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Judicial Watch • JW v DOJ Ohr Fusion GPS transcript 00491

JW v DOJ Ohr Fusion GPS transcript 00491

JW v DOJ Ohr Fusion GPS transcript 00491

Page 1: JW v DOJ Ohr Fusion GPS transcript 00491

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Number of Pages:22

Date Created:June 26, 2018

Date Uploaded to the Library:June 28, 2018

Tags:gerardi, Nellie, GPS, Fusion, 00491, Ohr, cotca, jones, DOJ, FOIA


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THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH
vs.
U.S. DEPARTMENT JUSTICE
Defendant.
Plaintiff,
Docket No. 18-491-RBW
Washington, D.C.
June 14, 2018
11:00 a.m.
TRANSCRIPT STATUS CONFERENCE
BEFORE THE HONORABLE SENIOR JUDGE REGGIE WALTON
UNITED STATES DISTRICT JUDGE
APPEARANCES:
For the Plaintiff:
Ramona Cotca, Attorney-at-Law
JUDICIAL WATCH, INC.
425 Third Street, Suite 800
Washington, D.C. 20024
(202) 646-5172, Ext. 328
Email: rcotca@judicialwatch.org
For the Defendant:
Michael Joseph Gerardi, Attorney-at-Law
U.S. DEPARTMENT JUSTICE
Civil Divsion, Federal Programs Branch Massachusettts Avenue,
Washington, D.C. 20530
(202) 616-0680
email:michael.j.gerardi@usdoj.gov
Court Reporter:
Cathryn Jones, RPR
Official Court Reporter
Room 6521, U.S. District Court
333 Constitution Avenue, Room 6521
Washington, D.C. 20001
(202) 354-3246
Email: Cathryn_Jones@dcd.uscourts.gov
Proceedings recorded machine shorthand, transcript
produced computer-aided transcription.
THE DEPUTY CLERK:
Your Honor, this morning this re:
Justice.
step forward and identify yourselves for the record, please.
Judicial Watch versus the U.S. Department
This Civil Action 18-491.
MS. COTCA:
Ask the parties
Good morning, Ramona Cotca for
Judicial Watch, and counsels table Tom Fenton
behalf Judicial Watch.
THE COURT:
MR. GERARDI:
Good morning.
Good morning, your Honor.
Michael
Gerardi behalf the Department Justice. counsel table Marcia Berman, also from the Department Justice and Timothy Zeese [phonetic] and Brian Flanagan
from OIP.
THE COURT:
Good morning.
And with
What exactly the
information that youre seeking acquire from the
government?
MS. COTCA:
Meaning the FOIA request?
THE COURT:
Yes.
MS. COTCA: the FOIA request ask for
communications between the Attorney Generals office from,
and one individual, third party, Nellie Ohr, who was with
Fusion GPS.
December
And the time frame from January 2015
THE COURT:
One moment.
January 2015 what?
MS. COTCA:
December 12, 2017.
THE COURT:
And who this woman?
Whats this
entity Fusion?
MS. COTCA:
Fusion GPS the entity that hired
Christopher Steele, who authored the dossier about Donald
Trump, and that was believe publicized later after the new
administration came power 2017.
Nellie Ohr work on, for the purposes doing the
opposition research for, Donald Trump the president now.
Fusion GPS hired
And all this was financed the DNC.
sorry?
Nellie Ohr
THE COURT:
Who she, and what her position?
MS. COTCA:
Right.
Nellie Ohr worked for Fusion
GPS.
Bruce Ohr, was working.
Department Justice during this time.
theres lot public interest with respect
communications between the Department Justice and Nellie
Ohr.
And the relationship with the DOJ that her husband,
THE COURT: was high official the
And that why
And has the government obtained
information about the request thats being made responsive information?
responsive records that would satisfy the FOIA request?
Government, have you able identify
MR. GERARDI: date, have not been able
identify responsive records, your Honor.
Part the reason
for that the, this part the reason were here schedule the time frame which the government has
complete its search for records and form production
schedule.
search for records will take.
records yet, but our search ongoing.
And the dispute were having the time that
THE COURT: havent identified
And how long you think its going take you determine there are responsive documents?
MR. GERARDI:
Well, proposed our status
report, our initial proposal the initial proposal put the status report search custodians who
worked the office the Attorney General during, from
the range basically January 2016 January 20, 2017,
basically when the administration changed over.
That significant number custodians.
And
given OIPs current backlog requests and you know, they
obviously have handle requests that are litigation and
then significant number requests that are not the
subject litigation, weve proposed schedule six
months order complete those, the searches those
individuals.
THE COURT:
Whats the workload that they have
now?
MR. GERARDI:
Well, your Honor, set out
page and our status report the current backlog
requests quite significant. received from the agency this morning, but the total, the
total backlog the agency today for all its
tracks.
under around 1700 requests.
noted theres significant number complex track requests
like this one that are ahead the queue and that
includes litigation cases and non-litigation cases. have some updated figures
Meaning theres different tracks the cases fall
THE COURT:
And our status report
How many people are assigned
this?
MR. GERARDI:
Your Honor, dont know have answer that question terms like the number
staff OIP have assigned this.
from OIP counsel
THE COURT: have representatives
Can somebody tell how many people?
Because get very frustrated with the government because
Congress its wisdom created this law, which good
law, but yet constantly have the government telling
they only have limited number people the searches
for this information.
going enact laws they need provide the means which
the agencies can the work.
And seems Congress
MR. GERARDI:
THE COURT:
[Brief pause.]
Give moment confer with -Yes.
MR. GERARDI:
Your Honor, OIPs current staff individuals.
THE COURT:
And theyre all doing these records
searches?
who knows whats going on.
Let get somebody here who can talk
MR. GERARDI:
THE COURT:
[Brief pause.]
THE COURT:
MR. SWANSON:
Give just moment, your Honor.
All right.
Yes.
Your name?
Brian Flanagan.
The initial request
staff has people and the initial request staff handles
all incoming requests and the processing those requests completion. different phases, but that the size the team that
handles initial requests.
The requests different people handle them
THE COURT:
Thank you.
You wanted say
MS. COTCA:
Well responsive that, that was part
something? the joint status report and just wanted address that
point, that the Court.
Judicial Watch would say people, and yet the
Department Justice has represented that they have
influx the FOIA requests.
perhaps the agency should commit more people handle the
increase the FOIA requests. theres such influx then
Eleven people for the entire
Department Justice very, very, very small
percentage.
But initially, mean also just want address
with respect what opposing counsel said for the
search.
Department Justice has not even begun the search, that
its just queue. understanding date has been that the
And
THE COURT:
When did you submit your request?
MS. COTCA:
The request was submitted December, believe December 2017.
the search, its already been six months. Justice asking another six months the search.
And some degree but addition theyre also trying
modify the FOIA request.
entire timeframe that Judicial Watch had asked.
reasonable.
request not reasonable, that its unduly burdensome.
FOIA
Hence, the cutoff date for
The Department
They are not searching for the
And its
They have not made the argument that the FOIA
The
THE COURT:
And dates back to?
MS. COTCA:
January 1st, 2015.
THE COURT:
And the basis for dating back that
MS. COTCA: know that Fusion GPS was working
date?
with Nellie Ohr the opposition research.
back 2015, one year prior more than reasonable
And date going
request records for one year before. 2010.
Were not going back
And believe
THE COURT:
Was she with Fusion that time?
MS. COTCA: dont have that information.
Perhaps the Department Justice has that information.
Judicial Watch does not have the information when she was
hired.
2016.
the year prior. know that the dossier was being created therefore our rationale lets seek records for
And then December 12, 2017, which right
before Bruce Ohr was dismissed from the department, was let from his position the Department Justice. the rationale for the time frame the request.
tried limit much possible.
THE COURT: that
Does the government know when she
started working with Fusion GPS?
MR. GERARDI:
Your Honor, dont have our
research date doesnt indicate that there are records
from that time frame.
THE COURT:
Well theyre requesting that the
search date back January 1st, 2015, and youre saying
should start some time 2016.
their position?
MR. GERARDI:
Why you disagree with can take step back.
Its,
what weve proposed prioritize the search 2016.
think plaintiff has acknowledged this individual was
involved opposition research during the presidential
campaign. 2016.
search order get the, think the heart their
request faster.
The presidential campaign obviously takes place
And propose prioritize that part the
Obviously something came the search
2016 records that suggested there was reason believe
records existed prior that continue, would
obviously look into that and maybe consider expanding the
search team, consider that timeframe.
THE COURT:
But why should what you find regarding
2016 dictate whether you look 2015?
MR. GERARDI:
Well, doesnt necessarily dictate
it, but might provide basis might provide
basis
THE COURT: seems the better approach
would youre saying you think more fruitful
search 2016, that search try and get that
information, but then subsequent that then look 2015 youre saying 2016 going have the most fruitful
information.
MR. GERARDI:
Right.
And prioritize the search search 2016 first.
something the records from that suggest there was
communication going further back that might reason
But say that something you discovered
continue searching for 2016 records.
THE COURT: question is:
Why are you taking
2015 off the table and except you find something related 2016?
MR. GERARDI:
Because were trying mean
part the reason for the proposal was try and keep the
search time minimum.
morning since the status report.
that search 2016 records that weve proposed about
Weve conferred with OIP this think that can
four and half months.
way get the core what the plaintiffs request
about.
that will allow better determine whether 2015 search records appropriate.
And think that thats the fastest
And think based that well have information dont think Ive answered your question though.
THE COURT: just dont understand, and seems they have good faith basis for believing that
search for records related 2015 would appropriate. just dont see how you predicate whether youre going
search 2015 based upon what you find 2016.
fine youre saying you think its going more
fruitful 2016 first and then 2015 thereafter.
dont have problem with that.
can say well, what find regarding 2016 going
predicate whether think need search for 2015. think its just dont see how you
MR. GERARDI: mean think Ive explained why. think that this 2016, mean maybe just dont
THE COURT: dont have problem with that.
you think the information that theyre looking for
probably going found records from 2016, that
first, and then once you finish that then 2015.
fine.
MR. GERARDI:
proposed.
Thats
Yeah, and think thats what
The real reason comes issue
met and conferred about this schedule one kind proposes
way focus the search narrow the search time was
focus 2016.
doesnt, didnt get the plaintiffs where they were trying get terms the time frame the schedule.
The difference between 2015 and 2016 though
THE COURT:
Well, she correct that this
point there hasnt been any search conducted?
MR. GERARDI: would disagree with that.
Obviously, weve been trying determine what the core
custodians that are going search is, and weve been
meeting and conferring with them over that.
consider that part the search. would you mean that has OIP like actually gone and
done the email search that has not been done yet.
process that were having, meeting and conferring and trying identify who the right people search are part
This
the search.
THE COURT:
Well the process actual searching
the emails when will that start?
MR. GERARDI: dont know precisely when would
start.
complete within the backlog that OIP currently dealing
with, and that weve set forth our position that.
What know that the time would take
THE COURT: think its been almost, since
December when the initial request was made more should have
been done now.
whos going come into office and they say theyre going disrupter, that they should appreciate theres going lot FOIA requests and therefore, should gear deal with those requests.
the position that you have limited staff and therefore, you
cant comply with these requests.
have been anticipated that you were going get inundated
with requests when you have somebody who says theyre going come and totally disrupter.
And seems you have someone not real sympathetic
Because think should think youre going have get some more
people.
being filled the government, you just need get more
people.
keep getting from the government, from various agencies
cant this, cant that because dont have the mean, understand lot positions arent mean FOIA considered very important.
resources. not real sympathetic that.
important.
Open government important, and government has comply with FOIA order make open government.
FOIA
What will Ill continue the matter for two
months.
the checks that need done, and that this information provided rolling basis.
two months.
and records they exists are starting produced.
Ill require that you all start immediately doing
Ill have you all back expect see that the search has been begun
MR. GERARDI:
THE COURT:
Anything else?
MS. COTCA: just want clarify for the Court
Thank you, your Honor.
that dont have issue with respect how the
Department Justice wants prioritize the search.
just want make sure that the search conducted for the
entirety the FOIA request.
the Court well that were also seeking records from 2017,
and that request well was made
THE COURT:
And would like remind
Like said, dont have problem
with them taking the position that they believe its going more fruitful look 2016 first, but dont think
they can take off the table 2015 2017, based upon what
they find regarding 2016.
MS. COTCA:
Correct.
Its our position theyre
trying chip away the actual request.
THE COURT: dont think they can that.
MS. COTCA:
And thats plaintiffs position
well.
Thank you.
THE COURT:
MR. GERARDI:
THE COURT:
MR. GERARDI:
Very well.
The 20th August.
May heard briefly?
Yes.
Obviously out respect your
ruling today this issue. Justice focuses its search may defend that search, the
eventual search decides undertake, thats obviously
not issue for you to, thats going decided today.
That issue for summary judgment based the agencys
determination what reasonable search is.
THE COURT:
MR. GERARDI: terms how the Department
Right.
There are other reasons for, there
are other substantive reasons for focusing the search the
way have including the Attorney Generals recusal
matters related the 2016 election.
what search undertake obviously have the right
defend whatever search undertake reasonable
summary judgment.
obviously.
And regardless didnt understand you say that just want make clear that there are other
reasons that the agency has beyond perimeters and discussion
today about why these searches are reasonable.
And the
agencies obviously reserve the right defend the
reasonableness its search the appropriate time.
THE COURT:
Understood.
MS. COTCA:
Your Honor, may just respond that
THE COURT:
Yes.
briefly?
better.
MS. COTCA:
Thats okay.
While have this out.
THE COURT:
10:30, okay.
Yes, you wanted say
MS. COTCA:
Yes.
Plaintiff okay.
Actually the 21st would
But ahead, sorry.
The 20th August?
something?
Obviously theres time for
summary judgment briefing, but plaintiffs position
mean, the motion itself has nonfrivolous, the
Justice Department going just continue take its
position that theyre not going search for the entirety the FOIA request, dont even know how this Justice
Department can get summary judgment motion theyre
going refuse conduct search for 2017 and 2015.
There has good faith basis submitting
that the department entitled summary judgment.
THE COURT: cant obviously project.
Obviously, said before think would appropriate
prioritize searching the 2016 records.
see how they take off the table 2015 and 2017, but they
And cant, dont
say based upon what they found 2016 supports the position
they shouldnt have the other search thats something
Ill have address.
MS. COTCA:
Okay.
THE COURT:
Thank you.
MS. COTCA:
Thank you, your Honor.
[Thereupon, the proceedings adjourned 11:23
a.m.]
CERTIFICATE Cathryn Jones, Official Court Reporter
for the United States District Court the District
Columbia, hereby certify that reported, machine
shorthand, the proceedings had and testimony adduced the
above case. further certify that the foregoing pages
constitute the official transcript said proceedings
transcribed from machine shorthand notes. witness whereof, have hereto subscribed
name, this the 26th day June, 2018.
/s/_Cathryn Jones
Cathryn Jones, RPR
Official Court Reporter
MR. GERARDI: [21]
MR. SWANSON: [1] 6/9
MS. COTCA: [19]
THE COURT: [41]
THE DEPUTY CLERK: [1] 2/1 [1] 1/6 [1] 17/13
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Fusion [8] 2/23 3/3 3/4 3/7 3/13 7/23
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15/20
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5/16 5/18 8/14 12/22 12/24 13/2 13/2
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GPS [6] 2/23 3/4 3/7 3/14 7/23 8/15
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15/14 15/20
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have [36]
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Hence [1] 7/10
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Honor [11] 2/2 2/10 3/25 4/24 5/11 6/1
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HONORABLE [1] 1/9
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13/13 14/8 15/17 15/25
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Ill [4] 13/4 13/5 13/7 16/3 [4] 3/10 12/14 13/1 15/7
Ive [2] 10/15 11/1
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gear [1] 12/13
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General [1] 4/12
12/9
Generals [2] 2/21 14/17
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Gerardi [2] 1/15 2/11
get [11] 5/16 6/4 9/4 9/18 10/11 11/13 interest [1] 3/17
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inundated [1] 12/17
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getting [1] 12/24 [58]
Give [2] 5/23 6/6
issue [5] 11/9 13/13 14/8 14/11 14/12
given [1] 4/16 [22] [2] 8/11 15/7
its [11] 4/7 7/7 7/11 7/15 7/17 8/23
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Michael [2] 1/15 2/10
its... [5] 10/20 10/21 12/8 13/20 13/24
might
[3] 9/14 9/14 9/25
its [6] 4/3 5/3 5/17 14/9 15/2 15/15
minimum
[1] 10/7
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January [6] 2/23 2/25 4/13 4/13 7/20 months [6] 4/20 7/11 7/12 10/10 13/5
13/8
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more [8] 6/24 7/25 9/17 10/21 12/9
January [1] 2/23
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January [1] 4/13
morning
[7] 2/2 2/6 2/9 2/10 2/15 5/2
joint [1] 6/19
10/8
Jones [5] 1/20 1/23 17/2 17/13 17/14
most [1] 9/20
Joseph [1] 1/15
motion [2] 15/14 15/18
JUDGE [2] 1/9 1/10
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15/21
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parties [1] 2/4
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percentage [1] 7/2
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plaintiffs [1] 11/13
please [1] 2/5
point [2] 6/20 11/16
JUDICIAL [8] 1/3 1/12 2/3 2/7 2/8 6/21
position [11] 3/12 8/11 8/22 12/7
7/15 8/6
6/9 17/11
name
[2]
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judicialwatch.org [1] 1/14
narrow [1] 11/11
16/1
June [2] 1/5 17/11
9/13
necessarily
[1]
positions
[1] 12/21
just [14] 6/6 6/19 7/3 7/7 10/16 10/19
5/21 10/25 12/22 13/6
need
[4]
8/13
possible
[1]
10/23 11/2 12/22 13/12 13/15 14/23
2/22 3/8 3/10 3/13 3/18 7/24 power [1] 3/7
Nellie
[6]
15/4 15/15
new [1] 3/6
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JUSTICE [17] 1/5 1/16 2/4 2/11 2/13
1/4
[1]
predicate [2] 10/19 10/25
3/16 3/18 6/22 7/1 7/6 7/12 8/5 8/11
5/8
non
[1]
president [1] 3/9
13/14 14/9 15/15 15/17
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prior [3] 7/25 8/9 9/8
3/24
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not
[13]
prioritize [5] 8/24 9/3 9/22 13/14 15/24
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probably [1] 11/5
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know [8] 4/16 5/11 7/23 8/7 8/14 12/4 noted [1] 5/6
17/9
notes
[1]
proceedings [4] 1/24 16/7 17/5 17/8
12/5 15/17
3/9
4/23
12/10
now
[3]
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production [1] 4/3
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Programs [1] 1/16
law [4] 1/12 1/15 5/17 5/18
obtained [1] 3/20
project [1] 15/22
laws [1] 5/21
4/17
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obviously
[13]
proposal [3] 4/10 4/10 10/6
let [2] 6/4 8/10
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propose [1] 9/3
lets [1] 8/8
15/22 15/22
proposed [5] 4/9 4/19 8/24 10/9 11/9
like [5] 5/7 5/12 11/22 13/16 13/19
off [3] 10/3 13/22 15/25
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2/21
4/12
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office
[3]
provide [3] 5/21 9/14 9/14
limited [2] 5/19 12/15
1/21
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17/2
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official
[5]
provided [1] 13/7
4/17
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5/8
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litigation [4]
Ohr [8] 2/22 3/8 3/10 3/13 3/15 3/19
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7/24 8/10
publicized [1] 3/6
look [4] 9/9 9/12 9/19 13/21
2/14
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OIP
[6]
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OIPs [2] 4/16 6/1
put [1] 4/11
lot [3] 3/17 12/13 12/21
okay [4] 15/8 15/9 15/10 16/4
once [1] 11/6
one [6] 2/22 2/25 5/7 7/25 8/1 11/10
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5/19
only
[1]
quite [1] 5/1
make [3] 13/3 13/15 14/23
13/2
13/3
open
[2]
many [2] 5/9 5/15
opposing [1] 7/4
Marcia [1] 2/12
3/9
7/24
9/1
opposition
[3]
Ramona [2] 1/12 2/6
Massachusettts [1] 1/17
4/20
9/4
13/3
order
[3]
range [1] 4/13
matter [1] 13/4
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16/2
other
[4]
rationale [2] 8/8 8/12
14/18
matters [1]
our [9] 4/6 4/9 4/10 4/25 5/5 8/8 8/16 RBW [1] 1/4
may [3] 14/5 14/9 15/4
12/7 13/24
rcotca [1] 1/14
maybe [2] 9/9 11/2
4/24
14/7
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out
[3] [1] 2/3 [11] 2/11 5/15 5/18 5/20 5/23 6/4
over [2] 4/14 11/20
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6/4 6/6 9/16 10/17 12/10
reason [6] 3/25 4/1 9/7 9/25 10/6 11/9
mean [8] 7/3 10/5 11/1 11/2 11/22
reasonable [6] 7/16 7/17 7/25 14/13
12/21 12/23 15/14
4/25
page
[1]
14/20 14/25
Meaning [2] 2/18 5/4
pages [1] 17/7
reasonableness [1] 15/2
means [1] 5/21
part [7] 3/25 4/1 6/18 9/3 10/6 11/21
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some [4] 5/1 7/13 8/21 12/20
somebody [3] 5/15 6/4 12/18
received [1] 5/2
someone [1] 12/10
record [1] 2/5
something [7] 6/17 9/6 9/23 9/24 10/3
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15/11 16/2
records [20]
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REGGIE [1] 1/9
STATES [3] 1/1 1/10 17/3
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relationship [1] 3/14
10/8
remind [1] 13/16
Steele
[1] 3/5
report [6] 4/10 4/11 4/25 5/5 6/19 10/8
2/5 8/23
step
[2]
reported [1] 17/4
1/13
Street
[1]
Reporter [4] 1/20 1/21 17/2 17/14
4/19
subject
[1]
representatives [1] 5/13
7/8
submit
[1]
represented [1] 6/22
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request [19]
submitting [1] 15/20
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such [1] 6/23
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Suite [1] 1/13
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15/21
respond [1] 15/4
supports
[1] 16/1
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13/15
sure
[1]
right [8] 3/13 6/7 8/9 9/22 11/25 14/14 [1] 1/13
14/19 15/1
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Room [2] 1/21 1/22
RPR [2] 1/20 17/14
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take [7] 4/5 4/8 8/23 12/5 13/22 15/15
15/25
takes
[1] 9/2
said [4] 7/4 13/19 15/23 17/8
taking
[2] 10/2 13/20
satisfy [1] 3/23
6/4
talk
[1]
say [8] 6/16 6/21 9/23 10/24 12/11
6/14 9/10
team
[2]
14/21 15/10 16/1
5/15
tell
[1]
saying [4] 8/20 9/17 9/20 10/21
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search [45]
than [1] 7/25
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Thank [5] 6/16 13/10 14/3 16/5 16/6
searching [4] 7/14 10/1 12/2 15/24
that [99]
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seek [1] 8/8
14/10 14/11 15/8 16/2
seeking [2] 2/16 13/17
their
[2] 8/22 9/4
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them
[3] 6/13 11/20 13/20
SENIOR [1] 1/9
4/18 6/23 8/9 9/19 9/19 10/22
then
[8]
set [2] 4/24 12/7
11/6 11/6
she [5] 3/12 8/3 8/6 8/14 11/15
there [9] 4/8 8/17 9/7 9/24 11/16 14/15
shorthand [3] 1/24 17/5 17/9
14/15 14/23 15/20
should [7] 6/24 8/21 9/11 12/9 12/12
theres
[6] 3/17 5/4 5/6 6/23 12/12
12/13 12/16
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shouldnt [1] 16/2
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since [2] 10/8 12/8
Thereupon [1] 16/7
six [3] 4/19 7/11 7/12
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they [20]
small [1] 7/1
theyre [9] 6/3 7/13 8/19 11/4 12/11 [14] 2/20 3/16 4/5 4/13 7/11 8/8
12/18 13/24 15/16 15/18
8/11 8/23 9/3 10/18 12/14 12/20 12/22
think
[21]
15/14
third [2] 1/13 2/22
this [26]
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8/18 8/21 10/7 11/11 11/14 12/5 15/2
15/12
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Timothy [1] 2/13
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Tom [1] 2/7
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Trump [2] 3/6 3/9
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13/25
two [2] 13/4 13/8
U.S [4] 1/5 1/16 1/21 2/3
under [1] 5/5
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Understood [1] 15/3
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unduly [1] 7/17
UNITED [3] 1/1 1/10 17/3 [5] 6/4 9/6 11/9 11/15 12/13
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usdoj.gov [1] 1/18
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WALTON [1] 1/9
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was [20]
Washington [4] 1/5 1/13 1/17 1/22
WATCH [8] 1/3 1/12 2/3 2/7 2/8 6/21
7/15 8/6
way [3] 10/11 11/11 14/17 [33]
well [1] 10/12
were [6] 4/1 4/4 8/1 10/5 11/24 13/17
weve [7] 4/19 8/24 10/7 10/9 11/18
11/19 12/7
well [12] 4/9 4/24 6/18 8/19 9/13 10/24
11/15 12/2 13/17 13/18 14/3 14/4
were [2] 11/13 12/17
what [17] 2/15 2/25 3/12 7/4 8/24 9/11
10/11 10/20 10/24 11/8 11/18 12/5
13/4 13/22 14/13 14/19 16/1
whats [3] 3/2 4/22 6/5
whatever [1] 14/20
when [8] 4/14 7/8 8/6 8/14 12/3 12/4
12/9 12/18
where [1] 11/13
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While [1] 15/8
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11/25 12/18
whos [1] 12/11
why [6] 3/16 8/21 9/11 10/2 11/1 14/25
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11/17 11/20 12/4 12/5 13/16 15/6
15/23
Yeah [1] 11/8
year [3] 7/25 8/1 8/9
Yes [7] 2/19 5/24 6/9 14/6 15/6 15/10
15/12
yet [4] 4/6 5/18 6/21 11/23
you [36]
youre [7] 2/16 8/20 9/17 9/20 10/19
10/21 12/20
your [15] 2/2 2/10 3/25 4/24 5/11 6/1
6/6 6/9 7/8 8/16 10/15 13/10 14/7 15/4
16/6
yourselves [1] 2/5
Zeese [1] 2/13