JW v State Interrogatories 01242
Number of Pages:4
Date Created:January 15, 2019
Date Uploaded to the Library:January 15, 2019
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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 INTERROGATORIES 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, submits the following interrogatories answered under oath Defendant U.S. Department State. INSTRUCTIONS AND DEFINITIONS Your answers these interrogatories should include information within your actual constructive possession, custody, control, including information which may held your attorneys, representatives, all persons acting under, by, through you, subject your control supervision, and all persons acting your behalf. you cannot answer interrogatory fully and completely, answer much you can and provide all facts upon which you rely support your contention that you cannot answer fully and completely. each instance which you claim insufficient knowledge information answer interrogatory fully and completely, describe all the efforts you made locate the information needed answer the interrogatory and identify each person, any, who known you have such information. answering interrogatory, state whether the information furnished the answer within the personal knowledge the person answering and, not, identify each person who has personal knowledge the information furnished the answer. you object any portion interrogatory, but not the entire interrogatory, identify the specific portion the interrogatory which objection made and answer the portion the interrogatory which objection made. you object any interrogatory the grounds that the interrogatory overly broad unduly burdensome, answer the interrogatory providing all information that not alleged overly broad unduly burdensome and identify the nature, quality, quantity, volume the withheld information and the effort that would required provide the withheld information. you object any interrogatory the grounds that the interrogatory calls for information that subject claim privilege, state 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. And and are construed both conjunctively and disjunctively, necessary, make the interrogatory inclusive rather than exclusive. Similarly, any use the singular shall also mean the plural and vice versa, give the interrogatory its broadest possible meanmg. The definitions provided below are hereby incorporated into each interrogatory which the term appears: Identify when used with respect natural person means state the persons full name, present last known business address (or, business address, home address), and the persons employer and position the time question with respect the particular interrogatory involved. Office the Secretary refers the Office the Secretary within the U.S. Department State. State Department refers the U.S. Department State. INTERROGATORIES Identify the individuals referenced the first full paragraph the fourth page the Federal Bureau oflnvestigations December 30, 2015 report (available ECF No. 62-1) describing its December 22, 2015 interview Bryan Pagliano. Identify the analysts who performed the search the Office the Secretary records September 23, 2014 described paragraphs 14-16 John Hacketts July 2015 declaration (available ECF 19-2). Identify the individuals who performed the search described paragraph John Hacketts July 2015 declaration (available ECF 19-2) well the dates they searched. Identify the number emails contained within State Department records sent from the clintonemail.com domain name including the carbon copy and blind copy functions for the time period from September 11, 2012 February 2013 for the following individuals: Alice Wells; Andrew Shapiro; Anne-Marie Slaughter; Caroline Adler; Cheryl Mills; Claire Coleman; Dan Schwerin; Huma Abedin; Jacob Sullivan; Joseph MacManus; Judith McHale; Lauren Jiloty; Lona Valmoro; Maria Sand; Melanne Verveer; Monica Hanley; Patrick Kennedy; Philippe Reines; Richard Verma; Robert Russo; Susan Rice; Victoria Nuland; Wendy Sherman; and William Bums Dated: January 15, 2019 Respectfully submitted, /s/ Michael Bekesha Michael Bekesha D.C. Bar No. 995749 JUDICIAL WATCH, INC Counsel for PlaintiffJudicial Watch, Inc.