Civil Procedure Keyed to Cross
Alexander v. F.B.I
Alexander and other individuals instigated an action against the Federal Bureau of Investigation (FBI) and the Executive Office of the President (EOP) on the grounds that the FBI had violated their privacy rights when they wrongfully turning over FBI files of prior White House appointees and employees of both Reagan and Bush administrations to the EOP. Alexander and the other individuals demanded with reasonable particularity that the EOP elect a deponent to appear and give testimony on its behalf under Federal Rule of Civil Procedure (FRCP) 30(b)(6) about the recordings, both the audio and video, as well as the surveillance systems in the White House. Subsequently, Director of White House Operations John Dankowski, was designated to testify. Dankowski had 12 years of experience and supervised all purchasing. Once Dankowski’s deposition was complete, Alexander and the other individuals motioned to compel the EOP to re-elect a FRCP 30(b)(6) witness and pay the plaintiffs’ attorney’s fees and costs. Further, Alexander and the other individuals contend that Dankowski lacked knowledge on surveillance systems, thus, was not qualified to testify; failed to effectively prepare for the deposition, besides referring political appointees; was not experienced the a secret surveillance department; and did not effectively respond to questions involving the existence of a White House voicemail recording system from 1992–1994.
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