Title: Volume FOIA 001

Release Date: 2014-03-20

Text: 00001



Volume 1 of 111
SJAR ROT
FOIA Version

VERBAT IM 1

RECORD OF TRIAL2

(and accompanying papers)















of
(Name: Last, First, Middie initiai) (Sociai Security Number) (Rank)
Headquarters and
Headquarters Company,
United States Army Garrison U-S- Army Fort Myer, VA 22211
(Unit/Command Name) (Branch of Service) (Station or Ship)
By
GENERAL COURT-MARTIAL
convened by Commander



(Titie of Con vening Authority)

UNITED STATES ARMY MILITARY DISTRICT OF WASHINGTON
(Unit/Command of Con vening Authority)

Tried at

Fort. Meade, MD on see below

(Piace or Piaces of Triai) (Date or Dates of Triai)







Date or Dates of Trial:

23 February 2012, 15?16 March 2012, 24?26 April 2012, 6?8 June 2012, 25 June 2012,

16?19 July 2012, 28?30 August 20l2, 2 October 2012, 12 October 2012, 17?18 October 2012,
7?8 November 2012, 27 November 2 December 2012, 5?7 December 2012, 10?11 December 2012,
8?9 January 2013, 16 January 2013, 26 February 1 March 2013, 8 March 2013,

10 April 2013, 7?8 May 2013, 21 May 2013, 3?5 June 2013, 10?12 JUne 2013, 17?18 June 2013,
25?28 June 2013, 1?2 July 2013, 8?10 July 2013, 15 July 2013, 18?19 July 2013,

25?26 July 2013, 28 July 2 August 2013, 5?9 August 2013, 12?14 August 2013,

16 August 2013, and 19?21 August 2013.

1 insert "verbatim or "summarized as appropriate. This form be used by the Army and Navy for verbatim records of triai oniy.)

2 See inside back co ver for instructions as to preparation and arrangement.

DD FORM 490, MAY 2000 PREVIOUS EDITION IS OBSOLETE Front Cover



00002

POST-TRIAL DOCUMENTS

PAPERWORK PERTAINING TO
CONFINEMENT

00003

DEPARTMENT OF THE ARMY
US ARMY INSTALLATION MANAGEMENT COMMAND
JOINT BASE MYER - HENDERSON HALL
MILITARY PERSONNEL DIVISION
106 CUSTER ROAD, BUILDING 202
FORT MYER, VIRGINIA 22211?1199

ORDERS 235 48 24 AUGUST 2013
MANNING, BRADLEY PV1 HHC USAG (wouc01) FORT MYER, VA 22211
You will proceed on permanent change of station as indicated.

Assigned to: PERSONNEL CONTROL FACILITY (W6CSPR) FT. SILL, OK WITH
CONFINEMENT AT THE UNITED STATES ARMY DISCIPLINARY BARRACKS, FT.
LEAVENWORTH, KS 66027

Reporting date: 22 AUGUST 2013 (VOCDR CONFIRMED)

Additional instructions: Sentencing in accordance with DD Form 2707
(Confinement Order) signed by CPT Von Elten Alexander, JA, (Trial Counsel).

FOR ARMY USE:

Auth: AR 27 10 Pers con no: NA

MDC: 7BE3 Asg to dsg: NA
indic: NOT APPLICABLE Control specialty: NONE
PPD: NONE Pers scty code: NA

PMOS: NA

SDN: MAN9504PL23548
Format: 410

FOR THE COMMANDER:









DISTRIBUTION:

(1)

LAW DIV, BLDG 32, FORT MCNAIR, DC 20319 (3)
PCF, FT. SILL, OK (3)

HHC USAG, FT. MYER, VA 22211

PV1 MANNING (15)



00004

DEPARTMENT OF THE ARMY

ARMY CORRECTIONS COMMAND
150 ARMY PENTAGON
WASHINGTON DC 200100150



REPLY TO
INTENTION OF

DAPM-ACC 22 August 13

MEMORANDUM FOR RECORD

SUBJECT: Transfer of Prisoner

1. The transfer of the following prisoner(s) to the USDB at Ft Leavenworth has been approved
by this office.

Name: Mannin Bradley
850*

Grade: E-3

Losing Unit; HHC, USAG, JBH-HH. Ft. MYER VA 22211
Charge(s): 134, 92

Date Adjudged: 21 Aug 13
Sentence: 35 Years

PTA: None

Presentence Confinement21181
Admin Credit: 112

Discharge: DD

Alcohol Related: No

Age: 25

Service: Arm
COM:

E-mail:
Transfer date: 22 Aug 13

2. Remarks:

3. POC for this memorandum ls Larry kester or Laura Mitchell at DSN

?oom





Correctional Program pecialist



00005

.DAPM-ACC 13 Mar 13

MEMORANDUM FOR RECORD

SUBJECT: Department of Army Confinement Procedures Checklist

1. IAW AR 190-47, based on operational requirements and programs, Army Corrections
Command (ACC) will determine place of incarceration for all Army prisoners who are sentenced
to confinement beyond 30 days. Notification of summary remaining in local contract jails
is required, including the required confinement documents and confinement checklist. Local
contract jails may not be used to confine adjudged prisoners beyond 30 days without prior
approval from ACC.

2. The enciosed checklist is required for any Courts-Martial resulting in a sentence to
confinement and will be completely filled out by the primary SJA FCC/representative.
required documents will be scanned and emailed to Mike Chvojka, Laura Mitchell and Lar

Kester at faxed to DSN
(do not fax the MPR and ROI. They wi be hand carried by escorts).

3. Reassignment orders: Soldiers who receive a sentence of 121 days or more confinement
without a punitive discharge/dismissal, or?adjudged a punitive discharge/dismissal will be
administratively assigned to the appropriate PCF with confinement at the designated
correctional IAW AR 600?62, Para 3-12. For those prisoners that do not meet the criteria
for reassignment the commander/186 contact information is required (e-mail, phone, and
address).

4. The transfer date is coordinated with ACC and the SJA representative/losing unit. The ACC
designated transfer date is the expected arrival date and is not an on or about date. if the unit is
unable to complete the mission on the designated date, ACC or the gaining facility needs to be
noti?ed immediately. Before conducting the actual transfer of the prisoner(s), the losing unit or
SJA representative will contact the gaining ACC facility and provide the escorts information as
well as their travel itinerary. SJA wiil provide the escorts with the checklist and ail required
documents to be hand carried to the gaining facility. it is highly encouraged that unit
commanders contact the installation PMO for escorting instructions/assistance for high
risk/special management prisoners.

5. ACC Points of contact be Mike Chvojka,
Encl .J. ST EBEL

Confinement Procedures Checklist Operations Division Chief
Army Corrections Command





00006

CONFINEMENT PROCEDURES CHECKLIST
DD Form 2704 (MAR 2013) WW

DD Form (MAR 2013) Result of Triai
DD Form 2707 (MAR 2013) Confinement Order
on Form 453 (MAY 2090) Charge Sheet

initiate



Report of Investigation (CID Report) ONLY 1 no nor FAX)
ERBIORB ?if
Pre-ETrial Agreement (if any)
Age of prisoner mg?

Is the prisoner currently in pretrial confinement, if so where?
Gender: Fm
Any previous disciplinary actions?
Were alcoho! or drugs a contributing factor in this case? Ni
Is the prisoner currently under a Doctors? care?
(lf so, iist name and phone number of Health Care Provider) NO.

Does the prisoner have any current or ongoing medical probierns or

require Speciai medical equipment?

Are there any mental health problems, suicidal/homicidelihomosexeall
assaultive thoughts or tendencies or a history of mental health problems? 31L

Does the prisoner have any PTSD related issues?

Has the prisoner assaulted or threatened any staff or other prisoners? 3; NW

List names of medications prescribed for prisoner and daily dosages if
applicable None.

List names of medications prescribed for prisoner and daily dosages if
applicable None .

How many days medication supply will prisoner have on hand upon arrival? we

Is the prisoner an escape risk? (If yes, expiain why)









00007

CONFINEMENT PROCEDURES CHECKLIST CONT.

Was DNA sample collected? {If yes, include test kit

is there any additional information that should be known about this prisoner?
(If 50, list it here)



Any additionai remaiks, comments. or concerns:
Prisoner confined at JRCF, Ft Leavenworth, KS durinq Pre?Trial.







Requested move date: 2 2 August 2 1 3

Prisoner's UIC: Wt)va



Primary SJA POC:

SJA POC ible name



I

numberi?Commercial or DSN

Phone numb-arms?




SJA PDC lam a signature



Unit



156's legible name

enfCornmereial or USN



1 5 email EUGFESS

Corn Commander Ia this name

ilmianl ismmander?s inane numberiCdmmai-ciat or USN





00008



1. DATE OF TRIAL
DEPARTMENT OF DEFENSE REPORT OF RESULT OF TRIAL 20130603





TD: {Cumming Anthony)
Commander, Headquarters, United States 15111111.r Military District of Washington, Fort Lesley J. MCNair, Washington DC 20319



1. NOTIFICATION UNDER R.C.M. 1101 IS HEREBY GIVEN IN THE CASE OF THE UNITED STATES VERSUS:















































a. NAME (Last, Fm, Mijdb BRANCH OF SERVICE c. RANKIORADE 11- Dun (Last 4)
Manning, Bradley E. Army 3
a. ORGANIZATION add-ass) 3i OF one}
JUDGEALONE ALONE
h. CONVENED HY: COURT MARTIAL ORDER a. ISSUINO COMMAND d. DATE
I
201 10202
3. OF OFFENSES, PLEAS AND FINDINGS
a. CHARCEI h. d. e. f.
SPECIFICATION UCMJ CODE BRIEF DESCRIPTION OF OFFENSE PLEA FINDING
SEE CONTINUATION SHEET
La. DATE h. DATE OF ANY FORFEITURES OR REDUCTIONS
20130321 20130903
6. SENTENCE

To forfeit ail pay and allowances; to he redueed to Private, to be con?ned for 35 years; and to be IiishonorI'IIJIJ.r discharged from the Service.



Ea. CONTENTS OF PRE-TRIAL AGREEMENT CONCERNING SENTENCE TO CONFINEMENT (If 3ij























None.

h. DAYS OF PRE-TRIAL CREDIT C. DAYS OF OTHER JUDGE ORDERED CREDIT TOTAL PRESENTENCE CREDIT TOWARD POST-TRIAL
1131 112 CDNFINEHENT 1293

1. DNA PROCESSING: IAIN 10 U.S.C. 51566 IS IS NOT REQUIRED.

E. OFFENDER REGISTRAHON: 42 U.S.C. i140? IS IS NOT REQUIRED.

El. COMPANION ACCUSEDICO-ACCUSED {Namafs} and Soda: Sasumjr Numberfs) {Ifan?}

None.



1o. DISTRIBUTION {Copy pmuead IO
Cdr, HHC, SJA, HQ, Con?nement FSCility aocuserl', Defense Counsel









11. SIGNED BY {Kane} I I TRIAL COUNSEL I SUMMARY OFFICER

a. NAME (Last, First. A?db may} h. c. BRANCH OF SERVICE

Fein, Ashden (NMI) ?1 Army

at. SIGNATURE e.
20130321









FORM 2707-1, MAR 2013 PREVIOUS EDITION IS OBSOLETE. Adobe PmIassIonaIx

00009





INSTRUCTIONS FOR COMPLETING DD FORM 2707-1, OF DEFENSE REPORT OF RESULT OF

Date of Trial: Enter date (and all other dates) as 4 digit year, 2 digit month and 2 digit day, no separators.
To: Address to the Convening Authority (CA). Include at least two elements of CA unit, geographical location and ZIP code.

. United States versus:

. Name. Enter the accused name (Last, First, Middle Initial).

. Branch of Service (Army, Navy, Air Force, etc.).

Rank/Grade (E-6, etc.).

. ID number or Social Security Number (Last4 only).

. Organization. Accused full unit address. Include at least two elements of the accused unit, geographical location and ZIP code.

maps-ma

2. Type of Court Martial. a. Enter an in the appropriate box.
b. - d. Convened by: Convening Order number(s), issuing command, and date(s) of the Court Martial Order Number(s), or, if the
trial is by SCM, note on form as appropriate and enter the date of detail of the SCM from the referral on PartV, DD Form 458.

. Summary of Offenses, Pleas, and Findings.

. Charge Number(s) and Specification(s), if any.

. UCMJ Article(s). Article number list from the Uniform Code of Military Justice (example: ART 121).

. DIBRS Code. Offense severity scale, reference 1325.7 for code listing (example: ART 121-A1).
. Brief Description of Offense (example: Larceny).

. f. Pleas/Findings. Respective pleas and findings or other disposition.

(DQ000303

4.a. Date Adjudged. Date of court-martial.

b. Date of Forfeitures or Reductions. Any forfeiture of pay or allowances or reduction in grade that is included in a sentence ofa
CM takes effect on the earlier of: (1) the date that is 14 days after date on which the sentence is adjudged; or (2) the date on which
the sentence is approved by the convening authority.

5. Sentence. Enter the sentence of the court-martial. If trial resulted in an acquittal, enter

Admin/Judicial Credit/Pre-Trial Agreement.

Enterthe content of pre-trial agreement concerning sentence, if any. If none, enter "None".

Enterthe number of days the accused was in pre-trial (pre?sentence confinement). If none, enter

c. Enter the number of days ofjudge ordered administrative credit for illegal pre-trial (pre-sentence) confinement restriction found
tantamount to confinement, if any. If none, enter

d. Enter the total number of days of pre-trial and judge ordered credit (pre-sentence) confinement credit towards post-trial
confinement, if any. If none, enter



7. DNA Processing. In accordance with 10 U.S.C. 1565, DNA samples are required on each person subject to UCMJ who is or
has been convicted of a "Qualifying Military Offense" (QMO). A QMO is any offense under UCMJ punishable by a sentence to
confinement for more than one year. regardless of the sentence imposed. The Service is authorized to collect DNA samples at any
time after a general or special court?martial sentence is adjudged for one or more It is the Court?Martial Convening
Authority (CMCA) action under Article 60 that determines whetherthe result of trial concludes with a QMO conviction.

NOTE: DNA sample does not apply to the finding of SCM or proceeding under Article 15, UCMJ.

8. Sex Offender Registration. In accordance with 42 U.S.C. 14071: a person convicted of any of the offenses punishable under
the UCMJ (reference 1325.7 for listing). NOTE: A "Qualifying Military Offense" is a felony or sexual offense determined
by the Secretary of Defense to be a QMO for the purpose of 10 U.S.C.

9. Companion Accused/Co-Accused. Enter the name(s) and Social Security Number(s) (last 4 digits only) of companion or
co-accused, if any. If none, enter

10. Distribution. Enter a list of copies furnished to named agencies or units (example: Finance, Company, etc.). NOTE: Make
sufficient copies after the form is signed by the trial counsel or SCM Officer. Forward the original to the convening authority.

11. Signed By. Enter an in the box to indicate whether Trial Counsel or Summary Court-Martial Officer.

a. e. Enter the full name, rank/grade and branch of service of the trial counsel orthe summary court-martial officer.

NOTE: You should ensure that a copy of the Department of Defense Result of Trial is expeditiously provided to the Finance and
Accounting Office (FAO) in any case involving a reduction in rank or forfeiture of pay or fine.



DD FORM 2707~1 (BACK), MAR 2013







00010

CONTINUATION SHEET, DD Form 2707?1 PFC MANNING, BRADLEY,
US. Army, Headquarters and Headquarters Comany, US. Army Garrison, Joint Base Myer?
Henderson Hall, Fort Myer, VA 22211

Section IV Continued:



a.
. C.DIBRS . . f.
ARTICLES) C.DE (LBRIEI DESCRIPTION .1 OIIENSE e. PLEA FINDINGS



In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
I/The 104 1 November 2009 and on or about NG NG
27 May 2010, without proper
authority, knowingly give
intelligence to the enemy, through
indirect means.

In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
1 November 2009 and on or about
27 May 2010, wrongfully and
wantonly cause to be published on
the intemet intelligence belonging
to the United States government,
having knowledge that intelligence
published on the intemet is
accessible to the enemy, such
conduct being prejudicial to good
order and discipline in the armed
forces and being of a nature to bring
discredit upon the armed forces.

In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
15 February 2010 and on or about 5
April 2010, having unauthorized
possession of information relating GM
to the national defense, to wit: a
video ?le named "12 JUL 07 CZ
ENGAGEMENT ZONE 30 GC
Anyoneavi", with reason to believe
such infonnation could be used to
the injury of the United States or to
the advantage of any foreign nation,

1



11/1 134 NG



11/2 134 134-Y1



















00011



CONTINUATION SHEET, DD Form 2707?1 PFC MANNING, BRADLEY, E,
US. Army, Headquarters and Headquarters Company, US. Annyr Garrison, Joint Base Myer-
Henderson Hall. Fort Myer, VA 22211





willfully communicate, deliver,
transmit, or cause to be
communicated, delivered, or
transmitted, the said information, to
a person not entitled to receive it, in
violation of 18 US. Code Section
793(e), such conduct being
prejudicial to good order and
discipline in the armed forces and
being of a nature to bring discredit
upon the armed forces.

Not Guilty, but Guilty of the
excepted words and figures ?15
February 2010? and ?5 April 2010?,
substituting therefor the words and
figures ?14 February 2010? and ?21
February 2010?; further excepting
the words ?information relating to
the national defense, to wit:?;
further excepting the words ?with
reason to believe such information
could be used to the injury of the
United States or to the advantage of
any foreign nation, willfully
communicate, deliver, transmit, or
cause to be communicated,
delivered, or transmitted,?,
substituting therefor the words ?did
willfully communicate?; further
excepting the words and ?gures, ?in
violation of 18 US. Code Section




Not Guilty, but Guilty of the
excepted words and ?gures.

In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
11/3 134 134-Y1 Hammer, Iraq, between on or about
22 March 2010 and on or about 26
March 2010, having unauthorized
possession of information relating

2





















CONTINUATION SHEET, DD Form 2707?1 PFC MANNING, BRADLEY, Eu



00012

US. Army, Headquarters and Headquarters Company, US. Army Garrison, Joint Base Myerw

Henderson Hall, Fort Myer, VA 22211





to the national defense, to wit:
more than one classi?ed
memorandum produced by a United
States government intelligence
agency, with reason to believe such
information could be used to the
injury of the United States or to the
advantage of any foreign nation,
willfully communicate, deliver,
transmit, or cause to be
communicated, delivered, or
transmitted, the said information, to
a person not entitled to receive it, in
violation of 18 US, Code Section
793(e), such conduct being
prejudicial to good order and
discipline in the armed forces and
being of a nature to bring discredit
upon the armed forces.











Not Guilty, but Guilty of the
excepted words and ?gures ?22
March 2010? and ?26 March 2010?,
substituting therefor the words and
?gures ?17 March 2010? and ?22
March 2010?; further excepting the
words ?information relating to the
national defense, to wit?; further
excepting the words ?with reason to
believe such information could be
used to the injury of the United
States or to the advantage of any
foreign nation, willfully
communicate, deliver, transmit, or
cause to be communicated,
delivered, or transmitted,?,
substituting therefor the words ?did
willfully communicate?; further
excepting the words and ?gures ?in
violation of 18 US. Code Section


Not Guilty, but Guilty of the









3

00013

CONTINUATION SHEET, DD Form 2707?1 PFC MANNING, BRADLEY,
U.S. Army, Headquarters and Headquarters Company, US. Army Garrison, Joint Base Myer?

Henderson Hall, Fort Myer, VA 22211



excepted the words and figures "22
March 2010", substituting therefor
the words and figures "17 March
2010".



11/4

134

134-Y1

In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
31 December 2009 and on or about
5 January 2010, steal, purloin, or
knowingly convert another, a record or thing of
value of the United States or of a
department or agency thereof, to
wit: the Combined Information
Data Network Exchange Iraq
database containing more than
380,000 records belonging to the
United States government, of a
value of more than $1,000, in
violation of 18 US. Code Section
641, such conduct being prejudicial
to good order and discipline in the
armed forces and being of a nature
to bring discredit upon the armed
forces.

NG





After pleas but before ?ndings,
the Military Judge granted an
opposed motion by the Government
to amend the Speci?cation,
excepting the words ?to wit:? and
substituting therefor the words ?to
wit: a portion of?.









134



134-Y1



In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
31 December 2009 and on or about
9 February 2010, having
unauthorized possession of
information relating to the national
defense, to wit: more than twenty











4



00014



CONTINUATION SHEET, DD Form 2707?1 PFC MANNING, BRADLEY, E.,
US. Army, Headguarters and Headquarters Company, US. Army Garrison, Joint Base Myer?
Henderson Hall, Fort Myer, VA 22211





classi?ed records from the
Combined Information Data
Network Exchange Iraq database,
with reason to believe such
information could be used to the
injury of the United States or to the
advantage of any foreign nation,
willfully communicate, deliver,
transmit, or cause to be
communicated, delivered, or
transmitted, the said information, to
a person not entitled to receive it, in
violation of 18 US. Code Section
793(e), such conduct being
prejudicial to good order and
discipline in the armed forces and
being of a nature to bring discredit
upon the armed forces.

After arraignment but before
pleas, the Military Judge granted an
unopposed motion by the
Government to amend the
Speci?cation, adding the words
?and at or near Rockville,
Maryland,? after ?Iraq,?.



Not Guilty, but Guilty of the
excepted words and ?gures ?31
December 2009? and ?9 February
2010?, substituting therefor the
words and ?gures ?5 January 2010?
and ?3 February 2010?; further
excepting the words ?information
relating to the national defense, to
wit:?; further excepting the words
?with reason to believe such
information could be used to the
injury of the United States or to the
advantage of any foreign nation,
willfully communicate, deliver,
transmit, or cause to be
communicated, delivered, or

5



















00015

CONTINUATION SHEET, DD Form 2707-1 PFC MANNING, BRADLEY, E.,
US. Army, Headquarters and Headquarters Company, US. Army Garrison, Joint
Henderson Hall, Fort Myer, VA 22211







transmitted,?, substituting therefor
the words, ?did willfully
communicate?; further excepting
the words and ?gures ?in violation
of 18 US. Code Section
In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
31 December 2009 and on or about
8 January 2010, steal, purloin, or
knowingly convert another, a record or thing of
value of the United States or of a
department or agency thereof, to
wit: the Combined Information

11/6 134 l34-Y1 Data Network Exchange NG
Afghanistan database containing
more than 90,000 records belonging
to the United States government, of
a value of more than $1,000, in
violation of 18 US. Code Section
641, such conduct being prejudicial
to good order and discipline in the
armed forces and being of a nature
to bring discredit upon the armed
forces.

After pleas but before ?ndings,
the Military Judge granted an
opposed motion by the Government
to amend the Speci?cation,
excepting the words ?to wit:? and
substituting therefor the words ?to
wit: a portion of?.

In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
31 December 2009 and on or about
9 February 2010, having
unauthorized possession of
information relating to the national

6







11/7 134 134-Y1



















CONTINUATION SHEET, DD Form 2707-1 PFC MANNING, BRADLEY, E.,
US. Army, Headguarters and Headquarters Company, US. Army Garrison, Joint

Henderson Hall, Fort Myer, VA 22211

00016

!ase Cl"



defense, to wit: more than twenty
classi?ed records from the
Combined Information Data
Network Exchange Afghanistan
database, with reason to believe
such information could be used to
the injury of the United States or to
the advantage of any foreign nation,
willfully communicate, deliver,
transmit, or cause to be
communicated, delivered, or
transmitted, the said information, to
a person not entitled to receive it, in
violation of 18 US. Code Section
793(e), such conduct being
prejudicial to good order and
discipline in the armed forces and
being of a nature to bring discredit
upon the armed forces.











After arraignment but before
pleas, the Military Judge granted an
unopposed motion by the
Government to amend the
Speci?cation, adding the words
?and at or near Rockville,
Maryland,? after ?Iraq,?.

Not Guilty, but Guilty of the
excepted words and ?gures ?31
December 2009? and ?9 February
2010?, substituting the words and
?gures ?5 January 2010? and ?3
February 2010?; further excepting
the words ?information relating to
the national defense, to wit:?;
further excepting the words ?with
reason to believe such information
could be used to the injury of the
United States or to the advantage of
any foreign nation, willfully
communicate, deliver, transmit, or
cause to be communicated,









7



00017

CONTINUATION SHEET, DD Form 2707-1 PFC MANNING, BRADLEY, E.,
U.S. Army, Headquarters and Headquarters Company, U.S. Army Garrison, Joint Base lVIverw

Henderson Hall, Fort Myer, VA 22211



delivered, or transmitted,?,
substituting therefor the words ?did
willfully communicate?; further
excepting the words and ?gures ?in
violation of 18 U.S. Code



11/8

134

134-Yl

In that Private First Class Bradley
E. Manning, U.S. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, on or about 8 March
2010, steal, purloin, 0r lmowingly
convert another, a record or thing of value
of the United States 0r of a
department or agency thereof, to
wit: a United States Southern
Command database containing
more than 700 records belonging to
the United States government, of a
value of more than $1,000, in
violation of 18 U.S. Code Section
641, such conduct being prejudicial
to good order and discipline in the
armed forces and being of a nature
to bring discredit upon the armed
forces.

NG



11/9





134



l34-Yl



In that Private First Class Bradley
E. Manning, U.S. Army, did, at or
near Contingency Operating Station
.Hammer, Iraq, between on or about
8 March 2010 and on or about 27
May 2010, having unauthorized
possession of infonnation relating
to the national defense, to wit:
more than three classi?ed records
from a United States Southern
Command database, with reason to
believe such information could be
used to the injury of the United
States or to the advantage of any
foreign nation, willfully
communicate, deliver, transmit, or











8



00018

CONTINUATION SHEET, DD Form 2707?1 PFC MANNING, BRADLEY,
US. Army, Headquarters and Headquarters Company, US. Army Garrison, Joint ase ver-

Henderson. Hall, Fort Myer, VA 22211



cause to be communicated,
delivered, or tansmitted, the said
infonnation, to a person not entitled
to receive it, in violation of 18 US.
Code Section 793(e), such conduct
being prejudicial to good order and
discipline in the armed forces and
being of a nature to bring discredit
upon the armed forces.



Not Guilty, but Guilty 0fthe
excepted words and ?gures
?between on or about 8 March 2010
and on or about 27 May 2010?,
substituting therefor the words and
figures ?on or about 8 March
2010?; further excepting the words
?information relating to the national
defense, to wit:?; further excepting
the words ?with reason to believe
such information could be used to
the injury of the United States or to
the advantage of any foreign nation,
willfully communicate, deliver,
transmit, or cause to be
communicated, delivered, or
transmitted,?, substituting therefor
the words ?did willfully
communicate?; further excepting
the words and ?gures ?in violation
of 18 US. Code









134







In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
11 April 2010 and on or about 27
May 2010, having unauthorized
possession of information relating
to the national defense, to wit:
more than ?ve classi?ed records
relating to a military operation in
Farah Province, Afghanistan









9



CONTINUATION SHEET, DD Form 2707-1 PFC MANNING, BRADLEY, E.,
US. Army, Headguarters and Headquarters Company, US. Army Garrison. Joint Base Myer;

Henderson Hall, Fort Myer, VA 22211





00019



occurring on or about 4 May 2009,
with reason to believe such
information could be used to the
injury of the United States or to the
advantage of any foreign nation,
willfully communicate, deliver,
transmit, or cause to be
communicated, delivered, or
transmitted, the said information, to
a person not entitled to receive it, in
violation of 18 US. Code Section
793(e), such conduct being
prejudicial to good order and
discipline in the armed forces and
being of a nature to bring discredit
upon the armed forces.



Not Guilty, but Guilty of the
excepted words and ?gures ?11
April 2010? and ?27 May 2010?,
substituting therefor the words and
?gures ?10 April 2010? and ?12
April 2010?; further excepting the
words ?information relating to the
national defense, to wit:?; further
excepting the words ?with reason to
believe such information could be
used to the injury of the United
States or to the advantage of any
foreign nation, willfully
communicate, deliver, transmit, or
cause to be communicated,
delivered, or transmitted,?,
substituting therefor the words ?did
willfully communicate?; further
excepting the words and ?gures ?in
violation of 18 US. Code Section










134







In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about



NG



NG





10

CONTINUATION SHEET, DD Form 2707-1 PFC MANNING, BRADLEY, E.

00020



US. Army, Headquarters and Headquarters Company, US. Garrison, Joint !ase aver-



Henderson Hall, Fort Myer, VA 22211





1 November 2009 and on or about 8
January 2010, having unauthorized
possession of information relating
to the national defense, to wit: a
?le named PAX.zip"
containing a video named
PAX.wmv", with reason to believe
such information could be used to
the injury of the United States or to
the advantage of any foreign nation,
willfully communicate, deliver,
transmit, or cause to be
communicated, delivered, or
transmitted, the said information, to
a person not entitled to receive it, in
violation of 18 US. Code Section
793(6), such conduct being
prejudicial to good order and
discipline in the armed forces and
being of a nature to bring discredit
upon the armed forces.









134

134-Y1

In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
28 March 2010 and on or about 4
May 2010, steal, purloin, or
knowingly convert another, a record or thing of
value of the United States or of a
department or agency thereof, to
wit: the Department of State Net-
Centric Diplomacy database
containing more than 250,000
records belonging to the United
States government, of a value of
more than $1,000, in violation of 18
US. Code Section 641, such
conduct being prejudicial to good
order and discipline in the armed
forces and being of a nature to bring
discredit upon the armed forces.



NG











11

CONTINUATION SHEET, DD Form 2707-1 PFC MANNING, BRADLEY, E.,
US. ArmL Headguarters and Headquarters Company, US. Army Garrison, Joint Base Myer?

Henderson Hall, Fort Myer, VA 22211



00021



11/13

134

134-Y1

In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
28 March 2010 and on or about 27
May 2010, having knowingly
exceeded authorized access on a
Secret Internet Protocol Router
Network computer, and by means
of such conduct having obtained
information that has been
determined by the United States
government pursuant to an
Executive Order or statute to
require protection against
unauthorized disclosure for reasons
of national defense or foreign
relations, to wit: more than
seventy??ve classi?ed United States
Department of State cables,
willfully communicate, deliver,
transmit, or cause to be
communicated, delivered, or
transmitted the said information, to
a person not entitled to receive it,
with reason to believe that such
information so obtained could be
used to the injury of the United
States, or to the advantage of any
foreign nation, in violation of 18
US. Code Section 103 such
conduct being prejudicial to good
order and discipline in the armed
forces and being of a nature to bring
discredit upon the armed forces.











Not Guilty, but Guilty of the
excepted words and figures ?27
May 2010?, substituting therefor the
words and ?gures ?4 May 2010?;
further excepting the words
?knowingly exceeded authorized
access?, substituting therefor the









12

00022



CONTINUATION SHEET, DD Form 2707?1 PFC MANNING, BRADLEY, E.,
US. Army, Headquarters and Headquarters Company, US. Army Garrison, Joint Base Mver-
Henderson Hall, Fort Myer, VA 22211



words ?knowingly accessed?;
further excepting the words ?with
reason to believe that such
infonnation so obtained could be
used to the injury of the United
States, or to the advantage of any
foreign nation, in violation of 18
US. Code Section

In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
15 February 2010 and on or about
18 February 2010, having
knowingly exceeded authorized
access on a Secret Internet Protocol
Router Network computer, and by
means of such conduct having
obtained information that has been
determined by the United States
government pursuant to an
Executive Order or statute to
require protection against
unauthorized disclosure for reasons
of national defense or foreign
relations, to wit: a classi?ed
Department of State cable titled
?Reykjavik-13?, willfully
communicate, deliver, transmit, or
cause to be communicated,
delivered, or transmitted the said
information, to a person not entitled
to receive it, with reason to believe
that such information so obtained
could be used to the injury of the
United States, or to the advantage of
any foreign nation, in violation of
18 US. Code Section 103
such conduct being prejudicial to
good order and discipline in the
armed forces and being of a nature
to bring discredit upon the almed

13



11/14 134 134-Y1



















CONTINUATION SHEET, DD Form 2707?1

PFC MANNING, BRADLEY, E.





00023



US. Army, Headquarters and Headquarters Company, US. Army Garrison. Joint Base Myer-
Henderson Hall, Fort Myer. VA 22211





forces.



Not Guilty, but Guilty of the
excepted words and ?gures ?15
February 2010? and ?18 February
2010?, substituting therefor the
words and figures ?14 February
2010? and ?15 February 2010?;
further excepting the words
?knowingly exceeded authorized
access?, substituting therefor the
words ?knowingly accessed?;
further excepting the words ?with
reason to believe that such
information so obtained could be
used to the injury of the United
States, or to the advantage of any
foreign nation, in violation of 18
US. Code Section

Not Guilty, but Guilty of the
excepted words and figures.









134







In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
15 February 2010 and on or about
15 March 2010, having
unauthorized possession of
information relating to the national
defense, to wit: a classified record
produced by a United States Army
intelligence organization, dated 18
March 2008, with reason to believe
such information could be used to
the injury of the United States or to
the advantage of any foreign nation,
willfully communicate, deliver,
transmit, or cause to be
communicated, delivered, or
transmitted, the said information, to
a person not entitled to receive it, in



6*







14



CONTINUATION SHEET, DD Form 2707-1

00024





PFC MANNING, BRADLEY,
US. Army, Headquarters and Headquarters Company, US. Army Garrison, Joint ase ver-

Henderson Hall, Fort Myer, VA 22211



violation of 18 US. Code Section
793(e), such conduct being
prejudicial to good order and
discipline in the armed forces and
being of a nature to bring discredit
upon the armed forces.



Not Guilty, but Guilty to the
excepted words and figures
?between on or about 15 February
2010 and on or about 15 March
2010?, substituting therefor the
words and figures ?on or about 8
March 2010?; further excepting the
words ?information relating to the
national defense, to wit:?; further
excepting the words ?with reason to
believe such information could be
used to the injury of the United
States or to the advantage of any
foreign nation, willfully
communicate, deliver, transmit, or
cause to be communicated,
delivered, or transmitted,?,
substituting therefor the words ?did
willfully communicate?; further
excepting the words and ?gures ?in
violation of 18 US. Code Section




11/16





134



134-Y1



In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
11 May 2010 and on or about 27
May 2010, steal, purloin, or
knowingly convert another, a record or thing of
value of the United States or of a
department or agency thereof, to
wit: the United States Forces Iraq
Microsoft Outlook I SharePoint
Exchange Server global address list











15

00025

CONTINUATION SHEET, DD Form 2707-1 PFC MANNING, BRADLEY, E.,
US. Army, Headqualters and Headquarters Company, US. Army Garrison, Joint Base Myer?
Henderson Hall, Fort Mver, VA 22211





belonging to the United States
government, of a value of more than
$1,000, in violation of 18 US. Code
Section 641, such conduct being
prejudicial to good order and
discipline in the armed forces and
being of a nature to bring discredit
upon the armed forces.

After pleas but before ?ndings,
the Military Judge granted an
opposed motion by the Government
to amend the Speci?cation,
excepting the words ?to wit:? and
substituting therefor the words ?to
wit: a portion of?.

In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
1 November 2009 and on or about 8
March 2010, violate a lawful
general regulation, to wit:
paragraph Army
Regulation 25-2, dated 24 October
2007, by attempting to bypass
network or information system
security mechanisms.

In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
1 1 February 2010 and on or about 3
April 2010, violate a lawful general
regulation, to wit: paragraph 4-
Army Regulation 25-2,
dated 24 October 2007, by adding
unauthorized software to a Secret
Internet Protocol Router Network
computer.

In that Private First Class Bradley
92 092-A0 E. Manning, US. Army, did, at or NG
near Contingency Operating Station

16





92 092-A0 NG



92 092-A0 NG





















00026

CONTINUATION SHEET, DD Form 2707-1 PFC MANNING, BRADLEY,
US. Army, Headquarters and Headquarters Company, US. Army Garrison, Joint Base Myer-
Henderson Hall, Fort Myer, VA 22211





Hammer, Iraq, on or about 4 May
2010, violate a lawful general
regulation, to wit: paragraph 4-
Army Regulation 25?2,
dated 24 October 2007, by adding
unauthorized software to a Secret
Internet Protocol Router Network
computer.

In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, between on or about
1 1 May 2010 and on or about 27
92 May 2010, violate a lawful general NG
regulation, to wit: paragraph 4-
Army Regulation 25?2,
dated 24 October 2007, by using an
information system in a manner
other than its intended purpose.

In that Private First Class Bradley
E. Manning, US. Army, did, at or
near Contingency Operating Station
Hammer, Iraq, on divers occasions
between on or? about 1 November
92 092-A0 2009 and on or about 27 May 2010,
violate a lawful general regulation,
to wit: paragraph 7-4, Army
Regulation 380-5, dated 29
September 2000, by wrongfully
storing classi?ed information.

Not Guilty, but Guilty to the
excepted words and ?gures, ?1
November 2009?, substituting
therefor the words and ?gures ?8
January 2010?.







Not Guilty, but Guilty of the
excepted words and ?gures.

















17



00027



ORDER



1. PERSON TO BE CONFINED 2. DATE
8. NAME (Last, First, Middle Initial) RITY NUMBER
























Manning, Bradley E. 2013082]
c. BRANCH d. GRADE 9 (Parent unit)
Army HHC. USAG, JBM-HH, Ft. Myer, VA 2221]
3. TYPE OF CONFINEMENT
a PRE-TRIAL b. RESULT OF NJP c. RESULT OF COURT MARTIAL:
[Em I:Ives Em EYES mm EYES
d. TYPE OF COURT MARTIAL: SCM I SPCM [l GCM El VACATED SUSPENSION



4. OF UCMJ ARTICLES VIOLATED (List all cheryels) r?l prisoner ls pro-trial. List guilty ?nding(s) only if prisoner is postotn'al.)
Article 134 Article 134 - 18 USC 793(8) Article 134 - 18 USC 64] Article 134 18 USC 1030(a)(l)
and Article 92 (x5)



5. SENTENCE ADJUDGED (Annotate sentence from the result of trial) ADJUDGED DATE
TO fOIfeit all pay and allowances, to he reduced to Private, l, to be confined for 35 years, and to be
dishonorably discharged from the Service. 20130821





6. IF THE SENTENCE IS DEFERRED, THE DATE DEFERMENT IS TERMINATED:



7. PERSON DIRECTING CONFINEMENT



NAME (Last, Middle Initial). GRADE AND TITLE h. IGNATURE c. DATE d. TIME
. 1;
von Ellen. Alexander, 03. Thai Counsel 20130821 Tr'bL}











8. LEGAL REVIEW AND APPROVAL REQUIRED (Review required by different name at 7 a and b.



a. DNA PROCESSING IS IS NOT REQUIRED UNDER 10 USC. 1555.







COLLECTED: YES P: NO
Io, SEX OFFENDER REGISTRATION IS IS NOT REQUIRED UNDER 42 USC. 14071
TYPED NAME (Last. First, Middle Initial). GRADE AND TITLE a e. DATE
I
Fem, Ashden (NMI). 0-4, Trial Counsel r- A- 20,3082,







9. MEDICAL CERTIFICATE (Required completion only when applicable by Servrce regurarlon)

e. The above named prisoner was examined by me at on 90/5"va and found to be
.
lor con?nement I certify that from this examination the execution of the foregoing sentence to con?nement will will not
produce serious Injury to the prisoner?s health. -- -

b. The following lrregularities were noted during the examination (List only non-medleallnformetlon. Refer to SF 600 for all medical infonnetion,
lncludlng Hlv, TB and pregnancy tests and results.)







10. EXAMINER



a. TYPED TITLE I b. SIGNATURE c. DATE d. TIME
Mo, FHA
Colonel, US. Army Medical Corps I 30,33 0- d' a; 002 a














11. RECEIPT FOR PRISONER (Completed by the correctlonal lacll
a. THE PRISONER NAMED ABOVE HAS BEEN RECEIVED FOR CONFINEMENT AT (Facility Name and Location)





AND TIME-
(Time)
I). PERSON RECEIPTING FOR PRISONER (Typed c. SIGNATURE d. DATE e. TIME
name (Last, First. Grade and Title)













DD FORM 2707, MAR 2013 PREVIOUS EDITION IS OBSOLETE Adobe Prolessiunal

00028

FOR OFFICIAL USE ONLY
Law Enforcement Sensitive

DATE: 21 AUG 2013

FROM: SAC CCIU WASHINGTON METRO RA QUANTICO

TO:

CHIEF OF CRIMINAL JUSTICE MDW FT MCNAIR DC







SUBIECT: CID REPORT OF INVESTIGATION 10TH - 0028?
5Y2P2 8P5 8P3 9G1 9G2F

DRAFTER:
RELEASER:

1. OF OCCURRENCES:
1. 01 NOV 2009, 0001 24 MAY 2010, 2300; VARIOUS LOCATIONS,
FORWARD OPERATING BASE (FOB) HAMMER, IRAQ, AE 09308



2. REPORTED: 10 JUN 2010, 1247
3. IN



1

FOR OFFICIAL USE ONLY
Law Enforcement Sensitive



00029

FOR OFFICIAL USE ONLY

Law Enforcement Sensitive



4. SUBJECT:

1. MANNING, BRADLEY
HEADQUARTERS AND HEADQ ANY (HHC), 2ND
BRIGADE COMBAT TEAM (BCT), 10TH MOUNTAIN DIVISION, FORWARD
OPERATING BASE (FOB) HAMMER, IRAQ, ARMED FORCES AFRICA, CANADA,
EUROPE MIDDLE EAST 09308; CT (ARTICLE 106A,
A US. GOVERNMENT COMPUTER WITHOUT, OR IN EXCESS OF,
AUTHORIZATION (18 USC TO A US. GOVERNMENT
COMPUTER (18 USC



5. VICTIM:

1. US. (ARTICLE 106A,
A US. GOVERNMENT COMPUTER WITHOUT, OR IN EXCESS OF,
AUTHORIZATION (18 USC TO A US. GOVERNMENT
COMPUTER (18 USC

6. INVESTIGATIVE SUMMARY:

THE INFORMATION IN THIS REPORT IS BASED UPON AN ALLEGATION OR
PRELIMINARY INVESTIGATION AND MAY BE CHANGED PRIOR TO THE
COMPLETION OF THE INVESTIGATION.

10TH STATUS:

THIS STATUS REPORT WAS GENERATED TO PROVIDE AN INVESTIGATIVE UPDATE.
ON 21 AUG 13 JUDGE LIND SENTENCED PFC MANNING TO 35 YEARS
CONFINEMENT, REDUCTION IN GRADE TO E?l, FORFEITURE OF ALL PAY AND
ALLOWANCES, AND DISHONORABLE DISCHARGE.

PENDING FINAL REVIEW BY THE COURT MARTIAL CONVENING AUTHORITY,

2
FOR OFFICIAL USE ONLY

Law Enforcement Sensitive

00030

FOR OFFICIAL USE ONLY
Law Enforcement Sensitive

REMAINING SUPPORT TO THE PROSECUTION TEAM AND PUBLICATION OF THE
FINAL REPORT OF INVESTIGATION.

9TH STATUS:
THIS STATUS REPORT WAS GENERATED TO PROVIDE AN INVESTIGATIVE UPDATE.

ON 3 JUN 13, GENERAL COURT MARTIAL PROCEEDINGS BEGAN AGAINST PFC
MANNING CULMINATING IN THE VERDICT ISSUED ON 30 JUL 13 BY COL DENISE R.
LIND, CHIEF JUDGE, US. ARMY IST JUDICIAL CIRCUIT. COL LIND FOUND PFC
MANNING NOT GUILTY OF AIDING THE ENEMY, AND ONE OTHER SPECIFICATION
OF RELEASING INFORMATION. COL LIND FOUND PFC MANNING GUILTY OF 20
OTHER SPECIFICATIONS RELATED TO THE THEFT AND RELEASE OF HUNDREDS OF
THOUSANDS OF INTELLIGENCE DOCUMENTS. THE SENTENCING HEARING WAS
SCHEDULED TO COMMENCE ON 31 JUL 13 AND WAS EXPECTED TO LAST UNTIL
MID AUGUST. BASED ON THE VERDICT, PFC MANNING FACES A MAXIMUM
SENTENCE OF 136 YEARS.

PENDING FINAL SENTENCING OF PFC MANNING AND PUBLICATION OF THE FINAL
REPORT OF INVESTIGATION.

8TH STATUS:
THIS STATUS REPORT WAS GENERATED TO PROVIDE AN INVESTIGATIVE UPDATE.

ON 26 AUG 11, WIKILEAKS BEGAN THE RELEASE OF APPROXIMATELY 122,000
ADDITIONAL DEPARTMENT OF STATE (DOS) CABLES ONTO THE INTERNET, WHICH
INCLUDED THE UNREDACTED NAMES OF INDIVIDUALS WHO HAD SPOKEN TO
AMERICAN DIPLOMATS WITH AN EXPECTATION OF CONFIDENTIALITY. IN SOME
CASES, THE CABLES WERE MARKED WITH THE WARNING
IN REGARDS TO THE IDENTITIES. FURTHER, DER FREITAG, A
GERMAN PUBLICATION, REPORTED THAT AN FILE CONTAINING ALL
OF THE 251,287 DIPLOMATIC CABLES CLAIMED TO BE IN THE POSSESSION OF
WIKILEAKS WAS INADVERTENTLY POSTED BY WIKILEAKS MONTHS AGO.
ADDITIONALLY, THEY REPORTED THE PAS SWORD TO THAT FILE WAS RECENTLY
MADE AVAILABLE ON THE INTERNET VIA AN UNINTENTIONAL DISCLOSURE BY
AN OF WIKILEAKS (NFI). THE CABLES IN THIS FILE WERE
REPORTED TO HAVE BEEN UNREDACTED, THEREBY EXPOSING DIPLOMATIC
SOURCES TO POSSIBLE REPRISAL.

TO DATE, CCIU HAS VERIFIED THAT WIKILEAKS POSTED APPROXIMATELY 122,000
UNREDACTED DOCUMENTS THAT APPEAR TO BE LEGITIMATE DOS CABLES,

3

FOR OFFICIAL USE ONLY
Law Enforcement Sensitive

00031

FOR OFFICIAL USE ONLY

Law Enforcement Sensitive

CLASSIFIED AND UNCLASSIFIED. THE 122,000 CABLES HAVE BEEN COLLECTED AS
EVIDENCE AND ANALYSIS IS ONGOING.

INVESTIGATION CONTINUES BY CID, FBI, AND DSS.
7TH STATUS:
THIS STATUS REPORT WAS GENERATED TO PROVIDE AN INVESTIGATIVE UPDATE.

ON 24 APR 11, WIKILEAKS POSTED ON THEIR WEBSITE APPROXIMATELY 779
SENSITIVE DOCUMENTS RELATED TO DETAINEES HOUSED AT U.S. NAVAL
STATION GUANTANAMO BAY, MANY OF WHICH WERE CLASSIFIED. THE RELEASE
WAS COORDINATED WITH THE NEW YORK TIMES, WASHINGTON POST, EL PAIS (A
SPANISH NEWSPAPER) AND OTHER NEWS MEDIA EACH OF
WHICH PUBLISHED SEPARATE ARTICLES ON THEIR WEB SITES. CCIU ANALYSIS
INDICATES THE DOCUMENTS ORIGINATED FROM WEB SERVERS HOSTING THE
INTELINK RELATED WEBSITE INTELLIPEDIA, WHICH IS ACCESSIBLE ON THE
SIPRNET. FURTHER, CCIU PRELIMINARY FORENSIC EXAMINATIONS FOUND
REMNANTS OF DETAINEE DOCUMENTS RELATED TO GUANTANAMO BAY ON
BOTH PFC SIPRNET AND PERSONALLY OWNED COMPUTERS, AND
HAVE IDENTIFIED LOG FILES SHOWING WHEN THESE DOCUMENTS WERE
ALLEGEDLY ACCESSED BY PFC MANNING. FORENSIC ANALYSIS CONTINUES.

ON 20 APR 11, PFC MANNING WAS TRANSFERRED FROM THE MARINE CORPS BASE
BRIG, QUANTICO, VA TO THE MIDWEST JOINT REGIONAL CORRECTIONAL
FACILITY, FORT LEAVENWORTH, KS, PENDING AN ARTICLE 32 HEARING.
MARTIAL JURISDICTION FOR PFC MANNING REMAINS WITH THE COMMANDING
GENERAL, MILITARY DISTRICT OF WASHINGTON.

INVESTIGATION CONTINUES BY CID, FBI, AND DSS.
6TH STATUS:
THIS STATUS REPORT WAS GENERATED TO PROVIDE AN INVESTIGATIVE UPDATE.

ON 28 NOV 10, WIKILEAKS POSTED ON THEIR WEBSITE APPROXIMATELY 243
SENSITIVE STATE DEPARTMENT CABLES, MANY OF WHICH WERE CLASSIFIED.
WIKILEAKS INDICATED IT WAS IN POSSESSION OF 251,287 STATE DEPARTMENT
CABLES AND WOULD RELEASE THE REMAINDER OVER THE NEXT FEW MONTHS.
WIKILEAKS COORDINATED THIS RELEASE WITH DER SPIEGEL (A GERMAN NEWS
MAGAZINE), THE GUARDIAN (A UK. NEWSPAPER), LE MONDE (A FRENCH
NEWSPAPER), AND OTHER MEDIA OUTLETS, EACH OF WHICH PUBLISHED

4
FOR OFFICIAL USE ONLY

Law Enforcement Sensitive

00032

FOR OFFICIAL USE ONLY
Law Enforcement Sansitive

ARTICLES ON THEIR WEBSITES CCIU ANALYSIS INDICATES THE DOCUMENTS
ORIGINATED FROM A CLASSIFIED STATE DEPARTMENT DATABASE LOCATED ON
THE SIPRNET. FURTHER, CCIU PRELIMINARY FORENSIC EXAMINATIONS FOUND
OF THE STATE DEPARTMENT CABLES ON BOTH PFC
SIPRNET AND PERSONALLY OWNED COMPUTERS. FORENSIC ANALYSIS
CONTINUES.

THE LOSS OR COMPROMISE OF CLASSIFIED INFORMATION AND THE LOSS OF
PERSONALLY IDENTIFIAELE INFORMATION (PII) IS BEING ASSESSED. THE
ESTIMATED COST OF DAMAGE IS PENDING. THE POSSIBILITY OF ADDITIONAL
OFFENSES AND SUBJECTS IS BEING EVALUATED.

INVESTIGATION CONTINUES BY CID, FBI, AND DSS.
5TH STATUS:
THIS STATUS REPORT WAS GENERATED TO PROVIDE AN INVESTIGATIVE UPDATE

ON 22 OCT 10, WIKILEAKS POSTED ON THEIR WEBSITE APPROXIMATELY 391,832
CLASSIFIED DOCUMENTS RELATING TO THE WAR IN IRAQ. THE RELEASE WAS
COORDINATED WITH THE NEW YORK TIMES, DER SPIEGEL (A GERMAN NEWS
MAGAZINE), THE GUARDIAN (A UK. NEWSPAPER), AND AL IAZEERA (AN ARABIC
LANGUAGE NEWS NETWORK), EACH OF WHICH PUBLISHED SEPARATE ARTICLES
ON THEIR WEB SITES. CCIU ANALYSIS INDICATES THE DOCUMENTS ORIGINATED
FROM ONE OF THE COMBINED INFORMATION DATA EXCHANGE (CIDNE) SERVERS
LOCATED ON THE FURTHER, CCIU PRELIMINARY FORENSIC
EXAMINATIONS FOUND REMNANTS OF CIDNE DOCUMENTS RELATING TO IRAQ
ON BOTH PFC SIPRNET AND PERSONALLY OWNED COMPUTERS.
FORENSIC ANALYSIS CONTINUES.

THE LOSS OR COMPROMISE OF CLASSIFIED INFORMATION AND THE LOSS OF
PERSONALLY IDENTIFIABLE INFOIUVIATION (PII) IS BEING ASSESSED. THE
ESTIMATED COST OF DAMAGE IS PENDING, THE POSSIBILITY OF ADDITIONAL
OFFENSES AND SUBJECTS IS BEING EVALUATED.

INVESTIGATION CONTINUES BY FBL AND DSS.

4TH STATUS:

THIS STATUS REPORT WAS GENERATED TO PROVIDE AN INVESTIGATIVE UPDATEAUG 10,, WIKILEAKS POSTED CLASSIFIED PORTABLE

5

FOR OFFICIAL USE ONLY
Law Enforcement Sensitive



00033

FOR OFFICIAL USE ONLY
Law Enforcement Sensitive

DOCUMENT FORMAT (PDF) DOCUMENTS CONTAINING U.S. GOVERNMENT
REPORTING. PRELIMINARY ANALYSIS BY ANOTHER GOVERNMENT AGENCY
DISCLOSED PFC INTELINK ACCOUNT WAS THE ONLY ACCOUNT USED
TO VIEW AND OBTAIN THE PDF VERSION OF THESE DOCUMENTS PRIOR TO THEIR
RELEASE BY WIKILEAKS.

INITIAL FINDINGS INDICATE PFC SIPRNET ACCOUNT ACCESSED
APPROXIMATELY 20 OTHER CLASSIFIED DOCUMENTS PRODUCED BY THE OTHER
GOVERNMENT AGENCY. COLLECTION OF THE RELEVANT LOGS AND OTHER
FORENSIC ANALYSIS IS PENDING.

THE LOSS OR COMPROMISE OF CLASSIFIED INFORMATION AND THE LOSS OF
PERSONALLY IDENTIFIABLE INFORMATION (PII) IS BEING ASSESSED. THE
ESTIMATED COST OF DAMAGE IS PENDING. THE POSSIBILITY OF ADDITIONAL
OFFENSES AND SUBJECTS IS BEING EVALUATED.

INVESTIGATION CONTINUES BY CID, FBI, AND DSS.
3D STATUS:
THIS STATUS REPORT WAS GENERATED TO PROVIDE AN INVESTIGATIVE UPDATE.

ON OR ABOUT 30 JUL 10, WIKILEAKS POSTED AN FILE NAMED
WHICH IS SUSPECTED TO CONTAIN ADDITIONAL CLASSIFIED
DOCUMENTS. THE NATURE AND CONTENTS OF THE FILE ARE UNKNOWN. THE
FILE WAS DOWNLOADED AND COLLECTED AS EVIDENCE AND
EFFORTS ARE ONGOING.

ON 3 AUG 10, THE FBI ASSUMED THE LEAD AGENCY ROLE FOR MATTERS
INVOLVING POTENTIAL CIVILIAN SUSPECTS.

THIS IS A JOINT INVESTIGATION BY CID, DSS, AND THE FBI, WITH FBI AS THE
LEAD INVESTIGATIVE AGENCY FOR ALL CIVILIAN RELATED LEADS. CID
REMAINS THE LEAD INVESTIGATIVE AGENCY FOR ALL US. ARMY LEADS AND
MATTERS INVOLVING PFC MANNING. DSS WILL PURSUE ALL LEADS INVOLVING
THE DOS.




INVESTIGATION CONTINUES BY CID, FBI, AND DSS.

2D STATUS:

6
FOR OFFICIAL USE ONLY

Law Enforcement Sensitive



00034

FOR OFFICIAL USE ONLY

Law Enforcement Sensitive

THIS STATUS REPORT WAS GENERATED TO ADD THE FEDERAL BUREAU OF
INVESTIGATION (FBI) AS A JOINT PARTNER IN THIS INVESTIGATION AND PROVIDE
AN INVESTIGATIVE UPDATE.

ON 25 JUL 10, PUBLISHED ON THEIR WEBSITE APPROXIMATELY
77,000 CLASSIFIED DOCUMENTS RELATING TO THE WAR IN AFGHANISTAN. THE
RELEASE WAS COORDINATED WITH THE NEW YORK TIMES, DER SPIEGEL (A
GERMAN NEWS MAGAZINE), AND THE GUARDIAN (A UK. NEWSPAPER), EACH OF
WHICH PUBLISHED SEPARATE ARTICLES ON THEIR WEB SITES. CCIU ANALYSIS
INDICATES THE DOCUMENTS ORIGINATED FROM ONE OF THE COMBINED
INFORMATION DATA EXCHANGE (CIDNE) SERVERS LOCATED ON THE SIPRNET.
FURTHER, CCIU FORENSIC EXAMINATIONS FOUND REMNANTS OF CIDNE
DOCUMENTS RELATING TO IRAQ ON BOTH PFC SIPRNET AND
PERSONALLY OWNED COMPUTERS. FORENSIC ANALYSIS CONTINUES.

ON 29 JUL 10, THIS OFFICE WAS NOTIFIED THAT JURISDICTION
FOR PFC MANNING WAS TRANSFERRED FROM THE COMMANDING GENERAL, U.S.
DIVISION - CENTER, TO THE COMMANDING GENERAL, MILITARY DISTRICT OF
WASHINGTON. PFC MANNING WAS TRANSFERRED FROM THE THEATER FIELD
CONFINEMENT FACILITY, KUWAIT TO THE MARINE CORPS BASE BRIG, QUANTICO,
VA.

ON 30 JUL 10, THE WASHINGTON FIELD OFFICE, FBI, AGREED TO PARTICIPATE
OINTLY IN THIS INVESTIGATION.

THIS IS A JOINT INVESTIGATION BY CID, DSS, AND THE FBI, WITH CID AS THE
LEAD INVESTIGATIVE AGENCY. CID HAS PRIMARY RESPONSIBILITY FOR
COORDINATING ALL LEADS AFFECTING THE US. ARMY, AND DSS HAS
RESPONSIBILITY FOR LEADS INVOLVING THE DOS. THE FBI IS RESPONSIBLE FOR
PROVIDING COUNTERESPIONAGE EXPERTISE AND INVESTIGATIVE SUPPORT. THE

INVESTIGATION CONTINUES BY CID, DSS, AND FBI.
INITIAL:

ON 10 JUN 10, CID REPORT OF INVESTIGATION (ROI) WAS
CONTROL TRANSFERRED TO THIS OFFICE. THIS IS A CATEGORY I MONITORED
ROI.

ON 25 MAY 10, A CID SOURCE OF INFORMATION REPORTED THAT A SOLDIER
STATIONED IN IRAQ CLAIMED IN ONLINE CHAT SESSIONS THAT HE HAD

7

FOR OFFICIAL USE ONLY
Law Enforcement Sensitive

00035

FOR OFFICIAL USE ONLY
Law Enfercement Sensitive

DISCLOSED CLASSIFIED US. GOVERNMENT INFORMATION TO THE
OF WHICH THE
SUBSEQUENTLY POSTED ON THE PUBLICLY AVAILABLE WEB SITE.

PRELIMINARY INVESTIGATION REVEALED PFC MANNING, WHILE STATIONED AT
FORWARD OPERATING BASE (FOB) ENGAGED IN ONLINE CHAT
SESSIONS IN WHICH HE DISCLOSED THAT HE HAD GAINED ACCESS TO
CLASSIFIED US. GOVERNMENT COMPUTER SYSTEMS TO OBTAIN CLASSIFIED
INFORMATION. PFC MANNING SPECIFICALLY CLAIMED HE HAD OBTAINED TWO
CLASSIFIED US. AMY VIDEOS AND APPROXIMATELY 260,000 CLASSIFIED
DEPARTMENT OF STATE (DOS) DOCUIVIENTS. HE FURTHER CLAIMED TO HAVE
PROVIDED BOTH VIDEOS AND A PORTION OF THE CLASSIFIED DOS INFORMATION
TO A FOREIGN NATIONAL ASSOCIATED WITH WHO LATER POSTED
SOME OF THE INFORMATION TO THE PUBLICLY ACCESSIBLE WEB
SITE. IN THE CHAT SESSIONS, PFC MANNING REVEALED HE INITIALLY
DISCLOSED THE CLASSIFIED INFORMATION AS A TEST TO DETERMINE IF HE
COULD DO SO WITHOUT BEING DETECTED BY AUTHORITIES. HE
ACKNOWLEDGED THAT THE DISCLOSURES WOULD ADVERSELY AFFECT U.S.
FOREIGN RELATIONS.

ON 27 MAY 10, PFC MANNING WAS APPREIIENDED BY CID. PFC MANNING
INVOKED HIS RIGHT TO LEGAL COUNSEL AND DECLINED TO MAKE ANY
STATEMENTS. A MILITARY SEARCH AUTHORIZATION WAS EXECUTED ON PFC
WORK. AND LIVING AREAS, RESULTING IN THE SEIZURE OF VARIOUS
ITEMS OF DIGITAL EVIDENCE.

PRELIMINARY FORENSIC EXAMINATIONS REVEALED PFC MANNING EXCEEDED
HIS AUTHORIZED ACCESS TO CLASSIFIED US. GOVERNMENT COMPUTERS AND
DOWNLOADED APPROXIMATELY 10,000 CLASSIFIED AND UNCLASSIFIED DOS
DOCUMENTS AND AT LEAST ONE CLASSIFIED US. ARMY VIDEO. TO DATE, NO
EVIDENCE HAS BEEN FOUND THAT WOULD SIBSTANTIATE PFC
CLAIM OF DOWNLOADING 260,000 DOS DOCUMENTS. FORENSIC ANALYSIS
CONTINUES.

THE LOSS OR COMPROMISE OF CLASSIFIED INFORMATION AND THE LOSS OF
PERSONALLY IDENTIFIABLE INFORMATION (PII) IS BEING ASSESSED. THE
ESTIMATED COST OF DAMAGE IS PENDWG. THE POSSIBILITY OF ADDITIONAL
OFFENSES AND SUBJECTS IS BEING EVALUATED.

THIS IS A JOINT INVESTIGATION BY CID AND THE DOS: DIPLOMATIC SECURITY
SERVICE (DSS), WITH CID AS THE LEAD INVESTIGATIVE AGENCY. CID HAS
PRIMARY RESPONSIBILITY FOR COORDINATING ALL LEADS AFFECTING THE US.

8

FOR OFFICIAL USE ONLY
Lawr Enforcement Sensitive



00036

FOR OFFICIAL USE ONLY

Law Enforcement Sensitive

WLITY FOR LEADS INVOLVING THE DOS. THE-

INVESTIGATION CONTINUES BY CID AND DSS.



CID REPORTS OF INVESTIGATION ARE SUBJECT TO A QUALITY ASSURANCE
REVIEW BY CID HIGHER HEADQUARTERS.

7. COMMANDERS ARE REMINDED OF THE PROVISIONS OF AR 600-8-2 PERTAINING
TO SUSPENSION OF FAVORABLE PERSONNEL ACTIONS AND AR 380?67 FOR THE
SUSPENSION OF SECURITY CLEARANCES OF PERSONS UNDER INVESTIGATION.

8. USACIDC REPORTS ARE EXEMPT FROM AUTOMATIC TERMINATION OF
PROTECTIVE MARKINGS IN ACCORDANCE WITH CHAPTER 3, AR 25-65.

9

FOR OFFICIAL USE ONLY
Law Enforcement Sensitive

00037

ARTICLE 32
INVESTIGATION


-0

UNCLASSIFIED EXHIBIT 55 Encls)



INVESTIGATING REPORT
I?WChar'ges Under 3.2. and ROM. 405. for Courts-Martial}































1a. {Name afhwejtigarmg ejects?- GRADE c. ORGANIZATION DATE OF REPOR
Last, First. MI)
Almenza. Paul R. 0-5 Legal Support DetachmenHLSO} I I Ian 20I2
2a. TO: (Name ry'O?Icer who directed the b. TITLE 0. ORGANIZATION
Im'mugmmn Lem?. .UD Army ?artisan
Coma? Carl Jr. Joint Base MyerJ?Iendersnn Hall. Fort Myer. VA 222] I
33. NAME OF ACCUSED (I'mr. Fir". I). GRADE C. SSN (I. ORGANIZATION 3. DATE OF CHARGES
Manning, Bradley E. E-3 HHC. USAG. JB Myer-Hen. Hall 1 March 20] I
{Cheek aunt-er) YES NO
4. IN ACCORDANCE WITH ARTICLE 32. UCMJ. AND ROM. 405. MANUAL FOR COURTS-MARTIAL.
I HAVE INVESTIGATED THE CHARGES APPENUED HERETO {Exhibit 1)
5. THE ACCUSED WAS REPRESENTED BY COUNSEL (If not. see 9 below)
B. COUNSEL WHO REPRESENTED THE ACCUSED WAS QUALIFIED UNDER RCM. 405m} 50201]
Ta. NAME OF DEFENSE COUNSEL (Lust. First. GRADE 33. NAME OF ASSISTANT DEFENSE COUNSEL {Jami b. GRADE
Coombs. David E. CIV Kemkes. Matthew .1. 0-4







c. ORGANIZATION I?Tfapproprimej c. ORGANIZATION
US. Army Trial Defense Service. Atlantic Region







d. ADDRESS El. ADDRESS (Hepprepnmw

I I South Angell St.. Smte 317 229 I'Orresl Circle

Providence. RI {12906 Myer. VA 222l

Q. ITO be signed by net-used greet-med wan-ea meme! accused does no! IIng'. I'm-estigan'rlg q?iecr epraI'n In deter? In Item 3H
3. PLACE b. DATE





I HAVE BEEN INFORMED OF MY RIGHT TO BE REPRESENTED IN THIS INVESTIGATION BY COUNSEL. INCLUDING MY RIGHT TO
CIVILIAN OR MILITARY COUNSEL OF MY CHOICE IF REASONABLY AVAILABLE. I WAIVE MY RIGHT TO COUNSEL IN THIS INVESTIGATION.



I3. SIGNATURE OF ACCUSED



10. AT THE BEGINNING OF THE INVESTIGATION INFORMED THE ACCUSED IIppropI-Iate eerwen NO



THE CHARGEIS) UNDER INVESTIGATION



THE IDENTITY OF THE ACCUSER



THE RIGHT AGAINST SELF-INCRIMINATION UNDER ARTICLE 31



. THE PURPOSE OF THE INVESTIGATION





THE WITNESSES AND OTHER EVIDENCE KNOWN TO ME WHICH EXPECTED TO PRESENT



THE RIGHT TO WITNESSES



. THE RIGHT TO HAVE AVAILABLE WITNESSES AND EVIDENCE PRESENTED



THE RIGHT TO PRESENT ANYTHING IN DEFENSE. EXTENUATION. OR MITIGATION



THE RIGHT TO MAKE A SWORN OR UNSWORN STATEMENT. ORALLY OR IN WRITING



a



B. THE RIGHT TO BE PRESENT THROUGHOUT THE TAKING OF EVIDENCE
f.
9

I.
j.
1



Ia. THE ACCUSED AND COUNSEL WERE PRESENT THROUGHOUT THE PRESENTATION OF EVIDENCE I'I'fn?le accused
or cuemef were absent during any part q?he heImr I







b. STATE THE CIRCUMSTANCES AND DESCRIBE THE PROCEEDINGS CONDUCTED IN THE ABSENCE OF ACCUSED OR COUNSEL



NOTE: If additional space is required for any itemI enter the addltionaf material In Item 21 or on a separate sheet. Identify such material with
the proper numerical and. It appropriate, lettered heading II-LI-Imxpte .I Securely attach any additional sheets to the form and add a note In
the appropriate item of the form: "See additional sheet."





DD Form 45?. AUG 34 EDITION OF OCT as Is OBSOLETE. Adobe Pretesemnal an

UNCLASSIFIED WITH IO EXHIBIT 55 Encls)



UNCLASSIFIED EXHIBIT 55 EncIs)



123. THE FOLLOWING WITNESSES TESTIFIED UNDER OATH: (Check appropriate answer;



























NAME (Last. First. MI) GRADE Hfam't ORGANIZATIONIADDRESS (Whichwer is appropriate; YES NO
Graham. Toni MP Det Scho?eld Barracks,
Roberisun. Caider Computer Crimes Investlgotwe CID. Germany
Manda.- Mark Computer Crimes Investigative Unit, CID. VA
-
Benenmum Troy .S. Treaoury Dopanment tfonnerly ofCompuler Crime:-
Investlgauv:
. A .

Madnd, Bryan H. (REL) ?c m?
See continuation sheet

I). THE SUBSTANCE OF THE TESTIMONY OF THESE WITNESSES HAS BEEN REDUCED TO WRITING AND IS ATTACHED.
13a. THE FOLLOWING STATEMENTS, DOCUMENTS. OR MATTERS WERE THE ACCUSED WAS PERMITTED TO

EXAMINE EACH.
DESCRIPTION OF ITEM LOCATION OF ORIGINAL {Knot attached)



Soc continuation sheet

















b. EACH ITEM CONSIDERED, OR A COPY OR RECITAL OF THE SUBSTANCE OR NATURE THEREOF, IS ATTACHED



14. THERE ARE GROUNDS TO BELIEVE THAT THE ACCUSED WAS NOT RESPONSIBLE FOR THE OFFENSEIS) OR NOT
COMPETENT TO PARTICIPATE IN THE DEFENSE. (SEE RCM 909. warm



15. THE DEFENSE DID REOUEST OBJECTIONS TO BE NOTED IN THIS REPORT {If has. spa-cm,i In Item 2f below!



16. ALL ESSENTIAL WITNESSES WILL BE AVAILABLE IN THE EVENT OF TRIAL



17. THE CHARGES AND SPECIFICATIONS ARE IN PROPER FORM



1B. REASONABLE GROUNDS EXIST TO BELIEVE THAT THE ACCUSED COMMITTED THE OFFENSEISJ ALLEGED



19. I AM NOT AWARE OF ANY GROUNDS WHICH WOULD DIS-QUALIFY ME FROM ACTING AS INVESTIGATING OFFICER.
(See REM. mid) (I 1.









20. I
a. TRIAL BY SUMMARY SPECIAL GENERAL COURT-MARTIAL

b- OTHER (Spec-95v In Item 2! below}



21. REMARKS rfnciud'c. a: newsman expfamtionfor any delta): in the im'esligmion. and erpfanammfar am! above.)
See continuation slich

[For classi?ed testimony and exhibits. 5E: classi?ed annex. An unclassi?ed memorandum concoming the classified annex is attached as IO Ex. 55.]



223. TYPED NAME OFINVESTIGATING OFFICER D. GRADE c. ORGANIZATION

Almanza' Pm? 0'5 I??th Judge AdvoCatc General Detachment ILSO)















d. SIGNATURE OF INVESTIGATING OFFICER 3. DATE
I IlJan 2012


DD Form ?it?Reverse, AUG 84

UNCLASSIFIED WITH IO EXHIBIT 55

00040
Continuation Sheet. DD Form 457. U.S. v. PFC Bradley E. Manning

Item 8a. assistant defense counsel:

Paul R. Bouchard. 0-3 (P). US. Army Trial Defense Service. Atlantic Branch. 4217 Roberts
Ave. 3rd Floor. Fort Meade. MD 20755

Item I2a. witnesses who testified tmder oath:

Lim. Steven .I.. 0-3. HQ. First Army DivisiomEast. Fort Meade. MD

Fulton. Casey M.. 0-3. 2nd Bde. 10th Mountain Div.. Fort Drum. NY

Adkins. Paul D-. E-7. 10th Mountain Div. Fort Drum.

Balonek. Kyle 1.. W01. 10th Mountain Div.. Fart Drum. NY2

Madaras. Chad M.. E-S. 2nd Bde. 10th Mountain Div.. Fort Drum. NY

Milliman. Jason A.. Palmyra. VA

Cherepko. Thomas M.. 0-3. NATO Force Command Madrid. Spain

Shaver. David. Computer Crimes Investigative Unit. USACIDC. Quantico. VA
Baker. Eric 3.. ISL-4. 62nd Military Police Detachment. Fort Drum. NY

Johnson. Mark. Computer Crimes Investigative Unit. USACIDC. Quantico. VA
Showman. .Iihrleah. Syracuse. NY

Bigelow. Peter .I.. E-6. AFSOUTH BN Naples. Italy

Williamson. Alfred. Computer Crimes Investigative Unit. USACIDC. Quantieo. VA
Edwards. Antonio. Computer Crimes Investigative Unit. USACIDC. Quantico. VA
Lamo. Adrian. Carmichael. CA

Padgett. Daniel. E-S. 2nd Bde. 10th Mountain Div.. Fort Drum. NY

Keay. Barclay D.. 0-3. 2nd Bde. 10th Mountain Div.. Fort Drum. NY

Item 13a. statements. documents. or matters considered:

The documents considered are listed Evidence List). As the defense
objected on the basis of lack of authentication to several categories of documentsDeterminations Regarding DefenSe Objections to Government Evidence). I
determined I would consider certain documents subject to authentication. Those documents are
listed below:

IA Exam (Bates

IA Training Requirement (Bates 003 75772)

IA Virtual Training (Bates 003 75773)

Virtual Training 2 (Bates 00375 774]

Test Results (Bates it 00022348)

Al-Qaida Recruiting Video (Bates 00408202-36)

Al-Qaida in the Arabian Peninsula Magazine Bates it 00012570-71 1)

Enemy 1 Possession Evidence (HR 6 089 0563 ll (Redacted). Bates 00410660-64: Metadata
display. Bates 0041065 8-59: and Forensically recovered material. Bates 0041065467}



SFC Adkins invoked his Article 3] rights; I therefore detennined he was unavailable and considered his sworn
statements {Bates it 000133? ~76z 000 33 78-32: 00013334-ST).

3 WOI Balonek invoked his Article 3 rights: I therefore determined he was unavailable and considered his sworn
statement (Bates a 00013416-20).

Continuation Sheet. DD Form 457. US. v. PFC Bradley E. Manning

C3 Document Bates 003 78141-4?)

PFC Manning?s Military Intelligence Work Product {Range Stery Board. Bates 00410607-09;
multiple SIPRN ET email dated 100112. Bates 00410613-14; Multiple SIPRNET email (Bates
00410615-1 8: SIPRNET email dated 09] I 30 Bates 00410600-021

Afghanistan War Logs Posted by WikiLeaks (Bates 00410668?70')

HR 5 332 0069 10 (Bates 00410619?22)

DISA Trickler Report (Bates 00410653)

CIDNE data on the Internet (Bates ti 00410554)

NCD Valuation Documents {Bates 00410556-60)

Additionally, I considered the sworn statements of Adkins {Bates 0001337146;
00013378-82: 00013384-87) and W01 Balonek (Bates 00013416-20). who invoked their
Atticle 31 rights.

Attached are the following marked exhibits:

IO Ex. It D) Notice of Appearance. Mr. Coombs

10 Ex. Defense Motion Requesting Recusal of Investigating Of?cer. 16 December 201
[0 Ex. 3 Writ Seeking Access to the Proceedings (not considered)

10 Ex. Sealed Defense Stipulation of Expected Testimony (not considered)

[0 Ex. 5 Closed Hearing Checklist. 13 December 201 (not considered)
10 Ex. 6 Government Request for Closed Session. 15 December 201 1
10 Ex. 7 Open Hearing Checklist. 13 December 2011 {not considered)
10 Ex. 8 Closed Hearing Checklist. 19 December 201 I (not considered)

10 Ex. 9 Open Hearing Checklist. 19 December 201 1 (not considered)

10 Ex. Bates 00409680-84. 00409719-21

10 Ex. I l( P) Bates 00376856. 00409685-718

10 Ex. 12 Closed Hearing Checklist. 19 December 2011 (not considered)

IO Ex. 13 Open Hearing Checklist. 19 December 201 1 (not considered)

10 Ex. 14(1)) Defense Assertion of Privilege Under NLRB. 503. 19 December 2011

10 Ex. Government Response to Defense Assertion of Privilege Under MILE. 503.
20 December 201 1

10 Ex. 16 Unclassi?ed Closed Hearing Checklist. 20 December 201 1 (not considered)

10 Ex. 17 Unclassi?ed Open Hearing Checklist. 20 December 201 I (not considered)

10 Ex. 18(1)) Bates 00410555. 00409679

[0 Ex. 19(0) [.amo Chat

10 Ex. 20 Writ-Appeal Seeking Access to the Proceedings (not considered)

10 Ex. 211D) Defense Article 32 Exhibits

10 Ex. 22 10 Appointment Memorandum. 4 August 2010

10 Ex. 23 Directive to Investigate Additional Charges Memorandum. 18 March 201 1

10 Ex. 24 Special Instructions for Article 32 Investigation Memorandum.
16 November 201 1

IO Ex. 25 Charge Sheet containing Additional Charges 1-111 and their Speci?cations.
1 March 2011

10 Ex. 26 Defense Notice Under M.R.E. 5050013). 22 November 201 1

10 Ex. 27' Article 32 Investigation Noti?cation Memorandum. 23 November 11



Continuation Sheet, DD Form 457, U.S. v. PFC Bradley E. Manning

[Article 32 Investigation Noti?cation Memorandum Acknowledgement.

28 November 1 1

Defense Motion for Closed Hearing Under R.C.M 405(h)(3), 28 November 2011
Defense Request for Production of Evidence

Government Response to Defense Request for Production of Evidence,

30 November 201 1

Defense Request to Compel Production of Evidence. 1 December 2011

Defense Request for Article 32 Witnesses. 2 December 2011

Government Requested Evidence List. 2 December 2011

Government Response to Defense Request to Close Article 32 Hearing.

4 December 201 1

Defense Response to Government?s 405(h)(3) Filing, 4 December 201 1
Government Response to Defense Notice Under M.R.E-.

5 December 201 1

Government Additional Requested Evidence List. 7 December 201 1
Government Response to Defense Request for Article 32 Witnesses.

December 2011

Defense Witness Justi?cation. 8 Dec-ember 201 1

Witness List, 13 December 201 1

Closure Determination. 13 December 2011

Evidence List. 14 December 2011

Determinations Regarding Defense Objections to Government Evidence.

14 December 201]

Determinations as to Defense Requested Evidence. 15 December 2011
Determinations as to Defense Requested Witnesses. 15 December 201 1
Determinations as to Defense Requested Witnesses Revised. 16 December 201 1
Determinations as to Defense Requested Witnesses - Revised. 17 December 201 1
Reconsideration of Closure Determination. 20 December 201 1

Determination on Defense Assertion of Privilege Under M.R.E. 503,

21 December 2011

Defense Notice of Evidence. 23 December 201 I

Memoranda concerning excludable delay. various dates

E-mails discussing consideration of statements under penalty of perjury. various
dates

10 Chronology

Unclassi?ed memorandum. without enclosures, concerning classified annex to
this report containing 10 Exhibits (C) (C) 5. 1 January 2012

Transcript of Hearing (Verbatim 16 December 201 I. Summarized 17-22
December 201 1)

14.1

00043
Continuation Sheet, DD Form 457, LLS. v. PFC Bradley E. Manning

Item 21 remarks:



I. Ariaivsis oftheAddr?rionat Charges and Their Speci?cations?

The following supports my determination that reasonable grounds exist to believe that the
accused committed the offenses alleged in Additional Charges 1-111 and their Speci?cations. In
order that this document may remain unclassi?ed. have referenced Bates numbers of classi?ed
documents in the record where necessary and have only included unclassi?ed references to the
information contained in those documents. Also. in light ofthe voluminous record in this case, I
typically simply refer to Bates numbers of documents instead of referring to documents attached
as hard copy exhibits.

Additional Charge 1 and its Speci?cation (Art. 104, UCMJ):

Lent-

In order to prove this offense, the government must establish the following four elements:

1) that at or near Contingency Operating Station Hammer. Iraq, between on or about 1
November 2009 and on or about 27 May 2010. the accused, without proper authority, knowingly
gave intelligence information to certain persons, namely: Al-Qaida. Al?Qaida in the Arabian
Peninsula, and a person or entity speci?ed in Bates 00410660-64:

that the accused did so through indirect means:

(3) that Al-Qaida, Al-Qaida in the Arabian Peninsula, and a person or entity speci?ed in Bates
00410660-64 were enemies; and

that this intelligence information was true, at least in part.

?Intelligence? means any helpful information. given to and received by the enemy, which is true,
at least in part.

?Enemy? includes not only organized opposing forces in time of war, but also any other hostile
body that our forces may be opposing such as a rebellious mob or a band of renegade-s and
includes civilians as well as members of military organizations.

Under US. v. Batchei'or. 22 C.M.R. 144. 158 (CMA. 1956), ?Article 104(2) ofthe Code does
not require a specific criminal intent of any sort" and thus is a general intent crime.



Charges were initially prefen?ed against the accused on 5 July 2010. On 18 Mar 201 l. the convening authority
informed me that those Original charges were dismissed and directed me not to consider them. See 10 Ex. 23.

4

Continuation Sheet, no ram 457, ms. v. PFC Bradley E. Manning

Facts

The evidence showed that PFC Manning knew the enemy received information from
WikiLeal-tsfl The evidence also showed that from November 2009 through May 2010. there
were over one hundred searches for WikiLeaks under PFC Manning?s user pro?les on his
primary and secondary SIPRNET computers.5 More generally. the evidence showed the accused
knew that our adversaries, including enemy governments and non-government organizations
such as terrorists. obtained information via the Internet because he was required to conduct a
training presentation on Operational Security as corrective training when he was at Advanced

Individual Training on 13 J1me 21003."

Additionally. the evidence showed that the accused was a trained intelligence analyst who was
developing his skills during the deployment? Finally, the evidence showed that PFC Manning
signed non-disclosure agreements stating that ?unauthorized disclosure ofclassi?ed
information by me could cause damage or irreparable injury to the United States or could be used
to advantage by a foreign nation."3 It is reasonable to infer from these facts that the accused
knew enemies ofthe United States would receive information released by WikiLeaks.

The evidence showed that the accused, at or near Contingency Operating Base Hammer,?
between on or about 1 November 2009 and on or about 27 May 2010. knowingly gave
intelligence information to WikiLeaks. including: a video file named ?12 JUL 07' CZ
ENGAGEMENT ZONE 30 more than one classi?ed memorandum produced
by a United States Government intelligence agency; the IDNE-lraq database; the CIDNE
Afghanistan database; a United States Southern Command database. more than ?ve classified
records relating to a military operation in Farah Province, Afghanistan, occurring on or about 4
May 2009; a ?le named PAXzip? containing a video named 2'2 PAX.wmv;" the
Department of State Net-Centric Diplomacy database; a classi?ed record produced by a United
States Army intelligence organization, dated 18 March 2008; and the United States Forces Iraq
Microsoft Outlookaharepoint Exchange Server global address list.m While some of this
information was not classi?ed, the evidence showed that it is all ?intelligence information" in
that it would be helpful for the enemy to possess and was true, at least in part. For example, the
CIDNE databases contained a vast amount of information concerning enemy tactics and the US.
military?s response to those tactics.II while the last item listed, the global address list. would be



?i See Army intelligence Forensic Report, Bates if 0046452-66 and attachments.

5 Testimony of SA Shaver.

See PFC Manning's External Hard Drive Forensic Report, Bates 00l25270-3 8. in particular Bates it 001253 I4-
16- for a copy of the PowerPoint presentation the accused gave. SF Madrid also testi?ed that the accused?s
corrective training presentation explained that it could be dangerous to disclose classified information because
outside entities could seek U.S. information. Additionally. SFC Madrid teati?ed that the accused also submitted a
typed document providing more detail. including references to the relevant regulations.

Testimony Fulton.

See PFC Manning?s Non-Disclosure Agreements. Bates 0002291243. {10(136801-02.

Throughout the hearing. the witnesses typically referred to Hammer? rather than ?Contingency Operating
Base Hammer." [1 was clear. however. that they were referring to the same place.

'0 The analysis of Speci?cations 246 of Additional Charge II provides more detail about the offense conduct
involving each ofthese items.

Testimony Fulton.



00045
Continuation Sheet, on Form 457, vs. v. PFC Bradley E. Mending

helpful for the enemy to possess in that it would enable the enemy to engage in ?Spearfishing,? a
targeted attempt to gain from an unsuspecting source by masquerading as someone
the source trusts: speci?c information such as knowledge of full names and emails facilitates
Spearfishng because it is more likely to make the targeted source believe the spear?sher is
legitimate.

While the evidence did not show that PFC Manning directly provided this intelligence
information to Al-Qaida, Al-Qaida in the Arabian Peninsula, or the person or entity speci?ed in
Bates 00410660-64. the evidence did show that PFC Manning provided this intelligence
information to WikiLeaks. and that enemies of the United States possessed this information. For
example. the video named ??12 Jul 07 CZ ENGAGEMENT ZONE 20 SC Anyoneavi" is
contained in the recruiting video produced by Al-Qaida?s media arml3 and is described as
?footage published by the WikiLeaks website," which clearly indicates that the enemy obtained
this video from WikiLeaks. That video also speci?cally references the leak of a State
Department cable, which indicates they obtained the cable from WikiLeaks. and also references
WikiL-eaks documents describing communications by leaders in Islamic countries with the
United States. which also indicates they are referring to State Department cables they obtained
from WikiLeaks. Another example is that the evidence showed the CIDNEeAfghanistan
information was available to the enemy via the Internet."1 The accused therefore indirectly
provided this intelligence information to the enemy by providing it to WikiLeaks.

The evidence also showed that Al-Qaida. Al?Qaida in the Arabian Peninsula. and the classified
person or entity speci?ed in Bates 00410660-64 are enemies of the United States. First. the
recruiting video produced by Al-Qaida?s media arm'5 exhorts the viewer to attack the United
States. Similarly. the Al-Qaida in the Arabian Peninsula ?Inspire? magazines and associated
explanatory materialsm make clear that AQAP is also an enemy of the United States. Finally. the
description of the classi?ed person or entity specified in Bates 00410660-64 leaves little doubt
as to whether that person or entity is an enemy of the United States.

The evidence also showed that the information at issue is true. at least in part. For example. the
video entitled ?12 JUL 07 CZ ENGAGEMENT ZONE 30 GC. Anyoneavi" depicts what it
depicts. There was no evidence that any of the information at issue was false.

Although this offense is a general intent crime. the evidence showed that PFC Manning made
statements during a counseling session with then-SPC Showman prior to the deployment to the
effect that the American flag meant nothing to him and that he held no allegiance to this country
or to its people.? While this statement was made in the context of a counseling session that PFC
Manning was not pleased to be participating in. and thus may have been made printerin to ?push
the buttons" of the person counseling him. PFC Manning was a trained intelligence analyst and
should have known not to make such a statement flippantly. Accordingly. there are reasonable



'2 Testimony of SA Bettencourt.

'3 Bates a

Data on the Internet, Bates it

'5 Bates is: 00403202?236.

Bates a 00012570-711.

'7 Testimony of Ms. Showman in defense-requested closed session.

6

Continuation Sheet, DDForm 457, U.S. v. PFC Bradley E. Man-ding

grounds to believe that PFC Manning meant what he said. which turn would support the requisite
criminal intent were this a specific intent crime.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Additional Charge I and its Speci?cation.

Additional Charge 11, Speci?cation 1 (Art. 134, UCMJ):
Law
In order to prove this offense. the government must establish the following two elements:

(I that at our near Contingency Operating Station Hammer, Iraq. between on or about 1
November 2009 and on or about 27 May 2010. the accused wrongfully and wantonly caused
intelligence belonging to the United States to be published on the Internet, having knowledge
that intelligence published on the Internet is accessible to the enemy; and

that. under the circumstances. the conduct of the accused was to the prejudice of good order
and discipline in the armed forces and was ofa nature to bring discredit upon the armed forces.

?Conduct prejudicial to good order and discipline" is conduct which causes a reasonably direct
and obvious injury to good order and discipline. ?Service discrediting conduct" is conduct
which tends to harm the reputation of the service or lower it in public esteem.

Facts

The facts at issue here are similar to those discussed above concerning Additional Charge I and
its Speci?cation. Speci?cally. there is little doubt that between the dates and at the location
alleged. PFC Manning caused intelligence belonging to the United States to be published on the
Internet by providing it to WikiLeaks. and that when he did so he knew intelligence published on
the Internet is accessible to the enemy.

Additionally. testimony was presented that PFC Manning?s conduct was prejudicial to good
order and discipline and service discrediting. '8 The evidence showed that it is impossible to
control or verify each and every download or transfer ofinformation that intelligence
conduct. due to the tempo of operations in a Sensitive Compartmented Information Facility such
as the facility where PFC Manning worked in Iraq. Because of this. the evidence showed that
trust is important in protecting classi?ed information.? PFC Manning's violations of that trust
prejudiced good order and discipline and also discredited the service.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation 1 of Additional Charge 11.



'3 Testimony Lim.
Testimony Lim and Fulton.

00047
Continuation Sheet. DD ?rm 457. U.S. v. PFC Bradley E.

Additittnal Charge ll. Speci?cation 2 (Art. 134. 18 U.S.C. 793(e)):
Law
In order to prove this offense. the government must establish the following five elements:

(1) that at or near Contingency Operating Station Hammer. Iraq. between on or about 15
February 2010 and on or about 5 April 2010. the accused had unauthorized possession of
information relating to the national defense. to wit: a video file named ?12 JUL 07 C2
ENGAGEMENT ZONE 30 GC Anyoneavi";

(2) that the accused had reason to believe such information could be used to the injury ofthe
United States or to the advantage of any foreign nation;

(3) that the accused willfully communicated. delivered. transmitted. or caused to be
communicated, delivered. or transmitted the said information to a person not entitled to receive
it;

{24) that 18 U.S.C. section 793(c) exists; and

(5) that the accused's conduct was prejudicial to good order and discipline in the armed forces
and was of a nature to bring discredit upon the armed forces??

Facts

The evidence showed that "l 2 .lul 07" was searched for from both of PFC Manning?s primary
and secondary SIPRNET computers? The evidence also showed that the Apache air Strike
video located on the network share drive belonging to the 2nd Brigade Combat Team. 10th
Mountain Division. Of?ce of the Staff Judge Advocate. exactly matched a video identi?ed in
PFC Manning?s user pro?le on PFC Manning?s primary SIPRNET computer}: The evidence
also showed that a D-RW containing a video named "12 JUL 07 CZ ENGAGEMENT ZONE
30 GC An onewmv" was accessed using PFC Manning?s personal Macintosh computer on 15
Feb 22.010.?3 Additionally. the evidence showed that a CD-RW created on 27 April 2010
containing a video named ?12 JUL 07 ENGAGEMENT ZONE 30 Anyonewmv" (which
did not have all of the content of the video found on PFC Manning's primary SIPRNET
computer). with a sticker on it. was found in PFC Manning?s on-post quarters!? The
evidence showed that WikiLeaks released this video on 5 April 2010.2?

While there was no digital forensic evidence from PFC Manning's personal computer directly
indicating that this video was uploaded to WikiLeaks. the forensic examination did ?nd evidence
in Unallocated Clusters (UC) (brie?y. areas on a disk where the data has been "deleted" but still



3? These elements are a tailored version of Eighth Circuit Model Jury Instruction 6.18.1030A.

2' Intetink Logs Forensic Report. Bates it 00375] ?5429. at page I I (this document also has the relevant dates}.

23 lo"1 Mountain Shares Forensic Report. Bates tr 00046074-00046097. at 22.

33 See PFC Manning?s Personal Computer Forensic Report. Bates it 00 l24283?362. at pages 48-49.

?m Sec PFC Manning?s CD Forensic Report. Bates 00l995] 1-522. at pages 1. 7-8.

1? PFC Manning?s Personal Computer Forensic Report. Bates rt at Attachment 5. Bates tr 00I25269
(carved_ 8408_72473024123_Collateral

8

00048
Continuation Sheet. DD Form 457, US. v. PFC Bradley E. Manning

remains on the disk and can be recovered forensically) of multiple references to the WikiLeaks
upload webpage. including a webpage containing a link to
upload documents to WikiLeaks. and also references indicating a possible upload of the Farah
records gsee discussion of Additional Charge 11, Speci?cation 10. below] to the WikiLeaks
website.?? Moreover, PFC Manning's chats with a person using the
user name. aliased as Nathaniel Frank from 22 February 2010 to
25 March 2010, and as Julian Assange {editor of WikiLeaks) from 17 May 2010 to 24 May 2010
discussed uploading material to ?v'ifikiLeaks.27 These facts. taken together. provide circumstantial
evidence that PFC Manning uploaded the video to WikiLeaks.

The evidence also showed that on 19 May 2010. in an email exchange with Eric
Schmiedl. PFC Manning wrote. "Are you familiar with WikiLeaks." and then alter receiving an
affirmative reply from Mr. Schmiedl. then wrote. was the source of the 12 JUL 07 video from
the Apache Weapons Team. which killed the two journalists and injured two kids.?23

Additionally. the evidence showed that the accused. in his chats with Mr. Lame, admitted
forwarding the video that is the subject of this speci?cation. also referred to as the ?collateral
murder? or video. to WikiLeaks. In those chats. a person using the ?bradassST' screen
name. who Mr. Lamo determined to be the accused. made the following statements: (1) ?the CM
video came from a server in our domain! and not a single person noticed? (2) in response to
Lamo?s question about what CM meant. "Apache Weapons Team video of 12 Jul 07 airstrike on
Reuters some sketchy but fairly normal and civilians" (3) in response to
Lamo's question of where he (Lame) could transmit similar material if he had it. "wl.org
submission system?; and (4) "i couldn't let these things stay inside of the and
inside of my head i recognized the value of some knew what they dug
deeper i watched that video cold. for instance at ?rst it wasjust a bunch of guys
getting shot up by a no big about two dozen more where that came from
but something struck me as odd with the van thing-.. and also the fact it was being stored
in a JAG officer's so i looked into eventually tracked down the date, and then
the exact GPS and i was ok. so thats what then i went to the
regular internet. .. and it was still on my so i typed into goog. .. the date. and the
and then I see this 3iraq.html
i kept that in my mind for probably a month and a before 1 forwarded it to

?.29
them.



36 PFC Manning?s Personal Computer Forensic Report. Bates 00124233662. at 05-67.

27 PFC Manning's Personal Computer Forensic Report. Bates at 00124283662. at 20-32. 76.

is See PFC Manning?s Personal Computer Forensic Report. Bates it 00124233662. at page 44. Note that the login
password for PFC Manning?s personal computer was ??1?Wink149213." which also was the for PFC
Manning?s GPG keyring which contained a key used to emails between Schmied] and PFC Manning. The
forensic examiner concluded "it is likely that PFC Manning neglected to enable when sending the
message quoted above. M, at 45. "TWin I 492!!" was also identi?ed as a password for several instant messaging

accounts. including

a variation of this password.
was identi?ed as the password for id. at 14. The

commonality among these passwords indicates that the same individual used them.
?9 Lamo Chat1 10 Ex. 19(0). at 25-26. (This chat is also in the forensic reports at Lamo Forensic Report, Bates a
0012410Ti3 I- at Attachment J.) During his testimony. Mr. Lame explained that the person using the












Continuation Sheet, DD Form 457, US. v. PFC Bradley E. Manning

The evidence showed that WikiLeaks released this video on 5 April 2010.3? WikiLeaks was not
entitled to receive this video. which relates to the national defense because it depicts the
activities of the military. Also. the evidence shows that PFC Manning had reason to believe that
the video could be used to the injury of the United States in that PFC Manning knew the enemy
accessed information avaiIable on the Internet. Additionally. 18 793(e') exists. Finally,
PFC Manning?s conduct in providing this video to WikiLeaks is prejudicial to good order and
discipline and service discrediting.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Specification 2 of Additional Charge 11.

Additional Charge ll. Speci?cation 3 (Art. 134. 18 U.S.C. 793(6):
Law
in order to prove this offense. the government must establish the following ?ve elements:

that at or near Contingency Operating Station Hammer. Iraq. between on or about 22 March
2010 and on or about 26 March 2010. the accused had unauthorized possession of information
relating to the national defense. to wit: more than one classi?ed memorandum produced by a
United States Government intelligence agency:

(2) that the accused had reason to believe such information could be used to the injury of the
United States or to the advantage of any foreign nation:

(3) that the accused willfully communicated. delivered. transmitted. or caused to be
communicated, delivered. or transmitted the said information to a person not entitled to receive
it;

(4) that 18 U.S.C. section 793(c_) exists; and

(5) that the accused's conduct was prejudicial to good order and discipline in the armed forces
and was of a nature to bring discredit upon the armed forces.

Facts

The memoranda at issue are at Bates 00378084-090 and were produced by a United States
government intelligence agency. The evidence showed they were properly classified.? 1



online identity identi?ed himself as Bradley Manning by sending Lamo a friend request when Lamo asked ifhe was
a tacebook user and also by providing Lamo PFC Manning?s AKO account user name and password.

lntelink Logs Forensic Report, Bates 003751 16-129. at 9.

3' See document at Bates a 003781484 T5.

10

Continuation Sheet. no ?rm 457. US. v. PFC Bradley E.

Moreover. the evidence showed that PFC Manning knew they were classi?ed because they were
properly marked.

Testimony during the classi?ed portion of the hearing described the acgessing and manipulation
of these memoranda on PFC Manning's primary SIPRNET computer??

Analysis of PFC Manning?s personal computer showed a containing a ?le named
"blahzip" was burned on an unknown Windows computer at 12:55 on 22 March 2010 and was
accessed on PFC Manning?s personal computers? The evidence also showed that on 22 March
2010. a user ofPF Manning?s user account viewed .pdf ?les of the memoranda at issue on his
primary SIPRNET account: the forensic examiner concluded that the sequence of viewing the
?les and then accessing the ?le ?could indicate [the memoranda at issue] were
compressed in blahzip.?1H

The contents of the memoranda are such that a person familiar with them would conclude that if
released they could be used to the injury of the United States.

While there was no digital forensic evidence from PFC. Manning's personal computer directly
indicating that these memoranda were uploaded to WikiLeal-ts, the forensic examination did ?nd
evidence in Unallocated Clusters (UC) (briefly. areas on a disk where the data has been ?deleted?
but still remains on the disk and can be recovered forensically] ofmultiple references to the
WikiLealts upload webpage. including a webpage containing
a link to upload documents to WikiLeaks. and also references indicating a possible upload of the
Farah records (see discussion of Additional Charge 11. Speci?cation 10. below) to the WikiLeaks
website.35 Moreover. PFC Manning?s chats with a person using the
user name. aliased as Nathaniel Frank from 22 February 2010 to
25 March 2010, and as Julian Assange (editor of WikiLeaks) from 17 May 2010 to 24 May 2010
discussed uploading material to WikiLeaks.3? These facts. taken together. provide circumstantial
evidence that PFC Manning uploaded the memoranda to WikiLeal-zs.

WikiLeaks was not entitled to receive these memoranda. which relate to the national defense.
Also. the evidence shows that PFC. Manning had reason to believe that the video could be used to
the injury of the United States in that PFC Manning knew the enemy accessed information
available on the Internet. Additionally. 18 U.S.C. 793 exists. Finally. PFC Manning?s conduct
in providing this video to WikiLeaks is prejudicial to good order and discipline and service
disorcditing.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation 3 of Additional Charge 11.



32 Classi?ed testimony of SA Shaver. 10 Ex. (C) 5 (including relevant dates).

3" 10th Mountain Shares Forensic report. Bates at 2 I -22: PFC Manning?s Personal Computer
Forensic Report. Bates it? 0012-4283-3623. at 49.

34 PFC Manning's Primary SIPRNET Computer Forensic Report. Bates 002] l037?l 10. at 50. 72.

35 PFC Manning's Personal Computer Forensic Report. Bates it 00l24283?362. at 65-67. 17-73.

3'5 PFC Manning?s Personal Computer Forensic Report. Bates 00l24283-362. at 20-32. 76.

ll

Continuation Sheet, DD form 457. US. v. PFC Bradley E. Manning

Additional Charge ll. Specification 4 (Art. 134. 18 U.S.C. 641):
Law
In order to prove this offense. the government must establish the following five elements:

(1) that at or near Contingency Operating Station Hammer. Iraq. between on or about 31
December 2009 and on or about 5 January 2010. the accused voluntarily. intentionally and
knowingly stole. purloined. or converted a thing ofvalue. to wit: the Combined Information Data
Network Iraq database containing more than 380.000 recordsanother:

that the thing ofvalue belonged to the United States and had a value in excess ol?One
Thousand Dollars

(3) that the accu5ed did so with intent to deprive the owner of the use or bene?t ofthe thing of
value so tat-ten:

(4) that 18 USC. section 641 exists; and

(5) that. under the circumstances. the conduct of the accused was to the prejudice of good order
and discipline in the armed forces and was of a nature to bring discredit upon the armed forces.

The word ?value?? means the face. par. or market value. or cost price. either wholesale or retail.
whichever is greater.

A "thing ofvalue" can be tangible or intangible property.

It is not necessary to prove that the accused knew that the Government owned the property at the
time of the wrengful taking so long as it is established that the Government did in fact own the
money or property involved. that it had a value in excess of One Thousand Dollars and
that the accused knowingly and willfully stole. purloined. or converted it.?

Facts

The evidence showed that an SD Card recovered from the residence of PFC Manning's aunt
contained an archive file named When
using the password mentioned above. this ?le contained the complete
CIDNE databases for Afghanistan (91.91 1 reports) and Iraq (391.883 reports). It also contained
a ?le describing the contents and stating. "It?s already been sanitized of any source
identifying information. You might need to sit on this information. perhaps 90?180 days. to
?gure out how best to release such a large amount ofdata. and to protect source. This is possibly
one of the more signi?cant documents of our time. removing the fog of war. and revealing the
true nature of215t century asymmetric warfare. Have a good day."3



37 These elements are a tailored version ofEighlh Circuit Model Jury Instruction 6.18.641.
"m PFC Manning?s SD lCart! Forensic Report. Bates it 001253 l9-3 l. at 1-2. 9.



Continuation Sheet, no FTi'rm 457.113. v. PFC Bradley E. Manning

The evidence showed that PFC Manning was at his aunt's residence on or about 26 January
The evidence also showed that WikiLeaks released 391.840 reports from the IDNE-
Iraq database.?m The evidence also showed that in Unallocated Clusters on PFC Manning?s
personal computer. there was information ?liker obtained? from the database and
that documents containing the same text and associated photographs were found in PFC
Manning?s SIPRNET shared folder; the forensic examiner concluded is likely the photos
and documents in PFC SIPRNET shared folder were copied to [his] personal
computer through the use of removable

While there was no digital forensic evidence from PFC Manning's persOnal cemputer directly
indicating that the database was uploaded to WikiLeaks. the forensic examination
did find evidence in Unallocated Clusters of multiple references to the WikiLeaks upload
webpag?e. including a webpage containing a link to upload
documents to WikiLeaks. and also references indicating a possible upload of the Farah records
(see discussion of Additional Charge II. Speci?cation 10. below) to the WikiLeaks website.?
Moreover. PFC Manning?s chats with a person using the user
name. aliased as Nathaniel Frank from 22 February 2010 to 25 March 2010. and as Julian
Assange {editor of WikiLeaks) from 17 May 2010 to 24 Ma}.r 2010 discussed uploading material
to WikiLeaks.4" These facts. taken together. provide circumstantial evidence that PFC Manning
uploaded the database to WikiL-eaks.

PFC Manning?s comments in the "read me? document quoted above indicate that he converted
the database another in that he wanted to make this information
public and thus deprive its owner. the United States. of its use or bene?t. While PFC Manning in
his duties as an intelligence analyst deployed to Iraq had reason to use the lDNE-Iraq database
every day}1 he had no authorization to take this database from its owner and thus his taking it
constituted stealing it.

While there was no direct evidence provided of the value of the database. there was
evidence provided that the valuation of the Net-Centric Diplomacy database was over $4
million.45 This circumstantial evidence supports a conclusion that the value of the
database was over $1.000.

The evidence showed that 13 U.S.C. 641 exists and that PFC Manning's conduct in stealing the
database and converting WikiLeaks was prejudicial to good order

and discipline and service discrediting.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation 4 of Additional Charge 11.



39 PFC Manning's so Card Forensic Report. Bates 0012531941. at 7.

4? CIDNE Files Forensic Report. Bates it 0005431117. at 5; Testimony of SA Bettencourt (CIDN E-lraq database
released in October 20101.

4' PFC Manning?s Personal Computer Forensic Report. Bates it 00124283662. at 62-63.

41 PFC Manning?s Personal Computer Forensic Report. Bates it 0012-4233-3362. at 65-67- 77-78.

?3 PFC Manning?s Personal Computer Forensic Report. Bates it 00124283362. at 20-33. 1'6.

4" Testimony Lim.

?5 NCD valuation Documents. Bates ou4tosso-oo.

11

Continuation Sheet, DD lit-frm 457., v. PFC Bradley E. Mannii'ig

Additional Charge II, Speci?cation 5 (Art. 134, 18 U.S.C. 793(e)):
Law
In order to prove this offense. the government must establish the following ?ve elements:

that at or near Contingency Operating Station Hammer. Iraq. between on or about 31
December 2009 and on or about 9 February 2010. the accused had unauthorized possession of
information relating to the national defense. to wit: more than twenty classi?ed records from the
Combined Information Data Network Exchange Iraq database;

(2) that the accused had reason to believe that the information he possessed could be used to the
injury of the United States or to the advantage of any foreign nation;

that the accused willfully communicated. delivered. or transmitted the said information to a
person not entitled to receive it:

that 13 U.S.C. section 793(e'1exists; and

that, under the circumstances. the conduct ofthe accused was to the prejudice of good order
and discipline in the armed forces and was ofa nature to bring discredit upon the armed forces.

Farm

The evidence showed that an SD Card recovered from the residence of PFC Manning?s aunt
contained an archive file named When
using the password mentioned above. this ?le contained the complete
CIDNE databases for Afghanistan (91.91 1 reports) and Iraq (391.883 reports). It also contained
a tile describing the contents and stating, ?It?s already been sanitized of any source
identifying information. You might need to sit on this information. perhaps 90-180 days. to
figure out how best to release such a large amount of data. and to protect source. This is possibly
one of the more signi?cant documents of our time. removing the fog of war. and revealing the
true nature of 21st century asymmetric warfare. Have a good day."46

The evidence showed that PFC Manning was at his aunt?s residence on or about 26 January
2010.? The evidence also showed that WikiLeaks released 391.340 reports from the CIDNE-
Iraq database.? The evidence also showed that in Unallocated Clusters on PFC Manning's
personal computer. there was information ?liker obtained" from the database and
that documents containing the same text and associated photographs were found in PF
Manning?s SIPRNET shared folder: the forensic examiner concluded is likely the photos



*5 PFC Manning?s so Card Forensic Report. Bates a 0012531931, at I-2. 9.

4? PFC Manning?s SD Card Forensic Report. Bates ti {1013531961, at

?13 CIDNE Files Forensic Report. Bates 0005431241 at 5; Testimony ofSA Bettencourt database
released in October 2010').

14

Continuation Sheet, DD Foi'm 457.. US. v. PFC Bradley E. Manning

and documents in PFC MANNINGS SIPRNET shared folder were copied to {his} personal
Computer through the use of removable media??

While there was no digital forensic evidence from PFC Manning?s personal computer directly
indicating that the database was Uploaded to WikiLeaks. the forensic examination
did ?nd evidence in Unallocated Clusters of multiple references to the WikiLeaks upload
webpage. including a webpage containing a link to upload
documents to WikiLeaks. and also references indicating a possible upload of the Farah records
(see discussion of Additional Charge Speci?cation 10. below) to the WikiLeaks website.30
Moreover, PFC Manning?s chats with a person using the pressassociation@jabber.ecc.de user
name. aliased as Nathaniel Frank from 22 February 2010 to 25 March 2010, and as Julian
Assange (editor of WikiLeaks) from 17 May 2010 to 24 May 2010 discussed uploading material
to ?.lv'ikiLeaks.SI These facts. taken together. provide circumstantial evidence that PFC Manning
uploaded the IDNE?lraq database to WikiLeal-ts.

PFC. Manning?s comments in the ?read me" document quoted above indicate that he knew the
database would be released and that the information contained in the reports. by ?removing the
fog of war" concerning actions in which US. military forces were involved. could be used to the
injury of the United States. His statement in that document that the recipient needed to "sit on
the information to protect source? indicates that he knew WikiLeaks was not entitled to
receive this information.

The evidence showed that there were more than twenty of these and that they were
properly classi?ed and remain classified.S3

The evidence showed that 18 U.S.C.. 793(e) exists and that PFC Manning's conduct in providing
the database to WikiLeaks was prejudicial to good order and discipline and service discrediting.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Specification 5 of Additional Charge ll.

Additional Charge ll, Speci?cation 6 (Art. 134, 18 U.S.C. 641):
Law

in order to prove this offense. the government must establish the following ?ve elements:



"9 PFC Manning?s Personal Computer Forensic Report. Bates it 00124233362. at 62-63.

5? PFC Manning?s Personal Computer Forensic Report. Bates it 00124283662. at 65-67. 71-78.
5] PFC Manningis Personal Computer Forensic Report. Bates 00124233662. at 20-32. 76.

53 Bates is 00377912473021

53 Classi?cation Review. Bates is 00376879302.



Continuation Sheet, DD [form 457, U.S. v. PFC Bradley E. Manning

(1) that at or near Contingency Operating Station Hammer. Iraq. between on or about 31
December 2009 and on or about 8 January 2010. the accused voluntarily. intentionally and
knowingly stole, purloined. or converted a thing of value. to wit: the Combined Information Data
Network Afghanistan database containing more than 90.000 recordsanother:

(2) that the thing of value belonged to the United States and had a value in excess of One
Thousand Dollars

3) that the accused did so with intent to deprive the owner of the use or benefit of the thing of
value so taken:

that 18 U.S.C. section 641 exists; and

that. under the circumstances. the conduct of the accused was to the prejudice of good order
and discipline in the armed forces and was ofa nature to bring discredit upon the armed forces.

Facts

The evidence showed that an SD Card recovered from the residence of PFC Manning?s aunt
contained an archive ?le named 00KM380lyada.tar.bz2.nc." When
using the password mentioned above. this ?le contained the complete
IDNE databases for Afghanistan (91.911 reports) and Iraq (391.383 reports). It also contained
a ?le describing the contents and stating. ?It?s already been sanitized of any source
identifying information. You might need to sit on this information. perhaps 90-180 days, to
?gure out how best to release such a large amount of data, and to protect source. This is possibly
one of the more signi?cant documents of our time. removing the fog of war. and revealing the
true nature of 21 st century asynu'netric warfare. Have a good day.?5

The evidence showed that PFC Manning was at his aunt's residence on or about 26 January
2010.::5 The evidence also showed that WikiLeaks released 74.278 reports from the CIDNE-
Afghanistan database.5h

The evidence showed that between 1 January 2010 and 7 January 2010. there were 372
connections from the server containing the CIDNE-At?ghanistan database and PFC Manning?s
secondary SIPRNET computer. resulting in the transfer of 256.76 MB of data to PFC Manning?s
secondary SIPRNET computer.?Tr The evidence showed that the ?last modi?ed? date for the
ClDNE-Afghanistan ?le contained in the yata.tar.bz2.nc lile mentioned above was 8 January



5* PFC Manning?s so Card Forensic Report. Bates [1012531931. at 1-2. 9.

5i PFC Manning?s SD Card Forensic Report. Bates 00125319-31. at 7.

5" CIDNE Files Forensic Report. Bates 000543 I 2-12. at 5; Testimony ofSA Bettencourt (CIDNE-Afghanistan
database released in July 2010).

5? Centaur Logs Forensic Report. Bates it 0004656176. at 1.

16

Continuation Sheet, DD Form 457, US. v. PFC Bradley E.

2010.58 The entirety of the ClDNE-Afghanistan database so downloaded was located during the
forensic examination of PFC Manning?s SD cards?

While there was no digital forensic evidence from PFC Manning?s personal computer directly
indicating that the ClDNE-Afghanistan database was uploaded to Wild Leaks. the forensic
examination did ?nd evidence in Unallocated Clusters of multiple references to the WikiLeaks
upload webpage, including a webpage containing a link to
upload documents to Wild Leaks. and also references indicating a possible upload of the Farah
records (see discussion of Additional Charge Speci?cation 10. below) to the WikiLeaks
website.? Moreover, PFC Manning?s chats with a person using the
user name. aliased as Nathaniel Frank from 22 February 2010 to
25 March 2010, and as Julian Assange (editor of WikiLeaks) from 17 May 2010 to 24 May 2010
discussed uploading material to WikiLeaks.? These facts, taken together, provide circumstantial
evidence that PFC Manning uploaded the lDNE-Afghanistan database to WikiLeaks.

PFC Manning?s comments in the ?read me" document quoted above indicate that he converted
the database another in that he wanted to make this information
public and thus deprive its owner, the United States, of its use or bene?t. While PFC Manning in
his duties as an intelligence analyst deployed to Iraq had reason to use the database
every day. he had no need to access the CIDNE-Afghanistan databasel'2 and he had no
authorization to take this database from its owner and thus his taking it constituted stealing it.

While there was no direct evidence provided of the value of the CIDNE-Afghanistan database.
there was evidence provided that the valuation of the Net-Centric Diplomacy database was over
$4 million.? This circumstantial evidence supports a conclusion that the value of the
Iraq database. was over 351.000.

The evidence showed that 18 U.S.C . 641 exists and that PFC Manning's conduct in stealing the
database and converting WikiLeaks was prejudicial to good order

and discipline and service discrediting.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Specification 6 of Additional Charge II.

Additional Charge ll, Speci?cation 7 (Art. 134, 18 U.S.C. 793(e)):

Lun-



5? PFC Manning's so Card Forensic Report, Bates 001253 use I, at 940.

59 Centaur Logs Forensic Report. Bates it at 7.

6? PFC Manning?s Personal Computer Forensic Report. Bates 00124233662, at 65-67. 77-78.
PFC Manning?s Personal Computer Forensic Report. Bates 00124233662, at 20-32. 76.

?51 Testimony Lim.

5" NCD Valuation Documents. Bates 00410556-?0.

l7

Continuation Sheet, DD ?irm 457, U.S. v. PFC Bradley E. Manning

In order to prove this offense. the government must establish the following ?ve elements:

(1) that at or near Contingency Operating Station Hammer, Iraq, between on or about 31
December 2009 and on or about 9 February 2010. the accused had unauthorized possession of
informatiOn relating to the national defense. to wit: more than twenty classi?ed records from the
Combined Information Data Network Exchange Afghanistan database;

that the accused had reason to believe that the information he possessed could be used to the
injury of the United States Or to the advantage of any foreign nation:

that the accused willfully communicated. delivered. or transmitted the said information to a
person not entitled to receive it:

that 18 U.S.C. section T93te) exists; and

(5) that. under the circumstances. the conduct of the accused was to the prejudice of good order
and discipline in the armed forces and was ofa nature to bring discredit upon the armed forces.

Fa

The evidence showed that an SD Card recovered from the residence of PFC Manning?s aunt
contained an archive file named When
using the password mentioned above. this ?le contained the complete
CIDNE databases for Afghanistan (91.91 1 reports) and Iraq (391.883 reports). It also contained
a file describing the contents and stating. ?It?s already been sanitized of any source
identifying information. You might need to sit on this information. perhaps 90-180 days. to
?gure out how best to release such a large amount of data. and to protect source. This is possibly
one of the more signi?cant documents of our time. removing the fog of war, and revealing the
true nature of let century asymmetric warfare. Have a good days?!5

The evidence showed that PFC Manning was at his aunt's residence on or about 26 January 10.65
The evidince also showed that WikiLeaks released 74.778 reports from the ClDNE-Afghanistan
database.

The evidence showed that between 1 January 2010 and 7 January 2010. there were 372
connections from the server containing the ClDNE-Afghanistan database and PFC Manning's
secondary SIPRNET computer. resulting in the transfer of256.76 MB of data to PFC Manning's
secondary SIPRNET computer)? The evidence showed that the ?last modi?ed" date for the
ClDNE-Afghanistan ?le contained in the yata.tar.b22.nc ?le mentioned above was 8 January



PFC Manning?s so Card Forensic Report, Bates at 0012531941. at 1-2, 9.

6} PFC Manning?s SD Card Forensic Report, Bates 0012531961. at

CIDNE Files Forensic Report. Bates 0005431241?. at 5; Testimony ot'SA Bettencourt (ClDNE-Afghanistan
database reteased in July 2010'}.

5?7 Centaur Logs Forensic Report. Bates a 0004656746. at

18

Continuation Sheet, DD Form 457, US. v. PFC Bradley E. Mannihg

2010.?8 The entirety of the lDNE-Afghanistan database so downloaded was located during the
forensic examination of PFC Manning?s SD card)?

While there was no digital forensic evidence from PFC Manning?s personal computer
indicating that the CIDN E-Afghanistan database was uploaded to WikiLeaks. the forensic
examination did ?nd evidence in Unallocated Clusters of multiple references to the WiltiLealts
upload webpage. including a webpage containing a link to
upload documents to WikiLeaks. and also references indicating a possible upload of the Farah
records (see discussion of Additional Charge 11. Speci?cation 10. below} to the WikiLeaks
websitem Moreover. PFC Marming?s chats with a person using the
user name. aliased as Nathaniel Frank from 22 February 2010 to
25 March 2010. and as Julian Assange (editor of WikiLeaks) from 17 May 2010 to 24 May 2010
discussed uploading material to WileE?kS.? These facts, taken together, provide circumstantial
evidence that PFC Manning uploaded the ClDNE-Afghanistan database to WikiLeaks.

PFC Manning?s comments in the ?read me" document quoted above indicate that he knew the
database would be released and that the information contained in the reports. by "removing the
fog of war" concerning actions in which US. military forces were involved. could be used to the
injury of the United States. His statement in that document that the recipient needed to ?sit on
the information to protect source" indicates that he knew WikiLeaks was not entitled to
receive this information. While PFC Manning in his duties as an intelligence analyst deployed to
Iraq had reason to use the lDNE-lraq database every day. he had no need to access the CIDNE-
Afghanistan database. 72

The evidence showed that there were more than twenty of these documents?3 and that the}r were
properly classified and remain classified.H

The evidence showed that 18 U.S.C. 793(e) exists and that PFC Manning?s conduct in providing
the database to WikiLeaks was prejudicial to good order and discipline and service discrediting.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation 7 of Additional Charge 11.

Additional Charge ll. Speci?cation 8 (Art. 134. 18 U.S.C. 641):

Low



5?3 PFC Manning?s so Card Forensic Report. Bates :7 001253 19-3 1. at 9.10.

6" Centaur Logs Forensic Report. Bates it 00046567-1?6. at 7.

7" PFC Manning?s Personal Computer Forensic Report. Bates 00124233662. at 65-61
PFC Manning?s Personal Computer Forensic Report. Bates it 0012-4233-3631. at 20-32. 76.
Testimony Lim.

1' Bates 71 0037784667791 1.

7* Classi?cation Review. Bates 7: 00376879302.

Continuation Sheet, DD Farm 457, v. PFC Bradley E. Mandi?rig

In order to prove this offense. the government must establish the following ?ve elements:

i that at or near Contingency Operating Station Hammer, Iraq, on or about 8 March 2010, the
accused voluntarily. intentionally and knowingly stole, purloined. or converted a thing of value.
to wit: a United States Southern Command database containing more than 700 records belonging
to the United States government another;

that the thing of value belonged to the United States and had a value in excess of One
Thousand Dollars

that the accused did so with intent to deprive the owner of the use or bene?t of the thing of
value so taken;

that 18 U.S.C. section 641 exists: and

(5) that. under the circumstances, the conduct of the accused was to the prejudice of good order
and discipline in the armed forces and was of a nature to bring discredit upon the armed forces.

acts

The evidence showed that a user of PFC Manning?s primary and secondary SIPRN ET computers
searched for retention of interrogation videos. initially On 23 November 2009, and during the
month of March 2010 conducted over 700 searches using wget commands (which are used to
download ?les from a web server} pertaining to Guantanamo Bay detainees. The forensic
examiner downloaded the same documents using the same program, and veri?ed that those
documents were the same documents on the WikiLeaks website by comparing them.? The
forensic examiner also found four complete JTF Guantanamo Bay detainee assessments on PFC
Manning?s primary computer under PFC Manning?s user profile;6 Moreover, in his
chats with Mr. Lamo, PFC Manning admitted providing these documents to WikiLeaks in the
following statements: ?oh, the TF GTMO Assange has those too;" and. a?er Lamo
said he read those papers and asked if Assange had "[a]nything else interesting on his table",
PFC. Manning said. ?idk don?t know] i only know what I provide hint."1r

The evidence showed there was no work related reason For PFC Manning to search for
Guantanamo er Guantanamo detainee assessments.78

The evidence showed that the terms or keywords ?Guantanamo? or were searched for
from PFC Manning's primary and secondary SIPRNET computers a total of I 7 times?3 The



Ti Testimony ofSA Shaver.

Testimony of SA Shaver.

7" Lamo Chat. [0 Ex. 19in). at 44.

7? Testimony Fulton: Testimony Lim.

lntelink Log Files Forensic Report. Bates 003 751 115-129. at 9.

20

Continuation Sheet, DD Form 457, U.S. v. PFC Bradley E. Manning

evidence also showed that the wget command was used 793 times to download documents
pertaining to Guantanamo detainees from PFC Manning's primary SIPRNET computer.1m

The evidence showed that on 8 March 2010. in an online chat with

e, aliased to Nathaniel Frank at the time but later aliased to Julian
Assange (editor PFC Manning made statements including: ?anyway im
throwing everything I got on GTMO at you should take a while to get up the
Stunmaryfhistoryfhealth conditionsfreasons for retaining or transfer of nearly every detainee I
have a that organizes the info as much as possible."32

Additionally, the forensic examination of PFC Manning?s personal computer found evidence in
Unallocated Clusters of multiple references to the WikiL-eaks upload webpage.
including a webpage containing a link to upload documents to
WikiLeaks. and also references indicating a possible upload of the Farah records (see discussion
of Additional Charge ll. Speci?cation 10. below] to the WikiLeaks websites?; These facts, taken
together. support the conclusion that PFC Manning uploaded the Southern Command database to
WikiLeaks.

The evidence showed that between 24 April 2011 and 21 June 2011 WikiLeaks released 765
detainee assessment briefs. documents pertaining to detainees at Guantanamo Bay. Cuba.34

PFC Manning?s comments in his chats with Mr. Lamo about why he released documents to
WikiLeaks indicate that that he converted this database another in
that he wanted to make this information public and thus deprive its owner. the United States. of
its use or benelfitf'l?S PFC Manning had no need to access Guantanamo detainee assessments for
hisjob??' and he had no authorization to take this database from its owner and thus his taking it
constituted stealing it.

While there was no direct evidence provided of the value of the Southern Command database.
there was evidence provided that the valuation of the Net?Centric Diplomacy database was over
$4 millions? There was also evidence provided that the value of the information WikiLeaks
possessed was 12 million pounds. or between $15-20 million.? This circumstantial evidence
supports a conclusion that the value of the Southern Command database was over $1.000.



3" lntelink Log Files Forensic Report. Bates 003751 I6- I 29, at 12.

31 The evidence showed that a person using the ?de user name was aliased as Nathaniel
Frank from 22 February 2010 to 25 March 20 it). and as Julian Assange {editor ofWikiLeal-ts) from 17' May 20l0 to
24 May 2010. PFC Manning's Personal Computer Forensic Report. Bates ti 00I24283-362. at 20-32. 76.

3: PFC Manning?s Personal Computer Forensic Report. Bates 0012-4233-3622. at 23.

33 PFC Manning?s Personal Computer Forensic Report. Bates 00124233-362. at 65-67,

$4 Testimony ofSA Bettencourt.

35 For example. PFC Manning stated. in reference to the State Department Cables. that ?it was forwarded to WL
and god knows what happens now hopefully worldwide discussion. debates. and reforms I want people to see
the regardless of who they are. .. because without information. you cannot make informed decisions as a
public." 10 Ex. at 33.

'3 Testimony Lirn.

*7 NCD Valuation Documents, Bates a 00410556-60.

3" Testimony ot?SA Bettencourt.

Continuation Sheet, no 457. vs. v. PFC Bradley E.

The evidence showed that 18 U.S.C. 641 exists and that PFC Manning's conduct in stealing the
database and converting WikiLeaks was prejudicial to good order
and discipline and service discrediting.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation 8 ofAdditional Charge ll.

Additional Charge II, Speci?cation 9 (Art. 134, 18 U.S.C. 79302)}:
Lot-v
In order to prove this offense. the government must establish the following five elements:

(1) that at or near Contingency Operating Station Hammer. Iraq. between on or about 3 March
2010 and on or about 27 May 2010. the accused had unauthorized possession of information
relating to the national defense, to wit: more than three classi?ed records from a United States
Southern Command database:

(2) that the accused had reason to believe that the information he possessed could be used to the
injury ofthe United States or to the advantage of any foreign nation:

(3) that the accused willfully communicated. delivered. or transmitted the said information to a
person not entitled to receive it:

(4) that 18 U.S.C. section 793(c} exists; and

(5) that. under the circumstances. the conduct of the accused was to the prejudice of good order
and discipline in the armed forces and was of a nature to bring discredit upon the armed forces.

Facts

The evidence showed that a user of PFC Manning?s primary and secondary SIPRNET computers
searched for retention of interrogation videos. and during the month of November conducted
over 700 searches using wget commands (which are used to download ?les from a web server)
pertaining to Guantanamo Bay detainee suspects. The forensic examiner downloaded the same
documents using the same program. and verified that those documents were the same documents
on the WikiLeaks website by comparing them.89 The forensic examiner also found four
complete .ITF Guantanamo Bay detainee assessments on PFC Manning?s primary SIPRNET
computer under PFC Manning?s user pro?le??' Moreover. in his chats with Mr. Lamo. PFC
Manning admitted providing these documents to WikiLeaks in the following statements: ?oh. the
JTF GTMO Assange has those 100;? and. after Lamo said he read those papers and
asked if Assange had ?[a]nything else interesting on his table". PFC Manning said. "idk don?t
know] 1 only know what I provide himfm



3" Testimony ofSA Shaver.
"0 Testimony of SA Shaver.
Lamo Chat. IO Ex. 19(0). at 44.




Continuation Sheet, DD 457. U.S. v. PFC Bradley E. Manning

The evidence showed there was no work related reason for PFC Manning to search for
. 7
Guantanamo or Guantanamo detalnee assessments.}'

The evidence showed that the terms or keywords ?Guantanamo? or were searched for
from PFC Manning?s primary and secondary SIPRNET computers a total of 17 timest3 The
evidence also showed that the wget command was used 793 times to download documents
pertaining to Guantanamo detainees from PFC Manning's primary SIPRNET computer.g4

The evidence showed that on 3 March 2010. in an online chat with
aliased to Nathaniel Frank at the time but later aliased to Julian
Assange [editor of WiltiLealts).q5 PFC Manning made statements including: ?anyway. im
throwing everything I got on JTF GTMO at you should take a while to get up tho
summarvihistory/health conditionsfreasons for retaining or transfer of nearly every detainee
have a that organizes the info as much as

Additionally. the forensic examination Manning's personal computer Found evidence in
Unallocated Clusters of multiple references to the WikiLeaks upload webpage.
including a webpage containing a link to upload documents to
WikiLeaks. and also references indicating a possible upload of the Farah records (see discussion
of Additional Charge 11. Speci?cation ll]. below) to the WikiLeaks website.m These facts. taken
together. support the conclusion that PFC Manning uploaded the Southern Command database to
WikiLeaks.

The evidence showed that between 24 April 20] and 21 June 201 WikiLeaks released 7'65
detainee assessment briefs. documents pertaining to detainees at Guantanamo Bay. Cubaqs

PFC Manning?s comments in his chats with the person using the pressassociation screen name.
later aliased as Julian Assange. indicate that he had reason to believe the infermation he provided
concerning JTF GTMO detention memos could be used to the inj ury of the United States. In
those chats. PFC Manning asked: "how valuable are JTF GT M0 detention memos containing
summaries. background info. capture info. etc." and received the response. "quite valuable to the
lawyers of these guys who are trying to get them out. where those memos suggest their
innocencet?bad proceedure."qq PFC Manning had no need to access Guantanamo detainee
assessments for hisjobdn? and he had no authorization to provide these records to WikiLeaks.
who was not authorized to receive it.



92 Testimony Fulton; testimony Lim.

"3 lntelink Log Files Forensic Report. Bates 003751 Iii-129. at s.
"4 lntelink Log Files Forensic Report. Bates tr' 0
95 The evidence showed that a person using the user name was aliased as Nathaniel
Frank from 22 February 20:0 to 25 March 2010. and as Julian Assange {editor ot?WikiLeaks) from May 2010 to
24 May 20l0. PFC Manning?s Personal Computer Forensic Report. Bates ti 00124283?362. at 20-32. To.

9? PFC Manning's Personal Computer Forensic Report. Bates 00124283662. at 23.

9'1 PFC Manning's Personal Computer Forensic Report. Bates a 00l24283-362. at 65-67, 77-78.

95 Testimony of SA Betteneourt.

PFC Manning?s Personal Computer Forensic Report. Bates it 00l24283-362. at 22-

Testimony Lint.





23

Continuation Sheet, DD Flo-rm 457, U.S. v. PFC Bradley E. Martan

The evidence showed that there were more than three of these records'm and that they were
properly classi?ed and remain classifiedw"

The evidence showed that 18 793(e'} exists and that PFC Manning's conduct in providing
these records to WikiLeaks was prejudicial to good order and discipline and service discrediting.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Specification 9 of Additional Charge ll.

Additional Charge II, Speci?cation 10 (Art. 134, UCMJ: 18 U.S.C. 793(6):
Law
In order to prove this offense. the government must establish the following ?ve elements:

(1) that at or near Contingency Operating Station Hammer. Iraq. between on or about 1 April
2010 and on or about 27 May 2010. the accused had unauthorized possession of information
relating to the national defense. to wit: more than five classi?ed records relating to a military
operation in Farah Province. Afghanistan occurring on or about 4 May 2009;

(2) that the accused had reason to believe that the information he possessed could be used to the
injury of the United States or to the advantage of any foreign nation;

(3) that the accused willfully communicated. delivered, or transmitted the said information to a
person not entitled to receive it:

that 13 U.S.C. section 793(e) exists: and

(5) that. under the circumstances. the conduct of the accused was to the prejudice of good order
and discipline in the armed forces and was of a nature to bring discredit upon the armed forces

acts

The evidence showed that a user of PFC Manning's user account on his primary SIPRN ET
computer downloaded 135 ?les from a centcom.smil.mil server on 10 April 2010: shortly
thereafter. after these files were viewed. the farah.zip ?le was viewed on 10 April 2010 on PFC
Manning?s primary SIPRNET computer.?3

The evidence showed that a CD created on I 1 April 2010 at 9: 18 am containing a ?le named
"farahzip" was accessed on PFC Manning?s personal computer.m



Bates 00373123440.

Classi?cation Review. Bates 0037864649.

PFC Manning?s Primary SIPRNET Computer Forensic Report. Bales 003' 10374 ?1 at 53'53?
PFC Manning?s Personal Computer Forensic Report. Bates 00124283662. at 49.

24

Continuation Sheet. no [Fa-m 457, vs. v. PFC Bradley s. Mannirt'g

The evidence from Unallocated Clusters on PFC Manning?s personal computer indicated that
seven ?les with names like "farahpartl .rar" had existed in a ?farah? folder on the desktop ofthat
computer. The evidence also showed that at least four of these files had been uploaded to
WikiLeaks after having been using the program. as they had the .nc ?le
extension added an indicator of the use of that program??
Additionally. the examination of Unallocated Clusters on PFC Manning?s personal computer
revealed that classi?ed documents relating to the operation in Farah Province, Afghanistan, on or
about 4 May 2009 that were found on the centcomsmilmil server and also on PFC Manning's
primary SIPRNET computer existed on his personal computer.

The evidence showed that in a chat with Mr. Lamo. PFC Manning stated. in reSponse to Lanio?s
question ?what do you consider the highlights" immediately following PFC Manning?s statement
that he only knew what he provided to Mr. Assange. ?The Gharani airstrike videos and full
report. lraq war event log. the ?Gitmo Papers.? and State Department cable database.?lm In the
context ot?his discussion earlier in those chats concerning the State Department cables where he
said. ?it was forwarded to WL and god knows what happens now hopefully worldwide
discussion. debates. and reforms?? PFC Manning had reason to believe that the information in
these documents could be used to the injury of the United States. PFC Manning had no need to
access information concerning Afghanistan for his job.mg and he had no authorization to provide
these documents to WikiLeaks. which was not authorized to receive it.

ll?

The evidence showed that there were more than ?ve of these records and that they were

properly classi?ed and remain classified.

The evidence showed that 18 U.S.C. 793(e} exists and that PFC Manning's conduct in providing
these records to WikiLeaks was prejudicial to good order and discipline and service discrediting.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation 10 ot?Additional Charge

Additional Charge Speci?cation 1] (Art. 134, 18 U.S.C. 793(el):
Law
In order to prove this offense. the government must establish the following ?ve elements:

that at or near Contingency Operating Station Hammer. Iraq. between on or about 1
November 2009 and on or about 8 January 2010. the accused had unauthorized possession of



PFC Meanings Personal Computer Forensic Report. Bates at 00124233452. at 65-68.

1% PFC Manning's Personal Computer Forensic Report. Bates UDI24283-362. at 54-58.

Lamo Chat. to Exhibit at 44-45.

Lento Chat. IO Es. 19(0). at 33.

"m Testimony Lirn {stating PFC Manning had no need to access the CIDN E~Afghanistan database for his
job).

?0 Bates at 00371425493.

Classi?cation Review. Bates at 00376379302.

Continuation Sheet, DD Form 457. U.S. v. PFC Bradley E. Manning

information relating to the national defense- to wit: a file named PAX.zip" containing a
video named PAmev":

that the acoused had reason to believe that the information he possessed could be used to the
injury of the United States or to the advantage of any foreign nation:

3) that the accused willfully communicated. delivered. or transmitted the said information to a
person not entitled to receive it;

that 13 U.S.C. section 793(c) exists: and

that, under the circumstances, the conduct of the accused was to the prejudice of good order
and discipline in the armed forces and was ofa nature to bring discredit upon the armed forces

Facts

On 8 .lanuary 2010. WikiLeaks tweeted that they had a video ofthe Gharani airstrike video that
was and asked for supercomputer time {presumably to it).1 '2 In his chats
with Mr. Lame. PFC Manning acknowledged that Assange had this video in an
format: ?they also caught wind that he [Assange] had a of the Gharani airstrike in
Afghanistan. which he has. but hasn?t yet the production team was actually
working on the Baghdad strike though. which was never really enerypted he's got the whole
15-6 for that incident so it wont just be video with no contest but its not nearly as
it was an awful incident. but nothing like the baghdad one the investigating
of?cers left the material unprotected, sitting in a director on a centcomsmilmil server but
they did zip up the files, aes?256. with an excellent so afaik [as far as I know] it
hasn?t been broken yet."i '3

Additionally. as mentioned above. PFC Manning stated that the "highlights" of what he provided
to Mr. Assange included "the Gharani airstrike videos and full report.?I

The evidence also showed that a computer owned by a Mr. Jason Katz. a former employee of the
Department of Energy. contained a ?le named BE.zip_. and within that ?le was an
password?protected file named BE 22 'PAX.wmv. The password the ferensic examiners obtained
from ENTC OM to open the file by the same name on the centcom.smil.mil server also opened
the file on Mr. Kate?s computer. and the files appeared to be the same. The ?le was placed on
Mr. Katz?s computer on 15 December 2009 and Mr. Kata had installed a cracking
program and was trying to the liltilh

This evidence. particularly PFC Manning?s statements as to where the file was located and his
knowledge that the files had been zipped "with an excellent password." together with the
evidence indicating that PFC Manning had uploaded the farahzip ?les, circumstantially



"3 Testimony of SA Bettencourt; Bates
Lame Chat. [0 Ex. win), at tO-l 1.

Lamo Chat, 10 Exhibit

"5 Testimony of SA Shaver.

Continuation Sheet. no 457, us. v. PFC Bradley E. Manni?h?g

indicates that PFC Manning provided the BE 22 PAX.wmv file to WikiLeaks and that ?le was
the one that was placed on Mr. Katz?s computer.

The evidence showed that in the context of his chats with Mr. Lamo concerning the State
Department cables where he said. ?it was forwarded to WL and god knows what happens now
hopefully worldwide discussion. debatesa and reforms."] PFC Manning had reason to
believe that the information in this video could be used to the injury of the United States. PFC
Manning had no need to access information concerning Afghanian for hisjob.' and he had no
authorization to provide these doCuments to WikiLeaks. which was not authorized to receive it.

The evidence showed that this video was properly classi?ed and remains classified' '3

The evidence showed that 18 U.S.C. 793(e') exists and that PFC Manning's conduct in providing
these records to WikiLeaks was prejudicial to good order and discipline and service diserediting.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation ll of Additional Charge ll.

Additional Charge Specification 12 (Art. 134, 18 U.S.C. 641]:
Law
In order to prove this offense. the government must establish the following ?ve elements:

(1) that at or near Contingency Operating Station Hammer, Iraq, between on or about 28 March
2010 and on or about 4 May 2010? the accused voluntarily, intentionally and knowineg stole,
purloined. or converted a thing of value. to wit: the Department of State Net-Centric Diplomacy
database containing more than 250.000 records belonging to the United States government another:

(2) that the thing of value belonged to the United States and had a value in excess of One
Thousand Dollars

that the accused did so with intent to deprive the owner of the use or bene?t of the thing of
value so taken;

(4) that 18 U.S.C. section 641 exists; and

that, under the circumstances. the conduct of the accused was to the prejudice of good order
and discipline in the armed forces and was ot?a nature to bring discredit upon the armed forces.



Lamo Chat, 10 Ex. 19(0). a: 33.

1? Testimony of CPT Lim (stating PFC Manning had no need to access the ClDNE-Afghanistan database for his
job).

Classi?cation Review? Bates a

27

Continuation Sheet, no 457,115.? PFC Bradley E. Mattan

Facts

The evidence showed that PFC Manning?s primary SIPRN ET computer contained, under his
user pro?le. a ?le named ??leszip? in the ??bloop" folder that had over 10,000 Department of
State cables in .html web page format. and that over 4,000 of these cables were classified. 1 '9 A
CD accessed on PFC Manning?s personal computer containing ?leszip was burned on 4 May
10.12? The evidence showed that another document in the ?bloop'? folder. was a
spreadsheet with cables published in March, April. and May 2010.1"zl The tab in this spreadsheet
including cables published in March and April 2010 started with a cable with number 251,288.

The evidence showed that PFC Manning?s primary SIPRNET computer had a version of wget
(software used to download ?les from a server) that was the same version found in the
Department ot?State log ?les, the Intelink log ?les. and that was downloaded on a NIPRNET
computer by the bradleymanning user pro?le. '22 A user of PFC Manning?s user pro?le on that
NIPRNET computer did Google searches for WikiLeaks and wget.exe on 3 May 2010 and
downloaded wget to that pro?le. A user of PFC Manning?s user pro?le then transferred wget
from the NIPRNET to SIPRNET on 4 May 2010, under PFC Manning?s user profile.123

The evidence showed that on 20 August 201 WikiLeaks released 251,287 Department of State
cables in unredacted form and made them available on the lnternt?etd24 While the evidence was
that Wild Leaks did not release the cables in the'?leszip folder?? the fOrensic examination found
thousands of State Department cables in unallocated space on PFC Manning?s primary
computer, ranging in classi?cation from unclassified to secret; many were complete, but many
others were not.l?6 Additionally, the forensic examination of PFC Manning?s primary SIPRNET
computer revealed that a deleted and partially overwritten file named

ile?tbackupuarahzip" was originally created on 10 April 2010 and contained 582 Department of
State Cables. over 250 of which were classi?ed?? The evidence showed the Department of
State cables were in .csv format, a way of moving ?les from one database to another. and were
Base64 encoded'28 Analysis Manning's secondary SIPRNET computer and his personal
computer also showed many Department of State cables that had been converted to Base64 and
stored in .csv Speci?cally, approximately 1 13.000 complete Department ot?State
cables converted to Base64 were found in a deleted .csv ?le in Unallocated Clusters on PFC



?9 Testimony Shaver: PFC Manning?s Primary SIPRNET Computer Forensic Report. Bates ti! 00211037-1 10.
at 3 I.

Testimony Shaver.

PFC Manning?s Primary SIPRNET Computer Forensic Report, Bates 0021 1037?! 10, at 31; spreadsheet. at
Bates 00296932; Testimony of SA Shaver.

'33 PFC Manning?s Primary SIPRNET Computer Forensic Report. Bates 0021 103 10- at 37.

'33 Testimony of SA Shaver.

'24 Testimony of SA Bettencourt; Testimony ofSA Shaver.

'35 Testimony of SA Shaver. SA Shaver also testi?ed there was a problem with ?leszip when it was created, and if
a person using WinZip tried to open it. it would not open because it was a corrupted tile. and one would need special
tools to open the ?les in fileszip. Based on that testimony, it appears that WikiLeaks did not release the cables in
l'iles.aip because they could not open them.

12" Testimony of SA Shaver.

PFC Manning?s Primary SIPRNET Computer Forensic Report, Bates it 0021 10374 10. at 34-36-

?23 Testimony of SA Shaver.

'39 PFC Manning?s Primary SIPRNET Computer Forensic Report. Bates 0021 1037410. at 36.

28

Continuation Sheet, DD F-drm 457, US. v. PFC Bradley E. Mannidg

Manning?s secondary SIPRNET computeer and evidence of Department of State cables
published before March 2010 were found in Unallocated Clusters on PFC Manning's personal
computer. including data appearing to have a .csv ?le structure listing Department of State cables
with numbers preceding 251.28? in a format similar to the cables found on PFC Manning?s
primary SIPRNET Computer. Additionally. examination of Department of State cable
message record numbers released by WikiLeal-ts identi?ed 251,298 individual message record
numbers: examination of PFC Manning?s personal computer and his primary and secondary
SIPRNET computers showed that they contained 83% of all the message record numbers
released to WikiLeaks. '33

This evidence, taken together, leads to a conclusion that the 251,287 ?les released by WikiLeaks
were provided to WikiLeaks by PFC Manning.

The evidence showed that in his chats with Mr. Lamo concerning the State Department cables.
PFC Manning said, ?it was forwarded to WL and god knows what happens now hopefully
worldwide discussion. debates, and reforms I want people to see the regardless of who
they because without information. you cannot make informed decisions as a public.?33 which
indicates that that he converted this database another in that he
wanted to make this information public and thus deprive its owner. the United States, of its use
or bene?t. While there was evidence that PFC Manning had the authority to access diplomatic
cables for his job.I34 he had no authorization to take this database from its owner and thus his
taking it constituted stealing it.

The evidence showed that the valuation of the Net-Centric Diplomacy database was over $4
million.

The evidence showed that 18 U.S.C. 64] exists and that PFC Manning?s conduct in stealing the
database and converting WikiLeaks was prejudicial to good order

and discipline and was service discrediting.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Specification 12 of Additional Charge ll.

Additional Charge Speci?cation 13 (Art. 134, 18 U.S.C. 1030(a)(l)):
Lott]

In order to prove this offense. the govermnent must establish the following six elements:



n" PFC Manning's Secondary SIPRNET Computer Forensic Report. Bates it 00199494607. at l. 1244.
PFC Manning?s Personal Computer Forensic Report. Bates 00124233662. at 51-54.

Files Forensic Report. Bares 0005432064. at I4.

"13 Lamo Chat. [0 Ex. at 33.

Testimony Lim (stating he gave the link through email to access diplomatic cables).
?5 NCD Valuation Documents. Bates 004

29

Continuation Sheet. no ?rm 457. as. v. PFC Bradley E. Manning

that at or near Contingency Operating Station Hammer. Iraq. between on or about 28 March
2010 and on or about 2? May 2010. the accused knowingly exceeded authorized access on a
Secret Internet Protocol Router Network computer;

(2) that the accused obtained information that has been determined by the United States
government by Executive Order or statute to require protection against unauthorized disclosure
for reasons of national defense or foreign relations. to wit: more than seventy-five classi?ed
United States Department of State cables;

that the accused had reason to believe that the information he obtained could be used to the
injury of the United States or to the advantage of any foreign nation;

(4) that the accused willfully communicated delivered. or transmitted the said information to a
person not entitled to receive it:

(5) that IS U.S.C. section and

that. under the circumstances. the conduct of the accused was to the prejudice of good order
and discipline in the armed forces and was of a nature to bring disoredit upon the armed
forces.?

Facts

The evidence showed that PFC Manning?s primary SIPRN ET computer contained. under his
user pro?le. a ?le named ??leszip? in the "bloop? folder that had over 10.000 Departmentjof'
State cables in .html web page format. and that over 4.000 of these cables were classi?ed. A
CD accessed on PFC Manning?s personal computer containing ?leszip was burned on 4 May
10. '33 The evidence showed that another document in the ?bloop? folder. was a
spreadsheet with cables published in March. April. and May 2010"?) The tab in this spreadsheet
including cables published in March and April 2010 started with a cable with number 251.288.
The evidence showed that PFC Manning?s primary computer had a version of wget
(software used to download ?les from a server) that was the same version found in the
Department of State log ?les. the lntelink log ?les. and that was downloaded on a NIPRNET
computer by a user of PFC Manning?s user profile.?40 A user of PFC Manning's user pro?le on
that NIPRNET computer did Google searches for WikiLeaks and wgetexe on 3 May 10 and
downloaded wget to that pro?le. A user of PFC Manning?s user pro?le then transferred wget
from the NIPRNET to SIPRNET on 4 May 2010. under PFC Manning?s user pro?lem



13? These elements are a tailored version of Eighth Circuit Model Jury Instruction 6.18.1030A.

Testimony of SA Shaver: PFC Manning?s Primary SIPRNET Computer Forensic Report. Bates it 002! 1037-] 10.
at 31.

?3 Testimony ofSA Shaver.

"19 PFC Manning?s Primary SIPRNET Computer Forensic Report. Bates a 002] l037-1 at 3 spreadsheet. at
Bates 00296982: Testimony ofSA Shaver.

PFC Manning?s Primary SIPRNET Computer Forensic Report. Bates a? 0021 1037-l 10. at 37.

Testimony ofSA Shaver.

Continuation Sheet, DD Form 457. US. v. PFC Bradley E. Manning

The evidence showed that on 20 August 2011. WikiLeaks released 251.287 Department of State
cables in unredacted form and made them available on the Internet?: While the evidence was
that WikiLeaks did not release the cables in the tileszip folder.I43 the forensic examination found
thousands of State Department cables in unallocated space on PFC Manning?s primary SIPRNET
computer. ranging in classification from unclassified to secret; many were complete, but many
others were not.l '4 Additionally. the forensic examination Manning's primary SIPRNET
computer revealed that a deleted and partially overwritten ?le named "etiLost
Filelbackuplfarahzip" was originally created on 10 April 2010 and contained 582 Department of
State Cables. over 250 of which were classi?ed.MS The evidence showed the Department of
State cables were in .csv format. a way of moving ?les from one database to another. and were
Base64 encoded."m Analysis of PFC Manning's secondary SIPRNET computer and his personal
computer also showed many Department of State cables that had been converted to Base64 and
stored in .csv format?? Speci?cally. approximately 1 13.000 complete Department of State
cables converted to Base64 were found in a deleted .csv file in Unallocated Clusters on PFC
Manning's secondary SIPRNET computerfw? and evidence of Department of State cables
published before March 2010 were found in Unallocated Clusters on PFC Manning?s personal
computer. including data appearing to have a .csv file structure listing Department of State cables
with numbers preceding 251.287r in a format similar to the cables found on PFC Manning?s
primary SIPRN ET Computer?? Additionally. examination of Department of State cable
message record numbers released by WikiLeaks identi?ed 251.298 individual message record
numbers; examination of PFC Manning?s personal computer and his primary and secondary
SIPRNET computers showed that they contained 83% ofall the message record numbers
released to WikiLealts.

This evidence. taken together. leads to a conclusion that the 251.28? ?les released by WikiLeaks
were provided to WikiLeaks by PFC Manning.

The evidence showed that in his chats with Mr. Lamo concerning the State Department cables.
PFC Manning said, "it was forwarded to WL and god knows what happens now hopefully
worldwide discussion. debates. and reforms i want people to see the regardless of who
they because without information. you cannot make informed decisions as a publicfm
which indicates that that he had reason to believe that the information he obtained could be used
to the injury of the United States or to the advantage of any foreign nation.



'42 Testimony of SA Bettencourt: Testimony of SA Shaver.

"3 Testimony ot'SA Shaver. SA Shaver also testi?ed there was a problem with ?leszip when it was created. and if
a person using WinZip tried to open it. it would not open because it was a corrupted file. and one would need special
tools to open the ?les in tileszip. Based on that testimony. it appears that WikiLeaks did not release the cables in
files.zip because they could not open them.

'44 Testimony ofSA Shaver.

?5 PFC Manning?s Primary SIPRN ET Computer Forensic Report. Bates at 002 I 1037-1 l0. at 34?36.

?6 Testimony ot?SA Shaver.

?7 PFC Manning?s Primary SIPRN ET Computer Forensic Report. Bates 0021 1037-1 10. at 36.

PFC Manning?s Secondary SIPRNET Computer Forensic Report. Bates it 00199494-507. at 1. l2-l4.

"9 PFC Manning?s Personal Computer Forensic Report. Bates 0012-4283-3452. at 51-54.

Files Forensic Report. Bates if 0005432034. at 14.

Lamo Chat. [0 Es. 19(0). at 33.

Continuation Sheet. DD Form 457, U.S. v. PFC Bradley E. Mannihg

While there was evidence that PFC Manning had the authority to access diplomatic cables for his
job,I52 the context of that evidence was that access was authorized for the to do theirjob.
The evidence also showed that before logging on to his primary and secondary SIPRNET
computers. PFC Manning had to click on a warning banner. the first sentence of which
read. ?You are accessing a US. Government (USG) information System US) that is provided for
USS-authorized use only?"53 Accordingly. accessing diplomatic cables in order to provide them
to a person not entitled to receive it exceeded authorized access. PFC Manning had no
authorization to transfer this information to WikiLeal-ts. which was not entitled to receive it.

The evidence showed that these cables were properly classi?ed and remain classi?ed]S4

The evidence showed that 18 U.S.C. 1030( 1] exists and that PFC Manning?s conduct in
providing these classified cables to WikiLeaks was prejudicial to good order and discipline and
was service discrediting.

Additional Charge 11, Speci?cation 14 (Art. 134, 18 U.S.C.
Law
in order to prove this offense. the government must establish the following six elements:

that at or near Contingency Operating Station Hammer. Iraq. between on or about 15
February 2010 and on or about 18 February 2010. the accused knowingly exceeded authorized
access on a Secret lnternet Protocol Router Network computer;

(2) that the accused obtained information that has been determined by the United States
government by Executive Order or statute to require protection against unauthorized disclosure
for reasons of national defense or foreign relations. to wit: a classi?ed United States Department
of State cable titled ?Reykjavik-13";

(3) that the accused had reason to believe that the information he obtained could be used to the
injury of the United States or to the advantage of any foreign nation:

(4) that the accused willfully communicated. delivered. or transmitted the said information to a
person not entitled to receive it:

(5) that 18 U.S.C. section 1030(all exists: and

that. under the circumstances. the conduct of the accused was to the prejudice of good order
and discipline in the armed forces and was of a nature to bring discredit upon the armed forces.



'53 Testimony of CPT Lim {stating he gave the link through email to access diplomatic cables].
?53 Testimony ofSA Shaver: ID Es. at 1 (Bates newness).
Classi?cation Review, Bates a {10376903-53.



LIJ

Continuation Sheet, DD Form 457, US. v. PFC Bradley E. Manning

Facts

The evidence showed that the keyword "Iceland" was searched for a total of fourteen times from
both of PFC Manning?s primary and secondary SIPRNET computers. '55 The ?rst search for
iceland was on 9 January 2010 and came from PFC Manning?s profile.156 The evidence also
showed that PFC Manning accessed a CD created on 15 February 2010 at 6:21 am containing the
?le. UReykjaviktht? on his personal computerd? The evidence also showed that
WikiLeaks released ReykjaviktlS on 18 February 2010.?13 Additionally, the evidence showed
that when Mr. Lamo asked for ?bona ?des? during their chats, during the discussion of the State
Cables, PFC Manning stated. "this one was a test: Classi?ed cable from US Embassy Reykjavik
on Icesave dated 13 Jan 2010 .. the result of that one was that the icelandic ambassador to the US
was recalled. and ?red that?sjust one cable??9 This evidence. taken together, leads to a
conclusion that the Reykjavik-l 3 cable was provided to WikiLeaks by PFC Manning.

The evidence showed that in his chats with Mr. Lamo concerning the State Department cables.
PFC Manning said, ?Hilary Clinton. and several thousand diplomats around the werld are going
to have a heart attack when they wake up one morning, and finds an entire repository of
classi?ed foreign policy is available. in searehable format to the public theres so it
affects everybody on everywhere there's a US there?s a diplomatic scandal that
will be Iceland, the Vatican. Spain. Brazil. Madagascar. if its a country. and its
recognized by the US as a country. its got dirt on it its open worldwide anarchy
in CSV format. . and ?it was forwarded to WL and god knows what happens now
hopefully worldwide discussion. debates, and reforms I want people to see the
regardless of who they because without information, you cannot make informed decisions
as a which indicates that that he had reason to believe that the information he obtained
could be used to the injury of the United States or to the advantage ofany foreign nation.

While there was evidence that PFC Manning had the authority to access diplomatic cables for his
job.'62 the context of that evidence was that access was authorized for the to do theirjob.
The evidence also showed that before logging on to his primary and secondary SIPRNET
computers. PFC Manning had to click on a warning banner. the first sentence of which
read, ?You are accessing a U.S. Govermnent (USO) Information System (IS) that is provided for
USO-authorized use Accordingly. accessing diplomatic cables in order to provide them
to a person not entitled to receive it exceeded authorized access. PFC Manning had no
authorization to transfer this information to WikiLeaks, which was not entitled to receive it.



'55 lntelink Logs Forensic Report. Bates is 003751 16-129. at 8.

Testimony of SA Shaver.

'57 PFC Manning?s Personal Computer Forensic Report, Bates t?t 00124233-362. at 49.

'53 Testimony of SA Bettencourt; PFC Manning?s Personal Computer Forensic Report, Bates #1 00124283662. at
Attachment 3 {Carved_l55659_l 12253792254_l

Lame Chat. to ES. at 9.

Lamo Chat. 10 Ex. rain). at s.

Lamo Chat. 10 Ex. 19:13). at 33.

Testimony Lim (stating he gave the link through email to access diplomatic cables).

Testimony ofSA Shaver; 10 Ex. tits). at I (Bates a 00376856).

33

Continuation Sheet, DD 457, v. PFC Bradley E. Manning

The evidence showed that this cable was properly classi?ed and remains classi?ed.?

The evidence showed that 18 U.S.C. 1030(ait?l} exists and that PFC Mamiing?s conduct in
providing this classified cable to WikiLeaks was prejudicial to good order and discipline and was
service discrediting.

Additional Charge 11. Speci?cation 15 (Art. 134, 18 U.S.C. 793(e)):
eri
In order to prove this offense. the government must establish the following ?ve elements:

1) that at or near Contingency Operating Station Hammer, Iraq, between on or about 15
February 2010 and on or about 15 March 2010. the accused had unauthorized possession of
information relating to the national defense, to wit: a classi?ed record produced by a United
States Army intelligence organiZation, dated 18 March 2003:

that the accused had reason to believe that the information he possessed could be used to the
injury of the United States or to the advantage of any foreign nation;

(3) that the accused willfully communicated. delivered. or transmitted the said information to a
person not entitled to receive it;

(4) that 18 USC. section 793(e) exists; and

(5) that. under the circumstances, the conduct ofthe accused was to the prejudice of good order
and discipline in the armed forces and was of a nature to bring discredit upon the armed forces.

Facts

The evidence showed that "between [the document at issue] was
accessed only 12 times; 4 of the 12 accesses during that period were attributed to IP addresses
assigned to PFC Manning?s SIPRNET

The evidence showed that the classified record produced by a United States Army intelligence
organization copied from the SIPRNET contained the same content as the document that was
posted to WikiLeaks on 15 March 2010.? The evidence showed that in a chat with

(aliased at the time to Nathaniel Frank but later to Julian
Assange), the accused discussed this report. stating: YT article has LTC Packnetl allegedly



Classi?cation Review. Bates ii 003%903-53.

Army Intelligence Forensic Report. Bates it 004645166, at 1 I.

Army Intelligence Forensic Report, Bates 0046452-66, at 5-7 (the date oflhe document at issue is contained in
that Report); Testimony ot?SA Bertencourt.

34

Continuation Sheet, DD [Farm 457, U.S. v. PFC Bradley E. Manning

con?rming the authenticityr of the 2008 report posted on The Early Bird the same da
of that chat, 18 March 2010, had an article from the New York Times discussing that report.1h

The contents of the document at issue indicate that PFC Manning had reason to believe that the
information in this document could be used to the injury of the United States. PFC Manning had
no need to access information concerning WikiLeaks for hisjobd?g and he had no authorization
to provide this document to WikiLeaks. which was not authorized to receive it.

The evidence showed that this document was properly classi?ed and remains classi?ed.

The evidence showed that 18 U.S.C- 793(e'} exists and that PFC Manning's conduct in providing
this document to WikiLeaks was prejudicial to good order and discipline and was service
discrediting.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation 15 ot?Additional Charge

Additional Charge ll, Speci?cation 16 (Art. 134, 18 U.S.C. 641):
Law
In order to prove this offense, the government must establish the following ?ve elements:

(1) that at or near Contingency Operating Station Hammer. Iraq. between on or about 11 May
3010 and on or about 27 May 2010, the accused voluntarily. intentionally and knowingly stole,
purloined. or converted a thing of value, to wit: the United States Forces Iraq Microso?
Outlookaharepoint Exchange Server global address list belonging to the United States
government another;

(2) that the thing of value belonged to the United States and had a value in excess of One
Thoosand Dollars

(3) that the accused did so with intent to deprive the owner ot?the use or benefit ofthe thing of
value so taken:

(4) that IS U.S.C. section 641 exists: and

that. under the circumstances. the conduct of the accused was to the prejudice of good order
and discipline in the armed forces and was of a nature to bring discredit upon the armed forces.

Facts



'67 PFC Manning Personal Computer Forensic Report- Bates it 124283-362. at 3 I: Army Intelligence Forensic
Report, Bates it 004645266. at 10-] l.

IO Es. 1 HP). p. 20-21.

Testimony Lim.

Classi?cation Review. Bates it 0041063364.

Lu
U1

Continuation Sheet, DD ?rm 457.. U.S. v. PFC Bradley E. Manning

The evidence showed that on 7? May 2010. WikiLeaks tweeted a request seeking as many mail
addresses as possiblem The evidence showed that the Supply Annex NIPRN ET Computer to
which PFC Manning had access contained a large text ?le named ?blahtxt? appearing to be an
extract of an Exchange global address list in the peter.bigelow user account. and that based on
the analysis of PFC Manning?s personal computer and primary SIPRNET computer. ?blah?
appeared to be a ?le name that PFC Manning commonly used?: The evidence showed that the
?le creation dates for the ?les related to the global address list on the Supply Annex NIPRNET
computer were 13 May and 22 May 10'? The evidence also showed that the temporary internet
?les of 830 Peter Bigelow?s user account contained searches for how to obtain a global address
list from Microsoft Outlook.1M

The evidence showed that the Supply Annex NIPRNET computer did not require CAC logon. so
the. forensic analysis was unable to determine whether SSG Bigelow created the global access list
?les or if PFC Manning used his account.175 However. the recycle bin for $86 Bigelow?s
account contained documents related to PFC Manning. such as a copy of his Article 15.
counseling statements. and other documents!? and the temporary internet ?les on 888
Bigelow?s account included an amazoncom checkout page indicating that the item purchased
would be sent to PFC Manning at an address in Potomac. Maryland. and included evidence of
Google searches for WikiLeaks and Julian Assange,m and the Google search page login user
was PFC Manning?s G-mail account.?1 all of which indicates that PFC Manning was using 880
Bigelow's account.

The evidence showed that PFC Manning?s personal computer contained. in unallocated clusters.
a test fragment showing intent to ?acquire and ex?ltrate Global Address List from United States
Forces Iraq Microsoft Outlook t? Sharepoint Exchange Server.? and also contained an
extracted portion of an Exchange global address list. which led the examiner to conclude ?it
seems likely PFC MANNING completed the 'task" identi?ed above."m

The global address list would be helpful for the enemy to possess in that it would enable the
enemy to engage in ?spear?shing.? a targeted attempt to gain information from an unauspecting
source by masquerading as someone the source trusts; speci?c information such as knowledge of
full names and emails facilitates spear?shing because it is more likely to make the targeted
source believe the spear?sher is legitimate.l 0

PFC Manning?s searching for the global address list and how to ex?ltrate it shortly after
WikiLeaks tweeted asking for as many .mil address as possible indicates that that be converted
the global address list another in that he wanted to make this



Bates 00410594-95.

1? Supply Annex NIPRNET Computer Forensic Report, Bates tr 0019-9556-90. at l.

Supply Annex NIPRN ET Computer Forensic Report. Bates r?t' 0019955630. at 13.

Supply Annex NIPRNET Computer Forensic Report. Bates rt 00199556-90. at 29-32.

'75 Supply Annex NIPRNET Computer Forensic Report. Bates rt 00 99556-90. at 12.

Supply Annen Computer Forensic Report. Bates tr 00l99556-90. at 17.

?7 Supply Annex NIPRNET Computer Forensic Report. Bates tr 00199556-90. at 2 .22. 27-29.
?73 Testimony ofSA Williamson.

PFC Manning's Personal Computer Forensic Report. Bates it 00124233462. at 64-65.

Testimony ot?SA Bettencourt.

36

Continuation Sheet, DD ?rm 457, U.S. v. PFC Bradleyr E. Manning

information public by giving it to WikiLeaks and thus deprive its owner. the United States. of its
use or benefitm PFC Manning had no authorization to take the global address list from its
owner and thus his taking it constituted stealing it.

While there was no direct evidence provided of the value of the global address list. there was
evidence provided that the valuation of the Net-Centric Diplomacy database was over $4
million.lg There was also evidence provided that the value of the information WikiLeaks
possessed was 12 million pounds. or between $15-20 million]33 This circumstantial evidence
supports a conclusion that the value of the global address list was over 1.000.

The evidence showed that 18 U.S.C. 641 exists and that PFC Manning?s conduct in stealing the
global address list and converting WikiLeaks was prejudicial to
good order and discipline and service discrediting.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation 16 of Additional Charge

Additional Charge Speci?cation 1 (Art. 92, UCMJ):
Law
In order to prove this offense. the government must establish the Following three elements:

1) that there was in existence a certain lawful general regulation in the following terms:
paragraph 4-Stajt4). Army Regulation 25-2. dated 24 October 2007. which provides: "the
following activities are specifically prohibited by any authorized user on a Government provided
IS or connection: Attempts to strain. test. circumvent. or bypass network or 18 security
mechanisms. or to perform network or keystroke monitoring. RCERTS, Red Team, or other
of?cial activities. operating in their of?cial capacities only. may be exempted from this
requirement":

that the accused had a duty to obey such regulation; and
that at or near Contingency Operating Station Hammer. Iraq. between on or about 1
November 2009 and on or about 8 March 2010. the accused violated this lawful general

regulation by attempting to bypass network or information system security mechanisms.

Facts



For example, PFC Manning stated. in reference to the State Department Cables. that ?it was forwarded to Wt.

and god knows what happens now hopefully worldwide discussion, debates. and reforms i want people to see

the regardless of who they because without information- you cannot make informed decisions as a
ubiic." [0 Es. th?D}. at33.

33 nco valuation Documents. Bates a 004 0556-60.

Testimony ofSA Benencom.

Continuation Sheet. DD ?rm 457, U.S. v. PFC Bradley E. Marran

Examination of PFC. Manning?s secondary SIPRNET computer revealed a text string that he had
provided to (aliased at the time to Nathaniel Frank but later to
Julian Assange) in a deleted chat session found on his personal computer in that chat which
occurred on 8 March 2010. PFC Manning asked. "any good at 1m has cracking," provided the
text string, and said ?i had to hexadump a SAM ?le. since i don"t have the system

The evidence also showed that PFC Manning attempted to obtain the password ofthe FTPUSER
account on his secondary SIPRNET computer. which could have been used to attempt to hide his
true identity while using that computer.1 Given the extent of his conduct described in this
report, it is reasonable to conclude that PFC Manning attempted to find a way to hide his activity
while engaging in that conduct.

The evidence showed the regulation at issue existed and PFC Manning had a duty to obey it.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation 1 ofAdditional Charge Ill.

Additional Charge Ill, Speci?cation 2 (Art. 92, UCMJ):
Law
In order to prove this offense. the government must establish the following three elements:

that there was in existence a certain lawful general regulation in the following terms:
paragraph Army Regulation 25-2. dated 34 October 2007. which provides: ?the
following activities are specifically prohibited by any authorized user on a Government provided
IS 0r connection: Modi?cation of the IS or software. use of it in any manner other than its
intended purpose. or adding user-configurable or unauthorized software such as. but not limited
to. commercial instant messaging. commercial Internet chat. collaborative environments. or peer-
to-peer client applications. These applications create exploitable vulnerabilities and circumvent
normal means of securing and monitoring network activityr and provide a vector for the
introduction of malicious code. remote access. network intrusions or the es?ltration of protected
data?:

(2) that the accused had a duty to obe}F such regulation; and

(3) that at or near Contingency Operating Station Hammer. Iraq. between on or about 1 1
February 2010 and on or about 3 April 2010. the accused violated this lawful general regulation
by adding unauthorized software to a Secret Internet Protocol Router Network Computer.
Facts



PFC Manning?s Personal Computer Forensic Report. Bates it 00124233662. at 25 (the forensic examiner noted
that ?the terminology hash cracking? and ?hexadumping a SAM ?le' are techniques used for gaining
unauthorized access to a Windows-based computer by breaking the login password"); PFC Manning?s Secondary
SIPRNET Computer Forensic Report. Bates a 00199494607. at 9.

'85 PFC Manning's Secondary SIPRNET Computer Forensic Report. Bates 00l99494-j??t. at 940.

38

Continuation Sheet. DD ?rm 457. US. v. PFC Bradley E. Manniu-ig

The evidence showed that the wget command was used to download documents pertaining to
Guantanamo Bay detainees from PFC Manning?s primary SIPRNET In order for
wget to have been used. it must have been installed.

The evidence showed that wget was not authorized softwarem

The evidence showed the regulation at issue existed and PFC Manning had a duty to obey it.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation 2 of Additional Charge

Additional Charge Speci?cation 3 (Art. 92, UCMJ):
Law
In order to prove this offense. the government must establish the following three elements:

(I) that there was in existence a certain lawful general regulation in the following terms:
paragraph Army Regulation 25-2. dated 24 October 2007'. which provides: ?the
following activities are specifically prohibited by any authorized user on a Government provided
IS or connection: Modification of the IS or software. use of it in any manner other than its
intended purpose, or adding user-con?gurable or unauthorized software such as. but not limited
to . commercial instant messaging. commercial Internet chat. collaborative environments. or
peer-to-peer client applications. These applications create exploitable vulnerabilities and
circumvent normal means of securing and monitoring network activity and provide a vector for
the introduction of malicious code. remote access. network intrusions or the ex?ltration of
protected data":

that the accused had a duty to obey such regulation; and

that at or near Contingency Operating Station Hammer. Iraq. on or about 4 May 2010. the
accused violated this lawful general regulation by adding unauthorized software to a Secret
Internet Protocol Router Network Computer.

Facts

The evidence showed that PFC Manning's primary SIPRNET computer had a version of wget
(software used to download ?les from a server) that was the same version found in the
Department of State log files, the lntelink log ?les. and that was downloaded by the
bradleymanning user pro?le on a NIPRNET computer)? A user of PFC Manning?s user profile
on that NIPRNET computer did Google searches for WikiLeaks and wgetexe on 3 May 10 and



13" lntelink Logs Forensic Report. Bates it 00375] 16-139. at 12 (this document includes examples of dates of such

use of ?gen.
'37 Testimony of CPT Cherepko.
PFC Manning?s Primary SIPRNET Computer Forensic Report. Bates it 0021 1031-1 It]. at 37.

39

Continuation Sheet, DD form 457, U.S. v. PFC Bradley E. Manning

downloaded wget to that profile. A user of PFC Manning?s user pro?le then transferred
from the NIPRNET to SIPRNET on 4 May 2010. under PFC Manning's user pro?le. '39

The evidence showed that wget was not authorized software. "m

The evidence showed the regulation at issue existed and PFC Manning had a duty to obey it.

i thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation 3 of Additional Charge

Additional Charge Ill, Speci?cation 4 (Art. 92, UCMJ):
Law
In order to prove this offense. the government must establish the following three elements:

(1 that there was in existence a certain lawful general regulation in the following terms:
paragraph Army Regulation 25-2, dated 24 October 2007. which provides: ?the
following activities are specifically prohibited by any authorized user on a Government provided
IS or connection: Modi?cation of the IS or software. use of it in any manner other than its
intended purpose, or adding user-con?gurable or unauthorized software such as, but not limited
to . commercial instant messaging. commercial Internet chat. collaborative environments, or
peer-to?peer client applications. These applications create exploitable vulnerabilities and
circumvent normal means of securing and monitoring network activity and provide a vector for
the introduction of malicious code. remote access. network intrusions or the of
protected data?;

that the accused had a duty to obey such regulation: and

that at or near Contingency Operating Station Hammer. Iraq, between on or about 11 May
2010 and on or about 27 May 2010, the accused violated this lawful general regulation by using
an information system in a manner other than its intended purpose.

Facts

The evidence showed that on 7' May 2010. WikiLeaks tweeted a request seeking as many .mil
addresses as possible!? The evidence showed that the Supply Annex NIPRNET Computer to
which PFC Manning had access contained a large text file named "blahtxt" appearing to be an
extract of an Exchange global address list in the peter.bigelow user account. and that based on
the analysis of PFC Manning?s personal computer and primary SIPRNET computer. ?blah?
appeared to be a file name that PFC Manning commonly used.192 The evidence showed that the
?le creation dates for the files related to the global address list on the Supply Annex NIPRNET



1? Testimony ot'SA Shaver.

Testimony Chercpko.
Bates it 0041059435.
Supply Annex NIPRN ET Computer Forensic Report. Bates no masses-so. at I.

40

Continuation Sheet, DD ?rm 457, U.S. v. PFC Bradley E. Manning

computer were 13 May and 22 May 2010.193 The evidence also showed that the temporary
internet ?les of SSG Bigelow?s user account contained searches for how to obtain a global
address list from Microsoft Outlook. '94

The evidence showed that the Supply Annex NIPRNET computer did not require CAC logon. so
the forensic analysis was unable to determine whether SSG Bigelow created the global access list
?les or if PFC Manning used his accountng However, the recycle bin for 886 Bigelow?s
account contained documents related to PFC Manning, such as a copy of his Article 15,
counseling statements, and other documentsm and the temporary internet files on SSG
Bigelow?s account included an amazoncom checkout page indicating that the item purchased
would be sent to PFC Manning at an address in Potomac. Maryland. and included evidence of
Google searches for WikiLeaks and Julian Assangefgl and the Google search page login user
was PFC Manning?s G-mail all of which indicates that PFC Manning was using 336
Bigelow?s account.

The evidence showed that PFC Manning?s personal computer contained, in unallocated clusters,
a text fragment showing intent to "acquire and extiltrate Global Address List from United States
Forces Iraq Microsoft Outlook Sharepoint Exchange Server," and also contained an
extracted portion of an Exchange global address list. which led the examiner to conclude "it
seems likely PFC MANNING completed the 'task? identi?ed abovefdgq

PFC Manning?s searching for the global address list and how to ex?ltrate it shortly after
WikiLeaks tweeted asking for as many .mil address as possible indicates that that he used the
Supply Annex NIPRNET computer for a other than its intended purpose by obtaining the global
access list.

The evidence showed the regulation at issue existed and PFC Manning had a duty to obey it.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation 4 of Additional Charge 111.

Additional Charge Speci?cation 5 (Art. 92, UCMJ):
Lori-ii
In order to prove this offense. the government must establish the following three elements:

(I) that there was in existence a certain law?il general regulation in the following terms:
paragraph 7-4, Army Regulation 380-5. dated 29 September 2000, which provides, in relevant



Supply Annex NIPRN ET Computer Forensic Report, Bates 00199556490, at l3.

Supply Annex NIPRN ET Computer Forensic Report. Bates it 0019955630. at 20-32.

'95 Supply Annex NIPRN ET Computer Forensic Report. Bates 0019955630. at 12.

Supply Annex NIPRNET Compmer Forensic Report. Bates it 00199556-90. at I7.

Supply Annex NIPRNET Computer Forensic Report. Bates 00i99555-90. at alas. 27-29.
?is Testimony of SA Williamson.

PFC Manning?s Personal Computer Forensic Report, Bates 00124283662. at 64-65.

4i

Continuation Sheet, no ?rm 457, vs. v. are Bradley E. Mann?g

part: "Classified information that is not under the personal control and observation of an
authorized person. is to be guarded or stored in a locked security container, vault, room, or area,
pursuant to the level of classi?cation and this regulation by one or more of the following
methods: SECRET information will be stored in the same manner as prescribed for TOP
SECRET [in a GSA-approved security container with one of the listed supplemental controls or
in a vault or security room] in a GSA-approved security container without Supplemental
controls CONFIDENTIAL information will be stored in the same manner as prescribed for
TOP SECRET and SECRET information except that supplemental controls are not required?;

that the accused had a duty to obey such regulation: and

that at or near Contingency Operating Station Hammer. Iraq, on divers occasions between on
or about 1 November 2009 and on or about 2? May 2010, the accusod violated this lawful
general regulation by wrongfully storing classified information.

Facts

As outlined in this report, the evidence showed that throughout. PFC Manning brought CD5 with
classi?ed information on them and accessed them on his personal computer, and showed that his
personal computer contained classi?ed information. There was no evidence that the personal
computer c?gtaining classi?ed information was stored in an approved manner as required by the
regulation.

The evidence showed the regulation at issue existed and PFC Manning had a duty to obey it.

I thus conclude that reasonable grounds exist to believe that PFC Manning committed the offense
alleged in Speci?cation 5 of Additional Charge [11.

II. Analysis of Matters Raised by the Accused
Overcharging by the Government

The defense argued that Additional Charge 1 and its Specification, Specification 1 of Additional
Charge 11. and all ?ve Speci?cations of Additional Charge should be dismissed. The defense
also argued that the remaining Speci?cations of Additional Charge 11 shoold be consolidated into
one Speci?cation alleging violations of 18 U.S.C. section 641, one Speci?cation alleging
violations of 18 U.S.C . section 793(e). and one Speci?cation alleging violations of 18 U.S.C.
section if the charged offenses were either dismissed or consolidated as sought by
the defense. PFC Manning would face a maximum penalty of 30 years.

As outlined above. there are reasonable grounds to believe that PFC Manning committed the
offenses alleged in Additional Charge and its Specification and in Additional Charge
Speci?cation 1. These are serious charges. but so too is the offense conduct they allege.



Note that 1 do not believe that PFC Manning?s storage ofthe CD marked 12 JUL 07 C2 ENGAGEMENT ZONE
30 CC, with a sticker attached. in his quarters constitutes a violation ofthis regulation as there was no
evidence that the video contained on that CD was in fact classi?ed.

42

Continuation Sheet. DD farm 457. US. v. PFC Bradley E. Manning

Moreover. the Court of Appeals for the Armed Forces recently found that an Article 134 offense
alleging wrongfully providing information about the US. military to persons the accused thought
were members of Al-Qaida was not multiplicious with attempted violations of Article 104.
including attempting to give intelligence to the enemy. U. S. v. Anderson. 68 MJ. 378. 384-85
(C.A.A.F. 20 0). Accordingly. it would be inappropriate to recommend that these charges be
dismissed.

With respect to the remaining Speci?cations of Additional Charge charged under Article 134
as violations of 18 U.S.C. section 641. 8 violations of 18 U.S.C. 793(e). and 2 violations of 18
U.S.C. 1030(a)(l) (all also including charging the relevant conduct as prejudicial to good order
and discipline and service discreditingl. each speci?cation charges a separate and distinct
criminal act occurring at different times or involving different information. As Anderson stated,
for multiplicity analysis "the applicable rule is that. where the same act or transaction constitutes
a violation of two distinct statutory provisions. the test to be applied to determine whether there
are two offenses or only one. is whether each provision reqoires proof of a fact which the other
does not." Anderson. 68 MJ. at 385 (quoting v. United States. 284 US. 299. 304
(1932)).

A review of the elements of the speci?cations in Additional Charge ll alleging violations of 18
U.S.C.. sections 793(e). 641. and 1) indicates that each of these statutes requires ?proof
of a fact which the others do not." For example. the section 793te) offenses require proof that
the accused had unauthorized possession of information relating to the national defense. while
the section offenses require proof that the accused exceeded authorized access on a
computer and also obtained information that has been determined by the United States
government to require protection against unauthorized disclosure for reasons of national defense
or foreign relations. Accordingly. even though these offenses have two elements in common
(having reason to believe that the information could be used to the injury of the United States or
to the advantage of any foreign nation. and willfully communicating the infomtation to a person
not entitled to receive it), the offenses are not multiplicious. Similarly. the section 641 offenses
are not multiplicious with the section 793(e) and section '1 offenses because the section
641 elements require proof of different facts than do the elements of the other offenses.

As to whether any of the Speci?cations 2-16 of Additional Charge ll constitute an unreasonable
multiplication of charges. the Specifications allege separate criminal transactions involving
different time periods and different information. For example. one of the two Speci?cations
alleging violations of 18 U.S.C.. section 1030(al(1) (Specification 13) alleges conduct between
on or about 28 Mar 10 and on or about 27 May 10 involving more than 75 classi?ed Department
of State cables. while the other Speci?cation 141 alleges conduct between on or about involving one particular Department of State cable. An analysis of the other
Speci?cations of Additional Charge [1 charging violations of the same statute leads to the same
conclusion??



30' Note that in those cases where the dates of the Speci?cations in Additional Charge 11 overlap (13 7'93
violations: Speci?cations 2 and 3; Speci?cations 5 and 7: Speci?cations 2. 3. and 0; Speci?cations 9 and 10;
Speci?cations 3. 9 and 15: and I8 USC 641 violations: Speci?cations 4 and the information that is the subject of
the charged offense is separate and distinct. indicating that the criminal act charged in each specification is separate
and distinct.

43

Continuation Sheet, DD ?rm 457, US. v. PFC Bradley E. Manning

Anderson cites the ?ve part test used to determine whether there is unreasonable multiplication
of charges omitting the first factor. which simply asks whether the accused objected at trial. the
test asks. ?Is each charge and speci?cation aimed at separate criminal acts? Does
the number of charges and speci?cations misrepresent or exaggerate the [accused's]
criminality? Does the number ofcharges and speci?cations unfairly increase the
[accused's] punitive exposure? [and] Is there any evidence of prosecutorial overreaching or
abuse in the drafting of the charges?" Anderson. 68 MJ. at 386 (emphasis in original; quoting
US. v. Quiroz, 55 MJ. 334. 338 2001)). As outlined above. here each charge and
speci?cation is aimed at a separate criminal act. and thus I do not believe the number
of charges and speci?cations misrepresents or exaggerates PFC Manning?s criminality.

As to whether the number of charges and speci?cations unfairly increases his punitive exposure.
the Anderson court?s reasoning is instructive: ?[Anderson?s] punitive exposure was not
increased, because a conviction on any one of the Articles 80. UCMJ, offenses had a maximum
punishment of life con?nement; and the Government could easily have broken up the
speci?cations as drafted into multiple different speci?cations based on speci?c contacts. e-mails,
lntemet postings. etc." Id. Given the maximum penalty under Additional Charge 1 and its
Speci?cation. PFC Manning?s punitive exposure is similarly not unfairly increased here.

Finally. there was no evidence of prosecutorial abuse or overreach in the drafting of the charges.
As a result. I do not believe the charges and speci?cations constitute an unreasonable
multiplication ofcharges.

As to the Speci?cations of Additional Charge the evidence showed that it was common for
soldiers to lay music and games and to watch movies on computers in the at FOB
Hammett-m? There was also evidence that it was not uncommon to add software to those
computers. such as Chat.?203 However. the evidence also showed that there was a
mission-related reason for the addition of MIRC Chat. as used it to chat with the
aviation community concerning their work.204 and even for listening to music. as it helped reduce
stress and helped the perfomi their duties more effectively.MS In contrast. there was no
evidence showing there was a mission-related reason to add the software wget to these
computers, nor was there evidence showing there was a mission-related reason for PFC
Marming?s other conduct alleged in these Speci?cations. Moreover. whether or not other
software such as Chat was added to the computers. or whether or not games. music. or
movies was played on the computers. the basis for these charges is not that PFC Manning added
such other software or played games. music. or movies on these computers. Quite the contrary -



Testimony of CPT Fulton (saw soldiers listen to music in the SCIF. it was common for them to transfer music
from the SIPRNET to another network. no one ever told her that music on the SIPRNET was a violation of
information assurance security procedures. and soldiers would watch movies and play games on their workstations);
Testimony of SGT Padgett (they were told music was authorized in the SCIF and there was music and also games
on the shared drive on the SIPRNET terminals; movies were allowed. but only on the unclassi?ed computers}.

3?3 Testimony of SGT Madaras (MIRC chat was added to the computers once they got to Iraq}; Testimony of Mr.
Milliman (sometimes he would see software programs installed on the computers without his knowledge. but thal
was not common}.

:04 Testimony of PT Cherepko; Testimony of SA Shaver; Testimony of Mr. Milliman (MIRC Chat was authorized
to be installed soldiers were not supposed to install it themselves but they could have done it if they wanted to}.
3'5 Testimony Keay (music tolerated so Soldiers could be more productive).

44

Continuation Sheet, DD ?rm 457, U.S. v. PFC Bradley E. Manni?n'g

the basis for these charges is that PFC Manning attempted to bypass computer security
mechanisms. added unauthorized software. misused an information system, and wrongfully
stored classi?ed material as part of his efforts to provide information to WikiLeaks. Thus. the
evidence of other potential regulatory violations in the SCIF at FOB Hammer - much of which
appears to have been authorized, condoned. or at least had a mission-related purpose does not
rise to the level of a potential defense against these Speci?cations.

Rather. this evidence may serve as extenuating or mitigating evidence; in that case. however. the
severity of the offense conduct is such that it would not indicate that disposition of the
Speci?cations by anything other than referral to a general court-martial is appropriate. This is
because this evidence does not indicate that. should PFC Manning be convicted of these
Speci?cations. a sentence at or below the jurisdictional limits of a lesser level of court-martial
would be appropriate, nor does it indicate that another disposition of these Speci?cations would
be appropriate.

Death Penalty Unwarranted

With resPe-ct to Additional Charge 1. the defense noted that the government has stated that they
will not seek the death penalty in this case. Should there be any question on this issue. I
recommend against seeking the death penalty in this case as that penalty appears unwarranted
given the facts and circumstances of the charged offenses.

The Command?s Failures Made It Possible for PFC Manning?s Conduct to Occur

There were numerous failures on the part of the command that could have prevented PFC
Manning from conunitting the charged offenses involving classi?ed information and information
available on SIPRNET. Most egregiously. the command took no action whatsoever to review
whether PFC Manning?s access to classi?ed information should be suspended or revoked after
he made statements. before the deployment even occurred. to the effect that the American flag
was meaningless to him and he had no loyalty to this But there were other examples
such as physical outbursts where PFC Manning?s behavior was such that it should have
prompted review of his access to classi?ed informationzm There was evidence that had the
command been aware of these issues. PFC Manning would have been removed from the
While PFC Manning received regular behavioral health services, it does not appear any mental
health provider made a de?nitive recommendation that his access to classi?ed information be
rescinded until 28 May lO.2th Admittedly. the evidence surrounding the global address list
showed that PFC Manning continued to obtain information in order to provide it to WikiLeaks
even after losing his access to classi?ed information. which indicates that removing PFC
Manning?s access to classified information earlier would not have entirely prevented his offense
conduct. Nevertheless. the evidence also showed that. had the command taken steps earlier to
review PFC Manning?s suitability for continued access to classi?ed information. the command



3? Testimony of SPC Showman in defense-requesred closed session.

:07 See. for example. It) Ex. 2ND). at Ex. C. at Bates 0001336167 dated 2] Dec 26 Apr 09 [appears
mis-dated]. and 8 May It) by then-MSG Adkins describing PFC Manning?s erratic behavior}.

we Testimony of CPT Lim.

10 Ex. zuo). at Ex. Manning?s mental health records). at Bates a 0001414743.

45

Continuation Sheet, DD form 457, US. v. PFC Bradley E. Mannihg

could have limited PFC Manning's Opportunity to obtain classi?ed information and information
available on SIPRNET.

The command?s failures in this regard, however, do not negate PFC Manning?s intent or
knowledge in engaging in the charged conduct. Whether or not the commands failures could be
considered extenuating or mitigating for purposes of determining an appropriate sentence should
this case be referred to trial and should PFC Manning be convicted of any offenses. the severity
ofthe charged conduct is such that this information does not bear on whether PFC Manning
should face trial by general court-martial. trial by a lesser level of court?martial. or whether other
disposition of the charges is appropriate. Simply put. this information does not indicate that the
disposition of these charges should be less than by referral to general court-martial. This is
because this evidence does not indicate that. if PFC Manning were convicted of the offenses. a
sentence at or below the jurisdictional limits of a lesser level of court-martial would be
appropriate should he be convicted. nor does it indicate that other disposition of the charges is
appropriate.

PFC Manning's Behavioral Health Issuesf?ender Identity Disorder Should Be Considered

The record is replete with information concerning PFC Manning?s behavioral health treatment.
including for his gender identity disorder?? The evidence also showed that PFC Manning told
then-MSG Adkins about his gender identity issues by email,211 that PFC Manning had repeatedly
searched for information on the Internet concerning gender identity disorder and had information
concerning separation from the military for such disorder and concerning transgender persons in
the milita ii that he used an online identity named brearmaemanning to communicate on the
lntezrpet.? and that he cross-dressed as a female when he was on leave in late Jan?early Feb

10.

There was. however, no evidence that PFC Manning?s behavioral health issues. including his
gender identity disorder. prevented him from forming the requisite knowledge and intent for any
of the charged offenses. Moreover, behavioral health evaluations prepared on 22 and 23 May 10
stated that PFC Manning ?had the mental capacity to understand and participate in the
proceedings? and "was mentally responsible."3"

As to whether evidence of PFC Manning?s behavioral health issues, although not rising to the
level of a defense. could be considered extenuating md mitigating evidence. the severity of the
charged offenses is such that this evidence would not indicate that disposition of these charges
other than by referral to general court?martial is appropriate. This is because this evidence does
not indicate that, if PFC Manning were convicted of the offenses, a sentence at or below the
jurisdictional limits of a lesser level of court-martial would be appropriate. nor does it indicate
that other disposition of the charges is appropriate.



2"'10 Ex. sup). Es. o.

3? IO Ex. 21in), Es. E.

3? 10 Ex. sup), Ex. F, o. l.

21310 Ex. 21(0). Ex. H.

3? Lamo Chat. 10 Ex. 19(0). at 4041.

1? 10 Ex. 21(0). Ex. at Bates is 00014133-39.000l4147-48.

46

Continuation Sheet. DD Form 457. U.S. v. PFC Bradley E. Manning

PFC Manning Faced a Hostile Work Environment

The evidence indicated that PFC Manning perceived that the SCIF at FOB Hammer had a hostile
work environment against

As to whether this evidence could be considered extenuating and mitigating evidence. the
severity of the charged offenses is such that this evidence would not indicate that disposition of
these charges other than by referral to general court-martial is appropriate. This is because this
evidence does not indicate that. if PFC Manning were convicted of the offenses. a sentence at or
below the jurisdictional limits of a lesser level of court-martial would be appropriate, nor does it
indicate that other disposition of the charges is appropriate.

Comparativer Little Harm Was Caused by the Leaks

The defense argued that the charged information is ?out and open" in the public and ?the sky has
not fallen? as a result. and thus questioned whether the determinations in the classi?cation
review documents as to the harm likely to be caused by the release of the charged information
are valid.

The evidence showed. however. that the information PF Manning provided to WikiLeaks has
been found in the possession of the enemy"? The evidence thus does not support a conclusion
that little harm was caused by the leaks.

PFC Manning Had an Idealis?c Motive for His Actions

The defense argued that PFC Manning was young. idealistic, and had a strong moral compass.
indicating that he had an idealistic motive for his offenses.

The evidence showed that PFC Manning may have believed that his conduct was motivated. at
least in part. by idealism. For example. in his chats with Mr. Lame. after explaining how
weaknesses in protecting the information at issue helped make his actions possible ("it was a
massive data facilitated by numerous both physically. technically. and
perfect example of how not to do INFOSEC listened and lip-synced to Lady
Gaga?s Telephone while cx?ltrating possibly the largest data spillage in american history
pretty simple, and unglamorous weak servers. weak logging. weak physical security, weak
counter-intelligence. inattentive signal a perfect storm"). PFC Manning gave a
window into his motivation: ?its sad i mean. what if i were someone more malicious outlined above. the evidence showed that enemies ot'the United States possessed the information provided to
WikiLeaks by PFC Manning. For example. the video named ?12 Jul 07 CZ ENGAGEMENT ZONE 20 SC.
Anyoneavi" is contained in the recruiting video produced by Al-Qaida?s media arm (Bates 004082D2-236f} and is
described as "footage published by the WikiLeaks website." which clearly indicates that the enemy obtained this
video from WikiLeaks. That video also speci?cally references the leak ot?a State Department cable. which indicates
they obtained the cable from WikiLeaks. and also references WikiLeaks documents describing communications by
leaders in Islamic countries with the United States. which also indicates they are referring to State Department
cables they obtained from WikiLeaks.

47

Continuation Sheet, DD ?it-m 457, v. PFC Bradley E. Mandi-rig

could have sold to russia or china. and made bank?" and in response to Mr. Lamo's question as
to why he didn't sell this information. PFC Manning stated. ?because it"s public data it
belongs in the public domain information should be free because another state wouldjust
take advantage ofthe try and get some edge ifits out in the it should be
a public good?!?

However. assuming that PFC Manning had an idealistic motive for his actions. such motive
would not negate the requisite knowledge and intent for the charged offenses. Moreover. even if
the nature of his motive could be considered extenuating and mitigating evidence should this
case be referred to trial and should he be convicted of any offenses, I do not believe this evidence
would indicate that any disposition at this stage of the proceedings less than referral to trial by
general court-martial would be appropriate.

Defense Objections During the Hearing

1. At the outset of the hearing. the defense objected to my acting as the Investigating Of?cer in
this case and asked that I recuse myself?? I consulted with my legal advisor who advised me as
to the standard of R.C.M. 902(a) that recusal is required if my impartiality may reasonably be
questioned. My legal advisor also said that the test is ?any conduct that would lead a reasonable
man knowing all the circumstances to the conclusion that [my] impartiality might reasonably
be questioned." I do not believe a reasonable person knowing all the circumstances would be led
to the conclusion that my impartiality might reasonably be questioned. and thus denied the
defense?s recusal request. making the following essential findings of fact:

a. As a civilian, I am employed by the Department of Justice as a Deputy Chief in the
Criminal Division?s Child Exploitation and Obscenity Section. My section does not handle cases
involving conduct of which PFC Manning is accused.

b. I was not aware of the specifics ofDOJ?s investigation into the WikiLeaks matter
before reviewing materials in my role of as investigating of?cer.

c. I sent emails to ecunsel concerning this matter from my usdoj. gov email account.

d. I stated the reasons for my denial of the defense request to produce the DOJ file in this
case in my written determinations as to defense requested evidence.

e. While I am employed as a civilian by the Department of Justice that is investigating
this matter. no aspect of my DOJ work in the Child Exploitation and Obscenity Section is
involved with or otherwise relates to the allegations against PFC Manning.

f. I made written determinations as to defense-requested witnesses in writing based on
my determinations as to whether the expected testimony was necessary to make an informed
recommendation as to the truth of the charges. the form of the charges. and the disposition of the



Lama Chat1 IO Ex. l9(D). at 33.
ID Ex.

48

Continuation Sheet, DD [Farm 457, v. PFC Bradley E. Mann'iI-t'g

charges. and also determined whether witnesses were reasonably available. I also considered
whether the expected testimony was cumulative to the testimony of other witnesses.

g. In addition. after my legal adviser called me on 15 December 2011 to discuss R.C.M.
405m? 1) and 405(a)(' to ensure that I was properly considering them. I reconsidered my
earlier determination as to three defense requested witnesses. My legal adviser made no
recommendations as to my determinations on defense requested witnesses.

h. My determination as to the defense?s closure request was made after consulting my
legal adviser and providing his advice to the parties. That determination was consistent with the
legal advice I received. I provided the reasons for that determination in writing. applying R.C.M.
806(b)(2). (Subsequently. granted the defenses closure request in partm)

i. My determination as to my ability to consider statements under penalty of perjury
under 28 U.S.C. 1746 was made after consulting with my legal adviser and after providing his
advice and cases and legislative history he provided me to the parties. and my determination was
consistent with my legal advisor's advice. I provided that determination in writing to counsel via
a 141-418 December email. 1 did limited research into the matter before seeking my legal
advisor?s advice.

j. I conclude that a reasonable person knowing all the above facts would not conclude
that my impartiality might reasonably be questioned.

2. During the testimony of SA Graham. the defense objected to my admonishng the government
that. with respect to evidence that the defense objected to based on lack of authentication. I
would only consider authenticated evidence and I then asked the government ifthere were any
documents they wanted me to consider that they would need SA Graham to authenticate before
letting her off the phone. The defense objected that by making these comments I went beyond
my role as 10 and was telling the government how to perfect their case. In making these
comments. I simply was trying to make the proceeding more efficient by ensuring I wouldn?t
have to call this witness again. She is in Hawaii and we had a hard time getting her on the
phone.

3. During the testimony of SA Mander. the defense objected to my denial of their request that
the investigative ?les ofthe FBI and the State Department be produced. I referred the defense to
my written determinations as to defenseprequested evidence and noted that the defense can raise
this issue at the appropriate time should this case be referred to trial.

4. During the testimony of CPT Lim- the defense objected to the witness stating that the
accused?s conduct was service-discrediting and prejudicial to good order and discipline.

5. Before the taking of classi?ed testimony. the defense objected to the government?s providing
late notice of their intent to introduce classified evidence and testimony and objected to the
taking ofclassi?ed testimony and my consideration of classi?ed evidence based on this late



32? See IO Ex. 49.


Continuation Sheet, DD Form 457, v. PFC Bradley E. Manning

notice. The defense requesred that I append reasons for denying their request to the report of
investigation. The main reason I denied the defenses request is that the converting authority?s
special instructions requiring 14 days' notice of the intent to disclose classified information
applies only to the defense. not to the government. I also noted that there was no evidence the
government was trying to engage in trial by ambush. and that the defense had been in possession
ofthe underlying information since 8 November 2011.

6. During SPC Baker?s testimony. the defense objected to my allowing the government to ask
the witness about the accused?s statements about his feelings about the military. I overruled the
objection.

7. During Mr. Johnson?s testimony, the defense objected to the government putting up a
screenshot of a chat allegedly between the accused and Mr. Lamb showing the accused?s name
rather than the online identity "bradassB'7.? sustained that objection.

3. During Mr. Lamo's testimony. the defense objected to consideration of the alleged chats
between the accused and Mr. Lamo on the grounds that they are privileged under MILE. 503.
The parties submitted written briefs on this issue?! I overruled the defense objection and my
written determination of this issue is attached.222

9. On the morning of21 December. the defense objected to continuing the hearing until
Thursday morning. 22 December. for arguments because the defense was ready to argue at l500
on 21 December. I denied the objection because at a conference on 20 December. the parties
agreed to break early on 21 December and to present argument Thursday morning. 22 December.
and the government relied on that agreement in planning its preparation.

10. Additionally. the defense made various objections throughout the testimony to the
government?s questions. Those objections are contained in the transcript of the hearing.



33? lo Ess. 14,

IO Es. 5t}.
50

IN THE UNITED STATES ARMY

FIRST JUDICIAL CIRCUIT

UNITED STATES

CIVILIAN DEFENSE COUNSEL
NOTICE OF APPEARANCE

.

MANNING. Bradley E.. PFC

LLS. Army.

Headquarters and Headquarters umpany. U.S.
Amty Garrison. Joint Base Myer? Henderson Hall.
Fort Myer. VA 22211

DATED: I6 December 20! I



Pursuant to the Rules of Practice before Army Courts-Martial. I hereby provide notice to
the Investigating Of?cer of my appearance on behalfof PFC. Bradley Manning. My of?ce
address and phone numbers are: 1 I South Angel] Street. Suite 317. Providence. Rhode Island
02906: of?ce phone: (508) 689-4616 or (800) 588-4156: office fax: {508) 639-9282. I am a
member in good standing and licensed to practice in the following states: Massachusetts
-. California and District ofColumbia I have been sworn into the
following courts: US. Supreme Court. Supreme Court of California. Court oprpeals for the
Armed Forces. and the Army Court ofCriminal Appeals.

I am currently a reserve member ofthc United States Army with the rank of Lieutenant
Colonel. I have been qualified and certi?ed under Article 27(b) and sworn under Article 42(a).
Uniform Code of Military Justice. 1 have not acted in any manner that might tend to disqualify
me in this Article 32 hearing.

Respectfully submitted.

Wk

DAVID EDWARD COOMBS
Civilian Defense Counsel

UFCR. EXHIBIT

THE UNITED STATES ARMY
FIRST JUDICIAL CIRCUIT

UNITED STATES

DEFENSE MOTION
v. REQUESTING RECUSAL 0F

INVESTIGATING OFFICER
MANNING, Bradley E., PFC UNDER R.C.M. 902(3)
US. Army,
Headquarters and Headquarters Company, U.S.
Army Garrison, Joint Base Myer-Henderson Hall, DATED: 16 December 2011
Fort Myer, VA 22211

RELIEF SOUGHT

1. PFC Bradley E. Manning, by and through counsel, moves the Investigating Of?cer, pursuant
to R.C.M. to recuse himself in the instant case.

BURDEN OF PERSUASION AND BURDEN OF PROOF

2. As the moving party, the defense has the burden of persuasion. R.C.M. 905(c)(2). The
burden of proof is by a preponderance of the evidence. ROM. 905(c)(1).

FACTS

3. The Investigating Officer in this case is a career prosecutor for the Department of Justice. He
has spent approximately 10 years prosecuting crimes on behalf of the United States government.

4. The Department of Justice has separately initiated, and is currently pursuing, a collateral
investigation into the alleged crimes in this case. As part of that investigation, several
individuals who may know or have come into contact with PFC Manning have been subpoenaed
and ordered to testify at a grand jury hearing.

5. The defense requested in the Defense Request for Production of Evidence on 22 November
201 1, that the information obtained pursuant to the investigation being conducted by the
Department of Justice be turned over to the defense. The Investigating Of?cer denied that
request.

6. Both the defense and the government submitted a request for the production of witnesses at
the Article 32 hearing. The Investigating Of?cer ruled that each and every government witness
was relevant to the proceeding, though certain of the witnesses were deemed not reasonably
available. Of the 38 witnesses that the defense requested that were not also requested by the

m. arcs. truism azco)

government, the Investigating Of?cer ordered only two witnesses to appear at the Article 32
hearing. In reality, one is not currently able to appear in person at the Article 32 hearing so the
detonse has agreed to allow that individual to testify telephonically. This means that only one
defense witness (out of 38} will appear at the Article 32 in person. In effect. the Investigating
Officer?s ruling means that virtually all of the witnesses testifying will be government witnesses.

7. The defense also filed a motion dated 28 November 2011 requesting the Investigating Of?cer
to close the hearing during instances in which the government intended to elicit four or five
particular instances of alleged uncharged misconduct. The defense noted that the evidence is
unreliable, likely inadmissible in a court-martial, and prejudicial to the accused. The
Investigating Of?cer agreed that ?[T]here is a substantial probability that an overriding interest
will be prejudiced if proceedings remain open.? However, he was of the view that options short
of closure could remedy any potential prejudice of panel members. The defense asked the
Investigating Officer to reconsider his ruling on closure; he refused to do so.

8. In the alternative, the defense asked that the Investigating Officer exclude media from the
courtroom during the portions of the hearing in which the instances of alleged uncharged
misconduct were referenced. According to the Manual for Courts Martial, this would not
constitute ?closure? and thus would not be subject to the four part test outlined in R.C.M.
The defense further requested that the Investigating Of?cer impose a gag order on all
remaining (non-media) participants, prohibiting them from speaking about the alleged uncharged
misconduct. The Investigating Of?cer denied the defense?s request.

9. On 8 December 201 1, the defense ?led a Request to Compel Production of Witnesses,
including six Original Classi?cation Authorities (OCAs). The goverrunent opposed the
defense?s request and sought to introduce unsworn statements of the OCAs in lieu of sworn
statements under The Investigating Officer engaged in extensive research on
behalf of the prosecution. producing five cases that he claimed supported the government?s
position. The government, for its part, did not produce one case to support its argument.
Ultimately. the Investigating Of?cer ruled in favor of the prosecution on the admissibility of the
unswom statements. Notably; the Investigating Of?cer began his own independent research on
this issue even prior to notifying the defense of his decision on whether the OCAs would be
produced.

WITNESSESIEVIDENCE
10. The following evidence is adduced in support of this motion:

a) Resume of LTC Paul Almanza;

b) Government Requested Witness List for Article 32 Investigation;

c) Defense Request fer Article 32 Witnesses;

d) Defense Request to Compel Production of Witnesses (8 December 20]
e) Defense Request for Production of Evidence (22 November 2011);

f) Defense Request to Compel Production of Evidence (1 December 2011);
g) Sealed Defense Motion for a Closed Hearing under Rule

h) Sealed Defense Response to Government?s 405(h)(3) ?ling.
i) Emails pertaining to government?s request to introduce unsworn statements of OCAs.

LEGAL AUTHORITY AND ARGUMENT

11. It is trite law that an accused has a constitutional right to an impartial judge. United States
v. Butcher, 56 90 (C.A.A.F. 2001). ?The neutrality required by constitutional due
process helps to guarantee that life, liberty, or property will not be taken on the basis of an
erroneous or distorted conception of the facts or the law. At the same time, it preserves both the
appearance and reality of fairness, generating the feeling, so important to a popular government,
that justice has been done. by ensuring that no person will be deprived of his interests in the
absence ofa proceeding in which he may present his case with assurance that the arbiter is not
predisposed to find against him.? Id. (citations omitted).

12. Under R.C.M. 902(a), militaryjudge shall disqualify himself or herself in any
proceeding in which that military judge?s impartiality might reasonably be questioned.? This
section was designed to effectuate an accused?s constitutional right to an impartial decision-
maker and to preserve public con?dence in the military justice system. See United States v.
Wright, 52 MJ. 136, 141 (C.A.A.F. 1999) (?The exhortation of the statute is designed to foster
the appearance of justice within thejudicial system?); Butcher, supra at 90 (?This section was
enacted to maintain public con?dence in the judicial system by avoiding even the appearance of
partiality)(citations omitted).

13. An Investigating Of?cer is under the same obligations as a military judge to disqualify
himself in cases where his impartiality might reasonably be questioned. ?In determining
impartiality, investigating officers, whose functions are judicial and quasi-judicial, are held to
the same standards as military judges.? United States v. Merritt, 2009 WL 1936628 at *2
(A.F.Ct.Crim.App.), citing United States v. Collins. 6 MJ. 256 (C .M.A. 1979); United States v.
Cunningham, 30 CMR. 402, 404

l4. Notably, the test under R.C.M. 902(a) is not actual partiality, but the existence of a
reasonable question about impartiality. R.C.M. 902 is not assessed in the mind of the military
judge himself, but rather in the mind of a reasonable person who has knowledge of all the facts.
United States v. Martinez, 19 MJ. 652, 654 (A.C.M.R. 1984) (?We note that the proper test is
whether the charge of lack of impartiality is grounded on facts that would create a reasonable
doubt concerning thejudge's impartiality, not in the mind of the judge himself or even
necessarily in the mind of the appellant, but rather in the mind of a reasonable man who has
knowledge of all the facts?) (internal citations and parentheticals omitted); United States v.
Kincitetoe, 14 40, 50 (C.M.A. 1982') (?Any conduct that would lead a reasonable man
knowing all the circumstances to the conclusion that thejudge's impartiality might reasonably be
questioned? is a basis for the judge's disquali?cation") citing E. Thode, NOTES To
Coos or JUDICIAL CONDUCT 6t) (1973); United States v. Foster, 64 NM. 331, 333 (C.A.A.F.
2007) (?the test is whether the military judge's actions would cause a reasonable person
observing the trial to question the court-martial's legality, fairness, and impartiality").

15. A reasonable observer with knowledge of all the facts in the instant case might reasonably
question the Investigating Of?cer?s impartiality in this case for the following reasons:

16. The Investigating Of?cer?s Con?ict of Interest: The Investigating Of?cer in this case is a
career prosecutor the Department of Justice. He has spent approximately 10 years
prosecuting crimes on behalf of the United States government. To an outside observer, it
appears questionable that an individual who has devoted much of his life to prosecuting
criminals would now be able to "switch gearsimpartial arbiter.

17. The fact that the Department of Justice currently has an ongoing collateral criminal
investigation in this case would also cause a reasonable person to question the impartiality of the
Investigating Of?cer. The reasonableness of this belief is compounded by the fact that the
Investigating Of?cer has determined that the defense?s request for the Department of ustice?s
collateral investigation is ?not reasonably available.? Surely, to hold otherwise (Le. to compel
production of the document) would put the Investigating Of?cer in a delicate and unpleasant
situation upon return to his position as a Department of Justice employee.

18. Clearly, there is a real conflict of interest in having a Department of Justice prosecutor
preside over the instant case. A reasonable person viewing the proceedings from the outside
would have serious questions about the impartiality of this Investigating Of?cer.

19. The Investigating Of?cer?s Rulings on Defense Witnesses: The defense requested 43
witnesses. Ten of these witnesses were also requested by the government. Of the remaining 38
witnesses that were requested only by the defense, the Investigating Officer determined that only
rive would appear at the Article 32 hearing. In reality, one is not currently able to appear in
person at the Article 32 hearing so the defense has agreed to allow that individual to testify
telephonically. This means that only one defense witness (out of 38) will appear at the Article
3?2 in person. In effect, the Investigating Of?cer?s ruling means that virtually all of the witnesses
testifying will be government witnesses.

20. This case is said to involve the largest military leak of documents in United States history.
The government has charged PFC Manning with 22 specifications, carrying a maximum
punishment of life in prison without the possibility of parole. It de?es logic that, in a case such
as this, the Investigating Officer would limit the defense?s ability to call the overwhelming
majority of its witnesses.

21. Anecdotally, the defense observes that it has been able to call more witnesses in Article 32
hearings involving simple assault or minor drug possession. Here, where the accused risks
spending life in prison, it is beyond the realm of comprehension that the defense would only be
permitted to examine one witness in person.

22. The Investigating Of?cer?s ruling on the defense witness request would cause a reasonable
observer to believe that the playing ground is not fair. While the government is able to call
virtually everyone it wants, the defense must proceed with its hands tied behind its back. Such a
one-sided ruling whether motivated by actual bias or not creates the reasonable perception
that the Investigating Officer is not impartial.

23. The Investigating Officer?s Ruling On the Defense?s Closure Motion: On 28 November
2011, the defense filed a motion requesting the Investigating Of?cer to close the hearing during
instances in which the government intended to elicit particular instances of alleged uncharged
misconduct. The defense noted that the evidence is unreliable, likely inadmissible in an actual
court-martial, and highly prejudicial to the accused. The defense argued that to allow the
evidence to be adduced in an open fortun would prejudice PFC Manning?s right to a fair trial, as
it would put a military judge in a position where he would have to ?un-ring a bell."

24. The Investigating Of?cer agreed that ?[T]here is a substantial probability that an overriding
interest will be prejudiced if proceedings remain open.? He also agreed that the defense?s
request was narrowly tailored. However, the Investigating Officer was of the view that options
short of closure could remedy any potential prejudice of panel members. In this respect, he
stated:

I find that this part of the test is not met because, should this case be referred to trial, a
military judge will have the ability to take appropriate protective measures. For example,
a militaryjudge can ensure that thorough voir dire is conducted of prospective panel
members. This would address the defenses concern that ?if [this] information is
disclosed to the public prior to trial, it will have a detrimental impact on PFC Manning?s
ability to obtain a fair and impartial trial because prospective panel members hearing the
information are likely to form an opinion regarding PFC Manning based upon this
information.? Defense 23 November 2011 request, para. 10. Thorough voir dire would
also address the defenses concern as to the military judge and the defense having to ?un-
ring a hell with the members" because it would cover any issues as to whether the public
disclosure of this information affected prospective panel members? ability to sit on the
panel. In this regard, I note that R.C.M. 912(f)(1)(M) and (N) state that member
shall be excused for cause whenever it appears that the member [h]as informed or
expressed a definite opinion as to the guilt or innocence of the accused as to any offense
charged [or] [s]hou1d not sit as a member in the interest of having the court-martial
free from substantial doubt as to legality, fairness, and impartiality." The discussion to
R.C.M. 912(00) notes that ?grounds for challenge under subsection (N) [include] that
the member: has a decidedly hostile attitude toward a party". The grounds for
granting a challenge for cause would thus ensure that, as the defense has stated,
Manning is entitled to a trial before an unbiased panel that has no preconceived opinions
about him.? Defense 28 November 2011 request, para. 10. Finally, if this case were
referred to trial a military judge will have the ability to issue rulings and instructions
necessary to ensure that the trial is not affected by the disclosure of this information at the
Article 32 investigation.

25. The Investigating Of?cer appears to have overlooked the severity of the charges in this
case. PFC Manning has already been subjected to extensive media scrutiny in this case. He has
been referred to as a ?traitor? who has ?blood on his hands.? Govermnent officials have even
called for his execution. And all this was prior to PFC Manning even having a preliminary

UI

hearing. That the Investigating Of?cer claims that voir dire and an instruction can ?cure? the
prejudice occasioned by the public disclosure of this information is further evidence of his bias.

26. In its Sealed Defense Response to Government?s 405(h)(3) ?ling, the defense pointed out
that in all of the cases cited by the government in support of its motion to keep the hearing open,
it was the government that was seeking closure over defense objection. Here, the defense is in
the rare position of seeking closure to protect the accused?s right to a fair trial. The
government?s rebuttal was, in essence, that the public had a ?right to know? this information.
Incidentally, it is ironic that the government has championed the public?s ?right to know? in a
case where the government?s position on the merits is that the public did not have a right to
know. Based on his ruling, the Investigating Of?cer appears to have agreed that the publicis
?right to know? this evidence evidence that likely will be ruled inadmissible under M.R.E.
404(b) or 403 overrides the accused's right to a fair trial.

27. The defense requested that the Investigating Of?cer reconsider his ruling. In so doing, the
defense reminded the Investigating Of?cer that ?[tjhis case has already been subjected to
extensive media scrutiny and PFC Manning has already been adjudged guilty in the court of
public opinion. Moreover, several high-ranking of?cials (both military and government) have
made improper comments concerning PFC Manning's probable guilt and appropriate
punishment. In a case such as this, there is no substitute for ensuring that potentially
inadmissible and highly inflammatory evidence is not placed into the public realm.? The
Investigating Of?cer was of the view that any prejudice caused by such statements could also be
remedied through voir dire and instructions:

Additionally, with respect to the defense?s reference to ?high-ranking of?cials
havjing] made improper comments concerning PFC Manning's probable guilt and
appropriate punishment," in Mr. Coombs?s 131621 December 2011 email, I ?nd that
thorough voir dire and appropriate rulings and instructions by the military judge will
adequately address the risk of unlawful command in?uence.

28. Apparently, the Investigating Of?cer is comfortable piling prejudice on top of prejudice
so long as a military judge deals with the issue through voir dire or an instruction down the road.
It is incomprehensible that the Investigating Of?cer?s solution is to allow what he and the
concede will be negative fallout for the accused with a view to cleaning up the mess
later on.

29. The defense motion requesting limited closure was, in colloquial terms, a ?no-brainer.? No
prejudice can come of ruling in favor of the defense. Nor can any prejudice come to the
government in ruling in favor of the defense. The only prejudice that can (and undoubtedly will)
result is in the Investigating Officer ruling against the defense. The defense maintains that the
government would like the media to hear the evidence precisely in order to cause the very
prejudice which they then say can be ?fixed? through voir dire or a limiting instruction. Such a
position is absurd and the ruling of the Investigating Of?cer in this respect would cause a
reasonable observer to question his impartiality.

30. Although baf?ed by the Investigating Of?cer?s determination on its closure motion, the
defense then requested that the Investigating Officer exclude the media from limited portions of
the Article 32 hearing and issue a gag order for those non-media Spectators who remained in the
court room. Such a solution would not be considered ?closure? under R.C.M. 806 and thus,
would not be subject to the four-part test that the defense maintains the Investigating Of?cer
incorrectly applied. The Investigating Of?cer refused to do so and would not provide a
justi?cation for this ruling other than to cross-reference his previous ruling on the closure
motion.

31. On 14 December 2011, the defense asked the Investigating Of?cer to reconsider his ruling
on the closure motion and on the defense?s altemative request to exclude media from the
courtroom during the portions of the hearing in which the instances of alleged uncharged
misconduct were referenced. The Investigating Of?cer indicated that he would take the requests
under advisement. On 15 December 2011, the Investigating Of?cer denied the defense?s
request. The Investigating Of?cer did not provide anyjustification for these rulings.

32. The Investigating Of?cer?s Ruling on Government Witnesses? Unsworn Statements: 0n 8
December 2011, the defense ?led a Request to Compel Production of Witnesses, including six
Original Classi?cation Authorities

33. The government opposed the request and instead sought to adduce unsworn statements from
the six OCAs in lieu of sworn statements under R.C.M. The section provides that:

The investigating of?cer may consider. over objection of the defense, when the witness is
not reasonably available:

i) Sworn statements;

ii) Statements under oath taken by telephone, radio, or similar means providing each
party the opportunity to question the witness

Prior testimony under oath; and

iv) Deposition of that witness; and

v) In time of war, unsworn statements.

34. The government maintains the unsworn statements are, in effect, sworn statements.
The government?s argument in its entirety is as follows:

The United States objects to your consideration of Article 131, Perjury, as a reference in
determining whether a statement is properly sworn. Article 131 is a punitive article
intended to criminalize sworn statements by Servicemembers during ajudicial
proceeding. The original classification authority (OCA) reviews are simply sworn
statements made ?under penalty of perjury" 28 U.S.C. 1746. Rather than Article
131, the United States recommends you consider Article 134, False Swearing, and
speci?cally the portion under the explanation which states, does not include

such statements made in ajudicial proceeding or course of ustice, as these are under
Article 131, See MCM, part IV, paragraph 79c(1). Under the defense's

proposed analysis, the only sworn statements that you could consider during this
investigation, are previously sworn statements given under oath at an Article 32
investigation or court-martial. [Email from CPT Fein, 8 December 20]

35. The defense asserts that the language of R.C.M. 405(g)(4)(B) is clear the
Investigating Of?cer may consider only ?sworn statements? and not unsworn statements signed
under penalty of perjury. In an effort to convince the Investigating Of?cer to apply the plain
meaning of the statute, the defense pointed to Article 131 in order to show that the dra?ers of the
Manual for Courts Martial were aware of 28 U.S.C. 1746 and chose not to incorporate that
section into R.C.M. Had the dra?ers intended unswom statements under R.C.M.
405(g)(4)(B) to be admissible, they could have easily enumerated that exception under the
section.

36. On 12 December 2011, the Investigating Of?cer, the government and the defense conducted
a telephonic 302 conference. One of the issues discussed was whether the unswom statements
could be admitted in lieu of sworn statements. The Investigating Of?cer sua sponte provided the
parties with two cases that he believed supported the proposition the government was advancing.
In other words, the Investigating Of?cer did the government's work for it. Notably, the
Investigating Officer was investigating how to adduce the government?s evidence before ruling
on the defense?s motion to compel production of witnesses. The Investigating Of?cer was
looking for ways to admit the statements because he had already predetermined that the OCAs
would not be called to testify in person.

37. By response email on 12 December 201 l, the defense objected to the investigating Officer's
reading of the two cases it was relying on:

In response to your request for us to look at 2010 WL 2265833 and 2002 WL 243445, the
defense's position is that both cases are inapplicable to the situation at hand. In Faison,
the ID found that TRD was unavailable and that her videotaped statement was sworn.
Such a determination was appropriate given the fact TRD responded to questions
indicating that she knew the difference between the truth and a lie and promised to tell
the truth. As the 10 and the AFCCA correctly concluded, this colloquy more than
adequately satis?ed the oath/affirmation requirement so as to make videotaped
statement a sworn statement under R.C.M. In the instant case, unsworn
statements under 28 U.S.C. U46 do not share any of the same hallmarks of a sworn
statement. The statements are not made in front of anyone and the statements are not
similar, in that they are not made in front of a person authorized to administer oaths.

Likewise, Elsewer dealt with a videotaped interview that was done without a formal
swearing or oath. However, it quali?ed as a sworn statement in accordance with R.C.M.
since on a later date the unavailable witness did swear to the truth of the
statements contained therein. The ID correctly found this to be a sworn adoption of the
videotaped interviews that, pursuant to United States v. Wood, 36 NH. 651 (A.C.M.R.
1992), rendered it admissible. None of the individuals who provided the unsworn
statements under 28 U.S. C. 1746 have subsequently provided a sworn adoption of their
unsworn statement in accordance with R.C.M.

An unsworn statement provided under 28 U.S.C. 1746 does not qualify as a sworn
statement. In order for an unsworn statement provided under 28 U.S.C. 1746 to be
admissible, it must be subscribed and signed "in ajudicial proceeding or course of
justice" at the Article 32 hearing. A plain reading of 28 U.S.C Section 1746 and R.C.M.
405(h)(1)(A) undercuts any argument to the contrary. [Email from defense to
Investigating Of?cer, 12 December 201

38. The government?s one line reSponse was, ?The United States maintains its previously stated
position on the validity of the sworn statements." [Email from CPT Fein to Investigating
Of?cer, 12 December 201 The Investigating O?icer did not ask the government to respond
speci?cally to the defense?s argument or to advance its own interpretation of the cases.

39. On 14 December 201], the Investigating Of?cer ruled in favor of the prosecution, but not
before taking it upon himself again to do the government?s research. In support of its ruling, the
Investigating Of?cer produced three new cases that he believes supports the proposition the
government is advancing. Only one of these is a military case; two are federal appellate cases.
The defense maintains that none of the cases offers support for the proposition that an unsworn
statement under 28 US. C. 1746 can be converted into a sworn statement under ROM.
In fact, the only military case cited by the Investigating Of?cer, United States v.
Ganderman, 67 MJ. 683 2009) appears to lend more support to the defense?s position
that that of the Of?cer. The Army Court of Criminal Appeals in
Gunderman emphasizes that, ?To be admissible before this court, factual assertions must be
admitted in a proper form Indeed, our own internal rules re?ect this requirement for some
form of solemnity." 1d. At 686-7. The court continued, ?By reaf?rming this requirement, we do
not exalt form over substance However, assertions of fact must either be contained in the
record or be offered in an admissible form.? Id. At 688. In short, Gunderman establishes that
fenn is important and evidence proffered by either party must be ?in an admissible form.?

40. In making his ruling, the Investigating Officer stated, also note that the classification
review statements at issue all indicate that they are in the ?course of justice? as they all indicate
the persons making the statements knew they were being prepared for use in this case. As such, 1
consider these statements to have the same indicia of reliability as sworn statements.? [Email
from Investigating Of?cer, 14 December 2011]. The last line of the Investigating Officer?s
ruling clearly reveals that he has not deemed an unsworn statement made under penalty of
perjury to be equivalent to a ?sworn statement" under Rather, he has determined
that an unsworn statement should be admissible because it carries with it ?the same indicia of
reliability as sworn statements.? Id. The Investigating Of?cer has fabricated a new ground upon
which to admit statements under 405(g)(4)(l3) that the statement carries ?the same indicia of
reliability as sworn statements.? The Investigating Of?cer, after bending over backwards to
make the government?s case for it, has now read into 405(g)(4)(B) a new ground for the
admissibility of unsworn statements. This is not permitted under military law. See United States
v. Wore. I 232, 285 (CMA 1976') rule is well settled that a plain and unambiguous
statute is to be applied, not interpreted. Where no ambiguity is apparent there is no reason to
resort to rules of statutory construction, which are intended solely to remove not create doubt").

41. In short, despite a clear statement in R.C.M. 405(g)(4)(B) that the Investigating Of?cer
admit only ?sworn statements," the Investigating Of?cer: a) did extensive research on the issue
on behalf of the govermnent; b) provided the defense with ?ve cases to support the government?s
position; c) read in a new ground for admissibility into R.C.M. and d) proceeded to
rule in favor of the prosecution. It strains credulity to believe that the Investigating Of?cer was
acting as an impartial neutral when he actively engaged in extensive research to support the
government?s position (without requiring that the government do this research itself) and
proceeded to create a new ground for the admissibility of statements at the Article 32 hearing.
The Investigating Of?cer has never once produced a case that supported the defense.

42. The Investigating Of?cer?s conduct in this case is similar to that of the military judge in
United States v. George, 40 MJ. 540 (A.C.M.R. 1994). Like the Investigating Of?cer in this
case, the military judge in George was ?a reserve officer who was normally employed as a
civilian prosecutor." Id. at 543. The Army Court of Military Review noted that a civilian
prosecutor who was on active duty for a short period of time for duty as a militaryjudge, it was
important for him to ensure that his conduct at trial enhanced both the appearance and actuality
of impartiality and fairness of the military justice system.? Id. In particular, the court in George
held that ?[t]he military judge improperly limited the number of witnesses [for the defense] 1d.
at 544. The court also expressed concern over the ?military judge assisting the trial counsel to
try his case, and aiding him in making the foundation for these evidentiary issues.? Id. (internal
citations omitted). Finally, the military judge ?made many rulings that revealed his advocacy for
the prosecution" such that he abandoned his role as an impartial arbiter and ?became an advocate
for the prosecution.? Id. In the instant case, it similarly appears that the Investigating Of?cer
has abandoned his role as a third-party neutral and instead has become an instrument of the
prosecution.

43. Based on:

a) his civilian role in the Department of Justice and the ongoing Department of Justice
criminal investigation;

b) his ruling that the defense could only examine 2 of its 38 requested witnesses;

c) his determination that the public?s ?right to know" supersedes PFC Manning?s right to a
fair trial;

d) his extensive research for the government, following by a favorable ruling for the
prosecution;

there is a reasonable question about the Investigating Of?cer?s impartiality in the instant case. A
reasonable observer, familiar with the facts and circumstances surrounding this case, would
conclude that the ?decks are stacked" against the defense and that the Investigating Officer
should recuse himself in order to preserve the integrity of the militaryjustice process.

1 {l

CONCLUSION

44. Based on the above, the defense requests that the Investigating Of?cer reeuse himself in the
above-titled matter under R.C.M. 902.

DAVID EDWARD MBS
Civilian Defense Counsel

1]

(Q
'd on the front lines for social justice





December I. 5. 2.011

Clerk of the Court

US. Army Court of Criminal Appeals
9275 Gunston Road

Fort Belvoir, VA 2306075546

Re: United States v. Manning, Article 32 Hearing, Ft. Meade, Maryland; Julian
Assange 3: Wikileaks v. United States 8; Lt. Col. Paul Almanza

Dear Clerk of the Court:

We represent represent the Wikileaks media organization and its publisher Mr. Julian
Assange regarding access to the Article 32 proceedings in United States Bradlev Manning,
scheduled to begin at Fort Meade. Maryland, on December 16. 2011.

We are ?ling a Petition for Extraordinary Relief in Form of Writ of Mandamus to
ensure counsel?s access to the Manning Article 32 hearing. Specifically, Ms. Jennifer Robinson
and Center for Constitutional Rights attorney. Ms. Amanda Jacobsen, are attempting to gain
access to observe the proceedings. This Petition seeks counsel's access to the actual hearing
room in which the Manning proceedings are to take place.

Consistent with the rules of this Court, please immediater forward this Petition to the
Judge Advocate General. so to ensure that counsel?s rightful access to these proceedings is not
denied.

If you have any questions or concerns please do not hesitate to call me directly at 212-

Respectfully submitted.

Baher Azmy

cc: Mr. Julian Assange
Ms. Jennifer Robinson
Ms. Amanda Jacobsen
Clerk of Court. US. Army udiciary

new york, ny 10012
i; WEE-L i'l? 34.195}

:43?


EXHIBH

IN THE UNITED STATES ARMY
COURT OF CRIMINAL APPEALS


JULIAN ASSANGE and WIKILEAKS,

Petitioners, Docket No. ARMY

v. Article 32 Hearing in
. United States v. Manning,
UNITED STATES OF AMERICA and Ft. Meade, Maryland
LIEUTENANT COLONEL PAUL ALMANZA,
DATED: 15 December 2011

Respondents.

_wx

PETITION FOR.EKTRAORDINARY RELIEF IN THE NATURE OF WRITS
OF MENDAMUS AND PROHIBITION, OR, ALTERNATIVELY, APPLICATION

FOR STAY OF PROCEEDINGS, AND SUPPORTING MEMORANUM OF LAW

Petitioners Julian Assange and Wikileaks, by and through
their undersigned counsel, respectfully submit this request for
extraordinary relief, pursuant to the All Writs Act, 28 U.S.C.
1651(a1, Rules 2(b) and 20 of the Courts of Criminal Appeals
Rules of Practice and Procedure, and Rules 20.1 and 20.2 of the
0.8. Army Court of Criminal Appeals Rules.

Statement of the Case and Issues Presented

On November 28, 2010, the Wikileaks media organization and
its publisher Julian Assange commenced reporting on thousands of
allegedly classified and unclassified 0.8. State Department
diplomatic cables. The cables were also published by other
national and international media organizations, including The

New York Times, The Guardian, Der Spiegel, Le Monde, and El

HIV. BFCR. EXHIBII #5

Pals. To our knowledge, the U.S. government has never
officially confirmed or denied whether any of the cables are
indeed classified. However, the government has targeted and
threatened Mr. Assange, Wikileaks, and their supporters,
employees and contractors around the world with criminal
prosecution arising from their journalistic activities.

Although the U.S. government has never successfully
prosecuted anyone accused of soliciting or receiving allegedly
classified information, federal prosecutors have reportedly
convened a grand jury in the Eastern District of Virginia to
investigate whether Mr. Assange conspired with Army Private
Bradley Manning to violate the Espionage Act of 1917, 18 U.S.C.
793 et seq., and other federal laws. The grand jury
investigation conducted entirely in secret, without any
involvement permitted by defense counsel, and in a district with
the highest concentration of military and government jurors in
the United States so far has included the issuance of
subpoenas that reportedly name Mr. Assange, Wikileaks and
Private Manning. These production orders have been served in
relation to Wikileaks? supporters on media companies such as
Google and Twitter.

In addition, and of paramount importance here, Private
Manning was arrested in May 2010 in Iraq on suspicion that he

provided the diplomatic cables (and possibly other allegedly

m. urea. EXHIBIT #3

classified information) to Mr. Assange and/or Wikileaks.
Private Manning now faces the possibility of court?martial for
offenses including aiding the enemy in violation of Article 104
of the Uniform Code of Military Justice. These offenses are
serious but wholly unproven. There is strong evidence that
Private Manning has nonetheless suffered serious human rights
violations as a result of these unproven claims, including
prolonged isolation and sensory deprivation, and other torture
or cruel, inhuman and degrading treatment reminiscent of the
worst abuses at Guantanamo Bay. The U.S. government has notably
refused to allow the United Nations Special Rapporteur for
Torture to adequately assess Private Manning's treatment and
conditions.

It is in this context that Private Manning?s Article 32
hearing is scheduled to commence at Ft. Meade, Maryland, on
Friday, December 16, 2011. Notwithstanding the intense public
interest in this case, and Petitioners? obvious, unique interest
in these proceedings, as described below the limited procedures
established to allow public access to the proceedings are
plainly insufficient to ensure that Mr. Assange and Wikileaks,
by and through their counsel, are able fully and adequately to
observe the proceedings and safeguard their rights and
interests, as well as Private Manning?s legal and humanitarian

rights and the right of the public access to the proceedings.

to

NH. UFDH.

Indeed, Respondents have failed and refused to guaranty access
to Petitioners' counsel despite repeated communications and
requests via telephone, email and letter to the U.S. Army
District of Washington Public Affairs Office and officials at
Ft. Meade. See, Attachment (letter requesting access}.

Accordingly, the failure and refusal to respond to
Petitioners? request for guaranteed access to the Article 32
hearing in this case, and the lack of adequate capacity
otherwise to accommodate the media and other interested parties
such as Mr. Assange and Wikileaks, constitutes a constructive,
blanket denial of public access to the proceedings. Petitioners
thus request that the Court grant relief as follows.

Specific Relief Sought

l. Petitioners request a writ of mandamus to compel the
Investigating Officer assigned to preside over the Article 32
hearing in this case to provide and guaranty access for counsel
for Petitioners to the proceedings in their entirety.

2. Petitioners request a writ of prohibition to reverse
and undo the current procedures affording limited access to the
Article 32 hearing, which constitute a constructive, blanket
denial of the right of public access to the proceedings.

3. Alternatively, Petitioners request an order staying
the Article 32 hearing in order to allow the Court to consider

this Petition, and to allow Petitioners to seek any further

W. crzz. and.th #3

judicial relief which may be necessary to protect Petitioners'
rights and interests in these proceedings.
Reasons for Granting the Writs

The Court should grant the requested relief, pursuant to
the All Writs Act, 28 U.S.C. 1651(a), to open the proceedings
and ensure access for the public generally and for Mr. Assange
and Wikileaks specifically. Relief should be granted because
this matter involves exceptional circumstances warranting the
Court's intervention at this time, relief has been requested but
cannot be obtained in any other form or in any other court, and
issuance of the write will aid the Court?s jurisdiction.
Respondents? decision effectively to close the proceedings and
deny access to Petitioners, particularly given their unique
interest, is clearly erroneous and amounts to usurpation of
authority.

A. Eight of Public Access

The Court?s authority to act on the merits of this Petition
and grant relief is clear and indisputable. See Denver Post Co.
v. United States, Army Misc. 20041215 (A.C.C.A. 2005}, available
at 2005 CCA LEXIS 550 (exercising jurisdiction and granting writ
of mandamus to allow public access to Article 32 proceedings).
Equally established and uncontroversial is the right of public
access to judicial proceedings, including Article 32 hearings,

which may be overcome only on a ?case?hy?case, witness-by?



HIV. BFBR.

witness, and circumstance?by?circumstance basis." ABC, Inc. v.
Powell, 47 M.J. 363, 365 (C.A.A.F. 1997), available at 1997 CAAF
LEXIS 74. The right of public access is rooted in the common
law and the First Amendment to the United States Constitution.
See, Nixon v. warner Commc?ns, Inc., 435 U.S. 589, 59?
(1978); In re washington Post Co., 807 F.2d 383, 390 {4th Cir.
1986); washington Post Co. v. Robinson, 935 F.2d 282, 287 (D.C.
Cir. 1991).

The right of public access exists to ensure that courts
have a "measure of accountability" and to promote ?confidence in
the administration of justice." United States v. Amodeo, 71
F.3d 1044, 1048 {2d Cir. 1995). Access to information is
especially important when it concerns matters relating to
national defense and foreign relations, where public scrutiny is
the only effective restraint on government. See Maw York Times
v. United States, 403 U.S. 713, 728 (1971) (Stewart, J.,
concurring) (?In the absence of the governmental checks and
balances present in other areas of our national life, the only
effective restraint upon executive policy and power in the areas
of national defense and international affairs may lie in an
enlightened citizenry -- in an informed and critical public
opinion which alone can here protect the values of democratic





HIV. DFBR. EXHIBIT #3

The Supreme Court has repeatedly stated that openness has a
positive effect on the truth?determining function of
proceedings. See Gannett Co. V. DePasquale, 443 U.8. 368, 383
(1979) (?Openness in court proceedings may improve the quality
of testimony, induce unknown witnesses to come forward with
relevant testimony, cause all trial participants to perform
their duties more conscientiously"); Richmond Newspapers, Inc.
v. Virginia, 448 U.S. 555, 596 (1980) {open trials promote ?true
and accurate fact?finding") (Brennan, J., concurring); Globe
Newspaper Co. v. superior Court, 457 U.S. 596, 606 (1982)
("[P1ublic scrutiny enhances the quality and safeguards the
integrity of the factfinding see also Brown
Williamson Tobacco Corp. v. FTC, 710 F.2d 1165, 1179 {6th Cir.
1983) (Gannett's beneficial "fact?finding considerations"
militate in favor of openness "regardless of the type of
proceeding"). This effect is tangible, not speculative: the
Court has held that openness can affect outcome. Accordingly,
if the government attempts to restrict or deny the right of
access, it bears the burden of by showing that the limitation is
necessary to protect a compelling government interest and is
narrowly tailored to serve that interest. See, Robinson,
935 F.2d at 287.

In contravention of these authorities, Petitioners are

informed and believe that Respondents in this case have set

UH. Wald. ?Mall 33

aside only about eight seats in the Article 32 hearing room, for
members of the media selected by the U.S. Army District of
Washington Public Affairs Office, based on undisclosed criteria.
They also understand that a limited number of other members of
the media and the general public will be selected by lottery to
observe the proceedings in an overflow room via limited video
feed. These procedures are plainly insufficient to ensure that
Wikileaks and Mr. Assange, by and through their counsel, are
able fully and adequately to observe the proceedings and
safeguard their rights and interests.

B. Due Process Rights



These rights and interests of Mr. Assange and Wikileaks may
include, among others, their Fifth Amendment due process rights
and their Sixth Amendment interest in confronting any
allegations against them, particularly as relates to the grand
jury investigation in the Eastern District of Virginia, which is
apparently targeting Mr. Assange in connection with matters that
will likely be addressed at Private Manning?s Article 32
hearing. Access is also important to protect Private Manning's
legal right to a fair and impartial hearing, and his
humanitarian right to be free of torture and other unlawful
abuse, as well as the general right of public access to the

proceedings.

m. arm. EXHIBIT #5

As set forth above, Petitioners' unique interest in these
proceedings is obvious. If prior official statements relating
to Private Manning - both on and off the record - are to be
believed, it is nearly certain that allegations regarding Mr.
Assange and Wikileaks will be disclosed in these proceedings.
See, Ellen Nakashima Jerry Markon, WikiLeaks Founder
Could Be Charged Under Espionage Act, Wash. Post, Nov. 30, 2010
{quoting Attorney General Eric Holder and other government
sources); Charlie Savage, U.S. Tries to Build Case for
Conspiracy by Wikileaks, N.Y. Times, Dec. 15, 2010 (same).

Mr. Assange and Wikileaks need to know what those
allegations may include in order to ensure the proceedings are
as open, honest and transparent as possible. Consistent with
the factafinding purpose of open trials, which the Supreme Court
has held may affect their outcome, Petitioners? counsel must
have the ability to observe the proceedings in their entirety in
order to evaluate live witness testimony and other evidence as

it is presented. Counsel also must have access to the hearing



room (rather than the overflow room} so that they may object and
request permission to be heard if the Investigating Officer
determines that it may be necessary to close portions of the

hearing.1 Factual assertions made in these proceedings may well



1 To the extent that portions of the proceedings may be closed to
protect classified information, CCR requests that its attorneys
who already hold security clearances be allowed to observe the

9



L. HHIMT 3

be erroneous, and counsel for Wikileaks and Mr. Assange are in
the best position to evaluate them and correct the
record as may be necessary to prevent further substantial
prejudice to Private Manning, and to protect the interests of
Mr. Assange, Wikileaks and their supporters in connection with
these proceedings and other ongoing or possible future
proceedings here and abroad, including the grand jury
investigation and any threatened prosecution of Mr. Assange, as
well as any request for his extradition to the United States.
Transparency and accountability are especially important in
military proceedings such as these because "military trial
courts in our country are not standing or permanent courts," and
may be convened by various commanding officers without any
centralized oversight at the trial stage. See Eugene R. Fidell,
Accountability, Transparency Public Confidence in the

Administration of Military Jostice, 9 Green Bag 2d 361 (2006).



closed sessions on the ground that Wikileaks and Mr. Assange
plainly have a ?need to know" all information concerning them.
For example, it would be necessary for counsel to evaluate
whether information was improperly deemed classified in order to
conceal evidence of illegality or prevent embarrassment to the
ExeCutive Branch. At a minimum, the proceedings should be
delayed to permit a ?need to know" determination to be made by
the relevant agencies and reviewed by the courts.

10

Wu ..F #3

Conclusion
For these reasons, the Petition should be granted.

Date: New York, New York
December 15, 2011

Respectfully submitted,

Xs/ Baher Azmy

Vincent Warren, Executive Director
Baher Azmy, Legal Director

Michael Ratner, President Emeritus
CENTER FOR CONSTITUTIONAL RIGHTS
666 Broadway, 1th Floor

New York, New York 10012

Tel: (212) 614?6464

Fax: {212) 614?6499

Counsel for Julian Assange
and Wikileaksa



2 Petitioners' counsel are not admitted to practice before the
Court and therefore request permission, pursuant to Rule 8(c) of
the Courts of Criminal Appeals Rules of Practice and Procedure,
to appear pro hac vice for the limited purpose of litigating
this Petition. Good cause exists to grant this request given
the emergency nature of the relief requested and the serious
nature of the issues at stake in this case. Counsel are members
in good standing of the bar in New York State, and are admitted
to practice before various federal courts.

i_l


HIV. BFCR. EXHIBIT 3

Certificate of Service



I hereby certify on this 15th day of December 2011, I

caused the foregoing Petition for Extraordinary Relief to be

and

filed with the Court, via facsimile and overnight mail,

served on Respondents, via overnight mail, at the following

addresses:

U.S. Army Court of Criminal Appeals
Office of the Clerk of Court

9275 Gunston Road
Fort Belvoir, VA
Fax: 703?806?0124

22060-5546

- and

Clerk of Court

U.S. Army Judiciary
901 North Stuart Street,
Arlington, VA 22203?1837
Fax: 703?696?8777


Suite 1200

and

Lt. Col. Paul Almanza

U.S. Army Reserve Judge

150th Legal Support Organization
Ft. Meade, MD 20755

Eaher Azmy

IHV. UFBR.



Exhibit A

4135-}

s.

centeriorconstitutionalright 5
December 13. 20! I

Via Federal E_xpress

Investigating Of?cer

cfo Military District of Washington
Public Affairs Office

103 Third Avenue

Washington. DC. 20319

Re: United States Bradley ill-fanning
Dear Sir:

The Center for Constitutional Rights represents the Wikileaks media organization and
its publisher Julian Assange regarding access to the Article 32 proceedings in United States v. Bradley
Manning. scheduled to begin at Fort Meade. Maryland. on December 16. 201 I. We request that you
allocate two seats in the hearing room. for a CCR attorney and for Mr. Assange?s non?U.S. counsel
Jennifer Robinson. so that they may observe the proceedings on behalf of our clients.

We understand from telephone calls and written communications with the U.S. Army District
of Washington Public Affairs Of?ce and officials at Fort Meade that only about eight seats in the
hearing room will be set aside for members of the media selected by the Public Affairs Office. We
also understand that a limited number of other members of the media and the general public will be.
selected by lottery to observe the proceedings in an over?ow room via limited video feed. These
procedures are plainly insufficient to ensure that Wikileaks and Mr. Assange. by and through their
counsel. are able fully and adequately to observe the proceedings and safeguard their rights and
interests. including under the Fifth and Sixth Amendments to the Constitution. as well as Private
Bradley Manning?s legal and humanitarian rights and the right of public access to the proceedings.

Our clients? unique interest in these proceedings is obvious. For more than a year. there has
been intense worldwide speculation that hundreds of thousands of allegedly classi?ed diplomatic
cables published by Wikileaks as well as The New York Times. The Guardian, and other international
media organizations - were provided to Wikileaks and Mr. Assange by Private Manning. There is
strong evidence that Private Manning has suffered serious human rights violations as a result of those
unproven claims. including prolonged isolation and sensory deprivation, and other torture or cruel.
inhuman and degrading treatment reminiscent of the worst abuses at Guantanamo Bay. (Throughout
all of his detention. the US. government has refused to allow the United Nations Special Rapporteur
for Torture to adequately assess Private Manning?s treatment and conditions.) If prior of?cial
statements relating to Private Manning are to be believed. it is nearly certain that allegations regarding
Wikileaks and Mr. Assange will be disclosed in these proceedings.

1st. arcs. Etaiazt #3
98M

Mr. Assange and Wikileaks need to know what those allegations may include in order to ensure
the proceedings are as open. honest and transparent as possible. Their counsel must have the ability to
observe the proceedings in their entirety in order to evaluate live witness testimony and other evidence
as it is presented.? Factual assertions made in these proceedings may well be erroneous. and counsel
for Wikileaks and Mr. Assange are in the best position to evaluate them and correct the
record as may be necessary to prevent further substantial prejudice to Private Manning. and to protect
the interests of Mr. Assange. Wikileaks and their supporters in connection with these proceedings and
other ongoing or possible future proceedings here and abroad. Transparency and accountability are
especially important in military proceedings such as these because ?military trial courts in our country
are not standing or permanent courts." and may be convened by various commanding of?cers without
any centralized oversight at the trial stage. See Eugene R. Fidel]. Accountability-t Transparent?
Public Confidence in the Adminisrrm?ion of Military Justice. 9 Green Bag 2d 36] (2006).

Mr. Assange also notably has a particular personal interest in the Article 32 proceedings
because it appears that federal prosecutors in the Eastern District of Virginia have been issuing
subpoenas to supporters of Wikileaks in order to investigate matters that. based on prior of?cial
statements. will likely be addressed in Private Manning?s Article 32 proceedings. It has been reported
that these subpoenas are the result of a grand jury process that has. as is the norm in the United States.
taken place entirely in secret without any involvement permitted by defense counsel. in a district that
has the highest concentration of military and governmentjurors in the nation. The names of Mr.
Assange. Wikileaks. and Private Manning reportedly appear on many of the production orders coming
out of this grand jury process that have been sort ed in relation to Wikilcaks' supporters on companies
such as Google and Twitter.

Moreover. guaranteed access for media organization such as Wikileaks and its publisher Mr.
Assange is necessary to ensure public access to the proceedings. which is protected at common law
and by the First Amendment to the Constitution. Indeed. given the intense public interest in this case.
we are concerned that the lack of adequate capacity to accommodate the media and other interested
parties such as Wikileaks and Mr. Assange may result in a constructive. blanket denial of public access
to the proceedings. See Denver Post Co. v. United States. Army Misc. 2004135 (A.C.C.A. 2005),
mtailable or 2005 CCA LEXIS 550 (granting writ of mandamus to allow public access to Article 32
proceedings).

in sum. counsel for Mr. Assange and Wikileaks have a professional duty of care which must be
exercised not only for the bene?t of our clients but also for others whose life or liberty is at risk.
including alleged sources such as Private Manning as well as WikiLeaks supporters. employees and
contractors who have been subject to US. government surveillance in relation to their constitutionally
protected activities. We hope that you will approve our request for guaranteed access to these Article
32 proceedings. We further ask for your response by no later than the close of business on



To the extent that portions of the proceedings may be closed to protect classi?ed information. CCR requests that
its attorneys who already hold security clearances be allowed to observe the closed sessions on the ground that Wikileaks
and Mr. Assange plainly have a ?need to know" all information concerning them, For example. it would be necessary for
counsel to evaluate whether information was improperly deemed classi?ed in order to conceal evidence ofillegality or
prevent embarrassment to the Executive Branch. A: a minimum. the proceedings should be delayed to permit a ?need to
know? determination to be made by the relevant agencies and reviewed by the courts.

l-J

#3

Wednesday, December 14. 201 1. so that we may seek any relief which may be necessary in court. Mr.

Azmy, legal director. may be reached by phone at -

Very truly yours.

Baher Azmy
Vince. Warren
Michael Ratner
cc: Jennifer Robinson
Convening Authority

Exmattr?
?78m,

Exhibit Offered But Not
Considered

Investigating Officer Exhibi

IN THE UNITED STATES ARMY

FIRST JUDICIAL CIRCUIT

UNITED STATES

SEALED DEFENSE STIPULATION
v. 0F EXPECTED TESTIMONY


MANNING, Bradley 13., PFC
U.S. Anny.
Headquarters and Headquarters Company, US.
Army Garrison, Joint Base Myer-Henderson Hall, DATED 17 December 2011
Fort Myer, VA 222! I

1. Pursuant to Rule for Courts-Martial (R.C.M.) 1103A the defense ?les this sealed stipulation
of expected testimony under R.C.M. It is hereby stipulated by the Defense,
with the express consent of PFC Bradley E. Manning, the Accused, that if Ms. Jihrleah W.
Showman were asked at this Article 32 hearing, she would testify the following:

In the July or August 2009 timeframe, 1 was verbally counseling PFC Manning. During the
counseling session, PFC Manning was not paying attention to me. I could tell by his body
language that he seemed disinterested. I then raised my voice to get his attention. I asked in
why did he join the United States Army. He told me that he joined the military for the
educational bene?ts. I then tapped the flag on my shoulder and then said what does this flag
mean to you. PFC Manning told me the ?ag meant nothing to him and that he belonged to no
people. He then said he had no allegiance to this country. I became very upset at this point with
him. I told SFC Adkins about this statements by PFC Manning and said that PFC Manning
needed to be taken to mental health.

2. The defense offers this stipulation in order to avoid having to elicit this testimony from Ms.
Showman or from any other individual in open court. The defense requests that the Investigating
Of?cer direct the government not to elicit this testimony from Ms. Showman or any other
witnesses. The defense further requests that the Investigating Of?cer direct the government to
refer to this testimony as Testimony during its argument.

,7 we" .
If.?
gas-r3131 s. oh?vm
PFC, U.S. Army Civilian Defense Counsel
Accused

EFCE.
(D)

Closed Hearing Checklist



All spectators have been cleared out of the courtroom. ,jfi/?



Ail remaining personnel possess a valid, SJA issued security badge. 0 I
r?x



.
Guards are posted outside courtroom entrances.



I I . . .
Classified recording equrpment IS In place.









I
Audio and video feed to the M00 and the theater has been severed.



Time 2255? Date ia/xeg?ex/





HIV. DFCR. 5

w/ ENMOSURE)

DEPARTMENT OF THE ARMY
us- new murmur or wasnmeron
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REPLY TO
sum OF



15 December 2011

MEMORANDUM FOR LTC Paul Almanaa, 150th Judge Advocate General Detachment, Legal
Support Organization, MG Albert C- Lieber USAR Center, 6901 Telegraph Road, Alexandria,
VA 22310

SUBJECT: Request for a CloSed Session of the Article 32 Investigation United States v. PFC
Bradley Manning

1. The United States requests you close the Article 32 investigation so that you may hear
testimony relating to the following classi?ed evidence:

a. Speci?cation 3 of Charge 11 (BATES 00378084 - 00378086 00378087 - 00378090).
The existence of these underlying documents is classi?ed and open testimony about these
documents is classi?ed. See Enclosure.

b. Speci?c Testimony of SA David Shaver. SA Shaver will testify to the manner and
method the accused allegedly used to access BATES 00378084 00378086 8: 00378087 -
00378090 and provide them to a person or persons not entitled to receive them.

2. The United States requests this closed session, and deems it necessary based on the following
facts:

at The documents are properly classi?ed;
b. Protecting this classi?ed information from public disclosure is an overriding interest;

c. The overriding interest of protecting this classi?ed information outweighs the value of an
open proceeding; and

d. The United States considered other methods of protecting the information. but no lesser
methods short of closing the proceeding can be used to protect that interest and adequately
present evidence on the relevant charge and speci?cation.



I
5.

Encl assess

as CPT. A
Trial Counsel

UNCLASSIFIED w/ ENCLOSURE)

OFCR. (.0

Open Hearing Checklist







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Secured all classified material from the TC.




Secured all classified material from the DC.



Secured all classified material from the IQ.




The courtroom safe is locked.









Unclassified recording equipment is in place. 0;



Time Date /8 Dec: Jo





41w. EXHIBH in?

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All spectators have been cleared out of the courtroom.



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Audio and video feed to the M00 and the theater has been severed.






04/





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0n 51?193?16 5:59 E5. Bradley Fanning wrote:

A ms: the saute: 05 up: l' 351?. f1? vise?s iron: tin} Agatha Bazaar-.3 Enema.
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You can currently contact our investigations editer directly in Iceland +354 862 3481 24 hour
service; ask for "Julian Aesange".

SEER, EXHIBIT 1(2)
pg (5, (P)

ManningB_004 09 721

1 Criminal Event



Kidnapping
Loo?ng
Murder
Smuggling

2 Enemy Action



Ambush
Assassination
Direct Fire
Indirect Fire
Raid

SAFIRE
Sniper Ops

3 Explosive Hazard




1
2
3
4
5
6

Explosion

Found I Cleared
Hoax

Suspected
Interdiction
Unexploded Ordnance

riendly Action

Cache Found I Cleared
Close Air Support
Cordon Search
Escalation of Force
Other

Raid

5 Friendly Fire

1

2
3
4

Blue-Blue
Blue-Green
Green-Blue
Green-Green

6 Non-Combat Event

ManningB_DD4DQ?1 9

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TASK: Acquire and exfiitrate gioba1 Address List From United States
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PURPOSE: To e?mai1 ciassified messages from CIDNE event leg
from 2004 to 2009.
METHOD: Acquire document
ENDSTATE:
TARGET: United States Forces - Iraq 0ut1ook Sharepoint Exchange Server
OBJECTIVE:

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You are accessing a US. Government Information System that is
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routinely intercepts and monitors communications on this i3 for purposes
gincluding, but not limited to, penetration testing, CDMSEC, monitoring, network
operations and defense, personnel misconduct law enforcement 1, and
Ecounterinteiligence [Cl] investigations. At any time, the USE may inspect and
seize data stored on this IS. Communications using, or data stored on, this IS are

i not private, are subiect to routine monitoring, interception and search, and may be
disclosed or used for any USE authorized purpose. This IS inciudes security
measures authentication and access controls] to protect USE interests-not

for your personal benefit or privacy. Notwithstanding the above, using this IS does
2 not constitute consent to PM, LE, or Cl investigative searching or monitoring of
the contect of priviledged communications, or work product, related to personal
representation or services by attorneys, or clergy, and their
iassistants. Such communications and work product are private and confidential.
See User Agreement or details.



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UFCR. HLP)
pg, .2 of- 35

CURRENT NEWS



EARLY BIRD
March 18,2010

Use of these news items does not re?ect of?cial endorsement.
Reproduction for private use or gain is subject to original copyright restrictions.
Item numbers indicate order of appearance only.



AFGHANISTAN

l.

Taliban Hit Back In Maria With A Campaign Intimidation

[New York Nordland

The Taliban have begun waging a campaign of intimidation in Marja that some local Afghan leaders worry has
jeopardized the success of an American-led offensive there meant as an early test of a revised military approach in
Afghanistan.

Taliban sin or In attl 1- Mar at:

(Philadelphia Inquirer). . . . Heidi Vogt. Associated Press

A month after losing control of its southern base in Marjah. the Taliban has begun to ?ght back. launching a
campaign of assassination and intimidation to frighten people from supporting the United States and its Afghan
allies.

3. ik aidT KilALeadr I a a
(New York Times).. ..David E. Sanger
A strike by an unmanned drone last Week killed a senior commander of Al Qacda who had played a significant role
in planning the killing of Central Intelligence Agency operatives in late December at a base in Afghanistan.
according to American of?cials.

4. ttacks ar'ln In
Washington Whitlock
Taliban ?ghters more than doubled the number of homemade bombs they used against US. and NATO forces in
Afghanistan last year. relying on explosives that are often far more primitive than the ones used in Iraq.

5. ah
H. MeMiehael
Efforts to lay political and security groundwork in the Taliban stronghold of Kandahar have already begun. even as
the U.S.-led coalition continues efforts to pacify Marjah, the U.S. general leading the effort said Wednesdayraft
(Renters. com) . . . . Peter Gram Reuters
One of the most important trade routes in Asia was closed last week while a boyish-looking man everyone calls "the
general" shoWed around the commander of US. and NATO forces in Afghanistan.

Afghan Dent
(Phifodefpfiio fnqnireri . . . . Associated Press
The United States has reached an agreement with other countries to cancel $1.6 billion in debt owed by Afghanistan
to creditor nations and international lending organizations.

TE ROR I SM

m. urea. imp-)

- FT
ManningB_DD409686 _3 (Jr

page I
ll. lADir rn Atta HaeHhie l-a a
(Washington Warriclr and Peter Finn
Aggressive attacks against al-Qaeda in Pakistanls tribal region have driven Osarna bin Laden and his top deputies
deeper into hiding and disrupted their ability to plan sophisticated operations. CIA Director Leon Panetta said
Wednesday.

Milita - a] ti i

WashingtonpostxoW..?Anne Flaherty. Associated Press

The top U.S. commander in Afghanistan said Wednesday that it remains the goal of U.S. troops to capture Usama
bin Laden alive and "bring him to justicer?Warn
(Christian Science Monitor Richey
The United States faces an expanding array of AI Qacda-related threats that extend far beyond the lawless regions of
southwest Asia and into the US itself via radical Islamist websites. FBI Director Robert Mueller told a House
Appropriations subcommittee on Wednesday.

IRAQ

ll. Irrain tri Aw: i
{Lost Angela's Parker
With more than 86% of the votes tallied in Iraq?s parliamentary elections and the race still neck and neck, hopes that
the country might move beyond its deep Shiite-Sunni divide appear to be fading in a slew of sectarian politics.

12. Vote Accentuate-s Iraq's Deep Splits
(Washington Fade]
The emerging results from last week's parliamentary elections have made clear that Iraq remains a dangerously
polarized nation, with deep regional and sectarian schisms that could widen as the us. military draws down

CONGRESS

i3. Turns Up Heat 0n Earmarks, Pentagon
(St. Louis Post-Dispatchin?ill Lamhrecht
Sen. Claire MeCasltill is pressing the Pentagon to release records on billions of dollars in defense projects aivarded
through congressional earmarks. part of a growing move to restrict lawmakers' practice of directing expensive
projects back home to their districts and states.

l4. 2 ad?! a As Hill Ba I: 2 Herb
(Defense Rutherford
Navy Secretary Ray Mabus said yesterday the service is keeping a mid-April deadline for industry bids on the
Littoral Combat Ship (LCSL amid concerns about the losing shipbuildcr protesting the contract award and a call
from one side to delay the schedule

15. ?pth sides To Tgs?? ?gy Ban Hearing
H. MeMiehael

Thursday?s Senate Armed Services Committee hearing on the ?don?t ask. don't tell" policy that bars open service by
gays the second in six weeks will feature three outside witnesses who are all former commissioned of?cers.

lti. hall :1 es :1 tract-In
.. ..Antonic Boessenkool
The Pentagon has made major improvements in how it contracts for "contingency" operations in Iraq and
Afghanistan for jobs such as food service, laundry. construction, security. translators and logistics, but challenges
remain. Pentagon and Government Accountability Of?ce officials told Congress members March

IT. oat 3 id Wi I
Matthews
Okay, everyone agrees - the cost of' solid rocket motors is going up. The question is how much. Sen. David Vitrer.
insisted again March that the cost of solid rocket motors that the .5. military needs for its intercontinental
ballistic missiles will double Barack Obama gets his way.

(in. arcs. into)
Lioi 35 -

ManningB_0040963?

page 3
IR. rs noel ht fsWamA ain Bo se.
Maze
Despite meeting all recruiting and retention goals. the service personnel chiefs pleaded with a House panel
Wednesday to keep paying enlistment and selective bonuses.

DEFENSE DEPARTMENT

l9. ?guraan Sges A Threat inige
(New York Strom

To the list of the enemies threatening the security of the United Statcs. the Pentagon has added WikiLcaks.org. a tiny
online source of information and documents that governments and corporations around the world would prefer to
keep secret.

2t]. -
{San Antonio Contreras
As he bats down allegations that he ran an DfT-thc-boolts spy operation in Afghanistan and Pakistan. a civilian
Defense Department of?cial has been locked out ofhis of?ce at Lackland AFB and remains cautious about who
visits him at his San Antonio apartment.

21. a l' lnTheD a
(European Stars and Patton
As millions of Americans scramble to make last-minute adjustments to their NCAA tournament brackets, the
Defense Department is playing the role of bracket buster before the tournament even tips off Thursday.

22. To Battle Qnmgutcr Hackers. The Pentagon Trains (hm
Thompson
After years of building ?rewalls and other defenses against relentless hacker attacks. the Pentagon is going over to
the dark side of computer warfare. Only ethically, of course. The Defense Department. like most large organizations,
has recognized that no wall is high enough to keep out skilled and determined hackers for keeps. Instead. it has
decided that in order to anticipate and thwart those attacks. it needs to know what the hackch lmow.



PAKISTAN

23. Ll!" .I
(New York aqar Liillani and ack Healy
Five young American Muslims detained in Pakistan in December on suspicion of seeking to join jihadists in
Afghanistan were formally charged Wednesday, in a case that added to fears that Westerners might increasingly be
taming to lslamist-inspired terrorism5T0 all
(Renters. Entous. Reuters
U.S. investigators have recently been given more regular direct access to Pakistani-ch interrogations of the Afghan
Taliban?s No. 2 leader. US. of?cials said on Wednesday. one month after his arrest was announced.

ASIAIPACIFIC

25.
{Washington services
Officials in the impoverished Central Asian nation of said the United States plans to build a $5 million
military base fer training local troops. already hosts a LLS. base in Manes. outside the capital. Bishkek.
which is used as a regional hub for the U.S.-led war in nearby Afghanistan. The government last year backed
offa threat to evtct US. forces from Mamas a?er Washington offered to triple its rent.









26. H3.
tDefemeNen-w. mm)" . . Shaun Tendon. Agenec

The United States said March 1? that it needs to maintain a base on the Japanese island of Okinawa to defend the
region. as the new in Tokyo considers scrapping a previous plan.




I



w.

A

ManningB_OO409683 of- 35

page 4
Kim. Reuters
North Korea has increased its missile arsenal by 25 percent in the past two years to about LOUD. expanding the threat
the state poses to the region. the South's defense chief said Wednesday.

28. long-? ms Years Lgft?
{Korea Herald). . .. Kim Sovhyun
North Korean leader Kim .loug-il. whose questionable health has received international attention. appears to have

three years left to liver a senior U.S. of?cial was quoted as saying.

EUROPE

29. s'nLae nr tl
(New York
With the United States and Russia still haggling over the ?ne print of a long-delayed arms control pact, Secretary of
State Hillary Rodham Clinton Ie? Washington on Wednesday for high- level meetings in Moscow, as the Dbama
administration tried to push the talks across the ?nish line.

30. ykrsine: Venue Offered For Arms Talks

(New York E. Kramer
Ukraine?s new president, Viktor F. Yanukovich. has o?crod Kiev as a location for the United States and Russia to

sign a revamped nuclear arms reduction u'eaty, once it has been agreed to.

Ml DEAST
31. Obama Says To Pu rsue Aggressive Iran Sanctions

(Reuters. Mason and Deborah Charles, Reuters
President Barack Ubama said on Wednesday the United States would pursue "aggressive sanctions" to prevent lran
from getting a nuclear weapon that could potentially spark a nuclear arms race in the Middle East.

AMERICAS

32. linton ales To Mexi uT TalkAbout Dr Fl

. Deborah Charles. Reuters
US. Secretary of State Hillary Clinton will lead a top-level delegation to Mexico on March 23 to discuss efforts to

?ght drug cartels, I0 days after three people linked to a US. consulate were killcd in a border city.

AIR FORCE

33. Matthew

Chen-y. John Roberts
For nine years. she kept a secret. Jene Newsome didn?t tell anyone in the Air Force she was a lesbian. Then just as

momentum was building to repeal the military's "Don?t Asia Don't Tell" policy. was outed by a third party. It
was actually her local police department in South Dakota a?cr they saw an Iowa marriage certi?cate in her home.

NATIONAL SECURITY

34. Inside The Rio
Washington Gert:

coining; Conventional vs. nuke; Antiomilitary fatwa.

PIRACY

35. a P'ral or i
(London Times}. . . . Foreign Staff
Dutch Marines fought off an ill-advised attempt by pirates to hijack the warship Trump off the coast of Somalia

yesterday.

ManningB_00409689



page 5

MILITARY

36. Making A
O?Neil
We?re back with our ?Making A Di report tonight. It's about a military tradition in this country dating back
to the time of the cavalry, using a horse-drawn hearse -- a caisson -- at military funerals.

3 7.
(New York Winter
Sheng, a photographer. had ?nished the ?rst phase ot'?Don?t Ask. Don?t Tell," a series of portraits of gay men
and lesbians serving in the military. all of them in uniform and with their faces obscured in some way by a hand. a
door frame or by darkness.

VETERANS

38.
Washington Post). . . Associated Press
VA medical centers need to Speed up compensation and pension medical exams to veterans so that it can expedite
disability claims, the department's inspector general reported Wednesday.

39. iath Wat(New York Thomas
journey to the Paralympies began in 2005. Two months after he was deployed to Afghanistan with the
Army, an explosive device went offender the truck in which he was riding. Both of his legs were later amputated
above the knee. While recovering at Brooke Army Medical Center in San Antonio. Soulc threw himself into
athletics. sampling sports like fencing and sitting volleyball.

BUSINESS

40. Al 2 Pr i Deal
(Washington Port).. .. News
The Air Force said it will request $6.5 billion. or foot years of funding, for a Lockheed Martin military
communications program that plans to launch its ?rst satellite in September after six years of delays. The funding
request for ?scal years an 2-2015. part of a $9.9 billion program. suggests that delays and technical problems have
been worked out.

hr 2 ALin In a Tanker Price
(The Tiron
Northrop Grumman?s announcement backing out of the competition for the Air Force's $35 billion refueling aircra?
contract included a ?nal parting shot at main rival Boeing.

42. in [ed 1* Amid
(Defense Malenic
A top Boeing of?cial said yesterday that the company will provide the Defense Department thorough pricing data
should it be chosen to provide the Air Force with a replacement ?eet for its aging KC- 35 tanker aircraft.

43. ?ngering
(Aerospace Dniiv d?c De?nite Re;mrti..
Lockheed Martin?s ?rst F-3SB {Stovl} aircraft demonstrated the capability to
hover freer March 17 during a test ?ight at Naval Air Station Patuxent River, Md.

OPINION

44. ure' i
(Washington Post}. David Ignatius
The headline read like something you might see in the conspiracy-minded Pakistani press: "Contractors Tied to
Effort to Track and Kill Militants." But the story appeared in Monday?s New York Times. and it hi some
big problems that have developed in the murky at between military and intelligence activities.

ManningB_00409690

page (1

45. A Politically Feasible ,lgt
{New l?ork
There has been yet another setback in the Air Force?s long. agonizing process to replace its fleet of Eisenhower-era
aerial refueling planes. Northrop Grumman and its European partnerT the European Aeronautic Defense and Space
Company. dropped out of the competition this month. charging that the new contract speci?cations are tilted against

their much larger Airbus A330 in favor of Boeing?s 76?.

CORRECTIONS

46. Cogection
Washington Washington Post
A March [7 Economy Business article, about accusations in Europe that the Pentagon altered speci?cations for a

new refueling tanker plane to favor Boeing in its competition for the contract against a consortium that includes
Europe's Airbus. incorrectly referred to the Boeing 763' as new. The jettincr. a military version of which is a
contender for the contract, has been in service since [982.

Hill. BFCR.
.13 Bd?

ManningB_00409691

New York Times

March Ill. Bill!)

Pg.

l. Taliban Hit Back In
Marja With A
Campaign 01'
Intimidation

By Rod Nordland

KABUL. Afghanistan
The Taliban have begun
waging a campaign of
intimidation in Marja that some
local Afghan leaders worry has
jeopardized the success of an
American-led offensive there
meant as an early test of a
revised military approach in
Afghanistan.

The Taliban tactics have
included at least one beheading
in a broader effort to terrorize
residents and undermine what
military of?cials have said is
the most important aim of the
offensive: the attempt to
establish a strong local
government that can restore
services. The offensive ousted
the Taliban from control of
their last population center in
southern Helmand Provinec.
but maintaining control over
such territory has proved
elusive in the past.

Though Marja has an
occupation force numbering
more than one coalition soldier
or police of?cer for every eight
residents, Taliban agitators
have been able to wage an
underground campaign of
subversion, which residents say
has in the past two
weeks.

?After dark the city is like
the kingdom of the Taliban."
said a tribal elder living in
Marja. who spoke on the
condition of anonymity out of
fear of the Taliban. ?The
government and international
forces cannot defend anyone
even one kilometer from their
bases."

The new governor of
Marja. Haji Abdul Zahir. said
the militants were now holding
meetings in randomly selected
homes roughly every other
night. gathering residents
together and demanding that
they turn over the names of
anyone cooperating with the

ManningB_00409692

authorities.

Mr. Zahir said the Taliban
also regularly issued ?night
letters." posted at mosques or
on utility poles. warning
against such collaboration. and
o?cn intimidated residents into
providing them with shelter
and food, even in densely
populated neighborhoods of
the city. which has a
population of 30,000.

"They are threatening and
intimidating these people who
are cooperating." he said in a
telephone interview. ?They
have been involved in the area
for a long time and they know
how to intimidate people. They
threaten them with beheadings.
cutting off hands and feet, all
the things they did when they
were the government.?

More than 6.000 American
soldiers, Marines and British
soldiers fought their way into
Marja beginning Feb. 13. along
with thousands of Afghan
troops and police of?cers.
Many others have reinforced
the occupatirm since to protect
an in?ux of Afghan of?cials
and Western experts to build
an effective government in
Marja. That effort to win own
the local populace is at the
heart of the American and
Afghan government strategy.
and NATO officials have said
it is proceeding well.

Journalists have still not
been allowed to visit Marja
independently. however: they
must be embedded with the
American military. Marja is
meant to be a template for a
similar campaign aimed for
spring in neighboring
Kandahar Province. the
Taliban's heartland.

NATO and Marine Corps
spokesmen did not
immediately respond to
requests for comment on the
situation in Marja.

Mr. Zahir said it was
dif?cult for the authorities to
counter the Talibanis campaign
because the militants were
mostly moving around without
guns. relying on fear rather
than threats. ?If they are
detained. they claim they are
just ordinary citizens." he said.

?At the same time. they still
have a lot of sympathy among
the people."

He said it was impossible
to estimate how many Taliban
?ghters remained in the city.
?It?s like an ant hole." he said.
?When you look into an ant
hole. who knows how many
ants there are??

The tribal elder declared
that in his area. called Block S.
the Taliban had complete
freedom of movement after
dark. He said he believed that
was true in many other parts of
the city as well. He and the
governor were among ?ve
community leaders in Marja
who expressed similar
concerns about the Taliban
intimidation campaign.

On March 10. the elder
said. a resident of the same
area named Nissar Ahmad. 25.
was abducted from his home
and beheaded. and his body
was dumped at night next to
the main local school. where
residents would be certain to
see it in the morning.

saw his body myself.?
the elder said. adding that he
had heard of other beheadings.
Mr. Ahmad had previously
been a Taliban supporter but
had switched allegiance after
the city fell. the elder said.

Mr. Zahir dismissed
reports of beheadings as
rumors. Mr. Ahmad. he

maintained. was killed as the
result of a personal dispute.
However. he said there had
been Taliban beatings.
including that of a teacher at a
new school who was severely
beaten on Tuesday.

Walid Jan Sabir. the
Afghan member of Parliament
for Marja and the surrounding
Nad Ali District. said he had
heard reports from Marja
elders visiting his of?ce in
Kabul this week of two
bclreadings of pro-government
elders. both members of the
govemment's Community
Development Council.

MI. Sabir scoffed at Mr.
Zahir's denial of beheadings.
saying. ?He is not from the
area and he is only staying in
his of?ce so he doesn?t know

Hit. arcs.

page 7
what is happening." Mr. Zahir
lived for many years in
Germany. where court of?cials
said he was jailed for stabbing
a stepson. Mr. Zahir has denied
that.

A spokesman for the
Interior Ministry. Zemarai
Bashary. said the police in
Marja had been told to
investigate the beheading
reports.

?We don?t know ifit's one
person or many cases and
many persons. but We are
investigating and we will soon
have an answer." he said.

The Marja elder also said
there were many accounts of
the Taliban's forcing residents
to attend night meetings where
they threatened retaliation
against anyone cooperating
with the government or NATO
and wamed that anyone who
took even a low-paying
government job would have his
earnings con?scated. Mr. Zahir
said there were many accounts
of such con?scations from new
employees in government work

programs.
The elder said most people
in Marja supported the

government?s efforts to restore
control. but most were also
afraid to challenge the Taliban.

"I'm not saying the
Taliban will win this war." he
said. ?If the government
strengthens their positions and
creates small bases all over
town close to one another and
then permanently patrols
between these bases. they can
get rid of the Taliban."

Mr. Sabir Was critical of
American and Afghan forces
for surrendering the night. ?At
night the local people are the
hostages of the Taliban." he
said. Since many tribal leaders
have fled out of fear. and many
of the Afghan of?cials coming
in now are not from Marja. it is
dif?cult for them to know who
the Taliban activists are.

?The Taliban and the
Marja residents all have boards
and turbans so it's impossible
to distinguish them." he said.
?If it goes on like this I?m sure
the situation will deteriorate
and we'll ?nd it?s chaos there

99 Ci of

or




again."

Sanger Rohimi contributed
reporting ??om Kobui. and on
employee of The New York
Helmand Province.



Philadelphia Inquirer

March 18.

2. Taliban Using Fear In
The Battle For Marjah

US. troops counter with
dmiomaty and development.
but my quick action is key.
By Heidi Vogt, Associated
Press

MARJAH. Afghanistan --
A month after losing control of
its southern base in Marjah. the
Taliban has begun to ?ght
back. launching a campaign of
assassination and intimidation
to frighten people from
supporting the United States
and its Afghan allies.

At least one alleged
govemment sympathizer has
been beheaded. There are
rumors that others have been
killed. Afghans in the town that
Afghan. and NATO
troops captured in a [lune-week
assault that began Feb. 13
awake to letters posted on their
doors Warning against helping
the troops.

The new governor of
Mar-jab. Abdul Zahir, said the
Taliban was now holding
meetings in randomly selected
homes roughly every other
night, gathering residents and
demanding they turn over the
names of anyone cooperating
with the authorities.

Winning public support in
this former Taliban stronghold
in Holmand province 360 miles

southwest of Kabul is
considered essential to
preventing insurgents from
returning.

Military commanders

believe the Taliban campaign
is achieving some success
because of questions raised at
town meetings: Do the 1.1.5.
forces want to shut down the
mosques and ban prayer? Will
they use lookout posts on their
bases to ogle women? Are they
going to take farmers? land
astray??

"Dislocating the insurgents

physically was easy." said Lt.

Col. lc?' Rule. head of
operations for Marines in
Helmand. "Dislocating them

socially - proving that we're
here to stay and to help - is a
lot harder."

There are no ?rm ?gures
on how many Taliban ?ghters
are left in Marjah. Marine and
Afghan of?cials say they
believe that most of those still
here are from the area and that
the foreign ?ghters have ?ed.

Regardless of Taliban
numbers. their in?uence is still
felt. New cell-phone towers
brought phone service to
Marjah a little more than a
week ago. But the service
doesn't work at night because
the Taliban threatens or bribes
tower operators to shut off the
network. presumably to
prevent people from alerting
troops as extremists plant
bombs after dark.

Some of the Workers on
canal-clearing projects have
been threatened or have been
beaten up by insurgents.

At least one canal worker
who received threats returned
and said he would keep
working despite the risk. said
Maj. David Fennell. who
oversees about 15 civil affairs
troops. "That's when you know
that you fought the Taliban and
you won." said.

This is the struggle for
Matjah now: winning people
over with ajob or a vaccination
for a child. The victories are
small because the Taliban
already proved it can make
good on its promises by
enforcing harsh justice while in
power.

"My sense is that the
Taliban will rein?ltrate in due
course as the Afghan
government fails to live up to
the modest expectations NATO
has of it." said
Patterson. a former UN.
political?atTairs expert in
Afghanistan. "1 do not think
that the Taliban have been
weakened in Helmand by the
loss of Marjah."

Many of the estimated
R0300 people here share the

same fears. even though there

are about 4.000 NATO and
Afghan troops in and around
Marjah. Some say they are
afraid to take money from the
military bccatIsc if the Taliban
?nd them with the cash. they
will be punished.

The Marines are trying to
win partly through diplomacy
and partly through getting
development and infrastructure
projects running as quickly as
possible. U.S. troops are
having success with offering to
repair mosques or install
loudspeakers to try to win over
mullahs while creating an
unattractive target for Taliban
extremists who won't want to
attack mosques.

This may overestimate the
Taliban's restraint. The
beheaded man was a mosque
leader.

Even so. projects of all
types push ahead. Three
medical clinics are open and
two interim schools have
started with more than
students.

Zahir said he and his
advisers believe they need to
show they have the Upper hand
by the end of the month. "We
have about two weeks to prove
ourselves." he said.

The Marines refuse to give
precise time ?ames but
acknowledge they have only a
short time. "If this takes six to
seven months. that gives a big

enough window to the
Taliban." Marine Lt. Col.
Calvert Worth Jr. said.

This urticie contains

information from the New York
Times.



New York Times

March 13. ECHO

3. Drone Strike Said To
Kill A Leader Of Al

Qaeda
By David E. Sanger
WASHINGTON A
strike by an unmanned drone
last week killed a senior
commander of Al Qacda who
had played a signi?cant role in
planning the killing of lCentral
Intelligence Agency operatives
in late December at a base in

00143

page ti
Afghanistan, according to
American of?cials.

The March ii strike was
one of a series aimed at
suspected participants in the
deadly attack in Khost
Province. which took place just
before a meeting with a
militant who the Americans
believed could provide
information on Al Qaeda?s
operations. Seven Americans
and a Jordanian intelligence
officer died in that attack.

According to a United
States
of?cial. the Qacda operative
killed last week was Hussein
til-Yemeni. The drone missile
struck in Miram Shah in North
Waziristan. a pan of Pakistan
where Al Qaeda is considered
well dug in.

The official. who spoke on
the condition of anonymity.
described Mr. Yemeni as an
?Al Qacda planner and
facilitator" in his late 205 or
early 305. who had established
ties with the Haqqani network.
which has planned many
Taliban attacks in Afghanistan.
and with Al Qaeda in the
Arabian Peninsula. His role
was described by one
American official as a ?conduit
in Pakistan for funds. messages
and recruits. but his real
specialty was bombs and
suicide operations."

It was unclear exactly
what role Mr. Yemeni might
have played in preparing the
Jordanian double-agent.
Humam Khalil Abu Mulal
al-Balawi. also known as
Humam Khalil Mohammad,
for his meeting in Khost on
Dec. 30. Mr. Balawi was not
searched when entering the
compound. and detonated his
suicide vest just before he was
to be patted down ahead of his

meeting with a number of

CLA. of?cials. In an unusual
statement. a senior intelligence
of?cial told reporters the
deaths would be ?avenged
through successful. aggressive
operations."
The drone attacks are part
of a covert program that
American of?cials of?cially
refuse to talk about. but whose

arcs. EXHIBIT it Map)
K?s r374 :55

ll?.

ManningB_?O409593

existence is an open secret.
Last year there were roughly
55 drone attacks in Pakistan
against Al Qaeda and the
Taliban. based on news
reporting about the damage
they caused. The attacks are a
key element of an effort to put
pressure on Al Qaeda and its
leadership. but in recent weeks
they appear to have been used

to kill those believed
responsible for the Khost
attack.

In a speech last week in
Oklahoma. the C.I.A. director.
Leon Panetta. said he believed
that the pressure on Al Qaeda
had grown so much in recent
months that the leadership of
its traditional hierarchy,
including Osama bin Laden.
had been greatly diminished.
He said recent communications
intercepts had overheard
younger militants complaining
about the absence of
leadership.

At the end of the Bush
administration. intelligence
of?cials made similar claims.
At the same time. some
otlicials concede. an operation
as complex as that in Khost
demonstrates that Al Qacda
and the Taliban can still carry
out sophisticated terror actions.



Washington Post

March 18. 20?)

Pg. [0

4. Attacks Searing

In Afghanistan
Taiibmr?ghters' low-ted: but
deadly tactic hinders US.

By Craig Whitlock

Taliban ?ghters more than
doubled the number of
homemade bombs they used
against US. and NATO forces
in Afghanistan last year.
relying on explosives that are
often far more primitive than
the ones used in Iraq.

The embrace of a low-tech
approach by Taliban-trained
bombmakers -- they are
building improvised explosive
devices. or lEDs. out of
licrtilimr and diesel fuel has
stymied a $17 billion U.S.
against the
devices in Iraq and

ManningB_ClO409694

Afghanistan. military officials
say. Electronic scanners or
which were
commonly deployed in Iraq.
can detect only bombs with
metal parts or circuitry.

"Technology is not going
to solve this problem." said
Anny Lt. Gen. Michael Oates.
director of the military?s Joint
IED Defeat Organisation. or
JIEDDO. don't think you can
defeat the IED as a weapon
system. It is too easy to use."

U.S. military officials said
they expected the number of
IED attacks to climb further
this year as 40.000 U.S. and
NATO reinforcements pour
into Afghanistan.

Gates said technological
advances have enabled the
military to save lives by
providing better armor and
other forms of protection for
troops. But he said the
high-tech approach -- despite
billions of dollars in research --
has failed to produce an
effective way to detect IE.le in
the ?eld. About of

the devices that are found
be fore they explode are
detected the old-fashioned

way: by troops who notice
telltale signs. such as a recently
disturbed patch of dirt that
might be covering up a bomb.

Despite the insurgents'
crude approach. the explosive
power of their 11305 is
growing. Each bombing in
Afghanistan. on average.
causes 50 percent more
casualties than it did three
years ago. Gates said
Wednesday at a House
committee hearing. US.
of?cials say even armored
troop-camped vehicles that
were designed to protect
against roadside bombs are
now vulnerable.

All told. the US. military
recorded H.159 IED incidents
in Afghanistan in 2009.
compared with 3,867 in 2008
and 2.677 the year before.

Last month. 3'21 IEDs
blew up or were defused in
Afghanistan. slowing a major
Marinenled offensive in
Helmand province and killing
28 LLS. and allied troops.

These bombs are the leading
cause of U.S. casualties by a

large margin.

The number of attacks
in Iraq. meanwhile. has
plummeted. mirroring the

overall decrease in violence in
that country. At their peak. in
200?. Iraqi insurgents
employed 23.0th IEDs. Last
year, that number fell to about

3.000. according to U.S.
military ?gures.

Oates credited U.S.
countermeasures such as
interrupting the ?ow of

military-grade explosives and
detonators from Iran for
some of the decrease. Other
military of?cials said a bigger
factor was the overall reduction
in the intensity of the
insurgency; as sectarian
?ghting faded. people simply
stopped planting bombs.

Maj. Gen. Michael T.
Flyrui. the head of U.S.
military intelligence in

Afghanistan. has said that the
most effective way to combat
the flood of IEDs is to embrace
an overall
strategy. If U.S. and NATO
forces can win the support of

the local population. the
thinking goes. the bombings
will stop.

But with the number of
attacks soaring in
Afghanistan. Defense Secretary
Robert M. Gates created a task
force in November to devise
more short-term solutions for
responding to the threat. He
gave the group six months to

come up with
recommendations.
"There?s no doubt the

urgency has picked up." said
Oates. who took over as
director of JIEDDU in Jannary
and sits on the task force. "We
don?t have years to wait to start
changing the momentum in
Afghanistan."

HEDDO. which has a staff
of about 3.500. was created in
EUUE after 11.5. commanders in
Iraq said they needed a major
research effort to come up with
ways to ?ght Some
military of?cials likened the
campaign to a modern-day
Manhattan Project. the code

HIV.

00144

page 9
name for the secret program
that developed the ?rst atomic
bomb.

Congress has spent nearly
billion on IED research
and training programs. not
including money allocated for
armored vehicles and other
equipment to protect troops.

In Iraq. in addition to
using electronic the
US. military employed a range
of tactics to detect IEDs.
Unmanned aircraft and blimps
armed with cameras roamed
the skies to look for insurgents
as they placed bombs along
roadsides and under bridges.

But experts said those
tactics are only marginally
useful in Afghanistan. Because
of the country's moumainous
terrain. surveillance drones
have a harder time spotting
bombers at work. Unlike in
Iraq. most of the roads are
unpaved. making it more
dif?cult to detect bombs buried
in the dirt.

"It's just a tough
environment." said Command
Sgt. Maj. Todd M. Burnett.
who oversees training
programs for IIEDDO. "It's the
harshest conditions imaginable
for a soldier."

Kenneth Comer.
JIEDDO's deputy director of
intelligence. said insurgents in
Afghanian and Iraq were
constantly adapting their
bombmaking tactics to stay a
step ahead of
technological advances. He
Said that it was unlikely that
the US. military would ever
catch up but that it needed to
keep trying until broader
counterinsurgency efforts take
root. The alternative. he said.
would result in higher U.S.
casualties and more
momentum for enemy forces.

"We will never win in that
space." he said. "But we can
lose in that space."



AnnyTimes.com

March 1120?)

5. Lays Out
Campaign For
Kandahar

DFCR. EXHIBIT it I

pg Cd.

By William H. McMichacl.
Staff writer

Efforts to lay political and
security groundivork in the
Taliban stronghold of
Kandahar have already begun.
even as the U.S.?lcd coalition

continues efforts to pacify
Marjah. the US. general
leading the effort said
Wednesday.

Both goals are key to the

Dbama administration's
campaign to secure
Afghanistan and establish

credible governance.

The campaign to remove
the Taliban from Kandahar
won?t take the form of last
month's D?day-style military
movement into Marjah. to the
east in neighboring Helmand
province. but will be a gradual
buildup that employs both
military force and political
maneuvers, said Army Gen.
Stanley
commander of U.S. and NATO
troops in Afghanistan, dining a
satellite-linked meeting with
Pentagon reporters.

?What you are going to
see in the months ahead
without giving too much detail
is a number of activities to
shape the political relationships
in and around Kandahar.?
said. ?As you
know. it's a complex. grouping
of tribes and other relationships
that de?ne how power is
shared in Kandahar."

This process has become
?*very damaged? in the past few
years. said. ?So
one of the things we?ll be
doing is working with
political leaders to try to get an
outcome that makes sense.
That will then be supported by
security operations and that
will. in some cases. be
increased partnering inside the
city with the Afghan National
Police. We intend to put more
forces in there to give better
presence and better support to
their internal security."

said he has
already increased coalition
forces around Kandahar. and
will "continue to increase
Afghan National Security
Forces and coalition forces in

ManningB_00409695

the months ahead.?

The provincial capital has
recently been struck by Taliban
bemb attacks described as a
?warning? to
killing or wounding more than
90 civilians. the Associated
Press reported.

In congressional testimony
this week.
acknowledged. as did Army
Gen. David Petraeus. chief of
US. Central Command. that
more trainers are needed to
help increase Afghan National
Security Forces capabilities.

"We have been very
unequivocal back both to
Washington. DC. and of

course. more appropriately. to
said.

The number of trainers in
country has been increased
?signi?cantly.? he said. as have
moves linking coalition and
Afghan forces. all efforts to
develop the Afghan force. But
to produce quality trainees at
the desired rare. he said. ?we
need additional trainers."

said he was
?pleased? with the progress
made to date in Marjah. ?But I
would also say that We are just
really still in the back end of
the military phase of this. and
that the longer-term phases
where we?ve got to establish
credible Afghan govemance
is a signi?cant task in front of
us.

acknowledged
full awareness of the July ll.
EDI l. date Obama has set for
the beginning of the
withdrawal of US. forces from
Afghanistan, but said. as have
sevch US. of?cials. that ?the
scope and the rate" of
withdrawal ?will be based
upon conditions."

He added his belief that
enough trained and capable
Afghan National Security
Forces will be in place at that
point to provide increasing
security where they are
stationed around the country.



Reuterscom
March 18. 2010

6. US Troops Leave
Border To Afghan Boss

Accused Of Graft
By Peter Ciralf. Reuters

SPIN EOLDAK.
Afghanistan One of the most
important trade routes in Asia
was closed last week while a
boyish-looking man everyone
calls "the general" showed
around the commander of US.

and NATO forces in
Afghanistan.
General Stanley

to the
top of a roof. where "the
general" -- of?cially a colonel
in the Afghan Border Police --
pointed out the area where
NATO forces plan to build a
new $20 million border station.

U.S. forces are not allowed
near the teeming border when
it is open. so they have never
seen quite how Colonel Abdul
Razziq, the 3D-something
Afghan border police boss in
Spin Boldak. single~handedly
rules over billions in
international trade.

They say he has done a
good job keeping the border
moving and secure. They also
believe he is. as one senior
military official put it. "a
crook".

Or. as Lieutenant-Colonel
Pat Keane. head of a NATO
unit trying to improve
Afghanistan's border controls.
put it more delicately: "He
keeps the peace down here.
Trucks ?ow. commerce ?ows.
At the same time. he is getting
additional incomes."

visit to
Razziq at least his second so
far this year -- shows the tough
choices U.S. of?cials face
trying to fight corruption in
Afghanistan. while relying on

of?cials they believe arc
themselves eon'upt.

For now Razziq is the
Americans' man in Spin
Boldak. where US. forces
expect him to help them

dramatically increase their own
shipments of supplies for their
growing military presence.
Rarziq. a leader of one of
the two main tribes in the
border area of Kandahar
province. commands a few
thousand local policemen in
blue-grey uniforms at the

Hit. arcs. EXHIBIT .l 1 mi?)

00145

page It)
frontier. one of only two legal
highway crossing points
between Afghanistan and
Pakistan.

A man with an easy smile
and a friendly air who denies
illegal activity. Razziq beamed
beside the US. commander as

praised him in
front of local teleVision
cameras.

"Colonel Razziq is trying
to make some changes that
allow battle to move more
smoothly.? said.
am very optimistic that with
the plans that I've heard. we
can increase efficiency and
decrease corruption."

Just how much pro?t
Razziq makes from his total
control of the border is
impossible to gauge. About
700 trucks cross the frontier
each day, linking Pakistan with
southern Afghanistan. Iran and
central Asia beyond.

During a brie?ng with
and his top aides
before the trip to meet Rarziq.
the head of Afghan customs.
Bismullah Kamrnawie. told the
American officers that
corruption at Razziq's border
post was "total".

The Afghan government
colleCIs about $40 million in
customs revenue in Kandahar
Province per year. about a fifth
of what it should collect.
Kammawic told Reuters.
adding that the target was just
an estimate since nobody really
knows what comes in.

Razziq and his men
control one of the main
outgoing routes from the

southern Afghan agricultural
heartland that produces nearly
all the world's illegal opium.

A 1500 word investigative
story in Harper?s Magazine last
year. which included
interviews with Fashion drug
traders and smugglers on both
sides of the header. described
Razziq as controlling an
empire worth millions in
annual kickbacks.

It described his own lavish
compound, ?lled with
armoured vehicles. and said he
runs a network of private
prisons for those who cross



'11Crti?:
PC:

him. According to the
Washington Post. the Harper's
story is being used to teach
US. intelligence agents about
the reality on the ground in
Afghanistan.

Yet despite their clear
suspicions. U.S. forces have so
far agreed essentially to give
Razziq a free hand. Under a
deal reached on the grourid.
US. troops in the area have
pledged not to visit the border
when it is open.

One of the aims of
visit was to sign
a document that would allow
his troops unfettered access.
No luck.

After a two-hour meeting
full of speeches on the
importance of cooperation.
Razziq and his boss from

Kabul. border police
commander Mohammad
Younus Noorvai, politely

declined to sign in the absence
of two cabinet ministers.

With 30,000 additional
US. troops arriving as part of
President Barack Obama's
escalation strategy this year --
most to Kandahar and
neighbouring areas -- NATO
will need to double its own
supply traf?c through Spin
Boldak in coming months.
They need Razziq to keep the
border open longer so more
traf?c can pass.

They will also have to deal
with other of?cials they say
they have questions about.
above all the head of
Kandahar's provincial council.
President Hamid Kamai's
half-brother Ahmad Wall
Karzai. considered the most
power?rl roan in the province.

Ahmad Wali Kamai has
long denied Western media
reports that he is involved in
the drug trade- The New York
Times also reported last year
that he was on the CIA's
payroll.

Being so closely allied to
of?cials they suspect of graft
makes military commanders
uncomfortable. but they are
wary of disrespecting the
Afghan authorities they are
there to protect.

Last week. NATO of?cials

made clear they would not
intervene despite learning that
the man chosen to run Marjah.
a town US. Marines fought for
last month. may have spent
four years in a German prison
for attempting to stab his
stepson to death.

In an interview after
meeting Razziq. McClu'ysral
said ?ghting corruption is
crucial because it is what
drives Afghans into the arms of
insurgents. But he declined to
address speci?c accusations
against Razziq and Ahmad
Wali

"To the degree that
(corruption) is one of the
causes of the insurgency. it
worries me more than the
insurgency itself."
said. "We can ?ght the
insurgency: we can defeat the
forces of the insurgency. the
ground forces and whatnot. But
if we don't have effective

governance. credible
governance. than you don't
defeat the cause of the
insurgency."

Before his trip to see
Razziq. listened as
staff doscribed plans for the
new $20 million customs
depot.

"This is what we're good
at: building stuff and projects."
said. "We're not so
good at the cultural stuff"



Philadelphia Inquirer
March 18.2011)
7. Cancels Afghan
Debt

The United States has
reached an agreement with
other countries to cancel $1.6
billion in debt owed by
Afghanistan to creditor nations

and international lending
organizations.

Deputy U.S. Treasury
Secretary Neal Wolin said
yesterday that the decision to
cancel the debt was a
recognition of the progress
Afghanistan had made in

strengthening its economy.
"Lifting the debt burden
inherited by the Afghan
government marks a crucial
step on Afghanistan's road to

economic sustainability."
Wolin said.

The Treasury said that
since 2002. technical advisers
worked with the Afghan
Ministry of Finance to help
restructure the debt.

The accord covets not only
debt owed by Afghanistan to
the United States and other
individual countries but also
loans extended by the
lntemational Monetary Fund
and World Bank.

Treasury officials said that
about $1le million of the debt
was owed to the United States.

Associated Press



Washington Post

March 13.2010

Pg.

8. CIA Director Says
Attacks Have

Al-Qaeda

Landsat deep in hiding:
credits c?ortr with
Pakistan

By Joby Warriek and Peter
Finn

Aggressive attacks against
al-Qaeda in Pakistan's tribal
region have driven Osama bin
Laden and his top deputies
deeper into hiding and
disrupted their ability to plan
sophisticated operations. CIA
Director Leon Panetta said
Wednesday.

So profound is aI-Qacda's
disarray that one of its
lieutenants. in a recently
intercepted message. pleaded
with bin Laden to come to the
group's rescue and provide
some leadership. Panetta said.
He credited improved
coordination with Pakistan's
government and what he called
"the most aggressive operation
that CIA has been involved in
in our history." offering a
near-acknowledgment of what
is of?cially a secret war.

"Those operations are
seriously disrupting al~Qacda."
Panctta said. "It's pretty clear
from all the intelligence we are
getting that they are having a
very dif?cult time putting
together any kind of command
and control. that they are
scrambling. And that we really

00146

page i I

do have them on the run."
Panetta is one of several
senior of?cials who have
stepped forward to argue that
the administration is making
gains against extremists. in part
to rebut Republican criticism
that President Obama has
weakened national security. He
is not the ?rst 1A director to
point to progress in the war
against al-Qacda. claims that
sometimes prove too
ambitious. have an excellent
idea of where [bin Laden] is."
then-CIA Director Porter J.
(loss told an interviewer in

2005.

Senior Obama
administration of?cials this
week have given sharply

different views on how bin
Laden would be dealt with if
he fell into LLS. hands. Gen.
Stanley A. the
commander of 1.1.5. and NATO
forces in Afghanistan. said
Wednesday that the military
would "certainly" try to capture
bin Laden alive and "bring him
to justice."

A day earlier. Anomcy
General Eric H. Holder Jr. told
a congressional panel that bin
Laden would never go on trial
in the United States because
the chances of him being
caught alive are
"in?nitesimal." He predicted
?atly that bin Laden will be
killed -- either by U.S. forces
or by al-Qaeda operatives
determined to prevent him
from being captured.

Panetta said the agency
has a plan in the event that a
top al-Qaeda leader is captured.
"The most likely scenario is
you bring them to a military
facility. and we would then do
the questioning" there. he said.

A steady toll on al-Qaeda

Reflecting on his 13
months at the helm of the CIA.
Panetta made no prediction
about the fate of the man who
has eluded a worldwide
manhunt for nine years. But he
said the combined
U.S.-Pakistani campaign is
taking a steady toll in terms of
al-Qaeda leaders killed and
captured, and is undercutting
the group's ability to coordinate

-.. . ti"
Hotl?ll I i kw
A8

lli'fll

I

ManningB_00409696 I a

attacks outside its base along
the Afghanistan-Pakistan
border.

To illustrate that progress.
intelligence of?cials
revealed new details of a
March it killing of a top
aI-Qacda commander in the
militant stronghold of Miram
Shah in North Waziristan. in
Pakistan's autonomous tribal
region. The al-Qaeda of?cial
died in what local news reports
described as a missile strike by
an unmanned aerial vehicle. In
keeping with long-standing
practice, the of?cials spoke on
the condition of anonymity
because the formally
declines to acknowledge U.S.
participation in attacks inside
Pakistani territory.

Hussein al~Yemeni. the
man killed in the attack. was
identi?ed by one intelligence
of?cial as among al-Qaeda's
top EU leaders and a participant
in the planning for a Dec. 30
suicide bombing at a CIA base
in the province of Khost in
custom Afghanistan. The
bombing. in which a Jordanian
double agent gained access to
the CIA base and killed seven
of?cers and contractors. was

the deadliest single blow
against the agency in a
quarter-century.

Panetta's upbeat remarks
contrasted with recent
intelligence assessments of
continuing terrorist threats

against the US. homeland. But
he also said al-Qaeda will
continue to look for ways to
strike inside the United States.
and he noted that the
organization is seeking to
recruit people who lack
criminal records or known ties
to terrorist groups.

He cited the recent
examples of Najibullah Zazi,
an Afghan immigrant who
targeted the New York subway
system and pleaded guilty to
terrorism charges. and Umar

Farouk Abdulmutal lab. a
Nigerian charged with
attempting to detonate

explosives on a commercial

?ight about to land in Detroit.
"How many other Zazis

are there -- the people who

halve a clean record who
suddenly, for some crusty
reason. decide to get involved
with jihad?" Panetta said. "The
bomber in Detroit -- this
person suddenly goes oil", has a
US. visa. and within 30 days
he's recruited to strap a bomb
on and come to this country.
What we are seeing is that they
are now looking for those kind
of clean credentials."

Such threats make it all the
more necessary to strike
al-Qaeda in its home base.
Pauetta said. "The president
gave us the mission to disnipt,
dismantle and defeat al-Qaeda
and their military allies, and I
think that's what we are trying
to do."

Secret strikes

Counting the March 8
operation. the CIA is believed
to have mounted 22 such
strikes this year. putting the
agency on coursi: to exceed last
year's roughly 53 strikes, a
record. The March 8 event is
believed to have been the ?rst
to occur in an urban area; a
LLS. intelligence official
familiar with the operation said
the building that was targeted
housed "a large number of
al~Qaeda? ?ghters who were
developing explosives. There
were no other casualties, the
of?cial said.

Panetta. while declining to
comment on the strike itself.
said the death of the avaaeda
commander sent a "very
important signal that they are
not going to be able to hide in
urban areas."

He also cited recent arrests
of top Taliban ?gures most
notably Mullah Abdul Ghani
Barndar. captured in Karachi in
early February -- as tangible
evidence of improving ties
with Pakistan's intelligence
service. He said that Pakistan
has given the CIA access to
Baradar since his capture and

added that "we're getting
intell i from the
interrogation.

A senior intelligence

official revealed that Baradar
was tracked down as part of a
joint operation with Pakistan
that targeted members of a

Taliban leadership council
known as the Quetta Shura. A
breakthrough came when the
intelligence agencies obtained
a list of Taliban phone
numbers, one of which led
them directly to Baradar, the
o?icial said.

Panetta said coordination

between the CM and its
Pakistani counterparts had
improved over the past year,
despite occasional "Friction
based on past history."
"Generally we?ve had
mach better relationships." he
said. "We do a lot more

operations together. That's how
Estrada: was captured as well
as . They have been
much more tolerant of the
operations we have there."
Where is bin Laden?
Panetta said the agency
does not know precisely where
bin Laden and his top deputy,
Ayman al-Zawahiri. are hiding,
but he said agency of?cials

believe the two are inside
Pakistan. "either in the
northern tribal areas or in
North Waziristan. or

somewhere in that vicinity."

While there have been no
continued sightings of either
man since 2003. the continued
pressure increases the
opportunities for catching one
or both. Panetta said. "We
thought that the increased
pressure would do one of two
things: that it would either
bring them out to try to exnrt
some leadership in what is an
organization in real trouble. or
that they would go deeper into
hiding." he said. "And so far
we think they are going deeper
into hiding."

Inside the door of Panetta?s
o?ice is a color-coded map of
the tribal areas in Pakistan, the
only map on a wall decorated
with photographs of Panetta's
long career in Washington.

"You can bet there is
going to be a conversation in
this of?ce during the day that
involves something on that
map." he said.

Sto?' writer Craig
Whirlock and surf researcher
Julie Tare contributed to this
nynni

00147

page [1



Washingtonpost.com

March Il. 2010

9. US Military: Goal
Still To Capture Bin
Laden Alive

By Anne Flaherty, Associated
Press

WASHINGTON -- The
top U.S. commander in
Afghanistan said Wednesday
that it remains the goal of U.S.
troops to capture Osama bin
Laden alive and "bring him to
justice."

The comment by Gen.
Stanley to
reporters was in contrast to
remarks made a day earlier by
Attorney General Eric Holder.
Holder told Congress that the
chances of capturing bin Laden
alive were "in?nitesimal"
because he would probably be
killed by US. forces or by one
ofhis own ?ghters.

Bin Laden's whereabouts
have longed vexed U.S.
of?cials. But his elusive status
has recently taken on new
meaning as President Barack
Dbama pushes to try suspected

terrorists in civilian courts

instead of more secretive

military tribunals.
Congressional

Republicans are pushing back
by saying that bin Laden and
others like him shouldn't be
given the same rights as US.
citizens.

Holder said in House
testimony that terrorists
wouldn't be given any more
rights than serial killers like
Charles Manson. He also
dismissed the example of bin
Laden being given access to
U.S. courts as a red herring in
the debate.

"Let's deal with reality."
Holder said. "The reality is that
WE will be reading Miranda
rights to the corpse of Usama
bin Laden. He will never
appear in an American


When was
asked whether the US. had
given up on capturing bin
Laden alive. he said. "Wow,
no.?

IHV. arcs. My)
@9140935

ManningB_DD409697

If bin Laden enters
Afghanistan. "we would
certainly go after trying to
capture him alive and bring
him to justice."
told Pentagon reporters from
Kabul.

think that is something
that is understood by
everyone." he said.



Christian Science Monitor
(csmonitorcom)

March 17, 2010

10. Al Qaeda Websites
Present Growing
Threat, 's Mueller

Warns
By Warren Richey, Staff writer
The United States faces an
expanding array of AI
Qacda-rclatcd threats that
extend far beyond the lawless
regions of southwest Asia and
into the US itsch via radical
Islamist websites. FBI Director
Robert Mueller told a House

Appropriations subcommittee
on Wednesday.
?For those in the

intelligence community there
has been a shift in the degree
of concern about affiliates of
Al Qaeda growing in strength
and presenting a much
enhanced threat to the United
States." the Federal Bureau of
Investigation director said.

Prior to the Still attacks.
he said, the AI Qacda threat
largely resided in or near
Afghanistan. Now. however.
US intelligence of?cials are
monitoring the growth of
groups based in Somalia and
Yemen. among others.

Some 313th] naturalired
US citizens currontly reside in
Yemen. Mr. said. and
intelligence of?cers are
attempting to identify if any
have been radicaiized. trained,
and tasked to return to the US
to conduct attacks.

In addition. Mueller
warned of the threat of Al
Qacda supporters emerging
within the US domestic

population who have grown
sympathetic to Al Qacda
through contact with militant
websites.



FBI agents are attempting
to head off traditional means of
radicalization within American
prisons or in small pockets in
certain US communities. But
Mueller said the hardest to
counter is the militant
international dialogue
underway on pro-AI Qaeda
websites.

?The one that is most
worrisome is the Internet.? Mr.
Mucllertesti?ed.

In nearly 2.5 hours of
testimony. Mueller also
defended the FBI 's
interrogation of alleged
Christmas bomber Ulnar
Abdulmutallab. and he
revealed the Obama
administration's plans to
deploy a high-value terrorist
interrogation team within the
domestic US.

011 Tuesday, Attorney
General Eric Holder was
grilled by Republican members
of the same House
subcommittee for failing to
Mr. Abdulmutallab as an
enemy combatant.
Administration critics say that
rather than giving him Miranda
warnings about his right to
remain silent and obtain a
lawyer. the alleged terrorist
should have been turned over
for inde?nite military detention
and interrogation by members
ofthe newly formed high?valuc
terrorist team.

Mueller disagreed.
believe that the special agent in
charge and the agents on the
ground [in Detroit] did an
admirable job," he said. ?We
could have brought in more
subject-matter experts but they
were not readin available on
the ground at that time.?

The FBI director said that
sometimes the best opportunity
to obtain statements born a
suspect is immediately
following the arrest. ?You have
to act relatively quickly." he
said.

Mueller said officials on
the scene turned to an
experienced FBI interrogator
who had served in the Middle
East. They also brought in an
explosives expert to participate
in the questioning.

Abdulmutallab was
initially talkative. providing
important details. of?cials have
said. But later. after he was
read his Miranda rights, he
stopped talking.

Rep. Frank Wolf of
Virginia said Abdulmutallab
should have been placed in
military detention long enough
to allow interrogation
specialists to fly to Detroit to
question him.

?We are not saying the
agent] who drew the short
straw to work in Detroit on
Christmas Day was a bad
person.? he said. He jost
wasn?t the best quali?ed in the
country to perform the job at
hand. Representative Wolf
said.

The FBI director said the
agents used their skills and
expertise to good effect.
could not get an expert on
Nigerian radicalism there that
fast.? he said. In such cases. it
is necessary to rely on the
judgment and ability of
of?cials on the scene. he said.

Mueller said he would
have liked having the
high-value interrogation team
in Detroit, and he said the
administration is currently
developing guidelines to cover
USnbascd interrogation
sessions by the group.

Wolf complained that the
administration had announced
the creation of the interrogation
team seven months ago. but
that it won?t be operational at
the national counterterrorism
center until August.



Los Angeles Times
March I8, 20:0
Pg. I
11. Iraqi Vote Strips
Away Unity
The still-right race dashes
hopes that the notion might
conquer its sectarian divide.
By Ned Parker

BAGHDAD With more
than 80% ofthe votes rallied in
Iraq's parliamentary elections
and the race still neck and
neck. hopes that the country
might move beyond its deep
Shiite-Sunni divide appear to

rt'
ll?cuj l-

page [3
be fading in a stew of sectarian
politics.

Prime Minister Nomi
Maliki. who once campaigned
as a nationalist leader
responsible for restoring
security to all Iraqis. is now
falling back on his Shiite
Muslim religious identity to
position himself against
challenger lyad Allawi. a
secular Shiite popular with the
minority Sunni Arab
population.

Maliki's allies contend that
he is the only acceptable
choice for the country's Shiite
majority, which suffered under
the rule of Saddam Hussein
and members of his
Sunni-dominated Baath Party.

If Allawi is defeated in
coming negotiations to form a
government. it would be seen
as a major setback for Sunnis.
who have viewed the national
elections as a chance to regain
some of the privileges lost
when Hussein was toppled in
the EUUJ U.S.-lcd invasion of
Iraq.

Willi most of the March '3
vote results in. Maliki's slate
leads in six provinces in the
Shiite-dominated south and
remains narrowa ahead in
religioust m'nicd Baghdad.
Allawi's slate appears to have
won in five northern provinces
with large Sunni populations
that were once hotbeds of the
Sunni-led insurgency.

A stable government is
seen as vital to the future of
Iraq as the nation prepares For
the departure of American
combat troops by the end of
August and all US. forces by
the end of 2011. Its last
national elections. in January
ZIIUS. which Sunnis largely
boycotted. helped ignite a civil
war in which Sunni Arab
insurgents fought against
militias backed by the
Shiite-dominated

Some say the
current election ?ght could
push the sides back to that cm
i Sunnis again I?ch
marginalized and take up arms.

Last fall when Maliki.
seeking a second term as prime
minister, announced his State

of Law coalition, he boasted a
collection of prominent Shiite
and Sunni ?gures. The alliance
sought to build upon his
success in January 2009
provincial elections. when
Maliki campaigned as a
nationalist ?gure who had
restored public safety for all
sects.

But an increase in deadly
bombings since August. and a
round of disquali?eations of
election candidates because of
their alleged ties to the Heath
Party. has returned him to his
earlier role as a conservative
Shiite.

Tire Sunni population
voted in droves for Allawi's
Iraqiya slate. which included
well-known Sunni lamnakers
Usama Naja? and Vice
President Tariq Hashimi, both
of whom are seen as protectors
of the Sunni community and
the professional and business
class under Hussein.

Now. with Malilti's slate
leading in more provinces and
swapping leads with Allawi in
the popular vote. the prime
minister's associates have been
playing the sectarian card.
labeling Allawi?s coalition as
anti~Shiite and closing ranks
based on sect. Maliki has also
accused the other side of Fraud.
a charge Western of?cials say
is unsubstantiated. In doing so.
Maliki?s coalition is following
the example of Allawi. who
voiced similar concerns even
before the vote.

"Most people understand
the lraqiya list has many
Baathists," Sami Askari. a
senior adviser to Maliki. said
Monday, predicting that the
country's influential Shiite
clergy would never endorse a
government headed by those
with perceived links to the

Hussein era. Askari also
claimed that lraqis saw
Allawi's list as backed by

Saudi Arabia. a largely Sunni
country that many Iraqi Shiites
view as irrevocably hostile.
Those in Maliki's circle insist
that the prime minister post
must go to a Shiite with proper
religions credentials.

"[yad [Allawi] is Shiite but





he is representing the Sunnis.
This will rule him out." said
Maliki ally Erna! Shabandar. a
onetime lawmaker who left
Allawi's parliamentary bloc
last year. disillusioned with the
former prime minister's
autocratic decisi0n~making
style.

Already. pressure is
building for Shiite toes of
Malilti to support him for a
second term for sectarian
reasons, according to
Shahandar.

Leaders of the Islamic
Supreme Council of Iraq and
Shiite cleric .?vluqtada Sadr's
political movement loathe
Maliki and would like to
unseat him. but they know they
can never back Allawi.
Shabandar said.

am sure the marjaiyah
[Shiite clergy] will support
Maliki." he said. adding that
Shiite politicians have been
visiting Shiite clerical leaders
in Najaf?. who are seen as the
protectors of Iraq's Shiite
faithful.

He said the clerics have
started to let it be known that
the Islamic Supreme Council
should avoid opposing Maliki
so as not to endanger the
majority sect.

"If there is a possibility for
Heath to in?ltrate power. it is
through Allawi." Shabandar
said.

Maliki also now appears
likely to receive the backing of
neighboring Iran. a Shiite
nation with close ties to the
prime minister's Shiite
opponents. Shabandar said.
Iran. loathed by Iraq?s Sunni
Arabs. had opposed Maliki's
earlier efforts to break army
from the other Shiite religious
parties. but it sees him as a
lesaer evil than Allawi,
Shabandar said.

Maliki appears to have no
qualms about crafting a less
inclusive governing coalition
than in 2006. when Sunnis.
Shiites and Kurds were all
awarded ministries under the
supervision of the US. Even
hopes for a variety of Kurdish
voices in Baghdad has
diminished. as a rival Kurdish

faction. called Change, fared
poorly against the main
Kurdish bloc for seats in
parliament.

"The government of
cunrpromise and quota is
?nished. We are going toWard
a parliamentary majority."
Shabandar said. "There is a
difference between the state
and the government. The
Sunnis will get what they
deserve in the .
When there is a Kurdish-Shiite
coalition. it doesn?t mean there
are no Sunnis in it."

Iraq's Sunnis view the
possibility of Allawi's defeat
with fear.

"The future will be very
black for the Sunnis." said a

former insurgent who
identi?ed himself as Abu
Ahmed.

He worries that a
govenrment with minimal

Sunni participation will lead to
security crackdowns.

"Maliki has this path
some with me or I'll exclude
you.? the former insurgent said.



Washington Post

March 18. 2010

Pg. 8

12. Vote Accentuates
Iraq?s Deep Splits
Mar?iki, Allowr' In Tight Battle:
Smell o/?sct?rorionism is

flowng around again
By Leila Fade]

BAGH DAD -- The
emerging results from last

week's parliamentary elections
have made clear that Iraq
remains a dangeroust
polarized nation. with deep
regional and sectarian schisms
that could widen as the US.
military draws down.

The race to become Iraq's
next prime minister is so tight
that it remains unclear who
will come out ahead. The
country is caught between two
men: Ayad Allawi. a secular
Shiite who became the
candidate of choice for Sunni
Arabs. and incumbent Nouri
al-Malilti. an Islamist Shiite
who has recast himself as a

nationalist while still
promising to serve the
I
i ll '1 I

DFCR.

page l4

once-oppressod Shiite
majority.

No matter which man's

slate wins more seats.

diplomats and Iraqi of?cials
say the post-election jockeying
to build a governing coalition
could give rise to new con?icts
in Iraq's Shiite-dominated
south and the Sunni-dominated
west. with the potential to
unravel hard-won security
gains.

With US troop levels set
to dip to about 50.ll{ltl by the
end of the summer. the
elections appear likely to give
rise to an Iraq even more
sharply divided than in the
recent past. with Islamist
Shiites trying to maintain their
control in the government and
Sunni Arabs hoping to assert a
louder voice. albeit with a
Shiite at the helm.

"Already the smell of
sectarianism is [lowing around
again." Allawi said in an
interview last week with The
Washington Post.

Many Sunnis view Allawi.
a former prime minister. as a
potential benevolent dictator
who could repair Iraq's tenuous
relationship with Arab
neighbors. Among ordinary
Shiites. Maliki's popularity is
such that be attracted more
votes than any other
parliamentary candidate.

But as a politician. Maliki
has many enemies and few
loyal friends. which could
complicate the task of forming
the new governing coalition he
needs to stay on as prime
minister. He broke with Iraq?s
largest Shiite political grouping
to reinvent himself as a
nationalist and now faces
mistrust among many Shiites.

Maliki's biggest Shiite
rivals are the followers of fiery
cleric Moqtada al-Sadr. who
have long walked a ?ne line
between politics and violence.
The Sadrists could become the
dominant Voice in the
second?largest Shiite bloc in
the parliament. This could
make Maliki's attempt to form
a new government pain?rl both
politically and possibly
through violence in the streets(P)

With more than 30 percent
of votes counted in lraq. the
regional and sectarian split has
been stark.

Allawi holds leads in the
four mostly Sunni provinces in
the west and north, including a
decisive lead in Anbar
province. once the bastion of
the Sunni insurgency. in those
Sunni areas. Malilci has
attracted little support. Allawi
also is ahead in the
battleground province of
Tamim. where Kurds. Arabs
and Turkmens all claim the
capital. Kirkulr.

But in Baghdad. the
capital. .?v?laliki is still leading.
and he continues to lead in six
of the nine southern provinces
where Shiites hold a large
majority. and where Allawi's
slate is doing poorly.

Both Maliki and Allawi
are trying to Woo the Kurds
and form a coalition that will
ultimately appoint the
president. who will then
the largest bloc in parliament
the ?rst chance to form a
government and choose the
prime minister. But for both
men. the path is ?lled with
obstacles.

lfMaliki. a divisive ?gure
whom many former allies
describe as authoritarian and in
some cases duplicitous. wins
the plurality in parliament but
proves unacceptable to most
rival blocs. it would mean
months of political
maneuvering that could spill
into the streets and spark
bloodshed. In Iraq. violence
has hiatorically been the
ultimate card in politics.

"Remember. the south
challenged Saddam [Hussein]
with all of his powers." Sadiq

alsRikabi. a top adviser to
Maliki. said Wednesday.
referring to the l99l Shiite
uprising. He spoke about

concerns of Fraud by rivals as
the votes were being counted.
"Our people are still suffering
in the south. and they are
patient for one reason: Their
rights in Baghdad will be
protected.?

It is unclear whether
Maliki would accept a defeat

quietly and walk aWay. Top
of?cials in his State of Law
bloc Warn that there will be
"chaos" if election results are
not transparent and that Maliki
will stay in his position until

every vote is manually
recounted.
While Maliki has a

cohesive political bloc. the
resistance to him among other
Shiite groups means that many
may ?nd it dif?cult to strike a
deal that would leave him as
prime minister. For now.
Maliki's bloc has closed ranks
around him. but its members
may ultimately have to decide
whether to stick with him if it
means risking control of the
government.

The Sadrists. projected to
win 35 to 40 seats in the
325-seat parliament. have said
in the past that they considered
Maliki treacherous for his
strike against them in 2008.
when he went after their militia
and arrested tens of men in the
southcm city of Basra. The
militia was seen as a major
player in much of the sectarian
violence that paralyzed Iraq.
Maliki is leading in oil-rich
Basra province.

A Sadr movement oflicial
who spoke on the condition of
anonymity said the group's
resurgent power meant that
Maliki and his party could no
longer act alone. "They are not
the majority." the official said.
"If they want to have the title
of prime minister. they have to
listen to others. not put their
conditions on others."

But an alliance betWeen
Sadrists and Allawi may prove
just as dif?cult, The former
prime minister has allied
himself with Sunni Arabs
whom most Shiites and Kurds
would consider unacceptable.
His party has also been the
focus of a controversial
commission. run by Shiite
candidates. that purged tens of
candidates belonging to his list
for alleged loyalties to
Hussein's outlawed Baalh
Party. The move galvanized
Sunni voters. but it alienated
some of Allawi?s smaller.
Shiite constituency.

Ultimately, Allawi's
popularity as the man for Sunni
Arabs in Iraq could be his
undoing.

"It's more or less an
unwritten dictum that this post
for prime minister should be
for the Shiites." said Erzat
Shahbandar. a Shiite lawmaker
and member of Maliki's
political bloc. "Although
Allawi is a Shiite. he is a
candidate from a Sunni
electorate.

Correspondent Ernesto
Londth contributed to this
report.



St. Louis PoslvDispatch
March 17. 2010

Pg. 1

13. McCaskill Turns Up
Heat On Earmarks.
Pentagon

Requesrfor data is par! of
drive by Congress to curb
special} projects.

By Bill Lambrecht

WASHINGTON - Sen.
Claire McC'askill is pressing
the Pentagon to release records
on billions of dollars in defense
projects awarded through
congressional earmarks. part of
a growing move to restrict
lawmakers' practice of
directing expensive projects
back home to their districts and
states.

A year to the day alter her
?rst demand for Pentagon
documents. McCaskill.
said Tuesday that she had
grown increasingly frustrated
with the agency's refusal to
comply. Pentagon of?cials
have provided sketchy
information on a fraction of
recent congressional-directed
awards for military spending,
and McCaskill has received
nothing from military of?cials
in more than six months. she
said.

McCaskill. who chairs a
Senate subcommittee on
contracting oversight. said one
of her aims was tabulating the
number of no?hid contracts
awarded to companies at the
behest of powerful members of
Congress.

"I'm trying to be patient,

page 15
but I?m not giving up." she
said. feel a little like the dog
that caught its tail."

McCaskill said she
intended to telephone Pentagon
of?cials shortly and also was
considering holding a public
hearing. Another option would
be for her committee to
sitpr the documents.

Steve Ellis. vice president
of the watchdog group
Taxpayers for Common Sense.
said the Pentagon budget
directed more earmarks to
for-pro?t companies than any
other federal agency. But
taxpayers rarely know which
companies get the awards and
have no input in evaluating
companies' performances. he
said. Pentagon of?cials did not
immediately respond to
requests for comment.

McCaskiIl?s efforts are part
of a renewed drive in Congress
to curb the use of earmarks,
which added more than $30
billion to the federal budget
over the past We years.

Last week. House
Democrats banned the use of
earmarks that would be

directed to for-pro?t entities in
the new budget. A day later.
House Republicans went a step
further by committing the GOP
to a one-year ban on all
earmarks. And McCasl-till
co-sponsored an amendment
that would in effect ban
earmarks for two years by
requiring an extraordinary
two-thirds majority to pass any
legislation containing pet
projects. But Tuesday evening.
the Senate demonstrated its
fondness for earmarks by
voting more than to kill the
proposed two-year ban.

However. the Senate did
approve an amendment
ctr-sponsored by McCaskill to
cancel ?mding for an estimated
$600 million for highway
projects obtained by earmarks
a decade or more ago but not
yetbuilt.

By all accounts. the
quostion of earmarks is shaping
up as a political issue this

election year. Missouri
Secretary of State Robin
Carnahan. the Democrats'

Eifi-iilli it

Mannin 00409700 . pi I
- L?k?lg ?r

likely candidate for Missouri's
opening Senate seat. responded
last week to the new earmarks
prohibitions by saying
Congress should "ban them
all.?I Previously. she had
committed only to reforming
the earmarks process.

"There's on accountability
about how money is being
spent." she added later in an
interview. "The only people
who like earmarks are the
politicians who give them out
and the lobbyists who help get
them."

The issue lends itself to
Carnahan?s drive to paint
hcr5elf as the outsider in the
Senate election. Like many in

Congress. Rep. Roy Blunt.
R-Spring?eld. her likely
opponent in November. has

made use of earmarks. He
helped secure more than $20
million for several Missouri
projects last year. among them
defense-related awards for
companies in his southwestern
Missouri district.

After the GDP caucus
adopted its oncryear ban. Blunt
said he would sponsor a
Spending reduction in Congress
roughly equivalent to the last
two years of local-project
awards. A spokeswoman said
last week that he would abide
by the House GOP ban; he was
unavailable Tuesday for
comment.

Carnahan and Blunt are
competing to replace Sen.
Christopher "Kit" Bond. who is
retiring. Bond. a Republican.
has relied heavily on earmarks
during his four terms in of?ce.

Bond defends
earmarks as a means by which
Congress. rather than the
government. can oversee
taxpayers? money. His of?ce
said Tuesday: "All
discretionary money gets

earmarked by someone - either
by an elected of?cial in
Congress or an unclectcd one
within the bureaucracy. Right
now. about 93 percent of the
money is unmarked by
bureaucrats."



Defense Daily

March Is. 2010

14. Navy Stands By LCS
Due Date As Hill
Backers 0f Each Bidder

Swap Barbs
By Emelie Rutherford

Navy Secretary Ray
Mabus said yesterday the

service is keeping a mid-April
deadline for industry bids on
the Littoral Combat Ship
amid concerns about
the losing shipbuilder
protesting the contract award
and a call from one side to
delay the schedule.

Some observers predict the
loser of the two-way contest
between Lockheed Martin and
General Dynamics teams.
which have each built early
LESS. will protest the Navy's
contract award to government
auditors. The service has set an
April 12 date for the two
industry teams in the contest to
build the next ll) littoral ships.
The Navy also plans to allow

additional shipbuilders to
compete to build future
versions of the selected ship
design.

Sen. Richard Shelby

(ll-Ala.) made an unsuccessful
request to the Navy during a
budget hearing yesterday to
delay the April 12 due date for
LCS proposals until the
Congressional Budget Of?ce
provides a requested
assessment. He supports
General Dynamics' bid to build
it) all-aluminum trimaran
LCSs at Mobile. Ala-based
Austal USA.

Shelby joined other
Alabama lawmakers March It
in requesting the CBO
investigate the total lifeeyclc
costs of the LCSs. They argue
the LCS request for proposals
does not address
"critical factors" related to the
total-ownership costs and
technical capabilities of the
two competing designs. and
claim Lockheed Martin?s
ship would have higher
Iifeeycle operating costs than
General Dynamics' aluminum
version.

"I?m concerned. Mr.
Secretary about ef?ciency.

which is a big cost." Shelby
said yesterday during a Senate
Appropriations Defense
subcommittee
hearing on the Navy and
Marine Corps' ?scal year 201]
budget requests.

Shelby charged if the
is not amended. to include an
evaluation factor that considers
energy-consumption costs. the
ship acquisition would not jibe
with Mabus' statements
regarding considering energy
costs in contracting.

Mabus said the LES was
designed with total-ownership
costs in mind.

Fuel savings are shown
when the littoral ships are used
at very high speeds. and the
Navy "very infrequently" plans
to use the vessels at such high

speeds. the Navy secretary
said. Chief of Naval
Operations Adm. Gary

Roughead reiterated this point
to reporters after the hearing.
saying there is not a huge
divergence in fuel consumption
between the two LC classes.

Mabus told the panel he
stands by "the uncut RFP.
which stresses the cost to
purchase the ship. so that we
can get enough of these ships.

"Both variants. we believe.
meet every requirement that we
have. not only operationally
but also in terms of life-cycle
costs going forward." he added.

Shelby asked the Navy to
delay the April 12 due date for
LCS bids until the CEO
responds to the Alabama
lawmakers request for 3 LC
review. Mabus after the
hearing told reporters the
current REP schedule stands.

SAC-D member Sen Herb
Kohl (D-Wis.) during the
hearing countered Shelby's
claims that the Lookheed
Martin-Marinade Marine
semi-planing monohull LCS.
built in his state. would cost
the Navy more to operate.

Kohl charged the General
Dynamics LCS has a "radical"
design. rendering its operating
costs dif?cult to estimate. He
also raised concerns about the
aluminum LCS. saying the
Navy does not traditionally use

page lo
the metal be implied would not
be as stable as steel.

"It seems in very real
sense that we're comparing
apples and oranges." Kohl said
about the competing LCS
designs.

Mabus responded that the
Navy does not "foresee any
signi?cant issues for either
variant? and is focused on
keeping down LCS costs down
so the service can buy 55 of
them.

Kohl asked if aluminum
ships are more expensive to ?x
than steel vessels. because ofa
shortage of aluminum-trained
welders at shipyards. Mabus.
though. said welding for the
metals is similar and thus
training for aluminum can be
arranged.

Navy leaders alter the
hearing told reporters they
have high con?dence in the
LCS RFP. Mabus said
modifying the RFP would lead
to delays that would raise "real
concerns" regarding building
and ?elding the LCSS when
needed. He noted the Navy
already extended the due date
for proposal by two weeks to
answer eonttnetors' questions.

"We think both sets of
builders have had adequate
time to look at this and to get
their proposals in in time."
Mabus said.

Roughead said a protest of
the contract decision "would he
extraordinarily disruptive to
[the] ability of the ?eet to
accomplish it missions in the
?xture."



AnnyTimes.corn
March 2010
Both Sides To
Testify At Gay Ban
Hearing
By William H. MeMichael.
Staff writer

Thursday's Senate Armed
Services Committee hearing on
the ?don?t ask. don?t tell"
policy that bars open service
by gays the second in six
weeks will feature three
outside witnesses who are all
former commissioned of?cers.

arcs. EXHIBIT rm?)
Pg l8 Oi

llill.

ManningE_UO409701

Two were booted out for
being gay. and a retired Marine
Corps four-star general will
testify in favor of keeping the
law that bans openly gay
service members.

At the ?rst hearing. on
Feb. 2, Defense Secretary
Robert Gates and Joint Chiefs
Chairman Adm. Mike Mullen
told the committee that they
back President Ubama's call
for repeal ofthc current law.

Their testimony opened
the door for congressional
Democrats to begin holding
hearings on the effect of repeal.

Meanwhile. two
Gates-directed studies one
due in December. another due
to Gates at the end of this week
will look at the effect of
change across the military and.
separately. how the Pentagon
can ?enforce this law in a fairer
manner." in Gates? words.
while the longer-term review
plays out.

Thursday's hearing will
give those who attend a chance
to hear the view from both
sides of the fence.

Retired Marine Corps Gen.
John ?lack? Shcehan.
appearing at the invitation of
the committee's Republican
staff. has never publicly
addressed the issua of gays in
the military; by expressing
opposition to repeal of the ban.
he will join forces with Marine
Corps Commandant Gen.
James Conway. who told the
committee Feb. 25 hearing that
he wants to ?keep the law such
that it is."

The other service chiefs
have not expressed outright
opposition to repeal. but the
top Army and Air Force
generals agreed with Conway
that making a change during
wartime would be disruptive.

Former Air Force Maj.
Mike Almy and former Navy
Lt. j.g. Jenny Kopfstein both
lost their careers over the ban
on gays and will testify in
favor of repeal.

Almy?s story is
particularly compelling
because he says he was "outed"
by an improper search of his
belongings after rotating out of

Iraq.
?The search was

conducted without ever once
consulting with a lawyer.?
Almy told talk show
host Rachel Maddow on March
3. ?My private e-mails were
forwarded to my commander.
who called me into his office
and demanded that I give him
an explanation. I refused.

?Don?t ask. don?t tell?
failed me despite the fact that I
lived up to the premises of this
law and nevcr disclosed my
private life." Almy said.
?Never once in my 13-year
career did 1 make a statement
to the military that violated
?don?t ask. don?t tell.?

Almy earlier appeared on
Capitol Hill on March 3 at the
invitation of Sen. Joe
Lieberman. I~Conn.. and four
other senators who have
introduced a bill to repeal the
ban.

in contrast. was
openly gay yet deployed twice
on a Navy cruiser before her
discharge. according to a
biography supplied by the
Legal
Defense Fund. a Washington.
D.C.. legal group representing
both of the gay veterans and
devoted to repeal of the law.

Kopfstein graduated from
the U.S. Naval Academy in
1999 and. during her ?rst
deployment as a surface
warfare of?cer aboard the
Japan-based cruiser Shiloh,
told her commanding officer
that she was a lesbian. it was
not an effort to get out of the
military; as she told the
Washington Post in 2005.
didn?t want to have to lie about
myself."

Her commanding ol?cer
requested an investigation but
nothing happened for a year.
and Kopfsteirl underwent a
second sis-month deployment
on Shiloh in support of the War
in Afghanistan.

According to SLDN.
discharge board
was convened 19 months after
her initial admission. Both her
fortner and current
commanding of?cers testi?ed
on her behalf. but she lost her

commission.

Shcehan reached the top
rungs of the military during his
35 years of service.
Commissioned in 1962. he is a
combat veteran of the Vietnam
War and 199t?s Desert Storm
and a recipient of the Silver
Star and two Purple Hearts. He
capped his career as Supreme
Allied Commander Atlantic
and commander of U.S.
Atlantic Command now
U.S. Joint Forces Command.

Following his 1997
retireman Shcehan joined
Bechtel [ntemationaL an
international engineering,
construction and project
management company. as a
senior vice president.

He served as special
adviser for central Asia for two
U.S. defense secretaries. and
also sat on former Defense
Secretary Donald Rumfeld's
Defense Policy Board. from
2901 to 2003.

Sheehan is af?liated with
an international leadership
group. Global Zero. which is
dedicated to the elimination of
nuclear weapons over the neat
quarter-country.



DefenseNews.com
March 17. 2010
16. Challenges Remain
In Battle?eld
Contracting
By Antonie Boessenkool

The Pentagon has made
major improvements in how it
contracts for "contingency"
operations in Iraq and
Afghanistan for jobs such as
food service.
construction. security.
translators and logistics. but
challenges remain. Pentagon

and Govcrrunent
Accountability Office (GAO)
of?cials told Congress

members March 17.

The GAO. the auditing
arm of Congress. said it
recommended how the
Pentagon could improve
wartime contracting in areas
such as providing enough
personnel to oversee
contractors, screening

page 17'
host-coimu?y and third-country
nationals hired by contractors.
and training military personnel
on how to work with
contractors in the ?eld.

has made many
recommendations starting in
the mid-'90s at addressing each
of these challenges." William
Solis. director of defense
capabilities and management
for GAO. told members of the
US. House Appropriations
defense subcommittee. While
the department has
implemented some of those
recommendations. ?it's been
slow to implement others."

Those shortcomings
include a lack of suf?cient and
suf?ciently trained military
personnel and civilian
employees to oversee
contractors day-to-day during
wartime operations. For
example. in Afghanistan. there
was concern the military didn't
have people with enough
knowledge of trades such as
plumbing and electrical wiring
to oversee contractors doing
those jobs.

But. said Shay Assad.
Pentagon director of defense
procurement and acquisition

policy. improvements have
been made in wartime
contracting. For example.

Assad said. the Pentagon has

improved on ?lling its
requirements for trained
contracting of?cer
representatives to oversee
contractors in Iraq and

Afghanistan. In the last year.
the Pentagon Went from ?lling
59 percent of those slots in Iraq
to 94 percent. In Afghanistan.
the till rate went from 38
percent in January 2009 to 84
percent in January 2010, he
said.

One concern raised at the
hearing was whether 0.5.
contractors and the U.S.
military adequately screen
host~country nationals and
third-country nationals who
work for US. contractors.

A high proportion of those
working for contracting
companies hired by the US.
military fall into those two
categories. According to data

IHV. arcs. EXHIBIT



prepared by and
presented at the heari ng. only 9
percent of contractors in
Afghanistan and 28 percent of
contractors in iraq are US.

citizens. The rest are
categorized as thirdcountry
nationals or host-country
nationals. In Afghanistan.

host-country nationals are 75
percent of all contractors.
according to

While some members of
the committee pointed to hiring
host-country nationals as a way
to stimulate local economies in
the ?eld. Rep. Marcy Kaptur,
D-Uhio. said that practice risks
security breaches, especially
when such hires aren?t
adequately screened.

"I?m very concerned about
the security of our forces."
Kaptur said. Although hiring
locals may help foster good
relationships with local
communities, "each one is also
a potential for in?ltration and a
breach."

"It is a concern. and it is a
risk." Assad responded. "We
are doing what we can do to
screen local nationals. but it is
a challenge."



DefenscN ews.com

March 17. 2010

17. Senator Says Solid
Rocket Motor Costs
Will Double. Navy

Disagrees
By William Matthews

Okay. everyone agrees
the cost of solid rocket motors
is going up. The question is
how much.

Sen. David Vitter.
insisted again March 1? that
the cost of solid rocket motors
that the U.S. military needs for
its intercontinental ballistic
missiles will double if
President Bamek Obama gets
his way.

Vitter blames Oharna's
space strategy. as spelled out in
the 2011 budget. which would
cancel NASA's Constellation
program.

Constellation is
developing the next rocket and
crew capsule to take humans

into space. The current launch
vehicle. the space shuttle. is to
retire this year.

With Constellation over
budget and behind schedule.
the Ubama administration
favors encouraging private
space companies to develop the

next generation of launch
vehicles.
While others praise

lUrbarna's plan to invest in
commercial space companies.
1 Jitter worries that one of the
real losers in all this will be the
US. military.

His logic: NASA is the
nation's biggest customer for
solid rocket motors. so if
NASA drops out ofthe market.
prices for everyone else will
double. The military needs
solid rocket motors for
Minuteman ballistic missiles.
submarine-based Trident
ballistic missiles. missile
interceptors and all sorts of
tactical missiles.

The Navy. which has
studied the matter. says prices
will probably rise. but they
won?t double.

During a Senate Armed
Services strategic forces
subcommittee hearing, Rear
Adm. Stephen Johnson. said he
expects solid rocket motor
prices to rise 10 to 20 percent.
He assured Vitter that till}
percent price growth is not
likely. Johnson heads Navy
strategic systems programs.

Viticr. who has been
sounding this alarm since the
2011 budget was unveiled Feb.
l. socmed unconvinced.

NASA provides T0 percent
of the business that sustains the
solid rocket meter industry. he
said. If that vanishes. costs for
other customers must increase
more than 20 percent.

Not so. said Johnson.
NASA's requirements are so
different from the military's -
think size and weight - that
eliminating NASA's demand
will not cause military rocket
costs to double.

"it's a valid concern."
Johnson told Vitter. And costs
may rise. possibly 20 percent.
But they won?t double.

In other testimony, senior

Air Force of?cials said they
plan to spend $5.5 billion over
the next six years to modernize
U.S. bombers. Those are the
3-52. the newest of which is
48 years old; the Bvl. which
has been flying since 1986'. and
the B-2, which dates to 1993.

While upgrading data
links. targeting pods and
avionics, the Air Force will
also begin designing a new
bomber that could be manned
or unmanned. sopersonic or
subsonic. It didn't come up in
the subcommittee hearing. but
the Air Force has said that the
study alone will cost $2 billion
to $4 billion a year. with the
aim of developing a new
bomber by 2020.



ArmyTimeseom

March 17. 2010 I
18. Personnel Chiefs
Warn Against Cuts To

Bonuses

By Rick Maze. Staff writer
Despite meeting all

recruiting and retention goals.

the service personnel chiefs

pleaded with a House panel

Wednesday to keep paying

enlistment and selective
bonuses.
lilford Stanley.

undersecretary of defense for
personnel and readiness. said
military pay and benefits
generally are competitive with
the private sector. and that
large across-the-board
increases are not wanted or
needed.

?The state of military
compensation is healthy."
Stanley told the House Armed
Ser?ces Committee?s military
personnel panel. ?For the ?rst
time. we truly have the ability
to target pay with pinpoint
accuracy to achieve desired
aims and maximize effects of
dollars spent."

Service of?cials said they
may be recruiting and keeping

enough people to meet
numerical goals and they
noted that they are reducing
bonus budgets but they

worry about Congress cutting
too deeply.

J:

00153

page ill

The Air Force. for
example. wants $11.45 million
for bonuses in ?scal 2011. said
Lt. Gen. Richard Newton. that
service's deputy chief of staff
for manpower and personnel.

?These pays are critical as
we shape the force to meet new
and emerging missions and
support the combatant
commanders in today?s fight.?
Newton said.

Lt. Gen. Richard Zilmer.
the deputy Marine Corps
commandant for manpower
and reserve affairs. said the
Corps also is cutting bonuses
but continues to expect to need
signi?cant entry bonuses to
meet goals for recruits in some
critically needed skills.

The Army budget for
bonuses was $4.9 billion in
fiscal 2009 and was reduced to
$4.4 billion this year. For 201 l.
the Army wants $4.5 billion.
an amount that re?ects the cost
of anniversary payments for
bonuses already signed. said
Maj. Gen. Thomas Bostiek. the
Army's deputy chief of staff
for personnel.



New York Times

March 18, 2010

19. Pentagon Sees A
Threat From Online

Muekrakers
By Stephanie Strum

To the list of the enemies
threatening the security of the
United States. the Pentagon has
added WikiLeaks.org. a tiny
online source of information
and documents that
governments and corporations
around the world Would prefer
to keep secret.

The Pentagon assessed the
danger WikiLeaks.org posed to
the Army in a report marked
??inautltorized disclosure
subject to criminal sanctions.?
it concluded that
?WikiLcalts.org represents a
potential force protection.
counterintelligence. OPSEC
and INFOSEC threat to the
US. Army" or. in plain

English. a threat to Army
operations and information.
WikiLeaks. true to its

ilhltill fl. Help)
pg local 35

ManningB_OU409703

mission to publish materials
that expose secrets of all kinds,
published the 2008 Pentagon
report about itself on Monday.

Lt. Col. Lee Packnett. an
Army spokesman. con?rmed
that the report was real. Julian
Assangc. the editor of
WiltiLcaks. said the concerns
the report raised were
hypothetical.

?it did not point to
anything that has actually
happened as a result of the
release.? Mr. ASSangc said. ?It
contains the analyst's best
guesses as to how the
information could be used to
harm the Anny but no concrete
examples of any real harm
being done."

WikiLcaks. a nonpro?t
organization, has rankled
governments and companies
around the world with its
publication of materials
intended to be kept secret. For
instance. the Army?s report
says that in 2008. access to the
Web site in the United States
was cut off by court order after
Bank Julius Baer. a Swiss
?nancial institution. sued it for
publishing documents
implicating Error in money
laundering. grand larceny and
tax evasion. Access was
restored n?cr two when
the bank dropped its case.

Governments. including
those of North Korea and
Thailand. also have tried to
prevent access to the site and
complained about its release of
materials critical of their
governments and policies.

The Army's interest in
WikiLeal-zs appears to have
been spurred by. among other
things. its publication and
analysis of classi?ed and
unclassi?ed Army documents
containing information about

military equipment1 units.
operations and ?nearly the
entire order of battle" for

American forces in Iraq and
Afghanistan in April 2007.
WikiLcal-rs also published
an outdated. unclassi?ed copy
of the ?standard operating
procedures? at the military
prison in Guantanamo Bay.
Cuba. WiI-riLeaks said the

document revealed methods by
which the military prevented
prisoners from meeting with
the International Red Cross and
the use of ?extreme
stress? as a
means of torture.

The Amy's report on
WikiLcaks does not say
whether WikiLcaks? analysis
of that document was accurate.
it does charge that some of
WikiLeaks?s other
interpretation of information is
?awed but does not say
speci?cally in what way.

The report also airs the
Pentagon's concern over some
2.000 pages of documents
WikiLcaks released on
equipment used by coalition
forces in Iraq and Afghanistan.
The Pentagon concluded that
such information could be used
by foreign intelligence
services. terrorist groups and
others to identify
vulnerabilities. plan attacks and
build new devices.

WikiLcalts, which Won
Amnesty lnternational?s new
media award in 2009. almost
closed this year because it was
broke and still operates at less
than its full capacity. It relies

on donations from humans
rights groups. joumalists.
technology buffs and

individuals. and Mr. Assangc
said it had raised just
two-thirds of the 3600.000
needed for its budget this year
and thus was not publishing
everything it had.

Perhaps the most amusing
aspect of the Army's report. to
Mr. Assange. was its
speculation that WikiLeaks is
supported by the Central
Intelligence Agency. only
wish they would step forward
with a check ifthat?s the case."
he said.



San Antonio
March 2010
20. In fir-Gathering
Of?ce Defended
By Guillermo Contreras.
Express-News

As he bats down
allegations that he ran an
off-the-books spy operation in

Afghanistan and Pakistan. a
civilian Defense Department
official has been locked out of
his of?ce at Lackland AFB and
remains cautious about who
visits him at his San Antonio
apartment.

in interviews Tuesday and
Wednesday with the San
Antonio Express-News.
Michael D, Furlong. 56. said a
report earlier this week in the
New York Times incorrectly
portrayed the now-suspended
program he ran.

He denied allegations that
he inappropriately diverted
millions of dollars for the
operation and said his military
superiors approved the
program. which at one point
was supervised by LLS.
commanders and a separate
NATO command.

Furlong is accused of
using civilian subcontractors to
secretly collect information
that later was used to target and
kill suspected militants.

Furlong claimed Robert
Young Pclton who hosted
cable W's ?The World's Most
Dangerous Places" and was a
government subcontractor
related to Furlong's program
reported ?wild accusations?
about him to the as part of
a ?vendetta? that stoked the
agency to complain to the
Defense Department that the
program invaded its turf.

He contended that CIA
of?cials were briefed about the
program's concept and a legal
opinion was sought that
deemed the eventual Operation
lawful.

But the Pentagon has
launched internal and criminal
investigations of Furlong and
millions of dollars spent on the
program.

But Pclton said Furlong
tricked him and his business
partner into believing the
program Was meant to gather
cultural and political
information in Afghanistan and
Pakistan. and that Furlong
added components to it meant
to gather intelligence that could
have resulted in people
working for his company or
suspected militants getting

page It?!
killed.

"No. we're not engaged in
a vendetta against Michael
Furlong." Pclton said in an
interview.

He added that Furlong's
accusations are an attempt to
deflect blame for his own
ill-advised actions.

Pclton also denied having
made any claims to the CIA
about Furlong.

?That's a ?gment of Mr.
Furlong's quite imaginative
paranoia." Pclton said.

Furlong said he has been
denied access to documents
and c-mails he says can verify
his story.

?This is not about anything
but providing the best force
protection we can provide all
of those Ell-somethings in
t'oxholes.? Furlong said. ?it's
about saving lives."

The Express-News was
unable to independently verify
many of Furlong's claims
because the military also
clamped down in light of the
investigations.

The Defense Deparnnent
said it was investigating the
allegations in the Times report.
and Furlong's clairns after
being informed of them by the
Express-News.

"The department is in the
process of gathering the facts
surrouriding these allegations
to determine if there was any
inappropriate conduct.?
Pentagon spokesman Bryan
Whitman said by c-mail. ?If
any improprietics are found.
the department will take
appropriate corrective action.?

A LLS. intelligence
of?cial. who requested
anonymity bccausc of the
sensitivity oflhe matter, said in
response to Furlong's claims:
?Both DOD and CIA opposed
what this individual (Furlong)
was trying to do. If this activity
was fully authorized by the top
military brass. you've got to
ask yourself why DOD
launched an investigation. It
was DOD that shut it down.
after all."

?This wasn't a case of turf.
It was something that struck
both military and intelligence

rz-o'. area. retransmit)

2? Orr

of?cials as a serious


Trading accusations

Jeff Addieott. the former
senior legal adviser to U.S.
Army special forces. said
civilian contractors are relied
on heavily by the military and
can be used in defensive
operations. but not in offensive
scenarios.

?1 would say if we are
using them to gather
intelligence. We are not
violating the law of war as long
as they are not pulling the
trigger." said Addicott. director
of the Center for Terrorism
Law at St. Mary's University.
"But if they're involved in the
offensive use of violence. that
would be a violation."

Furlong said the
outsourced. unarmed teams he
used didn't go around ?kicking
in doors? and killing people.

He said Pclton?s claims to
the Times that Furlong referred
to his teams of contractors as
"my Jason Bournes? a
movie character spy was
fantasy concocted by Pelton.

Furlong said Peltou was
upset his company didn?t get

the entire $24.8 million
funding that Furlong was able
to get through various
?contract vehicles" to fund the
program.

Pelton called Furlong?s
allegations self-serving and
unu'utbful.

While the contractors

included former operatives of
the CIA and military special
operations forces. Furlong said
their role was to collect
information that is openly
available. such as banter at
markets or bazaars that might

contain information about
potential attacks on US.
interests.

In the pipeline

Furlong said their
inlbmiation helped prevent

assassinations of two Afghani
government of?cials friendly
to the U.S.

take stuff in open source
and throw it in the intelligence
pipeline." Furlong said. don't
take this infon?nalion and go
directly to a kill. It is not the

ManningB_?U409?05

\u-r

spot and shoot operation that
he (Pclton) is making it sound
like."

Furlong is retired from the
Army and said he is a principal
strategist. a civilian employee
of the Senior Executive
Service. for the
Nebraska-based U.S. Strategic
Command. which runs the
Joint Information Operations
Warfare Center at Lackland
AFB in San Antonio.

The center provides global

support for U.S. combat
commanders. but the matters
involving Furlong's
controversial acts occurred

while Furlong was detailed to
U.S. Central Command. which
is running theater operations in
Afghanistan and Iraq.

Furlong said the origins of
the program date to July 2008.
when U.S. forces suffered a
blow by an ambush at Wanat,
Afghanistan.

He said Anny Gen. David
McKiernan. then the top U.S.
general in Afghanistan.
reached out to the military's
network and Furlong
was called in because of his
experience in
operations.

?McKiernan was ?t to be
tied." Furlong said. ?He said to
me. need to know what's
going on outside the wire. How
can this surprise attack happen
to us??

Furlong said he was asked
to provide a ?commercial
information service that would
enhance our situation
understanding of the
environment" and offered a
proposal using former
journalists to provide ?ground
truth."

But Pelton. who also has
written books about war zones.
offered a different account.

He said he and his
business partner. Eason Jordan.
a former television news
executive. had previously set
up a pay-for-access Web site
about Iraq. iraqsloggcr.com.
and had no input from Furlong.

Pclton said McKieman
provided $1 million from his
command's contingency funds
for Patton and Jordan to

operate another Web site that
collected information about
Afghanistan and Pakistan from
open sources and to produce
reports and analyses.

Pelton said Furlong was at
the meeting with McKiernan,
and Furlong said he could fund
the proposal. known as AfPax
Insider.

McKicrnan was ?red last
May by the Ubama
administration in what some
speculated Was an attempt to
jump-start a new war strategy
that relied more on
counterinsurgency tactics and
less on conventional warfare.

Reached by phone by the
Express-News. the now-retired
MeKicman declined comment
on the matter.

The AfPax Insider Web
site Was launched after that
meeting. but Pelton said initial
payments were delayed for
unknown reasons until
February 2009. and then were
provided through St.
Pctersburg. Fla-based
International Media Ventures.

That company didn?t
respond to the Express-News?
requests for comment.

Furlong said he ran into
hurdles in getting the program
going. in part. because the CIA
?pushed back" and wanted a
legal review of his proposal.
Such a review was done and
the conceptual program was
found to be lawful. Furlong
said.

Furlong also said he
obtained $24.8 million in
funding for the program under
the Joint Improvised Explosive
Device Defeat Organization. a
Pentagon research organiration
meant to help reduce the
threats from roadside bombs.

But Pelton and Eason.
Furlong said. were removed
from the project in September
after Rear Adm. Gregory
Smith. the top military
spokesman in Afghanistan and
Furlong's boss. decided he
didn't Want AtPax's services.

And. Furlong said. a
review of its services showed it
?over-promised and
under-delivered.?

The work then was given



page 20
to other International Media
Ventures' subcontractors who
did better. he said. Furlong
declined to identify them for
security reasons. but the New
York Times identi?ed one as
Boston-based American
International Services Corp.
run by a former Green Beret.

Pelton. Furlong said. sent
him an e-mail stating that. if
AfPax didn't get reinstated. he
would ?blow this whole
operation up." something
Pelton denies.

Last fall. the New York
Times reported. the CIA's
station chief in Kabul sent a
cable to the Defense
Department complaining that
Furlong was doing things
illegally. It eventually resulted
in the military ending the
program several months before
its May 3] completion.

Furlong's version also
clashes with the claims of
Smith. who told the Times he
wasn't aWare of what
lntemational Media Ventures
employees might be doing in
Afghanistan in relation to
urlong's program.

Smith also told the Times
he opposed AfPas's proposals.
and that Furlong wanted to
spend whatever money was le?
over elsewhere. Smith said $l5
million was unaccounted for.
and that he had no idea where
the money went.

Furlong disputed this.
saying Smith had a
representative at a program
review last month in Tampa.

?This event (the Feb. 12
review) re?ected that all the
funds and contractor
deliverables were accounted
for." Furlong said. ?One thing I
am not is a crook.?



European Stars and Stripes
March [8.2010
Pg. I
21. No Gambling In The
Wanna Bet?
By Mark Patton. Stars and
Stripes

WIESBADEN. Germany
A As millions of Americans
scramble to make last-minute
adjustments to their NCAA

ii'r?. ill
eras

It?)

tournament brackets. the
Defense Department is playing
the role of bracket buster
before the tournament tips
off Thursday.

?Office pools on March
Madness are not authorired or
permitted.? according to DOD
spokeswoman Maj. April
Cunningham.

Joint Ethics Regulations
state that DOD employees are
prohibited from gambling
while on duty. or in federally
tinned offices.

But of?ces are most
March Madness pools take
place.

A recent survey by the
Spherion Corporation estimates
45 percent of workers have
participated in an of?ce pool
before. and 56 percent ofthose
who have participated
speci?cally took part in March
Madness pools. The
tournament might cost U.S.
employers as much as $l.8
billion in unproductive wages
during the ?rst week of action.
according to an annual survey
by Chicago-based placement
?rm Challenger. Gray d:
Christmas Inc.

Sgt. Michael Metabowu
with the Armored Division
headquarters said he is
participating in five different
bracket challenges this year.

The North Carolina native
said basketball brackets were a
part of his upbringing and. now
that he lives in Germany. it
doesn?t interfere with his work
because the games occur later
in the day. He said he also
participates in several of?ce
pools. including a recent
fantasy football league. where
participants pitched in $2 a
week.

?Everyone was invited to
join. of?cers and enlisted
alike," he said. think it
builds camaraderie."

But the military says
violators who misuse
government resources or
participate in gambling

between of?cers and enlisted
may be punished under the
Uniform Code of Military
Justice or face other
disciplinary actions. according

to Maj. Paul Bodnar.
spokesperson for the 66th
Military Intelligence Brigade.
Unless. that is, the
gambling comes in the form of
the playing the slot machines at
the base bowling alleys or
clubs. According to military
of?cials. some policy
exemptions exist. including the
slots that generate revenue for

Morale. Welfare and
Recreation services.
?While servicemember

demand for gambling similar to
home may be one reason DOD
provides slots. another reason
is likely the signi?cant amount
of money they generate." said
Keith Whyte. executive
director of the Washington.
DC .-based National Council
on Problem Gambling.
According to ?gures
released in 2003. annual pro?ts

from military gambling
overseas total about $184
million.

The irony is not lost on the
soldiers.

think it?s hypocritical."
said Pfc. Bobby One: with In
AD headquarters in
Wiesbaden. ?As long as you
keep your soldier mentality.
you should be allowed to
gamble."

Plus. ?lling out a bracket
is different than playing the
slots constantly. said Staff Sgt.
Wayne Washington. who was
visiting Wicsbadcn on his
leave from Fort Hood. Texas.

?Sports. it?s camaraderie.
A soldier's gonna bet on what
state or university they?re
from." Washington said.
?Gambling once a year versus
someone who comes to gamble
at slots every day is something
different: that's an addiction.

In the end. while NCAA
offico pools are illegal, don't
expect the Army to
coon-martial anyone soon for
?lling out a bracket.

Enforcement of such
gambling issues is handled at
the unit level. according to
Gary Comerford. a spokesman
in Washington for the
Department of Defense's
Of?ce of Inspector General.
The DOD does not monitor or

track DOD employees
participating in March
Madness pools unless it is a
particularly pool or
a scam. .

But ?when money?s
involved. eyebrows should be
raised." said Capt. Emilee
Elbert. an administrative law
attorney at U.S. Army
Europe's Office of the Judge
Advocate. ?What probably
happens in most situations is
we just overlook it and that's
a problem."



Time.com
March 18, 2010
22. To Battle Computer
Hackers. The Pentagon
Trains Its Own
By Mark Thompson.
Washington

After years of building
?rewalls and other defenses
against relentless hacker

attacks. the Pentagon is going
over to the dark side of
computer warfare. Only
ethically. of course. The
Defense Department. like most
large organizations. has
recognized that no wall is high
enough to keep out skilled and
determined hackers for keeps.
Instead. it has decided that in
order to anticipate and thwart
those attacks. it needs to know
what the hackers know.

"More than 100 foreign
intelligence organizations are
trying to hack into U.S.
systems." Deputy Defense
Secretary William
warned last month. "Some
governments already have the
capacity to disrupt elements of
the U.S. information
infrastructure." So the
Pentagon recently modi?ed its
regulations to allow military
computer experts to be trained
in computer hacking. gaining
designation as "certi?ed ethical
hackers." They'll join more
than 20.000 such good-guy
hackers around the world who
have earned that recognition
since 2003 from the private
International Council of
Consultants (also
known as the EC?C?ouncil}.

page 2
"We are creating
cyber~bodyguards." says

Sanjay Basivi. president of the
council. "We're not creating
combat people." But as the
world becomes increasingly
interconnected via the lntemct.
the stakes have becomc too
high to rely on static defenses
alone to protect the immense
floors of vital information that
operate the world's ?nancial.
medical. governmental and
infrastructure systems. "The
bad guys already have the
hacking technologies." Bavisi
says. "We can say. 'Tough
luck. the bad guys play by
different rules and you can?t do
anything about it. so just go
lock your doors.? Or we can tell
the good guys. Wt: will arm
you with the same knowledge
as the bad guys. because to
defeat the hacker you need to
be able to think like one.?

Basivi and the Pentagon
are sensitive to the possibility
that the tactics taught could be
used other purposes. "We're
not training Department of
Defense guys to become
hackers and start hacking into
China or any other countries."
he says. Week-long courses
will train them in l?tl different
hacking techniques and
technologies. ranging from
viruses. worms. sniffer-s and
phishing to warfare. The
cost of the course ranges from
$450 to $2.500 depending on
the training involved.

Pentagon personnel "are
not learning to hack." insists
Air Force Lieut. Col. Eric
Butterbaugh. While the
Eff-Council calls it "certified
ethical hacker" training. the
U.S. military also calls it
"penetration testing" or
"red-teaming." These are
proven military techniques that
have been used for decades to
hone war-?ghting skills. The
Air Force and Navy. for
example. maintain "aggressor
squadrons" of ES and
warplanes to give U.S. military
pilots practice against the
tactics of potential foes. And
the Army's National Training
Center at Fort Irwin. Calif. has
long boasted a highly-trained

area. txntatta Mi")

(J:
11 list)-

ManningB_OD409?06



"op-for" opposition force
that regular U.S. Army units
engage in realistic war games.

The program will be no
cure-all for the Pentagon,
whose networks are backed
hundreds of times a day. Adriel
Desautels, the chief technology
of?cer at Netragard LLC.. a
Massachusotls?bascd
anti-hacking out?t, says that
while "it's better than nothing,"
there are simply too many
vulnerabilities to protect the
Pentagon's estimated 10
million computers. Desautels
likens it to 1,000 Dutch boys
trying to stop water from
?owing through a dike
springing millions of leaks.
"The threat is de?ned by the
real black hats. and it?s
impossible to know what the
black hats are researching," he
says. "The number of
vulnerabilities far exceeds
what any white hats are going
to discover."

Both and
stisi say there are no
coneems that military

personnel trained as hackers
might go rogue. "Computer
network defense service
providers," Butterbaugh says,
?are vetted and have security
clearances." Not only that, adds
Bavisi: those named as ethical
hackers have to sign a legally
binding pledge that they will
not engage in malicious
hacking. "So far," he says, "we
haven't had a single case where
someone became a real
hacker.?1



New York Times
March IS. 2010
23. 5 Americans Held In
Pakistan Plead Not
Guilty To Terrorism
Charges
By Waqar Gillani and Jack
Healy

LAHORE, Pakistan
Five young American Muslims
detained in Pakistan in
December on suspicion of
seeking to join jihadists in
Afghanistan were formally
charged Wednesday, in a case
that added to fears that

Westerners might increasingly
be turning to lslamist-inspircd
terrorism.

The ?ve men, friends from
the Washington suburbs in
their late teens and early 20s,
pleaded not guilty to the
charges, which include plotting
attacks in Afghanistan, raising
money to commit terrorism and
planning attacks against
Pakistani allies and targets
within the country, according
to Hassan Katehela. a defense
lawyer for the men. Some of

the charges crry life
imprisonment sentences.
The ?ve are Romy

Zamzam, a dental student of
Egyptian descent at Howard
University; Ahmed Abdullah
Minni, a native of Eritrea;
Amati Hassan Yemer,
originally from Ethiopia; and
Umer Farooq and Waqar Khan,
who are of Pakistani
background. They are
scheduled to appear in court
again on March 31, when the

government is expected to
present evidence.
The ?ling of formal

charges indicated that the men
were not likely to be deported
to the United States soon.
although the possibility of their
expulsion had been raised by
American of?cials in the days
after their arrest.

Pakistani authorities said

the men, encouraged by
Internet contacts with a
Pakistani militant, went to

Pakistan last year seeking to
wage jihad against American
troops in Afghanistan. They
were arrested in early
December in the city of
Sargodha and have been jailed
there since.

At a closed hearing on
Wednesday, a district judge in
Sargodha read a three-page
description of the ?ve Charges
that had been ?led against each
man. In addition to plotting
attacks in Afghanistan. they
were accused of planning
assaults on a Pakistani nuclear
power plant and Pakistani air
force bases in Sargodha and
the central city of Miariwali,
Mr. Katehela, the defense
lawyer. said in a telephone

interview.
The ease of the ?ve young
men is among a handth of

high-pro?le terroriSm cases
that have recently stimed
concerns about the

radicalization of Muslims in
the United States.

This month, a New Jersey
man accused of joining Al
Qaeda was arrested in a sweep
in Yemen, then shot a guard to
death at the hospital where he
had been taken for treatment,
the authorities said. A federal
indictment unsealed last week
tied a woman
who called herself Jihadlane
on the Internet to a plot to kill a

Swedish artist who had
depicted the Prophet
Muhammad's head on a dog?s
body.

David C. Headley of
Chicago was accused in

December of helping to scout
out locations for the deadly
attacks on Mumbai, India. in
2008, and has also been
charged with planning to attack
a Danish newspaper that
incensed many Muslims by

printing cartoons with the
image of the Prophet
Muhammad.

Mr. Headlcy was expected
to plead guilty on Thursday.

Najibullah Zazi, an
Afghan immigrant who worked
at a co?'ec stand in lower
Manhattan, pleaded guilty in
February to plotting to bomb
the New York subway.
American authorities called the
case one of the most serious

threats since the Sept. 11
attacks.
Other cases that have

drawn concem include those of
the several Somali-Americans
in Minnesota who returned to

Africa to ?ght alongside
Islamic militants who control
much of Somalia; the

Muslim-American
accused of shooting [3 people
to death at Fort Hood. Tenn,
and a Long Island man who
converted to Islam and traveled
to Pakistan and Afghanistan to
join up with militants.

Wirqu Gifford reported
from Lahore, and Jack Heal}!
from New York.

page 22



Reuterscom

March 17, 2010

24. Americans Have
Direct Access To
Taliban No. 2

By Adam Entous. Reuters

WASHINGTON U.S.
investigators have recently
been given more regular direct
access to Pakistani-led
interrogations of the Afghan
Taliban?s No. 2 leader, US.
of?cials said on
one month alter his arrest was
announced.

Pakistani limitations on
US. access to Mullah Abdul
Ghani Baradar have been a
source of tension since he was
captured in the port city of
Karachi. The joint operation
that nabbed the Taliban's top
military commander has been
so shrouded in secrecy that
US. and Pakistani of?cials
could not even say with
certainty what day it took
place.

It was unclear whether the
direct U.S. access, disclosed by
of?cials who requested
anonymity, was yielding useful
intelligence.

But the commander of
U5. and NATO forces in
Afghanistan, General Stanley
McClu'ystal, held out Baredar's
arrest as a potential
game-changer. telling reporters
separately that it "seems to
have shaken the con?dence of
some of the Afghan Taliban
leadership." did
not discuss the interrogation
issue.

Previously undisclosed
details about the joint
U.S.-Pakistani raid. believed to
how taken place in late
January. shed new light on
what has been described in
Washington as a major
intelligence and propaganda
coup that could open divisions
within Taliban ranks and
weaken a deadly insurgency
after eight years of war.

But many questions
remain unanswered, such as
whether Pakistan's powerful
intelligence service was

?tment

LII

ManningB_00409T07

turning against its long-time
Taliban allies. or took action
against Baradar to ensure its
interests would be represented
in any future reconciliation
process.

"We see indications that
they are trying to ?gure out
what way ahead that they
should plot." told
reporters in a conference call
from Afghanistan. referring to

the tentative response of
Taliban leaders to Baradar's
arrest.

Mark Sedwill. a British
diplomat serving as the senior
NATO civilian of?cial in
Afghanistan, said; "In a sense I
think they (Afghan Taliban
leaders) are recalibrating
because they don't yet know
where they stand. That's a good
thing -- we want them to be
uncertain about their future."

"This is going to be a real
poker game with these guys
over the next few months."
Scdwill added. referring to the
possibility that some Taliban
leaders might opt to reach out
for a deal.

Pakistan has balked at
handing over Baradar either to
the United States or to
Afghanistan for interrogation.
and some U.S. of?cials have
complained privately about a
lack of direct access to the
secret interrogation sessions.

U5. FBI director Robert
Mueller was in Islamabad late
last month to discuss the issue
and to press for more access
for US. investigators.

"There is direct access to
him." a US. of?cial said on
condition ol'anonymity.

He described the level of

direct access of late as
"de?n iter more than
minimal."

"More information is
coming out of these
discussions." the of?cial

added. though he declined to
say whether any of the
information was useful to the
U.S. government or military.
Initially. U.S. of?cials
characterized the intelligence

value as minimal. But a
mi litury of?cial said on
Wednesday that a "good"

amount of information was
?owing to commanders and
"the hope is this is a precursor
of things to come.

New information from
U.S. officials about the Karachi
operation cast doubt on what
some observers termed the
"dumb luck theory" of how
Baradar was captured that he
was swept up in a raid
targeting others.

"This wasn't a case of
simple happenstanee." said a
US. counterterrorism of?cial
familiar with the operation.

"There was intelligence
that came together and made
this a Baradar-related

operation. There were strong
indications in advance that the
capture would involve, if not
him. at least some of his
associates." the of?cial added.
The arrest was not
disclosed because "it took a
while to identify Baradar"
conclusiirely. the
counterterrorisrn of?cial said.
US. of?cials and
are still debating Pakistan's
motives, The arrest followed
Afghan President Hamid
Karzai's announcement of a
high pro?le effort aimed at

reconciling with Taliban
leaders.

There have been
con?icting reports that
Baradar. the former top

Taliban military commander.
might haste been talking to
Kabul. and that may have led
to his arrest.
Additional
Sue Fleming.

reporting by



Washington Post
March 18. 2010

25. Discloses

US. Base Plan
By News services

Of?cials in the
impoverished Central Asian

nation of said the
United States plans to build a
$5 million military base for
training local troops.
already hosts a
US. base in Mamas. outside the
capital. Bishkek. which is used
as a regional hub for the
ESL-led war in nearby

Afghanistan. The Kyrgin
govemment last year backed
off a threat to evict U.S. forces
from Manas alter Washington
offered to triple its rent.

From new services



Defeanewscom
March 17. 2010
26. 0.5. Says Okinawa
Base Needed To Defend
Japan
By Shaun Tendon, Agence
France?Presse

WASHINGTON -- The
United States said March 17
that it needs to maintain a base
on the Japanese island of
Okinawa to defend the region.
as the new govemment in
Tokyo considers scrapping a
previous plan.

Senior US. of?cials told

Congress that while they
respected the decisions of
Prime Minister Tukio
Hntoyarna's six-month-old

government. they hoped to go
ahead with a plan to move the

Futenma air base within
Okinawa.

Michael Scltitfer. a senior
Pentagon official. told a

congressional panel that troops
in Okinawa were the only
ground forces "between Hawaii
and India" which the United
States could quickly deploy.

"Futenma may be but one
base and one part of a larger
alliance relationship. but peace
and stability in the region
depend in no small part on the
enduring presence of forward
deployed U.S. forces in Japan."
said Schiffer. the deputy
assistant secretary of defense
for Asia.

"The United States cannot
meet its treaty obligations to
defend Japan. cannot respond
to humanitarian crises or
natural disasters. cannot meet
its commiUHents for regional
peace and stability without
forward deployed ground
forces in Japan.? he said.

He said the Futenrna move
was a "lynehpin" of 2006
deal under which more than
8.000 US. troops would leave
Okinatva for the US. territory

00158

page 23-
of Guam.

Under the agreement.
Futenrna would move from the
crowded urban hub of
Ginowan to a quiet village.

Schiffer and Joseph
Donovan. his counterpart at the

State Department. both
testi?ed that the deal was the
best solution to limit the
impact on Okinawa while
maintaining troops in the
region.

But some of Hatoyama?s
left-leaning allies want the base
moved entirely out of Japan.
blaming the noops for noise
and crime.

Despite President Barack
Obama's support for the 2006
deal. several lawmakers from
his Democratic Party have
voiced sympathy for
Okinawans' grievances.

Rep. Eni Faleomavaegm a
Democrat who heads the
House Foreign Affairs
subcommittee on Asia. pointed
out that Okinawa accounts for
one percent of Japan's land but
two-thirds of bases
deployed there.

"The Okinawans feel like
they're always being the
whipping boy for the last 50
years. We just put our military
people there and don't have to
worry about it." Falcomavaega
said.

But Republican Rep. Ed
Royce of California said that
the Hatoyama government had
"badly handled" the Futenma
issue.

"The alliance has been a
force for stability in a very
tough neighborhood but there
is cause for concern." Royce
said.

"Japan?s government is
inexperienced. Some Japanese
leaders would like to see
Tokyo tilt more towards
Beijing." he said.

Hatoyama has called for a

more equal relationship
between Tokyo and
Washington and suggested

creating an East Asian regional
network without the United
States. which stations 41000

troops in Japan under a
security treaty.
lehiro Dzawa. the

Hit. arcs. EXHIBIT nee)

Manninga_eo4osroa

backroom powerbroker of the
ruling Democratic Party of
Japan. in December took
hundreds of lawmakers to visit
Beijing. sending the United

States scrambling to invite
more Japanese MP3 to
Washington.

But most U.S. are
doubtful about a wider shift
toward Beijing. noting that
Japan has deep-rooted
historical tensions with China
and longstanding concerns
about the giant neighbor's
soaring military budget.

US. expectations of Japan
may be colored by the
2001-2006 premiership of
Juniehiro Koizumi who broke
taboos by sending troops to
Iraq and defying China. said
Michael Auslin. a scholar at
the American Enterprise
Institute think tank.

"Ii'anything. current trends
in Japanese policymaking.
including Japan's recent
outreach to China. re?ect a
retunt to a more traditional
Japanese position that attempts
to maintain some level of
balance in Japanese foreign
policy." Auslin said.



Reuterscom

March 17. 2010

27. North Korea Has
1,000 Missiles, South
Says

By Jack Kim. Reuters

SEOUL -- North Korea
has increased its missile
arsenal by 25 percent in the
past two years to about 1.000.
expanding the threat the state
poses to the region. the Smiths
defense chief said Wednesday.

Pyongyang's arsenal
includes intenncdiate-range
missiles that can hit targets at
up to 3.000 km miles}
away. Yonhap news agency
quoted Kim Tao-young as
telling a forum of business
leaders.

The missiles could hit all
of Japan and put U.S. military
bases in Guam at risk.

South Korea?s last estimate
of the North's missile stockpile
was $00 done in 2008. Yonhap

said. Its Defense White Paper
in 2008 said the North had
deployed the intermediate
range missile.

The estimate comes at a
time when the North is seen to
be under increasing pressure to
return to six-party talks on
nuclear disarmament,
following economic sanctions
imposed on it after its nuclear
test in May 2009.

North Korean leader Kim
Jong-il has been trying to hold
the destitute state together as
its economic troubles mount.
the South Korean defense
ol?eial said.

"Kim long-ll is struggling
to stabilize his regime and hold
its system together and has
been focusing on securing
resources from the outside
while maintaining a planned
economy." he said.

A botched attempt to
reform the currency triggered
anger among an already

importerished public because it
stoked in?ation.

News reports said Kim
may visit China late this month
for the first time in four years
to shore up investment from
his biggest benefactor in new



projects his country has
launched to increase its meager
international trade and
commerce.

Korea Herald

March IS. 2010
28. 'Kim Jung-i] Has

Three Years Left'
By Kim So-hyun

North Korean leader Kim
Jung-ii. whose questionable
health has received
international attention. appears
to have three years left to live.
a senior US. of?cial was
quoted as saying.

Kurt Campbell. U.S.
assistant secretary of state for
East Asian and Paci?c affairs,
voiced his observations on
sonsitive issues such as Kim's
life expectancy and
Pyongyangs preparations for
power succession during a
closed-door meeting with
South Korean lawnmkers and
defectors from the North at the

US, embassy in Seoul on Feb.
3. multiple participants said.

"Medical analyses suggest
that Kim has another three
years left to live." Campbell
was quoted as saying during
the meeting.

South Korean observers
suspect the 68-year-old Kim
may have a kidney disease.
judging from his usually white

?ngernails in recent
photographs and from bits of
intelligence. Kim reportedly

suffered a stroke in the summer
of 2003 and disappeared from
the public for months.

Campbell also noted that
the power transfer process
from Kim Jong-il to his third
son long-eon was entirely
different from that of the Kim
lI-sung-Kim long-i]
succession. to a
participant.

The US. of?cial said that
Chang Song-thaek. Kim
Jong~il's brother-in-law and
chief of administration at the
North Korean Workers' Party.
will serve as the guardian once
Jong-eun takes over.

Campbell also mentioned
the possibility of cracks in the
relationship between the junion
Kim and his uncle. participants
said.

Campbell was on a
three-day visit to Seoul for
discussions with South Korean
of?cials on North Korea and
the Washington-Seoul alliance.

according



New York Times
March 13. 2010
29. Clinton To Meet
With Russian Leaders
On Arms Control Talks
By Mark Landler

SHANNON. Ireland
With the United States and
Russia still haggling over the
fine print of a long-delayed
arms control pact. Secretary of
State Hillary Rodham Clinton
left Washington on Wednesday
for high?level meetings in
Moscow. as the Obama
administration tried to push the
talks across the ?nish line.

Mrs. Clinton planned to
meet President Dmitri A.

00159

page 2-1
Medvedev of Rossia and the
foreign minister, Sergey V.
Lavrov. who expressed
con?dence last week that a
deal could be reached by the
end of the month.

That would allow
President Dbama to present. the
agreement. which would make
deep cuts in the nuclear
arsenals of both countries. at an
international summit on
nuclear non-proliferation next
month in Washington.

?Certainly this is a
moment when we've made a
lot of progress and we certainly
hope to make more. and the

secretary?s involvement is
extremely important." the
undersecretary of state for
political affairs. William J.
Burns. said to reporters
traveling on Mrs. CI inton' 5
plane.

?We want to move ahead
to ?nish the agreement.? he
said.

In Moscow. Mrs. Clinton
will also meet with leaders
from the Eumpean Union and
the United Nations. as well as
Russia. to discuss the fallout
from a sharp con?ict between
the United States and Israel
over the Israeli govemment's
announcement of a housing
plan for Jews in East Jerusalem
last week.

Although an anus deal
could theoretically be
announced while Mrs. Clinton
is in Moscow. the months of
tortuous negotiations have
made administration of?cials
extremely leery of predicting
the end of a process they had
once claimed Would be
wrapped up by the end of last
year.

In recent weeks. Mr.
Obama has thrust himself into
the negotiations. speaking
twice by phone with Mr.
in the last three
weeks. In the ?rst call. Mr.
Obama was surprised to hear
the Russian president raise
several fresh hurdles. including
the revised American plan for a
missile-defense system. which
Mr. Obama believed had been
settled by negotiators in
Geneva.

IHV. UFCR. EXHIBIT a MW)
93 aegis/.5.

ManningE_00409?09

?Every time you think
you ?re done, new issues pop up
in Geneva1 and what seemed
like trivia become major
political issues,? said another
senior administration official.
speaking on the condition on
anonymity because he was not
authorized to speak publicly.

Now, both sides said the
talks were back on track,
though administration of?cials
concede there were still
differences over a hand?rl of
issues like transparency and the
missile defense system. Russia
reacted badly to an
announcement in January that
Romania would host part of the
system, and reintroduced a
demand that the treaty contain
language limiting the system.

Mr. lDbamta held a second.
more upbeat, call with Mr.
Mcdvedcv last Saturday, and
the White House hopes that
Mrs. Clinton's meeting with
the Russian president at his
dacha will build on that
momentum.

?Otherwise. it does not get
done," the of?cial said.
?Otherwise. it drags on like the
last Start Treaty, which I think
took nine years."

The agreement, which
would replace the Strategic
Arms Reduction Treaty of
1991, or Start. would be a
symbol of the new relationship
Mr. Dbama is trying to forge
with Russia. It would reduce
deployed strategic warheads
and delivery systems by at
least 25 percent.

Citing another sign of
better ties between the
countries, of?cials said that 30
percent of supplies for
American troops in
Afghanistan were now being
shipped through Russian
territory, either by airplane or
train.

Mrs. Clinton is also
expected to seek a public show
of support from Russia for
tougher United Nations
sanctions against Iran. which
could help the administration
press its case with a resistant
China.

Russia has been more open
to a harder line toward Tehran

ManningB_0040971D



since the [ranian government
rebuffed a proposal to ship
much of its
uranium to Russia and France
to be enriched to a higher level
to fuel a research reactor in
Tehran that produces medical
isotopes,

But China has so far
insisted on using diplomacy
rather than additional
sanctions, which has left the
United States scrambling to
line up international support
for a resolution in the Security
Council.

Mr. Burns, the
undersecretary of state, said he
was con?dent a resolution
would he adopted. though he
did not offer a timetable.
?There?s a sense of urgency
that we feel, and We'd like to
move this ahead as quickly as
we can," he said.



New York Times
March 13.2010
30. Ukraine: Venue
Offered For Arms Talks
By Andrew E. Kramer
Ukraine's new president,
Viktor F. Yanultovich, has
offered Kiev as a location for
the United States and Russia to
sign a revamped noclcar arms
reduction treaty, once it has
been agreed to. Though the
peace agreement is unrelated to
Ukraine. having the treaty
formally signed in Kiev. the
capital. would be rich in
symbolism for a country whose
recent internal politics became
a tug of war between Russia
and the West for economic and
political in?uence. Mr.
Yanukovich, though he is
generally viewed as leaning
heavily toward Russia, has
promoted the idea of Ukraine
as bridge between East and
West. rather than a country that
falls readily within either
sphere of influence. Russian
of?cials welcomed the offer;
the United States would prefer
Prague. where Presith
Obama gave a speech on
disarmament last year,
Ukraine's new foreign
minister, Kostyantyn
said Wednesday.



Reuterscom

March li?. ROI [1

31. Obama Says US. To

Pursue Aggressive Iran

Sanctions

By Jeff Mason and Deborah

Charles. Reuters
WASHINGTON --

President Barack Obama said

on Wednesday the United
States would pursue
?aggressive sanctions" to

prevent Iran from getting a
nuclear weapon that could
potentially spark a nuclear
arms race in the Middle East.

Obama, who had made the
goal of pursuing dialogue with
[ran a cornerstone of his
administration's foreign policy
at the beginning of his
presidency, said he had been
successful in getting the
international community to
isolate Tehran.

"As we've seen, the Iranian
government has been more
concerned about preventing
their people from exercising
their democratic and human
rights than trying to solve this
problem diplomatically."
Obama said in an interview on
Fox News Channel's Special
Report with Bret Baier.

"That?s why we're going to
go after aggressive sanctions.
We haven?t taken any options
off the table. We are going to
keep on pushing," Obama said.

Iran denies it is seeking to
build a nuclear bomb and says
its nuclear program is aimed at
generating clecuicity.

Obama said preventing
Iran from acquiring a nuclear
weapon was one of his
administration's highest
priorities.

"It is a hard problem but is
a problem that we need to
solve because if Iran gets a
nuclear weapon then you could
potentially sea a nuclear arms
race throughout the Middle
East and that would be
tremendously damaging to our
national security interests," he
said.

US. of?cials said on
Tuesday the pace of lran's

lio'r.

i:l i:

page 25
nuolear weapons development
appears to have slowed. buying
time for a new round of
sanctions now and potentially
more sweeping measures later.



Reuters.com

March 17. 2010

32. Clinton, Gates To

Mexico To Talk About

Drug Fight

By Deborah Charles. Reuters
WASHINGTON US.

Secretary of State. Hillary

Clinton will lead a top-level
delegation to Mexico on March
23 to discuss efforts to fight
drug cartels, [0 days after three

people linked to a US
consulate were killed in a
border city.

State Department

spokesman PJ. Crowley said
Clinton would be accompanied
by Secretary of Defense Robert
Gates, Homeland Security
Secretary Janet Napolitano and
Director of National
Intelligence Dennis Blair as
well as other senior national
security officials.

They will be meeting to
discuss the US. Merida
Initiative. a 200? plan to give
Mexico $1.4 billion to help
?ght the country's powerful
drug cartels. Crowley said the
meeting had been in
preparation Ibr several months.

Two Americans and one
Mexican linked to the US.
consulate in Ciudad Juarez,
just over the border from El
Paso, Texas. were killed on
Saturday. The killings were
part of a surge in drug-related
violence along the
border.



CNN
March 17, 2010
33. Cops Out Lesbian
Staff Sgt.
American
(CNN). 8:00 AM
KJRAN CHETRY: For
nine years, she kept a secret.
Jenc Newsorne didn't tell
anyone in the Air Force she
was a lesbian. Then just as
momentum was building to

Morning





repeal the military's "Don't
Ask. Don?t Tell" policy. Jene
was outed by a third party. lt
was actually her local police
department in South Dakota

alter they saw an Iowa
marriage certi?cate in her
home.

JOHN ROBERTS: She's
now discharged from the Air
Force. Jene and the American
lCivil Liberties Union have
?led a complaint against the
Rapid City Police Department.
saying that the of?cers violated
her privacy. The police
department. meanwhile,
maintains they were simply
following routine procedures.

Jene joins thus morning
via Sirpr from Fairbanks.
Alaska. Good to see you this
morning. Just to set the stage
here. you got married. as Kiran
. said. in Iowa last October to
your partner. Cheryl Hudson.
You were sticking by the
"Don?t Ask. Don't Tell" policy
until this incident with the
Rapid City Police Department.

?What happened. and how
did your sexual orientation get
reported up to the military?

JENE NEWSOME: Well.
they just came to my home
back in November. and like
they said. they said they seen
the marriage certificate and
pretty much reported it to the
military. But I think they were
upset that I didn?t cooperate as
well as they wanted me to
during the situation.

ROBERTS: Now. just in
terms. by way of further
explanation of why the police
department was at your home,
they were there to serve a
felony arrest Warrant on your
ptu'tner'?

NEWSDME: Correct.

CHETRY: And how did
they see your marriage
certi?cate?

NEWSOME: They said
they seen it on the kitchen table
through the window.
supposedly. It doesn't make
much sense to me. but that's
what they said.

CHETRY: So. what do

for something. or they might
have seen it a little bit and
could tell it was some type of
document ?'om louvre. But i
think that they looked into it
further.

ROBERTS: So the real
point in all ofthis. Jene. is why
the police department reported
your marital status up to the
military. We know that one of
the officers who was there at
your home is a member of the
Army National Guard.

Was there any reason in
your mind for the police
department to report the
existence of this marriage
certi?cate to the military?

NEWSOME: I don't think
there was much of a reason.
They wanted me to come home
from work so I could open up
my home to them. and was
unable to leave work. And I
think the of?cer was upset over
the situation and that's why he
reported it.

He explained to me that he
knew how the military worked
and he explained to me that he
Was in the Army National
Guard and he would just let the
military handle it.

ROBERTS: In your
knowledge. is it common for
the police to report to the
military if the spouse of a
member of the armed services
is involved in some sort of
criminal complaint?

NEWSOME: No. No. it's
not.

CHETRY: Well, here's
what they're saying. the Rapid
City police of?cers. They gave
us this statement. and I'd like to
get your reaction. They said the
arrest report was later
forwarded by a detective to the
United States Air Force
consistent with long-standing
practices of open
communication when military
personnel have contact with
local law enforcement.

They go on to say they
regret that the information led
to your discharge and they say
it's best addressed by the Air
Force. They say they were

NEWSOME: don't
believe that because usually if
the military member is in some
kind of trouble with the law
and committed a crime of some
sort. And that wasn't the case
with me.

ROBERTS: And in your
knowledge. again. that doesn't
extend to the spouse or a
family member of a member of
the military services?

NEWSOME: No. it
doesn't.
ROBERTS: 0K. The

police department is make
nothing apology. as we said.
saying that the oflieers acted

properly according to
depanment procedure.
But last month the

secretary of defense. Robert
Gates. said that the military
would. quote, "raise the bar of
credible information needed to
institute an inquiry in "Don't
Ask. Don't Tell,? and might
even stop dismissing Hoops

based on third-party
accusations. which is what
happened here.

You were discharged hack
in January. I'm wondering if,
based on what Secretary Gates
said. you might make a case
for reinstatement. Do you think
it's maybe too late. or Would
you even want to do that?

NEWSOME: Well. if they
decided to drop "Don't Ask.
Don?t Tell" altogether. it's a
great consideration.

How frustrating
is it for you knowing that
"Don?t Ask, Don't Tell" was
pending. the repeal of it.
knowing that it's something
that has been called for now by
many. and knowing that you've
been discharged because a
third party outed you?

NEWSOME: It's very
?nstratjng. I was looking
forward to the change. I

believed in the change. And it
was a great disappointment
when I found out that was
being discharged. especially
under the circumstances.
ROBERTS: Jene
Newsomc. thanks for joining

page 26
ROBERTS: Thanks again.



Washington Times
March 18. 2010
Pg. it
34. Inside The Ring
By Bill Gert:
Cyberwarfare coming
The Pentagon?s massive
worldwide computer networks
were hit with a major
malicious so?ware attack in
2008 through a computer flash
drive inserted into a computer.
The electronic strike was a
watershed event that triggered
cybersecurity improvements
and a temporary ban on the use
of portable storage devices. the

commander of the US.
Strategic Command said
Tuesday.

Air Force Gen. Kevin
Chilton. commander of the
Strategic Command. told a
House hearing that such
penetrations are an example of
the types of threats facing the
military as it gears up for
computer warfare and the
creation of a new cyberwarfarc
command.

"We can anticipate that
adversarial actors will make
cyberspace a battle ??ont in
future warfare." Gen. Chilton
said. ?Even today. intrusions

and espionage into our
networks. as well as
eybe r-inci dents abroad.

highlight the unprecedented
and diverse challenges we face
in the battle for information."

Gen. Chilton described the
penetration as a "serious
intrusion" he called a "seminal
event" for the military and
Pentagon.

Defense officials said at
the time that the sophisticated
electronic computer break-in
likely was canied out by the

Chinese government or
military, although attributing it
directly to Beijing was
dif?cult.

Lt. Cmdr. Steve Curry. a
Strategic Command of?cial.
said later that the 2008 attack
involved "particular variants of

you think really happened? followmg long-standing us this morning to tell your computer wont?ts" that
NEWSOME: I think that practices. You say you don't story. We do appreciate it. ?infected computers

they were just looking. looking necessarily believe that. Why? NEWSOME: No problem. and targeted Mlcr?so?
Pg F5 ..

Windows operating systems."
He declined to provide further
details. citing security
considerations.

Gen. Chilton said that as a
result of hacking. "our forces
developed new network
monitoring and evaluation
systems and grappled with the
security needs of sprawling
networks where low cost and
ef?ciency have often taken
priority over security."

Strategic Command is
moving ahead with plans
announced in October to set up
a new US. Cybezr Command
near the National Security
Agency at Fort Meade. Md.

In a ?rst step. two units
already are being consolidated.
The Joint Task Force-Global
Network Operations, which
conduets cyberdefcnse. is
being put together with the
Joint Functional Component
Command for Network
Warfare. the offensive
cyhenvarfare component. he
said.

"We've already started to
unify those two mission areas."
Gen. Chilton said.

The new subcommand has
been delayed by the Senate.
which has yet to hold hearings
on the nomination of its
commander. current NSA
Director Army Lt. Gen. Keith
Alexander.

Conventional vs. nuke

James N. Miller. deputy
undersecretary of defense for
policy. told Congress this week
that the Pentagon is working
on conventionally armed
loug?range missiles and other
non?nuclear strike weapons as
part of its efforts to limit
nuclear weapons.

Mr. Miller said the effort

grew out of the recent
four-year strategy review.
Pentagon officials are "now
studying the appropriate

long-term mix of non-nuclear
long-range strike capabilities.

including penetrating and
standoff bombers. cruise
missiles. and conventionally

armed ballistic missiles." Mr.
Miller told the House Anned
Services strategic forces
subcommittee.

The use of conventionally
tipped. long-range missiles was
opposed in the past by some in
Congress who feared their use
would trigger a nuclear war if
states such as Rossia and China
misinterpreted any launch of a
non?nuclear as a nuclear
attack and they ?red their
nuclear missiles in retaliation
as part of what is called
launch-on-warning.

Air Force Gen. Kevin
Chilton. commander of the
US. Strategic Command. who

appeared with Mr. Miller
before the House Anned
Services strategic forces
subcommittee on Tuesday. said
he does not support a
one-for-one replacement of
nuclear warheads with

precision-guided conventional
bombs or missiles-
Conventional-missile
strikes can be a deterrent to an
invasion of South Korea by
North Korea. but "we have to
be careful when we start
talking about one-for-onc
substitutions of conventional
weapons for nuclr Weapons."
he said.
"whm
deterrence

it comes to the
mission. not the
war?ghting mission
necessarily. the nuclear
weapon has a deterrent factor
that far exceeds a conventional
threat." he said.

Rapid global strikes with
non-nuclear missiles would be
"an additional weapon in the
quiver of the president" during
a crisis when only nuclear
missiles are a timely option. he
said.

"But the connective tissue
between that and the
one-for-one exchange for a
nuclear deterrent. I'm not quite
there." he said.

The effort is expected to
be outlined in detail in the
Nuclear Posture Review the
Pentagon is expected to make
public next moulh.

Mr. Miller said the new
Strategic An'ns Reduction
Treaty being negotiated with
Moscow is expected to be
completed in the next few
weeks. It is aimed at cutting
nuclear weapons to between



1.5130 and 1.635 warheads and
between 500 and 1.100
missiles and bombers.
Anti-military fatwa
Pentagon spokesmen
declined to comment on the
fatwa, or religious edict. issued
sevEral years ago by the
Assembly of Muslim Jurists in
America (AMIA) that prohibits
Muslims from providing food
to US. and allied troops
working in Muslim countries.
such as Iraq and Afghanistan.
The fatwa by Main Khalid
al-Qudah is dated June 20,
BUM. and was issued in
response to the question of
whether a Muslim who owns a
shipping company is allowed
under Islamic law to transport
food from a storage facility to a
harbor. "knowing that these
supplies will be sent to soldiers
Working in Islamic countries
under the auspices of the allied
forces."
"That would not be
permissible. for that would be

helping others in sin and
transgression." the fatwa
stated.

According to terrorism

the fanva highlights

the shortcomings of the
Pentagon?s aggressive
"outreach" program to

American Muslim groups over
the past several years.
According to critics. the
program sought to win over the
groups. but often included
Muslims organizations with
ties to the radical Muslim
Brotherhood. the Egyptian
group that has provided the
ideological underpinnings for

al Qaeda.
Patrick Poole. a
counter-terrorism specialist.

said the fatvva indicates the
Pentagon's efforts to mitigate
the threat from American
Muslims through public
outreach is not working.

"For years. the Pentagon
has invested heavily in various
Muslim-outreach programs.
only to ?nd time and again that
they were one-way. dead-end
streets." he said.

Mr. Poole said the
outreach effons are misguided
because the Pentagon has beau

page 2?

?reaching out to the wrong
Muslim leaders."

"The best example is the

Pentagon's reliance on
Abdurahman Alamoudi to
establish their MUsl im
ehaplaincy program in the

[9905. and who at the time was
al Qaeda?s top American
fundraiser and the most
prominent Islamic ?gure in the
country." he said.

Alamoudi. founder of the
American Muslim Council. is
currently serving a 23?year
prison term on
terrorism-related charges.

"In that the Pentagon
ignored many calls of concern
about Alamoudi's outspoken
extremism." Mr. Poole said.
"And now that we see with
these anti-military fatwas
issued by top American Islamic
leaders that nearly two decades
of outreach efforts to the
Muslim community are utter
failures. the Pentagon doesn't
want to address the fact that
they are not working."

Paul Sperry. a journalist
who specializes in Islamist
extremism. said the AMJA is
known to be close to Muslim
Brotherhood leaders who often
pose as moderate American
Muslim scholars.

"Many of them
Islam at the
Brotherhood-condoned
American Open University." he
said. "That's why their rulings
are so strict in their compliance
to medieval Shariah code.
including advocating
adherence to barbaric 'hudood'
punishments for crimes against
Islam." Hudood is the Islamic
practice of beheading
apostates. cutting off the limbs
of thieves or stoning women
for in?delity.

A spokesman for the
AMJA could not be reached
for cemment.

A second American
Muslim. the Yemen-based al
Qacda. leader Anwar al?Awlaki

teach
Mosl im

also has issued a fatwa
declaring the wars in Iraq and
Afghanistan to be crimes

against Muslims.
He warned other American
Muslims not to serve in the

arcs. EXHIBII i} no?)
Pg {1535

Hill.

ManningB_OO409712

LLS. military or support U.S.
military efforts. He also has
issued a fatwa that said U.S.
troops and bases should be
attacked.



London Times
March 18. 20th

35. Somali Pirates
Captured After
Attack On

Dutch Warship

By Foreign Staff, Nairobi

Dutch Marines fought off
an ill-advised attempt by
pirates to hijack the warship
Tromp off the coast of Somalia
yesterday.

Troops ?red warning shots
when the pirates raced towards
them in small skiffs
prompting a swift about-turn
and an unsuccessful attempt to
flee when the pirates realised
their mistake. The skiffs were
later sunk and the pirates'
weapons con?scated. "It shows
a lack of sophistication but
it is a wanting that they will
attack any vessel." Commander
John Harbour, an EU Naval
Force spokesman, said.

The EU Naval Force has
dismpted ll pirate attack
groups off the coast of East
Africa over the past two weeks
as part of a more o??cnsivc
mindset to stop pirate attacks,
he said.

say piracy will
continue to be a problem until
an effective government is
established on Somalia's
lawless shores. It has not had a
functioning government since a
socialist dictatorship dissolved
into civil war years ago.
The current administration is
too busy ?ghting an Islamic
insurgency to tackle the
well-anncd and well-funded
pirate bases along its
Minn-mile long coastline.

The London-based
International Maritime Bureau
says Somali pirates captured 47
vessels last year and launched
21? attacks. More than 100
crew are still being held.



NBC
March 17. 201i]

ManningB_00409?13

36. Making A Difference

NBC News.
PM

BRIAN WILLIAMS:
We?re back with our ?Making
A Difference" report tonight.
It?s about a military tradition in
this country dating back to the
time of the cavalry, using a
horse-drawn hearse -- a caisson
-- at military funerals.

With 1.800 American
veterans dying each day on
average. it?s a rare honor these
days. But one woman is
personally making sure some
people do get to continue this
tradition.

Her story tonight from
NBC's Roger O'Neil.

ROGER it is a
solemn and lonely lane they
travel. The silence broken by
the steady cadence of the
horse. whose ancestors once
carried warriors into battle. But
on this day, Lorraine Melgosa
and her Percheron carry a
warrior to a more pcace?il
place. with poignant words
from a poem.

LORRAINE MELGOSA
[Ownen Homanrawn Hearse];
?My task is no burden for the
honor is great. With courage
and pride, he died for his
country.?

For five years,
the plain spoken farmer from
Colorado has traveled
thousands of miles over four
states. This is her duty. she
says. to soldiers she did not
know.

MELGOSA: These brave
men and women that
voluntarily raise their hands
and said I'm going to protect
this nation, then I need to raise
my hand and help honor those
that did that.

This is the 39th
flag-draped east-tin the carriage
driver and her horse have taken
to their ?nal resting place. She
expects nothing in return.

Charlene Westbrook says
Lorraine's big horse and big
heart made burying her soldier
husband Kenneth a little easier.

HARLENE
WESTBROOK [Wife of
Deceased Soldier]: For her to
sacri?ce. you know. her time.

?1

her money and for her to do
this for our family. there were
no words.

MELGOSA: ?For with
dignity and grace, I?ll carry
him home. With each strike of
my massive hooves, his soul
will soar in the heavens
above."

The poem ends:
?Down the lane slowly, I'll
go." As one said, with a horse,
a hearse, and a sense of duty, a
woman pays tribute to fallen
heroes.

Roger O'Neil, NBC News,
Colorado Springs. Colorado.



New York Times
March 18, 2010
37. He Asked. They

Told.
By Laurie Wincr

Los Angeles -- AFTER he
posted the ?rst seven pictures
on his Web Site, .lcff
could not sleep.

kept getting up and
checking my c-mail," he said.
?l was expecting to hear from
someone in the military. What
if they demanded information
?'om me? Some of the people
photographed have been
serving for 20 years. They
could lose their pensions."

Mr. a
photographer, had ?nished the
?rst phase of ?Don?t Ask.
Don't Tell." a series of
poi-nails of gay men and
lesbians serving in the military,
all ofthem in uniform and with
their faces obscured in some
way by a hand. a door ?ame
or by darkness. Some subjects
turn their backs to the camera.
In one image an airman who
takes the pseudonym Jess sits
on a hotel bed leaning inward.
One elbow rests on his knee.
his hand cupping his face to
shield it from the camera. The
portrait is pervaded by a sense
of loneliness and isolation.

?Don't Ask, Don?t Tell,? a
self-published book
{dadtbook.com; $24.95}, had
grown out of Mr. Sheng?s
earlier project, ?Fearless,?
which featured large. glossy
portraits of young athletes who
are openly gay, bisexual or



page 28
transgender. Since 2006,
"Fearless" has toured more

than 40 colleges and high
schools in the United States
and last month was shown at
Pride House, a space created at
the Olympic Games in
Vancouver, British Columbia.
for gay athletes to relax with
family and friends.

?Fearless,? in turn, had
grown out of the experience
the photographer had playing
tennis in high school.

Mr. is a handsome.
slim, 29-year-old who favors
jeans and fresh button-down
cotton shirts and somehow
always looks as if he just got
out of the shower. The son of
Taiwanese immigrants. he was
raised in Thousand Oaks. a
suburb of Los Angeles. He was
bright and coordinated
student class presidenL
president of the California
Association of Student
Councils and a good tennis
player.

But he found he could
never fully relax in the World
of competitive sports. ?There?s
a lot of homophobia." he said.
was not comfortable being
out"

At Harvard, Mr. Sheug left
tennis behind and discovered a
new preoccupation: he picked
up a camera and found he
loved the solitary hours spent
in the darkroom. ?It was a
refuge for me," he said during
a recent interview in his roomy
studio, nestled behind a
flooring factory on an
industrial stretch just east of
Culver City.

Mr. Sheng was a freshman
in 1993 when Matthew
Shepard was killed in
Wyoming. Shaken, he wanted
to go to a campus memorial
service, but he did not for fear
of breaking down in public.

His idea for ?Fearless?
was to "photograph people I
looked up to. people who had
done something signi?cant that
had been impossible for me to
do,? he said. That series now
includes Ill] athletes from the
United States and Canada,
almost all stare frankly into the
camera. Mr. explained

For?
.

Pg 3ft)

1

oi- 325

IT MILD)

his choice: ?Sometimes when
you get stared at. your only
choice is to stare back."

In early 2003. when
?Fearless? began getting
attention in the press. Mr.
Sheng received his ?rst c-mail
message from a service
member saying he had been
moved by the photos. More
e-mail messages came. about
It} in all. before the
photographer realized he had
found his next project. He
began traveling the country to
interview and shoot military
personnel. either in their
bedrooms or in hotel rooms
near their bases. Al tirst he
paid his travel expenses
himself: later. he was helped
by a grant from the Paul and
Daisy Soros Foundation. (Mr.
also teaches full time at
the University of (?alifomia.
Santa Barbara.)

Where the ?Fearless?
photos were bright and glossy
(they were shot on film). the
new works are muted and
shadow-?lled. For ?Don?t Ask.
Don't Tell." Mr. Sheng used a
digital camera. which allowed
him to show his subjects their
pictures right away and so.
he said. helped to build trust.

Mr. has
photographed 40 servicemen
and servicewomen so far and
plans to shoot 20 more. His
?Don't Ask. Don?t Tell" Show.
featuring around 30 photos.
will open at the Kaycee Ulsen
Gallery in Culver City in
September. Mr. Sheng is at
work on a second volume of
the book.

He described his subjecui.
identi?ed only by ?rst names
that are pseudonyms. as people
who ?didn?t want to risk their
careers. but who wanted to take
some kind of stand.? Earnest
and passionate about his work.
Mr. Sheng said he struggles to
avoid being heavy-handed as
an artist. ?1 merge a light for
social equality with
photography. but I'm always
trying to ?gure out how to do it
intelligently." he said.

Mr. Sheng recalled his
?rst interview with Matt. one
of his military subjects.

ManningB_00409T14

asked him if he had seen
anyone die.? Mr. Sheng said.
his face ?lling with color.
knew he was a medic who
served two tours in Iraq.? In
his last tour, Matt told Mr.
Sheng, his truck was hit by an
improvised explosive device.
Matt was injured and his two
closest Friends were killed.

Reached by phone in
Texas. Matt. 24. said he has
decided not to re-enlist. He
said he was disturbed by the
situation: of a friend who Was
discharged after being spotted
dancing with another man in a


?Once you are deployed.?
he said. ?you live with people
in an intimate way. You trust
them with your life and they
become brothers and sisters. I
couldn?t help thinking that it'
something happened to me, no
one would know who I was.
That is not the way I Want to
leave this world.?

Matt said he was ?blow
away? when he saw his photo
in Mr. Sheng's book.
became very emotional." he
said. In the book. Mr.
reproduces one of Maith
e?mail messages in which he
writes. ?After all I had been
through in one instant I
could go from War Hero to
The gay soldier that was
discharged. How could this be
right??

The airman known as less
is perhaps the project?s most
visible ?gure. It was his image
that landed on the book cover
and in Time magazine in
Febmary.

love the photo." he said
over the phone a few days ago.
?It?s great but it?s also
revealing. If you knew me. you
would know it's me in that
photo. I didn't realize that my
photo was going to be that out
there. I did worry that
something might happen. but
nothing did. I?m proud I did it.
I think it shows to conservative
Americans that gay military is
just normal."

After serving in
Afghanistan. Jess was moved
from what he called a ?more
liberal? unit to one where he

was ?pushed back in the
closet" He ?nds his situation
dif?cult ?You can?t get to
know people," he said. ?You
can't develop bonds with the
people you?re ?ghting with day
in and day out. I can?t talk
about myself. I?m afraid I?ll
reveal something. I?m
constantly on guard."

Mr. Sheng recently met
and photographed an ROTC
cadet who was planning on
becoming a doctor. After three
years of training. she was ready
to deploy. When she read her
honor oath. which states that ?a
cadet will not lie. cheat or
steal. nor tolerate those who
do." the young woman decided
she must tell her commanding
of?cer the truth about herself.
That commander immediately
pressed for her discharge.
"Now." said Mr. Sheng. ?she
may have to ?nd a way to pay
back the $80,000 spent on her
education."

For ?Fearless,? Mr. Sheng
had considered making a ?lm
but eventually ?gured he had
made the right choice for the
project. ?People are not going
to see a 90-minute
documentary about gay
athletes or about DADT unless
they already agree with its
premise." he said. ?But people
can happen upon a picture.
Some piettn'es like the ones
of civil rights protesters being
attacked by dogs sum up
what?s really at stake. People
who don?t even mean to see it
end up seeing it. And then
things change."

The policy known as
?don?t ask. don?t tell" the
DADT he refers to has been
in place since 1993. Last
month Adm. Michael Mullen.
the chairman of the Joint
Chiefs of Staff, called for an
end to it. saying. cannot
escape being troubled by the
fact that we have in place a
policy which forces young men
and women to lie about who
they are in order to defend their
fellow citizens."

And this week. Gen. David
Petraens. head of the Central
Command. testi?ed before the
Senate Armed Services

00164

page 29
Committee. saying he believed
that "the time has come to
consider a change to Don't
Ask. Don?t Tell." adding. "but
I think it should be done in a
thoughtful and deliberative
matter."

For his part. Mr. Sheng
said he believes things will
change. ?Straight or gay. my
generation sees homophobia as
being openly racist.? he said.



Washington Post
March 18. 2010

Pg. 3

38. Compensation
Exams Need To Be
Expedited

VA medical centers need
to speed up compensation and
pension medical exams to
veterans so that it can expedite
disability claims. the
department's inspector general
reported Wednesday.

At a facility in Roscburg.
Ore. hundreds of requests for
an exam were tucked in ?le
cabinets so a timeliness quota
could be met. And claims at an
outpatient clinic in
Winston-Salem. were
processed out of order also to
help with the quota, the IG
said.

The chairman of the
Senate Veterans Affairs
Committee. Daniel K. Akaka,
says VA needs to devote more
resources to ?xing the
problem. VA has told the
inspector general it will do
that.

-- Associated Press



New York Times
March 13. 2010
39. In Biathlon. War

Veteran Revels In

Latest Challenge
By Katie Thomas

As a boy growing up in
California and then Texas.
Andy Soule was not much of
an athlete.

?He liked to play Logos
and draw and those kinds of
things." recalled his mother,
Debbie Soule. He did not take
to Little League or soccer. In

high school. Soulc ran track
and cross-country. making the
varsity team in high school and
winning a few medals. But ?he
wasn?t a star by any means,?
his mother said. "He was just a
member ofthe team."

Soulebronze medalist. He was third

in the SEA-kilometer. or
.49-mile. pursuit sitting
biathlon event Saturday.

becoming the first American to
win a medal at the Paralympic
Games in Vancouver and
Whistler. British Columbia.
and the ?rst American in
history to win a medal in
biathlon. He placed fourth
Wednesday in the
[ZS-kilometer. or lilo-mile.
sitting event and shot perfectly.
hitting all 20 of the targets
during the race.

Soulc?s journey to the
Paralympics began in 2005.
Two months after he was
deployed to Afghanistan with
the Army. an explosive device
went off under the truck in
which he was riding. Both of
his legs were later amputated
above the knee.

While recovering at
Brooke Army Medical Center
in San Antonio. Soule threw
himself into athletics. sampling
sports like fencing and sitting
volleyball. During a
handeycling event in San
Antonio. Settle said, he met
Marc Mast. who ran a training
program for disabled skiers in
Idaho.

?He felt that I had
potential to be a good Nordic
sit-skier. based on seeing me
Soule said.
couldn?t be a soldier. certainly
not in the infantry anymore. I
needed something new to
challenge me."

Soulc entered the Army in
2002. motivated by the terrorist
attacks of Sept. 1 1. He also felt
lost at Texas where he
was ajunior. was burned out
on college." he said. wasn?t
doing well-"

Biathlon was a good ?t
because it combined an
endurance sport and shooting.
Soule grew up visiting a
shooting range with his father,

971 5

who is retired from the Air
Force. and felt comfortable
with a rifle. Paralympic
and cross-country
skiers who do not have the use
of their legs race in special
chairs attached to skis.

Soule accepted Mast's
invitation in 2005 and traveled
to Sun Valley. Idaho. to attend
a development camp for
beginning skiers. In 2006. he
moved there to train ?ill time
and quickly made his mark.
Soule won a silver medal at the
national championships in
2007. and ?nished in the top
10 in two World Cop races the
same year.

On Thursday, Settle
finished behind three biathletes
from Russia. which so far has
dominated the Paralympics just
weeks after its team was
widely thought to have
at the
Olympics. As of Thursday.
Russian athletes had won 8
gold medals and 23 medals
over all. The United States.
which won the overall medal
count at the Olympics. is in
sixth place. with one gold
medal and four medals over all.

Sonle is also competing in
cross-country skiing and will
race in two more events.
?When he was injured. I knew
he would walk again, I knew
he would have a normal life.?
Debbie Soule said. ?But I
couldn't even dream that he
would do something like this.
This is pretty amazing."



Washington Post

March 18. 2010

Pg. 14

40. Air Force Proceeds

With Lockheed Deal

The Air Force said it will
request $6.5 billion, or four
years of Funding, for a
Lockheed Martin military
communications program that
plans to launch its first satellite
in September after six years of
delays. The funding request for
?scal years 2012-2015. part of
a $9.9 billion program.
suggests that delays and
technical problems have been
worked out.

\w

Bethesda-based Lockheed
and its top subcontractor.
Northrop Grumman. have been
awarded contracts for the ?rst
three of six planned satellites.



-- Bionmberg News
The Hill
March 18. 2010
41. Northrop Draws A
Line In Sand On Tanker
Price
By Roxana Tiron

Northrop Grumman's

announcement backing out of
the competition for the Air
Force's $35 billion refueling
aircratt contract included a
?nal parting shot at main rival

Boeing.
At the end of its
six-paragraph stateman

Northrop President and CEO
Wes Bush released the price
that Northrop and its partner.
EA US. had negotiated with the
Pentagon during a previous
competition to build the tanker.

Northrop believes that
price. $184 million. should
effectively be the cost ceiling
the Air Force pays for its new
tanker. Bush said the Air Force
should ?expect the bill to be
much less? for the Boeing
tanker.

Randy Belote, Northrop?s
vice president for strategic
communications. on
Wednesday reaf?n-ncd his
company's belief that Boeing?s
tankers should cost less
because the 3'6? aircraft is
smaller than the 111330-200
Northrop and EADS offered.

Belotc said he was
reacting to criticism Northrop
received for including the price
in its exit announcement. Some
said the $184 million
price was irrelevant because it
relates to a different tanker
contract that Boeing
successfully challenged.

Northrop~EADS initially
won a competition against
Boeing to build the tankers in
2008. but Boeing protested that
award with the Govertunent
Accountability Of?ce (GAO).
Pentagon of?cials then
reopened the competition.

00165

page 3?

in an e-mail Wednesday.
Belotc again noted that the
Pentagon agreed to a $184
million per-aircraft price for
the ?rst ?ll A330-based tanker

aircraft. including the
non-recurring development
costs.

"With the department?s
decision to procure a much
smaller. less capable design,
the taxpayer should certame
expect the bill to be much less
than the $184 million per
tanker that the Air Force would
have paid Northrop Grumman
for the more modern. more

capable KC-45 rc fueling

tanker.? Belotc said.
Lawmakers from

Alabama. where Northrop

planned to build the tanker. had
expressed concern that tanker
costs could increase if
Northrop followed through on
threats to pull out of what it
said was an unfair competition
that favored Boeing's bid.

Pentagon of?cials now
face the challenge of
negotiating a ?xed-price

contract within budget after
aiming to drive down costs
through competition. The
Pentagon so far has not
announced any changes to the
bidding process to
accommodate a sole bidder.

A defense analyst said
Northrop may have helped the
Pentagon in its negotiations
with Boeing in releasing the
$184 million price.

"There might be factions
in the Pentagon that wanted
them to bid to keep Boeing?s
bid competitive. and this might
be a minimum way of showing
support for the Pentagon by
helping to keep Boeing's bid
competitive." said Richard
Aboula?a. vice president of
analysis at the Teal Group.

?We are 100 percent
focused on submitting a fully
responsive. transparent and
competitive tanker proposal to
the Air Force. ?Boeing
recognich it must earn the
tanker contract by providing
the Air Force with a modern
and capable tanker that meets
or exceeds all war?ghter
requirements and is

L.r?i
?r
lt-?l. ind-Oi

cost?effective to buy. own and
operate." said Boeing
spokesman Bill Barksdalc.
Pentagon acquisition chief
Ashton Carter said the ?rst two
lots of the new liq-tanker fleet

will be purchased at a ?rm ?y-by-wire refueling boom. to the prior one. with

fixed price. while the data Should it be chosen to Northrop escalationy" he said. "And

remaining lots will use a ?not provide the Air Force with a Grumman-EABS won a we're trying ?to drive to a

to exceed" structure and replacement ?eet far its aging contract to boild 179 tankers number that Will Win."

economic price adjustment 1.10135 tanker aircraft based on the Airbus A33tl for 1 Albaugh added that

provisions to protect "both "we have told the Air the Air Force in February be a program_that can

taxpayers and industry." Force and the Department Dr 2008. The contract was generate about $3 billion ayear
Boeing has defended the Defense maE they.? get full canceled when US. auditors in round numbers for the

Pentagon?s bidding process for insight into mm and upheld a Boeing protest tied to Boeing Company.?

the tanker program. sayingthit pricing informatiom and they AirI forged missteps to

did not over - - eva uating is. I

Chicagorhascd company. sslg?ili?grf?ig??rg? Northrop Grumman CEO Ecmspacc Dailyd't Defense

Boning Of?cials are already aviation division. "We're going was Bush a March 8 letter 13 3010

working to dispel any to be fully transparent on to Pentagon of?cials outlining Paula .

perceptions that the company his company's reasons for 8-

would take advantage of the Gangr?simul supporters dropping out of the bidding, 43- Hovenug I

situation. of indmw rival Nurmrop warned the government not to Lmkheed Ma?lns ?rst
?We remain in a Grumman have warned than overpay l'orancw?tattker. Bush F3513

competitive situation," Tirn Since that cump??yls decision noted that the Air Force had

Kcating, Boeing?s senior vice

Transparency Amid
Sole-Source Concerns
By Marina Malcnic

A top Boeing of?cial said
yesterday that the company

to drop out of the contest, the



May It}. The company said
earlier this month that it plans
to modernize its 767
commercial aircraft with a new
digital ?ight deck from its 737
Dreamlincr. as well as a new

planned to pay a unit ?yaway

page 3!
specify. But he said that a ?nal
price would not be far removed
from its 2008 bid.

"The expectation. certainly
of the Air Force, is that it will
be a number reasonably close



[Stovl) aircraft demonstrated

resident for government - cost of approximately $lB4 the capability to hover
gperations. said at a meeting rglgi?nov; a: million per tanker for the ?rst March l'i'during a test flight at
with reporters March Boeing 63 A33??based aircraft Naval Air Station Panixcnt
?There isacontract we have to Grumman proposed by Northrop River. Md. aircraft took
win. We have not won it yet." last week that it Grumman-EADS--a number off conventionally. then pilot

Northrop Grumman
blamed the Pentagon bidding
process for its decision to pull

would not bid for the work,
alleging that the Air Forcds
request for proposals outlined

that included the non?recurring
development costs.
"With the Department's

Graham Tomlinson slowed it
to 60 knots and ?ew a
decelerating approach to zero

out. It said the process favored '35l manth favors Boeingts decision to procure a much airspeed at 150 feet above the
the smaller refueling aircra? smaller tanker. Hump smaller, less capable design. runway. After completing all
offered by Boeing. and that the indusuy p?m?r. the taxpayer should certainly hover test points,

NorthroprEADS team had little
chance to win the contract even
if it spent millions on the
competition.

Northrop?s decision to pull

Airbus parent company EADS
North America, has remained
quiet about its intentions.
Albaugh Said that Boeing
is still operating under the

expect the bill to be much
less." he wrote.

Albaugh yesterday told
reporters that Boeing continuos
to work on driving doivn the

executed a Stovl landing at 70
knots airspeed. according to
Lockheed. Later in the day.
performed the first F-JS
short takeoff too.



out has created tension assumption that mere will he a cost of the in? commercial

between the European Union competition fur m3 work. aircraft on which its tanker washingmn Post

and the ??lled Stales' which Pentagon officials have wui?ld be basgd? He 531d ll]: Mal-ch13 so?)
European of?cials have} said mum be worth up to $50 rfnajor cost-putting ifforgoge? Pg 19

accused the United States - rom comp a ra .
protectionism. arguing the the llfe 0f the modifications to the aircraft on The
Pentagon changed "Um. assumption i5u his the main production intern Sples I
speci?cations for the new going to be Everett. Wash..before shipping By David Ignatius

tanker to favor Boeing.
French President Nicolas

Albaiigh said. "In the event that
it's not, they're going to go

it to Wichita, Kan, for
integration of mission systems.

The headline read like
something you might see in the

Sarkozy is expected to share thwugh a" the wait and pricing "The original . way? that conspiracy-minded Pakistani
his gripes with President information in excruciating we've done derivative aircraft press: Contractors Tied to
Baraek Dbama when he visits demll And wc-rc going to in the past has been to ?y it to Effort it: Track and Kill
the White House later this make sum they have full access Wichita cut it up. and putit Militants. I But the! story
month. and that we're tom?), back together again." he said. appeared in Mondays New



Defense Daily

transparent on that."
Boeing has said that it will

"This is new a much more
ef?cient way to build the
airplane. and it will drive the

York Times, and it highlighted
some big problems that have
developed in the murky area

mu
Pg. 1 ?Lhasa-1 refueling airman in Asked how lar the intelligence actiwtics. .
42.Boeing Pledges aproposalit plansm submit an company aims to drive that The starting Ipoml for
Tanker Cost cost. Albaugh would not understanding this covert
Hill. arcs. EXHIBIT it Mr)
..,
ManningB_OD409?16 Ch: :53 Oi"-

Intrigue Is that the
military has lon been unhappy
about the quality of CIA
intelligence in Afghanistan.
The frustration surfaced
publicly in January in a report
by t' top military intelligence
off in Kabul, Maj. Gen.
T. that began:
"Ii-"Ff" years into the war in

Afghanistan, the U.S.
intelligence community is only
marginally relevant to the

overall strategy."

It's a complicated tale, but
it has some simple lessons:
Under the heading of
operations" or
"force protection," the military
has launched intelligence
activities that. were they
conducted by the CIA. might
require a presidential ?nding
and noti?cation of Congress.
And by using contractors who
operate "outside the wire? in
Afghanistan and Pakistan, the
military has gotten informatiort
that is sometimes better than
what the CIA is offering.

A reconstruction of what

happened. based on
conversations with a
half-dozen military and

intelligence contests, raise-S
crucial issues: What new
military procedures are needed
to bring "information
operations" and related
activities under better control??
And how can the CIA improve
its own collection efforts so
that private contractors
brought in to ?ll the gaps?

The outsourced
intelligence operation
described by the Times began
in 2008 with a push from the
Pentagon's Strategic
Command, which oversees
information operations. A
Stratcorn civilian named
Michael D. Furlong began
funding former journalists to
provide "ground truth." with a
planned budget of$22 million.

Another private
intelligence effort was
launched in November 2008.
when a Boston ?rm called
American International
Security Corp. was
hired by the New York Times
to free its reporter David

Rohde. who had been
kidnapped by the Taliban that
month. The ?rm tamed to
Duane "Dewey" Clarridge. a
former CIA of?cer who
launched the agency's
counterterrorism center in 1936
and was an important ?gure in
the Iran-contra affair. He set
about building a network of
informants who could help free
Robdc.

Rohde escaped in June
2009. but Clan?idge's network

continued to function. It
currently has about 1 0
operatives who act as case
of?cers. drawn from the

United States. Britain. South
Africa and other countries.
These of?cers. in tum. run
about 20 "principal agents"
who are in contact with
roughly 40 sources in
Afghanistan and Pakistan.

(.?Iarridge had been in
contact with US. Special
Operations Command
in Tampa since
March 2009 to share
information and to make sure
that his private network
wouldn*t clash with US.
operatives. He is said to have
briefed both Adm. Eric Olson.
the head of SOCOM, and Lt.
Gen. David Fridovich, the
director of its center for special
operations.

Clarridge's contacts with
the military deepened last July
a?er be provided detailed
intelligence about an Army
soldier, Pfc. Howe Bergdahl.
who had been captured by the
Taliban in eastern Afghanistan.

The two outsourced
operations linked up in
mid-2009. after Furlong met
one of Clanidgc?s operatives in
Dubai. In October, the military
aWardcd a contract for several
million dollars to Clarridge and
AISC through a series of
subcontractors.

The CIA, meanwhile. was
llummoxed by Clan?idge's
freelancing. The new chief of
station in Kabul protested last
summer, and lawyers drew up
new rules. Clarridge?s mission
was described as "force
protection." a normal military
activity in a war zone. His

unclassi?ed reports were fed
into the .l-3 operations center in
Kabul. and then often
classi?ed and disseminated
though intelligence channels.

Clanidge's reports carried
the rubric "Force Protection
Atmospherics." His sources
were described as
"cooperators" and his effort
was termed "commercially
gathered? data. rather than
intelligence collection.

But these semantics didn't
resolve the tension between
military activities. which fall
under Title. 10 of the US.
Code. and covert action,
which is authorized under Title
50. This gray area has led
Adm. Dennis Blair. the director
of national intelligence, to
argue privately that the country
may need what could be
described as a new "Title 60."
that blends the two in a
coherent framework with
proper controls.

The case of the clandestine
contractors should prompt a
serious debate about creating
such a Title 60. and about the
military"s rules for information

operations. Meanwhile.
Clarridge's private network
continues to provide fresh

intelligence. His latest report
from Palttia province was
disseminated on Monday, the
same day the New York Times
article appeared.



New York Times
March IS. 2010
45. A Politically Feasible

Jet

There has been yet another
setback in the Air Force?s long,
agonizing process to replace its
?eet of Eisenhower?era aerial
refueling planes. Northrop
Grumman and its European
partner. the European
Aeronautic Defense and Space
Company. dropped out of the
competition this month,
charging that the new contract
Speci?cations are tilted against
their much larger Airbus A330
in favor of Boeing's 7'67.

That leaves the Pentagon
with only one bid hardly a
recipe to get the best tanker

00167

page 32

fleet at the best cost.
From a capabilities
standpoint. we could see

advantages in both planes. The
Pentagon says that between the
two rounds of bidding, it
developed a more precise idea
of what it needed. But its
repeated flip-?ops feed
suspicions that politics and
lobbying are what mattered
most. Boeing's Capitol Hill
supporters mainly from
Washington State built a
case around stars. stripes and
American jobs and, by
implication. against a
consortium that had. gasp, a
European partner.

For American taxpayers
and their armed forces to get
the best possible tanker ?eet
or other military equipment
for the money. quali?ed
European partners must be
permitted to compete fairly.
For the record. the Airbus
tankers would have been
assembled in Alabama. The
nation's European allies are
now understandably charging
protectionism. This could
cause problems down the road
for the American defense
industry, the biggest military
exporter in the world.

The tanker tale is also one
more reminder of why the
Pentagon needs to clean up its
procurement process and
how much further it has to go.
despite Defense Secretary
Robert Gatcs's pledges of
reform.

The ?rst attempt to replace
the tankers came to grief in
2004. Senator John McCain
scuttled a cozy, tailor-made
deal to lease Boeing jets.
unearthing evidence that an Air
Force of?cial had tried to get a
job at Boeing while she was
handling negotiations over the
lease.

The Pentagon then ordered
an auction for a $40 billion
contract to buy the planes. But
when the Air Force decided for
the Airbus, Eccing and its
favorite lawmakers cried foul.
The Government
Accountability Of?ce agreed
with Boeing. arguing that the
Air Force favored Northrop:

arcs. EXHIBIT rs nae)
pgsu 04.313

ManningB_00409717

page 33
giving it points for size
although the specs didn't call
for a bigger plane; giving
Northrop advice along the way;
and cutting it slack on several
reql

he Air Force went back
drawing board to craft
Widelines for the bidding.
The rest is history. Both jets
have pros and cons. The Airbus
is bigger and can carry bigger
hauls of fuel or cargo. Boeing's
jets are smaller and cheaper
not to be frowned at in these
lean times. Unfortunately. it
doesn?t seem to matter. The
Air Force seems stuck with the
politically feasible jet. It might
be the best one, but it might
not



Washington Post
March 18. 2010
Pg. 2

46. Correction

A March 17 Economy 3:
Business article, about
accusations in Europe that the
Pentagon altered speci?cations
for a new refueling tanker
plane to favor Boeing in its
competition For the contract
against a consortium that
includes Europe?s Airbus,
incorrectly referred to the
Boeing as? as new. The
jetliner, a military version of
which is a contender for the
contract1 has been in service
since 1982.

Editor's Note: The article
by Edward Cody appeared in
the Current News Eoriy Bird,
March 17. 2010.

-3

INV. OFBR. EXHIBIT it HUG
ManninQB_00409T13 0; 5?5

Closed Hearing Checklist









All spectators have been cleared out of the courtroom. 99/

All remaining personnel possess a valid, SJA issued security badge.

Guards are posted outside courtroom entrances.

Classified recording equipment is in place. g7









Audio and video feed to the M00 and the theater has been severed.






'5

Signed Time rive Date 1



BFCR. EXHIBIT

Open Hearing Checklist



Classified display laptop (if used) is disconnected and secured.






Secured all classified material from the l0 Support Paralegal.
7

Secured all classified material from the TC.



Secured all classified material from the DC.





Secured all classified material from the IO.



The courtroom safe is locked.







Unclassified recording equipment is in place.







Signed Time 557 Date 4' 3 ?ll/H
A?nl

HIV.

UFBR.

EXHIBH #la

IN THE UNITED STATES ARMY

FIRST JUDICIAL CIRCUIT
UNITED STATES
DEFENSE ASSERTION OF
v. PRIVILEGE UNDER M.R.E.
503
MANNING, Bradley E., PFC
U.S. Anny,
Headquarters and Headquarters Company, U.S.
Army Garrison, Joint Base Myer-Henderson Hall, DATED: 19 December 2011
Fort Myer, VA 22211

1. PFC Bradley E. Manning, by and through counsel. pursuant to Military Rule of Evidence
(M.R.E.) 503, asserts privilege over conversations with Mr. Adrian Lamo.

2. The privilege under M.R.E. 503 protects communications made as a formal act of religion or
conscience. This privilege may be claimed by the penitent. United States v. Napoleon, 46 M.J.
279 For the privilege to apply, the following must be true:

a. The communication must be made either as a formal act of religion or as a matter of
conscience;

b. be made to a clergyman in his or her capacity as a spiritual advisor or to a
clergyman?s assistant in his or her capacity as an assistant to a spiritual advisor; AND

c. be intended to be con?dential. Id.

3. When a chaplain meets with a penitent, M.R.E. 503 allows the disclosing person to prevent
the chaplain from disclosing the contents of the statement when it was made as a formal act of
religion or as a matter of conscience. United States v. Banner, 57 MJ. 210 (C.A.A.F. 2002); see
also United States v. Shelton. 64 MJ. 32 (C.A.A.F. 2006)(holding that communications made to
a civilian minister acting as a marital counselor were covered by the privilege).

4. in this case, PFC Manning had a conversation with Mr. Adrian Lamo between 20 May and 26
May 2010. The conversation with Mr. Lamo began with Mr. Lamo stating ?I?m ajournalist and
a minister. You can pick either, and treat this as a confession or an interview (never to be
published) enjoy a modicum of legal protection." PFC Manning accepted this offer by
continuing the conversation.

5. Shortly after extending an offer to treat the conversation as a confession or an interview, Mr.
Lamo asked PFC Manning if he wanted to go to the press. PFC Manning replied that he did not.
Later, PFC Manning told Mr. Lamo ?but im (sic) not a source for im (sic) talking to you
as someone who needs moral and emotional fucking support.? Mr. Lama responded, ?i (sic) told
you, none of this is For print."

Ira. are. ermine-v-01"

i 0?

6. The subsequent conversation over the 20 May through 26 May 2010 time period indicates
clearly that PFC Manning engaged in the conversation as a matter of conscience; he was seeking
guidance from Mr. Lamo in his capacity as a spiritual advisor; and he intended the conversation
to be con?dential. First, PFC Mamting discussed numerous sensitive personal topics with Mr.
Lame, including the moral struggles he was dealing with in a deployed environment. Second,
PFC Manning repeatedly sought guidance and advice from Mr. Lame. Finally, PFC Manning
used an message provider in order to ensure the communication with Mr. Lamo was
con?dential.

I Under the above facts, PFC Bradley E. Manning, by and through counsel, pursuant to
Military Rule of Evidence (M.R.E.) 503, asserts privilege over all the conversations with Mr.
Adrian Lamo.

VID E. COOMBS

Civilian Defense Counsel





DEPARTMENT OF THE ARMY
UNITED STATES ARMY MILITARY DISTRICT OF WASHINGTON
210 A STREET
FORT LESLEY J. MCNAIR, DC 20319-5013

REPLY TO
ATTENTION OF



ANJA-CL 20 December 20 1

MEMORANDUM FOR LTC Paul Almanza, 150th Judge Advocate General Detachment, Legal
Support Organization, MG Albert C. Lieber USAR Center, 6901 Telegraph Road, Alexandria,
Virginia 22310

SUBJECT: Response to Defense Assertion of Privilege under MRE 503

1. The United States requests you deny Defense Assertion of Privilege under Military Rule of
Evidence (MRE) 503.

2. The Military Rules of Evidence shall not apply in pretrial investigations, with the exception
of, inter alia, Section privileges. See Rule for Courts-Martial (RCM) 405(i). MRE 503(a)
protects ?a con?dential communication by the person to a clergyman. . . if such communication is
made either as a formal act of religion or as a matter of conscience.? MRE 503(a). The elements
to assert this privilege include: (1 the communication musr be made either as a formal act of
religion or as a matter of conscience; it must be made to a clergyman in his capacity as a
spiritual advisor; and (3) the communication must be intended to be con?dential. See United
States v. Shelton, 64 MJ. 32 (C.A.A.F. 2006). The burden rests with the party asserting the
privilege. See United States v. Darbin, 68 MJ. 271 (C .A.A.F. 2010).

3. The defense alleges that the accused made admissions as a matter of conscience. A
communication is ?not privileged, even it?made to a clergyman. if it is made for emotional
support and consolation rather than as a tbrmal act of religion or as a matter of conscience.?
United States v. Napolean, 46 NM. 279 (C.A.A.F. 1997) (citing United States v. Cataman, 26
MJ. 407 (C.M.A. 1988)). In Napoleon, the privilege did not apply because the facts suggested
that the accused "was seeking emotional support and consolation, not guidance or forgiveness."
Id, at 285 (emphasis added). Here, the accused admitted he was "talking to [Mr. Lamo] as
someone who need[ed] moral and emotional support.? This admission confirms the
communication is not privileged. A ?matter of conscience? is privately held within a person.?
Shelton, 64 MJ. at 32. In Shelton, an admission was made as a matter of conscience given the
religious connotation with which the admission was provided. See id (the meeting began with a
prayer, took place in a church, and included religious atmosphere and spiritual language, such as
?you claim to be a Christian, Christians don?t tell lies?); see also United States v. Ishanr, 48 MJ.
603 (N-M. Ct. Crim. App. 1998) {admissions with "obvious religious overtones" qualify as
matters of conscience). At no point did the accused seek guidance in conscience, defined as ?the
moral sense of right or wrong." Black?s Law Dictionary (9th ed. 2009). The accused admitted
that he was ?godless? and that he has ?always been too intellectual. . .for religion." The
communication is boastful, not a matter of conscience. The accused bragged he would "?listen[]
and lip-sync[] to Lady Gaga?s Telephone while ex?ltrating (sic) possibly the largest data spillage
in American history." The accused bragged about his contacts and exploits and argued

HIV. arcs.



.


ANJA-CL
SUBJECT: Response to Defense Assertion of Privilege under MRE 503

?information should be free? and in the ?public domain.? The accused sought recognition. not
forgiveness, for his acts. For these reasons, the accused did not make his admissions as a matter
of conscience.

4. A communication is ??con?dential? if made to clergyman in the clergyman?s capacity as a
spiritual advisor. . .and not intended to be disclosed to third MRE 503(b)(3). The
admission fails this element for three reasons. First, MI. Lamo was not a clergyman under
military law. A ?clergyman? is ?intended to mean a person ?regularly engaged in activities
conforming at least in a general way with those of a Catholic priest, Jewish rabbi, or minister of
an established Protestant denomination.? Napoleon, 46 MJ. at 279 (citing S. Saltzburg M.
Martin, Federal Rules of Evidence Manual 601-02 (5th ed. 1990). Mr. Lame allegedly earned a
ministerial certi?cation online, but does not regularly engage in religious activities or advertise
his religious beliefs. Accordingly, Mr. Lamo is not a clergyman under this privilege and the
accused had no reasonable belief otherwise. Second, the accused did not con?de with Mr. Lamo
in his clerical capacity. Mr. Lamo informed the accused that he was ?ajournalist and a minister?
and that the accused "[could] pick either, and treat this as a confession or an interview (never to
be published) enjoy a modicum of legal protection." The accused responded ?Assange
level?". ignoring Mr. Lamo?s alleged religious position and instead focusing on his status as a
journalist. The accused admitted Mr. Lamo's relationship with WikiLeaks was ?how [he]
noticed [Mn Lamo]" and maintained a video titled ?Hackers Wanted? starring Mr. Lamo, a
renowned computer hacker, on the desktop of his personal computer. The accused quickly
learned oer. Lamo?s sexual orientation and continued contact with him to cope with his
alleged feeling of isolation. The accused initiated and continued contact with Mr. Lamo for
these purposes, not for clerical guidance. The defense presents no evidence that the accused
sought out Mr. Lamo for any other reason.

5. The clerical privilege ?recognizes the human need to disclose to a spiritual counselor, in total
and absolute confidence, what are believed to be ?awed acts or thoughts and to receive priestly
consolation and guidance in return." Trommel v. United States, 445 US. 40, 51 {1980).
Protecting these chat logs as privileged communications violates the very spirit of the privilege.
At no point did the accused admit any wrongdoing or request guidance in return. Instead, the
accused praised the ?highlights? of his misconduct with the overarching objective ?to witness[]
the world freak out as its most intimate secrets [were] revealed.?

6. The point of contact for this memorandum is CPT J. Hunter Whyte - I


Encl ANGEL M. RGAARD
Chat Logs (BATES 00124132-00124149) CPT. .l A
Trial Counsel

tut. new. rte-ab"

l'-J

5'
Closed Hearing Checklist





All spectators have been cleared out of the courtroom.





All remaining personnel possess a valid, SJA issued security'badge.

H,




Guards are posted outside courtroom entrances.





Classified recording equipment is in place.







Audio and video feed to the M00 and the theater has been severed.







974?

Signed 2- Timef?i 2 Date?! "212044
I/xl

Lyn/(ix!

Hill.

UFBR.

EXHIBIT #:Lo

Ht};
Open Hearing Checklist























Classified display laptop (if used) is disconnected and secured.
Secured all classified material from the 10 Support Paralegal.
Secured all classified material from the TC.
Secured all classified material from the DC.
Secured all classified material from the IO.
The courtroom safe is locked.
Unclassified recording equipment is in place. 0
.
LJAE 1' Pl 3

Time Date ligag/g

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(1:40:51 bradass87 has not been authenticated yet. You should authenticate this buddy.
(1:40:51 Unveri?ed conversation with bradassB7 started.

{1:41:12 hi

{1:44:04 how are you?

{1:47:01 bradassa'o?: im an army intelligence analyst. deployed to eastern baohdad. pending
discharge for "adiustment disorder" in lieu of ?gender identity disorder"

{1:56:24 brada5587: im sure you're pretty

{1:58:31 PMibradassE?: if you had unprecedented access to classified networks 14 hours a day 7
days a week for 8+ months. what would you do?

{1:58:31 info@adrianlamo.com Tired of being tired

{2:17:29 bradassB7:

{8:07:29 infofdiadrianlamocom: What?s your

{3:16:24 bradassB7: re: "What?s your Intelligence Analyst (33)

(3:16:24 info@adrianlamo.com Tired of being tired



{10:13:20 bradassB7: The message received from bradassa'r' is unreadable. as you
are not currently communicating privately.

(10:13:27 Unveri?ed conversation with bradassB? started.

(10:13:27 bradassB7: [resent]
(10:13:50 info@adrianlamo.com: hello

(10:13:57 bradassB7: re: ?What?s your Intelligence Analyst

(10:14:08 AM) info@adrianlamo.com: *nod?

(10:14:27 bradassBT: anyway. how are you?

(10:14:28 AM) info@adrianlamo.com: my ex was 978

(10:14:44 bradassB7: ick

(10:14:50 bradassB7: 35M now-a-days

(10:14:50 info@adrianlamo.com: made for quiet dinner convo. neither of us talked about our
days;>

(10:15:29 bradassa7: so yeah

(10:15:41 AM) bradassBT: im in a sticky

(10:16:56 bradass?7: its nice to meet you only starting to familiarize myself with whats
available in open source

(10:17:45 AM) info@adrianlamo.com: open source or

(10:17:51 AM) info@adrianlamo.com: Pleased to meet you.

{10:17:54 AM) same deal

(10:19:00 AM) bradassST: im kind of coming out of a its going to take some time. buti
hopefully wont be a ghost anymore

(10:19:53 AM) info@adrianlamo.com: You mentioned gender identity, I believe.

(10:19:59 AM) bradassai': ive had an unusual. and very stressful experience over the last decade
or so

(10:20:53 bradassB7: questioned my gender for several sexual orientation was
easy to ?gure but i started to come to terms with it during the first few months of my
deployment

Page 1 of 43

m. arcs. We)

00180

(10:21:09 AM) info@adrianlamo.com: May ask the particulars?

(10:21:34 AM) I?m bi myself. and my ex is MTF.

(10:21:34 AM) bradassBT: fairly but careful. so yes..

(10:22:00 AM) im aware of your bi part

(10:22:24 AM) bradassB7: uhm. trying to keep a low profile for now though, just a warning
(10:23:34 AM) info@adrianlamo.com: I?m a journalist and a minister. You can pick either. and treat
this as a confession or an interview (never to be published) 8: enjoy a modicum of legal protection.
(10:24:07 AM) assange level?

{10:25:12 AM) or are you socially engineering

(10:25:51 AM) info@adrianlamo.com: You must not have done your research

(10:25:57 AM) into@adrianlamo.com: i could have ?ipped for the FBI.

(10:26:05 AM) info@adrianlamo.com: Gotten a sweeter deal.

(10:26:10 AM) info@adrianlamo.com: Before they fucked up.

(10:26:14 AM) info@adrianlamo.com: And I got one anyway.

(10:26:14 AM) bradassBT: indeed

(10:26:16 AM) info@adrianlamo.com: I held out.

(10:27:04 AM) info@adrianlamo.com: I know what being in a little room haying U.S. Code its
consequences explained to you by people who don?t smile is like.

(10:22:06 AM) btw. reminds saw a USAF report mentioning something about an
"Adrian Lamo" being in possession of French classi?ed material

(10:2?:57 AM) it flips both ways Title 10. Section 654 of US Code
(10:23:06 AM) bradassBT: (DADT)

(10:28:29 AM) info@adrianlamo.com: Of course. you could be false flagging me. I say "Can I see
it?" and bam, I'm a criminal.

(10:28:52 AM) do they do that?

(10:29:10 AM) info@adrianlamo.com: You don't know?

(10:29:33 AM) bradassBT: no FBI is the only beast i know nothing about

(10:29:43 AM) bradassS?f: i play with foreigners

(10:29:46 AM) info@adrianlamo.com: They have a grudge.

(10:30:09 AM) info@adrianlamo.com: They had to apologize for how they handled my case. In
public.

(10:30:13 AM) brad-3358?: CIA. NSA. those are whati know

(10:30:15 AM) info@adrianlamo.com: To the press.

(10:30:25 AM) inf0@adrianlamo.com: They _hate_ that.

(10:30:32 AM) bradassS'i?: PR games

(10:30:57 AM) info@adrianlarno.com: My ?le runs 3000 pages. I don?t know how typical that is.
(10:31 AM) bractass?i?: yery atypical

(10:31:16 AM) bradassB?: im sorry i dont have access to LES material

(10:31 :29 AM) info@adrianlamo.com: I wouldn't ask you to use such access.

(10:31 :40 AM) brads-13587: i know, i'd offer it

(10:31:53 AM) hold on

(10:33:28 AM) bradassa'i': this is what i do for friends: http:iibit.lyraLqui

(10:35:14 AM) bradassa'f: [the one below it is mine too]

Page 2 of 43

[10:35:30 AM) bradass?h >sigh<

(10:36:46 AM) bradassB7: living such an opaque life. has forced me never to take transparency,
openness. and honesty for granted

{10:37:31 AM) hradassBT:

{10:38:37 AM) info@adriantamo.corn: I've been a friend to Wikileaks - l've repeatedly asked
people who download Hackers Wanted to donate.

(10:38:44 AM) info@adrianlarno.com: And donated myself.

{10:38:49 AM) bradass?'I: i know

(10:33:59 AM) actually how i noticed you

(10:39:20 AM) info@adrianlamo.com: Whether I?ve given material. isn?t material. Semi~pun
intended.

(10:39:28 AM) during my usual open source collection [twitten newsgooglecom, etc]
[10:40:03 AM) bradassBT: >nod<

{10:40:51 AM) they?ve got a lot of ammunition. its the support they need from the public
in publishing the material coming through soon

[10:41:42 AM) info@adrianlamo.com: In general terms. have you seen my name anywhere else
l'rn not aware of? specify no particular venue.

{10:41:59 AM) not

(10:42:55 AM) bradassa'i': uhm OGA networks have you at results, all OSINT not
connected to Law Enforcement stuff

(10:44:10 bradassB7: 1 mention of your name with the french classi?ed but it was
from a product that is over-written since the producer doesn?t archive. couldn?t access the full
bit

(10:45:13 AM) bradassB'r': im sorry, if seem kind of creepy

(10:45:18 AM) stiflif i

(10:45:32 AM) info@adrianlamo.com: You don?t know how creepy my contacts get.

(10:45:49 AM) bradass??: how does this one rate

{10:46:10 AM) bradassa'l': 1-10 scale perhaps?

{10:47:15 AM) info@adrianlamo.com: 7ish. 1H on reliability/quality of data based on statements
made. Even odds on being a false flag.

{10:47:20 AM) info@adrianlamo.com: Nothing personal.

(10:47:57 AM) bradassB7: its ok

{10:43:00 AM) info@adrianlarno.com: This is dangerous. We learned my lessons in tightropes.
(10:48:05 bradassB7: i?ve got time

(10:48:43 AM) info@adrianlamo.com: Would you know if a speci?c person had authored a
repor?paper?

{10:49:23 AM) bradass?'r: not

[10:49:42 AM) bradassBY: bureaucrats usually aren?t that intelligenti find

(10:49:54 bradassB7: [re: false flag]

(10:50:03 info@adrianlamo.com: Webster. Timothy D.

{10:51:05 who?s that?

(10:51:21 bradassa'r': he's an author obviously

{10:51:28 bradasstih Sex and Intimacy [goog]

Page 3 of 48

(10:51:59 AM) info@adrianlarno.com: SA with NGA (former)

(10:52:18 AM) squints

(10:52:22 AM) bradassST: >shiyer<

(10:53:01 AM) brada5587: squints creep me out

(10:53:06 AM) info@adrianlamo.com: Specialty FCI in cyber?areas.

(10:53:53 AM) bradassa'i?: no

(10:54:45 AM) im not really sure where this is apart from awkward weirdness
(10:55:31 AM) info@adrianlamo.com: I apologize if I've made you feel awkward.

(10:55:37 AM) bradassBT: no. its me

(10:55:54 AM) oracles-.587: i said too much too fast

(10:55:59 info@adrianlamo.com: He wrote a paper a while back. was curious how it had
been received by the IC.

(10:56:36 AM) bradassa'l: i guess i can ?nd out. though im restricted to SIPR now. because of the
discharge proceedings

(10:58:10 AM) bradassB7: am i coming off too quick? ive closed myself off for so
(10:58:41 AM) bradass37: ithought i?d reach out to someone who would possibly
(10:59:01? AM) brada5587: s? [this person is kind of fragile]

(10:59:29 AM) bradassBT:

(11:00:53 AM) bradassa7: anyway. i?m going i'll be back in about 30?
40 min?

(11:01:39 AM) info@adrianlamo.com: i?ll be around

(11:01:43 AM) info@adrianlamo.com: i usually am

(11:01:44 AM) bradassai':

(11:01:47 AM) hradassBT:

(11:01:48 AM) info@adrianlamo.com: around and understanding both

(11:02:17 AM) info@adrianlamo.com: be well. and stay out of trouble

(11:22:11 AM) wow. that was quick

(11:22:50 AM) iguess i can talk a little bit about imean. We
really got nothing to lose [i know. sounds desperate]

(11:23:19 AM) bradassBT: i was born in central oldahoma. grew up in a small town called crescent.
just north of oklahoma city

(11:23:59 AM) bradassBT: dad was a manager of computer programmers at hertz corporation.
doing legacy maint.. etc

(11:24:41 AM) mother was british (speci?cally welsh). married father while he was
stationed at an air force base in southwest wales

(11:25:18 AM) info@adrianlamo.com: I?m of Scottish 8: Welsh descent.

(11:25:22 AM) info@adrianlamo.com: On one side.

(11:27:18 AM) bradassBT: i was a short (still am). very intelligent (could read at 3 and multiply
divide by 4). very effeminate. and glued to a computer screen at these young ages (MSDOS
Windows 3.1 i played SimCity [the original] obsessively

(11:27:40 AM) bradass?7: an easy target by

(11:28:07 AM) bradass?i?: grew up in a highly evangelical town with more church pews than people
(11:28:48 AM) so. i got pretty messed up at "girly boy" ?teacher?s pet". etc

Page 4 of 48

(11:29:57 AM) bradassal?: home was the same. alcoholic father and mother was very
nice. but very needy father was very wealthy (lots of nice toys 1 computer stuff). but
abusive

(11:31:07 AM) bradassBT: my favorite things growing up were reading my watching
PBS (the only channel i could get on my TV) building with legs. and playing on my dad?s hand-me?
down computers

(11:31:42 AM) bradassBT: i lived in the middte of nowhere, so i had no neighbors to hang out with.
and my dad would never take me anyway. because after work heid hit the bottle

(11:32:58 AM) bradass?'l': i was a science fair won grand prize in my town 3 years in a row.
and played on the "academic bowl team" as team leader (which meant state championship!)
(11:33:45 AM) bradassBT: i didnt like getting beat up or called gay [didn't really know what gay
meant. but knew it was semething bad)

(11:34:06 AM) bradassa7: so ijoined sports teams, and started becoming an athlete

(11:34:15 AM) bradassB'l?: around this time (middle my parents divorced

(11:36:34 AM) bradassB'l': my father in a drunken stupor got angry with me because i was doing
some noisy homework while he was watching he went into his bedroom. pulled out a shotgun.
and chased me out of the the door was deadbolted. so i couldn't get out before he caught
up with so my mother (also wasted) threw a lamp over his head. .. and i proceeded to ?ght
him. breaking his nose. and made it out of the my father let off one or two shots. causing
damage, but injuring nobody. except for the belt lashing i got for "making him shoot up the house?
{11:36:59 AM) bradassa'l': i went to school the next day. and my teachers noticed the wounds, and
got social workers involved

(11:37:11 AM) bradassa'l': he immediately stopped drinking. and my mother filed for divorce
(11:37:29 AM) bradassa'l': after the divorce. my mother attempted

(11:33:23 AM) bradassST: aftertaking care of her for awhile. and gaining custody of me. my mother
took me to her hometown, haverfordwest, to live and go to school

(11:38:49 AM) bradasth': i spent four years in the UK. continuing my education

(11:39:13 AM) bradassB?: i also started playing around more and more with computers. speci?cially
webservers

(11:39:54 AM) bradassB7: to try and mitigate various ?nancial problems while going to school. i got
the idea with a rather sly friend to form an internet

(11:40:25 AM) bradass?ir': archive
(11:40:57? AM) bradassB7: we fell out over variOus and the project was ended. luckily
without any losses

(11:41:57 AM) bradassBT: i learned a lot about running LAMP jazz. routing. as well as
the business stuff. PR

(11:42:24 AM) bradassB'i': after that fell through. my education started to slip as my
mother started getting very ill

(11:42:43 AM) she had a minor then a mild and i was getting desperate
(11:43:02 AM) bradassS7: so i called my father. and begged him to live in the US again

(11:43:19 AM) bradassBT: my passport had expired so i had to travel overnight to Iondon
(11:44:11 AM) bradassa'i': i stayed at a hostel in the kings cross area overnight, and left to go to
hyde park [where all the embassies are]

Page 5 of 48

(11:45:13 bradassB7: what really sucked though, was that as i entered the all hell
started breaking there was a horrific boom, screaming. sirens. and thick black it
was july 7th

{11:45:39 bradassB'l': i panicked and went by foot, not knowing what was going on

(11:45:47 info@adrianlamo.com: sorry for latency things demanding my attention are
exceeding my capacity to allocate resources, forcing me to double-book mentally: and that only
scales so far.

(11:46:04 bradassB?: its ok, im just venting a lot

(11:47:28 bradassBT: im very isolated lost all of my emotional support
family, boyfriend. trusting im a mess

(11:49:02 bradass?l': im in the desert. with a bunch of hyper-masculine trigger happy ignorant
rednecks as and the only safe place i seem to have is this satellite internet connection
(11:49:51 bradassBT: and i already got myself into minor trouble, revealing my uncertainty over
my gender which is causing me to lose this and putting me in an awkward limbo
(11:50:54 AM) bradassBT: i wish it were as simple as "hey, go transition?. .. but i need to get
paperwork financial stuff legal and im still deployed. so i have to redeploy
back to the US and be outprocessed

(11:52:09 AM) bradassB'l: i could be hanging out here in limbo as a super-intelligent. awkwardly
effeminate supply guy [pick up these boxes and move them] for up to two months

(11:52:23 AM) bradassBY: at the very least, i managed to keep my security clearance [so far]
(11:5?t49 AM) brada558?: im sorry, im a total mess right

(11:58:33 bradasst?': and little does anyone know. but among this ?visible? mess, theres the
mess i created that no?one knows about yet

(11:58:59 bradassB7: i have no idea what im doing right now

(12:00:34 bradassB7: im so sorry

(12:04:36 info@adrianlamo.com: don't be sorry, just give me a chanCe to read

(12:06:18 info@adrianlamo.corn: how did this not come up as an issue in your background
check? I?m guessing you have an and not a T8.

(12:06:29 TSISCI

(12:06:47 PM) bradassBT: i enlisted in height of iraq war. no-one double checked much
(12:07:06 PM) info@adrianlamo.com: Well. hell, if you made it in, maybe I should reconsider the
offer I got from what used to be

(12:07:09 bradassB?: background checks are jokes anyway

(12:07:23 info@adrianlamo.com: it's hit-or?miss.

(12:08:04 bradassBT: wouldn't have been worth it

(12:10:21 bradassB7: they are a mess. and wholly dependent on frivolous network security
contracts and physically securing networks

(12:10:58 PM) info@adrianlamo.com: I doubt they?d hire me to dick around with that.

(12:11 :03 PM) bradassal": i've been penetrating *.smi .mil networks for over a year

(12:11 :21 PM) bradassBT: as well as *.sgoy.gov

(12:11:49 PM) bradassa7: ive created a massive mess

(12:12:30 PM) bradassB?: and no-one has a clue, because 95% of efforts are on physical security
of classified and managing OPSEC on unclassified networks

Page 6 of 48

(12:12:46 PM) info@adrianlamo.com: Want to go to the press?

(12:12:51 PM) bradassa'i': no

(12:12:59 PM) bradassBT: theres an issue with that

(12:13:01 PM) info@adrianlamo.com: open offer.

(12:15:11 PM) bradassB'l': hypothetical question: if you had free reign over classi?ed networks for
long periods of say. 8-9 and you saw incredible things. awful things that
belonged in the public domain. and not on some server stored in a dark room in Washington
what would you do?

(12:16:38 PM) bradassBT: or Guantanamo. Bagram. Bucca. Taji. VBC for that

(12:17:47 PM) bradassBT: things that would have an impact on 6.7 billion people

(12:21:24 PM) bradassBI?: a database of half a million events during the iraq from
2004 to with reports. date time groups. lat-Ion locations. casualty or 260.000
state department cables from embassies and consulates all over the world, explaining how the ?rst
world eXploits the third. in detail. from an internal perspective?

(12:22:49 PM) bradassB7: the air-gap has been

(12:23:19 PM) info@adrianlamo.com: how so?

(12:26:09 PM) info@adrianlamo.com: yt?

(12:26:09 PM) bradassBT: lets just say *someone" i know intimately well. has been penetrating US
classified networks. mining data like the ones and been transferring that data from the
classi?ed networks over the ?air gap" onto a commercial network computer. .. sorting the data.
compressing it. it. and uploading it to a crazy white haired aussie who can?t seem to stay
in one country very long

(12:27:13 PM) bradassa'i': im here

(12:27:24 PM) info@adrianlamo.com: Depends. What are the particulars?

(12:28:19 PM) bradassB7: theres substantial tag i think

(12:29:52 PM) info@adrianlamo.com: I don't understand.

(12:30:13 PM) bradassBY: what was the last message you recieved?

(12:30:47 PM) info@adrianlamo.com: (12:28:19 PM) bradassB7: theres substantial lag i think
(12:30:56 PM) brads-15587: before that

(12:31:09 PM) info@adrianlamo.com: (12:25:09 PM) bradassBT: lets just say *someone' i know
intimately well. has been penetrating US classified networks. mining data like the ones
and been transferring that data from the classified networks over the "air gap" onto a commercial
network sorting the data. compressing it. it. and uploading it to a crazy white
haired aussie who can?t seem to stay in one country very long

(12:27:13 PM) bradassBT: im here

(12:27:24 PM) info@adrianlamo.com: Depends. What are the particulars?

(12:31:43 PM) bradassBT: crazy white haired dude Julian Assange

(12:33:05 PM) bradassBT: in other ive made a huge mess

(12:35:17 PM) bradassBT: im im just emotionally fractured

(12:39:12 PM) bradassBT: im a total mass

(12:41 :54 PM) bradassB7: i think im in more potential heat than you ever were

(12:41 :54 PM) info@adrianlamo.com I have more messages than resources
allocatable to action them. Please be very patient.

Page 7 of 48

{12:45:59 info@adrianlamo.com: not mandatorin

(12:46:08 info@adrianlamo.com: there are always outs

(12:46:17 info@adrianlarno.com: how long have you helped Wlkileaks?

(12:49:09 PM) bradassB7: since they released the 9H1 ?pager messages"

(12:49:38 PM) bradassB?: i immediately recognized that they were from an NBA database. and i
felt comfortable enough to come forward

(12:50:20 bradassBT: right after thanksgiving timeframe of 2009

(12:52:33 PM) bradassBT: Hilar?ilr Clinton, and several thousand diplomats around the world are
going to have a heart attack when they wake up one morning, and ?nds an entire repository of
classi?ed foreign policy is available; in searchable format to the

(12:53:41 brada5587: siHiIarylHitlary

PM) info@adrianlamo.com: What sort of content?

(12:56:36 PM) info@adrianlarno.com: cigarette

(12:56:43 PM) info@adrianlamo.com: keep typing <3

(12:59:41 PM) bradassBT: crazy, almost criminal political the non-PR?
versions of world events and all kinds of stuff like everything from the buildup to the
Iraq War during Powell, to what the actual content of ?aid packages" is: for instance, PR that the US
is sending aid to pakistan includes funding for that much is true. it includes
that, but the other 85% of it is for F-16 ?ghters and munitions to aid in the Afghanistan effort. so the
US can call in Pakistanis to do aerial bombing instead of americans potentially killing civilians and
creating a PR crisis

(1:00:57 bradassBT: theres so it affects everybody on everywhere there's a
US there's a diplomatic scandal that will be Iceland, the Vatican. Spain. Brazil.
Madascar. if its a country. and its recognized by the US as a country, its got dirt on it

{1:01:27 bradassB?: i need one myself

(1:10:38 PM) bradassB?: its open world-wide anarchy in CSV its Climategate
with a global scope, and breathtaking its beautiful. and

{1:10:33 info@adrianlamo.ccm I have more messages than resources
allocatable to action them. Please be very patient.

(1:1 1 :54 its important that it gets i feel. for some bizarre reason
{1:12:02 bradassB'i': it might actually change something

(1:13:10 bradassBT: dont wish to be a part of at least not im not i
wouldn?t mind going to prison for the rest of my life. or being executed so much, if it wasn't for the
possibility of having pictures of plastered all over the world as

(1:14:11 bradassBY: i've totally lost my i make no the CPU is not made for this


(1:14:42 PM) bradass?7: slas boyias a boy

(1:30:32 >sigh<

(1:31:40 bradassBT: i just wanted enough time to ?gure myself to be and be
running around all the time. trying to meet someone else's expectations

(1:32:01 bradassB'r': ?and not be

(1:33:03 bradassa7: im just kind of drifting now. .

Page 8 of 48

{1:34:11 bradassB?: waiting to redeploy to the US. be and ?gure out how on
earth im going to transition

{1:34:45 bradassB7: all while witnessing the world freak out as its most intimate secrets are
revealed

[1:35:06 bradass?7: its such an awkward place to be in, emotionally and
[1:35:05 info@adrianlamo.com I have more messages than resources
allocatable to action them. Please be very patient.

{L39m3 bradassBT: i cant believe what im confessing to you

{1:40:20 bradassBT: ive been so isolated so i iust wanted to be nice. and live a normal
but events kept forcingme to ?gure out ways to smart enough to know whats going
on. but helpless to do anything. .. no-one took any notice of me

[1:40:43 oracles-.587:

[1:43:51 info@adrianlamg.Cgm: back

[1:43:59 im self medicating like crazy when im not toiling in the suoolv of?ce (my
new location. since im being discharged. im not officallv intel anymore}

(1:44:11 bradassB?: you missed a

(1:45:00 info@adrianlamo.com: what kind of scandal?

{1:45:16 bradass?7: hundreds of them

1:45:40 PM info adrianlamo.com: like what? I?m enuinel curious about details.
(1:46:01 bradass?'i': i dont theres so 1 dont have the original material anymore
(1:46:13 bradassBT: the Holy See and its position on the Vatican sex scandals
{1:46:26 info@adrianlamo.com: plav it by ear

{1:46:29 bradassa'l: the broiling one in Germm

{1:47:36 bradassBT: im sorry. there's so its impossible for any one human to read all
and not feel and possibly desensitized

(1:48:20 bradass?T: the scope is so and yet the death so rich

[1:48:50 info@gdrianlamo.com: give me some bona ?des vanno? any specifics.

(1:49:40 this one was a test: Classi?ed cable from US Embassv Revkiavik on
Icesave dated 13 Jan 2010

(1:50:30 bradassBT: the result of that one was that the icelandic ambassador to the US was
recalled. and ?red

(1 :51 :02 bradassBT: thats iust one

{1:51:14 info@gdrianlgmo.com: Anything unreleased?

{1:51:25 bradassS7: i?d have to ask assanqe

[1:51:53 bradassBT: i zero?lled the original

[1:51:54 info?adrignlamocom: why do you answer to him?

[1:52:29 i i iust want the material out i dont want to be a part of it
[1:52:54 PM) info@adrlanlamo.com: i've been considering helping wikileaks with opsec

[1:53:13 PM) bradassB'I: they have decent im obviously violating it

[1:53:34 bradassBT: im a wreck

(1:53:47 bradassBY: im a total fucking wreck right now

(1:54:04 info@adrianlamo.corn: not really. 2600 is an ally of wikileaks.

(1:54:10 info@adrianlamo.com: how old are you?





Page 9 of 48

(1:54:15 PM) brada558?: 22

(1:54:55 PM) bradassB?: but im not a source for im talking to you as someone who needs
moral and emotional fucking support

(1:55:02 PM) bradassBT:

(1:55:10 PM) info@aclrianlamo.com: i told you. none of this is for print

(1:55:16 ok. ok

(1 :55:19 info@adriantamo.com: i want to know who i?m supporting

(1:55:25 info@adrianlamo.com: no names as yet

{1:55:26 im flipping

1:55:32 PM) info@adrianlamo.com: security.

(1:55:43 PM) bradassBT: huh?

(1:55:51 info@adrianlamo.com: re. no names as yet.

(1:55:56 PM) info@adrianlamo.com: except brad. i assume.

(1:55:23 bradassBT: ive already sent you full name in

(1:56:43 info@adrianlamo.com: oh! you?re the PGP guy

(1:56:52 PM) bradass??i': yeah, im sorry

(1:56:57 PM) info@adrianlamo.com: i?m an idiot

(1:57:33 PM) bradassa'I: im pretty reckless at this point

(1:57:53 PM) bradassa'i': but im trying not to end up with 5.56mm rounds in my
(1:53:38 PM) bradassBT: that i fired.

(2:00:18 PM) bradass?T: im not lying when i say im totally out of it right now

(2:01:02 PM) bradassB?: ok, im not suicidal quite

(2:01:14 bradassBT: but im pretty desperate for some non?isolation

(2:02:34 PM) bradas587: idk anymore

(2:04:29 bradass?i': im a source. not quite a volunteer

(2:05:38 bradass?7: i mean. im a hioh pro?le and We developed a relationship with
but i dont know much more than what he tells me. which is very little

(2:05:58 bradass??: it tool-t me four months to con?rm that the person i was communicating
was in fact assanoe

{2:10:01 info@adrianlarno.com: how?d you do that?

(2:12:45 bradassS?: oathered more info when i questioned him whenever he was beinq tailed
in Sweden by State Department iwas tryino to hours out who was following and
and he was tellino me stories of other times he?s been and they matched up with
the ones he's said publicly

(2:14:23 info?zad?g?lamdcom: did that bear out? the surveillance?

(2:14:46 based on the description he oave me, assessed it was the Northern
Europe Diplomatic Security tryino to ?oure out how he set the Reykiavik

(2:15:57 theualso oauoht wind that he had a of the Gharani airstrike in
afohanistan. which he has, but hasn?t the production team was actually workino on
the Baohdad strike though. which was never really

(2:15:22 PM) bradassBT: he?s not the whole 15-6 for that so it wont iust be video with no
context

Page 10 of 48

(2:16:55 PM) but its not nearly as it was an awful incident. but nothing like
the baghdad one

{2:17:59 PM) bradassB?: the investigating of?cers left the material unprotectedLsittino in a directory
on a centcomsmitmil

(2:18:03 PM) bradassB7: server
2:18:56 PM bradassBT: but the did zi
afaik it hasn?t been broken vet
{2:19:12 PM) bradassB?: 14+
[2:13:37 bradassBT: i can?t believe what im telling you

{2:19:50 PM) bradassBT: ive had too many chinks in my armor

{2:20:52 PM) bradass87: im a broken soul

{2:21:22 PM) bradassBT: i need to go eat. ill

(2:21:26 PM) info@adrianlamo.com: *hug"

{2:21:39 PM) bradassB?: thank you it means a lot

(2:54:21 im sorry

{2:54:21 info@adrianlamo.com I have more messages than resources
atlocatable to action them. Please be very patient.

(2:55:00 PM) bradassa'i': ugh

(2:56:34 PM) bradassB'h my family is my boyfriend ditched me without telling
im losing my losing my career i dont have much more except for this laptop.
some books. and a hell of a story

(2:57:25 PM) bradasst37: honestly, scared

(2:52:32 bradassa?l': and i have no-one i trust

(2:53:21 bradassB7: i need a lot of

(2:58:48 PM) bradassBY: i dont know ifi can rebuild from

(3:00:43 PM) info@adriantamo.com: you can always rebuild.

(3:01:03 PM) bradassB7: yes. but i cant KEEP rebuilding all the damn im exhausted
(3:01:26 PM) bradassB'l?: i didnt get into my boot with homelessness across the country in ?06
(3:01:45 PM) bradassBT: i drifted from oktahoma city. to tulsa. to chicago. and ?nally landed at my
aunt's house in DC

{3:02:29 bradassBT: im in desperation to get somewhere in i joined the
and that's proven to be a disaster now

(3:02:49 bradassB7: i've done a lot of random stuff. that no-one knows

(3:03:09 PM) bradassS'i': its just such a disconnect between myself. and what i and what
people see

(3:04:57 PM) bradassa'l': and now i'm quite possibly on the verge of being the most notorious
"hacktivist" or whatever you want to call its all a big mess i've im sorry.
(3:05:51 im pouring my heart out to someone i've never met. and i dont exactly
have a lot of proof of anything

(3:05:59 PM) bradassBT: im shattered

(3:06:4i' PM) bradassST: im so exhausted

(3:07:10 PM) im a real

[3:11:13 PM) info@adrianlamo.com: no apologies needed



the ?les. aes?256 with an excellent so



Page 11 of 48

(3:12:00 oracles.th ?gulp?:

(3:12:34 PM) bradassa'i': i wish i could explain the pain

(3:12:39 info@adrianlamo.com: are you on Facebook?

(3:12:56 PM) info@adrianlamo.com: As an aside. are you concerned about prosecution?
(3:13:02 PM) bradassBIh sort you cant ?nd me

(3:13:15 PM) info@adrianlarno.com: Your MICE seems to be ideology.

(3:14:32 info@adrianlamo.com: I can't ?nd a SPC in ZBCT 1DMTN 82?

(3:15:14 PM) bradassBT:

(3:15:39 info@adrianlamo.corn: Nope.

(3:15:06 PM) login.? ?rstlast

[3:16:45 PM) bradassa?: pass: [redacted] [no spaces]

(3:17:06 PM) info@adrianlamo.com: wanna sponsor me for an AKO account? I used to have one


(3:17:14 PM) bradassa?i': sure

(3:17:32 PM) bradass?i': use mine. its not really of any use to me right now

(3:1?:47 PM) info@adrianlamo.com: negatory

(3:17:48 PM) bradassa'f: sorry "i

(3:18:05 PM) info@adrianlamo.com: ijust wanted back
(3:18:24 PM) bradassS?: ok

(3:18:59 PM) info@adrianlamo.com: remember. ?nding stuff is what i do. and curiosity is my
game.

(3:19:09 PM) bradassBT: i know

(3:19:23 PM) info@adrianlamo.com: including your personal ad from 3 years ago.
(3:19:32 bradassBT: which one?

(3:19:50 PM) info@adrianlamo.com: i closed the window: it wasn't relevant

(3:20:13 PM) bradassSi?: via bradassBT. .. i dont know how that one got set up.
(3:20:14 info@adrianlamo.com: sadly. it lacked a photo

(3:20:33 bradassB7: its from some kind of weird fetish

(3:20:37 bradassBT: they wouldn't let me delete it

(3:21 :07 bradass?'i': im pretty intenyebbies-wise

(3:21:43 PM) bradassBT: is there a public facebook i can add you from?

(3:22:59 PM) bradasst?': wow, didnt knowi had a xanga account

(3:23:15 PM) info@adrianlamo.com: what do you mean re. facebook

(3:24:06 PM) bradassa7: mine is not you must be a friend to see or a friend of a friend
to even know it exists

(3:24:23 PM) info@adrianlamo.com: facebookcomffelon

(3:24:54 PM) bradassS'i': requested

(3:25:41 god that pacman thing is starting to get annoying

(3:25:14 PM) bradass?7: enjoyed it at ?rst. but now everytime i open a new browser
whoo-whoo-whoo-whoo?whoo

(3:26:53 PM) bradass?'l: let me make more info available to you

(3:27:00 PM) bradassa?f: hold on, need change my privacy settings

(3:23:10 PM) info@adrianlamo.com: you?re kinda cute.

Page 12 of 48

(3:23:44 PM) bradassa?: refresh, you should be able to see check to see if you can see
more photo albums

(3:29:33 PM) bradassBi":
snc3fh3024snc3i'11156



(3:29:46 PM) bradassB'i?: one of the few times you will ever see the inside of a SCIF

(3:30:09 PM) bradassBT: the map in the background is classi?ed SECRETNREL TO USA, MCFI
(3:31:11 PM) brad-35587: behind the cabinet) with the blue bucket on is the entrance to the
SIGINT section

(3:31 :42 PM) medals-58?: is where they process all the recorded phone data from towers in all of
eastern baghdad

(3:32:27 PM) bradassBY: interrogator chick on top right corner

(3:33:04 PM) bradassB7: you can see me slowly descending spiritually in the wall posts
(3:35:09 PM) bradassBT: i cant really seem to de?ne my ideology

{3:36:07 PM) info@adrianiamo.com: You already have my most permissive privacy settings.
(3:36:26 PM) bradassBTalbums?

(3:38:39 PM) bradassB'i': we have two mutual friends. how interesting

(3:40:08 PM) bradassST?: small world

(3:41 :39 PM) bradassBT: asigh<

(3:41:51 PM) bradassBT: Iauren your ?ex?

(3:42:15 PM) bradassa'i': tyler watkins would be fucking ditched me

(3:42:30 PM) bradassBT: im still utterly flabberghasted

(3:43:13 PM) i dont i cant seem to hold a We got so much
baggage

(3:45:04 PM) bradassSi': im all mixed up

(3:46:14 PM) bradassa'i': lost a in a short period of time

(3:48:20 PM) bradassST: im a mess. huh

(3:49:41 PM) info@adrianlamo.com: i?m familiar with loss

(3:49:52 PM) info@adrianlamo.com: lauren?s in AZ

(3:50:36 PM) info@adrianlamo.com: was that a yay or nay on the AKO sponsorship. or does your
acc?t have that ability?

Page 13 of 48

{3:51:31 bradassBT: cant seem to do it without con?rmation of spouse seems to be
no way around also. you?d be booted out by the time i get discharged

(3:55:06 i dont know how im going to break the news to

(3:56:16 bradassBT: how would you rate the ethics of my situation?

(4:03:06 PM) bradassBT: ugh. im a mess

(4:07:14 PM) bradassBT: what ideology do i seem to be foliowing?

(4:16:26 PM) bradassBT: :sigh:

(4:16:34 bradassBT: *sigh*

(4:28:34 PM) bradassB7: i'll work on the ako its getting awfully need sleep
(4:54:44 PM) info@adrianlamo.com: sorry i'm just swamped today. i?ll be more talkative in the
future.

(4:55:16 PM) info@adrianlamo.com: keep your chin up. for me. *re?hug?



(7:18:03 AM) bradass??: The message received from bradasstit'rr is unreadable. as you
are not currently communicating privately.

(7:19:05 AM) Unveri?ed conversation with bradass87 started.

0:19:12 infot?iadrianlamocom: hey you

(7:19:19 info@adrianlamo.com: resend?

[7:19:19 bradassa'r': whats up?

[7:19:49 said hello

(7:19:46 AM) info@adrianlamo.com: waking up. got up about an hour ago. 0615.

l?:20:10 brgdass?'r': heh. the evening is still young here

info@adrianlamo.com: how?re you feeling today?

(320:3? modest-18?: im feeling a little better.._

[7:20:52 AM) bradassBmind. keeping to myself

(7:22:18 info@adrianlamo.com: an?hirtg new a. exciting?

[7:24:21 hradass?h no. was outside in the sun all 110 degrees F. doing various details
for a visitirMand and some college team?s



(7:24:43 info@adriantamo.com: cheerleaders.
(7:24:46 ran a but no-one showed threw a lot of food away
7:25:20 AM as football visitin on off a art of Morale



Welfare and Recreation projects

(7:25:39 info@adriantamo.com: *sigh*

(7:26:01 bradassai?: >shrug<

[7:26:37 brgdassa7: im and smell like charcoal. sweat. and thats
about all thats new

(7:26:47 infot?zadrianlamocom: Is there a Baghdad 2600 meeting? :5

{7:28:04 bradgss?h there?s only one other person im aware of that actually knows anything
about computer he?s a analyst. of course

(7:28:41 is he the other one who pokes around he network?
(7:29:26 AM) afaik. he doesn't play around with classi?ed but im sure

he's cagable

Page 14 of 48

(7:30:09 AM) infoQadria?mosom: then it stands to reason that vou have at least 3 people who
have some intosec knowledge

(3:31:15 bradassa'i?: im not quite sure what vou?re saving

(7:31:23 AM) bradassa7: infosec knowledge of what?

(7:31:29 baggeth the networks?

(7:32:13 precise-587: i know a lot of computer securitv people

(7:33:44 info?ladrianlammcom: i mean. in a wav that would lend itself to a meeting.
(7:33:33 info?adrianlamo.com: i'm writincLa message trvino to tie meetings together globallv
with a sampling of onlL-vBGOOpeopte to work with and get to go out and evangelize. so i have it on
the brain

7:33:50 AM bradassa7: know how to. but dont

[7:34:33 AMJ bradassBT: vou don?t want these people having a meeting

(7:34:48 bradass?: i guess vou do

(7:35:37 AM) bradass?7: other person knows a lot about how to tap cellular phones (its
his job. after all)

(7:35:56 bradassBY: PROPHET team

(7:36:22 AM) bradassB7:

(7:36:47 AM) info@adrianlamo.com: Can they do CDMA or GSM over-the~air vs. at the switch?
(7:37:07 AM) bradass?i?: both

(7:37:16 bradassBT: v3 as well

(7:37:48 AM) bradassBT: over?the-air and at switches and

(7:38:05 AM) bradassa7: redundancy for locational re?nement

(7:38:14 info@adrianlamo.com: I assume the same could be done in the US.

{7:38:37 bradassB7: of course

(7:39:14 info@adrianlamo.com: Too bad Philip Agee died. You and he would have fun
conversations.

(7:39:43 bradassB'i': well. im not an expert in irn Just familiar

(7:40:06 AM) info@adrianiamo.com: Neither was he. He just didn?t like what he saw in the course
of his work.

(7:40:11 AM) info@adrianlamo.com: And wrote about it.

(7:40:43 AM) info@adrianlamo.com: "Inside the Company? - followed by ?On the Run",
predictably.

(7:40:56 AM) bradassa7: i know that approximately 85?90% of global transmissions are sifted
through by but vast majority is noise. .. so its getting harder and harder for them to track
anything

(7:41:31 AM) bradassBT: its like ?nding a needle in a

(7:42:11 AM) info@adrianlamo.com: Especially the way I speak Spanish. Rapid?re. few pauses
between words :p

(7:43:11 AM) bradassB7: heh

(7:43:41 AM) info@adrianlamo.com: Colombians in Colombia think all Americans are CIA. it?s kind
of funny.



Page 15 of 48

(7:44:01 AM) breasts-587: but once a single piece of information is then the databases can
be sifted and sifted and sifted some more. for re?nement, so other intelligence functions can get in
the act

(7:44:09 AM) info@adrianlamo.com: Fortunately, there are plenty of Colombians with my skin
tone.

(7:44:20 AM) bradassB7: >nod<

(7:45:52 AM) bradassa7: im not all that paranoid about NBA i SIGINT you just have to
be OPSEC savvy. and you're all good

(7:45:27 AM) bradassB7: and FISA actually does come in very handy

(7:46:46 AM) bradassBT: though. its frequently overlooked

(7:47:36 AM) bradass87: they?ll collect signal information. to refine other intel sources and try to
collect

(7:47:57 AM) bradassB7: erasing the signal data

(7:48:11 AM) bradassB7: since its not legally "evidence"

(7:49:38 AM) bractassl37: and yes. illegal wiretaps are used in coordination between NSA and FBI ..
though its not seen as illegal, because often the data is only used to give leads

(7:49:42 bradassB7: and not evidence

(7:50:49 AM) info@adrianlamo.com: *nod"

(7:50:52 AM) bradassa7: one of the reasons assange uses his rubberhose plausibly deniable
whole-disk setup

(7:51:46 AM) bradassST: i can see both sides of the whole illegal wiretap debate

(7:52:17 AM) bradass37: it IS awfully useful in catching bad but innocent privacy IS


(7:52:37 AM) bradassBT: but everyone does it

(7:53:08 AM) bradassB7: its an thats my honest opinion

(7:53:31 AM) bradas587: so. i as much as i can

(7:54:31 AM) info@adrianlamo.com: how much can be trusted?

(7:54:38 AM) info@adrianlamo.com: say. is PGP secure?

(7:55:13 AM) bradass87: depends on the depends on how safe you keep
your private keys

(7:55:25 AM) bradassBT: DES Triple you're doomed in minutes

(7:55:45 AM) AES take brute force

(7:56:06 AM) bradassBT: days to weeks to break

(7:56:24 AM) bradassai': its about securing the keys. using complex enough

(7:56:42 AM) bradassB7: and sticking to Rijndael variants

(7:57:15 AM) info@adrianlamo.com: Does keylength matter past 2048?

(7:57:28 AM) bradassB7: it can

(7:53:06 AM) RSA 1024 takes a few university of michigan finally broke it with
a partial

(7:59:00 AM) bradassBT: never heard of it being broken NSA can feasibly do it. if
they want to allocate national level ?number-crunching" time to do

(7:59:56 AM) info@adrianlamo.com: What about

(8:00:33 AM) bradassa7: OTR is but change ?ngerprints every few weeks

Page 16 of 48

{8:00:59 AM) bradass?i': its not frequently used by its not a priority to find a crack
(8:01 :25 AM) bradassST: the whole pidgin adium learning curve has its advantage

{8:01 :30 AM) info@adrianlamo.com: Does Assanoe use AIM or other messaoind services? id like
to chat with him one of these davs about opsec. Mv onlv credentials beyond intrusion are that the
FBI never dot mv data or found mekbefore my negotiated surrender. but that?s somethinq.
{8:01:53 AM) info@adrianlamo.com: And my data was never recovered.

{8:02:07 AM) brawl?ass?z no he does not use AIM

(3:02:37 info@adrianlamo.com: How would I get ahold of him?

(3:433:59 bradassw: he would come to m!

{8:03:25 AM) infof?ladrianlamocom: I've never failed to set ahold of someone.

(8:03:29 bradass?7: he does use OTR but discusses nothino OPSEC

(8:03:42 I cornered Ashcroft IRL. in the end.

(8:04:19 bradassBT: he *mioht? use the cocde iabber but vou didn?t hear that from
1133

(8:04:33 dotcha

(8:06:00 bradassB7: im going to grab some dinner.

info@adrianlamo.com: 130826&id=704990
(8:06:47 tnfo?adrianlamo.com: ididn?t pass securitv, either. or rather. i did

[8:06:52 info?gdrianiamo.corn: eniov dinner.

(8:05:55 info@adriantamo.com: twvs.

(9:12:38 bk

(9:12:38 info@adrianlamo.com have more messages than resources
allocatable to action them. Please be very patient.

(9:22:54 bradassBT: marine ilieoal. but certainlv easv

(9:24:11 bradassa'I: ashcroft?

(9:24:24 bradassST: oh.

(9:24:29 bradassBT: >vawn<

(9:26:52 AMLbradassSi': im realiv not familiar at all with FBI stuff

(9_:27:04 AM) americans have so manv more riohts than non-americans

(9:31:42 bradassa7: its awful

(9:46:11 info?adrianlamocom: Ashcroft's DOJ tried to use the USA PATRIOT Acton me.
(10:05:24 info?adrianlamo.com: around?

{10:12:34 bradassB7: veah

{10:12:57 info@adrianlamo.com: are vou baptist bv anv chance?

(10:13:34 bradassa'l: raised never believed a word of it

(30:13:59 bradassa'l: im i duess i follow humanist values thouoh

(10:14:15 bradass?i': have custom dodtaos that sav "Humanist"

(10:15:19 AM) bradassB7: always been too intellectual. if notjust plain queer. for religion
(10:15:48 bradassB'I: why?

(10:17:15 AM) info@adrianlamo.com: regional religions in the US. incorrect hunch
(10:17:34 bradassBT: i suffered out there

(10:17:56 brad?55372 i was the on? non-religious person in town

Page 17 of 48

(10:18:17 orator?1558?: more_pews than

(10:13:37 bradassB7: i understand them thouoh

mm 8:53 im not mean to they *reallv* don?t know

[10:19:39 brad-35387: i ooliteiv but thev are the ones who qet uncomfortable when i
make. verv politely. good leading

?0:20:48 (bv leadinq points. i mean ask multiple questions, with obvious answers.
then ask a question based on the answers from the previous questions that challenges their normal
response to the same question)

(10:21:26 bf?d35537: [excellent example of this:


10:28:21 AaassBT: new orker is runnino 10k word article on More on 30 may,





[10:23:21 info@adrianlamo.com have more messaoes than resources
allocatable to action them. Please be verv patient.

mz33:07 info@adrianlamo.com: one moment fone

(10:33:30 boa?dassB'r?: {trackino device}

(10:37:28 AM) bradassBT: trust level increasino?? louantifv]

(10:58:30 AM) bradassBT:

snc3lh5005snc3r1

{10:58:30 AM) info@adrianlamo.com I have more messages than resources
allocatable to action them. Please be very patient.

bradassB?: :whistle:

(11:09:27 AM) info@adrianlamo.com have more messages than resources
allocatable to action them. Please be very patient.

(11:16:39 bradassat': here's an awkward i look so short



Page 18 of 48



(11:17:45 AM) info@adrianlarno.com: was on the phone. may have a gig copy-editing.
(11:21:34 info@adrianlamo.com: ironic, huh?

(11:21:55 AM) info@adrianlamo.com: well, not ironic

(11:21:57? AM) info@adrianlamo.com: just funny

(11:22:14 AM) info@adrianlamo.com: all the things i could do. buti copy-edit

(11:28:33 AM) Iol

(11:28:38 bradassS?: not much different from my (previous?) job

(11:28:42 AM) bradassa'I: take slides from subordinate battalions, change wording improve
spelling. replace battalion symbols with brigade symbols. disseminate throughout brigade and
forward to division

(11:29:12 bradassBT: leaves a computer savvy guy a lot of time to pry around

(11:31:13 AM) bradassa'f: i dont know what im going to do

(11:31:13 AM) bradassBT: well. obviously

(11:31:17? AM) bradassBY: i guess i could start electrolysis as soon im back in the even
before im outprocessed

(11:36:12 bradassBT: still gonna be weird watching the world change on the macro scale:
while my life changes on the micro

(11:36:12 AM) info@adrianlamo.com I have more messages than resources
allocatable to action them. Please be very patient.

(11:35:12 AM) never been good at the micro

(12:12:01 PM) bradassB7: fucking satellite internet

(12:12:01 PM) info@adrianlamo.com I have more messages than resources
allocatable to action them. Please be very patient.

(12:13:25 PM) bradassBT: light dust might go in and out of Cx

(12:33:53 PM) bradassBT: still there?

(12:33:53 PM) info@adrianlamo.com have more messages than resources
allocatable to action them. Please be very patient.

(12:38:30 PM) bradassST: ping

(1 :08:40 PM) bradass??: ping

(1 :24:21 bradassBT: did you know it took NBA 6 months. and 50 people to ?gure out how to
tap the iPhone

Page 19 of 48

(1:24:21 info@adrianiamo.com i have more messages than resources
allocatable to action them. Please be very patient.

{1:26:16 bradassBT: they honestly didn?t know what was going on, because of the sudden
format switch when made the contract

(1:26:32 PM) bradassa?I:

(1:2?:42 PM) bradassBT: [not 100% if thats true. but i?ve heard enough variations by NSA types to
betieve it]

(1:27:46 PM) bradass?'i': *sure

[1:35:13 bradassBT: ping

(1 :40:41 PM) bradassB7: ping

(1 :41:29 PM) bradassBT: [sorry. have a lot on my i like talking]

(1:55:28 PM) sleep [you can reply. ill check in morning]

(12:24:04 PM) bradassa?: hello again
(12:24:04 PM) info@adrianlamo.com I?m not here right now

(12:24:15 bradassBT has not been authenticated yet. You should authenticate this buddy.
(12:24:15 Unveri?ed conversation with bradassS? started.

(12:24:58 PM) bradassa7: hello again

[12:26:54 PM) tirade-15587: The New York Times

Published. January 201 1919



OPEN DEPLOMACY.

?Open diplomacy" does not mean
that every word said in preparing a
treaty should be shouted to the whole
world and submitted to all the mis-
constructions that malevolence. folly.
and evil ingenuity could put upon it.
Open diplomacy is the opposite of se-
cret diplomacy, which consisted in the
underhand negotiation of treaties
whose very existence was kept from
the world. It consisted also in the
modi?cation of openly negotiated
treaties by secret treaties by some

of the Powers behind the backs of the
others. it is against this kind of
double dealing and secret dealing, the
mother of wars. that the world
protested. It has demanded the sub-
stitution of open diplomacy for secret
diplomacy. But open diplomacy does

Page 20 of 4B

not turn a peace conference into a
debating society.

It would be reasonable for the
newspaper correspondents at Ver-
sailles to expect that the delicate work
of reconciling divergent points of view
on so tender a subject as national in?
terests should be wholly conducted in
their presence. The conferees, by rev
serving the right of holding executive
sessions while they admit the corre-
spondents to open sessions, have gone
as far as the needs of the public de-
manned. The world has intrusted the
Peace Conference with the work of
preparing the treaty, it wishes to
know what is done. and why it is
done: but the sensible part of it, at
any rate, has no desire to have spread
before it all the heart~to-heart talks
and turns of phrase of men perform-
ing the gigantic task of reconciling
national differences and coming to
agreement. It wishes to give malice
and anti-Ally propaganda as little as
possible to distort and warp. lt

knows from four years? experience
what in?nite possibilities are in

that line.

Copyright The New York Times

(01:58:40 PM) bradassB?: hi

(02:00:30 PM) info@adrianlamo.com: hey

(02:00:37 PM) info@adrianlamo.com: just woke up from a nap

(02:00:42 PM) bradassBT:

(02:00:58 PM) info@adrianlamo.com: feel hung over, without any alcohol to blame for it
{02:01:10 PM) info@adrianlarno.com: how's stuff?

(02:01:14 PM) bradassSY: haven?t had any alcohol since September

(02:01:24 PM) info@adrianlamo.com: i don't usually drink

[02:01:23 PM) bradassBT: nor do i

{02:01:52 PM) bradassB'I?: but i had a few drinks in September, since i knew i wasn't going to have
any for awhile

Page 21 of 43

(02:02:05 PM) info@adrianlamo.com: good enough reason.

(02:02:12 PM) bradassaifz uhm. i was reduced in rank today

(02:03:23 PM) info@adrianlamo.com: to what?

(02:03:27 PM) bradassBT: received a ?Company Grade Article 15" a formality (they only reduced
me in grade, and aren?t making me do "extra duty?) since they needed to punish me in some way
(02:03:36 PM) bradassB?: PFC

(02:04:59 PM) bradass87: i punched a colleague in the face during an (something i
NEVER DO. . . its whats sparked this whole saga

(02:06:24 PM) info@adrianlarno.com: did they have it oming?

(02:06:33 PM) brada558?: yes

(02:06:44 PM) bradassBT: as a result, i was referred (forced) to behavioral to evaluate
as a result. my commander had access to all of my mental health ergo how they found
out about my cross-dressing history. discomfort with my role in society. and the environment We
placed myself in

(02:07:03 PM) bradassa7?2 it was a minor but it brought attention to me

(02:02:46 PM) bradassa'l': the person kind of deserved but kind of it wasn't worth this
mass at all

(02:08:14 PM) bradassBT: (had a lot of high ?ves and "Go Mannings!")

(02:08:31 PM) bradassB?: not proud of it at all

(02:03:38 PM) info@adrianlamo.com: These things happen.

(02:00:41 PM) bradass87: and very surprised

(02:08:52 PM) brada5587: im not a violent person

(02:09:05 PM) bradass87: (odd to hear from someone in the Army?)

(02:09:13 PM) info@adrianlamo.com: neither am i. but i?ll be violent ifi have to.

(02:09:58 PM) info@adrianlamo.com: most people in the Army aren?t in specialties that involve
directly servicing targets.

(02:10:14 PM) bradassBT: im glad you realize that

(02:10:22 PM) bradassB7: (forgot you dated a Cl guy)

(02:11:10 PM) info@adrianlamo.com: make it my business to know as much as I can about
relevant topics.

(02:1 1 :43 PM) bradassa'l': indeed. a heavy curiosity

(02:11:51 bradassBT: ?nd much more about me?

(02:12:13 PM) info@adrianlamo.com: Only by talking to you 2)

(02:12:27 PM) info@adrianlamo.com: it'd be rude to deep search you.

(02:12:45 PM) bradassBT: its something im used to

(02:12:58 PM) bradassBT: i barely

(02:13:07 PM) bradassBT: because i anticipate interest

(02:13:15 PM) info@adrianlamo.com: words and actions say more than records on paper
(02:13:29 PM) bradassB?I: >nod< know this all too well

(02:13:54 PM) bradassa'f: gathering as many documents as possible re: my career

(02:14:12 PM) bradassS?: trying to control the narrative

(02:14:50 PM) bradas587: From an award recommendation (never completed}: Manning's
persistence led to the disruption of ?Former Special Groups" in the New Baghdad area. SPC

Page 22 of 43

Manning's tracking of targets led to the identi?cation of previously unknown enemy support zones.
His analysis led to heavy targeting of insurgent leaders in the area that consistently disrupted their
operations. SPC Manning?s dedication led to the detainment of Malik Fadil aI-Ugayli. a Tier 2 level
target within the Commando

Recommended awards for assisting in the disruption of Former Special Groups (FSG) in
Southeastern Baghdad. identifying and disrupting operations from previously unknown enemy
support zones in Hayy Zafaraniyah. and assisting in the detainment of Malik Fadil al-Ugayli. a Tier 2
level target.

(02:15:41? bradassai': Malik was a heavy cell phone user

(02:17:42 PM) info@adrianlamo.com: I gave mine to a friend to make one call a mile away and
then went dark.

(02:17z4? PM) info@adrianlamo.com: During my hunt.

[02:1?:57 PM) bradasst37: smart move

(02:19:54 PM) bradassBT: my speciality is (was) tracking a Shi'a group called Khatiai'o Hizbollah,..
they were OPSEC savvy as all didn't even know the group existed until Iranian
backed they make al-Qaeda knock offs look like

(02:20:13? PM) bradassS?: they?re the most dangerous guys in the

(02:20:28 PM) that is

(02:21 :10 PM) info@adrianlamo.com: Only because they are savvy in helping their communities
and building goodwill.

{02:21 :39 PM) info@adrianlamo.com: otherwise they're just light infantry.

(02:21 :52 bradassa7: they also specialize in the construction of EFPs

(02:22:02 bradass?i?: so good, we cant trace anything

(02:22:11 PM) not a sensor, not a cell nothing but a crater

(02:22:35 PM) bradassBT: they're ghosts

{02:22:54 info@adrianlamo.com: They taught Israel a few memorable lessons.

{02:23:16 bradassB7: they stopped targeting us. thank

(02:23:35 PM) bradassBT: they?ve moved into the political phase of their operations

(02:23:51 PM) info@adrianlamo.com: Fucks are our allies and still spy on us as much as they
please. And it?s kosher: cos it's part of the game.

(02:23:58 PM) info@adrianlamo.com: Israel. that is.

(02:24:23 PM) bradassa'i': well. we?ve got plenty of assets watching them all NF stuff of
course

(02:24:51 PM) info@adrianlamo.com: that's different. we're the Godd Guys (TM)

(02:24:56 PM) info@adrianlarno.com: *good

(02:26:01 bradassBT: i dont believe in good guys versus bad guys i only a plethora
of states acting in self with varying ethics and moral standards of course. but self-interest
nonetheless

[02:26:18 bradass?'f: slonlyl'onlv see!

{02:26:47 info@gdrianlgmo.com: the tm meant i was being facetious

(02:26:59 bradassST: gotchya
Page 23 ode

l02:2?:47 bradassBY: i mean. we're better in some we're much more use a
lot more words and qual techniques to leoitimize evemthinq

[02:28:00 PM) brada5587: its better than disappearinq in the middle of the niqht

[02:28:19 PM) bradassBY: but iust because somethind is more subtlegoesn?t make it riqht
[02:29:04 hradassBT: i quess im too idealistic

{02:31:02 PM) bradass?T: i think the thinq that qot me the that made me rethink the world
more than an?hing

{02:35:46 bradassB'I: was watchinq 15 detainees taken bv the Iraqi Federal for
p_rinting_ "anti?Iraqi literature?. .. the iraqi federal police wouldn?t cooperate with US forces, so iwas
instructed to investiqate the matter. ?nd out who the "bad quvs? were, and how signi?cant this was
for the it turned out. thev had printed a scholarlv critique aqainst PM i had an
interpreter read it for and when i found out that it was a beniqn political critique titled ?Where
did the monev do?" and followinq the corruption trail within the PM's i immediately took
that information and *ran" to the of?cer to explain what was he didn't want to hear anv of
he told me to shut up and explain how we could assist the FPs in ?ndinq
(02:35:46 info@adrianlamo.com I'm not here rioht now

(02:36:2? PM) brada558?: evervthinq started slippinq after i saw things differenth
{02:37:37 PM) bradass?i': i had alwavs questioned the thinqs worked. and investiqated to find the
but that was a point where i was a *part* of i was activelv involved in somethinq
that i was completelv aqainst. ..

[Ewen info?adrianlamocom: That could happen in Colombia.

[02:38:21 PM) info@adrianlamo.com: Different cultures. dude.

m:38:28 info@adrianlamo.com: Life is cheaper.

{02:38:34 oh im quite aware

(02:38:45 PM) infofc'ggdrianlamocom: What would vou do if vour rote iw Wikileaks seemed in
danger of beinq blown?

(02:33:48 bradassB7: but i was a part of and completer

(02:39:01 sometimes we?re all helpless

(02:39:34 PM) bradassB'F: and fiqure out how i could qet mv side of the storv befOre
evervthinp was twisted around to make me look like Nidal Hassan

13:40:15 PM) bradassBT: i dont think its going to happen

[02:40:26 PM) bradassa7: i mean, i was never noticed

[02:41:10 PM) bradassB?: reqular_lv except when i had somethinq then it was
back to "brinq me coffee. then sweep the floor"

(M24 bradas_s87: i never quite understood that

(02:42:44 bradassat': felt like i was an abused work

m2:43:33 bradassah also. theres qod awful accountabilitv of IP

02:44:47 the network was upqraded. and patched up so many and
svstems would do down. loos would be and when moved or hard drives were
zeroed

(02:45:12 bradassB'i?: its impossible to trace much on these ?eld

[02:46:10 PM) and who would honestlv expect so much information to be ex?ltrated
from a ?eld network?







Page 24 of 48

(02:46:25 info?adrianlamo.comt I'd be one paranoid boy in vour shoes.

t02:4?:07 the CM video came from a server in our domain! and not a sinole person
no?ced

10_2:4r:g1 info?adrianlamocom1

PM) bradass?T: Apache Weapons Team video of 12 JUL 07 airstrike on Reuters
some sketchy but fairly normal and civilians

{02:48:52 info?tadrianlamocom: How lono between the leak and the publication?
102:49z?l? bradassa'i': some time in februarv

{02:49:25 bradassBT: it was uploaded

{02:50:04 info?adrianlamocom: uploaded where? how would I transmit somethinq ifl had
similarly damning data

{02:51:49 bradassST: preferava openssl the file with see-255. .. then use at
prearranged drop to addresses

10215208 bradaSSB7: keepino the and uploadino via a different means
(02:52:31 info?adrianlamocom: so i myself would be SOL wro a way to prearranqe
[02:54:33 bradassB'r': not the submission should suf?ce thouoh
i'd use tor on top of

{02:54:43 PM) bradasstiT: but you're data is ooino to be watched

[02:54:44 bradassBT: *your

(02:54:49 bradassBT: by someone. more than liker

(02:54:53 PM) info@adrianiamo.com: submission where?

102:55:07 PM) bradassB'?: w .oro submission system

(02:55:23 PM) info@adrianlamo.com: in the massive queue?

(02:55:54 PM) bradassBT: lol. yeah. it IS pretty

[02:55:56 PM) bradassB?: buried

(02:56:04 PM) bradassa'i?: i see what you mean

[02:56:35 PM) bradassBT: lonq term sources do oet i can see where the "unfairness"
factor comes in

{02:56:53 info@adrianlamo.com: how does that preference work?

{02:57:47 bradassBY: the material is easy to

{02:58:27 because they know a bit more about the source than a pureiy
anon mous one

(02:59:04 bradassBi': and con?rmation publicly from earlier material. would make them more
likeiv to i

[02:59:16 PM) bradassBY: im not savino they but i can see how that might develop
[03:00:18 PM) bradassST: if two of the laroest public relations "coups" have come from a single
for instance

{03:02:03 bra?iss?i': purer 'submittinq' material is more liker to oet overlooked
without contacting them by other means and saving hey. check your submissions for

{03:02:03 info@adrianiamo.com I'm not here right now

{03:02:19 bradassB?: sfyoufso

(03:03:38 PM) bradassB?: iono. im not so ive seen the way the system works. and the
way the pubiic reacts, and the way the PR people ive never felt threatened





Page 25 of 48

(03:06:10 PM) bradassBT: i dont know whats wrong with

(03:07:01 PM) bradassBT: i couldnt let these thinos stay inside of the and inside of
my

(03:07:26 PM) brew?35587: i recognized the value of some

(03:07:33 bradass?7: knew what they duq deeper

(03:07:53 P1911 bradassB7: i watched that video cold. for instance

(03:10:32 at ?rst it was iust a bunch of guys getting shot up by a
no bio about two dozen more where that came from but something struck
me as odd with the van and also the fact it was being stored in a JAG of?cer's so
i looked into eventually tracked down the date; and then the exact GPS and i was
ok. so thats what then i went to the regglar and it was still on my
so i typed into the date. and the and then i see this


(03:11:07 bradassB7: i kept that in my mind for probably a month and a before
i forwarded it to them

(03:11:54 bradassa'I: then there was the Finkel book

(03:12:16 PM) bradassBT: im almost certain he had a copy

(03:12:16 PM) info@adrianlamo.com I?m not here right now

(03:13:31 PM) bradassa7: it was i mean. i've identi?ed bodies its rare to do so.
but usually its iust some nobody

(03:13:48 PM) it humanized the whote re-sensitized me

(03:15:38 i dont im just. weird i guess

(03:15:49 i cant separate myself from others

(03:16:12 PM) ifeel connected to like they were distant family

(03:16:24 PM) bradassB'l': care?

(03:17:27 PM) sums it up for me
(03:18:17 bradassB7: i probably shouldn?t have read sagan, feynman. and so many intellectual
authors last

(03:21:11 PM) bradass?'f: >sigh<

(03:22:14 PM) info@adrianlamo.com: i get that

(03:22:45 bradassa7: get that connection?

(03:23:38 info@adriantamo.com: yeah.

(03:24:08 PM) info@adrianlamo.com: which is why i?m sad for the people i sometimes have to
hurt.

(03:24:10 PM) we?re and were killing and no?one seems to see
and it bothers me

(03:24:26 bradass87: apathy

(03:25:28 bradass87: apathy is far worse than the active participation

(03:26:23 PM) brada5587: >hug<

(03:29:31 PM) brada5587: http:iivimeo.coml5081720 Elie Wiesel summed it up pretty well for me-
though his story is much much more important that mine

(03:29:48 bradassB7: *than

(03:31:33 PM) bradassBT: I prefer a painful truth over any blissful fantasy.

Page 26 M48

(03:31:48 PM) bradassBT: slatthe

(03:32:05 PM) info@adrianlarno.ccm: *hugback?

(03:34:16 PM) bradassa?i':

(03:35:44 PM) brada5587: i think ive been traumatized too much by reality. to care about
consequences of shattering the fantasy

(03:36:18 bradass8?: im not brave, im weak

(03:39:00 PM) info@adrianlamo.com: sometimes they're the same thing

(03:40:33 PM) info@adrianlamo.com:

(03:40:43 bradass?i?:

(03:52:34 bradass?'i': like i think ive said im not so much scared of getting caught
and facing consequences at this as i am of bei_ng misunderstood. and never having the
chance to live the life i wanted

(03:52:34 PM) info@adrianlamo.com l'm not here right now

(03:53:38 PM) bradassBY: im way way way too easy to

(03:55:52 PM) bradassa'i': i dont like this person that people no-cne knows who i am inside
(04:24:21 info@adrianlamo.com: are you in the green zone? *random*

(04:26:02 PM) info@adrianlamo.com: i know all about having a persona vs. a real person
(04:26:06 info@adriantamc.com: <3

(04:28:46 yt?

(06:19:10 PM) bradassB? has signed off.

(01:3?:03 bra-dassfl??r has signed on.

(01:37:51 AM) bradassBT: no im at FOB hammer (re: green zone}; persona is killing the fuck
out of me at this

(01:3?:51 AM) info@adrianlamo.com I'm not here right now

(01:37:55 AM) Error setting up private conversation: Malformed message received

(01 :3?:55 We received an unreadable message from brada5587.

(01:37:58 AM) [resent] im at FOB hammer (re: green zone): persons
is killing the fuck out of me at this

(01 :38:07 AM) bradassB? has ended hisiher private conversation with you: you should do the same.
(01 :38:18 AM) Error setting up private conversation: Malformed message received

(01:38:20 The message received from bradassB? is unreadable, as you are not
currently communicating privately.

(01:38:30 AM) Error setting up private conversation: Malformed message received

(01:38:33 The message received from bradassai? is unreadable, as you are not
currently communicating privately.

(01:38:43 Error setting up private conversation; Malformed message received

(01:38:46 The message received from bradassB? is unreadable. as you are not
currently communicating privately.

(01:38:57 Error setting up private conversation: Malformed message received

(01:38:59 AM) The message received from bradassBT is unreadable. as you are not
currently communicating privately.

(01:39:10 AM) Error setting up private conversation: Malformed message received

Page 2? of 48

(01:39:13 AM) The message received from bradassB?? is Unreadable, as you are not
currently communicating privately.

{01:39:22 AM) Error setting up private conversation: Malformed message received

(01:39:25 AM) The message received from bradassB? is unreadable. as you are not
currently communicating privately.

[01:39:36 AM) Error setting up private conversation: Malformed message received

{01:39:39 AM) The message received from bradassB7 is unreadable. as you are not
currently communicating privately.

(01:39:49 AM) Error setting up private conversation: Malformed message received

(01:39:52 AM) The message received from bradassB? is unreadable, as you are not
currently communicating privately.

(01:40:02 AM) Error setting up private conversation: Malformed message received

(01:40:04 AM) The message received from bradassB? is unreadable. as you are not
currently communicating privately.

(01:40:15 Error setting up private conversation: Malformed message received

(01:40:18 AM) The message received from bradassBT is unreadable. as you are not
currently communicating privately.

(01:40:30 AM) Error setting up private conversation: Malforrned message received

[01:40:31 AM) The message received from bradassB? is unreadable. as you are not
currently communicating privately.

(01:40:41 AM) Error setting up private cenversation: Malformed message received

(01:40:45 AM) The message received from bradassS? is unreadable. as you are not
currently communicating privately.

(01:40:54 AM) Error setting up private conversation: Malformed message received

(01:40:57 AM) The message received from bradassB? is unreadable. as you are not
currently communicating privately.

[01:41:08 AM) Error setting up private conversation: lv'lalfonned message received

(01 :41 :10 AM) The message received from bradassa? is unreadable. as you are not
currently communicating privately.

[01:41:21 AM) Error setting up private conversation: Malformed message received

(01:41:23 AM) The message received from is unreadable. as you are not
currently communicating privately.

(01:41:37 AM) Error setting up private conversation: Malformed message received

(01:41:50 AM) Error setting up private conversation: Malformed message received

(01:41:52 AM) The message received from bradassB? is unreadable. as you are not
currently communicating privately.

{01:42:03 AM) Error setting up private conversation: Malformed message received

{01:42:05 AM) The message received from bradassB? is unreadable. as you are not
currently communicating privately.

{01:42:19 AM) Error setting up private conversation: Malformed message received

AM) The message received from bradassBi? is unreadable. as you are not
currently communicating privately.

[01:45:20 AM) Unveri?ed conversation with bradassB? started.

Page 28 of 48

(01:45:20 AM) bradassBT: [resent] otrfritzing

(01:45:40 AM) bradassB? has ended hisfher private conversation with you; you should do the same.
(01 :45:46 AM) The following message received from bradassB?? was not [ctr is bugging
out]

(01:45:54 AM) Unveri?ed conversation with bradassB? started.

(01:46:02 AM) bradassB7: no im at FOB hammer (re: green zone): persona is Killing the fuck
out of me at this

(01 :48:15 AM) bradassBT: [phew. seems to be working now]

(01:47:36 AM) info@adrianlamo.com:

(01:48:50 AM) bradass87: Manning's persistence led to the disruption of "Former Special
Groups? in the New Baghdad area. SPC Manning's tracking of targets led to the identification of
previously unknown enemy support zones. His anatysis led to heavy targeting of insurgent leaders in
the area that consistently disrupted their operations. SPC Manning?s dedication led to the
detainment of Malik Fadil al-Ugayli. a Tier 2 level target within the Commando

(01:49:17 AM) hradassBT: oh sent you that last night. nevermind

(01:49:59 AM) bradassB7: im hoping i can get a decent job through connections

(01:50:48 info@adrianlamo.com: what kind of work?

(01:50:59 AM) bradassBT: >shrug<

(01:51:11 AM) bradass?i': i'm good at so much

(01:51:34 AM) bradass?7: proving it is the ergo contacts

(01 :51:36 AM) bradassB7: im such a ghost

(01:53:36 AM) bradas587: graphics design, web development. intelligence analysis. mathematics.
economics. and both domestic and international politics

(01:53:43 AM) bradassBT: dont really have a specialty; can roam

(01 :54:47 AM) bradassB7: if it involves thought. rather than menial i can probably do it
(02:06:07 AM) bradassa7: im an east so i'll probably roam up and down from Boston to
DC for building connections

(02:07:34 AM) bradassBT: im writing my resume already

(02:10:58 AM) bradass?7: i need to buiid a portfolio

(02:11:17 AM) bradassa7: so i might freetance for a few weeks

(02:19:39 AM) bradassBT: assange offered me a position at wl. .. but im not interested right
too much excess baggage

(02:20:19 AM) bradassB7: its also a shoe-string cant make much of living doing that
(02:31:38 AM) bradassBT: i dont know what to call myself

(05:15:39 AM) bradassBT has signed off.

(07:21:07 AM) bradassB7 has signed on.

(07:31:09 AM) bradassB7: hello

(07:33:22 AM) info@adrianlamo.com: hey

(07:33:56 AM) info@adrianlamo.com: teil him i?ll do opsec for ?em

{07:34:03 AM) info@adrianlamo.com: is he gay?

(07:34:11 AM) into@adrianiarno.com: *random"

(07:34:18 AM) bradassS7: are you talking to the right person?

(07:34:23 AM) info@adrianlamo.com: yeah

Page 29 of 48

(0?:34:36 AM) white haired crazy dude?

(0?:34:38 AM) info@adrianlamo.com: continuing conyo where it dropped
(0?:34:43 AM) info@adrianlamo.com: yeah

AM) no..

(07:34:52 AM) bradassB'I: yery str8

(0?:35:47 AM) bradassBT: had a camera smuggled yia rectum he commented that he?s
"de?niter not gay"

(07:37:44 AM) Wadi-1558?: [lang story]

(03:01:09 AM) bradassEtT has become idle.

(08:05:33 AM) bradassS? has signed off.

(10:29:02 AM) bradassa'i? has signed on.

(10:29:02 AM) bradassB? is no longer idle.

Breanna Manning
gonna-haw-r-
4 I: .m w. i

The (Witter account of a "Breanne til-anoint in DC.



(10:33:53 AM) im already starting to give "Breanne" a digital twitten
youtube accounts set up in her name

(10:35:02 AM) bradassa'f: domain and server set up some time this going to design and
build an entire content management system from scratch

(10:35:43 AM) bradassB?: literally going backwards four years to start

(10:56:28 AM) bradassBY: this is such a

(11:02:24 AM) i need a lot more than a hug

(11:03:05 AM) bradassa7own, i but people are gonna see
my true colors either way

(05:35:45 PM) bradassa? has signed on.

(05:46:39 PM) info@adrianlamo.com: hey

(05:47:10 PM) info@adrianlamo.com: how?s stuff?

(01:20:55 AM) bradassBT has signed on.

(01:2?:30 AM) bradassSI': im alive

(01:27:40 AM) bradass?'l: and breathing

(01:28:10 AM) info@adrianlamo.com: good to hear

(01:28:27? info@adrianlamo.com: SITREP

(01:35:50 AM) bradassBT: 1 PAX up

(01:35:23 AM) bradassa'l: i had an hour session with my therapist

(01:35:40 AM) brada5587: i didnt say word for like 30 minutes

Page 30 of 48

(01:36:47 AM) ijust sat there. and he took notes

(01:37:18 AM) hradassa'r': im an awkward patient

(01:38:13 AM) bradassBT: its dif?cult to communicate with therapists

(01:38:27 AM) bradassBT: i try to explain something and they twist it around

(01:39:04 AM) bradassB?: and then they ask why i dont want to say anything

(01:39:43 AM) bradassBT: one of my friends is in the Democratic Primary for a South Dakota
Senate Angie we played Guitar Hero together

(01:40:15 AM) bradassB7: very very gay

(01:41:22 AM) bradassB7: State Senate that [not federal]

(01:42:05 AM) bradassBT:

(01:42:36 AM) info@adrianlarno.com: I gathered

(01:43:53 AM) bradassBT: same circle of friends as he's cute. but he's a so
we didn't work out [redacted]

(01:44:40 AM) bradassBY: slept with him a few times, but sex was

(01:44:50 AM) info@adrianlamo.com: howso?

(01 :45:04 AM) bradassa7: two

(01:45:40 AM) bradassBT: so. we?re friends

(01:46:43 AM) bradassai?: though. its been a and political friends can forget you exist in
three news cycles

(01:4?:19 AM) bradassa'i': kind of reinforces my cyniciSm

(01:4?:55 AM) bradass?'i': i still have a little spark of a dream call me

(01 :48:30 AM) bradassB?: but. i'd like to insert myself into politics) as a technical person with real
ideas?.

(01 :49:28 AM) bradassB7: too many words in political too short of an attention
too short of goals

(01:50:38 AM) bradassBT: humanity can accomplish so but its like herding cats
(01:50:57 AM) bradassa'f: getting the smart people with ideas to cooperate. that is

(01:51 :55 AM) bradassB?: im probany suffering from depression

(01:51:59 AM) bradass87:

(01:52:03 AM) bradassS?:

(01:52:06 AM) brada338?:

(01:52:15 AM) info@adrianlamo.com: Who isn?t

[01:52:20 AM) bradass$?: goddamn. i missed the key twice

(01:52:27? AM) info@adrianlamo.com: l'm supposedly bipolar.

(01:52:38 AM) bradassBT: oh well. still not medicated

(01:53:00 AM) bradassBT: i dont believe a third of the

(01:53:53 AM) bradassBT: so many Disorders that so many people fall it just seems like a
method to categorize a person. medicate them, and make money from prescription medications
(01:54:04 AM) info@adrianlamo.com:

(01:54:31 AM) bradassa'l: i?d like to meet a single person that wouldn't fall into a Disorder in the
DSM-IV-TR

(01:55:31 AM) bradassBT: [I'm random. too]

(02:01:12 AM) info@adrianlamo.corn: no such animal

Page 31 of 48

(02:02:25 bradassBT: indeed

(02:02:39 AM) bradassB7:

33203110 bradassBT: amazino how the world works

(02:03:27 takes 5 decrees of separation to a whole new level

(02:04:12 info@adrianlamo.com: hev. vacaville

(02:04:18 info@adrianlamo.com: at

(02:04:23 AM) info@adrianlamo.com: vacaville

[92:05:12 bradassBT: its almost bookworthv in itself, how this plaved

AM) brawls?58?: event occurs in 200?. i watch video in 2009 with no context. do research.
forward information to qroup of FOI research occurs, video is released in 2010. those
involved come forward to discuss event. i witness those involved cominq forward to discuss publiclv.
even add them as friends on without them knowino who i am

(02033? bradassah thev touch mv life, i touch their life. thev touch life full circle
[02:08:58 info@adrianlamo.com: Life?s funnv.

{02:09:24 infotaadrianlamocom: *random" are vou concerned about lookino into your
Wiki stuff? I was alwavs paranoid.

[02:09:40 AM) bradassB7: CID has no open investigation

{02:10:28 AM) bradass8?: State Department will be butt dont think thev're capable
of tracino

[02:10:44 what about Cl?

(02:10:51 bradass87: might be a concressional investigation. and a joint effort to ?oure out
what happened

[02:11:23 bradassBT: CI probava took note, but it had no effect on operations

{32:11:48 bradassBY: so. it was publiclv damagino. but didn?t increase attacks or
(02:12:10 AM) info@adriantm.com: *nod"'

[02:12:34 AM) bradassBT: re: ioint effort will be purelv political, ?fact "how can we stop
this from happenino aoain"

{02:12:46 bradassB?: reqardinq State Dept. cables

EJ213212 infotamanlamocom: Would the cables come from State?

[02:13:21 brads-5587: yes

(02:13:25 bradassS?: State Department

[92:13:29 AM) info@adrianlamo.com: was alwavs a commercial intruder.

(02:13:51 info?adrianlamocom: does voUr iob afford vou access?

{02:13:59 AMI info@adrianlamo.com: except for the UN.

[02:14:03 bradassBT: because i have a workstation

m2:14:15 AM) and World Bank.

?21411? AM) bradassaT: *had?

(92:14:36 A?info?adrianl?mo.com: So vou have these stored now?

[02:14:54 bradassB7: i had two one connected to SIPRNET the other to


(02:15:07? bradassBT: no. thev?re government laptops

(02:15:18 bradassB7: they've been zerofilled

[02:15:22 AM) bradassB?: because of the pullout





Page 32 of 4B

{02:15:57 bradassB'I: evidence was bv the svstem itself

{02:16:10 AM) info?gadrianlamocom: So how would vou deplov the cables? If at all.
{02:16:26 bmssat': oh cables are reports

{02:16:34 info@adriantamo.aom: ah

{02:16:38 bradassa7: State Department Cable a Memorandum

{02:16:48 AMLinfot?tadrianlamocom: embassy cables?

{03:16:54 bradassB?: ves

[02:17:00 bradass?7: 260.000 in all

[02:17:10 AM) bradass?i?: i mentioned this previously

{02:17:14 AM) info?adrianlamocomz ves

{02:17:31 info?adrianlamocom: stored locallv. or retreiveable?

{02:17:35 bradassB?: latrine

{02:1?:43 AM) bradassaT: i dont have a com: anvmore

{02:17:59 info?tadrianlamocom: *nod"

{02:18:09 AM) thev were stored on a centralized

{02:18:34 infot?jadrianlamocom: what?s vour endoame pla?. then?

{02:18:36 bradassB7: it was vulnerable as fuck

bradassBT: well. it was forwarded to WL

{02:21:13 bradassS?: and cod knows what happens now

{02:22:27 bradassST: hopefullv worldwide discussion, debates. and reforms
{02:23:06 bradassBY: if than were doomed

{02:23:18 AM) as a species

{02:24:13 AM) bradass?h i will of?ciallv give up on the societv we have if nothino happens
{02:24:58 AM) bra?dasth the reaction to the video pave me immense iReport was
Twitter

{02:25:18 Edass??i': people who saw. knewthere was something wronq
{02:26:10 medals-58?: Washinoton Post sat on the David Finkel acquired a copv while
embedded out here

@2636 AM) bradassBT: {also reason as to there's probava no investigation]
@2010 hradassB?: i want people to see the regardless of who thev because
without information. vou cannot make informed decisions as a public

[0_2:23:10 info@adrianlamo.com I?m not here rioht now
{02:28:50 AM) bradassBT: ifi knew then. what i knew kind of
[02:29:31 AM) bradassB?: or mavbe im iustxound, naive and

{02:30:09 AM) which do vou think it is?

{02:30:29 im hopino for the former

{02:30:53 bradassBT: it cant be the latter

{02:31:06 because if it were fuckino screwed

{02:31:12 bradassB7: {as a societvl

{02:31 :49 bradassB7: and i dont want to believe that we?re screwed

{02:32:53 food

{02:32:58 info@adrianlamo.com: kk

{02:33:00 AM) info@adrianlamo.com: and



Page 33 of 48

(02:33:03 AM) info@adrianlamo.com: fwiw
(02:33:10 AM) info@adrianlamo.com: me neither

(03:14:33 AM) bradassB7':
(03:14:32 AM) bradassB'i?:
(03:16:02 AM) bradass?T:
Wind: at 11 kmih
Humidity: 5%

>phew<
its hot as fuck


(03:16:44 AM) info@adrianlamo.com: wb

(03:16:55 AM) bradassBT:
(03:17:03 AM) bradassB?:

its raining there


(03:17:16 AM) info@adrianlamo.com: rain is nicce
(03:17:26 AM) info@adrianlamo.com: welcome neck

(03:17:36 AM) bradassB7:
(03:18:16 AM) bradass?i':
(03:18:38 AM) bradassa'i':
Current: Cloudy

Wind: 8 at 8 kmih
Humidity: 100%

(03:19:21 AM)
(03:19:45 AM) bradass87:
(03:19:58 AM) bradassBT:
(03:20:12 AM) bradassSi':
(03:20:41 AM) bradassBT:
(03:21 :01 AM) bradassB'i':
(03:22:22 AM) bradassST:
forms clay

(03:22:59 AM) bradassB'i':
(03:24:51 AM)
and shrubs

(03:25:18 AM) bradassB'r':
(03:26:00 AM) bradassB7:
(03:26:52 AM) bradassBi':
(03:22:14 AM) bradassBY:
(03:30:28 AM) bradassST:

nvm, just cloudy

nice i



here. its hot. and fucking hot

[double emphasis on hot]

its also rather dusty

i?d prefer the heat over the peanut butter that forms when it rains

i grow 3 inches in height when it rains here

its a desert. but the ground is fertile its a ?ne silt that

"Fertile Crescent"
vegetation is an odd mixture of deciduous and tropical trees

and usually keeled over from wind erosion

i dont think 99% of the people i work with would make such observations
humans brought a lot of gravel and pebbles in from turkish

so that KBR contractors dont get their feel too dirty when it rains

im still slowly trying to download that "leaked" documentary

(03:31:16 AM) info@adrianlamo.com:
(03:31:33 AM) info@adrianlamo.com: it was

(03:31:51 AM) bradassB'i':

satellite internet is not very falls in and out depending on

bandwidth ebbs and ?ows
(03:33:22 AM) info@adrianlamo.com: bro sleep

(03:33:30 AM)
hours
(03:33:38 AM) bradassB7:

then there?s the points when generators are switched over every 24-48

im going back to work

(03:33:56 AM) info@adrianlamo.com:

Page 34 of 48

(03:34:37 AM) info@adrianiamo.com:

(03:34:52 info@adrianlamo.com: er

(03:35:01 AM) info@adrianlamo.com: sleep

(04:06:46 AM) has signed off.

{06:22:53 AM) bradassS? has signed on.

{06:42:38 AM) has signed off.

(01:35:26 PM) bradassBT has signed on.

{01:33:27 PM) hrada358?: >yawn<

{01:38:43 info@adrianlamo.com: g?day ace

(01:39:09 PM) bradassBT: its iate,.. internet just came back up for me
(01:39:25 PM) *n0d*

{01:40:18 PM) bradassB?:

(01:40:44 PM) bradassB?: my ex is wearing my pink shirt at a damn "tea party" counterprotest


ash1ihs461 a1!25335_58945795969



[01:40:44 PM) info@adrianlamd.com:

Page 35 01?48

(01:40:56 PM) info@adrianlamo.com: that ierk!

(01:41:03 PM) bradassB7:

(01 :41:25 PM) bradassB?: oh well, its just #35

(01 :41:36 PM) bradass87: he hates i have proof he wore it

(01:42:28 PM) info@adrianlamo.com: are you seeing anyone in the .mil'?

{01 :42:40 PM) bradassB7: aw} no

(01:43:01 PM) bradassah i dated having two paranoid people doesn't work

(01:43:12 info@adrianlamo.com: my ex said was lousy with queers

(01:43:18 PM) bradassB'h i've had sex with .mil but overall its bad

(01:43:32 PM) Cl?

(01:43:13? PM) bradassST: why would Cl be involved

(01:43:45 info@adrianlamo.com: my ex was 9H3

(01:44:14 PM) bradassSY: i forget it was probably pretty bad in the past

(01:44:33 PM) bradassa'lz DADT isnt really enforced

(01:44:58 PM) bradassBY: top interrogator here has a civil union in NJ

(01 :45:18 PM) bradassB7: i punched a dyke in the

(01:45:22 PM) info@adrianlamo.com: tol

(01:45:43 PM) bradassa?: half the 82 shop was at least bi

(01:45:57 info@adrianlamo.com: you know this personalvlike?

(01:46:05 PM) it was all female

(01:46:10 PM) info@adrianlamo.com: ah

(01:46:46 bradassB7?: i got sick of these dykes and their it was worse than "The


(01:47:12 PM) bradass?'f: i even created a "chart"

(01:47:42 info@adrianlamo.com: physical or virtual?

(01 :48:07 PM) bradassBT: we never got a replacement Cl expert

(01:48:39 PM) bradassBT: on SIPR

(01:49:20 info@adrianlamo.com: shouldn't be a challenge for you to ex?ltrate a copy
(01:51:07 bradassB?: that was probably a primary Cl of?cer was an open position.
taken up by a lesbian interrogator who was more worried about the drama than the ex?ltration of
classi?ed information

(01:51:25 PM) bradassB?: dual plus she was only an

(01:52:30 PM) bradassBT: funnv thino we transffered so much data on unmarked
[01:52:42 PM) bradassa'x': evervone music

(01:53:05 braggeth all out in the open

(?:53:53 bradassBT: brinoino CDs too and from the networks waslis a common phenomeon
(01:54:14 PM) is that how you act the cables out?

(01:54:28 PM) medias.th perhaps

(01:54:42 bradassBT: i would come in with music on a CD-RW

(01:55:21 bradassBT: labelled with somethino like ?Ladv erase the then write
a compressed split ?le

(01:55:46 bradassa7: no-one suspected a thino

(01:55:48 bradassB7: kind of sad

Page 36 01?48

m:56:04 PM) info@adrianlamo.com: and odds are. thev never will

{01:56:07 bradassBT: i didnt even have to hide anvthino

{01:56:36 PM) info@adrianlamo.com: from a professional perspective. i'rn curious how the server
they were on was insecure

{01:5?:19 vou had people workino 14 hours a every single no
no

[01:5?:27 brada5387: people stopped carind after 3 weeks

{01:57:44 PM) i mean. technicallv speakind

{01:57:51 PM) info@adrianlarno.com: or was it phvsical

{01:57:52 bradassB?: >nod<

{01:58:16 bradassa7: there was no phvsical security

01:58:18 PM info adrianlamo.com: it was sical access wasn't it

{01:58:20 info@adrianlamo.com: hah

{01:53:33 brgdassai': it was there. but not reallv

{01:58:51 bradassBT: 5 diqit cipher but vou could knock and the

{01:58:55 bradassB7: 'on

{01:59:15 bradassBT: weapons. but evervone has weapons

{02:00:12 bradas587: evervone iust sat at their watchind music videos I car
chases buildinds and writing more stuff to the culture fed opportunities
{02:01:44 PM) hardest part is arouablv internet uploadind anv sensitive data
over the open internet is a bad since networks are monitored for anv
tvpes

info@adrianlamo.con1: tor?

{02:02:13 PM) bradassBT: tor

{02:02:33 PM) *nod"

{02:03:05 info@adrianlamo.comz not quite howi might do it. but good

{02:03:22 bra?ssa'r: i even asked the NSA ouv if he could ?nd anv susoicious activitv coming
out of local he shruoded and ?its not a priority?

{02:03:53 PM bradass?7: went back to watching "anle?s Eve"

{02:03:55 info@adrianlamo.com: oh. those NSA guys.

{02:04:05 info@adrianlamo.com:

(02:04:15 info@adrianlamo.com: probably thought it was plausible

(02:04:40 bradassB7: he had a lot of girl scout cookies

(02:05:03 info@adrianlamo.com: not a Threat Level fan.

(02:05:20 PM) bradassB?: don'tiudge. he actually kept up with that stuff

(02:05:33 PM) info@adrianlamo.com: clearlyI not enough

{02:05:39 PM) bradasth and we were in a SCIF. so he would and and talk
(02:05:58 PM) bradassai?: NSA how FISA i even asked a hypothetical
question of my and he was "if that did doubtful anyone would ?gure it all
out. .. resources are plus the mess"

{02:07:20 PM) bradassai': we tracked two american citizens "off-the-record"

{02:07:30 PM) info@adrianlamo.com: who. and why?

{02:07:59 bradassBT: two naturalized american





Page 37 of 48

(02:08:22 PM) blades.th one lived in texas for 1? years before moying back to and then

started constructed

(02:08:41 PM) only part of the name i remember is "Nai?m Mazan"
(02:08:58 PM) bradassBT: he was de?nitely crooked

(02:09:10 PM) bradassB7: neither were high pro?le

(02:11:16 PM) bradassBT: that product did thrown around a saw our report regurgitated by

NCIS
[02:11 :33 PM) bradass?h CID doesn't make fancy Cl products

(02:12:23 PM) bradassBT: it was a massive data facilitated by numerous

both physically. technically. and cutturally
{02:13:02 PM) bradass87: perfect example of how not to do INFOSEC

[02:14:21 PM) listened and lip-synced to Lady Gaoa?s Telephone while ex?ltratratino

possibly the laroest data spillaoe in american history

{02:15:03 pretty simple. and unolamorous

{02:16:37 bradassBT: *exfiltratino

[32:17:56 bradassB?: weak servers. weak loading. weak physicai security. weak counter.
intetlioence. inattentive sional a perfect storm

{02:19:03 brada558?: >sioh<

102:19:19 bradass?h sounds gram bad huh?

{02:20:06 info??drianlamoeom: kinda :x

(02:20:25 PM bradassB'I:

[02:20:52 PM) info@adrianlamo.com: i mean. for the .mll

[02:21:08 PM) bradass??: well. it SHOULD be better

[02:21:32 PM) bradass?'f: its sad

[02:22:47 PM) i mean what if i were someone more malicious

[02:23:25 PMijgradassa? i could?ye sold to russia or china. and made bank?

(02:23:36 info@adriantamo.ccm: why didn?t you?

(02:23:58 bradassB?: because it's_public data

[02:24:15 PM) info@adrianlamo.com: i mean, the cables

[02:24:46 PM) bradassB?: it belonqs in the public domain

[9_2:2_5:15 PM) Macias.th information should be free

(02:25:39 PM) bradasst37: it belonos in the public domain

{02:26:18 PM)
and get some edge
(02:26:55
(02:27:04 bradassB?:
[02:27:23 brgdass?h rather than some slimy intel collector

MQVIB bradassBY: im crazy like that

[02:29:18 info@adrianlamo.com I'm not here right now
[02:29:31 PM) info@adrianlamo.com: sorry, phone call

{02:30:03 bradassBT: nip

{02:35:42 trades.th "Net-Centric Diplomacyshould be a public
*do the

because another state would iust take edyantaqe of the



Page 38 of 43

(02:38:29 bradassB7: photos by the guy who
runs ?Net-Centric Diplomacy"

(02:41:23 PM) bradassBT: AKA


(02:41:23 PM) info@adrianlamo.com I?m not here right now

(02:44:06 PM) bradassB7:
tips.l

(02:44:07 PM) bradassB7: paragraph 2.

(02:46:25 PM) info@adrianlamo.com: ck: back

(02:46:42 PM) info@adrianlamo.com: two back-to-back calls

(02:47:06 PM) bradassBT: im so im ready for whoever you called

(02:47:56 PM) info@adrianlamo.com: haha

(02:48:32 info@adrianlamo.com: or was that serious paranoia?

(02:48:54 bradassBY: would i be communicating with you if i were that paranoid?

(02:49:36 PM) info@adrianlamo.com: hey, people are strange

(02:49:54 PM) bradassai': re: sent links. basically all published cables that aren't NODIS. or EXDIS
(02:50:44 PM) bradassBY:
originating post's or office?s Web site. (see 5 FAM 770 for policies regarding information on Federal
Web site and 5 H-443.1. When and How to Use

(02:51:58 PM) bradassa'r':

(02:52:03 PM) bradassB?: [reference]

(02:52:47 bradass?: state dept fucked placed volumes and volumes of information in
a single soot. with no security

(02:53:28 PM) info@adrianlamo.com: only the people you trust can fuck you infowise ;e
(02:54:03 bradassBT': so anything published, and classi?ed up to SECRETHNOFDRN
(02:54:44 PM) info@adrianlamo.com: in all seriousness, would you shoot if MP's showed up?
(02:55:04 PM) bradassB?: why would i need to?

{02:55:18 PM) info@adrianlamo.com: suicide by MP.

(02:55:34 bradassa?:

(02:55:39 bradassBT: do i seem unhinged?

(02:56:04 PM) info@adrianlamo.com: i mean. showed up for you if Julian were to slip up.
(02:56:46 PM) brada5587: he knows very little about me

(02:56:54 PM) bradassB7: he takes source protection uber?seriously

(02:51:01 PM) bradassa?: ?lie to me" he says

(02:5?z06 PM) info@adrianlamo.com: Really. Interesting.

(02:57:34 bradassBT: he wont work with you if you reveal too much about yourself

(02:58:13 info@adrianlamo.com: why talk to me?

(02:58:4? bradassB'r': because im isolated as my life is falling apart: and i dont have
anyone to talk to

(02:59:02 PM) info@adrianlamo.com: I'm flattered

(02:59:09 PM) info@adrianlamo.com: How is it falling apart?

(02:59:41 PM) bradass?i': family and possibility of transition in near
future

Page 39 of 48

(03:00:21 PM) its all happening so quick for its overwhelming

(03:00:35 info@adrianlamo.com: but you make a cute boy!

(03:00:53 bradassBT: im not comfortable with myself

(03:01:06 PM) bradass?i': im in an awkward state

(03:01:23 info@adrianlamo.com: i den't understand. buti understand the idea. if that makes
sense.

(03:01:39 bradass?i': and the weird part i love my iwas very good at iwish this
didnt have to happen like this

(03:01:48 info@adrianlamo.com: one of my ex?s is living as a girl in .au

(03:02:05 bradassBT: i dont understand it either

(03:04:05 PM) its clearly an i mean, idont think its normal for people to spend
this much time worrying about whether they?re behaving masculine enough. whether what they?re
going to say is going to be perceived as not to mention how i feel about the for
whatever reason. im not comfortable with i mean. i behave and look like a male. but its not
?me?

(03:04:34 PM) bradassBT: odd

(03:04:40 PM) bradassST: or at least painful

(03:05:31 PM) brada55871 8 months ago, if you'd have asked me whether i wanted i would identify
as female, i'd say you were crazy

(03:05:11 bradassB?: that started to slip very quickly, as the stresses continued and piled up
(03:06:48 PM) bradassBT: i had about three successively worse. each one revealing
more and more of my uncertainty and emotional insecurity

(03:02-05? PM) bradassB7: i spend a lot of time thinking of im now very
familiar with the and have a rough plan of how to get portions of it to work

(03:10:34 PM) info@adrianlamo.com: *nod?

(03:10:39 info@adrianlamo.com: *makes the bed"

(03:11:15 PM) bradassBT: have you heard similar?

(03:11 :22 PM) info@adrianlamo.com: yes

(03:12:25 PM) bradassB?: what did your ex say? if you dont mind me asking?

(03:14:15 PM) they felt uncomfortable in their own body. they hated their
genitals. they didn?t like looking manly

(03:14:49 bradassBT: im uncomfortable with my role in society in

(03:15:30 PM) bradassB7: im not so uncomfortable with my genitalia. i mean. it works for but i
dont like the masculine features in my appearance

(03:17:04 brada5587: iwent on leave in Iatejanuaiy it early i cross-dressed.
full wig. breastforms. dress. the i had crossdressed but i was for a
few days

(03:17:33 PM) bradassB?: i blended

(03:17:34 bradassa7: no?one knew

(03:18:06 PM) bradassBT: the ?rst thing i learned was that chivalry isn?t men would walk out
of their way and open doors for me. .. it was so weird

(03:18:19 PM) info@adrianlamo.com:

Page 40 of 43

(03:18:51 PM) bradassai?: i was referred to as ?Ma'am? or "Miss" at places like Starbucks and
McDonalds (hey. im not a fancy eater}

(03:19:35 PM) bradassBT: i even took the Acela from DC to whatever compelled me to do
but i wanted to see my then-still-boyfriend

(03:20:01 PM) i rode the train. dressed in a casual business out?t

(03:20:36 PM) bradassB7: i really enjoyed the minus the conductor

(03:21:06 PM) bradassBT: as he asked for my ID. and clipped my he made a fuss

(03:21 :24 PM) info@adrianlamo.com: that sucks =2

(03:21 :25 PM) brada5587: ?Thank you. MISTER

(03:21:31 PM) info@adrianlamo.com: asshole

(03:21:35 PM) info@adrianlamo.com: him. not you

(03:21:41 PM) bradass?i?: i know

(03:21:53 PM) bradassai': it an experience i wont

(03:22:36 PM) bradassS?: i 99.9% of people coming from irao and afghanrstan want to
come home. see their families. get drunk. get

(03:22:56 PM) bradassBT: wanted to try living as a woman. for whatever reason

(03:23:14 PM) obviously. its important to since there were plenty of other things i
couldive done

(03:23:23 PM) info@adrianlamo.com: Overall. how did you feel about your sojourn?

(03:25:50 PM) bradassBT: idk. ijust kind of blended i didn't have to make an effort to do so. it
just came instead of thinking all the time about how im perceived. being self conscious. i
just let myself iwas still self-concious. but in a different iwas worried about
whetheri looked pretty. whether my makeup was running. whetheri spilled coffee on my (expensive)
and to some extent whether i was

(03:28:12 PM) bradassBT: but i went to get and bought cigarettes (i know. need to
and the man asked about had a heart he couldn?t hold
himself back, he looked up and down and gave me this look WTF. it is the
handed it back to and tried to keep himself so i wasn?t worried about whetheri
was passing as much. because he had no idea whatsoever

(03:23:55 PM) info@adrianlamo.com: i smoze zero to ?ve a day myself.

(03:29:44 PM) bradass?'l: but the point was. i guess my face is androgynous enough thati can
pass with ease

(03:30:11 PM) bradassa'i': my prominent adams apple is the only issue i was concerned about
(03:30:26 PM) so i wore a turtleneck. and had collar up with my coat

(03:30:29 PM) info@adrianlamo.com: yeah. i'd say that re. the former.

(03:30:38 PM) info@adrianlamo.com: which i ?nd cute.

(03:32:29 PM) bradassBT: i dont think i'd need much work done for FFS. ifi soaked for it
(03:32:58 PM) bradassBT: *sought it

(03:33:01? PM) bradassBT: (my english is BAD today)

(03:34:25 PM) info@adrianlamo.com: hey. can you torrent from there

(03:34:45 PM) bradassBT: i?ve it eats too much bandwidth

(03:34:54 PM) info@adrianlamo.com: limit it

(03:35:00 PM) info@adrianlamo.com: with utorrent

Page 41 of 4B

[03:35:14 PM) bradass?'i': itsjust not working

[03:35:20 PM) info@aclrianlamo.com: shame

{03:35:23 PM) bradassBT: satellite cant handle

(03:36:05 bradassB7: one of the reasons its taking so long to see ?Hackers still
downloading portions

(03:36:14 PM) info@adrianlamo.com: *nod?

[03:38:07 PM) brads-558?: its not much of a picl but here's harry pontino
c39d25f27dlpd the man who's mission it is to sell
the bene?ts of NCD throughout the State Department Military. and IC

(03:38:18 PM) bradassa'h i feel terribly. terribly sorry for the quy

[03:39:17 bradass?i?: im not a bad person. i keep track of evemhing

[03:39:30 bradasSST: i watch the whole thino unfold. .. from a distance

[03:40:01' brew?assBT: i read what everyone look at keep and feel for
Hm

(03:40:10 since im basically playing a vital role in their life

[03:40:29 bradassB7: without ever meeting them

[03:40:53 bradassBT: i was like that as an intellioence analyst as well

{03:41:09 info?adrianlamo.com: i know the feeling, in a way.

{03:41:44 most didnt but i knew, i was playing a role in the lives of hundreds
of people. without them knowlno buti cared, and kt?Jl track of some of the details. make
sure everybody was okay

brada5587: them knowino me

(03:43:27 PM) idont think of myself as playino ?god? or anything. because im im
iust playing my role for the i dont control the way they react

{?:44:15 bradass??l: there are far more people who do what i doJ in state interest. on daily
basis. and dont dive a fuck

(03:45:01 bradassB7: thats how i try to separate myself

[03:45:13 PM) bradassBT: from my (former) colleagues

{03:45:31 info@adrianlamo.com: odds are. people feel the same way about you.

(03:46:16 PM) bradas58?: how do you mean?

(03:49:25 PM) info@adrianlamo.com: at higher or different levels. making decisions that affect
you.

(03:50:32 PM) predates-.87: in Ethan McCord?s for i watched the guy earlier this
year. alter i decided to release. carrying the girl and boy out of the and imagining hislher
reaction to seeing themselves on television. again and then he came out publicly and said
so on Australian television

{03:51 :08 PM) bradassa'f: how he saw himself on television that is

(03:51:36 bradassBT: coming home from dropping kids off school at

(03:51:48 PM) or picking them cant more liker picking up
(03:51:56 PM) bradassai': [afternoon it evening]

{03:52:10 yes, but im often aware of who?s making decisions that affect me
(03:52:13 PM) bradassBT: most aren?t

(03:52:28 PM) info@adrianlamo.com: who is?

Page 42 of 48

(03:52:49 PM) info@adrianlamo.com: making them. apart from immediate superiors.
(03:53:00 PM) bradass?h Commanders. Politicians. Journalists. the ltry to keep track
[03:53:25 PM) bradassait: i have sources in the White House re: DADT and the disaster that keeps
going on with that

(03:53:49 PM) info@adrianlamo.com: anyone i should know? i?m in DC a lot.

(03:53:52 PM) brada5587: not to mention HRC

(03:53:58 PM) info@adrianlamo.com: raised there.

(03:53:59 PM) Shin lnouye

(03:54:32 PM) info@adrianlamo.com: from grades 2-5

(03:54:51 PM) predates-.87: also. some Joint Staff a (bisexual) LTC at the Pentagon
(03:55:42 PM) bradassBT: only agency i cant get information out of at the highest levels is the
i've never needed a source there

(03:56:16 PM) info@adrianlamo.com: anyone I should talk to if you disappear one day?
(03:55:29 PM) brads-3537: good question

(03:57:10 PM) bradassB?: igave ex?bf a some use he is now

(03:5?:29 PM) info@adrianlamo.com: have more cred with the press

(03:5?:37 PM) bradassBT:

(03:53:05 PM) bradassa7: I?m a source for Chris Johnson of Washington ifeed with my
sub-sources

(03:59:03 PM) bradassB7: not to mention objective personal experience of and how its
actually working out ?on the ground"

(03:59:11 PM) info@adrianlamo.com: what about the sub-sources themselves? just out in the
cold?

(03:59:38 PM) brada5587: yes. they're politically tied

(04:00:50 PM) bradassaT: so. they wouldn't be in the cold. per se

(04:00:51? PM) bradassST: out i would disavow them

(04:00:58 PM) info@adrianlamo.com: everything else. but you don't trust me with that? heh.
(04:01:19 PM) bradassBT: these are good people. who just happen to be gay

(04:01:29 PM) bradassail: it would be wrong of me to con?rm i' deny

(04:01:45 PM) bradass?i': check queertycom (mostly accurate)

(04:01:50 PM) bradassB7: 7P

(04:01:52 PM) info@adrianlamo.com: fair enough

(04:02:15 PM) bradassaT: ask them. not i say

(04:02:48 PM) bradassai': (i keep my promises to my friends. believe it or not)

(04:03:15 info@adrianlamo.com: can respect that.

(04:03:21 PM) info@adrianlamo.com: And do.

(04:04:10 PM) bradassa'i': Just hang around the right bars at the right times in Dupont and
you can meet them yourself. you wouldn?t need me

(04:04:26 PM) info@adrianlamo.com: have. Hung out there

(04:04:42 PM) info@adrianlamo.com: Any bars in particular?

(04:04:52 PM) bradassaT: they keep freakinl changing

(04:05:14 PM) info@adrianlarno.com: heh

Page 43 of 48

(04:05:16 PM) bradassB'i': changing names and its been a different scene every time i
go back to

(04:05:38 PM) bradassBY: and im only gone 4-6 months each time

(04:06:22 PM) i usually give [redacted] a call ifi need to know whats hot in town
(04:07:47 PM) oracles.th here?s some public advice:


(04:08:08 bradassa7: [Tweet redacted]

(04:09:11 bradass?h iwas [redactedfs ?rst boyfriend after [redacted]

(04:09:28 PM) bradass?i': i encouraged him to seek out relationships again"

(04:09:31 PM) bradassS?:

(04:10:04 PM) bradass?i': now has engaged to his fiancee {redacted}

(04:10:32 PM) bradassET: (im a pretty connected guy for a ghost. i guess)

(04:12:01 info@adrianlamo.com:

(04:13:27 bradassBT: i guess in a way. im just getting started

(04:13:43 PM) bradassBT: i im not even 23 ye

(04:13:48 PM) bradassBT: *yet

(04:19:02 PM) info@adrianlamo.com: this is true

(04:22:03 PM) bradassa'l: i keep my DADT trail semi-secure

(04:22:11 PM) info@adrianlamo.com: howso?

(04:22:1? PM) bradassBT: i ?gure its plausible deniabilitv

(04:22:43 PM) bradassB'I: for the more extreme stuff

(04:22:56 info@adrianlamo.com: howso?

(04:23:13 PM) bradassS?: well. if investigated, it provides a huge number of red herrings
(04:23:57 PM) bradassa7: politically it would be a small domestic scandal
(04:25:33 bradassa'r': one of my contacts is the Special Forces of?cer who was involved in the
(awful) interrogation of John Walker Lindh

(04:26:02 PM) bradass?'? he witnessed the death of his CIA colleagues

(04:26:23 bradassBT: he?s a and he?s gay

(04:27:34 *capture and interrogation of

(04:28:13 PM) bradassB7: i know. its all very complicated and dif?cult to believe. which is good for
me

(04:28:56 PM) bradassBT: but. i hope i can live a less ambiguous life as i transition
(04:29:30 PM) info@adrianlamo.com: wish you a less ambiguous life as well.

{04:29:41 PM) bradasstit thank you

(04:29:57 bradass?h i sincerer believe i deserve one

(04:31 :26 PM) bradassBT:

{04:32:05 bradassBT: oh. the JTF GTMO Assanoe has those too

{04:32:16 info?adrianlamosom: Read it.

(04:33:21 info@adrianlamo.com: Anvthinq else interesting on his table. as a former collector
of interestino .com info?

[04:33:44 PM) bradass?'i': i onlv know what i provide him xD

(04:34:14 PM) info@gdrianlamo.com: what do vou consider the highlights?

Page 44 of 43

(04:35:31 PM) bradassBT: The Gharani airstrike videos and full report. lragwar event loo. the
?Gitmc Papers". and State Department cable database

@3550 PM) info@adrianlamo.com: Not too shabbv.

(04:36:03 PM) bradass?h thats lust

(04:36:25 PM) bradassBT: idk about the he *hopefullv* has more

(04:36:38 PM) info@adrianlamo.com: he does.

(04:36:52 PM) info@adrianlamo.com: i tested him once.

(04:37:03 PM) info@adrianlamo.com: i denated once upon a time

PM) info@adrianlamo.com: the donor e-mail soiicitation was
(04:37:19 PM) bradassB7: and leaked the list of donars

(04:37:23 PM) info@adrianlamo.com: not

(04:3?:28 PM) info@adrianlamo.com: yeah.

(04:3?:31 PM) bradassBT: ?donor

(04:37:44 PM) info@adrianlamo.com: he ran it anyway.

(04:3?:51 PM) bradass?? >nod<

(04:31:51 info@adrianlamo.com: that's integrity.

(04:38:14 PM) bradassa'r': welt. afaik. he made an attempt to contact as many of those on the list as
possible

(04:38:20 PM) bradassa7: i dont know if thats true

(04:38:30 PM) info@adrianlamo.com: didn't contact me

(04:39:29 PM) bradassBT: icelandic reporters from RUV travelled to baghdad and found the two
kids. and the reuters staff famiiy

(04:39:38 PM) bradass87: as a WL ?away team"

(04:40:25 PM) bradassa7: ijust finished downloading HW

PM) bradass?i': im not Sure whether i?d be considered a type of "hacker". ?cracker?.
?hacktivist?. "leaker" or

(04:42:26 PM) bradassBT: im lust reallv

(04:44:21 PMMadassBY: starts off like everv phvsics r' astro class ever
(04:44:21 PM) info@adrianlamo.com I'm not here right now
[04:44:45 PM) bradassBT: albeit without the algebraic proofs

[04:45:20 PM) info@adrianlamo.com: or a

(04:45:48 PM) bradassBT: i couldn't be a

(04:45:59 PM) bradassSY: spies dont post thinds up for the world to see

04:46:14 PM info adrianlamo.com: Wh Wikileaks would be the erfect cover
[04:46:23 PM) info@adrianlamo.com: Thev post what?s not useful

(04:46:29 PM) infot?tgdrianlamocom: And keep the rest

(04:46:36 PM) info@adrianlamo.com: *devil's advocate"

(04:46:55 PM) bradassBT: too much Wayne Madsen for

(04:4?142 PM) info@adrianlamo.com:

(04:48:10 PM) info@adrianlamo.com: i didn't know who he was until just now
(04:55:35 PM) bradassBT: im "pink hat"

(05:13:21 PM) oh. btw. .. china has a massive botnet

(05:13:21 PM) info@adrianlamo.com I'm not here right now



Page 45 of 4B

(05:13:31 bradassB?: 45+ million. grows 100.000 every two weeks

(05:14:44 bradassBT: it pings eucom and pacom servers every two weeks at the same
spread out to prevent the bandwidth from being detected (it was identi?ed at 20 million in late
2008)

(05:14:54 PM) bradassB?: *2003}

(05:15:53 PM) bradassa'I: 45+ million ip i ?gure they must have a pro-installed system
on consumer electronics

(05:20:00 bradassBT: are you familiar with the Byzantine problem sets?

(05:22:15 info@adrianlamo.com: nope

(05:23:10 PM) bradassa'lz Byzantine is the code word for all the chinese in?ltration problem
the ones that get .mil info. as well as penetrate google (like what became public earlier this year)
(05:23:16 PM) bradassBT?: yahoo. etc

(05:23:23 PM) bradassBY: mostly .gov and .mil

(05:23:46 bradassBT: there are several sub-problem sets.._

(05:24:15 bradassBT: Byzantine Candor. for instance

(05:24:51 PM) bradassS'I: its what 95% of information warfare people work on in

(05:25:15 bradassa'l': china can knock out any network in the world with a 0005

(05:25:20 bradassB7:

(05:36:07? their gateways throughout the world are clearly identified, and are being
tracked carefully

(05:35:07 PM) info@adrianlamo.com I?m not here right now

(05:46:21 PM) info@adrianlarno.com: interesting

(05:4?:21 info@adrianlamo.com: yet i can compromise foreign networks because they speak
machine and use English-friendly products.

PM) bradassB?: yeah. china uses a lot of poor spear ?shing

(05:43:31? PM) bradassai": they dont get much. since they cant penetrate the

(05:48:59 PM) info@adrianlamo.com: Do you know of any ops in Colombia other than anti?narco
ones?

(05:50:11 PM) bradassB?: not i know of state department initiatives to improve relations
with mostly because of our poor history and because we?re still tracking FARC
(05:50:30 PM) info@adrianlamo.corn: Venezuela?

(05:50:45 PM) bradassBT: borders watched closeiy

(05:51 :12 PM) info@adrianlamo.com: But nothing speci?c?

(05:51:24 bradassBT: smuggling, for some reason a lot of DC politicos don't like
Chavez

(05:51:41 PM) info@adrianlamo.com: imagine that.

(05:51:53 PM) bradassBT: i dont give speci?cs unless i have them in front of me, sorry

(05:52:09 PM) info@adrianlamo.com: why?

(05:52:24 PM) brada5587: because my memory sucks sometimes

(05:52:52 info@adrianlamo.com: You?re a leftist. I take it. Not a bad thing. My dad has a book
signed by Philip Agee.

(05:53:09 PM) bradassBT: i dont have a doctrine

(05:53:40 PM) bradass?h socialism (capitalism are the same thing in practice

Page 46 of 4B

(05:53:57 PM) info@adrianlamo.com: Everyone does. Our beliefs place us somewhere. even if it's
?centrist?

(05:54:15 PM) bradassBT: i knowi do. but i havent quite de?ned it

(05:54:17 PM) info@adrianlamo.corn: except apathetic

(05:54:42 PM) bradassB'I: apathy is its own 3rd i have special graph for
(05:54:56 PM) info@adrianlamo.com: I?m a fan of of realpolitik myself.

(05:55:10 PM) bradass?T: i dont quite know

(05:55:34 PM) bradassBT: seen too much reality to be "polar"

(05:56:02 PM) bradassB7: idont like dogma. thats one thing i can say without doubt. .
(05:56:13 PM) info@adrianlamo.com: Reality how you say. is what you can getaway with.
(06:00:36 PM) bradassBT: ive seen detailed imagery of columbia

(06:01:00 PM) bradassBT: as well as tehran haiti's reconstruction

(06:01:24 PM) bradassST: even the reykjavik embassy

(06:01:24 PM) info@adrianlamo-oom l'm not here right now

(06:01:51 PM) info@adrianlamo.com: Colombia with an 0. Pet peeve.

(06:02:08 PM) bradasst37: my bad

(06:02:15 PM) bradass?i': im a DC guy. it slipped

(06:02:27 PM) info@adrianlamo.com: They have McDonald's in Tehran yet?

(06:02:41 PM) bradassB7: no. but i was awestruck

(06:03:09 PM) info@adrianlamo.com: not familiar

(06:03:26 PM) bradass87: public transit systems. highways systems. its a very advanced way
far ahead of its like 19805 japan

(06:04:17 PM) bradass?7: still behind that curve. but remarkably

(06:04:47 PM) bradassBT: definitely a comparasion to japan, with the mountains and the buildings
placed on top of buildings to save room

(06:05:05 PM) bradassa7: its no joke of a city

(06:08:53 PM) info@adrianlamo.com: What?s your greatest fear?

(06:09:24 bradassBT: dying without ever truly living

(06:10:16 PM) bradassBT: cliche. but honest

(06:10:33 PM) info@adrianlamo.com: i keep forgetting you?re 22

(06:11:50 PM) info@adrianlamo.com: i had my ?rst (really! (more?n six months) at 22
(06:12:13 PM) info@adrianlamo.com: They went on the run from the FBI fw me

(06:12:30 PM) info@adrianlamo.com: that?s loverl

(06:12:46 PM) info@adrianlamo.com: Crazy as a shithouse rat. tho.

(06:16:09 PM) bradassST: Iol

(06:16:21 bradassST: i dont know if i can meet people who love me

(06:16:37 PM) bradassBT: no-one ever sticks around long enough to know me

(06:16:45 PM) bradassB7: those who do. become good

(06:16:51 PM) bradassBT: but thats not the same

(06:17:18 PM) bradassBT: ijust ended my ?rst

(06:17:30 PM) bradassBT: so im probably still depressed

(06:17:45 PM) bradasst37: (i dont know my own emotions that well)

(06:17:58 bradassST: [repression is a bitch]

Page 47 of 48

(06:19:08 PM) bradassB?l?: i often get to know people intimately well
(06:19:14 PM) bradass?h but it doesn't re?ect

(06:24:29 PM) bradass?'l': ive seen far more than a 22 We should
{06:25:00 PM) info@adrianlamo.com: so had 1 =2

Page 48 of 48

IN THE UNITED STATES COURT OF APPEALS
FOR THE ARMED FORCES


JULIAN ASSANGE and WIKILEAKS, WRITPAPPEAL PETITION FOR
REVIEW OF ARMY COURT OF
Petitioners, CRIMINAL APPEALS DECISION
ON APPLICATION FOR
v. EXTRAORDINARY RELIEF
UNITED STATES OF AMERICA and Army Crim. App. Misc. Dkt.
LIEUTENANT COLONEL PAUL ALMANZA, No. 20111146
Respondents.
i A
Preamble

Petitioners Julian Assange and Wikileaks, by and through
their undersigned counsel, respectfully submit this Writ-Appeal
Petition. Petitioners request an order reversing the decision
of the U.S. Army Court of Criminal Appeals, dated December 16,
2011, denying their request for extraordinary relief. See Exh.
A.l Reversal is necessary to assure meaningful access to the
Article 32 proceedings against Mr. Bradley Manning to the legal
representatives of Petitioners, whose interests are seriously

implicated by the conduct and content of these proceedings.



1 Petitioners? counsel were admitted pro hac vice by the U.S.
Army Court of Criminal Appeals for purpose of litigating the
Petition. To the extent required, they separately request
permission to appear pro hac vice before this Court for the same
purpose. Good cause exists to grant this request given the
emergency nature of the relief requested and the serious nature
of the issues at stake in this case. Counsel are members in
good standing of the bar in New York State, and are admitted to
practice in numerous federal courts.

1N9. DFBR. EXHIBIT 92?

History of the Case

On the evening of December 15, 2011, Petitioners filed a
petition for extraordinary relief before the U.S. Army Court of
Criminal Appeals, seeking guaranteed access to the Article 32
hearing in United States v. Bradley Manning, which commenced on
December 16, 2011, at Ft. Meade, Maryland. Alternatively,
Petitioners requested a stay of the proceedings in order to seek
any further judicial relief that might be necessary. Although
counsel for Petitioners were afforded access to the hearing room
on the first day of the proceedings, their request for
guaranteed access to the remainder of the proceedings, including
any closed sessions involving classified information, was denied
by the Investigating Officer without hearing oral argument from
Petitioners' counsel. Thus, in light of severely limited access
to the live hearing room, Petitionersr counsel have no assurance
that they will be able to continue to observe the proceedings
and protect Petitioners' substantial interests.

Relief Sought

1. Petitioners request an order reversing the decision of
the U.S. Army Court of Criminal Appeals summarily denying their
petition for extraordinary relief.

2. Petitioners request a writ of mandamus to compel the
Investigating Officer assigned to preside over the Article 32

hearing in this case to provide and guaranty access for counsel



for Petitioners to the proceedings in their entirety for his
noanS and US counsel, as well as any closed, classified
sessions for his nominated U.S. counsel who maintains Top
Secrethensitive Compartmentalized Information security
clearance.

Reasons for Granting the writs

Petitioners respectfully refer the Court to their Petition
for Extraordinary Relief submitted to the U.S. Army Court of
Criminal Appeals. Because the proceedings in united States v.
Bradley Manning are currently underway, and because of the
serious nature of the issues at stake in that case for
Private Manning and for Petitioners this application involves
extraordinary circumstances warranting the Court's immediate
review. Thus, in the interest of time and in order to obtain
expeditious relief, Petitioners stand on their prior submission
to the U.S. Army Court of Criminal Appeals. See Exh. B.

In addition, Petitioners contend that the Court's decision
denying their petition was legally erroneous and an abuse of
discretion because it failed to offer any factual or legal
explanation or justification for the ruling. The court also
apparently failed to apply established legal precedent ensuring
the public right of access to judicial proceedings,
including Article 32 proceedings, or to consider Petitioners'

obvious, unique interests in observing the Manning proceedings

first?hand in their entirety. Indeed, the court apparently
failed to recognize the potentially serious ramifications of
denying Petitioners' counsel guaranteed access to the
proceedings, not only in connection with the Manning case but
also in connection with any threatened criminal prosecution of
Mr. Assange in the Eastern District of Virginia, as well as any
future request to extradite him to the United States.

In light of the extant criminal investigation of Mr.
Assange, Mr. Assange and Wikileaks have a manifest and
compelling interest in having their counsel attend Private
Manning's proceedings. This interest was highlighted during the
very course of proceedings on December 16, 2011. Mr. Coomhs,
counsel for Private Manning, reiterated in argument the very
serious nature of the allegations against Private Manning
alleged to be a WikiLeaks source - emphasizing that the charge
of ?aiding the enemy? carries the death penalty. Mr. Coombs
made specific representations about the potential for pressure
upon Private Manning to accept a plea bargain in order to
implicate Mr. Assange and WikiLeaks in the ongoing Department of
Justice criminal investigation. In addition, Mr. Coombs sought
recusal of the Article 32 Investigating Officer specifically

because of that Officer's employment with the Department of

Justice.2 This further underscores the interconnectedness of
this Article 32 proceeding and jeopardy to Mr. Assange's
interests.

Further, by their very nature, Article 32 proceedings do
not result in verbatim transcripts of proceedings that are
accessible to the public or to parties with a serious interest
in the case, which serves to amplify the injustice of the Army
Court of Criminal Appeals? decision to refuse to grant
WikiLeaks' legal representatives guaranteed access to the
hearing. it is also our understanding that the relevant
authorities will not provide WikiLeaks' representatives access
to verbatim transcripts, despite our obvious interests in the
proceedings. Without guaranteed access to attend the
proceedings (in both opened and classified sessions of the
proceedings), they are unable to assess the evidence presented
against WikiLeaks? alleged source or against WikiLeaks itself
and Mr. Assange.

Finally, the 0.8. legal representative of Wikileaks? and
Mr. Assange, Amanda Jacobsen, maintains Top Secret/Sensitive

Compartmentalized Information security clearance.





It would appear that the Investigating Officer has a
conflict of interest, insofar as decisions he would make in
favor of Mr. Manning {or protective of Wikileaks? interests} and
contrary to the interests of the United States, may affect his
employment status, prospects or reputation with the Department
of Justice.

Under relevant military guidelines, and based on the foregoing,
Ms. Jacobson will plainly have a ?need to know" information
arising from these proceedings that implicate our clients?
interests. Accordingly, she should have the opportunity to
address the Tribunal on her ?need to know" information in
situations in which the Tribunal seeks to close proceedings to

the public.

Conclusion
For these reasons, and the reasons set forth below in the
Petition below, the Writ-Appeal Petition should be granted.

Date: New York, New York
December 17, 20ll

Respectfully submitted,

Eaher Azmy

Vincent Warren, Executive Director
Baher Army, Legal Director
Michael Ratner, President Emeritus
CENTER FOR CONSTITUTIONAL RIGHTS
666 Broadway, 7th Floor

New York, New York 10012

Tel: [212) 614*6464

Fax: (212) 614?6499

Counsel for Julian Assange
and Wikileaks

Certificate of Service
I hereby certify on this 17th day of December 2011,r I
caused the foregoing Writ-Appeal Petition to be filed with the
Court electronically, and served on Respondents, via overnight

mail, at the following address:
Lt. Col. Paul Almanza
U.S. Army Reserve Judge

150th Legal Support Organization
Ft. Meade, MD 20755

Eaher Azmy



Exhibit A

UNITED STATES ARMY COURT OF CRIMINAL APPEALS

Before
SIMS. COOK, and GALLAGHER
Appellate Military Judges

JULIAN ASSANGE and WIKILEAKS,
Petitioners
v.
THE UNITED STATES OF AMERICA and
Lieutenant Colonel PAUL ALMANZA
Respondents

ARMY MISC 20111146

. . The Petitioners? request to appear pro hac vice for the limited purpose of
litigating their petition is GRANTED. On consideration ofthe Petition for
Extraordinary Relief in the Nature of Writs of Mandamus and Prohibition, the
petition is DENIED. Petitioners? request to stay proceedings in the court-martial of
Slater Manning is DENIED.

DATE: 16 December 2011
FOR THE COURT:



MALCOLM H.
Clerk of Court



UIRES, JR.

CF: JALS-DA
JALS-GA
ALS-TJ
A LS-C R4
Petitioner
Respondent

Exhibit

IN THE UNITED STATES ARMY
COURT OF CRIMINAL APPEALS


JULIAN ASSANGE and WIKILEAKS,

Petitioners, Docket No. ARMY

v. Article 32 Hearing in
. United States V. Manning.
UNITED STATES OF AMERICA and Ft. Meade, Maryland
LIEUTENANT COLONEL PAUL ALMANZA,
DATED: 15 December 2011

Respondents.



PETITION FOR EXTRAORDINARI RELIEF IN THE NATURE OF WRITE
OF HANDAMUS AND PROHIBITION, 0R, ALTERNATIVELY, APPLICATION

FOR STAY OF AND SUPPORTING MEMORANUM OF LAW

Petitioners Julian Assange and Wikileaks, by and through
their undersigned counsel, respectfully submit this request for
extraordinary relief, pursuant to the All Writs Act, 28 U.S.C.
1651(a), Rules 2(b) and 20 of the Courts of Criminal Appeals
Rules of Practice and Procedure, and Rules 20.1 and 20.2 of the
U.S. Army Court of Criminal Appeals Rules.

Statement of the Case and Issues Presented

On November 28, 2010, the Wikileaks media organization and
its publisher Julian Assange commenced reporting on thousands of
allegedly classified and unclassified U.S. State Department
diplomatic cables. The cables were also published by other
national and international media organizations, including The

New York Times, The Guardian, Der Spiegel, Le Mbnde, and El

Pais. To our knowledge, the U.S. government has never
officially confirmed or denied whether any of the cables are
indeed classified. However, the government has targeted and
threatened Mr. Assange, Wikileaks, and their supporters,
employees and contractors around the world with criminal
prosecution arising from their journalistic activities.

Although the U.S. government has never successfully
prosecuted anyone accused of soliciting or receiving allegedly
classified information, federal prosecutors have reportedly
convened a grand jury in the Eastern District of Virginia to
investigate whether Mr. Assange conspired with Army Private
Bradley Manning to violate the Espionage Act of 1917, 18 U.S.C.
793 et seq., and other federal laws. The grand jury
investigation conducted entirely in secret, without any
involvement permitted by defense counsel, and in a district with
the highest concentration of military and government jurors in
the United States so far has included the issuance of
subpoenas that reportedly name Mr. Assange, Wikileaks and
Private Manning. These production orders have been served in
relation to Wikileaks? supporters on media companies such as
Google and Twitter.

In addition, and of paramount importance herer Private
Manning was arrested in May 2010 in Iraq on suspicion that he

provided the diplomatic cables (and possibly other allegedly

(NJ

classified information) to Mr. Assange and/or Wikileaks.
Private Manning now faces the possibility of court?martial for
offenses including aiding the enemy in violation of Article 104
of the Uniform Code of Military Justice. These offenses are
serious but wholly unproven. There is strong evidence that
Private Manning has nonetheless suffered serious human rights
violations as a result of these unproven claims, including
prolonged isolation and sensory deprivation, and other torture
or cruel, inhuman and degrading treatment reminiscent of the
worst abuses at Guantanamo Bay. The U.S. government has notably
refused to allow the United Nations Special Rapporteur for
Torture to adequately assess Private Manning?s treatment and
conditions.

It is in this context that Private Manning's Article 32
hearing is scheduled to commence at Ft. Meade, Maryland, on
Friday, December 16, 2011. Notwithstanding the intense public
interest in this case, and Fetitioners' obvious, unique interest
in these proceedings, as described below the limited procedures
established to allow public access to the proceedings are
plainly insufficient to ensure that Mr. Assange and Wikileaks,
by and through their counsel, are able fully and adequately to
observe the proceedings and safeguard their rights and
interests, as well as Private Manning's legal and humanitarian

rights and the right of the public access to the proceedings.

Indeed, Respondents have failed and refused to guaranty access
to Petitioners? counsel despite repeated communications and
requests via telephone, email and letter to the U.S. Army
District of Washington Public Affairs Office and officials at
Ft. Meade. See, Attachment (letter requesting access).

Accordingly, the failure and refusal to respond to
Petitioners? request for guaranteed access to the Article 32
hearing in this case, and the lack of adequate capacity
otherwise to accommodate the media and other interested parties
such as Mr. Assange and Wikileaks, constitutes a constructive,
blanket denial of public access to the proceedings. Petitioners
thus request that the Court grant relief as follows.

Specific Relief SougEE

l. Petitioners request a writ of mandamus to compel the
Investigating Officer assigned to preside over the Article 32
hearing in this case to provide and guaranty access for counsel
for Petitioners to the proceedings in their entirety.

2. Petitioners request a writ of prohibition to reverse
and undo the current procedures affording limited access to the
Article 32 hearing, which constitute a constructive, blanket
denial of the right of public access to the proceedings.

3. Alternatively, Petitioners request an order staying
the Article 32 hearing in order to allow the Court to consider

this Petition, and to allow Petitioners to seek any further

judicial relief which may be necessary to protect Petitioners?
rights and interests in these proceedings.
Reasons for Granting the Writs

The Court should grant the requested relief, pursuant to
the All Writs Act, 28 U.S.C. 1651(ai, to open the proceedings
and ensure access for the public generally and for Mr. Assange
and Wikileaks specifically. Relief should be granted because
this matter involves exceptional circumstances warranting the
Court's intervention at this time, relief has been requested but
cannot be obtained in any other form or in any other court, and
issuance of the writs will aid the Court's jurisdiction.
Respondents? decision effectively to close the proceedings and
deny access to Petitioners, particularly given their unique
interest, is clearly erroneous and amounts to usurpation of
authority.

A. Right of Public Access

The Court?s authority to act on the merits of this Petition
and grant relief is clear and indisputable. See Denver Post Co.
v. United States, Army Misc. 20041215 2005), available
at 2005 CCA LEXIS 550 (exercising jurisdiction and granting writ
of mandamus to allow public access to Article 32 proceedings).
Equally established and uncontroversial is the right of public
access to judicial proceedings, including Article 32 hearings,

which may be overcome only on a ?case?by?case, witness-by?

witness, and circumstance-by?circumstance basis." ABC, Inc. v.
Powell, 47 M.J. 363, 365 (C.A.A.F. 1997}, available at 1997 CARP
LEXIS 74. The right of public access is rooted in the common
law and the First Amendment to the United States Constitution.
See, Nixon v. warner Commc'ns, Inc., 435 U.S. 589, 597
(1978); In re Washington Post Co., 807 F.2d 383, 390 (4th Cir.
1986}; washington Post Co. V. Robinson, 935 F.2d 282, 287 (D.C.
Cir. 1991).

The right of public aCCess exists to ensure that courts
have a "measure of accountability? and to promote ?confidence in
the administration of justice." United States v. Amodeo, 71
F.3d 1044, 1043 {2d Cir. 1995). Access to information is
especially important when it concerns matters relating to
national defense and foreign relations, where public scrutiny is
the only effective restraint on government. See New York Times
v. United States, 403 U.S. 713, 728 {1971) (Stewart, J.,
concurring} ("In the absence of the governmental checks and
balances present in other areas of our national life, the only
effective restraint upon executive policy and power in the areas
of national defense and international affairs may lie in an
enlightened citizenry in an informed and critical public
opinion which alone can here protect the values of democratic



The Supreme Court has repeatedly stated that openness has a
positive effect on the truth~determining function of
proceedings. See Gannett Co. v. DePasguale, 443 U.S. 368, 383
(1979} (?Openness in court proceedings may improve the quality
of testimony, induce unknown witnesses to come forward with
relevant testimony, cause all trial participants to perform
their duties more conscientiously"); Richmond Newspapers, Inc.
v. Virginia, 448 U.S. 555, 596 (1980) (open trials promote ?true
and accurate fact?finding") (Brennan, J., concurring); Globe
Newspaper Co. v. Superior Court, 457 0.8. 596, 606 (l982)
(?EPJublic scrutiny enhances the quality and safeguards the
integrity of the factfinding see also Brown
Williamson Tobacco Corp. v. FTC, 710 F.2d 1165, 1179 (6th Cir.
1983) (Gannett's beneficial ?fact?finding considerations"
militate in favor of openness "regardless of the type of
proceeding?). This effect is tangible, not speculative: the
Court has held that openness can affect outcome. Accordingly,
if the government attempts to restrict or deny the right of
access, it bears the burden of by showing that the limitation is
necessary to protect a compelling government interest and is
narrowly tailored to serve that interest. See, Robinson,
935 F.2d at 287.

In contravention of these authorities, Petitioners are

informed and believe that Respondents in this case have set

aside only about eight seats in the Article 32 hearing room, for
members of the media selected by the U.S. Army District of
Washington Public Affairs Office, based on undisclosed criteria.
They also understand that a limited number of other members of
the media and the general public will be selected by lottery to
observe the proceedings in an overflow room via limited video
feed. These procedures are plainly insufficient to ensure that
Wikileaks and Mr. Assange, by and through their counsel, are
able fully and adequately to observe the proceedings and
safeguard their rights and interests.

B. Due Process Rights

These rights and interests of Mr. Assange and Wikileaks may
include, among others, their Fifth Amendment due process rights
and their Sixth Amendment interest in confronting any
allegations against them, particularly as relates to the grand
jury investigation in the Eastern District of Virginia, which is
apparently targeting Mr. Assange in connection with matters that
will likely be addressed at Private Manning's Article 32
hearing. Access is also important to protect Private Manning's
legal right to a fair and impartial hearing, and his
humanitarian right to be free of torture and other unlawful
abuse, as well as the general right of public access to the

proceedings.

on

00245

As set forth above, Petitioners? unique interest in these
proceedings is obvious. If prior official statements relating
to Private Manning - both on and off the record are to be
believed, it is nearly certain that allegations regarding Mr.
Assange and Wikileaks will be disclosed in these proceedings.
See, Ellen Nakashima Jerry Markon, WikiLeaks Founder
Could Be Charged Under Espionage Act, Wash. Post, Nov. 30, 2010
(quoting Attorney General Eric Holder and other government
sources); Charlie Savage, U.S. Tries to Build Case for
Conspiracy by Wikileaks, N.Y. Times, Dec. 15, 2010 (same).

Mr. Assange and Wikileaks need to know what those
allegations may include in order to ensure the proceedings are
as open, honest and transparent as possible. Consistent with
the fact?finding purpose of open trials, which the Supreme Court
has held may affect their outcome, Petitioners' counsel must
have the ability to observe the proceedings in their entirety in
order to evaluate live witness testimony and other evidence as
it is presented. Counsel also must have access to the hearing
room (rather than the overflow room) so that they may object and
request permission to be heard if the Investigating Officer
determines that it may be necessary to close portions of the

hearing.1 Factual assertions made in these proceedings may well



1 To the extent that portions of the proceedings may be closed to
protect classified information, CCR requests that its attorneys
who already hold seCurity clearances be allowed to observe the

9

be erroneous, and counsel for Wikileaks and Mr. Assange are in
the best position to evaluate them and correct the
record as may be necessary to prevent further substantial
prejudice to Private Manning, and to protect the interests of
Mr. Assange, Wikileaks and their supporters in connection with
these proceedings and other ongoing or possible future
proceedings here and abroad, including the grand jury
investigation and any threatened prosecution of Mr. Assange, as
well as any request for his extradition to the United States.
Transparency and accountability are especially important in
military proceedings such as these because ?military trial
courts in our country are nor standing or permanent courts," and
may be convened by various commanding officers without any
centralized oversight at the trial stage. See Eugene R. Fidell,
Accountability, Transparency Public Confidence in the

Administration of Military Jostice, 9 Green Bag 2d 361 (2006}.



closed sessions on the ground that Wikileaks and Mr. Assange
plainly have a "need to know? all information concerning them.
For example, it would be necessary for counsel to evaluate
whether information was improperly deemed classified in order to
conceal evidence of illegality or prevent embarrassment to the
Executive Branch. At a minimum, the proceedings should be
delayed to permit a ?need to know? determination to be made by
the relevant agencies and reviewed by the courts.

10

Conclusion
For these reasons, the Petition should be granted.

Date: New York, New York
December 15, 2011

Respectfully submitted,

15/ Baher Azmy

Vincent Warren, Executive Director
Baher Azmy, Legal Director

Michael Ratner, President Emeritus
CENTER FOR CONSTITUTIONAL RIGHTS
666 Broadway, 7th Floor

New York, New York 10012

Tel: (212) 614?6464

Fax: (212} 614?6499



Counsel for Julian Assange
and Wikileaks?



2 Petitioners' counsel are not admitted to practice before the
Court and therefore request permission, pursuant to Rule 8(c) of
the Courts of Criminal Appeals Rules of Practice and Procedure,
to appear pro hac vice for the limited purpose of litigating
this Petition. Good cause exists to grant this request given
the emergency nature of the relief requested and the serious
nature of the issues at stake in this case. Counsel are members
in good standing of the bar in New York State, and are admitted
to practice before various federal courts.

11

Certificate of Service
I hereby certify on this 15th day of December 2011, I
caused the foregoing Petition for Extraordinary Relief to be
filed with the Court, via facsimile and overnight mail, and
served on Respondents, via overnight mail, at the following

addresses:

Urs. Army Court of Criminal Appeals
Office of the Clerk of Court

9275 Gunston Road

Fort Belvoir, VA 22060-5546

Fax: 7034806-0124

and -

Clerk of Court

U.S. Army Judiciary

901 North Stuart Street, Suite 1200
Arlington, VA 22203?1837

Fax: 703-696-8777

and -

Lt. Col. Paul Almanza

U.S. Army Reserve Judge

150th Legal Support Organization
Ft. Meade, MD 20?55

Baher Army



l2

Exhibit A

?hr

centeriorconstitutionalrights
December 13. 20l I

Via Federal Express

Investigating Officer

cfo Military District of Washington
Public Affairs Of?ce

103 Third Avenue

Washington. D.C. 20319

Re: United States v. Bradley .I'Lfanning
Dear Sir:

The Center for Constitutional Rights represents the Wikileal-ts media organization and
its publisher Julian Assange regarding access to the Article 32 proceedings in United States v. Bradley
Manning. scheduled to begin at Fort Meade. Maryland. on December 16. 20] 1. We request that you
allocate two seats in the hearing room. for a CC attorney and for Mr. Assange's non-US. counsel
Jennifer Robinson. so that they may observe the proceedings on behalf of our clients.

We understand from telephone calls and written communications with the US. Army District
of Washington Public Affairs Office and of?cials at Fort Meade that only about eight seats in the
hearing room will be set aside for members of the media selected by the Public Affairs Of?ce. We
also understand that a limited number of other members of the media and the general public will be
selected by lottery to observe the proceedings in an over?ow room via limited video feed. These
procedures are plainly insufficient to ensure that Wikileaks and Mr. Assange. by and through their
counsel. are able fully and adequately to observe the proceedings and safeguard their rights and
interests, including under the Fifth and Sixth Amendments to the Constitution. as well as Private
Bradley Manning?s legal and humanitarian rights and the right of public access to the proceedings.

Our clients? unique interest in these proceedings is obvious. For more than a year. there has
been intense worldwide speculation that hundreds of thousands of allegedly classi?ed diplomatic
cables published by Wikileaks as well as The New York Times. The Guardian. and other international
media organizations were provided to Wikileaks and Mr. Assange by Private Manning. There is
strong evidence that Private Manning has suffered serious human rights violations as a result of those
unproven claims. including prolonged isolation and sensory deprivation. and other torture or cruel.
inhuman and degrading treatment reminiscent of the worst abuses at Guantanamo Bay. Throughout
all of his detention. the US. government has refused to allow the United Nations Special Rapporteur
for Torture to adequately assess Private Manning?s treatment and conditions.) If prior of?cial
statements relating to Private Manning are to be believed. it is nearly certain that allegations regarding
Wikileaks and Mr. Assange will be disclosed in these proceedings.

Mr. Assange and Wikileaks need to know what those allegations may include in order to ensure
the proceedings are as open. honest and transparent as possible. Their counsel must have the ability to
observe the proceedings in their entirety in order to evaluate live witness testimony and other evidence
as it is presented: Factual assertions made in these proceedings may well be erroneous. and counsel
for Wikileaks and Mr. Assange are in the best position to evaluate them and correct the
record as may be necessary to prevent further substantial prejudice to Private Manning. and to protect
the interests of Mr. Assange. Wikileaks and their supporters in connection with these proceedings and
other ongoing or possible future proceedings here and abroad. Transparency and accountability are
especially important in military proceedings such as these because ?military trial courts in our country
are not standing or permanent courts." and may be convened by various commanding officers without
any centralized oversight at the trial stage. See Eugene R. Fidell. Accountabfiint. Transparency d?r
Public Confidence in the Administration of Mt] tl?tj.? Justice. 9 Green Bag 2d 36] (2006}.

Mr. Assange also notably has a particular personal interest in the Article 32 proceedings
because it appears that federal prosecutors in the Eastern District ot?Virginia have been issuing
subpoenas to supporters of Wikilealts in order to investigate matters that. based on prior of?cial
statements. will likely be addressed in Private Manning?s Article 32 proceedings. it has been reported
that these subpoenas are the result of a grandjury process that has. as is the norm in the United States.
taken place entirely in secret without any involvement permitted by defense counsel. in a district that
has the highest concentration of military and govemmentjurors in the nation. The names of Mr.
r?tssange. Wikilcaks. and Pritatc Manning reportedly appear on many of" the production orders coming
out ol'this grand jury process that have been sert ed in relation to Wikilcaks' supporters on companies
such as tiOoglc and Twitter.

Moreover. guaranteed access for media organization such as Wikileaks and its publisher Mr.
Assange is necessary to ensure public access to the proceedings. which is protected at common law
and by the First Amendment to the Constitution. Indeed. given the intense public interest in this case.
we are concerned that the lack of adequate capacity to accommodate the media and other interested
parties such as Wikileaks and Mr. Assange may result in a constructive. blanket denial ofpublic access
to the proceedings. See Denver Post Co. v. United States. Army Misc. 20041215 2005).
available at 2005 CCA LEXIS 550 (granting writ of mandamus to allow public access to Article 32
proceedings].

In sum. counsel for Mr. Assange and Wikileaks have a professional duty of care which must be
exercised not only for the bene?t of our clients but also for others whose life or liberty is at risk.
including alleged sources such as Private Manning as well as WikiLeaks supporters. employees and
contractors who have been subject to U.S. government surveillance in relation to their constitutionally-
protected activities. We hope that you will approve our request for guaranteed access to these Article
32 proceedings. We further ask for your response by no later than the close of business on



To the extent that portions ofthe proceedings may be closed to protect classi?ed information, CCR requests that
its attorneys who already hold security clearances he ailovved to observe the closed sessions on the ground that Wikileaks
and Mr. Assange plainly have a ?need to know" all information concerning them. For example. it would be necessary for
counsel to evaluate whether information was improperly deemed classi?ed in order to conceal evidence ofillegality or
prevent embarrassment to the Executive Branch. At a minimum. the proceedings should be delayed to permit a "need to
know? determination to be made by the relevant agencies and reviewed by the courts.

fd



Wednesday. December 14, 20! I, so that we may seek any relief which may be necessary in court. Mr.
Azmy, legal director. may be reached by phone at (2l2) 614-6427.

Very truly yours.

Baher Azmy
Vince Warren
Michael Ratner
cc: Jennifer Robinson
Convening Authority

Article 32 Exhibits
A) Secretary of the Army 15-6 Executive Summary
B) PFC Bradley Ma nning?s Counseling Records
C) MSG Paul Adkins? Memorandums for Record
D) PFC Bradley Manning?s Mental Health Records
El PFC Bradley Manning?s ?My Problem Email"
CID Computer Forensics "Crossdressing.com document?
CID Computer Forensics "Amazon order [Facial Feminization Surgeryl"
CID Computer Forensics "Breanna Documents?

CID Documents Seized in PFC Bradley Manning?s CHU

PFC Bradley Manning?s Equal Opportunity Complaint

m. orca. to)

EXHIBIT A


UNCLASSIFIEDHFOR OFFICIAL USE ONLY

DEPARTMENT OF THE ARMY
us. sew COMBINED ARMS CENTER AND FORT LEAVENWORTH
415 SHERMAN AVENUE UNIT 1
FORT KANSAS scum-2300




ATTEPHICIMOF

ATZL-CG 14 February 2011

MEMORANDUM FOR Secretary of the Army

SUBJECT: AR 15-6 Investigation - Compromise of Classified Information to Wikiteaks
(EXECUTIVE SUMMARY)

1. On 16 Decam per 2010, lwas appointed by The Honorable John M. McHugh.
Secretary of the Army, to conduct an Army Regulation 15-6 Investigation into the
compromise of classified information to Wikileaks. My appointment followed a
Secretary of Defense Memorandum to the Secretary of the Army, dated 14 December
2010, noting that additional inquiry beyond the previously conducted Army Regulation
(AR) 380-5 and United States Forces-Iraq (USF-I) AR 15-6 was required. My detailed
report, following this Executive Summary, is the result of a comprehensive, multi-
disciplinary, and independent administrative investigation into the facts and
circumstances associated with the suspected compromise of classified national security
information by Private First Class (PFC) Bradley E. Manning to the Wikileaks

organization

2. Summary of Incident. PFC Manning deployed to Iraq with the 2d Brigade Combat
Team (BCT), 10th Mountain Division {2!10 on 11 October 2009. As a military
intelligence analyst. PFC Manning worked in the Sensitive Compartmented Information
Facility (SCIF) where he had unfettered access to classified information. Between 11
October 2009 and his apprehension on 27 May 2010. PFC Manning allegedly
downloaded classified information onto his computer, removed that
information from his workplace. and transferred that information to persons not entitled
to receive classified information. Due to a lack of physical security and supervision,
PFC Manning was able to take classi?ed information out of the SCIF unchecked.
Because of the on-going criminal investigation, this investigation did not focus on the
exact means and mechanism by which PFC Manning allegedly acquired, downloaded,
removed, and allegedly disclosed classified information to third parties. Instead, this
investigation focused on the chain of command and the institutional systems,
procedures, processes and conditions that may have contributed to the compromise of
classified information.

3 Findings and Recommendations. The following is a brief summary of the findings

and recommendations that are set out in full detail in the final AR 15-6 report. I looked
at three specific areas to determine what, if any, factors contributed to the unauthorized

disclosure of classified information

UNCLASSIFIEDHFOR OFFICIAL USE ONLY

ManningB_00013163



UNCLASSIFIEDHFOR OFFICIAL USE ONLY

ATZL-CG
SUBJECT: AR 15-6 Investigation - Compromise of Classified Information to Wikileaks

(EXECUTIVE SUMMARY)

a. PFC Manning.

(1) Early Warning Signs. The investigation identified several early warning signs
with PFC Manning?s pre- and post-accession into the Army. These included;
behavioral health issues which were not identified during accession screening or during
his security clearance investigation; conflict with his stepmother: "skipping out" on a
lease; being an "authority hater?, conflict with other basic training trainees to include an
alleged assault: and "tantrum fits of rage." While this investigation has the benefit of
hindsight, the red flags that were raised prior to and early on in PFC Manning's military
career provided some notice that issues could arise

(2) Basic Training and Advance Individual Training (AIT). PFC Manning enlisted
to serve as a MOS 35F. Intelligence Analyst. and met all prerequisites for award of the
MOS, including scoring 128 on the skilled technical (ST) portion of Armed Services
Vocational Aptitude Battery Test (ASVAB). He attended Basrc Training at Fort Leonard
Wood. MD from 5 October 200? through 6 April 2008 and AIT at Fort Huachuca, AZ
from 7 April 2008 until on or about 2? August 2008. While at Basic Training and he
had some disciplinary issues and a command-referral to behavioral health for ?tantrum
fits of rage?; however, none of these issues were conveyed to those conducting his
security clearance investigation nor did any specific event in and of itself, or
cumulatively, result in action to deny PFC Manning's clearance. PFC Manning
submitted his Top Secrethensitive Compartmented information (TSISCI) security
clearance application on or about 26 September 2007. On 6 October 2008. after
completion of a security clearance investigation and Army (3-2 adjudication, he was
awarded a TSISCI clearance.

2l10 MTN. From 28 August 2008 until 10 October 2009, PFC Manning
served at Fort Drum. NY and one rotation at the Joint Readiness Training Center
(JRTC), Fort Polk, LA. On 11 October 2009, he deployed with 2l10 MTN in support of
Operation Iraqi Freedom. serving in the brigade intelligence (3-2) section on Forward
Operating Base (FOB) Hammer. On 8 May 2010. PFC Manning was moved from the S-
2 section to the supply room after assaulting SPC Jirleah Showman, another member of
the 3-2 section. Once moved to the supply room. PFC Manning no longer had access
to the SCIF.

(4) Warning Signs and Failure to Take Action. The Investigation revealed at
least fourteen warning signs. occurring on different dates and times from PFC
Manning's initial entry onto active duty in 2007 to the day he assaulted SPC Showman.
These warning signs either individually, or collectively. should have resulted in his chain
of command initiating behavioral health assessments, considering disciplinary action
and determining whether to suspend or revoke his access to classi?ed information.

'1
4

UNCLASSIFIEDHFOR OFFICIAL USE ONLY

ManningE_00013164

hr by

UNCLASSIFIEDNFOR OFFICIAL USE ONLY

ATZL-CG
SUBJECT: AR 15-6 Investigation - Compromise of Classified Information to Wikileaks

(EXECUTIVE SUMMARY)

b. Chain of Command and Supervisors.

(1) Failure of Command and Supervisors. Due to a dysfunctional leadership
environment in the 2110 MTN 8-2 section and the failure of the Company Commander
to provide command oversight. PFC Manning?s alleged pattern of behavioral health
issues. disrespect, insubordination. and disloyal statements were not properly
addressed. It was not until PFC Manning assaulted another Soldier that steps were
taken to suspend his access to classified information. The Investigation assessed what
role. if any. was played by a total of 25 personnel ranging from the Commander. 2f 10
MTN to PFC Mannings ?rst-line supervisors as well as personnel responsible for
oversight and management of the SCIF and the computer network. The Investigation
uncovered varying degrees of culpability or failures for 15 of the 26 Soldiers
investigated.

(2) Noncommissioned Officer In Charge The Investigation revealed
that the Master Sergeant of the 3-2 section. took it upon himself to
watch over. safeguard, and insulate PFC Manning from other leaders in the chain of
command. exceeding his authority under traditional commandfnon-command
relationships. The accomplished this by usurping the first-line and mid?level
supervisors of their leadership responsibilities and directing them to perform only
technical responsibilities. The NCOIC personally considered PFC Manning to be
unstable at times as evidenced in three Memoranda for Record he generated from
December 2009 through April 2010. Although he was the NCOIC of the 3-2 Section. he
had a duty to keep the chain of command infon'ned of PFC Manning's disciplinary and
behavioral health issues which he did not do. The NCOIC also failed to take
appropriate steps to safeguard classified information by not enforcing the physical
security standards of the SCIF leg, allowing personal removable media into the
I find that the NCOIC was derelict in the performance of his duties. Specifically. he
failed to provide appropriate supervision and leadership of enlisted personnel in the 8-2
section and failed to properly implement and enforce physical and personnel security
measures affecting the SCIF. I have determined that administrative or nonjudicial
action is insufficient to address his dereliction of duty and his repeated failures as a
leader. Therefore. I am recommending a Court-Martial in his case.

(3) Other Leadership and Supervisory Failures. Besides the NCOIC. there were
fourteen other Soldiers who failed in executing their leadership and supervisory
responsibilities. The contemplated actions for these individuals range from a written

admonition to a General Officer Memorandum of Reprimand. Personnel in the following
ranks and position were all culpable of leadership and supervisory failures:

3
UNCLASSIFIEDHFOR OFFICIAL USE ONLY

ManningB_00013155



UNCLASSIFIEDHFOR OFFICIAL USE ONLY


SUBJECT: AR 15?6 Investigation - Compromise of Classified tnforrnation to Wikileaks

(EXECUTIVE SUMMARY)

a. 2110 MTN Executive Of?cer (X0), Lieutenant Colonel (LTC) for failing to
provide proper management and supervision of the 3?2 section, as well as failing to
take appropriate steps to ensure the security of the classified network:

b. Multinational Division-Baghdad (MND-B) and is! Cavalry Division (100).
Assistant Chief of Staff, 6?6. LTC for failing to ensure the 2ND MTN tactical network
was properly certified, accredited and inspected;

c. U.S. Division-Center and 1st Armored Division (1A0). Assistant
Chief of Staff. (5-6. LTC) for failing to ensure the 210 MTN tactical network was
properly certified, accredited and inspected:

d. CD Information Assurance Manager (IAM), Major (MAJ) for failing to
verify 2i 1 MTN tactical network was property certified and accredited and for failing to
conduct proper inspections;

e. USU-CHAD IAM. MAJ for failing to verify 2ND MTN tactical network was
properly certified and accredited and for failing to conduct proper inspections;

f_ 2? MTN, Signal Officer (8-8). MAJ for failing to ensure the timer certi?cation
and accreditation of the brigade?s network or ensuring the preper supervision of the
same;

g. 21 0 MTN. intelligence Of?cer (3-2). MAJ for failing to properly supervise the
8-2 section and the personnel therein:

h. Headquarters and Headquarters Company (HHC), 2ND MTN. Commander.
MAJ for failing to exercise proper command oversight over his Company and the
Soldiers under his charge and for lacking the necessary and required situational
awareness of ongoing operations to properly lead the Soldiers under his charge:

i. HHC. 2i10 MTN. First Sergeant, First SergeantiiSG) forfeiting to exercise
proper command oversight over his Company and the Soldiers under his charge and for
lacking the necessary and required situational awareness of ongoing operations to
properly lead the Soldiers under his charge;

2110 MTN. IAM and assistant 8?6, Captain (CPT) for failing to certify and
accredit the 2! 10 BCT network;

it. MICO (Company B). 2:10 Brigade Special Troops Battalion (BSTB). then 2ND

MTN 8-2. CPT) for lacking situational awareness of personnel issues as AIS-2 and for
failing to influence and supervise 8-2 operations as the

4

UNCLASSIFIEDHFOR OFFICIAL USE ONLY

ManningB_DDO?l 3166

5: "up
UNCLASSIFIEDHFOR OFFICIAL USE ONLY

ATZL-CG
SUBJECT: AR 15-6 Investigation - Compromise of Classified Information to Wikilealts

(EXECUTIVE SUMMARY)

I- 2ND MTN Special Security Representative. 1st Lieutenant (1LT) for failing to
properly implement and enforce physical and personnel security measures affecting the

SCIF:

m. 2ND MTN intelligence fusion OIC, Chief Warrant Officer2(CW2) forfeiting to
take appropriate action as the first officer in PFC Manning?s supervisory chain of
command; and

n. 2? MTN fusion cell, Warrant Officer 1 (W01), previously Staff Sergeant
(88G) for failing to take appropriate action as the first noncommissioned officer in PFC

Manning's supervisory chain of com mand.

(4) Information Assurance (IA) Supervisory Responsibility. As noted above, this
investigation found failures within the IA supervisory chain. Specifically. the division-
level IA personnel failed to ensure the 2ND MTN network was certified and accredited.
and failed to conduct inspections in accordance with relevant regulations and policies.
These supervisory failures may not have prevented PFC Manning's alleged criminal
misconduct. but they did result in a network that operated outside Army and
regulations and applicable standards.

(5) individual Responsibility. While the investigation uncovered leadership
failures, technical failures, or both by some personnel in the handling of PFC Manning?s
conduct. to include conduct requiring behavioral health referrals. none of these failures
were the cause of any alleged criminal activity by PFC Manning.

c. Policy] Procedures. Processes and Conditions

(1) Personnel Security. The Investigation also found that while the Single Scope
Background Investigation (SSBI) was purportedly done to standard, several red flags or
areas of note were not adequately addressed by investigators. These areas include
PFC Manning "skipping out" on his lease. reported conflict with his stepmother and
making false statements on his security clearance application. Due to PFC Manning?s
age at the time of enlistment. and his home of residence in the United Kingdom, the
period of time covered by the was only 28 months. This short investigative time
period limited the information the adjudicators had available to make a proper
determination of PFC Manning's eligibility for a Further, there is a lack of
understanding by low and mid-level leaders of their responsibilities regarding
conducting continuous evaluations of an individual?s eligibility to have access to
classified information. This lack of understanding is an institutional problem that
requires training and emphasis across the Army.

5

UNCLASSIFIEDHFOR OFFICIAL USE ONLY

Manning?_0001316?

\f 5--

UNCLASSIFIEDHFOR OFFICIAL USE ONLY

ATZL-CG
SUBJECT: AR 15-6 Investigation - Compromise of Classified Information to Wikileaks

SUMMARY)

(2) SCI Physical Security. Beyond the already noted failure of the unit to enforce
applicable standards, this investigation revealed outdated and inadequate regulatory
guidance. The proper exercise of physical security may have provided an adequate
deterrent to prevent the compromise of classified information While the noted
deficiencies were not the cause of PFC Manning?s alleged unauthorized disclosure,
these deficiencies contributed to a SCIF that was operating outside of Director of
National Intelligence (DNI). Department of Defense and Department of the Army
DA regulations and standards. Ambiguity among the current regulations warrants a
review to ensure a consistent set of standards. Further. training is available at the
Defense Intelligence Agency (DIA), but current DA regulations do not require or provide
guidance to participate in this training.

Information Assurance. Both 2/1 0 MTN and its deployed division
headquarters did not fully comply with information assurance regulations, policies and
standards. Had IA measures been fully implemented. PFC Manning's ability to
allegedly download thousands of pieces of classi?ed information would have been
hampered, but most likely would not have been completely prevented. Further,
appropriate IA measures could have provided sufficient deterrence to PFC Manning?s
alleged criminal conduct. There were technical and procedural deficiencies including a
. failure to certify the network and a failure to conduct inspections of the network by
5 higher headquarters. Other issues include inadequate training and insufficient
regulatory guidance at the and DA levels. These deficiencies should be addressed
in order to ensure IA personnel are competent in executing their IA responsibilities.

Behavioral Health Concerns. This investigation revealed concerns with how
behavioral health issues are addressed by some leaders and by behavioral health
providers

Command vs. Self-Referral to Behavioral Health. Despite the numerous
alleged disrespectful and insubordinate outbursts and alleged violent behavior which
should have triggered a command-referral, PFC Manning was allowed to use the self-
referral process associated with behavioral health evaluations to keep his personal
issues from his chain of command. A command-referral could have provided PFC
Manning's Company Commander with the necessary information from behavioral health
providers to make an informed decision on whether or not to deploy PFC Manning or to
allow his continued access to classified information.

Behavioral Incidents Not Linked to Security Clearance. Neither PFC
Manning?s leaders nor his behavioral health providers linked PFC Manning's conduct
with his eligibility to have continued access to classified information. While the
investigation discovered at least fourteen behavioral and conduct issues, none triggered
a suspension of PFC Manningis access to classi?ed information or a Derogatory Report

6
UNCLASSIFIEDHFOR OFFICIAL USE ONLY



\ur

UNCLASSIFIEDHFOR OFFICIAL USE ONLY

ATZL-CG
SUBJECT: AR 15-6 Investigation - Compromise of Classified Information to Wikileaks

(EXECUTIVE SUMMARY)

to the Central Clearance Facility for additional inquiry. it was only after PFC Manning
assaulted a fellow Soldier on 8 May 2010 that his access to classified information was
suspended. Currently. commanders are the only personnel authorized to submit
derogatory reports. Current policies and regulations limit the quantity and quality of
information commanders can have regarding behavioral health issues, speci?cally in the
area of self-referrals. Commanders need greater access to behavioral health
information to adequately assess 3 Soldiers initial and continued access to classified

information.

Behavioral Health Regulations Training Deficiency. Our finding is that the
Directive Type Memorandum (DTM) 09-006. Subject: Revising Command Notification
Requirements to Dispel Stigma in Providing Mental Health Care to Military Personnel is
adequate in its identification of the conditions necessary for behavioral health providers
to notify commanders when there is a risk to self. others. or the mission. The issue is in
training both the behavioral health providers and the commanders. Recommend the
Army review the training on and implementation of DTM 09-006 to ensure behavioral
health providers and commanders understand the policies regarding commanders?
access to mental health information. This information can be critical for commanders in
making decisions regarding individuals? access to classified information.

(5) Impacts of Modularity. During the majority of the 2f 10 MTN's Army Force
Generation (ARFORGEN) trainiready phases their higher headquarters was deployed.
This resulted in the loss of training and readiness oversight of unit training. Oversight
was particularly absent for the specialized and technical training regarding physical
security, information assurance and personnel security. The Army must address unit
training requirements usually performed by higher headquarters in their oversight role
when that higher headquarters is not available during the ARFORGEN cycle.

(6) Leading the New Culture. There is a cultural gap between ?rst-line and mid-
level leaders and young Soldiers of the ?new culture". The "new culture" is
characterized as being; transparent. social media?savvy and isolated from the physical
world. Some of these Soldiers develop loyalties to the virtual world which can conflict
with their loyalties in the physical world. The virtual world comes with a different set of
standards and often no values. What is concerning is that this generation generally
feels it is okay to have a different set of values in the virtual world. Military culture relies
heavily on small unit cohesion; the ?new culture? Soldier provides unique challenges for
military leaders at all levels. First-line and mid?level supervisors. only a few years older
than the Soldiers they are leading, generally do not have the same affinity for the virtual
world since the expansion of social media is only a few years old. Further. those
supervisors. while proficient in combat, are challenged when it comes to leading
Soldiers in garrison and administrative tasks. First-line supervisors must understand
the differences the "new culture" brings and must work to build small unit cohesion

7

UNCLASSIFIEDHFOR OFFICIAL USE ONLY

ManningB_00013169



$531-?


SUBJECT: AR 15-6 investigation - Compromise of Classified information to Wikileaks

SUMMARY)

Team building must be emphasized at ati ievets of. leadership Professional Military
Education (PME) courses. the prencornrnand course and toast commander and
?rst sergeant (CORN 8(3) courses should focus their efforts ptoinding ail leaders with
the skills to mitigate the challenges of leading the "new culture" of Soldiers.

4. A number of de?ciencies were identi?ed throughout this investigation. some of which
oentributed to the one uthorized disclosure of eiassi?ed information. Despite the time
constraints associated with this investigation. the investigative team attempted to
thoroughly investigate ail concerns which were identi?ed and provide sound
recommendations to address these concerns.

5. POC for this memorandum is the undersigned a-



ROBERT L. ASLEN: JR
Lieutenant eneral. USA
investigating Of?cer

CF.

HON John M. MoHugh, Secretary of the Army

GEN George Casey, Army Chief of Staff
8

ii??i?ia?ai. {new

Manninge_oom 31rd

EXHIBIT

AR 15-6 REPORT

Compromise Of Classified Information To WiKiLeaks

10

11

12

ManningB_DGU?l 38H

Counseling File Index

DA Form 4856, PFC
Bradley E. Manning

DA Form 4856, PFC
Bradley E. Manning

DA Form 4856, PFC
Bradley E. Manning

DA Form 4856, PFC
Bradley E. Manning

DA Form 4856, PFC
Bradley E. Manning

DA Form 4856, PFC
Bradley E. Manning

DA Form 4856, PFC
Bradley E. Manning

DA Farm 4856, PFC
Bradley E. Manning

DA Form 4856, PFC
Bradley E. Manning

DA Form 4856, PFC
Bradley E. Manning

DA Form 4856, PFC
Bradley E. Manning

DA Form 4856, PFC
Bradley E. Manning
Down range Assault

DA Form 4856, PFC Bradley E. Manning, 11 Sep 08
[Initial Integration Counseling)

DA Form 4856, PFC Bradley E. Manning 11 Sep 08
Performance}

DA Form 4856, PFC Bradley E. Manning, 26 Sep 08
{Event Oriented APFT Failure)

DA Form 4856, PFC Bradley E. Manning 1 Nov 08
(End of Month Counseling}

DA Form 4856, PFC Bradley E. Manning 7 Nov 08-
{Event Oriented ?Veterans Day Weekend)

DA Form 4856, PFC Bradley E. Manning, 17 Dec 08
{Event Oriented Black Leave)

DA Form 4856, PFC Bradley E. Manning 15 Jan 09
[Event Oriented MLK Weekend}

DA Form 4856, PFC Bradley E. Manning, 1 Feb 09
Caunseling for January)

DA Form 4856, PFC Bradley E. Manning 7 Apr 09
{Initial New Team Leader) (SPC Showman}

DA Form 4856, PFC Bradley E. Manning Apr 09
{Event Oriented - FTR and Disrespect)

DA Form 4856, PFC Bradley E. Manning 3 Jun 09
[Performance Counseling - June)

DA Form 4856, PFC Bradley E. Manning, 17 May
10 (Event Oriented Assault and Battery]

DEVELOPMENTAL COUNSELING FORM
Far of burl. Ill FM 21.1mm.- simulaan





BY THE ACT 0F
5 USE 301. Roma?: 10 USC 34113. Sic-I?ll?! 0 Alli-1y and EU. (SSH)













AU
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Din-Ghan II My,
PART I - DATA
Nan-u rm: Fin: mmaa Sada! accuri?r No. Dual
Manning. Bradley 5 PVIIEZ I i SEP 08
01me rum and Tm of Counubt
HIE. 2d BUT, IN: MTN Ill?:l (LI) 350103: Ania, ACT NCOIC



PART II - BACKGROUND INFDMATIOH
Pan-pan a! Comlhg: [Lad-ruin: ma rum IN the mouths: a . gram or amt-oriented mill-lg.
Indm?udn It? MI: and unnatural" Mar In com-rah?



INITIAL INTEGRATION COUNSELING



PART - EUHIMRY OF nominate
Cowl-I- n?ll ucllon during or Iran-dimly "menu! ?wanna.



Kc)! Palm: cl Elwin-Ian:
INTEGRATION COUNSELING: FV2 Mung. ?11991:: In HHC. 2d BET, 10 MTN DIV (LII. null upIuytd unit In ?It Anny. Thu
unit is tn own for its cumulus, "Mammals Ind you In expach perform a: m: high?: standards for Ill-a: Amy md ?u nil. SSE Kyla annual:
will In: your swim and all im? will In: hauuhl In him or lung]! until fan-be: unlit: IS IMPORTANT. w: and la Imuw when:
yau In. all": you In: doing. Ind. win; ?u plan to dn in the neu- rum: ham: to an mm: In an wan nrieuud ?counseling, Rep-led u?'cum

mu mull Uml?um Cod: ormuwy Julia: (UCMJJ action. lie-:9 war man out ml warty. Providu I am of 1mm- LES at man- munulinu
union

PERSONAL APPEARANCEIMILITMIY BEARING: Naming. the ngulnm which cm wur nu! arm uniform it AR 6704.
Fumiliu'rm this rum-nan as this a pan or lam-5 nsddiu- nd mum-wing military bum-in; You will lisp youth-it to standard uld your
smut-bin. As: new Soldier. you man be awn: of whatpupal}: mam mm mm. Marlyn sound DH and
mum yum?f I comp-clam con?dant Sbldiq

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arrivinpu I new win You: m? u: Imnuwly scheduled for 15 Prepmyuumzrnow on you: own an: and pull: )?owll?wkn conducting
PT with the Ih?p. You In Illa meld In mdu? PT :5 pm origin; - Suldin In Lil: ?slim. You Ina}- In chug: ofu but pct-sauna} On Inf
7 given mains.

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pmme for IRTC You will In: mind an ncG?-A Ind lb: shop produq made dun?n; 1h: marina. There nu ma: which m:
011' llama la Sam's-rs of Fun mum. You will In mum on m: other an: us off limit:

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mm will be pliaflly dtplogml

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NOV All you bus will In: moped): mulccd In! your has Iqwcd any prim to ?pm: My pmsoud issues Ihu Iris: during lh: will
b: hailed by 556 Bum}: or Just Icl us know ifyau mud sum-nu.



OTHER
Tm- lam mu In upon: mama-11ml {am mam 1mm. separalian 1151's, or upon minimal. For annual-I
numerical: Ind no?ulan al' In? or mum-mum at local mum: and AR ans-am.



DA UN 1935 EDITION 0F Jun as Is assay: m:

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Ensure PVI Manning is the right plan a: the right limt and in the right uniform
Ennu': PVZ is input 2d BCT camp: 3' policiu

EnSum plenty af?rms is allotted for Civilim Education

Sig-law- or Gwalior. SSG Jcse Ania Date: I I SEP 05



PART W-ASEESSMENT OF THE PLAN OF acnuu



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DEVELOPMENTAL COUNSELING FORM
For uu nl Inl- lam. FM 12-100. money It TRADOC



DATA ETTHE PMVACT ACT 0? ?1le
5 USC 3m. Dipli?unluul Emulsions; 1O UBC 3:113. ur {Ill Anny Ind ED 9397
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and mm" the Ind-r: hm Ind chi-muons pmri'u ,l

EVENT ORIENTED COUNSELING FUR APFT FAILURE



PART II . SUI-ART 0F COURSELING
m- ucus:- during or Emmi, Iw-oquinth



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REVERSE. DI FOR. ?It.

ManningB_DOU1 3818

AFDPIHDD







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PART ll - IAOKGRDUND



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mummies-Hm? madam roarme
mun-unmarde



.mi??.amr? Mm. Farm





DA IORII Juu mu Eamon cur JUN I: owns

ManningB_DDO13879

"Hui-1 I





mam?: mom



1-1- ?-dm Inuit-l hum mu mull-ill



Iguana-um: Th


Imam?w: Inn-o Winn-imam:

mun-Imam

Sign-tn II hind-dill Own-lid:





"It! hm? luau-hmamuiu in #:191an a. man of action;

Cna?nun to keep SM infomud.

Conant? to mentor SM 10 In competent Indra.

?an-m NW um:







haw?I:
WJ

Unborn-lam









m: am the tour-dou- In! th- Inilvluunl sauna-ltd should I Heard of ?u counseling.







In]! ll".

ManningB_O{JO1 3880

mum









. -VELOPMEHTAL COUNSELING
Forulo ol Hi: form. on FM 2.2.100; Ila prawn-rut lamb



DATA IEOIJIRED BY THE Hill-I'm ET OF 197?

MINORITY: 5 USC 3M. DIMMIM I nonunion; 1D USO .3013. Emmy of Iho Anny Ind 5.0. 9?39?
PHHCIPM. Fwoae: To ?mum-n In wwu??nq ma momma muslin-q on and? to
mu'nug uses; For nominal. Ind-r dual-comm um Fill 22-109. London show on Ihlo form mum.
0mm man-y.



PART I - ADMINISTRATIVE BET
















. . Will"
mo?il??tuf ?ll?wm a: WBl/m 2 lr7 [do I) We
Goonin?on

?Nams and ?lls at Gounu

to am piv?
PART II - BACKGROUND INFORMATION





Puma? of Count Iling: (Luau dun ?u mm for the Gaming 0.3.. or "lan mouth-r9.
and Made: the r: odor?: flat; and Marion: print lo the m;

Even! Orioolod Emulation For Vanna: my Wodan Dl-tl Nev}



PART - mum OF COUNSEUHG
Cumulus "can tum or lanolin-Ir mum to oounullno.
Palm: of mm:
The purpouoflhio nouns-Ila; I: to diam Block Luv: coming up, and who! :1pr you. You haw been in tho unit In; Claim}! 11 111i: point
you hum non Ind hoard who" Ill-n: don mound should to nil-no ovoid tho "mould-IL: runner.

The Brigade, lotu?oa, Ind Con-[play luv: all had tuna and problem: sound by driatiu Then is obi-alum? NO TOLEIMICE to
driohngo?'mu. If you In and-Ir ?gym WILL NOT drink and" any chumnmol, [you mail. you WILL NOT on: alcohol for ?you ?do:
1 . Addillomlly ifrw or: our 2 Ind you Ih mlunioluiomuwho in Mil Ind thy two: but bomd?nkinnw and
to luvo ASH. you could [till he causal jun ra- boil; that. Dial:th Driving Wu bow MAW: mum; dawn uldrivc. noun!
uni ?are is obsolulaly no unnu- for drinking nod drivinl. Tim is Ill-In mollm my to In hm safely. When you mill: Ind Grin you on!
yourull' Ind other: at risk. Call I null or use your Chill of ?mum!? Hoke our: you In: your ARRIVE ALIVE CARD at limo.

DIUGS- There is null-lily NO TOLERANCE to on; an. ll in not talented no my cum no I will mom-no 1h: nub-urn punith it you
coma up [admin [at drug on. Thu in tho polli'b?ily IDDW. Uri-nulls. DO Hm how I drug, or dcohol prob?. ?null

WIT in ASAP.

LIMITS- The lounge ?ail-lion wilhout gm ll Jill mild. Condo z'o of?imm UNLESS you one moivod I hrlorfrum 5-2. lfyou ml
to [a umidc ol'lhil nap. HUST PUT IN A PASS REQUEST Ind thy nun In in by COB on dendnr. Ifyuu won! uh. pro-1 at In:
Immopmp?fm Ind l-ill gallium Taryn. WM: rout-nun and lo hurt: my ul?you: mum-a that)!? u: goingm.or:.nmy.mil Ind ?ll am the risk mum: onliu Ind pn?nl I up; alum for mo.

SAFE EEX- ll'you dooldc lo Inn nu. no: you ?no condom union you on having on will: yanrwi?. Be at: ifruu u: ?nial tn. You
doo?t mm or and lo STD. If you on link. don't have n: wilhmuno wit: [mules undowoman dun your wife if
yawn: ?Mod. Thu: no Ill ouhjm to punt-Inn out madm- UCMI.

HUHTDIO- Ruling mm in upon u. If you with to lo hustling. you mm uh: {In humor: ul'cly wnnoomnd by MWR out! you MUST how I
llama. You studio moon may I limos. Alwyn troll your weapons I: if ll iI Wad. Go hunting with I buddy. We don't nod to low

ml?mpm'??
SPOUSES ABUSE- Tho Amy his I no tolerance ml: do I ohm healing your wlfo. Ifyou so and Il your wife you thin]: you ongoing ll:

hp, vol I?lj'. hull-Ia. nod nil your buddy or lunar?: roman yon-?If flout Illa Illa-lion. We can put ran in Ihe human For tho mall? on! you all
ullr tn lb: dleI?n tho um day lid-lint This incl-Mu you child": nod you.

WRECKLESSIDANGEROUS ACTIVITIES- Th: maul: him Kins: FIJI: MT Only "in in tamarind "In whorl that ll I lihiunm
and uhh I hilly. Don't drink Ind Il?l?. Hyou to ?Moro, L?lkl I huddy - II lil'l?.



OTHER MW [1110003

Tm lam: uni Ia duo-wad upon: rumor-maul (omit-monme mm. le?ii?l'llt ?11.01 won Mllan For Input-lion
madam-nu and abdication ol Ion of hm?hl'conunuml no local um and AR 615-2011







APO

DA 455-6. JUN 1959 EDITION OF JUN as l5 OBSOLETE

ManningB_DDO13881

3'

nun-mm I:me an ammonium: Marika-turfme
?NIP-rtme

Mmmh??u?mv? kahuna-ht?.

Mills:

?lo-Hoary.



all ?will.

Dashing-urth urn-Ill.



31'me Ila-syn nwummhurm



n?h ?ling: {Thu Eur-min: {no In! adul- 01' me ?33:03: and check: rm Sumt?n?d? Mama If. plan damn.
Emmi! mama-minth

mum:

mu mull-d

1
sign-mummy: 2/7 Q. Nod 03

I

Luna-W1:me

Muf?n-um?



Com-lulu: mu





Nata; Both ?n counselor and the Individual counsqu shank! "tall-I 2] record ?lth-a mulling.

1mm?

ManningB_00013882







DEVELOPIIENTAL COUNSELING FORM
Format?!



DATA REQUIED IT THE OF "14











5 use 3o1. Dan-mum: Run-millions: use 301:. oflm Aim 5.0. 53!? gas?;
meu To mm bold? Ill mud-in?rm and Houdini mom dill-I ?ml to Minolta.
Roy-nus was; For IIodor ombwom 22-100. should um HI fom II mmry.
DMCLOIURE: Childm- II mint-w.

Nm I:er ?u Rmiqud-a ?ooill Security Ho. Doll o! OWN-IBM
aningjm?ey Pm! DEC 03
Ornul'iallim Name and Tilt DIG-mull}!
HHC. 2d BCT. 10111 MTN DIV For! Drum. NY 13602 858 ioso Anion. Senior lumlligmoe Susan:





Fm II - HWIDUHD INFORMATION



rum-on of Goon-Jinn: (Laud-r am no rum ?u comma. I4. Mahmud youth or mm mm.
and loom mm km and oosmo'ons poor In on mnubngJ

Eco: Drion Cumming For DEC DI Black Luv: ZODECN - SMNGI.



PART -SUIWDF Gallium
I:th ?it nodul- May or mom-I1 Io nouns-lino.



PM oi Bimini:
Th4: purpose oflhh muslin; to discus: that have coming up. no who: I ?pool from you. You In Ih: unil Ion. unoth II Ill-I:on out other: in: dune wlool no uhouldb-c ml: to ovoid the was mulnku yourself. Esp-v1

DRINKING. The Eripoe. Bull-tin. Ind Conway but! inns: Ind problem mused by drinking. That is. minimal: NU TGLERAHCE ID
damning Il?you Ito undo: no. you WILL NOT drink under my commune?. ll'you In 2 I. you Wiu. NUT boy alcohol fox ?you: undo!
21. Additionay H'on In ml: no you momma mam: loMmummwM who is undo: 2! Incl they or two hon drinking you cloud
to luvs autumn could Ii" b: chuiedju? for ooin; more. Drinkmgud Drivlu locum: bqu In AW: and Ilythiu also you can drivc. not jun
cm. Them 1! Ibnolocoly no arm: for drinking lid divinl. There is Imus among: my to so; homo ?fair. Who: you drink Ind am: you out
yoursoll'uud moon I: risk.CI1 I ah or one your chin cream-mt Hoke sure you hm your ARRIVE ALIVE CARD II than.

DRUGS- Thr- iI Iholuu-Jy NO TOLERANCE oh; uoo. is not Iolontod to my cutout-.11le Iocoumud iho muimum pun is):th ifyou
com: up posing for drug no Tho-c I: IN my: pomhimy of mm Urinuyniu on DR lids. "you one I drug or noohoel probhol. mo?

ill ASAP

MJLEAGF. Tho Idiom Imhnlou I pus! is 75 ullu. Candi Ii of! 1mm WLHS you have room vod I. brief from 5-1 If you wont to
go outside onhis none. v01: MUST PUT IN A PASS REQUEST Ind lhqv' mus: ho to by COB on Wednesdny "you mm to uh: I. piss. no
for m: proper form: Ind-l willpt than: for you Whu'u you land in your pass must. you and o how I copy cryosu- soul: to whore you on going.
Von need to no to Irmy.mil and ?ll out Ibo rill: mom! unlim- Ind print I oopy ofmn [or m: 3 an,

SAFE SEX. "you deem to hm ms. mutt (If: you won I moon. 8: Hf: ifyou on him; us. You don't wool. and In STD "you In:
Iiollo. don?t I'm: us win somon: die"! spoon. perilous undomoot olhor duo. your spook iryoo?ro amid. This In: all

ml:qu to puiwnout moor new a i :11

Ilium: scam in upon in. you man to to hunting. you sum sol-I lhI hunter's ?fay noun: n?'crod by HWR Ind you MUST Law I
Iim. Wu ml:- to have ?menu-My II limos. May: on! your wupomu iru Ii lauded. Du homing Imh I buddy. w: don?t ncod Io Ion:
moon: to stupidity. Em
SPOUSF. ABUSE- Tho Anny In: I no calm ml; to do 1 Ioou: boning your wowyour :pouoo um you think you [01.155
to hit hot. mil: my. bro-duo. ml call your hudoy or amino mum-c youmlf from 1h: mum?. We can put you In. an: bunch: for 11:: night Ind you
can all: no the chm-m also out dry ifomrod 11m Include: you swam Ind you. a:

WREEKLESSJDANGEROUS ACTIVITIES- Tho BlIok River and Kings FIB: Ir: off limits. Only own: in wthorizod am: who? Ihcro is I Hun-rd
Ind with I way. Don't drink udswim. ll'you 1o ?who-rs. I13: I buddy - It limos.



OTHER Hlmuc'rlouo
This iarln all h: hwy-o upon: mum-uni {our loan mum hos-hm]. sepam?on II ETS. or upon rm. For moor-non



WI: Ind no?iu?on onou oI Ian banal dim 635-200.





wounoo

DA FORM 4356. Jun HIE somon or JUN :5 IS oasou'r:

Manningaj?m 3533





arm: (Mn: mush. Milt ?Md-owe: rm much-g .1me runand Inna-diam Human-aim sum-imam Dena-?Crate mun I mam! mm- mm herm and

mm!!me

.mmh

Danna-nu.

Danahl?l?w.

Im?ms?CmifyI-Ii-ulhuhl?u.
hn?tluumw.mum

mil-unwilling
uim



mun-dug: Th
memfwdu
mm: mm maume

mama.? Eradicy Mmm'ng an: :1 use on Bin



HIE-rum

war-am on: 11 DEC ml
2

me-mrwm?llm anew
nun?nu.- gamma-ammo.- dodud mall? mmit








:3me DIM cl MINI:





Ion: Both ?u unwound an Individual annual-d Ihnu? rat-In a (?on ??fth. oomllna.





mammau:m

1'

ManningB_00013834





DEVELOPMENTAL counsmue FORII
Formal ml. IooFu 12.100; 1M promo-um II TRADOC



RITA name: BYTHE 1914
Am: I U86- Rogulo?ono; USE ?13.3mm; of tho Arm and 5.0. HOT [555?
pmuwu ?mg: To not! In conduit I?d moron mum-ulna on: unlit-mg to
For what-ammo loldor Cardamom um PM 22400. Ll?ll'l mud uu um Iota to actually.









mums m:
DISCLOSURE: II Win.
PART I - ADMIITMTNI DATA
am Ina-mama Social Security Na. Doualme
Mailing. Bradley Prom: 15 JAN 09
0mm Home In! Tull cl
HHC. 2d mm MIN Fort Drum. NY 13602 836 late Ania, Senior lnto?iaencc Sago-om





PART I BACKGROUND INFORMATION
Pun-past oi Gmllog: (Loom! do!? Inc moan In: Ibo ammonium o4. or mm mung.
and {mu mo am has: Ind obs-?lial" pic to ammonia?



Even: Dn'ulcd Counanng FM MLK wmod WMLIIG
Clm?ilt locum duan orlmn?y In town-Inn.




The arms mm
paindllc??u tool luminous.qu up. um thI I upon: from you. You hove bow in Ibo uni! loo; mush II this
lulu} who: other: done wrong no should II: to world mom minute. roundf.

The Bullion. Ind have Ind ism no Fromm: nosed by anti". The." I: namely H0 TOLERAHEE
thinking mm. It you on not: on. you WILL NOT dn'nk under my ?remen. If you In you WILL NOT our Icon] in own?
1i. Additionally ?you on: ow: 11nd you ?nd younoll'io like an: locuioo o: moon: who is undo: 11nd they on or low Iron winking you load
In In" HAP. you could all II: chinoqu for och. than. Drinkhu Ind Dl'ivx'ng inotudu boots mdAW: no anything do: you can drive. nou'uIl
out. There is IhIoIme no Ion:qu drink; on! Nut", 113:: Is Ila-?y: mat-harm)! Io lukomenfoy. mm Mink and dive you put
mlfood other: It n?Ik. Call a ooh or your club ?comma. Muir: son: you on: your ARRIVE ALIVE CARD II tines. gm

DMJ 55-- There 1: Ibrahim)! NO TOLWCE Io drug on. II II not Iolaubd In any can: sad 1 will remand {brawn-um punishment il'ynu
cent up with: for drug on. The: I: Imus 1h: of 1m Uri-mph DO DRUGS. II?you In: I on. or Ikohol prowl-m. mu

'rourld?n ASAP. at

MILEAGE LIMTIS- mailpr limit-lion whom: I pus ?Hail: Coo-hi Iofrnuiu UNLESS you how remind I brief [mo 5411'on will In
go outlidl: anus range. You MUST PUT IN A PASS REQUEST out they own in by COB on wand-y. Hyou mm to who I pom. Is: In:
for pro-ya tom: Ind lwiugol Ihoo: rwyou. Who you hood In your pus ?out. you what: I copy oryour rum: to Wino you on. goingInmynil and ?ll on! the mt Income? mun: Ind pn?ol loopyorlhn for Inc. ?51

Hutu. onto our: you won- I modal. Boo-1': ?you It: ?ning on. You don't want or need an STD. If you on

SAFE SEX- lfrou lucid: to
of II. or I. mane olhor tho-yon: spouIe ifyou'ro nursed. Than on .11

unto. 4011 home so: with our: spoon. pun-II noon the
ninja 10W noon

HUNTING- Human: scum iupuo uI. 1 ?on wish to lo hunting. yo
limo. You and In hm: weapons Ilhty II In times. Mayo out you
Io Mai-If a

must are the mama's army mum orfucd by NIH. mom MUST have I
wupuu II it i: is IoIoco. Go homing will I buddy. No don't and to loot

SPOUSE Amy ha I on tomato rqu I autumn-1m: your spam. Ifyou no: so and :1 your spam um you IhIok you In going
to hit her, mil: my. Income. Ind all your buddy or Hymn-I team from the sin-Idea. We can put you in tho hunch: rm the ni ht Ind you



WRECKLESSIDAHGEKOUS Tb: Block Riva Ind King: Full: or: animus. Only swim in human-ind Iron who": 1hr: is I Hfoguld
mum-hwy. body-nuns?. Gem

um
amoral-mum'- M. sapora?m upon riser-mom. Fm nonunion

vouoinrlnonl
moo-nu. Ind noti?uIIon of km a! Wm no ml ulmadun Ind AR ass-zoo.









DA FORM 43?, JUN 15? EDITION OF JUN 85 IS OBSOLETE APO FIN 00

ManningBRODD?l 3585









M?m: mud-u
Wound




-
humus-r.

man-am. ?9945

mat-tum ?Er-1

humusmauuirmm-pm



9f!?

anwmwuwm?m



mm.- m-


WW 2 ham dawn-human?.

?ritual mailmafttg?m





Gin
mama-arm: PFCanty on: 15 MR up
Luann-pom
mum Intuit: Du: 15 1111109







rmw-m?_ alt-Em arm



wmmummumm: TM mam-day?


Duh-I'm



cm









Hm: Both ml cauru?u and th- lndhiduli muscled nhnuId I neon! of?u mum-?ns.





arm-inn:

ManningB_O?U13886



DEVELOPMENTAL COUNSELING FORM
For guru 22-100; In manual Wigwam:



DATA Reclaimuse am. Dunlde aluminum: in us: 301:. simian of Ill-Army and I: o. In? ism}











AUTHORITV:
PRINCIPAL FWOIE: To lunar: In murmur-a and naming cos-ruling duh lo "warn-In.
?ow? ?as; Fol 'ril?ur FM Tau-u. LlldI-rn Ihunld all Ill-ll I'm II nit-om
DWGLOSURE: [Malnu- 'll vainly-3.
DIRT I -ADHHIITHATIVE DATA
Hm Firlt. All} RandGr'adn Social - Dill nl? Cumming
Manning Bradley ?Iranian Name ant: Till-mm
ZBCT MTN DIV Fort Drum. NY 13502 550 Kyle Bllonulr, Strgunl





PART II - BACKGROUND INFORMTIGH



Pun-pun at Counseling: My yarn in mm Id: 0: warming. 19.. aar-?annamaWaa-m-r urn-will at uni-aim malls.
and mm: reader?s rm and null-Imam pair In ml mum-aim.)

Manny Comiiq [a Jul-rim:r



Ill - ill OF COUNSELIIU
[his unlin- ?rth] In inn-Idlle lulu-quill town-lulu.



Kq Paint- clam
PFC MIMI, this is your unalth counseling for 1h! lonlh ul?Jlnnanr. Th: kc)! will: of din-11min": wil be:

Umfm Ind App-cum: Continue to hep up with your warms Ind unlinue in look ahud a in will: you will need far Ilium: day I: wdl. A
few lime: you {and yourself-or hula; mandala 5 an: 1: ml bail; in the prop? place. You mm 1M: lo anew ll prior i: being Inward but ii
required you In [aka-W my? to 3:1 to II. Also. he pro-ultra drum groaning ?mud: lfynu mite: um yawn-i: is will; long and may he
perusal! lam ll cal. lfyou and I ridno muttering. axon afyartpecaar NCO: to get you mm.

Phylicll Frau: my paspcuivcym I: ?nd. maul: ll": lie APPT will: Sit-ups bum; 11ml nah mm. mli gin you
sent hauler album malacth you can do um willhelpln build um um to mamywmI-up count Continua pm rm madman

during nub- PT Is wall I: on yourm ?rst. ?rm

Hillary Burial; You Ilium-y bush; is nor lid. hum. I will offer an: um um would us: mun lupnm hr: mum 1hr II.
an bacon: ?u and or mun! when you henna-i: 'mloldcd? cr If! like: air Milli that you We main; It?s not uncommon but allure 1.1m
you hurdle in: I parades? numb]! not '11th ?mu lunch" 01? ?will; ii in lfrou Mancini-5 Iridium. you
an luins?u mull In DI if: NCO all: you In pt I Tin:

me: use Fact. button lane I: ?an [inn I ?reahe.,umlt. Bah

Job Pro?cimy' You hr: mild Hi. put in yanjnb ?hid mkinu. Building in Gunman Upd-Il: Bucl' uni Comma and Sui? 11ml
issulucrbin. Um will he um by this Brig-d: Ind Dublin: Comm-admit :5 ill: Brigade Surf. Thus fu- yna unites: premium Im
in?: but complain?! by af?om.? or the ?up. imp up on good wort Md i look run-um! to continue wining with 3m: m1er product: in the

Over-ll: You were proud? to Private Fim Clusmlnunlh and l?ad ll wuwdl In; um?un The nun-Mp will he Specialist mil
with Um mi: f?pmliblli?u Yul: will lug?: an a sprint: Ind will he I NOB in mini?, Om Ulcmrul
month: you will likely it looked far a uni-m la mama. Norton inn-win; on uh: ?discussed in?ll: marlin; Ind hn?l??l gun-lurk
dunk, ulhcnal lewd. lull-am loan-143ml:th Suldkr unknoth board in lb: wait; mm W:qu

impure for thin I: I tun Io mum Ilium u: pup-ad ml campatitiw when rim tine mu.

Kai: up good would



or?aluarnucnm
Thu rum: will he untrund upon: (outlaw-lull ram-mun Wat-w aim-l1. ?Furlth It ETE. or upon nil-rum. For mat-on



rnulrimnu aid marlin-?an ul In: in mum-Mum. Inc-J air-ulna and AH ans-29a







DA FORM ?55. JUN DF run I5 13 OBSOLETE

ManningB_00013887





.wm Samar lnfumcd at my In the lamina lehnduh.



Phi-Hula: immu?dmm ?ank-mqu Tum
mung-er hula-Haw mum-numme awn-mum and



dint ii? tum km [inn-ti.
4U I??l?lhl? :9 hp": Ill-Ia urinal-=3.
JH?lnui-nuklp?mmw Inn-annual?,

din-ii ruin ummwm Inn!



all-hum Th:

um Immune-1M4
mac-mm 1m


sun-?mum. a? "so

a:
MWH: mam magma-mum.)
-w1llxiw inm?on lm?mving?t upm.



?Hill provide 891:?: with shady min: for hearth

mum ?It 3?3 3n.?



FAITH-ml??lmaff??mn?rm
?may: Eldon Inna-am ?mar-tun? manna-(om: ammunth




nu'l a! Mum-at









Natl: Both an annular and Individqu ?amt-d about-d rut-1n a moi-II a! th- ?nailing.





mummy :umm







DEVELOPMENTAL COUNSELING
Fc af ram. 6-22: Ian-Icy I: 1 0c.



REQUJIRED BY THE OF 157-!















MTV: 5 use m. mam-um: Hamil-dam.- use 301:. hum of la- Arrny and 5.0. In? :ssu:
PRINCIPAL PuRPan: To nun hid-fl. in conducting and ?carding mun-lung unfailing to

ROME MES: For IUWU Iuddr div-lunar? MW FM 15-22. Luau Md nu man Tom mill?.

Birdw- II mummy.

PART - ADMNISTRAHVE mu
mm: (by. Pam. Ranxa'?rm social Steamy Ho Dun cred ruling
WING. BRADLEY E. PFC I as Q- f-?t ?ll 300??
Drama-Han Nam Ind Tm at Conn-Liar
HHC EBCT SPC JIHRLEAH W. SHOWMAN. TEAM LEADER
un?ru - BACKGROUND Imam





Purpose of counseling: (Mru?u tb- rlum m- my. want-04mm Wag. Md Mud?
in?ir's {odd and animated: prior to did Maudie-9)

Ina": ill-New Tn u: Loader
Duty ?pcruli??l Soldia explanations



PART - M7 GP mm IE
Cupid: 1.th Halon durin. dr Wilbur tuba-qua Ill 1: ?unsung.





My Foinu of Milan:

PFC Humid; lb: is u: rel-"ls to expend pyramid: dd uni dl?l'ducy I Suld hr amped In lb: JBCT 5?1:
Ynu will b: migrant-bl: rm uphoan ?u renninon guidmm palaiud within the.

- Menuhin Division Bin: Back. ilpl'l nf?ydu: ul?ilr nib-m.

- Th: ZBCT CQIIM Policies

- 1h: IIHC ZBCT Conan-Id Putin's

- Abiding by the ?dam of mu upped-twat" you (your

all was you uphold u: Amy?s Cum and Comic.

. Md?un. Six. Sex-[mt an: Ill which will be used thing?s.

Pun-dc la: and mum: will only be mu: In by the union You arm moda- uuse min :9 unbound: malt. you.

a You will comm-.1ny in a milky; upholding thawed Amy "in: of L-D-R-S-H-I-P

- Mum by simpl: [milks did will cut: you ml: nah? am It: my man].

. Undunud um null mm ?has and to lips: In one humanly dimidhhu the ran.

a ?u will Imp a up: lint drum-minia- with)!? laden-Hp II lilacs. {um 15H: Show-nu In your hm Linc

- You will mm: I: swam: with grouped: in Mr 15% gnawing midtown-dandy inform?: and upcoming
mm

a You will mm lo the upth plan army's: thorium line In! in the rim uniInm.

- taunt!? is no: Id Ilibi. and chow; hep open lid: of coma-?an to hand: quuinm val-h any doubt or confusion.

a You will a nil tune: minuin your arm. equpm, and prcyud dqsloy.

- A scum 15 I Wm: - swaminlc Ire Our
Miinry Ounplliom! Spud-Jig.

alumni Ii only as man; Ind will. the 543mm mun: u.

a Team an on individual um mm or I minim it I: I mums-d

- This is a hy- adapt-um to success which in ?plus the Ibo-er. Comic-lid: a Anny Wines

pro?cient in mum-min; you: Mu my may: from How pool Manda}: Command ud Stuff Brianrandy no uan: any union mod to 1m.
- Your duty dump-lion willnow and change with n?u'linn to wad? minim.
. lucrch 01' yaw duqr that: is no room Far 'checkinl the box' when an ?bj??I-t is

3 Your umivc amine. unmande i: hindrance to you Ovid-ID partial-nu: as it. my be him-rm; your rut aged: Ind hydmio:

impacting you: 0mm puma-nu.
a aninin?uin in nah-win; will?: In My: i: mud-lb

of Inning I ?Saldicr [malignant Analyst

Ic. anion no not hm: mom: vision md nan: 3m Imp the 9111::



OTHER
1m ion-n will upon.- rl?llm?l (our than run-wit? W). trillion It ITS. or upon Idiom-M. For sap-union
nadir-mt: and mliuh'un n! In: of WNWI an Inn! GWII Ind All ads-nan.







awn-Evita

DA FORH 4356, HAR 2M5 EDITION OF JUN II DHDLETE

ManningB?uom 3889



3.: in
WI: enough .l'o mn- uranium-I In: Win?: annular Indra-aha?- Ema In; :Nihlumn.? (PM Mm)

Stun mm.-

trap-on and mercicnry In all operan
a Consumption: 5 day.

0 Ha: Ha: rink at SPC

PU: 29? w. [7.59 mg!?
a an anti: hum-i 0 film; Cmuspundc? cc Cam?:

0 Connie.-

I)





Long um:
autumn Dunc.-

9 Min": Dam:
0
a





Sill-Hf! Wan: mu ?mamas than! Mr om:- nxuun and cm: the sum Midi-arms the ?u diction TM
gamma mm? mm: (spawn

me mu. Wu mh In- Ilium-?an

mam-dual cam-Incl run





Du: 90040?40?1





LIN-rhlm?ll?lh? {Did-?l mam-Mama: 1-1 mm plan radio-?
0 Keep the Soldier informed of dutin and responsibilities

0 B: gullible fol qucsuona

a Hold the Soldier to the Standard

0 Train the Soldier for upcoming even




Signllurl of mm;



- - LWWMAN um 325193?:
,2



PART IV A ASSESSMENT OF PLAN OF acmu



mm (Old rm gun It mien name In. ruswrs? This I: arm ?u louver nu! ma mum mum
and predates Hum arm-Inna 1hr blur-up mum-q.)

Cosme-Int. Baum-led Oslo or Autumn".







N010: Both the cuunaolor and the nouns-lad should "till! I record of the







REVERSE. DA ICE. ?ll, 2m r!

Manning BWUCICH 3390



DEVELOPMENTAL couuszun'n mar
Pu- ath?Ll??lt??hm?wh?l.


mm use 5.0 cal-{55m
mm mm Tannin mun: mammal?! mm In lamina?.
hum HHWIULWFHIQZ. MMmHIMnn-mm





















MI ?5?33
mm Iii-mun: I: Velma-1..
mu i .
?no that Hi. Human-m Tin an aim
mm aumav 1a. E3 01 gm :3
DEM
HHC 15:1 SPC :1er msnowmau. 11am Lawn
PART it Imam Emu?



Purpm Iran-Imam Man-tum run-num- cows-earn: whim-
MIWan-umln?rh?bmm

Em D?n?im
?desultpm-Whrm Amway Fur-nub





Fm "-me
Wummummh



Iii-Imam

fhm?linn
,9


- Yumd??mhm?mdumxkiunm.




. him-s

whammw?hm.
- Sap-nth mallard



5. ?Jim: Han-uln
?autumn-museum
night-Imth LIL-.1 H. alum
Cali.th unnatural-we M. Inna-inn?
my?. Irwin-inn? ?Emma-WW mWhWEHMu-n?lm Int:
mumps-Hunt Hm. urns-dwqu
?Mnmumwm
men-lithiuqu ldewIGI-a?nl Unit: Hmrih mum. UWWHM
Law. Wanda



mum
Tum-Elna..me umu?l.uwm Farm






#9 Find.?





DA FORE all. an: autumn OF In at mum







?maul-want:


Carmina ?It-inu-

Ynu?qulmnomniu tannin um Mutants-liade

:3 cm: waMkm
WIW?lr?hu-?.

- hum-Allie (H.



Mun-u: ??bl hid-rm?" midyde: afra- suaion and sham rm sum mm NW WW
d?mf?uw mum Emmy-um;

mun-an:
?mmra
DLEYEMANMNG Dill: 0?





magnum
I Infum ?ll Soll?lr ofthairdz?chey.

b. 0 Provide cumin Idling fur the Suldi?.

in Army]
9 ref{nu-amalga- amlu Hit damn-sub? m: ulnar-mam: WW
M.)

MIT NW mum-Ml; ml: u'l mum-nu







Hula: Both ?u count-Int and {In tndl?dunl :molod should min a mum at th- wumllnu.





amt". Fall an. ?u u: or gm

ManningB_UOU13892







DEVELOPMENTAL COUNSELING FORM
Forunol [m loan. on FM 3-12: propunonl IMII TRADDC



DATA THE MAW ACT OF

5 use :01. Rogulo?onl: 10 U51: 3011. Soul-w E0. 5397















AW:
PURPOSE: To null loader: In Mg and mourning consuming doll to Moron-Illa.
ROUTINE uses: For loan-r downturn-uni LILW Fill Load-rs would on oil- lon'rl run-marl.
DIN-loun- is voluntary.
PART I - ADMINISTRATIVE DATA
Nam rm. Firm, om meme b?i one ofCoLI-Inll?nn
BRADLEYE. lE3 -I- Eco? 04,93
Wm Name and Tm oi ammo:
SPC JIHRLEAH W. SHOWMAN. LEADER





PART II - EACKGROUMO IR FORMATION



in- leader?s fool: and phonon-ms prior to cumming.)

Performance Profom'onol Development
Motu Jun:

Purpoio of Cour-soul log: (Loader It?ll mo ?uun rormo mounting o. snow or IN



PART Ill summv Di: co?ssuno
Geno-loll. HI: noIIon or My ooh-uncut to soon-oan



K11 Polo-tin aluminium:

Bluc Book Euuro thou stun.de In thoroughly known.

and on?! do
- ?l'out dolly nation: In indium: ofyou' ulna. me your woman: Ind women?! go hood and hind

uni fill an my uninioo. Emir. maxim ill-mun mm radar-n.
. The annual is the Ann: Ii v: to uphold it

mil continuum Will'l you: pm in their Ilium so a to hop the non: tom informal! and fit to fight.
You: puforoumn [or the moth of Mo:-

mlinn: this pom tomato line rniumn Ind individual dllpuln'oo It talus-Iona.
. sohnol Ihm wore Ion: actuation: Ind con?icts.-

mono:
. This '5 duo moot hporunt one for momma and Noah. oonlni: than practices.

:r CON GRADULATIONS on you oucouu'u mpiuloo or your mining.

in This is aim-um in b: was oruo ?um: prior to it incoming owing inn-z

All!? [Willi you donionnl Won in mood.
Soot My Will mom tho dam-m Ind mom vol! I: mynodnoidocom

in nu: stud-Jo you lwill In required in Ill: you

ham) to ml: rule.

Tum will may: upl?l? omndmi. [I'm Ton Luna- nonhuman! you will and by until you: Tom mm;

PFC MANNING in: following is in mum: to your pufumooc fo: the month of Mg} I: well a your upon-lion: for It": moon: or June
A5 numbn- of: unit IBM to ma Mounuin Divloion you or: oxpl?ul Io mow. luv: and onion: 1h: mounds of the 1m- Mouomo DWIlj?l'l
a You Will condos: youmll'wilh military bum-g ooholiol It: Milton-nails Ind Array nluu in who: you", do.

You youmll?ulhymully no your equipment. yourskillo. no your pom-.1 drain to ma you or: My: raid)! to deploy

You will tag :1 open lino ofoomunimion will your Whip all lin?. You will know and use your Chain of Com appropruldy Von

- You: perfonnuoc through 1354: month of my in shown pin: since you: In: consoling. You hove moi-loom! on open line of communion.

:r Ensuri- you: no ow: oryou: ?moulding: um pronoun. it Hull: on: In?th Rombcr 1o conduct yawn" in o.

Your physical ?lm? 1! um I ugliness. You will ho dud-ind warts-01H. prom to condom amnion allow in o?moon how. in your in!

Your our-ll patron-mom: nu led you In bola] remand to coup-Lo II the MIng Sdnia of m: Month Bouo.
- Disciplioo is I mus: mining exercise all the high pron op-lnnpo. ?nm is onlyI going to incl-rm you: opportunities

Um: of room produm arm not he Ilium motion-l time hoyood routin- hula to In only from moh- job: no lob-coo mm [All 60041 pr 1
Turn Ludo-r ta million in ulna my snob bro-la during work hourswill: you There will



OTHER INSTRUCTIOIIB



This loam will on Unbound noon: moulli rum: in? )1anqu (rum. ?onion 1: ES. or upon moron-m. For Iom?m
inqule and nook-dim ol low of momma-noon no loul circum- and AR 635-200.





Do sass. MAR Eamon or JUN 99 I5 OBSOLETE

ManningB_0001 3393

HDFEIIW



A
In of M?u (Damn mm: mm: suntan: w?i do after me comm:er session met: m. lg: man you?). ?re swam ml?
Wm: mm: grandam MIMI banana: and m?ude I mm M: furlmp'muumon and Ian-um (PM Maw}





Shun term;
a Ind Pru?uicucy 11: Ill opemiou
Curran: . 02
0 Mute the rush
APFT- .1 RUN
In cram ham: or Amy Cumin-undue: Earn:
a Collage;

a Soldin will pup for upcoming Soldier of month baud


Eon. term.
I: Buchclurs

Mum: Dugnc.
a




Bunk-n Ola-Ina: (TM lander many-Ina the My punts of!? anon Jr rm: sum-norm: Underarm-m m- ore?! auction
Wm? tarnish-mm: rum: Imam-m.)

mammal mm rue 61m vulh ur- Inlumwlon than,
Individual martian-I l7



Smuhrcuflnmiduu Cumulut WY E. MANNING am: 3


Lust-r ?pendulum [Laws Minna-MM; mm mummy MI man or
0 Keep the Soldier iafmmed of duties and
a uvailnbb for questions
a Hold the Soldier In the
a Train 1h: Soldier Fur upcoming went:








Signalm- Uf Com: Daw-




OF THE PLAN OF mm"
{mamma- aflcnalucmlvo In unwed "sum? semen is by hour and mo imwu cum-Md
far Mint-aw mum-Eng)



Emma Individual undo-cl; Data or Ass-mnth







Nata: Both Iha counnlor and ?u Individual counnlod Ihouid raisin "cord of the counseling.





HARM mun-zoo

ManningB_DGU13894





COURIELIHG Fall'-

"minimum-m:



mamw?mmwm

m; mum]
"In" Iawmm-?mm-mhm .
mm Maul-inn-?
mm: man-ma



um umwu?mu







Mm. ?if rm m; barium?h;
mum-m m-
Wreath-I

HHC le'T. TN DIV 5 GT 1.1km P50



pm I -



Furna- anion-ml: Wand-wit?er
i?uc'uduwu?humutummuum?

1am Inn!



awn-mum

mi?
mum-r ltm?MMHh??o?d?

l?tjtt?l?km? .AV ATTEMPT TD (VI-lift HIE DIIUIS AND IS AN ATTF YOU
You in?ll.? WUQSTANIITIUKT van ENGAGE 1" FURTHER 0!
CONTINUES TO MAY Piotr-3359 1'0! rm: All!?
OF AI m-m. IF AWTWEI WARNID THE m. YW CGULDIECHWI: FROM

A WMOMAILH AND YOU SHOULD 'm
autumn. IIAL vulture IN Chm.th LIFE. IN mm. HAY IE HIE 113 ALI.
unanw LHDII Will VENIAL AND HAY Au?ll" IJ'I'Ill-ul
NOS-Whl'rl? HLASUIB.







mm
?animal mumm.an-wm Fur-m
?Inputs-w ?in??m mum-Hanna:





Han- Jill! 1m ormuu 030L515 0'

ManningB?ODm 3895







rump-n cum "nu-u- Jumlhn?w mun-r9 Illa-m 33-15:!
Mk??un?wmumimwnimoWH-MHMH

nun-?WNW:



h?ll?l??ff?

hum! lupin



Mnan mu "Min-0mm wiler Tn


mm If. may;an

?wt??l

.1

dem- .. 'j 1* In



Lunar run-an emu UPI 6' WJ
Eumht?unw him-"minimiin walk-Inn uten- II it in and: known.







maw?/ an.

2/



mun-1: rot-am: pm roman-acme I'm mm? HM maul-u Wear: hell-?ll! ?mw


ml! hm Mal-Am









this: Iota a. mum and In IMI ?will! shut-I mm I nut-d of In "Hauling.







m: an. aw nil

ManningB_DGO1 3895





EXHIBIT

DEPARTMENT OF THE ARMY
Headquarters and Headquarters Company. Second Brigade Combat Team
10?? Manntain Division {Light infantry)
FOB Hammer
APO. AE 09303

2] December 2(309

MEMOR ANQUM FOR RECORD

SUBJECT: Behavinur {3f SPC Bradley Manning

This highlights incidences of meats} instability in SPC Biadiey Manning. The
waits have extended ever a period {if manths preteding the unit?s deployment to 09-10.
His instability seams heightened since November. 3009? culminating in between
himscifand his supcwiscr on 2010300EC09 in the brigade can Fciencc roam.

2. Appmximaieiy :hrce months prior to our depleymeni. ei [he-r June at Juiy. 2009i SPC
Manning?s supervise: went :0 his mum 10 check on him missing morning formation. Upon
renunng his mom, the: supervimr mpiaincd a plan of cams-cave actieri. As I approached.
SPC Manning suddenly began screaming He clencheei his ?sts, his neck and
(13:25 bulged, and his faint: ca rimmed. He screamed three times, than stepped, caught his breath.
and himself. The rest ofthc day. Manning seemed to Function normally. that
lime, asked SPC Manning to voluntarily attend a evaluation. to which he azng
His supervisor arranged for the meeting and assured he anide in the place and time.

3. i decided SPC Manning should depioy given mangawer and he warned receptive to

possible therapy andmr medication. and suffered no athcr major uutbursts. To my knawiadge.

however. due to our depinjimem timelinc. SPC Manning only agenda: cue session, and no (in:
issued him mcdication. During this tima i had SP6 Manning visii his chaplain at feast once to
{cam coping skills fer anger and mess management

4. Omin- Soldiers have wimmed similar behaviour during other sm?zi wants: namciy
meiings addressing spmi?c shortcomings such as punctuality and of
The uuibursts seem more vialan the deeper we gt) inm that

5. 011 about i counscied SPC Manning the 1055 his roam key. The Mayor
Celt required the IGT issue a new kty. During the municiing, SPC Manning shaved a
chair and began yeEling about the session. itocii: SPC Manning nutsidi: and caimbd him down.
Earlier in the day, he rec:in a psskagc his father that. he obviously found :0 be an
unwelwme intrusion. SPC Manning has speaker: of a probiernatic rciationsisip with his famer due
in part in a physicaliy abusive skimmed. I assessed his outburst stmmed in part from the
siressarinduccd by father?s unwanted gift.

ManningB_DOU13362


Behaviour of SPC Manning

13 and ?20 DEC SPC Manning's him twice regarding
ponctuaiity. During the cocond counseling. SPC Manning become and began yelling on
at ices! three occasions, ?nally ?ipping a table: during a confrontation with two superiors.
Neither Soidicr bciicved 59C Manning the physical violence agcitiat them or himscif.
One Sciatic! SPC Manning, tintii he ccimod down. Wham icomod about the incident
that morning, i talked with him at length about this behaviour. ad vising him i would remove the
bolt from his weapon as a promotion. which I did. Additionally. I stated his behaviour could no:
be and that i would rather have a stable. unknowltzigcabic pcrfomct over his erratic. if
cizirripotmu:t bchaviotir. i gave him the option of voluntary or command-refute! to the. combat
51m; unit. He opted to voluntarily attmd contracting. During the: mum of tho day, 3553C
Manning visited sick call for neck pain from his cariicr confrontation, as well as
anxiety. The doctor piacod him on 24 hours quarters and a evaluation visit
for 2

A?'ct io??cptii with Manning. assess he is salvage-chic ifhe
recoich and actively participates in extensive therapy immediatciy [at ices! once
to twicc a week on an iodc?nitc basis). coupled with responsive evaluations.
medication and foiiow-up on dosages. Based on my iimitcd knowledge of SPC
Manning. i assess he suffers from acute po5t-traumatic stress disordcr developed during his
abusive chiidhood. may also suffer from a form of anxiety disorder. Ho statcs rcguintiy he
bciicvcs he is a success despite Frequent comments to him regaxding his as an
intciligmcc attaiyst. I regulariy see him outside his quot-tics during off-time when he should he
ciao-ping. He reports it is aimom impossible for him to sloop doc to anxiety regarding reporting
iatc to work.

3. SPC Manning stated repeatedly that he deco not feel he has any problems. and therapy Wit! bc
ofiittic to no voice. He stated he trusts virtualiy no therapists. and scams to fcci disdain for
them. Ho is guarde? certain impacts ofhis private iifc. and
compartmentalich what information he will and no: share with others. Wizat he does not
Sham scents to add a signi?cant amount of internal and anxiety for Manning. H:
ms to be a cangiomerctioo of ambition. and deep-scated insecurity.

9. Tito point of contact for this memorandum ES the undersigned. at I



E, 1w ?:uw-M

PAUL ADHERE
MSG. USA.
Master Sergeant

ManningB_DDU13353

DEPARTMENT OF THE ARMY
Headquarters and Headquarters Company. Secnnd Brigade Combat Team
it)? Mountain Division (Light infantry}
FOB Hammer
APO. AE 09308

36 APR 09

EMORA NDUM FOR RECGR

SUBJECT T: Recent Behaviour of SPC Bradtey Manning

t. This additional memorandum supports a 2} DEC MFR. and highlights continued
innidennes of mental instability in SFC Bradley Manning. The events have reemcrgud and
intensi?ed over a period of two weeks. Hi5 instability seems heightmed since midPAprii 2610.
culminating in ?'equent catatonic periods and claims of dissoczation

2. Manning has exhibited bizarre behaviour. stepping in mid-sentence dining
conversations. giving blank states when Spoken to. and similar behaviour. which has increased in
frequency and intensity. This problem gives an impression nf disrespect and to his
noncommissioned of?cers and of?cers.

3. Additionally. Manning has reported an altered or dissociated state
recently. This state gives him the impression of watching himself an a screen, as though events
around him. and pertaining to him. are not actually occurring TG-hirn but someone
else

4. SPC Manning has reported having no sense of time and frequentiy ?nds himself in a
dreamlike state. He claims this issue resulted in late reporting to his place of duty on 26 APR it}.

5. His of?ces report hint to be distant and distracted at best. His duty
competence does not seem to be signi?cantly affeeted. He sometimes produces accurate
products in a timely manner. Other days his performance is signi?cantly degraded. We are
unsure at this time if he presents a threat to himself. though he does not seem to be in danger
merrily in my cstirnnticn. His inatnbility is a constant of concern. however, due in its

inherently fluid nature.

6. Manning seen-is tn create internal pressure due to unnamed conflicts he seems unwitting
tn discuss. and incapable of handling by himself. tannin-tended he see CH Howell on
25 APR :0 to set: if the chaplain could provide cnping skills (it an avenue for discussmn
net previously explored.

ManningB_00013364


SUBJECT: Recent Behaviour Bradiey Manning

7. These issues seem to arise in clusters due :0 internal pressures. SPC Manning retreated {be
same as other Soidiers in the section.

8 arr: with dissociative identity discrder. and sametirnes sense the presence efaitered
personaiities during SPC Manning?s unsettled periods of behaviour. By seif~admissiem he
experienced a :ess-thsn-ideai ehiidhood and abandonmenmwe situations. I do not assess at this
time the: SPC Manning?s behaviour is Spurieus but 0f?! deeper medieai eonditien
1111an a: this time. My ceneem is that Manning?s mndition is deteriorating and possibly
becoming detrimental 10 the good order of the unit. if requireri in PCS. i fear the remit would be
fer SPC Manning. including M1 action and a chapter under conditions ether~thari
honorable. eteeiera.

9. SPC Manning cantirrues ?0 report ihe therapy he receives is unpr?ductive with the dealer's
discussiens and therapeutic approaches efnc value. He sent me an email on 24455 APR i0,
which he later claimed he tried to recs-1E. in Summary. Manning stated the problem is
longstanding; deep?seated and intensifying desirile his best efforts to the contrary. He eieims his
life and mnerionaiily is: extremely degraded due to his prebiems. He fears his enly help lies in
discipiinary action and possibiy chapter. He repairs dif?culty in sieeping. concentrating. Hiking
with when.

10 The point ofcontaet for this memoremi arr: is the undersignedi

ADKINS
MSG. USA
Master Sergeani

ManningB_ODU?l 3355

DEPARTMENT OF THE ARMY
Headquarters and Headquach Company. Second Brigade Combat Team
10"" Mountain Divisian itighi Infantry)
FOE Hammer
APB. ME. 093%

MAY EU

MEMORANDUM FOR RECORD

SUBJECT: Recent Behaviour of Bradley Manning

1. This additional memorandum Siippiirts Zi QEE {19 and APR 10 MFRS. and highiights
cantiriued incidences of meats? instabit'iiy Smitty Manning.

2. On SPC Manning ic? the work ares during a unit infurmai meal. I attributed
his absence to discomfort With some 9f his cowcrkers. and assmned he moved to another work
arta in order not to partitipate in the ?mt?tion. Abuut an hour iattr. a Sohiier infurmcd ma SPC
Manning was sitting (in the of a storage m?m in a fetal

3_ When i uttered the room. SPC Manning was sitting upright with his knew tucked up towards
his chin. ohvinusiy agitatcid about something. Hi: clutched his hand as thnugh in pain. He
cicnched his eyes shut and said naming I noticed beside him is {hiding chair with cut marks an
the padded seat. and an 0pm gerber knife triad: at SPC Manning?s feet. Severn-.1 pints; of Cut
vinyl 33y min}. 011 the scat he: inched with the blade the words. ?i During the
caurse 0f the convarsationi I ?etuminad he was not in immndiate danger of cutting himseii'. He:

stated he did at}! knew whyhe etched these wards

4. Through repeated questions. i was able to get SPC Manning to respond. He then spoke at
length about issws. Ht: stamd he felt he was mt there, and was not a pmon- He: stated
he had m3 persenality. He went at: It) expiain that the aim parser: who was speaking was a
pawnality of the. pagan sitting on the ?oor in ohvicaus pain. tie the anaiogy
of him being a turtle with a care personality. and swam? layers of hardenw shell. ?agmmted
and designed to protect the: core parsanatity. and function in different situations as the need
requimd Hi.- aim drew the anaiagy ofhis personaiitits being (trauma.

5. Manning receittiy suffered a recent brcaivup with 3 12105:: friend the Emma. This
situation has caused him ccnsiderabie distress. hath personally and concerning semi: ofhis
property be stored with ihz?s individuai for safekecping.

EPIC Manning ?uczuated during the canversation bem'ee-n a cairn individual and one in pain
As he spoke he sacmtd to he unhapgy with what he raveaioti, and withdrew back to the state in

ManningB_ODO13366

..--I


SUBEECT: Behaviour of?S?? Bradiey Manning

which I {Quad him. After about an hour. i was called to work and had is have SPC Manning. i
checked in: hem Eater He seemed t9 bc calm and I ic? me do other wcrk.

3 comidercd during the canvarsation whether to ahead Manning hi5 22mm". 23111 decide?
he seemed ta rccovt: suf?cimtiy to finish zhe 1&5: {am hours efh?s shift. Late: in the Evening
SPC Manning Struck Shewman in $23: face: during an argument.

8. A?crhis discussion with CPT Wursiay. ensqu hf: wen! :0 his mom withcut weapon. We
spoke at length ahmn his chiidhmd and masons forjoin'mg the Army. ?e alse stated he had nu
intenti?? cfst?king SPC and had no idea why he did it. He then Stated he: may have
rammed as perceived ?ights de?iz?vercd by SPC Showman prior to Sinking her. He also
expressmi signi?cam comm-n ofhis actions. inctuding UCMJ and 0TH
discharge. He staae?- aha: extra duty might cause: further aggravaiion. He. 33:1th this in a matter
of fact mam?2?, no: threatening. He aEso expressed wnacm as. to where he wnuid war}: in the
mining days. mid ham nothing had ham decided a: :h?s point but my dtsire was {a see: he
rest-Wad proper Ezeauncnt far has He returned to his ara?ier at appr?ximafely


The paint cf contact. far this: mmnerandum is {hit under?ignai Eli?I

\v
5/


PAC-L
{5833.

Master Sea-gems

ManningB_DDU13367

EXHIBIT

AR 15?6 Report

Compromise of Classified Information to Wikiieaks

DATE: 30 June 2009
PAGES: 2
FORM: SF 600
SUMMARY:

Recommended to Behavioral Heaith at Fort Drum by NCOIC. Session for 60
minutes and released without limitations.

ManningB_OOD14069



Tam-piggy"

Ema?momma}: CAKE

Patient MANNING. BRADLEY EDWARD 03:27.10 Jun 2009 1315 EDT App! 'lype. SPEC
Treatment Faaluar. GUTHRJE AHC CLINIC vaider HESWEBER.PETER
Oldpatient

MA RADLEY HJWA DIM-1 5'3395131
Rank PRIVATE FIRRT CLASS

Hull. FHA

Help! Rut Rm. RECORDS 3003-1941 STUDENT CLINIC


Tn' PVCM:
?Emil?! OF MEDICAL STANDARD Elli?Ii] .
ION 1'5 BY THE PRIVACY ACT 1931 Prisrrihed (SS-A Ind
[l THES INFORMAUUK [h :1 VIDJTEON DIJ FEDERAL. HE. PRUSECUTED

'h







EA 1,1131ng CHBQEOLOG REICQEQQLMEDIQL CABL

Jun 20091253
Flti'iijr.? Fl Drum NY Clinic: Fifth-lion Clinic Prm'idc'r: RESWEBEH.










MANNING, ELM-AH
Hunk CLASS
UHIL.
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cu . .. . Am?:
"airs rm; unwacvm'r urmumoarzun ACCESS mum-bu: cat-urn IEMR

HS 1 IBM A CF FEDERAL 1 .AW VHF. Wll..l. m; PROSECLTED Hl



AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 19 August 2009
PAGES: 2
FORM: SF 600
SUMMARY:

Walk in at Behavioral Health at Fort Drum. Session for 20?30 minutes and
released without limitations.

ManningB_OOD14072



qty-23.114 REFURD

RECORD 0F MEDICAL egg

Patient MANNING. BRADLEY EDWARD Date 19 Aug 20GB 1006 EDT

Treatmen'. facihty. GUTHFIIE AHC Climc: CUNIC
Patient Siam: Outpali-anl

Appl Type EST
F'mwdar. DEHERRERAMENHETH

Smsur-?SSN MANNING, BRADLEY
Rank PRIVATE FIRST CLASS

'lJrL ll W?C?lPilh

0mm Rm RECORDS STUDENT


r9
Hu'oI-m or 11mm. CAME sunlan FORM GOD (HEY. 5.1
HHS 105- IF. lH1-.' ACT um WI i'mniln-d #3:?er Ind If?th
r0 nus IS A Dr LAW viommns WILL BE mm







RECORD RECORD OF Mr?qa?ma









MANNING. BRADLEY
Hunk? FIRST CLASS

L?mt
Ouupn?cc Hm' RECORDS





PCM:
Tcl__
I E. RECORD OF FARE 3.1 .LMMRIJ FORM 60!] (HI-1V.
Hus EMHRMA 1 ILIN 1H IE3 THE PRIVACY ACT OF UNnLiTl?jmzt-rn full-'55 i'rHcrihHl tax-3.x m1
TC THIS :5 or FEDERAL LAW wommns WILL BE ?ii-?R

1r. ..,

ManningB_UUD14074

AR 15?6 Report

Compromise of Classified Information to Wikileaks

DATE: 15 September 2009
PAGES: 2
FORM: SF 500
SUMMARY:

Appointment at Behavioral Health at Fort Drum. Session for 55 minutes and
released without limitations.

ManningB_00014075





CHRONULOGICAL

Patient: MANNING, EDWARD Date: 15 2009 GEM EDT

Tiaalman: Family. GUTHRIE AHC CLINIC
Patient Status.- Oulpa?ent

App! Tyne: SPEC
Provider



5pm: :5er MANNING. anmEv
Rank FRI "(Kl?if HRST CLASS
up" PEA
Hum: m. Rm: RECORDS 3111mm CLINIC

m. PCM
RECORD MEDICAL FARE. STAMMHLI FORM mower s:
Hus :5 :1 Rn rm "rm; PR1 vars? ACT or 1-91: sin-1mm cm "a mu:
.?Cr nus If: VIOLATION 0r Law neurons WILL BE PRCISFICIJTEE. FIRW HI f'FRi





Ram?m



INFORMATION ?r??tl?'l'hC'TFD THE PRIVACY ACT OF i974
1 ifih A OF FEDERAL LAW. VIOLATDRS BE

ManningE_OGO14U??

A





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Rank

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Tel. PCM:


FIRST CMES



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FIRMR HI

AR 15-6 Report

Compromise of Classi?ed Information to Wikileaks

DATE: 23 September 2009
PAGES: 2
FORM: SF 600
SU MMARY:

Appointment at Behavioral Health at Fort Drum. Session for 60 minutes and
released without limitations.

ManningB_00014G?B





RECORD or EDICAL (ARE.

Patient MANNING. BRADLEY EDWARD Date. 23 Sap 21309 1001!] EDT App! Type EST
Twatmem Facilny: GUTHRIE AHC Chm: CLINIC Prev-?den
Pailent Status Outpatient

Spunmr?iSN: MANNING. BRADLEY
Rank PRIVATE CLASS

mu

Outpl Rec Rm: RECORDS




tPLv?diW} ACCESS Pruitt-flanDERALLAW VIOLATDHS WILL BE PRUSECU HI

0-:





EA LTH RECON



CIIRONOLOGICAL RECORD OF



SmnaurISSN: BRADLEY

Hunk FRI FIRST {1.41.511

Hm:

'J'Ulpl Rec. Hm RECORDS
pm-

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REC MEDICAL CARE. STANDARD FORM buu (REV. IN
THIS [3 PRO Et'Ti-? HY THF PRIVACY 191-1 UNAUTHORIZED ACCESS b30514 Ird
THIS DP FEDERAL LAW. CF50 ml-JiM?



s. AR 15-6 Report

Compromise of Classi?ed Information to Wikileaks

DATE: 29 September 2009
PAGES: 2
FORM: SF 600
SUMMARY:

Appointment at Behavioral Health at Fort Drum. Session for 60 minutes and
released without limitations.

ManningB_OOD14031





Ci?DNOL-ogge ric??j?iilicih?hi?

Palienl: MANNING. BRADLEY EDWARD
Trealmani Facihly' GUTHRJE
Patient Slams: Outpatient

Date 15 Sup 2009 DQUD EDT
Crime; CLINIC

Spunwr?SSN-
Raul..-

Llnil

Duml Rec. Rm:

FEM:

Appl Type EST
pTD-Ja?el' GRETSCH.JOSEPH

MANNING. BRADLFY EDWAR
CLASS





M.

RECORD OF MEDICAL CARE

THIS INFORMATHLIN I5 PROTECTED Hf THE PRIVACY ACI FEDERHL LAW WDLATCRS .

ManningBrUOU?l 4082

mm.an GDIHREL 5;
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Tl IIS INFORMATION lb PRU [13' THE PRIVACY ACT I974 UNAUTHORIZED ACCESS
TIT) THIS :5 UF FEDERAL LAW. Vl?ll? TORS WILL BF

MANNING. Emmi?
PRIVATE FIRST



RECUNUS


I?rm?bcd by USA and
Im?usrrs

AR 15-6 Report

Compromise of Classi?ed Information to Wikileaks

DATE: 21 December 2009
PAGES: 2
FORM: MFR
SUMMARY:

Written by MSG Paul Adkins at FOB Hammer. Recommends he visit Combat
Stress Clinic given his behavior and mental instability.

ManningB__DDG?i 4084





DEPARTMENT OF THE
Headquarters and Headquarters Company, Second Brigade Combat Team
10'11 Mountain Division (Light Infantry)
FOB Hammer
APO, Mi 09308

AFZS-LFJ 21 December 2009

MEMORANDUM FOR RECORD

SUBJECT: Behaviour of SPC Bradley Manning

1. This mei'norandum highlights incidences of mental instability in SPC Bradley Manning. The
events have extended over a period of months preceding the unit?s deployment to OIF 09-10.
His instability seems heightened since November, 2009, culminating in a confrontation between
himself and his supervisor on 201030DEC09 in the brigade 82 conference room.

2. Approximately three months prior to our deployment, either June or July, 2009, SPC
Manning?s supervisor went to his room to check on him missing morning formation. Upon
returning from his room, the supervisor explained a plan of corrective action. As I approached,
SPC Manning suddenly began screaming uncontrollably. He clenched his ?sts, his neck and
eyes bulged, and his face contorted. He screamed three times, then stopped, caught his breath,
and collected himscli The rest of the day, SPC Manning seemed to function normally. At that
time, I asked SPC Manning to voluntarily attend a evaluation, to which he agreed.
His supervisor arranged for the meeting and ensured he arrived at the proper place and time.

3. I decided SPC Manning should deploy given manpower issues, and he scorned receptive to
possible therapy andfor medication, and sulfered no other major outbursts. To my lmowledge,
however, due to our deployment timeline, SPC Manning only attended one session, and no one
issued him medication. During this time, I had SPC Manning visit his chaplain at least once to
learn cuping skills for anger and stress managemenL

4. Other Soldiers have witnessed similar behaviour during other events, namely
counselings addressing speci?c shortcomings such as punctuality and accountability of
equipment. The outbursts seem more violent the deeper we go into the deployment.

5. On about I counseled SPC Manning on the loss of his room key. The Mayor
Cell required the DA4356 IOT issue a new key. During the counseling, SPC Manning shoved a
chair and began yelling about the session. I took SPC Manning outside and calmed him down.
Earlier in the day, he received a package ?'orn his father that he obviously found to he an
unwelcome intrusion. SPC Manning has spoken of a problematic relationship with his father due
in part to a physically abusive childhood. 1 assessed his outburst stenuned in part ?rom the
stressor induced by his father?s unwanted gift.

ManningB_00014085





AFZS-LF-I
SUBJECT: Behaviour of SPC Bradley Manning

6. Between 18 and 20 DEC 09, SPC Manning?s supervisor counseled him twice regarding
punctuality. During the second counseling, SPC Manning became ?nious and began yelling on
at least three occasions, ?nally ?ipping a table during a confrontation with two superiors.
Neither Soldier believed SPC Manning directed the physical violence against them or himself.
One Soldier restrained SPC Manning until he calmed down. When I learned about the incident
that rooming, I talked with him at length about this behaviour, advising him I would remove the
bolt from his weapon as a precaution, which I did. Additionally, I stated his behaviour could not
be tolerated, and that I would rather have a stable, unknowledgeahle peafonner over his erratic, if
competent, behaviour. I gave him the option of voluntary or command-referral to the combat
stress unit. He opted to voluntarily attend counseling. During the coins: of the day, SPC
Manning visited sick call for neck pain stemming from his earlier confrontation, as well as
anxiety. The doctor placed him on 24 hours quarters and schedqu a evaluation visit

for 210300DEC09.

7. After several conversations with SPC Manning, I assess he is salvageable if he
receives and actively participates in extensive therapy (at least once
to twice a week on an inde?nite basis}, coupled with responsive evaluations,
medication and follow?up adjustments on dosages. Based on my limited knowledge of SPC
Manning, I assess he suffers thorn acute post-traumatic stress disorder developed during his
abusive childhood. He may also suffer ?our a form of anxiety disorder. He states regularly he
never believes he is a success despite frequent comments to him regarding his competence as an
intelligence analyst. I regularly see him outside his quarters during off-time wh he should be
sleeping. He reports it is almoSI impossible for him to sleep due to anxiety regarding reporting
late to work.

8. SPC Manning stated repeatedly that he does not feel he has any problems, and therapy will be
oflittle to no value He stated he trusts virtually no therapists, and seems to feel disdain for
them. He is extremely guarded concerning certain aspects of his private life, and
compartmentalizes what information he will and will not share with others. What he does not
share seems to add a signi?cant mount of internal pressure and anxiety for SPC Manning. He
seems to be a conglomeraticn of ambition, egression and deep?seated insecurity.

orandum is the undersigned, a?


PAUL DAVID ADKINS
MSG, USA
Master Sergeant




ManningB_00014086



AR 15-6 Report

Compromise of Classi?ed Information to Wikileaks

DATE: 24 December 2009
PAGES: 2
FORM: SF 600
SUMMARY:

Command-directed evaluation at Combat Stress Clinic at FOB Hammer.
evaluation and released without limitations.

ManningB_00014087



JEF-w'ti EEC: BIL

9r 503m 1. Mm

Patiem BRADLEY Due. 24 DEC 2009 1799 AST
Facility Clinic: CUM EAT STRESS Clinic}


AppITypc: RUUTN
Frau-idea LEIBMAN. MARTIN

Smnwu??iN EDWAR
Rank PRIVATE FIRST CLABB
1er.
Uulpl Rte Rm RECOHDE
FEM:
Tel
REC I1 l- Diff-U. CARE . TANDARD FORM ?ll} (REV. 5!
THIS If: BY THE PHVACY ACTCIF ACCESS

Prmrihrd by CEA and 111'. ME
TO THIS HUN :5 fl. OF FEDERAL LAW WILL HF FIR-HR HI 10'45-535

ru?lanningBJUUfH 4088



RECORD 7'
LI Dec 1009 IBM

CHROHOLOCICAL





MANNING
Rank PRIVATF FIRST CLASS
Uni!

Wl? CD

Uutpl Rec. Rm- RECORDS ROOM-MI STUDENI





PPM.
'Icl PCM
(ARE STANDARD FORM PRQVACY OF LINAU ACCESS Pf?rril?ard b; GSA um! ICMR
[0 THIS IS A. VIOLATION CF LAW 1 5R5 WILL HF.

FTFH-IR HI (TR 10545?505

ManningB_00014089

AR 15-6 Report

Compromise of Classi?ed Information to Wikileaks

DATE: 25 December 2009
PAGES: 2
FORM: MEDCOM 4038
SUMMARY:

Report of Mental Status Exam. Meets retention requirements but needs further
examination.

ManningB_UOD1l4090





REPORT OF BEHAVIORAL HEALTH EVALUATION

For as: ofthil Form. MEDCOM 4043; The In may is MEDCOM
NAME: MANNING. BRADLEY GRADE: E4

REASON FOR BH EVALUATION

ManningEi-_ODU14DQ1



ManningB_OGD14092



AR 15?6 Report

Compromise of Classified Information to Wikileaks

DATE: 30 December 2009
PAGES: 2
FORM: SF 600
SUMMARY:

Seen as a referral from previous provider at Combat Stress Clinic at FOB Hammer.
Released without limitation with foilow up in one week.





am}.



Patient: HANMNG. BRADLEY Dale: Dec 2009 1541 App: Type: HDUTN
Facililgpl WSFSAI Cuntc. COMBAT STRESS Provider WORSLEY. MICHAEL


MANNING, BRADLEY
flan}. FIRST CLASS


(Jutpl?cc Flu]


TelSTAVUAHCI I-EJHM
IHIS .5 paunztnan Lw nus. ACT or NH {'le Prmribed um mm:
HHS 7101-; I5 CJF FEDERAL LAW WILL uL-l PROSECUTED HI

Man ningB?OW 4094





HEALTH

?Jll Dec 2009 16-11
Fuilir}

ManningB_00014095

{'linh?t [hum


WSFSAI

CHRONOLOGICAL RECORD OF 5112:3125}, mm:

htilzr I?m-rider







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THIS IS 57.23 RY THE: PRIVAFY Arr WE- IGM #3579] ACCESS
r5 A UF FEDERAL LAW VIOLA. WIJ. BE


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TEI.

MANNING. BRADLEY
CLASS



RECORDS ROOM-MI STUDENT CLINIC

FORM {ulr? IREV.
I?ru-crilrdn} USA and


AR 15?5 Report

Compromise of Classi?ed Information to Wikileaks

DATE: 6 January 2010
PAGES: 1
FORM: SF 600
SUMMARY:

Appointment at Combat Stress Clinic at FOB Hammer. Released without
limitations with follow-up in one week.

ManningB_DUU14096





{135mm Rlagonn i CHRONOLOGICAL RECORD OF MEDICAL CA RE

Patient: MANNING, BRADLEY

[3313205 Jan 201? 1613 AST
Facilrly:

RDUTN
Clinic; COMBAT STRESS Clinic Provider: MICH AEL


N51 BRAD LE I1 5939'
Ran PRIVA TE IRET

Ur. rz

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Tel FCM:

STANDARD FORM ?uu mews;
THIS WFORMATION IS PROTECTED BYTHE PRIVACY UNAUTHORIZED ACCESS

Prestrila-l-d by USA. Ind
if. A VIOLATICINOF FEDERALLAW. WILL BE PROSECUTED.

FIHMH (fl-'51

n.

Man



AR 15?6 Report

Compromise of Classified Information to Wikileaks

DATE: 16 February 2010
PAGES: 1
FORM: SF 600
SUMMARY:

Appointment at Combat Stress Ciinic at FOB Hammer. Released without
Iimitations with follow-up in two weeks.









HEALTH RLCORQ



WSFSAI

Patient. MANNING, BRADLEY



Ti ?5 INFURMA FICN IS PROTECTED BY 1 HE PRIVACY ACT 570}.
TU '75 EM IS VIOLATION 0F FEDERAL LAW WILL BF

ManningB_OOD14099

RECORD MHHII

HRONOLOGICAL RECORD

Date. 16 Feb 2019 1506 AST
Chm: COMBAT STRESS CIinlc


App! Type: ROUTH
P'Gvidar WORSLEY. MICHAEL





5nomm?SSN
Rank

Hull.

Hull}! Rut: Rm


Tc'

BRADLEY
FE FIRST CLASS



RECORDS CLINIC


l?rm?btd by USA End
FIRMR HI Ill-(uni

t. AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 2 March 2010
PAGES: 1
FORM: SF 600
SUMMARY:

Appointment at Combat Stress Clinic at FOB Hammer. Released without
limitations with follow-up in two weeks.

ManningB_00014100





CH m:m0u?u?:1m yggconng?l DICAL RE

Patren! MANNING. BRADLEY 0519.. 02 Ha: 201131356 AST
Faciily WSFSAI

ROUTN
Elli-11c. COMBAT STRESS Clinic Provider: WORSLEY, MICHAEL


3;;10'1 Siva-V5151? MAHNSHEJ, rm. EDWA
?ank
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UH 71V rm. PRIVACY 19M IN ACCESS 9'5!le MR
Ti} Ilfl? IS A VIDIATJDN OT- FEDFRM 1 AW VIULATORH WIH BF. PROHFCUTED Hi




AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 16 March 2010
PAGES: 1
FORM: SF 600
SUMMARY:

Appointment at Combat Stress Clinic at FOB Hammer. Released without
limitations with follow-up in one week.

ManningB_DDO' 4102





?gcogp

CHRONOLOGICAL u?



Pahent' MANNING. BRADLEY Dale. 16 Mat 2010 150? AST App: Type ROUTN
Faci?ly Clinic. CUHBAT STRESS Clinic Provider: WORSLEY. MICHAEL


BRAD: FY
Hank PRIVATE FIRST (1:155

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RECORD OF

AHMED FORM Mil (RI-ix
uv THE 01- vm min-511m mum-:5 M'st mm:
THIS [NI-(mm TIOH vuuquow or FEDERAL LAW mu. m: FRI 353-15





AR 15-6 Report

Compromise of Classi?ed Information to Wikiiea ks

DATE: 23 March 2010
PAGES: 1
FORM: SF 600
SUMMARY:

Appointment at Combat Stress Clinic at FOB Hammer. Released without
limitations with follow-up in one week.

ManningEi_?O?1410d





HEQOKD CHRONOLOGICAL RECORD OF
Pam-n. MANNING. BRADLEY Dale 1.3 Mar 20101453 Appt Type? ROUTE
Faciin WEFSAI Clint: COMBAT STRESS Clinic Draw-lam: WOHSLEY. MICHAEL






MANNING BRADLEY
Rank PRIVATE FIRE

Unn'

Uuipl Hm HTL TUI-LNT



PC31-

AL a?cmm (REV. 53
mi}, mm Tr THE-I PRIVACY OF 1:74 Prbniba! h: GSA and ?Mn

Ii.) I HZS l3 A 0? WULATURS ?111.55: PHD-IF HI (FRI Iii-45.505

ManningB_UUO14105

AR 15?6 Report

Compromise of Classified Information to Wikileaks

DATE: 30 March 2010
PAGES: 1
FORM: SF 600
SUMMARY:

Appointment at Combat Stress Clinic at FOB Hammer. Released without
limitations with follow-up in one week.

ManningB_DDOi41i}5









Lj?HF?fgl?) RECOQQ or'??nic? CARE
Palienl: MANNING, BRADLEY Dale. 30 Mar 20101604 AST App! Type. ROUTN
Facility WSFSAI cum:- COMBAT STRESS Clinic Provider. WURSLET. MICHAEL
(HAMMER)





MANNING. BRADLEY 5939Silnl





Rank PRIVATE FIRST CLASS

[mm Ru Rm Rtme-MI F: RIDE-NT CLINIC
PCM
1c! PCM
mama? . "Mu. . (.mmEv. 5]
THIS PROTECTED BY THE ACTOF W74 (PLJEI-STW UNAUTHURIZED I?mhhed hr GSA mu

H515 OF LAW VIOLATURS WILL 33F. Hi

A a



00337



INSTRUCTIONS FOR PREPARING AND ARRANGING RECORD OF TRIAL





USE OF FORM Use this form and MOM, 1984,
Appendix 14, will be used by the trial counsel and
the reporter as a guide to the preparation of the
record of trial in general and special court?martial
cases in which a verbatim record is prepared. Air
Force uses this form and departmental
instructions as a guide to the preparation of the
record of trial in general and special court?martial
cases in which a summarized record is authorized.
Army and Navy use DD Form 491 for records of
trial in general and special court?martial cases in
which a summarized record is authorized.
lnapplicable words of the printed text will be
deleted.

COPIES See MOM, 1984, RCM 1103(g). The
convening authority may direct the preparation of
additional copies.

ARRANGEMENT When forwarded to the
appropriate Judge Advocate General or for judge
advocate review pursuant to Article 64(a), the
record will be arranged and bound with allied
papers in the sequence indicated below. Trial
counsel is responsible for arranging the record as
indicated, except that items 6, 7, and 15e will be
inserted by the convening or reviewing authority,
as appropriate, and items 10 and 14 will be
inserted by either trial counsel or the convening or
reviewing authority, whichever has custody of
them.

1. Front cover and inside front cover (chronology
sheet) of DD Form 490.

2. Judge advocate's review pursuant to Article
64(a), if any.

3. Request of accused for appellate defense
counsel, or waiver/withdrawal of appellate rights,
if applicable.

4. Briefs of counsel submitted after trial, if any
(Article

5. DD Form 494, "Court?Martial Data Sheet."

6. Court?martial orders promulgating the result of
trial as to each accused, in 10 copies when the
record is verbatim and in 4 copies when it is
summarized.

7. When required, signed recommendation of
staff judge advocate or legal officer, in duplicate,
together with all clemency papers, including
clemency recommendations by court members.



8. Matters submitted by the accused pursuant to
Article 60 (MOM, 1984, RCM 1105).

9. DD Form 458, "Charge Sheet" (unless included
at the point of arraignment in the record).

10. Congressional inquiries and replies, if any.

11. DD Form 457, "Investigating Officer's Report,"
pursuant to Article 32, if such investigation was
conducted, followed by any other papers which
accompanied the charges when referred for trial,
unless included in the record of trial proper.

12. Advice of staff judge advocate or legal officer,
when prepared pursuant to Article 34 or otherwise.

13. Requests by counsel and action of the
convening authority taken thereon requests
concerning delay, witnesses and depositions).

14. Records of former trials.
15. Record of trial in the following order:
a. Errata sheet, if any.

b. lndex sheet with reverse side containing
receipt of accused or defense counsel for copy of
record or certificate in lieu of receipt.

c. Record of proceedings in court, including
Article 39(a) sessions, if any.

d. Authentication sheet, followed by certificate
of correction, if any.

e. Action of convening authority and, if appro?
priate, action of officer exercising general court?
martial jurisdiction.

f. Exhibits admitted in evidence.

g. Exhibits not received in evidence. The page
of the record of trial where each exhibit was
offered and rejected will be noted on the front of
each exhibit.

h. Appellate exhibits, such as proposed in?
structions, written offers of proof or preliminary
evidence (real or documentary), and briefs of
counsel submitted at trial.



DD FORM 490, MAY 2000

Inside of Back Cover



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