Case 1:16-cv-00461-ABJ Document 20-4 Filed 06/20/16 Page 1 of 5

Exhibit C

Case 1:16-cv-00461-ABJ Document 20-4 Filed 06/20/16 Page 2 of 5

Hatchett, Andrew
Sandberg, Justin (CIV) <Justin.Sandberg@usdoj.gov>
Thursday, May 19, 2016 5:23 PM
Kang, Edward
Barnaby, Kelley
RE: Rep. Nat'l Comm. v. U.S. Dep't of State, 16-CV-461: Narrowing

From:
Sent:
To:
Cc:
Subject:

Ted: Thanks for your email. Ive provided answers to your questions below. It is important to understand that the
document counts here are approximations, and the resulting page counts are based on an assumption of approximately
1.6 pages per document. The actual length could fluctuate considerably from one document to the next. Moreover,
because we werent in a position to open each attachment to an email, the estimate is based solely on parent
documents. Thus, the total number of pages, even after narrowing, is likely quite a bit higher than 450,000 pages.

Are the 450,000 pages that you identify below include classified material? If it does, what is the page count for only
non-classified?
This figure is, as we mentioned, a rough estimate. Of those approximately 450,000 pages, less than ten
percent were classified.

Can you break down the total page count by the three custodians at issue (Kennedy, Mills, Sullivan)?
Sullivan had approximately 120,000 documents, totaling more than approximately 200,000 pages, after
search criteria were applied.

Kennedy had approximately 95,000 documents, totaling more than approximately 150,000 pages, after
search criteria were applied.

Mills had approximately 66,000 documents, totaling more than approximately 100,000 pages, after search
criteria were applied.

Are you further able to break down the number of pages associated with each of the search terms that we sent
you?
The fact that the documents were in various formats and databases necessitated a variety of search
techniques to arrive at this estimate. As such, such a breakdown is not readily available.
I look forward to hearing from you. Justin
From: Kang, Edward [mailto:Edward.Kang@alston.com]
Sent: Thursday, May 19, 2016 9:18 AM
To: Sandberg, Justin (CIV)
Cc: Barnaby, Kelley
Subject: RE: Rep. Nat'l Comm. v. U.S. Dep't of State, 16-CV-461: Narrowing

Hi Justin. Thank you for the update. We have a few follow-up questions based on your email.

Are the 450,000 pages that you identify below include classified material? If it does, what is the page count for
only non-classified?
1

Case 1:16-cv-00461-ABJ Document 20-4 Filed 06/20/16 Page 3 of 5

Can you break down the total page count by the three custodians at issue (Kennedy, Mills, Sullivan)?

Are you further able to break down the number of pages associated with each of the search terms that we sent
you?

Answers to these questions will better guide us on discussing next steps. Thanks very much.

Ted
__________________________________________________________
Edward T. Kang
Alston + Bird LLP I 950 F Street, NW, Washington, DC 20004
202-239-3728 O I 703-635-9373 C
edward.kang@alston.com

http://www.alston.com/professionals/edward-kang/
From: Sandberg, Justin (CIV) [mailto:Justin.Sandberg@usdoj.gov]
Sent: Wednesday, May 18, 2016 5:34 PM
To: Kang, Edward <Edward.Kang@alston.com>
Cc: Barnaby, Kelley <Kelley.Barnaby@alston.com>
Subject: RE: Rep. Nat'l Comm. v. U.S. Dep't of State, 16-CV-461: Narrowing
Good evening, Ted.
We have assessed, to the extent possible given technological limitations, the effect of the search terms and date limits
on the universe of documents potentially responsive to your requests for the Mills, Sullivan, and Kennedy
records. Unfortunately, with respect to these three requests, there are approximately 450,000 total potentially
responsive pages. Given the Departments current workload and the complexity of the review required for these
documents, including interagency consultations, the Department cannot process more than 500 pages a month. Thus, it
would take about 75 years to process these requests. Accordingly, the Department has concluded that, even as
narrowed, each of these three requests would impose an unreasonable burden, and it will not gather or process
documents potentially responsive to them. Please let me know how you would like to proceed as to these requests, i.e.,
whether you would like to move to summary judgment briefing or would prefer to jointly seek an extension of the
upcoming deadline to allow the parties to negotiate more limited requests.
The Department continues to gather information regarding the requests related to Pagliano and Secretary Clinton, and I
hope to have more information to share with you tomorrow.
I look forward to hearing from you. Justin
From: Kang, Edward [mailto:Edward.Kang@alston.com]
Sent: Friday, May 13, 2016 9:25 PM
To: Sandberg, Justin (CIV)
Cc: Barnaby, Kelley
Subject: RE: Rep. Nat'l Comm. v. U.S. Dep't of State, 16-CV-461: Narrowing

Hi Justin. Here is what my client proposes on limitations for the Mills production. We look forward to your
response. Thank you.

Proposed limitations on Mills-related documents

2

Case 1:16-cv-00461-ABJ Document 20-4 Filed 06/20/16 Page 4 of 5

1/21/09 1/11/10 can be dropped from the timeframe of our request.

For the period 1/12/10 2/2/13, please exclude all emails received from:

OpsNewsTicker@state.gov

OpsAlert@state.gov

For the period 2/3/13 10/31/13, the request remains unmodified (Produce these emails first)

__________________________________________________________
Edward T. Kang
Alston + Bird LLP I 950 F Street, NW, Washington, DC 20004
202-239-3728 O I 703-635-9373 C
edward.kang@alston.com

http://www.alston.com/professionals/edward-kang/
From: Sandberg, Justin (CIV) [mailto:Justin.Sandberg@usdoj.gov]
Sent: Thursday, May 12, 2016 4:37 PM
To: Kang, Edward <Edward.Kang@alston.com>
Cc: Barnaby, Kelley <Kelley.Barnaby@alston.com>
Subject: RE: Rep. Nat'l Comm. v. U.S. Dep't of State, 16-CV-461: Narrowing
Good afternoon, Ted. Do you know when you will be able to send those search terms? Best, Justin
From: Kang, Edward [mailto:Edward.Kang@alston.com]
Sent: Wednesday, May 11, 2016 2:34 PM
To: Sandberg, Justin (CIV)
Cc: Barnaby, Kelley
Subject: RE: Rep. Nat'l Comm. v. U.S. Dep't of State, 16-CV-461: Narrowing

Justin,
Thank you for your email. We look forward to hearing from you about how much our Kennedy/Sullivan search terms
were able to limit the volume of documents please let us know as soon as possible once you have more
information. We will be providing you with search terms with respect to the Mills emails, and we will be providing you
with those terms later this week.
I also appreciate the update on the Pagliano records. While I dont recall being told that the information previously
provided was not final (I only recall being informed that there were no Pagliano and Clinton records that were
responsive to our requests), I am glad to hear that the State Department has been able to locate emails related to Mr.
Pagliano. We would request that those emails be produced as soon as possible.
Do you know if the State Department has similarly been able to locate any blackberry and/or text messages with respect
to Mrs. Clinton from the requested time period? Thank you very much.

Ted
__________________________________________________________
Edward T. Kang
3

Case 1:16-cv-00461-ABJ Document 20-4 Filed 06/20/16 Page 5 of 5

Alston + Bird LLP I 950 F Street, NW, Washington, DC 20004
202-239-3728 O I 703-635-9373 C
edward.kang@alston.com

http://www.alston.com/professionals/edward-kang/
From: Sandberg, Justin (CIV) [mailto:Justin.Sandberg@usdoj.gov]
Sent: Tuesday, May 10, 2016 4:21 PM
To: Kang, Edward <Edward.Kang@alston.com>
Cc: Barnaby, Kelley <Kelley.Barnaby@alston.com>
Subject: RE: Rep. Nat'l Comm. v. U.S. Dep't of State, 16-CV-461: Narrowing
Ted: We are assessing whether the search terms that you have proposed for the Kennedy and Sullivan emails will
meaningfully reduce the volume of documents to a reasonable level. I take it that your client is declining to provide
search terms with respect to the Mills emails. Is that correct? Also, Ive been informed that the State Department has
some emails related to Mr. Pagliano, and Im in the process of gathering more information about those. Of course, as I
noted during our conversations, the information that I provided to you earlier was not final. I look forward to hearing
from you. Justin
From: Kang, Edward [mailto:Edward.Kang@alston.com]
Sent: Sunday, May 08, 2016 1:59 PM
To: Sandberg, Justin (CIV)
Cc: Barnaby, Kelley
Subject: RE: Rep. Nat'l Comm. v. U.S. Dep't of State, 16-CV-461: Extension Motion

Hi Justin. Attached please find our clients proposed search terms for the Kennedy and Sullivan emails. Please note that
for the Kennedy emails, we have two groups of search terms one group for when Clinton was at the State Department
and another group for after she left that position. Thanks very much, and enjoy the rest of the weekend.

Ted
__________________________________________________________
Edward T. Kang
Alston + Bird LLP I 950 F Street, NW, Washington, DC 20004
202-239-3728 O I 703-635-9373 C
edward.kang@alston.com

http://www.alston.com/professionals/edward-kang/
From: Sandberg, Justin (CIV) [mailto:Justin.Sandberg@usdoj.gov]
Sent: Friday, May 6, 2016 4:31 PM
To: Kang, Edward <Edward.Kang@alston.com>
Cc: Barnaby, Kelley <Kelley.Barnaby@alston.com>
Subject: RE: Rep. Nat'l Comm. v. U.S. Dep't of State, 16-CV-461: Extension Motion
Ted: No problem. We cannot incorporate these edits. Accordingly, in our motion for an extension, we will note your
clients lack of consent. Best, Justin
From: Kang, Edward [mailto:Edward.Kang@alston.com]
Sent: Friday, May 06, 2016 10:06 AM
To: Sandberg, Justin (CIV)
Cc: Barnaby, Kelley
Subject: RE: Rep. Nat'l Comm. v. U.S. Dep't of State, 16-CV-461: Extension Motion