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Judicial Watch Submits Proposed Witness List, Discovery Plan to Federal Court in Clinton Email...
Judicial Watch ^ | March 15, 2016 | Tom Fitton

Posted on 03/15/2016 11:27:13 AM PDT by jazusamo

Full title: Judicial Watch Submits Proposed Witness List, Discovery Plan to Federal Court in Clinton Email Matter

(Washington, DC) – Judicial Watch today filed a plan for “ narrowly tailored discovery” into former Secretary of State Hillary Clinton’s email matter with a federal court. Judicial Watch’s discovery plan seeks the testimony of eight current and former State Department officials, including top State Department official Patrick Kennedy, former State IT employee Bryan Pagliano, and Clinton’s two top aides at the State Department: Cheryl Mills and Huma Abedin. Judicial Watch’s plan says that “based on information learned during discovery, the deposition of Mrs. Clinton may be necessary” but would only occur with permission by the Court.

During a court hearing on February 23, U.S. District Court Judge Emmet G. Sullivan granted Judicial Watch’s motion for discovery into whether the State Department and Clinton deliberately thwarted the Freedom of Information Act (FOIA) for six years. The discovery arises in a Judicial Watch FOIA lawsuit that seeks records about the controversial employment status of Huma Abedin, former Deputy Chief of Staff to Clinton. The lawsuit was reopened because of revelations about the clintonemail.com system. (Judicial Watch v. U.S. Department of State (No. 1:13-cv-01363)).

Judicial Watch seeks testimony from:

Stephen D. Mull (Executive Secretary of the State Department from June 2009 to October 2012 and suggested that Mrs. Clinton be issued a State Department BlackBerry, which would protect her identity and would also be subject to FOIA requests);

Lewis A. Lukens (Executive Director of the Executive Secretariat from 2008 to 2011 and emailed with Patrick Kennedy and Cheryl Smith about setting up a computer for Mrs. Clinton to check her clintonemail.com email account);

Patrick F. Kennedy (Under Secretary for Management since 2007 and the Secretary’s principal advisor on management issues, including technology and information services);

Donald R. Reid (Senior Coordinator for Security Infrastructure, Bureau of Diplomatic Security since 2003 and was involved in early discussions about Mrs. Clinton using her BlackBerry and other devices to conduct official State Department business);

30(b)(6) deposition(s) of Defendant [designated witness(es) for the State Department] regarding the processing of FOIA requests, including Plaintiff’s FOIA request, for emails of Mrs. Clinton and Ms. Abedin both during Mrs. Clinton’s tenure as Secretary of State and after;

Cheryl D. Mills (Mrs. Clinton’s Chief of Staff throughout her four years as Secretary of State);

Huma Abedin (Mrs. Clinton’s Deputy Chief of Staff and a senior advisor to Mrs. Clinton throughout her four years as Secretary of State and also had an email account on clintonemail.com); and

Bryan Pagliano (State Department Schedule C employee who has been reported to have serviced and maintained the server that hosted the “clintonemail.com” system during Mrs. Clinton’s tenure as Secretary of State four years as secretary).

With respect to testimony of Clinton, the Judicial Watch court filing states:

Based on information learned during discovery, the deposition of Mrs. Clinton may be necessary. If [Judicial Watch] believes Mrs. Clinton’s testimony is required, it will request permission from the Court at the appropriate time.

Judicial Watch also seeks court approval of written questions requiring answers under oath by the State Department:

Who was responsible for processing and/or responding to record requests, including FOIA requests, concerning emails of Mrs. Clinton and other employees of the Office of the Secretary;

Who was responsible for the inventorying or other accounting of Mrs. Clinton’s and Ms. Abedin’s emails, records, and information;

Who was responsible for responding to Plaintiff’s FOIA request from the date of submission to the present; and

Which State Department officials and employees had and/or used an account on the clintonemail.com system to conduct official government business.

Judicial Watch also seeks testimony from a 30 (b)(6) witness or witnesses who can provide testimony on behalf of the State Department on the following issues:

the creation or establishment of the clintonemail.com system as well as any maintenance, service, or support provided by the State Department of that system;

the knowledge or awareness of State Department officials and employees about the existence and use of the clintonemail.com system;

any instructions or directions given to State Department officials and employees about communicating with Mrs. Clinton and Ms. Abedin via email;

any inquiries into Mrs. Clinton’s use of the clintonemail.com system as well as any discussions about responding to such inquiries or publicly revealing the existence and use of the clintonemail.com system to the public; and

the inventorying or other accounting of Mrs. Clinton’s and Ms. Abedin’s email upon their departure from the State Department.

The Judicial Watch plan requests only eight weeks to conduct the requested depositions. Judge Sullivan will rule on Judicial Watch’s proposed discovery plan after April 15.

“This discovery will help Judicial Watch get all of the facts behind Hillary Clinton’s and the Obama State Department’s thwarting of FOIA so that the public can be sure that all of the emails from her illicit email system are reviewed and released to the public as the law requires,” stated Judicial Watch president Tom Fitton.


TOPICS: Crime/Corruption; Government; News/Current Events; Politics/Elections
KEYWORDS: cherylmills; clinton; depositions; discovery; emails; foia; hillary; humaabedin; judgesullivan; judicialwatch; jw; scandal; statedepartment

1 posted on 03/15/2016 11:27:13 AM PDT by jazusamo
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2 posted on 03/15/2016 11:29:22 AM PDT by DoughtyOne (Facing Trump nomination inevitability, folks are now openly trying to help Hillary destroy him.)
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To: jazusamo

meanwhile across town, these same people are being squeezed by the FBI


3 posted on 03/15/2016 11:38:35 AM PDT by bert ((K.E.; N.P.; GOPc;+12, 73, ....carson is the kinder gentler trump.)
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To: bert
Have to wonder if the FBI has been in contact with J.W.?

Reviewing what they have to date through court orders.

4 posted on 03/15/2016 11:41:16 AM PDT by TexasCajun (#BlackViolenceMatters)
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To: bert

Yep, and the tighter the better. At least we’ll hear from JW findings, not so sure about the FBIs.


5 posted on 03/15/2016 11:43:58 AM PDT by jazusamo (Have YOU Donated to Free Republic? https://secure.freerepublic.com/donate/)
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To: jazusamo; TexasCajun

well, the thing that seems plain to me now is that is sucks to be them


6 posted on 03/15/2016 11:47:55 AM PDT by bert ((K.E.; N.P.; GOPc;+12, 73, ....carson is the kinder gentler trump.)
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To: bert; TexasCajun

It sure does, and Hillary can put on the calm act but she’s gotta be sweating too. LOL!


7 posted on 03/15/2016 11:51:48 AM PDT by jazusamo (Have YOU Donated to Free Republic? https://secure.freerepublic.com/donate/)
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To: jazusamo
You bet she's sweating!

Will Obama & Lunch indict me on FBI recommendation? ...it's a conspiracy!

Will Obama pardon me since I have the goods on him? ..does he even care at this point?

Will Obama let this drag out till a new Republican administration? ...damn him!

8 posted on 03/15/2016 12:00:10 PM PDT by TexasCajun (#BlackViolenceMatters)
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To: jazusamo

yep.....she’s so flummoxed she forgot about the 4 Americans killed in Benghazi in her town hall last night....


9 posted on 03/15/2016 12:01:47 PM PDT by soozla (Truth prevails, regardless of who is willing to accept it ~ now or later.)
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To: jazusamo

Hillary is going to be protected at all costs. One would think Huma would be protected, but Hillary made Webb Hubble roll over twice, so if it comes down to it, Huma better hope for a nice cell - perhaps the one that was decorated by Martha Stewart when she was in the federal pen.

Of course, DOJ may sweep everything under the rug.


10 posted on 03/15/2016 12:10:32 PM PDT by PAR35
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To: jazusamo
Trump should appoint Tom Finton for his AG
11 posted on 03/15/2016 12:31:30 PM PDT by drypowder
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To: drypowder

An excellent suggestion...He’d shake up all the leftist fed attorneys hired by 0bama and Holder, maybe even make it tough enough for many of them that they’d quit.


12 posted on 03/15/2016 12:57:43 PM PDT by jazusamo (Have YOU Donated to Free Republic? https://secure.freerepublic.com/donate/)
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To: jazusamo

Trump needs to fire every single political appointee from the last 10’years.


13 posted on 03/15/2016 1:03:13 PM PDT by Lurker (Violence is rarely the answer. But when it is it is the only answer.)
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To: Lurker

I couldn’t agree more...The problem with these lawyers are they were hired as federal employees and aren’t political appointees, in excess of a hundred of them.


14 posted on 03/15/2016 1:14:12 PM PDT by jazusamo (Have YOU Donated to Free Republic? https://secure.freerepublic.com/donate/)
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