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Judicial Watch • JW v State Sheryl Walter depo 01242

JW v State Sheryl Walter depo 01242

JW v State Sheryl Walter depo 01242

Page 1: JW v State Sheryl Walter depo 01242

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Number of Pages:53

Date Created:June 17, 2019

Date Uploaded to the Library:June 19, 2019

Tags:Sheryl, cotca, samuelson, planetdepos, 01242, Walter, Foundation, Hillary Clinton, White House, State Department, FOIA


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Planet Depos Make Happen
Transcript Sheryl Walter
Date: June 14, 2019
Case: Judicial Watch, Inc. -v- U.S. Department State
Planet Depos
Phone: 888.433.3767
Email:: transcripts@planetdepos.com
www.planetdepos.com
WORLDWIDE COURT REPORTING INTERPRETATION TRIAL SERVICES
Transcript Sheryl Walter
Conducted June 14, 2019 THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA BEHALF PLAINTIFF:
RAMONA COTCA, ESQUIRE
JUDICIAL WATCH, INC.,
LAUREN BURKE, ESQUIRE
JUDICIAL WATCH, INC. Civil Action No.
425 Third Street,
Suite 800
Plaintiff,
U.S. DEPARTMENT STATE, 14-01242 (RCL)
Defendant.
Washington, 20024
(202) 646-5172
Videotaped Deposition SHERYL WALTER BEHALF DEFENDANT AND THE WITNESS:
Washington,
STEPHEN PEZZI, ESQUIRE
Friday, June 14, 2019
U.S. DEPARTMENT JUSTICE
2:04 p.m.
FEDERAL PROGRAMS BRANCH
1100 Street,
Washington, 20005
(202) 305-7583 Job No.:
245268 Pages 102 Reported by:
Debra Whitehead
Videotaped Deposition SHERYL WALTER, held
the offices of: BEHALF DEFENDANT AND THE WITNESS:
ELIZABETH SHAPIRO, ESQUIRE
PLANET DEPOS
U.S. DEPARTMENT JUSTICE
1100 Connecticut Avenue,
CIVIL DIVISION
Suite 950 Massachusetts Avenue,
Washington, 20036
Washington, 20530
(888) 433-3767
(202) 514-2205 BEHALF DEFENDANT:
MICHAEL LIEBERMAN, ESQUIRE Approved Reporter the United States District
Pursuant notice, before Debra Whitehead,
UNITED STATES DEPARTMENT STATE Court and Notary Public the District Columbia.
2201 Street,
Washington, 20520
(202) 647-6371 ALSO PRESENT:
JEREMY DINEEN, Video Specialist
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Sheryl Walter
Conducted June 14, 2019
EXAMINATION SHERYL WALTER
PAGE Ms. Cotca
EXHIBITS MARKED TODAYS SESSION
(Retained Counsel)
WALTER DEPOSITION EXHIBIT
Exhibit
and Services, A/GIS/IPS org
Chart
Exhibit
Dated 4/19/13 from Mr. Davis
Mr. Johnson
Dated 12/27/12 from Ms. Walter Ms. Samuelson
DOS_00000898_0001
DOS_00000898_0002
Exhibit
E-mail String, Bates Nos.
DOS_00000901_0001
DOS_00000901_0005
EXHIBITS MARKED TODAYS SESSION CONTINUED
WALTER DEPOSITION EXHIBIT
Exhibit
E-mail String, Bates Nos.
E-mail String, Bates Nos.
DOS_00001326_0001
DOS_00001326_0003
Exhibit
Departing Officials:
Procedures
For the Removal Personal
Papers and Non-Record Matter,
Government Records, Briefing
Booklet for Federal Officials,
Bureau Administration, Office Information Programs and
Services, March 2012
January 25, 2013
Exhibit
DOS_00003631 DOS_00003632
Exhibit
DOS_00000902_0005
Exhibit
PAGE
E-mail String, Bates Nos.
DOS_00000902_0001
E-mail String, Bates Nos.
Twitter
PAGE
Exhibit
6/10/13 Article from The
E-mail String Ending with E-mail
Exhibit
Exhibit
(Retained Counsel)
FINNEY DEPOSITION EXHIBIT
Guardian, Hillary Clinton Joins
E-mail String Ending with E-mail
EXHIBITS MARKED PRIOR SESSIONS
PAGE
Office Information Programs
PROCEEDINGS
VIDEO SPECIALIST: Here begins Disk Number the videotaped deposition Sheryl Walter the matter Judicial Watch, Inc., the U.S. Department State, the U.S. District Court for the District Columbia; Case Number 14-01242.
Todays date June 14, 2019. The time the video monitor 2:04 p.m. The videographer today Jeremy Dineen, representing Planet Depos. This video deposition taking place the offices Planet Depos, 1100 Connecticut Avenue, Northwest, Suite 950, Washington, DC.
Would counsel please voice-identify themselves and state whom they represent.
MS. COTCA: Ramona Cotca, for the plaintiff.
MS. BURKE: Lauren Burke, for the
plaintiff.
MR. PEZZI: Stephen Pezzi from the Department Justice, behalf the defendant,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Sheryl Walter
Conducted June 14, 2019 12) the Department State and behalf the witness her official capacity former employee the United States Department State.
And the witness reserves the right read and sign the transcript.
MS. SHAPIRO: Elizabeth Shapiro, behalf the defendant and the witness her capacity former employee the State Department.
MR. LIEBERMAN: Michael Lieberman, for
the
State
Department.
VIDEO SPECIALIST: Thank you.
The court reporter today Debbie Whitehead, representing Planet Depos.
Would the reporter please swear the
witness.
SHERYL WALTER, having been duly sworn, testified follows: EXAMINATION COUNSEL FOR PLAINTIFF MS. COTCA: Good afternoon, Ms. Walter. Before begin, could you please state your name, for the Yes. Okay. All right. Nonetheless, just you need break any point, please let know and were happy break. Okay? Thank you. Sure. And the only other thing is, ask question that you think you need clarification you dont understand, please let know and happy clarify it. you dont, Ill assume you understood the question. that fair? course. Yes. Thank you. Can can you please let know what your position was the State Department? Yes. was the director the Office Information Programs and Services. Okay. the Department State. Okay. And what was the time frame that you were there? was there from 2011 2014. record. name Sheryl Walter. Okay.
MR. PEZZI: And before get started sorry interrupt just want clear for the record that our expectation that the questioning going limited minutes, based the representations that Judicial Watch made the court.
MS. COTCA: are going try stay within the minutes that represented the court.
MR. PEZZI: appreciate that.
MS. COTCA: course. Ms. Walter, have you ever been deposed before? Yes. Okay. youre familiar with the rules deposition? Yes. Okay. And understand that youre attorney. Correct? March 2014. Okay. And when did you begin 2011? Was December 2011, you recall? was either was either November December. Okay. Thank you.
(Walter Deposition Exhibit marked for identification, retained counsel.) Here, Ill just show you whats been marked whats been premarked Exhibit
MS. COTCA: And Lauren will hand out
copies
for you all. just want to, you can take look it. And this chart your office? Yes, appears be. Okay. the time that was the State Department. Correct. And were just going focus, the time period just going from 2011 2014 when you left the State Department. March 2014.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Sheryl Walter
Conducted June 14, 2019 Yes. Just during your tenure the State Department. Okay?
And you were the director. And thats the top the chart. Correct? Correct. Okay. Can you tell what did your office do? What did IPS do? Well, lays out here, were charge information programs and services for the State Department; that included records and archives administration, included processing FOIA requests, included the departments library, and variety things related records. Okay. fair say that your -16 your office was primarily was handled the FOIA program the State Department? Yes. Okay. And for which you were the director of. Correct? Yes. Okay. During your time when you were that came that related her e-mails?
MR. PEZZI: Objection. Form. No. The process would the same for any request. Okay. Specific for FOIA requests relating Secretary Clinton, just want understand, once was came into your office and was tasked one the two offices that that you identified, how would the search for e-mails from the Secretarys offices tasked that point?
MR. PEZZI: Objection. Foundation. can tell you how how from what recall -15 Sure. how searches would tasked.
Which was that one the analysts would contact their contact that particular bureau office division, and send them copy the request and tell them the sorts records that they would asked look for. Okay. there from two thousand November, December, 2011, March 2014, when FOIA requests came the department for e-mails from Secretary Clintons office, how were those FOIA requests tasked?
MR. PEZZI: Objection. Foundation. Well, can tell you how FOIA request was generally tasked the State Department. And would true for any FOIA request. Okay. Which was that request would come in, and would tasked out one the offices under the excuse me, under our see, trying remember now. Under our either under request for liaison division the programs and policies. And would given analyst research and figure out what -18 what parts the department should tasked search for records. Okay. Was there any difference the processing the request during Secretary Clintons tenure with respect FOIA requests (13 16) And was them search for them. Okay. the management analyst that would task it, who would they contact for searches done the Secretarys office?
MR. PEZZI: Objection. Form. And again, this just the tenure from
Secretary
Clintons term. Whoever had been tasked the Office the Secretary those searches. And not know exactly who that would be. You dont know who that during Secretary Clintons tenure, throughout your period the State Department? Throughout period the State Department, dont know exactly who the person would be. What was their title position? dont know what that would be. Okay. Okay. You provided declaration, part which was redacted, the court this case. And there you had for that declaration you had said that you had reviewed
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Sheryl Walter
Conducted June 14, 2019 (17 20) certain e-mails regards FOIA request that was submitted CREW, which Citizens For Responsibility and Ethics Washington, 2012. going ask you few questions about those documents. Okay.
(Walter Deposition Exhibit marked for identification, retained counsel.) And Ill show you whats been premarked Exhibit
MR. PEZZI: And just want clear for the record, there was also unredacted version that declaration that Judicial Watch has.
MS. COTCA: Correct. not going get into the unredacted version.
MR. PEZZI: Totally understood. just wanted clear for the record that you had it.
MS. COTCA: For sure, yes.
THE WITNESS: you have copy?
MR. PEZZI: Yes. officials. have can get the details can call the White House back. think they would like quick turnaround this. you see that? Yes. you recall receiving this FOIA request No. from CREW? No, dont. All right. you recall receiving telephone call from the White House about this request? not recall receiving phone call myself from the White House. Okay. you recall anybody receiving call from the White House about the CREW request? Well, from the context this document that youve shown me, apparently someone was called the White House, but was not me. you have was there anybody else your office who would have been position MS. COTCA: this one the documents that you reviewed for the preparation your declaration? Yes, appears be. Okay. All right. you recall well, want point you the first e-mail, which appears the third page the document.
Just for the record, this Exhibit and its document Bates-stamped DOS-899. And its four-page document that was produced the State Department discovery this case. you can look the e-mail, your e-mail from December 20th, 2012. Theres two them. just the one from me? Right. Just the one from you, the last one. the first one appearing the e-mail chain. The time stamp 12:38. Got it. Okay. Yeah. Where says, called. Have you received FOIA request from CREW the topic personal use e-mail senior have received call from the White House No. during this time frame? No. Okay. your testimony that your office would have been contacted, would have been you -MR. PEZZI: Objection form. have received the phone call?
MR. PEZZI: Objection form. its hard for know. cant speculate. Okay. you know why and pointing here your e-mail, have can you give the details can call the White House back.
Did you call the White House back response regards this FOIA request? did not make any phone call the White House. You you have want understand your testimony. want clear
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Sheryl Walter
Conducted June 14, 2019 your testimony. that you did not call the White House, that you dont recall calling the White House? dont recall calling the White House. Okay. During your tenure the State Department, did you communicate with the White House about any other FOIA request? No, did not. Are you aware any other instances where the White House would have contacted the State Department about FOIA request?
MR. PEZZI: Objection. Form. Foundation. And during this during your tenure the State Department. not aware anyone else. would not know anyone else was contacted not. Well, not asking you were directly contacted. But you are you have any knowledge about the White House contacting either not know. Would you have known her position and title the time that you were the State Department?
MR. PEZZI: Objection. Form. might have, but cant tell you that now. Okay. the e-mail Ms. Samuelson you wrote, Heather. Copy attached. was our significant weekly FOIA report that sent and S/ES also.
What significant weekly FOIA report? what was the time -14 the time? this e-mail was sent? Yes. would ask the the seniors who reported collect any FOIA requests that might significance broader scale, just would able have list some those watch them. Okay. And why was CREWs request placed this Significant FOIA Report? your office within IPS dont have any independent knowledge that, no. Okay. Can moving further the chain, the e-mail chain, and again also e-mail from you, from December 20th, 2012, time stamp 1:54 p.m., Ms. Heather Samuelson.
MR. PEZZI: Why dont you take moment review the e-mail chain.
THE WITNESS: Uh-huh. Okay. Okay. Who Heather Samuelson? dont have independent knowledge who she is. But know from having reviewed the filings this case that she had title White House Liaison. Okay. you know which office her office was in? not. Okay. you know that she worked under Patrick Kennedy and under Cheryl Mills the time that she was the State Department? (21 24) not know. because requested was the topic personal use Secretary e-mail Secretary Clinton?
MR. PEZZI: Objection. Form.
Foundation. cant tell you what reason that was that list. Okay. believe you just testified that you had senior people your office who compiled the FOIA requests.
Who were the who were those individuals? They would supervisors who worked mostly the programs and policies division. that the chart here? Okay. Yes. And who were the supervisors that division the time? the best recollection, Patrick
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Sheryl Walter
Conducted June 14, 2019 Scholl was the chief that. not cant recall who his deputies were. Okay. Thank you.
For the record, what does refer and S/ES that e-mail? would refer the Office Legal Advisor. And generally means the Office the Secretary. The ES, sorry, cant remember. Okay. But would just pure speculation, would some subset the Office the Secretary, but dont know. Okay. And later the e-mail you say, practical matter given our workload, wont processed for some months.
Why did you include that your e-mail Ms. Samuelson, that the FOIA request wouldnt processed within some months?
MR. PEZZI: Objection. Form. Its its factual statement about when would when would potentially processed. e-mail. The same e-mail, actually, that was the last exhibit, but appears this one well, from December 20th, 2012. Uh-huh. When youre inquiring the State Department received the CREW FOIA request.
You stated there that apparently other agencies have.
How did you know that other agencies had received similar request?
MR. PEZZI: Objection. Foundation. dont know how would have known that. not saying didnt know that, because said it. But dont know how.
MS. SHAPIRO: Ramona, can ask you
question?
MS. COTCA: Yes.
MS. SHAPIRO: Sorry interrupt. These two documents look like theyre completely separate documents.
Are they separate documents that youve collated? Did Ms. Samuelson ask you with respect
when
the CREW request would processed? dont have any recollection that. Okay.
(Walter Deposition Exhibit marked for identification, retained counsel.) want show you whats been premarked Exhibit
And, again, for the record e-mail chain between you and Ms. Samuelson from December 2012 about the CREW request. And the last page actually, looks like appears Outlook entry for conference call regarding the CREW FOIA request. that accurate? This -MR. PEZZI: Have you had minute review the document front you?
THE WITNESS: still looking through it. Okay. Okay. want point you your (25 28)
MS. COTCA: Yes.
MS. SHAPIRO: Okay.
MS. COTCA: But they are all documents that the State Department produced, both the documents the State Department produced separate FOIA -MS. SHAPIRO: Correct.
MS. COTCA: case relating the processing the CREW request.
MS. SHAPIRO: Correct. They had different numbers, -MS. COTCA: They are different numbers.
MS. SHAPIRO: just wanted her understand that these did not exist together.
MS. COTCA: Correct. MS. COTCA: can point you Ms. Samuelsons e-mail December 24, 2012, appearing the first page the document, which the fourth e-mail down. Where she says, Thank much, Cheryl. you could add that list, that would great.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Sheryl Walter
Conducted June 14, 2019
Why did you ask Ms. Samuelson she wanted added the list for the Significant FOIA Report?
MR. PEZZI: Objection. Foundation. dont recall the time.
But general practice was keep people informed. And more people wanted see list like that, would happy provide it. Did Ms. Samuelson ask you about being included the list for the Significant FOIA Report? She says -MR. PEZZI: Same objection. She says right here, you could add that list, that would great. Well, actually, Exhibit you look the third page, the top the third page? With when its your e-mail Ms. Samuelson from December 20th, 2012, 1:54? Uh-huh. you see where you ask, you want Foundation. think you asked that already. And have always wanted make sure all jobs, make sure that people who were interested particular topic had information they needed. And she was seemed interested this, included her the list. you know how that you came what precipitated you being touch with Ms. Samuelson about this FOIA request?
MR. PEZZI: Objection. Form. dont specifically recall, no. Did you ever meet Ms. Samuelson? did, not recall. Did you engage often, during your tenure the State Department from November, December, 2011, through March 2013, with the White House Liaisons Office? Not that recall. Did appear unusual you that somebody within the White House Liaisons Office would interested FOIA request pertaining add you that list? Yes. Okay. And then Exhibit Ms. Samuelson wrote, you could add that list after December 24. Yes. shes actually responding you agree that shes actually responding your question whether you she wanted added the list?
MR. PEZZI: Objection. Form.
Foundation. That would way interpret this. there different way interpreting it? looking just the context the document, and thats what can see from the document. Okay. you know why you why you asked Ms. Samuelson she wanted added the list?
MR. PEZZI: Objection. Form. (29 32) the Secretarys e-mails?
MR. PEZZI: Objection. Form. Foundation. cant tell you whether was unusual not. Well, did appear you the time?
MR. PEZZI: Same objections. cant recall what was thinking the time. And, also, looking again Exhibit the top the e-mail chain. December 27, you write Ms. Samuelson, Absolutely. youll shoot e-mail youre back, well find time. Shouldnt take long. But really would like your input.
What the input you wanted from
Ms.
Samuelson regards the CREW FOIA request?
MR. PEZZI: Objection. Foundation. sorry, dont recall. But this your e-mail. that not right? e-mail, yes.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Sheryl Walter
Conducted June 14, 2019 Okay. Three the third e-mail down the same exhibit Are talking about Exhibit Exhibit yes. Same exhibit. Your e-mail December Ms. Samuelson, time stamp 3:26. Say, Heather, are you around. begins with, Hi, Heather, are you around tomorrow. Yes. Okay. you see where you said, discussed this our let restart. discussed this with our attorneys today and wanted get your thoughts approach are considering. you recall what the approach that
you
were
considering that time?
MR. PEZZI: And you can answer that with yes no. No. that what you wanted discuss with Ms. Samuelson, the approach that you discussed with the attorneys? Okay. can have you look whats been premarked Exhibit
Ms. Walter, this also e-mail chain between you and Ms. Samuelson, spanning from January 10, 2013, through January 26, 2013. Again about the CREW request.
And again, includes the your initial e-mail from December actually, does not. can have you look the first e-mail the e-mail chain from January 10, 2013, from you Ms. Samuelson? 1:01 p.m.? Yes. Yes. Okay. want you can point you the body your e-mail. was this e-mail that you sent Ms. Samuelson January 10, 2013?
MR. PEZZI: Well, have you had chance review the e-mail that counsel pointing to? ask because youre youre moving little bit
MR. PEZZI: Objection. Form.
Foundation. the extent the question calling for the contents her discussion with attorneys, would instruct her not answer the basis the attorney-client privilege and the attorney work product doctrine.
But she can answer whether she recalls.
MS. COTCA: Okay. The question yes no. No, dont. Thank you.
During your practice and experience the director IPS and handling the FOIA program the State Department, was normal practice review FOIA processing with the White House liaison?
MR. PEZZI: Objection. Form. Foundation. no. wouldnt say that did.
(Walter Deposition Exhibit marked for
identification,
retained counsel.) (33 36) quickly, and just want make sure she had opportunity review it.
MS. COTCA: Actually, not. finished reviewing it. And looks from the context the e-mail that that what was. Thank you.
MS. COTCA: Can off the record for minute.
VIDEO SPECIALIST: are going off the record 14:30. recess was taken.)
VIDEO SPECIALIST: are back the record 14:32. MS. COTCA: Ms. Walter, going back your e-mail January 10, 2013. You wrote Ms. Samuelson, Did you ever get any intel regarding what other agencies are doing regarding this FOIA request that seeks records about the number e-mail accounts associated with the Secretary.
Then you wrote, but isnt specifying
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Sheryl Walter
Conducted June 14, 2019 personal e-mail, are interpreting official accounts only. you see that? Yes, do. Okay. This e-mail that you sent Ms. Samuelson January 10, 2013? Thats what the document appears say. Okay. Did you receive any intelligence what other agencies were doing about this FOIA request? dont recall anything other than whats this e-mail. you have independent recollection whats this e-mail are you saying -15 dont have any independent recollection. Okay. you know, you have any recollection why you were asking Ms. Samuelson what other agencies were doing regards FOIA request that was submitted the State Department?
MR. PEZZI: Objection. Form. use e-mail senior officials? you see that? do. Okay. And you agree that, youre referring this CREW request the topic personal use e-mail senior officials.
Right? No. Actually, disagree with your interpretation. Okay. What what would read this e-mail saying that there was call, and the question was whether had received that. not not did not independently characterize that.
(Walter Deposition Exhibit marked for identification, retained counsel.) Let show you whats been premarked Exhibit
And again, this another e-mail chain
which
you are included with respect the CREW request, subject line included Foundation. dont have any independent recollection that, why. Okay. want the e-mails that weve reviewed far, question is, why did you inform Ms. Samuelson that the State Department would interpreting the CREW FOIA request seek only official accounts Secretary Clinton, opposed personal e-mail accounts, when you and other State Department officials referred the request seeking personal e-mail the Secretary?
MR. PEZZI: Objection. Form. Foundation. That seems not exactly sure what youre asking. lets back Exhibit
And would the third page the exhibit, the bottom e-mail from you, December 20th, 2012, time stamped 12:38 p.m., where you said, White House called. Have received FOIA request from CREW the topic personal (37 40) the subject line WHNS Clintons e-mails. For the record, its Department State Bates-numbered 901. Its five-page document. this one the e-mails that you e-mail chains that you reviewed preparation your declaration? like finish reviewing it, please. Sure. Okay. Okay. can point you the e-mail Page the exhibit, from Edgar Jaramillo Patrick Scholl and Terry Gordon. believe Patrick Scholl you identified earlier. Right? Yes, did. Okay. See his e-mail there, FYI, tasked S/ES-CR and IRM with the attached request regarding S/Clintons private e-mails, which the White House also had interest knowing about from FOIA. you see that? Yes, do.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Sheryl Walter
Conducted June 14, 2019 And fair say that this e-mail the CREW request being termed seeking Secretary Clintons private e-mails?
MR. PEZZI: Objection. Foundation. What would only know that
looking
through the the rest the e-mail chain. wouldnt know that from just looking this e-mail. Okay. So, but you agree that looking the rest the e-mail chain, that the discussion with respect the CREW request that seeks e-mails from Secretary Clintons personal e-mails. Correct?
MR. PEZZI: Objection. Form. Foundation. That the characterization Mr. Jaramillos e-mail. Okay. And that was Mr. Scholl.
Correct? youre referring the March 27th, 2013, 5:33 e-mail, yes. Okay. And Mr. Scholl you said was the the FOIA program the State Department, would you consider individual would use their personal e-mail account for state-related business, would that considered official record?
MR. PEZZI: Objection. Form. thats hypothetical question that dont know the answer to. You didnt know the answer that when you were the State Department?
MR. PEZZI: Same objection. person used their private e-mail? that what youre asking? The ask the question is, that begs the question, your earlier answer, State Department official used their personal e-mail account for State Department business, would that not considered official record? would depend the facts the case. And cant speculate something hypothetical. Correct. And you had noticed that chief Programs and Policies Division.
What was what was Mr. Scholl was involved FOIA? supervised the FOIA process. Okay. question, going back earlier, the State Department officials are referring the CREW request seeking records relating Secretary Clintons personal e-mail, why did you inform Ms. Samuelson that the State Department would interpreting the CREW request seeking only official accounts -MR. PEZZI: Objection. e-mail accounts?
MR. PEZZI: Form. Foundation. would only speculation part. But general, the State Department can only search for official records. And any there was vague request that would interpret being for official records. Okay. All right. then let guess then that begs the question, FOIA, when you receive FOIA requests and being charge (41 44) State Department official used personal e-mail account for State Department business, being charge the FOIA division, program the State Department, werent you responsible identify and find out, personal e-mail account was being used for State Department business, make sure that the State Department had access those official records? No.
MR. PEZZI: Objection. Form. Foundation. Whose responsibility was the State Department ensure that the State Department identified all the sources that had official State Department records response FOIA, that was not you? The the FOIA office was responsible for tasking departments and offices and bureaus search for official records. Okay. But asking who was responsible ensure that all sources containing official State Department records were identifiable
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Sheryl Walter
Conducted June 14, 2019 order searched response FOIA.
MR. PEZZI: Same objections. think Ive answered that question already. was the individual bureaus offices and departments. Did you have notice 2012, during this entire time frame that you were communicating with Ms. Samuelson and other State Department officials from December 2012 through May 2013, that Secretary Clinton used personal e-mail account for State Department business? No.
MR. PEZZI: Objection. Form. Foundation. Who Karen Finnegan? Karen Finnegan was worked for me, and she was she was head our our litigation and appeals. For FOIA? For FOIA.
MS. COTCA: All right. think want take break. me. Okay. cant independently say that saw screen, but ... Okay. Did you know where Ms. Samuelson was going next? did not. Okay. you know today that she went the White House Counsels Office?
MR. PEZZI: Objection. Form.
Foundation. dont know where she went. You dont know that today, sitting here today? never knew, and dont know now. you know who Brock Johnson is? No, dont. you know why she asked that Brock Johnson will following the request her stead?
MR. PEZZI: Same objections. No, dont.
VIDEO SPECIALIST: are going off the
record 14:42. recess was taken.)
VIDEO SPECIALIST: are back the record 14:52. MS. COTCA: Okay. Ms. Walter, want you look again Exhibit
Did you know well, let me, the second page, the first full e-mail from Heather Samuelson March State Department officials, including you, and Brock Johnson. And appears that she informs you that she will leaving, that Friday her last day the State Department. you see that? March 4th 2:02 p.m.? Yes. Yes. Okay. this e-mail that you received back March 2013? assume so, since its sitting front (45 48) Thank you.
And what was the State Departments final response CREW response the request?
MR. PEZZI: Objection. Form. Foundation. dont know when was finally responded to. Okay. When but what was the final what was the response that the State Department made CREW with respect any records that were located result their FOIA request? -MR. PEZZI: Same objections. dont dont recall. are you aware that May the State Department responded CREW that had located records response?
MR. PEZZI: Same objections. not recall that. Okay. Again, look Exhibit please.
And the same e-mail from Edgar Jaramillo
PLANET DEPOS
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Transcript Sheryl Walter
Conducted June 14, 2019 Patrick Scholl and Terry Gordon from March 27, 2013, appearing Page the exhibit? you see that? The March 27, 2013, 5:33? Yes. And there where Mr. Jaramillo informs them that tasked S/ES-CR and IRM with the attached request. This referencing the CREW request, regarding Clintons private e-mails. you see that? Yes, do. Okay. And whos whats S/ES-CR? not know. dont know exactly what S/ES-CR is. Okay. you know what IRM is? IRM believe was bureau that dealt with classified information. But cant tell you that for sure. Thats just speculation. Okay. you see where reports that both bureaus reported zero relevant docs found, and have draft and will draft Oglesby letter the requester? speak. this could have been part rolling response and not the final response. just dont know. Okay. But this response was that there were records located. Correct? For those two searches. Correct.
MR. PEZZI: Objection. Foundation. Okay. far can tell. just but dont know for sure. Okay. During the time frame all this e-mail traffic relating the CREW request, and from December 20th until Ms. Samuelson advised that she was leaving the State Department March 2013, did Heather Samuelson inform you that Secretary Secretary Clintons e-mail address that she used while the State Department?
MR. PEZZI: Objection. Form.
Foundation. No. Yes. Sheryls e-mail attached. you see that? Yes. Okay. What Oglesby letter? Oglesby? Yes. Oglesby letter would letter saying there were documents responsive request. Okay. And this was reference the CREW request? Yes.
MR. PEZZI: Objection. Foundation. Although would say there are often times FOIA requests are responded multiple times. this would may one response the course multiple responses request. Can you explain that? dont understand what you mean that. Sure. Sure. can happen FOIA request that there are rolling responses, (49 52) Okay. Again during this time frame
all
this e-mail traffic that you had with Ms. Samuelson about the CREW request, did you ask Ms. Samuelson whether Secretary Clinton used any e-mail for State Department business?
MR. PEZZI: Same objections. dont recall. Wouldnt that have been logical question logical next step take determine how respond CREWs FOIA request?
MR. PEZZI: Objection. Form. thats question cant answer. dont know. Did you any point and again during this time period, approach the Secretarys office while Secretary Clinton was still office determine Secretary Clinton used e-mail for State Department business, the State Department could respond CREW?
MR. PEZZI: Objection. Form. Foundation. youre asking did ever approach
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Transcript Sheryl Walter
Conducted June 14, 2019 (53 56) the Secretarys office, no. When you started the State Department November, December 2011 you started the director IPS. Correct? When started with Yes. the State Department? Yes. Yes. Okay. What, anything, were you informed with respect whether Secretary Clinton used e-mail for State Department business? dont recall being informed anything. Was there time where the question whether Secretary Clinton used e-mail was raised you? Not that recall. Well, the CREW request raised that issue, did not?
MR. PEZZI: Objection. Form.
Foundation. The CREW request speaks for itself. interpreting the CREW request requesting for official accounts only.
You stated that you see where you tell her that youre considering contacting the requester find out exactly what theyre looking for? see that line. you see that? Okay.
Did you anybody else that youre aware contact Anne Weismann anybody CREW understand what exactly was they were looking for?
MR. PEZZI: Objection. Form. Foundation. dont recall. you know Ms. Samuelson had any concerns about the approach you took with respect how you would interpret the CREW FOIA request -MR. PEZZI: Same objections. -22 following your question her your Well, asks for e-mail accounts that
Secretary
Clinton used the State Department, did not?
MR. PEZZI: Same objections. can can ask for whatever requests. doesnt mean they existed. No. But raised the issue whether Secretary Clinton used e-mail the State Department, did not?
MR. PEZZI: Same objections. asked requested e-mails that Secretary Clinton may have had. Okay. cant speak for what CREW was requesting. Okay. Actually sorry. you could look Exhibit
And this your January 10, 2013, e-mail Ms. Samuelson about the CREW FOIA request. Uh-huh. And this where youre informing Ms. Samuelson that the State Department will e-mail? dont know she did did not. Were you aware that Cheryl Mills was also informed the the CREW FOIA request?
MR. PEZZI: Objection. Form. Foundation. have information about that. dont know. question is, were you aware, back December 2012, that Ms. Cheryl Mills would -11 was also made aware the CREW FOIA request? -MR. PEZZI: Same objections. dont have any recollection that. Okay. you dont recall either way, whether you knew whether you didnt know?
MR. PEZZI: Same objections. dont know. Okay. During your experience the director IPS and charge the FOIA program from November 2011 until Secretary Clinton left February February 2013, did you engage
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Transcript Sheryl Walter
Conducted June 14, 2019 communicate with Ms. with Ms. Mills about any other FOIA requests that had come relating Secretary Clintons e-mail?
MR. PEZZI: Objection. Form. never had any contact with Ms. Mills. want move past the May time frame when State Department responded CREW.
Who Mr. Hackett, John Hackett? was deputy. Okay. And when did come board? actually dont remember exactly when came board. Okay. Are you familiar with his testimony that gave this case? No. Okay. Was there time 2013 around June 2013 that Mr. Hackett raised the issue Secretary Clintons e-mail you?
MR. PEZZI: Objection. Form. Its possible, but dont remember it. just want show you whats been marked Exhibit Clarence Finneys (57 60)
MR. PEZZI: Objection. Form. could have, but dont specifically remember. you have any general recollection about it? Recollection about about what particular? Well, your answer that you dont specifically remember. question is, you have any general remembrance it? And what was your question again? With respect whether Mr. Hackett had raised any concerns you upon seeing this photograph with Secretary Clinton holding this electronic device.
MR. PEZZI: Objection. Form. certainly could have. could have discussed it. Whether raised concerns, cant say. Why cant you say? Because dont know, remember the content our conversation. deposition.
MS. COTCA: And not marking here, but just showing the witness.
(Finney Exhibit previously marked, retained counsel.) Its two articles from June 10,
2013.
And they apparently, according the articles, apparently Secretary Clinton joined Twitter that day. And the photograph there the one she chose post Twitter. you recognize that photograph? Have
you
ever
seen this photograph before? have seen that photograph before. Okay. And just for the record, thats photograph Secretary Clinton with the sunglasses eyeglasses and holding BlackBerry. that right? Holding device that looks like BlackBerry. dont know for sure. Okay. you recall Mr. Hackett raised any concerns when that photograph appeared around June 2013? you remember any discussions you had
with
Mr. Hackett around the time frame June 2013 the summer 2013 with respect e-mail that Secretary Clinton may may not have used the State Department?
MR. PEZZI: Objection. Form. dont remember any particular conversations. you recall all that issue being raised during that time frame?
MR. PEZZI: Objection. Form. The issue when you say that issue, what you mean that issue? Again, were talking about this photograph and whether Secretary Clinton used any e-mail the time when she was the State Department.
MR. PEZZI: Objection. Form. have tell you dont remember any specific conversations. not asking you remember specific conversations. asking you you recall that
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Transcript Sheryl Walter
Conducted June 14, 2019 issue being raised. And that issue, mean the issue whether Secretary Clinton used e-mail while she was the State Department.
MR. PEZZI: Same objection. Well, certainly theres picture that
the
Secretary appearing hold device. could have been someone elses device. dont know.
There was speculation what device that might have been. But other than that ... okay. When you say there was speculation what device that might have been, whats the time frame and what are you referring when you say that? dont recall the time frame. Okay. would have have been after this picture, clearly. Okay. And what you recall about the speculation that you referred to? dont remember details about the speculation, just that she was holding device whether Secretary Clinton used e-mail account while she was the State Department?
MR. PEZZI: Objection. Form. that his his testimony, then thats his testimony. Does that surprise you, that recalls these conversations with you, and you have memory it?
MR. PEZZI: Same objection. cant say that surprised not surprised, thats what his recollection is. telling you that dont remember the content those those conversations.
But Ive told you that there was generally speculation about what the Secretary may may not have been using. Okay. And question, followup question that is, what steps did you take did your office take being responsible for the FOIA program, for the entire FOIA program the State Department, determine whether those speculations were true not? that might might not have been BlackBerry. Okay. And when that speculation arose and when you became aware that, was there anything you did result understand whether and find the truth whether Secretary Clinton used e-mail while she was the State Department?
MR. PEZZI: Objection. Form. All can back what weve discussed before, which how searched for -11 for documents the State Department, which task the Secretarys office and other offices for documents. And that how would know about what kind documents might have been generated the Secretary anyone else. Are you surprised were tell that you Mr. Hackett testified this case that was very concerned when that was concerned when saw that photograph, and that raised that issue with you and actually raised the issue that no-responsive-record responses should sent FOIA requestors until your office determines (61 64)
MR. PEZZI: Objection. Form.
Foundation. Ive told you before, the way that determine determine what documents may responsive task the the various offices and departments. your testimony that you took steps result?
MR. PEZZI: Objection. Form. not telling you didnt took that took steps, just that that the way that the that IPS worked. understand. But thats not actually responding question.
What the process for IPS was does not answer question what steps you took determine whether those speculations were true not.
MR. PEZZI: Objection. Form. can only tell you that what did was the context what our responsibilities were IPS.
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Transcript Sheryl Walter
Conducted June 14, 2019
(Walter Deposition Exhibit marked for identification, retained counsel.) Ill show you whats been premarked Exhibit
MS. COTCA: For the record,
document
number Bates Stamp 902. Its five-page document, and was produced the State Department Judicial Watch discovery this case.
MR. PEZZI: Sorry. This Exhibit
MS. COTCA: Exhibit Ms. Walter, let know once youve had chance -14 Bates-stamped 902 the bottom? Yes, 902. not going ask you about every single e-mail this e-mail chain. Ill point you just few. Okay. All right. Can point you to, its going the third page the document. e-mail from you, dated August 2013, time supervised the analysts that actually processed the FOIA requests. Okay. Some them, not all them. The ones that were under his supervision. Okay. Were there several? Yes. Okay. How many? Not enough, that was for sure. dont cant really recall.
Okay. And just want raise your attention to, Can you get copy all requests related Secretary Clintons e-mails. Uh-huh. you recall why did you ask for copy all requests related Secretary Clintons e-mails?
And request, did you mean FOIA requests, assume? FOIA requests. Okay. Because the previous e-mail that stamped 10:51, Karen Finnegan, Patrick Scholl, John Hackett, Marianne Manheim, and Geoffrey Hermesman. you see that? Yes. Okay. you see your e-mail well,
this e-mail that you sent these State Department officials back August 2013? Well, appears be. Okay. And again, the subject actually IPS Significant FOIA Report. you see where you write Jeff, Can you get copy all requests related Secretary Clintons e-mails? you see that? Yes. All right. Who Jeff? was one the supervisory analysts who worked for Pat Scholl. And what what was his responsibilities, and what did day-to-day basis? (65 68) chain, Margaret Grafeld had asked for copies requests related Secretary Clintons e-mails. Okay. And who Margaret Grafeld? She was the Deputy Assistant Secretary for Global Information Services. she was direct supervisor. Okay. you know why Ms. Grafeld requested from and John, that John Hackett? yes, assume so. Okay. Why Ms. Grafeld requested Mr. Hackett provide her with copies all FOIA requests related Secretary Clintons e-mails?
MR. PEZZI: Objection. Form. Foundation. dont know why she she was interested, but she was interested, clearly, other she wouldnt have asked for them. Okay. Mr. Hackett was working under you.
Right? Yes. that time?
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Transcript Sheryl Walter
Conducted June 14, 2019 reported you? Yes. Okay. did anything with respect what Ms. Grafeld would request, you would also kept abreast? Yes. Okay. you know why August 2013 the IPS office and why Ms. Grafelds office was raising issue with FOIA requests relating Secretary Clintons e-mails? No, dont. Did you that point take any steps determine Secretary Clinton had used e-mail -MR. PEZZI: Objection. for State Department business?
MR. PEZZI: Objection. Form. again, Ive described, the way that search for documents task the the offices. And would have been tasking the Secretarys office. But that Deputy Assistant Secretary, she would generally interested e-mails that would relate principal the State Department. That would not issue. But cant recall any specific instance. let ask you this: Secretary Clinton did not use e-mail, and thats what the State Department believed, your office believed August 2013, why would requests for her e-mails issue?
MR. PEZZI: Objection. Form. Foundation. What you mean issue? Why would concern? Because -MR. PEZZI: Same objections. dont question why people ask for whatever they ask for. receive FOIA requests, and respond them. Right. But isnt your obligation the director IPS ensure that your responses FOIA requests are complete and accurate? did not independent investigation. Okay. you didnt independent investigation. But, obviously, there was concern within your office about FOIA requests relating Secretary Clintons e-mails. that fair say?
MR. PEZZI: Objection. Form. Foundation. cant agree with the characterization. can just say whats here, which that Margaret Grafeld asked, based conversation with John Hackett assume its John Hackett about Secretary Clintons e-mails. Was there another time when Ms. Grafeld had requested all FOIA requests relating senior-level associate official the State Department their e-mail use?
MR. PEZZI: Objection. Form. Foundation. that particular the your particular question, cant recall. can clarify one thing, though. Which (69 72)
MR. PEZZI: Objection. Form.
Foundation. Our our our responsibility was produce official records that were identified the bureaus, offices, and various places that tasked. Right. But wasnt heading the FOIA program the State Department, wasnt part your responsibility ensure that when the agency, the State Department, respond responded requestor, that that was complete response? Our our responsibility -MR. PEZZI: Objection. Form. our responsibility adequate search. And doesnt adequate search mean complete search for all potentially responsive records?
MR. PEZZI: Objection. Form. Foundation. And responsive records would the ones that have been produced the bureaus, offices,
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Transcript Sheryl Walter
Conducted June 14, 2019 whatever, wherever had tasked them. Can point you the second page this exhibit, Ms. Finnegans e-mail you and others, dated August 2013.
And shes addressing this you. She
says,
Sheryl: follow early response, Cristina handling the Judicial Watch case and its Case Number 2013-772, front pending front Judge Kollar-Kotelly -10 which still pending, actually that seeks access all communications, including e-mail, between the department and President Clinton and/or his foundation regarding clearing his speeches. dont believe that this case necessarily includes Secretary Clintons e-mails. you see that? do. Why did she why was why does she comment whether the FOIA request necessarily included Secretary Clintons e-mails August 2013?
MR. PEZZI: Objection. Form. record 15:30. MS. COTCA: Ms. Walter, you recall around June 2013 the summer 2013, whether there was directive from your office from IPS the FOIA branch not send any further no-records response FOIAs that related Secretary Clintons e-mails? dont remember that, no. you know whether the State Department continued send any no-records responses FOIA requests relating Secretary Clintons e-mails after June 2013 until the time that you left the State Department? No, dont know that. All right. With Ms. Walter, based on, you know, the speculations that you said were raised and all the discussions that were reflected that are reflected all these e-mails contained the exhibits that youve been shown, did you that point any point during this time frame ask whether Secretary Foundation. Beyond the scope. cant tell you exactly why. could speculate that the context this e-mail chain, that was one the issues that was being discussed. she volunteered that information. But dont otherwise know why she would raise that. Well, wouldnt she okay. And she she reported directly you? Yes, she did. Okay.
All right. Moving forward late 2013, early 2014.
MS. COTCA: you need break, Ms. Walter?
THE WITNESS: think would like
break,
actually.
MS. COTCA: Why dont take break.
VIDEO SPECIALIST: are going off the record 15:20. recess was taken.)
VIDEO SPECIALIST: are back the (73 76) Clinton used e-mail while she was the State Department?
MR. PEZZI: Objection. Form. Asked who? Anybody.
MR. PEZZI: Same objection. dont recall that.
(Walter Deposition Exhibit marked for identification, retained counsel.) showing you whats been premarked Exhibit Okay. Okay. Thank you.
MS. COTCA: For the record, this Bates-stamped DOS Document 3631 produced the State Department plaintiff discovery this case. This e-mails you, between you and Ms. Tasha Thian, about departing senior senior department officials departing from the State Department January 2013. you see want point you the
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Transcript Sheryl Walter
Conducted June 14, 2019 e-mail from Ms. Thian you January 11. And she wrote you, Ms. Mills wants know the review procedures for personal papers. you see that? Yes. What was the review process for personal papers? Tasha Thian was the person who was charge that. dont know the details. Okay. Then the first e-mail the exhibit, from you, dated January 11, 2013, its the top Page where -13 youre saying the first. Meaning -14 The last -15 top. the e-mail chain. The last the chain? Correct. Thank you. Yes.
Where says, Tasha will let Clarence know she unable attend and also let her know that Cheryl and Jennifer already have been briefed you and have guidance booklet. would guidance records retention when when leaving department. But that would from taking this from the context this e-mail. Okay. appreciate that. Thank you.
(Walter Deposition Exhibit marked for identification, retained counsel.) you would look whats been premarked Exhibit
And just really only have questions with respect the e-mail from Ms. Grafeld you and Ms. Tasha Thian, from December January 27, 2013. With the subject, Departing Officials. Which actually the first e-mail the e-mail chain. all the way the bottom. You mean the reverse. Right? Yes. Thank you.
And specifically the paragraph where says, According todays DN, the Secretarys departing February This also means that her senior noncareer staff, particularly Cheryl Mills, whose records would want, will also leaving: that are you referring Cheryl
Cheryl
Mills? the context this? Yes. would assume yes. And who Jennifer who youre referring
that e-mail? dont know. There Jennifer the bottom the e-mail, might her. But dont know for that for sure. Who the Jennifer thats referenced the bottom the e-mail? dont know who she is. Okay. And the you, are you referring Ms. Grafeld? Yes. Okay. And then you state that had the guidance booklet.
Whats the guidance booklet youre referring there? would dont know for sure, but would assume the context this document that (77 80) While have spoken with Sheryl months ago about the Secretarys records, Clarence has the first line responsibility for ensuring that they all, including the counselor all her roles, adhere the laws and regs. trust you are working closely with him. you see that? Yes, do. Okay. Did you receive this e-mail back January 2013? Well, the context the copy this e-mail, would assume so. Okay. couple questions here. The Clarence thats referenced here, that Clarence Finney? dont know for sure, but probably is. Okay. And who Mr. Finney the time? what was his position the time, you recall? know that remember that there was Clarence who worked the Secretarys
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Transcript Sheryl Walter
Conducted June 14, 2019 (81 84) office related records. Okay. dont remember what his last name was. Sure. Okay. And the comment about, including the counselor all her roles, that reference Cheryl Mills?
MR. PEZZI: Objection. Form. can only tell you the context this sentence, that would appear so. Okay. And what were all Ms. Mills roles the State Department? What was the concern here about that? have -MR. PEZZI: Objection. Form. Foundation. have idea. you know why Ms. Grafeld wrote you and Ms. Tasha Thian that she trusts you are working closely with Clarence, and also ensure that your contacts and have done their jobs, including our ability capture e-mail our special archive system? departing officials? Yes. Okay. And what the the reference to, our special archive system?
What does that refer to?
Where that? Its the last sentence the e-mail. Well, actually, just this page, not the entire e-mail. this same paragraph that were looking at. dont know the answer that. Was there archive system special archive system that State Department used? dont know what shes referring to. Okay. What the first page the exhibit, draft notice Ms. Thians e-mail January 29? Whats draft notice? can only speculate. Its probably departmental.
(Walter Deposition Exhibit marked for
identification,
retained counsel.) Let show you whats been marked
MR. PEZZI: Objection. Form.
Foundation. dont find anything remarkable that. Okay. Was there any concern from that Ms. Grafeld had with respect making sure that all the Secretarys records were retained and captured the State Department prior her leaving?
MR. PEZZI: Same objections. would say that were all concerned about that. Okay. Did you work with Mr. Finney -14 closely with Mr. Finney, prior Secretarys departure? did not work with Mr. Finney. Okay. Tasha Thian would have done that. Okay. Did Tasha Thian report you? Yes, she did. Okay. And would she keep you abreast what she was doing with respect the Exhibit that notice? dont know. Its notice, but dont know was notice. Was there specific type notice that departing officials received the State Department prior their departure?
MR. PEZZI: Objection. Form. Foundation. particular notice? Yeah. With respect their responsibilities and obligations make sure that all their State Department records remain the State Department. dont know that there was any -MR. PEZZI: Same objections. particular notice. Was there anything that departing -19 departing State Department officials had sign -MR. PEZZI: Same -21 certifying that they left with the
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Transcript Sheryl Walter
Conducted June 14, 2019 State Department all their State Department records prior departing?
MR. PEZZI: Same objections. dont recall anything Okay. like that.
(Walter Deposition Exhibit marked for identification, retained counsel.) Let show you whats been premarked Exhibit 10. Its booklet called titled Government Records Briefing Booklet For Federal Officials. And has your name Page the document.
MS. COTCA: And, for the record, document Bates-numbered 2968, going 2996, Bates stamped. And again, was produced the State Department discovery this case. you recognize this document? tell you the truth, not. Did your office create this document?
MR. PEZZI: Objection. Form. Foundation. Foundation. Well, just reading from the front page, says Briefing Booklet For Federal Officials Regarding Government Records. Okay. And who was provided copy this this booklet?
MR. PEZZI: Same objections. would expect officials the State Department. does that mean all all State Department officials? dont -MR. PEZZI: Same objections. dont know exactly whom was provided. Would have been provided the Secretarys office?
MR. PEZZI: Same objections. would assume so, but not know that for sure. Okay. Well, your role the director IPS would you have the expectation that the Well, has the stamp the front that says the Bureau Administration. Was that your office, Office Information Programs IPS IPS was part the Bureau Administration. Right. And the title, the first page says Bureau Administration, Office Information Programs and Services. you see that? do. Okay. Was that your office? That was office. Okay. That you were the director March 2012. Correct? Yes. Okay. you know your office created this document? would appear that did. Okay. you know for what purpose this document was created?
MR. PEZZI: Objection. Form. (85 88) Secretarys office would provided with booklet that your office created for federal officials with respect government records?
MR. PEZZI: Objection. Form. Foundation. would expectation that all State Department officials would have such have access such. Okay. want refer you Page the booklet. And its titled Are E-mail Messages Records.
And the second bullet point says -12 well, the top says, E-mail Messages. And then want point you the second bullet point, where says, Must printed out paper form and filed with the appropriate paper files they fall within the definition record and are not archived SMART approved system. you see that? Yes, do. Okay. Was that the policy the State
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Transcript Sheryl Walter
Conducted June 14, 2019 Department March 2012?
MR. PEZZI: Objection. Form. Foundation. Its contained document that was published the State Department. cant imagine that would not be. Okay. want point you Page 11. the top the page says, What are other What are the responsibilities the federal official under the information access laws?
And then goes discuss the Freedom Information Act, and also Privacy Act. you see that? Yes. Okay. Was this provided for purposes that State Department officials would know what their responsibilities are under the Freedom Information Act?
MR. PEZZI: Objection. Form.
Foundation. Thats the title the the top (89 92) federal officials follow the law. Okay. Did your office you know what precipitated your office create this document?
MR. PEZZI: Objection. Form. Foundation. said, dont recall this document. But this appears something that would regularly provided federal officials the State Department. Okay. And are this document -12 when when you say regularly provided State Department officials, what you mean that? mean that part informing officials what their responsibilities are, this would something given officials the course their business. Okay. And would you expect that Secretary Clintons office would have been provided with something similar when they started the State Department 2009?
MR. PEZZI: Objection. Form. the page, would expect that this was about informing the responsibilities federal officials under the information laws. Why was that important do? Its always important know what your responsibilities are. Why?
MR. PEZZI: Objection. Form. Why important? Uh-huh. know why what laws you should respond to? Uh-huh. Because thats your thats your responsibility. was the expectation that the State Department and the Secretarys office should abide under the laws the Freedom Information Act and the Privacy Act this document? -MR. PEZZI: Objection. Form. expectation that that Foundation. dont have any independent knowledge. wasnt there 2009. But your expectation that the Secretarys office would have been informed the info type information thats included Exhibit the time that the Secretary started her tenure the State Department?
MR. PEZZI: Objection. Form. Foundation. cant speak cant speak what happened when the Secretary started.
MS. COTCA: Can off the record.
VIDEO SPECIALIST: are going off the record 15:46. recess was taken.)
VIDEO SPECIALIST: are back the record 16:07. MS. COTCA: Ms. Walter, you recall FOIA request that the State Department received from Gawker for e-mails between Secretary Clinton and Sidney
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Transcript Sheryl Walter
Conducted June 14, 2019 Blumenthal 2013? No, dont. you have any recollection were you aware any e-mail that was located response the search done upon receiving that request that identified Secretary Clintons e-mail the record hrc22@clintonemail.com?
MR. PEZZI: Objection. Form. Foundation. Are you talking about response the the FOIA request you just mentioned? not not saying response that was sent out. But result -14 But your -15 search done response Gawkers FOIA request? Thats what was asking you. Yes. No. you have any recollection with respect whether Mr. John Hackett raised Secretary Clintons e-mail account relation the Gawker havent
MR. PEZZI: Same objections. never recall seeing reference that e-mail address. the director IPS charge FOIA, wasnt your responsibility raise the speculations that you testified earlier about Secretary Clintons e-mails the appropriate office responsible for managing State Department records?
MR. PEZZI: Objection. Form. responsibility was implement the Freedom Information Act the ways that -14 Ive described already. Okay. are you your testimony that you that your role the director IPS, you did not have any responsibility address those speculations with the appropriate departments the State Department responsible for managing State Department records? that your testimony?
MR. PEZZI: Objection. Form. request -MR. PEZZI: Same objections. sometime November 2013 and/or January 2014?
MR. PEZZI: Same objections. No. No, dont. Okay. During your time the State Department did anybody ever tell you that Secretary Clinton used e-mail for State Department business?
MR. PEZZI: Same objections. dont recall any discussions about that, no. When was the first time that you saw any reference Secretary Clintons e-mail address hdr22@clintonemail.com?
MR. PEZZI: Objection. Form. dont know that that her e-mail address. Well, when was when the first time that you ever saw reference that e-mail address? (93 96) testimony that performed responsibilities the way understood them assigned me. Okay. Again, thats not question. question your testimony that your responsibility did not obligate you raise those speculations the appropriate offices within the State Department that was responsible for managing State Department records.
MR. PEZZI: Objection. Form. Asked and answered several times now. And would ask that you keep your questions factual matters within the witness knowledge.
MS. COTCA: Well, its about her responsibilities and what she was obligated the director IPS. And the problem that the witness still hasnt answered question.
MR. PEZZI: dont agree with that.
MS. COTCA: Okay.
MR. PEZZI: You can ask your question. objected for the record. dont agree with the premise
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Transcript Sheryl Walter
Conducted June 14, 2019 your question. Whats the premise that you disagree with? That youre trying characterize what responsibilities were not. And Ive described you what responsibilities were. Right. just asking, are your testimony that you were not responsible the director IPS make aware the appropriate office responsible for managing records the State Department when you were made aware the speculations about Secretary Clintons e-mail account?
MR. PEZZI: Objection. Form. think have think Ive answered that question already. your testimony that during your tenure the State Department, you not recall ever dealing with the issue surrounding Secretary Clintons e-mail, other than the speculations that you testified earlier today?
MR. PEZZI: Objection. Form. Clintons e-mail outside the speculations that you testified today? Not outside
MR. PEZZI: Objection form. what weve talked about.
MS. COTCA: Off the record.
VIDEO SPECIALIST: are going off the record 16:12. recess was taken.)
VIDEO SPECIALIST: are back the
record 16:14. MS. COTCA: Ms. Walter, when the news came out March 2015 that Secretary Clinton had used personal e-mail for State Department business, did that surprise you?
MR. PEZZI: Objection. Form. think wasnt something had known before.
MS. COTCA: Thats it.
MR. PEZZI: questions questions from the government. Well, dont really understand your question. Because weve been talking about the fact that did deal with the e-mail, requests for e-mails. Okay. Correct. But thought your testimony that you dont recall that request for e-mails with respect dont recall those specific requests Okay. but looking the e-mails the e-mail exhibits youve shown me, clearly did. Well, did that refresh your recollection the request? Not the not the details it; just the fact of. Okay. outside, independent trying understand what your testimony here today.
Independent the documents that youve been shown, your testimony that you have recollection, sitting here today, about ever dealing with the issue surrounding Secretary (97 100)
100
VIDEO SPECIALIST: there are
further
questions then this ends the deposition, and are going off the record 16:15.
COURT REPORTER: Mr. Pezzi, same order?
MR. PEZZI: Yes, please.
(Off the record 4:15 p.m.)
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Sheryl Walter
Conducted June 14, 2019
101
ACKNOWLEDGMENT DEPONENT SHERYL WALTER, hereby acknowledge
that have read and examined the foregoing
testimony, and the same true, correct and
complete transcription the testimony given
me, and any corrections appear the attached
Errata sheet signed me.
_______________________ ________________________
(DATE)
(SIGNATURE)
102
CERTIFICATE SHORTHAND REPORTER NOTARY PUBLIC Debra Ann Whitehead, the officer before whom
the foregoing deposition was taken, hereby
certify that the foregoing transcript true and
correct record the testimony given; that said
testimony was taken stenographically and
thereafter reduced typewriting 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. WITNESS WHEREOF, have hereunto set hand and
affixed notarial seal this 16th day June,
2019. commission expires:
September 14, 2023
_;:;;..,.
...... ..:....;.,
----------------------------NOTARY PUBLIC AND FOR THE
DISTRICT COLUMBIA
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM (101 104)
Transcript Sheryl Walter
Conducted June 14, 2019
abide
90:17
ability
81:21
able
23:19
about
17:5, 19:12,
19:17, 21:8,
21:12, 21:22,
25:20, 26:11,
29:10, 31:10,
33:3, 35:6,
36:20, 37:9,
40:19, 52:3,
54:19, 55:17,
56:7, 57:1,
59:5, 59:6,
60:14, 61:19,
61:21, 62:13,
63:15, 65:16,
70:4, 70:13,
76:19, 80:1,
81:4, 81:12,
82:12, 90:1,
93:10, 94:12,
95:7, 96:14,
97:12, 98:2,
98:21, 99:5
abreast
69:5, 82:21
absolutely
32:12
access
44:7, 73:11,
88:8, 89:10
according
58:7, 79:19
account
43:3, 43:17,
44:2, 44:5,
45:10, 63:1,
93:22, 97:13
accounts
36:21, 37:2,
38:8, 38:10,
42:11, 42:13,
54:1, 55:2
accurate
26:15, 71:22
acknowledge
101:2
acknowledgment
101:1
act
89:13, 89:19,
90:19, 95:13
action
1:6
actually
26:12, 27:1,
29:17, 30:7,
30:8, 35:8,
36:3, 39:8,
54:16, 57:11,
62:20, 64:13,
66:10, 67:2,
73:10, 74:17,
79:13, 83:8
add
28:21, 29:15,
30:1, 30:4
added
29:2, 30:9,
30:20
address
51:18, 94:15,
94:19, 94:22,
95:4, 95:17
addressing
73:5
adequate
72:15, 72:16
adhere
80:4
administration
6:17, 13:11,
86:2, 86:6, 86:8
advised
51:15
advisor
25:7
affixed
102:13
after
30:5, 61:17,
75:13
afternoon
9:21
again
16:6, 22:5,
26:9, 32:10,
35:5, 35:7,
39:20, 46:8,
48:21, 52:1,
52:14, 59:11,
60:14, 66:10,
69:18, 85:16,
96:4
agencies
27:8, 27:9,
36:19, 37:9,
37:19
agency
72:10
ago
80:1
agree
30:8, 39:4,
41:9, 70:9,
96:18, 96:22
all
11:2, 12:12,
18:5, 19:11,
28:3, 31:3,
42:20, 44:14,
44:21, 45:21,
51:13, 52:2,
60:9, 62:9,
65:20, 66:13,
66:17, 67:4,
67:12, 67:16,
68:12, 70:15,
72:17, 73:11,
74:12, 75:16,
75:18, 75:19,
79:14, 80:3,
80:4, 81:5,
81:10, 82:7,
82:11, 84:13,
85:1, 87:10,
88:6
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
already
31:2, 45:4,
77:21, 95:14,
97:16
also
4:18, 17:12,
22:5, 23:11,
32:10, 35:3,
40:19, 56:3,
56:11, 69:4,
77:20, 79:20,
79:22, 81:19,
89:13
although
50:15
always
31:3, 90:5
analyst
14:16, 16:2
analysts
15:17, 66:18,
67:1
ann
102:2
anne
55:10
another
39:20, 70:14
answer
33:17, 34:4,
34:7, 43:8,
43:9, 43:15,
52:12, 59:8,
64:16, 83:11
answered
45:3, 96:11,
96:17, 97:15
any
11:3, 14:9,
14:20, 15:4,
20:19, 21:8,
21:10, 21:21,
22:2, 23:17,
26:3, 36:18,
37:8, 37:15,
37:17, 38:2,
42:17, 48:10,
52:4, 52:14,
Transcript Sheryl Walter
Conducted June 14, 2019
55:16, 56:14,
57:2, 57:5,
58:21, 59:4,
59:10, 59:13,
60:1, 60:7,
60:15, 60:19,
69:12, 71:5,
75:6, 75:11,
75:21, 82:5,
84:15, 92:2,
93:3, 93:4,
93:20, 94:12,
94:14, 95:17,
101:6, 102:10
anybody
19:16, 19:21,
55:9, 55:10,
76:5, 94:8
anyone
21:17, 21:18,
62:15
anything
37:11, 53:10,
53:13, 62:4,
69:3, 82:3,
84:18, 85:4
apparently
19:19, 27:7,
58:7, 58:8
appeals
45:18
appear
31:20, 32:6,
81:9, 86:19,
101:6
appeared
58:21
appearing
18:17, 28:18,
49:2, 61:6
appears
12:15, 18:4,
18:7, 26:12,
27:2, 37:7,
46:13, 66:9,
91:8
appreciate
10:13, 79:4
approach
33:13, 33:15,
33:21, 52:15,
52:22, 55:17
appropriate
88:16, 95:8,
95:18, 96:7,
97:9
approved
2:12, 88:19
archive
81:22, 83:4,
83:12, 83:13
archived
88:18
archives
13:11
arose
62:2
around
33:6, 33:7,
57:16, 58:22,
60:2, 75:3
article
7:4
articles
58:6, 58:8
ask
11:7, 17:4,
23:16, 26:1,
27:15, 29:1,
29:10, 29:22,
35:22, 43:14,
52:3, 54:5,
65:16, 67:15,
71:6, 71:17,
71:18, 75:22,
96:11, 96:20
asked
15:21, 30:20,
31:2, 47:18,
54:11, 68:1,
68:18, 70:11,
76:4, 96:10
asking
21:20, 37:18,
38:16, 43:13,
44:20, 52:22,
60:21, 60:22,
93:17, 97:7
asks
54:1
assigned
96:3
assistant
68:4, 71:1
associate
70:16
associated
36:21
assume
11:10, 46:22,
67:19, 68:10,
70:12, 78:5,
78:22, 80:12,
87:19
attached
23:9, 40:17,
49:7, 50:2,
101:6
attend
77:20
attention
67:12
attorney
10:22, 34:6
attorney-client
34:5
attorneys
33:12, 33:22,
34:4
august
65:22, 66:8,
69:7, 71:9,
73:4, 73:20
avenue
2:5, 4:6, 8:13
aware
21:10, 21:17,
48:16, 55:9,
56:3, 56:9,
56:11, 62:3,
93:4, 97:9,
97:11
back
19:2, 20:16,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
20:17, 32:13,
36:13, 36:16,
38:17, 42:5,
46:4, 46:21,
56:9, 62:9,
66:8, 74:22,
80:9, 92:17,
99:10
based
10:8, 70:11,
75:16
basis
34:5, 66:22
bates
5:17, 5:20,
6:3, 6:6, 6:8,
65:6, 85:15
bates-numbered
40:3, 85:15
bates-stamped
18:9, 65:14,
76:15
became
62:3
because
24:2, 27:13,
35:22, 59:21,
67:22, 71:15,
90:14, 98:2
been
9:18, 10:15,
12:9, 12:10,
16:8, 17:9,
19:22, 20:6,
20:7, 26:7,
35:2, 39:18,
51:2, 52:8,
57:21, 61:7,
61:10, 61:13,
61:17, 62:1,
62:14, 63:16,
65:3, 69:20,
72:22, 75:20,
76:10, 77:21,
79:7, 83:22,
85:9, 87:16,
91:19, 92:5,
98:2, 98:20
Transcript Sheryl Walter
Conducted June 14, 2019
before
2:11, 9:21,
10:4, 10:16,
58:12, 58:13,
62:10, 64:3,
99:19, 102:2
begin
9:22, 12:2
begins
8:2, 33:7
begs
42:21, 43:14
behalf
3:2, 3:11, 4:2,
4:10, 8:22, 9:1,
9:7
being
29:10, 31:9,
41:2, 42:19,
42:22, 44:2,
44:5, 53:13,
60:9, 61:1,
63:19, 74:4
believe
24:10, 40:13,
49:16, 73:14
believed
71:8
best
24:22
between
26:10, 35:4,
73:12, 76:18,
92:22
beyond
74:1
bit
35:22
blackberry
58:16, 58:19,
62:1
blumenthal
93:1
board
57:10, 57:12
body
35:17
booklet
6:16, 77:22,
78:18, 78:19,
85:10, 85:11,
87:3, 87:6,
88:2, 88:10
both
28:4, 49:20
bottom
38:19, 65:14,
78:9, 78:12,
79:15
branch
3:14, 75:6
break
11:3, 11:4,
45:22, 74:14,
74:17, 74:18
briefed
77:21
briefing
6:15, 85:11,
87:3
broader
23:18
brock
46:12, 47:16,
47:18
bullet
88:12, 88:14
bureau
6:17, 15:18,
49:16, 86:2,
86:5, 86:8
bureaus
45:4
bureaus
44:18, 49:20,
72:5, 72:22
burke
3:4, 8:19
business
43:4, 43:17,
44:2, 44:6,
45:11, 52:5,
52:18, 53:12,
69:16, 91:17,
94:10, 99:15
call
19:2, 19:12,
19:14, 19:17,
20:1, 20:9,
20:15, 20:17,
20:19, 21:2,
26:13, 39:12
called
18:20, 19:20,
38:21, 85:10
calling
21:3, 21:5,
34:2
came
14:2, 15:1,
15:7, 31:8,
57:12, 99:13
can
11:13, 12:13,
13:6, 14:7,
15:13, 18:12,
19:1, 19:2,
20:14, 20:15,
22:4, 27:15,
28:17, 30:17,
33:17, 34:7,
35:1, 35:10,
35:16, 36:8,
40:10, 42:16,
50:19, 50:21,
51:11, 54:5,
62:9, 64:20,
65:20, 66:12,
67:12, 70:10,
70:22, 73:2,
81:8, 83:18,
92:13, 96:20
cant
20:11, 23:6,
24:8, 25:1,
25:8, 32:4,
32:8, 43:20,
47:3, 49:17,
52:12, 54:14,
59:18, 59:20,
63:10, 67:10,
70:9, 70:21,
71:4, 74:2,
89:5, 92:11
capacity
9:2, 9:8
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
capture
81:21
captured
82:8
case
8:6, 16:21,
18:11, 22:15,
28:8, 43:19,
57:14, 62:17,
65:9, 73:7,
73:8, 73:14,
76:17, 85:17,
102:10
46:12
certain
17:1
certainly
59:17, 61:5
certificate
102:1
certify
102:4
certifying
84:22
chain
18:18, 22:5,
22:9, 26:10,
32:11, 35:3,
35:11, 39:20,
41:7, 41:10,
65:17, 68:1,
74:4, 77:16,
77:17, 79:14
chains
40:5
chance
35:20, 65:13
characterization
41:16, 70:10
characterize
39:15, 97:4
charge
13:9, 42:22,
44:3, 56:20,
77:9, 95:5
chart
5:10, 12:14,
Transcript Sheryl Walter
Conducted June 14, 2019
13:4, 24:18
cheryl
22:21, 28:21,
56:3, 56:10,
77:21, 78:1,
78:2, 79:21,
81:6
chief
25:1, 42:1
chose
58:10
citizens
17:2
civil
1:6, 4:5
clarence
57:22, 77:19,
80:2, 80:14,
80:15, 80:22,
81:19
clarification
11:8
clarify
11:9, 70:22
classified
49:17
clear
10:6, 17:11,
17:18, 20:22
clearing
73:13
clearly
61:18, 68:17,
98:11
clinton
7:5, 15:6,
24:4, 38:9,
45:10, 52:4,
52:16, 52:17,
53:11, 53:15,
54:2, 54:8,
54:12, 56:21,
58:8, 58:15,
59:14, 60:4,
60:15, 61:2,
62:6, 63:1,
69:13, 71:7,
73:12, 76:1,
92:22, 94:9,
99:14
clintons
14:4, 14:22,
16:7, 16:12,
40:1, 40:18,
41:3, 41:12,
42:8, 49:8,
51:18, 57:3,
57:18, 66:14,
67:13, 67:16,
68:2, 68:13,
69:10, 70:5,
70:13, 73:15,
73:20, 75:8,
75:12, 91:19,
93:6, 93:22,
94:15, 95:8,
97:12, 97:20,
99:1
closely
80:6, 81:19,
82:14
collated
27:22
collect
23:17
columbia
1:2, 2:13, 8:6,
102:21
com
93:7, 94:16
come
14:11, 57:2,
57:10
comment
73:19, 81:4
commission
102:16
communicate
21:7, 57:1
communicating
45:7
communications
73:11
compiled
24:11
complete
71:22, 72:11,
72:17, 101:5
completely
27:19
concern
70:4, 71:14,
81:12, 82:5
concerned
62:18, 82:11
concerns
55:17, 58:21,
59:13, 59:18
conference
26:13
connecticut
2:5, 8:13
consider
43:2
considered
43:4, 43:18
considering
33:14, 33:16,
55:4
contact
15:18, 16:3,
55:10, 57:5
contacted
20:6, 21:11,
21:18, 21:21
contacting
21:22, 55:4
contacts
81:20
contained
75:20, 89:4
containing
44:21
content
59:22, 63:12
contents
34:3
context
19:18, 30:16,
36:5, 64:21,
74:3, 78:3,
78:22, 79:3,
80:11, 81:8
continued
6:1, 75:11
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
conversation
59:22, 70:12
conversations
60:8, 60:20,
60:22, 63:7,
63:13
copies
12:12, 68:1,
68:12
copy
15:19, 17:21,
23:9, 66:13,
67:12, 67:15,
80:11, 87:5
correct
10:22, 12:19,
13:4, 13:5,
13:20, 17:15,
28:7, 28:10,
28:15, 41:13,
41:19, 43:22,
51:6, 51:8,
53:4, 77:18,
86:15, 98:5,
101:4, 102:5
corrections
101:6
cotca
3:3, 5:3, 8:17,
9:20, 10:10,
10:14, 12:11,
17:15, 17:20,
18:1, 27:17,
28:1, 28:3,
28:8, 28:12,
28:15, 28:16,
34:8, 36:3,
36:8, 36:15,
45:21, 46:6,
58:2, 65:5,
65:11, 74:14,
74:18, 75:2,
76:14, 85:14,
92:13, 92:19,
96:14, 96:19,
99:6, 99:12,
99:20
could
9:22, 28:21,
Transcript Sheryl Walter
Conducted June 14, 2019
29:15, 30:4,
51:2, 52:19,
54:17, 59:2,
59:17, 61:7,
74:3
counsel
5:6, 7:2, 8:15,
9:19, 12:8,
17:8, 26:6,
34:22, 35:21,
39:17, 58:5,
65:2, 76:9,
79:6, 83:21,
85:8, 102:9
counsels
47:9
counselor
80:4, 81:5
couple
80:13
course
10:14, 11:12,
50:18, 91:17
court
1:1, 2:13, 8:6,
9:13, 10:9,
10:12, 16:20,
100:4
create
85:20, 91:3
created
86:18, 86:21,
88:2
crew
17:2, 18:21,
19:9, 19:17,
26:2, 26:11,
26:14, 27:6,
28:9, 32:17,
35:6, 38:7,
38:22, 39:5,
39:22, 41:2,
41:11, 42:7,
42:10, 48:3,
48:10, 48:17,
49:8, 50:12,
51:14, 52:3,
52:19, 53:18,
53:22, 54:14,
54:19, 55:1,
55:10, 55:18,
56:4, 56:11,
57:7
crews
23:21, 52:10
cristina
73:7
date
8:8, 101:10
dated
5:12, 5:15,
65:22, 73:4,
77:11
davis
5:12
day
46:14, 58:9,
102:13
day-to-day
66:22
1:12, 2:4, 2:7,
3:8, 3:16, 4:7,
4:14, 8:14
deal
98:3
dealing
97:19, 98:22
dealt
49:16
debbie
9:13
debra
1:22, 2:11,
102:2
december
12:3, 12:5,
14:1, 18:13,
22:6, 26:11,
27:3, 28:18,
29:20, 30:5,
31:16, 32:11,
33:5, 35:8,
38:19, 45:9,
51:15, 53:3,
56:10, 79:12
declaration
16:19, 16:22,
17:13, 18:3,
40:6
defendant
1:8, 3:11, 4:2,
4:10, 8:22, 9:7
definition
88:17
departing
6:11, 76:19,
76:20, 79:13,
79:20, 83:1,
84:6, 84:18,
84:19, 85:2
departments
13:12, 48:2
departmental
83:19
departments
44:18, 45:5,
64:6, 95:19
departure
82:15, 84:7
depend
43:19
deponent
101:1
depos
2:4, 8:11,
8:12, 9:14
deposed
10:15
deposition
1:11, 2:1, 5:7,
6:2, 7:3, 8:3,
8:11, 10:19,
12:7, 17:7,
26:5, 34:21,
39:16, 58:1,
65:1, 76:8,
79:5, 83:20,
85:7, 100:2,
102:3
deputies
25:2
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
deputy
57:9, 68:4,
71:1
described
69:18, 95:14,
97:6
details
19:1, 20:15,
61:21, 77:9,
98:14
determine
52:10, 52:17,
63:21, 64:4,
64:17, 69:13
determines
62:22
device
58:18, 59:15,
61:6, 61:7,
61:9, 61:12,
61:22
did
12:2, 13:6,
13:7, 20:17,
20:19, 21:2,
21:7, 21:9,
25:16, 26:1,
27:9, 28:14,
29:1, 29:10,
31:13, 31:14,
31:15, 31:20,
32:6, 34:20,
36:18, 37:8,
38:6, 39:14,
40:15, 42:9,
45:6, 46:9,
47:5, 47:7,
51:17, 52:3,
52:14, 52:22,
53:19, 54:3,
54:9, 55:9,
56:2, 56:22,
57:10, 62:4,
63:18, 63:19,
64:20, 66:21,
67:15, 67:18,
69:3, 69:12,
70:1, 71:7,
Transcript Sheryl Walter
Conducted June 14, 2019
73:18, 74:10,
75:21, 80:9,
82:13, 82:16,
82:19, 82:20,
85:20, 86:19,
91:2, 94:8,
95:17, 96:6,
98:3, 98:11,
98:12, 99:15
didnt
27:13, 43:9,
56:16, 64:10,
70:2
difference
14:20
different
28:11, 28:12,
30:14
dineen
4:19, 8:10
direct
68:6
direction
102:8
directive
75:5
directly
21:20, 74:9
director
11:16, 13:3,
13:20, 34:13,
53:4, 56:20,
71:21, 86:14,
87:21, 95:5,
95:16, 96:16,
97:9
disagree
39:8, 97:2
discovery
18:11, 65:8,
76:16, 85:17
discuss
33:20, 89:12
discussed
33:11, 33:12,
33:21, 59:18,
62:10, 74:5
discussion
34:3, 41:11
discussions
60:1, 75:18,
94:12
disk
8:2
district
1:1, 1:2, 2:12,
2:13, 8:5, 8:6,
102:21
division
4:5, 14:15,
15:19, 24:17,
24:21, 42:1,
44:3
79:19
docs
49:20
doctrine
34:6
document
18:7, 18:9,
18:10, 19:18,
26:18, 28:19,
30:17, 30:18,
37:7, 40:3,
65:6, 65:7,
65:21, 76:15,
78:22, 85:13,
85:15, 85:18,
85:20, 86:18,
86:21, 89:4,
90:19, 91:4,
91:8, 91:11
documents
17:5, 18:2,
27:19, 27:20,
27:21, 28:3,
28:5, 50:9,
62:11, 62:13,
62:14, 64:4,
69:19, 98:19
does
25:4, 35:8,
63:6, 64:15,
73:18, 83:5,
87:10
doesnt
54:6, 72:16
doing
36:19, 37:9,
37:19, 82:22
dont
11:8, 11:10,
16:11, 16:15,
16:18, 19:10,
21:3, 21:5,
22:2, 22:8,
22:13, 25:12,
26:3, 27:12,
27:14, 29:6,
31:12, 32:19,
34:10, 37:11,
37:15, 38:2,
43:8, 47:12,
47:13, 47:15,
47:17, 47:22,
48:6, 48:15,
49:13, 50:19,
51:3, 51:12,
52:7, 52:13,
53:13, 55:15,
56:2, 56:8,
56:14, 56:15,
56:18, 57:11,
57:20, 58:19,
59:2, 59:8,
59:21, 60:7,
60:19, 61:7,
61:15, 61:21,
63:12, 67:10,
68:16, 69:11,
71:17, 73:14,
74:6, 74:18,
75:9, 75:15,
76:7, 77:9,
78:8, 78:10,
78:13, 78:21,
80:16, 81:3,
82:3, 83:11,
83:14, 84:3,
84:15, 85:4,
87:12, 87:14,
91:7, 92:2,
93:2, 94:6,
94:12, 94:18,
96:18, 96:22,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
98:1, 98:6, 98:8
done
16:4, 81:20,
82:18, 93:5,
93:15
dos
6:7, 18:9,
76:15
dos_
5:18, 5:19,
5:21, 5:22, 6:4,
6:5, 6:9, 6:10
down
28:20, 33:1
draft
49:21, 83:16,
83:17
duly
9:18
during
13:1, 13:22,
14:21, 16:11,
20:3, 21:6,
21:15, 31:15,
34:12, 45:6,
51:13, 52:1,
52:14, 56:19,
60:10, 75:22,
94:7, 97:17
e-mails
14:3, 15:1,
15:10, 17:1,
32:1, 38:4,
40:1, 40:4,
40:18, 41:3,
41:12, 41:13,
49:9, 54:11,
66:14, 67:13,
67:17, 68:2,
68:13, 69:10,
70:5, 70:13,
71:2, 71:10,
73:15, 73:20,
75:8, 75:12,
75:20, 76:18,
92:22, 95:8,
Transcript Sheryl Walter
Conducted June 14, 2019
98:4, 98:7,
98:10
earlier
40:14, 42:6,
43:15, 95:7,
97:21
early
73:6, 74:13
edgar
40:11, 48:22
either
12:4, 14:14,
21:22, 56:15
electronic
59:15
elizabeth
4:3, 9:6
else
19:21, 21:17,
21:18, 55:9,
62:15
elses
61:7
employed
102:10
employee
9:3, 9:8
ending
5:11, 5:14
ends
100:2
engage
31:15, 56:22
enough
67:9
ensure
44:13, 44:21,
71:21, 72:9,
81:19
ensuring
80:3
entire
45:7, 63:20,
83:9
entry
26:13
errata
101:7
23:11, 25:5,
25:8
es-cr
40:17, 49:6,
49:12, 49:14
esquire
3:3, 3:4, 3:12,
4:3, 4:11
ethics
17:3
ever
10:15, 31:13,
36:18, 52:22,
58:12, 94:8,
94:21, 97:19,
98:21
every
65:16
exactly
16:10, 16:15,
38:15, 49:13,
55:5, 55:11,
57:11, 74:2,
87:14
examination
5:2, 9:19
examined
101:3
excuse
14:13
exhibit
5:7, 5:8, 5:11,
5:14, 5:17,
5:20, 6:2, 6:3,
6:6, 6:8, 6:11,
6:15, 7:3, 7:4,
12:7, 12:10,
17:7, 17:10,
18:8, 26:5,
26:8, 27:2,
29:17, 30:3,
32:10, 33:2,
33:3, 33:4,
34:21, 35:2,
38:17, 38:19,
39:16, 39:19,
40:11, 46:8,
48:21, 49:2,
54:17, 57:22,
58:4, 65:1,
65:4, 65:10,
65:11, 73:3,
76:8, 76:11,
77:11, 79:5,
79:8, 83:16,
83:20, 84:1,
85:7, 85:10,
92:7
exhibits
5:5, 6:1, 7:1,
75:20, 98:11
exist
28:14
existed
54:6
expect
87:8, 90:1,
91:18
expectation
10:6, 87:22,
88:6, 90:16,
90:22, 92:4
experience
34:12, 56:19
expires
102:16
explain
50:19
extent
34:2
eyeglasses
58:16
fact
98:3, 98:15
facts
43:19
factual
25:20, 96:12
fair
11:11, 13:15,
41:1, 70:6
fall
88:17
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
familiar
10:18, 57:13
far
38:5, 51:11
february
56:22, 79:20
federal
3:14, 6:16,
85:11, 87:3,
88:2, 89:10,
90:2, 91:1, 91:9
few
17:4, 65:18
figure
14:17
filed
88:16
files
88:17
filings
22:15
final
48:2, 48:9,
51:3
finally
48:6
financial
102:11
find
32:13, 44:5,
55:5, 62:5, 82:3
finish
40:7
finished
36:4
finnegan
45:15, 45:16,
66:1
finnegans
73:3
finney
7:3, 58:4,
80:15, 80:18,
82:13, 82:14,
82:16
finneys
57:22
first
18:6, 18:17,
Transcript Sheryl Walter
Conducted June 14, 2019
28:19, 35:10,
46:10, 77:10,
77:13, 79:13,
80:2, 83:15,
86:7, 94:14,
94:20
five-page
40:3, 65:6
focus
12:19
foia
13:12, 13:17,
14:2, 14:4,
14:7, 14:9,
14:22, 15:5,
17:1, 18:21,
19:6, 20:18,
21:8, 21:12,
23:10, 23:12,
23:17, 23:22,
24:12, 25:17,
26:14, 27:6,
28:6, 29:3,
29:11, 31:10,
31:22, 32:17,
34:13, 34:15,
36:19, 37:10,
37:20, 38:7,
38:22, 40:20,
42:3, 42:4,
42:21, 42:22,
43:1, 44:3,
44:15, 44:17,
45:1, 45:19,
45:20, 48:12,
50:16, 50:22,
52:10, 54:19,
55:18, 56:4,
56:11, 56:20,
57:2, 62:22,
63:20, 66:11,
67:2, 67:18,
67:20, 68:12,
69:9, 70:4,
70:15, 71:18,
71:22, 72:7,
73:19, 75:6,
75:11, 92:20,
93:11, 93:16,
95:6
foias
75:7
follow
73:6, 91:1
following
47:19, 55:22
follows
9:18
followup
63:17
foregoing
101:3, 102:3,
102:4
form
15:2, 16:5,
20:8, 20:10,
21:13, 23:5,
24:6, 25:19,
30:11, 30:22,
31:11, 32:2,
34:1, 34:17,
37:22, 38:13,
41:14, 42:14,
43:6, 44:10,
45:13, 47:10,
48:4, 51:20,
52:11, 52:20,
53:20, 55:13,
56:5, 57:4,
57:19, 59:1,
59:16, 60:6,
60:11, 60:18,
62:8, 63:3,
64:1, 64:9,
64:19, 68:14,
69:17, 70:7,
70:18, 71:11,
72:1, 72:13,
72:19, 73:22,
76:3, 81:7,
81:14, 82:1,
84:8, 85:21,
86:22, 88:4,
88:16, 89:2,
89:20, 90:8,
90:21, 91:5,
91:22, 92:9,
93:8, 94:17,
95:11, 95:22,
96:10, 97:14,
97:22, 99:4,
99:17
former
9:2, 9:8
forward
74:12
found
49:20
foundation
14:6, 15:12,
21:14, 24:7,
27:11, 29:5,
30:12, 31:1,
32:3, 32:18,
34:2, 34:18,
38:1, 38:14,
41:4, 41:15,
42:14, 44:11,
45:14, 47:11,
48:5, 50:14,
51:9, 51:21,
52:21, 53:21,
55:14, 56:6,
64:2, 68:15,
70:8, 70:19,
71:12, 72:2,
72:20, 73:13,
74:1, 81:15,
82:2, 84:9,
85:22, 87:1,
88:5, 89:3,
89:21, 91:6,
92:1, 92:10,
93:9
four-page
18:10
fourth
28:19
frame
11:20, 20:3,
45:7, 51:13,
52:1, 57:6,
60:2, 60:10,
61:13, 61:15,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
75:22
freedom
89:13, 89:18,
90:18, 95:13
friday
1:13, 46:14
from
5:12, 5:15,
7:4, 8:21,
11:22, 12:20,
14:1, 14:3,
15:10, 15:13,
16:6, 18:13,
18:15, 18:16,
18:21, 19:9,
19:12, 19:15,
19:17, 19:18,
20:1, 22:6,
22:14, 26:10,
27:3, 29:20,
30:17, 31:16,
32:16, 35:4,
35:8, 35:11,
35:12, 36:5,
38:19, 38:22,
40:11, 40:20,
41:7, 41:12,
45:9, 46:10,
48:22, 49:1,
51:15, 56:21,
58:6, 65:22,
68:8, 75:5,
76:20, 77:1,
77:11, 79:3,
79:10, 79:11,
82:5, 87:2,
92:21, 99:22
front
26:18, 46:22,
73:8, 73:9,
86:1, 87:2
full
46:10
further
22:4, 75:6,
100:2
fyi
40:16
Transcript Sheryl Walter
Conducted June 14, 2019
gave
57:14
gawker
92:21, 93:22
gawkers
93:15
general
29:7, 42:16,
59:4, 59:10
generally
14:8, 25:7,
63:15, 71:2
generated
62:14
geoffrey
66:2
get
10:4, 17:16,
19:1, 33:13,
36:18, 66:13,
67:12
gis
5:9
give
20:15
given
14:16, 25:14,
91:16, 101:5,
102:5
global
68:5
36:8, 38:17,
62:9, 92:13
goes
89:12
going
10:7, 10:10,
12:19, 12:20,
17:4, 17:15,
36:10, 36:16,
42:5, 46:1,
47:6, 65:16,
65:21, 74:19,
85:15, 92:14,
99:7, 100:3
good
9:21
gordon
40:12, 49:1
got
18:19
government
6:15, 85:11,
87:4, 88:3,
99:22
grafeld
68:1, 68:3,
68:7, 68:11,
69:4, 70:11,
70:14, 78:15,
79:11, 81:17,
82:6
grafelds
69:8
great
28:22, 29:16
guardian
7:5
guess
42:21
guidance
77:22, 78:18,
78:19, 79:1
hackett
57:8, 57:17,
58:20, 59:12,
60:2, 62:17,
66:2, 68:9,
68:12, 68:19,
70:12, 70:13,
93:21
had
16:8, 16:21,
16:22, 17:18,
22:15, 24:11,
26:17, 27:9,
28:10, 31:5,
35:20, 36:1,
39:13, 40:19,
43:22, 44:7,
44:14, 48:17,
52:2, 54:12,
55:16, 57:2,
57:5, 59:12,
60:1, 65:12,
68:1, 69:13,
70:15, 73:1,
78:17, 82:6,
84:19, 99:14,
99:19
hand
12:11, 102:12
handled
13:16
handling
34:13, 73:7
happen
50:21
happened
92:12
happy
11:4, 11:9,
29:9
hard
20:11
has
17:14, 80:2,
85:12, 86:1
hasnt
96:17
have
10:15, 17:21,
18:21, 19:1,
19:21, 19:22,
20:1, 20:6,
20:7, 20:9,
20:14, 20:21,
21:11, 21:21,
22:2, 22:13,
23:2, 23:6,
23:19, 26:3,
26:17, 27:8,
27:12, 31:3,
35:1, 35:10,
35:20, 37:13,
37:15, 37:17,
38:2, 38:21,
45:6, 49:21,
51:2, 52:8,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
54:12, 56:7,
56:14, 58:11,
58:13, 59:2,
59:4, 59:10,
59:17, 60:4,
60:19, 61:7,
61:10, 61:12,
61:17, 62:1,
62:14, 63:7,
63:16, 68:18,
69:20, 72:22,
77:21, 77:22,
79:9, 80:1,
81:13, 81:16,
81:20, 82:18,
87:16, 87:22,
88:7, 88:8,
91:19, 92:2,
92:5, 93:3,
93:20, 95:17,
97:15, 98:20,
101:3, 102:10,
102:12
havent
95:1
having
9:18, 22:14
hdr@clintonemail
94:16
head
45:17
heading
72:7
heather
22:7, 22:12,
23:9, 33:6,
33:7, 46:10,
51:17
held
2:1
her
9:2, 9:7, 15:1,
22:17, 23:2,
28:13, 31:7,
34:3, 34:4,
46:14, 47:19,
55:4, 55:22,
68:12, 71:9,
Transcript Sheryl Walter
Conducted June 14, 2019
77:20, 78:9,
79:20, 80:4,
81:5, 82:8,
92:8, 94:18,
96:14
here
8:2, 12:9,
13:8, 20:14,
24:18, 29:15,
47:13, 58:2,
70:10, 80:13,
80:14, 81:12,
98:17, 98:21
hereby
101:2, 102:3
hereunto
102:12
hermesman
66:3
23:9, 33:6,
33:7
hillary
7:5
him
80:6
his
25:2, 40:16,
57:13, 63:4,
63:5, 63:11,
66:20, 67:5,
73:13, 80:19,
81:3
hold
61:6
holding
58:16, 58:18,
59:14, 61:22
house
19:2, 19:12,
19:15, 19:17,
19:20, 20:1,
20:16, 20:17,
20:20, 21:3,
21:4, 21:5,
21:8, 21:11,
21:22, 22:16,
31:17, 31:21,
34:16, 38:21,
40:19, 47:9
how
14:4, 14:7,
15:9, 15:13,
15:16, 27:9,
27:12, 27:14,
31:8, 52:10,
55:18, 62:10,
62:13, 67:8
hrc@clintonemail
93:7
hypothetical
43:7, 43:21
ill
11:10, 12:9,
17:9, 65:3,
65:17
ive
45:3, 63:14,
64:3, 69:18,
95:14, 97:5,
97:15
idea
81:16
identifiable
44:22
identification
12:8, 17:8,
26:6, 34:22,
39:17, 65:2,
76:9, 79:6,
83:21, 85:8
identified
15:9, 40:13,
44:14, 72:4,
93:6
identify
44:4
imagine
89:6
implement
95:12
important
90:4, 90:5,
90:9
inc
1:4, 3:5, 8:4
include
25:16
included
13:10, 13:11,
13:12, 29:11,
31:7, 39:21,
39:22, 73:20,
92:6
includes
35:7, 73:15
including
46:12, 73:11,
80:4, 81:5,
81:21
independent
22:2, 22:13,
37:13, 37:15,
38:2, 70:1,
70:2, 92:2,
98:16, 98:19
independently
39:14, 47:3
individual
43:2, 45:4
individuals
24:14
info
92:6
inform
38:6, 42:9,
51:17
information
5:8, 6:18,
11:17, 13:9,
31:5, 49:17,
56:7, 68:5,
74:5, 86:4,
86:9, 89:10,
89:13, 89:19,
90:3, 90:18,
92:6, 95:13
informed
29:8, 53:11,
53:13, 56:4,
92:5
informing
54:21, 90:2,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
91:14
informs
46:13, 49:6
initial
35:8
input
32:15, 32:16
inquiring
27:5
instance
71:5
instances
21:10
instruct
34:4
intel
36:18
intelligence
37:8
interest
40:19, 102:11
interested
31:4, 31:6,
31:22, 68:17,
71:2
interpret
30:13, 42:18,
55:18
interpretation
39:9
interpreting
30:14, 37:1,
38:7, 42:10,
55:1
interrupt
10:5, 27:18
into
15:7, 17:16
investigation
70:1, 70:3
involved
42:3
ips
5:9, 13:7,
22:1, 34:13,
53:4, 56:20,
64:12, 64:15,
64:22, 66:11,
Transcript Sheryl Walter
Conducted June 14, 2019
69:8, 71:21,
75:5, 86:5,
87:22, 95:5,
95:16, 96:16,
97:9
irm
40:17, 49:6,
49:15, 49:16
isnt
36:22, 71:20
issue
53:18, 54:7,
57:17, 60:9,
60:12, 60:13,
61:1, 61:2,
62:20, 69:9,
71:4, 71:10,
71:13, 97:19,
98:22
issues
74:4
its
18:9, 18:10,
20:11, 25:20,
29:19, 40:2,
40:3, 46:22,
57:20, 58:6,
65:6, 65:20,
70:12, 73:8,
77:11, 83:7,
83:18, 84:3,
85:10, 88:10,
89:4, 90:5,
96:14
its
102:11
itself
53:22
january
6:14, 35:5,
35:11, 35:19,
36:17, 37:6,
54:18, 76:21,
77:1, 77:11,
79:12, 80:10,
83:17, 94:4
jaramillo
40:11, 48:22,
49:5
jaramillos
41:17
jeff
66:12, 66:17
jennifer
77:21, 78:6,
78:8, 78:11
jeremy
4:19, 8:10
job
1:20
jobs
31:4, 81:21
john
57:8, 66:2,
68:8, 70:12,
70:13, 93:21
johnson
5:13, 46:13,
47:16, 47:19
joined
58:8
joins
7:5
judge
73:9
judicial
1:4, 3:5, 8:4,
10:9, 17:13,
65:8, 73:7
june
1:13, 8:8,
57:17, 58:6,
58:22, 60:3,
75:4, 75:13,
102:13
just
10:5, 11:2,
12:9, 12:13,
12:19, 12:20,
13:1, 15:6,
16:6, 17:11,
17:17, 18:8,
18:14, 18:16,
23:18, 24:10,
25:10, 28:13,
30:16, 36:1,
41:7, 49:18,
51:3, 51:11,
57:21, 58:3,
58:14, 61:22,
64:11, 65:18,
67:11, 70:10,
79:9, 83:8,
87:2, 93:11,
97:7, 98:15
justice
3:13, 4:4, 8:22
karen
45:15, 45:16,
66:1
keep
29:7, 82:21,
96:12
kennedy
22:21
kept
69:5
kind
62:14
knew
47:15, 56:16
know
11:3, 11:9,
11:14, 16:10,
16:11, 16:15,
16:18, 20:11,
20:13, 21:18,
22:14, 22:17,
22:20, 23:1,
24:1, 25:12,
27:9, 27:12,
27:13, 27:14,
30:19, 31:8,
37:17, 41:5,
41:7, 43:8,
43:9, 46:9,
47:5, 47:8,
47:12, 47:13,
47:15, 47:16,
47:18, 48:6,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
49:13, 49:15,
51:4, 51:12,
52:13, 55:16,
56:2, 56:8,
56:16, 56:18,
58:19, 59:21,
61:8, 62:13,
65:12, 68:7,
68:16, 69:7,
74:6, 75:10,
75:15, 75:17,
77:2, 77:9,
77:20, 78:8,
78:10, 78:13,
78:21, 80:16,
80:21, 81:17,
83:11, 83:14,
84:3, 84:4,
84:15, 86:17,
86:20, 87:14,
87:19, 89:17,
90:5, 90:11,
91:2, 94:18
knowing
40:19
knowledge
21:22, 22:2,
22:13, 92:2,
96:13
known
23:2, 27:12,
99:19
kollar-kotelly
73:9
last
18:16, 26:12,
27:2, 46:14,
77:14, 77:17,
81:3, 83:7
late
74:12
later
25:13
lauren
3:4, 8:19,
12:11
Transcript Sheryl Walter
Conducted June 14, 2019
law
91:1
laws
80:5, 89:11,
90:3, 90:11,
90:18
lays
13:8
leaving
46:14, 51:16,
79:2, 79:22,
82:9
left
12:21, 56:21,
75:13, 84:22
legal
25:6
let
11:3, 11:8,
11:13, 33:11,
39:18, 42:20,
46:9, 65:12,
71:6, 77:19,
77:20, 83:22,
85:9
lets
38:17
letter
49:22, 50:5,
50:8
liaison
14:15, 22:16,
34:16
liaisons
31:18, 31:21
library
13:13
lieberman
4:11, 9:10
like
19:3, 26:12,
27:19, 29:9,
32:14, 40:7,
58:18, 74:16,
85:6
limited
10:7
line
39:22, 40:1,
55:7, 80:3
list
23:19, 24:9,
28:21, 29:2,
29:9, 29:11,
29:16, 30:1,
30:5, 30:10,
30:21, 31:7
litigation
45:17
little
35:22
located
48:11, 48:17,
51:6, 93:4
logical
52:8, 52:9
long
32:14
look
12:13, 15:21,
18:12, 27:19,
29:17, 35:1,
35:10, 46:7,
48:21, 54:17,
79:7
looking
26:19, 30:16,
32:10, 41:6,
41:7, 41:9,
55:6, 55:11,
83:10, 98:10
looks
26:12, 36:5,
58:18
made
10:9, 48:10,
56:11, 97:11
make
20:19, 31:3,
31:4, 36:1,
44:6, 84:12,
97:9
making
82:6
management
16:2
managing
95:9, 95:20,
96:8, 97:10
manheim
66:2
many
67:8
march
6:19, 12:1,
12:22, 14:2,
31:17, 41:20,
46:11, 46:17,
46:21, 49:1,
49:4, 51:16,
86:15, 89:1,
99:14
margaret
68:1, 68:3,
70:11
marianne
66:2
marked
5:5, 6:1, 7:1,
12:7, 12:10,
17:7, 26:5,
34:21, 39:16,
57:22, 58:4,
65:1, 76:8,
79:5, 83:20,
83:22, 85:7
marking
58:2
massachusetts
4:6
matter
6:13, 8:4,
25:14
matters
96:12
may
45:9, 48:16,
50:17, 54:12,
57:6, 60:4,
63:15, 63:16,
64:4
mean
50:20, 54:6,
60:13, 61:1,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
67:18, 71:13,
72:16, 79:16,
87:10, 91:13,
91:14
meaning
77:13
means
25:7, 79:20
meet
31:13
memory
63:8
mentioned
93:11
messages
88:10, 88:13
michael
4:11, 9:10
might
23:6, 23:18,
61:10, 61:12,
62:1, 62:14,
78:9
mills
22:21, 56:3,
56:10, 57:1,
57:5, 77:2,
78:2, 79:21,
81:6, 81:10
minute
26:17, 36:9
minutes
10:8, 10:11
moment
22:8
monitor
8:9
months
25:15, 25:18,
80:1
more
29:8
mostly
24:16
move
57:6
moving
22:4, 35:22,
Transcript Sheryl Walter
Conducted June 14, 2019
74:12
much
28:20
multiple
50:16, 50:18
must
88:15
myself
19:15
name
9:22, 10:2,
81:3, 85:12
necessarily
73:15, 73:19
need
11:3, 11:7,
74:14
needed
31:5
neither
102:9
never
47:15, 57:5,
95:3
news
99:13
next
47:6, 52:9
no-records
75:6, 75:11
no-responsive-record
62:21
non-record
6:13
noncareer
79:21
nonetheless
11:2
nor
102:9
normal
34:14
northwest
8:13
nos
5:17, 5:20,
6:3, 6:6, 6:8
not
16:9, 17:15,
19:14, 19:20,
20:19, 21:2,
21:9, 21:17,
21:18, 21:19,
21:20, 22:19,
23:1, 24:1,
25:1, 27:13,
28:14, 31:14,
31:19, 32:5,
32:21, 34:4,
35:9, 36:3,
38:15, 39:14,
43:18, 44:16,
47:7, 48:20,
49:13, 51:3,
53:17, 53:19,
54:3, 54:9,
56:2, 58:2,
60:4, 60:21,
62:1, 63:11,
63:16, 63:22,
64:10, 64:13,
64:15, 64:18,
65:16, 67:4,
67:9, 70:1,
71:4, 71:7,
75:6, 82:16,
83:8, 85:19,
87:19, 88:18,
89:6, 93:12,
95:17, 96:4,
96:6, 97:5,
97:8, 97:18,
98:14, 99:3
notarial
102:13
notary
2:13, 102:1,
102:20
notice
2:11, 45:6,
83:16, 83:17,
84:2, 84:3,
84:4, 84:5,
84:10, 84:17
noticed
43:22
november
12:4, 14:1,
31:16, 53:3,
56:21, 94:3
now
14:14, 23:7,
47:15, 96:11
number
8:3, 8:6,
36:20, 65:6,
73:8
numbers
28:11, 28:12
2:5, 3:15, 4:6,
4:13
objected
96:21
objection
14:6, 15:2,
15:12, 16:5,
20:8, 20:10,
21:13, 23:5,
24:6, 25:19,
27:11, 29:5,
29:14, 30:11,
30:22, 31:11,
32:2, 32:18,
34:1, 34:17,
37:22, 38:13,
41:4, 41:14,
42:12, 43:6,
43:11, 44:10,
45:13, 47:10,
48:4, 50:14,
51:9, 51:20,
52:11, 52:20,
53:20, 55:13,
56:5, 57:4,
57:19, 59:1,
59:16, 60:6,
60:11, 60:18,
61:4, 62:8,
63:3, 63:9,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
64:1, 64:9,
64:19, 68:14,
69:15, 69:17,
70:7, 70:18,
71:11, 72:1,
72:13, 72:19,
73:22, 76:3,
76:6, 81:7,
81:14, 82:1,
84:8, 85:21,
86:22, 88:4,
89:2, 89:20,
90:8, 90:21,
91:5, 91:22,
92:9, 93:8,
94:17, 95:11,
95:22, 96:10,
97:14, 97:22,
99:4, 99:17
objections
32:7, 45:2,
47:21, 48:14,
48:19, 52:6,
54:4, 54:10,
55:20, 56:13,
56:17, 71:16,
82:10, 84:16,
85:3, 87:7,
87:13, 87:18,
94:2, 94:5,
94:11, 95:2
obligate
96:6
obligated
96:15
obligation
71:20
obligations
84:12
obviously
70:3
off
36:8, 36:10,
46:1, 74:19,
92:13, 92:14,
99:6, 99:7,
100:3, 100:6
office
5:8, 6:17,
Transcript Sheryl Walter
Conducted June 14, 2019
11:16, 12:14,
13:7, 13:16,
14:4, 15:8,
15:19, 16:4,
16:8, 19:22,
20:6, 22:1,
22:17, 22:18,
24:11, 25:6,
25:7, 25:11,
31:18, 31:21,
44:17, 47:9,
52:15, 52:16,
53:1, 62:12,
62:22, 63:19,
69:8, 69:21,
70:4, 71:8,
75:5, 81:1,
85:20, 86:3,
86:8, 86:12,
86:13, 86:17,
87:17, 88:1,
88:2, 90:17,
91:2, 91:3,
91:19, 92:5,
95:9, 97:10
officer
102:2
offices
2:2, 8:12,
14:12, 15:8,
15:10, 44:18,
45:5, 62:12,
64:5, 69:20,
72:5, 72:22,
96:7
official
9:2, 37:2,
38:8, 42:11,
42:17, 42:19,
43:4, 43:16,
43:18, 44:1,
44:8, 44:14,
44:19, 44:21,
55:2, 70:16,
72:4, 89:10
officials
6:11, 6:16,
19:1, 38:11,
39:1, 39:6,
42:6, 45:8,
46:12, 66:8,
76:20, 79:13,
83:1, 84:6,
84:19, 85:12,
87:3, 87:8,
87:11, 88:3,
88:7, 89:17,
90:3, 91:1,
91:10, 91:13,
91:15, 91:16
often
31:15, 50:15
oglesby
49:22, 50:5,
50:6, 50:8
once
15:7, 65:12
one
14:12, 15:8,
15:17, 18:2,
18:14, 18:16,
18:17, 27:2,
40:4, 50:17,
58:10, 66:18,
70:22, 74:4
ones
67:4, 72:21
only
11:6, 37:2,
38:8, 41:5,
42:11, 42:15,
42:16, 55:2,
64:20, 79:9,
81:8, 83:18
opportunity
36:2
opposed
38:9
order
45:1, 100:4
org
5:9
other
11:6, 21:8,
21:10, 27:7,
27:9, 36:18,
37:9, 37:11,
37:19, 38:10,
45:8, 57:2,
61:10, 62:12,
68:17, 89:9,
97:20
others
73:4
otherwise
74:6, 102:11
our
10:6, 14:13,
14:14, 23:9,
25:14, 33:11,
33:12, 45:17,
59:22, 64:21,
72:3, 72:12,
72:14, 81:21,
81:22, 83:4
out
12:11, 13:8,
14:12, 14:17,
44:5, 55:5,
88:15, 93:13,
99:13
outcome
102:11
outlook
26:13
outside
98:16, 99:1,
99:3
page
5:2, 5:7, 6:2,
7:3, 18:7,
26:12, 28:19,
29:18, 38:18,
40:11, 46:10,
49:2, 65:21,
73:2, 77:12,
83:8, 83:15,
85:12, 86:8,
87:2, 88:9,
89:7, 89:8, 90:1
pages
1:21
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
paper
88:16
papers
6:13, 77:3,
77:7
paragraph
79:18, 83:9
part
16:20, 42:15,
51:2, 72:8,
86:5, 91:14
particular
15:18, 31:5,
59:7, 60:7,
70:20, 70:21,
84:10, 84:17
particularly
79:21
parties
102:10
parts
14:18
past
57:6
pat
66:19
patrick
22:21, 24:22,
40:12, 40:13,
49:1, 66:1
pending
73:9, 73:10
people
24:11, 29:8,
31:4, 71:17
performed
96:1
period
12:20, 16:13,
16:14, 52:15
person
16:15, 43:12,
77:8
personal
6:12, 18:22,
24:3, 37:1,
38:9, 38:12,
38:22, 39:6,
Transcript Sheryl Walter
Conducted June 14, 2019
41:13, 42:8,
43:3, 43:16,
44:1, 44:5,
45:10, 77:3,
77:6, 99:15
pertaining
31:22
phone
19:14, 20:9,
20:19
photo