Transcript of document discussion
25 wouldn't be – would not be understandable.
13
1 But in any event, my position I would just like to
2 present to the Court is I think it would be appropriate to
3 store it in the Portland FBI SCIF. I think we could do so
4 in a manner that in no way prejudices the Court's review or
5 the plaintiffs', and I don't think that really it's a matter
6 of any particular concern.
7 THE COURT: Well, the issue of concern depends on
8 your perspective.
9 Mr. Goldberg, let's assume that the litigation
10 security section is not going to be able to do anything less
11 than indicating that this should go into one of the present
12 facilities either in Portland or Seattle. Let's assume that
13 the originator does not declassify it or it cannot be
14 redacted, so that we're faced with placing this in a SCIF
15 either in Portland or in Seattle. Do you want to rethink
16 your position regarding the FBI SCIF, given that it's a
17 question of access both by the Court as necessary, by you as
18 necessary, and by the other parties?
19 MR. GOLDBERG: I certainly don't want to create
20 unnecessary logistical problems for anyone here, but I don't
21 know if I'm ready to respond to that as quickly as the – at
22 least immediately at this point. I think that the Court –
23 Can I ask a question of Mr. Borgen?
24 THE COURT: Yes. Go ahead.
25 MR. GOLDBERG: Is that okay?
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1 THE COURT: Yes.
2 MR. GOLDBERG: Mr. Borgen, is it possible, from
3 what Mr. Coppolino said, given the security that already
4 exists in the federal courthouse here, is there any
5 possibility of a room within the courthouse being basically
6 turned into a SCIF or somehow modified into a SCIF without
7 there being a huge production around it?
8 MR. BORGEN: No. There is no way to avoid that.
9 MR. GOLDBERG: What is the particular attributes
10 of a SCIF?
11 MR. COPPOLINO: Your Honor, I'm not sure he's
12 going to be permitted to answer all of the details of that
13 question. This is Mr. Coppolino speaking.
14 THE COURT: He can speak generally, can't he,
15 Mr. Coppolino?
16 MR. COPPOLINO: If he can state it without
17 disclosing any classified information, he can attempt to do
18 so without objection from me.
19 THE COURT: All right. Go ahead, Mr. Borgen.
20 MR. BORGEN: The facility itself has structural
21 hardening, there's building access that have to be modified,
22 alarms. And as he pointed out, it's about 30,000 to
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