The White House FBI files controversy of the Clinton Administration, often referred to as Filegate, arose in June 1996 around improper access in 1993 and 1994 to FBI security-clearance documents. Craig Livingstone, director of the White House's Office of Personnel Security, improperly requested, and received from the FBI, background reports concerning several hundred individuals without asking permission. The revelations provoked a strong political and press reaction because many of the files covered White House employees from previous Republican administrations, including top presidential advisors. Under criticism, Livingstone resigned from his position. Allegations were made that senior White House figures, including First Lady Hillary Rodham Clinton, may have requested and read the files for political purposes, and that the First Lady had authorized the hiring of the underqualified Livingstone. The matter was investigated by the House Government Reform and Oversight Committee, the Senate Judiciary Committee, and the Whitewater Independent Counsel. In 1998, Independent Counsel Kenneth Starr exonerated President Bill Clinton as well as the First Lady of any involvement in the matter. In 2000, Independent Counsel Robert Ray issued his final report on Filegate, stating that there was no credible evidence of any criminal activity by any individual in the matter and no credible evidence that senior White House figures or the First Lady had requested the files or had acted improperly or testified improperly regarding Livingstone's hiring. A separate lawsuit on the matter brought by Judicial Watch, a conservative watchdog group, lingered on for years and was dismissed by a federal judge in 2010. Improper use of files issue "Filegate" began on June 5, 1996, when Republican Pennsylvania Congressman William F. Clinger, Jr., chair of the House Committee on Government Reform and Oversight, announced that the committee had found, during their ongoing "Travelgate" investigations, that FBI background reports on Travelgate figure Billy Dale had been delivered to the White House. The following day, the White House delivered to the committee hundreds of other such files related to White House employees of the Reagan Administration and George H. W. Bush Administration, for which Craig Livingstone, director of the White House's Office of Personnel Security, had improperly requested and received background reports from the FBI in 1993 and 1994, without asking permission of the subject individuals. Estimates ranged from 400 to 700 to 900 unauthorized file disclosures. The incident caused an intense burst of criticism because many of the files covered White House