 18/13 19/11 19/17 20/8
20/14 20/17 20/18 20/20 21/4 21/10
22/1 22/6 22/10 22/12 22/15 23/2 23/3
23/4 26/11 26/11 26/17 27/7 27/23
28/9 28/19 32/19 34/11 37/5
our [19] 2/21 3/12 5/20 6/16 6/23 8/13
9/17 10/13 14/3 16/1 16/19 21/2 21/8
21/9 28/1 31/23 34/11 34/21 34/24
out [30] 6/24 8/9 8/21 9/19 10/13
11/13 11/17 11/21 11/25 13/4 15/7
15/9 15/18 15/21 16/23 18/21 19/7
19/20 21/14 22/2 23/2 24/3 24/5 28/1
28/13 32/3 34/23 36/14 37/12 37/15
over [10] 8/1 13/15 14/7 16/9 16/17
27/3 35/14 36/12 36/15 36/24
overwhelming [1] 30/4
own [3] 25/11 25/13 30/4
p.m [2] 1/6 38/2
pace [1] 17/12
page [3] 14/24 25/8 25/8
pages [25] 5/20 6/17 7/10 8/1 8/2 8/9
8/11 8/14 8/15 8/17 8/18 8/22 8/22
8/23 9/24 17/12 23/18 23/21 23/21
24/12 26/5 26/6 36/24 36/25 38/9
part [23] 2/24 3/13 3/15 3/16 3/18 3/25
4/1 4/6 4/6 5/22 5/24 7/8 8/14 9/9 10/3
14/22 15/12 28/21 28/22 30/6 30/10
30/11 33/17
partial [1] 28/22
particular [1] 22/13
parties [3] 9/5 19/20 28/12
parts [4] 2/19 3/11 8/23 17/22
party [5] 11/15 11/17 11/18 13/20
33/11
past [2] 19/10 34/24
pause [3] 17/9 31/3 33/25
penalize [1] 22/15
penalized [1] 33/12
penalizing [2] 22/16 32/19
pending [11] 17/19 18/14 20/20 21/10
28/4 28/4 28/5 28/6 29/25 34/16 35/5
people [6] 23/11 36/9 36/12 36/14
36/14 36/22
peoples [1] 20/8
per [3] 5/20 14/24 17/12
percentage [2] 31/10 31/15
perhaps [1] 29/18
period [3] 23/22 25/24 27/3
personally [1] 33/2
pick [1] 27/16
piecemeal [2] 13/1 32/21
piggyback [1] 19/5
place [3] 12/1 12/6 13/16
plaintiff [6] 1/3 1/12 4/8 6/9 6/23 17/14
plaintiffs [1] 31/16
plaintiffs [2] 16/13 31/10
plays [1] 11/21
please [1] 2/4
plus [1] 8/21
podium [1] 2/4
point [5] 10/24 20/11 31/12 32/17
36/24
policy [5] 6/16 6/24 6/25 13/4 32/3
portion [2] 28/23 36/5
portions [2] 6/12 7/1
posed [1] 19/15
position [14] 3/6 3/13 11/18 12/24
14/4 16/1 20/10 22/25 23/1 23/2 30/16
resolution [1] 33/11
resources [7] 13/14 15/5 16/23 28/8
position... [3] 30/19 30/22 31/23
28/9 29/16 31/25
positions [1] 7/12
respect [21] 3/13 3/15 3/16 9/10 10/3
possession [1] 6/2
13/7 13/9 13/11 13/24 29/20 30/6
possible [1] 33/12
quantity [1] 16/2
30/11 31/8 32/7 32/9 33/8 33/17 35/15
posted [3] 5/10 8/11 10/15
question [15] 5/9 10/11 18/4 18/17
35/16 35/21 37/6
posting [1] 4/15
19/15 19/16 20/9 21/3 22/2 27/5 29/13 respond [8] 11/6 17/3 24/4 31/5 33/22
potential [3] 11/4 12/23 15/25
29/14 29/24 31/7 37/13
34/5 34/8 37/9
potentially [4] 8/15 21/7 31/18 32/14
queue [5] 19/19 22/12 24/5 32/3 33/14 responded [1] 34/25
precisely [1] 15/1
queues [1] 13/3
responding [2] 17/20 35/1
prefer [1] 21/4
quickly [2] 19/21 37/9
response [5] 3/1 3/3 4/16 10/20 24/17
preferences [1] 35/14
quite [1] 9/20
responses [1] 35/15
preferential [1] 13/14
responsive [20] 3/2 3/14 3/17 3/25
preferred [1] 22/18
4/23 5/4 5/6 5/8 5/24 8/15 9/19 12/23
prepare [1] 29/21
ran [1] 16/6
13/19 13/23 15/25 31/16 31/18 31/23
prepared [2] 26/10 27/6
RANDOLPH [1] 1/9
32/9 32/14
president [2] 2/8 20/24
RDM [1] 1/4
result [1] 19/21
press [1] 24/3
reached [1] 35/9
retrieved [6] 2/21 4/7 4/11 14/10 14/21
pressing [3] 19/19 22/3 35/19
read [1] 25/8
32/13
presumably [2] 19/25 29/21
ready [1] 35/20
retrieving [2] 5/25 15/13
presumedly [2] 11/10 11/17
reallocate [1] 15/5
review [13] 8/18 11/14 11/24 19/25
presumption [1] 27/2
really [6] 10/21 15/18 15/24 20/9 34/13 20/3 21/21 22/22 26/2 27/4 29/19
preventing [1] 27/24
35/3
29/20 36/24 37/16
print [1] 34/23
reason [4] 19/15 22/13 22/13 35/23
reviewed [2] 23/21 25/22
prioritized [1] 14/7
reasonable [4] 9/17 27/2 27/3 31/24 reviewing [5] 10/25 27/24 36/23 36/25
probably [8] 3/5 22/8 23/22 24/24
reasons [2] 14/6 19/11
37/4
28/17 34/16 35/13 36/5
recall [1] 37/5
reviews [2] 36/9 36/15
problem [4] 9/25 12/23 21/24 26/12
received [5] 6/3 6/21 6/22 13/12 30/15 right [15] 10/8 11/19 12/9 13/6 15/6
proceed [1] 14/14
receiving [1] 6/12
16/16 18/14 20/17 20/25 26/19 27/20
proceedings [4] 1/24 38/1 38/7 38/10 recent [1] 15/8
29/1 31/6 34/18 36/11
process [20] 3/4 6/17 7/2 11/10 11/22 record [2] 2/5 14/19
robust [1] 22/5
13/16 15/5 15/6 15/9 16/22 17/1 17/11 recorded [1] 1/24
rolling [1] 24/22
17/21 21/11 24/10 29/5 29/8 29/25
records [62]
room [3] 1/20 22/4 22/6
33/5 36/18
recovered [2] 4/11 12/5
rough [2] 31/17 32/15
processed [7] 3/23 5/7 7/3 13/20
recovering [1] 5/25
RPR [2] 1/19 38/16
14/12 29/6 33/1
redact [1] 20/2
run [3] 14/25 21/18 23/16
processing [22] 3/19 4/2 5/7 5/20 6/25 reevaluate [1] 7/18
10/9 10/20 13/3 14/14 15/17 19/4
references [1] 15/23
19/18 20/15 22/21 24/12 25/15 25/25 referred [1] 30/17
said [11] 6/9 8/3 13/20 14/8 22/6 27/25
30/1 32/2 33/4 33/6 34/21
regardless [1] 5/5
31/21 33/3 34/2 36/18 38/10
produce [2] 8/18 37/16
rejected [2] 13/1 13/5
same [3] 13/12 14/22 32/6
produced [7] 1/24 7/11 8/4 10/17
relate [1] 16/3
say [15] 3/3 7/17 7/19 17/22 20/11
24/22 25/3 25/22
related [2] 2/24 2/25
21/4 22/4 22/10 24/6 28/7 33/16 34/16
producing [4] 25/1 26/17 27/13 29/16 relates [1] 5/24
34/24 35/18 37/13
production [12] 3/20 4/5 4/6 7/15 7/19 relation [1] 31/16
saying [5] 19/23 23/5 23/12 24/21 27/7
8/16 12/17 18/3 26/5 27/14 27/15
relatively [2] 9/21 23/22
says [1] 30/23
27/17
release [4] 6/12 6/14 13/21 19/5
schedule [9] 3/21 5/7 5/20 7/15 7/22
Program [1] 1/16
released [4] 4/9 4/19 7/1 17/15
8/16 12/17 14/24 15/17
properly [1] 34/8
releases [1] 17/16
scope [1] 9/15
proposal [1] 8/13
releasing [1] 4/15
scroll [1] 25/8
proposed [3] 7/16 9/21 14/24
relevance [1] 8/25
search [17] 8/14 9/15 9/23 14/25
proposing [1] 12/3
remaining [1] 4/10
15/24 16/6 16/14 16/18 17/2 17/24
prospective [1] 2/17
Remind [1] 4/14
18/2 21/18 23/17 24/18 25/11 34/8
provide [4] 14/2 31/15 31/19 32/16
report [2] 4/3 7/11
37/9
provided [2] 9/23 14/12
reported [1] 38/6
searchable [2] 25/5 25/10
provides [1] 13/17
Reporter [4] 1/19 1/19 38/4 38/16
searched [3] 8/12 18/9 28/24
public [6] 4/19 5/10 13/22 17/16 29/11 request [65]
searches [2] 25/13 27/9
36/2
requested [2] 5/2 15/8
searching [1] 9/18
publicly [1] 7/4
requesting [2] 6/5 6/6
second [16] 2/24 5/22 7/8 9/9 13/19
pull [6] 15/7 15/9 15/9 15/17 15/21
requestor [3] 22/1 25/11 35/14
14/22 15/11 18/15 19/9 20/3 28/21
29/19
requestors [11] 13/15 14/7 19/12 22/6 29/20 30/10 31/1 32/12 33/17
punish [1] 29/13
22/10 22/15 23/4 26/12 29/15 32/20
secret [1] 16/7
punished [1] 29/9
33/12
Secretary [3] 2/23 9/4 9/8
purposes [1] 3/20
requests [48]
see [11] 8/14 9/13 11/24 28/5 28/12
pursuant [2] 3/23 6/15
required [4] 21/21 25/2 30/20 35/18
28/15 28/19 29/12 30/23 35/8 37/10
push [1] 19/23
requiring [1] 8/19
seek [2] 34/7 36/20
pushed [1] 20/8
put [7] 20/11 21/5 22/25 23/1 23/5
28/2 35/24
putting [3] 25/10 26/13 26/13
27/17
specifically [3] 21/18 25/20 26/16
seeking [3] 18/6 29/13 31/10
spend [1] 22/2
seem [4] 11/7 35/2 36/16 37/4
spoke [2] 3/3 21/16
seems [4] 11/4 29/9 30/21 37/18
spread [1] 10/12
send [3] 11/17 22/17 22/18
staff [1] 37/3
SENIOR [1] 1/9
stand [3] 2/16 31/7 33/7
sense [11] 3/5 8/17 10/19 12/17 15/18
standard [2] 35/25 35/25
16/2 21/12 27/14 31/12 35/2 37/15
standing [2] 18/19 28/15
sent [3] 18/24 19/3 19/9
start [5] 2/16 25/25 28/3 36/22 36/23
sentences [1] 21/23
State [42]
separate [2] 8/9 37/2
stated [2] 6/11 26/16
series [2] 23/9 23/11
STATES [3] 1/1 1/10 38/5
serve [1] 17/22
status [8] 1/8 4/3 4/4 7/11 7/12 28/13
served [1] 18/5
28/16 37/22
server [1] 14/22
statute [1] 32/24
set [7] 8/4 27/21 28/13 29/21 32/11
stay [4] 34/4 36/17 36/20 36/22
32/12 37/22
step [1] 33/4
sets [2] 32/10 32/14
still [6] 10/4 14/4 28/20 28/20 29/1
several [6] 6/14 9/3 9/3 18/10 20/23
34/2
21/20
stipulate [1] 16/18
share [1] 21/19
stop [3] 19/22 26/17 27/15
she [2] 5/19 7/22
Street [1] 1/13
shift [1] 28/8
strong [1] 36/2
short [1] 23/22
subfiles [1] 16/7
shorter [1] 28/17
subject [3] 5/9 15/15 16/3
shorthand [3] 1/24 38/7 38/11
submitted [2] 2/19 3/12
should [9] 5/22 14/7 25/2 28/25 30/14
subscribed [1] 38/12
30/20 34/9 35/24 36/8
subset [3] 17/25 18/6 18/7
shouldnt [1] 26/4
substantial [2] 37/3 37/19
shown [2] 23/24 23/25
substantially [1] 23/10
shows [2] 9/24 9/25
substantive [1] 18/10
similar [1] 3/13
such [2] 23/9 25/3
simple [2] 23/14 23/16
sue [1] 34/22
simply [2] 32/5 32/22
sued [3] 11/3 11/5 30/16
since [1] 33/5
suggest [1] 30/21
situation [2] 15/16 27/18
suggested [1] 9/21
six [4] 10/7 10/12 11/22 28/14
suggesting [3] 19/11 33/10 34/18
sixth [1] 12/22
suing [1] 19/11
slow [1] 26/18
Suite [1] 1/13
small [2] 18/10 24/15
supposed [1] 25/16
snags [1] 26/1
sure [11] 2/18 5/3 22/20 23/23 24/21 [66]
26/15 29/14 31/2 35/14 36/2 36/11
solution [2] 9/21 10/1
surprised [1] 24/25
some [27] 4/7 7/3 11/1 11/9 11/14
suspect [1] 24/24
12/22 17/1 17/22 17/25 18/7 21/23
1/13
22/1 22/5 22/12 22/13 22/14 24/9 26/1 [1]
system [1] 19/14
28/9 29/23 31/12 33/14 35/8 35/20
35/23 36/12 37/15
somebody [2] 20/7 23/19
table [2] 2/8 2/12
somehow [1] 4/16
take [19] 11/22 17/2 17/12 21/8 23/19
someone [7] 17/21 19/21 19/22 19/25 24/4 24/7 24/7 26/21 26/22 26/23 27/1
21/25 21/25 29/18
27/25 28/8 29/10 34/10 37/2 37/12
something [13] 7/24 14/19 20/4 20/5 37/16
27/16 28/1 28/6 28/13 35/19 37/12
taken [2] 12/24 29/23
37/14 37/17 37/18
talk [6] 3/7 7/8 26/3 26/6 34/22 35/10
somewhat [1] 3/13
talked [1] 19/10
somewhere [1] 33/9
talking [9] 9/11 20/4 24/16 26/9 26/21
sooner [1] 17/23
27/20 27/21 30/10 37/17
sorry [3] 10/6 26/7 32/13
target [1] 18/23
sort [6] 18/7 22/3 26/10 35/12 35/24
targeted [2] 23/7 37/9
37/8
tell [2] 25/13 26/23
sorts [1] 16/11
ten [7] 8/17 8/18 8/21 8/22 9/25 34/16
sought [2] 36/17 36/22
34/24
sounded [1] 19/4
terms [1] 31/24
sounds [2] 3/8 28/23
testimony [2] 19/1 38/7
source [1] 3/14
text [1] 10/14
specific [5] 9/10 15/8 15/18 15/21
than [7] 10/14 20/16 20/19 23/6 28/17
35/4 37/19
Thank [8] 2/15 7/6 7/7 17/10 30/25
33/19 33/20 37/24
that [225]
thats [27] 4/22 6/18 14/17 16/1 21/10
21/21 21/24 22/20 22/21 23/13 23/23
23/25 24/16 27/2 27/5 28/19 30/16
30/21 32/16 34/6 34/9 35/19 35/20
35/22 36/1 36/4 36/7
their [9] 3/6 9/13 14/6 19/21 24/10
24/17 25/11 35/15 37/6
theirs [1] 23/6
them [15] 4/2 15/9 15/10 19/24 20/15
22/4 22/22 22/23 23/19 24/4 24/7
27/24 29/19 29/19 32/6
themselves [1] 24/19
then [32] 3/6 4/15 4/24 5/18 8/15 8/20
8/22 8/23 9/24 11/17 11/22 11/24
14/14 15/16 16/21 20/3 21/3 23/3 23/7
24/3 24/5 25/14 26/6 26/11 29/5 29/19
29/21 30/9 30/19 34/9 35/10 36/7
there [41]
theres [13] 12/1 17/22 17/25 19/8
20/3 24/9 26/18 27/14 28/6 28/19 29/3
35/8 35/20
Thereupon [1] 38/1
these [16] 9/6 12/16 15/5 16/9 17/14
18/24 21/6 25/21 26/25 27/24 32/15
33/6 34/5 34/9 36/18 37/16
they [70]
theyre [15] 10/25 11/24 16/10 16/11
16/16 18/6 21/11 22/1 23/15 24/11
24/12 24/21 25/10 30/15 34/20
theyve [6] 18/9 23/17 24/25 27/13
30/4 30/17
thing [2] 12/4 34/22
things [4] 2/16 23/9 24/20 36/10
think [24] 7/17 9/16 9/20 12/4 12/15
14/12 16/15 17/11 19/18 24/9 25/23
28/1 28/20 29/12 29/14 31/23 31/24
33/15 34/5 34/14 35/12 35/23 36/4
36/24
third [9] 1/13 9/5 11/15 11/17 11/18
13/20 13/21 19/20 33/11
this [60]
those [18] 3/22 4/1 4/6 7/3 8/18 8/21
8/22 8/24 11/1 15/9 18/22 20/2 23/9
23/18 23/21 26/6 31/19 35/11
though [7] 3/5 3/14 19/4 20/6 21/24
26/24 29/9
thought [1] 30/10
thousand [2] 13/1 32/21
three [5] 25/24 25/25 26/23 27/1 27/13
through [4] 8/20 20/2 29/18 33/14
throughout [3] 10/13 15/23 16/6
time [16] 7/14 7/18 19/9 22/2 22/11
23/20 23/22 24/4 27/4 28/18 29/23
32/2 33/7 37/12 37/13 37/15
timely [3] 24/11 25/22 25/23
times [3] 9/25 32/4 35/17
timing [1] 18/24
today [4] 12/24 18/19 28/11 37/20
together [1] 22/4
told [4] 5/19 12/8 28/24 31/15
Tom [1] 2/8
too [1] 26/11
took [1] 12/25
top [2] 16/7 20/22
total [3] 23/20 29/2 32/9
totally [1] 31/24
towards [1] 21/11
track [1] 23/13
tracks [1] 23/14
transcribed [1] 38/11
transcript [3] 1/8 1/24 38/10
transcription [1] 1/24
transfer [1] 13/19
transferred [10] 3/19 4/12 10/6 10/7
10/22 10/25 12/12 13/10 14/9 32/8
transfers [1] 11/23
treat [1] 35/24
treated [2] 29/15 35/16
treatment [1] 13/15
true [4] 11/13 22/20 23/23 23/25
try [3] 12/16 16/23 19/16
trying [4] 18/20 19/12 19/14 31/25
turn [4] 11/13 13/8 23/7 32/5
two [19] 2/19 3/11 5/13 5/14 8/14 16/3
17/4 17/24 19/10 21/23 24/17 24/20
24/21 24/23 28/18 32/10 32/13 33/8
37/23
type [2] 9/12 15/20
types [3] 8/7 15/20 15/21
U.S [6] 1/5 1/15 1/20 2/3 2/11 2/13
unable [1] 37/14
unclear [1] 16/9
under [4] 16/9 16/15 16/17 35/10
understand [7] 11/11 19/7 21/20
27/19 29/16 37/7 37/8
understanding [2] 2/21 10/9
unfairly [1] 22/15
UNITED [3] 1/1 1/10 38/5
unlike [1] 8/6
unlikely [1] 11/7
until [4] 21/17 26/4 34/22 36/19 [9] 9/8 9/24 9/25 21/17 27/16 29/21
33/13 37/2 37/12
urgent [1] 22/3 [11] 5/19 8/19 9/23 11/6 22/22 24/7
25/13 26/6 29/11 29/23 34/22
usage [1] 2/23
use [1] 29/10
used [1] 15/6
validated [1] 32/3
versus [3] 2/3 3/22 15/20
very [10] 5/15 8/4 16/22 16/24 24/13
27/17 31/17 32/15 32/20 35/19
view [1] 37/8
volume [3] 31/5 31/14 31/17
wait [10] 8/19 11/21 13/8 14/4 22/11
22/22 24/17 24/21 26/4 32/5
want [18] 9/12 10/16 11/6 14/18 17/25
21/8 22/11 22/22 22/23 25/12 27/23
28/8 31/4 31/20 32/6 32/15 32/18
34/16
wanted [1] 33/22
wants [4] 22/17 27/22 27/23 37/7
was [28] 2/20 2/22 3/12 4/11 5/16 6/5
6/12 6/14 7/9 7/12 7/13 9/2 12/11
12/25 14/10 19/1 19/2 19/4 19/16
19/16 20/9 21/13 21/18 28/24 33/10
36/8 36/13 36/24
Washington [4] 1/5 1/13 1/17 1/21
wasnt [3] 7/16 21/14 21/17
WATCH [50]
Watchs [5] 17/3 23/5 23/8 29/8 33/13
way [11] 11/16 16/23 18/2 22/14 22/14
24/1 28/19 29/15 33/11 36/12 37/10 [120]
wed [2] 17/23 29/4
well [2] 19/23 35/9
were [31] 9/9 9/11 15/25 17/24 18/1
18/19 18/20 18/22 19/12 19/13 19/13
20/3 20/11 21/13 24/14 24/16 25/14
25/20 25/21 26/9 26/21 27/4 27/20
27/21 28/8 28/11 28/15 29/9 35/14
37/17 37/25
weve [3] 8/1 8/4 19/7
week [1] 12/25
weeks [6] 17/25 19/10 28/14 28/18
35/10 37/23
well [16] 4/4 4/23 4/25 10/20 12/4
12/21 13/3 15/13 17/22 24/6 24/9
27/11 30/10 31/4 32/6 35/24
were [19] 2/20 3/19 4/12 6/6 6/22 12/5
13/10 14/21 15/14 19/5 19/6 19/8 22/6
30/10 31/15 31/21 32/7 35/18 36/23
werent [1] 18/21
what [52]
whats [8] 9/19 9/19 24/5 31/8 31/12
31/14 31/22 35/5
when [6] 9/2 11/13 21/16 27/16 29/7
32/25
where [23] 2/16 3/4 3/14 8/7 8/21 8/24
10/5 10/21 12/16 12/22 18/6 21/10
22/9 23/2 23/2 26/25 27/13 28/7 28/15
31/7 33/7 33/17 35/19
whereof [1] 38/12
whether [6] 5/6 10/18 20/7 20/17
20/19 37/15
which [27] 2/21 3/24 4/8 5/24 8/8
11/15 13/5 13/18 14/11 14/12 14/23
15/1 15/16 19/15 20/7 23/17 27/8
28/23 28/24 31/23 32/3 32/14 33/11
34/25 35/17 36/8 37/18
while [6] 16/22 20/12 21/5 22/11 26/14
27/9
White [1] 6/8
who [3] 19/20 22/7 23/4
whove [1] 29/23
whole [4] 6/21 15/7 25/15 25/21
whose [1] 29/24
why [11] 2/15 13/5 14/6 14/23 19/10
19/11 22/13 23/13 35/3 35/6 37/10
will [10] 5/6 5/10 6/15 6/16 14/13
14/14 15/3 33/4 34/10 34/22
willing [2] 21/14 21/18
withheld [1] 8/22
withholding [1] 31/21
withholdings [2] 26/7 26/8
without [1] 9/18
witness [1] 38/12
word [9] 8/12 8/14 9/18 14/25 16/8
16/14 17/14 23/16 24/19
words [1] 32/19
work [10] 19/6 20/5 20/6 25/16 26/17
27/25 28/13 30/7 37/11 37/14
worked [1] 35/6
working [3] 18/14 20/10 27/15
works [1] 24/1
world [2] 35/20 35/21
would [59]
wouldnt [5] 8/24 16/17 23/19 24/24
33/12
year [1] 24/18
years [6] 24/21 24/23 25/14 27/13
34/16 34/24
yes [7] 4/18 5/12 7/5 7/5 9/16 17/8
33/18
yesterday [5] 3/4 3/17 9/22 10/4 21/15
yet [1] 3/2
you [88]
youd [1] 18/15
youre [3] 3/21 18/14 37/14
youve [3] 20/24 23/2 30/24
your [49]
yourself [3] 2/4 22/25 23/1