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Judicial Watch • JW v. State HRC Responses 01363

JW v. State HRC Responses 01363

JW v. State HRC Responses 01363

Page 1: JW v. State HRC Responses 01363

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Number of Pages:23

Date Created:October 12, 2016

Date Uploaded to the Library:October 13, 2016

Tags:objects, responses, objection, interrogatory, interrogatories, clintonemail, HRC, exhibit, 01363, response, email, Benghazi, Secretary, clinton, filed, Obama, State Department, plaintiff, document, account, FOIA, department


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Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
EXHIBIT
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
Plaintiff,
U.S. DEPARTMENT STATE,
Defendant.
Civil Action No. 13-cv-1363 (EGS)
NON-PARTY HILLARY RODHAM CLINTON RESPONSE PLAINTIFF INTERROGATORIES
Pursuant the Court August 19, 2016 order and Rule the Federal Rules Civil
Procedure, Non-Party Hillary Rodham Clinton hereby responds Plaintiff Interrogatories
dated August 30, 2016. The General Objections and the Objections the Definitions set forth
below are incorporated into each the specific responses that follow. Any specific objections
are addition the General Objections and Objections the Definitions, and failure
reiterate General Objection Objection the Definitions does not constitute waiver that any other objection.
GENERAL OBJECTIONS
Secretary Clinton objects the Interrogatories the ground that any discovery Secretary Clinton unwarranted this case, for the reasons set forth Secretary Clinton
Opposition Plaintiff Motion Depose Hillary Rodham Clinton, Clarence Finney, and John
Bentel (Dkt. #102) and Surreply Further Opposition Plaintiff Motion Depose Hillary
Rodham Clinton, Clarence Finney, and John Bentel (Dkt. #109), and stated Secretary
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
Clinton counsel during the Court hearing July 18, 2016. Secretary Clinton will answer the
Interrogatories notwithstanding this objection, subject the other objections stated herein.
Secretary Clinton objects the Interrogatories insofar they request information
outside the scope permitted discovery this case. The Court permitted discovery
Secretary Clinton the topics the purpose for the creation and operation the
clintonemail.com system for State Department business, well the State Department
approach and practice for processing FOIA requests that potentially implicated former Secretary
Clinton and Ms. Abedin e-mails and State processing the FOIA request that the subject this action. Dkt. #124, 14, (internal quotation marks omitted). Secretary Clinton will
answer the Interrogatories insofar they seek non-privileged information related those topics.
Secretary Clinton objects the Interrogatories insofar they request information
relating events that occurred, actions taken Secretary Clinton, after her tenure
Secretary State. Such post-tenure actions events are not within the scope the permitted
topics discovery set forth General Objection No.
Secretary Clinton objects the Interrogatories insofar they request information
about Secretary Clinton use her clintonemail.com account send and receive e-mails that
were personal nature, such use not within the scope the permitted topics set forth
General Objection No. Secretary Clinton will construe the Interrogatories ask only about
her use her clintonemail.com account send and receive e-mails related State Department
business.
Secretary Clinton objects the Interrogatories insofar they request information
about management, retention, and/or preservation federal records. This action arises under
FOIA, which does not govern management, retention, preservation federal records. See
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
Kissinger Reporters Committee for Freedom the Press, 445 U.S. 136, 152 (1980).
Accordingly, management, retention, and/or preservation federal records are not within the
scope the permitted topics discovery set forth General Objection No.
Secretary Clinton objects Instruction No. insofar purports require
Secretary Clinton provide information that not within her personal knowledge. The purpose the limited discovery permitted the Court obtain Secretary Clinton personal
knowledge her purpose using the [clintonemail.com] system. Dkt. #124, 16; see also id. (directing Plaintiff propound questions that are relevant Secretary Clinton unique
first-hand knowledge Secretary Clinton answering these Interrogatories based her direct
personal knowledge. She not undertaking provide information known only other persons,
including but not limited her attorneys, representatives, persons acting under, by, through
her, subject her control supervision, other persons acting her behalf.
Secretary Clinton objects these Interrogatories the extent that they call for
the production information that privileged otherwise protected from discovery the
attorney-client privilege, the work product doctrine, any other applicable privilege, protection, immunity. Secretary Clinton will respond only the extent privileged otherwise protected
information not required and the extent that the Interrogatory not otherwise objectionable.
Secretary Clinton objects Instruction No. insofar purports require
Secretary Clinton identify the factual and legal basis for claim privilege. Secretary
Clinton not providing herewith privilege log.
OBJECTIONS DEFINITIONS
Secretary Clinton objects the definition Clintonemail.com email system
insofar refers e-mail system(s), server(s), provider(s), and infrastructure used host her
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
clintonemail.com e-mail account after her tenure Secretary State. Information concerning
the e-mail system(s), server(s), provider(s), and infrastructure used host her clintonemail.com
account after her tenure Secretary State not relevant the purpose for the creation and
operation the clintonemail.com account during her tenure Secretary State, and therefore outside the scope the permitted discovery. answering these Interrogatories, Secretary
Clinton will construe the term Clintonemail.com email system refer the e-mail system(s),
server(s), provider(s), and infrastructure used host her clintonemail.com e-mail account during
her tenure Secretary State.
Secretary Clinton objects the definition Clintonemail.com account insofar refers e-mail addresses used other individuals ending the domain name
clintonemail.com. answering these Interrogatories, Secretary Clinton will construe the term
Clintonemail.com account refer hdr22@clintonemail.com, which was the
clintonemail.com account used Secretary Clinton during her tenure.
RESPONSES INTERROGATORIES
Describe the creation the clintonemail.com system, including who decided create the system, the date was decided create the system, why was created, who
set up, and when became operational.
Response: Secretary Clinton objects Interrogatory No. outside the scope
permitted discovery. The clintonemail.com system, that term defined the Instructions
and subject Secretary Clinton objection that definition, consisted equipment set
host e-mail for President Clinton staff. Information regarding the creation that system,
including the reasons for its creation, irrelevant this lawsuit and outside the scope
permitted discovery. The Court permitted discovery this case the question the purpose
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
for the creation and operation the clintonemail.com system for State Department business.
Dkt. #124, (emphasis added). That question the subject Interrogatory No. which
answered below.
Describe the creation your clintonemail.com email account, including who
decided create it, when was created, why was created, and, you did not set the
account yourself, who set for you.
Response: the Senate, when Secretary Clinton began using e-mail, she used personal
e-mail account for both work-related and personal e-mail. Secretary Clinton decided
transition from the account she used her tenure the Senate the clintonemail.com account.
She recalls that was created early 2009. Secretary Clinton did not set the account.
Although Secretary Clinton does not have specific knowledge the details the account
creation, her best understanding that one President Clinton aides, Justin Cooper, set the
account. She decided use clintonemail.com account for the purpose convenience.
When did you decide use clintonemail.com email account conduct
official State Department business and whom did you consult making this decision?
Response: Secretary Clinton recalls deciding use clintonemail.com e-mail account
conduct official State Department business early 2009. She does not recall any specific
consultations regarding the decision use the clintonemail.com account for official State
Department business.
Identify all communications which you participated concerning relating your decision use clintonemail.com email account conduct official State
Department business and, for each communication, identify the time, date, place, manner
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
(e.g., person, writing, telephone, electronic other means), persons present participating, and content the communication.
Response: Secretary Clinton objects Interrogatory No. insofar purports
request information about communications after her tenure Secretary State, which
communications would irrelevant the purpose for the creation and operation her
clintonemail.com account while she was Secretary State. Subject the foregoing objection,
Secretary Clinton states that she does not recall participating any communications before
during her tenure Secretary State concerning relating her decision use
clintonemail.com account conduct official State Department business. Minutes interview aired July 24, 2016, you stated that was
recommended you use personal email account conduct official State Department
business. What recommendations were you given about using not using personal
email account conduct official State Department business, who made any such
recommendations, and when were any such recommendations made?
Response: Secretary Clinton objects Interrogatory No. insofar misstates her
comments the Minutes interview that aired July 24, 2016. that interview, she stated
that was recommended that [using personal e-mail] would convenient. Subject that
objection, Secretary Clinton states that former Secretary State Colin Powell advised her
2009 about his use personal e-mail account conduct official State Department business.
Were you ever advised, cautioned, warned, was ever suggested, did
you ever participate any communication, conversation, meeting which was
discussed that your use clintonemail.com email account conduct official State
Department business conflicted with violated federal recordkeeping laws. For each
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
instance which you were advised, cautioned warned, which such suggestion
was made, which such discussion took place, identify the time, date, place, manner
(e.g., person, writing, telephone, electronic other means), persons present participating, and content the advice, caution, warning, suggestion, discussion.
Response: Secretary Clinton objects Interrogatory No. the ground that requests
information that not within the scope permitted discovery for the reason set forth General
Objection No. Secretary Clinton further objects Interrogatory No. the extent requests
information about communications made other persons that were not conveyed Secretary
Clinton. Subject and without waiving the foregoing objections, Secretary Clinton states that
she does not recall being advised, cautioned, warned, she does not recall that was ever
suggested her, and she does not recall participating any communication, conversation,
meeting which was discussed that her use clintonemail.com e-mail account conduct
official State Department business conflicted with violated federal recordkeeping laws.
Your campaign website states, When Clinton got the Department, she
opted use her personal email account matter convenience. What factors other
than convenience did you consider deciding use personal email account conduct
official State Department business? Include your answer whether you considered
federal records management and preservation requirements and how email you used
conduct official State Department business would searched response FOIA
requests.
Response: Secretary Clinton objects Interrogatory No. the ground that requests
information that not within the scope permitted discovery for the reason set forth General
Objection No. Subject and without waiving that objection, Secretary Clinton states that she
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
does not recall considering factors other than convenience deciding use personal e-mail
account conduct official State Department business.
After President Obama nominated you Secretary State and during
your tenure secretary, did you expect the State Department receive FOIA requests for concerning your email?
Response: Secretary Clinton does not recall whether she had specific expectation that
the State Department would receive FOIA requests for concerning her e-mail. She understood
that, because her practice was e-mail State Department staff their state.gov accounts, her email was being captured the State Department recordkeeping systems.
During your tenure Secretary State, did you understand that email you
sent received the course conducting official State Department business was subject FOIA?
Response: Secretary Clinton understood that e-mail she sent received the course
conducting official State Department business was subject FOIA. She further understood that,
because her practice was e-mail State Department staff their state.gov accounts, her e-mail
was being captured the State Department recordkeeping systems.
10.
During your tenure Secretary State, how did you manage and preserve
emails your clintonemail.com email account sent received the course conducting
official State Department business, and what, anything, did you make those emails
available the Department for conducting searches response FOIA requests?
Response: Secretary Clinton objects Interrogatory No. the ground that
requests information that not within the scope permitted discovery for the reason set forth
General Objection No. Secretary Clinton further objects Interrogatory No. the ground
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
that the word manage vague. Subject and without waiving the foregoing objections,
Secretary Clinton states that her practice was e-mail State Department staff their state.gov
e-mail accounts, and Secretary Clinton understood that those e-mails were preserved the
Department recordkeeping systems and available the Department conducting searches
response FOIA requests.
11.
During your tenure Secretary State, what, any, effort did you make
inform the State Department records management personnel (e.g., Clarence Finney
the Executive Secretariat Office Correspondence and Records) about your use
clintonemail.com email account conduct official State Department business?
Response: Secretary Clinton does not recall specifically informing the State
Department records management personnel about her use her clintonemail.com e-mail
account conduct official State Department business; she did openly communicate via her
clintonemail.com account with many people the State Department. Secretary Clinton does not
recall interacting with Clarence Finney employees the Executive Secretariat Office
Correspondence and Records.
12.
During your tenure Secretary State, did State Department personnel
ever request access your clintonemail.com email account search for email responsive FOIA request? so, identify the date access your account was requested, the
person persons requesting access, and whether access was granted denied.
Response: Secretary Clinton objects Interrogatory No. insofar requests
information about requests for access her clintonemail.com account that may have been
directed other persons that were not conveyed her. Subject the foregoing objection,
Secretary Clinton states that she does not recall State Department personnel asking her for access
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page her clintonemail.com e-mail account search for e-mail responsive FOIA request during
her tenure Secretary State.
13. the time you decided use your clintonemail.com email account
conduct official State Department business, any time thereafter during your tenure
Secretary State, did you consider how emails you sent received from persons who
did not have State Department email accounts (i.e., state.gov accounts) would
maintained and preserved the Department searched the Department response FOIA requests? so, what was your understanding about how such emails would
maintained, preserved, searched the Department response FOIA requests?
Response: Secretary Clinton objects Interrogatory No. the ground that
requests information that not within the scope permitted discovery for the reason set forth
General Objection No. Subject and without waiving the foregoing objection, Secretary
Clinton states that was her practice conducting State Department business e-mail State
Department staff their state.gov accounts, and she did not consider how e-mails she sent
received from persons who did not have State Department e-mail accounts would searched
the Department response FOIA requests.
14. March 2009, Assistant Secretary State for Diplomatic Security Eric Boswell wrote Information Memo your Chief Staff, Cheryl Mills, that
cannot stress too strongly, however, that any unclassified BlackBerry highly vulnerable any setting remotely and covertly monitoring conversations, retrieving email, and
exploiting calendars. March 11, 2009 email states that, management meeting with
the assistant secretaries, you approached Assistant Secretary Boswell and mentioned that
you had read the and that you get it. Did you review the March 2009
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
Information Memo, and, so, why did you continue using unclassified BlackBerry
access your clintonemail.com email account conduct official State Department business?
Copies the March 2009 Information Memo and March 11, 2009 email are attached
Exhibit for your review.
Response: Secretary Clinton objects Interrogatory No. seeking information
outside the scope the permitted discovery this case. The Court May 2016 Order
provides that Plaintiff not entitled discovery the subject cybersecurity issues. Dkt.
#73, 13.
15. November 13, 2010 email exchange with Huma Abedin about problems
with your clintonemail.com email account, you wrote Ms. Abedin, response her
suggestion that you use State Department email account release your email address
the Department, Let get separate address device. Why did you continue using
your clintonemail.com email account conduct official State Department business after
agreeing November 13, 2010 get separate address device? Include your
answer whether address you meant official State Department email account (i.e.,
state.gov account) and device you meant State Department-issued BlackBerry.
copy the November 13, 2010 email exchange with Ms. Abedin attached Exhibit
for your review.
Response: Secretary Clinton recalls that her November 13, 2010 e-mail exchange with
Huma Abedin attached Exhibit Plaintiff Interrogatories was triggered problem
with the State Department telephone system. When Secretary Clinton wrote, This not
good system, she was referring the way which the State Department would notify her
telephone calls. Secretary Clinton does not recall what precisely she meant the words
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
address device. the best her recollection, she meant that she was willing use
State Department e-mail account device would resolve the problems with receiving
telephone calls, long her personal e-mails with family and friends would not accessible the State Department. Following this e-mail exchange, the State Department changed the way which notified Secretary Clinton telephone calls, resolving the problem that triggered this
e-mail.
16.
Email exchanges among your top aides and assistants August 30, 2011
discuss providing you with State Department-issued BlackBerry State Department
email address. the course these discussions, State Department Executive Secretary
Stephen Mull wrote, [W]e are working provide the Secretary per her request
Department issued BlackBerry replace her personal unit which malfunctioning
(possibly because her personal email server down). will prepare two versions for
her use one with operating State Department email account (which would mask her
identity, but which would also subject FOIA requests). Similarly, John Bentel, the
Director Information and Records Management the Executive Secretariat, wrote,
You should aware that any email would through the Department infrastructure
and [be] subject FOIA searches. Did you request State-Department issued
Blackberry State Department email account around August 2011, and, so, why
did you continue using your personal device and clintonemail.com email account
conduct official State Department business instead replacing your device and account
with State Department-issued BlackBerry State Department email account? Include your answer whether the fact that State Department-issued BlackBerry State
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
Department email address would subject FOIA affected your decision. Copies the
email exchanges are attached Exhibit for your review.
Response: Secretary Clinton does not recall requesting State Department-issued
Blackberry State Department e-mail account around August 2011.
17. February 2011, Assistant Secretary Boswell sent you Information
Memo noting dramatic increase since January 2011 attempts compromise the
private home email accounts senior Department officials. Assistant Secretary Boswell
urge[d] Department users minimize the use personal web-email for business. Did
you review Assistant Secretary Boswell Information Memo after February 2011,
and, so, why did you continue using your clintonemail.com email account conduct
official State Department business? Include your answer any steps you took minimize
use your clintonemail.com email account after reviewing the memo. copy Assistant
Secretary Boswell February 2011 Information Memo attached Exhibit for your
review.
Response: Secretary Clinton objects Interrogatory No. outside the scope
permitted discovery, the Court May 2016 Order provides that Plaintiff not entitled
discovery the subject cybersecurity issues. Dkt. #73, 13. Subject and without
waiving the foregoing objection, Secretary Clinton states that she does not recall reviewing
Assistant Secretary Bowell Information Memo attached Exhibit Plaintiff
Interrogatories during her tenure Secretary State.
18. June 28, 2011, you sent message all State Department personnel
about securing personal email accounts. the message, you noted recent targeting
personal email accounts online adversaries and directed all personnel [a]void
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
conducting official Department business from your personal email accounts. Why did you
continue using your clintonemail.com email account conduct official State Department
business after June 28, 2011, when you were advising all State Department Personnel
avoid doing so? copy the June 28, 2011 message attached Exhibit for your
review.
Response: Secretary Clinton objects Interrogatory No. outside the scope
permitted discovery, the Court May 2016 Order provides that Plaintiff not entitled
discovery the subject cybersecurity issues. Dkt. #73, 13. Secretary Clinton further
objects Interrogatory No. the ground that mischaracterizes Secretary Clinton the
sender and author the June 28, 2011 cable attached Plaintiff Interrogatories Exhibit
During Secretary Clinton tenure Secretary State, all cables originating from Main State
ended with the name CLINTON. The presence Secretary Clinton name the end the
cable was formality, and did not mean that she sent, authored, reviewed the cable. Subject and without waiving the foregoing objections, Secretary Clinton states that she does not recall
seeing the June 28, 2011 cable attached Exhibit Plaintiff Interrogatories during her
tenure Secretary State.
19.
Were you ever advised, cautioned, warned about hacking attempted
hacking your clintonemail.com email account the server that hosted your
clintonemail.com account and, so, what did you response the advice, caution,
warning?
Response: Secretary Clinton objects Interrogatory No. outside the scope
permitted discovery, the Court May 2016 Order provides that Plaintiff not entitled
discovery the subject cybersecurity issues. Dkt. #73, 13. Secretary Clinton further
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
objects Interrogatory No. insofar requests information about whether Secretary Clinton
was advised, cautioned, warned about hacking attempted hacking her clintonemail.com
e-mail account after her tenure Secretary State, which irrelevant the purpose for her
creation and operation the clintonemail.com account while Secretary State and therefore
outside the scope permitted discovery. Subject and without waiving the foregoing
objections, Secretary Clinton states that she does not recall being advised, cautioned, warned
during her tenure Secretary State about hacking attempted hacking her
clintonemail.com e-mail account the server that hosted her clintonemail.com account.
20.
When you were preparing leave office, did you consider allowing the State
Department access your clintonemail.com email account manage and preserve the
official emails your account and search those emails response FOIA requests?
you considered allowing access your email account, why did you decide against it?
you did not consider allowing access your email account, why not?
Response: Secretary Clinton objects Interrogatory No. the ground that
requests information that outside the scope permitted discovery for the reason set forth
General Objection No. Secretary Clinton further objects Interrogatory No. the ground
that the word manage vague. Subject and without waiving the foregoing objections,
Secretary Clinton states that she does not recall considering whether allow the State
Department access her clintonemail.com e-mail account when she was preparing leave
office. She believed that her e-mails with persons with state.gov e-mail accounts were already
captured the State Department recordkeeping systems. Secretary Clinton does not recall
anyone from the State Department asking her for access her clintonemail.com e-mail account asking her print her work-related e-mails when she was preparing leave office.
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
21.
After you left office, did you believe you could alter, destroy, disclose, use
email you sent received concerning official State Department business you saw fit?
not, why not?
Response: Secretary Clinton objects Interrogatory No. outside the scope
permitted discovery this case for the reason set forth General Objection No. Secretary
Clinton further objects Interrogatory No. the ground that requests information that
outside the scope permitted discovery for the reason set forth General Objection No.
Subject and without waiving the foregoing objections, Secretary Clinton states that she does
not recall considering after she left office whether she could alter, destroy, disclose, use emails concerning official State Department business. Secretary Clinton further refers Plaintiff
her Response Interrogatory No. 22.
22. late 2014, the State Department asked that you make available the
Department copies any federal records which you were aware, such email sent received personal email account while serving Secretary State. After you left
office but before your attorneys reviewed the email your clintonemail.com email account response the State Department request, did you alter, destroy, disclose, use any
the email the account authorize instruct that any email the account altered,
destroyed, disclosed, used? so, describe any email that was altered, destroyed,
disclosed, used, when the alteration, destruction, disclosure, use took place, and the
circumstances under which the email was altered, destroyed, disclosed, used? copy November 12, 2014 letter from Under Secretary State for Management Patrick
Kennedy regarding the State Department request attached Exhibit for your
review.
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
Response: Secretary Clinton objects Interrogatory No. outside the scope
permitted discovery this case for the reason set forth General Objection No. Secretary
Clinton further objects Interrogatory No. the ground that requests information that
outside the scope permitted discovery for the reason set forth General Objection No.
Secretary Clinton further objects Interrogatory No. insofar requests information about
all e-mail her clintonemail.com account, including personal e-mail. Subject and without
waiving the foregoing objections, Secretary Clinton states that she does not recall altering,
destroying, disclosing, using any e-mails related official State Department business from
her tenure Secretary State her clintonemail.com account instructing anyone else after she left office and before her attorneys reviewed the e-mails her clintonemail.com email account response the State Department request.
23.
After your lawyers completed their review the emails your
clintonemail.com email account late 2014, were the electronic versions your emails
preserved, deleted, destroyed? they were deleted destroyed, what tool software
was used delete destroy them, who deleted destroyed them, and was the deletion
destruction done your direction?
Response: Secretary Clinton objects Interrogatory No. outside the scope
permitted discovery for the reason set forth General Objection No. Secretary Clinton
further objects Interrogatory No. the ground that requests information that outside
the scope permitted discovery for the reason set forth General Objection No. Secretary
Clinton further objects Interrogatory No. insofar requests information about all e-mail her clintonemail.com account, including personal e-mail. Subject and without waiving the
foregoing objections, Secretary Clinton states that was her expectation that all her work-
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
related and potentially work-related e-mail then her custody would provided the State
Department response its request. Secretary Clinton believes that her attorneys retained
copies the e-mails provided the State Department December 2014, but she does not have
any personal knowledge about the details that process. Secretary Clinton decided that, once
her work-related and potentially work-related e-mails were provided the State Department, she
had reason keep her personal e-mails, which did not relate official State Department
business. She believes that her personal e-mails were not kept, and she does not have any
personal knowledge about the details that process.
24.
During your October 22, 2015 appearance before the U.S. House
Representatives Select Committee Benghazi, you testified that percent your
emails were the State system and they wanted see them, they would certainly
have been able so. Identify the basis for this statement, including all facts which
you relied support the statement, how and when you became aware these facts, and, you were made aware these facts through another person, identify the person
who made you aware these facts.
Response: Secretary Clinton objects Interrogatory No. the ground that calls
for information protected the attorney-client privilege.
25.
Identify all communications between you and Brian Pagliano concerning
relating the management, preservation, deletion, destruction any emails your
clintonemail.com email account, including any instruction direction Mr. Pagliano
about the management, preservation, deletion, destruction emails your account
when transferring the clintonemail.com email system any alternate replacement
server. For each communication, identify the time, date, place, manner (e.g., person,
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
writing, telephone, electronic other means), persons present participating,
and content the communication.
Response: Secretary Clinton objects Interrogatory No. the ground that
requests information that outside the scope permitted discovery for the reasons set forth
General Objection No. Secretary Clinton further objects Interrogatory No. the ground
that the word management vague. Secretary Clinton further objects Interrogatory No.
insofar requests information related alternate replacement servers used after Secretary
Clinton tenure Secretary State. Subject and without waiving the foregoing objections,
Secretary Clinton states that she does not recall having communications with Bryan Pagliano
concerning relating the management, preservation, deletion, destruction any e-mails
her clintonemail.com email account.
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
Dated: October 13, 2016
By:
/s/ David Kendall
David Kendall (D.C. Bar No. 252890)
Katherine Turner (D.C. Bar No. 495528)
Amy Mason Saharia (D.C. Bar No. 981644)
WILLIAMS CONNOLLY LLP
725 Twelfth Street, N.W.
Washington, 20005
Telephone: (202) 434-5000
Facsimile: (202) 434-5029
dkendall@wc.com
kturner@wc.com
asaharia@wc.com
Counsel for Non-Party Hillary Rodham
Clinton
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
Case 1:13-cv-01363-EGS Document 137-1 Filed 10/13/16 Page
CERTIFICATE SERVICE David Kendall, counsel for Non-Party Hillary Rodham Clinton, certify that,
October 13, 2016, copy the foregoing Response Plaintiff Interrogatories was filed via the
Court electronic filing system, and served via that system upon all parties required served.
/s/ David Kendall
David Kendall