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Judicial Watch • JW v. State court transcript 01363

JW v. State court transcript 01363

JW v. State court transcript 01363

Page 1: JW v. State court transcript 01363

Category:Clintons

Number of Pages:36

Date Created:August 4, 2015

Date Uploaded to the Library:August 05, 2015

Tags:Alright, wechsler, BlackBerries, Transcript, honor, Bekesha, 01363, search, Plaintiffs, Abedin, Mills, government, clinton, State Department, plaintiff, records, FOIA, department, court, Judge


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THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
Plaintiff,
vs.
UNITED STATES DEPARTMENT STATE, No.
13-CV-1363 (EGS)
Washington,
July 31, 2015
11:22 a.m.
Defendant.
_________________________/
TRANSCRIPT STATUS HEARING
BEFORE THE HONORABLE EMMET SULLIVAN
UNITED STATES DISTRICT JUDGE
APPEARANCES:
For the Plaintiff:
MICHAEL BEKESHA, ATTORNEY
Judicial Watch, Inc.
425 Third Street, SW, Suite 800
Washington, 20024
202-646-5172
For the Defendant:
PETER WECHSLER, TRIAL ATTORNEY
U.S. Department Justice
Federal Programs Branch Civil Div. Massachusetts Avenue,
Washington, 20530
202-514-2705
Court Reporter:
JEFF HOOK, CSR, RPR
Official Court Reporter
U.S. Courthouse, Room 4700-C
333 Constitution Avenue,
Washington, 20001
202-354-3373
Proceedings recorded mechanical stenography; transcript
produced computer-aided transcription.
002
COURTROOM DEPUTY:
Calling civil action 13-1363,
Judicial Watch, Inc. versus Department State.
counsel please approach the lecturn and identify themselves
for the record.
MR. BEKESHA:
Would
Good morning, your Honor.
Bekesha behalf Judicial Watch.
Michael
Orfanedes and Tom Fitton.
THE COURT:
Along with Paul
Alright, good morning.
MR. WECHSLER:
Good morning, your Honor.
Peter
Wechsler from the Department Justice representing the State
Department.
Berman.
Along with are Elizabeth Shapiro and Marcia
THE COURT:
Alright, good morning.
There was
document filed last evening that seems suggest that
whatever disputes there were, theyve been resolved, that
correct?
Have you seen that?
MR. BEKESHA:
THE COURT:
Yes, have, your Honor.
Why dont you come forward. you
agree?
MR. BEKESHA:
Thank you, your Honor.
With respect what was filed yesterday, when filed the joint status
report July 1st, there were three issues that were
involved:
pages e-mails; when the State Department would search
When the State Department would search the 55,000
003
e-mails provided them Ms. Abedin and Ms. Mills; and then
the third issue was whether those additional searches was
sufficient satisfy the standards FOIA.
it, there were three issues contention.
State changed their position.
concerns, the first two issues, but one issue does remain.
THE COURT: when filed
The Department
They satisfied now two our
Alright.
And the remaining issue
which one?
MR. BEKESHA:
Whether the State Department will
conduct additional searches, because the searches that have
been conducted date are incomplete.
THE COURT:
Okay.
Does not the last paragraph
the document, document 17, address that issue, that the
Department will also conduct revised search the records
system that were initially searched?
the third issue?
MR. BEKESHA:
Does that not resolve does not, your Honor.
What that
would would searching the same systems records with
these search terms.
Court whether not that search sufficient because they
are incomplete systems records.
known for the past three years two years, that those
systems records are incomplete.
her aides used non State Department e-mail addresses
conduct official business.
Our concern and the issue before the
And the State Department has
Mrs. Clinton, several
Those e-mails will not necessarily
004 right the system records they search.
THE COURT: what you believe that the
Government should doing then address the third issue
that you contend unresolved?
MR. BEKESHA: think what had originally asked
for was some information that had better sense what
systems records are out there. computer equipment, devices within the State Department
that may contain this information.
But for example, there may Mrs. Clinton used
desktop BlackBerry while the State Department, when
she left that may have went storage.
from the internet, may sitting basement with all
her e-mails it.
may backups these devices that could searched.
may servers that may able searched.
know what all the possibilities are because the State
Department unwilling work with and provide this
very limited, very important information. figure out where else the State Department can look
within the State Department that they satisfy their
obligations under FOIA. was unplugged
Those records could searched.
There
There just dont
All were trying mean, the other possibility is, you know, not
all clear and theres evidence that all records that the
55,000 pages all records that Mrs. Clinton has. Wednesday held hearing, asked the head the FOIA
Judge Leon
005
department for the State Department testify.
that hearing Mr. Hackett, whos head the State Departments
FOIA, said that does not know all the work related
e-mails have been turned over.
Mrs. Clinton, Ms. Abedin and Ms. Mills.
transcript.
didnt get done until 9:00 a.m. this morning.
copies with me, and happy add onto the record after
were here.
And during
And said that about have copies the was two hour hearing the court reporter brought can point the Court few places where the
State Department admits that does not know whether all
the records that have been returned that were taken from
the State Department have actually been returned.
THE COURT:
Are addressing the same issue,
colleague and Judge Leon?
MR. BEKESHA:
Judge Leons concern more about the
processing because its taken place over four year period
time.
searches does not appear issue that case.
case primarily about the searching the 55,000 pages
which the State Department has done here well other
records.
obligated search find responsive records. fact, whether not there are other additional
That
But nothing about where else the State Department
THE COURT: want make sure understand what
youre saying.
Government say that searched its own files, should
Youre saying that its not enough for the
006
searching something else.
MR. BEKESHA:
THE COURT:
And what the something else?
Well, the something -Are you satisfied with the Government
saying searched its own files for the relevant time period,
and that will understand this status report, will
research some its own files?
the Government should doing addition searching its
own files?
MR. BEKESHA:
What that you contend
Well, like when they searched the
first time around 2013, theyre searching incomplete
systems records.
some records dont exist, and they dont want and search
where records could exist.
little bit easier because when gets into electronic records can confusing.
you know, put paper box, and you know that you have
federal record here and its not that box and that could several hundred pages havent been put that box.
Government cant just search that box and say, Ive done
reasonable search, because they know that the records that
theyre looking for arent that box, theyre somewhere
else.
where
Theyre searching places where they know for example, Ill make
But you are storing records box,
The
And thats what have here, have instance
THE COURT: you seem suggest that the
Government knows that there are records elsewhere that they
007
arent searching, and theyre intentionally not searching
those records elsewhere?
MR. BEKESHA:
Thats correct, your Honor.
And
think the evidence shows that.
years used e-mail address that was not state.gov.
she sent e-mails people the State Department, the
State Department knew that her records would not the
database they searched.
they told they searched her records.
Secretary Clinton for her four
She said
And they didnt tell that when
They didnt tell
that before closed the case, they didnt tell that after closed the case.
filed the motion reopen the case. read about the news, and they had said, you know, this incomplete record, probably wouldnt have closed the case that point.
would have had to, you know, continue discussions and figure
out what the State Department could correct that issue. they didnt tell first, and now they continue not
tell where else the records may exist. said old desktop.
server.
may have and that she used.
possible places that records could find, and the Agency has obligation conduct these searches because they know the
system records that they are searching incomplete.
They could exist
They could exist backup
And they could exist this server that Mrs. Clinton
THE COURT:
And all these places are
Alright, thank you.
Let hear from
008
Government counsel.
Good morning.
MR. WECHSLER:
Good morning, your Honor. your
Honor mentioned, the joint status report that was filed
Plaintiff raised three issues:
55,000 pages; two, any e-mails Abedin Mills that
were personal e-mail account; and three, assurances that
the searches that had been conducted other existing
Department documents were satisfactory.
the following.
One, the Clinton e-mails, the the Department did
They agreed search terms for the Clinton
e-mails.
pages the agreed search terms, and they determined there
were responsive records.
documents that have been provided date Ms. Mills and
Ms. Abedin, and they determined that there were responsive
records.
agreed upon for the Clinton e-mails.
category, the Department agreed research conduct
revised search all the record systems that had
determined were reasonably likely have responsive records.
And those systems records and offices were identified
Plaintiff the initial record, the transmittal letter with
the initial records that were provided.
They searched through electronically those 55,000
Second, they searched the
Again, using the same search terms that had been
And the third result, the Department going research the
Bureau Human Resources, the Office the Executive
Secretariat, the Office the Legal Adviser and the Central
009
Foreign Policy Records.
FOIA request this case extremely limited.
all notifications personnel action forms for Ms. Abedin.
Those have been provided through the initial search.
and all contracts including, but not limited to, personal
services contracts between the Department and Ms. Abedin.
far know, there are such documents, but again will
research.
reopening the case:
Now, bear mind that Plaintiffs
One, any and
Two, any three really the topic issue the
Records regarding authorization for
Ms. Abedin represent individual clients otherwise engage outside employment while employed the Department. fairly narrow set personnel records, records for
authorization outside employment.
reasonable that the Department determined that, for example,
the Human Resources Bureau, the Office the Executive
Secretariat and the other offices that mentioned would
reasonably likely have responsive records.
That entirely this point suggestion that the Department
follow through the statement its status report that
will conduct revised search all those systems records find any additional documents, again using the agreed
search terms that the parties had already come agreement
on. submitted detailing the searches that were conducted and
the processing any additional responsive records.
And that that point necessary, declaration
And only
010
then should Plaintiff permitted discuss what seem
very far afield items such discovery equipment, devices,
technology.
Federal Records Act case.
bring Federal Records Act case against the Department
regarding this exact issue the 55,000 e-mails.
before another judge, that pending.
Because this FOIA request, this not
THE COURT:
MR. WECHSLER:
And the way, Plaintiffs did
And they can
Which judge that, that Judge Leon?
No, that Judge Boasberg.
And
the way, the number that
THE COURT:
Shouldnt one judge not me, shouldnt
one judge have all these cases?
talk.
That
Maybe the three should
Any objection one judge resolving all these issues?
MR. WECHSLER: not prepared respond that
today, but will say that the civil action number
THE COURT:
around our court?
Are there any other lawsuits kicking
MR. WECHSLER: yeah, Judicial Watch has many
cases involving these records.
(JEB).
Federal Records Act case here.
THE COURT:
MR. WECHSLER:
That case number 15-cv-785
Now, the other distinction again, were not
Correct.
The other distinction the case
did not involve these FOIA requests, was something
completely different.
There were five different categories,
011
and the only interrelation one them involved Ms. Abedin,
but involved very different point.
employment special government employee, not authorization
for outside employment.
whatever occurred another hearing another case brought Plaintiff really does not bear upon whether not the
Department exercising its reasonable efforts here.
THE COURT:
youre saying. involved her
Thats apples and oranges. let see understand what
Youre proposing that the Government research
using terms that have been agreed upon the parties, and
then produce appropriate subject challenge the
Plaintiff with respect the adequacy that search?
MR. WECHSLER:
THE COURT:
Yes, your Honor. think agree with that. mean,
think agree with that, thats reasonable.
back and say this what weve done, weve used the terms
weve agreed to.
privileged, whatever.
you know what judge, thats inadequate for the following
reasons then.
back.
one judge, not me, having all these cases.
think there are too many judges.
MR. BEKESHA:
Because you come
This what were producing, this whats
Then Plaintiff position say, think, but let invite Plaintiffs counsel
But actually going talk colleagues about
point first. seems
Sure, your Honor, can address that
Judicial Watch does have several cases.
012
THE COURT:
MR. BEKESHA:
That address the 55,000 e-mails?
All different issues, issues relating Mrs. Clintons e-mails, the actual records; some records
related other aides, their e-mails; FOIA requests about the
fact that Mrs. Clinton had private e-mail server, have
some requests about that.
THE COURT:
MR. BEKESHA:
THE COURT:
There may about so. lawsuits?
About lawsuits ours.
Theres there judge this court who does
not have one these cases?
MR. BEKESHA: dont know about that. know
that believe was Judge Contreras least two
occasions, one one our cases
THE COURT: dont know would burdensome
for one judge have everything.
MR. BEKESHA:
THE COURT:
MR. BEKESHA:
THE COURT:
MR. BEKESHA: asked about consolidation.
Which judge was that?
Contreras. interested that? think may have been. know the
Governments position dont want state what their
position is, but think they pretty much said they didnt
think was appropriate that time.
the hearings reached out the Government and said
want sit down and talk about all these cases.
You know, after one
013
havent heard back about that.
for one judge handle all these cases
THE COURT: you think makes sense
You know what, going send
e-mail colleagues, just raise it, you know.
were all independent.
lawsuits that are arguably related and grow out the same
subjected matter, Mrs. Clintons e-mails, seems one
judge would then you know, dont know. mean,
But youre telling there are
MR. BEKESHA:
And then with respect the Federal
Records Act lawsuit that the Government talked about, thats
very different lawsuit.
Kerry recover all e-mails taken from the State Department.
THE COURT:
MR. BEKESHA:
Thats lawsuit compel Secretary
That sounds different, right.
Yeah, thats very different from
the case thats here.
wait for summary judgment whenever that may occur and that
may not occur for quite some time, the Government still hasnt
said when expects Mrs. Clinton finish producing all
the records she may have she ever will.
and Mills the same.
that they conducted search the first time around, and
learned through the media that were mistaken taking
their word for what they did.
more time for them conduct searches which they wont
even say will they search these other systems records
The reason think its improper
And Ms. Abedin also relied their statements dont think need wait
014
that would appropriate search.
THE COURT:
Its speculation though, isnt it, about
these other systems that may may not exist? the extent which the Government has obligation
search?
records, right? mean, what
The Government has obligation search its
MR. BEKESHA:
They have obligation search
their records using methods that are reasonably expected
produce responsive records.
THE COURT:
MR. BEKESHA:
Right.
Its not reasonably expected
produce responsive records you know that the records arent
going where youre looking. once again search system records thats incomplete.
Theyre going search the Office the Executive
Secretariat.
Office the Secretary.
Ms. Mills, Ms. Abedin and Mrs. Clinton didnt exclusively
and Mrs. Clinton didnt use all, the State Departments
e-mail server.
they know theyre not going there.
and search there again.
The State Department wants
Thats supposed have all the e-mails the
Theyre going search that, but those records arent going there, and
THE COURT:
But they want
Did Mrs. Clinton admit that she used
private server?
MR. BEKESHA:
Mrs. Clinton said that she used
015
server that was not state.gov. private still unclear.
agency for the four years she was the head the agency.
Arguably she made decision that the system records she
was going use was this server.
property the State Department she was the head the
agency.
these are all issues that weve tried discuss with the
Government, and the Government says were searching the
Whether not thats personal
She used the head the
Maybe that server was dont know that, thats another issue.
You know,
55,000, you know, trust us, were going the correct
searches, you know, thats good enough under FOIA.
not.
this case year later, and have spend more time
court trying figure out whats good enough, what should
believe the Government doing and should take their word face value.
this time.
when brief the issue.
the Court can start resolving today. did that once and now were back.
Well, its had reopen
And just dont think thats appropriate think shouldnt have wait until who knows
Let the Court resolve it. think
The first step identify places which information
records may stored.
BlackBerries sitting around basement, then they cant
search there.
the table.
systems backup computers, backup servers then they cant there are desktops
The answer that question, that issue off the State Department doesnt backup their
016
search there.
know, thats all were looking for.
that process.
the technology, you know, they dont have access the server
that was used Mrs. Clinton, Ms. Mills, Ms. Abedin, you
know, all those issues are then off the table. that question takes that off the table.
You
And can through they dont have backups, they dont keep
But the final last issue Mrs. Clinton still has
this server that has least all her e-mails it, she
has the e-mails Ms. Abedin it. least know that
Ms. Abedin used e-mail address conduct official
business.
those e-mails the joint status report. still dont know what e-mail addresses she was using when
she was not using state.gov because the Government redacted
the domain name.
addresses were this Clinton e-mail server that was set Mrs. Clinton conduct official business during her four
years Secretary State Ms. Mills was using another
e-mail server another account conduct official business. were just looking for answers that can move the was huma@clintonemail.com. attached one
And then Ms. Mills, dont know Ms. Mills e-mail
process along, and that dont get stuck the same
position were.
you did good search and then the New York Times writes
piece another year and have reopen this case for
second time.
They conduct searches, say trust you, just dont think that makes lot sense.
017
THE COURT:
MR. WECHSLER:
Right.
Counsel?
Briefly, your Honor, the Plaintiff
spoke moving the process along.
Department has done the last days.
search terms. e-mails.
e-mails provided date Ms. Mills and Ms. Abedin.
Department not saying trust us, the Department saying
here what weve done, will complete the process,
Thats precisely what the
They agreed
They conducted search 55,000 pages
They conducted additional search the
research the initial systems record.
The
submit declaration the parties cant resolve
THE COURT: necessary, will
But the Plaintiffs not talking about
the initial systems record, the Plaintiff appears
addressing systems record that may exist outside the
government agency.
MR. WECHSLER:
Those are not systems record then.
The definition system record the agency.
under the definition the term system record.
THE COURT:
MR. WECHSLER:
Thats would not private servers?
When say private, what were
saying non state.gov. individually not our concern.
obligation search documents the possession and
control the Department.
that, and are going research those. whether its owned company
But the point the FOIA
Theres question have done
Weve also agreed,
018
weve sent letters all the former
THE COURT:
Alright.
The Plaintiff, let just
pick his argument though.
may have personal servers, they may have personal BlackBerries
that have government records.
obligation attempt search those potential records?
MR. WECHSLER: says Mrs. Clinton others
Does the Government have
No, but what the Government did
send letter two different sets letters, one the
former secretaries requesting that they provide all documents
that may federal records including e-mails non
state.gov account.
pages.
The former secretary provided 55,000
THE COURT:
MR. WECHSLER:
Right.
The Government also sent letter
Ms. Mills and Ms. Abedin particular requesting that they
send all federal records, and theyre the process doing
that.
documents and that the they acknowledged the letter, they provided some
THE COURT:
Were they asked were any those
individuals asked whether not they maintained government
files private servers, BlackBerries other electronic
devices?
MR. WECHSLER:
They were simply asked provide any
documents that may constitute federal records.
words, that were sent during the course the other
019
THE COURT:
what about question though?
whether not they maintained government files any private
servers, BlackBerries other electronic devices?
not, why shouldnt they asked that?
MR. WECHSLER:
Were they expressly asked
And
They were asked for the actual
documents, the things. understand what youre saying, but
THE COURT: understand that.
that answer twice, understand that.
You just gave
What about question
though?
government files any private lets just say electronic
devices otherwise?
Were they asked whether not they maintained
MR. WECHSLER: that degree, but again
THE COURT:
MR. WECHSLER: dont believe that the letters went
Why shouldnt they asked that?
Well, perhaps that would follow, but believe the initial -THE COURT: think should direct the Government ask that question them.
yes, then those would devices that should searched
the Government.
Because indeed the answer
Wouldnt you agree?
MR. WECHSLER:
THE COURT:
No, dont. think that
Lets talk about this for second.
Alright, suppose the answer yes, government files were
maintained private server, BlackBerry device and
020
laptop, and thats the answer.
obligation, any?
MR. WECHSLER:
Then whats the Governments
The primary FOIA obligation
documents that are the possession the Government,
documents created the course business that
THE COURT: understand that, but saying
response your question the answer yeah, the way,
government records were maintained private iPhone
Android whatever and thats the answer, then the
Government has obligation search those records?
MR. WECHSLER:
Not search.
The obligation what theyve done which say you have such
documents including personal e-mails, provide them us.
THE COURT:
Okay.
Alright, were talking around
this issue though. that the Government should directed ask those
individuals whether not they did fact maintain, keep,
whatever the language is, possess government materials
private electronic devices otherwise, just that question,
and get answer.
Governments obligation that point. seems unless theres seems
And then figure out what the
MR. WECHSLER: believe the answer was given
indirectly.
from non state.gov account, the answer yes presumably.
That is, furnishing e-mails that were sent
THE COURT:
Have they responded that they furnished
021
all the government materials maintained private servers,
cetera?
MR. WECHSLER:
THE COURT:
MR. WECHSLER:
The documents that were
And not, why shouldnt they?
They are the process completing
that that initial documents were provided.
THE COURT: understand what Plaintiffs saying,
and just trying make easier for everyone get
this information the information exists. understand what
Plaintiffs saying, makes good point.
thing about sending the Government off fishing
expedition try and find something.
though for the Government ask former government employees
tell whether not you maintained our files your
private servers and other electronic devices otherwise.
And otherwise would electronic devices that box
their garage whatever.
yes, you must declare under penalty whether not you have
provided the Government with copies all those materials.
And you havent, give those materials and then
determine whether bases exist for other kinds discovery.
But theres one
Theres another thing
Tell that.
And the answer
But Counsel makes good point, and just think theres
some questions that need answered though.
not going send you off searching here, there and
everywhere.
You know,
But think those very precise questions should
022 directed those three individuals for the purpose
identifying whether not there are other devices and
otherwise that are existence that have materials that the
Government has that the Governments entitled get. point.
MR. WECHSLER:
Thats
Yeah, submit that the next step
could that the Government provide copies the letters
that were sent the former secretaries and Ms. Mills and
Ms. Abedin.
THE COURT:
MR. WECHSLER:
The Plaintiffs not seen those letters?
They have seen they are attached some their pleadings believe.
THE COURT:
Well, theyre attached their
pleadings theyve seen them then guess, right?
MR. WECHSLER:
THE COURT:
MR. BEKESHA:
THE COURT:
MR. BEKESHA:
Yeah.
Wait minute, think Counsel -May answer, your Honor?
Yes. asked the Government provide
those letters, they did not provide them.
requests asking for those records because the Government
wouldnt provide them this case.
THE COURT: have sent FOIA
But youre agreeable providing those
letters now?
MR. WECHSLER:
Yes.
023
THE COURT:
Alright, okay.
Forthwith, thats fine.
And can get the bottom this.
impose any unreasonable barriers anyone, especially the
Government thats overburdened.
theyre saying is, You know, Judge, there may other
devices that have this material.
case, and you dont know.
asked.
answered.
Look, not going
But fair fair.
All dont know that the
But least the question should
And maybe the questions have already been asked and
And so, the answers should part
declaration from the Government that the public that the
Plaintiffs know that the Governments been duly diligent and
asked the questions that should asked.
trying get access information that theyre entitled have access to.
youre going turn those letters over? not trying trick you, you know, but
MR. WECHSLER:
THE COURT:
MR. WECHSLER:
THE COURT: mean, all theyre
Yes, your Honor.
And the responses, right?
Yes, your Honor.
Okay, thats fine. you have copies
today?
MR. WECHSLER: not, but can provide the
substance which was that there were requests Ms. Mills and
Ms. Abedin that they make available the Department any
federal records that they may have their possession such
e-mails concerning official government business sent
024
received personal e-mail account while serving their
official capacities with the Department there any reason believe that those records may not otherwise preserved the Departments recordkeeping systems.
THE COURT:
Okay.
sound like?
MR. WECHSLER:
THE COURT: theyve been asked that
Yes.
And all they need copy that
letter them, those individuals, and copy their
responses, and then can from there.
think can spend anymore time today. still think what proposing not unreasonable,
that the event theyve not been asked they should
directed to, tell you whether not there are any
additional devices that have materials that have not been
heretofore turned over the Government.
MR. WECHSLER: mean, dont mean, would like
They were asked provide any such
documents.
THE COURT:
Alright. think you need see the
letters anyway and the responses.
just speculating about what should done this point.
MR. BEKESHA:
THE COURT:
that.
Thank you. mean, otherwise were
Thank you.
But thank you very much, appreciate
Yes, Counsel?
MR. BEKESHA:
Two quick points, your Honor?
025
THE COURT:
MR. BEKESHA:
Yeah, sure. dont want confuse anything more,
but also when was talking about the BlackBerries and
desktops, meant the ones that were officially issued the
State Department.
Mrs. Clinton. State Department BlackBerries
THE COURT:
Thats why said other devices
otherwise something like that.
MR. BEKESHA:
Some those could the State
Departments possession, because arguably when Mrs. Clinton
longer was Secretary State she turned over her BlackBerry
that was issued the State Department.
THE COURT:
MR. BEKESHA:
Right. the BlackBerry may not her
possession, may the State Departments possession.
And that was another one the questions had.
THE COURT: see. then other words, the
State Department could have that device and not had the
opportunity search because was unaware that had
it. mean, thats possible.
MR. BEKESHA: that needed to, that they had
and they needed because the records werent the box.
THE COURT:
Right.
Alright, heres what going do.
copy the letter those individuals and copy the
Youre going get those questions youll get
026
responses from those individuals, youll get that information.
And what going since dont know what the responses
are have idea what the letters say going
issue minute order that also directs the Government ask
the questions that think should asked this point.
Now, may well that those questions have been answered,
but dont want bring you back week two weeks
talk about okay, where from here.
issue that. going the extent theyve already been answered, then course the Government does not need to.
that additional directive that other devices identified
that may well the possession the Government and have
not been searched the Government.
MR. BEKESHA:
Okay, your Honor.
But will add
One other possible
question asked, during the hearing before Judge Leon,
the attorney that the Plaintiff that case, went
through list questions about employees that received the
letters that counsel was just referring to. and can submit the transcript, was for Mrs. Clinton,
she turned over 55,000 pages.
everything.
this case, provided boxes records.
that everything, the head the FOIA for the State Department
said, dont know what did.
that may important posed Ms. Mills, Ms. Abedin,
And the answer dont know thats
With respect Mr. Reines, whos not issue
When asked another question
027
Mrs. Clinton is, Have you produced everything?
right now, the State Department doesnt know everything has
been produced thats their possession, they just know that
something has been produced.
THE COURT:
MR. BEKESHA:
THE COURT:
Because think thats fair, Ill that.
Thank you, your Honor.
Ill try put together fair minute
order and Ill issue that.
objections then the Government can object, but think thats think thats fair. there are
fair.
one letter each the three individuals, Counsel,
series letters, the letter and the responses? going direct that those letters was just
MR. WECHSLER:
One letter Ms. Mills and
Ms. Abedin, separate letter was sent former Secretary
Clinton.
THE COURT:
Alright.
And the Government has agreed turn over those letters and the responses Plaintiffs
counsel and post them the docket, correct?
MR. WECHSLER:
THE COURT:
MR. BEKESHA:
Yes.
Alright, thats fine. sorry, your Honor, co-counsel
reminded one other small point.
the joint status report, Ms. Abedin least used one e-mail
address that was clintonemail.com.
other e-mail accounts are the server Mrs. Clinton. demonstrated dont know what
028
would helpful for Mrs. Clinton identify what
Ms. Mills and Ms. Abedin used her server conduct official
business.
access the server, Mrs. Clinton may have it.
Because Ms. Mills and Ms. Abedin may not have
THE COURT: trying make easy for everyone,
thats why said other devices, cetera otherwise.
well figure out some language use answer that
legitimate concern.
MR. BEKESHA:
THE COURT:
else?
Thank you, your Honor.
Alright, well try that.
Anything have another status hearing date?
MR. WECHSLER:
MR. BEKESHA:
THE COURT:
Labor Day so.
No, your Honor.
No, your Honor. should bring you back maybe after
What about that?
MR. BEKESHA:
MR. WECHSLER:
THE COURT:
Thats fine.
Thats fine.
Alright.
Lets pick date.
Counsel, going suggest September the 10th 10:00 oclock. that bad date bad time?
MR. BEKESHA:
THE COURT:
Good date?
Thats okay, your Honor.
You sure? that bad date? mean, theres better date can give you
MR. BEKESHA:
THE COURT:
Its fine, your Honor.
September the 10:00 a.m., and
029
that will status hearing.
appropriate minute order that addresses the concerns.
are good concerns, youll get answers.
going research.
Well try put together
Those
The Government
What about producing the results the research that you
refer your status report filed yesterday, how much time you need for that?
MR. WECHSLER: the search, notify Plaintiff responsive records and then
process thereafter.
THE COURT:
MR. BEKESHA:
THE COURT: think thats fair enough, alright.
Anything else? suggest that days actually
No, your Honor.
Alright, everyone have nice weekend.
Good see everyone.
(Proceedings concluded 11:58 a.m.) [4] 12/6 12/7 12/8 13/5
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identify [3] 2/4 15/20 28/1
kicking [1] 10/16
identify what [1] 28/1
kinds [1] 21/21
identifying [1] 22/2
knew [1] 7/7 [39]
know [46]
important [2] 4/18 26/25
known [1] 3/22
impose [1] 23/3
knows [2] 6/25 15/17
improper [1] 13/15 [69]
inadequate [1] 11/19
Labor [1] 28/15
INC [3] 1/3 1/14 2/3
language [2] 20/18 28/7
including [3] 9/5 18/10 20/13
incomplete [7] 3/11 3/21 3/23 6/10 7/13 laptop [1] 20/1
last [4] 2/15 3/12 16/7 17/4
7/24 14/14
later [1] 15/13
indeed [1] 19/19
lawsuit [3] 13/10 13/11 13/11
independent [1] 13/5
lawsuits [4] 10/16 12/7 12/8 13/6
indirectly [1] 20/23
learned [1] 13/22
individual [1] 9/10
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individually [1] 17/22
lecturn [1] 2/4
individuals [7] 18/20 20/17 22/1 24/9
left [1] 4/11
25/25 26/1 27/11
information [8] 4/6 4/9 4/18 15/20 21/9 Legal [1] 8/25
legitimate [1] 28/8
21/9 23/13 26/1
Leon [4] 4/24 5/14 10/8 26/15
initial [7] 8/21 8/22 9/4 17/10 17/13
Leons [1] 5/15
19/17 21/6
let [5] 7/25 11/8 11/20 15/18 18/2
initially [1] 3/15
lets [3] 19/11 19/23 28/18
instance [1] 6/22
letter [10] 8/21 18/8 18/14 18/17 24/9
intentionally [1] 7/1
25/25 27/11 27/12 27/13 27/14
interested [1] 12/19
letters [14] 18/1 18/8 19/13 22/7 22/10
internet [1] 4/12
22/20 22/24 23/15 24/20 26/3 26/18
interrelation [1] 11/1
27/10 27/12 27/17
into [1] 6/14
like [4] 6/9 24/6 24/11 25/8
invite [1] 11/20
likely [2] 8/19 9/17
involve [1] 10/24
limited [3] 4/18 9/2 9/5
involved [4] 2/24 11/1 11/2 11/2
list [1] 26/17
involving [1] 10/19
little [1] 6/14
iPhone [1] 20/8
longer [1] 25/11 [88]
look [2] 4/19 23/2 the [1] 18/18
looking [4] 6/21 14/13 16/2 16/20
isnt [1] 14/2
issue [21] 3/2 3/6 3/7 3/13 3/16 3/19 4/3 lot [1] 16/25
5/13 5/18 7/16 9/8 10/6 15/7 15/18
15/23 16/7 20/15 26/4 26/9 26/21 27/8
made [1] 15/4
issued [2] 25/4 25/12
mail [14] 3/24 7/5 8/6 12/5 13/4 14/20
issues [9] 2/23 3/4 3/6 8/4 10/13 12/2
16/10 16/13 16/15 16/16 16/19 24/1
12/2 15/8 16/6
27/23 27/25 [60]
its [9] 5/16 5/24 6/17 13/15 14/2 14/11 mails [26] 2/25 3/1 3/25 4/13 5/4 7/6 8/4
8/5 8/10 8/16 10/6 12/1 12/3 12/4 13/7
15/11 17/21 28/24
13/12 14/16 16/8 16/9 16/12 17/6 17/7
items [1] 10/2
18/10 20/13 20/23 23/25
its [7] 5/25 6/4 6/6 6/7 9/19 11/7 14/5
maintain [1] 20/17
maintained [7] 18/20 19/3 19/10 19/25
maintained... [3] 20/8 21/1 21/14
make [5] 5/23 6/13 21/8 23/23 28/5
makes [4] 13/1 16/25 21/10 21/22
many [2] 10/18 11/23
Marcia [1] 2/12
Massachusetts [1] 1/18
material [1] 23/6
materials [6] 20/18 21/1 21/19 21/20
22/3 24/15
matter [2] 13/7 30/4
may [33]
maybe [4] 10/12 15/5 23/8 28/14 [17] 2/7 2/12 5/8 7/25 10/11 11/8
11/20 11/22 11/22 13/5 13/7 18/2 19/8
20/15 20/16 21/11 27/22
mean [10] 4/22 11/14 13/4 14/3 23/12
24/10 24/11 24/20 25/20 28/22
meant [1] 25/4
mechanical [1] 1/24
media [1] 13/22
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MICHAEL [2] 1/13 2/6
Mills [17] 3/1 5/5 8/5 8/13 13/20 14/18
16/5 16/12 16/18 17/7 18/15 22/8 23/22
26/25 27/13 28/2 28/3
Mills [1] 16/15
mind [1] 9/1
minute [4] 22/16 26/4 27/7 29/2
mistaken [1] 13/22
more [4] 5/15 13/24 15/13 25/2
morning [7] 2/6 2/9 2/10 2/14 5/7 8/1 8/2
motion [1] 7/12
move [1] 16/20
moving [1] 17/3
Mr. [2] 5/2 26/21
Mr. Hackett [1] 5/2
Mr. Reines [1] 26/21
Mrs [1] 18/3
Mrs. [23] 3/23 4/9 4/24 5/5 7/20 12/3
12/5 13/7 13/18 14/18 14/19 14/23
14/25 16/5 16/7 16/17 25/6 25/10 26/19
27/1 27/25 28/1 28/4
Mrs. Clinton [21] 3/23 4/9 4/24 5/5 7/20
12/5 13/18 14/18 14/19 14/23 14/25
16/5 16/7 16/17 25/6 25/10 26/19 27/1
27/25 28/1 28/4
Mrs. Clintons [2] 12/3 13/7 [2] 17/7 18/15
Ms. [35]
Ms. Abedin [19] 3/1 5/5 8/14 9/3 9/6
9/10 11/1 13/19 14/18 16/5 16/9 16/10
22/9 23/23 26/25 27/14 27/23 28/2 28/3
Ms. Mills [15] 3/1 5/5 8/13 14/18 16/5
16/12 16/18 17/7 18/15 22/8 23/22
26/25 27/13 28/2 28/3
Ms. Mills [1] 16/15
much [3] 12/22 24/23 29/6
must [1] 21/18 [9] 5/13 9/18 11/21 13/4 19/2 19/9
20/8 22/5 27/21
name [1] 16/15
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necessarily [1] 3/25
necessary [2] 9/23 17/10
need [6] 13/23 21/23 24/8 24/19 26/10
29/7
needed [2] 25/21 25/22
New [1] 16/23
news [1] 7/11
next [1] 22/6
nice [1] 29/14 [15] 1/4 4/23 8/12 8/14 9/7 10/9
15/21 17/24 18/7 19/22 20/10 25/10
28/12 28/13 29/13
non [4] 3/24 17/21 18/10 20/24
not [67]
nothing [1] 5/21
notifications [1] 9/3
notify [1] 29/9
now [8] 3/5 7/17 9/1 10/20 15/12 22/24
26/6 27/2
number [3] 10/10 10/15 10/19 [2] 1/18 1/21
oclock [1] 28/19
object [1] 27/9
objection [1] 10/13
objections [1] 27/9
obligated [1] 5/22
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18/6 20/2 20/3 20/10 20/11 20/21
obligations [1] 4/21
occasions [1] 12/13
occur [2] 13/16 13/17
occurred [1] 11/5
off [5] 15/23 16/1 16/6 21/11 21/24
Office [5] 8/24 8/25 9/15 14/15 14/17
offices [2] 8/20 9/16
official [8] 1/20 3/25 16/10 16/17 16/19
23/25 24/2 28/2
officially [1] 25/4 [2] 10/18 20/7
okay [8] 3/12 20/14 23/1 23/19 24/5
26/8 26/14 28/21
old [1] 7/19 [34]
once [2] 14/14 15/12
one [25] 3/6 3/8 8/4 9/2 10/11 10/12
10/13 11/1 11/22 12/10 12/13 12/13
12/15 12/23 13/2 13/7 16/11 18/8 21/10
25/16 26/14 27/11 27/13 27/22 27/23
ones [1] 25/4
only [2] 9/25 11/1
onto [1] 5/8
opportunity [1] 25/19 [46]
oranges [1] 11/4
order [3] 26/4 27/8 29/2
Orfanedes [1] 2/8
originally [1] 4/5
other [25] 4/22 5/17 5/20 8/7 9/16 10/16
10/20 10/23 12/4 13/25 14/3 18/21
18/24 19/4 21/15 21/21 22/2 23/5 25/7
25/17 26/11 26/14 27/22 27/25 28/6
others [1] 18/3
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21/16 22/3 24/3 24/20 25/8 28/6
our [6] 3/5 3/19 10/17 12/13 17/22 21/14
ours [1] 12/8
out [8] 4/7 4/19 7/16 12/24 13/6 15/14
20/20 28/7
outside [4] 9/11 9/13 11/4 17/14
over [7] 5/4 5/16 23/15 24/16 25/11
26/20 27/17
overburdened [1] 23/4
own [4] 5/25 6/4 6/6 6/8
owned [1] 17/21
pages [9] 2/25 4/24 5/19 6/18 8/5 8/11
17/5 18/12 26/20
paper [1] 6/16
paragraph [1] 3/12
part [1] 23/9
particular [1] 18/15
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Paul [1] 2/7
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people [1] 7/6
perhaps [1] 19/16
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20/13 24/1
personnel [2] 9/3 9/12
PETER [2] 1/16 2/10
pick [2] 18/3 28/18
piece [1] 16/24
place [1] 5/16
places [5] 5/9 6/11 7/21 7/22 15/20
Plaintiff [13] 1/4 1/13 8/4 8/21 10/1 11/6
11/12 11/18 17/2 17/13 18/2 26/16 29/9
Plaintiffs [7] 9/1 11/20 17/12 21/7 21/10
22/10 27/17
Plaintiffs [2] 10/4 23/11
pleadings [2] 22/12 22/14
please [1] 2/4
point [14] 5/9 7/14 9/18 9/23 11/2 11/25
17/22 20/21 21/10 21/22 22/5 24/21
26/5 27/22
points [1] 24/25
Policy [1] 9/1
posed [1] 26/25
position [5] 3/5 11/18 12/21 12/22 16/22
possess [1] 20/18
possession [8] 17/23 20/4 23/24 25/10
25/15 25/15 26/12 27/3
possibilities [1] 4/16
possibility [1] 4/22
possible [3] 7/22 25/20 26/14
post [1] 27/18
potential [1] 18/6
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pretty [1] 12/22
primarily [1] 5/19
primary [1] 20/3
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18/21 19/3 19/11 19/25 20/8 20/19 21/1
21/15
privileged [1] 11/18
probably [1] 7/14
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process [7] 16/3 16/21 17/3 17/9 18/16
21/5 29/10
processing [2] 5/16 9/25
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produced [4] 1/25 27/1 27/3 27/4
producing [3] 11/17 13/18 29/5
Programs [1] 1/17
property [1] 15/6
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provide [10] 4/17 18/9 18/23 20/13 22/7
22/19 22/20 22/22 23/21 24/17
provided [10] 3/1 8/13 8/22 9/4 17/7
18/11 18/17 21/6 21/19 26/22
providing [1] 22/23
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put [4] 6/16 6/18 27/7 29/1
special [1] 11/3
speculating [1] 24/21
said [12] 5/3 5/4 7/5 7/13 7/19 12/22
speculation [1] 14/2
question [11] 15/23 16/1 17/24 19/2
12/24 13/18 14/25 25/7 26/24 28/6
spend [2] 15/13 24/11
19/9 19/19 20/7 20/19 23/7 26/15 26/24 same [6] 3/18 5/13 8/15 13/6 13/20
spoke [1] 17/3
questions [9] 21/23 21/25 23/8 23/12
16/21
standards [1] 3/3
25/16 25/24 26/5 26/6 26/17
satisfactory [1] 8/8
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quick [1] 24/25
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state [39]
quite [1] 13/17
satisfy [2] 3/3 4/20
state.gov [6] 7/5 15/1 16/14 17/21 18/11
say [11] 5/25 6/19 10/15 11/16 11/18
20/24
13/25 16/22 17/20 19/11 20/12 26/3
statement [1] 9/19
raise [1] 13/4
saying [12] 5/24 5/24 6/4 11/9 17/8 17/8 statements [1] 13/20
raised [1] 8/4
17/21 19/1 20/6 21/7 21/10 23/5
STATES [3] 1/1 1/6 1/11
reached [1] 12/24
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read [1] 7/11
search [40]
27/23 28/11 29/1 29/6
really [2] 9/8 11/6
searched [13] 3/15 4/13 4/14 4/15 5/25 stenography [1] 1/24
reason [2] 13/15 24/2
6/4 6/9 7/8 7/9 8/10 8/12 19/20 26/13
step [2] 15/20 22/6
reasonable [4] 6/20 9/14 11/7 11/15
searches [10] 3/2 3/10 3/10 5/18 7/23
still [5] 13/17 15/2 16/7 16/13 24/12
reasonably [4] 8/19 9/17 14/8 14/11
8/7 9/24 13/24 15/11 16/22
storage [1] 4/11
reasons [1] 11/20
searching [11] 3/18 5/19 6/1 6/7 6/10
stored [1] 15/21
received [2] 24/1 26/17
6/11 7/1 7/1 7/24 15/9 21/24
storing [1] 6/15
record [13] 2/5 5/8 6/17 7/13 8/18 8/21 second [3] 8/12 16/25 19/23
Street [1] 1/14
17/10 17/13 17/14 17/16 17/17 17/18
Secretariat [3] 8/25 9/16 14/16
stuck [1] 16/21
30/3
secretaries [2] 18/9 22/8
subject [1] 11/11
recorded [1] 1/24
secretary [7] 7/4 13/11 14/17 16/18
subjected [1] 13/7
recordkeeping [1] 24/4
18/11 25/11 27/14
submit [3] 17/11 22/6 26/19
records [68]
see [4] 11/8 24/19 25/17 29/15
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recover [1] 13/12
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redacted [1] 16/14
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refer [1] 29/6
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sufficient [2] 3/3 3/20
referring [1] 26/18
send [4] 13/3 18/8 18/16 21/24
suggest [4] 2/15 6/24 28/19 29/8
regarding [2] 9/9 10/6
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Reines [1] 26/21
sense [3] 4/6 13/1 16/25
Suite [1] 1/14
related [3] 5/3 12/4 13/6
sent [9] 7/6 18/1 18/14 18/25 20/23 22/8 SULLIVAN [1] 1/10
relating [1] 12/2
22/20 23/25 27/14
summary [1] 13/16
relevant [1] 6/4
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suppose [1] 19/24
relied [1] 13/20
September [2] 28/19 28/25
supposed [1] 14/16
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September the [2] 28/19 28/25
sure [4] 5/23 11/24 25/1 28/22
remaining [1] 3/7
series [1] 27/12 [1] 1/14
reminded [1] 27/22
server [16] 7/20 7/20 12/5 14/20 14/24 system [7] 3/15 4/1 7/24 14/14 15/4
reopen [3] 7/12 15/12 16/24
15/1 15/5 15/5 16/4 16/8 16/16 16/19
17/17 17/18
reopening [1] 9/9
19/25 27/25 28/2 28/4
systems [16] 3/18 3/21 3/23 4/7 6/11
report [7] 2/23 6/5 8/3 9/19 16/12 27/23 servers [8] 4/15 15/25 17/19 18/4 18/21 8/18 8/20 9/20 13/25 14/3 15/25 17/10
29/6
19/4 21/1 21/15
17/13 17/14 17/16 24/4
reporter [3] 1/20 1/20 5/6
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represent [1] 9/10
serving [1] 24/1
representing [1] 2/11
set [2] 9/12 16/16
table [3] 15/24 16/1 16/6
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take [1] 15/15
requesting [2] 18/9 18/15
several [3] 3/23 6/18 11/25
taken [3] 5/11 5/16 13/12
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Shapiro [1] 2/12
takes [1] 16/1
23/22
she [18] 4/11 7/5 7/6 7/21 13/19 13/19 taking [1] 13/22
research [9] 6/6 8/17 8/23 9/8 11/9
14/23 14/25 15/2 15/3 15/4 15/4 15/6
talk [5] 10/13 11/21 12/25 19/23 26/8
17/10 17/25 29/4 29/5
16/8 16/13 16/14 25/11 26/20
talked [1] 13/10
resolve [3] 3/15 15/18 17/11
should [18] 4/3 5/25 6/7 10/1 10/12
talking [3] 17/12 20/14 25/3
resolved [1] 2/16
15/14 15/15 19/18 19/20 20/16 21/25
technology [2] 10/3 16/4
resolving [2] 10/13 15/19
23/7 23/9 23/12 24/13 24/21 26/5 28/14 tell [8] 7/8 7/9 7/10 7/17 7/18 21/14
Resources [2] 8/24 9/15
shouldnt [6] 10/11 10/11 15/17 19/5
21/17 24/14
respect [4] 2/21 11/12 13/9 26/21
19/15 21/4
telling [1] 13/5
respond [1] 10/14
shows [1] 7/4
term [1] 17/18
responded [1] 20/25
simply [1] 18/23
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since [1] 26/2
11/16 17/5
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sit [1] 12/25
testify [1] 5/1
26/2 27/12 27/17
sitting [2] 4/12 15/22
thank [7] 2/21 7/25 24/22 24/23 24/24
responsive [9] 5/22 8/12 8/14 8/19 9/17 small [1] 27/22
27/6 28/9
9/25 14/9 14/12 29/9 [45]
that [233]
result [1] 8/23
some [11] 4/6 6/6 6/12 12/3 12/6 13/17 thats [37]
results [1] 29/5
18/17 21/23 22/12 25/9 28/7
the former [1] 18/1
returned [2] 5/11 5/12
something [7] 6/1 6/1 6/2 10/24 21/12
their [16] 3/5 4/20 12/4 12/21 13/20
revised [3] 3/14 8/18 9/20
25/8 27/4
13/23 14/8 15/15 15/24 21/17 22/12
right [11] 4/1 13/13 14/6 14/10 17/1
somewhere [1] 6/21
22/13 23/24 24/1 24/9 27/3
18/13 22/14 23/17 25/13 25/23 27/2
Room [1] 1/21
RPR [3] 1/20 30/2 30/9
unclear [1] 15/2
under [4] 4/21 15/11 17/18 21/18
them [10] 3/1 11/1 13/24 19/19 20/13
understand [9] 5/23 6/5 11/8 19/1 19/8
22/14 22/20 22/22 24/9 27/18
19/9 20/6 21/7 21/9
themselves [1] 2/4
UNITED [3] 1/1 1/6 1/11
then [25] 3/1 4/3 10/1 11/11 11/18 11/20 unless [1] 20/15
13/8 13/9 15/22 15/25 16/6 16/12 16/23 unplugged [1] 4/11
17/16 19/20 20/1 20/9 20/20 21/20
unreasonable [2] 23/3 24/12
22/14 24/10 25/17 26/9 27/9 29/9
unresolved [1] 4/4
there [33]
until [2] 5/7 15/17
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21/12 21/22 28/23 [2] 16/16 18/3
thereafter [1] 29/10
upon [3] 8/16 11/6 11/10
these [15] 3/19 4/14 7/21 7/23 10/12 [15] 4/17 4/17 7/8 7/9 7/9 7/10 7/17
10/13 10/19 10/24 11/22 12/10 12/25
7/18 10/12 15/10 17/8 20/13 21/14
13/2 13/25 14/3 15/8
21/17 21/20
they [78]
use [3] 14/19 15/5 28/7
theyre [13] 6/10 6/11 6/21 6/21 7/1
used [12] 3/24 4/9 7/5 7/21 11/16 14/23
14/15 14/17 14/21 18/16 22/13 23/5
14/25 15/2 16/5 16/10 27/23 28/2
23/12 23/13
using [7] 8/15 9/21 11/10 14/8 16/13
theyve [6] 2/16 20/12 22/14 24/5 24/13 16/14 16/18
26/9
thing [2] 21/11 21/12
things [1] 19/7
value [1] 15/16
think [29] 4/5 7/4 11/14 11/15 11/20
versus [1] 2/3
11/23 12/20 12/22 12/23 13/1 13/15
very [8] 4/18 4/18 10/2 11/2 13/11 13/14
13/23 15/16 15/17 15/18 16/25 19/18
21/25 24/23
19/22 21/22 21/25 22/16 24/11 24/12
24/19 26/5 27/5 27/8 27/9 29/11
wait [4] 13/16 13/23 15/17 22/16
think that [1] 19/22
want [7] 5/23 6/12 12/21 12/25 14/21
third [5] 1/14 3/2 3/16 4/3 8/16
25/2 26/7
this [30] 4/9 4/17 5/7 6/5 7/13 7/20 9/2
9/18 10/3 10/3 10/6 11/16 11/17 11/17 wants [1] 14/13
12/9 15/5 15/13 15/17 16/8 16/16 16/24 was [37]
19/23 20/15 21/9 22/22 23/2 23/6 24/21 Washington [4] 1/5 1/15 1/18 1/22
WATCH [6] 1/3 1/14 2/3 2/7 10/18 11/25
26/5 26/22
way [3] 10/4 10/10 20/7
those [38] [65]
though [7] 14/2 18/3 19/2 19/10 20/15
well [3] 28/7 28/10 29/1
21/13 21/23
three [9] 2/23 3/4 3/22 8/4 8/6 9/8 10/12 were [13] 4/18 5/9 10/20 11/17 13/5
15/9 15/10 15/12 16/2 16/20 17/20
22/1 27/11
20/14 24/20
through [6] 8/10 9/4 9/19 13/22 16/2
weve [7] 11/16 11/16 11/17 15/8 17/9
26/17
17/25 18/1
time [13] 5/17 6/4 6/10 12/23 13/17
WECHSLER [2] 1/16 2/11
13/21 13/24 15/13 15/17 16/25 24/11
Wednesday [1] 4/25
28/20 29/6
week [1] 26/7
Times [1] 16/23
weekend [1] 29/14
titled [1] 30/4
weeks [1] 26/7
today [4] 10/15 15/19 23/20 24/11
well [8] 5/20 6/2 6/9 15/11 19/16 22/13
together [2] 27/7 29/1
26/6 26/12
told [1] 7/9
went [3] 4/11 19/13 26/16
Tom [1] 2/8
were [34]
too [1] 11/23
were sent [1] 18/25
topic [1] 9/8
werent [1] 25/22
transcript [5] 1/10 1/24 5/6 26/19 30/3
what [44]
transcription [1] 1/25
whats [3] 11/17 15/14 20/1
transmittal [1] 8/21
whatever [6] 2/16 11/5 11/18 20/9 20/18
TRIAL [1] 1/16
21/17
trick [1] 23/14
when [15] 2/22 2/24 2/25 3/3 4/10 6/9
tried [1] 15/8
6/14 7/8 13/18 15/18 16/13 17/20 25/3
trust [3] 15/10 16/22 17/8
25/10 26/22
try [4] 21/12 27/7 28/10 29/1
whenever [1] 13/16
trying [6] 4/18 15/14 21/8 23/13 23/14
where [9] 4/19 5/9 5/21 6/11 6/13 6/23
28/5
7/18 14/13 26/8
turn [2] 23/15 27/17
whether [17] 3/2 3/9 3/20 5/10 5/17 11/6
turned [4] 5/4 24/16 25/11 26/20
15/1 17/21 18/20 19/3 19/10 20/17
twice [1] 19/9
21/14 21/18 21/21 22/2 24/14
two [10] 3/5 3/6 3/22 5/6 8/5 9/4 12/12
which [9] 3/8 5/20 10/8 12/17 13/24 14/4
18/8 24/25 26/7
15/20 20/12 23/22
while [3] 4/10 9/11 24/1
who [2] 12/9 15/17
U.S [2] 1/17 1/21
whos [2] 5/2 26/21
unaware [1] 25/19
why [6] 2/19 19/5 19/15 21/4 25/7 28/6
will [14] 3/9 3/14 3/25 6/5 6/5 9/7 9/20
10/15 13/19 13/25 17/9 17/10 26/10
29/1
within [2] 4/8 4/20
wont [1] 13/24
word [2] 13/23 15/15
words [2] 18/25 25/17
work [2] 4/17 5/3
would [17] 2/3 2/24 2/25 3/18 3/18 7/7
7/15 9/16 12/14 13/8 14/1 17/19 19/16
19/20 21/16 24/11 28/1
would then [1] 13/8
wouldnt [3] 7/14 19/21 22/22
writes [1] 16/23
yeah [6] 10/18 13/14 20/7 22/6 22/15
25/1
year [3] 5/16 15/13 16/24
years [5] 3/22 3/22 7/5 15/3 16/18
yes [13] 2/18 11/13 19/20 19/24 20/24
21/18 22/18 22/25 23/16 23/18 24/7
24/24 27/19
yesterday [2] 2/22 29/6
York [1] 16/23
you [61]
youll [3] 25/24 26/1 29/3
youre [10] 5/24 5/24 11/9 11/9 13/5
14/13 19/1 22/23 23/15 25/24
your [27] 2/6 2/10 2/18 2/21 3/17 7/3 8/2
8/2 11/13 11/24 17/2 20/7 21/14 22/17
23/16 23/18 24/25 26/14 27/6 27/21
28/9 28/12 28/13 28/21 28/24 29/6
29/13