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Judicial Watch • JW v. State Jiloty Answers 01242

JW v. State Jiloty Answers 01242

JW v. State Jiloty Answers 01242

Page 1: JW v. State Jiloty Answers 01242

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Number of Pages:8

Date Created:May 10, 2019

Date Uploaded to the Library:June 04, 2019

Tags:Jiloty, 01242, Susan Rice, Freedom, Benghazi, clinton, State Department, FOIA


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THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
Plaintiff,
U.S. DEPARTMENT STATE,
Defendant.
Civil Action No. 14-cv-1242 (RCL)
LAUREN JILOTY RESPONSES AND OBJECTIONS
PLAINTIFF INTERROGATORIES LAUREN JILOTY
Pursuant Rule the Federal Rules Civil Procedure, and subject and without
waiving her objection the propriety any discovery this matter, Lauren Jiloty hereby
responds Plaintiff Judicial Watch, Inc. Judicial Watch Interrogatories Lauren Jiloty:
INTERROGATORY ONE:
Did you load contacts into any Secretary Clinton Blackberries during her tenure the
State Department? so, identify those contacts.
Response: Ms. Jiloty objects this interrogatory because seeks information that not
Ms. Jilotys possession, custody, control. Ms. Jiloty served special assistant Secretary
Clinton from December 2008 through October 2011, ending her tenure the State Department
approximately eleven months before the Benghazi attacks. this role, Ms. Jiloty conducted
number activities Secretary Clinton behalf, including accepting and making phone calls,
scheduling, and, occasionally, loading contacts into Secretary Clinton Blackberry. Ms. Jiloty
loaded contacts into Secretary Clinton Blackberry only when requested the Secretary another
staff member. When Ms. Jiloty received this request, the Secretary another staff member would
provide the Blackberry Ms. Jiloty, Ms. Jiloty would obtain the Blackberry from secure storage
location outside the Secretary office. After loading the contact information, Ms. Jiloty would then
immediately return the Blackberry the Secretary staff member the Blackberry secure
storage location outside the Secretary office. Ms. Jiloty did not have independent control the
Blackberry and its contact list. Ms. Jiloty also did not have the password needed access the
Blackberry and its contents and relied either the Secretary staff member open for her.
Unless permitted access the Blackberry for the discrete and limited task uploading contact
information, Ms. Jiloty did not otherwise have access the Blackberry and its contact list. After
conducting reasonably diligent search for any list contacts that might responsive this
interrogatory, Ms. Jiloty has confirmed that she does not have list contacts. Accordingly, Ms.
Jiloty unable identify the contacts the Blackberry. Ms. Jiloty further objects Plaintiff
characterization this interrogatory one interrogatory, when fact contains discrete
subpart. Fed. Civ. 33(a)(1). Going forward, Ms. Jiloty will consider this interrogatory
count two (2) interrogatories for purposes the presumptive limit the number
interrogatories set forth Federal Rule Civil Procedure 33(a)(1).
INTERROGATORY TWO:
Did you create, update, maintain master list all contacts you added and/or updated
Secretary Clinton blackberries? so, when did you create the list, how often did you update it,
where and how was the list saved, was updated throughout Secretary Clinton tenure the State
Department, and who had access it?
Response: Ms. Jiloty objects Plaintiff characterization this interrogatory one
interrogatory, when fact contains six (6) discrete subparts. Fed. Civ. 33(a)(1). Going
forward, Ms. Jiloty will consider this interrogatory count seven (7) interrogatories for purposes the presumptive limit the number interrogatories set forth Federal Rule Civil Procedure
33(a)(1). Ms. Jiloty did not create, maintain, update master list all contacts that Ms. Jiloty
added updated Secretary Clinton Blackberry. Once Ms. Jiloty received request add
update contact the Blackberry, the Secretary another staff member would provide the
Blackberry Ms. Jiloty, Ms. Jiloty would obtain the Blackberry from secure storage location
outside the Secretary office for this discreet and limited task. After the Blackberry had been
opened for her the Secretary staff member and after loading the contact information, Ms. Jiloty
would then immediately return the Blackberry the Secretary the staffer the Blackberry
secure storage location outside the Secretary office. Ms. Jiloty did not have independent control the Blackberry and its contact list. Accordingly, Ms. Jiloty unable provide master list
all contacts that were added updated the Blackberry.
INTERROGATORY THREE:
Identify the individuals whom Secretary Clinton most frequently emailed during her
tenure the State Department about official government business.
Response: Ms. Jiloty objects this interrogatory because beyond the scope the
discovery ordered the Court. particular, irrelevant the question whether the State
Department conducted adequate search response the FOIA request that Judicial Watch
submitted the State Department regarding certain talking points provided the State Department Susan Rice about the Benghazi attacks. Ms. Jiloty further objects this interrogatory overly
broad the extent requires Ms. Jiloty provide the names individuals who are not involved the case issue. Ms. Jiloty also objects the interrogatory the extent requires Ms. Jiloty
provide information that not within her personal knowledge. Ms. Jiloty was not privy the
Secretary email traffic, except insofar she received email from the Secretary.
result, Ms. Jiloty cannot provide the information sought this interrogatory. Any attempt
would require speculation.
Although Ms. Jiloty occasionally loaded contacts into Secretary
Clinton Blackberry, Ms. Jiloty unable identify the individuals with whom Secretary Clinton
most frequently emailed because this exceeds the scope her personal knowledge and any
knowledge gained her professional capacity special assistant Secretary Clinton.
INTERROGATORY FOUR:
Did you use non-State Department email account conduct official government business
while employed the State Department? so, why did you so, what email account did you use,
how many times did you use it, and with whom did you email?
Response: Ms. Jiloty objects Plaintiff characterization this interrogatory one
interrogatory, when fact contains four (4) discrete subparts. Fed. Civ. 33(a)(1). Going
forward, Ms. Jiloty will consider this interrogatory count five (5) interrogatories for purposes the presumptive limit the number interrogatories set forth Federal Rule Civil Procedure
33(a)(1). Ms. Jiloty almost always used her State Department email conduct official government
business while employed the State Department. When Ms. Jiloty occasionally sent received
emails her personal email account, they generally fell two categories: (1) Ms. Jiloty needed
complete work from home, (2) the State Department email servers failed promptly deliver
earlier message and the Secretary sent follow-up email asking Ms. Jiloty received the earlier
message sent Ms. Jiloty State Department email account. both cases, Ms. Jiloty practice
was forward the work she had completed home her State Department email account
copy her State Department email account her response forward the email her State
Department email account and then respond the sender from her State Department email account.
Ms. Jiloty estimates that during her two-and-a-half year tenure the State Department, she received
less than one hundred State Department official business emails her personal email account.
INTERROGATORY FIVE:
Have you deleted emails with State Department email accounts from your non-State
Department email account? so, when did you delete them, why did you delete them, how many
did you delete, and did you copy archive them any way before deleting them?
Response: Ms. Jiloty objects Plaintiff characterization this interrogatory one
interrogatory, when fact contains four (4) discrete subparts. Fed. Civ. 33(a)(1). Going
forward, Ms. Jiloty will consider this interrogatory count five (5) interrogatories for purposes the presumptive limit the number interrogatories set forth Federal Rule Civil Procedure
33(a)(1). Ms. Jiloty has not deleted any emails with State Department email accounts from her nonState Department email account.
INTERROGATORY SIX: you currently have any State Department records your possession? not, does the
State Department have all emails sent received you from both your State Department and nonState Department email accounts which you conducted official government business?
Response: Ms. Jiloty objects Plaintiff characterization this interrogatory one
interrogatory, when fact contains discrete subpart. Fed. Civ. 33(a)(1). Going forward,
Ms. Jiloty will consider this interrogatory count two (2) interrogatories for purposes the
presumptive limit the number interrogatories set forth Federal Rule Civil Procedure
33(a)(1). Ms. Jiloty has emails with State Department email accounts that were sent her non-State
Department email accounts. When Ms. Jiloty received State Department email her personal
email account, Ms. Jiloty practice was forward the work she had completed home her State
Department email account, copy her State Department email account her response, forward the
email her State Department email account and then respond the sender from her State
Department email account. Accordingly, the State Department has all emails sent received
her received her from her State Department and non-State Department email accounts which
she conducted official government business.
INTERROGATORY SEVEN:
During Secretary Clinton tenure the State Department, identify all individuals who
conducted searches for records Secretary Clinton response Freedom Information Act
requests.
Response: Ms. Jiloty objects this interrogatory because overly broad and beyond the
scope the discovery ordered the Court. particular, the interrogatory focus all FOIA
requests irrelevant the question whether the State Department conducted adequate search response this specific FOIA request that Judicial Watch submitted the State Department
regarding certain talking points provided the State Department Susan Rice about the Benghazi
attacks. Ms. Jiloty further objects this interrogatory because seeks information outside the scope Ms. Jilotys personal knowledge any knowledge gained her professional capacity special
assistant Secretary Clinton. Ms. Jiloty was not involved conducting searches for records
response Freedom Information Act requests. Further, Ms. Jiloty unable identify any
individuals who conducted these searches during her tenure the State Department. Furthermore,
Ms. Jiloty left the State Department October 2011, approximately eleven months before the
Benghazi attacks. such, Ms. Jiloty unable identify any individuals who conducted searches
for records Secretary Clinton response this specific Freedom Information Act request.
INTERROGATORY EIGHT:
During Secretary Clinton tenure the State Department, describe your role searching
for records otherwise responding Freedom Information Act requests.
Response: Ms. Jiloty objects this interrogatory because overly broad and beyond the
scope the discovery ordered the Court. particular, irrelevant the question whether
the State Department conducted adequate search response this specific FOIA request that
Judicial Watch submitted the State Department regarding certain talking points provided the
State Department Susan Rice about the Benghazi attacks. Ms. Jiloty was not involved
conducting searches for records response Freedom Information Act requests during her
tenure the State Department. Ms. Jiloty left the State Department October 2011, approximately
eleven months before the Benghazi attacks. result, Ms. Jiloty had role conducting searches
for records Secretary Clinton response this specific Freedom Information Act request.
Dated: May 10, 2019
Respectfully submitted,
/s/ Michael Neil
Michael ONeil
D.C. Bar No. 81034
KL Gates LLP
1601 Street,
Washington, D.C. 20006
(202) 661-6226
Nancy Iheanacho
KL Gates LLP
1601 Street,
Washington, D.C. 20006
(202) 778-9423
Counsel for Lauren Jiloty
VERIFICATION Lauren Jiloty, state that have read Plaintiff Judicial Watch Inc.s Interrogatories
Lauren Jiloty. declare under penalty perjury that answers are true and correct the best knowledge, information, and belief.
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Dated: May L) 2019
Laure1iJHoty