Good day, deposition lovers. As promised, here is the libretto of Huma "the body person" Abedin (HA), auditioning before a panel of critics (lawyers). Performance date was June 28, 2016. Ms. Abedin sang, Huma's song.

For those needing to know more about the guest soloist, I suggest a sojourn to Wikipedia: Huma Abedin. The orchestration was a quintet of fine lawyers, proudly provided by the Department of State (DOS).

NOTICE: Like a Wagnerian Opera, this goes on far too long. The reason for the extreme length of this is that HA is second only to HRC in the DOS hierarchy. As much detail was included to satiate anyone who wants to find all the details. Strictly speaking, this record is not verbatim because a verbatim report is only useful for attorneys and cat litter boxes.

Cliff's Notes version:
1. Lots of minutiae
2. Questioning included emails that only surfaced a few days before the deposition
3. Relatively few questions witness was instructed not to answer
4. If HRC goes down, HA, at least, is going down with her--can't tell because we don't know what answers may be incomplete or downright false
5. It seems to me very likely that after reading this deposition, Judge Emmet Sullivan may compel HRC to testify.
6. Underlinings in the text are mine; emphasizing what I think may important. Other readers may find that there were important issues I did not underline. Please comment.
7. Baseball metaphors are used occasionally by me in my running commentary. For those of that don't know the game, you won't be missing anything.
8. This admittedly a long slog--took me quite a while to condense this into a legible, even though exhausting, format.
Cheers!

This is HA's first deposition.

Q: What is your current employment?
A: I work at the Hillary for America presidential campaign.
Q: And what is your position?
A: I am the vice-chair of the campaign.

Lawyer-client privilege:

Q: Are all of the documents that you've reviewed in the presence of your counsel?
A: Yes.

Scope of employment at DOS:

Q: When did you begin working for the State Department?
A: It was in January of 2009.
Q: What was your position at the time?
A: I was Deputy Chief of Staff in the Office of the Secretary. Deputy Chief of Staff for operations in the Office of the Secretary.
Q: How long did you stay at the State Department?
A: I stayed throughout her tenure, until 2013.
Q: That would be February of 2013? Is that correct?
A: That is correct.
Q: Did your position change at all while you were at the State Department?
A: Yes, it did.
Q: When did it change, and how did it -- what did it change to?
A: It changed, if my memory serves me correctly, in the last six months it was about June of 2012, and I transitioned to being a senior advisor to the Office of the Secretary.

More on scope of employment:

Q: As the Deputy Chief of Staff, what were your duties and responsibilities at the State Department?
A: My responsibilities were the long-term and short-term planning, coordinating with other senior members of the department and other agencies, and then working with the Secretary's scheduler, and her team who traveled with her, to implement her domestic and foreign travel.
Q: When you said long-term planning and short-term planning, what planning are you talking about?
A: Her overseas trips and domestic trips and
events that she would do in Washington at the
department and throughout the city.
Q: Did you continue having those roles, those duties and responsibilities, when your position changed in 2012?
A: Yes, they did.

Work after leaving DOS:

Q: Did you continue working for the Secretary when you left the State Department?
A: Yes.

Now, about that private server:

Q: I'd like to change the conversation or the questions to the Clinton server for the Clinton e-mail accounts. When I say "the Clinton server," do you understand that to mean the server that provided --or that was connected to the e-mail accounts, or the e-mail account for Secretary Clinton with a domain @Clintonemail.com?...Just for clarity of the record, I'll refer to it as the Clinton server. Can we agree, during the deposition?
When was the server set up?
A: I don't know exactly...I wasn't involved in the -- in the setting up of the server, so any answer I give -- I would give you would be my speculating.
Q: When did you first become aware of the Clinton server?
A: I don't know that I experienced the -- the notion of the server for -- for my purposes. It was a matter of obtaining an e-mail address. I -- I don't ...

Oh, you admit using the server for your own purposes--and using a private email address.

A: I didn't really think about the server until the -- all the press reports in the last year and a half --came out.

Silly me! The fact that you used the same server as HRC and you were her chief of staff during all 4 years of Medusa's control of DOS, and you didn't think about it? Oh my! I suppose you didn't know about HRC's frequent use of emails during those four years--during which time at least 62,000 emails were sent or received on that private server. Now let's see: four years equals 365 X 4 = 1460 days (which is actually longer than the U.S. was fighting World War 2). So, averaging this out: 62,000 (that we know of) emails in 1460 days, means that 45 emails traversed that server DAILY. But of course new emails keep popping up, like weeds in a garden, including those 165 emails just turned over by DOS this week. Sorry, I'm getting ahead of myself.

The reason for a new email address:

Q: You just testified that it was a matter of obtaining an e-mail address. Can you tell me more about that? Can you explain that, what you mean by that?
A: Yes, of course. In the -- towards the end of 2008, after the presidential campaign had ended, Secretary Clinton's first presidential campaign had ended and she was leaving the Senate, I was losing both my Senate e-mail, as well as my Clinton campaign e-mail. So I reached out to the person I had generally been in touch with in President Clinton's office on IT matters and asked him what I should do, since I was losing an e-mail account. I always had an e-mail account associated with the Clinton family to deal with their -- to deal with their personal matters.
Q: Was this before starting at the State Department?
A: It would have been prior to starting at the State Department when we had the conversations, because we were -- I was losing -- in the process of transitioning. So, yes.
Q: Who did you speak with for --who is the IT person that you spoke to?
A: My memory is that it was Justin Cooper, who worked in President Clinton's office.
Q: What was his position in President Clinton's office?

Just in time comes Justin Cooper to the rescue!

A: He was one of his senior staff members who traveled with him and did -- had many responsibilities, and one of them was helping with the IT support.
Q: With respect to obtaining an e-mail address, what happened after you informed Justin Cooper about the need for you to have another e-mail account set up?
A: From my memory, he had mentioned that there was an @Clintonemail.com address that he could provide for me, that he was doing a similar arrangement for the Secretary, and that we could --that I could also have that e-mail address. And he sent it to me.
Q: What was that e-mail address?
A: It was Huma@Clintonemail.com.
Q: What was the Secretary's e-mail address on that account, on that server?
A: It was HDR22@Clintonemail.com.
Q: Is Justin Cooper the only individual you spoke in that time frame about getting an e-mail account set up?
A: Justin is who I remember talking to. Over the years there were two people I talked to about IT issues. It was either Justin or Bryan Pagliano.
Q: We'll get to Mr. Pagliano. But just for clarification, with respect to your
communications with Bryan Pagliano, were those -- once the e-mail account was set up and dealing with technical issues? With respect to your conversations with Mr. Pagliano, was that in connection with setting up the e-mail account?
A: My memory is I talked to Justin. Justin, for the many years before, was our primary point of contact. Frankly, every time anything was broken, you called Justin, it got fixed very quickly. Justin was usually my primary point of contact. Were there times when I called him and said, You should consult with Bryan, yes. I don't remember the time frame. I know Bryan wasn't really involved in anything related to IT for the Clintons until the campaign, the 2008 presidential campaign.
Q: When Mr. Cooper advised you to go and consult with Mr. Pagliano, do you recall the issues?
A: It was usually if our e-mail wasn't working, you know, there was a delay, can't figure out what's going on. I would call Justin. Usually Justin would just fix it over the phone. But were there periods where he said, Call Bryan? Absolutely.
Q: Do you know why the Clintonemail.com system was set up? Why was the e-mails with the Clinton @Clintonemail.com created?
A: As I mentioned earlier, I was losing both my e-mail addresses at the end of the presidential campaign and the Senate. So
both my, you know, Clinton e-mail addresses were going. I needed a new e-mail. I remember just reaching out and saying, what should I do. I'm no longer going to have HillaryClinton.com, and he suggested @Clintonemail.com being an option.

Now we get Hillary and setting up the private server:

Q: At that time did Secretary Clinton already have an e-mail account associated with the @Clintonemail.com?
A: She had an e-mail account, yes. It was not @Clinton e-mail. It was another e-mail that it was associated with the BlackBerry she was using during the presidential campaign.
Q: What was that e-mail address?
A: I think it was HR15@AT&T.BlackBerry.net.
Q: When did you first become aware of the HDR22@Clintonemail.com account for the Secretary?
A: It would have been around the same time. We were both transitioning around the same time.
Q: Do you know why Secretary's e-mail address was set up?
A: Yes. As I mentioned, she had had a previous e-mail account that was on her BlackBerry. She had had been experiencing technical issues. She had been having problems with that BlackBerry, with that e-mail address. And so they also gave her an @Clintonemail.com address so they could help with IT issues.
Q: Do you know if anyone else had any involvement on the technical side of setting up the Clintonemail.com system, other than Justin Cooper?
A: I don't know who else was involved.
Q: Do you know who paid for the server?
A: I don't.
Q: Do you know who paid for setting up the Clintonemail.com system?
A: I don't know.

Who else had private server access?

Q: How many e-mail accounts were associated with the Clintonemail.com system --in 2009?
A: My understanding was Chelsea.
Q: Chelsea. And nobody else from the State Department had an e-mail account associated with the Clintonemail.com system that you know of?
A: That's correct.

Now, mixing business with personal email:

Q: When you came to the State Department, were you also assigned an e-mail account issued by the State Department?
A: Yes, I was.
Q: What was that e-mail account?
A: That was AbedinH@State.gov.
Q: Did you use that account for your state-related work?
A: Yes, I did.
Q: Did you also use your e-mail account that was issued with the domain @Clintonemail.com for your State Department work?
A: My practice was to use my State.gov e-mail. I did the vast majority of my work on State.gov, at my computer and on my BlackBerry when we traveled. And I used Clinton e-mail for just about everything else. I used that for the Clinton family matters and, frankly, I used it for my own personal e-mail, as well.
Q: But you also used it at times for state-related matters?
A: Yes. There were occasions when I did do that, correct.
Q: Were there occasions when you used that with Secretary Clinton, where both of you used only the Clintonemail.com accounts?
A: There were occasions when that occurred, yes.
Q: When you were working at the State Department, other than your Clintonemail.com account and your State.gov account, did you have any other e-mail accounts that you used at any point for work-related matters at the State Department?
A: I had a Yahoo.com e-mail account that was purely a personal account where -- that I rarely used. But there were occasions when I forwarded State Department press clips to that account to be printed.
Q: Any other e-mail accounts that you used when you were at the State Department?
A: No.

Okay, Huma, you may be going to jail for using the private server for State business. Maybe you will have adjoining cells with the Ice Queen--if the FBI starts on your criminal/espionage case.

Now we come to the "It was allowed" claim by HRC:

Q: Other than your State.gov e-mail account, did you have access to any other e-mail accounts for your State Department-issued BlackBerry?
A: No. We were not allowed to have another e-mail account on our State.gov devices.

Q: How is it that you came to be issued a BlackBerry by the State Department?
A: My recollection was it was part of the transition process into the State Department. If I remember, somebody came into my office and gave me a box with a BlackBerry in it, and I signed a form.
Q: So you didn't ask anybody for a state-issued BlackBerry; you were just given one?
A: I don't remember asking. I experienced it as just part of the transition that the new staff at the State Department was receiving, at least in my office.

Wiggle room for HRC and HA?

A: I don't specifically remember the person who handed me my BlackBerry, no.
Q: Were there any discussions during the transition about Secretary Clinton having a BlackBerry for her e-mail use?
A: I don't remember any conversations during the transition period about giving her a State Department BlackBerry. The only
conversations I remember were a few months in, where she had requested a secure BlackBerry, but that did not come to fruition.
Q: Did the Secretary have a BlackBerry for her use while she was the Secretary of State?
A: Yes, she did.
Q: How did she come to have that BlackBerry?
A: That was the BlackBerry that she had received, in late 2008 at the conclusion of the presidential campaign. It was her personal BlackBerry that she came in with.
Q: What e-mail account was associated with that BlackBerry?
A: That was the HDR22@Clintonemail.com.

"Convenience" is now broached:

Q: Did the Secretary have any other electronic devices, such as smart phones, iPads, mini iPad, that was also connected to her @Clintonemail.com account...anytime during her tenure at the State Department.
A: While she was at State, she did obtain an iPad, and that did have her e-mail account. She could access her e-mail on that iPad. It was not her practice to do so, but when her system on her BlackBerry went down, there was a period where I know she did use her e-mail on her iPad for maybe a week or two, if I remember correctly.

Now, weren't some of those system "breakdowns" due to shutting the server down because of hacking?

Q: During the transition period or shortly after, so late 2008, early 2009, did you and the Secretary discuss your use of the e-mail with a domain @Clintonemail.com for State Department work?
A: I have no recollection having a conversation like that with her.

Here comes the don't know nothin' 'bout no people part. The same theme present in ALL preceding depositions (except for, of course, Bryan Pagliano, who consumed many fifths on the day of his hearing).

Q: Did you have any such discussions with anybody else at the State Department?
A: Any discussions, I'm sorry, about?
Q: About your use of the Clintonemail.com account for State Department work-related matters.
A: I don't remember having any specific discussions, but the address, it wasn't -- people there -- or is it -- are you okay?
Q: Yeah.
A: Sorry. But people at the State Department did have my Clinton e-mail account. When State.gov was down, that's how they contacted me, communicated with me.
Q: Who at the State Department had access to your e-mail, to your Clinton e-mail account?
A: I couldn't tell you exactly name by name who had my Clinton e-mail account. It generally was people individuals who needed to communicate, send me a schedule if we were overseas and State.gov was down, the individuals at State who had to send the schedule for the next day or send a document would send it to Clinton e-mail, generally cc State.gov. But I would have given that address to people as my secondary address when State.gov wasn't working.
Q: How did they obtain your e-mail account?
A: I would have provided my e-mail address to my colleagues who would need to reach me, particularly if we were overseas.

The topic shifts to what HRC and when she knew about being allowed. Note: I usually edit the data to make it more readable, but this time, I will present HA's answer, just as she stammered it:

Q: What about Secretary Clinton; did she have any discussions with anybody at the State Department -- and this is again in the early 2008, two thousand -- late 2008, early 2009 time frame -- about her use of her Clinton e-mail account for State Department business?
A: I--I--I don't know. I--I don't know.

Enough about you, Huma, let's talk about Hillary:

Q Do you know why did the Secretary not continue using her HRC15@ATT.Blackberry.net account exclusively, like she did when she was Senator?
A: I think I mentioned earlier she was having problems with that AT&T address. Throughout the presidential campaign she was using it, throughout the 2008 presidential campaign, and was constantly having issues. And so we -- it was just a natural
transition. It came with a new device and a new --a new e-mail address. It was just technical difficulties.
Q: What came with a new device?
A: HDR22@Clintonemail.com.
Q: Did you, during that time frame again, discuss with Secretary Clinton about having a separate e-mail account for state business and having a separate e-mail account for your personal matters?
A: I don't remember having conversations like that with her, no.
Q: Do you recall any discussions in late 2008, early 2009, about Secretary Clinton having an e-mail issued by the State Department for her state-related work?
A: No, I don't remember.
Q: Do you know why Secretary Clinton did not want to use a state-issued e-mail account for her state-related work?
A: So from my understanding, I just saw it as continue doing what she was doing before she arrived at the State Department.
She had always had a personal device since she had started using e-mail. That's what she used when she was in the Senate. She did not have a Senate.gov account. And she also did not have a Hillary Clinton campaign account.

Translation: Hillary Clinton was not going to be bothered by trifles such as national security.

Was it "allowed" that HA flaunt security a la HRC?

Q: When you started at the State Department and provided your e-mail address to some of the colleagues associated with the Clinton e-mail account, did anybody tell you not to use the Clinton e-mail account for work-related purposes?
A: Well, I don't -- I don't -- I don't remember a specific conversation like that. But as I -- I think I mentioned earlier, we used State.gov for work. That was my work e-mail address. That was my work BlackBerry. That was my primary BlackBerry, particularly when I traveled. I traveled a good percentage of my life was on the road, and my State Department BlackBerry was my primary. So I -- I always tried to do the right thing and tried to be on my State.gov BlackBerry. That was my practice. And using Clinton e-mail was not -- was not something that I -- I understood as my primary work e-mail, aside from personal matters as they related to the Secretary and her family and her friends, and then my personal e-mails.

So, HA is not going to fall on her sword for Hillary--but future developments will show whether HRC will thrust her sword into HA.

For those of you who feel as if this is somewhat like an echo chamber, you are not mistaken. Just like the picadors coming at the bull from different directions, those pesky JW lawyers are doing it to HA:

Q: But did anybody at the State Department tell you not to use your Clinton e-mail account for State-related purposes?
A: I don't remember a specific conversation with somebody telling me that. And I assumed it was okay to do. I don't --as I've stated earlier, my practice was to use State.gov for my work e-mail. Did I think I wasn't allowed to use Clinton e-mail? No. I thought I -- I thought that was permitted. But my practice was to use State.gov.

Well, if HRC could do that, why couldn't HA used the private server for government work? Surely, the Boss lady would be doing everything on the up-and-up.

Q: Do you know if anybody at the State Department told Secretary Clinton not to use her Clinton e-mail account for State-related matters?
A: Not that I'm aware of.
Q: Do you recall when Secretary Clinton first began using her Clinton e-mail account?
A: It would have been I -- early 2009; late 2008, maybe early 2009.

How about the previous BlackBerry?

Q: Just briefly going back to the Secretary's HR15@AT&T.BlackBerry account. Does she continue using that during her tenure at the State Department?
A: I believe that transitioned out. I think that just went away, and she transitioned to the Clinton e-mail account. I don't know if there was any overlap, and if it was during that transition time. But she transitioned to Clinton e-mail. I certainly was not e-mailing her at that account [HR15@AT&T.BlackBerry]...I think the HDR22 was the only e-mail address she used, aside from the transition period from the AT&T e-mail address. And then either towards the end of her time at State or after she left State, she transitioned to another e-mail address.

Access between HA and HRC emails:

Q: You accessed your Clinton e-mail account via your BlackBerry associated with that account. Right?
A: I had a BlackBerry, and I could access it from a desktop, as well.

Clarence Finney back in the news:

Q: Who is Clarence Finney during your time at the State Department?
A: He was responsible for the records and management office.
Q: Did Mr. Finney know about your Clintonemail.com account?
A: I don't know.
Q: Did you ever give him your e-mail address on the Clintonemail.com account?
A: I don't remember if I specifically gave it to Clarence.
Q: How did you normally communicate with Mr. Finney?
A: I remember two specific occasions when we had first arrived, of having a meeting with my team about the kinds of materials that we could bring in. The Secretary did have a lot of personal files coming in with her. And discussing what we would bring in and where it would go. And then I remember before we left we had a meeting again with the same team and Clarence about what we were allowed to take. And he instructed us on the process that we needed to go through to review our materials and place them in boxes, which his office -- he and his office then reviewed and pulled out what they determined we
could not take with us, and the other boxes we were allowed to leave with.
Q: Do you know if Mr. Finney was aware of Secretary Clinton's e-mail on the Clintonemail.com system?
A: I don't know if he was.

Getting back to the beginning of the line-up:

Q: Do you know Stephen Mull?
A: Yes. I saw Steve during the period that he was Executive Secretary I saw him every day.
Q: Did you provide your e-mail account associated with the Clintonemail.com system to Mr. Mull?
A: I can't remember if Steve had it.

Q: Do you know Mr. Lukens?
A: Yes.
Q: Did you interact with Mr. Lukens during your time at the State Department for work-related matters?
A: Yes. On a daily basis, and in many countries around the world.
Q: Did you provide him your e-mail address associated with your account on the Clintonemail.com system?
A: You are testing my memory. I don't know if Lew had it, but I would be surprised if he didn't. Because a lot of times State.gov wasn't working was when we were overseas, and so many people would sometimes they would e-mail me on my State.gov address and cc my Clinton e-mail. So it wasn't -- it wasn't unknown.

Oops. Lew, looks like you got some 'splaining to do. Apparently, HA isn't going to fall on her sword for you either--this testimony contradicts LL's deposition profession of ignorance.

Q: Do you know if Mr. Lukens was aware of the Secretary's e-mail account associated with the Clintonemail.com system?
A: Lew would have been aware that the Secretary was e-mailing on her BlackBerry. It was something that she did on a regular basis and very actively when we weren't in the office. And as I mentioned earlier, he traveled everywhere with us. So he was aware that she was e-mailing, and that she had a BlackBerry device. I don't know that Lew had her e-mail address.

HA did not read HRC's emails! Oh, yeah. That's a good one. Even Foreign Ministers from other nations had to go through HA to talk to her Heinous:

A: I wasn't reading her e-mails. There were -- there -- so I couldn't tell you specifically what she was e-mailing about. But there was certainly a lot of personal things she was e-mailing on that device. And she did use that address to stay in touch with the department when she was traveling. But it was not where she did most of her work, since most of her work was done in person or by paper or on the phone.
Q: But is it fair to say that the Secretary e-mailed frequently for State-related matters via her BlackBerry?
A: I have no way of knowing the answer to that question.

Q: Do you know if Mr. Lukens was ever told that the Secretary was using her BlackBerry only for personal matters?
A: I don't know.
Q: Did you ever tell Mr. Lukens that the Secretary was using her BlackBerry to e-mail for personal matters only?
A: I don't recall having a conversation like that with Lew.

Q: Is that something you would have told anybody during your time at the State Department?
A: I don't know that it would have -- I don't know that it would have occurred to me. So, no, it doesn't -- I don't know -- I don't know why that would -- why that would occur to me.
Q: Well, because the Secretary used her e-mail account for State Department matters, as well. Correct?
A: Yeah. Yes, she -- she absolutely did that. She absolutely did that. She was e-mailing with many people at the State Department and outside the State Department. So it's -- it wasn't a secret that she was using this e-mail account to be communicating with U.S. government officials, because they were receiving e-mails from her.

HA is casting a wide net to snare the co-conspirators, dupes, amnesiacs, and other incompetent DOS staffers. Maybe, they'll be getting all-expense paid vacations at Club Fed (aka Graybar Hotel). I like that one so much, let's play it again:

A: Yeah. Yes, she -- she absolutely did that. She absolutely did that. She was e-mailing with many people at the State Department and outside the State Department. So it's -- it wasn't a secret that she was using this e-mail account to be communicating with U.S. government officials, because they were receiving e-mails from her.

More about "it was allowed":

Q: Upon becoming the head of the agency, did the Secretary request authorization from anyone at the State Department to use her Clintonemail.com for State Department business?
A: Not that I'm aware of.

Hillary set the example, so why shouldn't HA do the same?

Q: When you e-mailed with the Secretary via your Clintonemail.com account during your time at the State Department, did Secretary Clinton ever object to your use of that account for State Department business?
A: No, not that I remember. No.

Roster of potential witnesses:

Q: Who else was in the Office of the Secretary during your tenure at the State Department? Who else worked within the Office of the Secretary?
A: She had a primary assistant in the office, who is a career foreign service officer who sat outside her office. Claire Coleman. She had a personal aide, Monica Hanley, who traveled with her and also was in the office to provide support. She had a director of scheduling, Lona Valmoro, and Linda Dewan, who also assisted with scheduling, primarily in the building is what Linda was responsible for. There was the executive assistant, it was Joe Macmanus for a period, and then Alice Wells for a period. There were two line officers. They changed over time, that were responsible for the paper that went in and came out of the Secretary's office. Dan Fogarty, who was a civil servant, who was responsible for the official correspondence when Secretary Clinton went overseas, to do thank-you notes. Rob Russo, who was responsible for all of her personal correspondence. Lauren
Jiloty...Her personal correspondence related to non-State Department work. So her friends from Chicago sending her a letter, Rob would process those.

More on who was in the inner sanctum:

A: Cheryl Mills, our chief of staff, our counselor and chief of staff. Cheryl had two staff who worked outside her office. Jake Sullivan who was my co-deputy chief of staff for a period, and then he went on to be the director of policy planning.
And then our offices extended to the deputy secretaries on either side...Lauren Jiloty was her assistant in the office as well. She provided support to Claire. And she would often travel, she and Monica [Hanley] switched out traveling. And then she left, but she was not there for the entire tenure...She communicated with all the individuals on that list on a regular basis every day in the office. And then when she was on the road, some combination of these people were either with her or she spoke. She would call back to the department on a regular basis when she was overseas.
Q: To the extent that you know, did the Secretary communicate via her e-mail account with leadership of the State Department?
A: Yes, she did.
Q: That would include Patrick Kennedy?
A: I would imagine it included Pat Kennedy.
Q: How about Harold Koh?
A: Same. I don't know if Harold e-mailed with her directly. But both of them were part of the senior team that met with her every day. And everybody was aware that she would e-mail. So the short answer is I don't know if Harold specifically e-mailed with her, but I believe he did.

Did people outside DOS know about the private server?

Q: Then also during the Secretary's tenure at the State Department, to the extent that you know did she also e-mail to communicate with government officials outside the State Department for State Department business?
A: Yes, she did.

How about accounts on Bill Clinton's email domain?

Q: Did you have an e-mail account with the domain PresidentClinton.com during your time at the State Department?
A: No, I did not.

Who did the IT on the private server?

Q: During your tenure at the State Department, who oversaw the operation of the Clintonemail.com system?
A: I can speak to when I was having challenges with my e-mail or delays or when the Secretary was and I would call Justin or Bryan, depending on the time. And as I think I may have indicated before, I'm unclear, I'm a little fuzzy on when it was Justin versus Bryan [Pagliano], but it was one of the two of them. I usually reached out to Justin, and he would say on this -- you know, ask Bryan. It was usually Justin. I think I probably just e-mailed with him, probably, and said it's not working, can you help fix whatever specific matter it was.

Okay, Mr. Cooper, exactly what was your security clearance when you were noodling around in HRC's server? Maybe we'll get to that later.

Q: Did you e-mail Mr. Pagliano to his State Department-issued e-mail account?
A: I'm not sure. I'm not sure if I did.
Q: Did you have an e-mail address for Mr. Pagliano over than his State Department e-mail address?
A: I believe the e-mail address I would have used would have been what we had prior to coming to the State Department. So I don't know if it would have been a Gmail. I'm completely speculating if it was --I don't know where I e-mailed Bryan. I don't know where I e-mailed Bryan. It was not that frequent. This was not something that happened very often.

More about Bryan Pagliano:

Q: Did you ever e-mail with Mr. Pagliano prior to May of 2009 about e-mail issues with the Clintonemail.com system prior to May of 2009?
A: I don't know.

Q: Did you ever interact with the IRM office [information resource management--IT] for the Executive Secretariat, when you were at the State Department, for e-mail-related issues?
A: I'm sure I did. Usually if there was a problem with State.gov e-mail, we just picked up the phone and called the help desk and said, I'm having a challenge. If I was in the office somebody would come over and address it. If we were on the road we would ask our colleagues who were traveling with us for assistance. So I don't have a specific name of a person that I would have worked with in that office to address e-mail issues.

Note: when the problem was with the private server, HA would usually contact Justin Cooper (JC) or Bryan Pagliano (BP). But when the problem involved State.gov system, it was (usually) IRM at DOS.

Q: Did you ever raise issues with the Secretary's e-mail account with someone in that [IRM] office?
A: I may have.
Q: Do you recall who you would have raised that issue with?
A: I couldn't tell you. I don't know that I could name people who worked in that office.
Q: Did you ever discuss any of the e-mail issues that Secretary Clinton had for use at the State Department with Lewis Lukens?
A: I don't remember having any conversations with Lew about it. But I just don't remember conversations specifically with Lew.
Q: How about with Mr. Mull?
A: I remember an exchange with Steve during a specific period, during a hurricane, about challenges she was having, yes.
Q: What was that exchange?
A: Just that she was having communications issues in the midst of a hurricane...But I think it was Hurricane Irene. And I was pregnant.

Q: When you say "communications issues," that included e-mail issues for the Secretary. Correct?
A: It did, yes.
Q: Who else at the State Department was also assisting with trying to resolve the e-mail issues that the Secretary was having at that time?
A: From my memory it was our chief of staff and it was Steve, and her assistant who was with her. The Secretary's assistant, Monica Hanley..

Who else at DOS knew about BP providing IT service on the private server?

Q: Do you know if Patrick Kennedy was aware that Mr. Pagliano was providing technical support for the Clintonemail.com system during his tenure at the State Department?
A: I don't know.
Q: Who at the State Department, as far as you know, knew that the server for the Clintonemail.com system was located in Secretary Clinton's residence in New York?
A: I don't know.

There we go again, that pesky "it was allowed" question.

Q: Ms. Abedin, just a couple followup questions in relation to Secretary Clinton's e-mail account. Who gave the BlackBerry and e-mail address to Secretary Clinton?
A: I don't know. I suspect it was Justin, who gave it to me, as well.
Q: Do you know who actually set up the server?
A: No, I don't.

Convenience?

Q: I believe your testimony earlier this morning was that you came to understand that Secretary Clinton was continuing her practice to use a personal account for the reason for having the Clintonemail.com account.
A: She had one BlackBerry device with one e-mail account. She had always had one BlackBerry device with one e-mail account that she used as her primary e-mail. And it was a device and an account that she provided personally.
Q: How is it that you came to learn that she preferred to continue that practice at the State Department?
A: It was in the course of normal business, she carried that one device and continued working on that one device as we were at State, as she had the previous years.
Q: But you didn't actually have conversations with the Secretary about her wanting to continue that practice at the State Department?
A: I can only tell you what I observed, which is her continuing to use one device and one e-mail account.

Was it a general practice at DOS to have separate email accounts?

Q: You also testified that you were prohibited to have other e-mail accounts associated with your State Department-issued BlackBerry.
A: Yes. That was my understanding.
Q: How did you come to have that understanding?
A: It was just a general knowledge amongst those of us who were coming in from the outside, joining the State Department. The political appointees who came in, many people came with separate devices. And we understood that we were not able to put the Gmail accounts, if you will, or whatever additional e-mail accounts, onto our State Department BlackBerrys.
Q: Did anybody from the State Department inform you that you couldn't have a separate e-mail account put on your State
Department-issued BlackBerry?
A: I don't remember a specific conversation with a State Department official. I do know what all of our understanding was that we could not, on the State Department device that we were carrying, we were not allowed to put any other accounts on there. That was clear.

It was "general knowledge" but nobody thought to inform the SOS that they couldn't have private email? Well maybe they did, but probably they wanted to keep their jobs (speculating on my part).

Q: Do you know why you were not allowed to have other e-mail accounts associated with your State Department-issued BlackBerry?
A: I don't know. I only know what I practiced, which was the two different BlackBerrys.

Q: Did you consult with anyone from Clarence Finney's office about the use of the Clintonemail.com for State-related matters? And when I said "you," either for -- on your behalf or on behalf of the Secretary.
A: I don't recall any conversations.
Q: Did you or the Secretary or anyone on behalf of the Secretary consult with anybody in Patrick Kennedy's office about your use of the Clintonemail.com accounts for State Department business?
A: Not that I remember.
Q: How about with anyone in the IRM office or the Executive Secretariat; did you or the Secretary or anyone on behalf of the Secretary consult with them about your use of the Clintonemail.com accounts for State Department business?
A: Not that I remember.
Q: Did you consult with anybody at the State Department or did the -- Secretary Clinton consult with anybody at the State Department or anyone on her behalf about the use of the Clintonemail.com accounts for State Department business?
A: I don't remember any conversations like that.

So the co-deputy chief of staff is unaware of anyone seeking legal guidance as to the operation of the private server.

Q: Did you consult with anybody at the State Department about your use of the Clintonemail.com account for State Department business?
A: I used my State Department e-mail, and that was my practice. My Clinton e-mail account, as I think I said earlier, wasn't something I kept hidden. It was shared with people, people at State used it particularly when State.gov was down. I used it. I assumed it was okay to use it. I wasn't told that I couldn't use it. But my practice was to use my State.gov

The previous is a re-iteration of "other people in the DOS knew about the private server and HA's use of it.

Q: But the question is whether you consulted with anybody at the State Department about your use of the Clintonemail.com system for State Department business.
A: I shared that e-mail account with people at the State Department. I do not remember a conversation, a specific conversation that I had, no.

Q: Do you know if Secretary Clinton or anyone on her behalf consulted or spoke with anybody at the State Department about her use of her Clintonemail.com account for State Department business?
A: I don't know.
Q: Do you recall a memo that Secretary Clinton had issued in 2011 to the State Department agency-wide that employees should only use their State Department e-mail accounts for State Department business?
A: I don't remember a memo -- specifically a memo like that, no.
Q: Do you remember any instruction or directive that the Secretary gave to employees at the State Department not to use their personal e-mail accounts for State Department business?
A: No, I don't.

Q Did you ever discuss with the Secretary the issue of State Department employees using their personal e-mail accounts for State Department business?
A: I don't remember.
Q: Did you ever discuss that issue with Cheryl Mills?
A: I don't recall.
Q: Do you know whether Secretary Clinton and Cheryl Mills ever discussed that issue?
A: No, I don't.

Referring to Exhibit 2, appended to this deposition, comes the following interchange:

Q Okay. So I'll just summarize what the document appears to be. If you agree that it seems to be an exchange of e-mails relating to a meeting with you in or around December 17, 2010.
A: Yes.
Q: Could you look at Page(s) 9 and 10 of the exhibit. And then do you see the last e-mail -- I'll point you to the last e-mail on Page 9, dated December 17, 2010, from, it appears to be Cindy T. Almodovar, to S/ES-IRM-tech. Do you recall having a meeting with Cindy Almodovar on December 17, 2010, to go over mail issues?
A: I don't remember meeting with Cindy on that specific date. But I now can see from the exchange that we did meet.She was at the -- in the IT tech department. If we had challenges with our e-mail,
Cindy was one of the people who we contacted.
Q: That's the IRM office for the Executive Secretariat with the designation S/ES-IRM.
A: That's correct.
Q: Can you tell me what the substance of the meeting was?
A: It appears from this document that there were e-mails being sent from the Clintonemail.com e-mail addresses to State that
were not being received.
Q: That Secretary Clinton was having that issue with her e-mail?
A: It appears as though I was having that issue, as well.
Q: Do you know Ms. Almodovar's position with S/ES-IRM within the State Department at that time?
A: This e-mail says she is the supervisory systems administrator, IRM POEMS help desk. I don't remember the meeting, so I
couldn't tell you what the specifics in the meeting. I think they're reflected in this document. But I think it suggests that we were having communication challenges between the two e-mail accounts.
Q: This is communication challenges between the two e-mail accounts for you and Secretary Clinton at the Clintonemail.com to
State Department e-mail accounts. Correct?
A: Yes. I mean, it appears as though it was both. It was not just Clinton e-mail. There is a House.gov e-mail account listed here, as well. And that e-mail also did not get through to the State.gov e-mail system.

More about IT matters:

Q: What I read at the bottom of the e-mail, on Page 9 I think it says, "I have a contact for the @Clinton e-mail site. His name is Bryan Pagliano, and he actually now works for State. But he apparently set all of this up." Did you inform Ms. Almodovar that Mr. Pagliano was the contact, and that he set the whole system up?
A: I don't know that that's information I would have given her.

Bingo: a definite connection between BP and the set-up of the Private Server. So that makes the prior pseudo-deposition (Pagliano's Symphony number 5) much more important. There's two ways this door swings: one is toward BP (who has already taken refuge behind the Fifth) and the other direction is to HRC herself. At this point, although I am not a lawyer, it would be safe to assume that HRC will be invited to give her side of the story--in person.

Dear readers, those few of you who have been patient enough to read this far (yawn), we come to another spin on the merry-go-round, or haven't we heard this before?

Q: Were there other occasions when you met with somebody about technical issues with the Clintonemail.com system from the IRM office for the Executive Secretariat?
A: I don't remember. There were occasions where we had technical challenges, and I reached out to whoever I thought could help.
Q: Other than Cindy Almodovar, do you recall any other individuals in the IRM office for the Executive Secretariat who you
exchanged or discussed e-mail issues for the Clintonemail.com system?
A: I don't remember, no.

Speaking about resolving IT challenges:

Q: Do you recall how the issue was resolved?
A: I can't explain a lot of what exchanges they sent I actually don't understand, reading through these e-mail exchanges they had amongst themselves that I am not on. They clearly took some actions that made our e-mails actually go through.
Q: Did the issue resolve with the Clinton e-mails actually being able to go through to the State Department e-mail accounts?
A: Well, and also to a house account.

Interesting. Should we now be looking for another source of Clinton emails in this "House account"?

More on email challenges, other than those cited in Exhibit 2:

A: So this was not the only occasion where we had challenges, where somebody said, I sent an e-mail and it didn't go through or not.
Q: In connection to that meeting and the issues that you and the Secretary were having with the Clinton e-mail dot com accounts do you recall any conversations or any exchanges with Bryan Pagliano about that?
A: There were occasions where I communicated with Bryan when I was having technical issues. I don't remember specific time periods. But there were instances where I did have to communicate with Bryan or Justin, yes.

Remember, lawyers get paid by the hour, hence a rationale for this repetitious questioning (my apologies to any attorneys who may be reading this, but you know what I mean).

Still referring to Exhibit 2:

Q: On Page 4, if you can take a look at the second full e-mail from, it looks like Trey Jammes to Thomas Lawrence and some other individuals on December 21st, 2010, at 2:39 p.m. Do you see that e-mail?
A: I do.
Q: Do you know who Trey Jammes is?
A: I don't.
Q: How about Thomas Lawrence?
A: No.
Q: And I'm just going to go through all the individuals in the e-mail. Do you know who Kenneth LaVolpe is?
A: No.
Q: How about Jay Gazlay?
A: No.
Q: What about Ebenezer Mensah?
A: No.
Q: Do you know who Nancy Wilson is?
A: No.
Q: So as far as you recall, you did not exchange or you did not communicate with them in relation to the e-mail issues that you and the Secretary were experiencing.
A: It appears as though Cindy was my point of contact, from looking at the exchange.

That was a nice non-response to the question.
So, let's move on to more emails:

Q: Have you seen Exhibit 3, looks like it's a string of e-mails regarding the Secretary's e-mail account and your e-mail account in or around January 9th and 10th of 2011.
A: Yes
Q: Do you recall there being an issue with the server for the Clintonemail.com system being attacked, as Justin Cooper said on the second page of the exhibit?
A: Yes.

The famous hack attack.

Q: Can you tell me what you recall about the issue with the server?
A: Just really what's exchanged in this e-mail. Justin saying, I think from -- for my experience, my e-mail wasn't working. I reached out to Justin. He said he was dealing with some technical -- in this case he suggested what -- somebody was trying to get in -- hack us, I'm quoting Justin. And for my purposes it was a matter of my e-mails not coming through for a while, and then from my memory it restored pretty quickly.
Q: When you say your e-mails weren't coming through, is that your e-mails to your Clintonemail.com account?
A: Yes

Okay Hillary, now tell us again how secure your server was.

Now, about more fingers in the pie:

Q: Who is Doug Band?
A: Doug Band used to work for President Clinton.
Q: When did his employment for President Clinton terminate?
A: Sometime in the last few years. He was President Clinton's senior advisor, chief of staff, in the period after he left the White House.
Q: Do you know whether he was involved in any way with dealing issues with the Clinton server?
A: Not that I'm aware of.
Q: Do you know why Justin Cooper included him on the e-mail to you on January 9, 2011?
A: Aside from the fact that he was probably informing Doug as well about the issue. Doug was somebody who worked with Justin in President Clinton's office.

Presumably, since Bill was no longer in the WH, then we can assume that Doug Band lacked sufficient security clearance to read this DOS emails.

Q: Did you ever contact Doug Band when you ever had issues with the Clintonemail.com account?
A: He was a very close colleague of mine. And we talked all the time and communicated all the time. I don't remember Doug
being a person I would go to on technical issues.
Q: Do you know if the Secretary ever contacted Doug Band when she encountered issues with her Clintonemail.com?
A: Not that I'm aware of
Q: Do you know whether Doug Band provided any technical support or services for the Clintonemail.com accounts during your tenure at the State Department?
A: No, I don't believe so.

Back to Exhibit 3:

Q: Then the last page of the exhibit? That's an e-mail from you, it looks like to Jacob Sullivan and Cheryl Mills on January 10, 2011. And after you've reviewed these documents, what do you recall about the e-mail exchange between you and Jacob Sullivan and Cheryl Mills on January 10, 2011?
A: Since my e-mail to my colleagues at State was probably not knowing how Justin was resolving this issue, just informing them that she [who is "she"? CM or HRC] wasn't going to have access to e-mail. I just sent them this message so I could explain by the phone, or in person, as I say here.
Q: Where you write, "Don't e-mail HRC anything sensitive," HRC refers to Secretary Clinton. Is that right?
A: Yes.
Q: Then you write, "I can explain more in person."
A: Yes.
Q: What did you explain to Ms. Mills and Mr. Sullivan?
A: Looking at this e-mail chain, I would have informed them in person what Justin had told me by e-mail.
Q: That the server was hacked?
A: I don't believe that's what his e-mail said.
Q: Well, I'm sorry, but I thought you testified that you reviewed the document and the documents have refreshed your recollection.
A: Yes. Yes. Yes.
Q: What do you recall about the explanation that you provided to Ms. Mills and Mr. Sullivan?
A: I wouldn't be able to recall the conversation exactly. But having seen this chain, what I would have said is, Justin e-mailed me to tell me that someone was trying to hack the system, and I would have told them that. I would have told them that in person.

What do have to say about that, CM? Think you might be invited back to give some clarifications?

FOIA training, or lack thereof:

Q: When you started at the State Department, were you provided any training or guidance with respect to the Freedom of Information Act? And I will shorten that by referring to it as FOIA.
A: I don't remember a specific FOIA briefing or training.
Q: Do you recall being provided any manuals that dealt with FOIA when you started your tenure at the State Department?
A: I may have been provided. I don't remember the manuals.
Q: Do you know whether Secretary Clinton received any guidance or if anybody consulted with her about FOIA upon her entering her tenure at the State Department?
A: I don't know. I wasn't in all briefings with her.
Q: Are you familiar with FOIA?
A: Yes.
Q: During your tenure at the State Department, were you aware that federal records belonged to the agency?
A: Yes.

But Hillary, you didn't know what your underlings knew?

Q: Were you aware, during your tenure at the State Department, that you had an obligation to preserve those e-mails?
A: The e-mails on my State Department system existed on my computer, and I -- I didn't have a practice of managing my mailbox other than leaving what was in there sitting in there. So for my BlackBerry, if I exceeded the limit, I think it auto deleted. But, no, I didn't -- it wasn't my -- I didn't -- I didn't have a -- I didn't go into my e-mails and delete State.gov e-mails. They just lived on my computer.
Q: The question is not just limited to State.gov e-mails; it's in connection to all of your e-mails for State Department business.
A: That was my practice for all my e-mail accounts. I didn't have a particular form of organizing them. I had a few folders, but they were not deleted. They all stayed in whatever device I was using at the time or whatever desktop I was on at the time.
Q: To clarify for the record, when you say you had a few folders set up is that on your e-mail account, or are these physical folders that you had set up?
A: It would have been folders on my Outlook account on my State Department computer.

According to this testimony, HA did not delete any of her own emails from State.gov or Clinton private server.

Q: Could you access your Clintonemail.com e-mail on your desktop at the State Department?
A: Yes.
Q: Did you access your Clinton e-mail dot com?
A: Yes, I did.
Q: Did you do that for State Department business?
A: I did that when I was working or responding to e-mails that came in. I couldn't check my Clinton BlackBerry, I didn't have access to my Clinton e-mail BlackBerry when I was in the office, so it was the only way I could check my Clinton e-mails.
Q: How did you access your Clintonemail.com account off your desktop?
A: It was a fairly simple login system. It was through a web browser. It was just Safari or ...

Doesn't seem too secure to me.

More on FOIA:

Q: During your tenure at the State Department, were you aware of your obligations to search your e-mails for State-related business under FOIA?
A: It was never a matter that was raised with me. I was never asked to search my e-mails for anything related to FOIA when I was at State, that I ...
Q: I guess that's my question. Did you ever search your State.gov account for any e-mails in response to a FOIA request or litigation?
A: No, I did not.
Q: Were you ever asked to search your State.gov e-mail account in response to a FOIA request or FOIA litigation?
A: No.
Q: Were you ever asked to search your Clintonemail.com account during your tenure at the State Department in response to a FOIA request or FOIA litigation?
A: No, I was not.
Q: Do you know if anybody else searched your State.gov account for you in response to a FOIA request or FOIA litigation during your tenure there?
A: Not that I'm aware of.
Q: Are you aware if anybody else searched your Clintonemail.com account during your tenure at the State Department in response to a FOIA request or FOIA litigation?
A: Not that I'm aware of.
Q: Are you aware of any FOIA requests that were sent or received to the Secretary's office during your tenure at the State Department?
A: I don't remember any such instances.
Q: Do you know how FOIA requests were processed in the Secretary's office during your tenure at the Department of State?
A: No, I am not aware.
Q: Did you ever discuss any FOIA requests with anybody in the Secretary's office during your tenure there?
A: I don't have any memory of doing so.
Q: How about FOIA in general; do you recall any discussions that you may have had either with Cheryl Mills, Secretary Clinton, or anybody else in the Secretary's office, about FOIA?
A: It wasn't anything that I remember having discussions about.
Q: You knew Clarence Finney during your tenure at the State Department. Right?
A: Yes, I did.
Q: Did you ever discuss FOIA with Mr. Finney during your tenure at the State Department?
A: I remember briefing with Clarence when he first arrived about the documents that we were able to bring in with us. But I don't remember having a conversation like that with Clarence

Pause. For the sake of sustainability, we will take a brief respite from this "fascinating" conversation...OK Break time is over. Back to work.

Q: During your tenure at the State Department, did you know that your e-mails relating to State Department business were subject to FOIA?
A: Yes.
Q: When you were at the State Department, did you know that your e-mails relating to State Department business on your
Clintonemail.com account were also subject to FOIA?
A: Yes.

So, Hillary, HA knew this about emails on YOUR private server being subject to FOIA. Then you must have known about it, too. So, what excuse do you have for refusing to turn over some (but certainly not all) emails until you were sued by JW? And even then you delayed, delayed, delayed.

Q: Did Secretary Clinton know, as far as you're aware, that her e-mails relating to State Department business on her Clintonemail.com account were subject to FOIA?
A: I don't know. You would have to ask her.

Gee, JW, why don't you take this nice lady up on her suggestion and see if you can get Judge Sullivan to agree?

Another useless trip on the merry-go-round:

Q: Did you inform Mr. Finney that you had State Department-related e-mails on your Clintonemail.com?
A: As I think I mentioned earlier, I don't remember telling Clarence about Clintonemail.com.

A: I was using my State.gov e-mail for the majority of my State Department business. In many instances it was forwarding a document to be printed, a press clipping, a schedule. So those were all e-mails that were captured in the
system. And it was sent to Clinton e-mail. I had forwarded it to Clinton e-mail to print. My understanding, my
practice, from what I -- how I was functioning, I -- I wasn't perfect, but I did the best I could, was putting everything on State.gov. There were documents that were forwarded from State.gov to Clinton e-mail. Those were captured in the system.

Is that so?

And so that is how I operated. And I understood that everything that was on the State.gov system was kept in the system and retained in the system.

Somebody forgot to tell DOS about those emails--until they were compelled in Federal Court to look for them--and not a very good job did DOS do.

Q: Was the issue about how Secretary Clinton's e-mails could be accessed to respond to FOIA ever discussed by anybody within the Secretary's office?
A: Not that I'm aware.
Q: When you used your Clintonemail.com account for State Department-related business, did you ever print and file the e-mails?
A: No. I don't believe I did.
Q: Did you ever save the e-mails either as a PST or a PDF file?
A: No, I did not

Now comes a fast rendition of passing the buck:

Q Why not?
A: Honestly, I wish I thought about it at the time. As I said, I wasn't perfect. I tried to do all of my work on State.gov. And I do believe I did the majority of my work on State.gov. And many of the instances where I was on Clinton e-mail, it was because I had forwarded something from a State.gov account into Clinton e-mail, and in other instances from my Clinton e-mail I was communicating with somebody who was on a State.gov account, and it was captured through there..

Sorry to interrupt, but DOS spokesperson, Karin Lang says "no". Only a few documents from HRC's private server were preserved by DOS. Proceed:

I did the best I could to do everything right. I -- it did not occur to me to print and file.

Q: With respect to those State Department work-related e-mails on the Clintonemail.com accounts, what did you do, if anything, to preserve those e-mails?
A: I did not do anything to preserve those e-mails.

But, but, but,

A: The instances where it was Clintonemail to Clintonemail, there were instances where the content of those e-mails had personal matters in there, and there may have also been State Department matters in there, too.

Sorry, HA, but that testimony gets neither you nor HRC off the hook for failing to take adequate care to protect government files. They should never have been on that private server. HA, even if you're not a lawyer and even if if you were unaware of your obligation to keep state secrets secure, then you are probably guilty of gross negligence.

Q: As far as you know, if you know, what did Secretary Clinton do to ensure that her work-related e-mails were preserved?
A: She generally e-mailed people on their State.gov e-mail accounts, and through that manner, those e-mails were captured in the system.

Gosh darn it, HA, didn't your wonderful team of lawyers explain to you that designated DOS spokesperson, Karin Lang said that DOS did no such thing? Somebody's got some explaining to do here. How do you like the color orange?

Q: Do you know if any of the Secretary's e-mails relating to State Department business were printed and filed on the Secretary's behalf during your tenure at the State Department?
A: Not that I'm aware of...
Q: Do you know whether Secretary Clinton ever deleted any of her work-related e-mails on her Clintonemail.com account during her tenure at the State Department?
A: Not that I'm aware of.

Q: Was there a daily meeting with senior leadership within her [HRC] office during your tenure at the State
Department?
A: Yes, there was
Q: Was FOIA ever discussed during those meetings?
A: I don't remember...
Q: Do you have knowledge about a FOIA request that was submitted by CREW in December 2012 to the State Department for records relating to Secretary Clinton's e-mails? CREW's a nonprofit organization.
A: I know about it through media reports in the last year, yes.
Q: Did you not have any knowledge about it during your tenure at the State Department?
A: No.

OIG Report:

Q: Are you aware of the State Department's OIG report that was issued in January 2016 discussing processing of FOIA during Secretary Clinton's tenure?
A: I'm aware there was a report, yes. I have not reviewed that report.

More about CREW's FOIA requests:

Q: So it's fair then that you do not know Cheryl Mills' involvement, State Spokesperson Brock Johnson, Heather Samuelson's involvement with that FOIA request?
A: I don't know anything about this, no.

Q: Ms. Abedin, then let's just go back to the questioning about the State Department's OIG's report issued in January of 2016, in connection with FOIA processing during Secretary Clinton's tenure. Were you contacted by the State OIG's
office in connection with their investigation?
A: Yes. I was contacted through my attorneys.
Q: Did you refuse to speak with the State OIG's office in connection with their investigation?
A: On the advice of my attorneys I did, yes.
Q: Are you familiar with a report that was issued by the State Department's OIG office in May of this year with respect to Secretary Clinton's use of the Clintonemail.com during her tenure at the State Department?
A: I'm not aware that there were two reports. I know there was a report that I was asked to participate in that through my
attorneys, and I declined to do so through my attorneys.
Q: Do you know if that was after January of this year?
A: I don't know.

Talking about a meeting with Clarence Finney when HRC and company were departing DOS:

A: As the Secretary was preparing to transition from the State Department, I don't remember if I requested it through Clarence or vice versa. But we met with Clarence and other members of the Secretary's staff to get guidance on how we should be collecting the documents that we would be allowed to leave with at the end of her tenure.
Q: What is the guidance that was provided with respect to what documents you could leave, from the State Department?
A: We were all told to go through our files. And anything that appeared related to the State Department or work at the State Department we either left or made requests to make copies of, and they reviewed those boxes before they were sealed.

Loophole "big enough to drive a Mack Truck through": The materials were self-selected by the involved staffers as to what they considered personal. Any work that staffers considered "personal" was not put in those boxes subject to sealing.

Q: Was Mr. Finney in this meeting?
A: Yes. We discussed returning our devices at the end of our tenure and also told that the only materials we were allowed to leave with the State Department were our personal photos that may have been taken on our State Department BlackBerrys and retained on our desktops, and our contacts. And we came in with most of our contacts. Everything else was left on our laptops, preserved on our laptops. And I was given a CD disk, that had my contacts and my photos on it. And I left with that. Everything else stayed.
Q And what about any discussions during the meetings with respect to e-mails, work-related e-mails -- and again when I say "work related" I mean State Department-related e-mails -- that existed on personal e-mail accounts?
A: I don't remember specifics of discussing that in a meeting with Clarence.

Traffic alert. Mack Truck passing through.

Q: Who was in the meeting?
A: Myself, Clarence. From the personal staff that was leaving Rob Russo was there, Monica Hanley, Joe Macmanus, Lona Valmoro. Those are the people I remember in the meeting.
Q: Was Cheryl Mills in that meeting?
A: I don't remember Cheryl being in that particular meeting.
Q: Where was the meeting held?
A: In the conference room in the Secretary's office.
Q: Do you remember when or how soon prior to leaving the State Department this meeting took place?
A: I remember it was a few months.
Q: Do you know if Lauren Jiloty was part of the meeting?
A: I'm fairly certain Lauren had already left.
Q: How about Jacob Sullivan; was he part of that meeting?
A: I don't remember Jake [being there].
Q: What about Secretary Clinton; was she in the meeting?
A: She was not... The Secretary's office was also packed up and the materials that were put in boxes, this was everything from the books that she had on her bookshelf, to decorations or gifts that she may have received, and paper. All of those items were packed by staff, and those boxes were also not sealed until the protocol office had signed off on the items that were taken. And the same thing with the papers. She may have been in her office when that happened. I have no memory of her being there herself when we were packing.
Q: Did the Secretary provide any instructions with respect to what to do with her work -- State Department-related e-mails on her Clintonemail.com prior to leaving the State Department?
A: Not that I'm aware of.
Q: Did you ask her for any instructions with respect to what to do with her State-related e-mails?
A: I don't remember.
Q: Do you know if anybody did?
A: I don't.

Okay, Hillary, looks like the ball is in your court. You were the sole arbiter of what stayed and what went from your records at DOS--or will some patsy be found?

Q Do you know why nobody informed Mr. Finney about the State-related e-mails on Secretary Clinton's Clintonemail.com account?
A: It is not anything that occurred to us.

Q: Ms. Abedin, are you familiar with the SMART system that was introduced at the State Department in 2009? And SMART system stands for State messaging and archiving retrieval toolset.
A: I don't know what that is.

Now to Exhibit 4:

Q: Have you reviewed the document?
A: Yes.
Q: When was that?
A: When I was reviewing with my attorneys.
Q: That is in preparation for today's deposition. Right?
A: Yes.

Back to the home server:

Q: Do you recall any work that was done by State Department employees on the Clinton e-mail server that was located in Secretary Clinton's house in New York?
A: I recall that there was equipment, State Department equipment, installed in both her residences, in New York and in Washington.
Q: I want to focus on the equipment installed in her residence in New York. Were you involved in setting up for the State Department employees to go in and install whatever they needed to install at the Secretary's residence in New York?
A: Yes, I was.

HA, you have admitted your involvement in a very serious problem. Mr. Comey, are you reading this?

Q: Do you know who Purcell Lee is?
A: I do know Purcell, yes.
Q: Who is Purcell?
A: Purcell was our main point of contact on all matters related to technology needs in the Secretary's office, or for when we were traveling domestically or overseas.
Q: Was Purcell Lee working within the Secretary's office or in a separate office of the State Department?
A: He was in a separate office, but he would come into the Secretary's office to do whatever work was required. Purcell was in the IT office

A: I don't know John Bentel.
Q: You don't know that he was the director of the IRM office for the Executive Secretariat during that time?

Confused? I am. What happened to JC and BP?

After naming other individuals, presumably associated with DOS IT:

Q: Were you informed about the work they did on the server in the basement of the residence that's referenced on Page 2 of the exhibit?
A: I don't remember being informed about that.
Q: On Page 2, do you see where the server is identified in the basement telephone closet?
A: I see that.

So the server was not in the bathroom after all.

Now onto Exhibit 5:

Q: I just want to point your direction to the last e-mail on the document, it looks like it's from Secretary Clinton to Lona Valmoro and you. The date of that is September 20, 2009. Is that right?
A: Yes
Q: Do you see in the cc line that e-mail address, H2 -- well, the address looks like HR15@ATT.Blackberry.net?
A: Yes.
Q: All right. Is that the Secretary Clinton's e-mail address that you testified to earlier today?
A: That's the one I remember, yes.
Q: Do you know why the Secretary included her ATT.Blackberry.net e-mail on the cc line in her e-mail to you and Ms. Valmoro?
A: I don't know why.

Now onto email Exhibit 6:

Q: Is this a fair description of the document, it looks like to be an e-mail from Secretary Clinton to Lauren Jiloty?
A: That is Lauren Jiloty, yes.
Q: The date of the e-mail, for the record, is May 7, 2009. Is that right?
A: That's right.
Q: It looks like Secretary Clinton e-mailed Ms. Jiloty to help her update her berry with e-mail addresses of key staff like Monica [Hanley], Chris, et cetera. When Secretary Clinton referred to "my berry," is she referencing her BlackBerry there?
A: Yes.
Q: That's the BlackBerry that she used for her State Department business. Correct?
A: Yes...I don't know who she's referring to when she wrote "Chris" in this e-mail.
Q: Do you know if the Secretary had contacts of senior leadership leadership at the State Department for her State Department business?
A: She did.

Q: How did Secretary Clinton's staff update senior leadership at the State Department where they could reach her via e-mail for any new employees that were coming in at the State Department? Q: nHow would they know how to contact Secretary Clinton?
A: Most of the time they were seeing her in person, or it wasn't uncommon for them to put a call in to Claire. So most of their interaction, people at State Department either saw her, talked to her by phone, requested a meeting. There were instances where she provided her e-mail address in meetings to senior staff, or she would send an e-mail. And there were -- there were staff, senior staff, who asked for her e-mail address, and they were provided.

In other words, HRC's email address wasn't a secret kept away from staffers. So in all the prior depositions, except for BP, everybody played dumb, i.e., they didn't know anything about her private email account?

Q: Do you know if a directory or anything similar to a directory would be sent out to update senior staff about how they could contact Secretary Clinton by e-mail if they wanted to?
A: I'm not aware of such a directory.

On to Exhibit 7 (ferreting out who was in the know about HRC's BlackBerry account name):

Q: I'd like to just point you to the last e-mail on the document, from what appears to be Secretary Clinton to Lauren Jiloty again, dated September 7, 2009. Q: The subject is BlackBerry.
A: Yes.
Q: For the record the e-mail states, "Tomorrow please add more State names, all Under and Assistant Secretaries and the special assistants/exec crew. Thanks." The BlackBerry that Secretary Clinton is referencing, is this the BlackBerry that she used for her State Department business?
A: Yes.
Q: The Under and Assistant Secretaries the Secretary is referring to in her September 7, 2009, are those from the State Department?..Do you know if Secretary Clinton had the contacts on her BlackBerry for State
Department purposes for the Under and Assistant Secretaries at the State Department?
A: I know she had State Department staff's e-mail addresses. I couldn't list all the names of the State staff who were in there.
Q: In that second to the bottom e-mail from Lauren Jiloty, to the Secretary on September 8, 2009? Do you see where Ms. Jiloty tells Secretary Clinton, "I'm also making a master list for you of everyone I have added, updated, so you
can see." Do you know, was a master list with everyone that's been added on the Secretary's BlackBerry?
A: I don't recall seeing a list like that. I didn't participate.
Q: Did you have any exchanges with Ms. Jiloty with respect to what contacts should be put on Secretary Clinton's BlackBerry account during her tenure at the State Department?
A: I don't remember conversations with Lauren about who she was adding to the Secretary's contacts, no.

On to Exhibit 8 (did HRC actually a State.gov email address after all?):

Q: At the top of the document, do you see an e-mail, for the record it looks like it's an e-mail from Monica Hanley to you, on August 30th, 2011, at the top. Did I read that correctly?
A: That's right. That's right.
Q: It includes an e-mail address for State.gov, SSHRC@State.gov. Are you familiar with that e-mail account?
A: I'm not familiar with this particular e-mail address.
Q: Was that e-mail address created for Secretary Clinton, if you know, during her tenure at the State Department?
A: I have seen this document so I've tried to think about what this e-mail address could be. It is not familiar to me. It is not one that I know to have been created for her. I do know that there were some instances where the Secretary was sending department-wide e-mails, if I remember correctly it was the first --whether it was a Happy New Year message, there were some mass e-mails that were sent out on occasion, and this could have been for that, thus the SSHRC.
But I am otherwise not familiar with this particular e-mail address.
Q: Do you recall this e-mail exchange that you had during your time at the State Department?
A: I did not recall this exchange.
Q: Were you aware of any conversations or exchanges that Monica Hanley had with John Bentel about him advising her that the e-mail would go through the department's infrastructure and subject to FOIA searches?
A: Yes, I see what's in this document. But I wasn't aware of any conversations that Monica had with Mr. Bentel.
Q: Was FOIA a sensitive issue in the Secretary's office during Secretary Clinton's tenure at the State Department?
A: No, it wasn't.
Q: Since seeing this document, have you had any discussions about it, or the substance of it, with anybody other than your attorneys?
A: No.

On to Exhibit 9, which is also Exhibit 4 in Lukens' deposition:

Q: Do you recall the e-mail exchanges that occurred between you and Mr. Mull in or around August 30th that's reflected in this document?
A: Yes, I do.
Q: Can you tell me what your recollection is about the exchanges and what led to having these e-mail exchanges.
A: I don't remember, I think I mentioned this earlier. But I took a vacation when I was pregnant, and I was out of the country during this time period. The Secretary was also taking a short vacation with her family at a rental house. She was having communications issues, and the department was made aware of it. Cheryl and Steve... Cheryl Mills and Steve Mull.
Q: If you can turn to Page 2 of the document, the e-mail from Mr. Mull to Cheryl Mills, where Mr. Mull discusses possibly preparing two versions of a BlackBerry for the Secretary to use, one with a State Department e-mail account and one that would just have her phone and Internet capability. Do you remember that exchange?
A: My memory has been refreshed, having read the exchange, yes.
Q: Do you recall why did Mr. Mull suggest having these two separate BlackBerrys for the Secretary to use?
A: I think everybody from the State Department who was aware of the fact that she was having communications challenges was trying to provide solutions to fix the communications issues she was having.

So, prior deponents, HA says everybody was aware of communications problems and none of you admitted to knowing much, if at all, about this?

Q: Did Secretary Clinton agree to have two separate BlackBerrys as a result?
A: Not that I am aware of. I--Idon't remember discussing this with the Secretary in the time.
Q: Do you recall discussing this with Cheryl Mills at that time?
A: No.
Q: Do you recall discussing it with anybody else, including Patrick Kennedy or Monica Hanley?
A: I don't remember any conversations, phone conversations, outside of this exchange.
Q: Do you see the first sentence of that last paragraph on the second page of the document. "Separately we are working to provide the Secretary per her request a department-issued BlackBerry to replace her personal unit, which is
malfunctioning." And in parentheses, "possibly because of her personal e-mail server is down."
A: Yes, I do.
Q: Do you know how Mr. Mull knew that Secretary Clinton had a personal e-mail server?
A: I don't know.
Q: Did you ever tell Mr. Mull that Secretary had a personal e-mail server?
A: Not that I recall.
Q: Did you ever inform Mr. Mull that Secretary Clinton's residence housed a server in New
York for her e-mail?
A: No.
Q: Also on the same sentence.He writes, "We're working to provide the Secretary per her request a department-issued
BlackBerry." Did the Secretary request a department-issued BlackBerry, as far as you know?
A: I don't know.
Q: Do you know if anybody made such a request on the Secretary's behalf?
A: I wasn't involved in the conversations. I don't know who would have made that request on her behalf, I'm sorry.
Q: In the second sentence of that same paragraph, the statement that's in the parentheses, "which would mask her identity, but which would also be subject to FOIA requests."
A: Yes, I do.
Q: Do you know why Mr. Mull wrote that, that the e-mail account would be subject toFOIA requests?
A: I can't speak to why he wrote that.
Q: Was the usage of Secretary Clinton's e-mail discussed with Mr. Mull in connection to them being -- the e-mails being
subject to FOIA requests, if you know?
A: Not that I'm aware of.
Q: I just want to go back up to, again, the language in the first parentheses, "possibly because of her personal e-mail server is
down." Did you -- did you inform Mr. Mull about a personal e-mail account being down for the Secretary?
A: I don't recall. I wasn't -- I wasn't there. I was out of the country in this specific instance.
Q: Do you know if Cheryl Mills informed Mr. Mull about a personal e-mail account for Secretary Clinton being down during this time frame?
A: I don't know.
Q: Did you ever inform Mr. Mull about Secretary Clinton's e-mail account on the Clintonemail.com server?
A: I don't remember informing him, but her e-mail account was not a secret in our the department, and with senior members of the State Department.
Q: Do you recall any discussions you had with Mr. Mull about Secretary Clinton's e-mail account being down?
A: I remember this exchange. It was a hurricane. I remember not being there. I remember being on this e-mail chain. I don't remember any conversations outside she was experiencing issues, we were all trying to find a solution...I didn't think that the solution made a whole lot of sense, given the issues.
Q: Why didn't you think the solution made a whole lot of sense, given the issues?
A: We were in the middle of a hurricane. My memory is it was Hurricane Irene, that phone systems, phone lines, were completely down. That she couldn't have calls connected. I remember that the White House was having challenges, as I think I noted here, too. There were generally communication issues that were pretty widespread in New York at the time. I knew at the time that her preference was to carry one device. So adding not just one but two additional devices seemed quite a complicated solution for a matter that would be resolved once connectivity was restored and once the phone lines were up and systems were back up and running. Adding two additional devices to something that was going to be corrected didn't seem to make a lot of sense to me.
Q: Why would there be two additional devices added?
A: If you look at Steve's e-mail, it says, We'll prepare two versions for her to use, one with an operating State Department e-mail account, and another would just have a phone and Internet capability. So that would go from carrying one device to carrying three devices[?] And that is what I would be responding to in that line.
Q: Then the top e-mail that you sent to Steve Mull on August 30th, you say, "It's pretty silly and she knows it," on the first page of the document?

Another admission that those in the know should have known about the non-State.gov email address.

Q: Then I'll point you to the last sentence of that paragraph where it says, "We're working with Monica [Hanley] to hammer out the details of what will best meet the Secretary's needs." On the first page of the document, I want to talk about your e-mail to Mr. Mull and Cheryl Mills on August 30th, 2011. You write, "Steve, let's discuss the State BlackBerry. Doesn't make a whole lot of sense." Do you recall that e-mail exchange?
A: Yes. My memory has been refreshed now that I've read this e-mail.

Q: What did you mean as being pretty silly? What were you referring to?
A: The notion that we were having all of these challenges getting calls connected and e-mails through and not being able to have the common team connect a call. And we were in a hurricane. So not understanding why you're not getting calls, why
anyone isn't getting calls is we're -- we're in a hurricane. So when this issue is resolved for everybody who is having connectivity issues, we would be able to be back to business. But this was a unique situation that prevented a normal form of communications from taking place. And that included hard lines, as I'm sure
you've noted in this exchange, as well.
Q: So this is unique to the issues that you and the Secretary experienced with your Clinton e-mail accounts to deliver to State.gov e-mail accounts that we talked about earlier today?
A: I don't agree with the characterization. This also related to hard lines. These were calls being transferred on hard lines, that's why the communications team was onsite. And previously, as I had testified, it was not just lack of e-mails going through on Clinton e-mail; it was State.gov e-mails going to outside e-mail accounts. And so that wasn't just Clinton e-mail. In one instance it was a House.gov account.

Seventh inning stretch. Now on to Exhibit 10:

Q: Do you recall, after reviewing this document, do you recall this e-mail exchange you had with Secretary Clinton on November 13, 2010?
A: Yes... I remember there being instances where we had communications issues. This appears to be one of those instances.
Q: I'd like to point you to the second e-mail from the top on this document, from you to Secretary Clinton, November 13, 2010, where you state, "We should talk about putting you on State e-mail or releasing your e-mail address to the department so you are not going to spam."
A: I remember looking for solutions whenever there were challenges with our communications. I didn't remember this particular note to her. But this e-mail obviously states that, yes.
Q: Well, did you discuss this potential solution with anybody?
A: I don't remember.

More about fixing email problems:

Q: When you wrote "releasing your e-mail address to the department," can you explain what you meant by that?
A: So let me just give you some context of how I would have experienced a situation like this. Her initial e-mail was about a phone call with a foreign foreign minister, which she missed and missed the call because I never got her e-mail suggests giving us the signoff to do it. So she wasn't able to do her job, do what she needed to do. My response would have been, Here are some suggestions. I cannot tell you if I called somebody else. I don't remember calling anybody else. Or if I on my own said, Here are some solutions so that your e-mails get through to us so that we can place calls to foreign officials. You know, she clearly missed the window in this exchange.
Q: What did you mean by "releasing your e-mail address to the department"?
A: I'm not sure I would know how to define that then or define that now. I might have also just be my -- my being frustrated back at the fact that I wasn't getting her messages. Just reading the exchange, she seems frustrated because she's not able to do her job. I seem frustrated back because I'm not -- so I -- I couldn't define to you exactly what that meant.
Q: But looking at it today and reflecting back on the exchange you had at that time, if you're able to say what you intended to mean by that statement with respect to releasing her e-mail address to the department.
A: I couldn't tell you.
Q: Do you recall any discussions with Secretary Clinton, other than this e-mail exchange, about releasing Secretary Clinton's e-mail address to the department?
A: No.
Q: So in response to the two recommendations that you made to Secretary Clinton, what do you recall with respect to how she responded to those recommendations?
A: I don't recall any response other than once the system was back up and running, we just proceeded with business the
way it was before.
Q: So just so I understand, the only thing you recall is that the Secretary responded back by e-mail to you.
A: Yes.

Email Accessibility issues:

Q: Secretary Clinton wrote to you on November 13, 2010, "Let's get separate address or device, but I don't want any risk of the personal being accessible." Did you discuss with Secretary Clinton her not wanting a separate -- or her not wanting any risk of personal being accessible?
A: I don't recall talking to her about it outside of reading it in this e-mail.
Q: Do you know why Secretary Clinton didn't want any risk of her personal e-mail being accessible?
A: I understand this to her not wanting her private personal e-mails being accessible To anybody.
Q: This e-mail exchange when you recommended releasing your e-mail address to the department, what department were you
referring to?
A: It would have been at the State Department.

Q: So for the State Department, if you know, why did Secretary Clinton not want any risk of her personal e-mail being accessed?
A: I understand that as any personal e-mails not being accessible to anybody; to the public or just like anybody who has personal e-mail would want to keep their personal e-mail private.
Q: But again, we're talking about with respect to Secretary Clinton's work at the State Department. She used this e-mail account for her State Department work. Correct?
A: In addition to her personal, that is correct.
Q: But this is the only e-mail account that she used for her State Department work. Is that right?
A: That's right.
Q: So with respect to her e-mail that she used for her State Department work do you know why Secretary Clinton didn't want to risk any of her personal e-mail account being accessible while at the State Department?
A: I read that line exactly the way she wrote it, which is, let's get a separate address. There was no resistance to getting a
separate e-mail address, as I'm reading it in this document. And not wanting her personal e-mails to be accessible to the public. To personal e-mails being accessible to anybody. I would imagine anybody who has personal e-mail doesn't want that
personal e-mail to be read by anybody else. I read it the same way as she has written it.
Q: How do you read the personal being accessible? Is that -- do you read that as referring to Secretary Clinton's personal account or an individual e-mail?
A: I read that as any personal e-mails being accessible.
Q: So individual e-mails on Secretary Clinton's account.
A: Yes.

A hint that HRC may be needed to clarify the accessibility issue further:
A: Yes. Most of her State e-mails were being sent to State.gov addresses, they were going into the system.
Q: Do you know if that's what Secretary Clinton meant?
A: I don't know.
Q: We would have to ask her to know; wouldn't we?
A: I don't know.

Q: Was a separate address or device provided to Secretary Clinton after she wrote that to you on November 13, 2010?
A: There was not.
Q: Why not?
A: As had happened in other instances, the matter resolved itself, or was resolved, and we went back to the prior practice.
Q: Do you know how the matter was resolved?
A: I don't remember in this specific instance.
Q: Ms. Abedin, before moving on, I just have another followup question with respect to your testimony about the Secretary not wanting her personal e-mail to be accessible to the public. How would they be accessible to the public?
A: As I had stated, I read that as she not wanting her personal e-mail to be accessible by anyone. Just like I would not want my personal e-mail to be read by anybody else, I interpreted that for her, as well.
Q: Did the Secretary not want her personal e-mail account to be accessible pursuant to FOIA?
A: I absolutely do not believe that, no.

Another exhibit--Exhibit 11:

Q: Do you recall the e-mail exchange that you had with Secretary Clinton and Lauren Jiloty on March 22nd about designing a system that the Secretary wanted with respect to her personal and official files?
A: Yes. I remember conversations we were having during the transition of how to manage the paper.
Q: The conversations that you recall, are those independent of what's reflected in the document?
A: Yes.
Q: Can you first tell me about the conversations that you recall with respect to the system.
A: Generally understanding from the career State Department employees about how the paper that went in to the Secretary, official State Department materials that went in to the Secretary, how those were handled coming out, and versus personal things that may have come out and how those could be maintained.
Q: What do you mean by "coming out"?
A: When they were in the Secretary's Outbox. So it went into her Inbox, and what came out of her Inbox, and I think that is what she's referring to here.
Q: So what is being referred to in this document, does it refer to only hard-copy documents?
A: Yes. That is how I read this document.
Q: Okay. And what is the system that the Secretary wanted and designed with respect to managing her personal and official files?
A: I think it was a matter of understanding what the system was, the process was in place. We were coming in to an existing system, and how that paper flow worked and how things were filed when she sent them out. And, likewise, things that were coming in that might be personal, if there was a news article that she saw that she was interested in, she would put it in her Outbox. Trying to understand where all those things went. We would go overseas, there would be menus from official State dinners. Where does that go. Just trying to understand where items where paper items were filed when she put them in her
Outbox.
Q: With respect to the system, were there any e-mails that would be printed and would be filed? And I'm referring to her State Department work e-mails.
A: Not that I remember.
Q: This is something you worked on with Lauren Jiloty? Is that right?
A: It was something that all of us who were new to the department, in her immediate office, her assistants, were learning how to manage the paper properly.

Patience, deposition fans, we're at the bottom of the ninth:

Q: Moving on to the end of your employment at the State Department and afterwards. Did you discuss with Cheryl Mills or have any exchanges with Cheryl Mills about the setup of the server?
A: The setup of the Clinton server?
Q: Correct.
A: Not that I remember with Cheryl, no.
Q: . Who did you discuss the setup of the server after you left the State Department?
A: The awareness of the server and the presence was something I experienced reading in some news articles about a year, a year-and-a-half ago, when it was being publicly discussed.
Q: Are you aware of any discussions that Ms. Mills had with Bryan Pagliano about the setup of the server? And for that time frame, it's after she had left the State Department.
A: No, I'm not.
Q: Since leaving the State Department, have you had any contact with Bryan Pagliano about the Clintonemail.com system or the Clinton server?
A: No, I have not.
Q: How about with Justin Cooper?
A: I saw Justin at a wedding about three weeks ago, but I did not have a discussion with him about this at all.
Q: Other than seeing him at the wedding, did you have any discussions since leaving the State Department with Mr. Cooper about the Clinton server or the e-mail system?
A: No.
Q: Do you know Ms. Samuelson?
A: I do know Heather. We worked together at the State Department and prior to that in the 2008 Clinton campaign.
Q: The presidential Clinton campaign.
A: Yes.
Q: What was Ms. Samuelson's position at the State Department during your tenure there?
A: She is an attorney. And at State Heather I believe Heather worked in the counselor's office.
Q: On what, if any, work-related matters did you exchange with Ms. Samuelson during your tenure at the State Department?
A: And my memory is vague. Potentially personnel, bringing on new staff, is what I -- I don't -- I don't -- I don't remember much professional interaction with Heather at the State Department.
Q: Did you interact with Ms. Samuelson at the State Department for Mr. Pagliano to come onboard to the State Department in 2009?
A: No, I don't remember that.
Q: Since leaving the State Department, have you had any contact or communications with Ms. Samuelson with respect to the setup of the server or the Clinton e-mail system?
A: No, I haven't.
Q: Did you have any discussions with respect to the setup of the server or the Clinton e-mail system since you left the State Department with any of the attorneys on behalf of Ms. Mills?
A: No, I have not talked to her attorneys.
Q: Did you discuss the setup of the server or the Clinton e-mail system since you left the State Department with Secretary Clinton?
A: No.
Q: The same question with any of the attorneys for Secretary Clinton.
A: No.
Q: Do you know who Oscar Flores is?
A: I do know Oscar, yes.
Q: Can you tell me how you know Mr. Flores?
A: I have known him for 20 years now. He is the property manager at the Clinton's residence in Chappaqua.
Q: Do you know what involvement Mr. Flores had with respect to the setup of the server or maintaining the Clinton system?
A: No, I don't.
Q: How about John Davidson;
A: I know John Davidson, yes.
Q: How do you know him?
A: He works in President Clinton's office now, and I've known him for many years.
Q: Do you have any knowledge with respect to any involvement he may have had with respect to setting up the server or maintaining the Clintonemail.com system?
A: No.
Q: Ms. Abedin, in this lawsuit you returned some of your federal records to the State Department. Is that correct? Processing of this particular FOIA request. Judge Sullivan issued an order for the State Department to request the return of Ms. Abedin's e-mails. I think it's entirely within the scope.
A: Yes, I did.
Q: When did you return records to the State Department? In the summer of last year?
A: That sounds right.
Q: How did you go about searching for what records you may have in your possession to be returned to the State Department?
A: I looked for all the devices that may have any of my State Department work on it and gave them to my attorneys for them to review for all relevant documents. And gave them devices and paper.
Q: What devices did you return for your attorneys to look through with respect to federal records you may have had in your possession to be returned to the State Department?
A: If my memory serves me correctly, it was two laptops, a BlackBerry, and some files that I found in my apartment.
Q: The BlackBerry that you returned, is that a BlackBerry that was associated with your Clintonemail.com account?
A: Yes.

HA is trying to dodge a bullet or two here:

Q: The two laptops that you provided to your attorneys to look through, did they have e-mails from the Clintonemail.com account?
A: I was not involved in the process. I provided them with the devices and the materials and asked them to find whatever they thought was relevant and appropriate, whatever was their determination as to what was a federal record, and they did. They turned materials in, and I know they did so. I couldn't tell you from what device.
Q: Did you provide your account information, your login and your password to your Clintonemail.com account, to your attorneys, for them to review all of the e-mails that were on that account?
A: Yes, I did.

Questioning continues in the midst of increasing legal wrangling:

Q: What was your practice since you left the State Department with respect to e-mails that were on your Clintonemail.com account, and how you managed those e-mails? There are federal records that were on that account, and I'm asking how she managed those federal records prior to returning them, physically returning them.
A: My practice with my Clinton e-mail was similar to what I had with my State account, which is that I left everything in the Inbox, and I transitioned to a new e-mail once the Secretary's office was set up, her personal office post State Department. And I no longer used Clinton e-mail.

Now about the home server backup:

Q Did you have any contact or communications with anybody from Platte River Networks with respect to the setup of the server or the Clintonemail.com system? Let's start with while you were at State Department.
A: I don't remember conversations while I was at State. But after -- and my memory on the dates is fuzzy here. But once, when Platte River took over the IT responsibility for the office of the President and Chelsea, and then the -- and including
the office of the former Secretary, I did have a new contact to whom I would then communicate with when we were having issues with our e-mails.
Q: My followup question was, what were the exchanges that you had with the individuals at Platte Networks?
A: I don't remember having very many. It was just an introduction of a new -- there was a new team that had been hired to provide IT support.
Q: Did you have any contact with anybody from Datto, Inc., with respect to the setup of the server?
A: It doesn't sound familiar to me.
Q: What is the Clinton Executive Service Corp.? Are you familiar with the Clinton Executive Service Corporation?
A: I'm not.

Record retention and/or deletion:

Q: Ms. Abedin, just a few more questions. After you left the State Department and prior to providing access to your Clinton e-mail account to your attorneys last year, did you delete any of your e-mails on the Clintonemail.com account?
A: No.
Q: Do you recall how many e-mails were on your account and how many were returned to the State Department last year?
A: I don't recall how many were returned. I certainly don't recall how many was on the account. I ceased to use that account. I transitioned to a new office account. I just left everything on what -- on the system, I guess.
Q: Can you still access your account to the Clintonemail.com address?
A: No. I haven't been able to for some time.

Back to Exhibit 10:

Q: [Ezxhibit 10] is the e-mail exchange you had with Secretary Clinton on November 13 of 2010.Do you know whether Secretary Clinton returned that record to the State Department?
A: I don't know if she turned it in.

Questioning now by deponent's lawyers:

Q: As Deputy Chief of Staff for operations, were you responsible for overseeing records retention for the Office of the Secretary?
A: No.
Q: Who was responsible for that function, to your knowledge?
A: There were State Department officials responsible.
Q: As Deputy Chief of Staff for operations, were you responsible for overseeing compliance with FOIA requests in the Office of the Secretary?
A: No.
Q: Who, to your knowledge, was responsible for that function?
A: Career State Department officials.
Q: Do you have any personal knowledge, sitting here today, of the process used by the State Department for producing records to Judicial Watch in this litigation?
A: No.
Q: Do you know how the State Department processed FOIA requests that seek records from your Clintonemail.com account?
A: No, I don't.
Q: Do you know how the State Department processed FOIA requests to seek records from Secretary Clinton's e-mail accounts?
A: No, I don't.
Q: At any time during your tenure at the State Department, did you have any concerns about the Secretary's use of Clintonemail.com for State Department business?
A: No, I didn't.
Q: Why not?
A: I assumed it was allowed. It didn't occur to us.
Q: Were you responsible for setting up the Clintonemail.com system?
A: No.
Q: Were you responsible for maintaining the Clintonemail.com system?
A: No.
Q: What e-mail did you use to conduct State Department-related business while you were a State Department employee?
A: I used my State.gov.
Q: How would you characterize your use of State.gov in relation to your Clintonemail.com account?
A: I did the vast majority of my work on my State.gov account.
Q: To your knowledge, how did Secretary Clinton typically conduct State Department business?
A: Most of her State Department business was done in person, in meetings at the State Department or when she traveled, or by phone.
Q: When she used e-mail, she used her Clintonemail.com account?
A: When she used e-mail off hours and when we were on the road, she did use, yes, Clintonemail.com.
Q: Was that a secret, to your knowledge, within the State Department?
A: It was not a secret.
Q: Do you have any reason to believe that Clintonemail.com was used by anyone to thwart FOIA obligations?
A: Absolutely not.

JW's attorneys take another shot at HA:

Q: Ms. Abedin, with respect to the question your attorney was asking you about who at the State Department was responsible for overseeing document retention, you said, you answered, State Department officials. Who are those officials?
A: I couldn't name them all individually by name, which is why I answered it that way.
Q: Can you identify the offices or office that they worked in, referring to with respect to overseeing document retention.
A: It would be the Office of Records and Management, is my understanding.
Q: And then also the same question with respect to State Department officials, you said who oversaw FOIA requests during
your tenure there. Can you identify them by name?
A: I don't know who was responsible at the State Department for FOIA requests.
Q: How do you know they were State career officials when you answered your attorney's question?
A: I would imagine the overseeing FOIA is a matter that doesn't matter who is the Secretary of State, there's a process in place that exists at the department that existed before we got there, that existed when we were there, and continues to exist.
So there is an office within the department that is responsible for that. I can't imagine that's not a career State Department official who is responsible.

QUESTIONS WITNESS WAS INSTRUCTED NOT TO ANSWER:

Page 13:

Q: Prior to coming here today, have you reviewed any other documents in preparation for your deposition today? What are those documents that you've reviewed?

Page 14:

Q: What are the documents that you've reviewed that have been previously produced by the State Department?

Page 16:

Q: Why did the change take place?

Page 59:

Q: To the extent that you know, was the PresidentClinton.com e-mail accounts also hosted on the same server that hosted the @Clintonemail.com accounts?

Page 60:

Q: Ms. Abedin, did you have an e-mail account on the PresidentClinton.com -- or with the PresidentClinton.com domain?

Page 74:

Q: During your time at the State Department, did you or the Secretary consult with your use of the Clinton e-mail account for State Department work with anybody in the legal advisor's office?

Page 130:

Q: Were you contacted by the State Department's OIG office with respect to their investigation for their January 2016 report?

Page 131:

Q: Since September of 2015, were you contacted by anybody within the State Department's OIG office to discuss issues relating to FOIA processing in Secretary Clinton's office during her tenure at the State Department?

Page 209:

Q: Do you know if they reviewed all of the e-mails that were on your Clintonemail.com

Page 210:

Q: Without going into discussions you had with your attorneys, do you know what process was undertaken as part of the review of your records to return federal records to the State Department?

Page 212:

Q: Who is paying for your legal fees for your representation in this lawsuit?