Professional Documents
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Sherrod V Breitbart - O'Connor Notice of Filing Documents
Sherrod V Breitbart - O'Connor Notice of Filing Documents
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NOTICE OF FILING
Please take notice that, pursuant to the Courts order of October 28, 2014 denying the
Motion of the United States for an Order Requiring Certain Documents and Information to be
Filed, if at All, Under Seal [Dkt. No. 136], Defendant Larry OConnor hereby files the attached
Exhibits A and B to his Reply in Support of Motion to Enforce the Deposition Subpoenas to
Krysta Harden and Cheryl Cook and Require Production of Certain USDA Headquarters Emails
[Dkt. No. 137] (the Reply). The Reply previously was submitted without the attached exhibits
on July 14, 2014.
Respectfully submitted,
By:
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on October 31, 2014, I served a true and correct copy of the
foregoing Notice of Filing via CM/ECF on the following:
Eric A. Dubelier
Daniel Z. Herbst
REED SMITH LLP
1301 K Street NW
Suite 1100, East Tower
Washington, DC 20005
Tel: (202) 414-9200
Fax: (202) 414-9299
edubelier@reedsmith.com
dherbst@reedsmith.com
Harrison J. Dossick
REED SMITH LLP
1901 Avenue of the Stars Suite 700
Los Angeles, CA 90067-6078
Tel: (310) 734-5200
Fax: (310) 734-5299
hdossick@reedsmith.com
Thomas A. Clare
CLARE LOCKE LLP
902 Prince Street
Alexandria, VA 22314
Telephone: (202) 628-7400
tom@clarelocke.com
Exhibit A
TJV
From:
Sent:
To:
Subject:
TJV
2010 5:37 PM
Re:
Dallas - she has offered her resignation which is appropriate. The WH is involved and we are
waiting for
go-ahead to
her resignation. I suspect some direction from WH soon.
TV
Original Message
From: Tonsager, Dallas
To: TJV
Sent: Mon Jul 19 17:30:47 2010
subject:
Mr. Secretary
I had tried you earlier today on a different email address which failed.
I am shocked by the comments made by State Director Shirley Sherrod and posted on the
internet. She was immediately suspended and my understanding is she has resigned.
Dallas
"Confidential" Under the Terms of the Protective Order Dated January 22, 2014 (ECF No. 86)
USDA
Subject to further review, covered by the Privacy Act Stipulation and Protective Order Dated April 22, 2014 (ECF No. 106)
00004926 T
-
out to Jesse
From: Harden,
Tuesday, July 20, 2010 2:
PM
To:
, John
Cc: Cluthe, Sally
Subject: Need numbers and times for others
Besides Clyburn and Bishop
"Confidential" Under the Terms of the Protective Order Dated January 22, 2014 (ECF No. 86)
USDA
Subject to further review, covered by the Privacy Act Stipulation and Protective Order Dated April 22, 2014 (ECF No. 106)
00005200 T
Tatianya
On hold as I
John
Bennie Thompson
Scheduler
Andrea Lee
Scheduler
Sheila Jackson-Lee
Angela Master
Scheduler
225-2201
225-3816
2:
Al Sharpton
PM
"Confidential" Under the Terms of the Protective Order Dated January 22, 2014 (ECF No. 86)
USDA
Subject to further review, covered by the Privacy Act Stipulation and Protective Order Dated April 22, 2014 (ECF No. 106)
00005262 T
-----Original
From: Harden, Krysta
Sent: Tuesday, July 20, 2010 2:35 PM
: Berge, John
Cc: Cluthe, Sally
Subject: Need numbers and times for others
Besides Clyburn and Bishop
"Confidential" Under the Terms of the Protective Order Dated January 22, 2014 (ECF No. 86)
USDA
Subject to further review, covered by the Privacy Act Stipulation and Protective Order Dated April 22, 2014 (ECF No. 106)
00006419 T
On hold as I
lee - 225-5876
225-3101
calvinsmyre@synovus.com
lakimba DeSadier
Executive Director
202-624-5457 office
out to
"Confidential" Under the Terms of the Protective Order Dated January 22, 2014 (ECF No. 86)
USDA
Subject to further review, covered by the Privacy Act Stipulation and Protective Order Dated April 22, 2014 (ECF No. 106)
00006680 T
Exhibit B