IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

)

JUDICIAL WATCH, INC., )

)

Plaintiff, )

)

v. ) Civil Action No. 13-cv-1363 (EGS)

)

U.S. DEPARTMENT OF STATE, )

)

Defendant. )

)

PLAINTIFF’S INTERROGATORIES TO FORMER U.S. SECRETARY

OF STATE HILLARY RODHAM CLINTON

Plaintiff Judicial Watch, Inc., pursuant to the Court’s August 19, 2016 order and Rule 33

of the Federal Rules of Civil Procedure, submits the following interrogatories to be answered

under oath by former U.S. Secretary of State Hillary Rodham Clinton.

INSTRUCTIONS AND DEFINITIONS

1. Your answers to these interrogatories should include information within your

actual or constructive possession, custody, or control, including information which may be held

by your attorneys, representatives, all persons acting under, by, or through you, or subject to your

control or supervision, and all persons acting on your behalf.

2. If you cannot answer an interrogatory fully and completely, answer as much as

you can and provide all facts upon which you rely in support of your contention that you cannot

answer fully and completely.

3. If you object to any portion of an interrogatory, but not the entire interrogatory,

identify the specific portion of the interrogatory to which objection is made and answer the

portion of the interrogatory to which no objection is made.

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4. If you object to any interrogatory on the grounds that the interrogatory is overly

broad or unduly burdensome, answer the interrogatory by providing all information that is not

alleged to be overly broad or unduly burdensome and identify the nature, quality, quantity, or

volume of the withheld information and the effort that would be required to provide the withheld

information.

5. If you object to any interrogatory on the grounds that the interrogatory calls for

information that is subject to a claim of privilege, state the privilege that is claimed to apply and

identify all information sufficient to permit Plaintiff to contest the claim of privilege and to

permit the Court to reach a determination concerning the validity of the claim of privilege,

together with the factual and legal basis for the claim of privilege.

6. “And” and “or” are to be construed both conjunctively and disjunctively, as

necessary, to make the interrogatory inclusive rather than exclusive. Similarly, any use of the

singular shall also mean the plural and vice versa, to give the interrogatory its broadest possible

meaning.

7. The definitions provided below are hereby incorporated into each interrogatory in

which the term appears:

a. “Clintonemail.com email system” refers to the email system, server(s),

provider(s) and infrastructure that hosted any email account with the domain name

“clintonemail.com.”

b. “Clintonemail.com account” refers to any email address with the domain

name “clintonemail.com.”

c. “Communication” refers to any transmission, conveyance, or exchange of

information, whether facts, ideas, inquiries, or otherwise, and regardless of form, method, or

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medium. It shall include, without limitation, any conference, contact, conversation,

correspondence, discussion, email, internet posting, instant message, letter, meeting, telegram,

telefax, text message, “tweet,” or voice mail message.

d. “Department” or “State Department” refers to the U.S. Department of

State, the defendant in this action.

e. “FOIA” refers to the Freedom of Information Act, 5 U.S.C. § 552.

INTERROGATORIES

1. Describe the creation of the clintonemail.com system, including who decided to

create the system, the date it was decided to create the system, why it was created, who set it up,

and when it became operational.

2. Describe the creation of your clintonemail.com email account, including who

decided to create it, when it was created, why it was created, and, if you did not set up the

account yourself, who set it up for you.

3. When did you decide to use a clintonemail.com email account to conduct official

State Department business and whom did you consult in making this decision?

4. Identify all communications in which you participated concerning or relating to

your decision to use a clintonemail.com email account to conduct official State Department

business and, for each communication, identify the time, date, place, manner (e.g., in person, in

writing, by telephone, or by electronic or other means), persons present or participating, and

content of the communication.

5. In a 60 Minutes interview aired on July 24, 2016, you stated that it was

“recommended” you use a personal email account to conduct official State Department business.

What recommendations were you given about using or not using a personal email account to

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conduct official State Department business, who made any such recommendations, and when

were any such recommendations made?

6. Were you ever advised, cautioned, or warned, was it ever suggested, or did you

ever participate in any communication, conversation, or meeting in which it was discussed that

your use of a clintonemail.com email account to conduct official State Department business

conflicted with or violated federal recordkeeping laws. For each instance in which you were so

advised, cautioned or warned, in which such a suggestion was made, or in which such a

discussion took place, identify the time, date, place, manner (e.g., in person, in writing, by

telephone, or by electronic or other means), persons present or participating, and content of the

advice, caution, warning, suggestion, or discussion.

7. Your campaign website states, “When Clinton got to the Department, she opted to

use her personal email account as a matter of convenience.” What factors other than

convenience did you consider in deciding to use a personal email account to conduct official

State Department business? Include in your answer whether you considered federal records

management and preservation requirements and how email you used to conduct official State

Department business would be searched in response to FOIA requests.

8. After President Obama nominated you to be Secretary of State and during your

tenure as secretary, did you expect the State Department to receive FOIA requests for or

concerning your email?

9. During your tenure as Secretary of State, did you understand that email you sent

or received in the course of conducting official State Department business was subject to FOIA?

10. During your tenure as Secretary of State, how did you manage and preserve

emails in your clintonemail.com email account sent or received in the course of conducting

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official State Department business, and what, if anything, did you do to make those emails

available to the Department for conducting searches in response to FOIA requests?

11. During your tenure as Secretary of State, what, if any, effort did you make to

inform the State Department’s records management personnel (e.g., Clarence Finney or the

Executive Secretariat’s Office of Correspondence and Records) about your use of a

clintonemail.com email account to conduct official State Department business?

12. During your tenure as Secretary of State, did State Department personnel ever

request access to your clintonemail.com email account to search for email responsive to a FOIA

request? If so, identify the date access to your account was requested, the person or persons

requesting access, and whether access was granted or denied.

13. At the time you decided to use your clintonemail.com email account to conduct

official State Department business, or at any time thereafter during your tenure as Secretary of

State, did you consider how emails you sent to or received from persons who did not have State

Department email accounts (i.e., “state.gov” accounts) would be maintained and preserved by the

Department or searched by the Department in response to FOIA requests? If so, what was your

understanding about how such emails would be maintained, preserved, or searched by the

Department in response to FOIA requests?

14. On March 6, 2009, Assistant Secretary of State for Diplomatic Security Eric J.

Boswell wrote in an Information Memo to your Chief of Staff, Cheryl Mills, that he “cannot

stress too strongly, however, that any unclassified BlackBerry is highly vulnerable in any setting

to remotely and covertly monitoring conversations, retrieving email, and exploiting calendars.”

A March 11, 2009 email states that, in a management meeting with the assistant secretaries, you

approached Assistant Secretary Boswell and mentioned that you had read the “IM” and that you

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“get it.” Did you review the March 6, 2009 Information Memo, and, if so, why did you continue

using an unclassified BlackBerry to access your clintonemail.com email account to conduct

official State Department business? Copies of the March 6, 2009 Information Memo and March

11, 2009 email are attached as Exhibit A for your review.

15. In a November 13, 2010 email exchange with Huma Abedin about problems with

your clintonemail.com email account, you wrote to Ms. Abedin, in response to her suggestion

that you use a State Department email account or release your email address to the Department,

“Let’s get a separate address or device.” Why did you continue using your clintonemail.com

email account to conduct official State Department business after agreeing on November 13,

2010 to “get a separate address or device?” Include in your answer whether by “address” you

meant an official State Department email account (i.e., a “state.gov” account) and by “device”

you meant a State Department-issued BlackBerry. A copy of the November 13, 2010 email

exchange with Ms. Abedin is attached as Exhibit B for your review.

16. Email exchanges among your top aides and assistants in August 30, 2011 discuss

providing you with a State Department-issued BlackBerry or State Department email address. In

the course of these discussions, State Department Executive Secretary Stephen Mull wrote,

“[W]e are working to provide the Secretary per her request a Department issued BlackBerry to

replace her personal unit which is malfunctioning (possibly because of her personal email server

is down). We will prepare two versions for her to use – one with an operating State Department

email account (which would mask her identity, but which would also be subject to FOIA

requests).” Similarly, John Bentel, the Director of Information and Records Management in the

Executive Secretariat, wrote, “You should be aware that any email would go through the

Department’s infrastructure and [be] subject to FOIA searches.” Did you request a State-

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Department issued Blackberry or a State Department email account in or around August 2011,

and, if so, why did you continue using your personal device and clintonemail.com email account

to conduct official State Department business instead of replacing your device and account with

a State Department-issued BlackBerry or a State Department email account? Include in your

answer whether the fact that a State Department-issued BlackBerry or a State Department email

address would be subject to FOIA affected your decision. Copies of the email exchanges are

attached as Exhibit C for your review.

17. In February 2011, Assistant Secretary Boswell sent you an Information Memo

noting “a dramatic increase since January 2011 in attempts . . . to compromise the private home

email accounts of senior Department officials.” Assistant Secretary Boswell “urge[d]

Department users to minimize the use of personal web-email for business.” Did you review

Assistant Secretary Boswell’s Information Memo in or after February 2011, and, if so, why did

you continue using your clintonemail.com email account to conduct official State Department

business? Include in your answer any steps you took to minimize use of your clintonemail.com

email account after reviewing the memo. A copy of Assistant Secretary Boswell’s February

2011 Information Memo is attached as Exhibit D for your review.

18. On June 28, 2011, you sent a message to all State Department personnel about

securing personal email accounts. In the message, you noted “recent targeting of personal email

accounts by online adversaries” and directed all personnel to “[a]void conducting official

Department business from your personal email accounts.” Why did you continue using your

clintonemail.com email account to conduct official State Department business after June 28,

2011, when you were advising all State Department Personnel to avoid doing so? A copy of the

June 28, 2011 message is attached as Exhibit E for your review.

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19. Were you ever advised, cautioned, or warned about hacking or attempted hacking

of your clintonemail.com email account or the server that hosted your clintonemail.com account

and, if so, what did you do in response to the advice, caution, or warning?

20. When you were preparing to leave office, did you consider allowing the State

Department access to your clintonemail.com email account to manage and preserve the official

emails in your account and to search those emails in response to FOIA requests? If you

considered allowing access to your email account, why did you decide against it? If you did not

consider allowing access to your email account, why not?

21. After you left office, did you believe you could alter, destroy, disclose, or use

email you sent or received concerning official State Department business as you saw fit? If not,

why not?

22. In late 2014, the State Department asked that you make available to the

Department copies of any federal records of which you were aware, “such as an email sent or

received on a personal email account while serving as Secretary of State.” After you left office

but before your attorneys reviewed the email in your clintonemail.com email account in response

to the State Department’s request, did you alter, destroy, disclose, or use any of the email in the

account or authorize or instruct that any email in the account be altered, destroyed, disclosed, or

used? If so, describe any email that was altered, destroyed, disclosed, or used, when the

alteration, destruction, disclosure, or use took place, and the circumstances under which the

email was altered, destroyed, disclosed, or used? A copy of a November 12, 2014 letter from

Under Secretary of State for Management Patrick F. Kennedy regarding the State Department’s

request is attached as Exhibit F for your review.

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23. After your lawyers completed their review of the emails in your clintonemail.com

email account in late 2014, were the electronic versions of your emails preserved, deleted, or

destroyed? If they were deleted or destroyed, what tool or software was used to delete or destroy

them, who deleted or destroyed them, and was the deletion or destruction done at your direction?

24. During your October 22, 2015 appearance before the U.S. House of

Representatives Select Committee on Benghazi, you testified that 90 to 95 percent of your emails

“were in the State’s system” and “if they wanted to see them, they would certainly have been

able to do so.” Identify the basis for this statement, including all facts on which you relied in

support of the statement, how and when you became aware of these facts, and, if you were made

aware of these facts by or through another person, identify the person who made you aware of

these facts.

25. Identify all communications between you and Brian Pagliano concerning or

relating to the management, preservation, deletion, or destruction of any emails in your

clintonemail.com email account, including any instruction or direction to Mr. Pagliano about the

management, preservation, deletion, or destruction of emails in your account when transferring

the clintonemail.com email system to any alternate or replacement server. For each

communication, identify the time, date, place, manner (e.g., in person, in writing, by telephone,

or by electronic or other means), persons present or participating, and content of the

communication.

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Dated: August 30, 2016 Respectfully submitted,

/s/ Michael Bekesha

Michael Bekesha

D.C. Bar No. 995749

JUDICIAL WATCH, INC.

425 Third Street S.W., Suite 800

Washington, DC 20024

(202) 646-5172

Counsel for Plaintiff Judicial Watch, Inc.

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Exhibit C

) 0 5 6 71 IED U.S, Department of'State Case. No, F~2015-126.B.5 Doc No. COS9.05671 Date!- 0111512016

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-~1'1atiks fo.r. rei:liindtng;all of t~ls verv helpful i:ootextt II .@

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Ste:v~ ~ 1.t\t~i ~.1'$cus~Jh.e $ta.te blai;lcl:!err.y, dpeso·~ o:iale c; .w~o.I~ 'Pt<of. se..r\~e. A.s'fQr t~t:.:~q\Jlpf:l\i;!.n~1 (h~ ~cmim:o t~;im \i'l~s lfmlted irr ·som:e:~ap~c.itY· ~~~"~~. weJ~,o·n.ot ... h~ye" ay~l,\Qil~~~ frQllliPWrt~r.s 9J r:e~1d~n~e to fns@\L·eqviprnenl . .W~ dl.d it reiptJS~,j«fd)ticnally, ass· knQw~ t~e t~arir ~ldr;irt'h~ve a~~ss io .t11e= ~toperty until ~ .coupl'e·ef hours befQre S:arrlvec;t F.ln<Jilv~ a~'l?i/l!(I the? wN~e-Jiouse att~~red,. thl~·was· a pr:~tty:wJd.e 'spread pr<)blf?ll); nQtJ)Jstaff~ctlng·: i!~ ~ !i.V~ 1ilo.u1a ~~ilf' O\aJlf:i :tnif\d.

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Th.anks ·again tor alerting r.ne .to the comn:i~nlcatlqns ·issues the S'ee:retarv has .beer:r flavfrtf. tl~r~~:i .a ~tp.tus re·port:

• Qo .the Immediate ...erebler:n ef !M2.eg~s:not~ beh~g.atile ,to. ij~ve- b~r·call5" transren:~d,j · · ·: : '

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• On trye !'!"Ore long t~r'r'n issue, 1'ye asked our tearn to dev.elop an enhanced I I

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EXHIBrT

UNCLASSll='IEO U.S. Department of State Case No. F-2015-12685 Doc No. C059056J1 Date: 01/1512016

CO!? 90 5 .6.7 l!ED U.S. Departm~ru qf Stat:. Cas~rNo. F-2015~1;l685 Doc No. C05905671 Date·: 01/1512016

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package of cap~billti~ ·and equlprn~n~._ tl:lat we WOIJl.d pr.9pqse·~eploying y.,ith the Secrefary to t,le a~ closely cd•loca.ted as possible with her when she ·is on trav.el away from h~f l.lSY.al

residec;i~e:$. !he. pac;l<age· wtll tndu.de t\':llil.~ th;1~ ;i:ntkip.cit!!' tt)e .norrnaJfy. un:expected such as hurricanes, pow~r outages, ecirthq9~~es, Jt>t:l)5t$; etc, ss,1cti as generators, unintl!rl'iJpted

PQWer supplies-, .supprementar.y satellite c:apai:i!lfties, inc.ludi!'ig satelllte _phones· for when local i,ofrastruc:r.ur.e falls (as lt .ditl !n NY over tt'.ie ~eekeridf . .. ·separate.ly.1 we are:workins. ·t9 provide t.fie :Secretary per he·c request a Dep~rtmel'lt: issµed Bl;itkberf'j to ·r.epla·ce. her il¢rSoiia.I \Jl)lt: wtikh is' malfuncti<:lriing (Pt>ssiQly ~caus~ oi her

p-er.som~l .e:malt. serv~r- :ls ~.QWnl. W.~ will tifep.are tW.o vmic;>ns foi' tier to use ... one w(th ar.i opera.ting State. p~par:tn:u~_nt e~-a.1.1 ~c~~~.~~ lwnlcn wpula mask liet Id.entity, but wt\IC.h woµld cilsci. be subject to rl!llA reql.iests)i. aiid anotb~t which wo~M juS,t-.h;;ivl!! p'ho.i:\e ~(ld intecnet

-~P-~P11ity,_ W.e'~¢. W.Qr~lng ~I.th Morilta: t9 fouyirner 9ut the ~etal~s of-what wijl be.st'meet

t.h~. ~ec,~~wy'.s. n.~e.ds:.

Rlea:s~ let rn~ knqw. If ypu reed. ill'vt'11llg more for. now, and 1~11 be in ·tqutjl with the above lo('!~er. 'ter~ options soon.

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N C05905671 Date: 01/1512016 U S D ar1-ent of State C~se No. F-2015--12685 Ooc o.

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!RELEASE IN FUUJ

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REVIEW AUTHORITY: Archie Bolster, enlor Reviewer

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UNCLASSIFIED U.S. Department of State Case No. 0.2016-06755 Doc No. C06052787 Date: 06/2012016

Exhibit D

cu.) ts'.) / ~ u 4 1t-1t:u u .:::i. ueparunem or :::>tate ~ase NO. r·£U1!:>-U!)(J4~ uoc; No. l;05Bbf~U4 Date: 11/0512015 ;

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IEW AUT-HOR1.TY: Barbara ~ielsen, Senior ·--·---- - -- 1 Reviewer

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·m"!iSUges. app+!ar to b¢ ~l::!b~ . .. .s:: gdVoauneltl llffici&a :btit ·ate tfosiflc:c! lei :rid r~iP.ients into cu;civaiing ~m~d · m~iiicic.>us ccd'1 by oli,;k.l~ on·ti.nia~un~r:r w · liuk Althoqg}}; the ta.rge(s are unc;~~i~d. ~fSQnal 1t-mJ1;il accounL~ tfl~ tikcly W> .. 1~:i\r-t is lo_ ~ompromi~ ~r uccuLQ'rts 0 anrJ.. ~~u:b:-' gatJl a.t;c~~ tu.::pcl;c~ 'dncLlfl'!~~ '~~ ~1* in',fonnuiipn th ii ~ou Id a:tblc:f · ·~ie.al S~\t~lh\h<:! .and f2~~ibb• bhidariai[ Tlie pc~oi'uil e-mail ri'flamib· '!l'lnD<! ... "ll!~~ i~ qi ri~k. .

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UNCLASSIFIED !J;S:. De~rtment of State ca~ N~. F-2Q15--0~ Doc ~ci:'. C05857004 Date' 11/0512(}.15

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Exhibit E

MRN: D•telDTG: From: AcUon: E.0.: TAGS: Subject:

UNCLAS STATE 065111

E.O. 13526: NIA

.UN.C..LA$.$1FIEO

11 STATE65111

Jun 28, 2011 I 282223Z J.UN 11 SECSTATE WASHDC ALL DIPLOMATIC AND CONSULAR POSTS COlLECTIVEROUnNE

13526 APCS,ASEC,AADP, AMGT Securing Personal E-mail Accounts

TAGS: APCS, ASEC, MOP, AMGT SUBJECT: Securing Personal E-mail Accounts

Reference:

A) 12.F~ 544.3

1. Department of State users are encouraged to check the security settings and change passwords of their hOme e-mail accounts because of recent targeting of personal e-mail accounts by online adversaries. Security gu/delfnes have been posted on the DS/$1/CS Cyber Security Awareness web page: https://intranet.ds.state.sbu/DS/Sl/CS/Awareness1/Content/Pers onal%20Emall.espx.

2. Recently, Google asserted that onllne adversaries are targeting the personal Gmail accounts of U.S. government employees. Although the company believes It has taken appropriate steps to remediate Identified activity. users should exercise caution and follow best practices In order to protect personal e-mail and prevent the compromise of government and personal information. The OS/SI/CS Cyber Security Awareness web site contains guides to help secure the web-based e-mail accounts of users and 'their families. This information can be accessed at: https:flintranet.ds.6'ate.sbu/DS/Sl/CS1Awareness1/Content/Pers onal%20Emaif.aspx.

3. What can you and your family members do? {a) Follow the personal e-mail guides posted on the Awareness site to change your password, to ensure that messages are not

auto-fo1WSrdlng to an unintended address, and to verify that other security settings are property configured. (b} Beware of e-mail messages that include links to password reset web pages. These can be easily faked. (o) Create strong passwords for alt of your on line accounts, change them often, and never use the same password for more than one account (d) Avoid conducting official Department business from your personal e-mail accounts. (e) Do not reveal your personal e-mail address in your work "Out of Office" message. (f) Do not auto-forward Department e-mail l'o personal e-mail accounts, which is prohibited by Department policy (12 FAM 544.3).

4. Questions regaroing cyber security awareness should be addressed to awareness@state.gov CLINTON

"

Exhibit F

Case 1:13-cv-01363-EGS Document 18-1 Filed 08/06/15 Page 1 of 20

UNDER SECRETARY OF STATE

FOR MANAGEMENT

WASHINGTON

t!DV 1 2 ((M.

The Department of State has a longstanding and continuing commitment to preserving the history of U.S. diplomacy, estabHshed in authorities under the Federal Records Act of 1950. 1 am writing to you, the representative of Secretary of State Hillary Clinton, as well as to representatives of other fonner Secretaries (principals), to request your assistance in further meeting this requirement.

The Federal Records Act of 1950, as amended, 44 U.S.C. chapters 29, 31 and 33, seeks to ensure the preservation of an authoritative record of official correspondence, com mun i cations, and documentation. Last year, in Bulletin 2013-03, the National Archives and Records Administration (NARA) clarified records management responsibilities regarding the use of personal email accounts for official government business. NARA recommended that agencies refer to its guidance when advising incoming and departing agency employees about their records management responsibilities. This bulletin was followed by additional NARA guidance on managing email issued on September 15, 2014. See enclosed.

We recognize that some period of time has passed since your principal served as Secretary of State and that the NARA guidance post-dates that service. Nevertheless, we bring the NARA guidance to your attention in order to ensure that the Department's records are as complete as possible. Accordingly, we ask that should your principal or his or her authorized representative be aware or become aware in the future of a federal record, such as an email sent or received on a personal email account while serving as Secretary of State, that a copy of this record be made avairable to the Department. In this regard, please note that diverse Department records are subject to various disposition schedules, with most

Enclosures - 3

Ms. Cheryl Mills,

Case 1:13-cv-01363-EGS Document 18-1 Filed 08/06/15 Page 2 of 20

-2-

Secretary of State records retained permanently. We ask that a record be provided to the Department if there is reason to believe that it may not otherwise be preserved in the Department's recordkeeping system.

The Department is wiJling to provide assistance to you in this effort. In the meantime, should you have any questions regarding this request, please do not hesitate to contact William Fischer, NGIS/IPS/RA, Agency Records Officer, at (202) 261-83 69.

We greatly appreciate your consideration of and assistance with this matter.

Sincerely,

a::.::nnedy