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Judicial Watch • JW v State Hillary email discovery 01363

JW v State Hillary email discovery 01363

JW v State Hillary email discovery 01363

Page 1: JW v State Hillary email discovery 01363

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Number of Pages:5

Date Created:March 15, 2016

Date Uploaded to the Library:March 15, 2016

Tags:clintonemail, Discovery, 01363, Abedin, hillary, email, Secretary, defendant, filed, clinton, plaintiff, document, State Department, michael, FOIA, department, district


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Case 1:13-cv-01363-EGS Document Filed 03/15/16 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)
PLAINTIFF JUDICIAL WATCH RESPONSE
THE COURT FEBRUARY 23, 2016 ORDER
Pursuant the Court February 23, 2016 Order, Plaintiff Judicial Watch states:
Attached Exhibit Plaintiff proposed discovery plan.
Judicial Watch only aware one pending motion for discovery related the
use the clintonemail.com system Mrs. Clinton and least one other former State
Department employee conduct official government business. That motion was filed
Judicial Watch, Inc. U.S. Department State, Case No. 14-cv-01242-RCL before Judge
Lamberth and has been fully briefed October 2015. Judicial Watch has reason
dispute Defendant assertion that two other motions for discovery have been filed cases
which Judicial Watch not party.
Dated: March 15, 2016
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.
Case 1:13-cv-01363-EGS Document 58-1 Filed 03/15/16 Page
EXHIBIT
Case 1:13-cv-01363-EGS Document 58-1 Filed 03/15/16 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)
PLAINTIFF JUDICIAL WATCH PROPOSED DISCOVERY PLAN
Pursuant the Court February 23, 2016 Order, Plaintiff submits this proposed
discovery plan:
Plaintiff intends depose the following individuals:
Stephen Mull (Executive Secretary the State Department from June
2009 October 2012 and suggested that Mrs. Clinton issued State
Department BlackBerry, which would protect her identity and would also subject FOIA requests);
Lewis Lukens (Executive Director the Executive Secretariat from
2008 2011 and emailed with Patrick Kennedy and Cheryl Mills about
setting computer for Mrs. Clinton check her clintonemail.com
email account);
Patrick Kennedy (Under Secretary for Management since 2007 and
the Secretary State principal advisor management issues, including
technology and information services);
Donald Reid (Senior Coordinator for Security Infrastructure, Bureau
Diplomatic Security since 2003 and was involved early discussions
about Mrs. Clinton using her BlackBerry and other devices conduct
official State Department business);
30(b)(6) deposition(s) Defendant regarding the processing FOIA
requests, including Plaintiff FOIA request, for emails Mrs. Clinton and
Ms. Abedin both during Mrs. Clinton tenure Secretary State and after;
Case 1:13-cv-01363-EGS Document 58-1 Filed 03/15/16 Page
Huma Abedin (Mrs. Clinton Deputy Chief Staff and senior advisor Mrs. Clinton throughout her four years Secretary State and also
had email account clintonemail.com); and
Cheryl Mills (Mrs. Clinton Chief Staff throughout her four years
Secretary State);
Bryan Pagliano (State Department Schedule employee who has been
reported have serviced and maintained the server that hosted the
clintonemail.com system during Mrs. Clinton tenure Secretary
State).
Plaintiff intends conduct these depositions within eight weeks the Court
order Plaintiff proposed discovery plan.
Based information learned during discovery, the deposition Mrs. Clinton
may necessary. Plaintiff believes Mrs. Clinton testimony required, will request
permission from the Court the appropriate time. the extent that the above-identified individuals have not already provided the
information, Plaintiff will request permission from the Court conduct 30(b)(6) deposition(s)
Defendant concerning:
the creation establishment the clintonemail.com system well
any maintenance, service, support provided the State Department
that system;
the knowledge awareness State Department officials and employees
about the existence and use the clintonemail.com system;
any instructions directions given State Department officials and
employees about communicating with Mrs. Clinton and Ms. Abedin via
email;
any inquiries into Mrs. Clinton use the clintonemail.com system
well any discussions about responding such inquiries publicly
revealing the existence and use the clintonemail.com system the
public; and
the inventorying other accounting Mrs. Clinton and Ms. Abedin
email upon their departure from the State Department.
-2-
Case 1:13-cv-01363-EGS Document 58-1 Filed 03/15/16 Page
Plaintiff also intends submit the following interrogatories Defendant assist
Plaintiff identifying key individuals responsible for specific functions the State Department:
Who was responsible for the inventorying other accounting Mrs.
Clinton and Ms. Abedin emails, records, and information;
Who was responsible for responding Plaintiff FOIA request from the
date submission the present; and
Who was responsible for processing and/or responding record requests,
including FOIA requests, concerning emails Mrs. Clinton and other
employees the Office the Secretary;
Which State Department officials and employees had and/or used
account the clintonemail.com system conduct official government
business.
Plaintiff requests that the Court shorten the time period for Defendant respond Plaintiff interrogatories days. the extent that the individuals identified response Plaintiff
interrogatories have not already been deposed, Plaintiff will request permission from the Court
depose such individuals, Plaintiff determines their testimony necessary.
Dated: March 15, 2016
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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