(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: