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OIS Cases FileGate-Exhibits-05

OIS Cases FileGate-Exhibits-05

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  • demand_answers

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THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT COLUMBIA 

CARA ALEXANDER, al., 
Plaintiffs, 
FEDERAL BUREAU INVESTIGATION, al., 
Defendants. 
))) 

JOHN NilCHAEL GR.Th1LEY, al., Plaintiffs, .......... 
Civil Action Nos. 96-2123/97-1288 (RCL) 
FEDERAL BUREAU 
INVESTIGATION, al., 

Defendants. 

PLEASE TAKE NOTICE that Plaintiffs, counsel, and pursuant Rules 26, 30(b)(6), and the Federal Rules Civil Procedure, will take the deposition The United States Department Justice the offices Judicial Watch Inc., 501 School Street, S.W., Suite 725, Washington, D.C. beginning June 11, 1999 8:00 a.m. The deposition shall continue from day day until completed, excluding Saturdays, Sundays, and holidays, and shall take place before notary public some other officer authorized administer oaths and record testimony pursuant Rule the Federal Rules Civil Procedure. The Plaintiffs require testimony 

about all matters which refer to, relate to, form the underlying factual basis for the finding the Certification the United States Department Justice, dated and signed Eva Plaza, Deputy Assistant Attorney General, February 18, 1997, stating that the Plaintiffs' invasion privacy claims against David Craig Livingstone, Anthony Marceca, and Bernard Nussbaum arise from conduct performed them within the scope their fonner employment the White House. copy said Certification hereto attached Exhibit The deposition shall recorded videotape. The Deponent required bring the documents described Attachment subpoena served relation this notice, copy which said subpoena hereto attached Exhibit 
JUDICIAL WATCH, INC. 

}ttomeys for Plaintiffs 

EXHIBIT 

CARA LESLIE ALEXANDER, al. 
)Plaintiffs, civil Action No. FEDERAL BUREAU INVESTIGATION, 6-21.23 (RCL) EXECUTIVE OFFICE THE PRESIDENT,
HILLARY RODHAM CLINTON, BERNARD NUSSBAUM, DAVID CRAIG LIVINGSTONE, ANTHONY MARCECA, 
)Defendants. Eva Plaza, Deputy Assistant Attorney General, civil 
Division, United states Department Justice acting pursuant 
the pro-Visions tJ. s.c  2079 (d) (2), arid Virtue the authori vested C.F.R.  15.3 (1996), and appendix, hereby certify that have read the complaint this action. the basis the information now available with respect the allegations therein, find that the invasion privacy claim asserted against individual defendants Bernard Nussbaum, David Craig Livingstone, and Anthony Marceca this lawsuit arises from conduct performed them 
within the scope their former 
federal employment the.White House. 
Date: February 18, 1997 

EVA Deputy 
civil 

EXHIBIT2 

Issued the 
UNITED STATES DISTRICT COURT 

COLUMBIADISTRICT 
Cara Leslie exander al., Plaintiff, 
SUBPOENA CIVIL CASE 

[Rj YOU ARE COMMANDED produce and permit inspectrotand copying the following documents objects the place, 
date, and time specified below (list documents objects): designated Attachment 
4.J'
-vJ..a. /lzUti.t? dtJ1uSJ)N.
d)iu  ,,4_ 1-t) 

ATTACHMENT 

NOTE Rule 30(b)(6) the Federal Rules Civil Procedure requires that Department designate one more its officers employees testify its behalf about all matters relevant the basis the Certification the United States Department Justice, dated and 
signed Eva Plaza, Deputy Assistant Attorney General February 18, 1997, stating that the Plaintiffs' invasion privacy claims against David Craig Livingstone, Anthony Marceca and Bernard Nussbaum arise from conduct performed them within the scope their former employment the White House. one more officer employee designated., the Department required, for each individual designated, set forth the matters which such designated individual individuals shall testify. 
The word "document" shall mean any written graphic matter other means preserving thought expression, and all tangible things from which information can processed transcribed, including, but not limited to, correspondence, memoranda, notes, messages, letters, telegrams, teletypedmessages, bulletins, diaries, chronological data, minutes, books, reports, charts, ledgers, invoices, worksheets, receipts, computer recordations (including, but not limited to, file listings), printouts, schedules, affidavits, contracts, transcripts, surveys, graphic representations any kind, photographs, graphs, microfilm, video tapes, tape recordings, motion pictures other film. 
The word "involving" means including, summarizing, recording, containing, listing, pertaining, concerning, comprising, consisting, addressing, describing, mentioning, referring, relating to, reflecting. producing documents requested herein, you shall produce originals documents full, without abridgment, abbreviation expurgation any sort. 
All documents shall segregated accordance with the numbered and lettered paragraphs and subparagraphs herein. 
All documents requested herein which you withhold production the basis claim privilege statutory authority shall listed accordance with the procedure described instruction above and shall identified by: author(s); addressee(s); date; type document; subject matter; number pages; number attachments appendices; indicated blind copies; all persons whom shown explained; present custodian; and 

factual legal basis for claimed privilege, specific statutory authority which provides the claimed base for non-production. 
All documents requested herein which have been destroyed, placed beyond your control, otherwise disposed shall identified by: author(s); adclressee(s); date; type document; subject matter; number pages; number attachments appendices; 

indicated blind copies; all persons whom distributed, shown explained; date destruction other disposition; reason for destruction other disposition; person authorizing destruction other disposition; person destroying otherwise disposing document; and not destroyed, person possession document otherwise disposed of. 

SCHEDULE DOCUMENTS Any and all records, correspondence, notes, communications other documents and things which refer to, relate to, form the underlying factual basis for the following finding Eva Plaza, Deputy Assistant Attorney General, Civil Division, United States Department Justice, made Certification dated and signed the said Eva Plaza February 18, 1997: the basis the infonnation now available with respect the allegations therein [i.e., the Plaintiffs' complaint case no. 96-2123], find that the invasion privacy claim asserted against individual defendants Bernard Nussbaum, David Craig Livingstone, and Anthony Marceca this lawsuit arises from conduct performed them within the scope their fonner federal employment the White House. true and correct copy the said Certification hereto attached. 
JUDICIAL WATCH, INC. 

Attorneys for Plaintiffs 
CA.RA  LESLIE  ALEXANDER,  al.  
Plaintiffs,  
FEDERAL BUREAU INVESTIGATION, EXECUTIVE OFFICE THE PRESIDENT, HILLARY RODHAM CLINTON, BERNARD NUSSBAUM, DAVID CRAIG LIVINGSTONE .ANTHONY MARCECA,  Civil Action No. 96-23-23 (RCL)  
Defendants.  

CERTIFICATION Ev'a Plaza, Deputy Assistant Attorney General, civil Division United States Department Justice, acting pursuant the provisions u.s.c.  2679(d) (2), and virtue the author ity vested C.F.R.  15.3 (1996), and appendix, hereby certify that have read the complaint this action. the basis the information now available with respect the allegations therein, find that the invasion privacy claim asserted against individual defendants Bernard Nussbawn, David Craig Livingstone, and Anthony Marceca this lawsuit arises from conduct performed them within the scope their former federal employment the White House. 
Date: February 18, 1997 

CERTIFICATE SERVICE hereby certify that the 7th day June, 1999, true and correct the foregoing Notice Rule 30(b)(6) Deposition, together with true and correct copy Subpoena the United States Depaitment Justice, was served hand upon the following: 
Attorneys for Defendants Federal Bureau Investigation and Executive Office 
the President: 
James Gilligan, Esq. 
Elizabeth Shapiro, Esq. 
Julia Fayngold Covey, Esq. 

U.S. DEPARTMENT JUSTICE .O. Box 883 Washington, 20044 
Attorneys for Defendant Hillary Rodham Clinton: 
David Kendall, Esq. 
Paul Gaffney, Esq. 
Marcie Ziegler, Esq. 
WlLLIAMS CONNOLLY 
725 12th Street, N.W. 
Washington, 20005



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