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Judicial Watch • JW v State document request 01242

JW v State document request 01242

JW v State document request 01242

Page 1: JW v State document request 01242

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Number of Pages:4

Date Created:January 15, 2019

Date Uploaded to the Library:January 15, 2019

Tags:Smilansky, Procedure, 01242, rules, control, privilege, record, Civil, Secretary, Hillary Clinton, michael, State Department, federal, plaintiff, request, document, records, department, FOIA, office


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THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
WDICIAL WATCH, INC.,
Plaintiff,
U.S. DEPARTMENT STATE,
Defendant.
Civil Action No. 14-cv-1242 (RCL)
PLAINTIFF JUDICIAL WATCH, INC.S REQUEST FOR PRODUCTION
DOCUMENTS DEFENDANT U.S. DEPARTMENT STATE
Plaintiff Judicial Watch, Inc., pursuant the Courts January 15, 2019 Memorandum and
Order and Rule the Federal Rules Civil Procedure, requests that Defendant U.S.
Department State produce the following documents:
INSTRUCTIONS AND DEFINITIONS
The requests set forth herein seek records your actual constructive
possession, control, custody, including records which may held your attorneys,
representatives, all persons acting under, by, through you, subject your control
supervision, and all persons acting your behalf. you object any portion request, but not the entire request, identify the
specific portion the request which objection made and respond the portion the
request which objection made. you object request the grounds that the request overly broad unduly
burdensome, respond the request providing all records that are not alleged overly
broad unduly burdensome and identify the nature, quality, quantity, volume the withheld
records and the effort that would required provide the withheld records. you object request the grounds that the request calls for the production record that subject claim privilege, identify the privilege that claimed apply
and identify all information sufficient permit Plaintiff contest the claim privilege and
permit the Court reach determination concerning the validity the claim privilege,
together with the factual and legal basis for the claim privilege. Such information should
include, but not limited to, (i) the nature the record (e.g., inter-office memorandum,
correspondence, report), (ii) the author, sender, and recipient the record, (iii) the date the
record, and (iv) description the subject matter the record. record once your possession control responsive request and the
record longer your possession control, state when the record was most recently your
possession control and what disposition was made the record, including the identity the
person entity now possession exercising control over the record. the record has
been destroyed, state when and where was destroyed and identify the person who directed its
destruction.
Where record portion record responsive one more these
requests, produce the entire record, including any attachments exhibits thereto.
The present tense includes the past and future tenses; the singular includes the
plural and the plural includes the singular; any and all each mean any and all;
including mean including but not limited to; and and each encompass both
and and or; and words the masculine, feminine, neuter form include each the other
genders.
The definitions provided below are hereby incorporated into each interrogatory
which the term appears:
Communication means any record recording any type
transmission, conveyance, exchange information, whether facts, ideas, inquiries,
otherwise, and regardless form, method, medium. includes, without limitation, any
record recording any conference, conversation, correspondence, discussion, email, internet
posting (including Facebook, Instagram, Snapchat), instant message, letter, meeting, telefax,
text message, tweet, voice mail message.
Concerning and relating mean affecting, analyzing, bearing upon,
commenting on, comprising, concerning, connected with, considering, constituting, containing,
dealing with, describing, discussing, embodying, embracing, encompassing, entailing,
establishing, evidencing, germane to, identifying, implicating, including, incorporating,
involving, pertaining to, presenting, purporting to, recommending, regarding, relating to,
referring to, reflecting, reporting on, respecting, responding to, setting forth, showing,
studying any manner and whole part.
FOIA refers the Freedom oflnformation Act.
Office the Secretary refers the Office the Secretary within the
U.S. Department State.
Record synonymous meaning and equal scope the description Rule 34(a)(l) the Federal Rules Civil Procedure and includes, but not limited to,
electronically stored information. Any draft non-identical copy separate record within the
meaning the term record. request for record meant include any attachment
exhibit accompanying the record and any file folder which the record maintained.
State Department refers the U.S. Department State.
REQUESTS unredacted copy August 2014 email exchange between Clarence
Finney, Jonathon Wasser, James Bair, Andrew Keller, and Gene Smilansky. unredacted copy May 2013 email exchange between Gene Smilansky,
Brett Gittleson, Sheryl Walter, and others. copy the email exchanges available ECF No. 62-3 with the Exemption
redactions removed.
All records concerning the State Departments pre-February 2015 awareness
the need continue searching for records responsive this FOIA request, well those
records locations.
All records including internal communications concerning the FOIA request issue this litigation.
All records relating the Departments practices, policies, and actions
accounting for Office the Secretary records, including the emails Hillary Clinton, Cheryl
Mills, Huma Abedin, Jacob Sullivan, and other staff, during and after their employment.
Respectfully submitted,
Dated: January 15, 2019
/s/ Michael Bekesha
Michael Bekesha
D.C. Bar No. 995749
JUDICIAL WATCH, INC.
Counsel for PlaintiffJudicial Watch, Inc.