Skip to content

Get Judicial Watch Updates!

DONATE

Judicial Watch • JW v State Plf’s Response 01363

JW v State Plf’s Response 01363

JW v State Plf’s Response 01363

Page 1: JW v State Plf’s Response  01363

Category:Clintons

Number of Pages:3

Date Created:August 10, 2015

Date Uploaded to the Library:August 11, 2015

Tags:possession, Plfs, returned, official, notice, 01363, Abedin, response, Mills, responsive, defendant, clinton, filed, State Department, michael, plaintiff, document, records, FOIA, report


File Scanned for Malware

Donate now to keep these documents public!


See Generated Text   ∨

Autogenerated text from PDF

Case 1:13-cv-01363-EGS Document Filed 08/10/15 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
Plaintiff,
U.S. DEPARTMENT STATE,
Defendant.
Civil Action No. 13-cv-1363 (EGS)
PLAINTIFF RESPONSE
DEFENDANT RECENT FILINGS
Plaintiff Judicial Watch, Inc., counsel, respectfully submits this response
Defendant August 2015 Notice Filing, its August 2015 Status Report, and its August
10, 2015 Status Report:
Neither the Court nor Plaintiff any closer knowing where responsive records
may exist.
Both Mrs. Clinton and Ms. Mills state that they not know what records would responsive Judicial Watch FOIA request. Therefore, the utmost importance that
all federal records the possession Mrs. Clinton, Ms. Abedin, and Ms. Mills returned
Defendant enable Defendant conduct search reasonably calculated uncover all
responsive records.
Although Mrs. Clinton filed declaration under penalty perjury, many issues
remain unresolved. still unknown whether Mrs. Clinton has returned Defendant all
emails clintonemail.com which she conducted official government business. Mrs.
Clinton declaration only identifies the fact that she directed all potential federal records
Case 1:13-cv-01363-EGS Document Filed 08/10/15 Page
returned Defendant. She does not identify who she directed return such records
Defendant. Nor does she identify the process and criteria which the unnamed individual was search for, review, and return Defendant all potential federal records.
There also evidence whatsoever that all responsive information that was her possession was returned Defendant. Mrs. Clinton did not identify whether she used
any email server besides clintonemail.com. Nor did she identify whether she has returned
Defendant all Ms. Abedin emails clintonemail.com which Ms. Abedin conducted
official government business.
Ms. Abedin and Ms. Mills entirely ignored the Court order. Neither Ms. Abedin
nor Ms. Mills confirmed, under penalty perjury, that they have returned all responsive
information that was their possession. Nor did they describe, under penalty perjury,
the extent which they used Mrs. Clintons email server conduct official government
business.
With respect Ms. Abedin, there evidence all that she has returned all
responsive information that was her possession. Nor there any evidence that either
Mrs. Clinton Ms. Abedin has returned any the emails clintonemail.com which official
government business was conducted Ms. Abedin. Nor there any evidence identifying who
has possession such records. Nor has Ms. Abedin identified whether she used any other email
servers conduct official government business.
With respect Ms. Mills, there evidence whatsoever that she has returned
all responsive information that was her possession. Since Ms. Mills purportedly did not
-2-
Case 1:13-cv-01363-EGS Document Filed 08/10/15 Page
use clintonemail.com, important know what email server she used other than Defendant
email server conduct official government business.
Along with its August 2015 Notice Filing, Defendant filed additional letters
that sent Ms. Abedin and Ms. Mills July 31, 2015. These letters requested that Ms.
Abedin and Ms. Mills now take steps return all copies potential federal records [their]
possession soon possible and that they provide electronically stored records
original/native electronic format with the associated metadata. Based the entire record,
appears that Defendant has not requested Mrs. Clinton take similar steps return all copies
potential federal records her possession soon possible and provide electronically
stored records their original/native electronic format with the associated metadata.
Because these aforementioned omissions and the fact that Defendant will not
identify until August 14, 2015 any and all servers, accounts, hard drives, other devices
currently the possession control the State Department otherwise that may contain
responsive information, still unknown whether Defendant has requested Mrs. Clinton, Ms.
Abedin, and Ms. Mills return Defendant all records systems records that may contain
information responsive Plaintiff FOIA request.
Dated: August 10, 2015
Respectfully submitted,
/s/ Michael Bekesha
Michael Bekesha
JUDICIAL WATCH, INC.
425 Third Street S.W., Suite 800
Washington, 20024
(202) 646-5172
Counsel for Plaintiff Judicial Watch, Inc.
-3-