The second of planned Judicial Watch depositions, carried out under the order of Judge Sullivan, involving Clinton chief-of-staff Cheryl Mills was taken on May 27, 2016--under oath (penalty of perjury). Ms. Mills, herself a lawyer had an assemblage of her own attorneys. This stuff ain't cheap; I wonder who is footing the bill here for respondent's legal fees--it is probably us, we the people, because the named defendant in this proceeding is the U.S. Department of State. Oh, the irony, that American citizens should twice have to bear the costs of Hillary's "convenient" discretions. The first cost is still unknown, because the damage to the U.S. foreign service is yet to be calculated. Indeed, with over 31,000 quasi-personal emails deleted by HRC, we may never know the full extent of damage her bad behavior has inflicted on overseas, largely covert--but always secret--activities.

In this the second deposition by Judicial Watch, Mills, one of Hillary's co-conspirators in clandestine undermining of U.S. National Security, was asked many questions, of which a great number she did not answer on advice of counsel. These will be listed at the end of this deposition summary, but you can download Mills deposition here

Cliff's Notes version of this 269 page deposition: "See no evil, hear no evil, speak no evil."

TEASER ALERT: To entice you readers into reading further into this exercise, possible Chinese Hacking.
But You'll have to struggle through this to find that. (Share the "joys" of wading through depositions).

Lingering unresolved, contradictory answers about Executive Secretariat, the citations for which are included below:

CM stated that Executive Secretariat did not have access to HRC's emails. So how could they co-ordinate with HRC, about preservation or deletion of documents? Who watched the watchers?

Credentials: University of Virginia, graduating in 1987.
Stanford University Law school graduating in 1990.
White House (WH) staff 1993-1999, associate, then deputy counsel
CM became HRC's lawyer when HRC left DOS.

While at WH, responded to requests for documents and other materials. Email began to be used at the end of her tenure as counsel.
Started work at Department of State (DOS) January 2009 as uncompensated temporary employee, become full-time in May 2009.

Shortly before coming to the State Department, Judge Lamberth ruled in the Alexander case, in which he criticized your conduct, as well as some others, in the White House with respect to handling of e-mail requests. And I believe the word he used was "loathsome."

A And, you know, I can't speak to both his observations or the set of facts in that regard, because I think I would need to -- to do that well, I've always tried my best to be responsive and tried my best to do the best that I could. ...

MS. BERMAN [one of Mills' attorneys]: We have a very specific scope of permissible discovery. And the portion of it that I believe your questioning is purportedly directed to is the process, the -- the State Department's approach and practice for processing FOIA requests that potentially implicated former Secretary Clinton and Ms. Abedin's e-mails.

JW's attorney Cotca goes on to talk of the allowed scope of this deposition:

Just to respond now to the objection. As the chief of staff and counselor in the Secretary's office, Judge Sullivan's order in this case goes specifically to sensitivity with respect to e-mail issues and how FOIA requests were processed at the Secretary's office. So we do think that Ms. Mills' experience in that regard as the chief of staff for her entire tenure and her counselor is relevant and within the scope.

After some legal wrangling, Mills replied:

A So I was chief of staff and counselor...At the department there are a broad array of kind of both policy and programmatic issues that the department handles...so diplomacy itself has a long history. And so a lot of it is about what has been done in the past and how you do it in the future, particularly when you're dealing with nation states. And so the role of the chief of staff is often to try to provide both advice and guidance but also, more particularly, support for navigating the multiplicity of issues that come before the Secretary. Which on a given day can really range from Iraq to Iceland and everything in between, as well as development that we are doing and development investments that we might be making in countries around the world.

Note the duties described included developing investments in countries around the world. This is a direct tie-in for evidence of critical pay-for-play charges but which are not the subject of this inquiry.

Now more about her duties, which actually blended two previously separate functions at DOS: chief of staff AND DOS counsel.

if you think about what secretaries do, there really is the immediate, and then there is a short term and then there's a long term. I tended to be more in the immediate. So if there was something that needed to be addressed, it was a conflict among bureaus that had to be navigated, those were the types of issues that typically would be in front of me on any given day.

After previously working for HRC on the 2008 presidential campaign, Mills was asked to join DOS. Discussing CM's role during the transition period from Bush 2.0 and Obama:

MS. COTCA: The transition process to the State Department is definitely within the scope, to the extent about office setups and what equipment was provided and what devices were provided to Secretary Clinton with respect to e-mail questions....
A: So I didn't set up Secretary Clinton's office.

Now, some shadow boxing: duck and feint: reference is made to Lewis Lukens (LL) who was the first deposed in emailgate

Q: His deposition was taken, and I'll just tell you this. His deposition was taken last week, and he identified you as the point of contact with respect to issues involving setting up the different offices in the Secretary's office, and that sort of thing. Were you the point of contact?...

A: But if you are asking whether or not I was the point of contact in that context, I think it would depend on what the matter was...Not that I recall a lot of conversations with Lou Lukens. I certainly did have conversations with him.

Regarding the setup of CM's personal office:

A: Yes, I did have a State Department BlackBerry.
Q: Okay. Did you ask for it?
A: I don't recall if I asked for it or not, but I know I received one.
Q: Okay. And did you have a State Department e-mail when you came on board?
A: I don't know when they created my State Department e-mail, but I did have a State Department e-mail that I used when I was at the department.

CM denied knowledge of how her own email system was created.

CM's counsel's interpretation of the scope of the deposition

MS. WILKINSON: ...You're supposed to talking about the creation and operation of Clintonemail.com for the State Department business, the approach to processing FOIA requests that implicated either the Secretary Clinton or Ms. Abedin's e-mails, and the processing of FOIA requests. Her State Department e-mail is not part of those topics.

CM was unaware of discussions about HRC's personal email account, but:

A: So the Secretary has spoken about the fact that she had made a determination that she would use her personal account, and that is exactly what she did...So Secretary Clinton continued a practice that she was using of her personal e-mail. And I don't know that I could articulate that there was a specific discussion as opposed to her continuation of a practice she had been using when she was Senator...

So Secretary Clinton when she was in the Senate had an A T&T or what I call an A T&T account that ultimately transitioned to an account that was Clinton e-mail...[she had a] BlackBerry that was associated with an A T&T e-mail.

HRC had two email accounts initially at DOS:

A: So Secretary Clinton used -- always used one e-mail account when she was using an e-mail account. So when she initially arrived she was continuing to use the AT&T accounts, and then transitioned to the dot Clinton e-mail, or Clintonemail.com account. And during her tenure those were the two addresses, if you will, that she used.

Page 49: Between February and April time frame (2009) HRC informed [some] DOS staffers of her new email address.

A: You have handed me a document that is an e-mail that has the Secretary's e-mail address, to Lona Valmoro and Huma Abedin, requesting a time that she can meet with her undersecretaries each week...[dated] September 20,2009

CM could recall two of HRC's email addresses: HDR22@clintonemail.com and HROD17, thinking that HDR22@clintonemail.com around Feb.-April 2009 was the one in use. But now another email address is described: HR15@att.blackberry.net--CM was unaware of why HRC began using clintonemail in March [2009].

CM admits to transferring (at least one) email from a staffer to HRC at the HDR22@clintonemail address as early as January 30, 2009 (page 62). HRC began tenure as Sec DOS on January 22, 2009.

Huma Abedin (HA) had her own email account on HRC's private server: habedin@hillaryclinton.com.

HRC's Senate email address: HR15@AT&T.blackberry.net.

On August 22, 2014, CM began communications with John Kerry's chief-of-staff, David Wade, regarding return of HRC's emails to DOS

CM now distinguishes her roles at DOS being HRC's counsel from CM's role being counsel to HRC after leaving DOS:

A: Correct. So the counselor role at the State Department is not a lawyer role. The counselor role at the State Department is actually a policy role. And so it's on particular policy issues that might be relevant to the Secretary.

CM did not learn the details about HRC's email set-up until both had exited DOS, at which time CM was HRC's lawyer. David Kendall was HRC's counsel after she left DOS. Other HRC attorneys post-DOS include Williams & Connolly.

CM stated that she first met Bryan Magliano in 2008 during HRC's presidential campaign:

A: I know I spoke with Mr. Pagliano about the setup of the server during the period in which I was representing Secretary Clinton, which would have been after two thousand -- which would have been post her departure from the State Department. At least that's my best recollection.

CM spoke to Justin Cooper, who actually obtained the IP address for clintonemail.com only after CM became HRC's lawyer.

A: Mr. Cooper was a senior advisor to President Clinton and a personal aid who managed issues related to President Clinton's business as well as their household.

CM was aware of Platte River Networks as being an email service company that transitioned HRC's emails in 2013.
She was unaware of discussing with Platte River the email server set-up. She was unfamiliar with Datto Network.
CM was unaware of whether HA had more than one email account on Clinton's private server and HA also had a State.gov email account. There was no DOS staff email directory.

CM admits that HRC did NOT have an State.gov email account while at DOS. Regarding DOS staffers contacting HRC by email:

A: If she had e-mailed with them they would be able to reach her. They could come upstairs and seek her e-mail address from the special assistants or others who were familiar with it. Or they could seek to engage her. As a practical matter, Secretary Clinton overwhelmingly met with people. So her modality of engagement was not traditionally the e-mail. She traditionally used meetings and phone calls as the way in which she engaged in her day-to-day business for the department.

A: Jacob Sullivan was deputy chief of staff and managed policy at the department, and then subsequently became the head of policy and planning.
Q: Okay. He was within the Secretary's office. Correct?
A: Correct.
Q: Okay. And Secretary Clinton e-mailed with Mr. Sullivan for government-related business?
A To my knowledge, yes.
Q: Okay. And just by our count of the records that Secretary Clinton returned, we counted 3,887 e-mails that were sent and 1,412 e-mails that were received...between Mr. Sullivan and Secretary Clinton...
A: So I know that the Secretary returned over 30,000 e-mails. I don't know the breakdown of that in terms of how they broke down by individual.

CM did not know whether Susan Rice, who during HRC's tenure at DOS, was U.N. ambassador corresponded by email with HRC. But later in the deposition she was handed an email:

A: This is an e-mail from Secretary Clinton to Susan on her State.gov account, and then Susan responding.

More about transferring HRC's email address to other people:

A: saying, Do you want him [Rahm Emanuel] to have your e-mail. And then I sent an e-mail to the Secretary And the Secretary then responded to me, saying, yes. And then I responded saying, K. Will give him directly. And this exchange is happening on our State e-mail accounts.

More on HRC communicating with others about DOS business:

A: Correct. Secretary Clinton's e-mail is Clintonemail.com. It was her practice to e-mail for State matters on individuals' government accounts.

An email to John Kerry from HRC dated March 18, 2012, from her private server was produced as exhibit 6 to the deposition transcript. Other emails originating from State.gov officials to Clinton's private server were also produced in exhibit 6:
Former energy secretary Steven Chu;
Dennis McDonough, deputy national security counsel

CM provided HRC's email address to David Axelrod; and to John Pedestal, who in 2009 was president of the Center for American Progress.

Discussing email traffic between HRC and Nora Toiv, CM's assistant at State, [starting at page 136] the subject of multiple email addresses arises:

A: So I don't know how records get produced. Because obviously these are records that have been produced -- I'm not going to speculate where they came from. But I think part of the confusion, at least for me as I'm reading these, is they have a variety of different e-mail addresses that I don't believe actually are reflective of the Secretary's at that time. And I think it's more a reflection of the time and when these got produced. And some of these are just aggregated. Because this second e-mail page is actually still in the same traffic. It starts with the same, For future reference, this is my -- my Gmail. Thanks. And then she has the same thing, That's all I have. And then it says, You've always e-mailed me on my State. And then it says, Weird, since my address book has your Gmail. Maybe the Chinese hacked it.

Did that really occur--maybe it did, although CM seems to regard the hacking comment as a joke. Some joke!!!

The time has come to talk about blackberries and SCIFs said the Walrus to the Carpenter:

A: I know that at the time when Secretary Clinton started at the department, we had asked whether or not there could be a BlackBerry that was a department-issued BlackBerry that would be able to -- be able to be used inside her office space. The seventh floor, where many of the senior leadership work, is considered a safe. Or a SCIF, if you will, is the terminology. And inside the SCIF typically you're not able to use your mobile device. And so the question was, one, can she get a device that would be able to be compatible with being able to use it in her office.
Q: Okay, did she end up being able to get one?
A: No.

More about Blackberrys and SCIFs:

A: So the State Department had advised -- their diplomatic security team had advised that she could not use and none of the staff could use a BlackBerry inside the SCIF. Whether or not it was State or not issued by State, you couldn't use a BlackBerry inside the SCIF. And so in order to be able to check your BlackBerrys, you needed to leave the seventh floor area where all our offices were. And so if you walked outside in the hallway or if you went to the counsel's office, in her instance that would be an area that was not inside a secure space, and you could check your BlackBerry, whether or not that was a State BlackBerry or -- or not a State BlackBerry.

A: ...And just to be specific, so that I know, there is a reference in the first few pages [of a specific email] with respect to setting up the office across the hall for her to use, as well as the potential to set up a PC in her office...Secretary Clinton's office is 100 percent inside the SCIF.

The office across the hall from HRC was outside the SCIF so anyone could State or non-State BlackBerry in there.

so I don't know how frequently she went out to go use that space...she sent or received at least 20 [emails] a day.

About stand alone PCs:

Q: Okay. And was a standalone PC ever set up in the Secretary's office?
A: Not to my knowledge. Or there was not one set up that she used. I don't know if it was never set up, or set up and pulled away. I don't know the answer to that question. But not to my knowledge did she ever use a standalone PC.
Q: Okay. I'm sorry. Patrick Kennedy e-mailed you about the idea of setting up a standalone separate network PC. Is that --
A: He did e-mail me that.

About Bryan Pagliano:

Q: Okay. And just the last page of the exhibit, there's an e-mail to Patrick Kennedy. If you can look at that. "Please let me know when you are ready to give Bryan his assignment at IRM."
A: I don't know what IRM stands for. I know it's the acronym that's associated with the technology department at the State Department.
Q: Okay. Is there a separate department that handles technology just for the Secretary's office?
A: So I don't know how to think about the divisions. I do know that there was a group called Poems that typically is who I called when I was an issue with respect to my e-mail or my devices. And so did other folks who were in the seventh floor, which would be the Secretary and extended senior leadership's offices...On occasion I would interact with Mr. Pagliano...In my presence, I don't recall occasions where he interacted with the Secretary.

Q: Exhibit 10 contains, let's see, an e-mail from Stephen Mull to you, on August 30th, 2011. And as you can see on the second page of the exhibit, he is writing to you with respect to a request from the Secretary for a department-issued BlackBerry to replace her personal unit. "Separately we are working to provide the Secretary per her request a department issued BlackBerry to replace her personal unit." Then do you see where he writes in the next sentence, "We will prepare two versions for her to use, one with operating State Department e-mail account which would mask her identity but which would also be subject to FOIA requests"?

HRC never obtained a State.gov issued BlackBerry

Email "capture" on DOS servers:

A: I don't have a recollection of having a discussion with somebody in the Secretary's office and her e-mail being subject to FOIA. It was my impression it was.
Q: Your impression it was -- that her Clinton.com e-mail --
A: Would be captured, yes...It was my impression that when she e-mailed, because it was her practice to e-mail people on their State accounts when she was doing State business, that any of those communications would be captured and maintained by the State Department system.

Handling of FOIA requests:

A: So I can speak to my experience. The State Department itself has an office that actually manages and responds to FOIAs. If there was a request that came, those requests typically, if they were coming to me, would come to my office for me, and I would have to do a search and respond...I don't know how to speak about how they processed that or what searches they undertook. So I don't know how the Executive Secretary or the special assistant staff would have undertaken to look for the responsive records,

Executive Secretariat's access to emails:

To my knowledge, they did not have access to her e-mail account.

State Department capture of emails:

Q: Did you or anybody inform anybody within the Executive Secretariat's office that Secretary Clinton's account was not captured on the State Department's system?
A: So I don't have a recollection, with respect to FOIA, of making that type of an affirmative engagement. Because Secretary Clinton e-mailed relatively a wide swath of folks, more than a hundred, certainly, in the department. And so her use of her e-mail was not something that was unknown...I would also be surprised that they [Executive Secretariat] would be unaware that it was not on the State.gov system...On occasion, really most of the time she communicated with me on State matters on my State account. She communicated with Ms. Abedin on her State account as well, but also on her Clinton e-mail account.

Other than HA, CM was unaware of anyone else, including Brian Magliano and Jacob Sullivan, who had an account on Clinton's private server.

Regarding CM's personal knowledge of HRC printing or saving emails:

So I'm not familiar with a practice where she would print and save her e-mails. I obviously have seen a lot of e-mails where she would say, Please print. But I don't know that she had a practice of printing and saving her e-mails.

CM never dealt with FOIA requests directed to HRC. She also had no knowledge of how other staffers, including HRC, responded to FOIA requests.

Benghazi:

A: I don't recall having a FOIA request related to Benghazi that I was stepping through while I was there.
Q: Ms. Mills, did you communicate with the Secretary about the Benghazi attacks by e-mail?
A: I may have. I don't recall. Because in realtime obviously her office is about, happily or sadly, five to seven feet from mine. And so given the sets of events that were happening in that time period, there was a lot of, obviously, direct communication.
Q: Okay. Did you communicate with Ms. Abedin about the Benghazi attacks via e-mail?
A: I absolutely might have. I don't have a recollection of doing that, but I might have...So in response to requests that came in from Congress, I did review my records to provide material that would be responsive.

Benghazi FOIAs, is there more to it?:

Q: My understanding was that you testified in front of Congress. Do you remember your testimony before -- providing testimony before the select committee, the Benghazi Select Committee?
A: Yes.
Q: And my understanding is that you testified that you were the point person with respect to searching of records that related to the Benghazi attacks in the Secretary's office.
MS. WILKINSON [attorney for CM]: Objection. Form.
A: That's not my recollection. So I might have done that, but that's not my recollection.

Q: So when there was a FOIA request that came in that related to the Secretary's e-mails, why was there a different practice and her e-mail account was not searched, but your e-mail account was searched?
...A: and so a request would come to me. But I was not the Secretary of State. So when requests would come to the Secretary of State, that might follow a different process because it's the Secretary of State, as opposed to ones that came to me. I can only speak to the ones that came to me.

Was there anyone else at State that knew about HRC's private server, not already mentioned:

Q: Did you ever inform Mr. Finney about the Clinton e-mail account during your time there, with respect to FOIA requests?
A: I don't have a recollection of doing so...I don't believe I know John Bentel.

During the transition from Clinton's tenure as SOS and John Kerry's at DOS, CM is unaware of anyone discussing the saving of Clinton's emails at State.

Q: Well, what about -- let's talk about the Secretary's records, file cabinet, let's say, her hard-copy records that she had at the State Department.
What happened to those when she left?
MS. BERMAN: Objection. Goes beyond the scope of permissible discovery.
MS. WILKINSON: Same. And form and foundation.
A: So I can only speak to what I know. The Executive Secretariat always is in that position of managing both paper and materials and information that relate to the Secretary. I can't speak to what their processes and protocols are...they provide information with respect to materials and other things. That's the same.

Core issue:

CM did not discuss disposition of Clinton's records with Patrick Kennedy when she left office.

Q: Did you and the Secretary have any discussions with respect to inventorying or identifying federal records from her e-mails?
...A: I don't recall having those kinds of discussions... I don't recall having discussions about how someone might access her e-mail apart from what was already in the State Department system.

Q: Ms. Mills, was your understanding that Secretary Clinton could do whatever she wanted with her e-mail records when you were at the State Department?
...A: I don't know that I had an understanding like that, no. I don't know that I had an understanding at all.
Q: So are you aware of Secretary Clinton deleting any federal records that were on her e-mail account when she was the Secretary?
A: I don't know if she did or she didn't.

CM did not remember discussing disposition of emails with HRC while both were still at DOS.

A: I don't know that I had a particular understanding as to what she could or couldn't do with respect to those records [after HRC left DOS], because I don't know that I reflected on them.
Q: Did you ever discuss with her with respect to whether she could delete them or not?
...A: I don't recall having a conversation like that... I am aware that, with respect to records I had returned, that Judge Sullivan said to maintain records that we [I] had returned.

Complicity in deletion HRC's "personal emails"?

Q: Was there -- well, wasn't there a search of records -- of the e-mails on Clinton e-mail account to determine which ones of those were federal records and which ones were personal records?
A: We reviewed her records to determine what were federal records that should be returned or what potentially were federal records. So what we used as work-related records, and that's what was returned.

State Department's recent Office of Inspector General (OIG) report:

A: The State Department OIG issued a report in the last couple of days with respect to Secretary -- former Secretary's use of e-mail...I have not had occasion yet to review it.
A: So the FOIA office would send out from time to time FOIAs of interest. And those could be of interest for any number of different reasons. I don't obviously have what their criteria was that they would use. If those were -- if those came out and I received one of them, because I was a part of the community that would, I would look at that.
Q: Okay. And when that happened, did you at any time inform them with respect to Secretary Clinton's e-mail account and that her e-mails were stored on her account?
A: I don't recall doing that.

More Benghazzzi:

Q: With respect to the testimony that you gave to the Benghazi select committee back in September of last year, do you recall testifying that you coordinated a team of six to ten persons searching and reviewing records for requests related to the Benghazi attacks?...
A: I remember testifying about Benghazi and having a set of responsibilities for how we managed the overarching sets of challenges that were associated with the loss of our ambassador and Sean Smith.

Regarding FOIA training when coming to DOS, CM does not recall receiving any. She also denied any training about preserving federal records and Records Management of emails.

Home server issues:

Q: Ms. Mills, are you aware of -- was there a memo that was prepared by the IRM staff for the Secretary's office regarding communications equipment in the Secretary's residence which identified her server back in 2009?
A: Not that I am aware of.

The Empire strikes back, i.e. defense attorneys asking "clean-up" questions.

Q: As chief of staff and counselor for Secretary Clinton, were you responsible for day-to-day FOIA requests that came to the Executive Secretariat?
A: No, I wasn't.
Q: Were you responsible on a day-to-day basis for retention of documents, whether they were e-mails or hard-copy documents or memos that went in and out of the Secretary's office?
A: No, I wasn't.
Q: Were there people in the Executive Secretariat who had those responsibilities?
A: Yes...
Q: And was the Secretary, did she have contact directly with those folks?
A: Yes, she did.

Clinton's management style:

Q: As her chief of staff and counselor, can you explain how Secretary Clinton regularly communicated her State Department business?
A: Well, so Secretary Clinton is a person who likes to engage directly. And so typically her way
of engaging and managing the issues and people that she worked with is to meet with them one on one or in meetings that were regularly scheduled meetings. So each day she had a set of regularly scheduled meetings to meet with her staff that were the assistant secretaries and the undersecretaries, as well as others that she might be engaging with. She also received an enormous amount of paper. She's a vociferous reader, and so she would read through all the different memoranda and materials. And as a general matter she -- when she was in the department she obviously worked in her office space where she would consume most of those materials and where she would engage in most of those meetings. So most of the day she was in meetings or reading through briefing materials.
Q: When Secretary Clinton was at the State Department and in her office, did she even have the ability to e-mail from her office?
A: So to access her e-mail, her -- the SCIF was a SCIF that didn't allow for BlackBerrys to be used, or any personal devices of that nature to be used inside the SCIFs.

YOU MAY NOW LEAVE THE ROOM (AND REALISM) IF YOU BELIEVE THE NEXT EXCHANGE:

Q: Based on your knowledge and experience, what percentage of her communications doing State Department business were through e-mail?
A: Very little.

So, where did the server come from?:

A: The server preexisted Secretary Clinton's arrival at the State Department. President Clinton had established a server for the purposes of his own staff office, and -- and her -- her e-mail was subsequently put on that. That was not information I had contemporaneous knowledge of. It is information that I've come to learn over the course of my time period since then.

Did Bill Clinton also use emails on the private server to a much greater degree than which has previously been acknowledged?

Q: And are there -- is there information on the Clinton website right now about how documents were reviewed and how the server was used that's available to the public as well as the people here who asked you questions?
A: Yes.

CM's "painful testimony" before Judge Lamberth in another issue:

Q: Did you -- you said during questioning that you did not read Judge Lamberth's opinion about certain testimony that you and others gave. Is there a reason you did not read that opinion?
A: Yes.
Q: Why didn't you read it?
A: You know, I--I work--I come to government because I try to do my best. And this was obviously an opinion that was very critical of me personally. And I -- that's hurtful...

Collaboration between HRC and CM to evade FOIA requests:

Q: And did you do anything with the Secretary to avoid FOIA by having her e-mails sent -- or at least the e-mails she sent to you, on to your State.gov account?
A: No.

Executive Secretariat and Clinton's records:

Q: Ms. Mills, I just have a couple of questions. I believe you testified moments ago to your counsel in response to her question that you believed that Secretary Clinton was communicating with the folks responsible for records in the Executive Secretariat. Do you recall that?
A: So what I recall is that Secretary Clinton engages with the -- the Executive Secretary team. They all sit right outside her office, and she would engage with them regularly, correct. She engaged with them every day...
Q: In person. Is that what you meant?
A: Yes. They all sit right -- right in front of her office...I know that the Executive Secretary obviously manages all the records related to the Secretary...we had three different Executive Secretaries during the tenure when we were there. I believe when we arrived Dan Smith was the head of the Executive Secretariat, and then Steve Mull and I think in the end John Bass...They were responsible for all of her records. And if there was a FOIA request, it typically would go in to the front office,

More about the Home Server:

...the server was in place at the Clinton's residence prior to Secretary Clinton becoming Secretary. It subsequently was upgraded. And it was being used for the President's personal staff, and her e-mail was put on that server...my understanding around that was not during the time period while I was at the department...
Q: Did you learn that from Mr. Pagliano?
A: I don't know that I did learn that from Mr . Pagliano.

QUESTIONS WITNESS WAS TOLD NOT TO ANSWER:
Page 41:

Q: Okay. How did you find out about the e-mail, your e-mail account, to use at the State Department?

Page 64:

Q: ...Do you agree that you email to Secretary Clinton on January 30th, 2009, was related to your work at the State Department?.

Page 85 (re other legal counsel for HRC post-DOS):

Q: Okay. Just for the attorneys, was it also Heather Samuelson?

Page 96:

Q: Okay. Did you think -- was -- let me rephrase that. Was Mr. Pagliano an agent of the Clintons at the time that you spoke to him about the setup of the server?

Page 100:

Q: Did you ever represent Mr. Pagliano or Justin Cooper?

Page 102:

A: Oscar Flores is a personal aid to Secretary Clinton and a household employee of President and Secretary Clinton.
Q: And what did Oscar Flores tell you with respect to the setup of the server?

Page 225:

Q: Ms. Mills, did the State IG contact you to speak about a CREW FOIA request?

Page 226:

Q: Ms. Mills, did you refuse to speak to the State IG about the FOIA CREW request?

Page 235:

Q: All right. What did you do with your records, your paper records, when you left?

Pages 249-250:

Q: Okay. In the report it states that staff failed to comply with department policies intended to implement NARA [got me there, acronym fans] regulations because of these e-mails -- because of these e-mails were preserved in department record system prior to their production in 2015. How do you feel about the State OIG coming to the conclusion that you failed to comply with department policies --