IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA ZIVA BRANSTETTER and BH Media Group Inc. d/b/a TULSA WORLD, Plaintiffs, v. Case No. CV-14-2372 Judge Patricia G. Parrish MARY FALLIN, in her official capacity as GOVERNOR OF THE STATE OF OKAHOMA; MICHAEL C. THOMPSON, in his official capacity as COMMISSIONER OF THE OKLAHOMA DEPARTMENTOF PUBLIC SAFETY, Defendants. GOVERNOR MARY FALLIN’S RESPONSE TO PLAINTIFFS' FIRST SET OF INTERROGATORIES Governor Mary Fallin responds to Plaintiff’s First Set of Interrogatories to Governor Mary Fallin (“Requests”) with the following responses and objections. Governor Fallin reserves the right to supplement these responses and objections during or after completion of discovery, and further reserves the right to introduce evidence at the time of trial based upon information and/or documents located, developed or discovered subsequent to the date hereof, which evidence may supplement, amplify, modify or be in conflict with the information provided to Plaintiffs which is based on present information only. GENERAL OBJECTIONS AND CONDITIONS The following objections and conditions qualify each and every answer of Governor Mary Fallin to Plaintiffs’ discovery requests, and are incorporated by this reference into each and every answer to Plaintiffs’ discovery requests, as is fully set forth therein: 1. These Responses are based upon information presently available to Governor Fallin. Governor Fallin’s discovery and investigation in this case is continuing and are not complete; these Responses therefore cannot and do not purport to set forth all facts, theories, or evidence upon which Governor Fallin will ultimately rely after discovery and investigation are complete. Governor Fallin reserves the right to amend, modify, and supplement these Responses. 2. Governor Fallin objects to the definitions and instructions contained in Plaintiffs’ discovery requests to the extent that they attempt to impose obligations or requirements beyond those imposed by the applicable statutes and/or schedules set by the Court. 3. Governor Fallin objects to Plaintiffs’ discovery requests to the extent they call for the disclosure of information which is protected from discovery and privileged for the reason that (a) is subject to the attorney/client privilege; (b) is covered by the “work product” doctrine; (c) was generated and in anticipation of litigation or for trial by or for Defendants or Defendants’ representatives, including their attorneys, consultants or agents; (d) was prepared for the purposes of settlement negotiation; (e) is protected as a trade secret; (f) is subject to a protective or confidentiality agreement or order; and (g) is subject to the deliberative privilege; (h) is subject to the executive privilege, or (i) is otherwise privileged or beyond the scope of discovery under the applicable rules and laws. 4. Where Governor Fallin refers Plaintiffs to the documents which will be produced by the Defendants for the purposes of responding to any discovery request, such production of documents and information shall also be subject to all of the objections and conditions set forth in Defendants’ responses to Plaintiffs’ requests for production of documents, and all such objections and conditions are incorporated in this pleading by reference as if fully set forth herein. 5. By responding to the discovery requests of the Plaintiffs, Governor Fallin concedes neither the relevancy nor the admissibility of any information provided or documents produced in response to such requests. The production of information or documents in response to a specific Page 2 of 13 discovery request does not constitute an admission that such information is probative of any particular issue in this case. 6. Governor Fallin objects to each discovery request to the extent that it seeks information relating to time periods as to which Plaintiffs’ claims are barred under applicable statutes of limitations and/or laches or otherwise barred by the Court. 7. Governor Fallin objects to Plaintiffs’ discovery requests to the extent they seek information which is neither relevant nor likely to lead to the discovery of admissible evidence. 8. Governor Fallin is continuing to investigate and research Plaintiff’s claims and allegations. Governor Fallin reserves the right, as additional information is discovered, analyzed or made available during the course of these proceedings, to supplement and/or revise her Responses to Plaintiffs’ discovery requests. 9. Governor Fallin objects to the extent the Plaintiffs’ discovery requests seek information and/or documents generated and/or formulated by persons or entities independent of her or in the custody or control of third-parties. 10. Governor Fallin objects to the extent the Plaintiffs’ discovery requests are amorphous, vague, overly broad, unduly burdensome and so costly as to render compliance impractical. Subject to the foregoing objections and conditions and subject to the specific additional objections made with respect to each discovery request, Governor Mary Fallin hereby submits her Responses to the Interrogatories propounded by Plaintiffs, as follows: Page 3 of 13 INTERROGATORIES 1. IDENTIFY all PERSONS who have participated in processing and/or responding to requests for access to PUBLIC RECORDS made to YOU since January 1, 2011. RESPONSE: Governor Mary Fallin objects to the overly broad time frame contained in Interrogatory Number 1. The current open records policy at issue in this case was not implemented until 2012. The following is responsive under the current open records policy: Steve Mullins, General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; Jennifer E. Chance, Deputy General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; Audrey Rockwell, Paralegal, Office of the General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; Steven Babcock, Legal Intern, Office of the General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; John Brannan, Legal Intern, Office of the General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; Andrew Gin, Legal Intern, Office of the General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; Page 4 of 13 Jasmine House, Intern, Office of the General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)5228891; Rebecca Frazier, Assistant United States Attorney, 210 Park Avenue, Suite 400, Oklahoma Tower, Oklahoma City, Oklahoma 73102; (405)553-8804 (former Deputy General Counsel to Governor Mary Fallin); Jeffrey Cartmell, Deputy Director and Counsel, Office of State Finance, Gaming Compliance Unit, 2300 North Lincoln Boulevard, Suite 122, Oklahoma City, Oklahoma, 73105 (405)522-8841(former Deputy General Counsel to Governor Mary Fallin); Alyssa Bickford, employee of the Office of Governor Mary Fallin, c/o Office of Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 122, Oklahoma City, Oklahoma, 73105 (405)521-2342; Cody Inman, Director of Constituent Services, Office of Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 122, Oklahoma City, Oklahoma, 73105 (405)521-8891; Sean Rose, Public Affairs Liaison, Office of Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 122, Oklahoma City, Oklahoma, 73105 (405)521-8891 Walter Yoder, 3115 North Lincoln Boulevard, Oklahoma City, Oklahoma 73105; (405)5212444; Information Services Division, Office of Management and Enterprise Services, 3115 North Lincoln Boulevard, Oklahoma City, Oklahoma 73105; (405)521-2444. The following is a list of former interns who assisted in the processing of open records for the Office of Governor Mary Fallin under the current open records policy: Page 5 of 13 Casey Crook, Jared Barton, Cary Ann Cashion, Laura Lopez, Rebecca Stevenson, Tonya Kiper, Zach Deaton, Elizabeth Mccoy, Vicky Tran, Ashley Stribling, Austin Hughes, Brittany Bates, Daniel Kirrane, Emily Kitchens, Evan Taylor, Hayley Scott, Hunter Holmes, Jessalyn McAlister, Mackenzie Smith, Maggie Tulley, Molly Hawkins, Morgan McCullough, Rachel Hummel, Rilee Harrison, Tori Ross. These interns would have been involved only the scanning of physical documents or the conversion of electronic documents, and would have not been involved in the review or release of documents. This office does not possess the current address or telephone phone number of the above listed former interns. See also Response to Interrogatory Number 4. 2. IDENTIFY all PERSONS who have participated in formulating or developing YOUR policies and/or procedures for responding to requests for access to PUBLIC RECORDS since January 1, 2011. RESPONSE: Governor Mary Fallin objects to the overly broad time frame contained in Interrogatory Number 2. The current open records policy at issue in this case was not implemented until 2012. Thus, this Interrogatory is not calculated to lead to the discovery of relevant or admissible evidence, insofar as it requests information prior to the implementation of the current open records policy. The following is responsive to the Interrogatory under the current open records policy: Steve Mullins, General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; Denise Northrup, Chief of Staff, Office of Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)521-2342; Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)521-2342. Page 6 of 13 3. IDENTIFY all PERSONS responsible for ensuring that YOUR policies and/or procedures for responding to requests for access to PUBLIC RECORDS are followed. RESPONSE: Steve Mullins, General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; Jennifer E. Chance, Deputy General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; Audrey Rockwell, Paralegal, Office of the General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861. 4. IDENTIFY all PERSONS who have participated in processing and/or responding to the request to YOU for access to PUBLIC RECORDS that is at issue in this ACTION. RESPONSE: Steve Mullins, General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; Audrey Rockwell, Paralegal, Office of the General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; Jennifer E. Chance, Deputy General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; Steven Babcock, Legal Intern, Office of the General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; John Brannan, Legal Intern, Office of the General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8861; Andrew Gin, Legal Intern, Office of the General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Page 7 of 13 Oklahoma 73105; (405)522-8861; Jasmine House, Intern, Office of the General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105; (405)522-8891; Walter Yoder, 3115 North Lincoln Boulevard, Oklahoma City, Oklahoma 73105; (405)521-2444; Information Services Division, Office of Management and Enterprise Services, 3115 North Lincoln Boulevard, Oklahoma City, Oklahoma 73105; (405)521-2444. 5. IDENTIFY all requests for PUBLIC RECORDS that were "answered immediately," as described in Paragraph 15 of the ROCKWELL AFFIDAVIT, since January 1, 2011. For purposes of this Interrogatory, IDENTIFY means to state: (i) the name of the requestor, (ii) the general subject matter of the request, (iii) the date the request was received, (iv) the date the request was fulfilled, and (v) the number of pages of records produced or made available in response the request. RESPONSE: Governor Mary Fallin objects to the overly broad time frame contained in Interrogatory Number 5. The current open records policy at issue in this case was not implemented until 2012. Thus, this Interrogatory is not calculated to lead to the discovery of relevant or admissible evidence, insofar as it requests information prior to the implementation of the current open records policy. The following is responsive to the Interrogatory under the current Open Records policy: See attached documents. 6. IDENTIFY all requests for PUBLIC RECORDS other than those identified in response to the immediately preceding Interrogatory-received by YOU since January 1, 2011 that were not placed in the "open records queue" described in Paragraph 15 of the ROCKWELL AFFIDAVIT. For purposes of this Interrogatory, IDENTIFY means to state: (i) the name of the requestor, (ii) the general subject matter of the request, (iii) the date the request was received, (iv) Page 8 of 13 the date the request was fulfilled, and (v) the number of pages of records produced or made available in response the request. RESPONSE: Governor Fallin objects to the overly broad time frame contained in Interrogatory Number 6. The current open records policy at issue in this case was not implemented until 2012. Thus, this Interrogatory is not calculated to lead to the discovery of relevant or admissible evidence, insofar as it requests information prior to the implementation of the current open records policy. The following is responsive to the Interrogatory under the current open records policy: The Office of Governor Mary Fallin does not retain the requested information regarding incidental records requests. 7. IDENTIFY all PUBLIC RECORDS '"red-flagged' for sensitivity," as described in Paragraph 20 of the CHANCE AFFIDAVIT, since January 1, 2011. RESPONSE: Governor Fallin objects to the overly broad time frame contained in Interrogatory Number 7. The current open records policy at issue in this case was not implemented until 2012. Thus, this Interrogatory is not calculated to lead to the discovery of relevant or admissible evidence, insofar as it requests information prior to the implementation of the current open records policy. Governor Fallin further objects to Interrogatory Number 7 on the basis any response is subject to executive privilege and/or attorney-client privilege. 8. For each PUBLIC RECORD "'red-flagged' for sensitivity," as described in Paragraph 20 of the CHANCE AFFIDAVIT, since January 1, 2011, IDENTIFY the request(s) for PUBLIC RECORDS that it was responsive to. For purposes of this Interrogatory, IDENTIFY means to state: (i) the name of the requestor, (ii) the general subject matter of the request, (iii) the date the request was received, (iv) the date the request was fulfilled, and (v) the number of pages of records produced or made available in response the request. Page 9 of 13 RESPONSE: Governor Mary Fallin objects to the overly broad time frame contained in Interrogatory Number 8. The current open records policy at issue in this case was not implemented until 2012. Thus, this Interrogatory is not calculated to lead to the discovery of relevant or admissible evidence, insofar as it requests information prior to the implementation of the current open records policy. Governor Fallin further objects to Interrogatory Number 8 on the basis any response is subject to executive privilege and attorney-client privilege. Without waiving said objections, see Response to Request for Production Number 6. 9. IDENTIFY all internal COMMUNICATIONS made or received by YOUR MEDIA TEAM relating to any request for PUBLIC RECORDS since January 1, 2011. RESPONSE: Governor Fallin objects to the overly broad time frame contained in Interrogatory Number 8. The current open records policy at issue in this case was not implemented until 2012. Thus, this Interrogatory is not calculated to lead to the discovery of relevant or admissible evidence, insofar as it requests information prior to the implementation of the current open records policy. The following is responsive to the Interrogatory under the current open records policy: See attached documents. 10. IDENTIFY all internal COMMUNICATIONS made or received by FALLIN relating to any request for PUBLIC RECORDS since January 1, 2011. RESPONSE: None. 11. IDENTIFY all internal COMMUNICATIONS made or received by NORTHRUP relating to any request for PUBLIC RECORDS since January 1, 2011. RESPONSE: Governor Fallin objects to the overly broad time frame contained in Interrogatory Number 11. The current open records policy at issue in this case was not implemented until 2012. Thus, this Interrogatory is not calculated to lead to the discovery of relevant or admissible Page 10 of 13 evidence, insofar as it requests information prior to the implementation of the current open records policy. The following is responsive to the Interrogatory under the current open records policy: See attached documents. 12. Identify the date on which the "email documentation pull" described in Paragraph 26 of the ROCKWELL AFFIDAVIT was sent to the Information Services Division of the Office of Management Enterprise Services. RESPONSE: See Governor Fallin’s Response to Plaintiff’s Request for Production Number 13. Identify the date by which "all physical documentation regarding executions" had "been gathered," as described in Paragraph 26 of the ROCKWELL AFFIDAVIT. RESPONSE: February 2015. 14. Identify the date by which "all physical documentation regarding executions" was "scanned in" as described in Paragraph 26 of the ROCKWELL AFFIDAVIT. RESPONSE: February 2015. 15. Describe in detail YOUR efforts to search for and retrieve PUBLIC RECORDS stored on unofficial or private email accounts or systems, including but not limited to email sent or received from any non-"ok.gov" or non-"state.ok.us" email address-for the purposes of responding to the request for PUBLIC RECORDS that is at issue in this ACTION. RESPONSE: All electronic/email records are stored on the server operated by the Office of Management and Enterprise Services (OMES), which services the Office of the Governor. If there are responsive emails/records from private email accounts contained within the records on the OMES server, those responsive emails are produced in open records request responses, unless those emails are withheld due to privilege(s) or another exception to the Open Records Act. Page 11 of 13 16. IDENTIFY all PERSONS with knowledge of any fact set forth in YOUR response to the immediately preceding Interrogatory. RESPONSE: Governor Fallin objects Interrogatory Number 16 as overly broad, and upon the basis that it is unduly burdensome. Employees of the Governor’s Office and employees of the Office of Management and Enterprise Services, as well as numerous individuals, known and unknown to the Governor Fallin, may have knowledge of “any fact” set forth in the Response to Interrogatory Number 15. The following is a list of persons who have specific, first-hand knowledge of the information contained in the Response to Interrogatory Number 15, known to Governor Fallin: Steve Mullins, General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105, (405)522-8861; Jennifer E. Chance, Deputy General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105, (405)522-8861; Audrey Rockwell, Paralegal, Office of the General Counsel to Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105, (405)522-8861; Denise Northrup, Chief of Staff, Office of Governor Mary Fallin, 2300 North Lincoln Boulevard, Suite 212, Oklahoma City, Oklahoma 73105, (405)522-8832; Rebecca Frazier, Assistant United States Attorney, 210 Park Avenue, Suite 400, Oklahoma Tower, Oklahoma City, Oklahoma 73102, (405)553-8804; Jeffrey Cartmell, Deputy Director and Counsel, Office of State Finance, Gaming Compliance Unit, 2300 North Lincoln Boulevard, Suite 122, Oklahoma City, Oklahoma, 73105 (405)5228841(former Deputy General Counsel to Governor Mary Fallin); Page 12 of 13 Alex Weintz, Communications Director, Office of Governor Mary Fallin, 2300 North Lincoln Boulevard, Oklahoma City, Oklahoma 73105; (405)522-8819. Respectfully submitted, , OBA #19320 puty General Counsel to the Governor Office of Governor Mary Fallin 2300 No11h Lincoln Boulevard, Suite 212 Oklahoma City, Oklahoma 73105 (405)522-8861 telephone (405)523-4224 facsimile jennifer.chance@gov.ok.gov ATTORNEY FOR GOVERNOR MARY FALLIN Page 13 of 13 VERIFICATION I, Jennifer E. Chance, Deputy General Counsel to the Governor of the State of Oklahoma, have read the foregoing Responses of Governor Mary Fallin to Plaintiffs' First Set of Inte1rngatories to Governor Mary Fallin, and am familiar with the contents thereof. These responses are based on the records and information still in existence, presently recollected, and thus far discovered in the course of preparation of these responses. Subject to these limitations, the responses are true and correct to the best of my knowledge and belief. e ty General Counsel to the Governor State of Oklahoma CERTIFICATE OF SERVICE I hereby certify that on this 10th day of July, 2015, a true and correct copy of the forgoing was served by U.S. Mail, postage prepaid and/or emailed to the following: Katie Townsend The Repotters Committee for Freedom of the Press 1156 15 1h Street NW Washington, DC 20005 ktownsend@rcfp.org Robert D. Nelon Hall, Estill, Hardwick, Gable, Golden & Nelson Chase Tower, Suite 2900 100 North Broadway Oklahoma City, Oklahoma 73102 bnelon@hallestill.com Steven J. Krise General Counsel Depaitment of Public Safety 3600 Martin Luther King Ave. Oklahoma City, OK 73111 405.425.2158 '(Telephone) 405.425-2660 (Facsimile) skrise@dps.state.ok.us ATTORNEY FOR COMMISSIONER MICHAEL C. THOMPSON ...._---;t,el)!ltfe• p General Counsel to the Governor State of Oklahoma From: To: Subject: Date: Mike Soraghan Audrey Rockwell [Caution: Message contains Redirect URL content] RE: Audrey Rockwell wants to share "Open Records" with you Monday, March 23, 2015 2:41:25 PM Got it. Downloading files now.   Mike Soraghan Reporter EnergyWire msoraghan@eenews.net about.me/mike.soraghan 202-446-0423 (desk) 202-709-3699 (mobile)   _____________________________________________________________ Environment & Energy Publishing, LLC 122 C Street, NW, Suite 722, Washington, DC 20001 www.eenews.net • www.eenews.tv EnergyWire, ClimateWire, E&E Daily, Greenwire, E&ENews PM, E&ETV     From: Audrey Rockwell [mailto:Audrey.Rockwell@gov.ok.gov] Sent: Monday, March 23, 2015 3:31 PM To: Mike Soraghan Subject: RE: Audrey Rockwell wants to share "Open Records" with you Should be getting an invite.   From: Mike Soraghan [mailto:msoraghan@eenews.net] Sent: Monday, March 23, 2015 2:29 PM To: Audrey Rockwell Subject: [Caution: Message contains Redirect URL content] RE: Audrey Rockwell wants to share "Open Records" with you Hi. Thank you so much for your help with this. Could you send these to my gmail – msoraghan@gmail.com ?   I should have suggested this earlier. My dropbox is tied to that email.   Mike Soraghan Reporter EnergyWire msoraghan@eenews.net about.me/mike.soraghan 202-446-0423 (desk) Interrogatory #5 1 of 47 202-709-3699 (mobile)   _____________________________________________________________ Environment & Energy Publishing, LLC 122 C Street, NW, Suite 722, Washington, DC 20001 www.eenews.net • www.eenews.tv EnergyWire, ClimateWire, E&E Daily, Greenwire, E&ENews PM, E&ETV     From: Audrey via Dropbox [mailto:no-reply@dropbox.com] Sent: Monday, March 23, 2015 3:00 PM To: Mike Soraghan Subject: Audrey Rockwell wants to share "Open Records" with you Hi M, Audrey (auddydrockwell@gmail.com) invited you to a Dropbox shared folder called "Open Records." View folder Enjoy! - The Dropbox Team © 2015 Dropbox Interrogatory #5 2 of 47 From: To: Subject: Date: Mike Soraghan Audrey Rockwell [Caution: Message contains Redirect URL content] RE: Open Records Request EnergyWire Thursday, July 09, 2015 11:18:35 AM Thank you. The best address is: Mike Soraghan EnergyWire - Environment & Energy Publishing, LLC 122 C St. NW, Suite 722 Washington, D.C., 20001 Mike Soraghan Reporter, EnergyWire msoraghan@eenews.net 202-709-3699 Environment & Energy Publishing, LLC 122 C St. NW, Suite 722, Washington, D.C. 20001 www.eenews.net EnergyWire, ClimateWire, E&E Daily, Greenwire, E&ENews PM, E&ETV ________________________________________ From: Audrey Rockwell [Audrey.Rockwell@gov.ok.gov] Sent: Thursday, July 09, 2015 12:08 PM To: Mike Soraghan Subject: RE: Open Records Request EnergyWire Mike, I have another request we completed yesterday that is similar to your request. However the file is too large in my opinion to dropbox. I am happy to send these files to you via mail. If you will send me an address I will put them in the mail today. Audrey From: Mike Soraghan [mailto:msoraghan@eenews.net] Sent: Friday, June 12, 2015 3:34 PM To: Audrey Rockwell Subject: [Caution: Message contains Redirect URL content] RE: Open Records Request EnergyWire Hi. We talked a while back about my records request. You noted that there could be a wait and graciously suggested some documents from a previous request. Those documents have been very helpful. Would it be possible to get an ETA on the original request? Thanks, Mike Soraghan Reporter EnergyWire msoraghan@eenews.net about.me/mike.soraghan 202-446-0423 (desk) Interrogatory #5 3 of 47 202-709-3699 (mobile) _____________________________________________________________ Environment & Energy Publishing, LLC 122 C Street, NW, Suite 722, Washington, DC 20001 www.eenews.net • www.eenews.tv EnergyWire, ClimateWire, E&E Daily, Greenwire, E&ENews PM, E&ETV From: Alex Weintz [mailto:Alex.Weintz@gov.ok.gov] Sent: Monday, March 23, 2015 2:41 PM To: Mike Soraghan; Michael McNutt Cc: Audrey Rockwell Subject: RE: Open Records Request EnergyWire Hi Mike, I sent this on to Audrey Rockwell (also CC’d) who handles Open Records requests. thanks Alex Weintz Communications Director Office of Governor Mary Fallin phone: (405) 522-8819 cell: (405) 535-7317 Alex.Weintz@gov.ok.gov DISCLAIMER — Any and all communications sent to and received from this e-mail address may be subject to the Oklahoma Open Meetings and Open Records Act. Accordingly, please be advised that should your communications be responsive to an Open Records Request and not subject to any privilege, they may be turned over to a third party. This disclaimer does not waive any right or privilege that may be claimed by the state of Oklahoma, the Office of the Governor, or the sender of this message. From: Mike Soraghan [mailto:msoraghan@eenews.net] Sent: Monday, March 23, 2015 1:36 PM To: Michael McNutt; Alex Weintz Subject: FW: Open Records Request EnergyWire Mr Weintz , Mr. McNutt, Hi. I tried filing this as an open records request a week or so ago and I’ve gotten no response. Can you tell me who is the records custodian for the Governor’s Office/ Thank you, Mike Soraghan Reporter EnergyWire msoraghan@eenews.net about.me/mike.soraghan 202-446-0423 (desk) 202-709-3699 (mobile) _____________________________________________________________ Environment & Energy Publishing, LLC 122 C Street, NW, Suite 722, Washington, DC 20001 Interrogatory #5 4 of 47 www.eenews.net • www.eenews.tv EnergyWire, ClimateWire, E&E Daily, Greenwire, E&ENews PM, E&ETV From: Mike Soraghan Sent: Tuesday, March 03, 2015 6:33 PM To: Aaron.Cooper@gov.ok.gov Subject: Open Records Request EnergyWire Mr. Cooper, Hi. Can you point me toward the proper contact for an open records request? Thank you, Mike Soraghan Reporter EnergyWire msoraghan@eenews.net about.me/mike.soraghan 202-446-0423 (desk) 202-709-3699 (mobile) _____________________________________________________________ Environment & Energy Publishing, LLC 122 C Street, NW, Suite 722, Washington, DC 20001 www.eenews.net • www.eenews.tv EnergyWire, ClimateWire, E&E Daily, Greenwire, E&ENews PM, E&ETV Interrogatory #5 5 of 47 Audrey Rockwell From: Sent: To: Subject: Audrey Rockwell Monday, April 27, 2015 5:09 PM '16120-16313481@requests.muckrock.com' Response to Open Records Request Mr. Bennett, Regarding your open record request dated February 11, 2015, the office of Governor Mary Fallin does not maintain records regarding government watch lists. Secondly, the Federal Bureau of Investigation and the Department of Homeland Security are federal entities and our office has no jurisdiction over federal agencies. 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(YC' JJl.f~V~ /)1U/fl'1'i> tl'/.E.A4.l'J... l,J ~'l . f , ~ 5 ,_;.r~. l.gJ £~/>M~l/1.idt, - - - fl~-k: . rift~ /iVQuil./l, -- ~, ----- ~tlio J ,o,J Br_. · ....... '--= ......-...... - - - fro,.Bo « 5 'IL LKK11v/lo~ b/(U, __ __ -73<>5/ _ _ --................ Interrogatory #5 43 of 47 From: To: Subject: Date: Steve Horn Audrey Rockwell Re: Re: Friday, January 30, 2015 12:55:14 PM Got 'em all. Thanks a bunch! Did you say there was also another set of documents, too, or just those until you can get to my request? On Fri, Jan 30, 2015 at 12:45 PM, Audrey Rockwell wrote: Files 1 & 2 are now available   From: Steve Horn [mailto:steve@desmogblog.com] Sent: Friday, January 30, 2015 11:44 AM To: Audrey Rockwell Subject: Re:   Received and downloaded. Thanks!   On Fri, Jan 30, 2015 at 11:36 AM, Audrey Rockwell wrote: The records have uploaded.       Interrogatory #5 44 of 47 STATE OF OK L AHOMA OF F I CE OF TH E G OVERNOR March 6, 2015 Ms. Randi Millerd 3926 93rd Avenue SW Olympia, Washington 98506 Re: Open Records Request Dear Ms. Millerd: Pursuant to your electronic request dated March 5, 2015, enclosed are the non-privileged documents responsive to your Open Records request regarding the " Baby Veronica" case. Please feel free to contact me at (405) 522-8853 or Alex Weintz, Communications Director at (405) 522-8819 if you have any fmiher questions. Sincerely, ~\.?in!!: General Counsel SUITE 2 1 2 • S T A T E CAPI TOL B UILD I NG • OKLAHOMA CITY, OKLA H OMA • 73105 • 4 05/52 1 · 2342 Interrogatory #5 ~ \.I recycled paper 45 of 47 From: To: Subject: Date: Sumer Curry Audrey Rockwell Baby Veronica Request Friday, March 06, 2015 2:49:22 PM Audrey, How would you like me to handle this? Thanks, Sumer   From: CMS form builder system [mailto:noreply@www.ok.gov] Sent: Thursday, March 05, 2015 8:22 PM To: CMS Email Group Subject: A user has completed the "EmailContactForm2" A user has completed the "EmailContactForm2" form on your Web site. E-mail Governor Fallin To e-mail a question or comment to Governor Mary Fallin, please use the form below. Please note, the Office of Governor Mary Fallin receives a large volume of correspondence. The governor appreciates hearing your comments, questions and concerns. If your message is an emergency or requires immediate attention, please call the governor's office at (405) 521-2342. Name: Randi Millerd E-mail Address: r.millerd@hotmail.com Phone Number: Address: 3926 93rd Ave SW City: Olympia State: WA Zipcode: 98506 Subject: Baby Veronica Interrogatory #5 46 of 47 Message: I am wanting to request all email correspondences between Governor Mary Fallin and Governor Nikki Haley regarding Veronica Brown, Dusten Brown and Matt and Melanie Capobianco. I am researching the Veronica Brown case and believe there were improprieties involved in her forced adoption to the South Carolina couple. Thank you. Do you require a reply from the governor's office? Yes This is an automatic message notifying you of a new form completion. Please do not respond. Interrogatory #5 47 of 47