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Judicial Watch • JW v State Sullivan depo 01242

JW v State Sullivan depo 01242

JW v State Sullivan depo 01242

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Date Created:April 24, 2019

Date Uploaded to the Library:April 24, 2019

Tags:Jacob Sullivan, Bekesha, Transcript, 01242, Susan Rice, Sullivan, Benghazi, Hillary Clinton, clinton, White House, Obama, State Department, FBI, DOJ, department, FOIA, CIA


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Planet Depose Make Happen,.
Transcript Jacob Sullivan
Date: April 16, 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 THE UNITED STATES DISTRI COURT
FOR THE STRIC COLUMBIA
----------------------------------------
JUDICIAL WATCH,
INC.,
Plaintiff,
U.S. DEPARTMENT STATE,
C.A. 14-01242
Defendant.
(RCL)
---------- ---- -------------- ---------
DEPOSITION JACOB SULLIVAN
THIS DEPOSITION TAKEN PURSUANT NOTICE OHIVE,
155 FLEET STREET,
APRIL 16, 2019, COMMENCING 8:57 A.M.
PORTSMOUTH, NEW HAMPSHIRE, TUESDAY,
Transcript Jacob Sullivan
Conducted April 16, 2019
APPEARANCES
For the Plaintiff:
By:
James Peterson, Esq.
425 Third Street, Suite 800
Washington, 20024
Michael Bekesha, Esq.
For the Def end ant: DEPARTMENT JUSTICE
By:
Stephen Pezzi, Esq.
Cassandra Kildow, Esq.
1100 Street
Washington, 20005
Elizabeth Shapiro, Esq.
PIANET DEPOS
888.433.3767 IWWW.PIANETDEPOS.COM
Transcript Jacob Sullivan
Conducted April 16, 2019
APPEARANCES (Contd):
For the Deponent:
WILKINSON, WALSH
By:
Hal Brewster, Esq.
2001 Street, NW, 10th Floor
Washington, 20036
ESKOVITZ
Cali Cope-Kasten, Esq.
Videographer:
Paul Pazolt, Legal Video Specialist
Court reporter:
Sharon Saalfield, LCR No. 147, CSR, RPR, CRR
PLANET DEPOS
888.433.3767 WWW.PIANETDEPOS.COM
Transcript Jacob Sullivan
Conducted April 16, 2019
STIPULATIONS agreed that the deposition shall taken
the first instance stenotype and when transcribed may used for all purposes for which depositions are
competent under Federal law.
Notice,
filing,
caption and all other formalities
are waived.
reserved and may taken court time trial.
All objections except form are further agreed that the deposition not
signed within thirty
counsel,
(30)
days after submission
the signature the deponent waived.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Jacob Sullivan
Conducted April 16, 2019
INDEX
WITNESS
Jacob Sullivan Mr. Bekesha
PAGE Ms. Cope-Kasten
EXHIBITS
NUMBER
DESCRIPTION
9/15/12 email from Sullivan Ryu
9/15/12 email from Sullivan Ryu
7/29/12 email from Mills Sullivan
8/11/15 Unclassified Memo
1/26/10 email from Sullivan Abedin
6/17/11 email from Clinton Sullivan
1/10/11 email from Abedin Sullivan and Mills
9/25/10 email from Clinton Sullivan
PAGE
7/22/11 email from Abedin Sullivan
Errata Sheet:
(Original exhibits were retained Mr. Bekesha.)
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Jacob Sullivan
Conducted April 16, 2019
(Exhibits and marked for
identification.)
VIDEOGRAPHER:
Here begins DVD number one the videotaped deposition Jacob Sullivan the matter Judicial Watch, Incorporated,
versus the Department State, the
District Court, District Columbia.
number 14-01242 RCL.
Case
Todays date April 16th, 2019.
The
time the video monitor approximately 8:57
a.m.
representing Planet Depos.
The videographer today Paul Pazolt
This video deposition taking place
155 Fleet Street, Portsmouth, New Hampshire.
Would counsel please voice identify
themselves and state whom they represent?
MR. BEKESHA:
Michael Bekesha behalf
Judicial Watch.
MR. PETERSON:
James Peterson behalf
Judicial Watch.
MS. COPE-KASTEN:
Cali Cope-Kasten
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Jacob Sullivan
Conducted April 16, 2019
beha_l Jake LLi_v a_.o
MR. BREWSTER:
Hal Brewster, also
behalf Jake Sullivan.
MS. SHAPIRO:
Elizabeth Shapiro behalf the Department State and behalf the
witness his capacity former State
Department official.
MR. PEZZI:
Stephen Pezzi from the
Department Justice also behalf the
Department State.
MS. KILDOW:
Cassandra Kildow behalf
the Department State.
VIDEOGRAPHER:
The court reporter today
Sharon Saalfield representing Planet Depos.
Would the court reporter please swear the
witness?
JACOB SULLIVAN,
having been duly sworn Ms. Saalfield,
was deposed and testified follows:
EXAMINATION MR. BEKESHA:
Good morning, Mr. Sullivan. name Michael
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Jacob Sullivan
Conducted April 16, 2019
Bekesha.
here ask you some questions about one Judicial
Watchs Freedom Information Acts lawsuits
against the State Department, specifically questions
about whether Secretary Clintons use private
email server was intended stymie FOIA and whether
the State Department has adequately searched for
records responsive Judicial Watchs FOIA requests
concerning the talking points provided Ambassador
Susan Rice concerning the September 11th, 2012
attacks Benghazi prior her September 16th,
2012 television appearances.
spell your name for the record? name Jake Sullivan.
J-A-K-E,
S-U-L-L-I-V-A-N.
Thank you.
Also like over few ground
rules.
about them, but will helpful make this
deposition more smoothly.
Before begin, could you please state and attorney for Judicial Watch.
Your counsel may have already talked you dont hear one questions, let
know and Ill happy repeat it. you dont
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Jacob Sullivan
Conducted April 16, 2019
1,,1_nd.e rsta_nd one questi.ori_s _l_e_t_____me_ h.at
well and Ill try make myself clearer.
Its also important that you respond out loud opposed shaking your head even gestures
because the court reporter cant record those
things.
Finally, its important that you wait until
done asking questions, your counsel
Ms. Shapiro making objections, wait until theyre
done speaking.
one time.
The court reporter can only record
Also, you need break any point, please
let know.
but happy take breaks whenever your counsel you need.
Were going move through quickly
Just let know.
With that, lets jump right and lets mark
this Exhibit
pre-marked Exhibit guess was already you could just take minute and look over
the email?
Okay.
Excellent.
Thank you.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Jacob Sullivan
Conducted April 16, 2019
For the record, Exhibit has been marked.
Its email chain.
email from you dated September 15th, 2012 2:44
p.m. with the subject forward; that
correct? the top the chain its
Yes.
Who this email sent to? was sent Rexon Ryu.
And who Rexon Ryu? was the deputy USUN,
Thank you. the subject refers says
you and Erin.
the mission the
United Nations.
Who Erin? believe Erin Erin Pelton who was Susan Rices
senior advisor some sort advisor Susan
Rice. you have any idea what her title was? dont recall her title.
Okay.
And that was advisor Ambassador Rices
position the USUN?
Right. think Erin was attached USUN well
but not hundred percent sure that.
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019
Okay eat you
Movin down the
guess the previous email right below it.
want through and identify all those
individuals that the email went to.
Lets start with Benjamin Rhodes.
just
Who
Mr. Rhodes?
Mr. Rhodes was senior advisor President
Obama. you know what his title and what office was
located in? believe his title was Deputy National Security
Advisor.
Okay. not sure what you mean what office was
located in. was located the White House national
wasnt located the State Department?
No. was official associated with the White
House.
Okay.
Thank you.
The next person that the email
was sent to,
the email address there. looks like just the name part you know who that
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Jacob Sullivan
Conducted April 16, 2019
individual is? believe that thats the email address for Michael
Morell.
Okay. was the Deputy Director the Central
Intelligence Agency the time.
Going the next person.
Robert
Robert Cardillo was the Deputy Director National
Intelligence, the Deputy DNI.
Okay.
Cardillo?
And who Mr. Morell?
What about the next person?
MS. SHAPIRO:
Looks like Alan going just object for may have pause confer with moment.
the witness because dont want him
disclose any name that redacted pursuant
the NSA Act that would inappropriate the
public record.
MR. BEKESHA:
Okay.
MS. SHAPIRO: you dont mind just
confer
MR. BEKESHA:
Not all.
MS. SHAPIRO: for moment?
PLANET DEPOS
888.433.3767 WWW.PIANETDEPOS.COM
Thank you.
Transcript Jacob Sullivan
Conducted April 16, 2019 BEKESHA: that individual not State Departme employee?
MS. SHAPIRO:
You can answer that.
THE WITNESS: dont believe thats
State Department employee.
MR. BEKESHA:
Okay.
Lets move then.
MS. SHAPIRO:
All right.
MR. BEKESHA:
Well try resolve those they come up.
MS. SHAPIRO:
Thank you.
MR. BEKESHA:
Not trying beyond what need. MR. BEKESHA:
The next individual, looks like Matt Olsen?
Matt Olsen believe the time was the director
the National Counterterrorism Center.
What about the next person?
Mark Giuliano?
Yes. think Mark Giuliano
and again, sorry, this
was seven years ago.
the FBI, was senior official the FBI. think was attached
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019
Okay. looks like the next email address,
Cingli potentially? dont.
Okay.
Lisa Monaco, you know who that is?
The next one, Lisa Monaco? think 2012 she was DOJ but
dont know that for certain.
Was she somewhere else before after DOJ?
After she became the national
the Homeland
Security and Counterterrorism advisor President
Obama but believe 2012 she was DOJ.
The next one G-E-0-R-G-J-W-2?
MS. SHAPIRO: going just ask that
maybe you follow with the same question
about whether not worked for State before
the witness answers. MR. BEKESHA:
Did work the State Department? dont think but not actually sure who that
is.
MR. BEKESHA:
Okay. that going
applying the rest that row, Betsy?
MS. SHAPIRO: believe so.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Jacob Sullivan
Conducted April 16, 2019 MR._ BEK.ESRA:
C-Y-N-T-H-1-R.
No.
C-H-R-I-S-T-R-M?
No.
And then Rodney, R-0-D-N-E-Y-A-S? you know who that is? you know who that is? you know who
that is? do.
Was that State Department employee?
No.
Okay.
All right.
Thank you.
Going little bit
more broadly now with this email.
about what this email chain is?
Could you talk
This email chain originated with Michael Morell
sending around his suggested points that were
prepared for the CIA shared with the House
Permanent Select Committee Intelligence that
reflected the best understanding the intelligence
community this time what happened the
evening September 11th Benghazi.
Okay.
one,
And lower down the page guess its the
two,
the 4th email. says,
Per the
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019
discussion Deputies. you see that? do.
What does Deputies mean?
MS. COPE-KASTEN:
speculation.
Objection.
Calls for
You may answer.
THE WITNESS:
That refers the Deputies
Committee which the sub-cabinet officials
below cabinet level, the Deputy Director
the Central Intelligence Agency,
DNI, the Deputy Secretary State and
forth. address issues foreign policy and
national security.
There was meeting probably two three times
Okay. you know who attended you recall who
attended those meetings?
Was there particular meeting that took
day through this period.
Okay.
place around that time that this referring to?
They gather the Deputies Committee MR. BEKESHA:
the Deputy think was fluid group people.
The core
folks were those deputies that just described,
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
the
Transcript Jacob Sullivan
Conducted April 16, 2019
deputies the various cabinet agencies ..relative
national security, but then there was series
other participants from the main national security
and foreign policy agencies well.
How about from the State Department?
The State Department would have had rotating cast several different participants. you recall who those individuals would have
been? couldnt tell you everybody who was there, no.
Could you tell some who you remember, who
you remember? attended some them, not all them.
Pat
Kennedy attended some them.
memory from long time ago. guessing little bit say who was the
room for these meetings.
meetings.
just with respect Benghazi, but with respect
the threats and attacks our embassies across the
region.
deck.
Youre testing sorry, mean, had lot were meeting around the clock, not this was time that was all hands
There were lot people coming and out
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Jacob Sullivan
Conducted April 16, 2019 various rooms.
Approximately how many meetings did you attend
during this time period?
MS. COPE-KASTEN:
Objection.
Relevance,
beyond the scope.
MS. SHAPIRO:
Same objection.
THE WITNESS: think was was
meetings virtually all day, every day. MR. BEKESHA:
Okay.
Besides this chain emails, you recall
any other emails that were being circulated
regarding these talking points these points,
you called them? when you say, other emails being circulated
with respect these points, can you can you
clarify?
Sure.
Ill strike that question and may come back later. you know these points that are being
discussed this email chain, this email chain
made its way Ambassador Rice?
MS. COPE-KASTEN:
Objection.
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Calls for
Transcript Jacob Sullivan
Conducted April 16, 2019
spec latio ion
MR. BEKESHA:
You may answer the question.
THE WITNESS: dont know what happened
with the points after sent this email
Rexon. MR. BEKESHA:
Okay. the top says,
You and Erin should
confirm with Ben that Susan can deploy tomorrow.
Who Ben?
Ben Ben Rhodes.
Okay.
Susan Susan Rice.
And what you mean by,
Rexon had emailed say,
And who Susan?
Can deploy tomorrow?
Hey, hear that there
are points that the CIA has prepared that reflect
the intelligence communitys assessment what
happened Benghazi.
Because like Susan have them.
Can you send them me?
And thats what doing here. sent him
email that basically said,
have check with Ben whether not she could
use them.
Here they are, but you
PLANET DEPOS
888.433.3767 WWW.PLANETDEPOS.COM
Transcript Jacob Sullivan
Conducted April 16, 2019
And you know she used the talking points?
Like said, wasnt part her prep for the
Sunday show not sure what she relied
her points.
played into her preparation.
just dont know exactly how these
Did you ever speak Ambassador Rice email -strike.
Did you ever speak Ambassador Rice before
before her appearances?
she COPE-KASTEN:
Objection.
Beyond the
scope.
THE WITNESS: mean, spoke with her
many times over the years, but you mean
this MR. BEKESHA: this context following these
No. was not part her preparation for these
points, no.
Did you ever email with her about these points? dont remember emailing with her about these
points.
Lets have you take look whats been pre-marked
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019
_____a3_
Exhibi __2_._________
Have you had chance look the email?
Yeah.
Okay.
Great.
Thank you.
Exhibit
just for the
record, appears email from you dated
September 15, 2012, 2:44 p.m. Rexon Ryu;
that correct?
Yes.
Great.
Just one quick question this.
Who
Eric going not pronounce his last name
correctly Pelofsky?
Yeah, thats his thats his last name. you know who is?
Yeah.
Eric Pelofsky worked for Rexon the USUN
office Washington.
Okay. know this several years ago but you
recall you ever used non-State Department email
account during the time period between the Benghazi
attack and September 16th guess were
2012?
MS. SHAPIRO:
Objection form.
THE WITNESS: non-State Department
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019
email account between September 11th and
September 16th? MR. BEKESHA:
Yeah, dont remember.
Okay.
for State Department.
Sorry about that. you know any those individuals that
you identified the previous email chain used
non-government email accounts during that time
period conduct government business?
MS. COPE-KASTEN:
Object the form.
Lack foundation.
THE WITNESS:
No, dont know any
them did. MR. BEKESHA:
Okay.
Besides email communications, you recall
during that same time period there were other
ring types communications, you sent
received text messages between that time period
about these talking points?
MS. SHAPIRO:
Object form.
MS. COPE-KASTEN:
Same objection.
THE WITNESS: dont remember sending
No,
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019
any t~xt messages. MR. BEKESHA:
How about Blackberry messages? Blackberry messages.
Chat messages
Oh, Blackberry messages meaning emails? guess Blackberry pins. dont remember sending any those that
Chat messages anything else instantaneous
written communication?
No,
time period.
the short BBM
messages?
You know,
No, dont think used chat during time the
State Department.
Okay.
Thank you. believe you told the Benghazi
select committee that lot people from the State
Department were involved making sure these talking
points said what they wanted them say.
recall who some those individuals were? you
MS. SHAPIRO:
Object form.
THE WITNESS:
Well, you sent this you
showed this document earlier which contains
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019
the relevant three bullets which think are
what youre referring the talking points.
MR. BEKESHA:
Yes.
THE WITNESS:
And this email chain were
the people who were asked review and sign
off those talking points, and they represent
individuals from across various agencies the government. MR. BEKESHA:
Okay.
Were there other individuals besides yourself the State Department that was specifically
involved either creating signing off the
talking points?
Nobody the State Department was part creating
the talking points. the CIA.
What about revising them making comments them?
Okay.
The talking points were created dont remember other people weighed the
talking points.
Its very possible that they did. revisions these,
were change mission change consulate
you can see this document,
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019
mi;;sion diplomatic post_, _because wasnt
technically consulate, and add which was
missing the third tick. didnt want didnt want suggest that
there was any substantive changes.
Were not here
for that, and know youve answered lot
questions from lot different people around
that.
have talked to.
mean anything substantive,
there. just trying figure out who you may when said revisions didnt
just what the paper just wondering you talked anybody
else, you emailed anybody else about the talking
points, not dont care about the substance
what was changing and what wasnt.
MS. COPE-KASTEN:
MR. BEKESHA:
You may answer the question.
THE WITNESS: far remember, when
Object the form.
these points came said they looked fine
except for these changes.
consulting with anybody else them.
MR. BEKESHA: dont recall
Mark this Exhibit
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019
(Exhibit marked for identification.) MR. BEKESHA:
Have you had chance review the exhibit?
Yes.
For the record,
this appears email chain,
the top email from Cheryl Mills dated September 29,
2012, 1:18 p.m.; that correct?
Yes. you recall this email chain? do. you recall what its about? general. recall this email chain, yeah. mean, couldnt tell you what the
specific words are, all which are blocked,
couldnt tell you.
Yeah, dont care about
But general, generally, what was about? was effort provide Secretary Clinton with
yes, could tell you.
some points she could use for conversation with
Senator McCain the aftermath the attack
Benghazi and the governments response it.
Okay.
And the top email here appears email
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019 Cheryl Mill-5 providing_ sDme _tho_ugh_ts tho_s_e
points?
Thats right.
Who Cheryl Mills?
Cheryl Mills was the chief staff the State
Department.
Okay.
Yes,
And the last person Phillip
Philippe Reines, completely got that wrong.
Thats okay.
Who he?
Philippe Reines was the Deputy Assistant Secretary
And youre this email well? am.
(sic)
Reines?
yes.
for Public Affairs State.
Okay.
Looking the line this email,
says jake.sullivan, and theres part redacted.
you know that your personal email address? believe is.
Okay. you know why Ms. Mills was sending this
your personal email address?
MS. COPE-KASTEN:
Objection.
PLANET DEPOS
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Calls for
Transcript Jacob Sullivan
Conducted April 16, 2019
speculation.
Lack foundation.
MR. BEKESHA:
You may answer the question.
THE WITNESS: dont know. sent the
points, you can see from the subsequent
email,
Secretary Clinton and Cheryl.
speculate why she may have used her
personal email.
from State Department account have would note this all transpired
Saturday but couldnt tell you why she was
writing from her personal account. MR. BEKESHA:
Did she write from her personal account your
personal account often?
MS. COPE-KASTEN:
MR. BEKESHA:
You may answer the question
THE WITNESS:
She did from time time. MR. BEKESHA:
Did you ever have any discussions with her about use non-State Department email accounts?
Vague. wouldnt say was often.
Objection. dont remember talking her about it, no.
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019
Okay you now who Dave Adams is?
Yes.
Who he? was the Assistant Secretary for Legislative
Affairs yes,
secretary.
Legislative Affairs the State Department.
Okay. believe was the assistant was senior official involved with
Was involved discussions about the
talking points between Benghazi and this time
Ambassador Rice went the Sunday shows? dont remember.
Its possible that was
email chain but dont remember was
not.
Okay.
Victoria Nuland was the spokesperson the State
How about who Victoria Nuland?
Department.
Okay.
Was she involved with the either reviewing looking just discussing the talking points
between Benghazi and the time Ambassador Rice went the Sunday shows?
MS. COPE-KASTEN:
scope.
Objection.
Lack foundation.
PLANET DEPOS
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Beyond the
Transcript Jacob Sullivan
Conducted April 16, 2019
THE WITNESS:
She raised questions,
recall, about the original draft the talking
points basically saying, you know,
going here?
these things?
But beyond that,
involved.
This doesnt sound right me. dont remember her being you remember that was done over email
person over the phone?
What are you trying with MR. BEKESHA:
What believe was done over email since there were
multiple hours testimony many people about
that particular email.
testified it.
discussions from from her beyond that set
exchanges.
She testified it. dont recall any other going switch gears little bit now
Okay. you recall that accountability review
board was set after the Benghazi terrorist
attack?
Yes.
Were you part that process all?
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019 was think the accountability review board dont
spoke part that process.
recall, but believe that had speak with them, did all the other senior officials. you recall you provided them with any
documents? dont remember. you recall you reviewed assembled any
documents anybodys during that time period
provided the board? dont remember doing that, you recall you destroyed any documents prior the accountability review board?
no. would remember destroyed any documents.
did not.
Okay.
Similarly, Secretary Clinton testified before
Congress part about Benghazi for quite some time, long period time.
preparation for her testimony?
Were you involved the was.
Did you provide any documents Secretary Clinton anyone else preparation for that testimony?
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019
MS. COPE-KASTEN:
Objection.
Beyond the
scope.
MR. BEKESHA:
You may answer the question.
THE WITNESS: dont think provided
documents her,
preparation sessions where asked her very
difficult questions playing member
Congress, but dont remember providing any
documents her. remember being MR. BEKESHA:
no. you remember reviewing any documents?
MS. COPE-KASTEN:
Objection.
Beyond the
scope.
THE WITNESS: documents but,
what they were.
accountability review board report and previous
Benghazi material from the hill, but you know, dont know exactly what that
reviewed.
you know, mean, couldnt tell you sure read the MR. BEKESHA: remember reviewing lot
Okay.
More generally, when Congressional did you
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019
ever_ respond -=-:- did you ever search for. rec_ards,
your own records,
inquiries subpoenas while you were the State
Department? response any Congressional
MS. SHAPIRO:
Object form.
THE WITNESS:
Yes. response Congressional requests. provided documents MR. BEKESHA:
Okay.
Were those your own records did you review
records for someone else?
No,
Okay.
just own records
What about response FOIA requests?
you ever search your records respond FOIA
requests? SHAPIRO:
MS. COPE-KASTEN:
THE WITNESS:
Did
Object form.
Same objection. dont remember ever being
asked look for records relation FOIA
requests. MR. BEKESHA
Did you ever review search Secretary Clintons
records response FOIA request
PLANET DEPOS
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Transcript Jacob Sullivan
Conducted April 16, 2019
Congressional inquiry during her during your time
period the State Department?
MS. SHAPIRO:
MS. COPE-KASTEN:
THE WITNESS:
Object relevance.
No. MR. BEKESHA:
Object form. you know who would have searched Secretary
Clintons records? dont.
When you started the State Department, did you
receive FOIA training? dont remember receiving FOIA training, you recall receiving any FOIA training during any your time the State Department? dont remember receiving FOIA training.
Okay.
Did you ever receive records management
training?
no. dont remember any records management training.
had general sense of,
you know,
maintaining records, but dont remember any
training.
the idea
11I
What you mean that?
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Jus hat was conscious not deleting the emails
from my, you know, sent and received, but
destroying documents removing documents
anything like that.
Okay.
Besides training, did you ever receive any
memos guidance any type paper regarding
regarding records management issues? dont remember.
Okay.
What about when you left the State
Department?
training about what you could could not take with
you?
Did you receive any guidance moved from the State Department directly the
White House just went from one the other,
dont remember guidance training the course
making that transition.
wasnt actually leaving government service, and
Okay.
Did you ever receive guidance instruction
about using non-State Department email accounts
conduct official government business? dont remember any specific training about it,
no.
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Okay. guidance
Did you use
during your tenure the State
Department, did you use non-State Department email
accounts conduct official government business? did. used State Department account
predominantly but did use Gmail.
Did you have clintonemail.com email account?
No. you know how much email you sent using your Gmail
account for state when ask these questions
its always about conduct official State
Department business.
can get long and winded.
your Gmail account only asking about the use
State Department business.
MS. COPE-KASTEN: can keep saying but whenever refer
Object the form
the question.
THE WITNESS: dont know. just
know was small fraction the overall
email that sent and received but couldnt
give you number.
Ive seen the catalogue
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what gave _the_S_ta_te Department__ hut _that, course, also included was interspersed
with lot personal messages well,
dont dont have fixed number for you. MR. BEKESHA: you know how often you would have used it, the
Gmail account?
Like said, predominantly relied State
Department emails, terms overall email
use would have been small percentage the
time.
Did you email specific people when using the Gmail
account would you just email whoever you needed for State Department business?
MS. SHAPIRO:
Objection form.
THE WITNESS: the course job
traveled considerable amount, traveled with
Secretary Clinton 112 countries, was the
road quite bit, and was typically when
traveling nights and weekends when would
use Gmail and there wasnt set group
people that emailed. would whenever
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important immediate business needed get done emailed wide range officials the
State Department. MR. BEKESHA:
Did you any point during your tenure the
State Department did you talk anybody about your
use Gmail that time?
about use Gmail, no. dont remember talking people specifically
Okay.
Did you ever ask for permission approval so? dont remember doing that.
When you left the State Department, went work for
the White House, did you provide the State
Department with emails from your Gmail account? did not that until later.
And when did you that?
That was the first half the summer 2015,
believe.
Okay.
And how did you return them?
Can you more specific?
Sure. sorry.
How did you decide which emails return?
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asked them review that they could take
look every email sent and received over the
entire period time the State Department and
make sure that anything that even remotely resembled federal record could turned over State.
Did they review your records one one?
MS. COPE-KASTEN: going object here
and remind Mr. Sullivan that anything
aware between what you did, what your
attorneys did,
privilege,
without touching that,
Otherwise,
privilege.
conversations attorney/client the extent that you can answer
you may so. going object the basis
MR. BEKESHA:
You can answer the question.
THE WITNESS:
Just have sense
this privilege thing, you mind
have word with
MR. BEKESHA:
No. you want take
minute?
MS. COPE-KASTEN:
just
Sure.
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MR. BEKESHA:
VIDEOGRAPHER:
the record 9:32 a.m.
Off the record.
Please stand by.
(Recess taken.)
VIDEOGRAPHER:
Going off
Going back the record
9:36 a.m.
MS. COPE-KASTEN:
Mr. Bekesha, think
were okay here but you could ahead and
reask your same question Mr. Sullivan?
MR. BEKESHA:
Sure. MR. BEKESHA:
Did they review your records one one? dont know. you know besides what your attorneys may have
told you about the process that they went through?
No.
All know that said earlier,
gave them access Gmail in-box, and the idea
was that they could through the entirety
in-box,
resembled federal record, that and turn over the State Department.
And then have further visibility into the
identify anything that even remotely
take expansive view
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_____pLocess what _they~did ___ L_to_0_k _my-SBli __crn_t___QL it,
The next thing saw was the document that was
produced advance today from State saying weve
got this many records.
were things that went beyond federal records and
included personal records,
Okay.
Included among these records thats all know. you know all federal records from your
Gmail account were produced the State
Department? believe they were.
Okay. you know that for certainty you just
believe so? have strong confidence that given the instructions
and the process, that for that four-year period from
start finish, federal record was turned over the State
Department.
every document that have that was
MR. BEKESHA:
Okay.
Thank you.
Let
introduce this Exhibit
(Exhibit marked for identification.)
THE WITNESS:
Would you like read
the whole document?
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MR. BEKESHA:
Sure. going point few but you feel more comfortable reading
the whole thing now, ahead.
just point you couple paragraphs and you
can take time read those paragraphs then
you want.
sense you.
Whatever whatever makes the most
THE WITNESS:
Otherwise, Ill
Why dont that?
Because, mean,
its five pages, you
want point specific things and then
need take little time look
MR. BEKESHA:
Sure.
THE WITNESS: the context that,
can that. MR. BEKESHA:
Not problem.
Just for the record, Exhibit
State Department memo dated August 11, 2015 with the
subject Jake Sullivans July 30th, 2015 response
Under Secretary Kennedys March 11, 2015 letter;
that correct? does,
Okay. that what this appears be?
yeah.
Have you seen this before?
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Yes.
This the document that was referring to. just saw when was produced the last
couple days.
And who was produced by? believe was produced the government.
Okay.
Ill have you turn
this one isnt
page numbers, but page three.
there with the breakdown documents year and
type described the table below.
that?
Yes,
Okay.
Theres chart you see that chart says total from January
22nd, 2009 February 24th, 2013.
that? you see that what your date range your
employment the State Department?
That yes.
Okay.
Were there any additional days that you were the State Department besides that time period? SHAPIRO:
Objection form.
THE WITNESS:
Not that recall.
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those are the dates service. MR. BEKESHA:
Okay. the chart says that there were 9,585
email documents that were produced.
that? you see do. you know that accurate number? have idea
All know that think thats over-inclusive number based what the document
goes say, which that there are instances
personal communications that relate solely
private affairs.
couldnt tell you thats accurate number
not federal records.
Okay. think that you know,
Moving the next page, the last you want take
paragraph that page.
moment read it, then have question about it.
Yeah.
Okay.
Towards the end the paragraph says,
This
collection includes email correspondence between
Mr. Sullivan, Ms. Cheryl Mills-- going
mispronounce.
Reines, you said?
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Reines. Reines and others conducted solely personal
accounts. just had question about when you sent email
from your Gmail account,
did you try send
would you often send other non-government
email accounts?
MS. COPE-KASTEN:
Object the form
the question.
MS. SHAPIRO:
Same objection.
THE WITNESS: understand your
question,
send from Gmail someone elses non-State
email.
sent State Department accounts, but there
are instances that that aware of, yes.
there would times when would
Those were not frequent. typically MR. BEKESHA:
When you did that, did you anything ensure
that those records would make their way into State
Department record systems?
MS. COPE-KASTEN:
Object the form
the question.
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THE WITNESS: the time some, but not
all cases.
emails through lawyer search turn over
the State Department which is, you know, how
theyre reflected and included this document
here. MR. BEKESHA:
Sure. the end, captured all those you did while you were employment
the State Department try get them into the State
Department system, how would you so?
MS. SHAPIRO:
Object form.
MS. COPE-KASTEN:
THE WITNESS:
Same objection.
Well, frequently either emailing another State Department account
myself the State Department system well, would forward emails the State
Department account, State Department
account. MR. BEKESHA: you recall who else the State Department used
non-State Department email accounts conduct
official government business?
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A..
___
=---I_couldn-t.giv_e_you_a_lisL.of_names_. L.m_____
sorry. there anybody particular that you recall that
you would receive emails from that were from
non-State Department email account8?
MS. COPE-KASTEN:
THE WITNESS:
Objection.
Vague. mean, you know,
obviously
just having read this paragraph, Cheryl and
Philippe would sometimes send emails from their
personal accounts.
well.
time time, you know, people use personal
email accounts but couldnt tell you who. think others would
You know, recollection that from MR. BEKESHA:
Would you say using personal email accounts was the
norm, something that people just frequently that
people just did?
MS. COPE-KASTEN:
Object the form
the question.
MS. SHAPIRO:
Objection form.
THE WITNESS: wouldnt say was the
norm.
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Transcript Jacob Sullivan
Conducted April 16, 2019 MR. BEKESHA:
You said that for majority your emails you
would use State Department email account?
Yes.
Why was that?
Because thought that the kind standard
operating procedure the ordinary course
business, there werent reasons related
expeditiously being able carry out functions the Deputy Chief Staff, that using the State
Department system was the natural normal thing for do, and did it.
Did you ever think about the Freedom Information
Act while you were using State during your time the State Department? did not.
Okay.
Was your personal email account ever
hacked?
MS. COPE-KASTEN:
Objection.
Beyond the
scope.
MR. BEKESHA:
You may answer the question.
THE WITNESS: dont dont know.
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dont not aware o_f _it being hack_ed MR. BEKESHA:
Okay. you know that Ambassador Stephen Mull said
that thought your email was compromised
2011?
MS. SHAPIRO:
MS. COPE-KASTEN:
Objection form.
Objection.
Beyond the
scope.
prongs Judge Sullivans discovery order you
think this goes to, Mr. Bekesha?
Can you help understand which the
MR. BEKESHA: prong one.
And can
move the questions along and see
MS. COPE-KASTEN:
Secretary Clintons email?
his understanding what happened his
own email account?
MR. BEKESHA: the prong
Youre asking about just wondering
happened, not his understanding it.
MS. COPE-KASTEN: going continue
assert that this beyond the scope.
answer the extent that you know.
THE WITNESS:
You may not exactly familiar
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with what youre talking about. MR. BEKESHA:
Okay.
Did you ever have any conversations with
Secretary Clinton about your personal email account
being compromised hacked?
MS. SHAPIRO:
MS. COPE-KASTEN:
THE WITNESS:
Beyond the
No. MR. BEKESHA:
Objection.
scope.
Objection form.
What about conversations with Cheryl Mills about
that topic? COPE-KASTEN: SHAPIRO:
Objection form.
THE WITNESS:
No.
MR. BEKESHA:
Okay.
five-minute break?
little bit.
VIDEOGRAPHER:
the record 9:47 a.m
(Recess taken.)
VIDEOGRAPHER:
Why dont take
Were switching gears
Same objection.
Please stand by.
Going off
Going back the record
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Transcript Jacob Sullivan
Conducted April 16, 2019 ._m MR. BEKESHA:
When did you start the State Department,
Mr. Sullivan? January 2009.
Okay.
Deputy Chief Staff.
Okay. was responsible for the kind organization and
And what was your title?
And what was your general responsibilities?
management the policy-making process the State
Department which meant advising the Secretary
directly policy issues were surfaced her
level, and working with the bureaus and embassies
they were developing policy recommendations for
her.
And when did you leave the State Department go,
guess, the White House? left February 2013.
Okay.
And did your job title stay the same during
that time period?
About halfway through became the Director
Policy Planning.
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And just very briefly, what were your
responsibilities there?
Okay.
The policy planning staff the State Department
responsible for medium and long-range planning
State, looking beyond the immediate day day
broader trends,
policy.
themes and strategies and foreign
And these positions did you travel with Secretary
Clinton? did. mentioned before, traveled with her 112 countries. you spent lot time with her? did.
Would you consider yourself gate-keeper her?
MS. COPE-KASTEN:
THE WITNESS: wouldnt consider myself
gate-keeper anybody. MR. BEKESHA:
Okay.
Did you ever see Secretary Clinton use
Blackberry?
Object the form
the question. did.
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know what email account was that State was
that Blackberry?
Yes.
And what was that email accounL? was clintonemail.com email account.
When did you first become aware that email
account?
Right around the time that came the State
Department.
And how did you learn what the email account was? dont remember.
Did Secretary Clinton have State Department email
account?
Not that aware of.
Okay.
Did you think that was unusual?
MS. COPE-KASTEN:
THE WITNESS:
Objection.
Relevance. didnt think much about
it. job responsibility,
State having worked for Secretary Clinton
before she was the State Department and when
The her email practices werent part
and had come
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she was the Senate, and she had personal
email account the Senate well other
members Congress did.
over and kept using personal email account, didnt really occur that there was
anything unusual about it. when she switched MR. BEKESHA:
Did you ever talk her about her email account?
No.
Did you talk anybody while you were the State
Department about Secretary Clintons email
account?
MS. COPE-KASTEN:
THE WITNESS:
Objection.
Relevance.
About her email account? MR. BEKESHA:
About the email account?
Not that remember, no.
Okay. any point during your tenure the State
Department were you concerned about FOIA records
management when came Secretary Clintons email
account?
MS. SHAPIRO:
Objection form.
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Conducted April 16, 2019 MS~ COPE-KASTEN~
THE WITNESS:
Sam~__ objection~ wasnt.
And dont mean say that mean dont think its matter concern.
focused job responsibilities which weLe
centrally about the and fro policies
including the crises that were dealing with daily basis. MR. BEKESHA: mean say that was
Did you ever send classified information
Secretary Clintons email account? dont believe did, no.
MR. BEKESHA:
Okay.
Lets ahead and
mark this Exhibit
(Exhibit marked for identification.)
MS. COPE-KASTEN:
Mr. Bekesha, you know there were additional pages this email this the end the document?
MR. BEKESHA: think its the end the
document based how pulled off the State
Departments website.
THE WITNESS:
Okay.
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Conducted April 16, 2019 MR. BEKESHA:
Have you had chance review the document?
Yes. appears whats marked Exhibit
email from you Huma Abedin and Hillary Clinton
dated January 26th, 2010, with the subject, Call
sheet; that correct?
Right. you know you sent this from your personal
Yes.
email account your State Department email
account? not hundred percent sure but looks like
its from personal account.
Okay. you recall sending this email? dont specifically remember it, no.
Okay. you know you recall why you sent
from your Gmail account what appears
well, Hillary Clintons email account but also Huma
Abedins clintonemail.com email account?
MS. SHAPIRO:
Object form.
MS. COPE-KASTEN:
THE WITNESS:
Same objection. couldnt tell you why
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specifically sent this email from personal
account, no, but would note that appears
that theres attachment this
very possible that order for not just
send email Blackberry but send from desktop laptop,
difficulty getting onto the State Departments
system.
MR. BEKESHA:
that may have had
Okay.
Lets mark the next
exhibit Exhibit
(Exhibit marked for identification.)
THE WITNESS:
Okay. MR. BEKESHA:
Perfect.
Exhibit appears email from
Hillary Clinton you dated September 25th, that correct?
2010;
Yes. email chain with that being the top email?
Right.
Okay. dont.
Okay. you recall this email? you can see the first email,
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like you sent email Secretary Clinton using
your State Department email account; that
correct?
Yes.
And then Secretary Clinton responded your email
but sent your personal email account?
Right. the body the email she says shes doing
because email glitches? you see that? do. you know what shes referring there? dont.
MS. COPE-KASTEN:
foundation.
Lack
Calls for speculation. MR. BEKESHA:
Objection. you recall there were email glitches
Secretary Clintons email during her time the
State Department?
MS. COPE-KASTEN:
Objection.
Lack
foundation.
THE WITNESS: dont really have memory email glitches.
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MR. BEKESHA:
Okay.
(Exhibit marked for identification.)
THE WITNESS:
Okay MR. BEKESHA:
Exhibit appears email from Ruma Abedin
you and Cheryl Mills dated January 10th, 2011;
that correct?
Yes. the subject the email says,
HRC anything sensitive.
person; that correct?
Dont email can explain more
Thats what says the subject line, yes.
Okay. dont.
Okay. you recall this email? you know what its referring to?
MS. COPE-KASTEN:
foundation.
Objection.
Lack
Calls for speculation.
THE WITNESS: actually dont.
MR. BEKESHA:
Okay. can move
Exhibit
(Exhibit marked for identification.)
THE WITNESS:
Does this on?
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MR. BEKESHA: dont believe so.
looks like the top the document cut off
from the printers, but not not that
aware of.
THE WITNESS:
Okay.
Okay. MR. BEKESHA:
Have you had chance review the record?
Yes. appears Exhibit appears email from
Hillary Clinton you dated June 17th, 2011,
email chain with that being the top email; that
correct?
Thats correct.
Okay.
The top the email says, they cant
turn into non-paper with identifying heading
and send non-secure. you see that? do.
What does that mean? non-paper phrase did not know until went the State Department.
you typically share with foreign government,
its document that doesnt contain classified non-paper document
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information thats. unclass do_c _that doesnt have
anything that denotes something official.
its kind unofficial presentation that can
shared with others. what Secretary Clinton was asking
was take the material that had and turn into
this kind non-paper with identifying heading.
What does she mean send non-secure?
Well, what shes referring that she couldnt
get the secure fax work, you can see the
next email down,
material she could non-secure consistent with
not containing classified information. she wanted get much the
MR. BEKESHA:
Okay.
(Exhibit marked for identification.) MR. BEKESHA:
Have you had chance review the exhibit?
Yes.
And Exhibit email chain. the top
email from Huma Abedin you dated July 22nd, 2011; that correct?
Yes.
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Okay. you recall this email chain? not.
Okay. dont. you know what its about? see the subject line says, Draft high
level narrative and work plan, but dont know
what that refers to.
Okay.
After the subject also says brackets,
Note use personal/Gmail. do. you know why says that? dont.
email.
Okay.
That was written the initial dont know what that refers to.
Did you receive emails often from Ms. Mills
that had that connotation?
Not that remember. you recall any email you see that?
any emails which she
made point noting use personal/Gmail?
Well, looking one but thats not notation
thats familiar me. you know this was non-State Department work? dont.
Were all set with that email. dont.
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Conducted April 16, 201 _Do you kn_ow who the s_tate Department knew
Secretary Clintons email address?
MS. COPE-KASTEN:
Objection.
Lack
foundation.
THE WITNESS: couldnt tell you exactly
who, but significant number officials
the State Department were sent emails her
personal email address and received emails from
her personal email address MR. BEKESHA: you know was secret well-guarded COPE-KASTEN: SHAPIRO:
Objection the form.
Objection form. MR. BEKESHA:
her email account? was not secret well-guarded. was widely
known among relevant senior officials the
department and even beyond the department because
Secretary Clinton was emailing with number
different individuals and from her
clintonemail.com email account.
You mentioned earlier that you saw Secretary Clinton
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with Blackberry.
devices any time?
Did you see her with any other
MS. COPE-KASTEN:
THE WITNESS:
Objection.
Vague. remember her occasionally
having iPad with her trips that took. MR. BEKESHA:
Would she also have her Blackberry the same
time? not actually sure.
Okay.
Did you ever see her use flip phone
another cell phone? flip phone?
Yes.
No.
Okay.
No. you know who Justin Cooper is? do.
Who he? worked for, maybe still works for President
Clinton.
Did you have any contact with him regarding
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Se_cretary Clintons_ email account.R? did not.
Okay. do.
Who he? worked for Secretary Clinton her campaign and you know who Bryan Pagliano is?
then worked the State Department information
technology-related issues.
Okay.
Did you ever speak with Mr.
Pagliano about
Secretary Clintons email account?
Not that recall, no.
Okay.
Did you ever speak with while you were
the State Department, did you ever speak with Huma
Abedin about Secretary Clintons email account?
Not about her email account, imagine you talked her about lot different
things,
Yeah,
no.
though? talked her pretty much every day about
lot different things largely related the
intersection between our two jobs which were sort
operations and policy.
Did you ever talk her about records management
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emails more generally? dont dont remember having any conversations
with her about that.
Did you ever speak Ms. Abedin about FOIA?
No, not that can remember.
Okay.
Did you ever speak Ms. Mills while you
were the State Department about Secretary
Clintons email account?
Not about her email account, no.
What about records management the Freedom
Information Act? dont remember talking Cheryl about FOIA
either.
Okay. you know who Heather Samuelson is? do.
Who she?
She lawyer.
Well, did she work the State Department when you
were the State Department?
She did. you know what her job title was?
Actually, dont know what her job title was.
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Conducted April 16, 2019 you know wha_t her responsibi-1i ties role was
generally?
She came into the State Department working issues
related the White House liaison which meant that
she worked get individuals onboarded for both
appointments and Senate-confirmed positions.
Okay.
While you were the State Department did
you ever talk Ms. Samuelson about Hillary
Secretary Clintons email account?
No.
Did you ever speak with her about records management FOIA? the State Department?
While you were the State Department.
No. you know Secretary Clinton had SCIF one both her houses? believe she did, you know her email server was the SCIF?
yes.
MS. COPE-KASTEN:
Objection.
Lack
foundation.
THE WITNESS: didnt know she had
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Transcript Jacob Sullivan
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email server until became public 2015, have idea where was. MR. BEKESHA:
Okay.
Were going move couple discussions
after you left the State Department. you need take break before change gears
little bit? okay.
Okay. dont know
Great.
After you left the State Department did you
speak with Cheryl Mills about Secretary Clintons
email account?
MS. COPE-KASTEN:
And again here, just
going caution Mr. Sullivan that the
extent that you had conversations with
Ms. Mills that were her capacity
attorney, that would privileged information
and going instruct you not answer
that basis, but you can answer without
getting into that, ahead.
THE WITNESS: remember conversation
the summer 2014 where the subject turning
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Transcript Jacob Sullivan
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over all Secretary Clintons emails came
but dont remember the specific details
that conversation. MR. BEKESHA: Ms. Mills one your attorneys?
One attorneys?
Yes.
Shes not.
Has she ever represented you?
Represented me?
Yes, your attorney.
No. you recall when the summer 2014 that
conversation took place? afraid dont. you recall was over the phone person email? was either over the phone person.
wasnt email because remember speaking with her
about it.
have been over the phone. think was person but might you know anybody else was that part
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Transcript Jacob Sullivan
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that conversation? dont remember.
us. not sure.
Okay. think was just the two
There might have been someone else there but
And you dont really recall the specifics,
what you discussed?
No.
Just what stuck out me, the reason
remember because remember having
discussion which left and thinking, okay, you
know,
her emails the State Department.
was pretty much what took away from that
conversation.
Okay.
Secretary Clintons going produce all
Thats
Was there any discussion that time about
your own personal email account?
Not that time, no.
Okay.
Were you part that did Ms. Mills ask
you participate reviewing any records
sorry, any emails Secretary Clinton that
time?
that
Heather Samuelson, who you mentioned earlier,
reached out some point say,
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Yeah,
Transcript Jacob Sullivan
Conducted April 16, 2019
may need you look some records see
theyre federal records not, but then never
followed didnt participate records
review.
And when did that conversation take place? think was the fall 2014, but honestly,
couldnt even pinpoint month.
Any idea how much what time period lapsed between
your conversation with Ms. Mills and
Ms. Samuelson? dont know. didnt think them directly
related.
Okay.
How did you have that conversation with
Ms. Samuelson?
person?
Was phone?
MS. COPE-KASTEN:
THE WITNESS:
Objection.
Relevance. dont dont MR. BEKESHA: email?
remember. you know anybody else was part that
conversation? dont think so, no. think think she was
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Transcript Jacob Sullivan
Conducted April 16, 2019
asking stand by, needed, look it.
And did you ever look any records?
No,
records over the State Department. didnt participate the process turning
Besides these besides the summer 2014, have
you spoken with Ms. Mills any other point about
Secretary Clintons emails? you might imagine, the subject Secretary
Clintons emails has come many times
conversation with Ms. Mills, but mostly regard
the fact that was topic conversation among
the entire country, not anything special about
Cheryl and talking about it.
When was the last time you spoke with Ms. Mills
about this topic?
MS. COPE-KASTEN:
THE WITNESS:
Objection relevance.
You know, sitting here today sad say havent talked Cheryl
too long, and about this topic
considerable amount time.
you how long. couldnt tell MR. BEKESHA:
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Transcript Jacob Sullivan
Conducted April 16, 2019
Okay.
What about Ms. Samuelson?
Besides the fall 2014, did you speak her any other point
about Secretary Clintons emails?
Same thing with with Cheryl.
Unfortunately,
emails has been topic conversation with and
just about every waking person that Ive encountered the past several years, but nothing particularly
distinctive about conversations with Heather
Samuelson.
Okay.
the subject Hillary Clintons
When was the last time you spoke with her
about Secretary Clintons emails?
About Secretary Clintons emails?
Yeah.
You know, commiserated with her about having
depositions this particular litigation recently
but havent had substantive conversation with
her about Secretary Clintons emails dont
know.
Did you talk about your testimony today with her?
Only insofar said that was having
deposition today and she wished good luck and
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Transcript Jacob Sullivan
Conducted April 16, 2019
wished her good luck hers but didnt
didnt talk about the substance it.
Okay.
No, hasnt.
Hopefully today hasnt been too painful.
MR. BEKESHA:
Thank you.
Why dont take
five-minute break and then well come back, and have couple more questions and some
clean-up and then well good go.
VIDEOGRAPHER:
Please stand by.
the record 10:20 a.m.
(Recess taken.)
MR. BREWSTER:
Did you want the
transcript order?
MS. SHAPIRO:
COURT REPORTER:
What would you like?
Going off think thats the end.
MR. BREWSTER:
Yes, sure. ahead.
Well take one
non-expedited.
COURT REPORTER:
And how would you like
your transcript?
MR. BEKESHA:
Expedited, please.
COURT REPORTER:
And print electronic?
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Conducted April 16, 2019
MR. BEKESHA:
COURT REPORTER:
MR. BREWSTER:
MR. PEZZI:
Electronic fine.
And electronic for you?
Yes, please.
Well take expedited
although the last time through you guys think
you had send draft invoice.
thats thats, your view, what
required,
feel free send the email
address that have there.
take expedited whenever these guys get it.
COURT REPORTER:
electronic for you okay?
MR. PEZZI:
COURT REPORTER:
VIDEOGRAPHER:
10:29 a.m. MR. BEKESHA:
Otherwise, well
Thank you.
And
Perfect, yeah.
Okay.
Thank you.
Going back the record
Mr. Sullivan, besides your attorneys, have you
spoken anyone else about your testimony today? wife.
Did you talk substance with her just that you
were had the deposition today?
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Transcript Jacob Sullivan
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Mostly just that had the deposition.
Okay.
And you didnt speak anybody else about
substance todays
No.
Okay. preparing for todays testimony,
did you
review any documents records?
MS. COPE-KASTEN:
Objection. remind
Mr. Sullivan that anything that reviewed
connection with your lawyers privileged
information,
answer with respect that. MR. BEKESHA:
and instruct you not
Did you review any records that werent provided
your attorneys? did not.
Okay.
You mentioned earlier that you received
least one record from the State Department; that
correct?
Yes.
Did you receive others?
Yes. received binder information that
believe was produced you.
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Transcript Jacob Sullivan
Conducted April 16, 2019
MS. SHAPIRO: just going obje~t on_
the same grounds attorney/client privilege,
that anything that his attorneys from the State
Department would have provided him would also privileged.
MR. BEKESHA:
Okay. MR. BEKESHA:
Have you spoken Secretary Clinton after she left
office about her use email?
MS. COPE-KASTEN:
THE WITNESS:
Yes. MR. BEKESHA:
When was the last time you spoke her about her
use email, about the issue?
MS. COPE-KASTEN:
Beyond the scope
THE WITNESS:
Objection relevance.
Objection relevance.
Long time ago. MR. BEKESHA:
Okay.
Did you speak have you spoken you
mentioned that before todays testimony you havent
spoken Ms. Abedin Ms. Mills about your
testimony today.
Did you speak their attorneys
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Transcript Jacob Sullivan
Conducted April 16, 2019 the capacity being their attorneys?
theres some overlap there.
MS. COPE-KASTEN:
Objection. know
Vague.
Can
you maybe restate that question?
MR. BEKESHA:
Sure. MR. BEKESHA:
Have you have you spoken Ms. Abedins
attorneys about the email issue recently?
No.
Have you spoken Cheryl Mills attorneys, her
attorneys, about the email issue?
MS. COPE-KASTEN:
Objection relevance.
And again, think were getting into
attorney/client privilege issue here the
extent that theres overlap here, just
going instruct him not answer cant that without getting into privileged
communications.
THE WITNESS: guess, suffice say, havent talked Cheryl any her
representatives about Cheryls and
Cheryls anything about this case.
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Trying
Transcript Jacob Sullivan
Conducted April 16, 2019 avoid the attorne /client issue.
MR. BEKESHA:
its complicated.
THE WITNESS:
Sure, thats fine. know
The spirit the answer
your question least no.
MR. BEKESHA:
Thats all was
asking.
Okay. MR. BEKESHA:
Have you spoken anybody the State Department
since you left the State Department about Secretary
Clintons email use?
Other than speaking the attorneys present here
today briefly yesterday and the phone briefly
few days before that, no.
Okay.
Oh, wait.
Let let back up.
Since Ive
left the State Department?
Since you left the State Department.
Well, okay, again, same answer before. mean,
have former colleagues from the State Department,
and the subject Hillary Clintons email use
obviously came over the course 2015 and 2016.
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Transcript Jacob Sullivan
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Preparing for the deposition today, besides counsel
for the State Department, have you talked anybody the State Department about your testimony
about the issue?
No.
Okay.
Yes. whom? number different people.
Are you currently employed? employed
Dartmouth College, University New Hampshire,
private consulting firm,
International Peace.
Are you employed Secretary Clinton any
capacity? not.
MS. COPE-KASTEN:
Are you employed President Clinton any
capacity?
MS. COPE-KASTEN:
and beyond the scope.
Objection relevance. MR. BEKESHA:
Carnegie Endowment for
THE WITNESS:
Objection relevance not.
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Transcript Jacob Sullivan
Conducted April 16, 2019 MR. BEKESHA:
What about Clinton Executive Services?
MS. COPE-KASTEN:
THE WITNESS:
Same objection. dont know what that is. MR. BEKESHA:
Okay.
Has Secretary Clinton anyone associated
with her offered you any future employment?
MS. COPE-KASTEN:
Objection.
Relevance.
Beyond the scope.
about here terms whats discoverable?
MR. BEKESHA:
What prong are talking
Are you instructing him not answer?
MS. COPE-KASTEN:
Not far. just struggling understand.
MR. BEKESHA:
The first prong.
THE WITNESS:
No. mean, have not been
offered any future employment Hillary
Clinton. MR. BEKESHA: Secretary Clinton anyone associated with her
paying your legal matters related your
legal bills related todays testimony?
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Conducted April 16, 2019
No.
Has Secretary Clinton anyone associated with her
paid any your legal bills related her the
matter her email use?
MS. COPE-KASTEN:
THE WITNESS:
No. MR. BEKESHA:
Objection relevance.
Has Secretary Clinton anyone else associated with
her provided you with any financial incentives
related your testimony today this matter
generally?
No.
Thats, think,
absurd its face.
You talked about that youve had seems like
everybody wants talk you some point about
Secretary Clintons emails.
regret not saying anything her during your tenure the State Department about her use non-State
Department email account?
MS. COPE-KASTEN: this point you
Objection the form
the question.
MS. SHAPIRO:
Objection.
MS. COPE-KASTEN:
Objection relevance.
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Objecti
Be_yond the scop
MS. SHAPIRO:
Same objections.
MR. BEKESHA:
You may answer the question.
THE WITNESS:
Sure. regret lot
things about the 2016 election.
this email issue blew up.
Clinton has said herself,
State Department account.
part job thinking about Secretary
Clintons emails dont think sort
fell down directly job, but wish
had thought during the time were
State?
this point wouldnt have thought that?
Okay. wish she had used wasnt really mean, what human being the best your knowledge have all your
answers been truthful today?
Yes.
Like Secretary MR. BEKESHA: course. regret that
MR. BEKESHA: have nothing else this
time.
EXAMINATION MS. COPE-KASTEN:
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Transcript Jacob Sullivan
Conducted April 16, 2019
Mr. Sullivan, you recall series questions
about your use personal email during your time
the State Department? you recall Mr. Bekesha asking you question
about whether you ever sent classified information
from your personal email account?
Yes going direct you what Mr. Bekesha marked Exhibit
line call sheet dated January 26th, 2010.
recall questions about this email?
This email with the subject you do. you understand that portions this email have some point time been identified
classified?
Yes the time that you sent this emai did you have understanding that that information was assified?
Thank you for giving the opportunity clarify
this.
When sent email, best judgment was
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that none the material was classified, and felt comfortable sending the email
unclassified system.
been upclassified but the time that sent it,
did not believe that was classified.
The material has subsequently
Are you aware any information that suggests
you that Hillary Clinton used personal email
account during her time the State Department
stymie FOIA?
No.
MS. COPE-KASTEN: have further
questions.
MS. SHAPIRO: questions from State.
MR. BEKESHA:
All set.
VIDEOGRAPHER:
All set?
Please stand by.
This marks the end the deposition Jacob
Sullivan.
a.m. are going off the record 10:38
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