Title: Volume FOIA 002

Release Date: 2014-03-20

Text: 00338



Volume 2 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 2012, 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DD FORM 490, MAY 2000 PREVIOUS EDITION IS OBSOLETE Front Cover



AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 6 April 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_DUO14108



jun LTH nggpau RECORD OF MIL 11193.1. may.

Patienl HIANNING. BRADLEY Dale: 06 Apr 2011: 14413 AST App! Type ROUTH
FaCi'ity. WSFSAI Clinic: COMBAT srness Cllnic Pruv'raer. MICHAEL

5h





Sphninrf??h? BHADLEV
Rank PRWATF FIRST CLASS
Um:

Dui?l Hut. R'n'







RECORD OF I
rum; :51 many 1 IN THE PRIVACY ACT or LJhALi'muszDnurt?lisri Emu-bed by Cit-ad If-?m
TL: THIS IS a wom'nzw fj'r- mum-m1 LAW mom TDRS wn; 1E

ManningB_UDDM109

FORM Hill 5]

AR 15-6 Report

Compromise of Classified Information to Wikilea ks

DATE: 26 April 2010
(Note: error in typed date on MFR)
PAGES: 2
FORM: MFR
SUMMARY:

Written by MSG Paul Adkins at FOB Hammer. Discusses continued behavior
issues and mental instability. Therapy does not seem to be working.

ManningB?DO?r 41 1 0



DEPARTMENT OF THE ARMY
Headquarters and quuarters Company, Second Brigade Combat Team
to? Mountain Division (Light Infantry)
FOB Hammer
APO, AE 09303

AFZS-LFJ 26 APR 09

MEMORANDUM FOR RECORD

SUBJECT: Recent Behaviour of SPC Bradley Manning

1. This additional memorandum supports a 21 DEC 09 MFR, and highlights continued
incidences of mental instability in SPC Bradley Manning. The events have reernerged and
intensi?ed over a period of two weeks. His instability seems heightened since mid-April 201 G,
culminating in frequent catatonic periods and claims ofdissociation.

2. SPC Manning has exhibited bizarre behaviour, stopping in mid?sentence during
conversations, giving blank stares when spoken to, and similar behaviour, which has increased in
frequency and intensity. This problem gives an impression of disrespect and disinterest to his
noneommissioned of?cers and of?cers.

3. Additionally, SPC Manning has reported an altered or dissociated state of consciousness
recently. This state gives him the impression of watching himself on a screen, as though events

unfolding around him, and pertaining to him, are not actually occurring TO him but semeone
else.

4. SPC Manning has reported having no sensecftirne and ?'cquently ?nds himself in a

dreamlike state. He claims this issue resulted in late reporting to his place ofduty on 26 APR 10.

5. His noncommissioned of?cers report him to he distant and distracted at best. His duty
competence does not seem to be signi?cantly affected. l-le sometimes produces accurate
products in a timely.r manner. Other days his performance is signi?cantly.r degraded. We are
unsure at this time if he presents a threat to hiinself, though he does not seem to he in chnger
currently in my estirnation. His instability is a constant source of concern, however, due to its

inherently ?uid nature.

6. SPC Manning seems to create internal pressure due to unnamed con?icts he seems unwilling
to discuss, and incapable of handling by himself. I recommended he see CH (CPT) Howell the chaplain could provide helpful coping skills or an avenue for discussion

not previously explored

ManningB_UD?14111




SUBJECT: Recent Behaviour of SPC Bradleyr Manning

7. These issues seem to arise in clusters due to internal pressures. SPC Manning is treated the
same as other Soldiers in the section.

3. I am familiar with dissociative identity disorder, and sometimes sense the presence of altered
personalities during SPC Manning?s unsettled periods of behaviour. By self-admission, he
experienced a less?than-ideal childhood and situations. I do not assess at this
time that SPC Manning?s behaviour is spurious but of a deeper medical condition
unknown at this time. My concern is that SPC Manning?s condition is deteriorating and possibly
becoming detrimental to the good order of the unit. If required to PCS, I fear the result would be
disastrous for SPC Manning, including UCMJ action and a chapter under conditions othenthan

honorable, etcetera.

9. SPC Manning continues to report the therapy he receives is unproductive, with the doctor?s
discussions and therapeutic approaches of no value. He sent me an email on 24-25 APR 10,
which he later claimed he tried to recall. in summary, SPC Manning stated the problem is
longstanding, deep?seated and intensifying deepite his best efforts to the contrary. He claims his
life and functionality is extremely degraded due to his problems. He fears his only help lies in
disciplinary action and possibly chapter. He reports dif?culty in sleeping, concentrating, talking

with others.

ID. The point cfeontaet for this memorandum is the undersigned, at?



PAUL DA ADKINS
MSG, USA
Master Sergeant

ManningB_DOD14l12



AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 7 May 2010
(Note: Form lists 8 May as date, but note cites 1 May as appointment date)
PAGES: 1
FORM: SF 600
SUMMARY:

Appointment with Combat Stress Clinic at FOB Hammer. Released without
limitations with follow-up in 2 days. SM discusses concern for "current situation"
and dismayed that he "did not have controi over the outcome."

ManningB_DDU1411 3



Hm LTH RECIJBLL

Patient MANNING. BRADLEY Date DB Mar 2010 085$ AST Appl Type RDUTN
Facirlly WSFSAI Clinic COMBAT STRESS Clinic PruwicfE-r WORSLEY, HICHAEL


MANMNU. ERAS-LET EDWARDS-151339504
Flank. CIAHF.

Lhn- waft: ZPEA

{Jun}! Flt-c Rm 413.5 5T:

l'i?M

Tu]

FUHM mu 5;
T'lentth ?331 and
I??II-thmul

mi t? 41}er
PHUI We: M'l I974
H's THIS Ham-Rm Hm" IS e?u OF FEDERM LAW WELL 5: PROSECUTED





a, AR 15-6 Report

Compromise of Classi?ed Information to Wikilea ks

DATE: 8 May 2010
PAGES: 2
FORM: MFR
SUMMARY:

Written by MSG Paul Adkins at FOB Hammer. Discusses continued behavior
issues and mental instability.

41 1 5



DEPARTMENT OF THE ARMY
Headqnarters and Headquarters Company. Second Brigade Combat Team
El'll Mountain Division (Light Infantry)
FOB Hammer
APO, AE D9308

03 MAY ll'l

MEMORANDUM OR RECORD

SUBJECT: Recent Behaviour of SPC Bradley Manning

1. This additional memomndum supports MFRs, and highlights
continued incidences of mental instability in SPC Bradley Manning.

2. On D71830MAY10 SPC Manning left the work area during a unit infonnal meal. I attributed
his absence to discomfort with some of his coworkers, and assumed he moved to another work
area in order not to participate in the Modem About an hour laterI a Soldier informed me SPC
Manning was sitting on the floor of a storage room in a fetal position.

3. When uttered the room, SPC Manning was sitting upright with his knees tucked up towards
his chin, obviously agitated about something. He clutched his head as though in pain. He
clenched his eyes shut and said nothing. I noticed beside him a folding chair with out marks on
the padded seat, and an open gerber knife blade at SPC Manning's feet. Several pieces of cut
vinyl lay by the tool. On the seat he etched with the blade the words, During the
course of the conversation, 1 determined he was not in immediate danger of cutting himself. He
stated he did not know why he etched these words.

4. Through repeated questions, I was able to get SPC Marming to respond. He then spoke at
length about several issues. .He stated he felt he was not there, and was not a person. He stated
he had no personality. He went on to explain that the calm person who was speaking was a
personality independent of the person sitting on the ?oor in obvious pain. He drew the analogy
of him being a turtle with a core personality, and several layers of hat-dated shell, fragmented
and designed to protect the core personality, and Function in different situations as the need
required. He also drew the analogy of his personalities being like layers of onion.

5. SPC Manning recently suffered a recent break-up with a close ?iend in the States. This
situation has caused him considerable distress, both personally and concerning some of his
preperty he stored with this individual for safekeeping.

6. SPC Manning ?uctuated during the conversation between a calm individual and one in pain.
As he spoke he seemed to be unhappy with what he revealed, and withdrew back to the state in





AF ZS-L -l
SUBJECT: Recent Behaviour of SPC Bradley Manning

whichi found him. Alter about an hour, I was called to work and had to leaVe SPC Manning. I
checked on him later. He seemed to be calm, and I left to do other work.

7. I considered during the conversation whether to send SPC Manning to his trailer, but decided
he seemed to recover suf?ciently to ?nish the last four hours of his shift. Later in the evening
SPC Manning struck SPC Showman in the face during an argument

8. After his discussion with CPT Worsley, I ensured he went to his room wimout weapon We
spoke at length about his childhood and reasons for joining the Anny. He also stated he had no
intention of striking SPC Showman, and had no idea why he did it. He then stated he may have
responded to perceived slights delivered by SPC Showman prior to striking her. He also
expressed signi?cant concern of the repercussions of his actions, including UCMJ and 0TH
diacharge. He stated that extra duty might cause further aggravation. He stated this in a matter
of fact manner, not threatening He alsn expressed concern as to where he would work in the
coming days. I told him nothing had been decided at this point, but my desire was to see he
received proper treacnent for his illness He returned to his trailer at approximater

0803001? D.

9. The point of contact for this memorandum is the undersigned, at?



PAUL DAVID ADKINS
MSG, USA
Master Sergeant

ManningB_DDOt4117

AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 8 May 2010
PAGES: 2
FORM: SF 600
SUMMARY:

Brought to Combat Stress Clinic at FOB Hammer by NCOIC at 0130 for striking
another SM. Released with work/duty limitations with follow-up in 1 day.

Manningano??tdiia





E?h_

?almn: HANNING, BRADLEY Dale. as May 201:: r3553 AST Appl TypE' RourN
:acmw; WSFSA1 aim: COMBAT STRESS cum; Provider. WURSLEY. MICHAEL
,1




Rank

PRIVATE CLASS
Uml.
(mm: Rm; Rm- RECORDS STUDENT CLIHJF

FEM
FEM
RECORD 0F FARE
THIH PRIVACY ACTHF

Sty-murmn FURM wu- qnn.
TU THIS 13 A VIOLATION OF FEDERAL LAW WULATDRS W7LL BF:

l-?r?cnhurl b] and H'th
FIRMHHI

ManningB_OOGM119





I
?18 May 20m W53

Fu?lii}: Threat" Fa mm} Provider: Thulrr Provider

('Ilnic: Tth!? Clinic

RECORD {Emyjcaticma





(Ful?l. Ru:


Tut.




mm IS m? Tin-f Pmmc?r 01'- mm 33-51%) UNAUTHORIZED ACCESS
5m: um I: p. cm: mw wan. HE

4

MANNING. .F EDW 59303.14

Spunmr??i??
Rank. PREVA H: HRS {1.5.55
1 ml:

RECORDS HFIEJM-MI STE

5]
Prmfirm'} b? and TCMR
{i1

.g

AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 10 May 2010
PAGES: 2
FORM: SF 600
SUMMARY:

Appointment at Combat Stress Clinic at FOB Hammer. Released with work/duty
limitations with foliow?up in 1 day.

ManningB_00014121



Fallen: BRADLEY Date: 1D May 2010 1412 App! Type RDUTN
Fully: WSFSAI Chm: comm $13553 cum: Mower: won susv.


Hpn?am? 5H- MA law's. BRA. r31 ?r F. J-w ARDIM 5 Imam-1
[-15an FLASH

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(Imp! Rn; Hm- RFCUHUS


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mun RECORD OF mm: 51?anan FORM mm mm: 5}
Hal!? av THE PRIVACY ACT OF WM F'er h: 65A and WW
'r HHS from I5 A OF LAW 3F CFHI 101-45505

ManningB_OOD14122





_H?a Balm:
Mayl?l? l?lZ
'l'henlcr FMiJiu' lmit: Thenm Clinlc I'I-midcr: 'l'hcalrr I'rm idtr

RECORD 9F EDICAL

WSF 3A1



MANNING. BRADLEY
Rank: PRIVA

Uni]:

Oulpl Rec Rm: RECORDS ROOM-VJ STUDTEN CLINIC










'icI
. . . . . anuauummzse
THIS INFORMATION L'w THF at I974 Lr'Nm ACCESS Frescth nqusn. Ind MIMI:
In lillH r5 A (Jr LAW WOLA Wm, HF. FIRMRHI

ManningE_DOO14123

AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 12 May 2010
PAGES: 1
FORM: SF 600
SUMMARY:

Appointment at Combat Stress Clinic at FOB Hammer. Released with work/duty
limitations with follow?up in 2 days.

ManningB_UDO1 4124



PaInen'L MANNING. BRADLEY







Facing.r WSFSAI

CH RIJNOLQQICA Bygomn

Data 12 May 2910 1035 AST
COMBAT STRESS Clinic




Appt Type; ROUTN
.F'ramdar: WORSLEY. MICHAEL





MANNING. HFAEJLEY
Hank PRIVATE



11.: Jim Rec. Rm


I cl





REFURD {All}:
TI il?w' IIDN i?i [3Wr THE UF W75-
NJ HHS IS A OF EFDERAL LAW WILL EFL PROSECUTH)

ManningB_OOD14125

Brawn-m0 s:
Ir} GSA
Ht

AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 13 May 2010
PAGES: 2
FORM: SF 600
SUMMARY:

Appointment at Combat Stress Clinic at FOB Hammer. Released with work/duty
limitations with follow-up in 2 days.

Manning?_00014126





Patient MANNING, BRADLEY

Daie: 13 May 2010 1115 AST App! Type RDUTN
Faculty WSFSAI

Cl'mm; COMBAT amass Clinic Prowdar; WORSLEY, MICHAEL




EN IP40. UP. A [1 Lli?! AR LEE-11459395174
Rink CLASS



Dulpl?v: him RECORDS STUJJIIN:



Tet
FORM MI v. 5.
r-rcm-im Gil-R Ind IFMR
FIRMR rm 1111.41505

. . . . . . . . RE
THIS. INFCIRMATIUN PRO: Mfr-H) THE PRIVACY Aer ACCESS
'10 Inf-7 :5 A Cill LAW ATQRS ?s'~'lLL BE

ManningB_ODO1412?





55930811 I OF MEDICAL mgr:
I3. l215
Fmilit}: Thu-am Facilil} Flinir: Then!" f'linir Prmidrrz'l'hrulrr I'rm'idcr
x:



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Rank mm 11-; I-?It-ts?r'

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0F s1}:ch AL. mm; FORM 600m?.
THIS I5 [m m; nu: ALT 01"- Itm {puns-m ?mun IURIZED pascnwarm mm or- FEDERAL Law v10: .ATDRS um.

ManningB_UOO14'l2E

AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 15 May 2010
PAGES: 2
FORM: SF 600
SUMMARY:

Appointment at Combat Stress Clinic at FOB Hammer. Released with work/duty
limitations with follow-up in 3 days.

Manningl3_00014129





0F ma?j?m . me;

Patient: MANMHG. BRADLEV Date: 15 May 2313 1052 AST App: Tarp: mum
Fat-Illa; Ciimc COMBAT amass Clinic Prowder- WORSLEY. mama.




Maulaqa'SSN: BRADLEY
Rank. PRIVATE FIRST CLASS

li BE

4' Truml Rec. Rm RECORDS ETUUEH


_u-i PPM
nF MI-ZIJI AHF. FORM 6m": (HEN. 5}
runs 15; B's? 11 IF. MT an: m! 5m} ACCESS Prescribed mum. mas WILL 10245-1415

r-V







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IS Ha} Z?l? ?52
Facility: 'l'hemcr Faritilz. {?Iimc: Illum-
't?r
?u-r



MANHIH C, BRADLEY
Rink: HHS:

Umt

Hum: J'tcL Rm






(cl. PCM
0F MEDIFM, Fen-ti! 68:) (REV. 53
Hm rs BY THE Pmmc?mm OF n?c-m mm mm
10 INFORMATION I5 A VIOLATION OF FEDERAL LAW VH3: ATDRS um; BE {in Hm? 10145-51?

ManningB_ODD14131

AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 19 May 2010
PAGES: 1
FORM: SF 600
SUMMARY:

Appointment at Combat Stress Clinic at FOB Hammer. Released with work/duty
limitations with follow-up in 3 days.

ManningB_UUDT4132



-. ..

HEALTH n?rogzn CHRONULGCIEIL knit?pkg RE

NH, Pal'ant: MANNINE BRADLEY Dale. 19 May 2010 1015 AST ADDI HOUTN
Famldy. WSFSAI Clinic COMBAT STRESS Cllnir. Provider WURSLEY, INCHAEL






IR A
l?l:

mt ?Jr H31 )2 FHA

('1qu1 Rent Rm RUCJN-H.





CM:
Tc!
runux?m?mt?m. 0r (um: STAND-WU FORM ma (REV, 5)
'i'l HS INFORMATION If? BY THE THORTEED 113- and
HHS. A VIOLATION OF WDLATDRR Bl: PROSECI 'Tf-Ll.) 30145-5115

33

AR 15-6 Report

Compromise of Classi?ed Information to Wikileaks

DATE: 22 May 2010
PAGES: 2
FORM: SF 600
SUMMARY:

Referred to Combat Stress Clinic at FOB Hammer for CDMHE. Released with
work/duty limitations with follow-up in 1 hour.

ManningEl?om 4 1 34



OF 7_

PallenL MANNING. BRADLEY Data! 22 May 1010 D518 AST App! Type ROUTN
Facl'ihu WEFSAI STRESS Clinic Edan


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0mm Rm RECORDS Titian-MI

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in. ..

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Hi1FEDERAL WILL BE FRUSECU

ManningB_DOO14 36



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QBMECEQEAL RECORB



('l?ink: Clinic

22 Ma 201 112
Wald. Edan
WSFSAI

l'rmiurr: Theater l'rm-idcr





REFUND CIF HEDICAL AMI-I

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PRIVATE-I
i UP BA.

Ouileuu Rm RECORDS ROOM-MI TUBES: CLINIC


'I'ci. FEM.

STANDARD Hum bat-{RE}
m. 55.1 H'th
L'Hll inn?15.5w

AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 22 Mai,' 2010
PAGES: 2
FORM: MEDCOM 4038
SUMMARY:

Request for behavioral health evaluation for misconduct. Recommended for
initiation of a Chapter 5-17 separation.

ManningB_0001413?



REPORT OF BEHAVIORAL HEALTH EVALUATION
I

For use uf?us form $11.33: The coonan agancy MEUCOM

NAME: SSH:
Manning, Bradley

REASON FOR BH EVALUATION





MarmingB_?OO14139



AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 26 May 2010
PAGES: 2
FORM: SF 600
SUMMARY:

Appointment at Combat Stress Clinic at FOB Hammer. Released without
limitations with follow-up in 5 days.

ManningB_00014140



WLi??Eb?rili



REE?Eatin?d EDIELEARE

Paiisnl MANNING, BRADLEY Data' 25 May 20101106 AST App! Type RDUTN
Facuiy. WSFSAJ CIIHICZ COMBAT STRESS Clinic meder, WORSLEY. MICHAEL






MANNWG BRADLEY
Rank



Dunn Rcu Rm hen-mm?:





PCM
. . - -
"grant: or ?mum. (amt: smnumn mum um
mm I5 BY THE. ACT 191-: UNAUTHORIZED

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:n'r'sn? IS a x101 DF I u; vro:_A mu PROSECEJTFD

CPR 1

1 41



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Thu-alt: Facilit}



INFORMATION IS PRIVACY ACT 1'97-1 433-57?) UNAI Aff?ii??i
THIS IS A LAW UP.



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OF EDICAL can;

Harmer! Tllculrr I'rm Idrr





i' RECURD 0F


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Uulpl Rec Hm


?Tut

MANNING.
PRIVA FIRST



RECORDS STUDIIH f'

[.40 CREV. F1
l'rcuribrd by USA and
FIRMH lil

.-

AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 28 Mien;r 2010
PAGES: 2
FORM: SF 600
SUMMARY:

Referred to Combat Stress Clinic at F08 Hammer. SM being investigated by CID
for compromise of classified information. Released with work/duty limitations
with follow-up.



RENE 1

pfni'??i?nfci?t'

Pallant MANNING. BRADLEV Dale. 28 May 2MB 1521 AST Apt)! Tyne ROUTN
WSFSAI Clinic: COMBAT STRESS Clinic Providu. Crilch?lld, Edan


SLW-lniun'h' 1" Dan-l
Rum.
Unu.

?uth Flt-c Rm
iiL'M
emanu. Rare-nu n'r' 5 mm: BAND-1RD FORM W0 5!

as i'mm-rrl-n m' my \t?f?F?iR Pracrihni [cm
:0 mm nirvana-a11m: :3 A Pause. - m. tug?495.5115



Manning 4 144







25 Hay 1m IGII
Futility: 'I'hrulcr Facilin

Theater





ManningB_DDOT4l45

?Elm A1. FARE

OFMEQLQAL CAR

I?ruridtr: l'i ultr Providcr


Hank
l'r.II

MA NNING. BRADF..F 59395!?
PRIVATE FIRE CLA .55
WECDEPHA

Chum Hut; Hm


rut

HY THE ACT 01: 197-1
1'fo TJIH IEJHIRMAHUN L5 A Mu?. UF- FEDERAE. LAW VICHA WILL E555 FHOSECUTED

STANDARD I'm-m mo 5]
Prmriluu by [25.1 and
Fla-mu Isl Erbium?45.505

AR 15-6 Report

Compromise of Classified Information to Wikileaks

DATE: 23 May 2010
PAGES: 2
FORM: MEDCOM 4038
SUMMARY:

Request for behavioral health evaluation for risk assessment. Considered high
risk.

ManningB?G?MM?



REPORT OF BEHAVIORAL HEALTH EVALUATION
I

For use. of this farm; sec MEDCOM 40-33: The :0 (meat agency is MEDCDM

NAM-E: GRADE: SSH:
MSW

REASON FOR BE EVALUATION

ManningB_OOD14 147



4 1:18



EXHIBIT

Earns. B?an LTC BUT KG



From: Lim. Steven J. EFT BDE 52
Sent: Friday. June 0-4. 2010 2:39 PM
To: Kama. Brian 29.0110an BOT X0
Subject: PW: Mv Problem
Attachments: brass-Ina.ij
Titus Classi?cation: UNCLASSIFIED
Titus Fu?Clmi?ca?m:



?assagos??~~
From: Adkins, Paul ZBCTIBHTN MSG SET 52 HCDIC

Sent: Thursday, June 33, 2313 9:51 PM

him. Steven 3. 895 52

Subjoct: av: My Problem

Sir.

Per conversation.
Wr-

MSG Paul David Adkins



From: ?anning, Bradley SPC BEE $2

Sent: Saturday, april 24, 2913 7:48 PM

Adkins, Paul ZBCTIBMTN MSG BET $2 NCDIC
Subject: My Problem



This is my problem. I've had signs of it for a very long time. Its caused problems within my
Family. I thought a career in the military would get rid of it. It?s not something I seek out
for attention, and I?ve been trying very, very hard to get rid of it by placing myself in
situations where it would be impossible. But, it's not going away. its haunting no more and
more as I get older. Now, the consequences of it are dire, at a time when its causing me

great pain in itself.

As a result, I?m not sure that to do about it. It?s destroyed my ties with my family, caused
me to lose several jobs2 and its currently affecting my career and preventing me From
developing as a person. It?s the cause of nay pain and confusion, and turns even the most
basic things in my life extremely dif?cult.

I don?t know what to do anymore, and the only "help" that seems to be available is severe
punishment andfor getting rid of me. All I do know. is that fear of getting caught has caused
no to go to great to consciously hide the problem. As a result, the problem and the
constant cover-op has worn me down to a point where it's always on my mind, making it
oifficolt to concentrate at work, difficult to pay attention to whatever is going on,
difficult to sleep, impossible to have any meaningful conversations, and makes my entire life

feel like a bad dream that won't and.

ManningB_UOU15006

Like I said, 1 Can't know what ta d9 and 1 know whats guing ta happen; but at this
point, it feels l;ke i?m net really ?here* anymare, an? everyane's CO?carned ahaut ma and

afraid of me. 'I?m sorry.

u?r

SPC ?rm-11a)!

Commands SEE ?nalyst

32 39515:: IQHTH
Reamer, Iraq

Manninga?om 500T



Manninng?om 5008

EXHIBIT



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You are here: gorge ?mle Fashion Crossdreasencom Introduces 3 New Hiding Gaff and Tucking Gaff Styles

Crossdresser.com Introduces 3 New Hiding Gaff and Tucking
Gaff Styles

Ely bestvalueproducts on November 13, 2009
1,20-1

ossdressercom, the Crossdressing Couture designers add three new styles of
?nding and tucking gaffs with New:r improved, style enhancements

FOR IMMEDIATE RELEASE
(Eree?ess?eleaw) November 13. 2009

There may be many definitions of the word gaff, however in the world of the crossdressing male, it has only one meaning. The gaff is
THE concealing garment needed to help flatten out the front crotch area, and nobody does it better than Suddenly fem, the couture

lingerie division of CrossDresser.corn.

Willow Wilson at Suddenly Fem explains, ?The Gaff is used to smooth out the front crotch area. Our special hiding gaffs do not have any
special extra gadgets or pockets like one might find at other suppliers we have tried those other products and they are NOT strong and
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at a time. We know our gaff designs work because we have had many customers test drive our designs and the feedback is that Suddenly

Fern makes the best Hiding gaffs for the crossdresser."

1

2
There are several new additions early this season. Style 41014 is .1
made in a sexy burgundy mesh design with the added bene?t of
a reinforced crotch area. Style 41015 is a new White satin design
for crossdressing men who desire a super strong design and
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-

Report of Supply Annex NIPR

ManningB_00036554

Appende





CAF 0025?1 0361

Suddenly Fem is leading the way in fashion. comfort and respect

for the sophisticated crossdresser. All styles are designed and
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Crossdressemom Introduces 3 New Hiding Gaff and Tocking Gaff Styles

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nc re ?a ewDes?nin rossdr Wis



hiVlSan of Best Value Products, Suddenly Fern is a rarity in the cross dressing industry that manufactures every item to accommodate

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The cross dressing experts at Suddenly Fem take care to personally approve each and every item for a high-end, elegant look that is

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For more information on Suddenly Fem of Best Value Products, call 215-881?9470 or visit straw:tis'ossiaresserstom

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I til?- i
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Report of Supply Annex MIPR

ManningB_00036565

I?d

23-4.? 5.3

ROI 00251000314011?
Appendix CAF 0025-1 0361

Website:
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w?r

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Manning 34300365732

EXHIBIT



FOR OFFICIAL ash: ONLY





































--
.. . - . a . . .i
DCFL
LTI-IOMAS P. MILLEY i DCFL-EOIOTIDUUSE
.- Tufig-5;. 715123;";
i-
?9 Applied this password to SUBJECTS file, previously extracted from
directory: The "foginkeycham" ?le unlocked.
Used Keychain utility on the Examination platform to display and recover all Ofthc
"'login. kc?ychain passwords:
3.710 . . A?aehbeE-m-?a?b?eag, . a
attfelnama-L-n lilac-e55 Central
1 Marne
"fi?fa
mm
Amount
Where
I tenements

i Sim-a- pas swam Tl?'?Attribnles Accesg Control

as .- -

I: i . Name: A553


Kind Fri-Zr rJ

Account linus?ma marmmq

Where A2an MM.

can men I

Mm aamsrd

FINAL ENTRY ON THIS PAGE











Iron-1'. 1.2

awn-rad by: 1, [Jun-um

4

FOR OFFICIAL USE ONLY Page.



of

16

Initials:


man-T F's-it'd! A



REPORT



Ron: was-loctozzi-iol I7
CID Regulation 195-1



PAGE 5 OF 9 PAGES



DETAILS

(reconstructed from HTML found in unallocated Space). the questioner (or questioners) is unknown, but
Mr. LAMO appeared to be providing the answers.



Mt] PM Ma! 21nd m:
- (2.131152 :5 your new: on piracy? 4in a flim?td unlit cams: an inflated pm: mad Iian'ffomJ-pma 54:? PM Mai: 22nd vi: human
I (33-: you cadt'l? Haw does Yen." Language lumen; latent leak like even I hide in! 1:32 mimonnlhow'af 532335237 5 21 PM Ha: 32nd Ell- 11.:

Q'l'fyou :culd change three things it: your Fr] res-c Morin"! Paw I?m or falling for 22nd fen-mm.?





I Juan got done watching Ha :kers Waited A Mad no?'img re do with the Ink, 1nd I155 43.05 PM 22nd In: fem-ISM
- Q39 you Fray any incite And if 50, whaf: your preferred plain! A Disk: 3d. Willie-.1me radii: 3'35 PM Mag 23nd. via ME
I Q?ome pluses 115* you gar: some 3153' no ?Meek: what such was It? AMonsy ka 3'35- PM MAE 22nd In: Emma:

i @0qu wil be retains. a random keepsake. no wubng nacho: i'l M11 E'Egd via mobile web



- Arbitrary congrats to for beta; follower I 25? Not much con-guard to some. but appraised l_l ?13. Amity Lin-:1 ?1 5:115er



I You. used to smoke (moan: push 3 AI smoke Ind metres 3 a? 14 3 23 AM Mail 211d new

{5324:7432 L: i May 2256 via



a ?lm-131i: reta- 3Q Aldrdiiavr chi: zoned recently. and don". fed eunfo nab]: than-1.3 hm?fc- -:
mot:
. I

. We: mimirw
- 83:: Strange luck.





5.5" Felon-1.1g 2 Follower; PEE- "Jared

. L3 i. at?
- Favorite:







Figure 3 conversation between Mr. LAMO and unknown questioner(s]

References to ?breannaemanning? were found in several locations on the disk, including in the system's
restore point ?les. Two of those references provided information pertaining to Gmail and Twitter accounts
are shown below.





Vis?zedz swamp -- -- -- - -5 in 3-1 -1-
- C-on fi. r-m y-o u-r rJ-i-t-t-er' -h-m-u-n-ni-nq-f-n-I b-r-
a. n'n'a . 111-1111 1mg 3 9 111-1 . - --

l'cv-us 'cv-'
Figure 9 Text referencing, Gmail and Twitter accounts believed to belong to PFC MANNING as ?Bresnna?



















i rvneo NAME AND SEQUENCE NUMBER ORGANIZATION
Computer Crime Investigative Unit
SA D. PITTMAN.- Army cm, Fort Belvoir. VA 22050
SIGNATURE DATE EXHIBIT
_r 18 Jun 10
CID FORliil 94 FOR OFFICIAL USE ONLY LAW ENFORCEMENT SENSITIVE

or-nlassy?h??vidouewj?aor
ADDroved

in! an!

F-?rn' Goose?-



INVESTIGATION REPORT Enema-10mm



Rota 17
CID Regulatron 195-1
PAGE 6 OF 9 PAGES





DETAILS



?ia'isated: sump - - - - - -0 -
h'n an-na-n-g 5 Lr'e-e't. - Built~1H-FVisiterl: Swamp
er.comftavoricesll47937o?.rss -Ir- -- 3- a a. n-n-i n-g -n a -rhoops: {Email
-- - -- n-a-l -- -l3~a 11-! -1 -r 1 59-0-131'
-T-w'i-t-t err-11: on m-e-n-n-i-n-g 1 mt -- hie-en n-are-41c -- - -- - la -
i- - - ik-W?isieed: sump rentihceps?ltnricceneom? tolluuers Hell--
I
I - X- T-uict~e-r ?Po-cpl! -uh-o- f-o-llow- 'h-ma-n-n-i-n'g tun
Iitr-rah-rih-riH?rm?rm-wm ?m-ui- await-em- -- --
Figure 10 - Text referencing Gmail and Twitter accounts believed to belong to PFC MANNING as ?Breanne?

References to both ?bradlevemanning? and ?breannaernanning? were found in numerous locations on
the disk, including indications that someone accessed and managed those email account from the
examined system.

References to ?wiltilealcs? were found in numerous locations on the disk. primarily in the Internet history
for the ?swamp rat? user. The ?wiltileaks? references in the active Internet history on the disk all appear
in sites last accessed between 22 and 24 May 10. Many of the pertinent references to ?wikileaks? appear
to relate to searches for or the accessing of stories related to the ?Adrian Lamo video release", as well as
searches for Wikileaks on Twitter and F?endFeed.com.

Examination ofthe C\Users swamp rat\AppData \Roaming\Google\Local Search
. file revealed what appeared to be the content of the user?s Google Web
History file. Google Web History is an add-on function ofa user?s normal user account that allows the
user to view and search across the full text ot?pagcs they have visited, including Google searches, web
pages, images, and video and news stories. The contents ofthis goog1e%2web . file appear to relate to
PFC interests.











TYDED AGENTS NAME AND SEQUENCE NUMBER ORGANIZATION
Computer Cnme investigative Unit
SA Rvan D. PITT MAN- us. Anny CID. Fort Belvoir va 22060
SIGNATURE DATE EXHIBIT
18 on 10







CID FORLIVI 94 FOR OFFICIAL USE ONLY - LAW ENFORCEMENT SENSITIVE

Approved








-"'Ulm qw:P I
ROINUMBER mamas-moron:

REPORT

CID Regulation 195-1

I7








































PAGE 8 OF 9 PAGES
DETALLS

-e-a-r-n-e-s~t 'W'a'l-l-H-o-r-k
11-51-54:


a-n-a'l y-s't'

FT-E- -m-a~r-kvert- 11-: l'e't- 'h?a "re-r-f-o-r-d'w-e-s ?vi-191?]


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r-e-t-a'tll-o-n
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.


im-t-ew-s-tq-n-e ~21 a-n-a- ~5-a-r


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Figure 12 Excerpt from google?webm ?le
.m.h.srgs.
'h-u-tlf-i-rug-c-o-n- roe-51-
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v-u-r's'u p-h D't'o'i'h-o-p-
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is Two-Wino: i't'B'S'
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m-h ye-
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-c-o-n e-cm-i -f 1;
c-o-n-n-e C't'l'f?Y' ~f-a-r ta
d-o-v-n-l a'd- e-c-t-l-f 1: -f-e 1: a
l-a-nn-LL-n onto- a 21 a 2-5-
[q-e-n-de 1-d-a-n-t-1-t-y- 111-5-131-511} -



Figure 13 Excerpt from google%2weh . or ?le

The google%2web - ?le also appeared to contain the ?Work Experience? section from a resume

pertainingr to an ?Intelligence Analyst





TYPED AGENTS NAME AND SEQUENCE NUMBER

SA Rvan D.

ORGANIZATION
Computer Crime Investigative Unit

US. Army CID, Fort Belvoir. VA 22060



SIGNATURE



DATE

18Jun10





CID FORM 94



FOR OFFICIAL USE ONLY LAW ENFORCEMENT SENSITIVE

Aporoved



EXHIBIT I



ManningBrU DU45T33

Nut
EPCD 111-1'0, Item 1 M23

I may) l?th gender" [denim-?3





FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_DDU45583

EPCD 111?13, Item 9 of 23

SECURITY





3: Ee;araz-c' Prccee3;?q5
I. Hecha.1?m
cw J?rer LN Tf?pte:
f3: C"rrarder
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Hf FLana ha:a:d;nq laser a? Hip-git, Cnagze:
fr?zraiuur if:
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Eaferencef :3 Regul'ticas, IE Zia:

9::i:_e3
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- ':tfaq=:i5? aTqunents

FOR USE ONLY


Mannth_00045595

Item 9 of 23

r-?i

?1

10.

12.
13.
14.

ManningB_DOD45597

'h-r


Conway. 203:. ?How frequently does transsexuaiism occur?"
Accessed February 9. 2503 at


Anne Boiin. 1988. In search of eve: Transsexual rites of passage.
South Hadley. MA: Bergin and Garvey;

Anne Lawrence. 2033. ?FaCLors associated with satisfaction or regret
following male-to-female sex reassignment surgery.? Archives of
Sexual Behavior 32: 299-315:

Henry Rubin. 2003. Self made men: identity and embodiment among
transsexual men. Nashviile. TN: Vanderbilt University Press;

Kristen Soniit. 2306. ?Just one of the guys? How transmen make
gender visible at work." Gender Society 20 :41: 465-490:

Kristen Schilt ano Catherine Connell. 2307. ?Do workplace gender
:ransitions make gender trouble?" Gender, Work and OrganizatLon 14
i5): 596-618.

Joanne Meyerowitz. EDGE. How sex changed: A history of
transsexualism in America. Camoridge: Harvard UniverSity Press.
Jamison Green. 20C4. Becoming a visible man. Nashvilie: Vanderbilt
University Press.

George R. Brown. 1983. ?Transsexuals in the military: Fiight into
hypermaSCulinity," Archives of Sexual Behavior 17(6): 52e-537.
Tarrvn M. Wit:en. 200?. ?Gender identity and the military:
Transgender, transsexual, and inteISex-identified individuals in the
armed forces.? Santa, Barbara, CA: The Palm Center.

5.5. Army. 2007. ?Standards of modica_ fitness," AR 46-5Cl.

Kitten, ?Gender identity and the
295 297~298 {c.M.A.l
1355 (A.C.M.R.: 1994.

U.S. v. Guerrero. 33 M.J. i991;
5.5. v. Modesto, 39 X.J.
Kristen Clements?Nelle, Rani Yarn, and Mitchell Katz. EDGE.
?Attempted suicide among transgende: persons: The influence of
gender-based discrimination and violence-? Journal of Homosexuality
51(32: -3-69

Kriszen Clements?Nelle, Rani ?arx, and Mitchell Katz. 2C06.
"Attempted soioide among :ransgende: perenns: Tne infiiener of

gender-based discrimination and violence.? 4ournal of romosexuality

5173): 53-69

FOR OFFICIAL USE
LAW ENFORCEMENT SENSITNE

EPCD 111-10, Item 9 of23



18r11

ManningB_Do[145598




Paisley Currah, Richard M. Juanq, and Shannon Price Minter
2606. Transgende: rights. Minneapolis, MN: University of Minnesota
Press

Richard Green. 1985.

discrimination and the criteria of sex." Yale Law a Policy Review

?Spelling ?relief' for transsexuals: Employment

4:125?146

Claudine Griggs. 1998. S?he: Changing sex and changing ciothes. New
York: Berg

Pooja S. Gehi and Gao:iel Arkles. 2C07. ?Unraveling injustice: Race
and class impact of medicaio exclusions of transition-reiated
healthcare for :ransgender people.? Sexuality Research a Social
Policy 7-35. ?rnold 9. and Anthony R. D'Augelli.
2006. ?Transgender youth: invisible and vulnerable." Jovrnal of
Homosexuality 51(1): 111-128

Emilia L. Lombardi. Riki Anne Wilchins, Jana Priesing, and Diana
Malouf. 200:. ?Gender vioience: Transgender experiences with
violence and diecrimination." Journal of Homosexuality 42i1): 89-101
Rita M. Melendez and Rogerio Finto. 2007. really a hard
life?: Love, gender and Efv risk among male-tOFEemale transgende:
persons.? Culture, Health Sexuality

Shannon Minter. 2303. ?Employment discrimination against transgender
people: Case law, statutes, and workplace policies." Accessed Angus:
3. EDGE a;
annualfpaperef2003fminter.pdf

T. Vemoto. D. Operario, J. Keatley. and 3. Villegas. 2064. ?Social
context of HIV risk benaviours among male-to-female Lranagendera of
colcer." AIDS Care 16(6): 724-735

Jodi Sperber. StewaI: Landera and Susan Lawrence. EGQB. "Access to
heal:ncare for transgendered persons; Results of a needs
in Boaton.? International Journal of Transgenderjsm 3(2-31: 75-91
Rebecca L. Stotzer. 2308. ?Gender identity and hate crimes: Violence
against transgender people in Lee Angelea County.? Sexoaiity
Research a Social Policy 43-52

Stephen Whittle. EGOZ. Respec: and equalizy: Transsexua; and

transgenoor rights. Portland.

Julie A. Greenberg. 2806. ?The roads less traveled: :he probiem with
binary sex categories" op. EL-TB in Curran, Huang and Minter
Transgenoer rights.

FOR OFFICIAL USE ONLV

LAW ENFORCEMENT SENSITIVE

EPCD 111-10. Item 9 01'Barrie Therne. 1993. Gender play: Gir;s ann boys 1: school. New
Brunswick, NJ: Rutgers Universizy Press.

Judith Halberstem. 1998. Female masculinity. Durham, NC: Duke
University Press.
Thom Shanker. June 23, 2008. ??Don't ask dcn?t :ell' hits WOmen much
mere." The New York Times. Section R, p. 14.

?Transgender health and the law: Identifying and fighting hesltn
care discrim;nstion.? Recessed Asses: S, 2055 at



PhiLaeelphia Daily News. 2301. ?San Francisco will pay for workers'



Sex charges. Sectien A. p. 14
Althea Chang. 2008. ?Unusual perks: Goldman Sachs covers sex
changes.? Accessed Angus: B, 2008 at

ham

WaLter Meyer et al. 200;. The Harry Benjamsn Internat;ona; Gender
Asseciatict's Standares of Care for Geneer Lcentity
Disorders, sixzh vers;on. Accessed August 5, 2038 at

1

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITNE

if
13 of 23

3?35. Persa?ai?ty, conditiuns. transsexual, gender identity. exhibitianism,
transvestism. voyeurism. other paraphitias. or fastitious dimmers; disorders 01? impuise contra! not
elsewhare classi?ed

a. 9?1 til-.mrfr M. m- em?rcn; 13.5 :iinisrdn's 13;" mpuim: cumrni
thanm-ean-{nL 'vugcua'nm. 31h." pmagahihm. nr ?lcnuum .Esmmivn. pupil-.mmzmi minimum.
gender iLiL'ntiijf shun-def Ir: major [Mex-?3. 91 I'm- gmn?din with .15 mung: us 4 Diil'i'i'?i
Jit?m?t in change a! guru Emu-J21! Liysgensmw. dyxs'bnuhwml remain-Ah?
{mm :?uruimvm made-r ma in?ivi?mi unfit

Ifww ('ntml'rtium rcmicr am andmduat 5mm tatizc: ihan unfu woman: Him-v? 131:
xim?niny 'E'ilcic rumi?lmni ME u?cnh anti: lEu'rmgh 413m:ni.emtiw cimimeis. including 31.9. HF-
US AR 1335-- 45: AR 2%

3*35. Adjustment disorders.

Millalimm! in June 1r damn?; alt-rm an nu; main: in: imimdual uni}! a!
grhjo?mal airmshai?iy. hm ram- iraz': tum-a Fur ii't'wunrcm will imwi'cwnt'c military
dl?k'

3-31 Eating disorders
annex 4m :cl?cryzil h- \11 are sitting minus/cw dial 41's: unratquumne {fl In?uil't?wn! Hm: ullL'rILt?i'c' Wail:

111' duh

3-33. Skin and ceilular tissues
'E?itc- E?f?l? .?vi
a. Flown-r. anti {muri'mum wilt; 1hr: mm?aemmw m? Jan;- zw Leann-g
HR: Latin-n: or who itniimry magnum-1n

?mgr-r, Hm? than! nuykz?ilic. Ia; m'mmcni, 4m: ?ind: Mm Em: Sum}ch
nf' ehlm

my!" 1mm inner :il Egg-d.

(um um! {rm-m. e?uu ramzhs'mpf;


xi imw'?cring mm wrinrmunce a? rim}
:3 Elf-Juli Jsrruur chsmilg'w nr' Infra. when Ihgw 1mm; than n?immu} mt?ilf'nnlmul and thri?iislm Ia;
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.333 AR 253 December 13%"

FDR OFFICPAL USE ONLY
LAW ENFORCEMENT SENSITIVE



Aims

19 of 23
Rey-playing the Game: Hypnagogic image-yin
Normals and Amnesics
Robert Stickgold, er al.

Science 290, 350 {2000):
DOI: 10.1125iscience.290.5490.350







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EPCD 111?10. Item ?l9 of 23


Temperature of 51": and 40 cycles on a FTC-200
thermocyc.er Research}. A pontive control was
then performed under the same PCl-l con ditmn with
genomic DNA as template. All primer pairs gener-
atEd the expected amplicons were then
performed on the RNA eetract With a dillerent
thermocycier. All primer pairs generated ampiicons
of the expected sizes and sequences.

13 For the location and the designation of selected
primers, SEE Web fig, 4 (Ill

Primer sequences are as follows
chItXZ. -CATTAC-
.
Rtgl?li
ATAT
Ftc_hemC'2. TATGCTE
603 cheerB. lacs
3 RC .hernCd

REPORTS

ec_iihic.1. sari rca'. Rc_u~
biGZ.
and
TCGCICTTC-B

2i} Arriinca acid sequence ?identities for the repeat-de-
rived peptides {and The rest of the proteins] are ?E?ll:
for Kth, 31% {8335: ?or R9543 and 52%
for PGIA

21. Lioer and Sharples. Nucleic Acids Res 13.
5503 [1990]

22 Bachellier l-M Clement. Ho?nung, Res Micro-
brol 15-0. 62? [?999l

23. As ravealt-d by a partial. low-slgnihcance match be-
tween RSA and 23 amino acid rest-dues at the 3' end
of a Salmonella ryphimmrum hypoznetical DEF
{SwissProt accession number P155550 A ESE-like
inverted repeat is also present in the NHrterminai

Replaying the Game:
Hypnagogic Images in Normals
and Amnesics

Robert Stickgald,? April Malia,1 Denise Maguire.1
David Iliadder'iherry,1 Margaret CD'Connor2

Participants playing the computer game Tetris reported intrusive. stereotypical.
visual images of the game at sleep onset. Three amnesii: patients with extensive
bilateral medial temporal lobe damage produced similar hypnagogic reports
despite being unable to recall playing the game. suggesting that such imageryl
may arise without important contribution from the declarative memory sys-
tern. In addition. control participants reported images from previously played
versions of the game. demonstrating that remote memories can in?uence the

images from recent waiting experience-

People who engage in novel physical or incri-
nil for periods of time
often a hallucinatory replay ofihc
us they liill asleep. phenomenon
holed ll'l huih literary and sources
(I ll. Although the origin ol'ihcsc images In
waking experience appoars clout. Ihc sniirui:
within ihi: brain and tho l'iinchon such
unspen- are uncertain. If those images are
by ntcmiin' systems.
uinnCsic patients with bilateral hippocampiil
should not otpcrience them. Bucnusc
are capable of reporting dream ox-
it}. the quesuon can he It'lttiln-
ingfully addressed

M051 studtes of dreaming involve rc-
purls of mental actiwly after forced awak-
emngs from rapid movement
sloop in. 3'1 or alter spontaneous awakcn?
my in the niidclli: ol'thc night or morning
Ml Hypirapupic represents an-
other source of sleep-stale menial imagery



'Laborato'y of Department of Psy-
chiatry, Harvard Medical School. T4 lenwood Road.
Boston MA 02115? USA. ?Memory Disorders Researc'i
Center, Boston Uriversity Medical School. Divlsion ol
Behaworal Neurology. Beth lsrael Deaconess Medical
Boston MA aria USA.

"in whom correspondence shciuld he addressed. 5?
mail'

ill?DI. Studies of the rule of slecp ll'l
learning and memory hiivr- generally ig-
norcd the hypnagogiu period. focusing inv
stead on posSIhlc roles of REM sleep and
deep. slow wm-e sleep {ll?Hi i.

We asked 2? participants in play hours-
ufihu computer game Toms ll-?l over 3 clays.
2 hours :n the lli??'l? exposure and hour each
subsequent morner and evening llh'l. Three
groups of participants were studied: 2 nov?
ices with no prior Tetris Ill ch-
pcne 'L'v'llh Considerable Tctris experience.
and 5 amnesics bilateral nie-
(lull temporal lobe damage I?ll-ll, ?iimcrpunls
were repetitively pronipied for mentalion roe
ports during the first of aineniplcd


Even though the five patients
were of average intelligence. may more un-
able to 1mm i'lr?ld retain new episodic infor-
motion regardless of modality
or the nature of the malcriol. 'l'lic perfor-
mance the patients showed only
minimal. ath-it Signi?cant.
over 7 hours ol?play lFig. ii. The mean score
increased from 537 polnls on pu?iuipaiils'
first gume to a ?rst average ofo?l.
thi: five lht: satires in-
creased by Brit-ii in 884 puinis per game
if}! Although game playing is often seen

00284000221401 1?

region of the that gene in fell! 19?: The"! rs no
signi?cant Similarity between this REE-lute sequence
and nor newly described RPE sequence

24. Reviewed in F, Perler. Nucleic Arid: Ices 27' 3%
(west

25 We examined the structures whose ho-
motngs are known to contain inteins lAB-t.
1ECL. ERIC. tent. and

26 Moncnois. personal communication

2? Muller Murat Res 1. 2 {1964].

23 Tao. Bausch. C. Richmond. Ft Blattner.
Conway}. Earle-rial 131, 5425 (1999]

29 We thank Abergel. D, Gautheret. and
bath let their help at various stages of this wail-i

If April 2000; accepted 25 August 2000

as busod on pmcudurol learning {which
preserved in amnesia]. lhi: group
demonstrated impoverished learning in
comparison with normal nuances. suggest-
mg Ihal Tcli?is pro-fluency may also depend
on declarative memory systems, This inlur-
prclatlun is supported by the finde Ilizii
loft and right hippocampal glue-use unlit..-
lion during Totris play decreases during
training in proporticin in improvement Il'l
performance. suggesting a shif'l and} from
hippocampal dependence learning ph?
tcaus

Three of the live patients produced it
total of eight reports of Teri-is- imugerg.
aeross three l'IlLll'llS. These reports .icmtmi-
cd for 7.4% of all hypnagogic reports col-
lected, to diet seen Ill normal pur-
ticipants lTZ'l?u: F1g. In contrast.
there was only a single report ofa Ihuught
about Tctris wuhoul clearly associated iin-
agery Fig. As with the ??rll1?ll
participants. The visual imagery reported
was highly stereotyped (34]

Normal cunirols pi'iur experi-
ence- playing Tctris had first game scorn
averaging 73h. signi?cantly higher Ih:in
that of the umncsics ll?l They showed
considerable improvement in performance
over the 3 days and nix lFip. Ii
{36 l. The appearance of hypnagogic Tetra
images in nuwces was very ln lhot
seen Nine of ill nuv-
ices produced a ioial of 19' reports of Tulrle
imagery over two Itighls of recording. a
rL'p?i'l rule very similar To That of fill.?
nc-sies (Fig. 2M. imagery dE?SEl?thtl
showed ihe some highly slereon'pcd cur-
tool as seen Willi the Ein?lnC?ilES if]. 5.3m .
iucs produced I: reports of lhoughls of
Tctris n?ithoui imagery lFig. Such re-
ports. clearly linked to declarative mung-
rics. were virtually absent ii: the amnesia?.

ninety percent reports tvitli images
from those novices ll'i' out of were uh-
taincd on rhe second night In contrast~ two.
thirds of the reports of thoughts alone out
of ill occurred on the firsi nighi {Fig ll
Although this difference in disiribuuons is

'13 OCTOEEH BUBBva?ALSEgg?Nstciencemagorg



LAW ENFORCEMENT

Dowmoaded lrom on January 14. 2010

Item ?19 01?23

highly signi?cant lid}. ?irther studies Will he
needed to con?rm the ?nding. Nevertheless.
the distribution of images is not what would
he expected tithe. images were the product of
either demand characteristics or it simple and
replay of recent. repetitive, sensory
stimuli

?xorittal participants Willi calensn-e ex-
perience playing Tetrts- but who in general
had no recent praclicc produced high
scores from the start and showed no signif-
icant improvement over the six sessions
il?tg Ii (Elli. Nevertheless. the}.i also pro-
dueeo' hypnagogic Tetrts imagery. Over the
three nights, 5 ofthe lt'J experts produced
ll reports of hypnagogic imagery.r
i4 T?lt?. ot'235 reponsi. as well its 13 reports
of thoughts without images 6.5% of 235
rcportsi ?ts With the other groups. the im-
agei'y reported was stereotyped t3?. In
addition to these stereotyped images. two
ol' the live experts who reported Tetris
imagery described images from earlier wet-
shim-i of the game. which they had not
played in the last 1 or 5 years.
{It in these cases. the image constmenon
process follntitred associative links and in-
mrporatcd older memories in preference to
images from recent play.

Normal participants {ttovtces and ex-
pei'ts eotnbinedi showed signi?cantly dil?
lt?lt?l'll' for repons of images and
though.? across the sleep onset period [Fig.
?lter an Initial 2 5-fold increase From
presleep to IS 9 into sleep (45% compared
utth I the frequency of Tetris imag-
es lhen dropped In afterjusl
I ITltl?I In contrast. thoughts about Tetris
dropped in halfhetween tht: period
?lid :5 5 into sleep {7 3 to and then
remained constant across the next 3 min

it

l'f-i. :tt 3 min]
6000


3 cool) --

.
ti:
on
eooc- J.
to

I 1'





Test session

Fig. 1. Game performance. Mean Scores, aver-
aged across participants, for each p13)f session.
Participants receive about 20 points for each
piece put into play. Session is first game
score of first session. Solid circles. experts: open
circles. novices: hatched circles. amnesics. Error
bars SEM.

ManningB_ODD45623

REPORTS

Identifying the sources of memories
used in dream construction ts eon-
tingem on the investigator's SuhleCllh'i'.? tn~
of obs?utc symbolic transfor-
mation: of the original memory or on the
dreamcr's onit subjective evaluation lo the
case or" hypnagogic reports oi? Telris untie-
es. no such interpretations are
needed Only reports that de-
scribed images or thoughts related to Terms
were counted. indeed. what was most
ing about the data was the strong similarin
in reports from different indit-itluals. In all
cases. reported images included seeing
Tetrts pieces. usually Falling in from of
one?s eyes and sometimes rotating or fitting
into empty spaces at the bottom of the
screen. On rare occasions. participants also
reported seeing completed lines disappear-
ting. Among the 38 reports ot'intagcry. there
were no reports of hitting the picture sur-
rounding the play ltrain-?ow. the Scoreboard.
or the keyboard or of typing on the key?
board. and there were only two reports of
Seeing the eompuim itself. in none of them:
reports did the iningcn' appear bilarre
None appeared ll'l inappropriate settings or
associated with inappropriate thoughts.

in addition to collecting hypnagogie re-
ports at sleep onset. participants were also
instructed to report any thoughts. images. or
feelings about Tetris that occurred at other
times. Seven of 2 noriccs and 4 of It}
experts reported a total til-J4 images ofTetrtr.
during waking As hypnagogtc images.
the vast majority of daytime images occurred
only.r after a 24-hour delay. Will] only? four
reports [it?tr'ii occurring on the ?rst do}: of play
tilt. Thus, the production of this imagery is
not limited to the sleep state but can occur in
waiting :is well Two spontaneous reports of
hypnagnpic Tetris imagery were repnned by
'l?iu't?IiLCS at sleep onsets other than when c0m~
outer-initiated were performed.
These included one report of sleep onset trn-
agery from an afternoon nap on the first day
of the protocol and one of sleep onset after a
spontaneous awakening on the

Fig. 2. Report frequenv
cies. For each partici-
pant group. the cumu?
lative number of re-
ports containing vi?
sual images of Tetris or
(B) thoughts of Tetris
without imagras is giv-
en. normalited to the
total number of reports
collected across threa-
nights. Reports from
novices were collected
on only the ?rst two
nights. and graph

to
a9

Novices
6%

no
a?

?s of reports {cumulative}

as

Cl 1

Night

Images
Amnesia?

2

0028?1 17

third night. These images. both conceivably
sleep onset REM rcporis. were more complex
and bizarre than the others in our sample
{34.1.

The questions of how material is selected
for and then incorporated into dreams :tnd
what this entire process scores to-
tnain largely unresolteri. But the tint: pre-
sented here. looking at sleep onset hypnago-
git imagery. prowde some into these
isues.

Out of 2? participants. l't' i'tiJ'i'ui reportr
ed stereotypical hypnagogic images ofTe-
iris during the first nights of play. integer}-
clearly induced by the earlier Telris play
Unlike the images of REM sleep dreams.
these images were relatively accurate. rcp?
resentations of the actual Visual iinairery
perceived during play ol? the prime. allteit
abstracted. with removal of notiESsential
grime elements. This higth consistent im-
agery across partteipants and groups sug-
gests that image 1? all group:-
estracted and abstracted the mast salient
aspects of the experience by a similar piti?
ccss. This. along with the report ritie Front
antnesie participants. argues strongly
against demand characreristics playing a
major role in the production of reports of
Tetris imagery {3:31.

The apparent 24-hour delay between the
start of plat.r and the subsequent appearance
of gain: images in the reports of
suggests that the rules for selection of li'l?lv
ages for incorporal?t0n at sleep onset 10'
?wires ti complex algorithm. Similar lags
have also been reported between patting
experiences and their apparent incorpora-
tion into REM dreams its _iit'i_ The
course of appearance of Term images
across the sleep onset period rs ulsu strik-
ing. The rapid decay in frequency rut" l'etris
images across the first 2 to 3 min of sleep
occurred in the liter: of it stead} or eten
rising rate of report of images in general
over this time interval Thus the
occurrence Tetris images seems
uniquely linked to sleep onset itself.

Thoughts


5%
4579

2%

Expens

1 2 3
Night

of reports {Cumulative}

points are normalized tor three nights. The upward curvature of the comes in indicates that reported
frequency of images increased across the nights. whereas the downward curvature In (B) indicates that
the frequency of thoughts alone decreased across nights

Uggtg?pv 13 DUDBER 2000

LAW ENFORCEMENT SENSITWE

from on Januaryr 14. 2010

351

\u

352

EPCD 111-10. Item 19 of 23
Hr

Fig. 3. Images and thoughts of

Tetris across the sleep onset pe- -
ri'od. Percentage of reports
collected before sleep onset
(Waite) and after sleep onset
{sleep} that contained either im-
ages of Tetris {solid bars] or
thought of Tetris without images
[open bars). Although thoughts
were most common in the
presleep period. images were
most common after sleep Onset:
the difference was significant
{chi-square test. if - 4.5. df
l. 0.033}. (I) Percentage of
reports collected after sleep on?
set that contained either images
of Tetris (solid circles] or
thoughts of Tetris without imag?
es [open circles]. Although the

10% ?r

?l

i

Percent of reports



D?fu

Wake Sleep

REPORTS



0 so 120
Sleep time {soc}

frequencyI of thoughts remained constant over the 3 min of sleep onset (P 0.4), the frequency
of images decreased with increasing periods of sleep from 11.0.86,

df 3. ops).

ISL-cause reported images originated
from recent experiences. one might assume
lhiit hypnagogic image construction is int:-
diatcd by hippocampal declarative
Our dala argue mains: this
assumption. If image simply
reflected t'eacti?i'alion of recon: memories.
the images should have been most common
on the ?rst night. instead. only ltl'lrii of the
images reported by novices occurred on
the ?rst night. whereas 909's} Occurred on
the sccond night. Two at" live exports reported
imager incorporating abstracted dctails From
Tclris that look place i to 5 years
These reports underscore the infinimcc
of remote memoncs [that may be less depen-
dent nn hippocriinpal on Image cou-
s:iuciion. Most is the presence oft?iicso
same image: in the hypnagogic reports from
All ofthc patients ?on: densely :im-
l'letlL! and could not produce dcclarnlii'c mom-
uric-i iil' cicnls none of them
remembered the Ten-is game or the experiment?
from out: soy-sum to next Hill. Tiicat:
participants produced hypnagtigic? images of
cont ci-ciils eli'cn lhougli the}I did nol have
of them. The idea than
the declarative memory system is not active at
sleep onset is further supportcd by the results of
Wyatt id tell. who dcmoreatralcd tilt".
explicit recall of words and word pairs was
impaired which words were presented 3
min of sleep tll?th?l.

Tiic preservation of hypnagogic
images ll?. suggests that :hcy do not
depend on medial temporal structures It'lr
waited in declarative nicmon' HUI. Instead.
it is Iii-ccly that these perceptual
Il??h are mediated by implied l'l?tL?l?t'lOl'y pro-
cesses. as seen in other studies With amne-
II should lac noted thin
the unincsics were substantially older than
slit: normal notices and that tho
til Hny .in alternative explanation

thin tsii'. rennin: further :nt-estiphtioh.

This lack of hippocampal involi?cniciit
in image construction could explain many
of the formal properties of dreams lJOl
Without lht: anchor of temporal and spatial
associations Found in hippocanipnl declar-
Ilil?u'C memories. mucli ot'lho of
dreams. including their
congrtiitics. and uncertainties would
appear alinosli inevitable. This would be
especially ttlu: dunno:I REM sleep. when
there is ct idenre not only ihiit hippocampal
is hlticked hut also Iliat it-eiilt
associations in cortical memory systems
are preferentially accessed thus the
hypnagogic report from an afternoon nap of
Terri's pieces tailing onlo a pardon path


We have very Eililc information con-
the function of those images or of?
ihe physiological processes underlying
them. The probability of having Telris i111-
:ing for both the nowch and export groups
was intensely i'clatcd to initial poii'oiv
mancc. suggesting a relation to the learning
process itself {Jill} Experts incorporated
roiaicd from carlicr play. incrim-
rics that were presumably activated by the
recent Tclris play. One possible function
for the of lhesu memories would
he to alter lilClr structures. or
in ways that are adaptive for
the organism. With such predictable ?1550-
cnitions being made and presumany
at sleep onset. Hill: can only
surmise that during REM sleep more tin-
predictable. potentially valuable. but fic-
useless. associations are and.
when appropriate. Sll?lillal?i}' strengthened

References and Notes

1 Frost. North of Boston Holt. New York.
Frost described the sensation in his ?Eii-t aoer'n ?Mte'
ApplerPica-ng"
I was well

JIM-IN

20

0028-1 011?

Upoo my way to sleep

Arid i could tell

what form my dreaming was about to take
Magni?ed apples appear and disappear.
Stern end and blossom end.

And every lit-ck of tusset showing dear

My instep arch not only keeps the ache.

It keeps the pressure of a ladder-round

I Feel the ladder may as the Dough; band
B. Hebh. Rev 1'5. 466 [1963}

. L. Schacter. Rev. BS. 452
. 3t Greenberg, C. Pearlman. Mayer, Harte-anti.

ill-fen Gen 18. 203 {1963]

-t Cathala. Lallont. Esnaul'i. i: Sereni
Sitsou. Neurophysioi ?lm 13. 1TB [198%]

tniiobus. 20. 56? [1933]

Foulltes, Dream-1mg A
Analysis (Enhanm. Hillsdale. 1935]

Dot-nhofl, Finding Meaning in Dreams A Quain-
tirari?ve Approach (Plenum. New York, 1996}

Families ano Ci. Vogel.J Abnorm F'syicl?iol 70. 231
pass:-

1. Rowles. it. Stickgold. J. A. Hobs-tin. Conscious Cogn
?r 6? {1998)

A Mawornatis. Hypnagogi?a The Unique State of
Consciousness Betwtten Waitcfuln?s and {Rout-
iedge 8r Kegan Paul. London. 198-7}

. SchitLtei. Bull. 83. 452 {19?53

Greenberg and C. A. Pearlman, Pamper! Biol Med
17, 513 [1974i

. C. snitch Behav Brain Res 59. [1995)

Hennevin. Hers. Mano, Bloch. Sena-i.- strain
Res 69, 125 {1995}

Sticlgold. Trends Cogn Sc: 2. 454 {1993]

The Macintosh of Telrls [copyright 1933.
Sphere, Inc] was entail-ed irorn Spectrorn HoloByte
[Alameda. CAI For a mole complete descripticin of
the game. see Science Dnlme

Sessions began hem-2M and 11 am and between
and 11 pm

Novices were 13 to 25 years old, had less than ?In
hours of lileurrie video game eiperience. and had
no prior experience with Tetrls Experts were also
1it to 25 years old lhey averaged over hours
at liietinie experience with Hum [50 to 500
hoursl but only one participant reported having
played In the 3 weeks before testing Amnesic
patients were 21 to 62 years old {42.3
and were all apparently at: had EIIPHSWE
medial temporal lobe damage, including the hip?
potarnpal loimation three snltered lesions sec-
ondary to anciria. one to Herpes SimplEI. enceph-
alitis. and one to a cerebrovascular accident. Pa-
tients had i2 to at: years oi education :15 2 3 6
years] They had normal {as [WEchsler Adult 'ri-
teltigence Scale Ill. - 9e it] but severer
impaired memory function) {Wechsler Memory-
Scaie Ill?General Memory point 436 32]

Additional test results can he
found on Science Quinn: {51) All participants pro-
moter: internal. review hoard-approved informed
consent before participation in the study Partici-
pants in the three g'oiips provided similar mot" hers
ol hypnagogic reports. Vow-ices averaged 7.6 re-
ports per night. experts i" 8 per night. and arr-ne-
siacs 2 per night In addition, nonamnesic panic-
ipants were instructed to (any recordEr
them during the day and report any occurrences o?l
?thoughts. images. OI ieeI-ngs' related to Tetns
that they experienced while awate Reports Front-
nor-amnestcs were dlctaled MTG Pearlcorder 59%
hand?lied microcassette recorders :hitt autorrei'

rally stamped the tune anc? date onto the record

trig, Those ?rorn amnesics were recorded by the
experimenter. who in cases prompted 9hr- pa-
tient For the repar't, often as a supplement to the
CUmputer-gene-?ated prompt Novices were probed
during the lust two nights of play. as were i of the
10 aspects the has? at the data iron? these
the final sewn espeIts and all amne

siacs were crowd for :hree nights

awakening was done with the Night-
cep sleep monitoring system as described by Row-
ley or .ii' HG). Report: were collected horn the

13 OCTOBER

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presleep period. when participants were attempt-
ing to {all asleep. as well as alter intervals ol '5 to
180 of sleep. during the first hour after
participants retired for the night Muitiple lorced
awakenings were made each night. in pseudoran-
dorn Order. balanced across participants and nignts.
alter IS. TS 120 and 180 of eyelid quies-
cence and additional reports were requested
ether 3 E. and 9 mm or wake belore the initial sleep
onset and alter 3 min ol? wake alter any forced
awaken-ops. When such wait: periods occurred
There were a maximum of to report requests per
night and no more than 5 from periods at wake
The two periods at sleep [15 to 180 s] produced
between ?5 and 55 reports each. there were 154
walie state reports Frequencies of requests and
reports at Tetiis imagery or thoughts did not diller
significantly between notices and experts. Partici-
pants were instructed to dictate reports at any
"thoughts. images. 0r feeiings" that they were
experiencing belore being prompted to report or_ if
appropriate. to state that there were none Partic-
ipanrs were normally awakened by digitized voice
recordings ohm the computEr an appro-
priate wake or sleep interval and Instructed to
dictate their reports into microcassette recorders
In some cases, amnesic participants were awali-
ened by the experimenter

Because ol missed sessions. indwidual patients
played four to so: sessions Repeated measures anal-
ysis of variance showed significant Il'l'l-
provernent over four sessions [it S. 665
000?] All patients at least 13 games
during the First session and showed no significant
-iernent across these IBganies [individuals i- r.
011 03 Ear each.group i 0111.9 - H.951 By
contrast. age-matched normal novices [51 I 3?
i[rears] all showed Signi?cant improvement [ll'ldlli'ldu-
ais 5. 933 Far each: group DH. -
00005] and Improved an average or INK across the
our session The 3656 increase across in settioris
teen in patients is comparable to the 29% Increase
seen over six sessions in a single arr-mess: patient by
winter [52]

it Haier er al.. Brain Res 570. 134 [1992}
Normals. Consisting of 12 novices and 10 experts.
produced a total of 30 repairs of Tetris imagery in
413 reports (so? tutti.

In all cases. reported images included Tetris-iilre
shapes. usually falling Il'i front of the partiCipants
eyes and sometimes rotating or titring together In
no case did the participant report seeing or touch-
ing the keyboard or actually playing the game and
in no case was the imagery seen in inappropriate
contests Thus. one amnesic reported. "i was iust
trying to figure out those shapes and how to get
them aligned" day whereas another report-
ed "thinking about little squares coming down on a
Screen and trying to put them in place" IP15 day
3} a third amnesic reported seeing "images that
are turned on their side I don't know what they are
from. I I could remember. but they are like
blocks" clayr Despite references to "those
shapes" an: "a sCreeri.? participants gave no indi?
cation ol recalling the origin 0' these images.
turner they appear to be images at events for
which they had no conscious recollection
?wo-taiiedt test. til ?l-t_t 3 i0 0.00% ran
this and all D?I'l'lEf analyses ol novice scores. one
participant whose initial game Score was 24 SD
above the mean of the either It novrces. was
extruded

Repeated measures ANOVA across the 1;in: game
and siir sessions of - T. i3 c. 00001
Post-"cc contrasts showed significant improve-
ments after the lirst game r. 0.0001) and lust
[9 retond 0005} and third a
00"] sessions there was a trend toward additionai
improvement alter the fourth session as well

CI 1 i}



Manning 0045625

REPORTS

Thus. one participant reported. "I?m Just watching
tiles doom" its-i}l whereas another
reported. "I'm rotating it and I'm Fitting the blocks
in like I'm supposed to" [Al-l clay 2] A third
reported ?iust seeing Tetris shapes ?oating around
in my head like they would in the gar-ire. tailing
down sort 0' putting them together in my rnind?
day 2] It should be emphaslred that none of
these reports described episodic memories For
exampie. no one reported being in therr ioom
Sitting at their desk. or using their computer its
the amnESIcs. the images occurred Without
reference to time or place and appeared. rather. to
be eitracted and abstracted from the actual
eiipErience

Chi-square test: 1&6. d! a D001 for
reports: if -- 2. df 004 Ior participants.
01 the 10 participants. only one had played withm
the last 3 weeks. and two had not played in the
previous year

Repeated measures ANDVA across the first game
and siir sessions.- of a E. 24 O30
Reported imagery included ?a Tetris screen and the
pieces fitting together in various ways? dayr
and seeing. in my mind how the game pieces
kind ol float down and lit into the other pieces. and
am also rotating them' day 2]

One expert reported. "Its Weird because I dont
see it the way we play it on this computer I see it like
I used to pay it at home where its in different colors
and stull him that and the boxes look a little d'ih?er-
ent" She also reported heanng the music that ac?
companied the game on her Original Nintendo tier-
sion whereas the version used in the experiment was
silent.

Binomial distribution anaysis 0 until

in one instance. the participant reported dozing oil
In the afternoon while "thinking about a project I
have for work that inroliies designing a garden
space indoors and as I was Thl?ll?g about it in my
mum little Tetris pieces kept falling down into the
garden spaces. which they wouldn?t really [do]
because Ithey aref geometrical and garden spaces
are nice and towing."

One concern in this study was whether demand
characteristics wood bias participants to report
Tetris images when they slid not. in fact. occur.
Several aspects of the actual reports argue against
this The reports lrorn amnesics obvrously were not
Fabricated to please us. because participants could
not euan remember that they had played Tetrrs
Second. the eirtreme similarity between reports
would not he expected. Thus. we receiined no
reports tii'I paninparits "playing' Tetris. which we
would have espected 'Erorn invented reports. in
addition. the preponderance of images from nov-
Ices 0n the second night and the higher rate of
Images reported alter sleep onset compared with
the presteep period are counterintuitwe To the
Expectations DI demand characteristics. A mdre
subt'i.? concern or that more general geometric
images were being interpreted as let'is images *0
Jooli for nonspecific effects, we searched the teiit
ol 3'95 hypnagogic from an earlier study
(to: for the words squait[s[. rectangl?s]. itar[s).
diamoni?s] biockjs]. geometr?yjc]. sparklge mg}.
it]. shapelsj. pattein[s]. tiie[s].
Pauling]. rotat[e adios}. tornied].
Tetris, gain-ills]. screenls?l, and wdeo[s]
Only ?Du' "rimm- contained these words in
relevant forms [e 3. references :0 Harvard
"Square?. "Star" Tree. 'la .ing? asleep and being
out of "shape.' were excluded! The words rectan?
gle. diamond. sparkling kaleidoscope, tile. goon-iat-
ric rotate. and Tetris did not appear any content
Taken together. these ?ndings suggest that there is
no irnoortant contamination at our data from re-
sponses to demand characteristics although the
possibility oF some minimal contribution cannot be
eliminated

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LAW ENFORCEMENT SENSITIVE

36Jouvet Ann Practicieri 29. 2? [Hrs]

It ii. Powell. 1' A Nielsen] Cheung. Cer-
uenlta. Percept Mot Skills 31. 95 [1995]

A Nielsen and it ill. Powell. Lin-v Orr
14. 551 [1989)

On one occasion. alter playing he' evening session
of Tetris. participant showered and put on her
pajamas in preparat-on lor bed Upon returning to
her bedroom she was clearly surprised to lino the
experimenter sitting by nor bed. and asked him.
"Who are you. and what are you? doing in my
bedroom" Nevertheless. she subsequently pro-
duced hypnagcigic Tetris Imagew The complete
dissociation of rriemoiy from hypnagog-c
imagery was seen most clearlyI In the case at DP.
who explicitly reported being unaware ol the
sciurce cl thesa images

K.Wyatt.ll F. Boots-n] Anthony} Eater-it. Sleep
1? see [1994}

Wyatt. R. It. ?ootsrni 5 Alan] Anthony.
Sleep 20. [199?]

Squire, Fiychol. Rev 99 191 [1952)

Schacter and Tultiing Memory systems l99d
Press. Cambridge MA. 19941

and Keane. in varieties of Unicorn
scious Processing NM Findings and New Compari-
sons, 3. Degrlder. E. De Haan. i: Heywood. 5:15 in
Press.

and O'Connor. Serum Neuroi, in
press

A Hobson. the Dreaming dram [hasic Books New
\?orli. 19551.

. . 5 A. Holfrrian. C1 Kostner. Hum
Neurobiol E. 157 [193?]

G. Bots?lu. Cerebr Cortex 6. El {1995]

ii. Stickgold. soon. Riitenhouse. i ii Hobson.
Coon Neurosci 11. 182 [1999]

The 3 novices [out all 2 who produced no rpports oi
Ferris images periormed twrce as well at the remain.
ing. 9 during the initial 2-hour training [mean
scores 2934 compared with 1516. unpaired test
10. l' - 369. Similarly lhenumtier
of Tetns images reported by experts showed a neg-
ative correlation with initiai parlormance that tip
preached significance It" - -D?3d d' II
Amnesrcs showed a Sii'mlar negative correlation out
it did not approach slgnificance [r 0-15. of 1.
01]. Thus. Tetns imagery was negatively coire~
lated with initial performance.
Supplementary material is available at
seiericernag orgflea?lurefdatai' 105005 .7 shl.
W. Winter. implicit and explicit cognitive functioning
in hippocarnpai amnesei Hicroloinri 96135632.
Jinn Arbor. 1995}

Total numbers of hypnagogic repurts and 0? par-
iicipants reporting images and thoughts were as
lollows. matrices [open circles} 133 reports 12
participants. 9 of whom promised 19 reports
01? images and ii 0" whom gave 1.1 reports a'
thoughts without images. experts [tilled circies]
235 reports 'rom 10 participants. 5 ol whom
gave 11 reports Images and 5 ol wit-0?? [509th
gave 13 reports of thoughts without images and
amnesics [hatched circles]. 103 reports from 5
partitipants. 3 ol whom pioirioii 3 reports at
images ano 1 of whom repertec a single
thought with-put images.

This research was supported by a giant from the
MacArthur Foundation's Mind-Body by
Natlonal Institute of Mental Health grants MH-
13323 and and by National institute
of Neurological Disorders and Stroiie program
project grant NSEEQES We thank an anonymous
reviewer for suggesting the analysis of reports by
s'er-p fir-ii,-



2 March accepted 1 September coop

SCIENCE VOL 290 13 OCTOBER 2000

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EPCD 11140 Item 2001?23




PA

Hm mum: PUBLHS POLICY



DER PEOPLE. THE US.
SUMMARY AND OF TH 2008
TRANSGENDER AMERICAN VETERANS ASSOCIATION SURVEY

\Vhitepapcr pruparcd {hr 'ihc Palm (WaiterE
and the Tram-gander Amwrican Veterans
n. - -
by karl Bryant, PHD and PHD-

AUU ST 2808

I i" (.xr'li?2.rJilpri a I If: I
Pr'd: in. ?inst1.'i'L .WI-den - LAW ENFORCEMENT SENSITIVE

"M?hhihg??omseze

EPCD 111-10. Item 20 of 23 0028?1













































TABLE OF CONTENTS

Overview 1
Executive Summary ofKev Findings 1
Iiilletliodolog)r 1
A Note on our 'l'erminologv 2
Background on Transgender People in the Military.r 3
Demographics Survey Participants 3
Experiences oFDiscriminarion Outside ofthe Militaryr 5
Transgender Service Members and the "Don't ask. don't tell? Policy
Transgender Veterans? Experiences with the Veterans Adminisrration 7
Research Summary

Research Implications and Recommendations

Appendix A: Survey Participant Characteristics 1 1
Appendix B: TAVA Transgender Veterans Survey Questions 15

LIST or FIGURES
Figure One: Branch oFServicc 4
Figure Two: Gender Identities 4
Figure Three: Gender Expressions 5
Figure Four: Forms and Prevalence ofDisci-imination and Violence 6
Figure Five: Examples oFTreatments Accessed at VA Hospitals 3
HST OF [5

Table One: General Demographic Characterisrics 11
Table Two: Socioeconomic Characteristics 12.
Table Three: Gender Identity. Expression, and Sexual Orientation 13
Table Four: Military Service Characeerisrics

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EPCD 111-10, item 20 of 23 . ?1D1?i?

1'

OVERVIEW

This paper reports ?ndings from a survey oftransgendet service members and veterans designed and admininered
by the Transgender American Veterans Association TAVA was founded in 2003 with the goal ofensur?
ing that transgender militar}r veterans receive fair. equitable. and digni?ed treatment From Veterans Association
(VA) Hospitals.? The resulting survey,r data produced compelling ?ndings indicating that transgender service
members and veterans. like many transgender people in the 1.7.5.. face various forms oi?discrimination based on
their transgender Status. Transgender people in particular Faced discrimination while serving in the military. as
well as when they accessed or tried to ateess services through VA Hospitals.

EXECUTIVE SU MMARY OF KEY Fl DINGS
This survey produced the ?rst major empirical data on transgender people in the military. The key ?ndings from
the 82? surveys1 ?lled out by US. military veterans and active-service personnel included;

1 Survey participants ranged across all branches ofthe service. with the highest proportion having
served in the Army or Navy

0 Nearly one third ofrhe survey participants reported having experienced some form ofdiscrimi-
nation in the workplace: the same amount reported some Other Form ofnon-employment related
discrimination. such as being unable to obtain identi?cation documents that re?ecred their new
name and gender.

I Ofthe 660 participants who identi?ed as transsexual. 97% reported the}; were unable to transi-
tion before leaving the military.

A full 33% oi'survcv respondents reported that when the)? were in the military. people suspected
or asked ifrhev were gay. In addition. 14% had been quesrioned be an of?cer about their
sexual orientation.

0 These violations of"don't ask. don't tell" varied by gender. 'I'ransmen were almost two times
more lilter to report they were suspecred ofbeing gay than transwomen.

9 About a third ofthose using the VA hospital had broached the subject ot'medicaJ gender transiv
tions with the VA sraii'. Most ofthem had their requests denied.

0 Respondents reported organizational discrimination at the VA in a lack ofclear and consistent
ptaCtiee. with little support For gender transitions. In addition. there were many reports oFinrerr
personal discrimination. via lack from VA doctors. non-medical Staff. and nurses

METHODOLOGY

TAVA designed their survey to capture a broad swath of" the life experiences. both military and non?military.
of transgender service members and veterans. The survey collected data on demographics gender identity.
income). military history (tug. rank. years served), discrimination in the military. discrimination outside of the
military (cg. employment. housing]. and experiences with VA Hospitals. The ?nal survey instrument had 11?
?xed answer and open response quesnons and was administered on-Iine From the 13th of December 2007 to the
15: oiiMay 2008.5



1 missmn sutement and Further Information about theorganizatlon can be found at

I000 respondents tools all or pan ot'the survey. However. not all Indicated that they had served or one or more branches or'tht US- military. For the
analysis presented herein. we include response data only from the 827 respondents who completed all or part ofthe survey and who also indicated
that their had sewed {or were currently serving} in the U. 5. A1: Forte. Armv, Marines. Navy. Coast lCuard. Air National Guard. National Searcher
Reserves [anv branch].

\v The survey was created and administered using surrey monhc For a complete list not-survey questions. see Appendix

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EPCD 111-10. Item 20 of 23 . .
-

Collecting a random sample of transgender people is not possible, as the numerical bounds of the population

are unknown.i Transgender people also are widely dispersed geographically (meaning there are no transgender
enclaves to sample from) and are often hidden due to societal stigma. These issues preclude gathering a random
sample of the population of transgender people through traditional means (mailings. telephone calls, etc). To
get participants, TAVA used a convenience sampling method.? TAVA listserv members were invited to take the
survey: in addition. the survey was Featured prominently on TAVA's Website. as well as on the websites oFmany
LGBT organizations. and on transgender-related websites and bliogs.IE The non-randomization ol?the dam collec-
tion means it is not possible to state with con?dence that the findings are representative oi'the US. transgender
population. Hiawever. as there is so little data on transgender people in the military. these data Still provide an
important Fit-5t step toward illuminating the experiences ofmembers ofthis group.

The data From this survey Face Several sources of potential bias. First. as the survey was administered on?linc.
there was no way to veriFy itpartieipants were actually transgender service members or veterans. Second. on?line
surveys create a bias toward higher socio?economieal classes. as lower income individuals are less likely to have
access to the lnternet. Finally. the advertising of the survey on LGBT websites limits participants to those who
feel comfortable accessing such sites. As such. there is a pocential exclusion oftransgender people who are Hdeep
stealth" - a community term that refers to people who have undergone a gender transition and maintain no ties
to a transgender and r?or LGBT community.

A NOTE ON OUR TERMINOLOGY

Terminology about individuals who live in a gender other than the one they were assigned at birth has been
changing rapidly in the last twenty years. Hisrorieally, these individuals have been referred to as "transsexuals" - a
term developed by the community in the 19405: With the rise activism in the 19905,
?transgender? came into more common usage as an umbrella term for a wide variety oFgender identities that
could be labeled by sodety as non-traditional.a Transgender. as such, could include people who seek to live in a
gender other than that which they were assigned at birth. Feminine men. and masculine women. The terms "Fev
malevto-male" {sometimes abbreviated FTMJ and "transmei'i'" often are used to refer to Female-bodied individuals
(tag. people assigned female at birth] who personally identify as male or masculine. The terms "male?to-iiemale"
(sometimes abbreviated MTF) and "transwonien" o?en are used to refer to male-bodied individuals (Lg. people
assigned male at birth;lI who personally identify as female or Feminine. The term "transgender" also can include
male?tn-Female and female?to?male crossdressers individuals who wear clothing not commonly associated with
their birth gender. occasiOnally or Frequently, but do not plan on undergoing gender transitions. Interseir people
- individuals born with a variety ofconditions where reprodueti've and sexual anatomy does not Fall within the
common definitions of male and Female may also consider themselves trar?gender.?1

To Fully understand the experiences of transgender people requires a working knowledge of the distinctions
between sex. gender. and sexual orientation. "Male" and ?female? are biological seit categories generally linked

The exact size of the transgender population is a topic debate Conservative estimates place them as about .[HlH?Hiofthe population. while
other estimates place them at closer to .9496. For a wider discussion this issue. see Conway. 200i. "How frequently does tnnhesuallsm tic-
eue?" Accessed February 9.1003

5 Most research conducted with transgendcr people ages a convenience sampling method. due to the impossibility of generating a random sample.
Transgendrr people typical iy are recruited from sup port and social groups. or From listserves and on-linc communities. For other examples ofthis
method. see Anne Holin. 1938. In mirth gin-e: "Ii-annefo rites ofpasmgr. South Hadley, MA: Bergin and Garvey; Finite Lawrence. 2003-. 0Factors
associated With satisfaction or regret following male?to-feinale sex reassign-merit of-S'rxruri' Behiimor 3-3: 299-315; Henry Rub1 n.
2603. Sty-made mien: Identity and em?ndi'mmr among transsexual mm. Nashville. TN: L'nivetsity I?rcss: Kristen Schilt. 2006. "just (me of
the gut-59 How transnien make gender Visible at work" Gender iti- Smirrii 20 pi]: 465 44550; Kristen Schilr and Cadaerme Comic-ll 2007 ?Do work?
place geiider transitions make gentler trouble?" Gender. l-?l-iirkmia' Organization 596-615.

The hole to the survey spread Virally. as many different people repeated the call for participants. This makes it impossible to provide an ethanstive list
of all the locations where potential participants could Find the survey link.

Seej'oanne 2002. thenged: it?stoic, quJr-znsirxmdism in Amen-.2. Cambridge: Harvard Universes Press.

For more information about the development oFthis term. seejaniiscin Green. 2004. Returning .: i?iizoi?r iviori. Nashville: Vanderbilt Universiti- Press
See the website ofthc Former lnterstt Society olNorth America [unvniisnaorgl For more information on intersexualiiy.

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_00045629

EPCD 111?10, Item 20 of 23 V.

to a set of. anatomical markets. including chromosomes and reproductive capacities. Gender identity is people?s
sense of themselves as men. weimen. andfor somewhere in between this gender binary. Gender expression is
how people present themselves to the world as masculine. Feminine. androgynous. or a combination ofany or all
of these elements. Finally. sexual orientation refers to the object ofpcople's sexual desire (cg. homosexual, het-
erosexual. bisexual}. As transgender people?s experiences reveal. these elements biological sex. gender identity.
gender cspression. and sexual orientation - are not sunk. and do not always Fall into a set and predictable pattern.
Rather. someone can be assigned male at birth. but have a gender identity and gender expression as a feminine
woman. And. she may identify as heterosexual, lesbian. bisexual. or some other sexual identity entirely.

BACKG ROUN on TRANSGENDER PEOPLE THE MILITARY

While there are very few studies that Focus speci?cally on transgender people serving in the US. military.? exist-
ing research indicates that military policies and practices negatively impact transgender. transsexual, and
identi?ed people in the L13. armed forces. For example. one report suggesred that:

On an inseitutional level. the US. military has taken the traditional Stand that non-traditional
gender identities Fall under the aegis ofdisease. in particular and that individu?
als claiming such identities are therefore to be removed from Service or to be prevented from

entering the service wherever and whenever possible.?

This approach to non-traditionally gendered people maniFeSts in Formal policy. For instance. the Army Medical
Services Standards of Medical Fitness include transsexualism and transvesrism (a label o?en applied
to among its "causes for rejection for appointment. enlistment. and induction."11 US. military
recruitment policies and practices deem transgender individuals mentally ill. and thus unsuitable for service. Fur-
ther. individuals who attempt to transition from male to female or female to male during military service ?may
be discharged under enlistment violations. as well as through rules relating to homosexuality or cross-dressing or
through being classi?ed as un?t or having a personality disorder."? Various Formal and informal
recruitment policies. enlistment rules. healthcare policies. and military case law'l concerning crossdressing and
gender transitioning negatively impact the lives oftransgender and non?ttaditionally gendered service members};
These policies and practices severely limit transgender service r'nei?nbersr ability to freely express non-normative

gender identities. and can result in extremely punitive actions.

UFMOG ICS ON TAVA SURVEY
Survey participants resided in leersc geographic regions from all over the United States. '7 Most were mid-lti to
older adultsHi and had been or were currently married.H The participants also represented diverse socioeconomic
characteristics. Abour halfofthe participants reported an annual income ofover $40,000, with the most typical
source ofincome being From full?time employment. Mon participants owned their own homes; those who
did not own their domicilcs were typically renters (34% oftotal)??

For the only peer renewed publication addressing transgender people in the US Military. I.cc George ll. Brown 1989. "Transsexual: in the military Flight into
hyperrnast ulinatyf (tn-Inter sfSruw' Behavior
"Tatryn Winch ?Geucier and the military Transgender. transsexual. and mt?iee-rdmr?ed individual; in The armed rorcee" Santa. Barbs?,

CA The Palm Center '3

Lj- Emil? ?Stn?dlrd! ot?medlca. tithes-a." All 10 in]. A. (cased August 3. .4 http-S. awry rrtr?llu?pa {CF?nib," put 2; I5 for


1 ?II?ittcn. "Lender identity. and the military" H.

Sec Us 297-193 A. WW: US Modesto. 39 K155 HEM.
Watch. identity and the mlilill}?
For mute information on the lull demographic pro?le olsurvt?y partmpanrs. see Appendix A

The large" proportion". tended 1n the Mid North stat-rs i?L KY. ll?vl. MN. MI. 13%l. . 'mtheaht states PA. DE. MD. Wt DC. lc'?l. South
state! t'l?N. NC . 5C. 521. AL. M5. Fl: or California! i Pill

e6 v: :1 or older.
Iii-Wt: had been married at some paint. 43% Were currently married to a person Ol-Ei?lc opposite sea

'All over lili'i- have been rounded in the nearest whole number an mu. paper

FOR USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_DDO45330

111-10, Item 20 of23 17

Surwy parrsapumx ranged new?: a? branch? :15 thu xvi-wry. Figm'r Una show-a, 15w ?111;th prupmtmu
in 133?35} wrMavy 113.1. lair-g:
mm?: w?m: an eni?xmi mu}: m-n- in :51: jumm'vniimt-j iunim
(sf 'crr i39?h'f. 3:111le ?fth-me swig: Npurtvd uf??ccr uni-:3. funmm?ium's made up {he Largo: fi?qj?rzi?n 69%?
Nari}: half- nF 1:51: a-N?ln} had m'wd in a mum'th mm: The 'L?Llnt Izmw?l?v wan: houuruiwiy
{Inchargusi thu sccniid hi3:in rcp?rt?f disiimfgt: hti?ng

ENSURE



















Arm-j Maw Am'r?orca Manatee. R4354?!an Mai!
{Emma

Figs?:- I'm: ?hum-y. 13w :dt?ntf?ni ?tm?dt'. in ta?r'n'u ui imw 11-53ch
the broader ui' 1hr Huag?rn?? rd: an the RITE:
burwcun and 2W: identi?ed 2.5 L'nhudrcaxcrh With 1h;
hams; limit-bmiwd. Th: run-naming {aura-d rimmuivu an 113:: FTM Ct'JrEti?ailm'l
.mmr: {Ichcr ?mam identity rat m1 Jungtr Multt??mi .ls' vr Emu-gender

i'i?LJi?iE bib-71H

HM

InEErsex Ma?a;
L1 Me ?ne: 3-H.
a

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43W?1'39 n-if run-r law-mum Ht '1 gnu}:-
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. . .

4m Luxunwr fiat?. mun-.1 .u a.
l-Iwuzr.? v: up?. - L'x 31-.

FOR USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_DUG45631

EFCD 111-10, Item 20 of 23 0928-10-510221-10117

.x IE I Thru- Iiimw-a. 'Iiu'tii'i mun akrrnai?mii li?rzi'u? :5 rank- {-115 time. Email {n tun :nmz.
3 1 LI r:
Inuit. muii Mm: Ewan? .13 {Irm?c HIE mm. mm:

i
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Hui em: {ii-NI

Ci)
?th?g'




Mai? Fewaae
Tune

Aiiemamg

..

Bumsc {armpit gum-ml}; k'l'allitlt in tin: milnas In {hair LITV Ecumgu fur-I, :3:er mic-n nut had a?u? uppurtunu'y
I31. ?mm'ml ability In LitIdIL-rmki? my Incdiagig?mi .1 Ef?lit?l' Iramit?un - .1 that um he IerrI-iI'Icij;
afapt'i'ljiivt. it" heady .lfc ?nvuh-ui. militari-
I'll'gtiil?nuih and a?turcpruvum from
Tim Inmru- IIuIzIsga-ndn' :Imi ?s'?dt?r rurmnz pulpit wrung tha- .?Irr: 'ii'lt'H try-H var Eh:-
a: the Ihu' m-rc .It Thirch frhu I-iuzm EIL- :11: gun-u- Eindmg that
reapmz?cma ?mri?cd .15 mid ihrj' trauma-3n byiul't' ill.?ng the miixmr?,
bu. typical I-xpcsicnw for Hum-man and gcndu' ma?imar {cunnic?syntiicd pmspic that rim-v Mu am:
wIiemrn whiitr arrv?ngi and flu: mil-itsary rape?ricut?r rmn?mnnm .uui In?nity tum?:
is rim: {ha-v :u mm willie: :I'rn'ing. :15. we dis-cum brinw. :hu Emmi cxpi'gsiitm Em
{Eti?m' in turn}; :q'urrmu?m. Intiming Elam? and ?d'wr {tannin-:1: wutihn

van-m: I'fliv'fl?khlfi'? and veterans.

Flii?fiiliiNiiflfh Di ?351.! :5
M?Irmring rugs-mg ruwnwh {11.21: Indiana?s riILIt ri?nz'mgfiuiur par-pic: cxpxiium': chum;-
rrmud tn thrir grader SL1er parragipamz; ripnrm? that {hay mu {incrim?raatms}.



3.1. 53:; aqua: {Handy-:41: -- 1r 5.1 i 31' 13?;

Lg. KEI-l?rr 51 :Irsn Ninth-:3} Elli?1'3 71m myth: min. mi; .5111: jig-min!
ts Li; 4ij tat-01c gain-9? 31-901. Riv-5c? E?Tuz'riit. 21.51ng! ?ung. and Haj-Junta ?I'm {Blah?r
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FOR OFFICJAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_UOO45632



EPCD 111-10. Item 20 of 23 IV ou2a~1m1uz214u1w

F3

and ether 9-3111? ul'swgatiu: trutmcm it: scruml .arism Hf {hear iivcx. 51:. Pagan.- Four simwa?. rum-1:: aru-
thm} puninpmu rt'pm'tud having cwpurimrcd mm: lira-TE? titlciihcrimimz?cm tin: Wu?!
appramzmalnl} LIN: mm: .m'mmi; Icp?f?hg Ehcjv? beliru-u' ?111)? had rm: hum Pun-d fur .: :ch apcc??u'mlv
Entrants; Wen: sung-mics: :31. Fed? 1?1?2'62 u?pzrr'tcsi timu ?nd {mm ?nzd From .i jub- ?uc hung
?nd; 40% of aims: graph: ha's'ing been ?tui rmm- 1m mach}- Nca?y {13% rupurwd experimch (Zip-Ell, Hams-n
i'mm :tr: empictyra: they mm:- mid thd: m; en. Etc-i313; fired {m
not hired} 13111.3.th tinny wan: ?H'Hrfi' was as} im??u'zum gunk-r .sz
cmpkaymcn: (incrimi?mion: mew: iikci; in 3:90;: {daring (incriminasmn wits-:3 Ihcy prawn-d ah
{cumin mimic mnn? ducmmumiml disc: :imr gut-?1k

Hume: 11.11;: 0% m: i-

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that

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{3 mJaazrd?hr??rirmnamm 'iim mm:
1111C Wurhpimrr Wu: dif?cult}- EUR. 3 muddy ranmui cxgurmun: {:21 a} [15* :mm-
pumpkf? 2135: ?urvt?y parraupmm that rhu- fmi 0.1" dif?cuitf.? obtaining



in tn dm's?: rim gram? A $1.1ng nil-writcnurx mt}: 1212Cfpti?5933; vmlumc.
163$: Ni?i?li'inld lath-mg; haw, t5?: vu-Eim ml. physical? x-iuicnm and 16% leaving nip-ml. Fm imd?t
awkward riparian? um} rvpurtcd {115:5 ni'viuh?ngc. 5:11"? .md parricipxnta rcpm?wd
Etiglwr umidcmm Em; die} mzih: (51' hum?: Them: :51 ml camgnuri
EMri?Ii a. 1m rowan-ad Emmy, ?51:51 farm and Huh-tin:

ism} ?ia?tf aimvc.

m?





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fiu'u :1 :vFJ-u in: m1"- 1' Ram: H:

\r 1'

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_UDD45633

EPCD 111-10. item 20 of 23 .v [3025-1 i?

TRANSG ENDER SERVICE EMBERS AND THF AS POUCY
Participants' responses indicated that they are impacted by the US. militaryls current "don't ash. don't tell"
(DADT) policy on homosexuality. even though that policy (the implementation oltitle 1i} United States Code?
6'34 or ?Policy Concerning Homosexuality in the Armed Forces"l is not designed to regulate service eligibility by
transgender people. A full 33% reported that when they were in the military. people suspeCted or directly asked
ii'they were gay. In addition. 14% had been questioned by an officer about their sexual orientation. For younger
respondents (aged 13?35). all ofwhorn had served under DADT. this ?nding was even more pronounced: 61%
reported that when they were in the military. people suspected or direetly asked ifthey were gay: 20% had been
questioned by an of?cer about their sexual orientation.

Such varied signi?cantly by gender. Transmen were almost two times more likely to report they were
suspected oF being gay than transwomen (72% vs. They were three times more likely than
to have been asked by an o?icer abour their sexual orientation (33% vs. These numbers suggest being
in the military as a prcetransition transman is a very dichrent experience than being in the military as a pre-
transition transwoman. and that DADT policies and homophobic military cultures di?'erentially impact these

two subpopulations.

What accounts for this gender difference may be the societal leeway for gender croSsing. For example, during
childhood girls can adopt masculine dress and behavior with little sanction, but boys cannot adopt Feminine
dress and behavior.15 While female?bodied people face pressure to conform to Feminine norms in adolescence
and adulthood.? they are still able to adopt masculine gender expressions, such as wearing pants. having short
haircuts, and not wearing makeup. Male-bodied people. in contrast. face Stigma. ridicule. and violence if they
adopt feminine gender expressions, such as wearingdresscs or make-up. These differences mean that pre-transition
transmen can be masculine?appearing women in the military more readily than pre?transition transwomen can be
feminine-appearing men. However. as masculine women ?t many people?s Stereotypes oilesbians, pro-transition
k" transmen who do adopt a masculine appearance seem to Face more open questioning of their Sexual orientation.
Thus. while masculine Female-bodied people are generally more tolerated than liemininc male-bodied people. this
may create a situation where pre-transition transmen r{yeho appear to others as masculine women] are more likely
to be targeted by anti-homosexual policies than are pro-transition rranswomen. who face many more pressures to

appear as normatively masculine men.

"The gender diliercnces found in this survey march ?ndings about the diflbrential impacr of DADT on women
versus men reported in other research. While women make up only 14% of the Army and 20% of the Air Force,
in some years they account for up to half ofdischarges via DADT in those branches of the military? Thus. just
as women in the military are disproportionately discharged through DADT, pte-transition transmen {who may
appear socially as masculine women} are diSpropo rtionately suspected of and quesrioned about being gay.

RANSGEN DER VETERANS. EXP Rl ENCES WITH THE VETE RAMS ADMIN
Only 29% of the sample currently used a VA hospital.? Transgender veterans who used the VA tended to be middle aged
or older. and not working For pay. 70% oFthose using the VA Fall between the ages 46% were retired. living 0n
social security. or living on some form of non-employment?relared income. 35% were unemployed due to disability. Only
2.3% were working Full-time For pay. Nearly two thirds ofthose who used the VA had an annual income ofless than
5313.000. with over one third malongless than 5 i 5.000 a year.

13% of those using VA hospitals identi?ed somewhere on the FTM spectrum. while 32% identi?ed somewhere
on the MTF spectrum. This gender breakdown te?ecrs the disproportionate amount tiimen in the military and



Sec. 3., Barrie Tnorne I995. Genderpiay; Girl's and be]: in school. New Erilnsu'lelt. NJ Rutgers University Press.

1" See. c.g.._ludith 1993. Fannie masculinity. Durham. NC: Duke Universe}; Press

Sec. (3.. Thom Shani-scrim? 13. 2003. "'Doii't ask don't tell' hits women much more The Netti limit Tom's. Stt'hon A7 p. l4.
33% with: sample reported that they had at one um: {currently or in the past) used The Us For primary care.

FOR OFFLCIAL USE ONLY
LAW ENFORCEMENT



111-10. Itern 20 of23 h,

zlzs: ?13.153: of MIN 63' idbum NW. of rim mtati watt-mm Hung
if): "Pk-13.1 Knit?!" QOH. EL 11., Hi. W1. MN, 3415?: wen: 3t. Eikriv us: the VA than drum: Fixing North
or ?zmrh, rhu gem-mi sum-c? who mcti the VA were Iiiu?f haw served ?at;
:X?ny 5.0m? ham-c}- ?mph, mes: af?uence 131:2}; VA im?cpimi? were imnm?wi?y dsquiurgitd

at ?isghamc? 4.!th him}.

Pigs?? fin? ilhm?: win} mz?zs?- mm.- !mm 511:: Vi?: ?ct?ll?cd a mrium hm'r?: rula?'gi .iztd rm;

retaacd tn Ehmng transgnindcr.

HW- EKAMPHH ?le f'ft'iHP?l'i(BID items-g n9ra~GiD
harmonies hormones therapy

whip: amp}: ?14;ng rumrd away :mm I'm- Vii {ha-r Ewing Ainmr .1 thin? :13? aim-u;
Wang tin: {unplug inn-E 15mm. de tilt mb?m?r ni'nn-dwu: 39:?ng zmm?umw with VA 3am. (IL-mud}; than,
??di?ridaidis snugh: imrmonu tharapjt. gummi surgcr}; .zmi fm' :mnyum - hex: ans-guy {duublc
unzi Thu magnum nprmui ham-mg ti:ch rugumts denied. Mam uucrans rcpumd
bring mid {imp}? ?am: :1 ita- Jakarta md mic-j VA pviicy. 5% my; Ira-pmadrrit nutch mm
Haiti-?1fi-?z?rmi' If}: I?l?vm faculfhxunmg Eva's? Quiy tam has} :1
sprii?c ma?a}; gram-?: ta them [u back up ii?: (incitir?f dam?. Eflmving that Rick in?lrs'nu} p?iiq?z anther
rc: di?k?t?m: 5mm:ng from (imam. ?1 mh?mf i?wghingen. {3m :fezh's?ss'im'rimx-
52:51?qu rim::' H3: {Man Him 251'? am x: m; '3 .eft'rm-m'. Lim- "11:1"ng rm; Saw?"cm? .11 ?1 tam-rd Hignmfizing

ms puma; th?if quantum. i? my mg: rim-5 rm; mm mm mm kwwy.?

few ix'epm'idcr'utx rupaarzui bang rurmd dawn rizur pmcL-durm {Eur m3 musicich mgdwaify mammary Eur their
birth gunfcr: p.13"! smuaru for frumiohmf?uf pump]: and Wam'n fur Huh-hundred. Wm; much
mum hr La?nic?e? wrgur?m Much hysterectnmim. ruasmuwmx? and urchiwt?nnc?,
Empt'mdmn dimrim Emit-Hm .-. Lick m" Lima: ind waning and lime: suppan
['le gaudy? Un?mium. In addirwh. their war?: n-gmjx ra?parrs LVi-i?iffp?f??ll?i ?Iixurimimnran. EL: L1: u?
from VA El?n}. mm mcdimi um?- V?i?fs. and aazu'am "1?33? 1hch cu?er- oi
fruit: ain't: mm}- dt??L?l'ihL? "up?cui" - r-ciuszng dung: qunnm?n, failure;
10 a new mum in tin. ruin.?ng inn}: at zms?mgt?ndct yam'nrs. rtt?ning {ht-m an
d?mmxaix uayn?. rr?mrig It: Hui: than f?r gamma mums! {an} Gnu l'u?lputidc?lt rush mild ?r .:
n'f?gixm; gig-#15- 3314? duet; ?rmns'c' 1' S: rm 5mm": In #56 Elmer me? :12; w; ?rhr: ?urrufm
A nuihu? '1 i? :?u?pnm?h?nt hots-Ll. any; ?an-1f?? KIM

is hm: I?d-fragraxrr in :12} {Muir i??L {{er having. thrir mudic? pru'm'j; ?viniat'mi by

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_00045635

111310. item 20 of 23

cw VA doctors and nurses. In many oi: these cases. doctors and nurses violated the Hippocratic Oath do no harm
by singling out and stigmatizing their transgender patients. Illustrating this. one MTF respondent recounted
the following experience: '14 nurse puffed nay partner out in the barf! qr!ij l?f?i Hospital where was an
[and said]. ?i?im know that is really a man. doniyon?? While these are just a Few examples. they clearly show
the discriminatory experiences transgendcr veterans are facing in VA hospitals - discrimination based on their
non?traditiona.l gender identities. This discrimination is not unique to transgender veterans - many transgender
people face similar issues to cart: and stigmatizatinn by medical sta?in their daily lives}?

RESEARCH SUMMARY

In summary. this survey ofthe experiences members and veterans in the US. reveals a wide
variety ofdiscriminati on both inside and outside the military. Both MTFs and FTMs report being passed over for
jobs or being openly fired. being denied necessary ID changes. and being vicrims ofpersonal and sexual violence
due to their transgender status. Crossdressers report less overt forms ofdiscrirnination. though they are extremely
vulnerable. too. if they are "discovered" by employers.

Within the military. transgender service members are prohibited From Freely expressing non-traditional gender
identities by military culture and formal organizational policies. Yet. in direct violation and
transwomen Still report being directly questioned abour their sexual orientation - even when they have not made
any surgical or hormonal changes to their birth gender. Female?bodied people report being openly questioned
about being gay by Fellow soldiers and of?cers at a signi?cantly higher rate than male-bodied people supporting
research that suggests that DADT is being diliercntially enforced upon fit-male soldiers.

Transgendcr veterans report a variety ofexpericnces with the VA hospitals. While the majority of participants
did not currently use the VA hospital, those who did report an array of experiences with organizational and
interpersonal discrimination from doctors. nurses. and non-medical Staff. Further.peopie who sought medicalized
aspects of gender transitions from the VA h05pital were typically denied this care. While experiences varied
between VA hospitals. as well as from doctor to doctor. these ?ndings suggest that the VA hospital is at a besr a
precarious environment for transgender veterans. and at worst. a location ofstigma and discrimination.

RES EARCH lM AND RECOMM EN DATIONS

Survey responses make clear that rransgender service members are negatively affected by the current DADT
policy. even though the policy does not directly apply to them. Transgendcr and other service members expressing
non-traditional gender identities are often perceived as lesbian. gay. or bisexual. thus increasing the likelihood that
they will be invesrigated under DADT. DADT targets these service members regardless ofthcir actual sexual
orientation. Further. DADT disproportionately afiects service members who are Female. female-bodied. or on
the FTM continuum. in sum. the experiencrs ottransgender service members clearly show that DADT is not

being implemented as designed-

?While repealing DADT might alleviate some ol'Lhe scrutiny to which transgender service members are subiect. such
a policy shift would nor be suf?cient. Beyond the ell-ecu there is clear evidence that transgender service
members are negatively impacted by exisring military policy and culture. The current US. military orientation to
transgender service members - which is both pathologizing and punitive is not the only possible approach. In
fact. the UK. Canada. Israel. and Thailand all have integrated militaries. with provisions For transgender military
service. Canada's Department ofNational Defence pays in certain cases For sex reassignment surgeries. Exisring
research suggests that alienwing medical gender transitions for service members would nor create a ?nancial burden
on the military. as the percentage of people accessing such services would be quite small a ?nding that has
led name city agencies, and some Fortune 500 companies. to add medical coverage For gender transition-related



1" For more information. see "'l'ransgendcr health and the law: Identifying and lighting health care Accessed August 3. 2003 at


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20 of 23

10

surgeries and other procedures for transgend er employees."O W?ith orher countries increasingly allowing the open

service oftransgender members. and other sectors ofthe US. business world making similar adjustments. the US.
military will soon be the anomalous case ifit does nor develop policy to keep pace.

Data from this survey show that in both aetive duty and veteran contexts. transgender people are currently hindered
from expressing their desired gender identities. Yet. the World Professional Association For Transgender Health
the leading organization of health professionals specializing in transgender patient populations
de?nes its ?Overarching Treatment Goal" as "lasting pcrso rial comfort with the gendered selfin order to maximize
overall well-being and self-ful?llment?? The US. Military and Veterans Administration should
develop policies and procedures including, For example. adopting Standards of Care as clinical
guidelines for providing services to transgender persons - that more fullyr allow transgender service members and
veterans to express their gender identities.

In the case oftransgender veterans seeking medical care (whether it he transgender-related healthcare needs or not).
the data shows that those who acCess VA hospitals are among the most vulnerable within the larger transgender
veteran population. They tend to be older, unemployed or underemployed. and lower income or livingin poverty.
They likely access services at Wit institutions in part because ofa lack ofviable alternatives. This constellation of
marginalities may mean that these service members rely. without any other options. on VA services.

A typical mission statement of the VA Hospital reads like this one From the Washington, DC. VA Medical
Center:

W?e are dedicated to providing high quality. comprehensive health care to veterans in an environ-
ment that Fosters trust, respecr, commitment. compassion and excellence. We serve as a major
resource for health services. education and research that bene?t our patients, their families. the
community. the network and the nation.

These survey ?ndings suggest that many VA Hospitals have a long way to go toward meeting this goal. As
members of the US. military who have served their country. transgender veterans should have the same access
to professional medical care- for bod?n transgender-spccihc and general medical needs. as any other veterans.
Following well established protocols for providing medical services to transEender patient populations would
esrahlish guidelines for doctors and would allow veterans seeking transgender-speci?c care to know what services
they could cape-er to access consistently. Patients and doctors (as well as other medical and non?medical VA
staFl} could be held accountable to such standards of practice. Such institutional guidelines could also provide
uniformity across VA hospitals. which would help mitigate against the kinds oi'uneven and unpredictable services
across institutions that survey participants described.

Finally. as a minimal step toward remedying the many instances of interpersonal discrimination evidenced in
the survey data. VA Staff should be educated in rcspecrful ways of interfacing with transgender clients. All VA
personnel should receive diversity and sensitivity training as a ?rst step toward providing appropriate. respectful
treatment to the transgender veterans who st:ch healthcare at VA insdtutions.



For more inFOtmation. no this cnsti'ncne?r analysis. sci.- Philadelphia l'htit News. Zilill. "Qan Francisco will pay For workers sea changes Stction
A. p. Althea Chang. 3008. L311 usual perks. Goldman Sachs covers sex changes." Accessed August 8,1008 at EGDB


Whiter Meyer er Emil. 73M Han? Brogamrn International Glenda Dyi?phona Asst-union? i Shirt-forth of Cari-fer Gender Identity Disorders. unit-ll
{Kristin Accessed August El. 2008 at P. 1.

\l?I This is availahle at:

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ManningB_0G04563?

EPCD 111-10. Item 20 of 23 .V

APPENDIX A: SURVEY PARTICIPANT CHARACTERISTICS





EM: 1
Demographic Charactcrisdcs
Character-isn't Frequency? Percent
Age 32?
178-25 I 9 2. 3
26-3 5 7 9. 4
3645 MS I 5
45-5 5 244 29.5
56-65 .332 34. I
Over 65 5 9 7. I
Am: (JRcsia'mre 81' 9
New Ehgfand .73 3. 5?
Nor-them: I28 1' 5. 6
3mg!me I 1' I 13.6
1'49 18.2
1-1-93: A?ss?nppi Harri: 40 4. 9
.?Jz'ssi?ippi mar/J 5 4" 6. 2
Sardbwes! .72 E. 3
\u M'an nmin 50 6.
Norrhwesr 5 I 6. 2
Cali/9mm 6? .7 10. 6
.4!!th ar Hawaii 0. 9
Membcrafa re?gion 339XSH 4L3
Halal/ionsbe Status
mmwed 63.3fm 6 83. 5
Ever dwarfed 9 S4. 9
Currth legalb married
-m 03310051}: person 34 43.
-m 5.2m: srxpe mar: :7 [796 S. 8'
Cu rrfariamfnp 42/8 I 8 65. 3
Camrrzirmem ceremony 2 6H304 32. 5
{Jun/13' with puri?er 443K791 5. 0
Happy with [Jff? 435/13! 0 59'. 9

and denominators Frequency culumns tin: numbcr oFIndawdu?s who respond-rd rh: tram. rchc:

ol?rhos: who reipondrd to the: item.

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EPCD111-10.ltem 20 of 23 .V





I 2
1732516 .2
Socioeconomic Characrcrisdcs
Characteristic Frequtn g! Percent
In came Level 320
14.8
1'27 15.5
340,001-360,000 I43 H10
Omar $60,000 2' I 8 26.6
Income Source?r) 826

4m imam: 48 5.3
-m.?fimrj' rtrircmm: 2 9. 9
dim (7:?in [26 I 5.3
406ml! .refurig' 9.3 1"
won?er retirement Parr?rim! ?npiqymm! 53 4
FulI-rime employment 3 7'15 45.5
.Mufn'pfeja?j 35 4. 2
Livia cm in w?mmts,
in critance, lottery 136/323 1 6. 5
.Empfoytd in area (if training or degree 330/320 40. 2
Making more than minimum wag: 5 0.7.41? I .3 .2. 4
Etaer?led?r Elankruprry #318 26'. 0
Edumtiona! Degree-{s} 822
No degrcHigh 50'1an 9! I
Same college 28 I 34.2
Associate: drgrec?) 7" f6.
Bachelor: degmefs} 69 20. 6
Masren dryer-(5) I 3.3 16.
Dacia rm" dqgreef?s) 3 0 3. 6
Housing Status 2 822
Ow?/marrgage primary residence 44 7 54. 4
Ournfmo?gnge rerzmz'pmpergr?and 3,7 4.5
Ranting 2'35 34.
Live with?mibuf?imd 9. 6
Gwemmcn rj?rifir}, bomea'm street I I .2

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3

Gender [dc-mi :31, Expression, and Sexual Orientation

Characteristic Frequency Percent

as Ira 534/3 13 34. 1

Ever identi?ed 45 transgender- 6 37.3

Grader Idea!in 327
Female (F) 431? 52.
Emu": 229
Inter-sex 26 3. I
Neuiratl 2.7 3.3
Uha'q?md 32 3. 9
Other 32 9. 9

Gende'r Expression 324
Fermfefu? time 2 99 6.3
Mafe?df time 300 34.3
M'ale arfmakrp?m time 203 25.2
Male. ?rm/11': androgynous 69 3.4

Femzu'e or andragvmm 7? 4. 5

Andragynaus-?? Hm: I I I3

Gender l??ridnt Identity 8 I .7
Nari-op .7 0. 9
Prat-0p Fm .M 36 4.4
Pan-0p Warmcxua! 30 .7
Nan-a}? Ira rmexuaz' 1' 43 13. I
Prevap iranm'xua! to 253 31. 0
Pan-0p nurmexualonger identify a; m: msrxual I 2 1.5
ro?dre?er 1' .72 3 I. 1
Other 3 9 4. 3

Sexual Orientation?) 81 4
Herermexual 3 05 3 5
Bin.er 302 3 3
(Far 23 2. 8
L?bian I 65 .30. 3
.Jsexuat' 45 3. 5
Remand! 2 3. 3

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321533 4
Military Service Characterisrics
Characteristic Frequency Percent
Branch (35) afSerm'ce 32?
A?ir Farr:- i' 94 33.5
Amy: 3 1' 5 38. .2
Marine; 93 I 2.2
Na 15.- .236 .33. 5
National/A 1' biannual/Cam: Erhard 3-1 I 0.2
Rrsc'ruw 33 I 0. 6
Currenrizy Stu:ng 2/81 1 ~12
Ever served in rumba: zone 383/309 43.
?ights: Rank: Enlisted 172}
junior aimed (E1 :0 34.7 43.}
junior
?0 ?6 ,1 2.79 38.
Sm:er rm?i?edx?zVCO ngchI Rank: O?cer I 12
janiw q?cer (CH 04} .77 68.3
Samar ?re? ?05 to 010,} 35 31.3
?pefs) ofDiscbm-ge "97"
Hanan-INK 68 ,7 36. 2
Genera! :3
64 3.0
Other dengwated pill-1251M!
and menmf ['ana?iriam I 4 8
Under other than banambk I 4
Other {3.30:5 qfdijcbargf 0?8 0

ManningB_DDU45641

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210f23 0028-1D-CID221-10117

Archives of Sexual Behavior, Val. if, Na. 6, MRS

Transsexuals in the Military: Flight
Into Hypermaseulinity

George R. Brown, M.D.. Capt.



A sample of ll male patients meeting DSM-lt'l criteria for
transsexualirm was seen over a 3-yearperioa? by a military,I Eight
patients had extensive military experience, including combat duty in some
cases. At the time afevalaatian three were an active duty, one was a Depart-
ment of Defense employee, and four were veterans. Evidence is presented
for a hypermasculine phase of development that coincides with the age of
enlistment in nearly all cases. The underpinnings of the choice
to enlist in trammal males are discussed. Outcome of militaryI service was
premature discharge in over 60%. The militaryfs management of gender?
servicemen is described. Current military palicies. in association
with the proposed hyperm arcaltne phase of transsexual development, may
actually result in a higher prevalence of transsemalisrn in the military than
in the civilian population.

KEY WORDS: hypermascuiine: military: gender identity development; gender transmacho. to have weapons. to bc a ?ghter. and to kill. at ?rsl
in play, then maybe later in a war. {Money 1980)

INTRODUCTION

The cancept of hypermaculinity, described in part by Money in the
quote abuts. has been variably described throughout this century as "make-
bciieve masculinity" (Fenichel, 1945], ?masculine proteSt" (Adler, 1923x1955)

The views expressed herein are those of the author and do not necessarily reflect those of the
Department of Defense or the United States Air Force.
cf Mental Wright-Patterson Air Force Base, Dayton. Ohio

45433v5300.
3T0 whom correspondence should be addressed at [1 I63 Mesquite Flat. HCIOICS, Texas 73023.

527

?5 Plenum Pubh-l-Jna Carp-oration

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Manning

EPCD 111-10. item 210f23

51! Brown

?macho personality" (Chodoff, 1932), and "Man?s Man" or ?Ladies? Man"
(Glass. 1984}. Hypermasculinity has multiple facets with sexual and gender
implications and inventories have been developed to assess its features (Mosh-
er and Sirltin. 1934}. Characteristics include foolhardiness. overcompetitive-
ness. bellicosity. fragile hardiness. and equations of ?Hriolence as manly" and
?danger as excitement? (Glass, 1934; Mosher and Sirkin, 1934}.

Cultural factors are important in a consideration of hypermasculinjty,
as the term may have inappropriate, judgmental connotations depending on
its usage. Masculinity itself is not a unitary construct; the line separating ma-
ture masculinity from hypermasculinity can be drawn in different places on
a continuum of male gender roles depending on cultural context. Role be-
havior that is deemed hypermasculine in middle-class, Caucasian, American
culture may be considered mature masculinity in a Hispanic society {Gold-
wert. 1985). This clinical investigation accepts the general de?nitions of hypers
masculime as indicated by the previously cited authors as they apply to the
cultural contexts of the patients in the group to be described.

Three major theoretical constructs have been applied to the induction
of a hypermasculine adaptation in males: repudiation of feminine aspects
of the self, defense against homosexual anxiety, and early/middle childhood
parental in?uences (Glass, 1934; Ovesey, 1969; Mosher and Sirltin, 1984).
Most relevant to a consideration of males is the first of
these constructs. Stoller and Herdt (1982), in their cross-cultural contribu-
tion to the study of masculinity, noted that the repudiation of feminine aspects

of the self in a sexually dichotomized society can become a ?frantic preoccu-

pation". It is clear that the transsexual drive for sex reassignment surgery
and hormones qualifies as ?frantic preoccupation? and. had we seen these
very same patients while they transverse their rocky hypermasculine terrain,
one can readily speculate the same would have applied.

As an active duty military at a mailer medical center 1 have
had the special opportunity of studying such patients in the midst of their
"rocky hypermasculine terrain." The Air Force base is situated in the mid-
western United States in a community of about 300,000 military mem?h?ers,
dependents. retirees, and civilians; all individuals who have, or have had,
a connecdon to any branch of the U. 3. military service are entitled to psy-
chiatric care at this facility.

intuitively. one would assume that the prevalence of severe gender dys-
phoria and, specifically transsexualism, would be low in the military-
certainly lower than in the civilian pupulation. Surely, a male who is gender
and engages in cross-gender activities and possibly sexual activity
with other males would not voluntarily submit himself to a system known
for its staunch intolerance of deviancy in any form. whether it be homosex-
uality, long hair, or wrinkled uniforms. Furthermore, given an incidence of

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Transsexuals in the Military 529
transsexualism of between 1:37.000 and males (Roberto. 1933).
the likelihood of seeing any transsexual patients in the general adult outpatient
clinic or the 30-hed inpatient unit at this medical center over a 3-year time
span is low. It seems especially unlikely in the absence of any Specialty clin-
ics dealing with sexual or identity problems or any interest in studying
problems believed by many not to exist in this system.

During the past 3 years I have evaluated ll biologic males with severe
gender all of whom meet (American Associ-
ation. 1930) criteria for a diagnosis of transsexualism. Three had had no
tary experience. Eight had had extensive active duty military experience; only
one was drafted, then chose to enlist. The other seven joined voluntarily at
a time when no draft existed or other options were readily available to them.
All branches of service were represented; three were on active duty at the
time of evaluation, one was a Department of Defense employee. and four
were veterans. Ages ranged from 20 to 44 years. Three were of?cers. All
were Cancasian and six had been married. All were requesting cross-gender
hormones and/or sex reassignment surgery.

0f the three civilian patients evaluated. one had received written and
verbal recommendations from his internist to ?join the Arnty. go to boot
carnp. and learn how to run over trees with a tank? as treatment for his trans-
sexualism. This advice was rejected.

A striking similarity was noted in the histories of nearly all of the mili-
tary gender They joined the service, in their words, ?to become
a real man.? Representative quotes from taped interviews include:

I tried to do things to make me feel more masculine. like joining the Navy and get-
ting married.

I joined the Navy hoping maybe the problem would go away. It did for a while. but
it's still here.

I joined the Air Force as a cover. In uniform. my masculinity would not be
questioned?I was above reproach.

The following two cases are representative of the group.

CASE A

L. 3.. a 37-year-old. single. Caucasian. biological male. was aban-
doned by his natural mother at birth and adopted by a. Huddle-income child-
less couple at 2 weeks of age- He showed an interest in cross-gender activities
throughout childhood, including doll play and extensive nonfetishistic cross-
dressing beginning at age 6. He was the object of ridicule by boys his age.
especially when he wore unisex clothes to school. Adolescence was partic-
ularly tumultuous and after graduating from high school, he enlisted in the

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EPCD 111-10, Item 21of23

53"] Brown

Air Force. He believed basic training and military discipline ?would make
a man out of me? and ?make my [adoptive] father proud of me.? After suc-
cessfully completing basic training, he became a laboratory technician at a
base in Germany and lived in the male barracks. The only period of his life
he did not cross-dress was during the first half of his tour of duty. Concur-
rently, he took up avocations that involved signi?cant personal risk: moun-
tain climbing in the Alps and high-speed race car driving. He masturbated
for the first time at age 19 and began dating women. During the peak of
hostilities in Southeast Asia, he applied for combat helicopter training. He
completed his JLye-er tour of duty without incident and went to college, dur-
ing which he experienced increasing gender (which had reemerged
before his discharge from the military]. substance abuse, and depressive sym-
ptomatology. These prompted multiple requests for hormones and
surgery and an evaluation at a Gender identity Clinic 9 years ago. At the
time of the current evaluation, he had been taking prescribed female hor-
mones and living successfully in the cross-gender role for over a year as a
female nursing student. He has not participated in dangerous sports for many
years and dates exclusively heterosexual men. He has no medical or surgical
problems and no personality disorder.

CASEB

L, N., a 26-year-old single. Caucasian, biological male, was the youn?

gest of three sons born to a farming family from the Midwest. His father

retired after serving 2.0 years in the Air Force, and was described as emo-
tionally distant and physically absent during L. entire childhood. He
cross-dressed privately boginning at age 7 and would pray asking
God to let him wake up the next morning as a girl. He was quiet, withdrawn.
and socially awkward as an adolescent. After graduation from high school,
he went to college where he joined a fratcmity, lived in a male dormitory,
cut his hair short, and began dating women. He discontinued all cross-gender
activities and enrolled in an Air Force program as an officer candidate. Af-
ter 2 years, he became disillusioned with the ndlitary and questioned his origi?
nal motives for joining thought it would make a man out of He
intentionally failed a college course in order to be dismissed from the Air
Force. He resumed his cross-gender activities and went on to work in the
male role at a major Air Force base as a Department of Defense employee
handling sensitive inf orrnation requiring a security clearance. He had been
taking female hormones. binding his genitals, and growing his hair long for
3 months prior to evaluation and he cross-dresses in all environments out-
side of work. He has no medical or surgical problems and, althoIJgh he dis-
plays schizoid and avoidant traits, no personality disorder is diagnosable.

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EPCD 111?10, Itom 2101'23

Transsexuals in the Military 53!

FLIGHT INTO HYPERMASCULINITY

The transsexual ?flight into femininity" is well-described by Steiner at
at. (I978) as a possible phase observed in middle adulthood applicants for
sex reassignment surgery. It is clear that in the cases above. and in others
1 am aware of anecdotally 6 transsexual ?ghter pilots; Lothstein. per-
sonal communication. 1936). a diametrically Opposed phenomenon may be
occurring: 3 ?flight into hypetrnasculinity.? For some. the mere actof enlist-
ing was not enough. In the first case described above the patient deliberately
chose the path of greatest danger while in the service: He elected to leave
the relative safety of his laboratory technician job and apply for combat
helicopter pilot training at the peak of the Viet Nam war, when this was an
extremely high-mortality position. Another patient in this sample graduated
second in his class at Officer's Candidate School. He volunteered for Spe-
cial Warfare School, became a Green Beret, and saw extensive combat in
Viet Nam and Thailand, completing 4 years of active duty in the Army. In
addition to these cases, the military experiences of several well-known trans-
sexual individuals are well-documented in their autobiographies (Cowell,
1954; Jorgensen, 1967; Morris. 1974; Richards. 1933}.

Gershman (1986) has stated that the development of identity is an ex-
ample of a continuum within an individual and evolution is continuous
around a central core. Although core gender identity is believed to be large-
ly established by 18 months. other maturational levels of development are
operational throughout childhood and adolescence, with attainment of a
mature gender identity! role in early adulthood in many individuals (Gersh-
man, 1968).

Levine et al. (1975) described a ?role transformation" in the 12 male
transsexuals they studied. Military history was not speci?ed. The succession
of roles they observed was as follows: role ambivalence. transsexual ho-
mosexuality, ?drag queen," adult transsexual. The 3 patients in this military
population seem to have undergone a succession of identities and roles as
well. although my observations ?t more closely with the evolution delineat-
ed in Fig. l.

The gender-disordered child has. at t'nt?ist1 an awareness of the self as
different from the societal dictates of his anatomy. He does not know what a
transsexual is and feels confused about his identity/role. According to Stoller
191'4; 1975}. a lack of symbiosis anxiety as a protective shield against femininity
may contribute to early overidentification with an engul?ng mother,
unimpeded by the proverbial absent, unreliable, and inconsistent father.
Whether or not this theory is widely applicable, the pro-transsexual adolescent
does not possess the ego strength to withstand the social ostracization and
ridicule of adopting the cross-gender role. Furthermore, he cannot tolerate

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512 Brown
NEBULOUS DISTURBAHCE

IN GENDER SENSE

AMBIUE LE HCE

CROSS-GENDER ACTWITY

AVOIDANCE

Mien?lloo

mm
senwcei

Breakdown of detenses

ADULT TRAHSSEKUALISM

Fig. 1. Transsexual role transfon'natian.

his growing awareness of the mismatch between his anatomy and sense of
self. In the prevailing adolescent atmosphere of individualized conformity.

min in? is the means of securing supplies and bol5tering

a flagging self-esteem. Even adolescents are readily:F
rejected by their peers for minor aberrations in behavior and appearance.
The ?solution? (adaptation) to this dilemma may he withdrawal into schizoid
isolation and fantasy. a well-known clinical variant among applicants for
sex reassignment (Meyer. I974). Alternatively. he may attempt to ?force a
fit? by the unconscious and conscious "selection" of a hypermasculine adap-
tation. InadeQuate. faulty object relations and a high prevalence of borderline
personality organization {Levine and Lothstein, I981) obviate a consideration
of a more moderate, androgynous approach. Androgyny or integration are
not rejected, they merely do not exist as choices for the untreated transsexual.

For the hypermasculinc phase male in late adolescence,
?the first order of business of being a man is: don't be a woman? (Stoller and
Herdt, 1932). Bene?ts theoretically accrued from such a hype-masculine ?ight
include: Panacea for a varier of anxieties, homosexual anxiety. anxiety
over loss of love of famin and friends. (ii) Recoup of lost of love and respect
from signi?cant others, especially parertts tdoalienation}. Trial identi?cations
with hypermasculine ?gures interpreted as more socially acceptable and
readily available in the mass media. (iv) safe haven away from

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Transsexuals in the Military 533
intense cross-gender feelings: More masculinity is seen as less femininity and
less problematic (requires purge of all aspects of the lemme self).

This hypennascullne flight coincides chronologically with the age most
men enter military service, either voluntarily or via the draft. The military
places a high premium on virility. stoicism, machismo. assertiveness, and
all that is. by de?nition, hypermasculine. It seems that active duty is a natural
choice for the male in the hypermasculine phase who is
attempting to make a last ditch effort to take the path of least resistance
vis?a?vis society and family. He sees a chance to maximize his ambivalently
present masculine self while de+integrating and purging his feminine self. all
in the service of adaptation and accommodation. in an all-volunteer force
(the situation that has pertained since 1973}. the prevalence of gender-
initially hypermasculine males could very well be much higher
than in the civilian population as a result of this mechanism, which clearly
relies heavily on reaction formation for its unconscious components.

OUTCOME

What is the outcome of the soldier? An answer to
this question can he, at best. educated speculation given the size of this sample
and the genera] selection for more severely disturbed individuals. Literature
is almost entirely lacking on the subject. with the exception of a single paper
detailing the n?litary?s management of five cases of gender and
one case of physical intersex in a soldier?s spouse {Jones et at. 1984). A
consideration of the eight patients in the present sample and the ?ve reported
by Jones and co?workers indicates four possible outcomes:

1. Early {less than 1 year) break down in hypermasculine defenses with

premature discharge;

2. Later (after 1 year) breakdown with premature discharge from

service;

3. Completion of tour(s} of duty subsequent to breakdown in

hypertnasculine defenses;

4. Completion of tourfs) of duty with hypermasculine defenses intact;

self-referral later in life as veteran.
Half of the patients in this sample evidenced the first outcome; one each
for outcomes 2 and 3; two for outcome 4. The ?ve cases described by Jones
er al. assorted one case to outcomes 1, 3, and 4 and two cases to outcome 2.
Completion of all tours of duty or a 20-year career subsequent to a breakdown
in hypermasculine defenses accompanied by adoption of a cross-gender
identityz?rolc is the least likely outcome of the 13 cases listed, while early
discharge at less than 1 year of service is the most likely outcome, initiated

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EPCD 111-10. Item 2101?23

534 Brown

by the Individual or by the military system. This is not surprising given that
hypermasculinity is itself a form of gender disorder, speci?cally a disorder
of gender role in response to a primdry disorder of core gender identity. These
component disorders conflict with each other. creating a self-imposed
mismatch between core gender identity and gender role. The resolution of
this con?ict necessitates abolition of the hypennasculine role and defensive
Structure and evolution towards the adult transsexual phase with its
concomitant quest for hormones and surgery.

MILITARY POLICY

Current military policy regarding service members
is sketchy and appears to be applied on a case-by?case basis. The military?s
formal position as applied to transsexuals who are self? or serviceidenti ?od
is often the same as in cases of homosexuality and bisexuality as de?ned in
Department of Defense memorandum 1332.14, dated 23 January 1982:
Homosexuality and bisexuality are incompatible with military service and
their presence ?adversely affects the ability of the Armed Services to maintain
discipline, good order, and morale? [Jones et all, 1934). Transsexuals can
be considered as homosexual or bisexual by military definition if they engage
in, or desire to engage in. bodily contact for the purposes of sexual
gratification with a person of the same anatomic sex. This results in

\v prohibition from enlistment or separation from service through administrative

(nonmedical) channels, usually with an Honorable Discharge.

Heterosexual transsexuals. as de?ned by a desire for sexual contact
with the anatomically other sex American Association,
1930), pose a more dif?cult problem. Their gender disorder cannot be ignored
or relegated to irrelevancy in this unusual situation. Policy is still evolving
in this area.

For those who receive sex reassignment, irrespective of sexual
orientation. medical arguments have been used successfully to suppon both
prohibition from enlistment and separation from service (Doe v. Alexander.
I981). A more recent legal opinion prepared for the U. 5. Air Force supports
the use of medical arguments the probable need for specialized medical.
surgical, and care is incompatible with worldwide deployment)
over the vague, general grounds fer discharge as applied to homosexuals in
Air Force regulations AFM 39-12 and AFR 36-2 l982f24, 1984).

The above considerations are usually circumvented entirely by the
medical authorities. possibly due to these vagaries. and patients are diagnosed
with personality disorders (usually Borderline} and administratively discharged
as ?unadaptable to military service? on that basis. The matter is far from

FOR USE
LAW ENFORCEMENT

ManningB_UUO45649

EPCD 111*10. Item 2101?23

'Irenssnuels in the Mllilary 535

resolved and largely untested. The legal opinion cited previously summariZes
the military?s precarious position:
The short of the matter seems to be that if we propose to base the policy of discharging
members who under sex change operations on promotion of good order. discipline.
morale. or other similar virtues. we must prepare for a challenge on the ground that

there is no mph-ice! evidence that transsexuals have an adverse impact on those values.
asserts. 1984).

Given that gender is an all-pervasive disorder and not an
?off-duty? or alternative lifestyle. it seems that the adaptability
of some crOss-gendered servicemen is predicated upon intact hypermasculine
defenses. Without a signi?cant breakdown in these defenses. they do not
come to the attention of the system and are not identi?ed as ?deviant.? For
the majority, whose hypermasmdine ?ight falls far short of a complete tour
of duty. military life itself becomes yet another mismatch. The difficulties
they experience in nearly all facets of military life (o?er evolving beyond this
phase) leads first to their identi?cation as deviant and, second. to mandatory
evaluation for con?rmation of that suspicion. At this point. both the patient
and military system are happy to part and go their separate ways. On the
other hand. it is conceivable that a signi?cant number of higher functioning
transsexuals without severe character pathology could traverse the military
system undetected. as did four of the veterans in this sample.

CONCLUSION

A phase of hypermasculinity scents to he experienced by the
males in this sample. usually during middle to late
adolescence and variably sustained into young or middle adulthood. As a
caricature of mature masculinity, the hypermasculinity adaptation in these
males necessitates a way of being that is nonfcminine; risk-taking
behaviors. machismo. and a facade of power are prized. While some patients
choose hypermasculine pursuits limited to contact sports, race car driving.
0r mountain climbing. an unknown number choose military service as the
quintessential hypermasculine environment in which to purge their
Cross~gender identi?cations.

The prevalence of transsexualism in the armed forces may actually be
much higher than in the civilian population. This potentially increased loading
of transsexuals in uniform may be due to the hypennasculine phase adaptation
described and possibly to existing military policies. For example, it has been
previously hypothesized that the number of homosexuals in the military is
actually increased by military policies that exclude women from the draft
and concentrate on late adolescent males lIflrlarry. 1984). This theory is predi?

USE ONLY
LAW ENFORCEMENT SENSITWE

Manning3_00045650

EPCD 111.10. item 210123

536 Brown

noted on the finding that the homosexual men who enlisted or were drafted at
age 17 or 18 did not yet "know" they were gay, as the median age of "coming
out? assuming a homosexual role} is 19 or 20 years (Dank. Harry
and DeVall. 1978). As military policies. formal and informal, serve to
reaffirm values of masculinity and heterosexuality, they also serve as an
enticement for the hypermasculine phase male who is
frequently in this very age group.

There are numerous other motivations, overt and covert. underlying
the decision to enlist in the military service. Many of these may have little
or nothing to do with hypennasculinlty. patriotism. desire to be in close
quarters with other males. economic pragmatism in a difficult job market,
method of escape from a malignant home environment. It is unclear what
role these factors may play in the male population, in
addition to the hypennaseuline defensive structure.

More study is warranted on the prevalence of gender disorders in the
military environment. Awareness of these problems, especially in the active
duty force. is essential for the provision of optimal mental health care in
the context of the mission of the Demrtment of Defense. While information
on the natural history of male gender in the military is sparse.
data on the prevalence of gender disorders in women who choose military
careers is entirely lacking. This, too. could he a fruitful avenue of inquiry
in future studies of gender in the military.

ACKNOWLEDGMENTS

The author thanks Sandra Dinwoodie for preparation of the
manuscript: Lynda Collier. Lt. Colonel. Ret.. for assistance in data collec-
tion; and Leslie Lothstein. for helpful comments on the manuscript.

REFERENCES

Adler. A. The Practice and Theory translated by P. Rabin
(Original work published 1923). Routledge and chan Paul. London.

American Association. 1980}. Diagnostic and Statistical Manual of Mantel Dis-
orders oil. APA. Washington. DC,

Chodoff. P. {1932). Hysteria and women. Am. 139: 545-55].

Cowell. R. (1954). Roberto Commits Story. William Heinermann Ltd.. London.

Dank. B. {will}. Coming out in the gay world. lat.-

Doe v- Alexander (1981}. SIDF. Supp 900. D. Minn.

Feniehel. {1945). The Theory of Neurosis. Norton. New York.

Gershman. H. [1968}. The evolution of gender identity. Am. 28:

Glass, L. L. {1984)- Man?s mam?ladies? man: motifs of hype-masculinity- 260-273.

M. {1985}. Meadean machismo: the flight from femininity. Rev. 72:
l?blb?.

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_UGU45651

EPCD 111-10, item 21 of23

ManningB_00045652

-1D1 1?

Trauma-ls in the War: 53'!

Harry. J. {1934}. Homosexual men and women who served their oounu-y. J. Homom. lt?l:
?7-125.

Hwy, 1., and DeVall. W. The Soda! Organization ofGay Miller. Freezer. New York.

Jones. F. 13., Deekcn. M. CL. and Eshelman. S. D. ?984). Sexual reassignment surgery and
the military: Case reports. Milit. Maui 149: Ill-275.

Jorgensen. C. {1961). A Personal Autobiography, Paul 5. En'kson. New York.

Levine. E. M.. Shaina. C. H., and h?hailovic. M. (1975). Male to female: The role transfor-
mation of transsexuals. Arrh. Set. Benin. 4:

Levine. 5. 3.. and Lothstein. L. M. {1951]. Trumalism or the gender
Sex. Merit. Ther. 7: 85-] H.

Meyer. J. K. Clinical variants among applicants for sex reassignment. Arch. Sex. so
how. 3: 527658.

Money, J. [1980}. Love and Low Sicknm. Johns Hopkins University Press. Baltimore.

Morris. J. (1974}. Conundrum, Harcourt Brace Iovanovich. New York.

Moshe-r. D. L. and Sirkin. M. (1934]. Measuring a macho personality constellation. J. Res.
Pars. l3: 150463.

982214 [1934). Med. Service: Big. 35: 2.

Ovesey. L. (1969]. Homosexuality and Pmdo?ommaliry. Science Home, New York.

Richards. R. {1983}. The Renee Richards Story: Second Serve, Stein and Day, New York.

Roberto. L. G. {1933]. Issues in diagnosis and treatment of transsmalism. Ami. Sex. Behuu.
I2: 445-473-

Steiner, B. ?It. Salterberg, and Muir. C. F. [1978}. Flight into funininity: the male
menopause? Can. J?s?hi?h Assoc. J. 23: 4054M).

Stolter, R. {1974). Symbiosis anxiety and the development of masculinity. Arch. Gen.
chi'm?. 30: 164-1?.

Stolier. R. J. (1905}. Per-version: The Erotic Form of Hatred. Pantheon. New York.

Blotter. R. J.. and Herdt. G. H. [1982}. The dewlopment of masculinity: A urosecultural con-
tribution. J. Am. Assoc. 30: 29-61.

FOR OFFICLAL USE ONLY
LAW ENFORCEMENT SENSITIVE


EPCD111-10. Item 22 01'23 UD23-10-C1D221-1U11T

N- I . .
:t?m Wer








{lirllEIF.

u-IhJ': Wu";



.: 1- hr vilr-Ja-ir'e! win: pa mgr-1:



ii);
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11-11



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I 111': ?w ?um-rm 11354:: Fri-m



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i-s?a?w wma,

mm?nm:
am My

:2 um 5114 2hr



LO 1k.-






minim?.- ?ninth-HE IE'G'f-l'l



Lin: -- 110:0}:-



h-x'a'xi. fllzii - . :1er





In

3'49: aim-L'inr-n' :5

7'1" - -






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a s. -.



turf-u. m- Ema-n



5 dun-34; :11

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inn." NIH: Sic-~51.



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3:924:51 gnuccEIL nanny-5n.

bav-r 3:13 ?of?Zn?! In?m [a 15:



I5 ,Huhh 24f i.



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I ?4 enu'lni't-Su If-?s uq- I on "InI.-.
ft i 4' ?Ill I i" 'Gqs'J' - 1 :l'tht'Lwnt. 9131:"



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Thu?

val? ?i'u r. -I may.



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I-I



:mimm-v. :37:

gm; pa. I.- qu2- 01:9 i

:u i'urghg-I' rr-II--"-t



nigh-n: and
4 I?m-r; am I: hint.



?pd

1:94}?





:{azlliiulls- .Iia?. can-I [Zr-"t mica-1: It:





03 ahe- lump 1_



uni-l

mm.













_1

.. ful?l-V 3r Sun?s? I'lruf


z'I. Ill!?







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Aih' I. war-3

avadarnp II-

.
Em all-l;-



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mm 9115" -1.

2119'"
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at 1? il?l?n-














..11.-. pm; -I.. ,7



Ir -.

-: rs



Hill" I

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE



\u-v
22 of 23

E?tli? ma! {cw-5 11:" um-uhnv .me? mine "ik?mlnuu' 3am



may: gin-Hi}: Inhu'i'. fins! ?.dcniitg'

What m?dim?nm Aw: Emniwa

Elancrun 1'.inch :vf' main-arm: um ha- mwci u: Tin- 12?n-rio' 2-H:
g; ilufh: ?3rrz'mir .m
3mm: em: 2w karma-1:? gm'uilk'mh?: Win-i; on H'uut' 2-0105 (WHILE:
graham: mu}: 3114531.: UN: En yum
"ml, rs-?pusl? ?a 1m- E-mm: uE Lima. MI Ibrahim: 31m:



um 15m:

that's-mm? uni ran-4' are :th?-?ihf-T Hanu- uf- lu'imc'ej

Elu'l gfgi-IJitgr-l In ?kl-FL
e-r
midi-cf In f5}? um:

2 iv :u?d rhuarnmcu. Ii :5



T. Estrogen

y. miemrm wr ?E?mnik'
hhgiu'?; Irmm, I?J'gkr. {inn m; an {Hiram-4 .2: mm 1x13} 1? uhmi-k

_md (11-11,. huh-wk

ran hr min-h wip-

mi? ?Jr-:5 apphru?un; -

wk?: nr 'l?rmavfir ?Pm? :rgq?u mm?
mgox?znm - nunmmu'n-im' uybh muss:

Fm arms-um? 13m! awn?: ?,Insimv?lwm. wall-gr? Iu - rim-L" .?lvl-
a --: 1.2km: 1hr- ruiin-r thus; by pill; pr 11.13421.on
F-u- rim. itnmuu-ttudv?
?mm in, :i manim i lit-t Mal-{i Fir-1v-
Trags?emmi ui-r ma?a-L ma: 1:5 1%:34' n? 3171
1911* trim-25.3 mum an ?Sm-9am lair-n F-h jitlEmcd-Ehnh.
LE MT I 15?: in; ?lnwu-W 1?i'rirv'r-

=im. nan: run-tr.? .ai u: autumn 13:11:11}; 1-7421.?
?whims!? ml. him: -
u: uQ-Ji M1hh-u- H. has 1hr
J?wmmn'?? and m? an?
nub-awn mu?lw nuns-iraea- wumnr- rams Hi?wh :hq-w 1? lint

1-1? mm: name minim


0028-1D-CID221-10117

.3. Antiuanuroge n5 {aim knuwn as androgen Hackers
or andregen antagonists}

Anti 13f?;- wll'rt: ii} an?: kf1i'x'1 "Hui
rad-nu: - ?'muic pin-hm! mull?. 233:3 inns A fluid}? 6:16} Fm-
H-umug?r phi; hrip mu 'mma ihaiflir??r fir-?31?! walnut!) tr?
?nd .4161: TEE f?a' ll?ii?'rm
1.1 pm 1116 an": nunm? 11'1?u'nll'. :u
NH. 11:: stu-ridc? E?s-mu?? 17w:
n-a: ?a 94:61. Ella! 3'25k' Emir lil? mastmr. Ami iivtl ?mtg-nu?
a1,- gmwt??- {JJl?iL'rW?rfL

Ann- Hula-ham II?ng nit-.1; mitiiz?u? b- an tlh'



gal. raw: '?ilams {i'EL'llw'?liil'ng?Ith

til-l- :d?uuhl If! :uu :35 uni 11:4 ??e-v13.
:rn'hmuma. ?av- iu-Jhll raik: .ta-ur-Iuird Enuiu drier, Anh-
(In?n- vr-u lh r-Irr-ar?rwv nth-w 11-? MTV- 12;] Mam! reguicm-
I imLu'H mura- J'br :1 Nun'- Jaimh'nm't' .1
'h m'lm??n

3. Frogestage n5



in.? .1 rmx?? H?mi-H?? .Ilmm mag; mar .

9m?- {or 2':in .x "thw trutr? ?mghn'fth mu.





far. ?mm:

.-

wag-m; "ogr- um.- tn Iiu- 1:4; at rqu! iimt she? un- :Iuwtt-u:
u- gamuunmr and Sam.? 1's 1?;sz ?fray-wuwiaia'h m-"lmlr :EPpn-?hmn.
Wm-Ag?t {Judi}. :uui tum-(I rm}. niu': wanna
I: {draw-v. Li'awhngu' mam-n4: mu?! The.
nm??unm in?; ?r
I as a v-ryinr'rImJ-J Grin?? arm?nsm'ttaa-
mic. n: -: L: Emmi: nae; ii:

'0 'hvt? uh?! mutt-u: hr-a- whit tlaygil: eta-wimnuI-ez?.

mm

mm gen-?g. gm! Int ugmy inhabit- tar-it.-





L-s-m; n- u- 41 mum?: Ewan-m w: anti yum ismi. -

f: I twu?jn'l



FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_00045554

K,


EPCD 111-10. Han 22 of 23

Wimt?g a ?36595?

35 151:: Lam :npx vat. z??ialh' Thrf? mi?
hut-mm,? n-r drug..- ?q-nimg: wind in ti-rrg?ud: an
art; tin-{Emiamn 13.15 f'l?si'ri am! ?fth Ml? - 134-, whai J-



mu:
urgiier tdLnElt. :lm?i ?vi-I'm em: on: wand i! 1le mark-1m.? un mm Wu.-
ht-d? Fawn; unfit-1?s Him: -
am? mmummus in?.ng Emu" 9111:3115" 'un win-f IE-f-u?u n'



median! Hm.

'I'm'r righ'! i3. nf' airy-{M ?Jen: mh)? 1191? *1 th ?am: An
gr? :uad :ilmsivmms'?
n: daiih?rn! ?Hi-Is: 'a?izh ,a win; Eras Harv
Emmi; 1:31:13?; {an-fl ?am m-m'u-
alarm Lung; ai?nirm wk? :i'm-1wrnn'12n-sxu a: ti?; wil-
r?'htv?h In! H11 haw. :mwmasn timi um gas-uh am?
taut-?13m Orr: 54.1.1.2: mu; away-1m 1'.'ilt- pun: 'qu 13.12::

man-tug:- - Jar E: 15! .1 11-1wa 310;: tr- liiurilq. tie-J .Ilii?mlm





3'44 Eluh? 3:11 mu.









Tier with us: 11.35:! i? wmrnarsay: We 53:11?: t-Hmm'mnr
{mamasis 'm-d =3 an RC ?mi gm". HULEV tar-gnu; (lb-Ho-





is: $331.- err Phagu?? ?film in al?h
may .xrzul 1-5; 1 hum-r dwin- si? 1"th inn-Pr I?M-mill ilt?vhh
at 11.23: 2.53135:- suit: :4me. 1mm- im? 31m: hmurim raw-arts i! ?t'rm
hwy:- h-a'r; pt'ndnm? via-?4- Kim: .-- 1 night: 05' than
rEn-H "menu-aha iiru: his": brim: hulk wait: wrur ?11 mh'
311931 [131' m: 1h: 73m": WU haw We
?ci #153113 :rpif?mlf?. w?i'u' 1361'?



0028-1 17

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Enrogm

the-.551 mb'E-m ?Milan?s
Brand name tau-utter-

ichhg?ima?.

9315-1"



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{791:5} 9:51)} amt}! Er" Hm; van. rh?l; *3 In?; 3019:]!
5: :F-eu: 1W7 ?If; {hr 114-! din-
;kaus qmn'mih many {15- ?m

:9 on" um .- "35 66:1:

Ir'. 1? (my .41?

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n?

tag-unit?: M: nva w; 1.31:9 vim 33": "be; m' f'uzgng'q

mamas: we?. Emmi-t? ?lmy-5'} ?liv'rd-r.
numgh?




- 01., -- Jug-gnu, nu :94 an}: 51> -I cut?? me rerx'?': 11-25

$2 a? (LET. mm.

In part-3:53: ?win-nine? mar {Jewim? nfwu'd
mm- hrlni?w. 1m quill}: 5m em: in; taking
pa ma: :5 F: rant :zi'hm-I. Arm-min. 55mm
:L:1ri Ln hummnvu ?Wu- Irrugllt- I'Iu'i"! azur? that:
?ung-gt: happen: 1mm: :yur?k?'r fur .muu? ??ljrh? Hm}: ?Uzi-:5?



?sung. Illb?' ?an: 5m: dawn wt: gun-?1 r-lw? 5: ms! a yum?
91?) h'll?il?k?. .1 ih-H' an?
Jam: 5m: ?wt-.1 mar:- 11% 'mu?lja' 1 Cunni?n?
u- hmur?l?mnf h; mama? ruiim". Tamra; m-mr 1mm
{in-T alt" gym-91h- gum- inud?} Haw-H1. aha-:35: 31:11:
:5 km ?Ii; mi. a :Juiha?bird what tran-u Jumilil
?tn-55m}! "411.13.; anI-?M- may m- H-itvr a Elilh'f'i'n'l v.5.
:taviunaupn {If amnimHL-n? of quia?hfl?m mil??! {km thv? rimr



Jain-r momma} d: Etw ler'vsr?r Sanka; yum]: Mr
war buff]. u= 41?} .s Itm' ?mania! ni iI-Amrtel'emv

dug-mam is as?? 53:

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSJTIVE






EPCD 111-10. Item 22 of 23

(Mu-v1- ?r Tm: wih Lwr=5 to ?arr tin wing-'3'. n! :5;ch1.in mm a!
inc-(Eimum far that raw ul' t'mu- Mp n: pyFr?t?w" hum.- mf?'l?h 11mm-
}uw?t? u-?uiizim ?r'hm dim-M may 'gim nay-gm?: li?Jl. mu
min? {Sahib-am uni V?nm?n 1} auppI-Aawr?b E1: paasnr'l 313::3' tr rn~ 5-

Wiaat {Zhanga? (an i $993,, anti
#3995: 5mm?

"Pm-Jihad harm-Aw" hu- amp-"Mn! av-y't-Ejui-agil'm' br'nt'i'lw
raj-m5 ml'l Imit- mar? m-ndvr ah r?uhi-uz: and

HJ ?Hug-111' {"93 SKEW-M: xi?i?i" 14"? Ln??
h?i 9.1.231? ?ank-1:1; "Hm: ?rm; Ema-z inning: Lam






?.A-mm :Inh" hairin?! when Haw rat-Ar: min-v.5. For swim
Hm: it" awn-11 wig}! 14kg?; Ere-?ltmw'
and rm ull'lu'u- IL minivan nR phvan'ai Vila-IN": hula??

Thr- dd-guv' mil 22-h.- ?i Hutu" rivgu'l?i- Lari?? ?In; (i1 f?r




iwah? ??nk-It vid?mng yam- ?gr mm llt-I' :zf
r:

Aidri

.1.

g'msr hen. am! hm- quanta-1 5TB: Emir . 1 vz-rri:





wag, "(khan-in? 'zmv. umr hud'} in.

Taking anti-androgen; alone {without estragen)




Tukm: 1-- 9. tHIItI-h-c-h hue- -i s-ni-nu

glimmer, arr-.- mum-:6. 5:3 il?'dlt'i?ld'u'. him kins; Fur till-?I



3-031. I-udf? 13w- Hush-gm .zn-r ox,
?.41 my m: :rm?n-

Twulihe?g?i 1mm anu-mumgum wary mun mum" in ram-sou:
Average timr?m E?vzc: uf blacth Minimum





"'np-Ilh ant? :ly'i??'avi- V- dint!"





57.1mm; mzu - Evan:- r. .- J5: or: Hw?n?mal
we?: - :xm'c ?aw! .Jl?tv 5:1- 1am
din-u "1-11 d'r J-?wn- r:
- .b'nnw J-. s'hdlr ?ye-w "Emulglnu; Hui:



anal-4.1! than: a? 3mm? 3min :4 m: er -: may nan
humans Imus arm rim cam-:1 43.119
urn? HW- r'

.?mii- ?magma i?ut??r +1111": tux-3y
in. (?at annuals: w. and: may. (Mean and pm: 11:35?





2. 35:5an

134-11113?? pip-Mud "ivmlulzllugf? Fi?-n raw-u 1 in
iM- .?ta-cggnufs -1 m1; mini-Zulu,- :94: paw Isa-1h- ma?. ham; ?drug-f:

H?i'e?t?frrh ram! ur. Summ'P?wn sh" ?nun-153:3:



win-tit a?a?n ?rnrn perwr! 1n pus-1n:
?w'agc melimt pl



- (3.13555
ovi?gnpw- ram". and 1r: ham:-





- 1'

:r?v vii vim:-
II-i?mr?f-? ?57. in?rm-g L'ol?" c?
11:19:115? 191:?
12w" hwy-9:; 1- gr:~::ul1 a: all

. and mum 1 'Hwa. mam: am; :?mumm its:




yum-:1-
in] arr. ax'l'h
- Haw?: umm-J "an" . Nahum-Hag
Eff-:1
hunger. we!? we but?;
I a! gamble 5nd: men-?hang? #16 Ha: when
.. .





Err-.04 mus gmw?: aha-:14 s-arit- ?nl? Ix maul". argtcinm -
3.:I1r- 17.n- uun: ?reh- Iur lug-114i Mallzl- {tn?il 1h:
?Arm thy-?r 53- 31?w gr .17: 5"nrt.?
la: lilr?nst', nu: 5mm iu?w?i? Em A mg, if ma:
251- mm! 3mm}- wl?: Em Hm :wm? lumlkin 4:141? {-3334 numih m:
fur' (UH-1

A 51?: mud;



mm mm wumh-r nusmu? ?ai? Sunny :5
Tl?n- ml! Sunk nan-:1 tau-Jib? Wu c1
Jay" is; {my :44? ml surmour'e





Mun: Hi n: Etaimx'n Hr- .?sw mean. 11:15:54
thl- tnm? :iu- gnu-?aw ?1:5 Wz?l? In ww
um Hanna: um: Hw- aim?. Hm- w?s mm? I319
Natl :Ewn (monihc. tin-1 {awn-

dawn- bin-IT

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_?DO45656



\u-r
111-10, Item 22 of 23

I Junk may Emu Sam? Elm! ?ve! 31-11! ?z-Htf - Md:
1'

mummy? ?rm-u! his-.13 45.14. lunar :nu 3?an
th-w-?upuwm

i135: mung? 19 mm- 5* sin-w hh?ifwtm, pl ?mug. ?mum
mama?

. rah-mi 1: what 31:121- Iv-r-?w

taxi; int-H- 353:; nil-u? 15w I'tbiihf?k'i TIM-A- ?uryrni-

Minor Ema-rand Ml Haul}. .I'uh' In: ?hf??tl :fy'uu m?dl?;



m'a? 911"" I?h rage}; Bu??

. - -
3km Thaw: {th??g?i Q?mm?m?:

Mud. ltu?mun'r 151?: up} 4H-
pyruggnu-sgl r91: H3: ?n'a't?allr?lt mm! Hi {hung-.0

will u: 'ihr: - {Wi- ?15 Huang 1315'! Maj; in?




iz' F35 :w 11m: atEtH-m r-Hny?x; Bur-mum.- Ha dam
yew sh.







M: 3w.u:- wu 511.1?.- mm:



W'd ?1



New: ENWH: it v-?ull 4! um quip an? .51;
In.

5va rmu? Lug-.141 3133.2?. 'l'l'nff? "uh-czlubz-?nlla
ha; I?rHLiztli'? emu: a?e?r



rem 3mm. aw canv- lhi --





mutanira?e'mgvm WW:
Bil-Imam Nrrumw??. :m'qda' -r?u.Hcm.1?? mnw'lh
Ewn Elam,- hn?ay?. trim-.- m? rs?? and 3mm
2:2 (5: wr'i :iu? mum.
liuii?. Lil?i Engel- ant-v {Ir-durilaqw "pg-(31 "Tap.
- un?t-Mum ?my .Lht'?u it:







4



1: ITvrm an L: an;

Inukt- uni. {umr hat?! "Vl'll ti dwa- Edi-1w: rho
:?luiuvgtiufi anurrp'w- .51; ?r-zni 512.; yam mi}. ?mliuna
in?ulkmy Erkf'm'n mu m; aha-mm if iasu- 4.31mi
autumn-4L fmt: pm wm?k mii. Emir in: 1'1: .JT mn- ?iir??i

muggy, mark Hm: .hq-IL- arr- w- cu.





Wasn?t image?

Hormuna therapy won't active.- all body image
problems.

Tin,- 5145mm!? {humbly}: W: [1-14 ?lth 5:1.an
35' r51?. 45.1%! (kn-yr we yum mm ems-n.- rim-51'
'Pn- a-t-h-
um; 11.
.Al'h'r hatred-luv .?u'rul we; nun. e?sui




ivr'r- itch-:1! ur-? ?who rm-ru ?1:11



fun! 1197.?. 415: .u

fl rem h- Epmi 2r, ?yam-.21- gg-tuid n. lu-ij' ?1mg?



Pr?rnmmaai NH m? ?=m1 an!

mg: ismh??l? aw."

bani-"nun:



411?!-

1. Harmonie Iherapy won?t make. you imq
somebody else.

1 Eu? Ll! ?1 - 34.. nil: a bur"
1- i 9? L.
. H915



i?rm'hqw ii hint". ?1

Imw-rpumzmi thy mm ?zzy-mama 515' 25.1; pm. ws-n- r11.



. .
u-

"hr 3.1m: Isa-:1 3-315?! and



a

yup: am. a! 524-: dcidu'
:ghgilJ Wham-cw Emu?. farm {Wei -1 u< ?Why-chi MM

p.

urahmrjun vi? mi! Hinwhtilv. amt 9.15512! Myrna: anti lhs-z.
9:311 mumv ?Mumm- Ei?etrm'm mm .5 43? 31-15 ?u m-sr" ash-{shim +1
mar mli ?an. away



"-Huw?i gm.- I5:
gun-.5 Hm! year?: v.13:- mm EH and 5erall'ri I'm:
. in. gun rr [pmiminiy :mng u. Ew-

Till; :?Hlt'mfd Ln mmunl Ema-nil}. Izumwtw in. 1h Ii Tum?. Eu?irih- who. zt?lerr-
?er {mar-fl gen-Hui Ii'ymiriaufza mu' qui {imi taking: hui'?icd?'ri
ru-a?k niirwu'vr I'm'nr Hum" it 11-91?; inn-W.- dam-nah?.
Lu}- mrII-r-glrai lam?: :31:
ELI-?mug?! n. 131? Guys-?3m! 31?5"" Edi-i -I- 1" h-d'mdm-w
14in. :i I-umw.? IfNifl'l'lr?i n1 humth

.1IEE 13m, gut-4. mg -.I Lulu-r u: rhinrgu

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE



EPCD111-10.ltern 22 Of23

3. ?ormane theta par wun't prmride you with a
perfect community.

Ed?m? mm.- !H-uj?i- ?m'?iur?a: gain-rainy tn 1?2!?in a?elliuflf 15hr.
w?hd they my ?in; lilimu; x: wk.
3.. :1 tht- 353' ?acid oil-v 1* ?tn-361? :34: ?w {mum-h a"
w:ij hv I: -i-1-y nu: 1115'.

mij 1312:! 2w un?t:

9-1133. Ina] Aft-Y :iul)? 131-3. rt-umm than. wi? Iw
w?uialrxi .1.. L's-uh? man? in": pUI-?i in; Ihr Wm . 1
Qua ?511r 5d?; {runs yrugiil' 'Jl?j?w'h liwg?x?r rhalg?ai firm
{wigs}; In :34. gnarl-1.x? that?: Illu'
11;: MO. l'a 333'! .n mm. gnu-:6:- 2am?
?(Kiwi-5

33-inng1h+: uzt nun. gnaw?. n! :9 .- unmnum an
:?umqu?r iu-umulz?l?} mn: wrmEr- When H?m?m? ?mm-1m?:
Khmer .: daw- n. izrl?i utim an:ka mm.- Iszxw gum
2-.Jmim- {Nit-:3 Hun-.125. Thrall?. .ur :1 m' armri dam. pen-5:1. Lelia
45w: 1312i bin??g: tut-31: humumw arc-13*:

m-Mih fur

dkri?? 111125th




hank: 4}
3294'! lax'cmp' 37mm r33p5rrlisnuw auwmun Fun
m. imp: Ejt?'?hg?g a 1.1 axmtiv mar ?air-53TH! airway.



nub" htaui's: Eris-m2): Hal-4H. E-?Hal 11.5. hm? E's-v




malt-:5 1mg: y'c-t: u? I?m] i- km" HE run-hum
{mi-{wring rm human-ma

4? Humane timrapy won't remove an

"maie?!?ma scatiine?spects at your body

Rum.? ?Sara-3 {Ewan-1? Mai-:34 {Eh-mm;



Mi,- rm]; pl; The; r;l 'mtil? :41 Iihrhm

hm?r swam. 4m m- um] Jim

Hm! thug-Mm! {mm ihr a1 plum-In.

:rl4lj'ln i "0.11 .111?;





iI-Ii mnur aim-?51w rm}- mz?w ?I'ji; 5mm 3? h?

'st I Maw-3914', bu: qu my; and




..


155-?: aim-1:54 aw h? mun-r in! mm rc-nyq'r raw-w
pw-unmurll' Er-w hun- Iulrt? in? rag km.? in}:

0023-1 D2214 D1 17

Muir! :1 mum-z: mas- .u'ic-u Ski-m1 at! ?lm? "mini mm: mi:

Zuni? H'th 541?!" my: Elan-31mm: winir utin gig.- ima-



1:11.; - :ll? rho: matfn?u: area}:

"Fe??miznm humwhr :i'u 12 change mum- ?v him-Pi it



panama: 1- banana: mil-e! ?an-m ihz'ra'spp- HM: Eli-5p Juan-.1?
pm? mhe akin-1'15 .zrnpe-r-rh ?unaimi w- Smut- Ri'l'lr'r.



mm- 3.1% Innis :Jf :mi. RT- 1-- 1?

"milk-:- raj-w: Wat-Jr E:

mm i?ruu- campy-xi EH 1' pain-Pas Ii'nazm'rmg
Imw i c'i'rizlmr.? lite: -.- 't may: vnm? Hum-i F?uul
3-1 T5 Aur??w autumn-Ewan 'rrz 43w! h: i'h?ago- 13w
a3: agn- ui Iha- ?mi? and and Nuin?' 4 mam??



?5-36: Tin-m :trr :m in. ?152-1 'r?Msr LII-?ght ihr




3:;znzL.






?mk? Eimh Inui'sshli 5?:me Hut wilt timid!

aunt u?'tn! whom-1w? .nfu?i

nmir saint-1:115 phfn?n?. ?la'r -r'I Ifl?l? 33690515?. :1

m. 1m?- Imw; gr: ram gin-ti a; 1-p31i2-n3-

Ilfh??n?f 11sz Ali in" ?lm] hum!?
:I?m?ilr?n: Unpmumlg m. im?u ?rm: aw:- :n
Lri'nluin- ym'nry. ?Li-u! idle-Klan?; 'Fr?manmms
mm lr-ir- ?rm. snywaamg 1h?: tide rafr-u-J-m: 5"?kfzg"1? Tr.
rim .niualpu: mm um: wayr gnu-m} Londom: mm the; 5m;
gnu; ur w; '?arv'n- mlh-Ii 71-. minim-2? m1 (an as?? m.



Wim?i are ?rm ?umimtx Sid? Ef?mtami?a
=53? ?kminizi?g? Harmm?m?

7m? a'ifi?r In .uzti ?ml'nn .211: rm: NEE-
Hm" mur?z's 1m uh'? kw in p:th

u! hm'm-me- mma-w trims}? 4511:}; I Linn-nu

nigh?? fr; :rw, 51-: 'Ith um v4.11. ?Van?-



Mum 3? 1:3 "mm ?ska ui hz?PJms?e?w: my: hi lime.?

I hum-mu L?mt st- 2 ihrt'? 11- HrI-t? 3:



. rl-iqi

Pb. {1-22 unt'HEih'r. [nu-mil: Emm- Silk-I5 M: 1-340 --.-



?12

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_00045658


Item 22 01?23

119k} :?-Md?nkt. Lin-1 ??rlnsa'umq: ?Em! Ezr?f-?h :ism- whim-5'.
mu: dun-.1 y-za m: war ml: hf him-ti aim om




42.4w: and tit-JEN- :i pug-xih?m ML tin- :mimull 1:5
1313?; mm Nu?; (mm: HIT-ail

1. Genet all risks

Th6 ":I?ki i?lj' ?it h'L-c-i

Thump an 45 inn-'i'iniyttr mm?! :4 bun: 991-11? n!

. H, mm





ms! ?mm: 54: Elu- Managua-v.1
:5th why: '1 .1-111151fz .5 hl??f?mhe? arugula; gta? mm,?
J91





h' u_-r 9m}- mr- iww- ?Em and :u-dniwu?lj Far ll cut him.
.mnura-ml rum 8 ur m- hvuh'a ?lm?s-s!
it: Mr: ii-k??ia?








night-1'? in :2 flu: wrung I. . hf '44-
t'humgl-z? Hm 4m': in

. .: pa-np'u'

?l'rm .{I'icu'I mm; mains: m.

\ri- 1th, megs-i a'rrywih Emmi- w?u. .



.i-A.r1 1n2i: alumna?
var-d :I-mzu mm.?



~15 5mm? uin Ii'gf?L'. wut'?t?d
un?lur Hf hum 7? mm mm 'mu ?unk-41:1 dim?! inluuy
En i-m- Isu?i?ilrhsu'. 'mcifm? g-rrahvc?mlml

r?I?



aw! I).

2. time af estragen

gang?: ?11. ?ran?; ?915 q: ana-L
.1 twig: win! an 55W 1. {Mammy-rat hruir 13mm";
-.- Tim.-




hum}: ?ruhlrm- with ?31: "via is
?ak "Ham-4 virus a, gnu-IE1 Ins?wz fur; :mkz'w Hum? v. in. Mi
mm: The 23:3 5h.? wn?i am an
.. ?.535, you; 3r;- J: y??g?uil-g-L 1mm u?gi'. mil}. gwgur-u'ilkl mm :1 iuv. (la-I .12







hard: :15- }.?aHi ah Platinum: n51: Mum] m'w mm; h:
van-41w: 1-515: hm 39", tank-w :hm

mi :d-m l-f. ?my .4 Zn'a'ur d-w-

vars-$6? chrm'; ?4 1hr 9:13 imiv mr'uinr'mrr, :mi Lt?:
?imam Hurriixr: .gm-mgn
"am-:3 Park timing?: m3. ham:

bdrm-1'- Hm 253':

L.- hi?" 1






a
I It! WERE 1J1: 314?va

["3284 D-CI D221 -1 D1 17

ganiihiuri?lrl fun .3 4w chit-1 5323'. {um ?mum in: ray-hay

5p rig?? :m?ny

Emu-.1131: mum mummli Lil mi [I?H?wulh? This! mm
ha- 1.:1 lung: mm xvi-Iir'h arm" 1" Elm-wt Hum-ti Fern-2:54 h'
ltd?.- inf-n.- wiry"! {barman ?:35 rail is? $1 ?1.1
:m?mim; .1: H?i?f? n! nwdu??tinr: ?St-11115". rm".
1L vmni - Flt-cam: cud-r?- ?mm-1th}; HI vii-mm;
:uhr 31135.1".

snub??M Lu Hit- mm :s



P?'kmf?i ff?t?-xn! ?alh??i if;
171m: madam-hr -.-
hrui. v" :f'yni: 134' main: 4 .IHLQEH if? daft-es.

:i hrul'lh gamut-WAG;-





?353-. hr? .v-t gr-wlr: :4 nit-4- Imnu'w $2521.34? tim?mmv tt'nw
nu Hwy-Lu innit-rm J'ararw?u?l 11'31- - air-.559? mm?u?m 1-.2 11w

gawk-mun n} 9.4-3.1



'u tum: main. El :2 :mi kin-um: 1.114:- mi; of ?mm

5mm".er- ii?: yahulmw gland. Maria Illa?im'? ywiu?m

a; all; has



Mi'nr?ng?h .
um. haw.- innmm'lws Fr. IE1 :1 11-45%. i'si-th
Fruitrk'l: Han?). ?wfkr? I'll: itm-d tiir'1'21??i? 3'01: and

strain-2'35. and hu?; "Hz; 1w Irwin

?rt-x hut?! :3 auldm'r?ml

in mi kit-um: Mir-dig! mm":
132153.- .L'I'uilh (tar!i [Hunt- i?ld?x?il"; ?Mfr i?li'iv :i-frl?l I'utl >15 3111?}
win-34!, 4hr.- Jtm'iim; Ixnnurnum HI Inward
r1:er .uT IF 3.14; hm?r. .1 imam; mam-f.- [mat-U t'numrt hat-1-
Ewrr. ?un?t; 311123." fur: uwe (lulu: wan. .lls? .utu'
as here?. 11-5-54 w-Jf. war I'mvujl-r

Haas 3h run-Eq- ?gm- u! tin-mu? mun-r:

3. Side e?eu?risks 6f anti-androgen;



.gfir-?MF Ltu- Huh-r ans-.41 wit:- the: knin?m I:

are, 15:5: 1:31! haw:



1:1. ?provi- wan-r ahm-E mt; pm- my Hi 32



{Hum-rm, uni! if-w ?lm-.1 pn'asuu 1" :nniv E: s-x-c?fa u! airman?:
:31: ?.1311; mm: Jan wan-w u-hhrw 4? 11mm: 11-: hiw

infamy: rm: The: inn-winds 1w :wnm'rnt'a



?lam-r Ewe-I: and hum-n: n3?. 1'2. 2i?- Iv.? ma

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_DDU45559



K,

\o
EPCD 111-10, Item 22 Df 23

1- 3 igimzn Wu 1- Walden?

II Hkrm: :uwm?ar-r-n fhli 5.1? rim" Mt'm?l! puns?! mm
durm- f3; 1131313512113:

??ung ?tram-V?. Nuna- 1" .
mini-.1 1 lwi?li'lu'il. Sim-1??. fir-mm?? .
ghaha . i .- Hamlin-1.5% n15 I'wuph? laugh



gar-dust.- err inn?: awhium:

mar: :Fa-a mm.? .1 Earn Hh. .949:

w'm: punk-rind]

vr'lrf-vllr-I'

Summary 54d:- Elfecu u! MTF h?imunv {huf?ng

[rear-156%: ism-wed I?m: - mtlimwn Ira-I LI-stg?y

- helm.?
umnm- m, 4m: mm?: 36;: nutm-w-I-

83094-9 Fain hawbl-t ads: n?m?

- mum Wm}. 11.? - :Hmn rams-4m





:rrk tit-?n ?s'fl'm 9'14}

3? .?auwu'y ?'54
- m" nag-me. 3H a) til

5:113:11 ntin in arid

?Page: - a! quitsumue:

up? mean. up. i am.



f't? mum-n tile-.11.;

=4

?51k} Fambie 5di- effect:
am mam: :usu. are - 55-?l 3r,?
?1 at thigh.?
Mg? Mel: than?:
mdc' LIM

-

no
u.



Chatmim Whii? Yeutwhicmg


?15 Eur?;- mu Hm: Mummy?: fay-MEN? w-wl HI 1'!qu r?3-12
:5 I11 wguq? many-.- arm-mi
5mm: ?rm? gun-pr nib-r $111132: rwnzaumr the Mn:

22-13 Mm in $11: mm Al hum. 3-4 ?Ir-1. we: leu-



imvrr s?tr-?mtzuumr 3' ion-a! :wmtir- with :3
fit-I- mi? Lin-11'
- aim-u luau: inn-N315

rho}: pm: h' Fmi inf-swan: g?I-u! \W'mhi. .1 Fun-:2 :flim {lb-.15:



that Wm: Mn: Tux. mans-1 .uvi i6." Lt ?ml
um Am: um 59.11125 :hmi mm

I chm]; 3m ?mum; ugh: E-hd?yl-l? lL-In'. um l'n' nth-?Ki
mum' tin-rum. "r may}: hair." ?Ir. 5m! I'm-m 1:114 - um.st
{ts-av?

1' Emit?; frat?1 f't'wm yr?: ?Hr-?1 ?inf. Haw-b ?Iulw "-lnmt
513:3? 11min-

m; why: {mu {mm 5411'! :Rrevh ?ux-1.1m: ML: 4:



?rude-1 m-jn'miu'ag: 731: maid; am

?lth-Mb," hwillh inn-?f?lh
ma harm?. whq-H?m! murm'nu? {hr-mp5. mamas? risks-Ah.-
min.-

Im raw-w. c: c'nmn'r?r mm- ?nal MW ?1113? -I mm";



?Mu-t comm-2 E?Iruvudim; w-sr my {main nu;an anti->125

rm (skim: rP?rfm 547? tit-13m rm-Jt- ?and?
5-. pr?m: . 4 v. Eng-r nw'tznu unm .: 9w? Ful- mum
uni-2mm: mu m: mum" arm-Jth err alm- 11: aim ?tn-$71355
anon lurid?:

Wink- Hr} Hu;- Program . ?mam; Em- rips-L



3 3?0? ?rl?



5; had rum? light.? than ?mu warm, at":

maxi, am: amino daaumhxz hr Han-1:: mmhil

. did-fu?nr-



. .HFI IE
Q. I Ir . M: nutan In? Pl

.h nun-pl fl. mu m. ?at-rim II: - \Er. Ew-uIHh



[w 4ij .P man- rm .h H- :h ..



FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_DOU45560

EPCD Item 22 Df23

1.3m .?as?fse?i'e ?roll 511w e? - -.rE limsr 1211-? in: {In
II turnta?v main and-hr ?aky-:6 1i; 31%.
?Elm: ilk-33:16 :a'sum. Liz?: ?minim mm hr rummiis'd. Wu 1:141:36
in?lrhr-j' tn vb?li?lifl? :qn? HE Fad-femur. 5mm 5pm:- mu}: 'tu- ?Humid
unlii :?um ?um Mai!" 251-1 mum ?mtm'.

r?axim?xing me ?am?ita. f?isaimmng
Risks

Their.- :1 number M'?u'ngs dr- zu nc'ir- :m-cuw-
innuma iltumgw {in ME NH um}. miv :ts
Hr inform-w} wank. inn to win-cl.
Wu 'nrii:



planar-Jr .urie ?mi ngi-iE-ruH
:0 1w M?s-um Mimi: mu! 1-3- mm mt?u-rmmi
pug! ?~1er (.1651: 3? )?luli re lint H'hqiv'l'i' in:
ifml'. thr? Jimlih I?m-gram Ward rum: hm 'nr'ir
Iwu H'smm'r-o.

Hwy ram-3M. or rm Hum Stigmata mm
na'is uu?n?vr-d hmumm: "mam: If w: :Irr- 3 .u'mokn?. mm-
e-Aq r?wr? Emu-5 1:15;? hum-1n h- 3-13: 'an? hunt! Emily l-u h'u?l?
sgun- pmHIh-r my; nun-En wu th?w'uinl: I: {pl-n umer
h. r1 nu: hum-3p?? mr mums: mania-r, i1 41-!
sum you awrn't Icmir' N1: quit, rutt?i
duh-*1 551:1") ?mlr 'uir hvipx

1 Paint! {malt}: runo- pmv-Ma?r (rm: trust um! mm in: harms! mill
Tu 13:: the nun: hurl-time Tum-d :u is: Ain't t? ml}:
.a?w-nh- :aEv-ut yum warn. mmam: 5m 3319-: and any liri??irSIr-F :a'nu
:n-r ?aw-swarm: 'a'lu. :nwd ilt? P- $15k Liam-xiv Ah yin-.4
.iumlli'. mm: aim?! 1mm h-znli- dink-5E.
hum! Haw-i him: w. .191: ml?: Min" mwimmun





--.I all In JI .



my mama; Hug-[mun- I?m-l am? In?: Pn- 3: tin-m-
~lnn??s .md hetlag 'I?yr-rli-ezi if-?m Fin-m arrll help cram-a rim: that I:
"min err-t:

warm?: ?aura-mu. Tf {mmhr tan-?? rmmgi? pm-i ul? 1hr
m?m Manta- imvuu tw- sent I-r- sir-sh u-uh
- .imnan'l, mlnyim




purl-.1445? Ehgl
ii
$3.1m; K'dl?i'll my? Inn's?: Hal Fall?: win-r11 1mm nn't miw

nnf?mnhw?S 351

:d

(I:

II

0023-1D-CID221-10117

?an? t'mmgr mitmfin? on :tmrr ?rm-:3 run! hmltia
pram-1M- :i s-u'n 9mm Ia: mm 4-an IM M?unu u!
male-um? 'I'rtkma mpduanm: :mm as hurt? z'
air-v. Ii-awrl HM



(Enid Hun. risk: :1:ou
va?t'l: ml Hume?. .ucmml h?m :mmu'He-ru: Wuf lumilil Wart
s-mmtu? wh- kuj?s mm! mm thy-m 1} gm; wan! yum
memrstinn. 1an?: mur h?alii'. firs:

Trukr a Mfistir: Up?r?m:h raga-m- Purqu Emmi; numb;st mors-
iiun Eur-vii. am! 1 manque-i ?My mo way I?m
Shun: {in-up'm h: H-Irmn'r- ?rf' Elfc? 2512'.
id Qua:th gamma, and ark-ht mm
mm shun: hvin max-{mm van #141] with nth-2w hem}?
:u E31 hilt an End 15' l'n'iil l'mm muwhi

Kmm: {H?wir? gu rarity?: 333:7.) Hm wraith Palm-m:-
ran jun, :imi nu 1mm and Iraunrum hie-m";
mu] cal;- 9134'- F'?ip (have?! ital}.- Fr-ir and
an yam} nun-n. Tva my. mm ?Hi: Idknwik 51" pm . r-e-1
:mr-surn'tv Hashim: trans-u muf?n! Wat-113.6?









n: inn: hr .5me prim-uhnln-?d

Qua-51km s? Cnntam the Transgender Heaith Frog ram:
nm1-12-mnamm armlu?adew-xl?c Lam". :Wl
imam?? ?1 1 49911- 5 314 its-333m? 95-2"-
Eruj-J: izrain hhenl?x' and


li?n5q1?n we: I-?ain: Eonah- .a arc-nan- rah-.4 ar?fl car-f-uje-unul-?ew
.



pen-q Ia; .c-whnf- ir: Bf, wilmm'. .1 In H, Iu-m?wh an :ma-m.
k1: team pe-uMev mm bfo {arr-1 "Elude.

nit-Hamrsl argon: ham ?vuwx} via-11:; any;

gr." H?lal'g-

healing-won] urn-?ma mm 5132-: Err-5: ""33 um: 'u-le





- red-immeahm-?ugyr Mm'i wand-?1

- ?bre-raw nahmn, wan ?rm-mitt; and buppo':

Erma-J

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_OUU45661



22 of 23







FOR USE ONLY
LAW ENFORCEMENT SENS1TIVE

ManningB_UOO45652

EPCD 111?10. Item 23 of 23 DD2B-10-CID221-1D117

Gender Idem?? and Hm Military - "fraaxgmder, ?I"raas?eumt and hunger

identi?ed individualist the [21.5. ?rmrd Farms

A rerun. the i'aim (?cm-2r
l. u-?rsuy 1:3" 5mm: Barbara



'i?m'ytm Waiicn. MSW.
February 2907?





?taxuasui?w. Dumas: and Selma 'I'remiiuicm-c Remarcn institule. itdm?mmi,
\ilrgimu 23234::me irausucaec?vrgz. i-or mum snii-mlratmn. piczmt mil
xuxr??m ear ?rim mg

FOR OFFICIAL USE
LAW ENFORCEMENT SENSITIVE

ManningB_DDO45663



EPCD 111-10. Item 23 0f 23 0023-10-CIE12214D11T



My ma?a?? fin-f m: a: m?'yr?j- qf'lf?wxc?? marmph'.
mig?imlj- Index - "'ng m-rr?mrnmex Hl??u?k'i" - Hugh? .1
ind?frmri?y. mm?
um?? am a; Hanna; 1' u! .4 ?Minimum- 3? mifz'fm'r aim
rm :fn- mam afiwa?gm mm? plum?! and
ur?uh?', gmhm-m?infing and mum?;
iuugmwc. Immir emf rtgc. Tn i'rpirar-uh? m?muj: prrfu'fm?
aim-1'imy'mm? {win-aw; hm'rt'? wins groups mar
have: {hr ma?a! my! Hum Hm! {In nu!
5?in {haw (intriguing?my 1; mmi'c (. 1.311331th, ff?r? :ha?
Surre'frujb- {If (31' rim c'n?mrws. M??mg {hair
may Mung, mm? t?fj'icic'mhr
Hm! 1-5.-

F?r maps-1w ?f?-?eslem manna lhc. Emtiy can nub: assume m'n Nahum-:1! iiwrmn. the:
male had} and the Mimic: body. This binary we?: :?rf the. had}: and m: Hubscqumi
ulhzi'nretaiinna ih??igh hm}: rm and gendcraupmm In tn: ii willed Macaw-n. :md man}- Hf
01.1: American ansguutmnh. such as. me hast: than and pursonnci
pt'?i?ic? upon this iracmmtal new. Fur thcse any ot?thi-r, \r??rw of
sex and gender 15 men as: lii'td??l?illi?g K111: accepted, natumi orer 01' ihmgs. i-immr?cr. a
mung-my rui' and many nun-Wencrn individuals dc. nw wax and gender
:45 mm: ?uid cum'cplh. Wimihcr our: hwlimus that gender and am an: Maury and ?rmi. or
lira: $133; an: man:- i?mid. with the main- Ui'gcmim' Edema}; norm :1 uimiicngc if) the
milrt?r} argue in lhir'. pupcn thus ?mailman! 11163! that the inc-:33: mu Pam: only um: ni'
Harms. am: that {hum are: E33 hit-i rsimcrfui nu:

ma Him-3.x- pnhc?ies and

Li Gwen-ire?

The. fun than smiiwry semen im-rth us. the. Immune. praciiccs ui'nhysicat mining and strum
humminn la's discipline as Ric-1y Smuiar cmmi bi: matte ?tum
training. Yam, Kidd and paint uni.

Few ari'ihe Emmy? nl' :mraticm Snn?? ever intended in: them
to be. uniwrsa! am] mam-c. In particuiar- we we may: alhlmiu

Maze regaidad an a ?nuilc prawcc' and tilt: maimin (If
serial mailabic I'm spurt:- v. {hr buys and mm;

Thus, like the the immunon was nah-Juli}- male-
ccnwi'mi and haul in Jim] 11h this Hui-magnet}! (?I'i'cmuic ammu-

Accmi?ng La?- Ream;

In the: iliila?. gunmen ihir pm}- and icvcl pinyin; 51:31:31?:
missiri? imr cumpeummi and zair?clcs gm:



Nran-rv'wz-u um: my). .4 Nut-q. . [lair-tin. NH)
Wynn. 'erux? Emu-:91- ran-.11. 5'11 fll?zzm-rr- Wran 91-333 LC r5. in mi: Mayan rims, ?inrm? *i
IJ

FL H.313 md f? EL'aurm?ly. ?Mar-mm angina Ir. m'ne v.4 1m jam Kim: ?n Juik??!

.145

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LAW ENFORCEMENT SENSITIVE

ManningB_00045664

EPCD 111-1 0. Item 23 of 23

:15 331mm in fan" utmmemien 1:15:51 mimnaih'snat Sp??
Imim'atamv have been {ward to

Similarly, the idcai hmijr, that albictw ix Eli?iumali}: made.
and ?ux idea} rspresmls Elle M?wie? binary wi' 11m nature?s: Izmiily manna. Fm? man-1mm
we know that ?pink is girh :md him: 13' fat boy but we dun't know Wham we
learned il hx'iw

?I'hc flaws ofnulitary Mammy. an the development art?s trzedimmulty meantime
kiwi}- mm physime?y and as wail Uh an {sf this ?nch mm E518 lairgui'
"Fundy" ui'Ii'n: mihiury' and its guilculmn uh?tilcs and n?guiaumns in Order Et?i mm: the
Wed {01' cunnlxu-wud) Harms." in?rm- lh? tin: 513nm: rd 313111113! which
cm-m?jiing Ih measured in military contems. MCFOYI pHH-uh?? the I'u?mm'ka UH
{emaic KEEFIJIHI, Of?cer an in?ighL mm m?sm?n's MW Ui'li?nnic military capahihl?g?

Snldu?i'ing nut-him; a 1:5; ol'phy?ical {it'lirizies Eikc E'ii??i?g, jumping
up email dam-n. and muwimg. bramv m'rmcn can (hand: nun 2% we? gin;
men do. Um women do :15 was? mm cirJ.?

Thia brwl'smemcm illustrate? ehs: than an: mien ussmnamzi wuh u-umuu and
men's. h?n?livs and zitcir hininyicu! ?iff?cruncex. i1 re?t-?1: {hr 2: mud Ia
min-rpm ihcsc {fulcrum-ms being Liciictcm?nrv; czar an Eh: part w" Ema]:
imdiw and stl'cnglies m; 111:; part Mmu?it: I i'thc min-:1 pf rigidny is M11:
maic muscutmmr and the mm: [wads- wuh sniinms, and
discrimiuzlmm 111:1? cur: hnnjie: i5 arguably usgtxumi in the mtinm?}: [wed in
M11110: bud K15 napa?xlr Hf gum?. mg whims";

m?ic and kin-alt:- bikdics Elisa requires 1hr: tr: Jeni mm a:
whit: :?angc +raf' maln- whose: hadms may mi ?t mam},- mm either cmugm?y. Mu:-
1ra11rs?cxual and ladivn?ia?s When LII-J limes. hc-fwucn mair: and femalts mt
hlurrcai. prubiunn ??ery: thmugh thu challenge such ambiguity pow,? Lurrcm
lcgui. ha?rhat-mmi and tricdsuii What 310131 the. unitvi?uai and tilt: say?w?tm;
response in ambiguity can he Lll?li? xaiacmm in narurc. ?iuwiwr'c was thirs more cicarfy
acre! Ihni?e H1 {ht mam? ?if rim: milling-z" Much hm {wen ma 11w.
mama and ?3 hemmed 1311: 5:11p: u! this rerun?! it.) sua?icw Um: particular literalmu
anapn,1riam'rc 1h;- iusut: (if gender nit-1111M in the military 511:: undergarmqu mu: the gay.
k-shian. and hijaexuui Eiiemsum {mums m: ihi? mm: of gemun'y 31mm; th?t sat
hem-cm what auxtlatiiy Zi?nwcd am?: mu. 31mm. What emerge-.4. fruit:
ma; Jiulugaw :3 one of the principal icgni pm?mcrm uscd define ivm? umhsgunm
gentler idem-Ems arc award in Hm mllilm'}:

is grcumdcd in 113+: hinr?cdiuui, bushel?
ma: only tut-ax: saws, male and .icmuim. $1351 and that am? gem-am}-
is tin: 43:11}; nuccptahic ihm: Thsa wm?rmrd 135.- a: [-Jibi?ciai mandate



.- . .. .. . '3 I -
rf?. Kai-Ls. tame-2r fdutamv am; Hr. HJ-nm .?uie'?n'rw ?sh-53.

as um
?swti'H?gm. 5:61am
Wat-21. Emu-1e: acrsiu-s

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LAW ENFORCEMENT SENSITIVE

ManningB_UOO45665



EPCD 11140. Item 23 (#23

44

3.51411 htmu?mexatainy 5131' ratuaii}: {anacqumhlu nr it um." ??blicai manna
iictihcus 20:1 3] statics. "If men has interwumc with a man mm a murmur. hum
im a?mminmmn The}? mum be W110 death.? Coanucmiy. zl'u? mriitnry, as a pan
aflhis Judew?(?imstimrIslam?; rc?ccts and mil-areas this. hmary aysicm of
and summing; through the: mamh?c ?31? "dmn?i ?ask. 1km! 1.2257?:

For the named Emma. gcn?m' Identity. which is 315.0 labeled Evy ihv nuhtm'}: 35
{writer Ci??ipliu?t?h Hti mam.
{itcwamm 11-01:; strict mais?I?emafc hadxm 1mm}: of Waxiem socmlugy.
puruminr?fy ilmt m' Western military institutions." As; Ul'tlals rt?gmrt, huh: has: ?931
written csancemmg the mp1: :Jf mm-erluiwmi gtmict liiCiltiliUii Ihc malimn'. i in
uun?em cannon, and: liicmiima Hm? Eh? uareE'tu dchaeami Llih?timt?uns sex.
sexuaiily and maini mic. thereby mummi?in creating perceived dimmer it: me.- rigid :?m?fer
(sf-st main:th Hiructum. Tim disun?lcr and the censcqucm mam!in to {ll?ii?gui?h
whirl}; marked 5cm: hm.- inletm?cd Ilac Vu??rli reamian nonuwnihrarniug gandcr
jdtnu?llus. +92. W35 the came: when [he- Lx'ss Ange!? 1m} Eu: Shot and 1: LEE. Maniac
after hr aliugmliy munich .1 Such :zciimis. am: GKi?li?Ii?
throughum the mark}. As Hagar uhmn

The high lavas iegai. scmi-EeguL :mu?i c?ra-jmhuial wn?icnce agamst ighi
peupix: in many with: Jenna-racists res-11H from HR: $1.33th :3
mmhmaimn Ecgauws, weak
unacceptuhir Fi?tif? ?mrcca and deep inn-?15 a? mmiemi Thcx'c
ihr?c iimm L's! Huicnw Hand mm 9:11.111 mhm" wrlumt iam-s!
me; much nfTme Police: um?mnmruiic whee;
\y Mid t?f?f?fludit?jui ?rth-?31?

in addition. these:- same Swami; 21m when one ?:urmcicrs EEK: imp?? u:
[mess-:3: gm 1134x351 gender and gender ulmu?iiy perceived hf; mdwuluals sziemai to tin: Mannisz pm?snn.



A .?ihcxu. imam: .an Hmucancxua?aly Ema?! {Ta-Am"! "runner: H4. 111 flu-all." "flurmulla
aha: ic?ue.? i" i. :31 ?m 3.11; fax-awn?" .13
Dew: rum! Emmi "h 1mm: Biat??r.l?l?r .am? :ih Elm-rm'urismnn .xf?omm? i fit-3'?
,Jmur?n (m infra-m1 Eu:

mm- huh,- nw? :c in Ewmmarum? lcslumn. o: h-?S?hai '?cau?u?i allci'mwi?h 337d '5
4307:5119! app?? in Hausgm?m. ga?itnicr Idcniiuu

Hcmca? Erma?? "imm?runh Mun rsi'iuam'sa; (uh: 331.2 CHEM:

(With and in Mum}, Ekut' V9.1: ?mt-ml 1:3} mm lush i?ri?i?ihh?} 1115mm
1 K1 Velma. heme Tin: {Rumm- 5r: ?carit; I?m tk-mc?u? him?: Sand-c Hummus! tesm-s
lawn? -r?memui-if Jr?amr?h- fie-imvn'u'u: Swami '4 1165:: L4

5 $211 LEE

VI ?v?-?Iinm, E. I: P. Wmemd. Hun-3 13mm in timrma. Hing. N. \r
EFF-mum's mm A. N. Shmgau. nan-aguniic: and In My u; in mm? than mm'
imam" an am,? ?13:53 f'sf?prn he thur mm ?2 Misha-Human:
?i ?.'Lmnc 5mm Pc-Iiu'. 1: hitimy mmwun?. r: rims: 2? Darwin-luv 3?
351:8: *H'aih "11ml HE (inn Hm I .lul?a
rim} [Ag-ma My s" .132 mm".
Mr I L-cl?t-fm and Raging." 1.. 1. Paar-?5. a! Erin-nu If? fii?

inn-.1 "ih??nm; Mime anal-Lamar mast-s; main; and dimer. Law and Livia-.3.
Ira-5w?? a? "i'mr. :51? 31" {unwilnuu ask furs-.1 is {fir-ht:
?arriva- m1 huh, Maui} - i. i lasagna-Hy HM:de Hm. [Ln-er; as st



3-1 5 p.








nun-t to 1 3-111?, Iii; dun {cl-cram? .?s'rr'eh'fr' Hart. 'fi?u:

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITWE



111-10. Item 23 of23 [1028?1 1?

?at: our cuimrc {he rigzdil) ni?scmeai ailI'fcrcucc. gender re?ex, and gamma}: rs
Warming increasingEy Essa While nu: univemal. I'm mun}! armed {Hem m:
hanger 3.x" miirmn,? training exciusively based 12110:?: 3 mm ham-can male. anti
i'emnh: ba?sdics. Thi?; raise-a pcatrnliaiiy co:an qaxmlinm Wlih in tranrxgen?xtn
lmnascxim}. and mdiwduals in aucta 3'5 when. Liam Eh:
ihmaleuw-malc transsexual min? Dues ht: if??tfi wiih the man baa-mesa hr: 15 5t: Mtim?eci
pam-npcmiweiy. manning he opts ?ar surgery. dun-a hc mm mm. inmvmac
his chrcammnmes are ibnmic" sinus mac Eundiu ihc NY ?rmaie'.? Similar
wart: Ema 1.13,? 1h?: inm'rmtiumi {'Jiy?mps't Whiiu minimal}, H. is pussahic Ihui
the {Ir-35mm: m?auch bodies in the mummy :nigin he saw. :13 a gateway
un?crmimug the hired uf ?triciiy 5cm Emu},- am! Him? {119
of 11m Ir?il?iemi? masculine {and}: Ye: ans-er. such uhii?gi?? may ha
lgmiwd, far I'm mailer how and in Vv?fk
var inlcraewidcuii?tsl 1min Hunt}. ?l??ti1L1N ni'Lit-c nnlimry' are. they are
cmmumnm? by 1h: mihlm?y?g of :s hil'lCl :?i'p?raimrl hummrn naic and
fcmaic and am rcquiw? in ??iow us mics regarding 1m? autumn m? drum: mdimhsals
Who LiC?w?i?ik? i'mm scxu?i and gender unrmra.

i2 Brief Stud} (ialtciusinns

The primary 011:1. that the 1.5.3. Human-R hisimicnl ircaimcni :31" mm-
gendered. :zsnhiihaumsijr' gendered. and-?0: gvmicrtd
audit-immis- ha; created a ii'mmdahh: x'wca'aiiy litigant-1: in the mtl?ary system
g, and Ill?nl?l'tg; man}; manta: pm?sula?y ?5105;- wim fail within Variational}-
z?wcupicd um}: mics Wad}, 31065 that .r-?uncrican
are amt: inmracl mm hr with
{mm ?sher or mihtazims (Ina: in
:Jmtituiimmiwc?d m3 mmx?cwal, or J?ica?scx?iLEcnlii3??
individuals mum ht: mm?cuiiy .md legaily handled. m-cn il' m?il?ry pubic-an
ware {men i? working with such imlmduals. Hm enslimlimm! wasu'amm mmhi mews}?
mm {mm (mamarring Such ms El?i?hllii}: mum}. man whom mime?
Rig-untied 33:13:11} is es ass-er hem ur when :hc gender dialijit! has. nccurrcd paw:-
mai?imy hen-mu.

the siudy ?nds ?11231 military n'cairm-rm of cur man-
gendered individuaia it 1 i pruvcna?m-c- am 131.21 hr: Iran?.
inun'scx?, mt?: ihc military and {2's acme: Fenian-c:
{hum from the mifilnry when they are an?idcntu?mi Tim {regiment emergus from din-x11
Eng? pumth and Mimi). imiwiduui ur group {imims 1:3 tin ulhcmisc.
Mnrm?wcr. whim con?icts m' 411?: "nanny" do arise. they me sypumii}: nan?Erma and 1h:



i iirphn. itmnic if: Hm I r-mmum, Sum} mt.- 1 "313w.



wag-552' hum. n: 1.13:: Mmikr' r: i P. Hymn?. "m m. ?wn?x f??d
. (w ?re. V. ..
- - Juan's-arr! halted 3"
Haws: ("Mugged Fug-g,"



.. MEL 12:41.45}
- - Ext-gun:

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_DUU45657

EPCD 111-101 Item 23 of 23 0028-10-Cl0221-10117

Lo":

m?imry is swii?: and surgical. It exams 1m: ?disease.? 1mm ?16:1de 01' ab;-
Form. returning the dump-ml :dcaiizcd hndy in. the. rammi'

Then: 1:5 nn cunimnrsuz; rm whether my not non-md?tiomi gender identities rightiy shank!
be viewed 21$ .1 nm?ua! muulinnu or a paych?pa?m!may. While. the traditi?mi? Wcasimt
ma?icai vim is :1qu the. is a basis fur man}: grams which art:
?nciuds? (3131313.? the barmaid transgemim timbre?m i5 um accepted an
mane mimics. Indeed. as bdrm. sums: ?mrign countries :?luw :ranssexuais u)
:1ch in their annual? Farce; because: ?116}: x?icw 1h:- iasuc as being my: 91? 3
disqurilii'ying mt??iu?i tnndilmn. not a

{3m if:ch tins stu??y finds the]! 1m: has taken 11minme
stand :5in nm-Irudilinuai gender Identith ?tH nmicr the may?; ni'discaw, pamme
and 11111! imiix?idualn dummy. and: :herc?u?c In in:
rcm?wd {mm service at in he pr??nlud l?mm me genius wherever and
possihic. erhm-u 1.2+ t?m mum clear 5* nicknamed than in the Army Mm?cai
Suniccs Standards (If Medium ?lms-?x Much states in Section 331.1 m1 Psycimsmuatl
Cnmi?iinns shut the "caime for injection for aluminimcm. and induction an:
transvesaiimn. rnycurmm. and nlher pamphj?as In this
rcgulatim, Ihc military Incorrectly ctamsi?cs transsexuuiism 15; a pamphliia. a piy'chintnc
?1150:1161 ms-ulving dexr?tam sag-meal practices. and jump-:3. mmsacxuahsu?: 91:51
lmmpiuhaa ?arch as imam-chi]; {cushism {icijahiring nothing {if aninihut' 'I'hlS
fimhcr timsc mdwiduals do an ulcmil}: and perm-Ludrm {he
ngu'! M'hmm}: sexual and itiealmmitm ul'zhc mamm?nc hotly.? Recent
abut}! like whim}; as)? gender admin}: dlsurdqr as 2.1 diagnosis. much ?rst; a
psyuiu'apmhulugy. is inuiudsd an Karmic and Dt'd?chti' id?sliz?cd cam: law: il'lti?imltri
the mummy"; um: m" [mu-an, gay. and -1rwa~.md cam-Jaw sun'mm?ing
dressing: 515 the pathway in prrz-acculc the ?rmupic cases. hung US, 1-
(jucmrm I and Li). Madam?1?



Lastly. "In? 51ml}; ?uda as Jiwrsu and Jinan).
pm'mi'mi in ma mum}: cu-unirm .?zuuh m: 1511:1157? she (I'm-uh Rupuhiic,'_

-
bpmn." and lhzmand 3le such wiulu mom Wuxwrn mums 5ludtcd mt.



Army 5&1- ii?
mum-Hm gay-main; A {hulqruilui'}, ?mu .?ichL'a'5'3'1 1.1m nu .m Mr" a, {'11 H?vash 513m?
in?. ghmim. ?mu. 5"3'31
Puma}. r21 Main-:5: Eulncx

r?nma-m?set: Psyaheamu manna.? i?IIr-c


H. hum?: Jan! .1. ?much-4:; 3.1. 3an (19min 1'5} ?ungm?ktlv and {J'L?Jz?llunl tz-Emm':
Eh 3. ,I'mu 3min! Pu? Jug; ?as! Hun.er maturner-'1. 3T1 3.1] 3M sf 81.31.;

I ?i v. hiadasla.1nk?r..i. Hlf?.? HR 1"in

?rm? in: mum: 1w? un-mmg bar-mar? ?35. Z?l'ilm

Amanda?; Hm aim-?r. "The mu: mime?ch us mm: was ts.- Ian- 2131mm} man-rm
till-ulde

?m?mlm?; ham: Prwziwcri mutt: ?am-3r he?dwnr an
m? Hagan nu .1 112111"; t: Samm- z'??il?m??lg Hvuultm ?ch Nam-gum.
and ash?wk Ani'raand

FDR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_00045563

EPCD 111-10, Item 23 01'23

f?

ENDER THE

Having laid cam an m-rn'im= in the mamas amt min-rm! in calm?:
aim-u: imdy. am. gender. and scmm?t?y. we will mm- examine: in greater detail how the
LS. addmmexs such mum in 11.5; and medical p?iicies in Jet-imam
gender idcniiqr. As; we Show. the military views tramsg?nder. and
transsexual id?nlifwcl mdn'y?uztis m; and deviant, and drank:
?acj if": incomi?mi with the nmscuimc ideal has 2m icmg mod is


interning and lhe Mi?iary

Tht: 1.15, tmiliisr'y docs nu! ailuw Imam-L?: :nd?z'mmh be me- ?hca's;
muncrsuiiuns comfucwd by may Lm?cmgatm- z?h nuiamziv cc rue-mired the
I'rzihm-ing mfmmulmn hung; pmme imam-.5; imh?nduallsum1m! .?rilUu-cd be
?'lct?hi?l'z'i of {be :?ii'my Tim Murmur} 51:11:? 11:3! im?i?hhi?tl? are
nm :xilmvmi in the Mai-1mg": him-y and Fem: ICCHIHCTS state-:1 than the}:
Miran-ml that "ht?i?g a ?:15 a: mammal ziisxgualam'ataml" and Hui 1.1m Kan-'32
Emil 1hr Air Furu: mauid nut Lit-cm 111cm us; cundntaics For their ?nned Barnum brunch.
than [1163" mm: the pqinmtivc which i'url?hm aligmulixw
Ihc "mlcmax" 3.11ch a'?'iwmg. Rmcmitcrx were. unable prnruiv :1 m' trimaran
111;; [his ?ack to accept an in?iwjunl
I'm-1th iilnsimacs the mmaruhing tl'u' 1h?: m??ary 0f cla?si??mg the body in
gather math: 01' ?tmnic terms The Navy rmu?nilCr ma! 5:51;- bciim an! 111% "this
minimum wank! require much n'a?cdicai treatment and that 1116: 34:1??me hm wish be
taking sac-h an i?t'h?n?idliizi mm :15 11m; 111-: rcm'uilm ?5 :gnnramtt about mg-
emltlui "JazcdiLal isxuca" inwiwd nmy be a tr.) {lac rihza'n?m?srt with
having to duct! with an ??nality that! {mars iiu: Immn?arica [mm tun and {break and its
pnk?ml?i in much the name 111:1! mum-w}; an: "Stu-d? undcr {0



?ah?cu-mw? and ?53?th 'I?muwua mu: f'vnideMI-Mts r11inc-Emmrimuef 'iiuu-C Ma: manna.?
E?Sra?mn mm f?u'tq m: ij- ?3 3-H

"'f'iungt iit?Srs (?smnw Prey-cm .?timirsair-n it: Eruph?unu I . Ail-113: "lmrunuxsi Pam
in: Arms. 1'13: In}; ?scu'y Again-.3 f. Hi; \usk-n Wrr': Mn?uml?m 25-. Jim}. Ians?u??
Swim-4&3 Jgjm-u 1n Amnf inure.? \rvud Remasth T3. "Kenn-u.? - =5
5:493. {Laws-:rmi "m?sr 1c Eur fr: [hastranaLHun Nah "News "5 in?. Multan! Ema; rm. "wm
3.3. llam??uuls Avme Ann; T-cxut- Mime-540:1 5 IF. shim?:
innunr?; 3H, fink-1.- mix ?2 Al'timuun 'Am'h "Gr?cu. ?g?my: L. ?Lanna-M Win: Primary, ?1 .?Jfbi?-t
?Snam. {311:3 'i'ranssr?xua! hitiim 3k ?5.31. Hugh-J1 hen-du- "anmc 5. 9U. Mari . "Spam
Eit- Enema :0 Scm; ihu M?mar}. f' ram. New Mummy)?. \?lamh 3:51".
"'i'iL-u M?imeja' Hulls Scrapping ?eizrma! i?sfmr?cr Tag}: 3&1: Lina-H." Fran-1y ?xuguii-I. i I. 3.1m,- ??I'hmlasmi
fit-1}, quitEI-rm.? "4:613:55- JR:(mm. "Hm 1141531"): 1.1.5.5 Hrw'nmnn.
"Thaa?gmd f?m?i; {icing-mamas; n! I answering; {unsung?naT Pmmh:





:?nuggw, l3 'El'H'l-i. . . .
Fawn "mum-g Sting-ta Lid . Ant-gum 3 1:112.
?i 3mm: agiunm Mm;- ?dunss?m liuis." Emma-cm! Shir. January 3164. "11:54th
thruA'rmira 'f?iuu-aws?s Mum Lust I'I'mgc 01 ?rm-:35 Hm fr?aa?m-eu ?31:1:
Sun-1a: H3. 2:561},
?rm-4:111: masts-ms {Evil-1?:

a .

?(lansw Emmi this: F- i I 113'!?

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_00045669

EPCD 111-10. Item 23 cf 23

rem-cf dismml'm ni'thc paren?. H. 11st? be painted mm mm meg? mica: appiy
an 1m: Valium: Guard and the Rama-1:5

and the Military

1? ?hiIv the human; that gamma 2111* medica?y
unquali?td 10 serum, 1; deems ifxfi?iigfim?ICr identi?ed as psycImIi'Eg?caliy In
aim 0:113.? refereed study of miinary. Brown the: militant
m: a chasm: For the phase of ?mast-ma} dwi?upmcm. In this sung I '1
male pain-nu 11:11:6th DEM siimds'mis were mam? Bunsen
atmeg "Eigin nl't?hc ?ssimts had extcnaivc unwary 3 n-crmm :Julivc duty. I
was a {Jcparunmz of ?efmse citlph'zyca and 4 were. mac-ram.? 03' t?e?cvancc the that
than. the nutunmc. xat? mIIimt}; service was. mum-Hare discharge 111 ms.- majur?}:
I?m-v: mi: 131:1: the. Irsililmjr is a pIiiL?C when: mac c>;pccl :0 see a Ia 31::
number ?\h?lwn you think of it, what mph: mzmcuiim?:
acmipmion u?guld am enlarging wam In my than the In fact. mime I?m:me
w-maic midicn ilmgiu in the American and the War And
fur Lil'l i5; ?ning everything In den}- ur trying It! 123-:
impuisc. whai better way In try That is. why any many ufus MTFs an: Eagic Swma am!
mismana- :15 chI 211:: malice nI??cwrm ?glucrs? and paf?m?IICx. Yes. 191:: nf 113-." Simrlm
wmmenm made by Lissa an Fume I'?zirce and crack marksman Eh: ?at:
:miatar}. "Lake: many tramgmu?ix and she. 131-3115;. became
an I became crack I Ill! 5931mm}; 3L EMF-5.111: um! i did
nursmg? ?upping the ciasx.??3' Dcspizc this 5. marginahmza
maple. u. high the Army Medium Run-Mm; Sujndm'ds ni' mam: f?imesa

Man's clczu'Iy Scuinn 2?36 am {fiund?nms that [113: "causcs Em TCNEIMIE
I'm agapuimmcm. and insimslicm are Irunfiscxunlism,
transvuxlil?sm? voycunsm. and ?IIch is menth above. this rcguiatnm
clcm'Iy Immune. It'alusenmiirsrm nun?pumpi?haw wuh the 5.3mm pumphihas. gush as:



Il' Emrrw?c Shi'wa 91' ?mm: ?chin?

I 11" i' Lima iln?xwa? Ijugt?A?: whims: $3 an; gal rh?cnsc-

Hum-u. "I?rnnz-bmna?a. [Ii-i Mainsm?'?gn: mm hs'msw rat- I.

37'

Hi;- uL-rgma 53:, mc-m;;m Aggy; MEJML ,5 :mrf?i'h1risfum' ifmnwi HI. um;
.?L'uuw W1. 4? ELI.

Hi. in?zam'h?w? 5?4" 3i?






-

Hun, tn. wk a .. --

(-9

(Email! I 151'." Primlizfrl?m??jll
ask. I?m-z: Prcn? 1?s}

.FL. {'Iu 1? Hus-1*! Hm} 'zcn -. Limits-.1, i.
:nrsa

-Z. blawdard? :31 i'unth? II.

A nirFTL'fm f??'zugj??liai?c Anya-amp?. .?rmf .?mwum m? Huang,? ,E-h-e?yu? i?nuuiu' x, mi I :93 ii}:

If; wi'Hnm'n E??'mm I 41' War

.
?mute-1' I?e?ul'u- Lh'am?luq' 15 uni-.31 iLh' hung, will? Null,? ?h i??d
Pm :Isdiwzjm? mm! a 1111:?; and :L'm5a usmlin?icmmn {Hm awn-3y a [jam-c
In: any a? helm; 1hr: :uIIu-r .92.: I, II: dl'nLi-miial'1 In! 11?: Illi 4.1: 542:. si?rW-I'
I'm: gamma 'z-lt' 1.1.1.:3 I d=51n?wma== 1h. 5m: :lflm??lh wari? ?in, mica!
must"; madman: ?rm: mutunmml hat-WI :tngtun'lrslaz await ul-
Iierir-Inatg. l. mks-nus? each 9" {lame mum um {mm-y 31:1? m'?i 5m.- cxahdm?d. Name-rear 1 (NIKE-2E
Edcm'ny Dim-def: m5: 5min} till: amuu'. pnr??yIHI'Il?:

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningBr00045670

111-10, Item 23 of 23 0028-10-CID221-10117

1mmth 13: f?clishism. This; mmadcma?tmimn in" Lt'zln?ismaimn an. :1 pm?aphilta sligm?ii MD:
11:05: Indivaduais whusc gandm Edwin}: an}; Witt; deuam rum: :mdaiiamtl maie and
female. uivni?nes. and may imm- and autumn-phobia wilhin Hm nniiun'y. THIS
trident 1n the 25m nun? umciu. mantiuncc! mm a Li}. Manna
was Sim; by Inca! paling az?tax kiElmg iranmcwul pun-mum

:15 Li'gni Nam-w:er Sun-ma} {nude numb: Hut. "'i'wsfr
:?i'?bmi ai?rumiimsmis: may mu afoul
The Fifi-=1. 13 When 1t) the m?uar} The 59mm rtiutcs tn
alrcmiy lbs." maliiarymc Because this guide I'm garassgiccm'c
service hers and mum scrving, the s?tuntiuns {mung transgendcr Moran
an: Imyund its gimp:

are entering IIH: mihmry? am: submct tn both and a
H'such an Individual sti?e: Ehui hr 5116 transsexual! or
Imus-identi?ed. then aha}; in: rue-Jim! as un?t under the appjicablt? madtuai ?hl?d??ib?
the branch uf'scz'vicc lht? Endn?iduai :mm?tpiing An endividtml wish has
my twirl c?'gender innds?gamnh inch 1h; nr gcude?mn?nnmg
angst}. will he hath than: 1hr unlit fir-1 wcii
m: haying had surgery Ihui i3. cunsidc ad a ?Imam gaunt! n;
Shank! an individual {1112mm in a hi'hwry I'Jf'gnmicr mmiif'rcuiicm the mum: nf
rnmin'c ?jury-Ema! gammy an individuni?s gamma as deasgnalcd 31
harm. and if man 1h: sci i-zdcuai?cc! current gem?cr. ht: and can
ht: urn-d {iimhargc 1'1 candmale- Ezii?if'icatit'm Hf [hf
M: Lin; ?mn 11m},- hc he: :1 [i?aulduicm mxlialnlum and subjcc 111:: hen-'15:
mumbvr "m penalme am? dirzcharge

indivuiuza 1's whi- aka who. tn daring their {2:113}: :0 main ur mak'
I'vmatl?c may be discharged unch us wail as ain?uugh mics
r'uluiang in hummcwality or af?rm-drcasnag nl' Humigia luring ciarssi?cd aw-
un?l (if having a permmniity dt??l?dt?r The unimry ducs not ratcugmrc 11w
smud:=:rd:a Mums: when. it mmes therapy. ii? mg: in the gander
identity. am} ge?dcr am?t?ming (.?c?naequrnliy- the lmhlam ml} nut pnwa'eic
the medium summit nucwxury {u 3.5515! a writ: in Iransilimmlg 1mm his her
m'igiuul Mcnliiy the int-gm Making Marc-11hr: rmhlary?s mc?iual and



:3 k-Lwnr Min: nit Pmice mic: human-\- 1' jig-I :1 ."ruuir. Kim-31'th
"1 _i 35% rd .15' ?22:30?. i 133:1?: Evil? Elsz??un: 311?.?
i- 35$ If: (Muslims? Vets.? ?vhilia?; 1r21mm? inn-r.- 5i}
:2 ?nd

?rs-+1

.

?Rania. :tE fluids:

-1

:9 Aim-2*. 3n i??ycihmm iaik?uflj?ruu. mun-um 'lfq'rnmzu' .

Wed-'4 inim'n?rm?. 311?." 55h: rim"? ?xmm?m (HI-?div? kin-"11
{hapiuuzz ?ymugninn, mm ?nus-u 3.9.121: mfg;-

Vehlirr Fur-i u- Eiasr: I'ramlaims ?Lriun i12- Frans.
{may 4. $9314 ii he. riwt ?gkmi [incln?'n'nl? rim!) mm? it.? 1: lk?uli
?it-It'd guts-cm run-er. fd?JF-?jt?l mea?n-LJE amt aim-1hr: Hungary mu 252:! my? mime-:1 r0

rs? cmas?hs?mmz?. 4m HL??Ekrz- (magma? ?ni?ls :l .l

FDR USE
LAW ENFORCEMENT SENSITIVE

Manning

EPCD 111-10, Item 23 01?23

=3

services in address nuns-reimcd issues: an when he prahicmmic far
membt?r aw} ?comm-sautmx with mihtary hcaith-care [:rcwiaicrs arr mu muiidcuml
and any mm-vming harms; can: and mum llkciy mil. kw in
thew Comma 31:15 and wparm 'u'm pmceu??nga begun??

Uni?m: Ci's'?iim?. Mm rm: i?lgEEmST vmian?cms cnn??idmuahi'y and
ins-Macy [1y Euws such 9.14 the Hmhit mum'an and Am. nuiiml'y
member}. and their medical ream-d9. Each "doctor-patient In addiriun 11%
111i: lack gun-ice mcn?mm am ?3ch hardahips mi ?Iii!me f?mm 11mm
in the genera? 1.191151133111111 when transatimtifmd Imimc?muis are dcahng with heniihmrc
wanders (inc pammpam in a recent imdy ?lmed, "Thch 32:: grads at" Him-if
in iat?ntmn best-1th Hm}: refuse in subject. mmin 5mm}: pussi?nic
mistrcaiman and ridiculc pnr?ucapam Diner's-ch spent 3hqu hung
cinclma? a:th grning inappropriate . I was cmn-nwai I ?111114 he
msutuuomlaggd if 1 mid the? math. 1 ham?: Hm; {cm- was m::51.ar1s1hi? and humd is: real
in fact: at as haiiuvcd Ihal Ty?: Hunter. a Washingamt Di" pat-cm
Lr??mtkuui mu: u?owcd it} Need in my ihc ali'cci huts-1MB ?(mid um
Irma: hm: the}; app an 10 have? beliex ed that she was gay: my! 1131;} M05 4" Addimnuily
1i:ch the inability to access ecu-tray.? and the legal system's
t'uliurc 10 mapnud to wink-rice and abuse agmml and micmex
individuaix inure similar Surmumiing healthcarc
021:: survey I'ewondmn 11w fhlims'ing sinry:

:1 mi!ch minim! vimcd the unu'crsit}: clam; fur hank pain
b: ms: ilawuta'vr diacm'drcd 11131 5th: hail hum! muted fur imam?
madam? wm?e. an capimf knew on bar chart miriguous
Uttlitaiaaf The atudrnt Eh: ciin?c the
Dream: um that she *A-uzgid he Immecrd :12? :3 freak



m: gallant: up fin duh- ;mgl :s slur gnuuwsuel guy-tin ?rciqi': {955-211} {13cm dilcci ?r nude

.iw gum-I. ?fth;- ?q?lrc?lf?l?l? Erbium and \l?d?ifl}; (If

Liam mmp?mc 1mm 5.1mm rcamwnvui. "rims:

'mrmm may ht? Hamil-HE'S: :im?ual?i?h-d For umum? any?: new: am; am:- Lafird hm}. Gut. :zr'mf
TH.



i. -
{irra'u'hu also .?ei
mum-5. h. in: Adda} In "Sun-rut} Hindu"

Slum- 'framucnuu I ?gum EJL'xi-ihf, duc?uu [it hyt'ym:

t? ..
Rxn: #hrv





Iran?iuu?n.; Rascargia

II ?x-i "Ursula ?Imit- than: i it:- 53 Ese?il?limn: ?nah?r vi 1:an Wu?;
Fm: ?m5 ?rift: sa?a'iu'szl 6 U. Slum: .?1rzzi [whit "Ban: watt:- ihr-
1m ss-Ii?c- ?r?i?yu- RemLumhaaih R. ?1 5'1
?mm: Liuuticr Edwina-5's. E?Zwuncnuc-z mm Known-3: :md
llf??f} $441}:

?rmzi Km: tau-uh 31!? 1.1.11: 33:31:: 111mm; .3. gt' Hip-.5; Paint} 15:taur'= M'i'rmmg: Bay. [mi?ml urn:
Imam-raisin l' 91:12:" ?1 .uk Pink: Edmund} {1-43, Linux-3:, My?; glau?id?qnl 3:44:51]



- . it:
Mgr-1 ?1:1 13:31: anew: MapsPny'w. 'Smaa iiyrm'Hzl'm himnuns:- mesm

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE





EPCD 111-10, Item 23 {#23 00234061022140??

{Inc an the ?ea: sitgma and mammal pint-min! Ear x-?micncc 21m} persecution: trans-
:dernti?mi iudmduaia the may chmsu in use. nmami?ury awn-inc?, in Lia-?ct- su
whims-5 than i1 as mum-um: accogumc that cash hunch vi" mu anncd forces has.
speci?c regulatinm around yawning Micmai imahhcm-c back Failure
abide. by thesa- :uguimimm amid place a service: see-king
l'm?ithcarc at risk i?r mmanai adi?n under ihu Such :mu'an amid lead in mun-
murtiu! :tulmns.

Wlule in 1th minim. Indix'idzmis may chums in their gamer-
cunlirz'?ing at large: idem 113? clmhing. Ila-mum; as the 512:5 ??ijv' the Identity (if
and not llu: Large: identity as tultd. sen-en.- who Erma?drum cuuid b4:
pru?vtuitc?l tunic! the because. ?fth-1'. ct?mliasliun of but}: saw. gmder
njesmry. and mummy :ndiriduais {In uhume in crush] {31w risks If ihey
make any sexual ?dcmily in any mdn?ain? in me mainm-y M1114:
manual points mu. ?aha minim}: mmid View nuilc-tn?Ibmaki trunwamni.
:1 Pea-units. having. sexual mamas: Iii: nmirs to he
cumminng iiplb . inmi wmzhi in: therc?nr'i Quince: umna'Ms-iraux'c and
disciplinary

A numbcr arm-t a ??rmer .'~cn'scc 'uwn'?'scr: has been disdun?gcd
{Inna minim}- and has (leaded EU lranaiimn. may in: {uni?ed during Hammer}:

[{fius'ul'! for milihn?y xenacc .13 a mule Hie. 1:126 mm. hm}
waved in Vicmum and in mimemux nther campaigns: throughout mu:
5" yawning and had taken a or uimui

59391 gain; on ycar status upon A5 sum as her
11-min} disc-I?uu?gc ma: wmpk??I?d. 31h: irnrg?n Iransiimn from mm}: In
anm?lc. an even] She had hem! pianmng airmail}: her whuic 1:112.
Saddam Hmscin had d?i'i?cmm r-izms Ili'rr her. iimugh, and
Sump; ht:an munching! in {he Persian Gun: {isan war: uni?ed mm of
mam-*4: mama. M?mngh she had by than 15:11:: been i?n?ing as wnmun
frir mm" ?1 wm. 31w sheared lac: iuukr??. pm mm}- px'u?cripiimm and
amndicd (Eutf 1m :1 year When prcancd Ei'a as why she hadn't
chnl?mged her call-Hp 51w than she didn't haw he??
aliyuhm 5mm. changed. her berm?ta."

Fm: hm; hum dunmnsimied 1.31:: prawns Lmuaim?vns {11211 Lake pings: zil'tcr the
ui?nclim-me saw-ice can 51in mute. Snm'hir Samaria; mam he.
onrminnud Fur military um! Manama! Guard mcmL'ai-rm

Hit mum: iisuca can he an amped w: an man-Mani"; hmmt}
has discusmi imam wu?iraus. life stage. 1531.313}? Wlih g.m1dcr."? Numerous
mama-mm quesamm arm: Em- mi?imn- Emmi"; raw-ac? gendunmiatcd and

mychuivgica} mms'.? the sxs?piy vhf: macs-553:3 medical supp-art Eh:



liy-w, mam: Mn;- ENE: Wing-:1 Anniysps. laws-3'33 Lumhsm?

arc-.1, f?Jie?llzi. ?J'v Ivan-1" 11.,

11mm:- Adda: awarena?zf
1 In?, l'numg?rmh?'
I 14:11"?

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_UOO45673



111-10. Item 23 of 23



indi ?duals in after the}: mumiew acme?aim}; Hen-met?: l-iuw wii! Incdmai
custa- be charged? I-iuw medical arising in the murse 0E gemiw tranmmna
hr: scan and Wl? gas-inhian caf?simke nr H1116: ginning :?ohiems be: seen at? a
mmsequencc ul' taking wasng ?mi ihereihrc 31m he cuv'erad un?t-r n1:th ry bene?ts??
Wi?i! alJ'Ilei?g hi: ?fret-ed For nacmiwm win: Wit-151 unamiinn
and who need ta 510;: 51:19ng {safari can he Huw w?i denial can:
he mm;- have hum sta?cd? l-km- {wards in: handin?'?
("an nm?cs or in: changed" i?iuw ind!? iduais ha: imrwd 1f
choose. in h: buried at El miistas'j:

Aging has, ham sh?wn In he a cum-um in 111:: mnununityf? When
aniimr}? member: ?rm! musing 11mm what mii they hm: 1n
I'm-Hines" inc-:1 hm: already use impurmm?e 01'th mummy ofgt-nau'lc
cam and gender 193$ rights 01 aging
rdcmii'imi {Til'lh'id?xiiliv? hm a been dmcussml.? me may iShUCh wiil be: main-55M by
military rules. 10 bu: scan. 1. minions quesurms arise mama-mung ?nciui nuppon.
Hi1?. win f?'nrmm' :mmcumm he: handled? K?r?hu: about friends; and Mg?i?cnm
0:11ch mu in the military"? Thing a Large Iaicraiurc mhli importance M'mcin?
?ummn ueiwm?l?s quality 01' hie. lungex-izy. and huaith."

The Harm?mmsc ni'rcligiuurwirmmiIt}: in successful} 33mg h: 21:50 ah?:
lawman: "3 Him: wiIi issaucss ?mm-tum!in and reiigirmity be: addr?scd? Will
ex~rnflitmjv mcmha?rs hr. :?iuw?d attend cert-mimics;
their former places; uf'w?nmlup?f? BTIxi-?ll?ji?f :55.th upper: mil has-3111M care.
paiimiiw 1.21m. and fuhm: military- htmnis?. En: handled for person? Mm an: er



f' Duchy Swm?r}: 9.1 "4 A. 1' its: fit-pvt." w! man-una{hum-n. and l. and in Pairwim

Hum-a 'I'c?mmznI?L?i'ifiL hamw?lh?r ?gmg :it: I'nmuuw Rig-1H2kirrunrm-r-t JIM: and Ma=t=qx1rzainl :1 rt and hurrxt}. 4:51

ilmr 7-

r' M. [Mu-cu, :mci S. P. i'iac (Haunt; n! anti 4h: Ln?. 'r'ih his. .?fc'rl'rr'i
u? ml g?ln-l?l. 11.27. Li, .:

i" if. I anyzeuzi fialsuei. "Bung ?n HI: Hopi? am! licmu 55-1: and Evian?it's {w ?333.
It?! '31. tilt-?11 kc. Id? it ?uid." .S??vl r11, qi'nc'Jm' Hm}! ?mg?it?-S}

mm?. aim mm. Vijhimung (an. WWI

H. inn-tr. "Hm m; Ema-tart; [H?st and Her-Ju- Did Mfr." F'fn- Mr. 4 Chi?: fin-331. H. anz:
Liar! aniJL?Iw. Hem-am l'ypu: am}; 31.41".? 3in am! ram-mfg Ein- L?fdv?ld "J-Tuucm 5mm: Silvia"
M. ?-?mt3wr: and :1 Seaman. '1nE?Fumcv: ?Vim-?113- mama. Sewn? 'wuwi?. and
"??wum-r We? Hum-g In 1 am: no. A .?x?itm- mrtnixsm?l'va mm" hemp 1-4 m. I (CHINE: Ti Rama)
F. E-Iyikmnw. mm E-hnHmu-rh "Eh-:7 imam mm I?M-sacs] am! ?mm! K. upmgm-
NIL-round- .iumu- a! and 7% 56114 11 4' Run-:ng E'junhgn:
(.352. L, Baum am} I HLngawn, amumg I :13: [Nazis and ps?gui?a?fign?i? ?5:5 vim??

1?3 hiCtt-cv SW 3: Tncm'y r-?f 4 lh? II-.LE H: ?w
Shaman-jg: I) (Vim-n. J. Shem?. and f; -k Haptgm Madman am} .tistqa-talurzi Abn?nmh.?
554. nn '3 d?i?my 112? THE kuuw and 15 ?Liam. r?u'U'H'?i?i
I?cn?mal k?icaww. and I Ina-1 We." 3? 411:5 i} kulrnnam. L. 411d 5'
Ligand}. ":?H?bcmi Jami {Hiif-E'H'u Finn:ng "Er Smiles ?iuuraciin
3x335: no 4

1.. i'cimszam. i" 3 :?im'n?l pf Arum? - Wart-V
fit-cm

FOR OFFIUAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_DD?456?4



EPCD 111-10. Item 23 of 23 0028-10-CID221-1D117

and farmer mining be attain make use 01
?v A manna-5'? Wlii 1311?}: In: mspcacai :11 their new Wiil their medical
rec-uni?; to re?ect when muse indn?idunis an: in need ni?
in}: can: and whun in central 31131 an nniixiduni have E5313. respect"
spmm?s miinary manner}; he handicd? inw n-ih' nan marriagcs.
icgzzi n: Stine but another. he. addressed when in nuliiary
bene?ts for the. nurviving spnuac? Eqnni?y nnpuriam is 13w gunman m?nhcihnr or 110'; PM
wiil train iis {maniac-art: pun-stir?: in the SIR: cnurau :31"
per-5mm}. \?c'mc ohms-c are a in ?w
him-mum.

Transgendm' Law and the Military. Thus-r. 2:5 spark? cast: law dcaimg speczi'acniiy
mm m- titanium and 1hr. nniimi'y. Tim ?rs: was appears in in:
{be Aicxander winch the Ann}; its pnlicy ni'denymg eniisinmn
in transsexual persons. arguing that presented a median} prnl?errn in
Him! Ihcir mataimmenh In: hunrmne suppiumcnmimn migh: no: he avaiiahie 8i name
incantan where they could In: assigned. The gnarl dL?L?ilElL?d tn mach the ui'?w mac
suit}. Tn Ley?and 1 Or;- I, tin: case nt?mmd an Air Fan-1.:
msuwm Layinmi who. u'hlic iamwmhi}: giixchar?gnd Li?li?f computing a: an:
surgery. arguml than 1136 discharge was gmumfcd in and phyhinn! un?mua?
and mm mm not 13w can: "fin: mun ruled that the dischargv was m:
case in" Inu?mew and {harci'nrc ilmnd nn rem-(n: tn mic an the grands; {11?

1.33. unl??nc Tin: wurf's l'mdmg was. aha: ?mmu mudil?ni always
K. manure dsmhaz'gc immune-11m ?mam-m innit-min}- impairs. 1hr: ornium'a mining.
14:! perfm'n's wannaul zimpnic {lb-:11} Hangsmunlism n1 tar-111% at};
has e'accun ed Such a mnaiitiun, because ail stamens in {his haw puluniiul
which may Imam: median! can: and maintenance nm mailublc as! all
pr-tentnii plank. 01' ?1$$iglilhi?m II. is Mir:me in non: that the min-1. render-mg Fifi
jugigmcm. 11!?me 112:: genital surgery tn [355 m' amputation nl'a limb time-i1}; renaming
inc cnimtmi nersnn unniaie tin: I'nii nl" snidicnng.

iau' m' 1mnsnemai-Memi13nd indwiz'lunis had yen
undergone gander surgery 5mm; nub. li'h: L15. Dawn: 1 WEE). Davin was charged under
Anni}: 1.14 oi'thc LICMJ. DEN-I5 had rumwai a nf gunuim? disorder by
tam-CH1: \sn'y 113ychixtn'1mstud had [new 1101 nnly ?n?mn?numg treatment
an! 1314: Inn had been ntlunding transsexual suppim grin-43:: in and around :hc
?rm. case and ($1.46 iam- wmivns air-aunt: the. menu: nf Crim-
dmsxing which in disenswd in nun

3.4. 1= 5. it is nmmr?lan: Ln diningumh between aims:
(licking and ur Ethan-cm '1 While Ehc gn?cn? inc?1
chiming: {1335.4 nniicr rim: rutwnc hfn'zinsgaidcr identinum E: and pamphdia and in an?:



-.- 11551351 "mm mm}. .

(In Risa stun.

,gnu' I: a "funk,- t. Hi skiinmn; Pow-ital mt Maritaw .Hhi
I'amn; I I'm-1m} 2?9 1- mi: wink mu

:75?sz n: aria: h: llL??C-?rlrf iron-uh. :65

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_000456?5



EPCD 23 of23

the same as [mm-emu {cilhhi??l The Jam; mt make:
'l?a'amsh- c511: fetishism ialicmuu criteria; {Du-er
a: period via! team! ?3 mamhy. in :1 mate. rccurreni. imam: ?Finally Humming
Fantasies. sewai urgys._ barbarian: inmiving and {hi 'I'hc 2351135105,
5:3;qu urges. m? behax-iurs cause Chlaimttl}; or nupmnnem in
umupmionzlL m- ?riparian! mum nf Emma

on thy uihcr 13am- do um hen-c dynanuca; tisswiaic? with
mm-dressmg. Mm: uros??cir?s?ing individuals Main: [3131 they un?t?drum in (nu-aim?
[hum nf thenmciwa Snme indmdunia may :jumg-c use amnii atmuurm
uI' In alts-r their phyriical Marten-2'. mime tndiw?unln
Mm may .11 3mm. decldc In mum- aims; the
What in? :mparmm us than the vii-1min car't'mrdressuvlg
with U'nnzn-wmism and annanjcra 1a,: hit :1 paych?putiwingp, mach}; aiinwing an
Individual ha {ilwiuzargc? rm :?xciditinfsnaiiy'. Sh?i?d the truss-drawn; ha: saw. and
members can bu promuuimi minim" J?hfhf?iill?} mm
cram-drawing. ?A?hih: in nut a pm" Vim-21mm uf'mliwr
Articic LU unbecoming} m' rungs: [34 13mm?! airtight
perminmg in guud artist and diacmline]: 3.4: 3 nmuar. an}- mc?dcnw ui'cmss-
dawrssing hmughi :3 uruimnzami's Lutcnhun will hr ?nqu in he pr?iudmai 3:an :ardcr
and dimiylmc. "rm mum! by Sun'h'a} Guld? and IS diauussmi in sly-my
The: WES opinim: in United Stairs Ban-1:: stafcd Ihm hwamc llu': crass-r
i'il'??hmg Eihi?i?, pinuc m; a m?ihary ilmlailatiun [hm \wuhi "vinualiy? diwup he DTCJIKHUM
gum! and discipline and diacmdzung tn the smucd flatten?? Moran'ch the

mun also rammed mu that [ht-i} unusual cumiiucg ?her: :i mew-red m1 unwary
Installation. held an advent; cl'fmi 0n miizmly uni-2:: um} di?uipiinc and created a ncgamc
pcrn'rpiiun ul' Eins- amhml white-H

qumltull it}: and whmizm mm? af?xi-erss-my
puth shank! bL? punished wars wnaigumd by line \qu??nrinc Carp.? :51" ??tlitary
Run-"jaw in UnilL?d If Thy com": {hm {he Ut'l??i'ilici Hi'ti?i?:
did ?minus. the i315; [Wm chums ?inch: ?14. not withstamlmg 315 ham-mg 13km
piacc t'rf'Fhasc. The court did am cranium Unwd States firm-1.2: 3.1.4. rcquinng that Ihc
cross-(ircmung 1111 base wnlalc Amclu F. (mnduct Riitht?l?.
Dari-s was Euler?prulmi Eu l?gruan that. "grass-dressing. can x-?miaie :?miuiu 13?1
mgardics5 nl'ilic sum; as" the cmkith? mannich ihu: at him '33 min-Isa: 4:113:11 nu
5:1?ch and L'hscmiin?: and created a Etcgmiu? Mme ammi Thr-
mura argued that 1h? maximum I'm ?mud? .?Kriiclc 1E4 i1;
by reigning 151:: permitted 1hr 113031 elm-ml}-
rcimmi. Amen: 134 'i'hu L?mn?l conch-dad mu:





i- .w uxulzzniz?. sec Artw- hmmcal Strumap :9 mil-.3!

shim-mum, I Just! mm: Eben" w: Hanan-31.! :ai.

Prague: haw?3" u: v.15 Iii: Hib?sc." imn' Mulch DA ?34.11 4'3
Nana, 2-1: 3-H 4J5- Hf" HES:

[Thin-d 3:533:5-

{3:2 Ian 4.443

i I'IL'l-ni Faith -.

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_000455??



11T-1EJ. Item 23 of 23 GOES-1031022140117


pub?: mum dose}; u?scmhicz; conduct umlm Amulc 13:1; ?mrvihm
maximum fu'maahmcm ?amid appty 21?: I1 dam: I'm Crmducz. The Ctmri defined
awarded}; mnduci m4

(Em-duct such a ?atten: ax to affix; the and gum :11" pumm-
may wimmg and who be m- prr-x'n'kcd 1n
mere-h}; It includes conduct that madam-gem puhiac murals
outrages: puhiic decenq and any isrurl?nuce m' ?Jansen-{inns or
mthui?cm character

Thug. individe could he wmimc? it?! ?ulmgc
public time-Hey or endanger pubin?: msm?a when ihc cimhing of 'z'hcir 13:11:31 Mcmiiy?
?lmy may ccansinjcred violaivrm oi Article and ih?i?t?hj? mi};ch at."
pummhmunl am} pmsi?nlc discharge ?rm? the msijsary This: tinmsasm M15 lin?lhci?
cisiht?u?331ed in a ?tting r'cfcascs in which militpiy personm? were ?isvhargcd ?'ar behavwr
R?I?i?td In and other mam-m,

Expimmg that ramming, ni?gcmim'. mummy: and shimmy. I'ayim' amt Rum present a
cilsuussnm ?ul'rnundmg ?1:3 quanta: drag" and gcmier and sv'xtmi
rah-11311114135? 131 a drag subarctm 10 ting ?nely. mzmy maiE-tn-fmnnic
w?i wad: ?drag.? cm?m?mm?nl? Hider u: ?nd ?ini?i?ff?i??'i?li {7mm 1hr
{if the Meant}- aim-13m. these :uuimduais u?n 1d in: perceived :15 Tmmusm an!
In that the} an: ?natal nmica.? 1"er 1h: a?'ihr i?il'gt'l Mammy. Harry
shank! in: gmrcuivmi 112a Hem-c, they shuuhi be men a5. lwieruscxuni. is um:
Lima?mm than tin; mics :u pummum and dts'chm?gt'

Individuals win? mu an military gamma:

[Hahn Hf gumiwriclcr?lty arm as Eur the msinnry Fur usam'epic.
supp-Jae :1 male svid?u whims- Ln man} man-military inalc~zwibntaic 1L :5
payable. under mm Ezaw catnl'?ishcd in Van Ham?ng Mewnder, that me;- midget can
in: mm: ha: has max?mi [ht nuisschuulf: Elwn- that legal
praaimzium than tamed m1 sexual can he ammundud $171--
cnu?nhng :m gum'im? idcmiw iil's'mgm with his or Mr target identity.
landing 5-3 111:: ?iu' Eitiga?imf?:

i: aim important to imdc?sand the. gas-nuns: ul
Mr ihe word m'r! :1 ?if a

5 . ?Ji?rjn?s??i l5 ?if?$35? grenivdnr?nig .91 Euro. "mi" xs-?gasmjum 3
I'uahM-t. I) .?irmy 1- f} '3!!fo 'I'hg-ag; mud?; hyiggxm:
?1 Jim! min-1' Fin-Haas .

Rup?. "'E?wu'n Eh?u.? {32m 1:1' "M?gis?lzi?lizg {is-mic!- ?kul .n u} it}?
m- 4 I 14. :1 LTitAI?-?ilmj z. Jr .15 hurrm?cumis 1. aiming "imift "um-rum!
indium Lung. one; Warner: 1.1 firm-Nani :Ilt \?crmrI-n. and

Xian?! Kari-rm rm lmJ-??t?a. HT s'?f?m ?r1: um} - huh; agraunm :15. Irv-m



i

?v'J-u 151*1'. fuss-r: 5 71?: t: ij:;5r:351. fratm- .. :Ivhmic 3:95;?
'H-smih." as ?nun-12:1; a

Mu? L2: 111.?, E's-e93: Emu-d Huunlaiuur lutdulgh Hm(fwd?

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

Manning





111-1Cl. Item 23 01?23

5?4-
15.?

Sinnimfy? Argcn?zm. word iriamvcaiitu is 115m 10 cicscrihxr
whirl is cailml .d lmnaavxu?l in indies, ihc Hijm de?ne 2133
mini gender. Hijm ?mlwitiuals are male; 111' idcmi?smg as: the
"Ihmi .532" Hf India. Bangiadmh. and Pnkismn. 'I'I?acy HS acilhcr mun
mar ?wugh tin-y ":?itl?cr to {Emnwelvc? with pre'mmum? and was}: to he:
witn'cd if} m; frmalc. In Hindu cantata {hat-'5' in :1 apatiaii Uni-if: :icwwd "the
Baimchum Mum ?I'hc In?ian gmemmem has mama};
Hijm by ihui they mm- !mx-c legal mains, as a third gun?rr. in Pnkisinn. they
are ?35 Mm mi 5: hard 4:3 heggum
dancers and pmsiiluicx.? Hijr? incuns in Urdu? Ema must 01" them are
described 53.x ia?answn-?esaiws Again. in such a w: wet? the
snn?aii?n and idcnmim, and he Eitidil??t?. we
sea the lack nfcim??y hum-car; the and the mm-
pallmiugy of cmss-drcs?ing. Szmrim mauve. mat: in Linc: 5:3"th East and East Amn
511d] 35.4 ind?ncsiu 13ml 'ihuiihm?i when: 52mm} um} gander diva-ff;in 311: not 0m}-
mm'c th'idt'?'f??l? hm 1mm;- rcudil}:

the S. armed abs-C135. such mzitumf grammes; can raise important
management at" pvt-mime]. Fur example. Indagcnuus mm in
Paa?t: ?engage in gender {Maine's than hiamncesiiy him: 11:41.1 ark-nicely
for {heir ?af?x-w: This; is partucuiarl}; impumm: {in mail-:5 in
Tiara-m?! wha [might foftnw such and win: to cniigf in the 1.5.24.
mg?lmy? which cauld require men: in "cause mad durum" mammal-mama: gender
p??illi?l? nr aim: I'm-c dxscimrgc.

2.5. Transsexuality and Himary Functimning. uucmcm al'hnw Ewing Imus-
may m? may :t?'cut 4.: sen-ace atmiity in t'unauam as a hm;
1mm addressed in mm: int-3mm ii?i'uf?c?i, and Wick 101.1%: mm {he
par-him; m- not a "trnnascwal piim wuh ul?f'ccimg
High! can he raven as a risk due 131 The report NEH-15S than
ummcmuia mum undurgu man} ch:zngca._ sumac of which mquim [h ?33eg ami aha: 11m;
?muk! be This of EHIS 5122131312121 that th'. gander changm;
muitl "signi?cantly" impact an mdividuai?s ability in as :3 wither. 'l?hcy
?n'lhcr argur that "if?nabEXi?l?i? lend to have more amasndcas ni' mmicly am] Gem-{Won
lite-m lh?: tmrm." 'l?hcrc 1'3 rm evldisncm hammer. in xnppawl aim: Hater:an mar it-a 11 ?12m
What the. gmup [5 when such 3 5:531:3an E3 1 Hide. I?ur 11305.0:



?Than in?rm}- Harm? D?m-rdrr I?xirii'iu} Junk? ham-a f?rcn lupus: 1i.
Unity PM anm. Hum .?v?inu. Mu: lunar}. 151:: Afru'a inning-arr ?mm f. EiliH
- 1-. -.--










-- -1
. I 3nd
?i?al?u?v-?in - and mm: :msi Nagy-takes: M??-?uimir} u!

.ir: my: 1-: {39-1-1} T's ?Uvmirmd rjsuiie: Tlm?ri (jg-Me: In inri-n?

3.1: ism wing, mx .2 :7
I Fain-mun. I: Hg:th l'r?itgii LAM Hulgh- [imam and hc?izi? IT?llr-z?fit-IE' Mm?:
121% mm: 11-12%! Hr-m?m run-f ?m'mnand i'rma. rm 51.339112"!
319.3%

-. m] 1E I WILL mui F-Lgn: ?nah-1y "de1?: Numbv?. ?-U?Sahl-

111.

F'wmhw Erma T25 ?Hi?khi? Mm?f?iur 5. d3.? :1 La \H?i I M'hm"! {if 3394b 1W 3:5! 1

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningB_UOD45678



ltem 23 of 23
l?

he {in expencme limbs 61' am?; ?321}; and sympiums: {cud t0 manly: mu:- liimr.
fitment; and WICL tl'lm"1lwuugll ?lWEi?'i?iC??i and wiill the
patient. the transsexual :36st ml he: cansulered unsafe in

The ca?amplux m" 111:: binale ml? lhe haul}; and gender 3m 51:
pszicminl qxluarslinm alum: linw the if F9 arm-ml ?ll-gm 531mm .wlacl with tin: lmiita?m hi
?th wumrles that (in adapt aw non-rmrmam'e lacuna-:5. pollute nape-rut
Ia?- participants}. ?ay example lsrael?s mr?usn'gnc?s ur the Him:
121' luciia? amid in: highly as hm lumen. a'spm'aie
lil?dcm with Jhmign Il?lililzi??s?

3.9 51111.?? ,1 3" AN SIGN

The mllitarfy vim-:5 imln?idunlrs wh-I MIL-mil}; :15 magma; tz'aimgumlcr. transsexual.
rn' f?lh??l' ny?rn?nmumiw gender pr medically :am'lm'
disturbed and umln?mpwnily um m?ntcd flirt-ca.
lmliv?duaia idenuly {luring cnlisimm: 1111:1513. Hana-pawns are smnmanly
disqualified under unclusml rules. Individuals dunk: 1'0 Mental}
duan their cure.ch ?c discharged under the 5mm mics: 0t" il?caught
arc discharged llflii?i? criminal or :ulmimsmsiwc sanctions. Smulurly
miersm-idenii?cd individuals are excluded from me I mililary as ?hermaphmania.? :5
term that sum as palm-1L 13hr,ng anal pcjm-ztm-e by many. All l; military
1w Cranlelclc? indicated llaal. interact-z idcniilicd indwuluza am: presumed
remurc grade: medical attcmiun than ahc :11"?le {Limes um prance would he
g? excluded {'mm sen-ice. altlmugh m: Wile unable ulcmufy any :ugulalm'}; lugut 3r
palm}: 1135:: IN lhis clam}.

W: ?nd llml. whuihcr u? um mumbcm ul?ilm: armed lulu-5 are w?llng in work
with individuals. in film ham: wail-.131} ?1151 Mlle?? lhll.?
immwied mm slat-m. military personnel are: gum-rally,- unmraimnl cutie
cannm a: mare inclusiw Given these curmm mimi'rainia. :hc 1.
shimmy may problems when Intrraming mm mzl?zarlcs ?rm am: mink?
when it to trummuxuul

EDGEM EN TN

A mimh?r 01' individuals h?vc? asszsicd Ill Ila: m" Elm iprer ?mil-J Elia:
in tin: Individuals for discussilm and lid? luummg case hm
related In mmsgemlcr mama in the mllimry

Shannan 311mm. l..i?1w aim] Policy lii?iilwt?r
I - U9.
Relwcm Huwwr and Shawn 5mm Ic-srn'zm Legal lhefmm? Mylamric
. A . -
R, Frye. \cclamam? Ssrnuncmm. :md $13-11. PLLC



FOR OFFJCIAL USE ONLY
LAW ENFORCEMENT SENSITIVE

ManningEl_OOD456?9





EPCD 111-10. Item 23 of 23 17

(Thus W. Daiay. Luv: (Emmi
Cunt: 0f Amt-2115 for the Anzami Services?

wnuld ?31.50 Him in thank Dwain: Comm. Dan-1d l?emnicy. and Sim-en 1.31315; f0:
{Emir vnrmu? tm sex, gmder. semnmy, Uh: body. and
as related In the mam-r131 uz'this Lliscuxsinn





FOR OFFICIAL USE ONLY
LAW ENFORCEMENT

ManningB_?DD45630





EF-CD 1-11-10. Item :1 0f 23

3-5 February. 291 (I

OFFICHRL USE
Lr'h??lw? FDRC T'u? NT 5 ?3 VE

Man rung 04 5533



111-10, Item 4 {5f ?23

PCS-F: CI sinL I-JSE C: h:
:23: r: I Ti





EPCD 111-11], itemd ofE?E



FOR CIFFICML WISE DNLY
ENFORCEMENT SEP-JSITIVE

ManningB_00045590

Item 5 ij23 17"









Fr?jF-g CJFFICAL LEE-E
SENSITIVE

ManningB_00045591

sessiroofe?uwuew





EPCU 111-10. Item 7? of 23 0023?1





You Must Knock On The Door Prior To Entering!

If You Have Nothing Smart To Say Then It Better Not Come Out Of Your Mouthl

This Office Belongs To CW2 Hack And SPC Showman So Keep Your (Stubby Hands Out!
Unless Your Chest Carries Some Heavy Rank Don?t Even Bother Knocking!

The Individuals That Own This Office Are In The Business Of Catching Shit Bags 50 If You

Think For One Second That You Can Come In Here And Bug Us With Sissy Shit Then You
Might Want To Rethink Your Path In Life.

Targeting Will Not Play Games In Your Lane 50 If It is Games That You Want To Play
Then By All Means Drag My Ass In With You But Beware You Will

If Any One Of These Rules Confuse You Then Maybe You Should Turn Your Sorry Ass Around
Because You Have No Business Being In My Office!

GkoayllH

FOR OFFICIAL USE ONLY
LAW ENFORCEMENT SENSITIVE





Mum, 333mg} 3 My?
df?} 9?39

LL



EINLISNES MW
KIND H03

?83 $0 LUSH CiDdEl



ManningB_00?45594

POD 1 7'1'3- 3' 3-3

OFFICIAL USE

-





$11-10 Itemf?erZS



Page 2

FOR IJSE




11-10, item 00228- 1?

Page 1

FEE-Q C-FFIC AL JEE


ManningB_00045592



APPENDIX I

DEPARTMENT OF THE ARMY
JOINT BASE HENDERSON HALL
204 LEE AVENUE
mm 222114199

HEPL ?r ICI




4 M13 3' 1?0







MIWN 5-K JR l? In: 1 Wm .?kdx'mzulc ia'hl.
Mwa 1 Funk; (HUI '[L'IL'gI'uph Rand. .\!mundrin.
32m:

In

Tull :131' :lm'amnlwi mx'L'inL :12; nth?l'
lira-lit; \hmnu L. and Huudqnurhn'? .8

11?

".ran} Hum Hal]. 1-111'1 I

f. Ynu Mi! 1n :u'mruiunuu uil'n 1: 1. HTML Nm! Rid-J I'm'
4. 4M ?13 ".mil 215.1: ir.

lejx' Imli] Thu ii:



H11. Mum. nl' :hc 'x-i'mLulL- It 1'54 Arm} ul'
IMIJKK I hL?lnu'L' MIL in! .13 In L'wl'mmllu'c. prt'lpcl?L?hli'1plL'liu'J11 .11 {in
IL'pwt. mu? ?Hun l'nL' .zmll .H.
\I'Inja lm! SL-H ?1?41 Nu;- .m mix-L?rmu?ml :?ulL? In the Linc!
3mm Emmi. Ilmrliw'u. .n'lmi ru?la [hL' 111cth nulrzidc

\H'ht'l'L? all haw h't bu

l. I'hu: manna}. 1r L'nirIlL-d Ln 1-11?. xi lets-.1] unicsw his
wnn'ur. Ihih t?iphl Lu: il'l-c 3% ht: LiL'lutlL?J 'J?riul

(mm-3:11:11an

urilim mun". l'w cyIrIsIthl'uLi .19 .E 1mm Ihr LunLlLirunm and
M'l'r 111-4 L'u'unSL?! uilhmn .111 mm
In 14h u. th' Ihcir?
?hula 1.7: HII

f} Yum WEI Liump uiv yum: HIM - wisz 13H my, 3min the Links

I

'i nu uili sL'hcniniL? a 11111:. mm; .11le immunm Ju: hm hm: l'nL- .ant?mi'm :J'Llill

{Lidmivlzu'hlc :?cquL-le; in [its - Im new H'th "Julian! Hr l'nL'
ann?nL"; In: [in Inch-ti J'mm :Hc a
?f

munsul w. unimy :mJ cumL-h n: m: :v-mr: n: i Imm uppr Lzulufws cxcurb
alziyh LlL'itl'. urilmL? and Ifi hL'

tn] ?r'x I

if

m. DFCR. EXHIBIT ZZ



DEPARTMENT OF THE ARMY
JOINT BASE BAYER-HENDERSON HALL
LEE AVENUE
FORT MYER. VIRGINIA 22211-1199



8 MAR 20h

HH-ZA



MEMORANDUM FOR Paul Almanza, 150th Judge Advocate General Detachment, Legal
Support Organization, MG Albert C. Lieber USAR Center, 6901 Telegraph Road, .v?tlexandria,
VA 22310

SUBJECT: Directive to Investigate Additional Charges US. v. PF Bradlev Manning

1. On 4 August 2010, I appointed you to investigate the original charges, dated 5 July 2010 and
any other related matters concerning PFC Manning. Additional charges were preferred against
PFC Manning on 1 March 20] 1 and are enclosed for you to investigate. Although the alleged
misconduct is substantially similar between the two charge sheets, I dismissed the original
charges and direct you not to consider those charges.

2. All other guidance, previously provided in the original appointment memorandum, remains in
effect and the Article 32 investigation is still delayed based on the defense counsel?s request,
dated 12 Aug 10.



CARL R. JR.
COL, AV
Commanding

Encls
1. Charge Sheet, 5 Jul 10
2. Charge Sheet, 1 Mar 11

CF: [wofencls]

1 Trial Counsel
l-Defense Counsel
l-Legal Advisor

INV. DFCR. EXHIBII





DEPARTMENT OF THE ARMY
JOINT BASE MYER - HENDERSON HALL
204 LEE AVENUE
FORT MYER, VIRGINFA 2221 1-1199
- REPLY To
OF
IMND-MHH-ZA lb {0'30 ll



MEMORANDUM FOR LTC Paul Almanza. 150th Judge Advocate General Detachment. Legal
Support Organization, MG Albert C. Lieber, USAR Center, 6901 Telegraph Road, Alexandria,

VA 22310

SUBJECT: Special Instructions for Investigation under Article 32, UCMJ

I. You are directed to resume the investigation of the enclosed charges and any other related
matters concerning PFC Bradley Manning, l-Ieadquarters and I-leadquarters
Company, US. Army Garrison, Joint Base Myer?Henderson Hall. Fort Myer, VA, 222] 1. This
is your primary duty until the investigation is completed.

0n 4 August 2010, appointed you to investigate the original charges, dated 5 July 2010, and
any other related matters concerning the accused. On IS March 2011. I dismissed the original
charges and directed you to investigate the additional charges preferred against PFC Manning,
dated 1 March 20] l, and any other related matters concerning the accused.

3. The accused is entitled to quali?ed legal counsel as a matter of right, unless he expressly
waives this right. The accused is represented by Mr. David Coombs, civilian defense counsel.
and multiple members of the U.S. Army Trial Defense Service (TBS). Trial counsel from the
Of?ce of the Staff Judge Advocate (OSJA), Military District of Washington will
represent the United States. The trial counsel and the defense counsel each play an adversarial
role in the proceedings and you must avoid talking to either party about the merits of the ease
outside of settings where all parties have the opportunity to be heard.

4. You will conduct your investigation in accordance with Article 32, UCMJ, and Rule for
Courts-Martial 405. You will also use DA Pamphlet 27-? as a procedural guide in
conducting your investigation.

5. The accused is charged with Aiding the Enemy by Giving Intelligence, a violation of Article
104, UCMJ, as well as multiple violations of Articles 92 and I34, UCMJ relating to downloading
and transmitting various classi?ed documents, photographs, and videos from Secret Internet
Protocol Router Network databases. You will use applicable portions of Military Rule of
Evidence (MRE) 505 as your procedural guide when classi?ed information is used during the
investigation, subject to the following instructions:

a. The accused is required to comply with the notice provisions of MRE 505th), and the
below special instructions.

HIV. UFCR. EXHIBIT


SUBJECT: Special Instructions for Investigation under Article 32. UCMJ

if the accused intends to disclose or to cause the disclosure of classi?ed information in
any manner. or requests classi?ed information not previously produced in discovery, the defense
counsel must provide written notice no later than fourteen days before the scheduled date of the
Article 32 hearing. This request will be routed through you and the trial counsel to the
undersigned. but only if you determine that the requested information is relevant to the
investigation, not cumulative, and requested in a timely manner.

(2) At my direction. the trial counsel will attempt to obtain the requested classified
information on behalf of the defense or request authority for the defense to use the classified
information in their possession at the Article 32 investigation. If the OCA does not agree to
produce the classified information andlor agree to its use during the Article 32. then the material
is not ?reasonably available" under RCM 405lg)(2).

(3) MRE 505. that decision may not be challenged until referral of the case to a
court?martial. but you will include a statement of the reasons for your determination in the record
of investigation and note any objection by the accused.

(4) All classi?ed information used during your investigation is subject to my Protective
Order for Classi?ed information. dated 17 September 2010.

b. Article 32 investigations are open to the public and you will ensure the Article 32 is kept
open to the public whenever possible. If either party intends to disclose or introduce classified
information in an open forum. during the Article 32. you will conduct a closure hearing as
outlined in RCM before closing the proceeding and excluding the public. To assist in
your determination under RCM 806(bJ(2), you will require both parties to submit in advance a
proposed plan for the introduction of classified information during the proceeding, including
subject areas or lines of questioning that may elicit classi?ed responses during the testimony of
witnesses. You will review the potentially classified subject matter areas in advance to
understand how and why the subject area could involve a classi?ed matter and develop closure
procedures in consultation with your security officer.

c. You will have a security of?cer assigned to you for the duration of the proceeding. up to
and including Ihe completion of your ?ndings and recommendations. The security of?cer will
assist you whenever questions arise as to the classi?cation of particular documents. proper
handling or storage of classi?ed information. or subject areas that may involve classi?ed matters.
You will consult your security of?cer when determining whether or not to close the proceeding
to the public to ensure that proper procedures are followed and classi?ed information is not
inadvertently disclosed in a public forum- The security of?cer will be present during the entire
proceeding and should be prepared to assist you if any testimony. inquiry. discussion of
evidence. or documentary evidence could result in the disclosure of classi?ed information in a
setting not approved for disclosure.

6. You will schedule the time and date of the Article 32 hearing within seven days of receiving
this memorandum. However. you will not convene the Article 32 investigation any sooner than
thirty days from the date of this memorandum. The Article 32 will take place in the Fort Meade.

IJ


SUBJECT: Special Instructions for Investigation under Article 32, UCMJ

Maryland courtroom, and thirty days of lead time is required to execute the OPLAN to ensure
proper security for the accused and other participants, establish the special infrastructure for the
hearings, and prepare to have the capability to conduct closed hearings.

7. You will complete your investigation no later than sixty days from the date of this
memorandum. The completed report will include a summarized transcript of the Article 32
investigation. Pursuant to RCM 707(c)(1), you may approve any reasonable delay of the Article
32 investigation; however, you are not authorized to grant a delay that would prevent you from
completing your investigation within sixty calendar days of the date of this memorandum.
Requests for delay beyond this time must be submitted to me for approval. All requests for
delays must be in writing and will be either approved or disapproved in writing.

8. Contact the Chief, Administrative Law Division, OSJA, MDW to coordinate with your legal
adviser- Consult your legal advisor befone the hearing and throughout the Article 3?2 process for
advice as to procedure, guidance of law applicable to the case, and proper completion of the
report. The OSJA, MDW will provide administrative support for this investigation. Contact the
Chief Paralegal to coordinate administrative support.



[1

2 Boots CARL R. COFFMAN, .l R.
1. Appointment Memo, 4 Aug 10 COL, AV
2. Additional Charges Directive. 18 Mar 11 Commanding

CF: (wowr encl)
Trial Counsel
Defense Counsel























CHARGESHEET

. NAME or ACCUSED test. First MI) 2. SSN a. GRADE DR RANK 4. PAY GRADE
MANNING Bradley . PFC E- 3
UNIT oR 5. CURRENT SERVICE
Headquarters and Headquarters Company, A
U.S. Army Garrison, Joint Base Myer~Henderson Hall
Fort Myer, Virginia 22211 2 Oct 07 4 years
PAY PER MONTH 23 NATURE or RESTHAINT or 9. IMPOSEU
accuseo
a BASIC SEAIFOREIGN DUTY c. Tom.
$1,950.00 None $1,950.00 Pro?Trial Confinement 29 May 10 -











II. CHARGES AND SPECIFICATIONS



lC. ADDITIONAL CHARGE I: VIOLATION OF THE UCMJ, ARTICLE 104.

THE SPECIFICATION: In that Private First Class Bradley E. Manning, 0.5. Army,
did, at or near Contingency Operating Station Hammer, Iraq, between on or about
1 November 2009 and on or about 27 May 2010, without Proper authority,
knowingly give intelligence to the enemy, through indirect means.

ADDITIONAL CHARGE II: VIOLATION OF THE UCMJ, ARTICLE 134.

SPECIFICATION 1: In that Private First Class Bradley E. Manning, U.S. Army.
did, at or near Contingency Operating Station Hammer, Iraq, between on or about
1 November 2009 and on or about 2? May 2010, wrongfully and wantonly cause to
be published on the internet intelligence belonging to the United States
government, having knowledge that intelligence published on the internet 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.

{See Continuation Sheeti















Ill. PREFERRAL
l1a NAHE OF ACCUSER {Last First. Mil b. GRADE t: OHGANFZATION OF ACCUSER
Leiker, Cameron SIGNATURE oF accuses 2. DATE
.- (trace: 1 MAR 2011
AFFIDAVIT: Before me, the undersigned, authorized by law to administer oaths in eases ofthis character, personally appeared the
above named accuser this r' day orig" i? 20] l, and signed the foregoing charges and Speci?cations

under oath that heishe is a person subject to the Uniform Code ofMilitary Justice and that heishe either has personal knowledge of
or has investigated the matters set forth therein and that the same are true to the best of hisfher knowledge and belief.







ASHDEN FEIN MDW, OSJA

Typed Name of Of?cer Organization 0! Of?cer
0-3 Trial Counsel
Grade Clitoral Capacity to Administer Oath

{Sea CM. 30?:?Dl - must be a commissioned officer)

-- - Sty-nature



DD FORM 458, MAY 2000 PREVIOUS I5 OBSOLETE

nu. nrcn. EXHIBIT 2?5"



?w







































































12' 3-15!!me
On 2011. the accused was Infermed of the charges against himlher and of the namets] of
The accusert known to me {See ROM 308 {See R. C. M. 303 rtnotr'?oatuon cannot be made.)
CAMERON USA
Typed Name of Immediate Command-er Organizatr'On of Immem'ate Commander
A o- 5

Signature
N. RECEIPT BY SUMHARY COURTMARTIAL CONVENING AUTHORITY
13.
The swom charges were received at hours, Emm? 2011 at HQ CMD 3N USA
DestgnoIrOn of Command or
Officer Exercising Summary Court-Marriat [See I: M. 403}

CAMERON A. LEIKER Command ing
Typed Name of Officer omotat Capaaty of Ot?oer Stormy
.12; i 5

v. REFERRAL: SERVICE OF CHARGES
14a. DESIGNATION 0F COMMAND OF CDWENING AUTHORITY b. PLACE DATE
Referred for mat to the Court-martial convened by
20? . suogecttolhe following
By Of
Command or Order
Typed Name of Of?cer afloat Capacdy of Dmcer
Grade
Srgnarure
15.
On . 2011 . I [caused to be) served a copy hereof on (each of] the above named accused.
Typed Name or Tn'a! Caunset Grade or Rank of Tn'at Counset
Srgnature
1? When an commander signs personatty. words are
2 See RC. M. 60 1(a) concerning instructions. If name, so state.
DD FORM 458 (BACK), MAY 2000

\ur
CONTINUATION SHEET, DA FORM 453, MANNING, Bradley E.,

Headquarters and Headquarters Company, U.S. Army Garrison, Joint Ease
Myer-Henderson Hall, Fort Myer, Virginia 22211

Item 10 [Cont'd}:

SPECIFICATION 2: In that Private First Class Bradley E. Manning, U.S.
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 to the national
defense, to wit: a video file named ?12 JUL 0? CZ ENGAGEMENT ZONE 30
GE Anyone.avi", 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 0.8. 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.

SPECIFICATION 3: In that Private First Class Bradley E. Manning, U.S.
Army, did, at or near Contingency Operating Station Hammer, Iraq,
between on or about 22 March 2010 and on or about 26 March 2010,
having unauthorized possession of information relating to the national
defense, to wit: more than one classified 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 U.S. 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.

SPECIFICATION 4: In that Private First Class Bradley E. Manning, U.S.
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 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.



CONTINUATION SHEET, DA FORM 458, MANNING, Bradley E.
Headquarters and Headquarters Company, 0.3. Army Garrison. Joint Base
Myer-Henderson Hall, Fort Myer, Virginia 22211



SPECIFICATION 5: In that Private First Class Bradley E. Manning, 0.3.
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 classified 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 U.S. Code Section 793{el,
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.

SPECIFICATION s: In that Private First Class Bradley s. Manning, 0.3.
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 Data Network
Exchange 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 0.8. 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.

SPECIFICATION 7: In that Private First Class Bradley E. Manning, U.S.
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 classified 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 0.8. Code Section 193(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.

'v

CONTINUATION SHEET, DA FORM 458, MANNING, Bradley E.
Headquarters and Headquarters Company, 0.5. Army Garrison, Joint Base
Myer-Henderson Hall, Fort Myer, Virginia 22211

SPECIFICATION 8: 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, or knowingly convert another, a record or thing of value of the United.States
or 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.

SPECIFICATION 9: In that Private First Class Bradley S. Manning, U.S.
Army, did, at or near Contingency Operating Station Hammer, Iraq,
between on or about 8 March 2010 and on or about 2? May 2010, having
unauthorized possession of information relating to the national
defense, to wit: more than three classified 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 cause to be communicated, delivered, or transmitted, the
said information, to a person not entitled to receive it, in violation
of 18 U.S. Code Section 793ce), 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.

SPECIFICATION 10: In that Private First Class Bradley E. Manning,
U.S. Army, did, at or near Contingency Operating Station Hammer, Iraq,
between on or about 11 April 2010 and on or about 2? May 20l0, having
unauthorized possession of information relating to the national
defense, to wit: more than five classified records relating to a
military operation in Farah Province, Afghanistan occurring on or
about 4 May 2009, with reason to believe 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 0.8. Code
Section 293{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.

luv
CONTINUATION SHEET, DA FORM 458, MANNING, Bradley

Headquarters and Headquarters Company, 0.8. Army Garrison, Joint Base
Myer-Henderson Hall, Fort Myer, Virginia 22211

SPECIFICATION 11: In that Private First Class Bradley E. Manning,
U.S. Army, did, at or near Contingency Operating Station Hammer, Iraq,
between on or about 1 November 2009 and on or about 8 January 2010,
having unauthorized possession of information relating to the national
defense, to wit: a file named PAK.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 0.8. Code
Section 783(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.

SPECIFICATION 12: In that Private First Class Bradley E. Manning,
U.S. 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
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.

SPECIFICATION 13: In that Private First Class Bradley E. Manning,
U.S. Army, did, at or near Contingency Operating Station Hammer, Iraq,
between on or about 28 March 2010 and on or about 2? 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~five classified 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 0.3. Code Section 1030(a)(1), such conduct
being prejudicial to good order and discipline in the armed forces and
being of a nature to bring discredit upon the armed farces.

\If
CONTINUATION SHEET, DA FORM 458, MANNING, Bradley E.,

Headquarters and Headquarters Company, U.S. Army Garrison, Joint Base
Myer?Henderson Hall, Fort Myer, Virginia 22211

SPECIFICATION 14: In that Private First Class Bradley E. Manning,
U.S. 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 classified 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 U.S. Code Section 1030(a}(1}, 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.

SPECIFICATION 15: In that Private First Class Bradley E. Manning,
U.S. 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 violation of 10 U.S. 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.

SPECIFICATION 16: In that Private First Class Bradley E. Manning,
U.S. Army, did, at or near Contingency Operating Station Hammer, Iraq,
between on or about 11 May 2010 and on or about 2? 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 SharePoint Exchange Server global address list 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.

Ht
CONTINUATION SHEET, DA FORM 458, MANNING, Bradley

Headquarters and Headquarters Company, U.S. Army Garrison, Joint Base
Myer-Henderson Hall, Fort Myer, Virginia 22211

ADDITIONAL CHARGE VIOLATION OF THE UCMJ, ARTICLE 92.

SPECIFICATION 1: In that Private First Class Bradley E. Manning, U.S.
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.

SPECIFICATION 2: In that Private First Class Bradley E. Manning, U.S.
Army, did, at or near Contingency Operating Station Hammer, Iraq,
between on or about 11 February 2010 and on or about 3 April 2010,
violate a lawful general regulation, to wit: paragraph
Army Regulation 25-2, dated 24 October 2007, by adding unauthorized
software to a Secret Internet Protocol Router Network computer.

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

SPECIFICATION 4: In that Private First Class Bradley E. Manning, U.S.
Army, did, at or near Contingency Operating Station Hammer, Iraq,
between on or about 11 May 2010 and on or about 27 May 2010, violate a
lawful general regulation, to wit: paragraph 4?Staii3l, Army
Regulation 25-2, dated 24 October 200?, by using an information system
in a manner other than its intended purpose.

SPECIFICATION 5: In that Private First Class Bradley E. Manning, U.S.
Army, did, 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, violate a lawful general regulation, to wit: paragraph
2-4, Army Regulation 380?5, dated 29 September 2000, by wrongfully
storing classified information.

IN THE UNITED STATES ARMY
FIRST JUDICIAL CIRCUIT

UNITED STATES

DEFENSE NOTICE UNDER
MILITARY RULE OF EVIDENCE


V.

MANNING. Bradley 13.. PFC

LLS. Army.

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

DATED 22 November 20l

- .

1. Pursuant to Military Rule of Evidence 505th)(3). PFC Manning. by and through counsel,
provides notice to the government that the defense intends to present. either through cross-
examination of the government?s witnesses or dttring the defense?s presentation, the following
evidence during the Article 32 hearing:

a. CIDNE Afghanistan Signi?cant Activity Reports (SIGACTs). The CIDNE Afghanistan
SIGACTs consist of91.731 documents covering a period from 1 January 2004 to 31 December
2009. The defense intends to discuss each individual SIGACT report that is the subject of
Speci?cation 7 ofCharge II with Vice Admiral Robert S. Harward. Speci?cally. the defense
intends to discuss Vice Admiral l-larward?s classi ?cation determination and his determination
regarding the impact on national security from having this information released publicaliy. The
defense also intends to discuss. in general. the Afghanistan SIGACT reperts that are the subject
of Specification 6 of Charge II with Vice Admiral 'i-larwat?d;

b. CLDNE Iraq The CIDNE Iraq SIGACTs consist of 391,832 documents
covering a period from I January 2004 to 3] December 2009. Again. the defense intends to
discuss each individual SIGACT report that is the subject 5 of Charge II with
Vice Admiral Robert S. Ham-ard. Speci?cally, the defense intends to discuss Vice Admiral
Ilarward?s classi?cation determination and his determination regarding the impact on national
security from having this information released publically. The defense also intends to discuss. in
general, the Iraq SIGACT reports that are the subject 4 ofCharge II with Vice
Admiral Harward;

c. Other Brie?ngs as well as the Granai Airstrilte Video and accompanying 15-6
Investigation Report. This information contains a video of an airstrike that took place on 4 May
2009 along with the resulting 15-6 investigation and numerous other brie?ngs. The airstrike
involved the dropping of 500 b and 1,0001b bombs on a suspected militant compound. The
bombing resulted in anywhere between 30 to I40 civilians being killed. The defense intends to
discuss each individual itctn listed on page 14 and 15 ofVice Admiral Harward?s classi?cation
review. Some of this information also appears to be the subject of Rear Admiral Kevin M.
Donegan's classi?cation review. Speci?cally. the defense intends to discuss Vice Admiral

HIV. arcs. EXHIBIT

Harward?s and Rear Admiral Donegan?s classi?cation detemiinations and their determination
regarding the impact on national security from having this information released publically. The
items referenced are the subject of Speci?cations l0 and of Charge

d. A diplomatic cable known as Reykjavik-13. This diplomatic cable was From the embassy
in Reykjavik detailing the ?nancial dif?culties of a privately owned Icelandic bank called
Landsbanki, which offered online savings accounts under the ?Icesave? brand. The bank was
placed into receivership by the Icelandic Financial Supervisory Authority on 7 October 2008.
The defense intends to discuss the diplomatic cable that is the subject of Speci?cation 14 of
Charge II with Mr. Patrick F. Kennedy. Specifically, the defense intends to discuss Mr.
Kennedy?s classi?cation determination and his determination regarding the impact on national
security from having this information released publically;

e. Diplomatic cable database. This database contains 251.287 documents. The contents of
the cables describe international affairs from 300 embassies dating from 1966 to 20] 0. Over
130,000 of the documents are unclassified. some 100.000 are labeled "con?dential", about
6,000 documents are classi?ed as ?secret?. and none are classi?ed as "top secret." The defense
intends to discuss each diplomatic cable that is the subject of Specification 13 ofCharge II with
Mr. Patrick F. Kennedy. Specifically, the defense intends to discuss Mr. Kennedy's
classi?cation determination and his determination regarding the impact on national security from
having this information released publically. The defense also intends to discuss the diplomatic
cables in general that are the subject of Speci?cation [2 of Charge 11 with Mr. Kennedy;

f. Apache Helicopter Video. A thirty-nine minute Apache cockpit gun-sight video depicting
a series ofair?to-ground attacks conducted by a team of two US. Anny Ari-64 Apache
helicopters in Al-Antin al-Thaniyah. in the district ofNew Baghdad in Baghdad. The attacks
took place on 12 July 2007. in the ?rst strike. 30mm cannon ?re was directed at a group of nine
men; two were war correspondents for Reuters Saeed Chmagh and Namir Noor-Elden. Eight
men were killed, including Noor-Eldeen. Chmagh was wounded. In the second airstrikc. 30mm
cannon ?re was directed at Chmagh and two other unarmed men and their unmarked van as they
were attempting to help Chamgh into the van. Two children inside the van were wounded. three
more men were killed. including Chmagh. [n a third airstrike, an Apache helicopter team ?red
three l4 Hell?re missiles to destroy a building after they had observed men enter the
building. The defense intends to discuss the Apache helicopter video that is the subject of
Speci?cation 2 of Charge II with CPT James Kolky. Speci?cally. the defense intends to discuss
CPT Kolky?s classi?cation determination and his determination regarding the impact on national
security from having this information released publically;

g. US. Army's Threat Assessment. A thirty-two page doctunent prepared by the Cyber
Counterintelligcnce Assessments Branch of the Army?s Center along with
the National Ground Intelligence Center to assess the counterintelligence threat posed to the U.S.
Army by Wikileaks. This document is the subject of Speci?cation 15 ofCharge II. The defense
intends to discuss the threat assessment with the individual who is identified as completing the
classi?cation review. Speci?cally. the defense intends to discuss the classi?cation determination
and the determination regarding the impact on national security from having this information
released publically;

h. The Guantanamo Files. This database consists of 7'79 Secret case ?les. These memoranda
contain information about each prisoner to include their background; how they were captured;
whether they are regarded as low; medium or high risk; whether they should be released or not.
The defense intends to discuss each document that is the subject of Speci?cation 9 of Charge 11
with Rear Admiral David Woods. Speci?cally, the defense intends to discuss the classi?cation
determination of Rear Admiral Woods and the determination regarding the impact on national
security from having this information released publieally. The defense also intends to discuss. in
general. the Guantanamo ?les that are the subject of Speci?cation 8 of Charge ii;

i. Government Intelligence Agency Memorandums. Speci?cation 3 of Charge 11 alleges that
between 22 March 2010 and 26 March 2010 PFC Manning unlawfully disclosed "more than one
classi?ed memorandum produced by a United States government intelligence agency.? The
defense intends to discuss each document that is the subject of Speci?cation 3 of Charge 11 with
Mr. Robert L. Roland. Speci?cally, the defense intends to discuss Mr. Roland's classi?cation
determination and his determination regarding the impact on national security from having this
information released publically.

j. Chat Log. A text log ofa computer chat session allegedly between Mr. Adrian Lamo and
PFC Manning. Although the log has no classi?cation markings. according to Mr. Robert E.
Betz, it contains national security information preperly classi?ed at the SECRET level. The
defense intends on exploring the subject matter of the test log with Mr. Beta. Speci?cally, the
defense intends to discuss Mr. Betz?s classi?cation determination and his determination
regarding the impact on national security from having this information released publically.

2. Nothing contained in this notice should be construed in any manner as a concession by PFC
Manning or his defense that the listed items are appropriately classi?ed pursuant to Executive
Order 13256 or that the disclosure of such information would be detrimental to the national

- v'io EDWARD
Civilian Defense Counsel

'4

DEPARTMENT OF THE ARMY
150TH JUDGE ADVOCATE GENERAL DETACHMENT (Lsoi
mo ALBERT c. LIEBER USAR CENTER
6901 TELEGRAPH ROAD

ALEXANDRIA, VIRGINIA 22310-3320
REPLY To

CI



ARRC-CAR-LSQ 23 November 201 I

MEMORANDUM OR Private First Class Bradley E. Manning

SUBJECT: Article 32th) Investigation

1. At 0830 on 16 December 2.01 1. in the courtroom at Fort Meade. Maryland. I will conduct an
investigation pursuant to Article 3211b). UCMJ. to investigate the facts and circtunstances
concerning the additional charges and their speci?cations preferred against you on 1 March
2011. Additional Charge I and its Speci?cation alleges aiding the enemy. in violation of Article
104. UCMJ. Additional Charge 11 and its 16 Speci?cations allege causing intelligence belonging
to the United States Government to be published on the Internet, transmitting national defense
information to a person not entitled to receive it. and stealing a record or thing of value of the
United States. in violation of Article 134. UCMJ. Additional Charge and its 5 Speci?cations
allege failure to obey a lawful general regulation. in violation of Article 92. UCMJ.

2. You have the right to be present during the entire investigation. Additionally. you have the
right to be represented at all times during the investigation by legally quali?ed counsel. Counsel
may be a civilian lawyer of your own choice. provided at no expense to the United States: a
quali?ed military lawyer of your own selection. if reasonably available; or a quali?ed military
counsel detailed by the Trial Defense Service. There is no cost for military counsel. You also
have the right to waive representation by counsel. 1 have been informed that you are represented
by MAJ Kemkes and Bouchard as military counsel. and Mr. Coombs as civilian counsel.
Should that not be correct. please advise me of your representation by 1700 Eastern time. 2
December 201 1. As I understand you are currently in pretrial con?nement and represented by
counsel. 1 am providing this memorandum to your counsel for delivery to you.

3. Please submit any request for continuance from the above date and time set for the
investigation to me no later than 1700 Eastern time. 2 December 201 1. With any request for
continuance. your counsel must provide detailed justi?cation for the requested delay.

4. You will be provided with a list of witnesses I intend to have present during this investigation.
and the evidence I intend on considering. no later than 7 December 201 l.

5. As the investigating of?cer. I will try to arrange for the appearance of any witnesses you want
to testify at the hearing. Please send me the names and addresses of such witnesses by 1700
Eastern time. 9 December 201 1. If. at a later time. you identify additional witnesses. please
inform me of their names and contact information through which they can be reached. including
addresses and phone numbers.

m. UFCR. EXHIBIT


SUBJECT: Amide 32(1))

6. You may contact me by; e-mail at?

7. for this memorandum is the undersigned.





.ii

PAUL R. ALMANZA
LTC. JA. USAR
Investigating Of?cer

CF:

MAJ Matthew Kemk
Paul Bouchar
CPT Ashden Fein {at
r. David C00:an (at



AFZB-JA-TDS 28 November EDI 1

MEMORANDUM FOR Article 32 Investigating Of?cer, LTC Paul Alntanza, 150th Judge
Advocate General Detachment, Legal Support Organization, MG Albert C. Licber USAR
Center, 6901 Telegraph Road. Alexandria, Virginia 22310
SUBJECT: Article 32(b) Investigating Of?cer Noti?cation - United States v. PFC Bradlev E.
Manning
1. I acknowledge receipt of your noti?cation memorandum dated 23 November Bill 1.
2. I respectfully request to be represented by the following counsel:

a. Mr. David E. Coombs: Civilian Counsel

b. MAJ Matthew J. Kernkes: Detailed Defense Counsel

e. Paul R. Bouehard: Detailed Defense Counsel

3. I understand that while my military attorneys will be furnished at no expense to me, the
Government will not pay for the costs ofmy civilian attorney.

4. I understand that Mr. Coombs has already provided you with a written request for evidence,

It is my understanding that he will also provide you with a written request for witneSSes by your
required timeline.

BRADLEY E. MANNING

PFC, UK. rmy ..






tuv. urea. EXHIBIT 2?

IN THE UNITED STATES ARMY
FIRST JUDICIAL CIRCUIT

UNITED STATES
SEALED DEFENSE MOTION

FOR A CLOSED HEARING
UNDER R.C.M. 405(h)(3}

V.

MANNING. Bradley F..- PFC

U.S. Army,

Headquarters and Headquarters Company, US.
Amiy Garrison. Joint Base Myer-Henderson Hall.
Fort Myer, VA 2221

DATED: 28 November 201 1

RELIEE souoHT

1. PFC Bradley E. Manning. by and through counsel, under a request that this motion be sealed
pursuant to R.C.M. 1 103A, moves the Investigating Officer, pursuant to R.C.M to
direct the Government to request a closed hearing anytime it anticipates referencing the speci?ed
information in this motion, whether through the questioning of a witness or in argument.
Additionally, the Defense requests that the Investigating Of?cer order the Govemment to
instruct its witnesses not to reference the speci?ed conduct during any open hearing.

BURDEN 0F PERSUASION AND BURDEN OFPROOF

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. PFC Manning is charged with five speci?cations of violating a lawful general regulation, one
speci?cation of aiding the enemy. one specification of disorders and neglects to the prejudice of
good order and discipline and service discrediting. eight speci?cations ot'cornmunicating
classi?ed information, five speci?cations of stealing or knowingly converting govemment
property, and two specifications of knowingly exceeding authorized access to a government
computer. in violation of Articles 92, 104, and 134. Uniform Code of Military Justice (UCMJ)
10 use. 892, 904, 934 (2010').

4. Through the production of unclassi?ed discovery and a classi?ed government brie?ng, the
Defense was provided with information regarding the following:



a. Disloyal Statements: PFC Manning allegedly stated to SPC Jihrleah Showman, and on a
separate occasion to W2 Joshua Ehresman, that he had no loyalty to the United States and that

m. arcs. EXHIBIT

?the ?ag on his shoulder meant nothing to him.? SPC Showman alleges that during a counseling
session, PFC Manning told her that he had no loyalty to the United States, that the American
Flag meant nothing to him, and that he had to scrub the internet to ensure he would get a security
clearance. SPC Showman does not recall the exact time period when these statements were
made, although she indicated that she believed that they occurred in March or April of 2009 and
that she raised this issue With then MSG Paul Adkins. CW2 Ehresman alleges that PFC
Manning made similar comments to him in the February or March of 201 0 time?'ame.
According to CW2 Ehresnian, PFC Manning stated that ?the US. Flag meant nothing to him and
that he had no loyalties to our country.? CW2 Ehresman stated that at the time he was not
concerned for PFC Manning's patriotism but that he was concerned PFC Manning may be
suffering from depression or other anger issues.

is. Pretrial Con?nement Admission: On 18 My 2011, Special Agent Troy Bettencourt
interviewed Inmate Christopher R. Whit?eld at the Joint Regional Con?nement Facility (JRCF)
at Fort Leavenworth. According to Inmate Whit?eld, PFC Manning confessed to him that he
(PFC Manning) had sold information to Wikilealrs. Inmate Whit?eld alleged that he had come
into contact with PFC Manning through his role as representative of the Inmate Advisory
Council (IAC). Inmate Whit?eld. as a post-trial inmate, should never have been allowed to
associate with pretrial detainees. However, he was apparently mistakenly taken to the pretrial
con?nees section to discuss potential IAC issues with pretrial detainees. Inmate Whit?eld told
SA Bettencourt that when he was taken to the pretrial section, he explained the purpose of his
visit and asked PFC Manning who the JRCF. PFC Manning allegedly
responded with, sold information to Wikileaks." Shortly after this alleged statement, the
guards realized that Inmate Whit?eld should not have been in the pretrial area as the pretrial
detainees had their own representative. The guards then took Inmate Whit?eld out of the
pretrial area.

c. Advanced Individual Training Mi social?neg: While at AIT, PFC Manning allegedly
posted a video to YouTube regarding Sensitive Compartmented Information Facilities (SCIFs)
located on Fort Huachuca, Arizona. PFC Manning's video allegedly referenced his access to
classi?ed material. Based upon this conduct, PFC Manning was counseled on the unauthorized
disclosure of information and was required to provide training for the unit regarding operational
Security.

d. Basic Course Misconduct: 0n 1 November 2007, while in a medical hold status, PFC
Manning allegedly stabbed another trainee in the stomach several times with a pencil.
According to SPC Roderick Handy, the other trainee was mocking PFC Manning and a verbal
altercation turned physical when PFC Manning charged the other trainee. When PFC Manning
charged the other trainee, he allegedly struck the trainee in the stomach with his head and
attempted to stab him with a dull pencil several times. The alleged assault of the trainee by PF
Manning did not result in any injuries as the pencil did not break the skin. The situation was
resolved by other trainees stepping in to separate the soldiers. The alleged incident was never
reported and therefore never documented.



e. Classi?ed Government Brie?ng: On 3 November 2011, the Government provided a
classified brie?ng to the Defense team regarding the classi?ed discovery and other aspects of the

case. As part of that briefing. the Government indicated that it had computer forensic
information that supported a determination that various terrorist groups. to include Al-Qaeda and
Hizb?L Islami Gulbuddin had obtained copies of the information released by Wikileaks.





5. The Defense does not request any witnesses be produced for this motion. The Defense
respectfully requests the Investigating Of?cer to consider the following evidence in support of
the Defense?s motion.

a. DA Form 2823, SPC Jihrleah W. Showman. 0001371 1-14

h. DA Form 2823. CW2 Joshua D. Ehresman, 00022168-69

c. Agent Investigative Report. SA Troy M. Bettencourt. 00045916.
d. DA Form 2323, SPC Roderick Lewis Handy. 00021929-32.

e. Interview Memorandum for Record. SF (Retired) Brian Madrid, 000l3768-69.

LEGAL AUTHORITY AND ARGUMENT

6. Generally. an Article 32 hearing should remain open to the public whenever possible. R.C.M.
However. access by spectators to all or part of a proceeding may be restricted or
foreclosed in the discretion of the investigating Of?cer. id. Closure of the hearing is appropriate
whenever ?an overriding interest exists that outweighs the value of an open investigation.? Id?
see discussion.

7. The discussion to the rule provides a non-exhaustive list of examples of "overriding
interests.? See generally, ABC, Inc, v. Powell. 47 MJ. 363 (C.A.A.F. (closure may be
appropriate on a case by case. witness by witness basis when the cited reasons are to maintain
integrity of the military justice system, prevent dissemination ofevidence that might not be
admissible at trial. or in order to prevent contamination of the potential pool of panel members}.
Additionally. the analysis to R.C.M. refers to R.C.M. 306(b)(2} [governing closure of
the trial) for other examples of why a hearing may be closed. Both the analysis and the
discussion to the rule support a determination that a hearing may be closed when it seeks to
prevent the publication of information that may improperly in?uence potential panel members.

3. Within the Army. the test for when a hearing may be closed is discussed in United States v.
Anderson. 46 MJ. 728 1997) (adopting the ?stringent test? for clasure of court-
martial proceedings citing Press-?Enterprise Co. v. Superior Court. 478 1.1.3. 1 (1986)]; ABC, Inc.
v. Powell. 47 MJ. 363 (C.A.A.F. 1997]). Under the Anderson test. a hearing may be closed to
the public provided that following test is met:

a. The party seeking closure must advance an overriding interest that is likely to be
prejudiced;

b. The closure must be narrowly tailored to protect that interest;
c. The trial court must consider reasonable alternatives to closure; and
d. The trial court must make adequate ?ndings supporting the closure to aid in review.

9. In the instant case. the defense requests that the Investigating Ollicer close the hearing to
protect PFC. Manning?s right to a fair trial. The admissibility of the information detailed above
at trial is yet to be determined. The Defense intends to move the trial court to exclude the above
referenced information as either being irrelevant. unfairly prejudicial. or as being inadmissible
crimes. wrongs. or acts to prove character in order to show action in conformity therewith. See
M.R.E. 401. 403. and 404(b).

10. If the above 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. PFC Manning is entitled to a trial before an unbiased panel that has no
preconceived opinions about him. If the Government is permitted to adduce this evidence at the
Article 32 hearing, a trial judge and PFC Manning's Defense will be unfairly placed in the
position of having to '?un-ring a bell? with the members and fashion an appropriate instruction
should the evidence be deemed as inadmissible. The Defense and military judge should not be
placed in this position when closing the hearing and instructing the Government not to elicit or
reference this information in an open forum can avoid such consequences.

1 l. The hearing would only have to be closed in very limited circumstances that is, if and
when the Government attempts to elicit the above information. At all other times. the hearing
may remain open. As such. the closure can be narrowly tailored to protect the interest of
ensuring that inflammatory and likely inadmissible evidence is not publicly disclosed in advance
oftrial. No other alternative. short of closure of the entire Article 32 hearing, is available in
order to protect the overriding interest of ensuring a fair trial for PFC Manning.

12. The Investigating Officer should find that closure of the hearing whenever the Government
references the evidence specified in this motion is the only available remedy. The Investigation
Of?cer should determine that closure is required in order to protect PFC Manning?s ability to
obtain a fair trial; that closure of the hearing may be narrowly tailored to protect that interest; and
that there is no other available alternative short of closure that will protect this interest.

CONCLUSION

13. Based on the above. the Defense requests that the Investigating Officer order the
Government to request a closure of the hearing whenever it anticipates referencing the above
information either through the questioning of a witness or through argument. Additionally. the

Defense requests that the Investigating Of?cer order the Government to instruct its witnesses not
to reference the above referenced information during any open session of the Article 32 hearing
without ?rst alerting the Investigating Of?cer. The witness should simply state that the question
would require a response that must be made during a closed hearing. At that time, the hearing
should be closed to the public and the witness permitted to respond. Once the witness has
provided their answer, the hearing can again be opened to the public.



DAVID EDWARD COOMBS
Civilian Defense Counsel

UNITED STATES
DEFENSE REQUEST FOR

v. PRODUCTION OF EVIDENCE

MANNING, Bradley 13., PFC

US. Army,

I-Ieadquarters and Headquarters Company, ILS.
Army Garrison. Joint Base Myer?Henderson Hall,
Fort Myer, VA 222l

DATED: 22 November 201 I

?uv?wv'v??v

1. On behalf Bradley E. Manning, his civilian counsel, David E. Coornbs. requests the
production of the below listed evidence. The defense also requests that the Investigating Of?cer,
LTC Paul Almanza, include the below listed evidence in his Article 32 notification letter for the

following reasons:

a. In order to inquire into the truth of the matter alleged in the charges, consider the form of
the charges. and assist the Investigating Of?cer in making recommendations as to disposition of
the charges. See Rule for Courts-Martial

b. In order to serve as a means of discovery for the defense. The defense has repeatedly
requested the below discovery in this case, but the government has consistently responded with a
blanket denial of the defense request. See R.C.M. 405(a} Discussion (stating the ?investigation
also serves as a means of discovery" for the defense); R.C.M. 405(g)(l )(B)(stating ?evidence,
including documents or physical evidence, which is under the control ofthe Government and
which is relevant to the investigation and not cumulative, shall he produced. .

e. In order to present matters in mitigation of the charged offenses. R.C.M. 405(1) (stating an
accused has the right to present evidence in defense. mitigation. and extenuation); Article 32(b),
Uniform Code of Military Justice (UCMJ) (stating an accused may ?present anything he may
desire in his own behalf, either in defense or mitigation, and the investigation officer shall
examine available witnesses requested. United States v. Garcia, 59 MJ. 447, 451
2004) (ruling that an accused has the right to present anything he may desire in his own behalf at
an Article 32 in defense or mitigation);

2. On 18 January 20] l, the defense was notified that PFC Manning, at the direction of CWO4
James Averhart, was placed in suicide risk. This decision was made over the recommendations
of Capt. William Homer and the defense appointed expert Capt. Kevin Moore. When PFC
Manning was being ordered to Surrender his clothes as part of the unnecessary suicide risk, the
Brig made the decision to videotape this event along with an interrogation of PFC Manning by
CWO4 Averhart and others. On It) January 201 1, the defense ?led a preservation ofevidence
request with the govenurtent and a request for production of the video. The defense believes the
video will support PFC Manning?s claim of unlawful pretrial punishment. The govcrrunent has
yet to respond to the defense request. See R.C.M. 405(e?) Discussion (stating that inquiry into

HIV. UFCR. EXHIBIT 30

other issues such as legality of searches or the admissibility of evidence is proper by an Article
32 Investigating Officer].

3. The defense has previously requested a copy of all adverse administrative or UCMJ action, all
supporting documentation. and any rebuttal materials to such action based upon the 15-6
investigation conducted by LTG Robert Caslen Jr. or any other governmental investigation,
with regards to any individual that was the subject ol?such an adverse action in relation to the
alleged leak of classi?ed information in this case. The previous requests included, but was not
limited to, the following individuals: COL. David M. Miller, COL Paul R. Walter, LTC Brian
D. Kerns, LTC Rodney Gar?eld, LTC Randolph Wardle. MAJ Eric Davis, MAJ Erie Graham,
MAJ Jason A. Morrow, MAJ Clifford D. Clausen, MAJ Elijah A Dreher, PT Matthew W.
Freeburg, 136 Eric H. Usbeck, CPT Thomas M. Cherepko, CPT Steven J. Lim, CPT Barclay D.
Keay, Casey Martin, Tanya M. Gaab, 1LT Elizabeth A. Fields. W2 Joshua D.
Ehresman, CW2 Chad Eastep, CW2 Alfred Lyons, Kyle J. Balonek, SFC Paul D. Adkins,
SSG Lawrence W. Mitchell, SGT Daniel W. Padgett, and PFC irleah W. Showman. The
government has so far only provided information in relation to SFC Paul D. Adkins.

4. The defense speci?cally requested an Encase forensic image of each computer from the
Tactical Sensitive Compartmented Information Facility and the Tactical Operations
Center of Headquarters and Headquarter Company 2nd Brigade Combat Team
(BCTJ, lOth Mountain Division, Forward Operating Base (FOB) Hammer, Iraq. The defense has
previously requested these items in discovery and filed a presewation ofevidenee request with
the government. An inspection of all seized governmental computers from the T-SCIF and TOC
would allow the defenSe to provide evidence that it was common for soldiers to add unauthorized
computer programs to include, but not limited to: {a full featured Internet Relay Chat
client for Windows that can he used to communicate, share, play or work with others on IRC
networks); Wget (a web crawler program designed for robustness over slow or unstable network
connections); GEOTRANS an application program which allows a user to easily convert
geOgraphic coordinates among a wide variety ofcoordinate systems, map projections and
datums); and Grid Extractor {a binary executable capable of extracting MGRS grids from
multiple free text documents and importing them into a Microsoft Excel spreadsheet) to their
computers. The government has used this alleged conduct to charge PFC Manning with two
Speci?cations of a violation of Article 92.

5. The defense has previously requested any Brady or Jencks material in the government?s
possession. Brody v. Maryland, 373 US. 33 (1963) (holding that due process requires the
govenimcnt to turn over exculpatory evidence in its possession): Jena-?rs v. United States, 353
US. 65? (1957) (holding that, in a criminal prosecution, the government may not withhold
documents relied upon by government witnesses, even where disclosure of those documents
might damage national security matters). Under military law, the trial counsel has an af?rmative
obligation to seek out requested evidence by the defense that is in the possession ofthe
government even il?that evidence is not already in the immediate possession of the trial counsel.
United Slates v, Williams, 50 MJ. 436, 441 1999); United States v. Baton, 863 F.2d
1032, I036 Cir. was); United States v, Brooks, sea F.2d 1500, 1503 (1992) {the government
is considered to have possession of information that is in the control of agencies that are ?closely
aligned with the prosecution"). The defense speci?cally requests the below listed inlormation

from the government that is in control of agencies that are closely aligned with this prosecution.
The trial counsel has responded with a blanket denial of the requested information despite the
fact that this information clearly impacts not only on the form and proper disposition of the
charges- but also represents clear Brady and Jencks material:

a. White House: Mr. Russell Travers, National Security Staffs Senior Advisor for
Information Access and Security Policy was tasked to lead a comprehensive effort to review the
alleged leaks in this case. He has completed a report detailing the rather benign nature ot?the
leaks and the lack of any real damage to national security. The defense requests a copy of this
review and any assessment given. or discussions concerning, the WikiLeaks disclosures by any
member of the government to President Barack H. Obama. The defense requests any c-mail.
report, assessment. directive, or discussion by President Obama to the Department of Defense
conceming this case in order to determine the presence of unlawful command influence. See
R.C.M. 405te). Additionally- defcnse requests any e-mail, report, assessment, directive, or
discussion by President Obama to the Department of State or Department of Justice concerning

this case;

b. Central Intelligence Agency: The Original Classi?cation Authority?s classification
review was completed by Mr. Robert L. Roland. His classi?cation review indicated that a
disclosure of the charged information could be expected to cause damage or serious damage to
national security. This determination is at odds with the damage assessment completed by the
WikiLcaks Task Force and by the Information Review Task Force. Additionally. this
determination is at odds with the Of?ce of Security's review at the direction of former Director
Leon Panetta. As such, Mr. Roland should not be permitted to espouse an opinion which is
inconsistent with the damage assessments conducted by the government. Brad)? Maryland,
373 US. 83 (1963}; Jencks v. United States, 353 U.S. 65? (1957);

c. Department of Defense: Early on in the investigation. the Department of Defense reached
out for assistance from the Department of State, the Federal Bureau of Investigation, the
Defense Intelligence Agency, the Of?ce of the National Counterintelligence Executive and the
Central Intelligence Agency. The defense is entitled to receive any forensic results and
investigative reports by any of the cooperating agencies in this investigation. toured States v.
Williams, 50 MJ. 4313. 441 (C.A.A.F. 1999); [failed States v. Bryon. 368 F.2d 1032, 1036 (91"
Cir. Unr'tedStot?es v. Brooks, 966 F.2d 1500. 1503 (1993]; Article 46. Uniform Code of
Military Justice Finally. former Secretary of Defense Robert M. Gates on 29 July 2010
directed the Defense intelligence Agency to lead a comprehensive review of the documents
allegedly given to WikiLeaks and to coordinate under the Information Review Task Force
formerly TF 725} to conduct a complete damage review. The results of this damage
review undercut the testimony of each of the representatives from the OCA for the charged
documents in this case. Speci?cally, the damage assessment concluded that all of the
information allegedly leaked was either dated. represented low?level opinions. or was already
eonrmonly understood and known due to previous public disclosures.

d. Department ofJustiee: The defense requests any and all documentation related to the
Department of Justice investigation into the alleged leaks by Wikilsealts as referenced by
Attorney General of the United States Eric H. Holder, to include any grand jury testimony and

any information relating to any 18 U.S.C. 2703M) order or any search warrant by the
government of Twitter, aeebook. Google or any other social media site. Bit-adv v. ridatjtfand.
37?3 US. 33 (1963); Jencks v. 353 US. 657 (1957);

e. Department of State: The Department of State formed a task force of over 120 individuals
to review each released diplomatic cable. The task force conducted a damage assessment of the
leaked cables and concluded that the information leaked either represented low-level opinions or
was already commonly known due to previous public disclosures. According to published
reports in multiple new agencies. including the Associated Press. The Huf?ngton Post. and
Reuters, internal US. government reviews by the Department of Defense and the Department of
State have determined that the leak of diplomatic cables caused only limited damage to US.
interests abroad; despite the Obama administration?s public statements to the contrary.
congressional of?cial briefed on the reviews stated that the administration felt compelled to say
publicly that the revelations had seriously damaged American interests in order to bolster legal
efforts to shut down the WikiLeaks website and bring charges against the leakers. According to
the published account ?We were told (the impact of WiltiLeatrs revelations) was embarrassing
but not damaging.? said the of?cial. who attended a brie?ng given in late 20 I) by State
Department of?cials. National security officials familiar with the damage assessments being
conducted by defense and intelligence agencies told Reuters the reviews so far have shown
?pockets? of short-term damage; some of it potentially harmful.? See generally,
huf?ngtonpost. comfztil 1101f 0778.11tml). This determination
is at odds with the classi?cation review conducted by the OCA. Mr. Patrick Kennedy should not
be permitted to espouse an opinion which is inconsistent with the damage assessments conducted
by the government. Brady v. Maryland; 373 .S. 33 [1963);Jenei1r v. United States, 353 US.

657

6. The de?ense has requested a copy of the Damage Assessment of Compromised Information
that is required to be submitted to the Special Security Of?cer (380) under
once an SCI Security Of?cial determines that a security violation has occurred. The damage
assessment is supposed to contain the date of the assessment; the name and of?ce symbol
conducting the assessment; subjeetftitle, date; number; originator and original classi?cation of
document; whether the document can be declassi?ed or downgraded; either in whole or in part;
justi?cation for classi?cation the speci?c statements in the document which are classi?ed. the
basis for classi?cation. and a complete bibliography of all classi?ed source materials used itt
preparation of the document); whether the classi?ed information identi?ed is accurate; whether
the classi?ed information identi?ed was the subject of any of?cial release; and whether the
information identi?ed as classi?ed can be edited for the purpose of prosecution. The
govemment has not yet provided this infomtation to the defense. This information should be
ordered produced for the consideration of the Investigating Of?cer at the Article 32.

7. The defense requested a copy of the ?nal security violation investigation report submitted to
the 380 Defense Intelligence Agency under The report is used to
assess intent, location of the incident; rislt of compromise, sensitivity of information. and
mitigating factors in arriving at a ?nal analysis of the incident. The government has not yet
provided this information to the defense. This information should be ordered produced for the
consideration of the Investigating Officer at the Article 32.

8. The defense has previously requested any known evidence tending to diminish credibility of
any government witness including, but not limited to, prior convictions under Military Rule of
Evidence 609, evidence of other character, conduct, or bias hearing on witness
credibility under M.R.E. 608. Speci?cally, the defense requests the name and contact
information for any law enforcement agent working with Mr. Adrian A. Lamo. See Brady v.
Maryland, 373 1.1.8. 83 (1963); limited States v. Agars, 42? US 97 {1976).

9. The defense has previously requested a copy of all audio and video surveillance of the
visitation booths at Quantico, Virginia when individuals, including defense team members, met
with PFC Mamring. The defense also requests a copy of all audio and video surveillance of the
visitation rooms at the Joint Regional Correctional Facility at Fort Leavenworth, Kansas when
individuals, including defense team members, met with PFC Manning. The government has only
provided a partial account of the audio and video surveillance in its possession.

- "g

DA EDWARD COOMBS
Civilian Defense Counsel

DEPARTM EMT OF TH AR MY
US. ARMY HILITAFW DISTRICT OF WASHINGTON
210 A STREET
FORT LESLEY J. MOHAIR, DC 2D319-SD13

TD
ATTENTION OF



30 November 2011

MEMORANDUM FOR LTC Paul Almanza, 150th Judge Advocate General Detachment, Legal
Support Organization, MG Albert C. Lieber, USAR Center, 6901 Telegraph Road, Alexandria,
VA 22310

SUBJECT: Response to Defense Request for Production of Evidence, 22 November 2011
United States v. PFC Bradlev Manning

1. The below responses to the defense production request account for the ongoing national
security concerns of this case, the ongoing law enforcement investigationls), and comply with
the limitations of applicable Executive Orders. The United States acknowledges its requirements
under Article 46, UCMJ, the Rules for Courts-Martial, and relevant case law.

2. Discovery Response-

a. The alleged video of PFC Manning being ordered to surrender his clothes as part of
suicide risk and of an alleged interrogation of PFC Manning by CWO4 Averhart and others. See

Production Request. paragraph 2.

RESPONSE: The United States will provide all matters requested that are in its
possession no later than 2 December 2011.

b. A copy of all adverse administrative or UCMJ actions, all supporting documentation. and
any rebuttal materials to such action based upon the 15-6 investigation conducted by LTG Robert
L. Caslen r. See Production Request, paragraph 3.

RESPONSE: The United States has provided all matters requested that are in its
possession.

c. An Encase forensic image of each computer from the Tactical Sensitive Compartmented
Information Facility and the Tactical Operations Center (TOC) of Headquarters and
Headquarter Company 2nd Brigade Combat Team (BCT), 10th Mountain Division.
Forward Operating Base (FOB) Hammer, Iraq. See Production Request, paragraph 4.

RESPONSE: The United States has provided to the defense an Encase forensic image of
all electronic storage devices, including hard drives, examined by law enforcement that were
included in the forensic reports. Additionally, the United States is still actively working to
preserve related computer hard drives based on defense?s preservation request dated 21

September 201 1.

HIV. arcs. EXHIBIT 3!


SUBJECT: Response to Defense Request for Production of Evidence. 22 November 201 1

United States v. PFC Bradlev Mannine

d. Any Brady or Jencks material in the possession of the White House. speci?cally an
alleged report completed by Mr. Russell Travers. See Production Request. paragraph 5.

RESPONSE: The United States presently has no knowledge of any Brody or Jerickr
material in the possession of any member of the White House. The United States will fumish
said records to the defense should it become aware of such records. The United States has no
knowledge of the alleged report completed by Mr. Russell Travers. The United States will make
a determination whether to provide the information if and when it becomes aware of such
records.

c. Any Brody or material in the possession of the Central Intelligence Agency. See
Production Request, paragraph 5.

RESPONSE: The United States presently has no knowledge of any Brady or Jeneks
material in the possession of any employee of the Central Intelligence Agency. The United
States will furnish said records to the defense should it become aware of such records. The
United States provided the applicable classi?cation review completed by Mr. Robert Roland, as
cited by the defense. The United States does not presently have the authority to disclose damage
assessments. if any, cited by the defense and will make a determination whether to provide the
information if and when it becomes available.

f. Any Brady or .fenckt material in the possession of the Department of Defense, including
any forensic results and investigative reports by the Department of Defense. See Production
Request. paragraph 5.

RESPONSE: The United States presently has no knowledge of any Brody or Jencks
material in the possession of any employee of the Department of Defense. The United States
will furnish said records to the defense should it become aware of such records. The United
States has provided all forensic results and investigative reports requested that are in its
possession and that the United States has authority to disclose. The United States understands its
continuing obligation to provide information reaponsive to this request. The United States does
not presently have the authority to disclose damage assessments, if any. cited by the defense and
will make a determination whether to provide the information if and when it becomes available.

g. Any Brady or fencer material in the possession of the Department of Justice, specifically
any and all documentation related to the Department of Justice investigation into the alleged
leaks by WikiLeaks as referenced by Attorney General of the United States Eric H. Holder. to
include any grand jury testimony or any search warrant of Twitter. Facebook. Google, or any
other social media site. See Production Request, paragraph 5.

RESPONSE: The United States presently has no knowledge of any Brady or fender
material from the Department of Justice, to include any grand jury testimony and search
warrants. The United States will furnish said records to the defense should it become aware of
such records.

IJ

ANJA-CL
SUBJECT: Response to Defense Request for Production of Evidence, 2'2 November EDI I

United States v. PFC Bradley Manning

it. Any Brady or Jericch material in the possession of the Department of State. See
Production Request. paragraph 5.

RESPONSE: The United States presently has no knowledge of any Brady or Jenr?ks
material from the Department of State. The United States will furnish said records to the defense
should it become aware of such records. The United States has provided the applicable
classification review completed by Mr. Patrick Kennedy, as cited by the defense. The United
States does not presently have the authority to disclose damage assessments. if any, cited by the
defense and will make a determination whether to provide the information if and when it

becomes available.

i. A copy of the Damage Assessment of Compromised Information that is required to be
submitted to the Special Security officer (880) under once an SCI Security
Of?cial determinates that a security violation has occurred. The government has not yet
provided this information to the defense. See Production Request. paragraph 6.

RESPONSE: The regulation cited by the defense only applies to a compromise of
sensitive compartmented information (SCI). and there is currently no evidence supporting a
compromise of SCI. The United States provided the completed investigation required under
Army Regulation 380-5, for an alleged compromise of classi?ed information.

j. A copy of the ?nal security violation investigation report submitted to the 580
under The government has not yet provided this information to the defense.

See Production Request, paragraph 7.

RESPONSE: The regulation cited by the defense only applies to a compromise of
sensitive eompartmented information (SCI), and there is currently no evidence supporting a
compromise of SCI. The United States provided the completed investigation required under
Army Regulation 330-5. for an alleged compromise of classi?ed information.

it. Any known evidence tending to diminish credibility of any govemment witness. See
Production Request, paragraph 3.

RESPONSE: The United States has provided all matters requested that are in its
possession and that the United States has authority to disclose. The United States understands its
continuing obligation to provide information responsive to this request.

I. The name and contact information for any law enforcement agent working with Mr.
Adrian A. Lamo. See Production Request. paragraph 8.

RESPONSE: This information is available at CCIU. Contact SAC Kenneth King at
this information.


SUBJECT: Response to Defense Request for Production of Evidence, 22 November 2011 -

United States v. PFC Bradlev Manning

m. A cop},r of all audio and video surveillance of the visitation booths at Quantico, Virginia
when individuals, including defense team members, met with PFC Manning, as well as a cop},r of
all audio and video surveillance of the visitation rooms at the Joint Regional Coweetional
Facility at Fort Leavenworth, Kansas when individuals, including defense team members. met
with PFC Manning. See Production Request, paragraph 9.

RESPONSE: The United States has provided matters responsive to this request and will
provide all remaining matters in its possession no later than 2 December 201 l. The United
States understands its continuing obligation to provide information responsive to this request.

3. The point of contact of this memorandum is the undersigned.





SHDEN FEIN
CPT, 1A
Trial Counsel

CF:
Defense Counsel

UNITED STATES
DEFENSE REQUEST TO
V- COMPEL PRODUCTION
OF EVIDENCE

MANNING, Bradley PFC
US. Army,
Headquarters and Headquarters Company, US.

Army Garrison, Joint Base Myer-Henderson Hall,
Fort Myer, VA 2221

DATED: 1 December 20]]



I. INTRODUCTION

1. In accordance with the Rules for Courts-Martial 405(flt'10) and (glU Manual
for Courts~Manial (MOM), United States. 2008; Article 46, Uniform Code of Military Justice;
and the Fifth and Sixth Amendments to the United States Constitution. defense counsel in the
above entitled case respectfully request that the Investigating Of?cer compel production of
evidence.

11. BACKGROUND

2. PFC Bradley Manning is charged with various offenses under Article 92 and Article 134 of
the UCMJ. The offenses deal with the incorporation, under Article 134, of the Espionage Statute
18 U.S.C. 793(c). Public Money or Property Statute 18 U.S.C. 641. and Computer Fraud
Statute 18 U.S.C. 1030(a)(1). The original charges were preferred on 5 July 2010. Those
charges were dismissed by the convening authority on 18 March 201 l. The current charges were
preferred on 1 March 2011.

3. On 22 November 201 I. the defense submitted a request for production of evidence at the
Article 32 hearing under R.C.M. The government responded to the defense
request for production of evidence on 30 November 20] 1.

DISCUSSION

4. Under RUM. 405 and 701, the defense may request materials that are within the possession.
custodyu or control of military authorities. The government is obligated by law to turn over
evidence in its possession, as well as to retrieve from other government agencies and entities
outside of their immediate office relevant evidence upon a defense request. United States v.
Williams._ 50 MJ. 436 (.C.A.A.F. 1999}. This motion renews the defenses request for the
previously mentioned items in the Defense Request For Production Of Evidence.

5. The standard set out in R.C.M. 405 and R.C.M. 7?01 requires the government to turn over
items that are within the ?govermnent?s control." This requirement means that the trial counsel.



f"


JIL-

upon defense request, has an af?rmative obligation to seek out requested evidence that is in the
possession of the government even if that evidence is not already in its immediate possession.

Id. at 441. The ?prosecutor will be deemed to have knowledge of and access to anything in the
possession, custody, or control of any federal agency participating in the same investigation of
the defendant.? United States v. Bryan, 868 F.2d 1032, 1036 (9th Cir. 1989); Williams, 50 MJ. at
441. Furthermore, R.C.M. 405(g)(1)(B) and 703(a) establishes the standard for discovery in
military courts: the prosecution and defense ?shall have equal opportunity to obtain witnesses
and evidence." See Article 46, UCMJ.

6. In the instant case, the defense requested the production of evidence at the Article 32 hearing.
Instead of responding to the defense request as envisioned under R.C.M. the
government simply treated the request as another request for discovery. Consistent with its
previous responses to discovery requests, the government provided one of the following
responses: a general denial; a statement that it had already provided all information in its
possession; or a statement that it was either unaware of any information or did not presently
have the authority to disclose the requested information.

7. To ensure that R.C.M. 405 and 703 will have meaning at trial, ?[e]ach party shall have
adequate Opportunity to prepare its case and equal opportunity to interview witnesses and inspect
evidence.? R.C.M. 701(e). The accused is entitled to inspect both exculpatory and inculpatory
evidence. Brady v. Maryland, 373 83 (1963); United States v. Kern, 22 MJ. 49, 51
(C.M.A. 1936). Construing the due process clause, the Supreme Court in Brady v. Maryland
established a duty to disclose evidence favorable to the defense: ?the suppression by the
prosecution of evidence favorable to an accused upon request violates due process where the
evidence is material, either to guilt or punishment, irrespective of the good faith or bad faith of
the prosecutor." Brady v. Maryland, 373 U.S. 83, 8? (1963 As the numerous cases deciding
Brady v. Maryland claims indicate, ?Tavomble? is not the same as evidence that proves the
defendant to be totally innocent or establishes an unshakable alibi. Anything that tends to assist
the defense, cast doubt on the government's case, or impact on a potential punishment is
?evidence favorable to an accused. See generaliy, Army Regulation 27-26, paragraph
United States v. Kinzer, 39 MJ. 559, 562 (A.C.M.R. 1994); United States v. Adens, 56 MJ. 724
(A.C.C.A. 2002). The defense has requested the following information be produced at the
Article 32 hearing:

a. The video of PFC Manning being ordered to surrender his clothing at the direction of
CWO4 James Averhart and his subsequent interrogation on 18 January 201 1. Given the fact the
defense ?led a preservation of evidence request on 19 January 201 1 nearly one year ago the
government has no excuse for not providing the video. See Appendix A. The video is clearly
within the possession of the government and should have already been produced. The
government has responded that it ?will provide all matters requested that are it is possession no
later than 2 December 2011.

b. A copy of all adverse administrative or UCMJ actions, all supporting documentation and
any rebuttal materials to such action based upon the 15?6 investigation conducted by LTG Robert
L. Caslen Jr. The matters requested can easily be found by going to the specifically listed
servicemembers? of?cial records. Williams, 50 MJ. at 441 (government, upon defense request,



has an a?innative obligation to seek out requested evidence). It is without dispute that several
of?cers and enlisted members received adverse administrative actions as a result of their failure
to take appropriate action in this case. See Appendix B. 'Ihus far, the defense believes it has
only received information on one of the ?fteen individuals recommended for adverse
administrative action. The government has responded that it ?has provided all matters requested
that are in its possession.

c. An Encase forensic image of each computer from the Tactical Sensitive Compartmented
Information Facility (T-SCIF) and the Tactical Operations Center (TOC) of Headquarters and
Headquarters Company (HHC), 2nd Brigade Combat Team (BOT), 10th Mountain Division,
Forward Operating Base (FOB) Hammer, Iraq. The lead investigative unit for the government
requested preservation of these items on 30 September 2010. See Appendix C. Given the
government?s own preservation request, it should easily be able to determine the location of
these items. The government responded to the defense request by stating that ?it is still actively
working to preserve related computer hard drives based on defense ?s preservation request dated
2l September l.

d. The defense requested any Bran): or Jencks material in the government's possession.
Brady v. Maryland, 373 U.S. 83 (1963) (holding that due process requires the government to turn
over exculpatory evidence in its possession); Jencks v. United States, 353 U.S. 65? (1957)
(holding that in a criminal prosecution, the government may not withhold documents relied upon
by government witnesses, even where disclosure of those documents might damage national
security matters). Under military law, the trial counsel has an af?rmative obligation to seek out
requested evidence by the defense that is in the possession of the government even if that
evidence is not already in the immediate possession of the trial counsel. United States v.
William, 50 MJ. 436, 441 (C.A.A.F. 1999); United States v. Bryan, 868 F.2d 1032, 1036 (91th
Cir. 1989); United States v. Brooks, 966 F.2d 1500, 1503 (1992) (the government is considered
to have possession of information that is in the control of agencies that are ?closely aligned with
the prosecution"). The defense speci?cally requested the below listed information from the
government that is in control of agencies that are closely aligned with this prosecution. As is
apparent from the government?s responses, it has either purposefully chosen to not search for the
speci?cally requested information, or is shirking its responsibility to do so by saying it has ?no
knowledge?:

i) Mr. Russell Travers, National Security Staff?s Senior Advisor for Information Access
and Security Policy was tasked to lead a comprehensive effort to review the alleged leaks in this
case. See Appendix D. The government responded to the defense request by stating that it "has
no knowledge of any Brady or Jencks material [and] will make a determination whether to
provide the information if and when it becomes aware of such records.

ii) A copy of any e-mail, report, assessment, directive, or discussion by President Obama
to the Department of Defense concerning this case in order to determine the presence of unlaw?il
command in?uence. See R.C.M. 405(e). Additionally, defense requests any e-mail, report,
assessment, directive, or discussion by President Obama to the Department of State or
Department of Justice concerning this case. The government responded to the defense request by
stating that it ?has no knowledge of any Braaj? or Jencks material [and] will make a

determination whether to provide the information if'and when it becomes aware ofsaeh
records.

The damage assessment conducted by the lnfonnation Review Task Force and by the
Of?ce ot'Security. See Appendix and F. The government responded that it ?tats no
hnowiedge of'any Brady or Jencks rnateriai [and] does not present/y have the rtathoritt-? to
disciose damage assessments. {fan}: cited by the defense and make a determination whether
to provide the information {food when it becomes avaiiahie.

iv) The collateral investigations by the Department of State. the Federal Bureau of
Investigation, the Defense Intelligence Agency. the Of?ce of the National Countetiittelligciice
Executive and the Central Intelligence Agency. The defense is entitled to receive any forensic
results and investigative reports by any of the cooperating agencies in this investigation. United
States v. 50 MJ. 436. 441 (C.A.A.F. 1999); United States v. Bevan. 868 F.2d 1032,
l036 (9m Cir. 1989}; United States v. Brooks, 966 F.2d lSDl]. 1503 (1992): Article 46. Uniform
Code of Military Justice (UCMJ J. The government responded that it "has no knowledge otany
Brady or Jenct'rs materiat [array has provided aiifirrensic results and investigative reports
requested that are in its possession and that the United States has authority to diseiose.

v) The Department of Justice investigation into the alleged leaks by WikiLeaks as
referenced by Attorney General of the United States Eric H. Holder. to include any grand jury
testimony and any information relating to any 18 U.S.C. 2703M) order or any search warrant
by the government of Twitter, Facebook. Google or any other social media site. Brady v.
Marviand, 373 U-S- B3 (.1963); Jeneirs v. United States. 353 U.S. 65? (1957}. The government
responded that it "presently has no knowledge ofany Broajt or Jenchs ntateriai and
tarnish said records to the defense shoaiti it become aware ofsaeh records.

vi) The Department of State damage assessment review conducted by its task Force of over
120 individuals. This task force reviewed each released diplomatic cable. See Appendix G. The
government responded that it "has no haowiedge ofany Brady or .Ienchs materiai [and] does
not presentiy have the HttiitOt?tiJf to diseiose damage assessments. ifany. cited by the defense and
wiit' make a determination whether to provide the information [fond when it becomes avaiiabie.

e. The Damage Assessment ofCompromised Information that is required to be submitted to
the Special Security Of?cer (350) under DOD 5105.21-M-1 once an SCI Security Of?cial
determines that a security violation has occurred. The defense also requested a copy of the ?nal
security violation investigation report submitted to the $30 DoDt Defense Intelligence Agency
under Bed) $105.21 The government had not previously responded to the defense
discovery requests for this information. The government's response con?rms that the alleged
disclosures in this case did not involve any sensitive compartmented information. While this fact
alone is not dispositive of whether the alleged disclosures caused harm, it is an additional factor
supporting the defense request for production of the above damage assessments. in response to
the defense request/"or production of evidence, the government responded that it "there is
carrentty no evidence Supporting a compromise of'sensitive cottntartntenteti information (SCH.

8. Under R.C.M. 4ll5lg}{ 1 it upon receiving a defense request production of evidence. the
investigating officer should make an initial determination whether the information requested is
"reasonably available." R.C.M. "Evidence is reasonably available if its
signi?cance outweighs the difficulty. expense. delay. and effect on operations ofobtaining the
evidence.? R.C.M. Military courts recognize "a much more direct and generally
broader means of discovery by an accused than is normally available to hint in civilian courts."
United States v. Reece. 25 MJ. 93. 94 (C .M.A. 1937). Regarding discovery. ?military law has
been preeminent. jealously guaranteeing to the accused the right to be effectively represented by
counsel through affording every opportunity to prepare his case by openly disclosing. the
Government?s evidence.? United States v. Enioe- 35 C.M.R. 223. 230 (CMA. 1965). The only
restrictions placed upon liberal defense discovery are that the information requested must be
relevant and necessary to the subject of the inquiry. and the request must be reasonable. Reece.
25 MJ. at 95. "[Dletermination ofthe relevance and necessity of defense requested evidence
should be made by the court. not ex 9. one by the prosecutor." id. at 94 n. 4. According to the
Court of Military Appeals. the Military Rules ovaidence establish low threshold of
relevance." id. at 9:3. Relevant evidence is ?any ?evidence having any tendency to make the
existence of any fact that is ofconsequence to the determination of the action more probable or
less probable than it would be without the evidence.? id. at 95, quoting Military Rule of
Evidence (NLRB) 40]. In addition. the Court ofMilitary Appeals stated in United States v.
Hart. 29 MJ. 407, 4i 0 1990):

in his opinion at the court below. Judge Gilley adopted the premise that, under
Article 4a, discovery available to the accused in courts-martial is broader than the
discovery rights granted to most civilian defendants. From this, he correctly
reasoned that: where prosecutorial misconduct is present or where the
Government fails to disclose information pursuant to a specific request. the
evidence will be considered ?material unless failure to disclose" can be
demonstrated to ?be harmless beyond a reasonable doubt.?

9. In accordance with these rules and law. the defense has requested the opportunity to inspect
or receive copies of the items listed above in multiple defense discovery requests and has also
requested that this information be produced at the Article 32 hearing. Thus far. the government
has consistently failed to adequately respond.

If}. The government's latest response is yet another example of its failure to exercise due
diligence in obtaining requested information. The government has failed to provide a detailed
account ofits efforts to comply with its discovery obligations. Additionally. the government?s
response that it ?does not presentiy have the authority to disclose damage assessments. ital 1y.
cited by the defense anar will make a determination t-vhetiter to provide the information [fond
when it becomes avaitabie" is either intentionally obstructionist or yet another example of its
failure to exercise dtte diligence.

1. Under the rules. the government is not allowed to remain ignorant of the presence of
evidence favorable to the accused that is reasonably within its possession. United States v.
50 NH. 436 1999); United States v. Btjvan, 868 .2d l032. 1036 ('9111 Cir.

1989). Instead, if the Investigating Of?cer determines that the infonnation requested by the
defense is reasonable available. one of the following must occur:

a. The Investigating Of?cer orders the custodian of the evidence to produce it at the Article
32 hearing and the custodian produces it. R.C.M. or

b. The Investigating Of?cer orders the custodian of the evidence to produce it at the Article
32 hearing and once ordered. the custodian of the evidence determines the information is not
reasonably available. If this happens the Investigating Officer and the accused are bound by the
determination. Id. However. the Investigating Of?cer must include a statement of the reasons
for that determination in the record of the investigation. R.C.M. Once the case is
referred. the accused is permitted under R.C.M. 906(b'J(3) to move the militaryjudgc to review
the determination during a pretrial session; or

c. The Investigating Of?cer orders the custodian of the evidence to produce it at the Article
32 hearing and once ordered, the convening authority determines the evidence should be
withheld under Military Rule of Evidence since production of the evidence
cannot be done without causing identi?able damage to national security; or

d. The Investigating Of?cer orders the custodian of the evidence to produce it at the Article
32 hearing and once ordered. the government objects to the production of the evidence on
grounds of privilege and an in-camera review is conducted by the Investigating Of?cer under
M.R.E. 5056). A M.R.E. 5056) review is appropriate since the investigating Of?cer has the
authority to perform those tasks that clearly impact the conduct of the Article 32 hearing. See
R.C.M. 405(i] {providing that rules of privilege in Section of the M.C.M. apply to the Article
32).

12. The government should not be permitted to determine what evidence will and will not he
produced at the Article 32 hearing. The requested information is necessary for the defense to
adequately prepare its case. Without the requested discovery. any Article 32 Investigation will
be de?cient. See R.C.M. 905(b)(1} and 906(b)(3} {concerning motions for appropriate relief
relating to the pretrial investigation}.

IV. RELIEF REQUESTED

I3. Pursuant to the Fifth and Sixth Amendments to the United States Constitution. Article 46
UCMJ, R.C.M. 405. 701. and the defense requests the Investigating Of?cer to issue
an order requiring the government to obtain the requested information. Failing to obtain the
information. the government should he required to provide a detailed account of its efforts for
review by the Investigating Officer.

,2
xi?,

Di vto EDWARD coon/113s

Civilian Defense Counsel

APPENDIX A

l} I)
-. DEFENSE REQUEST TO
v. . PRESERVE EVIDE-

MANNING. Bradley PFC .
US. Army.

Headquarters and Headquarters Company, US.
Army Garrison1 Joint Base Myerllenderson Hall,
l-ort Myer. VA 222ll

19 January 201



i. In accordancte with the Rules for CourtsaMartiai (R.C.M.) 70l(a} and Manual for
CourtsoMartial, United States, 2008, Article 45, Uniform Code of Military Justice. and
other applicable law, defense counsel in the above entitled ease respectfully request that
the US. Government preserve the con?nement facility video tape of the alleged
disruptive behavior Bradley Manning and provide a copy to the defense for its
inspection.

1. Or: 18 January 201 l. the defenSe was noti?ed that PFC Manning, at the direction of
CW04 .l'antes Avert-tan, was placed in suicide prevention. This decision was made os'er
the recommendations of Capt. William Hooter and the defense appointed expert Capt.
Kevin Moore. When PFC Manning was being ordered to surrender his eiothes. the Brig
made the decision to videotape this event along with an interrogation of PFC Manning by
C9904 Averltart and others.

3. In accordance with RLIM. party shall have equal opportunity to
inspect evidence.? Defense counsel is requesting an equal opportunity to inspect the
video tape. The defense believes this evidence will support a motion for credit for
unlawful pretrial punishment under Anicle 13, Uniform Code t'tt'Military Justice

{1 ECMJ).

4. Defense counsel respectfully request the Get-eminent present-e the video and provide
a copy to the detonat-

A copy ot?this request was served on Trial Counsel by email on 19 January 2m 1.

I.
2?
. .-

lit-stilt t- mid-tat: it NBS
Civilian Defense Counsel

APPENDIX

DEPARTMENT OF THE ARMY
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MEMORANDUM FOR Deputy Chief of Staff Office of the Deputyg??hietegf
300 Army Pentagon, Washington, DC 20310-0300
SUBJECT: Request for DA Initiated Flags Re. Army 15-6 investigation
Compromise of Classified Information to Wilcileaks

1. On 15 December 2010 the Secretary at the Army appointedethe as
Investigating Officer into the Compromise of Classified information to Wilcleaks.
Paragraph 2c of the appointment memorandum directs {?at and. as
appropriate. take action with regard to any personwho should he held accountable for
faitures or deficiencies - to include the exercise of poor judgment in Army
programs. policies or procedures to PFC Bradley Manning,

2. Consistent with the Secretary's guidance 1 have 15 personnel whose
actions i am investigating to assess what role. it"aneet?e?} played in PFC Manning's
compromise of information to Wikileaks and what action to take. if any. based on each
individuals actions and level of culpabil_it_v,_,if any. Consistent with Army Regulation 600-
8?2. Paragraph 1-11, personnel formal or informal, are required to
be flagged pending the compietion otithetinvesttgation and any follow on adverse action
that might resuit from the investigatio?ayi

3. In accordance with AR 6005-8-21, Paragraphs 1?11 and 1-12. and my appolmmem
memorandum dated 18 December'ZO?eS: I request that non-transferable fsags he
:nitiated against the following 15 named personnet.














Brian D. xx
LTC Rodney Gar?eld,
LTC Randolanardte.
MAJ Eric Davisgim-n
MAJ Eric G'aham
MAJ
MAJ-Ctittord E33 Clause
MAJ Elijat?t Breher, at

CPT'Thontas Ctterepko.
1' Steven J. I im_
2 '1LI__EttzabetltA. Fields. xx



Manning 0357


SUBJECT: Request for DA Initiated Flags Re: Army 15-6 Investigation into
Compromise of Classi?ed Information to Wikileaks





13. CW2 Joshua D. Ehresmanl
14? W01 Kyle J. Balonek.
15. MSG Paul D. Adkinsr

4. Appropriate action shall be taken to remove the Flags at the appropriate tzme and
consistent with 600-8-2. Paragraph 1-12. .

5. P00 for this action is mi Executive Officen LTC Thomas a-


.4
lai?rr?fti?z
Enol ROBERT CAqun as
SecArmy Appt Memo, 16 Dec 10 Lieutenant General JSA
lnvostigating Of?cer

Manning

UNCLASSIFIEUHFOR OFFICIAL USE ONLY

ATZL-CG
SUBJECT: AR 15-8 Report Compromise of Classified Information to Wikilealts

[including conduct warranting his referral to Behavioral?Heallh). none of these failures
absolve PFC Manning of any alleged criminal activity 1"









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Figure 9. Accountabiliteresp-onsioilitv Matrix.

6. Specit'-c findings and recomrnendatnons pertaining to each it?dividual
referenced in Figure ?3 above are addressed below



Nothing uncovered during this investigation aosolves PFC Manning of personal
reeponaoilitv t'0r his alleged discloaure of senattive and Classmed information. Likewise. nothing
uncovered during this investigation regarding PFC hilai'iriing's behavioral health appears to relieve
him of reeponsibrlitv for his alleged of eeneitive and Classi?ed information. Of note the
investigative charter did not include a formal assessment at PFC Manning and none was

conducted

95
OFFICIAL USE ONLY

ManningB?OUm 3265

APPENDIX




DEPARTMENT OF THE ARMY
unneo STATES item CRIMINAL COMMAND
COMPUTER CRIME INVESTIGATWE UNIT
msumerou METRO RESIDENT AGENCY
9305 Lowest nose. BUILDING 193
FORT umomm 22060-5593



T0
OF

WM ilti Sep Still)

MEMORANDUM FOR Commander, 2d Brigade Combat Team l0?1 Mountain Division.
Fort Drum, NY 1360?.

SUBJECT: Seizure oi'Governntom Computers and Related Fquiontent

l. This office is investigating the unauthorized eiselosure ofelussi?ed information and related
offenses, which occurred while 2d BCT was deployed to hot}. The investigation has identi?ed
numerous items ofdigital media that may hold evidence of the crintets} or materially assist this
investigation.

2. Agents from :his office have seize-ti anther will seize items nt?elassii?ied and unclassi?ed
digital media such as servers. domain controllers. and hard (hires believed to hold inliinnetioii
pertinent to this investigation.

3. Should your Staff identi?r any additional hard chives {classi?ed or unclassi?ed) used during
the deployment to ll'ilf?t i not informing you that these items represent potential evidence. and
must be preserved as such. l?leiise tnli?h'n'l me immediately should additional hard drives he
found.

4. Agents will provide at receipt, DA Form 413?. Evideneef'Property Custody Document for all
items seized. This may be used for inventory accountability purposes.

5. Most items collected as evidence should hr: processed and returned to you within the next few
weeks. Please note. the supporting Trial Counsel may identify certain items ol'et-itienee that are
required through the end of the Iritil.

ti. Point of contact for this memorandum is ?te undersigiietl at
[gr

T. t. -t :lii'I
slitting in there:



.l


Manninga?oozatsoq

APPENDIX

Obama calls in expert Russell Travers to stop
new leaks amid WikiLeaks scandal

- From:AFt?
- December 02-

BARACK Obama has appointed an anti-terrorism expert to lead US efforts to mitigate the
damage of the WikiLeaks breach and prevent future illegal data disclosures.

Russell Travers. deputy director ot'inl'onnation sharing at the National Counterrorism Centre.
?will lead a comprehensive effort to identity and develop the structural reforms needed in light
of' the WikjLeaks breach.? the White House said in a statement.

Washington has been in damage control mode ever since the whistleblower website last weekend
began publicly disclosing some 250.000 secret US diplomatic cables. many of which revealed
embarrassing assessments of foreign leaders.

While the White House was seeking to play down the impact ofthe security violations. the
?l'ravers appointment was among the clearest signs that the Obama administration tit-?as seriously
stung by the data dump and was taking substantive steps to avoid a repeat.

Among his new duties, 'l'ravers will be advising national security staff on ?corrective actions.
mitigation measures. and policy recommendations related to the breach." according to the White
House.

He will also coordinate interagency discussions on developing actions "regarding technological
andfor policy changes to limit the likelihood of such a leak reoccurring."

Travers has been tasked with collating the Stream of terrorism-related information pouring into
US agencies since the attacks ol?September l, 200].

The Washington Post describes him as the maintainer of the government database of terrorist
entities and a coordinator of terrorism information-sharing initiatives.

The National Countcr~Terrorism Centre where he works was among several agencies blamed for
failing to uncover a plot to blow up a US airliner on Christmas Day last year.

The vast majority ofthe cables revealed by WikiLcaks in its latest document dump originated
from the State Department or its diplomats in overseas missions. and State has launched a review
of its security procedures.

?The department will also deploy an automated tool that will continuously monitor the classi?ed
network to detect anomalies that would not be readily apparent." as well as stat't' who will

analyse the anomalies ?to ensure that they do not represent threats to the ystem,? the White
House said.

The president?s intelligence advisory board will look at ways the executive branch shares and
protects classi?ed data, and will work ?with departments and agencies across the government to
ensure they gain a comprehensive appreciation of all relevant challenges and requirements
necessary to safeguard classi?ed information and networks.?

PIAB will "examine the current posture of the whole ot?govenunent? in terms of leaks of
classi?ed data and will "examine the balance between the need to share information and the need
to protect infonnatiOn.?

APPENDIX

y.

0025 7001022171311?
OFFICIAL USE ONLY

SECRETARY OF DEFENSE
11:00 DEFENSE PENTAGDN
WASHINGTON. DC 20301-1000



AUG 5 2010

MEMORANDUM FOR SECRETARIES OF 12% MILITARY DEPARTMENTS
CHAIRMAN OF THE JOINT CHIEFS OF STAFF
UNDER SECRETARIES OF DEFENSE,
ASSISTANT SECRETARIES OF DEFENSE
GENERAL CUUNS EL OF THE DEPARTMENT OF DEFENSE
DIRECTOR, OPERATIONAL TEST AND EVALUATION
DIRECTOR, COST ASSESSMENT AND PROGRAM



INSPECTOR GENERAL OF Tl-l'E DEPARTMENT OF DEFENSE
TO THE SECRETARY OF DEFENSE
DIRECTOR, ISTRATION AND MANAGEMENT
DIRECTOR, NET ASSESSMENT
DIRECTORS OF THE DEFENSE AGENC 113.3
OF THE DOD FIELD ACTIVITIES

Subject: Task Force to Review Unauthorized DiscIOSure of Classi?ed Information

On 1113; 2.8, 2010. I directed the Director, Defense Intelligence Agency
to establish an lufonnatioo Review Task Force (IRTF) to lead a comprehensive
Department of Defense review of classi?ed documents posted to the WiltiLeaks
website (owzwiltileaksorg) on Jul}r 25, 2010, and any other associated materials.
Department of Defense Components should provide any assistance required to ensure
the timely completion of the review.

(UWOUD) The IRTF will review the impact of the unauthorized disclosure of
classi?ed information speci?ed above. The will coordinate throughout the
Intelligence Commenity in cenduc?ng this time-sensitive review and integrate its efforts

with those of the National Counterintelligenoe Executive.

The IRTF will provide regular updates to the Office of the Secretary of

Defense (03D) on its ?ndings. A more comprehensive interim report will be protected as
the effort progresses. That report will include the following items:

0 (UHFDUO) Any released information with immediate force protection implications;

- Any released infonnation concerning allies or coalition partners that not}r
negatively foreign policy;

. 9590913549 -
5' tootsie ll till

UNCLASSIFIEDHFOR OFFICIAL USE ONLY

mw






OFFICIAL USE oNLr

- (UHIFOUO) Any intelligence reporting;

I Any released infonnation concerning intelligence sources or methods;
0 Any infomatiou on civilian casualties not previously released;

Any derogatory cornrnents regarding Afghan culture or Islam; and

I Any related data that may have also have been released to WikiLealcs,
but not posrecL

A ?nal. report will be produced once all documents are assessed.

(UNFOUO) The is the single organization with .antltorit}r and reaponsibility to
conduct the review regarding this unauthorized disclosure. By soparate tasking, I am
directing 15513311) to conduct an assessment of the Depamnent?s procedures for accessing
and transporting classi?ed utforrnation.

(UUFOUO) This review is separate from, and unrelated to, an}r criminal invangation of
the leakai infonnation. The assesth and review of the leaked documents is not intended
to. and shall not limit in any way, the ability of Department, Federal Bureau of Investigation
or any other federal criminal ii:wc.stigators1 trial counsel and prosecutors to conduCt
investigative and trial proceedings in support of possible prosecutions under the Uniform
Code of Military Justice or federal criminal provisions.

My?t?;
Director of National Intelligence
Director, Central Intelligence Agency

Assistant Secretary of State for Intelligence 8; Research
National Counterintelligencc Center

CC:

UNCLASSIFHEDIFOR USE. ONLY
new E?FftiitTiElftlilt?t *z'iEilE-lil' 1"st



OF DEFENSE
1000 DEFENSE FENTAGON
WASHINGTON. DC 20301-1000



The Honorable Carl Levin
Chaimtan

Committee on Armed Services
United States Senate
Washington, DC 20510

Dear Mr. Chairman:

Thank you for your July 28, 2010, loner regarding the anesthetized disclosure and
publication of classi?ed military documents by the WiltiLeaits organiza?on. I share your
concerns about the potential compromise of classi?ed information and its effect on the
ofour troops, allies, and Afghan partners.

After consulting with the Director of the Federal Bureau of Investigation, 1 have
directed a thorough investigation to determine the scope of any unauthorized release of
classi?ed information and identify the person or persons responsible. I have also
established an interagency information Review Task Force, led by the Defense
Intelligence Agency, to assess the content of any compromised information and the
impacts of such a compromise. Our hai?cl review ordinates meat of the information
contained in these documents relates to tactical military operations. The initial
assessment in no may disownts the risk to national security: hotnever, the review to date
has not revealed any sensitive intelligence sources and methods compromised by this
disclosure.

The documents do contain the names of cooperative Afghan nationals and the

Department takes very serious!)I the Taliban threats recently dismissed in the press. We
assess this rislt as likely to cause signi?cant harm or damage to the national security

interests of the United States and are examining mitigation options. We are working
closer with our allies to determine what risks our mission punters may face as a result
of the disclosure. There is a possibility that additional military documents may be
published by WW and the Deparnnent is developing courses of action to address
this possibility.

The scope of the assessment and nature ofthe investigative process require a great
deal of tinie and effort. I am committed to investigating this matter and determining

ii 3 Si'l'JEii

upgopintnan?ontnradumme?skofw such unmpromisuiutheme. Weill-Ill
keg: you as additional informa?on becomes available.

fag-Um?

no:
Th: Honorable John McCain
Ranking Mamba:

APPENDIX



Message from the Director: Recent Media
Leaks

November 8, 2010

We have seen in recent months a damaging spate of media leaks on a wide range oi?national
security issues. WikiLeaks is but one egregious example. in some cases, CIA sources and
methods have been compromised. harming our mission and endangering lives.

When information about our intelligence, our people, or our operations appears in the media. it
does incredible damage to our nation?s security and our ability to do our job of protecting the
nation. More importantly, it could jeopardize lives. For this reason, such leaks cannot be
tolerated. The Of?ce of Security is directed to fully investigate these matters. Unauthorized
disclosures of classi?ed information also will be referred to the Department of Justice. Our
government is taking a hard line. as demonstrated by the prosecutions of a former National
Security Agency of?cial, a Federal Bureau of Investigation linguist, and a State Department
contractor.

Here at the Agency, we are a family. which means we depend on each other?sharing burdens.
challenges, and successes. But sharing cannot extend beyond the limits set by law and the ?need
to know? principle. The media, the public, even ferrner colleagues, are not entitled to details of
our work.

I would ask that every employee reflect on the responsibilities and privileges ofservicc at CIA.
Every of?cer takes a secrecy oath, which obligates us to protect classi?ed infonnation while we
serve at the Agency and after we leave. A vast majority ol?oi'l'tcers live up to their oath. but even
a small number of leaks can do great damage. Our adversaries bene?t, while our credibility. our
operations, and. ultimately, our ability to accomplish the mission all take a hit. Our sworn duty to
the American people is to protect them and we must do nothing to violate the law or that sacred
pledge.

Leon E. Panetta

CIA launches task force to assess impact of U.S. cables' exposure
by WikiLeaks

By Greg Miller

Washington Post Staff Writer
Wednesday. December 22. 2010: 12:24 AM

The CIA has launched a task force to assess the impact ofthe exposure of Ln'ittsartds of I
diplomatic cables and ?les by Vt'ikilcalxs.

Officially. the panel is called the WikiLeaks Task Force. But at CIA headquarters. it's mainly
known by its all-too-apt acronym:

The irreverence is perhaps understandable for an agency that has been relatively unscathed by
WikiLealts. Only a handful ?les have surfaced on the WikiLealts Web site, and records
from other agencies posted online reveal remarkahh litllg about CIA employees or operations.

Even so, CIA officials said the agency is conducting an extensive inventory ofthe classi?ed
information. which is routiner distributed on a dozen or more networks that connect agency
employees around the world.

And the task force is focused on the immediate impact of the most recently released files. One
issue is whether the agency's ability to recruit informants could be damaged by declining
confidence in the US. government?s ability to keep seerets.

"The director asked the task force to examine whether the latest release of WikiLeaks documents
mi affect the agency's foreign relationships or operations-" CIA spokesman George Little
said. The panel is being led by the Counterintelligence Center but has more than two
dozen members front departments across the agency.

To some agency veterans. WiltiLeal-ts has vindicated the CIA's long-standing aversion to sharing
secrets with other government agencies. a posture that came under sharp criticism after it was
identified as a factor that contributed to the nation?s failure to prevent the attacks of Sept. l.
2001.

Even while moving to share more information over the past decade- the agency "has not
capitulated to this business of making everything available to outsiders." said a former high-
ranking, CIA official who recently retired. "They don't even make everything at ailahle to
insiders. And by and large the system has worked."

CIA veterans said most ofthe agenc_v?s international correspondence is classified at the "Secret"
level. same as the records that ended up online. But the agency has always insisted on using its
own systems.

As recently as two years ago. the agency rejected a request to make more of its intelligence
reports available on the SIPRNET. the classi?ed network used by the Pentagon to pass
information around the world.

"We simply said we weren?t going to do it," another former CIA of?cial said. "The consensus
was there were simply too many people potentially who had access."

The former of?cials spoke on condition of anonymity because they weren?t authorized to discuss
agency security measures.

Among those people with access to was a low-level .3. Army intelligence analyst-
Bradley E. Manning. who has been charged with disclosing classi?ed information and is
suspected of using a simple thumb drive to steal the ?les that were sent to WikiLeaks.

The 1A has had its own computer scandals. Security clearances for former CIA director John
Deutch were suspended in the late 19905 after he was accosed of keeping classi?ed information
on his computer at home.

Of?cials said the agency has also had internal dif?culty keeping track of laptops that are sent to
overseas stations. as well as sensitive information shared with thousands of contractors that the
CIA has hired as part ofa build-up over the past 10 years-

The agency employs software measures to minimize the chance of a WiltiLeaks-like leak.
Agency systems send warnings to administrators whenever a large amount of data is
downloaded. And most ot?the IA's computers are not equipped to allow the use ofa removable
d?ve

Asked what might happen if he had inserted a thumb drive into the machine at his desk. the
former senior CIA of?cial quipped: "There would probably be a little trap door under my chair.?

Even so, CIA security experts have fretted for years about the implications ofrnoying secret
information from pieces of paper to digital ?les that can be distributed online-

"It'sjust a huge vulnerability." the former high-ranking CIA of?cer said. "Nobody could carry
out enough paper to do what WikiLeaks has done."

APPENDIX

U.S. officials privately say WikiLeaks damage
limited

Tue. Jan 18 2011

By Mark Hosenball

WASHINGTON (Reuters) Internal 8. government reviews have determined that a mass leak of diplomatic cables
caused only limited damage to US. interests abroad. despite the Obama administration's public statements to the
contrary.

A congressional of?cial briefed on the reviews said the administration felt compelled to say publicly that the
revelations had seriously damaged American interests in order to bolster legal efforts to shut down the WikiLeaks
website and bring charges against the leakers.

"l think they just want to present the toughest front they can muster," the of?cial said.

But State Department of?cials have privately told Congress they eitpect overall damage to 5. foreign policy to be
containable. said the of?cial. one oi two congressional aides familiar with the brie?ngs who spoke to Reuters on
condition of anonymity

?We were told (the impact of Wit-iiLealts revelations) was embarrassing but not damaging." said the of?cial. who
attended a brie?ng given in late 2010 by State Department of?cials.

WikiLeaks caused a media and diplomatic uproar late last year when it began to dribble out its cache of more than
250.000 U.S diplomatic cables

Major headlines were generated by some of the cables. which revealed that Saudi leaders had urged US. military
action against Iran and detailed contacts between US diplomats and political dissidents and opposition leaders in
some countries

"From our standpoint. there has been substantial damage.? State Department spokesman Crowley told Reuters.

'We believe that hundreds of people have been put at potential risk because their names have been compromised in
the release of these cables.? he said

YEMEN TIES STRAINED

National security of?cials familiar with the damage assessments being conducted by defense and intelligence
agencies told Reuters the reviews so far have shown "pockets" of short-term damage. some of it potentially harmful.
Long-term damage to 3 intelligence and defense operations. however. is unlikely to be serious. they said

Some of the cases of more serious damage have occurred in countries where WikiLeaI-ts' revelations have publicized
closer ties Washington than local of?cials publicly admit.

For example. a cable released by WikiLeaks quoted Yemen's president saying he would allow US. personnel to
engage in coontersterronsm operations on Yemeni territory even as he said publicly that the operations were being
handled by domestic security forces.

LJ.S. of?cials say the continued media attention on such revelations has made It dif?cult for Washington to repair
relations with govarnments critical to its counter-terrorism operations. such as Pakistan and Yemen

00539

Two U.S. intelligence of?cials said they were aware of speci?c cases where damage caused by WiltiLealts'
revelations have been assessed as serious to grave. though they said they could not discuss the subject matter
because it remained highly classi?ed.

Crowley said the State Department had helped move a small number of people compromised by the leaks to safer
locations.

Damage assessments by the State Department. Pentagon and U.S. intelligence community are still continuing, so the
current view of many of?cials that damage has been limited could change if and when WikiLeaks and its media
partners publish more documents.

The assessments also cover the leaking of tens of thousands of military ?eld reports from Iraq and Afghanistan.

Special investigative teams are also combing through unpublished material which US. investigators believe is in the
hands of WikiLeaks.

U.S. of?cials and sources close to WikiLeaks have said the website is sitting on a cache of documents related to the
U.S detention facility at Guantanamo Bay. Cuba. which includes intelligencesbased risk assessments of detainees.

A spokeswoman forthe of?ce of Director of National Intelligence James Clapper. which oversees all US. intelligence
agencies. said, "The irresponsible and reckless behavior of WikiLeaks has of course caused damage and will
continue to be damaging in the months and years to come."

But current and former intelligence of?cials note that while WiltiLeaks has released a handful of inconsequential CIA
analytical reports. the website has made public law if any real intelligence secrets. including reports from undercover
agents or ultra-sensitive technical intelligence reports. such as spy satellite pictures or communications intercepts.

Shortly before WikiLealts began its gradual release of State Department cables last year. department of?cials sent
emails to contacts on Capitol Hill predicting dire consequences. said one of the two congressional aides briefed on
the internal government reviews.

However, shortly after stories about the cables ?rst began to appear in the media. State Department of?cials were
already privater playing down the damage, the two congressional of?cials said

The US. government is examining whether criminal charges can be brought against WikiLeaits founder Julian
Assange. Assange is in London ?ghting extradition to Sweden for questioning in a sexual misconduct investigation.

UNITED STATES
DEFENSE REQUEST FOR
ARTICLE 32 WITNESSES

MANNING. Bradley Ii. PH:

US. Army. sax-xx

Headquarters and Headquarters Company. LIB.
Army Garrison. Joint Base Mycr-l-lenderson Hall.
Fort Myer- VA 2321

DATED: 2 December 201]



On hehalfofPFC Bradleyr E. Manning. his civilian counsel. David E. Coombs requests
the attendance ot'each ofthe below listed witnesses for the following reasons:

a) In order to inquire into the truth ofthe matter alleged in the charges. consider the
form of the charges. and assist the Investigating Of?cer in making recommendations as to
disposition ofthe charges. See Rule for Courts-Martial 405(a};

b) In order to serve as a means of discover for the defense. The defense has been
unable to speak with several of the listed witnessed due to their lack ofeooperatitm with
requests to be intenriewed prior to the Article 32 hearing. See ROM. 405{a) Discussion
[stating the "investigation also serves as a means of discovery" for the defense}:

c} In order to present matters in mitigation the charged offenses. ROM. 405(1?)
{stating an accused has the right to present evidence in defense. mitigation. and
attenuation); Article 32th). Uniform Code Justice (UCMJ) (stating an accused
may ?present anything he may desire in his own behalf. either in defense or mitigation.
and the investigation officer shall examine available witnesses requested. titrated
States v. Garcia. 59 447. 451 (C.A.A.F. that an accused has the right to
present anything he may desire in his own behalf at an Article 32 in defense or
mitigation);

cl] In order to inquire into the issues of unlawful command influence and unlawful
pretrial punishment in violation of Articles 13 and 37 ofthe See R.C.M. 4USle}
Discussion (stating that inquiry in to other issues such as legality of searches or the
admissibility of evidence is proper by an Article 32 Investigating Of?cer}.

I) SA 'l'oni M. Graham. 102"" MP Detachment.
SA Graham is 0m: oi?thc

law enforcement agents that conducted work on this case. SA Graham was the
primary agent involved in the initial investigation of the ease beginning on 25 May
2010. SA Graham will testify about the investigative steps taken from the time of'the

LA.)
?3

HIV. HFCR.



United States v. Manning: Article 32 Witness List

4)



initial involvement until the matter was transferred to the Computer Crime
investigation Unit on 33 June 2010.

SA Mark A. Mander. Gliilfi. I -
- - SA Mandcr is one ot? the law
enforcement agents that conducted work on this case for the CC NJ. He is the drat'ter
ot?most of the CH) Reports of investigation. He is part oi?ajoint investigation by CID
and the Department of State (DOS) Diplomatic Security Service (USS). Under the
cooperative investigation agreement. C1D is the lead investigative agency with
primary responsibility for coordinating all leads affecting the L18. Army. and D354 has
responsibility for leads involving the DOS. The Federal Bureau ol?lnvestigation
(FBI) laterjoined as a joint partner in the investigation with responsibility for
providing countercspionage expertise, investigative support. and as the lead agency
for all civilian related leads.

SA Calder L. Robertson 111. 6813. Computer Crime Investigation Unit (CCIU),
Manchu. (?m-many. - Il_ He
extracted the hard drives from the two and one NIPR computers collected from
the the personal laptop of 880 Bigelow. and the personal external hard drive of
PFC Manning. SA Robertson wili testify about his involvement in the investigation
and the steps he took from the initial reporting of the alleged incident on 25 May 2010
until present regarding the forensic imaging and evidence collection ofciectronic
media seized in Iraq.

SA David S. Shaver, 6813. Computer Crimes investigative Unit. 27130 Telegraph
Road, Quantico. Virginia 22134, SA
Shaver is a forensic examiner who conducted an examination of the computers used
by PFC .?v?Iarming within the -SC IF- 44 loose hard drives seized from BCT.
digital media collected from PFC Manning's Aunt's residence, various log ?les from
CIDNE lraq and Afghanistan. log tiles from the Army Counterintelligenee
Center (ACIC). and his personal computer equipment. SAC Shaver completed 10
classified CCIU reports and will testify about the nature ot?his forensic examinatirtn
and the results of his examination.

SA Charles T. Ames Jr.. 0813. 9305 Lowen Road, Fort 'Belvoir. Virginia 22060.
- - SA Ames of
the law enliorcemcnt agents that conducted work on this case. He interviewed
numerous witnesses during the investigation from 3d He also detailed
the collection ol?classitied information for the Inlormation Review "ran; orce's
damage assessment.

SA Alt?red L. Williamson. Digital Forensics and Research Branch. Computer Crimes
Investigative Unit. 27130 Telegraph Road. Quantieo. Virginia 22134. - -
A forensic examiner who examined the 118.

Government Supply Annex ET computer (Unclassi?ed). utilized by PFC

.-

Linited States v. Manning: Article 32 Witness List

Bradley Manning. He will testify about the nature of his forensic examination and the
results of his examination. He will also testify about. his forensic analysis and
evidence collection from PFC Manning?s cellular telephone. the computer assigned IP
address 144. I 07'. 7.19 and the forensic imaging of the Wikileaks website.

7) SA Troy M. Bettencourt- Computer Crimes Investigative Unit. 3t] Telegraph
Road. Quantico. Virginia 221.34
SA Bettencourt is one ofthe agents that worked extensiver on this case for CCIU to
include inten-?iewing multiple witnesses in the case and conducting field investigation
for the CCIU. SA Betteneourt will testify about his involvement in the case and the
investigative steps that he took.

Si SA Ronald K. Rock. United States Department of State, Diplomatic Security Service
Of?ce of Professional Responsibility?

?as Rock is one of the law entbreement agents that conducted
wor on 1s ease. te defense requests that SA Rock be instructed to provide the
Investigating Of?cer and the defense with a complete copy of DSS case file number
Pit-2t) 0-000th and any other collateral investigations by the DSS related to this case
at least two weeks prior to the start ofthe Article 32 hearing.

SA Patrick Wheeler. Federal Bureau ol'investigation. the defense does not have
contact information for SA Wheeler. but believes that he would be the best
representative from the FBI to discuss the initial involvement ofthe FBI and their
subsequent investigation. SA Wheeler is one ofthc law enforcement agents that
conducted work on this case. He was the that agent to make contact with Adrian
Lamo on 25 May 2010 in order to obtain the alleged chat logs between Mr. lame and
PFC Manning. The defense requests that SA Wheeler be instructed to provide the
investigating Officer and the defense with a complete copy of FBI case ?le number
242460 and any other collateral investigations by the FBI related to this case at least
two weeks prior to the start of the Article 32 hearing.

10) Martin Leibman. Kenncr Army Health Clinic. 700 24?? Street. Fort Lee. Virginia
23801. that performed a
command-referred behavioral health evaluation BHE on PFC Manning '24 December
2009. CPT Leibman will testify that he determined PFC Manning appeared to be
under a considerable amount of stress at the time of his evaluation. He will also
testify that PFC Manning did not appear to have any social support system and
seemed hypersensitive to any criticism. He recommended that PFC Manning he
moved from the night shift to the day shift and that he be given a low intensity duty
for the immediate future. He also determined that PFC Manning was potentially
dangerous to himself and others and recommended removal of his weapon or removal
of the bolt from his weapon along with increased monitoring and supervision. He
will testify that he used a behavioral health evaluation form that was not approved.
MIZDCOM Form 4038. On that form. however. there was a block that permitted the
behavioral health provider to indicate that the Soldier being evaluated was riot





United States v. Manning: Article 32 Witness List

suitable for continued access to classi?ed material. Despite having this option. CPT
Leiebman did not check this box. He will testify that he does not remember why he
did not check that boa. Had he done so. PFC Manning?s security clearance would
have been revoked and he would not have had access to classi?ed materials after that
date.

1 ll CPT Michael E. Worsley. 1908?? MC Detachment. 500 SW 42? Street, Topeka.
Kansas 66609-1241 will testify
that he treated PFC Matuting on numerous between December 2009 and 26 May
2010. As part ot?his treatment, CPT Worsley considered letters written by PFC
Manning?s noncommissioned officer in charge. then MSG Adkins. He will testify
that new SFC Adkins expressed concern about PFC. Manning?s mental and emotional
stability in the three letters noting that PFC Manning appeared to be suffering greatly
and also having dif?culty sharing his problem. CPT Worsley will testify that he
contacted SFC Adkins alter each evaluation was completed in order to give him a
summary of the information from his review and to allow Adkins to share his
thoughts and concerns. Despite the behavior of PFC Manning. CPT Worser will
admit that he never made a recommendation to the command concerning whether to
suspend PFC. Manning?s security clearance. He did. however. speak with MAJ
Clifford Clauscn and 180 Erie Usbeek about his reviews and PFC Manning's need
for ongoing long term to explore and understand his issues.

12} CPT Edan A. Critchlield. Department of Behavioral Medicine. I 1050 Mt- Belvedere
Blvd. Fort Drum. New York 13603.
He is a that performed a behavioral health evaluation on PFC Mtutning on
22 May and 28 May 2010. He will testify that SF Adkins had expressed concern to
him about PFC Manning around 10 April 2010. and had given him a memorandum
where he documented his concerns. Since PF Manning?s primary clinician. PT
Worsley. was on leave at the time. he completed the command directed mental health
evaluation. Based on his interview ofPli Manning and review of his records, CPT
Critchfield will testify that be determined PFC Manning was at risk to himself and
others and recommended that he not have an operable weapon. He will testify that he
considered making a recommendation as to PFC Manning?s access to classi?ed
information in his 22 May 2010 evaluation but did not do so because he had been
informed that PFC. Marming was no longer allowed in the Instead, he deleted
the block referencing access to classi?ed on the MEDCOM Form 4038 in
order to have more space to write notes on the form. PT ritehtield will testify that
he did receive training on the subject of Soldier suitability for access to classified
information. The training that he received was informal ?onithc-job? training during
his residency. He will testify that the factors suggested to look for in making
suitability determinations were (1) reliability. (2) stability. and (3t judgment. On his
28 May 2010 mental health evaluation. CPT Critchfield will testify that he made a
recommendation that PFC Manning was not suitable for continued access to classified
material and that his security clearance should be rescinded.

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Linited States v. Manning: Article 32 Witness List

iza ion Command. Fort Bliss. Texas 79916.
'ormer 2nd Commander, He will
testify that the brigade did not want to take the wrong personnel forward. nor did the
brigade want to leave a large rear behind fora small staff to manage and lead. the
expected the leaders in the Brigade to identify those soldiers who should not deploy.
He will testify that his 5-2. the of?cer in charge of PFC Manning. MAJ Clifford
Clausen. was not up to the standard that he expected out of someone
in that position. Based upon his discussions with then LTC Paul Walter and LTC
Brian Kerns. 01.- Miller decided it was best to remove MAJ Clausen from his
position as the 8'2 and place Lint into that job. He will testify that from his
perspective, the issues surrounding PFC Manning should have been something that
the 82 personnel would have been more involved in than the company. However-
there were several issues that may have impacted the response to PFC Manning?s
issues. First. during that time period the fonner company commander. MAJ Elijah
Dreher was relieved over property accountability and due to the fact he was not
making good decisions. Second. MSG Adkins. the NCOIC in the SE Section. was
"marginal. but not bad enough to either relieve or replace. He will testify that then
MSG Adkins was technically competent but that he lacked leader skills expected ofa
MSG. He will also testify that commanders {in conjunction with their unit securin
manager) are allotted 30 days to submit an initial DA 5243-R following the discovery
of credible derogatory information on a Soldier. After the initial DEROG is
submitted and processed by SIDICCF, the unit has 90 days to submit a follow-up
5248-]? if there is a pending investigation or adverse action taken (cg. summary
court-martial). Once the are completed and the Soldier has
been cleared/Charged of offense. the unit must submit a final DEROG. In this case.
he will testify that then MSG Adkins failed to keep the chain of command informed
Manning emotional and mental condition. He will testify that this failure
resulted in the command not submitting a DEROG in a timely manner.

COL David M. Miller Bri ade Mo






l4) LTC Brian Kems. Old Dominion University. 4? Brigade Cadet Command, Rollins
Hall Room 119. Norfolk Virginia 23529
former Executive Of?cer for 2nd He will testify
that he was Clausen's direct supervisor. He believed that MAJ Clauscn could
not provide COL h-liller with accurate or timely estimates or intelligence- and could
not talk to COL Miller in a way that served the Commander's needs. The brigade
commander ?nally lost con?dence in MAJ Clausen and made the decision after
approximately 6 months to move hint. He will testify that the unit did not conduct a
formal relief for cause. but moved him to a transition team. According to LTC
MAJ lausen?s performance was weak. but not so weak as to warrant a relief for
cause. LTC Kerns did not believe MAJ Clauscn was not a strong leader. He tried to
decentralize Operations but didn?t have enough oversight to control. He empowered
junior members who were too inexperience to do the job and did our step in to correct
when they made mistakes. He will testify that MAJ Clausen was unable to mentor or
develop younger of?cers and didn't have much direct control over the shop. He will
also testify that MAJ Clausen was handicapped by weak NCO leadership in his shop.



00545
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United States v. Manning: Article 32 Witness List

Speci?cally, his NCOIC. then MSG Adkins was not an effective leader. In his
opinion. both MAJ Clausen and MSG Adkins were weak leaders. He will testify that
he was unaware of any leadership guidance provided in the 82 sections regarding
enlisted personnel management. He will testify that it did not surprise him that MAJ
Clausen put out information that Warrant Officers and oncommissioned Of?cers
were to defer all management responsibilities to MSG Adkins. He will testify that
perhaps the command was too generous with MAJ Clausen and that removing him
from his position earlier would have been advantageous. He will testify that he
believes PFC Manning?s mental and emotional issues were more than enough to put
others at risk and should have resulted in an immediate DEROG. He will testify that
he did not know anything about PFC Manning?s conduct until a recommendation for
separation was made by the chain of command. He will testify that none of the
mental or emotional health concerns. prior to May of 2010, made it to his level.
Kerns will testify that the failure to properly DEROG PFC Manning?s was the unit?s
biggest failure. He believes that the unit should have pulled PFC Manning?s access to
classi?ed information much earlier. He will testify that the unit should have
recognized him as needing help and that his condition made him unfit for service as
an intelligence analyst. He will also testify that the assistant 86 for the brigade. CPT
Cherepko came to him with concerns about unauthorized personal media on
machines. According to Chcrepko, personnel were putting unauthorised media
on computers such as programs. games, videos, and music. LTC Kerns will testify
that it was fairly common when the unit arrived to see games, music and movies on
the He believed that it was fairly common across Iraq. He will testify that
he tried to get the staff to do the right thing, but media on the continued to
be the standard. He will testify that at no point was UCMJ punishment applied to
those who were placing unauthorized in'fomiation on He will acknowledge
that with respect to the media on the he believed that the Army had become
too comfortable working on while deployed. It is his opinion that this may
have bred some complacency because of the ease of access. He believes that most
Soldiers did not realize that that placing music and other media on
computers was wrong because of how prevalent those items vvere across Iraq. He will
also testify that after PFC Manning was arrested. COL Miller ordered him to take a
complete look at INFOSEC across the brigade. He formed a working group
consisting of the SGT-VI. SE. 36 and ID personnel to look at how the brigade was
operating. Based upon this review, the $6 removed universal ability to write to disks;
there was additional compartmentalizing ofinformation within the BCT based on a
need to know; the 86 instructed staffon how to lock out directories and the brigade
established an SOP on the implementation for reviewing infractions for potential
DEROG actions.

In MAJ Elijah a. Dreher. - (Fowler HHC-
zecr Commander). attain testify that he had very little interaction with the 3:
shop. He will also testify about the guidance he gave regarding whether soldiers
would deploy. He will testify that he was not made aware of any effort to keep PFC
Manning from deploying. He will testify that his understanding was that

?r

United States v. Manning: Article 32 Witness List

Manning's issues came about after deploying. He was not aware that SFC Adkins
recommended to Manning that he self-refer to Mental Health or that
Manning even went to Mental Health prior to the deployment. He will also testth
that he was not adequately informed of PFC Manning?s mental health issues by MAJ
Clausen or SFC Adkins. His TBS crumsel is C'PTSteve .S'nchotnski at Flirt (Jordon

16) MAJ Clifford D. Clausen. National Radio Frequency COMECT Center.

He was the Bill] 55-3 until being
replaced by Lim. He will testify that SFC Adkins did tell him about an outburst
by PFC Manning before the deployment. but that he does not remember Adkins
having a conversation with him about leaving PFC Manning on rear detachment. He
will also testify that he did not recall talking to the company commander about
Manning?s behavioral health issues. He will testify that it was his practice to not take
many issues outside of the 82 Shop, and that he believed the supervision policy
having every issue go through SFC Adkins was ?ne. Finally. he will testify that
music CDs were allowed in the

CPT Barclay D. Keajr. HHC. 4?3l infantry Battalion. Brigade Combat Team, 10'Ii

Mountain Division, Buildin 10210 North Riva Ridge. Fort Drum. New York 13632.
(night shift 01C lior the T-SCIF for 2nd

. l. W1 test] yttat to tevet t. . 1anning was good at hisjob and he was
also impressed with PFC Manning's computer skills. Despite this belief. he will
testi?v that PFC Manning should not have been a soldier as he seemed to act
immature. He will testify that hot: could not demand things from PFC Manning as he
had a sol" skirt and was not receptive to commands. He will testil?v that there was a
lack of leadership on the night shift which PFC Manning worked on. He will testify
that from his perspective PliC Manning wanted to be a good soldier. but naturally was
not good at the basic soldier skills. He will also testit}I that music. movies. and games
were common on machines. He will testify that he went to a lot ot? people to
try to determine if it was a problem to have media on SIl?liLNet because he did not
think it was proper. He will testify that he spoke with several indisiduals within the
about this issue, but no one could provide him with an answer. He will testify
that eventually it became the nomt to see soldiers listening to music watching
movies. and playing games on machines.




13) CPT Matthet-v W. Frecburg, till 12. Armored Division Road. Fort Drum.
New York 13602. Compani-
commander and book holder for all the computers within lle
will testi?r about providing commander?s authorization to seize and search the
computers PFC h-lanning was known to work on. He also provided setu'ch
authorization to search PFC Manning's room. He will testify that he never received
any from the 53 Section concerning an_v ot?l?FC Manning's mental Dr
emotional issues ttntil alter the alleged assault Showman. He will testify that
after the alleged assault. he removed PFC Manning from the T-ElellT and sent him to



United States v. Manning: Article 32 Witness List

work in the Supply Room. He then gave PFC Manning an Article 15 reducing him
from SPC to PFC. Along with the Article 15. CPT Freeburg will testify that he filled
out a DEROG form in order to suSpend PFC Manning?s security clearance. CPT
Freehurg will testify he then went to CPT Worsley at Behavioral Health to discuss
PFC Manning's condition. Worsely told him that PFC Manning's troubles were
deeper than the Army could ?x and that he should be separated. CPT Freeburg will
testify that he then sent PFC Manning to CPT Critch?eld for an evaluation. Based
upon the mental health recommendations, CPT Freehurg will testify that he initiated
the cltapter paperwork. l-?rechurg will testify that he believed it was shocking that
something more serious had not been done to address PFC Manning?s behavioral
issues prior to him assaulting SPC Showman and receiving an Article 15. He will
also testify that he was aware that personnel had placed video games. movies. and
music on the Sll?Rth drive.

19) CPT Steven J. Lim. First Army Division East. 6-2, 4550 Llewelyn Drive, Fort
Meade, Maryland 20755?-?lle will testify
that he knew about PFC Manning emotional and mental health issues before taking
over as the brigade 82. Additionally. he will testify that PFC Manning was
counseled on a few occasions due to his emotional and mental issues and that he was
informed that PFC Manning was seeing a doctor about his condition. Despite this
knowledge. CPT Lim will testify that he was not aware of the Full extent of Pl?
Manning mental health issues. He will testify that once he learned ot?the entire facts
surrounding PFC Manning, he believed that PFC Manning should not have been
deployed. He will also testify that he gave a negative counseling to SFC Adkins for
Failing to inform him of the various issues PFC Manning was struggling with during
the deployment. PT Lim will testify that soldiers were authorized to bring music
CDs to listen to in the CPT Lim will also testify that the T-SCIF failed to
draft a Standard Operating Procedure (SOP). CPT [.im will testify that he passed the
link to the US. Embassy cables to the various including PFC Manning. He
disseminated the link to the BET 32 shop and the BN 82?s sometime in the beginning
of January 20l in order to allow the to better understand the Iraqi political
situation. He will also testify that the comments in the press that say the release of the
IDNE database compromised our key sources and put the lives ol?sourees at risk are
inaccurate. Any name in the CIDNE database (Iraq and Afghanistan] were just names
put in by a soldier who spoke to some local national and not soorces lint the United
States. Lim believes that although a name may he in CIDNE, it was likely
spelled phonetically and did not contain the full name of the individual. Lim
knows that he had the ability to pull 50 different ways to spell Muhammad when he
would do a CIDNE database search. That fact there were so many different ways to
spell Muhammad is indicative ofthe fact the names in the [Thile database were not
accurate accounts.

20' CPT Thomas M. Chere ko. NATO Force Command Madrid, Madrid. Spain 09649,
He was the assistant 8-6 for the
EBCT. He will testify that the infonnation assurance procedures were not being






United States v. Manning; Article 32 Witness List

followed by the brigade. He knew that Soldiers would go to the local market and buy
movies. music and games and place the information on their SIPR and NPR
computers. He tried to address the issue but could not get any support from the
leadership to enloree the standards. He raised the movie and music concern to the 36.
Morrow. and the Brigade X0. LT Kerns. but that nothing was done. When the
mood struck him. he would scan the shared drive for music. movies and games and
will testify that he would find it every day. Every time that he found unauthorized
material on the he would delete it. Occasionally. he would find a Soldier
that would have a huge amount of unauthorized material on their computer ?in one
instance it was 300 Gigabytes of information. but nothing was done. He will testify
that as the IASO he did not know that he needed to prepare a Information
Assurance Certification and Accreditation Process (DIACAP) packet for certi?cation
and accreditation of the brigade network. He will also testify that due to this failure,
it was later determined that the brigade did not have an Approval to Operate or
an interim Approval to Operate (IATO) for their network. Additionally. the brigade
did not receive a t?omtal IA certi?cation and accreditation inspection during its tour.
contrary to the guidance in MNF-I Directives. Finally. he will testify that he knew
about personal software being loaded on the and he would remove the
software when he came across it. He is re resented CPT Bargain? at
For! Myer,



21} CPT Michael R. Johnson. Brigade- 25'? Airborne Infantry Division. .loint Base
Elmendorlt-Rjehardson. Alaska 99505._.

He will testify that SFC Adkins was in charge of
all enlisted responsibilities. He will testify that whenever he engaged the Soldiers on
issues as a leader that he was told to back off by SFC Adkins. CPT Lim, and MAJ
Clausen. He will testify that the MAJ Clausen. did not set standards for the unit.
Based upon this lack ofleadership, he will testify that a lot of conduct was ignored.
He will testify that he remembers venting to MAJ Claus-en and SFC Adkins about
how nothing was being done to address PFC Manning?s mental and emotional issues.
He will state that when he addressed these concerns to MAJ Clauscn and SFC Adkins
that he was told that he needed to stay in his lane. After the change in leadership
within the 32 Section. he will testify that all ofthe of?cers sat down to discuss soldier
standards in an attempt to address substandard conduct. However. SFC Adkins
objected to any changes and would not allow anyone to address the issues
surrounding PF Manning. As such. he will testify that nothing was done to address
PFC Manning?s mental and emotional issues.

22} 1LT Tanya Marie (iaab. ll] K), 525?? BFSB, Fort Bragg. North Carolina?
will testify that SFC Adkins was in charge ofthe
administrative details and supervision of the soldiers within the 82 Section. She will
testify that she was made aware of many of the issues surrounding PFC Manning
when she arrived to the unit. In her opinion. PFC Manning should have been
removed from his position in the early on in the deployment. However. she
felt that the leadership within the 82 section was not really concerned with

i)

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United States v. Manning: Article 32 Witness List

disciplining Soldiers. She will testify that she asked SFC Adkins why PFC Manning
was not removed from his position in the T-SClli? earlier. and that he told her that it
was a manpower issue. She will testify that she believes that PFC Manning's issues
were not taken seriously and no one took any steps to help him or even recognize that
he needed help, She believes the unit failed to take proper action and failed to
properly reSpond to the issues that PFC Manning was obviously struggling with both
before and during the deployment.

23} Elizabeth A. Fields- as the
Special Security Represetltative (SSR) for the T-SCIF and part ofthe Sunni Team.
She will testify that she odly received one hour ol?training at 10'h MTN to be the SSR.
For the Her train 1g covered the basic rules and regulations For a at
Fort Drum. She will testi that her training did not really cover ensuring the security
ot?a TASCIF. However. 1c will testify that she was only the SSR at Fort Drum.
When her unit deployed to Iraq. she will testify that then MSG Adkins was the one
that worked the security of the T-SCIF and she dealt with security clearances. She
will testify that SFC Adkins did not receive any training to be the SSR. However. he
just assumed the position under the approval of the 3?2, MAJ Clausen. She. will
testify that she believed SFC Adkins provided terrible supervisory leadership. She
thought he was a terrible leader because the problems within the unit were constantly
being ignored. She will testify that it was obvious to everyone that PFC Manning was
struggling with mental and emotional issues. However- she will testify that when she
tried to deal with the issue and get Manning help. she was told that it was an
NCO problem and to stay out ol?it by SFC Adkins. She will also testify that she did
not believe that MAJ Clausen had any type of management over the section. She also
did not believe that the Company 180 cared about the SE section because they were
not co-loeated. She will testify that she was aware of multiple issues with PFC
Manning but stated that PFC Manning stayed in the because SliC Adkins
said that we needed personnel. She will testify that she believed that there was a lack
ol?lcadership across the board. She will testiFy that as leaders they should have
pushed harder From the NCOs to the Of?cers. She will testify that she. was puzzled
why PFC Manning was not removed from the a?er previous behavior
incidents that occurred between him and SPC Padgett in December of 2009. She will
testify that it was simply accepted that people brought in CD5 and DVDs into the T-
She believed that there was no unit training at 2H 0 that focused on T-SCIF
operations during the deployment.

ewz Joshua D. Ber. 10*? Mm . Fort Drum. NY 13602. (3151
He is represr-rnted by




responsible for any personnel who worked in the 52 section. He will testify that on
several occasions he returned to SFC Adkins and MAJ Clausen to clarify their
expectations about his responsibilities regarding enlisted Soldiers and Of?cers and his
non-role in soldier leadership was reinforced on each occasion. CW2 Ehresman was

IO

hr

United States v. Manning: Anicle 32 Witness List

aware of multiple emotional outbursts by PFC Manning. He will testify that prior to
the deployment he recommended that PFC Manning should not deploy and expressed
this directly to MAJ Clauscn. P'l? Martin and SFC Adkins. He will testify that he
was told that PFC Manning would deploy due to manpower issues. He will testify
that he witnessed an incident in December of 2009 by PFC Manning that required him
to physically involve himselt?in the situation in order to ensure PFC Manning did not
try to harm himself or others. After this emotional outburst. he will testify that he
spoke to SF Adkins and recommended that he take the bolt from PFC ltl?lanning's
weapon. send him to mental health and then get him out of the Army. He also spoke
with CPT Lint. CPT Martin and 186 Eric lisbeck about his concerns after the
outburst by PF Manning. He will testify that even after expressing these concerns.
nothing was done.

25] MSG Eric Llsheck. Fert Bliss. Texas.?
t'fornicr ISG oflIlIC. 2nd He will testify that prior to the dePloyment, he
received occasional comments from SFC Adkins regarding PFC Mamiing?s attitude
and personal problems. However. he was never aware ot?any suggestion not to
deploy PFC Manning. He will testify that he was made aware ofone incident during
the deployment involving PFC Manning by another soldier. MSG Usbeck then
sought out SFC Adkins to clarify what this soldier had told him. After looming what
happened. MSG LIsbeck along with SPC Showman decided to counsel PFC Manning
for about 45-60 minutes and referred him to Mental Health for evaluation. He will
testify that could not recall ifthe referral was command directed or if Manning
volunteered. He will testify that he later learned that PFC Manning had not gone to
mental health as required. However. due to his transition- he will testify that he
informed his replacement of the issue instead of attempting to address the issue
himself.

26'] MSG Mark S. Woodworth, Task Force 3. OPS GRP. JRTC. Port Arthur
Terrace. Leesville. Louisiana 71446.
?He became the 13C: of the company in March of
3010. He will testify that he was briefed on Manning having an issue with tunithcr
soldier. He believed that PFC Manning had gone to Combat Stress and seen a
prowl-rider. The next thing he heard about PFC Manning was the assault of SPC
Showman. After the assault ot?Sl?C Showman. PFC Manning was moved to the
Supply room. He will testify that SFC Adkins did not talk to him about removing the
bolt from PFC Marming's weapon. He also does not recall any discussions about
sending PFC Manning back to the States or chaptering him out of the Army. He will
also testify about C1D coming to the unit and scarcitng PFC Manning?s living
quarters and work space.





27) Patti David Adkins. one, 2? act. Fort Drum, New York 13601DSNF
is represented by TBS Counsel*anning?s Once a MSG, SFC Adkins

was administratively reduced by a board due to being derelict in his duties. The board



United States v. Manning: Article 33 Witness List

concluded that SF Adkins failed to take proper steps in addressing PFC Manning's
issues. SF Adkins will testify that he was aware of the problems of PFC Manning.
Over the course of several months, he will testify that he drafted three memorandums
detailing various behavioral health concerns of PFC Manning. Despite this
knowledge. SFC Adkins will testify that he failed to notify anyone of these concerns
that could have taken steps to take care of PFC Manning and ensure that he was
getting the help that he needed. instead, he will testify that he simply allowed PFC
Manning to continue to work in the T-SCIF as an intelligence analyst. SFC Adkins
will testify that he assessed that PFC Manning was salvageahle ifhe received and
actively participated in extensive therapy 1-2 times a week on an
inde?nite basis} coupled with responsive evaluations. medication and
follow-up adjustments on dosages.

23 380 Lawrence We ?ne Mitchell, l-lHC. 2nd BCT. Fort Drum, New York 13602,

SSG Mitchell will testify that he
originally did not have supervisory responsibilities at the unit. After approximately
60 days. he was given responsibility for supervising two subordinate 35F Soldiers:
one of these soldiers was PFC Manning. When SSG Mitchell got to the unit in May
of 2009. he observed operations for approximately 90 days and then approached SFC
Adkins to let him know his input about operations. SSG Mitchell will testify that he
speci?cally told SFC Adkins that PFC Manning needed to be chaptered of the Army.
8530 Mitchell believed that PFC Manning clearly was struggling with emotional
issues that made hint ill-suited for military service. This conversation occurred in
June or July off-1009. SSG Mitchell will testify that he approached SFC Adkins
thereafter about separating PFC Manning from the Army but was aware that
he could only take the issue to his supervisor so many times before it fell on deafears.
SSG Mitchel] will testify that he found an iPod on a bunk and looked through it to
determine the onner. When SSG Mitchel] viewed photos on the iPod. he noted that
PFC Manning was attending what looked like a gay pride parade. He will also testify
that he knew PFC Manning was suffering from extreme emotional issues. During the
deployment. he found PFC Manning curled in the lietai position in the Brigade
conference room, rocking hintselfhack and forth. SSG Mitchell will testify that he
was appointed as a Special Security Representative (SSR) on orders for the
The responsibilities for the SSR included reviewing security clearance requests.
initiating DEROGs recommending security clearances for personnel in the SE shop.
producing an SOP and security. While he was appointed as a SSR, he will
testify that he did not conduct those duties. SSG Mitchell will testify that he believes
the reason PFC Manning was allowed to remain in the military and did not receive the
help that he needed to deal with his issues was because SF Adkins had in?uence
over every action taken on personnel in the SE section and it was his decision not to
do anything.



29') SGT Rebecca M. Schwab. 21 1 London Road. Concord. New Hampshire 03301.

She will testify that she has known

PFC Manning since 2008. in the 2008 time frame, PFC Manning told her that he was

l2

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United States v. Manning: Article 32 Witness List

gay. She will testify that she believes that it was a huge issue for him and that he
could not be true to himself without the risk of losing his job. She will testify that she
believed that PFC Manning felt like he had no one to talk to. She believes that PFC
Manning was veiy intelligent and knew a lot about the World issues. She feels that
Manning had a few emotional issues and these issues made it difficult for him to
adjust to the military life.

an so?r Daniel w. Padgett. a Company. BSTB. l0"? Mountain Division. Fort
Drum. New York
supervisor of PFC Manning. He will testify that PFC Manning was a very good
analyst. who was good with computers but timid and not good at public speaking. He
will testify that he was assigned as the night shift NCOIC with then SPC Manning and
SPC Cooley. He was assigned this position even though he had not yet been to any
leadership schools. He will testify that there really was not anyone supervising the
night shift. He will also testify that when he needed to counsel PFC Manning he went
to SSG Balonek and asked him if he could counsel him. He will testify that he was
given permission to handle disciplinary actions for PFC Manning by SFC Adkins and
SSG Balonek. He will testify that he believed that he was in essence taking care of
other NCOs soldiers and that PFC Manning should ltave been counseled by SSG
Balonek. lle will testify that during one counseling session in December of2009.
PFC Manning grabbed the table and ?ipped it. He will testify that PFC Manning did
not approach him, but he was concerned when PFC Manning stepped towards the
weapons rack. He will testify that when PFC Manning stepped towards the weapons
rack. CW2 grabbed PFC Manning from behind and held him until he
calmed down. He will testify that although PFC Manning later apologized to him.
that he believes PFC Manning should have been removed from the after the
incident. Finally. he will testify that personnel in the T-SCIF were told that they
could listen to music CDs and watch movies in the T-SCIF.

31} SGT David A. Sadtler. 709 Ml Battalion. LLS. Army Garrison. Wieshaden. (USN)
He is a 35K signal intelligence

analyst. He will testify that he first met PFC Manning at a rotation at C. He will
testify that he believes that PFC Manning used to be a very happy and very hyper
individual, but his leadership wore him down. He will State that PFC Manning was
upset that no one cared about the mission. He also believed that the unit made it very
dif?cult on PFC. Manning as it seemed to outcast him as though they were trying to
get him out ofthe Army. He will testify that a lot of people had support from other
people. but that he didn't believe PFC Manning had any support from his chain of
command. He will testify that he recalls an incident when PFC Manning found a
report that apparently upset him. PFC Manning had found in the report that some
Iraqis or possibly some Moroccans were being arrested at a printing press facility.
SGT Sadtler will testify that attached to this report was some evidence which had
been collected: however, this information was in Arabic. He will testify that PFC
Manning had taken the time to have the document translated and tried to show the
translation to his superiors. He will testify that PFC Manning was very upset about

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United States v. Manning: Article 32 Witness List

the issue. He will testify that ifthere was a moment in which PFC Manning may have
snapped, this would have been it. SGT Sadtler will testify that everyone stonewalled
PFC Manning on the issue as no one thought it was a big deal. lie will testify that the
translation indicated that the individuals being arrested had printed documents that
were questioning whether the Iraqi govemment was embezzling public funds.

32) SGT Lorena Cooley. l-ll-IC BCT. Fort Drum. New York.
SGT Cooley will testify that she believes that PFC
Manning was picked on by other because they assumed that he was gay. She will
testify that SFC Adkins minimized a lot of things with PFC thning and tried to
keep things within the shop. SGT Cooley will testify that PF Manning should have
probably gotten help before they deployed. Finally, she will testin that Soldiers
brought in for music and movies and that this information was placed on the
computers.

33) SGT Sheri Walsh. - - -
SGT Walsh will testify that PFC Manning had
conversations with her about relationship issues and the fact he was having gender
identify issues. She will testify that PFC Manning spoke to her often about wanting
to get an Honorable Discharge so that he could keep his Top Secret Clearance after
his release from the Army. She will testify that she noticed that very few people
would talk to PFC Manning. She will testify that every time that she saw PC
Manning. he was by himself. She will testify that others would make fun of PFC
Manning?s size and the fact that they believed he was gay. One time SGT Walsh saw
PFC Manning coming out ofhis room: two soldiers pushed the door back into PFC
Manning?s face. She will testify that PFC Manning was obviously upset and
embarrassed about having the door pushed back into his face. She will testify that
instead of complaining about the conduct. PFC Manning simply said that he walked
into the door by accident. SGT Walsh will testify that she believes PliC Manning was
at a very confusing time in his life. She does not believe that the Army was a good fit
for him based upon where he was at in his life.

34' SPC .lihrleah W. Showman. Fort Drum. New Yerk 13602. -

Showman will testify about being aware of
PFC Manning's emotional issues. She will testify that she went to SFC Adkins and
recommended that PFC Manning not deploy due to his emotional issues. She will
testify that she believes that she was the first in the T-SC 1F to see the "Apache video?
which she found of her own accord in a network folder. She will testify that she
called CW2 Elucsman. SSG Balonek, and another soldier over to see the video. SPC
Showman will testity that over the next few days. several ofthe "i-Sle personnel
debated about whether the video showed a camera or a rocket propelled Grenade
(RPS) launcher and whether the actions of the Apache crew were appropriate under
the circumstances. SPC Showman will testify about her time as PFC Manning direct
supervisor and her multiple observations of PFC Manning both before and during the



I-?i



United States v- Manning: Article 32 Witness List

deployment that indicated to her PFC Manning was struggling both emotionally and
mentally.

35) Adrian Lamo. 3506 Carmichael, CA 95608.

Mr. Lanto will testify about the chat conversations that he had
with an individual alleged to have been PFC Manning between 21 May 2010 and 25
May 2010. He will also testify about the nature of the conversations and his
subsequent actions.

36) President Barack ()bama. The White House. [600 Avenue NW.
Washington, 20500.? The defense requests the presence of
President Obama in order to discuss the issue of Unlawful Command influence [UCl?t
Under Rule for Courts-Martial 405(e). the defense is entitled to explore the issue of
UCI. Under the Uniform Code ofMilitary Justice a superior officer in the
chain oi?command is prohibited from saying or doing anything that could influence
any decision by a subordinate in how to handle a military justice matter. As the
Commander in Chief. President Obama made improper comments on 21 April 20! 1.
when he decided to comment on PFC Manning and his case. On that date. he
responded to questions regarding PFC Manning?s alleged actions by concluding that
"We?re a nation of laws. We don"t let individuals make their own decisions about
how the laws operate. He Manning] broke the law." The comments by
President Obama are UCI. The defense intends to question President Obarna on the
nature of his discussions with members of the military regarding this case and
whether he has made any other statements that would either influence the prosecution
of this case or PFC Manning?s right to obtain a fair trial. in additional to the
issue. President Obama will testi?' about his t-?iews on the Afghanistan Ts
released by Wikileaks. He will testify that the leak did not reveal any issues that had
not already informed our public debate on Afghanistan. He will also testify that the
Afghanistan point to the some challenges that led him to conduct an
extensive review ot?the Afghanistan policy. President Obama will also testify about
the problem clever-classi?cation within the government. Specifically. that he
supported and signed into law the Reducing Over-Classi?cation Act on 7 October
2010. Additionally. he will testify that on his first full day in of?ce. 21 January 2009.
he issued two memoranda for the head of Executive Departments and Agencies that
were related to transparency in The first memorandum focused on the
administration of the Freedom of lnt?onnation Act (FOIA). and the second focused on
transparency and open goyemment. President Obama will testify that the
transparency memorandum he ?wrote committed the. administration to ?an
unprecedented level of openness" and to the establishment of ?a system of
transparency. public participation. and collaboration." President Obama will testiiy
that on 8 December 2009 his administration released a third memorandum an Open
Government Directive (060). The OGD included detailed instructions for
departments and agencies on how they are to "implement the principles of
transparency. participation. and collaboration." Finally, on 29 December 2009.
President Obama will testify that he issued Executive Order 13526 in an attempt to



United States v. Manning: Article 32 Witness List

improve the system for classifying, safeguarding, and declassifying national security
information. including the establishment of the National Declassification Center.

37) Former Secretary Robert Gates, Chancellor. College of William and Mary. PD. Box
8795. Williamsburg. VA 23187, Former Secretary Gates will testify
that the Afghanistan and Iraq SIGACT releases did not reveal any sensitive
intelligence sources or methods. He will also testify that the Department of Defense
could not point to anyone itt Afghanistan or [raq harmed due to the documents
released by Wikileaks. He will testify that the Afghanistan and Iraq are
simply ground-level ?eld reports that document dated activities which do not disclose
sensitive information or our sources and methods. Former Secretary Gates will also
testify that the initial public descriptions of the harnt to foreign policy due to the
publication of diplomatic cables were ?fairly significantly overwrought." He will also
testify that although the disclosures were embarrassing and awkward. they did not
represent signi?cant consequences to foreign policy. Finally. Former Secretary Gates
will testify that on 39 July 20 i 0. he directed the Defense intelligence Agency (DIA) to
lead a comprehensive review ot?the documents allegedly given to Wikileaks and to
coordinate under the lnfonnation Reviet-v Task Force (lRTii formerly TF 725) to
conduct a complete damage review. He will testify that the damage review con?rmed
that the alleged leaks represented a low to at best moderate risk to national security.
Speci?cally. that all of the information allegedly leaked was either dated. represented
low-level opinions. or was already commonly underStood and know dtte to previous
public disclosures.

38:) Secretary Hillary R. Clinton. US. Department of State. 2201 Street NW.
Washington, D.C. 20520_ Secretary Clinton will testify that she has
raised the issue of the disclosure ot?diplomatic cables with foreign leaders ?in order to
assure our colleagues that it will not in any way interfere with American diplomacy or
our commitment to continuing important work that is ongoing." Secretary Clinton
will also testify that she has not had any concerns expressed to her about whether any
nation would not continue to work with the United States or would not continue to
discuss important matters going due to the alleged leaks. As such. Secretary
Clinton will testify that although the leaks were embarrassing for the administration,
that she concurs with Former Secretary Gates? opinion that they did not represent
signi?cant consequences to foreign policy.

39) CPT James Kolky. l"l Cavalry Division. Fort Hood. Tesas. Brigade - -
- He will testify about his classi?cation review of
the three Apache gun videos that were sent to his Division by
Specifically. he will testify that the videos were not classi?ed at the time oftheir
alleged release. However. he will testify that he believes that videos should have been
classified. He will testify regarding his classi?cation detennination.



United States v. Manning: Article 32 Witness List

40) RADM Kevin M. Donegan. Director of Operations for United States Central
Command. 71 15. South Boundary Boulevard. MacDill Air Force Base. Florida
RADM Doncsa? conducted
classi?cation reviews on two PowerPoint slide presentations ofof?cial reports
originated by the PowerPoint presentations are the subject of
Speci?cation 10 ot?Charge Il. RADM Donegan will testify regarding his
classi?cation determination and his beliefot?the impact on national security due to
the release of the information.

Robert E. Beta, USCYBERCOM Chief Classi?cation Advisory Of?cer. the
government has not provided the defense with contact information for Mr. Beta. Mr.
Beta will testify about his classi?cation determination concerning the alleged chat
logs between Mr. Lame and PFC Bradley Manning. Speci?cally. he will testify about
his classi?cation assessment of information discussed in the alleged chat logs. Mr.
Betz believes the limited discussion caused "serious damage" to national security.

42] LtGen Robert E. Schmidle. Deputy Commander U.S. Cyber Command. -
Schmidle. as the Original Classi?cation
Authority (OCA) over the discussed by Mr. Beta. l.tGen Schmidle will
testify that he concurs with the classi?cation determination and impact statements
made by Mr. Beta. The defense would like to question him regarding his declaration
and the basis for his belief.

43} VADM Robert S. Harward, USCENTCOM. Deputy Commander. MacDill Air
Force Base. Florida 3362}, t_t?_snM
liatward will testify concerning his classi?cation review and classi?cation
concerning the CIDNE Afghanistan Events. CIDNE Iraq Events. other
brie?ngs and the BE22 video. Specifically, VADM l-larward will testify
concerning his classi?cation determination and his beliet?ot?the impact on national
security from having this information released to the public.

44) Patrick F. Kennedy. Under Seeretary of State for Management, the defense does not
have contact information for Mr. Kennedy. Mr. Kennedy will testify concerning his
review of the disclosure ot?Department of State Diplomatic Cables stored within the
Net-Centric Diplomacy server and part Mr. Ketmedy will testify
concerning his classi?cation determination and the impact of the release of'thc
information on national security.

45) RADM David B. Woods. Commander. Joint Task Force Guantanamo (J TF-
RADM Woods will testify
concerning his review ot?the disclosure of ?re documents. totaling twenty-two pages.
RADM Woods will testify concerning his classification detennination and the impact
of the release of the intonnation on national security.



United States v. Manning: Article 32 Witness List

46') CAPT Kevin D. Moore. Walter Reed National Military Medical enter.?
will testify that during a meeting in early
January ofEtll l, the Security atta ton Commander in charge of the Quantico Brig.
Col. Robert Oltman. clearly stated to the Brig Staff that will not have anything
happen to Manning on my So. nothing is going to He won?t be
able to hurt himself and he won?t be able to get away, and our way of making sure of
that is that is he. will remain on Maximum Custody and POI indefinitely." He will
testify that one ofthe other Brig Capt. William Hoeter then said "You
know Sir, I am concerned because if you are going to do that. maybe you want to call
it something else because it is not based upon anything from behavioral health." In
response. Capt. Moore will testify that Col. Oltman said "We will do whatever we
want to do. You make a recommendation and then I have to make a decision based
upon everything else." Capt. Moore will testify that Capt. I-Ioeter then said. ?Well
then don?t say it is based upon mental health. You can say it is Maximum Custody.
and just don?t put that we [behavioral health] are somehow int-'olyed in this." Col.
Oltman replied. ?Well. that is what we are going to do." Capt. Moore will testify that
he spoke with others at the Brig to see if they knew why the Brig was so heavy
handed on PFC Manning. He will testify that others at the Brig told him that they
have never seen anything like this before. Capt. Moore will testify that others told
him that they were afraid to speak out about the situation given the concern of what
would happen as a result of any complaint about PFC Manning?s treatment.



er Walter Reed National Military Medical Center.
will testify that neither the Quantico Brig

. nor the Security Battalion Commander. Co].
Robert Olttnan. gave him any reasons for maintaining the Prevention of Injury
precautions other than stating it was for PFC Manning?s safety. He will testify that
Col. Oltman intimated that he was receiving instruction form a higher authority on the
matter but did not say who was providing this direction. Capt. I-Iocter will testify that
he knew that the higher base authorities had frequent (sometimes weeklyl meetings to
discuss PFC Manning. Capt. lloeter will testify that he gave weekly status reports
stating that he felt the POI precautions were unnecessary. Capt. Ilueter will testify
that he recalls a meeting with Col. Oltman where he stated that PFC. Manning would
remain in his current status Maximum Custody and POI unless and until he received
instructions from higher authority to the contrary. Capt. Hooter cannot recall Col.
Oltman?s exact words. but he does recall that Col. Oltman made it clear that nothing
would change with PFC Manning regardless ofhis behavior or the recommendations
ofhehavioral health.




48) inmate Christopher Whitfield. Joint Regional Correction Facility Fort
Leavenworth. Kansas. Inmate Whit?eld will testify that he was taken to the pretrial
section at the JRCF and met with PFC Manning. He will testify that he explained the
purpose of his visit and asked PFC Manning who the
.IRCF. PFC Manning allegedly responded with, sold information to Wikileaks."



United States v. Manning: Article 32 Witness List

Shortly after this alieged statement, the guards realized that Inmate Whit?eld should

not have been in the pretrial area.

DAVID E. COOMBS
Civilian Defense Counsel



UNCLASSIFIEWLES

DEPARTMENT OF THE ARMY
u.s. ARMY MILITARY DISTRICT oF wasamoron
210 A STREET
FORT LESLEY J. DC 20319-5013

REPLY TO
ATTENTION OF



2 December 201 1

MEMORANDUM FOR LTC Paul Almanza, 150th Judge Advocate General Detachment, Legal
Support Organization, MG Albert C. Lieber USAR Center. 6901 Telegraph Road. Alexandria,
VA 22310

SUBJECT: Requested Evidence List for Article 32 Investigation - United States v. PFC Bradlev
Mannino



l. The United States requests you consider the following evidence during the Article 32
proceeding in the above-referenced case:

3. Charged Documents.

(1) Batch #1 (00376954 - 00377572). See Enclosure 1.
(2) Batch #2 (00377626 - 00377675). See Enclosure 1.
(3) Batch #3 (00377845 - 00378140). See Enclosure 1.

h. Classi?cation Reviews.

(1) Classi?cation Review (CENTCOM) (00376871 00376873).
(2) Classi?cation Review (DISA) (00376890 - 00376890).

(3) Classi?cation Review (CYBERCOM) (00376875 - 00376878).
(4) Classi?cation Review (CENTCOM) (00376879 00376902).
(5) Classi?cation Review (DDS) (00376903 00376953).

(6) Classi?cation Review (Other) (00378148 - 00378175).

(7) Classi?cation Review (SOUTHCOM) (00378646 00378649).

c. Accused?s Personnel Records.

(1) PFC Bradley E. Manning?s OMPF (00000116 - 00000164).
(2) PFC Bradley E. Manning?s ERB (00000006).
(3) Security Clearance Documents.

(at) Batch #1(00015617 00015619).

(13) Batch #2 (00022898 00022913).

Batch #3 (00022947 - 00022949).

Batch #4 (00036801 00036802).

(1. Accused?s Training.

(1) Advanced Individual Training (AIT) Training.

UNCLASSIFIEDIILES
1111!. one. EXHIBIT

UNCLASSIFIEIWIES

ANJA-CL
SUBJECT: Requested Evidence List for Article 32 Investigation - United States 17. PFC Bradley

Manning

Batch #1 (00001052 - 00011344).
(13) Batch #2 (0001 1649 00012569).

(2) The Accused?s AIT Corrective Training Slideshow (00125314 - 00125316).

(3) The Accused's Information Assurance Training.
IA Exam (00375763?00375771).
(13) IA Training Requirement (00375772).
(0) IA Virtual Training (00375773).
(11) Virtual Training #2 (00375774).
(12) Test Results (00022348).

e. Law Enforcement Investigations.
(1) CID Case File.

Batch #1 (00000179 00000376).
(6) Batch #2 (00000402 4 0000041 1).
Batch #3 (00021364 - 00025526).
(6) Batch #4 (00026079 - 00026082).
(3) Batch #5 (00026356 00036786).
(1) Batch #6 (00045302 - 00046073).
Batch #7 (00375183 - 00375724).
Batch #8 (00378219 - 00378623).
(1) Batch #9 (00378626 - 00378645).
Batch #10 (00407991 ?00408088).

(2) CID Forensic Reports.

10th Mountain Shares (00046074 - 00046451).

(6) Army Intelligence Report (00046452 00046566).

(0) CENTAUR Logs (00046567 00052616).

(01) CENTCOM Server (00052617 - 00054311).

CIDNE Files (00054312 - 00054319).

(0 Department of State Files (00054320 - 00119042).

SOUTHCOM Comparison (00375008 - 003751 15).

Intelink Logs (00119043 00375129).

Lamo Chats (00124107 - 00124282).

0) Manning?s Personal Computer (00124283 00125269).

(14) Manning?s External Hard Drive (00125270 - 00125318).

(I) Manning?s SD Card (00125319 - 00199473).

(to) Computers 148.17.172.115 and 22.225.28.54 (00199474 00199485).
(11) SIPRNET Computer 22.225.29.185 (00199486 - 00199493).
(0) SIPRNET Computer 22.225.41.40 (00199494 4 00199510).

2
UNCLASSIFIEDIHJES w! ENCLOSURES)


ANJA-CL

SUBJECT: Requested Evidence List for Article 32 Investigation United States v. PFC Bradley

Manning

Manning?s CD (00199511 - 00199523).

NIPRNET Computer 144.107.17.139 (00199524 - 00199555).

NIPRNET Computer 144.107.19 (00199556 - 00211019).

(5) NIPRNET Computer 147.198.178.143 (0021 1020 - 0021 1027').

(I) SIPRNET Computer 22.225.23.216 (002] 1028 - 0021 1036).

SIPRNET Computer 22.225.41.22 (00211037 - 00243945) (00243882

003 74370).

OGA Documents (00374371 00375007).

f. Military Intelligence Investigations.

(1)

(3)

Investigation

(3) Batch #1 (00044865 00045301).
Batch #2 (00375173 - 00375182).
Batch #3 (00377582 00377625).
(Cl) Batch #4 (00377748 - 00377844).
Batch #5 (00378203 00378218).
Investigation

Batch #1 (00375130 - 00375172).
Batch #2 (00377573 00377581).
Batch #3 (00377736 9 00377747).
Batch #4 (00378177 - 00378202}.
Investigation #3 (00377676 - 00377735).

g. Administrative Investigations.

(1)

(3)

AR 380-5 Investigation (00000663 00000771).
USF-I AR 15-6 Investigation (00012721 - 00012903).
SecArmy AR 15?6 Investigation.

(3) Batch #1 (00013162 - 00020152).

Batch #2 (00036787 - 00036788).

h. Enemv Possession of WikiLealgs Material.

(1.)


(4)

Al-Qa'ida Recruiting Video (00408202 - 00408236).

Al-Qa'ida in the Arabian Peninsula Magazine (00012570 0001271 1).
Enemy Number 1 Possession Report. See Enclosure 2.

Enemy Number 2 Possession Report. See Enclosure 2.

i. Miscellaneous Documents.


(21

DOGS-A Logan Banner (00376856 - 003768.56).
C3 Document (00378141 - 00378147).

3

UNCLASSIFIEDHLES (SECRETHOBCONINOFORN w! ENCLOSURES)

UNCLASSIFIEDWLES (SECRETIIORCONINOFORN

ANJA-CL
SUBJECT: Requested Evidence List for Article 32 Investigation - United States v. PFC Bradlev

Manning

j. Common References.

(1) United States Code.
18 USC 793(e).
13 USC 64}.
18 USC
(2) Executive Orders.
(3.) Executive Order 12958.
Executive Order 13292.
Executive Order 13526.
(3) Regulations.
AR 380-5 (00001403 00001718).
AR 25-2 (00038974 - 00039076).
CENTCOM Regulation 25-206 {00016128 00016229).
(4) Public Law 107-40, The Authorization for Use of Military Force, 18 Sep 01.

2. If necessary, the prosecution may request you consider additional evidence which is relevant.
and not cumulative, to the investigation.




2 Encls ASHDEN FEIN
1. Charged Documents CPT, A
2. Additional Classi?ed Evidence Trial Counsel

4
UNCLASSIFIEDHLES w! ENCLOSURES)

DE PARTM ENT OF THE ARMY
us. ARMY MILITARY DISTRICT or WASHINGTON
210 A STREET
FORT LESLEY mounts, Dc 20319?5313

RE FL 1? 1?0
ATTENTION OF



A NJA-CL 4 December 20] 1

MEMORANDUM FOR Paul Almanza. 150th Judge Advocate General Detachment? Legal
Support Organization. MG Albert C. Lieber. USAR Center. 6901 Telegraph Road. Alexandria.
VA 22310

Response to Defense Request to Close Article 32 Hearing United States v. PFC
Bradley Manning

1. PURPOSE. The prosecution requests you deny the defense request to close the Article 32
hearing to the public when certain unclassi?ed information relevant to the case is discussed.
Closure of the hearing for those unclassi?ed portions cited by the defense is a drastic remedy and
reasonable alternatives to closure are available in this case and in all courts?martial to protect the
accused?s right to a fair trial.

2. LA W. "Article 3'2 investigations are public hearings and should remain open to the public
whenever possible." Rule for Courts-Martial 405(hlt3} discussion. The investigating
of?cer (101 may close the Article 32 proceeding if ll "an overriding interest exists that
outweighs the value of an open proceeding" and (2) ?no lesser methods short of closing the
proceeding can be used to protect the overriding interest." Id. 1f proper, closure must be
?narrowly tailored to achieve the overriding interest that justi?ed the closure.? Id. Closure must
be determined on a ?case-by?case, tvitness-by?witness. circumstance?by?circumstance analysis.?
Id. If the IQ ?nds that closing the hearing is necessary. the 10 ?must make speci?c ?ndings of
fact in writing that support the closure? and ?include {those ?ndings] in the Article 32
investigating of?cer's report.? hi. Examples in RCM 405ihlt3) include protecting child
Witnesses, sexual assault victims. and classified materials. (if. The analysis of RCM 405thlt3t
refers to RCM S?otb?ttzt for additional examples.

.5. ARGUMENT.

a. The facts and law do not justify closing the proceeding to the public for those
unclassified portions cited by the defense. Courts agree that ?la]bsent ?cause that outweighs the
value ot?openness.? the military aecased is. . .entitled to a public Article 3 2 investigative
hearing." ABC. inc. v. Powell. 47 MJ. 363. 365. (C.A.A.F. 1997') (citing Press-Enterprise Co. v.
Superior Court Riverside County. 464 US. 501. 509 {1984)}. The accused is not
the only party that bene?ts from the right to a public hearing; ?the press [and public at large]
enjoy? the same right and [have] standing to complain ifaccess is denied." hi; see also US.
Const. amend. VI (the accused has a Sixth Amendment ci'institutional right to a public trial); see
also Globe! Newspaper Co. v. Superior ofMossminrsetts. 457 US. l-?W 1982) the public
has a First Amendment constitutional right to be present at criminal trials].

ltt?t. arcs. EXHIBIT


Response to Defense Request to Close Article 32 Hearing united States v. PFC

Bradley Manning

b. The defense cites the accused's right to a fair trial as an overriding interestjustifying
closure and speci?cally requests closure ?to prevent the publication ot'information that may
improperly in?uence potential panel members." If this case is referred to court-martial. there are
specific processes designed to protect the accused?s right to a fair trial at all stages that are
integral to the military justice system, including a thorough voir dire of panel members. motions
practice to exclude inadmissible evidence. and jury instructions to limit what evidence may he
considered by the panel. See RC 806iblt2) discussion {there are ?altemative means of
protecting the proceeding from [the] harmful effects of publicity. including a thorough voir
dire"l. Defense counsel. the prosecution. and the military judge will have the opportunity to
explore the effect ofpublieity on the panel members prior to trial. and the militaryjudge may
instruct the panel during trial as well.

c. Additionally. the defense's argument that publication of information may improperly
in?uence potential panel members contradicts its own use of a public blog to disseminate, among
other things. existing defense requests. its proposed witness list. and Twitter updates. The
defense?s stated purpose for these publications is ?to ensure that accurate and timely information
[of this case] is made available to the public."I The defense?s own blog includes a posting titled
"Public and Media Access to Article acknowledging the public?s interest in the upcoming
Article 32 investigation. The military justice system is designed to protect the accused?s right to
a fair trial and the public?s right to an open hearing. Therefore. the 10 should be reluctant to
close the Article 32 hearing solely to ensure that prospective panel members are not tainted by
outside influences when multiple avenues exist to guard against any prejudice towards the
accused. See Dem-er Post Corp. United States. 2005 WL 65 9929 (A. Ct. Crim. App. 2005}.

4. CONCLUSION. The prosecution requests you deny the defense. request and protect the
public's right to a public Article 32 hearing. Excluding the public for those unclassified portions
cited by the. defense is unnecessary to protect the accused's right to a fair trial where fundamental
processes of the military justice. system serve as a means of protecting the proceedings from any
potential effects of publicity and ensuring the accused's right to a fair trial.

The point of contact for this memorandum is the undersigned at-

"r?isr-tDEN shits
CPT. .IA
Trial Counsel

CF:
Defense Counsel



1 See Bloc of available (If http?ww'tv

IN THE UNITED STATES ARMY
FIRST JUDICIAL CIRCUIT

UNITED STATES
SEALED DEFENSE RESPONSE
v. T0 GOVERNMENTS 405(h)(3)
FILING
MANNING. Bradleyr E.. PFC
US. Anny.
Headquarters and Headquarters Company. US.
Army Garrison. Joint Base Myer-Henderson Hall. DATED: 4 December 201 1
Fort Myer. VA 222] 1
RELIEF SOUGHT

1. PF Bradley E. Manning, by and through counsel. under a request that this motion be scaled
pursuant to R.C.M. 1103A. moves the Investigating Of?cer. pursuant to R.C.M 405thit3). to
direct the Government to requesl a closed hearing anytime it anticipates referencing the specified
information in this motion. whether through the questioning of a witness or in argument.
Additionally. the Defense requests that the Investigating Officer order the Government to
instruct its witnesses not to reference the speci?ed conduct during any open hearing.

BURDEN OF PERSIEASION AND BURDEN OF PROOF

2. As the moving party. the Defense has the burden of persuasion. 905(c)(2). The
burden of proof is by a preponderance ofthe evidence. ROM. 905(c)(l

EELS.

3. 28 November 201 1, the Defense filed a request for a limited closure ofthe hearing under
R.C.M. 405(h)t3). The Government responded to this motion on 4 December 201 I.

WITNESSESIEVIDENCE



4. The Defense does not request any witnesses be produced for this motion. The Defense
respectfully requests the lnvesugating Officer to consider the following evidence in support of
the Defense?s motion.

a. DA Form 2823, Jihrleah W. Showman. 000137] 1-14

b. DA Form 2823, CW2 Joshua D. Ehresman. 00022l68-69

not. area. EXHIBIT 36

c. Agent Investigative Report. SA Troy M. Bettencourt. {10045916.
d. DA Form 2823, SPC Roderick Lewis Handy, 0002192932.
e. Interview Memorandum for Record, SFC (Retired) Brian Madrid. 0001326869.

f. Army News Release #1 1-39. dated 21 November 201 1.

LEGAL AUTHORITY AND ARGUMENT

5. The Defense reasserts the position re?ected in its earlier ?led motion. 1-1owever. the Defense
would like to specifically respond to matters raised by the Government in its ?ling.

6. The Government cites cases which refer to the "right" or "entitlement" of the accused to a
public Article 32 hearing. See Response to Defense Request to Close Article Hearing at
paras. St and The Government appears to construe the cases to mean that the right of
the accused to a public Article 32 hearing corresponds to a right of the Government to mandate a
public Article 32 hearing. in other words. the Government eon?ates the right of the accused to a
hearing in a public forum with a requirement that the hearing be in a public forum
notwithstanding the accused?s position on the issue.

7. Notably. in all ofthe cases cited by the Government. it was the prosecution that was
attempting to close the Article 32 (or other) hearing while the accused was attempting to assert
the right to a public hearing. Sec, Giobe Newspaper Company v. Superior Conrrjor the
Colony ofNor?rik. 457' .S. 596. 606 (1932) (state ?attempt[ingj to deny the. right of [public]
access? to criminal hearing); ABC, Inc. v. Powell, 47 3.4.1. 363, 363 (C.A.A.F. 1997i (accused
seeking writ of mandamus requesting that Article 32 hearing ?be Opened to the press and public?
over Government?s objection): Denver Post Corp. v. United States. 2005 WL 6519929 (Army
Ct. Crim. App.) (investigating of?cer closing the hearing in response to Government request).
Indeed, the case law consistently refers to the Government?s "heavy burden? in establishing that
a hearing should be closed to the public. See, United States v. Grands-tn. 2 116. 122
(C.M.A. (referring to the ?heavy burden" of the prosecution in establishing that a
classi?ed hearing should be closed to the public]. Here, it is the accused who is asserting his
right to close parts of the hearing in order to preserve the integrity of thejudicial process and to
ensure his right to a fair trial. The Government has not cited one case where the Defense
attempted to have parts of the Article 32 closed. while the Government championed the
accused?s "right" to an Open hearing.

8. While the Defense acknowledges the general right of the public to attend criminal
proceedings. such right is not unfettered and must be balanced by the right of the accused to a
fair trial. The Defense thus its position in the original Sealed Defense Motion for a
Closed Hearing Under R.C.M. Speci?cally, the Defense maintains that the public's
interest in ?ve discrete pieces of evidence, which may or may not be admissible if the case
proceeds to trial. is not suf?ciently ovarwhelming to override the accused's right to a fair trial.

9. The Defense believes it is important that this case be tried as openly as is possible. consistent
with the rights ofthe accused. In that spirit. the Defense has posted on its law firm website
redacted court filings after having them reviewed by its security experts. The Government
appears to insinuate that such one-sided postings of Defense documents are prejudicial as they
may ?improperly in?uence potential panel members." See Response to Defense Request to
Close Article Hearing at para. The Defense would very much like to post publicly any
and all Government motions and ?lings in this case. The Defense has not done so to date due to
the Government consistently marking its documents with or Of?cial Use Only" or as ?Defense
Counsel Copy." Under either marking. it is the Defensels understanding. consistent with the
convening authority?s protective order. that it is not permitted to disclose these items. If this is
not the position ofthc Government. the Defense will more than happily post publicly all relevant
redacted filings in this case.

10. Finally. the Government completely ntischaracterizes the Defense?s posting entitled, ?Public
and Media Access to the Article 32.? The posting merely directs public inquiries, consistent
with the Army's News Release. to the LLS. Army Military District of Washington Public. Affairs
Of?ce. See Attachment A. The posting reads. in its totality, as follows: "All inquiries regarding
access to the upcoming Article 32 hearing should be directed to the US. Army Military District
of Washington Public Affairs Office at or (202) o85-464S.?

CONCLUSION

1. Based on the above. the Defense requests that the Investigating Of?cer order the
Government to request a closure ofthe hearing whenever it anticipates referencing the above
information either through the questioning of a witness or through argument. Additionally, the
Defense requests that the Investigating Of?cer order the Government to instruct its witnesses not
to reference the above referenced information during any open session ofthe Article 32 hearing
without ?rst alerting the Investigating Of?cer. The witness should simply state that the question
would require a response that must be made during a closed hearing. At that time, the hearing
should be closed to the public and the wimess permitted to respond. Once the witness has
provided his or her answer, the hearing can again be opened to the public.





L.
DAVID EDWARD . MISS
Civilian Defense Counsel



DEPARTMENT OF THE ARMY
US. ARMY MILITARY DISTRICT OF WASHINGTON
210 A STREET
FORT LESLEY J. MCMAIH, DC 203195013

TU
ATTE DF



ANJA-CL 5 December 201 1

MEMORANDUM FOR LTC Paul Almanza, 150th Judge Advocate General Detachment, Legal
Support Organization, MG Albert C. Lieber, USAR Center, 6901 Telegraph Road, Alexandria.

VA 22310

SUBJECT: Response to Defense Notice Under MRE 505(h)(3} United States v. PFC Bradlev
Manning

1. Under para. the defense alleges it ?intends to discuss [the] classi?cation determination"
of the Apache video. However, the Apache video is not classi?ed. Thus, norice is not required

under MRE 505(h)(3).

2. The point of contact for this memorandum is the undersigned at?



3/ .
{If
planner: FEIN
car, JA
Trial Counsel

CF:
Defense Counsel

m. arse. was? '37



DEPARTMENT OF THE ARMY
U.S. ARMY MILITARY DISTRICT OF WASHINGTON
210 A STREET
FORT LESLEY J. MCNAIFI, DC 203195013

REPLY TO
ATTENTION 0F



7 December 2011

MEMORANDUM FOR LTC Paul Almanza, 150th Judge Advocate General Detachment. Legal
Support Organization, MG Albert C. Lieber USAR Center. 6901 Telegraph Road, Alexandria,

VA 22310

SUBJECT: Additional Requested Evidence List for Article 32 investigation - United States v.
PFC Bradlev Manning

1. in addition to the Requested Evidence List for Article 32 investigation, dated 2 December
2011, the United States requests you consider the following evidence during the Article 32
proceeding in the above-referenced case;

3. Classi?cation Reviews.
Classi?cation Review (OGA) (00410623 - 00410634).
6. Accused?s Personnel Records.

Security Clearance Documents. Batch #5 (00000430 - 00000450).

c. Accused ?5 Training.

The Accused?s Information Assurance Training.
IA Awareness-October Training Disk (00409673).
IA Awareness-October 2009-v8_0 Training Disk (00409674).
Phishing Awareness-April 2008-v1_0 Training Disk (00409675).
(Cl) I?ll-October 2007-v1_0 Training Disk (00409676).

(2) The Accused Pro-Deployment Training.
Iraq Overview PowerPoint (00409722 00409740).
Afghanistan Overview PowerPoint (00409741 . 00409780).

Classi?ed Information Systems. CIDNE Export Screenshots (00410665
00410667).

d. Law Enforcement Investigations.

CID Case File.
1 1 Batch #11 (00409673 - 00409678).
Batch #12 (00409781 00410553).

UNCLASSIFIEDHLES
Hit. em. Hillan 3?

ANJA -CL





SUBJECT: Additional Requested Evidence List for Article 32 Investigation - United States v.
PFC Bradley Manning



Batch #13 (00410635 - 00410649).

e. Enemv Possession of WikiLeaks Material.

Enemy Number 1 Possession Evidence.

HR 6 039 0563 11 (Redacted) (00410660 00410664).
Metadata Display (00410658 00410659).

Forensically Recovered Material (00410654 - 00410657).


(2)
(3)

f. Miscellaneous Documents.

(1)

(2)
00410571)
00410583)

00410593).

(3)

The Accused?s Military Intelligence Work Product.

(4)

(C)

(B)
(0


(0

Storyboard (00410603 - 00410606).

Range Storyboard (00410607 - 00410609).

11R 6 068 4579 10 (00410610 4 00410612).

SIPRNET Email, dated 100112 (00410613 - 00410614).
SIPRNET Email, dated 100224 (00410615).

SIPRNET Email, dated 100308 (004106 I 6).

SIPRNET Email, dated 100419 (00410617).

SIPRNET Email, dated 100425 (00410618).

SIPRNET Email, dated 091130 (00410600 00410602).

WikiLeaks Background.

(3)

(C)



(.0


WikiLeaks Most Wanted Leaks of 2009, dated 090830 (00410561
WikiLeaks Most Wanted Leaks of 2009, dated 091105 (00410572 -
WikiLeaks Most Wanted Leaks of 2009, dated 100522 (00410584
Afghanistan War Logs Posted by WikiLeaks (00410668 - 00410670).
Tweet, dated 100507 (00410594 - 00410595).

Tweet, dated 100103 (00410596 00410597).
Tweet, dated 100216 (00410598 - 00410599).

The Accused?s Other Documents.



(C)


(0

(11)


WikiLeaks Contact Information File (00409721).

CIDNE Types File (00409719).

Written Note Related to GAL Extraction (00409720).

Sereenshot of Google Search for GAL Extraction Macro (00409679).
Early Bird Article, dated 20100318 (00409686 00409718).

Mac Quickstart Bar Screenshot (00409630).

Mac Password Keychain Screenshot (00409683).

Email dated 100520 (00409681).

Email dated 100520 (00409682).







UNCIJASSIFIEDMJES
ANJA-CL
SUBJECT: Additional Requested Evidence List for Article 32 Investigation United States v.
PFC Bradlev Manning

Email, dated 100408 (00409684).
Email, dated 100410 (00409685).
(1) IIR 5 332 0069 10 (00410619 - 00410622).

(4) Defense Information Systems Agency Documents.
(3) DISA Trickler Report (00410653).
DISA Trickier Report End 1 (00410650).
to) DISA Trickler Report Encl 3 (00410651).

(5) Other.
CIDNE Data on the Internet (00410554).
GAL Extraction Instructions Screenshot (00410555).
CENTCOM Sharepoint Architecture (00410635).
NCD Valuation Documents (00410556 - 00410560).

2. If necessary, the prosecution may request you consider additional evidence which is relevant,
and not cumulative, to the investigation.

f- .


f,
if
ASHDEN FEIN
CPT, IA
Trial Counsel

CF:
Defense Counsel

3


FOR OFFICIAL USE ONLY

DEPARTMENT OF THE ARMY
US. ARMY MILITARY DISTRICT OF WASHINGTON
210 A STREET
FDHT LESLEV J. MOHAIR. DC 20315-5013

1 T0
ATTENTION 0F



ANJA-CL 7 December 2011

MEMORANDUM FOR LTC Paul Almanza. lSOth Judge Advocate General Detachment, Legal
Support Organization. MG Albert C. Lieber. USAR Center. 6901 Telegraph Road, Alexandria.
VA 22310

SUBJECT: Response to Defense Request fer Article 32 Witnesses United States v. PFC
Bradley Manning

1. PURPOSE. The prosecution responds to the Defense Request for Article 32 Witnesses as
follows and, where applicable, requests you find the witnesses not reasonably available or the
defense?s proffered testimony cumulative or not relevant to the Article 32 investigation.

2. LAW. ?[A]ny witness whose testimony would be relevant to the investigation and not
cumulative. shall be produced if reasonably available." Manual for Courts?Martial. Rule fer
Courts-Martial (RCM) 405(g}(l see also RCM 405(a) discussion (the primary objective of the
investigation is ?to inquire into the truth of the matters set forth in the charges, [to verify] the
form of the charges, and to secure information on which to determine what disposition should be

made of the case").
3. RESPONSES.
a. SA Toni Graham. The United States does not object to this witness.
b. SA Mark Mander. The United States does not object to this witness.
c. SA calder Robertson. The United States does not object to this witness.
d. SA David Shaver. The United States does not object to this witness.
e. SA Charles Ames. The United States objects to the defense request for this witness.

The defense?s proffered testimony is cumulative with other law enforcement witnesses, namely
SA Toni Graham, SA Mark Mander, SA Calder Robertson, SA David Shaver, SA Alfred

Williamson. and SA Troy Bettencourt.
f. SA Alfred Williamson. The United States does not object to this witness.

g. SA Troy Bettencourt. The United States does not object to this witness.

FOR OFFICIAL USE ONLY
ll?. DFCR. EXHISIT 30f

FOR OFFICIAL USE ONLY
ANJA-CL
SUBJECT: Response to Defense Request for Article 32 Witnesses United States v. PFC

Bradley Manning

h. SA Ronald Rock. The United States objects to the defense request for this witness. The
defense?s proffered testimony is cumulative with other law enforcement witnesses, namely SA
Toni Graham. SA Mark Mander, SA Calder Robertson, SA David Shaver, SA Alfred
Williamson, and SA Troy Betteneourt. This case is a joint investigation and the above CID
agents can testify about this matter.

i. SA Patrick Wheeler. The United States objects to the defense request for this witness.
The defense?s proffered testimony is cumulative with other law enforcement witnesses, namely
SA Toni Graham, SA Mark Mander, SA Calder Robertson, SA David Shaver, SA Alfred
Williamson, and SA Troy Bettencourt. This case is ajoint investigation and the above C1D
agents can testify about this matter.

j. CPT Martin Leibman. The United States objects to the defense request for this witness.
The defense?s proffered testimony regarding PFC Manning?s mental status and MEDCOM Form
4038 is not relevant to the Article 32 investigation and will only serve to distract from the
relevant issues. In addition, en 22 April 20l 1, an RCM 7015 board concluded that Manning
did not have a severe mental disease or defect at the time of the alleged criminal conduct that
resulted in him being unable to appreciate the nature and quality or wrongfulness of his
conduct.? See RCM 405(a) discussion (the primary objective of the investigation is ?to inquire
into the truth of the matters set forth in the charges, [to verify] the form of the charges, and to
secure information on which to determine what disposition should be made of the case?}. The
alleged testimony of CPT Leibman is outside the scope of the Article 32 investigation. Even if
found relevant, the proffered testimony is cumulative with testimony from witnesses who
worked with PFC Manning, namely CPT Lim. CPT Fulton, W01 Balonek. SFC Adkins, SGT
Madaras, and Ms. Showman.

k. CPT Michael Worsley. The United States objects to the defense request for this
witness. The defense?s proffered testimony regarding PFC Manning's mental status and his
alleged communications with SFC Adkins, MAJ Clausen, and MSG Usbeck is not relevant to the
Article 32 investigation and will only serve to distract from the relevant issues. In addition, on
22 April 201 1, an RCM 706 board concluded that Manning did not have a severe mental
disease or defect at the time of the alleged criminal conduct that resulted in him being unable to
appreciate the nature and quality or wrongfulness of his conduct." See RCM 405(a) discussion
(the primary objective of the investigation is "to inquire into the truth of the matters set forth in
the charges, [to verify] the form of the charges, and to secure information on which to determine
what disposition should be made of the case"). The alleged testimony of CPT is outside
the scope of the Article 32 investigation. Even if found relevant, the proffered testimony is
cumulative with testimony from witnesses who worked with PFC Manning, namely CPT Lim,
CPT Fulton, W01 Balonek, SFC Adkins, SGT Madaras, and Ms. Showman.

l. CPT Edan Critchfield. The United States objects to the defense request for this witness.
The defense?s proffered testimony regarding PFC Manning?s mental status, his alleged
recommendation, his alleged training on Soldier suitability for access to classi?ed information,

2
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SUBJECT: Response to Defense Request for Article 32 Witnesses United States v. PFC

Bradlev Manning

and the alleged MEDCOM Form 4038 is not relevant to the Article 32 investigation and will
only serve to distract from the relevant issues. In addition, on 22 April 20! 1, an RCM 706 board
concluded that Manning did not have a severe mental disease or defect at the time of the
alleged criminal conduct that resulted in him being unable to appreciate the nature and quality or
wrongfulness of his conduct.? See RCM 405m) discussion (the primary objective of the
investigation is ?to inquire into the truth of the matters set forth in the charges, [to verify] the
form of the charges, and to secure information on which to determine what disposition should be
made of the case"). The alleged teStimony of CPT Critch?eld is outside the scope of the Article
32 investigation. Even if found relevant, the proffered testimony is cumulative with testimony
from witnesses who worked with PFC Manning, namely CPT Lim, CPT Fulton, Balonek,
SFC Adkins, SGT Madaras, and Ms. Showman.

m. COL David Miller. The United States objects to the defense request for this witness.
The defense?s proffered testimony regarding the commands decision to deploy PFC Manning
and his opinion of Clausen, MAJ Dreher, and MSG Adkins is not relevant to the Article 32
investigation and will only serve to distract from the relevant issues. See RCM 405ta) discussion
(the primary objective of the investigation is "to inquire into the truth of the matters set forth in
the charges. [to verify] the form of the charges, and to secure information on which to determine
what disposition should be made of the case"). The alleged testimony of COL Miller is outside
the scope of the Article 32 investigation. Even if found relevant. the proffered testimony is
cumulative with other witnesses in the chain of command, namely CPT Lim, CPT Fulton, W01
Balonek, SFC Adkins, and Ms. Showman.

n. LTC Brian Kerns. The United States objects to the defense request for this witness.
The defense?s proffered testimony regarding his opinion of Clausen and MSG Adkins and
the alleged operations of the working group is not relevant to the Article 32 investigation and
will only serve to distract from the relevant issues. See RCM 405(a) discussion {the primary
objective of the investigation is ?to inquire into the truth of the matters set forth in the charges,
[to verify] the form of the charges, and to secure information on which to determine what
disposition should be made of the ease"). The alleged testimony of LTC Kerns is outside the
scope of the Article 32 investigation. Even if found relevant, the proffered testimony is
cumulative with other witnesses in the chain of command, namely CPT Lim, CPT Fulton, W01

Balonek, SFC Adkins, and Ms. Showman.

0. Elijah Dreher. The United States objects to the defense request for this witness.
The defense?s proffered testimony regarding his alleged ignorance of issues relating to PFC
Manning is not relevant to the Article 32 investigation and will only serve to distract from the
relevant issues. See RCM 405(a) discussion (the primary objective of the investigation is ?to
inquire into the truth of the matters set forth in the charges, [to verify] the form of the charges,
and to secure information on which to determine what disposition should be made of the case").
The alleged testimony of MAJ Dreher is outside the scope of the Article 32 investigation. Even
if found relevant, the proffered testimony is cumulative with other witnesses in the chain of
command, namely CPT Lim, CPT Fulton, W01 Balonek, SFC Adkins, and Ms. Showman.

3
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FOR OFFICIAL USE ONLY

SUBJECT: Response to Defense Request for Article 32 Witnesses United States v. PFC

Bradley Manning

p. MAJ Clifford Clausen. The United States objects to the defense request for this witness.
The defense's proffered testimony regarding his alleged ignorance of information relating to PFC
Manning is not relevant to the Article 32 investigation and will only serve to distract from the
relevant issues. See RCM 405{a) discussion (the primary objective of the investigation is ?to
inquire into the truth of the matters set forth in the charges, [to verify] the form of the charges,
and to secure information on which to determine what disposition should be made of the case").
The alleged testimony of Clausen is outside the scope of the Article 32 investigation. Even
if found relevant, the proffered testimony relating to operations in the 8-2 office is cumulative
with other witnesses who worked in the 8?2 office, namely CPT Lim. CPT Fulton.
Balonek, SFC Adkins, SGT Madaras, and Ms. Showman.

q. CPT Barclay Keay. The United States objects to the defense request for this witness.
The defense?s proffered testimony regarding his alleged opinion that media devices should not
be allowed in the 8-2 office is not relevant to the Article 32 investigation and will only serve to
distract from the relevant issues. See RCM 405(a) discussion (the primary objective of the
investigation is ?to inquire into the truth of the matters set forth in the charges, [to verify} the
form of the charges, and to secure information on which to determine what disposition should be
made of the case"). The alleged testimony of CPT Keay is outside the scope of the Article 32
investigation. Even if found relevant, the proffered testimony relating to PFC Manning's work
performance and operations in the 5-2 office is cumulative with other witnesses who worked in
the 3-2 office, namely CPT Lim, CPT Fulton, W01 Balonek, SFC Adkins, SGT Madaras. and

Ms. Showman.

r. CPT Matthew Freeburg. The United States objects to the defense request for this
witness. The defense's proffered testimony regarding PFC Manning?s alleged behavioral issues
and any actions taken by the chain of command in response is not relevant to the Article 32
investigation and will only serve to distract from the relevant issues. See RCM 405(a) discussion
(the primary objective of the investigation is ?to inquire into the truth of the matters set forth in
the charges, [to verify] the form of the charges, and to secure information on which to determine
what disposition should be made of the case"). The alleged testimony of CPT Freeburg is
outside the scope of the Article 32 investigation. Even if found relevant, the proffered testimony
is cumulative with other unit witnesses, namely CPT Lim, PT Fulton, W01 Baloaek, SFC

Adkins, SGT Madaras, and Ms. Showman.
s. CPT Steven Lim. The United States does not object to this witness.
t. CPT Thomas Cherepko. The United States does not object to this witness.

u. CPT Michael Johnson. The United States objects to the defense request for this witness.
The defense's proffered testimony regarding PFC Manning?s mental status and his opinion and
interactions with SFC Adkins, CPT Lim, and MAJ Clausen is not relevant to the Article 32
investigation and will only serve to distract from the relevant issues. In addition, on 22 April
201 1, an RCM 706 board concluded that Manning did not have a severe mental disease or

4
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ANJA-CL
SUBJECT: Response to Defense Request for Article 32 Witnesses United States v. PFC

Bradley Manning

defect at the time of the alleged criminal conduct that resulted in him being unable to appreciate
the nature and quality or wrongfulness of his conduct." See RCM 405(a) discussion {the primary
objective of the investigation is "to inquire into the truth of the matters set forth in the charges,
[to verify] the form of the charges, and to secure information on which to determine what
disposition should be made of the case"). The alleged testimony of CPT Johnson is outside the
scope of the Article 32 investigation. Even if found relevant, the proffered testimony is
cumulative with other expected witnesses, namely CPT Lint, CPT Fulton, W01 Balonek, SFC
Adkins, SGT Madaras, and Ms. Showman.

v. 1LT Tanya Gaab. The United States objects to the defense request for this witness. The
defense's proffered testimony regarding her alleged opinion(s) of PFC Manning and of the
leadership, the command decision to deploy PFC Manning, and PFC Manning?s mental status is
not relevant to the Article 32 investigation and will only serve to distract from the relevant
issues. In addition, on 22 April 201 I, an RCM 706 board concluded that Manning did not
have a severe mental disease or defect at the time of the alleged criminal conduct that resulted in
him being unable to appreciate the nature and quality or wrongfulness of his conduct." See RCM
405(a) discussion (the primary objective of the investigation is "to inquire into the truth of the
matters set forth in the charges, [to verify] the form of the charges, and to secure information on
which to determine what disposition should be made of the case"). The alleged testimony of
1LT Gaab is outside the scope of the Article 32 investigation. Even if found relevant, the
proffered testimony is cumulative with other expected witnesses, namely CPT Lim, CPT Fulton.
W01 Balonek, SFC Adkins, SGT Madaras, and Ms. Showman.

w. 1LT Elizabeth Fields. The United States objects to the defense request for this witness.
The defense?s proffered testimony regarding her alleged training as the SSH and her opinion of
the leadership is not relevant to the Article 32 investigatiOn and will only serve to distract from
the relevant issues. See RCM 405(a) discussion (the primary objective of the investigation is ?to
inquire into the truth of the matters set forth in the charges, [to verify] the ferm of the charges,
and to secure information on which to determine what disposition should be made of the case").
The alleged testimony of ILT Fields is outside the scope of the Article 32 investigation. Even if
found relevant. the proffered testimony relating to conduct in the 5-2 of?ce is cumulative with
other witnesses who worked in the of?ce, namely CPT Lim, CPT Fulton, W01 Balonek,
SFC Adkins, SGT Madaras, and Ms. Showman.

CW2 Joshua Ehresman. The United States objects to the defense request for this
witness. The defense?s proffered testimony regarding PFC Manning's alleged mental status and
the decision to deploy PFC Manning is not relevant to the Article 32 investigation and will only
serve to distract from the relevant issues. In addition. on 22 April 201 I, an RCM 706 board
concluded that Manning did not have a severe mental disease or defect at the time of the
alleged criminal cenduct that resulted in him being unable to appreciate the nature and quality or
wrongfulness of his conduct." See RCM 405(a) discussion [the primary objective of the
investigation is ?to inquire into the truth of the matters set forth in the charges, [to verify] the
form of the charges, and to secure infermation on which to determine what disposition should be

5
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FOR OFFICIAL USE ONLY

ANJA-CL
SUBJECT: Response to Defense Request fer Article 32 Witnesses United States v. PFC

Bradley Manning

made of the case?). The alleged testimony of CW2 Ehresman is outside the scope of the Article
32 investigation. Even if found relevant, the proffered testimony relating to conduct in the 8?2
office is cumulative with other witnesses who worked in the 3?2 office, namely CPT Lim, CPT
Fulton. Balonek, SFC Adkins, SGT Madaras, and Ms. Showman.

y. MSG Eric Usbeck. The United States objects to the defense request for this witness.
The defense?s proffered testimony regarding PFC Manning?s alleged mental status and attitude is
not relevant to the Article 32 investigati0n and will only serve to distraCt from the relevant
issues. In addition, on 22 April 201 i, an RCM 706 board concluded that Manning did not
have a severe mental disease or defect at the time of the alleged criminal conduct that resulted in
him being unable to appreciate the nature and quality or wrongfulness of his conduct." See RCM
405(a) discussion (the primary objective of the investigation is ?to inquire into the truth of the
matters set forth in the charges. [to verify] the form of the charges, and to secure information on
which to determine what diSposition should be made of the case"). The alleged testimony of
MSG Usbeck is outside the scope of the Article 32 investigation. Even if found relevant. the
proffered testimony relating to PFC Manning's alleged conduct is cumulative with other
witnesses in the chain of command, namely CPT Lim, CPT Fulton, WOI Balonek, SFC Adkins.
and Ms. Showman.

z. MSG Mark Woodworth. The United States objects to the defense request for this
witness. The defense?s proffered testimony regarding PFC Manning's mental status is not
relevant to the Article 32 investigation and will only serve to distract from the relevant issues. In
addition, on 22 April 2011, an RCM 706 board concluded that Manning did not have a
severe mental disease or defect at the time of the alleged criminal conduct that resulted in him
being unable to appreciate the nature. and quality or of his conduct." See RCM
405(a) discussion (the primary objective of the investigation is ?to inquire into the truth of the
matters set forth in the charges. [to verify] the form of the charges, and to secure information on
which to determine what disposition should be made of the case"). The alleged testimony of
MSG Woodworth is outside the scope of the Article 32 investigation. Even if found relevant, the
proffered testimony is cumulative with other witnesses in the chain of command, namely CPT
Lim, CPT Fulton, Balonek, SFC Adkins, and Ms. Showman, and law enforcement
witnesses, namely SA Toni Graham. SA Mark Mander, SA Calder Robertson, SA David Shaver,

SA Alfred Williamson, and SA Troy Bettencoutt.
aa. SFC Paul Adkins. The United States does not object to this witness.

bb. 836 Lawrence Mitchell. The United States objects to the defense request for this
witness. The defensc?s proffered testimony regarding any alleged photos observed on PFC
Manning?s iPod, his mental status, and any attempt to chapter PFC Manning out of the military is
not relevant to the Article 32 investigation and will only serve to distract from the relevant
issues. In addition, on 22 April 20] 1, an RCM 706 board concluded that Manning did not
have a severe mental disease or defect at the time of the alleged criminal conduct that resulted in
him being unable to appreciate the nature and quality or wrongfulness of his conduct.? See RCM

6
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SUBJECT: Response to Defense Request for Article 32 Witnesses United States v. PFC

Bradley Manning

405(a} discussion (the primary objective of the investigation is ?to inquire into the truth of the
matters set forth in the charges, [to verify] the form of the charges, and to secure information on
which to determine what disposition should be made of the case?). The alleged testimony of
SSG Mitchell is outside the scope of the Article investigation. Even if found relevant, the
proffered testimony relating to PFC Manning's alleged conduct is cumulative with witnesses
who worked in the 3-2 of?ce, namely CPT Lim, CPT Fulton, W01 Balonek, SFC Adkins, SGT
Madaras, and Ms. Showman.

cc. SGT Rebecca Schwab. The United States objects to the defense request for this
witness. The defense's proffered testimony regarding PFC Manning alleged sexual orientation
and her opinion of PFC Manning is not relevant to the Article 32 investigation and will only
serve to distract from the relevant issues. See RCM 405(a) discussion (the primary objective of
the investigation is ?to inquire into the truth ofthe matters set forth in the charges, [to verify] the
form of the charges, and to secure information on which to determine what disposition should be
made of the case"). The alleged testimony of SGT Schwab is outside the scope of the Article 32
investigation. Even if found relevant, the proffered testimony is cumulative with other witnesses
who wOrked with the accused, namely CPT Lim, CPT Fulton, W01 Balonek, SFC Adkins, SGT
Madaras, and Ms. Showman.

dd. SGT Daniel Padgett. The United States objects to the defense request for this witness.
The defense?s proffered testimony regarding his opinion of the chain of command is not relevant
to the Article 32 investigation and will only serve to distract from the relevant issues. See RCM
405(a) discussion {the primary objective of the investigation is ?to inquire into the truth of the
matters set furth in the charges, [to verify] the form of the charges, and to secure information on
which to determine what disposition should be made of the case?). The alleged testimony of
SGT Padgett is outside the scope of the Article 32 investigation. Even if found relevant, the
proffered testimony relating to PFC Manning?s conduct and operations in the 5-2 office is
cumulative with other witnesses who worked in the 3-2 of?ce, namely CPT Lim, CPT Fulton,
W01 Balooek, SFC Adkins, SGT Madaras, and Ms. Showman.

ee. SGT David Sadtler. The United States objects to the defense request for this witness.
The defense?s proffered testimony regarding an incident that upset PFC Manning and his opinion
of PFC Manning and the chain of command is not relevant to the Article 32 investigation and
will only serve to distract from the relevant issues. See discussion (the primary
objecdve of the investigation is ?to inquire into the truth of the matters set forth in the charges,
[to verify] the form of the charges, and to secure information on which to determine what
disposition should be made of the case"). The alleged testimony of SGT Sadtler is outside the
scope of the Article 32 investigation. Even if found relevant, the proffered teStimony is
cumulative with other witnesses who worked in the 3-2 shop, namely CPT Lim. CPT Fulton,
Balonek, SFC Adkins, SGT Madaras, and Ms. Showman.

ff. SGT Lorena Cooley. The United States objects to the defense request for this witness.
The defense?s proffered testimony regarding PFC Manning?s treatment by the unit and her

7
FOR OFFICIAL USE ONLY

FOR OFFICIAL USE ONLY

ANJA-CL
SUBJECT: Response to Defense Request for Article 32 Witnesses United States v. PFC

Bradley Manning

opinion of the chain of command is not relevant to the Article 32 investigation and will only
serve to distract from the relevant issues. See RCM 405(a) discussion the primary objective of
the investigation is ?to inquire into the truth of the matters set forth in the charges. [to verify] the
form of the charges, and to secure information On which to determine what disposition should be
made of the case"). The alleged testimony of SGT Cooley is outside the scope of the Article 32
investigation. Even if found relevant, the proffered testimony is cumulative with other witnesses
who worked in the 5-2 of?ce, namely Lim, CPT Fulton, W01 Balonek, SFC Adkins, SGT
Madaras, and Ms. Showman.

gg. SGT Sheri Walsh. The United States objects to the defense request for this witness.
The defense?s proffered testimony regarding PFC Manning?s treatment by the unit and PFC
Manning alleged mental issues is not relevant to the Article 32 investigation and will only serve
to distract from the relevant issues. In addition, on 22 April 201 I. an RCM 1?06 board concluded
that Manning did not have a severe mental disease or defect at the time of the alleged
criminal conduct that resulted in him being unable to appreciate the nature and quality or
wrongfulness of his conduct." See RCM 405(a) discussion (the primary objective of the
investigation is ?to inquire into the truth of the matters set forth in the charges, [to verify] the
form of the charges, and to secure information on which to determine what diSposition should be
made of the case"). The alleged testimony of SGT Walsh is outside the scope of the Article 32
investigation. Even if found relevant, the proffered testimony is cumulative with other witnesses
who worked in the 5-2 of?ce, namely CPT Lim, CPT Fulton, W01 Baionek, SFC Adkins, SGT
Madaras, and Ms. Showman.

hh. Ms. Jihrleah Showman. The United States does not object to this witness.
ii. Mr. Adrian Lame. The United States does not object to this witness.

jj. President Barack Obama. The United States objects to the defense's request for this
witness. The defense's proffered testimony is not relevant to the Article 32 investigation
because it involves matters outside the scope of the investigation and will only serve to distract
from the relevant issues. See RCM 405(a} discussion (the primary objective of the investigation
is ?to inquire into the truth of the matters set forth in the charges, [to verify] the form of the
charges, and to secure information on which to determine what disposition should be made ofthe

case").

kit. Dr. Robert Gates. The United States objects to the defense?s request for this witness.
The defense's proffered testimony is not relevant to the Article 32 investigation because it
involves matters outside the scope of the investigation and will only serve to distract from the
relevant issues. See RCM 405(a) discussion (the primary objective of the investigation is ?to
inquire into the truth of the matters set forth in the charges, [to verify] the form of the charges,
and to secure information on which to determine what disposition should be made of the case").

8
FOR OFFICIAL USE ONLY

FOR OFFICIAL USE ONLY

ANJA-CL
SUBJECT: Response to Defense Request for Article 32 Witnesses United States v. PFC

Bradley Manning

11. Honorable Hillary Clinton. The United States objects to the defense?s request for this
witness. The defense?s proffered testimony is not relevant to the Article 32. investigation
because it involves matters outside the scope of the investigation and will only serve to distract
from the relevant issues. See RCM 405(a) discussion (the primary objective of the investigation
is ?to inquire into the truth of the matters set forth in the charges, [to verify] the form of the
charges. and to secure information on which to determine what disposition should be made of the

case").

mm. CPT James Kolky. The United States objects to the defense request for this witness.
The defense's proffered testimony is not relevant to the Article 32 investigation and will Only
serve to distract from the relevant issues. The Apache video is not classified, and the United

States does not allege otherwise.

an. RADM Kevin Donegan. The United States objects to the defense request for this
witness. The United States requests you find RADM Donegan not reasonably available for the
Article 32 given his positioa as Director of Operations, CENTCOM. See RCM 405(g)(1)(B} (a
witness is not reasonably available if the ?dif?culty, expense. delay, and effect on military
operations? of obtaining the testimony outweighs its significance).

on. Mr. Robert Betz. The United States objects to the defense request for this witness.
The United States requests you ?nd Mr. Betz nor reasonably available for the Article 32 given
his position as ChiefClassification Advisory Officer. CYBERCOM- See RCM 405(g}( (a
witness is not reasonably available if the ?dif?culty, expense, delay, and effect on military
operations" of obtaining the testimony outweighs its significance).

pp. LtGen Robert Schmidle. The United States objects to the defense request for this
witness. The United States requests you find LtGen Schmidle not reasonably available for the
Article 32 given his position as Deputy Commander, CYBERCOM. See RCM 405(g)(l (a
witness is not reasonably available if the ?difficulty, expense. delay, and effect on military
operations? of obtaining the testimony outweighs its signi?cance).

qq. VADM Robert Harward. The United States objects to the defense request for this
witness. The United States requests you ?nd VADM Harward not reasonably available for the
Article 32 given his position as Deputy Commander, CENTCOM. See RCM {a
witness is not reasonably available if the ?difficulty. expense, delay, and effect on military
operations" of obtaining the testimony outweighs its signi?cance).

rr. Honorable Patrick Kennedy. The United States objects to the defense request for this
witness. The United States requests you ?nd Honorable Kennedy not reasonably available for
the Article 32 given his position as Under Secretary of State for Management. See RCM
)(Bi (a witness is not reasonably available if the ?dif?culty, expense, delay, and effect
on military operations" of obtaining the testimony outweighs its significance).

9
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FOR OFFICIAL USE ONLY
ANJA-CL
SUBJECT: Response to Defense Request for Article 32 Witnesses United States v. PFC

Bradiev Mannins

ss. RADM David Woods. The United States objects to the defense request for this
witness. according to testimony anticipated by defense. The United States requests you find
RADM Woods not reasonably available for the Article 32 given his position as Commander.
Joint Task Force - Guantanamo. See RCM 405(gitl (a witness is not reasonably available if
the ?dif?culty, expense. delay. and effect on military operations? of obtaining the testimony
outweighs its significance].

tt. CAPT Kevin Moore. The United States objects to the defense request for this witness.
The defense?s proffered testimony regarding PFC Manning?s alleged POI status is not relevant to
the Article 32 investigation and will only serve to distract from the relevant issues. See RCM
405(3) discussion the primary objective of the investigation is ?to inquire into the truth of the
matters set forth in the charges. [to verify] the form of the charges. and to secure information on
which to determine what disposition should be made of the case?)- The alleged testimony of
CAPT Moore is outside the scope of the Article 32 investigation.

uu. CAPT William Hector. The United States objects to the defense request for this
witness. The defense?s proffered testimony regarding PFC Manning's alleged POI status is not
relevant to the Article 3?2 investigation and will only serve to distract from the relevant issues.
See RCM 405(a) discussion (the primary objective of the investigation is ?to inquire into the
truth of the matters set forth in the charges, [to verify] the form of the charges, and to secure
information on which to determine what disposition should be made of the ease"). The alleged
testimony of CAPT Hector is outside the scope of the Article 32 investigation.

vv. Inmate Christopher Whit?eld. The United States objects to the defense request for this
witness. The defense?s proffered testimony is cumulative with law enforcement agents. namely
SA Toni Graham, SA Mark Mander. SA Calder Robertson. SA David Shaver. SA Alfred
Williamson, and SA Troy Bettencourt.

4. The point of contact for this memorandum is the undersigned at?
i


ASHDEN FEIN
CPT, JA

Trial Counsel

CF:
Defense Counsel

It)
FOR OFFICIAL USE ONLY

8 December 201 I

MEMORANDUM FOR Article 32 Investigating Of?cer, LTC Paul Alman'aa. 15(1th Judge
Advocate General Detachment, Legal Support Organization. MG Albert C. Lieber USAR
Center, 6901 Telegraph Road, Alexandria, Virginia 22310

SUBJECT: Witness Justi?cation United States v. PFC Bradley 13. Manning

1. On 2 December 201 l. the defense in the above case served a copy of its witness request on
the govemment. Below, the defense sets forth the relevancy of each witness that the
government opposes and notes that under Article 32th) Uniform Code of Military Justice, PFC
Manning has the right to cross-examine witnesses against him, and present anything he may
desire either in defense or mitigation.

a. SA Charles Ames SA Ronald Rock and SA Patrick Wheeler. As noted in the defense?s
witness request, the defense believes each of the requested agents is relevant and will provide
needed testimony at the Article 32. The defense would like to note that over 22 CID agents
participated in the investigation of this case. The fact that the defense-requested agents mirror
those of the government (with the exception of SA Ames) should speak to the reasonableness
of the defense?s request. The defense has requested the attendance of SA Rock and SA
Wheeler in order to provide the Investigating Officer with testimony concerning the joint
investigations being conducted by both the Department of State and the Federal Bureau of
lnvesrigation. Notably. SA Rock was on the original witness list filed on 7 July
2(110. According to the government?s memo dated 7 December 201 1, the other agents
Graham. SAM Mander, SA Robertson, SA Shaver. SA Williamson and SA Bettencourt can
provide the needed testimony.? Their testimony, however, will in large part be hearsay
evidence about what other agents have done on the case and what witnesses have told these
other case agents. Such testimony will do little to aid the investigating Officer in conducting a
?thorough and impartial investigation Ofall matters? as required by Article 32(a) UCMJ.
Further. the defense has a legitimate interest in using the Article 32 hearing as a discovery tool
(see discussion to R.C.M. 405111)}. If the defense does not have the opponunity to question the
case agents about evidence they developed. witnesses they interviewed. leads they pursued.
leads they elected not to pursue. and other relevant matters. the defense will also be denied an
important function that the Article 32 investigation is designed to accomplish. Given the status
of current and ongoing operations and the fact that case agents are likely spread throughout the
United States and overseas, the Article 32 investigation is the only realistic mechanism
available to the defense to personally question the case agents involved in the investigation.

b. Key Leaders of 2nd Brigade Combat Team: In the defense?s witness request. the
defense requested that selected key leaders ofthe 2nd Brigade Combat Team be made available.

1) The relevancy of these witnesses should be obvious. Each of these witnesses can

provide different insight into the events that transpired between 1 November 2000 and 27 May
2010. Because each witness viewed the events from a different perspective, their individual

HIV. OFER.





. .

SUBJECT: Witness Justi?cation - United States v. PFC Bradley E. Manning

testimony is independently relevant. The defense notes for example. that all ofthe requested
witnesses provided sworn statements as part of the Secretary ofthe Army's 15-6 Investigation.
This includes COL Miller. LTC Kems. MAJ Dreher. PT Freeburg. MSG Usbeck, and MSG
Woodworth. The statements from these witnesses provide different and important details about
the events.

COL Miller's statement about the perception of the leadership qualities of MAJ
Dreher, MAJ Clausen. and MSG Adkins is relevant to their response or lack of a response in
this case. Additionally, the fact that COL Miller ultimately decided to remove MAJ Dreher and
MAJ Clausen from their respective positions and considered MSG Adkins ?marginal, but not
bad enough to either relieve or replace" is also relevant and provides mitigation evidence that
the investigating Of?cer should consider.

LTC Kerns will testify not only to MAJ Clausen's weak performance and the
fact that he was not a strong leader. but he will also testify that MAJ Clausen did not take
appropriate action to correct mistakes made by junior members in his unit and did not have
control over the 3-2 shop. LTC Kerns will also testify that MAJ Clausen was handicapped by
weak NCO leadership and that MSG Adkins was not an effective leader. Kerns also
provides key testimony regarding the 3-2 section?s failure to initiate a suspension
Mamring?s security clearance when it became obvious that such action was required.

MAJ Dreher will testify to the fact he was not kept aware of the problems being
suttered by PFC Manning. He will testify the MAJ Clausen and MSG Adkins failed to inform
him of PFC Manning's mental health issues. DitTerenees in details and differing perspectives
such as these cannot be resolved by merely looking at the sworn statements or considering the
hearsay testimony of the witnesses the government wishes to bring.

CPT Freeburg, MSG Usbeck. and MSG Woodwlo will testify about the
commands lack of relevant information from MAJ Clausen and MSG Adkins concerning PFC
Manning. The failure to provide this information impacted not only the decision regarding
whether to deploy PFC Manning. but also the timeliness of the suspension of PFC Manning's
security clearance.

2) In its response to the defense witness request, the government states that the
dcfense?s proffered testimony regarding the total breakdown in command and control within the
Section and the multiple failures by the unit to take basic steps in reSponse to clear mental
health issues being suffered by PFC. Manning is somehow ?not relevant to the Article 32
investigation and will only serve to distract from the relevant issues.? The government cites to
R.C.M. 405ml. lneitplicably. the government ignores REM. 405m and controlling case law
which clearly states an accused has the right to present evidence in defense, mitigation. and
extenuation at the Article 32. See R.C.M. 4050? (stating an accused has the right to present
Evidence in defense. mitigation. and extenuation); Article 321(k)). Uniform Code of Military
Justice (stating an accused may ?present anything he may desire in his own behalf.
either in defense or mitigation. and the investigation of?cer shall examine available witnesses



00584
\I-r

SUBJECT: Witness Justification - United States v. PFC Bradlev E.

United States v. Garcia. 59 MJ. 447, 451 (OAK-1T. 2004ltruling that an
accused has the right to present anything he may desire in his own behalfat an Article 32 in
defense or mitigation). Each of the above requested witnesses will have relevant and
independent information of the events that transpired, and all of these witnesses should be
produced in order to accomplish the purposes of the investigation. Simply reading the sworn
statements of some of these witnesses and hearing from a few others will not allow either party
or the Investigating Of?cer to explore the relevant information. The listed witnesses need to he
questioned personally and individually about what they saw. heard. and experienced is
to be a thorough and impartial investigation.'

c. Key Members of 2nd Brigade Combat Team?s 8-2 Section: In the defense-'5 witness
request, the defense requested that selected key members of the intelligence section of the 2nd
Brigade Combat Team be made available.

ll The relevancy of these witnesses should also be obvious. Each ot?these witnesses
can provide different insight into the events that transpired between 1 November 2009 and 27
May 2010. Because each witness viewed the events from a different perspective, their
individual testimony is independently relevant. The defense notes for example, that all of the
requested witnesses provided swom statements as part of the Secretary ofthe Annyis
investigation. This includes MAJ Clausen. Keay. CPT Johnson, ll.?l' Gaab. 1LT Fields,
CW2 Ehresman. 5986 Mitchell. Schwab, SGT Padgett. SGT Sadtler. SGT Cooley. and
SGT Walsh. The statements from these witnesses provide different and important details about
the events. Each of these witnesses can provide unique information regarding not only the
dysfunctional leadership scheme by MAJ Clausen and MSG Adkins. but also the numerous
recommendations to get PFC Manning help both prior to the deployment and during the
deployment. Each witness will provide relevant mitigation and extenuation evidence regarding
how the 8-2 section failed to notify the company commander of the issues PFC Manning was
struggling with or the multiple acts of behavior that should have resulted in an immediate
suspension of PFC Manning's security clearance.

In its response to the defense witness request for relevant 8-2 section witnesses. the
government states that the testimony ot'these witnesses is somehow "not relevant to the Article
32 investigation and will only serve to distract from the relevant issues." The government also
opines that the breakdown in command and control, the decision to deploy PFC Manning, and
the decision to not suspend his security clearance earlier ?is not relevant to the Article 32
Investigation and will only serve to distract from the relevant issues." The government cites to
ROM. 405ml. Again. the government ignores R.C.l'vl. 405m and controlling case law which





it is troubling that in the government?s response dated 7" December EDI t. it objects to every listed witness by the
defense that is not also on the government?s list. The government does not scent to be interested at all in providing
an thorough and impartial investigation. The government indicates that it is going to go to the espense and trouble
ofbringing two civilian witnesses and other military witnesses from multiple duty locations in the United States
and overseas. and yet the government claims that it is too costly and troublesome to bring any ofthe defense
requested witnesses. Such a position defies logic and common sense.




Vin?r \ur

SUBJECT: Witness Justi?cation - United States v. PFC Bradlev F.. Manning

clearly states an accused has the right to present evidence in defense. mitigation. and
extenuation at tlte Article 32. See R.C.M. 4050?) (stating an accused has the right to present
evidence in defense. mitigation, and extenuation); Article 32th}. Uniform Code ofMilitatjv
Justice [stating an accused may "present anything he may desire in his own behalf.
either in defense or mitigation. and the investigation officer shall examine available witnesses
requested. . United States v. Garcia. 59 MJ. 447. 45] (C.A.A.F. that an
accused has the right to present anything he may desire in his own behalfat an Article 32 in
defense or mitigation). Each of the above requested witnesses will have relevant and
independent information of the events that transpired. and all of these witnesses should be
produced in order to accomplish the purposes of the investigation.

(1. Mental Health Providers: In the defensc's witness request. it requested CPT Lcihman.
PT Worsley, and CPT Critch?eld be made available.

1) The relevancy of these witnesses should also be obvious. Each of these witnesses
provided mental health treatment to PFC Manning or conducted a behavioral health
examination for the command. Because each witness was involved at different times and in
different aspects. their individual testimony is independently relevant.

2) The government states the testimony of these mental health providers ?is not
relevant to the Article 32 investigation and will only serve to distract from the relevant issues.?
Additionally. the government points to the fact that a 706 board concluded that
Manning did not have a severe mental disease or defect at the time ofthe. allged criminal
conduct that resulted in him being unable to appreciate the nature and quality or wrongfulness
ofhis conduct" as a basis to ignore any mental health testimony. Such a position is
indefensible. The fact PFC Manning did not have a ?severe mental disease or defect" only
indicates that he does not have a basis to claim an insanity defense. Such a conclusion does not
speak to any diminished capacity or mitigating and extenuating circumstances. See REM.
405m (stating an accused has the right to present evidence in defense. mitigation. and
extenuationl: Article Uniform Code of Military Justice (UCMJ) (stating an accused may
?present anything he may desire in his own behalf, either in defense or mitigation. and the
investigation of?cer shall examine available witnesses requested. United States v. Garcia.
59 NH. 447'. 451 (C.A.A.F. 2004ltruling that an accused has the right to present anything he
may desire in his own behalfat an Article 32 in defense or mitigation]. Each of the above
requested witnesses will have relevant and independent and all of these witnesses
should be produced in order to accomplish the purposes of the investigation.

e. Original Classi?cation Authorities (OCA): In the witness request. the defense
requested each of the individuals that provided OCA reviews be made available.

1 'l'he relevancyr ofthese witnesses should also be obvious. Each ol'thesc witnesses
provided a unswom af?davit under 23 1.5.813. $4 1746.

00586


Witness Justi?cation - Lfnited States v. PFC Bradlev li. Mannine

2) The government objected to the defense request for any of these witnesses. The
government, without any justification. requested that you find the requested witness were not
reasonably available given the importance oftheir respective postion. The government seems
to argue that in matters ofjustice. if you have too important of a position. you should not be
bothered. Military justice should not be controlled by the importance of your duty position.
Each individual took the time to provide an unswom af?davit. The defense should be provided
with the opportunity to examine these witnesses at the Article 32 hearing.

3) In the event these witnesses are not produced, the defense objects to the Investigating
Officer considering their unsworn statements. R.C.M. Unsworn statements
under 28 U.S.C. I746 cannot be considered by the Investgating Of?cer. The Manual for
Courts-Martial requires that testimony given at an Article 32 be under oath. R.C.M.
If a witness is deemed not reasonably available. the Investigating Of?cer can
consider sworn statements. R.C.M. A unsworn statement provided under 28
U.S.C. 1746 is not a sworn statement. In order for an unsworn statement provided under 28
1746 to be admissible. it must be subscribed and signed "in ajudic?ial proceeding or
course ot?justice? in order to subject the declarant to the penalty of perjury at the Article 32
hearing. See Article 131 (noting that ?Section 1246 does not change the requirement that a
deposition be given under oath or alter the situation where an oath is required to be taken before
a speci?c person"): See also 28 1746 (noting that the unsworn declaration is not
effective in "depositions or an oath of of?ce. or an oath required to be taken before a speci?ed


f. Current and ormer Members of the US. Government: In the defenses witness request.
the defense requested President Obama, Secretary Clinton. and former Secretary Gates be made
available.

The relevancy of these witnesses should be obvious. Each of these witnesses has
provided statements that contradict those given by the OCA witnesses regarding the alleged
damage caused by the unauthorized disclosures. Additionally. each of these witnesses is
relevant in order to inquire into the issues of unlawful command influence and unlawful pretrial
punishment in violation ofAtticles 13 and 37 of the UCMJ. See 405t'c') Discussion
(stating that inquiry into other issues such as legality of searches or the admissibility of
evidence is proper by an Article 32 Investigating Of?cer).

2) The government apparently has no dif?culty obtaining the presence ot'civilian
witnesses when it deems it necessary. The defense requests that the Investigating Of?cer
contact each civilian witness and invite each witness to attend pursuant to R.C.M.

3) The de?ense objects to the witnesses not being produced at the Article 32 based solcy
on the determination by the government that they are too important to be tnade available.
Assuming the witnesses are not produced. the defense will request a deposition of these
witnesses ifcharges are referred. pursuant to RJCM. 702 and the holding in United States v.
Chocolate. 5 MJ. I43 1978).



SUBJECT: Witness Justi?cation - United States v. PFC Bradlev E. Manning

g. Mental Health Providers at the Quantico Con?nement Facility: In the defense?s witness
request1 the defense requested CAPT Moore and CAPT Hooter be made available.

1) The relevancy of these witnesses should is obvious. Each of these witnesses has
provided statements that would support the fact PFC Manning was subjected to unlawful
pretrial punishment under Article 13 of the niform Code ofMilitary Justice. Sea RUM.
405ml Discussion (stating that inquiry into other issues such as legality of searches or the
admissibility ofevidence is proper by an Article 32 Investigating Of?cer).

2) The government objects to the defense request. stating that the alleged unlawful
pretrial punishment is not relevant at the Article 32 investigation and will only serve to distract
from the relevant issues. Whether PF Manning was unlawfully punished prior to trial is a
relevant matter for you to consider. The facts of his unlawful pretrial punishment is appropriate
infomiation for you to consider in forming your recommendations to the convening authority.
The issue is also important for the integrity ofthe military justice system and the appearance of
fairness in the process.

h. Inmate Christoper Whitfield: In the defenses witness request. it requested Inmate
Whit?eld be made available. The relevancy of this witness should be obvious. Any agent
testifying to the matters allegedly heard by Inmate Whit?eld would only be testifying to
hearsay. Given the potential impact of his testimony. Inmate Whit?eld must be produced in
order to provide for a thorough and impartial investigation.

2. PFC Manning is charged with offenses that carry the maximum punishment of life without
the possibility of parole. His charges are among the most serious charges that a soldier can
face. The government must be prepared to accept the costs incurred by the seriousness of the
charges that they have preferred against PFC Manning. Anything but the personal appearances
of all witnesses requested by the defense and government would deny Manning his right to
a thorough and impartial investigation and turn this into a hollow exercise.

3. The govenunent?s claim that the cost and burden is too great to require the production and
personal appearance of relevant and necessary witnesses is not justi?ed. It was the
governments decision to conduct this Article 32 investigation at Fort Meade. The defense?s
position has been consistent; it does not object to this location provided it has the personal
appearance of all relevant and necessary witnesses. The government should not be allowed to
use its own decision to conduct the investigation at Fort Meade as a way to avoid making

relevant witnesses available.

DAVID EDWARD COOMBS
Civilian Defense Counsel

6

DEPARTMENT OF THE ARMY
150TH JUDGE ADVOCATE GENERAL DETACHMENT
MG- ALBERT C. LIEBER CENTER
6901 TELEGRAPH ROAD

ALEXANDRIA. VIRGINIA 22310-3320
REPLY TO

ATTENTION OF



AFRC-MJVA 13 December 201 1

MEMORANDUM FOR US v. Manning Article 32(b) Participants

SUBJECT: Witness List

1. As indicated in my original noti?cation memorandum of23 November 201 1, as delayed by
my e-mail noti?cation to you of 7 December 2011. below is a list of the witnesses I intend on
calling during the investigation of this case and my initial determination as to whether witnesses
are reasonably available. Government counsel, please advise both me and defense counsel if you
believe any ofthe witnesses designated below as reasonably available are not reasonably
available: for any witness designated as not reasonably available or that you believe is not
reasonably available, please indicate whether he or she will be available by telephone during the
investigation or whether you believe another alternative to testimony is appropriate.

SFC Paul Adkins (reasonably available}

SPC Eric S. Baker (reasonably available)

W01 Kyle J. Balonek (not reasonably available)
SA Troy Bettencourt (reasonably available)
386 Peter Bigelow (not reasonably available}
CPT Thomas Cherepko (not reasonably available)
SA Antonio Edwards (reasonably available)
CPT Casey Fulton {reasonably available)

SA Toni Graham {not reasonably available)

Mr, Mark Johnson (reasonably available)

Mr. Adrian Lame (not reasonably available)

PT Steven Lim (reasonably available)

. SGT Chad Madaras (not reasonably available)
Brian Madrid (not reasonably available}
SA Mark Mander(reasonab1y available]

Mr. Jason Milliman (not reasonably available)
SA Calder Robertson (not reasonably available)
SA David Shaver (reasonably available)

Ms. .lihrleah Showman (not reasonably available)
SA Alfred Williamson {reasonably available)

PT Barclay Keay (reasonably available}

SGT Daniel Padgett (reasonably available}



w. Inmate Christopher Whit?eld (not reasonably available}
it. RADM Kevin Donegan (not reasonably available}
y. Mr. Robert Betz (not reasonably available)

IHV. ores. EXHIBIT

A RC- MJ A
SUBJECT: Witness List

2. LtGen Robert Schmidle {not reasonably available)

an. VADM Robert l-larn-?ard {not reasonably available}

bb. Mr. Patrick Kennedy (not reasonably available}

ee. RADl?v-?l David Woods (not reasonany available}

dd. Person subscribing Bates numbers (lil3781484l0378175 and (not
l'easonably' available}

2. Please address all questions or eoneems to the undersigned



POC for this memorandum is the undersigned.

I.

tit-t la



PAUL R. ALMANZA

LTC. JA. USAR
Investigating Of?cer

CF:
MAJ Matthew Kenike
Paul Bouchar
CPT Ashden Fein (at
Mr. David Cooran {a
JoDean Morrow
CPT Angel Ovet'gaard
PT Jeffrey Whyte (a
LTC Mark llolzer (at









DEPARTMENT OF THE ARMY
150m JUDGE ADVOCATE GENERAL DETACHMENT (LSD)
MG ALBERT c. LIEBER USAR CENTER
69:11 TELEGRAPH ROAD

ALEXANDRIA. VIRGINIA 22310-3320
REPLY To
ATTENTION OF



AFRC-MJVA 13 DeCember 2011

MEMORANDUM FOR US v. Manning Article 32(b) Participants

SUBJECT: Closure Determination

I. On 28 November 2011. the defense submitted a request For a closed hearing under ROM.
405th)(3) requesting the closure ot?the Article 32 proceedings covering five matters: the
accused's alleged disloya] statements to Ms. Showman and CW2 Ehresman; the accused?s
alleged admission to Inmate Whit?eld while in pretrial con?nement that he had sold information
to Wikileaks; the accused?s alleged misconduct while at AIT involving posting a video to
YouTube regarding SC IFs at Fort Huachuca: the accused's alleged misconduct while at the
basic course involving attempting to stab another trainee with a dull pencil; and any
information that various terrorist groups had obtained copies ofthe information released by
Wikileaks. The government responded to this request on 4 December 201 1 and the defense
Submitted a reply that same day.

2. On 7 December 201 I. I provided notice to the parties that I intended to request my legal
advisor for advice concerning the defense request and that I intended to provide him copies of
their submissions. I provided that material to my legal advisor on 8 December 20! 1 and
received his legal advice via a telephone conference on 12 December. I summarized that advice
to counsel in a telephone conference on 12 December. During that call. I heard from Mr.
Coombs and CPT ein and subsequently received email communications from them later that
day concerning their respective positions. I also considered the six items that the defense
requested I consider.

3. The discussion at R.C.M. 405(hlf3} provides that: ?[w]hen an overriding interest exists that
outweighs the value of an open investigation. the hearing may be closed to spectators."
However, ?investigating of?cers must conclude that no lesser methods short of closing the
Article 32 can be used to protect the overriding interest in the case? and "investigating officers
must conduct a case-by-case. witness~by-witness, circumstance-by?circumstance analysis of
whether closure is necessary." ?If . .. [an] investigating of?cer believes closing the Article 32
investigation is necessary. the investigating of?cer must make specific ?ndings of fact in
writing that support the closure." The analysis of R.C.M. 405(h)(3) provides. ?See also R.C.M.
806 for examples of some reasons why a pretrial investigation hearing might be closed."

4. R.C .M. 806(b)(2) provides a four-part test for analyzing closure of courts-martial that is
consistent with the discussion at R.C.M. 405(h)(3). Under this test. proceedings shall be open
unless: ?there is a substantial probability that an overriding interest will be prejudiced if
proceedings remain open"; ?closure is no broader than necessary to protect the overriding

IHV. urea. Exsiaii t/Z



AFRC-MWA
SUBJECT: Closure Determination

interest?: ?reasonable alternatives to closure were considered and found inadequatef? and
?the military judge makes case-speci?c ?ndings on the record justifying closure." The
discussion at R.C.M. recognizes that the public has an interest in public proceedings
and states that ?[ojpening trials to public scrutiny reduces the chance of arbitrary and capricious
decisions and enhances public confidence in the court-martial process." Additionally, the
discussion states:

The most likely reason for a defense request to close court-martial proceedings is
to minimize the potentially adverse effect of publicity on the trial. For example. a
pretrial Article hearing at which the admissibility of a confession will be
litigated may. under some circumstances. be closed. in accordance with this Rule.
in order to prevent disclostu'e to the public (and hence to potential members) of
the very evidence that may be excluded. When such publicity may be a problem.
a session should be closed only as a last resort.

There are alternative means of protecting the proceedings from harmful effects of
publicity. including a thorough voir dire (see R.C.M. 912}. and. if necessary. a
continuance to allow the harmful effects of publicity to dissipate {see R.C.M.
906t'bltl

4. Analyzing the issue under the test at PLUM. 306(b)(2):

a. "[T]here is a substantial probability that an overriding interest will be prejudiced if
proceedings remain open." The defense has stated it intends to move at trial to exclude all five
categories of information on various grounds. and ?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 28 November 201 1
request. paras. 9-10. I ?nd that this portion of the test for closure is met as to all five categories
of information given that if this case were referred to trial. and if the military judge were to
exclude all five categories of information. public disclosure of this information could raise an
issue as to whether prospective panel members had heard the information and had formed an
opinion as to PFC Manning based on that information.

b. ?[Cllosure is no broader than necessary to protect the overriding interest.? The
defense has requested closure limited only to ?if and when the Government attempts to elicit the
above information." Defense 28 November 2011 request. para ll. 1 find that this portion of the
test for closure is met as to all ?ve categories of information given that the defense has not
requested 'a blanket closure of the Article 3?2 investigation. or even that the investigation be
closed for the entirety of any witness?s testimony. but rather merely merely has requested a
closure tailored to the ?ve speci?c categories of information at issue. Thus. pursuant to the
defense's request. a witness could testify in an open proceeding on matters other than the ?ve
specific categories of information at issue. and the investigation would only be closed when that
witness were to testify about one of the five categories ofinformation.

.v

AFRC-M.WA
SUBJECT: Closure Determination

c. "[R]easonable alternatives to closure were considered and found inadequate.? The
defense argues that if its closure request is denied and this case is referred to trial, "atrial judge
and PFC Manning?s defense will be unfairly placed in the position of having to ?un-ring a bell'
with the members and fashion an appropriate instruction should the evidence be deemed as
inadmissible.? Defense 28 November 1 1 request. para. 1-0. I find that this part ofthe test is not
met because. should this case be referred to trial, a militaryjudge 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 defense?s 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 28 November 201 I request, para. 10. Thorough voir dire would also
address the defense?s concern as to the militaryjudge and the defense having to ?Lin-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. 91 I and state that member shall be excused for cause
whenever it appears that the member [hjas informed or expressed a definite opinion as to the
guilt or innocence ofthe accused as to any offense charged [or] [s]hould 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. notes that ?grounds for challenge under
subsection [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.

cl. ?[T]he [investigating officer] makes case?speci?c ?ndings on the record justifying
closure." Given my determination as to reasonable alternatives to closure. it is unnecessary to
address this part of the test.

5. For the reasons stated above in paragraph 4c. 1 have determined that lesser methods short of
closing the Article 32 investigation can be used to protect the accused?s ability to obtain a fair
and impartial trial. The defense's closure request is therefore denied.

3. POC for this memorandum is the undersigned.

$1212

PAU R. ALMANZA
LTC. JA, USAR
Investigating Officer


SUBJECT: Closure Determination

CF:
MAJ Matthew
Paul Bouchat'
CPT Ashden Fein (at
Mr. David Coman [at
JUDean Morrow
CPT Ange] Overgaard
PT Jeffrey Why-{c (a
LTC Mark Holxcr {at









00593

DEPARTMENT OF THE ARMY
150m JUDGE ADVOCATE GENERAL DETACHMENT (1.50}
MB ALBERT c. LIEBER USAR CENTER
6901 TELEGRAPH ROAD

ALEXANDRIA, VIRGINIA 22310-3320
REPLY TO

OF



AFRC-MJVA 14 December 2011

MEMORANDUM FOR US v. Manning Article 32th} Participants

SUBJECT: Evidence List

1. As indicated in my original notification memorandum of23 November 201]. as delayed by
my e?mail noti?cation to you of 7 December 20] 1. below is a list of the evidence I intend to
consider at the investigation:

3. Charged Documents:

Batch #1 (003 76954-003775721)
Batch #2 (?00377626-00377675)
Batch #3 (00377845-00378140).

?l




b. Classi?cation Reviews:

CENTCOM (00.376871003768731

CYBERCOM (003 76875-003768781
CENTCOM (003 76879-003 769021
(?00376903-00376953}

Other (003 78148-003 78 75)
SOUTHC OM (00378646003 78649)
USA (00410623-00410634).



c. Accused's Personnel Records:

1. PFC Manning's OMPF

2. PFC Manning?s ERB (00000006)

3. Security Clearance Documents

a. Batch #1 {00015617-000156191

Batch #2 {00022398-00022913}
Batch #3 {00022947-00022949'}
Batch #4 (00036801-00036802'}
Batch #5

rap-r157

d. Accused's Training:
1. AIT Corrective Training Slideshow (00125314-00125316)
2. Information Assurance Training
a. IA Exam {00375768-00375771)
b. IA Training Requirement {00375772}

nan
k,

F?rrlla
II

?ml



AFRC-MJVA
SUBJECT: Evidence List

reserves?r1

1.

IA Virtual Training (003 75 723)

IA Virtual Training #2 (00375774)

Test Results (00022343)

1A Training Disk (00409673)
IA Awareness-October2009-v8_0 Training Disk (00409674)
Phishing Training Disk (00409675)
I?ll-October Training Disk (00409676)

3. Pre~Deployment Training

a.
1).

Iraq Overview PowerPoint (00409222-00409240)
Afghanistan Overview PowerPoint (00409741-00409230)

4. Classified Information Systems. Export Screenshots (00410665-
00410667}

e. Law Enforcement Investigations:
I . CID Case File (note: I will not consider sworn statements. agent?s
investigation reports. and canvass interview worksheets contained in the C11)

case ?le)

ere-?Terra we 0-.0 are

1T1.

Batch #1 {0000017'9-00000376)
Batch 02(00000402-0000041 1}
Batch #3 (00021364-00025526}
Batch #4 (00026079-00026082)
Batch #5 ('00026356-00036786}
Batch #6 (00045302-000460?3)
Batch #7 (00375183-00375724}
Batch #3 ('00378219-00378623}
Batch #9 (00378626-00378645)
Batch #10 {00407991-00403088}
Batch #11 (00409673-00409673)
Batch #12 (00409781-00410553)
Batch #13 (00410635-00410649)

2. CID Forensic Reports

5'51? Fe.?

l-n H.
a

10th Mountain Shares (00046074-00046451)

Army Intelligence Report (00046452-00046566)
CENTAUR Logs ('00046562-00052616}

CENTCOM Server (00052617-0005431 l)

CIDNE Files {00054312?00054319}

Department of State Files (00054320-001 19042)
SOUTHCOM Comparison (00375003-003751 15)

lntelink

Lamo Chats (00124107-00124282)

PFC Manning?s Personal Computer {00124283-00125269')

k. PFC Manning?s External Hard Drive ('00125270?00125318)

1T1.

PFC Manning's SD Card (00125319-00199473l
Computers 143.171.172.115 and 22.225.28.54 (00199474?00199435}
SIPRNET Computer 22.225.29.185 (00199486-00199493)



AFRC-MJVA
SUBJECT: Evidence List

11.

SIPRNET Computer 22.225.41.40 (00199494~00199510)
PFC Manning?s CD (00199511-0199523}

NIPRNET Computer 144.107.17.139 (00199524?00199555)
NIPRNET Computer 144.107.19 (00199556-00211019)
NIPRNET Computer 147.198.178.143 ('00211020-00211027)
SIPRNET Computer 22.225.28.216 (00211028-0021 1036)
SIPRNET Computer 22.225.41.22 (00211037-00243945 and
00243882?00374370)

v. 06.4 Documents (00374371-003 75007)

Pawnee?

Administrative Investigations (note: 1 will not consider sworn statements, agent?s
investigation reports. interview MFRs, or canvass interview worksheets contained in
these documents):
1. AR 380-5 Investigation (00000663?00000771)
2. USF-I AR 15-6 Investigation
3. SecArmy AR 15-6 Investigation
a. Batch #1 (00013162-00020152)
b. Batch #2 (00036787-00036788)

Enemy Possession of Wikileaks Material:
Al-Qa?ida Recruiting Video (00408202-00408236}
Al-Qa?ida in the Arabian Peninsula Magazine (00012570-0001271
Enemy Number 1 Possession Report (classified evidence)
Enemy Number 2 Possession Report (classi?ed evidence)
Enemy Number 1 Possession Evidence
a. HR 6 089 0563 11 (Redacted) (00410660-00410664)
b. Metadata display (00410658-00410659)
c. Forensically Recovered Material (00410654-00410657)



Miscellaneous Documents:
DCGS-A Logon Banner {00.376855003768561
C3 Document {'00378141-00378147)
PFC Manning's Military Intelligence Work Product
Storyboard (00410603-00410606)
Range Storyboard {00410607-00410609)
11R 6 068 4579 10 (00410610-00410612)
SIPRNET Email, dated 100112100410613?00410614)
SIPRNET Email, dated 100224 (00410615)
SIPRNET Email, dated 100308 (00410616)
SIPRNET Email. dated 100419 (00410617)
SIPRNET Email. dated 100425 (00410618)

i. SIPRNET Email. dated 091130 (00410600-004106021
4. WikiLeaks Background

a. WikiLeaks Most Wanted Leaks of2009. dated 090830 (00410561-

00410571)

bl

ww



hr Nu-

AFRC-MJVA
SUBJECT: Evidence List

b. WikiLeaks Most Wanted Leaks of 2009. dated 091 105 (00410572-
00410583)
c. WikiLeaks Most Wanted Leaks of 2009. dated 100522 (00410584-
00410593)
Afghanistan War Logs Posted by WikiLeaks (00410668?00410670)
Tweet. dated 10050? (00410594-00410595)
Tweet. dated 100108 (00410596-00410597)
g. Tweet. dated 1.00216 (00410598-00410599)
5. PFC Manning?s Other Docntnents
a. WikiLeaks Contact Information File (00409721)
b. CIDNE Types File (00409719)
Written Note Related to GAL Extraction (00409720)
d. Screenshot of Google Search for GAL Extraction Macro (00409679)
Early Bird Article, dated 20100318 (00409686-00409718)
f. Mac Quickstart Bar Screenshot (00409680)


i.

ewth



. Mac Password Keychain Screenshot (00409683)
Email dated 100520 (00409681)
Email dated 100520 (00409682)
j. Email. dated 100408 (00409684)
Email, dated 100410 (00409685)
1. HR 5 332 006910(00410619-00410622)
6. Defense Information Systems Agency. Documents
a. Trickler Report (00410653)
b. DISA Trickler Report Encl 1 (00410650)
c. DISA Trickler Report Encl 3 (00410651
7, OthEr
CIDNE Data on the Internet (00410554)
GAL Extraction Instructions Screenshot (00410555)
ENTCOM Sharepoint Architecture (00410635)
NC Valuation Documents (00410556-00410560).



i. Common References:
1. United States Code
a. 18 L1.S.C. 793(e)
b. 18 U.S.C. 51$ 64]
c. 18 1030(a)(1)
Executive Orders
a. E0 12958
b. E0 13292
e. E0 13526
Regulations
a. AR 380-5 (00001408-00001718)
b. AR 25-2 ('00038974-00039076)
c. CENTCOM Regulation 25-206 (00016128-00016229)



Lu

w.

AF RC -M.IVA
SUBJECT: Evidence List

4. Public Lave 1ft7-4U. for Use of Military Force. 18 September
2001.

. Please address all questions or concerns to the undersigned at

. for this memorandum is the undersigned.

tJ

EJJ

fir fa,

PAUL R.
LTC. JA. LTSAR
Investigating Officer

CF:
MAJ Matthew Kemke
Paul Bouchar
CPT Ashden Fein (at
Mr. David (foombs [a
CPT .loDean Morrow
CPT Angel Overgaard
CPT Jeffrey W11 yte (a
[fl?C Mark Iiolzcr (at






DEPARTMENT OF THE ARMY
150TH JUDGE GENERAL (LSD)
MG ALBERT c. LIEBER USAR CENTER
59m TELEGRAPH ROAD

ALEXANDRIA, VIRGINIA 22310-3320
REPLY To

ATTENTION OF



AFRC-M.WA 14 December 20]

MEMORANDUM FOR US v. Manning Article 32(b) Participants

SUBJECT: Determinations Regarding Defense Objections to Government Evidence

I. On 12 December 201 I. Mr. Coombs. CPT Fein. and I engaged in a telephone conference
where we discussed the government?s 2 December and 7 December requested evidence lists.
During that conversation, the defense either stated they did not object to certain listed items of
evidence or raised an objection. The government then responded to objections. This document
provides my determinations regarding the defenses objections.

a. Charged Documents:
l. Batch #1 (00376954-00377572))
2 Batch #2 (00377626-00377675}
3. Batch #3 (00377845-00378140).

There was no defense objection to these documents.

b. Classi?cation Reviews:

1. CENTCOM (00376871-00376873)
DISA (00376890-00376890)
CYBERCOM (00376875-003 76878)
CENTCOM (0037?6879-003 76902)
(00376903-00376953)
Other
SOUTHCOM (00.378646003753649)
OGA (00410623-00410634}.

.45 s? t4



The defense objected that unsworn statements cannot be considered over defense objection under
ROM. The Government responded that statements made under penalty ot'perjury
can be considered. Per the legal advisor's advice. these statements can be considered.

c. Accused?s Personnel Records:
1. PFC Manning?s OMPF (00000116-00000164):
2. PFC Manning?s ERB (00000006)
3 Security Clearance Documents
3. Batch #1 (000156]7-00015619)
b. Batch #2 (00022898-00022913)
c. Batch #3 (00022947-00022949)

IHV. GFER. {dbl


SUBJECT: Determinations Regarding Defense Objections to Government Evidence

d. Batch #4 (00036801-00036802)
e. Batch #5 (00000430?00000450n.

There was no defense objection to these documents.

(1. Accused?s Training:
1. AIT Training

a. Batch #1 (00001052-00011344)

b. Batch #2 (00011649-00012569)

The defense objected under R.C.M. that these documents cannot be considered
because they are not authenticated. The government responded that they are not sure this
represents the exact AIT training the accused received. but they have a witness who can describe
the training he received. I will not consider these documents.

2. AIT Corrective Training Slideshow (00125314-00125316)
3. Information Assurance Training

IA Exam {00375768?00375 77]

Training Requirement (003 75772)

Virtual Training (00375773)

IA Virtual Training #2 (00375774)

Test Results (00022348)



The defense objected under R.C.M. 405Ig_)i5 that these documents cannot be considered
because they are not authenticated. The government responded that these documents can be
authenticated by agents. Subject to authentication. I will consider these documents.

IA Awareness-October2008-v7_0 Training Disk (00409673)
IA Awareness-OctoberZ009-v8_0 Training Disk (00409674)
Phishing Awareness-April2008-vl_0 Training Disk (00409675)
PlI-October 2007-vl_0 Training Disk (00409676)

.H-g'tr: rt:

There was no defense objection to these documents.

4. Pre-Deplovment Training
a. Iraq Overview PowerPoint (00409722-00409740)
b. Afghanistan Overview PowerPoint (00409741-00409780)
5. Classi?ed Information Systems. IDNE Export Screenshots (00410665-
00410667)

There was no defense objection to these doctunents.
e. Law Enforcement Investigations:

1. CID Case File
a. Batch #1 {:00000179-00000376)



AFRC-MJVA



SUBJECT: Determinations Regarding Defense Objections to Government Evidence

3 53-5227

Batch #2 (00000402-0000041 1}
Batch #3 (00021 364?0110255261
Batch #4 (00026079-00026082)
Batch #5 (00026356-00036786}
Batch #6 {00045302-00046073)
Batch #7 {003751 83410375724}
Batch #8 (00378219?00378623)
Batch #9 {00378620003781.5451
Batch 10 (00407991-00408088)
Batch #1 1 (00409673-00409678}
Batch #12 (00409781-00410553}

. Batch #13 (0041 DEBS-00410649)

The defense objected that these documents contained hearsay within hearsay. and that Ale and
sworn statements cannot be considered over defense objection. The government responded that
multiple agents can testify as to the contents of these documents. I will consider these
documents, but will not consider swom statements. AIRS, or canvass interview worksheets.

2. C1D Forensic Reports



V.

10th Mountain Shares (00046074-00046451 1

Army Intelligence Report (00046452-00046566)
CENTAUR Logs (00046567-000526161

ENTC OM Server {00052617-0005431 1 1

CIDNE Files (00054312-00054319)

Department of State Files (000543204101 19042)
SOUTHCOM Comparison (00375008-00375115)

Intelink Logs (00] 1904300375129)

Lamo Chats {'00124107-00124282)

PFC Manning?s Personal Computer {00124283-00125269)
PFC Manning's External Hard Drive (00125270?00125318)
PFC Manning?s SD Card (00125319-00199473)

. Computers 148.17.172.115 and 22.225.28.54 (00199474-00199485)

SIPRNET Computer 22.225.29.185 (00199486-00199493}
SIPRNET Computer 22.225.41.40 (00199494?001995 10)
PFC Marming's CD {0019951 1-0199523)

NIPRNET Computer 144.107.17.139 (00199524-00199555)
NIPRNET Computer 144.107.19 (00199556-00211019)
NIPRNET Computer 147.198.178.143 {'00211020-00211027}
SIPRNET Computer 22.225.28.216 (0021 1028-0021 1036}
SIPRNET Computer 22.225.41.22 (0021 103 7-00243945 and
00243 882-0033743701

OGA Documents (003 74371-00375007}

There was no defense objection to these documents.



AFRC-MIVA
SUBJECT: Determinations Regarding Defense Objections to Government Evidence

f. Military Intelligence Investigations:

1. Investigation #1
a. Batch #1 (00044865-00045301)
b. Batch #2 (00375173?00375182)
c. Batch #3
(1. Batch #4 (003 T7748-003 77844)
e. Batch #5 (00378203-00378218)

2. Investigation #2
a. Batch #1 (00375130-00375172)
b. Batch #2 (00377573-00377581}
c. Batch #3 (00377736-00377747)
d. Batch #4 (00378177-00378202)

3. Investigation #3 (00377676?00377735)

The defense objected under R.C.M that these documents cannot be considered
because they are not authenticated. The government responded that they will not have a military
intelligence witness to authenticate these documents. and that they are incorporated in the CID
investigative documents. I will not consider these documents.

g. Administrative Investigations:
1. AR 380-5 Investigation (00000663?00000771)
2. USF-I AR 15-6 Investigation
3. SecArmy AR 15-6 Investigation
a. Batch #1 {00013162-00020152)
b. Batch #2 {00036787-00036788}

There was no defense objection to these documents. I will consider these documents, but will
not consider sworn statements. interview MFRs, AIRS, and canvass interview worksheets.

h. Enemy Possession of Wikileaks Material:
1. AI-Qa?ida Recruiting Video (00403202-00408236l

Al-Qa?ida in the Arabian Peninsula Magazine (00012570-00012711)
Enemy Number 1 Possession Report (classified evidence}
Enemy Number 2 Possession Report (classi?ed evidence)
Enemy Number 1 Possession Evidence

a. 6 039 0563 II (Redacted) (00410660?00410664}

b. Metadata display (00410658?00410659)

c. Forensically Recovered Material (00410654?00410657')

Meww

The defense objected under RC .M that these documents cannot be considered
because they are not authenticated. The government responded that these documents can be
authenticated by agents. Subject to authentication. I will consider these documents.

i. Miscellaneous Documents:
1. DCGS-A Logon Banner (00376856-00376856)

AFRC-MJVA

SUBJECT: Determinations Regarding Defense Objections to Govermnent Evidence

2. C3 Document (00378141-00378147)
3. PFC Manning?s Military Intelligence Work Product



i.

Storyboard (00410603-00410606}

Range Storyboard (00410607?00410609)

11R 6 068 4579 10 (00410610-00410612)

SIPRNET Email, dated 100112 (00410613-00410614}
SIPRNET Email. dated 100224 (00410615)

SIPRNET Email. dated 100308 (00410616)
SIPRNET Email. dated 100419 (00410617)

SIPRNET Email, dated 100425 (00410618)
SIPRNET Email, dated 09] 130 (00410600-00410602)

The defense objected under R.C.M that these documents cannot be considered
because they are not authenticated. The government responded that these documents can be
authenticated by agents. Subject to authentication. I will consider these documents.

4. WikiLeaks Background

a.

b.



WikiLeaks Most Wanted Leaks of 2009, dated 090830 (00410561-

00410571)

WikiLeaks Most Wanted Leaks of2009, dated 091 105 (00410572-

00410583")

WikiLcaks Most Wanted Leaks ot?2009. dated 100522 (00410584-

004105931

Afghanistan War Logs Posted by WikiLeaks {00410668-00410670)
Tweet, dated 100507 (00410594-00410595)

Tweet. dated 100108

Tweet, dated 100216 {00410598?00410599)

The defense objected under R.C.M that these documents cannot be considered
because they are not authenticated. The government responded that these documents can be
authenticated by agents. Subject to authentication, 1 will consider these documents.

5. PFC Manning?s Other Documents

Fen-?ere er.? 4.0.624

WikiLeaks Contact Information File (00409721)

CIDNE Types File (004097191

Written Note Related to GAL Extraction (00409720)
Screenshot ofGoogle Search for GAL Extraction Macro (00409679)
Early Bird Article. dated 20100318 (00409686-004097181
Mac Quickstart Bar Screenshot (00409680)

Mac Password Keychain Screenshot (004096831

Email dated 100520 (00409681)

Email dated 100520 (00409682)

Email. dated 100408 {00409684}

Email. dated 100410 {00409685}

11R 5 332 0069 10 (00410619-00410622)

V.

AFRC-MJVA
SUBJECT: Determinations Regarding Defense Objections to Government Evidence

The defense objected under R.C.M that these documents cannot be considered
because they are not authenticated. The government responded that these documents can be
authenticated by agents. Subject to authentication, I will consider these documents.

6. Defense Information Systems Agency Documents
a. DISA Trickle-r Report (00410653)
b. DISA Trickler Report Encl 1 (00410650)
c. DISA Trickler Report Encl 3 (00410651)

The defense objected under R.C.M that these documents cannot be considered
because they are not authenticated. The government responded that these documents can be
authenticated by agents. Subject to authentication. 1 will consider these documents.

7. Other
a. IDNE Data on the Internet (00410554)
b. GAL Extraction Instructions Screenshot (00410555)
c. ENTC OM Sharepoint Architecture {00410635}
d. NCD Valuation Documents (00410556-00410560j.

The defense objected under R.C.M that these documents cannot be considered
because they are not authenticated. The government responded that these documents can be
authenticated by agents. Subject to authentication. 1 will consider these documents.

j. Common References:
1. United States Code
a. 18 U.S.C. T9302)
b.
c. 18 U.S.C.

2. Executive Orders
a. E0 12958
b. EO 13292
e. E0 13526

3. Regulations
a. AR 380-5 (00001403-00001718}
b. AR 25-2 (00033974?00039076)
c. CENTCOM Regulation 25-206 (00016128-00016229)
4. Public. Law 107-40. Authorization for Use of Military Force. 18 September
2001.

There was no defense obj ection to these documents.

3. Please address all questions or concerns to the undersigned at pauI.r.almanza@us.army.mil
and at

h?v

AFRC-MJVA
SUBJECT: Determinations Regarding Defense Objections to Evidence

4. PUC for this memorandum is the undersigned.



PAUL R.
LTC- .lA.
Ink-emigrating. Of?cer

CF:
MAJ Matthew
Paul Bouchar
CPT Ashden Fair: (at a
Mr. David (?oomhs {a
CPT JoDean Moran-V
Angel Ow-?ergamrd
CPT Jeffrey Whyte (a
MC Mark Holzer {at 1








00605





DEPARTMENT OF THE ARMY
150TH JUDGE ADVOCATE GENERAL DETACHMENT
MG ALBERT c. LIEBER USAR CENTER
6901 TELEGRAPH ROAD
ALEXANDRIA. 22310?3320

REF LY TO
ATTENTION DF

15 December 2011

MEMORANDUM FOR US v. Manning Article 32th) Participants

SUBJECT: Determinations as to Defense Requested Evidence

I. This document provides my determinations as to defense requested evidence listed in the
defenses 1 December 201 1 request to compel production of evidence:

d.

The video Manning being ordered to surrender his clothing at the direction of
CW4 Averhart and his subsequent interrogation on 18 January 2011 - this evidence is
not relevant to the form of the charges, the truth of the charges. or information as may
be necessary to make an informed recommendation as to disposition; specifically. the
circumstances surrounding PFC Manning?s placement in suicide risk are not relevant
to a determination as whether PFC Manning committed the charged offenses and if
so. what the disposition of those charges should be.

A copy of adverse administrative or UCMJ actions. and all supperting documentation
and rebuttal materials, based upon the AR 15-6 investigation conducted by LTG
Caslen or any other governmental investigation this evidence is not relevant to the
form of the charges, the truth of the charges, or information as may be necessary to
make an informed recommendation as to disposition; speci?cally. whether or not
other individuals received adverse action as a result of their conduct described in that
investigation (and note that there is no indication that such conduct was substantially
similar to the totality of the conduct PFC Manning is alleged to have engaged in) is
not relevant to a determination as to whether PFC Manning committed the charged
offenses and if so. what the disposition of those charges should be.

An Encase forensic image of each computer from the T-SC IF and the TOC of HHC.
EBCT. 10lh Mountain Division, FOB Hammer. Iraq this evidence is relevant as it
could help establish that it was common for soldiers in these locations to place
unauthorized software to these computers; however. this evidence is not reasonably
available because its signi?cance is lessened by the fact it is cumulative to the
testimony of at least CPT Keay and PT herepko, and as the government has
indicated that it is still working to preserve this evidence. its limited signi?cance is
not outweighed by the delay ofobtaining this evidence.

A damage review or assessment of the alleged disclosures in this case led by Mr.
Russell Travers. any communications concerning those disclosures by any
governrnental employee to President Obama. and any communications concerning
this case by President Obama to the Departments of Defense. State. or Justice this
evidence is not relevant to the form of the charges. the truth of the charges. or
information as may be necessary to make an informed recommendation as to

111V. UFCR. Eiililiill





SUBJECT: Determinations as to Defense Requested Evidence

Us

disposition; speci?cally, the extent of the harm caused by the alleged disclosures and
whether any statements by President Obama may have influenced the prosecution in
this case are not relevant to a determination as to whether PFC Manning committed
the charged offenses and if so, what the disposition of those charges should be.
Damage assessment conducted by the Information Review Task Force and the Of?ce
of Security this evidence is not relevant to the form ofthe charges, the truth of the
charges, or information as may be necessary to make an informed recommendation as
to disposition; speci?cally. the extent of the harm caused by the charged offenses is
not relevant to a determination as to whether PFC Manning committed the charged
offenses and if so. what the disposition of those charges should be. Additionally, I
understand from the 12 December 2011 telephone conference with CPT Fein and Mr.
Coombs that the government does not have the authority to disclose damage
assessments and thus I conclude that any evidence of damage assessments is not
reasonably available.

Collateral investigations by the Department of State, the FBI. DIA, the Of?ce of the
National Counterintelligence Executive, and the CIA this evidence is not reasonably
available; as this was a joint investigation, this evidence is cumulative with evidence
of the CID case file, and its limited signi?cance is not outweighed by the delay in
obtaining this evidence.

The Department of Justice investigation into the alleged disclosures as referenced by
Attorney General Holder, including grand jury material, 18 U.S.C. Section 2703M)
orders, and search warrants this evidence is not reasonably available; as this was a
joint investigation, this evidence is cumulative with evidence of the CID case ?le, and
also the government has said it has no knowledge of grand jury testimony or search
warrants from the Department of Justice, which leads to a conclusion that the limited
signi?cance ofthis evidence is not outweighed by the delay in obtaining it.

The Department of State damage assessment review conducted by its task force of
over 120 individuals this evidence is not relevant to the form of the charges, the
truth of the charges. or information as may be necessary to make an informed
recommendation as to disposition; speci?cally, the extent of the harm caused by the
charged offenses is not relevant to a determination as to whether PFC Manning
committed the charged offenses and if so, what the disposition of those charges
should be. Additionally, I understand from the 12 December 201 1 telephone
conference with CPT Fein and Mr. Coombs that the government does not have the
authority to disclose damage assessments and thus I conclude that any evidence of
damage assessments is not reasonably available.

The Damage Assessment ofCompromised Information required to be submitted to
the $50 under 5 105.21-Msl once an SCI security official determines that a
security violation has occurred, and the final security investigation violation report
submitted to the 880 under this evidence is not
reasonably available because the government has indicated that this regulation only
applies to violations involving the compromise of Sensitive Compartmented
Information material and there is currently no evidence indicating a compromise of
such material in this case.



AFRC-MJVA
SUBJECT: Determinations as to Defense Requested Evidence

2

. Please address all uestians or concerns. In the undersigned at?




3. POC for this memm?andum is the undersigned.

7 r?

PAUL R. ALMANZA
LTLI JA. USAR
lax-?astigmng Of?cer

C13:

MAJ Matthew Kemk

Paul Bouehar
Ashden Fcin (at

Mr. David Coomhs {a
CPT .TODean Morrow
Angel Overgaar

PT Jeffrey Why-1:: (a
LTC Mark l-inizei? {a1





AFRC-MJVA

DEPARTMENT OF THE ARMY
15am JUDGE ADVOCATE GENERAL DETACHMENT
MG ALBERT c. LIEBER usas CENTER
5901 TELEGRAPH ROAD
ALEXANDRIA. VIRGINIA 22310?3320

T0
INTENTION OF

15 December 20] 1

MEMORANDUM FOR US v. Manning Article 32(b) Participants

SUBJECT: Determinations as to Defense Requested Witnesses

I. This document provides my determinations as to defense requested witnesses.

SA Toni Graham - she is not reasonably available because while her testimony is
relevant, she is located in Hawaii and the significance of her expected testimony with
respect to the ?rst month of the investigation and her personal appearance does not
outweigh the difficulty and cost of obtaining her presence at the investigation.

SA Mark Mander reasonably available.

SA Calder Robertson - he is not reasonably available because while his testimony is
relevant, he is located in Germany and the signi?cance of his expected testimony with
respect to obtaining the collection of digital evidence and forensic imaging does not
outweigh the dif?culty and cost ofobtaining his presence at the investigation.

SA David Shaver reasonably available.

SACharles Ames his expected testimony is cumulative with other law enforcement
witnesses involved in the investigation; to the extent his testimony would cover the
collection of classified information for the Information Review Task orce?s damage
assessment, I understand from the 12 December 2011 telephone conference with CPT
Polo and Mr. oombs that the government does not have the authority to disclose
damage assessments and thus I conclude that any testimony concerning such topics
would not be permissible.

SA Alfred Williamson reasonably available.

SA Troy Bettencourt reasonably available.

SA Ronald Rock as the law enforcement investigation was ajoint investigation. his
expected testimony is cumulative with other law enforcement witnesses involved in
the investigation.

SA Patrick Wheeler as the law enforcement investigation was ajoint investigation,
his expected testimony is cumulative with other law enforcement witnesses involved
in the investigation; moreover, his testimony concerning his contacts with Mr. Adrian
Lamo is cumulative with Mr. Lamo?s testimony.

CPT Martin Liebman his expected testimony is not relevant to the form of the
charges. the truth of the charges. or information as may be necessary to make an
informed recommendation as to disposition; speci?cally. CPT Liebman?s concerns
about PFC Manning?s mental health did not rise to the level of causing him to
indicate that PFC Manning was not suitable for continued access to classified
material, and thus are not relevant to a determination as to whether PFC Manning

luv. arcs. EthiBti

AFRC-MJVA
SUBJECT: Determinations as to Defense Requested Witnesses

committed the charged offenses and if so, what the disposition of those charges
should be. I note that with respect to all the defense-requested witnesses concerning
PFC Manning's mental health issues, the government has stated that on 22 April

20] 1, an R.C.M. 706 board concluded that Manning did not have a severe
mental disease or defect at the time of the alleged criminal conduct that resulted in
him being unable to appreciate the nature and quality or wrongfulness of his
conduct.?)

k. CPT Michael Worsley his expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition: speci?cally, PT Worsley?s concerns
about PFC Manning?s behavior and issues did not rise to the level of causing him to
recommend to the command that they should suspend PFC Manning's clearance and
thus is not relevant to a determination as to whether PFC Manning committed the
charged offenses and if so, what the disposition of those charges should be.

1. CPT Edan Critch?cld - his expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; specifically, CPT Critchfield only
recommended that PFC Manning was not suitable for continued access to classi?ed
material and that his security clearance should be suspended on 28 May 2010, after
the dates of all charged offenses, and despite his determination on 22 May 2010 that
PFC Manning was at risk to himself and others, he did not make a recommendation as
to PFC Manning?s continued access to classified information on that date due to
having been informed that PFC Manning was no longer allowed in the T-SCIF, and
thus is not relevant to a determination as to whether PFC Manning committed the
charged offenses and if so, what the disposition of those charges should be.

m. COL David Miller his expected testimony is not relevant to the form of the charges,
the truth of the charges, or information as may be necessary to make an informed
recommendation as to disposition; specifically, whether the command could or should
have monitored and addressed PFC Manning?s conduct and behavior better, and
whether the command should have removed his access to classi?ed information
earlier, is not relevant to a determination as to whether PFC Manning committed the
charged offenses and if so, what the disposition of those charges should be.

n. LTC Brian Kems his expected testimony is not relevant to the form of the charges.
the truth of the charges, or information as may be necessary to make an informed
recommendation as to disposition; speci?cally. whether the command could or should
have monitored and addressed PFC Manning?s conduct and behavior better, and
whether the command should have removed his access to classified information
earlier, is not relevant to a determination as to whether PFC Manning committed the
charged offenses and if so, what the disposition of those charges should be.
Moreover, his information as to whether unauthorized mediafprograms were
commonly on SIPRN ET computers is cumulative to the testimony Cherepko.
CPT Keay, and SGT Padgett, and his testimony as to remedial measures the
command took to improve INFOSEC measures is not relevant as it post-dates the
charged offenses.




SUBJECT: Determinations as to Defense Requested Witnesses

o. MAJ Elijah Dreher his expected testimony is not relevant to the form of the
charges, the truth of the charges. or information as may be necessary to make an
informed recommendation as to diSposition; speci?cally, whether the command could
or should have monitored and addressed PFC Manning?s mental health issues better,
and should have left PFC Manning back instead of taking him on the deployment, and
whether or not he was aware or should have been aware Manning?s mental
health issues, is not relevant to a determination as to whether PFC Manning
committed the charged offenses, and if so. what the disposition of those charges
should be.

p. MAJ Clifford D. lausen his expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; specifically. whether the command could
or should have monitored and addressed PFC Manning?s conduct and behavior better
is not relevant to a determination as to whether PFC MaIming committed the charged
offenses and if so. what the disposition of those charges should be. Moreover, his
information as to whether music CDs were allowed in the T-SCIF is cumulative to the
testimony of CPT Cherepko. CPT Keay. and SGT Padgett.

q. CPT Barclay Keay not reasonably available due to previously scheduled leave;
although he would have been available on 3 or 4 January 2012, the significance of his
testimony does not outweigh the delay in securing his personal appearance.
understand the government and the defense join in requesting that he be considered
not reasonably available and that he testify by telephone.

CPT Matthew W. Freeburg his expected testimony is not relevant to the form ofthe
charges, the truth of charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command could
have monitored and addressed PFC Manning's conduct and mental health issues
better, the circumstances of his removing PFC Manning from the T-SCIF and
assigning him to the supply room, the Article 15 PFC Manning received, CPT
Freeburg?s interaction with CPT Worsley where he received CPT Worsley's opinion
as to the extent of PFC Manning?s condition, his sending PFC Manning to CPT
Criteh?eld for an evaluation, and his initiation of chapter paperwork, is not relevant
to a determination as to whether PFC Manning committed the charged offenses,
especially as PT ritchlield did not recommend that PFC Manning?s access to
classi?ed infonnation be rescinded. His information as to whether videogames,
movies. and music was placed on the is cumulative to the testimony of CPT
Cherepko, CPT Keay. and SGT Padgett.

s. CPT Steven Lim - reasonably available.

1. CPT Thomas herepko reasonably available.

u. CPT Michael Johnson his expected testimony is not relevant to the form of the
charges, the truth of the charges. or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command could
or should have monitored and addressed PFC Manning?s conduct and behavior better
is not relevant to a determination as to whether PFC Manning committed the charged
offenses and ifso, what the disposition of those charges should be.

AFRC-MJVA



SUBJECT: Determinations as to Defense Requested Witnesses

V.



1LT Tanya Gaab her expected testimony is not relevant to the form of the charges,
the truth of the charges. or information as may be necessary to make an informed
recommendation as to disposition; speci?cally, whether the command could or should
have monitored and addressed PFC Manning's conduct and mental health issues
better, and why they did not remove him from the T-SCIF earlier, is not relevant to a
determination as to whether he committed the charged offenses and if so, what the
disposition of those charges should be.

1LT Elizabeth Fields her expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command could
or should have monitored and addressed PFC Manning?s conduct and mental health
issues better, and why they did not remove him from the T-SCIF earlier. is not
relevant to a determination as to whether he committed the charged offenses and if so.
what the disposition of those charges should be. Her information as to whether CDs
and DVDs were permitted in the T-SCIF is cumulative to the testimony of at least
CPT Lim and SGT Padgett.

CW2 Joshua Ehresman his expected testimony is not relevant to the fonn of the
charges, the truth ofthe charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command could
or should have monitored and addressed PFC Manning?s conduct and behavior better,
and whether the command should have taken PFC Manning on the deployment, as
well as CW2 Ehresman?s recommendation, after an incident in which he intervened,
that PFC. Manning have his weapon?s bolt removed, be sent to mental health, and then
be separated from the Army, which resulted in no action being taken, is not relevant
to a determination as to whether PFC Manning committed the charged offenses and if
so, what the disposition of those charges should be.

MSG Eric Usbeck his expected testimony is not relevant to the form of the charges,
the truth of the charges, or information as may be necessary to make an informed
recommendation as to disposition; speci?cally, whether the command could or should
have monitored and addressed PFC Manning?s conduct and behavior better, and
whether the command should have taken PFC. Manning on the deployment, as well as
his counseling PFC Manning and referring him to mental health for evaluation, and
his not personally following up after learning that PFC. Manning did not in fact go to
mental health is not relevant to a determination as to whether PFC Manning
committed the charged offenses and if so, what the disposition of those charges
should be. Additionally, his information as to the counseling of PFC Manning is
cumulative with Ms. Showman?s.

MSG Mark Woodworth his expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; specifically, his being briefed on PFC
Manning?s issue with another soldier or his assault on SPC Showman, and his
knowledge that PFC Manning was moved to the supply room. and his lack of
recollection about any discussion of sending PFC Manning back to the States or
chaptering him out. and his knowledge of the search of PFC Manning?s quarters and





SUBJECT: Determinations as to Defense Requested Witnesses

aa.
bb.

CC.

dd.

68.

ff.

3g-

hh.

work space, is not relevant to a determination as to whether PFC Manning committed
the charged offenses and if so, what the disposition ofthose charges should be.

SFC Paul Adkins reasonably available (pending invocation of rights issue).

SSG Lawrence Mitchell his expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the whether the
command could or should have monitored and addressed PFC Manning's conduct
and behavior better, whether SFC Adkins did not do anything to address PFC
Manning?s issues, whether PFC Manning was gay, and whether the command should
have chaptered him out of the Army, is not relevant to a determination as to whether
PFC Manning committed the charged offenses and if so, what the disposition of those
charges should be.

SGT Rebecca Schwab her expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether PFC Manning was
gay and whether he had emotional issues that made him difficult to adjust to military
life is not relevant to a determination as to whether he committed the charged
offenses and if so, what the disposition of those charges should be.

SGT Daniel Padgett reasonably available.

SGT David Sadtler - his expected testimony is not relevant to the form of the
charges. the truth of the charges. or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command
ostracized PFC Manning and did not support him, and disregarded his concerns about
a particular report, is not relevant to a determination as to whether he committed the
charged offenses and if so, what the disposition of those charges should be.

SGT Lorena Cooley - her expected testimony is not relevant to the form of the
charges. the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; specifically, whether PFC Manning was
picked on by other soldiers because they assumed he was gay, the nature of SFC
Adkin?s leadership, and whether PFC Manning should have gotten help for his issues
before they deployed is not relevant to a determination as to whether he committed
the charged offenses and if so, what the disposition ofthose charges should be.
Additionally, her information about CDs for music and movies being placed on
SIPRNET computers is cumulative to at least CPT Cherepko and CPT Keay.

SGT Sheri Walsh her expected testimony is not relevant to the form of the charges,
the truth of the charges, or information as may be necessary to make an informed
recommendation as to disposition: specifically, whether PFC Manning had
relationship and gender identity issues and whether other soldiers made fun of him
due to his size and their belief he was gay, his response to a particular incident, and
her opinion as to whether the Army was a good ?t for him at this time of his life, is
not relevant to a determination as to whether he committed the charged offenses and
if so. what the disposition of those charges should be.

Ms. Jihrleah Showman she is not reasonably available because while her testimony
is relevant. she is located in Syracuse. NY and the signi?cance of her expected

U1

AFRC-MJVA



SUBJECT: Determinations as to Defense Requested Witnesses

ii.

kk.

l'Il.

nn.

testimony with respect to her recommendation to SFC Adkins that PFC Manning not
deploy due to his emotional issues, the circumstances of her viewing the ?Apache
video" in the and her experiences as PFC Manning?s direct supervisor do not
outweigh the difficulty and cost of obtaining her presence at the investigation.

Mr. Adrian Lamo reasonably available.

President Barack Obama his expected testimony is not relevant to the form ofthe
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether any statements by
President Obama may have in?uenced the prosecution in this case, the extent of the
harm caused by the alleged disclosures, or the alleged problem of over-classi?cation
is not relevant to a determination as to whether PFC Manning committed the charged
offenses and if so, what the disposition of those charges should be. The defense may
of course voir dire the investigating of?cer to inquire as to whether any unlawful
command influence taints the Article 32 investigation.

Former Secretary Robert Gates his expected testimony is not relevant to the form of
the charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, the extent ofthe harm
caused by the charged offenses, the initial public descriptions of the harm caused by
the charged offenses. and the effect of the charged offenses on foreign policy is not
relevant to a determination as to whether PFC Manning committed the charged
offenses and if so, what the disposition of those charges should be. Additionally, to
the extent his testimony would cover the damage review conducted by the
Information Review Task Force's damage assessment, I understand from the 12
December 201 1 telephone conference with CPT Fein and Mr. Coombs that the
government does not have the authority to disclose damage assessments and thus I
conclude that any testimony concerning such topics would not be permissible.
Secretary Hillary Clinton 4 her expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, her raising the issue of the
disclosed diplomatic cables with foreign leaders, the extent of the harm caused by the
charged offenses, and the effect of the alleged disclosures on foreign policy is not
relevant to a determination as to whether PFC Manning conunitted the charged
offenses and if so, what the disposition of those charges should be.

PT James Kolky his expected testimony is not relevant to the form of the
charges, the truth of the charges. or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether three Apache gun
videos that were sent to his Division were not classi?ed at the time of their alleged
release and whether they should have been, recognizing that the government states
the video is not classi?ed and does not allege it is classi?ed, is not relevant to a
determination as to whether PFC Manning committed the charged offenses and if so,
what the disposition of those charges should be.

RADM Kevin Donegan he is not reasonably available because while his testimony
is relevant, he is located in Florida and is Director of Operations; the
significance of his expected testimony with respect to his classification

AFRC-MJVA

*0

SUBJECT: Determinations as to Defense Requested Witnesses

00.

pp.

CM-

53.

It.

1111.

determinations concerning the two PowerPoints at issue does not outweigh the
dif?culty. expense. and effect on military operations of obtaining his presence at the
investigation.

Mr. Robert Beta he is not reasonably available because while his testimony is
relevant, he is Chief Classi?cation Advisory Officer; the signi?cance
of his expected testimony with respect to his classi?cation determinations concerning
the alleged chat logs between Mr. Lame and PFC Manning does not outweigh the
effect on military operations of obtaining his presence at the investigation.

LtGen Robert Schmidle. Jr. he is not reasonably available because while his
testimony is relevant, he is Deputy Commander; the signi?cance of
his expected testimony with respect to his classi?cation determinations concerning
the alleged chat logs between Mr. Lamo and PFC Manning does not outweigh the
effect on military operations of obtaining his presence at the investigation.

VADM Robert Harward he is not reasonably available because while his testimony
is relevant, he is located in Florida and is CENTC OM ?5 Deputy Commander; the
significance of his expected testimony with respect to his classi?cation
determinations concerning the CIDNE Afghanistan Events. CIDNE Iraq Events, other
briefings and the BE22 PAX.wmv video does not outweigh the difficulty, expense.
and effect on military operations ofobtaining his presence at the investigation.

Mr. Patrick Kennedy he is not reasonably available because while his testimony is
relevant. he is Undersecretary of State for Management: the signi?cance of his
expected testimony with respect to his classi?cation determinations concerning
diplomatic cables does not outweigh the dif?culty of obtaining his presence at the
investigation.

RADM David Woods he is not reasonably available because while his testimony is
relevant. he is Commander of the Joint Task Force - Guantanamo; the signi?cance of
his expected testimony with respect to his classi?cation determinations concerning
the documents at issue does not outweigh the dif?culty. expense. and effect on
military operations ofobtaining his presence at the investigation.

CAPT Kevin Moore his expected testimony is not relevant to the form of the
charges. the truth ofthe charges. or information as may be necessary to make an
informed recommendation as to disposition; Specifically. whether the Security
Battalion commander at the Quantico Brig made determinations concerning
Prevention of Injury precautions that behavioral health did not believe were necessary
is not relevant to a determination as to whether PFC Manning committed the charged
offenses and ifso. what the disposition of those charges should be.

CAPT William Hochter his expected testimony is not relevant to the form of the
charges, the truth of the charges. or information as may be necessary to make an
informed recommendation as to disposition: speci?cally. whether the Security
Battalion commander at the Quantico Brig made determinations concerning
Prevention of Injury precautions that behavioral health did not believe were necessary
is not relevant to a determination as to whether PFC Manning committed the charged
offenses and if so. what the disposition of those charges should be.

AF RC - MJ A
SUBJECT: Determinations as to Defense Requested Witnesses

2. Please address all questions or concerns to the undersigned at

3. far this memorandum is the undersigned.



PAUL R. ALMANZA

LTC. JA, USAR
Investigating Of?cer

I:

MAJ Matthew Kemk
Paul Beuehar
CPT Ashden Fein {at
Mr. David (.?nernbs (a
CPT JeDean Metros-v
PT Angel Orergaar
CPT Jeffrey Why-1e {a
LTC Mark Helzer (at





AFRC-MJVA

DEPARTMENT OF THE ARMY
150m JUDGE GENERAL DETACHMENT {Lsoi
MG ALBERT c. USAR CENTER
5901 TELEGRAPH ROAD
ALEXANDRIA. 2231mm}

REPLY TO
ATTE DH 0F

16 December 201 1

MEMORANDUM FOR US v. Manning Article 32(b) Participants

SUBJECT: Determinations as to Defense Requested Witnesses Revised

1. This document provides my revised determinations as to defense requested witnesses. As
outlined below, I have reconsidered my earlier determinations concerning PT Liebman. CPT
Worsely. and CPT Critchfield.

are?

SA Toni Graham she is not reasonably available because while her testimony is
relevant. she is located in Hawaii and the signi?cance ofhcr expeCted testimony with
respect to the first month of the investigation and her personal appearance does not
outweigh the dif?culty and cost of obtaining her presence at the investigation.

SA Mark Mander reasonably available.

SA Calder Robertson he is not reasonably available because while his testimony is
relevant, he is located in Germany and the signi?cance ofhis expected testimony with
respect to obtaining the collection of digital evidence and forensic imaging does not
outweigh the dif?culty and cost ofobtaining his presence at the investigation.

SA David Shaver reasonably available.

SACharles Ames his expected testimony is cumulative with other law enforcement
witnesses involved in the investigation; to the extent his testimony would cover the
collection ofclassi?ed information for the Information Review Task orce?s damage
assessment, I understand from the 12 December 201 telephone conference with CPT
Fein and Mr. Coombs that the government does not have the authority to disclose
damage assessments and thus I conclude that any testimony concerning such topics
would not be permissible.

SA Alfred Williamson - reasonably available.

SA Troy Bettencourt reasonably available.

SA Ronald Rock as the law enforcement investigation was a joint investigation, his
expected testimony is cumulative with other law enforcement witnesses involved in
the investigation.

SA Patrick Wheeler as the law enforcement investigation was ajoint investigation,
his expected testimony is cumulative with other law enforcement witnesses involved
in the investigation; moreover, his testimony concerning his contacts with Mr. Adrian
Lamo is cumulative with Mr. Lamo?s testimony.

CPT Martin Liebman reasonably available. I note that while CPT Liebman?s
concerns about PFC Manning?s mental health did not rise to the level of causing him
to indicate that PFC Manning was not suitable for continued access to classified
information. his expected testimony is relevant concerning whether PFC Manning

INV. DFCR. EKHIBII

If"




AFRC-MJVA
SUBJECT: Determinations as to Defense Requested Witnesses Revised

had diminished capacity at the time ofthe alleged offenses and also will help to
explain the circumstances surrounding the commission of the alleged offenses. (I note
that with respect to all the defense-requested witnesses concerning PFC Manning?s
mental health issues. the government has stated that on 22 April 201 i. an R.C.M. 706
board concluded that Manning did not have a severe mental disease or defect at
the time of the alleged criminal conduct that reSulted in him being unable to
appreciate the nature and quality or wrongfulness of his conduct")

k. CPT Michael Worsley he is not reasonably available because while his testimony is
relevant (while his concerns about PFC Manning?s behavior and issues did not rise to
the level ofcausing him to recommend to the command that they should suspend PFC
Manning?s clearance. his expected testimony is relevant concerning whether PFC
Manning had diminished capacity at the time of the alleged offenses and also will
help to explain the circumstances surrounding the commission of the alleged
offenses}, he is located in Kansas and the signi?cance of his expected testimony with
respect to his treatment of PFC Marming and his opinion of PFC Manning's need for
ongoing long term does not outweigh the difficulty and cost of
obtaining his presence at the investigation.

1. CPT Edan Critchfield reasonably available. I note that while he only recommended
that PFC Manning was not suitable for continued access to classified material and
that his security clearance should be suspended on 28 May 2010. after the dates of all
charged offenses. and despite his determination on 22 May 2010 that PFC Manning
was at risk to himself and others. he did not make a recommendation as to PFC
Manning's continued access to classified information on that date due to having been
informed that PFC Manning was no longer allowed in the T-SCIF, his expected
testimony is relevant concerning whether PFC Manning had diminished capacity at
the time ofthe alleged offenses and also will help to explain the circumstances
surrounding the commission of the alleged offenses.

m. COL David Miller his expected testimony is not relevant to the form of the charges.
the truth of the charges, or infonnation as may be necessary to make an informed
recommendation as to disposition; specifically, whether the command c0uld or should
have monitored and addressed PFC Manning?s conduct and behavior better, and
whether the command should have removed his access to classified information
earlier. is not relevant to a determination as to whether PFC Manning committed the
charged offenses and if so, what the disposition of those charges should be.

n. LTC Brian Kerns his expected testimony is not relevant to the form of the charges,
the truth of the charges. or information as may be necessary to make an informed
recommendation as to disposition; Specifically. whether the command could or should
have monitored and addressed PFC Manning's conduct and behavior better. and
whether the command should have removed his access to classi?ed information
earlier. is not relevant to a determination as to whether PFC Manning committed the
charged offenses and if so, what the disposition of those charges should be.
Moreover, his information as to whether unauthorized mediafprograms were
commonly on SIPRNET computers is cumulative to the testimony of OPT Cherepko,
CPT Keay. and SGT Padgett. and his testimony as to remedial measures the

l'-J

00619

AFRC-MJVA
SUBJECT: Determinations as to Defense Requested Wimesses - Revised

command took to improve measures is not relevant as it post-dates the
charged offenses.

MAJ Elijah Dreher his expected testimony is not relevant to the form of the
charges, the truth of the charges. or information as may be necessary to make an
informed recommendation as to disposition; specifically, whether the command could
or should have monitored and addressed PFC Manningis mental health issues better.
and should have left PFC Manning back instead of taking him on the deployment, and
whether or not he was aware or should have been aware Manning?s mental
health issues, is not relevant to a determination as to whether PFC Manning
committed the charged offenses, and if so, what the disposition of those charges
should be.

MAJ Clifford D. Clausen his expected testimony is not relevant to the form of the
charges, the truth of the charges. or information as may be necessary to make an
informed recommendation as to disposition; specifically, whether the command could
or should have monitored and addressed PFC Manning?s conduct and behavior better
is not relevant to a determination as to whether PFC Manning committed the charged
offenses and if so, what the disposition of those charges should be. Moreover, his
informatioa as to whether music CDs were allowed in the T-SCIF is cumulative to the
testimony of CPT Cherepko, PT Keay, and SGT Padgett.

CPT Barclay Keay not reasonably available due to previously scheduled leave;
although he would have been available on 3 or 4 January 2012. the signi?cance of his
testimony does not outweigh the delay in securing his personal appearance. I
understand the government and the defensejoin in requesting that he be considered
not reasonably available and that he testify by telephone.

CPT Matthew W. Freeburg his expected testimony is not relevant to the form of the
charges. the truth of charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command could
have monitored and addressed PFC Manning?s conduct and mental health issues
better, the circumstances of his removing PFC Manning from the T-SCIF and
assigning him to the supply room, the Article 15 PFC Manning receiVed, CPT
Freeburg?s interaction with CPT Worsley where he received CPT Worsley?s opinion
as to the extent of PFC Manning?s condition. his sending PFC Manning to CPT
Critch?eld for an evaluation. and his initiation of chapter paperwork. is not relevant
to a determination as to whether PFC. Manning committed the charged offenses,
capecially as CPT Critch?eld did not recommend that PFC Manning?s access to
classi?ed information be rescinded. His information as to whether videogames.
movies. and music was placed on the is cumulative to the testimony of CPT
Cherepko. PT Keay. and SGT Padgett.

CPT Steven Lirn reasonably available.

CPT Thomas Cherepko reasonably available.

CPT Michael Johnson his expected testimony is not relevant to the form of the
charges, the truth of the charges. or information as may be necessary to make an
informed recommendation as to disposition; specifically, whether the command could
or should have monitored and addressed PFC Manning?s conduct and behavior better

AFRC-MJVA
SUBJECT: Determinations as to Defense Requested Witnesses - Revised

is not relevant to a determination as to whether PFC Manning committed the charged
offenses and if so, what the disposition of those charges should be.

1LT Tanya Gaab her expected testimony is not relevant to the form ofthe charges,
the truth ofthe charges. or information as may be necessary to make an informed
recommendation as to disposition; speci?cally, whether the command could or should
have monitored and addressed PFC Manning?s conduct and mental health issues
better. and why they did not remove him from the T-SC IF earlier, is not relevant to a
determination as to whether he committed the charged offenses and if so, what the
disposition of those charges should be.

1LT Elizabeth Fields her expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command could
or should have monitored and addressed PFC. Manning?s conduct and mental health
issues better, and why they did not remove him from the T-SC IF earlier, is not
relevant to a determination as to whether he committed the charged offenses and if so,
what the disposition of those charges should be. Her information as to whether CDs
and DVDs were permitted in the is cumulative to the testimony of at least
CPT Lim and SGT Padgett.

W2 Joshua Ehresman his expected testimony is not relevant to the form of the
charges. the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition: speci?cally, whether the command could
or should have monitored and addressed PFC Matming?s conduct and behavior better.
and whether the command should have taken PFC. Manning on the deployment, as
well as CW2 Ehresman's recommendation, after an incident in which he intervened,
that PFC Manning have his weapon?s bolt removed, be sent to mental health, and then
be separated from the Army, which resulted in no action being taken, is not relevant
to a determination as to whether PFC Manning committed the charged offenses and if
so, what the disposition of those charges should be.

MSG Erie Usbeck his expected testimony is not relevant to the form of the charges.
the truth of the charges, or information as may be necessary to make an informed
recommendation as to disposition; specifically. whether the command could or should
have monitored and addressed PFC Manning?s conduct and behavior better, and
whether the command should have taken PFC. Manning on the deployment, as well as
his counseling PFC Marming and referring him to mental health for evaluation, and
his not personally following up after learning that PFC Manning did not in fact go to
mental health is not relevant to a determination as to whether PFC Manning
committed the charged offenses and if so. what the disposition of those charges
should be. Additionally, his information as to the counseling of PFC Manning is
cumulative with Ms. Showman?s.

MSG Mark Woodworth his expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition: Specifically. his being briefed on PFC
Manning?s issue with another soldier or his assault on SPC Showman, and his
knowledge that PFC Manning was moved to the supply room, and his lack of

AFRC-MJVA



SUBJECT: Determinations as to Defense Requested Witnesses - Revised

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bb.

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recollection about any discussion ofsending PFC Manning back to the States or
chaptering him out, and his knowledge of the search of PFC Manning?s quarters and
work space, is not relevant to a determination as to whether PFC Manning committed
the charged offenses and if so. what the disposition of those charges should be.

SFC Paul Adkins reasonably available (pending invocation of rights issue).

SSG Lawrence Mitchell his expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the whether the
command could or should have monitored and addressed PFC Manning?s conduct
and behavior better, whether SFC Adkins did not do anything to address PFC
Manning?s issues, whether PFC Manning was gay, and whether the command should
have chaptered him out of the Army, is not relevant to a determination as to whether
PFC Manning committed the charged offenses and if so, what the disposition of those
charges should be.

SGT Rebecca Schwab her expected testimony is not relevant to the form of the
charges, the truth of the charges. or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether PFC Manning was
gay and whether he had emotional issues that made him dif?cult to adjust to military
life is not relevant to a determination as to whether he committed the charged
offenses and if so, what the disposition of those charges should be.

SGT Daniel Padgett - reasonably available.

SGT David Sadtler his expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command
ostracized PFC Manning and did not support him, and disregarded his concerns about
a particular report, is not relevant to a determination as to whether he committed the
charged offenses and if so, what the disposition of those charges should be.

SGT Lorena Cooley her expected testimony is not relevant to the form of the
charges, the truth of the charges. or information as may be necessary to make an
informed recommendation as to disposition; Speci?cally, whether PFC Manning was
picked on by other soldiers because they assumed he was gay, the nature of SFC
Adkin?s leadership, and whether PFC Manning should have gotten help for his issues
before they deployed is not relevant to a determination as to whether he committed
the charged offenses and if so, what the disposition of those charges should be.
Additionally, her information about CD5 for music and movies being placed on
SIPRNET computers is cumulative to at least CPT Cherepko and CPT Keay.

SGT Sheri Walsh her expected testimony is not relevant to the form of the charges,
the truth ofthe charges. or information as may be necessary to make an informed
recommendation as to disposition; speci?cally. whether PFC Manning had
relationship and gender identity issues and whether other soldiers made fun of him
due to his size and their belief he was gay, his response to a particular incident, and
her opinion as to whether the Army was a good ?t for him at this time ofhis life, is
not relevant to a determination as to whether he committed the charged offenses and
if so, what the disposition of those charges should be.

U:

AFRC-MJVA

Iv

SUBJECT: Determinations as to Defense Requested Witnesses - Revised

hh.

ii.

kk.

lTlITl.

Ms. Jihrleah Showman she is not reasonably available because while her testimony
is relevant. she is located in Syracuse, NY and the signi?cance of her expected
testimony with respect to her recommendation to SF C. Adkins that PFC Manning not
deploy due to his emotional issues. the circumstances of her viewing the ?Apache
video" in the T-SCIF. and her experiences as PFC Manning?s direct supervisor do not
outweigh the dif?culty and cost ofobtaining her presence at the investigation.

Mr. Adrian Lamo reasonably available.

President Barack Obama his expected testimony is not relevant to the form of the
charges. the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally. whether any statements by
President Obama may have in?uenced the prosecution in this case, the extent of the
harm caused by the alleged disclosures. or the alleged problem of over-classi?cation
is not relevant to a determination as to whether PFC Manning committed the charged
offenses and if so, what the disposition of those charges should be. The defense may
of course vor'r dire the investigating officer to inquire as to whether any unlawful
conunand in?Uence taints the Article 32 investigation.

Former Secretary Robert Gates his expected testimony is not relevant to the form of
the charges. the truth of the charges. or information as may be necessary to make an
informed recommendation as to diaposition; specifically, the extent of the harm
caused by the charged offenses. the initial public descriptions ofthe harm caused by
the charged offenses. and the effect of the charged offenses on foreign policy is not
relevant to a determination as to whether PFC Manning committed the charged
offenses and if so. what the disposition of those charges should be. Additionally. to
the extent his testimony would cover the damage review conducted by the
Information Review Task Force?s damage assessment, I understand from the 12
December 201 1 telephone conference with PT ein and Mr. oombs that the
government does not have the to disclose damage assessments and thus I
conclude that any testimony concerning such topics would not be permissible.
Secretary Hillary Clinton her expected testimony is not relevant to the form of the
charges. the truth of the charges. or information as may be necessary to make an
informed recommendation as to disposition; specifically. her raising the issue of the
disclosed diplomatic cables with foreign leaders. the extent of the harm caused by the
charged offenses, and the effect of the alleged disclosures on foreign policy is not
relevant to a determination as to whether PFC Manning committed the charged
offenses and if so. what the dispositiOn of those charges should be.

PT James Kolky his expected testimony is not relevant to the form of the
charges, the truth of the charges. or information as may be necessary to make an
informed recommendation as to disposition; speci?cally. whether three Apache gun
videos that were sent to his Division were not classified at the time of their alleged
release and whether they should have been. recognizing that the government states
the video is not classified and does not allege it is classified. is not relevant to a
determination as to whether PFC Manning committed the charged offenses and if so.
what the disposition of those charges should be.

AFRC-MJVA

00623



SUBJECT: Determinations as to Defense Requested Witnesses - Revised

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RADM Kevin Donegan he is not reasonably available because while his testimony
is relevant, he is located in Florida and is Director of Operations; the
signi?cance of his expected testimony with respect to his classi?cation
determinations concerning the two PowerPoints at issue does not outweigh the
dif?culty, expense. and effect on military operations of obtaining his presence at the
investigation.

Mr. Robert Betz he is not reasonably available because while his testimony is
relevant, he is Chief Classi?cation Advisory Of?cer; the signi?cance
of his expected testimony with respect to his classi?cation determinations concerning
the alleged chat logs between Mr. Lamo and PFC Manning does not outweigh the
effect on military operations of obtaining his presence at the investigation.

LtGen Robert Schmidle, Jr. he is not reasonably available because while his
testimony is relevant, he is Deputy Commander; the signi?cance of
his expected testimony with respect to his classi?cation determinations concerning
the alleged chat logs between Mr. Lame and PFC Manning does not outweigh the
effect on military operations of obtaining his presence at the investigation.

VADM Robert Harward he is not reasonably available because while his testimony
is relevant, he is located in Florida and is Deputy Commander; the
signi?cance of his expected testimony with respect to his classi?cation
determinations concerning the CIDNE Afghanistan Events, CIDNE Iraq Events, other
brie?ngs and the BEBE PAX.wmv video does not outweigh the dif?culty, expense,
and effect on military operations of obtaining his presence at the investigation.

Mr. Patrick Kennedy - he is not reasonably available because while his testimony is
relevant, he is Undersecretary of State for Management; the signi?cance of his
expected testimony with respect to his classi?cation determinations concerning
diplomatic cables does not outweigh the dif?culty of obtaining his presence at the
investigation.

RADM David Woods he is not reasonably available because while his testimony is
relevant, he is Commander of the Joint Task Force - Guantanamo; the signi?cance of
his expected testimony with respect to his classi?cation determinations concerning
the documents at issue does not outweigh the dif?culty, expense. and effect on
military operations of obtaining his presence at the investigation.

CAPT Kevin Moore his expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the Security
Battalion commander at the Quantico Brig made determinations concerning
Prevention of ury precautions that behavioral health did not believe were necessary
is not relevant to a determination as to whether PF Manning committed the charged
offenses and if so, what the disposition of those charges should be.

CAPT William Hochter his expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the Security
Battalion commander at the Quantico Brig made determinations concerning
Prevention of Injury precautions that behavioral health did not believe were necessary

VA
Detenninations as to Defense Requested Witnesses Revised

is not to a determination as to whether PFC lulanning eornntitted the charged
olitenses and it?so. what the disposition ofthose eharges should be.

2. Please address all questions or concerns to the undersigned at?

5

.1. POC for this memorandum is the undersigned.

PAUL. R.
LTC. JA. USAR
Investigating Ol?eer

Cl?:

Matthett' Kemltes
CPTILP) Paul Bouehard
Ashden Fein {at as
Mr. David Coombs (at
.IoDean Morrow
Clrl' Angel Overgaard
C?l?l .lefli'ey {at
LTC Marl; l-lolzer (at In







?v

DEPARTMENT OF THE ARMY
15DTH JUDGE ADVOCATE GENERAL DETACHMENT (L30)
MG ALBERT c. USAR CENTER
5901 TELEGRAPH ROAD
ALEXANDRIA. 22310-33er



TO
ATTENTION OF

AFROMJ VA 17 December 201

MEMORANDUM FOR US v. Manning Article 32(b) Participants

SUBJECT: Determinations as to Defense Requested Witnesses Revised

1. This document provides my revised determinations as to defense requested witnesses. As
outlined below, I have reconsidered my earlier determinations concerning CPT Liebman, CPT
Worsely, and CPT Critch?eld. This 1? December version corrects an administrative error in the
16 December 2011 version of this document with respect to CPT Cherepko.

a. SA Toni Graham she is not reasonably available because while her testimony is
relevant, she is located in Hawaii and the signi?cance of her expected testimony with
respect to the ?rst month of the investigation and her personal appearance does not
outweigh the dif?culty and cost of obtaining her presence at the investigation.

. SA Mark Mander reasonably available.

c. SA Calder Robertson he is not reasonably available because while his testimony is
relevant. he is located in Germany and the significance of his expected testimony with
respect to obtaining the collection ofdigital evidence and forensic imaging does not
outweigh the dif?culty and cost of obtaining his presence at the investigation.

d. SA David Shaver reasonably available.

e. SAC harles Ames his expected testimony is cumulative with other law enforcement
witnesses involved in the investigation; to the extent his testimony would cover the
collection of classi?ed information for the lnforrnation Review Task Force?s damage
assessment, I understand from the 12 December 2011 telephone conference with CPT
ein and Mr. Coombs that the government does not have the authority to disclose
damage assessments and thus I conclude that any testimony concerning such topics
would not be permissible.

f. SA Alfred Williamson A reasonably available.

g, SA Troy Bettencourt reasonably available.

h. SA Ronald Rock as the law enforcement investigation was a joint investigation, his
expected testimony is cumulative with other law enforcement witnesses involved in
the investigation.

i. SA Patrick Wheeler as the law enforcement investigation was a joint investigation,
his expected testimony is cumulative with other law enforcement witnesses involved
in the investigation; moreover. his testimony concerning his contacts with Mr. Adrian
Lamo is cumulative with Mr. Lamo*s testimony.

j. CPT Martin Liebman reasonably available. I note that while CPT Liebman?s
concerns about PFC Manning's mental health did not rise to the level ofcausing him
to indicate that PFC Manning was not suitable for continued access to classified

ll'tl?. arcs.

AFRC-MIVA
SUBJECT: Determinations as to Defense Requested Witnesses Revised

information, his expected testimony is relevant concerning whether PFC Manning
had diminished capacity at the time of the alleged offenses and also will help to
explain the circumstances surrounding the commission of the alleged offenses. (I note
that with respect to all the defense-requested witnesses concerning PFC Manning?s
mental health issues, the government has stated that on 22 April 2011, an R.C.M. 706
board concluded that Manning did not have a severe mental disease or defect at
the time of the alleged criminal conduct that resulted in him being unable to
appreciate the nature and quality or wrongfulness of his conduct")

k. CPT Michael Worsley he is not reasonably available because while his testimony is
relevant (while his concerns about PFC Manning?s behavior and issues did not rise to
the level of causing him to recommend to the command that they should suspend PFC
Manning?s clearance, his expected testimony is relevant concerning whether PFC
Manning had diminished capacity at the time of the alleged offenses and also will
help to explain the circumstances surrounding the commission of the alleged
offenses), he is located in Kansas and the signi?cance of his expected testimony with
respect to his treatment of PFC Manning and his opinion of PFC Manning?s need for
ongoing long term does not outweigh the dif?culty and cost of
obtaining his presence at the investigation.

I. CPT Edan Critch?eld reasonably available. I note that while he only recommended
that PFC Manning was not suitable for continued access to classi?ed material and
that his security clearance should be suspended on 28 May 2010, after the dates of all
charged offenses. and deSpite his determination on 22 May 2010 that PFC Manning
was at risk to himself and others. he did not make a recommendation as to PFC
Manning?s continued access to classified information on that date due to having been
informed that PFC Manning was no longer allowed in the T-SCIF, his expected
testimooy is relevant concerning whether PFC Manning had diminished capacity at
the time of the alleged offenses and also will help to explain the circumstances
surrounding the commission of the alleged offenses.

m. COL David Miller his expected testimony is not relevant to the form of the charges,
the truth of the charges, or information as may be necessary to make an informed
recommendation as to disposition; specifically, whether the command could or should
have monitored and addressed PFC Manning?s conduct and behavior better, and
whether the command should have removed his access to classi?ed information
earlier, is not relevant to a determination as to whether PFC Manning committed the
charged offenses and if so, what the disposition of those charges should be.

n. LTC Brian Kerns his expected testimony is not relevant to the form of the charges,
the truth of the charges, or information as may be necessary to make an informed
recommendation as to disposition; speci?cally, whether the command could or should
have monitored and addressed PFC Manning?s conduct and behavior better, and
whether the command should have removed his access to classified information
earlier, is not relevant to a determination as to whether PFC Mamiing committed the
charged offenses and ifso, what the disposition of those charges should be.
Moreover, his information as to whether unauthorized media/programs were
commonly on SIPRNET computers is cumulative to the testimony of CPT Cherepko,



AFRC-MJVA
SUBJECT: Determinations as to Defense Requested Witnesses - Revised


I

CPT Keay, and SGT Padgett, and his testimony as to remedial measures the
command took to improve INFOSEC measures is not relevant as it post-dates the
charged offenses.

MAJ Elijah Dreher his expected testimony is not relevant to the form of the
charges. the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command could
or should have monitored and addressed PFC Manning?s mental health issues better,
and should have left PFC Manning back instead of taking him on the deployment, and
whether or not he was aware or should have been aware of PFC Manning?s mental
health issues, is not relevant to a determination as to whether PFC Manning
committed the charged offenses, and ifso, what the disposition of those charges
should be.

MAJ Clifford D. lausen his expected testimony is not relevant to the form of the
charges. the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command could
or should have monitored and addressed PFC Manning?s conduct and behavior better
is not relevant to a determination as to whether PFC Manning committed the charged
offenses and if so, what the disposition of those charges should be. Moreover, his
information as to whether music CDs were allowed in the T-SCIF is cumulative to the
testimony Cherepko. CPT Keay, and SGT Padgett.

CPT Barclay Keay not reasonably available due to previously scheduled leave;
although he would have been available on 3 or 4 January 2012. the signi?cance of his
testimony does not outweigh the delay in securing his personal appearance. I
understand the government and the defense join in requesting that he be considered
not reasonably available and that he testify by telephone.

CPT Matthew W. reeburg his expected testimony is not relevant to the form of the
charges. the truth of charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command could
have monitored and addressed PFC Manning?s conduct and mental health issues
better, the circumstances of his removing PFC Manning from the T-SCIF and
assigning him to the supply room, the Article 15 PFC Manning received, CPT
Freeburg?s interaction with CPT Worsley where he received CPT Worsley?s opinion
as to the extent of PFC Manning?s condition, his sending PFC Manning to CPT
for an evaluation, and his initiation of chapter paperwork, is not relevant
to a determination as to whether PFC Manning committed the charged offenses,
especially as CPT Critchfield did not recommend that PFC Manning?s access to
classi?ed information be rescinded. His information as to whether videogames,
movies, and music was placed on the is cumulative to the testimony of CPT
Cherepko, CPT Keay. and SGT Padgett.

CPT Steven Lim reasonably available.

CPT Thomas Cherepko not reasonably available.

CPT Michael Johnson his expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command could

AFRC-MJVA
SUBJECT: Determinations as to Defense Requested Witnesses - Revised

or should have monitored and addressed PFC Manning?s conduct and behavior better
is not relevant to a determination as to whether PFC Manning committed the charged
offenses and if so, what the disposition of those charges should be.

1LT Tanya Gaab her expected testimony is not relevant to the form of the charges,
the truth of the charges, or information as may be necessary to make an informed
recommendation as to disposition; speci?cally, whether the command could or should
have monitored and addressed PFC Manning?s conduct and mental health issues
better, and why they did not remove him from the earlier, is not relevant to a
determination as to whether he committed the charged offenses and if so, what the
disposition of those charges should be.

1LT Elizabeth Fields her expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command could
or should have monitored and addressed PFC Manning?s conduct and mental health
issues better, and why they did not remove him from the T-SCIF earlier, is not
relevant to a determination as to whether he committed the charged offenses and if so,
what the disposition of those charges should be. Her information as to whether CDs
and DVDs were permitted in the T-SCIF is cumulative to the testimony of at least
CPT Lim and SGT Padgett.

CW2 Joshua Ehresman his expected testimony is not relevant to the form of the
charges. the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; specifically, whether the command could
or should have monitored and addressed PFC Manning?s conduct and behavior better,
and whether the command should have taken PFC Manning on the deployment, as
well as CW2 Ehresman?s recommendation, after an incident in which he intervened,
that PFC Manning have his weapons bolt removed, be sent to mental health, and then
be separated from the Army, which resulted in no action being taken, is not relevant
to a determination as to whether PFC Manning committed the charged offenses and if
so, what the disposition of those charges should be.

MSG Eric Usbeck his expected testimony is not relevant to the form of the charges,
the truth of the charges, or information as may be necessary to make an informed
recommendation as to disposition; specifically, whether the command could or should
have monitored and addressed PFC Manning?s conduct and behavior better, and
whether the command should have taken PFC Manning on the deployment, as well as
his counseling PFC Manning and referring him to mental health for evaluation, and
his not personally Following up after learning that PFC Manning did not in fact go to
mental health is not relevant to a determination as to whether PFC Manning
committed the charged offenses and if so, what the disposition of those charges
should be. Additionally. his information as to the counseling of PFC Manning is
cumulative with Ms. Showman's.

MSG Mark Woodworth his expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, his being briefed on PFC.
Manning?s issue with another soldier or his assault on SPC Showman, and his

AFRC-MIVA



SUBJECT: Determinations as to Defense Requested Witnesses - Revised

aa.
bb.

CC.

dd.
ee.

ff.

Eg-

knowledge that PFC Manning was moved to the supply room; and his lack of
recollection about any discussion of sending PFC Manning back to the States or
chaptering him out. and his knowledge ofthe search of PFC Manning?s quarters and
work space; is not relevant to a determination as to whether PFC Manning committed
the charged offenses and if so; what the disposition of those charges should be.

SFC Paul Adkins reasonably available (pending invocation of rights issue).

SSG Lawrence Mitchell his expected testimony is not relevant to the form of the
charges. the truth of the charges; or information as may be necessary to make an
informed recommendation as to disposition; specifically. whether the whether the
command could or should have monitored and addressed PFC Manning?s conduct
and behavior better, whether SF Adkins did not do anything to address PFC
Manning?s issues; whether PFC Manning was gay; and whether the command should
have chaptered him out of the Anny. is not relevant to a determination as to whether
PFC. Manning committed the charged offenses and if so, what the disposition of those
charges should be.

SGT Rebecca Schwab her expected testimony is not relevant to the form of the
charges. the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; specifically. whether PFC. Manning was
gay and whether he had emotional issues that made him dif?cult to adjust to military
life is not relevant to a determination as to whether he committed the charged
offenses and if so, what the diSpOSili?n of those charges should be.

SGT Daniel Padgett reasonably available.

SGT David Sadtler his expected testimony is not relevant to the form of the
charges; the truth of the charges; or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the command
ostracized PFC Manning and did not support him; and disregarded his concerns about
a particular report; is not relevant to a determination as to whether he committed the
charged offenses and if so. what the disposition of those charges should be.

SGT Lorena Cooley her expected testimony is not relevant to the form of the
charges; the truth of the charges; or information as may be necessary to make an
informed recommendation as to disposition; specifically, whether PFC Manning was
picked on by other soldiers because they assumed he was gay. the nature of SFC
Adkin's leadership, and whether PFC Manning should have gotten help for his issues
before they deployed is not relevant to a determination as to whether he committed
the charged offenses and if so; what the disposition of those charges should be.
Additionally; her information about CDs for music and movies being placed on
SIPRNET computers is cumulative to at least CPT Cherepko and CPT Keay.

SGT Sheri Walsh 4 her expected testimony is not relevant to the form of the charges,
the truth of the charges. or information as may be necessary to make an informed
recommendation as to disposition; specifically; whether PFC Manning had
relationship and gender identity issues and whether other soldiers made fun of him
due to his size and their belief he was gay; his response to a particular incident, and
her opinion as to whether the Army was a good fit for him at this time of his life; is

AFRC-MJVA

?h

SUBJECT: Determinations as to Defense Requested Witnesses - Revised

hh.

ii.

kk.

ll.

not relevant to a determination as to whether he committed the charged offenses and
if so, what the disposition of those charges should be.

Ms. Jihrleah Showman she is not reasonably available because while her testimony
is relevant, she is located in Syracuse. NY and the signi?cance of her expected
testimony with respect to her recommendation to SFC Adkins that PFC Manning not
deploy due to his emotional issues, the circumstances of her viewing the ?Apache
video" in the T-SCIF, and her experiences as PFC Manning?s direct supervisor do not
outweigh the difficulty and cost of obtaining her presence at the investigation.

Mr. Adrian Lamo reasonably available.

President Barack Obama - his expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally. whether any statements by
President Obama may have influenced the prosecution in this case, the extent of the
harm caused by the alleged disclosures. or the alleged problem of over-classi?cation
is not relevant to a determination as to whether PFC Manning committed the charged
offenses and if so, what the disposition of those charges should be. The defense may
of course voir dire the investigating of?cer to inquire as to whether any unlawful
command influence taints the Article 32 investigation.

Former Secretary Robert Gates - his expected testimony is not relevant to the form of
the charges, the truth of the charges. or information as may be necessary to make an
informed recormnendation as to disposition; speci?cally, the extent of the harm
caused by the charged offenses, the initial public descriptions of the harm caused by
the charged offenses, and the effect of the charged offenses on foreign policy is not
relevant to a determination as to whether PFC Manning committed the charged
offenses and if so, what the disposition of those charges should be. Additionally, to
the extent his testimony would cover the damage review conducted by the
Information Review Task orce?s damage assessment, I understand from the 12
December 201 telephone conference with CPT Fein and Mr. Coombs that the
government does not have the authority to disclose damage assessments and thus I
conclude that any testimony concerning such topics would not be permissible.
Secretary Hillary Clinton 7 her expected testimony is not relevant to the form of the
charges, the truth of the charges, or information as may be necessary to make an
informed recommendation as to disposition; specifically, her raising the issue of the
disclosed diplomatic cables with foreign leaders, the extent of the harm caused by the
charged offenses, and the effect of the alleged disclosures on foreign policy is not
relevant to a determination as to whether PFC Manning committed the charged
offenses and if so, what the disposition of those charges should be.

m. CPT James Kolky his expected testimony is not relevant to the form of the

charges, the truth of the charges. or as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether three Apache gun
videos that were sent to his Division were not classi?ed at the time of their alleged
release and whether they should have been, recognizing that the government states
the video is not classified and does not allege it is classi?ed, is not relevant to a

6

AFRC-MJVA

1..

SUBJECT: Determinations as to Defense Requested Witnesses - Revised

00.

P11



1T.

35.

it.

[11.1.

determination as to whether PFC Manning committed the charged offenses and if so,
what the disposition of those charges should be.

. RADM Kevin Donegan he is not reasonably available because while his testimony

is relevant, he is located in Florida and is Director of Operations; the
signi?cance of his expected testimony with respect to his classi?cation
determinations concerning the two PowerPoints at issue does not outweigh the
dif?culty, expense, and effect on military operations of obtaining his presence at the
investigation.

Mr. Robert Betz he is not reasonably available because while his testimony is
relevant, he is Chief Classi?cation Advisory Of?cer; the signi?cance
of his expected testimony with respect to his classi?cation determinations concerning
the alleged chat logs between Mr. Lamo and PFC Manning does not outweigh the
effect on military operations of obtaining his presence at the investigation.

LtGen Robert Schmidle, Jr. he is not reasonably available because while his
testimony is relevant, he is YB Deputy Commander; the signi?cance of
his expected testimony with respect to his classi?cation determinations concerning
the alleged chat logs between Mr. Lamo and PFC Manning does not outweigh the
effect on military operations of obtaining his presence at the investigation.

VADM Robert Harward he is not reasonably available because while his testimony
is relevant, he is located in Florida and is Deputy Commander; the
signi?cance of his expected testimony with respect to his classi?cation
determinations concerning the CIDNE Afghanistan Events, CIDNE Iraq Events, other
brie?ngs and the BE22 PAX.wmv video does not outweigh the dif?culty, expense,
and effect on military operations of obtaining his presence at the investigation.

Mr. Patrick Kennedy he is not reasonably available because while his testimony is
relevant, he is Undersecretary of State for Management; the signi?cance of his
expected testimony with respect to his classi?cation determinations concerning
diplomatic cables does not outweigh the dif?culty of obtaining his presence at the
investigation.

RADM David Woods he is not reasonably available because while his testimony is
relevant, he is Commander of the Joint Task Force - Guantanamo; the signi?cance of
his expected testimony with respect to his classification determinations concerning
the documents at issue does not outweigh the dif?culty, expense, and effect on
military operations of obtaining his presence at the investigation.

CAPT Kevin Moore his expected testimony is not relevant to the form of the
charges, the truth ofthe charges, or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the Security
Battalion commander at the Quantieo Brig made determinations concerning
Prevention of Injury precautions that behavioral health did not believe were necessary
is not relevant to a determination as to whether PFC Manning committed the charged
offenses and if so. what the disposition of those charges should be.

CAPT William Hochter his expected testimony is not relevant to the form of the
charges, the truth of the charges. or information as may be necessary to make an
informed recommendation as to disposition; speci?cally, whether the Security

RC-MJ VA -
SUBJECT: Determinations as to Defense Requested Witnesses Revised

Battalion commander at the Quantieo Brig made determinations concerning
Prevention of Injury precautions that behavioral health did not believe were necessary
is not relevant to a determination as to whether PFC Manning committed the charged
offenses and if so. what the disposition ofthose charges should be.

uestions or eoneerns to the undersigned at?



3. POC for this memorandum is the undersigned.

PAUL R. ALMANZA
JA, USAR
Investigating Of?cer


MAJ Matthew Kemke
Paul Bouehar
CPT Ashden Fein {at
Mr. David Coombs {a
CPT JoDean Morrow
Angel Overgaar
CPT jel'l'rey [a
LTC Mark Holzer {at



v? V,

DEPARTMENT OF THE ARMY
1suTH JUDGE onooATE GENERAL DETACHMENT (LSD)
MG ALBERT c. LIEBER USAR CENTER
6901 TELEGRAPH

ALEXANDRIA. VIRGINIA 22310-3320
REPLY TO

ATTENTION 0F



20 December 201 1

MEMORANDUM FOR US v. Manning Article 32(b) Participants

SUBJECT: Reconsideration of Closure Determination

1. On 28 November 201 l, the defense submitted a request for closure of these proceedings
during the discussion of five separate topics, including the at hand two alleged disloyal
statements by PFC Manning to then-SPC Showman, one to the effect that he had no loyalty to
the United States and the second to the effect that the ?ag on his shoulder ?meant nothing to
him.? After receiving the government?s response to that request on 4 December, I denied it on
13 December. I then denied the defense?s request that I reconsider the denial on 14 December
2011.

2. I now reconsider that denial concerning the two statements at issue. My 13 December denial
was premised on the third part of the test at RCM 806(b)(2) - that reasonable alternatives to
closure were considered and found inadequate.

3. In making my determination concerning this request, I have reconsidered the 19 January 201
sworn statement of then-SPC Showman (Bates number 0001371 1-14). I have also reconsidered
counsel?s written submissions on the closure request. The government and the defense both
stood on their previous arguments and did not present further argument.

4. The accused has the burden of persuasion on his request and the burden is of proof is by a
preponderance of the evidence under RCM 905(c)(1) and

5. Analyzing the issue under the test at R.C.M.

a. ?[T]here is a substantial probability that an overriding interest will be prejudiced if
proceedings remain open.? The accused?s right to a fair trial is an overriding interest. There is a
substantial probability that public disclosure of the accused?s alleged disloyal statements given
the high level of media coverage of this case in the National Capital Region would prejudice the
accused?s right to a fair trial in that prospective panel members would likely have heard this
information and would liker have formed an opinion as to his guilt or innocence of the charged
offenses based on that information. This probability is exacerbated by the fact that the
statements at issue due to their nature would liker receive extremely prominent placement in
any media coverage concerning this case.

b. ?[C]losure is no broader than necessary to protect the overriding interest." The
closure is narrowl}r tailored to protecting the accosed?s right to a fair trial because it is limited

INV. arm, EXHIBIT 9/9


SUBJECT: Reconsideration of Closure Determination

only to Ms. Showman?s discussion of the two statements at issue. Unlike in ABC, Inc. v. Powell.
47 M.J. 363 (1997), which rejected a blanket closure ofan Article 32 hearing. this closure is
extremely limited. This closure is targeted only at the two statements at issue, and lasted for
approximately 5 minutes of testimony. The closure is thus no broader than necessary.

c. alternatives to closure were considered and found inadequate.? I have
reconsidered my earlier determination that this part of the test is not met because if this case
were referred to trial, adequate reasonable alternatives to closure would include a military
judge?s ability to take appropriate protective measures such as thorough voir dire of prospective
panel members and appropriate instructions to the panel members. Given the extent of the
pretrial publicity this matter has received and will continue to receive, and the in?ammatory
nature of these two statements. upon reconsideration I now conclude there is a signi?cant risk
that a prospective panel member would be unable to fully set aside his or her already having
heard that the accused had made statements to the effect that he had no loyalty to the United
States and that the flag on his shoulder ?meant nothing to him.? These statements are more than
evidence concerning the accused?s offenses; rather, they are statements that denigrate and reject
the very reasons that potential panel members serve in the military. Accordingly, there is a
significant risk that thorough voir dire will not be able to ensure that the panel is free of persons
who should not sit as members in the interests of having the court-martial free from Substantial
doubt as to legality. fairness, and impartiality. This extremely limited closure will avoid that
signi?cant risk.

d. ?[The investigating officer] makes case-speci?c ?ndings on the record justifying
closure." 1 have made findings justifying this limited closure in the preceding paragraphs.

6. I read the substance of this document into the record when making my determination as to a
limited closure of the proceedings for the testimony of Ms. Showman concerning the alleged

disloyal statements at issue.

7. FCC for this memorandum is the undersigned.


PAUL R. ALMANZA
LTC, JA, USAR

Investigating Of?cer

CF:
Counsel

DEPARTMENT OF THE ARMY
150TH JUDGE ADVOCATE GENERAL DETACHMENT (L50)
MG ALBERT c. LIEBER USAR CENTER
6901 TELEGRAPH ROAD

ALEXANDRIA. VIRGINIA 22310-3320
REPLY TO

ATTENTION OF



AFRC-MJVA 21 December 201 1

MEMORANDUM FOR US v. Manning Article 32(b) Participants

SUBJECT: Determination on Defense Assertion of Privilege under M.R.E. 503

1. On 19 December 201 1, the defense submitted an assertion of privilege under M.R.E. 503.
Communications to Clergy, for the chats he had with Mr. Adrian Lamo. The government
submitted its response on 20 December 2011. During a conference before Mr. Lamo's testimony
on 20 December 2011, I denied the defense?s assertion of privilege because, having reviewed the
chats, I found the test for the establishment of the privilege was not met. I stated I would append
my written determination to the report of investigation.

2. NLRB. 503, like the other privilege rules in M.R.E. Section V, applies to Article 32
investigations. R.C.M. 405(i). However, in order for the privilege to apply to prevent
consideration of evidence. the privilege must ?rst exist concerning that evidence. The party
asserting the privilege has the burden of establishing it exists. US. v, Shelton, 64 MJ. 32, 37
(2006); US. v. Durbin, 68 MJ. 271, 274 (2010) (discussing M.R.E. 504)).

3. For M.R.E. 503 to apply, a three-part test must be met: the communication must be made
either as a formal act of religion or as a matter of conscience; the communication must be
made to a member of the clergy in his or her capacity as a spiritual advisor (or to the clergy
member?s assistant in his or her capacity as the clergy member?s assistant); and the
conununication must be intended to be con?dential. Sheltonmake the following determinations:

a. PFC. Manning?s statements in the chats were not made as a formal act of religion. The
chats themselves preclude a determination that they were made as a formal act of religion
because they include PFC Manning?s statements such as ?raised never believed a
word of it," ?im i guess i follow humanist values though,? and ?always been too
intellectual, if not just plain queer, for religion.? 10 Ex. 19(d), p. 17.]

b. PFC Manning's statements in the chats were not made as a matter of conscience. A
matter of conscience includes statements made to a member of the clergy under circumstances
burdening appellant?s conscience. Shaken, 64 MJ. at 38 (circumstances include acceptance of
guilt and crying out for help); US. v. Richards, 17 MJ. 1016, 1018-20 1934)



I refer to this document used by the defense to cross-examine Mr. Lame rather than the chats in the forensic
reports because the latter chats are classi?ed.

1

MW. UFCR. EXHIBIT 9

00636
AFRC-MJVA
SUBJECT: Determination on Defense Assertion of Privilege Under M.R.E. 503.

(circumstances include person making statement to chaplain ?visibly upset and nervous,"
?admitted he was troubled by guilt," and ?expressed remorse?). The chats demonstrate that
these circumstances do not apply. After introductory matters the chats begin with PFC Manning
mentioning his ?unusual, and very stressful experience over the last decade or so? involving him
?question[ing] his gender for several and stating his ?sexual orientation was easy to
?gure but I started to come to terms with it during the course of my deployment.? 10 Ex.
19(d), p. 1. PFC Manning thus raised these topics, which are discussed throughout the chats,
before Mr. Lamo?s reference to his status as ajourrtalist and a minister {quoted below in para.
4c). Moreover, the chats do not include any reference to PFC Manning being troubled by guilt
or expressing remorse about these topics. Rather, the chats are replete with statements indicating
that what PFC Manning was seeking in his chats with Mr. Lamo was emotional support and
consolation. Under U.S. v. Napoleon, 46 MJ. 279, 285 (1997'), cert. denied, 522 US. 953
(1997), communication is not privileged, even if made to a clergyman, if it is made for
emotional support and consolation rather than as a formal act of religion or as a matter of
conscience." Examples of PFC Manning?s statements demonstrating he was seeking emotional
support and consolation include: ?im very isolated atm. .. lost all of my emotional support
family. boyfriend, trusting im a mess," [0 Ex. 19(d), at 6; ?im
im just emotionally fractured," id. at 7, ?its such an awkward place to be in, emotionally and
id. at ?im a total fucking wreck right now,? id; ?but im not a source for
im talking to you as someone who needs moral and emotional fucking support," id. at 10.
While at one point PFC Manning stated "im a broken soul id. at 1, this statement does not
indicate the statements in the chats were made as a matter ol?conscience because it is made in the
context ofsomeone seeking emotional support and consolation. (With respect to PFC Manning?s
statements in the chats about his alleged offenses, the chats indicate the opposite of his being
troubled by guilt or accepting remorse and I need not discuss them further.)

c. Mr. Lamo was not a clergyman under M.R.E. 503, and even assuming argrrendo that
he were, PFC Manning could not have had a reasonable belief that he was. In the chats, Mr.
Lamo stated he was a minister (on cross-examination, Mr. Lamo stated he was a minister in the
Universal Life Church). Under Napoleon, 46 at 284, which discusses the Advisory
Committee Note to proposed-but-not-adopted Fed. R. Evid. 506, ?"clergyman? was 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 ofan established Protestant denomination.? There
simply is no evidence that Mr. Lamo meets this test. and even if he did meet the test, it is not
reasonable that PFC Manning would believe he was a ?clergyman? based on one brief statement
in an email chat by Mr. Lamo focusing not on the spiritual advice he could give PFC Manning,
but rather solely on the reasons the discussion would be con?dential: ?I'm a journalist and a
minister. You can pick either, and treat this as a confession or an interview (never to be
published) (it enjoy a modicum oflegal protection.? 10 Ex. 19(d), p. 2.

d. Assuming arguendo that Mr. Lamo were a clergyman, PFC Manning did not make
statements to Mr. Lamo in his capacity as a clergyman. In response to Mr. Lamo's offer to pick
one of two bases for con?dentiality, PFC Manning ignored Mr. Lamo?s statement that he was a
minister and asked ?assange level?? and ?or are you socially engineering indicating that PFC

In}

AFRC-MJVA
SUBJECT: Determination on Defense Assertion of Privilege Under M.R.E. 503.

Manning focused on Mr. Lamo?s statement that he was ajournalist. The chats do not indicate
that PFC Manning focused on Mr. Lamo?s statement that he was a clergyman.

e- The chats were which indicates that PFC Manning intended that they be
kept con?dential.

5. For the foregoing reasons, I determine that the ?rst two parts of the three-part of the test for
establishing that PFC Manning?s chats with Mr. Larno are covered by M.R.E. 503 are not met. I
thus deny the defense assertion of privilege under M.R.E. 503.

6. POC for this memorandum is the undersigned.

a;

PAUL R. ALMANZA
LTC. JA, USAR
Investigating Of?cer

CF:
Counsel

IN THE UNITED STATES ARMY
FIRST JUDICIAL CIRCUIT
UNITED STATES

DEFENSE NOTICE OF
EVIDENCE

V.

MANNING, Bradley PFC

US. Army.

Headquarters and Headquarters Company. US.
Army Garrison. Joint Base Myer-Henderson Hall.
Fort Myers VA 2221 1

DATED 23 December 201 1



1. The defense submitted Investigating Of?cer Exhibit number 19 in lieu of calling CPT Martin
Leibman. PT Michael Worsley. and PT Edan Crilchlield by telephone.

2. The Investigating Of?cer Exhibit should include the following:
a. Secretary of the Army 15-6 Executive Summary: Bates Number 00013163 - 00013170:
b. PFC Bradley Manning's Counseling Records: Bates Number 00013872 - 00013896;
c. MSG Paul Adkins? Memorandums for Record Bates Number 00013362 - 00013367;
d. PFC Bradley Manning's Mental Health Records Bates Number 00014069 - 00014143;
e. PFC Bradley Manning?s ?My Problem Email? Bates Number 00015006 - 00015003;

I. CID Computer Forensics ?C?rossdressingeom document" Bates Number 00036564 -
00036568;

g. CID Computer Forensics ?Amazon order [Facial Feminization Surgery)? Bates Number
00036572;

11. CID Computer Forensics '?Breanna Documents? 7- Bates Number 021695 - 021696. and
0216.93;

i. CID Documents Seized in PFC Bradley Manning?s CHU Bates Number 00045733;
00045583: 00045596 - 00045599; 00045619 4 00045680:

j. PFC Bradley Manning?s Equal Opportunity Complain Bates Number 00045585 -
00045586: 00045538 00045594.

110'. user. EXHIBIT 4/

00639



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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