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Judicial Watch • JW v. State Pagliano refusal of deposition 01363

JW v. State Pagliano refusal of deposition 01363

JW v. State Pagliano refusal of deposition 01363

Page 1: JW v. State Pagliano refusal of deposition 01363


Number of Pages:1

Date Created:May 21, 2016

Date Uploaded to the Library:May 25, 2016

Tags:strauss, macdougall, refusal, paglianos, hillary clinton email, subpoena, Connor, Clinton Emails, cotca, Pagliano, bryan, Hillary Clinton Email Scandal, deposition, order, Washington

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Akin Gump
MARKJ.MACDOUGALL 202.887.4510/fax:+1 202.887.4288
May 21,2016
Ramona Cotca, Esq.
Judicial Watch, Inc.
425 Third Street,
Suite 800
Washington, 20024
Re: Judicial Watch, Inc. Dept State, Case No. 13-1363 (D.D.C.)
Deposition Bryan Pagliano noticed for June 2016
Dear Ms. Cotca, you know, represent Bryan Pagliano. Last week accepted service behalf our
client Rule subpoena, dated May 12,2016, that was issued the captioned case (the
Subpoena). The Subpoena calls for Mr. Pagliano appear and testify deposition
taken June 6,2016. have read the Memorandum and Order issued the Court this case May 2016 and
have noted, particular, the limitations the scope discovery articulated Section III. are writing inform you that, with the advice counsel, Mr. Pagliano will decline
answer any and all questions that may put him the scheduled deposition reliance
his rights under the Fifth Amendment the U.S. Constitution. Given Mr. Paglianos stated
intention, and order avoid the uruiecessary waste ofresourc~s and undue imposition Mr.
Paglianos time, would ask that Judicial Watch, Inc. withdraw the Subpoena and excuse Mr.
Pagliano from appearing June 6,2016.
Please let know you require any additional information there are aspects this matter
that should discuss telephone.
Mar MacDougall
Sean Mcy
Constance Connor
Connor Mullin
Robert Strauss Building 11333 New Hampshire Avenue, N.W.I Washington, D.C. 20036-15641202.887.40001 fax: 202.887.42881