Request for a Status Conference - Judicial Watch

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
CARA ALEXANDER, et al., )
)
Plaintiffs, )
)
v. ) Civil Action Nos.
) 96-2123/97-1288 (RCL)
FEDERAL BUREAU OF )
INVESTIGATION, et al., )
)
Defendants. )
____________________________________)
PLAINTIFFS’ REQUEST FOR A STATUS CONFERENCE
Plaintiffs hereby respectfully request that a status conference be held in the above-captioned
matter at the earliest practicable date. Plaintiffs wish to discuss generally with the Court the Notice
filed by counsel for Defendant Executive Office of the President (“EOP”) on August 15, 2001. In
particular, Plaintiffs wish to discuss with the Court the qualifications of the Alexandria, Virginiabased
company Corbett Technologies (“Corbett”) to extract e-mail and other data from the back up
tapes that Defendant EOP has been unable to restore, and the steps that will be taken by Corbett to
ensure the security of the backup tapes while they are in Corbett’s possession. Plaintiffs note that
Corbett has not played any role in these proceedings to date, and that Defendant EOP’s Notice,
which is not accompanied by affidavit, contains virtually no description of Corbett’s qualifications
to play such an important role in the Tape Restoration Project.
Plaintiffs respectfully submit that time is of the essence in this matter, as according to
Defendant EOP’s Notice, the transfer of original backup tapes to Corbett from the National Archives
“will begin on August 27, 2001 or shortly thereafter.” See Notice at 4.
In addition, Plaintiffs would like to discuss the Court’s timetable for completing the e-mail

proceedings, which began in February 2000, are almost 21 months old (nearly 2 years), and which
have held up adjudication of this case, since crucial evidence has been suppressed and/or destroyed
and thus was not produced. In addition, key witnesses have been threatened and justice has been
obstructed.
Finally, Plaintiffs ask for a status conference to discuss taking the deposition of Defendant
Hillary Rodham Clinton, which has been deferred for five years. This case was filed on September
12, 1996.
Plaintiffs understand the Court’s busy schedule and has great respect for its diligence, hard
work, and commitment to justice, and therefore requests only a hearing of one half hour in duration.
WHEREFORE, Plaintiffs respectfully request that the Court hold a status conference in this
matter at the earliest practicable date.
Respectfully submitted,
___________________
Larry Klayman, Esq.
DC Bar No. 334581
JUDICIAL WATCH, INC
501 School Street, S.W. Suite 725
Washington, D.C. 20024
(202) 646-5172
Attorney for the Plaintiffs
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LOCAL RULE 7.1(m) CERTIFICATE OF COUNSEL
On August 28, 2001, I contacted James J. Gilligan, Esq., counsel for Defendants U.S.
Department of Justice and Federal Bureau of Investigation, by telephone, to confer and to inquire
whether his clients would consent to the relief requested herein. Mr. Gilligan stated that his clients
would not take a position on Plaintiffs’ motion.
On August 28, 2001, I also contacted Paul Gaffney, Esq., counsel for Defendant Hillary
Rodham Clinton, by telephone, to inquire whether his client would consent to the relief requested
herein. Mr. Gaffney stated that he opposes Plaintiffs’ request.
__________________________
Jason Aldrich, Esq.
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
CARA ALEXANDER, et al., )
)
Plaintiffs, )
)
v. ) Civil Action Nos.
) 96-2123/97-1288 (RCL)
FEDERAL BUREAU OF )
INVESTIGATION, et al., )
)
Defendants. )
____________________________________)
[PROPOSED] ORDER
Upon consideration of Plaintiffs’ Request for a Status Conference, and the entire record
herein, it is hereby ORDERED that:
A status conference will be held on _________________, 2001 at ________.
DONE AND ORDERED this _____ day of ____________, 2001.
_________________________
Royce C. Lamberth
United States District Judge
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Copies to:
Larry Klayman, Esq.
JUDICIAL WATCH, INC..
501 School Street, S.W.
Suite 725
Washington, D.C. 20024
Attorneys for Defendants Federal Bureau of Investigation and Executive Office of the President:
James J. Gilligan, Esq.
Elizabeth Shapiro, Esq.
U.S. DEPARTMENT OF JUSTICE
P.O. Box 883
Washington D.C. 20044
Attorneys for Defendant Hillary Rodham Clinton:
David E. Kendall, Esq.
Paul Gaffney, Esq.
WILLIAMS AND CONNOLLY
725 12 TH Street, N.W.
Washington, D.C. 20005
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CERTIFICATE OF SERVICE
I hereby certify that on September 12, 2001, a true and correct copy of the foregoing
PLAINTIFFS’ REQUEST FOR A STATUS CONFERENCE was served by first class U.S. mail on
the following:
Attorneys for Defendants Federal Bureau of Investigation and Executive Office of the President:
James J. Gilligan, Esq.
Elizabeth Shapiro, Esq.
U.S. DEPARTMENT OF JUSTICE
P.O. Box 883
Washington D.C. 20044
Attorneys for Defendant Hillary Rodham Clinton:
David E. Kendall, Esq.
Paul Gaffney, Esq.
WILLIAMS AND CONNOLLY
725 12 TH Street, N.W.
Washington, D.C. 20005
________________
Jason Aldrich
6