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Judicial Watch • JW v State Cooper depo 01242

JW v State Cooper depo 01242

JW v State Cooper depo 01242

Page 1: JW v State Cooper depo 01242

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Number of Pages:55

Date Created:March 19, 2019

Date Uploaded to the Library:April 25, 2019

Tags:objection, planetdepos, blackberry, Pagliano, Justin, 01242, cooper, Clintons, Secretary, Hillary Clinton, State Department, FBI


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Transcript Justin Cooper
Date: March 14, 2019
Case: Judicial Watch, Inc. -v- U.S. Department State
Planet Depos
Phone: 888.433.3767
Email:: transcripts@planetdepos.com
www.planetdepos.com
WORLDWIDE COURT REPORTING INTERPRETATION TRIAL SERVICES
Transcript Justin Cooper
Conducted March 14, 2019
WILMER CUTLER PICKERING HALE
-----------------------------------------x
JUDICAL WATCH, INC.,
Plaintiff,
and DORR, LLP
1875 Pennsylvania Avenue,
INDEX NO: 14-01242 (RCL)
Washington, 20006
BY:
-against-
Defendant.
----------------------------------------x
VIDEOGRAPHER: DMITRY ZVONKOV
CHARLES SPETH, ESQ.
U.S. DEPARTMENT STATE, THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
DEPOSITION JUSTIN COOPER, taken Plaintiff, World Trade Center, New York, New York, on,
March 14, 2019, commencing 8:07 oclock a.m.,
before Christine Cutrone, shorthand (Stenotype)
reporter and Notary Public within and for the
State New York.
JUDICIAL WATCH
Attorney for Plaintiff
425 Third Street
Suite 800
Washington, 20024
BY: MICHAEL BEKESHA, ESQ.
RAMONA COTCA, ESQ.
JAMES PETERSON, ESQ.
WITNESS
JUSTIN COOPER
EXAMINATIONS
PAGE
MR. BEKESHA
No.
Description
interview was marked Plaintiffs
Exhibit 302 form the FBI
U.S. DEPARTMENT JUSTICE
Attorney for Defendant
new setup, was marked Plaintiffs
1100 Street
Exhibit
Washingtion, 20005
BY: ELIZABETH SHAPIRO, ESQ.
STEPHEN PEZZI, ESQ.
ROBERT PRINCE, ESQ.
E-mail Secretary Clinton about
E-mail was marked Plaintiffs
Exhibit
e-mail chain between witness and
Secretary Clinton from August 30th
and August 31, 2011 was marked
Plaintiffs Exhibit
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Justin Cooper
Conducted March 14, 2019 e-mail between witness, John
Davidson, Bryan Pagliano trying
resolve issue related
Secretary Clintons Blackberry was
marked Plaintiffs Exhibit e-mail from the witness
Secretary Clinton September
25th, 2009 was marked Plaintiffs
Exhibit two e-mails between witness and
Secretary Clinton dated September
29, 2009 was marked Plaintiffs
Exhibit two e-mails between witness and
Secretary Clinton June 2011
was marked Plaintiffs Exhibit e-mails regarding Secretarys
Blackberry failing, was marked
Plaintiffs Exhibit e-mail chain between you Huma
Abedin and Monica Hanley was
marked Plaintiffs Exhibit e-mails between myself, Bryan
Pagliano, Secretary Clinton and
Flores was marked Plaintiffs
Exhibit ABC News article written
Marcio Jose Sanchez entitled
Coming Hillary Clinton 2000
was marked Plaintiffs Exhibit HEREBY STIPULATED AND AGREED that the filing and sealing the within deposition be, and the same are hereby waived; FURTHER STIPULATED AND AGREED that all objections, except the form the question, and the same are hereby reserved the time the trial; FURTHER STIPULATED AND AGREED that the within deposition may sworn before any Notary Public with the same force and effect sworn before Justice this Court; FURTHER STIPULATED that the transcript certified the reporter;
THE VIDEOGRAPHER: This begins disk number one the videotaped deposition Justin Cooper the matter Judicial Watch, Inc., versus U.S. Department State the U.S. District Court for the District Columbia. Todays date March 14, 2019. The time the video screen 8:07 a.m. The videographer today Dmitry Zvonkov. The court reporter Christine Cutrone both with Planet Depos. This video deposition taking place Seven World Trade Center the 45th floor New York, New York.
Will counsel please identify themselves for the record.
MR. BEKESHA: Michael Bekesha behalf Judicial Watch.
MR. PETERSON: James Peterson behalf Judicial.
MS. COTCA: Ramona Cotca, Judicial.
MR. SPETH: Charles Speth behalf Justin Cooper.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Justin Cooper
Conducted March 14, 2019
MS. SHAPIRO: Elizabeth Shapiro behalf the Department State.
MR. PEZZI: Stephen Pezzi from the
Department Justice behalf the
Department State.
MR. PRINCE: Robert Prince from the
Department Justice behalf the
Department State.
THE VIDEOGRAPHER: Would the court
reporter please swear the witness. having first been duly sworn Notary Public, for and within the State New York, upon being examined, testified follows: EXAMINATION MR. BEKESHA: Good morning, Mr. Cooper. name Michael Bekesha. attorney for Judicial Watch. here ask you some questions about one Judicial Watchs Freedom Information Act lawsuits counsel Ms. Shapiro making objection, wait until theyre done speaking give your response. Make life lot easier the court reporter, because she can only take down one thing time.
With that out the way, have you
ever
created setup e-mail account for Hillary Clinton?
Yes.
How many e-mails accounts have you created setup? the best recollection two three.
When did you create the first one? cant speak. dont recall when the first would have been setup. But something that was used her blackberry device. youre referring some the use the servers that were later setup, believe that first e-mail address was setup 2009.
Was there e-mail address setup before that?
She was using blackberry that you against the State Department. Specifically questions about whether Secretary Clintons use private e-mail server was intended stymie FOIL. And whether the State Department was adequately searched the State Department adequately searched for records responsive Judicial Watchs FOIL request.
Before begin could you please state and spell your full name for the record? Justin Cooper J-U-S-T-I-N. Cooper C-O-O-P-E-R. Thank you. Also just like
over
few quick ground rules. Your counsel has -12 may have already talked you about them, but will help the deposition more smoothly. you dont hear one questions, please let know and Ill repeat it. you dont understand one questions, again, just let know and Ill try make clearer. Its important that you respond out loud opposed shaking your head even gestures, because the court reporter cannot record these sorts things. Finally its important that you wait until done asking question your 12) know, the blackberry service that time gave you the offer use blackberry internet service which was provided the wireless carrier and she had e-mail that service.
And you may have just helped set that up? may have set that up. dont recall.
And then the second one was the one @Clintonemail.com?
Correct.
And was there additional one additional others besides those? know one time changed her e-mail address the prefix her e-mail address the Clinton e-mail server domain.
That was maybe around 2013 after the Sidney Blumenthal e-mails made public?
That sounds correct. just wanted establish all kind know what e-mail addresses were talking about. Today our focus going the
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Justin Cooper
Conducted March 14, 2019 Clintonemail.com that she used during her tenure the State Department.
Regarding that e-mail account, you recall when you were first approached setup that Clintonemail.com e-mail account for Secretary Clinton? dont have, again, specific recollection when was had existing servers place for Presidents Clintons office. And somewhere either late early was discussion that occurred about creating e-mail address for Secretary Clinton. you recall who approached you about creating e-mail account? would have been discussion with Huma Abedin. you recall anybody else were those conversations?
Not particularly. you know how many conversations you may have had? idea. had another conversation with Huma. think there were some questions the robustness the setup that Secretary Clinton soon Secretary Clinton had and the number people who were aware her e-mail address and she was going change her e-mail address which certainly she could have done the existing setup that she was using. But was there some other solution that she might use. And somewhere that discussion ended with her coming onto the system that President Clintons office had setup. Just clear the existing system that she had that was the black ATT blackberry e-mail account -15 Correct. HR15? That sounds correct. When you had conversations about maybe putting Secretary Clinton the servers that were already setup for President Clintons office, was there discussion about what the e-mail address -22 what the domain name would for Mrs. Clinton? you know she approached you
before after Mrs. Clinton became secretary state? dont have any specific recollection when the conversations that heard. When she first approached you, what
was
the
conversation about? What did she ask you do? Thats ten years ago. dont know that remember the verbatim conversations. You know had these existing had existing setup for President Clintons office which maintained e-mail for his sort close cadre staff. some point had actually, following recommendation from when had spoken gentleman named Bryan Pagliano who was the head for the Clinton campaign. Both understand had any specific recommendations how might upgrade the system that were using for President Clintons office. And also learning that had surplus equipment that could purchase implement different system. That sort that somewhere those conversations may have (13 16) Yes. You know the dont think
she
was
going following the presidential campaign use PresidentClinton.com her domain. And, you know, tossed around various ideas what that could be. And, you know, the process doing that you online and see whats available. And, you know, that time, maybe different than today, there are people who use more creative domain names than others. Former late President Bush used something FLFW formally the free world. that makes representation. And there was choice whether youre going use something like that sort pretty straight forward. And however the discussions transpired, was obviously the result that she used something that was very obviously related her. you know who those were those conversations with you about the potential domain? Primarily between myself and Huma Abedin. you recall who came with
Clintonemail.com?
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Justin Cooper
Conducted March 14, 2019 dont specifically recall. said sure searched for various availabilities and combinations things and presented list and kicked around those names. Was that what was presented Mrs. Clinton? dont recall. you know she had any input what the creation the domain name was? dont recall. Did you register that domain name? believe so. you recall when you did so? believe was January 09. you know why -15
(Court
reporter needed plug
computer.) Repeat the question? dont recall where was going with that. you recall who created the how many e-mail accounts were oh, know what was natural flow things more than any dates certain that that was being prepared.
Okay. Thank you. you know that time Secretary Clinton was thinking about using State Department e-mail account? dont recall any conversations about that.
Did you have any conversations with Huma Abedin anyone else about using G-mail another more commercial server host Secretary Clintons e-mail? dont specifically recall any conversations like that.
Did you ever speak Huma about whether not the secretary wanted her e-mail private server? dont know dont know that those sort words that phrasing would have been used. think there was general understanding that had, for President Clintons office, the server setup. That was option where house e-mail account for Secretary Clinton. going ask. apologize. you know why the domain name was created that time? There was, you know, there was movement create new e-mail address for Secretary Clinton referred before which she could have clearly had one the ATT system, but was looking for something that was little bit more robust. And that was the timing around it. mean think there were several reasons why there was movement new e-mail solution sorts. Sure. was wondering little bit more specifically the timing.
Was there any significance the timing when the domain name was registered? You know dont secretary that
point
was preparing take the role secretary state. think was more about figuring out what her e-mail solution was going over that period time. Moving away from her existing address many people had acquired over the period the campaign. think that was just sort the (17 20) Were any other during those
discussions,
was there any discussion other individuals that would housed that same e-mail server same e-mail account? Well, again, President Clintons office was already using the server. that cadre individuals were the server using it. Sorry. Specifically Clintonemail.com. dont want get into what President Clintons servers were. dont know that time that
time dont know what other discussions there were. know ultimately both Huma Abedin and Chelsea Clinton had Clinton e-mail.com accounts. not sure when they first came requested began using that server. Would you have setup the e-mail accounts for Ms. Abedin and Chelsea Clinton? Myself and Bryan Pagliano. you know started asking this before and dont think followed through. you know who created the HDR22
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Justin Cooper
Conducted March 14, 2019 (21 24) alias e-mail address?
You know dont know how how was sort conceived speak why that option over others. You know sure some point the secretary was comfortable with that and would have chosen that address. you know you came with something that Ms. Abedin recommended? dont recall. Its possible.
Going back little bit, who did you you recall when you were thinking about putting Clintonemail.com Secretary Clintons e-mail even before name came the Apple server, did you talk anybody besides Ms. Abedin about that?
MS. SHAPIRO: Just object form.
Did you introduce Apple server? Did miss
something?
MR. BEKESHA: Thats fine. can
clarify. Not problem. refer Apple server. think thats the same thing that you were referring President Clintons server, that accurate? Before was created the process creating it. Primarily would have been Huma. you recall there was anybody else? dont recall conversations.
(FD 302 form the FBI interview was marked Plaintiffs Exhibit for identification, this date March
14, 2019.) Ill let you take minute look what has been marked Exhibit
(Witness peruses document.) Did you have chance look Exhibit Oh, yes.
MR. BEKESHA: For the record,
Exhibit appears 302 form
the FBI interview that happened
April 19th, 2016. Does that appear accurate? Yes. Not sure. view them both
President
Clintons servers. There were two servers. Maybe can stipulate that Apple server was the first server that was used, and then there was subsequent server which can call from various documents can refer the window server the Pagliano server. And just for clarification, the Apple server for the relevant time period that was existence for todays deposition maybe January 2009 March 2009? No. The Apple server was brought online June 2008. believe the time youre referring there when Secretary Clinton had e-mail account that went through that server. Okay. Thank you.
Before January 2009 right around then when you were thinking about putting e-mail account e-mail system the Apple server for Secretary Clinton, did you speak anybody else about that besides Huma Abedin? Sorry. You said before -22 Let direct your attention the
fourth
paragraph about four lines up. This redacted version, dont know who the interviewee some the names.
But want direct your attention the line that starts off with the redaction and says, blank recall the conversation with Huma Abedin and Cooper regarding the addition Hillary Clinton the Apple server; you see that? do. you know who that individual would
be?
MR. SPETH: Objection. Foundation. You may answer it. suspect its Doug Band. The next line says, blank thought
was
bad idea, but the issue had been decided that point time; you see that? Yes. assuming that blank there also Doug Band?
MR. SPETH: Same objection.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Justin Cooper
Conducted March 14, 2019 you know thats correct? appears that way. you recall conversation that included Doug Band about placing Hillary Clintons e-mail the Apple server? dont specifically recall conversation. Ill also note earlier that paragraph talks about 2006 and 2007, Justin Cooper obtained private e-mail server, the Apple server. think know from other facts thats well before the time period that actually occurred. Okay. you recall Mr. Band stating that thought was bad idea? dont recall that. you know why thought was
bad
idea?
MR. SPETH: Objection. Foundation. cant speculate that. Who Doug Band? colleague mine from time
working
for President Clinton. What was his did also work for meeting our needs almost from the start the robustness. way was successful because was working good solution, but there was demand and that would have quickly exceeded the capacity the server, wanted look for other alternatives. Was that because the use President Clintons office the use Secretary Clinton?
MR. SPETH: Objection. Compound.
You
can answer. The use President Clintons office. Thank you. dont want get into President Clintons use any the servers today, but just want make sure delineate and distinguish between issues and what was going dont have get into that material.
MS. SHAPIRO: Thank you. Well get into the Pagliano server couple moments. just want finish the Apple server first.
Once everything was transferred over President Clinton?
Yes. this January 2009 sorry 2009 time period, what was his role with President Clinton? not sure his exact title, but was senior advisor high level staff person for President Clinton.
Did interact with Secretary Clinton all? sure from time time, yes.
Did have any involvement with helping you create the e-mail system?
No.
Would did have any involvement helping manage the e-mail system?
No.
Thank you. When did the Apple server ceased used? the best recollection was early 2009 when made the transition the Pagliano server. And the Apple server wasnt really (25 28) the Pagliano server, what happened the Apple server? was repurposed used basically ordinary home computer the Clinton residence. Were there e-mails still the Apple server once everything was transferred over?
MR. SPETH: Objection. Foundation. You may answer the question. dont recall whether you know what material was retained that server. Was wiped -11 dont know whether was wiped. Sorry. problem. Was wiped clean before was transitioned into being used regular computer? dont recall. were wiped, was that something that you would have done?
MR. SPETH: Objection. Foundation. You may answer the question. Possibly. dont know.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Justin Cooper
Conducted March 14, 2019 you know that computer still being used the Clinton residence? have idea. now lets transition what referred previously the windows server the Pagliano server. going refer the Pagliano server just let you know.
When did you when was the first discussion was there discussion about transferring over from the Apple the Pagliano server?
Sorry, whats the...
When was the first conversation discuss the transfer? cant precise, but the Fall 08.
And whose idea was transfer system servers? mentioned before, dont think were satisfied with the performance the system that created the Apple server. And the prospect being able add users that end conversation was with Mr. Pagliano? mean you just trying pin down dates you can. understand. And cant remember. Again was ten years ago. Thank you. Just you know trying pin down you can. Understood. you recall when the some point you the Clintons purchased new equipment from Mr. Pagliano repurposed equipment from Mr. Pagliano use the server? Yes. The same timeframe. not sure that can precise all the sequencing, but once they were able decommission the pieces, you know, when paid and when reprogrammed them, cant speak the specific timeline around that. When was the when did the server operational? believe really didnt operational until March 09. And when went operational, what e-mail systems were placed that server?
keep with the changes, other changes that were
occurring technology the time. think its
hard for all sort take time warp back
and remember how often were changing devices
how the technology which now seems fairly rudimentary
was changing. And clearly saw that needed
proper blackberry server accompany the system.
And were looking for ways source that. And some conversation was recommended Bryan
Pagliano seeing how they talk him about how
they were running their e-mail system for the
campaign. Talking him resource. And that one those conversations dont know how
many there were. dont remember. made
aware they had surplus. They were going have
surplus equipment. And could repurposed
purchase from them. And think you answered this
previously, Ms. Abedin recommended was the one
that recommended you speak with Mr. Pagliano? Yes. you recall when your first (29 32) Sorry, can you when say e-mail
systems,
what are you referring to? was couple systems accounts President Clintons staff? Not the software. Not the software. Just trying
figure
out mean guess the problem have lot different terms going on. know. can very confusing. Just trying figure out -10 Things could called the wrong
terms. Yes. thank you.
MS. SHAPIRO: Are you excluding
President Clintons staff from your question?
MR. BEKESHA: fine with him
saying President Clintons staff well
the Clintonemail.com. just want -19 President Clintons staff was think the terms ported over the new server. their data was moved over. Their accounts were moved over
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Justin Cooper
Conducted March 14, 2019 the new server and Bryan managed that process and does that answer? does. Thank you. And what about Clintonemail.com? was also put the new server. you recall who specifically did that task? That would have been Bryan. When was transferred over, you recall what e-mail addresses existed the Clintonemail.com system? think calling sorry, just not rude -14 Correct terms. calling system think
misnomer. that domain maybe the proper terminology.
Secretary Clinton had the account that domain. And dont know when other people specifically came online, being the other two that recall Huma and Chelsea, when they had initial accounts that domain. You may answer the question. dont. doesnt surprise me. Who assume there was contract some sort with Mr. Pagliano? dont recall specifically contract, but there were terms that would be, you know, remunerated for the time put forth setting the server and ultimately managing it. And who would contractor and employee, who would have been working for? What specific entity? dont recall what specific entity would have been. But generally this was all paid for personally the Clintons. then there was specific entity not that was moved through and would have been the person who would have signed off that made those payments. Made sure those payments occurred. And would have been payments from maybe joint account between the two Clintons one specific? cant specifically recall. you know Mr. Pagliano did you ever talk Mr. Pagliano, have conversation with him about the fact that Secretary Clinton was going have e-mail account the Pagliano server? dont recall when the first time that conversation would have occurred. was proactive conversation not, dont recall. you recall during your conversations during this time period when you first spoke with him and was being setup, that you indicated that Secretary Clinton was going have e-mail account the server was building?
MR. SPETH: Objection form.
ahead. mean just dont have any recollection when that when became aware -17 when would have shared that.
Would you surprised learn that Mr. Pagliano didnt know initially that Secretary Clinton had e-mail account the server?
MR. SPETH: Objection form.
Foundation. (33 36)
MS. SHAPIRO: Objection relevance.
Did you during this initial time period, did you ever talk Mr. Pagliano about federal records retention issues? dont recall any conversations. What about any time during Secretary
Clintons
four terms, did you have any conversations with Mr. Pagliano about federal records, retention issues?
MR. SPETH: Objection.
MS. SHAPIRO: Objection. Four terms? Sorry. Four years.
MR. SPETH: Objection form. dont recall any specific conversations. Also let know you need break. Yeah, actually this perfect, since youre bringing up.
THE VIDEOGRAPHER: Were off the
record 8:37.
(Whereupon, short break was taken.)
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Justin Cooper
Conducted March 14, 2019
THE VIDEOGRAPHER: 8:46. the
record.
MR. BEKESHA: Great, thank you. MR. BEKESHA: Mr. Cooper, again, any point you need break, please let know. Were not going past oclock probably anywhere close, have little bit time. Thanks. Also feel free correct
terminology. dont know this stuff. And feel free educate and maybe others the room well. Dont hesitate Okay. let know.
MR. BEKESHA: going introduce
this now Exhibit
(E-mail Secretary Clinton about new setup, was marked Plaintiffs Exhibit for identification, this date March
14, 2019.) Just take moment look the too you are ready.
What did you mean this these two sentences? cant precisely recall how this was setup the time, but the setup would have the e-mails. This being this the new e-mail address, this the Apple server timeframe. The e-mails would the domain directed the Apple server. And the Apple server, the best recollection, forwarding along the e-mails secretary Clintons Blackberry e-mail address. And then the next part that would make her Blackberry e-mail address appear were representative the e-mail address the Clinton e-mail system that was linked here. some point did you make the Clintonemail.com account active that she could send from that e-mail account and not from the Blackberry account? believe so. you recall when that was? not. exhibit.
(Witness peruses document).
You had chance review the exhibit?
Yes.
Could you identify just briefly what has been marked Exhibit
Its e-mail from myself. Appears Secretary Clinton regarding new e-mail setup.
Thank you. The first line says, your new e-mail address has been created. you recall when specifically this was? dont specifically recall.
The next line is, youll receive mail your Berry that sent this address. this just you letting her know that e-mail address has been setup and shell start receiving e-mails?
Yes.
The next line is, right now you cannot send from this address. can make that active now (37 40)
Once the Clintonemail.com was setup the Apple server, what was your role with man did you manage the e-mail?
Can you explain what you mean managing? just trying figure out what your role was when came Clintonemail.com after was created?
Once was once individual account would have been created the server, really wasnt much manage. The user was had connectivity. Short problem with that connectivity was their own. you recall when you created Chelsea Clintons e-mail account?
MS. SHAPIRO: Objection. Relevance. dont. you recall when you created Huma Abedins e-mail account? dont recall. you recall time period was January February March April 2009?
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Justin Cooper
Conducted March 14, 2019 really dont recall. Thank you.
Were there ever connectivity issues with Clintonemail.com and the e-mail accounts associated with that domain name? Yeah. think there were over period time that both servers were place there were connectivity issues due wide variety causes. And how would you learn there were
problems? think just any would learn that theres problem. many cases something not working. Youre not getting your e-mail. Youre not connected sometimes. The connectivity issues were tied the service provider ATT Verizon whomever your device may connected to. Sometimes once were the Pagliano server, were the full Blackberry infrastructure which has its own components, sort out the ether that could fail and lack activity. Then there could have been something with the connectivity the servers
(Witness peruses document.) You had chance review Exhibit Yes. Could you identify what Exhibit is? What appears be? exchange e-mails between myself and Secretary Clinton. Thats for September 2009? Yes. Great. Thank you.
Going the first e-mail the chain the bottom one from Secretary Clinton? Correct. And this e-mail seemed guess you know what she referring that first e-mail where she says, message from last night, did you receive it? have idea. And your response her appears just explaining what maybe the issue was? Correct. Thank you. themselves that could have caused disruption.
And with Secretary Clintons e-mail account, did she ever have any problems connecting sending receiving e-mail accounts while her e-mail was the well just focus the Pagliano server now? dont specifically recall, but sure that there were instances where she had connectivity issues.
How would you find out about those issues?
Someone else would usually alert she would reach out some cases which were maybe perceived connectivity issues.
MR. BEKESHA: Why dont just
through series e-mails now. Ill
introduce them each separately make
easier everybody. But well through
them quickly. Mark this Exhibit
(E-mail was marked Plaintiffs Exhibit for identification, this date March 14, 2019.) (41 44)
MR. BEKESHA: Mark this Exhibit
(E-mail chain between witness and Secretary Clinton from August 30th and August 31, 2011 was marked Plaintiffs Exhibit for identification, this date March 14, 2019.)
(Witness peruses document.) Had you chance look over Exhibit Yes. And Exhibit appears e-mail
chain
between you and Secretary Clinton from August 30th and August 31, 2011? Appears that way, yes. What pad? pad was reference Secretarys iPad. Did you setup iPad for Secretary Clinton? dont recall setting iPad for her. you know who did?
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Justin Cooper
Conducted March 14, 2019
No, dont recall. you know when was setup? dont recall. seems the original e-mail completely blank. just want your response. says, got your e-mail. The system the iPad dag. that typo does that mean something? believe thats typo. you know what was supposed be? could speculate, but believe probably dead. you know says then continues, though can setup e-mail there youd like. Your HDR22Clintonemail.com backup your own server and should delivering your Blackberry. you know what e-mail you were saying you could setup the iPad? dont remember specifically the routed to, guess, Google infrastructure account versus Blackberry?
MR. SPETH: Objection form.
Mischaracterizes his testimony.
MS. SHAPIRO: Objection form.
You can answer the question.
Could you repeat the question?
Sure. can try and clarify.
You know some the FBI 302s theres discussions several individuals that when there were issues with the Blackberry with Secretary Clintons Blackberry, that there was separate G-mail account setup that was used for her communicate have e-mails. just trying wonder did you setup that account for her? dont specifically recall setting up, but the reference dont know that its fair say there was G-mail account setup for her that aware of. There was the ability route the server through G-mail infrastructure using her e-mail address, that she would still receive messages. sequencing here. Looking the date, this was during one the major storms the east coast. believe was Irene. And there were some outage. And the Secretary was using her iPad communicate. And think just saying here that her Blackberry back and running. Were you going setup the HR22@Clintonemail.com the iPad different e-mail account that time? dont recall.
MS. SHAPIRO: Objection form. dont recall what that, you know -12 that inference true. Did you ever create G-mail account for Secretary Clinton? dont recall specifically creating
G-mail
account for her. There was point time -17 subsequent time when used the Google mail infrastructure backup. dont recall creating G-mail address for her. there were issues with her
pertaining other outages, did some e-mails were (45 48) Okay. there wasnt separate and
distinct
HillaryClinton@G-mail.com that you know of? Not that know of. Okay. Thank you. Again thats probably lot confusion with lay people using trying talk technical. Right. Thank you. you know how often during her four years her e-mail address had routed through the G-mail infrastructure? believe that only happened once. Were you did you manage that? Did you set that up? dont recall whether wholly managed that, but was part the discussions around implementing that. Who else would have been part those discussions? Bryan Pagliano. Anybody else? Not that recall.
PLANET DEPOS
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Transcript Justin Cooper
Conducted March 14, 2019 Huma Abedin? May have been aware the ultimate result. there were issues with connectivity times, were you the first point contact Secretary Clinton was having issues? cant speak whether thats the case, but usually was maybe the ultimate point contact. Maybe came through would you
hear
from
Huma Abedin? Possibly. Was there anyone else Secretary Clintons staff that you may have heard from she was having issues with her e-mail? Its possible that came from others. When there were issues, did you help try fix those was somebody else somebody else responsible for trying fix the issues? think was circumstance circumstance consideration. was generally Huma Abedin and Monica Hanley.
Whos Monica Hanley? aide Secretary Clinton.
You dont know what her title was? not.
She was the State Department? believe so.
Thank you. Did Secretary Clinton use more than one Blackberry during the four years? Did she get Blackberries replaced?
Yes. She fairly regularly had Blackberries replaced.
And would you help her with that replacement process?
Sometimes.
What would that mean? What would you do? would have new Blackberry. Her data she liked make sure preserve her data. the data would backed usually desktop computer accessing the server. One time What you mean that, you could
elaborate? Your questions are vague terms what the problem was. depending what the problem was availability, may have reached out someone else solve it. may have been something simple pulling out battery and restarting device. may have been more complex problem. its hard say what the tasks were that were followed on. Who else would you reach out say
you
werent
available? Again Bryan Pagliano was the other person that had access the server could was server related where diagnosed something from the server. Was there anyone else that you recall? Not particularly. The secretary may have had some aide along her side that was helping implement whatever solution may have been. you recall who her aides were
during
that period time? (49 52) password setup activate the Blackberry. The Blackberry the new Blackberry someone puts sim card into it. Types that one-time password. And activates, communicates with the server and brings down information. And the other files that doesnt bring down, get moved back from the desktop computer. Where was this desktop computer located? varied depending who was assisting the process. What you mean that? she was replacing her Blackberry Washington DC, may have been someone helping her this from her home Washington DC. was with her New York, may have helped her New York it. varied from, best recollection, from time time. And what info data was transferred the desktop computer during this process?
MS. SHAPIRO: Object form.
You may answer.
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Conducted March 14, 2019
The theres program, Blackberry desktop program. not sure thats the exact name. That allows you chose which files can come down. typically people use complete backup the file. You could select things and out.
Would that include e-mails?
Could include e-mails.
And once the new Blackberry was and running, what happened that data that was the desktop computers? cant say any specific instance what happened them.
Did you ever use one your personal one your own desktop computers this?
Yes. you still have e-mails Secretary Clinton those computers?
No.
Did you turn those computers over the FBI any point?
Yes, did. you know they recovered any that Bryan Pagliano oversaw that functionality. you werent responsible for any the backup backup the server?
MR. SPETH: Object form. No. Did you know that Bryan Pagliano worked for the State Department? Yes. you know when started the State Department? dont know specifically when started. know was after the server was initially setup. While was State Department employee, was still under contract with the Clintons help manage backup, whatever was doing with the Pagliano server?
MR. SPETH: Objection foundation.
Form.
MS. SHAPIRO: Objection form. not sure that thats the right phraseology for it. think was quote/unquote e-mails off those computers? cant speak what they recovered. Was secretary Clintons e-mails backed once was the Pagliano server?
MR. SPETH: Object form. The Pagliano server had backup device. And what would that device backup would backup e-mails? Backup believe the entire server. Which may include e-mails? Would include e-mails. Thank you. dont know how backup devices work. just trying No, no. clarify. you know how often that server backed itself up? dont recall. you know was once day, once week once year? dont recall. That was something (53 56) under contract. But would from time time monitor, update, perform service the server and was compensated for the time that took that. know when you had testified before Congress there was lot interest about brute force attacks against the Pagliano server. not interested those attacks and arguing about what you meant that and not. know Congress seemed enjoy that lot. But was interested little bit your communications with the secret service.
How many times did you contact the
secret
service
about the Pagliano server and these issues?
MS. SHAPIRO: just going
object relevance. What prong the
permitted discovery this germane to?
MR. BEKESHA: goes part one
stymieing FOIL. Whether U.S. Government,
the secret service ever contacted and knew
about the information and whether not
was related other government agencies.
MS. SHAPIRO: Okay. ahead.
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Transcript Justin Cooper
Conducted March 14, 2019
object, because dont see that connection,
but ahead and ask him. Can you repeat it? just wondering how many times did you talk the secret contact the secret service when you had issue? Yeah. vaguely remember one two times. When you reached out the secret service, did they know that Secretary Clinton had e-mail account the server?
MR. SPETH: Objection foundation. dont recall. you know you informed the secret service any time that? dont recall whether did didnt. Okay. Thank you.
MR. BEKESHA: Just take quick two
minute break.
THE VIDEOGRAPHER: Were off the
record 9:09. This looks appears the same period one the storms where discussed earlier there may have been rerouting the domain through the Google infrastructure. And returning our native infrastructure, looked like there was need clear out some settings make sure that happening. Great. And who John Davidson? aide President Clinton. you know what his title was? dont know what his title was, sorry. Were there titles? (No response.) What was his role all this? How
does fit into Secretary Clintons e-mail? suspect was just close proximity her the time. you recall other instances where may have been involved helping out issues? Not specifically. you know was involved
(Whereupon, short break was taken.)
THE VIDEOGRAPHER: Back the record 9:14.
MR. BEKESHA: Great. Thank you.
Lets mark this Exhibit
(E-mail between witness, John Davidson, Bryan Pagliano trying resolve issue related Secretary Clintons Blackberry was marked Plaintiffs Exhibit for identification, this date March 14, 2019.)
(Witness peruses document.)
Did you have chance review the document?
Yes.
Could you identify for the record what has been marked Exhibit
Appears e-mail between myself, John Davidson, Bryan Pagliano trying resolve issue related Secretary Clintons Blackberry. you know what that issue was? (57 60) creating the e-mail account all?
No. discussions about creating e-mail account?
No. was more just one off person that may have been proximity that time?
Correct.
MR. BEKESHA: Were done with that
exhibit.
(E-mail from the witness Secretary Clinton September 25th, 2009 was marked Plaintiffs Exhibit for identification, this date March 14, 2019.)
Before get Exhibit Let just followup one quick question about the Google infrastructure. Was that something that was always place? guess dont really understand what and how works. Did store e-mails there? Was something that somebody could always the Google account and access e-mail any point was something that was turned and turned off when
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Conducted March 14, 2019 needed?
MS. SHAPIRO: Objection form.
MR. SPETH: Same objection. cant specifically recall the time how exactly this was setup. But Google offers the ability route the domain through their infrastructure and then, you know, you could have very much like the Apple server, theres possibility bouncing into the underlying Blackberry e-mail address something quick get around. cant speak whether anything was stored boxes that time. Was there ever discussion permanently stay the Google infrastructure? Not that recall. Now turning your attention what has been marked Exhibit
Have you had opportunity review it? have not.
(Witness peruses document.) Yes. had truncated message, you have click more, more for all the rest the message load in. Because all the e-mails are the server. youre just having send message from the device back the server say send the rest this message. Okay. every time this instance when Secretary Clinton got new Blackberry, did all her e-mails transfer from the server the new Blackberry?
MR. SPETH: Object form. cant say that all her e-mails came down. the best recollection, generally working with these devices, you dont you had ten years e-mails, theyre not all going load onto your Blackberry. They probably wont fit onto your Blackberry. Blackberry sends down from the server some group active e-mails recent e-mails. dont know how qualify it. Its not expertise. But the e-mails are all still resolving remaining the server. And during that time would have been for the most the And Exhibit appears e-mail
from
you Secretary Clinton September 25th, 2009? Correct. this talks about your new Berry set. this time did Secretary Clinton get new Blackberry? believe thats what its indicated here. Three lines down, messages from your old Berry are there, but read the text when you open message. What does that mean? When new Blackberry connects the Blackberry enterprise server, information brought from the server onto the Blackberry. Most information theres always some settings some lingering things that for some reason dont transfer over. usually had two-step process which was let the Blackberry enterprise server populate the new device, and then bring over select complete information from the previous device. here what this saying the message you ever (61 64) The Pagliano server. The Pagliano. For sure the Pagliano server. Were e-mails stored any point the Apple server was that dont recall.
MR. BEKESHA: Mark this Exhibit
(Two e-mails between witness and Secretary Clinton dated September 29, 2009 was marked Plaintiffs Exhibit for identification, this date March 14, 2019.)
(Witness peruses document.) Had you chance review Exhibit Yes. And Exhibit appears e-mail
chain
between you two e-mails between you and Secretary Clinton dated September 29, 2009? Correct. Great. the message, you state theyre all backed the server. The easiest and quickest way log the web mail server.
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Conducted March 14, 2019 you know Secretary Clinton ever used the web mail server? dont recall. Did you ever walk her through the process? dont recall did didnt. you know anybody accessed Secretary Clintons e-mails through the web mail server? dont recall. Also this e-mail you say, your old Berry has messages backed August 29, 2009, and then only saved messages prior that. thats what were just talking about before that the berry the Blackberry only maintains more recent some e-mails? Right. Correct. But everything was still contained the Pagliano server? Correct.
MR. BEKESHA: Introduce this
Exhibit Thats understanding.
(E-mails regarding Secretarys Blackberry failing, was marked Plaintiffs Exhibit for identification, this date March 14, 2019.)
(Witness peruses document). All set? Yes. Could you just identify Exhibit for the record? Series e-mails regarding Secretarys Blackberry failing not working including Huma Abedin and Monica Hanley chain e-mails. Thank you.
Who Monica Hanley? Shes aide Secretary Clinton. you know when you communicated her with her what e-mail address you used for her? dont recall. Part the e-mail address redacted here. you know that personal e-mail
(Two e-mails between witness and
Secretary
Clinton June 2011 was marked Plaintiffs Exhibit for identification, this date March 14, 2019.)
(Witness peruses document). Could you just identify Exhibit for
the
record
please? Its two e-mails between myself and Secretary Clinton June 2011. And again this appears e-mail exchange regarding getting Secretary Clinton new Blackberry? Correct. And again just want emphasize were all clear, one your lines all your older messages will remain the server? Correct. Thats the Pagliano server? Correct. Its your understanding that throughout the four years her tenure, all e-mails were maintained the Pagliano server? (65 68) account State Department e-mail account? dont know. Did Monica Hanley have e-mail address Clintonemail.com? dont recall she did. And again, just for the record, know
this
getting tedious and apologize, but for the second e-mail the chain says, all your info the server, which you can access any web enabled assume thats device something there. But thats the Pagliano server? Correct.
MR. BEKESHA: And just hand out one
more e-mail this grouping.
(E-mail chain between you Huma Abedin and Monica Hanley was marked Plaintiffs Exhibit for identification, this
date March 14, 2019.)
(Witness peruses document.) Have you had opportunity look it? Yes.
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Conducted March 14, 2019 And just for the record, Exhibit appears e-mail chain between you, Huma Abedin, Monica Hanley, and the beginning Secretary Clinton around January 20th and January 21st, 2012? Yes. Looking the second e-mail the first page, the e-mail from Huma you and Monica says, Huma writes, she wants print her pictures and memos before switch Berries she can sure she has them. She also told she wants get everything the new Berry especially her saved e-mails. you know what memos the e-mail referring to? would assume pictures and memos.
Memos app the Blackberry. not sure that thats anything more than notes she may have kept that app. fair speculate that, dont believe that refers cant really speak that refers something more complicated than that. inclination here memos being the notes that are kept the memo pad app the phone. myself, Bryan Pagliano and some Secretary Clinton Oscar Flores relating looks like secretary having some trouble with her Blackberry.
And who Oscar Flores?
Oscar Flores the Clintons house
manager
Chappaqua.
What does that mean?
Hes their household staff person.
What was his role Clintonemail.com domain name and e-mail address it?
MR. SPETH: Object form.
MS. SHAPIRO: Object form. dont believe had any, you know, specific role the involvement this. may have been user the system. believe was the user the system. Generally knew how use the Blackberry.
And the system, you mean the Pagliano server?
Server. Sorry. not Clintonemail.com e-mail account? you know those memos were
transferred
from one Blackberry another? memos, mean the notes the memos app? think there was obviously reading this there was conscious effort make sure that was happening here. you know those notes the information contained within the memos app was the Pagliano server backed saved? dont know. dont recall.
(E-mails between myself, Bryan
Pagliano,
Secretary
Clinton and Flores was marked Plaintiffs Exhibit for identification, this date March 14, 2019.)
(Witness peruses document).
Did you have opportunity review the exhibit? Yes. Could you just briefly identify the exhibit for the record? Its series e-mails between (69 72)
Correct. the best your knowledge? the best knowledge, had presidentclinton.com e-mail.
Would help secretary Clinton problems came with her e-mail account?
Sure. From time time.
Was similar John Davidson where she was -Proximity? proximity?
MR. SPETH: Object form. would say proximity accurate. guess one, two other questions from this.
Bryan Pagliano the last e-mail says, need put policies for iPhone and iPad use like password expiration and complex requirements. you know what meant that?
Over the course lifetime the server, Bryan was consistently recommending new policies that would keep even more secure. And
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Conducted March 14, 2019 the technology itself was evolving, providing new opportunities that. When started off with the server there were users iPhones and iPads. And think you get this timeframe 2012 those devices start become more ubiquitous, and cant recall who how many users would have been using those devices, but certainly would have wanted those sorts policies people were starting use those devices the system.
Was this more concern because Secretary Clinton was using the server and these systems for her e-mail usage? dont know was more less specific her. Just the general protection the system whole all the users. some point was the Pagliano server stopped being used? That was really poorly worded question.
Rephrase please.
Absolutely.
Sometimes just comes out and you think what. reports, know that e-mail account was transferred some point. believe was called PRN.
Plat River Networks believe? believe thats correct.
Did you have any role whatsoever during that transition process?
You know turned over credentials for the servers that could accessed the transition, but, believe, thats the extent participation the process.
Did you you know Monica Hanley some point archived e-mails during this time period?
MR. SPETH: Object form and
foundation.
MS. SHAPIRO: Objection.
Ill just more specific. Secretary Clintons e-mails?
There was dont know was related that transition. There was point when Monica Hanley was trying create offline archive
Was there end date when the Clintons stopped using the Pagliano server have their e-mail it?
There was. dont know the specific date, but there was. you know approximate dates? believe was approximately the summer 2013.
And why was the server why did they transition away from the Pagliano server? cant really speak the reasons why that was occurring. really wasnt very much part that process. was transitioning out many roles with President Clinton that time, and didnt take the duty trying figure out what the next incarnation that this was going be.
Were you involved any early discussions about what would next?
Not particularly that recall. you know where the e-mail was transitioned after the Pagliano server? understand, from reading news (73 76) Secretary Clintons e-mails. you know when that was taking place? cant precise. believe was the Spring 2013, but not sure that thats accurate. you know Secretary Clinton was still office when Monica when Ms. Hanley was that was that correct time, she would have been office.
Did you help her with that process?
Yes, some extent.
What you know mean that? mean walked her through over the phone that process and had supplied computer from President Clintons office for her use try achieve that.
And you know she was successful? not. you know what anything was transferred onto that computer? not.
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Transcript Justin Cooper
Conducted March 14, 2019 you know what happened the Pagliano server after was done being used. not. certainly read news reports that had different things, but had personal knowledge what happened the server.
Did you ever talk Mr. Pagliano about what happened that server?
No.
Are you possession any Secretary Clintons e-mails?
No.
Have you turned strike that.
Did you turnover any e-mails Secretary Clinton the FBI?
Yes. turned over those materials the FBI.
Did they return those you?
They did not.
Prior turning material over the FBI, did you delete any Secretary any Secretary -21 e-mails Secretary Clinton that you had saved any your computers? discussions with her about that. Why you believe that how you know that? Limited universe people that would have that discussion. briefly touched the brute force attacks.
Did Secretary Clinton know those were taking place when they were?
MS. SHAPIRO: Object form.
Objection relevance.
MR. SPETH: Objection form. Did you speak Secretary Clinton about those issues? dont recall speaking her about those issues. any point during her four years, did you ever talk Secretary Clinton about transitioning another e-mail account system?
MS. SHAPIRO: Objection form.
MR. SPETH: Objection form
account system. No. weve talked lot about lot different issues today. just have couple questions that didnt follow through on. talked about the creation the system.
Was Secretary Clinton part any
those
discussions?
MR. SPETH: Objection form.
MS. SHAPIRO: Objection form.
Vague.
MR. SPETH: Vague system.
MR. BEKESHA: can rephrase. Did Secretary did you have any conversations with Secretary Clinton about the creation the domain name Clintonemail.com? dont recall specifically whether had conversation with her that that was relayed through others. you know anybody else had conversations with Secretary Clinton about the creation the domain name Clintonemail.com? believe Huma Abedin had some (77 80) You can answer. actually not sure what youre asking. Sure. guess the question is, some point she transitioned from the Blackberry ATT the system that was the Pagliano server.
Was there any discussions with her move her e-mail account something that wasnt the Pagliano server? Not that was part of. Did you have any conversations with
anyone
else about changing her e-mail account moving away from the Pagliano server during the four years? Not that recall. you believe that Secretary Clinton
should
have used the State Department e-mail account? Thats not for opine on. you know did you know that she was using her Clintonemail.com e-mail account conduct State Department business? not sure that thats something
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Conducted March 14, 2019 that knew could determine. Were you concerned all about record retention related Secretary Clintons work related e-mail accounts work related e-mails?
MS. SHAPIRO: Objection. Thats
outside the scope the deposition. You may answer the question. Could you repeat the question again? Yeah. Did you have any concerns about record retention issues related Secretary Clintons work related e-mails? viewed her usage this was her personal e-mail account. Wasnt really focused what the content her e-mail was the extent she was using it, youre suggesting for work purposes. Did you ever see Secretary Clinton use carry more than one device time? Yes. What other devices would she use? recall her least the earlier days using flip phone. flip phone while she was secretary state? dont recall when she stopped started using the flip phone. you know she continues use flip phone this day? not know. you know she would times carry flip phone, Blackberry and iPad while she was secretary state? cant say. Did you ever see her carrying Blackberry and iPad the same time? not sure ever recall seeing her carry iPad. But she had one that she used
occasionally? Yes. you know who Cheryl Mills is? Yes. Who she? She long time associate the Clintons. Attorney for them. Secretary Clintons you recall what that time period
the
earlier
days would be?
MS. SHAPIRO: didnt hear you say
what phone?
THE WITNESS: flip phone.
MS. SHAPIRO: Flip phone. Sorry. not. you know she used flip phone while she was secretary state?
MR. SPETH: Lets off for minute.
THE VIDEOGRAPHER: Were off 9:46.
(Whereupon, short break was taken stop the noise construction going the next room.)
THE VIDEOGRAPHER: This begins disk
number the deposition Justin Cooper.
Were the record 9:52.
MR. BEKESHA: Great. And think had open question before all the banging started. Ill just back that. you know Secretary Clinton used (81 84) chief staff. Friend mine. Did you have any conversations with Cheryl Mills about the Clintonemail.com domain name during the relevant period end 2008, early 2009 and Secretary Clinton leaving office?
MS. SHAPIRO: Objection form. dont know that can specify dates, but some point had conversation with Cheryl Mills about the general setup the system. She asked could give her brief description the setup the system. you recall Secretary Clinton was still was secretary state that time? dont recall that timing of. you know was earlier, later? mean any type timing. know its tough. Its been couple years. really dont recall. What are the timeframes again? guess wondering was either before she was secretary state, while she was secretary state post being secretary state.
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Transcript Justin Cooper
Conducted March 14, 2019 can answer that. had conversation with Ms. Mills regarding just the quick explanation the set the server. After she was secretary state think when the first public stories appeared about the server.
And you recall any conversation about the server the domain name prior that conversation? dont recall any. little bit earlier you mentioned that there was limited universe individuals that would have types conversations with Secretary Clinton. You mentioned Huma Abedin was one those people.
Were there any other individuals that you would consider part limited universe?
MR. SPETH: Objection form.
Vague. dont know can answer that. Relation
Relation the topics were talking about today. says that then Senator Clinton said 2001, much Ive ever been investigated and all that, you know, why would dont even want why would ever want e-mail? And then can you imagine? you see that? Yes. Were you working for the Clintons 2001? sorry. not clear you added some words The next paragraph says, can you imagine. You added words the beginning. You said then Secretary Clinton. just not confused what timeframe this paragraph referring to. Okay. the paragraph before the article talks about footage from 2001 report talking about this discussion. Right. And guess question is, were you working for the Clintons between 2000, 2001?
MR. SPETH: Same objection.
MS. SHAPIRO: Objection form. cant really say who she spoke about this.
(ABC News article written Marcio Jose Sanchez entitled Coming Hillary Clinton 2000 was marked Plaintiffs Exhibit for identification, this
date March 14, 2019.)
(Witness peruses document.) Had chance read? Yes.
MR. BEKESHA: For identification
purposes, Exhibit appears ABC
News article written Marcio Jose
Sanchez entitled Coming Hillary Clinton 2000. Why would have ever wanted
e-mail. Does that seem accurate? Yes. just want turn your attention
real
briefly the fourth paragraph. the article (85 88) Yes. Sorry, the underlining section here not part the story? that like insert link? think could be. Did read that correctly? think so. Trying print things
can little bit challenge. apologize. youre reading this going from paper trail much. Yes.
Have you ever heard this quote before? No. Were done with that exhibit. few last questions, then well take another short break and then well wrap up.
Besides counsel, have you spoken
anyone
today
about your testimony?
MR. SPETH: Object form. Has
spoken anybody today?
MR. BEKESHA: About testimony today. Have you spoken anybody about the
fact
that
you were testifying today, besides counsel,
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Transcript Justin Cooper
Conducted March 14, 2019 because dont want get into those privileged conversations? Yeah, no, just generally made some people close aware scheduling, being unavailable today for testimony. Have you talked them about substance? No. Have you spoken Secretary Clinton, President Clinton, Ms. Abedin anyone else since the news broke about this issue, about the issues weve talked about today?
MS. SHAPIRO: Objection form.
MR. SPETH: Object form news
broke. Since the New York times article 2015, have you ever spoken Secretary Clinton, President Clinton, Ms. Abedin about the issues weve talked about today since 2015?
MR. SPETH: Same objection. that group, Ive spoken President Clinton. discussion. you know what you talked about? Not substantively. Just the timing things. preparing for todays testimony, did you review any documents records? reviewed the 302s that were released the FBI. interviews well reviewed the transcript congressional testimony. And materials which your office provided like day yesterday. Did you only testify before Congress one time? Correct. the best your knowledge, have
all
your
answer been truthful today? Yes. Secretary Clinton, Present Clinton anyone affiliated with them paying your legal bills related this matter any other matters concerning Secretary Clintons e-mail usage?
MR. SPETH: Object form. Vague. What did you talk President Clinton
about?
What did you discuss? one point just asked for brief description what the server was. Was that the extent the conversation? Yes. Have you talked any those individuals lawyers about the issues talked about today? You know Ive spoken Cheryl Mills she was serving their lawyer general capacity. How many times have you spoken Ms. Mills about the issue? About the issue, couldnt say.
MR. SPETH: Object form what
the issue. About the domain name, the e-mail accounts and the issues discussed today. couldnt say. speak friends more than anything else. sure its come (89 92) Sorry. Could you repeat the question? Sure. Secretary Clinton, President Clinton anyone associated with them paying your legal bills for today any other matters related Secretary Clintons use e-mail?
MR. SPETH: Same objection. relation today its unclear Ill reimbursed for these for legal fees from the Clintons. previous legal fees about year after the conclusion the congressional testimony through lawyers was negotiated for settlement for the Clintons make payment. When you refer Clintons, that Clinton executive service the Clintons personally? dont know what entity took care that. you dont know its President Clinton, Secretary Clinton them jointly? dont know. Besides what just discussed, has Secretary Clinton, President Clinton anyone associated with them provided you with any additional
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Conducted March 14, 2019 financial incentives related todays testimony the e-mail matter more generally?
MS. SHAPIRO: Object form.
Mischaracterization.
MR. SPETH: Same objection.
No. Now that are about ten years later, you regret setting the Clintonemail.com domain name and the e-mail addresses?
MS. SHAPIRO: Objection relevance.
MR. SPETH: Objection form. You can answer the question. dont think opinion matters here. But you regret it?
MS. SHAPIRO: Same objection. Again, dont think opinion matters here. Could you answer the question please? dont regret it. Thank you.
MR. BEKESHA: Lets take very short
break and should all set. all? made her aware that was scheduled. That was it? Yes. Did you have conversations with her before you testified before Congress? dont recall. Did you have any conversations with her before you spoke with the FBI? certainly dont recall. you know you ever talked Ms. Mills about what you were going testify about what you were going tell the FBI? Thats not something that would have shared. When did you last speak with Ms. Abedin? idea. Not recently? Not recently. Have you spoken Secretary Clinton
THE VIDEOGRAPHER: Were off the
record 10:04.
(Whereupon, short break was taken.)
THE VIDEOGRAPHER: Back the record 10:12.
Thank, Mr. Cooper. Just very few more. you know Heather Simonson?
Yes.
Who she?
Shes woman who over the years worked for Secretary Clinton. not sure what specific capacities. you communicate with her? sure have some point time.
Did you ever communicate with her about Secretary Clintons e-mails?
Not that recall.
When did you last speak with Cheryl
Mills?
Last week.
Did you talk about this deposition (93 96) recently?
No.
Have you spoken with President Clinton recently?
Just the end last year.
Anything related e-mails?
Not all.
MR. BEKESHA: have other
questions.
MS. SHAPIRO: have questions.
MR. SPETH: questions.
THE VIDEOGRAPHER: This concludes
todays proceeding. The total number
disks used were two. Were off the record 10:14.
THE COURT REPORTER: Are you getting transcript?
MR. SPETH: Yes, please.
MR. BEKESHA: Well take rush
service.
THE COURT REPORTER: Youre talking about expediting?
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Conducted March 14, 2019 (97 100)
MR. BEKESHA: Yes.
MR. PEZZI: ordering the
transcript.
(Time noted: 10:15 a.m.)
ACKNOWLEDGMENT DEPONENT JUSTIN COOPER, hereby
acknowledge that have read and examined the
foregoing testimony, and the same true, correct
and complete transcription the testimony given and any corrections appear the attached Errata
sheet signed me.
STATE NEW YORK ss.:
COUNTY NEW YORK
CERT IFICAT CHRISTINE CUTRONE, Shorthand Reporter and Notary Public within and for the State New
York, hereby state:
That the witness whose examination herein
before set forth was duly sworn and that such
examination true record the testimony
given such witness. further state that not related any these parties this action blood
marriage, and that not any way interested the outcome this matter. WITNESS WHEREOF, have hereunto set
hand this 19th day March, 2019.
Reading and signing was not requested.
___________________
CHRISTINE CUTRONE
________________ _________________________________
(DATE)
(SIGNATURE)
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Transcript Justin Cooper
Conducted March 14, 2019
abc
6:5, 86:5,
86:14
abedin
5:21, 13:16,
16:20, 19:9,
20:13, 20:18,
21:8, 21:14,
22:21, 24:7,
30:19, 49:1,
49:11, 51:1,
67:13, 68:15,
69:3, 78:22,
85:13, 89:10,
89:18, 95:18
abedins
40:19
ability
47:20, 61:6
able
29:22, 31:14
about
4:14, 9:21,
10:2, 10:13,
12:22, 13:11,
13:13, 14:7,
15:18, 15:21,
16:18, 18:18,
19:4, 19:6,
19:9, 19:14,
21:11, 21:14,
22:18, 22:21,
24:2, 25:4,
25:8, 29:9,
30:10, 33:3,
34:3, 36:3,
36:6, 36:8,
37:18, 42:10,
56:5, 56:7,
56:12, 56:20,
60:3, 60:16,
62:5, 65:15,
74:18, 77:7,
78:2, 78:5,
78:14, 78:20,
79:1, 79:14,
79:15, 79:18,
80:12, 81:2,
81:9, 84:3,
84:9, 85:5,
85:7, 85:22,
86:4, 87:18,
87:19, 88:17,
88:20, 88:21,
89:6, 89:11,
89:12, 89:18,
89:19, 90:2,
90:9, 90:15,
90:16, 90:19,
91:2, 92:9,
93:7, 94:17,
94:22, 95:13,
96:22
absolutely
73:20
access
50:14, 60:21,
68:9
accessed
65:7, 75:9
accessing
51:22
accompany
30:7
account
11:6, 13:3,
13:5, 13:14,
15:14, 19:5,
19:22, 20:4,
22:15, 22:19,
33:18, 34:4,
34:12, 34:20,
35:20, 39:17,
39:18, 39:19,
40:10, 40:15,
40:19, 42:3,
46:9, 46:14,
46:17, 47:1,
47:13, 47:16,
47:19, 57:11,
60:1, 60:4,
60:21, 68:1,
71:22, 72:6,
75:1, 79:19,
79:22, 80:8,
80:12, 80:17,
80:20, 81:13
accounts
11:9, 17:22,
20:14, 20:18,
32:3, 32:22,
33:22, 41:4,
42:4, 81:4,
90:20
accurate
21:22, 23:21,
72:13, 76:6,
86:19
achieve
76:17
acknowledge
98:3
acknowledgment
98:1
acquired
18:21
act
9:22
action
99:14
activate
52:1
activates
52:4
active
38:22, 39:17,
63:17
activity
41:21
actually
14:14, 25:11,
36:18, 80:2
add
29:22
added
87:9, 87:13
addition
24:8
additional
12:12, 12:13,
92:22
address
11:18, 11:20,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
12:15, 13:12,
15:5, 15:6,
15:21, 18:5,
18:21, 21:1,
21:6, 38:11,
38:16, 38:18,
38:22, 39:7,
39:11, 39:13,
39:14, 46:20,
47:22, 48:10,
61:10, 67:19,
67:21, 68:4,
71:10
addresses
12:21, 33:10,
93:9
adequately
10:4, 10:5
advisor
26:7
affiliated
91:19
after
12:17, 14:2,
40:7, 55:12,
74:21, 77:2,
85:3, 92:10
again
10:17, 13:7,
20:5, 31:4,
37:5, 48:4,
50:13, 66:10,
66:14, 68:6,
81:8, 84:19,
93:16
against
1:8, 10:1, 56:6
agencies
56:21
ago
14:9, 31:4
agreed
7:1, 7:5, 7:8
ahead
34:14, 56:22,
57:2
aide
50:19, 51:4,
Transcript Justin Cooper
Conducted March 14, 2019
59:9, 67:17
aides
50:21
alert
42:12
alias
21:1
all
7:5, 12:20,
26:10, 30:3,
31:13, 35:13,
59:15, 60:1,
63:2, 63:3,
63:8, 63:11,
63:14, 63:19,
64:21, 66:15,
66:21, 67:7,
68:8, 73:15,
81:2, 82:20,
87:2, 91:16,
93:22, 95:1,
96:7
allows
53:3
almost
27:1
along
39:10, 50:19
already
10:13, 15:20,
20:6
also
10:11, 14:19,
24:20, 25:7,
25:22, 33:5,
36:17, 37:10,
65:11, 69:10
alternatives
27:6
always
60:17, 60:20,
62:16
another
15:1, 19:10,
70:2, 79:19,
88:15
answer
24:14, 27:11,
28:8, 28:21,
33:2, 35:1,
47:6, 52:22,
80:1, 81:7,
85:1, 85:19,
91:16, 93:12,
93:18
answered
30:18
any
7:10, 14:4,
14:17, 17:8,
18:14, 19:1,
19:6, 19:8,
19:12, 20:1,
20:2, 26:12,
26:15, 27:14,
34:15, 36:5,
36:6, 36:7,
36:15, 37:5,
41:12, 42:3,
53:11, 53:20,
53:22, 55:2,
57:15, 60:21,
64:4, 68:9,
71:13, 74:17,
75:6, 77:9,
77:13, 77:20,
77:22, 78:6,
78:13, 79:17,
80:7, 80:11,
81:9, 84:2,
84:16, 85:6,
85:9, 85:15,
90:8, 91:6,
91:20, 92:4,
92:22, 95:9,
98:6, 99:13,
99:15
anybody
13:17, 21:14,
22:20, 23:4,
48:21, 65:7,
78:19, 88:19,
88:21
anyone
19:9, 49:13,
50:17, 80:12,
88:17, 89:10,
91:19, 92:3,
92:21
anything
61:11, 69:17,
76:20, 90:22,
96:6
anywhere
37:7
apologize
18:1, 68:7,
88:7
app
69:16, 69:18,
69:22, 70:3,
70:8
appear
23:21, 39:13,
98:6
appeared
85:5
appears
23:18, 25:2,
38:8, 43:5,
43:19, 44:11,
44:14, 58:18,
59:1, 62:1,
64:16, 66:10,
69:2, 86:14
apple
21:13, 21:16,
21:20, 22:3,
22:8, 22:12,
22:19, 24:9,
25:5, 25:9,
26:18, 26:22,
27:21, 28:1,
28:5, 29:10,
29:21, 39:7,
39:9, 40:2,
61:8, 64:5
approached
13:4, 13:13,
14:1, 14:6
approximate
74:6
approximately
74:7
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
april
23:20, 40:22
archive
75:22
archived
75:13
arguing
56:7
around
12:17, 16:4,
17:4, 18:9,
22:17, 31:16,
48:17, 61:11,
69:4
article
6:5, 86:5,
86:15, 86:22,
87:18, 89:16
ask
9:21, 14:7,
18:1, 57:2
asked
84:10, 90:3
asking
10:22, 20:20,
80:3
assisting
52:11
associate
83:21
associated
41:5, 92:3,
92:22
assume
35:3, 68:10,
69:15
assuming
24:20
att
15:13, 18:7,
41:16, 80:5
attached
98:6
attacks
56:6, 56:7,
79:7
attention
24:1, 24:5,
Transcript Justin Cooper
Conducted March 14, 2019
61:16, 86:21
attorney
2:4, 2:15,
9:20, 83:22
august
4:20, 4:21,
44:3, 44:4,
44:13, 65:12
availabilities
17:2
availability
50:5
available
16:6, 50:12
avenue
3:4
aware
15:4, 30:15,
34:16, 47:20,
49:2, 89:4, 95:2
away
18:20, 74:10,
80:13
back
21:10, 30:3,
46:6, 52:6,
58:2, 63:4,
82:20, 94:4
backed
51:21, 54:3,
54:18, 64:21,
65:12, 70:9
backup
45:17, 46:19,
53:4, 54:6,
54:8, 54:9,
54:10, 54:13,
55:3, 55:16
bad
24:17, 25:13,
25:16
band
24:15, 24:21,
25:4, 25:12,
25:19
banging
82:20
basically
28:3
battery
50:7
became
14:2, 34:16
because
10:20, 11:3,
27:2, 27:7,
57:1, 63:2,
73:10, 89:1
become
73:5
been
9:12, 11:15,
13:15, 19:18,
23:3, 23:12,
24:17, 33:8,
35:10, 35:13,
35:16, 35:19,
38:7, 38:11,
38:18, 40:10,
41:21, 48:18,
49:2, 50:6,
50:8, 50:20,
52:14, 58:17,
59:3, 59:20,
60:7, 61:17,
63:22, 71:15,
73:6, 76:10,
84:17, 87:2,
91:16
before
1:17, 7:9,
7:11, 10:7,
11:21, 14:2,
18:6, 20:21,
21:13, 22:17,
22:22, 23:1,
25:11, 28:14,
29:19, 56:4,
60:15, 65:15,
69:9, 82:20,
84:21, 87:17,
88:11, 91:12,
95:7, 95:10,
99:10
began
20:15
begin
10:7
beginning
69:3, 87:13
begins
8:1, 82:15
behalf
8:17, 8:19,
8:21, 9:2, 9:4,
9:7
being
9:14, 19:2,
28:15, 29:2,
29:22, 33:20,
34:10, 39:6,
69:21, 73:17,
77:2, 84:22,
89:4
bekesha
2:8, 4:4, 8:16,
9:18, 9:20,
21:18, 23:17,
32:17, 37:3,
37:4, 37:16,
42:15, 44:1,
56:17, 57:19,
58:4, 60:9,
64:7, 65:21,
68:13, 78:12,
82:18, 86:13,
88:20, 93:21,
96:8, 96:19,
97:1
believe
11:18, 17:12,
17:14, 22:13,
31:19, 39:20,
45:10, 45:13,
46:3, 48:12,
51:8, 54:10,
62:8, 69:19,
71:13, 71:15,
74:7, 75:2,
75:4, 75:5,
75:10, 76:4,
78:22, 79:2,
80:16
berries
69:9
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
berry
38:16, 62:5,
62:11, 65:12,
65:15, 69:11
besides
12:13, 21:14,
22:21, 88:16,
88:22, 92:20
best
11:11, 26:20,
39:9, 52:17,
63:12, 72:2,
72:3, 91:15
between
4:19, 5:1,
5:10, 5:14,
5:20, 6:1,
16:19, 27:16,
35:20, 43:6,
44:2, 44:12,
58:6, 58:18,
64:8, 64:17,
66:1, 66:8,
68:15, 69:2,
70:11, 70:22,
87:22
bills
91:20, 92:4
bit
18:8, 18:12,
21:10, 37:8,
56:9, 85:10,
88:7
black
15:13
blackberries
51:11, 51:13
blackberry
5:4, 5:18,
11:16, 11:22,
12:1, 12:2,
15:13, 30:7,
39:11, 39:13,
39:19, 41:19,
45:19, 46:5,
47:2, 47:11,
47:12, 51:10,
51:19, 52:1,
Transcript Justin Cooper
Conducted March 14, 2019
52:2, 52:13,
53:1, 53:8,
58:9, 58:21,
61:10, 62:7,
62:13, 62:14,
62:15, 62:19,
63:7, 63:9,
63:15, 63:16,
65:15, 66:12,
67:3, 67:12,
69:16, 70:2,
71:3, 71:17,
80:5, 83:8,
83:12
blank
24:7, 24:16,
24:20, 45:5
blood
99:14
blumenthal
12:18
both
8:10, 14:16,
20:13, 22:1,
41:7
bottom
43:12
bouncing
61:9
boxes
61:12
break
36:17, 36:22,
37:6, 57:20,
58:1, 82:12,
88:15, 93:22,
94:3
brief
84:10, 90:4
briefly
38:6, 70:20,
79:6, 86:22
bring
52:6, 62:20
bringing
36:19
brings
52:4
broke
89:11, 89:15
brought
22:12, 62:14
brute
56:5, 79:6
bryan
5:2, 6:1,
14:15, 20:19,
30:9, 33:1,
33:8, 48:20,
50:13, 55:1,
55:6, 58:7,
58:19, 70:11,
71:1, 72:16,
72:21
building
34:12
bush
16:9
business
80:21
c-o-o-p-e-r
10:10
cadre
14:13, 20:6
call
22:5
called
32:11, 75:2
calling
33:12, 33:15
came
16:21, 20:15,
21:7, 21:13,
33:20, 40:7,
49:10, 49:16,
63:12, 72:6
campaign
14:16, 16:3,
18:22, 30:12
can
11:4, 21:18,
22:3, 22:5,
22:6, 27:11,
31:2, 31:6,
31:13, 32:1,
32:9, 38:22,
40:4, 45:16,
47:6, 47:8,
53:3, 57:3,
68:9, 69:9,
78:12, 80:1,
84:7, 85:1,
85:19, 87:4,
87:11, 88:7,
93:12
cant
11:14, 25:18,
29:15, 31:3,
31:16, 35:22,
39:4, 49:7,
53:11, 54:2,
61:4, 61:11,
63:11, 69:19,
73:6, 74:11,
76:4, 83:10,
86:3
cannot
10:20, 38:21
capacities
94:13
capacity
27:5, 90:13
card
52:3
care
92:15
carrier
12:3
carry
81:18, 83:8,
83:14
carrying
83:11
case
49:8
cases
41:13, 42:13
caused
42:1
causes
41:9
ceased
26:19
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
center
1:15, 8:12
certain
19:1
certainly
15:6, 73:7,
77:3, 95:11
certified
7:13
chain
4:19, 5:20,
43:11, 44:2,
44:12, 64:17,
67:13, 68:8,
68:15, 69:2
challenge
88:7
chance
23:14, 38:3,
43:2, 44:8,
58:13, 64:14,
86:11
change
15:5
changed
12:14
changes
30:1
changing
30:4, 30:6,
80:12
chappaqua
71:6
charles
3:6, 8:21
chelsea
20:13, 20:18,
33:21, 40:14
cheryl
83:18, 84:3,
84:9, 90:11,
94:19
chief
84:1
choice
16:11
chose
53:3
Transcript Justin Cooper
Conducted March 14, 2019
chosen
21:6
christine
1:17, 8:9,
99:6, 99:22
circumstance
49:21, 49:22
clarification
22:8
clarify
21:19, 47:8,
54:16
clean
28:14
clear
15:12, 59:6,
66:15, 87:9
clearer
10:18
clearly
18:7, 30:6
click
63:1
clintons
5:4, 10:2,
13:9, 14:12,
14:19, 15:10,
15:20, 19:11,
19:20, 20:5,
20:9, 21:12,
21:22, 22:2,
25:4, 27:8,
27:12, 27:14,
31:9, 32:4,
32:15, 32:18,
32:20, 36:7,
39:11, 40:15,
42:2, 47:12,
49:14, 54:3,
58:8, 58:20,
59:16, 65:8,
71:5, 75:19,
76:1, 76:16,
77:10, 81:3,
81:11, 83:22,
91:21, 92:5,
94:17
clintonemail
13:1, 13:5,
16:22, 20:8,
21:12, 32:19,
33:4, 33:11,
39:17, 40:1,
40:7, 41:4,
68:4, 71:9,
71:21, 78:15,
78:21, 80:20,
84:3, 93:8
clintons
35:14, 35:20,
55:16, 74:2,
83:22, 87:7,
87:22, 92:9,
92:12, 92:13,
92:14
close
14:13, 37:7,
59:17, 89:4
coast
46:2
colleague
25:20
columbia
1:2, 8:6
com
12:10, 13:1,
13:5, 16:3,
16:22, 20:8,
20:14, 21:12,
32:19, 33:4,
33:11, 39:17,
40:1, 40:7,
41:4, 45:17,
46:8, 48:2,
68:4, 71:9,
71:21, 72:4,
78:15, 78:21,
80:20, 84:3,
93:8
combinations
17:3
come
53:3, 90:22
comes
73:21
comfortable
21:5
coming
6:7, 15:10,
86:6, 86:16
commencing
1:16
commercial
19:10
communicate
46:4, 47:14,
94:14, 94:16
communicated
67:18
communicates
52:4
communications
56:10
compensated
56:3
complete
53:4, 62:20,
98:5
completely
45:5
complex
50:8, 72:18
complicated
69:20
components
41:20
compound
27:10
computer
17:17, 28:4,
28:16, 29:1,
51:22, 52:7,
52:8, 52:20,
76:15, 76:21
computers
53:10, 53:14,
53:17, 53:19,
54:1, 77:22
conceived
21:3
concern
73:10
concerned
81:2
concerning
91:21
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
concerns
81:9
concludes
96:12
conclusion
92:10
conduct
80:21
confused
87:15
confusing
32:9
confusion
48:5
congress
56:5, 56:8,
91:12, 95:7
congressional
91:9, 92:10
connected
41:15, 41:17
connecting
42:3
connection
57:1
connectivity
40:12, 40:13,
41:3, 41:8,
41:15, 41:22,
42:9, 42:14,
49:5
connects
62:13
conscious
70:5
consider
85:16
consideration
49:22
consistently
72:21
construction
82:13
contact
49:6, 49:9,
56:11, 57:5
contacted
56:19
Transcript Justin Cooper
Conducted March 14, 2019
contained
65:18, 70:8
content
81:14
continues
45:16, 83:4
contract
35:3, 35:6,
55:15, 56:1
contractor
35:9
conversation
14:7, 15:1,
24:7, 25:3,
25:7, 29:13,
30:9, 31:1,
34:2, 34:6,
34:7, 78:17,
84:8, 85:2,
85:6, 85:8, 90:6
conversations
13:18, 13:20,
14:5, 14:10,
14:22, 15:18,
16:18, 19:6,
19:8, 19:13,
23:6, 30:13,
34:9, 36:5,
36:7, 36:16,
78:14, 78:20,
80:11, 84:2,
85:12, 89:2,
95:6, 95:9
cooper
1:14, 4:4, 8:3,
8:22, 9:19,
10:9, 24:8,
25:8, 37:5,
82:16, 94:6,
98:2
correct
12:11, 12:19,
15:15, 15:17,
25:1, 33:14,
37:10, 43:13,
43:21, 60:8,
62:4, 64:19,
65:17, 65:20,
66:13, 66:17,
66:19, 68:12,
72:1, 75:5,
76:9, 91:14,
98:4
corrections
98:6
correctly
88:5
cotca
2:9, 8:20
could
10:7, 14:20,
15:6, 16:5,
18:6, 30:16,
32:11, 38:6,
39:17, 41:20,
41:21, 42:1,
43:4, 45:13,
45:21, 47:7,
50:1, 50:14,
53:5, 53:7,
58:16, 60:20,
61:7, 66:6,
67:9, 70:20,
75:9, 81:1,
81:8, 84:10,
88:4, 92:1,
93:18
couldnt
90:16, 90:21
counsel
8:14, 10:12,
11:1, 88:16,
88:22
county
99:3
couple
27:20, 32:3,
78:3, 84:17
course
72:20
court
1:1, 7:11, 8:5,
8:9, 9:9, 10:20,
11:3, 17:16,
96:16, 96:21
create
11:13, 18:5,
26:13, 46:14,
75:22
created
11:6, 11:10,
17:21, 18:3,
20:22, 23:1,
29:21, 38:11,
40:8, 40:10,
40:14, 40:18
creating
13:11, 13:14,
23:2, 46:16,
46:19, 60:1,
60:3
creation
17:9, 78:5,
78:15, 78:21
creative
16:8
credentials
75:8
cutler
3:2
cutrone
1:17, 8:10,
99:6, 99:22
dag
45:8
data
32:22, 51:20,
51:21, 52:19,
53:9
date
8:6, 23:9,
37:20, 42:22,
44:6, 46:1,
58:10, 60:14,
64:11, 66:4,
67:5, 68:18,
70:14, 74:1,
74:5, 86:9,
98:10
dated
5:11, 64:9,
64:18
dates
19:1, 31:2,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
74:6, 84:8
davidson
5:2, 58:7,
58:19, 59:8,
72:8
day
54:20, 83:5,
91:10, 99:18
days
81:22, 82:2
2:7, 2:17, 3:5,
52:14, 52:15
dead
45:14
decided
24:17
decommission
31:14
defendant
1:11, 2:15
delete
77:20
delineate
27:15
delivering
45:18
demand
27:3
department
1:9, 2:14, 8:4,
9:2, 9:4, 9:5,
9:7, 9:8, 10:1,
10:4, 10:5,
13:2, 19:5,
51:7, 55:7,
55:10, 55:14,
68:1, 80:17,
80:21
depending
50:4, 52:10
deponent
98:1
depos
8:10
deposition
1:14, 7:2, 7:9,
8:2, 8:11,
Transcript Justin Cooper
Conducted March 14, 2019
10:14, 22:10,
81:6, 82:16,
94:22
description
4:9, 84:10,
90:4
desktop
51:22, 52:7,
52:8, 52:20,
53:2, 53:10,
53:14
determine
81:1
device
11:16, 41:17,
50:8, 54:7,
54:8, 62:20,
62:21, 63:4,
68:10, 81:18
devices
30:4, 54:14,
63:13, 73:5,
73:7, 73:9,
81:20
diagnosed
50:15
did
11:13, 14:7,
17:11, 17:13,
19:8, 19:14,
21:10, 21:13,
21:16, 22:20,
23:14, 25:22,
26:9, 26:12,
26:15, 26:18,
29:8, 31:17,
33:6, 34:1,
36:2, 36:3,
36:7, 39:2,
39:16, 40:2,
42:3, 43:16,
44:18, 44:22,
46:14, 46:22,
47:15, 48:13,
49:18, 51:9,
51:10, 53:13,
53:19, 53:21,
55:6, 56:11,
57:4, 57:10,
57:16, 58:13,
60:19, 62:6,
63:8, 65:4,
65:6, 68:3,
68:5, 70:17,
74:9, 75:6,
75:12, 76:11,
77:6, 77:13,
77:17, 77:18,
77:20, 78:13,
79:8, 79:13,
79:18, 80:11,
80:19, 81:9,
81:17, 83:11,
84:2, 88:5,
90:1, 90:2,
91:6, 91:12,
94:16, 94:19,
94:22, 95:6,
95:9, 95:17
didnt
31:19, 34:19,
57:17, 65:6,
74:15, 78:4,
82:3
different
14:21, 16:7,
32:8, 46:8,
77:4, 78:3
direct
24:1, 24:5
directed
39:8
discovery
56:16
discuss
29:14, 90:2
discussed
59:3, 90:20,
92:20
discussion
13:11, 13:15,
15:9, 15:21,
20:2, 29:9,
61:13, 79:5,
87:19, 91:1
discussions
16:14, 20:2,
20:12, 47:10,
48:16, 48:19,
60:3, 74:18,
78:7, 79:1, 80:7
disk
8:1, 82:15
disks
96:14
disruption
42:1
distinct
48:2
distinguish
27:16
district
1:1, 1:2, 8:5
dmitry
3:9, 8:8
document
23:13, 38:2,
43:1, 44:7,
58:12, 58:14,
61:21, 64:13,
66:5, 67:6,
68:19, 70:16,
86:10
documents
22:6, 91:6
does
23:21, 33:2,
33:3, 45:8,
59:16, 62:12,
71:7, 86:19
doesnt
35:2, 52:6
doing
16:6, 55:17
domain
12:16, 15:22,
16:3, 16:8,
16:18, 17:9,
17:11, 18:2,
18:15, 33:16,
33:19, 33:22,
39:8, 41:5,
59:4, 61:6,
71:10, 78:15,
78:21, 84:3,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
85:7, 90:19,
93:8
done
10:22, 11:2,
15:7, 28:19,
60:9, 77:2,
88:13
dorr
3:3
doug
24:15, 24:21,
25:4, 25:19
down
11:4, 31:2,
31:6, 52:5,
52:6, 53:4,
62:10, 63:12,
63:16
due
41:8
duly
9:12, 99:10
during
13:1, 20:1,
34:8, 34:9,
36:2, 36:6,
46:2, 48:9,
50:22, 51:10,
52:20, 63:21,
75:7, 75:13,
79:17, 80:13,
84:4
duty
74:15
e-mails
5:10, 5:14,
5:17, 6:1, 11:9,
12:18, 28:5,
38:19, 39:6,
39:8, 39:10,
42:16, 43:6,
46:22, 47:14,
53:6, 53:7,
53:16, 54:1,
54:3, 54:9,
54:11, 54:12,
Transcript Justin Cooper
Conducted March 14, 2019
60:19, 63:3,
63:8, 63:11,
63:14, 63:17,
63:18, 63:19,
64:4, 64:8,
64:17, 65:8,
65:16, 66:1,
66:8, 66:21,
67:2, 67:11,
67:14, 69:12,
70:11, 70:22,
75:13, 75:19,
76:1, 77:10,
77:13, 77:21,
81:4, 81:11,
94:17, 96:6
each
42:17
earlier
25:7, 59:3,
81:21, 82:2,
84:15, 85:10
early
13:10, 26:21,
74:17, 84:4
easier
11:3, 42:18
easiest
64:21
east
46:2
educate
37:12
effect
7:10
effort
70:5
either
13:10, 84:20
elaborate
50:2
elizabeth
2:18, 9:1
else
13:17, 19:9,
22:20, 23:5,
42:12, 48:18,
48:21, 49:13,
49:19, 49:20,
50:6, 50:11,
50:17, 78:19,
80:12, 89:10,
90:22
emphasize
66:14
employee
35:10, 55:15
enabled
68:10
end
29:22, 74:1,
84:4, 96:5
ended
15:9
enjoy
56:9
enterprise
62:14, 62:19
entire
54:10
entitled
6:6, 86:6,
86:16
entity
35:11, 35:12,
35:15, 92:15
equipment
14:20, 30:16,
31:10
errata
98:6
especially
69:11
esq
2:8, 2:9, 2:10,
2:18, 2:19,
2:20, 3:6
establish
12:20
ether
41:20
even
10:19, 21:12,
72:22, 87:3
ever
11:6, 19:14,
34:2, 36:3,
41:3, 42:3,
46:14, 53:13,
56:19, 61:13,
62:22, 65:1,
65:4, 77:6,
79:18, 81:17,
83:11, 83:13,
86:17, 87:2,
87:4, 88:11,
89:17, 94:16,
95:12
every
63:6
everybody
42:18
everything
27:22, 28:6,
65:18, 69:11
evolving
73:1
exact
26:6, 53:2
exactly
61:5
examination
9:17, 99:9,
99:11
examinations
4:3
examined
9:14, 98:3
exceeded
27:4
except
7:5
exchange
43:6, 66:11
excluding
32:14
executive
92:14
exhibit
4:13, 4:16,
4:18, 4:22, 5:5,
5:9, 5:13, 5:16,
5:19, 5:22, 6:4,
6:8, 23:8,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
23:12, 23:15,
23:18, 37:17,
37:19, 38:1,
38:4, 38:7,
42:19, 42:21,
43:2, 43:4,
44:1, 44:5,
44:9, 44:11,
58:5, 58:9,
58:17, 60:10,
60:13, 60:15,
61:17, 62:1,
64:7, 64:10,
64:14, 64:16,
65:22, 66:3,
66:6, 67:4,
67:9, 68:17,
69:1, 70:13,
70:18, 70:21,
86:8, 86:14,
88:13
existed
33:10
existence
22:10
existing
13:8, 14:11,
15:7, 15:12,
18:20
expediting
96:22
expertise
63:19
expiration
72:18
explain
40:4
explaining
43:20
explanation
85:3
extent
75:10, 76:12,
81:14, 90:5
fact
34:3, 88:22
Transcript Justin Cooper
Conducted March 14, 2019
facts
25:10
fail
41:20
failing
5:18, 67:3,
67:12
fair
47:18, 69:18
fairly
30:5, 51:12
fall
29:15
fbi
4:11, 23:7,
23:19, 47:9,
53:20, 77:14,
77:16, 77:20,
91:8, 95:10,
95:14
4:11, 23:7,
23:18
february
40:22
federal
36:4, 36:8
feel
37:10, 37:11
fees
92:8, 92:9
few
10:12, 88:14,
94:6
figure
32:7, 32:10,
40:6, 74:15
figuring
18:18
file
53:5
files
52:5, 53:3
filing
7:2
finally
10:21
financial
93:1
find
42:10
fine
21:18, 32:17
finish
27:20
first
9:12, 11:13,
11:15, 11:18,
13:4, 14:6,
20:15, 22:4,
27:21, 29:8,
29:13, 30:22,
34:5, 34:9,
38:10, 43:11,
43:15, 49:5,
69:7, 85:4
fit
59:16, 63:16
fix
49:19, 49:20
flfw
16:10
flip
81:22, 82:5,
82:6, 82:8,
83:1, 83:3,
83:5, 83:8
floor
8:12
flores
6:3, 70:12,
71:2, 71:4, 71:5
flow
19:1
focus
12:22, 42:5
focused
81:13
foil
10:3, 10:6,
56:18
follow
78:4
followed
20:21, 50:10
following
14:14, 16:2
follows
9:15
followup
60:16
footage
87:18
force
7:10, 56:6,
79:6
foregoing
98:4
form
4:11, 7:5,
21:15, 23:7,
23:18, 34:13,
34:21, 36:14,
46:11, 47:3,
47:5, 52:21,
54:5, 55:4,
55:19, 55:20,
61:2, 63:10,
71:11, 71:12,
72:12, 75:15,
78:8, 78:9,
79:10, 79:12,
79:20, 79:21,
84:6, 85:17,
86:2, 88:18,
89:13, 89:14,
90:17, 91:22,
93:3, 93:11
formally
16:10
former
16:9
forth
35:7, 99:10
forward
16:13
forwarding
39:10
foundation
24:13, 25:17,
28:7, 28:20,
34:22, 55:18,
57:12, 75:16
four
24:2, 36:7,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
36:12, 36:13,
48:9, 51:10,
66:21, 79:17,
80:14
fourth
24:2, 86:22
free
16:10, 37:10,
37:12
freedom
9:22
friend
84:1
friends
90:21
from
4:20, 5:6, 9:3,
9:6, 14:14,
18:20, 22:5,
25:10, 25:20,
26:11, 27:1,
29:10, 30:17,
31:10, 31:11,
32:15, 35:19,
38:8, 38:22,
39:18, 43:12,
43:16, 44:3,
44:12, 49:11,
49:14, 49:16,
50:15, 52:6,
52:15, 52:17,
52:18, 56:1,
60:11, 62:2,
62:10, 62:15,
62:21, 63:4,
63:8, 63:16,
69:7, 70:2,
72:7, 72:14,
74:10, 74:22,
76:16, 80:5,
80:13, 87:18,
88:8, 92:9
full
10:8, 41:19
functionality
55:1
further
7:4, 7:8, 7:12,
Transcript Justin Cooper
Conducted March 14, 2019
99:13
g-mail
19:9, 46:14,
46:17, 46:20,
47:13, 47:19,
47:21, 48:11
gave
12:1
general
19:19, 73:14,
84:9, 90:12
generally
35:13, 51:1,
63:13, 71:16,
89:3, 93:2
gentleman
14:15
germane
56:16
gestures
10:20
get
20:9, 27:13,
27:17, 27:19,
51:11, 52:6,
60:15, 61:10,
62:6, 69:10,
73:4, 89:1
getting
41:14, 66:11,
68:7, 96:16
give
11:2, 84:10
given
98:5, 99:12
10:11, 10:14,
16:6, 31:17,
31:19, 34:13,
37:7, 39:8,
42:15, 42:18,
45:5, 56:22,
57:2, 60:20,
82:10, 82:20
goes
56:17
going
12:22, 15:5,
16:2, 16:12,
17:19, 18:1,
18:19, 21:10,
27:16, 29:6,
30:15, 32:8,
34:3, 34:11,
37:6, 37:16,
43:11, 46:7,
56:14, 63:14,
74:16, 82:13,
88:8, 95:13,
95:14
good
9:19, 27:3
google
46:18, 47:1,
59:4, 60:16,
60:21, 61:5,
61:14
got
45:7, 63:7
government
56:18, 56:21
great
37:3, 43:10,
58:4, 59:8,
64:20, 82:18
ground
10:12
group
63:17, 89:21
grouping
68:14
guess
32:7, 43:14,
47:1, 60:18,
72:14, 80:4,
84:20, 87:21
had
12:3, 13:8,
13:21, 14:11,
14:14, 14:15,
14:17, 14:20,
15:1, 15:4,
15:11, 15:13,
15:18, 17:8,
18:7, 18:21,
19:20, 20:14,
22:14, 24:17,
30:15, 33:18,
33:21, 34:20,
38:3, 40:11,
42:8, 43:2,
44:8, 48:10,
50:14, 50:19,
51:12, 54:6,
56:4, 57:6,
57:10, 61:18,
62:18, 63:1,
63:14, 64:14,
68:20, 71:13,
72:3, 76:15,
77:4, 77:21,
78:17, 78:19,
78:22, 82:19,
83:15, 84:8,
85:1, 86:11
hale
3:2
hand
68:13, 99:18
hanley
5:21, 51:2,
51:3, 67:13,
67:16, 68:3,
68:16, 69:3,
75:13, 75:22,
76:8
happened
23:19, 28:1,
48:12, 53:9,
53:12, 77:1,
77:5, 77:7
happening
59:7, 70:6
hard
30:3, 50:9
has
10:12, 23:12,
38:7, 38:11,
38:18, 41:19,
58:17, 61:16,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
65:12, 69:10,
88:18, 92:20
having
9:12, 49:6,
49:15, 63:4,
71:3
hdr
20:22
hdrclintonemail
45:17
hes
71:8
head
10:19, 14:16
hear
10:15, 49:11,
82:3
heard
14:5, 49:14,
88:11
heather
94:8
help
10:14, 49:18,
51:14, 55:16,
72:5, 76:11
helped
12:5, 52:16
helping
26:13, 26:16,
50:19, 52:14,
59:20
her
11:16, 12:14,
12:15, 13:1,
15:5, 15:6,
15:9, 16:3,
16:16, 18:19,
18:20, 19:15,
38:17, 39:12,
42:4, 43:19,
44:21, 46:4,
46:5, 46:17,
46:20, 46:21,
47:13, 47:16,
47:19, 47:21,
48:9, 48:10,
49:15, 50:19,
Transcript Justin Cooper
Conducted March 14, 2019
50:21, 51:5,
51:14, 51:20,
52:13, 52:14,
52:15, 52:16,
59:18, 63:8,
63:11, 65:4,
66:21, 67:18,
67:19, 69:8,
69:11, 71:3,
72:6, 73:12,
73:14, 76:11,
76:14, 76:16,
78:17, 79:1,
79:15, 79:17,
80:7, 80:8,
80:12, 80:20,
81:12, 81:14,
81:21, 83:11,
83:13, 84:10,
94:14, 94:16,
95:2, 95:6,
95:10
here
9:21, 39:15,
46:1, 46:5,
62:9, 62:21,
67:22, 69:21,
70:6, 88:2,
93:13, 93:17
hereby
7:1, 7:3, 7:6,
98:2, 99:8
herein
99:9
hereunto
99:17
hesitate
37:13
high
26:7
hillary
6:7, 11:6,
24:8, 25:4,
86:6, 86:16
hillaryclinton@g-mail
48:2
him
30:10, 30:12,
32:17, 34:3,
34:10, 57:2
his
14:13, 25:22,
26:4, 26:6,
47:4, 59:10,
59:11, 59:15,
71:9
home
28:4, 52:15
host
19:10
house
19:21, 71:5
housed
20:3
household
71:8
how
11:9, 13:20,
14:18, 17:21,
21:2, 30:4,
30:5, 30:10,
30:13, 39:4,
41:10, 42:10,
48:9, 54:13,
54:17, 56:11,
57:4, 59:15,
60:19, 61:5,
63:18, 71:16,
73:6, 79:2,
90:14
however
16:13
15:16
hr@clintonemail
46:8
huma
5:20, 13:16,
15:1, 16:19,
19:9, 19:14,
20:13, 22:21,
23:3, 24:7,
33:21, 40:18,
49:1, 49:11,
51:1, 67:13,
68:15, 69:2,
69:7, 69:8,
78:22, 85:13
ill
10:16, 10:17,
23:11, 25:7,
42:16, 75:18,
82:20, 92:8
ive
87:2, 89:21,
90:11
idea
13:22, 24:17,
25:13, 25:16,
29:3, 29:17,
43:18, 95:19
ideas
16:4
identification
23:9, 37:20,
42:21, 44:5,
58:10, 60:13,
64:11, 66:3,
67:4, 68:17,
70:14, 86:8,
86:13
identify
8:14, 38:6,
43:4, 58:16,
66:6, 67:9,
70:20
imagine
87:5, 87:12
implement
14:21, 50:20
implementing
48:17
important
10:18, 10:21
inc
1:5, 8:4
incarnation
74:16
incentives
93:1
inclination
69:21
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
include
53:6, 53:7,
54:11, 54:12
included
25:4
including
67:13
index
1:7
indicated
34:11, 62:8
individual
24:11, 40:9
individuals
20:3, 20:7,
47:10, 85:11,
85:15, 90:9
inference
46:13
info
52:19, 68:8
information
9:22, 52:5,
56:20, 62:14,
62:16, 62:21,
70:8
informed
57:14
infrastructure
41:19, 46:19,
47:1, 47:21,
48:11, 59:4,
59:5, 60:17,
61:7, 61:14
initial
33:21, 36:2
initially
34:19, 55:13
input
17:8
insert
88:3
instance
53:11, 63:7
instances
42:8, 59:19
intended
10:3
Transcript Justin Cooper
Conducted March 14, 2019
interact
26:9
interest
56:5
interested
56:7, 56:9,
99:15
internet
12:2
interview
4:12, 23:8,
23:19
interviewee
24:4
interviews
91:8
into
20:9, 27:13,
27:17, 27:19,
28:15, 52:3,
59:16, 61:9,
89:1
introduce
21:16, 37:16,
42:17, 65:21
investigated
87:2
involved
59:20, 59:22,
74:17
involvement
26:12, 26:16,
71:14
ipad
44:17, 44:18,
44:20, 45:8,
45:21, 46:4,
46:8, 72:17,
83:8, 83:12,
83:14
ipads
73:3
iphone
72:17
iphones
73:3
irene
46:3
issue
5:3, 24:17,
43:20, 57:6,
58:8, 58:20,
58:22, 89:11,
90:15, 90:16,
90:18
issues
27:16, 36:4,
36:9, 41:3,
41:8, 41:15,
42:9, 42:11,
42:14, 46:21,
47:11, 49:4,
49:6, 49:15,
49:18, 49:20,
56:13, 59:20,
78:3, 79:14,
79:16, 81:10,
89:11, 89:18,
90:9, 90:20
its
10:18, 10:21,
21:9, 24:15,
30:2, 38:8,
47:18, 49:16,
50:9, 62:8,
63:18, 66:8,
66:20, 70:22,
84:16, 90:22,
92:7, 92:17
its
41:19
itself
54:18, 73:1
j-u-s-t-i-n
10:9
james
2:10, 8:18
january
17:14, 22:11,
22:17, 26:3,
40:22, 69:4
john
5:1, 58:6,
58:19, 59:8,
72:8
joint
35:20
jointly
92:18
jose
6:6, 86:6,
86:15
judical
1:5
judicial
2:3, 8:3, 8:17,
8:19, 8:20,
9:20, 9:22, 10:6
june
5:15, 22:13,
66:2, 66:9
just
10:11, 10:17,
12:5, 12:20,
15:12, 18:22,
21:15, 22:8,
27:15, 27:20,
29:7, 31:2,
31:5, 32:6,
32:10, 32:19,
33:12, 34:15,
37:22, 38:6,
38:17, 40:6,
41:12, 42:5,
42:15, 43:20,
45:5, 46:5,
47:15, 54:14,
56:14, 57:4,
57:19, 59:17,
60:6, 60:16,
63:3, 65:14,
66:6, 66:14,
67:9, 68:6,
68:13, 69:1,
70:20, 73:14,
73:21, 75:18,
78:3, 82:20,
85:2, 86:21,
87:14, 89:3,
90:3, 91:3,
92:20, 94:6,
96:5
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
justice
2:14, 7:11,
9:4, 9:7
justin
1:14, 4:4, 8:3,
8:22, 10:9,
25:8, 82:16,
98:2
keep
30:1, 72:22
kept
69:18, 69:22
kicked
17:4
kind
12:21
knew
56:19, 71:16,
81:1
knowledge
72:2, 72:3,
77:5, 91:15
lack
41:21
last
43:16, 72:16,
88:14, 94:19,
94:21, 95:17,
96:5
late
13:10, 16:9
later
11:18, 84:15,
93:7
lawsuits
9:22
lawyer
90:12
lawyers
90:9, 92:11
lay
48:5
learn
34:18, 41:10,
Transcript Justin Cooper
Conducted March 14, 2019
41:12
learning
14:19
least
81:21
leaving
84:5
legal
91:19, 92:4,
92:8, 92:9
less
73:13
let
10:15, 10:17,
23:11, 24:1,
29:7, 36:17,
37:6, 37:15,
60:15, 62:19
lets
29:4, 58:5,
82:10, 93:21
letting
38:17
level
26:7
life
11:3
lifetime
72:20
like
10:11, 16:12,
19:13, 45:17,
59:6, 61:8,
71:2, 72:18,
88:2, 91:10
liked
51:20
limited
79:4, 85:11,
85:16
line
24:6, 24:16,
38:10, 38:15,
38:21
lines
24:2, 62:10,
66:15
lingering
62:17
link
88:3
linked
39:15
list
17:3
little
18:8, 18:12,
21:10, 37:8,
56:9, 85:10,
88:7
llp
3:3
load
63:2, 63:15
located
52:9
log
64:22
long
83:21
look
23:11, 23:14,
27:5, 37:22,
44:8, 68:20
looked
59:5
looking
18:7, 30:8,
46:1, 69:6
looks
59:1, 71:2
lot
11:3, 32:8,
48:5, 56:5,
56:9, 78:2
loud
10:19
made
12:18, 26:21,
30:14, 35:17,
89:3, 95:2
mail
38:15, 46:18,
64:22, 65:2,
65:8
maintained
14:12, 66:22
maintains
65:16
major
46:2
make
10:18, 11:3,
27:15, 38:22,
39:12, 39:16,
42:17, 51:20,
59:7, 70:5,
92:12
makes
16:11
making
11:1
man
40:2
manage
26:16, 40:3,
40:11, 48:13,
55:16
managed
33:1, 48:16
manager
71:6
managing
35:8, 40:5
many
11:9, 13:20,
17:22, 18:21,
30:14, 41:13,
56:11, 57:4,
73:6, 74:14,
90:14
march
1:16, 8:6,
22:11, 23:9,
31:20, 37:20,
40:22, 42:22,
44:6, 58:10,
60:14, 64:11,
66:4, 67:5,
68:18, 70:14,
86:9, 99:18
marcio
6:6, 86:5,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
86:15
mark
42:19, 44:1,
58:5, 64:7
marked
4:12, 4:15,
4:17, 4:21, 5:5,
5:8, 5:12, 5:16,
5:18, 5:22, 6:3,
6:8, 23:8,
23:12, 37:19,
38:7, 42:20,
44:4, 58:9,
58:17, 60:12,
61:17, 64:10,
66:2, 67:3,
68:16, 70:13,
86:7
marriage
99:15
material
27:17, 28:10,
77:19
materials
77:15, 91:10
matter
8:3, 91:20,
93:2, 99:16
matters
91:20, 92:4,
93:13, 93:17
may
7:9, 10:13,
12:5, 12:7,
13:21, 14:22,
24:14, 28:8,
28:21, 35:1,
41:17, 49:2,
49:14, 50:5,
50:6, 50:8,
50:18, 50:20,
52:14, 52:16,
52:22, 54:11,
59:3, 59:20,
60:7, 69:17,
71:14, 81:7
maybe
12:17, 15:18,
Transcript Justin Cooper
Conducted March 14, 2019
16:7, 22:3,
22:10, 33:16,
35:20, 37:12,
42:13, 43:20,
49:8, 49:10
mean
18:9, 31:1,
32:7, 34:15,
39:2, 40:4,
45:9, 50:1,
51:17, 52:12,
62:12, 70:3,
71:7, 71:18,
76:13, 76:14,
84:16
meant
56:8, 72:19
meeting
27:1
memo
69:22
memos
69:9, 69:13,
69:15, 69:16,
69:21, 70:1,
70:3, 70:8
mentioned
29:19, 85:10,
85:13
message
43:16, 62:12,
62:22, 63:1,
63:2, 63:4,
63:5, 64:20
messages
47:22, 62:10,
65:12, 65:13,
66:16
michael
2:8, 8:16, 9:20
might
14:18, 15:8
mills
83:18, 84:3,
84:9, 85:2,
90:11, 90:15,
94:20, 95:13
mine
25:20, 84:1
minute
23:11, 57:20,
82:10
mischaracterization
93:4
mischaracterizes
47:4
misnomer
33:16
miss
21:16
moment
37:22
moments
27:20
monica
5:21, 51:2,
51:3, 67:13,
67:16, 68:3,
68:16, 69:3,
69:7, 75:12,
75:22, 76:8
monitor
56:2
more
10:14, 16:8,
18:8, 18:13,
18:18, 19:1,
19:10, 50:8,
51:10, 60:6,
63:1, 65:16,
68:14, 69:17,
69:20, 72:22,
73:5, 73:10,
73:13, 75:18,
81:18, 90:22,
93:2, 94:7
morning
9:19
most
62:15, 63:22
move
80:8
moved
32:22, 35:15,
52:6
movement
18:5, 18:10
moving
18:20, 80:13
mrs
14:2, 15:22,
17:6
much
40:11, 61:8,
74:12, 87:2,
88:9
myself
6:1, 16:19,
20:19, 38:8,
43:6, 58:19,
66:8, 70:11,
71:1
name
9:19, 10:8,
15:22, 17:9,
17:11, 18:2,
18:15, 21:13,
41:5, 53:3,
71:10, 78:15,
78:21, 84:3,
85:7, 90:19,
93:9
named
14:15
names
16:9, 17:4,
24:4
native
59:5
natural
19:1
need
36:17, 37:6,
59:6, 72:17
needed
17:16, 30:6,
61:1
needs
27:1
negotiated
92:11
networks
75:4
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
new
1:15, 1:19,
4:15, 8:12,
8:13, 9:14,
18:5, 18:11,
31:9, 32:21,
33:1, 33:5,
37:19, 38:9,
38:11, 39:6,
51:19, 52:2,
52:16, 53:8,
62:5, 62:6,
62:13, 62:20,
63:7, 63:9,
66:11, 69:11,
72:21, 73:1,
89:16, 99:1,
99:3, 99:7
news
6:5, 74:22,
77:3, 86:5,
86:15, 89:11,
89:14
next
24:16, 38:15,
38:21, 39:12,
74:16, 74:18,
82:14, 87:11
night
43:16
noise
82:13
not
13:19, 19:15,
20:14, 21:19,
22:1, 26:6,
31:12, 32:5,
32:6, 33:12,
34:7, 35:15,
37:6, 39:18,
39:22, 41:14,
41:15, 48:3,
48:22, 50:18,
51:6, 53:2,
55:21, 56:6,
56:8, 56:20,
59:21, 61:15,
61:20, 63:14,
Transcript Justin Cooper
Conducted March 14, 2019
63:18, 67:12,
69:16, 71:21,
74:19, 76:5,
76:19, 76:22,
77:3, 77:18,
80:2, 80:10,
80:15, 80:18,
80:22, 82:7,
83:6, 83:13,
87:9, 87:14,
88:2, 91:3,
94:12, 94:18,
95:15, 95:20,
95:21, 96:7,
99:13, 99:15,
99:19
notary
1:18, 7:10,
9:13, 99:7
note
25:7
noted
97:4
notes
69:17, 69:22,
70:3, 70:7
now
29:4, 30:5,
37:17, 38:21,
38:22, 42:6,
42:16, 61:16,
93:7
number
8:2, 15:4,
82:16, 96:13
2:16, 3:4
oclock
1:16, 37:7
object
21:15, 52:21,
54:5, 55:4,
56:15, 57:1,
63:10, 71:11,
71:12, 72:12,
75:15, 79:10,
88:18, 89:14,
90:17, 91:22,
93:3
objection
11:1, 24:13,
24:22, 25:17,
27:10, 28:7,
28:20, 34:13,
34:21, 36:1,
36:10, 36:11,
36:14, 40:16,
46:11, 47:3,
47:5, 55:18,
55:20, 57:12,
61:2, 61:3,
75:17, 78:8,
78:9, 79:11,
79:12, 79:20,
79:21, 81:5,
84:6, 85:17,
86:1, 86:2,
89:13, 89:20,
92:6, 93:5,
93:10, 93:11,
93:15
objections
7:5
obtained
25:9
obviously
16:14, 16:15,
70:4
occasionally
83:16
occurred
13:11, 25:11,
34:6, 35:18
occurring
30:2, 74:12
off
24:6, 35:17,
36:20, 54:1,
57:21, 60:6,
60:22, 73:2,
82:10, 82:11,
94:1, 96:14
offer
12:2
offers
61:5
office
13:9, 14:12,
14:19, 15:11,
15:20, 19:20,
20:6, 27:8,
27:12, 76:8,
76:10, 76:16,
84:5, 91:10
offline
75:22
often
30:4, 48:9,
54:17
17:22, 23:16
okay
19:3, 22:16,
25:12, 37:14,
48:1, 48:4,
56:22, 57:18,
63:6, 87:17
old
62:11, 65:11
older
66:16
once
27:22, 28:6,
31:14, 40:1,
40:9, 41:18,
48:12, 53:8,
54:4, 54:20,
54:21
one
8:2, 9:21,
10:15, 10:16,
11:4, 11:13,
12:9, 12:12,
12:14, 18:7,
30:13, 30:19,
35:20, 43:12,
46:2, 51:10,
51:22, 53:13,
53:14, 56:17,
57:7, 59:2,
60:6, 60:16,
66:15, 68:13,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
70:2, 72:14,
81:18, 83:15,
85:13, 90:3,
91:13
one-time
52:3
online
16:6, 22:13,
33:20
only
11:4, 48:12,
65:13, 65:15,
91:12
onto
15:10, 62:15,
63:15, 63:16,
76:21
open
62:12, 82:19
operational
31:18, 31:20,
31:21
opine
80:18
opinion
93:13, 93:16
opportunities
73:2
opportunity
61:18, 68:20,
70:17
opposed
10:19
option
19:21, 21:3
ordering
97:2
ordinary
28:4
original
45:4
oscar
71:2, 71:4,
71:5
other
15:8, 20:1,
20:2, 20:12,
25:10, 27:6,
Transcript Justin Cooper
Conducted March 14, 2019
30:1, 33:19,
33:20, 46:22,
50:13, 52:5,
56:21, 59:19,
72:14, 81:20,
85:15, 91:20,
92:4, 96:8
others
12:13, 16:9,
21:4, 37:12,
49:17, 78:18
our
12:22, 27:1,
59:5
out
10:18, 11:5,
18:18, 32:7,
32:10, 40:6,
41:20, 42:10,
42:13, 50:6,
50:7, 50:11,
53:5, 57:9,
59:6, 59:20,
68:13, 73:21,
74:13, 74:15
outage
46:3
outages
46:22
outcome
99:16
outside
81:6
over
10:12, 18:19,
18:21, 21:4,
27:22, 28:6,
29:10, 32:21,
32:22, 33:9,
41:6, 44:8,
53:19, 62:18,
62:20, 72:20,
75:8, 76:14,
77:15, 77:19,
94:11
oversaw
55:1
own
40:13, 41:19,
45:18, 53:14
pad
44:15, 44:16,
69:22
page
4:3, 4:9, 69:7
pagliano
5:2, 6:2,
14:15, 20:19,
22:7, 26:22,
27:19, 28:1,
29:6, 29:7,
29:10, 30:10,
30:20, 31:1,
31:10, 31:11,
34:1, 34:2,
34:4, 34:19,
35:4,