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

JW v. State Pagliano refusal of video 01363

JW v. State Pagliano refusal of video 01363

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


Number of Pages:1

Date Created:May 25, 2016

Date Uploaded to the Library:May 25, 2016

Tags:akingump, stenographic, strauss, refusal, paglianos, hillary clinton email, cotca, Video, Pagliano, Hillary Clinton Email Scandal, amendment, rights, deposition, order, Washington

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MARKJ.MACDOUGALL 202.887.4510/fax: 202.887.4288
May 25,2016
Ramona Cotca
Senior Attorney
Judicial Watch, Inc.
425 Third Street, SW, Suite 800
Washington, 20024
Re: Judicial Watch, Inc. Dept State, Case No. 13-1363 (D.D.C.)
Dear Ms. Cotca, understand from your May 24, 2016 email that Judicial Watch insisting that our client,
Bryan Pagliano, appear for deposition and assert his rights under the Fifth Amendment the
record June 2016.
The subpoena that was served Mr. Pagliano provides that the deposition will recorded
stenographic and audiovisual means.; you know, the only proper purpose videotaped
deposition record deponents demeanor order assist the trier fact assessing
credibility. have made clear that, given the scope the Courts order, Mr. Pagliano will
decline answer each and every question reliance his Fifth Amendment rights.
Accordingly, there can proper purpose seeking make video recording Mr.
Paglianos testimony. would like your advance assuranc~ that Mr. Paglianos deposition will recorded solely
stenographic means. you are unwilling provide that assurance, please let know
immediately that may timely seek protective order.
Nothing this letter intended waive, modify release any right, privilege remedy that
may available- our client.
RobertS. Strauss Building 11333 New Hampshire Avenue, N.W. 1Washington, D.C. 20036-1564 1202.887.4000 1fax 202.887.4288