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Judicial Watch • JW v. State Mills Interrogatories 01363

JW v. State Mills Interrogatories 01363

JW v. State Mills Interrogatories 01363

Page 1: JW v. State Mills Interrogatories 01363

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Number of Pages:4

Date Created:June 30, 2016

Date Uploaded to the Library:August 09, 2016

Tags:Oscar, identified, conversation, Ramona, Rodham, interrogatory, interrogatories, clintonemail, Pagliano, accounts, 01363, Abedin, Mills, email, Secretary, clinton, State Department, plaintiff, department


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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 INTERROGATORIES CHERYL MILLS
Plaintiff Judicial Watch, Inc., pursuant agreement with Cheryl Mills, requests that
Ms. Mills fully answer the following interrogatories under oath, required Fed. Civ.
33, attempt resolve discovery dispute concerning Ms. Mills refusal answer certain
questions posed her her May 27, 2016 court-ordered deposition this lawsuit.
DEFINITIONS
The following words terms shall deemed mean the following:
The term clintonemail.com email system shall mean the email system,
server(s), provider(s) and infrastructure that hosted the email accounts used former Secretary State Hillary Rodham Clinton and her deputy chief staff, Huma Abedin, during their tenure the State Department with the domain name clintonemail.com.
The term clintonemail.com email account for former Secretary State Hillary
Rodham Clinton shall mean the email account used Secretary Clinton during her tenure the
State Department with the domain name clintonemail.com.
The term clintonemail.com email account for Huma Abedin shall mean the
email account used Ms. Abedin during her tenure the State Department with the domain
name clintonemail.com.
The term concerning shall mean affecting, bearing upon, comprising,
constituting, containing, dealing with, embodying, embracing, encompassing, entailing,
evidencing, germane to, identifying, implicating, including, incorporating, involving, pertaining
to, regarding, relating to, referring to, reflecting any manner.
The term describe shall mean fully and completely state, explain, illustrate,
characterize, define, delineate, recount, detail, designate, expound, elucidate, recapitulate.
INSTRUCTIONS you object any interrogatory the grounds that the interrogatory calls for
information that subject claim privilege, state with specificity the privilege that
claimed apply and identify all information sufficient permit Plaintiff contest the claim
privilege and permit the Court reach determination concerning the validity the claim
privilege, together with the factual and legal basis for the claim privilege.
INTERROGATORIES
Describe with specificity each conversation you had with Bryan Pagliano
concerning the setup the clintonemail.com system that hosted Secretary Clinton and Ms.
Abedin clintonemail.com email accounts, including, the extent such issues were discussed,
any and all server(s) used for the system and accounts, when the servers and accounts were set
up, who set them up, where they were set up, how they were set up, and why they were set up.
Also include your answer, when each conversation took place, names all persons present
during each conversation, method communication (whether person otherwise) and the
approximate duration each conversation. You may limit your answer the time period after
you left the State Department around February 2013.
Name all individuals Bryan Pagliano identified, any, all conversations
described your answers Interrogatory No. above with knowledge about the setup the
clintonemail.com system. Include your answer the title and positions all persons
identified, including but not limited all employees identified from the State Department.
Describe with specificity each conversation you had with Justin Cooper
concerning the setup the clintonemail.com system that hosted Secretary Clinton and Ms.
Abedin clintonemail.com email accounts, including, the extent such issues were discussed,
any and all server(s) used for the system and accounts, when the servers and accounts were set
up, who set them up, where they were set up, how they were set up, and why they were set up.
Also include your answer, when each conversation took place, names all persons present
during each conversation, method communication (whether person otherwise) and the
approximate duration each conversation. You may limit your answer the time period after
you left the State Department around February 2013.
Name all individuals Justin Cooper identified, any, all conversations
described your answers Interrogatory No. above with knowledge about the setup the
clintonemail.com system. Include your answer the title and positions all persons
identified, including but not limited all employees identified from the State Department.
Describe with specificity each conversation you had with Oscar Flores concerning
the setup the clintonemail.com system that hosted Secretary Clinton and Ms. Abedin
clintonemail.com email accounts, including, the extent such issues were discussed, any and
all server(s) used for the system and accounts, when the servers and accounts were set up, who
set them up, where they were set up, how they were set up, and why they were set up. Also
include your answer, when each conversation took place, names all persons present during
each conversation, method communication (whether person otherwise) and the
approximate duration each conversation. You may limit your answer the time period after
you left the State Department around February 2013.
Name all individuals Oscar Flores identified, any, all conversations described your answers Interrogatory No. above with knowledge about the setup the
clintonemail.com system. Include your answer the title and positions all persons
identified, including but not limited all employees identified from the State Department.
Dated: June 30, 2016
Respectfully submitted,
/s/ Ramona Cotca
Ramona Cotca (D.C. Bar No. 501159)
Judicial Watch, Inc.
425 Third Street,
Suite 800
Washington, 20024
(202) 646-5172
rcotca@judicialwatch.org
Counsel for Plaintiff