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Judicial Watch • Heather Samuelson deposition 01242 pg 49

Heather Samuelson deposition 01242 pg 49

Heather Samuelson deposition 01242 pg 49

Page 1: Heather Samuelson deposition 01242 pg 49

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Number of Pages:1

Date Created:June 27, 2019

Date Uploaded to the Library:June 27, 2019

Tags:objection, heather, cotca, samuelson, Brewster, Kendall, 01242, Clintons, Susan Rice, FOIA


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Transcript Heather Samuelson
Conducted June 13, 2019
189 Yes. You are still serving the attorney for Secretary Clinton. Correct? Correct. Okay. you still have copy the after-action memo that you created around December 2014 memorializing the search you did for Secretary Clintons e-mails? may. Who else has copy the after-action memo that you provided to? Well, was was with her attorneys. cant speak who who kept the memo. Okay. when youre referring her attorneys, are you just referring Cheryl Mills and David Kendall? Yes, referring David Kendall, yes. Okay. Any any other attorneys? Not that can think for this. Did you review your after-action memo that you created around December 2014 preparation for todays deposition?
191 Okay. And how did you search for Ambassador Susan Rice? How did you use that search term? Well, first, said, had sorted her Inbox and from would look any e-mails she had between herself and Secretary Rice. And then also searched for names senior department officials. when you did this search for the names senior department officials, did you just use use the word Rice alone? couldnt tell you today. was five years ago. Okay. But that information that you have available that would contained the after-action memo that you created December 2014.
MR. BREWSTER: Objection. that correct?
MR. BREWSTER: Calls for privileged
information
for attorney work product.
MS. COTCA: just saying that she has
190
MR. BREWSTER: Objection. Calls for
privileged
information.
Ill instruct her not answer. Okay. Sitting here today, youre not able say for sure that you used the term ambassador key search term review Secretary Clintons e-mails. that right? Thats correct. But, again, the keywords were really just spot checking, make sure didnt miss anything the full review that already went over. And understand your testimony and what youre saying about that. But trying get understanding specific key keyword terms that were used search Secretary Clintons e-mails that are relevant Judicial Watchs FOIA request this case.
Did you use Rice -18 did. search term? did. She was one the names that searched. (189 192)
192 the after action asking that for her confirm that she has the after-action memo that she created around December 2014.
MR. BREWSTER: Your question phrased asking for the contents privileged memo.
MS. COTCA: No. Let rephrase it, thats the way that youre understanding the question. MS. COTCA: question is, would you able determine looking your after-action memo that you created December 2014 whether you used the term Rice alone part the keyword search?
MR. BREWSTER: Objection. Calls for privileged information. going instruct her not answer.
MS. COTCA: And, again, whats the privilege that you are asserting for that?
MR. BREWSTER: Attorney work product. Did you use the search term U.S.U N/W? Not that recall.
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