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Judicial Watch • JW v State Heather Samuelson deposition 01242 exhibit

JW v State Heather Samuelson deposition 01242 exhibit

JW v State Heather Samuelson deposition 01242 exhibit

Page 1: JW v State Heather Samuelson deposition 01242 exhibit


Number of Pages:6

Date Created:June 17, 2019

Date Uploaded to the Library:June 28, 2019

Tags:Secretaries, samuelson, hanley, Kendall, 01242, exhibit, deposition, Mills, Emails, Benghazi, Hillary Clinton, clinton, FBI, DOJ, FOIA

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DATE os-n-2016 J37J85B4 tTSICG
FD-302a (RC, 10-(,-95)
Dale oftranseriplion
5/25/2016 _,,___
(U//FSHe) May 24, 2016, HEATHER SAMUELSON, Date or-f_B_irt_h.....RN re-establish connection HRC emails
November 2014.
FD-302a (Re,. 10-(,-95)
Continuation FD-302 _=In=lc~1Y=ic~\~o~f I=lc=a=
th=cr~S=m=m=1c=lso~n 5125120 Page _-+_
(U/ff0U9-) SAMUELSON was never given dl:rect access the mailboxes the server and she
was not aware anybody else being granted such access. SAMUELSON was never given administrative
access the server and she was not aware anybody else being granted administrative access.
Cull and Review Emails
(U//FOUO) SAMUELSON stated she was primarily responsible for conducting the review the
direction MILLS and KENDALL. She conducted the review over the course several months and
Completed just prior December 20! when the documents were turned over DOS.
SAMUELSON conducted the review her laptop, both her apartment and MILLS office
Friendship Heights, Washington DC.
(U//Fe-He) SAMUELSON reviewed the emails provided PRN Microsoft Outlook and
placed any responsive emails separate folder. She began adding alI the .gov emails and any
email from .mil email address the folder. She then searched the emails provided PRN for
any email from senior leadership DOS. This included key individuals such Under Secretaries,
Assistant Secretaries, Ambassadors, Department Heads, and Senior DOS Aides. SAMUELSON then
reviewed the sender and receivers the remaining emails identify any congress members, foreign
leaders, other official contacts. Lastly, she searched the remaining emails for key words that included
terms such Afghanistan, Libya, and Benghazi.
(U//rOUO) SAMUELSON reviewed the sender, receiver and subject line every single email
during the review, However, she stated that she did not read the content each individ~al email she
could determine was work personal emai1 from the sender, receiver subject line. SAMUELSON
provided that she did her best review and identify any emails that were potentia11y mix work and
personal content. When asked how work related emails between ABEDJN and CLINTON may have been
missed, SAMUELSON stated ABEDIN may have kept emails that CLINTON did not.
(U/iFOUO) SAMUELSON did not have formal process for removing duplicate copies the
same email from the set work related emails. She did not ask PRN assist with this process.
SAMUELSON stated she would remove copy the email she noticed that was duplicate but she
did not have formalized consistent process for identifying and removing duplicates.
(U//rOUO) Upon completing the review, SAMUELSON printed all the emails she deemed relevant. The paper copies were then subsequently reviewed MILLS and KENDALL and anything
they deemed riot .to work related was shredded. The remaining physical documents were ultimately
provided DOS. SAMUELSON stated that she printed the emails MILLS office and noted there
still printer MILLS office but she was not sure was the same printer.
(U//FOUO) Following the review, SAMUELSON created digital copy, preservation copy, the relevant documents that were provided DOS. The files were placed thumb drive and
provided KENDALL. SAMUELSON believed this drive the same thumb drive provided the FBI KENDALL. SAMUELSON also created second copy the documents provided DOS and placed
FD-302a (Re,, 10-(,-95)
on~ 5/25/2Hl6 Page _:i~-
them second laptop hers. SAMUELSON was not aware any other copies the files. Nor was
she aware master copy all the personal and private emails.
(U/ifOU9-) SAMUELSON was shown copies the thumb drives previously provided the FBI
but could not recall any were the same the one she had used. One the thumb drives was labeled PRIME and SAMUELSON did not know what the label referred to.
(U/,FOUO) The review methodo1ogy was developed SAMUELSON, MILLS and KENDALL.
SAMUELSON did not consider using any commercia11y ava_ilable e-discoveiy tools for the review and
they did not consult any individuals who were not agent Clinton during the review process.
SAMUELSON stated they did not discuss how handle potentially classified emails during the review
because they had reason believe any classified material was contained the emails. She further
noted that none the emails were marked being classified.
(U//FOUO) During the review process SAMUELSON noticed the imported emails displayed
CLINTON email hrod despite the fact this address was not created until after
CLINTON tenure. SAMUELSON discussed the issue with!
lbut she did not fully
understand his explanation for why this was occurring and was never able resolve the problem.
SAMUELSON did not consult anybody else about this issue.
Deletion Emails
(U//FOUO) January 2015, SAMUELSON asked! remove the exported
emails files that had previously been provided her PRN. Whi she retained separate digital copies the emails provided DOS, discussed above, she longer wanted 1he email exports provided
PRN her computer. U~ing similar process described above!
bccessed her computer
remotely and removed the files. SAMUELSON provided thad
!took additional steps during
t.he deletion process the files would not recoverable. SAMUELSON did not know what software
processes were used
!but believed that the files would difficult, not impossible,
recover. SAMUELSON did not remember having any discussions withl
about deleting
relevant data from the. free space her laptop Nor did she recall any discussions with
about the use of:BleachBit. SAMUELSON did not recall deleting any the files herself before
contacting PRN.
(U//FOU.0) SAMUELSON stated that May 2015 she deleted some emails from her copy
the work related emails that wete previously provided DOS. SAMUELSON explained that she was
notified DOS, prior the release the first tranche ofFOIA emails, that some the work related
emails they had turned over were classified. She was instructed DOS delete the files and then empty
those files from the trash bin. SAMUELSON did not believe these files were removed from the thumb
drive she had previous1y provided KENDALL.
(U//~UO) about December 2014, SAMUELSON was call which the email
retention policy was discussed. She was aware the retention period was changed days and any older
FD-302a {RC, 10-(,-95)
Co11ti11uatio11ofFD-302 _=[n=tc-- _,_,
-ic=---=O_,_ ,._,_llc=a=1h=cr._.S=m=m=1c=Js=o11_ _____.... 5/25/20 Page
emails would deleted. However, SAMUELSON did not direct PRN remove any exported .pst files the server any mailboxes the server.
(U//f0U0) SAMUELSON was not aware any other deletions relevant emails. She was
aware PRN traveled the datacenter March 2ffl via her role counsel, but had not instructed
them so. SAMUELSON was not aware exports deletions conducted PRN the server
September 2015.
Devices used During the Review
(U//rOUO) SAMUELSON used her own laptop conduct the review and noted that she also
used the laptop for other work related matters well. She described Lenovo Yoga laptop.
SAMUELSON stated that following the review she accidentally spilled water the laptop. Fearing that
the computer would fail, she purchased second Lenovo laptop and placed copy the emails that were
prepared for DOS it. SAMUELSON noted that the Lenovo Yoga computer continued work until
sometime last year when failed power on. The Lenovo Yoga computer currently the
possession her counsel and the second Lenovo was given KENDALL and then subsequently turned
over the FBJ. SAMUELSON reviewed pictures the laptops that were previously turned over the
FBI and stated that the silver Lenovo laptop appeared the same the laptop that she used.
(U// FOUO) SAMUELSON stated that both laptops were connected the internet and they both
had antivirus software installed them. SAMUELSON did hot repurpose the laptops after the review
and never attempted reformat factory reset the computers.
(U//FOUO) copy the original interview notes are enclosed envelope.