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Judicial Watch • JW v. State Mills Response to Interrogatories 01363

JW v. State Mills Response to Interrogatories 01363

JW v. State Mills Response to Interrogatories 01363

Page 1: JW v. State Mills Response to Interrogatories 01363

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Number of Pages:8

Date Created:July 11, 2016

Date Uploaded to the Library:August 09, 2016

Tags:Platte, Oscar, identified, conversation, interrogatory, interrogatories, Networks, River, clintonemail, Pagliano, Justin, recall, bryan, Clintons, cooper, 01363, response, Mills, email, Secretary, 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)
~~~~~~~~~~)
NON-PARTY DEPONENT CHERYL MILLS RESPONSES PLAINTIFFS
INTERROGATORIES May 27, 2016, non-party deponent Cheryl Mills sat for deposition the above
captioned case and answered Plaintiffs questions, the best her ability, for nearly hours.
During that time, counsel for Ms. Mills instructed her not answer certain questions that appeared call for information covered the attorney-client privilege. Subsequently, Plaintiff informed
Ms. Mills its intent file motion compel Ms. Mills answer certain questions objected that basis. effort resolve this dispute without the involvement the Court, Ms. Mills
and Plaintiff agreed that Plaintiff would prepare detailed interrogatories specifying the particular
information sought for Ms. Mills review. Having reviewed those interrogatories, Ms. Mills
able provide the responses set forth below without divulging information protected the
attorney-client work product privilege. Plaintiff has agreed that Ms. Mills provision these
responses obviates the need for the motion compel had previously contemplated. providing these responses, Ms. Mills does not, and does not intend to, waive any
privilege. Nor does she waive any objections made her counsel questions posed during her
May deposition, including objections information Plaintiff sought being outside the scope
permissible discovery defined the Court its Order May 2016.
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, compnsmg,
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 Clintons and Ms.
Abedins clintonemail.com email accounts, including, the extent such issues were discussed,
any and all server( 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.
Response: recall having conversations with Bryan Pagliano, which believe were telephone,
three time periods following February 2013: around March 2013, when the email account Sidney Blumenthal was
compromised hacker known Guccifer. recall, these discussions
involved whether this event might affect Secretary Clintons email; around Spring 2013, during the transition Platte River Networks.
recall, these discussions were the context contract negotiations with Platte
River Networks and involved how the needs the clintonemail.com system would met the services proposed Platte River Networks; and and around Summer Fall 2014, when were seeking gather Secretary
Clintons emails provide those that were work-related the Department State. recall, these discussions involved whether Platte River Networks would have
the technical capacity and the appropriate source from which gather Secretary
Clintons email from the clintonemail.com system. not recall discussing any the above conversations the initial set the
clintonemail.com system, including who set the system, when was set up, where the
system was located, the reason for which had been established, anything related
Huma Abedins email account. While not recall the duration these conversations, believe that Bryan and were the only parties these conversations.
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.
Response: described Response above, not recall conversations regarding the initial set the clintonemail.com system. such, not recall Bryan identifying any person persons with knowledge the initial set the clintonemail.com system.
Describe with specificity each conversation you had with Justin Cooper concerning
the setup the clintonemail.com system that hosted Secretary Clintons and Ms. Abedins
clintonemail.com email accounts, including, the extent such issues were discussed, any and
all server( 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.
Response: the best recollection, had telephone conversations with Justin Cooper about the
initial set Secretary Clintons email early 2015. recall that Justin advised that
President Clintons office originally hosted its office staff email Apple server, and
that 2009, their email was migrated newer server that was acquired from excess
equipment available from Secretary Clintons 2008 presidential campaign. recall that
Justin advised that Secretary Clintons clintonemail.com account was later added
this existing server when she transitioned from the email address she had used while she
was the Senate. believe that Justin advised that Bryan Pagliano had assisted with
the installation this newer server. While not recall the duration these
conversations, believe that Justin and were the only parties these conversations.
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.
Response: the best recollection, believe Justin identified Bryan Pagliano having
knowledge about the initial set the clintonemail.com system.
Describe with specificity each conversation you had with Oscar Flores concerning
the setup the clintonemail.com system that hosted Secretary Clintons and Ms. Abedins
clintonemail.com email accounts, including, the extent such issues were discussed, any and
all server( 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.
Response: the best recollection, recall one telephone conversation with Oscar Flores about
Secretary Clintons email system early 2015. While not recall the duration the
call, believe was relatively short and that Oscar and were the only parties this
conversation. recall that Oscar advised that President Clintons personal staffs email
had been Apple computer server and that some point the personal staffs email
was migrated new equipment. believe that Oscar advised that Justin Cooper, who
had previously served President Clintons aide and advisor, might have more
information about the email system than Oscar had.
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.
Response: the best recollection, believe that Oscar identified Justin Cooper potentially
having more information than Oscar had about the initial set the clintonemail.com
system.
Dated: July 11, 2016
Respectfully submitted,
Isl Beth Wilkinson
Beth Wilkinson (D.C. Bar No. 462561)
Alexandra Walsh (D.C. Bar No. 490484)
WILKINSON WALSH ESKOVITZ LLP
1900 Street NW, Suite 800
Washington, D.C. 20036
Telephone: (202) 847-4000
Facsimile: (202) 847-4005
bwilkinson@wilkinsonwalsh.com
awalsh@wilkinsonwalsh.com
Counsel for Ms. Mills
VERIFICATION hereby declare under penalty perjury that the facts stated the foregoing responses
Judicial Watchs Interrogatories (Nos. 1-6) are true and correct the best knowledge,
information, and belief.
Dated: July l!_, 2016
C~D.MILLS
CERTIFICATE SERVICE hereby certify that July 11, 2016, the foregoing Interrogatory Responses were served
upon the parties this case via electronic mail.
Isl Beth Wilkinson
Counsel for Cheryl Mills