Judicial Watch Releases New Hillary Clinton Email Answers Given under Oath and She Can’t Recall Anything

UNBELIEVABLE … HILLARY CLINTON’S ANSWERS TO INTERROGATORIES IS SHE CAN’T RECALL ANYTHING.

Judicial Watch has released Hillary Clinton’s written responses under oath to their court ordered interrogatories by U.S. District Court Judge Emmet G. Sullivan and the answers are typical Clintonian nonsense and a disgrace. The former Secretary of State and current Democrat nominee for president seems to have forgot everything. I am beginning to wonder if she could recall her name. So what seems to be the problem with Hillary Clinton, does she have no short term memory, no long term memory, or is she just a lying and deceptive sack of sh*t? America, do you want to wake up one day to Hillary saying, I don’t recall that I took away the Second Amendment and America’s liberties?

AMERICA, WAKE THE HELL UP AND UNDERSTAND WHAT IS GOING ON! WE ARE ALL BEING PLAYED BY THE CLINTON’S, THE DEMOCRAT PARTY AND THE MSM. ENOUGH IS ENOUGH. DO NOT REWARD THIS LIAR WITH THE PRESIDENCY.

What difference does it make that I can’t recall, the MSM will never report on it, they are in my pocket

RESPONSES TO 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.

Response: Secretary Clinton objects to Interrogatory No. 1 as outside the scope of permitted discovery. The clintonemail.com system, as that term is defined in the Instructions and subject to Secretary Clinton’s objection to that definition, consisted of equipment set up to host e-mail for President Clinton’s staff. Information regarding the creation of that system, including the reasons for its creation, is irrelevant to this lawsuit and outside the scope of permitted discovery. The Court permitted discovery in this case on the question of “the purpose for the creation and operation of the clintonemail.com system for State Department business.” Dkt. #124, at 17 (emphasis added). That question is the subject of Interrogatory No. 2, which is answered below.

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.

Response: In the Senate, when Secretary Clinton began using e-mail, she used a personal e-mail account for both work-related and personal e-mail. Secretary Clinton decided to transition from the account she used in her tenure at the Senate to the clintonemail.com account. She recalls that it was created in early 2009. Secretary Clinton did not set up the account. Although Secretary Clinton does not have specific knowledge of the details of the account’s creation, her best understanding is that one of President Clinton’s aides, Justin Cooper, set up the account. She decided to use a clintonemail.com account for the purpose of convenience.

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?

Response: Secretary Clinton recalls deciding to use a clintonemail.com e-mail account to conduct official State Department business in early 2009. She does not recall any specific consultations regarding the decision to use the clintonemail.com account for official State Department business.

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.

Response: Secretary Clinton objects to Interrogatory No. 4 insofar as it purports to request information about communications after her tenure as Secretary of State, which communications would be irrelevant to the purpose for the creation and operation of her clintonemail.com account while she was Secretary of State. Subject to the foregoing objection, Secretary Clinton states that she does not recall participating in any communications before or during her tenure as Secretary of State concerning or relating to her decision to use a clintonemail.com account to conduct official State Department business.

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

Response: Secretary Clinton objects to Interrogatory No. 5 insofar as it misstates her comments in the 60 Minutes interview that aired on July 24, 2016. In that interview, she stated that “it was recommended that [using personal e-mail] would be convenient.” Subject to that objection, Secretary Clinton states that former Secretary of State Colin Powell advised her in 2009 about his use of a personal e-mail account to conduct official State Department business.

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.

Response: Secretary Clinton objects to Interrogatory No. 6 on the ground that it requests information that is not within the scope of permitted discovery for the reason set forth in General Objection No. 5. Secretary Clinton further objects to Interrogatory No. 6 to the extent it requests information about communications made to other persons that were not conveyed to Secretary Clinton. Subject to and without waiving the foregoing objections, Secretary Clinton states that she does not recall being advised, cautioned, or warned, she does not recall that it was ever suggested to her, and she does not recall participating in any communication, conversation, or meeting in which it was discussed that her use of a clintonemail.com e-mail account to conduct official State Department business conflicted with or violated federal recordkeeping laws.

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.

Response: Secretary Clinton objects to Interrogatory No. 7 on the ground that it requests information that is not within the scope of permitted discovery for the reason set forth in General Objection No. 5. Subject to and without waiving that objection, Secretary Clinton states that she does not recall considering factors other than convenience in deciding to use a personal e-mail account to conduct official State Department business.

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?

Response: Secretary Clinton does not recall whether she had a specific expectation that the State Department would receive FOIA requests for or concerning her e-mail. She understood that, because her practice was to e-mail State Department staff on their state.gov accounts, her email was being captured in the State Department’s recordkeeping systems.

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?

Response: Secretary Clinton understood that e-mail she sent or received in the course of conducting official State Department business was subject to FOIA. She further understood that, because her practice was to e-mail State Department staff on their state.gov accounts, her e-mail was being captured in the State Department’s recordkeeping systems.

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 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?

Response: Secretary Clinton objects to Interrogatory No. 10 on the ground that it requests information that is not within the scope of permitted discovery for the reason set forth in General Objection No. 5. Secretary Clinton further objects to Interrogatory No. 10 on the ground that the word “manage” is vague. Subject to and without waiving the foregoing objections, Secretary Clinton states that her practice was to e-mail State Department staff on their state.gov e-mail accounts, and Secretary Clinton understood that those e-mails were preserved in the Department’s recordkeeping systems and available to the Department in 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?

Response: Secretary Clinton does not recall specifically informing the State Department’s records management personnel about her use of her clintonemail.com e-mail account to conduct official State Department business; she did openly communicate via her clintonemail.com account with many people in the State Department. Secretary Clinton does not recall interacting with Clarence Finney or employees of the Executive Secretariat’s Office of Correspondence and Records.

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.

Response: Secretary Clinton objects to Interrogatory No. 12 insofar as it requests information about requests for access to her clintonemail.com account that may have been directed to other persons that were not conveyed to her. Subject to the foregoing objection, Secretary Clinton states that she does not recall State Department personnel asking her for access to her clintonemail.com e-mail account to search for e-mail responsive to a FOIA request during her tenure as Secretary of State.

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 bemaintained 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 bemaintained, preserved, or searched by the Department in response to FOIA requests?

Response: Secretary Clinton objects to Interrogatory No. 13 on the ground that it requests information that is not within the scope of permitted discovery for the reason set forth in General Objection No. 5. Subject to and without waiving the foregoing objection, Secretary Clinton states that it was her practice in conducting State Department business to e-mail State Department staff on their state.gov accounts, and she did not consider how e-mails she sent to or received from persons who did not have State Department e-mail accounts would be 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 “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.

Response: Secretary Clinton objects to Interrogatory No. 14 as seeking information outside the scope of the permitted discovery in this case. The Court’s May 4, 2016 Order provides that Plaintiff is not entitled to discovery on the subject of “cybersecurity issues.” Dkt. #73, at 13.

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.

Response: Secretary Clinton recalls that her November 13, 2010 e-mail exchange with Huma Abedin attached as Exhibit B to Plaintiff’s Interrogatories was triggered by a problem with the State Department’s telephone system. When Secretary Clinton wrote, “This is not a good system,” she was referring to the way in which the State Department would notify her of telephone calls. Secretary Clinton does not recall what precisely she meant by the words “address” or “device.” To the best of her recollection, she meant that she was willing to use a State Department e-mail account or device if it would resolve the problems with receiving telephone calls, so long as her personal e-mails with family and friends would not be accessible to the State Department. Following this e-mail exchange, the State Department changed the way in which it notified Secretary Clinton of telephone calls, resolving the problem that triggered this e-mail.

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

Response: Secretary Clinton does not recall requesting a State Department-issued Blackberry or a State Department e-mail account in or around August 2011.

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.

Response: Secretary Clinton objects to Interrogatory No. 19 as outside the scope of permitted discovery, as the Court’s May 4, 2016 Order provides that Plaintiff is not entitled to discovery on the subject of “cybersecurity issues.” Dkt. #73, at 13. Subject to and without waiving the foregoing objection, Secretary Clinton states that she does not recall reviewing Assistant Secretary Bowell’s Information Memo attached as Exhibit D to Plaintiff’s Interrogatories during her tenure as Secretary of State.

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.

Response: Secretary Clinton objects to Interrogatory No. 18 as outside the scope of permitted discovery, as the Court’s May 4, 2016 Order provides that Plaintiff is not entitled to discovery on the subject of “cybersecurity issues.” Dkt. #73, at 13. Secretary Clinton further objects to Interrogatory No. 18 on the ground that it mischaracterizes Secretary Clinton as the sender and author of the June 28, 2011 cable attached to Plaintiff’s Interrogatories as Exhibit E. During Secretary Clinton’s tenure as Secretary of State, all cables originating from Main State ended with the name “CLINTON.” The presence of Secretary Clinton’s name at the end of the cable was a formality, and it did not mean that she sent, authored, or reviewed the cable. Subject to and without waiving the foregoing objections, Secretary Clinton states that she does not recall seeing the June 28, 2011 cable attached as Exhibit E to Plaintiff’s Interrogatories during her tenure as Secretary of State.

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?

Response: Secretary Clinton objects to Interrogatory No. 19 as outside the scope of permitted discovery, as the Court’s May 4, 2016 Order provides that Plaintiff is not entitled to discovery on the subject of “cybersecurity issues.” Dkt. #73, at 13. Secretary Clinton further objects to Interrogatory No. 19 insofar as it requests information about whether Secretary Clinton was advised, cautioned, or warned about hacking or attempted hacking of her clintonemail.com e-mail account after her tenure as Secretary of State, which is irrelevant to the purpose for her creation and operation of the clintonemail.com account while Secretary of State and therefore outside the scope of permitted discovery. Subject to and without waiving the foregoing objections, Secretary Clinton states that she does not recall being advised, cautioned, or warned during her tenure as Secretary of State about hacking or attempted hacking of her clintonemail.com e-mail account or the server that hosted her clintonemail.com account.

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?

Response: Secretary Clinton objects to Interrogatory No. 20 on the ground that it requests information that is outside the scope of permitted discovery for the reason set forth in General Objection No. 5. Secretary Clinton further objects to Interrogatory No. 20 on the ground that the word “manage” is vague. Subject to and without waiving the foregoing objections, Secretary Clinton states that she does not recall considering whether to allow the State Department access to her clintonemail.com e-mail account when she was preparing to leave office. She believed that her e-mails with persons with state.gov e-mail accounts were already captured in the State Department’s recordkeeping systems. Secretary Clinton does not recall anyone from the State Department asking her for access to her clintonemail.com e-mail account or asking her to print her work-related e-mails when she was preparing to leave office.

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?

Response: Secretary Clinton objects to Interrogatory No. 21 as outside the scope of permitted discovery in this case for the reason set forth in General Objection No. 3. Secretary Clinton further objects to Interrogatory No. 21 on the ground that it requests information that is outside the scope of permitted discovery for the reason set forth in General Objection No. 5. Subject to and without waiving the foregoing objections, Secretary Clinton states that she does not recall considering after she left office whether she could alter, destroy, disclose, or use emails concerning official State Department business. Secretary Clinton further refers Plaintiff to her Response to Interrogatory No. 22.

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.

Response: Secretary Clinton objects to Interrogatory No. 22 as outside the scope of permitted discovery in this case for the reason set forth in General Objection No. 3. Secretary Clinton further objects to Interrogatory No. 22 on the ground that it requests information that is outside the scope of permitted discovery for the reason set forth in General Objection No. 5. Secretary Clinton further objects to Interrogatory No. 22 insofar as it requests information about all e-mail in her clintonemail.com account, including personal e-mail. Subject to and without waiving the foregoing objections, Secretary Clinton states that she does not recall altering, destroying, disclosing, or using any e-mails related to official State Department business from her tenure as Secretary of State in her clintonemail.com account or instructing anyone else to do so after she left office and before her attorneys reviewed the e-mails in her clintonemail.com email account in response to the State Department’s request.

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?

Response: Secretary Clinton objects to Interrogatory No. 23 as outside the scope of permitted discovery for the reason set forth in General Objection No. 3. Secretary Clinton further objects to Interrogatory No. 23 on the ground that it requests information that is outside the scope of permitted discovery for the reason set forth in General Objection No. 5. Secretary Clinton further objects to Interrogatory No. 23 insofar as it requests information about all e-mail in her clintonemail.com account, including personal e-mail. Subject to and without waiving the foregoing objections, Secretary Clinton states that it was her expectation that all of her work-related and potentially work-related e-mail then in her custody would be provided to the State Department in response to its request. Secretary Clinton believes that her attorneys retained copies of the e-mails provided to the State Department in December 2014, but she does not have any personal knowledge about the details of that process. Secretary Clinton decided that, once her work-related and potentially work-related e-mails were provided to the State Department, she had no reason to keep her personal e-mails, which did not relate to official State Department business. She believes that her personal e-mails were not kept, and she does not have any personal knowledge about the details of that process.

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.

Response: Secretary Clinton objects to Interrogatory No. 24 on the ground that it calls for information protected by the attorney-client privilege.

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 (e.g., in person, in writing, by telephone, or by electronic or other means), persons present or participating, and content of the communication.

Response: Secretary Clinton objects to Interrogatory No. 25 on the ground that it requests information that is outside the scope of permitted discovery for the reasons set forth in General Objection No. 5. Secretary Clinton further objects to Interrogatory No. 25 on the ground that the word “management” is vague. Secretary Clinton further objects to Interrogatory No. 25 insofar as it requests information related to alternate or replacement servers used after Secretary Clinton’s tenure as Secretary of State. Subject to and without waiving the foregoing objections, Secretary Clinton states that she does not recall having communications with Bryan Pagliano concerning or relating to the management, preservation, deletion, or destruction of any e-mails in her clintonemail.com email account.