Title: Def Discovery Req, 8 Dec 10

Release Date: 2014-03-20

Text: UNITED STATES OF AMERICAv.Manning, Bradley E.PFC, U.S. Army,HHC, U.S. Army Garrison,Joint Base Myer-Henderson HallFort Myer, Virginia 22211Prosecution Responseto Defense Motion toCompel DiscoveryEnclosure 123 August 2012UNITED STATESREQUESTMANNING. Bradley PFCArmy.-Headquarters and Headquarters Company. US.Army Garrison. Joint Base Myer-Henderson Hall.Fort Myer. VA 222llDATED: 8 December 20101. In accordance with the Rules for Courts-Martial and the Nlilitary Rules of tvidence.Manual for United States. 2008. Article 40. Uniform Code of .\lilitaryJustice. and other applicable law. request for supplemental discovery is ltereby ntade forthe charged offenses iit the case ofllnited States v. Bradley E. Manning.2. The defense requests that the government respond to each item listed in its 29 Octoberand 15 November 2010 discovery requests and the following additional discovery:a) The names and contact information for all govemment investigators wlto haveparticipated or who are presently participating in the investigation of the case. previouslyrequested on 29 October and 15 November 2010. Specifically. contact information forSA Hyung Kim front the Department of Defense and SA Richard Bowen front the ArmyComputer Crimes Unit and an inventory oftlte items seized from the home of Mr. PaulFrancia at 60] Hazelwood Terrace. Rochester. .\ew York l-1609.bl All forensic results and investigative reports by the Department of State regarding theinformation obtained by Wikileaks as referenced by Assistant Secretary ofState forPublic Affairs P.J. Crowley. Additionally. any specific damage assessment by theDepartment of State regarding the disclosures ofthe diplomatic cables by WikiLeaks.Any assessment. report. mail. or document by Secretary ofState Hillary RodhamClinton regarding the disclosures ofdiplontatic cables by Wikileaks. Any report. e-mail.or document discussing the need for the State Department to disconnect access to its filesfrom the govemmenfs classi?ed network.c) All forensic results and investigative reports by the Department of Defense regardingthe information obtained by Wikileaks and the results of any ioint investigation with theFederal Bureau of Investigation (FBI) as referenced by Secretary of Defense Robert Gates. Additionally. an_v speci?c damage assessment by the Department of Defenseregarding the disclosure ofclassifted docuntents and videos. the subject oftltis case. byWiltileaks.Defense Discovery Request PFC Bradley E. Manningd) Any and all documentation related to the Department ofJustice investigation into thealleged leaks by WikiLeaks as referenced by Attorney General ofthe I 'nited States EricH. Holder.e) Any and all documentation related to President Barack H. Obama's order for aninvestigation and a government wide-review ofhow agencies safeguard sensitiveinformation. Additionally. any and all documents related to the steps the administrationis considering regarding these leaks and the nature ofthe criminal investigation underwayinto how the documents were made public as referenced by Robert Gibbs. the WhiteHouse spokesman.f) Any assessment given. or discussions concerning. the Wikileaks disclosures by anymember of the govemment to President Obama. Any e?mail. report. assessment.directive. or discussion by President Obama to the Department of Defense. Department ofState or Department oflustice.g) Any and all documents relating to the Government Task Force created to review thevarious WikiLeaks releases for potentially damaging information prior to the actualreleases. This Task Force apparently had over 130 members reviewing the documentsthat were either released or pending release to determine the possible harm to nationalsecurity.h) The results of any investigation or review by Mr. Russell Travers who has beenappointed by President Obama to head an interagency committee assigned to assess thedamage caused WikiLeaks exposures and to organize efforts to tighten security measuresin government agencies.i) Any and all documentation related to the Pentagoifs review on the policy andtechnological shortfalls that led to the WikiI-eaks disclosures as referenced by Pentagonspokesman Bryan Whitman.j) Any and all documentation related to the Central Intelligence Agency (CIA)investigation of Wikileaks announced by CIA Director Leon Panetta and any internal orexternal memorandums addressing the investigation of Wikileaks. PFC Bradley Manningor the nature ofthe Office of Security?s investigation into these matters.k) Any and all documentation relating to the govemment?s position of taking a hard lineon unauthorized leaks of information. as demonstrated by the prosecutions ofa formerNational Security Agency official. a Federal Bureau oflnvestigation linguist. and a StateDepartment contractor and referenced by CIA Director Leon Panetta. Additionally. anyand all memorandums. e-mails. or other references by Congressmen. Senators. orgovernment officials conceming the disposition ofthis case or the need to punish PFCBradley Manning.Defense Discovery Request PFC Bradley E. Manningl) Any and all documentation. e-mails, or reports given to the Summary Court-MartialConvening Authority, the General Court-Martial Convening Authority, or the Staff JudgeAdvocate concerning the disposition of PFC Bradley Manning's case or the nature of thecharges or possible charges against PFC Manning. Speci?cally, any attempt to in?uencethe independent discretion-of anyone involved in the military justice process.m) Any and all documents or observation notes by employees of the Quanticoconfmement facility relating to PFC Bradley Manning.11) The results of the 15-6 investigation into the govemment?s improper release ofclassi?ed information to the defense. Whether the 15-6 investigating officer looked intothe following additional potential spillage:i. The disc allegedly found in PFC Manning?s Room indicated the contents wereSECRET. A photo of the disk can be found at 000293. Was the title on the diskclassi?ed or not?ii. The photos of the T-SCIF show a map in the background that was partiallyexposed (000301 and 000302).The snapshots of the computer screens in the T-SCIF were exposed. Was thereclassi?ed information being viewed on the screen? (000305 and 000306).iv. The snapshots of the computers had documentation on the table appear to showclassi?ed information. (000333, 000334, and 000335).v. Was the investigating officer made aware of the govemment disclosure of theoriginal ?ve discs to the military defense counsel?3. The defense requests that the government inform the defense counsel if it does notintend to comply with any speci?c provision of this request.4. It is understood that this is a continuing request.5. A copy of this request was served on Trial Counsel by e-mail on 8 December 2010.1 AVID EDWARD C0 ABSCivilian Defense Counsel


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