Y Attachment_Montgomery Declaration

Case 3:06-cv-00056-MMD-CSD Document 1216-2 Filed 08/20/22 Page 1 of 194

4
194
1100 Glendon Avenue | 14th Floor

Los Angeles, CA 90024.3503
main: 310.500.3500
dir: 310.500.3614
fax: 310.500.3501
Notice of Privilege/Confidentiality Privileged and Confidential information may be contained in this message. If you are not the
addressee indicated in this message (or Responsible for delivery of the message to such person), you may not copy or deliver this
message to anyone. In such case, you should destroy this message and kindly notify the sender by reply email. Please advise
immediately if you or your employer does not consent to Internet email for messages of this kind. Opinions, conclusions and other
information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed
by it.
IRS Circular 230 Disclosure: To ensure compliance with Treasury Department Regulations, we advise you that, unless otherwise
expressly indicated, any federal tax advice contained in this communication was not intended or written to be used, and cannot be
used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or applicable state or local tax law
provisions or (ii) promoting, marketing or recommending to another party any tax-related matter addressed herein.
From: Eisenberg, Joseph

To: Terry, Billie
Cc: Dennis
Subject: FW: Review of former counsel files at Liner firm by United States
Date: Monday, May 24, 2010 1:08:10 PM
Attachments: Liner Document Inventory.pdf
Liner Hard Drive Inventory.pdf
Liner CD Inventory.pdf
-----Original Message-----
From: Gomez, Raphael (CIV) [mailto:Raphael.Gomez@usdoj.gov]
Sent: Monday, May 24, 2010 12:57 PM
To: Ellyn S. Garofalo; Kathleen Goldberg; Eisenberg, Joseph; Michael
Flynn
Cc: Wells, Carlotta (CIV); Raya, Sharon M. (CIV)
Subject: Review of former counsel files at Liner firm by United States
Counsel,
As we orally have informed you, the United States has conducted an

initial review of the 210 boxes of former counsel files at the Liner
firm. All 210 boxes of materials, minus the documents and media pulled
for further security review, require no further review by the United
States.
Please find attached an inventory of the hard copies, hard drives, and
CD's/DVD's that have been pulled from boxes 101 through 210 (please note
that the first 100 boxes were discovery produced by eTreppid to
Montgomery in the eTreppid case and were released by the United States
in late January 2010).
We will forward a projected date for completion of the review of the

pulled hard copies, hard drives and CD's/DVD's.
If you have any questions, please email or call.
Raphael Gomez
Carlotta Wells
202 514-1318
202 514-4522
Case 3:06-cv-00056-MMD-CSDLINER FILES: CD1216-2
Document INVENTORY
Filed 08/20/22 Page 122 of 194
CD No. ADDITIONAL INFO

BOX 101
CD - 000001
CD - 000002
CD - 000003
CD - 000004 DVD
CD - 000005
CD - 000006
CD - 000007
CD - 000008
CD - 000009
CD - 000010
CD - 000011 DVD
CD - 000012 DVD
CD - 000013
CD - 000014
CD - 000015 DVD
CD - 000016 DVD
CD - 000017 DVD
CD - 000018 *Microsoft XP
CD - 000019 *Dancing w/ the stars DVD
CD - 000020 *Dancing w/ the stars DVD
CD - 000021
CD - 000022
CD - 000023 DVD
CD - 000024 DVD
CD - 000025 DVD
CD - 000026 DVD
CD - 000027 DVD
CD - 000028 DVD
CD - 000029 DVD
CD - 000030 DVD
CD - 000031 DVD
CD - 000032
CD - 000033
CD - 000034 DVD
CD - 000035
CD - 000036
CD - 000037
CD - 000038 DVD
CD - 000039 DVD
CD - 000040
CD - 000041
CD - 000042 DVD
CD - 000043 DVD
CD - 000044 DVD
CD - 000045
* - Will be reviewed before copying CD INVENTORY PAGE 1 DOJ Security Office Boxes 1-3
Document INVENTORY
Filed 08/20/22 Page 123 of 194
CD - 000046
CD - 000047
CD - 000048
CD - 000049
CD - 000050
CD - 000051
CD - 000052
CD - 000053 DVD
CD - 000054
CD - 000055 DVD
CD - 000056 DVD
CD - 000057
CD - 000058
CD - 000059 DVD
CD - 000060 DVD
CD - 000061 DVD
CD - 000062
CD - 000063 DVD
CD - 000064 DVD
CD - 000065 DVD
CD - 000066 DVD
CD - 000067 DVD
CD - 000068
CD - 000069
CD - 000070 DVD
CD - 000071 DVD
CD - 000072 DVD
CD - 000073 DVD
CD - 000074
CD - 000075
CD - 000076 DVD
CD - 000077 DVD
CD - 000078 DVD
CD - 000079 DVD
CD - 000080
CD - 000081
CD - 000082
CD - 000083
CD - 000084
CD - 000085 DVD
CD - 000086 DVD
CD - 000087 DVD
CD - 000088 DVD
CD - 000089
CD - 000090
CD - 000091 DVD
CD - 000092
Document INVENTORY
Filed 08/20/22 Page 124 of 194
CD - 000093 DVD
CD - 000094 DVD
CD - 000095 DVD
CD - 000096 DVD
CD - 000097 DVD
CD - 000098
CD - 000099
CD - 000100 DVD
CD - 000101 DVD
CD - 000102
CD - 000103 DVD
CD - 000104 DVD
CD - 000105 DVD
CD - 000106 DVD
CD - 000107 DVD
CD - 000108 DVD
CD - 000109 DVD
CD - 000110 DVD
CD - 000111 DVD
CD - 000112 DVD
CD - 000113 DVD
CD - 000114 DVD
CD - 000115
CD - 000116 DVD
CD - 000117 DVD
CD - 000118
CD - 000119
CD - 000120 DVD
CD - 000121 DVD
CD - 000122
CD - 000123
CD - 000124
CD - 000125
CD - 000126
CD - 000127
CD - 000128
CD - 000129
CD - 000130
CD - 000131
CD - 000132
CD - 000133 DVD
CD - 000134
CD - 000135
CD - 000136
CD - 000137
CD - 000138
CD - 000139
Document INVENTORY
Filed 08/20/22 Page 125 of 194
CD - 000140
CD - 000141
CD - 000142
CD - 000143
CD - 000144
CD - 000145
CD - 000146
CD - 000147
CD - 000148
CD - 000149
CD - 000150
CD - 000151
CD - 000152
CD - 000153
CD - 000154
CD - 000155
CD - 000156
CD - 000157
CD - 000158
CD - 000159
CD - 000160
CD - 000161
CD - 000162
CD - 000163
CD - 000164
CD - 000165
CD - 000166
CD - 000167
CD - 000168
CD - 000169
CD - 000170
CD - 000171
CD - 000172
CD - 000173
CD - 000174
CD - 000175
CD - 000176
CD - 000177
CD - 000178
CD - 000179
CD - 000180
CD - 000181
CD - 000182
CD - 000183
CD - 000184
CD - 000185
CD - 000186
Document INVENTORY
Filed 08/20/22 Page 126 of 194
CD - 000187
CD - 000188
CD - 000189
CD - 000190
CD - 000191
CD - 000192
CD - 000193
CD - 000194
CD - 000195
CD - 000196
CD - 000197
CD - 000198
CD - 000199 DVD
CD - 000200 DVD
CD - 000201 DVD
BOX - 105
CD - 000223 *Fire Connect
CD - 000224
CD - 000225
CD - 000226
CD - 000227 *Dark City (Movie) DVD
CD - 000228 *School of Rock (Movie) DVD
CD - 000229 *Lost in Trans (Movie) DVD
CD - 000230 *After the Sunset (Movie) DVD
CD - 000231 DVD
CD - 000232 DVD
CD - 000233 DVD
CD - 000234 DVD
CD - 000235 DVD
CD - 000236 *Windows XP
CD - 000237 DVD
CD - 000238 DVD
CD - 000239 *Sync master
CD - 000240 * Windows XP
CD - 000241 DVD
CD - 000242 *Video Capture Software
CD - 000244 DVD
CD - 000245 *Video Capture Software
CD - 000247 DVD
CD - 000248 DVD
CD - 000249 DVD
CD - 000250 DVD
CD - 000251
CD - 000252 DVD
CD - 000253 DVD
Document INVENTORY
Filed 08/20/22 Page 127 of 194
CD - 000254
CD - 000255
CD - 000256 DVD
CD - 000257 DVD
CD - 000258 DVD
CD - 000259
CD - 000260 DVD
CD - 000261 DVD
CD - 000262 DVD
CD - 000263 DVD
CD - 000264 DVD
CD - 000265
CD - 000266 DVD
CD - 000267
CD - 000268 DVD
CD - 000269 DVD
CD - 000270 DVD
CD - 000271 DVD
CD - 000272
CD - 000273
CD - 000274 DVD
CD - 000275 DVD
CD - 000276
CD - 000277
BOX 106
CD - 000219
BOX 114
CD - 000278
CD - 000279 DVD
CD - 000280
CD - 000281 DVD
CD - 000282
CD - 000283* (IBM Commercial)
CD - 000284
CD - 000285
CD - 000286
CD - 000287
CD - 000288 DVD
CD - 000289
CD - 000290
CD - 000291
CD - 000292
CD - 000293
CD - 000294
CD - 000295
CD - 000296
CD - 000297* (Adobe)
Document INVENTORY
Filed 08/20/22 Page 128 of 194
CD - 000298
CD - 000299
CD - 000300
CD - 000301
CD - 000302
CD - 000303
CD - 000304
CD - 000305 DVD
CD - 000306
CD - 000307
CD - 000308
CD - 000309* (Music)
CD - 000310* (Win 95)
CD - 000311
CD - 000312
CD - 000313
CD - 000314
CD - 000315 DVD
CD - 000316
CD - 000317* (WIN 95)
CD - 000318 DVD
CD - 000319
CD - 000320
CD - 000321
CD - 000322
CD - 000323
CD - 000324* (Old Windows Upd.)
CD - 000325
CD - 000326
CD - 000327
CD - 000328
CD - 000329* (Elvis pt. 2)
CD - 000330
CD - 000331
CD - 000332
CD - 000333
CD - 000334
CD - 000335
CD - 000336
CD - 000337
CD - 000338
CD - 000339
CD - 000340
CD - 000341
CD - 000342
CD - 000343
CD - 000344
Document INVENTORY
Filed 08/20/22 Page 129 of 194
CD - 000345
CD - 000346
CD - 000347
CD - 000348
CD - 000349
CD - 000350
CD - 000351
CD - 000352
CD - 000353
CD - 000354
CD - 000355
CD - 000356
CD - 000357
CD - 000358 DVD
CD - 000359
CD - 000360** (Unreadable 360-370) DVD
CD - 000361
CD - 000362
CD - 000363
CD - 000364
CD - 000365
CD - 000366
CD - 000367 DVD
CD - 000368
CD - 000369
CD - 000370**
CD - 000371* (Dolby Test Files)
CD - 000372
CD - 000373* (Kodak Frames)
CD - 000374* (Partition Magic 8.02)
CD - 000375
CD - 000376* (HP) DVD
CD - 000377* (ADP)
CD - 000378
CD - 000379 DVD
CD - 000380
CD - 000381* (Win XP)
CD - 000382
CD - 000383 DVD
CD - 000384* (Mic Office 2003)
CD - 000385* (Mic XP)
CD - 000386* (Dancing w/ Stars) DVD
CD - 000388 DVD
CD - 000389
CD - 000390
CD - 000391 DVD
Document INVENTORY
Filed 08/20/22 Page 130 of 194
CD - 000392 DVD
CD - 000393 DVD
CD - 000394
CD - 000395
CD - 000396* (Symantec)
CD - 000397* (Mic XP)
CD - 000398 DVD
CD - 000399* (Mic Office 2003)
CD - 000400* (Mic XP)
CD - 000403 DVD
CD - 000404
CD - 000405
CD - 000406 DVD
CD - 000407 DVD
CD - 000408 DVD
CD - 000409
CD - 000410
CD - 000411* (Symantec)
CD - 000412* (Microsoft XP)
CD - 000413 DVD
CD - 000414* (Mic Office 2003)
CD - 000415* (Mic XP)
CD - 000418 DVD
CD - 000419
CD - 000420
CD - 000421 DVD
CD - 000422 DVD
CD - 000423 DVD
CD - 000424
CD - 000425
CD - 000426*(Symantec)
CD - 000427* (Mic XP)
BOX 117
CD - 000220
BOX 131
CD - 000217
BOX 145
CD - 000218
BOX 165
CD - 000431
CD - 000432
BOX 180
CD - 000221
Document INVENTORY
Filed 08/20/22 Page 131 of 194
BOX 181
CD - 000202
CD - 000203
CD - 000204
CD - 000205 DVD
CD - 000206 DVD
CD - 000207
CD - 000208 DVD
CD - 000209
CD - 000210
CD - 000211
CD - 000212 DVD
CD - 000213 DVD
CD - 000214
CD - 000215
CD - 000216
CD - 000430 DVD
BOX 188-1
CD - 000222
BOX 189
CD - 000428
BOX 190
CD - 000429
BOX 207
CD - 000433
CD - 000434
CD - 000435
LINER FILES: DOCUMENT INVENTORY
Present BOX CONTENTS DESCRIPTION RELEASED PULL DETAILS

N/A 1 DISCOVERY N/A Y
DOJ Security Office Boxes 1-3 DOCUMENT INVENTORY PAGE 1




1 Pull:
N/A 101 OTHER Y
Pull 1: CDs that appear to be discovery materials

N/A 102 OTHER N/A Y

4 Pulls:
Pull 1: 6/19/06 Flynn Email (001-005)
YES 103 OTHER Pull 2: 7/19/06 Flynn Email (001-004) N
Pull 3: 8/14/06 Flynn Email (001-014)
Pull 4: 9/26/06 Mongtomery Email (001-016)
YES 104 OTHER 1 Pull: N

Pull 1: 3/1/06 Flynn Ltr (001-008)
N/A 105 OTHER Hard drives and CDs N
1 Pull:
N/A 106 OTHER Y
Pull 1: CD
6 Pulls:
Pull 1: 3/11/06 Dec of Flynn (001-004);
Pull 2: 3/11/06 Dec of Flynn (001-004);
YES 107 PLEADINGS Pull 3: 4/3/06 Reply Memo (001-029); y
Pull 4: 4/21/08 Reply Memo (001-035);
Pull 5: 3/11/06 Dec of Flynn (001-006);
Pull 6: 4/3/06 Reply Memo (001-029)
2 Pulls:
Pull 1:Flynn Declaration (001-007)
YES 108 PLEADINGS Y
Pull 2: 3/17/07 Email (001-002)
2 Pulls:
YES 109 OTHER Pull 1: 2/26/07 Email (001); Y
Pull 2: 2/13/07 Email (001)
N/A 110 OTHER N/A Y
N/A 111 OTHER N/A Y
N/A 112 OTHER N/A Y
5 Pulls:
Pull 1: 2/13/07 Email (001-009);
Pull 2: 2/26/07 Email (001-004);
YES 113 OTHER N
Pull 3: 3/16/07 Email (001-012);
Pull 4: 3/16/07 Email (001-008);
Pull 5: 3/24/07 Email (001-003)
N/A 114 OTHER CDs for review N
N/A 115 PLEADINGS N/A Y
N/A 116 OTHER Hard drives N

4 Pulls:
Pull 1: 7/5/06 Email (001);
Pull 1: 001-022
YES 136 OTHER Pull 2: Contract Documents (001-010); Y
Pull 2:
Pull 3: Negroponte Questions (001-005)
Pull 4: Montgomery Declaration (001-022)
3 Pulls:
Pull 1: 4/10/06 Park Email (001-004);
Pull 2: 001-004
YES 137 OTHER Pull 2: 3/11/06 Flynn Declaration -Unsigned- (001-004) Y
Pull 3: 001-029
Pull 3: Reply Memo for Return of Property (001-029)
YES 138 PLEADINGS N/A Y
Pull 15: Complaint for violation of false claims act

30 Pulls:
Draft-5 (001-046);
Pull 1: 2/2007 Flynn Declaration (001-016);
Pull 16: Complaint for violation of false claims act
Pull 2: 2/2007 Montgomery Declaration (001-009;
Draft-6 (001-046);
Pull 3: 2/26/2007 Email (001);
Pull 17: Flynn Declaration (001-004);
Pull 4: 2/13/2007 Email (001-003);
Pull 5: 2/2007 Montgomery Declaration (001-005);
Pull 19: Motion to Unseal (001-017);
Pull 6: 2/2007 Montgomery Declaration (001-006);
Pull 7: 2/2007 Flynn Declaration in Supp of Montgomery Opp. to Govt
Motion to Strike (001-018);
Pull 22: Negroponte Questions (001-009);
Pull 8: 2/2007 Montgomery Declaration 2 copies -Unsigned-(001-019);
Pull 9: 3/2007 Email Chain (001-011);
YES 139 OTHER Pull 10: 3/16/07 Email (001-004);
Pull 11: Complaint for violation of false claims act Draft-1 (001-046);
Pull 26: 2/9/07 Flynn Ltr (001-005);
Pull 27: 2/9/07 Flynn Ltr (001-005);
Pull 28: 2/9/07 Flynn Ltr (001-003);
Pull 29: 3/24/07 Email (001-002)
Pull 30: 1/2007 Montgomery Declaration (001-007)
N


6 Pulls:
Pull 1: 4/13/07 Flynn Ltr (001-018);
Pull 2: 2/9/07 Flynn Ltr (001-010);
YES 158 OTHER Pull 3: 6/22/06 Flynn Email (001-002); Y
Pull 4: 6/22/06 Flynn Email (001-002);
Pull 5: 3/1/06 Flynn Ltr (001-013);
Pull 6: 7/26/06 Flynn Ltr (001-007)
N/A 160 OTHER N/A Y
1 Pull:
YES 164 OTHER Y
Pull 1: 4/13/07 Flynn Ltr. (001-009)
2 Pulls:
Pull 1: CD With Document Attached (001)
YES 165 OTHER Y
Pull 2: CD With Document Attached (001-030)
3 Pulls:
Pull 1: DM2845-2886 (001-042);
YES 166 OTHER Y
Pull 2: DM2987-2998 (001-012);
Pull 3: DM3145-3151 (001-007)
N/A 167 OTHER N/A Y
N/A 169 OTHER N/A Y
N/A 170 OTHER N/A Y
1 Pull:
YES 171 OTHER Y
Pull 1: Draft Flynn Ltr (001-008)
1 Pull:
YES 172 OTHER Y
Pull 1: Potential witness list with handwritten notations (001-002)

4 Pulls:
Pull 1: 2/27/07 Dec of Flynn(001-037);
YES 174 PLEADINGS Pull 2: 6/2/06 Dec of Michael West (001-008); Y
Pull 3: 06-cv-0263 Dkt# 125 Transcript (001-085);
Pull 4: 3/3/06 Dec of Michael West (001-014)



N/A 204 OTHER N/A Y
8 Pulls:
Pull 1: 4/10/06 Email (001-004);
Pull 2: 10/31/07 Email (001-002);
Pull 3: 3/16-18/07 Email chain (001-004);
Pull 4: 3/16-18/07 Email chain (001-007);
YES 205 OTHER Pull 5: 3/16-18/07 Email chain (001-007); Y
Pull 6: 6/23/07 Email (001);
Pull 7: 3/11/06 Dec of Montgomery for Return of Property -Unsigned-
& 4/3/06 Reply Memo un Support of Motion for Return of Property
(001-033);
Pull 8: 3/11/06 Dec of Flynn; (001-004)
N/A 206 OTHER N/A Y
6 Pulls:
Pull 1: 2 CDs
Pull 2: Cover sheet and Index of Emails in “Inbox” (001-0038)
Pull 3: Index of Emails in “Sent” (001-015)
YES 207 PLEADINGS Y
Pull 4: 1 CD
Pull 5: Index of Emails in “Inbox” (001-037)
Pull 6: Index of Emails in “Sent” (001-016)
N/A 208 OTHER N/A Y

3 Pulls:
Pull 1: Sealed Montgomery Declaration (001-036)
YES 209 PLEADINGS Y Pull 3: 001-022
Pull 2: Working Chronology (001-014)
Pull 3: Sealed Montgomery Declaration (001-022)

Dennis Lee Montgomery - November 18, 2010
UNITED STATES BANKRUPTCY COURT 1 For the United States of America:
CENTRAL DISTRICT OF CALIFORNIA
2 U.S. DEPARTMENT OF JUSTICE
In re: Dennis and Kathleen ) 3 CIVIL DIVISION

Montgomery ) 4 BY: CARLOTTA P. WELLS, Senior Counsel
)
5 Federal Programs Branch
Michael J. Flynn, )
) 6 20 Massachusetts Avenue, NW
Plaintiff, ) 7 Room 7150
) 8 Washington, DC 20530
vs. ) Case No.: 2:10-bk-18510-bb
)
9 (202) 514-4522
Dennis Lee Montgomery and ) 10 Also Present:
Brenda Kathleen Montgomery, ) 11 Michael J. Flynn, Esq.
)
12 Sharon Raya, Paralegal to Ms. Wells
Defendants. )
______________________________) 13 Tom (last name withheld), U.S. Government
14 Morgan (last name withheld), U.S.
15 Government
16 Videographer:
Videotaped Deposition of: DENNIS LEE MONTGOMERY 17 Jesse Navarro, Orravan Video Litigation
Date: November 18, 2010
18 Services
Reported by: Stephanie P. Borthwick
C.S.R. No. 12088 19
20
21
22
23
24
25
Page 3
1 Deposition of DENNIS LEE MONTGOMERY, taken on 1 INDEX

2 behalf of the Plaintiff, before Stephanie P. 2
3 Borthwick, a Certified Shorthand Reporter, 3 Deposition of DENNIS LEE MONTGOMERY
4 commencing at the hour of 9:20 a.m., Thursday, 4 Taken on November 18, 2010
5 November 18, 2010, at the offices of Yates Court 5
6 Reporters, 74967 Sheryl Avenue, Palm Desert, 6 Examination By: Page
7 California. 7 MR. CONANT 24
8 APPEARANCES: 8
9 For the Plaintiff: 9 Information Requested:
10 CONANT LAW, LLC 10 (None)
11 Attorneys at Law 11
12 BY: CHRISTOPHER J. CONANT, ESQ. 12 Questions Instructed Not to Answer: Page Line
13 730 17th Street 13 Q. Has your attorney, to your 45 3
14 Suite 200 14 knowledge, been in contact with any
15 Denver, Colorado 80202 15 agency of the United States
16 (303) 298-1800 16 government concerning your personal
17 For the Defendants: 17 property that's listed on these
18 DION-KINDEM & CROCKETT 18 schedules?
19 Attorneys at Law 19 Q. Is it your testimony, 46 9
20 BY: WILLIAM E. CROCKETT, ESQ. 20 Mr. Montgomery, that you have no
21 LNR Warner Center 21 personal property that falls within
22 21271 Burbank Boulevard 22 the description of this paragraph
23 Suite 100 23 here on page 22-9?
24 Woodland Hills, California 91367-6667 24 ///
25 (818) 883-4400 25 ///
Page 2 Page 4
1 (Pages 1 to 4)
YATES COURT REPORTERS 800.669.1866
1 21 19-page Wells Fargo PMA 306 1 because to do so would violate the terms of the
2 Package of Istvan Burgyan, 2 United States protective order, which all the
3 Bates Nos. 00552-70 3 parties to the bankruptcy proceeding have agreed to.
4 22 Five pages of Istvan Burgyan's 309 4 MR. CROCKETT: Bill Crockett on behalf of
5 bank records, Bates 5 Dennis Montgomery.
6 Nos. 00943-47 6 THE WITNESS: Dennis Montgomery.
7 23 Two-page Bank of America 312 7 THE VIDEOGRAPHER: Would the court reporter
8 statement of Istvan Burgyan, 8 please swear in the witness.
9 Bates Nos. 00933-34 9 THE REPORTER: Please raise your right
10 24 One page of photocopied 313 10 hand.
11 documents including a 11 Do you solemnly state under penalty of
12 cashier's check paid to 12 perjury that the testimony you will give in this
13 Caesar's Casino and Wells 13 matter will be the truth, the whole truth, and
14 Fargo Bank records. 14 nothing but the truth?
15 25 18 pages of MontBleu Resort 315 15 THE WITNESS: Yes.
16 Memo Reports 16 THE REPORTER: Thank you.
17 26 Three-pages of win/loss 324 17 MR. CONANT: Okay. Thank you.
18 documents 18 Before we start examining the witness, I
19 27 37 pages of Customer 328 19 want to state for the record that there are present
20 Transaction Inquiries 20 in the room four representatives from the U.S.
21 28 11 pages of miscellaneous 330 21 Government, two of which apparently have no last
22 casino documents 22 name.
23 /// 23 We'll ask on the record of Ms. Wells to
24 /// 24 provide their last names and the government agency
25 /// 25 that they purportedly work for.
Page 13 Page 15
1 THE VIDEOGRAPHER: Good morning. Here 1 MS. WELLS: And I cannot, because to do so
2 begins Media No. 1 in the video deposition of Dennis 2 would violate the terms of the United States
3 Lee Montgomery in the matter of Michael J. Flynn 3 protective order.
4 versus Dennis Lee Montgomery, et al., in the 4 MR. CONANT: Ms. Wells, do you have a copy
5 United States Bankruptcy Court of California, Case 5 of the protective order in front of you?
6 No. 2:10-bk-18510-bb. 6 MS. WELLS: I do. Do you have one?
7 Today's date is November 18th, 2010. The 7 MR. CONANT: I have a copy in front of me.
8 time is 9:20 a.m. This deposition is being taken at 8 I'd like to actually get it admitted as an exhibit
9 74967 Sheryl Avenue, Palm Desert, California, and 9 in this deposition.
10 was made at the request of Mr. Christopher Conant of 10 Let me -- while I work on getting extra
11 the law offices of Conant Law, LLC. 11 copies to admit as an exhibit, Ms. Wells, can you
12 The videographer is Jesse Navarro here on 12 review the protective order and identify which
13 behalf of Orravan Video Litigation Services, 13 specific portion of the protective order you're --
14 Indian Wells, California. 14 MS. WELLS: Am I a witness now? All I can
15 Would counsel and all present please 15 tell you is it's pretty self-evident from the face
16 identify yourselves and state whom you represent. 16 of the United States protective order what's
17 MR. CONANT: Christopher Conant for the 17 protected, what isn't.
18 plaintiff, Michael J. Flynn. 18 The information that's protected is set
19 MR. FLYNN: And Michael J. Flynn in 19 forth in paragraphs 2 and paragraphs 3.
20 persona. 20 MR. CONANT: How does those pertain
21 MS. WELLS: Carlotta Wells on behalf of the 21 specifically to the identities of these gentlemen
22 United States and with the United States Department 22 and why they're here today?
23 of Justice. Sharon Raya is with me from my office. 23 MS. WELLS: I think it's self-evident and
24 With me, also, are Morgan and Tom, who are with the 24 if you want to read those paragraphs into the
25 government and I can't disclose anything further 25 record, feel free to.
Page 14 Page 16
4 (Pages 13 to 16)
1 MR. CONANT: I don't -- well -- 1 reviewed in connection with your meeting with Judge
2 MS. WELLS: Paragraphs 2 and 3 of the 2 Pro that were -- that originated from my client
3 United States protective order, which is 3 Michael Flynn?
4 Document 253, District of Nevada Case File 30656. 4 MS. WELLS: This is not the subject of this
5 MR. CONANT: Ms. Wells, who is making the 5 deposition. We're not here to talk about this. If
6 decision regarding what is -- why these gentleman 6 Mr. Flynn wants to have a conversation with me about
7 are here? 7 this we can have it, but it's not appropriate for
8 Who in the government made a decision why 8 the record.
9 these gentlemen are here? Who in the government 9 MR. CONANT: It is appropriate for the
10 made a decision for these two gentlemen to be here 10 record. You are --
11 today? 11 MS. WELLS: It does -- what does that have
12 MS. WELLS: This particular deposition is 12 to do with the information we're here to protect
13 being handled in the manner that all information 13 now? The long and the short of it is that there
14 related to this case has been handled. It's been a 14 were documents, as you know, from the Order that the
15 joint decision between those attorneys representing 15 court in Montana sent to Judge Pro.
16 the United States' interests and the agencies whose 16 He asked the United States to take a look
17 information we're protecting. 17 at them to determine the extent to which there's
18 That's all I'm going to say. 18 information that may or may not be protected under
19 MR. CONANT: Were these gentleman at all 19 the United States protective order.
20 involved in any way in the litigation in Nevada? 20 Upon the limited review that we did in his
21 MS. WELLS: I'm not going to go any further 21 chambers yesterday, we determined that there was
22 than what I've already said. 22 enough of a question there that we need to take the
23 MR. CONANT: Were you meeting with Judge 23 documents back with us to Washington to do a more
24 Pro in the U.S. District Court for the district of 24 thorough review. That's it.
25 Nevada yesterday? 25 MR. CONANT: What documents did you review?
Page 17 Page 19
1 MS. WELLS: At Judge Pro's insistence, yes. 1 MS. WELLS: The documents that the court in
2 We met with him in his chambers yesterday. 2 Montana sent.
3 MR. CONANT: Who is "we"? 3 MR. CONANT: What documents were those?
4 MS. WELLS: The people representing the 4 MS. WELLS: I didn't take a list. It's not
5 United States Department of Justice and the United 5 a very big -- it's a small pile, not even an inch
6 States in this case. 6 thick.
7 MR. CONANT: Who were those? I'm asking 7 MR. FLYNN: This is Michael Flynn. I'm
8 for the identities, Ms. Wells. 8 going to put a statement on the record.
9 MS. WELLS: All I'm saying is that people 9 The documents that were given to David
10 from the government met with him and I mean it 10 Cotner, counsel for the trustee in the Montana
11 actually -- if you really need to know, it was the 11 bankruptcy proceeding, were very limited and I
12 four of us here. 12 specifically reviewed them before giving them to
13 MR. CONANT: Did Judge Pro -- when did 13 Cotner.
14 Judge Pro contact you to meet with him? 14 They were apparently subsequently given to
15 MS. WELLS: I'm not going to say anything 15 Judge Kirscher and they had all been previously
16 more other than we're complying with the terms of 16 reviewed by the federal government, Department of
17 the order that Judge Pro entered, I believe it was 17 Justice, and approved. And except for the Sandoval
18 October 30th, and we were there because of that 18 complaint, they are publicly on file in the Nevada
19 order. 19 District Court and can be picked up online.
20 MR. CONANT: What order? 20 So unless documents were added that I don't
21 MS. WELLS: Let's see. 21 know about -- and I don't know about any of the
22 It was the order dated October 28th, 2010, 22 documents, I don't have the identity of the
23 Docket No. 1172, same case, Montgomery versus 23 documents that were given to Judge Kirscher or
24 eTreppid Technology. 24 subsequently conveyed to Judge Pro -- there are no
25 MR. CONANT: Were there any documents 25 documents that do not comply with the US protective
Page 18 Page 20
5 (Pages 17 to 20)
1 order in any way. 1 here from the US government, two of who, apparently,
2 So if either documents were added by 2 have no last names and are from some unidentified
3 someone or there has been a change in the position 3 agency with the government.
4 of the Department of Justice with regard to the 4 And for the record, Ms. Wells is not
5 scope of the protective order, then there is nothing 5 indicating how their involvement is at all
6 in any of the documents given to Cotner, apparently 6 implicated in the protective order. The protective
7 passed on to Judge Kirscher, which would violate the 7 order only governs issues concerning intelligence
8 terms of the U.S. protective order. 8 agencies as defined in the National Security Act and
9 MR. CONANT: Do you have a copy, Ms. Wells, 9 we have no indication of what agencies these
10 of the letter or whatever communication there was 10 gentlemen are with and whether they're with an
11 between Judge Kirscher and Judge Pro? 11 intelligence agency or whether it's an
12 MS. WELLS: No. 12 administrative branch of the government that's not
13 MR. CONANT: Who at the government have you 13 included within the National Security Act as an
14 been talking to regarding the matter involving the 14 intelligence agency.
15 letter from Judge Kirscher to Judge Pro? 15 So we simply don't know what is -- what is
16 MS. WELLS: I'm not here to answer these 16 purportedly being protected by the protective order
17 questions. I'm here to enforce the terms of the 17 or not.
18 United States protective order and only people with 18 MR. FLYNN: We think -- at this juncture
19 the United States have that authority and the 19 I'll put on the record that I believe -- I didn't
20 ability to determine what's protected and what isn't 20 believe it during the Nevada proceedings, I thought
21 and that's all we're here for. 21 there were legitimate interests to be protected in
22 It's a very limited role that we're 22 terms of identities of intelligence agency
23 playing, it's a very limited role, and I can tell 23 individuals, but at this point I believe that the
24 you on the record that what we're doing here today 24 Department of Justice has gone far beyond that and
25 is entirely consistent with what we've done ever 25 is now using, under the guise of national security
Page 21 Page 23
1 since we first got involved in this case and ever 1 for reasons related to the facts that I put in the
2 since Judge Pro acknowledged there was information 2 emails to you, Carlotta, has gone far beyond the
3 to be protected. 3 scope of national security in an effort to cover up
4 That's all I'm going to say and I'll keep 4 or conceal the fraudulent activities of
5 saying the same thing over and over again. 5 Mr. Montgomery as I've repeatedly said in emails.
6 MR. FLYNN: It's completely inaccurate. 6 So why don't we just start.
7 For the record, these gentlemen, however nice 7 EXAMINATION
8 gentleman they may be, never participated and never 8 BY MR. CONANT:
9 appeared in courtrooms in any of the Nevada 9 Q. Okay. All right. Turning to
10 proceedings, Ms. Wells, and you know it and I know 10 Mr. Montgomery. Mr. Montgomery, let's start
11 it. 11 something.
12 So this four-person deluge from the 12 Can you state your name for the record.
13 Department of Justice in Dennis Montgomery's 13 A. Dennis Montgomery.
14 deposition is apparently being done for some reasons 14 Q. What's your -- do you have a middle name?
15 completely extraneous to the materials in the 15 A. Lee.
16 protective order, but why don't we get started. 16 Q. Do you understand what it means to take a
17 MR. CONANT: I just want to state one last 17 deposition, Mr. Montgomery?
18 thing for the record. When I deposed Istvan Burgyan 18 A. Yes.
19 in this very case on September 22nd, the U.S. 19 Q. What do you understand that to mean?
20 Government showed no interest in this matter. 20 A. You're going to ask me questions; I'm going
21 I had to call Mr. Gomez at his office in 21 to answer them.
22 D.C. halfway through the deposition, because there 22 Q. Do you know -- do you understand that your
23 became an issue regarding the protective order. 23 testimony today is under the penalty of perjury?
24 Mr. Gomez was completely indifferent regarding this 24 A. Yes.
25 case and now, for some reason, we have four people 25 Q. Do you understand what that means?
Page 22 Page 24
6 (Pages 21 to 24)
Carl Cameron
Chief Political Correspondent
FOX NEWS CHANNEL
202-320-2105
1
COMMITTEE SENSITIVE
EXECUTIVE SESSION
COMMITTEE ON THE JUDICIARY,
JOINT WITH THE
COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT,
U.S. HOUSE OF REPRESENTATIVES,
WASHINGTON, D.C.
INTERVIEW OF: JAMES A. BAKER (DAY 2)
Thursday, October 18, 2018
Washington, D.C.
The interview in the above matter was held in Room 2141, Rayburn
House Office Building, commencing at 10:01 a.m.
Present: Representatives Meadows, Jordan, Ratcliffe, and
Gaetz.
COMMITTEE SENSITIVE
5
COMMITTEE SENSITIVE
here.
Mr. Breitenbach. Unlawful surveillance of whom?
Mr. Baker. Of Americans, including government officials.
Yeah. I can go -- I mean --
Mr. Jordan. Who was his client?
Mr. Baker. Can I just -- I'm turning to the Bureau to describe
this. So his client was an individual named Dennis Montgomery, who
I believe, to the best of my recollection, he said that he had been
a U.S. Government contractor and, in the course of that work, had come
across evidence of unlawful surveillance by the government of
Americans -- and including government officials -- and wanted to give
that information to the Bureau, which eventually did take place.
Mr. Jordan. And was this -- I'm sorry. Go ahead.
Mr. Sommers. During what time period?
Mr. Jordan. Yeah. That's what I was going to ask.
Mr. Baker. To the best of my recollection, it's in the late
summer, early fall 2016.
Mr. Sommers. And the surveillance, what time period was that?
Mr. Baker. I'm not entirely sure what the timeframe was. It was
a significant -- it was -- one of the issues in the case was it was
a large amount of data that he had that he wanted to provide, that
these -- these disks or other media had a lot of data on them about
this, allegedly.
Mr. Sommers. Surveillance by whom?
Mr. Baker. By the U.S. Government itself of Americans,
COMMITTEE SENSITIVE
From: Dickas, J (Intelligence)

To: Dennis (dennis@ncoder.net)
Subject: RE: CIA
Date: Thursday, September 18, 2014 5:18:50 PM
Hi Mr. Montgomery,
Apologies for the slow response, I was out of the office for a couple weeks. Based on my
examination of your case, it looks to me like the Department of Defense Inspector General is
actually best positioned to review your complaint that the work you performed for the government
was illegal or improper. If you are having a hard time bringing this issue to the DoD IG’s attention, I
believe Sen. Cantwell’s casework staff is in a good position to help you get in touch with them.
Hope that is helpful.
John
From: Dennis [mailto:dennis@ncoder.net]

Sent: Thursday, September 18, 2014 3:49 PM
To: Dickas, J (Intelligence)
Cc: Wolfe, J (Intelligence)
Subject: CIA
Would you at least give me the courtesy of acknowledging my email. I have limited ways
to communicate with you and your committee.
It has been over a year since you sent me this email below.
I have followed the proper channels to file my whistle blower complaints with the
intelligence community. I have been told to be patient. You made it clear in you August
16, 2013 email that you would like to help me but cautioned me about releasing sensitive
documents, which I have not done.
I am a American who has information regarding US government intelligence agencies

mass surveillance of Americans, that you may not have been aware of. At this point, I
will assume you have verified that I was working for companies that had contracts with
the CIA, DOD,DNI, HOMELAND SECURITY, as well as others.
I thought at one point you and your committee would help me move my whistleblower
complaints forward?
I have followed the rules you ask me to follow. I will cooperate fully with you other
members of your committee regarding information that is contained in the various
whistleblower complaints that I have filed with the Inspector General’s within the
intelligence community.
I am disabled, and have limited ways to communicate with you. I am trying to do the
right thing.
Please help me.
Dennis Montgomery
dennis@ncoder.net
619.508.1964
From: Dickas, J (Intelligence) [j

Sent: Friday, August 16, 2013 12:51 PM
To: Dennis
Subject: RE: CIA
Hi Mr. Montgomery -
I would still recommend that you work with Senator Cantwell's casework staff to try to get a response
from the CIA Inspector General regarding your complaint. Have you tried to contact Senator Cantwell's
staff about this?
Also, you mentioned protections for whistleblower complaints - it is important to emphasize that such
protections have generally not been interpreted to cover disclosures of classified information through
improper channels. So I would strongly recommend that you not convey any classified information via
any unclassified modes of communication, or to any staff that do not have the necessary security
clearances. You seem to have been pretty careful not to do this so far, but some of your comments
make me concerned that you may be considering violating classification rules in the course of your
interactions with congressional staff, and many congressional staff (myself included) would feel
compelled to report the violation if you did so. I would definitely like to be helpful in getting your
concern addressed, but if you violate any laws regarding the protection of classified information I don't
think anyone in the legislative branch will be able to help or protect you.
Let me know if you need any help getting back in touch with Senator Cantwell's office, and have a
great weekend.
John
From: Dennis [dennis@ncoder.net]

Sent: 15 August 2013 00:29
Subject: CIA
This is not a complete list of individuals in Congress that had their personal data harvested. I just
wanted to give you some idea how wide spread it was. I would hope the information I have
provided to you and whoever you provide it to; is treated as information that being submitted as a
whistleblower complaint, and protected accordingly. I continue to try to look for “Proper Channels”
to go through in blowing the whistle on these illegal “document harvesting programs”, and the US
Government officials that were involved in these programs. This work was nothing more than the
US Government spying on US citizens, without their knowledge, consent or any court order.
I along with my family have been threatened, harassed, and when I wouldn’t agree to stop my effort
to whistle blow on the US Intelligence community, discredited. It is not fair for the US Government
to leak false information to the press in hopes of getting me to stop my whistle blowing campaign,
and when I attempt to defend myself, hold me to the State Secrets Privilege.
It is important to remember it was the government who came to me to do the work, not me going
to the government looking for work...
I am just one US citizen that is trying to get the truth out if the face of insurmountable obstacles.
I appreciate all of your help.

Dennis Montgomery
dennis@ncoder.net
619.508.1964

Sent: Wednesday, August 14, 2013 8:48 PM
To: 'Dickas, J (Intelligence)'
Subject: CIA
John, In the years I was involved with these programs the following individuals had data harvested
by the US Government, at least once. Over half this individuals have had their personal data
harvested more than twice. As you can see, the program did not discriminate based on political
party; 48 Democrats and 35 Republicans. Would you like me to provide more information? There
are tens of millions of records that were harvested.
I am sure I have already violated this State Secrets Privilege by disclosing this information, even
without disclosing what was actually harvested. Why wouldn’t the Inspector General of the DNI,
Inspector General of the DOJ, Inspector General of the Air Force, or the Inspector General of the
CIA want to get to the bottom of these disclosures and let me file a whistleblower complaint? I
suspect it has something to do with politics, James Clapper, John Brennan, and the other US
Government officials that were involved in this “illegal” data gathering effort and what they actually
used the data for.
How can the US Government classify this information as classified, secret, or top secret when these
individuals obviously had nothing to do with terrorism, like the other 10 million US Citizens that had
their personal information harvested, without their knowledge, consent, or court order under the
disguise of “national security.”
ADAM SMITH,CONGRESSMAN,D
ALCEE HASTINGS,CONGRESSMAN,D
BARBARA BOXER,SENATOR,D
BILL NELSON,SENATOR,D
BOB GOODLATTE,CONGRESSMAN,R
CARL LEVIN,SENATOR,D
CHARLES GRASSLEY,SENATOR,R
CHARLES SCHUMER,SENATOR,D
COLLIN PETERSON,CONGRESSMAN,D
DANNY DAVIS,CONGRESSMAN,D
DAVE CAMP,CONGRESSMAN,R
DAVID PRICE,CONGRESSMAN,D
DEREK KILMER,CONGRESSMAN,D
DIANNE FEINSTEIN,SENATOR,D
DONALD PAYNE,CONGRESSMAN,D
ED PASTOR,CONGRESSMAN,D
EDDIE JOHNSON,CONGRESSMAN,D
EDWARD MARKEY,CONGRESSMAN,D
ELIJAH CUMMINGS,CONGRESSMAN,D
FRANK LUCAS,CONGRESSMAN,R
FRANK PALLONE,CONGRESSMAN,D
FRED UPTON,CONGRESSMAN,R
GENE GREEN,CONGRESSMAN,D
HARRY REID,SENATOR,D
HENRY CUELLAR,CONGRESSMAN,D
HOWARD COBLE,CONGRESSMAN,R
JACK KINGSTON,CONGRESSMAN,R
JAMES CLYBURN,CONGRESSMAN,D
JAMES INHOFE,SENATOR,R
JEB HENSARLING,CONGRESSMAN,R
JEFF MILLER,CONGRESSMAN,R
JEFF SESSIONS,SENATOR,R
JIM COOPER,CONGRESSMAN,D
JOE BARTON,CONGRESSMAN,R
JOHN BOEHNER,CONGRESSMAN,R
JOHN BOOZMAN,SENATOR,R
JOHN CONYERS,CONGRESSMAN,D
JOHN DELANEY,CONGRESSMAN,D
JOHN DUNCAN,CONGRESSMAN,R
JOHN LEWIS,CONGRESSMAN,D
JOHN MCCAIN,SENATOR,R
JOSE SERRANO,CONGRESSMAN,D
KAY GRANGER,CONGRESSMAN,R
LAMAR ALEXANDER,SENATOR,R
LAMAR SMITH,CONGRESSMAN,R
LEE TERRY,CONGRESSMAN,R
LEONARD LANCE,CONGRESSMAN,R
LORETTA SANCHEZ,CONGRESSMAN,D
MARCO RUBIO,SENATOR,R
MARK KIRK,SENATOR,R
MARK SANFORD,CONGRESSMAN,R
MARSHA BLACKBURN,CONGRESSMAN,R
MAX BAUCUS,SENATOR,D
MELVIN WATT,CONGRESSMAN,D
MICHAEL MICHAUD,CONGRESSMAN,D
MICHAEL TURNER,CONGRESSMAN,R
MIKE THOMPSON,CONGRESSMAN,D
MITCH MCCONNELL,SENATOR,R
PAT ROBERTS,SENATOR,R
PATRICK LEAHY,SENATOR,D
PATTY MURRAY,SENATOR,D
PAUL RYAN,SENATOR,D
PETER DEFAZIO,CONGRESSMAN,D
RALPH HALL,CONGRESSMAN,R
RICHARD BURR,CONGRESSMAN,R
RICHARD DURBIN,SENATOR,D
RICK LARSEN,CONGRESSMAN,D
ROBERT ANDREWS,CONGRESSMAN,D
ROBERT MENENDEZ,SENATOR,D
RON WYDEN,SENATOR,D
ROSCOE BARTLETT,CONGRESSMAN,R
RUBEN HINOJOSA,CONGRESSMAN,D
SANDER LEVIN,CONGRESSMAN,D
SANFORD BISHOP,CONGRESSMAN,D
SAXBY CHAMBLISS,SENATOR,R
SHERROD BROWN,CONGRESSMAN,D
STEPHEN LYNCH,CONGRESSMAN,D
STEVE COHEN,CONGRESSMAN,D
SUSAN COLLINS,SENATOR,R
TIM RYAN,CONGRESSMAN,D
TOM COBURN,CONGRESSMAN,R
TOM HARKIN,SENATOR,D
TOM LATHAM,CONGRESSMAN,R

Dennis Montgomery
dennis@ncoder.net
619.508.1964
From: Dickas, J (Intelligence) [mailto:J_Dickas@ssci.senate.gov]

Sent: Wednesday, August 14, 2013 10:57 AM
To: Dennis
Subject: RE: CIA
Hi Mr. Montgomery -
I would definitely not recommend simply disclosing classified information publicly. If you believe that
the work that the CIA contracted you to do was illegal or improper, I would encourage you to keep
trying to bring it to the attention of the CIA Inspector General. The CIA IG actually has a fairly good
track record of investigating issues like this, and unlike the other Inspectors General that you have
previously contacted, the the CIA IG is well positioned to look into the matter.
If you have not yet received a response from the CIA IG, I would recommend contacting Senator
Cantwell's caseworker and asking for assistance. Congressional caseworkers are generally quite good at
getting government agencies to respond to constituent inquiries and concerns. And if you need any
help getting in touch with a caseworker, let me know and I'd be happy to help facilitate with Sen.
Cantwell's office.
John Dickas

Sent: 14 August 2013 11:00
Subject: CIA
I have to been unsuccessful with moving my whistleblower case forward within the US government.
I have been rejected by the Office of Special Counsel, the Inspector General of the DNI, and the
Inspector General of the DOJ. I provided my whistleblower complaint to the Inspector General of
the CIA, but have not heard back from them. I have sent faxes to them, asking them to just confirm
they have received my information. Still no response from Inspector General of the CIA.
I appreciate you dialog regarding the whistleblowers laws “currently in place as being inadequate.”
It seems like my only option now, is to release the information to the public, and let the public
investigate for themselves what has really gone on. This would expose both the inadequate
whistleblower laws regarding the intelligence community, the vast amount of data that was actually
harvested, and the US government officials that created, supervised, and abused the programs
under “the disguise” of national security or the “patriot act.”
The State Secrets Privilege was issued against me to “hide crimes” committed by former US
Government officials that worked on these information gathering programs. These programs are
now controlled by individuals that are currently in the highest government offices in our country
today. These programs gathered tens of millions of records of personal information that had
absolutely nothing to do with “national security”, without any court oversight. No one was exempt
from these “covert programs” including some of the members of the current congress; Ron
Wyden, John Boehner, Harry Reid, and many others.
According to current administration officials, Snowden did follow the correct protocol for
whistleblowing on US Government officials or “illegal data harvesting programs” within the
intelligence community. Given what I have gone through for the last 6 years, I doubt it would have
made much difference. There are no whistleblowing laws within the US Government intelligence
community, and the journey I have gone through only proves that.

Dennis Montgomery
dennis@ncoder.net
619.508.1964

Sent: Tuesday, August 13, 2013 3:20 PM
To: 'Dickas, J (Intelligence)'
Subject: CIA
The rejection of the whistleblower complaint rejection by the Inspector General Director of the DNI
doesn’t make since to me.
All of the work that was done from 2008-2010 was done under secrecy at Fort Washington, MD,
and James Clapper. The program there was “document harvesting” information from millions of US
Citizens personal information. As I reported to you before, when I was working there, I saw
employees from CIA that I had worked with years earlier.
The work that was done at Fort Washington was under an Air Force and DNI contract. Given the fact
that James Clapper is the head of the DNI, and the work that was done at Fort Washington was
under his direct control, how could the Inspector General of the DNI, claim it is not under his
purview to investigate?
I have also included the rejection letter by the Office of Special Counsel. That office suggested I
contact my senators or congressman for help. Which I have done.
I have tried to go through the necessary steps to file my whistleblower complaint against US
government programs and officials with the correct US government agency. It has become obvious
to me, that US government individuals involved in these programs, don’t want these investigations
to move.
Dennis Montgomery
dennis@ncoder.net
619.508.1964

Sent: Tuesday, August 13, 2013 2:35 PM
To: Dennis
Subject: RE: CIA
Mr. Montgomery -
I definitely agree that the intelligence whistleblower laws currently in place are inadequate. I do think
that the IG that is best positioned to address your concern that your work for the CIA was illegal and/or
improper is the CIA IG. If the CIA IG has not responded to your attempts to communicate with them,
Senator Cantwell's casework staff might be able to help you get in touch with them.
John

Sent: 13 August 2013 16:52
Subject: CIA
I filed a whistleblower complaint with the Inspector General of the DOJ, and sent a copy of it to the
Attorney General Eric Holder and the Deputy Attorney General, James Cole. The whistleblower
complaint was against the two DOJ attorneys and the FBI Special Agent that were involved in the
illegal raid on my home and property. I just received a rejection letter by the Inspector General of
the DOJ, who referred it to the FBI. This is the same FBI that the judge has already ruled had
already violated my 4th Amendment rights in the first place.
The DOJ doesn’t want me to provide them information regarding the illegal document harvesting
programs that were run by the intelligence community, against American citizens in this country.
They are hiding behind the State Secrets Privilege to “conceal the crimes” and the government
officials that were involved in these programs.
The Inspector General of the DNI has also refused to investigate my whistleblower against James
Clapper and the DNI. They had determined it was not under their purview.
It doesn’t seem like a whistleblower process really exists in this country when it comes to the
intelligence community.
Dennis Montgomery
619.508.1964

Sent: Tuesday, August 13, 2013 10:35 AM
To: Dennis
Subject: RE: CIA
Hi Mr. Montgomery,
If the CIA IG has not confirmed receipt of the information that you sent, the easiest thing to do might
be to have the caseworker from Sen. Cantwell's office contact them and ask them to confirm receipt of
the materials. If you need help getting in touch with them, just let me know.
John

Sent: 12 August 2013 11:51
Subject: CIA
John,
I have no way know if the information I sent to the Inspector General of the CIA on 8/6/13 was
received. I have asked for some kind of confirmation from the Inspector General of the CIA that my
information was received by his office.
Dennis Montgomery
dennis@ncoder.net
619.508.1964

Y Attachment_Montgomery Declaration

Uploaded by

Y Attachment_Montgomery Declaration

Uploaded by

Case 3:06-cv-00056-MMD-CSD Document 1216-2 Filed 08/20/22 Page 1 of 194

Case 3:06-cv-00056-MMD-CSD Document 1216-2 Filed 08/20/22 Page 2 of 194

1100 Glendon Avenue | 14th Floor

From: Eisenberg, Joseph

As we orally have informed you, the United States has conducted an

We will forward a projected date for completion of the review of the

If you have any questions, please email or call.

CD No. ADDITIONAL INFO

Present BOX CONTENTS DESCRIPTION RELEASED PULL DETAILS

N/A 33 DISCOVERY N/A Y

DOJ Security Office Boxes 1-3 DOCUMENT INVENTORY PAGE 1

N/A 34 DISCOVERY N/A Y

N/A 67 DISCOVERY N/A Y

DOJ Security Office Boxes 1-3 DOCUMENT INVENTORY PAGE 2

N/A 68 DISCOVERY N/A Y

DOJ Security Office Boxes 1-3 DOCUMENT INVENTORY PAGE 3

N/A 102 OTHER N/A Y

YES 104 OTHER 1 Pull: N

DOJ Security Office Boxes 1-3 DOCUMENT INVENTORY PAGE 4

YES 138 PLEADINGS N/A Y

Pull 15: Complaint for violation of false claims act

DOJ Security Office Boxes 1-3 DOCUMENT INVENTORY PAGE 7

N/A 156 PLEADINGS N/A Y

N/A 173 PLEADINGS N/A Y

Pull 4: 3/3/06 Dec of Michael West (001-014)

DOJ Security Office Boxes 1-3 DOCUMENT INVENTORY PAGE 9

N/A 203 OTHER Hard drives N

N/A 208 OTHER N/A Y

DOJ Security Office Boxes 1-3 DOCUMENT INVENTORY PAGE 11

In re: Dennis and Kathleen ) 3 CIVIL DIVISION

1 Deposition of DENNIS LEE MONTGOMERY, taken on 1 INDEX

COMMITTEE ON THE JUDICIARY,

JOINT WITH THE

COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT,

U.S. HOUSE OF REPRESENTATIVES,

INTERVIEW OF: JAMES A. BAKER (DAY 2)

Thursday, October 18, 2018

House Office Building, commencing at 10:01 a.m.

Present: Representatives Meadows, Jordan, Ratcliffe, and

Mr. Breitenbach. Unlawful surveillance of whom?

Mr. Baker. Of Americans, including government officials.

Yeah. I can go -- I mean --

Mr. Jordan. Who was his client?

Mr. Baker. Can I just -- I'm turning to the Bureau to describe

this. So his client was an individual named Dennis Montgomery, who

I believe, to the best of my recollection, he said that he had been

across evidence of unlawful surveillance by the government of

Americans -- and including government officials -- and wanted to give

that information to the Bureau, which eventually did take place.

Mr. Jordan. And was this -- I'm sorry. Go ahead.

Mr. Sommers. During what time period?

Mr. Jordan. Yeah. That's what I was going to ask.

Mr. Baker. To the best of my recollection, it's in the late

summer, early fall 2016.

a significant -- it was -- one of the issues in the case was it was

a large amount of data that he had that he wanted to provide, that

Mr. Sommers. Surveillance by whom?

Mr. Baker. By the U.S. Government itself of Americans,

From: Dickas, J (Intelligence)

From: Dennis [mailto:dennis@ncoder.net]

I am a American who has information regarding US government intelligence agencies

Please help me.

From: Dickas, J (Intelligence) [j

From: Dennis [dennis@ncoder.net]

I appreciate all of your help.

From: Dennis [mailto:dennis@ncoder.net]

I appreciate all of your help.

From: Dickas, J (Intelligence) [mailto:J_Dickas@ssci.senate.gov]

From: Dennis [dennis@ncoder.net]

I appreciate all of your help.

From: Dennis [mailto:dennis@ncoder.net]

From: Dickas, J (Intelligence) [mailto:J_Dickas@ssci.senate.gov]

From: Dennis [dennis@ncoder.net]

already violated my 4th Amendment rights in the first place.

From: Dickas, J (Intelligence) [mailto:J_Dickas@ssci.senate.gov]

From: Dennis [dennis@ncoder.net]