August 22, 2019 – A federal judge criticizes State and Justice departments on Clinton email cover-up; gives Clinton and Mills 30 days to oppose being deposed
“Judicial Watch released the transcript today from their hearing on Thursday, August 22, 2019, where U.S. District Court Judge Royce C. Lamberth granted significant new discovery to Judicial Watch on the Clinton email issue (Judicial Watch v. U.S. Department of State (No. 1:14-cv-01242)).
During the hearing, Judge Lamberth specifically raised concerns about a Clinton email cache recently discussed in a letter to Senator Charles Grassley (R-IA) and wants Judicial Watch to “shake this tree” on this issue.[J]ust last week, the Senate’s – Senate Finance and Homeland Security Committees released documents revealing that Clinton IT aide Paul Combetta copied all but four of the missing emails to a Gmail account that does not appear to have ever been reconstructed and searched. The court thinks Judicial Watch ought to shake this tree.
Judge Lamberth also criticized the State Department’s handling and production of Clinton’s emails in this case stating, “There is no FOIA [Freedom of Information Act] exemption for political expedience, nor is there one for bureaucratic incompetence.”
At the beginning of their oral arguments, lawyers for the State Department wrongfully stated that Judicial Watch could no longer continue their discovery. The court stopped their arguments saying that Judicial Watch can continue to find more evidence in this case:
STATE DEPARTMENT: … it is, of course, Judicial Watch’s burden to explain to Your Honor why there has been good cause to reopen discovery now that discovery has closed in this case.
THE COURT: Well, I didn’t close discovery. So your premise is wrong.
STATE DEPARTMENT: Fair enough, Your Honor. Whether you want to call it closed or not, it is still —
THE COURT: I didn’t close it. I said I would have a status after they took this initial discovery, and that’s what I’m doing today. I didn’t close discovery.
STATE DEPARTMENT: That’s right, Your Honor, but it is still Judicial Watch’s —
THE COURT: So they don’t need any good cause —
STATE DEPARTMENT: Whether
THE COURT: — Today the good cause continues from whether or not State was acting in good faith, and I’ll tell you everything they’ve discovered in this period raises serious questions about what the hell the State Department’s doing here.
The court rejected DOJ and State efforts to derail further Judicial Watch discovery. Judge Lamberth called their arguments “preposterous” and cited a prior Judicial Watch FOIA case in which he ordered U.S. Marshals to seize records from a Clinton administration official.
I’ll tell you another thing I didn’t like in your brief. I’ll tell you right now upfront. You put in your brief the most preposterous thing, I thought, in your brief was the very idea that — let me read you the line. Competitive Enterprise Institute was a case of first impression and that some District Judge bought that and the Court of Appeals reversed it. Now, that wasn’t a case of first impression at all. The first impression with me was a case I had involving Ron Brown and the travel records of whether or not, in the Commerce Department — and it was a Judicial Watch case — whether or not the Commerce Department was selling seats on trade missions, and I had a Deputy Under Secretary of Commerce who took a box of records home and then they gave a no-records response and, in the course of that, I found out he had taken the records home and they said they had no records. I sent marshals over and they got the box at his house, and I ordered them – the marshals — to seize the records. That was the first case.
The Judge also stated that the government has mishandled this case and the discovery of information including former Secretary Clinton’s emails so poorly that Judicial Watch may have the ability to prove they acted in “bad faith,” which would entitle them to attorney’s fees.
Judge Lamberth detailed how the State Department “spent three months from November 2014 trying to make this case disappear,” and that after discovering the State Department’s actions and omissions, “Now we know more, but we have even more questions than answers. So I won’t hold it against Judicial Watch for expanding their initial discovery request now.”
Judge Lamberth stated his goal was to restore the public’s faith in their government, which may have been damaged because of the Clinton email investigation:
When I authorized discovery back in December, I described my goal: to rule out egregious government misconduct and vindicate the public’s faith in the State and Justice Departments. That’s still my goal today. This isn’t a case I relish, but it’s the case before me now, and it’s a case of the government’s making.”
The court granted Judicial Watch seven additional depositions, three interrogatories and four document requests related to former Secretary of State Hillary Clinton’s use of a private email server. Hillary Clinton and her former top aide and current lawyer Cheryl Mills were given 30 days to oppose being deposed by Judicial Watch.
Below is the court’s ruling from the bench granting Judicial Watch’s significant new discovery:”
August 21, 2019 – Judicial Watch will seek the deposition of Hillary Clinton and Cheryl Mills
“Judicial Watch announced today that a federal court ordered a hearing for Thursday, August 22, 2019, on the Clinton email issue. On December 6, 2018, U.S. District Court Judge Lamberth ordered Obama administration senior State Department officials, lawyers and Clinton aides to be deposed or answer written questions under oath.
The court ruled that the Clinton email system was “one of the gravest modern offenses to government transparency.” The court ordered discovery into three specific areas: whether Secretary Clinton’s email use of a private email server was intended to stymie FOIA; whether the State Department’s intent to settle this case in late 2014 and early 2015 amounted to bad faith; and whether the State Department has adequately searched for records responsive to Judicial Watch’s request.
Judicial Watch deposed nearly a dozen witnesses and will seek addition[al] witnesses and documents from the court, including the deposition of Hillary Clinton and Cheryl Mills, her chief of staff at State and personal lawyer who directed the destruction of 33,000 State Department Clinton emails. Lawyers for Clinton and Mills are expected at the hearing Thursday.”
August 1, 2019 – John Solomon reports Durham and Horowitz have interviewed Joseph Mifsud and obtained an audio-taped deposition
(…) “Solomon told Sean Hannity that Western asset Joseph Mifsud has already testified and the Durham investigators have already obtained a taped deposition of his testimony.
Last week former US Attorney Joe diGenova also reported that US Attorney John Durham and IG Horowitz have already interviewed Joseph Mifsud.
John Solomon: I can report absolutely that the Durham investigators have now obtained an audio-taped deposition of Joseph Mifsud where he describes his work, why he targeted Papadopoulos, who directed him to do that, what directions he was given and why he set that entire process of introducing George Papadopoulos to Russia in motion in March of 2016. Which is really the flashpoint the start point of this whole Russia collusion narrative.
July 23, 2019 – Durham’s team reaches out to Mifsud to review a deposition he gave last year that suggests he was instructed to put Papadopoulos in touch with Russians
“While most of the political world focused its attention elsewhere, special prosecutor John Durham’s team quietly reached out this summer to a lawyer representing European academic Joseph Mifsud, one of the earliest and most mysterious figures in the now closed Russia-collusion case.
An investigator told Swiss attorney Stephan Roh that Durham’s team wanted to interview Mifsud, or at the very least review a recorded deposition the professor gave in summer 2018 about his role in the drama involving Donald Trump, Russia and the 2016 election.
(…) For those who don’t remember, Mifsud is a Maltese-born academic with a VIP Rolodex who frequented Rome and London for years and engaged at the highest levels of Western diplomatic and intelligence circles.
Mueller’s team alleges that Mifsud is the person who fed a story in spring 2016 to Trump campaign adviser George Papadopoulos about Moscow possessing purloined emails from former Secretary of State Hillary Clinton. It was the earliest known contact in the now-debunked collusion narrative and the seminal event that the FBI says prompted it on July 31, 2016, to open its probe into the Trump campaign.
Mueller concluded that Mifsud was a person with extensive Russia ties who planted the story about the Clinton emails in Moscow and then lied about his dealings with Papadopoulos when interviewed by the FBI in 2017. Papadopoulos has pleaded guilty to lying to the FBI about his contacts with Mifsud.
(…) Conservative defenders of President Trump, including former House Intelligence Committee Chairman Devin Nunes (R-Calif.) and Senate Judiciary Committee Chairman Lindsey Graham (R-S.C.), have raised recent concerns that Mueller’s portrayal of the Mifsud-Papadopoulos contacts doesn’t add up.
Roh told me the information he is preparing to share with Durham’s team from his client will accentuate those concerns.
Mifsud was a “longtime cooperator of western intel” who was asked specifically by his contacts at Link University in Rome and the London Center of International Law Practice (LCILP) — two academic groups with ties to Western diplomacy and intelligence — to meet with Papadopoulos at a dinner in Rome in mid-March 2016, Roh told me.
A May 2019 letter from Nunes to U.S. intelligence officials corroborates some of Roh’s account, revealing photos showing that the FBI conducted training at Link in fall 2016 and that Mifsud and other Link officials met regularly with world leaders, including Boris Johnson, elected today as Britain’s new prime minister.
A few days after the March dinner, Roh added, Mifsud received instructions from Link superiors to “put Papadopoulos in contact with Russians,” including a think tank figure named Ivan Timofeev and a woman he was instructed to identify to Papadopoulos as Vladimir Putin’s niece.
Mifsud knew the woman was not the Russian president’s niece but, rather, a student who was involved with both the Link and LCILP campuses, and the professor believed there was an effort underway to determine whether Papadopoulos was an “agent provocateur” seeking foreign contacts, Roh said.
The evidence, he told me, “clearly indicates that this was not only a surveillance op but a more sophisticated intel operation” in which Mifsud became involved.” (Read more: The Hill, 7/23/2019)
- 2016 Election
- Clinton emails
- Federal Bureau of Investigations (FBI)
- George Papadopoulos
- Ivan Timofeev
- John Durham
- Joseph Mifsud
- July 2019
- Link Campus University Rome
- London Academy of Diplomacy (LAD)
- Stephan Roh
- The London Centre for International Law Practice (LCILP)
- Trump campaign
- Trump Russia collusion
June 18, 2019 – Judicial Watch releases transcript of Justin Cooper’s deposition – Cheryl Mills communicates with him a week prior to testimony
“Judicial Watch today released the deposition transcript of Justin Cooper, a former aide to President Bill Clinton and Clinton Foundation employee who registered the domain name of the unsecure clintonemail.com server that Hillary Clinton used while serving as Secretary of State. Cooper admits that he spoke with Cheryl Mills, Clinton’s former chief of staff, one week prior to his deposition and let her know that the deposition had been scheduled. Cooper also said that he worked with Huma Abedin, Clinton’s deputy chief of staff, to create the private email system, but can’t recall if Clinton had any input in its creation or if he wiped the original server. The entire transcript is available here.
(…) Cooper testified that he spoke with Mills the week before giving his deposition:
Q When did you last speak with Cheryl Mills?
A Last week.
Judge Lamberth late last year criticized the DOJ, saying he was “dumbfounded” by the Inspector General report revealing that Mills had been given immunity and was allowed to accompany former Secretary of State Hillary Clinton to her FBI interview. The full transcript of that hearing is available here.
I did print out and read that 500-page report when I got it and I was actually dumbfounded when found out, in reading that report, that Cheryl Mills had been given immunity because … I had myself found that Cheryl Mills had committed perjury and lied under oath in a published opinion I had issued in a Judicial Watch case where I found her unworthy of belief, and I was quite shocked to find out she had been given immunity in — by the Justice Department in the Hillary Clinton email case. So I did not know that until I read the IG report and learned that and that she had accompanied the Secretary to her interview.
(In an April 28, 2008 ruling relating to Mills’ conduct as a White House official in responding to concerns about lost White House email records, Judge Lamberth called Mills’ participation in the matter “loathsome.” He further stated Mills was responsible for “the most critical error made in this entire fiasco … Mills’ actions were totally inadequate to address the problem.”)
When Cooper was asked who approached him about creating the clintonemail.com account, Cooper answered: “It would have been a discussion with Huma Abedin.” Cooper also testified that Abedin was his primary contact regarding the choice of the domain name that was registered “I believe” in “January ’09.”
Cooper’s testimony is at odds with a 2016 Judicial Watch deposition of Abedin in which she testified that she became aware of the server through “reading in some news articles about a year, a year-and-a-half ago, when it was – it was being publicly discussed.”
Cooper said “I don’t recall” when asked if Clinton herself had any input in the creation of the domain name.
Cooper also testified that there were two servers: an original “Apple server” and then a Windows server, which was “the Pagliano server,” named after Clinton’s top State Department IT specialist Bryan Pagliano. Cooper said he couldn’t recall whether the Apple server was wiped once her emails were transferred over to the Pagliano server in early 2009.
When Cooper was asked to testify how many e-mails accounts he created or setup for Clinton he answered, “To the best of my recollection two or three.” Cooper also said that he and Pagliano set up email accounts for Abedin and Chelsea Clinton.
Pagliano was a Clinton State Department IT official who repeatedly invoked his Fifth Amendment right to not answer questions in a 2016 Judicial Watch deposition.
(…) He identified controversial Clinton Foundation official and advisor to President Clinton Doug Band as the individual in a redacted FBI 302 report who had conversations with Cooper and Abedin about the Apple server and who thought adding Hillary Clinton to the server was a “bad idea.”
Q Let me direct your attention to the fourth paragraph about four lines up. This is a redacted version, so we don’t know who the interviewee is or some of the names. But I want to direct your attention to the line that starts off with the redaction and says, blank recall the conversation with Huma Abedin and Cooper regarding the addition of Hillary Clinton to the Apple server; do you see that?
A I do.
Q Do you know who that individual would be …
A I suspect it’s Doug Band.
Q The next line says, blank thought it was a bad idea, but the issue had been decided by that point in time; do you see that?
June 13, 2019 – Heather Samuelson’s Judicial Watch deposition discusses her immunity, when she became aware of the private server and deleting 33,000 emails
“Judicial Watch announced today that former Secretary of State Hillary Clinton’s White House Liaison at the State Department, and later Clinton’s personal lawyer, Heather Samuelson, admitted under oath that she was granted immunity by the U.S. Department of Justice in June 2016:
Samuelson: I was provided limited production immunity by the Department of Justice.
Judicial Watch: And when was that?
Samuelson: My recollection, it was June 2015 [later corrected to 2016].
A complete copy of her deposition transcript is available here. Samuelson also revealed that, contrary to what she told the FBI in 2016, she was, in fact, aware that Sec. Clinton used a private email account while secretary of state:
Judicial Watch: Ms. Samuelson, when did you first become aware that Secretary Clinton used the e-mail address firstname.lastname@example.org while she was at the State Department?
Samuelson: I believe I first became aware when either she e-mailed me on personal matters, such as wishing me happy birthday, or when I infrequently would receive e-mails forwarded to me from others at the department that had that e-mail address listed elsewhere in the document.
Judicial Watch: Okay. And who were the State Department officials?
Samuelson: I recall Cheryl Mills, but it could have been others.
Samuel’s admission to Judicial Watch that she became aware of Clinton’s non-State.gov emails during her service in the Clinton State Department White House Liaison Office during Clinton’s tenure as secretary of state (January 2009 – February 2013) contradicts the notation in the FBI’s May 24, 2016 302 report on Samuelson’s interview with FBI agents:
Samuelson did not become aware of Clinton’s use of a private email account and server until she was serving as Clinton’s personal attorney.
After Clinton left office, Samuelson worked for a year in the office of the White House Counsel before becoming Clinton’s personal attorney, where, in 2014, she was primarily responsible for conducting the review of Clinton emails and sorting out “personal” emails from government emails, which were returned to the State Department under the direction of Cheryl Mills and Clinton lawyer David Kendall. After the emails were returned to State, Clinton deleted the rest of the “personal” emails from her server, wiping it clean. Samuelson conducted the review of emails on her laptop, using Clinton server files downloaded from Platte River Networks, which housed the Clinton email server. Judicial Watch questioned her about a “gap” in the emails she discovered:
Judicial Watch: I believe you, during your interview with the FBI, you were asked about a gap in e-mails that you noticed in Secretary Clinton’s e-mails from January 2009 to March of 2009. Do you recall that?
Samuelson: I do.
Judicial Watch: Okay. Can you explain to me what that gap was?
Samuelson: My understanding is — well, I’m sorry. I should say my recollection is when we received the documents — the file from Platte River Networks, there was a period of time that was missing in her e-mails. And that period of time was January 2009 to March 2009.
Judicial Watch: And what did you do as the result of discovering this gap in the e-mails from January 2009 to March 2009?
Samuelson: I asked Platte River why we did not have — why they did not provide those.
Judicial Watch: And what did they tell you?
Samuelson: They said they did not have that information.
Judicial Watch: Did Platte River have access during 2014 to the server that housed Secretary Clinton’s e-mails to her Clintonemail.com account –
– and was there any discussion as to whether they could obtain Secretary Clinton’s e-mails from that server from January 2009 to March 2009?
Samuelson: I did ask them, and they said they did not have any e-mails from that period.
Samuelson also testified in her deposition that she created an “after action memo” in or around December 2014 to memorialize the email search. Samuelson’s lawyer directed her not to answer questions about this memo.” (Read more: Judicial Watch, 6/28/2019)
June 3, 2019 – Former State official testifies he warned about Clinton email issues and was concerned about interference with classified Clinton Benghazi emails
“Judicial Watch announced today that John Hackett, the former Director for Information Programs and Services (IPS), which handles records management at the State Department, testified under oath that he had raised concerns that former Secretary of State Hillary Clinton’s staff had “culled out 30,000” of the secretary’s “personal” emails without following strict National Archives standards. The full deposition transcript is available here.
John Hackett, as part of a series of court-ordered depositions and questions under oath of senior Obama-era State Department officials, lawyers, and Clinton aides, also revealed that he believed there was interference with the formal Freedom of Information Act (FOIA) review process related to the classification of Clinton’s Benghazi-related emails.
Hackett served first as deputy director then as director for Information Programs and Services, which handles the FOIA request program and the retirement of and declassification of documents at the State Department. He was at the department from April 2013 to March 2016.
In March 2015, Clinton told reporters that she and her staff had deleted more than 30,000 emails “because they were personal and private about matters that I believed were within the scope of my personal privacy.” ABC News reported: “However, after a year-long investigation, the FBI recovered more than 17,000 emails that had been deleted or otherwise not turned over to the State Department, and many of them were work-related, the FBI has said.”
(Heather Samuelson, the Clinton lawyer who deleted the Clinton emails, separately testified to Judicial Watch that she received immunity from the Justice Department.)
Hackett answered during the deposition that he recalled a conversation that he had when he was at the State Department about requesting rules or parameters from Secretary Clinton or her attorneys that they used to segregate her personal and official work emails.
Hackett: I recall it wasn’t much of a conversation. I — I was — I mean, I have to say, it was emphatic to the Under Secretary of Management — and I didn’t speak in tones like that very often to him — you know, that we needed these — you know, the guidelines.
Judicial Watch: And when you said, the Under Secretary, are you referring to Patrick Kennedy [then-Under Secretary of State for Management]?
Hackett: I think I might have raised it to Rich Visek, the Acting Office of Legal Advisor, or Peggy — or Margaret Grafeld [an executive-level State Department FOIA official] raised it to Rich, as well.
Judicial Watch: Why did you feel so strongly that this was necessary, that they provide this information?
Hackett: Well, we heard that there were 50,000 or 60,000 emails, and that they had – “they” being the Secretary’s team — had culled out 30,000 of these. And which is — so we wanted to know what criteria they used. The standard from the National Archives is very strict. If there was — if there were mixed records, that would be considered a federal record. If it was mixed personal and mentioned a discussion, that would be — under the narrow National Archives rules, it would be considered a federal record.
(…) Hackett testified that his initial concern over Secretary Clinton’s email use arose in June 2013 when he said he viewed a photograph on the WTOP website of Clinton “sitting on a plane with a BlackBerry. “And that got me thinking that, well, what — what was that BlackBerry? Was it a government BlackBerry? And if so, where were the emails relating to that BlackBerry?” Hackett said.
Hackett testified he went to then-IPS Director Sheryl Walter “after seeing that photograph and suggested that we had to be careful about what sort of responses we made relating to Hillary Clinton’s emails, when it — if there was a No Record Located response that was being given out. In fact, I advised Sheryl that we should stop giving No Record Located responses until we come to — kind of come, you know — find out what that BlackBerry meant, come to ground about what was known about the former Secretary’s emailing habits.”
Asked how Walter responded, Hackett said “My recollection is, she agreed with me.”
“The other thing that we did, or I did at that time, was, we wanted to find out what this BlackBerry meant,” Hackett testified. “So we tasked — my recollection is, we verbally tasked Tasha Thian, the department’s Records Manager at that time, to look into the BlackBerry. And I believe Tasha contacted Clarence Finney in the Secretary’s office to ask him what he knew about the former Secretary’s emailing habits.”
Asked what Thian found out, Hackett responded: “I don’t recall exactly what she found out, but she didn’t find out much. Tasha also contacted the part of the State Department that’s part of the intelligence community, and Intelligence and Research Bureau, to ask to see if there were any classified emails on — in the classified systems that the Secretary might have produced. And I do recall that I think Tasha came back with the answer that they did not have any.”
Hackett went on to say that “There was a lot of confusion about exactly what that BlackBerry, you know, meant at that time. you had a concern as to how the department was responding to FOIA requests that related to Secretary Clinton’s emails after you saw the photograph of the Secretary holding a BlackBerry. … My recollection is — and I had only been there two months — that someone had told me that, — and I can’t remember — that she did not have an email account, a government email account. So there was obviously a contradiction here when, you know, there’s that photograph. So we were just trying to find out what was the ground truth. So that’s why I had a concern about issuing responses that said no records had been located.” (Read more: Judicial Watch, 7/02/2019)
May 06, 2019 – Former Asst. Sec. of State for Diplomatic Security testifies under oath that he warned Hillary Clinton twice about unsecure BlackBerrys and personal emails
Judicial Watch released the deposition transcript of Eric Boswell, the former Assistant Secretary of State for Diplomatic Security during Hillary Clinton’s tenure as Secretary of State, in which he reveals that Hillary Clinton was warned twice against using unsecure BlackBerrys and personal emails to transmit classified material. A full transcript of the deposition is available here.
Boswell, who was responsible for securing classified and national security information, stated that Clinton and her staff were “wedded to their BlackBerrys.” Additionally, he stated that he and other former State Department employees “were surprised” that Clinton used clintonemail.com to conduct official government business.
In his deposition, Ambassador Boswell stated:
- Hillary Clinton and other Senior State Department officials were warned in 2009 that “any unclassified Blackberry is highly vulnerable in any setting to remotely and covertly monitoring conversations, retrieving emails and exploiting calendars.”
- Clinton was warned again in 2011 that “We also urge Department users to minimize the use of personal web email for business, as some compromised home systems have been reconfigured by these actors to automatically forward copies of all composed emails to an undisclosed recipient.”
- Clinton assured him that she “gets it” when he informed her about dangers of Blackberries.
- Clinton and her staff were “wedded to their blackberries” and wanted to continue using them in secure areas even after warning because it was a “convenience issue” to them.
- He and other former State Department employees “were surprised” to learn that Clinton used clintonemail.com to conduct official government business. Boswell claimed that they were not aware of such activity while still employed by the government.
Boswell was deposed as part of the discovery granted to Judicial Watch by U.S. District Court Judge Royce C. Lamberth in response to its Freedom of Information Act (FOIA) lawsuit involving former Secretary of State Hillary Clinton’s unsecured, non-government email system (Judicial Watch v. U.S. Department of State (No. 1:14-cv-01242)). (Read more: Judicial Watch, 5/29/2019)
February 28, 2019 – Judge orders release of Christopher Steele deposition
“A federal judge in Florida on Thursday ordered the release of depositions given by former British spy Christopher Steele and a longtime associate of late Republican Arizona Sen. John McCain in a lawsuit filed against BuzzFeed regarding Steele’s anti-Trump dossier.
U.S. District Court Judge Ursula Ungaro overruled requests by Steele and David Kramer, the former McCain associate, to keep depositions they gave in the BuzzFeed lawsuit under seal. Ungaro dismissed a lawsuit filed against BuzzFeed on Dec. 19, 2018, by Aleksej Gubarev, a Russian businessman accused in the dossier of using his companies to hack into DNC computers.
The depositions by Steele and Kramer, a former Department of State official, are likely to shed light on how the dossier was compiled and disseminated to U.S. government officials and the press. Ungaro ordered the documents’ release for March 14.
Kramer, a former State Department official, provided the dossier to a BuzzFeed reporter Dec. 28, 2016, several weeks after meeting with Steele in London.
Steele was hired in June 2016 by opposition research firm Fusion GPS to investigate then-candidate Donald Trump’s ties to Russia. He produced 17 separate memos dated between June 20, 2016, and Dec. 13, 2016, alleging a vast conspiracy between the Trump campaign and Kremlin to influence the election.” (Read more: The Daily Caller, 2/28/2019)
January 10, 2019 – Judicial Watch to depose former top officials involved in the Clinton email scandal
Judicial Watch announced today that it submitted a court-ordered discovery plan for the depositions of several top former government officials involved in the Clinton email scandal, including Obama administration senior officials Susan Rice, Ben Rhodes, Jacob Sullivan, and FBI official E.W. Priestap.
Judicial Watch “intends to update the Court regarding the depositions of Hillary Clinton and Cheryl Mills at the conclusion of the 16-week discovery period, unless the Court believes such notice is not necessary.” The plan for discovery is the latest development in Judicial Watch’s July 2014 FOIA lawsuit filed after the U.S. Department of State failed to respond to a May 13, 2014 FOIA request (Judicial Watch v. U.S. Department of State (No. 1:14-cv-01242)). Read the discovery plan here: