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Judicial Watch • JW v. State Lukens Testimony 01363

JW v. State Lukens Testimony 01363

JW v. State Lukens Testimony 01363

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Date Created:May 26, 2016

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Transcript Lewis Alan Lukens
Date: May 18, 2016
Case: Judicial Watch, Inc. -v- U.S. Department State
Planet Depos, LLC
Phone: 888-433-3767
Fax: 888-503-3767
Email: transcripts@planetdepos.com
Internet: www.planetdepos.com
Worldwide Court Reporting Interpretation Trial Services THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
Plaintiff, Civil Action No. 13-CV-1363
U.S. DEPARTMENT STATE,
Defendant.
Videotaped Deposition LEWIS ALAN LUKENS
Washington,
Wednesday, May 18, 2016
10:00 a.m.
Job No.:
111879
Reported By:
Rebecca Stonestreet, RPR, CRR
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Videotaped Deposition LEWIS ALAN LUKENS,
held the offices of:
U.S. DEPARTMENT JUSTICE Massachusetts Avenue,
Washington,
(202) 514-3319
20035
Pursuant notice, before
Rebecca Stonestreet, Court Reporter and
Notary Public and for the District Columbia.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 BEHALF PLAINTIFF:
MICHAEL BEKESHA, ESQUIRE
JAMES PETERSON, ESQUIRE
PAUL ORFANEDES, ESQUIRE
RAMONA COTCA, ESQUIRE
JUDICIAL WATCH, INC.
425 Third Street,
Suite 800
Washington,
(202) 646-5199
20024 BEHALF DEFENDANT:
CAROLINE LEWIS WOLVERTON, ESQUIRE
MARCIA BERMAN, ESQUIRE
STEVEN MYERS, ESQUIRE
U.S. DEPARTMENT JUSTICE
FEDERAL PROGRAMS BRANCH Massachusetts Avenue,
Washington,
(202) 514-3319
20530
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
ALSO PRESENT:
Thomas Fitton, President, Judicial Watch
Lara Berlin, Department State
Jeremy Dineen, Videographer
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
EXAMINATION LEWIS LUKENS
PAGE Mr. Bekesha Ms. Wolverton Mr. Bekesha
(Attached transcript.)
LUKENS DEPOSITION EXHIBIT
Exhibit
E-mail string
Exhibit
E-mail string
Exhibit
E-mail string
Exhibit
E-mail string
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
PAGE
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
THE VIDEOGRAPHER:
Here begins tape number
10:02:40 the videotaped deposition Lewis Lukens, the
10:02:42
matter Judicial Watch, Inc.
10:02:45
Department State, the U.S. District Court for
10:02:49
the District Columbia, case number 13-CV-1363.
10:02:53
the U.S.
Todays date May 18th, 2016, the time
the video monitor oclock.
today Jeremy Dineen, representing
10:03:08
Planet Depos.
10:03:12
The videographer
10:02:58
This video deposition taking place the
10:03:03
10:03:13
U.S. Department Justice, Massachusetts Avenue,
10:03:15
Northwest, Washington, D.C.
10:03:20
Would counsel please voice
10:03:22
identify themselves and state whom they
10:03:24
represent.
10:03:26
MR. BEKESHA:
plaintiff, Judicial Watch.
Michael Bekesha behalf
MR. ORFANEDES:
Paul Orfanedes behalf
plaintiff, Judicial Watch.
MS. COTCA:
Ramona Cotca behalf
Judicial Watch.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:03:26
10:03:33
10:03:33
10:03:34
10:03:34
10:03:36
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
MR. PETERSON: Judicial Watch.
MR. FITTON:
James Peterson behalf
10:03:39 Tom Fitton.
president Judicial Watch.
MS. WOLVERTON:
behalf the Department State.
MS. BERMAN:
Caroline Wolverton
Marcia Berman behalf
the Department State.
MR. MYERS:
MS. BERLIN:
10:03:42
10:03:47
10:03:48
10:03:48
Department State.
10:03:40
10:03:40
10:03:37
Steven Myers behalf the
10:03:49
10:03:51
Lara Berlin, Department
State.
10:03:52
10:03:54
THE VIDEOGRAPHER:
The court reporter
10:03:54
today Rebecca Stonestreet, representing
10:03:55
Planet Depos.
10:03:58
the witness and can begin.
Would the reporter please swear
10:03:59
(Oath administered court reporter.)
10:04:12
MS. WOLVERTON:
10:04:12
And Mr. Lukens reserves
the right read and sign the transcript the
10:04:14
conclusion the deposition.
10:04:16 BEKESHA:
Okay.
Thank you.
10:04:16
10:04:16
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
(LEWIS ALAN LUKENS, having been duly sworn,
10:04:16
testified follows:)
10:04:16
EXAMINATION COUNSEL FOR PLAINTIFF MR. BEKESHA:
11:40:16
10:04:19
Good morning, Mr. Lukens.
10:04:19
Good morning.
10:04:19 name Michael Bekesha.
10:04:19
attorney with Judicial Watch. here ask you
10:04:20
some questions today about one Judicial Watchs
10:04:23
Freedom Information Act lawsuits against the
10:04:25
State Department, specifically questions
10:04:28
surrounding the creation, purpose, and use the
10:04:30
Clintonemail.com system then Secretary State
10:04:33
Hillary Clinton and one her deputies, the Deputy
10:04:37
Chief Staff Huma Abedin, system they used
10:04:37
conduct official government business.
10:04:43
Before begin, could you please state
and spell your full name for the record?
10:04:46
L-U-K-E-N-S.
10:04:56
10:04:56
Lewis, L-E-W-I-S, Alan, A-L-A-N, Lukens,
10:04:43
Also would like over few ground
rules before begin.
Your counsel might have
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:04:48
10:04:58
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
already talked you about them, but will help
10:05:01
make this deposition little bit more smoothly.
10:05:04 you dont hear one questions, happy repeat it.
10:05:07
please let know.
10:05:09
you dont understand one questions, please
10:05:12
let know and Ill try rephrase the question
10:05:15 have you have better understanding the
10:05:15
question being asked.
10:05:17
Its also important that you respond out
loud any questions.
head, make any hand gestures, the court reporter
10:05:22
cant record that.
10:05:26
all questions spoken all answers
10:05:28
spoken.
10:05:32 you nod, shake your
10:05:17
And would easier for
Finally, you could wait until done
10:05:20
10:05:33
asking questions, your counsel has any
10:05:36
objections, wait until those are done, because its
10:05:38
difficult for the court reporter transcribe when
10:05:41
were speaking over each other.
10:05:44
With all that out the way, could you
10:05:46
give please give brief background about
10:05:48
your tenure the State Department?
10:05:51
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Ive been Foreign Service officer for
10:05:53
Ive served Southern China; the
10:05:56 years.
Ivory Coast; Sydney, Australia; Dublin,
10:06:01
Ireland; Baghdad; Vancouver, British Columbia;
10:06:06
Dakar, Senegal; and three tours
10:06:10
Washington, D.C., well current position
10:06:12
San Francisco.
10:06:14
Okay.
And before you know, today
10:06:14
were going focus your time one your
10:06:17
tours Washington, D.C., specifically when you
10:06:20
were deputy executive secretary the State
10:06:21
Department, and executive director.
10:06:25
was that between 2008 and 2009?
And think,
10:06:28 was between 2008 and 2011.
10:06:31
Yeah, sorry about that.
10:06:34
Before discuss that role specifically,
10:06:36 would just like talk about the general
10:06:38
structure the Office the Executive
10:06:41
Secretariat.
10:06:44
Executive Secretariat?
Whats the general purpose the
Generally would describe that the
office that facilitates the functioning the
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:06:46
10:06:47
10:06:50
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
bureaucracy for the Secretary State.
10:06:55
Okay.
And how that office structured?
10:06:59
Theres executive secretary who has
10:07:00
well, when worked there had four deputy
10:07:03
executive secretaries who between them supervised
10:07:06
logistics, paper flow, travel, and other support
10:07:11
for the secretary, the deputy secretary, and under
10:07:17
secretaries state and their staffs.
10:07:21
And you were one those four deputy
executive secretaries?
10:07:22
10:07:26 was.
10:07:26
And who were the executive secretaries
10:07:27
during your time there?
10:07:29
Daniel Smith was the executive secretary
10:07:30
for first year, from 2008 2009, and then
10:07:33
Steve Mull was executive secretary from 2009 until
10:07:36 departure 2011.
10:07:40
Okay.
Thank you. what were your
10:07:44
basic job functions deputy guess lets take
10:07:46 step back.
10:07:50
Your title was deputy executive secretary
and executive director. there difference
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:07:52
10:07:53
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
between the deputy executive secretary role and the
10:07:56
executive director role?
10:07:59
secretaries.
and paperwork, and role was logistics and
10:08:09
management support.
10:08:11
title, rank, the other deputies, but function
10:08:13
was quite different.
10:08:17 there are four deputy executive
Three them focus mostly policy
Okay. had the same sort
And how many did you have
10:08:01
10:08:05
10:08:18
employees working with you the executive
10:08:21
director position?
10:08:24 had roughly 110 employees working for
me.
10:08:24
10:08:28
And were there different departments
10:08:28
within that office that were reporting you?
10:08:30 had bureau security officer, had
10:08:33 human resources section, had budget section,
10:08:38 had general services section, and
10:08:42
communications section.
10:08:44
Could you talk little bit about the
general services section?
What was their role?
General services dealt with travel
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:08:44
10:08:46
10:08:49
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
support, with office space issues, with procurement
10:08:51
for the various offices.
10:08:55
it.
Thats basically about
10:08:58
Did the role change between the two
10:08:59
administrations, between Secretary Rice and
10:09:02
Secretary Clinton?
10:09:06
No.
10:09:06
Was your office involved responding
10:09:07
FOIA requests document requests from Congress?
10:09:13
No.
10:09:15
Was there separate department within
10:09:15
the executive secretariat that was responsible for
10:09:17
that?
10:09:20
Yes.
10:09:20
Who was charge that?
10:09:20
That office correspondence and records
10:09:22
unit, and that was the time headed
10:09:28
gentleman called Clarence Finney.
10:09:31
And did Mr. Finney report directly the
10:09:33
executive secretary did report one the
10:09:36
other deputy executive secretaries?
10:09:39 reported through one the deputy
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:09:41
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
the other deputies the executive secretary. 2009 you recall who would have
been reporting to?
10:09:43
10:09:45
10:09:49 dont recall.
10:09:49
Also within the Office the Executive
10:09:54
Secretariat, there office of, think its
10:09:58
Information Resource Management, IRM?
10:10:00
Yes.
10:10:03
Does that report does the director
10:10:03
S/ES-IRM report deputy executive secretary? reported me.
That was the
communications office that referenced.
Okay. you could talk little bit more about
10:10:18
communications.
10:10:11
10:10:13 IRM?
10:10:10
And what was the role
Thank you.
10:10:06
The role our IRM office was liaise
10:10:22
10:10:23
with the State Departments bigger IRM office
10:10:29
ensure that the State Department leadership and
10:10:31
their staff had the communications tools that they
10:10:33
needed their jobs.
10:10:35
And 2009, how large was that staff
within your office?
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:10:36
10:10:40
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Roughly 20, people.
10:10:42
Okay.
10:10:45
John Bentel.
10:10:47
And was there guess talk little
10:10:50
bit more about the liaising between the general IRM
10:11:01
and the one your department.
How did that
10:11:05
how did that play out?
Who was reporting did
10:11:08
they work together, was one person reporting
10:11:11
someone else?
10:11:14
And who was the director IRM? not sure understand the question.
10:11:16
Okay.
10:11:25 want change gears little
bit and talk about the transition between the two
10:11:28
administrations, Secretary Rice and former
10:11:31
and Secretary Clinton.
10:11:37
the transition Secretary Rice leaving the State
10:11:39
Department?
10:11:43
No.
10:11:43 you know who would have been involved
10:11:43
Did you have any role that transition process? would have been predecessor
executive director.
And what was was executive director
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:11:45
10:11:47
10:11:49
10:11:50
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 that time?
10:12:01
She was.
She was.
10:12:01
When did you become executive
director?
10:12:02
10:12:07 moved into the office September
10:12:08
2008, and double encumbered that position for
10:12:12
few months.
10:12:16
supporting the current Secretary State,
10:12:20
Condi Rice, and prepared for the transition and
10:12:23
prepared and started working bringing
10:12:27
the new team.
10:12:29 predecessor stayed the role
And when did that preparation start?
10:12:30 started September 2008.
10:12:32
Okay.
10:12:35
And what guess can
through that process.
did you start preparing?
What September 2008
10:12:39
10:12:41
Started preparing office space,
10:12:42
transition space for the new team. course
didnt know who the team was that point.
was really it. make the rounds the building and get
10:12:57
know the key players.
10:13:00
10:12:45
That
10:12:47 was sort opportunity for
10:12:54
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Okay.
And then when was the next big,
10:13:01
lack better term, milestone when
10:13:03
preparations started escalating little bit?
10:13:05 would say when President Obama named
Secretary Clinton his nominee.
10:13:08
10:13:12
And that would have been around
December 1st?
10:13:14
10:13:17 dont remember the date.
10:13:18
Okay.
10:13:19
But preparations started prior
Mrs. Clinton being sworn and taking office?
10:13:22
Yes.
10:13:25
What type preparations took place
10:13:25
after President Obama nominated Mrs. Clinton?
board.
Thats
10:13:36
really the main ones, until they came board.
10:13:42 started working bringing staff
10:13:28 said, office space issues.
And was there anybody within the
10:13:33
10:13:44
President-elects office somebody with
10:13:49
Mrs. Clinton that you were working with discussing
10:13:53
office space, transition space, and any those
10:13:56
logistics?
10:13:59 the State Department?
Did you have point contact outside
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:14:02
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
No.
10:14:02 then Mrs. Clinton the new
10:14:03
administration took over and Mrs. Clinton was sworn
10:14:11 January 21st, 2009.
10:14:14
Excuse me.
What happened what was the process
like when once she took office?
MS. WOLVERTON:
Objection.
10:14:18
10:14:21
Vague.
Prior couple days before she took
10:14:24
10:14:29
office, did you have any discussions with
10:14:32
individuals that may that may have entered
10:14:36
into her into her office, into the office the
10:14:39
secretary?
10:14:42
What kind discussions?
10:14:43
Discussions about office space, computer
10:14:44
equipment, how they show the first day, and
10:14:47
they need badges.
10:14:52
Basic logistics.
Yes.
10:14:55
Were those discussions taking place?
10:14:56
Yes.
10:14:57 you recall who you were discussing
10:14:58
those logistics with? had some discussions with Cheryl Mills.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:15:00
10:15:00
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Thats the only one can specifically remember.
Okay.
And you recall when those
10:15:11
10:15:13
discussions may have taken place, when the first
10:15:14
time you spoke with Ms. Mills?
10:15:18 dont recall when.
10:15:20
Had you known Ms. Mills prior this
10:15:20
transition process starting?
10:15:23
No.
10:15:25 lets talk little bit more detail
10:15:25
about what issues you were discussing with
10:15:30
Ms. Mills.
10:15:33
Yes.
What type office space?
Well, the Secretary decided fill
One them was office space?
10:15:34
For who?
10:15:35
10:15:37
second Deputy Secretary State position, which
10:15:43
had been the books but had not been filled
10:15:46
that date.
10:15:48
second Deputy Secretary State position would
10:15:51
sit.
10:15:55
can recall. there were questions about where the
That was really most the discussion that
Okay.
10:15:58
Was there discussion about
computer equipment?
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:15:58
10:16:00
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Not specifically.
10:16:00
Okay.
10:16:01
And then what does what did the
State Department prepare for Mrs. Clinton
10:16:07
assume the position when she was sworn in?
10:16:12
assume the Secretarys office was cleared out.
she assume the same office that Secretary Rice was
10:16:22
using?
10:16:27
MS. WOLVERTON:
MR. BEKESHA:
Objection.
Did
Compound.
Ill break down.
10:16:18
10:16:28
10:16:31
Lets start off with, did she use the
same office that Secretary Rice was using?
10:16:33
10:16:35
Yes.
10:16:40 what steps any were taken
10:16:40
prepare that office for Mrs. Clintons arrival? dont recall exactly.
They went and
10:16:42
10:16:45
cleaned the office and got prepared for new
10:16:48
occupant.
10:16:50
Any leftover records, you know what
would have happened those?
What about any computer equipment?
10:16:56 dont know.
10:16:51
10:16:56
10:16:57
you know Secretary Rice had computer her
10:17:01
PLANET DEPOS
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Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
desk?
10:17:05 dont know.
10:17:05 you know what would have happened
10:17:05
that computer equipment before Mrs. Clinton took
10:17:07
office?
10:17:10 dont know.
10:17:10 the process talking with Ms. Mills
10:17:10
about the transition, you know she asked for
10:17:15
Mrs. Clinton have computer her office?
10:17:20
She did not ask that.
10:17:23 you know computer was assigned
10:17:29
the Secretarys office?
10:17:32 dont believe was.
10:17:33 you know other secretaries before
10:17:35
her had computer assigned her office? believe Colin Powell had computer
the office.
Okay.
10:17:37
10:17:40
10:17:43 you know that computer was
10:17:44
the general OpenNet, was ClassNet, was
10:17:46 top secret classified machine? you know the
10:17:50
extent what type computer system was his
10:17:54
desk?
10:17:56
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 dont know.
10:17:56
While preparing for the transition, who
10:17:56
would charge setting e-mail accounts
10:18:02
for incoming employees incoming secretaries and
10:18:05
employees within the Office the Secretary?
10:18:09
That would the IRM office that worked
for me.
10:18:12
10:18:14 you know Mrs. Clinton the IRM
office set e-mail address for Mrs. Clinton?
10:18:14
10:18:18 dont believe they did.
10:18:21 you know why they didnt?
10:18:22 dont think was asked for.
10:18:24
Would Mrs. Clinton have was
10:18:27
required for Mrs. Clinton ask for e-mail
10:18:31
address for one assigned her?
10:18:34
Yes.
10:18:35
Was unusual the time did you
10:18:37
think was unusual that Mrs. Clinton didnt want
10:18:42 e-mail address assigned her?
10:18:45
No.
10:18:46
Why not?
10:18:47 not aware former Secretaries
10:18:47
PLANET DEPOS
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Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
State having e-mail addresses our system. you know any other employees within
10:18:52
10:18:57
the Office the Secretary was not assigned
10:18:59
e-mail address?
10:19:05
Not that aware of.
10:19:05
Did you ever e-mail send receive
10:19:06
e-mail with Mrs. Clinton, Secretary Clinton, during
10:19:15
the two years that you were there?
10:19:19
No.
MR. BEKESHA: going ahead and
mark this Exhibit Exhibit
(LUKENS Exhibit was marked for
10:19:21
identification and attached the transcript.) could have you take look whats
marked Exhibit you recognize this
document?
10:19:35
10:19:37
10:19:39
10:19:58
10:19:58
10:20:01
10:20:04 do.
10:20:04
Could you identify what this document is?
10:20:05
MS. WOLVERTON:
10:20:11
time read it, please?
MR. BEKESHA:
MS. WOLVERTON:
Can you give the witness
10:20:12
Yes.
Thank you.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:20:14
10:20:15
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Have you had chance look over the
document?
10:20:50
10:20:52
Yes.
10:20:52
Could you identify what the document is?
10:20:52
Its e-mail exchange between several
10:20:55
people regarding setting possibly setting
10:20:59 computer the Secretarys office.
10:21:03
Lets look the
10:21:05
guess the first e-mail the chain, which would
10:21:09
the second and the third page.
10:21:13 e-mail from Ms. Mills you.
correct?
Okay.
Thank you. looks like this that
10:21:19
10:21:22
Yes.
10:21:22 you could look bullet points number
10:21:23 and bullet point says:
Spoke Dan
setting counselor office for HRC she can
10:21:35
across hall regularly and check her e-mail.
10:21:40
10:21:28
Who Dan?
10:21:43
Dan Smith.
10:21:44
And was the executive secretary the
10:21:46
time?
10:21:50
Yes.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:21:50
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
And HRC Mrs. Clinton?
10:21:50 believe so.
10:21:54
Prior receiving this e-mail from
10:21:55
Ms. Mills, had you spoken with Dan Smith about this
10:22:00
issue?
10:22:04
Not that can recall.
10:22:04
Had you spoken Ms. Mills about this
10:22:06
issue prior this e-mail?
10:22:10 dont recall conversation with her.
10:22:12
Did you know anything about this issue,
10:22:13
about potentially setting computer the
10:22:17
office, before receiving this e-mail?
10:22:20 think that was the first time that
occurred me.
Okay.
10:22:23
10:22:29
Moving forward, later that day you
responded Ms. Mills.
was:
morning? workaround but need more info her use for
10:22:49
you.
10:22:54 the for HRC, can chat this
And then you say, may have thought BlackBerry.
One the things you said
10:22:29
Correct?
Yes.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:22:36
10:22:42
10:22:46
10:22:54
10:22:58
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Did you have conversation you
10:22:58
recall having conversation with Ms. Mills that
10:23:00
morning?
10:23:01
MS. WOLVERTON:
And just the e-mail
text use from you.
you.
MR. BEKESHA: sorry.
Thank you.
Yes, believe had conversation with
her that morning. you recall what that conversation
entailed?
10:23:08
10:23:08 think you said for
10:23:02
10:23:10
10:23:10
10:23:12
10:23:13
10:23:14
Yeah. the crux the issue was that
10:23:14
BlackBerrys and iPhones are not allowed the
10:23:20
Secretarys office suite, the question was, how
10:23:23 the Secretary going able check her
10:23:25
e-mails shes not able have the BlackBerry
10:23:28
her desk with her.
10:23:31
And what did you did you propose
solution that point?
10:23:39 proposal was set computer
10:23:40 her desk, standalone computer, for her
10:23:43
able access the Internet check her e-mails.
10:23:48
10:23:32
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Because she just want clear,
10:23:52
she didnt have computer her desk that
10:23:53
time?
10:23:56
Correct.
10:23:56
And why you know, why was the first
10:23:56
e-mail concerning setting computer the
10:24:01
counselor office?
10:24:04
that Ms. Millss office?
MS. WOLVERTON:
office.
The counselor office was
10:24:06
Objection.
Compound.
The first e-mail refers counselor
Was that Ms. Millss office?
10:24:08
10:24:10
10:24:13
Ms. Mills was the counselor.
10:24:15
And that would have been across the hall
10:24:19
from the just trying get the layout
10:24:22
the land.
10:24:24
hall from the Secretarys office?
Would that have been directly across the the previous administration, the
10:24:27
10:24:29
counselors office was across the hall from the
10:24:31
Secretarys office.
10:24:34 you know why Mr. Smith and Ms. Mills
10:24:35
talked about setting computer the
10:24:39
counselors office?
10:24:41
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 dont think they talked about that.
10:24:42 the work did the location the
10:24:43
counselors office change when Mrs. Clinton took
10:25:04
office?
10:25:06
Yes.
10:25:07
Where was where did change to?
10:25:07 was moved office somewhat
10:25:10
adjacent her office.
10:25:14 you know why that change was made?
10:25:15 dont.
10:25:19
Who requested for that change?
10:25:20 believe the counselor requested that
10:25:21
change.
10:25:24 you know the office set that
10:25:24
way the counselors office stayed the same
10:25:28
changed once Mrs. Clinton left office?
10:25:31 dont know.
10:25:33
After your conversation with Ms. Mills,
10:25:34
Ms. Mills e-mailed you, and talks about
10:25:45
sorry, the quality the e-mail little
10:25:52
difficult read, but says:
10:25:55
office across the hall for her use.
Lets set the needs
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:25:59
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
phone, cetera, she can across the hall
10:26:02
check her BB, her BlackBerry.
10:26:06
You mentioned that you talked about
setting computer her office.
why Ms. Mills seemed prefer having the computer
10:26:14
set the office across the hall?
10:26:19 you know
10:26:08
This wasnt for computer setup, this
10:26:12
10:26:21
was create space for her check her
10:26:25
BlackBerry.
10:26:29
Okay. the Secretarys office, that
whats considered SCIF?
The Secretarys office SCIF,
which encompasses lot more the seventh floor.
Okay.
And the office thats across the
hall outside that area?
10:26:30
10:26:34
10:26:35
10:26:38
10:26:41
10:26:43
Correct.
10:26:44
For the record, can you identify what
10:26:45
SCIF stands for?
Secure compartmentalized information
facility.
10:26:47
10:26:48
10:26:52
And just generally, what does that mean?
10:26:52
Its area that for security reasons
10:26:54
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 which for security reasons wireless devices are
10:26:58
prohibited.
10:27:03
10:27:03 this e-mail was talking about place
where she could use her BlackBerry?
10:27:05
Right.
10:27:07
The next e-mail the chain, which was
10:27:07
from you Ms. Mills, and this one ccd
10:27:16
HAbedin redacted domain name, Patrick Kennedy,
10:27:26
and Daniel Smith.
10:27:29
Who was Ms. Abedin?
10:27:31
That would Huma Abedin.
10:27:33
And Patrick Kennedy?
10:27:35
Patrick Kennedy was the Under Secretary
10:27:38 State for Management.
And what was his role, his
responsibilities, just generally?
The Under Secretary State for
10:27:41
10:27:41
10:27:43
10:27:45
Management responsible for all the management
10:27:48
operations the State Department.
10:27:50
And executive director, what was your
interaction with him?
Was there overlap your
two roles responsibilities?
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:27:51
10:27:56
10:27:59
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Not necessarily overlap, but
10:28:00
coordinated very closely issues with the
10:28:06
seventh floor.
10:28:08
And the seventh floor where the
Secretary the office the Secretary?
Yes.
Okay.
10:28:12
10:28:15
Thank you. this e-mail you wrote:
10:28:09
10:28:15
Also think
10:28:17
should ahead, but will await your green light,
10:28:20
and set standalone the Secretarys
10:28:23
office connected the Internet, but not through
10:28:29
our system, enable her check her e-mails from
10:28:33
her desk.
10:28:37 this the standalone that you
referred earlier?
10:28:37
10:28:37
Correct.
10:28:43
And dont want get into any the
10:28:43
details about the security the floor and how
10:28:44
computer systems are set up, but could you talk
10:28:45
generally about what you meant connected the
10:28:48
Internet without going through your system?
10:28:51 understanding the time was that
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:28:53
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
was possible connect computer the Internet
10:28:55
through hard through phone line, basically.
10:28:58
Through hard-wired, yeah.
10:29:01
Would that have been different setup
than any other employees the State Department?
MS. WOLVERTON:
Objection.
Lack
10:29:03
10:29:06
10:29:08
foundation.
10:29:10
10:29:12 you know how other computers within
the office the for employees within the
10:29:15
Office the Secretary were set up?
10:29:17
Not specifically, no.
10:29:21 you know this setup would have been
10:29:22
any different from the setup other employees?
10:29:24
Yes, this would have been different.
10:29:29
How would have been different?
10:29:30 understanding that most the
10:29:32
employees computers the State Department are
10:29:34
connected through the State Departments OpenNet
10:29:38
e-mail system, Internet system.
10:29:42 this one would have been separate from
the OpenNet system?
Correct.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:29:46
10:29:48
10:29:49
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 you know why why did you recommend
setting the system this way?
10:29:49
10:29:53
For ease access.
10:29:55
Why not set the computer did you
10:29:57
think about setting the computer the same way
10:30:01
other computers, through the OpenNet system?
10:30:04
The reason that proposed standalone
10:30:06 was that would make easier for her log
10:30:17
on.
10:30:20
And that point, far knew, there was requirement for her connected our
10:30:22
system.
10:30:25
How would have been easier log on?
Log what?
10:30:28 the Internet.
She would have required
fewer passwords.
Okay.
10:30:25
10:30:28
10:30:31 you need state.gov e-mail
10:30:32
address you know you need state.gov
10:30:37
e-mail address access the OpenNet system?
10:30:44
Through the state.gov system?
10:30:46
Through the state yes.
10:30:47
Yes.
10:30:47
Okay. access the computer?
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:30:47
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Yes.
Okay.
10:30:49
With Open with the OpenNet
10:30:49
system, could State Department employees access any
10:30:54
websites they wanted, are there limitations?
10:30:57
MS. WOLVERTON:
Objection.
Lack
10:31:00
foundation.
10:31:01
10:31:04 you know the Internet the
full Internet was available from these OpenNet
10:31:07
systems?
10:31:09
Yes.
10:31:09
Was the full Internet available
10:31:11
these these computer systems? mean, think there are
10:31:18
security firewalls place prevent employees
10:31:23
from going certain sites, but generally the
10:31:26
Internet available.
10:31:31 you know employees are able
10:31:32
access their Gmail, their Hotmail, you know,
10:31:34
commercial e-mail service
10:31:39 think so.
10:31:17
Yes.
10:31:40 from their computer?
10:31:41
Are they able to?
10:31:44
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Yes, they are.
10:31:45
And the reason just want
10:31:46
back to, all these you were able
10:31:52
employees were able access the Internet pretty
10:31:57
freely, maybe with some restrictions, you know
10:32:00
why Mrs. Clinton needed computer that would have
10:32:03
been different from the standard computer?
10:32:06
Well, again, thinking the time was
10:32:11 having standalone computer, she wouldnt have
10:32:13 log through our OpenNet system, which can
10:32:16
quite cumbersome and slow.
10:32:20 requires more passwords?
10:32:22
Correct.
10:32:23
Approximately when you sat down
10:32:24
your computer every day, did you have OpenNet
10:32:26
system your computer?
10:32:30
Yes.
10:32:33 you were access the Internet,
10:32:33
you recall how many passwords you would have
10:32:36
enter before being able use the Internet?
10:32:37
Its well, its one password but
has changed frequently.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:32:39
10:32:43
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
How often does have changed?
10:32:45
Seems like every week, but think its
10:32:48
every its every eight weeks.
10:32:50
Probably too many times.
10:32:54
And the system that was set
10:32:56
that you proposed setting Mrs. Clintons
10:33:00
desk, she would not have had change her password
10:33:05
every eight weeks?
10:33:08
She wouldnt have had password.
10:33:11 the computer would have just been open
10:33:12
and able use without going through any
10:33:15
security features?
10:33:17
Correct.
10:33:18 moment ago you said your thinking
10:33:19
that was your thinking the time.
thinking changed since 2009?
MS. WOLVERTON:
10:33:24
10:33:27
Vague.
Well come back that.
Was this computer set up, ultimately set
Okay.
Objection.
Has your
up?
10:33:29
10:33:36
10:33:39
10:33:46
No.
10:33:46 you know why wasnt set up?
10:33:46
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 dont know why.
10:33:51 can look the last e-mail the
10:33:52
chain, guess the first e-mail the page.
10:34:00
You wrote Patrick Kennedy was
10:34:06
Patrick Kennedy that who you reported to?
10:34:10
Or, sorry, Patrick Kennedy was the under secretary
10:34:14 management?
10:34:17
Correct.
10:34:17
Sorry about that.
10:34:18 this e-mail him, you wrote:
She says the problem
10:34:19
talked Cheryl about this. HRC does not know how use computer
10:34:24
e-mail, only BB.
10:34:29
training get her speed.
But said would not take much you know what the concern did you
10:34:21
10:34:33
10:34:35
and Ms. Mills have another conversation after your
10:34:38
initial conversation?
10:34:42
Yes.
10:34:43
And what did you talk about during that
10:34:43
conversation?
10:34:47
She said the Secretary very
10:34:47
comfortable checking her e-mails BlackBerry,
10:34:49
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
but shes not adept not used checking her
10:34:52
e-mails desktop.
10:34:57
Okay.
And you say wouldnt take
10:34:59
and your response was wouldnt take much
10:35:05
training get her speed.
10:35:08 that correct?
Thats what says.
10:35:10 you know that time did you know
10:35:12
what Mrs. Clinton was using check her e-mail?
10:35:14
No.
10:35:16
Were you aware that she
10:35:17
Well, sorry.
10:35:21
was using?
10:35:23
10:35:23
What you mean, what she guess she was using her BlackBerry
equipment check her e-mail.
10:35:27
Yeah.
10:35:29
Did you know what her e-mail account was?
10:35:29
No.
10:35:30
Did you this point believe that she
10:35:30
was using state.gov e-mail account?
10:35:34 not believe that.
10:35:38
Because that time you knew that she
10:35:40
was not assigned state.gov e-mail account?
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:35:42
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Correct.
10:35:45
Did you ask that time Ms. Mills what
10:35:46
e-mail address Mrs. Clinton was using?
10:35:52
No.
10:35:54
Did Ms. Mills was there any discussion
10:35:55
about let take that back.
Did Ms. Mills identify, besides
10:36:03
10:36:08
Mrs. Clinton using BlackBerry, anything else
10:36:11
about the e-mail that she was using?
10:36:13
Not that recall.
10:36:15
You mentioned that would have you
10:36:16
said would not take much training get her
10:36:21 speed.
10:36:24
What did you mean that? meant for her learn how check her
e-mail desktop computer.
But you didnt know what type e-mail
she was using that time?
10:36:27
10:36:31
10:36:35
10:36:38 didnt know.
10:36:39 you dont know was complicated
10:36:39 was not complicated check her e-mail?
10:36:41
Correct.
10:36:45
Did you have did you think that
10:36:46
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
time about whether not she was using Gmail
10:36:51
account, Hotmail account, some other e-mail
10:36:55
account?
10:36:58 assumed that she was using
commercially available e-mail account.
Okay. any point during the two years
10:36:58
10:37:01
10:37:02
you were that position did you learn what
10:37:08
Mrs. Clintons e-mail address was?
10:37:10
No.
10:37:12
Since those two years have you learned
10:37:12
what e-mail address Mrs. Clinton was using?
10:37:17
Yes.
10:37:21
When did you learn that?
10:37:21
Last year, the press.
10:37:22
Roughly around the New York Times
10:37:24
article?
10:37:29
Yes.
10:37:29
When you read that article heard about
10:37:29
the article that issue, what did you think about
10:37:34
it?
10:37:37
MS. WOLVERTON:
Objection.
Vague.
Did you read the New York Times article?
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:37:38
10:37:41
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 believe did.
10:37:45
Were you surprised that Mrs. Clinton was
10:37:46
using Clinton e-mail was using this e-mail
10:37:49
address, this e-mail service?
10:37:52
MS. WOLVERTON:
Objection.
Vague.
Were you surprised with what you read
the article?
Objection.
Vague.
10:38:13
MR. BEKESHA:
Are you instructing your
10:38:16
client Mr. Lukens not answer the question?
10:38:17
MS. WOLVERTON:
No.
10:38:21
the article?
Were you surprised with what you read
10:38:22
10:38:24
MS. WOLVERTON:
You may answer the extent you
10:38:04
Are you not answering
10:38:00
10:38:03
MS. WOLVERTON:
10:37:56
Same objection.
understand the question.
10:38:25
10:38:27
10:38:30
surprised.
10:38:32
10:38:32 not sure what you mean
What did you think when you read the
article?
10:38:30
10:38:35
MS. WOLVERTON:
Objection.
Vague.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:38:37
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 dont recall what thought when read
the article.
10:38:41
10:38:42
Have you discussed this besides
10:38:39
counsel and any law enforcement with active
10:38:45
where theres active law enforcement
10:38:50
investigation, have you talked anybody about
10:38:53
that article about the e-mail issue since year
10:38:55
ago?
10:38:58
No.
10:38:58
Besides setting the logistics for the
10:38:58
Secretary, you also set helped with your
10:39:38
office would help with the logistics with her
10:39:41
staff with the Office the Secretarys staff
10:39:43 well.
Correct?
10:39:47
Yes.
10:39:49
And one those individuals the time
10:39:49
was Ms. Huma Abedin?
10:39:51
Yes.
10:39:54 you know she was set state.gov
10:39:56
e-mail account?
10:40:03
Yes.
10:40:03
Was she set one?
10:40:04
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
She was.
10:40:06 you know Ms. Abedin used
10:40:06
non-state.gov e-mail account conduct official
10:40:11
government business?
10:40:16
10:40:28 want introduce
mark Exhibit its series e-mails.
(LUKENS Exhibit was marked for
10:40:16
MR. BEKESHA:
Not that recall.
identification and attached the transcript.) you could just take moment and
review the documents, Mr. Lukens.
10:40:29
10:40:37
10:40:38
10:40:38
10:40:40
Okay.
10:41:23
Exhibit [sic] approximately eight
10:41:24
e-mail chains eight e-mail conversations from
10:41:29
your time the State Department.
10:41:32
Exhibit
Exhibit
Yes.
10:41:37 you recall sending any these
10:41:38
10:41:34
Yeah, sorry.
10:41:35
e-mails, having any these e-mail
10:41:42
conversations?
10:41:44 didnt recall until now.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:41:45
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 you recall what e-mail account you sorry, most
10:41:47
were sending these e-mails to?
these e-mails are between you and Ms. Abedin.
10:41:57
Correct?
10:42:00
10:41:54
Correct.
10:42:01 you recall what e-mail address you
10:42:01
were using send and receive these e-mails
10:42:03
e-mail address Ms. Abedin?
10:42:10 sorry. dont recall the exact address.
10:42:13 you know was state.gov e-mail
10:42:14
address?
10:42:16
They appear not be.
10:42:16 you know what you recall what
10:42:18
e-mail address was?
10:42:21
No.
10:42:22 you recall Ms. Abedin used
10:42:23
non-state.gov e-mail accounts correspond with
10:42:28
you?
10:42:35
Well, the answer yes.
10:42:35
The first page sorry, the last
10:42:36
page the last e-mail chain the second
10:42:46
page, looks like this e-mail conversation starts
10:42:51
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
off from you Ms. Abedin?
10:42:53
Uh-huh.
10:42:56 you recall which e-mail address for
10:42:57
Ms. Abedin you used that time?
10:43:00 dont recall the address.
10:43:04
How would you you know how you
10:43:05
would have picked which e-mail address use?
10:43:07 dont remember why used this one.
10:43:09
And you dont recall how many e-mail
10:43:12
addresses she was using?
10:43:17 dont.
10:43:18
Or, sorry, how many you were
10:43:19
corresponding with her?
10:43:22 dont.
10:43:22
Used correspond with her.
10:43:23 any point during these conversations
10:43:24 during these e-mails others did you find
10:43:30
unusual that Ms. Abedin was using non-state.gov
10:43:33
e-mail account?
10:43:36
MS. WOLVERTON:
Objection.
Vague.
When sending these e-mails Ms. Abedin,
did you think about the fact that they were not
PLANET DEPOS
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10:43:37
10:43:41
10:43:46
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
you were sending e-mails her non-state.gov
10:43:49
e-mail account?
10:43:54
Not that recall.
10:43:55
Thinking about now, you think
10:43:56
its was rare send e-mails State
10:44:03
Department employees another e-mail account but
10:44:09
the one that was assigned the State Department?
10:44:11
MS. WOLVERTON:
Objection.
Vague.
Was this unusual, sending e-mail was
10:44:14
10:44:18 unusual for you send e-mails Ms. Abedin
10:44:20 non-state.gov e-mail account?
10:44:24
MS. WOLVERTON:
Objection.
Lack
10:44:26
foundation.
10:44:28
During your four years, did you
10:44:32
communicate with sorry, during the two years
10:44:34
overlap, did you communicate with Ms. Abedin
10:44:37
e-mail?
10:44:40
Yes.
10:44:40
Was frequent?
10:44:41
Yes.
10:44:42 you recall during that time, did
10:44:42
you recall sending e-mails her state.gov e-mail
PLANET DEPOS
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10:44:52
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
account?
10:44:55
Yes.
10:44:55 you recall before receiving these
10:44:56
exhibits, did you recall sending e-mails
10:45:00
non-state.gov e-mail account?
10:45:02
No.
10:45:04 you recall thinking any point about
10:45:08
where you were sending e-mails Ms. Abedin?
10:45:10
No.
10:45:13 you recall Ms. Abedin ever told you
10:45:13
what e-mail accounts use for her?
10:45:18
No.
10:45:20 you recall how you you know how
10:45:21
you would have received the e-mail account that was
10:45:25
used send these e-mails?
10:45:29
MS. WOLVERTON:
Objection.
Lack
10:45:31
foundation.
10:45:35 you recall Ill ask the question
10:45:35
again. you recall how you learned where send
10:45:37
these e-mails, how you learned the e-mail
10:45:41
address that you used send these e-mails?
10:45:43 must have received e-mail from her
PLANET DEPOS
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10:45:45
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 some point from that address.
10:45:48 this may have just been auto fill
10:45:50 your BlackBerry Outlook when you were sending
10:45:53
these?
10:45:58
MS. WOLVERTON:
Objection.
Objection,
calls for speculation.
10:45:58
10:45:59
Would this ask the question again,
10:46:01
was most likely auto fill feature you
10:46:04
think you would have manually entered her e-mail
10:46:08
account send her these e-mails?
10:46:11
MS. WOLVERTON:
10:46:14
MR. BEKESHA:
witness not answer?
Are you instructing the
MS. WOLVERTON:
Same objection.
10:46:16
10:46:17
No.
10:46:18
Would you like repeat the question?
10:46:19
Yes, please.
10:46:21
Would this would you have sent these
10:46:21
e-mails using this e-mail address because
10:46:25
auto fill feature piece computer equipment
10:46:27 because you would have manually typed her
10:46:30
e-mail address?
10:46:33
MS. WOLVERTON:
Same objection.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
10:46:34
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 would say because the auto fill
feature.
10:46:35
10:46:38 you know you sent and the
10:46:38
time you didnt know what the e-mail address was.
10:46:47
Correct?
10:46:49 dont
recall what now.
Okay.
10:46:51
10:46:54
Thank you.
10:46:54 you recall was e-mail the the time believe knew it.
Clinton Clintonemail.com?
10:46:55
10:47:04 dont recall.
10:47:07
Since then have you learned that
10:47:08
Ms. Abedin was using e-mail address the
10:47:15
Clintonemail.com system?
10:47:18
No.
10:47:20
When you were sending e-mails
10:47:20
Ms. Abedin her non-state.gov e-mail account
10:47:31
e-mail accounts, did you ever think about the
10:47:36
implications the Freedom Information Act
10:47:39
while sending those questions?
10:47:41
MS. WOLVERTON:
Objection.
Lack
foundation.
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10:47:43
10:47:49
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 you know what the Freedom
Information Act is?
10:47:49
10:47:54 general terms, yes.
10:47:54
During your time the State Department
10:47:56
over the course years, you said, have
10:48:00
you ever been instructed provided guidance about
10:48:04
the Freedom Information Act?
10:48:08
No.
10:48:11
While you were executive director, did
10:48:11
you receive any guidance about the Freedom
10:48:18
Information Act?
10:48:24
No.
10:48:24
Did you receive any guidance regarding
10:48:24
the Federal Records Act?
10:48:27
No.
10:48:29
Did you know that federal records were
10:48:29 preserved?
MS. WOLVERTON:
10:48:37
Objection.
Calls for
legal conclusion.
Would you routinely delete e-mails once
they were sent received?
Yes.
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10:48:38
10:48:42
10:48:47
10:48:51
10:48:53
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
What types e-mails would you delete?
10:48:56 kept files for various trips and things
10:49:01
where would keep e-mails until trips were over,
10:49:07
but after trips were over would often delete the
10:49:11
files clear clear out space inbox.
10:49:14
Did you ever think that those records
should preserved?
10:49:18
10:49:20 understanding that the State
10:49:21
Department preserves records independent whether
10:49:24 employee deletes not.
10:49:26 you know how that process works?
10:49:27
No.
10:49:31
And why did you believe that?
Was that
based conversation, guidance, memo? dont recall specifically. think
10:49:31
10:49:35
10:49:39
was based probably briefing got when
10:49:41
joined the Foreign Service.
10:49:45
And you mentioned earlier, and just
10:49:46
want confirm, that you didnt know Mrs. Clinton
10:50:07
was using Clintonemail.com until you heard
10:50:10
the news, you heard the press last year?
10:50:13
Correct.
PLANET DEPOS
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10:50:15
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 any point did you discuss with
10:50:16
Mrs. Clinton her use e-mail?
10:50:22
Never.
10:50:25
Did you ever discuss Mrs. Clintons use
10:50:26 e-mail with anybody else within her within
10:50:29
the Office the Secretary?
10:50:33
MS. WOLVERTON:
Objection.
Vague.
10:50:35
Did you ever did you ever talk
10:50:39
anybody else the Office the Secretary about
10:50:42
Mrs. Clintons e-mail usage?
10:50:46
MS. WOLVERTON:
MR. BEKESHA:
witness not answer?
Vague.
10:50:48
Are you instructing the
MS. WOLVERTON:
Objection.
10:50:52
10:50:54
No.
But will note that
its unclear what you mean e-mail usage.
already testified that they talked about her being
10:50:59
able access e-mail, dont know youre
10:51:04
asking about that terms e-mail usage
10:51:07
something else.
10:51:10
Hes
10:50:55
After the initial conversations, did you
10:50:56
10:51:14
know Mrs. Clinton was using e-mail conduct
10:51:16
official government business?
10:51:20
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Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 did not know.
10:51:21
You traveled with Mrs. Clinton all
10:51:23
her foreign travel, while you were there?
10:51:27
Yes.
10:51:31
Did you ever see Mrs. Clinton send
10:51:32
e-mail?
10:51:36
No.
10:51:37
Did you ever see Mrs. Clinton use her
10:51:37
BlackBerry?
10:51:41 saw her holding her BlackBerry.
10:51:41
Okay.
10:51:44
How often did you see Mrs. Clinton
holding her BlackBerry?
Infrequently during trips.
10:51:56 couldnt
put number it.
10:51:57
10:52:07
Were you with her did you have contact
10:52:08
with her while you were not traveling, while you
10:52:11
were the State Department?
10:52:13
Very rarely.
10:52:16
When you were when you did have the
10:52:16
occasion have contact with her, meetings
10:52:20
with her, did she have BlackBerry?
10:52:23
hold did she have BlackBerry?
Was she
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10:52:27
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Lets mark this
Exhibit
10:52:42
10:52:44
(LUKENS Exhibit was marked for
10:52:30
MR. BEKESHA:
No.
identification and attached the transcript.)
10:52:45
document
10:53:21
Yes.
10:53:22 Mr. Lukens?
10:53:22
Have you seen this record before?
10:53:25
Did you have chance review the
10:52:44
10:52:45
Not that recall.
10:53:28
Okay.
Looking the last e-mail the
10:53:29
page, its e-mail from Christopher Butzgy
10:53:35 you know who Christopher may not
10:53:44
pronouncing his name correctly Butzgy is?
10:53:47
Yes.
10:53:50
Who was who he?
10:53:51
Chris was one the IRM staffers who
10:53:52
worked the S/ES-IRM office.
And what does POEMS stand for?
parentheses says POEMS.
10:53:54 that
abbreviation?
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10:53:58
10:54:03
10:54:08
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Yes.
10:54:09 you know what that stands for?
10:54:10 believe its Principal Officers
10:54:12
Electronic Messaging System.
10:54:14
What does that mean?
10:54:16
That the classified computer system
10:54:17
that operates support the Secretary and under
10:54:19
secretaries and the other folks that took care
10:54:24 this office.
10:54:26
And you know what Chris duties, role
was this office?
Hes specialist.
10:54:26
10:54:30 was
specialist.
10:54:37
And who did report to; you recall?
10:54:37 would have reported John Bentel.
10:54:39
And then Mr. Bentel reported you?
10:54:41
Yes.
10:54:43 this e-mail Mr. Butzgy says: work
10:54:31
10:54:44 help desk analyst and has come
10:54:51
attention that one our customers has been
10:54:56
receiving permanent fatal errors from this address.
10:55:00
Can you please confirm you receive this
10:55:04
PLANET DEPOS
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Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
message.
10:55:08
Was this usual occurrence you
10:55:08
know this was usual occurrence the
10:55:09
State Department, that such e-mails like this were
10:55:12
sent?
10:55:14
MS. WOLVERTON:
Objection.
Vague.
Have you seen any e-mails similar this
before?
10:55:15
10:55:16
10:55:19
Not that recall.
10:55:19 you recall Mr. Bentel ever talked
10:55:20 you about this e-mail specifically?
10:55:25
Not that remember, no.
10:55:30 you know who the line?
10:55:32
No.
10:55:37 Mr. Bentel Mr. Bentel reported
10:55:40
directly you?
10:55:51
Yes.
10:55:53
Did you and him ever talk about
10:55:53
Mrs. Clintons e-mail address?
10:55:56
Not that recall, no.
10:55:58
Did you two ever talk about
10:55:59
Mrs. Clintons BlackBerry?
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10:56:03
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
No.
10:56:04
Did you have any communications with
10:56:05
Mr. Bentel about Mrs. Clintons use e-mail?
10:56:09
Not that remember, no.
10:56:14 you recall you know
10:56:15
Secretary Rice created non-state.gov e-mail
10:56:36
account use for official government business?
10:56:41 have idea.
10:56:43 you know she she used
10:56:45
non-state.gov e-mail accounts send receive
10:56:49
e-mail?
10:56:53 dont know.
10:56:53 you know Secretary Rice used
10:56:54
state.gov e-mail account conduct official
10:56:57
government business?
10:56:59 dont know.
10:57:00
Did you use non-state.gov e-mail
10:57:00
account conduct official government business,
10:57:04
have you used non-state.gov e-mail account
10:57:07
conduct official government business?
10:57:10 may have, yes.
10:57:12 you recall when under what
10:57:14
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Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
circumstances?
Are you talking about within the
10:57:17
10:57:17
framework this position, this job, other
10:57:21
jobs?
10:57:24 can start with this job, this you recall you ever used
10:57:24
position.
non-state.gov e-mail account conduct official
10:57:28
government business while you were executive
10:57:31
director?
10:57:33
10:57:26
Yes.
10:57:33
Under what circumstances?
10:57:33
Most often had print something
10:57:35
and were overseas trip, would send
10:57:38 personal e-mail address, which was then
10:57:42
connected printer our control rooms
10:57:44
overseas.
10:57:48
And thats because printers werent
connected why did you need that? was more expedient forward
10:57:48
10:57:52
10:57:54
e-mail my, case, Yahoo account, print
10:57:58
from computer setup our offices than you
10:58:03
couldnt print from BlackBerry overseas.
10:58:06
PLANET DEPOS
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Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Were you able access your state.gov
10:58:09
e-mail account desktop that wasnt your
10:58:12
desktop the office?
10:58:16
yes. often set desktops such well,
But you cant print from it.
Okay.
Was that web mail type system
or...
10:58:17
10:58:22
10:58:25
10:58:30 dont know what that means.
10:58:30
Did you onto the Internet access
10:58:31
your e-mail account?
10:58:34
Yes, there way access state.gov
10:58:35
through the Internet through more rigorous logon
10:58:37
system that requires token and password that
10:58:42
changes frequently, cetera.
10:58:46
computers when you log that way, youre
10:58:49
unable print.
10:58:52
But you accessed your personal
10:58:53
e-mail account, you were able open whatever you
10:58:56
were looking open and then print?
10:58:59
Okay.
But typically the
Yes.
10:59:00
Was that common occurrence with
10:59:00
State Department employees that you know of?
PLANET DEPOS
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10:59:06
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
MS. WOLVERTON:
Objection.
Vague.
10:59:08
Did you know other State Department
employees going through this same process print?
10:59:12
10:59:14
Yes.
10:59:18
Did you use your personal e-mail account
10:59:18 other other circumstances situations
10:59:25
besides print?
10:59:28
No, not that recall.
10:59:30
Why not?
10:59:31
Well, because the bulk the work was
10:59:32
done the state.gov account. switch over Yahoo.
There was reason
10:59:38
10:59:41
And think you just mentioned that you
10:59:42
were using Yahoo, but just for the record, did you
10:59:51
have Clintonemail.com e-mail address?
10:59:56
No. you know anybody else that did?
10:59:59
you know anybody that did?
10:59:59
11:00:01
No.
11:00:03
Did you ever instruct others within your
11:00:04
office not use their personal e-mail accounts?
Not that remember, no.
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11:00:08
11:00:11
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Were there any discussions within your
11:00:15
office about the use personal e-mails
11:00:19
employees?
11:00:23
Not that remember.
11:00:23
MR. BEKESHA:
11:00:44
(LUKENS Exhibit was marked for
Exhibit
identification and attached the transcript.)
Have you had chance look the
document?
11:00:46
11:00:47
11:00:47
11:01:55
Yes.
11:01:56
Have you seen this e-mail before?
11:01:56
Not that recall.
11:01:58
And when did you leave the executive
11:02:00
director position?
11:02:07 early June 2011.
11:02:08
Okay.
11:02:10
And for that guess for the
last two years you reported Stephen Mull?
11:02:17
Yes.
11:02:21 can take look the bottom
11:02:21
e-mail this document, which starts the first
11:02:25
page and carries over, e-mail from
11:02:28
Stephen Mull Cheryl Mills, Huma Abedin,
11:02:31
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Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Patrick Kennedy, Monica Hanley.
Stephen Mull was the executive secretary
11:02:37
that just referred to?
11:02:39
11:02:43
Correct.
11:02:43
And you know who Monica Hanley is?
11:02:43
She worked the Secretarys office.
11:02:46 you know what her position was, you
11:02:49
recall?
11:02:51 dont recall her title.
11:02:51
Looking the second page, Mr. Mull
11:02:53
stated:
Separately, are working provide the
Secretary, per her request, department-issued
11:03:08
BlackBerry replace her personal unit which
11:03:11
malfunctioning, possibly because her personal
11:03:15
e-mail server down.
11:03:17
versions for her use, one with operating
11:03:20
State Department e-mail account which would mask
11:03:23
her identity but which would also subject
11:03:27
FOIA requests, and another which would just have
11:03:29
phone and Internet capability.
Were working with
11:03:29
Monica hammer out the details what will best
11:03:32
meet the Secretarys needs.
11:03:35 will prepare two
PLANET DEPOS
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11:03:03
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Prior leaving believe you left
11:03:37
that position, the executive director position
11:03:39
approximately two months before this e-mail did
11:03:43
you have any conversations with Mr. Mull
11:03:48
Ms. Mills about replacing Mrs. Clintons BlackBerry
11:03:52
with State Department BlackBerry?
11:03:57
Not that remember, no.
11:04:00
When when did Mr. Mills approximate
11:04:01
sorry, Mr. Mull approximately take over
11:04:05
executive secretary?
11:04:09 would have been the summer 2009.
dont recall which month. that time did you talk Mr. Mull
about Mrs. Clintons BlackBerry?
11:04:09
11:04:13
11:04:14
11:04:17
Not that recall.
11:04:19
Did you talk him about any the
11:04:20
conversations you had couple months before about
11:04:25
setting computer her office for her
11:04:28
check her e-mail?
11:04:30
Not that recall, no.
11:04:31
Did you and Mr. Mull ever talk about
11:04:32
issuing Mrs. Clinton State Department e-mail
11:04:37
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Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
account?
11:04:40
Not that remember, no.
11:04:41
While you were executive director, did
11:04:42
you have handle any aspect processing FOIA
11:04:52
request?
11:04:57
No.
11:04:57
Did you ever have FOIA request asking
11:04:58
for your records?
11:05:01
No.
11:05:03
Did you ever have contact with anyone
11:05:03
processing FOIA request, asking for your records
11:05:06 records within your office?
11:05:10
No.
11:05:12 you know who would have been
11:05:12
responsible for processing responding FOIA
11:05:17
requests for the Office the Secretary while you
11:05:21
were there?
11:05:24
Yes.
11:05:25
Who was that person?
11:05:25
Clarence Finney, who ran the
11:05:26
correspondence and records unit. you know, when Secretary Rice left
PLANET DEPOS
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11:05:30
11:05:31
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
office, her records were accounted for
11:05:40
inventoried any way?
11:05:43 dont know.
11:05:46 you know who would have been
11:05:46
responsible for that that happened?
11:05:48
Clarence Finney.
11:05:50
Besides counsel and any law enforcement
11:05:52
agencies, have you spoken anyone today about
11:06:06
your testimony?
11:06:08
No.
11:06:08
Have you spoken Mrs. Clinton,
11:06:09
Ms. Abedin, Ms. Mills any their attorneys
11:06:11
recently?
11:06:14
No.
11:06:14
When was the last time you would have
11:06:14
spoken with Mrs. Clinton, Ms. Abedin, and
11:06:16
Ms. Mills?
11:06:21
MS. WOLVERTON:
Objection.
Withdrawn.
Or, make easier, when was the last
time you spoke with Mrs. Clinton?
11:06:24
11:06:26 spoke with Mrs. Clinton Ive spoken her once since left the job.
11:06:23
She was her
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Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
way Nelson Mandelas funeral South Africa,
11:06:34
that was
11:06:38
THE WITNESS:
Does anyone remember when
that was?
11:06:39
11:06:40
Anyway, she was Air Force One, the
President was flying the funeral. Senegal refuel. the ambassador there,
11:06:48
went out the airport hand case any
11:06:52
issues came up.
11:06:55
They stopped
11:06:41
She was still Secretary State the
time?
11:06:45
11:06:55
11:06:59
No, she was no, dont think she was.
11:06:59
When was the last time you you
11:07:02
recall the last time you spoke Ms. Abedin?
11:07:06
Same occasion.
11:07:08
What about Ms. Mills?
11:07:11
Not since left the office.
11:07:12
Since talked little bit about the
11:07:13
New York Times media reporting year ago.
11:07:20
Have you spoken anybody the State Department
11:07:24
about that news report that issue besides
11:07:26
counsel?
11:07:31
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
MS. WOLVERTON:
Objection.
Vague
that issue.
11:07:32
11:07:34
Have you spoken about the New York Times
article with anyone the State Department?
11:07:36
11:07:38
No.
11:07:40
Have you spoken anyone the State
11:07:41
Department about what was reported the New York
11:07:46
Times article?
11:07:49
MS. BERMAN:
interrupt? sorry, can just
You mean other than counsel?
same
11:07:54
11:07:57
MR. BEKESHA:
MS. BERMAN:
MR. BEKESHA:
Other than counsel --- qualification?
Yes.
11:07:57
11:07:57
11:07:59
Without counsel and any law enforcement
11:07:59
agency officials that are conducting active
11:08:01
investigation.
11:08:05
The
11:07:52
Yes.
11:08:05
Who have you spoken to?
11:08:06
Now forget her name. spoke
11:08:08
woman who works our press office who was
11:08:13
responding queries from the Washington Post, who
11:08:16
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
was following the New York Times story.
11:08:20
And what did you two talk about?
11:08:23
She asked the functions job
11:08:25
and almost the same questions that youre asking
11:08:31
me.
11:08:33
Did you provide her with any different
answers than youve provided today?
11:08:33
11:08:36
No.
11:08:39 there any information that you
11:08:39
provided her that havent covered today?
11:08:41
No.
11:08:43
Have you talked anybody else outside
11:08:44
the State Department about the New York Times
11:08:46
article?
11:08:49
No.
11:08:50
Have you talked anybody outside the
11:08:50
State Department counsel with the Justice
11:08:53
Department any law enforcement about the issues
11:08:56
contained within the newspaper article?
11:09:00
MS. WOLVERTON:
Objection.
Lack
11:09:02
foundation.
11:09:04
11:09:06
Have you talked anybody outside the
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
State Department, excluding all those various
11:09:09
people, about what was discussed the newspaper
11:09:13
article, the New York Times and other reporting?
11:09:17
MS. WOLVERTON:
But you can answer the extent youre
Same objection.
11:09:19
able.
11:09:21
11:09:23
Does wife count?
11:09:23
She does.
11:09:25
No.
11:09:27
When did you last speak with
11:09:28
Anybody else?
Stephen Mull?
11:09:34
Stephen Steve and had e-mail
exchange last summer.
June last year. about year ago.
June.
And did you two discuss any the issues
weve talked about today?
11:09:35
11:09:39
11:09:43
11:09:45
11:09:48
No.
11:09:49
When was the last time you talked with
11:09:49
Patrick Kennedy?
11:09:52 talked him last week.
11:09:53
Okay.
11:09:55
Did you that time did you
talk him about anything weve discussed today?
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
11:10:00
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
No.
11:10:04
Have you talked Mr. Kennedy about
11:10:05
Mrs. Clintons e-mail use since you left the Office
11:10:08 Secretary?
11:10:12
No.
11:10:14 you know who Bryan Pagliano is?
11:10:14 now.
11:10:19
When did you first learn who was?
11:10:21
Through press reports.
11:10:23
What have you learned about him?
11:10:25 understanding that was brought
11:10:27 board Schedule consultant.
Did you know him while you were
Washington
11:10:32
11:10:38
11:10:41
No.
11:10:42 during your time executive
11:10:42
director?
11:10:46
No.
11:10:46 you know other person,
11:10:46 you know was within the general IRM the
11:10:55
State Department, specifically within S/ES,
11:10:58
within the executive secretariats office?
11:11:04
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 understanding from the press that
11:11:08 was what call the big IRM, not the
11:11:11
S/ES-IRM.
11:11:14
And you didnt have occasion meet
him while you were the State Department?
11:11:18
Not that recall, no.
11:11:20
MR. BEKESHA:
11:11:26
Can take five-minute
break, ten-minute break?
MS. WOLVERTON:
11:11:30
Certainly.
THE VIDEOGRAPHER:
11:11:16 are off the record,
the time 11:09.
11:11:33
11:11:34
11:11:36
(Recess taken 11:09 a.m.)
11:11:38
THE VIDEOGRAPHER:
11:33:01
Here begins tape are back the record 11:30.
Great, thank you.
Mr. Lukens, just
have few more questions.
11:33:06
11:33:09
11:33:14
Okay.
11:33:15
You talked little bit before think
11:33:15
you said that you saw Secretary Clinton
11:33:18
possession BlackBerry, was infrequently?
11:33:21
Was that
11:33:26
11:33:26
Correct.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
How would you quantify infrequently?
11:33:26 few times month.
11:33:29
And you your travel with her was both
11:33:33
domestic and international, just international?
11:33:38
Just international.
11:33:40
Okay.
11:33:41 while you were traveling
internationally, you just saw her holding have
11:33:44
possession BlackBerry few times month?
11:33:48
Correct.
11:33:51 you know that was
11:33:51
State-Department-issued BlackBerry?
11:33:53 dont know.
11:33:55 you know who would have been charge
11:33:57 issuing BlackBerry the Secretary State?
11:34:00 would have been S/ES-IRM.
11:34:05
And they report you they reported
11:34:07 you?
11:34:09
Yeah. dont believe was
State Department BlackBerry.
Did you ever talk during the
11:34:10
11:34:12
11:34:15
transition process shortly after Mrs. Clinton
11:34:19
took office, did you ever talk with Cheryl Mills
11:34:22
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
about issuing Mrs. Clinton BlackBerry?
11:34:25 dont remember talked about
issuing her State Department BlackBerry.
talk about how she could access her BlackBerry.
11:34:29
11:34:33 while you were having those
11:34:35
conversations about whether not she could
11:34:37
the counselors office use BlackBerry, your
11:34:39
assumption was that was her personal BlackBerry
11:34:45
she wanted use?
11:34:47 did
11:34:27
Yes.
11:34:48 was State Department BlackBerry,
11:34:48
would she have been able use her office?
11:34:53
No.
11:34:55 you know she used after your
11:34:56
discussions, she used the counselors office
11:35:01
use her BlackBerry?
11:35:05 dont not aware that she did.
11:35:05
Was she able use was there
11:35:10
workaround, was she able use her BlackBerry
11:35:14
within her office?
11:35:17 never saw her use her BlackBerry her
office.
11:35:18
11:35:20
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
was authorized to? you know she was able to, she dont believe she would have been
authorized to. she were authorized use her
11:35:21
11:35:24
11:35:25
11:35:27
11:35:28
BlackBerry the office, where would that
11:35:31
authorization come from, approval come from?
11:35:35
Security.
And you recall who the head that
The Assistant Secretary For Diplomatic
Security that time was Eric Boswell.
11:35:39
11:35:42
office was that time? would have come from Diplomatic
And who would Mr. Boswell have reported
to?
11:35:42
11:35:45
11:35:46
11:35:49
11:35:53
11:35:57 would have reported Pat Kennedy,
the under secretary for management. you know you know waivers
11:35:57
11:36:02
11:36:05 exceptions were made for State employees
11:36:12 the Office the Secretary use their State
11:36:17
Department BlackBerrys within the executive suite
11:36:21
within the office the Secretary?
11:36:25
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 not aware any waivers that were
made.
11:36:27
11:36:29
Did you have State Department issued
BlackBerry?
11:36:33 did.
11:36:33
Those e-mail conversations looked
11:36:33
earlier that you had with Ms. Abedin, those would
11:36:36
have probably been your State while you were
11:36:39
using your State Department BlackBerry?
11:36:43
MS. WOLVERTON:
Objection.
Calls for
11:36:30
11:36:45
speculation.
11:36:47
Could you answer the question, please?
11:36:48
They were either from BlackBerry
11:36:49
from desktop. think one them you happened
11:36:52
11:36:53
potentially plane the time, that
11:36:56
would have been from your State Department
11:36:58
BlackBerry?
11:37:00
Yes.
Except could also access through
11:37:00
laptop our State Department account the plane.
11:37:04 could have been from the laptop too.
11:37:06
And you had Internet access on...
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
11:37:08
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Yes.
Okay.
11:37:11 you know Ms. Abedin had
State Department BlackBerry?
11:37:11
11:37:14
She did.
11:37:15 you know she used another
11:37:16
BlackBerry well?
Did you ever see her carrying
more than one BlackBerry?
11:37:20
11:37:23 did.
11:37:24
How many BlackBerrys did you see her
11:37:25
carrying one time?
11:37:30 think two.
11:37:31 you know how frequently she carried
11:37:31
more than one BlackBerry?
11:37:34 dont know the frequency.
11:37:35
Were there any were there instances
11:37:36
where you only saw her carrying one BlackBerry?
11:37:39 dont remember.
11:37:42
Would you say was more usual for her
11:37:44 carry two than one?
When you say carry, you mean visibly
11:37:48
her hands?
11:37:56
11:37:56
That you knew that was her?
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
11:37:50
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 have idea what was her purse.
11:37:58
Did you see her using two BlackBerrys
11:38:01
numerous occasions?
MS. WOLVERTON:
11:38:04
Objection.
Vague.
11:38:05
You can answer the question.
11:38:08
Define numerous, please.
11:38:09
You saw her using, times, two
11:38:11
BlackBerrys?
11:38:17
Yes.
11:38:17 you know Cheryl Mills used more
11:38:17
than one BlackBerry?
11:38:23
Not that was aware of.
11:38:23
And you mentioned earlier that during the
11:38:25
transition period you spoke with Cheryl Mills.
Was
she your point contact the extent you needed
11:38:34 over issues and discuss issues about the
11:38:38
incoming Secretary State?
11:38:43
11:38:32
Yes.
11:38:45
Did you talk anybody else during that
11:38:45
transition period immediately before right after
11:38:49
Mrs. Clinton took office, others that would have
11:38:52
been part the Office the Secretary the
11:38:58
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
transition team?
11:39:01
Sorry, you said before and after?
11:39:02
Yeah, around that period.
11:39:03
Because you
said most the work was done shortly before and
11:39:05
shortly after she took office.
11:39:08
Yeah, mean, most the work was done
11:39:11
after far on-boarding staff, because they
11:39:15
couldnt actually come until after inauguration
11:39:18
day.
11:39:22 most discussions pre-inauguration
space issues were with Cheryl Mills.
came on, then interacted with all them.
Once staff
Was there one particular point contact
11:39:26
11:39:30
11:39:34
within the Office the Secretary that you
11:39:37
communicated the most with?
11:39:41
Yes.
11:39:42
Who was that person?
11:39:42
Huma Abedin.
11:39:43
Did you ever speak with Ms. Abedin about
11:39:45
Mrs. Clinton Secretary Clintons BlackBerry, the
11:39:52
use her BlackBerry?
11:39:58
Not that recall, no.
11:39:59
Did you ever talk her about the
11:40:00
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
State whether not the State Department was
11:40:02
going issue Secretary Clinton BlackBerry?
11:40:04
Not that recall.
11:40:09
Looking those e-mails earlier,
11:40:10
seemed important appears that was
11:40:12
important for Secretary Clinton able use
11:40:14
her BlackBerry during the day.
11:40:18
that ended resolving itself?
MS. WOLVERTON: you know how
11:40:20
Objection.
11:40:23
Characterize mischaracterizing evidence, lack
11:40:26
foundation.
11:40:28
11:40:29 you know how the issue her
BlackBerry use while she was the
11:40:31
State Department was resolved?
11:40:34
No.
11:40:35
But you did you ever have meetings
11:40:35
with Mrs. Clinton within her office within the
11:40:41
executive suite?
11:40:45
Rarely, but did.
11:40:46
When you did, did you see her using
11:40:48
possession BlackBerry?
No.
Can just back?
11:40:52
Because did
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
11:40:53
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 occasion see Secretary Clinton the hallway
11:40:57
outside the SCIF standing there looking her
11:41:02
BlackBerry.
11:41:05
Okay.
Did you you know what she
was doing her BlackBerry that time?
11:41:05
11:41:10
No.
11:41:12
Did you think she was sending personal
11:41:12
e-mail reading personal e-mail that time?
11:41:15 had idea what she was doing.
11:41:18 you know you dont know she was
11:41:20
conducting official government business not
11:41:23
during that time?
11:41:25 dont know what she was doing.
11:41:25 you know other employees that may
11:41:26
have communicated with Mrs. Clinton via e-mail
11:41:29
conduct official government business?
11:41:32
MS. WOLVERTON:
Not that
11:41:34
Objection, vague.
Did you ever talk any other employees
11:41:34
11:41:36
about them sending e-mails receiving e-mails
11:41:38
from the Secretary?
11:41:41
No.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
11:41:42
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
About how many times did you see
11:41:42
Mrs. Clinton outside her office the hallway
11:41:57
using her BlackBerry?
11:41:59
MS. BERMAN:
mischaracterizing his testimony. going object.
Youre
Did you see Mrs. Clinton the hallway guess outside her office
11:42:01
11:42:03
11:42:05
with her BlackBerry?
the hallway outside the SCIF guess how you
11:42:13
described it?
11:42:16
11:42:08
Yes.
11:42:16
How often did you see her using having
11:42:17 possession using her BlackBerry that
11:42:22
hallway?
11:42:24
MS. BERMAN:
Same objection.
11:42:26
You can answer the question.
11:42:32 can recall maybe half dozen times.
11:42:34
MR. BEKESHA:
11:42:46
have.
11:42:47
MS. WOLVERTON:
Thats all the questions
Can take short
break?
11:42:49
11:42:51
MR. BEKESHA:
Sure.
THE VIDEOGRAPHER: are off the record
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
11:42:52
11:42:54
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016 11:40.
11:42:56
(Recess taken 11:40 a.m.)
11:42:59
THE VIDEOGRAPHER:
11:45:40
record 11:43.
EXAMINATION COUNSEL FOR DEFENDANT are back the MS. WOLVERTON:
Mr. Lukens, have just few questions
11:45:49
11:45:54
11:45:54 ask you.
Can you directing your attention
11:45:59
back whats been marked Exhibit please.
11:46:05
And the beginning the e-mail chain which
11:46:15
starts the bottom page and carries over
11:46:18
page and whats the sentence line marked
11:46:21
number the end there reference check
11:46:31
her e-mail.
11:46:33
HRC.
And did you testify that that was
11:46:37
reference former Secretary Clinton checking her
11:46:40
e-mail?
11:46:45
And earlier theres reference
11:45:55
Yes.
11:46:45
What was your understanding why former
11:46:45
Secretary Clinton wanted check her e-mail? understanding was for her stay
touch with family and friends.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
11:46:50
11:46:52
11:46:57
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Did you have any indication whether
she was checking e-mail for work purposes?
11:46:58
11:47:00
No.
11:47:03 can direct your attention later
11:47:04 the e-mail chain, page the very last
11:47:12
e-mail thats fully the page from
11:47:24
Patrick Kennedy you.
11:47:27
and Cheryl Mills.
standalone separate network [sic] great
11:47:40
idea.
11:47:45
And looks oh, you
And says:
Cheryl, the
Regards, Pat.
11:47:36 you see that?
11:47:48
Yes.
11:47:49
And you testified earlier that the
11:47:49
standalone computer was for the idea you
11:47:52
proposed was for former Secretary Clinton use
11:48:01
check her e-mail her office.
11:48:04 that correct?
Yes.
11:48:05
And the standalone computer that you
11:48:06
were proposing allow her check e-mail, was
11:48:10
that for her stay touch with family and
11:48:13
friends for work purposes?
11:48:15 understanding was family and friends.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
11:48:17
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
Did you have any reason believe that
11:48:20
the standalone computer would used for any other
11:48:25
purpose?
11:48:29
No.
11:48:29
Mr. Lukens, you testified earlier that
11:48:29
you didnt receive any guidance the Freedom
11:48:35
Information Act the Federal Records Act.
11:48:42
you mean during your tenure executive director
11:48:48 any point your career State?
11:48:50
Did meant during tenure this job
executive director.
11:48:54
11:48:58 you recall whether any point
11:48:59
your career you received guidance records
11:49:01
management?
11:49:03
Yes.
11:49:04 you recall whether included the
11:49:04
Freedom Information Act?
Yes.
11:49:09
MS. WOLVERTON: further questions.
Thank you.
MR. BEKESHA:
11:49:08
11:49:16
11:49:17
Just couple follow-up
questions.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
11:49:31
11:49:33
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
CONTINUED EXAMINATION COUNSEL FOR PLAINTIFF MR. BEKESHA:
11:49:35
You just testified was your
11:49:35
understanding Mrs. Clinton Secretary Clinton
11:49:37
was going use the standalone computer
11:49:40
communicate with family and friends, e-mail with
11:49:43
family and friends?
11:49:46
11:49:33
That was understanding the time.
11:49:46
Did you know how she was going
11:49:48
communicate with State Department officials?
11:49:50 did not.
11:49:53
Did you inquire with Ms. Abedin,
11:49:53
Ms. Mills, Mrs. Clinton about she needed
11:50:00
computer conduct official government business?
11:50:03
No.
11:50:05 any point did Mr. Kennedy, Ms. Mills,
11:50:06
Ms. Abedin ask you provide Mrs. Clinton with
11:50:12
computer conduct official government business?
11:50:19
Not that recall, no.
11:50:21
And you mentioned the use
11:50:22
BlackBerry you thought Mrs. Clinton was using
11:50:27
the BlackBerry and needed way use her
11:50:32
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
BlackBerry communicate with family and friends.
Did you think that she was going use
11:50:33
11:50:37
the BlackBerry conduct official government
11:50:39
business?
11:50:41
MS. BERMAN:
Objection.
Mischaracterizing former testimony.
11:50:42
11:50:44
You can answer the question.
11:50:45 understanding was that she was using
11:50:46
the equipment contact family and friends.
Did you ever think about whether not
11:50:50
11:50:53
she was going use that equipment conduct
11:50:54
official government business?
11:50:57 did not.
11:50:57
Did you ever have conversation with
11:50:58
anyone about whether she was going use that
11:51:00
equipment conduct official government business?
11:51:03
Not that recall.
11:51:05
Did you ever think about how Mrs. Clinton
11:51:06
was going how Mrs. Clinton was going
11:51:10
send e-mail conduct send receive e-mail
11:51:13
conduct official government business?
11:51:16
No.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
11:51:18
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
You mentioned that you did receive during
11:51:19
your career guidance about the Freedom
11:51:21
Information Act.
11:51:23
that guidance? you recall when you received
11:51:25 part new employee orientation when joined the State Department.
11:51:25
11:51:28
And when would that have been?
11:51:30
The summer 1989.
11:51:32
Did you receive any follow-up guidance
11:51:33
any additional training besides that guidance
11:51:38
the summer 1989?
11:51:41
Not that recall.
11:51:43
Okay.
11:51:44 you recall e-mails and
e-mail records were being discussed during your
11:51:47
training 1989?
11:51:50
Not that recall.
11:51:51 you know any point after 1989 you
11:51:52
received updated guidance training about the use
11:51:56 e-mail related federal records and the
11:51:58
Freedom Information Act?
11:52:02
Not that recall.
11:52:03
MR. BEKESHA:
11:52:06 have other questions.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
MS. WOLVERTON:
break, please.
11:52:08
11:52:11
THE VIDEOGRAPHER:
Well take one last are off the record 11:50.
11:52:13
11:52:15
(Recess taken 11:50 a.m.)
11:52:18
THE VIDEOGRAPHER:
11:58:58 are back the
record 11:56.
11:59:01
MS. WOLVERTON:
questions. have further
But said, Mr. Lukens does
11:59:05
11:59:06
reserve his right read and sign the transcript.
11:59:11
And also, invoke provision the discovery
11:59:16
order entered Judge Sullivan have the
11:59:22
three-day period after the transcript available
11:59:26 review for any necessary redactions
11:59:28
contemplated that paragraph.
11:59:32
MR. BEKESHA:
11:59:34 there specific portion the deposition that has raised that concern?
MS. WOLVERTON:
MR. BEKESHA:
Yes.
11:59:36
11:59:42
Are you willing identify
what that portion is?
11:59:43
11:59:45
MS. WOLVERTON:
MR. BEKESHA:
Not this time.
Just one second.
Sorry.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
11:59:47
11:59:58
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
MS. WOLVERTON: dont want risk
12:00:03
revealing any sensitive information identifying
12:00:06
the particular provision.
12:00:09
consideration, maybe would arrive different
12:00:13
position, but thats the reason for declining
12:00:17
identify it.
12:00:21
After further
MR. BEKESHA:
THE VIDEOGRAPHER:
Okay.
Nothing else.
This marks the end
the deposition Lewis Lukens. are going off
the record 11:58.
(Off the record 11:58 a.m.)
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
12:00:22
12:00:23
12:00:26
12:00:28
12:00:31
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
ACKNOWLEDGMENT DEPONENT LEWIS LUKENS, hereby acknowledge
that have read and examined the foregoing
testimony, and the same true, correct and
complete transcription the testimony given
and any corrections appear the attached Errata
sheet signed me.
________________________
(DATE)
_______________________
(SIGNATURE)
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
CERTIFICATE REPORTER NOTARY PUBLIC Rebecca Stonestreet, RPR-CRR and Notary
Public, hereby certify that there came before MAY 18, 2016, the deponent herein,
LEWIS LUKENS, who was duly sworn and
thereafter examined counsel for the respective
parties; that the questions asked said deponent
and the answers given were taken
stenographically and thereafter transcribed use computer-aided transcription and computer
printer under direction; that reading and
signing was requested; and that neither
counsel for, related to, nor employed any the
parties this case and have interest,
financial otherwise, its outcome.
_______________________________
NOTARY PUBLIC AND FOR THE
DISTRICT COLUMBIA commission expires March 31, 2018
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
abbreviation
54:22
Abedin
8:15 30:10,11 42:17
43:2 44:3,8,16 45:1,4
45:18,21 46:10,16
47:8,10 49:13,17
61:22 65:12,16 66:14
75:7 76:2 78:17,18
85:12,17
able
26:15,16,22 34:17,22
35:3,4,20 36:11 52:17
59:1,18 69:6 73:12,18
73:19 74:1 79:6
about
8:9 9:1,21 10:15,17
12:20 13:2 14:14
15:5,12 18:14 19:10
19:17,21 20:21 21:8
25:4,7,10,11 27:21
28:1,19 29:3 30:3
31:18,20 33:5 37:9,11
37:19 39:6,9 40:1,18
40:19 42:6,7 45:22
46:4 47:7 49:18 50:6
50:10 52:9,16,18
56:11,18,21 57:3 58:2
61:2 63:5,14,16,17,21
65:8 66:16,18,21 67:3
67:7 68:2,13,18 69:2
69:13,16,22 70:2,10
73:1,2,4,6 77:16
78:18,22 80:20 81:1
85:13 86:10,15,18
87:2,18
access
26:22 33:3,18,22 34:3
34:18 35:4,18 52:17
59:1,9,11 73:4 75:19
75:22
accessed
59:17
account
38:16,19,22 40:2,2,3,5
42:20 43:3 44:1
45:19 46:2,6,11 47:1
47:5,14 48:10 49:17
57:7,14,18,19 58:7,20
59:2,10,18 60:5,11
62:17 64:1 75:20
accounted
65:1
accounts
22:3 44:17 47:11 49:18
57:10 60:21
acknowledge
90:3
ACKNOWLEDGM...
90:1
across
24:17 27:13,15,18
28:22 29:1,6,14
Act
8:10 49:19 50:2,7,11
50:14 84:7,7,17 87:3
87:20
Action
1:7
active
42:4,5 67:16
actually
78:8
additional
87:10
address
22:9,15,19 23:4 33:17
33:18 39:3 40:8,11
41:4 44:6,8,9,11,14
45:3,5,7 47:21 48:1
48:18,21 49:4,13
55:21 56:19 58:14
60:15
addresses
23:1 45:10
adept
38:1
adjacent
28:8
administered
7:17
administration
18:3 27:17
administrations
13:5 15:13
Africa
66:1
after
17:13 28:18 37:16 51:4
52:20 72:21 73:14
77:20 78:2,5,7,8
87:17 88:13 89:3
again
35:8 47:19 48:7
against
8:10
agencies
65:8
agency
67:16
ago
36:14 42:8 66:19 69:13
ahead
23:10 31:9
Air
66:5
airport
66:8
Alan
1:13 2:1 8:1,19
all
9:13,13,20 30:18 35:3
53:2 69:1 78:11
81:17
allow
83:19
allowed
26:13
almost
68:4
already
9:1 52:16
also
4:3 8:21 9:9 14:5 31:8
42:11 62:18 75:19
88:11
ambassador
66:7
analyst
55:19
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
another
37:16 46:6 62:19 76:5
answer
41:11,16 44:19 48:13
52:13 69:5 75:12
77:5 81:15 86:7
answering
41:9
answers
9:13 68:7 91:10
any
9:10,11,16 15:14 17:20
18:9 20:13,18,21 23:2
31:17 32:5,13 34:3
36:11 39:5 40:6 42:4
43:19,20 45:16 47:7
50:10,13 52:1 56:7
57:2 61:1 63:4,16
64:4 65:2,7,12 66:8
67:15 68:6,9,18 69:15
75:1 76:15 80:19
83:1 84:1,2,6,9,12
85:16 87:9,10,17
88:14 89:2 90:7
91:15
anybody
17:17 42:6 52:5,9
60:17,18 66:20 68:12
68:16,22 69:8 77:19
anyone
64:10 65:8 66:3 67:4,6
86:15
anything
25:10 39:8 69:22
Anyway
66:5
appear
44:12 90:7
appears
79:5
approval
74:7
approximate
63:8
approximately
35:14 43:13 63:3,9
area
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
29:15,22
around
17:6 40:15 78:3
arrival
20:14
arrive
89:4
article
40:16,18,19,22 41:7,14
41:21 42:2,7 67:4,8
68:14,19 69:3
asked
9:8 21:8 22:12 68:3
91:9
asking
9:16 52:18 64:7,11
68:4
aspect
64:4
assigned
21:11,15 22:15,19 23:3
38:22 46:7
Assistant
74:12
assume
20:4,5,6
assumed
40:4
assumption
73:8
attached
5:10 23:13 43:9 54:5
61:7 90:7
attention
55:20 82:8 83:4
attorney
8:8
attorneys
65:12
Australia
10:3
authorization
74:7
authorized
74:2,4,5
auto
48:2,8,19 49:1
available
32:20 33:12 35:7
34:8,11,16 40:5 88:13
36:10 48:2 50:6
Avenue
55:20 63:11 64:14
2:6 3:20 6:12
65:4 72:13,15 73:12
await
74:3 75:8,17,21 77:22
31:9
82:9 87:7
aware
before
22:22 23:5 38:10 73:17 2:13 8:17,22 10:8,16
75:1 77:12
18:8 21:4,14 25:12
A-L-A-N
35:20 47:3 54:10
8:19
56:8 61:11 63:3,17
a.m
71:18 77:20 78:2,4
1:16 71:12 82:2 88:5
91:5
89:11
begin
7:16 8:17,22
beginning
82:10
5:9
begins
back
6:2 71:13
11:20 35:3 36:18 39:6 behalf
71:14 79:22 82:3,9
3:3,14 6:17,19,21 7:1,6
88:6
7:7,9
background
being
9:21
9:8 17:10 35:20 52:16
badges
87:14
18:16
Bekesha
Baghdad
3:4 5:4,6 6:17,17 7:21
10:4
8:4,7 20:9 23:10,21
based
26:7 41:10 43:6
51:14,16
48:12 52:12 54:2
basic
61:5 67:12,14 71:7
11:19 18:16
81:17,21 84:21 85:2
basically
87:22 88:16,19,22
13:2 32:2
89:7
believe
25:17,19,21 26:5 29:2
21:13,16 22:10 25:2
37:13
26:8 28:12 38:18,20
because
41:1 49:6 51:13 55:3
9:17 27:1 38:21 48:18
63:1 72:18 74:3 84:1
48:20 49:1 58:17
Bentel
60:10 62:14 78:3,7
15:3 55:15,16 56:10,15
79:22
56:15 57:3
become
Berlin
16:3
4:5 7:11,11
been
Berman
8:1 10:1 14:3 15:18,20 3:16 7:7,7 67:9,13 81:4
17:6 19:16,16 27:13
81:14 86:5
27:15 32:4,12,14,15
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
besides
39:7 42:3,10 60:7 65:7
66:21 87:10
best
62:21
better
9:7 17:2
between
10:13,14 11:5 12:1
13:4,5 15:5,12 24:5
44:3
big
17:1 71:2
bigger
14:17
bit
9:2 12:20 14:14 15:5
15:12 17:3 19:9
66:18 71:18
BlackBerry
25:21 26:16 29:2,9
30:4 37:22 38:13
39:8 48:3 53:9,10,12
53:21,22 56:22 58:22
62:13 63:5,6,14 71:20
72:8,11,14,19 73:1,3
73:4,7,8,11,16,19,21
74:6 75:4,9,13,18
76:3,6,7,13,16 77:11
78:19,20 79:2,7,13,21
80:3,5 81:3,7,12
85:21,22 86:1,3
BlackBerrys
26:13 74:21 76:9 77:2
77:8
board
17:15,16 70:12
books
19:16
Boswell
74:13,14
both
72:3
bottom
61:19 82:11
BRANCH
3:19
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
break
20:9 71:8,8 81:20 88:2
brief
9:21
briefing
51:16
bringing
16:10 17:14
British
10:4
brought
70:11
Bryan
70:6
budget
12:17
building
16:21
bulk
60:10
bullet
24:14,15
bureau
12:16
bureaucracy
11:1
business
8:16 43:4 52:22 57:7
57:15,18,20 58:8
80:11,16 85:14,18
86:4,12,16,21
Butzgy
54:13,15 55:18
3:1 4:1,1 5:1 6:1 70:12
88:11
call
71:2
called
13:18
calls
48:6 50:18 75:10
came
17:16 66:9 78:11 91:5
capability
62:20
care
55:8
career
84:9,13 87:2
Caroline
3:15 7:5
carried
76:12
carries
61:21 82:11
carry
76:19,20
carrying
76:6,10,16
case
6:6 58:20 66:8 91:16
ccd
30:7
certain
34:15
Certainly
71:9
CERTIFICATE
91:1
certify
91:5
cetera
29:1 59:14
chain
24:9 30:6 37:3 44:21
82:10 83:5
chains
43:14
chance
24:1 54:6 61:8
change
13:4 15:11 28:3,6,9,11
28:13 36:7
changed
28:16 35:22 36:1,16
changes
59:14
Characterize
79:10
charge
13:15 22:3 72:13
chat
25:17
check
24:17 26:15,22 29:2,8
31:12 38:8,14 39:14
39:20 63:19 82:13,20
83:16,19
checking
37:22 38:1 82:16 83:2
Cheryl
18:22 37:11 61:22
72:22 77:10,14 78:10
83:8,8
Chief
8:15
China
10:2
Chris
54:18 55:10
Christopher
54:13,14
circumstances
58:1,11 60:6
Civil
1:7
Clarence
13:18 64:20 65:6
classified
21:20 55:6
ClassNet
21:19
cleaned
20:16
clear
27:1 51:5,5
cleared
20:5
client
41:11
Clinton
8:14 13:6 15:14 17:5
17:10,13,19 18:2,3
20:3 21:4,9 22:8,9,13
22:14,18 23:7,7 25:1
28:3,16 35:6 38:8
39:3,8 40:11 41:2,3
49:10 51:19 52:2,21
53:2,5,8,11 63:22
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
65:11,16,20,21 71:19
72:21 73:1 77:21
78:19 79:2,6,17 80:1
80:15 81:2,6 82:16,20
83:15 85:4,4,13,17,21
86:18,19
Clintonemail.com
8:13 49:10,14 51:20
60:15
Clintons
20:14 36:6 40:8 52:4
52:10 56:19,22 57:3
63:5,14 70:3 78:19
closely
31:2
Coast
10:3
Colin
21:16
Columbia
1:2 2:15 6:6 10:4 91:21
come
36:18 55:19 74:7,7,8
78:8
comfortable
37:22
commercial
34:19
commercially
40:5
commission
91:22
common
59:21
communicate
46:15,16 85:6,10 86:1
communicated
78:14 80:15
communications
12:19 14:12,15,19 57:2
compartmentalized
29:19
complete
90:6
complicated
39:19,20
Compound
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
20:8 27:9
computer
18:14 19:22 20:21,22
21:4,9,11,15,16,18,21
24:7 25:11 26:20,21
27:2,6,21 29:4,5,7
31:19 32:1 33:4,5,22
34:12,21 35:6,7,9,15
35:16 36:10,19 37:12
39:15 48:19 55:6
58:21 63:18 83:14,18
84:2 85:5,14,18 91:12
computers
32:8,17 33:6 59:15
computer-aided
91:12
concern
37:15 88:17
concerning
27:6
conclusion
7:20 50:19
Condi
16:9
conduct
8:16 43:3 52:21 57:14
57:18,20 58:7 80:16
85:14,18 86:3,11,16
86:20,21
conducting
67:16 80:11
confirm
51:19 55:22
Congress
13:9
connect
32:1
connected
31:11,20 32:18 33:10
58:15,18
consideration
89:4
considered
29:11
consultant
70:12
contact
17:21 53:15,20 64:10
77:15 78:12 86:9
contained
68:19
contemplated
88:15
CONTINUED
85:1
control
58:15
conversation
25:9 26:1,2,8,10 28:18
37:16,17,20 44:22
51:14 86:14
conversations
43:14,21 45:16 52:20
63:4,17 73:6 75:6
coordinated
31:2
correct
24:12 25:21 27:4 29:16
31:16 32:22 35:13
36:13 37:8 38:5 39:1
39:21 42:14 44:4,5
49:5 51:22 62:4
71:22 72:9 83:16
90:5
corrections
90:7
correctly
54:15
correspond
44:17 45:15
correspondence
13:16 64:21
corresponding
45:13
Cotca
3:7 6:21,21
could
8:17 9:15,20 12:20
14:14 23:14,18 24:4
24:14 30:4 31:19
34:3 43:10 73:4,6
75:12,19,21
couldnt
53:13 58:22 78:8
counsel
6:14 8:3,22 9:16 42:4
65:7 66:22 67:10,12
67:15 68:17 82:5
85:1 91:8,15
counselor
24:16 27:7,7,10,12
28:12
counselors
27:18,22 28:3,15 73:7
73:15
count
69:7
couple
18:8 63:17 84:21
course
16:18 50:5
court
1:1 2:14 6:5 7:13,17
9:11,18
covered
68:10
create
29:8
created
57:6
creation
8:12
CRR
1:22
crux
26:12
cumbersome
35:11
current
10:6 16:8
customers
55:20
4:1 6:1
Dakar
10:5
Dan
24:15,18,19 25:4
Daniel
11:14 30:9
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
date
6:7 17:8 19:17 90:12
day
18:15 25:15 35:15 78:9
79:7
days
18:8
1:14 2:7 3:11,21
dealt
12:22
December
17:7
decided
19:14
declining
89:5
Defendant
1:10 3:14 82:5
Define
77:6
delete
50:20 51:1,4
deletes
51:10
department
1:9 2:5 3:18 4:5 6:5,12
7:6,8,10,11 8:11 9:22
10:12 13:11 14:18
15:6,16 17:22 20:3
30:19 32:5,17 34:3
43:15 46:6,7 50:4
51:9 53:17 56:4
59:22 60:2 62:17
63:6,22 66:20 67:4,7
68:13,17,18 69:1
70:21 71:5 72:19
73:3,11 74:21 75:3,9
75:17,20 76:3 79:1,14
85:10 87:6
departments
12:14
Departments
14:17 32:18
department-issued
62:12
departure
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
11:17
deponent
90:1 91:6,9
Depos
6:10 7:15
deposition
1:13 2:1 5:12 6:3,11
7:20 9:2 88:17 89:9
deputies
8:14 12:7 14:1
deputy
8:14 10:11 11:4,7,9,19
11:21 12:1,3 13:21,22
14:10 19:15,18
describe
10:21
described
81:9
desk
21:1,22 26:17,21 27:2
31:13 36:7 55:19
desktop
38:2 39:15 59:2,3
75:14
desktops
59:4
detail
19:9
details
31:18 62:21
devices
30:1
difference
11:22
different
12:8,14 32:4,13,14,15
35:7 68:6 89:4
difficult
9:18 28:21
Dineen
4:6 6:9
Diplomatic
74:8,12
direct
83:4
directing
82:8
direction
91:13
directly
13:19 27:15 56:16
director
10:12 11:22 12:2,11
14:9 15:2,21,22 16:4
30:20 50:9 58:9
61:14 63:2 64:3
70:17 84:8,11
discovery
88:11
discuss
10:16 52:1,4 69:15
77:16
discussed
42:3 69:2,22 87:14
discussing
17:19 18:20 19:10
discussion
19:19,21 39:5
discussions
18:9,13,14,18,22 19:3
61:1 73:15 78:9
District
1:1,2 2:15 6:5,6 91:21
document
13:9 23:16,18 24:2,4
54:7 61:9,20
documents
43:11
doing
80:5,9,13
domain
30:8
domestic
72:4
done
9:15,17 60:11 78:4,6
double
16:6
down
20:9 35:14 62:15
dozen
81:16
Dublin
10:3
duly
8:1 91:7
during
11:13 23:7 37:19 40:6
45:16,17 46:14,15,21
50:4 53:13 70:16
72:20 77:13,19 79:7
80:12 84:8,10 87:1,14
duties
55:10
D.C
6:13 10:6,10
31:12
encompasses
29:13
encumbered
16:6
ended
79:8
enforcement
42:4,5 65:7 67:15
68:18
ensure
14:18
entailed
26:11
enter
3:1,1 4:1,1,1 5:1,9 6:1
35:20
6:1
entered
earlier
18:10 48:9 88:12
31:15 51:18 75:7 77:13 equipment
79:4 82:14 83:13
18:15 19:22 20:21 21:4
84:5
38:14 48:19 86:9,11
early
86:16
61:15
Eric
ease
74:13
33:3
Errata
easier
90:7
9:12 33:8,12 65:19
errors
eight
55:21
36:3,8 43:13,14
escalating
either
17:3
75:13
ESQUIRE
Electronic
3:4,5,6,7,15,16,17
55:4
else
29:1 59:14
15:9 39:8 52:5,9,19
ever
60:17 68:12 69:8
23:6 47:10 49:18 50:6
77:19 89:7
51:6 52:4,8,8 53:5,8
employed
56:10,18,21 58:6
91:15
60:20 63:21 64:7,10
employee
72:20,22 76:6 78:18
51:10 87:5
78:22 79:16 80:19
employees
86:10,14,18
12:10,12 22:4,5 23:2
every
32:5,9,13,17 34:3,14
35:15 36:2,3,3,8
34:17 35:4 46:6
evidence
59:22 60:3 61:3
79:10
74:19 80:14,19
exact
enable
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
44:9
exactly
20:15
EXAMINATION
5:3 8:3 82:5 85:1
examined
90:4 91:8
Except
75:19
exceptions
74:19
exchange
24:5 69:13
excluding
69:1
Excuse
18:4
executive
10:11,12,18,20 11:3,5
11:10,12,14,16,21,22
12:1,2,3,10 13:12,20
13:21 14:1,5,10 15:21
15:22 16:3 24:20
30:20 50:9 58:8
61:13 62:2 63:2,10
64:3 70:16,22 74:21
79:18 84:8,11
Exhibit
5:12,13,14,15,16 23:11
23:11,12,15 43:7,8,13
43:16,17 54:3,4 61:5
61:6 82:9
exhibits
47:4
expedient
58:19
expires
91:22
extent
21:21 41:16 69:5 77:15
e-mail
5:13,14,15,16 22:3,9
22:14,19 23:1,4,6,7
24:5,9,11,17 25:3,8
25:12 26:4 27:6,10
28:20 30:3,6 31:8
32:19 33:16,18 34:19
37:2,3,10,13 38:8,14
38:16,19,22 39:3,9,15
39:16,20 40:2,5,8,11
41:3,3,4 42:7,20 43:3
43:14,14,20 44:1,6,8
44:10,14,17,21,22
45:3,7,9,19 46:2,6,9
46:11,17,22 47:5,11
47:14,20,22 48:9,18
48:21 49:4,9,13,17,18
52:2,5,10,15,17,18,21
53:6 54:12,13 55:18
56:11,19 57:3,6,10,11
57:14,17,19 58:7,14
58:20 59:2,10,18 60:5
60:15,21 61:11,20,21
62:15,17 63:3,19,22
69:12 70:3 75:6 80:8
80:8,15 82:10,14,17
82:20 83:2,5,6,16,19
85:6 86:20,20 87:14
87:19
e-mailed
28:19
e-mails
26:16,22 31:12 37:22
38:2 43:7,20 44:2,3,7
45:17,21 46:1,5,10,22
47:4,8,15,20,21 48:10
48:18 49:16 50:20
51:1,3 56:4,7 61:2
79:4 80:20,20 87:13
3:5
facilitates
10:22
facility
29:20
fact
45:22
family
82:22 83:20,22 85:6,7
86:1,9
far
33:9 78:7
fatal
55:21
feature
48:8,19 49:2
features
36:12
federal
3:19 50:14,16 84:7
87:19
few
8:21 16:7 71:16 72:2,8
82:7
fewer
33:15
files
51:2,5
fill
19:14 48:2,8,19 49:1
filled
19:16
Finally
9:15
financial
91:17
find
45:17
Finney
13:18,19 64:20 65:6
firewalls
34:14
first
11:15 18:15 19:3 24:9
25:13 27:5,10 37:3
44:20 61:20 70:8
Fitton
4:4 7:3,3
five-minute
71:7
floor
29:13 31:3,4,18
flow
11:6
flying
66:6
focus
10:9 12:4
FOIA
13:9 62:19 64:4,7,11
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
64:15
folks
55:8
following
68:1
follows
8:2
follow-up
84:21 87:9
Force
66:5
foregoing
90:4
foreign
10:1 51:17 53:3
forget
67:20
former
15:13 22:22 82:16,19
83:15 86:6
forward
25:15 58:19
foundation
32:7 34:6 46:13 47:17
49:22 68:21 79:11
four
11:4,9 12:3 46:14
framework
58:3
Francisco
10:7
Freedom
8:10 49:19 50:1,7,10
84:6,17 87:2,20
freely
35:5
frequency
76:14
frequent
46:19
frequently
35:22 59:14 76:12
friends
82:22 83:21,22 85:6,7
86:1,9
full
8:18 34:8,11
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
fully
83:6
function
12:7
functioning
10:22
functions
11:19 68:3
funeral
66:1,6
further
84:19 88:8 89:3
6:1
gears
15:11
general
10:17,19 12:18,21,22
15:5 21:19 50:3
70:20
generally
10:21 29:21 30:16
31:20 34:15
gentleman
13:18
gestures
9:11
give
9:21,21 23:19
given
90:6 91:10
Gmail
34:18 40:1
8:21 9:2 16:14 23:10
24:16 29:1,8 31:9
35:2 59:9 73:6 77:16
79:22
going
10:9 23:10 26:15 31:21
34:15 36:11 60:3
79:2 81:4 85:5,9 86:2
86:11,15,19,19 89:9
Good
8:5,6
government
8:16 43:4 52:22 57:7
57:15,18,20 58:8
80:11,16 85:14,18
86:3,12,16,21
great
71:15 83:9
green
31:9
ground
8:21
guess
11:19 15:4 16:14 24:9
37:3 38:13 61:16
81:7,8
guidance
50:6,10,13 51:14 84:6
84:13 87:2,4,9,10,18
5:9 54:13 56:13
HAbedin
30:8
half
81:16
hall
24:17 27:13,16,18
28:22 29:1,6,15
hallway
80:1 81:2,6,8,13
hammer
62:21
hand
9:11 66:8
handle
64:4
hands
76:21
Hanley
62:1,5
happened
18:5 20:19 21:3 65:5
75:15
happy
9:4
hard
32:2
hard-wired
32:3
head
9:11 74:10
headed
13:17
hear
9:3
heard
40:18 51:20,21
held
2:2
help
9:1 42:12 55:19
helped
42:11
here
6:2 8:8 71:13
hereby
90:3 91:5
herein
91:6
Hillary
8:14
hold
53:22
holding
53:10,12 72:7
Hotmail
34:18 40:2
HRC
24:16 25:1,17 37:12
82:15
Huma
8:15 30:11 42:17 61:22
78:17
human
12:17
idea
57:8 77:1 80:9 83:10
83:14
identification
23:13 43:9 54:5 61:7
identify
6:15 23:18 24:4 29:17
39:7 88:19 89:6
identifying
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
89:2
identity
62:18
immediately
77:20
implications
49:19
important
9:9 79:5,6
inauguration
78:8
inbox
51:5
Inc
1:4 3:8 6:4
included
84:16
incoming
22:4,4 77:17
independent
51:9
indication
83:1
individuals
18:10 42:16
info
25:19
information
8:10 14:7 29:19 49:19
50:2,7,11 68:9 84:7
84:17 87:3,20 89:2
infrequently
53:13 71:20 72:1
initial
37:17 52:20
inquire
85:12
instances
76:15
instruct
60:20
instructed
50:6
instructing
41:10 48:12 52:12
interacted
78:11
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
interaction
30:21
interest
91:16
international
72:4,4,5
internationally
72:7
Internet
26:22 31:11,21 32:1,19
33:14 34:7,8,11,16
35:4,18,20 59:9,12
62:20 75:22
interrupt
67:10
introduce
43:6
inventoried
65:2
investigation
42:6 67:17
invoke
88:11
involved
13:8 15:18
iPhones
26:13
Ireland
10:4
IRM
14:7,14,16,17 15:2,5
22:6,8 54:18 70:20
71:2
issue
25:5,8,10 26:12 40:19
42:7 66:21 67:2 79:2
79:12
issued
75:3
issues
13:1 17:15 19:10 31:2
66:9 68:18 69:15
77:16,16 78:10
issuing
63:22 72:14 73:1,3
itself
79:8
Ivory
10:3
3:6 4:4
James
3:5 7:1
January
18:4
Jeremy
4:6 6:9
job
1:20 11:19 58:3,5
65:22 68:3 84:10
jobs
14:20 58:4
John
15:3 55:15
joined
51:17 87:6
Judge
88:12
Judicial
1:4 3:8 4:4 6:4,18,20
6:22 7:2,4 8:8,9
June
61:15 69:13,14
Justice
2:5 3:18 6:12 68:17
keep
51:3
Kennedy
30:8,12,13 37:4,5,6
62:1 69:19 70:2
74:16 83:7 85:16
kept
51:2
key
16:22
kind
18:13
knew
33:9 38:21 49:6 76:22
know
9:4,6 10:8 15:18 16:19
16:22 20:18,20,22
21:2,3,6,8,11,14,18
21:20 22:1,8,11 23:2
25:10 27:5,20 28:9,14
28:17 29:4 32:8,12
33:1,17 34:7,17,18
35:5 36:22 37:1,12,15
38:7,7,16 39:16,18,19
42:19 43:2 44:10,13
45:6 47:13 49:3,4
50:1,16 51:11,19
52:17,21 53:1 54:14
55:2,10 56:3,13 57:5
57:9,12,13,16 59:8,22
60:2,17,18 62:5,7
64:14,22 65:3,4 70:6
70:13,19,20 72:10,12
72:13 73:14 74:1,18
74:18 76:2,5,12,14
77:10 79:7,12 80:4,10
80:10,13,14 85:9
87:17
known
19:6
lack
17:2 32:6 34:5 46:12
47:16 49:21 68:20
79:10
land
27:15
laptop
75:20,21
Lara
4:5 7:11
large
14:21
last
37:2 40:14 44:20,21
51:21 54:12 61:17
65:15,19 66:13,14
69:10,13,14,18,20
83:5 88:1
later
25:15 83:4
law
42:4,5 65:7 67:15
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
68:18
lawsuits
8:10
layout
27:14
leadership
14:18
learn
39:14 40:7,13 70:8
learned
40:10 47:19,20 49:12
70:10
leave
61:13
leaving
15:15 63:1
left
28:16 63:1 64:22 65:22
66:17 70:3
leftover
20:18
legal
50:19
lets
11:19 19:9 20:10 24:8
28:21 54:2
Lewis
1:13 2:1 3:15 5:3 6:3
8:1,19 89:9 90:3 91:7
liaise
14:16
liaising
15:5
light
31:9
limitations
34:4
line
32:2 56:13 82:12
little
9:2 12:20 14:14 15:4
15:11 17:3 19:9
28:20 66:18 71:18
location
28:2
log
33:8,12,13 35:10 59:15
Videotaped Deposition Lewis Alan Lukens
Conducted May 18, 2016
100
logistics
11:6 12:5 17:21 18:16
18:21 42:10,12
logon
59:12
look
23:14 24:1,8,14 37:2
61:8,19
looked
75:6
looking
54:12 59:19 62:10 79:4
80:2
looks
24:10 44:22 83:7
lot
29:13
loud
9:10
Lukens
1:13