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Judicial Watch • JW v State State status report 01363

JW v State State status report 01363

JW v State State status report 01363

Page 1: JW v State State status report 01363

Category:Clintons

Number of Pages:19

Date Created:August 12, 2015

Date Uploaded to the Library:August 13, 2015

Tags:Hillary Clinton Email Scandal


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Case 1:13-cv-01363-EGS Document Filed 08/12/15 Page
UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
Plaintiff,
UNITED STATES DEPARTMENT
STATE,
Defendant.
Civil Action No. 13-CV-1363 (EGS)
DEFENDANT AUGUST 12, 2015 STATUS REPORT August 2015, the Court directed the Government request that former Secretary
Clinton, Cheryl Mills, and Huma Abedin (i) not delete any federal documents, electronic
otherwise, their possession control, and (ii) provide appropriate assurances the
Government that they will not delete any such documents. The Court also directed the
Government inform the Court the status its compliance with this Order later than
August 12, 2015, including copy any such assurances provided these individuals. August 10, 2015, the Department sent letters former Secretary Clinton, Ms. Mills,
and Ms. Abedin, through their respective attorneys, requesting that they not delete any federal
documents, electronic otherwise, their possession control, and provide appropriate
assurances the Government that they will not delete any such documents. Copies the
Department letters counsel for the former Secretary, Ms. Mills, and Ms. Abedin are attached
hereto Exhibits and
Case 1:13-cv-01363-EGS Document Filed 08/12/15 Page
Today, August 12, 2015, the Department received responsive letters from Ms. Mills
counsel and former Secretary Clinton counsel and responsive email from Ms. Abedin
counsel. Copies those documents are attached hereto Exhibits and
Dated: August 12, 2015
Respectfully submitted,
BENJAMIN MIZER
Principal Deputy Assistant Attorney General
MARCIA BERMAN
Assistant Director
/s/ Peter Wechsler
PETER WECHSLER (MA 550339)
Senior Counsel
United States Department Justice
Civil Division, Federal Programs Branch Massachusetts Avenue, N.W.
Washington, D.C. 20530
Tel.: (202) 514-2705
Fax: (202) 616-8470
Email: peter.wechsler@usdoj.gov
Counsel for Defendant
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
EXHIBIT
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
EXHIBIT
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
EXHIBIT
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
EXHIBIT
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
PAUL, WEISS, RIFKIND, GARRISON LLP STREET,
TELEPHONE
BETH
(202) 223-7300
WILKINSON
TELEPHONE
FACSIMILE
E-MAIL
UNIT OFFICE TOWER BEIJING
FORTUNE PLAZA DONGSANHUAN 2HONGLU
CHAOYANG DISTRICT
BEIJING 100020
PEOPLES REPUBLIC CHINA
TELEPHONE (86-10) 5828-6300
12TH FLOOR, HONG KONG CLUB BUILDING CHATER ROAD, CENTRAL
HONG KONG
TELEPHONE (852) 2846-O30O
(202) 223-7340
(202) 204-7395
ALDER CASTLE NOBLE STREET
LONDON EC2V 7JU,
TELEPHONE (44 20) 7367 600
bwilkinson@paulweiss com
FUKOKU SEIMEI BUILDING
2-2 UCHISAIWAICHO 2-CHOME
CH1YODA-KU TOKYO lOO-OOI JAPAN
TELEPHONE (81-3) 3597-8101
August 12, 2015 Electronic Mail Hand Delivery
Patrick Kennedy
Under Secretary for Management
United States Department State
2201 Street,
Washington, 20520
TORONTO-DOMINION CENTRE KING STREET WEST, SUITE 3100 BOX 226
TORONTO, ONTARIO M5K 1J3
TELEPHONE (416) 504-0520
2001 STREET
WASHINGTON, 20006-1047
TELEPHONE (202) 223-7300
500 DELAWARE AVENUE, SUITE 200
POST OFFICE BOX
WILMINGTON, 19899-0032
TELEPHONE (302) 6S5-4410
Dear Under Secretary Kennedy: received your August 10, 2015 letter regarding Judge Emmet
Sullivans August 2015 Order Judicial Watch, Inc. U.S. Department State, No.
13-CV-1363.
First, ask you make clear Judge Sullivan that have provided you
with complete set any federal records potential federal records (hereinafter
referred potential federal records) that Ms. Cheryl Mills has identified her
custody and control. That original set documents the custody and control the
Department State.
Second, compliance with Judge Sullivans order, Ms. Mills will not
delete any potential federal records, electronic otherwise.
Third, you know, your July letter you asked return all copies Ms. Mills potential federal records, which includes electronic copies, the
Department. Because Ms. Mills had electronic copies the same documents provided
the Department, she had copies that fell under the August request. Accordingly, the
only way comply with the Departments request remove all copies (of the production
the Department has) from Ms. Mills custody and control delete the copiesfromher
electronic account, which she now will not do.
Fourth, ask you clarify with Judge Sullivan that was the State
Department that asked for the return all copies potential federal records Ms.
Mills possession; and, going forward will the State Departments responsibility
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
PAUL, WEISS, RIFKIND, GARRISON LLP
Patrick Kennedy
secure permission from Judge Sullivan remove any copies such emails from Ms.
Mills email account.
Finally, you know, have retained copy all the documents
provided the State Department behalf Ms. Mills Ms. Mills attorneys.
mentioned August letter, await instructions from you how store
retain our electronic copies Ms. Mills documents that are your custody and control.
Sincerely,
Beth Wilkinson
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
EXHIBIT
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
EXHIBIT
Case 1:13-cv-01363-EGS Document 24-1 Filed 08/12/15 Page
From: Rodriguez, Miguel [Miguel.Rodriguez@bryancave.com]
Sent: Wednesday, August 12, 2015 11:07 Eastern Standard Time
To: Patrick Kennedy
Cc: Rich Visek; Karen Dunn
Subject: Ms. Abedin Document Retention
Dear Under Secretary Kennedy, are receipt your August 10, 2015 letter regarding Judge Emmet Sullivan August 2015 Order Judicial Watch, Inc. Department State. want confirm for the Department that accordance with your request, Ms. Abedin will
not delete any potential federal records her possession.
Thank you.
Miguel Rodriguez
Bryan Cave LLP
1155 Street,
Washington, 20004
(202) 508-6031 (o)
(202) 578-9224 (c)
miguel.rodriguez@bryancave.com