From: Randall Parker 

http://www.judicialwatch.org/otherserver/2000/gallantdec.htm

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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