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Judicial Watch • JW v. State Def’s Reply 01363 081915

JW v. State Def’s Reply 01363 081915

JW v. State Def’s Reply 01363 081915

Page 1: JW v. State Def’s Reply 01363 081915


Number of Pages:6

Date Created:August 19, 2015

Date Uploaded to the Library:August 19, 2015

Tags:judicial watch v. state department, Hillary Clinton Email Scandal, State Department

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Case 1:13-cv-01363-EGS Document Filed 08/19/15 Page
Civil Action No. 13-CV-1363 (EGS)
DEFENDANT REPLY PLAINTIFF RESPONSE STATUS REPORT the Declaration John Hackett dated August 14, 2015 (ECF No. 26-1), the U.S.
Department State responded the Court order directing the Department, related
Judicial Watch FOIA requests this case, identify any and all servers, accounts, hard
drives, other devices currently the possession control the State Department
otherwise that may contain responsive information. July 31, 2015 Minute Order, (emphasis
Although plaintiff asserts that the Department failed address several issues with respect devices, see Plaintiff Response Defendant August 14, 2015 Status Report (Pl. Resp.)
(ECF No. 27), plaintiff overlooks the highlighted phrase quoted above from the July Order,
thereby criticizing the Department for failing discuss devices that longer exist that the
State Department reasonably determined not contain responsive information.
For example, Plaintiff errs contending (Pl. Resp. that the Department made
effort whatsoever gather information regarding any electronic devices used former
Secretary Clinton, Huma Abedin, and Cheryl Mills. After the Department conducted inquiry,
Case 1:13-cv-01363-EGS Document Filed 08/19/15 Page
for purposes responding the Court directive, into any personal computing devices that
issued these employees, the Department did not locate any such devices that may contain
records responsive plaintiff FOIA requests. Accordingly, Mr. Hackett stated that the
Department not currently aware any personal computing devices issued the Department former Secretary Clinton, Ms. Abedin, Ms. Mills that may contain records responsive
plaintiff FOIA request. Hackett Decl. (emphasis added).
For these reasons, plaintiff contentions miss the mark. Nevertheless, the Declaration
Joseph Macmanus, filed herewith, further states the Department inquiries the Office
Information Resource Management within the Office the Executive Secretariat S/ES-IRM
which the office responsible for issuing Department electronic devices Principal officials.
See Macmanus Decl. The Department electronic records systems and accounts, such email accounts, are generally housed Department servers. Id.
Finally, plaintiff makes assertions regarding two additional former Department
employees. See Pl. Res. Using search terms agreed upon the parties, the Department conducting revised search the offices and agency records systems that were initially
searched. See Defendant July Status Report. The Department identified five its offices
and record systems that were reasonably likely contain responsive records. See Hackett Decl. Within S/ES, the Department identified the accounts Ms. Abedin, Ms. Mills,
and two other former officials. Id. Former Secretary Clinton did not use
account. Macmanus Decl. the process conducting revised search S/ES, the
The Department conveyed this information plaintiff declaration filed another case.
See Declaration John Hackett Regarding Exemptions, n.6, filed July 2015 Judicial
Watch Dep State (D.D.C. No. 14-cv-01242) (Exh. 1).
Case 1:13-cv-01363-EGS Document Filed 08/19/15 Page
Department retrieved potentially responsive emails sent from Ms. Abedin and the
accounts Administrative Officer for S/ES and Senior Advisor the Office the Under
Secretary for Management White House Liaison Office. Id. result, addition
searching the email accounts Ms. Abedin and Ms. Mills, the Department initiated
searches those other two individuals accounts. Id.
DATED: August 19, 2015
Respectfully submitted,
Principal Deputy Assistant Attorney General
Assistant Director
/s/ Peter Wechsler
Senior Counsel
United States Department Justice
Civil Division, Federal Programs Branch Massachusetts Avenue, N.W.
Washington, D.C. 20530
Tel.: (202) 514-2705
Fax: (202) 616-8470
Counsel for Defendant
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Case 1:13-cv-01363-EGS Document 29-1 Filed 08/19/15 Page