---------- Forwarded message ----------
Date: Fri, 12 May 2000 12:30:14 -0400
From: Carl S. Webber <[EMAIL PROTECTED]>
DECLARATION OF KATHLEEN GALLANT
I, Kathleen Gallant, hereby state as follows:
1. I have personal knowledge of the matters attested to herein.
2. From January 12, 1998 through October 13,1998, I was the
Associate Director for the Information Systems and Technology
Division (IS&T) of the Executive Office of the President's Office
of Administration (OA). This position was a political
appointment. Among my duties, I was responsible for the
operational support for many of the computer systems for the EOP.
I currently run an $85 million major business group of an
information technology company in Northern Virginia with annual
revenues of $500 million and approximately 4500 employees.
3. In approximately June 1998, I came to learn of Project X, or
the "Mail2" problem, which was the failure of the Automated
Records Management System (ARMS) to capture incoming Internet
e-mail to White House staff, which resided on the Mail2 computer
server. I learned in June 1998 that the problem with the email
began in August 1996. As a result, this incoming email, which
numbered in the hundreds of thousands, was not searched by the
ARMS system in response to subpoenas and document requests. I
personally never saw any emails nor was I aware that any had been
printed or shown to anyone.
4. I also understand from the public record that Mark Lindsay of
OA has also been alleged to have made threats to the contractors
over Project X in order to keep it secret. Based on my experience
in working with them, I am confident that both Crabtree and
Lindsay are capable of conveying those threats to the contractors
and others. Certainly, the contractors acted, in their numerous
interactions with me as if they had been threatened. On several
occasions, Mark Lindsay told me not to record anything of
controversy in email communications. It was clear to me that he
did not want me to create any records that might embarrass or
cause legal implications if recorded by the ARMS system.
5. I was first briefed on Project X one day in a meeting in the
office of Paulette Cichon (then Deputy Director for Information
Management at OA and my supervisor) with Ms. Cichon and Betty
Lambuth. Ms. Lambuth, who was extremely nervous, at first refused
to tell me what concerned her. Only after Lindsay came into Ms.
Cichon's office during the meeting and gave Ms. Lambuth
permission to brief me, did she divulge to me what she knew about
the Project X email problem. At that time I was not aware of the
threats to Ms. Lambuth and the other Northrup Grumman employees.
6. Shortly thereafter, I learned from contractors Betty Lambuth,
Robert Haas, John Spriggs and Sandy Golas (all of whom I
interacted with regularly) that Laura Crabtree, who worked for
me, had threatened them with jail if they gave information about
Project X to unauthorized persons.
7. I quickly realized the impact the Project X issue would have
on email searches in response to subpoenas and document requests
(the searches were incomplete) and took several management steps
to try and correct the problem. I know that Mr. Lindsay and the
rest of the OA management, such as Ada Posey and Virginia Apuzzo,
were also aware of the implications of Project X as it related to
the accuracy of email searches.
8. Having seen a document in mid-June of 1998, showing that
Charles Ruff, then White House Counsel, was to be fully briefed
on the Project X email problem, I concluded that it was no longer
"classified" and could be discussed more openly within OA. In
fact, I ordered that the term "Project X" stop being used by OA
staff and that a more descriptive term "Mail2 reconstruction" or
variation thereof be used. At this time Ms. Crabtree was removed
from the project, in an attempt to reassure the Northrup Grumman
employees that they would not be subject to any future threats.
9. The first action I took was to order that the procedure that
was used to create "user id's" be corrected to prevent any more
users from having email that would not be properly captured by
the ARMS system.
10. I held several meetings with the Northrup Grumman staff
(Sandy Golas, Bob Haas and John Spriggs) who were familiar with
Lotus Notes (the computer system upon which emails were
transmitted), and the ARMS system. Because of Crabtree's threats
the contractors said they did not want to work on the Project X
problem.
11. Steve Hawkins, their Northrup Grumman supervisor, also told
me that his staff reported that Crabtree had threatened them over
Project X. Hawkins also told me he had a meeting with Lindsay in
which he and Lindsay disagreed strongly about the Project X email
secrecy. Given the fact that I thought the Project X issue should
be quickly fixed, I was anxious to persuade the contractors to
work on the project and resolve the problems. To that end, I
suggested to Steve Hawkins that the employees who worked directly
for Northrup Grumman consult with the company's legal counsel
about the threats to reassure them that it would be acceptable
for them to work on the project. I was told that this
consultation did take place.
12. Also, once I became aware of the need for additional hardware
to solve the Project X problem, I requested that Mark Lindsay and
Ada Posey take action to determine if National Security Council
(NSC) funds allocated by law for the ARMS system as it related to
NSC (as a result of the Armstrong v. EOP litigation), which still
had a large amount of unspent funds, could be directed to shoring
up the ARMS system. This would have allowed OA to rectify the
Project X problem (reconstructing the uncaptured email to the
ARMS system and fixing the "glitch" that caused the ARMS system
to not capture the incoming email in the first place).
13. Despite my repeated requests, and the vocal and written
concerns of OA computer specialist Daniel Barry (as confirmed in
recently publicly released emails from him) and Jim Wright (who
supervised Barry as head of the EOP Data Center), nothing of
consequence was ever done to reallocate funds, and therefore no
funds were available to purchase the equipment needed to rectify
the email problem. In fact, when I left OA in October 1998, the
incoming emails to those users on the Mail2 server were still not
being captured by the ARMS system, resulting in hundreds of
thousands of uncaptured emails remaining effectively hidden from
investigators. It appeared to me that Lindsay, his supervisors
and other White House officials simply did not want the problem
to become publicly known so they would not have to search the two
years of uncaptured email in the middle of the Lewinsky and other
ongoing criminal inquiries, such as those concerning campaign
fundraising and Filegate.
14. I am aware of testimony and reports that six months of the
Project X email resident on tape was overwritten and likely lost.
In March or April 1998, faced with a lack of funding to purchase
sufficient tapes to maintain the backup system, I authorized OA
staff to recycle older backup tapes and use them again. It was
our intent to have a rolling active archive of two years of tapes
at all times. It was in that context that some of the Project X
email tapes were overwritten. At the time that I ordered the
reuse of old tapes, I was under the impression that the ARMS
system was capturing all the email. Given my respect for the law
and my basic professionalism, I would never have authorized the
recycling of the tapes had I known that, in doing so, that the
only remaining copies of any emails would have been lost as a
result. The public record shows that Betty Lambuth believes that
backup tapes from the time period of June through September 1997
were recycled and overwritten. If, in fact, these tapes were
overwritten, I can only surmise that someone picked up tapes from
the middle of the year instead of using ones dated prior to
January 1997. Once the Project X problem became known, we stopped
using the existing tapes and I authorized the purchase of new
tapes. All available funds were used to purchase new tapes so
that we could continue to backup the EOP systems.
15. In February 2000, I was contacted by James Gilligan, an
attorney with the Department of Justice. Mr. Gilligan and I had
met once before during my tenure at OA, and he said that he
wanted to ask me questions and possibly depose me about the email
problem. I told him that I would be happy to answer his questions
but that he ought to hear my answers before deciding to depose me
as I wasn't sure he would like what I had to say. I never met
with Mr. Gilligan, nor have I been contacted by him again. Nor
have I been contacted since then by anyone in the Department of
Justice or the Office of Independent Counsel.
I swear under penalty of perjury that the foregoing is true and
correct.
Executed on May 10, 2000 in Washington DC.
_____________________
Kathleen Gallant
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Kadosh, Kadosh, Kadosh, YHVH, TZEVAOT
FROM THE DESK OF: <[EMAIL PROTECTED]>
*Mike Spitzer* <[EMAIL PROTECTED]>
~~~~~~~~ <[EMAIL PROTECTED]>
The Best Way To Destroy Enemies Is To Change Them To Friends
Shalom, A Salaam Aleikum, and to all, A Good Day.
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