Title: Volume FOIA 094

Release Date: 2014-03-20

Text: 30342

Volume 94 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 FCDIJC Ml/er: VA 22211
(Unit/Command Name) (Branch of Service) (Station or Snip)
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-9

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 ?verbatirri or ?surrimari'zeo? as appropriate. This form be used by the Army and Navy for verbatim records of triai

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

DD FORM 490, MAY 2000 PREWOUS OBSOLETE Front Cover



02885097 Previously Submitted in End 78
Previously in End 1
From: Fein, Ashden CPT USA SJA
sent: Monday, July 25, 2011 9:55 AM
To: COFFMAN, CARL COL MIL USA IMCOM
Cc: Matthew kemkes; Momow Ill, JoDean, CPT USA

Overgaard, Angel M.
CPT USA Ford, Arthur D. W01 USA Joshua
Tooman; Fond. Arthur D. W01 USA SJA

Subject: US v. PFC BM (Art 32 Delay Request)

Attachments: 11-Jul-25-Govemment Request to Delay Article 32 (ManningB).pdf
Importance: High

Sir,

The United States requests an additional delay o~F the Article 32. Please
see the attached request.

v/r
CPT Fein

Ashden Fein
CPT, JA

Defense_Unctass_Emai|_0635

02217288 Previously Submitted in Encl 78
Previously in End 1

From: comwm, cm COL MIL USA mcom

Sent: Monday, July 25. 2011 3:32 PM
To: Fein. Ashden CPT USA SJA
Cc: Matthew kemkes Morrow JoDean, CPT USA









SJA
coombs@am1ycourtmartialde ense.com;
M. CPT USA SJA
Arthur D. WOI USA
Joshua Tooman
SJ

Subject: Re; US v. PFC

Classi?cation: UNCLASSIFIED

Mr. Coombs.

Does the Defense have any issues with the request??
COL Coffman

Defense_Unclass_Emai|__O636

02216841 Previously Submitted in Encl 78




Previously in Encl 1
From:
Sent: Monday, July 25, 201 I 5:52 PM
To: COL MIL USA IMCOM
Cc: Matthew kemkes Morrow Ill, JoDean, CPT USA







SJA
Overgaard, Angel M. CPT USA A
Ford. Arthur D. W01 USA JFHQ-

Joshua Tooman

Fein, Ashden CPT USA SJA

Subject: [Suspected RE: US v. PFC BM (Art 32 Delay Request) (UNCLASSIFIED)
Attach: Article 32 Delay Request.pdf
Sir,

Please see the attached document for the defense response.


David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Office: 1-800-588-4156

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this

information may be unlawful and is

Defense_Unclass_Email_0637

02892690

Filename:

From:

Sent:
Subject:

Size:

Defense_UncIass_Emaii_O638



30346

RE: Protective Orders


Fein, Ashden CPT USA
SJA



Tuesday, July 26, 2011 7:14 AM
RE: Protective Orders (UNCLASSIFIED)

42KB (41,984 bytes)



02884706

30347

From: Fein, Ashden CPT USA SJA

Sent: Tuesday, July 26. 2011 8:10 AM

To:

Cc: Matthew kemkes: Morrow Ill. JoDean, CPT USA

Overgaard, Angel M. CPT USA Ford,
Arthur D. W01 USA Joshua Tooman

Subject: US v. PFC BM Discovery
Importance: High
David,

Good morning. we received your memorandum to the in reference to the Article 32 delay
request.

Yesterday, we delivered to MAJ Kemkes and placed in the US Mail for you, three DVDs of
discovery. These DVDs contain the majority of the unclassified CID case file (BATES 21364 -
36617), including a DVD of native files for certain file types. we are continuing to sort
through.the remaining information and seek the approvals we must have in order to produce
everything that is discoverable. As we have discussed in the past, our intent is to send the
information in waves as we receive approvals and not wait until we receive all approvals.

Below is a summary of the acknowledged protective orders we have received. Pursuant to the
protective orders, please ensure the information is not shared with any team member until we
receive a copy of the signed acknowledgments and initialed (or signed) federal protective
orders.

166% - Coombs, Kemkes, Santiago, and Purcell
Partial - Tooman
None All others

v/r
Ashden

Defense_Unclass_Emai|_0639

02981121

Previously in Encl 1
From: Fein, Ashden CPT USA SJA
Sent: Tuesday, July 26, 2011 8:10 AM
To:
Cc: Matthew kemkes; Momow Ill. JoDean, CPT USA

Ovengaand, Angel M. CPT USA Ford,
Arthur D. W01 USA ?Joshua Tooman'

Subject: US v. PFC BM Discovety
Importance: High
David,

Good morning. we received your memorandum to the in reference to the Article 32 delay
request.

Yesterday, we delivered to MAJ Kemkes and placed in the US Mail for you, three DVDs of
discovery. These DVDs contain the majority of the unclassified CID case file (BATES 21364
36617), including a DVD of native files for certain file types. we are continuing to sort
through the remaining information and seek the approvals we must have in order to produce
everything that is discoverable. As we have discussed in the past, our intent is to send the
information in waves as we receive approvals and not wait until we receive all approvals.

Below is a summary of the acknowledged protective orders we have received. Pursuant to the
protective orders, please ensure the information is not shared with any team member until we
receive a copy of the signed acknowledgments and initialed (or signed) federal protective
orders.

100% - Coombs, Kemkes, Santiago, and Purcell
Partial - Tooman
None All others

v/r
Ashden

Defense_Unclass_EmaiI_0640

02197661
30349

From: Ford. Arthur D. W01 USA JFHQ-NCRIMDW SJA

Sent: Tuesday. July 26, 2011 8:29 AM

To: Bouchard, Paul CPT MIL USA OSA

Cc: Fein, Ashden CPT USA

JFHQ-NCRIMDW Feito, Beatriz SGT USA JFHQ- NCRIMDW Fom, Arthur 0.
W01 USA SJA: Monow JoDean. CPT USA SJA:
Overgaard. Angel M. CPT USA Parra. Jairo A. W01 USA JFHQ-
Daniel W. SGT USA Whyle. Jeffmy H.
CPT USA JFHQ-NCRIMDW SJA

Subject: RE: Clari?cation; for computer forensic expert, Mr. Etic Lakes and Cyber Agents
(UNCLASSIFIED)
850006 By: A

Classification: UNCLASSIFIED
Caveats: FOUO

Sir,
Thank you very much for clearing that up for us.



Arthur Ford

W1, JA

Legal Administrator
com:
88:



Defense__Unclass_EmaiI_0641

30350



From: Fein, Asnden CPT USA SJA

Sent: Tuesday. July 26. 2011 9:13 AM
To: Ford, Arthur D. W01 USA 'Bouchard, Paul CPT MIL USA
cc: Feito, Beatnz SGT

USA JFHQ- Monow JoDean, CPT USA
Overgaard, Angel M. CPT USA SJA: Parra, Jalro A. W01 USA JFHQ-
NCRIMDW Waybright, Daniel W. SGT USA Whyte. Jeffrey H.
CPT USA JFHQ-NCRIMDW SJA
Subject: RE: Clari?cation; for compute: forensic expert. Mr. En?c Lakes and Cyber Agents
(UNCLASSIFIED)

Paul,

that about Trent Struttnann's clearance information? Could you please send
us his SSN so we can verify his clearance. Thank you.

Ashden

Defense_U ncIass_EmaiI_0642

02216836

30351













From: Bouchard. Paul CPT MIL USA

Sent: Tuesday, July 26, 2011 9:19 AM

To: Ford. Arthur D. WOI USA SJA

Cc: ein, Ashden CPT
USA A Feito. Beatriz SGT
USA JFHQ- SJA l> Ford. Anhur
W01 USA SJA
JoDean. CPT USA SJA
Anne! M. CPT USA SJ A

Parra. Jairo A. W01 USA JFHQ-

SJA Wavbriszht. Daniel W. SGT USA
SJA te, Jeffrey H.
CPT USA SJA

Subject: Re: RE: Clari?cation; for computer forensic expert, Mr. Eric Lakes and Cyber Agents
(UNCLASSIFIED)

Roger. Chief.



CPT Bouchatd

Defense_Unclass_EmaiI_0643

02216831

30352








From: Bouchard, Paul CPT MIL USA OSA
Sent: Tuesday, July 26, 20]] 9:21 AM
To: Fein, Ashden CPT USA SJA
Cc: Ford, Arthur D. W01 USA SJA

. Feito, Beatriz SGT USA JFHQ- SJA
Morrow JoDean. CPT USA IFHQ-
Overgaard, Angel M. CPT

USA SJA Parra, Jairo A.

W01 USA Wayb?ght,

Daniel W. SGT USA JFHQ-NC

Jeffrey H. CPT USA JFHQ-

SJA
Subject: Re: RE: Clari?cation; for computer forensic expert, Mr. Eric Lakes and Cyber Agents

(UNCLASSIFIED)
Roger. Ashden
I'm on it.

Paul

Defense_Unclass_Emai|_0644



02216814

30353

Tooman, Joshua CPT MIL us USA TRADOC

Tuesday. July 26. 2011 1:39 PM
To: Fein, Ashden CPT USA SJA

Subject: RE: Protective Otdets (UNCLASSIFIED)

signed By -

Classification: UNCLASSIFIED
Caveats: FOUO

Ashden
See attached.

Thanks,
Josh

Defense_Unc|ass_Emai|_O645



02884715 Previously Submitted in Encl 79
Previously S?abaggqted in Encl 1

From: Fein, Ashden CPT USA SJA

Sent: Tuesday, July 26, 2011 9:40 PM

To: 'Ahnanza,Paur

Cc: Matthew kemkes; Morrow JoDean, CPT USA
'Haber1and,John CPT MIL
Overgaand. Angel M. CP . Ford, Arthur D. W01 USA JFHQ-
?Joshua Tooman'

subject: US v. PFC BM Anicle 32 Delay

Attachments: Delay of Article 32 Investigation (ManningB).pdf

LTC Almanza,

Good evening. Please find attached an Article 32 delay approval signed by the


Thank you.

v/r?
CPT Fein

Ashden Fein
CPT, JA

Defense_Undass_Emai|_0646

02216813
I 30355


From: Bouchard, Paul Mr CIV USA AMC

Sent: Tuesday, July 26, 2011 9:41 PM
To: Fein, Ashden CPT USA SJA
Subject: Out of Of?ce AutoRepIy: US v. PFC BM Article 32 Delay

I will be on travel until August 1. I will be checking email. My cell for urgent matters.
Paul

Defense_UneIass_EmaiI_0647


02219487 Previously Submitted in End 79
30356

From Almam Paul

Sent: Wednesday, July 27, 2011 8:36 AM
To: Fein, Ashden USA sm
Cc: Matthew kemkes



Morrow JoDean, PT USA





Arthur D. W01 USA SJA
Joshua Tooman

Subject: RE: US v. PFC BM Article 32 Delay
Thank you. PT Fcin.
LTC Almama

Defense_Unclass_Emai|_O648



021 97501

30357

From: Fond, Arthur 0. W01 USA SJA

Sent: Wednesday, July 27, 2011 8:52 AM

TO: Bouchard. Paul CPT MIL USA OSA

Cc: Fein. Ashden CPT USA

Feito, Beatriz SGT USA JFHQ- NCRIMDW Ford, Arthur 0.
W01 USA SJA: Momow Ill, Jooean. CPT USA SJA:
Overoaard. Angel M. CPT USA JFHQ-NCRIMDW SJA: Parra, Jairo A. W01 USA JFHQ-
SJA: Daniel W. SGT USA JFHQ-NCRIMDW SJA: Whyte. Jaffney H.
CPT USA SJA

Subject: RE: Computer forensics. US v. Manning (UNCLASSIFIED)

Signed By: I

Classification: UNCLASSIFIED
Caveats: FOUO

Sir,

Thanks for your response. Mr. Lakes was not given a clearance for
this case; he already had one. If you want to request that Mr. Struttman be
granted a security clearance, you will need to request it in writing and
provide justification through the convening authority to the Army G2.

we can make it happen pretty quickly, if the convening authority
approves. Please let me know. Thanks.


Arthur Ford

B01, JA
Legal Administrator

com:
88:

Defense_Unc|ass_Emai|_0649

02902039



30358

From:
Sent:
To:

Cc:
subject:

Sir,

Are you available to chat?

Fein, Ashden CPT USA SJA
Wednesday, July 27, 2011 5:18 PM

I
Parra. Jairo A. W01 USA SJA
Forensic Expert Location

team setup at the Meade TDS. Thanks.

Ashden

Tracking:

Defense_Unclass_Email_0650

I would like to discuss the possibility of having the BM For-ensic

02901883



30359

From: Fein, Ashden CPT USA SJA
sent: Wednesday, July 27, 2011 7:58 PM

To:
Subject: Friday chat

David. Are you available to chat Friday morning?
like. Havea good evening.

Ashden

Defense_Unc|ass_Emai|_0651

I want to give you an update if you would

02216812
30360

From:

Sent: Wednesday. July 27, 201] 8:00 PM

To: Fein. Ashden CPT USA SJ
Subject: RE: Friday chat

Ashden,

Sounds good. What time do you want to have the chat?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Office:

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attorney-
client lnfom1ation and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, mpying or use of this
information may be unlawful and is

Defense_Unclass_EmaiI_0652



02901882

From:
Sent:
To:
Subject:

How is 1030?

Defense_Unc|ass_Email_0653

Fein, Ashden CPT USA JFHQ-NCRIMDW SJA
Wednesday, July 27, 2011 8:18 PM


Re: Friday chat

30361

02216810
30362

From:

Sent: Wednesday. July 27, 20] I 8:19 PM

To: Fein. Ashden CPT USA SJA
Subject: RE: Friday chat

Good for me. Just give me a call at the-number.

David E. Coombs, Esq.

Law Of?ce of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Office: 1-800-588-4156

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attorney-
client infomwation and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_Unclass_Email_0654



02197381



30363

From:

To:
Cc:

Subject
Attachments:

Signed By:

Caveats: FOUO

Sir,

Acknowledging receipt .



Arthur Ford

901, JA

Legal Administrator
com:
88:




Defense__Unc|ass__Email_0655

Ford. Arthur D. W01 USA SJA

Thursday. July 28, 2011 1:08 PM



Bouchard, Paul CPT MIL USA Fein, Ashden CPT USA
Feito, Beatriz SGT USA JFHQ- Ford, Arthur D. W01 USA JFHQ-
NCRIMDW Morrow JoDean. CPT USA JFHQ-NCRIMDW Overgaard, Angel
M. CPT USA JFHQ-NCRIMDW Pam. Jaim A. W01 USA
Waybright, Daniel W. SGT USA whyte, Jeffrey H. CPT USA
NCRIMDW SJA

FW: Request for Secret Clearance, Mr. Trent Struttmann. US v. Manning (UNCLASSIFIED)
Request for Sec Cleamece, Renewed Expert Request. Request
for Expert Assistant for PFC

I

Classification: UNCLASSIFIED
I
I

Thank you.



0221 6807
30364

From:
Sent: Thursday, July 28, 201 I 1:34 PM
To: Ford, Arthur D. WOI USA SJA

Cc: rem, Ashden cm USA sm
Morrow JoDean, CPT USA JFH SJA
Matthew kemkes

PM Bouchard Joshua

Subject: [Suspected RE: DVD for discovery (UNCLASSIFIED)








Mr. Ford,

I receive three CDs today. I tried opening the contents of each CD. Each time, I try the password?
or any variation thereof, I receive "Wrong password. Piease try again." Did you change the
passwor

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Of?ce: 1-800-588-4156

Fax: (508)689-9282



Notice: This transmission, including attachments, may contain confidential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete an copies. Unauthorized disclosure, copying or use of this

information may be unlawful and is

Defense_Unclass_EmaiI_0656



02197374

30365

From: Ford, Arthur D. WO1 USA SJA
Sent: Thutsday. July 28. 2011 2:32 PM
To:
Cc: Fein, Ashden CPT USA Morrow JoDean. CPT USA JFHQ-
Matthew kemkes; Paul Bouchard; Joshua Tooman;

I
Subject: RE: [Suspected RE: DVD for discovery (UNCLASSIFIED)
supwuIBy: I

Classification: UNCLASSIFIED
Caveats: FOU0

Sir,

I apologize For that. The password for this series of discs is v. PFC
Bradley Manning?. Additionally, the files named 22863-23362 and 24363-24862

have a password are

This is a complete oversight on my part. I am writing an SOP for this
process right now, so that we do not have this happen again.

is a more secure password, and will be the one
required by our SOP.

Thank you bringing it to my attention, and thank you For your patience as I
iron out the kinks in this new process.



Arthur Ford

ml, JA

Legal Administrator
Comm:
BB:



Defense_U nclass_EmaiI_0657






02216803
30366

From:

Sent: Thursday. July 28, 20! I 6: I4 PM

To: Ford. Arthur D. USA SJA

Cc: Fein, Ashden CPT USA SJA

Morrow JoDean, CPT USA IF SJA
Matthew kemkes
Pau Bouchard Joshua
Tooman
Subject: RE: [Suspected RE: DVD for discovery (UNCLASSIFIED)
Mr. Ford,

No worries. Thank you for responding so quickly. So far I have not had a problem opening any of the
?les. I have around six more to go. I will let you know if I have any issues.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs
11 South Angell Street, #317
Providence, RI 02906

Of?ce: 1-800-588-4156

Fax: (508) 689-9282


Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended

recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_UncIass_Email_0658



02933155

30367

1
From: Fein. Ashden CPT USA JFHQ-NCRIMDW SJA
sent: Friday, July 29, 2011 10:56 AM
To:
Subject: RE: Friday chat

David,

Once again, I apologize. we have an awards ceremony that I could not escape.
I will be calling in 10 min if you are available. Thanks.

Defense_Unc|ass_Emai|_O659

02216801
30368

From:

Sent: Friday, July 29, 2011 10:55 AM

To: Fein, Ashden USA sm
Subject: RE: Friday chat

Ashden,

Do you still want to talk this morning?
Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Of?ce: 1-800-588-4156

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attorney-
ciient information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_U nciass_EmaiI_0660



029331 53

30369

From: Fein, Ashden CPT USA SJA
Sent: Friday, July 29, 2011 11:06 AM

To:
Subject: RE: Friday chat

David,

I apologize again. I should have known better scheduling a phone call for
Friday morning. Lesson learned. Between connectivity issues and the awards
ceremony, this morning is proving to be difficult. we are heading to a
meeting at 1130 and should be back by 1500. How is 1600?

Ashden

Defense_UncIass_Emai|_0661



02216798

30370

From:
Sent: Friday, July 29, 20: I 11:25 AM

To: Fein, Ashden cm USA sm

Subject: RE: Friday chat

Ashden,
This afternoon does not work well for me. Let's shoot for Monday. What would be a good time for you?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Office: 1-800-588-4156

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attorney-
client lnfomwation and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_Unclass_Emai|_0662



029331 50

From:
Sent:
To:
Subject:

How about 1300?

Defense_Unc|ass_Emai|_0663

Fein, Ashden CPT USA SJA
Fliday, July 29, 2011 2:15 PM


RE: Friday chat

30371



02216794

30372

From:
Sent: Friday, July 29, 201 I 4:01 PM

To: ein. Ashden CPT USA SJA

Subject: RE: Friday chat

Sounds good. Have a great weekend.

Best,
David

David E. Coombs, Esq.

Law Of?ce of David E. Coombs

11 South Angell Street, #317
Providence. RI 02906

Of?ce: 1-800-588-4156

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_Unclass_Email_0664





02933146

30373

From: Fein, Ashden CPT USA SJA
Sent: Friday, July 29. 2011 4:09 PM

To:
Subject: RE: Friday chat

Same with you and your wife.

Defense_UncIass_EmaiI_0665

02197245
30374

From: Ford, Arthur D. WO1 USA SJA

sent: Monday. August 01. 2011 2:30 PM

To: Bouchand, Paul CPT MIL USA OSA

cc: Fein, Ashden CPT USA Feito, Beatriz SGT USA JFHQ-

Ford, Anhur D. W01 USA Morrow JoDean, CPT USA
Overgaard, Angel M. CPT USA JFHQ-NCRIMDW Parra, Jairo
A. W01 USA Daniel W. SGT USA
Whyie, Jeffrey H. CPT USA SJA

Subject: RE: Computer forensics, US v. Manning (UNCLASSIFIED)

S?gnedlayz

Classification: UNCLASSIFIED
Caveats: FOUO

Sir,

I am putting the documents together For this request. Can you
please send me Mr. Struttmann's date and place of birth? Thanks.



Arthur Ford
N01, JA
Legal Administrator

Comm:
BB:



From: Bouchard, Paul CPT MIL USA OSA [ma11to?.]
Sent: Tuesday, July 26, 2011 12:30 PM

To: Ford, Arthur D. H01 USA SJA

Cc:

Subject: Computer Forensics, US v. Manning

Mister Ford:

Trent Struttmann's is

I'm sorry I didn't know this earlier, but he will need a security clearance.
The Government got one for Mr. Lakes and now one of his employees, Mr.
Struttmann, will need the same. Please keep me in the loop on this --
paperwork, etc.

Also, how long do you think it will take For Mr. Struttmann to get a
security clearance?

Appreciate any feedback, and I apologize for not knowing earlier that Mr.
Struttmann needs a clearance.


CPT Paul Bouchard

original Message

Defense_Undass_Emai|_0666


02197245
30375

From: "Ford, Arthur D. W01 USA

?ues!ay, !u!y

Subject: RE: Clarification; for computer forensic expert, Mr. Eric Lakes and
Cyber Agents (UNCLASSIFIED)

To: "Bouchard, Paul CPT MIL USA
Cc:
Ashden CPT USA
Beatriz SGT USA JFHQ- SJA
"Ford, Arthur D. N01 USA
















"Morrow JoDean, CPT USA

"Overgaard, Angel
M. CPT USA JFHQ-NC "Parra,
Jairo A. W01 USA

"waybright, Daniel w. USA JFHQ-

?whyte, Jeffrey H. CPT USA

Classification: UNCLASSIFIED
Caveats: FOUO



Sir,



Thank you very much for clearing that up for us.






Arthur Ford

N01, JA

Legal Administrator

Comm:








From: Bouchard, Paul CPT MIL USA OSA

Email??
Sent: Mon ay, Ju 25, 2011 6:02 PM

To: Ford, Arthur D. W01 USA
Cc:
Subject: Clarification; for computer forensic exper r. ric

Lakes and
Cyber Agents (UNCLASSIFIED)

Mister Ford:

Thank you for your last e-mail. The following addresses the
you
pointed out:

Right now, we are still in the evidentiary phase of the case and our
monetary request is simply for evidence review and not trial prep.
US v.

Manning, as you know, is a big case involving some 8 terabytes of
data, data

the Defense has yet to receive from the Government. As such, there



2

Defense__U nclass_EmaiI_0666

02197245

is no way
Mr. Eric Lakes can predict how long it will take him and one of his
employees, Trent Struttmann, to do the analysis.

The computer forensics analysis will take place in the D.C. area.

It will be

performed by Mr. Lakes and Mr. Struttmann. To reduce travel costs,
they will

drive together from Lexington, Kentucky, instead of flying into D.C.

Cyber Agents will bill the Government weekly with the expectation

of being

paid on a basis. Like any business, Cyber Agents has expenses
(payroll, taxes, rent, etc.) and thus has cash flow needs.

Our request came in at $8,000.00 already approved, plus
$2,400.00) plus travel expenses. If the computer forensics
analysis takes

longer than that covered by the $8,000.00, then those additional
hours would

be billed at $175.00 per hour. Mr. Lakes roughly estimated
$8,000.00 for him

and Trent (plus travel expenses) to do the computer analysis, but
again,there is no way of telling how long the computer analysis
will take.

Mr. Lakes would like to be paid half upfront to cover
travel for

him and Trent. He informed me when he does cases involving the
Marines he's

paid half upfront for travel.

Note: Mr. Lakes now charges $1,600.00 per day per person for trial
workinstead of $1,400.00 per day per person as listed on one of
the old

attachments. However, this rate deals with trial prep -- basically
do we

need Mr. Lakes, or one of his employees, to be at the trial and/or
testify?Again, our request is for evidence review and analysis
right now. The

Defense does not know if we will need Mr. Lakes testimony or
presence at the

trial, but if we do, Cyber Agents will bill those services at that
rate --

$1,600 per day per person.

I hope this clears things up. Please feel free to e-mail me or
call me
anytime. My contact information is listed below.

Respectfully,

CPT Paul Bouchard
Defense Counsel

Trial Defense Services
Fort Meade, MD 20724

owe:



Defense_UncIass_EmaiI_0666

30376

02197245





cen=

Original Message

From: "Ford, Arthur D. N01 USA



Date: Tuesday, July 19, 2011 19:33

Subject: RE: Renewed request For computer Forensic expert, Mr.

Eric Lakes

and Cyber Agents (UNCLASSIFIED)

To:

Cc: "Fein, Ashden CPT USA
"Morrow JoDean, CPT USA
"Overgaard, Angel

M.

CPT USA

Classification: UNCLASSIFIED
Caveats: FOU0

Sir,
The request does not

I have some questions regarding your request.
match the fee schedule from the company.

The company charges $1,300 per additional hard drive, not $175 per
hour. (However, this does work out to about a 7.5 hour work day,
so if this
is the rationale, I just need to know how Cyber Agents intends to
invoice.)

They also charge $1,460 for trial prep, consulting, and testimony,
which is not addressed in the request. They charge this for every
day they
are out of their lab, and it is not addressed in your request. It
does not
address whether or not this is in addition to the $1,399 per hard
drive, or
just when they are here doing something that is not forensics.
whatever it
is, we need to know whether or not they will invoice us For it.

The request mentions employees generally, but not by name. we need
to know who they are so we can get P0's signed and clear up any
securityissues. Also, they need to tell us how many people they
are bringing so we
can estimate travel costs and ensure workstations are provided.

I don't remember ever hearing of an expert, or any contractor, being
paid in advance, and if you or Mr. Coombs have negotiated this,
then we need
to know that.

Thanks very much, Sir.

Defense_Unc|ass_EmaiI__0666

30377



02197245



H01 Arthur Ford
Legal Administrator
OSJA, USAMN



From: Ford, Arthur D. N01 USA SJA

Sent: Wednesday, July 13, 2011 2:42 PM

To: Feito, Beatriz SGT USA JFHQ- SJA

Subject: Fw: Renewed request for computer forensic expert, Mr.
Eric Lakes

and Cyber Agents (UNCLASSIFIED)



Classification: UNCLASSIFIED
Caveats: FOU0



W01 Arthur Ford
Legal Administrator
OSJA, USAMDN







From: Fein, Ashden CPT USA SJA

Sent: Wednesday, July 13, 2011 2:38 PM

To: Ford, Arthur D. N01 USA Overgaard, Angel M.
CPT USA

SJA

Subject: Fw: Renewed request for computer forensic expert, Mr.
Eric Lakes

and Cyber Agents

Ashden Fein
CPT, JA





From: Paul Bouchard [mailto

Sent: Thursday, July 67, 2611 2:30 AM

To: Fein, Ashden CPT USA SJA

Cc: com;
Subject: Renewed request For computer Forensic expert, Mr. Er

Lakes and




Defense_Unclass_Email_0666

30378



02197245

Cyber Agents
Ashden:

This is what we talked about -- the Defense renews its request For
Mr. Eric

Lakes and his company, Cyber Agents Inc., as an expert assistant
For the

Defense team. See attachments -- Mr. Lakes was previously approved
by the

original convening authority For $5,600.00. Given the amount of
data in the -

case at hand, Mr. Lakes will need more Funding to include costs
associatedfor travel.

Importantly, given that there is no way to precisely pinpoint how
long and

time consuming the computer Forensics will take, we are asking
that any

additional work be billed and subsequently paid at $175.00 per hour.

The first attachment clearly outlines our requests. The other
attachmentsare supporting documents.

I'll be at Fort Meade late next week.

E-mail me or call me should you have any questions.
Best,

Paul

Classification: UNCLASSIFIED
Caveats: FOUO

Classification: UNCLASSIFIED
Caveats: FOUO



Classification: UNCLASSIFIED
Caveats: FOUO



Classification: UNCLASSIFIED
Caveats: FOUO

Defense_Unc1ass__Email_O666

30379

02216793
30380

From: Tooman, Joshua CPT MIL US USA TRADO

Sent: Monday, August 01, 2011 3:10 PM
To: Fein, Ashden CPT USA SJA

Subject: Protective Ordets UNCLASSIFIED)
Signed By:

Classification: UNCLASSIFIED
Caveats: FOU0

Ashden
Can you verify that I have submitted all the necessary protective orders?

Thanks,
Josh

CPT Joshua J. Tooman

Defense Counsel

U.S. Army Trial Defense Service
415 Custer Avenue

Fort Leavenworth, Kansas 66027
Phone:

Fax:

DSN -

This e-mail message and any attachments may contain privileged
attorney-client and/or work-product information or other information
protected from release under FOIA. If you have received this e-mail in
error, please notify the sender. Do not copy or forward this e-mail without
the permission of the sender.

Classification: UNCLASSIFIED
Caveats: FOUO

Defense_Unclass_Emai|_0667



02922833

30381

From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA
Sent: Monday, August 01, 2011 4:15 PM

To: Tooman. Joshua CPT MIL US USA TRADOC
Cc: Ford, Arthur D. W01 USA JFHQ-NCRIMDW SJA
subject: RE: Protective Orders (UNCLASSIFIED)

Josh,

I am kicking this to Mr-. Ford for reply.

Ashden

Defense_Unc|ass_EmaiI_0668

30382



From: Tooman. Joshua CPT MIL US USA TRADOC
Sent: Monday. August 01. 2011 5:02 PM
To: Fein, Ashden CPT USA SJA

Subject: RE: Protective Otders UNCLASSIFIED)
Signed By: I

Classification: UNCLASSIFIED
Caveats: FOU0

Ihanks, Ashden.

Defense_Unc|ass_Emai|_0669



0291 7374

30383

From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA

Sent: Monday, August 01. 2011 6:01 PM

To:

Cc: Matthew kemkes; Morrow JoDean, CPT USA

Overgaard, Angel M. CPT USA JFHQ-NCRIMDW Fond,
Arthur D. W01 USA JFHQ-NCRIMDW Joshua Tooman
subject: Update

David,
Pursuant to our conversation today, below are some updates:

1. You asked about additional classified information being found above
the approx 10,000 on BM's personal computer: Yes, much more. It was found
on additional media devices that are not USG owned. The items are listed in
the unclas case file we produced. MTF on the details of the information
from the classified side of the file.

2. we intend on providing your defense experts a sterile laptop

computer with windows 7 for classified information. We intend on providing
a location (Ft Meade TDS) and a 5 drawer safe. we also will provide a Lacie
8Tb cube of classified forensic images of all the forensic evidence. we
expect them to bring their own encase software and other software forensic
tools.

3. we will provide all recordings we have from confinement at the TCF
and Quantico in the next wave of discovery, after tomorrow's CD is sent.

v/
Ashden

Defense_Unolass_EmaiI_O670

30384


Monday, August I, 2011 PM

Fein, Ashden CPT USA SJA
Matthew kemkes






Morrow Ill. oDean. CPT USA

Angel M. CPT USA SJA
Ford, Arthur D. W01 USA JFHQ-
I oshua Tooman




NC SJA

Subject: [Suspected RE: Update

Ashden,

1. Can you tell me which media devices (by BATES number) contained the additional information?
2. I will run this by our forensic experts to see if they have any concerns.

3. Sounds good.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Of?ce: 1-800-588-4156

Fax: (508) 689-9282




Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_Unclass_Emai|_0671

02949112
30385

From: Fein, Ashden CPT USA SJA

sent: Tuesday, August 02, 2011 7:55 AM

To:

cc: Matthew kemkes; Morrow Ill. JoDean. CPT USA

Ovetgaand, Angel M. CPT USA Ford,
Arthur . 0 SA - ?Joshua Tooman'
subject: RE: [Suspected RE: Update
David,

There are multiple media devices that other classified information was found
on and I would prefer to wait until we have the final approvals for releasing
classified information before identifying the exact items. All the
information is inextricably commingled and I do not want to release
potentially classified information without the proper authority and through an
improper medium.

Ashden

Defense_UncIass_EmaiI_0672



02197179

30386

From:
Sena:
To:
Cc:

Subject:
Signed By:

Fond, Arthur D. W01 USA SJA

Tuesday, August 02. 2011 1:40 PM

Paul Bouchani

Fein. Ashden CPT USA
Momow JoDean, CPT USA SJA

RE: Message and update from CPT Bouchani (UNCLASSIFIED)

I

Classification: UNCLASSIFIED

Caveats: F000
Sir,

No problem .
approved .

Chief



Arthur Ford
N01, JA
Lega
Comm:
88:

dninistrator

Defense_Unclass_Email_O673

I can't really give you an answer, because I don't want
comit the G2 to anything.
Thanks very much.

I will let everyone know as soon as it is

30387



From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA

Sent: Tuesday. August 02, 2011 2:51 PM
To:
Cc: Matthew kemkes' Morrow Jooean, CPT USA SJA:

Overgaam, Angel M. CPT USA JFHQ-NCRIMDW SJA: Fond,
Arthur D. W01 USA SJA: Joshua Tooman
Subiect: Discovery Update (US v. PFC BM)

David,

we sent you and Kemkes the following today in discovery (BATES
36618-36802)

CID Case File Updates

FLAG Memo for Sec Army 15-6

SFC Adkins Reduction Board Appeal and Attachments
BM's newly executed Nondisclosure Agreement (ADA)
Your tracking number: 7910 1960 0001 1272 6251.

v/r?
Ashden

Defense_Unclass_EmaiI_0674

02982675

30388

Fronu
sent
To:
Cc:

Sumed:

David,

Fein, Ashden CPT USA SJA

Tuesday, August 02,2011 2:51 PM



Matthew kemkes; Morrow JoDean, CPT USA

Overgaard, Angel M. CPT USA Ford,

Arthur D. W01 USA ?Joshua Tooman'

Discovery Update (US v. PFC BM)

we sent you and MAJ Kemkes the Following today in discovery (BATES

36618- 36802):

CID Case File Updates

FLAG Memo for Sec Army 15-6
SFC Adkins Reduction Board Appeal and Attachments
BM's newly executed Nondisclosure Agreement (NDA)

Your tracking number:

v/r
Ashden

Defense__UncIass_EmaiI_0675

7010 1060 0001 1272 6251.

0221 6784
30389

From Paul

Sent: Tuesday, August 2, 20] I 3:39 PM

To: rem, Ashden cm USA sm
Cc:

Subject: Fw: Forensic Laptop Hardware and Software
Attach: Eric Lakes CCE.vcf
Ashden:

Please read the below e-mail. It is from the Defense's computer forensics expert, Eric Lakes. It lists what he and
Trent Struttmann (one of his employees) will need to do the computer forensics work.

If need be, maybe we can have a conference call - me, you, and Eric -- to hash this out.

I read that the Government is considering the Fort Meade TDS Office as space for Mr. Lakes to do some of the
work. We do have plenty of space here. so I think it will work.

Please let me know if there are any issues. concerns. etc, with the specs outlined by Mr. Lakes.

My O?ice number is - and my cell phone is-

Thanks.
Paul

Defense_Unclass_Emai|_0676



0221 6782

30390



From Paul Bouchard:

Sent: Tuesday, August 2, 201 1 3:42 PM

To: Ford. Arthur D. WOI USA SJA

Cc: Fein, Ashden CPT

USA SJ A Morrow 111,
JoDean, CPT USA SJA

Subject: Re: Message and update from CPT Bouchard (UNCLASSIFIED)

Thanks. Chief.

Much appmciaicd Our position is the sooner the better. Do keep me posted.

Thank you.

Respectfully.

CPT Bouclmd

Defense_Unclass_EmaiI_0677



02933377

30391

From: Fein, Ashden CPT USA SJA

sent: Tuesday,Augus1 02. 2011 3:43 PM

To: ?Paul Bouchanf

Cc: Ford. Arthut D. W01

USA SJA
subject: RE: Forensic Laptop Hardware and So?ware
Paul,

A conference call is best. Set a time and lets chat. I am available after 1600 today, all
night, and most of tomorrow.

Ashden

Defense_Unclass_Email_0678

02216778
30392

From: Paul Bouchard?

Sent: Tuesday, August 2, 2011 4:26 PM

To: Fein, Ashden CPT USA SJA
Cc=

Subject: Re: Forensic Laptop Hardware and Software
Ashden:

What's the best phone number to call you at??

Thanks,

latd

Defense_Unclass_Emai|__0679

30393



From: Fein. Ashden CPT USA JFHQ-NCRIMDW SJA

Bent: Tuesday, August 02. 2011 4:48 PM

To: ?Paul Boucharcf

Cc: Ford, Arthur D. W01 USA SJA
subject: RE: Forensic Laptop Hardware and Software

-is my direct line. -is the office.

Defense_Unclass_Email_0680



02216771

30394

Fr?m= Bouchard

Sent: Tuesday. August 2, 20] I 5:24 PM

To: Fein, Ashden cm USA sm
Cc=

Subject: Re: Forensic Laptop Hardware and Software

CPT Fein. Mr. Lakes:

Wha1 is a good time for us to have a conference call tomonow? My schedule is
?exible.



Bouchard

Defense_UncIass_EmaiI_0681



30395



How is 1300

Defense_Unc|ass_EmaiI_0682

Fein, Ashden CPT USA SJA
Tuesday, August 02. 2011 5:25 PM
?Paul Bouchanf

Ford. Arthur 0. W01 USA JFHQ-NCRIMDW SJA
RE: Forensic Laptop Hardware and Software

02217123
30396

From: Eric Lakes
Sent: Tuesday, August 2, 2011 5:33 PM

To: Fein, Ashden CPT USA SJA

Paul Bouchard mi
Cc: F0rd, Arthur D. W01 USA SJA

Subject: !orens1c!aptop Hargware an! !oftware

That's good for me as well - call my cell number

Eric Lakes

Digital Forensic Examiner

Certi?ed Computer Examiner (CCE)
Certi?ed Homeland Security -
MCSE. MCP, Network Plus,
Cyber Agents, lnc.


616 Pasadena Drive

Lexington, KY 40503

cell -

Defense_U nciass_Em ai|_0683

02933358

30397

From:
Sent:
To:

Cc:
Subject:

Paul,

my don't you initiate and give us a can here at

Defense__Unclass_Email_0684

Fain, Ashden CPT USA SJA
Tuesday. August 02. 2011 5:36 PM

?Paul Bouchand'
Ford. Arthur D. W01 USA JFHQ-NCRIMDW SJA
RE: Forensic Laptop Hatdware and Software



02216767
30398

From Paul B?uchard?

Sent: Tuesday, August 2, 20] I 5:48 PM

To: E-ic Lake-s?

Cc: Ford. Arthur D. W01 USA SJ A

n, Ashden CPT USA SJA

Subject: Re: Forensic Laptop Hardware and Software

Mr. Lakes;

I need Trent's date of birth and place of birth for his security clearance. Also, Trent can start ?lling out the form
SF-86 as a hard copy so when he get's it in digits it'll be easier for him to complete. Lastly. we're planning a
conference call with CPT Fein for tomorrow at 1300. Let me know if this works for you.

Thanks,

CPT Bouchard

Defense_Unclass_Emai|_0685

02216765
30399





From:

Sent: Tuesday, August 2, 20] 7:19 PM

To: Fein. Ashden CPT USA SJA
Cc: Matthew kemkes Morrow Ill. JoDean. CPT USA





. Ovenzaard. Angel M. CPT USA SJA
Ford, Arthur D. W01 USA JFHQ-

A

Subject: [Suspected RE: Discovery Update (US v. PFC BM)

Ashden,
Thank you for the update.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs
11 South Angeli Street, #317
Providence, RI 02906

Office: 1-800-588-4156

Fax: (508) 689-9282




Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this

information may be unlawful and is

Defense_Unclass_EmaiI_o686



02216757

30400

From: Paul Bouchard?
Sent: Wednesday, August 3, 2011 9:22 AM

To: Fein, Ashden CPT USA SJA
Cc:

Subject: Re: Forensic Laptop Hardware and Software

Ashden and Eric.

Our conference call is slated for 1300 EST today.
I will call you both.

Best,

Paul

Defense_Unclass_Emai|_0687



02216756

Previously Sggmitted in Encl 1




From:

Sent: Wednesday, August 3, 2011 9:51 AM

To: Fein, Ashden CPT USA SJA
Cc: Matthew kemkes Morrow JoDea.n, CPT USA

SJA
Overgaard, Angel M. CPT USA SJ A
Ford, Arthur D. W01 USA IFHQ-
Joshua Tooman
Subject: Security Experts
Ashden,

My security expert informs me that no laptops were provided to them during the 706 - only safes to store.
I asked him how many laptops he would need, and he informed me that they would need three laptops to

review information. Let me know if you have any questions.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Of?ce: 1-800-588-4156

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this

information may be unlawful and is

Defense_Unclass_Emai|_0688

02216752
30402

Fr?'n=

Sent: Wednesday, August 3, 20] I I 1:35 AM


Cc: Fein. Ashden USA sm

Subject: Re: Forensic Laptop Hardware and Software

Ashden and Eric.
I will call you both at 1300 EST.

Below are the computer specs the Defense requires.
Thanks,
paul

Defense_Unclass__Emai|__O689

02933354
30403

From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA
8cm: Wednesday. August 03, 2011 1:00 PM

To: Paul Bouchard; Eric Lakes

subject: RE: Forensic Laptop Hardware and Software

Paul, I made it ontime. Please call when you can -

Defense_Unclass_EmaiI_0690

. 02920392

30404

From: Fein. Ashden CPT USA SJA

Sent: Wednesday. August 03. 2011 1:00 PM

To:

Cc: Matthew kemkes: Motrow Ill, JoDean, CPT USA

Overgaard, Angel M. CPT USA JFHQ-NCRIMDW Ford,
Annur D. W01 USA JFHQ-NCRIMDW Joshua Tooman
Subject: RE: Security Experts

Thank you.

Defense_Unclass_Emai|_0691



02216750
30405

ro-I-= Paul B?u?hard?

Sent: Wednesday, August 3, 20ll PM

To: Ford. Anhur D. WOI USA SJA

Cc: ?Fein, Ashden CPT USA SJA
Subject: Re: Message and update ?'om PT Bouchard (UNCLASSIFIED)

CPT Fein and Chief Ford;

Trent Struttmann's date of birth is and his place of birth is


CPT Bouchard

Defense_UncIass_Emai|_O692



02197145

30406

Ford, Arthur D. W01 USA SJA

Wednesday, August 3, 20|l l:03 PM

Fein. Ashden CPT USA SJ A

Re: Message and update from CPT Bouchard (UNCLASSIFIED)

From:
Sent:
To:
Cc:



Subject:

Sir,
Thanks.


W01 Arthur Ford
Legal Administrator



Defense_Unclass_Emai|_0693





02217111

30407

Fro-n= Encmesm

Sent: Wednesday, August 3, 2011 2:07 PM

To: ?Paul Bouchard'
Cc: Fein, Ashden CPT USA

Subject: RE: Message and update from CPT Bouchard (UNCLASSIFIED)
Attach: Eric Lakes CCE.vcf; Image (3).jpg; Image (4).jpg; Image (5).jpg; Image (6).

SATA LapTop Hard Drives re:
SAMSUNG Spinpoint MP4 HMSOOJJ 500GB 7200 RPM 2.5" SATA 3.0Gbls lntemal Notebook Hard Drive -Bare Drive

Cache: 1&6
Average Latency: 4.13m:
Features: SATA hhtive Commend Queuing Feature head with FOD technology Loed/Unload Heed Technology Silentseek NoiseGuerd

Parts: 3 years iimied
Model

-99

In some cases running a process from EnCase can take 8 or more hours before another process can be performed so we
may have to have someone in the area where the computer/s are running until the process is done.

CAGE Code for Cyber Agents, Inc. 4BTY1

.A.A.. .. .. .



(2 - License of NetAna|vsis)

?190.00 each

(2 - VMWare Workstation) -
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(2 - Live View Government) - free to Government

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(2 -Snaglt) -Snagit License: $49.95 USD each
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QTY: each

(2 - Microsoft Office PRO 2010 - Word, Excel, PowerPoint, Access, OutLook) - For a new PC preloaded with Microsoft ornce 2010
Oftice 2010 Professional Product Key card (no media)
System Requirements: Computer and processor: 500 or {ester processor Memory: 256 MB 512 MB recommended for graphics features, Outlook Instant Search,

and certain advanced functionality.
1 Hard disk: 3.0 GB eveiable disk space Dispiay: 1024x576 or higher resolution mentor Operating system: Windows XP with Service Pack (SP) 3 (32-bit operating system

(08) oniy) or\Mndows

Defense_UncIass_EmaiI_0694

02217111
30408

Features: Product Key. no Disc. For use with 1 new PC preloaded with O?ice 2010? (?Software downtoad also available at productkeycard) lndudes 2010
versions 01

Word. Excel. PowerPoint,OneNote.Out1ook. Publisher and Aooess. Mucmso? O?ica Professional 2010 gives you the tools to manage your business. connect with customers
and organize your life. Access

Model 269-14834

Item 8: N82E16832116859

Return Policy: Software Standard Return Poliq

$299.99 each
Adobe Acrobat Pro



Foil from

US 449.00
(2 - Adobe Acrobat) - each

1 1: Eric Lakes," cc:
Cyber Agents, Inc.

Dicital Forensic Examiner




3

From: Paul Bouchard [mai
Sent: Wednesday, August 03, 2011 1:03 PM
To: Ford, Arthur D. W01 USA SJA

Fein, Ashden CPT USA SJA
Su ect: Re: Message an update from CPT Bouchard (UNCLASSIFIED)
CPT Fein and Chief Ford:

Trent date of birth is and his place of birth i?


CPT Bouchard



To: "Ford, Arthur D. A -

Cc: ein, Ashden CPT USA
orrow I I, JoDean, CPT USA

Sent: Tuesday. August 2, 2011 3:42 PM
Subject: Re: Message and update from CPT Bouchard (UNCLASSIFIED)





Thanks, Chief.

Defense_Unclass__Email__0694

30409



Much appreciated. Our position is the sooner the better. Do keep me posted.

Thank you.
Respectfully,

CPT Bouchard

Defense_U ncIass_EmaiI_0694

30410






Fm-= vwraouchudm
Sent. Wednesday, August 3, 2011 2:23 PM

To: Fein. Ashden CPT USA
Cc: Ford. Arthur D. W01 USA SJA

Matthew kemkes

Subject: Fw: Message from CPT Bouchard

Attach: Eric Lakes CCE.vcf; Image (3).jpg; Image (4).jpg; Image (5).jpg; Image (6).jpg

Mister Ford:

The attachments are the signed protective orders by Eric Lakes. one of the computer forensics experts for the

Defense team in US v. Manning.

Respectfully,
CPT Bouchard

Defense_Unc|ass_Email_O695

02216739
3041 1

From: Pam aoucr-van

Sent: Wednesday, August 3, 20] I 2:26 PM

To:
Cc: Fein, Ashden CPT USA SJA

Subject: Re: Message and update from CPT Bouchard (UNCLASSIFIED)

Ashden FYI:

What we talked about during our recent teleconference. I think Eric sent it to you previously; just ensuring you
got it.



Paul

Defense_U nclass_Emai|_O696

02197128

30412

I

From: Ford, Arthur 0. W01 USA SJA

Sent: Wednesday. August 03. 2011 2:34 PM

To: Matthew kemkes

Cc: Bynoe, Lisa Monow Ill, JoDean, CPT USA

JFHQ-NCRIMDW Fein, Ashden CPT USA JFHQ-NCRIMDW SJA

Subject: RE: Discovety (UNCLASSIFIED)

suul?y: I

Classification: UNCLASSIFIED

Caveats I FQJO

MAJ Kenkes,

I just received a call from CID, saying that the discovery disc I
sent to you on 1 Jul was delivered on 26 Jul.
delivery, and let me know what condition the package was in?


Arthur Ford

wo1, JA
Legal Administrator

Conn:
88:

Defense_UncIass_EmaiI_0697

Could you please confirm
Thanks.

02216737
30413

From: Bynoe. Lisa RES usA usARc
Sent: Wednesday, August 03. 2011 2:3

To: Ford, Arthur D. W01 USA Matthew kemkes
Cc: Morrow Ill, JoDean. CPT USA JFHQ-NCRIMDW
Fein, Ashden CPT USA SJA
subject: RE: Discovery (UNCLASSIFIED)
s?gnedlBy:

Classification: UNCLASSIFIED
Caveats: FOUO

Sir,
The package was received and in good condition.

Respectfully,

Ms. Lisa Bynoe

TDS Paralegal

Trial Defense Services
204 Lee Ave, Suite 812
Fort Myer, VA 22211

Defense_UncIass_EmaiI_0698

30414



Fnmn:
sen
To:

Cc:
Sub?n:
Eric,
Thank you.

Ashden

Fein, Ashden CPT USA SJA
Wednesday. August 03. 2011 3:43 PM
Eric Lakes; ?Paul Bouchand';

. ur SJA
RE: Message and update from CPT Bouchatd (UNCLASSIFIED)

How many hard drives?

Defense_Unclass_Emai|_0699

02217102
30415

From: em Lakes?

Sent: Wednesday, August 3, 20] 1 4:16 PM

To: Fein. Ashden CPT USA SJA
Cc: 'Pau| Bouchard'
Subject: RE: Message and update from PT Bouchard (UNCLASSIFIED)

Attach: En'c Lakes CE.vcf

2 - one for each lmtop

Defense_UncIass_EmaiI_070O

02216709
Previously in Encl 1

From:
Sent: Wednesday, August 3, 20H 5: IO PM
To: Fein, Ashden CPT USA SJA

Cc: Matthew kemkes Morrow 111, oDean. CPT USA





vergaar Angel M. CPT USA SJA
Ford, Arthur D. W01 USA
Joshua Tooman

Subject: Expert Request
Attach: Dr. G?eger Capt. Moore Emailpdf; Dr. Grieger Cum'culum Vitaepdf; Dr.
Gricgcr Fee Schedulepdf
Ashden,

Please see that attached expert request. Let me know if you have any questions based upon a review of
the request and attachments.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Office: 1-800-588-4156

Fax: (508) 689-9282


mm@

Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_Unclass_Email_0701

02935188
Previously Sg?ngqifted in Encl 1

From: Fein. Ashden CPT USA SJA

sent: Wednesday, August 03. 2011 5:14 PM

To:

Cc: Matthew kemkes; Morrow Ill, JoDean. CPT USA JFHQ-NCRIMDW

Overgaaru, Angel M. CPT USA JFHQ-NCRIMDW Ford,
Arthur D. W01 USA JFHQ-NCRIMDW Joshua Tooman
Subject: RE: Expert Request

David,

Acknowledge receipt. Thank you and we will start working this immediately.

v/
Ashden

Defense_UncIass_EmaiI_0702

02216708
30418

From:

Sent: Thursday, August 4, 2011 4:22 PM

To: Ford. Arthur D. W01 USA SJ A
Cc: Morrow oDean, CPT USA SJ A






Fein, Ashden CPT USA
Matthew kemkes

Paul Bouchard Joshua




Tooman
Subject: Discovery

Mr. Ford,

I just wanted to let you know that I received, and was able to open, the unclassi?ed discovery disc 36618-
36802.

Best,
David

David E. Coombs, Esq.

Law Of?ce of David E. Coombs
11 South Angeli Street, #317
Providence, RI 02906

Office: 1-800-588-4156

Fax: (508) 689-9282



rtialdefense.com

Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_UncIass_Email_0703

02196796
30419

From: Ford. Arthur 0. W01 USA SJA

Sent: Thursday. August 04. 2011 4:28 PM

To:

Cc: Momow Ill, JoDean. CPT USA Fein, Ashden CPT USA JFHQ-

Matthew kemkes; Paul Bouchard; Joshua Tooman

Subject: RE: Discovery (UNCLASSIFIED)

Bin

Classification: UNCLASSIFIED

Caveats: FOUO

Sir,

Thanks very much.



Arthur Ford
wo1, JA
Legal Adninistrator

Comm:
BB:



Defense_U nclass_EmaiI_0704

30420

Faun:
Sent:
To:
cc:

suhkun:


David and Paul,

Fein, Ashden CPT USA SJA

Thursday. August 04. 2011 4:37 PM

?Paul Bouchard?;

Fotd. Arthur D. W01 USA JFHQ-NCRIMDW Morr an. JFHQ-
Eric Lakes

RE: Message and update from CPT Bouchard (UNCLASSIFIED)
puntmseuaformkesxbx

As you know, we received a list of items and software that Mr. Lakes
contends are required for his to effectively assist you (see attached

spreadsheet).

He looked at these requirements, and vetted them through our

expert to determine what software we can provide free of cost. Can you
please send us a written request, with justification, that we can use to
obtain approval from the CA For the expenditures, as none of this was

discussed in your expert witness requests.

v/
Ashden

Defense__Undass__EmaiI_0705

Thank you.

02982337
30421

From: Fein, Ashden CPT USA SJA

Sent: Thursday. August 04. 2011 4:37 PM

To: ?Paul Bouchanf;

Cc: Ford. Arthur D. W01 USA JFHQ-NCRIMDW Morrow JoDean. CPT USA JFHQ-

?Eric Lakes?
Subject: RE: Message and update from CPT Bouchard (UNCLASSIFIED)
Attachments: purchase list for Iakes.xlsx

David and Paul,

As you know, we received a list of items and software that Mr. Lakes
contends are required for him to effectively assist you (see attached
spreadsheet). we looked at these requirements, and vetted then through our
expert to determine what software we can provide free of cost. can you
please send us a written request, with justification, that we can use to
obtain approval from the CA for the expenditures, as none of this was
discussed in your expert witness requests. Thank you.

v/r
Ashden

Defense_Unclass_Emai|_0706

30422


Thursday, August 4, 20| I 4:43 PM

Fein, Ashden CPT USA SJA

Ford, Arthur D. WOI USA SJA



[Suspected RE: Message and update from CPT Bouchard (UNCLASSIFIED)

Ashden,

Paul will submit a separate request, with justification, for the listed items in excel spreadsheet. Let us
know if the government has any issues with the request once you receive it.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Of?ce: 1-800-588-4156

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain confidential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Dafense_Unclass_Email_0707

02949126
30423

From: Fein, Ashden CPT USA SJA

Sent: Thursday. August 04. 2011 5:06 PM

To:

Cc: Ford, Arthur D. W01 USA Monow JoDean, CPT USA JFHQ-



Subject: e: A E: Message and update from CPT Bouchard (UNCLASSIFIED)
Thanks.

Defense_U nc|ass_Emai|_0708

02216696

From:
Sent:
To:

Cc:

Subject:

30424

Paul Bouchard

Thursday, August 4, 201 1 6:26 PM

Fein, Ashden CPT USA SJA


Ford, Arthur D. W01 USA SJA

Morrow JoDean. CPT USA JFHQ-
En'c Lakes

Re: Message and update from CPT Bouchard (UNCLASSIFIED)










Roger. Thanks. I'll get on it.

Paul

Defense_UncIass_EmaiI_O709

021 96784
30425

From: Ford. Anhur 0. W01 USA SJA
Sent: Thursday, August 04. 2011 7:25 PM

To: 'Tooman, Joshua CPT MIL US USA
Cc: Fein. Ashden CPT USA SJA
Subject: RE: Manning Discover Issues (UNCLASSIFIED)
??onodlBy: I

Classification: UNCLASSIFIED
Caveats: FOUO

Sir,

I'm looking at our files, and your request is confusing. our files
are bates stamped by file, and 21152 falls into the middle of a file. can
you please re-confirm the numbers of the actual files you cannot open?
Also, not all of the files were so you should be able to open
some of them.

The discs I sent out have the numbers of the first and last file on
the disc. Is this the disc that you have? Thanks.



Arthur Ford

901, JA

Legal Administrator
com:

88:

Defense_Unc|ass_EmaiI_071 0

02941405

30426
From: Fein, Ashden CPT USA SJA
sent: Fn'day, August 05, 2011 7:24 AM
To: MATTHEW KEMKES
I
Cc: Morrow JoDean, CPT USA Ford, Anhur D. W01 USA JFHQ-
NcRnuovvsuA
subject: Conespondences between us and Defense
Gents,

Could you please ask all members of the defense to include me on all their
emails to individual members of the prosecution, even administrative emails.
I know most (on both sides) are not used to having to deal with so many
people on different issues, but I would like to ensure we maintain proper C2
and redundancy, so that all the defense requests and issues may be
adequately and efficiently resolved.

All members of the prosecution will include me on their emails as well.
Thank you.

v/
Ashden

Defense_Unclass_EmaiI_071 1

30427

Tooman. Joshua on MIL us USA nmpoc

Saturday, August 6, 20] I 7:29 AM
To: Fond. Arthur D. WOI USA SJA

Cc: Fein, Ashden cp-r USA sm


Subject: Re: Manning Discover Issues (UNCLASSIFIED)



Mr. Ford

luas unable to open the disc labeled (12934-2| I52) and the ?les contained therein. Speci?cally. I know I was unable to open the
?les containing pages 013 I62 thxough 013781 and pages 019893 through 020I52. I can get you a complete list on Tuesday.

Thanks and sorry for the confusion.
Tooman

Defense_Unc|ass_Emai|_0712

02216686

30428

From: Paul Bouchard

Sent: Saturday, August 6, 2011 9:44 AM

To: Fein, Ashden CPT USA

Cc:

Subject: Defense Request for hardware and software

Attach: Request for hardware and so?warepdf; Renewed Expert Request, PDF.pdf; Request for
Expert Assistant for PFC Manning.pdf; Hardware and software for US v.


Ashden,

Per our discussions, the Defense will need certain hardware equipment and software for Cyber Agents, Inc. to
do its job. We're requesting that the Government provide these items -- see attachments.

Call or e-mail me if you have any questions.

Thanks,

Paul

Defense__Unclass_Emai|_0713

,eji,j_

02938121
Previously Sgmgigted in Encl 1


From: Fein, Ashden CPT USA SJA

Sent: Saturday, August 06, 2011 7:33 PM

To: Paul Bouchard

cc: Ford, Arthur D. W01 USA JFHQ-NCRIMDW

Overgaard, Angel M. CPT USA JFHQ-NCRIMDW SJA
Subject: RE: Defense Request for hardware and software
Paul,

Thank you. we will review these requests this weekend and get back to you
by Tuesday on any issues, such as the request should be for the since
he owns the case and not the GCMCA.

In order not to have any unnecessary delay, please provide us, ASAP,
whatever research you have that shows the convening authority can appoint a
Corporation/Company as an expert assistant (along with all its employees)
vice only appointing individuals within the Corporation/Company. we have not
-Found a case on point.

Have a good weekend.

v/r
Ashden

Defense__U nclass_EmaiI_0714

02216685
30430

mm: Paul Bouchardj

Sent: Saturday, August 6, 20] I 9:06 PM

To: Fein, Ashden cm USA sm
Subject: Re: Defense Request for hardware and so?ware

()kay.

"Thank

Paul

Defense_Unclass_Emaii_0715

02216683

Previously in Encl 1

From: vauuawcnudm

Sent: Sunday, August 7, 20] 1 IO: 14 PM

To: Fein, Ashden CPT USA SJA

Cc:

Subject: Re: Defense Request for hardware and software

Ashden:

Do you really need legal precedent cited in order to appoint Cyber Agents, Inc. and its employees? Reason I ask
is, is there any prohibition requesting a corporation as a defense expert assi stant? The Government contracts
with companies all the time. .

Not trying to be a pain for you; just want to know.

Please advise. I'm sure we'll work it out.

Thanks,

Paul

Defense_Unclass_EmaiI_o716



we do need some legal precedent to accomplish this request. I absolutely
agree that corporations and companies are billed For expert assistance
witnesses; however we did not find any case law that supports the
proposition that an entire corporation and all its employees can be
appointed to the defense team as expert assistants. we consider the
prohibition to exist in the plain language of the rule, which identifies a
person and their qualifications and not a corporation.

we are still reviewing the request to ensure all the requirements are met,
specifically the fee schedule is clearly outlined.

v/r
Ashden



02938164
Previously in Encl 1


From: Fein. Ashden CPT USA SJA

Sent: Sunday, August 07, 2011 10:30 PM

To: ?Paul Bouchanf

Cc: Ovengaard. Angel M. CPT USA JFHQ-NCRIMDW

SJA
Subject RE: Defense Request for hardware and software
Paul,

02216680

Previously S?igmigted in Encl 1

From Paul B?uchar

Sent: Monday, August 8, 2011 7:37 AM

To: Fein. Ashden CPT USA SJA

Cc:

Subject: Re: Defense Request for hardware and software

Ashden:

What if I just submit a separate expert request for the appointment of Trent Struttmann as an additional defense
expert?

l'rn sure that the government has had multiple computer forensic experts at CC IU working on this case. Given
the amount of infonnation (8 terabytes) and the scope of work, the defense will need the services of an
additional representative from Cyber Agents. This additional expert is needed in order to perform the review
required in this case. and to avoid any unnecessarily delays due to the amount of infonnation required
to be reviewed.

Please let me know.

Thanks,

Paul



02938160

Previously in Encl 1

From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA

Sent: Monday. August 08. 2011 7:43 AM

To: ?Paul Bouchard'

Cc: Ford, Anhur D. W01 USA JFHQ-NCRIMDW

Overgaard, Angel M. CPT USA JFHQ-NCRIMDW SJA
Subject: RE: Defense Request for hardware and software
Paul,

At this point, we have no objection to multiple expert assistants to further
assist Eric Lakes and anyone else the defense requests. The only issue is
whether the convening authority has the power/authority to appoint a
company/corporation vice individual employees. we are already working an
additional appointment of Trent 5 along with a reappointment of Eric L.

By the end of today, I will provide you an email with a list of the other
information we will either need or recommend changed before we take the
request to the

v/r
Ashden

Defense_Unc|ass_Emai|_071 9

30435





Paul B?uchard?

Monday, August 8, 201 1 8:29 AM

Fein. Ashden CPT USA SJA
Ford, Arthur D. W01 USA
SJA Overgaard, Angel M. CPT USA IF HQ-

NC

Re: Defense Request for hardware and software





Defense_Unclass_Emai|_072O

02938143

30436
I
From: Fein, Ashden CPT USA SJA
Sent: Tuesday, August 09, 2011 3:15 AM
To: Paul Bouchard; 'Bouchard, Paul CPT MIL USA
cc: Ford, Arthur D. W01 USA JFHQ-NCRIMDW
Overgaard, Angel M. CPT USA JFHQ-NCRIMDW SJA
Subject: RE: Defense Request for hardware and software
Paul,

Please see below. If you can send this today we will get it to the
convening authority in the next 48 hours.

1. The request should be "to" the Garrison Commander (COL Coffman), not to
the C6. The currently owns the case.

2. The subject states that the request is for additional funding, but the
request is also to appoint a new defense expert and reappoint Mr. Lakes.

3. Please name the requested experts IAN RCM 703(d). The request does not
request a specific expert; it requests a corporation and its employees.

4. The request needs to layout the EXACT fee schedule and other expenses.
Currently, the request says that defense needs in additionally
[sic] funding to evaluate the data? and ?The possibility of additionally
[sic] funding at the rate of $175 per hour for further computer analysis if
need be.? It is unclear whether the $2400 is for estimated work which would
be billed at $175/hour or just an additional flat rate. Please provide a
concise billing rate and then an estimate of what the initial of days will
cost. He will be able to take this amount to the convening authority and
argue that initial cost to be approved. Additionally, without a concise and
clear billing schedule, we will not be able to get a contract setup through
Contracting.

V/r
Ashden

Defense_Unc|ass_Emai|_0721



02216673



Previously in Encl 1

From: Paul Bouchard?
Sent: Tuesday, August 9, 2011 8:59 AM
To: Fein, Ashden cm? USA

Bouchard. Paul CPT MIL USA OSA
Cc: Ford, Arthur D. W01 USA

SJA Overizaard. Angel M. CPT USA JFHO-

SJA
Subject: Re: Defense Request for hardware and software
CPT Fein:

It was good talking to you over the phone. I will get this to you today -- will con?rm with Eric Lakes.

As we discussed. better we start from scratch and forget that more than a year ago. Eric Lakes was approved for
$5,600.00. Given the volume of data involved in the case. Eric then asked for more money and also the help of
one of his employees. Bottom line: Best we start from scratch, especially given that it's a new convening
authority as compared to July of last year.

Again, I'll have this product to you today.


CPT Bouchard

Defense_Unclass_Emai|_0722

0221 6669
30438

From:

Sent: Tuesday, August 9, 20H 9; IO AM

To: Fein, Ashden CPT USA SJA
Cc: Ford, Arthur D. WOI USA SJA

Ovetgaaxd, Angel M. CPT USA JFHQ-
Paul Bouchard




Subject: [Suspected RE: Defense Request for hardware and software

Ashden,
Any update on the request for Dr. Grieger? Thanks.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282




Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or Company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disdosure, copying or use of this
information may be unlawful and is



02216665
30439

From: Paul Bouchardj

Sent: Tuesday. August 9, 20l I 1 1:43 AM
To: Fein. Ashden CPT USA SJA
?wow
Cc:
Subject: Re: Defense Request for hardware and software



The attachment is our new request. I haven't signed it yet -- would like you to see it First.

Pretty simple -- we're asking for Eric and Trent, they bill at $l 75.00 per hour per person; they estimate the work
to take ?ve days at a cost of $l4,000.00 excluding travel costs.

I have COL Co?man as the Is that the correct spelling of his name?? Do I need to have his first
name?

Let me know what you think. Once ?nalized, I'll sign and send the final version to you.

Thanks.
Paul

Defense_Unclass_Emai|_0724



0221 7083

30440

From Eric Lake-s?

Sent: Tuesday. August 9, 20] 1 1 :48 AM

To: ?Paul Fein. Ashden CPT us?.

SJA

Cc:

Subject: RE: Defense Request for hardware and so?ware

Attach: Eric Lakes CCE.vcf

No attachment in this email but:

Don't forget the non-transferrable software and the hard drives previously discussed



616 Pasadena Drive
Lexhmon, KY 40503


Defense_Unclass_EmaiI_0725

02938139

30441

From: Fein, Ashden CPT USA SJA
Sent: Tuesday, August 09, 2011 12:23 PM

To: Paul Bouchand;

cc:
Subject: RE: Defense Request for hardware and software

No attachments .

Defense_Unclass_Emai|_0726

029491 35

30442

From:
Sent:
To:
Cc:

Subject:

David,

Fein, Ashden CPT USA JFHQ-NCRIMDW SJA

Tuesday, August 09, 2011 12:34 PM



Fold. Arthur D. W01 USA JFHQ-NCRIMDW Overgaald, Angel M. CPT USA JFHQ-
NCRIMDW Paul Bouchand; Bouchand,PauI CPT MIL USA OSA

RE: [Suspected RE: Defense Request for hardware and software

we are working this request along with CyberAgents. My intent is to present
both to the convening authority. Last time we used Dr. Moore because you found
him. Have you explored any other options -For experts other than Dr. Grieger?

Thanks.

v/
Ashden

Defense_Unc|ass_Ernai|_0727

02216656
30443

From: Paul Bouchard

Sent: Tuesday, August 9, 201] 1:05 PM

To: Fein. Ashden CPT USA SJA



Cc:

Subject: Re: Defense Request for hardware and so?ware

Attach: Request for Computer Expert Assistant, US v. Manning,

Ashden et al. Sorry about forgetting to attach the document. Here it is.
Paul

Defense_UncIass_EmaiI_0728

02216650
Previously gitbmitted in Encl 1

From:

Sent: Tuesday, August 9, 2011 1:31 PM

To: Fein. Ashden CPT USA SJA
Cc: Ford, Arthur D. W01 USA SJA

Overgaard, Angel M. CPT USA JFHQ-



Subject: RE: [Suspected RE: Defense Request for hardware and so?ware

Ashden,

Yes, I explored other options with Dr. Jehie. My preference was to find someone in the Leavenworth area
that could more easily work with him and BM. However, there was no one available.

As mentioned in the expert request, the main concern of the defense is that any expert is responsive and
has adequate time to devote to the case. Given our track record so far with government employees, it
seems that the better course is to find someone that is being paid for his time (versus adding to his daily
duties). My guess is that an expert who charges by the hour will not cite other work con?icts as a reason
to disengage.

Best,
David

David E. Coombs, Esq.

Law Of?ce of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282




Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_Unclass_EmaiI_0729

02949013

From:
Sent:
To:
Cc:

Subject:

Thank you.

Defense_U nclass_EmaiI_0730

30445

Fein, Ashden CPT USA JFHQ-NCRIMDW SJA

Tuesday, August 09, 2011 1:58 PM



Ford, Arthur 0. W01 USA JFHQ-NCRIMDW Overgaard, Angel M. CPT USA JFHQ-
NCRIMDW Matthew kemkes; Bouchard,PauI CPT MIL USA USA

RE: [Suspected RE: Defense Request for hardware and so?ware

02938123
30446

From: Fein. Ashden CPT USA SJA

sent: Tuesday, August 09, 2011 2:34 PM

To: 'PaulBouchanf;

Cc: Overgaard, Angel M. CPT USA

SJA
Subject: RE: Defense Request for hatdware and software
Paul,

Overal1- no issues. some recommendations:

Changing THRU to Trial Counsel and not SJA. Also, in reference to paragraph
3c, we (counsel for the United States) recommend this COA and you seem to
support it along with your experts, this decision is ultimately up to the
convening authority. we are going to make this recommendation to the
convening authority along with providing him guidance from an IA expert.

Once you send a signed copy, we should be good to go.
Thanks.

Ashden

Defense_Unclass_Emai|_0731

30447



From: Fain, Ashden CPT USA SJA

Sent: Tuesday, August 09, 2011 3:19 PM
To:
Cc: Matthew kemkes; Motrow Ill, JoDean, CPT USA JFHQ-NCRIMDW

Overgaard, Angel M. CPT USA JFHQ-NCRIMDW Fond,
Anhur D. W01 USA JFHQ-NCRIMDW 'Josnua Tooman?

subject: Discovery Update (US v. PFC BM)

David,

we sent you and MA) Kemkes the Following today in discovery (BATES 036803):

Quantico Brig Recordings

Your tracking number: 7010 1060 0001 1272 6268

wt-
Ashden

Defense_Unclass_EmaiI_0732



02982674

30448

From:
Sent:
To:
Cc:

Subject:

David,

Fein, Ashden CPT USA SJA

Tuesday, August 09, 2011 3:19 PM



Matthew kemkes; Momow Ill, JoDean, CPT USA

Overgaand, Angel M. CPT USA JFHQ-NCRIMDW Ford,

Arthur D. W01 USA JFHQ-NCRIMDW ?Joshua Tooman'

Discovery Update (US v. PFC BM)

we sent you and MAJ Kemkes the following today in discovery (BATES 036803):

Quantico Brig Recordings

Your tracking number: 7010 1060 0001 1272 6268

v/r
Ashden

Defense_Unclass_EmaiI_0733

02933549

30449

From:
Sent
To:
Subject:

Commander, U.S. Army Garrison, Joint Base Myer - Henderson Hall, 264 Lee

Fein, Ashden CPT USA JFHQ-NCRIMDW SJA
Tuesday, August 09, 2011 3:25 PM

Paul Bouchard



Avenue, Fort Myer, VA 22211-1199

Defense_U nc|ass_EmaiI_O734

02216647
30450

From: Tooman. Joshua CPT MIL US USA TRADOC

sent: Tuesday, August 09. 2011 4:28 PM

To: Ford. Anhur D. W01 USA SJA

Cc: Fein, Ashden CPT USA SJA

Subject: RE: Manni Discover Issues (UNCLASSIFIED)
sum-av=

Classification: UNCLASSIFIED
Caveats: FOUO

Mr. Ford

I am unable to open the following files, all of which are what is labeled as
?Disc

012934-012934
012935-013161
013162-013661
013662-014161
914162-014661
014662-015161
015162-015661
015662-016161
016162-016661
016662-017161
917162-017661
017662-018161
018162-019661
019662-020152

Each attempt to open one of these files was met with the following error:
digital ID was used to this document but no digital ID is present to
it. Make sure your digital ID is properly installed or contact the

document author.?

Do you have any thoughts on what the hang up may be?

Thanks,
CPT Tooman

Defense_U nclass_EmaiI_0735

02196628
30451



From: Ford. Arthur D. W01 USA SJA

sent: Tuesday, August 09, 2011 4:39 PM

To: 'Tooman, Joshua CPT MIL US USA

Cc: Fein. Ashden CPT USA SJA

Subject: RE: Manni Discover Issues (UNCLASSIFIED)
s-an-?av:

Classification: UNCLASSIFIED
Caveats: FOUO

Sir,

The problem is with Those documents are with
your CAC certificate. we have them with the certificate that
you sent with your latest emails, and re-sent them to you yesterday. Please
let lle know if you receive their. Thanks, Sir.



Arthur Ford

wo1, JA

Legal Administrator
Com:

BB:

Defense_Unclass_EmaiI_0736



30452

From:
Sent:

To:

Cc:
Subject:
Signed By:

Tooman. Joshua CPT MIL US USA TRADOC

Tuesday, August 09. 2011 4:41 PM

Ford, Arthur D. W01 USA SJA
Fein, Ashden CPT USA JFHQ-NCRIMDW SJA
RE: Manning Discover Issues (UNCLASSIFIED)

Classification: UNCLASSIFIED

Caveats: FOUO
Excellent.

V/r
CPT Tooman

Defense_UncIass_EmaiI_0737

Thanks for your help!

02216638
30453

From: Paul Bouchard

Sent: Tuesday, August 9, 2011 5:35 PM

To: Fein, Ashden USA sm
Cc:



Subject: Defen se request for Computer Forensics Experts
Attach: Request for Eric and Trent,

Ashden:

The attachment is our request for Eric and Trent.

Thanks,

Paul

Defense_U nc|ass_EmaiI_0738

02196612
30454

From: Ford, Anhur D. W01 USA SJA
Sent: Wednesday, August 10, 2011 10:40 AM
To: David Coombs



Matthew kemkes; paul. bouchard

Cc: Fain. Ashden CPT USA Morrow JoDean, CPT USA JFHQ-
SJA
Subject: Protective order for 10SW576 (UNCLASSIFIED)
Attachments: 1 0SW576.pdf
Signed By:

Classification: UNCLASSIFIED
Caveats: FOUO

Everyone,

Attached is the disclosure and protective order for search warrant 105N576.
Please print, sign each page, and scan and send back to me. Thank you very much.



Arthur Ford

H31, JA

Legal Administrator
com:
-

Defense_Unclass_EmaiI_0739

02216633
30455

From:

Sent: Wednesday, August 10, 201 I I 1248 AM

To: Ford. Arthur D. W01 USA SJA
Cc: Fein, Ashden CPT USA SJA

Morrow JoDean, CPT USA IF SJA

Matthew
kemkes

Subject: RE: Protective order for IOSWS76 (UNCLASSIFIED)
Attach: I IOSWS76 Protective Orderpdf
Mr. Ford,

Here is the requested protective order.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

rm i .

Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the Intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_Unc|ass_EmaiI__0740

02216628

30456

T02

Cc:

Subject:
Attachments:
Signed By:

Tooman. Joshua CPT MIL US USA TRADOC

Wednesday, August 10, 2011 3:28 PM

Ford, Arthur D. W01 USA
Matthew kemkes; Santiago, Melissa CW2 RES USA:
Purcell. Cherise SSG RES USA

Fain. Ashden CPT USA Morrow JoDean. CPT USA JFHQ-
Ncummnovv SJA

RE: Protective omer for 10sW576 (UNCLASSIFIED)

Seamh_Warrant_PO.pdf

Classification: UNCLASSIFIED

Caveats: FOUO

Mr. Ford

The requested protective order is attached.

Thanks,
CPT Toonah

Defense_Unclass_Email_O741

02216627

30457

From: Paul aouchard
Sent: Thursday, August 20]] 9:23 AM

To: Fein. Ashden CPT USA SJA
Subject: Message from CPT Paul Bouchard

Ashden:

Keep me in the loop vis-a-vis Eric and Trents' acceptance and security clearances, hardware and so?ware, and
protective orders.

Thanks.

Best.

Paul

Defense_Unclass_EmaiI_0742

02196568
30458

From: Ford, Arthur D. W01 USA SJA

Sent: Thursday, August I I. 201 I 11:46 AM
To: A Fein,_Ashden CPT USA SJA





Subject: Re: Protective order for IOSWS76 (UNCLASSIFIED)

Sir.
Message mceived. I don't see any reason for them to sign the po. Thanks.



W01 Anlnr Ford
Legal Administrator



Defense_UncIass_EmaiI_0743

02216625

30459
From: Tooman, Joshua CPT MIL us USA TRADOC
sent: Thursday, August 11. 2011 6:29 PM
To: Ford, Arthur D. W01 USA SJA
Cc: Fein, Ashden CPT USA SJA
Subject: Disc Received (UNCLASSIFIED)
??gned|By:
Follow Up Flag: Follow up
Flag Status: Completed

Classification: UNCLASSIFIED
Caveats: FOUO

Mr. Ford

I received the disc that you sent and was able to open the files without
issue. Thank you. Just as a heads up, a number of files were on the
original disc, but NOT on the disc that you sent this week. As such, I do
not have functioning copies of the following files:

912934-912934
012935-913161
014162-014661
014662-015161
015162-015661
015662-016161
016162-016661
616662-017161
817162-017661
017662-018161
018162-019661

v/r
CPT Tooman

CPT Joshua J. Tooman

Defense Counsel

U.S. Army Trial Defense Service
415 Custer Avenue

Fort Leavenworth, Kansas 66627

Phone:
Fax:
DSN

This e-mail message and any attachments may contain privileged
attorney-client and/or work-product information or other information
protected from release under FOIA. If you have received this e-mail in
error, please notify the sender. Do not copy or forward this e-mail without
the permission of the sender.



Classification: UNCLASSIFIED
Caveats: FOUO

Defense_UncIass_EmaiI_0744

02196520
30460

From: Ford, Arthur o. W01 USA SJ

Sent: Thursday, August 11, 2011 7:26 PM



Cc: I-?ein, Ashden CPT USA
SJA

Subject: Re: Disc Received (UNCLASSIFIED)

Sir.
Thank you for letting me know. I will take care of it as soon as I can.


WOI Anhur Ford
Legal Administrator

Defense_Unclass_Emai|_0745

02914279

Subject:
Attachments:

Importance:

David,

Previously in End 1

Fein, Ashden CPT USA SJA

Thursday. August 11. 2011 10:10 PM



Morrow JoDean. CPT USA

Matthew kemkes; Ford, Annur o. wo1 USA JFHQ-


US v. PFC BM Updates

Appointment or Forensic Computer Expert (ManningB).pdf; 11-Aug-10-
Approval Defense Expert Forensic LCDR Moulton (ManningB).pdf; 11-
Approval for Defense Computer Hardware (ManningB).pdf; 11-Aug-10-
Approved Facility and Storage for Classi?ed Information (ManningB).pdf; 11-Aug-10-
Excludable Delay Memorandum (ManningB).pdf

High

Attached are the following five actions from the



LCDR Moulton may be reached

C611

. Appointment of Forensic Computer Experts

Approval for Defense Computer Hardware

Appointment of Expert Forensic

Approved Facility and Storage of Classified Information
Excludable Delay Memorandum

Additionally, we sent unclassified discovery (BATES: 036804-042806) today
which includes MAJ C1ausen's Adverse Action. (Tracking 8 7010 1060 0001 1272

6275)

v/r
Ashden

Defense_Unc|ass_Emai|_O746

02923025
30452

From: Fain, Ashden CPT USA SJA

Sent: Friday. August 12. 2011 7:09 AM

To: Ford. Arthur D. wo1 USA

Cc:

subject: RE: Protective otder for 1osws7e (UNCLASSIFIED)

I agree with Mr. Ford, with one caveat- if you ever intend to share ANY of
the information with Lakes or Struttmann, then they are required to sign the
protective orders.

Defense_Unclass_EmaiI_0747

02216624
30463

From:
Sent: Friday, August 12, 2011 8:05 AM

To: Fein, Ashden CPT USA SJA

Subject: CA Actions

Ashden,

Can you resend the CA actions that you sent to me last night? when I attempt to open the message, I
recieve an error message. Thanks.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_Unclass__EmaiI_0748

02943996
30464

From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA

Sent: Friday, August 12. 2011 8:07 AM

To:

Subject: Re: CA Actions

I will resend later this morning. I am out of the office but will be back in a little back.

Defense_Unclass_EmaiI_0749

02914266
30465

From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA

Sent: Friday, August 12. 2011 8:36 AM

To:

Subject: FW: US v. PFC BM Updates

Attachments: 11-Aug-10-Exciudabie Delay Memorandum (ManningB).pdf; 11-Aug-10-Approved Facility
and Storage for Classi?ed Infonnation (ManningB).pdf: Approval for
Defense Computer Hardware (ManningB).pdf; Approval Defense
Expert Forensic LCDR Moulton (ManningB).pdf;
Appointment of Forensic Computer Expert (ManningB).pdf

Importance: High

Resend . Please confirm receipt .

Defense_Unciass_Emai|_0750

02216622
30466

From:

Sent: Friday, August 12. 201 I 9:04 AM

To: Fein, Ashden CPT USA SJA
SubjectUpdates

Thank you.

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282
mm5m
yx.wmat.myc9unmartialdetensemm

Notice: This transmission, including attachments, may contain con?dential attorney-
client infomtation and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure. copying or use of this
information may be unlawful and is

Defense_Unclass_Emai|_O751

02216620

30467

From: Bouchard. Paul CPT MIL USA OSA

Sent: Friday, August 12, 201 10:18 AM

To: Fein, Ashden CPT USA SJA
Cc: Ford, Arthur D. W01 USA SJA



Subject: Re: RE: Protective order for IOSWS76 (UNCLASSIFIED)

Ashden:

Roger.

Thanks

Paul

Defense__Unclass_Email_0752

02949396

30468

From:
Sent:
To:
Cc:

Subject:

Mr. Rains,

For Tr-ent Struttman's clearance, his email is

Thank you.

v/
CPT Fein

Defense_Unc|ass_Email_O753

Fain, Ashden CPT USA SJA

Friday, August 12. 2011 4:51 PM

?Rains. Lany Mr CIV USA DCS

Ford, Arthur 0. W01 USA JFHQ-

NCRIMDW Uondan, Chades Mr CIV USA DCS

RE: (U) RE: (UNCLASSIFIED)



02230973

30469
From: Rains, Larry Mr CIV USA DCS
Sent: Friday, August 12, 2011 5:04 PM
To:
Cc: Fein, Ashden CPT USA JFHQ-NCRIMDW Jordan, Chades Mr CIV USA DCS G-2
Subject: (U) Secunty Clearance
Signed By:

Classification: OFFICIAL USE ONLY
Mr. Struttmann,

I am the Security Manager for ODCS, G-2 and have been asked to submit you
for a Secret level Security Clearance.

To assist me in initiating the investigation, please complete the
information below and return to me at your earliest convenience.

Full Name:

City and State of birth:

work Ph#:

Secondary Ph#: Cell ph)
Primary email:

Secondary email:

The Army G-2 is participating in the Army Investigative Enterprise System
Program which expedites the processing of PSI's (Personnel Security
Investigations) via the PSI Center of Excellence within a few
days, you will receive an email from the PSI-COE with a link to eQip and
instructions for completing the SF-86 online If you have any questions,
please call call center at 416-278-4194 or DSN 298-4194.

P.S. You must have your fingerprints taken and submitted electronically to
0PM within 30

days. Sooner, the better. You can have fingerprints taken at the Pentagon
if this location is accessible for you. Please call 763-697-9327 to
schedule.

Best regards,
Larry

Larry Rains

Security Manager/SSR
HQDA, OOCS, G-2

1666 Army Pentagon
Washington DC 20316-1666
Comm:
Fax:



Classification: OFFICIAL USE ONLY

Defense_Unclass__Emai|_0754

02949330
30470

From: Fein, Ashden CPT USA SJA

sent: Friday. August 12. 2011 5:SJA

subject: FW: (U) Security Clearance

Gents. FYSA.

Defense_Unc|ass_Emai|_0755

02919529
30471

From: Fain, Ashden CPT USA SJA

sent: Saturday. August 13. 2011 6:20 PM

To:

Cc: coom armycourlmama ense.com?; Ford. Arthur D. W01 USA JFHQ-NCRIMDW SJA
Subject: Struttmann's Clearance

Paul,

Trent S. has an investigation request open. He should have received
instructions that direct him to input his SF86 information into through
the OPH website. once he conpletes that, signs the document, and sends in
his fingerprints, we should be able to process everything VERY quickly.
Please let us know when those steps are completed so we can move quickly on
our end. Thanks and have a good weekend.

v/
Ashden

Defense_Unclass_EmaiI_0756

02216618

30472

Bouchard, Paul CPT MIL USA OSA

From:

Sent: Sunday, August 14, 20] 1 5:47 PM

To: Fein, Ashden CPT USA sm
Cc: coomb armycourtmartialdefensecom; Ford, Arthur D. W01 USA

SJA
Subject: Re: FW: (U) Security Clearance
Trent:

Please read below and follow instructions. This is for your security clearance.
Looking forward to working with you and Eric.

Best.
Paul

Defense_UncIass_Email_O757

02216617
30473

From: Bouchard, Paul CPT MIL USA OSA

Sent: Sunday, August 14, 201 1 5:49 PM

To: Fein. Ashden CPT USA SJA
Cc: Ford, Arthur D. W01 USA

3?

Subject: Re: Struttmann's Clearance
Tmm:
Please mad below and

Many ?anks


Paul

Defense_Unclass_Emai|_0758

%uj

02230946
30474

From: PSIP Center of Excellence
Sent: Monday, August 15, 2011

To=

Cc: Fein, Ashden CPT USA SJA



Subject: Applicant Action Required, Investigation Application Instructions, PSIP Record Number

Attach: eQlP User Instructions YOU MUST READ ME.pdf; Section_2l_Guidance.pdf

Mr. TRENT GREGORY STRUTTMANN:

The Personnel Security Investigation Center of Excellence has received a request to begin processing your
investigation application. The attachment provides detailed instructions to assist you with completing this process. It is
highly recommended that you read these instructions before you begin completing the form.

Once you have completed the form, you must release it to the for review. If the form contains errors or
is missing required information, it will be retumed to you via email for correction. Please ensure that you are monitoring
your email throughout this process.

The following must be received within ?ve (5) calendar days.

forms

Signed Signature Release Pages

Fingerprints

306 and/or Resume (when required)

To get started:
1. Access the form at:

To initially access the form you must authenticate your identity. When Question 2 asks for your city of birth use

the following spelling:

2. Contact your local security of?ce or hiring of?cia] to make anangements to be fmgerprinted.

AR 380-67 states that "failure to respond within the time limit prescribed by the requesting organization with the
required security forms or refusal to provide or permit access to the relevant information required by this regulation shall
result in termination of the individual's security investigation or assignment to sensitive duties utilizing the procedures of

paragraph 8-201 or further administrative processing of investigative requirement." Failure to meet this suspense will
result in noti?cation to your chain of command.

If you no longer require a background investigation or you cannot comply with these instructions, please have your
security manager or hiring of?eial contact the

If you have any questions, please call email us a
The call center is open between ours 0 an onday throug y. .
Documen tion re uired for this investigation request may be faxed to

Please do not respond to this email, as responses are not monitored.

PSIP Record Number:
Email Code: PSIP-0002-FP

Defense_Unc|ass_EmaiI_0759

02946330

30475

From:

To:

sutajoctz
Attachments:

FYSA .

Defense_UncIass__EmaiI_0760

Fein, Ashden CPT USA SJA
Mondav. Auaust 15. 2011 9:10 AM

ur . Q-NCRIMDW SJA

FW: Applicant Action Required, Investigation Application PSIP Record Number
CLR0000001573T7

User Instructions YOU MUST READ ME.pdf; Section_21_Guidanoe.pdf

02216616
Previously Sgmgigted in Encl 1

From:
Sent: Monday, August 15, 2011 1:50 PM

To: Fein, Ashden CPT USA SJA

Ford, Arthur D. USA SJ A




Cc: Matthew kemkes Paul Bouchard
Jos ua Tooman
Subject: Dr. Moulton
Ashden,

Who does Dr. Moulton need to coordinate with in order to obtain travel orders? I believe that MDW should
be providing the funding for his TDY. If this is not correct, can you point us in the right direction?
Thanks.

Best,
David

David E. Coombs, Esq.

Law Of?ce of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282
mm



Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure. Qopying or use of this
information may be unlawful and is

Defense_Unclass_Email_0761

02936023
Previously in Encl 1

From: Fein. Ashden CPT USA JFHQ-NCRIMDW SJA

Sent: Monday, August 15, 2011 1:53 PM

To: Ford. Atthur D. W01 USA JFHQ-NCRIMDW SJA
cc: Matthew kemkes; ?Paul Bouchard?; ?Joshua Tooman'

Subject: RE: Dr. Moulton

David,

we will figure out the process immediately. Please have Dr. Moulton send us
his DTS POC so we can coordinate the exchanges.


Ashden

Defense_Unc|ass_Emai|_0762

30478



From:
Sent: Monday, August 15, 2011 6:39 PM
To: Ford. Arthur D. WOI USA SJA

Cc: I-?ein, Ashden CPT USA SJA
Morrow JoDeanSubject: [Suspected Discovery

Mr. Ford,

Yester, I was received three discs labled 036803 - 036803 and opened each without incident. Today, I
received the single disc labled 036804 through 042806, but cannot access any of the documents.

when I load the disc, it reads the various ?les (this takes around two minutes to do as compared to
previous discs that only took seconds). After being able to see the contents, I then attempt to open one
of the ?les. The ?le takes a long time to upload (around ?ve minutes). After uploading, I am

then prompted for the password. Once I enter the password, the ?le starts to download to my computer.
Unfortunately, after about ten minutes, it just stops in the middle of the download (?les on previous discs
would download in a matter of seconds).

I have tried the disc on two separate computers. The ?rst, is a computer that I have never had any
problems opening previous discs. The second, is a speed demon that also could not open the
?les. Have you done something different with this CD as opposed to previous ones? If not, I will need to
have a new CD sent to me.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282
?aMmm.co.m


Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is prohibit .

Defense_Unclass_Emai|_0763

30479

Fain. Ashden CPT USA SJA: Morrow JoDean. CPT USA JFHQ-
Matthew kemkes;



02196465

From: Ford, Arthur D. W01 USA SJA
Sent: Tuesday. August 16, 2011 8:17 AM

To:

Cc:

I

Subject: isoovety (UNCLASSIFIED)
I

Classification: UNCLASSIFIED

Caveats: FOU0

Sir,

Thank you very much For letting me know.
to you today, and try to Figure out why you couldn't open it.

MAJ Kenkes,

Here you able to open your discs?

Thanks.



Arthur Ford

H01, JA

Legal Administrator
Conn:

BB:

Defense_Unclass_Email_0764



I will get a new disc in the mail

02216612
30480





From:

Sent: Wednesday, August 17, 20] 12:35 PM

To: Fein, Ashden CPT USA SJA
Cc: Matthew kemkes






Joshua Tooman
Arthur D. W01 USA SJA

Subject: [Suspected RE: Dr. Moulton

Ashden,
The DTS POC for Dr Moulton is Margarita Lopez. She is cc?d on this message.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282




Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_Unclass_Email_0765

A

Faun:
Sent:
To:
Cc:

subject:

Ms. Rodriguez,

30481

Fain, Ashden CPT USA SJA

Wednesday, August 17. 2011 12:36 PM



Matthew kemkes; Pau1 Bouchatd; Joshua Tooman; Ford, Anhur 0. W01 USA JFHQ-
NCRIMDW Pan'a. Jairo A. W01 USA JFHQ-


RE: Dr. Moulton

Please send the X-org and other information that we need to add or. Moulton
onto our LOA to N01 Parra (CCed). Thank you.

v/r
CPT Fein

Defense_Unclass_EmaiI_0766

30482



From: Kemkes, Matthew MAJ MIL USA

Sent: Wednesday, August 17, 2011 12:37 PM

To: Fein, Ashden CPT USA SJA
Subject: Out of O?lce AutoReply: Dr. Moulton

Sir/Ma'am,

I am out of the o?lce until 19 August. If you need inmtediate assistance, please contact CPT Michelle Borgnino or Ms. Lisa Bynoe at

Respectfully,
MAJ Kemkes

Defense_UncIass_Email_O767

02216610
30483

mm: Paul soucnaraj

Sent: Wednesday, August 17, 2011 5:27 PM

To: Fein, Ashden CPT USA SJA
Subject: Request from CPT Bouchard

Ashden:

Give me a call when you get a chance. Just want a sitrep. Issues I want to discuss are safe and secured facility.
Thanks,

l?aL?

Defense_Unclass_Emai|_O768





02921270

From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA
Sent: Wednesday. August 17. 2011 6:36 PM

To: Paul Bouchard

Subject: RE: Requesi from CPT Bouchard

Paul,

Lets chat tomorrow, unless you need tonight.

Ashden

Defense_U nc|ass_Email__0769

30484

02216609
30485

From: Paul Bouchard

Sent: Thursday, August 18, 2011 9:43 AM

To: Fein, Ashden CPT USA SJA
Cc:

Subject: Request sitrep from CPT Paul Bouchard

Ashden -- just would like to get a situation report as to where we're at.

1. Trent told me he ?lled out SF 86 and do let me know any status there.

2. Any issues with our software and hardware requests? Will we get these in time for early September, the
target date as to when the Gov't will provide us the classi?ed info?

3. We have a safe at MAJ Kemkes place of work, Fort Myer TDS. Chief Melgar here at Fort Meade infonned
me she's working to get a safe for my office. Will this second safe just be for the classified docs?

4. Where do you think Eric and Trent will do their computer forensics work, and what are your thoughts about
what En?c said regardingthe equipment having to run over night?

5. Do you think we're still on track for 1 September with all of the aforementioned?

Any feedback appreciated.

Thanks, Ashden.

Email me or call me anytime.



Paul

P.S. Still working to get on global e-mail; I'll let you know my new e-mail address once 1 get it.

Defense_Unclass__EmaiI__O770

02196237

30486

From: Ford, Arthur 0. W01 USA SJA

Sont: Thursday. August 18. 2011 9:59 AM

To:

Cc: Fein. Ashden CPT USA Waybright. Daniel W. SGT USA



subject: ?les (UNCLASSIFIED)

?HonodlBy: I

Classification: UNCLASSIFIED

Caveats: FOUO

Mr. Coombs,

In a few moments, you will see an email from me.
test document.
your cac certificates.
can open the file.

very much.



Arthur Ford
ml, JA

Legal Administrator

can-?=
wj

Defense_U nclass_Email_0771

It contains a
All the files that you were not able to open were with
we are trying to figure out why. Could you please advise us if you

Again, you will need your cac card to do so. Thank you

02196235
30487

From: Fond, Arthur D. W01 USA SJA
Sent: Thutsday. August 18, 2011 9:59 AM

To:

Cc: Fein, Ashden CPT USA Waybright, Daniel W. SGT USA JFHQ-



Subject: This Is the file (UNCLASSIFIED)

Iunachnmenms:



Classification: UNCLASSIFIED

Caveats: FOUO



Arthur Ford

hlol, JA

Legal Administrator


ee=

Defense_Unclass_EmaiI_0772



02196233
30488

From: Ford, Anhur 0. W01 USA SJA
sent: Thutsday. August 18. 2011 10:00 AM

To:

cc: Fain, Ashden CPT USA SJA
Subject: file attached (UNCLASSIFIED)


sinned 8v=
Classification: UNCLASSIFIED

Caveats: FOUO

R,

Arthur Ford

501, JA

Legal Administrator


em

Defense_Unc|ass_Emai|_0773



30489



From:
Sent: Thursday, August 18, 2011 AM

To: Foi Arthur D. WOI USA SJA

Cc: Fein, Ashden cm USA SJA

Wavbright. Daniel W. SGT USA SJA




Subject: [Suspected RE: This is the ?le (UNCLASSIFIED)

Mr. Ford,
I opened the attached PDF document without any issues.

Best,
David

David E. Coombs. Esq.
Law Office of David E. Coombs

11 South Angeli Street, #317

Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282




"?**Con?dentiaIity Notice: This transmission, including attachments, may contain con?dential attorney-
ciient information and is intended for the person(s) or company named. If you are not the intended

recipient, please notify the sender and delete all copies. Unauthorized disciosure, copying or use of this
information may be unlawful and is

Defense_Unclass_Emai|_0774

02921251
30490

From: Fein, Ashden CPT USA SJA

sent: Thutsday. August 18. 2011 11:49 AM

To:

cc: armyoounmema ense.oom; Mormw Ill, JoDean, CPT USA

Fotd, Arthur D. W01 USA SJA

subject: RE: Request sitrep from CPT Paul Bouchard

r?gh

Paul,

Thanks. Sorry I could not call last night. Below are my updates:

1. we should be on track. Did Trent send in his fingerprints and
signature card or electronic signature?

2. No issues with the purchasing. Pursuant to the order dated
10 Aug 11, we are working the purchase request and will have all the
material in our office. we will then coordinate through you to get the
software to your experts prior to them arriving so they can have their
computers ready to go. As a warning, we will likely need them to sign a
document that this software is only to be used for the sole purpose of this
case and no other purpose based on much of it being from an Army enterprise
license.

3. The United States will provide a safe at the Fort Meade TDS office,
pursuant to the directive in his 10 Aug 11 order.

4. Similar order, the forensic work
will be conducted at the Fort Meade TDS office. If your experts need to run
their computers overnight, then I assume your security experts will let you
know that the office/machines must be supervised/monitored the entire time
(positive control) because of the classified nature of the information.
Please let us know if you need assistance with this given the defense team's
security and administrative staff.

5. The goal is still 1 Sep 11; however I owe you, David, and the rest

of the team a hard date for planning purposes. In determining this date, we
are considering the award of the contract for CyberAgents, final acquisition
of all materials needed for the forensic team, and travel planning for the
defense for the handover and multi-day explanation. we intend to propose a
date NLT Monday CO8.

v/r
Ashden

Defense_UncIass_Emai|_0775

30491

ammo, Paul MIL us?. OSA

Thursday, August 18, 2011 1:37 PM

To: Fein. Ashden CPT USA SJA



Cc: Morrow JoDean, CPT USA JFHQ-
SJA ;Ford, Arthur D. W01 USA


Subject: Re: RE: Request sitrep from CPT Paul Bouchard

Thanks. Ashden

?lcon?nnthis

Paul



02216542
30492

From:

Sent: Friday, August 19, 2011 4:00 PM

To: Fein, Ashden CPT USA SJA
Cc: Ford, Arthur D. W01 USA SJA

Matthew



05 U3 00111811



Subject: Protective Orders
Attach: Dr. Iehle 2.pdf; Dr. Jehlepdf; Dr. Greypdf; Dr. Moulton.pdf
Ashden,

Please see the attached signed protective orders. These protective orders are for members of the defense
team. Although none are defense counsel or an "associate, paralegal, or clerical employee involved in the
defense of the accused? each is either detailed to or retained by the defense to assist on this case. It is
my understanding, that a separate approval for members of the defense team would not be required. Do
you concur with this belief, or does the matter need to be raised with COL Coffman?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282




Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Dei'ense_Unciass_Email_0777



02922870

30493

To:

Subject:

David,

I do not understand what you are asking.

YOU.

v/r
Ashden

Defanse_Undas_EmaiI_0778

Fain. Ashdon CPT USA JFHQ-NCRIMDW SJA

Friday. August 19. 2011 5:20 PM



Ford. Anhur 0. W01 USA Matthew
kemkos; Joshua Tooman; Overgaam. Angel M. CPT USA Monow
CPT USA SJA

RE: Protective Orders

Could you please clarify? Thank



02216541

30494

From: Tooman, Joshua CPT MIL US USA TRADOC

Sent: Friday, August 19, 2011 5:28 PM
To: Fein, Ashden CPT USA SJA
Subject: Out of O?ice AutoReply: Protective Orders

I am currently TDY at Fort Bliss. TX and have limited email access. I will return Monday, 29 August. If you need immediate
assistance please call - Thank you.

Defense_Unclass_Email_0779

02216539

From:
Sent:
To:
Cc:

Subject:

Previously in Encl 1


Friday, August 20] I 5:46 PM

Fein, Ashden CPT USA SJA

Ford, Arthur D. WOI USA SJ A

Joshua Tooman
ergaar Ang . PT JA
Morrow JoDean. CPT USA IF HQ-

Re: Protective Orders



COL Co??rmn's order does not seem to include disclosure to defense experts. I am assuming that this is an oversight. and that the
defense can share materials with its experts provided the protective orders are signed.

David

Sent from my Verizon Wireless

Defense_Unc|ass_EmaiI_0780

02195854

30496

From: Parra. Jairo A. W01 USA SJA
Sent: Friday. August 19, 2011 6:44 PM
To:
cc: Fain, Ashden CPT USA atthew kemkes; ?Paul uchard'; ?Joshua

Tooman?; Fond, Arthur D. W01 USA SJA

subject: RE: Dr. Moulton (UNCLASSIFIED)
SngnedIBy:

Classification: UNCLASSIFIED
Caveats: FOU0

Ms . Rodriguez,

I received an e-mail (please read below) that identifies you as the POC for Dr. Houlton
travel arrangements. For your SA, I have not received, as of today, any information that
allows me to create across-org on DTS for Dr. Moulton. It is of the outmost urgency that you
contact me at your earliest convenience to arrange travel arrangements and payment option for
Dr. Moulton. I sincerely appreciate you prompt response and assistance in this matter.

Thank you



JP

Jairo A. Parra
mi, JA

Legal Administrator
JFHQ-NCR, row








- Direct
- Blackberry
- Cell

CAUTION: The information contained in this email and any accompanying attachments may contain
Freedom of Information Act protected information, including attorney-client or attorney work
product privileged information. This information may not be released outside of the
Department of Defense without prior authorization from the Office of The Judge Advocate
General, Department of the Army. If you are not the intended recipient of this information,
any disclosure, copying, distribution, or the taking of any action in reliance on this
information is prohibited. If you received this email in error, please notify this office
immediately by return email (see 5 U.S.C. 552 and Army Regulations 25-55 and 27-2).

Defense_UncIass_EmaiI_0781

02922867
Previously Sggigitted in Encl 1

From: Fain. Ashden CPT USA SJA

sent: Friday. August 19, 2011 8:52 PM

To:

Cc: Ford, Anhur o. wo1 USA Matthew

kemkes; Joshua Tooman; Overgaam, Angel M. CPT USA Morrow
JoDean. CPT USA SJA
subject: RE: Protective Ordels

David,

All those on the defense team, including expert consultants and witnesses are
included under COL Coffman's order. It was intended and briefed to the COL
Coffnan that paragraph 2 sub includes "technical or expert services or
testimony? for the defense. we do understand the remainder of the sentence
states "in the prosecution of the accused" but we considered that statement
more broadly to include the prosecution and defense, since the "prosecution of
the accused? cannot occur without the defense having access to the
information.

v/
Ashden

Defense_U nc|ass_Email_0782

02230945
30498

From: PSIP Center of Excellence



Sent: Sunday, August 21, 2011 6:14 AM
To:
Cc: Fein, Ashden CPT USA SJ A

Subject: Investigation Status Update - Processing, Ticket No. 77

Mr. TRENT GREGORY STRUTTMANN:

The below infonnation is required to continue processing your background investigation. You were noti?ed via
email of the requirement to complete the online electronic fonn for this investigation. As a reminder, the link to
the fonn is:

In order to continue processing your background investigation, please submit the following information to the


Required Documentation:

FLNGERPRINTS REQUIRED:

Fingerprint cards- Contact your local security office or hiring official to facilitate

AR 380-67 states that "failure to respond within the time limit prescribed by the requesting organization with
the required security forms or refusal to provide or permit access to the relevant information required by this
regulation shall result in termination of the individual's security investigation or assignment to sensitive duties
utilizing the procedures of paragraph 8-20] or further administrative processing of investigative requirement."

If you no longer require a background investigation or you cannot comply with these please
have your security manager contact the PSI

If you have any questions, please call or email us at


The call center is open between the hours of 0600 and 2400 Monday through Friday. All times are
EST.



'nvestigation request may be faxed to
Your prompt attention to this matter will be greatly appreciated.

Please do not respond to this email, as responses are not monitored

Record Number: 573 77
Email Code: PSIP-0003

Defense_Unclass_Emai|_0783

029294 1 2

30499

From:
Sent:
To:
Cc:

subject:

Fein. Ashden CPT USA SJA
Sunday. August 21, 2011 8:54 AM


ur . 1 HQ-NCRIMDW Morrow JoDean. CPT USA JFHQ-

Fw. investigation status Update - Processing. Ticket No. CLR000000157377

Paul. Please see below. Trent needs to send in his fingerprint card or he will not be granted
a clearance. Please let me know when this occurs so we can continue moving on this issue.

Thanks.

Vr ashden

Defense_U nclass_EmaiI_0784

02216537

30500

Bouchand. Paul CPT MIL USA OSA




From:

Sent: Sunday. August 21, 20! I I104 AM

To: Fein, Ashden CPT USA SJA

Cc: Ford, Arthur D. W01 USA
SJA Morrow Jobmn, CPT USA JFHQ-
SJA

Subject: Re: Fw: Investigation Status Update - Processing, Ticket No. 57377

Trent:

Please read below and conply -- we need this to happen asap for your security clearance.



Defense_Unclass_EmaiI_0785

02230943
30501
From: PSIP Center of Excellence
Sent: Monday, August 22, 2011 10:33 AM

To: Fein, Ashden CPT USA SJA

Cc=

Subject: Informational, Security Clearance Processing, Ticket No. CLR0000001573 77

The Army Investigative Enterprise System (AIES) PSI Center of Excellence (PSI has received all of the
required documentation from TRENT GREGORY STRUTTMANN. At this time, no further action is required.
The investigative packet has been submitted to 0PM for scheduling.

If you have any questions, please contact the PSI

If you have any questions, please call 410-278-4194 or DSN 298-4194 or email us at
imneapgesi5@conus.army.mil.

The call center is open between the hours of 0600 and 2400 Monday through Friday. All times are
EST.

Documentation required for this investigation request may be faxed to
410-306-3858 or DSN 458-3858 or scanned and e-mailed to imneapgesi@conus.army.mil.

Please do not respond to this email, as responses are not monitored.

PSIP Record Number:
Email Code: PSIP-0006

Defense_Unc1ass_EmaiI_0786



02216534
30502

From: Bouchard, Paul CPT MIL USA OSA

Sent: Monday, August 22, 2011 lO:34 AM

To: Fein, Ashden CPT USA SJA



Cc:
Subject: Trent's ?ngerprints (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED

Ashden:
Please read below. I received tlis e-mail from Trent this rmming.

Let me know if you have any questions.
Thanks

Paul
Cent?

Paul.
I contacted the person who took my prims and she said everything wen though just fine. Sh: said that the c-mail we received was a
standard c-mail scri to all a icarls and that we should ignore that because the prints have been submitted mine is Nicki Clarke



Respectfully.






Cyber Inc.
6l6 Pasadcm Dr
Lexington. KY
O?ioez

Mobile:
On08/2 1/1 I. ?Fem Ashden CPT USA



Defense_Unclass_EmaiI_0787

02914746

30503
From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA
Sam: Monday. August 22, 2011 7:07 PM
To:
Cc: Matthew kemkes; Jmhua Tooman; Ford, Arthur D. W01 USA
JFHQ-NCRIMDW ergaa . USA JFHQ-NCRIMDW Morrow Ill,
JoDean. CPT USA SJA
Subject: US v. PFC BM Discovery, etc.
David,
Good evening. Below is an update on discovery and other issues:

1. A CD containing the Clausen files (036804-042866) was sent to you
(7010-1960-0001-1272-6282) and Kenkes should have received his copy
today or will tomorrow.

2. Last week, I emailed Paul that we should have an answer by C08 today
on when we expect to have the classified forensic evidence ready for you and
your team. For multiple reasons, we will not be able to provide an answer
today. I hope to be able to provide an answer by the end of this week to
allw you and your experts adequate time to plan for travel.

3. Trent Struttmann's clearance is being expeditiously processed. All
of his information appears to be received.

4. Contracting has received the CyberAgents contract and is working to
award the sole-source contract so we can ensure their payments are
preapproved prior to their arrival.

S. we are working on finalizing the acquisition of the defense forensic
computer equipment and software. Our intent is to acquire all the material
and then send it to your experts (once officially retained by Contracting)
so they can preload the software and be ready to go.

6. we are working on finalizing Dr. Mou1ton's travel arrangements (DTS)
so he can freely travel to

v/r
Ashden

Defense_Unclass_Email_0788


02216533

30504




From: Bouchard. Paul MIL us?. OSA
Sent: Tuesday. August 23, 20] I 8:05 AM
To: Fein, Ashden CPT USA SJA
Cc: Matthew kemkes
??Shu8
An ur . I SJA
Overgaard, Angel M. CPT USA IFHQ-
Morrow JoDean, CPT
USA JFHQ-NC

Subject: Re: US v. PFC BM Discovery, etc.
Thanks, Aslxien.
FYI - I have to teach a class at amp LeJeune. NC on Thursday. I will have e-mail capabilities and cell phone.

Paul

Def9nse_UncIass_EmaiI_0789

02230929
30505

From: Rains, Larty Mr USA DCS (3-2
Sent: Tuesday, August 23, 2011 4:39 PM

TO: I

Cc: Fein, Ashden CPT USA SJA

Subject: (U) Non-Disclosure Agreement

Attachments: SF 312 - STRUTTMAN.

Signed By:

Classification: OFFICIAL USE ONLY
Trent,

Please print, read, and sign in Front of a witness. Have witness complete
"witness" block. Then please scan and send back to me.

After I receive the SF-312, I will grant you an interim Secret clearance and
post the information in JPAS. Thanks.

Best regards,
Larry

Larry Rains

Security Manager/SSR
HQDA, ODCS, 6-2

1999 Army Pentagon
Washington DC 29319-1999
Comm:

Fax:

Classification: OFFICIAL USE ONLY

Defense_U nclass_Email_0790





30506

From:

Sent:

To:

cc:

Subject:
Attachments:

Pau1- FYSA.

Defense_Unciass_Email_0791

Fein, Ashden CPT USA SJA
Tuesday, August 23. 2011 5:17 PM

armycou 1a efense.oom; Ford. Arthur 0. W01 USA SJA
FW: (U) Non-Disclosure Agreement
SF 312 -

30507

Fein, Ashden CPT USA JFHQ-NCRIMDW SJA
Tuesday, August 23. 2011 5:17 PM

coom armycourtmama fense.oom; Ford. Arthur D. W01 USA JFHQ-NCRIMDW SJA
FW: (U) Non-Disclosure Agreement
SF 312 -

Pau1- FYSA.

Defense_Unc|ass_Emai|_0792

02216529

30508

From: Bouchard, Paul CPT MIL USA OSA
Sent: Wednesday, August 24, 2011 8:48 AM
SJA

Cc: coombs@armycourtm arti al defensecom;
Subject: Fwd: FW: (U) Non?Disclosure Agreement

Attach: (U) Non-Disclosure

Trent,

Please read the following e-mail from Mr. Rains and comply. Do cc me as well.


Paul

Trent, from Mr. Larry Rains:

Please prim, read, and sign in front of a witness. Have witness complete
"Witness" block. 'I'hen please scan and send back to me.

A?er I receive the SF-312, I will grant you an interim Secret clearance and
post the information in JPAS. Thanks.

Best regards,

Lam?

Lar'ryRajns

Security Manager/SSR
HQDA, ODCS, G-2
1000 Army Pentagon

Washi 11 DC 20310-1000
Comm:
Fax:





Defense_Unclass__Emai|_0793

02230927
30509

From: Reins, Larry Mr CIV USA DCS G-
Sent: Wednesday, August 24, 2011 9:02 A

To: Bouchard. Paul CPT MIL USA OSA
Cc:
Fein, Ashden CPT USA
subject: RE: FW: (U) Non-Disclosure Agreement


Classification: OFFICIAL USE ONLY

I received the SF-312 from Trent this morning. He has been granted an
Interim Secret clearance.

Best regards,
Larry

Defense_Unclass_EmaiI_0794

02216528
30510

From: Bouchard, Paul CPT MIL USA OSA

Sent: Wednesday, August 24, 2011 11:54 AM

To: Rains, Larry Mr CIV USA DCS G-

Cc: Fein,
Ashden CPT USA SJA -

Subject: RE: FW: (U) Non-Disclosure Agreement (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Thank you, sir.

Respectfully,

CPT Paul Bouchard

Defense Coimsel

Fort Meade. Marvland

Of?ce:

On 08/24/11, "Rains, Larry Mr CIV USA DCS ?wrote:

Classi?cation: OFFICIAL USE ONLY



I received the SF-312 from Trent this morning. He has been granted an
Interim Secret clearance.



Best regards,

Lany







From: Bouchard, Paul CPT M11. USA OSA
Sent: Wednesday, August 24, 2011 8:48 AM

To



c: coom _,armycourtmart1a ensecom; Rains, Lam? Mr CIV USA DCS G-2
Subject: Fwd: W: (U) Non-Disclosure Agreement



Trent,



Please read the following e-mail from Mr. Rains and comply. Do cc me as

well.



Paul



from Mr. Larry Rains:



Please print, read, and sign in front of a Have witness complete

"Witness" block. Then please scan and send back to me.



After 1 receive the SF-312, I will grant you an interim Secret clearance and

post the information in IPAS. Thanks.



Best regards,

Larry



Larry Rains

Security Manager/SSR

HQDA, ODCS, G-2

l0()0 Army Pentagon

Washington DC 20310-1000

Comm:

Fax:





Classification: OFFICIAL USE ONLY

Classi?cation: UNCLASSIFIED



Defense_Unciass_Emai1_O795

02942771
Previously Sggr?qed in Encl 1


From: Fein, Ashden CPT USA SJA
Sent: Wednesday, August 24, 2011 12:51 PM
To: Matthew kemkes
Cc: Morrow JoDean, CPT USA JFHQ-NCRIMDW
Boston, Louis J. MAJ USA JFHQ-NCRIMDW Chandler, Rodrick D. CW4 USA
JFHQ-NCRIMDW SJA
Subject: Classi?ed Computers
MAJ Kemkes,

we are still working on getting three computers to be used by the defense to
view, store, and handle classified information, above the resourcing
requirements for the forensic computer expert consultants. As you know,
there are special rules for the defense handling and using classified
information, and the prosecution team is best suited to ensure all rules are
followed and to ensure you have equal access to evidence. Therefore, the
main office kicked this resourcing issue over to the prosecution team and we
are directly working the issue to ensure that you have adequate systems in
place to use the classified information you are provided in discovery.

we will have final resolution on which computers will be signed over to the
defense prior to the disclosure of any classified information and with
adequate time to prepare your offices to receive the equipment and
subsequent information.

If you have any questions about this support, please let me know.

Thank you.

v/r
Ashden

Defense_Unc|ass__Emai|_O796

02916317 Previously Submitted in End 78
Previously in Encl 1

From: Fein, Ashden CPT USA SJA
Sent: Thursday. August 25. 2011 9:54 PM
To: Coffman, Can COL MIL USA
cc: Matthew kemkes; Tooman, Joshua CPT MIL US

USA Morrow m, JoDean, CPT USA JFHQ-

SJA: Overuaard. Angel M. USA SJA: Ford. Arthur 0.

W01 USA JFHQ-NCRIMDW SJA
Subject: US v. PFC BM (Art 32 Delay Request)
Attachments: 11-Aug-25-Govemment Request to Delay Article 32 (ManningB).pdf
hnponanco: r?gh
Sir,

The United States requests an additional delay of the Article 32.

Please

see the attached request.

v/r
CPT Fein

Defense_Unclass_EmaiI_0797



02216527
30513

From: Pau1Bouchardj>

Sent: Friday, August 26, 2011 11:23 AM
To: Matthew kemkes


Cc: Fein, Ashden CPT USA SJA

Subject: New e-mail address for CPT Paul Bouchard

All:

My Outlook Email is now up and running. That e-mail address is
send me stu?? on my AKO and Yahoo e-mail addresses.



CPT Paul Bouchard

Defense_Unclass_Email_0798

Previously Submitted in Encl 78








02217270
Previously in Encl 1
From=
Sent: Saturday, August 27, 20H 6:31 AM
To: Fein, Ashden CPT USA SJA
Cc: Matthew kemkes
Tooman, Joshua] PT MIL US USA
TRADOC Morrow Ill,
JoDean, CPT USA FHQ-NC SJ A
Overgaard. Angel M. CPT USA IF SJA
?Ford Arthur D. W01 USA JFHQ-
SJA
Subject: Re: US v. PFC BM (Art 32 Delay Request)
Mr. Coornbs

Do you have any issues or additiom?

COL Coffman

Sent Via BlackBeny by

Defense_Unclass_Emai|_0799

02216525 Previously Submitted in Encl 78
Previously in Encl 1








From:

Sent: Saturday, August 27, 20l I 7:5] PM

To:

Cc: Matthew kemkes Tooman,.loshua PT MIL US
USA TRADOC Morrow

HI, .loDean. CPT USA SJ A

Overgaard, Angel M. CPT USA FHQ-
Ford, Arthur D. WOI
USA SJ A Fein, Ashden CPT

USA SJA
Subject: [Suspected RE: US v. PFC BM (Art 32 Delay Request)

Sir,
The Defense maintains its previous position that any additional delay should not be excluded under R.C.M.

707(c). Instead, the requested delay should be credited to the Government for speedy trial purposes
under Article 10 of the Uniform Code of Military Justice.


David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all oopies. Unauthorized disclosure, oopying or use of this
information may be unlawful and is

Defense_Unclass_Email_0800

30516





From: Fein. Ashden CPT USA SJA

sent: Monday, August 29, 2011 7:27 AM

To:

cc: Morrow Iii, JoDean. CPT USA SJA

Subject: RE: [Suspected RE: US v. PFC BM (Art 32 Delay Request)
David,

Are you available to have a phone meeting this week? I would like to give you
an update and answer any questions you might have.

Thanks.

v/r?
Ashden

Defense_Unc|ass_Email_0B01

From:
Sent:
To:
Cc:

subject:

Attachments:

Paul,



Fain, Ashden CPT USA SJA
Monday. August 29. 2011 9:14 AM
I
ord, Arthur . 1 Morrow Ill, Jooean, CPT USA JFHQ-

SJA

Chatne Sheets

10-Jul-O5-Otioinal Charge Sheet DISMISSED REDACTED (MannihgB).pd1; 11-Mar-01-
Additional Charge Sheet REDACTED (ManningB).pdf; 11-Mar-08 Additional Charges
REDACTED (ManningB).pdf

Attached is the original charge sheet (dimissed), the additional charge
sheet which is now the charge sheet, and the transmittal.

v/r
Ashden

Defense_Unc|ass_Emai|_0802

0221 6522

30518

From:

Sent: Monday, August 29, 201 1 9:19 AM

To: Fein, Ashden CPT USA SJA
Cc: Morrow IH, .loDean, CPT USA SJA

Subject: RE: [Suspected RE: US v. PFC BM (Art 32 Delay Request)

Ashden.

How does tomorrow a?:ernoon work for you? I am available anytime a?er 1300.

Best,
David

David E. Coombs, Esq.

Law Of?ce of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attorney-
client infomiation and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, oopying or use of this
information may be unlawful and is

Defense_UncIass__Emai|_0803

30519

Fein, Ashden CPT USA SJA
Monday, August 29. 2011 9:20 AM

Mornow Ill, JoDean. CPI USA JFHQ-NCRIMDW SJA: Ford. Arthur D. W01 USA JFHQ-

NCRIMDW SJA

Charge sheets

10-Jul-O5-Original Charge Sheet DISMISSED REDACTED (ManningB).pdf; 11-Mar-01-
Additional Charge Sheet REDACTED (ManningB).pdf; 11-Mar-O8 Additional Charges
Transmittal REDACTED (ManningB).pdf

Paul,

Attached is the original charge sheet (dimissed), the additional charge
sheet which is now the charge sheet, and the transmittal.

v/r
Ashden

Defense_Undass_EmaiI_0804



02948994

30520

From:
Sent:
To:

Cc:
Subject:

David,

Fein, Ashden CPT USA SJA

Monday, August 29. 2011 9:20 AM


Morrow JoDean, CPT USA JFHQ-NCRIMDW SJA

RE: [Suspected RE: US v. PFC BM (Art 32 Delay Request)

Thank you. How 15 1708?

v/
Ashden

Defense_Unc|ass_Emai|_0805

02216518
30521

From:

Sent: Monday. August 29, 201 9:23 AM

To: Fein, Ashden CPT USA sm
Cc: Morrow JoDean, CPT USA SJA

Subject: RE: [Suspected REDelay Request)

Ashden,

1700 works for me.

W.

David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attorney-
ciient information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, mpying or use of this
information may be unlawful and is

Defense_Unc|ass_Emai|_0806





ozmawes
30522

From: Fein, Asnden CPT USA SJA

8cm: Monday. August 29. 2011 9:24 AM

To: Paul Bouchard; Matthew kemkes;

I
Cc:
Subjoct: RE: New e-mail address for CPT Paul Bouchard

Paul - this email address does not work, nor does the

Defense_Unc|ass_EmaiI_0807

02216517
30523

From: Paul Bouchard

Sent: Monday, August 29, 20] I 9:32 AM
To: Fein, Ashden CPT USA SJA
Subject: Re: New e-mail address for CPT Paul Bouchard





Ashden:

That's my new e-mail
Can you send me the updated charge sheet at


Paul

but I guess there's some connectivity issue.

Defense_Unclass_Emai|_O808

02943252



30524

Defense_U nclass_EmaiI_0809

Fein. Ashden CPT USA SJA
Monday, August 29, 2011 9:37 AM

Morrow JoDean, CPT USA Ford. Anhur D. W01 USA JFHQ-
SJA

FW: Chatne sheets

10-Jul-05-Otioinal Charge Sheet DISMISSED REDACTED (ManningB).pdf; 11-Mar-01-
Additional Charge Sheet REDACTED (ManningB).pdf; 11-Mar-O8 Additional Charges
Transmittal REDACTED (ManningB).pdf

02216516
30525

From:
Sent: Monday, August 29, 2011 2:45 PM
To: Ford, Arthur D. W01 USA SJA

Fein, Ashden CPT USA SJA





Cc: Matthew kemkes

Joshua Tooman
Subject: CD
Mr. Ford,

My of?ce has received the unclassi?ed discovery disc 036804-042806. I was able to download and open
the contents of the disc.

Best,
David

David E. Coombs, Esq.

Law Of?ce of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

I

i I .

Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_Unciass_Emai|_0810

02216512
30526

From:

Sent: Monday, August 29, 20] I 3:0] PM

To: Fein, Ashden CPT USA SJA
Subject: RE: [Suspected RE: US v. PFC BM (Art 32 Delay Request)

Ashden,

I need to reschedule our call. I just received news that a close family member passed away unexpectedly.

I am leaving tomorrow to participate in the funeral arrangements. I do not anticipate returning to the
of?oe this week. If there is something important for us to discuss, I can make time to talk to you tonight.
Otherwise, lets talk sometime early next week.

David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282
mymumanialdefem.com


Notice: This transmission, including attachments, may contain confidential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_Unclass_Email_081 1

02948990
30527

From: Fain, Ashden CPT USA SJA

Sent: Monday, August 29, 2011 3:02 PM

To:

Subject: RE: [Suspected RE: US v. PFC BM (Art 32 Delay Request)
David,

I am sorry to hear. I wanted to give you an update, but nothing is that
pressing. Lets talk next week. I hope to have a proposed set of days -For us
to get together and handover the classified information.

v/
Ashden

Defense_Unclass_EmaiI_081 2



02924567

30528

From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA
Sent: Monday, August 29, 2011 3:18 PM
To:
Cc: Matthew kemkes; Monow Ill, JoDean, CPT USA JFHQ-NCRIMDW Ford, Arthur D.
W01 USA JFHQ-NCRIMDW SJA
Subject: one note
David,

One thing I was planning on doing during our phone call tomorrow was to give
you a heads up, that your client has been on formal attachment orders to
FIJH, and now we plan on having him to the new in the next two weeks.
His physical location will not change, but his per-sonnel actions will move
to the MDH.

Thanks.


Ashden

Defense_Unclass_EmaiI_081 3

30529

Importance:

Defense-

Fein, Ashden CPT USA SJA

Monday, August 29, 2011 3:39 PM

Matthew kemkes; Tooman, Joshua CPT MIL US
USA TRADOC

Pane. Jairo A. A
SJA

Dr. Moulton Travel/LOA

A: Chandler, Rodrick D. CW4 USA JFHQ-

High

Please read below and let all your experts and others know For future

travel . Thank you.

v/r
CPT Fein

Defense_Unclass_Emai|_0814





Defense_Unclass_EmaiI_0815

02914759 Previousiy Submitted in End 79
Previously Sgtagtgged in End 1

From: Fein, Ashden CPT USA SJA

Sent: Monday. August 29. 2011 7:29 PM

To: 'AImanza. Paul?

cc: Matthew kemkes; Morrow Jooean. CPT USA

JFHQ-NCRIMDW 'Habenand,Jol1n CPT MIL
Overuaard. Anoel M. CPT USA JFHQ-NCRIMDW Food, Arthur D. W01 USA JFHQ-
SJA: ?Joshua Tooman'

Subject: US v. PFC BM Atticle 32 Delay

Attachments: Delay of Article 32 Investigation (ManningB).pdf

lmponanoe: High

LTC Alnanza,

Good evening. Please find attached an Article 32 delay approval signed by the



Thank you.

v/r

CPT Fein

Ashden Fein

CPT, JA





02219486 Previously Submitted in End 79
30531

mm: ?umam Pam A

Sent: Tuesday, August 30, 20! I 12:59 PM

To: Fein, Ashden CPT USA SJA
Cc: Matthew kemkes

Morrow JoDean, CPT USA
ergaa Angel
Ford,
Arthur D. W01 USA SJA
Joshua Tooman

Subject: RE: US v. PFC BM Article 32 Delay

Thank you. Fein.

Almanm

Defense_Unclass_EmaiI_0816



02216511

30532

From: Paul Bouchard

Sent: Wednesday, August 31, 2011 9:17 AM

To: Fein, Ashden CPT USA SJA
Cc:


Subject: Message from CPT Paul Bouchard

Ashden - FYI:

Eric and Trent have informed me that September 10-20 would work well for them to do the computer forensics.
(They have a case at Fort Bragg slated to end around Sept. 8; they could then drive up here and do the computer
forensics for US v. Manning). Do you think this can work?

We do have the Safe for classi?ed data next to my office. When do you think you'll provide us with the
classi?ed data and our software and hardware requests? Also, where (what facility) will they do the actual
computer forensics work?

Thanks,
Paul

Defense_Unclass_Emai|_O81 7

02928353
Previously Sglaggjged in Encl 1

From: Fein, Ashden CPT USA SJA

Sent: Wednesday, August 31, 2011 9:21 AM

To: Paul Bouchani

cc:
Ford, Arthur 0. W01 USA JFHQ-NCRIMDW Morrow JoDean, CPT USA JFHQ-
SJA

Subject RE: Message from CPT Paul Bouchand

Paul,

Thank you. That will not likely work for three reasons:

1. we are still working on receiving the final approvals from CIDC on
the release of their reports. we had to first get the underlying approvals
for all the substance evidence and now they are working on the final part.
2. Army contracting is still working on awarding CyberAgents the
contract for expert services. That might not be comleted by that point.
3. The equipment we ordered is on its way and should be here by the
middle of next week. Once we receive it and the contract for CyberAgents is
awarded, we will ship it out to CyberAgents for them to get their computers
ready for work. we plan on offering this to minimize any delay once they
arrive in the area.

As of today, I estimate the last week of September as being the time for us
to have all the authorities to turn over the classified evidence to the
defense. I do not recommend making non-refundable plans for the last week,
but that is our target. I will have better clarity by the middle of next
week.

v/
Ashden

Defense_Unclass_Email_0818



30534

PM Bwchard

Wednesday, August 20! I 9:49 AM

Fein. Ashden CPT USA SJA

coombs@aImycourtmani aIdef?ense.com;


Ford, Arthur D. W01 USA SJA
Morrow .loDean. CPT USA JFHQ-

Subject: Re: Message from CPT Paul Bouchard



Thanks, Ashden.

Paul

Defense_Unclass_Emai|_081 9



0291 8326

30535

From: Fein, Ashden CPT USA SJA
Sent: Wednesday, August 31, 2011 3:00 PM

To: Matthew kemkes

Subject: tomorrow

Sir? will you be around your office at 1266 tomor-row?

Defense_Unc|ass_EmaiI_0820

30536



From: Kemkes, Matthew MAJ MIL usA
Sent: Thursday. September 01. 2011 9:0

To: Fein, Ashden CPT USA SJA
Subject: RE: tomorrow (UNCLASSIFIED)
sinned By:

Classification: UNCLASSIFIED
Caveats: FGJO

I can be here if you need me to be. what's up?

Defense_Unclass_EmaiI_O821



02918316
30537

From: Fein. Ashden CPT USA JFHQ-NCRIMDW SJA
Sent: Thursday, September 01, 2011 9:44 AM

To: Kemkes, Matthew MAJ MIL USA

subject: RE: tomomow (UNCLASSIFIED)

I thought we would have classified information to tur-n-over and I was going
to bring the CD and the computer. But it won't happen today. Likely very
early next week- not -Forensic info but docs from an organization.

Defense_Unc|ass_Emai|_0822

30538



From: Fain, Ashden CPT USA SJA

Sent: Thursday. September 01. 2011 11:13 AM

To:

cc: Kemkes, Matthew MAJ MIL USA: ?iI; ?Joshua Tooman'; Morrow
JoDean, CPT USA Ford. Arthur D. W01 USA
SJA

Subject: US v. PFC BM (Discovery Update)

David,

we placed a DVD in the mail today containing unclassified discovery (BATES:
642807-044864). This DVD includes multiple pretrial confinement documents
from the confinement facilities. A copy is being delivered to MAJ Kemkes
today.

v/
Ashden

Defense_Unc1ass__EmaiI_0823

02981143
30539



From: Fein, Ashden CPT USA SJA

Sent: Thursday, September 01, 2011 11:13 AM

To:

Cc: Matthew kemkes; ?Joshua Tooman'; Morrow Ill, JoDean, CPT

USA Dw ond, Art ur . W01 USA SJA

subject: US v. PFC BM (Discovew Update)

David,

we placed a DVD in the mail today containing unclassified discovery (BATES:
042807-044864). This DVD includes multiple pretrial confinement documents
from the confinement facilities. A copy is being delivered to MAJ Kemkes
today.

v/r
Ashden

Defense_Unclass_Emai|_0824

02216507
30540

From: Tooman, Joshua CPT MIL US USA TRADOC

Sent: Wednesday, September 7, 2011 8:22 AM
To: Fein, Ashden CPT USA SJA
Subject: Out of Of?ce AutoReply: Email Outage

I am currently out of the of?ce. I will return Friday. 9 September. If you need immediate assistance please call Thank
you.

Defense_Unc|ass_Email_0825



02942773

30541

I

From: Fein, Ashden CPT USA SJA

Sent: Thursday. September 08. 2011 11:38 AM

To: Matthew kemkes;

Cc: Monow ill, JoDean, CPT USA Boston. Louis J. MAJ USA JFHQ-

NCRIMDW chandler, Rodrick D. CW4 USA JFHQ-NCRIMDW SJA
Subject: FW: Classi?ed Computers
hnponance: l?gh

Dave and MAJ Kemkes,

In addition to the aclninistrative and logistical support the OSJA is
providing for all matters unclassified, the prosecution (on behalf of the
convening authority) is working to provide the defense team three laptops
that will be ready to start processing classified information (please refer
to the below email, dated 24 Aug 11).

If you need additional classified information systems or other logistical
support for classified information for your case, please provide a written
request to the convening authority with justification, so that we can
process the request and determine if there are additional assets available
and what approvals we must obtain.

Please stress to your entire team that all information and any information
system associated with classified information must go through a formal
request process and not the normal acquisition processes. The prosecution
is ready to assist, once the request is made.
Thank you.

v/r
Ashden

Defense__UncIass_Email_0826

02939009

30542

Fnmn:
Sent:
To:
Cc:

subject:

Paul,

Fein. Ashden CPT USA SJA
Tuesday. September 13, 2011 12:48 PM

coom armycourtmama efenseoom; Morrow Ill. JoDean. CPT USA JFHQ-NCRIMDW
SJA: Ford, Arthur D. W01 USA SJA
Defense Expert Contract

Could you please confirm whether CyberAgents received the contract and is
ready to start providing direct services?

Thank you.

v/
Ashden

Defense_Undass_Emai|_0827

02216506
30543

From: Bouchard. Paul cm MIL USA OSA

Sent: Tuesday, September 13, 201 I 12:59 PM

To: Fein, Ashden CPT USA SJA


Subject: Re: Defense Expett Contract (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Eric/Trent:

Please tcspotd to CPT Fcin's It is my understanding that you received the contract and that you am ready to do the work.
Respectfully.
CPT Bouchatd

Defense_UncIass_EmaiI_0828



02217080
30544

mm: EdcLakese

Sent: Tuesday, September 13, 2011 1:05 PM
To: Bouchard, Paul PT MIL USA OSA Fein, Ashden
CPT USA SJ A
Cm

Subject: Re: Defense Expert Contract (UNCLASSIFIED)

They sent me the contract to sign off on a couple of weeks ago

Eric Lakes

Digital Forensic Examiner

Certi?ed Computer Examiner (CCE)
Certi?ed Homeland Secu rity -

MCSE, MCP, Network Plus,
Cyber Agents, Inc.


616 Pasadena Drive

Lexington, KY 40503

cell -
land me -

Defense_Unclass_EmaiI_0829

02216505
30545

From: Bouchard. Paul MIL USA OSA

Sent: Tuesday, September 13, 20ll 2:53 PM

To: Fein, Ashden CPT USA SJA
Cc:

Subject: Re: Defense Expert Contract, US v. Manning

Ashden:

E-mailed and just got off the phone with Eric Lakes. Yes did receive the contract. Eric filled it out and sent it back to a
Ms. Sherry Camer who I believe is out of Fort Myer. Eric and Trent are ready to do the work.

NOTE: Eric Ins trials from October I and another one on Nov. 13. He told me the last week of September and week of

October would work
Also. I recommend we have another teleconference with line to ensure all is good to go before he and Trent travel here. ie. what

facility will the work be done at. is all the hardware and software we the Deferse requested in order. etc.


Paul



0291 5752

From: Fein. Ashden CPT USA SJA

Sent: Thursday, September 15. 2011 8:59 PM

To:

cc: Matthew kemkes; Tooman,Joshua CPT MIL us USA TRADOC:



30546

Morrow Ill, JoDean, CPT USA JFHQ-NCRIMDW

A JFHQ-NCRIMDW Ford, Arthur D. W01 USA JFHQ-

SJA
subject: us v. PFC BM (Excludab|e Delay and Document Issue)
Attachments: 11-Sep-15-Excludable Delay Memorandum (ManningB).pdf
hnponance: Iimh

David and the Defense Team,
Attached is an accounting of the excludable delay.
-Break-

we have recently learned the page marked BATES 24459 should have been marked
classified by the original source, and we produced this page on an

unclassified disk on 25 July 2011. Please take the following remedial steps

to remove the document from your computer:

1. Destroy the unclassified disk containing the file "Unclassified Discovery
Manning

2. Permanently destroy or delete any paper or digital copy of the document, or
any digital file containing the contents of BATES 24459.

3. Notify Mr. Ford when you have completed 1 2.

we will immediately re-produce the documents in their entirety on a new disc
so that you may maintain them on your unclassified systems, with a redacted
version of the classified document. we will also produce in classified

discovery, an original copy of the document.
Please let me know if you have any questions. Thank you.

v/
Ashden

Defense_Undass_EmaiI_0831



02216504
30547

From: Kemkes, Matthew MAJ MIL us?.

Sent: Thursday, September 15, 2011 8:59 PM

To: Fein, Ashden USA sm
Subject: Out of Office AutoReply: US v. PFC BM (Excludable Delay and Document Issue)
Sir/Ma'am,

I am out of the office until 19 September. If you need immediate assistance, please contact CPT Michelle Borgnino or Ms. Lisa
Bynoe .

Respectfully,

MAJ Kemkes

Defense_Unclass_Emai|__0832



02943203
30548

1
From: Fein, Ashden CPT USA SJA

sent: Thursday. September 15, 2011 9:02 PM

To:

cc: Morrow Ill, JoDean, CPT USA JFHQ-NCRIMDW SJA

Subject: chat

David,

I hope all is well. Are you available tomorrow or early next week to chat?

Thanks.

Ashden

Defense__Unclass_Emai|_0833

02943203

30549

David,

I hope all is well.

Thanks.

Ashden

Defense_Unc|ass_Emai|__O833

Fein. Ashden CPT USA SJA
Thursday, September 15. 2011 9:02 PM


Morrow JoDean, CPT USA JFHQ-NCRIMDW SJA
chat

Are you available tomorrow or early next week to chat?

02216502
30550

From:

Sent: Thursday, September 15, 201 I 10:53 PM

To: Fein. Ashden CPT USA SJA
Cc: Matthew kemkes Tooman..|oshua CPT MIL US








USA TRADOC Morrow

JoDean, CPT USA SJA

Overgaard, Angel M. CPT USA FHQ-
SJA Ford. Arthur D. W01
USA SJA

Subject: [Suspected RE: US v. PFC BM (Excludable Delay and Document Issue)

Ashden,

Are you sure that you mean 24459? This document, 24459, is a CCIU chain of custody document
concerning a Quantico taped conversation.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282



""?"?Con?dentiaIity Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_U nclass_Emai|_0834

i

30551



From:

Sent: Thursday, September IS. 20! I 10:55 PM

To: Fein, Ashden CPT USA SJA
Subject: [Suspected RE: chat

Ashden,

Tomorrow at 1600 works for me. If that time is not good for you, we can shoot for anytime in die
morning on Monday.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended
recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of this
information may be unlawful and is

Defense_UncIass_Email_0835

02949144

30552



From: Fain, Ashden CPT USA SJA
sent: Thursday, September 15, 2011 11:15 PM

To:
Subject: Re: [Suspected RE: chai

David. 1600 works. I H111 double check the bates number tomorrow. The document is a 4137- cid
collection doc, but not an interview.

Defense_U nc|ass_Emai|_0836

02949089

30553

To:
Cc:

Subject:

Imponanoe:

David,

The actual document is BATES 24445.

Fein. Ashden CPT USA SJA

Friday, September 18. 2011 8:02 AM



Matthew kemkes; Tooman.Joshua CPT MIL US USA

Morrow Jooean, CPT USA SJA:

Overgaard. Angel M. CPT USA Fond. Arthur D. W01 USA JFHQ-


RE: [Suspected RE: US v. PFC BM (Excludaue Delay and Document Issue)

High

Please purge your systems of 24445 and

the new CD5 will go out today.

v/r
Ashden

Defense_Unc|ass_Emai|_0837



30554



From:








Sent: Friday, September 16, 20] 1 9:25 AM
To: Fein. Ashden CPT USA SJA
Cc: Matthew kemkes Tooman..loshua CPT MIL US

USA TRADOC
JoDean, CPT USA SJ A

. Overgaard, Angel M. CPT USA FHQ-
SJA Ford, Arthur D. W01
USA SJ A

Subject: RE: [Suspected RE: US v. PFC BM (Excludable Delay and Document Issue)

Ashden,

I have complied with your request.
Best.

David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attorney-
client information and is intended for the person(s) or company named. If you are not the intended I
recipient, please notify the sender and delete all copies. Unauthorized disclosure, oopying or use of this

information may be unlawful and is

Defense_Unclass_Emai|_0838

02948982

30555

From: Fain, Ashden CPT USA JFHQ-NCRIMDW SJA
Sent: Friday. September 16. 2011 9:32 AM
To:

Cc: Matthew kemkes; Tooman,Joshua CPT MIL US USA

Morrow JoDean, CPT USA JFHQ-NCRIMDW

eruaaru. Angel . USA SJA: Ford. Anhut D. W01 USA JFHQ-
SJA

Subject: RE: [Suspeded RE: US v. PFC BM (Excludable Delay and Document Issue)
Thank you .

Defense_Unclass_EmaiI_0839

30556

Tooman. Joshua 1 cm MIL Us USA mmoc

Friday, September 16, 20] 1 AM

Fein. Ashden cm USA sm?



Matthew kemkes
Morrow oDean. CPT USA SJA

Overgaard, Angel M. CPT USA JFHQ-
SJA Ford, Arthur D. W01
USA SJA





Subject: Re: [Suspected RE: US v. PFC BM (Excludable Delay and Document Issue)
Ashden

I have complied with your request.



Josh

Defense_Unclass_Emai|_084O



Previously in Encl 1

From: Fain, Ashden CPT USA SJA

sent: Friday, September 16. 2011 1:59 PM

To:

Cc: Matthew kemkes Tooman.Joshua CPT MIL US USA

Monow JoDean, CPT USA JFHQ-NCRIMDW SJA:
ergaatd. Angel . JFI-IQ-NCRIMDW SJA: Ford. Arthur 0. W01 USA JFHQ-


subject: US v. PFC BM (Excludable Delay and Document Issue)

Attachments: 11-Sep-16-Defense Classi?ed Computer Usage.pdf

Iimm

David and MAJ Kemkes,

Attached is a memorandum outlining the specialized computer equipment we are
providing the defense to review classified information and to provide to the
civilian forensic computer experts to handle classified information. we
intend to deliver the first batch of classified discovery today with the
computer equipment. Please let me know if you have any questions.

v/r
Ashden

Defense_Unclass_Emai|_0841

0291 5743

30558

From: Fein. Ashden CPT USA SJA
sent: Friday, September 16. 2011 3:02 PM
To: Kemkes, Matthew MAJ MIL USA

cc: 'Tooman.Joshua CPT MIL us USA Morrow m.
JoDean, CPT USA JFHQ-NCRIMDW Ovetgaand, ngel . USA HQ-
Ford. Arthur 0. wo1 USA JFHQ-NCRIMDW SJA

Subject: RE: Us v. PFC BM (ExcludabIe Delay and Document Issue)
Importance: High
MAJ Kellkes,

CH2 Santiago informed us that she does not have the combination to the safe;
therefore, we cannot deliver the classified disks today. Please let us know
when you are available so that we can deliver the equipment and first round of
classified information.

Thank you!

v/
Ashden

Defense_UncIass_EmaiI_0842



02923857
30559

From: Fein, Ashden CPT USA SJA
Sent: Friday, September 16, 2011 5:15 PM

To:
Subject: phone call

David,

I am sorry I did not call earlier. we are having network issues. I am
still available today and this weekend. If you want to set a time for
Monday, please let me know- I am available anytime.

Thanks!

Ashden

Defense_Unclass_Emai|_0843

02216495

From:
Sent:
To:
Subject:

30560


Friday, September 16, 2011 5:20 PM

Fein, Ashden CPT USA SJA

Re: phone call

No wotrics. If you can talk now. give me a call. anytime Monday moming works for me.

Best.
David

Sent from my Verizon Wireless BIackBen_v

Defense_Unclass_Emai|_0844

02923856

From: Fein. Ashden CPT USA JFHQ-NCRIMDW SJA
sent: Friday, September 16. 2011 5:22 PM

To:
Subject: Re: phone call

I can chat. will call in 3.

Defense_U nclass_Emai|_0845

30561

02216493

30562

From:

To:
Cc:

Subject:
Signed By:

Kemkes, Matthew MAJ MIL USA
Monday. September 19, 2011 8:50
Fein, Ashden CPT USA SJA
Tooman. Joshua CPT MIL US USA
Morrow Ill, JoDean, CPT USA JFHQ-NCRIMDW SJA:
eruaa . noel . Fom. Arthur D. W01 USA JFHQ-

RE: US v. PFC BM (Excludable Delay and Document Issue) (UNCLASSIFIED)
I

Classification: UNCLASSIFIED

Caveats: FOUO

CPT Fein,

I am back in the office and will be here all day. I have some client
appointuents so I suggest you call before just stopping by.

Respectfully,
MAJ Kenkes

Defense_Unc|ass_Emai|_0846


02915740
30563

From: Fain. Ashden CPT USA SJA

sent: Monday, September 19. 2011 8:54 AM

To: Kemkes, Matthew MAJ MIL USA

Cc: Tooman. Joshua CPT MIL US USA

Mornow Ill, JoDean, CPT USA SJA:
Overnaam. Angel .0 Fold, Arthur D. W01 USA JFHQ-



Subject: RE: US v. PFC BM (Excludable Delay and Document Issue) (UNCLASSIFIED)
Sir,

Thanks. we will call. If possible, I would like to stop by around 10?

Thanks. -

Ashden

Defense_U nc|ass_Emai|_0847

02216490

30564

To:
Cc:

subject:
Signed By:

Kemkes. Matthew MAJ MIL USA

Monday, September 19. 2011 9:02

Fain. Ashden CPT USA JFHQ-NCRIMDW SJA

coom arm courtmatiialdefenseoom; Tooman, Joshua CPT MIL US USA

;AMormw JoDean, CPT USA
ergaa . nge . SJA;Ford.At1hut D. W01 USA JFHQ-

NCRIMDW SJA
RE: US v. PFC BM (Excludable Delay and Document Issue) (UNCIJKSSIFIED)
I

Classification: UNCLASSIFIED

Caveats: FOUO
CPT Fein,
1090 sounds good.

Respectfully,
MAJ Kenkes

Defense_Unc|ass__Emai|_0848



02216489
30565

From: . Bouchard, Paul CPT MIL USA OSA

Sent: Monday. September I9, 20]! 9:05 AM

Lakes
Cc: rem. Ashden cm USA sm

Subject: Please respond to Mr. Lakes? inquiry, computers

Ashden:
Please see e-mail below from Eric Lakes. Will he and Tram be using Govcmmem computers or their own computers??

Paul

Defense_Unclass_EmaiI_0849

02923664
Previously in Encl 1

From: Fein, Ashden CPT USA SJA
Sent: Monday, September 19. 2011 9:41 AM
To: Bouchand. Paul CPT MIL USA Eric Lakes
Cc: Morrow JoDean, CPT USA
Kemkes, Matthew MAJ MIL Ford, Arthur D. W01 USA SJA
Subject: RE: Please respond to Mr. Lakes? inquiry, computers
Paul,

That is incorrect. As we discussed on the phone, we are providing two
harddrives and all the software. The three computers we are providing are
for the defense team to view classified information and process any
information during the process.

v/r
Ashden

-?-?-Original Message?-??-

From: Bouchard, Paul cm MIL usA OSA
Sent: Monday, September 19, 2011 9:85 AM

To: Eric Lakes

Cc: Fein, Ashden CPT USA SJA

Subject: Please respond to Mr. Lakes? inquiry, computers

Ashden:

Please see e-mail below from Eric Lakes. will he and Trent be using
Government computers or their own computers?

Thanks,

Paul

Original Message

From: Eric Lakes

Date: Monday, September 19, 2611 7:45

Subject: RE: US v. PFC BM (Excludable Delay and Document Issue)
To: "'Bouchard, Paul CPT MIL USA

So I am to assume they want us to use their computers now and not
ours is
that correct?





From: Bouchard, Paul CPT MIL USA OSA

mailto

Sent: Sunday, September 18, 2011 11:22 PM

To:

Subject: Fwd: US v. PFC BM (Excludable Delay and Document Issue)


Eric:

Defense_Unclass_Emai|_0850

02923664

Previously in Encl 1



I hope this includes the attachment. If not, 1'11 e-mail it to you
tomorrowmorning.

Paul

Defanr-e_Unclass_Emall_O85O



0291 5736

30568

To:
Cc:

Subject:

Sir,

It looks more like 1039.

Fein, Ashden CPT USA SJA

Monday. sep1ember19. 2011 9:42 AM

Kemkes, Matthew MAJ MIL USA

Tooman, Joshua CPT MIL US USA

Momow Ill, JoDean, CPT USA JFHQ-NCRIMDW SJA:

Overgaam, Angel M. CPT USA Ford, Anhur D. W01 USA JFHQ-
r?:RnwovvsuA.

RE: us v. PFC BM (Excludable Delay and Document Issue) (UNCLASSIFIED)

Also can you have CH2 Santiago and SSG Purcell

there- I have blackberries For them (From SS6 Phillips) and they need to sign

For them.
Thanks!

v/
Ashden

Defense_UncIass_EmaiI_0851

02217078

From:
Sent:
To:

Cc:

Subject:



Previously Su?p?t?ed in Encl 1

Eric Lakes

Monday, September I9, 2011 9:44 AM

Fein, Ashden CPT USA IF SJ A
Bouchard, Paul CPT MIL USA OSA Eric Lakes


Morrow oDea.Matthew kemkes
Ford, Arthur D. W01 USA A


RE: Please respond to Mr. Lakes? inquiry, computers






Ashden if you could send us the Hard Drives and Software to pneload on the hard drives before we come to Ft Meade that
could save a lot of time there and let us get everything after they are installed up to date on their (software) patches etc. .

Eric Lakes

Digital Forensic Examiner

Certi?ed Computer Examiner (CCE)
Certi?ed Homeland Security - Ill

MCSE, MCP, Network Plus,
Cyber Agents, Inc.

616 Pasadena Drive

Lexington, KY 40503

cell -
land in

Defense_Unc|ass_Emai|_0852



Previously in Encl 1

From: Fein, Asnden CPT USA JFHQ-NCRIMDW SJA

Sent: Monday. September 19. 2011 9:52 AM

To: Bouchard, Paul CPT MIL USA OSA

Cc: coom annycounmamaldefenseoom; Mon'ow JoDean, CPT USA JFHQ-NCRIMDW

Matthew kemkes; Ford, Arthur D. W01 USA SJA
subject: RE: Please respond to Mr. Lakes? inquiry. computers
Eric,

we will be delivering the harddrives and software to MAJ Kemkes this

morning.

V/r

Ashden

Defense_UncIass_Email_0853
.

02216486

30571

From:

To:
Cc:

Subject:
Signed By:

Kemkes. Matthew MAJ MIL USA

Monday, September 19. 2011 9:58

Fain, Ashden CPT USA SJA

Tooman, Joshua CPT MIL US USA
Morrow Ill, JoDean, CPT USA
ergaa . nae . JFHQ-NCRIMDW SJA: Fond. Anhur 0. W01 USA JFHQ(Excludable Delay and Document Issue) (UNCLASSIFIED)

I

Classification: UNCLASSIFIED

Caveats: FOU0

Fein,

I have a client coming at 1100 which is why I agreed to 1000.

IF you can

finish what we need to do in 30 minutes then let's knock it out.

CH2 Santiago will be here to sign for the 88s.

Respectfully,
MAJ Kenkes

Defense_UncIass_Email_0854

02216484
30572

From: Bouchard. Paul cm MIL USA OSA

Sent: Monday. September 19, 20] I 9:58 AM

To: Fein. Ashden CPT USA SJA
Subject: Re: Please respond to Mr. Lakes? inquiry, computers

?Hunks.

Paul

Defense_U nclass__EmaiI_0855



02915731

30573

From: Fein, Ashden CPT USA SJA

sent: Monday. September 19, 2011 10:12 AM

To: Kemkes, Matthew MAJ MIL USA

Cc: Tooman. Joshua CPT MIL US USA
Morrow JoDean, CPT USA JFHQ-NCRIMDW
Overgaard. Angel . CPT USA SJA: Ford. Arthur D. W01 USA JFHQ-
SJA

Subject: RE: US v. PFC BM (Excludable Delay and Document Issue) (UNCLASSIFIED)

Sir,

we only need 10 minutes. we are leaving now.

Defense_Unclass_Email_O856

02216481
30574

From: Kemkes, Matthew MAJ MIL USA 8?

Sent: Monday, September 19, 2011 10:1

To: Fein, Ashden CPT USA SJA

Cc: Tooman, Joshua CPT MIL us USA Morrow

JoDean, CPT USA JFHQ-NCRIMDW coorn armycou me la ense.com;
Overgaam. Angel M. CPT USA Fond, Arthur D. W01 USA JFHQ-


Subject: RE: [suspected v. a Delay and Document Issue)

(UNCLASSIFIED)
sinned 8w ?l
Classification: UNCLASSIFIED
Caveats: FOUO
CPT Fein,

we destroyed our digital copy of the file containing BATES 24445. we had no
paper copies to destroy. CPT Bouchard has the actual CD and he will destroy
it and confirm its destruction today.

Respectfully,
MA) Kemkes

Defense_Unc|ass_EmaiI_0857



02216480

From: Bouchard, Paul RCPT MIL USA OSA





Sent: Monday, September 19, 2011 3:43 PM
To: Fein, Ashden CPT USA SJ A
Ford, Arthur D. W01 USA
Cc: Matthew kemkes
Subject: Destruction of disk, US v. Manning (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
CPT Fein, Mister Ford:

have completely destroyed the unclassi?ed disk containing the ?les 24363-24862; I do not have the ?les on my computer.
Please con?rm receipt of this e-mail.

Respectfully,

CPT Paul Bouchard
Defense Counsel

Trial Defense Services
Fort Meade Field Office

2
Classi?cation: UNCLASSIFIED

Defense_Unclass_EmaiI_0858

02216478

30576

From:
Sent
To:
Cc:

Subject:
Attachments:
Signed By:

Kemkes, Matthew MAJ MIL

Tuesday, September 20, 2011 4:52 PM
Fein, Ashden CPT USA SJA
Tooman, Joshua
CPT MIL US USA TRADOC
Courier Cards (UNCLASSIFIED)
Request for Courier Cards.pdf
I

Classification: UNCLASSIFIED

Caveats: FOUO

Fein,

As we discussed yesterday, please find my request for courier cards attached.

Respectfully,

MAJ Matthew J. Kemkes

Senior Defense Counsel, NCR
U.S. Army Trial Defense Service

Fort Myer, Virginia

Office:

Classification: UNCLASSIFIED

Caveats: FOUO

Defense_Unclass_Emai|_0859

02941365

30577

From:
Sent:
To:
Cc:

Subject:

Sir,

Fein, Ashden CPT USA SJA

Wednesday, September 21, 2011 9:48 AM

Kemkes, Matthew MAJ MIL USA

Tooman, Joshua
CPT MIL US USA Morrow Ill, Jo an, - MDW Ford,
Arthur 0. W01 USA SJA

RE: Courier Cards (UNCLASSIFIED)

Acknowledge receipt and we are processing.

v/r
Ashden

Defense_Unclass_Emai|_0860



0291 5873

30578

From: Fein. Ashden CPT USA SJA

Sent: Wednesday, September 21. 2011 11:14 AM

To:

Cc: Matthew kemkes; Tooman,Joshua CPT MIL US USA

Monow Ill, JoDean, CPT USA
Overgaard. Angel M. CPT USA SJA: Fond. Anhur D. W01 USA JFHQ-

subject: US v. PFC BM (Discovery)

David,

On Monday, we delivered two classified CD5 containing and 00024383-60024459
(file containing information we requested be deleted from everyone's computer)
and 00044865-00045361 (portions of military intelligence investigations).
Yesterday, we sent you (tracking: 7010 1060 0001 1274 3999) 06021364-00036617
(majority of CID Case file with redacted classified file) and delivered a copy
to Fort Myer. we also delivered a new copy of 66636618-00042806 because of
CAC certificate errors.

Thank you.

V/r
Ashden

Defense_UncIass_Email_0861



02216476

30579

From:
Sent: Wednesday, September 20l 11:34 AM

To: Fein, Ashden CPT USA SJA

Cc: Matthew kemkes Tooman,Joshua CPT MIL US
USA TRADOC Morrow
Ill, .loDean, CPT - - A

Overgaard, Angel M. CPT USA FHQ-
Ford, Arthur D. W01
Melissa Santiago









USA JFHQ-NC




Subject: BM (Discovery)

Ashden.

Thank you. I just wanted to make sure that I am accurately tracking with what was provided by the
Government. If I understand you correctly, you have provided the following:

a) MAJ Kemkes: Gave him two classi?ed CDs (these CDs represent bates number 044865 to 045301) and
you provided a new CD 0243 83-024459 to account for the document that you requested the defense to destroy.

b) My Of?ce: A CD that is 021364 to 036617. I remember last week we talked about sending one large copy
of everything provided so far to the defense. but this CD is obviously not everything. Why is all of this
information being provided again? Other than the one document that you asked us to destroy, 02445, are all the
other documents identical? ls document 02445 now just a blank document so that the bates numbers for
previously provided documents have not changed? You indicate that you have also sent another CD 0366 8 to
042806. Why is this discovery being sent again? I have already received a replacement CD from Mr. Ford due
to the CAC certificate errors.

Best.
David

David E. Coombs, Esq.

Law Office of David E. Coombs

ll South Angell Street, #317
Providence, RI 02906

Toll Free: l-800-588-4156

Local: (508)689-4616

Fax: (508)689-9282



Notice: This transmission, including attachments, may contain confidential attomey-client
infonnation and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be
unlawful and is

Defense_Unclass_EmaiI_0862

02216474
Previously in Encl 1







From:

Sent: Wednesday, September 21, 2011 1:52 PM

To: Fein, Ashden CPT USA

Cc: Matthew kemkes . ToomanJoshua CPT MIL US
USA TRADOC Morrow

JoDean, CPT USA SJA
Overgaard, Angel M. CPT USA JF HQ-

Ford, Arthur D.
Melissa Santiago






USA SJ A





Subject: Preserve Evidence Request
Attach: Preserve Evidence - 21 Sep.pdf
Ashden,

Please see the attached request.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317

Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282





Notice: This transmission, including attachments, may contain confidential attomey-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be

unlawful and is

Defense__Unclass_EmaiI_0863



02923368

Previousfy in Encl 1

From: Fein, Ashden CPT USA SJA

Sent: Thursday, September 22. 2011 6:09 PM

To:

Cc: Matthew kemkes- Tooman Joshua CPT MIL US USA

Morrow Ill, JoDean, CPT USA
Overoaard. Angel M. CPT USA Ford. Arthur D. W01 USA JFHQ-
Melissa Santiago; Eric Lakes
Subject: RE: Preserve Evidence Request

David,

could you please clarify your request. Are you asking to have ALL harddrives
that were located in the TSCIF and TOC or only those that were collected by
CID and had Encase forensic images produced? Thank you.

v/ r-
Ashden

Defense_Unclass_Emai|_O864

From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA

Sent: Thutsday. September 22. 2011 7:20 PM
To:
cc: Matthew kemkes; Tooman.Joshua CPT MIL US USA

Mon-ow Jooean, CPT USA JFHQ-NCRIMDW
Overgaani. Angel . PT

SJA: Ford. Anhur D. W01 USA JFHQ-

NCRIMDW Melissa Santiago
Subject: RE: [Suspected RE: US v. PFC BM (Discovery)

David,
Below is an explanation of your comments and questions:

a) MAJ Kemkes: You are accurate. 024383-024459 is reproduced on a classified
CD so you have a copy of the original documents- no alteration except
classified markings.

b) Your Office: He did not send 036618 to 042806 to you, we delivered a copy
to Ft. Myer for CH2 Santiago. She could not access the document because they
were not with her certificates. we needed to provide another copy
so she could read the documents. 024445, on the unclassified side, is a
redacted document. The rest of the documents in that batch (021364 to 036617)
are the same. we provided another copy of the file because the original CD
needs to be destroyed, since it contained classified information. we want to
make sure you have all the documents so we re-sent the same batch with 024445
redacted.

v/r
Ashden

Defense_Unclass_Email_0865





Previously St?laggtted in Encl 1



From:
Sent: Friday, September 23, 201 l0:09 AM

To: Fein, Ashden CPT USA SJA
Cc: Matthew kem kes Tooman.Joshua PT MIL US
USA TRADOC Morrow

Ill, JoDean, CPT USA SJ A

Overgaard, Angel M. CPT USA FHQ-

Ford, Arthur D. W01

Melissa Santiago









SJA
USA SJA





Eric Lakes
Subject: [Suspected RE: Preserve Evidence Request




The defense request is for all hard drives that were located within the T-SCIF and the TOC.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

ll South Angell Street, #3 I7
Providence, RI 02906

Toll Free: l-800-588-4l56

Local: (508) 689-4616

Fax: (508)689-9282



""Conftdentiality Notice: This transmission, including attachments, may contain con?dential attomey-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be
unlawful and is prohibited.??

Defense_Unclass_EmaiI_0866

30584

Fein, Ashden CPT USA SJA

Friday. September 23. 2011 10:45 AM



Matthew kemkes; Tooman.Joshua CPT MIL US USA TRADOC:

Morrow Ill. JoDean, CPT USA SJA:

Ovemaard, Angel M. CPT USA JFHQ-NCRIMDW Ford. Arthur 0. W01 USA JFHQ-
NCRIMDW Melissa Santiago; En'c Lakes

Subject: RE: [Suspected RE: Preserve Evidence Request



Thank you.

Defense_Unclass_EmaiI_0867

-

02916328 Previously Submitted in Encl 78
Previously Syg?ggted in End 1

From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA

sent: 5:35 PM

To:

Cc: Matthew kemkes; Morrow JoDean, CPT USA
HaberIand.John cm? MIL USA:
Ovemaam. Angel M. CP USA HQ-NC DW Tooman, Joshua CPT MIL us


subject: US v. PFC BM (Art 32 Delay Request)

Attachments: 110926-Government Request to Delay Article 32.pdf

knponmnce: r?gh

Sir,

The United States requests a delay of the Article 32.
our digital scanner does not work, so I am providing an unsigned but
I will send an updated signed copy tomorrow.

request.
final version.

v/r
CPT Fein

Ashden Fein
CPI, JA

Defense_Unclass_Emai|_0868

Please see the attached

02916324 Previously Submitted in End 78

30586

From: Fein. Ashden CPT USA SJA

Sent: Tuesday, September 27, 2011 7:39 AM

To:

Cc: coorn armyoourtmamaldefensacom?; Matthew kemkes; MOWON Ill, Jooean, CPT USA
'HaberIand,John CPT MIL
Overgaand. Angel M. - Tooman. Joshua CPT MIL us
USA TRADOC

subjectDelay Request)

Attachments: 110926-Govemment Request to Delay Article 32.pdf

Sir,

Attached is a signed version. Thank you.

v/r?
Ashden

Defense_Unc|ass_Emai|_O869

02216471
30587

From:
Sent: Tuesday, September 27, 2011 11:54 AM

To: Fein, Ashden cp-r USA sm



Cc: Matthew kemkes Paul Bouchard

105*!? T??ma"
Subject: Rumor Mill
Ashden,

I am hearing that the Government is arranging to move PFC Manning for a meeting. This sounds like the
arrangements for the brie?ng on the classi?ed evidence. However, the nimor that I am heating is that this
meeting is with the UN Special Rapporteur on Torture. Any truth to this rumor?

Best,
David

David E. Coombs, Esq.

Law Of?ce of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508)689-4616

Fax: (508)689-9282

i



Notice: This transmission, including attachments, may contain confidential attomey-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be
unlaw?il and is

Defense_Unclass_Email_0870

Previously Submitted in Encl 78













Previously in Encl 1

From:

Sent: Tuesday, September 27, 20l I l2:27 PM

To:

Cc: Matthew kemkes Morrow Ill, .loDean, CPT USA

A
Haberland,.lohn PT MIL USA
Overgaard, Angel M. CPT USA
Tooman,Joshua CPT MIL US USA
Fein, Ashden CPT USA
SJA
Subject: [Suspected US v. PFC BM (Art 32 Delay Request)
Sir,

The Defense maintains its previous postion that any additional delay should not be excluded under R.C.M. 707
Instead, the requested delay should be credited to the Government for speedy trial purposes under Article
I0 of the Uniform Code of Military Justice.


David

David E. Coombs, Esq.

Law O?ice of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: I-800-588-4156

Local: (508) 689-4616

Fax: (508)689-9282



Notice: This transmission, including attachments, may contain confidential attomey-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be

unlawful and is prohibit

Defense_Unc|ass_EmaiI_0871

02920821



30589

2

From Fein, Ashden CPT USA JFHQ-NCRIMDW SJA

Sent Tuesday. September 27. 2011 3:01 PM

To:

Cc: Matthew kemkes; Paul Bouchard; Joshua Tooman; Haberland, John CPT USA Regimental

Judge Advocate

Subject RE: Rumor Mill

David,

Just rumor. No plans for movement or special meetings. we don't know where

that RUMINT came -From.

v/r?
Ashden

Defense_Unclass_Email_0872

02216468
Previously in Encl 1











From: Bouchard, Paul USA MIL (Us)
Sent: Wednesday, September 28, 2011 4:12 PM
To: Fein, Ashden CPT USA SJA
Cc: Robertson, Calder [11 USA CIV (US) Shaver,
David USA CIV (US Pittman, Ryan USA CIV
Ellis, Kirk
A IV (US)
Clapper, Charles USA
Bettencourt, Troy
3 airena, amara USA CIV
(U5)
Subject: CPT Bouchard wants to talk to 13 Government witnesses, US v. PFC Bradley Mannin

(UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: FOUO

Ashden FYI and heads up

I need to speak to the individuals listed on the cc line vis-a-vis the Manning case. As you know, we have equal access to
these persons as you do with any potential defense witnesses.

I have phone numbers for these individuals and will begin calling them tomorrow, 29 September. My questions will be in
the area of computer forensics.

I do not have any contact information - telephone or e-mail address for Mr. Mark Johnson. He apparently works at
the Computer Crimes Investigative Unit at Quantico, VA. Any contact information on Mr. Johnson is greatly appreciated.

Respectfully,

CPT Paul Bouchard

Defense Counsel

Trial Defense Services

Fort Meade Field Office

Fort Meade, Maryland
Office?
Classification: UNCLASSIFIED
Caveats: FOUO

Defense_Unclass_Email_0873

02181132

30591

From: Kim, Hyung SFC USA MIL (us)?l

Sent: Wednesday. September 28, 2011 4:17 PM

To: Bouchard, Paul CPT USA MIL Fein. Ashden CPT USA SJA

Cc: Robenson, Calder USA CIV (US): Shaver. David USA CIV (US): Pittman, Ryan
USA CIV (US): Ellis, Kirk USA CIV (US): Vwlliams.
Stephen USA vwtbur, John USA cw
Clapper, Charles USA CIV il; Bettencourt. Troy USA CIV
Mairena, Tamara USA CIV (US)

Subject: RE: CPT Bouchand wants to talk to 13 Government witnesses. us v. PFC Bradley Mannin
(UNCLASSIFIED)



Classification: UNCLASSIFIED
Caveats: FOUO

Sir,
I to CA since December 2010 and below is my new POC.


Kim

Acting Resident Agent in Charge
Laguna Niguel Fraud Resident Agency
U.S. Amy CID



.


Defense_Unc|ass__EmaiI_0874



02941021

From:

To:
Cc:

Subject:

CPT Bouchard,

Thank you for the heads up.

Previously in End 1

I

Fein, Ashden CPT USA SJA
Wednesday, September 28, 2011 4:58 PM
Bouchard. Paul CPT USA MIL (US)

Robertson. Calder USA us Shaver, David USA CIV Pittman. Ryan 0
USA Ellis, Kirk USA Williams,
Stephen USA CW (Us): vwnbur. John A cuv

Clapper. Charles USA CIV Bettencoun. Troy USA CIV
Mairena, Tamara USA CIV Morrow JoDeen, CPT USA JFHQ-NCRIMDW
SJA: Overuaard. Angel M. CPT USA SJA

RE: CPT Bouchard wants to talk to 13 Government witnesses, US v. PFC Bradley Mannin
(UNCLASSIFIED)

we will work to comply with this request to the

best OF our ability, while balancing the ongoing nature of this
investigation, other investigations by the United States Government, and

national security .

v/r
CPT Fein

Defense__Unclass__Emai|_0875

02916314 Previously Submitted in Encl 79

Previously in Encl 1

From: Fein, Ashden CPT USA SJA

sent: Wednesday. September 28. 2011 5:08 PM

To: 'AImanza. Paul?

Cc: Matthew kemkes; Morrow JoDean, CPT USA

Habe?and,John CPT MIL Overuaarcl, Angel M. CPT
- A: ooman.Joshua CPT MIL us USA TRADOC:


SubjectDelay)
Attachments: Delay of Article 32 Investigationpdf
Sir,

Good afternoon. The granted an additional delay 04? the Article 32
investigation. Please see attachment.

v/r~
CPT Fein

Defense_UncIass_Emai|_0876


30594

Fein, Ashden CPT USA SJA

Wednesday. September 28, 2011 5:09 PM



Matthew kemkes; Tooman,Joshua CPT MIL US USA
Morrow m, JoDean, CPT USA
Overuaard. Angel M. CP A Ford, Arthur D. W01 USA JFHQ-
Melissa Santiago; Eric Lakes

RE: [Suspected RE: Preserve Evidence Request

David,

Are you available to discuss this request over the telephone?
Thanks.

v/
Ashden

Defense_Unclass_EmaiI_0877

02216465

From:
Sent:
To:
Cc:

Subject:

Ashden,

30595


Thursday, September 29, 201 I 8:08 AM
Fein, Ashden CPT USA SJA

Matthew kemkes
USA TRADOC
Ill, .loDean, CPT USA JFH







Tooman.Joshua CPT MIL US
Morrow
SJA

)vergaard, Angel M. CPT USA FHQ-

Ford. Arthur D. W01

Melissa Santiago





USA SJA




RE: [Suspected RE: Preserve Evidence Request

am available between I200 and I300 or anytime a?er 1600 today.

Best,
David

David E. Coombs, Esq.

Law Of?ce of David E. Coombs
ll South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156
Local: (508) 689-4616

Fax: (508)689-9282




Notice: This transmission, including attachments, may contain con?dential attomey-client
infonnation and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be

unlawful and is prohibited.""

Defense_UncIass_EmaiI_0878

02949008
30596

From: Fein, Ashden CPT USA SJA

sent: Thutsday, September 29, 2011 9:31 AM

To:

Cc: Matthew kemkes; Tooman.Joshua CPT MIL US USA

Momow JoDean, CPT USA JFHQ-NCRIMDW
Overuaard. Angel M. CPT USA JFHQ-NCRIMDW SJA: Ford. Arthur D. W01 USA JFHQ-
Melissa Santiago; Eric Lakes
Subject: RE: [Suspected RE: Preserve Evidence Request

David,
Thanks. How is 1230?

v/r
Ashden

Defense_Unc|ass_Emai|_0B79

02216461

From:
Sent: Thursday, September 29, 20ll 9:41 AM

To: Fein. Ashden CPT USA SJA
Cc: Matthew kemke Tooman,Joshua CPT MIL US
USA TRADOC Morrow

Ill, JoDean, CPT USA SJA
Overgaard, Angel M. CPT USA

Ford, Arthur D.
Melissa Santiago

30597







USA SJA




Subject: RE: [Suspected RE: Preserve Evidence Request

1230 works fine for me.

David E. Coombs, Esq.

Law Ot?ce of David E. Coombs
ll South Angell Street, #317
Providence. RI 02906

Toll Free: 1-800-588-4156
Local: (508) 689-4616

Fax: (508)689-9282



"*Con?dentiality Notice: This transmission, including attachments, may contain con?dential attomey-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be
unlawful and is prohibited.""

Defense_Unclass_Email_088O

02949003
30598


From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA
Sent: Thursday, September 29. 2011 9:43 AM
To:
subject: Re: [Suspected RE: Preserve Evidence Request
Thanks.

Defense_Unc|ass_Emai|_0881



02219484

From:
Sent:
To:
Cc:

Subject:

Previously Submitted in End 79
30599

Almam Paul

Thursday, September 29Fein, Ashden CPT USA SJA

Matthew kemkes
SJA





Morrow Ill, JoDean(Art 32 Delay)

Thank you. CPT Fein.

LTC Almanza

Defense_Unclass__Email_0882

Previously S%'gted in Encl 1



From: Fein, Ashden CPT USA SJA

sent: Thursday. September 29, 2011 4:40 PM

To:

Cc: Matthew kemkes; Tooman,Joshua CPT MIL US USA

Momow JoDean, CPT USA
emaard. Angel . PT USA Ford. Arthur D. W01 USA JFHQ-

SJA: Melissa Santiago; En'c Lakes
Subject: RE: [Suspected RE: Presetve Evidence Request

David,

Thanks For the chat this afternoon. To recap, you are requesting the
preservation of the Following items:
1. A11 SIPR hard drives in the TOC and SCIF of 2/16 MTN, regardless if they

were seized or imaged
2. A11 Encase Forensic images of all computers seized by the United States

v/r
Ashden

Defense_Unclass_EmaiI_O883

02216457
Previously Si?gglitted in Encl 1

From:
Sent: Thursday, September 29, 20l I 4:43 PM

To: Fein. Ashden CPT USA SJA
Cc: Matthew kemkes Tooman.Joshua CPT MIL US
USA TRADOC Morrow

HI, JoDean, CPT USA SJ A
Overgaard, Angel M. CPT USA FHQ-

Ford, Arthur D. W01
. Melissa Santiago







SJA
USA I SJA




Subject: RE: [Suspected RE: Preserve Evidence Request

Ashden,

Your understanding of the Defense request to preserve evidence is correct.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

ll South Angell Street, #317
Providence, RI 02906

Toll Free: l-800-588-4l56

Local: (508) 689-4616

Fax: (508)689-9282



Notice: This transmission, including attachments, may contain con?dential attomey-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be
unlawful and is prohibited.??

Defense_Unclass_Emai|_0884

30602

Please see below.

Vr
Ashden

Defense_U nclass_Emai|_0885

Fein, Ashden CPT USA SJA
Thursday, September 29, 2011 6:18 PM


Monow Jooean, CPT USA JFHQ-NC ergaerd. Angel . CPT USA

Ford, Anhur D. W01 USA JFHQ-NCRIMDW SJA
Fw: CPT Bouchard wants to talk to 13 Government witnesses. US v. PFC Bradley Mannln
(UNCLASSIFIED)

If you have any questions, please let us know.

Previously in Encl 1


Friday, September 30, 20l I 8:27 AM

Fein, Ashden CPT USA SJA
Morrow .loDean, CPT USA SJA

Overgaard, Angel M. CPT USA JFHQ-
Ford. Arthur D. W01








USA SJA



Paul Bouchard
Subject: [Suspected Agent lnterviews



Ashden,

I don't see the necessity for Mr. Andrews? request to work through Mr. King. My main concern is that
coordinating with Mr. King will unnecessarily add a layer to the entire process. The agents that we want to
speak with are stationed in Alaska, Hawaii, Japan, Germany, Iraq, Afghanistan, and throughout CONUS.

Why is it necessary for Mr. King, as the SAC of CCIU, to coordinate interviews for each of these
witnesses? If Mr. King wanted to coordinate the interviews of CCIU agents in his office, then this
would make somewhat more sense. However, it appears that Mr. Andrew s? email is addressing all
CID agents. Also, I am troubled by his statement that "Kenny will coordinate the requests, as
appropriate." Does this mean that one or more agents will not cooperate with a defense interview
request?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street. #3 I 7

Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508)689-9282





?"Confidentiality Notice: This transmission, including attachments, may contain con?dential attorney-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be
unlawful and is prohibited.?*

Defense_Unclass_Email_0886

02216452
Previously in Encl 1

From: Kemkes, Matthew MAJ MIL us??
sent: Friday, September 30, 2011 4:25

To: Fein, Ashden CPT USA SJA

Cc: Santiago, Melissa CW2 RES USA
Subject: Request for Supplies (UNCLASSIFIED)

Attachments: Request for Supp|ies.pdf

Signed By:

Follow Up Flag: Follow up

Flag Status: Completed

Classification: UNCLASSIFIED
Caveats: FOU0

CPT Fein,

Please see the attached request.
Respectfully,

MAJ Matthew J. Kemkes

Senior Defense Counsel, NCR

U.S. Army Trial Defense Service

Fort Myer, Virginia

mice:

Classification: UNCLASSIFIED
Caveats: FOUO

Defense_Unc|ass_Emai|_0887

0292 276

30605

From: Fein, Asnden CPT USA SJA

Sent: Friday, September 30. 2011 5:40 PM

To: Matthew kemkes

Cc: Fotd, Arthur D.

W01 USA Morrow! I, an. USA SJA

Subject: Re: Request for Supplies (UNCLASSIFIED)

Sir. Ack.

Defense_U nclass_Em ail_0888

02947875
Previously in Encl 1

From: Fein. Ashden CPT USA SJA

Sent: Sunday, October 02. 2011 8:13 PM

To:

Cc: Momow Ill. JoDean. CPT USA JFHQ-NCRIMDW SJA: Overgaard. Angel M. CPT USA

SJA: Ford. Arthur 0. W01 USA JFHQ-NCRIMDW SJA:

subject: e: gem ntervnews

David,

I appreciate your concern; however, rather than an unnecessary added layer, CCIU's response
seems to be a more efficient means by which to coordinate the interviews of numerous agents.
As you accurately stated, agents are stationed worldwide, and coordinating interviews in
different time zones, particularly with deployed individuals, can be very time-consuming. SA
King will be able to de-conflict schedules for you and ensure the availability of the
appropriate individuals at a time convenient for you.

Also, this is still an ongoing national security investigation involving other law
enforcement agencies and equities, and classification reviews are still ongoing. It seems
much more burdensome and time-consuming for you to ask an agent a question and have to wait
for him to determine whether his response is classified or whether the information in his
response has been approved for released before he can answer your question.

In his email, SA Andrews refers to the unresolved classification and national security
issues. The ?as appropriate? language, therefore, likely refers to these concerns and
ensuring agent responses do not compromise any information that cannot be released at this
point in time.

CCIU is aware of the Article 32, Article 46, and the accused's right of equal access to
witnesses; however, given the national security concerns and pending approvals and
classification reviews, SA King's coordination seems necessary to ensure all equities are
protected while also ensuring your ability to prepare for the Article 32.

Please let me know if you have any further questions or concerns.

Vr
Ashden

Defense_Unc|ass_Emai|_0889

Previously in Encl 1


Sunday, October 2, 20]] I I :48 PM

Fein, Ashden cm USA sm

Morrow Ill, JoDean, CPT USA SJA
Overgaard, Angel M. CPT USA JFHQ-
Ford, Arthur D. W01





SJA
USA JFHQ-NC




Subject: [Suspected RE: Agent Interviews

Ashden,

I am all for efficiency, and I appreciate CC interest in assisting the Defense in coordinating the interviews
of numerous agents. I want to make sure that I understand how this process is intended to work. Is SA King
simply setting up convenient times for us to interview the requested agents or will he also have some additional
role? How is coordinating through SA King going to avoid a situation where an agent needs to determine
whether his response is classi?ed or not?? How is coordinating through SA King going to ensure that an agent's
response does not compromise any information that cannot be released at this point in time?

Best,
David

David E. Coombs. Esq.

Law Office of David E. oombs

ll South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 6894616

Fax: (508) 689-9282




Notice: This transmission, including attachments, may contain confidential attomey-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure. copying or use of this information may be
unlawful and is

Defense_U nclass_EmaiI_0890 A



02915871

30608

From: Fein, Ashden CPT USA SJA

sent: Monday, October 03. 2011 8:05 AM

To:

Cc: Matthew kemkes: 'Tooman.Joshua CPT MIL US USA
Morrow Ill, JoDean. CPT USA

orgaard, Angel M. USA Ford. Arthur D. W01 USA JFHQ-

INSRAUDVVSUA

Subject: US v. PFC BM (Discovery)

David,

On Friday, we re-sent to you (tracking: 7010 1060 0001 1274 4002) all the
material that we have produced thus far (00000001-00044864). we will deliver
a copy to MAJ Kemkes this morning. As we discussed on the phone, this
re-production and future productions will have each individual docunent
separated into its own PDF.

v/r
Ashden

we delivered two classified CD5 containing and 00024383-00024459

(file containing information we requested be deleted from everyone's computer)
and 00044865-00045301 (portions of military_intelligence investigations).
Yesterday, we sent you (tracking: 7010 1060 0001 1274 3999) 00021364-00036617
(majority of (ID Case file with redacted classified file) and delivered a copy
to Fort Myer. He also delivered a new copy of 00036618-00042806 because of
CAC certificate errors.

Thank you.


Ashden

Defense_Unc|ass_EmaiI_0891

02921279
30609

From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA
Sent: Tuesday, October 04, 2011 7:22 AM
To: Kemkes, Matthew MAJ MIL USA
cc: Santiago. Melissa CW2 RES Parra, Jairo
A. W01 USA JFHQ-NCRIMDW SJA
Subject: RE: Request for Supplies (UNCLASSIFIED)
Sir,

we are working this request. Once the government credit card is turned back
on and -Funded, we will act immediately.


Ashden

Defense_Unclass_Emai|_0892

30610



From: Fond, Arthur D. W01 USA SJA

Sent: Tuesday, October 04, 2011 7:34 PM
To: Matthew kemkes; Paul Bouchard;
?Santiago, Melissa CW2
RES
Cc: Fein. Ashden CPT USA SJA: Feito, Beatnz SGT USA JFHQ- NCRIMDW
SJA
Subject: EDVA Protective Orders (UNCLASSIFIED)

Attachments: 10GJ3793.pdf; 10sw396. 1OGJ3793-rnk.pdf; 11EC131.pdf
Signed By: 3

Classification: UNCLASSIFIED
Caveats: FOU0

Everyone,
Attached are Four disclosure and protective orders. As before,

please initial each page, sign the last page, scan, and email back to me.
Thank you very much. -



Arthur Ford
um, JA
Legal Administrator

Com:

BB:

Classification: UNCLASSIFIED
Caveats: FOUO

Defense_UncIass_Email_0893

02216433

From:
Sent:
To:

Cc:

Subject:
Attach:

30611

Pan? B?Uchar

Wednesday. October 5, 20] I I I224 AM

Ford, Arthur D. W01 USA SJA




Fein, Ashden cm USA sm

Feito. Beatriz SGT USA IF HQ- SJ A




Re: EDVA Protective Orders (UNCLASSIFIED)
POl.pdf; P02.pdf; P03.pdf; P04.pdf

Mister Ford:

addresses are on the cc line: nd/or

Respect?rlly,

CPT Paul Bouchard
Defense Counsel

Defense__Unclass_Emai|_0894

02216419
1 30612

From:
Sent:
To:

Cc:

Subject:
Attach:

Mr. Ford,


Wednesday, October 5, 201 1 2:40 PM
Ford, Arthur D. WOI USA SJA

Fein, Ashden USA SJA

Feito, Beatriz SGT USA JFHQ- SJ A
Matthew kemkes

Paul Bouchard





Santiago,Melissa



RES USA
EDVA Protective Orders (UNCLASSIFIED)
Protective Order -

As requested, 1 have attached the four signed protective orders.

Best.
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508)689-4616

Fax: (508) 689-9282



Notice: This transmission. including attachments. may contain con?dential attomey-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please

notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be
unlaw?il and is prohibited.??

Defense_Unclass_Email_O895

02216408

30613

From:
Sent
To:
Cc:

Subject:

Attachments:

Signed By:

Tooman, Joshua CPT MIL US USA TRADOC

Wednesday, October 05. 2011 5:03 PM

Fold, Arthur D. W01 USA
Matthew kemkes; Paul Bouchard; Purcell, Cherise SSG RES Santiago, Melissa 8
CW2 RES USA

Fein, Asnden CPT USA Feito. Beatriz SGT USA JFHQ-
SJA

RE: EDVA Protective Orders (UNCLASSIFIED)

Protective Otders Tooman Octobenpdf

Classification: UNCLASSIFIED
FOUO

Caveats:

Mr. Ford

Signed protective orders are attached, per your request.

v/r

CPT Toonan

Defense_Unclass_Email_0896



02949153

306M
From: Fein, Ashden CPT USA SJA
Sent: Thursday, October 06, 2011 10:41 AM
To:
Cc: Motrow Ill, JoDean. CPT USA Overgaani, Angel M. CPT USA
Fond, Arthur D. W01 USA JFH -NCRIMDW
?Tooman.Joshua CPT
MIL us USA
subject: RE: [Suspected RE: Agent Interviews
knponance: r?gh
David,

First, in reference to your questions below, it appears that SA King will be the arbiter on
what is protected information and not. I recommend contacting SA King about the agent
interview process, as he will best be able to address your specific questions. If you still
have any unanswered questions or concerns after talking to him, I will be more than happy to
assist in trying to clear up any potential issues.

Additionally, we received the final CCIU forensic reports and started preparing them for
approval and production. Over the next two weeks, we should have all the final approvals to
turn over the information to you and your team. we should be ready to meet with you and turn
over the classified forensic reports on 3-4 November 2911.

we would like to schedule that Thursday and Friday to assist the defense in getting through
the voluminous material we are preparing to provide. If the defense is willing to meet, we
will be able to orient you to the facts of the case, the layout of the reports, and give a
brief overview of the prosecution's case. This should overall speed up the pre-trial process
and minimize any future delays.

Please let me know if that date will work. we do not expect to have all the approvals back
and the documents ready for release, prior to 3 November.

Thank you.

v/
Ashden

Defense_UncIass_EmaiI_0897



02216402

30515
From:
Sent: Thursday, October 6. 20l ll:2l AM
To: Fein, Ashden USA SJA
Cc: Morrow JoDean, CPT USA SJA

Ove aard, An el M. CPT USA
Ford, Arthur D.





SJA
USA SJA






Tooman,Joshua



CPT MIL US USA TRADOC
Subject: RE: [Suspected RE: Agent Interviews

Ashden,

We will contact Mr. King to detennine the process that he envisions for being the "arbitrator" for our CID
interviews. If we have a problem with this process. we will alert you to the nature of our conoems.

Given the fact that you do not expect to have all of the approvals back and the documents ready for release prior
to 3 November. how confident are you in the 3-4 November date?? I suggest we schedule our meeting for at
least one week later on the 9th and 10th of November or even the 17th and 18th of November. This would
allow for the following:

a) The Government to know for sure that they have the necessary approvals back and documents ready for
release;

b) The defense team (experts and myself) to make the necessary travel arrangements with
con?dence that our travel plans will not need to be cancelled; and

c) The defense team to review the majority of the classified discovery prior to the meeting in order to get the
most out of the Govemment's presentation.

Your thoughts?

Best,
David

David E. Coombs, Esq.

Law Of?ce of David E. Coombs

I South Angell Street, #317

Providence. RI 02906

Toll Free: 1-800-588-4156

Local: (508)689-4616

Fax: (508) 689-9282





Notice: This transmission, including attachments, may contain con?dential attorney-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be
unlawful and is prohibit

Defense_UncIass_EmaiI_0898

02949073
30616

From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA

sent: Thursday. Octoberoa. 2011 12:41 PM

To:

Cc: Morrow Ill, JoDean, CPT USA Overgaand. Angel M. CPT USA

Ford. Arthur D. W01 USA JFHQ-NCRIMDW SJA:
I Toornan.Joshua CPT

Subject: RE: [Suspected RE: Agent lntetviews

David,
This might be better discussed over the phone. Are you available today? Thank you.

v/r?
Ashden

Defense_Unc|ass_Emai|_0899

02216395
30617

From:
Sent: Thursday, October 6, 20l PM

To: Fein. Ashden CPT USA







Cc: Morrow .loDean. CPT USA SJA
. Overgaard, Angel M. PT USA JFHQ-
SJA . Ford, Arthur D. W01
USA JA
Tooman,Joshua
CPT MIL US USA TRADOC
Subject: RE: [Suspected RE: Agent Interviews

Are you available at

David E. Coombs. Esq.

Law Office of David E. Coombs

ll South Angell Street, #317
Providence, RI 02906

Toll Free: I-800-588-4l56

Local: (508)689-4616

Fax: (508) 689-9282



Notice: This transmission, including attachments, may contain con?dential attomey-client
infonnation and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be

unlawful and is prohibited.??

Defense_Unc|ass__Email_0900

30618

Fein, Ashden CPT USA SJA

Thursday, October 06. 2011 1:05 PM



Morrow JoDean, CPT USA Overgaaru, Angel M. CPT USA
Ford, Arthur D. W01 USA JFHQ-NCRIMDW

Tooman.Joshua CPT



IL DOC
Subject: RE: [Suspected RE: Agent Interviews

David,

I am. I will call at 1438.

Defense_Unclass_EmaiI_0901

02949048
Previously Segted in End 1

From: Fein, Ashden CPT USA SJA

sent: Thursday, October 08. 2011 3:23 PM

To:

Cc: Momow JoDean, CPT USA JFHQ-NCRIMDW SJA: Overgaard, Angel M. CPT USA

Ford. Anhur D. W01 USA JFHQ-NCRIMDW SJA2

Toomarwosnua 4 cm

Subject: RE: [Suspected RE: Agent Interviews

David,

Thanks for the phone meeting. Please read below, and let me know if this is an accurate
recount:

1. The United States should be ready to turnover the classified Forensic evidence by 3 Nov
11. when it is ready, we will work to provide the production to the defense at Fort Myer.
Because of the New Developments course that week, you rather eet the following week for the
prosecution to discuss the case, as outlined below, with the defense.

2. we will plan on meeting on 8-9 Nov. The defense team will be present, with or without
the computer forensic experts and the security experts.

3. Depending on the outcome of the meeting, you might want to have your client flown out
to the NCR to sit down and receive the same briefing/explanation of the forensic evidence.
That decision will be made after the initial meeting.

4. Assuming the prosecution receives the final classification review, we the approvals to
turn over classified information, we will be ready to move immediately into the Article 32
investigation. The prosecution will notify the and the Article 32 will likely be
ordered to occur soon after the 8-9 Nov meeting.

5. The prosecution will make available the classified evidence as soon as we receive the
approvals and have it prepared to turn-over, even if before 3 Nov.

Thank you.

v/r
Ashden

Defense_Unclass_EmaiI_0902

Previously Syg?ggted in Encl 1



From:
Sent: Thursday. October 6. 20l 1 4:02 PM

To: Fein. Ashden CPT USA SJA








Cc: Morrow .loDean, CPT USA SJA
. Overgaard, Angel M. PT USA WHO-
Ford, Arthur D. W01
USA SJA
ToomanJoshua
CPT MIL US USA TRADOC
Subject: RE: [Suspected RE: Agent Interviews
Ashden,

I agree with your synopsis of our conversation.

If the classi?ed discovery is provided to the defense prior to our meeting, I will come down to look through the
information. Additionally, the defense will be ready to conduct the Article 32 as soon as the orders it
to begin. Once we receive the witness list from the Article 32 Officer, the defense will submit its witness list.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

ll South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508)689-4616

Fax: (508)689-9282
com



?"Conf1dentiality Notice; This transmission, including attachments, may contain con?dential attomey-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be
Lmlawful and is

Defense_Unclass_Email_0903

02949038

From:

To:
Cc:

Subject:

Thank you .

Defense_UncIass_EmaiI_0904

30621

Fein. Ashden CPT USA SJA

Thursday, October 06, 2011 4:05 PM



Motrow JoDean, CPT USA SJA: Overgaard, Angel M. CPT USA
Fond, Arthur D. W01 USA JFHQ-NCRIMDW

Tooman.Joshua CPT

RE: [Suspected RE: Agent Interviews

02230895
30622

From: Rains, Lany Mr CIV USA DCS G-2
sent: Thursday, October 13, 2011 12:45 PM

To: Fein, Ashden CPT USA SJA

Cc: Pittman, Jamil A Mr CIV US USA DCS G-2
Subject: tnuttman grante ecret Clearance

Signed Bv= 0

Classification: OFFICIAL USE ONLY

Ashden,

Re: PFC Manning Case

Mr. Struttman has been granted a Secret security clearance by Army CCF.

Best regards,
Larry

Larry Rains

Security Manager/SSR
HQDA, ODCS, G-2

1000 Army Pentagon
Washington DC 20310-1000

Comm:
Fax:

Classification: OFFICIAL USE ONLY

Defense_Unclass__EmaiI_0905

02949329



30623

From:
Sent:
To:
Cc:

Sub?n:
Larry,
Thank you.

v/r
Ashden

Defense_Unclass_EmaiI_0906

Fain, Ashden CPT USA SJA
Thutsday, October 13. 2011 12:58 PM
Rains, Larry Mr CIV USA DCS G-2
Pittman. Jamil A M: CIV US USA DCS G-2
nmman granted Secret Clearance

30624

Fain, Ashden CPT USA SJA

Thursday. October 13. 2011 1:09 PM

martia|defense.com'

Matthew kemkes; ooman,Joshua CPT MIL US USA

Morrow Ill, JoDean, CPT USA

Overoaard, Angel M. CPT USA SJA: Ford. Arthur D. W01 USA JFHQ-
SJA: ?Melissa Santiago?

Subject: US v. PFC BM (Discovery)



David,

Yesterday, we sent to you (tracking it 7010 1060 0001 1274 4019) and delivered
to MAJ Kemkes unclassified discovery (BATES: 00045302-00045581). These
documents are miscellaneous documents from the C10 case file. we also
re?de1ivered the three classified laptops to the TDS office and verified that
CH2 Santiago could log on to one of them.

v/r
Ashden

Defense_Unclass_EmaiI_0907



02981142

30625

From:
Sent
To:
Cc:

Sub?unz

David,

Fein, Ashden CPT USA SJA

Thursday, October 13, 2011 1:09 PM



Matthew kemkes; 'Tooman,Joshua CPT MIL US USA

Morrow JoDean, CPT USA

Overgaard, Angel M. CPT USA Ford, Arthur D. W01 USA JFHQ-
?Melissa Santiago?

US v. PFC BM (Discovery)

Yesterday, we sent to you (tracking 7010 1060 0001 1274 4019) and delivered

to MAJ Kemkes unclassified discovery (BATES: 00045302-06045581).
documents are miscellaneous documents from the (ID case file.

These
we also

re-delivered the three classified laptops to the TDS office and verified that
CW2 Santiago could log on to one of them.

v/r
Ashden

Defense_Unc|ass_Emai|_0908

02216380

Previously ed in Encl 1
From:
Sent: Thursday, October 13, ZOI I I235 PM
To: Fein, Ashden CPT USA SJA
Cc: Matthew kemkes Tooman,Joshua PT MIL US




USA TRADOC Morrow

Ill, JoDean, CPT USA JFH





SJ A
Overgaard, Angel M. CPT USA IFHQ-

. Ford, Arthur D. W01
Melissa Santiago





SJA
USA SJA




Subject: RE: US v. PFC BM (Discovery)
Attach: 13 Oct Discovery Request.pdf
Ashden,

Thank you for the update. Please see the attached discovery request. Let me know if you have any questions.

Best.
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508)689-4616

Fax: (508) 689-9282



Notice; This transmission. including attachments, may contain con?dential attomey-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be
unlawful and is prohibited.?"

Defense_Unclass_Email_O909



02949890
30627

9 9

From:

Sent: Thursday, Oc1ober13. 2011 1:35 PM

To: Fein. Ashden CPT USA JFHQ-NCRIMDW SJA

Cc: Matthew kemkes; Tooman,Joshua CPT MIL US USA

Monow JoDean, CPT USA JFHQ-NCRIMDW SJA:
emaa . Ange . A JFHQ-NCRIMDW SJA: Fotd. Arthur 0. W01 USA JFHQ-
Melissa Santiago

Subject: RE: US v. PFC BM (Discovery)

Attachments: 13 Oct Disoovety

Follow Up Flag: Follow up

I Flag status: Completed
Ashden,

Thank you for the update. Please see the attached discovery request. Let me know if you
have any questions.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317

Providence, RI 02986

Toll Free: 1-880-588-4156
Local: (593) 689-4616
Fax: (588) 689-9282



I

Notice: This transmission, including attachments, may contain confidential
attorney-client information and is intended for the person(s) or company named. If you are
not the intended recipient, please notify the sender and delete all copies. Unauthorized
disclosure, copying or use of this information may be unlawful and is

Defense_Unc1ass_Emai|_0910



0291 5879

30628

From:

To:
Cc:

Subject:

David,

Fain, Ashden CPT USA JFHQ-NCRIMDW SJA

Monday, October 17. 2011 9:45 AM



Matthew kemkes; Tooman.Joshua CPT MIL US USA

Morrow JoDean, CPT USA SJA:

Overoaand, Angel M. CPT USA SJA: Fond. Arthur D. W01 USA JFHQ-
NCRIMDW Melissa Santiago

RE: Us v. PFC BM (Discovery)

we acknowledge receipt of this discovery request and are working to process.

v/r
Ashden


Defense_Unclass_EmaiI_091 1

02981 140
Previously Sgg?ggted in Encl 1

From: Fein, Ashden CPT USA SJA

Sent: Monday, October 17. 2011 9:45 AM

To: .
Cc: Matthew kemkes; 'Tooman,Joshua CPT MIL US USA

Morrow Ill, JoDean. CPT USA
Overoaard, Angel M. CPT USA Ford. Arthur D. W01 USA JFHQ-
?Melissa Santiago?
Subject: RE: US v. PFC BM (Discovery)
David,

we acknowledge receipt of this discovery request and are working to process.

v/
Ashden

Defense_Unclass_EmaiI_0912

02916498
Previously in Encl 1

From: Fein, Ashden CPT USA SJA

Sent: Tuesday, October 18, 2011 9:23 AM

To:

cc: Matthew kemkes; Tooman.Joshua CPT MIL US USA

Morrow Jooean, CPT USA
Overuaaru. Angel M. CPT USA SJA: Fond, Arthur D. W01 USA JFHQ-
Melissa Santiago

subject: US v. PFC BM
Attachments: 111014-Excludabie Deiay Memorandumpdf
David,

Attached is the excludable delay accounting memo.

v/r~
Ashden

Defense_Unc|ass_Emai|_091 3



02216379

30631








From:

Sent: Tuesday. October I8. 20] 9:32 AM

To: Fein. Ashden CPT USA SJA

Cc: Matthew kcmkes Tooman.Joshua.| PT MIL US USA
TRADOC "a Mono? llI_. JoDean
PT USA SJA Overgaard, Angel
M. CPT USA SJA Ford. Arthur
D. W01 USA SJA Melissa Santiago

Subject: [Suspected RE: US v. PFC BM

Ashden,

Thank you. 1 also wanted to let you knots that I received the unclassi?ed discovery discs last week (0000000l-
00044864 and 00045301-00045581).

Best,
David

David E. Coombs. Esq.

Law Office of David E. Coombs

ll South Angell Street. #3l7
Providence. RI 02906

Toll Free; l-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282



?"Con?dentiality Notice: This transmission, including attachments. may contain con?dential attomey-client
information and is intended for the person(s) or company named. If you are not the intended recipient. please notify the
sender and delete all copies. Unauthorized disclosure. copying or use of this infonnation may be unlawful and is
prohibited!"

Defense_Unclass_EmaiI_0914

029491 09

30632

From:

Cc:

Subject:

Thank you.

Defense_UncIass_EmaiI_0915

Fain, Ashden CPT USA SJA

Tuesday, October 18. 2011 9:37 AM



Matthew kemkes; Tooman.Joshua CPT MIL US USA

Mormw JoDean, CPT USA JFHQ-NCRIMDW SJA:
ergaa . Ange . A Fotd, Arthur 0. W01 USA JFHQ-

NCRIMDW Melissa Santiago

RE: [Suspected RE: US v. PFC BM

02915877
30333
From: Fein, Ashden CPT USA SJA
Sent: Friday, October 21 2011 7:03 AM
To:
cc: Matthew kemkes; 'Tooman,Joshua CPT MIL US USA
Morrow Ill. Jooean, CPT USA JFHQ-NCRIMDW SJA:
ergaard. Angel M. CPT USA SJA: Ford. Arthur 0. W01 USA JFHQ-

subject: us v. PFC BM (Discovery)
David,

Yesterday, we sent to you (tracking: 7616 1066 0091 1274 4026) miscellaneous
CID documents from their case file (0O645582-00646973). He also delivered a
copy to MAJ Kemkes. Have a good weekend.

v/
Ashden

Defense_UncIass_EmaiI_0916



02981139



30634

From:
sent:
To:
Cc:

Subject:

David,

Yesterday, we sent to you (tracking:
CID documents from their case file (0004SS82-00046073).
Have a good weekend.

copy to MAJ Kemkes.

v/r?
Ashden

Defense_Unclass_Email_091 7

Fein, Ashden CPT USA SJA

Friday, October 21, 2011 7:03 AM



Matthew kemkes; 'Tooman,Joshua CPT MIL US USA

Morrow Ill, JoDean, CPT USA

Overgaard, Angel M. CPT USA Ford, Arthur D. W01 USA JFHQ-
SJA

US v. PFC BM (Discovery)

7010 1060 0001 1274 4026) miscellaneous
we also delivered a

02216378

30635
From: Tooman, Joshua CPT USA MIL (US)
Sent: Friday, October 21, 2011 7:04 AM
To: Fein, Ashden CPT USA SJA
Subject: Automatic reply: US v. PFC BM (Discovery)

I am currently on leave, 19 October 2011 - 2 November 2011, and will not have email access for the majority of this
time. I will return to the office on 3 November 2011. If you need immediate assistance, please contact Mr. Eddie Young

a

Defense__UncIass_EmaiI_0918

0291 6024
30636

From: Fein, Ashden CPT USA SJA

sent: Fnday. October 21. 2011 9:54 AM

To: Kernkes, Matthew MAJ MIL USA

Cc: 'Tooman,Joshua CPT MIL US USA

Morrow Ill, JoDean, CPT USA
Overgaam. Angel M. CPT USA JFHQ-NCRIMDW Ford. Arthur D. W01 USA JFHQ-
SJA
Subject: US v. PFC BM (Classi?ed Matenal Supply Request)

MAJ Kenkes,

we processed and ordered the material you requested to handle classified
material. we expect to have the supplies in and ready to be picked up by the
end of next week. we will notify CH2 Santiago once it is all ready to be
picked up.

v/r
Ashden

Defense_Unclass__Emai|__O919

0291 6332

Previously Submitted in Encl 78
Previously in Encl 1

From:

To:
Cc:

Subject:
Attachments:

lmponenoe:

Sir,

The United States requests a delay of the Article 32.

request.

V/r
CPT Fein

Ashden Fein
CPT, JA

Defense_Unc|ass_EmaiI_092O

Fein. Ashden CPT USA SJA
Tuesday, October 25, 2011 6:11 PM

Matthew kemkes; Morrow Jooean. CPT USA
'HaberIand.John CPT MIL
Overgaard, Angel M. CP - 'Tooman. Joshua CPT MIL US
USA

US v. PFC BM (Art 32 Delay Request)

111025-Govemment Request to Delay Atticle 32.pdf

High

Please see the attached

02916442

Previously in End 1

From:
800::
To:
Cc:

Subject:
tk?mchnun?sz

David,

Good evening .

and outlines some ground rules for our 8-9 Nov 11 meeting.
the meeting only to take one day, we are planning for two.
Please let me know if you have any questions.

time is T80.

-Break-

Fein, Ashden CPT USA SJA

Tuesday. October 25. 2011 6:15 PM



Matthew kemkes; Morrow Jooean. CPT USA JFHQ-NCRIMDW

'Habedand,John CPT MIL Ovetuaald. Angel M. CPT

DW A: ooman. Joshua CPT MIL US USA

Us v. PFC BM (8-9 Nov 11 Meeting)

111025-Proposed Meeting with Defensepdf

Attached is a memorandum that captures our previous discussions

Although we expect
The location and

Additionally, we are working to receive the final approval for the forensic

reports and other classified information.
Once we receive the approval, we will start production and have it

1 Nov.

ready for your team before the end of the week.

we hope to have this information by

Please let us know when you

would like us to schedule, if at all, your forensic computer experts to travel

out to Fort Meade.

v/r
Ashden

Defense_Undass_Email_O921

02216375
Previously in Encl 1

From:

Sent: Tuesday. October 25, 20] I 6:45 PM

To: Fein, Ashden CPT USA
Cc: Matthew kemkes Morrow .loDean, CPT USA










SJA



Haberland,John CPT MIL USA
Overgaard. Angel M. CPT USA
Tooman.Joshua CPT MIL US USA

TRADOC
Subject: [Suspected RE: US v. PFC BM (8-9 Nov ll Meeting)
Attach: TC Presentation.pdf
Ashden,

The terms of our November meeting as proposed in your memorandum are acceptable to the defense. I have
attached my signed acknowledgement.

I will be traveling to D.C. on the 7th along with other defense experts to conduct a review, prior to our meeting,
of the classi?ed discovery. Please let me know if anything affects the time line for the Government's disclosure
of the classified discovery. PT Bouchard will contact you later this week in regards to the forensic review by
Mr. Lakes and Mr. Struttman.

Let me know if you have any questions.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angeli Street, #3 I 7
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282



"?'?'Confidentiality Notice: This transmission, including attachments, may contain confidential attomey-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure. copying or use of this information may be
unlawful and is prohibited.?"

Defense_U nc|ass_Emai|_0922





02216373 Previously Submitted in Encl 78













Previously in Encl 1

From:

Sent: Tuesday, October 25, 2011 6:49 PM



Cc: Matthew kemkes Morrow Ill, .loDean, CPT USA

SJA
Habet1and.John CPT MIL USA
Overgaard. Angel M. CPT USA
Tooman,JoshuaJ CPT MIL US USA
ein, Ashden CPT USA
SJA
Subject: [Suspected RE: US v. PFC BM (Art 32 Delay Request)
Sir,

The defense maintains its previous position that any additional delay should not be excluded under R.C.M. 707
Instead, the requested delay should be credited to the Government for speedy trial purposes under Article
l0 of the Uniform Code of Military Justice.


David

David E. Coombs, Esq.

Law Of?ce of David E. Coombs

ll South Angell Street, #3l7
Providence, RI 02906

Toll Free: 56

Local: (508) 689-4616

Fax: (508)689-9282



"?"Con?dentiality Notice: This transmission, including attachments, may contain con?dential attorney-client
information and is intended for the person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be
unlawful and is prohibited."*

Defense_Unclass_Emai|__0923



30641

From: Bouchard. Paul CPT MIL USA OSA



Sent: Wednesday. October 26, 20] l2:0l PM
To: Fein. Ashden PT USA
A
Cc: Matthew kemkes Joshua
CPT MIL US USA
Subject: RE: US v. PFC BM (8-9 Nov 1] Meeting) (UNCLASSIFIED)
Attach: Tenns of

Classi?cation: UNCLASSIFIED


My signed copy of the of our Nov. 8-9 meeting is attached.
I will call you today or tomonow vis-a-vis fotcnsic ncvicw.
Thanks.

Paul

Defense_Unclass_Emai|_0924
A

30642

thanks.

Defense_Unclass_Email_0925

Fain, Ashden CPT USA SJA
Wednesday. October 26, 2011 12:35 PM
Bouchard, Paul CPT MIL USA

Matthew kemkes; Joshua CPT MIL US USA
TRADOC
RE: US v. 11 eetmo) (UNCLASSIFIED)

0221 7226



From: corrmm. cm COL MIL USA IMCOM



Sent: Wednesday, October 26, 201 4237 PM

To:

Cc: Matthew kemkes Morrow JoDean. cm USA
SJA








I-Iaberland,John CPT MIL USA
Overgaard, Angel M. CPT USA

I?ooman,Joshua CPT MIL US USA
Fein, Ashden CPT USA

Subject: RE: US v. PFC BM (Art 32 Delay Request) (UNCLASSIFIED)

Previously Submitted in Encl 78
Previously in Encl 1

Classification: UNCLASSIFIED
Thanks.
Co?man

On I0/25/l 1. courtmartialdefcnsecotn wrote;

Sir.





The defetse maintains its preyious position any additional delay should not be excluded tinder R.C.M. 707(c). Instead the
requested delay should be credited to the Got-cmment for speedy trial purposes under Article I0 of the Unifonn Code of Military
Justice.







David





David E. Coombs Esq.

Law Office of David E. Coornbs

It South Angell Suect. #317

Providence. RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-1616

Fax: (508) 689-9282



rsecom)





??Con?demiality Notice: This transmission. including attachments may contain con?dential attorney-clicm infonnation and is
intended for the person(s) or company named. If you are not the intended recipient. please notify the sender and delete all copies.
Umuthorized disclosure. copying or use of this infomtation may be unlawful and is prohibited!"

Defense_Unclass_Email_0926



02216368

30644

From: Bouchard, Paul CPT USA MIL (Us?

Sent: Wednesday, October 26, 2011 4:5] PM
To: Fein, Ashden CPT USA SJA
Subject: Message from CPT Paul Bouchard (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: FOUO

Ashden:
Give me a call tomorrow when you get a chance. I would like to discuss computer forensics Logistics with you.

Thanks,

Paul

Ciassification: UNCLASSIFIED
Caveats: FOUO

Defense_UncIass_EmaiI_0927

02926351
30645

From: Fein, Ashden CPT USA SJA

sent: Wednesday. Oclober 28, 2011 4:52 PM

To:

Subject: Re: Message ftom CPT Paul Bouchard (UNCLASSIFIED)
No prob. Thx.

Defense_UncIass_EmaiI_0928



02216367

30646

From: Bouchard, Paul CPT USA MIL (US)

Sent: Thursday, October 27, 2011 12:08 PM
To: Fein, Ashden CPT USA SJA
Subject: Please call me, CPT Paul Bouchard (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: FOUO

Ashden:
Please call me when you can. If I'm at lunch, my cell phone number is -

I need particulars on: when will we get the classified data, where the Nov. 8 meeting will be, etc.
Thanks,

Paul

Classi?cation: UNCLASSIFIED
Caveats: FOUO

Defense_UncIass_EmaiI_0929

02923685

30647

From: Fein. Ashden CPT USA JFHQ-NCRIMDW SJA

sent: Thursday. October 27. 2011 12:16 PM

To: Bouchard, Paul CPT USA MIL (US)

Subject: RE: Please call me, CPT Paul Bouchard (UNCLASSIFIED)
Paul,

Calling now. Sorry about the delay. I have been in and out of the office
since yesterday.

Ashden

Defense_Unc|ass_Email__0930

02216366
30648

From: Bouchard, Paul CPT USA MIL (U

Sent: Thursday, October 27, 201 1 2:44 PM

To: Fein, Ashden CPT USA SJA
Subject: Message from CPT Paul Bouchard (UNCLASSIFIED)

Classification: UNCLASSIFIED

Caveats: FOUO

Ashden:

Please call me again. Just want to go over a few things - five minutes tops.
Thanks,

paul

Classification: UNCLASSIFIED

Caveats: FOUO

Defense_Unc1ass_EmaiI_0931

0291 5964

30649

From:
Sent:
To:
Cc:

Subject:

MAJ Kellkes,

Fein, Ashden CPT USA SJA

Thursday. October 27, 2011 2:49 PM

'Kernkes. Matthew MAJ MIL

Morrow JoDean. CPT USA
'Haber1and.John CPT MIL Overgaalu, Angel M. CPT USA JFHQ-NCRIMDW
'Tooman.Joshua CPT MIL US USA

us v. PFC BM (Defense Supplies)

The following items have been purchased/acquired and are ready to be picked

up:
1. Five courier bags (3 large, 2 normal)
2. Printer (Dell 313cm)

3. Shredder (Olympia 671.1CF)

4. open/Close Magnet

5. Pack of SF-704

6. Courier Cards for you and CH2 Santiago

You may pickup these items at your convenience, please call first so wo1 Parra
or SGT waybright can ensure that someone is here to sign over the

supplies/equipment .

V/rs

Ashden

Defense_Unclass_Email_O932



02216365

Previously S?itb?ggted in Encl 1

From: Bouchard, Paul CPT USA MIL (US)

Sent: Thursday, October 27, 2011 3:01 PM

To: Fein, Ashden CPT USA SJA

Subject: Message from CPT Paul Bouchard (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: FOUO

Ashden:

1. When do you think the Defense's computer forensics team (Eric Lakes and Trent Struttmann) will be able to do
their forensics? I know you said you'll have the classified data for us by Nov. 3-4. Just wondering if there's
anything else we'll need for Eric and Trent to do their work.

2. Trent told me Eric already booked their (Eric and Trent's) travel for the meeting on Nov. 8 and possibly the
Flights to BWI, hotel, and car rental come out at $1332.75. They're expecting per diem for food and at cost for
gas. Are you okay with this? Again, they booked it in advance.

Thanks,

Paul

Classification: UNCLASSIFIED
Caveats: FOUO

Defense__Unc|ass_Email_0933

02926350

Previously S?l5J?'giFed in Enci 1

Subject: RE: Message from CPT Paul Bouchard (UNCLASSIFIED)

From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA
Sent: Thursday, October 27, 2011 3:01 PM

To: Bouchard, Paui CPT USA MIL (US)

Paul,

Please call so we can chat.

Defense_Unc|ass_Emai|_0934

Thanks.

02216364

Previously in Encl 1

From: Bouchard, Paul CPT USA MIL (U S)

Sent: Thursday, October 27, 201] 4:04 PM

To: Fein, Ashden CPT USA SJA
Cc:

Santiago, Melissa CW2 USA MIL (U S)
Subject: Message from CPT Paul Bouchard (UNCLASSIFIED)

Classification: UNCLASSIFIED

Caveats:

Ashden:

FOUO

It was good talking to you. Just a few things.

1.

3.
Appreci
Thanks,

Paul

Do you foresee Eric and Trent getting on and off post easily for the Nov. 8 meeting? Both Eric and Trent will
attend the Nov. 8 meeting, and it is my understanding that the meeting will be either at Fort Belvoir or the
Military District of Washington. Eric and Trent will be in a car rental. Do they a need a pass to get on base or a
CAC equivalent for contractors/visitors? If so, will this take a lot of time? Anyway we can streamline the process?
Just want their travel and on/off post access to be efficient.

Computer stuff. I Understand that the Government will give us the classi?ed data by the end of next week. What
I want to ensure is that the data (apparently a hard drive containing all of the pertinent forensic images) includes
ALL of the computers in question. For efficiency and cost-effective purposes, we want Eric and Trent to come to
the DC area once so they can do their forensics. I know lead defense counsel, David Coombs, asked for all of the
computers in the TSCIF. Will we get that ?the forensic images of all of the computers, not just the computer PFC

Manning was assigned to?
Understand the Defense Travel Issue (DTS) issue. Awaiting your e-mail on that.

ate any feedback.

Classification: UNCLASSIFIED
Caveats: FOUO

Defense_Unc|ass_Emai|_0935



02217076

30653

Fr?m= E?c Lakes

Sent: Thursday, October 27, 2011 4:15 PM

To: Bouchard, Paul CPT USA MIL Fein, Ashden

CPT USA SJA

Cc:
Santiago, Melissa CW2 USA MIL (US)



Subject: re: Message from CPT Paul Bouchard (UNCLASSIFIED)

Basically Ashden I am in the DEERS system but Trent is not - we need him entered so you can get us both sponsored so
we can get our Contractors ID Cards before we leave Lexington.

Thanks in advance;

En'c Lakes

Digital Forensic Examiner

Certi?ed Computer Examiner (CCE)
Certi?ed Homeland Security -

MCSE, MCP, Network Pius,
Cyber Agents, Inc.


616 Pasadena Drive

Lexinoton. KY 40503

cell-
land me -





Defense_UncIass_EmaiI_0936

30654



From: Bouchard, Paul acpr us?. MIL

Sent: Thursday. October 27, 201 I 4:20 PM
Fein, Ashden CPT USA SJA



To:

Fein, Ashden CPT USA SJA
Cc:
Subject: Message from CPT Paul Bouchard (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: FOU0

Ashden:

Please respom to e-mail below. Eric is in DEERs but Ttem isn't. This is about the ID issue I0 get on and off post.

Thanks.
Paul

Defense_Unc|ass_EmaiI_0937

30655



From: Fein. Ashden CPT USA SJA

3001: Thursday, October 27. 2011 5243 PM
To: 'Bouchard. Paul CPT USA MIL
Cc: ?Santiago. Melissa 8
CW2 USA MIL Parra, Jairo A. W01 USA SJA
Subject: RE: Message from CPT Paul Bouchard (UNCLASSIFIED)

All- I am preparing a more detailed email, but this should be a non-issue.
All the installations within the National Capital Region allow the public to
drive on post, even with rental cars. More importantly, our meeting on the
7th and 8th will not be a on a military installation, but rather at Metro
Park near Fort Belvoir. More details to follow.

Thanks!

Ashden

Defense_Unclass_Emai|_0938

0291 5538

30656
From: Fein. Ashden CPT USA JFHQ-NCRIMDW SJA
sent: Thursday. October 27. 2011 5:55 PM
To: 'Kemkes, Matthew MAJ MIL 'Bouchand.
Paul CPT USA MIL 'Tooman.Joshua CPT MIL US USA
Cc: Feito, Beatriz SGT USA JFHQ- NCRIMDW Parra, Jairo A. W01 USA JFHQ-
SJA: Morrow JoDean, CPT USA SJA
subject: Us v. PFC BM (Party. Witness, Expen Travel)
Attachments: ITO Worksheetpdf
All-

To facilitate the travel prosecution and defense witnesses and experts, the
OSJA has put in place procedures that should make travel simple and efficient.

For civilian personnel, not associated with this will be accomplish
through DTS. SGT Feito (prosecution paralegal) is authorized to create travel
orders for non-DOD civilians. She must have each traveler's full name, SSN,
address, and banking information and other information in the ITO worksheet
(attached). SGT Feito will directly assist the individual with reservations
for hotel and lodging. Depending on the situation and timing, now, OSJA might
directly pay for the flight rather than the individual paying through DTS.

For all Military or 000 personnel- SGT Feito needs their SSN and she will
X-Org that individual to the proper funding source and they will plan their
travel through DTS.

Bottom line: All travel for experts and witnesses needs to be coordinated
through SGT Feito and Mr. Parra. Mr. Parra is responsible to ensure the
travel occurs and the individuals are paid. Please notify SGT Feito and Mr.
Parra when the travel needs to occur, and they will make it happenl

If you have any questions please contact Mr. Parra (CCed) at?

v/r
CPT Fein

Defense_U nclass_EmaiI_0939



02916504

Previously S?gz?gitted in Encl 1

From: Fein, Ashden CPT USA SJA

Sent: Thutsday. October 27. 2011 10:06 PM

To:

Cc: Matthew kemkes: 'Tooman,Joshua CPT MIL US USA

Momow Ill, JoDean, CPT USA
Overgaam, Ange! M. CPT USA Fond. Arthur D. W01 USA JFHQ-
NCRIMDW ?Melissa Santiago?

Subject: US v. PFC BM
Attachments: 111027-Excludable Delay Memorandumpdf
David,

Attached is the excludable delay accounting memo.

v/r
Ashden

Defense_Unclass_Emai|_0940

02216362

From:
Sent:
To:

Cc:

Subject:

30658

Bouchard. Paul USA MIL (Us)

Friday. October 28. 20] I 9:03 AM

Fcin. CPT USA SJA
Santiago. Melissa 5 CW2 USA


MIL (US) Parra. Jairo A. I USA SJA




RE: Message from CPT Paul Bouchard (UNCLASSIFIED)

UNCLASSIFIED

Caveats: OUO

Thanks,
Paul

Defense_Unc|ass_EmaiI_0941

02216361
30659

From: Bouchard, Paul USA MIL

Sent: Friday, October 28To: Fein. Ashden CPT USA SJA
Matthew kemkes

Tooman, Joshua CPT USA MIL (US









Cc: Feito, Beatriz SGT USA JFHQ- SJA
Parra. Jairo A. WOI USA SJA
Morrow JoDean, CPT USA SJA

Subject: RE: US v. PFC BM (UNCLASSIFIED)

Classi?cation; UNCLASSIFIED

Caveats: FOUO

Thank you CPT Fein:

Do Eric Lakes and Trent Suuttmann have to comply with this for the planned meeting in 10 days given that they already booked their
travel??

Respectfully.

CPT Bouchatd

Defense_Unclass_Emai|_O942

02193065

30660
From: Petra. Jairo A. W01 USA SJA
Sent: Friday. October 28. 2011 9:18 AM
To: Bouchard, Paul CPT USA MIL Fein, Ashden CPT USA

Matthew kemkes: Tooman, Joshua CPT USA MIL


Cc: Feito, Ill. Jooean. CPT USA JFHQ-

rusnnwovv SJA
Subject: RE: US v. PFC BM (UNCLASSIFIED)
Sim-wBv=

Classification: UNCLASSIFIED
Caveats: FOU0

Sir,

The short answer to your question is yes. I will attempt to work with them
to get them reimbursed for the flight, provided it falls under the

guidelines of the JFTR, and ensure that the rest of their TDY is handled in
the appropriate manner. Please have them contact me (information below) or

my NDEA, SGT Beatriz Feito at If you have any further
questions please let me know. an you.

v/r,

JP

Jairo A. Parra

woi, JA

Legal Administrator
JFI-Q-NCR, IVDH





- Blackberry
. - Cell



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attorney-client or attorney work product privileged information.
This information may not be released outside of the Department of Defense
without prior authorization from the Office of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any
action in reliance on this information is prohibited. If you received this
email in error, please notify this office immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and

Defense_Unc|ass_Emai|_0943

02216358

From:
Sent:
To:

Subject:



30661

Bouchard. Paul usA MIL (us)

Friday, October 28, 201 1 9:27 AM

Parra, Jairo A. WOI USA SJA
Fein, Ashden CPT USA A
Matthew kemkes




3

US v. PFC BM (UNCLASSIFIED)

Classi?catiotr UNCLASSIFIED

Caveats: FOUO

Thank you. Clicf.

Eric and Tmm. plcasc comply (see below). Call or c-mail me if necessary.


CPT Bouchald

Defense_Unclass_EmaiI_0944



02216357
30662

From: Bouchard, Paul CPT USA MIL (US)

Sent: Thursday, November 3. 201 1 9:59 AM

To: Santiago, Melissa CW2 USA MIL (US) -

Cc: Fein, Ashden CPT USA
Subject: RE: Information needed for meeting next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: FOUO



Just to tecap - whene exactly will next week's meeting (Go\'emment's case presentation) be -- time. location building. etc. Any
updates appreciaed.
FYI: I'll be in court November 8. so I won?t be at the meeting. but the other members of the Defense Team ill be present.

Note: Please cc our legal administrator. hicl? Santiago. with any updates.


Paul

Defense_Undass_Email_0945



02216356
30663

From: Bouchard, Paul CPT MIL

Sent: Thursday, November 3, 201] 1 1:52 AM

Tm

Cc: Fein, Ashden CPT USA SJA
Subject: RE: FW: Perfect ruling by the Judge! (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: FOUO

Ashden:

Exactly where and when do we meet next week. Need speci?cs. I won't be there on Nov. 8 (US v. Esposito).

Any feedback appreciated.
Paul



From: Eric Lakes

Sent: Thursday, November 2

To: Bouchamd, Paul CPT USA MIL (U

Subject: re: FW: Perfect ruling by the Judge! (UNCLASSIFIED)

Email me the address that we have to go to next week

Eric Lakes

Digital Forensic Examiner

Certi?ed Computer Examiner (CCE)
Certified Homeland Security -
MCSE, MCP, Network Plus,
Cyber Agents, Inc.


616 Pasadena Drive

Lexington, KY 40503

cell-
land -

Classi?cation: UNCLASSIFIED
Caveats: FOUO



Defense_Unc|ass_Email_0946

02930395
30664

From: Fein, Ashden CPT USA SJA

Sent: Thursday, November 03, 2011 12:08 PM

To: 'Bouchard, Paul CPT USA MIL ?Santiago, Melissa CW2 USA MIL

Cc: Morrow JoDean, CPT USA JFHQ-NCRIMDW

SJA
Subject: RE: Information needed for meeting next week (UNCLASSIFIED)
Paul,

Thanks. I will have the final location worked out today and send it out.

Ashden

Defense_UncIass_Emai|_0947

02216354

From:
Sent:
To:
Cc:

Subject:

30665

Bouchard. Paul us?. MIL (us)

Thursday, November 3, 201 1 I227 PM




Fein, Ashden CPT USA SJA
Santiago, Melissa CW2 USA MIL (US)

Morrow JoDean. CPT USA JFHQ-
SJA

RE: Information needed for meeting next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED

Caveats: FOUO

Great. Thanics. Ashden

Paul

Defense_UncIass_EmaiI_O948

02192066

30666
From: Pena. Jaino A. WO1 USA SJA
Sent: Thursday, November 03, 2011 2:04 PM
To: Fein. Ashden CPT USA
Matthew kemkes; 'Bouchard. Paul CPT USA MIL 'Tooman,Joshua CPT MIL US

Cc: Feito. Beatriz - orrow JoDean, CPT USA JFHQ-
SJA
Subject: RE: US v. PFC BM (Party, Witness. Expert Travel) (UNCLASSIFIED)
??gned|By:

Classification: UNCLASSIFIED
Caveats: FOUO

All,

I have not heard anything from any of the Defense Forensic Computer Experts
in regards to their travel. If their travel orders and travel arrangements
are not coordinated a fixed prior to them traveling we cannot ensure that
they will be paid in an appropriate manner. It is important that they
follow the procedures set in place to ensure proper traveling methods and
entitlements are taken care of, and for accountability of funds IAN the
JFTR. Thank you.

v/r,

JP

Jairo A. Parra
N01, JA

Legal Administrator
JFHQ-NCR, vow








- Blackberry
- Cell



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attorney-client or attorney work product privileged information.
This information may not be released outside of the Department of Defense
without prior authorization from the Office of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any
action in reliance on this information is prohibited. If you received this
email in error, please notify this office immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and

Defense_U ncIass_Emai|_0949

0221 7074

From:

Sent:
To:

Cc:

Subject:

30667

Eric Lakes
Thursday, November 3, 2011 2:48 PM

Parra, Jairo A. W01 USA SJA
Fein, Ashden CPT USA SJ A
Matthew kemkes

Bouchard, Paul CPT USA MIL (US)

Tooman Joshua CPT MIL US USA TRADOC






Feito, Beat?z SGT USA JFHQ-


Morrow JoDean(Party, Witness, Expert Travel) (UNCLASSIFIED)

Cyber Agents had already before told bout DTS made our ?ight, hotel and rental car reservations. We now know that for
now on to coordinate all travel through the proper representative.

Eric Lakes

Digital Forensic Examiner

Certi?ed Computer Examiner (CCE)
Certi?ed Homeland Security -
MCSE, MCP, Network Plus,
Cyber Agents, Inc.


616 Pasadena Drive




cell

land me -

Lexinoton. KY 40503






Defense_Unclass_Emai|_O95O



02216353

30668

From: Bouchard. Paul USA MIL

Sent: Thursday, November 3. 201 I 2:56 PM

To: Parra, Jairo A. W01 USA SJA
Fein, Ashden CPT USA SJA
Matthew

Tooman, Joshua CPT USA MIL (US)

kemkes




Subject: RE: US v. PFC BM (Party, Witness. Expen Travel) (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: FOUO

Chief Pam:

We understand your position. however. our forensic team had booked their travel beforehand for the important meeting next week.
From here. we're good to go DTS-wise. but for next week's meeting an exception to policy is in order.

Appneeiate any feewaek and your understanding on this matter.

Respectfull) .

Paul Bouchard
Deferse Coumel

Trial Defeme Services
Fort Meade. MD TDS
Of?oe

Defense_Unc|ass_EmaiI_O951

02216350

From:
Sent:
To:
Cc:

Subject:
Attachments:
signed By:

30669

Tooman. Joshua cP1' usA um
Thursday, November 03, 2011 5:36

Fein, Ashden CPT USA
Matthew kemkes; Morrow JoDean, CPT USA SJA: Bouchand. Paul
CPT USA MIL Habenand, John CPT USA MIL Overgaard, Angel (8-9 Nov 11 Meeting) (UNCLASSIFIED)



I

Classification: UNCLASSIFIED

Caveats FOU0

Ashden

My signed acknowledgment of the terms of next week's meetings is attached.

Sorry For the delay.

v/r
Josh

Defense_UncIass_Emai|_0952

30670

Parra, Jairo A. W01 USA SJA
Thursday. November 03, 2011 7:56 PM

?Bouchard, Paul CPT USA MIL Fein. Ashden CPT USA
coombsgannyoounma Ia ensecom; Matthew kemkes; Tooman,



Joshua CPT USA MIL
subject: RE: US v. PFC BM (Party. Witness. fl rave CLASSIFIED)
sinned Bv=

Classification: UNCLASSIFIED
Caveats: FOUO

A11,

Regardless of current arrangements for travel, I would like to have a
conversation with Mr. Lakes and his team to ensure that his current travel
arrangements fall under the JFTR otherwise, payments might not be able to be
made in their entirety. If you have any questions please feel free to
contact me at your earliest convenience.

v/r.

JP

Jairo A. Parra
N01, JA

Legal Administrator
mu






"1



- Direct
- Blackberry
- Cell

The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attorney-client or attorney work product privileged information.
This information may not be released outside of the Department of Defense
without prior authorization from the office of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any
action in reliance on this information is prohibited. If you received this
email in error, please notify this office immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and

Defense_UncIass_EmaII_0953




0221 7071

30671







Fran? Eric Lakes
Sent: Thursday, November 3, 2011 9:54 PM
To: Parra, airo A. W01 USA SJ A
Bouchard, Paul CPT USA MIL (US)
Fein, Ashden CPT USA SJ A

Matthew kemkes Tooman. Joshua CPT USA MIL
(US)
Subject: RE: US v. PFC BM (Here are the reservations we already booked once we had the set
date)
Flights

2 Round-Trip Tickets
All ?ight times are local to each city.
Please check in with ASA DBA DELTA CONNECTTON on the day of departure for your boarding

pass.

Mon, Nov 7, 2011

Depart: 06:05 am
Arrive: 07:33 am

Online check-in code:

Delta Air Lines, Flight 5364
Economy Class

Operated by

ASA DBA DELTA
CONNECTION

Lexington, KY (LEX)

Atlanta? GA (ATL) Delta Air Lines

Travel time: 1 hr 28 mins
Seat request: 9D, 9A

1 Stop - change planes in Atlanta, GA (ATL)
Connection Time: 1 hr7 mins

Depart: 08:40 am
Arrive: 10:37 am

Atlanta, GA (ATL)
Baltimore, MD (BWI)

Delta Air Lines, Flight 2025

Dena Air Lines Economy Class

Travel time: 1 hr 57 mins
Seat request: 21 E, 21C

Thu, Nov 10, 2011

Depart: 09:00 am
Arrive: 10:32 am

Online check-in code: F61LQD

Airways, Flight 876
Economy Class

Baltimore, MD (BVVI)

Char1otte, NC (CLT) Us

Travel time: 1 hr 32 mins
Seat request: 14D, 15C

1 Stop - change planes in Charlotte, NC (CLT)
Connection Time: 38 mins

Depart: 11:10 am
Arrlve: 12:24 pm

Charlotte, NC (CLT)
Lexington, KY (LEX)

US Airways, Flight 3943
Economy Class

Operated by

US AIRWAYS EXPRESS-
AIR WISCONSIN

xf US Airways

Travel time: 1 hr 14 mins
Seat request: 4F, 4D

Passengers

Frequent Flier Information

Defense_UncIass_Email_0954

02217071

ERIC LAKES
TRENT STRUTTMANN

flight policies
Hotel

1 Room, 3 Nights
Con?rmation number: 3444628067
Hilton Garden Inn BWI Airport

Delta Air Lines:
Delta Air Lines

Contact: ERIC LAKES
Check in: Mon, Nov 7, 2011

1516 AERO DRIVE Check out: Thu, Nov 10, 2011
Linthicum, MD 21090 . - -
1.410.691.0500 1 Bedroom Accessible
Hotel policies

Attention - Hotel Front Desk

This is a pre-paid reservation. Please check your reservation system for payment information.
Pre-paid amount may not include extra fees payable to the hotel at check out.



30672

Car

3 Days

Con?rmation number: R9596170 Driver: ERIC LAKES

Dollar Rent A Car Car type: Economy

Pick-up date: Mon, Nov 7, 2011, 11:07 AM Drop-off date: Thu, Nov 10, 2011, 07:30
Pick-up location: AM

Drop-off location:
Baltimore Washington International Airport

Baltimore Washington lntemational Airport

Hours of operation

Sunday: -
Monday: -
Tuesday: -
Wednesday: -
Thursday: -
Friday: -
Saturday: -



Attention - car Rental Counter

This is a pre-paid reservation. Please check your reservation system for payment information covering time
and mileage. The car pre-paid amount does not include optional items or extra charges associated with the
reservation.

Pricing

Flight Hotel Car $1,063.50
Tax Recovery Charqe Service Fees: $169.35
Flight Hotel Car Total 1 1 $1,232.35
Travel Protection- 2 plans $99.90
Ton?. . . . .

We charged a total of $1 ,332.75 to your Visa??

Defense_Unclass_EmaiI_0954



30673

INSTRUCTIONS FOR PREPARING AND ARRANGING RECORD OF TRIAL
USE OF FORM - Use this form and MCM, 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.
Inapplicable words of the printed text will be
deleted.

8. Matters submitted by the accused pursuant to
Article 60 (MCM, 1984, RCM 1105).

COPIES - See MCM, 1984, RCM 1103(g). The
convening authority may direct the preparation of
additional copies.

12. Advice of staff judge advocate or legal officer,
when prepared pursuant to Article 34 or otherwise.

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.

13. Requests by counsel and action of the
convening authority taken thereon (e.g., requests
concerning delay, witnesses and depositions).

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 38(c)).
5. DD Form 494, "Court-Martial Data Sheet."

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.

14. Records of former trials.
15. Record of trial in the following order:
a. Errata sheet, if any.
b. Index 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 appropriate, action of officer exercising general courtmartial jurisdiction.
f. Exhibits admitted in evidence.

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.

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.

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.

h. Appellate exhibits, such as proposed instructions, 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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