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State coordination denial rule 01188

State coordination denial rule 01188

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Category:Clintons

Number of Pages:17

Date Created:September 5, 2015

Date Uploaded to the Library:October 08, 2015

Tags:rule, 01188, coordination, denial, Prince, guantanamo, orfanedes, Cases, Civil, motion, Hillary Clinton, September, filed, State Department, FBI, document, DOJ, FOIA, Supreme Court, department, robert, district, court, Judge


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Case 1:15-mc-01188 Document Filed 10/06/15 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA RE:
U.S. DEPARTMENT STATE FOIA
LITIGATION REGARDING EMAILS CERTAIN FORMER OFFICIALS
____________________________________)
Misc. No. 15-1188
RESPONDENT JUDICIAL WATCH, INC. MOTION
FOR RULE SANCTIONS
Respondent Judicial Watch, Inc. Judicial Watch counsel and pursuant Rule the Federal Rules Civil Procedure Rule respectfully requests that the U.S.
Department State State Department sanctioned for filing meritless action entirely
unwarranted existing law. grounds therefor, Judicial Watch states follows:
STATEMENT POINTS AND AUTHORITIES
Rule sanctions may imposed where party files pleading, motion other
paper with the court for improper purpose, that unwarranted existing law, that
lacking evidentiary support. Fed. Civ. 11(b)(1)-(3). [T]he district court accorded
wide discretion determining whether sanctions are appropriate. Gomez Aragon, 705
Supp. 21, n.2 (D.D.C. 2010) (quoting Westmoreland CBS, Inc., 770 F.2d 1168, 1174
(D.C. Cir. 1985)). Rule sanctions are extreme punishment for filing pleadings that
frustrate judicial proceedings. Brown FBI, 873 Supp. 388, 408 (D.D.C. 2012) (quoting
Wasserman Rodacker, 2007 U.S. Dist. LEXIS 51873 *24 (D.D.C. July 18, 2007)). The
test [for sanctions] under Rule objective one: that is, whether reasonable inquiry
would have revealed that there was basis law fact for the asserted claim. Sharp
Rosa Mexicano, D.C., LLC, 496 Supp. 93, 100 (D.D.C. 2007) (quoting Reynolds U.S.
Case 1:15-mc-01188 Document Filed 10/06/15 Page
Capitol Police Bd., 357 Supp. 19, (D.D.C. 2004)). Further, Rule includes safe
harbor provision which requires that the motion must first served the non-movant allow opportunity withdraw the challenged assertion. Fed. Civ. 11(c)(2). This procedural
rule must satisfied before the Court considers the substantive aspects plaintiff motion.
Brown, 873 Supp. 408. September 2015, the State Department initiated this lawsuit, purportedly miscellaneous action, seeking have the Chief Judge order many District Judges
transfer more than Freedom Information Act FOIA lawsuits, including least
lawsuits filed Judicial Watch, coordinating judge least for period time. See
United States Department State Motion for Designation Coordinating Judge and
Memorandum Support 15. Judicial Watch recognizes the extraordinary nature Rule
relief, but respectfully submits that the State Department extraordinary lawsuit one the rare
cases that warrants such relief.
The State Department lawsuit suffers from numerous fatal flaws, not the least
which are the State Department failure identify any basis for the Court subject matter
jurisdiction demonstrate why the relief the agency seeks properly the subject
miscellaneous action. The State Department also has failed identify any basis for the Court
assert personal jurisdiction over respondents the FOIA requestors who bought the more than
lawsuits question. There plainly has been service process, and mere notice action substitute for proper service process. See, e.g., Omni Capital Int Ltd. Rudolf Wolff
Co., 484 U.S. 97, 104 (1987); see also Ibiza Business Ltd. United States, 2010 U.S. Dist.
LEXIS 70903 (D.D.C. July 2010) (Lamberth, J.) (denying motion for default judgment
miscellaneous action due insufficiency service process). The State Department also
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Case 1:15-mc-01188 Document Filed 10/06/15 Page
failed join least indispensable parties, namely the district judges against whom they seek
relief.
Most fatal all, however, the complete absence any substantive legal basis
for the State Department claim. beyond peradventure that one district judge cannot order
another district judge take action case pending before that judge. Klayman KollarKotelly, 2013 U.S. App. LEXIS 10148 (D.C. Cir. May 20, 2013), reh denied 2013 U.S. App.
LEXIS 16769 (D.C. Cir. Aug. 12, 2013), reh banc denied 2013 U.S. App. LEXIS 16770
(D.C. Cir. Aug. 12, 2013); see also Celotex Corp. Edwards, 514 U.S. 300, 313 (1995); Jones Supreme Court the United States, 405 Fed. Appx. 508 (D.C. Cir. 2010) (per curium);
Prentice United States District Court, 307 Fed. Appx. 460 (D.C. Cir. 2008) (per curium);
Adams United States District Court, 2014 U.S. Dist. LEXIS 151044 (D.D.C. Oct. 23, 2014)
(Berman Jackson, J.); Mason Kahn 2008 U.S. Dist. LEXIS 50258 (D.D.C. June 30,
2008). Not only does district judge lack such power, but the Court lacks subject matter
jurisdiction consider claim that does. Klayman, 2013 U.S. App. LEXIS 10148 *2. Klayman, the plaintiff filed action seeking, among other relief, have one
district judge issue injunction against another district judge. Then Assistant United States
Attorney Rudolph Contreras now Judge Contreras argued Judge Leon that had
authority issue order Judge Kollar-Kotelly: This Court lacks jurisdiction order
District Judge take judicial action cases pending before that judge. Defendants
Memorandum Support Motion Dismiss Klayman Kollar-Kotelly, al., Case No.
11-1775 (RJL) (D.D.C. Dec. 2011) (ECF No. 11). Judge Leon agreed. Klayman KollarKotelly, 892 Supp.2d 261 (D.D.C. 2012). did the appellate court, which summarily
affirmed. Klayman, 2013 U.S. App. LEXIS 10148 *1. The relief the State Department seeks
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Case 1:15-mc-01188 Document Filed 10/06/15 Page
that district judge order many other district judges transfer more than FOIA
lawsuits single coordinating judge unwarranted any existing law. Fed.R.Civ.P.
11(b)(2). Nor warranted nonfrivolous argument for extending, modifying, reversing
existing law for establishing new law. Id.
The Guantanamo Bay detainee cases heard this Court following the United
State Supreme Court decision Boumediene Bush, 553 U.S. 723 (2008) are inapposite.
Regarding those cases, the Court resolved Executive Session designate single judge
coordinate and manage some 249 petitions for writs habeas corpus filed Guantanamo Bay
detainees. See Order 1-2, Guantanamo Bay Detainee Litig., Misc. No. 08-422 (TFH)
(D.D.C. July 2008) (ECF No. 1); see also Resolution the Executive Session, U.S. District
Court for the District Columbia (July 2008), attached Exhibit The Court Executive
Session resolution was administrative act, not judicial act. district judge was ordered
another district judge anything. Two district judges opted out the coordination
process, fact the State Department readily admits. See Motion 10, n.7. The fact that two
judges could opt out the coordination process established the Court for the
Guantanamo Bay detainee litigation further confirms that the process was consensual,
voluntary process which the participating judges agreed, not court-ordered relief.
Local Civil Rules 40.5(c) and 40.6(a), both which the State Department cites,
also not provide legal basis for the relief the State Department seeks. Both rules make clear
that the assignment and transfer processes they establish are effectuated only with the consent
the judges involved. Again, district judge ordered another district judge anything.
Before the State Department initiated its miscellaneous action September
2015, Judicial Watch asked identify the basis for its action. could not so. The State
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Case 1:15-mc-01188 Document Filed 10/06/15 Page
Department counsel wrote email earlier that same day, There precise rule that
provides for what are seeking. Since will filing notice with the motion attached
each case, all judges and plaintiffs will receive notice, and the Court will able
respond sees fit. See Exhibit Counsel continued, will, course, follow directions
from the Court turns out miscellaneous action inappropriate. Id. short, the State
Department knew its action had basis law certainly none that could identify but
nonetheless filed the action despite the time and expense Judicial Watch would forced incur result.
That time and expense has already been substantial and will only continue
increase. result the State Department initiation its miscellaneous action, Judicial
Watch has had divert its scarce time and not-for-profit resources away from other matters
that they might expended the State Department miscellaneous action. addition, the
State Department has filed (or declared its intention file) motions stay each the
underlying FOIA lawsuits brought Judicial Watch, pending the outcome the agency
miscellaneous action. Obviously, responding many motions stay will require (and
already has required) the expenditure substantial resources. One response due September
2015. See Minute Order, Judicial Watch, Inc. U.S. Dep States, Case No. 13-1363 (EGS)
(D. District Columbia) (Sep. 2015). hearing the State Department motion stay
that particular matter has been set for September 16, 2015. Minute Order, Judicial Watch, Inc.
U.S. Dep States, Case No. 13-1363 (EGS) (D. District Columbia) (Sep. 2015). None
these expenditures would have been necessary were not for the State Department clearly
baseless miscellaneous action. The State Department should required make Judicial Watch
whole paying Judicial Watch reasonable attorney fees and any associated costs.
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Case 1:15-mc-01188 Document Filed 10/06/15 Page
10. copy this motion was served counsel for the State Department, and all
other counsel record, least days before the motion was filed. the date filing, the
State Department has failed refused withdraw its baseless action.
WHEREFORE, Judicial Watch respectfully requests that Rule sanctions entered
against the State Department and that Judicial Watch awarded reasonable attorney fees and
costs sufficient make whole not only for the time and expense was unnecessarily forced
incur this matter, but also the underlying FOIA lawsuits affected the State Department
baseless action.
Dated: September 2015
Respectfully submitted,
/s/ Paul Orfanedes
Paul Orfanedes
D.C. Bar No. 429716
JUDICIAL WATCH, INC.
425 Third Street SW, Suite 800
Washington, D.C. 20025
Tel: (202) 646-5172
Fax: (202) 646-5199
Email: porfanedes@judicialwatch.org
Counsel for Judicial Watch, Inc.
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Case 1:15-mc-01188 Document Filed 10/06/15 Page
CERTIFICATE SERVICE hereby certify that September 2015 true and correct copy the foregoing
RESPONDENT JUDICIAL WATCH, INC. MOTION FOR RULE SANCTIONS was
served the following email and first class U.S. mail, postage prepaid:
Counsel for U.S. Dep State:
Elizabeth Shapiro
Robert Prince
U.S. DEPARTMENT JUSTICE
P.O. Box 883
Washington, 20044
Email: Elizabeth.Shapiro@usdoj.gov
Email: robert.prince@usdoj.gov
Counsel for Citizens United, Inc.:
Theodore Olson
Matthew McGill
GIBSON, DUNN CRUTCHER, L.L.P.
1050 Connecticut Avenue,
Washington, 20036-5306
Email: tolson@gibsondunn.com
Email: mmcgill@gibsondunn.com
Counsel for Jason Leopold:
Ryan Steven James
LAW OFFICE RYAN JAMES
5208 Capricorn Loop
Killeen, 76542
Email: rsjameslaw@gmail.com
Jeffrey Louis Light
LAW OFFICES JEFFREY LIGHT
1712 Eye Street,
Suite 915
Washington, 20006
Email: jeffrey@lawofficeofjeffreylight.com
/s/ Paul Orfanedes
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Case 1:15-mc-01188 Document 40-1 Filed 10/06/15 Page
EXHIBIT
RESPONDENT JUDICIAL WATCH, INC.S MOTION
FOR RULE SANCTIONS
Case 1:15-mc-01188 Document 40-1 Filed 10/06/15 Page
UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
RESOLUTION THE EXECUTIVE SESSION
July 1,2008
WHEREAS, some 249 cases pertaining more than 643 individual detainees who hav,e
been are being held Guantanamo Bay are pending with this Court (the Guantanamo Bay
cases); and
WHEREAS, expected that several dozen more new Guantanamo Bay cases
could filed with this Court the near future; and
WHEREAS, the interests the litigants, well the public, the Court, and
counsel, provide the most expeditious and efficient handling these cases; HEREBY RESOLVED the Executive Session the United States District
Court for the District Columbia that:
Senior Judge Thomas Hogan designated coordinate and manage
proceedings all Guantanamo Bay cases that these cases can addressed
expeditiously possible required the Supreme Court Boumediene
Bush. No. 06-1195, slip op. (U.S. June 12,2008).
All Guantanamo Bay cases, both those which have been filed and those which
may filed the future, are transferred the Judge whOln they an~
assigned, pursuant LCvR 40.6(a) and 40.5(e), Senior Judge Thomas
Hogan for coordination and management. The transferring Judge will retain. the:
case for all other purposes.
Senior Judge Thomas Hogan will identify and delineate both procedural a.nd
Case 1:15-mc-01188 Document 40-1 Filed 10/06/15 Page
substantive issues that are common all some these cases. the extent possible, Senior Judge Thomas Hogan will rule procedural
issues that are common these cases. substantive issues, Senior Judge Thomas Hogan will confer with those
Judges whose cases raise common substantive issues. the extent possibk, and
provided that consent given the transferring Judge, one the transferring
Judges Senior Judge Thomas Hogan will address specified substantive issues
that are common the Guantanamo Bay cases. Judge who does not agrt:{~
with any substantive decision reached this manner may resolve the issue his her own cases she deems appropriate.
LCvR 40.6(a) provides that: Judge, upon written advice the Calendar
Committee, may transfer directly all part any case the Judges docket any consenting
Judge (emphasis added).
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Case 1:15-mc-01188 Document 40-2 Filed 10/06/15 Page
EXHIBIT
RESPONDENT JUDICIAL WATCH, INC.S MOTION
FOR RULE SANCTIONS
Case 1:15-mc-01188 Document 40-2 Filed 10/06/15 Page
Paul Orfanedes
From:
Sent:
To:
Subject:
Attachments:
Prince, Robert (CIV) Robert.Prince@usdoj.gov>
Wednesday, September 02, 2015 11:01
Paul Orfanedes
RE: Seeking Judicial Watchs Position Motion Designate Coordinating Judge and
Corresponding Stay Motions cases State Department Dept State ForA Coordination Motion Proposed Order vOl.docx
Paul,
The plan seek coordinate 30+ cases specific list will included the motion).
What were proposing actually very simple. plan leave the involved questions the coordinating judge, whom
assume would seek input from the parties. Ive attached the proposed order and, you can see, simply asks for the
designation coordinating judge resolve and manage issues law, fact, and procedure arising the
Coordinated Cases from the search and production responsive records within the recently provided documents
(recently provided documents defined the order). That the relief were requesting. the email sent yesterday morning, gave some specific examples what those issues would include (scheduling
searches the recently provided documents, requests for information and discovery about those documents, and
requests for orders relating preservation the motion explains why the Court and the parties would benefit from
coordination these issues that have arisen multiple cases the district. But are not specifically asking the Court manage those issues particular way. the motion were addressing here does not seem particularly involved.
Given that there are other plaintiffs (all but one whom have responded with position statement include the
motion), not feasible engage detailed discussions about how these cases will proceed once coordinated. This
one the reasons that our motion contemplates that the coordinating judge resolve the detailed, involved questions,
with input from all parties. Weve described the relief are seeking; discussing questions not addressed the motion
are not necessary meaningfully confer.
Regarding the use miscellaneous action, there precise rule that provides for what are seeking, which not
traditional consolidation. Since will filing notice with the motion attached each case, all judges and
plaintiffs will receive notice, and the Court will able respond sees fit. will, course, follow direction from
the Court turns out miscellaneous action inappropriate.
Rob
Robert Prince
Trial Attorney
U.s. Department Justice, Civil Division
Federal Programs Branch
(202) 305-3654
The information this transmittal (including attachments, any) intended only for the recipient(s) listed above and contains
information thot confidential, Any review, use~ disclosure, distribution, copying this transmittal prohibited except
behalf the intended recipient. you have received this transmittal error, please notify immediately and destroy all copies
the transmittal. Your cooperation appreciated.
Case 1:15-mc-01188 Document 40-2 Filed 10/06/15 Page
From: Paul Orfanedes [mailto:POrfanedes@JUDICIALWATCH.ORG]
Sent: Tuesday, September 01, 2015 9:26
To: Prince, Robert (CIV)
Subject: RE: Seeking Judicial Watchs Position Motion Designate Coordinating Judge and Corresponding Stay
Motions cases State Department
Robert: familiar with miscellaneous actions relating discovery subpoenas, administrative subpoenas, judgment
enforcement, registration foreign judgments, etc. Frankly, Ive never heard party ongoing lawsuit opening
miscellaneous action the same court move for the designation coordinating judge. order better
understand what you propose, can you explain preliminary matter, how you settled this particular
procedure? What rule statute are you relying on? recall that coordinating judge was designated for the
Guantanamo Bay detainee cases} but was understanding that was done administratively the court think
was resolution the Executive Session not party motion. Also, which other cases you propose include this miscellaneous action? All so? indicated previously, what you propose involved question and its
going take some time for even understand it. sure well have more question, but dont think can say
weve met and conferred unless understand better.
Elizabeth Shapiro told Judge Contreras July (lAnd there are approximately various stages and various
forms. There are difficulties terms how they would consolidated, and since some them are different claims,
there are different parties, there are different stages. the mechanics that have eluded date, but havent
given the idea. asked her after the hearing DOJ wanted try talk about it. There was real response,
and never heard anything further until your email this morning. Not only not understand what you are
proposing, but dont understand why there seems sudden rush file something.
PJO
From: Prince, Robert (CIV) [mailto:Robert.Prince@usdoj.gov]
Sent: Tuesday, September 01, 2,015 3:44
To: Paul Orfanedes; Ramona Cotca; Michael Bekesha; Jason Aldrich; Lauren Burke; Chris Fedeli
Cc: Elliott, Stephen (CIV); Edney, Marsha (aV); Wechsler, Peter (CIV); Todd, James (CIV); Thurston, Robin (CIV);
Carmichael, Andrew (CIV); Anderson, Caroline (CIV); Olson, Lisa (aV); Riess, Daniel (CIV)
Subject: RE: Seeking Judicial Watchs POSition Motion DeSignate Coordinating Judge and Corresponding Stay
Motions cases State Department
Paul, can put your position down {{has not yet tak~n position (or, you prefer, ((needs see motion before taking
position
From: Paul Orfanedes [mailto:POrfanedes@JUDICIALWATCH.ORGJ
Sent: Tuesday, September 01, 2015 10:43
To: Prince, Robert (CIV); Ramona Cotca; Michael Bekesha; Jason Aldrich; Lauren Burke; Chris Fedeli
Cc: Elliott, Stephen (CIV); Edney, Marsha (CIV); Wechsler, Peter (CIV); Todd James (ClV); Thurston, Robin (CIV);
Carmichael, Andrew (CIV); Anderson, Caroline (CIV); Olson, Lisa (OV); Riess, Daniel (CIV)
Subject: RE: Seeking Judicial Watchs Position Motion Designate Coordinating Judge and Corresponding Stay
Motions cases State Department
Robert:
Well give some thought. wont decide your 4:00 p.m. deadline. this point, its more involved question
than that.
Case 1:15-mc-01188 Document 40-2 Filed 10/06/15 Page
PJO
from: Prince, Robert (CIV) [mailto:Robert.Prince@usdoLgov]
Sent: Tuesday, September 01, 2015 9:38
To: Ramona Cotca; Paul Orfanedes; Michael Bekesha; Jason Aldrich; Lauren Burke; Chris Fedeli
Cc: Elliott, Stephen (CIV); Edney, Marsha (CIV); Wechsler, Peter (CIV); Todd, James (CIV); Thurston, Robin (CIV);
Carmichael, Andrew (CIV); Anderson, Caroline (CIV); Olson, Lisa (CIV); Riess, Daniel (CIV)
Subject: Seeking Judicial Watchs Position Motion Designate Coordinating Judge and Corresponding Stay Motions cases State Department
Dear counsel,
This email reference the following cases:
Judicial Watch
Judicial Watch
Judicial Watch
Judicial Watch
Judicial Watch
Judicial Watch
Judicial Watch
Judicial Watch
Judicial Watch
Judicial Watch
Judicial Watch
Judicial Watch
Judicial Watch
Judicial Watch
Judicial Watch
Judicial Watch
U.S.
U.S.
U.S.
U.S.
U.S.
u.s.
U.S.
U.S.
U.S.
U.S.
U.S.
U.S.
U.S.
U.S.
U.S.
U.S.
Dept State, aI., Civil No. 12-893 (JDB)
Dept Defense, ai, Civil No. 14-812 (KBJ)
Dept State, Civil No. 12-2034 (RW)
Dept State, Civil No. 13-1363 (EGS)
Dept State, Civil No. 13-772 (CKK)
Dept State, Civil No. 14-1242 (RCL)
Dept State, Civil No. 14-1511 (ABJ)
Dept State, Civil No. 15-1128 (EGS)
Dept State, Civil No. 15-321 (CKK)
Dept State, Civil No. 15-646 (CKK)
Dept State, Civil No. 15-684 (BAH)
Dept State, Civil No. 15-687 (JEB)
Dept State, Civil No. 15-688 (RC)
Dept State, Civil No. 15-689 (RDM)
Dept State, Civil No, 15-691 (APM)
Dept State, Civil No. 15-692 (APM) seek your position two motions. First the Department State intends file motion with the Chief Judge seeking
deSignation coordinating judge for resolution and management common issues law, fact, and procedure across
numerous FOIA suits, including these cases, that implicate the search and proquction doc;uments that were provided the Department former Secretary State Hillary Clinton and, the extent applicable, certain other former
employees (Cheryl Mills, Huma Abedln, Jacob Sullivan, and Phillippe Reines). each case, the transferring judge would
retain the case for all other purposes, including searches for responsive records other than the provided
documents. The motion envisions coordination common issues such the scheduling searches the recently
provided documents, requests for information and discovery about those documents, and requests for orders relating
preservation.
This coordination motion will filed miscellaneous action. Once filed, the Department will file notice each the above-listed cases, along with copy the motion itself.
Second, the Department will filing motion each the above-listed cases seeking stay those portions each
case addressing the documents provided the Department former Secretary Clinton and the other former
employees until the coordination motion decided, and, granted, until the coordinating judge issues order
determining how proceed the cases listed that motion. The stay sought would not affect those portions the
cases that deal with the search and production other documents.
Could you please let know your position with respect each above-listed case today?
Best,
Case 1:15-mc-01188 Document 40-2 Filed 10/06/15 Page
Rob
Robert Prince
Trial Attorney
U.S. Department Justice, Civil Division
Federal Programs Branch
(202) 305-3654
The information this transmittal (including attachments, any) intended only for the recipient{s) listed above and contains
information that confidential. Any review, use, disclosure, distribution, copying this transmittal prohibited except
behalf the intended recipient. you have received this transmittal error, please notify immediately and destroy all copies
the transmittal. Your cooperation appreciated.
Case 1:15-mc-01188 Document 40-3 Filed 10/06/15 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA RE:
U.S. DEPARTMENT STATE FOIA
LITIGATION REGARDING EMAILS CERTAIN FORMER OFFICIALS
____________________________________)
Misc. No. 15-1188
[PROPOSED] ORDER GRANTING RESPONDENT JUDICIAL WATCH, INC.
MOTION FOR RULE SANCTIONS
Upon consideration Respondent Judicial Watch, Inc. Motion for Rule Sanctions,
any opposition thereto, and the entire record herein, hereby ORDERED that:
The motion GRANTED; and
The U.S. Department State shall and hereby required pay reasonable
attorney fees and costs incurred Judicial Watch, Inc., amount determined upon
submission Judicial Watch, Inc. verified itemization its attorney fees and costs.
Dated:
_____________________________
U.S. District Judge
Case 1:15-mc-01188 Document 40-3 Filed 10/06/15 Page
Copies to:
Paul Orfanedes
Michael Bekesha
Ramona Cotca
JUDICIAL WATCH, INC.
425 Third Street, SW, Suite 800
Washington, 20024
Elizabeth Shapiro
Robert Prince
U.S. DEPARTMENT JUSTICE
P.O. Box 883
Washington, 20044
Theodore Olson
Matthew McGill
GIBSON, DUNN CRUTCHER, L.L.P.
1050 Connecticut Avenue,
Washington, 20036-5306
Ryan Steven James
LAW OFFICE RYAN JAMES
5208 Capricorn Loop
Killeen, 76542
Jeffrey Louis Light
LAW OFFICES JEFFREY LIGHT
1712 Eye Street,
Suite 915
Washington, 20006
and
All other counsel record
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