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Judicial Watch • JW v State iPad iPhone 00646

JW v State iPad iPhone 00646

JW v State iPad iPhone 00646

Page 1: JW v State iPad iPhone 00646

Category:FOIA Request

Number of Pages:22

Date Created:September 2, 2015

Date Uploaded to the Library:September 02, 2015

Tags:Edney, cotca, Ramona, iPad, iPhone, 00646, Marsha, Plaintiffs, search, documents, responsive, Hillary Clinton, defendant, production, filed, State Department, plaintiff, document, records, FOIA, department, court, IRS, CIA


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Case 1:15-cv-00646-CKK Document Filed 09/01/15 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
Plaintiff,
U.S DEPARTMENT STATE,
Defendant.
Civ. No. 1:15-cv-00646 (CKK)
JOINT STATUS REPORT
Plaintiff Judicial Watch, Inc. and Defendant U.S. Department State, counsel and
pursuant the Courts Minute Order entered July 2015, respectfully submit this Joint Status
Report. the July Minute Order, the Court required (1) Defendant make its first production documents later than August 20, 2015 and (2) the parties file joint status report later than September 2015 which the parties propose schedule for further productions
and indicate the volume and scope ofresponsive documents. The parties are unable agree
proposed schedule and submit their separate statements and recommendations the Court
below.
Plaintiffs Statement and Recommendations
The Courts July Minute Order clearly required Defendant make its first
production responsive records later than August 20, 2015, and indicate the volume and
scope responsive documents. Defendant failed meet its obligations all fronts. the past sixty (60) days since the parties last Joint Status Report July
2015 Defendant produced two pages responsive email records (see emails attached
Exhibit I), its production was late (see August 27, 2015 email attached Exhibit and has
Case 1:15-cv-00646-CKK Document Filed 09/01/15 Page
not provided the information requested the Courts July 2015 order concerning the scope
and volume all potentially responsive records. August 27, 2015, one week after the Court-ordered production deadline,
Defendant produced its first set records via email response Plaintiffs FOIA requests.
The production consisted two pages email string dated February 2009 between Eric
Boswell, Donald Reid, Patrick Donovan and one other unidentified official, with the
subject line PDAs for and Staff. See Ex. Defendant withheld third email full the
allegation that exempt under FOIA. Id.
Concerning the scope the search, Defendant indicates only that initiated
searches the Bureau Diplomatic Security (DS) and the Office the Executive Secretariat
(S/ES). Id. Defendant did not indicate how many records reviewed part the initial
production two emails. August 27, 2015, Defendant indicated while conferring with Plaintiff that
located additional 250 pages potentially responsive records. Defendant did not indicate
when located these records, where located these records and why did not include these
records its review the initial production. Defendant also stated that its search was ongoing,
but did not give any indication when will complete its search all potentially responsive
records. also did not indicate the scope the search the volume all potentially
responsive records. Plaintiff requested that Defendant supplement its response and provide this
information before todays Joint Status Report. Defendant did not so.
Defendant remains unwilling provide time estimate when will complete
its initial search potentially responsive records, the scope its search, and the volume all
potentially responsive records. Defendant has yet identify the search terms used
-2-
Case 1:15-cv-00646-CKK Document Filed 09/01/15 Page
commence its search and S/ES. For example, two emails posted late yesterday evening
Defendant its FOIA line page refer the iPad requested Secretary Clinton
hPad. The email communications are between Secretary Clinton (hrod 17@clintonemail.com),
Philippe Reines (an unidentified non-state.gov email account, PIR