Title: 1371 Emails in Date Order

Release Date: 2014-03-20

Text: 0UNITED STATES OF AMERICAV.Manning, Bradley E.PFC, U.S. Army,HHC, U.S. Army Garrison,Joint Base Myer-Henderson HallFort Myer, Virginia 22211fiijjii Prosecution Response toDefense Motion to Dismissfor Lack of Speedy TrialEnclosure 110 October 2012EMAIL DATE RECEIVED TIME RECEIVEDUnc|assified_Email_0O01 29-Jul-10 16:35:06Unc|assified_Emai|_0002 29-Jul-10 18:23:34Unc|assified_Emai|_0003 30-Jul-10 20:14:36Unc|assified_Emai|_0004 2-Aug-10 12:36:00Unclassified_Email_0005 3-Aug-10 08:14:08Unclassified_Emai|_0006 3-Aug-10 08:42:00Unc|asslfied_Emai|_0007 3-Aug-10 08:42:02Unc|assified_Email_00O8 3-Aug-10 08:50:51Unc|assified_Email_0009 3?Aug-10 11:06:00Unc|assified_Emai|_0010 4-Aug-10 07:15:43Unclassified_Email_0011 4-Aug-10 10:10:00Unclassified_Email_0012 4?Aug-10 12:11:44Unc|assified_Emai|_0013 4?Aug-10 12:15:00Unc|assified_Emai|_0014 4-Aug-10 14:48:00Unc|assified_Email_0015 5-Aug-10 07:37:00Unclassified_Email_0016 5-Aug-10 14:24:25Unc|assified_Email_0017 6?Aug?10 15:04:48Unclassified_Emai|_0018 8?Aug?10 20:56:00Unc|assified_Email_0019 9-Aug?10 22:34:00Unc|assified_Emai|_0020 9-Aug-10 22:36:00Unc|assified_Email_0021 10-Aug-10 10:06:52Unclassified_Emai|_0022 10-Aug-10 10:11:02Unclassified_Email_0023 10-Aug-10 10:59:55Unclassified_Email_0024 10-Aug-10 22:37:00Unc|assified_Emai|_0025 11-Aug-10 09:27:41Unc|assified_Emai|_O026 11-Aug-10 09:33:00Unc|assified_Emai|_0027 11-Aug-10 13:08:15Unc|assified_Emai|_0028 11-Aug-10 13:14:00Unc|assified_Email_0029 12-Aug-10 07:51:22Unclassified_Email_0030 12-Aug-10 10:54:35Unc|assified_Email_0031 12-Aug-10 17:19:40Unc|assified_Emai|_0032 12-Aug-10 17:47:16Unclassified_Emai|_0033 12-Aug-10 19:00:00Unc|assified_Emai|_0034 12-Aug-10 19:25:00Unc|assified_Email_0035 12-Aug-10 20:11:00Unclassified_Emai|_0036 12-Aug-10 20:12:00Unclassified_Emai|_0037 13-Aug-10 16:56:50Unclassified_Emai|_0038 16-Aug-10 14:26:00Unc|assified_Emai|_0039 16-Aug-10 15:07:48Unclassified_Emai|_0040 16-Aug-10 21:57:28Unc|assified_Emai|_0041 17-Aug-10 17:18:39Unc|assified_Emai|_0042 18-Aug-10 15:57:02Unclassified_Email_0043 19-Aug-10 08:57:27Unclassified_Emai|_0044 19-Aug-10 10:53:45Unclassified_Email__0045 19-Aug-10 11:03:48Unclassified_Emai|_0046 19-Aug-10 12:39:05 EMAIL DATE RECEIVED TIME RECEIVEDUnclassified_Email_0047 22-Aug-10 23:14:00Unc|assified__Emai|_0048 23-Aug-10 14:54:00Unc|assified__Emai|_0049 23-Aug-10 15:27:40Unc|assified_Emai|_0050 24-Aug-10 11:35:18Unc|assified_Emai|_0051 25-Aug-10 10:27:13Unc|assified_Emai|_0052 25-Aug-10 10:53:00Unc|assified_Emai|_0053 25-Aug-10 17:27:40Unclassified_EmaiI_0054 25-Aug-10 19:48:57Unc|assified_Emai|_0055 26-Aug-10 07:06:24Unclassified_Emai|_0056 26-Aug-10 07:25:24Unc|assified_Emai|_0057 26-Aug-10 08:33:34Unclassified_Emai|__0058 26-Aug-10 08:38:30Unclassified_Emai|_0059 26-Aug-10 10:56:48UncIassified_Emai|_0060 26-Aug-10 11:43:42Unc|assified_Emai|_0061 26-Aug-10 11:55:01Unc|assified_Emai|_0062 1-Sep-10 08:48:56Unc|assified_Emai|_0063 1-Sep-10 10:51:05Unc|assified_Email_0064 9-Sep-10 13:52:28Unclassified_Email_0065 10-Sep-10 06:59:10Unc|assified_Email_0066 10-Sep-10 10:25:00Unc|assified_Emai|_0067 10-Sep-10 10:31:52Unc|assified_EmaiI_0068 10-Sep-10 18:12:00UncIassified_EmaiI__0069 10-Sep-10 18:16:46Unc|assified_Emai|_0070 13-Sep-10 13:45:40Unc|assified_Emai|_0071 13-Sep-10 14:04:45Unc|assified_Email_0072 13-Sep-10 18:18:08Unc|assified_Emai|_0073 14-Sep-10 16:28:25Unc|assified_Email_0074 15-Sep-10 13:36:23Unc|assified__Emai|_0075 17-Sep-10 18:51:00Unc|assified_Emai|_0076 18-Sep-10 14:43:50Unc|assified_Email_0077 20-Sep-10 13:53:12Unclassified_Emai|_0078 23-Sep-10 13:25:00Unc|assified_Emai|_0079 24-Sep-10 14:30:13Unc|assified_Emai|_0080 24-Sep-10 15:46:00Unc|assified_Emai|_0081 27-Sep-10 16:09:09Unclassified_Email_0082 28-Sep-10 19:16:12Unc|assified_Email_0083 29-Sep-10 09:56:00Unc|assified_Email_0084 29-Sep-10 12:26:31Unclassified_Emai|_0085 30-Sep-10 15:53:54Unc|assified_Emai|_0086 30-Sep-10 21:45:00Unc|assified_Emai|_0087 1-Oct-10 08:09:41Unclassified_Email_0088 4?0ct-10 11:15:30Unclassified_Emai|_0089 8-Oct-10 10:31:00Unc|assified_Emai|_0090 12-Oct-10 07:47:00Unc|assified_Emai|_0091 12-Oct-10 08:14:39Unc|assified_Emai|_0092 12-Oct-10 11:14:00 EMAIL DATE RECEIVEDTIME RECEIVEDUnclassified__Emai|_0093 12-Oct-10 14:04:00Unc|assified_Emai|_0094 13-Oct-10 20:53:00Unc|assified__Email_0095 14-Oct-10 17:59:33Unclassified_Emai|_0096 14-Oct-10 22:00:00Unc|assified_Email_0097 14-Oct-10 22:01:00Unc|assified_Email_0098 19-Oct-10 10:29:00Unc|assified_Emai|_0099 19-Oct-10 13:47:39Unc|assified_Emai|__0100 20-Oct-10 15:39:25Unc|assified_Emai|__0101 21-Oct-10 08:50:02Unc|assified_Emai|_0102 25-Oct-10 16:33:41Unclassified_Emai|_0103 25-Oct-10 20:59:00Unc|assified_Emai|_0104 26-Oct-10 07:03:29Unclassified_Emai|_0105 28-Oct-10 08:26:00Unc|assified_Emai|_0106 28-Oct-10 17:00:16Unclassified_Emai|_0107 28-Oct-10 18:36:00Unc|assified_Email_0108 29-Oct-10 09:04:00Unclassified_Emai|_0109 29-Oct-10 09:06:14Unc|assified_Email_0110 29-Oct-10 16:05:26Unc|assified_Emai|_0111 29-Oct-10 16:06:00UncIassified_Emai|_0112 29-Oct-10 16:17:19Unc|assified_Email_0113 1-Nov-10 15:29:05Unciassified_Email_0114 1-Nov-10 17:51:24Unc|assified_Emai|_0115 1-Nov-10 21:26:39Unc|assified_Emai|_0116 2?Nov?10 12:29:00Unc|assified_Email_0117 2?Nov?10 19:03:00Unc|assified_Emai|_0118 3-Nov-10 10:58:00Unc|assified_Emai|_0119 3-Nov-10 11:57:52Unc|assified_Emai|_0120 3-Nov-10 17:11:00Unc|assified_Emai|_0121 4-Nov-10 09:51:35Unc|assified_Email_0122 4-Nov-10 16:56:18Unc|assified_Emai|_0123 4-Nov-10 18:04:00Unclassified_Email_0124 5?Nov-10 09:15:00Unc|assified_Emai|_0125 6-Nov-10 14:00:03Unc|assified_Email__0126 8?Nov?10 09:47:28Unc|assified__Email_0127 8?Nov?10 15:49:46Unclassified_Emai|_0128 9?Nov-10 07:30:00Unc|assified_Emai|_0129 9?Nov-10 15:15:13Unc|assified_Emai|_0130 9-Nov?10 16:57:41Unc|assified_Email__013 1 9?Nov-10 17:06:16UncIassified_Emai|_0132 10-Nov-10 13:50:49Unc|assified_Email_0133 10-Nov-10 14:01:16Unc|assified_Emai|_0134 10-Nov-10 21:24:00Unc|assified_EmaiI_0135 11-Nov-10 09:43:00Unc|assified_Emai|_0136 12-Nov-10 15:02:51Unc|assified__Email_0137 12-Nov-10 15:08:42Unc|assified_Emai|_0138 15-Nov-10 14:40:02 EMAIL DATE RECEIVEDTIME RECEIVEDUnclassified_Emai|_0139 16-Nov-10 08:39:00Unc|assified_Email_0140 16-Nov-10 08:48:06Unc|assified_Email_0141 16-Nov-10 10:31:37Unc|assified_Email_0142 16-Nov-10 18:14:00Unc|assified_Emai|_0143 19-Nov-10 19:39:00Unc|assified_Email_0144 22-Nov-10 18:53:00Unc|assified__Emai1_0145 22-Nov-10 21:33:00Unc|assified_Emai|_0146 23-Nov-10 06:44:20Unc|assified_Emai|_0147 24-Nov-10 08:59:56Unc|assified__Emai|_0148 24-Nov-10 09:12:55Unclassified_Emai|_0149 29-Nov-10 13:40:30Unc|assified_Emaii_0150 29-Nov-10 18:26:26Unc|assified_Email_0151 30-Nov-10 13:21:55Unc|assified_Emai|_0152 30-Nov-10 13:33:00Unc|assified_Email_0153 30-Nov-10 18:02:21Unclassified_Email_0154 30-Nov-10 18:03:00Unclassified_Email_0155 30-Nov-10 18:09:17Unc|assified_Email_0156 30-Nov-10 18:34:00Unc|assified_Emai|_0157 30-Nov-10 21:11:00Unc|assified_Emai|_0158 6-Dec-10 15:42:36Unc|assified_Emai|_0159 7?Dec?10 13:58:11Unclassified_Emai|_0160 8-Dec-10 08:51:00Unc|assified_Email_0161 8-Dec-10 19:31:00Unc|assified_Emai|_0162 9-Dec-10 07:47:50Unc|assified_Email_0163 9-Dec-10 23:49:00Unc|assified_Emai|__0164 10-Dec-10 15:34:47UncIassified_Emai|_0165 10-Dec-10 16:55:51Unc|assified_Emai|_0166 12-Dec-10 22:59:00Unc|assified_Emai|_0167 12-Dec-10 23:27:00Unc|assified_Emai|_0168 13-Dec-10 06:47:43Unc|assified_Emai|__0169 13-Dec-10 13:44:20Unc|assified_Emai|_0170 17-Dec-10 08:33:00Unc|assified_Emai|__0171 17-Dec-10 15:29:23Unc|assified_Emai|_0172 20-Dec-10 10:47:35Unclassified_Emai|_0173 20-Dec-10 17:09:43Unc|assified_Email_0174 20-Dec-10 18:53:00Unclassified__Emai|_0175 20-Dec-10 18:59:00UncIassified_Emai|__0176 22-Dec-10 10:14:00Unc|assified_Emai|_0177 22-Dec-10 10:26:20Unc|assified_Emai|_0178 22-Dec-10 10:33:00Unc|assified_Email_0179 22-Dec-10 11:00:17Unc|assified_Emai|_0180 22-Dec-10 19:41:00Unc|assified_Email_0181 23-Dec-10 13:36:34Unc|assified_Emai|_0182 23-Dec-10 13:46:08Unclassified_EmaiI_0183 23-Dec-10 17:24:02Unclassified_EmaiI_0184 27-Dec-10 08:45:53EMAIL DATE RECEIVED TIME RECEIVEDUnclassified_Email_0185 27-Dec-10 09:09:49Unc|assified__Emai|_0186 29-Dec-10 07:54:00Unc|assified_Emai|__0187 29-Dec-10 08:32:00Unc|assified_Emai|_0188 29-Dec-10 10:29:00Unc|assified_Email_0189 29-Dec-10 10:32:00Unclassified_Emai|_0190 29-Dec-10 10:35:00Unc|assified_Email_0191 29-Dec-10 11:57:46Unc|assified_EmaiI_0192 29-Dec-10 16:14:47Unc|assified_Emai|_0193 30-Dec-10 12:04:51Unclassified__Emai|_0194 30-Dec-10 12:07:16Unc|assified_Emai|_0195 2?Jan?11 21:26:00Unc|assified_Emai|__0196 2-Ja n-11 23:07:00Unc|assified_Emai|_0197 3-Ja n-11 10:56:00Unc|assified_Emai|_0198 4?Jan?11 23:48:00Unc|assified_Emai|_0199 5-Jan-11 15:08:07Unc|assified_Emai|_0200 5-Jan-11 15:15:43Unclassified_Email_0201 5-Jan-11 22:55:00Unclassified_Email_0202 5-Jan-11 23:35:24Unclassified_Emai|_0203 6-Jan-11 11:18:57Unc|assified_Emai|_0204 6-Jan?11 18:35:22Unc|assified__Emai|_0205 6-Jan?11 23:48:31Unc|assified_Email_0206 9?Jan?11 19:03:00Unclassified_Emai|_0207 9-Jan-11 20:59:53Unc|assified_Emai|_0208 10-Jan-11 16:42:37Unc|assified_Emai|_0209 10-Jan-11 17:31:00Unc|assified_Emai|_0210 10-Jan-11 22:37:11Unclassified_Email_0211 12-Jan-11 11:55:03Unc|assified_Emai|_0212 12-Jan-11 12:06:59Unc|assified_Email_0213 12-Jan-11 15:04:00Unclassified_Emai|_0214 13-Jan-11 11:51:31Unc|assified_Emai|_0215 13-Jan-11 19:08:00Unc|assified_Emai|_0216 13-Jan-11 19:20:00Unc|assified_Emai|_0217 14-Jan-11 07:56:41Unc|assified_Emai|_0218 14-Jan-11 12:34:44UncIassified_Emai|_0219 19-Jan-11 12:08:00Unc|assified_Emai|_0220 19-Jan-11 12:53:54Unc|assified__Emai|_0221 19-Jan-11 18:12:0019-Jan-11 21:17:06Unc|assified_Emai|_0223 20-Jan-11 20:00:22Unclassified__Emai|_0224 21-Jan-11 08:24:48Unc|assified_Email_0225 21-Jan-11 08:28:00Unc|assified_Email_0226 21-Jan-11 10:17:26UncIassified_Emai|_0227 21-Jan-11 11:13:0021-Jan-11 13:37:49Unclassified_Emai|_0229 21-Jan-11 20:37:00Unc|assified_Emai|_0230 22-Jan-11 09:07:18EMAIL DATE RECEIVEDTIME RECEIVEDUnclassified_Emai|_0231 22-Jan-11 12:32:00Unclassified_Emai|_0232 25-Jan-11 19:16:00Unc|assified_Emai|__0233 25-Jan-11 21:47:00Unc|assified_Email_0234 25-Jan-11 21:50:00Unclassified_Emai|_0235 25-Jan-11 23:04:55Unclassified_Email_0236 26-Jan-11 08:47:00Unc|assified_Emai|_0237 26-Jan-11 09:56:16Unc|assified_Emai|_0238 26-Jan-11 17:48:00Unc|assified_Emai|_0239 27-Jan-11 07:19:08Unc|assified_Emai|_0240 27-Jan-11 08:07:00Unc|assified_Emai|_0241 28-Jan-11 09:03:00Unc|assified_Emai|_0242 31-Jan-11 10:26:00Unc|assified_Emai|_0243 3 1-Jan-11 22:03:00Unc|assified_Emai|_0244 31-Jan-11 22:38:26Unc|assified__Emai|_0245 1?Feb-11 05:48:57Unc|assified_Emai|_0246 1-Feb-11 12:09:04Unc|assified_Emai|_0247 1-Feb-11 12:11:49Unc|assified_Emai|_0248 3-Feb-11 18:57:00Unc|assified_Emai|_0249 3-Feb-11 19:41:00Unc|assified_EmaiI_0250 3-Feb-11 19:49:00Unc|assified_Emai|_0251 4-Feb-11 07:41:47Unclassified_Email_0252 4-Feb-11 08:00:00Unclassified_Email_0253 4-Feb-11 08:30:12Unc|assified_Emai|_0254 4-Feb-11 18:40:52Unc|assified_Emai|_0255 6-Feb-11 23:48:00Unc|assified__EmaiI__0256 7-Feb-11 01:38:31Unc|assified_Email_0257 7-Feb-11 08:34:00Unc|assified_Emai|_0258 7-Feb-11 08:46:03Unc|assified_Email_0259 7-Feb-11 08:49:00Unc|assified_Emai|_0260 7-Feb-11 09:07:00Unc|assified_Emai|_0261 7-Feb-11 13:50:16Unclassified_Emai|_0262 7-Feb-11 14:37:55Unclassified_Emai|_0263 7-Feb-11 17:50:00Unc|assified_Emai|_0264 8-Feb?11 12:50:00Unc|assified_Emai|_0265 8-Feb?11 18:23:00Unc|assified_Emai|__0266 9?Feb-11 05:16:36Unc|assified_Emai|_0267 9?Feb-11 06:48:00Unc|assified_Email_0268 9?Feb-11 07:51:54Unclassified_Email_0269 9?Feb-11 17:47:00Unc|assified__Emai|_0270 9?Feb-11 19:13:32Unclassified_Email_0271 10-Feb-11 14:02:03Unc|assified_Emai|_0272 10-Feb-11 19:49:00Unclassified_Emai|_0273 10-Feb-11 19:51:00Unc|assified_Emai|_0274 11-Feb-11 06:43:25Unclassified__Email_0275 11-Feb-11 06:49:50Unc|assified_EmaiI_0276 14-Feb-11 08:13:00 DATE RECEIVEDTIME RECEIVEDUnc|assified_Email_0277 14-Feb-11 08:44:42Unc|assified_Emai|_0278 14-Feb-11 16:11:00Unc|assified_Emai|_0279 15-Feb-11 10:54:44Unc|assified_Emai|_0280 15-Feb-11 11:57:05Unc|assified_Emai|_0281 15-Feb-11 14:09:43Unc|assified_Emai|_0282 15-Feb-11 23:00:00Unclassified_Emai|_0283 15-Feb-11 23:07:00Unclassified_Email_0284 16-Feb-11 08:07:19Unc|assified_Emai|_0285 16-Feb-11 13:07:21Unc|assified_Emai|_0286 17-Feb-11 17:05: 15Unc|assified_Emai|_0287 17-Feb-11 17:15:35Unc|assified_Emai|_0288 18-Feb-11 11:43:58Unc|assified_Emai|_0289 18-Feb-11 16:31: 19Unc|assified_Emai|_0290 21-Feb-11 19:29:00Unc|assified_Emai|_0291 21-Feb-11 20:50:59Unc|assified_Email_0292 21-Feb-11 21:00:00Unciassified_Emai!_0293 22-Feb-11 12:32:00Unclassified_Emai|_0294 24-Feb-11 07:35:02Unc|assified_Email_0295 24-Feb-11 09:08:36Unc|assified_Emai|_0296 24-Feb-11 11:25:55Unc|assified_Emai|_0297 24-Feb-11 15:49:44Unclassified_EmaiI_0298 24-Feb-11 16:30:21Unc|assified_Emai|_0299 24-Feb-11 16:56:41UncIassified_Emai|_0300 25-Feb-11 07:04:04Unc|assified_Emai|_0301 25-Feb-11 15:01:00Unc|assified_Emai|_0302 25-Feb-11 15:30:00Unc|assified_Email_0303 25-Feb-11 21:23:26Unc|assified__Email_0304 25-Feb-11 21:41:59Unc|assified__EmaiI_0305 26-Feb-11 16:43:00Unc|assified_Emai|_0306 26-Feb-11 16:46:00Unc|assified_Emai|_0307 27-Feb-11 19:24:00nclassified_Emai|_0308 27-Feb-11 21:31:00Unc|assified_Emai|_0309 28-Feb-11 07:20:00Unc|assified_Email_0310 28-Feb-11 10:09:02Unc|assified_Emai|_0311 28-Feb-11 11:29:28Unc|assified_Emai|_0312 28-Feb-11 18:05:20Unclassified_Email_0313 2-Mar-11 12:31:16Unc|assified_EmaiI_0314 2-Mar-11 15:57:00Unclassified_Emai|_0315 2-Mar-11 23:18:00nc|assified_Emai|_0316 3-Mar-11 08:33:24Unclassified_Emai|_0317 3-Mar-11 09:11:22Unc|assified_Emai|_0318 3-Mar-11 14:07:48Unclassified_Emai|_0319 3-Mar-11 20:55:13Unc|assified_Emai|_0320 3-Mar-11 22:12:00Unclassified__Email_0321 3-Mar-11 22:22:00Unclassified_Email_0322 3-Mar-11 22:59:09 EMAIL DATE RECEIVED TIME RECEIVEDUnclassified_Emai1_0323 4?Mar-11 12:56:32Unc|assified_Emai|__0324 4-Mar-11 16:50:44Unc|assified_Emai|_0325 5-Mar-11 11:47:43Unc|assified_Emai|_0326 7-Mar?11 18:18:05Unclassified_EmaiI__0327 8-Mar-11 09:27:32Unclassified_Email_0328 8-Mar-11 23:04:39Unc|assified_Emai|_0329 9-Mar-11 13:22:00Unc|assified_Emai|_0330 9-Mar-11 13:45:20Unc|assified_Email_0331 9-Mar-11 13:59:00Unc|assified_Email_0332 9-Mar-11 16:29:00UncIassified_EmaiI_0333 9-Mar-11 18:01:00UncIassified_Emai1_0334 10-Mar-11 08:38:35Unclassified_Emai|_0335 10-Mar-11 14:16:01Unc|assified_Emai|_0336 10-Mar-11 20:00:00Unc|assified_Emai|_0337 11-Mar-11 08:11:37Unc|assified_Emai|_0338 11-Mar-11 08:44:04Unc|assified_Email_0339 11-Mar-11 14:26:12Unc|assified_Emai|_0340 11-Mar-11 18:58:00Unc|assified_EmaiI_0341 14-Mar-11 07:45:00Unc|assified_EmaiI_0342 14-Mar-11 08:47:00Unclassified_Emai|_0343 14-Mar-11 10:04:39Unclassified_Emai|_0344 14-Mar-11 10:34:02Unclassified_Emai|__0345 14-Mar-11 10:54:00Unclassified_Emai|_0346 14-Mar-11 10:58:00Unclassified_Email_0347 14-Mar-11 11:00:00Unc|assified__Emai|_0348 14-Mar-11 11:10:45Unc|assified__Emai|_0349 14-Mar-11 13:13:00Unc|assified_Emai|_0350 14-Mar-11 13:20:33Unclassified_Email_0351 14-Mar-11 13:23:39Unc|assified_Emai|_0352 14-Mar-11 14:11:00Unc|assified_Emai|_0353 14-Mar-11 14:34:47Unc|assified_Emai|_0354 14-Mar-11 14:50:35Unc|assified_Email_0355 14-Mar-11 15:22:00Unc|assified_Emai|_0356 14-Mar-11 15:22:20Unc|assified_Emai|_0357 15-Mar-11 08:59:00Unc|assified_Emai|_0358 15-Mar-11 09:19:00Unc|assified_Emai|_0359 15-Mar-11 10:10:35Unclassified_Email_036O 15-Mar-11 13:59:00Unc|assified_Email_0361 15-Mar-11 14:15:00Unc|assified_Emai|_O362 15-Mar-11 15:47:00Unc|assified_Emai|_0363 15-Mar-11 16:05:59Unc|assified_EmaiI_0364 15-Mar-11 16:06:00Unc|assified_Emai|_0365 15-Mar-11 20:33:52Unc|assified_Emai|_0366 16-Mar-11 08:23:15Unc|assified__EmaiI_0367 17-Mar-11 07:56:00Unc|assified_Email_0368 20-Mar-11 00:37:00 EMAIL DATE RECEIVED TIME RECEIVEDUnc|assified_Emai|_0369 20-Mar-11 00:42:00Unc|assified_Emai|_0370 20-Mar-11 00:52:00Unc|assified_Emai|_0371 21-Mar-11 03:22:40Unc|assified_Emai|_0372 21-Mar-11 12:53:00UncIassified_Email__0373 21-Mar-11 15:29:00Unclassified_Email_0374 21-Mar-11 19:58:00Unc|assified_Emai|_0375 22-Mar-11 09:58:00Unc|assified_Emai|_0376 22-Mar-11 10:10:00Unc|assified_Emai|_0377 22-Mar-11 10:10:00Unc|assified_Email_0378 22-Mar-11 10:23:35Unc|assified_Email_0379 22-Mar-11 10:49:23Unclassified_Email_0380 22-Mar-11 10:59:00Unc|assified_Emai|_0381 24-Mar-11 14:57:18Unc|assified_Emai|_0382 28-Mar-11 14:25:37Unc|assified_Emai|_0383 28-Mar-11 21:33:00Unc|assified_Emai|_0384 30-Mar-11 08:02:55Unc|assified_Emai|_0385 30-Mar-11 08:06:00Unclassified_Emai|_0386 30-Mar-11 10:02:32Unc|assified_Emai|_0387 30-Mar-11 16:02:26Unc|assified_Emai|_0388 7-Apr-11 09:28:10Unclassified_Emai|_0389 7-Apr-11 10:14:18Unclassified_Email_0390 7-Apr-11 13:30:15Unc|assified_Emai|_0391 7-Apr-11 13:46:38Unc|assified_Emai|_0392 7-Apr-11 20:05:00Unc|assified_Email__0393 8?Apr-11 07:07:00Unc|assified_Email_0394 8-Apr?11 07:21:58Unc|assified__Emai|_0395 8?Apr-11 09:05:11Unc|assified_Emai|_0396 8?Apr-11 09:14:00Unc|assified_Emai|_0397 8-Apr?11 09:34:08Unc|assified_Emai|_0398 8-Apr?11 14:12:24Unclassified_Emai|_0399 8?Apr-11 14:59:00Unc|assified_Emai|_0400 11-Apr-11 13:15:00Unc|assified_Email_0401 12-Apr-11 18:29:00Unc|assified_Emai|_0402 12-Apr-11 19:42:15Unclassified_Email_0403 15-Apr-11 07:58:00UncIassified_Email_0404 15-Apr-11 09:07:55Unc|assified_Email_0405 15-Apr-11 09:20:36Unc|assified_Emai|_0406 15-Apr-11 09:42:33Unc|assified_Emai|_0407 15-Apr-11 09:59:31Unc|assified_Email_0408 15-Apr-11 17:30:00Unc|assified_Email_0409 16-Apr-11 08:31:01Unc|assified_Emai|_0410 18-Apr-11 13:05:34Unc|assified_Emai|_0411 18-Apr-11 15:23:00Unc|assified_EmaiI_0412 18-Apr-11 17:20:30Unclassified_Email_0413 20-Apr-11 09:37:08Unc|assified__Emai|_0414 20-Apr-11 09:38:00DATE RECEIVEDTIME RECEIVEDUnc|assified_Email_O415 20-Apr-11 14:44:36UncIassified_EmaiI_0416 21-Apr-11 09:57:00Unc|assified_Emai|_0417 21-Apr-11 20:51:00Unclassified_Emai|_0418 21-Apr-11 20:56:00Unc|assified_Email_0419 22-Apr-11 09:48:49Unc|assified_Emai|_0420 22-Apr-11 12:07:44Unc|assified_Emai|_0421 22-Apr-11 12:38:00Unc|assified_Emai|_0422 22-Apr-11 12:40:36Unc|assified_Emai|_0423 23-Apr-11 07:55:41Unc|assified_Emai|_0424 23-Apr-11 09:38:00Unc|assified_Emai|_0425 23-Apr-11 09:50:00Unc|assified_Emai|_0426 23-Apr-11 10:04:0023-Apr-11 10:44:27Unc|assified_Emai|_0428 23-Apr-11 12:41:00Unc|assified_Emai|_0429 24-Apr-11 00:38:34Unc|assified_Emai|_0430 24-Apr-11 07:09:20Unclassified_Email_0431 25-Apr-11 13:26:00Unclassified_Emai|_0432 25-Apr-11 14:56:47Unc|assified_Emai|_0433 25-Apr-11 15:08:20Unc|assified_Emai|_0434 25-Apr-11 16:43:00Unclassified_Emai|__0435 25-Apr-11 20:13:21Unclassified__Email_0436 26-Apr-11 15:58:00Unc|assified_Emai|_0437 26-Apr-11 20:16:00Unc|assified_Emai|_0438 26-Apr-11 21:07:59Unc|assified_Emai|_0439 27-Apr-11 14:35:12Unc|assified_Email_0440 28-Apr-11 11:48:40Unc|assified_Emai|_0441 29-Apr-11 09:00:00Unc|assified_Email__0442 29-Apr-11 09:03:00Unclassified_Emai1_0443 29-Apr-11 09:55:36Unclassified_Emai|_0444 29-Apr-11 11:53:00Unc|assified_Emai|_0445 29-Apr-11 12:00:00Unc|assified_Emai|_0446 29-Apr-11 12:04:24Unc|assified_Emai|_0447 29-Apr-11 18:13:00Unc|assified_Emai|_0448 29-Apr-11 18:19:00Unc|assified_EmaiI_0449 2-May-11 13:20:52Unclassified_Emai|__0450 4-May-11 18:18:005-May-11 11:30:55Unclassified_Email_0452 5-May-11 17:24:00Unc|assified_Emai|_0453 6-May-11 13:39:00Unc|assified_Emai|_0454 6-May-11 13:44:00Unc|assified_Emai|_0455 6-May-11 15:42:00Unc|assified_Email_0456 6-May-11 16:01:00Unciassified_Emai1_0457 8-May-11 14:18:42Unc|assified_Emai|_0458 10-May-11 10:14:52Unclassified_Email_0459 10-May-11 14:39: 14Unc|assified_Emai|_0460 11-May-11 07:30:00EMAIL DATE RECEIVEDTIME RECEIVEDUnc|assified_Emai|_0461 11-May-11 09:01:10Unc|assified_Emai|_0462 11-May-11 15:36:00Unc|assified_Emai|_0463 11-May-11 16:00:16Unc|assified__Emai|_0464 11-May-11 18:53:00Unc|assified_Emai|_0465 11-May-11 22:54:00Unc|assified_Emai|_0466 12-May-11 12:10:00Unc|assified_Email_0467 13-May-11 15:42:11Unc|assified_EmaiI_0468 13-May-11 17:18:33Unc|assified_Emai|_0469 18-May-11 08:57:44Unclassified_Email_0470 23-May-11 07:54:55Unc|assified_Emai|_0471 24-May-11 10:38:00Unc|assified_Emai|_0472 24-May-11 11:47:58Unclassified_Emai|_0473 24-May-11 16:57:13Unc|assified_Email_0474 24-May-11 20:45:51Unc|assified_Emai|_0475 25-May-11 16:58:24Unc|assified_Emai|_0476 25-May-11 23:17:39Unc|assified__Emai|_0477 26-May-11 18:21:00Unc|assified_Emai|_0478 26-May-11 18:26:00Unc|assified_Emai|_0479 26-May-11 21:38:00Unclassified_Email_0480 27-May-11 01:17:00Unc|assified_Emai|_0481 30-May-11 10:46:00Unc|assified_Emai|_0482 31-May-11 16:59:35Unc|assified_Emai|_0483 31-May-11 17:15:40Unc|assified_Emai|_0484 3-Jun?11 12:08:00Unc|assified_Emai|_0485 6-Jun-11 10: 16:07Unc|assified_Emai|_0486 6-Jun-11 13:30:00Unc|assified_Emai|__0487 6-Jun-11 17:23:43Unclassified_Email_0488 6-Jun-11 17:43:00Unciassified_Email_0489 7-Jun-11 07:55:52Unc|assified_Emai|_0490 7?Jun-11 08:16:08Unc|assified_Email_0491 7-Jun-11 08:21:00Unc|assified_Email_0492 7-Jun-11 08:23:52UncIassified_Email_0493 7-Jun-11 20:48:00Unc|assified_Emai|_0494 8-Jun-11 11:22:00Unclassified__Emai|_0495 8?Jun?11 11:33:44Unc|assified_Emai|_0496 8-Jun-11 14:48:02Unc|assified_Emai|_0497 8-Jun-11 16:14:20Unc|assified_Emai|_0498 8-Jun-11 16:47:54Unc|assified_Email_0499 8-Jun-11 17:04:17Unc|assified__Emai|_0500 9-Jun?11 15:16:00Unc|assified_Emai|_0501 10-Jun-11 10:10:05Unc|assified_Email_0502 14-Jun-11 21:04:00Unclassified_Emai|_0503 14-Jun-11 21:06:00Unc|assified_Emai|_0504 16-Jun-11 13:51:00Unc|assified_Emai|_0505 16-Jun-11 14:11:10Unc|assified_Emai|_0506 16-Jun-11 18:12:50EMAIL DATE RECEIVED TIME RECEIVEDUnc|assified_Email_0507 17-Jun-11 08:05:00Unclassified_Emai|_0508 17-Jun-11 14:03:06Unclassified_EfI1ai|_0509 17-Jun-11 16:24:35Unc|assified_Email__0510 20-Jun-11 11:59:23Unclassifled_EmaiI_0511 20-Jun-11 18:19:00Unclassified__Emai|_0512 20-Jun-11 21:08:56UncIassified_Emai|_0513 20-Jun-11 21:11:33UncIassified_Email_0514 21-Jun-11 11:27:36Unclassified_Emai|_0515 22-Jun-11 13:29:29Unc|assified_EmaiI_0516 22-Jun-11 18:13:00Unc|assified_Emai|_0517 23-Jun-11 13:10:46Unc|assified_Emai|_0518 23-Jun-11 14:43:00Unclassified_Emai|_0519 24-Jun-11 08:58:20Unclassified__Email_0520 24-Jun-11 13:31:35Unclassified_Email__0521 24-Jun-11 16:53:48Unc|assified_Emai|_0522 27-Jun-11 18:16:00Unc|assified_Email_0523 27-Jun-11 18:24:00Unc|assified_Emai|_0524 27-Jun-11 19:02:00Unc|assified_Emai|_0525 28-Jun-11 10:12:38UncIassified_Emai|_0526 28-Jun-11 12:27:59UncIassified_Emai|_0527 28-Jun-11 12:34:02Unc|assified_Emai|_0528 29-Jun-11 16:56:22Unclassified__Email_0529 29-Jun-11 18:17:00Unclassified_Email_0530 29-Jun-11 18:52:22Unclassified_Email__0531 29-Jun-11 20:37:33Unclassified_Emai|_0532 30-Jun-11 09:05:16Unclassified__Email_0533 30-Jun-11 22:56:00Unc|assified_Email_0534 5-Jul?11 14:03:14Unclassified_Emai|_0535 5-Jul-11 15:19:03Unc|assified_EmaiI_0536 7-Jul-11 02:30:32Unc|assified_Emai|_0537 08:54:15Unc|assified_EmaiI_0538 12-Jul-11 13:47:15UncIassified_Emai|_0539 12-Jul-11 19:46:00Unc|assified_Email_0540 13-Jul-11 16:22:00Unc|assified_Emai|_0541 13-Jul-11 17:33:17UncIassified_Emai|_0542 14-Jul-11 08:23:51Unclassified_Emai|_0543 14-Jul-11 09:54:59Unc|assified_EmaiI_0544 14-Jul-11 12:43:00Unclassified_Email_0545 14-Jul-11 15:30:49Unc|assified_Emai|_0546 15-Jul-11 09:35:37Unclassified_Email_0547 18-Jul-11 10:07:49Unclassified_Emai|_0548 18-Jul-11 13:02:00UncIassified_Email_0549 18-Jul-11 13:40:00Unc|assified_Email_0550 18-Jul-11 14:54:20UncIassified_Emai|_0551 18-Jul-11 14:55:00Unclassified_Emai|_0552 19-Jul-11 15:20:00 EMAIL DATE RECEIVEDTIME RECEIVEDUnclassified_Emai|_0553 21-Jul-11 12:08:50Unc|assified_Emai|_0554 13:26:30Unc|assified_EmaiI_0555 21-Jul-11 14:16:54Unc|assified_Emai|_0556 16:24:55Unclassified_Emai|_0557 22-Jul-11 17:06:13Unc|assified_Emai|_0558 25-Jul-11 09:54:00Unc|assified_Emai|_0559 25-Jul-11 15:20:00Unc|assified_Emai|_0560 25-Jul-11 15:31:36Unc|assified_Emai|_0561 25-Jul-11 17:52:36Unc|assified_Emai|_0562 26-Jul-11 08:10:22UncIassified_Email_0563 26-Jul-11 09:17:00UncIassified_Emai|_0564 26-Jul-11 15:06:30Unc|assified_Emai|_0565 26-Jul-11 21:40:00Unc|assified_Emai|_0566 27-Jul-11 07:48:39Unc|assified_Emai|_0567 27-Jul-11 07:49:00Unc|assified_Emai|_0568 27-Jul-11 09:52:00Unc|asslfied_Email_0569 28-Jul-11 17:15:00Unclassified_EmaiI_0570 28-Jul-11 17:16:00Unc|assified_Emai|_0571 28-Jul-11 17:16:00Unclassified_Emai|_0572 28-Jul-11 17:57:00Unc|assified_Emai|_0573 1-Aug-11 14:53:28Unc|assified_Emai|_0574 1-Aug?11 15:12:59Unc|assified_Emai|_0575 2-Aug-11 19:26:00Unclassified_Email_0576 3-Aug-11 09:01:00Unc|assified_Email_0577 3-Aug-11 09:50:37Unc|assified_Emai|_0578 3?Aug-11 14:41:00Unc|assified_Emai|_0579 3-Aug-11 17:10:10Unc|assified_Emai|_0580 3-Aug-11 17:14:00Unc|assified_Email_0581 4-Aug-11 11:20:20Unc|assified_Email__0582 6-Aug-11 19:32:00Unclassified_Email_0583 7-Aug-11 22:13:51Unc|assified__Email_0584 7-Aug-11 22:30:00Unc|assified_Email_0585 8?Aug-11 07:37:23Unclassified_Email__0586 8-Aug?11 07:42:00Unc|assified_Email_0587 8-Aug-11 08:25:00Unclassified__Emai|_0588 8-Aug-11 08:33:43Unc|assified_Emai|_0589 8-Aug-11 09:03:00Unc|assified_Emai|_0590 8-Aug-11 09:37:54Unc|assified_Emai|_0591 8-Aug?11 10:57:07Unc|assified_EmaiI_0592 8-Aug-11 11:31:43Unc|assified_Emai|_0593 8-Aug-11 14:10:00Unclassified_Emai|_0594 8-Aug-11 14:26:00Unclassified_Emai|_0595 9-Aug-11 08:59:24Unclassified__Emai|__0596 9-Aug-11 13:30:59Unclassified_Emai|_0597 9-Aug-11 15:19:00Unc|assified_Email_0598 11-Aug-11 07:19:00 EMAIL DATE RECEIVED TIME RECEIVEDUnclassified_Emai|_0599 11-Aug-11 08:25:56Unclassified_Emai|_0600 11-Aug-11 14:42:46Unc|assified_Emai|_0601 11-Aug-11 22:09:00UncIassified_Emai|_0602 12-Aug-11 07:20:00Unc|assified_Email_0603 12-Aug-11 14:40:19Unc|assifIed_EmaiI_0604 12-Aug-11 15:49:03Unc|assified_Email__0605 12-Aug-11 16:06:48Unc|assified_Emai|_0606 14-Aug-11 18:58:00Unclassified_EmaiI__0607 14-Aug-11 20:55:00Unc|assified_Emai|_0608 15-Aug-11 07:20:00Unc|assified__Emai|_0609 15-Aug-11 08:05:22Unc|assified_Email_0610 15-Aug-11 13:49:54UncIassified_EmaiI_0611 15-Aug-11 13:53:00Unc|assified_EmaII_0612 15-Aug-11 14:19:00Unc|assified_Email_0613 17-Aug-11 09:09:00UncIassified_Emai|_0614 17-Aug-11 09:45:58Unc|assified_EmaiI_0615 18-Aug-11 08:23:00Unc|assified_Emai|_0616 18-Aug-11 14:55:22Unc|assified_Emai|_0617 18-Aug-11 15:24:02Unc|assified_Email_0618 19-Aug-11 15:59:48Unc|assified_EmaiI_0619 19-Aug-11 17:46:46UncIassified_EmaiI_0620 19-Aug-11 18:51:00UncIassified__EmaiI__0621 22-Aug-11 06:41:00UncIassified_Email_0622 22-Aug-11 13:39:56UncIassified_Email_0623 22-Aug-11 19:07:00Unclassified_Emai|_0624 24-Aug-11 12:51:00Unc|assified_Emai|_0625 24-Aug-11 17:58:00Unc|assified_Emai|_0626 25-Aug-11 21:53:00Unc|assified_EmaiI_0627 27-Aug-11 06:31:29Unclassified_Email_0628 27-Aug-11 19:51:04Unclassified_Emai|_0629 29-Aug-11 07:25:00Unc|assified_Emai|_0630 29-Aug-11 10:33:00Unc|assified_Emai|_0631 29-Aug-11 11:18:00Unclassified__Emai|_0632 29-Aug-11 12:44:00Unc|assified_EmaiI_0633 29-Aug-11 12:49:00Unc|assified_EmaiI_0634 29-Aug-11 19:28:00Unc|assified_Emai|_0635 31-Aug-11 09:21:00Unc|assified_Emai|_0636 31-Aug-11 11:47:00Unc|assified_Email_0637 1-Sep-11 11:13:00Unc|assified_EmaiI_0638 7-Sep-11 20:57:00UncIassified_Email_0639 8-Sep-11 11:19:00Unc|assified_Emai|_0540 8-Sep-11 11:21:00Unc|assified_Emai|_0641 9-Sep-11 13:28:08UncIassified_Emai|_0642 11-Sep-11 13:11:00Unc|assified_EmaiI_0643 12-Sep-11 11:05:53Unc|assified__EmaiI_0644 13-Sep-11 07:53:00 EMAIL DATE RECEIVEDTIME RECEIVEDUnclassified_Emai|_0645 13-Sep-11 08:08:01Unclassified_Emai|_0646 16-Sep-11 13:58:00Unc|assified_Emai|_0647 18-Sep-11 21:20:00Unc|assified_Email_0648 19-Sep-11 09:40:00Unc|assified_Email_0649 19-Sep-11 09:45:29Unc|assified_Email_0650 19-Sep-11 09:52:00Unclassified_Emai|_0651 21-Sep-11 13:52:13Unc|assified_Email_0652 22-Sep-11 18:08:00Unclassified_Emai1_0653 23-Sep-11 10:09:10Unc|assified_Emai|_0654 26-Sep-11 13:12:00Unc|assified_Emai|_0655 26-Sep-11 13:13:00Unclassified_Emai|_0656 26-Sep-11 14:37:01Unclassified_Emai|_0657 26-Sep-11 15:13:32Unc|assified_Emai|_0658 26-Sep-11 15:23:00Unc|assified__Email_0659 26-Sep-11 15:24:33UncIassified_Email_0660 26-Sep-11 17:35:00Unclassified_Email_0661 27-Sep-11 12:27:09Unc|assified_EmaiI_0662 28-Sep-11 16:12:42Unc|assified_Emai|_0663 28-Sep-11 16:58:00Unc|assified__Emai|_0664 28-Sep-11 17:08:00Unc|assified_EmaiI_0665 29-Sep-11 16:39:00Unclassified_Emai|_0666 29-Sep-11 16:42:49Unc|assified_Emai|_0667 29-Sep-11 18:36:56Unclassified_Email_O668 30-Sep-11 08:27:14Unc|assified__Emai|_O669 30-Sep-11 16:26:46Unc|assified_Emai|_0670 2-Oct-11 20:12:40Unc|assified_Emai|_0671 2-Oct-11 23:47:544?Oct-11 17:35:56Unclassified_Emai|_0673 6-Oct-11 15:01:00Unc|assified_Emai|__0674 6-Oct-11 15:03:00Unc|assified_Emai|_0675 6-Oct-11 15:23:00Unc|assified_Email_0676 6-Oct-11 16:01:41Unclassified_Emai|_0677 6-Oct-11 16:24:22UncIassified_Emai|_0678 6-Oct-11 16:28:58Unc|assified_Email_0679 6-Oct-11 16:54:00Unc|assified_Emai|_0680 7?Oct-11 07:00:10Unclassified_Emai|_0681 7?Oct-11 17:22:00Unc|assified_Emai|_0682 7?Oct-11 17:22:00Unclassified_Email_0683 12-Oct-11 08:21:00Unclassified_Emai|_0684 12-Oct-11 08:46:00Unc|assified_Emai|_0685 12-Oct-11 08:46:01Unc|assified_Emai|_0686 12-Oct-11 08:55:39Unc|assified_EmaiI_0687 13-Oct-11 13:09:00Unc|assified_Emai|_0688 13-Oct-11 13:34:53Unclassified_Emai|_0689 17-Oct-11 09:45:30Unc|assified_Emai|_0690 18-Oct-11 09:22:00 EMAIL DATE RECEIVED TIME RECEIVEDUnc|assified_Emai|_0691 19-Oct-11 08:13:40Unc|assified_Emai|_0692 21-Oct-11 07:04:00Unclassified__Emai|_0693 25-Oct-11 18:10:00Unc|assified__Emai|_0694 25-Oct-11 18:14:00Unc|assified_Emai|_0695 25-Oct-11 18:45:00Unc|assified_Emai|_0696 25-Oct-11 18:49:07Unc|assified_Emai|_0697 26-Oct-11 11:51:00Unc|assified_Email_0698 26-Oct-11 16:36:49Unclassified_Emai|_0699 27-Oct-11 11:20:19Unc|assified_Email_0700 27-Oct-11 15:00:51Unc|assified_Emai|_0701 27-Oct-11 15:01:00Unc|assified_Emai|_0702 27-Oct-11 16:04:22Unclassified_Emai|_0703 27-Oct-11 22:06:00Unc|assified_Emai|_0704 28-Oct-11 16:24:24Unc|assified_EmaiI_0705 31-Oct-11 11:09:55Unc|assified_Email_0706 4-Nov?11 18:07:00Unc|assified_Emai|_0707 9?Nov?11 10:58:40Unc|assified_Email_0708 9?Nov?11 11:04:00Unc|assified_Emai|_0709 9?Nov?11 14:09:31Unc|assified_Emai|_0710 9?Nov?11 18:42:00Unc|assified_Emai|_0711 14-Nov-11 11:43:54Unc|assified_Emai|_0712 14-Nov-11 11:49:00Unc|assified_Emai|_0713 15-Nov-11 09:02:55Unc|assified_EmaiI_0714 15-Nov-11 09:05:00Unc|assified_Emai|_0715 15-Nov-11 09:37:00Unclassified_Email_0716 15-Nov-11 10:01:58Unc|assified_Emai|_0717 16-Nov-11 07:26:00Unc|assified_Emai|_0718 16-Nov-11 08:20:48Unc|assified_Emai|_0719 16-Nov-11 14:13:00Unc|assified_Emai|_0720 16-Nov-11 14:23:22Unc|assified_Email_0721 16-Nov-11 14:41:39Unclassified_Emai|_0722 16-Nov-11 17:03:00Unc|assified_Emai|_0723 16-Nov-11 17:25:00Unc|assified_Emai|_0724 16-Nov-11 18:35:25Unclassified_Email__0725 16-Nov-11 18:38:00Unc|assified_Emai|_0726 16-Nov-11 20:26:42Unc|assified_Email_0727 16-Nov-11 20:55:04Unc|assified_Email_0728 17-Nov-11 10:08:25Unclassified_Emai1_0729 17-Nov-11 11:35:00Unc|assified_Emai|_0730 17-Nov-11 12:21:46Unc|assified_Emai|_0731 21-Nov-11 10:05:36Unc|assified_Emai|_0732 21-Nov-11 14:57:00Unclassified_Emai|_0733 22-Nov-11 12:52:00Unc|assified_Emai|_0734 22-Nov-11 17:46:36Unc|assified_Email_0735 22-Nov-11 17:58:54Unc|assified__Email_0736 22-Nov-11 18:15:46EMAIL DATE RECEIVED TIME RECEIVEDUnclassified_EmaiI_0737 23-Nov-11 13:07:23Unciassified_Emai|__0738 28-Nov-11 14:13:53Unc|assified_Emai|_0739 28-Nov-11 22:31:00Unc|assified_Emai|_0740 29-Nov-11 13:36:10Unc|assified_Email_0741 30-Nov-11 11:52:28Unclassified_Emai|_0742 30-Nov-11 22:08:00UncIassified_Email_0743 1?Dec?11 10:15:15Unclassified_Emai|_0744 1-Dec-11 16:30:24Unc|assified_Emai|_0745 1?Dec?11 17:04:11Unc|assified_Emai|_0746 1-Dec-11 18:03:00Unc|assified_Emai|__0747 1-Dec-11 19:02:00Unc|assified_Email_0748 2-Dec-11 09:21:00Unc|assified_Emai|_0749 2-Dlec-11 18:49:00Unc|assified_Email_0750 2-Dec-11 18:50:00Unclassified_EmaiI_0751 2-Dec-11 23:00:56Unclassified_Email_0752 4-Dec-11 11:39:08UncIassified_Emai|__0753 4-Dec-11 12:38:00Unc|assified_Emai|_0754 4-Dec-11 16:44:53Unc|assified_Emai|__0755 5-Dec?11 08:22:00Unc|assified_Emai|__0756 5-Dec?11 20:42:00Unc|assified_Email__0757 5-Dec?11 21:26:00Unc|assified_Email_0758 6-Dec?11 09:41:00Unclassified_Emai|_0759 6-Dec?11 11:32:00UncIassified_Emai|_0760 6-Dec-11 15:40:00Unclassified_Emai|_0761 6-Dec-11 17:47:43Unc|assified_Emai|_0762 6-Dec?11 17:53:00Unc|assified_Emai|_0763 6-Dec-11 17:55:00Unc|assified_Email_0764 6-Dec-11 19:18:00Unclassified_Email_0765 7?Dec-11 17:50:47Unc|assified_Email_0766 7?Dec-11 18:29:00Unc|assified_Emai|_0767 7?Dec-11 19:16:00Unc|assified_Emai|_0768 7-Dec-11 19:22:00Unclassified_Email_0769 8-Dec-11 08:52:53Unclassified_Email_0770 8-Dec-11 10:01:03Unc|assified_Emai|_0771 8-Dec-11 12:56:07Unc|assified_Emai|_0772 8-Dec-11 16:00:00Unc|assified_Emai|__0773 8-Dec-11 16:20:10Unc|assified_Email_0774 9-Dec?11 09:26:10Unc|assified_Email_0775 9-Dec?11 09:34:03Unclassified_Emai|_0776 9-Dec?11 12:04:43Unc|assified_Email_0777 9-Dec?11 13:48:00Unc|assified_Email_0778 9-Dec?11 13:51:47UncIassified_Emai!_0779 9-Dec?11 15:05:29Unc|assified_Emai|_0780 9-Dec?11 15:09:00Unclassified_Emai|_0781 9-Dec?11 17:01:00Unc|assified_Emai|_0782 9-Dec?11 17:19:26EMAIL DATE RECEIVED TIME RECEIVEDnclassified_Emai|_0783 11-Dec-11 18:13:37nclassified_Emai|_0784 11-Dec-11 18:14:00nc|assified_Emai|__0785 11-Dec-11 23:17:24Unc|assified_Emai|_0786 12-Dec-11 17:44:27Unc|assified_Emai|_0787 12-Dec-11 20:59:4712-Dec-11 21:01:00Unc|assified_Email_0789 12-Dec-11 21:42:09Unc|assified_Emai|_0790 12-Dec-11 22:50:00Unc|assified__Email_0791 13-Dec-11 08:37:35Unclassified_Emai|_0792 13-Dec-11 08:55:54UncIassified_Emai|__0793 13-Dec-11 12:18:28Unc1assified_Email_0794 13-Dec-11 16:21:26Unc|assified_Emai|_0795 13-Dec-11 18:45:33Unc|assified_Emai|_0796 13-Dec-11 19:06:38Unc|assified_Emai|_0797 14-Dec-11 06:21:46Unc|assified_Emai|_0798 14-Dec-11 09:07:50Unc|assified_Email_0799 14-Dec-11 10:36:00Unc|assified_Emai|_0800 14-Dec-11 12:34:35Unc|assified_EmaiI_0801 14-Dec-11 13:03:28UncIassified_Emai1_0802 14-Dec-11 13:27: 17Unc|assified_EmaiI_0803 14-Dec-11 13:39:09Unc|assified_Emai|_0804 14-Dec-11 14:34:51Unc|assified_Emai|_0805 14-Dec-11 14:36:00Unc|assified_Emai|_0806 14-Dec-11 16:11:43Unc|assified_Emai|_0807 14-Dec-11 21:47:00Unclassified_Email__0808 14-Dec-11 22:47:20Unc|assified_Emai|_0809 15-Dec-11 11:13:03Unc|assified_Email_0810 2-Jan-12 21:21:00Unc|assified_Emai|_0811 2-Jan-12 21:26:00Unc|assified_Emai|_0812 2-Jan-12 21:28:00Unc|assified_Email_0813 2-Jan-12 21:31:00UncIassified_Email_0814 3-Jan-12 12:34:00Unc|assified_Emai|_0815 4?Jan-12 07:23:00Unclassified_Emai|_0816 4?Jan-12 10:55:00Unc|assified__Emai|_0817 4-Jan-12 16:59:38Unc|assified_Emai|_0818 4-Jan-12 19:01:40Unclassified_Emai|_0819 5-Jan?12 09:43:00Unc|assified_Emai|_0820 6?Jan?12 14:57:00Unc|assified_Emai|_0821 6?Jan?12 15:27:00Unc|assified_Email_0822 6?Ja n-12 17:59:00Uruclassified_Email_0823 6?Jan?12 18:01:00UncIassified__Email_0824 10-Jan-12 10:05:00Unnclassified_Emai|_0825 10-Jan-12 16:21:48Unc|assified_Emai|_0826 10-Jan-12 17:08:00Unc|assified_Email_0827 10-Jan-12 17:18:03Unc|assified_Emai|_0828 12-Jan-12 09:02:51EMAIL DATE RECEIVEDTIME RECEIVEDUnc|assified_Email_0829 12-Jan-12 13:59:00Unc|assified_Emai|_0830 16-Jan-12 15:39:31Unclassified_Emai|_083 1 18-Jan-12 07:29:00Unc|assified_Emai|_0832 18?Jan-12 08:56:11Unclassified_Emai|_0833 18-Jan-12 10:51:00Unclassified_Email_0834 18-Jan-12 19:09:00Unc|assified_Emai|_0835 18-Jan-12 21:30:18Unc|assified_Emai|_0836 18?Jan-12 21:45:00Unc|assified_Emai|_0837 19-Jan-12 09:02:20Unc|assified_Emai|_0838 19-Jan-12 14:47:10Unc|assified_Emai|_0839 19-Jan-12 17:36:44Unc|assified_Emai|_0840 20-Jan-12 14:25:09Unc|assified_Email_0841 20-Jan-12 15:14:00Unc|assified__Email_0842 23-Jan-12 05:44:00Unc|assified__Email_0843 23-Jan-12 09:11:00Unclassified__EmaiI_0844 23-Jan-12 12:21:28Unclassified_Emai|__0845 24-Jan-12 09:11:00Unc|assified_Emai|__0846 25-Jan-12 09:20:00Unc|assified_Emai|_0847 25-Jan-12 11:06:35Unc|assified_Emai|_0848 25-Jan-12 17:23:55Unc|assified_Emai|_0849 26-Jan-12 09:21:33Unclassified_Email_0850 26-Jan-12 11:12:00Unclassified_Emai|_0851 26-Jan-12 13:35:15Unc|assified_Emai|_0852 26-Jan-12 14:00:11Unclassified__Email_0853 26-Jan-12 14:59:08Unc|assified_Emai|_0854 27-Jan-12 17:01:03Unc|assified__Emai|_0855 27-Jan-12 20:56:32Unc|assified_Emai|_0856 30-Jan-12 16:10:46Unc|assified_Emai|__0857 31-Jan-12 10:57:06Unc|assified_Emai|_0858 31-Jan-12 11:56:41Unc|assified_Emai|_0859 31-Jan-12 16:48:00Unc|assified_Emai|__0860 31-Jan-12 17:41:52Unc|assified_Emai|__0861 1-Feb?12 14:13:00Unc|assified_Emai|_0862 1-Feb?12 18:12:00nclassified_Emai|_0863 2-Feb-12 08:30:58UncJassified_Emai|_0864 2-Feb-12 08:51:05Unc|assified_Emai|_0865 2-Feb-12 11:18:00Unc|assified_Emai|__0866 2-Feb-12 11:20:00nc|assified__Email_0867 3?Feb-12 08:03:00nclassified_Emai|_0868 7-Feb?12 07:45:00nc|assified_Emai|_0869 7-Feb?12 13:30:30nc|assified_Emai|_0870 7-Feb?12 18:13:00nc|assified_Emai|_0871 8-Feb-12 14:28:00nclassified__Emai|_0872 8-Feb-12 16:49:23nclassified_Emai|_0873 8-Feb-12 17:16:24Unclassified_Email_0874 8-Feb-12 22:14:00 EMAIL DATE RECEIVEDTIME RECEIVEDUnc|assified_Emai|_0875 8-Feb?12 22:18:16Unc|assified_Emai|_0876 13-Feb-12 10:06:00Unc|assified_Emai|_0877 15-Feb-12 08:28:28Unc|assified_Emai|_0878 15-Feb-12 08:50:01Unc|assified_Email_0879 15-Feb-12 10:24:00Unc|assified__Emai|_0880 15-Feb-12 10:54:33Unc|assified_Emai|_0881 16-Feb-12 10:22:29Unc|assified_Emai|_0882 16-Feb-12 10:27:35nc|assified_Emai|_0883 16-Feb-12 13:40:44nclassified_Emai|_0884 17-Feb-12 08:23:57Unc|assified_Email_0885 17-Feb-12 08:41:09UncIassified_Email_0886 17-Feb-12 11:05:24Unclassified_Email_0887 22-Feb-12 09:02:00Unc|assified__Emai|_0888 22-Feb-12 13:31:23Unc|assified_Emai|_0889 22-Feb-12 16:53:13nc|assified_Emai|_0890 22-Feb-12 17:13:48Unc|assified_Emai|_0891 23-Feb-12 10:42:58Unc|assified_Email_0892 24-Feb-12 17:36:45UncIassified_Emai|_0893 24-Feb-12 17:48:00Unc|assified_Emai|_0894 84-Feb-12 18:27:39Unc|assified_Emai|_0895 24-Feb-12 18:29:39Unc|assified_Emai|_0896 26-Feb-12 19:18:00Unc|assified_Emai|_0897 26-Feb-12 19:26:28Unc|assified_Emai|_0898 26-Feb-12 19:28:00Unc|assified_Emai|_0899 26-Feb-12 19:42:30Unc|assified_Emai|_0900 26-Feb-12 20:53:00Unc|assified_Emai|_0901 26-Feb-12 21:50:14Unc|assified_Email__0902 26-Feb-12 22:31:00Unc|assified_Email_0903 27-Feb-12 00:15:04Unc|assified__Emaii_0904 27-Feb-12 11:30:28Unc|assified_Emai|_0905 27-Feb-12 15:19:37Unc|assified_Emai|_0906 27-Feb-12 16:49:32Unc|assified_Emai|_0907 27-Feb-12 20:52:51Unc|assified_Emai|_0908 28-Feb-12 07:39:00Unc|assified_Emai|_0909 28-Feb-12 10:11:01Unc|assified_Emai|_0910 28-Feb-12 14:18:36Unc|assified_Emai|_0911 28-Feb-12 15:18:37Unc|assified_Emai|_0912 28-Feb-12 18:08:19Unc|assified_Emai|_0913 29-Feb-12 09:10:00Unc|assified_EmaiI_0914 29-Feb-12 10:25:36Unclassified_Emai|_0915 29-Feb-12 10:58:00Unc|assified_Emai|_0916 29-Feb-12 11:16:25Unc|assified_Emai|_0917 29-Feb-12 22:18:00Unc|assified_Emai|_0918 1-Mar-12 08:22:54Unc|assified_EmaiI_0919 1-Mar-12 08:32:00Unclassified_Email_0920 1-Mar-12 09:02:00EMAIL DATE RECEIVED TIME RECEIVEDUncIassified_Emai|_0921 1?Mar-12 10:59:02Unc|assified_Emai|__0922 1?Mar-12 12:22:28Unc|assified_Emai|_0923 1?Mar-12 16:00:36Unc|assified_Emai|_0924 1?Mar-12 19:17:00Unc|assified_Emai|_092S 2-Mar?12 10:33:46Unc|assified_Emai|_0926 2-Mar?12 12:11:38Unc|assified_Emai|_0927 2-Mar?12 12:22:00Unc|assified_Emai|_0928 2?Mar-12 12:53:44Unc|assified__Emai|_0929 5-Mar-12 16:58:00Unc|assified_Emai|_0930 5-Mar-12 17:23:21Unc|assified__Emai|_0931 5-Mar-12 17:51:00Unclassified_Emai|_0932 5-Mar-12 18:07:18Unc|assified_EmaiI_0933 5-Mar-12 18:26:00Unc|assified_Emai|_0934 5-Mar-12 18:27:00Unclassified_Emai|_0935 6?Mar?12 13:46:38Unc|assified_Emai|_0936 6?Mar?12 15:05:00Unc|assified_Email_0937 6?Mar?12 15:09:00Unclassified_Email_0938 6?Mar?12 17:59:37Unc|assified_Emai|_0939 6?Mar?12 18:06:00Unc|assified_Emai|_0940 7-Mar?12 08:21:43Unc|assified_Emai|_0941 7-Mar?12 11:45:16nc|assified_Emai|_0942 10-Mar-12 14:40:01nc|assified_Emai|_0943 11-Mar-12 15:20:13nc|assified_Email_0944 12-Mar-12 08:40:3812-Mar-12 14:56:59Unc|assified_Emai|_0946 13-Mar-12 09:46:18Unc|assified_Emai|_0947 13-Mar-12 09:48:00Unc|assified_Emai|_0948 13-Mar-12 09:51:00Unc|assified__Email_0949 13-Mar-12 10:30:11UncIassified_EmaiI_0950 13-Mar-12 20:17:00Unc|assified__Emai|_0951 13-Mar-12 21:17:09Unc|assified_Emai|_0952 15-Mar-12 19:30:18Unc|assified_Emai|_0953 16-Mar-12 08:28:47Unclassified_Email_0954 17-Mar-12 15:48:26Unc|assified_Emai|_0955 19-Mar-12 15:53:13Unc|assified_Emai|__0956 19-Mar-12 16:20:38Unc|assified_Emai|_0957 19-Mar-12 22:32:00Unc|assified_Email_0958 20-Mar-12 08:50:01Unc|assified_Email_0959 20-Mar-12 09:40:03Unc|assified_Emai|_0960 20-Mar-12 09:45:15Unclassified_Emai|_0961 20-Mar-12 10:24:34Unc|assified_Emai|_0962 20-Mar-12 10:42:38Unciassified_Email_0963 20-Mar-12 10:45:55Unc|assified_Emai|_0964 20-Mar-12 10:57:14Unc|assified_Email_0965 20-Mar-12 12:02:5 1Unclassified_Emai|_0966 20-Mar-12 12:09:03 EMAIL DATE RECEIVEDTIME RECEIVEDnc|assified_Emai|_0967 20-Mar-12 16:46:25nc|assified_Emai|_0968 20-Mar-12 20:08:00Unc|assified_Emai|_0969 22-Mar-12 07:32:00Unclassified_Email_0970 22-Mar-12 08:55:23Unc|assified_Emai|_0971 22-Mar-12 09:50:00Unc|assified_Emai|_0972 22-Mar-12 11:20:30Unclassified_Emai|_0973 22-Mar-12 11:58:00nc|assified_Emai|_0974 22-Mar-12 15:43:27Unc|assified_Emai|_0975 22-Mar-12 16:50:56UncIassified_Emai|_0976 26-Mar-12 09:59:00nc|assified_EmaiI_0977 26-Mar-12 11:56:00Unc|assified_Emai|_0978 26-Mar-12 15:09:20Unc|assified_Email_0979 26-Mar-12 15:10:04Unclassified_Email_0980 26-Mar-12 17:11:46Unc|assified__Email_0981 26-Mar-12 17:12:56Unc|assified_Emai|_0982 27-Mar-12 08:16:01nc|assified_Emai|_0983 27-Mar-12 09:44:00Unc|assified_Emai|_0984 27-Mar-12 09:50:39Unc|assified_Emai|_0985 27-Mar-12 10:05:00nc|assified_Emai|_0986 27-Mar-12 10:24:56nclassified_EmaiI_0987 27-Mar-12 10:41:42ncIassified_Emai|_0988 27-Mar-12 11:14:13Unc|assified__EmaiI_0989 27-Mar-12 13:00:27nc|assified_Email_0990 27-Mar-12 13:00:51Uunclassified_Emai|_0991 27-Mar-12 13 :03 :02Unc|assified_Emai|_0992 27-Mar-12 13:07:16Unc|assified_Emai|_0993 27-Mar-12 17:30:18Unc|assified__Emai|_0994 27-Mar-12 18:52:00UncIassified_Email_0995 27-Mar-12 18:57:44Unc|assified_Emai|__0996 28-Mar-12 08:04:43Unc|assified_Emai|__0997 28-Mar-12 08:12:39Unc|assified_Emai|_998 28-Mar-12 10:16:11Unc|assified_Emai|_999 28-Mar-12 10:41:04Unc|assified_Emai|_1000 28-Mar-12 15:41:07Unclassified_Emai|_1001 28-Mar-12 17:09:28Unclassified_EmaiI_1002 29-Mar-12 07:59:00Unc|assified_Emai|_1003 29-Mar-12 09:50:59Unc|assified_Emai|_1004 29-Mar-12 10:08:18Unc|assified_Email_1005 29-Mar-12 10:11:12Unc|assified_Emai|_1006 29-Mar-12 10:42:12Unc|assified_Emai|_1007 29-Mar-12 12:10:17Unclassified_Emai|_1008 29-Mar-12 12:19:07Unc|assified_Emai|_1009 29-Mar-12 12:21:58Unc|assified_Email__1010 29-Mar-12 12:24:24Unc|assified_Emai|_1011 29-Mar-12 12:45:51Unc|assified_Emai|_1012 29-Mar-12 12:47:33EMAIL DATE RECEIVEDTIME RECEIVEDU|nc|assified_Emai|__1013 29-Mar-12 12:49:02Unc|assified_Email_1014 29-Mar-12 14:17:28nc|assified_Emai|_1015 29-Mar-12 17:33:09nc|assified_EmaiI_1016 29-Mar-12 20:38:00Unc|assified__Emai|_1017 29-Mar-12 20:42:46Unc|assified_Emai|_1018 30-Mar-12 08:21:06Unc|assified_Emai|__1019 30-Mar-12 08:37:00Unc|assified_Emai|_1020 30-Mar-12 08:54:57UncIassified_EmaiI_1021 30-Mar-12 11:07:42UncIassified_EmaiI_1022 30-Mar-12 11:13:10Unc|assified_Emai|_1023 30-Mar-12 11:33:06Unc|assified_Emai|_1024 30-Mar-12 12:18:00Unc|assified__Emai|_1025 30-Mar-12 12:47:07Unc|assified_Emai|_1026 2-Apr-12 08:40:48Unc|assified_Emai|_1027 2-Apr-12 12:13:29Unc|assified_Emai|_1028 2-Apr-12 14:48:06Unc|assified_Emai|_1029 4-Apr-12 08:17:33Unc|assified_Emai|_1030 4-Apr-12 08:58:414-Apr-12 09:09:52Unclassified_Email_1032 4-Apr-12 09:30:39Unclassified__Emai|__1033 4-Apr-12 09:50:29Unc|assified_Emai|_1034 4-Apr-12 10:24:00Unc|assified_Emai|_1035 4-Apr-12 10:44:23Unc|assified_Emai|_1036 4-Apr-12 10:46:05Unc|assified_Emai|_1037 4-Apr-12 11:15:40Unc|assified_Emai|_1038 4-Apr-12 13:54:03Unc|assified_Email_1039 4-Apr-12 13:56:00Unclassified_Emai|_1040 4-Apr-12 13:56:40Unc|assified_EmaiI_1041 4-Apr-12 14:16:19Unclassified_Emai1__1042 4-Apr-12 14:48:04nc|assified_Emai|_1043 4-Apr-12 14:59:40Unc|assified_Emai|_1044 4-Apr-12 15:21:00nclassified_Emai|_1045 5-Apr?12 07:41:43nclassified_Email_1046 5-Apr-12 12:15:07Unc|assified_Emai|_1047 5-Apr-12 12:33:00Unc|assified__Emai|_1048 5-Apr?12 12:47:00Unc|assified__Email__1049 5-Apr-12 12:53:00Unc|assified_Emai|_1050 5-Apr-12 12:58:38Unc|assified_Email_1051 5-Apr-12 13:25:00Unc|assified_Emai|_1052 5-Apr?12 16:53:00Unclassified_Emai|_1053 5-Apr-12 16:59:47Unc|assified_Emai|_1054 5-Apr-12 17:03:00Unclassified__Emai|_1055 5-Apr?12 17:08:00Unc|assified_Emai|_1056 6?Apr-12 08:08:00Unclassified_Email_1057 6-Apr-12 10:41:00Unclassified_Email_1058 6-Apr-12 10:42:11 EMAIL DATE RECEIVED TIME RECEIVEDUnc|assified_Emai|_1059 6?Apr?12 10:47:45Unc|assified_Emai|_1060 6-Apr-12 10:49:15Unc|assified_Emai|_1061 6-Apr-12 11:32:00nc|assified_Email_1062 6-Apr-12 14:49:07nclassified_Email_1063 6-Apr-12 14:57:00nc|assified_Email_1064 6-Apr-12 17:12:00nc|assified_EmaiI_1065 6-Apr-12 17:42:58Unc|assified__Emai|_1066 8?Apr?12 22:16:00Unc|assified_Emai|_1067 9-Apr-12 07:42:32Unc|assified_Email_1068 9?Apr?12 09:06:00Unc|assified_Emai|_1069 9-Apr-12 09:09:00Unc|assified_Emai|_1070 9?Apr?12 10:53:00Unclassified_Emai|_1071 9-Apr-12 10:59:42UncIassified__Emai|_1072 9-Apr-12 11:35:00Unclassified_Email_1073 9-Apr-12 12:22:29Unclassified_Emai|_1074 9-Apr-12 14:29:00Unc|assified_Emai|_1075 9-Apr-12 21:44:00Unc|assified_Emai|_1076 9-Apr-12 22:06:00Unc|assified_Emai|_1077 9-Apr-12 22:08:00Unc|assified_Emai|_1078 10-Apr-12 08:34:00Unc|assified_Email_1079 10-Apr-12 08:46:23Unc|assified_Emai|_1080 10-Apr-12 09:34:51Unc|assified_Emai|_1081 10-Apr-12 10:30:16Unc|assified_Email_1082 10-Apr-12 15:05:23Unc|assified__Email_1083 11-Apr-12 09:09:10Unc|assified_Email_1084 11-Apr-12 09:23:00Unc|assified_Emai|_1085 11-Apr-12 14:56:53Unc|assified_Email_1086 11-Apr-12 15:32:00Unclassified_Email_1087 11-Apr-12 18:37:46Unc|assified_Emai|_1088 11-Apr-12 19:51:05Unc|assified_Email_1089 11-Apr-12 21:19:00Unc|assified_Emai|_1090 12-Apr-12 08:46:00UncIassified_Emai|__1091 12-Apr-12 08:52:00Unc|assified_Emai|_1092 12-Apr-12 08:56:00Unclassified_Emai|_1093 12-Apr-12 09:05:00Unc|assified_Emai|_1094 12-Apr-12 10:25:00UncIassified_Emai|_1095 12-Apr-12 14:39:25Unclassified_Emai|_1096 12-Apr-12 14:42:27Unclassified_Emai|_1097 12-Apr-12 18:30:00Unc|assified_Emai|_1098 13-Apr-12 09:50:00Unclassified__Email_1099 13-Apr-12 17:56:52UncIassified_Emai1_1100 15-Apr-12 22:08:00Unc|assified_Emai|_1101 16-Apr-12 10:28:00Unc|assified_Emai|_1102 16-Apr-12 11:07:00Unc|assified_Emai|_1103 16-Apr-12 11:12:00Unc|assified__Email_1104 16-Apr-12 11:13:27 EMAIL DATE RECEIVED TIME RECEIVEDUnclassified__Email__1105 16-Apr-12 11:20:00Unclassified__Emai|_1106 16-Apr-12 12:05:00Unclassified_Emai|_1107 16-Apr-12 15:52:00UncIassified_Emai|_1108 16-Apr-12 16:24:00Unclassified_Emai|_1109 16-Apr-12 17:01:49Unc|assified_Emai|_1110 16-Apr-12 17:31:00Unc|assified_Emai|__1111 16-Apr-12 17:47:00Unclassified__Emai|_1112 16-Apr-12 18:41:37Unc|assified_Email_1113 17-Apr-12 09:47:00Unc|assified_Email_1114 17-Apr-12 12:11:27Unc|assified_Email_1115 17-Apr-12 17:53:00Unclassified_Emai|_1116 18-Apr-12 09:17:00Unc|assified_Emai|_1117 18-Apr-12 12:50:00Unclassified_Emai|_1118 18-Apr-12 14:44:19Unc|assified_Emai|_1119 19-Apr-12 09:13:00Unc|assified_Emai|_1120 19-Apr-12 09:23:00Unc|assified_Emai|_1121 19-Apr-12 09:28:00Unclassified_Emai|_1122 19-Apr-12 09:29:00Unc|assified_Emai|_1123 19-Apr-12 09:36:00Unc|asSified_Emai|_1124 19-Apr-12 09:42:00Unc|assified_Emai|__1125 19-Apr-12 09:45:00Unc|assified_Emai|__1126 19-Apr-12 10:44:24Unclassified_Emai|_1127 19-Apr-12 11:14:32Unc|assified_Emai|_1128 19-Apr-12 13:47:12Unc|assified_Emai|_1129 19-Apr-12 18:21:51Unc|assified_Emai|_1130 20-Apr-12 11:45:25Unc|assified_Email_1131 20-Apr-12 12:34:09Unc|assified_Email_1132 20-Apr-12 18:44:00Unclassified_EmaiI_1133 20-Apr-12 18:47:00Unc|assified_Emai|_1134 20-Apr-12 18:50:03Unclassified_Emai|_1135 21-Apr-12 11:09:03Unc|assified_Emai|_1136 21-Apr-12 17:39:00Unc|assified_Emai|_1137 21-Apr-12 18:35:32Unclassified_Email_1138 23-Apr-12 10:51:02Unc|assified_Emai|_1139 23-Apr-12 12:38:59Unc|assified__Emai|_1140 23-Apr-12 19:30:00Unclassified__Emai|_1141 24-Apr-12 09:04:27Unclassified_Email_1142 24-Apr-12 20:10:00UncIassified_EmaiI_1143 25-Apr-12 12:40:22Unc|assified_Emai|_1144 30-Apr-12 17:09:59Unc|assified_Emai|_1145 1-May-12 13:22:20Unc|assified_Emai|_1146 1-May-12 15:38:00UncIassified_Emai|_1147 1-May-12 15:58:00Unc|assified_Emai|_1148 2-May-12 08:37:00Unclassified_Emai|_1149 2-May-12 08:42:00Unclassified_Email_1150 2-May-12 08:43:00 EMAIL DATE RECEIVEDTIME RECEIVEDUncIassified_Emai|_1151 2-May-12 08:46:00Unc|assified_Emai|_1152 2-May-12 08:48:00Unc|assified_Email_1153 2-May-12 08:58:00Unclassified_Emai|_1154 2-May-12 09:00:00Unclassified_Emai|_1155 2-May-12 09:08:00Unc|assified_Email_1156 2-May-12 09:21:002-May-12 14:16:00Unc|assified_Emai|_1158 2-May-12 15:02:00UncIassified_Emai|_1159 2-May-12 17:37:30Unc|assified_Emai|_1160 2-May-12 17:39:482-May-12 17:45:00Unc|assified_Emai|_1162 3-May-12 06:59:00nc|assified_Emai|_1163 3?May?12 07:01:00nc|assified_Email_1164 3?May?12 08:04:37Unclassified_Emai|_1165 3?May?12 13:26:43UncIassified_EmaiI_1166 3?May?12 14:12:00Unc|assified_EmaiI_1167 3?May?12 15:42:00Unclassified_Email_1168 3?May?12 18:16:00UncIassified_Emai|_1169 3?May?12 18:18:00UncIassified_Emai|_1170 3?May?12 18:20:00Unc|assified__EmaiI_1171 3-May-12 18:23:00Unclassified_Emai|_1172 3?May?12 18:24:00Unc|assified__Email_1173 3?May?12 18:25:00Unc|assified_Emai|_1174 3?May?12 18:27:00Unc|assified_Emai|_1175 3?May?12 18:28:00Unc|assified_Emai|_1176 3-May-12 18:29:00UncIassified_Emai|_1177 3?May?12 18:30:00UncIassified_EmaiI_1178 3?May?12 18:34:00Unc|assified_Emai|_1179 3-May-12 18:36:00UncIassified_Emai|_1180 3-May-12 18:36:00Unc|assified_Emai|_1181 3-May-12 18:38:00UncIassified_Emai|_1182 3?May?12 18:40:00Unc|assified_Emai|_1183 3?May?12 18:41:00Unc|assified_Emai|__1184 3-May-12 18:44:00Unc|assified_EmaiI_1185 3-May-12 19:19:01Unc|assified_Emai|_1186 4-May?12 06:54:06Unc|assified_Emai|_1187 4-May?12 09:36:00nc|assified_Emai|_1188 4-May?12 15:58:00Unc|assified_EmaiI_1189 4-May?12 16:16:00UncIassified_Email_1190 8-May-12 17:11:49Unc|assified_Emai|_1191 10-May-12 07:01:00U1nclassified_Emai|__1192 10-May-12 08:21:00UncIassified_Email_1193 10-May-12 08:21:08Unclassified_Emai|_1194 10-May-12 08:22:00Unclassified_Email_1195 11-May-12 10:29:00Unc|assified_Emai|_1196 14-May-12 12:19:00DATE RECEIVEDTIME RECEIVEDUnc|assified_Emai|_1197 14-May-12 15:55:00Unc!assified_Email_1198 15-May-12 15:09:29Unclassified_Email_1199 15-May-12 15:14:00Unc|assified_Emai|_1200 15-May-12 15:19:00U|nc|assified_Emai|__1201 16-May-12 14:58:00Unc|assified__Emai|_1202 17-May-12 11:00:03U|nc|assified_EmaiI_1203 18-May-12 15:59:00Unc|assified_Emai|_1204 21-May-12 08:42:00Unclassified_Email_1205 21-May-12 08:45:00Unclassified_Emai|_1206 21-May-12 09:27:00ncIassified_Emai|_1207 21-May-12 18:08:24nc|assified_Emai|_1208 21-May-12 19:06:00nc|assified_Emai|_1209 21-May-12 19:13:28nc|assified_Emai|_1210 21-May-12 21:31:00Unc|assified__Email__1211 22-May-12 10:39:28Unclassified_Email_1212 22-May-12 13:39:00Unc|assified_Emai|_1213 22-May-12 13:40:00Unc|assified_Emai|_1214 22-May-12 18:55:00Unc|assified_Emai|_1215 22-May-12 19:10:25Unc|assified_Emai|_1216 23-May-12 06:51:00Unc|assified_Email_1217 23-May-12 08:09:36Unc|assified_Emai|_1218 24-May-12 09:08:00Unc|assified_Emai|_1219 24-May-12 09:10:00Unc|assified_Emai|__1220 24-May-12 09:18:32Unclassified_Emai|__1221 24-May-12 09:33:00Unc|assified_Emai|_1222 24-May-12 09:35:00Unc|assified_Email_1223 24-May-12 22:25:12Unc|assified_Email_1224 29-May-12 17:09:00Unclassified_Email_1225 30-May-12 07:08:00Unc|assified_Emai|_1226 30-May-12 07:38:52Unc|assified_Emai|_1227 30-May-12 07:40:00Unc|assified_Emai|_1228 30-May-12 10:03:00Unc|assified_Emai|_1229 30-May-12 11:01:07Unc|assified_Emai|_1230 30-May-12 11:12:00Unc|assified_Emai|_1231 30-May-12 16:57:00Unc|assified_Emai|_1232 30-May-12 19:17:25Unc|assified_EmaiI_1233 31-May-12 07:19:00Unc|assified_Emai|_1234 1-Jun-12 19:35:00Unc|assified_Email_1235 2-Jun?12 08:47:01Unc|assified_Emai1_1236 2-Jun?12 12:01:27Unc|assified_Emai|_1237 2-Jun?12 12:07:46Unc|assified_Emai|_1238 3-Jun?12 22:00:27Unc|assified_Email_1239 3-Jun?12 22:00:27Unc|assified_Emai|_1240 3-Jun?12 22:00:27Unclassified_EmaiI_1241 4-Jun-12 09:35:46Unc|assified_Emai|_1242 4?Jun-12 23:08:00 EMAIL DATE RECEIVEDTIME RECEIVEDUnc|assified_Emai|_1243 4-Jun-12 23:12:00Unclassified_Emai|_1244 5?Jun?12 07:58:12Unc|assified_Email_1245 5-Jun-12 08:02:50Unc|assified_Email_1246 11-Jun-12 16:40:51Unc|assified_Emai|_1247 14-Jun-12 14:24:00Unc|assified_Emai|_1248 15-Jun-12 17:44:02Unc|assified_Email_1249 15-Jun-12 18:11:00Unc|assified_Emai|_1250 15-Jun-12 18:30:57Unc|assified_Emai|_1251 18-Jun-12 10:45:00Unc|assified_EmaiI_1252 18-Jun-12 10:51:43Unc|assified_Emai|_1253 18-Jun-12 16:30:56Unc|assified_Email_1254 18-Jun-12 17:20:56UInclassified_Emai|_1255 18-Jun-12 21:29:00Unc|assified_Emai|_1256 18-Jun-12 21:41:58Unclassified_Emai|_1257 19-Jun-12 09:54:00Unc|assified_Emai|_1258 19-Jun-12 11:02:00Unc|assified_Emai|_1259 19-Jun-12 14:33:44Unc|assified_Emai|_1260 19-Jun-12 20:38:00Unc|assified_Emai|_1261 20-Jun-12 07:16:51Unc|assified_Emai|_1262 20-Jun-12 07:53:00Unc|assified_Emai|_1263 21-Jun-12 17:57:00Unc|assified_Emai|_1264 22-Jun-12 21:20:00Unc|assified_Emai|_1265 25-Jun-12 08:37:00Unc|assified_Emai|_1266 25-Jun-12 08:37:36Unclassified_Email_1267 25-Jun-12 11:08:00Unclassified_Email_1268 26-Jun-12 13:59:59UncIassified_Emai|_1269 26-Jun-12 17:05:00Unc|assified_Emai|_1270 26-Jun-12 17:09:00U|nc|assified_Email_1271 27-Jun-12 06:59:00Unclassified_Email_1272 27-Jun-12 15:39:06Unc|assified__Emai|_1273 27-Jun-12 16:01:19Unc|assified_Emai|_1274 27-Jun-12 16:11:00Unc|assified_Emai|_1275 27-Jun-12 17:46:00Unc|assified_Email_1276 13:13:00Ulnc|assified_Emai|_1277 22:58:00Unclassified_Emai|_1278 2-Jul-12 20:14:00Unc|assified_Emai|_1279 5-Jul-12 08:50:54Unc|assified_Emai|_1280 15:04:31Unc|assified_Emai|_1281 6?Ju|?12 14:21:00Unc|assified_Emai|_1282 6?Ju|?12 15:15:00Unc|assified_Email_1283 6?Ju|?12 17:15:09Unclassified_Emai|_1284 9-Jul-12 13:45:02Unc|assified_Emai|_1285 13:49:18Unc|assified_Email_1286 9-Jul-12 14:12:55Unc|assified_Emai|_1287 9-Jul-12 18:28:00Unc|assified_Email_1288 18:40:43EMAIL DATE RECEIVED TIME RECEIVEDUnc|assified_Email_1289 9-Jul-12 19:14:00Unc|assified_Emai|_1290 9-Jul-12 19:20:00Unc|assified_Email_1291 10-Jul-12 11:00:00Unclassified_Email_1292 10-Jul-12 11:37:41Unclassified__Emai|_1293 10-Jul-12 12:22:00Unc|assified_Email_1294 11-Jul-12 12:43:15Unc|assified_Emai|_1295 11-Jul-12 18:00:00Unc|assified_Email_1296 12-Jul-12 09:39:51Unclassified_Email_1297 12-Jul-12 10:32:00Unclassified_Email_1298 12-Jul-12 13:27:42Unclassified_Email_1299 12-Jul-12 18:13:00UncIassified_Emai|_1300 17-Jul-12 20:18:00Unc|assified_Emai|_1301 17-Jul-12 20:19:00Unc|assified_Email_1302 17-Jul-12 20:20:00Unclassified_Emai|_1303 17-Jul-12 20:29:00Unclassified_Email_1304 18-Jul-12 08:01:39Unc|assified_Email_1305 18-Jul-12 08:09:49Unc|assified_Emai|_1306 18-Jul-12 08:33:36Unclassified_Emai|_1307 18-Jul-12 09:39:55Unclassified_Email_1308 18-Jul-12 10:01:23Unclassified_Email_1309 18-Jul-12 23:09:25Unc|assified_Email_1310 19-Jul-12 13:30:19Unclassified_Email_1311 19-Jul-12 15:47:55Unclassified_Email_1312 19-Jul-12 17:15:26Unclassified_Emai|_1313 20-Jul-12 09:53:00Unc|assified_Email_1314 20-Jul-12 10:06:00Unc|assified_Emai|_1315 20-Jul-12 11:53:12Unclassified_Email_1316 23-Jul-12 20:07:00Unclassified_Email_1317 24-Jul-12 07:50:41Unc|assified_Email_1318 24-Jul-12 09:27:44Unc|assified_Emai|_1319 24-Jul-12 09:53:12Unclassified_Email_1320 24-Jul-12 11:19:22Unclassified_Email_1321 24-Jul-12 15:56:45Unclassified_Emai|_1322 24-Jul-12 16:05:00Unclassified_Email_1323 24-Jul-12 16:38:09Unclassified_Emai|_1324 25-Jul-12 16:52:29Unclassified_Email_1325 26-Jul-12 17:49:00Unclassified_Email_1326 27-Jul-12 11:50:46Unc|assified_Email_1327 28-Jul-12 09:08:01Unc|assified_Email_1328 30-Jul-12 07:59:57Unclassified_Email_1329 30-Jul-12 10:29:00Unc|assified_Email_1330 30-Jul-12 15:21:00Unc|assified_Emai|_133 1 3-Aug-12 11:28:48Unclassified_Email_1332 3-Aug-12 12:40:29Unclassified_Email__1333 6-Aug-12 11:53:00Unclassified_Email_1334 6-Aug-12 14:13:00 EMAIL DATE RECEIVED TIME RECEIVEDUnc|assified_Email_1335 6-Aug-12 14:17:29Unc|assified_Email_1336 6-Aug?12 19:12:05Unclassified_Email_1337 6-Aug-12 20:45:24Unc|assified_Emai|_1338 7-Aug-12 12:01:00Unc|assified_Emai|_1339 7-Aug-12 18:42:00Unclassified_Email_1340 10-Aug-12 15:07:54Unc|assified_Email_1341 12-Aug-12 21:10:45Unc|assified_Emai|_1342 13-Aug-12 08:21:00Unc|assified_Emai|_1343 13-Aug-12 18:52:00Unc|assified_Emai|_1344 13-Aug-12 19:27:16Unc|assified_Emai|_1345 14-Aug-12 10:20:56Unc|assified_Emai|_1346 14-Aug-12 14:04:00Unclassified_Emai|_1347 14-Aug-12 14:26:07Unciassified_Emai|__1348 14-Aug-12 17:19:06Unc|assified_EmaiI__1349 15-Aug-12 11:41:18Unc|assified_Emai|_1350 15-Aug-12 21:05:00Unc|assified_Emai|_1351 15-Aug-12 21:10:00Unc|assified_Emai|_1352 16-Aug-12 08:21:00Unc|assified_Email_1353 16-Aug-12 11:30:12UncIassified_EmaiI_1354 16-Aug-12 11:36:00Unc|assified_Emai|_1355 17-Aug-12 12:56:00Unclassified_Emai|_1356 21-Aug-12 12:56:00Unc|assified_Emai|_1357 21-Aug-12 12:57:00Unc|assified_Email_1358 21-Aug-12 19:35:00Unclassified_Emai|_1359 22-Aug-12 18:52:00Unc|assified_Emai|_1360 22-Aug-12 19:03:33Unc|assified_Emai|_1361 27-Aug-12 10:48:03Unc|assified_Email_1362 27-Aug-12 10:49:20UncIassified_EmaiI_1363 28-Aug-12 10:38:00Unclassified_Emai|_1364 28-Aug-12 10:40:00Unc|assified_Emai|_1365 28-Aug-12 10:53:00Unc|assified_Emai|_1366 28-Aug-12 15:50:00Unc|assified_Emai|_1367 28-Aug-12 16:21:00UncIassified_Email_1368 29-Aug-12 14:31:11Unc|assified_Email_1369 4-Sep-12 09:39:00Unc|assified_Emai|_1370 11-Sep-12 09:11:00Unclassified_Emai|_1371 11-Sep-12 13:51:00 02213011 From: USA OTJAG ?O;conus.army.mil]Sent: Thursday, July 29, 2010 4:35 PMTo: Fein Ashden CPT USA smicuvUSA OTJAGCc: A MIL USA JAGSubject: POCs for Manning Case (UNCLASSIFIED)Categories: Blue CategoryGreetings All-This e-mail serves to link up the various parties working on the Manningcase.CPT Ashden Fein is the Chief of Military Justice at Mow, He is the lead counsel on the case.is theUS Army Criminal Investigation Command, .-153the case,Computer Crime Investigative Unit, working on is the OTJAG,is a?with D03, National Security Division, ice 0 Ju ge A vocate General 02877948 -From: Fein, Ashden CPT USA SJAMonda Auaust 02. 2010 12:36 PM Robinson. Bruce H. CPT USA SJAunponance: rugnSir. Good afternoon. Now that PFC Manning is Fully on board, we have some immediate issuesto bring to you in the form of paperwork for signature. Are you available send an intern (CPT Bruce Robinson) over to you to get a signature. If it?s okwith you, I can discuss with you over the phone what it is that you will be presented andthen you can decide what action you want to take. Unfortunately, our timeline is incrediblycompressed as I will explain later. Thank you.v/rAshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MUN) 02206533From: Rose, Luke CPT USD-C SJA Chief, Military Justice Sent: Tuesday, August 3, 2010 8: l4 AMTo: @state.gov'@usd0i gov?;Fein, Ashden CPT USA SJA Subject: Manning phone call (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUO I'm in Iraq with_ an? Do]. We'd like to initiate a phone call with you when you get in thismorning and are available. Please let me know a good number and time and we'll place the call. Thanks.r,LUKE ROSECPT, JAChief of Military Justice1st Armored Division andUnited States Division - CenterClassi?cation: UNCLASSIFIEDCaveats: FOUO02882533From: Fein, Ashden CPT USA SJASent: .2010 8:43 AMTo: Rose Luke CPT USD-C SJA Chief, Military JusticeCc: @usdoj.govIFIED)Subject: RE: Manmng phoneIF possible, can we conference 3-way? I should be able to initiate and set this up. Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington 02188854Sent: Tuesday, August 3, 2010 8:42 AMTo: Rose, Luke CPT USD-C SJA Chief, Military Justice Cc: gov; Fem.Ashden CPT USA SJASubject: RE: Manning phone call (UNCLASSIFIED)I'm free from now until 10 EDT. My open line is?. My STE is? Happy to take a callanytime from now to 10. Best, - 02206530From: Rose, Luke CPT USD-C SJA Chief, Military Justice Sent: Tuesday, August 3, 2010 8:51 AMTo: Fein, Ashden CPT USA JFH SJA a)state.gov>Cc Subject: RE: Manning phone call (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: OUOPlease initiate. We are standing by. 02872814From: Fein, Ashden CPT USA SJASent: Tuesday, August 03. 2010 11:07 AMTo: Cc:Subject: er anmng)Attachments: Charge Sheet (ManningB).pdf. RCM 706 Order (ManningB).pdfknponance: Sir,Good morning. Attached is a RCM 786 Board Order for PFC Bradley Manning. Attached is theorder and a copy of the charge sheet. Cced on this email are the defense counsel (CPTBouchard, CPT Eaton, and MAJ Hurley). Please advise of any delays and if your office needsadditional time than the allotted suspense, please forward the request through me for theconvening Authority.V/rCPT FeinAshden FeinCDT, JAChief, Military JusticeU.S. Army Military District of Washington (Mow) 02206514From: Rose, Luke CPT USD-C SJA Chief, Military Justice Sent: Wednesday, August 4, 2010 7:16 AMTo: USA OTJAG Cc: Fein, Ashden CPT USA SJA Subject: RE: RE: Request for Assistance (UXICLASSIFIFD)Classi?cation: UNCLASSIFIEDCaveats: NONESir.Is there a time this morning that we can have a conference call? Do] attomeys are here with me in Iraq and I think CPT Fcin shouldbe able to call from MDW. I'd like to discuss the prospect of getting classi?cation reviews of additional rnaterialV/r.LUKE ROSECPT. JAChief of Military JusticeArmored Division andUnited States Division - Center02870086From: Fein, Ashden CPT USA SJASent: Wednesda Au us! 04, 2010 10:10 AMTo: CIV USASubject: RE: Team Manning (UNCLASSIFIED)I appreciate it. For now, I would like to stick with you and the CCIU guys to get the rawdata dump and talk about issues. Then figure out the next step meeting with FBI, DOS, andD00. My intent is to get my head around all this and then come up with a plan of attack(prosecution). For now, we just need to know what is out there and the story behind the caseas oF Friday.Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of washington (Mow) 02221964From: Sweda, Michael Dr CIV USA MFDCOM WRAMCSent: Wednesday, August 4, 2010 l2: l0 PMTo: Fein, Ashden CPT USA SJA aton, Michael CPT USF-I SJ A Trial DefenseMorrow.wean CPT Mun Lange. i. weMll. USA MEDCOM WRAMC Montalbano, PaulDr CW USA Malone, Ricky COL MIL MEDCOM VVRA-W7 R15: RCM 706 ()rder (PFC Manning) (UNCLASSIHED)Classi?cation. Caveats: NONECPT Fein:I have consulted with LTC Christopher Lange. who is my counterpan asDirector of the Forensic Ps_v'cliiati_v Fellowship. regarding the Manningcase. We are in the process of assembling 21 team for the evaluation.and expect the direct evaluation piece (interview and testing) ofthisto be completed in two weeks. Genemll). we ask for at least a six weeksuspense date for completion ofa 706 repon. In the case of PFCManning. we would like to request a three month suspense from the datethat he is first seen. to allow fora thorough evaluation.Please feel free to call or e-inail if you have any questions.v/ r.Michael Sweda. Pli.D.. ABPP (Forensic)Board-(Tenlfied Forensic Chief. Forensic Ps_vcholog_v= ServiceDirector. Forensic Ps_vcholog_v Fellowship Walter Reed Anny Medical Center "The United States themselv-?es are essentially the greatest poem.Past and present and future are not disioined but Joined."From: Hurley. Thomas MAJ Mll. USA OTJAG Sent: 4 PMugust . .To: Fern. Ashden CPT USA Sweda. Michael Dr USAMEDCOM WRAMCCc; F.'ll0ll. Michael l. CPT USF-I ATna ense ttornc_v; Morrow. CPT MILUSASubject: RF. RCM 706 Order(PFC 02221960 Classification UNCLASSIFIEDCaveats: NON F.Dr. Sweda/C PT FeinThere is no need for the members ofthc board to have a securityclearance.I will speak with PFC Manning toinormw about the board and ensure thathisanswers to your questions do not include any classi?ed infonnation. Ifhefeels he must disclose classi?ed infonnation then he will let you knowthat there is more that he wants to say but cannot. CPT Fein and I willthen seek an exception to the cunent order.v/ Thomas F. HurleyMAJ. A Message From Fein. USA SJAImai!I.9.Sent: We nesday. . ugust . (H0 .1To. Sweda. Michael 0 Dr USA MEDCOM WRAMCCe: Hurley. Thomas MAJ MIL USA OTJAG:Faton. Michael PT SJ A Trial Defense Attomey; Morrow. JoDean CPT Mll. USAJCCII Manning) (UNCLASSIFIED)Sir. I do not foresee the need; howeverl rather defer that answer to MAJHurleyand the defense team. There is one caveat. A current protective orderisin place and it does not authorize the disclosure of any oftheclassi?edrelated to this case without affiniiative authorization. Soifthere ends up being a need. although doubtful. then the willneedto work to get an exception to the protective order.v/rCPT FeinFeinCPT. AChief. Military JusticeU.S. Anny Military District of Washington (MDW) Front: Sweda. Michael Dr CIV USA MEDCOM WRAMCnt: ne ugust04. l2:lO PMTo: FeirL CPT USA SJACc: Hurlev. Thomas MAJ MII. USA OTJAG. .02221960Eaton. Michael CPT SJ A Trial Defense Attomey; JCCII .: I rder (PFC Classi?cation: UNCLASSIFIEDCaveats: NONESir:Will the sanity board members require any level of security clearanceforthis??v/ r.Michael Swoda. ABPP (Forensic)Board-Certi?ed Forensic Chief. Forensic ServiceDirector. Forensic Fellowship Walter Reed Amty Medical Center "The United States themselves are essentially the greatest poem.Past and present and future are not disjoined but joined."From: Fein. Ashden CPT USA SJASent.Tues y.August0.. 01 II: ATo: Sweda. Michael Dr CIV USA MEDCOM WRAMCCc: Hurley. Thomas MAJ Mll. USA OTJAG:Rose. Luke CPT USD-C SJA Chief. MilitaryusticeSubject: RCM 706 Order (PFC Manning)Importance: HighSir.Good morning. Attached is a RCM 706 Board Order for PFC BradleyManning.Attached IS the order and a copy of the charge sheet. on thisemailare the defense counsel (CPT Bouchard. CPT Eaton. and MAJ Hurley).Pleaseadvise of any delays and if your office needs additional time than theallotted suspense. please forward the request through me or theConveni ngAuthority.CPT Fein02221960Ashden FeinCPT. JAChief. Military JusticeAnny Military District of Washington (MDW)?1Classi?cation Caveats: NONEClassi?cation UNCLASSIFIFDCaveats: NONEClassi?cation; UNCLASSIFIEDCaveats: NONE02874426From: Fein, Ashden CPT USA SJASent: Sunday. August 08, 2010 8:57 PMTo; Morrow, JoDean CPT MIL Eaton, Michael CPTusr=-I SJ A wmrley, Thomas MAJ MIL USA OTJAGSubject: anningGentlemen,Although email addresses are going to be changing in the near future, please ensure allemails to Government counsel include Fein, Morrow, Haberland, and Rose. I am going to try tosetup a generic account that will allow all emails to funnel to each of us with one address.This week, all government counsel (including Rose) will be at MDN.In the next two days, I would like to discuss, at a minimum, the following issues:1. Dr. Sweda's request for three months to complete the RCM 796.2. Any additional requirements the defense has for the Sanity Board (re: MAJ Hurley phoneconversation with me last week), so that we can get those Possible defense "objections" or "requests" to/for the Classified InformationProtective Order (re: MAJ Hurley phone conversation with me last week).4. A renewed defense delay for the Art 32, in light of the deployed counsel not beingpresent and the original request to delay the Art 32 until the completion of the RCM 766 (re:MAJ Hurley phone conversation last week and IQ defense counsel discussions with Roseanswer on potential delays so he can officially set the date and timefor the Art 32.S. Defense's request for a "number" to start negotiating a potential deal.of course we are always available to chat. Once we get settled in our new offices and getthe POC information hammered out, I will publish a Government POC list for you.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN) 02874422From: Ilein, Ashden CPT USA SJASent: Monday, August 09, 2010 10:34 PMTo: Fain, Ashden CPT USA ?Morrow. JoDean CPT MIL Eaton, Michael CPT USF-I SJ A Trial Defenseomey; a a IL Huney, Thomas MAJ MIL USA OTJAGSubject: RE: PFC ManningMAJ Hurley,Below recaps our conversation earlier in reference to our previous email:1. The Defense will decide by tonight whether they plan on requestingadditional tests or focuses for the RCM 766.2. The Defense agrees that the Sanity Board should be given a suspenseof 6 weeks to fully complete their evaluation and the United States willrecommend to the to extend the suspense to 6 weeks from the date ofthe action (in the next few days). The United States will also recommend tothe that he specify that the Sanity Board may request more time, butonly after consulting the Defense and United States and submitting theextension request in writing. The Defense and United States agreed that itis unneeded to ask/recommend the to order the Sanity Board to releasethe prosecution's results to the Defense prior to release to the UnitedStates; however the defense agreed that any objection will be relayed to theUnited States with an explanation of the objection.3. The Defense will submit an additional delay for the Art 32 to beheld after the Sanity Board is complete. The defense will do this by C08tomorrow so that the Art 32 ID will know that he will need to reschedule theArt 32 after the acts on the defense delay.4. The Defense will submit to the United States any "objections" or"requests" to/for the Classified Information Protective Order NLT Friday (13Aug 10).CPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN) 02881964From:SentTo:Cc:Subject:Sir,Fein, Ashden CPT USA SJAMonday. August 09, 2010 10:37 PMAlmanza. Paul; Morrow, JoDean CPT MIL Eaton.Michael CPT USF-I SJ A Trial Defense Attorney; a Hand. John CPT MIL Huney, Thomas MAJ MIL USA OTJAGnmmerman. ara . SA JFHQ- Autry, Carolyn Ms CIV JFHQ-Egan. MichaeI CIV SJARE: Adicle 32 (PFC Manning)The United States and Defense spoke today and we anticipate a delay requestto be submitted to the in the next few days, which will effectivelypush the Art 32 to the right.v/rCPT FeinAshden FeinCPT, JAChief, Military Justice U.S. Army Military District of Washington (MON) ?e02216953From: Huriey, Thomas MAJ MIL USA OTJAG Sent: Tuesday, August 10, 2010 10:07 AMTo: Sweda, Michael Dr CIV USA MEDCOM WRAMCCc: Fein. Ashden CPT USA Bouchard. Paul R. CPT USD-C DSTB COTDS Sr Defense Counsel; Eaton, Michael CPT USF-I SJ A Trial Defense AttorneySubject: RE: RCM 706 Order (PFC Manning) Signed By:Classification: UNCLASSIFIEDCaveats: NONEDr. SwedaI am one of PFC Manning's defense counsel. I know we all (the attorneys forboth parties) appreciate your prompt attention to this matter, and I knowthat we all want a thorough evaluation of PFC Manning that follows the ordersigned by COL Coffman on 3 August. However, we (the defense) would be muchmore comfortable with an initial six week suspense. If, at the end of thatsix weeks, you need more time to complete a thorough evaluation, then wewould request that you forward a request for an extension that estimates thetime required to complete the process.PFC Manning is in pre-trial confinement, and we want to get his casereferred to trial sooner rather than later.On a substantive note, we believe the order signed by COL Coffman issufficient for the charges now preferred. There are no other additionalquestions we want you to answer in the course of completing this matter.Thanks.v/rThomas F. HurleyMAJ, JA02216950From: Hurley, Thomas MAJ MIL USA OTJAG Sent: Tuesday, August 10. 2010 10:11 AMTo: Fein, Ashden CPT USA Morrow. JoDean CPT MIL Eaton, Michael CPT USF-I SJ A Trial Defenseorney; a an Subject: RE: PFC Manning (UNCLASSIFIED)Signed By: Classification: UNCLASSIFIEDCaveats: NONECPT FeinYour email below is a fair representation of what we discussed on the phoneyesterday. You can see from my email to Dr. Sweda that we are "on board"already with those matters discussed in paragraphs 1 and 2. I will getthose other matters to you IAW the timeline you described below.Thanks.V/rThomas F. HurleyMAJ, JA 02221954From:Sent:To:Cc:Subject:Sweda. Michael Dr USA MEDCOM Tuesday. August I0, ZOIO 1 00 AMHurley. Thomas MAJ MIL USA OTJAG Fein. Ashden CPT USA SJAEaton, Michael A Trial DefenseLangc, Christopher LTC MIL USA. Benesh. Samantha Hemphill, Marla MEDCOM WRAMCMll. USA MFDCOM MAMCMIL USA MEDCOM BAMCRE RCM 706 Order (PFC Manning) (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDaveats: NONEMAJ HurleyWe ill proceed illi this pleui tn (initial eck suspense date).It is therefore likel} that no will need an and ?ill sorequest along with an estimated time to completion if/ulicti needed.Please note that due to scliedtiling coii?icts. we will begin on 27 August. Please provide all standard relcvaiit documents relates to?mo evaluations. report ofcnininal inxestigation. mentalrecords. ERB. etc This be sent courier (FedEx orsimilar semcci to:Michael Chief. Forensic SemceWalter Reed Army Medical (?enter6900 Georgia NW0 (Borden Pat ilton). 3rd FloorWashington DC 2030'.?Michael Sticda. Pli.D.. ABPP (Forensic)Board-Certi?ed Forensic Chief. Forensic Service Director. Forensic Ps}cholog_\ Walter Reed Ann} Medical Center"The United States are the greatest Past and present and future are not disjoined btit joined."02870234From: Fein, Ashden CPT USA SJASent: 2010 10:38 PMSubject: pecial CaseSir. Any luck getting authorization for me to bring over the classified disk for the massprint job? Thanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDW) 02216944From:Sent:To:Subject:Attachments:Signed By:Classification:Caveats: NONECPT FeinHurley, Thomas MAJ MIL USA OTJAG Wednesday, August 11, 2010 9:27 AMFein, Ashden CPT USA SJAFW: Email Sent from Scanning Device (UNCLASSIFIED)document2010-08-1 1-092405.pdfUNCLASSIFIEDHere's the delay request.v/r~Thomas F. Hurley 02881 960 From:Sent:To:Cc:Subject:Attachments:Sir,Fein, Ashden CPT USA SJAWednesday, August 11, 2010 9:34 AMAlmanza. Paul; Monow. JoDean CPT MIL Eaton.Michael CPT USF-I SJ A Tn'a| Defense Attomey; aberiand. John CPT MIL Huney, Thomas MAJ MIL USA OTJAGummerman. ara . SA JFHQ- Autry. Carolyn Ms CIV JFHQ-Egan. Michael CIV SJARE: Article 32 (PFC Manning)Art 32 Defense Delay - 11 Aug 10 (ManningB).pdfThe Defense submitted a Formal Delay request. Do you have any objections orcomments before submitted to the v/rCPT FeinAshden FeinCPT, JAChief, Military Justice U.S. Army Military District of washington (Mow)(DSN 325)02219538 From: Almanza, Paul Sent: Wednesday, August I I, |:08 PMTo: Fein. Ashden USA SJA Cc: Zimmerman, Sara J. SGT USA JFHQ- SJAAutw, Carolyn Ms CW JFHQ-SJA Egan, Michael CW DW SJA Morrow, JODean CPT MILUSAMichael I, USF-I A Trial Defense AltomeyHaberland, John CPT MIL USA-, Hurley, Thomas MAJ MIL USA OTIAGSubject: RE: Anicle 32 (PFC Manning)Fem -No objections. As the defense ncqucsa is me. I'll submit anendorsement recommending approval of Ihc delay ncqucsl.Thanks.Almzm/.1 02876281From: Fein, Ashden CPT USA SJASent: 11,20101:14 PMTo:Subject: RE: Manning charging documentAttachments: Charge Sheet (ManningB).pdfThe original charge sheet is attached; however it will likely change and wewill also likely add more charges. It was great meeting you in person andit will be nice (I hope!) working with you over the next few months.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MOW) inal Messa From: state. ovSent: Wednesday, August 11, 2016 11:33 AMTo: Fein, Ashden CPT USA SJASubject: Manning charging documentHey Ashden: when you get a chance, can you lob over the official version ofMany thanks, glad we could all meet in person yesterday. Best --Attorney-AdviserOffice of Law Enforcement and IntelligenceU.S. Department of State02876281 02187829From: @dodiis.mil>Sent: Thursday, August 12, 2010 7:50 AMTo= ?@state.gov>Cc: @statc.gov>; Fein, Ashden CPT USA sm . - (SMO) @usdoj .gov>,@state.gov>Subject: DoD's lnfomiation Review Task Force (IRTF)HiThanks for your note. I look forward to a conversation regarding our complementary efforts regarding the leakeddocuments.Regards? Sent: Wednesday, August 11, 2010 5:52 PMTo:- - Fein, Ashden CPT USA Subject: RE: DoD's Information Review Task Force (IRTF)Hi-:My co|league? forwarded your message below thanks for reaching out to us. handles apanoply of information and classification issues for the Legal Adviser's office, and among other things, advises-who is the State rep you have probably seen on some of the recent SVTS calls. I work in the legal section thathandles law enforcement and intelligence matters. (A third colleague copied here,? handles legal issues forour Diplomatic Security Bureau). I know that? is interested in speaking with you, and is planning to be in touch when he returns to the officetomorrow. ln the meantime, though, ljust wanted to chime in quickly to say that the concern I be|iev:andwere trying to flag at yesterday's SVTS comes from State's past and current experience working with prosecutorson leak and espionage cases. Generally speaking, the practice in these prosecutions is not to produce formal damageassessments until after conviction and sentencing. So we (in the legal office) were surprised to learn of the scope ofactivities already underway, when we first learned of the NCIX effort at the end of last week. The Wikileaks matter isobviously unique in numerous ways that may (unavoidably) call for a departure from standard practice. State's concernin the first instance is just to make sure that the effort is being coordinated with, or at least undertaken with theknowledge of, appropriate prosecutors. In that vein, I am copying your colleague Ashden Fein from Fort McNair, inaddition to attorneys from Counterespionage section, with whom I have been working on the Manningprosecution. I'm not sure they are aware of the meeting that you mention below with the FBI. (There are a lot ofcooks in this big pot of broth.) My role in this is to ensure that State activities are being properly coordinated with theprosecution, so I just wanted to call this to their attention and make sure they also know that you are the appropriateDIA contact in case they have questions. As I mentioned-avill follow up with you tomorrow for a more detaileddiscussion and introduction.Many thanks - Attomcy-AdviscrOffice of Law Enforcement and IntelligenceUS. Department of State02187829 - 7Sent: Wednesday, August 11, 2010 3:09 PMTo:Subject: DoD's Information Review Task Force (IRTF)I called earlier to introduce myself, since I serve as the Legal Advisor to the IRTF and work the legal issuesassociated with our review of the unauthorized disclosure of classified information. I invite you to contact medirectly regarding any legal issues or concerns you may have with the work ofthe IRTF, since I understand youare involved in the State Department's related effort to review the material disclosed.The IRTF began DoD's information review on 28 July and has been working under our charter from theSecretary of Defense. A copy of the directive establishing the IRTF is attached.<<100805 SECDEF MEMO RE |RTF.pdf>>Last week I met with members of the FBI WFO as well as a US Attorney assigned to the case to explain theIRTF charter and to assure them that our review is separate from, and unrelated to, any criminal investigationof the leaked information and that the review is not intended to and shall not limit in any way federal criminalinvestigators or prosecutors. I look forward to talking with you.Thanks.Wh- Assistant General CounselDefense Intelligence Agency02187829 02212991From: omc Sent: Thursday, August 12, 2010 10:54 AMTo: Fein, Ashden CPT USA SJA Subject: FW: OCA list (UNCLASSIFIED)Attach: ALL ARMY OCA LIST October 2009.docClassi?cation" UNCLASSIFIEDCaveats: NONEHere is the Anny OCA list. 02212990From: USA OTJAG _@conus.amy.mil>Sent: Thursday, August 12, 2010 5:19 PMTo: Fein, Ashden CPT USA SJA Subject: COCOM OCA (UNCLASSIFIED)Classi?cation: NCLASSIFIEDCaveats: NONEAshden.I have the OCA list on SIPR. If you want it. please passme your SIPR address. Office of the Judge Advocate General of the Army, Pentagon 3D548NIPR: SIPR: (UHQDA-S.anny.sn1il.nulgov Tcl:Classi?cation: UNCLASSIFIEDCm-?cats: NONE 02880946 - From: Fein, Ashden CPT USA SJASent: Thursda Au ust 12 2010 5:47 PMTo: USA OTJAGSubject: Re: COCOM OCA (UNCLASSIFIED)Ashden FeinCPT, JAChief, Military Justice202-685-4963 (0)292-456-8236 (C)Original Message From: Mayfield, David A Mr CIV USA OTJAG To: Fein, Ashden CPT USA SJASent: Thu Aug 12 17:18:54 2010Subject: COCOM OCA (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONEAshden,I have the level OCA list on SIPR. If you want it, please pass me your SIPRaddress.DaveDavid A. MayfieldSenior Intelligence, Security and In?ormation Operations Legal Advisor O?Fice of the JudgeAdvocate General of the Arm Penta on 3D548 Classification: UNCLASSIFIEDCaveats: NONEI 02877774From: Fein, Ashden CPT USA SJASent: Thursda Au us! 12, 2010 7:00 PMTo: A SJASubject: IRTF MeetingSir,FYSA. I was invited and will attend an Information Review Task Force (IRTF) meeting at thePentagon held by? at 1330. The meeting is scheduled between the IRTF and CCIU(CID) to receive a ?Forensics update? of the wiki-case. The Army and prosecution teamswere invited in order to provide input on the impact of releasin some or all of the forensicinFormation to the IRTF. I will attend alon with . The attorneys are the same attorneys we metwith this week and are our counterparts on the federal side. I worked with? (GC,DIA) to get them invited so the EDVA 8 D03 equities are properly represented. In addition,attendance at this meeting and possible representation from "Team Manning? at Future updates,is consistent with the advice we received From? this week.v/rAshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of washington (MON)02877776 From: Fein, Ashden CPT USA SJASent: 112. 2010 7:26 PMTo: Cc: Subject IRTF MeetingGents,All four of us are invited to participate in the Information Review Task Force (IRTF) meetingbetween (Task Force Leader and the Army CID (CCIU) being held tomorrow at 1:36 atthe Pentagon. will meet us at the metro entrance of thePentagon at 1245 in order to assist in badging and Finding the conference room. Please letme know if you plan on attending. Thank you.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDW)02872802Subject:Attachments:Importance:Dr. Sweda,Fein, Ashden CPT USA SJAThutsday. August 12.2010 8:11 PMSweda. Michael Dr CIV USA MEDCOM WRAMC. Hudey. Thomas MAJ MIL USAOTJAG Eaton, Michael CPT USF-I SJ A Trial Defenseomey; ange. ns op er MIL USA MEDCOM WRAMCL Benesh, Samantha CPT MIL USA MEDCOM Hemphill. Marla LTC MIL USA MEDCOM BAMCRE: RCM 706 Order (PFC Manning) (UNCLASSIFIED)RCM 706 Extension - 12 Aug 10 (ManningB).pdfHighThe Convening Authority approved your requested extension of time. Pleasesee attached memorandum.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON)02881955From:Sent:To:Cc:Subject:Attachments:Importance:Sir,Fein, Ashden CPT USA SJAThursday. August 12. 2010 8:13 PMAlmanza. Paul; Morrow, JoDean CPT MIL Eaton.Michael CPT USF-I SJ A Trial Defense Attorney; Haberland. John CPT MIL Huney, Thomas MAJ MIL USA OTJAGImrnennan, ara . USA JFHQ- Autry. Carolyn Ms CIV JFHQ-SJA, Egan. Michael CIV SJARE: Article 32 (PFC Manning)Art 32 Deiay - 12 Aug 10 (ManningB).pdfHighThe convening Authority approved the defense delay of the Article 32Investigation.v/rCPT FeinAshden FeinCPT, JAPlease see attached memorandum.Chief, Military Justice U.S. Army Military District of Washington (MDN)02216943From: Huney, Thomas MAJ MIL USA OTJAG Sent: Fnday, August 13, 2010 4:56 PMTo: Fein, Ashden CPT USA SJACc: Bouchard, Paul R. CPT USD-C DSTB CO TDS Sr Defense Counsel; Eaton. Michael CPT USF-I SJ A Trial Defense AttomeySubpct Signed By:Classification: UNCLASSIFIEDCaveats: NONECPT Fein1. I told you on the phone today that I have not been detailed to representPFC Bradley Manning in his pending court-martial. COL Cremin, LTC Fleming,and LTC Febbo will decide who will ultimately be detailed in this case. Ianticipate that a decision on that matter will be made in the coming week.2. we agreed that any "objections" or "recommendations" that the defensehad to any potential Security Procedures memo signed by MG Horst would bedue today. I am not comfortable signing anything as a defense counsel inthis case (because I am not one any more), so I would request an extensionof time to make those "objections" or "recommendations" for a period of twoweeks. In that time, the new detailed counsel could offer whatever thoughtnecessary for the appropriate handling of classified matters. If MG Horstdoesn't want to wait (and her certainly doesn't have to), we would ask thathe consider the memo signed by CPT Bouchard on this topic. He submittedthat memo through PFC Mannings commanders and lawyers in the CENTCOM AOR.3. Please email or call me with any questions.Thanks.Thomas F. HurleyMAJ, JAUS Army Defense Counsel Assistance Program Classification: UNCLASSIFIEDCaveats: NONE 02872853From: Fein, Ashden CPT USA SJASent: 010 2:26 PMTo:Subject: QUICK uestuonwe are still working on the request for the OCA review. I do plan on sending you a copy ofthe request before the official request is forwarded. we have an admin question in referenceto this task. Are the MRN names classified or unclassified? Thanks.AshdenAshden Feincpr, JAChief, Military JusticeU.S. Army Military District of Washington (MDW) 02188838From: ?@state.gov>Sent: Monday, August 16, 2010 3:08 PMTo: Fein, Ashden CPT USA SJA Subject: RE: Quick QuestionHi Ashden:Just to clarify, by names," do you mean the numbers, or the subject titles (or both)? stands for "messageretrieval number", so usually it is a term applied to the numbers only.So there are potentially 3 questions here:(1) are the numbers classified?(2) are the titles/subject lines classified?(2) is the number in combination with the subject line classified?If your question is I know for a fact that subject lines of I know for a fact that the MRN names of many classifiedcables are, in fact, classified. What I don't know for sure is whether this is always true, or whether it is a case-by-casedetermination. For example, one could imagine a cable that is classified clue to one paragraph of its content, but wherethe title itself is fairly innocuous title Report from Bangkok"). Anyway, let me which of these perhapsall? - are your questions, and I will double check with the technical experts here. Many thanks In any 02872854From: Fein, Ashden CPT USA SJASent: Monda August 16. 2010 9:57 PMTo: ?@s1ate.gov'Cc: Morrow JoDean, CPT USA SJASubject: Re" Quick QuestionThanks for such a quick reply. To make this easy for our current purpose, how aboutjust an answer to number (1)-are the numbers themselves classified without the subject. Thereason For the question is to determine whether we can keep the numbers listed on unclas docsthat we use For our requests and notes. Thank you. AshdenAshden FeinCPT, JAChief, Military Justice 02188834Sent: Tuesday, August I7, 2010 5:18 PMTo: Fein, Ashden CPT USA SJA Subject: RE: Quick QuestionHi Ashden: I've confirmed, the numbers themselves are not classified or otherwise considered sensitive. Thanks forchecking! Deiartment of State02187823From: ?@dodiis.miI>Sent: Wednesday, August 18, 2010 3:52 PMTo: Fein, Ashden CPT USA SJA Subject: Access to Data SetAshden, when possible, let's discuss an information sharing question regarding some data the IRTF would liketo analyze. Thanks.- 02187819From ?@dodiis-mu>Sent: Thursday, August 19, 2010 8:56 AMTo: Fein, Ashden CPT USA SJA Subject: RE: Access to Data SetAshden, no need to call back right at this moment. I'm only following up on yesterday's discussion regarding the IRTFrequest to review the contents of the 11K disk. I'm going into the meeting with Dip Security. The topic will likelycome up, but I'll await your reply in due course. I understand you'll have to coordinate with Do] and CID perhaps.Thanks, Ashden! 02188816From _@statessov>Sent: Thursday, August 19, 2010 10:53 AMCc: :@state-gov>Subject: RE: Access to Data SetAshden, I did respond to your e-mail earlier today double-check your inbox!The sentence highlighted below is not quite accurate. I personally am not authorized to okay release of thecontent. What I did say is that the objection that I personally flagged for?and her team in my capacity ofcoordinating law enforcement concerns was related only to the fact that the disk came from CID and was shared withDiplomatic Security as part of the criminal investigation. That said, I am also not personally aware of any specificobjections to releasing the content, but that's something that- needs to coordinate and approve. 02187814From ?@dodiis-miI>Sent: Thursday, August 19, 2010 I 1:02 AMTo: ,.state.gov>; ein, Ashden CPT USA JFHQ-SJ A Cc: ?@state.gov>Subject: RE: Access to Data Set- you're absolutely correct, and I apologize for overstating your earlier comment. I only want to clarify whatmay be the equities of the various stakeholders. Would it be possible for you to work with. to clear the release ofthe 11K reports at least as far as DOS owns the content? Thanks.-02187811From:Sent:To:Cc:Subject:IWould you be in a position to work withthe 11K disk? I just talked wit! and he's ready to work with you in approachingith the request. He tellsme he does not have ready access to his unclassified email, but you can reach- atThanks. @dodiis.mil> Thursday, August 19, 2010 I238 PMdodiis.mil>;Ashden CPT USA JFHQ-NCFW: Access to Data Set state. ov>; Fein,the DOS LNO to the IRTF, to tee up the IRTF request for access to 02882200From: Fein, Ashden CPT USA SJASent: Sunda Au ust 22 2010 11:14 PMTo:Cc: Morrow JoDean. CPT USA SJASubject: RE: Access to Data Set - note 2 separate messages I just sent with this one to you. oneto you an(_ Iwe never connected on Friday. Is there still an outstanding issue that you want to discuss?I know we still owe you a draft request for the OCA review and then the actual Formalrequest. I hope to have this to you by the end of this week. of course, at this point weare still trying to Figure out the information to request as it trickles in. thank youagain!AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 02872830From: Fein, Ashden CPT USA SJASent: Monday, August 23, 2010 2:55 PMTo: Sweda. Michael Dr CIV USA MEDCOM Kemkes. Matthew MAJ MIL USACc: Eaton. Michael CPT USF-I SJ A Tnal Defenseomey; orrow ean. USA Rose. Luke CPT USD-CSJA Chief, Military Justice; Habenand. John CPT MIL USASubject: RCM 706 (PFC Manning)Importance: HighDr. Sweda,Thank you for the phone call. The purpose of this email is to document our conversation forthe Defense in this case. Also, the roster changed for the defense. For administrativematters, please include the entire distribution on your email. This includes the defense andGovernment counsel.You called to ask what matters the Sanity Board may review during the inquiry. Youspecifically asked whether there is a case file investigative files, witness statements,Soldier records, medical records, and/or mental health records available for the Board. Iasked you to please send an email to the entire distribution with specific requests of thedocuments the Board wants or needs for their inquiry.I also briefly explained that although the Board asked for three months, the conveningauthority only gave six weeks in order to reassess the Board's progress, and if the Boardrequires more time then there will be an opportunity to justify the additional time to theconvening Authority. Defense and Government counsel will be given the opportunity to commenton the request.Thank you.v/rCPT FeinAshden FeinCPT, 3AChief, Military JusticeU.S. Army Military District of Washington (DH) 02221952Sent: Monday, August 23, 20l0 3:27 PMTo: Fein, Ashden CPT USA SJA Matthew Eaton, Michael CPT SJ A Trial DefenseAttorney Morrow 111, JoDean, CPT USA JFIIQ- Subject: RE: RCM 706 (PFC Manning) (UNCLASSIFIED)Ce: Classi?cation: UNCLASSIFIEDCaveats: NONEALCON:We are scheduled to begin our evaluation of PFC Manning this Friday 27August. but have no records other than the 700 order and charge sheetWe ordinanlv ask for: mental health records (including inpatientstays. if any), medical records (non AHLTA. ifany. as AHLTA can beeasily viewed on line). witness statements. a rcpon (to the extent that is available given the pie-Article 32 standing ofthe ease. or a summary of investigation to date). witness statements.military employment records. and any other relevant documents.Please indicate what will be made available and when.Records iriay be sent by Fedl-Ix or similar couner to:Dr. Michael SwcdaChief. Walter Reed Forensic ServiceWalter Reed Anny Medical Center6900 Georgia Avenue NW6 (Borden Pavilion). Dept. 3rd FloorWashington DC 20307v/ r.Michael Sweda. ABPP (Forensic)Board-Certi?ed Forensic Ps) cliologistChief. Forensic ServiceDirector. Forensic Ps_veliolog_v Fellowship Walter Reed Army Medical Center "'I?he United States themselves are essentially the greatest poemPast and present and future are not disjoined butjoined."-??--Original ?v SJA 02221952Sent: Monday. August 23. 2010 2:55 PMTo: Sweda. Michael Dr USA MEDCOM Keinkes. Matthew] MAJ MILUSACc: Eaton. Michael CPT USF-I SJ ATrial ense ttomey; orrow . 0Dean. CPT USA Rose. Luke CPT USD-C SJ A Chief. Military Justice: I-laberland. John CPTMIL USASubject: RC 706 (PFC Manning)lmponance: HighDr. Swcda.Thank you for the phone call. The purpose of this email is to documentour conversation for the Defense in this case. Also. the roster changedfor the defense. For administrative matters. please include the entiredistribution on your email. This includes the defense and Govenunentcounsel.You called to ask what matters the Sanity Board may review during theinquiry. You specifically asked whether there is a case ?le .investigative files. witness statements. Soldier records. medicalrecords. and/or mental health records available for the Board. I askedyou to please send an email to the entire distribution with speci?crequests of the documents the Board wants or needs for their inquiry.I also briefly explained that although the Board asked for three months.the convening authority only gave six weeks in order to reassess theBoard's progress. and if the Board requires more time then there will bean opportunity to justify the additional time to the ConveningAuthority. Defense and Government counsel will be given the opporturiit_vto comment on the request.Thank you.v/rCPT FeinAshden FeinCPT. JAChief, Military JusticeUS. Anny Military District of Washington (MDW) Caveats: NONE02186174 From: conus.army.mauSent To:Cc: Fein, Ashden CPT USA JFH Morrow Ill JoDean CPT USA SJA: mstategov;Subject: CCIU 8 nc Meeting (UNCLASSIFIED)Signed By: ?@us.army.mi|Classification: UNCLASSIFIEDCaveats: FOUOCCIU is hosting our weekly meeting at the below listed date/time.Time: 1300Date: 25 Aug 16V/r Washington Metro Resident AgencyComputer Crime Investigative Unit9805 Lowen hoad, 193Fort Belvoir, VA 22060(Office) (Fax)Classification: UNCLASSIFIEDCaveats: FOUO 02215940From: Sent: Wednesday, August 25, 2010 10:27 AMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Paul Bouchard Mic ael Eaton . US.ARMY.MILSubject: rt Request - 706 BoardAttach: Manning - Expert CPT Fein,I have been retained by PFC Manning to represent him in his case. I will be making my representation ofhim public early next week. Please forward the attached request to the convening authority priorto having the R.C.M. 706 board begin its work. Additionally, please ensure that Dr. Sweda and the boardhave all of the requested documentation before beginning their work. This would prevent the necessity ofrequesting that the military judge reopen the R.C.M. 706 board at a later date.If you have any questions or concerns, feel free to contact me.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896. 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02879505From: Fein, Ashden CPT USA SJASent: Wednesday, August 25. 2010 10:53 AMTo:Rose. Luke CPT USD-C SJA Cniet, Military JusticeSubject: RE: Defense Expert Request - 706 BoardMr. Coombs- Acknowledged. The United States will process the defense requestimmediately.Dr. Sweda- The prosecution will present the delay request to the conveningauthority in the next 24 hours (assuming he is available) and have an answeron whether the RCM 706 Board is delayed or not.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of washington (MON) Cc: ew em es; au ucha ichael Eaton; Morrow Ill, JoDean_ CPT USA A: Haberiand. John CPT MIL USA:02214355From:Sent:To:Cc:Subject:.g0v>Wednesday, August 25, 2010 5:28 PM IV USA us.arm (USAVAE) 1 usdoj.gov>; (FBI)ic.fbi.gov>; (USAVAE) IV USA Fein,Ashden CPT USA SJA RE: Affidavits (UNCLASSIFIED)-rom our office will be taking the lead on the search warrants for Manning's Aunt?s house and the twoboxes from New York.ill coordinate with you am. Thanks for following up.02877770 From:Sent:To:Subject:Fein, Ashden CPT USA SJAst 25, 2010 7:49 PMusdoigovt . usdoj.gov';@usdo].gov usdoj.gov' @usdoj.gov';@usdoj.gov'; odiis.mil'; Morrowl . ean, CPT USA3?IRTF MTG -and Prosecution'teams? thank you all For meeting next week to discuss our wa Forward.dor atwe should all be available monday afternoon. I recommend meeting ata Facility in city so we can discuss at the sci level. How is 1406?Vr. AshdenAshden FeinCPT, JAChief, Military Justice02221950From:Sent:To:Cc:Subject:Thursday, August 26, 2010 7:06 AMFein, Ashden CPT USA SJA il>;Matthew kemkes '2 Eaton, Michael SJ A Trial DefenseAttorney Morrow .loDean, CPT USA JFHQ- - RE: RCM 706 (PFC Manning) (UNCLASSIFIED)Classi?cation. UNCLASSIFIEDCaveats: NONEALCON:We will meet tomorrow (27 Aug) with PFC Manning to begin our evaluation.Thus far. we have no documentation but can begin with cenatn aspects ofthe evaluation even in absence of this.I wanted to double check to that there are no security issuesabout our interview. and that we can handle notes in the usual manner.Michael SwedaChief. WRAMCC Forensic Service 6)From: Fein. Ashden CPT USA SJASent: 0 August .. 010 :55 PMTo: Sweda. Michael Dr CIV USA MFDCOM Kemkes. Matthew MAJ MILUSCc: Eaton. Michael cm SJ ATrial De cnse Attomey; Morrow JoDean. CPT USA SJA:Rose. Luke CPT USD-C SJA Chief. Military Justice: Haberland. John CPTMIL USASubject: RCM 706 (PFC Manning)Importance: llighDr. Sweda.Thank you for the phone call. The purpose of this entail is to documentour conversation for the Defense in this case. Also. the roster changedfor the defense. For administrative matters. please include the entiredistribution on your email. This includes the defense and Govemmentcounsel.You called to ask what matters the Sanity Board may review during theinquiry. You speci?cally asked whether there is a case file .investigative files. witness statements. Soldier records. medicalrecords. and/or mental health records available for the Board. I askedyou to please send an email to the entire distribution with specificrequests of the documents the Board wants or needs for their inquiry.I also brie?y explained that although the Board asked for three months.the convening authority only gave six weeks in order to reassess theBoard's progress. and if the Board requires more time then there will bean opponunity to justify the additional time to the Converting 02221950Authority. Defense and GOVCITIIHCHI counsel will be given the opportunityto comment on the request.Thank you.V/rCPT FeinFcinCPT. JAChief. Military JusticeU.S. Amiy Military District of Washington 02215931 Bouchard, Paul R. CPT USD-C DSTB CO TDS Sr Defense CounselFrom: Sent: Thursday, August 26, 2010 7.22 AMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Eaton, Michael L. PT USD-COfficer Subject: RE: Defense Expert Request - 706 BoardAttach: Manning - Expert Dr. Swcda:The lead attomey for Manning is Mr David (foomhs (His e-mail address is on the cc line. and please read the below e-mail).Yesterdux the Defense requested that an additional doctor -- one on the delense learn -- be appointed for purposes ol? the706. (See e-mail attachment).Moreover, given recent discussions with our client. we now have corieems as they pertain to the 706.With that. we request that the 706 be pushed back until these issues/requests are resolved.Respectfully.(Il"l? BouchardCl? l" l?aul BouchardSenior Defense (Iounsel Camp Liberty. Iraq 02872828From:SentTo:Cc:Subject:Fein, Ashden CPT USA SJAThursday, August 26. 2010 8:34 AM Matthew kemkesEaton, Michael CPT USF-I SJ A Trial Defenseomey: orrow ean_ USA SJA. anmng Dr. Sweda. As of late last night, the convening authority granted the defense delay until theGCMCA takes action on the expert request. The Formal documentation will be sent later thismorning. vr. CPT FeinAshden FeinCPT, JAChieF, Military Justice 02879522 - From: Fein, Ashden CPT USA SJASent: Thursday, August 26, 2010 8:39 AMTo:Cc:'coombs@armycourtmama defense.com'; Morrow .JoDean,CPT USA ?Iukerose mn - .army.mnSubject: Re: Defense Expen Request - 706 BoardMr. Coombs, et al, please outline your client's security concerns so that the United Statesmay take appropriate action. This is the first we have heard of these security concerns.Also please try to include all government counsel on your emails. Thank you.CPT FeinAshden FeinCPT, JAChief, Military JusticeOriginal Message From: Bouchard, Paul R. CPT uso-c osm 8 co TDS Sr Defense Counsel To: Fein, Ashden CPT USA SJACc: Matthew kemkes; Eaton, Michael L. CPT USD-C Officer Sent: Thu Aug 26 67:21:59 2018Subject: RE: Defense Expert Request - 786 BoardDr. Sweda:The lead attorney for PFC Manning is Mr. David Coombs (His e-mail address is on the cc line,and please read the below e-mail).Yesterday, the Defense respectfully requested that an additional doctor -- one on the defenseteam -- be appointed for purposes of the 706. (See e-mail attachment).Moreover, given recent discussions with our client, we now have security concerns as theypertain to the 706.with that, we request that the 786 be pushed back until these issues/requests are resolved.Respectfully,CPT BouchardCPT Paul BouchardSenior Defense CounselCamp Liberty, IraqMessage??--? 02879522From: Sent: Wednesday, August 25, 2910 5:27 PMCc: Bouchard, Paul R. CPT DSTB CO TDS Sr Defense Counsel;Eaton, Michael L. CPT uso-c Officer; Subject: Defense Expert Request - 766 BoardCPT Fein,I have been retained by PFC Manning to represent him in his case. I will be making myrepresentation of him public early next week. Please forward the attached request to theconvening authority prior to having the R.C.M. 766 board begin its work. Additionally,please ensure that Dr. Sweda and the board have all of the requested documentation beforebeginning their work. This would prevent the necessity of requesting that the military judgereopen the R.C.M. 766 board at a later date.If you have any questions or concerns, feel free to contact me.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02726Direct Dial: (461) 744-3607Office: (598) 674-6696Fax: (508) 324-9896Notice: This transmission, including attachments, may contain confidentialattorney-client information and is intended for the person(s) or company named. If you arenot the intended recipient, please notify the sender and delete all copies. Unauthorizeddisclosure, copying or use of this information may be unlawful and is 02187804From:Sent:To:Cc:Subject: ?@aodns.min>Thursday, August 26, 2010 10:58 AM Fein, Ashden PT USA SJA @usdoj .gov>; Morrow JoDcan, CPT USA SJA RE: IRTF MTG Monday. I400. EDVA. works. A building would be helpful. 'll13nks.02221947From:Sent:To:Ce:Subject:Thursday, August 26, 2010 1:44 AMFein, Ashden CPT USA SJA Matthew kemkes Eaton. Michael CPT IJSF-I SJ A Trial DefenseAttorney Morrow Jo[)ean, CPT USA IA I Com;RE: RCM 706 (PFC Manning) (UNCLASSIFIED)Classi?cation UNCLASSIFIEDCaveats: NONESir"I just wanted to make sure that I am tracking on this. This means thatwe will need to reschedule our first evnluatioit session for a laterdate??v/ r.Michael Sweda. ABPP (Forensic)Board-Certi?ed Forensic (?hief Forensic ServiceDirector. Forensic Ps_\ eliology Fellowslup Walter Reed Anny Medical Center "The United States themselves are essentially the greatest poem.Past and present and future are not disjoined but joined."?-?Original Message--??From: Fein. Ashden CPT USA SJASent: Thursday. August 26. 2t)l() 8:34 AMTo: Sweda, Michael Dr CIV USA MEDCOM Kemkes. Matthew MAJ MILCe; Eaton. Michael CPT USF-I SJ ATrial Defense Attomcx. Morrow JoDean. CPT USA Samantha ?vi MIL A MED MAM;Habcrland. John CPT Mll. USA:BeneshlSubject: Re: RICM we (pro Dr. Sweda. As of late last night. the com ening autlionty granted thedefense delay umil the GCMCA takes action on the expert request. Thefonnal documentation Will be sent later this moming. Vr. CPT FeinAshden FeinCPT. JAChief, Military Justice02221 947Original Message From To: FemEaton. IC 1c - ri eense ttomeyz. onow JoDcarL CPT USA ent. iu up, )0 Subject: RE: RCM 706 (PFC Manning) (UNCLASSIFIED)Classi?cation" UNCLASSIFIEDCaveats: NONEALCON:We will meet lomonow (27 Aug) with PFC Manning to begin our evaluation.Thus far. we have no documentation but can begin with certain aspects ofthe evaluation even in absence of this.I wanted to double check to con?rm that there are no security issuesabout our interview. and that we can handle notes in the usual manner.Michael SwedaChief. WRAMCC Forensic Service From: Fein. Ashden USA SJAent: on ugust .. To Sweda, Michael I)r CIV USA MEDCOM WRAMC. Kemkes. Matthew] MAJ MILUSA . Michael usr-I ATrial De ense Atlomcy; Morrow Ill. JoDean, CPT USA Rose. Luke CPT USD-C SJA Chief. Military Justice; llaberland. John CPTMIL USASubject: RCM 706 (PFC Manning)Importance: HighDr Sweda.Thank you for the phone call. The purpose of this email is to documentour conversation for the Defense in this case Also. the roster changedfor the defense. For administrative matters. please include the entiredistribution on your email. This includes the defense and Gov enunentcounsel.You called to ask what matters the Sanity Board ma_v review during theinquiry. You speci?cally asked whether there is a case file .investigative ?les. witness statements. Soldier records. medicalrecords. and/or mental health records available for the Board. I askedyou to please send an email to the entire distribution with speci?crequests of the documents the Board wants or needs for their inquiry.I also briefly explained that although the Board asked for three months.the convening authorit_v onl_v gave six weeks in order to reassess theBoard's progress. and if the Board requires more time then there will bean opportunitv to iustifv the additional time to the onvcning02221 947Authority. Defense and counsel will be given the opportunityto conuncul on the request.Thank you.v/rCPT FcinFcinCPT. JAChief. Military JusticeUS Amt)" Military of Washington (MDW) asst Caveats: NONEClassi?cation: Caveats: NONE02872825Subject:Fein, Ashden CPT USA SJA Thursday. August 26. 2010 11:55 AMMatthew kemkesaton. Michael CPT USF-I SJ A Trial Defenseorney; onow ean, USA JFHQ-NCRIMDW anmngDr. Sweda. Yes, please reschedule and please wait to reschedule until we get back to you inthe near Future. Vr.Ashden FeinCPT, JACPT FeinChief, Military Justice 02205997Morrow JoDean, CPT USA SJA mm: Sent: Wednesda Se tember I, 2010 844 AMCc: Fein, Ashden CPT USA SJA Subject: clearance and other issues (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUOGood morning. I am working with CPT Fein on the PFC Manning case and recent developments have led us to concludethat we will need to get Mr. David Coombs (PFC Manning's civilian defense counsel) a clearance for the durationof the case. I believe he already has an active SECRET clearance. Do you have example papen/vork we can use to getthe process started? I understand that the request is routed through your office.In addition, CPT Fein and I have been breaking down MRE 505 and would like to run our analysis by you as it pertains tothis case, i.e. what we would like the OCAS to accomplish with their classification reviews. Do you have time to chat inthe near future? Thanks for all your help.JoeCPT Joe MorrowTrial CounselUS Arm Milita District of WashingtonphonejClassi?cation: UNCLASSIFIEDCaveats: 02205994Morrow .loDean. CPT USA SJAFrom:Sent: Wednesday, September 1, 2010 1049 AMTo: Eaton,Michael I. CPT USF-I A 'l?n'al Defense ttorney Cc: ?Rose, Luke Lsr)-C SJA Chief. Military Subject: defense requests dated 25 and 26 August 2010 (IJNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats. FOUODefense team,The United States is currently processing your Defense Expert ConsultantRequest (dated 25 Aug 10) and your Request to Delay the RCM 706 Board (dated 26 Aug 10).In your request to delay the RCM 706 sanity board, you proffered that PFCManning would need to divulge information up to the level in order toparticipate in the inquiry of the board. What is your position with respectto the level of clearance you will need in order to effectively represent PFCManning? If you believe you will need an additional clearance above what youalready possess, the United States will need a formal request in writing withjustification.The United States is also working on your request for appointment of an expertconsultant in forensic and your request to have the expertconsultant participate before, during, and after the RCM 706 sanity board.Assuming classified information is authorized to be discussed at the RCM 706sanity board, are you also requesting the expert consultant be cleared at thelevel to be a full member of the defense team? If so, please amendyour request for the expert consultant to reflect this requirement.Thanks.CPT Joe MorrowTrial CounselUS Army Military District of WashingtonvhonejClassi?cation: UNCLASSIFIEDCaveats: FOUO 02205838Fmm_ Morrow Ill, JoDean, CPT USA SJASent: Thursday, Se tember 9, 2010 1:52 PMTo: USA OTJAG Cc: Fein, Ashden CPT USA SJA Subject: personal information (UNCLASSIFIED) Classi?cation: UNCLASSIFIEDCaveats: FOUOSir,Here is the requested information for defense counsel:David Edward Coombs (civilian defense counsel)Matthew John Kemkes (military defense counselMichael Lewis Eaton (military defense counsel)Paul Bouchard (military defense counsel) NOTE: There is a possibility that either Eaton or Bouchard will be taken off the case because they're both in Iraq.We are waiting for final word on what Manning was read-on to our request will likely mirror his level of access.Additionally, we can discuss ways to make this more palatable when we send up our formal request, but Ashden and Iwere thinking that perhaps we can limit access above SECRET to client communications only. Thanks for your help.CPT Joe MorrowTrial CounselUS Army Military District of WashingtonClassi?cation: UNCLASSIFIEDCaveats: FOUO 02185790From: Sent: Friday, September I0, 2010 6:59 AMTo: Fein, Ashden CPT USA SJA - Cc: us.army.miI>Subject: Re: Search Authorization for Fort Drum (UNCLASSIFIED)Attach: Search Authorization 0028-10-CID221-10107 (Fort Drum Items) I0-Sep-20l0.pdfClassi?cation: UNCLASSIFIEDCaveats: ENFORCEMENT SENSITIVEClassi?cation: UNCLASSIFIEDCaveats: ENFORCEMENT SENSITIVECPT FEIN,I am attaching the Search Authorization for the Fort Drum Items we discussed. Please let me know if you see any majorissues. I believe we mentioned at the meeting the plan is to:1. Review all of the computers/hard drives they have on hand to identify any that MANNING may have used;2. Seize/collect any hard drives or digital media with user profile on it for further examination back atCCIU.3. Seize/Collect the server MANNING used for his network storage space also for examination at Unfortunately, as I think I mentioned on the phone. one connex we were expecting to be at the unit (the Connex")has somehow wandered off since they were told it was there last; the connex that anived needs to get brought to the unitthis morning; there are a bunch of items in the Unit Vault to be looked at; and they need to ?gure out where the serverwe're looking for is, as it wasn't labeled correctly in their packing documents.I'm hoping I covered all bases. _(in Iraq) didn't have any questions on what I sent him, so I hope everything wasclear enough in what we were i to do me know if you see any problems so we can correct. The agent'son the ground. and are to begin the process of trying to look through all these itemsstarting sometime this morning. Washington Metro Resident AgencyComputer Crime Investigative Unit (CCIU)U.S. Army Criminal Investigation Command (USACIDC)9805 Lowen Road, Building 193Fort Belvoir. VA 2206002185790Email us.arm .milSIPRI Web: THIS EMAIL MAY CONTAIN LAW ENFORCEMENT SENSITIVE INFORMATION.NOTICE: This E-mail (including attachments) is covered by the Electronic Communications Privacy Act, 18 USC 2510-2521, is con?dential, and may be legally privileged. If you are not the intended recipient, you are hereby noti?ed that anyretention, dissemination, distribution, or copying of this communication is strictly prohibited and may be unlawful. Pleasereply to the senderthat you have received the message in error and then delete the message and any attachments.<_ I ic.fbi.ov>; I ic.fbi.gov>Weekly Coordination Meeting WFO will host a weekly WL coordination meeting tomorrow (Tuesday) at 1:30 p.m. The meeting will be held in the SAC's5thfloor conference room, 5020. Thanks to all.02205649Morrow JoDean, CPT USA SJAFrom:Sent: Monday, September I3, 2010 2:05 PMTo: USA OTJAG 1jconus.army.mil>Cc: Fein, Ashden CPT USA SJA Subject: additional personnel (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUOSir,I have the names and SSNS of the RCM 706 board and treating ready to send up. They shouldall be cleared to the level, but may not be read-on. Please advise on the way forward regardingpaperwork/justifications. Thank you.Respectfully,MorrowTrial CounselUS Army Military District of WashingtonClassi?cation: UNCLASSIFIEDCaveats: FOUO 02205647From:Sent:To:Cc:Subject:Morrow JoDean, CPT USA SJAMonday, September 13, 2010 6:18 PMMatthew kemkes?Rose, Luke CPT USD-C SJA Chief, MilitaryFein, Ashden CPT USA SJAcase update Classi?cation: UNCLASSIFIEDCaveats: FOIJOGentlemen,Update on current issues:The United States is continuing to work on identifying an expert, with the proper credentials, including asecurity clearance. Once we receive the information from the Chief, Forensic we will forward theaction to the The RCM 706 board members have been identified and we are processing your request to have them cleared todiscuss the mental impressions of PFC Manning during the examination.Your request for clearance for defense counsel is currently being processed. Please notify us if the threemilitary defense counsel will not be remaining on the case.ThanksCPT Joe MorrowTrial CounselUS Army Military District of WashingtonClassi?cation: UNCLASSIFIEDCaveats: FOUO 02205572Morrow Ill, JODcan, CPT USA SJA Sent: Tuesda Se tember 14, 2010 4:28 PMTo: Cc: Fein, Ashden CPT USA SJA Subject: RE: additional personnel (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUOSir.may be to identify a third manager at this stage as well - someone for the Aniclc 32 and the MJ/court. They wouldn't beneeded until later CPT Joe MorrowTrial CounselUS Annv Militarv District of Washington 02215900From: Sent: Wednesday, September 15, 2010 l:36 PMTo: Morrow JoDean, CPT USA SJACc: Rose,Luke CPT USD-C SJA Chief,Mi|itaIy Justice Fein, Ashden CPT USA SJAMatthew kemkes Subject: RE: case update (UNCLASSIFIED)Joe,Thank you for the update. I believe the defense counsel on the case will be just myself, MAJ Kemkesand CPT Bouchard. PFC Manning will be IMCing CPT Bouchard this or early next week. I have receivedconfirmation that the IMC request will be approved.Do you have any update on the defense request to have a forensic appointed to the defenseteam to sit in on the 706? I may have a lead on a forensic from the Air Force with a TS-SCIclearance. I hope to hear something this week on his availability.What tirne-line are you looking at to start up the 706? How are the classification reviews coming?Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02869426From: Fein, Ashden CPT USA SJASent: Friday, September 17, 2010 6:51 PMTo: Matthew kemkesCc: Rose.Luke CPT USD-C SJA Chief,MiIitary Justice: Morrow Ill,JoDean. CPT USA SJASubject: Update (US v. Manning)Attachments: Acknowledgment of Protective Order (ManningB).pdf; Protective Order for ClassifiedInformation (ManningB).pdf; Preliminary Classification Review of the Accused's MentalImpressions (ManningB).pdf; Appointment of Defense Security Expert Consultant(ManningB).pdf; Monitoring Acknowledgment hnponance: HuhSir,Good evening. The convening Authority took action on most of your most recent requests andattached are the actions and updates.1. Appointment of Defense Security Expert consultant. Attached is the appointmentmemorandum. Mr. Ganiel (ATEC) may be reached at or.2. In reference to the defense request for clearances for the defense team and theRCM 706 board, the convening Authority ordered that a preliminary classification review byyour defense expert occur of the accused's mental impressions and thoughts so that theconvening Authority can properly determine whether clearances and read-ons are required.Attached is the Preliminary classification Review Order. Please contact the Trial counsel,if you need assistance with setting up the logistics for your expert to conduct this review.3. The United States is still working on finding an available Forensic Expertconsultant with eligibility to obtain or have a clearance to present to the conveningAuthority. Although there are doctors who fit your request, there are very few with clearances, which we requested, in case that access level is ordered by the conveningAuthority. we expect an answer by the middle of next week. The United States is searchingacross all branches of the 4. The convening Authority issued a Protective Order for classified Information. Theprevious convening Authority also had a Protective Order in place in the originaljurisdiction. Attached is the Protective Order and its Acknowledgment. Please review thisProtective Order and have all members of the defense team (including the defense expert andthe accused) sign an acknowledgment prior to the discussion of classified information amongstyourselves. After the Preliminary classification Review is finished, the convening Authoritywill make a decision as to what level of classified information may be discussed amongst thedefense team, including the limits of the "need to know" and under what conditions.5. Finally, the United States will be monitoring and/or recording all communications bythe accused with another party to prevent the disclosure of classified information, exceptfor privileged communications with the defense team, the accused's behavioral healthproviders, and the brig chaplains. Attached is the acknowledgment which will be presented bythe Brig to the accused.If you have any questions, please call or email. Have a good weekend.v/r02889426AshdenAshden Feincpr, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 02215891From: Sent: Saturday, September 18, 2010 2:43 PMTo: Fein, Ashden CPT USA SJA Cc: Rose,Luke CPT USD-C SJA Chief,Military Justice Morrow JoDean, CPT USA SJAMatthew kemkesPaul Bouchard Subject: RE: Update (US v. Manning)Attach: Defense Response to Attachment A.pdfCPT Fein,Please review the attached response to the preliminary classification review order by COL Coffman. Thedefense's position is that this order is not a lawful one. Since this matter is not yet before a military court,the defense will need to know the government's position on this issue in a timely fashion in order seekextraordinary relief.Also, I have spoken with my client regarding the monitoring and/or recording acknowledgement. Basedupon our discussion, he has signed the acknowledgement. The defense requests notification of theprocedures that the confinement facility will use to ensure that privileged communications with defenseteam, PFC Manning's behavioral health providers, and the brig chaplains will not be mistaken monitored orrecorded.Finally, I have a lead on a possible military forensic that possesses a TS-SCI clearance. OnceI con?rm his availability, I will provide the government with his contact information.Feel free to contact me if you have any questions or concerns.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896ww. 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02187060Sent: on ay, eptem er 1To: I ic.fbi.gov>Subj eet: RE: Tuesday MeetingAs everyone seems to be able to make 10:00 tomorrow. we'll hme our weekly meeting then.Thank you.FBI Washin on Field Officemobile 02214143@usdoj .gov> From:Sent: Thursday, September 23, 2010 1:25 PMTo: Fein, Ashden CPT USA SJA Morrow JoDean, CPT USA SJAusdoj.gov>;usdoj.gov>;us o].gov>Cc: @ic.fbi.gov>Subject: Rule 6(e) Disclosure Motion/Order UpdateI have filed the motion to seek authorization to disclose grand jury matters. According to chambers, the Judgewill not be able to review it until Monday afternoon. I'll keep you posted.02205471From_ Zimmerman, Sara J. SGT USA SJASent: Friday, September 24, 20l 0 2:30 PMTo: Cc: Matthew kemkesFein, Ashden CPT USA SJA?Morrow, JoDean CPT MIL Haberl and, John CPT USA Regimental Judge AdvocateSubject: Preliminary Classi?cation Review Attach: Superseding Preliminary Classi?cation Review of the Accused's Mental Impressions(ManningB).pdf Classi?cation. UNCLASSIFIEDCaveats: OUOSir.is Ihe Preliminary (7lassil'Ic.'ttion Review of PFC Manning. lfyou have any questions. please direct them to Fcin.Thank you.SARA J. ZIMMERMANSGT. US Amtv Classi?cation? Caveats: OUO --02873126From: Fein, Ashden CPT USA SJASent: Friday. September 24. 2010 347 PMTo: Cc: Morrow Ill. JoDean. CPT USA SJASubject: RE: Preliminary Classi?cation Review (UNCLASSIFIED)Sir. Any movement on your proposed Expert in the DC area? we finallyFound one, after going across all branches, without a clearance that wewill need to get for him (and you) if the review comes back requiring theclearance. Thanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN) 02185688 @C0nUS-army-mil]Sent: Monda Se tember 27, 010 4:09 PM To:Morrow Ill, JoDean, CPT USA Fein, Ashden CPT USA JFHQ-Subject: Meeting (UNCLASSIFIED)Signed By: ?@us.army.mi|Classification: UNCLASSIFIEDCaveats: FOUOA11,As discussed last week, the bi?week1y meeting will be at CCIU tomorrow, 28 Sep 13, at1309. I do not have everyone on the distro list, so please Forward as appropriate.Thanks, Washington Metro Resident AgencyComputer Crime Investigative Unit9865 Lowen Road, 193Fort Belvoir, VA 22066(Office)(Fax) Classification: UNCLASSIFIEDCaveats: FOUO 02215869From: Sent: Tuesday, September 28, 2010 7:16 PMTo: Fein, Ashden CPT USA SJA Morrow JoDean, CPT USA . JACc: Matthew kemkes Paul Bouchard1 Subject: PCRO IssuesAttach: PCRO Expert lssuespdfAshden,I have attached several issues that Mr. Ganiel has identified in order to conduct his preliminaryclassification review. Please take a look at this list, and let me how the government will address thevarious classified information requirements addressed in the memorandum.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02874488From: Fein, Ashden CPT USA SJASent: Wednesday. September 29, 2010 9:57 AM To: Morrow Ill, JoDean, CPT USA SJACc: Matthew kemkes; Paul Bouchard; Zimmerman, Sara SGT USA JFHQ- SJASubject: RE: PCRO IssuesSir,Acknowledge receipt. Any more movement on your proposed Expert in the DC area? weFinally found one, after going across all branches, without a clearance that we willneed to get for him (and you) if the review comes back requiring the clearance.Thanks.AshdenAshden FeinCPT, JAChieF, Military JusticeU.S. Army Military District of Washington (MON) 02215865 From: Sent: Wednesday, September 29, 2010 12:26 PMTo: Fein, Ashden CPT USA SJACc: Matthew kemkes Paul BouchardZimmerman, Sara]. SGT USA JFHQ- SJA mil>; Morrow JoDean, CPTUSA SJA Subject: RE: PCRO IssuesAshden,No positive movement. The person is deploying so I am back to the drawing board.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896rm 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02205366Morrow Ill, JODean, CPT USA SJAl0 3:54 PMTo: USA OTJAG anny.mil> Cc: Fein, Ashden CPT USA SJA Subject: access/disclosure (UNCLASSIFIED) Classi?cation: UNCLASSIFIEDCaveats: FOUOSir,As you know, PFC Manning's security clearance is currently suspended. Does he need some kind of additionalauthorization from the Army or Convening Authority to allow him to discuss or view classified information (with hisattorneys or others) he previously had access to prior to his suspension? This assumes that whoever he is discussingclassified information with is cleared as well. Thanks for your help.CPT Joe MorrowTrial CounselUS Army Military District of WashingtonClassi?cation: UNCLASSIFIEDavcats: FOUO 02873438From: Fein, Ashden CPT USA SJASent: Thursda September 30. 2010 9:46 PMTo: ?conus.an'ny.mi|Cc: Morrow JoDean. CPT USA SJA: Zimmennan. Sara J. SGT USAJFHQ- NCRIMDW SJASubject: PFC ManningSir. Good evening. On Monday or Tuesday, will you be available to have a brief phoneconversation and For us to present some defense and government requests to you For theManning case? I know you will be TDY next week. Based on the briefing, we will be able todocument your decision (VOCO) and based on your direction, sign the documents you.thank you. Vr AshdenAshden FeinCPT, JAChieF, Military JusticeU.S. Army Military District of Washington (MON)0221 7450Sent: Friday. October 1, 2010 3:03 AMTo: Fein. Ashden USA SJA Subject: PFC Manning (UNCLASSIFIED)Classi?cation. UNCLASSIFIEDCaveats: FOUOlwill.as number is-02205285Morrow JoDean, CPT USA SJASent: Monday, October 4, 2010 I I I I6 AMTo: USA omo Cc: Fein, Ashden CPT USA SJA Subject: follow up on access/disclosure authorization (UNCLASSIFIED) Classi?cation: UNCLASSIFIEDCaveats: FOUOSir,Following up on my email from last Wednesday. Do you want to attack the access/disclosure authorization issue a CPT Joe MorrowTrial CounselUS Army Military District of Washington Classi?cation: UNCLASSIFIEDCaveats: FOUO02882275From: Fein, Ashden CPT USA SJASent: Frida October 08, 2010 10:31 AMTo: he ARE USA USCENTCOM Subject: RE: 151 Cav Tapes (UNCLASSIFIED)Attachments: Appendix 7-A - Sample CR Affidavitdoc; Sample Affidavit for Classi?cation ReviewdocxSir.Attached are two sample affidavits for the OCA designated classification review authority.In these samples, you will see the ultimate three questions that need to be answered. Pleasecall if you have any questions. Thank you.v/rAshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 02870447From: Fein. Ashden CPT USA SJASent: Tuesday, October 12, 2010 7:48 AMTo: Cc: Kemkes. Matthew MAJ MIL Morrow JoDean. CPT USA JFHQ-NCRIMDW SJASubject: SCIF LocationSir. Good morning. when we spoke last Thursday, you were going to get back to me on Fridayto let me know if the Defense wants to give input into the convening Authorities decision onchoosing to use the Field Investigative Unit (FIU) SCIF for the Preliminary ClassificationReview and, depending on the results of the classification review, client meetings and RCM706. Please let me know ASAP so we can present to the CA early this week. Thank you.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (Mow) 02215854From: Sent: Tuesday, October I2, 2010 8:15 AMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Morrow Ill, JoDcan, CPT USA Paul BouchardSubject: RE: SCIF LocationAshden,I am sorry, I believed that I was supposed to get back to you on Friday only if the defense had anyissues. The FIU location is fine for the PCR, client meetings, and the 706 board.Please let me know the contact information for the second security expert as soon as you can so that I canget him/her up to speed. As I mentioned before, Mr. Ganiel will be out of the loop until the 18th ofOctober.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 thisinformation may be unlawful and is 02876275From: Fein. Ashden CPT USA SJATuesda October 12, 2010 11:14 AM To Cc @conus.army.mil; Overgaard, Angel M. CPT USA Morrow JoDean. CPT USA SJASubject: Manning DocsSir. Good morning. Are you available for a 5 minute phone meeting later this afternoon forsigning some documents For approval/disapproval? I can also give you an update on the?Summit? request. Thank you.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (Mow)02874834From: Fein, Ashden CPT USA SJASent 204FMATo: Habenand. John CPT USA Regimental JudgeAdvocateCc: SA MIL USASubject: RE: New Issues (UNCLASSIFIED)CPT Haberland Please let me facilitate this introduction. - is the security manager for Flu and CPTHaberland is the trial counsel that is assigned to the wiki(Manning) case and will be the POCFor coordinating movements.we would like to tentatively setup a rehearsal of the movement next Tuesday (19 Oct). Thiswill include the going from Quantico to FIU and how they will move the accusedthrough the halls to the conference room. Is this possible? Then we will be able toschedule with 4 days notice the first meeting with Manning and his security team. Please letme know.Also,-and CPT H, please include me and-on all emails so we maintain SA. Thanks.CPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of washington (MON) 02881482From: Fein, Ashden CPT USA SJASent: Wednesday, October 13. 2010 8:53 PMTo: Cc: Matthew kemkes; Morrow Ill. JoDean, CPT USA Paul Bouchard;Rose. Luke CPT USD-C SJA Chief, Military Justice: Habertand. John CPT USA RegimentalJudge Advocate; Zimmerman. Sara J. SGT USA JFHQ- Autry. Carolyn Ms CIV JFHQ-NCRIMDW SJASubject: CA Actions (US v. Manning)Attachments: 2-Appointment of 2nd Defense Security Expert (ManningB).pdf; 1-Excludable DelayMemorandum (ManningB).pdf; 4-Response to Defense Request to Amend Protective Order(Manning8).pdf; 3-Appointment of Defense Expeit Consultant in Forensic (ManningB).pdf; 5-Approved Facility and Storage for Classi?ed Information (ManningB).pdfSir. Attached are the following five convening authorities actions:Excludable Delay MemorandumAppointment of 2d Defense Security ExpertAppointment of Defense Expert Consultant in Forensic Response to Defense Request to Amend the Protective OrderApproved Facility and Storage for Classified InformationLHDLAJKJD-1we are still working on your request to receive a bates stamped copy of theunclassified portion of the case file.V/rAshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDW) 02219532Fro-n= mmanza? Pam Sent: Thursday, October I4. 20I0 5:59 PMTo: Fein. Ashden (TPT USA SJA Matthew 'em esMorrow JoDcan. USA SJACc: Zimmerman. Sara J. SGT USA JFHQ- SJ ASubject: !mcL Hanmng)All -Sincc it's bunt about a month since uc last l'tn in to if_\ou have an_\ ETA on the of the santt_\ board.as the cuncnt dcla} we're on ml] cxpirc \\hCl1lhC board is completed. plcasc some thought as to whether youzmucipatc sccking delay of course on thesanity board is expected to be completed).Thanks!I. 02881951From: Fein. Ashden CPT USA SJASent: Thursday, October 14. 2010 10:00 PMTo: Almanza. Paul; Matthew kemkes; Morrow Ill,JoDean, CPT USA Haberiand, John CPT USA Regimental JudgeAdvocate: Rose. Luke CPT USD-C SJA Chiet, Military JusticeCc: Zimmerman. Sara J. SGT USA JFHQ- SJASubject: RE: Article 32 (PFC Manning)Sir,Currently we are still in pre-RCM 706 delay for security matters. At this point, we do nothave an estimate on their completion, but once they are then we should move directly in theRCM 706 board, pending a determination of security clearances. Thank you.v/rCPT FeinAshden FeinCPT, JAChieF, ?ilitary JusticeU.S. Army Military District of Washington (MOW) 02872832FronnSentTo:Cc:Subk?nzGentlemen,Fein, Ashden CPT USA SJAThursday, October 14. 2010 10:02 PMSweda. Michael Dr CIV USA MEDCOM Zimmerman. Sara J. SGT USA JFHQ- NCRIMDW em, en Q-Matthew kemkes; Morrow JoDean_ CPT USA Haberland, John CPT USA Regimental JudgeAdvocate; Rose, Luke CPT USD-C SJA Chiet. Military JusticeRCM 706 (PFC Manning)Currently we are still delayed For the RCM 766 For security matters. Atthis point, we do not have an estimate on their completion, but once theyare then we should move directly in the RCM 786 board, pending adetermination of security clearances. Thank you.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Nashington (MDN) 02874482From: Fein, Ashden CPT USA SJASent: Tuesday, October 19. 2010 10:29 AMTo: Morrow JoDean. CPT USA SJACc: Matthew kemkes; Paul Bouchard; Rose.Luke CPT USD-C SJA Chief.MiIitary Justice;Habenand, John CPT USA Regimental Judge Advocate; Zimmerman, Sara SGT USAJFHQ- SJA. Autry. Carolyn 0 Ms CIV SJASubject: PCRO UpdateSir,Have you been able to speak with your security experts and see when they will be ready tostart the review. The rehearsal For PFC Manning's movement from Quantico Brig to the FIU andprocedures within FIU should be completed this morning. After that we will be ready toschedule the first of however many meeting need to occur for your team. Thank you.v/rAshdenAshden FeinCPI, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 0221 5824From: Sent: Tuesday, October 19, 2010 1:48 PM Cc: Matthew kemkes Paul BouchardRose,Luke CPT USD-C SJA Chief,Military JusticeHaberland, John CPT Regimental Judge AdvocateZimmerman, Sara J. SGT '_AutJy, Carolyn Ms JFHQ-Morrow JoDean, CPTTo: Fein, Ashden USA SJA USA JFHQ-NCSubject: RE: PCRO UpdateAshden,I spoke with Mr. Hall and Mr. Ganiel. I am meeting with them tomorrow to discuss the PCR and theiranticipated time-line for their work. After my discussion, I will give you more information on when theywill be ready to start their review. How did the rehearsal go? Who will be the POC for the movement ofPFC Manning? How often during any given week can Mr. Ganiel and Mr. Hall meet with PFC Manning atthe Are there any day/time restrictions on their meetings?Both Mr. Hall and Mr. Ganiel believe that a two-week time period is unrealistic to complete the verificationprocess. Does the CA have a date that he would like the investigation to either be completed or for thedefense experts to submit justification for additional time?On an unrelated note, I spoke with COL Benedek last week. He was unaware of his pending appointmentto the defense team. He told me that he believed he could act as the defense appointed expert, butthat he would need speak to his boss to be sure. I haven't heard back from him yet.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02205091Morrow JoDean, CPT USA SJAFrom: . ASent: Wednesday, October 20, 2010 3 :39 PMTo: Fein, Ashden CPT 3? Matthew k?mkeS? Paul Bouchatd Rose,Luke CPT USD-C SJA Chief,Military JusticeHaberland, John PT SA Regimental Judge Advocate Zimmerman, Sara J. SGT USA JFHQ- Autrv, Carolyn Ms CIV JFHQ-Subject: RE: PCRO Update (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir.Please send your expert's thoughts on timing and when they are ready to start so we can plan the first of multiple meetings I assume).The rehearsal went well and the JBM-HH DES is ready to transport PFC Manning from Quantico directly to the The isready to receive PFC Manning. except we will need to obtain the Full Name and SSN of _vour experts - please send at your earliesteonvenie nee. There are currently no date or time restrictions. although we would like to knock out the physical meetings during theweek. but can possibly coordinate weekends. if needed. If the review process ends up taking more than two weeks. then please send arequest a few days out so we can present it to the CA for his approval/disapproval of an extension.As for a request for delay to start the PCR: Based on the PCRO. dated 22 Sep 10. your security expert coiLsultant(s) were directed tostart meeting with the accused NLT 8 Oct 10. absent an extension by the CA. Subsequently your security expert. through you.requested an additional expert. storage facilities. and ultimately a SCIF. The CA acted on that request on I2 Oct 10. I do not think thedefense needs to request the extension as required by the PCRO because the subsequent order dated I2 Oct I0 essentially grants a defacto extension. Your security experts started to coordi mile to meet ASAP with the accused and we are coordinating that meeting foryouorder.We are not sure how lines got crossed with COL Bcnedek. We were under the impression that he had been detailed to the case by Dr(COL) Ricky Malone. Chief. Forensic for and the USA. It is possible that COL Bcnedek was confused about theDefense vs. Prosecution team.CPT John liaberland (CCed) is the main POC from the prosecution team for coordinating with FIU and the escorts for PFC Manning.Please send the infonnation requested above (full name and SSN of defense experts) to him so he may pass along the info to the FIU.Thanks.AshdenJoe MorrowTrial CounselUS Annv Military District of Washington 02215811From: Sent: Thursday, October 2010 8:50 AMTo: Morrow JoDean, CPT USA SJA Cc: Matthew kemkcs Paul BouchardRose,Luke CPT USD-C SJA Chief,Military JusticeHa erland, John CPT USA Regimental Judge AdvocateZimmerman, Sara J. SGT USA JFHQ- Autry, Carolyn Ms CIV JFHQ-SJA Fein, Ashden CPT USASJA l>Subject: RE: PCRO Update (UNCLASSIFIED)Joe,I met with Mr. Hall and Mr. Ganiel yesterday. They would like to start their work by meeting with PFCManning at the FIU next Wednesday (27 October) at 1000. They anticipate this first meeting to lastapproximately three hours. This is the only meeting that they want to schedule for the first week. Basedupon this meeting, they will be in a better position to determine how many additional meetings may benecessary and an estimated time-line for the verification process.Mr. Hall and Mr. Ganiel have requested the following additional informationwith a phone number to ensure the necessary arrangements have been made forthe PCR. I will let Mr. Hall and Mr. Ganiel know that the FIU needs their full names and social securitynumbers. I believe they would like to give this information directly to the POC at the FIU instead of goingthrough multiple layers;b) Do the guards from the con?nement facility understand that they cannot be inside the room with PFCManning during the meeting with Mr. Hall and Mr. Ganiel? what arrangements have been made to ensurethat this is not an issue;c) PFC Manning's training records;d) Any documentation PFC Manning has signed dealing with information security;e) A list of all CI that PFC Manning has been read in on;f) A list of any refresher training PFC Manning has received;g) A list of any in-country training PFC Manning has received;h) who was the security manager at the time for the TSCIF PFC Manning worked in and can you give Mr.Ganiel and Mr. Hall contact information for this person;i) What was the SOP for the TSCIF PFC Manning worked in;j) What kind of entry/exit inspections were performed at the k) A copy of the Security Classification Guide for the With regards to the five discs that were previously given to the defense. These discs will likely assist inthe verification process. Mr. Ganiel and Mr Hall would like to know if these discs are classified or not? Ifso, who classified the discs? What is the highest level of classi?cation for the information on the discs? Ifthe classification is unknown or uncertain, Mr. Hall and Mr. Ganiel would need to have a stand-alonesystem provided to them classified at TS-SCI (laptop with removable hard drive) for them to review theinformation on the five discs.Let me know if you have any questions or concerns.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th Floor02215811Fall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 021 85629From:Sent:To:Subject: CIV USA USACIDC Mon ctober25 20I0 12:39 PMcDic.fbi.ov>' mc. 1.gov>;ov>;@ic.fbi.gov>"tau n>rgov>:EjUSAVA ajusdoj .gov>; ?usdo' (F/ic.fbi.0v> Mr CIV USA a us.army.mil>;CIV USA USACIDC ._a2us.army.mil> SA MIL USAFein, Ashden CPT USA SJAMorrow De PT A >us.annv.mil>' @us.a1my.mil>;Bi-Weekly Meeting (UNCLASSIFIED)Classilicution Caveats. All,?and I discussed the meeting originally scheduled for 1300/26 Oct l0 at CCIUL and with the lR'I?l' meeting in the muming, have tochange. lhe meeting will now be held at Oct It) (Wednesday), still at CCIU.Thanks,Acting Special Agent in Washington Metro Resident AgencyComputer Crime Investigative Unit98()5 Lowen Road, 193Fort Bclvoir, VA 22060(OtTicc)(Fax)Classi?cation: Caveats: 02877777From: Fein, Ashden CPT USA SJAMonda October 25. 2010 9:00 PM To: dodiismilCc: Morrow Ill. JoDean, CPT USA SJASubject Meetingnnponance: we just found out about the IRTF and prosecution teams meeting tomorrow morning. If its nottoo late, could we still attend. our information is below and I have a DIA blue badgealready, if that works.Ashden Fein, CPT, U.S. Army Military District of Washington, 643-18-S904Jodean Morrow, CPT U.S. Army Military District of Nashington, 337-74-4414Thank you.Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN)02187790 From:Sent:To:Cc:Subject:Signed By:dodiis.mil]Tuesday, October 26, 2010 7:03 AMFein, Ashden CPT USA SJAMorrow Ill, JoDean, CPT USA SJARE: IRTF Meetingd0diiS.mil It?s not too late, Ashden. See you later this morning.02879567From: Fein, Ashden CPT USA SJASent: Thursda October 28, 2010 8:27 AMTo: Cc: Morrow JoDean, CPT USA ?(mox-SMO)Subject: Data Set Review2,Good morning. After having our investigators run multiple forensic searches and ultimatelybuild a spreadsheet to assist us in sifting out different MRNS, we have a data set we wouldlike to discuss with you for our charging decision. Are you available tomorrow afternoon orearly next week to meet and discuss? we would also like to discuss our preferred OCA reviewsand to provide you with an overview of how we see the information being used throughout thecourt?martial process.Thanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN) 02215770From: coombs@armycourtm artialdefensecomSent: Thursday, October 28, 2010 5:00 PMTo: Fein, Ashden CPT USA SJA Morrow JoDean, CPT USA JACc: Matthew kemkes Paul BouchardSubject: Information Assurance ExpertAttach: IA Expert Ashden - Joe,I have attached a request for an information assurance expert. Mr. Hall and Mr. Ganiel met with PFCManning last Wednesday. Based upon information that they received, they have asked that an IA expertbe appointed to the defense team.Mr. Hall and Mr. Ganiel believe that one or two more visits with PFC Manning will be needed. They havenot given me a time line for completion of the PCR. They have, however, told me that they arereasonably confident that everyone will need a clearance.Feel free to call me if you have any questions or concerns.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02877853 From: Fein. Ashden CPT USA SJASent: Thursday, October 28, 2010 6-36 PMTo: Morrow Ill. JoDean, CPT USA SJACc: Matthew kemkes; Paul BouchardSubject: RE: Information Assurance ExpertSir,Thanks. Acknowledged. we owe you answers on this new request and yoursubsequent request providing your defense experts with specific information.we are diligently working the requests.AshdenAshden Feincpr, JAChief, Military JusticeU.S. Army Military District of Washington (MDN) 02873392From: Fein, Ashden CPT USA SJASent: Hide October 29 2010 9:04 AMTo: SA OTJAGSubject: RE: Phone Call (UNCLASSIFIED)Thanks sir. Actually are you available in 5 minutes?Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON)3 02212952 -From: OTJAG Sconus.army.miuSent: Friday, October 29, 2010 9:06 AMTo: Fein, Ashden CPT USA SJASubject: RE: Phone Call (UNCLASSIFIED)Signed By: musarmymilClassification: UNCLASSIFIEDCaveats: NONESure. Office of the Jud Advocate General of the Army, Pentagon 3D548NIPR: SIPR: QDA?S.army.smi1.mi1JWICS:Tel: 02979401Fr?m= ?@doc-gov!Sent: Thursday, March 01, 2012 4:00 PMTo: Bradle Princeton L. SGT USA SJACc:Subject: RE: Request to Review NCIX Response (UNCLASSIFIED)Sgt. Bradley,After conferring with our Office of General Counsel, please provide us with a formal requestthat contains:what information is needed, for what reason, who is the requestor, and under whatauthority is the request being madeAssurance that the information will only be disseminated through proper procedures fortransmittal of classified material and to appropriately cleared US Government personnel witha need to knowAssurance that the information is not used for any other purpose than your review,unless the Department of Commerce provides additional authorization Assurance that the documents which contain the information are returned to theDepartment of CommerceIf this matter requires further discussion, please contact me. Thanks for yourconsideration.p.S. Department of Commerce Office of Security1401 Constitution Ave NWWashington, DC 26239 02979401 02925507From: Fein, Ashden CPT USA SJASent: Thursday, March 01, 2012 7:18 PMTo: . David CoombsCc: Matthew kemkes; ?Paul Bouchard'; ?Joshua Tooman'; ?Melissa Santiago?; Morrow JoDean,CPT USA Overgaard, Angel M. CPT USA Whyte, Jeffrey H. CPT USA Ford, Arthur D. W01 USA JFHQ-SJASubhct RE:MummeHemsDavid,A. For your client's mail:Supporters or family may send mail to:Commander, HHC USAGAttn: PFC Manning239 Sheridan Ave, 417JBM-HH, VA 22211The mail will be logged once it is received at the company. Mail will be collected until acommand visit and then it will be brought to the facility. Mail will be screened inaccordance with the inmate hand book at the HCCF and then given to PFC Manning. If it mustbe returned or destroyed for any reason then that will be annotated on the log. PFC Manningwill sign the log to indicate that he received that mail on that day.B. As for your Touhy information request below:1. Yes. According to 5495.2 and AR 27-46, Touhy appears to not apply to access topersonnel or information for courts?martial.2. we are working with the organization to determine an appropriate response and the wayforward. I searched the CFR and found 22 CFR Part 172.3. we are working with the organization to determine an appropriate response and the wayforward. I searched the CFR and found the cite. If you call, I can give it to you over thephone so long as it is stored separate and apart from your email based on the sensitivenature; however I recommend typing the organization's name and "Touhy" in google, and youwill be pointed to the citation.4. we have been working with the organizations to determine if there is a streamlinedprocess either through the Touhy process or as an exception. we have also made it clear thatif Touhy is the only way and it does not hinder the process, that we as the militaryprosecution intend to submit the documents for the defense, once the defense completes therequirements.5. Early this week, the prosecution became aware that the normal course for all defensecounsel is to submit a Touhy request. Prior to then and continuing today, the prosecutionhas worked to see if there was a streamlined process to obtain the information.C. Uniforms: The command will contact you tomorrow.D. EnCase images: As previously stated, based on the defense preservation request, theUnited States preserved all the drives that could be reasonably located in the government.As we prepare for our motion response, we are updating the status of these drives to1 02925507understand the population that exists and finalizing whether any of them are discoverable(and produce them) or potentially discoverable (if the military judge rules in Favor of thedefense).v/rAshden02979731From: C@rcc.sov1Sent: Friday. March 02,2012 10:34 AMTo: Bradte Princeton L. SGT USA SJACc: Subject: RE: Request to Review NCJX Response (UNCLASSIFEED)Attachments: RE: Request to Review NCIX Response (UNCLASSIFIED)Here is what? the FCC security officer?, provided me. Please Contact us if youhave any further questions.For Internal Use Only work Product 0- Associate GeneralCounsel Federal Communications CommissionCC. OV02564547From: David Coombs Sent: Friday, March 2, 2012 12:11 PMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes ?Paul Bouchard?'1 Oshua T00man' ?Melissa Santiago? Morrow oDean, CPT USASJA Overgaard, Angel M.CPT USA 51A Whyte,Jeffrey H. use SJA ma Ford,Arthur D. W01 USA SJA ?mSubject: RE: Multiple ItemsAshden,I've spent the past couple of days trying to wrap my mind around your Touhy issue, and I can't seem to process what youthink this means going forward. If I understand what you are saying, despite the Government's discovery obligationsunder Williams, you think there is an additional impediment (the Touhy request) to the Defense getting discovery? So,even if a judge determines that the material is relevant and should be disclosed, you (the Government) will not discloseit and will require the Defense to go through cumbersome administrative channels to try to obtain this material?Ultimately, as you likely know, the agencies will deny access to these materials because they are classified, and that isone of the bases for denial of a Touhy request. So, even if you are ordered to produce this material, it will not beproduced because of bureaucratic red-tape.I'm sorry to be beating a dead horse, but if this is your position, it seems utterly crazy to me. Moreover, I don'tunderstand how the Government was able to provide other discovery from agencies outside the DOD, under your view,absent a Touhy request? With the discovery you already provided, you searched other agencies and provided theDefense with the relevant materials. Why is this any different? Are you saying it's different because in one scenario, theGovernment handed things over voluntarily, but in the other scenario, the Government would be handing things overpursuant to a Motion to Compel? If that's the case, then couldn't the Government simply deny discovery of materials itdidn't want to hand over to the Defense, have a judge order the production of the discovery, and then set Touhy up asthe ultimate roadblock? In other words, it seems that the Government ultimately controls whether the Defense willultimately have a "Touhy issue." Further, if a Motion to Compel is granted, it is the Government that is ordered toproduce evidence i.e. go get it and give it to the Defense. So I don't see how Touhy is implicated at all given that thediscovery request is of the Government, and not of the agency itself.Another thing I don't understand is that you've had access to these witnesses (since you were able to obtain the OCAunsworn declarations). You also represented at the Article 32 that all of these individuals were prepared to testifytelephonically if needed. This would appear to be a clear violation of Article 46 if you are now attempting to preventequal access to these witnesses by hiding behind Touhy.Finally, if under your view, Touhy regulations clearly apply as part of the criminal process and this is the way thatdiscovery/witness requests must be processed (even when compelled), how is it that you've only learned of this processa week ago? As you well know, I have been submitting discovery requests for a year and a half. I have been asking invarious capacities to speak with the OCAs for 5-6 months. How can you not have informed yourself of how mydiscovery/deposition requests could be satisfied before now? It seems that either: a) you were not diligent in processingDefense requests, or b) Touhy is not actually an impediment to me getting the relevant discovery, but rather an 11th-hour roadblock conveniently erected by the Government.I really need you to provide more clarity on the Government's position. Please do not tell me that you are "working withthe relevant agencies to find an answer.? The Government's position on how Touhy affects this case does not dependon consultation with other organizations. I ask that you clarify exactly how you think Touhy applies to your discovery02564547obligations by Monday at 5:00, so that we can be prepared to discuss this at our 802 Conference on Tuesday.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angeli Street, #317Providence, R1 02906Toll Free: 1-800-5884156Locai: (508) 689-4616Fax: (508) 689-9282Notice: This transmission, inciuding attachments, may contain confidentiai information and is intended for the person(s) or company named. If you are not the intended recipient, please notifythe sender and deiete all copies. Unauthorized disclosure, copying or use of this information may be uniawfui and is 02925484From:Sent:To:Cc:Subject:David,Thank you.Fein, Ashden CPT USA SJAFriday. March 02, 2012 12:23 PMDavid CoombsMatthew kemkes; ?Paul Bouchard'; ?Joshua Tooman'; ?Melissa Santiago?; Morrow Ill. JoDean.CPT USA Overgaard, Angel M. CPT USA Whyte, Jeffrey H. CPT USA Ford, Arthur D. WO1 USA JFHQ-SJARE: Multiple ItemsOn Monday, I will provide you a more detailed reply to this email; however attirst glance, I think you are misinterpreting or not understanding what I have previouslywrote.Overall this does not prevent the defense's access to witnesses and information, itsimply sets out requirements to request access under certain circumstances (as outlined inthe CFRS).v/rAshden02979725From: ?@epamaiI.epa.govlSent: Friday, March 02, 2012 12:54 PMTo: Bradle Princeton L. SGT USA SJACc:Subject: Re: Request to Review NC IX Response (UNCLASSIFIED)Sergeant Bradley:EPA has no documents to provide to the Department of the Army, per your request, below.Approximately one year ago, after reviewing approximately 2466 documents, EPA determined thatthere were no EPA documents that were problematic and needed to reported and provided toNCIX. EPA informed this to NCIX in an informal, oral communication. Office of General Counsel 02925640From: Fein, Ashden CPT USA SJASent: Monday, March 05, 2012 4:59 PMTo: Cc: Matthew kemkes; Paul Bouchard; Joshua Tooman; Melissa Santiago; Morrow JoDean,CPT USA Overgaard, Angel M. CPT USA Whyte, Jeffrey H. CPT USA Ford, Arthur D. W01 USA JFHQ-SJASubmct RE:MummeHemsDavid,Bottom line, the United States will not withhold any evidence based on the Touhy regulations.Our interpretation of the Touhy regulations and relevant case law is that the regulations areNOT a basis to withhold evidence from the defense. The Touhy regulations simply centralizethe decision making process within an agency, in order to provide information based onsubpoena, judicial order, or private party requests.Your prior requests, based on the purported authorities, were denied for multiple reasons,and then you asked for access based on the individuals being potential defense witnesses.This Touhy?issue arose when you asked for an update on the prosecution obtaining access totwo individuals for you to interview outside of the judicial process? thus a private partyrequest for an interview.If you do not wish to wait on a Court's ruling, then you may submit a Touhy request to theentities and request access to the individuals.It is the prosecution's intent to continue helping the defense obtain access, although theTouhy regulations do not make an exception for our assistance. The prosecution will assistyou with these requests, if you choose to go down this path concurrent with the judicial?process. If_the Court rules in favor of the defense on discovery or depositions dealing withoutside agencies, then the prosecution will continue to coordinate this judicial process withthe agencies under their Touhy regulations.Although Touhy applies, the prosecution does not forecast any issues with subpoenas orjudicial orders being executed under each entity's applicable rules. Again, Touhy is not abasis to withhold evidence, but rather a housekeeping rule to process requests and ensurecentralized decision?making. If information is withheld under Touhy regulations, it will bebased on a proper authority, such as the classified information privilege.v/rAshden02564499From: David Coombs Sent: Monday. March 5, 20l2 5:23 PMTo: Fein. Ashden CPT USA SJA Ce: Matthew kemkes ?Paul Bouehard' ?Joshua Tooman' Morrow Ill, JoDean, CPT USAOvergaard, Angel M.?Melissa Santiago?SJ ACPT USA SJAJeffrey CPT USA SJA Arthur D. WOI USA SJASubject: RE. Multiple ItemsBased ClTl.'Jll_ it is understand that.1) If the Conn orders depositions. }ou do not see the need fora Tollh) rmiiest from the and believe the Coun's order willbe complied with by the OCAS.2) if the Court orders the Defense requested discover)?. you do not see the need for it Touhy request from the Defense and believethe Cour1's order will be complied itli by the ?at If the Court orders the Defense requested discover). it will either be provided to the Defense or the Govemmem will seek tonot disclose the infonuatioii pursuant to 505; andl) If the Court does not order depositions. you believe that Touhy does apply and would necessitate zi request fonii theDefense in order to be provided equal access to the requested OC As under Anicle 46.Please me if the above is correct. Thank youBest.DavidDavid E. oonibs. EsqLziu Office of David E. (Toombsll South Angeli Street. #317Providence. RI t)2?)t)6Toll Free: I-800-588-1 56Local: (508) Fax? 689-9282coombs (2 aniiycouninanialdefciise.coiu??*Coiifideiitialit} Notice: This tmiisinission. including eoii?detitial and isintended for the person(s) or coinpany named. it you are not the intended recipient. please notify the sender and delete all copies.Unriutliori/.ed disclosure. copy ing or use of this inforuiatioii be unlziuliil and is prohibited 02925613From: Fein, Ashden CPT USA SJASent: Monday, March 05, 2012 5:51 PMTo: David CoombsCc: Matthew kemkes; ?Paul Bouchard'; ?Joshua Tooman'; ?Melissa Santiago?; Morrow JoDean,CPT USA Overgaard, Angel M. CPT USA Whyle,_Jeffrey H. CPT USA Ford, Arthur D. W01 USA SJASubject: RE: Multiple ItemsDavid,If the Court orders any process, then the prosecution will work with the entities under theirTouhy rules and will not turn to the defense to submit requests on top of the Court orderedprocess- the prosecution is responsible under the military justice system to obtain Courtordered evidence; however an entity can still object, but will have to state a proper basis.The prosecution has no reason to believe an entity will object, except on the basis ofclassified information. If there is no Court ordered process, then the defense will need tosubmit a Touhy request to speak with any Government employee outside of the pursuant tofederal law.It is the prosecution's intent to continue helping the defense obtain access, although theTouhy regulations seem to not make an exception for our assistance, but we will continue toendeavor to assist.I hope this clarifies the issue.v/rAshden 02564470From: David Coombs Sent: Monday, March 5, 2012 6:07 PMTo: Fein, Ashden cm USA SJA Cc: Matthew kemkes ?Paul Bouchard' 'Joshua Tooman' Morrow ill, JoDcan, CPT USA31>; Overgaard, Angel whyte,Ford. issa antiagoCPT USA Jeffrey H. CPT USA Arthur D. W01 USA SJA Subject: RE: Multiple ItemsAshden,Thank you. That does provide clarity. If the request for depositions is denied, I would like to submit a Touhv request forMr. Kennedy and for the OCA of Spec 3 and 15 of Charge II. Since each agency has its own specific requirements, canyou provide me with the format that the DOS and the OCA for Spec 3 and 15 of Charge II would require for such arequest? One potential problem with the Touhy request is that I will not know for sure the substance of the testimonyexpected of the relevant employee (other than what was stated in the classification determinations). This is one of thereasons that I would like to speak to these individuals.Finally, with regards to the DOD OCAs, I plan to wait on the judge's ruling regard the depositions before attempting tospeak with any of them. If the Court does not order depositions, does the Government want the Defense to go througha specific POC for each OCA (as the Government requested the Defense to do with Mr. Betz)? If so, could theGovernment be prepared to provide those POCs on the 16"? of March?Best,DavidIdentify the employee or record;Describe the relevance of the desired testimony or records to your proceeding and provide a copy of the pleadingsunderlying your request;Identify the parties to your proceeding and any known relationships they have to the Department's mission orprograms;Show that the desired testimony or records are not reasonably available from any other source;Show that no record could be provided and used in lieu of employee testimony;Provide the substance of the testimony expected of the employee; andExplain why you believe your Touhy Request compliesDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angeli Street, #317Providence, RI 02906Toll Free: 1-800-588-4156Local: (508)689-4616Fax: (508)689-9282Notice: This transmission, including attachments, may contain confidential attorney-client02564470information and is intended for the person(s) or company named. If you are not the intended recipient, please notifythe sender and delete all copies. Unauthorized disclosure, copying or use of this information may be unfawfui and is02925558From:Sent:To:Cc:Subject:David,Fein, Ashden CPT USA SJAMonday, March 05, 2012 6:27 PMDavid CoombsMatthew kemkes; ?Paul Bouchard'; ?Joshua Tooman'; ?Melissa Santiago?; Morrow JoDean,CPT USA Overgaard, Angel M. CPT USA Whyte, Jeffrey H. CPT USA Ford, Arthur D. W01 USA JFHQ-SJARE: Multiple ItemsIf the depositions are denied, the prosecution will assist with setting up the Touhy request,to include submitting them on behalF 0F the deFense (this will have to occur for one of the0CAs based on the classification). As For the 0CAs, we will start accumulating theproper POCs For each OCA so that the defense may reach out to them. we should be able toaccomplish this by 16 March, absent some major intervening issue.V/rAshden02936386From: Fein, Ashden CPT USA SJASent: Monday, March 05, 2012 6:27 PMTo: David CoombsCc: Matthew kemkes; 'Bouchard, Paul CPT USARMY ?Joshua Tooman'; ?Santiago,Melissa CW2 USARMY Morrow JoDean, CPT USA Overgaard, Angel M. CPT USA Whyte, Jeffrey H. CPT USA JFHQ-Ford, Arthur D. WO1 USA SJASubject: RE: Discovery Production UpdateDavid,we will start working on this tomorrow.v/r?Ashden02 564466From: David Coombs Sent: Tuesday, March 6, 2012 1:47 PMTo: Fein, Ashden CPT USA SJA Ce: Matthew kemkes 'Paul Bouehard''1 Oshua ?Melissa Santiago? Morrow Ill, JoDean, CPT USAOvergaard, Angel M.CPT USA SJA Whyte,Jeffrey CPT USA SJA Ford,Arthur or W01 USA SJA Subject: Clari?cationAshde n.With regards to missing emails due to the term WL, is the Government sure that it has received all entails from OCAS/investigativeagencies. etc. regarding potential Brady maten'aJ'.? In other words. if an agency sem the Govemment potential unclassi?ed Bradymaterial in an email that contained the term WL. would you have received the email?? I understand that you were able to retrieve non-received emails. Were you able to retrieve all non-received emails - or was there a date limit for how far back you could see blockedemails??Also. with regards to the Clause 3 the Govemmenl has included the Clause 1 and 2 language mllun each Clause 3speci?cation. Given that fact. is the planning on including recommended elements for the Clause 1 and 2 offenses shouldthe panel conclude that the specific Clause 3 offense is not proven'.?Best.DavidDavid E. Coombs. Esq.Law Office of David E. Coombs11 South Angel] Street. #317Providence. RI 02906Toll Free: Local: (508) 689-4616Fax: 689-9282**?Conf1dentiality Notice: This transmission. including attachments. rnay contain con?dential atlomey-client infonnation and isintended for the pcrson(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 02915513From: Fein, Ashden CPT USA SJASent: Tuesda March 06 2012 3:05 PMTo: teal)Cc: Whyte, Jeffrey H. CPT USA SJASubject: FW: US v. PFC BM (Preservation Request)Could you please provide us an update on this preservation request. Does the FBI have anyforensic images of drives that were collected from 2/10 MTN in Iraq that were not part ofCID's evidence? Thank you.v/rAshden02935108From:SentTo:Cc:Sumem:All,Fein, Ashden CPT USA SJATuesda March 06,2012 3:10 PMFBI - Morrow Ill, JoDean, CPT USA Overgaard, Angel M. CPT USAWhyte, Jeffrey H. CPT USA Ford, Arthur D.WO1 USA SJAFBlCaseFHeAfter Artie consolidated all of the reviews done NFO, FBI HQ, and EDVA, wehave the Following numbers: we would like to get the First two batches ready to go, so once the judicialprotective order is in place, we can disclose these documents. Thanks!Ashden02564465From: David Coombs Sent: Tuesday, March 6, 20l2 559 PMTo: Fein, Ashden CPT USA SJA Ce: Matthew kemkes 'Paul Bouchard''Joshua Tooman' ?Melissa Santiago? Morrow 111, JoDean, CPT USASJA Overgaard, Angel M.CPT USA Whvte.Jeffrey CPT USA SJA Ford.Anhur 1). W01 USA SJA Subject: Excludable DelayDoes the Govcmment have an_v documentation concerning the accounting of thetime for the time period between IS December 201 I and the date of refenal?.?The last excludable delay that I have covers 16 November 20] I to I5 DecemberBest.DavidDavid E. Coombs. Esq.Law Office of David E. Coombsll South Angeli Street. #317Providence. RI 02906Toll Free: I-800-588-4156Local: (508) 689-4616Fax: (508) 689-9282*??Con?dentiality Notice; This transmission. including attachments. maycontain con?dential attomey-ciiem infomtation and is intended for theperson(s) or company named. Ifyoti are not the intended recipient. pleasenotify the sender and delete all copies. Unautliorized disclosure. copyingor use of this infonnation may be unlawful and is 02935268From: Fein, Ashden CPT USA SJASent: Tuesday, March 06, 2012 6:06 PMTo: Fein, Ashden CPT USA ?David Coombs'Cc: Matthew kemkes; ?Paul Bouchard'; ?Joshua Tooman'; ?Melissa Santiago?; Morrow Ill. JoDean,CPT USA Overgaard, Angel M. CPT USA Whyle, Jeffrey H. CPT USA Ford, Arthur D. W01 USA JFHQ-NCRIMDW SJASubject: RE: Excludable DelayDavid,Thank you For the email. we will get you a response to this email and your previous in thenext Few days.V/rAshden 02864516From:Sent: Wednesday, March 07, 2012 8:10 AM To: Hughes, Brian A. LTC USA SJASubject: RE: US v. PFC BM (DOD PSR) (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOv/r02930219From: uspes.go?1Sent: Wednesday, March 07, 2012 11:45 ATo: Bradley, Princeton L. SGT USA SJASubject: RE: Request to Review NCIX Response (UNCLASSIFIED)have contacted you on behalf of the prosecuting attorneys to request a point of contact inyour General Counse1?s Office with regard to the documents your organization sent to the NCIXregarding the ?w#kileaks" incident. Those documents, should they be deemed relevant andnecessary, would be used in the U.S. Army Court Martial of PFC Bradley Manning, but only withthe permission of your agency."Sergeant Bradley,I believe I know what you are referring to. Shortly after the "w#kileaks? incident, I wascontacted by NCIX and given a briefing. They said they had done a word search (the wordsbeing "Postal", "Inspection", and Service") of the released records and found threepertaining to the Postal Inspection Service. They provided me with a CD containing thereports and asked me to review them and advise if we had been compromised in any way.The Postal Service does not have original classification authority, so I was somewhatsurprised that they had found anything pertaining to us. I reviewed the documents and theywere all the same document. It was a summary of activities compiled by another agency. Idon't know why it was classified. It mentioned a visit to a U.S. Attorney's Office andlisted what agencies were present. One was the Postal Inspection Service. The informationwas meaningless. I either phoned or emailed the NCIX contact and advised him of this. I didnot send any documents to the NCIX (?with regard to the documents your organization sent tothe Please advise if you need anything further. 02564458From: Sent: Saturday, March 10, 2012 2:40 PMTo: Fein. Ashden USA SJA Cc: Matthew kemkes . 'Bouchard, Paul USARMY ?Santiago, Melissa USARMYMorrow Ill, JODean, CPT USA Overgaard. Angel M. CPT USAWhvte. Jeffrey H. CPTl-zord. Arthur NC . SJAUSA SJAUSA SJASubject: RE. Delivery of DocumentsCan somebody from the Government please reportd to my email from this morning? Your motion responseswere due Thursday. and it is now Saturday and the Defense team is not in possession of all of yourdocumentation This is unacceptableDavidDavid Coombs, EsqLaw Office of David E. (?oombsll South Angell Street. #317Providence, RI 02006Toll Free? 1-800-588-4156Local? (508) 6894l6l6Fax? (508) 689-9282l\'otice' This transmission, including attachments. may contain con?dential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Ljnauthonzed disclosure, copying or use of this infomtation may beunlawful and is prohibited.??*02564447 From: David Coombs Sent: Sunday, March I I. 20l2 3:20 PMTo: Fem. Ashden (TPT USA SJA Cc: Matthew kemkes 'Bouchard, Paul USARMY (USY SJASJAITSA SJAUSA SJA Subject: RE. Delivery of Documents?Santiago, Melissa CW2 USARMYMorrow Ill. JoDeari, CPT USA WHO-Overgaard, Angel M. CPT USAWhyte. Jeffrey H. CPTFord. Arthur Ashden.I think lime a fundziinental problem ttli your entail issues are being addressed. Hie emails that I sent to you on Saturdax didml get kicked back until the end of the d2I_\? and the early nioniing hours of Sunday? I am eoncenied you not bereccixing from not only from others. Thus. I would like to [ind out how far you were able to you were missingeiuziils that referenced WL. Also. I knon that _\ou lime added your AKO address. but ue should also add :1 conunercial address toyour list. Would you have a problem ith that suggestion to allex tale this issue??. Best.DavidIDan id E. Cooinbs. Esq.. Li-1\\ Office of David E. CoombsII South Angeli Street. MI7Providence. RI 02906Toll Free: I SoLocal: (508) 689-1616Fax: (508) (I89-9282coombs'a comxi Notice; This ir.ntsinissioiL including nia_\ comatn conlideiitial intended for the pct$on(s) or company named. If you are not the intended recipient. please notif) the sender and delete all copies.ljmutliorized disclosure. copying or use of this IIl(l}' be unlau fit] and is 02979855From: _@usitc.govSent: Monday, March 12, 2012 8:40 AMTo: Bradley, Princeton L. SGT USA SJACc: Subject: RE: Request for Office of General Counsel Point of Contact (UNCLASSIFIED)Sgt. Bradley,Here is the contact information For the POCS in the General Counsel's office. SIPRNET andJHICS email addresses are not available. IF classified communications are required, pleasecontact me For alternative approaches.They have been cc'd on this email.Thanks,02979706From: ?@va.gov1Sent: Monday. March 12, 2012 2:57 PMTo: Bradle Princeton L. SGT USA JFHQ-NCRIMDW SJACc:Subject: FW: Request for OGC Point of Contact (UNCLASSIHED)Attachments: Undeliverabiez Request for OGC Point of Contact (UNCLASSIFIED)Follow Up Flag: Follow upFlag Status: CompletedPrinceton: Iim resending, as I got the attached undeliverable message in response to myoriginal email, below. _will be in touch with you on this matter. Office of General Counsel U.S.Department of Veterans AffairsThis message may contain information that is confidential and/or protected by law. If it hasbeen sent to you in error, please reply immediately to advise the sender of the error andthen destroy this message, any copies of this message and any printout of this message. Ifyou are not the intended recipient of the message, any unauthorized dissemination,distribution or copying of the material in this message, and any attachments to the message,is strictly forbidden.02564423From: David Coombs Sent: Tuesday. March 13, 2012 9:46 AMTo: Fein, Ashden CPT USA JFHQ-NCIUMDW SJA CC: Matthew kemkes 'Bouchard, Paul CPTUSARMY (usy ?Joshua Tooman''Santiago, Melissa CW2 USARMY Morrow JoDean, CPT USA SJA Overgaard, Angel M. CPT USA JFHQ-SJA Whyte, Jeffrey H. CPT USASJA Ford, Arthur D. CW2 i;sASJA Parra, Jairo A. woi USASJA mmSubject: Email AddressI have created an email account for the govemnient called The password for the account is passwordl234. I will be sending defensereply motions today to your govermnent addresses. Please respond so that Iknow you that lime received the reply motions. ln the future. unlessdirected not to do so by the Coun. I will send defense emails to the yahooaddress as well as your government addresses.As I asked you several weeks ago. can you tell me what steps the govcmnienthas taken to ensure that it has received all previously blocked emails thatcontained How far back did the govemme nt block emails with the word?Let me know if you have any questions.Best.DavidDavid Coombs. Esq.Law Office of David F.. Coombsll South Angell Street. #317Providence. RI 02906Toll Free: Local: (508) 689-1616Fax: (508) 689-9282Notice: This trzuisinission. including attaclinieiits. maycontain confidential attoniey-client infoniiation and is intended for thepcrs0n(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure. copyingor use of this infonnation may be unlawful and is prohibited 02935666From:Sent:To:Cc:Subject:Importance:David,Fein, Ashden CPT USA SJATuesday, March 13, 2012 9:48 AMDavid CoombsMatthew kemkes; 'Bouchard. Paul CPT USARMY ?Joshua Tooman'; ?Santiago,Melissa CW2 USARMY Morrow Ill, JoDean, CPT USA Overgaard, Angel M. CPT USA Whyte, Jeffrey H. CPT USA JFHQ-NCRIMDW Ford, Arthur D. CW2 USA Parra. Jairo A. W01USA SJARE:EmaHAdmessHighPlease do not send any government document to a civilian account. Please send to our normalemail and include my AKO. This is a security issue that'we can take up with the M3 thisweek. Thank you.v/rAshden02935663From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Tuesday, March 13, 2012 9:52 AMTo: David CoombsCc: Matthew kemkes; 'Bouchard, Paul CPT USARMY ?Joshua Tooman'; ?Santiago,Melissa CW2 USARMY Morrow Ill, JoDean, CPT USA Overgaard, Angel M. CPT USA Whyte, Jeffrey H. CPT USA Ford, Arthur D. CW2 USA Parra, Jairo A. W01USA SJASubject: RE: Email AddressImportance: HighDavid,Additionally, I am working on getting you an answer to your question you asked last week on 6March 2612 and asked again on this past Sunday. The most efficient way to ensure we receivean email is to wait an hour replies that we received the email.If not, then I recommend calling our office to confirm receipt and then we can go forward.V/rAshden02978026 From: Sent: Tuesday. March 13, 2012 10:29 AMTo: Bradley, Princeton L. SGT USA SJASubject: FW: NCIX Documents (UNCLASSIFIED)Follow Up Flag: Follow upFlag Status: FlaggedCategories: Red CategoryGood Morning Sgt. Bradley, hope all is well with you. We will be responding to you in thevery near future but I wanted to ask a few questions about your discovery process as I am notfamiliar with military trials. If information is deemed discoverable, are there rules toensure that the defense does not publicly disclose such materials? Are there any othermechanisms by which such information could be made public? Look forward to hearing from yousoon. Best Regards,(Field Operations and Information) Bureau of Alcohol, Tobacco,Firearms and Explosives U.S. Department of Justice99 New York Ave. NERm. 6E-441Washington, DC 29226deskcellfaxWARNING: This electronic transmission is intended only for the person(s) named above. It maycontain information that is confidential and protected from disclosure by the attorney?clientprivilege and/or work product doctrine or exempt from disclosure under other applicable laws.Any use, distribution, copying or other disclosure by any other person is strictlyprohibited. Do not forward or re-transmit without the permission of sender or ATF ChiefCounsel's Office. If you have received this transmission in error, please notify the senderat the number or e?mail above.ATTORNEY WORK PRODUCT PRIVILEGED DOCUMENT PRIVILEGED COMMUNICATIONNOTICE: This e?mail message and any attached files are intended solely for the use of theaddressee(s) named above in connection with official business. This communication maycontain Sensitive But Unclassified information that may be statutorily or otherwiseprohibited from being released without appropriate approval. Any review, use, ordissemination of this e?mail message and any attached file(s) in any form outside of theBureau of Alcohol, Tobacco, Firearms Explosives or the Department of Justice withoutexpress authorization is strictly prohibited. 02923690From: Fein, Ashden CPT USA SJASent: Tuesday, March 13, 2012 8:17 PMTo: David CoombsCc: Matthew kemkes; Morrow JoDean, CPT USA SJASubject: RE: please call David,we have started reviewing your enclosures for the replies and it appears to contain similarinformation that we have discussed before- relating a certain OCA by name to the actualspecification (the enclosures/attachments with your reply and the motions). In our reply, weenclosed the same email but provided a redacted form, yet in yours you kept the reference.we need to warn everyone not to open the documents until tomorrow morning, until we consultwith the OCA. I recommend you send an email to all parties asking them not to open any ofthe documents until tomorrow morning, and then we can chat late tomorrow morning.v/rAshden 02584420From: David Coombs Sent: Tuesday, March 13. 2012 9:17 PMTo: Fcin. Ashden cm USA SJA Cc: Matthew kemkes Morrow Ill, JoDean, CPTUSA SJASubject: please callI've looked more closely. and I don?t see anything referencing theorganization in either of the documems you are conccmed about. Thefootnote that you believe applies does not speak to a named individual. butrather the otganication So. even under your beyond-strti md reading ofthe footnote. then: is no problem hem.Best.DavidDavid E. Coombs. Esq.Law O?icc ofDa\'id E. Coombsll South Angel] Street. #317RI 02906Toll Free?: I-800-588-3 I56Local: (508) 689-4616Fax; (508) 689-9282wmv.annycourtmanialdcfensc.comNotice: This including maycontain oon?demizil attomcy-client infomtation and is intended for thepersona) or company named lfyou am not the intended recipient. pleasemtify the and delete all copies Unauthorized disclosure. copyingor use of this information may be unlawful and is proliibitcd'??02979404From: ?@doc.g0v]Sent: Thursday, March 15, 2012 7:30 PMTo: Bradley, Princeton L. SGT USA SJASubject: RE: Request to Review NCIX Response (UNCLASSIFIED)Sgt. Bradley the appropriate OGC contact. Please let meknow if you need anything else.02 562271From= Sent: Friday, March 16, 2012 8:29 AMTo: Fein, Ashden CPT USA SJA Morrow JoDean, CPT USA SJASubject: STPR Access for CDC (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONEGents.We need to discuss the speci?c needs of the CDC for a location in R1 for him to produce. store and transmit classi?ed pleadings. Myread is as follows:1. Classi?ed Computer - preferably stand alone lap top SECRET LEVEL.2. Classi?ed storage for documents and computer3 Access to govemment official who has SIPR access and can and transmit the pleadings via SIPR to the court and youDo you concur? We have a couple of leads on government facilities in RH that may be able to accommodate these security needs. Iwould like to ensure we have captured all of the needs however. prior to engaging ith them.r/ Officeof the Jud Advocate General of the Army. Pentagon 3DS48WICS: ,(tI.dami.ic. govTel:Classi?cation: UNCLASSIFIEDCaveats: NONE 02979789From: Bradley, Pnnceton L. SGT USA SJASent: Saturday, March 17, 2012 3:48 PMTo: _@gsa.9ov'Subject: Re: Request to Review NCIX Response (UNCLASSIFIED) I apologize for not responding to your email earlier, our team has been out of the officesince the 13th due to the motions hearing we for the trial. I will certainly double checkwith CPT Fein on Monday to ensure he has received the email and if not, we will Figure outanother means if necessary. Please let me know if you need anything from us in the meantimeand we will be more than happy to help.Very Respectfully,SGT Princeton BradleyOSJA, Military JusticeFort McNair, 3223-1 1 02979415From: Bradley, Princeton L. SGT USA SJASent: Monda March 19. 2012 3:53 PMTo: wdocgovSubject: equest to Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOMa?am,Good afternoon. I am a paralegal for the prosecution team in the Court?Martial of PrivateFirst Class Bradley Manning in connection with "w#kileaks." The purpose of this email istwofold: first, to affirm that you are a member of the General Counsel's Office, and second,request a copy of all documents that your organization provided to NCIX approximately oneyear ago. Although we have been coordinating with for the past year, just recentlythey have determined that we cannot review copies of your organization's documents in theirpossession, and we must directly go to your organization to coordinate a review.we are requesting this information to determine if there is any information that may bediscoverable and may require production by the government. None of the information will leaveour office, unless your organization has approved its release, and if those documents areclassified, they will remain classified at all times.we would like to review the documents from your organization as soon as possible. This shortsuspense is necessary as the accused was arraigned on the 23rd of February, and to allow forenough time to coordinate with your organization, if information is discoverable. If thedocuments referenced are classified, please feel free to use the SIPRNET and JWICS emailaddress for our lead prosecutor, Captain Ashden Fein. If you would like to speak with me,please call at 262-685-1975 and if you would like to speak with our lead prosecutor, pleasecall Captain Ashden Fein at 202-685-4572.Thank you.Very Respectfully,02979415Princeton BradleySergeant, U.S. ArmyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32Classification: UNCLASSIFIEDCaveats: FOUO02979408Fro"-= ?@doc-gov]Sent: Monday, March 19, 2012 4:21 PMTo: . SGT USA Cc: Subject: RE: Request to Review NCIX Response (UNCLASSIFIED)I am forwarding your message to ?in the Department of Commerce Office of Security(OSY). He has been handling and coordinating your request for records. As he informed you,OSY has been waiting for a formal written request for records from the Army, including thelegal authority for the request, the specific records requested, why they are needed, howthey will be handled and maintained (consistent with all applicable law), who will haveaccess to them, and that any further disclosure will be with the review and consent of theDepartment of Commerce. As _explained to you, the letter of request should be signedby someone with the authority to make the request at a high level in the organization.Please contact_for any questions about any records that might be at issue.General Law Division/Office of the General Counseltelephone: ?Cam 2Confidentiality Notice: This e-mail message is intended only for the named recipients. Itcontains information that may be confidential, privileged, attorney work product, orotherwise exempt from disclosure under applicable law. If you have received this message inerror, are not a named recipient, or are not the employee or agent responsible for deliveringthis message to a named recipient, be advised that any review, disclosure, use,dissemination, distribution, or reproduction of this message or its contents is strictlyprohibited. Please notify us immediately that you have received this message in error, anddelete the message.02936263From: Fein, Ashden CPT USA SJASent: Monday, March 19, 2012 10:33 PMTo: David CoombsCc: Matthew kemkes; 'Bouchard, Paul CPT USARMY ?Joshua Tooman'; ?Santiago,Melissa 8 CW2 USARMY Morrow Ill, JoDean, CPT USA CPTAngel Overgaard; Whyte, Jeffrey H. CPT USA Ford, Arthur D. CW2USA SJASumed: Dbawew,aoAttachments: 120316-Court Protective Order.pdfDavid,The United States intends to produce multiple interim CCIU forensic reports. If using thenormal production process, we would deliver 2.7 million pages in classified discovery. Overthe past few months, we have been working to prepare these massive files for production. TheUnited States would like to offer two courses of action, to make this more efficient for thedefense and ultimately easier to identify the changes (if any) in the reports. Most of thereports contain repetitive enclosures and attachments which are identical to the ones in thefinal report.Option 1: The United States produces all reports and enclosures with BATES numbers, but with"htm? and "html" files in a "zip" file. This production would total approximately 235,666documents containing 1.2 million pages.Option 2: The United States produces only the unique documents. we ran a MD5 hash programagainst the final report and all the interim reports. we know which documents are unique andwhich are not. This production would total approximately 556 unique documents containing165,666 pages.we leave this option up to the defense. Our default is to produce the information as wereceived it following the normal process. Please let me know which option the defenseprefers in order to make this more efficient.-Break-Attached is the Court protective order for classified information. Please have all membersof the defense team sign the acknowledgment and send back a scanned version.?Break?we are still working on obtaining a local government facility for you to work from andhopefully I will have an answer by Wednesday.v/rAshden02556055From:Sent:To:Cc:Subject:David Coombs Tuesday, March 20, ?.0l2 850 AMFein. Ashden MAJ LTSA SJA Matthew kemkes 'Bouehard_ Paul CPT USA RM ;'.loshua Tooman''Santiago, Melissa USARMY Morrow Ill, JoDean, CPT USA Overgaard, Angel N1 CPT USA JFHQ-Whyte. Jeffrey H. CPTFord. Arthur Discovery, etc.Ashdeii.A) Are the ititeriin CCIU reports related to the final rcpoi1s_vou havealready provided in er_v" Or. are these reports unrelated to the l'inalCCIU repons?B) I will emure that all members ofthe Defense team sign the enclosedprotective order. and send a signed copy of the aeknovv ledgenient back to )Oll.C) Thank _\ou for the ttpdateCatt youiprov ide me with an update on the entail issues" I am concerned bythe fact _vou did not receive COL Lind?s email until Mondtn xv hen she sent iton Frida). I atn also concerned that in_v email address is on some spatn/blocklist. Best.Din idDavid E. Cooinbs. EsqLa? O?ice of Dm id E. Coombsll South Angell?Slreel. Ml?A 02906Toll Fnee:A L?0C.?ll' (508) (508) eoombs :2 anti} mm arinycotirtntiinitildefense cont.\?otice. including attachnieiits. contain con?deinial attome} client infonmition and is intended for theperson(s) or conip:tn_\ lf_\ou_are not the intended recipient. pleasen0llf_\' the sender and delete all eoptes.A Unatitlion/ed disclosure. copy ing,or use of this inforination may? be unlawfitl and is pioliibited.??02979326From: Bradley, Princeton L. SGT USA SJASent: 20, 2012 9:40 AMTo:Subject: RE: Request to Reveiw NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good morning, I hope you have been well since we last spoke. I am justemailing you to ask if you or anyone else in your office has had anopportunity to locate the response generated by your office with regard tothe NCIX "w#ki1eaks? document review. Please let me know if you need anyadditional information from our office and I will do my best to assist.Very Respectfully,SGT Princeton BradleyParalegal Non?Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 .02979357From: Bradley, Princeton L. SGT USA SJASent: Tuesda March 20, 2012 9:45 AMTo: usdagovSubject: Request to Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOGood morning, I hope you have been well since we last spoke. I am just emailing you to askif you or anyone else in your office has had an opportunity to locate the response generatedby your office with regard to the NCIX "w#kileaks" document review. Please let me know ifyou need any additional information From our oFfice and I will do my best to assist.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned oFficerMilitary Justice, OSJAFort McNair, 32Classification: UNCLASSIFIEDCaveats: FOUO 02979748From: Bradley, Princeton L. SGT USA SJASent: 2012 10:25 AMTo:Subject: RE: Request to Review Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOGood morning, I hope you have been well since we last spoke. I am justemailing you to ask if you have been able to obtain an interim clearance toreview your agency's NCIX "w?kileaks" review response. Please let me knowif you need any information From our office and I will do my best to assist.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 02979929From: Bradley, Princeton L. SGT USA SJASent: Tuesda March 20. 2012 10:43 AMSubject: NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good afternoon, I hope you have been well since we last spoke. I am just emailing you to askif you or anyone else in your office has had an opportunity to locate the response generatedby your office with regard to the NCIX "w#ki1eaks" document review. Please let me know ifyou need any additional information from our office and I will do my best to assist.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 Classification: UNCLASSIFIEDCaveats: FOUO02979961From: Bradley. Princeton L. SGT USA SJASent: Tuesda March 20. 2012 10:46 AMTo: Subject: Request to Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good morning, I hope you have been well since we last spoke. I am just emailing you to askif you or anyone else in your office has had an opportunity to locate the response generatedby your office with regard to the NCIX "w#kileaks" document review. Please let me know ifyou need any additional information from our office and I will do my best to assist.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32Classification: UNCLASSIFIEDCaveats: FOUO 02979962From: Bradley, Princeton L. SGT USA JFHQ-NCRIMDW SJASent: Tuesda . March 20. 2012 10:57 AMTo: ?g>nsf.gov'Subject: Request for Point of Contact (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good morning, I hope that you are well. I am a paralegal for the prosecution team in theCourt-Martial of Private First Class Bradley Manning in connection with ?w#kileaks." Thepurpose of this email is to request the proper point of contact in your General Counsel?sOffice with regard to the documents your organization sent to the NCIX concerning the"w#kileaks" incident. Those documents, should they be deemed relevant and necessary, wouldbe used in the U.S. Army Court Martial of PFC Bradley Manning, but only with the permissionof your agency.These documents, should they be classified in nature, will remain classified at all times,and will only be used within the guidelines given by your General Counsel?s Office. Thisbeing said, the prosecuting attorneys need to coordinate with the proper point of contact toestablish those guidelines, and ensure proper use of those documents. If at all possible,please send both SIPRNET and JNICS email addresses, as well as phone numbers, for the pointsof contact that you are able to obtain. Also, I would stress that because the accused wasarraigned on the 23rd of February, the prosecution team is in need of this information assoon as possible. If you would like to speak with our lead prosecutor, Captain Ashden Fein,he may be reached at 202-685-4572. I will be more than happy to address any questions andconcerns as well. Thank you very much for your assistance in this matter, have a great day.Very Respectfully,Princeton BradleySergeant, U.S. ArmyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 3202979693From: Bradley, P?nceton L. SGT USA SJASent: Tuesda . March 20, 2012 12:03 PMTo:Cc:subject: Request to Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUO Good morning, I hope you have been well since we last spoke. I am emailing you to askif you have had an opportunity to locate the response generated by your office with regard tothe NCIX "w?kileaks" document review. Our exchange server here is recovering from a crashthat occurred last night and as a result our prior emails have been erased from my inbox.Please let me know if you need any additional information from our office and I will do mybest to assist.Very Respectfully,SGT Princeton BradleyParalegal Non?Commissioned OfficerMilitary Justice, OSJAFort McNair, 32Classification: UNCLASSIFIEDCaveats: FOUO02979971From: Bradley, Princeton L. SGT USA SJASent: Tuesda . March 20. 2012 12:09 PMTo: nrc.gov'Subject: Request to Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOMa?am,Good morning, I hope are well. I am emailing you to ask if you or anyone else in youroffice has had an opportunity to locate the response generated by your office with regard tothe NCIX "w#ki1eaks" document review. Per your out of office message, I did try contactingbut my emails were returned as undeliverable. Please let me know if you needany a itiona information from our office and I will do my best to assist.Very Respectfully,SGT Princeton BradleyParalegal Non?Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 Classification: UNCLASSIFIEDCaveats: FOUO02933116 From:Sent: Tuesday, March 20, 2012 4:46 PMTo: DawdcoombsCc:Subject: Re: FW: Discovery, etc.David,As you probably ?igured out, yes our email is down and I did not receive your previous email.I did receive your email dated 1412 today, to the I just Forwarded a response. we cannot send emails right now on our NIPR and there is no cross over from AKO to NIPR.To answer your questions below:A) The interim reports are directly related to the Forensic reports we provided. They arethe interim reports for those reports. The final reports were updated over time; howeverinterim reports were produced.For email issues, we are pushing For an answer and will get one. Today's issue was weatherrelated, and the Spam Filter is at a much higher level that we have already elevated. It isclear that your email is not blocked otherwise we would not receive the emails and themilitary defense counsel would not receive some of them. we are working to identify aspeci?ic issue, if it exists, and if not, then understand the general issues and try to letyou know so you can fix it, if possible. v/rAshden 02937766From: Fein, Ashden CPT USA SJASent: Tuesday, March 20, 2012 8:08 PMTo: David Coombs;Cc: Whyte. Jeffrey H. CPT USA Overgaard. Angel M. CPT USA JFHQ-Morrow Ill. JoDean. CPT USA Matthew kemkes;Subject: RE: Delivery Status Noti ucation (Failure)David,The reason you are getting it For some members of the team is that their mailboxes have notbeen migrated yet and are still being fixed? this message has nothing to do with yourspecific email, but all emails. This issue is being worked around the clock.V/rAshden02933110From: Fein, Ashden CPT USA SJASent: Thursday, March 22, 2012 7:33 AMTO: ?David Coombs'; 'Fein, Ashden CPT MIL USA Cc: Matthew kemkes; Morrow Ill, JoDean, CPT USA JFHQ-Overgaard, Angel M. CPT USA Whyte, Jeffrey H.CPT USA SJA: Parra. Jairo A. W01 USA SJASubject: RE: FW: Discovery, etc.David,Based on your guidance, we will provide the information by only producing the uniquedocuments, as determined by those that do not have the same MD5 hash as the final reportspreviously produced. This will be a much more efficient process for you to receive and reviewthis documentation. The government's priority in discovery was to get the final reports tothe defense as soon as possible, and then focus on the interim reports. Based on the massiveamount of information and the many different file types, it has taken months to process theinterim reports, as this has been an ongoing process.v/rAshden 02979329From: bbg.gov]Sent: urs ay, arc 2012 8:55 AMTo: Bradley, Princeton L. SGT USA SJASubject: RE: Request to Reveiw NCIX Response (UNCLASSIFIED)SGT Bradley,we're still trying to track it down, but we've narrowed the number of places we might ?indit. Thank you For the reminder, and I'll let you know as soon as we Find something.Regards,hsroaacasung Board or 02946291From: Fein, Ashden CPT USA SJATo: USA OTJAGSubject: FW: Army Request for Newport AssistanceImportance: HighFYSA.inal Messa From: m?mn1Sent: wednesda March 21 2612 11:58 AMCc: Subject: Army Request for Newport AssistanceImportance: High Sir, as discussed:Situation to this point. I called and spoke with ~yjsterday afternoon:I asked for more detail on the time and manpower support requirement. He was not able togive specifics, but he will call the prosecutor's office and get as much information as hecan.- I asked about base access. Mr. Coombs (Defense Counsel) is an Army Reserve JAG and hasbase access. He will not have any assistants or other staff requiring base access.I discussed equipment needs, specifically a scanner for use in the SIPR. stated that the Army would provide the means and equipment to complete work as needed.- I briefed?on the layout of our SIPR space, and discussed the fact that wecould not provide a segregated area to Mr. Coombs, as the SIPR room is an open classifiedwork space and other staff need to use it. This led to a discussion of alternative workspace availability (the Reserve Office, 2nd deck) and whether or not classified material andsegregated work could be performed there. As discussed with we can investigate whetheror not we can set the Reserve Office up as an "Open Secret" space by changing the lock andhaving a GSA safe (in the space) for Mr. Coombs to work. She is researching and will providedetails.Concerns:02946291 Very Respectfully,Program Support AssistantDefense Institute of International Legal Studies441 Elliot Avenue, Newport, RI 62841-1531UNCLASSIFIED. This electronic communication is from the Defense Institute of InternationalLegal Studies (DIILS) and may contain information that is privileged or pertaining tosensitive official policy and practices, and is to be used for official purposes only.Information contained within this document or attachments may contain Personally IdentifiableInformation (PII), disclosure of which is generally prohibited by the Privacy Act of 1974, 5U.S.C. 552a. Any misuse or unauthorized disclosure may result in both civil and criminalpenalties. If you received this message in error, please notify the sender.02979930From:Sent:To:Cc:Subject:Attachments:unaue I nasagov]Thursday, March 22, 2012 11:20 AMBradle Princeton L. SGT USA (HQ-M8000)HQ-M8000) HQ-LPD2 (HQ-(HQ-LP023) RE: Request to Review NCIX Response (UNCLASSIFEED)NASA Memo__reference Wikileaks__21 Oct 2010.pdf Division Head of the DPS Sanceguards Division and his staff were to ocate the CD Labeled SECRET) that ONCIX provided to us during October 2916.However, I've attached a copy 0F the review results that was provided by the SafeguardDivision Intel Res ectfully,NASA Counterintelligence02924767From: Fein, Ashden CPT USA SJASent: Thursday, March 22, 201211259 AMTo: 'David Coombs'Cc: Matthew kemkes; Bouchard, Paul CPT USARMY 'Tooman, Joshua CPT USARMY?Santiago, Melissa CW2 USARMY Morrow Ill, JoDean, CPT USA JFHQ-Overgaard, Angel M. CPT USA Whyte, Jeffrey H.CPT USA Ford, Arthur D. CW2 USA SJASubject: OCA Contact InfoDavid,As for the defense's request to speak with the Ambassador Kennedy and the OCA forSpecification 3 and 15 of Charge II, please follow the below procedures. I spoke with eachentity and below is the information they relayed.Ambassador Kennedy. Reference 22 CFR Part 172. Submit a request IAN Part 172, but ensureyou look over the entire section, it is very short. The POC and address is listed in theregulation, and so are the factors they consider. The request should be addressed to "Towhom it may Concern" and please place the following three individuals in the CC line of theletter: (1) Mr. John Blanck; (2) Mr. Jason Mehta; (3) Major Ashden Fein, US Army. Once youmail the request, to the address provided, please provide me a scanned copy. The prosecutionwill forward the digital copies to each individual in CC line and then the prosecution willtrack its progress at the Department. If there are any issues, then we will be the conduitbetween State and the defense. It is my understanding that the key is to ensure the requestis properly routed is to comply with the administrative procedures under Part 172.The OCA for Specification 3 and 15 of Charge II. Please refer to their Touhy regulations,which I found through Google or I can provide you via a phone conversation. Although theyprefer the request to be classified, they understand that you will likely submit anunclassified document. If unclassified, ensure that you vaguely refer to any specific factsthat are attributable to this OCA's employer. Unless you make this a classified request, donot use the Organization's name, any employee's name, references to the CFR that areattributable to the Organization, or direct references to any task force or assessment thatdoes or does not exist. You may reference a task force or assessment (if they exist) with adisclaimer, such as "The defense submits this request to show the OCA for Specification 3 and15 of Charge II will which is related to any assessment which may have beencompleted." This request should be addressed to "Brian G., Office of the General Counsel."Once you complete the request, please send the request to me (unclassified scan is fine) andthe prosecution will submit the request on your behalf directly to the Organization viasecure email. The prosecution will track its progress at the Organization. If there are anyissues, then we will be the conduit between the Organization and the defense.Please let me know if you have any questions. Also, we have reviewed our records and youshould have the contact information for all the remaining OCAs or other senior officials youhave asked for in the past. If not, then please send me a list so that we may continue toassist.Thank you!v/rAshden02979972Sent: ay, arc To: Bradley, Princeton L. SGT USA SJASubject: RE: Request to Review NCIX Response (UNCLASSIFIED)Sgt. BradleyI got hold of the person who was sent the email. He has been out for several weeks due to adeath in the family. we hope to get back to you by the beginning of next week if that isokay.Thanks.Nonproliferation and International Nuclear Security 0?Fice ofInternational Programs U.S. Nuclear Regulatory Commission 02562233From: on behalf of?US)Sent: Thursday, March 22, 2012 4:51 PMTo: Fein, Ashden MAJ USA SJASubject: FW: SIPR at NWC (UNCLASSIFIED)Flag Status: CompletedClassification: UNCLASSIFIEDCaveats: NONEAshden,A couple more POCs and info regarding NWC and NJS.Office of the Judge Advocate General of the Army, Pentagon 3D548NIPR:SIPR:JNICS:Tel: 02918034From: Fein, Ashden MAJ USA SJASent: Monda March 26, 2012 9:59 AMTo: ?state.gov;state.govCc: Bradley, Princeton L. SGT USA Feito, Beatriz SGT USA JFHQ-Ford, Arthur D. CW2 USA Parra, Jairo A. WO1USA Waybright, Daniel W. SGT USA Haberland, John CPT USA Regimental Judge Advocate; Morrow Ill, JoDean, CPT USAOvergaard, Angel M. CPT USA Whyte,Jeffrey H. CPT USA SJASubject: Touhy RequestAttachments: Touhy Request - Kennedy.pdfGood morning. Attached is a digital copy of the Touhy request submitted by the defensecounsel in the court?martial case of United States v. Private First Class Bradley Manning.Mr. Coombs sent the letter via FEDEX on Friday. Please let us know what else we can do toassist the defense and the Department with this submission.v/rAshden02919424From: Fein, Ashden MAJ USA SJASent: March 26, 2012 11:56 AMTo: @usnwc.eduCc: Parra, Jairo A. wo1 USA Subject: Suppon for US v. PFC ManningThank you for taking the time to discuss potential litigation support for the court?martialcase U.S. v. PFC Manning with N01 Jairo Parra. As you discussed over the phone withhim, here are the requirements:- workspace for classified information and storage (safe) up to Since thissupport is being provided to the defense we will need an area where the civilian defenseattorney can work without the observation of government officials and separate storage spacefor his work product. The defense attorney will work from a standalone laptop computer (USArmy provided).- Identification and appointment of a government official who has SIPRNET access and can"pdf" or otherwise import the attorney work product created by the defense counsel (courtpleadings/motions) and transmit/receive documents via SIPRNET to the Army trial judge, courtmembers, and the government prosecutors. we do not contemplate nor will we authorize thecivilian defense counsel direct access to SIPRNET. Rather the Army 62 (intel) has alreadygranted limited access to the defense to transmit the pleadings and other court documents viaSIPRNET. we envision the best means to accomplish this is by appointing one governmentofficial to be a member of the defense team for the sole purpose of providing SIPRNETtransmission/receipt support.The prosecution can fund any reasonable costs associated with this request. Additionally,Mr. Coombs is the defense attorney and he is a reservist in the USA JAGC.Thank you very much!v/rAshden FeinAshden FeinMAJ, JATrial Counsel 02983105From: Whyte, Jeffrey H. CPT USA SJASent: Monda March 26, 2012 3:09 PMre: j@nq.aoe.gov?Subject: US v. PFC Manning (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,I am one of the prosecutors in the above case.today regarding the documents your organizationwith my contact number (202-685-1975).Thank you, Sir.v/r3.Hunter whyteCPT, JATrial CounselClassification: UNCLASSIFIEDCaveats: FOUOAre you available to talk for a few minutesprovided our office? I left you a voicemailUnited States Army Military District of Washington (MDN)02983104From: Whyte, Jeffrey H. CPT USA SJASent: Monda March 26, 2012 3:10 PMTo: nasa.gov'Subject: US v. PFC Manning (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,I am one of the prosecutors in the above case. Are you available to talk for a few minutestoday regarding the documents your organization provided our office? I left you a voicemailwith my contact number (262-685-1975).Thank you, Sir.v/r3. Hunter whyteCPT, JATrial CounselUnited States Army Military District of Washington (MDN)Classification: UNCLASSIFIEDCaveats: FOUO02979563From: Bradley, Princeton L. SGT USA SJASent: arch 26, 2012 5:12 PMTo: @soI.doi.gov?Subject: Request 0 Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOGood afternoon. I am a paralegal for the prosecution team in the Court-Martial of PrivateFirst Class Bradley Manning in connection with "N#kileaks.? The purpose of this email istwofold: first, to affirm that you are a member of the General Counsel?s Office, and second,request a copy of all documents that your organization provided to NCIX approximately oneyear ago. Although we have been coordinating with for the past year, just recentlythey have determined that we cannot review copies of your organization's documents in theirpossession, and we must directly go to your organization to coordinate a review.we are requesting this information to determine if there is any information that may bediscoverable and may require production by the government. None of the information will leaveour office, unless your organization has approved its release, and if those documents areclassified, they will remain classified at all times.we would like to review the documents from your organization as soon as possible. This shortsuspense is necessary as the accused was arraigned on the 23rd of February, and to allow forenough time to coordinate with your organization, if information is discoverable. If thedocuments referenced are classified, please feel free to use the SIPRNET and JWICS emailaddresses below for our lead prosecutor, Major Ashden Fein. If you would like to speak withme, please call at - and if you would like to speak with our lead prosecutor,please call Major Ashden Fein at?.Thank you.Very Respectfully,02979563Princeton BradleySergeant, U.S. ArmyParalegal Non?Commissioned OfficerMilitary Justice, OSJAFort McNair, 32C1assiFication: UNCLASSIFIEDCaveats: FOUO 02980011From: Bradley, Princeton L. SGT USA SJASent: nd a 26, 2012 5:13 PMTo: opnmgovSubject: Request to Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOMa?am,Good afternoon. I am a paralegal for the prosecution team in the Court-Martial of PrivateFirst Class Bradley Manning in connection with ?w#kileaks." The purpose of this email istwofold: first, to affirm that you are a member of the General Counsel's Office, and second,request a copy of all documents that your organization provided to NCIX approximately oneyear ago. Although we have been coordinating with for the past year, just recentlythey have determined that we cannot review copies of your organization's documents in theirpossession, and we must directly go to your organization to coordinate a review.we are requesting this information to determine if there is any information that may bediscoverable and may require production by the government. None of the information will leaveour office, unless your organization has approved its release, and if those documents areclassified, they will remain classified at all times.we would like to review the documents from your organization as soon as possible. This shortsuspense is necessary as the accused was arraigned on the 23rd of February, and to allow forenough time to coordinate with your organization, if information is discoverable. If thedocuments referenced are classified, please feel free to use the SIPRNET and emailaddresses below for our lead prosecutor, Major Ashden Fein. If you would like to speak withme, please call at? and if you would like to speak with our lead prosecutor,please call Major Ashden Fein at Thank you.Very Respectfully,02980011Princeton BradleySergeant, U.S. ArmyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32Classification: UNCLASSIFIEDCaveats: FOU0 02565711 From: on behalf of-Sent: Tuesday, March 27. 2012 8:16 AMTo: Fein, Ashden MAJ USA JFHQ-NCRIMDW SJA Cc: Parra, Jairo A. W01 USA Ma Ield. David A Mr CIV USA NAVWARCOLSubject: RE: Support for US v. PFC ManningMAJ Fein:Upon receipt of the court order and appropriate documentation relating tothe security clearance of the defense counsel, the NNC will support. Thedesignated POC will be who works for our SecurityDirector Recommend be the designated member ofthe defense team to assist in the transmission of any documents.Please note that ?works 6766-1536, so NNC support isgenerally limited to those hours. If the defense counsel needs her supportoutside of those hours, we'll need to work out comp time and/or overtime IANstandard CIVPERS regs. Also, NHC handling of the classified laptop andmaterials will be done only IAN the regulations governing the handling ofclassified materials. Please advise if you have any questions.JAGC, USNStaff Judge AdvocateNaval war Collegeusnwc.eduDSNThis e-mail is For Official Use Only, is confidential, intended only for thenamed recipient(s) above and may contain information that is privileged,attorney work product, privacy sensitive or that is otherwise exempt fromdisclosure under applicable law. Any misuse or unauthorized disclosure ofprivacy sensitive information may result in civil and criminal Penalties.If you have received this message in error, or are not the namedrecipient(s), please immediately notify the sender and delete this e-mailmessage from your computer. Thank you.02919426From: Fein, Ashden MAJ USA SJASent: Tuesda March 27 2012 9:45 AMTo: NAVWARCOLcc: Parra Jairo A. W01 USA USA NAVWARCOL NAWNARCOLSubject: RE: Support for US v. PFC ManningAttachments: 120316-Order (Protective Order Classified |nformation).pdf; 120316-Order (Protective OrderClassified |nformation).pdfSir,Good morning and thank you! Attached are the two relevant orders. Although these orders donot specifically spell out which facility and its location, the term "Government Facility" isdefined as a "United States government building that is approved for handling and storage ofclassified information up to the level." W01 Parra will send out the JPASinformation for Mr. Coombs and the other members of the defense team.Mr. Coombs is a reserve US Army Judge Advocate and has a clearance granted to him bythe US Army for this case. we have a standalone classified laptop already designated for himto work from and a printer for him to use. In the end, we are asking for only three items:1. Space for him to work with classified material (hard copy, computer, printer - we provideall) 2. A safe to hold collateral material, including CD5, standalone computer,paper, etc.) 2. A point of contact made a member of the defense team to be a conduit forsending receiving emails (AND EMAILS ONLY) on SIPRNET and to send/receive classifiedinformation through Thank you.v/rMAJ Fein 02565707 From: NAVWARCO @usnwc.edu] on behalf 0-AVWARCOL -Sent: Tuesday, March 27, 2012 9:51 AMTo: Fein, Ashden MAJ USA JFHQ-NCRIMDW SJACc: R?arra, Jairo A. W01 USA Ma Ieid David A Mr CIV USA OTJAG:NAVWARCOLSubject: RE: Support for US v. PFC Manning MAJ Fein:we can accommodate the requests. we have a space For Mr. Coombs to workFrom, a safe to store the classified laptop and associated and/orpapers, and a POC . Mr. Coombs may come and go as he pleasesonce we get confirmation of his clearance. Hope this satisfies the request.Standing by For any questions that may arise. RImac. us~Staff Judge AdvocateNaval war Collegeusnwc.edu This e?mail is For OFFicial Use Only, is confidential, intended only for thenamed recipient(s) above and may contain information that is privileged,attorney work product, privacy sensitive or that is otherwise exempt fromdisclosure under applicable law. Any misuse or unauthorized disclosure ofprivacy sensitive inFormation may result in civil and criminal penalties.IF you have received this message in error, or are not the namedrecipient(s), please immediately notity the sender and delete this e?mailmessage From your computer. Thank you. 02919469From: Fein, Ashden MAJ USA SJASent: Tuesda March 27, 201210105 AMTo: Cc: Parra, Jairo A. WO1 USA USA NAVWARCOLSubject: RE: Support for US v. PFC ManningSir,Thank you For the support. we intend to present this "option" to the defense along with thepossibility of him working at DIILS. The resources at NNC seem more suitable For Mr.Coombs's task and I assume he will want to drive out to NWC to work.Thank you again!V/rMAJ Fein02555935 From; Parra. Jairo A. W01 USA SJASent: Tuesda March 27 2012 10:25 AMTo: ARCOL: Fe? SJANAVWARCOLSumea:AttachmentsPFC Manning (UNCLASSIFIED)MAJ Kemkes Mr. ombs CPT Bouchard CPT Tooman Classification: UNCLASSIFIEDCaveats: FOUOSir,Attached you will find all the JPAS printouts for all the members of theDefense Team.Note. I was not able to the message to all the recipients in thise-mail.v/r.JPJairo A. ParraN01, JALegal AdministratorJFHQ-NCR, MDW The information contained in this email and any accompanyingattachments 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 Defensewithout prior authorization from the Office of The Judge Advocate General,Department of the Army. If you are not the intended recipient of thisinformation, any disclosure, copying, distribution, or the taking of anyaction in reliance on this information is prohibited. If you received thisemail in error, please notify this office immediately by return email (see 5U.S.C. 552 and Army Regulations 25-55 and 02584318From: David Coonibs Sent: Tuesday, March 27. 2012 10:42 AMTo: Fein, Ashden MAJ USA SJA kemkes 'B0u?hard~ Paul CPTUSARMY ?Santiago, Melissa CW2 CSARMY(US) Morrow JoDcan, CPT USA JFHQ-SJA Ovcrgaard. Angel CPT USAKMDW 3? Jeffrey H. PTUSA SJA Ford. Arthur cw:USA ii?Ho-Ncwow sm Subject: RE. Update?lhank you for the update. You must haye read mind. becziusc I about to send you another email on many oftliese l) OCA Contact. I do contact iitforinutioii for each of the civiliuiiOCAS. intend to subtnit a Touhy request for the OCA for Spec 3 and I5 ofCharge ll. Houeyer. I still need ilie best yyay fonvard to contact the OCAs. Although I hay-e email addresses for each I imagine that they wouldlikely want me to coordinate with an aide before reaching out directly tothem. Please advise on that issue2) L105: Gener.illy_ wliat LlOs do you see?? I rczili/ed that this may heyyisliful thinking. but perhaps can present request forinstructions for the charged olTenscs and the identi?ed LlOs - or zisjointas can possibly? 3) Goyernnicnt Facility; Either yy ill be ?ne with inc.4) This is from 2009 Is this the latest and onlydocument detailing the approy ed softyy are on the Si Personal Security?: Have you been able to discuss my intended post the Best.Day? idDay id Esq.Law Office of David E. 11 South Street. #3l7Providence. RI 02906Toll Free: l-8t)t)-588-4 l5(?Local" (508) Fax?. (508) 689-9282coo ?(tanny counittartizildcfensccoinyy .coinNotice: This trzinsinission. zittacliniciits. maycontain coii?deiitial attorney -client and is intended for thepcrson(sl or company named. lfyoii are not the intended recipient. pleasenotify the sender and delete all copies. Unauthorized disclosure. copy ingor use of this information be and is 02585702From: NAVWARCOL -@usnwc.edu] on behalf 0-INAVWARCOLSent: Tuesday, March 27, 2012 11:14 AMTo: Parra, Jairo A. W01 USA Fein, Ashden MAJ USA cc: rusiome; AVWARCOLAVWARCOL:NAVWARCOLSubject: RE: Support for US v. PFC Manning (UNCLASSIFIED)N01 Parra:Copy all. Thanks.JAGC, USNStaff Judge AdvocateCollege.edu DSNThis e-mail is For Official Use Only, is confidential, intended only For thenamed recipient(s) above and may contain information that is privileged,attorney work product, privacy sensitive or that is otherwise exempt fromdisclosure under applicable law. Any misuse or unauthorized disclosure ofprivacy sensitive information may result in civil and criminal penalties.IF you have received this message in error, or are not the namedrecipient(s), please immediately notify the sender and delete this e?mailmessage From your computer. Thank you.02983103From: Whyte, Jeffrey H. CPT USA SJASent: Tuesda March 27, 2012 1:00 PMTo: Subject: US v. PFC Manning (UNCIJXSSIFIED)Classification: UNCLASSIFIEDCaveats: FOUO It was great speaking with you earlier today. Please let me know how the DOE wants to pursuethe discovery issue at your earliest convenience.Thank you.V/rCPT whyteClassification: UNCLASSIFIEDCaveats: FOUO02980009 From: opm.gov] Sent: Tuesday, March 27, 2012 1:01 PM To: Bradle Princeton L. SGT USA SJA 1Cc:Subject: RE: Request to Review Response (UNCLASSIFIED) Hello, ?from our office (copied on this email) has been assigned to this matterand will respond to your email. Thank you.02983102From: Whyte, Jeffrey H. CPT USA SJASent: Tuesday, March 27, 2012 1:03 PMTo:Subject: US v. PFC Manning (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,I am one of the prosecutors in the above case.today regarding the documents your organization provided our office?with my contact numberThank you, Sir.v/r3. Hunter whyteCPT, JATrial CounselClassification: UNCLASSIFIEDCaveats: FOUOAre you available to talk for a few minutesI left you a voicemail02980005From ?@opm.gov1Sent: Tuesday, March 27. 2012 1:07 PMTo: Ford, Arthur 0. CW2 USA SJACc: Bradley. Princeton L. SGT USA Subject: RE: Your request for OGC POCChief Ford, an attorney in my oH=ice,? just received another request fromSergeant Bradley ?or a point of contact in this matter. However, as we previously discussed,I will be the point of contact. Upon receipt of a request For records under 5 F.R.295.263, we will process it expeditiously.Sincerely, O?Fice of the General CounselU.S. 0fFice of Personnel ManagementTel:Fax:E-Mail: m. ov This message, including any attachments, is intended For the use of the addressee(s) only,and it may contain inFormation that is confidential, privileged or legally protected.Unauthorized review, distribution or copying of this message or of any accompanyingattachments is prohibited. IF you have received this message in error, please contact me byreturn email or by telephone, and permanently delete it and any accompanying attachments fromany system on which they may be stored.02560832 From: USARMY (US) ?@maiI.mil] on behalf of-SARMY (US)Sent: Tuesday, arch 27, 2012 5:30 PMTo: Hughes, Brian A. LTC USA SJACc: Fein, Ashden MAJ USA Morrow JoDean, CPT USA JFHQ-SJA ISubject: RE: US v. PFC BM (DOD PSR) (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOBrian - Yes, I believe we can meet 13 April suspense.v/r?--?-Original Message--?--From: Hughes, Brian A. LTC USA SJAmailto 1Sent: Tuesday, March 27, 2012 3:33 PMUSARMY (us)Cc: Fein, Ashden MAJ USARMY Morrow 3oDean, CPT USA SJASubject: RE: US v. PFC BM PSR) (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUO - The trial team will require some time to review any documentsthat the PSR turns up. would you be able to bring this to a close at HQDAby 13 APR 12 so that they can determine whether anything discoverable is inDA's possession?Thanks.v/rBRIAN ALLAN HUGHESLTC, JADeputy Staff Judge AdvocateJFHQ-NCR and U.S. Army Military District of Washington103 3rd Avenue SW, Building 32, Suite 100Fort Lesley J. McNair, DC 20319-5658 02936103From: Fein, Ashden MAJ USA SJASent: Tuesday. March 27. 2012 6:52 PMTo: David CoombsCc: Matthew kemkes; 'Bouchard, Paul CPT USARMY ?Santiago, Melissa CW2USARMY Morrow Ill, JoDean, CPT USA Overgaard, Angel M.CPT USA Whyte, Jeffrey H. CPT USA Ford,Arthur D. CW2 USA SJASubject: RE: DOJ DiscoveryDavid,we have provided the defense all the material we have from Do] (warrants and 18 USC 2763material), and any remaining information is part of the FBI file. On 16 Mar 12 and after theCourt ordered protective order was in place, we provided the defense the majority of thematerial which is classified from the FBI investigative file. This information includesmaterial that is subject to warrants and 18 USC 27@3(d) orders. we will continue to provideadditional material as we receive approvals.Based on the military judge's ruling and the FBI file being outside of military authorities,the United States will produce all information that is discoverable under RCM 761(a)(6),unless we assert the privilege and then we will provide the privileged information to themilitary judge for an in camera review.v/rAshden02564312From:Sent:To:Cc:Subject:David Coombs eom>Tuesday, March 27, 20l2 6:58 PMFein. Ashden MAJ USA SJAMatthew kemkesUSARMY Discovery 'Bouchard. Paul ?Santiago, Melissa CW2 USARMYMorrow ioDean. CPT USA Overgaard, Angel USAWhyte. Jeffrey H. Ford. Arthur I) Ashden.lam speci?cally referring to the Grand Jur} materials. Does the(iovernincnt intend to provide this mziteniil. lfso. when will you providethis lfiou intend to only provide ii poniori ivhzii ponion ?illsou prox idc and not provide?? Finally. ?lint legal simidnrd will you use todecide which Grand Jury mzilenals to provide??Best.D2l\? idDax id E. Coombs. Esq.Law Office of Den" id E. Coombsll Soutli Angeli Street. #317Providence. RI 02906Toll Free: I56Local]. (508) FM. (508) (:89-9282Notice: This tl?dl1SmiSSl0fL including mayuttome) -client and is intended for theperson(s) or mined. 1f_\oii am not the intended recipient. pleasenotify the sender and delete all copies. Uiiniitliorized disclosure. or use of this be uiilawful and IS 02562231From: Sent: Wednesday, March 28, IZOI2 8:05 AMTo: Fein. Ashden MAJ us?. SJA Subject: Govemment Facility in RI (UNCLASSIFIED)Classi?cation; UNCLASSIFIEDCaveats: NONEI also a call late from the DIILS. They do not the personnel to suppon SIPR transmissionwe go ilh want someone placed on orders lo accommodate Mr. oombs?s O?icc of the Jud Ahvocalc !cncr:1I 0! the Army. Pentagon 3D5-38unaiI.mi|.snxiI.milidami.ic.go\? 02562228Front: Sent: Wednesday. March 28, 2012 AMTo: Fein, Ashden MAJ USA SJASubject: Government Facility in RI (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDNONEposition should be NWC as it is the best equipped/resourced facilitx to handle the need.Omcc of the Jud Advocate General of the Amty. Pcmagon 30548MPR: y'inmil.n1ilsmil mt!JWICSI 11>02985872From: Whyte, Jeffrey H. CPT USA SJASent: Wednesday, March 28. 2012 3:41 PMTo: ?@hqdoe.gov'Subject: Assessment (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Per our conversation earlier today, please provide me with the position with respect tothe document we may be required to produce in discovery.Thank you.v/rCPT whyteClassification: UNCLASSIFIEDCaveats: FOUO02980812From: i@hq.doe.gov1Sent: Wednesday, March 28. 2012 5:09 PMTo: Whyte, Jeffrey H. CPT USA SJACc: i (IN)Subject: RE: Assessment (UNCLASSIFIED)Categories: Red CategoryCaptain whyte,After speaking with_ the senior DOE intelligence official involved with yourcase, I can now inform your office that if you have independently determined that it isnecessary to provide the Manning defense team access to the DOE damage assessment, or if ithas been requested that you do so via a discovery request, DOE will not object.However, although it is unclassified, the subject information is still sensitive and it wouldbe strongly desirable to provide the defense with access to the information in a ?readingroom? as you described it to me rather than simply physically (electronically?) handing itover.Office of the General CounselU.S. Department of Energy1969 Independence Avenue, s.w.Washington, D.C. 20585Tel.:*This e-mail communication (including any attachments) may contain legally privileged and/orconfidential information meant solely for the intended recipient. If you are not theintended recipient, you should stop reading this message and delete it from your systemimmediately. Any unauthorized reading, distribution, copying or other use of thiscommunication or its attachments is strictly prohibited. 02924772From:SentTo:Cc:Subject:Sir,NNC is the ilace. Do mind turnin? off DIILS and we will execute NNC.v/r?AshdenFein, Ashden MAJ USA SJA759AMUSA OTJAGParra, Jairo A. W01 USA SJANVVC 02979332From: Bradley, Princeton L. SGT USA SJASent: Thursda March 29, 2012 9:51 AMTo:Subject: RE: Request to Reveiw NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good morning, I hope that you have been well. I am just emailing toask if you had any luck trying to track down the NCIX response or if youneed any additional inFormation to aid in the search. Please let me know ifthere is anything help.Very Respectfully,SGT Princeton BradleyParalegal Non?Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 -102979358 From: Bradley, Princeton L. SGT USA SJASent: Thursda March 29, 2012 10:08 AMCc: Subject: Request to Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUO Good morning, I hope that you have been well since we last spoke. I amemailing you to ask if you have been able to determine a viable means of transmitting theNCIX response to us (if I recall correctly this was the subject of our last discussion). Ifyou require any additional information on our part, please let me know and I will be morethan happy to oblige. Thank you again for your help and have a great day.Very RespectFu1ly,SGT Princeton BradleyParalegal Non-Commissioned OFFicerMilitary Justice, OSJAFort McNair, 32Classification: UNCLASSIFIEDCaveats: FOUO02979531From: Bradley, Princeton L. SGT USA SJASent: Thursda March 29. 2012 10:11 AMTo: Subject: equest to Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good morning, I hope you have been well since we last spoke. I am just emailing you to askif you or anyone else in your office has had an opportunity to locate the response generatedby your office with regard to the NCIX "w#kileaks" document review. If no physical recordswere generated please just send me an email memorializing that statement. If you need anyadditional information from our office please let me know and I will do my best to assist.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned officerMilitary Justice, OSJAFort McNair, 32Classification: UNCLASSIFIEDCaveats: FOUO02979399Fr?m= ?@dm-usdaoovlSent: Thursday, March 29, 2012 10:41 AMTo: Bradiey, Princeton L. SGT USA SJACc:Sumem: Good morning Bradley,I apologize for the delay. I have been trying to figure out how to get these documents toyou. USDA does not have the capability to send these documents via a classified backbone andwill have to deliver them.I can get them copied and brought over to you. That seems to be the way it will have towork. will you be in tomorrow? If so, I can get these copied and make arrangements to bringthem over.I have Metro directions. All that I will need is base directions to get to your office..Regards,This electronic message contains information generated by the USDA solely for the intendedrecipients. Any unauthorized interception of this message or the use or disclosure of theinformation it contains may violate the law and subject the violator to civil or criminalpenalties. If you believe you have received this message in error, please notify the senderand delete the email immediately.02979974From: Bradley, Princeton L. SGT USA SJASent: Thursday, March 29, 2012 12:10 PMSubject: equest to eview CIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: Good afternoon, I hope that you have been well since we last spoke.I am emailing you to ask if the person who was originally asked about theNCIX Response has returned to the o?$ice. If not, are you aware of any othermembers of the General Counsel 0FFice that may be able to assist in thegovernment's request? Thank you in advance ?or your help and have a greatday.very Respectfully,SGI Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 102979751From: Bradley, Princeton L. SGT USA SJASent: Thursday, March 29. 2012 12:19 PMSubject: eques Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOGood afternoon, I hope that you have been well since we last spoke.I am contacting you to ask if your security department has had anopportunity to secure your clearance in order to view the NCIX material. Ifyou require any additional information or assistance with regard to the NCIXmaterial, please let me know and I will be happy to oblige. Thank you inadvance For your help and have a great day.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 02979864From: Bradley, Princeton L. SGT USA SJAsent: Thursda March 29. 2012 12:22 PMTo: usnegovSubject: RE: Request for Office of General Counsel Point of Contact (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good afternoon, I hope that you have been well since we last spoke.I just wanted to touch bases with you and let you know that I am stillworking with our counsel here to schedule a meeting with you to address anyquestions or concerns that you may have. In the meantime, iF there is anyinformation I can provide please let me know and I will be more than happyto help.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfricerMilitary Justice, OSJAFort McNair, 32 02979959From: Bradley. Princeton L. SGT USA SJASent: Thursda March 29, 2012 12:24 PMTo: #@nara.gov'Subject: eques to eview NCIX Response Documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOU0Sir,Good afternoon, I hope you have been well since we last spoke. I am just emailing you to askif you or anyone else in your o?Fice has had an opportunity to locate the response generatedby your office with regard to the NCIX "w?kileaks" document review. Please let me know ifyou need any additional information from our ofFice and I will do my best to assist.Very Respectfully,SGT Princeton BradleyParalegal Non?Commissioned OfficerMilitary Justice, OSJAFort McNair, 32Classification: UNCLASSIFIEDCaveats: FOUO 02979568From: Bradley, Princeton L. SGT USA SJASent: Thursday, March 29. 2012 12:46 PMTo: doi.ic.gov'Subject: eque for General Counsel Point of Contact (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good afternoon, I hope that you are doing well. I am a paralegal for the prosecution team inthe Court-Martial of Private First Class Bradley Manning in connection with ?w#kileaks." Thepurpose of this email is to request a point of contact in your General Counsel?s Office withregard to the documents your organization sent to the NCIX regarding the "N#kileaks"incident. Those documents, should they be deemed relevant and necessary, would be used inthe U.S. Army Court Martial of PFC Bradley Manning, but only with the permission of youragency.These documents will remain classified at all times, and will only be used, if at all, withinthe guidelines given by your General Counsel?s Office. This being said, the prosecutingattorneys need to coordinate with your OGC department to establish those guidelines andensure proper use of those documents. If at all possible, please send both SIPRNET and JNICSemail addresses, as well as phone numbers, for the points of contact that you are able toobtain. Also, I would stress that because the accused was arraigned as of the 23rd ofFebruary, the prosecution team is in need of this information as soon as possible. Thank youvery much for your assistance in this matter.Very Respectfully,Princeton BradleySergeant, U.S. ArmyParalegal Non?Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 02980207From: Bradley. P?nceton L. SGT USA SJASent: Thursda March 29. 2012 12:48 PMTo: usdoLgov'Subject: Request for Genera! Counsel Point of Contact (UNCLASSIFIED)Follow Up Flag: Follow upFlag Status: FlaggedClassification: UNCLASSIFIEDCaveats: FOUOSir,Good afternoon, I hope that you are doing well. I am a paralegal For the prosecution team inthe Court-Martial of Private First Class Bradley Manning in connection with "w#kileaks.? Thepurpose of this email is to request a point of contact in your General Counsel?s Office withregard to the documents your organization sent to the NCIX regarding the "w#kileaks"incident. Those documents, should they be deemed relevant and necessary, would be used inthe U.S. Army Court Martial of PFC Bradley Manning, but only with the permission of youragency.These documents will remain classified at all times, and will only be used, if at all, withinthe guidelines given by your General Counsel?s Office. This being said, the prosecutingattorneys need to coordinate with your OGC department to establish those guidelines andensure proper use of those documents. If at all possible, please send both SIPRNET and JNICSemail addresses, as well as phone numbers, for the points of contact that you are able toobtain. Also, I would stress that because the accused was arraigned as of the 23rd ofFebruary, the prosecution team is in need of this information as soon as possible. Thank youvery much for your assistance in this matter.Very Respectfully,Princeton BradleySergeant, U.S. ArmyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 3202980207C1assiFication: UNCLASSIFIEDCaveats: FOU002980197From: Bradley, Princeton L. SGT USA SJASent: Th March 29. 2012 12:49 PMTo: usaid.gov'Subject: Request for General Counsel Point of Contact (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good aFternoon, I hope that you are doing well. I am a paralegal for the prosecution team inthe Court-Martial of Private First Class Bradley Manning in connection with "N#kileaks." Thepurpose of this email is to request a point of contact in your General Counsel?s Office withregard to the documents your organization sent to the NCIX regarding the "w#ki1eaks"incident. Those documents, should they be deemed relevant and necessary, would be used inthe U.S. Army Court Martial of PFC Bradley Manning, but only with the permission of youragency.These documents will remain classified at all times, and will only be used, if at all, withinthe guidelines given by your General Counsel?s Office. This being said, the prosecutingattorneys need to coordinate with your OGC department to establish those guidelines andensure proper use of those documents. If at all possible, please send both SIPRNET and JNICSemail addresses, as well as phone numbers, For the points of contact that you are able toobtain. Also, I would stress that because the accused was arraigned as of the 23rd ofFebruary, the prosecution team is in need of this information as soon as possible. Thank youvery much for your assistance in this matter.Very Respectfully,Princeton BradleySergeant, U.S. ArmyParalegal Non?Commissioned 0FFicerMilitary Justice, OSJAFort McNair, 32 02930197 1Classification: UNCLASSIFIEDCaveats: FOUO02980200Sent ay, atT0: Bradle Princeton SGT Us JFH -N SJACc: Subject: RE: equest for General Counsel Point of Contact (UNCLASSIFIED)Sgt. Bradley,Please contact on this matter-.ThanksUS Agency For International Development1386 Ave NHWashington D.C 2652302980159 From: Bradley, Princeton L. SGT USA SJASent: Thursda March 29, 2012 5:33 PMTo: Cc: Subject: RE: Request to Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,I am usually in by 6860, however there is almost always someone who will bein the office before that time. My direct line is 292-685-4489. If there is noanswer then extension 1975 will reach anyone in our office.Very Respectfully,SGT Princeton BradleyParalegal Non?Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 02921722From: Fein, Ashden MAJ USA SJASent: Thursday, March 29, 2012 8:38 PMTo: David CoombsCc: 'Kemkes, Matthew MAJ USARMY 'Bouchard, Paul CPT USARMY ?JoshuaTooman'; ?Santiago, Melissa 8 CW2 USARMY Morrow JoDean, CPT USA JFHQ-Overgaard, Angel M. CPT USA Whyte, Jeffrey H.CPT USA Ford, Arthur D. CW2 USA SJASubject: RedactionsDavid,The government has no objection to a and below because those are matters 0F public record,so long as they are accurate. Depending on what is written in and c, the government mighthave an objection.V/rAshden02564273From:Sent:To:Cc:Subject:David Coombs com>Thursday, March 29, 2012 8:43 PMl-?ein. USA SJA'Kemkes, Matthew MAJ USARMY 'Bouchard_ Paul CPT USARMY (USYTooman' ?Santiago, Melissa CW2 USARMY Morrow JoDcan. CPT USA SJA Overuaard. Anuel CPT USA JFHO-SJ A com>; Ford. Arthur D. CW2 USA JFHQ-NC DW SJ ARedactionslhunk you for the clan ?cznion ill send the reductions on Mondzn. Ifyou spot anything that you Imc an inimcdizttc issue with. just let me knon.Best.Dm id E. Coombs. Esq.La? Ol?cc F. (?combsll South Street. #3 I 7Providence. RI Toll Free. I-800-588-l I56Local: (508) Fax: (508) coombsfa ??Con?dcntialit} Notice: This including inuyI contain confidential attomcy-client and 1S intended for thepcrsonts) or cotnpan_\ am not the intended recipient. pleasenotify the sender and delete all copies. disclosure. copyingor ILSC of this infonnution may be and is 02565652 From: NAVWARCOL ?@usnwc_edu] on behalf ofNAVWARCOLSent: Friday, March 30, 2012 8:21 AM To: Parra Jairo A. WO1 USA SJAAWNARCOUFein, Ashden MAJ USA SJASubject: Support for US v. PFC ManningAttachments: Courier Authorizationdoc; Courier Brie?ng.docN01 Parra,Since the Naval war College (NNC) has classified stand?alone laptops, I amrequesting not to hand?carry classified laptop or any classified materialsfrom your command. Also, classified printer and blank classified CD's willbe provided if needed.If hand?carrying classified laptop, via air travel, is opted, pleaseconsider the following request:1.) Courier must carry in his/her possession an UPDATED DD Form 2561.2.) Since classified materials are originating from your command, Irespectfully request to issue Authorization Letters for both arrival anddeparture dates from NNC. Please see attached sample of NNC AuthorizationLetter.3.) Courier must be briefed on his/her responsibilities. Please seeattached briefing for NNC Courier.4.) Classified materials must be deposited as soon as possible to NNCupon arrivalIf United States Postal Service (USPS) is opted, here is importantinformation for your reference:1.) The following address is for sending classified materials (Secretand below) to NNC:Outside package: PresidentNaval war College686 Cushing RoadNewport, RI 62841-1267Inside package: Attn: CMCONaval war College686 Cushing RoadNewport, RI 62841-1267Note: All registered mail addressed to President of the Naval war Collegeis opened ONLY by the Classified Material Control Officer (CMCO).2.) Registered Mail will take 3 or less working days before the materialarrives in its destination.3.) Federal Express, overnight can be used if overnight delivery ispreferred. Depending on the weight of the material, compared to using USPS,FedEx is cost effective contrary to others? speculation.4.) Using mail service is convenient especially if the Courier isarriving late at night. Courier will be able to go straight ahead tohis/her reserved room accommodation, go to dinner, and relax withoutworrying of the storage of classified materials.1025656525.) Using mail service will give me a chance to control and prepare thematerial for check?out.USPS or Secret Internet Protocol Router Network (SIPR) is the bestalternative for transmission of classified information (Secret and below).Unintentional, accidental or not, violation or infraction occur more in handcarrying classified materials.In the hope that you'll consider my request, I respectfully Classified Material Control OfficerNATO Sub?registry Control OfficerSIPR address: Naval war CollegeDSN:Comm:E?mai1: usnwc.eduHUMAN THREAT TO NATIONAL SECURITY:Did Not Know the Rules Did Not Understand the Rules - Did Not Follow theRules"FOR OFFICIAL USE ONLY PRIVACY SENSITIVE This electronic transmission>may contain confidential information intended only for the person(s)>named above. Any misuse or unauthorized disclosure may result in both>civil and criminal penalties. If you receive this transmission in>error, please notify the sender at the telephone number or e?mail addressabove.02949465From: Fein, Ashden MAJ USA JFHQ-NCRIMDW SJASent: Frida March 30 2012 8:37 AM To: Parra, Jairo A. W01 USA SJANAVWARCOLSubject: RE: Support for US v. PFC ManningMa'am,Thank you very much! The possible issue with Mr. Coombs and the defense using NwC'sstandalone classified laptops is that we must provide the defense with the ability to protecttheir information under the attorney/client privilege and work product privilege, thus no oneelse should be able to access the information (except security folks detailed to defenseteam). Additionally, at the end of the case, we will need to be able to preserve theinformation for the defense, if the accused is found guilty. will he be able to keep hisinformation digitally segregated from others who could possibly use the same laptops? Ifnot, we would like to provide a laptop to ensure there are no issues. Additionally, does theNNC standalone laptops burn we have and will have in the future classified information that we use in discovery that wemust provide to Mr. Coombs. Prior to now, our normal method of producing this information tothe defense is to the material onto (we have DOD authorization to burnclassified information). we then hand delivered the material with proper courierauthorization to the defense offices and they personally sign for and secure the material.we had intended to follow the same procedure, but send the material to NNC using authorizedmeans, USPS or FEDEX.Thank you again! I am confident that once we get the requirements setup, this should berelatively painless with our execution under the rules.V/rAshden02979379From: T@dm.usda.gov1Sent: Friday. March 30. 2012 8:55 AMTo: Bradle Princeton L. SGT USA SJAcc: oecSubject: RE: Delivery of ocuments (UNCLASSIFIED)Good morning Bradley,I'm working up the documents now and creating a transfer receipt. As soon as I'm ready tohead over, I will send you an email.Regards,02565646From: NAVWARCOL _@usnwc.ed u] on behalf ofNAVWARCOL Sent: Friday, March 30, 2012 11:08 AMTo: Fein, Ashden MAJ USA Parra. Jairo A. W01 USA SJACc: USA NAVWARCOL NAVWARCOLSubject: RE: Support for US v. PFC ManningFlag Status: CompletedSir,I will assign a stand- alone classified laptop solely for the defense teamuntil the job is done. Just let me know who will check it out. If you wantto preserve the information before the team leaves NNC, we can downloadeverything in CDs and delete all information from the laptop before I takeback its custody. I'll make sure that the laptop assign to the team haveburning capability, and that updates are installed.Also the classified safe in the workspace assigned to the defense team isalready in place, and will change the standard combination as soon aspossible. The two-drawer safe is for storage of classified materialsincluding the laptop.I understand how it is to protect and preserve important information soplease do not hesitate to contact me if there's anything else I can do toassist.wr:02983557From: Whyie, Jeffrey H. CPT USA SJASent: Frida March 30, 2012 11:13 AMTo: ?c.gov'Cc: ra ey, Princeton L. SGT USA SJASubject: US v. Manning (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOMa?am,I am one of the prosecutors in the case of United States v. PFC Bradley Manning. Per ourconversation, please send our office a copy of whatever document, if any, your organizationprovided NCIX in response to the alleged compromise of information in our case. The documentmay have assessed, for instance, what, if any, damage was caused to your organization becauseof the compromised information.CAUTION - If you send me the document via email, please do not write in the emailbecause our server is blocking emails with that word included. Thank you.Thank you so much for your help with this!v/rCPT whyteClassification: UNCLASSIFIEDCaveats: FOUO02983555From: Whyie, Jeffrey H. CPT USA SJASent: Friday, March 30, 2012 11:33 AMTo: Subject: RE: US v. Manning (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOMa'am,That is perfect. Thank you.Does your organization have any issue with us providing this document to thedefense in discovery?Thanks,CPT whyteMessage-??--From: Sent: Friday, March 36, 2612 11:26 AMTo: whyte, Jeffrey H. CPT USA SJASubject: RE: US v. Manning (UNCLASSIFIED)Sir,This letter pertains only to the records received from the Office ofNational Intelligence. It is an unclassified letter.FTCFrom: whyte, Jeffrey H. CPT USA SJAmailtoSent: Friday, March 30, 2012 11:13 AMTo=?Cc: Bradley, Princeton L. SGT USA SJASubject: US v. Manning (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUO02983555Ma'am,I am one of the prosecutors in the case of United States v. PFC BradleyManning. Per our conversation, please send our office a copy of whateverdocument, if any, your organization provided NCIX in response to the allegedcompromise of information in our case. The document may have assessed, forinstance, what, if any, damage was caused to your organization because ofthe compromised information.CAUTION If you send me the document via email, please do not writein the email because our server is blocking emails with thatword included. Thank you.Thank you so much for your help with this!v/rCPT whyteClassification: UNCLASSIFIEDCaveats: FOUOClassification: UNCLASSIFIEDCaveats: FOUO02919448From: Fein, Ashden MAJ USA SJASent: Frida Marc 30 2012 12:18 PM To: Parra Jairo A. W01 USA SJACc: USA NAVWARCOLSubject: RE: Support for US v. PFC ManningThank This should work. we will start coordinating getting the information up North.To recap-NWC Responsibilities:1. Provide the standalone classified laptop dedicated to the defense with burningcapability, which will be signed out to Mr. Coombs.2. Provide printer and print toner for the defense.3. Provide the safe for the material and laptop.4. Provide conduit for defense to scan and send classified emails (BUT NOT ACCESS SIPRNETnor have POC access ANY information on SIPRNET except emails pertaining to this case) 5.Receive any USPS Registered FEDEX classified discovery we send for the defense.6. Receive any classified emails containing discovery or other communications from thedefense team or prosecution or Court.Prosecution Team Responsibilities:1. Provide any additional supplies, including toner, if requested by NWC.2. Send SIPRNET email information to POC for the defense.3. Send USPS Registered FEDEX classified discovery for the defense.v/rAshden02565642From: on behalf ofAVWARCOLSent: Friday. March 30, 2012 12:47 PMTo: Fein, Ashden MAJ USA Parra, Jairo A. W01 USA Cc: NAVWARCOLSubject: RE: Support for US v. PFC ManningAshden,Thank you! I will proceed putting things together, and let us know ahead oftime of the team arrival.wr - 02980093Sent on ay, pn To: Bradley, Princeton L. SGT USA SJASubject: FW: Wiki UpdateSGT Bradley,Please see below. we could not Tind any TVA documents sent to NCIX, so I had them checkaround, and this was what I learned. It doesn?t appear that any TVA documents were involved.AttorneyTVA 0FFice o? General Counsel466 W. Summit Hill Drive, NT 6Knoxville, TN 37962(fax)- va. 0V) NOTICE: This electronic message transmission contains in?ormation which may be TVA SENSITIVE,TVA RESTRICTED or TVA CONFIDENTIAL. Any misuse or unauthorized disclosure can result in bothcivil and criminal penalties. If you are not the intended recipient, be aware that anydisclosure, copying, distribution or use of the content of this information is prohibited. Ifyou have received this communication in error, please noti?y me immediately by email anddelete the original message.02560674From: ?@dodiis mi|>Sent: Monday. April 2, 2012 12:13 PMTo: Fein. Ashden MAJ USA SJASubject: Question re Manning - Ruling on Defense Motion to Compel DiscoveryYes, absolutely. An_\ lune I and 441) 02979985From: Bradley, Princeton L. SGT USA SJASent: Monday, April 02, 2012 2:wnyte. Jeffrey CPT USA JFHQ-SJASubject: RE: Your request for OGC POC (UNCLASSIFIED)Attachments: Request to Review NCIX ResponsepdfClassification: UNCLASSIFIEDCaveats: FOUOGood afternoon, I hope that you are well. Please see the attachedwritten request to review the NCIX responsive documents created by yourorganization. Should you require any additional information please contactme and I will be happy to oblige.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 102979853From: Bradley, Princeton L. SGT USA SJASent: Wednesda A nl 04, 2012 8:18 AM To: sa.gov'Cc: Whyte, Jeffrey H. CPT USA SJASubject: NCIX Response Documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good morning, I hope that you are well. I just wanted to ask if you everreceived the SIPR email from Fein? I am asking because he notified me that he has notreceived the email containing the documents we discussed. IF it turns out that you cannottransmit them over SIPRNET, please let me know and we will use JNICS instead (it will justtake longer for us to confirm receipt).Very Respectfully,SGT Princeton BradleyParalegal Non?Commissioned OfficerMilitary Justice, OSJAFort McNair, 32Classification: UNCLASSIFIEDCaveats: FOUO02979848Fr?m= Sent: Wednesday, April 04, 2012 8:59 AMTo: Bradley, Princeton L. SGT USA SJASubject: Re: NCIX Response Documents (UNCLASSIFIED)Based on what has been in the news on GSA, I have been tied up with other immediate actions.i have time this morning and will ensure that I send the documents. I will send you an emailon the low side once the package has been sent.02979952 From: Bradley, Princeton L. SGT USA SJASent: Wednesda April 04, 2012 9:10 AMTo: Cc: (HQ-M8000)Subject: equest to eview NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOGood morning, I hope that you have been well since we last spoke. Iapologize for the delay in my next request, but I would like to know if itis possible For the prosecution to review the SECRET memo that was sent toONCIX. If possible please Forward the document to our lead prosecutor MAJFein at the address below. Should there be any questions or concerns pleaselet me know and I will be happy to address them. Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 3202979999From= ?@opm.9ov1Sent: Wednesday, April 04,2012 9:31 AMTo: Bradley, Princeton L. SGT USA JFHQ-NCRIMDW SJACc: Ford, Arthur D. CW2 USA JFHQ-NCRIMDW Fein, Ashden MAJ USA Why1e, Jeffrey H. CPT USA Subject: RE: Your request for OGC POC (UNCLASSIFIED)Our Associate General Counsel has approved your request. I will instruct our security officeto make courier arrangements with you for the relevant classified records. Under separatecover we will send you an unclassified letter memorializing the approval.Sincerely, Office of the General CounselU.S. Office of Personnel ManagementTel:Fax:E?Mai1: o.pm.govThis message, including any attachments, is intended for the use of the addressee(s) only,and it may contain information that is confidential, privileged or legally protected.Unauthorized review, distribution or copying of this message or of any accompanyingattachments is prohibited. If you have received this message in error, please contact me byreturn email or by telephone, and permanently delete it and any accompanying attachments fromany system on which they may be stored.02979516From: Bradley. Princeton L. SGT USA SJASent: Wednesday, April 04, 2012 9:Whyie, Jeffrey H. CPT USA JFHQ-SJASubject: RE: DOE WikiLeaks Response to NCIX (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good morning, I hope that you are well. I am SGT Princeton Bradley,a paralegal For the prosecution team in the U.S. Army Court-Martial ofPrivate First Class Bradley Manning with regard to "w#kileaks". I amcontacting you in regard to the documents you have submitted to ourprosecutor MAJ Fein via classified email. I understand that the informationis sensitive in nature, but because the documents themselves are not markedcan you please confirm the proper classification level of the information?Thank you in advance For your assistance on this matter.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 02979548From: Bradley, Princeton L. SGT USA SJASent: Wednesda A ril 04, 2012 10:24 AMTo:Cc: Whyte, Jeffrey H. CPT USA SJASubject: RE: NCIX Documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOU0 Good morning, I hope that you have been well since we last spoke. Iam emailing you to confirm the classification level of the documents wereceived from you since the documents themselves were not marked. Thank youagain for all the help you have provided, hopefully we will be able to stayout of your hair.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32S102979939From: ?@nasa.9ov1Sent: Wednesday, pril 04, 2012 10:44 AMTo: Bradle Princeton L. SGT USA SJACc: (HQ-MB000)Subject:RE: uest to Review NCIX Response (UNCLASSIFIED)Signed By: ?@nasa.govBradley,I will Forward the memo today. 02555315Overgaard, Angel CPT USA SJAFrom:Sent: Wednesday, April 4, 2012 l0:46 AMTo: Bouchard, Paul CPT USARMY (US) Cc: Fein. Ashden USA SJADavid Coombs ; Parra, Jairo A. W01 USASJA Ford. Arthur D. CW2 USASJASubject: Request additional nding, computer forensics. US v. Manning (UNCLASSIFIED)Attach: request additional funding 28 signedpdf Classi?cation. UNCLASSIFIEDCaveats: FOUOPaul.Could sou please provide more detail to the 3 Apr I2 request?? Since this is the second time defense is asking the CO to approxeadditional funds for defeme expens in just over 2 months. he ill likely need more of an explanation of why the last estimate was notrealistic and this one is.It seems that appx $4200 is for Mr presence at the motions hearing. but hat about the rest of the le. do the}need more than \\?l1ill the CG granted on I Feb [2 and where did that mone} go?? The requests states that last time the defense teamearl}. uhich scents to indicate that there still should be money remaining.Recommend drafting request like the last one (attached) for the most expeditious handling of the request. The attached pl?C\?lOllSrequest gives a breakdonn of the amount requested as well as a justification so the CG knew In the money was necessary. Thankvou?r.Angel02564250From: David Coombs Sent: Wednesday, April 4, 20l2 1'16 AMTo: Overgaard, Angel M. CPT USA SJA 'Bouchard, Paul CPT USARMY Cc: Fein, Ashden MAJ USA SJA Parra, no A. W01 USA Ford, Arthur D. CW2 USA SJA Subject: RE: Request additional funding, computer forensics, US v. Manning (UNCLASSIFIED)Angel.Our understanding is that the Govemtnent would like to have the fundingrequests done in increments as opposed to one lump sum?? If that is uue, wewill likel_v make these types of requests whenever additional work/pretrialpreparation is needed. 1 am not for sure how much of the initially approvedfunds are remaining. however. is that something that Mr. Parra or CW2 Fordcan tell us?? Once we have this ?gure. we could track the amount ofremaining funding left and the necessity for any future requests. Thelatest request is simply an estimate As we stated in the request. it islikely that the entire amount of funding will not be needed.If you would like. 1 could explore providing a lump sum estimate for thelikely forensic services/pretrial preparation/trial testimony for Mr Lakesand Mr. Stnittrnarm. Obviousl_v. this would be a best guess estimate. itthe funding were approved. it would eliminate the need to provide periodicrequests.With regards to additional justification for our latest request. theforensic work that was initially cotnpleted was designed to provide theDefense with an assessment of the work done by 1U and to determine if ourexperts spotted any issues. Based upon their report, the Defense hadseveral follow up questions/issues that need to be addressed in order for usto adequately prepare for trial. These additional questions/issues requiremore forensic work to be completed. Does this make sense?? Let me know ifthis is responsive to your questions and whether you would like a lump sumrequest to the CG or if we should continue submitting requests.Best.DavidDavid E. Coombs. Esq.Law Office of David E. Coombsll South Angel] Street, #317Providence. RI 02906Toll Free: 1-800-588-4 I56Local: (508) 689-4616Fax?: (508) 689-9282*??'Conf'ideritiality Notice: This transmission, including attachments, maycontain confidential attomey-client infonnation and is intended for theperson(s) or company named. If you are not the intended recipient. pleasenotify the sender and delete all copies. disclosure. copyingor use of this infonnation may be unlawful and is 02978046From: Bradley, Princeton L. SGT USA SJASent: Wednesda . A ril 04. 2012 1:54 PMTo: Cc: hyte, Je rey H. CPT USA SJASubject: RE: NCIX Documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOU0Sir,Good afternoon, I hope that you have been well. I am contacting youto ask if there has been any changes or updates with regard to our requestto review your agency's NCIX response. Please let me know if you need anyadditional information on our part and I will do my best to assist.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 02919503From: Fein, Ashden MAJ USA SJASent: Wednesda ril O4, 2012 1:57 PM To: Parra, Jairo A. wo1 USA SJACc: USA Subject: RE: Support for US v. PFC ManningMa'am,Did you receive the below email? IF so, is this an accurate reflection of our initialdivision or responsibilities? Thank you.V/rAshden 02979346From: Bradley. Princeton L. SGT USA SJASent: Wednesda ril 04, 2012 1:57 PMTo:Cc: Whyte, Jeffrey H. CPT USA SJASubject: RE: Request to Reveiw NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good afternoon, I hope that you have been well. I am emailing youto ask if you have had any success in tracking down the aforementioneddocuments. If you would prefer, I can ask our lead prosecutor to put you incontact with the personnel from the NCIX who would be in possession of yourresponse, should it in fact exist. Please let me know if there is anythingthat we can do to help.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 A02555302From:Sent:To:Subject:Overgaard. Angel M. PT USA SJAWednesday, April 4, 2012 2: 16 PMDavid Coombs 'Bouchard. paul USARMY Fein. Ashden MAJ USA SJA Parra. Jairo A. W01 USA SJA Ford. Arthur D. CW2 USA SJA n>RE Request additional funding, computer forensics. Class'ification: UNCLASSIFIEDFOUODa\?ld.l'm not sum here the incremental idea came from as that does not seem to be 111 line with the cost of etnplo_\ inent?required RCM 7t)3d An or littnp sum request for the likely forensic services/preinal preparzittort/tnal testimonyfor Mr Lakes and Mr. Stnittmann is to give to tire CG an accurate picture of amount of money that ?ill be required tofund thetn. The ttmount oit the contract does not matter as it is not C0llSidC red hen the makes his determination and contracting.catuiot pat an_\ amount the approval.Please estimate the full amount that is anticipated and submit it detailed request that shows hou the pre\ ious mone_\ was expended sothat the can make an infomied decision on funding. Please include the total amount of hours uorked and the total amount offtitune liotirs estimated uitlijitstificzitiort in your detailed accounting. Thank _\'0ulV/r.A ngel 02979417From: Bradley, Princeton L. SGT USA SJASent: Wednesda A ril 04, 2012 2:48 PM To:Cc: Whyte, Jeffrey H. CPT USA SJASubject: RE: Request to Review NCIX Response (UNCLASSIFIED)Attachments: Request to Review NCIX Response.pdfClassification: UNCLASSIFIEDCaveats: FOUOSir,I apologize For the lapse in communication on our end. Attached tothis email is our written request to review the NCIX response from yourdepartment. .Please let me know if there is any additional information yourequire and I will be happy to oblige.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 02565559From:SentTo:Cc:Sumem:Ashden,NAVWARCOL _@usnwc.edu] on behalf ofNAVWARCOLWednesday. April 04, 2012 3:00 PMFein, Ashden MAJ USA Parra, Jairo A. wo1 USA NAVWARCOL:NAVWARCOL NAVWARCOL2NAWNARCOLRE: Support for US v. PFC Manning Yes I received your e?mail. See my response below.All is set:workspace is ready.- (Stand- alone)Classified laptop is updated.?(Stand- alone)Classified Printer is set up.-Control procedure is in place.~My SIPR account is active to assist the team.-After the "job" is done, information is downloaded for control andtransmission in the CD, and all information is deleted from the laptop, harddrive will be completely wiped after the team leaves NNC.Badge access for the Naval war College will be ready as soon as we receivenotification of the team's arrival.Please don?t hesitate to contact me if there's anything else I can do toassist.Classified Material Control Officer (CMCO) From:SentTo:Cc:Subject:Thank you very much!Fein, Ashden MAJ USA SJAWednesday, April 04, 2012 3:22 PM Parra, Jairo A. wo1 USA SJA- RE: Support for US v. PFC Manningwe are going to work to receive the approval through the Army G2 to have you designated theauthorized government official for defense SIPRNET access. Once that is complete, then weshould be on our way.Additionally, we are working to get the first batch of ready to send FEDEX overnight.I hope to have them in the mail on Monday, and we will let you know when they are off bysending the tracking number.Thank you again!v/rAshden02565548NAVWARCOL ?@usnwc.edu] on behalf of NAVWARCOLSent: Thursday, April 05, 2012 7:42 AMTo: Fein, Ashden MAJ USA Parra, Jairo A. W01 USA NAVWARCOLSubject: RE: Support for US v. PFC ManningAshden,I believe everything is in place. And as soon as the team arrives:?Badge will be issued;Security will give a short brief;will escort the team in their workspace;- will turn over custody of classified safe;- CMCO will issue classified materialsall are good to go!Also, sending the FEDEX tracking number is much appreciated. Our excellentmailroom staff voluntarily make special trip whenever I send the trackingnumbers.Thank you for keeping me posted.V/r Classified Material Control OfficerNATO Sub?registry Control OfficerSIPR address: -@nwc.navy.smil.milNaval war Colle DSN:Comm:Ejmailz @usnwc.eduHUMAN THREAT TO NATIONAL SECURITY:Did Not Know the Rules Did Not Understand the Rules Did Not Follow theRules"FOR OFFICIAL USE ONLY PRIVACY SENSITIVE This electronic transmission>may contain confidential information intended only for the person(s)>named above. Any misuse or unauthorized disclosure may result in both>civil and criminal penalties. If you receive this transmission in>error, please notify the sender at the telephone number or e-mail addressabove.02980028From: _@opm.gov1Sent: Thursday, April 05, 2012 12:12 PMTo: Bradle Princeton L. SGT USA SJACc:Subject: Courier Arrangements for NCIX documentshnponance: i?ghGood Afternoon SGT Bradley,we have received the formal request to review the NCIX responsive documents. Our AssociateGeneral Counsel, has approved release of the documents. In order to ensure that the Armyreceive the documents no later than April 10, 2612. Please coordinate courier arrangements.I am located at headquarters and the address is 1909 Street, N.w. Washington, DC26415. Thank you.U.S. Office of Personnel Management 02980444From: Bradley, Princeton L. SGT USA SJASent: Thursday, April 05, 2012 12:34 PMTo: Ford, Arthur D. CW2 USA SJACc: Whyte, Jeffrey H. CPT USA SJA: Fein. Ashden MAJ USA JFHQ-SJASubject: FW: Couner Arrangements for NCIX documents (UNCLASSIFIED)hnponance: I?ghClassification: UNCLASSIFIEDCaveats: NONESir,when can we arrange to pick up these documents? If possible, I would like to pick upthe documents from the National Science Foundation on the same day we pick up these.Very Respectfully,SG1 Princeton BradleyParalegal Non-Commissioned OFFicerMilitary Justice, OSJAFort McNair, 32 9465From:SentTo:Cc:Subject:Thank you again.Fein, Ashden MAJ USA SJAThursda A mos 2012 12:47 PMParra, Jairo A. wo1 USA SJAUSA NAVWARCOL5 RE: Support for US v. PFC Manningwe are working on the Final approval from the Army G2. One Final note, ifthere is anything that Mr. Coombs requests that is outside the scope of our agreement, pleasenotify him that he must ask us (the prosecution) to assist and then we will work with NNC onthe issue.v/rAshden02930022From: Bradley, Princeton L. SGT USA SJASent: Thursda A ril 05 201212153 PM To:Cc: Ford. Arthur D. CW2 USA SJASubject: ouner Arrangements for NCIX documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONEGood afternoon, I hope that you are well. would it be ?easible ?or us to pick up thedocuments at about 1600 hours on Tuesday, April 10th?Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned officerMilitary Justice, OSJAFort Mcnair, 32 . 02565446 From: NAVWARCOL ?@usnwc.edu] on behalf ofSent: Thursday, April 05, 2012 12:59 PMTo: Fein, Ashden MAJ USA Parra, Jairo A. W01 USA Cc: USA NAWNARCOUNAVWARCOLSubject: RE: Suppon for US v. PFC ManningAshden,Roger to that. Thank you!Wr-02979968From: Bradley, Princeton L. SGT USA SJASent: Thursday, April 05. 2012 1:25 PMTo: Cc: e, Jeffrey H. CPT USA SJASubject: Pick Up of NCIX Responsive Documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONESir,Good afternoon. As per our phone conversation, if is possible we would liketo come by The National Science Foundation building and pick up the documents at 0939 onTuesday, April 19th.will be arriving to receive the documents.time please let me know and we will adjust the plan.More than likely I, along with another member of our prosecution team,If there are any conflicts or concerns with thisThank you again for your help in thismatter and have a great day.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerCaveats: NONEMilitary Justice, OSJAFort McNair, 32 Classification: UNCLASSIFIED02979588From: Bradley, Princeton L. SGT USA SJASent: Thursda A ril 05. 2012 4:53 PMTo: doI.govCc: hyte, Jeffrey H. CPT USA SJASubject: Request for General Counsel's Office Point of Contact (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONESir,Good afternoon, I hope that you are well. I am a paralegal for the prosecution team in theCourt?Martial of Private First Class Bradley Manning in connection with "wnkileaks." Thepurpose of this email is to request a point of contact in your General Counsel?s Office withregard to the documents your organization sent to the NCIX regarding the "w#kileaks"incident. Those documents, should they be deemed relevant and necessary, would be used inthe U.S. Army Court Martial of PFC Bradley Manning, but only with the permission of youragency. These documents will remain classified at all times, and will only be used, if at all, withinthe guidelines given by your General Counsel?s Office. This being said, the prosecutingattorneys need to coordinate with your OGC department to establish those guidelines andensure proper use of those documents. If at all possible, please send both SIPRNET and JNICSemail addresses, as well as phone numbers, for the points of contact that you are able toobtain. Also, I would stress that because the accused was arraigned as of the 23rd ofFebruary, the prosecution team is in need of this information as soon as possible. Thank youvery much for your assistance in this matter.Very Respectfully,Princeton BradleySergeant, U.S. ArmyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 02979579From: ?@doI.gov1Sent: Thursday, April 05, 2012 5:00 PMTo: Bradle Princeton L. SGT USA SJACc: SOLSubject: RE: Request for General Counsel's Office Point of Contact (UNCLASSIFIED)Hi Princeton,I suggest that you contac- I?ve copied him above.02979581From: Bradley. Princeton L. SGT USA SJASent: Thursda ril 05, 2012 5:04 PMTo: ismCc: hyte, Je rey H. CPT USA SJASubject: Request for General Counsel's Office Point of Contact (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONESir,Good afternoon, I hope that you are well. I am U.S. Army Sergeant Princeton Bradley, aparalegal for the prosecution team in the Court-Martial of Private First Class BradleyManning in connection with ?w8kileaks." The purpose of this email is to request a copy ofall documents that your organization provided to NCIX approximately one year ago. Although wehave been coordinating with for the past year, just recently they have determinedthat we cannot review copies of your organization's documents in their possession, and wemust directly go to your organization to coordinate a review.we are requesting this information to determine if there is any information that may bediscoverable and may require production by the government. None of the information will leaveour office, unless your organization has approved its release, and if those documents areclassified, they will remain classified at all times.we would like to review the documents from your organization as soon as possible. This shortsuspense is necessary as the accused was arraigned on the 23rd of February, and to allow forenough time to coordinate with your organization, if information is discoverable. If thedocuments referenced are classified, please feel free to use the SIPRNET and JNICS emailaddresses elnw for nur load nrosecutor, Major Ashden Fein. If you would like to speak withme, p1eas and if ou would like to speak with our lead prosecutor,please call Major Ashden Fein at thank you.Very Respectfully,Princeton BradleySergeant, U.S. ArmyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 From Bradley, Princeton L. SGT USA SJASent: Thursday. April 05, 2012 5:08 PMTo: hhsgovCc: hyte. Jeffrey H. CPT USA SJASubject Request to Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONESir,Good afternoon, I hope you have been well since we last spoke.I am just emailing youto ask if you or anyone else in your office has had an opportunity to locate the responsegenerated by your office with regard to the NCIX "w?kileaks" document review.Please let meknow if you need any additional information from our office and I will do my best to assist.Very Respectfully,SGT Princeton BradleyCaveats: NONEParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32?ElClassification: UNCLASSIFIED02936179From:Sent:To:Cc:Subject:Attachments:Sir,Fein, Ashden MAJ USA SJAAMUSA OTJAGFord, Arthur D. CW2 USA SJADocs120404?Request for Limited Defense Access to SIPRNET 120405-Request for Consent to Disclose Classified Information.pdf; 120316-Order (Protective OrderClassified information).pdfAttached are the two requests. I will send the classified enclosure on SIPR this morning.Our SIPR is Very slow, so I will list out the documents in an email and then send the actualenclosure.02918829From: Fein, Ashden MAJ USA SJASent: Friday, April 06, 2012 10:42 AMTo: DISA CIV DISA PEO-MAcc: Ford, Arthur D. CW2 USA Morrow Ill, JoDean, CPT USA JFHQ-SJASubject: RE: Thin Client Issues/Spt. to Trial Counsel (UNCLASSIFIED)Ma'am,Thank you. I do show that the email went out and your inbox should have received it. Ishould have better clarified our request. we would like to discuss the documents with you soyou know what we are turning over and to discuss the way Forward, based on your email below.As Far as actual approvals- we already have or will have the approvals to turn the documentsover in classified discovery. we would like to chat about their use during the trial.Thank you very much!v/rMAJ Fein From: David Coombs Sent: Friday, April 6, 20l2 lO:42 AMTo: Overgaard. Angel M. USA SJA'Bouchard, Paul CPT USARMY Ce: Fein. Ashden MAJ USA . Parra. Jairo A. W01 SJA Ford, Arthur D. CW2 USA SJA Santiago. Melissa CW2 USARMY(US)Subject: RE Request additional funding, computer forensics. US v. Manning (UNCLASSIFIED)Attach: Forensic Funding Funding Angel.Please see that attached request along with the reference Letme know if you ll2I\'C ilddiliollili questions. and yyheii you thisrequest to be acted upon by the ziuthonty Lastly. can youprovide me \\ll1lim update regarding the "oy'emge" issue from the initialfunding uutliorimtion?? wzint to sure that Mr. Ltikes and Mr.are paid for the work that they have perfomied. Thankyou.Best.DavidF.. Cooinbs. l-EsqL2l\\' O?'ice of D1l\'ld E. I 1 South Angeli Street. #317Providence. RI Toll Free: I56(508) Fax? (SUX) Notice: This including tittxiehments. maycontain confidemuil attomey-client infonnzition and is intended for thepersoiitsi or company named. Alf you are not the intended pleasenotify the sender and delete all copies. Unuutliori/.ed disclosure. copyingor use ofthis may be uiilayyful is Fromr ?@bb9?9ov1Sent: Friday, April 06, 2012 10:48 AMTo: Bradley, Princeton L. SGT USA SJACc: Whyte, Jeffrey H. CPT USA SJAsubject: RE: Request to Reveiw NCIX Response (UNCLASSIFIED)SGT Bradley,I've confirmed that our response to NCIX on this matter was in fact written by hand.Unfortunately, we did not make a copy of the response, and therefore NCIX has the originaland only existing copy.At this point, I see three possible courses of action:1. we could.contact NCIX and authorize it to release a copy of our response to your team; 2.we could contact NCIX and attempt to obtain a copy of the response to forward to you; 3.Your team can determine whether or not a copy of our response is even necessary to your case. After discussing our agency's response with I doubt that it will be of anysubstantive value to your case. However, if you still require a copy in order to establishthe responses from every Executive Branch agency, we're ready to assist you in trying toobtain one from NCIX.If you would like to call me to discuss the issues, I can be reached at I willbe leaving today at 1309, but I'll be back in the office Monday morning.Again, I apologize for how long it's taken the agency to sort this all out, but I lookforward to working to help you however we can.Regards,Broadcasting Board of Governors 02564223 From: David Coombs Sent: Friday, April 6. 2012 10:49 AMTo: Fein, Ashden MAJ SJA 3Cc: Morrow J0Dean. CPT USA SJAOvergaard, Angel M. CPT USA JFHQ-NC DW SJA rn>; Whyte, Jeffrey USASJA Ford, Arthur D. CW2 USASJA ?Santiago. Melissa CW2USARMY (llS)' os ua Tooman'Subject: iseovery esponseAttach: Defense Discovery ResponsepdfAshden.Here is the Defense discover} response. As stated in the response. he uillensure that _\ou are pro\ ided timelx access to the reciprocal discoier}.Please let me kno\\ if you questions.Best.Dai id E. Coonihs. Esq.Of?cc of David E. CoouibsI I South Angeli Street. #317Prmidcnce. Rl loll Free: Local (508) Fax: (508) cooinbs xx ??Con?dentialit_\ Notice: This including mil}contain altonie} ?cliei1t iitfontuttion and is intended for thepersontsi or named. If you are not the intended recipient. pleasenotify the sender and delete all copies. Un;inthon'zed disclosure. cop) ingor use infonnation be and is pmliibited 02983549 From: Whyte, Jeffrey H. CPT USA SJASent: Friday, April 06, 2012 11:32 AMTo:Cc: dni.gov; Fein, Ashden MAJ USA ra ey, Princeton L. SGT USA SJASubject: US v. Manning (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOU0mi:The prosecution in the case of United States v. PFC Bradley Manning requested to review thedocument your organization, the Broadcasting Board of Governors (BBG), provided NCIX inresponse to the compromised information. You told me the BBG provided NCIX with ahandwritten document, but that the BBG does not have a copy of this document in its records.Per our conversation earlier this morning, you told me your organization has authorized theprosecution to review this document.I am CC-ing two members of NCIX to this email who may require Further information to locatethis document and Further veriFication before sending the document to the prosecution.Please coordinate with them, so that we can timely review this document. This is time-sensitive.Thank you For your support, Sir. Have a good weekend.v/r3. Hunter whyteCPT, JATrial CounselUnited States Army Military District of Washington UAH [9423From: @doc.gov]Sent: nay, pr: 22:49 PMTo: Bradle Princeton L. SGT USA SJACc:Subject: RE: Request to Review NCIX Response (UNCLASSIFIED)Sgt. Bradley my staff will collect the documents and coordinate with you For delivery earlynext week. u4s/u4z/From: Bradley, Princeton L. SGT USA SJASent: Friday, April 06, 2012 2:57 PMTo:Cc: hyte. Jeffrey H. CPT USA SJAsubject: RE: Request to Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,That sounds great, please just let me know when you would like the documents to bedropped off and I will ensure that the proper arrangements are made. Thank you again Foryour help in this matter and I apologize For taking so long to respond to your request.Very RespectFul1y,SGT Princeton BradleyParalegal Non-Commissioned OfiicerMilitary Justice, OSJAFort McNair, 32 102919474From:SentTo:Cc:Sumem:Attachments:For your records.counsel to use you as the POC for SIPRNET emails.Fein, Ashden MAJ USA SJAFrida A ril O6 2012 5:12 PMParra, Jairo A. W01 USA SJASA ems; COL-NAWWARCOLRE: Suppon for US v. PFC Manning120404-Request for Limited Defense Access to SIPRNET Attached is a copy of the approval memorandum that authorizes the defenseThis memo was initialed by the DeputyChief of Staff for Intelligence, US Army.Following this email, I will send an email to Mr. Coombs with you Cced to introduce you andnotify him of the approval.v/rAshdenThank you again!02564220 From: David Coombs Sent: Friday, April 6, 2012 5:43 PMTo: Fein, Ashden MAJ USA SJACc: 'Kemkes, Matthew MAJ USARMY (US)'Bouchard, Paul CPT USARVIY ?Santiago,Melissa CW2 USARMY Morrow Ill,JoDean, CPT USA SJA Monday, April 9. 20l2 PMFein. Ashden MAJ USA JFHQ-NCIUMDW SJA 'Kemkes. Matthew MAJ 'Bouchard, Paul CPT USARMY Santiago?Melissa CW2 USARMY Morrow JoDean, CPT USA SJA Overgaard. Angel CPT USA SJA Whyte, Jeffrey PT USA SJA Ford, Arthur D. CW2 USA RE: Grand Jury Testimony Ashden.I am not for sure I understand our response What IS the "diseotemblematcnal" standard that _\ou are using to detertninc what to disclose?? Also.do you ll would take until Ist to complete your revicui? TheJur_\ tm'estig;ition started in December of 20 It). At that time. theDefense requested access to the investigation being conducted by the DOJ .Additionally. you have been on notice that these materials were the subjectof :1 compel discovery motion since Febniar}. I am not clear on uh} thereview hasn't :ilre:id_\ been done. and uh} I don't have these documentsBest.Dan idDavid E. Coonibs. Esq.Law Office of David E. oonibsI South Angeli Street. #1 I 7Providence. RI t)29tJ(?Toll Free: I56Local" (508)689-1616Fax: (508) Corn"?Con?dentialit_\ Notice: This transmission including ma)contain con?dential attome) -client infonnation and is intended for thepcrsontst or compan_\ named. lfgtou are not the intended recipient. pleasenottf_\? the sender and delete all copies disclosure copyingor use ofthis inlbnuation run; be unlauful and is prohibited.??02985603From: Whyte, Jeffrey H. CPT USA SJASent: Monda A ril 09, 2012 2:30 PMTo: wusms)Subject: ocumen request (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONESir,I spoke with you last week about a document our office was requesting from your organizationrelating to the case of US v. PFC Manning. Earlier today, I spoke with a member of ourorganization who said he would email me the re uested document. I think it washCan you please forward this email ti?I am writing you because we are having problems with our email server, so I'm afraid anyemail sent by?did not reach me. If he is sending me the document, please advisehim not to use the word ?w*k*Le*ks" because that word is currently blocked.Thank you, Sir.v/r3. Hunter whyteCPT, JATrial CounselUnited States Army Military District of washington uzu1rb3UFrom: Fein, Ashden MAJ USA SJASent: Monda ril 09, 2012 9:45 PMTo: ?ws)Subject: UpdateSir I am conducting an accounting o? everything I am tracking ?or organizations. Can youplease veri?y that the information below is accurate? Thanks!Ashden02917545From:Sent:To:Cc:Subject:Fein, Ashden MAJ USA SJA012 10:06 PMHaberland, John CPT USA Regimental Judge Advocate;Morrow Ill, JoDean, CPT USA Overgaard, Angel M. CPT USAVonEIten, Aiexander S. 1LT USA Whyte,Jeffrey H. CPT USA SJAUpdate Sir I am conducting an accounting of everything I am tracking For organizations across theboard.AshdenCan you please verify that the information below is accurate? Thanks!02917520From:Sent:To:Cc:Subject:Fein, Ashden MAJ USA SJAMonda A ril 09 2012 10:08 PMUSA USCENTCOM CCJA-SJAHaberland, John CPT USA Regimental Judge Advocate;Morrow JoDean, CPT USA Overgaard, Angel M. CPT USAVonEIten, Alexander S. 1LT USA Whyte,Jeffrey H. CPT USA SJAUpdme Sir I am conducting an accounting of everything I am tracking ?or organizations. Can youplease verify that the information below is accurate? Thanks!Ashden02932004From:SentTo:Cc:Sumem:David,Fein, Ashden MAJ USA SJATuesday, April 10,2012 8:34 AMDavid Coombs'Kemkes. Matthew MAJ USARMY 'Bouchard. Paul CPT USARMY ?Santiago,Melissa 8 CW2 USARMY Morrow Ill, JoDean, CPT USA Overgaard_ Angel M. CPT USA Whyte, Jeffrey H. CPT USA JFHQ-Ford, Arthur D. CW2 USA SJA RE: Grand Jury TestimonyMaterial outside the possession of military authorities is discoverable under RCM 7B1(a)(6)and Brady.The United States has provided the defense FBI and grand jury material above andbeyond this requirement and continues to review and coordinate additional review of material,including testimony.This case was referred in early February, and we have since beenlitigating this issue, which resulted in the United States informing the Court and defensethat we intend to produce, as soon as practicable, any discoverable material we identify andhave approval to make available. No later than 1 May is our best estimate considering theamount of information that the prosecution has a due diligence requirement to review andwhich we have been and are continuing to review.v/rAshden \lGnII\l\IlIll\?From:nara.gov]Sent: Tuesday, April 10, 2012 8:46 AMTo: Whyte, Jeffrey H. CPT USA SJASubject: Re: US v. PFC Bradley Manning (UNCLASSIFIED)Attachments:I did send it last week, but see now that I typed your name in incorrectly.again.. Please confirm that you have received it.ThanksGeneral CounselNational Archives and Records Administration8661-Adelphi Road, Suite 3116College Park, MD 26746-6661Wikileaks Damage Assessment DocumentHere it isSorry For the error.02980838From= ?@usdoJ.gov1Sent: Monday, April 09, 2012 12:29 PMTo: Wh Jeffre H. CPT SJAcc: ?tusms); (USMS)Subject: WikiLeaks Disclosure Assessment LetterAttachments: wiki leaks |tr.pdfCaptain white,Attached is the USMS letter in response to the request for an assessment of damage to theUSMS. This letter is shared with the prosecution for law enforcement purposes. It isrequested that you consult with me or someone from our office prior to any further disclosureof the document.Thank you,Associate General CounselUnited States Marshals Service2694 Jefferson Davis HighwayAlexandria, VA 22361Tele:Fax:02562206 215) <2z>m-airminv?Sent: Tuesday, April 10. 2012 AMTo: Fein, Ashden USA gm Subject: lfpdate Classi?cation: UNCLASSIFIEDCmcals: NONESec comments bclou Of?cc of the Jud Advocate of the Amy. Pentagon 3DS-18NPR. 11 mailmilSIPR: . -S .smil milTcl: ULDOU I 30From: DISA GC _@disa.miI] on behalf of?C|Vozsn GCSent: Tuesday, April 10, 2012 3:04 PMTo: Fein, Ashden MAJ USA SJACc: CIV PEO-MAsubject: RE: DISA Chief of Staff Memo asking that our data not be publicty posted (UNCLASSIFIED)hnponance: Classification: UNCLASSIFIEDCaveats: NONEDear MAJ Fine; 16 April 2612I was working on an email on SIPR, and my assigned thin client went black. Mr. and I.have reviewed the documents together, and have some comments to provide, but I may have towork them up on a different terminal latter this week.If any of the documents are proposed for public release, the photo of the former state dept.employee should be redacted, to protect his privacy. Since I understand he has retired fromfederal service, if information on him (which is not relevant to the events) could beredacted, that would be good.Also, please see OASD Memo, September 1, 2965, withholding of Information thatPersonally Identifies DOD Personnel (DSD 17746-B5) atwhich indicates personallyidentifying information may be inappropriate for inclusion in any medium available to thegeneral It goes on to state: . In general, release of information on personnel will be limited to the names, official titles, organizations, and telephone numbersfor personnel only at the office director level or above, provided a determination is madethat disclosure does not raise security or privacy concerns. No other information, includingroom numbers, will normally be released about these Given the high level of media interest in this case, and the propensity of criminal'hactivists' to attack anyone seen as 'anti~Manning' the indentifying information (to includenames, phone numbers, email addresses, locations etc.) on technical staff within mentioned in the documents should be redacted. None of the DISA personnel are at the directorlevel, and some are law enforcement or intelligence specialists.where the data is that of some element outside DISA, the organization that generated the datashould review the documents to determine classification level of that data.Sincereli,Deputy General Counsel, Regulatory International LawDefense Information stems Agency (Ft Meade, MD)Fax:_@disa.mi1 02979495 From: doc.gov]Sent: nes ay, pr: .2012 9:09 AMTo: Bradley, Princeton L. SGT USA SJASubject: documentsGood morning, Sergeant Bradley-I believe you spoke with Agent yesterday regarding documents we previouslyprovided to NCIX. I have the documents you requested available For release to you. Pleaseadvise when the most convenient time is For you to pick them up.Thank you-Intelligence AdvisorInvestigations and Intelligence Division0FFice oF SecurityU.S. Department of CommerceDes? mobumjsecure: doc. ov02979448From: Bradley, Princeton L. SGT USA SJASent: Wednesda April 11, 2012 9:CPT USA SJASubject: RE: documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONEGood morning, and thank you For your help coordinating the pickup of the documents. Ifpossible I would like to pick up the documents at 1460 today. -Please let me know where youwould like me to meet you as I am not familiar with the Department of Commerce building.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 .02564211 From: David Coombs Sent: Wednesday. April I l, 20l2 2:57 PMTo: Fein, Ashden USA SJA Overgaard, Angel M. PT A IFHQ-NCIVMDW SJAParra, Jairo A. JFHQ-NCFUMDWCc: Santiago, Melissa CW2 USARMY (US) Subject: DTS and FundingAngel,Can you provide me with an update on the Defense computer forensic funding request? My expert will need totravel next week in order to work on the case and prepare for his testimony during the Article 39(a) ThankyouBest,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Toll Free: l-800-588-4156Local: (508)689-4616Fax: (508) 6899282 Notice? This transmission, including attachments, may contain confidential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is prohibited.? ULUIUIWWFrom: Bradley, Princeton L. SGT USA SJASent: Wednesda April 11. 2012 3:33 PMTo: #@frb.govCc: hyte. Jeffrey H. CPT USA SJASubject: JWICS Address (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONESir,Good afternoon. As per our phone conversation, please see the JWICS addressfor our lead prosecutor, MAJ Ashden Fein below. Should you have any additional questions orconcerns please let me know.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32Classification: UNCLASSIFIEDCaveats: NONE 02564210From: David Coombs Sent: Wednesday, April I l, 2012 6:38 PMTo: Fein, Ashden USA SJA Overgaard, Angel M. CPT USA SJAWhyte, Jeffrey H. CPT Morrow Ill, JoDean, CPT USA IFHQ-Vonlilten, Alexander S. Parra. Jairo A. SJAUSA SJAW01 USA SJACc: "l?ooman, Joshua] CPT USARMY Santiago,Melissa CW2 USAKVIY (US) Subject: FundingAshden,Please provide me with an update regarding funding for the Defense computer forensic experts. My expert isplanning on traveling on the 17m to Fort Meade and staying until the Additionally, can you let me know when you intend to have PFC BM in the Fort Meade area?? I intend to comeearly, and if he is present, I would like for him to be brought to the Fort Meade TDS office.Best.DavidDavid E. Coombs, Esq.Law Office of David E. Coombsll South Angeli Street, #317Providence, RI 02906Toll Free: 1-800-588-4156Local" (508)689-4616Fax: (508) 689-9282oom rm i I ns .comNotice: This transmission, including attachments, may contain confidential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is 02564209 .From: David Coombs Sent: Wednesday, April 11,2012 7:51 PMTo: Fein, Ashden MAJ USA SJA Overgaard, Angel M. CPT USA SJ AWhyte, Jeffrey H. CPT USA Morrow Ill, JoDean, CPT USA .TFHQ-VonElten, Alexander S. 1LT1 Parra, Jairo A SJAUSA SJAW01 USA SJACc: 'Tooman, Joshua CPT USARMY Santiago,Melissa CW2 USARMY (US) Subject: TranscriptAshden,Can you provide me with an update on receiving the digital recordings?? I need these recordings for my replymotions. Will you be able to courier them to me before the end ofthe week??Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Street, #317Providence, RI 02906Toll Free. l-800-588-4156Local: (508) 689-4616Fax: (508) 689-9282comNotice: This transmission, including attachments, may contain con?dential attomey?clientinformation and is intended for the pcrson(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is prohibited.? 02933127From: Fein, Ashden MAJ USA SJASent: Wednesday, April 11, 2012 9:20 PMTo: David Coombs; Overgaard, Angel M. CPT USA Whyte, Jeffrey H.CPT USA Morrow JoDean, CPT USA VonE|ten, Alexander S. 1LT USA Parra, Jairo A. W01 USA JFHQ-SJACc: 'To0man, Joshua CPT USARMY Santiago, Melissa CW2 USARMY (US)Subject: RE: FundingDavid,we should have an answer on the additional Funding For your experts tomorrow, based on theplanned CG appointment. Mr. Parra is still confirming the issue with the overage and youshould have an answer From us on the overage by tomorrow.V/rAshden ULUISLI IFrom: Bradley, Princeton L. SGT USA SJASent: Thursda A ril 12, 2012 8:47 AMTo:Cc: ?lac, !e"rey H. CPT USA SJASubject: RE: US v. Manning Classification: UNCLASSIFIEDCaveats: FOUOGood morning, I hope you have been well. I just wanted to touch bases with you and askif the NCIX contacts were able to get you the information you needed. Please let me know ifthere is anything that I can do to help and have a great day!Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32I 02978068From: Bradley. Princeton L. SGT USA SJASan: Cc: e, rey .CPT USA Subject: RE: NCIX Documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good morning, I hope that you are well. Per the email traffic below, I am contactingyou with regard to receiving a copy of a document or series of documents your organizationmay have provided to the NCIX. If you require any additional information please Feel Free tocontact me and I will be happy to elaborate.Very Respectfully,Sergeant Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 02979593From: Bradley, Princeton L. SGT USA SJASent: Th ri 2. 2012 8:56 AMCc: yte, Je rey H. CPT USA SJA: Subject: RE: Request for General Counsel's Office Point of Contact (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONESir,Good morning, I hope that you are well. I am just emailing you to ask if you or anyoneelse in your office has had an opportunity to locate the response generated by your officewith regard to the NCIX "w#kileaks" document review. Please let me know if you need anyadditional information from our office and I will do my best to assist.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 u4auu1u9From: Bradley, Princeton L. SGT USA SJASent: Thursda A ril 12 2012 9:06 AMTo: Cc: Whyte_ Jeffrey H. CPT USA SJASubject: RE: Request to Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good morning, I hope you have been well since we last spoke. I am just emailing you to askif you or anyone else in your office has had an opportunity to locate the response generatedby your office with regard to the NCIX "wakileaks" document review. Please let me know ifyou need any additional information from our office and I will do my best to assist.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 102978118From: Bradley, Princeton L. SGT USA SJASent: Thursday. April 12, 2012 10:26 AM To:Cc: Whyte, Jeffrey H. CPT USA SJASubject: ATF NCIX Documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONESir,As per our phone conversation please see the SIPRNET email address for ourlead prosecutor MAJ Ashden Fein. Should you need any additional information please feel freeto contact me and I will be happy to assist.Very Respectfully,Sergeant Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32Classification: UNCLASSIFIEDCaveats: NONE02980171From:Sent:To:Cc:Subject:SGT Bradley,usaid.gov]Thursday, April 12, 2012 2:39 PMBradle Princeton L. SGT USA SJA;VVhwe.Jeffrey H. CPT USA SJARE: Request to Review NCIX Response Not a problem at all and thank you for the clarification. I also don't know of any officialresponse from the Agency. However, I believe our Office of Security should know if such aresponse was ever sent because I believe they were involved with the matter at that time.Please discuss it with_ when he gets back in the office on Monday.Reiards,02979195Sent: urs ay, pr: ,2012 2:42 PMTo: Bradley. Princeton L. SGT USA SJACc: Whyte, Jeffrey H. CPT USA SJASubject: RE: US v. Manning (UNCLASSIFIED)SGT Bradley,I've been well, and I hope you and your team have been too. I haven't heard anything FromNCIX, but I'll send a new email to them to try to get things rolling.Regards,Broadcasting Board of Governors UAHOD IDAFrom: Fein, Ashden MAJ USA SJASent: Thursday, April 12, 2012 6:31 PMTo: Cc: Kemkes, Matthew MAJ USARMY 'Bouchard, Paul CPT USARMY 'Tooman.Joshua CPT USARMY Santiago, Melissa CW2 USARMY Morrow Ill,JoDean, CPT USA Overgaard, Angel M. CPT USA Whyie, Jeffrey H. CPT USA VonElten, AlexanderS. 1LT USA JFHQ-NCRWIDW Ford, Arthur D. CW2 USA SJASumea: EmmnsAttachments: 120412- GCMCA Approval of Additional Funding of Defense Forensic Computer David,The GCMCA approved the defense funding request for an additional $76,699. Attached is theapproval.As for the amount remaining under prior approvals and the issue with unauthorized overages? Iwill send you an email early next week that outlines every issues that has been present andthe way forward. After reviewing our previous emails and the bills/accountings we havereceived from CyberAgents, there are too many inconsistencies between the emails andsubmissions to give you a clear answer. This will be resolved by wednesday.As for their travel-Although much of the computer systems processing outlined in your Renewal of Motion to CompelDiscovery might not take a long time as you have highlighted, what seems to be overlooked ishaving that volume of information reviewed by security experts and how much time that processwill take. Any information removed from a classified hard drive must be reviewed by securityexperts and will likely have to be submitted to 0CAs if classified information is found,including filenames. with that being said, we are still working with CCIU to determine howmuch information exists on the drives that will need to be reviewed by information securityprofessionals. Many of the drives are not operational or are wiped. I should have the exactnumber of the operational drives on Monday afternoon. we are positioned to schedule theirtravel and can do so Monday if you still want them to travel on Tuesday for this purpose. weoffer that we might be able to find a middle ground which won?t require this testimony ortravel and can discuss on Monday.v/rAshden02923623From: Fein, Ashden MAJ USA SJASent: Friday, April 13, 2012 9:51 AMTo: IRR USA USCENTCOM CCJA-SJASumem: Sir,Are you available For a quick chat this morning? Thanks. 02564202From: David Coombs Sent: Friday, April 13, 2012 557 PMTo: Fein, Ashden MAJ us?. SJA Overgaard, Angel M. CPT USA SJAMorrow JoDean, CPT USA WHO-Whyte, Jeffrey H. CPT USA11>; VonElten, Alexander S. SJASJAUSA SJACc: 'Tooman, Joshua CPT USARMY Su bj ect: DiscoveryI received the unclassi?ed discovery today. Also, the classi?ed discovery was received by NWC. havearranged to see the facility next week at the NWC.I have a couple of questions that I would like to have answers to:I) With regards to the unclassified damage assessments provided in discovery, when did the Governmentreceive these documents??2) Are there any more unclassified damages assessments in the Govemment?s possession?3) Do you have an update on the I4 hard drives?4) Who is the Govemment bringing from the Department of State for the motions hearing?? Can you providethis person?s contact information?5) Are you planning on providing me with your proposed If so, perhaps this is something we can agreeupon.6) Did you receive the emails from COL Lind regarding her email problems??7) have forwarded the documentation regarding badges for my family. Has Mr. Parra heard anything on thatissue?8) Has the DOS provided any further updates on my Touhy request?9) When does the Government plan to have PFC BM in the Fort Meade area?? Additionally, is the plan toreturn him to the JRCF immediately after the 39(a) is completed? The Defense?s preference would be to returnPFC BM to military control at the JRCF.Thank you for your attention to the above matters.Best,DavidDavid E. Coombs, Esq.Law Office of David E. CoombsSouth Angell Street, #317Providence, RI 02906Toll Free: l-800-588-4l56 UZ934955From: Fein, Ashden MAJ USA SJASent: Sunday, April 15, 2012 10:08 PM To: USAVAE Cc: Morrow m. JoDean, CPT USA Overgaard,Angel M. CPT USA Whyte, Jeffrey H. CPT USA VonE|ten, Alexander s. 1LT USA Ford, Arthur D. cw2 USASJASubject: FBI FileAll,Good evening. we have finally finished going through all the documents that we previouslymarked discoverable and that you reviewed for approval to release. There are 162 documentsremaining that no one (EDVA, FBI, or NFO) placed in the three buckets. Out of all thedocuments you either redacted or wholesale disapproved for release, we identified documents to discuss with you to figure out whether we may release only very specificportions.Is there a time this week for us to all meet for about 3 hours and finish this process? As astarting point- I propose Wednesday morning or afternoon. By lunch tomorrow, I should have the exact numbers of the documents for us to collectively gothrough. Once we finish this process and discuss the one outlier, this should complete ourreview of the main file, except anything new since we scanned the file.Thank you!v/rAshden02943156From: Fein, Ashden MAJ USA SJASent: Monda A ril 16, 2012 10:28 AMTo: ?ma USA USCENTCOM CCJA-SJASubject: chat todaySir,Are you available for a quick phone chat today? Thank you.Ashden02950705 From: Fein, Ashden MAJ USA SJASent: Monday, April 16, 2012 11:08 AM0:CC3 Monow1H,JoDean,CPTUSA Overgaard, Angel M. CPT USA Whyte,Jeffrey H. CPT USA VonElten, Alexander S. 1LT USA JFHQ-NCRSumed: RE-:Good morning. Could you please send me an update on the below areas. v/rAshdenFrom: Fein, Ashden MA3 USA SJASent: Thursda A ril 65 2612 8:67 AMTo:Cc: Morrow JoDean, CPTUSA Overgaard, Angel M. CPT USA whyte, Jeffrey H. CPT USAVonElten, Alexander S. 1LT USA SJASubject: RE:Thank you for the chat this morning. I am tracking only three issues from the order- 1. DIA's position on making the IRTF Final Report available to the defense counsel- eitherinvoking the classified information privilege on all/some of the information, making thereport available for inspection, or turning it over to the defense counsel in classifieddiscovery (there are other conceivable variations which we can discuss and we understand thisis subject to other equity holder's approval for their information which we are directly andcoordinatin 2. As part of our original Prudential Search Request, we identified that some IRTFinformation was missing. we returned the IRTF and are still owed the updated of all the IRTF material for us to review. Once we have all the PSR material based on ouroriginal broad request, we are confident that any information from this court's order orfuture requests/orders for potentially discoverable material would be found in our review ofthe PSR material. 02950705 Thank you!v/rAshden 02945638From: Fein, Ashden MAJ USA SJASent: Monda A ri|16 2012 11:13 AMTo:Subject: FW: Automatic reply:FYSA.Message~-~-?ii?ElSent: Monday, April 16, 2612 11:68 AMTo: Fein, Ashden USA SJASubject: Automatic reply:I am out of the office until Tuesday, 17 Apr 2912. From Friday?Monday, if you need to reachme in reiards to a legal matter, please email my home address a_or call meat02560659From= T@aoasas%min>Sent: Monday. April 16, 2OI2 llt|3 AMTo: Fein. MAJ USA DW SJA Subject: Automatic reply?I ould e-mail her at home. She has to have a backup. Defense Intelligence AgencyVvaslunizon DC 20341)02983543From: Whyle, Jeffrey H. CPT USA SJASent: Monda A ril 16, 2012 11:20 AMTo: Subject: US v. Manning (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONEGood morning-I am one of the prosecutors in the case of US v. Bradley Manning. Our office has been tryingto reach for the past few weeks without any luck. Could you please forwardthis email to or, at a minimum, give us a call as soon as possible? we are in themiddle of litigation and it is urgent that we speak with him. Thank you, Ma?am!v/r3. Hunter whyteCPT, JATrial CounselUnited States Army Military District of WashingtonClassification: UNCLASSIFIEDCaveats: NONE02983539From: Whyte, Jeffrey H. CPT USA SJASent: Monday, April 16, 2012 12:05 PMTo: ?@hhs.govSubject: US v. Manning (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONESir,Thank you for speaking with me earlier today. Here is my contact information for therequested material. Please let me know if your department requires anything additional fromour office or if you have any further questions about what we are requesting.v/r3. Hunter whyteCPT, JATrial CounselUnited States Army Military District of WashingtonClassification: UNCLASSIFIEDCaveats: NONE02931910From: Fein, Ashden MAJ USA SJASent: Monday. April 16, 2012 3:53 PMTo: David Coombs- vergaar, ngel .C Jeffrey H. CPT USA VonE|ten, Alexander S. 1LT USA JFHQ-NCRFord, Arthur D. CW2 USA SJASubject: Hard Drives (EnCase Forensic Images)Importance: HighDavid,After consultation with the government forensic experts, it appears that out of the 14 harddrives that were identified to be present in the TOC or SCIF, 2 drives are completelyinoperable, 7 drives are wiped, 4 drives have file structures present, and 1 drive ispartially wiped. In total, only 5 drives have any information that could answer your requestand ultimately the Court's order, dated 23 March 2012.Based on this information and in an effort to continue producing as much information indiscovery as possible, regardless of classification, the United States is willing to produceforensic copies of the 5 drives to the defense, but only after receiving authorization fromrelevant OCAs, if classified information is identified on the drives. In order to make thishappen, we will have our forensic experts continue their examination and then pass theinformation to the security experts to start a review. Our goal is to have the drivesexamined and approved for release by 18 May 2012, the Court's deadline for the other mattersin the defense motion to compel.The United States does not acknowledge any of the defense's arguments or statedinterpretation of the relevant authorities. The United States maintains that a completesearch of these drives is not material to the preparation of the defense, regardless of theirclassification. Additionally, the United States has never maintained that the forensiccomputer exams will take an extended period, but rather it would takes weeks for the securityexperts to review the 14 hard drives for classified information and the prosecution to obtainneeded approvals. Now knowing that only five drives are at issue (the fifth being partiallywiped), this process should not be too onerous for our security experts and they should beable to complete everything, including obtaining approvals, if any, within the next 39 days.Please let us know whether this is acceptable and we will notify the Court. Additionally,please let us know whether you still require your forensic experts to travel this week ornext week for the motions hearing.v/rAshden02979663 From: Bradley, Princeton L. SGT USA SJASent: Monda ril 16, 2012 4:24 PMTo: dotgovCc: Whyte. Jeffrey H. CPT USA JFHQ-SJASubject: RE: Request to Review NCIX Documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Good afternoon. As per our phone conversation, if at all possible we would like to pickup the documents on 18 April, 1636 hours. If this is not Feasible please let me know and wewill adjust. Thank you again for your help and have a great day.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 102564182From: David Coombs Sent: Monday. April 16, 2012 5:02 PMTo: Fein. Ashden MAJ USA SJA CC . Morrow J0DeanrCPT USA 5lA?>1 Overgaard.Angel CPT USA SJAWhyte, Jeffrey H. USA SJA \/onElten. Alexander S. 1LT USA JFHQ-A Ford? Arthur W2 USAreSubject: RE. Hard Drives (EnCase Forensic Images)Ashden.I guess don't understand vvliztt _\Oll are saying. lfyou are doing thesearches for uniiuthonxed per the Court's order. you should havethe results NLT 20 April. lf_vou are also doing 2! Search utilizing theuietliod the Defense expens suggested. _vou should have those results NLT 20April. 50 ould like the results ofeitlier search on or before 20 April.At that point. we can discuss hether you would also provide an EnCase cop)?to the DefenseAlso. can't you respond to an) of the Defense's questions until Fridzrv?I uould lilte to lime the uiisuers to the questions sooner nuher than later.especially respect to the follovving:I) With regards to the unclassi?ed damage assessments provided indiscover}. hen did the (iovenunent these documents??2) Are there an) more damages assessments in the Goveninient?spossession??3) Who IS the Govenuneiit bringing from the Departnient of State for themotions lienritig" Can you provide this person's Contact uiform;itiori"Best.DavidDavid E. Coombs. Esq.um Off ice of David Coombsll South Angell Street- #317Providence. RI Toll Free: I -8t)0-588-4156Local? (508) 689-8616Fax: (508) coo aniivcoun mun ialdefcnsecoin??Confidenti2ilit_v Notice: This including attachineiits. ui:i_vconlideritizil attonie} -client infoniiation and is intended for theperson(s) or nzmied lf_\on are not the intended recipient. pleasenotify the sender and delete all copies. Uiizititlionxed disclosure. copvingor use oftliis information be ful and is 02931901From: Fein. Ashden MAJ USA SJASent: Monday, April 16, 2012 5:31 PMTo: David Coombs- vergaard, ngel M. CPT USA Whyte.Jeffrey H. CPT USA VonEIten, Alexander S. 1LT USA JFHQ-NCRFord, Arthur D. CW2 USA SJASubject: RE: Hard Drives (Encase Forensic Images)David,As for the forensic drives, CID will continue examining the drives as per the Court's orderand we will provide the results by 20 April 2612. However, in an effort to save time andresources for all parties involved (defense, government computer experts, governmentclassification experts), we can produce the forensic images of the drives, as per thedefense's original request. The defense will be able to conduct any analysis/procedure itwishes with complete copies of the drives.we can wait until after 20 April 2012, however it will take more time after that to get thosedrives fully reviewed for security classification purposes, than merely the filenames. Ifthe defense ultimately wants the forensic images and access to the files (as per the originalmotion and the renewed motion) sooner than later, the United States recommends the defensesupport this way forward, so we can divert CID resources from continuing to search for theseprograms and having to dedicate security experts to the review of the lists, and just haveall of them focus on the actual files. we are confident we will be able to have themreviewed and approved, absent some unusual issue, by 18 May 2812.Following this email, I will send you responses to your questions from Friday. My previousemail was intended to simply explain that I will provide you answers by COB today, for yourquestions you asked on Friday.v/rAshden . 02936523From: Fein, Ashden MAJ USA SJASent: Jlonday, April 16, 2012 5:48 PMTo: David Coombs; Overgaard, Angel M. CPT USA Morrow Ill. JoDean,CPT USA JFHQ-NCRIMDW Whyte, Jeffrey H. CPT USA VonEIten, Alexander S. 1LT USA JFH -Cc: 'Tooman, Joshua CPT USARMY (USSubject: RE: DiscovewDavid,Below are our responses to the applicable questions. The others should be OBE or subject toother emails today.1) The prosecution has been working with many government agencies pursuant to our obligationto search for discoverable information under williams. As we identify discoverableinformation, we seek approvals to release the information. Over the past few weeks, wereviewed these particular assessments; identified discoverable information contained within,obtained approvals to release them, and produced them to the defense as soon as possible.2) The prosecution continues to review additional unclassified assessment(s), and willdiligently work to obtain approvals to turn the discoverable portions, if any, over indiscovery.4) The United States will notify you of the individual, once we receive the information. weexpect this decision in the next few days. Additionally, we will work to provide you contactinformation for the individual and/or setup a time prior to the motions hearing for you tointerview the individual.5) I am confident we can work on this as we move forwardposition tosend any as of yet. we will address this issue after the next motions hearing.7) I will check with Mr. Parra about this issue.8) The Department of State is processing your Touhy request and we were told that they mighthave an answer by the end of this week.9) Please see your previous email at the very bottom.A) Defense expert witnesses. we should be able to give you a comprehensive answer on thestatus of funding for your experts and their contract issues by Wednesday, as per my emaillast week. Once CW2 Parra returns this is his priority. They are currently funded for theirtravel tomorrow. SGT Feito is making their reservations and has been trying to contact them.8) OCA POCS.1. Rear Admiral David woods (CDR Thomas welsh, SJA, JTF-GTMO,2. LT Gen Schmidle (LTC Lisa Gumbs, OSJA, CYBERCOM at 1 3. Vice Admiral RobertHarward (should obtain tomorrow) 4. Rear Admiral Donegan (should obtain tomorrow)v/rAshden02584171From: David oombs Sent: Monday, April I6. 20l 2 6:42 PMTo: Fein. Ashden MAJ USA SJA Subject: DiscoveryAshden.With regards to lam not when the Goxenunent received theseassessments. I understand from your email that you reviewed the assessmentoverthe past few necks. but hon long lune you had these assessments??Additionally. some of these assessments are intenin assessments Do youhave am folloxx up assessments??Best.idDil\'ld E. Coombs. EsqLaw Ofl? ICC of David E. oombsll South Angel] Street. #317Providence. RI 02906Toll tee: Local? (508) 6894616Fax; (508) 689-9282Coombs (Ianii_\ counmartialdefensecoin.ann_\ coumuanialdefensecomNotice: This transniission including attacliments. maycontain con?dential infonnation and is intended for theperson(s) or compan} named. If you are not the intended recipient. pleasenotify the sender and delete all copies. disclosure. copyingor use of this inl'onnauon may be unlau ml and is pmhibiIed.""' 02936517From: Fem, Ashden MAJ USA SJASent: Tuesday, April 17, 2012 9:47 AMTo: David CoombsCc: Bouchard, Paul CPT USARMY Morrow Ill, JoDean,CPT USA Overgaard. Angel M. CPT USA Whyte, Jeffrey H. CPT USA VonEIten, Alexander S..1LT USAFord, Arthur D. CW2 USA SJASubject: RE: DiscoveryDavid,Since prior to referral, we have been coordinating with different federal organizations whichwe have reason to believe prepared an assessment, as a result of our continuing Williamsand/or ethical obligations. Those organizations began providing us with these assessments asearly as a few weeks ago and as recent as a few days ago. we adopted an efficient method ofreceiving, reviewing, and, if necessary, obtaining approval for the disclosure of theassessments, so that we can produce the discoverable portions, if any, to the defense as soonas possible. These assessments are the most current.The prosecution will continue to produce as much information as authorized to mirror open-file discovery, but only pursuant to the authority we receive, based on balancing disclosurewith protecting national security.v/rAshden02564158 From: David Coombs Sent: Tuesday, April 17. 20l2 l2:l 1 PMTo: l-?ein, Ashden MAJ SJA Cc: Morrow Ill, JoDean, CPT USA SJA Overuaard. Angel M. PT USA JFHQ-SJ Whvte, Jeffrey H. CPT USASJA VonElten, Alexander LT USA SJA Ford.Arthur USA SJA"looman. Joshua] CPT USARMY Subject: RE. DiscoveryAshden.These assessments are dated November 2010. Are you say ing that you JUSI gotthese ti ten weeks ago?? You stated in response to the Defense Motion toCompel that you had requested these items in May of2tll I Why areyou them 10 later??please ensurie that you do not send emails to CPT Bouchard or MAJKentkes. Your 1151 email had listed Bouelmd instead of CPT 'I'oom;in_Best.Dtix idDIl\'ld E. Esq.Law OfTice of Dmid E. Coombsll South Angell Street. Rl H2906Toll Free. l-800-588-4 156Local: (508)689-4016Fax: (508) 689-9282conicourttiizirtizildefeiiseconiNotice: This including attrichnieiits. ma)contain con?dential infomiation and is intended fortliepersontsl or named. lf)?Oll are not the intended recipient. pleasemtify the sender and delete all copies Uniiuthomed disclosure. copying,or use of this infoririation be unlawful and is prohibitcd.?? 02837919From: Fein, Ashden MAJ USA SJASent: Tuesday, April 17, 2012 5:54 PMTo: Lind. Denise COL USARMY (US)Cc: Ford. Arthur D. CW2 USA Tooman. Joshua CPT USARMY Santiago, Melissa CW2 USARMY MorrowJoDean, CPT USA JFHQ-NCRIMDW Overgaard, Angel M. CPT USA JFHQ-NCRIMDW Whyte. Jeffrey H. CPT USA VonElten. AlexanderS. 1LT USA ?VllL USA CIV SJASubject: RE: US v. PFC BM Ruling on Gov'l Request - Leave to Respond; Article 39(a); and tnalcalendar (UNCLASSIFIED)Ma'am,1. The majority of counsel have been at the Department of State this afternoon, therefore weare just starting to respond to emails.2. Department of State witness. Based on input and direction from the Department of State,the Department will make their draft assessment available pursuant to the Court's order. TheUnited States believes this makes the need for a witness moot.3. Forensic Computer expert witness. As per the email chain below, the United Statesnotified the defense that we have offered to make forensic images of the operable drivesavailable to the defense by 18 May 2812 in an effort to save time and resources for allparties involved (defense, government computer experts, government classification experts,and the Court). After CID's initial review in preparation for the 26 April 2812 deadline,they determined that only 5 of 14 drives are operable, therefore significantly reducing thetime required for security experts to conduct a review for classified information. However,based on the defense's email and pursuant to the Court?s order, the United States willcontinue to produce the list of programs by 26 April 2612. If the defense still requestsforensic copies of the drives or access to the files, then we will voluntarily comply;however that will take additional time. The United States believes this satisfies any issueswhich were discussed during the RCM 862 telephonic conference and ultimately in the defense'smotions, including the need to re-litigate this issue and have forensic experts present.4. Case Calendar. The prosecution realized that it has not provided any justification tothe Court on why the United States recommends bifurcating unclassified and classifiedevidentiary issues. If it may please the Court, the United States can file by Friday a briefexplanation with estimates of the volume of evidence the United States intends to introduce,unclassified and classified, during pretrial motions and the estimate of the total number ofwitnesses that will be required based on the charged offenses.V/rMAJ Fein02936509From:SentTo:Cc:Fein, Ashden MAJ USA SJAWednesday, April 18,2012 9:17 AMDawdcoombsMorrow Ill. JoDean, CPT USA Overgaard, Angel M. CPT USA Whyte. Jeffrey H. CPT USA JFHQ-VonEIten, Alexander S. 1LT USA Ford, Adhur D.CW2 USA 'Tooman. Joshua CPT USARMY Subject:David,RE: DiscoverySince May 2011, the United States has requested that all entities whose files it is requiredto search under Williamsand the evidence in thisOur continuing search ofdiscoverable informationThe prosecution and, if discoverable, todisclosed to the defenseto segregate and preserve any records related to the accused, NL,case. An example of this request has been provided in our filings.these records provided us with a good faith basis that potentiallymay exist within the files of more than fifty additional agencies.began coordinating with these agencies to review these materialsobtain approval to disclose in discovery. The assessments welast week are the unclassified discoverable materials we reviewedfrom these additional agencies.The United States continues receiving, reviewing, and, if necessary, obtaining approvals forthe disclosure of the assessments, both classified and unclassified, to the defense.v/rAshden -UZ9 I 9450From: Bradley, Princeton L. SGT USA SJASent: Wednesday, April 18, 2012 12:50 PMTo: doogovSubject: e: documents (UNCLASSIFIED)I Good afternoon! I hope that you have been well since we last spoke. I am emailing you to askif you still needed the NCIX point of contact to have the signed copy of your documentreleased to us. Thank you for your help thus Far and please contact us should you need anyother information.Very Respectfully,Sergeant Princeton BradleyParalegal Noncommissioned OfficerMilitary Justice, MDW OSJA02981242 Front soLdoLgov]Sent: Wednesday, Am?! 18, 2012 2:44 PMTo: - DW SJACc:Subject: RE: US v. Manning (UNCLASSIFIED)Cpt. whyte,we are happy to accommodate your request and provide our Damage Assessment. For our records,we ask that you provide, on letterhead, a written request stating what you require andexplaining whether it will be protected under court order, seal or equivalent.You may provide the letter via email. Please send it to myself and to the two addressescc'ed above.Thanks,Branch of General Legal Services uzsrsouoFrom: Bradley, Princeton L. SGT USA SJASent: Thursda A ril 19. 2012 9:14 AMTo:Cc: Whyte, Jeffrey H. CPT USA SJASubject: RE: US v. Manning (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOU0Good morning! I hope that you have been well since we last spoke. I am emailing you torequest a JWICS or SIPRNET email account for your Office of General Counsel, to which theprosecuting attorneys may send a written request regarding your organization's NCIXresponsive information. Should your Office of General Counsel not have JWICS or SIPRNETaccess, please notify the prosecution of an acceptable alternate, should one exist. If yourorganization does not have access to JWICS or SIPRNET systems at all, please let me know andwe will produce our request in a format that is not classified. Thank you for your continuedsupport of the prosecution. If you should require any additional information, please feelfree to contact me and I will be happy to help.Very Respectfully,Sergeant Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 1 02979394From: Bradley, Princeton L. SGT USA SJASent: 19 2012 9:23 AMTo:Cc: Whyie. Jeffrey H. CPT USA Subject: RE: Delivery of Documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOU0Good morning, I hope that you are well. I am emailing you to request a JNICS orSIPRNET email account for your Office of General Counsel, to which the prosecuting attorneysmay send a written request regarding your department?s NCIX responsive information. Shouldyour Office of General Counsel not have JWICS or SIPRNET access, please notify theprosecution of an acceptable alternate, should one exist. If your organization does not haveaccess to JNICS or SIPRNET systems at all, please let me know and we will produce our requestin a format that is not classified. Thank you for your continued support of the prosecution.If you should require any additional information, please feel free to contact me and I willbe happy to help.Very Respectfully,Sergeant Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 02979467From: Bradley, Princeton L. SGT USA JFHQ-NCRIMDW SJASent: Thursday, April 19, 2012 9:28 AMTo:Subject: RE: documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONESounds good. Also, (just a heads up) I am about to send out an email requesting aSIPRNET or JWICS email address to forward a request from our prosecuting attorneys to yourOGC. I just wanted to give you a heads up because although the request is regarding thedocuments I picked up, it is not a request to receive a signed copy of the documents since wealready discussed that issue.SGT BradleyI U43 I 5900From: Bradley, Princeton L. SGT USA SJA Sent: il 19, 2012 9:30 AMTo:Cc: hyte, Jeffrey H. CPT USA SJASubject: RE: documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONEGood morning, I hope that you are well. I am emailing you to request a JNICS orSIPRNET email account for your Office of General Counsel, to which the prosecuting attorneysmay send a written request regarding your department?s NCIX responsive information. Shouldyour Office of General Counsel not have JNICS or SIPRNET access, please notify theprosecution of an acceptable alternate, should one exist. If your organization does not haveaccess to or SIPRNET systems at all, please let me know and we will produce our requestin a format that is not classified. Thank you for your continued support of the prosecution.If you should require any additional information, please feel free to contact me and I willbe happy to help.Very Respectfully,Sergeant Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 02980231From: Bradley, Princeton L. SGT USA SJASent: Thursday. April 19. 2012 9:36 AMje?aagovCc: Whyle. Jeffrey H. CPT USA SJASubject: Request for Email Address (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONESir,Good morning, I hope that you have been well since we last spoke. I amemailing you to request a JWICS or SIPRNET email account For your Office of General Counsel,to which the prosecuting attorneys may send a written request regarding your organization?sNCIX responsive information. Should your Office of General Counsel not have JNICS or SIPRNETaccess, please notify the prosecution of an acceptable alternate, should one exist. IF yourorganization does not have access to JNICS or SIPRNET systems at all, please let me know andwe will produce our request in a Format that is not classified. Thank you For your continuedsupport of the prosecution. you should require any additional information, please Feelfree to contact me and I will be happy to help.Very Respectfully,Sergeant Princeton BradleyParalegal Non?Commissioned OfficerMilitary Justice, OSJAFort McNair, 32Classification: UNCLASSIFIEDCaveats: NONETracking:02979980From: Bradley, Princeton L. SGT USA SJASent: Thursda A 19,2012 9:43 AMTo: ondcp.eop.govCc: Whyte. rey . CPT USA SJASubject: Email Address Request (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONESir,Good morning, I hope that you have been well since we last spoke. I amemailing you to request a JWICS or SIPRNET email account for your Office of General Counsel,to which the prosecuting attorneys may send a written request regarding your organization?sNCIX responsive information. Should your Office of General Counsel not have JNICS or SIPRNETaccess, please notify the prosecution of an acceptable alternate, should one exist. If yourorganization does not have access to JNICS or SIPRNET systems at all, please let me know andwe will produce our request in a format that is not classified. Thank you for your continuedsupport of the prosecution. If you should require any additional information, please feelfree to contact me and I will be happy to help.Very Respectfully,Sergeant Princeton BradleyParalegal Non-Commissioned officerMilitary Justice, OSJAFort McNair, 32 Classification: UNCLASSIFIEDCaveats: NONE02980013From: Bradley, Princeton L. SGT USA SJASem: Thursday, April 19, 2012 9:USA Subject: Email Address Request (UNCIJXSSIFIED)Classification: UNCLASSIFIEDCaveats: NONESir,Good morning, I hope that you have been well since we last spoke. I am emailing you torequest a JNICS or SIPRNET email account for your Office of General Counsel, to which theprosecuting attorneys may send a written request regarding your organization's NCIXresponsive in?ormation. Should your Office of General Counsel not have JHICS or SIPRNETaccess, please noti?y the prosecution of an acceptable alternate, should one exist. yourorganization does not have access to JNICS or SIPRNET systems at all, please let me know andwe will produce our request in a Format that is not classified. Thank you for your continuedsupport of the prosecution. If you should require any additional information, please feelFree to contact me and I will be happy to help.Very Respectfully,Sergeant Princeton BradleyParalegal Non-Commissioned 0FFicerMilitary Justice, OSJAFort McNair, 32Classification: UNCLASSIFIEDCaveats: NONE Ford, Arthur D. CW2 USA SJA From: . Sent: Thursday, April 19, 2012 10:44 AMCc: Fein, Ashden MAJ USA SJA Subject: Case File (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONEWe would like to get an updated copy of your file. Please let me know when would be convenient for you. We wouldlike to Scan it the same way we did with the main file. Thanks very much.ArtieArthur FordCW2, JALegal AdministratorClassi?cation: UNCLASSIFIEDCaveats: NONE 02565405From: NAVWARCOL -@usnwc.edu] on behalf ofSent: Thursday, April 19, 201211:14 AMTo: Fein, Ashden MAJ USA Parra, Jairo A. CW2 USA Cc: USA NAVWARCOLSubject: Support for US v. PFC ManningAshden,FYI Mr. David Coombs "came on?board" today April 19, 2312. He's beenbriefed, materials were issued, and he's all settled in his workspace.V/r?Classified Material Control OfficerNATO Sub?registry Control OfficerSIPR address: Eilnwc . navy. smil . milNaval war Colle DSN:Comm:E?mail: HUMAN THREAT TO NATIONAL SECURITY:Did Not Know the Rules Did Not Understand the Rules Did Not Follow theRules"FOR OFFICIAL USE ONLY PRIVACY SENSITIVE This electronic transmission>may contain confidential information intended only for the person(s)>named above. Any misuse or unauthorized disclosure may result in both>civil and criminal penalties. If you receive this transmission in>error, please notify the sender at the telephone number or e?mail>addressabove.From: David oombs Sent: Thursday, April I9, 2012 1:47 PMTo: Fcin, Ashden MAJ USA SJA Overgaard, Angel M. CPT USA Morrow JoDean, CPT USA JFHQ-Whyte, Jeffrey H. CPT USAVonF.|ten, Alexander S.1-?ord. JAUSA Arthur D. CW2 USA SJACc: 'Tooman, Joshua CPT USARMY Santiago.Melissa 8 CW2 USARMY (US)Subject: IssuesAshden,Please provide answers to the following questions:I) Hard Copies: I would like to have hard copies of the charged documents for the 793(e) offenses delivered tothe You had previously indicated that this would not be a problem. Is this something that you couldaccomplish before the end of next week??2) FBI: I have looked through the majority of the FBI documentation and have some concerns regarding theredactions. Many of the documents are incomprehensible due to the scope of the redactions. Can you tell mewho redacted these documents, and what was the standard used for determining what should be redacted?Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs1 South Angeli Street, #3 I7Providence, RI 02906Toll Free: I -800-588-4156Local: (508) 689-4616Fax: (508)689-9282Notice: This transmission, including attachments, may contain confidential attomey-clientinformation and is intended for the person(s) or company named. Ifyou are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is prohibited 02554442From:Sent:To:Cc:Subject:Ford, Arthur D. CW2 USA SJAThursda A ril I9, 2012 6122 PMj@ic.fbi.gov>; Fein, Ashden USA SJA RE: Case File (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONEThanks- We are out all next week at the hearing anyways. Maybe we can set something up for the week after?? Just tell uswhen you can do it and we will make ourselves available. Thanks very much.ArtieAnhur FordCW2. ALegal AdministratorFrom?Sent: 'Thursday. April 19. 2012 4:49 PM mailtoTo? Ford. Arthur D. CW2 USA SJACc:?Subject: RE: Case File (UNCLASSIFIED)Anie. we can get this to you but I am out tomorrow and all next week. -or-can probably help next week. one of them willreach out to you to arrange.From: Ford, Arthur D. USA SJA ISent: Thursdav. A :11 2012 10:44 AMTo:Cc: Fein. Ashden MAJ USA SJASubject? Case File (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats. NONE02554442We would like to get an updated copy of your ?le. Please let me know when would be convenient for you. We would like to Scan itthe same way we did with the main ?le. Thanks very much.AtticAnhur FondCW2, JALegal AdministratorClassi?cation: UNCLASSIFIEDCaveats: NONEClassi?cation UNCLASSIFIEDCaveats: NONE02564128 From: David Coombs Sent: Friday, April 20, 20l2 ll.-45 AMTo: Fein. Ashden MAJ USA JFHQ-NCIUMDW SJA 'Tooman, Joshua CPT USARMY Cc: Morrow JoDean. USA Dvergaard. Angel CPT USA JFHQ-55/\ Whyte. Jeffrey H. CPT USASJA V0nF.lten, Alexander ll.T USA SJA Ford,Arthur D. USA Subject: RE Forensic Experts OverageAshden.detail the Goxemment has done to resolve this ISSUC ith(?an you also provide me ?Ill! 3 point that you lnvebeen working with :u to lCS0l\? this issue?? lf this issuecannot be it will be raised ith COL Lind git en the fact that itwill impact PFC Manning's right to obtain expert assistance.Best.Dm? ld E. Coombs. Latt of Dil\ id E. CoombsI South Angeli Street. M17Providence. RI 02906l'o|l Freer l-Xtxl-Sttx-4150Local (508) Fax: (508) coombs comNotice. This including ma}eont;tin coii?deittiul Z!ll0fllC_\ -client iuforinatioii and is intended for thepctsontsl or cotnpan_\ uzuued. If) on are not the intended recipient. pleasenolif} the sender and delete all copies. Unauthorized disclosure. copying.or use of this be and is I 40From:Sent:To:Cc:Subject:David Coombs Fn'da_v. April 20, 20l2 l3:3-1 PMFein. Ashden MAJ USA SJA 'Tooman, Joshua CPT USARMY Morrow Ill, JoDean. CPT USA Overgaard. Angel USA JFHQ-Jeffrey H. CPT USA Arthur D. USA RE. Forensic Experts Overage VonF.lIen, Alexander S.ll.T USA JA Ford,A Plcasc ptovidc .1 copy of current contract based upon llic approvedfunding request Tlinnk }ouBest.Dan idDax Id Coombs. EsqOffice of D1l\'ld E. Coonibsll #3 I 7Rl Toll Free: Local. (508) RU: (508) 689-9282coombsn coun Notice: This including ziluichnicms. ma)contain confidcnlizil auomc) -client infonnalion and is intended forihcpcrson(s) or coInpnn_\ named If you am no! the intended recipient. pleasenotify the sender and delete all copies. Unaulliorizcd disclosure. copyingor use of this may be unlamful and is isULOJVVU IFrom: Fein, Ashden MAJ USA SJASent: Friday. April 20, 2012 6:44 PMTo: ?David Coombs'; 'Tooman, Joshua CPT USARMY Cc: Morrow JoDean. CPT USA vergaar Angel M. CPT USA Whyte. Jeffrey H. CPT USA JFHQ-VonEIten. Alexander S. 1LT USA Ford, Anhur D.CW2 USA SJASubject: RE: Forensic Experts OverageDavid,Please discuss this with CPT Bouchard as the previous military defense counsel responsiblefor the defense contractor, including managing their services and ensuring they had theauthority to work. Mr. Parra explained this to him and Eric Lakes when the issue first cameup? that they need to contact contracting to resolve the overage issue.As for PFC Manning's continued right to expert assistance, there should be no issue. Yousubmitted a request for additional funding, and it was approved. Based on the approvals andcurrent contracts in place, the defense currently has $77,090 available for expertassistance. It is imperative that CPT Tooman (now) tracks the expenditures and ensures thedefense experts do not spend more than the United States authorized.v/rAshden02933384From: Fein, Ashden MAJ USA SJASent: Friday. April 20, 2012 6:48 PMTo: David Coombs; 'Tooman. Joshua CPT USARMY Cc: Morrow Ill, JoDean. CPT USA SJA:vergaar nge . Whyte. Jeffrey H. CPT USA JFHQ-VonEIten, Alexander S. 1LT USA Ford. Arthur D.CW2 USA SJASubject: RE: Forensic Expens OverageDavid,In my email yesterday, I sent the most recent copy, but it does not have the modification.Once we receive a copy, I can send you one. Additionally, the defense experts should alsohave copies.v/rAshdenULJU9 ILOFrom: David Coombs Sent: Friday, April 20, 6:49 PMTo: Fein. Ashden MAJ USA JFHQ-NCRIMDW SJA 'Tooman, Joshua CPT USARMY Cc: orrow JoDean, PT USA SJA Overgaard, Angel M. CPT USA JFHQ-SJA Whyte. Jeffrey H. cm USASJ A VonElten, Alexander ILT USA I SJA Ford,Arthur D. CW2 USA SJASubject: RE. Forensic Experts OveragcAgin. please provide me with a summary of what the Government has done toresolve this issue. Also. please provide me with a point of contact thatyou have been working mm in com racting. This will not be an issue thatthe Defense is ?gltting Vs itli Govemtucut contracts to resolve. This issuemust be resolved in the short tenn or it will impact on PFC Manning's tightto expert Best.DavidDavid E. Coombs. Esq.Lmi Oflicc ofDuvtd E. Coombsll South Angeli Street. #317Providence. RI 02906Toll Free: Local (508) 6894616Fax: (503) 689-9282?Con?dentiality Notice: This transmission. including tuzrycontain con?dential attomey-client infonnation and is intended for theperson(s) or company named. if you are not the intended recipient. pleasenotify the sender and delete all copies. Unauthorized disclosure. copyingor use of this information mzty be unlrm ml and is pmltibitcd."'o2564i22From: David Coombs Sent: Saturday, April 21, 2012 11.09 AMTo: Fein, Ashden USA SJAOvergaard, Angel M. CPT USA SJAMorrow JoDean_ CPT USA Jl?llQ-Whyte, Jeffrey H. CPT USAVonF.lten, Alexander S.. Ford. John Cc: "fooman, Joshua CPT USARMY Melissa CW2 USARMY (US)Santiago,Subject: ComputersAshden,Please start the process of providing EnCase copies of the relevant hard drives to the Defense Additionally, ourexperts did not receive a copy of the latest contract.Best,DavidDavid E. Coombs. Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Toll Free: 1-800-588-4156Local: (508)689-4616annycourtmartialdefense.con_1Notice: This transmission, including attachments, may contain confidential attomey-clientinformation and is intended for the person(s) or company named. lfyou are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use ofthis information may beunlawful and is ULDWIILIFrom: Fein, Ashden MAJ USA SJASent: Saturday, April 21, 2012 5:39 PMTo: David Coombs; Overgaard, Angel M. CPT USA Morrow JoDean.CPT USA Whyte, Jeffrey H. CPT USA VonE|ten_ Alexander S. 1LT USA Ford, Arthur D. CW2 USA JFHQ-SJACc: ?Tooman. Joshua CPT USARMY Santiago. Melissa 8 CW2 USARMY (US):1Subject: RE: ComputersDavid,we will start working on obtaining approvals to turn the drives over. Additionally, we willensure that the modified contract is sent out to the deFense expert and CPT Tooman as thegovernment representative.v/rAshden02564121 From: David Coombs Sent: Saturday, April 21, 2012 6:35 PMTo: Fein, Ashden MAJ USA A Overgaard, Angel M. PT SA SJAMorrow JoDean, CPT USA JFHQ-Whyte, Jeffrey H. CPT USAVonElten. Alexander S.Ford, John SJASJAUSA SJACIV (US) -Cc: 'Tooman, Joshua] USARMY Santiago,Melissa CW2 Subject: Outstanding IssuesAshden,Please respond to the following issues before the end of Monday:1) Who redacted the discovery and under what standard?2) What has the Government done to address the contract overage issue since January? Who in contracting hasthe Govemment being working with to resolve this issue?3) You had indicated that you would be providing additional Section disclosures to the Defense When willthese be provided? Also, why weren?t these part ofthe original Section disclosures?4) When does the Government intend to provide hard copies to me at the NWC ofthe 793 Charged documents?I intend to address each ofthe above issues during our next 802.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombsll South Angell Street, #317Providence, RI 02906Toll Free? l-800-588-4156Local: (503) 689-4616Fax: (508) 689-9282Notice: This transmission, including attachments, may contain confidential attorney-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this infomiation may beunlawful and is 02562190 @maiI.mi|] Sent: on ay, pn To: USA MIL USA OTJAGCc: USA Fein, AshdenMAJ USA Morrow Ill, JoDean, CPT USA SJASubject: Manning search (UNCLASSIFIED)hnponance: Classification: UNCLASSIFIEDCaveats: FOUOAs a follow on to our conversation of last Thursday, wehave identified hundreds of emails/documents that webelieve are responsive to the request. However that processcontinues with a number of individuals reviewing their holdingsto identify possibly responsive information.we have begun the process to transfer the information to disk.The process to download on to a disk is highly controlled witha number of steps involved. Main point being that this processto identify and prepare the information will take a number of daysto complete. Request the suspense date be moved until at leastthe 27th. (My understanding is that INSCOM is aware of the requestand has been working it for some time.)If you have any questions, please give me a call.Regards Classification: UNCLASSIFIEDCaveats: FOUO02562188 From: (US) ?@maii.rnil] on behalf of-SARMY (U S) Sent: Monday, April 23, 2012 12:39 PMTo: US MIL USA OTJAGCc: USA USA Fein, AshdenMAJ USA Morrow IH, JoDean, CPT USA JFHQ-NCRIMDW SJASubject: RE: Manning search (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUO- Just spoke with MDN. No issues with 27 April. V/r?Office OF The Judie Advocate General 02924286From: Fein, Ashden MAJ USA SJASent: Monday, April 23, 2012 7:30 PMTo: David CoombsCc: 'Tooman. Joshua CPT USARMY Santiago, Melissa CW2 USARMY Overgaard. Angel M. CPT USA Morrow Ill, JoDean, CPT USAWhyle, Jeffrey H. CPT USA VonEIten.Alexander S. 1LT USA SJA: Ford, John CIV (US)Subject: RE: Outstanding IssuesAttachments: 120423-Section Ill Disclosures.pdfDavid,1. For the FBI file, the United States provided the defense with, at a minimum, allinformation that we determined was discoverable under RCM 761(a)(6) and Brady. Redactedinformation falls outside RCM 761(a)(6) and Brady.2. As explained before, Mr. Parra spoke with Eric Lakes and CPT Bouchard about this beforethe arraignment. Specifically, Mr. Parra spoke with CPT Bouchard on the phone and explainedthat the military defense counsel, as the government supervisors of the contract must submita separate request to contracting because they are ultimately responsible for theunauthorized commitment of funds. Additionally, on 8 Feb 12, Mr. Parra spoke with Eric Lakesand CPT Bouchard on the phone and explained that in order to receive the payment for theunauthorized amount, both the military defense counsel and Eric Lakes had to deal directlywith the contracting officer who issued the contract. The information is printed on thecontract for the contractor and is Sherry L. Carner,At the end of last week, the contract modification did not occurbased on a funding issue; however today contracting is finalizing the modification. we willsend the updated contract, once we receive it, but Mr. Lakes will receive a copy before wedo. Still as of today, the defense has $35,660 for forensic expert consultation.3. The United States previously provided all the Section disclosures up to arraignment.Under our continuing Section obligation, the United States provides the attached updateddisclosures for information produced since arraignment.4. As per the Court's direction, the United States established a remote office in agovernment facility for you to work with classified information, including a printer. has a printer available with the standalone classified laptop. As per our arrangement withthe Nwc, that printer is to be used to print any classified material to minimize courieringof classified material. Along with the printer, is providing the toner or ink, and theprosecution is ready to send any additional supplies, if NNC requests. Please print thematerial at the government facility to minimize any possible security issues.5. OCA POC Contact Information. The last OCAs that you should need contact information forare at CENTCOM. Please contact COL Bruce Pagel, Acting SJA, CENTCOM atto coordinate any conversations or meetings. This should be theremaining POC contact information. Please let us know whether there are others that you needassistance with obtaining. The United States still has not received a Touhy request for theother Agency, if the defense still intends to submit one.6. Interim Forensic Reports. Today we delivered to CW2 Santiago a copy of the interimforensic reports (BATES: 00419805-00445563). we also a copy to (Tracking:798316692805).v/r 02924286Ashden02562185From: ?Us) on behalf m_(us)Sent: Tuesday, April 24, 2012 9:04 AMTo: Fein, Ashden MAJ USA Morrow Ill, JoDean, CPT USA cc= %usAonAe;jusAonAe-USA (US)Subject: Manning search request (UNCLASSIFIED)hnponance: Classification: UNCLASSIFIEDCaveats: FOUOAshden-I know you are rather busy this morning, but wanted to passalong some information. we have one disk ready that containsinformation from the NIPRNET (unclassified) system. we willhave at least one more (depending on volume) as we continue tosegregate and collect information.we will have at least one disk taken from the SIPRNET that willcontain information up to the Secret level.As I expected we will also have at least one disk that will be takenfrom the JWICS system. The actual information I believe is Top Secret,with a portion This data deals with the review of the lostinformation. when you have a moment please give me a call and we candetermine how to handle it.I expect to have most of the Unclassified and Secret information readyby Friday.RegardsClassification: UNCLASSIFIEDCaveats: FOUO02926960From:SentTo:Cc:Subject:-.Thank you!Fein, Ashden MAJ USA SJATuesda A ri|24 2012 3:10 PMMorrow Ill, JoDean, CPT USA SJAMIL USA MIL USA oec; IV USA Ford, Arthur D. CW2 - SJARE: Manning search request (UNCLASSIFIED)we are in the middle of Motions hearings and I will likely not be able to discussuntil Friday, the earliest. CH2 Artie Ford should be able to assist with coordination. Itwould be good if we could receive of all the information on separate disks.Unclass?should not be an issuecollateral?our closed system can hold up to this level and our open storage office Ts/sci -we have a standalone ts/sci computer in our MDN SCIF to review this material.Thank you.V/rAshden02979555From:SentTo:Cc:Sume?:hnponance:CPT whyte: @ios.doi.gov]Wednesday, April 25, 2012 12:40 PMwn e, Jeffre H. CPT USA SJABradley. Princeton L. SGT USA I do apologize for not getting back to you sooner. I have been in and out of the DC area overthe last several weeks for work related matters.I will provide you with the Interior's assessment. Although the assessment itself isunclassified, I haveit stored on my high side system. I will send the assessment via thehigh side to the high side email address you identified in your request.Best,Department of the Interior OLES1849 ST, NW, MS 3469Washington, DC 26248 (office)(mobile)(pager)ios.doi. ov 02864515FrontSent: Monday, April 30, 2012 5:10 PMTo: Hughes, Brian A. LTC USA SJASubject: Preservation of PFC Manning-related documents (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOBrian I have unclassified discs from the Deputy UnderSec. Of the Army, OCLL, andOCPA (Public Affairs) that are responsive to your request for thepreservation and production of records. I am awaiting documents from G6(hope to receive tomorrow morning as docs have already been identified).I received a call from AB of who received request from IMCOMchannels. has in its possession the 23 AUG 2016 investigationapproved by MG Garrett of and the document by whichdeclassified the document so as to provide it to the prosecution team. I amsure you alreadyhave these documents, but wanted me to check.v/r Criminal Law DivisionOffice of The Judge Advocate GeneralBB: Classification: UNCLASSIFIEDCaveats: FOUO 02821064From: Parra, Jairo A. CW2 USA JFHQ-NCRIMDW SJASent: Tuesday, May 01. 2012 1:22 PMTo: David Coombs; Fein. Ashden MAJ USA SJACc: an I890, nssa USARMY j?Subject: RE: Contract POC (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOU0David,As per our previous discussion and stated in your e?mail, it would be yourgovernment representative (defense counsel) who must contact the contractingofficer to address the issues with the unauthorized commitment of funds.I'm not totally sure if just a memorandum will address all the issues orconcerns the contractor may have. I would suggest you get all guidance andway forward from them to avoid future complications. The POC for this issueiS= Sherry L- Camer - As faras the modification of the current contract is concerned, the contractingoffice is working in issuing the contract as soon as possible. However, themodification of this contract should not prevent your experts in submittingan invoice for the last trip, as money still available under the currentcontract, which they can bill against in wAwF. If you have any questionsplease feel free to contact me at your earliest convenience.v/r,JPJairo A. ParraCW2, JALegal Administrator The information contained in this email and any accompanyingattachments 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 Defensewithout prior authorization from the Office of The Judge Advocate General,Department of the Army. If you are not the intended recipient of thisinformation, any disclosure, copying, distribution, or the taking of anyaction in reliance on this information is prohibited. If you received thisemail in error, please notify this office immediately by return email (see 5U.S.C. 552 and Army Regulations 25-55 and 02983518 From: Whyte. Jeffrey H. CPT USA SJASent: Tuesda Ma 01 2012 3:39 PMTo:Cc: Bradley, Princeton L. SGT USA JFHQ-NCRIMDW SJASubject: US v. Manning Classification: UNCLASSIFIEDCaveats: NONESir,Have you sent us the DOI's assessment? we have not received an email From your department.Please let me know when you send the assessment and I'll confirm receipt. Thanks, Sir.v/rCPT whyte02983214 From: Whyte, Jeffrey H. CPT USA SJASent: Tuesday, May 01. 2012 3:59 PMTo:Cc: Bradley, Princeton L. SGT USA JFHQ-Subject: US v. PFC Bradley Manning (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUO!recommended that we get in touch with you about a document that your agency mayave prepare relating to the above prosecution. Are you available to discuss over thephone? If so, please let me know what number works best ?or you.Thanks!v/rCPT whyte02979813From: Bradley, Princeton L. SGT USA SJASent: 28, 2012 10:16 AMTo:Subject: RE: Request to Review NCIX Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOGood morning, I hope that you have been well since we last spoke. Ijust wanted to let you know that MAJ Fein has had a chance to check hisJHICS account and the email did not go through. IF you intend to resend theemail please let we know so that I can ensure MAJ Fein is aware (his JNICSaccount must be accessed from an alternate location). IF you would like todevelop a plan 8, I will say that I am not opposed to meeting you at youroFFice to pick up the documents as I do have a courier card For documentsclassi?ied secret and below. Please let me know iF there is any otherassistance I can provide.Very Respectfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 1 02979800From: ?@gsa.gov1Sent: Wednesday, March 28, 2012 10:41 AMTo: Bradley. Princeton L. SGT USA SJASubject: Re: Request to Review NCIX Response (UNCLASSIFIED)SGT Bradley,I'm out on Navy duty this week (over at OJAG - Navy Yard). I will be back at GSA on Monday.I will try to reach my colleague at GSA who has regular access to our SCIF and come up with aPlan for getting this to you (or, worst case scenario, having you come to get it).wr, 02215763From: Sent: Friday, October 29, 2010 4:05 PMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Zimmerman, Sara . A JFH - SJA Subject: Defense Discovery RequestAttach: Discovery Request - Ashden - Joe,Please see the attached discovery request in preparation for the Article 32. The items requested in sub-paragraph are for the preliminary classification review. Let me know if you have any questions orconcerns.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02879524From:Sent:To:Cc:Subject:Sir,Fein. Ashden CPT USA SJAFriday, October 29. 2010 4:06 PMMatthew kemkes; Zimmetman. Sara J. SGT USA JFHQ-NCRIMDW SJA: orrow ll, Jo ean. CPT USA SJARE: Defense Discovery RequestAre we to assume this supersedes your email request For the items for the Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of washington (MDW) 02215761From: Sent: Friday, October 29, 2010 4: 16 PMTo: Fein, Ashden on USA sm Cc Matthew kemkes .Zimmerman, Sara J. SGT USA SJAMorrow Ill, JoDcan, CPT USA JFHQ-A Subject: RE: Defense Discovery RequestAshden,Many of the items are the same, but it does not supersede the earlier request. Let me know if you haveany questions or concerns.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: This transmission, including attachments, may contain confidential attorney-ciient information and is intended for the person(s) or company named. If you are not the intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02185615 From: CIV USA musarmymil]Sent: Monda November 01, 2010 3:29 PMTO: sdoj.gov; Morrow JoDean, CPT USA SJACc: CIV USA Fein, Ashden CPT USA IV US USASubject: Re: Aunt's Home (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: ENFORCEMENT SENSITIVEALCON,we have an appointment to meet with Ms. VAN (PFC MANNING's Aunt)tomorrow at her home at 1833. She advised that the box sent from theconfinement facility in Kuwait is still sealed and in her basement alongwith MANNING's other belongings. we'll get a written consent from herbefore looking at anything. Please let me know if you have anyquestionslconcerns/comments.Washington Metro Resident AgencyComputer Crime Investigative Unit (CCIU)U.S. Army Criminal Investigation Command (USACIDC)9895 Lowen Road, Building 193Fort Belvoir, VA 22060 Email:Email:SIPR: us.army.smil.mi1web: THIS EMAIL MAY CONTAIN LAW ENFORCEMENT SENSITIVE INFORMATION.NOTICE: This E?mail (including attachments) is covered by the ElectronicCommunications Privacy Act, 18 USC 2516-2521, is confidential, and may belegally privileged. If you are not the intended recipient, you are herebynotified that any retention, dissemination, distribution, or copying ofthis communication is strictly prohibited and may be unlawful. Please replyto the sender that you have received the message in error and then delete102185615the message and any attachments.Classification: UNCLASSIFIEDCaveats: ENFORCEMENT SENSITIVE02215760From: Sent: Monday, November 1, 2010 5:51 PMTo: Fein, Ashden CPT USA SJA Mmhew? Morrow 111, JoDean, USA SJA Hall Cassius Mr FMMC (FTMYER)?ales Subject: PCR InformationAshden,Mr. Hall and Mr. Ganiel need to obtain the following additional information for their PCR. I have cc'd themon this request.Please send them the damage assessments that were conducted by the OCAs in this case. They also wantthe SCG used to classify the information. Finally, they have asked for the government computer link tothe video that was allegedly released by PFC Manning.Feel free to call me if you have any questions or concerns.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02215757From: Sent: Monday, November l, 20l0 9:27 PMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkesMorrow JoDean. CPT USA SJAHall Cassius Mr FMMC (FTMYER)>4 ?ares Subject: RE: PCR InformationAshden,I agree with you in principle. However, I think the question becomes "when are they acting in theirdefense capacity?" Given the unique nature of the PCRO, I believe Mr. Hall and Mr. Ganiel are currentlyacting in their government capacity. How else can they be expected to conduct a verification review toaccurately determine the classi?cation level of information in the case?Under the PCRO, Mr. Hall and Mr. Ganiel are not only limited in what they can share with the government,given the fact not everyone on the defense team has the requisite security clearances, they cannotcurrently share this information with the defense. However, once they complete their work and determinethe classification level of information involved in the case, then appropriate steps will be taken to ensureeveryone involved in the case has the requisite clearances.After this is done, then the defense will be able to discuss with our client any information that was sharedwith Mr. Hall and Mr. Ganiel. Additionally, Mr. Hall and Mr. Ganiel will be able to discuss thissame information with the defense team.Does this make sense to you? I am free tomorrow anytime after 1500 for a telephone conversation.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is -- Original Message Subject: RE: PCR InformationFrom: "Fein Ashden CPT USA JFH MDW Date: Mon, November 01, 01 pmTo: Cc: "Matthew kemkes" ean,CPT USA orrow 02215757 "Hall CassiusMr FMM FTMYER ar es aniel"Sir,Are you available tomorrow to chat? I wanted to reply to all to emphasizethat the defense security experts should NOT be using JWICS or SIPR forresearch without authorization and we are working on that authorization.when they are acting in the defense capacity, they are not "governmentactors" thus their own authorization is limited to the scope of their normalcourse of business. We can discuss more tomorrow as we work to get them theproper authorizations for JWICS and SIPR. Thank you.AshdenAshden FeinCPT, JAChief, Military Justice From: Sent: Monday, November 01, 2010 5:51 PMTo: Fein, Ashden CPT USA SJACc: Matthew keml Sent: Thursday, November 4, 20l 0 9:52 AMTo: SMO) cL.usdoj.gov>; (SMO)@usdoj.gov>; FemMorrow .loDean, CPT USA JFHSubject: FW: Aunts House (UNCLASSIFIED)Thanks) Unbelievable that all that electronic media was missed.Please list all the items to be searched in Attachment A. along with thesealed box. If you send me the draft af?davit Friday/Saturday. I canturn it around over the weekend. and we can swear out the warrant nextweek. Hopefully. we'll ?nd something good.inal Messa Fromi CW SA lmailtez Sent: v, November 03. 2()l0 6:5-1 To: (USAVAE)Cc: (USAVAE)Subject: Re: Aunts House (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: ENFORCEMENT SENSITIVEWTUpdate on the Aunt?s House Another agent from my office and myself went out last night and got awritten consent from the aunt to search through MANNING's stuff that wasleft there. We ended up ?nding some more items of digital media thathadnot be discovered in the previous search in June when State Department.Army Military Intelligence and our guys went out. Apparently the auntwentthrough all of the stuff that was in the basement/house and packed upslu?? into large tupperware type containers and a dresser - Isuspect MANNING's Aunt put items belonging to MANNING which we hadn'tpreviously seen into these containers. Last night we recovered:(1) Hard Disk Drive(3) SD Memory Cards(I) Smart Media Card(14) CD-R Discs(2) CD-RW Discs(1) USB Memory CardI) Book with lots of highlights. underlines. tabbed pages. andnotesI don't have high-hopes the book (Jane Austen's ?Pride and Prejudice")isgoing to be signi?cant to our case. but you never know. As well as wealso collected the sealed box containing the personal belongings of PFC02214111MANNING which had been sent Certi?ed Mail to his Aunt's house from theconfinement facility in Kuwait - per our previous discussion. The boxappears to have been unopened since its arrival. Lastly. we took about250+ photos of all of the other uncollected items (mostly clothing.stereoequipment. text books. ctc.).I'll get the recent af?davit from SA- re-work it. and I'll senditto you for the search of these items. Give me a day or so.Special AgentWashington Metro Resident AgencyComputer Crime Investigative Unit (C CIU)U.S. Army Criminal Investigation Command (USACIDC)9805 Lowen Road. Building 193Fort Belvoir, VA 22060- Office- DSN- B1ackBerr'y- Fax Email: g"Lus.am1y.milEmail:SIPR: g.us.army.smil.milWeb: THIS EMAIL MAY CONTAIN LAW ENFORCEMENT SENSITIVE INFORMATION.NOTICE: This E-mail (including attachments) is covered by the ElectronicCommunications Privacy Act 18 USC 2510-2521. is con?dential. and maybelegally privileged. If you are not the intended recipient. you areherebynoti?ed that any retentiott dissemination distiibution. or copying ofthis communication is strictly prohibited and may be unlawful. Pleasereplyto the sender that you have received the message in error and thendeletethe message and any attachments.#31?Classi?cation: UNCLASSIFIEDCaveats: ENFORCEMENT SENSITIVE02188794From: state.gov>Sent: Thursday, November 4, 2010 4:56 PMTo: Fein, Ashden CPT USA SJA Cc: Morrow Ill JoDcan CPT USA JFH SJA Subject: RE: WikiHi Ashden: Sorry for the delay in getting back to you. I wound up being out sick at the end of last week, so am a bitmore behind than is even usual!Would Monday or Tuesday of next week work for you instead? I don't know if?mentioned, but I amactually going to be transitioning to a new portfolio, and my successor is arriving in the office on Monday.(Don't worry, am not abandoning you entirely, and am remaining in the law enforcement and intelligence section so itwill be easy to help ensure continuity. And of course, I will participate in the meeting!Anyway, let me know what might work on your end late morning or afternoon perhaps? and I'll round up folks here.Many thanks -LCS. Deiartment of StateThis email is UNCLASSIFIED. 02884036From: Fein. Ashden USA SJASent: Thursda November 04, 2010 6:05 PMTo: Cc: Morrow m, JoDean, CPT USA (sumo)Subject: RE: WikiThank you. I hope you are feeling better. we can all relate to being out sick and thenbecoming sickened after sifting through all the missed emails.Next week is great. I would prefer, if possible, to meet on Iuesday because I will be incourt on Monday. How is 1pm For everyone?AshdenAshden FeinCPT, JAChief, Military Justice 02905368From: Fein, Ashden CPT USA SJASent: 0 9:16 AMTo: USA OTJAGCc: Morrow Ill. .JoDean, CPT USA SJASubject: Convenmg Authonty Request for Defense Access (US v. Manning)Attachments: Defense Request for Access to Information Systems (ManningB).pdfunponance: HanSir. Attached is the Convening Authority?s request to the Army G2 for the defense expertconsu1tant?s access to SIPR 8 JNICS For the PCR. Could you please let us know how long youestimate it will take to process For approval? Thank you!AshdenAshden FeinCPT, JAChieF, Military )usticeU.S. Army Military District of Nashington (MON) 02907590From: Fein, Ashden CPT USA SJASent: Satunda November 06, 2010 2:00 PMTo: Subject: Re: ChatSir. Hopefully we will be able to chat on Monday. Although I was ready to give an answer toyou about the recent rfi-and your sipr email we realized that we still needed to chat withthe Forensic analyst at cid. we tried to get a hold avail.Hopefully we will get our questions answered by him on monday morning and then be able togive you a final answer. Thanks. Have a good weekend.AshdenAshden FeinCPT, JA 02185597 conus.army.mil> From:Sent: Monday, November 8, 2010 9:47 AMTo:usdoj.gov>;USA SJAMorrow, JoDean CPT MIL USA state. ov>;us.anny.mi|>Subject: RE: (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUOAll.Slight change: the meeting will be at I330.v/rWashington Metro Resident AgencyComputer Crime lnvestigative Unit98t)5 Lowcn Road. I93Fort Belvoir VA 22060 02188778Sent: Monday, November 8, 2010 3:48 PMTo: Fein Ashden CPT USA JFH SJA @usdoj.gov>Cc: Morrow JoDean, CPT USA SJASubject: RE: Wiki -- clearance informationHi all: ifyou can provide the following information below. I'll getyou lee'd up in our visitor clearance system. If not. no fears. we'lljust clear you in "manually."NameDOBID type (military. driver's license. passport. other) ID numberIn any event. you'll want to go to the Street lobby and speak with thereceptionist there. I'll count on meeting you in the lobby no laterthan 9:55 to take you upstairs -- you don't need an escort for securitypurposes. but it might help 'ou from etting lost. lfyou run into anyiroblerns. mi direct dial i? and our main office line isMany thanks --U.S. Department of State This email is UNCLASSIFIED 02907585From: Fein, Ashden CPT USA SJASent: 010 7:31 AMCc: on? . 0 an, USA SJASubject: RE: ChatSir. After finally getting a hold of the CID forensic examiner (who was out on a longweekend), we will be ready to give you the consolidated prosecution answer this afternoon.we are meeting with the EDVA to discuss this and other issues. we will try calling around1636. Thanks.AshdenAshden Feincpr, JAChief, Military JusticeU.S. Army Military District of Washington (MOW) 02187778mm: ?@doans.mn>Sent: Tuesday, November 9, 2010 3:15 PMTo: Fein, Ashden CPT USA SJA Subject: RE: Chatthat works. Thank you-02204919From_ Morrow JoDean, CPT USA SJASent: Tuesday, November 9, 2010 4:58 PMTo: ?@state.g0v>Cc: Fein, Ashden CPT USA SJA Subject: sample documents (UNCLASSIFIED)Attach: Sample OC A Cover Letter (Anny format).doc; Sample Affidavit for Classi?cationReview.docxClassi?cation: UNCLASSIFIEDCaveats: FOUOAs promised, attached is a sample OCA cover letter and a sample declaration. These are only drafts and I anticipatethere will be some formatting changes when you all produce the reviews. Let me know if you have any questions.Thanks!CPT Joe MorrowTrial CounselUS Army Military District of WashingtonClassi?cation: UNCLASSIFIEDCaveats: FOUO 02188764Sent: Tuesday, November 9, 2010 5:00 PM To: Morrow JoDean. CPT USA JFH SJA1 Fem, Ashden CPT USA SJACc: Subject: sample documents - wikiThanks very much Joe, and thanks again to both you and Ashden for coming over today. Copying. and-so you'llhave their e-mail addresses in one place for the future, as well as? to let them know that while their delightfulpresence was missed, we had a very productive meeting. Thanks again --iiDi SBUThis email is UNCLASSIFIED. 02204914Morrow JoDean, CPT USA SJAFrom: Sent: Wednesday, November 10, 2010 1:51 PMTo: @state.gov>; Fein, Ashden PT USA JFHQ-51/? Cc: @.state.gov>?state.gov>Subject: RE: sample documents - wiki (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUODOS folks.We are going to pick up the printed docs shortly. I couldn't reach any of you over the phone. but we'd like to stop by your place in -15minutes to drop off paper copies and a disc. Please email and let us know whether there is anyone we can leave this classi?edinfomtation with Thank you.JoeCPT Joe MorrowTrial CounselUS Armv Militarv District of Washington 02188761From ?@state.sov>Sent: Wednesday, November 10, 2010 2:01 PMTo: Morrow JoDean, CPT USA SJAFein, Ashden CPT USA Cc: Subject: RE: sample documents - wiki (UNCLASSIFIED)Hi Joe: son)-' day. but I am around and I think-is too. Butin any event. if you call our main number when you arrive one of our assistants.?can meet you downstairs and pickup this infomralion. They both have appropriate clearances. MarryIhanks!SBUThis email is UNCLASSIFIED02889843FrontSentTo:Cc:Subject: Thanks For yourall the MRNs isAshdenAshden FeinCPT, JAFein, Ashden CPT USA SJAWednesda Novemoet 10 2010 9:24 PM Morrow m. JoDean, USA SJAsamae !ocumen|s - help today. Hopefully those MRN printouts and the CD of the PDF containinghelpful For the first step of the process we discussed this week.Chief, Military Justice U.S. Army Military District of Washington (MON)02902202 From: Fein, Ashden CPT USA SJASent: 11, 2010 9:44 AMTo: USA USACIDCCc: CIV Morrow JoDean, CPT USA SJASubject:Fo?ownupAs a follow-up from this week's meeting, I am tracking the below administrative issues:1. Our Security and IA folks have now determined through NORTHCOM SSO and NSA that theemail - sent us on NIPR is classified and not just A fullsecurity investigation started on our side to contain the spillage and take the appropriatesteps to ensure the document is properly deleted. we have already changed our procedures forreceiving and distributing any information, and I suggest ya?ll do the same. I am not sureif the investigator is going to want to interview- or CCIU because the spillage on ourend begins with his email chain.2. You are going to get back to me next eek with the administrative plan on CCIUsupport to this case and ultimately how all the information is going to be analyzed acrossthe witness interviews, evidence collection, forensic analysis, etc. I need to get back withArmy G2 about the and I highly recommend you take the 1 or more that are offered.My biggest concern is that no one or group has combined all the information and tried to makesense of the forensics, witness statements, known evidence etc. in order to findinvestigative holes driving further investigation. we, have been doing someof this, but as prosecutors we cannot be the first~line Let alonethe possibility that physical evidence still exists today and could disappear as time passes.Also, we cannot wait until the end for the reasons already stated but also we are going tohave to start giving some of this information over to the defense as part of the Art 32process and any additional delay could have serious ramifications on this case.3. we still have not received a copy of the non-forensic side of the case file- swornstatements, AIRS, notes, etc. Other than in passing conversations with et al, wehave nothing to reference but for the initial CID report. The only seemingly comprehensiveinformation we have is on-going forensics. we need this ASAP. Although this will bea dump of information, it gives us some time to start going through it, vice having to getthrough everything at the end and then figure out what we can turnover in discovery.Thanks. I am available anytime to discuss.AshdenAshden Fein02902202CPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 02188754 From: @state.gov>Sent: Friday, November 12, 2010 3:03 PMTo: Fein Ashden CPT USA IFH SJA state.gov>; Morrow JoDean, CPT USA FHQ-SJ ACc: statc.gov>Subject: RE: sample documents - wiki (UNCLASSIFIED)Ashden.No problem. FYI. We handed over the materials to_ whowill work with our document specialists in the infommtion servicesdepartment to get this process started.Best. 02188750Sent: Friday, November 12, 2010 3:08 PMTo: Fein. Ashde -51*? Morrow Ill, JoDean, CPT USA SJASubject: RE: sample documents - wiki (UNCLASSIFIED)1 met Wednesday afternoon with?. the who oversees classi?cation issues for the Department. Herteam will review the documents and sort them into two stacks. as wediscussed at our meeting on Tuesday. We'll let you know as soon as thatpart of the review has been completed. U.S. Deirtment of StateSBUThis entail is UNCLASSIFIED02215731From: Sent: Monday, November 15, 2010 2:40 PMTo: Fein, Ashden CPT USA Cc: Matthew kemkesMorrow Ill, JoDean, CPT USA SJAHaberland, John CPT USA RegimentalRose,Luke CPT USD-C SJAZimmerman, Sara J. SGT USA Chief,Military JusticeJFHQ- SJ.Subject: Discovery RequestAttach: Discovery Request - I5 Nov.pdfAshden,Thank you for the additional discovery. I hope you enjoyed your Veteran's Day as well. I have attached asupplemental defense discovery request. Please let me know if you have any questions.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: This transmission, including attachments, may contain confidential attorney-client information and is intended for the person(s) or company named. ?If you are notthe intended recipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02903810From: Fein, Ashden CPT USA SJASent: Tuesday, November 16, 2010 8:40 AMTo: Cc: Matthew kemkes; Morrow JoDean. CPT USA JFHQ-i an . Jo egimental Judge Advocate: Rose,Luke CPTUSD-C SJA Chief.Military Justice; Zimmerman. Sara J. SGT USA JFHQ- NCRIMDW SJASubject: RE: Discovery RequestSir. Acknowledge receipt. Any update on the Did your experts get the appropriateaccess they needed? Do they need or want an additional meeting with the Accused? Ideally,we would like 4 days notice to coordinate the movement, so please let us know. Thanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN)02215729From: Sent: Tuesday, November 16, 2010 8:48 AMTo: Fein, Ashden CPT USA SJA Matthew kemkes Morrow 111, JoDean, PT USA SJAllabcrland, John CPT USA RegimentalRose,Luke CPT USD-C SJAZimmerman, Sara J. SGT USA Chief,Milita1y JusticeJFHQ- SJASubject: RE: Discovery RequestAshden,Mr. Hall and Mr. Ganiel would like to meet with PFC Manning again (ideally this week). They have sent anemail to Mr. Sessoms to try to coordinate such a meeting. I have a feeling, however, that Mr. Sessomsjust controls access to the SCIF. who do we need to coordinate with to arrange for the actual movementof PFC Manning?I believe Mr. Hall and Mr. Ganiel have the appropriate access to conduct their PCR. I will let you know ifthey raise any concerns with me.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02187770From: _@dodiis~miI>Sent: Tuesday, November 16, 2010 10:32 AMTo: Morrow ill, JoDean, CPT USA SJACc: Fein Ashden CPTU A FH -N SJA dodiis.mi1>Subject: IRTF CS5 AccessJoe,Looking forward to meeting tomorrow. Ashden says that he has a DIA badge, which will help him with access. Tofacilitate your access, please sen your SSAN, and she'll coordinate with the security office. If there arequestions, you can call me at02895475From Fein. Ashden CPT USA SJASent: Tuesda November 16, 2010 6:14 PMTo? USA OTJAGCc Morrow JoDean. CPT USA SJASubject: OCA Prelim ReviewsSir. Joe sent you the last powerpoint tonight in PDF form on SIPR. You should have receiveda total of 6 documents (2 for Farah) and (4 for GTMO). Could you please let us know whatelse you need from us in order to assist with getting the OCAs on track with conducting theirreview? we have the memo?s ready to go for the formal request after you help with gettingthe system more efficient. On that note, have you received the CENTCOM Apache review yet?we would like to notify defense (after discussing with D03) about the unclassified nature ofthe video so it shows substantial movement forward. Thanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN)02886537From: Fein, Ashden CPT USA SJASent: Friday, November 19. 2010 7:39 PMTo: Cc: Matthew kemkes: Morrow m, Jo0ean, CPT USA JFHQ-a a egimental Judge Advocate; Rose,Luke CPTUSD-C SJA Chief,Military Justice: Zimmerman. Sara J. SGT USA JFHQ- NCRIMDW SJASubject: Unclassi?ed Discovery (US v. Manning)Attachments: Unclassi?ed Discovery (000475-000662) (ManningB).pdfSir,Attached are the CENTCOM security classification guides (SCGS) in effectduring PFC Manning's deployment. The CENTCOM guides are unclassified (FOUO).Please pass these to your security experts. Also, there is an additionalguide from MNFI which is classified. I just sent an email with the guideattached to Mr. Ganiel for his and Mr. Hall's use during the PCR. Once thePCR is complete and we move to get you and the rest of the defense team theproper authorizations, the guide will be available as part of generaldiscovery. I already bates stamped the guide on the classified side. we arestill working the IA expert request. Have a great weekend.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDH) 02910459 From Fem, Ashden CPT USA SJASent 2010 6:54 PMTo: A USCENTCOM Cc: SA OTJAG: Morrow JoDean, CPT USA Subject: Another CENTCOM VideoSir. If you are available tonight or tomorrow, could you please call my Cell so we candiscuss another CENTCOM video? Thank you.V/f?AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON)02900798From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Monday, November 22, 2010 9:33 PMTo: USA USACc: Fein, Ashden CPT MIL USA MDWSubject: lnfonnation Flow Updateshnponance: Gents,Good evening. I know business is changing at CCIU now that you are rearranging the functionsof the team. The purpose of this email is a follow-up to multiple conversations we have hadabout information we (the prosecutors) need from CID, including our conversation tonight-Chuck. Unfortunately, the time is ettin ver ti ht and we need to start disclosin moremar-mauon to the ae+ense Bottom line? we have never received an UNCLAS or CLAS case file, except adump in July.The last copy of the case file we received was dated 14 Jul 10 (the interim report). we havenot received any other documentation, except a few items we specifically requested to fulfillan external requirement. we need a complete copy of the current case file so we can get spunup on the facts, and not just relying on being briefed.02900798Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 02187052Sent:To:Ce:Subject: In recognition of the upcoming holiday. them will be no meeting this week. The FBI will host the next meeting on Tuesday.November 30th at 1:00pm. Thanks and have a good holiday.Supervisory Special Agent (SSA)FBIWashington Field Office601 4th Street. NWWashin on DC 20535OfficeCell02204816From. Morrow Ill, JoDean, CPT USA Sent: Wednesday, November 24, 2010 9:00 AMTo: @state.gov>; state. gov>Cc: @state.gov>; Fein, CPT USA FHQ-SJASubject: update on cables (UNCLASSIFIED) Classi?cation: UNCLASSIFIEDCaveats: FOUOGood morning,Hope all is well at State. Just checking in to see where we're at with the document review. if there are any issues withour original plan, please let us know. We'd love to set up a second meeting for some time after the holiday, if thatworks for you.Have a great Thanksgiving!CPT Joe MorrowTrial CounselUS Army Military District of WashingtonClassi?cation: UNCLASSIFIEDCaveats: FOUO02188749From:Sent:To:Cc:Subject:SBUJoe,?@sww-sov>Wednesday, November 24, 2010 9:13 AMMorrow Ill, JODean, CPT USA SJA,state.gov>state.gov>; Fein, Ashden CPT USA SM Re: update on cables (UNCLASSIFIED) We received word late yesterday that the review has been completed. We'd be glad to meet with you next week to discussthe results. I will check with those who did the review on Monday to see when they are available for a meeting.Have a great Thanksgiving, as well. U.S. Deiartment of State02215716 . From: Sent: Monday, November 29, 2010 l:40 PMTo: Fein, Ashden CPT USA SJA Mam? kemkes Morrow Ill, JoDean, A SJA1-Iaberland, John CPT USA RegimentalRose,Luke CPT USD-C SJAZimmerman. Sara J. SGT USA Chief.Military JusticeJFHQ- SJASubject: Investigative RequestAttach: Investigative Expert Ashden - Joe,I hope you had a pleasant Thanksgiving. I have attached a request for investigative assistance. I alsowanted to touch base with you on a couple of other issues.1) I know that you stated you expected to have a new charge sheet in the case. Do you have a ideawhen that would occur?2) Once you are able to raise the issue, can you give me an update on your discussions with Quantico onthe POI restrictions for PFC Manning? In addition to the issue of not being able to have personalpossessions in his cell, have a pillow, or a sheet - the P01 also prevents him from exercising. Apparently,the facility is concerned that he would hurt himself if he exercised. If PFC Manning attempts to do push-ups or any other form of exercise, the guards will immediately instruct him to stop. As I mentionedbefore, it appears the command is ignoring the recommendation of Capt Hocter to take PFC Manning off ofPOI. I believe the restrictions do rise to the level of Article 13 punishment. I am hoping that you willmake more headway than I did on this issue.3) Defense Visit: I plan to come to D.C. on December 13 - 16. I am hoping that you can coordinate theoffice issue in order to meet with PFC Manning in some location other than the no?contact booths for acouple of those days. Also, during that time, I would like to sit down with you and Joe to have adiscussion on the case. Is there a good time for the two of you during that week?4) Computer Forensics: Do you know the results of the computer forensics by SA Robertson and SAShaver? If so, when do you believe Mr. Lakes will have access to the hard drives and CID's reports?Additionally, I understand that you can't share the information with me yet, but I would like to talk to youabout the general results of those reports. Are you available for a discussion sometime this afternoon?Feel free to call me if you have any questions or concerns.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-989602215716Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02900540From: Fein. Ashden CPT USA SJASent: Monday, November 29, 2010 6:26 PMTo: Cc: Matthew kemkes; Morrow Ill. Jooean. CPT USA JFHQ-a an egimental Judge Advocate: 'Iuke.rose@mnd-b.army.miI'; Zimmerman, Sara J. SGT USA JFHQ- SJAsubject: Re: Investigative RequestSir. Sorry we didn't get back to you sooner. Been incredibly busy today as you can imagine.will you be available around 1038 tomorrow morning?Ashden FeinCPI, JA02215701From: Sent: Tuesday, November 30, 2010 :22 PMTo: Fein, Ashden CPT USA SJA Cc: Morrow Ill, JoDean, CPT USA SJAMatthew kemkcsouchar Subject: RE: Manning Visit at Fort BelvoirAshden,I am Sorry, but I did not hear you mentioned having the defense meetings at the FIU building during ourearlier conversation. I may have missed that being said due to the fact that occasionally you and Joecancel each other out by being on speaker-phone. Had I heard you say this, I would have told you that Ididn't think that was a good idea.I understand that PFC Manning is on maximum custody. He really shouldn't be however. Also, I have hadother clients, most notably SGT Akbar, that were on maximum custody but still brought to the TDS of?cesfor pretrial preparation meetings.Additionally, the concern over others being within ear shot during defense discussions can be address byme and MAJ Kemkes. This would not be a basis for the defense deciding to use the FIU building. Iconcurred with the use of the FIU for the PCR because it was the right thing to do, and the appearanceissue could be managed. Asking TDS and myself to use the FIU to conduct our defense preparations issomething that just looks bad and is a nonstarter.Please make the arrangements to have PFC Manning brought to MAJ Kemkes' office in ACUs. If you feelthat this is an unreasonable request or are inclined to not support the request, please let me know.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02898249 . From: Fein, Ashden CPT USA SJASent: Tuesday, November 30, 2010 1:33 PMTo: Cc: Morrow JoDean, CPT USA Matthew kernkes; Paul Bouchard;Johntiabe?andSubject: RE: Manning Visit at Fon BelvoirSir. I understand your concerns and that FIU was originally chosen because it's a SCIF aswell. we are reviewing the Brig policies and will make every effort to make this happen,within the confines of the rules. Also for the uniform issue, the Soldiers in the NCR thatshow up to defense counsel's office in uniform, do so after the unit takes them back to theunit and allows them to change. This might still be able to occur, but would you prefer yourclient to go to the unit and change first, or go directly to TDS and change there? For FtMyer, the TDS office is more remote and provides your client more privacy than the HHC, USAGcompany area.will continue to work this issue.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MUN) 02188746From: @state.gov> Sent: Tuesday, November 30, 2010 6:02 PMTo: Fein, Ashden USA sm Morrow JoDean, CPT USA SJACc: Subject: Meeting tomorrow?Hi and Joe.Wilh apologies for me lalc notice. would you be available to meet regarding the documenl revlew lomormw aflcmoon?? We areavailable mos! of the aflemoon prior to 4pm. Let us know and we'll make anangemems for a conference room.Best.U.S. Department of State 02897050From: Fein. Ashden CPT USA SJASent: Tuesda November 30, 2010 6:03 PMTo: ?Morrow JoDean| CPT USA SJACc:Subject: RE: Meetmg tomorrow?-. Thanks. Lets plan on 1pm?Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN) 02188745 From: state.gov>Sent: Tuesday, November 30, 2010 6:09 PMTo: Fein, Ashden CPT USA SJAMorrow JoDean, CPT USA SJACc:/state.gov>;Subject: RE: Meeting tomorrow?Sure, that sounds good We'll see vou then.mm; I-?cin. Ashden cm IISA u-uQ-mwnw gm?Sent: Tuesday, November 30, 2010 6.03 PMTo: (iahan, Kimberly A. Morrow JoL)can_ Cl"! USA JH SJACc: Freeman. Jeremy Wilson, Kathleen Murphy. Nicholas Subject: Rli: Mccling tomorrow"Knmi hanks. Lets plan on lpmi?Ashden FeinCPT, JAChicll MiI1lzar? US. Army Military District of Washington 02885232From:SentTo:Cc:subject:Attachments:Importance:Sir.Fein, Ashden CPT USA SJATuesda November 30, 2010 6:34 PMUSA OTJAGMorrow JoDean. CPT USA SJAUS v. Manning Requests10-Nov-30-Request for Classi?cation Reviews (ManningB).pdf: 10-Nov-30-Request forAssistance for IA Expert (ManningB).pdfHighAttached are two requests From the prosecution team. I am going to send the Request ForClassification Reviews on SIPR with the enclosures attached tonight. we will be makingsubsequent Formal requests For classification reviews but these are For the documents we planon charging at this point. we are reviewing CIDNE-IZ documents but have not selected theones we intend to charge and introduce.Thanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MOW)02885256From:SentTo:Cc:Subject:hnponance:1?Good evening.garahni /farah air strike.Fein, Ashden CPT USA JFHQ-NCRIMDW SJA2010 9:11 PMUSA USCENTCOM SA Morrow JoDean, CPT USA SJAUS v. Manning - CENTCOM Docswe chatted two weeks ago about us getting a copy of the full 15-6 for theI would like to renew that request along with the followingdocuments:1. Original copy (unaltered) of the Garahni/Farah air strike video2. Original copy (unaltered) of the Garahni/Farah air strike 15-63. Any redacted releasable versions of #2 produced.4. The FOIA (releasable) copy of the apache video 15-6 (we have the Full version).IF possible, could we get these sooner than later, and have a rush order For the releasable(unclassiFied) copies because we need to turn these over to defense.v/rAshdenAshden Feincm, JAThanks.Chie?, Military JusticeU.S. Army Military District of Washington (MD) 02885256 02908324From: Fein, Ashden CPT USA SJASent: Monda December 06, 2010 3:43 PMTo: *@dodiis.mirSubject: CallSir. when you can please call my bb. Thanks.Ashden Fein 02204244Morrow JoDean, CPT USA SJAFrom: Sent: Tuesday, December 7, 2010 1:58 PMTo: ?@usearmymiI @us.army.mil>;Cc:iis.mil>; Fein, Ashden CPT USA SJASubject: meeting tomorrow at 1230 (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUOGentlemen,We are on for tomorrow at 1230 over in City.CPT Joe MorrowTrial CounselUS Army Military District of WashingtonClassi?cation: UNCLASSIFIEDCaveats: FOUO02885259 From: Fein. Ashden CPT USA SJASent: Wednesda Decembet O8. 2010 8:51 AMTo: A USCENTCOM Cc: USA Morrow Ill. JoDean, CPT USA SJASubject: RE: US v. Manning - CENTCOM DocsSir,Thank you for sending the Farah File (9 CD5). However, we did not receive the FOIA releasedversion of the Apache 15-6. Could you please send that copy ASAP. Also, has there been aFOIA request For the Farah 15-6 and/or video? Thank you gain.v/rAshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MOW) 02910791From: Fein, Ashden CPT USA SJAsent: Wednesda December 08, 2010 7:31 PM To: IV Morrow Ill JoDean. CPT USA JFH SJACc: (USAVAE): (USAVAE): Subject: RE: a couple questions (UNCLASSIFIED)Attachments: 10-Jul-05-Onginal Change Sheet (ManningB).pdfAttached is the original charging document (5 Jul 19) for PFC Manning which was initiallyexecuted in Iraq without the benefit of the majority of today's forensics. The documents andbasis will change with the addition of several more charges and amendments of many of theother charges. while the investigations with the different USG agencies is on?going, we areconcurrently preparing the buffet of charges we could charge, so that when we get the greenlight from the different original Classification Authorities, we will go forward.Currently we are waiting on a security classification review and then a mental health exam.Once the mental health exam is completed, we will move directly into our Article 32, UCMJinvestigation (preliminary hearing/grand jury equivalent).My contact information is below, if you would like to discuss more.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MOW) 02185378mu-= Sent: Thursday, December 9, 20l0 7.48 AMTo: Fein. Ashden CPT USA SJA Cc: Morrow JoDean, CPT USA SJASubject: brei?ng (UNCLASSIFIED)Attach: 20080609_opsec.pdfClassi?cation: UNCLASSIFIEDCaveats: FOUOSirs.While you are basking in the glow of all the smart people in Washington,we found this little nugget on his personal external hard drive in afolder called Documents\Homewor1(. It was originally saved as an OpenO?ice (free version of MS Office) presentation. I converted it to PDFto make it easier to view. Digital Forensics and Research BranchComputer Crime Investigative Unit193. 9805 Lowcn RoadFort Belvoir. VA 22060 .mil.smil_milClassi?cation: UNCLASSIFIEDCaveats: OUO02886185From: Fein. Ashden CPT USA SJASent: Thursday, December 09, 2010 11:50 PMTo: Cc: Monow Ill. JoDean. CPT USA Matthew kemkes;Subject: ateSir,Tomorrow the Quantico Brig is holding their Classification and Assignment Board, which makesrecommendations to the Brig OIC. we requested the OIC consider the issues you presented inhis determination of PFC Manning's status. we should Find out a result by C08 tomorrow onwhether his status is going to change. we obtained his uniforms and he will have them forhis meetings with you next week.we still are waiting on a nomination for an IA expert. As I previously stated, the Mow doesnot have any available IA experts so we had to go to the Army for that assistance.00 you still want to meet next week at Ft Meade? As previously stated, lets plan for earlyevening on wed? we confirmed that CID did collect PFC Manning's health records and we arenow working to get a copy. They currently have them sealed and once we take possession ofthem, we will release the documents after having a taint attorney review them for possibleprivileged documents (you will of course receive the privileged documents, but we will keepthem sealed).Thanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District 04 washington (MON) 0221 5682From: Sent: Friday, December 10, 2010 3:35 PMTo: Fein, Ashden CPT USA SJA Cc: Morrow Ill, .loDean, CPT USA SJAMatthew kemkes Subject: RE: UpdateAshden,Ijust spoke with Capt. Hocter. He says that PFC Manning was not looking as good today due to havinghis television privileges taken away. Apparently, the confinement facility decided to take away histelevision privileges when they heard about the rumor spreading in the news about PFC Manningcommitting suicide.As far as I know, they didn't explain to PFC Manning why his privileges were being taken away. Due tothis fact, PFC Manning apparently looked depressed today (after two days without the privileges). This, inturn, caused Capt. Hocter to recommend that he stay on POI until he looked normal again. Capt. Hocterdid recommend that the facility give back his television privileges and allow him to exercise.As far as the meeting on Wednesday, I would still like to meet. I know that we will have to be ?exible asto the time. Also, thank you for the update on the IA and medical records.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02212917From: mm OTJAG Sent: Fn'da December 10, 2010 4:55 PMTo: USA Cc: Fein, Ashden CPT USA SJA SubjectManning Requests (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONEI spoke with PT Fein the lead prosecutor for the Manning case and he believes the defense needs an operational level expert.Someone who implements AR 25-2 not write the policy.Please get in touch with him to pass along the name of such an Army expert as early as possible next week.ThanksRecall that I am on leave nenn week. 02886180From: Fein, Ashden CPT USA SJASent: Sunday. December 12, 2010 11:00 PMTo: Cc: Morrow HI, JoDean. CPT USA Matthew kemkes;ISubject: a Sir,Good evening. we are working to determine why PFC Manning's television privileges wereallegedly taken away. As previously stated, on 19 Dec 10 the Classification and AssignmentBoard met and we should know the results tomorrow whether some of the administrativeprotective measures can/will be lifted. The Army is working to provide the mostappropriate IA expert. I spoke with our POC on Friday and I expect to have an answer thefirst half of this week and then we will present the expert to the convening authority.Our trial this week could end earlier than expected, but I leave that decision to your co-counsel, MAJ Kemkes. As of now, Joe and I will plan to meet on wed late afternoon either atMeade or our office at McNair. we will remain flexible as well.Please let us know if there are any issues with your meetings this week with your client.All the arrangements are made and ready to execute.we are diligently working on determining what information we are in possession of and can bereleased pursuant to your requests.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDW) 02885208From: Fein, Ashden CPT USA SJASent: Sunda . December 12. 2010 11:28 PMCc: USA Morrow Ill, JoDean, CPT USA SJASubject: US v. Manning Requests (UNCLASSIFIED)hnponance: 8.Good evening. Thank you for your assistance. Once you identify the person who could fulfillthis requirement (IA practical experience, including SIPR, but NOT forensics), please sendthe name and contact info to me and my co?counse1 (CPT Joe Morrow-Cced). Thank you again.v/rAshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 02185288 From:CIV USA us.army.mi|]Sent on ay, ecen1er13,20106:To: Fein, Ashden CPT USA CIV Morrow m,JoDean. CPT USA SJALittle more serious note (UNCLASSIFIED)@us.army.miISubject:Signed By: Classification: UNCLASSIFIEDCaveats: FOUOIn examining the items from the Aunt's house, there was an File.Created in early Jan 16, which was located on a SD card (no clue on timezone). The File was named yada.tar.bz2.nc,appears to with and it was about 166MB. There are lots of photos on the various SD cards whichwill have to review, in several photos there are lots people.Not too sure who is who.Digital Forensics and Research BranchComputer Crime Investigative Unit193, 9865 Lowen RoadFort Belvoir, VA 22666 us.arm .mi1us.army.smi1.mi1Classification: UNCLASSIFIEDCaveats: FOUO02185277From: -Vlr CIV USA USACIDC -gconus.anny.miI]Sent: Monday, December 13, 2010 1:44 PMTo: Morrow JoDean, CPT USA Fein, Ashden CPT USA JFHQ-SJASubject: Mannin UNCLASSIFIED)Signed By: us.army.mi|Classification: UNCLASSIFIEDCaveats: FOUOGents,?reviewed an SD card seized from Manning's Aunt's house.Examination of the card found (as of now) 263 records related to Afghanistan(we're pretty sure it's CIDNE), and 366,174 records related to Iraq (alsopretty sure it's CIDNE). These were created on the card on or about 9 Jan 16. More toI Washington Metro Resident AgencyComputer Crime Investigative Unit9865 Lowen Road, 193Fort Belvoir, VA 22866 Classification: UNCLASSIFIEDCaveats: FOUO 02685215 From: Fein. Ashden CPT USA SJAsun: 10833AMTo: USA Cc: USA Morrow Ill. JoDean, CPT USA SJASubject: US Manning Requests (UNCLASSIFIED)hnponance: Good morning. I was wondering if you have the name For the IA expert we may use? we reallyneed to get that individual identified so that we can keep our case moving Forward, otherwisethere could be potential impact on the prosecution. Thank you.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 02223598From: USA CIOIG-6 Sent: Friday. December 17, 2010 3:29 PMCc: USA USA Subject: RE: US v. Manning Requests (UNCLASSIFIED)signed By: us.army.miIClassification: UNCLASSIFIEDCaveats: FOUOClassification: UNCLASSIFIEDCaveats: FUOCPT Fein,The organizational entity within Headquarters Department of the Army that hasoperational responsibility for implementing AR 25-2 on the HQDA NIPR andSIPRNETS is the Enterprise Security Services - Pentagon, a Directorate of theInformation Technology Agency, which is part of the Office of theAdministrative Assistant to the Secretary of the Army.The Information Assurance personnel who we (in the Cyber Directorate)contact regarding operational issues with the HQDA NIPR and SIPR networksare:?and Both are civilian employees.The Director of the Information Technology Agency is_, andSES.I have been unable to contact either-or_this afternoon.Respectfully, Office of InformationA uranc and ComplianceDSN 1s.army.mi1 02219526 Alma?-7-a? Paul Sent: Monday, December 20, 2010 10:47 AMTo: Fein. Ashden USA SJAMatthew kemkesMorrow Ill. JoDean. CPT USA SJA Haberland, John USA RegimentalJudge Advocate Rose, Luke SJAChief. Military JusticeCc: Zimmerman, Sara SGT JFHQ- SJASubject: RE Article 32 (PFC Manning)All -Just touching base agatn on the slams of matter. Let me Itnou Ifyou hate an ETA on the completion of the sanity boardThanks. and happy ]l0IidiI_\ to all of_\ouLTC Alman/a02185190From: USA _@us.anny.mil>Sent: Monday, December 20, 2010 5:09 PMTo: Morrow JODean, CPT USA SJAFein, Ashden CPT USA A Subject: Update (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOBusted open the ?le on the SD Card. Probably want to check your SIPR.Have a good meeting. Digital Forensics and Research BranchComputer Crime investigative Unit193, 9805 Lowen RoadFort Belvoir, VA 22060 us.army.mi|us.army.smi|.milClassification: UNCLASSIFIEDCaveats: FOUO02909150FrontSentTo:Cc:Subject:Sir,Good evening.Fein, Ashden CPT USA SJAMonday, December 20, 2010 6:53 PMAlmanza. Paul; Matthew kemkes; Morrow Ill.JoDean. CPT - a an ohn CPT USA Regimental JudgeAdvocate: Rose. Luke CPT USD-C SJA Chief, Militaty JushceZimmerman. Sara J. SGT USA JFHQ- SJARE: Article 32 (PFC Manning)The Sanity Board will likely begin after the New Year. we are currentlymoving into the process of ensuring all participants have appropriate clearances. Have aHappy Holidays!v/PCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Nashington (MON) 02885449FromSentTo:Cc:Subject:Hnponance:Sir,Good evening.of the process.Fein, Ashden CPT USA SJAMonday, December 20. 2010 6:59 PMCOM WRAMCorrow JoDean, CPT USA Kemkes. Matthew MAJ MIL USAUS BM (706 Board)HighThe US v. PFC Manning case has now moved into the security clearance portionFor this, we will need to ensure all the personnel who will be involved inthe case have adequate clearances and appropriate read-ons. can you please verify that thefollowing personnel will be the members of the RCM 706 Board? Thank you.706 Board:Dr. SwedaLTC SchneiderBeneshv/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON)02886049From: Fein, Ashden CPT USA SJAsent: Wednesday. December 22, 2010 10:14 AMTo:Cc: Morrow m, JoDean_ CPT USA SJASubject: Update (US v. BM)Good morning. I was wondering if you could please provide us an update from our lastmeeting? Thank you.Happy Holidays!AshdenAshden FeinCPI, JAChief, Military JusticeU.S. Army Military District of Washington (MN) 02212897From: 0TJAGconus.army.mil]sent: Wednesday, December 22, 2010 10:25 AMTo: Fein, Ashden CPT USA SJASubject: US v. Manning Requests (UNCLASSIFIED)Signed By: ?1@us.army.miIClassification: UNCLASSIFIEDCaveats: FOU0Ashden,Did you ever get the Office of the Jud Advocate General of the Army, Pentagon 3D548NIPR: conus.army.milSIPR: QDA?S.army.smil.mi1JHICS: ami.ic.govTel: 02885223From: Fein, Ashden CPT USA SJASent: Wednesda December 22, 2010 10:34 AMwe: om omeSubject: RE: US v. Manning Requests (UNCLASSIFIED)No sir. Spoke with your POC, and he said he was working it. He said Ishould have it by Mon and that did not happen.Ashden FeinCPT, Chief, Military JusticeU.S. Army Military District of Washington (MOW)02188737From: .state.gov>Sent: Wednesday, December 22, 20l0 10:59 AMTo: Fein, Ashden CPT USA SJA Ce: state.gov>; Morrow JoDean. CPT USA JFHQ- Subject: RE: Update (US v. BM)Ashden.Our folks here are still in the process of reviewing the docs for redactions. We've also developed a plan with our bureau leadershipon identifying appropriate deelarants for the documents you've identified for us. Several of the folks working on this are now out forthe holidays. so we should have a more detailed update for you just after the New Year.I hope that works for you.Any further developments on timing from your end??Thanks. and Happy Holidays to both of you!Best.PS -- I removeti from the list. as she's now taken over her new portfolio and quite busy with it! 02886052From: Fein, Ashden CPT USA SJASent: Wednesda December 22. 2010 7:42 PMTo:Cc: Morrow JoDean. CPT USA SJASubject: RE: Update (US v. BM) Thanks. we are preparing to move into the Mental Competency examination portion. we expectthis to take approximately 4-6 weeks after the new year. The key event that we are nowpreparing for is to have the new charges sworn out against BM by the second week of January.Prior to us doing this, we will need to figure out the number of documents from eachDepartment that we can use. what would be very helpful would be a thumbs up from you that wewill likely have the authority to proceed with the grouping of documents is currentlyreviewing. The formal approval can come later. Also, do you know if any of the documents inthe set we gave you have been released?Thank you. Happy Holidays!AshdenAshden FeinCPT, JAChief, Military lusticeU.S. Army Military District of washington (MON) 02188733From: ?@state.sov>Sent: Thursday, December 23, 2010 I136 PMTo: Fein, Ashden CPT USA SJA Cc: state.gov>; Morrow JoDean, CPT USA JFHQ-Subject: SBU: Update (US v. BM)Enforcement SensitiveHi Ashden.I left you a voicemail. but will be leaving early today and out next week. so wanted to follow up with an email. FYI. I'll haveblackbeny. but not sure what quality coverage I'll have after the 26th.We were working oil? the expectation. based on our last meeting. that your team would plan to announce new charges after the mentalcompetency hearing (rather than before it's completed). which we understood could be as early as end of January. It will be verydifficult for us to get a read from policymakers on the full batch of docs under review before then particularly given heavy holidayabsences in the upcoming week and that we'll be working with a number of regional bureaus. We will keep moving forward on thingshere. but why don't we touch base the first week in January. I don't expect we'll be able make representations about particulardocuments. or the full group. at that time. but we should be able to give you a general reaction from policy leaders and an update onwhere things stand.Based on my review only 6 documents in this group have been publicly released at this time. I'll send- the list on the class side.as 1 don't think I have your class email addresses. He can then pass along to you when he returns -- I think he's scheduled tobe in the office mid-to-late next week.Thanks. and have a and healthy holiday!PS -- Also. I have a new phone number (unlikely to change again in the near future):02889777 From: Fein_ Ashden CPT USA SJASent: Thursda December 23. 2010 1:46 PMTo: ?statagowCc: @state.gov'; MOITOW JoDean, CPT USA SJASubject: Re? Update (US V. BM)-. Thanks. we already left for the holidays as well but I am also available by bb. ourtimeline has accelerated a little bit, but really only by a week or two. The competencyhearing is going to start after the new year and it will hopefully speed up From 6 weeks to 4weeks. we will need to charge before its conclusion, thus by the midle of jan. Sorry for theconfusion. Thank you For your help and happy holidays!AshdenAshden FeinCPT, JA 02888258From: Fein, Ashden CPT USA SJASent: 010 5:24 PMTo: USA OTJAGSubject: Re: still on phone (UNCLASSIFIED)Sir?. _The big step right now is the IA expert and getting everyone theclearnaces. is complete and level is ts/sci-si, hcs, g. They didn't think tk. I havecoombs sf86 and he sent me a signed copy. Please let me know the best way Forward to get allinvolved the right clearances and read-on. Thx. Happy holidays.Ashden FeinCPT, JA02212886From: OTJAG Sent: Monday, December 27, 2010 8:35 AMTo: Fein, Ashden CPT us?. SJA Subject: RE: still on phone (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONEAshden.Below is the information and fomiat that I typically need to process arequest for a civilian defense attomcy. In the case of Coombs. myunderstanding is that he has a SECRET clearance in his reserve capacity.However. even this clearance is only good for granting access toclassi?ed at the SECRET level for work he conducts in his reserveas a civilian defense counsel. Thus we need the wholerequest to initiate the If his national agency and fingerprintchecks come back clean. he may be granted an interim.Regarding his detailed military TDS attorney I need his SSN to run hisstatus in JPAS. if he does not have a current TSSBI thert he will have tocomplete the EQU and submit the request similar to Coombs.Regarding the docs at Walter Reed. 1 need their SSNs as well. They willlikely not have so they will have to submit the too.There is the possibility that the TDS and Docs may be able to processtheir clearance requests through their servicing security offices.However. since they are not in TSSCI billets it likely will be betterfor them to submit the requests through me to the giventhe high level access that they need.Get me the SSNs ASAP and I will get back with you on the process. 1. Follow the procedures in AR 380-67. paragraph 3?404f_ You and MDWTDS will need to contact your supponing security office. This officewill be the central point for issueing the base clearances once inten'mclearances are passed from CCF. (Need to research how HCS and will beprovided. as this has never been needed before.)2. What I need specifically is:a A request memorandum thru the Office of the Judge AdvocateGeneral ATTN: DAJA-IO. Washington D.C. 20310-2212. FOR Deputy Chief ofStaff. G2. Al'l N: DAMI-CIS. Washington. D.C. 20310-1056. SUBJECT: RequestforAccess to Iassi?ed lrtfonnation by a Civilian Attorneyb. The memo needs to statel) Full name of the civilian attomey. includirtg SSN.dateand place of birth. Citizenship.2) Full name of the soldier facing couns-martial. typeofcourts-martial. name and amount of charges/specifications.022128863) Whether the civilian attorney has requested access totheclassi?ed information, the basis for the request and an endorsement bytheStaff Judge Advocate supporting the need to provide access to ensure theaccused is adequately provided legal counsel/representation.4) A statement discussing the relevance of classi?edinfomtation to the charges/courts-martial proceeding. Why. in light ofthe facts of the case. specifically does the civilian defense counselneed access to classifiedinfomtation.5) The level of classified information the civilianattorneyneeds access to SECRET. SECRET NOFORN. TOP SECRET. TOP SECRET(SCI). HCS. G. SI. TK etc.).6) A statement that the civilian attorney will submittheappropriate paperwork (SF 86) for a request for a security clearance. andexecute a DOD Non-Disclosure Agreement.3. Once I receive the signed memorandum from your office I will reviewitand coordinate as necessary. 1 then will forward the request to theDCSINT. G2 for their action. Office of the Jud Advocate General of the Army, Pentagon 3D548NLPR: @.conus.army.miISIPR: .HQDA-S.army.smil.milJWICS: dami.ic.govTel: 02212876From: USA OTJAG _@conus.army.miI]Sent: Monda December 27, 2010 8:54 AMTo: hum clo/G-6Cc: Fein, Ashden CPT USA SJASubject: FW: US v. Manning Requests (UNCLASSIFIED)Signed By: musarmymilFollow Up Flag: Follow upFlag Status: CompletedClassification: UNCLASSIFIEDCaveats: FOUO Could you please give me a status update on the identifying a SME inthe ManningCase?Thanks Office of the Jud Advocate General of the Army, Pentagon 3D548NIPR: @conus.army.mi1SIPR: @HQDA?S.army.smi1.milJHICS: ami.ic.govTel: 02885440 From. Fein, Ashden CPT USA SJASent: a mber 29.2010 7:55 AMTo: IV DISA PEO-MACc: IV cw USA USACIDC:Mr CIV US USA USACIDC: Morrow JoDean. CPT USA SJASubject: US v. BM (wiki)unponance: Good morning. I am the lead prosecutor for the wiki case of US v. PFC Manning. Theprosecution team, along with US Army CID, would like to schedule a meeting with you todiscuss the analysis your team conducted through the DISA web audit. we would like to meetASAP and will likely have Department of Justice attorneys joining us during the meeting. Areyou available this week or very early next week? Thank you.v/rCPT FeinAshden Feincpr, JAChief, Military JusticeU.S. Army Military District of Washington (MON)02888244From: Fein, Ashden CPT USA SJASent: Wednesda December 29. 2010 8:32 AMTo: hum omc;Cc: Morrow JoDean, CPT USA SJASubject: RE: still on phone (UNCLASSIFIED)hnponance: Sir,Below are our current names For those required access For over andindoctrination. My best guess on what levels each are currently clearedand/or read-on is in parenthesis next to their SSN. If its easier, I couldhave our security manager run everyone's SSN and then we could produce alist of those that need G2 assistance for expeditious processing and thosethat don't.Thanks.Ashden02884511From: Fein, Ashden CPT USA SJASent: ecember 29, 2010 10:30 AMTo: @iraq.centcom.miICc: Morrow JoDean, CPT USA Subject: US v. PFC Manning RFIhnponance: l?ghSir,Good afternoon. I am the lead prosecutor for US v. PFC Manning (wiki). we received a copyof the USF-I 15-6 investigation which was approved by M6 Garrett on 23 Aug 10. The versionwe received, along with the Secretary of the Army (SA) 15-6 team, is classified although the majority of the information appears to be UNCLASSIFIED.Is it possible for us to receive an UNCLASSIFIED version of the 15-6? If some of the pagesand/or enclosures are classified, it makes sense that we will have to keep those on SIPR, butif the majority is unclassified it will allow us to keep it as part of the normal court-martial process (unclassified discovery) and the SA investigators to use it as part of theirfindings and recommendations.Eventually during the court-martial process, we will be required to identify what isclassified or not, and then grant the authority for the defense team to have access. Thisrequest would streamline that process and hopefully include personnel that were part of theoriginal investigation, versus trying to complete this task months down the road.If possible, then please re?scan the UNCLASSIFIED version using a high resolution (366dpi) sothat we can reproduce it in the future.If this needs to be a more formal request, please let me know. Thank you.v/rCPT Fein02884511FcinCPT, JAChieF, Military justiceU.S. Army Military District of Washington (MDN) 02884505From: Fein, Ashden CPT USA SJASent: ecember 29. 2010 10:33 AMTo: iraq.centcom.mi|Cc: Morrow m, JoDean. CPT USA sJA;Eiraq.centcom.mirSubject: US v. PFC Manning RFIImportance: HighSir,Good afternoon. I am the lead prosecutor for US v. PFC Manning (wiki). wereceived a copy of the USF-I 1S-6 investigation which was approved by M6Garrett on 23 Aug 16. The version we received, along with the Secretary ofthe Army (SA) 15-6 team, is classified although the majority of theinformation appears to be UNCLASSIFIED.Is it possible for us to receive an UNCLASSIFIED version of the 15-6? Ifsome of the pages and/or enclosures are classified, it makes sense that wewill have to keep those on SIPR, but if the majority is unclassified it willallow us to keep it as part of the normal court-martial process(unclassified discovery) and the SA investigators to use it as part of theirfindings and recommendations.Eventually during the court-martial process, we will be required to identifywhat is classified or not, and then grant the authority for the defense teamto have access. This request would streamline that process and hopefullyinclude personnel that were part of the original investigation, versustrying to complete this task months down the road.If possible, then please re-scan the UNCLASSIFIED version using a highresolution (30edpi) so that we can reproduce it in the future.If this needs to be a more formal request, please let me know. Thank you.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (Mow) 02893209From: Fein. Ashden CPT USA SJASent: Wednesday, December 29, 2010 10:35 AMTo: May?eld, David A Mr CIV USA OTJAGSubject: PCR ResultsAttachments: Review Results (ManningB).pdfSir. I realized that we did not send this to you. It will be an enclosure to the Formalrequest for clearances.Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDW)Z-Z:I 02212869From: USA OTJAG Sent: Wednesday, December 29, 2010 I 1:57 AMTo: Fein, Ashden CPT USA SJA Subject: RE: PCR Results (UNCLASSIFIED)Classi?cation: Caveats: NONEThanks,I am working on this with the G2 Will let you know the next steps. ()f?ce of the Jud Advocate General of the Ann)?. Pentagon 3D548SIPR: @l smilmilCic. govTel02185139From: USA _@us.army.miI]Sent: Wednesday, December 29, 2010 4:14 PMTo: Fein, Ashden CPT USA Morrow JoDean, CPT USA SJACc: qus USA USACIDCSubject: Re: Interview with - Thursday. 30-Dec-2010 1330 (UNCLASSIFIED)Follow Up Flag: Follow upCommaaiClassification: UNCLASSIFIEDCaveats: ENFORCEMENT SENSITIVECPT FEIN and CPT MORRON,As I understand it, you?ll be meeting with the 15-6 Team tomorrow in the morning. Theinterview oF?is scheduled for 1330, and we?ll be meeting him at his place of worklocated at either 4550 Parade Field Lane 4550 LlewellynAvenue I am going to assume its building 4550 on the corner of Parade Field and Llewellyn).?advised it is right in front of the giant Flagpole (1st Army Division east) and nextto 902nd MI Headquarters. I need to check up on some things going on at Fort Meade(unrelated to this investigation) and I?ll meet you there about 1315. -advised thatone of us can give him a call when we arrive and he?ll have to figure out if we?ll needbadges to go to whatever space he has identified For us to use. His numbers are:Let me know if anything comes up. Washington Metro Resident AgencyComputer Crime Investigative Unit (CCIU)U.S. Army Criminal Investigation Command (USACIDC)9805 Lowen Road, Building 193Fort Belvoir, VA 22060 02185139 Email: us.army.mil Heb: THIS EMAIL MAY CONTAIN LAW ENFORCEMENT SENSITIVE INFORMATION.NOTICE: This E?mail (including attachments) is covered by the Electronic CommunicationsPrivacy Act, 18 USC 2519-2521, is confidential, and may be legally privileged. If you are notthe intended recipient, you are hereby notified that any retention, dissemination,distribution, or copying of this communication is strictly prohibited and may be unlawful.Please reply to the sender that you have received the message in error and then delete themessage and any attachments.Classification: UNCLASSIFIEDCaveats: ENFORCEMENT SENSITIVE02185109From:Sent:To:Cc:Subject:USA Thursday, December 30, 2010 l2:04 PMFein, Ashden CPT USA JFHQ-SJA Morrow Ill, JoDean, CPT USASJA USAVAE) usdo'. ov>'@ic.fbi.gov>; ,ic.fbi.gov>Affidavit issues (UNCLASSIFIED) Classi?cation: UNCLASSIFIEDCaveats: OUOConcerning the CD with the red SECERT sticker on it. That CD containeda copy of the CZ ENGAGEMENT ZONE 30 GC.wm\' apache air strikemovie on it. A mac computer was used to burn the CD.Digital Forensics and Research BranchComputer rime Investigative Unit193. 9805 Lowcn RoadFon Belvoir. VA 22060 . 0221 5646From: Sent: Thursday, December 30, 2010 12:07 PMTo: Fein, Ashden CPT USA SJA Cc: Morrow Ill, JoDean, CPT USA SJAMatthew kemkes Subject: . . . MotionAttach: MRE 505(h)(i) MotionpdfAshden - Joe,I have attached a motion outlining the defense's position on the requirement for a 505(h)(1) disclosure forthe 706 board. I know that you are being told that such a disclosure is not required. I thought a motionfrom the defense detailing our understanding of the controlling authorities might be helpful.If the individuals advising you on this issue still believe that a 505(h)(1) disclosure is not required, couldyou please ask them to point to the authority that they are relying upon? This information would assistthe defense in deciding how to handle this issue.I hope your holiday break is going well. Feel free to call me if you have any questions based upon themotion.Best.DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02910361From: Fein, Ashden CPT USA SJASent: Sunday. January 02, 2011 9:27 PMTo: USA USCENTCOM Cc: Morrow Ill, JoDean. CPT USA SJASubject: Apache VideoSir. Happy New Years! Thank you For all your assistance in 2616 and now the rodeo continuesinto 2611. Is there a way to receive an UNCLAS version of the apache video classificationreview so that we can disclose this to the defense? we need to let them know and thedocument is Thank you.v/rAshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of washington (Mow)02901388From: Fein, Ashden CPT USA SJATo: USA OTJAGCc: Morrow JoDean. CPT USA SJASubject: Happy New Year 8. ClearancesSir.Happy New year. The fun continues in ?11. Any update on the clearances? I would really liketo get the formal request For all personnel up to you by the middle of the week so we canstart moving. There is also a chance that Joe and I will be heading to Ft Drum this week forinterviews. Also, we still have not heard back from the IA section about an expert.Thanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON)02898574From: Fein, Ashden CPT USA SJASent: Monday, Januaty 03. 2011 10:56 AMTo: Cc: Morrow HI. JoDean, CPT USA JFHQ-NCRIMDW Matthew kemkes;Subject: Ho|nonDavid,Thank you. Although I did not respond sooner, we are working this issue concurrently withgetting everyone the requisite clearances. You should have also received through the US MailPFC Manning's medical records. Please confirm the receipt over email.Happy New Year!AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 02907527From: Fein, Ashden CPT USA SJASent: Tuesda Janua 04 2011 11:48 PMTo: ?um omeSubject: Chat tomorrowhnponance: Sir. Are you available tomorrow to chatDrum this week conductinginterviews but I am available by 88. would like to chat about the following four issues:1. Clearances2. OCA reviews for D00 info3. IA expert4. New issue: Defense 796 analysisThanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of washington (MDN)02215641From: Sent: Wednesday, January 5, 201 1 3:08 PMTo: Fein, Ashden CPT USA SJAMorrow Ill, JoDean, CPT USA JFHQ-Cc: Matthew kemkes Paul BouchardSubject: Con?nement Conditions of PFC Manning,Attach: Con?nement Memorandumpdf CWO4 Averhart,Please see the attached memorandum requesting that you change PFC Manning's current classificationand assignment. I would appreciate a response to my memorandum by 12 Jan. 2011. If you have anyquestions, feel free to contact me.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02215640From: Sent: Wednesday, January 5, 201 3:16 PMTo: Fein, Ashden CPT USA SJA Morrow JoDean, CPT USA SJACc: Matthew kemkes Paul BouchardSubject: 1) DisclosureAshden,I know you said you are working this issue. Can you tell me if the government's position is still that a 505disclosure is not required for the 706 board? I need to know this because I am exploring raisingthis issue as a writ to ACCA. I would like to try to resolve this issue before the start of the 706.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02910890From: Fein. Ashden CPT USA SJASent: Wednesday, January 05. 2011 10:56 PMTo: Morrow Ill, JoDean. CPT USA SJACc: Matthew kemkes; Paul BouchandSubject: RE: 505(h)(1) DisclosureSir,The prosecution team's position is that the Accused's discussion of his own classifiedthoughts during his RCM 796 board is not deemed a disclosure For purposes under MRE505(h)(1). we are still waiting on our technical higher?s re-concurrence oF our analysis.our plan is to provide you with our full analysis of the issue and then we move forward.This is being worked concurrently with obtaining the clearances For you and all otherparticipants. we are also Following-up with Quantico Brig on your written request and stillFinding the IA expert.v/rAshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 0221 5638From: Sent: Wednesday, January 5, 20ll 11:35 PMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Paul BouchardMorrow JoDean, CPT USA Subject: RE: 505(h)(l) DisclosureAshden,Thank you for the update. I will coordinate with DAD on the writ issue. For timing purposes, I would liketo have your written response and then ?le the writ on the same day. Give me a heads up when youexpect the written response to come my way.Also, I am working on the replacement forensic for the defense team. I spoke with COLMalone today. He had a couple of suggestions for a suitable replacement to COL Benedek in the MDWarea. I will hopefully have a name to submit to you sometime either this or early next week.Finally, I am hoping that my written request to the Brig will help move the con?nement issue forward. Ifnot, I will submit a motion to the CA next week. Please keep me posted if you have any luck with CWO4Averhait.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02212853From: USA OTJAG _@conusranny.mil>Sent: Thursday, January 6, 20] 1 1:18 AMTo: Fein, Ashden CPT USA SJA Subject: RE: Chat tomorrow (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONElam back in the office and ready to discuss. Sorry. but I had to takeleave. I am working on the clearance issue. I will send the speci?cclearance way ahead to you by COB today. Office of the Jud Advocate General of the Army, Pentagon 3D548milJWICS: ?71dami.ic.gov 02188730From ?@state.gov>Sent: Thursday, January 6, 20! 6:34 PMTo: Fein, Ashden CPT USA SJA Morrow .loDean, CPT USA SJA cc: Subject: Call tomorrow?Ashden and Joe,Do you have a few minutes tomorrow for a call to discuss a few issues that we've come across with the documentreview?- and I are both free tomorrow afternoon.It might be helpful for us to send you a few samples of what the cables would look like in redacted form on the highside. I understand that you might be on the road this week. Do you happen to have SIPR access?ThankslU.S. Deiartment of StateSBUThis email is 02907521From: Fein, Ashden CPT USA SJAsent: Thursda Janua 06 2011 11:49 PMTo: ?usnx OTJAGSubject: Re: Chat tomorrow (UNCLASSIFIED)Sir. Thanks. Absent being snowed in, we should be back in the A0 tomorrow late afternoon. wewill need to get the clearances through ASAP.Ashden FeinCPT, JA02893017From: Fein. Ashden CPT USA SJASent To: USA OTJAGCc: Morrow JoDean, CPT USA SJASubject: Phone MeetingSir. Can we schedule a phone meeting tomorrow (Monday) anytime after 1266? we would like todiscuss the below topics:1. IA Expert Request2. Clearances3. OCA Reviews for Info4. Classification Review by CENTCOM for Apache video5. DeFense?s RCM 796 analysis based on classified informationThanks.AshdenAshden FeinCDT, JAChief, Military JusticeU.S. Army Military District of Washington (MON)Z-1?1 02184969From:Sent:To:Cc:Subject:Attachments:Signed By:Importance:Follow Up Flag:Flag Status:CIV USA USACIDC ?@us.army.mil]Sunday, January 09, 2011 9:00 PM- - Fein, Ashden CPT USA SJACCIU - 701st OPS -Morrow JoDean, CPT USA SJACCIU review of documents requested for release to 15-6 Team15-6 Document us.army.mi|HighFollow upCompletedCCIU has completed its review of the documents requested by? For release tothe 15-6 team.Attached is a spreadsheet, which identifies those documents which CCIU doesnot recommend releasing to the 15-6 team.IF you require further clarification on any documents we will be available 24/7 to expediteany inquiries.v/r2 Washington Metro Resident AgencyComputer Crime Investigative Unit193, 9865 Lowen RoadFort Belvoir, VA 22660(W)(F)(C) us.army.smi1.mil02212845From: A OTJAG @conus army.mi1>Sent: Monday, January 10, 2011 4:42 PMTo: Fein, Ashden CPT USA SJA Subject: Security Clearances (UNCLASSIFIED)Attach:Request for Military Personnel Access (ManningB).doc; Request for Civilian AttorneyAccess (ManningB).docClassi?cation: UNCLASSIFIEDCaveats: NONEAshden.Attached are two request memos for completion One if for Coombs and theother is for all of the military personnel. I am going to get you asecurity office POC to process these clearances and accesses. Shouldhave the phone number tomorrow. Office of the Judge Advocate General of the Anny. Pentagon TID548NIPR: .miIrdami .ic. gov Tcl:Classi?cation: UNCLASSIFIEDCaveats: NONE02903550 From: Fein, Ashden CPT USA SJASent: 11 5:31 PMTo: USA OTJAGCc: USA USA JFHQ-Morrow MIL USA rmooc:ILUSATRADOCSubject: Document ReleaseAttachments: 15-6 Document ReIease.pdfhnponance: l?ghSir,Attached is the spreadsheet of the law enforcement and prosecution review of the Exhibitslist. The AR 15-6 investigators have a green light for the majority of the documentation.The items marked with a yellow are documents in which we will redact specific informationprior to release to the AR 15-6 investigative team. The items marked with a red aredocuments that we will not release because either its content or disclosure of its existencewill directly affect the ongoing criminal investigation (military and civilian) and thecriminal prosecutions.we will work to provide all the releasable documents ASAP.Earlier today, I sent the below but I do not think you received the email.As of today, law enforcement and the prosecution team consider no person still in Categorytherefore the investigative team should feel free to interview all those we originallyfenced. However, we would still like the maintain the ability to interview any remainingwitnesses first before the 15-6 investigators conduct their interviews.CID is working to get the contact information of those not at Ft Drum so that we can conductphone or in?person interviews of the remaining individuals. If there are additionalwitnesses, please have the investigators send us those names, so that we can analyze theirpotential effect on the law enforcement investigation and prosecution. we will work toconduct those interviews this week.v/rAshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN) 0221 5633From: Sent: Monday, January 10, 201 1 10:37 PMTo: Fein, Ashden CPT USA SJA Morrow JoDean, CPT USA IF SJACc: Matthew kemkes Paul BouchardSubject: Supplemental Discovery RequestAttach: Discovery Request - 10 Jan ll.pdfAshden,Here is a supplemental discovery request. Also, I was wondering when you thought you would beresponding to the 505 issue. I would like to have an idea on the time line in order to coordinatewith DAD. Feel free to call if you have any questions.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02223597From:Sent:To:Cc:Subject:Wednesday, January I2, 201] 11:55 AMUSA OTJAG -SA HQDA ITA ESS- us.army.mil>Fein, Ashden CPT USA SJ A US vs Manning Defense Team support (UNCLASSIFIED) Classi?cation: UNCLASSIFIEDCaveats: FOUOThis morning I discussed your requirement with Director of the Enterprise Security Services - Pemagon (ESS-P). and we tried to bring you in on a conference call. but your line went to voice messaging.We believe that?has an Information Assurance Subject Matter Expert on his staff that can support the Defense team.The only issue is to formally get an official tasking down through the tasking system toorganization. As I indicatedpncviously. ESS-P a element of the Information Technology Agency with is under the Administrative Assistant to the Secretary of theArmy. so the request would have to go to the Admin Assistant's office. O?icc of InfomtationAssurance and ComplianceSN-Classi?cationz UNCLASSIFIEDCaveats: FOUO02215629From: Sent: Wednesday, January 12, 201 12:06 PMTo: Fein, Ashden CPT USA SJA Morrow Ill, JoDean, CPT USA IF Cc: Matthew kemkes Paul BouchardSubject: Forensic stAttach: Forensic st Ashden,I wanted to let you know that I found a replacement for COL Benedek. The defense would like Capt.Kevin Moore to be assigned to the defense team. Capt. Moore just from Japan, and has not had achance to send me a CV. Do you need a CV, or will the attached request suffice?Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02902036From: Fein, Ashden CPT USA SJASent: Wednesday, Januaty 12, 2011 3:05 PMTo: Morrow JoDean. CPT USA SJACc: Matthew kemkes; Paul Bouchard; Car1iIe. Monica L. SFC USA SJASubject: RE: Forensic David,Thanks. we are swiftly moving on this by chatting with his leadership, to ensure there is noimpact. Also, I would like to introduce over email, SFC Monica Carlile (CCed) who is a newaddition to our team. Although SGT Zimmerman could never be replaced, SFC Carlile is goingto provide us paralegal support. Please include her on your emails to me and Joe. Ihankyou.AshdenAshden FeinCPT, JAChieF, Military JusticeU.S. Army Military District of Washington (MOW) 02215618From: Sent: Thursday, January 13, 20l 1l:5l AMTo: Fein, Ashden CPT USA Morrow JoDean, CPT USA JASJASubject: 30S(g) RequestAttach: 30S(g) Request - Military Magistrate's MFR.pdf; Quantico Brig MFR.pdf;Manning - Speedy Trial Request.pdfAshden,I have attached the renewed speedy trial request listing the Garrison commander instead of the GCMCA. Ihave also attached a request for release from confinement under R.C.M. 305(g) along with enclosures.As mentioned before, the defense believes that there is no legitimate government objective for the currentconfinement conditions. Given the consistent recommendations of Capt. Hocter and PFC Manning's modelbehavior, there is no justi?cation for PFC Manning to continue to be held in maximum custody and underPOI watch. Please present this request to the Garrison commander.The defense requests that the government respond in writing to the 305(g) request. Additionally, thedefense requests that to government obtain the requested documentation in the 5 January 2011memorandum to CWO4 Averhart, and any other supporting documentation from the Quantico Brigconcerning PFC Manning's classi?cation and assignment. The defense request that government providethis documentation to the defense.Please feel free to contact me if you have any questions or concerns.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Direct Dial: (401) 744-3007Office: (508) 674-6006Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02885280From: Fein, Ashden CPT USA SJAsent: 11 708 PMTo: USA OTJAGCc: Mon'ow Ill, JoDean. CPT USA SJASubject: US v. ManningAttachments: 11-Jan-13-Request Personnel Clearance and Access 11-Jan-13-Request Civilian Attorney Clearance and Access (ManningB).pdfSir,Attached are the clearance requests. we reduced the request by 1 because Capt Hocter willnot be his provider. As we have discussed over the past month, we request expeditedprocessing of all these individuals so that our case can keep moving forward. Thank you foryour preliminary work to get the right players in place and set the stage to get theseprocessed.v/rCPT FeinAshden FeinCPT, Chief, Military JusticeU.S. Army Military District of washington (MDN)02901080From: Fein, Ashden CPT USA SJASun: 11720PMTo: USA OTJAGCc: Morrow Ill, JoDean. CPT USA SJASubject: IA ExpertSir. Sorry to bombard your email tonight, but if its possible to the get the IA expert?sname by 1100 tomorrow, then we will be able to take it to the convening authority. Thanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (Mow)02212835From: OTJAG Sent: Friday, January 14, 20] 1 7:56 AMTo: Fein, Ashden CPT USA SJA Subject: RE: Expert (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONESent the name last night. O?ice of the Judge Advocate General of the Army. Pentagon 3D548mi.ic.gov 02212825From: USA OTJAG Sent: Friday, January 14, 2011 12:34 PMTo: Fein, Ashden CPT USA SJA Subject: RE: Draft Response (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUOBelow is the email on the IA SME.Classi?cation: UNCLASSIFIEDCaveats: FOUOGents.Please see below for the IA SME contact infomiation Please contact herandprovide any admin guidance for her to become pan of the defense team. NIPR: SIPR: .smiI.milJWI s: ?i)danii.ic.govTel From: IV USA HQDA ITA ESS-PSen? 3.2011 3223 PMTo" Mr CIV USA OTJAGsubject: arming Defense Team support (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUO USA HQDA ITA ESS-Pinal Messa Fromzi?v USA omcSent: Thu Januarv 13. 2011 3:22 PMTo lV USA HQDA ITA ESS-PSubject: RE: US vs Manning Defense Team support (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUOThe location is here in the DC area. Not sure where the defense learn ismeeting. TS SCI is just what may be needed.Please let me know when she is infomied and pass me her telephone02212825number.Thanks for your assistance. NIPR: @.conus.arIny.mi]SIPR: QHQDA-S.army.smi1.milJWICS: dami.ic.govTel:inal Messa From: lV USA HQDA ITA ESS-PSent: Thursday, January 13. 2011 Subject: RE: US vs Manning Defense Team support (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: OUOTSI SCI. I have not told her yet and will tell her when she returns fromameeting. do we have any anticipated timeline for this and length? Howaboutcation?11 mal Messa From: CIV USA OTJAGSen'Th 13,2011 USA HQDA ITA USA HQDA ITASubject: RE: US vs Manning Defense Team support (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUO-and:Per below need to coordinate the detailing 0- as an IASMEto the defense team in the c/in case of U.S. v. PFC Bradley Mamting. Myproposal is that we provide her name and contact infonnation to the MDWprosecution team as they need to facilitate her detail to the defenseteam.One question I have is does Ms-have a security Clearance and ifso.what level of access does she currently possess?Thanks for your assistance with this matter. @conus.army .milQHQDA-S.army.smil.mildami.ic. gov02212825 MIL USA OAA . .20l|l|:34AMTo CIV USA OTJAGCc: USA ooc;USAEiom ITA USA CIV USA HQDA ITASubject: RE: US vs Manning Defeme Team suppon (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUOWe have the expertise and are prepared to support this tasking. Ourlnfomiation Technology Agency. Enterprise Security Services - Pentagonhasidentified Ms. as the IA SME. Please coordinate thisdmy - 2 or Mr. 2 ?at:Executive Officer to theAdministrative Assistant to the Secretary of the AnnylActing Deputy Under Secretary of the Anny Pentagon TIE733fc: T.conus.a1my.milmilmi.ic. govFrom: Fein. Ashden CPT USA SJAlmailto.Sen" 4. 2011 I227 PMTo: Mr CIV USA Mono?. JoDean. CPT USASJACc: Haberland. John CPT MIL USASubject: RE: Draft Response (UNCLASSIFIED)Sir. Thanks. If its ok with you. can we chat later. We areinterviewingwitnesses right now. Also. could you please send the Unit of AssignmentforMs. I still never received your emails.Ashden FeinCPT. JA02212825Chief. Military JusticeU.S. Anny Militan District of Washington (MDW) inal Mcssa CIV USA OTJAGSent" Friday. January I4. 2()ll 12:08 PMTo: FcirL CPT USA Monow Ill. JoDean. CPT USASJACc: Habcrland. John CPT MIL USASubject: RE: Draft Response (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NOMELet?s talk about this. Not sure we want to address the need-to-know Iaccess issue. The policy R0 13526. 5200.1-R and AR 380-5 are allover the map on this issue. milMessage?-?--From: Fcin. USA JFH SJA OTJAG: Morrow Ill. JoDcan. CPT USASJACc: Haberland. John CPT MIL USASubject: Draft ResponseSir. Attached is Joe's draft response. We would like you to review andcomment. Also. please focus on the "Need to Know" paragraph. Thanks.Fein02212825CPT. JAChief. Military JusticeUS. Anny of Washington (MDW) Classi?cation: Caveats: NONEClassi?cation: UNCLASSIFIEDCaveats: FOUO02902832 From: Fein, Ashden CPT USA SJASentTo:Cc: orrow II, JoDean. CPT USA JFHO-uaagovSubject: Fw: EmaulCould one of you make it up to McLean tomorrow afternoon to pickup the new evidence fromPlease see below.AshdenAshden FeinCPT, JAChief, Military Justice 02215598From: Sent: Wednesday, January 19, 20l 12:53 PMTo: Fein, Ashden CPT USA SJA -Matthew kemkes Morrow Ill, JoDean, PT SJACarlile, Monica L. SFC USA JFHQ- Subject: Con?nement ConditionsAttach: Preserve Evidence Request. Ashden,Please see the attached request to preserve evidence. I would like to talk to you about this issue latertoday if possible. I am available anytime after 1630. Also, I want to know if the garrison commanderplans to respond to my 305(g) request. Based upon this latest incident, I am inclined to push forwardwith the 138 complaint. Thanks.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02885381From: Fem, Ashden CPT USA SJASent: Wednesday, January 19. 2011 6:12 PMTo: Kemkes. Matthew MAJ MIL USACc: 'HaberIand. John CPT MIL Canile, Monica L. SFC USA SJASubject: US v. BM UpdateMAJ It is our understanding that you might have met with the Brig OIC. If you?re willing todiscuss, could you please let us know if there is any resolution ?rom your meeting. Thankyou.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (Mow)02215595From: Sent: Wednesday, January 19, 201 9:17 PM Cc: Fein, Ashden CPT USA SJA. Morrow JoDean, CPT USA JFHQ-Matthew kemkesPaul Bouchard Subject: Article 138 ComplaintAttach: Article 138 Complaint - Sir,Please see the attached Article 138 complaint. The defense requests that you address this issue as soonas possible. If you have any questions, feel free to call me at (401) 744-3007.Respectfully,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02905596From: Fein, Ashden CPT USA SJASent: Thursday, January 20, 2011 8:00 PMTo: Cc: Matthew kemkes; Morrow Ill, JoDean. CPT USA JFHQ-an e, omca . Subject: e: on memen on sonsDavid. Just to reemphasize one point from our conversation tonight, we do not necessarilysupport your press release and the prosecution would prefer to handle this issue through thenormal pretrial process with the chain of command, as we are currently doing.Thanks.AshdenAshden FeinCPT, JAFrom: To: Fein, Ashden CPT USA SJAcc= Matthew ?emkes: all in JoDean, CPT USA Carlile, Monica L. SFC USA JohnHaberlana Sent: Thu Jan 20 16:07:58 2011Subject: RE: Confinement ConditionsAshden,I spoke with the confinement facility this afternoon. They told me that he was being removedfrom suicide risk. I appreciate the fact that you and John took agressive steps to addressthis issue. Now we need to get PFC Manning off of POI watch. Hopefully, the Article 138compliant, the R.C.M. 30S(g) request or the pending change of command at the Brig willaddress this issue. I intend to release the attached statement on my blog. However, Iwanted to see if you had any heartburn over anything in the statement.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 62720Office: 1-860-588-4156Fax: (508) 324-989602905596Notice: This transmission, including attachments, may contain confidentialattorney-client information and is intended for the person(s) or company named. If you arenot the intended recipient, please notify the sender and delete all copies. Unauthorizeddisclosure, copying or use of this information may be unlawful and is Original Message Subject: RE: Confinement ConditionsFrom: "Fein, Ashden CPT USA Date: Thu, January 29, 2611 3:37 pmTo: "John Haberland" "Morrow JoDean, CPT USA"Carlile,Monica L. SFC USA David. As of 1512hrs, PFC Manning is off suicide prevention status, butstill on POI. we are working with PFC Manning's chain of command and theBrig chain of command on all your points below, to include readdressing thePOI status.we also expect to formally present the RCM 365(g) request to COL Coffmantomorrow. In addition to the RCM 365(g) request, we will formally readdressthe POI status with him as well. COL Coffman is sending down his CSM to meetwith PFC Manning and get a sense of the situation. we are still waiting onreceiving all the substantiating documentation from the Brig and expect toget that information tomorrow morning and then present it to him tomorrowevening, absent an unforeseen change of events.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDH) ?-?-?Original From: Sent: Thursday, January 26, 2611 12:21 PMTo: Fein, Ashden CPT USA John HaberlandCc: Matthew kemkes; Morrow JoDean, CPTUSA Carlile, Monica L. SFC USA SJASubject: Confinement ConditionsAshden,02905596I understand that CNO4 Averhart is going to review the need for specialrestrictions later today. As I stated yesterday and in the 138 request, PFCManning does not need to be under POI watch or suicide risk. Please haveJohn request CWO4 Averhart to discuss this issue with COL Malone (Capt.Hocter's replacement). If his recommendation is to still remove him fromPOI, then I request that this be done today.If CWO4 will not remove PFC Manning from suicide risk and POI watch, can youtell me whether the goverment is considering moving PFC Manning to adifferent confinement facility? Thank you.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 62726Office: 1-860-588-4156Fax: (508) 324-9896?**Confidentiality Notice: This transmission, including attachments, maycontain confidential attorney?client information and is intended for theperson(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying oruse of this information may be unlawful and is -- Original Message Subject: RE: Confinement ConditionsFrom: "Fein, Ashden CPT USA Date: Wed, January 19, 2911 1:20 pmTo: Cc: "Matthew kemkes" 3"Morrow 3oDean, CPT USA"C3P1i1e,Monica L. SFC USA David,Lets plan on 1760. That should be enough time for us to contact theBrig inorder to understand what occurred today.AshdenAshden Fein02905596CPT, JAChief, Military JusticeU.S. Arm Militar District of washin ton MDW) From: Sent: Wednesday, January 19, 2911 12:53 PMTo: Fein, Ashden CPT USA SJACc: Matthew kemkes; .mil; Morrow JoDean, CPTUSA Carlile, Monica L. SFC USA SJASubject: Confinement ConditionsAshden,Please see the attached request to preserve evidence. I would like totalkto you about this issue later today if possible. I am availableanytimeafter 1636. Also, I want to know if the garrison commander plans torespondto my 305(g) request. Based upon this latest incident, I am inclinedto pushForward with the 138 complaint. Thanks.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 62729Oftice: 1-890-588-4156Fax: (588) 324-9896Notice: This transmission, including attachments,maycontain confidential attorney?client information and is intended fortheperson(s) or company named. IF you are not the intended recipient,pleasenotify the sender and delete all copies. Unauthorized disclosure,copying oruse of this information may be unlawful and is 0290559602212801From: nusza omc Sent: Friday, January 21, 2011 8:22 AMTo: Fein, Ashden CPT USA SJAMorrow JoDean, CPT USA SJACc: SA DCS G-2 H,us.army.mil>Subject: RE: TS Request (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONEAshden and Joe.Please provide the contact infonnation on all of the persons nequinngclearances or access readons to Mr. Rains. Of?oe of the Judge Advocate General of the Amuy. Pentagon 3D548'_7.conus.anny.mil. .smiI. milWICS a>dami.ic. gov 02887109From: Fein, Ashden CPT USA SJASent: 11 8:29 AMTo: SA DCS G-2Cc: USA Morrow JoDean_ CPT USA Canule. Monica L. SFC USA SJASubject: RE: TS Request (UNCLASSIFIED)Attachments: SF 86 - Importance: High Good morning. Attached is the SF86 from David Coombs, Defense Counsel. Can I schedule aphone call with you this morning so that we can work out the logistics of getting all theinfo you need as fast as possible. Thank you.v/rAshdenAshden Feincpr, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 02203420Carlile, Monica L. SFC USA SJASent: Friday, January 21, 201 I 10:17 AMTo: Cc: Fein, Ashden CPT USA SJA Subject: (UNCLASSIFIED)From:Classi?cation: Caveats: FOUOI am the Paralegal NCO assigned to the prosecuting team in US v. Manning. We need some information from you inorder to get things rolling on your upgrade. I need your city and state of birth, two contact numbers and an AKOemail address if you have one. If not, we will submit both of these addresses to G2 for them to send you links and otherdocumentation needed.V/rSFC CarlileSFC MONICA CARLILEPARALEGAL NCOU.S. Army Military District of Washington (MDVV)I cannot be reached at this office using my Global account. Please be sure to email at: Classi?cation: UNCLASSIFIEDCaveats: FOUO02885460From: Fein, Ashden CPT USA SJASent: Fnday. Janualy 21. 2011 11:13 AMTo: Sweda. Michael Dr CIV USA MEDCOM Cc: Morrow Ill, JoDean. CPT USA coom armycounmama ense.com'; 'Kemkes. Matthew MAJ MIL Canile.Monica L. SFC USA SJASubject: US v. BM (706 Board)hnponance: Dr. Sweda,Good morning. The purpose of this email is to give you an update on the RCM706 For PFC Manning. Although the board is still delayed, we expect theclearance issue to be resolved shortly. The Army G2 is sending emails tothose participants, in the overall CM process, that will need to completeby Monday morning so their clearance approval can be expedited. Asfor the RCM 706 Board, this will only apply to LTC Hemphill, all others havethe appropriate clearance. Once the clearances are approved for interim,then we will schedule a date and time for all those who need to be read-on,to meet in City For their read-on. I plan to give some lead timefor this and we will likely plan early morning or late in the day toaccommodate around work schedules. Once the read-ons are scheduled, then weexpect the Convening Authority to issue a supplemental order for the RCM 786to restart with special instructions.Assuming no critical issues in the remaining members Ianticipate the read-ons to occur the week after next and the RCM 766 tostart again the Following week.If you have any questions, please send them to the entire emaildistribution.Thank you and have a good weekend.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDW) 02203402From_ Carlile, Monica L. SFC USA SJASent: Friday, January 21, 201] 1:38 PMTo: Autry, Carolyn Ms CIV 51" Ce: Fein, Ashden CPT USA SJA Subject: FW: FINGERPRINTS (UNCLASSIFIED) Classi?cation: UNCLASSIFIEDCaveats: FOUOALL.Please see below. CPT Fein would like for it to be completed NLT Wednesday. 26 Feb I l. in orderto keep the process movingswiftly.V/rSFC Carlilel. A requirement prior to initiating your SSBI investigation is having your?ngerprints done in which shows in JPAS a few days later. Can _\ou please goto the nearest Security Office/ local police station to get your?ngerprints done electronically via a Electronic Fingerprint machine Please enter the below information in the Electronic Fingerprint machine inwhich will print out on the ?ngerprint card (FD-258).INFORMATION NEEDED FOR ADDRESS: HQDA ODCS. Ci-2. ARMY PENTAGON. WASHINGTON. DC 20310REASON: clearance upgradeSON: AR00 (AR vcro. zero)SOI: A334Enter in block: (US the letter PM. zero. rero. zero./.ulu)2. If your current organization does not have a Fingerprint machine. one isavailable on Fort Belvoir. VA.NOTE: Please call (703-805-3515) First to ensure that someone is available.9820 FLAGLER RD. BLDG 269. STE G2. RM I2902203402FORT BELVOIR, VA 22060-59293. If you are capability of completing your ?ngerprints at your localpolice station but does not have an "Electronic Fingerprint" machine. pleasemail (FEDEX) the ?ngerprint card (FD-258) to the below address.Send VIA FEDEX (overnight if possible)DEPARTIVIENT OF THE ARMYPSI CENTER OF EXCELLENCEABERDEEN BLVDABERDEEN PROVING GROUND. MD 21005-5001Please inform me of the method that you choose and when it was completed.v/rBONITA DAVISAssistant Security ManagerClassi?cation: UNCLASSIFIEDCaveats: OUO02891872From: Fein, Asnden CPT USA SJASent: Friday. January 21. 2011 8:37 PMTo: Cc: Morrow JoDean, CPT USA SJA: Matthew kemkes;Carine. Momca L. SFC USA- Subject: RCM 305(9) RequestAttachments: Response to RCM 305(9) Request David.Please find the attached RCM 385(g) action. Have a good weekend.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (How) 02215576From: Sent: Saturday, January 22, 201 1 9:07 AMTo: Fein, Ashden CPT USA SJA Subject: Discussion -Ashden,I would like to have a non-attribution discussion with you sometime this weekend. It is my hope that wecould have a rich discussion about the case and a free exchange of ideas. All comments would be off therecord. We would also agree that any comments made would not be repeated in any public forum or toany individual likely to release any statement to a public forum. If you are interested, I think it wouldbest if the discussion was just between us to start.Best,DavidDavid E. Coombs, Esq.Law Of?ce of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896rm rn 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 'o29o37s4From: Fein, Ashden CPT USA SJASent: Saturday. January 22. 2011 12:32 PMTo: Subject: RE: DiscussionDavid,Sounds good. How is 1600 tomorrow (Sunday)? If that is not a good time, I am available anytime after 1680.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (Mow) 02909155From: Fein, Ashden CPT USA SJASent: Tuesday, January 25, 2011 7:16 PMTo: ?Ahnanza.PaufCc: Carlile. Monica L. SFC USA SJA:Matthew kemkes; Morrow Ill. JoDean. CPT USASJA:Subject: Article 32 (PFC Manning)LTC Almanza,Good evening. The purpose of this email is to give you an update on the Article 32 for PFCManning. Although the RCM 766 board is still delayed, we expect the clearance issue to beresolved shortly. with the assistance of the Army 62, we are coordinating to have allforeseeable participants in the overall court-martial process receive clearances andsubsequent read-on's for the required compartments. Your clearance is currently valid andyou just need to be read?on.Read-on's will likely occur in City. I plan to give some lead time for this and wewill likely plan early morning or late in the day to accommodate around work schedules.Assuming no critical issues in the remaining participants I anticipate the read-ons to occur next week and the RCM 706 to start again the following week.IF you have any questions, please send them to the entire email distribution. Also, myoffice added SFC Monica Carlile to the team and she is currently the dedicated paralegal toall issues For this case, including providing you the needed support as the I0. SFC Carlileis CCed on this email.Thank you.V/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 02886266From: Fein, Ashden CPT USA SJASentTo:Cc: orrow 0 an. - MDW Cariile. Monica L. SFC USA JFHQ-SJASubject: Update I hope all is well. Are you available this week for us to give each other an update. If itsbeneficial, we can probably come over or we can just have a phone conference. Thanks.AshdenAshden Feincpr, JAChief, Military JusticeU.S. Army Military District of Nashington (MON) 02886265From: Fein. Ashden CPT USA SJASent: 2011 9:50 PMCc: -CIV Morrow m, JoDean, cm USA carmeMonica L. SFC USA SJASubject: UpdateGents,I am tracking these three outstanding issues. Any updates? Thanks.1. Traceroute paths For data sets2. DISA request for all info on SIPR and collection of information.3. Locate DCGS-A contractors and setup interviews with themAshdenAshden Feincpr, JAChief, Military Justice 02219521From: Alman/.21. P2 Sent: Tuesday. Januan 25. ZUII I l:(H PMTo: Fein. SJA Cc: C:1r|ile_ Momca L. USA SJAcoombs aarmycounmanialdefensecom; Matthew Ill. JODean. CPT USA SJA Subject: Re Article 32 (PFC Manning)i-?cm -lhank sou for keeping me puslcdFol rcud-on. I Ill be on navel fur the MI|ilar_\ Judge-'> Sumruu nc\l ucck I mm be cr. call} Munduxur lute I-nduv next m.-ck I'd be available the tollumng ucck.l.l'L' /\lmun/u02910828From: Fein. Ashden CPT USA SJAWednesday, January 26. 2011 8:47 AM To: CIV USA MEDCOM Cc: Morrow JoDean, CPT USA SJASubject 706 General Questions (PFC Manmng)Good morning. Are you available to discuss the administration of a 706? we are drafting thespecial instructions for PFC Manning's 796 and have logistics questions. I am availableanytime to call. Thank you.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDW)02188722From: ?@state.gov>Sent: Wednesday, January 26, 20] I 9:56 AMTo: Fein Ashden CPT USA JFH SJA @state.gov>Cc: Morrow Ill, JoDean, CPT USA SJACarlile, Monica L. SFC USA JFHQ-ASubject: RE: UpdateAshden,_and I could meet sometime tomorrow morning or on Friday (we're both free most of the day). Happy to haveyou come over here, or do a call if that's easier for you.Thanks!This email is UNCLASSIFIED.02900573From:Sent:To:Cc:Subject:Fein, Ashden CPT USA SJAWednesday, Janualy 26. 2011 5:48 PMus.army.mi; :us.an'ny.miI; Fusarmymil;gmaiI.com; CIV USA DCS -CarIiIe. Monica L. SFC USA SJAFW: Investigation Status Update - Processing, Ticket No. CLR000000084588(UNCLASSIFIED) All. Can you please clarify what exactly you need From? so she can Finalize theprocess? I think we are all confused. According to FedEx (Tracking?z 794346810944), herFingerprint card was delivered to Aberdeen on 24 Jan 11 at 0953 and signed For byThank you.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 02232112From:Sent:To:Cc:Subject: @.us.army.mi|>Thutsday, lanuaiy 27. 201! 7: I9 AMl-?ein. Ashden USA JFH SJA wgmailcom; TC MIL USA MEDCOM BAMCg_L.us.army mi Carlile. Monica L. SFC USA SJAil>' Mr CIV USA DCS C-2(3-2RE: Investigation Status Update - Processing. Ticket No. CLR00O0O0084S88(UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONEfioiThe requirement is good - the print check completed _\esterda_\ and posted to JCAVS. The on!) requirement uc still needIS to make some con'cctioiLs to the and release back to the (if not alread} done - APG has aopening until I000 tltis morning so I aim see if the nets c?QlP is read) to re\ ic\\ pet). The next c?QlP will also require newsignature pages that match the investigation ntiinbcrIf you an} other please let me lmoxt Som for the confusion the below e-mail.Personnel SCCul'll_\ InvestigationCenter of ExcellenceVOICC Comm:?/ DSN--Fa\' Comm: -1 DSN: 02907611From: Fein, Ashden CPT USA SJASent: 11 8:08 AMTo: USA OTJAGCc: Morrow Ill, JoDean. CPT USA SJASubject: ChatSir. Are you available to chat today on the following topics and anything else:2. Clearances (update From us)3. OCA Reviews For Info (update both ways)4. Classification Review by CENTCOM for Apache video (update by you) Thanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (Mow)0290761102215561From: Sent: Friday, January 28, 201 I 9:03 AMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Carlile, Monica L. A JFH -NC DW SJAHaberland.John CPT MIL USASubject: Update Ashden,I wanted to touch base with you on a couple of issues:1) Are there any issues with the 11 February 2011 transport of PFC Manning to Fort Myer?2) Has LTC Greer (Quantico SJA) released the requested Brig documents concerning PFC Manning'sclassification and assignment to you? He indicated that they were doing so.3) Have you heard anything regarding the Article 138 complaint?4) Is there an investigation into why CWO4 Averhart placed PFC Manning on suicide risk? If so, can youupdate me on the status?5) Where do we stand on the 505(h) issue for the 706 board?Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02911734From: Fein. Ashden CPT USA SJASent: 11 10:26 AMTo: 25ID SJACc: Cariile. Monica L. SFC USA SJASubject: FW: (U) TrackingImportance: HighChief,Good afternoon! 00 you know if your SSO will be able to conduct the read-on in the next 3days, if they coordinated directly without Directive from Army 62? Also, could you pleasehave the SSO send the Code" to us before the end of the day, because we have to provideit to the Army 62, even if the division S50 is going to execute without directive. Thankyou!CPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 02886251From: Fein, Ashden CPT USA SJASent: Monday, Januaty 31. 2011 10:03 PMTo: Cc: Matthew kemkes; Canile, Monica L. SFC USA HaberIand.John CPTMIL USA:Subject: RE: Updathnponance: David,As of today, all members of the RCM 766 are read-on to the required compartments and below isa status of the Defense team members:Coombs-scheduling local read-on or in DC Kemkes-Complete Bouchard-scheduling read-on intheater Ganiels-Complete Hall-Complete Moore?Complete Smith-?Need SSN and full nameIn addition, Malone and Alamanza are good. Tomorrow we are going to start coordinating re-starting the RCM 766, with the understanding that the Board will not meet with the accusedprior to you being read-on and having the ability to meet with your client first.1) Are there any issues with the 11 February 2011 transport of PFC Manning to Fort Myer?This transportation is lined up. Assuming you are read-on by then, are you going to want tomeet with your client in a SCIF during that trip?2) Has LTC Greer (Quantico SJA) released the requested Brig documents concerning PFCManning's classification and assignment to you? PFC Manning's command received the documentsthey requested in order to better understand the POI status and make recommendations to theBrig on the POI status. The is involved in ensuring PFC Manning is being properly takencare of and ensuring the Brig provides adequate care, safety, and security for PFC Manning.As you should already know, since PFC Manning's confinement, his chain of command visitspractically every week to ensure he is doing well, including the new garrison CSM in the past19 days.3) Have you heard anything regarding the Article 138 complaint? Quantico is in receipt ofthe complaint and they are processing the complaint IAN with the USMC rules.4) Is there an investigation into why CNO4 Averhart placed PFC Manning on suicide risk? Ifso, can you update me on the status? we are not aware of an investigation; however if thereis an investigation, it would be solely within the USMC chain of command. I do know that CH4Averhart as part of his normal change of jobs.5) where do we stand on the issue for the 766 board? we are working on finalizingour formal response to your request, in order to present to you for your review this week,along with proposed COAs if you disagree.6) Could you and the rest of your defense team please coordinate a head of time with theBrig if you are planning on calling or visiting your client. It is not the normal practicefor the Brig to quickly react and they will not always be able to accommodate no-notice phonecalls and no-notice visits, unless during visiting hours, including CAPT Moore. AlthoughCAPT Moore provides services at the Brig for other pre-trial confinees, he will not begranted his accustomed access to PFC Manning, without prior coordination, because he is nowpart of the defense team.02886251Thank you.Have a good week.Ashden Feincpr, JAChief, Military JusticeU.S. Army Military District of Washington (MDH) 02215555From: Sent: Monday, January 31, 2011 10:38 PMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Carlile, Monica L. SFC USA JF11Q-SM mi? Haberianwohn CPI MILI Subject: [Suspected RE: UpdateAshden,How long do you anticipate the read-on to require? Depending on the length of time, I may be able toconduct this in D.C. on the 11th.1) Even if the read-on is completed before or on the 11th, I would like to have PFC Manning taken to FortMyer. MAJ Kemkes needs to meet with PFC Manning in the morning, and I will be joining them in theafternoon.2) The defense would like to have the documentation provided by LTC Greer. will you be releasing thisinformation as part of the requested defense discovery?3) Got it. Have they provided you with any details for timing?4) Understood. The defense would like for the government to inquire as to whether there is aninvestigation of CW04 Averhart. The defense believes this information is relevant for any Article 13motion.5) Understood.6) I will make sure that Capt. Moore is made award of this issue. I would like for you to have Johninquire why I was denied access to PFC Manning last Sunday. I had called ahead of time and coordinatedthe attorney visit with Blenis. He informed that it would not be a problem. When I arrived atQuantico, I was denied access. The DBS informed me that they were not aware of my planned visit. Iwant to avoid this from happening again in the future.7) COL Malone: Can you con?rm that COL Malone recommended that PFC Manning be removed from POIwatch last week? I have been told that he did, but I want to verify this information.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896 mmNotice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02215552From: Bouchard, Paul CPT USCENTCOM USF-I Sent: ue ay, ruary 1, 1 AMTo: Fein, Ashden CPT USA Cc: Matthew kemkes; Cadile, Monica L. SFC USA Haber1and.John CPTSubject: RE: ateSigned By:FYII completed the read on certificates today at Camp Liberty, Iraq.CPT Paul Bouchard02215548 From: Sent: Tuesday, February 1, 20l l2:09 PMTo: Fein, Ashden CPT USA SJA l>Cc: Matthew kemkes Carlile, Monica L. SFC USA sm jg?, mmSubject: Susan Manning's VisitAshden,I also wanted to con?rm the time and days for PFC Bradley's mother visit. She is planning on coming February and also on 19 and 20 February. Am I correct that her visiting hourswill be from 1200 to 1500 on both days? Also, I wanted to make sure that the Brig knew she was comingand that there would be no issues with her getting on post.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896ce9_m_b?@ Fm -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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02203203From: Haberland, John CPT Mll, USA Sent: Tuesday, February 1, 2011 12:12 PMTo: Fcin, Ashden CPT USA SJA Cc: Matthew kemkes Carlile, Monica L. SFC USA JFHQ-SJA Subject: RE: Susan Manning's Visit (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUOSir,I will coordinate with the Brig to determine the exact visiting times and make sure that they are aware that his motherwill be visiting.Very Respectfully,CPT John B. HaberlandRegimental Judge Advocate3rd U.S. Infantry Regiment (The Old Guard)02885111From: Fein, Ashden CPT USA SJASem: Thursday, February 03, 2011 6:57 PMTo: mconus.army.miICc: Ovengaand, Angel M. CPT USA Morrow JoDean, CPT USASJA: Carlile. Monica L. SFC USA SJASumed: Sir. Mr. Coombs, defense attorney was read-on today. we dated the re-start of the RCM 786 for today and we are sending it out to theBoard. Thank you.v/rAshdenFcinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN) 02891837From: Fein, Ashden CPT USA SJASent: Thursday, February 03. 2011 7:42 PMTo: Sweda. Michael Dr CIV USA MEDCOM WRAMCCc: Benesh, Samantha CPT MIL USA MEDCOMMAMC. Hemphill, Mar1a LTC MIL USA MEDCOM Morrow Ill. JoDean, CPT USACarlile, Monica SFC USA SJA2Subject: Urder Attachments: 706 Order.pd!hnponance: HanDr. Sweda,Good evening. Attached is the convening Authority's order to re-start theRCM 706 Board For PFC Manning. The prosecution intends to prepare theallied documents to send to you and your team early next week. If you haveany questions, please ask. Thank you.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN) 02911568From: Fein, Ashden CPT USA SJASent: Thursday. February 03. 2011 7:50 PMTo: Cc: Matthew kemkes; Carlile, Monica L. SFC USA Haber1and.John CPTMIL USA Morrow nu. JoDean. CPT USA JFHQ-Subject: RE: [Suspected RE. UpdateDavid,After further review of my emails, I think we spoke about all outstanding issues today.Please let me know if there is anything else. Thank you.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON) 02221 882From: Sent: Friday, February 4, 201 I 7:42 AMTo: Fein, Ashden CPT USA Subject: RE. RCM 706 Order (PFC BM) (UNCLASSIFIED)Classit'ication; Caveats NONESir.Please infonn me ofhow/when I should be read on to this case securit_V' read on).ABPP (Forensic)Board-Certi?ed l-?oreiisie Chief, Forensic Ps_vcholog_v ServiceDirector, Forensic Fellowship Walter Reed Anny Medical Center "The United States themselves are essentially the greatest poemPast and present and future are not disjoined but joined From: Fem, Ashderi Cl"l? USA SJSent l-?ehniary 201 I 7 42 PMTo. Sweda. Michael Dr CIV USA MLDCOM WRAMC(Sc. Benesh, Samantha Cl"l? MIL USA Hemphill. Marla l.?l?C Mll. USAMlil)C()M Morrow JoDean. USA Carlile, Monica USA Kemkes,Matthew MAJ Mll. USASubject? RCM 706 Order BM)Importance: HighDr. Swcda,Good evening. Attached is the Converting Authority's order to re?start the RC 706 Board for PFC Manning. The prosecution intends toprepare the allied doctunents to send to you and your team early next week. If you have any questions. please ask. "thank you.v/rCl?l' FemAshden FeinJAChief, Militar? JusticeUS. Army Military l)istnet of Washington Classification: Caveats: NONI-I02891829From: Fein. Ashden CPT USA SJASent: Frida Februa 04, 2011 8:00 AMTo: US.ARMY.MILSubject: RE: RCM 706 Order (PFC BM) (UNCLASSIFIED)The DA Security personnel confirmed you are already read-on to Are you underthe impression that you are not?v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Arm Militar District of washin ton 02221879From: Sent: Friday, February 4, 2011 8:15 AMTo: Fein, Ashden CPT USA SJA Subject: RE: RCM 706 Order (PFC BM) (UNCLASSIFIED)Classi?cation. UNCLASSIFIEDCaveats: NONESir:I have been read on in the past in another case. I have made limited use of my security clearance in the past and am not thoroughlyfamiliar with the procedures. I thought the read on might be a issue. but now I know it is not.v/ r.ABPP (Forensic)Board-Certi?ed Forensic Chief. Forensic ServiceDirector. Forensic Fellowship Walter Reed Anny Medical (?enter "The United States themselves are essentially? the greatest poem.Past and present and future are not disjoined but joined."From; Fein_ Ashden CPT USA SJASent: I-?riday. Febniary 2t)! 1 8:00 AMTo: Sweda. Michael Swcda.The DA Security personnel con?nned you are already read-on toAre you under the impression that you are not??v/rCPT FeinAshden FeinCPT. JAChief, Military JusticeU.S. Ann Militan District of Washin ton MDW -?-?-Original *r?mI 02221879Sent: Friday. February 20! 7:42 AMTo. Fein. USA SJASubject: RE: RCM 706 Order(PFC BM) Classi?cation: UNCLASSIFIEDCaveats: NONESir:Please inform me of how/when I should be read on to this case security read on).Michael Sweda, ABPP (Forensic)Board-Cenilied Forensic PsehologistChief. Forensic Ps) chology ServiceDirector. Forensic Fellowship Walter Reed Anny Medical Center "The United States themselves are essentially the greatest poemPast and present and future are not disjoined but joined."--?--Original From: Fem CPT USA SJA ent: To: Svveda. Michael Dr CIV USA MEDCOM WRAMCCc: Benesh. Samantha Mll. USAMEDCOM MAMC: Hemphill. Marla LTC MIL USA MEDCOM BAMC: Morrow Ill.CPT USA Carlile. Monica L. SFC USA- in thew MAJ Mll, Subject: RCM 706 0rder(PFC BM)Importance: HighDr. SwedaGood evening. Attached is the Convening Authority?s order to re-stanthe RCM 706 Board for PFC Manning. The prosecution intends to preparethe allied documents to send to you and your team early next week. Ifyou have any questions. please ask. Tliank you.v/ CPT FeinFeinCPT. JAChief. Military JusticeU.S. Army Military District of Washington (MDW) 02221879Classi?cation: UNCLASSIFIEDCaveats: NONEClassi?cation: UNCLASSIFIEDCaveats: NONE02188712From: ?@state.gov>Sent: Friday, February 4, 201 1 6:41 PMTo: Fein, Ashden CPT USA SJA Morrow Ill, JoDean, CPT USA SJA Cc: state.gov>Subject: (SBU) updateSENSITIVE BUT UNCLASSIFIEDAshden and Joe.We have mostly completed our document review, and have updates for you. Should we plan to discuss Monday (bywhich time we may have received a response from or do we need to do it sooner??Let us know, and hope you guys are doing well.Thanks, U.S. Dggartment ofStateSBUThis email is UNCLASSIFIED.02884518Sir,Good morning.Fein, Ashden CPT USA SJASunda . Februa 06. 2011 11:49 PM?ver: Morrow m, Jo?inl CPT USA usr=-nUSA OTJAGRE: US v. PFC Manning RFIr?ghThe purpose of this email is a follow-up to my previous emaildated, 8 Jan 11 (below). Could you please point me in the right directionso that we can have an unclassified copy of the USF-I 15-6 approved bywe need this investigation for our own records and to provide indiscovery. The only version we have is classified that we received on aclassified disk.v/rCPT FeinAshden FeinCPT, JAThank you.Chief, Military JusticeU.S. Army Military District of Nashington (MON) 02228398From: USF-I iraq.centcom.mi|]Sent: Monday, Februaly 07, 2011 1:38 AMTo: USA SJACc: USA USF-I Subject: FW: US v. PFC Manning RFIImportance: HighFollow Up Flag: Follow upFlag Status: CompletedCPT Fein,I have taken over for My review of the Manning investigationyou reference indicates comports with yours. Only the action memo by-Garrett contains any classification markings. we are coordinating with ourclassification experts to try to get that classification removed, as itappears unusual the rest of the report is unclassified, but that document isnot. However, it may have been classified because it shows correctivemeasures that point out current vulnerabilities.To ensure there are no classification oversights in the rest of the report,we will ask them to review the entire file. USF-I OSJA 02911955From: Fein, Ashden CPT USA SJASent: Monda February 07, 2011 8:34 AMTo: @centcom.miISubject: FW: (U) RE: Classification Review (Video)Sir,Please read below. Can you assist in me having the approval to line throughthe classification? we are about to prefer additional charges and I wouldlike to share the information with the defense. Thank you.v/rAshdenAshden FeinJAChief, Military JusticeU.S. Army Military District of washington (MON) 02215541From: Sent: Monday, February 7, 2011 8:46 AMTo: Fein, Ashden CPT USA SJA Cc: Benesh,Samantha CPT MII. USA MEDCOM MAMCHemphi|l,Mar|a LTC MIL USA MEDCOMMorrow Ill, JoDean, CPT USA WHO-Carlile, Monica L. SFCMatthew Sweda Dr CIV USA MFDCOM WRAMCSubject: [Suspected RE: RCM 706 Order (PFC BM)Dr. Sweda,The R.C.M. 706 order indicates that the defense would like Capt. Kevin Moore to be permitted to "monitorthe examinations conducted by members of the board." I would like to clarify that the defense does notwant Capt. Moore to participate in the 706 board or to interject himself in any manner during the board.We simply request that Capt. Moore be allowed to sit while the board conducts its work. The goal of thisrequest is so that he could be in a better position to educate defense counsel on the board's testing andresults.Additionally, although the convening authority has given a four week suspense date for completion of theboard, the defense views this suspense as aspirational. Clearly, you and the board should feel free to takethe time necessary to conduct a thorough and complete examination of PFC Manning. If the boardrequires an extension of time, you should feel free to submit such a request through the trial counsel.Undoubtedly, any request for an extension of time by the board would be granted. In the end, the mostimportant thing is that the board takes the time it needs to in order to feel comfortable with its results.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02891868FrontSentTo:Cc:Subject:Dr. Sweda,Good morning.Fein, Ashden CPT USA SJAMonday. February 07, 2011 8:50 AMBenesh,Samantha CPT MIL USA MEDCOM Hemphil|,Mar1a LTC MIL USAMEDCOM Morrow JoDean, CPT USA Canile. Monica L.sec USA JFHO-NCRIMDW Matthew kemkes; Sweda.Michael Dr USA MEDCOM WRAMCRCM 706 (PFC BM)The prosecution has a compact disk of documents to serve as the allieddocuments for this case. what is the best way to ensure prompt delivery to you and theboard? Thank Ybu.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District o? Hashington (MUN) 02891863From: Fein. Ashden CPT USA SJASent: Monday, February 07, 2011 9:07 AMTo: Cc: Morrow JoDean, CPT USA Canile, Monica L. SFC USA JFHQ-Matthew kemkes; Subject: RCM 706 (PFC BM) DocumentsDavid,The United States plans on giving the RCM 766 Board a CD of all the allied documents thedefense has received to date. we also plan on compiling a list of documents the board shouldnot ?ocus on, in order to help them get through all the data. Once we finish the list today,we will send it to you For comment and input.AshdenAshden FeinCPT, JAChief, Military Justice 02189065mm: m@cenmommn>Sent: Monday, February 7, 201 1 1:50 PM To: Fein, Ashden CPT USA SJACc:@centcom.mil>Subject: US Manning Classi?cation Review (Video)CPT Fein: Feel free to line through and share with defense counsel. If you feel you need to memorialize this with a signatureon a memo. please let me know Otherwise. please "pen and ink" and proceed!U.S. Army Reserve (mobilized). Assistant SJAHQ. USCENTCOM (AI IN: 7| 15 S. Boundary Blvd. MacDill AFB. FL 3362 1-5101SN SIPR: aI.centcom.smil.mil 02221876Fr?m= sent: Monday, February 07,2011 2:36 PMTo: Fein, Ashden CPT USA Cc: Morrow Ill, JoDean. CPT USA Carine.onnca . Matihew kemkes;Subject: RCM 706 (PFC BM) (UNCLASS-IFIED) Signed By: BENESHSAMANTHAMARIE.1272647034Classification: UNCLASSIFIEDCaveats: NONECPT Fein,Dr. Sweda will be out of the office the rest of this week; please send thedisk to my attention via courier or Fed-Ex to the following address:ATTN: MAJ Samantha Benesh6989 Georgia Ave, N.N.6/Borden Pavilion, 3rd FloorDepartment of washington, DC 26307Please do NOT send the disk via USPS/regular mail. Our mail system at HRAMC isnotorious for losing letters or delivering them only after a significantdelay.v/r,Samantha M. BeneshMAJ, MS, USAForensic FellowWalter Reed Army Medical Center 02885743 From: Fein, Ashden CPT USA SJASent: Monda Februa 07, 2011 5:50 PMTo: A uscemcou Cc: IL USA USCENTCOM Subject: RE: US Manning Classification Review (Video)Sir,I just need acknowledgment from a person of proper authority. If you are that person, pleaseacknowledge and I will make it happen. Thank you.v/rAshdenAshden FeinCPT, JAChief, Military )usticeU.S. Army Military District of Washington (MUN) 02901061From: Fein, Ashden CPT USA SJASent: 08. 2011 12:50 PMTo:Subject: RE: IC BadgesSir. Thanks. I apologize. You did, but I think that was only for a DIA badge, like mine.Since then, we actually have not been back over, except I ran in to pick up documents. withthat application, then we can run over and get the IC badge made.Ashden Feincm, JAChief, Military JusticeU.S. Army Military District of Washington (MOW) 02901058From: Fein. Ashden CPT USA SJASent: 08. 2011 6:24 PMTo:Subject: RE: IC BadgesSir. Thanks. Is it possible for me to get an IC badge as well? My original form onlyauthorized a DIA badge and not IC badge.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MOW) 02221862From: Sent: Wednesday, February 9. 20l I 5:16 AMTo: Fein, Ashden us?. Cc= Subject: Initial plan for evaluation schedule (UNCLASSIFIED)Classi?cation: UNCLASSIFIEI)Caveats: NONECPT Fein:I believe? has been out of contact down in GTMO but will be back in the CONUS soon, We are discussing probabledates for the evaluation March. with the 16th being an interview. the testing. and I Marchan interview at a SCIF. We will need to know where the SCIF location will be. An additional date for testing may be needed.depending on how things go the l7th.I will get back to you as soon as possible regarding the request to have? sit in on the interview. At prescm. just to assistin planning. I think he should make anangements to attend the two interviews (16 Feb and I March). pending my having furtherdiscussions with the other board members. I have not yet been able to discuss the request with board members as a group due to?TDY.I strongly feel that observation of the testing is not advisable. as this may have unknown effects on the test results and the testing (ifobserved by a third pany) would not be performed in a standardived fashion.We ask that? adjust his schedule to the board's plans. Otherwise. scheduling becomes unwicld and the evaluation willundoubtedly be delayed as we try to coordinate four different schedules. Please tell him to call me athif he Insquestions. I will be at Ft Rucker this week on a TDY.Please forward this email (defense counsel) to others as needed.Classi?cation" UNCLASSIFIEDCaveats: NONE02900769From: Fein, Ashden CPT USA SJASent: Wednesday. February 09. 2011 6:49 AMTo:Cc:coom annycourtmartialdefensecom; Morrow JoDean. CPT USA SJA: Matthew kemkes: Haber1and_ John CPT MIL USASubject: RE: Initial plan for evalua Ion sc Dr. Sweda,Thank you. Cced are the defense counsel. As per the convening authority's guidance(paragraph 5, order dated 3 Feb 11, you as the Board president are authorized to ?determinethe extent to which the defense expert consultant Moore] may participate in the board'sinquiry." At this point, this decision is strictly up to you.If you feel CAPT Moore's participation will hinder the administrative process and/or affectthe board's test results and testing, and you want to exclude him from the overall process,this is completely up to you. The defense would then have to re-petition the conveningauthority to change his guidance. However, if you feel that CAPT Moore can fullyparticipate, or participate in some manner (less than full), then you may approve that aswell.To reiterate what Mr. Coombs stated in his email on Monday, 7 Feb 11, the most importantaspect of this RCM 706 (and all others) is that the board has adequate enough time tocomplete the process and is comfortable with the results. If CAPT Moore's participationaffects the results, then you are empowered to exclude him from the process.For the 16th and 17th, where do you envision the interview and testing to take place If at NRAMC, is it possible to schedule both during off-set hours? Pending contraryguidance, we will start making tentative plans for you to meet with PFC in a SCIF on 1 Mar.we are still working on the location, but it will likely be in or around Ft Belvoir, VA.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MOW) 02221859Sent: Wednesday, February 9, 201 752 AMTo: Fein, Ashden USA sm Cc: Morrow Ill, JoDean, CPT USA JFHQ-SJA Matthew kemkesnil;Subject: RE Initial plan for evaluation schedule Classificziuonz UNCLASSIFIED(?ax ems" NONI-ZSirWe plan 10 cxalumc at Quzuuico brig ifzn all possible. I do not pcrfonn of iduals ho are con?ned WRM ACfor sccunt} and reasonsWe will get back to you about CAPT Moore's possible punicipamon through unobtrusive for the inlcn lC\\ portions of theI am clear that his presence dunug psi Icstulg phases is undesirable from :1 slzuidpouu of standard testadmmislralion.Mic cda02890793 From: Fein, Ashden CPT USA SJASent: 09. 2011 5:48 PMTo:Subject: RE: Request for IC badges is inSir. Thanks. I sent to our security folks and they will hopefully do it by noon tomorrow.MTF .Ashden FeinCPT, JAChieF, Military JusticeU.S. Army Military District of Washington (How) 02188699From= _@state-sov>Sent: Wednesday, February 9, 201 1 6:46 PMTo: Fein, Ashden CPT USA SJAMorrow .loDean, CPT USA SJACc: @state.gov>Subject: email on S[PRnetAshden and Joe.FYI, l?vc sent _vou an email on with the list you requested on our call on Monday. Let us know if you have anyquestions or concerns.Thanks! U.S. Department of StateSBUThis email is UNCLASSIFIED.02216070From: Sent: Monday, December I2, 20] I 5:44 PMTo: Alm Fein, Ashden CPT USA SJA Cc= Matthew Morrow JoDean, CPT USA SJ AOvergaard, Angel M. CPT USA JFHQ- A Subject: RE: Telephonic 802LTC Almanza,28 U.S.C. I746 StatementsIn response to your request for us to look at 2010 WL 2265833 and 2002 WL 243445, the defense's position isthat both cases are inapplicable to the situation at hand. In Faison, the 10 found that TRD was unavailable andthat her videotaped statement was swom_ Such a detennination was appropriate given the fact TRD respondedto questions indicating that she knew the difference between the truth and a lie and promised to tell the truth.As the IO and the AFCCA correctly concluded, this colloquy more than adequately satisfied theoath/af?rrnation requirement so as to make TRD's videotaped statement a sworn statement under R.C.M . 405(g)In the instant case, unswom statements under 28 USC. 1746 do not share any of the samehallmarks of a sworn statement. The statements are not made in front of anyone and the statements are notsimilar, in that they are not made in front of a person authorized to administer oaths.Likewise, Elsevier dealt with a videotaped interview that was done without a formal swearing or oath.However, it qualified as a sworn statement in accordance with R.C.M. since on a later date theunavailable witness did swear to the of the statements contained therein. The IO correctly found this to bea sworn adoption of the videotaped interviews that, pursuant to United States v. Wood, 36 651 (A.C.M.R.I992), rendered it admissible. None of the individuals who provided the unswom statements under 28 U.S. C. 1746 have subsequently provided a sworn adoption of their unswom statement in accordance with R.C.M. 405An unswom statement provided under 28 U.S.C. I746 does not qualify as a sworn statement. In order for anunswom statement provided under 28 U.S.C. 1746 to be admissible, it must be subscribed and signed "in ajudicial proceeding or course of ustice" at the Article 32 hearing. A plain reading of 28 U.S.C Section I746and R.C.M. 405(h)(I undercuts any argument to the contrary.QlgsurgWhile the Defense acknowledges the general right of the public to attend criminal proceedings, such right is notunfettered and must be balanced by the right of the accused to a fair trial. Specifically, the Defense maintainsthat the public's interest in ?ve discrete pieces of evidence, which may or may not be admissible if the caseproceeds to trial, is not sufficiently overwhelming to override the accused's right to a fair trial. It is important tonote that all of the cases in this area involve the government attempting to close the Article 32 hearing while theaccused was attempting to assert the right to a public hearing. Here, it is the accused who is asserting his rightto close parts of the hearing in order to preserve the integrity of the judicial process and to ensure his right to afair trial. The Government can point to no harm to its case based upon the defense's request. Instead, thediscussion seems to be centered on subsequent steps that a military judge can take to cure any error at theArticle 32. This analysis is misguided given the relative ease of avoiding the harm and the limited nature of thedefense's request. Certainly, to the extent that we are going to err, we should err on the side of caution. In thisinstance, that would mean closing the hearing during those limited times requested by the defense.AIT Training 02216070The defense has attached the referenced email regarding the IT training.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Toll Free: 1-800-588-4156Local: (508)689-4616Fax: (508) 689-9282Notice: This transmission, including attachments, may contain con?dential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlaw?J1 and is 0221 9348From:Sent:To:Cc:Subject:Attach:Almanza, Paul LTC RES USAR USARC Monday, December 12, 201 1 9:00 PMMorrow JoDean, CPT USA SJAFein, Ashden CPT USA IA Overizaard. An2el M. CPT USA JFHQ-SJA Matthew kemkesWhyte, Jeffrey Witness List (UNCLASSIFIED)Manning Article 32 Witness List lrev.docClassilicaliotlt UNCLASSIFIEDCounsel -Attached per my conversation with CPT Fcin and Mr. Coombs this afternoon is a copy of my witness list for the hearing.I will circulate a signed version of this document as soon as possible.Tliank you.LTC AlmanzaClassi?cation: UNCLASSIFIED02919147From: Fein, Ashden CPT USA SJASent: Monday, December 12, 2011 9:01 PMTo: Almanza, PaulCc: Matthew kemkes; Morrow Ill, JoDean, CPT USA JFHQ-vergaa nge . A Whyte, Jeffrey H. CPT USA SJASubject: RE: Telephonic 802Sir,The United States maintains its previously stated position on both the validity of the swornstatements and keeping the hearing open to the public in order to reduce public scrutiny andensure transparency of the military justice process.Our systems were down tonight, and we will send a copy of the email the defense referencedtomorrow.v/rCPT Fein 02216066From: Sent: Monday, December 12, 20] 1 9:42 PMTo: A|m Fein, Ashden CPT USA SJA Cc= Matth Morrow 111, .loDean, CPT USA Overgaard, Angel M. CPT USA JFHQ- SJA Whyte, Jeffrey H. CPT USA SJASubject: RE: Telephonic 802LTC Almanza,The defense received your list of intended witnesses. It is the defense's understanding that the listed witnessesare those that you would want to hear from during the hearing. If a specific witness is listed as reasonablyavailable by you, then this witness is to be produced as a live witnesses. The defense is unsure of your intentregarding a witness that is on your list but is listed as "not reasonably available." It appears that you aredefening to the government regarding whether these witnesses will be produced and in what manner. Thedefense believes that this detennination must be made by you and not the government.If the defense's reading of your memorandum is correct, it appears that only 12 witnesses will be called at theArticle 32 (one of which will invoke his 5th Amendment Right). The remaining witnesses, under the aboveunderstanding, will testify if at all, at the government's discretion.With regards to the witnesses not listed by you, the defense requests a ruling regarding whether these witnesseshave been deemed as either not relevant, cumulative or not reasonably available. Under R.C.M. the defense objects to the determination that its listed witnesses are either not relevant, cumulative or notreasonably available.Best,DavidDavid E. Coombs, Esq.Law Office ofDavid E. Coombsll South Angell Street, #317Providence, RI 02906Toll Free: l-800-588-4l56Local: (508) 689-4616Fax: (508) 689-9282Notice: This transmission, including attachments, may contain con?dential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is prohibited.*"02919137From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Monday, December 12. 2011 10:51 PMTo: Almanza, Paul; Almanza, Paul LTC RES USARUSARCCc: Matthew kemkes; Morrow Ill, JoDean, CPT USA JFHQ-Overgaard, Angel M. CPT USA Whyle, Jeffrey H. CPT USA SJASubject: RE: Telephonic 802Attachments: SFC Adkins ART-31 .pdfSir,As For those witnesses you determined to be reasonably available, the United States agreeswith the defense's interpretation.Based on the attached memorandum, SFC Adkins is invoking his Article 31 rights. The UnitedStates will produce him if you determine his presence is required to invoke his rights.Otherwise, all the government's offered witnesses are available and the United States willcheck on the status of CPT Keay and SGT Padgett (defense offered witnesses) tomorrow morning.DTS should not be an issue, if they are available.As For any witness designated as not reasonably available, the government requests to callthem as telephonic witnesses, if you are not considering their sworn statements.The United States joins the defense in the request for you to annotate for the record whichwitnesses you deemed not relevant or relevant but cumulative.Finally, as we discussed earlier today during our conference call, the United States standsready to coordinate the travel for those witnesses that are reasonably available oralternative testimony of each witness that you deem relevant and not cumulative, from boththe government's and deFense's witness lists.Thank you.v/rCPT Fein02215050From: Sent: Tuesday, December 13, 201 1 8:38 AMTo: Almanza, Paul Almanza, Paul LTC RES USAR USARCCc= Matthew kemkes Morrow JoDean, CPT USA SJA Overgaard, Angel M. CPT USA JFHQ-SJA Jeffrey H. CPT USA SJAFein, Ashden CPT USA SJASubject: RE: Telephonic 802LTC Almanza,The defense requests that SFC Adkins be produced at the Article 32 hearing. The basis that SFC Adkins isattempting to avoid testifying is not a proper invocation of his Article 31 rights or his 5th Amendment rightagainst self-inclimination. The Fifth Amendment protections only apply to in a custodial interrogation andwhen the individual questioning is law enforcement. Article 3| applies only when the military questioner isacting or could reasonably be considered as acting in an official law enforcement or disciplinary capacity.United States v. Bell, 44 M.J. 403 (C.A.A.F. 1996) (Article 3l requirement for wamings does not apply at trialor Article 32 investigation). SFC Adkins is attempting to invoke his Article 3] rights in a noncriminal matter(administrative reduction) and when he is not the subject of any questioning designed to elicit incriminatingstatements. He should therefore be ordered to testify.In the alternative, the defense requests that the government provide a grant of testimonial immunity to SFCAdkins under R.C.M. 704(e). SFC Adkins is a material witness at the Article 32 hearing. The fact that he isappealing his reduction in rank should not provide him with the ability to avoid testifying.Best,DavidDavid E. Coombs, Esq.Law Office of David E. CoombsSouth Angell Street, #317Providence, RI 02906Toll Free: l-800-588-4156Local: (508) 689-4616Fax: (508) 689-9282Notice: This transmission, including attachments, may contain confidential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is prohibited/??*02219342From Atmanza.Pauim> Sent: Tuesday, December 13, 201 1 8:56 AMTo: Fein, Ashden CPT USA SJA Cc= Matthew kemkes Morrow Ill, JoDean, CPT USA SJAOvergaard, Angel M. CPT USA JFI IQ-yte, Jet rey H. cm? USA SJASubject: Re: Telephonie 802Counsel Yes. I intend that witnesses I listed as "reasonably available" be produced as live witnesses at the hearing, and witnesses I listed as"not reasonably available? be heard from through an alternative to testimony.My making initial determinations as to availability of witnesses does not constitute my deferring to the govenunent on whetherwitnesses will be produced or not. Rather, I Simply made an initial determination as to whether witnesses were reasonably availableor not per RCM 405(g)(2)(A) and (B).I then asked the govemment if they believed any wiuress was not reasonably available to see if there are any issues with immediatecommanders of military witnesses determining that they are not reasonably available or civilian witnesses not being reasonablyavailable.I then asked the govemment whether witnesses I initially dctemrined are not reasonably available will be available for telephonictestimony or whether they believe another alternative to testimony is appropriate in order to detennine whether there would be anyissue with telephonic testimony of the witnesses have initially detennined are not reasonably available.As counsel know, there is still an outstanding issue as to whether statements under penalty of perjury of certain witnesses on tny listdesignated as not reasonably available can be considered over defense objection. For other witnesses on my list that I initiallydetennined are not reasonably available. I intend to take their testimony telephonieally.I will of course note the defense objection and prepare a written detcnnination to whether I deemed witnesses not listed as notrelevant. cumulative. or not reasonably available.Please let me know if you have any questions.LTC Almanza02219335From:Sent:To:Ce:Subject:Attach:Almanza, Paul LTC RES USAR USARC Tuesday, December I3Morrow JoDean, CPT USA SJAFein, Ashden CPT USA Overgaard, Angel M. CPT USA SJAMatthew kemkesWhyte, Jeffrey H. CPT USA SJAHolzer, Mark LTC MIL USAOTJAGUS v. PFC BM - Closure Determination (UNCLASSIFIED)Manning Article Closure Determination 1.doc; Manning Article 32 WitnessList 12131 I.doc Classi?cation: UNCLASSIFIEDCounsel -Attached is my closure detennination. I've also attached another copy of my witness list - I had the wrong office symbolon what I provided Once I get these documents printed, I will provide signed copies.LTC Alman/aClassi?cation: NCLASSIHED02216057 From: Sent: Tuesday, December I3, 20I 1 4:21 PMTo: Almanza, Paul LTC RES USAR US iI>; Morrow JoDean, CPT USA SJA Fein, Ashden CPT USA SJA Overgaard, Angel M. CPT USA SJA Whyte, Jeffrey H. CPT USA SJACc: lzer, Mark I.TC Mll. USA OTJAGSubjectClosure Detennination (UNCLASSIFIED)I.TC Almanza,The defense does not agree with your analysis under R.C.M. 806(b)(2). The alternatives to closure that youconsidered are not, in fact, reasonable in this case. This case has already been subjected to extensive mediascrutiny and PFC Manning has already been adjudged guilty in the court of public opinion. Moreover, severalhigh-ranking officials (both military and government) have made improper comments concerning PFCManning's probable guilt and appropriate punishment. In a case such as this, there is no substitute for ensuringthat potentially inadmissible and highly in?ammatory evidence is not placed into the public realm.The defense respectfully requests that you reconsider your ruling. In the event that you decline to do so, thedefense alternatively requests that all media be barred from the proceedings in the five instances referenced inthe defense's motion. Any non-media individual would be permitted to remain in the courtroom. Under thediscussion to R.C.M. 806(b)(2), this is not a "closure" and therefore would not have to meet the elementsoutlined in the closure mles. Should you exclude media pursuant to this request, the defense further requeststhat you issue a gag order barring the individuals remaining in the courtroom from discussing the testimonyelicited.Best,DavidDavid E. Coombs, Esq.Law Of?ce of David E. CoombsI I South Angel] Street, #3 I 7Providence, RI 02906Toll Free: 1-800-588-4156Local: (508) 689-4616Fax: (508) 689-9282w. i inNotice: This transmission, including attachments, may contain confidential attomey-clientinfomiation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is 02216052From: Sent: Tuesday, December 13, 2011 6:45 PMTo: Fein, Ashden CPT USA SJA Almanza, Paul Almanza, Paul LTC RES USAR USARC Cc: Matthew kemkesMorrow oDean, CPT USA SJAOvergaard, Angel M. CPT USA JFHQ-SJA Whyte, Jeffrey H. CPT USA Subject: RE: Telephonic 802CPT Fein,Can you provide me with a list of those witnesses that the government is producing in person, and those that thegovernment will make available by telephone?Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Toll Free: l-800-S88-4l56Local: (508) 689-4616Fax: (508)689-9282Notice: This transmission, including attachments, may contain confidential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is 02216051From:Sent:To:Cc:Subject:Tuesday, December 13, 2011 7:07 PMAlmanza, Paul I.TC RES USAR USARC Morrow JoDean, CPT USA SJA Fein, Ashden CPT USA SJAOvergaard, Angel M, CPT USA SJAMatthew kemkesWhyte, Jeffrey II. CPT USA SJA olzer, Mark MIL USA OTJ AGRulings on Defense Motions I.TC Almanza,The defense requests that you issue a ruling on the following defense motions prior to the date ofthe Article 32:1) The defense request for production of evidence;2) The defense objections to the government's requested evidence;3) Those witnesses that are being produced in person, and those that are being produced by telephone;4) The basis for the denial of the defense requested witnesses;5) The defense request for reconsideration of the closure motion; and6) The defense request for exclusion of media and a gag order.Best,DavidDavid E. Coombs, Esq.Law Office of David E. CoombsI I South Angell Street, #317Providence, RI 02906Toll Free: 1-800-588-4156Local: (508)689-4616Fax: (508) 689-9282Notice: This transmission, including attachments, may contain confidential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this infonnation may beunlawful and is 02216046From: Sent: Tuesday, December 13, 201 1 8:30 PMi To: Fein, Ashden CPT USA SJA Almanza, Paul Almanza, Paul LTC RES USAR USARC Cc: Matthew kemkesMorrow Ill, JoDean, CPT USA SJAOvergaard, Angel M. CPT USA JFIIQ-Whyte, Jeffrey H. CPT USA Subject: RE: Telephonic 802LTC Almanza,The defense would also request that you issue a ruling on its request to order SFC Adkins to testify at theArticle 32 hearing given the fact that his basis for refusing to do so deals with an administrative matter. Thedefense also requests that the government indicate whether it has taken any steps to issue a grant of immunity toSFC Adkins, and if not, why not.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombsll South Angell Street, #317Providence, RI 02906Toll Free: 1-800-588-4156Local: (508) 689-4616Fax: (508) 689-9282momartialdefen se.com"*Conf1dentiality Notice: This transmission, including attachments, may contain confidential attomey?clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlaw?il and is 02219330Almanza? Paul Sent: Wednesday, December 14, 201 1 9:08 AMTo: (Tc: Matthew kemkes Morrow Ill, JoDcan, CPT USA SJAOvergaard, Angel M. CPT USA JFHQ-l; Whyle, JefTrey H. CPT USA SJAFein, Ashden CPT USA Holzer, Mark MIL USA DW SJASubject: Re: Telephonic 802Counsel-This provides notice that I intend to ask my legal advisor whether SFC Adkin should be produced at the hearing in light ofhis memorandum indicating that he intends to invoke his Article 31 and 5th Amendment rights and, if so, whether he maybe ordered to testify given that the matter cited in his memorandum is an administrative one.ihank you.LTC Almanza 02919120From: Fein. Ashden CPT USA JFHQ-NCRIMDW SJASent: Wednesday, December 14, 2011 10:37 AMTo: Almanza. Paul; coombs arm cour1martia|defense.c( Cc: Matthew kemkes; Morrow ean, -vergaa nge . A JFHQ-NCRIMDW Whyte, Jeffrey H. CPT USA JFHQ-NCRIMDW ozen a JAGSubject: RE: Telephonic 802Attachments: Fw: Swom Statement (UNCLASSIFIED)hnponance: l?ghSir,Good morning. The government was without email from at least 1937 last night until 1030 thismorning. This email serves as an update to your witness request and other administrativeissues up to 1937 last night. Email is sporadic but we should be able to continuecommunicating through email.witness List. The government is working to finalize whether witnesses will be available fortelephonic testimony. we do not anticipate any issues with telephonic testimony of thewitnesses you ruled "not available" except the below witnesses.1. we do not know whether the different original classification authorities (OCAs) will beavailable for telephonic testimony and will likely not know until 1300 on 15 Dec 11.2. The United States requests CPT Keay be deemed not reasonably available and testify viatelephone. CPT Keay is currently scheduled for block leave during the hearing and alreadyhas airline tickets and other non-refundable reservations. we are working to obtain copiesof his leave form and other travel documents.3. The United States requests SGT Padgett be deemed not reasonably available and testify viatelephone. SGT Padgett just returned from a five month TDY for MOS re?classificationtraining (AIT). He just returned to the unit and we expect more information from the commandin the next few hours. I will forward the commander's decision about his physical presenceand reason, once we receive it.4. The United States requests Mr. Adrian Lamo's be deemed reasonably available. Mr. Lamo isdiagnosed with asperger This is a high functioning form of autism. Based on hismedical condition, he will not likely be able to relay meaningful testimony over thetelephone that should assist you in your investigation, and allow the prosecution and defenseto adequately question him. Additionally, the witness would likely be non-responsive iftestifying over the telephone. Rather than rule him reasonably unavailable but available fortelephonic testimony, the United States requests the ability to produce him for in-persontestimony, if he is willing to participate in the hearing.5. The United States requests SFC Adkins be deemed not reasonably available based on thepreviously provided memorandum stating he intends to invoke his rights under Article 31. witness who is unavailable under Mil. R. Evid. is not ?reasonably available.'"RCM MRE 864(a)(1) incorporates in the claim of privilege against self-incrimination.6. W01 Balonek is not available for telephonic testimony based on the attached email statinghe intends to invoke his rights under Article 31. witness who is unavailable under Mil.R. Evid. is not ?reasonably available.'" RCM MRE 894(a)(1)incorporates in the claim of privilege against self-incrimination.7. As of three months ago, Inmate Whitfield was a represented party and the United States isworking to contact his civilian defense counsel to first determine whether he is still arepresented party, and then to request Inmate whitfield's cooperation with your order. Theconfinement facility is prepared to provide him access to a telephone for testimony.02919120v/rCPT Fein02216038From: Sent: Wednesday, December 14, 201 1 12:35 PMre: AImanza.va-rimcc: Manhewkemkesm;Morrow oDean, CPT USA SJ AOvergaard, Angel M. CPT USA yte, rey SJAHolzer, Mark LTC MIL USA OTJAGFein, Ashden CPT USA SJASubject: RE: Telephonic 802LTC Almanza,The defense objects to having the listed OCA witnesses testify by telephone. The defense's ability to questionthese witnesses will be frustrated by not having them in person. The defense intends to discuss classifiedinformation with each witness. In order to adequately do so, the defense will need to hand classifiedinfomration each individual witness. As such, having the witness testify by telephone will not ensure athorough and impartial Article 32 hearing.Additionally, the defense objects to each of the government's requests below concerning CPT Keay, SGTPadgett, SFC Adkins, W01 Balonek, and Inmate Whitfield. The government has had more than enough timeto ensure these witnesses were available to testify. The fact that a particular witness has made alternative plansshould not be held against the defense given our timely request for the witness.Best,DavidDavid E. Coombs, Esq.Law Office of David F-.. Coombs11 South Angell Street, #317Providence, RI 02906Toll Free: 1-800-588-41561 Local: (508)689-4616I Fax: (508) 689-9282Notice: This transmission, including attachments, may contain con?dential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleaseI notify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is 02219321FronnSentTo:Ck:Subject:Counsel -Almanza? Paul Wednesday, December 14, 2011 Matthew kemkes Morrow JoDean, CPT USA SJAOvergaard, Angel M. CPT USA SJA l; Whyte, Jeffrey H. CPT USA SJAHolzer, Mark LTC MII. USA OTJAGEein, Ashden USA SJARe: Telephonic 802Would you be available for a telephone conference at 1500 today? I'd like to discuss the issues concerning witnessavailability mentioned below.I am working on the other outstanding items.LTC Almanza 02919111From: Fein, Ashden CPT USA SJASent: Wednesday, December 14, 2011 1:es; Morrow JoDean, CPT USA JFHQ-hyte, Jeffrey H. CPT USA zer,Subject: Re: Telephonic 802Sir. No issues.02216029From: Sent: Wednesday, December 14, 201 1 1:39 PMNmanza? Paul Cc: Matthew kemkesMorrow Ill, JoDean, CPT USA SJAOvergaard, Angel M. CPT USA JFHQ- -, Whyte, Jeffrey H. CPT uszi SJAHolzer, Mark LTC MIL USA on/xoFein, Ashden CPT USA smSubject: RE: Telephonic 802LTC Almanza,I will be available on my cell at 1500.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Toll Free: 1-800-588-4156Local: (508)689-4616Fax: (508)689-9282Notice: This transmission, including attachments, may contain confidential attomey?clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is 02219311new mmanzamaun Sent: Wednesday, December 14, 201 1 2:34 PMTo: coombs@armycourtmaI1ialdefen se com; Cc: Matthew kemkesMorrow .|oDean, CPT USA SJAOvcrgaard, Angel M. CPT USA . . . SJAHolzer, Mark LTC MIL USA OTJAGFein, Ashden CPT USA SJA Subject: Re: Telephonic 802CPT Fein -I'll be available at Thanks.LTC Alrnanza 02919099From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Wednesday, December 14, 2011 2:36 PMTo: Almanza, Paul; Cc: Matthew kemkes; Morrow II oDean, CPT USA JFHQ-vergaa . nge . A JFHQ-NCRIMDW Whyie, Jeffrey H. CPT USA JFHQ-NCRIMDW SJA:Holzer, Mark LTC MIL USA OTJAGSubject: RE: Telephonic 802Sir,1500 works for the prosecution. I will initiate the phone call. Below are the government?sresponses and other comments of on-going issues:Excluding the Press. Sessions should only be closed as a last resort. The press is part ofthe public, and wholesale exclusion of the press is too broad. Again, the purpose of an openhearing is to subject the Article 32 to public scrutiny to ultimately enhance the public?sconfidence in our system. As the defense points out, this case already has media scrutinyand closing the hearing to the media will not achieve the purpose of the open hearing. Thisissue was contemplated by ACCA in its decision in Denver Post.OCA witnesses. The proposed testimony about alleged damage assessments is not relevant, andthe United States does not approval to turn over or use any damage assessments, if theyexists. Therefore, any proffered testimony by the defense will not be authorized to bediscussed. This is hypothetical testimony based on documents that may or may not exist. TheUnited States can affirm that some of the documents do exists and others do not. The UnitedStates is working on whether it has the authority to disclose the existence of the documentsto the defense, as requested by the investigating officer. Telephonic testimony, ifavailable, should suffice for the defense, prosecution, and investigating officer to have theopportunity to questions the declarants of all the sworn statements, for all but two of thedeclarations because those two are classified. If an OCA is available for telephonictestimony, then the United States will have a secure phone with speakerphone capabilityavailable for the defense, prosecution, and investigating officer to ask questions based onthose declarations.SGT Padgett and CPT Keay. At this point, we have been informed by the brigade judge advocatethat both Soldiers will likely be deemed not reasonably available. we are working thisprocedure and will provide any documentation, if this does occur.Government?s Time. The United States is working diligently to obtain the availability of allwitnesses you selected to provide testimony. The reason that CPT Keay, SGT Padgett, andInmate whitfield?s availability is taking longer than all the others is because none of thewitnesses were aware that the defense was asking for their participation in this Article 32.The first time any of them or their chains of command became aware, was after you publishedyour list. The United States does not prospectively notify individuals that they might becalled as defense witnesses, rather the United States coordinates travel and availabilityonce the investigating officer makes a determination, and there are no administrative issuesfor their production. The United States joins the defense in asking for your determination of what evidence youwill consider, so that the prosecution and defense will have time to ask for yourreconsideration, if needed.For administrative issues, the defense joins the United States in asking for you to pre-determine the format of the hearing. we offer that for taking testimony, the format be02919099similar to trial? direct, cross, re?direct, re?cross, and I0 questions. Additionally thatthere should be closing argument. The United States also asks For the ability to conduct avery limited opening statement that is limited to providing you a roadmap of the testimonyand the key pieces of evidence you will be reviewing. The defense does not join the UnitedStates in this request.v/rCPT Fein02219253From: Almanza, Paul LTC RES USAR USARC Sent: Wednesday, December I4, 20] 1 2:19 PMTo: Almanza, Paul Fein, Ashden CPT USA SJA Overgaard, Angel M. CPT USA SJAHolzer, Mark LTC MIL USA OTJAGMatthew kemkesyte, Je rey H. CPT USA SJAFein, Ashden CPT USA Morrow JoDean, CPT USA JFHQ- Cc: Subject: Determinations and Evidence List (UNCLASSIFIED)Attach: 28 USC 1746 Legislative Historynf; US v. Gunderrnan (67 MJ 683).rtf; Nissho-Iwai Kline (845 F2d Hart Hairston (343 F3d 762) 2003.rtf; Manning Article 32Def Obj to Gov Evid Deterrnin l2l4l l.doc; Manning Article 32 Evidence List12141 1.docClassi?cation: UNCLASSIFIEDCounsel -Three issues. listed below. And in addition to attaching the documents referenced in 1.. below. I am also attaching my detcnninationsregarding defense objections to evidence and my evidence list.I. Statements under penalty of perjury. I received legal advice from my legal advisor yesterday concerning whether a statementunder penalty of perjury constitutes a ?swom statement? permitting it to be considered over defense objection if the witness is notreasonably available. The advice was that in accordance with the text of 28 U.S.C. Section 1746, a declaration under penalty ofperjury is legally given "like force and effect? of a sworn statement and for purposes of consideration as an altemativc to testimony atthe Article 32 may be considered as a sworn statement. LTC Holzer also advised that the discussion to Article I31 (see para. 57c(3))mentions signing a summarized transcript of Article 32 testimony under penalty of perjury, which indicates that such statementssigned outside of an Anicle 32 hearing but associated with such an investigation can be considered. I also note that the classi?cationreview statements at issue all indicate that they arein the ?course of justice" as they all indicate the persons making the statements knew they were being prepared for use in this case.As such. I consider these statemems to have the same indicia of reliability as swom statements.Based on his advice and my review of the indicia of reliability, I intend to consider the statements made under penalty of perjuryprovided by RADM Kevin Donegan, Mr. Robert Betz. LtGen Robert VADM Robert Harward, Mr. Patrick Kennedy.RADM David Woods, and the person subscribing Bates numbers 00378148-00378175 and 00410623-00410634.LTC Holzer provided four documents, attached, supporting his advice:a. The legislative history of 28 U.S.C. Section 1746.b. US v. Gundermart 67 M.J. 683 (A.C.C.A. 2009)c. Nisslto-lwai v. Kline. 845 F.2d I300 (5th Cir. I988)d. Hart v. Hairston, 343 F.3d 762 (5th Cir. 2003).2. Request for reconsideration of closure deterrnination/request for media exclusion and gag order. I recognize that the defensedisagrees with my determination that reasonable alternatives to closure. such as thorough voir dire of the panel members andappropriate rulings and instructions by the military judge, would ensure that should this case be referred to trial. PFC Manning wouldreceive a fair trial. However. I do not believe that the defense has shown why these alternatives to closure are insufficient.Additionally, with respect to the reference to ?high-ranking officials hav[ing] made improper comments concerning PFCManning?s probable guilt and appropriate punishment." in Mr. Coombs?s I3 December 201 I email, I find that thorough voir direand appropriate nilings and instructions by the military judge will adequately address the risk of unlawful command in?uence. Itherefore deny the defense?s request for reconsideration of my closure determination. With respect to the defense?s request to exclude the media from discussion of the five topics at issue and to issue agag order preventing other witnesses from discussing those topics, those requests are denied.3. Invocation of Article 31/Fifth Amendment rights. The recommendation I received from my legal advisor was that once witnessesinvoke their Anicle 31 or Fifth Amendment rights. those witnesses are not reasonably available. LTC Holzer also recommended that02219253counsel for the witnesses be contacted to detennine whether there are any areas of inquiry that the witness could respond toquestioning without invoking their rights. Should it be the case that counsel indicate there are no areas that the witnesses will discussuithout invoking their rights. LTC Holzer recommended that the witness be called in lieu of relying on a mitten statement of theirintent to invoke their rights. Aceordiitgly. I intend to cull both SFC Adkins and WOI Balonek as noted belou.Tlumk _vou.LTC Alntanm0221 5966From: Sent: Wednesday, December 14, 20] 1 9:47 PMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Paul BouchardMenssa samiagom>Subject: Request for SupportCPT Fein,Pursuant to our conversation this evening, the defense requests that the government provide it with immediatepersonnel support. The defense needs one individual to provide physical control over the defense trailer duringthe hours of 2200 to 0800. The defense requests this support until its computer forensic work is completed.Currently, the defense team is ensuring that the trailer is guarded by counsel and CW2 Santiago.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Toll Free: 1-800-588-4156Local: (508)689-4616Fax: (508) 689-9282*"?Con?dentiality Notice: This transmission, including attachments, may contain confidential attomey-clientinfonnation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is 02219243From: Almanza, Paul LTC RES USAR USARC Sent: Wednesday, December 14, 201 1 10:47 PMTo: Almanza, PaulOvergaard, Angel M. CPT USA SJA Morrow .loDean, CPTUSA SJ A MatthewFein, Ashden CPT USA Holzer, Mark LTC MIL USA OTJ AGWhvte. Jeffrey H. CPT USA SJA Subject: Defense requested witness detemrinations, list of personal/telephone/other witnesses(UNCLASSIFIED)Attach: Manning Article 32 Defense Requested Witnesses Determinations 12141 1 .docClassification: UNCLASSIFIEDCounsel Attached are my determinations as to defense requested witnesses. and below is a list of the reasonably available witnesses I intend tohave appear personally, and for those witnesses who are not reasonably available, whether I intend to take their testimony by phone orto consider another alternative to testimony:SFC Paul Adkins (reasonably available in person)SPC Eric S. Baker (reasonably available in person)W01 Kyle J. Balonck (not reasonably available by telephone)SA Troy Bettencoun (reasonably available in person)SSG Peter Bigelow (not reasonably available - by telephone)CPT Thomas Cherepko (not reasonably available by telephone)SA Antonio Edwards (reasonably available in person)CPT Casey Fulton (reasonably available in person)SA Toni Graham not reasonably available by telephone)Mr. Mark Johnson (reasonably available in person)Mr. Adrian Lame (reasonably available in person)CPT Steven Lim (reasonably available in person)SGT Chad Madaras (not reasonably available by telephone)Brian Madrid (not reasonably available by telephone)SA Mark Mander (reasonably available in person)Mr. Jason Milliman (not reasonably available by telephone)SA Calder Robertson not reasonably available by telephone)SA David Shaver (reasonably available in person)Ms. Jihrleah Showman (not reasonably available by telephone)SA Alfred Williamson (reasonably available in person)CPT Barclay Keay (not reasonably available by telephone)SGT Daniel Padgett (reasonably available in person)Inmate Christopher Whit?eld (not reasonably available - by telephone)RADM Kevin Donegan (not reasonably available statement under penalty of perjury)Mr. Roben Betz (not reasonably available statement under penalty of perjury)LtGen Robert Sehmidle (not reasonably available - statement under penalty of perjury)VADM Robert I-larward (not reasonably available statement under penalty of perjury)Mr. Patrick Kennedy (not reasonably available statement under penalty of perjury)RADM David Woods (not reasonably available statement under penalty of perjury). Person subscribing Bates numbers 00378148-00378175 and 00410623-00410634 (not reasonably available statement underpenalty of perjury)Classi?cation: UNCLASSIFIED02219237From: Almanza, Paul LTC RES USAR USARC Sent: Thursday. December I5, 20l I lI.l3 AMTo: Overgaard, Angel M. CPT USA SJA Whyte. Jeffrey H. CPT USA SJA Almanza, PaulMatthew kemkes Ilolzer, Mark LTC MIL USA OTJAGUSA SJA I2; Fein, Ashden CPT Morrow looean, CPT USA SJASubject: Reconsideration of closure determination and defense requested witness detemiinations.list of personal/telephone/other witnesses (UNCLASSIFIED)Classification: UNCLASSIFIEDAll -After my denial of the defense closure request and the defenses request in the alteniatiie that I remove the media duringany discussion as to the Five topics zit issue and issue a gag order coneeniing those topics. my uneliniiged.I will amend the witness lists bCi0\\ to Initiate Wliitfield. As soon as I have the ability to amend thosedocuments and send them to you. I will.FYI. I am also uorking on a for the and will In\'llC _\Ollr on it this aftcnioon 02914952From: Fein, Ashden CPT USA SJASent To:Cc: Morrow Ill, JoDean. CPT USA JFHQ-NCRIMDW Overgaard, Angel M. CPT USAW01 USA (NSD) Whyte, Jeffrei H. CPT USA Ford, Arthur D.Subject: US v. PFC BM (Update)Happy new year! I hope all is well. Are you available in the next week (after Tuesday, 3Jan) for us to come over and discuss the way Forward with the FBI case file and the damageassessment? Because of the volume of information, a meeting sooner than later is preferred.Thank you.V/r?Ashden02914946From:SentTo:Cc:Subject:Sir,Happy new year!Fein, Ashden CPT USA SJAMonda Janua 02, 2012 9:26 PMMorrow Ill, JoDean, CPT USA Overgaard, Angel M. CPT USAJFHQ-NCRIMDW Whyte, Jeffrey H. CPT USA JFHQ-NCRIMDW Ford, Arthur D.W01 USA SJA:US V. PFC BM (Update)I hope all is well. Are you available in the next week (after Tuesday, 3Jan) For us to come over and discuss the way forward with the DIA PSR (we already received,but possibly incomplete) and the damage assessment, if any? Additionally, we would like todiscuss the possibilities of having some DIA ?experts? as witnesses For a CM, if the case isreferred.v/rAshdenThank you.02914944From:Sent:To:Cc:Subject:Happy new year!Fein, Ashden CPT USA SJAMonda ,Janua 02, 2012 9:29 PMnew oecMorrow JoDean, CPT USA JFHQ-NCFUMDW Overgaard, Angel M. CPT USAJFHQ-NCRIMDW Whyle. Jeffrei H. CPT USA JFHQ-NCRIMDW Ford, Arthur D.WO1 USA JFHQ-NCRIMDW SJAUS V. PFC BM (Update)(NSD) I hope all is well. Are you available in the next week (after Tuesday, 3Jan) For a phone conversation to discuss the DOD Thank you.v/r?Ashden02914942From: Fein, Ashden CPT USA SJASent: Monda Janua 02 2012 9:31 PMTo: Cc: Morrow Ill, JoDean, CPT USA Overgaard, Angel M. CPT USAWhyie, Jeffre H. CPT USA Ford, Arthur D.Subject: US V. PFC BM (Update)Happy new year! I hope all is well. Are you available in the next week (after Tuesday, 3Jan) For us to come over and discuss the way Forward with the D05 PSR, damage assessment (ifany), and discuss the need For certain expert witnesses For the merits and sentencing? Ialso remember from before the break, that, and? thought it might be a good idea forus to sit down on these issues with a ?'larger?? audience. Are you available For a preliminarymeeting to discuss the issues above? Thanks.V/rAshden02916092From:Sent:To:Cc:Subject:Attachments:Importance:Sir,Happy New Year!Fein, Ashden CPT USA SJATuesday. January 03, 2012 12:35 PMAlmanza, Paul LTC RES USAR USARCCPT USA Holzer, Mark LTC MIL USA Matthew kemkes;Whyte, Jeffrey H. CPT USA Morrow JoDean, CPT USA JFHQ-Ford, Arthur D. W01 USA JFHQ-SJAUS v. PFC BM (Article 32 Update)Article 32 Transcn'pt.pdf; Article 32 Exhibits.pdfHighAttached is the unclassitied portion of the hearing's summarized transcriptalong with an exhibit list. Ms. Williams finished these on 28 Dec 11. The classified portionis ready for your review at MDN and we will deliver a copy to the defense by tomorrowafternoon.Additionally, the United States asks that you exclude, as a reasonable delay, anytime between22 December 2011 and 3 January 2912 that you did not work on the Article 32 investigationbased on the federal holidays and weekends.Thank you.v/rCPT FeinOvergaard, Angel M.02915776From: Fein, Ashden CPT USA SJASent: Wednesday, January 04, 2012 7:24 AMTo: coombs Cc: il; Overgaard, Angel M. CPT USA Holzer, Mark LTC MIL USA Matthew kemkes; Whyte. Jeffrey H. CPT USA JFHQ-Morrow Ill, JoDean, CPT USA Subject: US v. PFC BM (Excludable Delay Accounting 8. Admin)Attachments: 120103-Excludable Delay Memorandum.pdfDavid,Good morning and happy new year. Attached is the most recent excludable delay accountingmemorandum signed by the As we continue discovery production over the next few days,where would you like us to send the information/documents and starting on what date? I wouldlike to make sure you are back in your o?ice bewcore we start sending the CD5.Thank you.v/rAshden02914894From: Fein, Ashden CPT USA SJASent: Wednesday, January 04, 2012 10:56 AMTo:cc: Morrow HI. JoDean. CPT USA Overgaard, Angel M. CPT USAJFHQ-NCRIMDW Whyte, Jeffrey H. CPT USA JFHQ-NCRIMDW Ford, Arthur D.W01 USA JFHQ-NCRIMDW Subject: RE: US V. PFC BM (Update)-3Thank you. Are you available tomorrow morning?V/rAshden02561291From:Sent:To:Cc:Subject:?@ic.fbi.gov>Wednesday. January 4, 2012 5:00 PMFein, Ashden CPT USA JFH SJA 1 ic.fbi.gov>Morrow Ill, JoDean, CPT USA SJAOvergaard, Angel M. CPT USA JFHQ-Jeffrey H. CPT USAFord, Arthur (Update)Ashden - How does Friday at 1 pm at FBIHQ work for you? If not, then we'll have to try something early next week.02565206From:Sent:To:(Tc:Subject:Almanza, Paul LTC RES USARC Wednesday, January 4, 2012 7:02 PMFein, Ashden CPT USA SJAAngel M. CPT USA SJAHolzer, Mark LT TMII. USA OTJAG (-Matthew kemkesSJA Jeffrey CPT Morrow Ill, JoDean, CPTFord, Arthur (Article 32 Update) (UNCLASSIFIED)Clussi?catioll: UNCLASSIFIEDCPT Fcin -I will exclude as a dcla} the days between 23 December 20 II and 3 Janmuy 2t)I2 hen I did not uork on theArticle 32 Investigation.Almnn/n02924578From: Fein, Ashden CPT USA SJASent: Thursda Janua 05, 2012 9:44 AMTo: ?000 oecCc: Morrow JoDean, CPT USA SJASubject: one more question1Thank you for your assistance. There was one more entity that I would like to brieflydiscuss? OSD. Are you available ?or a follow?up phone conversation?V/rAshden02914869From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Frida .Janua 06. 2012 2:57 PMTo: .Cc: orrow ean, PT USA Overgaard, Angel M. CPT USAJFHQ-NCRIMDW SJASubject: RE: US V. PFC BM (Update)Sir,How about Thursday at 1166? Our proposed topics are the damage assessment and the wayforward, possible DIA expert on some intel issues for trial, and to give you a generalupdate. If there is anyone you think would be appropriate for those topics, please feel Freeto invite. Thank you.v/rCPT Fein02914865From: Fein, Ashden CPT USA SJASent: Frida Janua O6 2012 3:27 PMTo:Cc: rrow . ean. CPT USA (JMD)Subject: RE: US v. PFC BM (Update) -Thursday is fine.Please let us know what time? sooner the better. 02914852From: Fein, Ashden CPT USA SJASent: Frida Janua O6 2012 5:59 PMTo:Cc:Subject: RE: US v. PFC BM (Update)Sir,wednesday at 1399 works. Thank you.V/r?CPT Fein02914848From: Fein, Ashden CPT USA SJASent: Fn'da Janua 06 2012 6:01 PMTo:Cc: Morrow JoDean. CPT USA (JMD)Subject: RE: US v. PFC BM (Update) we are free on Monday afternoon. Please let us know what time. we will be at the from 1939 until possibly 1280. So anytime after 1 should be good.Thanks.Ashden 02926426From: Fein, Ashden CPT USA SJASent: Tuesday, January 10, 2012 10:06 AMTo: Morrow m, JoDean. CPT USA Overgaard,An el M. CPT USA SJACc:Subject: mee mg yes er ay LASSIFIED)Attachments: Discovery Ob|igations.pdfA11- attached is the digital copy of the discovery obligations we have underthe military justice system.Thank you for yesterday's meeting!v/r?Ashden02560843 IFrom: @osd.miI>Sent: Tuesday, January 10, 2012 4:22 PMTo: Fein, Ashden CPT USA SJA Subject: PSR ManningAttach: PSR U.S. Department of Defense Of?ce of General CoumelI600 Defense Pentagon, Room 3B688Washin ton. D.C. 20301-160002915785From: Fein, Ashden CPT USA SJASent: Tuesda ,Janua 10, 2012 5:09 PM To: USA OTJAGCc: USA Morrow JoDean, CPT USA SJASubject: US v. PFC BM PSR)Attachments: PSR Manning.pdfSir,Good afternoon. As you will remember from the meeting you and I attended at LitigationDivision, OGC-DOD, the prosecution submitted to a prudential search request For our case.I was told by ?that DA has not responded to the DOD request (on our behalf).Could you please assist by determining what the status of DA's return on this prudentialsearch request. we are getting very close to referral, if any, and would like to ensure wehave adequate time to review any relevant material. Attached is the DOD memo. Thank you.v/rAshden02562361 From USARMY (us) USARMY (us)Sent Tuesday, January 10, 2012 5:18 PMTo: Fein Ashden CPT USA SJACc: USA Morrow JoDean, CPT USA JFHQ-SJASubject: RE: us v. PFC BM (DOD PSR) (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOAshden - Yes I'll follow up with DA OGC.0F?ice of The Judie Advocate GeneralBB: 02564918From: Sent: Thursday, January 12, 2012 9:03 AMFein, Ashden CPT USA SJA Cc: Overgaard, Angel M. CPT USA SJAMatthew kemkesWhyte, Jeffrey H. CPT USA Morrow JoDean, CPT USA IFI-IQ-SJAJoshua ToomanSubject: Deposition RequestAttach: Manning Deposition Request.pdfAshden,have attached a deposition request for the OCAs. I would like to start the depositions towards the middle ofFebruary. Ideally, we could conduct all of the depositions in the D.C. area over several days.On a side note, my office has not received any additional discovery. Have you sent anything to me yet??Best,DavidDavid Coombs, Esq.Law Office of David E. Coombs1 South Angell Street, #317Providence, RI 02906Toll Free: l-800-588-4156Local: (508) 689-4616Fax: (508) 689-9282 Notice: This transmission, including attachments, may contain confidential attomey-clientinfonnation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this infonnation may beunlawful and is 02916287From: Fein, Ashden CPT USA SJASent: Thursday, January 12, 2012 2:00 PMTo: Cc: Kemkes, Matthew MIL Paul Bouchard; Morrow m,JoDean, CPT USA Overgaard, Angel M. CPT USA JFHQ-Whyte, Jeffrey H. CPT USA SJASubject: US v. PFC BM (Article 32 Rec)Attachments: (U) 120112 - DD Form 457.txthnponance: I?ghDavid,The IO finished his report late yesterday and we finished scanning the report this morning.Attached is the main report. Please save the file from ?.txt? to ?.exe? and usingour standard password. we will overnight mail the full investigation and other discovery toyou and will deliver a copy to Ft Myer today, including two copies of the classifiedmaterial. I will send out the tracking number later today.we intend to present the report to the this afternoon so that he can start reviewingthe report immediately.v/rAshden02564909From: Sent: Monday, January 16, 2012 3:39 PMTo: Fein, CPT USA SJA Cc: Overgaard, Angel M. CPT USA SJAMatthew kemkesWhyte, Jeffrey H. CPT USA Morrow IH, JoDean, CPT USA IFHQ- SJA l>Subject: Deposition Request 2Attach: Deposition Request 2.pdfAshden,Please ?nd the attached deposition request. As with the former request, I would like to conduct the depositionsin February and in the D.C. area.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angeli Street, #317Providence, RI 02906Toll Free: 1-800-588-4156Local: (508) 689-4616Fax: (508) 689-9282Notice: This transmission, including attachments, may contain con?dential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this infonnation may beunlawful and is prohibited."*02918428From: Fein, Ashden CPT USA SJASent: 2012 7:30 AMCc: orrow 0 ean, USA SJASubject: RE: TodayThanks. we are running out of time and want to get ahead of this. Also, just as a warning,we have finished going through EVERYTHING else. we are tidying up the last pieces and thenwill coordinate with everyone by the end of the week to get the first batch to all 1Ashden02560473Sent: Wednesday, January 18, 20l2 8:56 AMTo: Fein, Ashden CPT USA SJA Subject: TodayWe'll bring il over. hat is the last scriaUdalc of the stuff you lnvc?02915942From:SentTo:Cc:Subject:Attachments:David,Fein, Ashden CPT USA SJAWednesday. January 18, 2012 10:52 AMOvergaard. Angel M. CPT USA Matthew kemkes; Whyte, Jeffrey H. CPT USA Morrow Ill, JoDean,CPT USA Joshua ToomanUS v. PFC BM (Deposition Requests)Response to Requests for Oral Attached is the action on the defense deposition requests.v/rAshden02915102From: Fein. Ashden CPT USA SJASent: Wednesday, January 18, 2012 7:10 PMTo: Cc: Overgaard. Angel M. CPT USA Matthew kemkes; Whyte, Jeffrey H. CPT USA JFHQ-NCRIMDW Morrow JoDean,CPT USA SJAJoshua ToomanSubject: US v. PFC BM (Transmittal)Attachments: 120118-Additional Cha rges Transmittal (Redacted).pdfImportance: HighDavid,Today, the transmitted the case to the GCMCA with a recommendation ?or a GCM.Attached is the redacted transmittal.Have a good night.v/r?Ashden02564854From: Bouchard, Paul cm? USARMY (us) Sent: Wednesday, January 18, 2012 9:30 PMTo: Fein, CPT USA SJ A Parra, Jairo A. W01 USA SJFeito, Beatriz SGT USA JFHQ- SJA Cc: Manning 'I?eam Matthew kemkes Tooman, Joshua] CPT USARMY (US)Subject: Request additional funding, computer forensics team, US v. Manning (UNCLASSIFIED)Attach: request additional ll-P-0079 AWD.doc; Appointment of Forensic Computer Expert (ManningB).pdfClassification: UNCLASSIFIEDCaveats: FOUOAshden,The first attachment is our request for additional funding for the Defense's computer forensics team. The otherattachments are pertinent supporting documents.Please acknowledge receipt of these.Thanks,PaulClassification: UNCLASSIFIEDCaveats: FOUO02921417From: Fein. Ashden CPT USA SJASent: Wednesday, January 18, 2012 9:46 PMTo: Bouchard, Paul CPT USARMY Parra. Jairo A. W01 USA Feito, Beatnz SGT USA JFHQ- SJACm Subject: RE: Request additional funding, computer forensics team, US v. Manning (UNCLASSIFIED)Paul,I acknowledge receipt. Because the case was transmitted to the GCMCA today, we owe you ananswer (hopefully by Friday) on whether we will take this to the or need you to re-draft the memo for the GCMCA. Additionally, we have to work contracting to figure out if thechange of the approving official changes the contract. we have already started to figurethis out.Additionally, what I don't see in your request is a breakdown of the total number of hoursthat you are requesting for your expert services. Please remember that because CyberAgentsbills per hour, your estimate and request needs to be in the form of total number of hours.I assume your math works, but the convening authority will authorize a certain amount ofmoney based on the proposed hours. As with all expert requests, we will take your requestand get input from our expert on whether it is reasonable before going to the conveningauthority.As you know, we are also trying to work through the "overage" that was caused during theArticle 32 when CyberAgents billed more than the convening authority authorized. Heauthorized no more than $14,000 to be spent and specifically required an additional writtenrequest before any more services may be rendered. Because this didn't happen and the changeof the convening authorities, we are working with contracting to figure out the way forward.At first glance, it appears the work which was previously performed and over $14,000 was notauthorized under the contract.we are here to assist and get this right so that the proper resources may be allocated toassist your client in his defense. I do not foresee a problem with getting this requestapproved, but we have to have a proper request, with the justified basis (number of hours andwhy, with some $pecificity).Thanks!v/rAshden02564852From: Bouchard, Paul PT IJSARMY (US) Sent: Thursday. January 19, 2012 9.02 AMTo: Fein, Ashden CPT USA SJAParra, Jairo A. WOI USA SJFeito, Beatriz SGT USA JFHQ- SJACc: Manning Team Matthew kemkes Subject: Request additional funding, computer orensics team, U. v. Manning(UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: Okay. Tlumks Can I call you this mommy. to discuss??Paul02564843From: Bouchard, Paul cm usmwv Sent: Thursday. January 19, 2012 2:46 PMTo: Fein. Ashden CPT USA SJA Subject: RE: Request additional funding, computer forensics team, US v. Manning(UNCLASSIFIED)Attach: request additional funding for computer forensics team I .docClassi?cation: UNCLASSIFIEDFOUOAshden.The attzicluncnt is our First request outlining total labor costs thus far and why we didn't submit a n'ttcn rcqucst when the approved threshold was reached. We are tsking for I 1.200 to cover Erick and Trent's work which now totals 525.200.Please let me know what you think.l'rn working on 011!? second request right now. the one outlining why Eric and Trent are con?dent they can complete the work withinI60 hours. That will be a request for an zrdditioml $28.000.00 (160 at I75 per hour).Thanks.Paul02564840From: Bouchard, Paul us/mmv (us) Sent: Thursday, January 19, 2012 5:37 PMTo: Fein, Ashden CPT USA SJA Subject: message from CPT Bouchard (UNCLASSIFIED)Attach: request additional funding for computer forensics team2.docClassification: UNCLASSIFIEDCaveats: FOUOAshden,This is our second request, the one asking for $28k.Do let me know who the convening authority is, and let me know your thoughts on these two requests.Thanks,PaulClassification: UNCLASSIFIEDCaveats: FOUO02564837 From: coombs@am1ycour1martialdefen secomSent: Friday, January 20, 20l 2 2:24 PMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Bouchard, Paul CPTTooman, Joshua CPT USARMYMorrow JoDean, CPT USA Overgaard, Angel M. CPT USAWhyte, Jeffrey H. CPTFord, Arthur D. WOIUSARMY (us)(US)SJASJAUSA SJA USA SJA Subject: Defense Discovery RequestAttach: Discovery Request - 20 Jan l2.pdfAshden,Please ?nd the attached defense discovery request. Additionally, I plan to submit a deposition request to MGLinnington over the weekend. Could you provide me with his correct "memorandum for" information? Thankyou.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Toll Free: I-800-S88-4156Local: (508) 689-4616Fax: (508)689-9282Notice: This transmission, including attachments, may contain con?dential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is 02939012From: Fein, Ashden CPT USA SJASent: Friday. January 20, 2012 3:15 PMTo: Cc: Matthew kemkes; Bouchard, Paul CPT USARMY Tooman, Joshua CPT USARMYMorrow JoDean, CPT USA JFHQ-NCRIMDW Ovengaard, Angel M. CPT USAWhyie, Jeffrev H. CPT USA Ford. Arthur D.W01 USA SJASubject: RE: Defense Discovery RequestDavid,Thank you. we will start working on this discovery request and we intend to give updatedanswers to all your previous requests by the end of next week.As for the GCMCA, we use the following for memorandums:MEMORANDUM FOR Commander, U.S. Army Military District of Washington, Fort Lesley 3. McNair,DC 20319-5058Additionally, as you might know, "bradleymanning.org" has called for supporters to fax,email, mail, and call the GCMCA to provide support for your client. we intend to recommend,through the SJA, for the GCMCA not to review any documentation by supporters, unless thedefense submits the matters for his consideration. we intend to work with the command groupto ensure all documentation is gathered and provided to us, so that we can expeditiouslyprovide the defense copies in discovery. our intent is to ensure the GCMCA only reviewsmaterial in the record and makes a referral decision based on the investigation, alliedpapers, defense submissions, and ultimately on the SJA's advice under Article 34, UCMJ.Have a good weekend.v/rAshden 02932878From: Fein, Ashden CPT USA SJASent: Monday. January 23, 2012 5:44 AMTo: Cc: Matthew kemkes; Bouchard, Paul CPT USARMY Tooman, Joshua CPTUSARMY Morrow Ill, JoDean, CPT USA Overgaard, Angel M.CPT USA Whyte, Jeffrey H. CPT USA Ford,Arthur 0. W01 USA Subject: RE: GCMCA Deposition RequestDavid,Thank you. I acknowledge receipt and we will start processing this request through theMilitary Justice section for the GCMCA.v/rAshden02939006FrontSentTo:Cc:Sumem:Paul,Please see below.resolution. Big issue- factual accuracy in the request billing.Fein, Ashden CPT USA SJAMonday. January 23, 2012 9:12 AMBouchard, Paul CPT USARMY (US)Overgaard, Angel M. CPT USA Parra, Jairo A. W01 USA JFHQ-SJADefense Expert Funding (UNCLASSIFIED)I am kicking this to Angel Overgaard so we can get speedyIrecommend making these changes and then sending them back to us for action.The new requests should be addressed to the Commander, MDN (as per the MEMOFOR line I sent Dave Coombs).Ashden02564830From: coombs@annycourtmartialdefense comSent: Monday, January 23, 20l2 |2:2l PMTo: Fein, Ashden USA SJA Cc: Matthew kemkes Bouchard, Paul CPT Tooman, Joshua CPT USARMYMorrow Ill, JoDean, CPT USA IFHQ-Overgaard, Angel M. CPT USAWh te, Jeffrey H. CPTcl, Arthur D. WOIUSARMY (us) SJAUSA SJAUSA SJA Subject: GCMCA Deposition RequestAttach: GCMCA Deposition Request.pdfAshden,Please see the attached deposition request.Best,DavidDavid E. Coombs, Esq.Law Office of David E. CoombsI I South Angell Street, #317Providence, RI 02906Toll Free: 1-800-588-4156Local: (508)689-4616Fax: (508)689-9282Notice: This transmission, including attachments, may contain con?dential attomey?clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is 02912754 From: Fein, Ashden CPT USA SJASent To: Cc: Morrow Ill, JoDean, CPT USA SJASubject: yesterday damageGents-Thank we thought the meeting went very well and please pass our thanks to Please let us know what you need from us. I know we owe you a breakdown o-F estimatedtimelines and priorities Additionally, we would like to chat about theFollowing three topics:1. way Forward with us looking at the DRAFT damage assessment2. way forward with PSR Thank you again.Ashden02920430From: Fein, Ashden CPT USA SJASent: Wednesda ,Janua 25, 2012 9:20 AMTo:Cc: Morrow JoDean, CPT USA JFHQ-NCRIMDW SJASubject: RE: Secure Call TodayThanks. I wanted to give you both an update on our review of the FBI file (almost Finished)and ask a question about damage/impact statements, if any.02564773From: Bouchard, Paul CPT USARMY Sent: Wednesday, January 25, 2012 I I AN1To: Overgaard, Angel M. CPT USA DW SJACc: Parra, Jairo A. WOI USA SJFein, Ashden CPT USA SJA Feito, Beatriz SGT USA JFHQ- SJA Subject: Defense request for additional Funding, US v. Manning (UNCLASSIFIED)Attach: request I Appointment of Forensic Computer Expert(ManningB) pdf, 1 l-P-0079 AWD_doc; request 42.pdfClassi?cation: Caveats? FOUOOvergaard.The attachments are Defense requests for additional funding, matter of US Manning. It also includes supporting documents.CPT Fern brought up good points in his recent c-mail. I've addressed those and edited our requests Please aeknou ledge receipt. and Contact me should you have any issues or concernsRespoctfullv.Pl? Paul BoucltardDefense Counsel02557995From: Overgaard, Angel M. CPT USA SJASent: Wednesday, January 25, 2012 5:24 PMTo: 'Bouchard, Paul CPT USARMY Cc: Fein, Ashden CPT USA JFHQ-NCRIMDW Parra, Jairo A. W01 USA JFHQ-NCRIMDWFeito, Beatriz SGT USA JFHQ- SJASubject: RE: Request for additional funding, 42k, US v. Manning (UNCLASSIFIED)Attachments: request42new.pdfClassi?cation: UNCLASSIFIEDCaveats: FOUOCPT Bouchard:I'm a little confused by this request. Your request that I looked at yesterdayfor the 528k made sense because the reasons you gave were that Mr. Lakes andMr. Struttman estimated they would work an additional 166 hours each.It is not clear (at least to me) From this request where the $42k amount iscoming From. $14k was already approved with an additional $11k requested, andthe old contract was ?or $56k. As CPT Fein stated, the $56k number is nolonger applicable because we will have to do a new contract. Could you pleaseclarify where the $42k Figure is coming from or let me know if I am missingsomething? Thanks!Angel02564764From: Bouchard, Paul Cl"l? USARMY (US) Sent: Thursday, January 26, 2012 9:22 AMTo: Overuaard, Angel M. CPT USA DW SJACc: Fein, Ashden CPT USA SJAParra, Jairo A. WOI USA SJFcito, Beatriz SGT USA SJASubject: RE: Request for additional funding, 42k, US v. Manning UNCLASSIFIEDCat-eatsf FOLIOAnge l.did make a slight error. We should have requested and not -I. request for additional funding. laysit otrt:Eric and Trent were approved for IJK. Thus far. their nod; totals 325.200. so we're respectfully asking that an additional $1 |.2tr0 beapproved for their work thus far.Eric and Trent are slated to come here for It) day 5 (Feb. 7) and complete the vyork. Ten days means 80 hours each (8 hours perday so I60 hours for both of them. Eric and Trent are confident they can complete the work in I60 hours (again. thus far. the_v'vespent I-I-I hours). I60 hours at per hour equals $28,000.00I should have requested SI l.2t)0 plus 328.000 equals $39.2tX).t)tt_ not (The 42K came from l4l~'. already approvedplus asking for 28.000 more). However. like paragraph 4 of our other request states. Erie and Trent will bill their work per hour.Maybe they'll be done in Hill hours. maybe I I0. Maybe they'll need I75 hours. Bottom line. they believe thc_v can finish the computerforensic vvork WITHIN lot) hoursThe CA will approve (we hope) whatever Ire believes to be fair. 39K is fair. So is 42K.Hope this clears it up. Good catch. I was olTv\itlr the math We're in the ballpark though. and again. [inc and Trent \\ill onlybill for the vvork they do.Thanks.Call or c-mail me if_vou have any questions.PattlIj02921359 From: Fein, Ashden CPT USA SJASent: Thursday, January 26, 2012 11:13 AMTo: Bouchard, Paul CPT USARMY Overgaard. Angel M. CPT USA SJACc: Parra, Jairo A. W01 USA Feito, Beatriz SGT USA SJASubject: RE: Request for additional funding, 42k, US v. Manning (UNCLASSIFIED)Paul-we are trying to make this as simple as possible For EVERYONE, including the CA. I recommendyou just make a request For what you need and disregard past acts . Just what you need andwhy. you need them to work 110 more hours, then ask For that and provide thejustification For 110 more hours. IF its only 160 more hours, then that amount, or 150hours, that amount. Don't worry about the past amounts or the billing issue with the overageor the previous contract.take of hours to complete. we will take that to our expert and the convening authority.Just a simple expert Funding request For of hours For a total of The reason it willAshden02557977From: Parra, Jairo A. W01 USA SJASent: Thursday, January 26. 2012 1:35 PMTo: 'Bouchard, Paul CPT USARMY Feito, Beatn'z SGT USA JFHQ- SJACc: Overgaard, Angel M. CPT USA Fein, Ashden CPT USA JFHQ-SJA: Ford, Anhur D. W01 USA SJASubject: RE: Travel for Mr. Lakes and Mr. Struttmann (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,To make things clear and avoid future complications with payments and/orcontracts, Eric Lakes and/or Trent Struttman (Cyberagents) are notauthorized to travel or perfume any work without a written consent/approvalby the CA. The Government cannot schedule or approve any travel prior tothe CA's approval of the defense request for an expert witnesses. AllowingMr. Lakes and Mr. Struttman to travel or perform any labor on behalf of thedefense prior to the CA's approval would constitute a violation of fiscallaw. This would ultimately be considered an unauthorized commitment ofgovernment funds. Needless to say, there is a legitimate urgency in regardsto this request. The defense team must be able to get the request toappoint an expert witness to the government as soon as possible for the CA'saction. In the mean time, I will begin to work with the MICC at Fort Myer,to ensure that a contract is awarded if and when the CA acts on thedefcnse's request. If you have any questions please feel free to contact meat your earliest convenience.v/r,JPJairo A. ParraN01, JALegal AdministratorJFHQ-NCR, MDN The information contained in this email and any accompanyingattachments 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 Defensewithout prior authorization from the Office of The Judge Advocate General,Department of the Army. If you are not the intended recipient of thisinformation, any disclosure, copying, distribution, or the taking of anyaction in reliance on this information is prohibited. If you received thisemail in error, please notify this office immediately by return email (see 51 02561275From: _@ic.ibiAsov>Sent: Thursday. January 26, 2012 2:00 PMTo: Fein Ashden CPT USA JFH SJA @ic.fbi.gov>Cc: Morrow JoDean, CPT USA SJASubject: RE: Secure Call TodayGmat. I'm in the o?icc today if_\ou an to give me .1 call. My desk phone is .1 STE Thanks!02564761From: Bouchard, Paul CPT USARMY (US) Sent: Thursday, January 26, 2012 2:58 PM To: Overgaard, Angel M. CPT USA SJAOvergaard, Angel M. CPT USA JFHQ-Cc: Fein, Ashden CPT USA SJAParra, Jairo A. USA SJFeito, Beatriz SGT USA JFH - SJASubject: Request for additional funding (UNCLASSIFIED)Attach: request additional funding 28 signedpdfClassification: UNCLASSIFIEDCaveats: FOUOAngel,We're requesting an additional $28,000.00. Recently spoke to Ashden on this. E-mail or call me if need be.PaulClassification: UNCLASSIFIEDCaveats: FOUO02564758From: Bouchard, Paul CPT USARMY (US) Sent: Friday, January 27, 20 I2 5:01 PMTo: Overgaard. Angel M. CPT USA SJACc: Fein, CPT USA SJA Parra, Jairo A. WOI USA SJFeito, Beatriz SGT JFHQ- SJASubject: RE: Request for additional funding (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCnvetits. FOUOAngel.Do let me know ifonr request is approved. I knoxx it's not your call. but Enc and Trent. the Defense computer expert .1Cc: "Matthew kemkes"CPT USARMY CPT USARMY CPT USA "Overgaard, Angel M. CPT USA "whyte, Jeffrey H. CPT USA"Ford, Arthur D. "Bouchard, Paul Tooman, Joshua "Morrow JoDean, W01 USA David,In the past 4 emails (including this one), I sent you the same discovery responses as before, but in adifferent format. This should fix the issue you identified.As for the contact information for Mr. Betz, Ambassador Kennedy, and Mr. Roland- All three are notcurrently identified as government witnesses. If they are identified as witnesses, then their contactinformation will be provided pursuant to the government's requirements under Article 46, UCMJ andrelevant portions of the RCM. If this is not responsive, the defense is invited to renew its request witha more specific basis and the proper authority for receiving the contact information.Although we responded the defense will receive the remainder of our responses by Friday (focusingon damage assessments, if any), we hope to have the authority to respond by tomorrow.v/rAshden02564754From: Bouchard, Paul CPT USARMY (US) Sent: Tuesday, January 31, 2012 10:57 AMTo: Overgaard, Angel M. CPT USA SJACc: Fein, Ashden CPT USA SJA Parra, Jairo A. W01 USA SJFeito, Beatriz SGT USA JFHQ- SJASubject: Question from Paul Bouchard (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOAngel,Don't mean to be a pest, but just wondering on the money approval issue for the Defense's computer forensics team.Any word yet? My concern is Eric and Trent blocked off Feb 8-17 to come here and finish the work. There travel has tobe booked by the Government, and apparently that won't happen until the money is approved.Any feedback appreciated.PaulClassification: UNCLASSIFIEDCaveats: FOUO02557773From: Parra, Jairo A. WO1 USA SJASent: Tuesday, January 31, 2012 11:57 AMTo: 'Bouchard. Paul CPT USARMY Overgaard, Angel M. CPT USA SJACc: Fein, Ashden CPT USA Feito, Beatriz SGT USA JFHQ- NCRIMDWSJASubject: RE: Question from CPT Paul Bouchard (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,As far as your expert witness questions are concern, I have all thedocuments required to execute the contract and Eric Lakes? (also TrentStrauttman) travel has been reserved, pending my final approval, for thedays you have requested. However, we are waiting for the CA to appoint themas part of the defense team as your expert consultants/witnesses. After theappointment has been approved by the CA, the CA's approval is sent tocontracting command to issue a contract. The government cannot get ahead ofthe contracting process and must wait for all the steps to occur prior toexecution. I'm confident that we will be able to execute all requirementsprior to the current scheduled dates of travel and Cyber Agents, INC. willbe able to perform their required work, but as you can see, there is achance where it may not happen as planned; I ?m just not able to guaranteethe whole process 196%. Please rest assured we are working this as a toppriority and will do everything in our power to execute this as soon aspossible. Thank you for your patience and understanding in this matter; Iknow this can get a bit frustrating.v/r,JPJairo A. Parrawo1, JALegal Administrator The information contained in this email and any accompanyingattachments 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 Defensewithout prior authorization from the Office of The Judge Advocate General,Department of the Army. If you are not the intended recipient of thisinformation, any disclosure, copying, distribution, or the taking of anyaction in reliance on this information is prohibited. If you received this102948376From: Fein, Ashden CPT USA SJASent: Tuesday, January 31. 2012 4:49 PMTo: Cc: Matthew kemkes; Bouchard, Paul CPT USARMY Tooman, Joshua CPTUSARMY Morrow JoDean, CPT USA Overgaard, Angel M.CPT USA Whyte, Jeffrey H. CPT USA JFHQ-NCRIMDW Ford,Arthur D. WO1 USA SJASubject: RE: 4 of 4Attachments: 120131-Defense Discovery Response David,At this time, we will not provide the contact information for Mr. Roland, Ambassador Kennedy,or Mr. Betz; however, if they are designated as government witnesses we will not only providethe information, but coordinate meetings for the defense to interview these senior levelofficials, and any other senior officials designated as government witnesses. These meetingswill be well before trial so that each party has adequate opportunity to prepare its case andequal opportunity to interview witnesses.As of today, none of these three individuals will be witnesses at a court-martial, if thecase is referred. Although the United States intends to call senior military/governmentofficials as witnesses, we have not identified these individuals as our witnesses. TheUnited States understands its obligations under Article 46, UCMJ, applicable rules, andapplicable case law, and is confident the defense will have equal opportunity to obtainwitnesses, as defined by these sources and overseen by a military judge.Also, as a reminder, please remain cognizant of the classified and otherwise sensitive natureof these individuals? work and their relationship to this case.Attached is our reply to your previous discovery requests, in reference to damage assessmentsand other documents related to DOD and Executive Branch departments and agencies.v/rAshdeni 02564748 i From: Sent: Tuesday, January 2012 5:42 PMTo: Fein, Ashden CPT USA SJ A Cc: Matthew kemkes Bouchard. Paul USARMY (U9) Tooman, Joshua CPT USARMYMorrow JoDean, CPT USA Overszaard, Angel M. CPT USAWhyte. Jeffrey H. CPT11>; Ford, Arthur W01Melissa SantiagoSJASJAUSA SJAUSA SJA Subject: RE: 4 of4Ashden,I would like to explore the possibility of calling these individuals as defense witnesses. Please be so kind as toprovide contact information for them. Thank you.Best.DavidDavid E. Coombs, Esq.Law Office of David E. Coombsll South Angell Street, #317Providence, RI 02906Toll Free: I -800-588-4156Local: (508) 689-4616Fax" (508) 689-9282""??"Confidentiality Notice: This transmission, including attachments, may contain confidential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthori zed disclosure, copying or use ofthis information may beunlawful and is 02934976 . From: Fein, Ashden CPT USA SJASent: Wednesda Februa 01 2012 2:14 PMTo:Cc: Morrow JoDean CPT USA Ford, Arthur D. W01 USA JFHQ-Subject: FBI Filewe are 98% complete reviewing the main File.on the phone?Are you available to discuss with a tech person Thanks!Ashden02948363 From: Fein, Ashden CPT USA SJASent: Wednesday, February 01, 2012 6:12 PMTo: Cc: Matthew kemkes; Bouchard, Paul CPT USARMY Tooman. Joshua CPTUSARMY Morrow Ill, JoDean, CPT USA Overgaard, Angel M.CPT USA Whyte, Jeffrey H. CPT USA Ford,Arthur D. WO1 USA Melissa SantiagoSubject: RE: 4 of 4Attachments: 120201-Defense Computer Forensics Expert Consu|tants.pdf; 120201-GCMCA Response toRequest for Oral Depositions.pdfDavid,Absolutely. we will start working with each organization to determine the best way for thedefense to contact the individuals.Attached are the GCMCA's decisions on the Defense Computer Forensic Experts and theDeposition Requests.Have a good night.v/rAshden02564743From: Bouchard, Paul CPT USARMY (US) Sent: Thursday, February 2, 2012 8:31 AMTo: Overgaard, Angel M. CPT USA SJAMatthew kemke Cc: Fein, Ashden CPT USA SJA Parra, Jairo A. W01 USA SJASantiago, Melissa CW2 USARMY (US) Subject: Computer Forensics Team (UNCLASSIFIED)9Classification: UNCIASSIFIEDCaveats: FOUOAngel, Giief Parra, Ashden:Thank you for your quick turnaround regarding the approval of additional funds for the Defense's Computer ForensicTeam, US v. Manning.CPT BouchardClassification: UNCLASSIFIEDCaveats: FOUO02564742From: Bouchard, Paul cm USARMY Sent: Thursday, February 2, 2012 8:51 AMTo: Parra, Jairo A. W01 USA SJFeito, Beatriz SGT USA JFIIQ- SJFein, Ashden CPT USA SJAOvergaard, Angel M. CPT USA SJACc: coom annycou ma ia eensecom; a ew emkesSantiago, Melissa CW2 USARMY (US) Subject: Billing, Computer Forensics Team (UNCLASSIFIED)Attach: Cyber Agents Invoice US Manning Cyber Agents Invoice US Manning ereview-32 Classification: UNCLASSIFIEDCaveats: FOUOMister Parra,The attachments are the pertinent billing invoices from the Defense Computer Forensic Team.I want to thank you, CPT Overgaard, and CPT Fein personally for your excellent work on the additional 28k approval.As per our discussion yesterday, it is our understanding that the Government is working on the travel arrangements forEric Lakes and Trent Struttmann for 8-17 Feb here at Fort Meade. Keep in mind that Mr. Lakes has requested a smokingroom for his hotel accommodations.CPT BouchardClassification: UNCLASSIFIEDCaveats: FOUO02915782 From: Fein, Ashden CPT USA SJASent: Thursda Februa 02 2012 11:19 AMCc: USA Morrow JoDean, CPT USA JFHQ-SJASubject: RE: US v. PFC BM PSR) (UNCLASSIFIED)Sir,Good morning. Have you heard back From OGC yet? Thank you.v/r~Ashden02924580From: Fein, Ashden CPT USA SJASent: 2012 11:20 AMCc: orrow 0 ean. PT USA SJAsubject: RE: one more questionGood morning. Have you been able to determine whether the Services (less Army) and 05D havebeen able to work on our we expect the case to be referred in the next week and oncethat occurs, our formal discovery obligations will vest. Thank you.v/rAshden02934984 From: Fein, Ashden CPT USA SJASent To:Cc: Morrow JoDean CPT USA Ford, Arthur D. W01 USA JFHQ-NCRIMDW Subject: RE: FBI FileAre you available for a phone cohversation later today about the FBI file and the wayForward?Thanks!Ashden02947984From: Fein, Ashden CPT USA SJASent: Tuesday, February 07, 2012 7:46 AMTo: Matthew kemkes; Bouchard, Paul CPTCc: Morrow Ill, JoDean, CPT USA SJASumem: admmGents-Please read the below link. Although the anonymous movement seems to support your client atthis time, a member might decide to Focus their attention on you or your team members.I highly recommend that you pull any personal and work emails off any civilian server andkeep the copies locally having all your personal emails sitting on GMAIL or YAHOO).Please let me know if there is any indication that a breach or a simple oddity occurs.v/rAshden02557513From: Parra, Jairo A. W01 USA SJASent: Tuesday, February 07, 2012 1:30 PMTo: 'Bouchard. Paul CPT USARMY ?Santiago, Melissa CW2 MIL USA MDWCc: Fein, Ashden CPT USA Ford, Arthur D. W01 USA Overgaard, Angel M. CPT USA JFHQ-NCRIMDW SJASubject: Expert Witness Contract (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOAll,The contract for the expert computer services of Mr. Lakes and Mr Struttman (Cyber Agents,Inc) is approved. I will be sending a copy of the approved contract shortly. For yourinformation, the convening authority, MG Michael S. Linnington, approved the defense'srequest on 1 February 2012. Contracting Command subsequently issued a contract on 6 February2012. The contract allows for the expenditure of $28,000.00, in individual billable hours,at $175.00 per hour. Any excess of funds beyond the approved amount of $28,000.00 must berequested, in writing by the defense team, and approved, by the convening authority, prior topayment or any work being performed by the experts. Additionally, reasonable travelreimbursement and per diem, the JFTR, is authorized.Note: Their travel is approved for tomorrow. More information on travel arrangements willbe provided shortly. Thank youv/r,JPJairo A. Parrawo1, JALegal AdministratorJFH -NCR MDN The information contained in.this email and any accompanying attachments maycontain Freedom of Information Act protected information, including attorney-client orattorney work product privileged information. This information may not be released outsideof the Department of Defense without prior authorization from the Office of The JudgeAdvocate General, Department of the Army. If you are not the intended recipient of thisinformation, any disclosure, copying, distribution, or the taking of any action in relianceon this information is prohibited. If you received this email in error, please notify thisoffice immediately by return email (see 5 U.S.C. 552 and Army Regulations 25-55 and 27-02935104From: Fein, Ashden CPT USA SJASent: Tuesda Februa 07 2012 6:14 PMTo:Cc: Morrow Ill, JoDean, CPT USA Ford, Arthur D. W01 USA JFHQ-SJASubject: FBI Case FileI was finally able to send you on SIPRNET the breakdown of the FBI file that we reviewed.The blue numbers are documents that we still need to go through, but will in the next day.Thanks!Ashden02947979From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Wednesday, February 08, 2012 2:29 PMTo: Cc: 'Kemkes, Matthew Bouchard, Paul CPT USARMY Tooman, Joshua CPT USARMY Morrow Ill, JoDean, CPT USA JFHQ-NCRIMDW Overgaard,Angel M. CPT USA JFHQ-NCRIMDW Whyte, Jeffrey H. CPT USA JFHQ-NCRIMDWFord, Arthur D. WO1 USA JFHQ-NCRIMDW Santiago, Melissa 8 CW2 USARMY(US)Subject: Admin for TodayDavid,During today's call, I would like to discuss these admin subjects with the M3. Do you haveany issues ahead of time- if not I would like to make this easy for her and add in thatdefense agrees/doesn't agree?1. The uniform for all proceedings be class A (ASU or Green).2. DA 62 supports Mr. Jay Prather (Security, DA 62) to be the court security officer (CSO).He was the CS0 for the Article 32 IO and has adequate knowledge about the types and substanceof the classified information in this case to efficiently support the M3.3. The United States plans on allocating the same amount of seats in the gallery as with theArticle 32. Each team will have 1 reserved row, 1 row for USG officials, 1-2 rows for press,and the remainder for spectators.4. The United States asks that CCTV be authorized for all open sessions of the court-martial.The CCTV will be on a 30 second delay to the overflow theater (for spectators) and the mediaoperations center. Additionally, unlike other trials, there will be a live feed to thedefense and prosecution trailers, where only team members w/ clearances are authorized.5. In order to ensure adequate security of the accused, court members, and spectators, theUnited States intends to issue security badges with different categories/colors of badgesthat authorize access to certain portions of the courthouse and outside structures. Anybadge, regardless of color, with stripes, will be pre-cleared for access to "secret"information. Access to "top secret" or "sci" material, if required, will be handledseparately.a. Black?MJ, CSO, MJ Paralegal, Panel, Security, Admin Leadershipb. Green-Counsel, Team Members, Leadership of FGGM staff sections (to provide logisticssupport)c. Blue-witnessesd. Red?Official Visitor (pre?planned individuals, including BM's and our family members, willbe authorized to be unescorted in the courtroom)e. PAOf. Media6. The United States recommends modifying the prohibitions listed in the court rules (RuleON.3), not to allow cell phones, etc. in the courtroom, regardless if it is turned off.02947979Because there will likely be closed sessions, this is a security risk and the command wouldlike to mitigate with this rule and cell phone monitoring equipment through ArmyCybercommand.7. The United States requests the authority to have no more than two armed MP5 in the back ofthe courtroom, in addition to standard command representative bailiffs. The purpose is toprotect the accused and the court members.8. Based on the current security assessment, the United States recommends the M3 travel inTDY status and not use her own POV. Additionally, the United States is prepared to fund theTDY, and has ensured the USG-employed defense and prosecution have equal access to this typeof funding.02564707 From: Sent: Wednesday, February 8, 20l2 4:49 PMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Paul BouchardMorrow Ill. JODean. CPT USA SJASJA ;Whyte. Jeffrey H. CPT SJA Ford, Arthur I) WOI (ISASJA Melissa Santiago17>Subject: Re: Admin for TodayI have an issue with number 7 on your list.Best.Sent from my Vcn'/on 02560453mm: Sent: Wednesday, February 8, 2012 5:16 PMTo: Fein, Ashden CPT USA SJA Subject: Re: FBI Case FileHc_v._ and I wan! to come out Fri around I015-I030 to sum looking at the docs you lagged. Is that time good for ou02935102 IFrom: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Wednesda Februa 08, 2012 10:15 PMTo:cc: Ford, Arthur D. W01 USA SJASubject: RE: FBI Case File- Friday is Fine. CID is going to be at the o-H-?ice as well For a meeting at 1060, butit should not matter. It would be good if ya'll came no earlier than 1636, but if you can'tcontrol it, we will deconflict.Ashden02560452From:Sent: Wednesday, February 8, 2012 I0: I8 PMTo: Fein, Ashden CPT USA SJSubject: Re: FBI Case FileNo problem. I030 it is.02927905From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Monday, February 13, 2012 10:06 AMTo: Ford, Arthur D. WO1 USA JFHQ-NCRIMDW Bradley, Princeton L. SGT USA JFHQ-NCRIMDW SJASubject: lets chat.Follow Up Flag: Follow upFlag Status: CompletedSir or Ma'am,Good morning. I am calling from an open unclassified line. My name is Sergeant PrincetonBradley and I am a paralegal for the prosecution team in the U.S. Army court-martial ofPrivate Bradley Manning of NikiLeaks. I have been asked by the prosecutors to call you inreference to a document or series of documents that your organization provided the NCIX.Over the past year we have worked with NCIX regarding this topic and they have now asked thatwe directly coordinate with the contributing organizations.with that being said, could I please get point of contact information from you so that myattorneys may contact a representative from your organization to discuss this matter. Emailis preferred and we have access to SIPRNET and JNICS.02979528 From: Tc-2in.doe.gov1Sent: Wednesday, February 15, 2012 8:26 AMTo: Bradle Princeton L. SGT USA SJACc: HQ)Subject: CONFIRM CONTACT INFORMATIONAttachments: Picture (Device Independent Bitmap) 1.jpgBradley,This is to confirm receipt of my contact information. I have cc?d DOE OGC as wellas Office of Intelligence and Counterintelligence. Office of the National Counterintelligence Executive NCIX:Cell: Unclassified: in.doe. ovSiprnet:02560450Fro-n= Sent: Wednesday, February I5, 2012 8:50 AMTo: Fein, Ashden CPT USA SJAMorrow JoDcan, CPT USA SJAOvergaard, Angel M. CPT USA JFHQ- SJ ASubject: Thursday good for another review session?_and I would like to continue our review starting Thursday at 0800. Is WO Ford and one of you all going to bearound to help us out? We will likely stay most of the day.Thanks,FBI Washington Field Office02942727From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Wednesday, February 15, 2012 10:25 AMTo: Cc: 'Kemkes, Matthew MIL Bouchard, Paul CPT USARMY Tooman, Joshua CPT USARMY Santiago, Melissa CW2 USARMY Ganiel, Charles USA CIVHall Cassius Mr FMMC Morrow JoDean, CPT USA Overgaard, Angel M. CPT USA Whyte, Jeffrey H. CPT USAJFHQ-NCRIMDW Ford, Arthur D. W01 USA SJASubject: Classified Informationhnponance: i?ghDavid,Pursuant to our phone call last night, I have consulted our experts about this repeated issueof questioning the classification authority's determination of a certain agency's involvementin this case. Please understand that defense security experts are appointed to consult withyou and the other defense attorneys on security matters and not to make any determination onwhether something is legally classified or not. Under federal law, these determinations arereserved solely for named 0CAs and their duly appointed delegates. The decision whetherinformation is or is not classified is not left to individuals who enjoy security clearances.The defense was provided two classification reviews (BATES 378148?378175 and BATES 416623-416634) on 8 November 2611 and 7 December 2011, respectively. Each of these contained afootnote which clearly states that the information at issue is classified and bothdocuments were signed by a competent authority (OCA). Furthermore, I explained this exactissue to you before the Article 32 over the phone and highlighted in?person to Mr. Hall andMr. Ganiel that they needed to review the footnotes on these two classification reviews tounderstand what is or is not classified according to the OCA.Classified discovery has proceeded in this case based on the defense team's acknowledgment of.their nondisclosure agreements and the classified information protective orders, andcontinued purposeful or grossly negligent disclosures will hinder future classifieddiscovery. Based on your representations last night and until the military judge issues anupdated protective order, we will not provide the defense any additional classifiedinformation.Recognizing that accidents can occur, please ensure that you follow both signed agreementsfrom this point forward and do not intentionally disclose classified material, as this couldbe a violation of 18 USC 793 and can result in a review of the defense team's securityclearances.Thank you.v/rAshden02980116From: Bradley, Princeton L. SGT USA SJASent: Febmary 15. 2012 10:55 AMTo: tva.gov'Subject: eque or OGC Point of Contact (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOSir,Per our earlier discussion, I would like to request an OGC point of contact with regard tothe documents your organization sent to the NCIX regarding the wiki?leaks incident. Thosedocuments, should they be deemed relevant and necessary, would be used in the U.S. Army CourtMartial of PFC Bradley Manning in connection to wiki-leaks. The prosecuting attorneys would?irst, however, need to coordinate with your OGC department to ensure proper use of thosedocuments. If at all possible, please send both SIPRNET and JNICS email addresses, as wellas phone numbers, for the points of contact that you are able to obtain. Also, I wouldstress that because the arraignment of the accused will take place next week, the prosecutionteam is in need these documents immediately. Thank you very much for your assistance in thismatter.Very Respecfully,SGT Princeton BradleyParalegal Non-Commissioned OfficerMilitary Justice, OSJAFort McNair, 32 Classification: UNCLASSIFIEDCaveats: FOUO02979694From: _@va-gov]Sent: Thursday, February 16. 2012 10:22 AMTo: Bradley, Princeton L. SGT USA SJASubject: equest or OGC Point of Contact (UNCLASSIFIED)Princeton: Your initial email indicated "because the arraignment of theaccused will take place next week, theprosecution team is in need these documents immediately." Since I'll be outof the office tomorro, if you'd like us to initiate any action this weekplease let me know today so that I can get the process going. Thanks. Office of General Counsel U.S. Department of Veterans AffairsThis message may contain information that is confidential and/or protected bylaw. If it has been sent to you in error, please reply immediately to advisethe sender of the error and then destroy this message, any copies of thismessage and any printout of this message. If you are not the intendedrecipient of the message, any unauthorized dissemination, distribution orcopying of the material in this message, and any attachments to the message,is strictly forbidden.02979688From: *@dot.govSent: ur a ebmary 16. 2012 10:27 AMTo: dot.govCc: rad ey. rinceton L. SGT USA dot.govSubject: FW: Request for OGC Point of Contact (UNCLASSIFIEAttachments: NCIX Justification.pdfAs per our discussion please see the attached document and the POC for this request below.I am including SGT Bradley on the cc line so he has your correct email.SGT Bradley ??telephone number is She is a Senior Attorneywithin the office of the General Counsel, Office of the Secretary of Transportation. Shewill coordinate the effort to get a response to the request put forth in the attachment.Please call if you need any further assistance. Office of Intelligence, Security, and Emergency Response (S-66)U.S. Department of TransportationOffice:Cell: 02564689From: Sent: Thursday. February I6, 2012 I241 PMTo: Fein, Ashden CPT USA SJA Cc: Morrow Ill, JoDean. CPT USA SJASubject: RE: Defense MotionsAshden,It is an ex parre supplement to our motion to compel discovery.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombsll South Angell Street, #317Providence, RI 02906Toll Free: 1-800-588-4156Local: (508) 689-4616Fem: (508) 689-9282Notice: This transmission, including attachments, may contain confidential attorney?clientinformation and is intended for the person(s) or company named. lf you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is 02980114 From: ?@tva-gov! 1Sent: Friday, February 17, 2012 8:24 AM ITo: Bradley, Princeton L. SGT USA SJASubject: RE: Request for OGC Point of Contact (UNCLASSIFIED)SGT Bradley,I am your POC here at OGC. My contact information is in the below signature block.Please note that these are all unsecure. we have limited facilities here at TVA For securedmessages, so if someone can call or email me with as much unclassified info as possible, wecan -Figure out our next step from there.Thanks. TVA Office of General Counsel466 N. Summit Hill Drive, HT 6Knoxville, TN 37962 VB . 0V)02560448From:Sent:To:Cc:Subject: ic.fbi .gov> Friday, February 17,2012 8:41 AMJic.fbi.gov>; Fein, Ashden CPT - SJA Initial discovery review completeWe finished our initial discovery review and are ready for EDVA and FBI OGC to review our review. The second reviewcan be done in a day. We would like to have this second review session on next week, but given the CH5 operations thatmay be going on, we may have to push it to the following week. I will update you all next week as our schedulebecomes clearer.Thanks,FBI Washington Field Office02930308 From: Fein. Ashden CPT USA SJASent: Frida February 17, 2012 11:05 AMTo: ic.fbi.gov'Cc: Morrow JoDean, CPT USASJASubject: Re: Initial discovery review completeThank you?For' spending all day at our office!we should be available any day but Thursday bc that is our arraignment.Ashden02925786From: Fein, Ashden CPT USA SJA Sent: Wednesda Februa 22, 2012 9:02 AMCc: (US)Subject: Mr. Boardman POC1.Good morning. Do you have contact information for? Army G2, who has beengraciously loaned to us for security matters?Thank you.Ashden02562329 From: USA DCS G-2 us.army.mi|} on behalf ofUSA ocs G-2 -Sent: Wednesday, Febmary 22, 2012 1:31 PMTo: SJACc: USA OTJAGSubject: RE: POC (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONE Hi Ashden?-works out at the Hoffman building. His phone isIf that address proves to be difficult to use (because of the changeover),try usinBest regards02978020From: ?@usdoi-oovlSent: Wednesday, February 22, 2012 4:49 PMTo: Bradle Princeton L. SGT USA JFHQ-NCRIMDW SJACc:Subject: Re: NCIX Documents (UNCLASSIFIED)Sergeant Bradley? I am an Associate Chief Counsel in ATF and my Deputy,?, and Iwill coordinate with Division ChieF_and others as necessary to honor your request. Iam home sick today and therefore unable to give you an approximate response time right nowbut we understand there is some urgency to your request. Someone from ATF will be back intouch soon.02979514 From: @hq.doe.gov]Sent: Wednesday, February 22, 2012 5:14 PMTo: Bradle Princeton L. SGT USA SJACc:Subject: RE: Request to Review NCIX Documents (UNCLASSIFIED)SGT?Bradley,In response to your email, yes, I am an attorney at DOE, in the Office of the GeneralCounsel, and I work in the Office of the Assistant General Counsel for International National Security.I'm adding attorney ?to this email because he works in our litigation shop, has aand has relevant work experience.Please feel free to contact ?or_ so that we can try to help yourprosecution team gain access to whatever in ormation you are seeking.NOTE: I will be out of the office on official travel all of next week with limited emailaccess.Office of the General CounselU.S. Department of Energy1660 Independence Avenue, s.w.Nashin ton D.C. 28585Tel.:*This e-mail communication (including any attachments) may contain legally privileged and/orconfidential information meant solely for the intended recipient. If you are not theintended recipient, you should stop reading this message and delete it from your systemimmediately. Any unauthorized reading, distribution, copying or other use of thiscommunication or its attachments is strictly prohibited.02979600From: ?@dot.govSent: Thursday, February 23, 2012 10:43 AMTo: Bradley, Princeton L. SGT USA SJASubject: RE: Request to Review NCIX Documents (UNCLASSIFIED)Bradley,I spoke with Sgt. waybright a few minutes ago and proposed that we hold a call tomorrow todiscuss the analysis document that you are seeking In order to ensure that all parties onour end are available, could we hold the call on Monday? I know you have?defined schedule,so please let me know if that is not an option and we will see what we can do on our end.Thank you.Office of the General CounselU.S. Department of Transportation1260 New Jersey Avenue, S.E.Room w96-329Washington, DC 26599Emai1= Secure E'"ai1= 02564669From: Sent: Friday, February 24, 2012 5:37 PMTo: Fein, Ashden CPT USA SJ A Morrow oDean, CPT USA IF SJAOvergaard, Angel M. CPT USA IF HQ-Whyte, Jeffrey H. CPT USA SJASJACc: Matthew kemkes Paul Bouchard Joshua Tooma Subject: Protective OrderAshden,I wanted to reach out to you to see if we could come to an agreement on the protective order. It seems to me that the reason for ourdisconnect is that we can't seem to agree on the basic issue. I understand your position to be that everyone has an obligation to protectclassi?ed information, and that it is not the role of the defense (or anyone) to second guess the classi?cation detenninations. I agreewith you on this. However, my view is that we need to ?gure out who decides whether something is in violation of the classi?cationdecision In some cases, it is clearly not self-evident whether something violates the determination or not.I do not believe that the government should unilaterally decide whether something that the defense or the judge submits is in violationof a classi?cation decision. Instead. I believe that a neutral third party (such as the Court Security Of?cer) should be given thisinterpretive nole. To be clear, the CS0 is not reviewing or second-guessing the classi?cation delerrnination, but simply providing hisexpert opinion whether, given the classi?cation detennination, a submission by either the defense or the runs afoul of theOCA prohibitions. This is exactly what Mr. Prather did with regards to the ex parte submission by the defense.It would be helpful if you could let me know by Monday whether we can at least agree on what the issue is here - i.e. who shoulddecide whether a given submission reveals classi?ed information in light of existing OCA classi?cation determinations. If we can'teven agree on the starting point for this discussion, it may not make sense to pursue this issue jointly.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angeli Street, #317Providence, RI 02906Toll Free: l-800-588-4l56Local: (508)689-4616Fax: (508)689-9282se.com?**Confrdentiality Notice: This transmission, including attachments, may contain confidential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is prohibited."*02923057From: Fein, Ashden CPT USA SJASent: Friday, February 24, 2012 5:49 PMTo: Morrow JoDean, CPT USA Overgaard, Angel M. CPT USA Whyte, Jeffrey H. CPT USAJFHQ-NCRIMDW SJACc: Matthew kemkes; Paul Bouchard; Joshua ToomanSubject: RE: Protective OrderDavid,I absolutely think we can reach an agreement! we met with the Department of JusticeLitigation Security Group today to understand how the federal courts administratively processfilings and other related matters in cases dealing with classified information.I am confident that by the middle to end of next week, we will have a draft of an order thatyou will likely be 98% amenable with. Our starting point will be your proposed order and weare going to work from there to find a process that will work with our partner organizations,the command, and everyone's resources.However, just to clarify a statement you wrote below-You wrote: do not believe that the government should unilaterally decide whether somethingthat the defense or the judge submits is in violation of a classification decision." what isconfusing is your use of the word "government." If you mean the prosecution, then we agree.If you mean the United States Government, then we disagree because an OCA, or their delegate,is the ultimate authority on what is classified when it comes to their classifiedinformation.Have a good weekend.v/rAshden02979616From:Sent:To:Cc:Subject:gydotgovFriday, February 24, 2012 6:28 PMBradley, Princeton L. SGT USA SJAFord, Arthur D. W01 USA SJARe: Request to Review NCIX Documents (UNCLASSIFIED)Thanks For coming to see us. we are located at 1268 New Jersey Ave.If you are coming by metro, we are directly across the street (diagonally) ?rom the Navy Yardmetro station.There is some, but not a lot oF street parking. If you are parking at the Navy Yard, we areon street, just west o-F the Navy Yard.The main entrance is on New Jersey Avenue and I will meet you there.My cell is Call me ii? you are running late or come in through another entrance.The documents you will be looking at are classified Secret.Thanks again and sorry For the short replies. Out of town and on B8 this weekend.i 02564664iFrom: Sent: Friday, February 24, 20|2 6:30 PMTo: Fein, Ashden CPT USA SJA Morrow JoDean, CPT USA SJA Overgaard, Angel M. CPT USA Whyte, Jeffrey H. CPT USA SJAJFHQ-NCIUMDW SJACc: Matthew kemkes Paul Bouchard Joshua Tooman Subject: RE: Protective OrderAshden,To clarify what I wrote: I did indeed mean "the prosecution" when I said "govemment". However, 1 do notbelieve that the prosecution should be the one working in conjunction with the OCA to makejudgment calls onwhether something is classi?ed. If your proposed order continues to maintain the position that the prosecutionin conjunction with the OCAs (or their delegates) should be the one to determine spillage, then I think wemay be at an impasse. Please advise on whether that is your position.Best.DavidDavid E. Coombs, Esq.Law Office of David E. Coombsll South Angeli Street, #317Providence, RI 02906Toll Free: I -800-588-4156Local: (508)689-4616Fax (508)689-9282"?"?C?onfrdentiality Notice: This transmission, including attachments, may contain confidential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use ofthis infomtation may beunlawful and is prohibited.""02923053From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Sunday, February 26, 2012 7:18 PMTo: Morrow JoDean, CPT USA Overgaard, Angel M. CPT USA Whyte, Jeffrey H. CPT USAJFHQ-NCRIMDW SJACc: Matthew kemkes; Paul Bouchard; Joshua ToomanSubject: RE: Protective OrderDavid,I know you asked for an answer by tomorrow, but that will be impossible because we will needa few days to speak with the OCA or their representatives. we ask that you give us until themiddle to the end of next week to come up with a proposal, so that we may work together tofind a reasonable way forward.As I stated in my previous email- I absolutely think we can reach an agreement that you willlikely be 98% amenable with. Our starting point will be your proposed order and we are goingto work from there to find a process that will work with our partner organizations, thecommand, and everyone's resources. v/rAshden02564658From: Sent: Sunday, February 26, 2012 7:26 PMTo: Fein, Ashden CPT USA SJA Morrow JoDean, CPT USA SJAOver aard. Angel M. CPT USA JFHQ-Whyte, Jeffrey H. CPT USA SJASJACc: Matthew kemkes Paul Bouchard Joshua Tooman Subject: RE: Protective OrderAshden,I am really just looking for a "yes" or "no" answer to the following question: ls it your position that the CS0(and not trial counsel) will work with the OCA to determine ifa ?ling contains classi?ed infonnation" I needan answer to this so that 1 can prepare accordingly. Thanks.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombsll South Angell Street, #317Providence, RI 02906Toll Free? I-800-588-4156Local: (508) 689-4616Fax: (508)689-9282??*C?onfidentiality Notice: This transmission, including attachments, may contain con?dential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure. copying or use of this information may beunlawful and is prohibited.""*02923047From:Sent:To:Cc:Subject:David,Thank you.Fein, Ashden CPT USA SJASunday, February 26, 2012 7:28 PMMorrow JoDean, CPT USA Overgaard, Angel M. CPT USA Whyte, Jeffrey H. CPT USASJA .Matthew kemkes; Paul Bouchard; Joshua ToomanRE: Protective OrderI intend to get you the answer by the middle to end of the week, once I speakwith the OCAs or their representatives about the issue.V/rAshden02564652 From: Sent: Sunday. Febmary 26, 20l2 7:42 PMTo: Fein, Ashden CPT USA SJA Morrow JoDean, CPT USA SJAOvergaard. Angel M. CPT USA JFHQ-SJA Whyte. Jeffrey H. CPT USASJA n>Cc: Matthew kemkes Paul BouchardJoshua Tooman 3*Subject: RE: Protective OrderAshden,I'm not sure why you can't answer that question now -- either you envision a role for the CS0 or you do not. Ifyou can't even give me the government's basic position on this critical issue who reviews and determineswhether a document contains classi?ed information), it doesn't really seem that you are amenable to workingtogether on this.DavidDavid E. Coombs, lisq.Law Office of David E. Coombsll South Angeli Street. #3l7Providence, RI 02906Toll Free: 1-800-588-4156Local: (508)689-4616Fax: (508)689-9282Notice: This transmission, including attachments, may contain confidential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient. pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is prohibited.""? 02923039 x? From: Fein, Ashden CPT USA SJASent: Sunday, February 26, 2012 8:54 PMTo: Morrow JoDean, CPT USA JFHQ-NCRIMDWOvergaard, Angel M. CPT USA JFHQ-NCRIMDW Whyte, Jeffrey H. CPT USASJACc: Matthew kemkes; Paul Bouchard; Joshua ToomanSubject: RE: Protective OrderDavid,I disagree? I know the prosecution and defense can work out a solution, but the prosecutionmust consider all equities involved. As you know, the prosecution represents the UnitedStates government and its collective interests. Just because we, as prosecutors, might think,a proposed course of action is the best way forward, that does not necessarily equate to themost efficient and approved way forward, especially if a course of action requirescooperation and concurrence with organizations outside the direct command and control of theconvening authority.It is very conceivable to envision a role for the CS0 to essentially be a classifiedinformation clerk for the Court; however before the prosecution, on behalf of the UnitedStates government, commits to any course of action, we MUST figure out the process, who wouldbe involved, and consider all courses of action (as directed by the military judge).As per the military judge's instructions, the prosecution is exploring all the differentmethods to allow for efficient and safe submissions of documents to the court and how to besthave that information managed. we should have a proposed way forward by the middle to end ofthis week, which we intend to share with you for comment, in an effort to work together for afinal product.v/rAshden02564644From: Sent: Sunday, February 26, 2012 9:50 PMTo: Fein, Ashden CPT USA SJA Morrow .|oDean, PT USA SJAOvergaard, Angel M. CPT USA ;Whyte, Jeffrey H. USA1> DW SJASJA Cc: Matthew kemkes Paul BouchardJoshua ToomanSubject: Protective OrderAshden,think that the Government is unnecessarily making the process more difficult than it needs to be. This issomething that CO1. [.ind cautioned against doing. Because you continue to refuse to provide any answer tobasic questions, I will proceed with a separate course of action.Best,DavidDavid E. Coombs. Esq.Law Office of David E. Coombs1 South Angell Street, #317Providence, RI 02906Toll Free: I-800-588-4 I56Local: (508) 689-46l6Fax: (508) 689-9282*"?"C0nfidentiality Notice: This transmission, including attachments, may contain con?dential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is 02923030From: Fein, Ashden CPT USA SJASent: Sunday, February 26, 2012 10:32 PMTo: Morrow Ill, JoDean, CPT USA JFHQ-NCRIMDWOvergaard, Angel M. CPT USA JFHQ-NCRIMDW Whyte, Jeffrey H. CPT USASJAcc: Matthew kemkes; Paul Bouchard; Joshua ToomanSubject: RE: Protective OrderDavid,It is unfortunate that within one duty day of our hearing, you have made the decision not towork together on this issue. Although your question seems simple to you and the defense, theprosecution is not in the position to commit to a course of action without first consultingwith the entities that would be required to actually conduct the work that you propose orthat COL Lind suggested, such as an OCA representative consulting with the CS0 or a C50equivalent, communicating over a secure network, etc.All the prosecution has asked for, from the defense, is a few days to consult with the equityholders to determine the most efficient means to protect the information and whether thedifferent proposals are feasible. As always, you are free to proceed with a separate courseof action; however the prosecution will diligently work this week to develop a proposed planand we will submit this plan to you, prior to submitting to the military judge (as shedirected), for comment to determine if there is a common plan or at least some processesthat both the defense and prosecution agrees with.v/rAshden02564634From: Sent: Monday, February 27, 2012 I2: I 5 AMTo: Fein, Ashden CPT SJA Morrow Ill, .loDean, CPT USA SJAOver aard, An el M. CPT USA JFHQ-Jeffrey H. CPT USA SJASJA Cc: Matthew kemkes Paul BouchardJoshua ToomanSubject: RE: Protective OrderAshden,'l'wo points of clari?cation:I. As you well know. I have not asked you to ?commit to a course of action" have asked in as manyways as I possibly can whether we even agree on the basic issue.2. Completing a protective order and then giving it to me for comment does not constitute ?workingtogether" on the protective order.DavidDavid E. Coombs, Esq.l.aw Office of David E. CoombsI I South Angell Street, #317Providence, RI 02906Toll Free: I-800-588-4 I56Local: (508) 689-46-I6Fax: (508) 689-9282Notice: This transmission, including attachments, may contain confidential attomey-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use ofthis information may beunlawful and is 02979758From: - ?@9sa.9ov1Sent: Monday, February 27, 2012 11:30 AMTo: Bradley, Princeton L. SGT USA SJASubject: Re: Request to Review NCIX Response (UNCLASSIFIED)Good morning, SGT Bradley.Yes, I am the attorney in Office of General Counsel who has been assigned to assistwith this matter,The records you request are currently held in GSA's SCIF by our Office of EmergencyResponse and Recovery (OERR),OERR has SIPRNET capability in our SCIF (upstairs from where I am sitting), but I don'tcurrently have a SIPRNET account myself - is it feasible For me to coordinate getting you theinformation you need via one of my colleagues in Office of General Counsel02979763From: ?@gsa.gov1Sent: Monday. February 27, 2012 3:20 PMTo: Bradley, Princeton L. SGT USA SJASubjecl: Re: Request to Review NCIX Response (UNCLASSIFIED)SGT Bradley,Roger all.FYI, I'll be out on Navy Reserve duty (hilariously, at Navy 0JAG's Classified LitigationDivision over at the Navy Yard) this wed., Thurs., and Friday (29 Feb 2 March) but I'll tryto monitor this email account whenever I'm not in our SCIF.Cheers, and wr,02979730 From: epamai|.epa.gov]Sent: 27, 2012 4 49 PMTo:Cc: epa.gov; Subject ega mg Coun Case PFC Manning, USAYou will be contacted by SGT Princeton Bradley, USA regarding the Courts Martial of PFCBradley Manning, USA. His contact information is below and email in cc block:SGT Princeton Bradley, USAOffice of the Staff Judge Advocate2' 2:-I U.S. Environmental Protection AgencyOffice of the Administrator/office of Homeland Security This email may contain For Official Use Only and information protected under the Privacy Actof 1974 as Amended.02564620From: David oombs Sent: Monday, February 27, 2012 8:53 PMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes ?Paul Bouchard' ?Joshua Tooman' Morrow IH, JoDean, CPT USAOvergaard, Angel M. ?Melissa Santiago?SJACPT USA SJ AJeffrey H. CPT USA SJAArthur D. W01 USA SJASubject: RE: ASUSAshden,It seems that you are proposing ?ve months of motions (Feb. 23-July 23). While I understand that the case is?complex? and involves ?a mass of classi?ed infonnation," preliminary motions should not take almost half ayear. I think you need to consolidate some of the motions to move the process along more expeditiously. Also,it appears that some of the timelines just don?t work; they allow the defense 1-2 days to prepare its submissions,while often allowing the government 2-3 weeks to prepare its submissions. The equities don?t seem to bebalanced.I also have the following speci?c concerns:- It doesn?t make sense to have the instructions and motions to dismiss due one duty day after the hearingwhere the Government will apparently provide the bill of particulars and respond to the requested discovery. If,for instance, you oppose discovery and the judge ultimately orders you to produce it, we won?t get that untilseveral weeks in. So, how could we finalize these dispositive motions without full discovery? Same with thebill of particulars if you provide us with every particular we are seeking (a proposition that you know I amdubious about), that leaves a turnaround of one day to ?nalize instructions/lesser included instructions. Thattimeline just doesn?t work.- You have continuing ?motions to compel discovery? if our motion is granted, that?s the end of it. I?m notsure why there are so many motions to compel additional discovery.- For the Speedy Tn'al motion, you indicate in a footnote that I said that the motion would be andreference novel legal issues. While I do anticipate that the motion may be I did not say that it wouldraise ?novel legal issues.? As you know, the speedy trial motion doesn?t involve particularly complicated law;it will be decided on the facts.- You are missing some things from your motions list that I think should be included your ?due diligence?statement re: Brady materials; and the potential request for amended Article disclosures motion (both ofwhich should be argued at the upcoming Article - Much of what you list under Phase 4 and 5 can be shortened signi?cantly (you have over two months forcvidentiary motions). The defense doesn?t anticipate submitting very much during your proposed phases. Irecommend that the two phases be combined and, if necessary, lengthen the Article 39(a) by a day or two.- Your witness list exchange date doesn?t seem to work. You suggest a Government response to the defense?switness list on April 13, but then you would like the defense to turn around and ?le a motion to compelwitnesses two duty days later. While you know I want to move the process along, you seem to propose 2-3week timelines for you to respond and 1-2 day timelines for me to respond.- We can?t just ignore the issue of the possible OCA depositions. If the Court orders this, the timelines willshift.Best,David02564620David E. Coombs, Esq.Law Office of David E. Coombsll South Angel] Street, #317Providence, RI 02906Toll Free: l-800-588-4156Local: (508) 689-4616Fax; (508) 689-9282Notice: This transmission, including attachments, may contain con?dential attorney-clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlaw?ll and is prohibited.??" 02945933IFrom: Fein, Ashden CPT USA SJASent: Tuesday, February 28, 2012 7:40 AMTo: David CoombsCc: Matthew kemkes; ?Paul Bouchard'; ?Joshua Tooman'; ?Melissa Santiago?; Morrow JoDean,CPT USA Overgaard, Angel M. CPT USA Whyte, Jeffrey H. CPT USA Ford, Arthur D. W01 USA JFHQ-SJASubject: RE: ASUsDavid,Thank you. You provided some good points which we will work into our proposal. I intend tosend you another this afternoon and then hopefully we can discuss late afternoon earlyevening when you finish your proposals and send them over.v/rAshden02979904From: ?@mcc.gov1Sent: Friday, February 24, 2012 2:30 PMTo: Bradley, Princeton L. SGT USA SJASubject: FW: Request to Review NCIX Response (UNCLASSIFIED)Attachments: Millennium Challenge Corporation - Review of Compromised InformationhtmBradley:Attached please find the report MCC compiled in response to the wikileaks matter. Let meknow if you need anything elseMillennium Challenge Corporation875 15th StreetWashington, DC 26965pm- 02564614From: David Coombs Sent: Tuesday, February 28, 2012 2:18 PMTo: Fein, Ashden CPT USA SJ A Cc: Matthew kemkes 'Paul Bouchard'Joshua Tooman'|Thursday, May S, 2011 11:3] AMFein, Ashden CPT USA SJAMorrow JoDean, CPT USA SJASubject: RE: CID Case File and UpdateHi Ashden/Joe,Thanks for the update and the disks. Andy and I have taken a preliminary look and wanted to give you advance notice ofsome potential concerns that we have with some of the items on the unclassified disk, as follows:l'hat's it for now. But, I think it is fair to say that we will likely need an extension from Monday May 9 to complete thereview and obtain all necessary court orders.02213452Thanks,02907447From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Thursday, May 05, 2011 5:25 PMTo: - Dean, CPT - MDW SJAUSAVAE (USAVAE - AVAE): -FNSD) (NSD) Cc:ergaard. Angel M. CPT USA JFHQ-NCRIMDW SJAsubject: RE: CID Case File and UpdateThank you! we will start looking at this over the weekend. You can have asmuch time as you need? how much more time do you think you need? I think it would be better, if you continued to identify each document youhave an issue with, and then we get together to discuss the way forward withthose documents. That way, we can ensure we conducted due diligence duringdiscovery and EDVA D03 is not conducting any unnecessary processing on ourbehalf.I added Captain Angel Overgaard to this email. She is our newest addition to"Team Thank you again.AshdenAshden FeinCPT, JA 02911659From: Fein, Ashden CPT USA SJASent: Frida Ma 06. 2011 1:40 PMTo: om.miI;? USA emsCc: orrow oDean, CPT USA JFHQ-NCRIMDW SJASubject: (US v. PFC BM) Prudential Search I Preservation MeetingImportance: HighAre you available Monday afternoon For a meeting about the Prudential Search Preservationissue For PFC I would like to setup a time that will allow forto join us. If you can volley a good time, I will coordinate with them so wecan hopefully get a time locked in. we might also want to invite ?because hetypically signs the wide preservation requests in civil litigation cases.Thank you.AshdenAshden FeinCPT, JA 02902992 From: Fein, Ashden CPT USA SJASent To:Cc: Morrow ill, JoDean. CPT USA JFHQ-NCRIMDW SJASubject: DSS FilesGood afternoon. After having some time with our PSR/preservation memo, do you have any inputthat might assist us with Dos? Otherwise, I plan on Finalizing the request this weekend andsending them out on Monday.New Issue- As you know, the BM investigation is a joint investigation between US Army CID,FBI, and DSS. we spent a good portion of last week at the FBI going through their files andconducting a preliminary PSR?1ike review For our Article 32 investigation. Are you availableearly next week to discuss setting up a similar process with the DSS files? Luckily, we cameup with the tiered process with the that might assist with Thank you and have a good weekend.AshdenAshden FeinCPT, JA 02911700From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Frida Ma 06 2011 3:43 PMTo: hoop oGC?usA emsCc: Morrow JoDean, CPT USA SJASubject: RE: (UNCLASSIFIED)Sir/Ma'am,How is 1039 on Tuesday either at the Pentagon or at Ft McNair If atthe pentagon, could one of you please assist with finding a conference room?AshdenAshden FeinCPT, JA 02911692From: Fein, Ashden CPT USA SJASent: Frida Ma 06 2011 4:02 PMTo: $009 oGc? USA omeCc: orrow 0 an. CPT USA JFHQ-NCRIMDW SJASubject: RE: (UNCLASSIFIED)Thank you. 1636 in your office. Could you please send the office number.Ashden FeinCPT, JA0221 9726From: MLL USA OTJAG?us.army.mil>Sent: Sunday, May 8, 2011 2:16 PMTo: Fein, CPT USA SJA Subject: FW: SecArmy 15-6 (UNCLASSIFIED)From: Fcin. CPT USA JFH SJASent: Monday. May 02. 2011 7:29 PMTo: Manon Andras M. LTC USA SJACc: Bradley. Corey L. COL USA SIASubject: SccArm_v 15-6Sir.The prosecution requests the full use and disclosure of the SccAnny 15-6to the defense counsel. We will provide the enurc with awatcmiark which states to control distribution Up to02219726this point. portions have been provided to the different respondents ofadministrative actions and its likely certain documents have made itsway to the defense. This information is reasonably consideredmitigating and within the possession of the U.S. Army, thus discoverableunder RCM 405 for the Article 32 investigation.In addition, the prosecution requests copies of all adrninislrative FLAGSand associated documentation resulting from the SecArmy 15-6. Finally.the prosecution also requests complete copies of all adverse judicial.non-judicial. and administrative actions taken against any Soldiers orcivilians, resulting from the SecArmy 15-6. Although all the actionsmight not be complete, the prosecution can stan processing thisinformation immediately.Thankyou.v/rAshdenAshden FeinCPT. AClassi?cation: UNCLASSIFIEDCaveats: NONE 0221 3446From: @usdoj.gov> Sent: Tuesday, May 10, 2011 10: 15 AMTo: Fein, Ashden CPT USA SJA Morrow Ill, JoDean, CPT USA SJACc:VI usdoj.gov>;Overgaard, Angel M. CPT USA SJA Subject: RE: CID Case File and UpdateAshden.We have ?nished our document by document review and will put together aspreadsheet. I can discuss late this afternoon or Fn'da_v. Please letme know what day/time works best for you.Thanks.-02213438 From= _@usdoJ?sov>Sent: Tuesday, May 10, 201 1 2:39 PMTo: Fein, Ashden CPT USA ow SJA il>;Morrow JoDean, CPT USA Cc:3 usdoj.gov>;ov>; OverSubject: RE: CID Case File and UpdateAttach: Discovery - Review Attached please ?nd the spreackheet I promised.Are you available for a conference call at 4:30?? 02900462From: Fein, Ashden CPT USA SJASent: 11 7:31 AMCc: Morrow JoDean. CPT USA SJAsubject: IRTF QuestionSir,Are you available For a quick chat? It might need to be via STE. Thanks.AshdenAshden FeinCPT, JA 02187701From: Sent: Wednesday, May 11, 2011 9:01 AMTo: Fein. Ashden CPT USA SJASubject: stionSigned By: dodiis.miIIt?11 have to be sometime after 1130.A-Shae" CPT USA 53?? .sent: Wednesday, May 11, 2011 7:31 AMTo: Miller, Kenneth (GOV)Cc: Boehman, LTC Michael Morrow JoDean, CPT USA SJASubject: IRTF QuestionSir,Are you available for a quick chat? It might need to be via STE. Thanks.AshdenAshden FeinCPT, JA 02900460From: Fein, Ashden CPT USA SJASent: Wednesda Ma 11 2011 3:36 PMTo:Subject: RE: IRTF QuestionSir,Are you available to chat? Thanks.Ashden FeinCPT, JA?-??-Original From: Miller, Kenneth (GOV) Sent: Wednesday, May 11, 2911 9:61 AMTo: Fein, Ashden CPT USA SJASubject: RE: IRTF QuestionIt'll have to be sometime after 1130.From: Fein, Ashden CPT USA SJA1Sent: Wednesday, May 11, 2011 7:31 AMTo: Miller, Kenneth (GOV)Cc: Boehman, LTC Michael Morrow JoDean, CPT USA SJASubject: IRTF QuestionSir,Are you available for a quick chat? It might need to be via STE. Thanks.AshdenAshden FeinCPT, JA 021876991 From: ?@dodiis.minSent: Wednesday, May 11, 2011 4:00 PMTo: Fein, Ashden CPT USA SJASubject: stionSigned By: dodiis.miICall now if possible, as I am in the office For about 15 minutes. 02911843From: Fein, Ashden CPT USA SJASent: Wednesda Ma 11 2011 6:53 PMTo: USA OTJAGSubject: RE: (U) RE: Read upgrade (UNCLASSIFIED)Attachments: 11-May-11-Request Personnel Clearance and Access (ManningB).pdfS1r? attached is the formal request.Ashden FeinCPT, JA02907420From: Fein, Ashden CPT USA SJASent: Wednesda Ma 11, 2011 10:55 PM To: Dean, CPT USA SJACc: (FBI):vergaard, Angel M. CP USA HQ-NCRIMDW SJASubject: RE: CID Case File and UpdateAll,Thank you again for the review of the CID files. CID is going to go backthrough with additional security experts and completely review the documentsfor a 3d and final time- just for classified and potentially classifiedinformation. we are going to continue to reference those documents to workon obtaining the appropriate authorities for disclosure.Joe and Angel are going to coordinate with- to finish scrubbing the FBIfiles, and then we will put together our "wish list" of the documents wewould like authorization to use and/or turn over in discovery. This processwas coordinated with NSLB.Ideally, in the coming weeks, we will have a comprehensive list of alldocuments in all investigative files (CID, FBI, and DSS), that we would liketo seek approval for use during discovery and we will present the list toall for input and potential follow-on action requesting a modificationof sealing orders).After your help with the initial scrub of CID's files for your own equities,it is clear that we need a more deliberate tracking mechanism for everyoneto reference. we will start creating that process and incorporate in thework that has already been completed.Thank you again for the assistance and support! Any recommendations areappreciated as we continue moving forward.AshdenAshden FeinCPT, JA 02896551From: Fein, Ashden CPT USA SJASent: Thursday, May 12, 2011 12:11 PMTo: OTJAGCc: Morrow JoDean, CPT USA SJASubject: MondaySir,Do you mind if we stop by and meet with the 962d For no more than 30 minutes afterthe Agency meeting?AshdenAshden FeinCPT, JA02215300From: Sent: Friday, May 13, 201 1 3:42 PMTo: Fein, Ashden USA sm Cc: Matthew kemkes Morrow Ill, .loDean, CPT USAA Joshua Tooman CPT lv1lL USASJFeito, Deatriz SGT USAOvergaard, Angel M.CPT USA JFHQ-NCSubject: Discovery Request /Various IssuesAttach: Discovery Request - l3 May.pdf'Ashden,Please ?nd the attached supplemental discovery request. I also wanted to raise the following additionalissues with you:a) When PFC Manning is brought back to the MDW area for pretrial prep, the Article 32, and the trial, wherewill he be held? If he is held in Quantico, will the Brig insist on placing him back in Maximum Custody andPrevention of Injury Status even though this is clearly not warranted given the facts?b) Have you heard anything from the unit regarding the travel debt erroneously being taken from PFCManning's pay?c) I have not received the discovery that you intended to mail on Monday. Should I have received thediscovery by now, or is there a new date for this discovery?d) Any update on when the defense computer forensic expert will be able to begin his work?e) Finally, I want to introduce the newest member of the defense team CPT Joshua Tooman. CPT Toomanis stationed at Fort Leavenworth. His of?ce will need a GSA-approved safe in order to enable the defenseteam to conduct trial prep at either Fort Leavenworth or Fort Myer.Let me know if you have any questions.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-9282Notice: This transmission, including attachments, may contain con?dential attorney-clientinformation 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 informationmay be unlawful and is 02903791From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJAsent: Friday. May 13, 2011 5:19 PMTo: Cc: Matthew kemkes; Morrow Ill. JoDean_ CPT USA Bouchard, Paul CPT USCENTCOM USF-I USCENTCOM-- - Canile. Monica L. USA JFHQ-NCRIMDW Fe: 0. ea nz - NCRIMDW SJA: Ovengaard. Angel M. CPTUSA SJASubject: Re: Discovery Request Nanous IssuesDavid. Thank you. My computer just died and I was planning on sending you a copy of theexcludable delay memo. I will send it on sunday when I return.As Far as the discovery- we were not able to get the cd out until yesterday. It is in themail and you should get it early next week. Included on the cd is a copy of the short form796 results, the 15-6 and the slide show the jrc? gave to the press.we are still working on the approvals for the unclass case File, classified case File, andthe raw Forensic information. we now have the equipment to burn a copy of the 8tb of data foryour expert and that is being worked. we are also working on a location at leavenworth foryou to discuss "secret" info with your client.No decision has been made on where your client will be housed when brought back to the ncr.we are looking at all options to ensure we comply with army and dod regulations.The unit is still working the travel debt issue. That was supposed to be discussed today whenthe co visited your client at the brig.Is CPT Tooman replacing any members or is he an additional member?Josh- welcome! Please send me an email with your SSN and P08 so we can process yourclearance.Finally- do you have a home cac reader for your personal/work computers?Have a good weekend.AshdenAshden FeinCPT, JA 02187125From: ?@staae.gov>Sent: Wednesday, May 18, 201 1 8:58 AMTo: Fein, Ashden CPT USA SJA Cc: Morrow Ill, .loDean, CPT USA SJASubject: RE: DSS FilesHi Ashden:I am not sure which ?les you have requested from the larger Department of State as I have not seen the memo. That request may takefurther coordination between your of?ee and State/L.Inasmuch as your request pertains to the law enforcement ?les in the ongoing investigatiorL those ?les are contained here in theDiplomatic Security Service (DSS). Office of Professional Responsibility. The ?les are mostly emails. repons. and memoranda whichI drafted as the case agent. As you know. it was initially solely a DSS investigation with Army CID joining in late May and FBI inlate July. I am prepared to have your of?ee review all DSS ?les related to the investigation. We would like to conduct the review oneday next week if you are available to visit our offices in Virginia. Let me know which day is best for you.Regards.Special Agent. Diplomatic Sccunty ScrvicclOf?ce of Professional Responsibility IIPR) This e-mail is unclassi?ed based on de?nitions provided in E.O. l2958 02885075From:Sent:To:Cc:Subject:Attachments:Sir,Fein, Ashden CPT USA SJAMonday, May 23, 2011 7:55 AM'Coffman. Carl COL MIL Matthew kemkes; Morrow JoDean, CPT USABouchard. Paul CPT USCENTCOM USF-I 'Haber1and.John CPT MIL Overgaard, Angel M. CPT USA JFHQ-NCRIMDWFord. Arthur (Art 32 Delay Request)11-May-22-Govemment Request to Delay Article 32 The United States requests an additional delay of the Article 32. Please seethe attached request.v/rCPT FeinAshden FeinCPT, JA02907549From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Tuesday, May 24. 2011 10:38 AMTo: USA OTJAGCc: Morrow JoDean, CPT USA SJASubject: chat todaySir, are you available to chat today? How is 1360. Thanks.Ashden FeinCPT, JA02212331From: USA OTJAG ?conus.am1y.miI]Sent: Tuesday, May 24, 2011 11:47 AMTo: Fein, Ashden CPT USA SJASubject: RE: chat toda (UNCLASSIFIED)Signed By: j@us.army.muClassification: UNCLASSIFIEDCaveats: NONEOK Office of the Jud Advocate General of the Army, Pentagon 3D548NIPR: SIPR: @HQDA?S.army.smi1.mi1JHICS:Tel:02217313From:Sent:To:Cc:Subject: COFFMAN, CARL COL MIL USA Tuesday. May 24, 2011 457 PMFein. Ashden cm us?. sm Matthew kemkesMorrow Ill, JODean, CPT USA SJA Bouchard, Paul CPT USCENTCOMUSF- . ?l Haberland,J0hn CPT MIL USA Ovcrgaard, Angel M.CPT USA SJAArthur (Art 32 Delay Request) (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDMr. Coombs.Please provide me aCOL CoffmarL at!ny you may have by COB 25 May 2()l I.0221 5286 From: Sent: Tuesday, May 24, 201 I 8:46 PMTo: COL MIL USA IMCOMCc: Matthew kemkes Morrow Ill. JoI)ean, CPT USASJA USCENTCOM I{aberland,John CPT MIL USAOverszaard. Angel M. CPT USA Bouchard, Paul CPT SJA Ford, Arthur W01 USA JFHQ-SJA Fein, Ashden CPT USA JFHQ-SJA Joshua Tooman Subject: [Suspected RE: US v. PFC BM (Art 32 Delay Request) (UNCLASSIFIED)Sir,The defense maintains it position as stated in the 26 April 2011 memorandum. Given the limiteddiscovery provided so far, it is likely that the Article 32 will need to be delayed in order to provide thedefense with the ability to adequately prepare. The defense requests that any additional delay be creditedto the government.v/rDavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02188667Fro"-= _@state~sov>Sent: Wednesday, May 25, 2011 4:58 PMTo: Fein Ashden CPT USA JFH SJA state.gov>Cc: Morrow JoDean, CPT USA SJAFord, Arthur D. W01 USA JFHQ-SJASubject: RE: UpdateHi Ashden. Both?and I are free Thursday morning and Friday. Would either ofthose work? Th).This email is UNCLASSIFIED.02215285From: Paul Bouchard Sent: Wednesday, May 25, 201 1:18 PMTo: Fein, Ashden CPT- Subject: Re: Computer Forensics, US v. ManningAshden:Four issues vis-a-vis computer forensics, US v. Manning.1. The Defense will need a forensic image of ALL ofthe media involved;2. The Defense will need a copy of all of the Government's digital forensic reports;3. The Defense respectfully requests copies of the CV3 of the Government experts that have handled and/orworked on any digital evidence (or potential digital evidence) in this case FROM THE 4. Finally, will the Government allow the Defense's computer forensic expert to analyze the digital media INHIS LAB or will he have to travel to the DC area or wherever he can view the materials?Please acknowledge receipt of this e-mail. Best way to reach me is via e-mail at this address,. My cell phone number?. You can call me anytime.Thanks,Paul 02905685From: Fein, Ashden CPT USA SJASent: Thursday, May 26. 2011 6:21 PMTo: Paul Bouchand: Cc: . Morrow JoDean. CPT USA JFHQ-NCRIMDW vetgaa . nge USA Ford, Arthur W01 USA JFHQ-Matthew kemkesSubject: RE: Computer Forensics. Us v. ManningPaul,Thank you for the email. Answers are below:1. The Defense will need a forensic image of ALL of the media involved;Response: This is already being worked. The United States purchased a 8TBRAID and provided it to CID. CID is working on creating forensic duplicatesof the data.2. The Defense will need a copy of all of the Government's digital forensicreports;Response: Acknowledged. That has been our intent from the beginning. weare still working to obtain the appropriate approvals from the relevant 0CAsbased on the volume of classified information contained in the reports andon the drives.3. The Defense respectfully requests copies of the of the Governmentexperts that have handled and/or worked on any digital evidence (orpotential digital evidence) in this case FROM THE Response: we will begin gathering that information and will provide in thefuture.4. Finally, will the Government allow the Defense's computer forensic expertto analyze the digital media IN HIS LAB or will he have to travel to the DCarea or wherever he can view the materials?Response: Nothing has been finalized, but the most likely COA is to have thedefense expert travel to DC (Fort Belvoir) to view the material in a securefacility. we are still working an the logistics and planning in order tomake this the most efficient and secure process for the defense.At this point for security purposes, we will not send out any documents to"yahoo" or any other civilian (non-USG) email addresses, except David'semail. we can email you at AKO, if you would like. Please let me know andthank you for the update!AshdenAshden FeinCPT, JA02884710From:SentTo:Cc:Subject:Attachments:LTC Almanza,Good evening.Fein, Ashden CPT USA SJAThursday, May 26. 2011 6:26 PMAhnanza.PaulMatthew kemkes; Monow JoDean. CPT USABoucnand. Paul CPT USCENTCOM USF-I JA-TBO Habenand,John CPT MIL USA: Overgaard, Angel M.CPT US - ord, Arthur D. W01 USA SJA: JoshuaToomanUS v. PFC BM Article 32 Delay RequestDelay of Article 32 Investigation (ManningB).pdfPlease find attached an Article 32 delay approval signed by theIn an effort to assess the prosecution, defense, and Article 32investigation I0's information security capability, are you able to sign andemails on your D03 computer or using your DOD CAC card?Thank you.v/rCPT FeinAshden FeinCPT, JA02889459 From: Fein, Ashden CPT USA SJASent: Thursda Ma 26 2011 9:39 PMTo: USA omcCc: orrow ean, USA JFHQ-NCRIMDW Ford, Arthur D. W01 USA SJASubject: Security Expert RequestAttachments: 11-May-26-Request for Government Security Expert (ManningB).pdf5i9"?d Bv= Sir,Attached is the Prosecution?s request For a Security Expert. Also, as you will notice, onall technical-assistance emails, I am adding wo1 Artie Ford who is our team administrator.He dove head first into this case and is already doing a phenomenal job. His role is tocontrol all RFIs, RFAs, and internal tasks to ensure the team stays on track and Frees upsome of my time. Thanks and have a good weekend.we are not in the office tomorrow, but I will be working from home. Please call my BB if youhave any questions or issues. I would also like to setup a time for us to meet next week sothat I can pick up the CD and we can chat about the way ahead, if you have some time.Thanks!AshdenAshden FeinCPT, JA02892482 From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: To:cc: Morrow JoDean CPT USA Ford, Arthur D.wo1 USA SJA: _@usdoj.govSubject: Attachments: Preservation Letter (DOS).pdfhnponance: Good evening. This email is in reference to the case of U.S. v. PFC Bradley E. Manning.Please see attached prudential search request For DOS Files and records.Thank you.V/rAshdenAshden FeinCPT, JA 0290299From: Fein, Ashden CPT USA SJASent: Monda May 30. 2011 10:47 AMTo: Cc: Morrow Ill, JoDean, CPT USA JFHQ-NCRIMDW SJA: Ford, Anhur D. W01 USA JFHQ-NCRIMDW Overgaard, Angel M. CPT USA JFHQ-NCRIMDW SJASubject: RE: DSS FilesThanks For the call on Friday. To recap- you plan on giving us thefollowing:1. A copy of the PST from the beginning up to the date the FBI joinedthe investigation.2. Copies all of MOIs3. A document capturing nothing occurred with the one piece of evidence4. Contact info for G. Mundy so we can precisely understand what typeof information the firewall logs capture.The other emails will be preserved and we will work with FBI and DSS toFigure out the way Forward with those because they contain other assetsoutside of this case.Thank you again!AshdenAshden FeinCPT, JA02199478From: Ford, Arthur D. W01 USA Sent: Tuesday, May 201 I 5:00 PMTo: A OTJAG Cc: Fein, Ashden CPT USA SJA Subject: Meeting Request (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUOSir,I wanted to set up a time with you that we could come over to your office, pick up the CD from you, and catchup with you on everything that is going on. Please let me know when this would be convenient for you. Thanks.ArthurW01 Arthur FordLegal Administrator Classi?cation: UNCLASSIFIEDCaveats: FOUO02212306From: A OTJAG Sent: Tuesday, May 31, 2011 5:15 PMTo: Fein, Ashden CPT USA SJA Subject: FW: Security Expert RequestAshden.Don't know if you He is the OTJAG Sec Manager. Heis responsive and on top of his he of course just wentthrough the certification dn'll for the OTJAG move back into thebuilding. He wiU Contact you tomonow. vocatc General of the Anny, Pentagon 3D548A-S .smil. mil. gov 02907205From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent To:Cc: Ford,Ar1hur D. W01 USA Morrow. JoDean CPT MIL USASubject: Classification Reviews Thank you For your help. Today?s meeting was a success and we are ready to answer anyquestions you have. Could you please send us an update on the OCA classification reviews?Thank you.v/rAshdenAshden FeinCPT, JA02188119From: _lV DISA GC Sent: Monday, June 6, 20] I 10:09 AMTo: Fein, Ashden CPT USA SJA Cc: Morrow Ill, .loDeanSubject: RE: Deelassi?cation Memo (UNCLASSIFIED)Classi?cation: Caveats: Attached IS a scanned copy of the Declassi?cation Memo signed today bythe DISA Chief of Staff. Please con?nn the address on the memo is avalid mailing address. and I will express mail the document to you.Sincencl Deputy General Counsel. Regulatory and International LawO?ice ofthe General Counsel (DISA Ft. Meade, Room C4A24L)Headquarters Defense lnfomtation stems A encyPhone: Unelas. Email {If you send tot eman a dresses. please send an unclas email totellme vou sent it to a classi?ed system: Ddisa.smil.mil(dzdisa. ic. gov JWICSI 02892500 From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJAsent: Monda .June 06. 2011 1:31 PMTo: IL USA OTJAGcc: MIL USA USA SJASubject: Attachments: 11-Jun-06-Preservation Letter (DOD) (ManningB).pdfSir,Good afternoon. asked me to send you the updated PSR. After receiving immediatefeedback from the members of the intelligence community, we made two changes to thisdocument. In this document, we clarified the preservation portion of this request to onlyencompass the material produced as part of the prudential search and we limited the scope notto include the NSA, DIA, and DISA. Since the transfer of this case, we have been goingdirect with those agencies. I am available if you have any questions.Thank you.v/rAshdenAshden FeinCPT, JA02212301From: USA OTJAG Sent: Monday, June 6, 201 1 5:22 PMTo: Fein, Ashden CPT USA SJA Subject: . RE: Security SMEWhen do you want to meet with him? Date and time. As of now he will notbe designated a member of your will simply conduct the ncvicw25 the government classi?cation SME. He is the SME for Anny G2. I thinkwe need to hold him in reserve to conduct any classi?cation issuesinvolving the case that may be in dispute. But let's discuss tomonow it"you want he do be designated as part of your team now. vocate General of the Anny. Pentagon 3D548@,conus.anny.mil02889448From: Fein, Ashden CPT USA SJASent: Monda June 06, 2011 5:43 PMTo: USA omeSubject: ecun Thanks sir. How about 1689 tomorrow?Ashden FeinCPT, JA 02212299From: -MIL USA OTJAG @us.army.mil]Sent: Tuesday, June 07, 2011 7:56 AM To: Fein, Ashden CPT USA JFHQ-NCRIMDW SJACc: MIL USA USA Subject: RE: PSR-DOD (UNCLASSIFIED)Signed By: ?@hqda.army.mi|Classification: UNCLASSIFIEDCaveats: NONEGot it CPT Fein. will let you know when sent for action. Office of The Jud Advocate Generalomcez ATTORNEY CONFIDENTIALITY NOTICE - FOR OFFICIAL USE ONLYCAUTION: The information contained in this email and any accompanyingattachments 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 Defensewithout prior authorization from the Office of The Judge Advocate General,Department of the Army. If you are not the intended recipient of thisinformation, any disclosure, copying, distribution, or the taking of anyaction in reliance on this information is prohibited. If you receive thisemail in error, please notify this office immediately by return email.02212296From: USA OTJAG mconusarmymil]Sent: Tuesday, June 07, 2011 8:16 AMTO: Fein, Ashden CPT USA SJASubject: RE: Securit SMESigned By: i@us.army.mi|ok office of the Jud Advocate General of the Army, Pentagon 3D548NIPR:SIPR:JWICS:Tel: 02889447From: Fein, Ashden CPT USA SJASent: Tuesda . June 07, 2011 8:22 AMTo: USA omc;Subject: ecunsinned Bv= Sir,I will be there at 1690 today with a copy of the CD for the expert andhopefully we can spend some time and chat about issues?Thanks.AshdenAshden FeinCPT, JA02212292From: USA OTJAG Sent: Tuesday, June 07, 2011 8:23 AMTo: Fein, Ashden CPT USA SJASubject: RE: Securit SMESigned By: ?@us.army.mi|Great. Office of the Jud Advocate General of the Army, Pentagon 3D548SIPR: QDA-S.army.smi1.mi1JHICS: ami.ic. ov02895447From: Fein. Ashden CPT USA SJASam: Tuesda June 07 2011 8:48 PMTo: USA OTJAGCc: Ford, Arthur D. W01 USA Morrow Ill. JoDean, CPT USA JFHQ-NCRIMDW SJASubject: OCA Update Good evening. Could you please send us an update on the OCA classification reviews for theFollowing OCAs:CENTCOMCYBERCOMINSCOMSOUTHCOMThank you.V/rCPT FeinAshden FeinCPT, JA02899395From: Fein, Ashden CPT USA SJASent: Wednesday, June 08, 2011 11:23 AMTo: Cc: Matthew kemkes; Ford. Arthur D. W01 USA SJAsubject: Legal AdministratorDave,Have you had enough time to make a decision whether you would like a legal administratordetailed to your team? we are at the point where we need to make a decision so orders can becut. IF you choose to have the legal administrator, our plan is to house him/her at Meade.Thanks.AshdenAshden FeinCPT, JA02215282From: Sent: Wednesday. June 8. 2011 11:34 AMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Ford. Arthur D. WOI USA JFHQ-SJA . Paul Bouchard ?5 Subject: [Suspected RE: Legal AdministratorAshden,I think I will have a better idea on this issue once we receive the classified discovery. Do you have an update onwhen you anticipate being able to release this information?Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-9282Notice: This transmission, including attachments, may contain confidential attorney?clientinformation and is intended for the person(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying or use of this information may beunlawful and is 02188660From: ?@state.gov> Sent: Wednesday, June 8, 201 1 2:47 PMTo: Fein, Ashden CPT USA SJA Cc ?@stateAsov>Subject: RE: Classi?cation ReviewsAshden, do you have a sample OCA declaration which we could provide to our folks so they can use it as a model inpreparing ours. It's possible that you already provided thisPST file. Th).This email is UNCLASSIFIED.02199152From: Ford, Arthur D. W01 USA SJA Sent: Wednesday, June 8, 20] 1 4:14 PMTo: DCS Cc: Fein, Ashden CPT USA SJA USA OTJAG Subject: RE: (U) Document review (UNCLASSIFIED)Attach: Copy of CCIU Unclass case log.x|sxClassi?cation; UNCLASSIFIEDCaveats: FOUOAttached is the spreadsheet detailing the contents of the CID Case File. Columns and are the starting and ending documentnumbers for each document. Column details those documents that we would like you to focus on. but please review the entire ?le.Please call if you have any questions. Thank you very much for your help.ArthurWOI Arthur FordLegal AdministratorOSJA. USAMDW02212284From: DCS Sent:Wednesday, June 08. 2011 4:48 PMTo: Ford, Arthur D. wo1 USA SJAcc: Fein, Ashden CPT USA A OTJAGSubject: RE: Document review (UNCLASSIFIED)Signed By: us.army.mi|Classification: OFFICIAL USE ONLYThanks. Just being careful.Regards02212284 Message??--?From: Ford, Arthur D. N01 USA SJAISent: nes a une To: IV USA DCS G-2Cc: Fein, Ashden USA CIV USAOTJAGSubject: RE: (U) Document review Classification: UNCLASSIFIEDCaveats: FOUOAttached is the spreadsheet detailing the contents of the CID CaseFile. Columns and are the starting and ending document numbers For eachdocument. Column details those documents that we would like you to focuson, but please review the entire ?ile. Please call if you have anyquestions. Thank you very much for your help.ArthurN01 Arthur FordLegal AdministratorOSJA, USAMDH 02212282From: ?vm_ USA OTJAG Sent: Wednesday, June 08, 2011 5:04 PMTo: Fein, Ashden CPT USA MIL USA OTJAGCc: JFHQ-SJASubject: RE: PSR-DOD (UNCLASSIFIED)Signed By: ?@us.army.mi|Classification: UNCLASSIFIEDCaveats: FOU0Ashden - we have forwarded MDw?s request to?of OGC and copyfurnished DA OGC.v/r? Office of The Jud Advocate GeneralBB: 02889553From: Fein, Ashden CPT USA SJASent: Thursda June 09 2011 3:17 PMTo:Cc: Morrow Ill, JoDean. CPT USA JFHQ-NCRIMDW Ford, Anhur D. W01 USA JFHO-Subject: SecArmy 15-6 UpdateSir,Good afternoon. Could you please send us an update on our request For authorization torelease the SecArmy 15-6 to the defense. Thank you.v/rCPT FeinAshden FeinCPT, JA02215279From: Sent: Friday, June l0, 2011 l0:l0 AMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Morrow Ill, JoDean, CPT USASJA Ange M. CPT USA SJAFord, Arthur D. W01 USA SJA Joshua ToomanSubject: [Suspected RE: US v. PFC BM UpdateAshden,Thank you for providing the defense with an update. Here are my responses to your questions:1. I will speak with PFC BM and let you know if there are any issues with his uniforms.2. Please let me know once the pay issue has been resolved.3. I don't believe that there is a difference between a member of the defense team for privilege purposesas opposed to a member of the defense team for clearance purposes. CPT Tooman is assigned to thedefense team to assist the defense and is ful?lling that role.4. Legal Administrator. I don't want to make this decision without knowing if a legal administrator will beneeded. The defense will wait until after it receives the discovery to make this determination. If it is toolate for the JAGC to provide someone, then perhaps someone could be to provide the neededsupport?5. when you provide the information, please provide a disc copy to me and to MAJ Kemkes. This way, itwill avoid having a timelag between when the defense team has access to the information. MAJ Kemkeswill ensure that a copy is given to CPT Bouchard.6. As with the unclassified case ?le, please provide disc copies to me and to MAJ Kemkes. Also, ourcomputer expert will need to have the travel/funding piece worked out in advance so that he canimmediately begin his work.7. As with Fort Myer, I want the safe to be in the TDS office. CPT Tooman's office is just as secure andlarger than MAJ Kemkes? office. The safe should be delivered to CPT Tooman's of?ce. If needed, thisoffice and the attached suite can be used for defense team meetings.8. Thank you. This should not be a problem. As with my visits when PFC BM was at Quantico, thisshould be treated as a standard PTC detainee being taken to the TDS offices to prepare for trial. PFC BMand I will be preparing for the Article 32. I understand your question, but will respond by simply statingthat our discussions cannot take place at the JRCF. See United States v. Schmidt, 60 M.J. 1, 2 (C.A.A.F.2004); see also United States v, King, 200 CAAF LEXIS 472 (C.A.A.F. May 8, 200) (?nding that theconvening authority's appointment of an Investigative Security Officer to monitor conversations betweendefense counsel and the accused was not proper).9. Thank you. It would help if the government would specifically detail what actions it has taken toobtain investigations conducted by Dos, and other intelligence agencies.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angeli Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-928202215279Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02885104From:Sent:To:Cc:Subject:Attachments:Importance:Fein. Ashden CPT USA SJATuesda June 14 2011 9:05 PM Tum OTJAG: Morrow. DW Ford. Arthur D. W01 USA JFHQ-NCRIMDWSJAUS v. PFC BM - PSR11-Jun-14-Preservation Letter HighPlease Find the attached updated PSR. I did not include the enclosure because the same onewas attached to our previous PSR. This should clarify the preservation issue and we areavailable to discuss the ?reasonable scope? of the PSR. we also submitted a similar requestto DOD, but excluded DIA from that request.V/rCPT FeinAshden Feincpr, 3A02884675From: Fein, Ashden CPT USA SJASent: Tuesda June 14 2011 9:07 PMTo: Cc: orrow 0 an - Ford Arthur D. W01 USA JFHQ-~cR/Mow s.?Ae?sA oweSubject: US v. PFC BM PSAttachments: 11-Jun-14-Preservation Letter (DOS).pdfImportance: High Please Find the attached updated PSR. I did not include the enclosure because the same onewas attached to our previous PSR. This should clarify the preservation issue and we areavailable to discuss the "reasonable scope? of the PSR.v/rCPT FeinAshden FeinCPT, JA02911606From: Fein, Ashden CPT USA SJASent: Thursday, June 16. 2011 1:51 PMTo: Cc: Matthew kemkes; Morrow JoDean, CPT USA rgaar nge . - om, Arthur 1 USA JFHQ-SJASubject: RE: [Suspected RE: Leavenworth VisitDavid,I agree with you, but for a few issues. First and foremost, the conveningauthority authorized classified discussions to occur at Fort Myer and forclassified information to be stored at Fort Myer with the concurrence of theArmy G2. Quantico Brig was not equipped to allow defense counsel to haveclassified discussions with their clients or have classified documents intheir facility, which is why his movement to Fort Myer was supported.we are working these similar issues at Similar to when PFC BM wasconfined at Quantico, we are working to determine if the facility can meet therequirements and whether there is an operational need to have PFC BM moved outof the facility to meet with you and the defense team. In addition to theserequirements, there are security concerns with moving BM outside of thefacility when the facility is possibly fully equipped to meet all otherrequirements.AshdenAshden FeinCPT, JA02215271From: Sent: Thursday, June 16, 2011 2:1] PMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Morrow Ill. JoDean, CPT USASJA Overgaard, Angel M. CPT USA SJAFord, Arthur D. W01 USA Subject: RE: [Suspected RE: Leavenworth VisitAshden,I don't think whether a particular confinement facility can support classified discussions or not should be afactor. It is widely accepted that part of adequately preparing for trial in our system involves clients beingremoved from pretrial confinement to meet with their defense counsel. The JRCF, like all confinementfacilities, is not conducive for pretrial preparation.I will have a signi?cant amount of documentation with me. This documentation will be difficult totransport into the facility on a daily basis. Additionally, I do not wish to have this documentation beingsubject to inspection. with regards to the JRCF's attorney?client meeting room, it is not sound proof (Ican make out conversations in other offices), has a window which allows meetings to be monitored(guards do sit and watch our meeting - and undoubtedly can also hear what is being said), and does nothave internet access or the capability of printing documents.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Of?ce: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 021 88658From: Sent: Thursday, June 16, 2011 6:12 PMTo: Fein, Ashden CPT USA SJA Cc: Morrow I11, JoDean, CPT USA SJASubject: Quick call tomorrow?Ashden and Joe do you have time for a quick call tomorrow about the preservation/search request? We're in theprocess of drafting guidance to send out and I wanted to go over a few questions. I'm in meetings most of tomorrow,but free after 2:30 or so if that works for you.Thanks,U.S. Deiartment of StateSBUThis email is UNCLASSIFIED.02887541From: Fein, Ashden CPT USA SJASent: Frida June 17 2011 8:06 AMre: -I-?usAmSubject: todaySir? are you around today and available for a quick chat? Thanks.Ashden FeinCPT, JA02183198 From:Sent:To:Cc:Subject:Attachments:Follow Up Flag:Flag Status:USACIDC Friday, June 17, 2011 2:03 PMMorrow JoDean, CPT USA Fein, Ashden CPT USA Ford, Arthur D. W01 USA Overgaard, Angel M. CPT USA JFHQ-Whyte, Jeffrey H.CPT USA SJADiscovery UpdateMISC460 - Request for status update a for - 2nd Lexis Nexis Check rt pdf; MISC458 - DA Form 5070-CID Form 44 - Investigative Worksheet of .pdf; AIR of -26 May 11.pdfFollow upCompleted As agreed regarding discovery updates, here are some additional documents that have beenadded to the case File since the last update. Washington Metro Resident AgencyComputer Crime Investigative UnitUS Army Criminal Investigation Command27136 Telegraph RoadQuantico, VA 22134 02212243From: USA OTJAG _@us.army.mil]Sent: Frida June 17 2011 4:24 PMTo: USA JFHQ-NCRIMDW SJACc: Fein, Ashden CPT USA MIL USA OTJAGSubject: FW: Discovery Request - US v. Manning (UNCLASSIFIED)Signed By: musarmymilClassification: UNCLASSIFIEDCaveats: FOU0Sir Below is approval message from of OGC citing OSD approval ofMDw's request to disclose the 15-6.Please note that 1) 0SD's approval was conditioned on the government'simplementation of the "maximum reasonably available protections" againstunauthorized dissemination or disclosure of all or part of the AR 15-6 and 2)notification requirement of unauthorized disclosure of 15-6.Please let us know if you have any questions or concerns with the caveatsarticulated by_ below.v/r r1m1nal Law DivisionOffice of The Judie Advocate General02188107From: DISA GC _@disa.mu]Sent: Monday, June 20, 2011 12:00 PMTo: Fein, Ashden CPT USA SJACc: Morrow JoDean, CPT USA SJASubject: RE: Phone Meeting (UNCLASSIFIED)Signed By: _@disa.miIClassitication: UNCLASSIFIEDCaveats: NONEThe materials described in the document provided do not exist at DISA. As I pointed outbelow, we do not store the data that transits the DISN. Any records including contentrelating to alleged criminal activities by an Army soldier would most likely be Found on Armysystems, in Army enclaves.SincerelilDeputy General Counsel, Regulatory and International LawOffice 0? the General Counsel (DISA Ft. Meade, Room C4A24L)Headquarters Defense Information Systems AgencyUnclas. Phone: Fax: @disa.m1 Unclas. Email:02899410From: Fein, Ashden CPT USA SJASent: Monday. June 20. 2011 6:20 PMTo: Cc: Matthew kemkes; Morrow Ill, JoDeanNCRIMDW SJASubject: RE: Leavenworth VisitDavid,we understand your preference to meet with your client at the TDS office; however yourdiscussions will likely occur at the JRCF. we reviewed all your concerns about the JRCF andworked with the JRCF to fix the issues. we are still finalizing one issue with the computerand printer access, which should be resolved tomorrow. The JRCF did confirm that thepersonnel in the legal office can hear through the wall, so that issue should be resolved.The command?s ultimate concern is your client?s safety and security of classifiedinformation. Please see below for the details.1. The attorney client room has been certified to hold classified discussions up to thelevel, with modifications to the area that are occurring this eek.2. No persons except for one 316 confinee escort will be present in the CJA office duringvisits between Counsel and the accused. The escort will remain on the far side of the CJAoffice where he will be able to observe the accused through the window but will not be ableto hear any communications between the accused and counsel.3. The JRCF will provide printer and internet capabilities for counsel during meetings inthe JRCF.4. You may secure unclassified materials in the meeting room in the CJA office overnightso that you will not have the facility.5. The CJA will meet you at the front of the security checkpoint and your material will bekept confidential during the inspection.Once we receive final confirmation from the JRCF about the internet and printing issue, thenwe will go to the convening authority to request an additional location authorized for thediscussion and review of classified information.v/rAshdenAshden FeinCPT, JA02215256From: Sent: Monday, June 20, 201 9.09 PMTo: Fein, Ashden CPT USA sm Cc: Matthew kemkes Morrow Ill, JoDean, CPT USASJA . PT USA SJAFord, Arthur D. W01 USA JFHQ-Subject: [Suspected RE: Leavenworth VisitAshden,As I mentioned on the phone, conducting pretrial preparation at the JRCF is unacceptable. Anyrequirement to do so impedes the effective defense of PFC BM and raises multiple ethical issues. I intendto come to Fort Leavenworth on the 22nd to meet with PFC BM at the TDS of?ces from the 22nd throughthe 24th. I request that the necessary arrangements be made to accommodate this request.During our conversation, you told me that I should have coordinated my movement request of PFC BMthrough you and not the JRCF. This request is in direct contradiction to the instruction that I receivedfrom the JRCF Commander, LTC Dawn Hilton. I met with LTC Hilton and her staff on 25 March 2011. Atthat time, I informed her that, on occasion, it will be necessary to meet with PFC BM at the TDS offices atFort Leavenworth. I asked her how such a request should be routed. She informed me that her staffhandles the movement of detainees all the time. She told me that such a request should be routedthrough the CJA at the JRCF and also her. She assured me that such a request would not be a problem aslong as she received at least two weeks notice. At that time, she did request that I conduct my meetingsat the JRCF unless it was necessary to meet in the TDS offices. I informed her that I would only ask forhim to be brought out the JRCF when it was necessary as part of his defense preparation. In April, Ivisited PFC BM at the JRCF. Given the nature of our discussion, it was not necessary to request that he betransported to the TDS offices. My meeting with him this week, however, does require him to be movedto the TDS offices.Also during our conversation, you told me that there were signi?cant security concerns surrounding myrequest. In response, I informed you of what the RDC at Fort Leavenworth, LTC Doug Watkins, relayedto me concerning the security requirements. You asked that I forward the content of that message toyou. Below, is the exact quote that I received from LTC Watkins:Taylor (SJA) called today about this visit, relaying concerns from the JRCF Commandant. BringingManning out requires one armed guard, two unarmed guards, and alert of the SRT during the time he isout. They are offering the atty-client room in the JRCF for the 3 days you are here."Please let me know if you need any additional information.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-928202215256Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02911610From: Fein, Ashden CPT USA SJASent: Monday, June 20.2011 9:12 PMTo: Cc: Matthew kemkes; Morrow Ill. JoDean, CPT USA gvergaag. !nge| SJA: Fond. Anhur 0 W01 USA JFHQ-SJASubject: Re: [Suspected RE: Leavenwotth VisitThank you. As we discussed on the phone, we are diligently working this request with thejrcf.Ashden FeinCPT, JA02900425From: Fein, Ashden CPT USA SJASent: Tuesday, June 21. 2011 11:28 AMTo: Subject: IssueStill working issue. Mt? by end of day.Ashden FeinCPT, JA02215252From: Sent: Wednesday, June 22, 201 1 I129 PMTo: Fein, Ashden CPT USA SJA Morrow Ill, JODean, CPT USA JA Cc: Matthew kemkes Paul Bouchardos ua Tooman Subject: Potential IssueAshden,Ijust wanted to alert you to a potential issue. According to the civilian here at TDS, the escorts from theJRCF came in this morning to look at the of?ce. They instructed him that the of?ce door would berequired to be open and that a guard would be required to have eyes on PFC BM at all times. This mustbe a BM-only requirement since it is nowhere in AR 190-5. Obviously, this is not going to work.The of?ce that I am meeting PFC BM is on the 2nd Floor. There is no exit other that through the commonarea where the guards can sit. I am not worried about PFC BM doing anything or attempting to escape.I wanted to alert you to this issue so that you could perhaps resolve it before it becomes an issue.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02886312From: Fein, Ashden CPT USA SJASent: Wednesday, June 22. 2011 6:14 PMTo: Cc: Matthew Kemkes; Morrow JoDeanSJASubject: UpdateAttachments: Purcell BIO DUTY Protective Order for LESInformation (ManningB).pdf; Protective Order for SecArmy 15-6(ManningB).pdf; 22Jun11 Protective Orders.pdt; 11-Jun-17-Excludable Delay Memorandum(ManningB).pdf; 11-Jun-22-Approved Facility and Storage for Classified Information(ManningB).pdfDavid,Good afternoon. I assume by not hearing back from you today, there were nofurther issues with you meeting with your client. Please let us know if thereare any issues.1. As you may already know, we worked to obtain a paralegal to push over toTDS for primary support of this case and your team. SSG Purcell surprisinglyarrived today. She comes highly recommended by multiple OSJAs and seemsincredibly bright and highly motivated. She also has an impressive resume -attached. we are working on her final mobilization orders and she is here onher two?week AT. Once MAJ Kemkes lets me know which office she will work outof, we will push her to TDS. She can assist MAJ Kemkes and his team until youneed her services for this case.2. Attached is an excludable delay accounting memorandum from the conveningauthority.3. Attached are two protective orders for unclassified discovery. The firstis for the Secretary of the Army 15-6 into the wikileaks disclosure. Thesecond is for law enforcement sensitive information and other sensitiveinformation. Please review and have your team members sign theacknowledgments. Note, the law enforcement sensitive protective orderrequires all members to sign a standard acknowledgment and also a copy of theactual federal protective orders provided as enclosures. As of this email,each member of the team should be sending in 7 total signed documents- 2acknowledgments and 5 Disclosure and Protective Orders. Once we receive theSecArmy 15-6 acknowledgments and everyone validates that their CACcertificates work on the PDF, we will send out the SecArmy 15-6 and allrelated material. Once we receive the other acknowledgment, protectiveorders, and a federal intelligence agency completes their classificationreview, we will send out the CID unclassified case file.4. Attached is the amended classified material handling and use order.5. we have not received the original signed classified protective order fromMs. Smith.6. CPT Casamatta should be obtaining the appropriate information from PFC BMabout his travel voucher issue to get final resolution. 028863127. All uniforms should have been received two weeks ago. This includes: 2ACU tops, 2 ACU bottoms, 1 patrol cap, 1 beret, 1 belt.8. we have a contract to have movers place a dedicated safe in CPT Tooman'soffice on 1 Jul. If you need to store notes during this trip, then there is adedicated drawer, with its own lock, for you to use, with a combination thatwill be set when you arrive. If you wish to have access, please let us (JohnHaberland) know, and we will ensure you have unfettered access.Have a good night.v/rAshdenAshden FeinCPT, JA02187683 From: @dia.mi|]Sent: Thursday, June 23, 2011 1:10 PMTo: Fein, Ashden CPT USA SJASubject: RE: PSR Other InfoSigned By: I am on leave next able stand ins.Deputy General Counsel OperationsDefense Intelligence Agency 02902167From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Thursda June 23, 2011 2:44 PM To:Cc: Ford. Arthur D. W01 USA Morrow JoDean,- CRIMDW SJASubject: RE: Follow-up to meeting: FBI OGC POC InfoI hope all is going well. It has been a while since we last spoke. weFinally Finished our initial review of the FBI Files and are now working onour request for copies and use during discovery. In addition, we areworking a Prudential Search Request of the FBI and would like to know who weshould address the request through and for? If could you please send thenames and titles of those individuals, we can send out our request.Thanks.AshdenAshden FeinCPT, JA02198644From: Ford, Arthur D. WO1 USA SJASent: Frida June 24. 2011 8:58 AMTm Cc: USA Fein, Ashden CPT USA SJASubject: Clearance Request (UNCLASSIFIED) Classification: UNCLASSIFIEDCaveats: FOUOSir,Attached is a request for clearances For two individuals that are a part ofthe Manning Case. Please let me know if you need anything else. Thank you, Sir.N01 Arthur FordLegal AdministratorOSJA, USAMDNClassification: UNCLASSIFIEDCaveats: FOUO 021 87676Sent: Friday, June 24, 20l I l:3l PMTo: Ford, Arthur D. W01 USA SJACc: Fein, Ashden CPT USA SJA Subject: RE: 1c Badges (UNCLASSIFIED)I submitted the request to our security chief and spoke to a rep from yourSSO.Will let _vou know as soon as I hear something.!nera| !?ounselDefense Intelligence AgencyWi i034002187667 From: @dia.mil>Sent: Friday, June 24, 201 4:53 PMTo: Ford, Arthur D. W01 USA SJACc: Fein, Ashden CPT USA SJAOvergaard, Angel M. CPT USA SJA@dia.mil>Subject: RE: IC Badges (UNCLASSIFIED)Attach: 1C badges approvedpdfSee attachment.IC badges are appnoved pending receipt of the clearances passed by your SSOto outs. I provided the S50 address to your SSO earlier today. !ss1s!n| !ounselDefense Intelligence AgencyWashinion, DC 2034002885077From:Sent:To:Cc:Subject:Attachments:Importance:Sir,Fein, Ashden CPT USA SJAMonday, June 27. 2011 6:17 PMCOFFMAN.CARL COL MIL USA IMCOMMatthew kemkes; Morrow Ill, JoDean, CPT USA :1 Overgaard. Angel M.CPT USA JFHQ-NCRIMDW SJA: Ford. Arthur 0 W01 USA JFHQ-NCRIMDW SJA: JoshuaTooman; Ford. Arthur 0. W01 USA JFHQ-NCRIMDW SJAUS v. PFC BM (Art 32 Delay Request)11-Jun-27-Government Request to Delay Article 32 (ManningB).pdfHighThe United States requests an additional delay of the Article 32. Please see the attachedrequest. we apologize For not providing an update sooner, but we were hoping to have anapproval before the end of last week.v/rCPT FeinAshden FeinCPT, JAAshden FeinCPT, JA02884839From:Sent:To:Cc:Subject:Attachments:Fein. Ashden CPT USA SJAMonday, June 27. 2011 6:25 PM Morrow Ill. JoDean. CPT USA JFHQ-ord(PSR)11-Jun-27~Preservation Letter (WATERMARK) (FBl).pdfPlease Find attached PSR. Thank you.v/r?AshdenAshden FeinCPT,JAA JFHQ-NCRIMDW Overgaard, Angel M.02897281From: Fein, Ashden CPT USA SJASent: Monday. June 27. 2011 7:03 PMTo: OTJAGCc: Morrow JoDean, CPT USA Ford, Anhur D. WO1 USA JFHQ-SJASubject: MeetingSir,welcome back. Are you available at 1499 tomorrow (Tuesday) or wed morning at 1939? we cancome over and huddle to give you and update and receive an update on the OCA classificationreviews.Thanks.AshdenAshden FeinCPT, JA02212228From: A OTJAG Sent: Tuesday, June 28, 201 I 10:13 AMTo: Fein, Ashden CPT USA SJA Subject: RE: Meeting (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONEMy of?cc. Office of the Judge Advocate General of the Anny. Pentagon 3DS48SIPR: JWICS: .?iIcdami.ic.gov 02887542From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Tuesda June 28. 2011 12:28 PMTo: how DISA GCCc: Morrow JoDean, CPT USA SJASubject: TodayMa'am. Are you available to meet at 1336. I am in a meeting that is running late. Thx.Ashden FeinCPT, JA02188097 From: DISA GC disa.mi|]Sent: Tuesday, June 28, 2011 12:35To: Fein, Ashden CPT USA SJASubject: RE: Toda UNCLASSIFIED)Signed By: @disa.mi|Classification: UNCLASSIFIEDCaveats: NONEI can do 13:36, but I have a 14:30 meeting in another part of the building, so we will haveby 14=15- 02217293From:Sent:To:Cc:Subject:COFFMAN, CARL COL MIL Wednesday, June 29, 20| 1 4:56 PMFein, Ashden CPT SJA Matthew kemkes il>; Morrow Ill, JoDean, CPT SJA - Overgaard, AngelM. CPT LISA Ford.Arthur D. WOI USA Joshua Tooman(Art 32 Delay Request) (UNCLASSIFIFD) Classi?cation: UNCLASSIFIEDMr. Coombs.Do you have any comments on the request??COL Coffman02903484 -From: Fein. Ashden CPT USA JFHQ-NCRIMDW SJASent: Wednesday, June 29, 2011 6:18 PMTo: MIL USA OTJAGCc: SA Morrow JoDean. CPT USA JFHQ-NCRIMDW SJASubject: DOD PSR Update (US v. PFC BM)Sir,Good afternoon. I was wondering if you have an update on the Prudential Search Request(PSR) the prosecution sent up a Few weeks ago? Thank you.V/rCPT FeinAshden FeinCPT, JA 02212226From: USA OTJAG Sent: Wednesday, June 29, 2011 6:33 PMTo: A PT SA SJACc: USA Morrow Ill, JoDean, CPT USA JFHQ-SJASubject: RE: PSR Update (UNCLASSIFIED)Signed By: ?us.army.miIClassification: UNCLASSIFIEDCaveats: FOUOAshden I have not heard from DOD, but will follow up.v/r? Office of The Jud Advocate GeneralBB:0221 5247From: Sent: Wednesday, June 29, 201 1 8:37 PMTo: COFFMANCARL COL MIL USA Cc: Matthew kemkes Morrow JoDean, CPT USAOvergaard, Angel M. CPT SJAFord, Arthur D. USA JFHQ-Joshua Toomanen U. A SJA SJASubject: [Suspected RE: US v. PFC BM (Art 32 Delay Request) (UNCLASSIFIED)Sir,The defense maintains it position as stated in its 26 April 2011 memorandum. Once the Government isable to provide the classified and unclassi?ed discovery, we will likely need to delay the Article 32 hearingin order to provide the defense with an opportunity to adequately prepare. The defense requests that anyadditional delay be credited to the government.DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02187628ay, une To: Fein, Ashden CPT USA Morrow JoDean, CPT USA JFHQ-SJA Cc:Subject: her InfoSigned By: dodiis.mi|Follow Up Flag: Follow upAshden, Joe,Enjoyed our meeting yesterday and appreciate all your hard work on the case.Here's an update with some request for additional information on some of theaction items:- CENTCOM classified documents. If you'll provide an audit trail includingthe contact information for the POC to whom you sent the request forclassification review, someone from IRTF will follow-up and try to shakeloose the CENTCOM reply. Alternatively - or perhaps in addition to that IRTF can help identify a SME to help you with the documents you intend touse. According to_. Deputy Chief, IRTF, Russ Enderton - theCENTCOM SME I suggested yesterday is on his way to Afghanistan in a fewweeks.Cost Data. and I will talk with? from the DIAFinancial Executive (FE) about IRTF costs. There's a spreadsheet shemaintains, and she can explain the details better than any of us. By theway,?works here at Russell Knox, same building as CID and you couldmeet with her if/when you visit here.IRTF Final Report. - also confirmed that the IRTF finalreport is complete and about ready to be published. You'll get a copy.PSR. The IRTF portion of DIA's reili is complete. ?prepared theIRTF reply to the PSR and reviewed and approved ityesterday. I've asked'later to confirm status of the overall DIAreply, which is due 5 July as I recall.Earlier PSR Stuff. I've also asked- to make the materialavailable to your team for review.Let me know if I've missed anything. Assistant General CounselDefense Intelligence AgencyRoom E3638 Russell?Knox Building, Quantico, VA 02907384From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Thursda June 30, 2011 10:56 PMUS USA USACIDC Cc: USAJFHQ-NCRIMDW Morrow JoDean, CPTUSA Ford, Arthur D. W01 USA JFHQ-NCRIMDW Overgaard.Angel M. CPT USA Feito, Beatriz SGT USA JFHQ- SJASubject: CID Case File DisclosureAttachments: Protected Docs.pdf; Complete Set of Docs.pdf; Protective Order forLES Information (ManningB).pdfAll,Good evening. Attached are two PDF documents of our master list of the CID unclassified casefile. After receiving input from our security experts, CID, EDVA, FBI, OGA, and the NSA, wehave filtered the documents into two group~ Those requiring further review/approvals andthose that we can release. This is all under the assumption that the defense counsel andmembers of the defense team sign the appropriate disclosure and protective orders. SeeAttached Order.we intend to produce the set of documents which are not ?protected? next week. Pleaseconduct a final review of our "Complete Set of Docs.pdf? to determine if there are anydocuments that you thing should be added to the initial ?Protected Docs.pdf? list. Once weconduct this first production, we will circle back and start working on the next productionof the remaining documents.If you have any questions, please call. The team will be back in the office startingTuesday, although we all have blackberries now. I will not be back for another week as Icatch-up on sleep in Anguilla.Thank you and have a good holiday weekend!v/rAshdenAshden Fein02907384cm?, JA02198356From: Morrow Ill, .JoDean, CPT USA SJASent: Tuesda .Jul 05,2011 2:03 PMTo: IV USA Cc: Fein. Ashden CPT USA Overgaard, Angel M. CPT USA JFHQ-SJASubject: chat (UNCLASSIFIED)94908? Classification: UNCLASSIFIEDCaveats: FOUOGents,Do you all have time for a phone chat about the way forward with CENTCOM and classificationreviews? Ashden and I spoke with each of you individually, but I think it would be helpful(at least to us) to put our heads together and come up with a tentative COA.Ashden is out this week, so it will just be me. I?m available at your convenience. Thanks.Respectfully,CPT Joe MorrowTrial CounselU.S. Army Military District of Washington (MDN)Classification: UNCLASSIFIEDCaveats: FOUO02187614From :@diaAmiI>Sent: Tuesday, July 5, 2011 3: I8 PMTo: Fein, Ashden cm USA sm-Cc= ?@dia.miI>Subject: CENTC OM Docs I spoke to the CENTCOM intcl attomcy and he will nosc around and try to ?ndout what the hold up is. I will let you know what he comes up with.V/r.02215207From: Paul Bouchard Sent: Thursday, July 7, 201 1 2:30 AMTo: Fein, Ashden CPT USA SJA Cc: Subject: Renewed request for computer forensic expert, Mr. Eric Lakes and Cyber AgentsAttach: Renewed Expert Request, PDF.pdf; Cyber Agents Fee Scheduledoc; Eric Lakes CV.doc;Request for Expert Assistant for PFC Ashden:This is what we talked about -- the Defense renews its request for Mr. EricLakes and his company. Cyber Agents lnc.. as an expert assistant for the Defensetcarn. See -- Mr. Lakes was previously approved by the originalconvening authority for $5600.00. Given the amount of data in the case at hand.Mr. Lakes will need more funding to include costs associated for travel.lmportantly, given that there is no way to precisely pinpoint how long and timeconsuming the computer forensics will take. we are asking that any additionalwork be billed and subsequently paid at per hour.The first attachment clearly outlines our requests. The other attachments aresupporting documents.I'll be at Fon Meade late next week.E-mail me or call me should you have any questions.Best.Paul02212224From: @conus.army.miuSent: Friday, July 08, 2011 8:54 AMTo: Morrow JoDean, CPT USA Cc: Fein. Ashden CPT USA Overgaard, Angel M. CPT USA JFHQ-NCRIMDW SJASubject: RE: chat (UNCLASSIFIED)Signed By: us.army.miIClassification: UNCLASSIFIEDCaveats: FOUO309,I have time today. I also have started on a equity" reviewof the CENTCOM Docs. Office of the Judge Advocate General of the Army, Pentagon 3D548NIPR:SIPR:JHICSTel: 02183102From: Sue?) ?@man.miI1Sent: Tuesday, July 12, 2011 1:47 PMTo: Fein, Ashden CPT USA Morrow Ill, JoDean, CPT USA JFHQ-SJAcc: Two; Sm)Subject: 902d Iogs (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOGents,I just got word from 902d that they did find some logs. I?m not exactly sure what they areat this point, but it sounded like they are also providing the docs BM accessed. -15going to pick them up for us this week.Classification: UNCLASSIFIEDCaveats: FOUO02892543From: Fein, Ashden CPT USA SJASent: Tuesda ,Jul 12, 2011 7:47 PMCc: orrow 0 an, A Ford, Arthur D. WO1 USA JFHQ-SJASubject: PSR Update5i9"?d Sir,Could you please send an update on the PSR we submitted? Thank you.v/r?AshdenAshden FeinCPT, JA02907528From: Fein, Ashden CPT USA SJASent: Wednesda Jul 13 2011 4:23 PMTo: ?uspx om;subject: chat tomorrowSir- are you available to chat on the phone tomorrow?Ashden FeinCPT, JA 02212222From: USA OTJAG Econusarmymil]Sent: Wednesday, July 13,2011 5:32 PMTo: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASubject: RE: chat tomorrow (UNCLASSIFIED)Signed By: musarmymilClassification: UNCLASSIFIEDCaveats: NONESure 0??ice of the Judge Advocate General o? the Army, Pentagon 3D548NIPR: SIPR:JNICS:Tel: 02212220From: OTJAG Sent: Thursday, July 14, 2011 8:24 AMTo: Fein, Ashden CPT USA SJASubject: RE: chat tomorrow (UNCLASSIFIED)Signed By: musarmymilClassification: UNCLASSIFIEDCaveats: NONE1136 is better for me. Office of the Jud Advocate General of the Army, Pentagon 3D548NIPR: SIPR:JWICS:Tel: 02907523From: Fein. Ashden CPT USA JFHQ-NCRIMDW SJASan: 55AMTo: USA OTJAGSubject: Re: chat tomorrow (UNCLASSIFIED)I will call. sir.02907961 From: Fein, Ashden CPT USA SJASent: 2011 12:43 PMTo:Cc:Subject: RE: CENTCOM DocsAre you around today? IF so can we chat about this ongoing issue? Thanks.AshdenAshden FeinCPT, JA02183015Subject:Attachments:Follow Up Flag:Flag Status:Thursday, July 14, 2011 3:31 PMFein, Ashden CPT USA Morrow JoDean, CPT USA JFHQ-NCRIMDW Ford, Arthur D. W01 USA JFHQ-NCRIMDW SJA@maiI.mi|RE: IA Discs- TDY risk matrix, Leavenworth_Chicago.pdf; MISC464 - Interviewresults of Inmate .pdf; - Final information - FBI302 re PFC financials 1 Jul 11. f? - Internet article containing chatlogs between PFC MANNING and?df; AIR of 21 Jun11.pdf; AIR of 22 Jun 11.pdf; AIR o_ 22 Jun 11.pdf; DA Fonn 4137099-11.pdf; DODIG Subpoena 2010233-10428 18 Jun 10 and subpoena results pertaining toPFC MANNINGS Facebook account.pdfFollow upCompletedAttached are some new documents to be added to your growing collection 0' discovery docs.Washington Metro Resident AgencyComputer Crime Investigative UnitUS Army Criminal Investigation Command27138 Telegraph RoadQuantico, VA 22134 02907955From: Fein, Ashden CPT USA SJASam: Frida Jul 15 2011 936 AMTo: aSubject: Re: CENTCOM DocsIf you are avail to chat, do you mind calling at?. My plane is runninglate so I should be available For the next 36-45 min. Ihx.02212213From: MIL USA SentMonday, July 18, 2011 10:08 AMTo: Fein_ Ashden CPT USA SJASubject: FW: Re uest for Preservation of Evidence (UNCLASSIFIED)Signed By: ?@us.army.mi|Classification: UNCLASSIFIEDCaveats: FOUOAshden - Please see e-mail below I am awaiting word from OGC on statusof request to preserve evidence. will let you know when I get moreinformation.Has 32 date been set yet?v/rCriminal Law DivisionOffice of The Judge Advocate Generalinal Messa i.?hm oecSent: Monday, July 18, 2011 9:43 AMTo: MIL USA OTJAGCc: MIL USA OTJAGSubject: RE: Request for Preservation of Evidence (UNCLASSIFIED)Let me check with Deputy General Counsel for LegalCounsel, as her office was given this tasking because it is similar to whatthey do in other litigation that involves records/files from possiblemultiple entities within DOD.inal Messa -i-141: usA ems|mailto?@us .army.mil|Sent: Friday, July 15, 2611 5:44 PMTo: DOD OGCCc: MIL USA OTJAGSubject: RE: Request for Preservation of Evidence (UNCLASSIFIED) Classification: UNCLASSIFIEDCaveats: FOUOMr.- MDW has asked for a status on its request for the search of102212213records and preservation of evidence related to the PFC Manning case.Appreciate your help.v/r Criminal Law Division Office of The Judge AdvocateGeneralinal Messa From: i Don oGcSent: Thursda June 69 2011 9:14 AMTo: MIL USA OTJAGSubject: RE: Request for Preservation of Evidence (UNCLASSIFIED)Thanks.??-?-Original From: MIL USA OTJAGmailto us.arm .milSent: Wednesday, June 98, 2011 5:91 PMTo: OGCCc: MIL USA CIV USA OGCSubject: Request for Preservation of Evidence (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: FOUOAs previously discussed with-, I am forwarding a request from theMilitary District of Washington OSJA to the Department of Defense for thesearch for records and preservation of evidence related to the case of US v.PFC Manning. A cover letter from- is also attached.I am ccing from DA OGC for her situational awareness.v/r Criminal Law Division Office of The Judge AdvocateGeneral 02212213Attachment Classification: UNCLASSIFIEDAttachment Caveats: NONEClassification: UNCLASSIFIEDCaveats: FOUOClassification: UNCLASSIFIEDCaveats: FOUOClassification: UNCLASSIFIEDCaveats: FOUO02213055 us.amiy.mil>; Fein, Ashden CPT USA SJASubject: RE: Meeting regarding Manning PSR With Capt Fein's eoneet entail this time.VIIFrom: DOD OGCSent: Monda Julv I8, 20] I 1:00 PMTo:rMlL USA MIL USA OTJAGL Cc: DOD OGCSubject: Meeting regarding Manning PSR Gentlemen.Our office will be handling the PSR. I spoke with Capt Fein this morning. He suggested that we have a meeting to assess how toproperly scope a pnidential search of to ensure efficiency and effectiveness. I propose meeting in our spaces here at 1099 14thStreet. Suite (at 14th and Streets two blocks north of the McPherson Square metro station on 14th Street). I had suggestedtomorrow at I400. but I am pretty ?exible on the tinting. Please let me know what would work best for you.Vr/Associate Deputy General Counsel (Litigation Counsel)U.S. Department of Defense O?ice of General Counsell60() Defense Pentagon Room 3B688Washington DC. 02897098 From: Fein, Ashden CPT USA SJASent: Monda Jul 18 2011 1:41 PMTo:cc:Subject: RE: Meeting regarding Manning PSRGentlemen,we (the prosecution) are free tomorrow afternoon and most of this week. wewould like to meet as soon as possible so this action can start workingthrough the system. Thank you.v/rAshdenAshden FeinCPT, JA02213053From:Sent:To:Cc:Subject:?@osd.mn>Monday. my 18. 2011 2:54 PMrm USA OTJAG MIL USA OTJAG .us.am1y.mil>; Fein. Ashden CPTjaw Meeting regarding Manning PSR (UNCLASSIFIED) Should plan on Tucsda) at I400 then. or unit unlil hear from?as Vr/MIL USA omo Scnt; Mondas. Julv I8. 2:04 PMTo DOD Subject: RE: Mccling regarding Manning PSR (UNCLASSIFIED)VirClassi?cation; UNCLASSIFIEDFOUOI am available at I-UK) on 'l?ucsda_\ as wellLieutenant Colonel. S. AmnOffice of The Jud Advocate General ?e02897095From:Sent:To:Cc:Subject:Fein, Ashden CPT USA JFHQ-NCRIMDW SJAMonda Jul 18 2011 2:56 PMDon oec?eMrL usA owAe:jMIL USA OTJAGSJA: MorrowIll, JoDean. CPT USA JFHQ-NCRIMDW SJARE: Meeting regarding Manning PSR (UNCLASSIFIED) The prosecution team will be there. Do we need to pass any clearance info?There will be two of us (Captain Ashden Fein and Captain Joe Morrow) and weboth have pentagon badges and IC badges.v/rAshdenAshden FeinCPT, JA02887464From:SentTo:Cc:Subject:Fein, Ashden CPT USA SJA'1 Ph?USA Morrow ill, JoDean, CPT USA Ford, Arthur D. W01 USA JFHQ-SJAToday's MeetingThank you for meeting with us today. To recap:Classification Reviews. You are still working with INSCOM on their classification review.The SOUTHCO classification review is being finalized and the ongoing issues with CENTCOM arebeing resolved through the Joint Staff. Thank you for assisting with speeding up the CENTCOMclassification review process by having the DA Staff conduct a pre?review to speed up theprocess with CENTCOM.Thank you.v/rCPT FeinAshden FeinCPT, JAYou are also working with CYBERCOM to finalize their review.02213037From:Sent:To:Subject:Attach: osdamiI>Thursday, July 21, 2011 12:09 PM ,osd.mil>, Fein, Ashden CPT USA9 SJA us.army.mi1>;SJA @ifh Morrow 111, JoDean,CPT USA JF11Q-NC RE: Meeting regarding Manning PSR (UNCLASSIFIED)Manning preservation with.docAll.I attached a draft tasking letter for the PSR. Plem let me know if there is anything that needs to be included in order to not frustratethe purpose of your request.02197868From: Morrow Ill, .JoDean, CPT USA SJASent 11'To:Cc: Fein, Ashden CPT USA SJASubject: RE: Meeting regarding Manning PSR (UNCLASSIFIED)Signed By:Classification: UNCLASSIFIEDCaveats: FOUO Do you have time for a phone call with me and Ashden? Let us know and wecan call or you can call Ashden's blackberry we are in theprocess of moving offices, so phone connectivity is limited right now.Thanks.CPT Joe MorrowTrial CounselU.S. Army Military District of Washington (MDN) 02197860From: Morrow JoDean, CPT USA SJASent: Thursda ,Jul 21, 2011 2:17 PMTo:Cc: Fein. Ashden CPT USA SJASubject: RE: Meeting regarding Manning PSR (UNCLASSIFIED)Attachments: OSD 03295-10 (Morrow HighIights).pdfSigned By:Classification: UNCLASSIFIEDCaveats: FOU0Attached is the sample distribution memorandum we received with highlightedThose offices, agencies, or organizationswe have dealt with directly or indirectly are highlighted in green. Thoseentities we have reason to believe may have responsive information arehighlighted in yellow. we highlighted DIA, DISA, and NSA, but we sent thoseagencies their own prudential search request and they should be excluded.This document is a starting point, but we defer to your judgment withrespect to distribution throughout 000. Our specific COCOM list is below,subject to the same caveat as above.COCOMS- CENTCOM- NORTHCOM- SOUTHCOM- USSOCOM- USSTRATCOMRespectfully,CPT Joe MorrowTrial CounselU.S. Army Military District of Washington (MDN) 02182977From: usAcIDc Sent: Monday, August 08. 2011 9:38 AMTo: Fein, Ashden CPT USA SJASubject: Discovery update (UNCLASSIFIED)Attachments: JRCF Interview worksheet, 1 Aug 11.pdf; - Registere abe|s.pdf; -Miscellaneous emails.pdf; MISC485 Miscellaneous notes - SA .pdfSigned By: ?@us.anny.miIClassification: UNCLASSIFIEDCaveats: FOUOSome more updated discovery. I do not yet have Artie and Joe's certs so Ionly sent this to you.Washington Metro Resident AgencyComputer Crime Investigative UnitUS Army Criminal Investigation Command27139 Telegraph Road, E6233uantico VA 22134 Classification: UNCLASSIFIEDCaveats: FOUO0218297702182977021829770218297702182977021829770218297702182977021829770218297702182977021829770218297702182977021829770218297702182977021829770218297702182977021829770218297702186865Sent: Friday, July 22, 20] I 5106 PMTo: Fein, Ashden CPT USA SJA Morrow Ill, JODean, CPT USA SJASubject: PSR responseAshden, Joe, I just got the disc of material to review. I won't be able to get through it before your requested date of Aug1. We'll let you know next week after we get through some of it when we think we will complete the review.FBI Washington Field Officeoffice:mobile02885097From:Sent:To:Cc:Subject:Attachments:Importance:Sir,Fein. Ashden CPT USA SJAMonday, July 25, 2011 9:55 AMCOFFMAN. CARL COL MIL USA IMCOMMatthew kemkes; Morrow JoDean, CPT USA I: Ovengaard, Angel M.CPT USA SJA: Ford, Arthur 0. W01 USA JoshuaTooman; Ford. Atthur (Art 32 Delay Request)11-Jul-25-Govemment Request to Delay Article 32 (ManningB).pdfHighThe United States requests an additional delay of the Article 32. Pleasesee the attached request.v/rCPT FeinAshden FeinCPT, JA02902198From SentTo:Cc:Subject:Good afternoon.Fein, Ashden CPT USA JFHQ-NCRIMDW SJAMonda ,Jul 25 2011 3:20 PMMorrow JoDean. CPT USA Ford. Arthur D. W01 USA JFHQ-NCRIMDW Overgaard, Angel M. CPT USA SJAFollow?up to MeetinOur schedules are open this week. when is a good a time tomeet at FBI main so we can discuss the way forward with the use request andThanks.Ashden02217288From:Sent:To:Cc:Subject:COFFMAN, CARL COL MIL USA IMCOM ?il>Monday, July 25, 201 I 332 PMFein, Ashden CPT USA SJA Matthew kcmkes Morrow Ill, JoDean, CPT USASJA >sM. CPT USA SJA Arthur D. W01 USA SJA Joshua Tooman Ford, Arthur D. W01 USA JFHO(Art 32 Delay Request) (UNCLASSIFIED) Overgaard, AngelClassi?cation: UNCLASSIFIEDMr. Coombs.Does the Defense have any issues with the request??COL CoffmanFord.02216841From: Sent: Monday, July 25, 2011 5:52 PMTo: COL MIL USA Cc: Matthew kemkesMorrow Ill, JoI)ean, CPT USA. - JA Overgaard, Angel M. CPT USA SJAFord. Arthur 1). W01 USA JFHQ-Joshua ToomanFein, Ashden CPT USA SJA SJA Subject: [Suspected RE: US v. PFC BM (Art 32 Delay Request) (UNCLASSIFIED)Attach: Article 32 Delay Sir,Please see the attached document for the defense response.DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02981121From: Fein, Ashden CPT USA SJASent: Tuesday. July 26, 2011 8:10 AMTo: Cc: Matthew kemkes; Morrow Ill, JoDean, CPT USA il'; Overgaard, Angel M. CPT USA Fond.ur . ?Joshua Tooman?Subject: US v. PFC BM Discoveryhnponance: David,Good morning. we received your memorandum to the in reference to the Article 32 delayrequest.Yesterday, we delivered to MA) Kemkes and placed in the US Mail for you, three DVDs ofdiscovery. 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 sortthrough the remaining information and seek the approvals we must have in order to produceeverything that is discoverable. As we have discussed in the past, our intent is to send theinformation 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 theprotective orders, please ensure the information is not shared with any team member until wereceive a copy of the signed acknowledgments and initialed (or signed) federal protectiveorders.100% - Coombs, Kemkes, Santiago, and PurcellPartial - ToomanNone All othersv/rAshden02903023From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Tuesda Jul 26. 2011 9:17 AMTo: ACc: Morrow JoDean, CPT USA Ford, Arthur D. W01 USA JFHQ-SJASubject: RE: DSS FilesI hope all is going well. Could you please provide us an update on burningthe DSS case file and associated PSTs onto disks for us? ThanksAshden02182944From:Sent:To:Subject:Attach:Tuesday, July 26, 20: 1 3:06 PMFein, Ashden CPT USA SJA Morrow JoDean, CPT USA JA Discovery Update (UNCLASSIFIED)AIR of_ 5 May Ilpdf; AIR of? I4 Jul Ilpdf; AIR of-I8 Jul DA Fonn 4l37, DN 099-] l.pdf; MISC466 - CID Fonn44 - Investigative Worksheet of Inmate - CID Form 44 -Investigative Worksheet and LexisNexis Report of pdf; MISC468 -Grand Jury list addition - MISC469 RFA to Ft LeavenworthRA re periodic re?interviews.pdfClassi?cation: UNCLASSIFIEDCaveats: OUOHere is the latest discove update. I still owe you the audio ?les of theoi and 2uetro AgencyComputer Crime Investigative UnitUS Army Criminal Investigation Command27130 Telegraph Road. E0233Quantico. VA 22134 Classi?cation: UNCLASSIFIEDCaveats: FOUO02884715From: Fein, Ashden CPT USA SJASent: Tuesday. July 26. 2011 9:40 PMTo: 'AImanza, Paul?Cc: Matthew kernkes; Morrow JoDean, CPT USA'Haber|and.John CPT MIL Overgaard, Angel M. CPT USA Ford, Arthur D. W01 USA JFHQ-?Joshua Tooman'subject: US v. PFC BM Article 32 DelayAttachments: Delay of Article 32 Investigation (ManningB).pdfLTC Almanza,Good evening. Please find attached an Article 32 delay approval signed by theThank you.v/rCPT FeinAshden FeinCPT, JA02188912 From: ic.fbi.gov>Sent: Wednesday, July 27, 201 1 7:49 AMTo: Fein Ashden CPT USA JFI-I SJA Subject: Re: Follow-up to MeetinAshden -How does Thursday at 2 pm work for you?Thanks.02902196From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Wednesday, July 27. 2011 7:50 AMTo:Cc: Morrow Ill, JoDean, CPT USA JFHQ-NCRIMDW Ford. Arthur D. W01 USA JFHQ-NCRIMDW Overgaard, Angel M. CPT USA JFHQ-NCRIMDW SJASubject: RE: Follow-up to Meetin2pm works well for us. Thanks.Ashden02900955From: Fein, Ashden CPT USA SJASam: 2011 9:52 AMTo:Subject: RE: info for you on your other e-mail-1IF you are available, could you please call? Thanks.Ashden02943395From: Fein, Ashden CPT USA SJASent: Thursda Jul 28 2011 5:16 PMTo: *usA OTJAGCc: Morrow Ill, JoDean, CPT USA Ford, Arthur D. WO1 USA JFHQ-SJASubject: CENTCOM Class ReviewAttachments: Sir,Please see attached re uest For CENTCOM to finish the classification review.we must have themcompleted prior to the Article 32. Thank you.v/rAshden02919770From:Sent:To:Cc:Subject:Attachments:Sir,Fein, Ashden CPT USA SJAUSA OTJAGMorrow Ill, JoDean, CPT USA Ford, Anhur D. WO1 USA JFHQ-SJASOUTHCOM Class ReviewThursdail Juli 28' 2011 5:17 PMPlease see attached request for SOUTHCOM to Finish the classificationwe must have themcomplete prior to Artic 32addendum with anadditional document For their review that was just found two weeks ago.Thank you.v/rAshden02930297From: Fein, Ashden CPT USA SJASent: Thursda Jul 28 2011 5:17 PMTo: USA OTJAGCc: Morrow JoDean, CPT USA Ford, Arthur D. W01 USA JFHQ-SJASubject: INSCOM Class ReviewAttachments: Sir,Please see attached request for INSCOM to finish the classification review.must have themcompleted prior to the Article 32. Thank you.v/rAshden02922846From:SentTo:Cc:Subject:Attachments:Thanks For the meeting today.Fein, Ashden CPT USA SJAThursda Jul 28, 2011 5:58 PMicIbLgovMorrow JoDean, CPT USA JFHQ-NCRIMDW Overgaard, Angel M. CPT USAFord, Arthur D. W01 USA SJAProtective OrdersProtective Orders (US v. BM).pdfAttached are copies of the protective orders.we did not include the Federal disclosure protective orders, but thedefense was required to sign those as well.As we understand from today's meeting, you are assisting with getting usaccess to the FBI case file and its sub?fi1es that directly deal with PFCManning (case name purposely removed). Thank you.Ashden02182762From:Sent:To:Subject:Attachments:Classification:Caveats: FOUOSA USACIDC ?@us.arrny.mil]Monday, August 01, 2011 2:53 PMFein. Ashden CPT USA Morrow Ill, JoDean, CPT USA JFHQ-Ford, Arthur D. W01 USA SJAMore discovery (UNCLASSIFIED)MISC481 - TDY Worksheet - Cincinnati.pdf; MISC482 - Miscellaneous JRCF notes.pdf;- Return of Service - brad|ey.manning Facebook - YahooInc information pertaining to email account MISC478 - Forensicexam tracking spreadsheet. f? MISC477 - orensic xamination MISC476 -morandum - FBI Memorandum reproperty_1.pdf; MISC474 - Grand Jury Notice - pdf; MISC473 -Miscellaneous Forensic Documents.pdf; MISC472 - Subpoena Results Documentationpertaining to ?@yahoo.com.pdr; MIS 4 1 - I tion TrackingSheet.pdf; - DA Forms 3964.pdf; AIR 18 Jul 11.pdf;DODIG Sub oena 2010247-10458 and subpoena results pertaining to a mit.edu.pdf; DODIG Subpoena 2010233-10433 results pertaining to theemail r; AIR of ?pr 11.pdf; JRCFCanvass Interview Worksheets, 6-7 May 11.pdf; AIR of 19 Jul 11.pdf UNCLASSIFIED?cleaned out his office which revealed some additional documents andneeded additions.The evidence tracker update is almost complete.Washington Metro Resident AgencyComputer Crime Investigative UnitUS Army Criminal Investigation Command27136 Telegraph Road, E6233Quantico, VA 22134 Classification: UNCLASSIFIEDCaveats: FOUO02188096From: mv DISA GC Sent: on ay, ugust 1, 2011 3:15 PMTo: Fein, Ashden CPT USA SJACc: Morrow Ill, JoDean, CPT USA SJASubject: US v. PFC BM Coming with CD5 to your place (UNCLASSIFIED)Signed By: ?@disa.mi|hnponance: Classification: UNCLASSIFIEDCaveats: NONEI have 2 unclas. CD5 and 1 CD I'll be there as soon as I can get there.SincerelDeputy General Counsel, Regulatory and International Law Office of theGeneral Counsel (DISA Ft. Meade, Room C4A24L) Headquarters DefenseInformation Systems AgencyPhone: Unclas. Email: Classification: UNCLASSIFIEDCaveats: NONE02936274From: Fein, Ashden CPT USA SJASent: Tuesda Au ust 02, 2011 7:27 PMTo: MIL USACc: Morrow Ill, JoDean, CPT USA SJASubject: Discovery Update (US v. PFC BM)hnponance: LowSir,Below is FYSA. As discussed before, we are continuing to provide evidence indiscovery as we receive approvals.v/rAshdenFrom: Sent: Tuesday, August 02, 2011 7:19 PMTo: Fein, Ashden CPT USA SJACc: Matthew kemkes; Morrow JoDean, CPT USA 3 Overgaard, Angel M. CPT USA Ford,Arthur D. N01 USA Joshua ToomanSubject: [Suspected RE: Discovery Update (US v. PFC BM)Importance: LowAshden,Thank you for the update.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-869-588-4156Fax: (508) 689-9282Notice: This transmission, including attachments, maycontain confidential attorney-client information and is intended for theperson(s) or company named. If you are not the intended recipient, pleasenotify the sender and delete all copies. Unauthorized disclosure, copying oruse of this information may be unlawful and is -- Original Message Subject: Discovery Update (US v. PFC BM)1 02936274From: "Fein, Ashden CPT USA Date: Tue, August 02, 2011 2:50 pmTo: Cc: "Matthew kemkes"CPT USA "Morrow JoDean,"overgaard, Angel M. CPT USA "Ford, Arthur D. N01 USA"Joshua Tooman" David,we sent you and Kemkes the following today in discovery (BATES36618-36802):(ID Case File UpdatesFLAG Memo for Sec Army 15-6SFC Adkins Reduction Board Appeal and AttachmentsBM's newly executed Nondisclosure Agreement (NDA)Your tracking number: 7010 1060 0001 1272 6251.v/rAshdenTracking:02925026From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Wednesda Au us! 03, 2011 9:02 AMTo:Cc: Morrow JoDean, CPT USA JFHQ-NCRIMDW SJASubject: RE: New Email AddressUnfortunately not. we are still working on approvals to turn overclassified information to the defense and then we will start lookin atdates +or the Article menthe trial. Probabl another man months. Thank you 02216756From: Sent: Wednesday, August 3, 20ll 9:51 AMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Morrow Ill. JoDean, CPT USASJA Overgaard, Angel M. CPT USA SJAFord, Arthur D. WOI USA JFHQ-SJA Joshua Tooman Subject: Security ExpertsAshden,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 toreview information. Let me know if you have any questions.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02942858From: Fein, Ashden CPT USA SJASent: Wednesda Au ust 03, 2011 2:42 PMTo: ?av DISA GCCc: orrow ean, CPT USA Ford, Arthur D. W01 USA JFHQ-SJASubject: Classification Guidehnponance: I?ghThank you again for such a quick response to the PSR. we are starting to gothrough the information. we are conducting a classification/security reviewof our case file and notice in the DISA SCG there is no definitions for thefollowing. Could you please provide some definitions so we can ensure ourmaterial is properly classified and handled appropriately:Customer IdentificationSystem IdentificationNAN identified as Port IdentificationThank you!CPT Fein02216709From: Sent: Wednesday, August 3, 201 I 5:10 PMTo: Fein, Ashden CPT USA SJ A Cc: Matthew kemkes Morrow JoDean, CPT USASJA vergaard, Angel M. CPT USA SJAFord, Arthur D. W01 USA JFHQ-Joshua ToomanSubject: Expert RequestAttach: Dr. Grieger Capt. Moore Emailpdf, Dr. Grieger Curriculum Vitae.pdf; Dr.Grieger Fee Schedu|e.pdfAshden,Please see that attached expert request. Let me know if you have any questions based upon a review ofthe request and attachments.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02935188Ftom: Fein, Ashden CPT USA SJASent: Wednesday. August 03. 2011 5:14 PMTo: Cc: Matthew kemkes; Morrow JoDean, CPT USA Overgaard, Angel M. CPT USA Ford.ur . 1 A Joshua ToomanSubject: RE: Expert RequestDavid,Acknowledge receipt. Thank you and we will start working this immediately.v/r?Ashden02188648From: _@state.gov>Sent: Thursday, August 4, 201 11:20 AMTo: Fein, Ashden CPT USA SJA Cc: ?@state-gov>Subject: Classi?cation ReviewAshden, I just left you a voice mail re the classification review. We've made good progress on it and should be finishingup a draft soon. If you could give me a call, I think we'd be able to facilitate next steps.My work My cell phone is_. I'm hoping you can call me today, but if not, tomorrow I willbe in Kansas City, but still available on my cell phone. In light of the progress we're making, I'm hoping we can talk asap(it'll be short).Also, as I noted in my last email, has assumed ?mrtfo?o. I have not yet had a chance to brief him on thismatter, but hope to do so soon.SBUThis email is UNCLASSIFIED.02938121From: Fein, Ashden CPT USA SJASent: Saturday, August 06, 2011 7:33 PMTo: Paul BouchardCc: Ford, Arthur D. W01 USA JFHQ-NCRIMDW Overgaard, Angel M. CPT USA SJASubject: RE: Defense Request for hardware and softwarePaul,Thank you. we will review these requests this weekend and get back to youby Tuesday on any issues, such as the request should be for the sincehe 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 aCorporation/Company as an expert assistant (along with all its employees)vice only appointing individuals within the Corporation/Company. we have notfound a case on point.Have a good weekend.v/rAshden02216683From: Paul Bouchard Sent: Sunday, August 7, 201 10:14 PMTo: Fein, Ashden CPT USA SJA Cc: Subject: Re: Defense Request for hardware and softwareAshden:Do you really need legal precedent cited in order to appoint Cyber Agents, Inc. and its employees? Reason askis, is there any prohibition requesting a corporation as a defense expert assistant? The Government contractswith 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,Paul02938164From: Fein, Ashden CPT USA SJASent: Sunday, August 07, 2011 10:30 PMTo: 'Pau|BouchanfCc: Overgaard, Angel M. CPT USA SJASubject: RE: Defense Request for hardware and softwarePaul,we do need some legal precedent to accomplish this request. I absolutelyagree that corporations and companies are billed for expert assistance witnesses; however we did not find any case law that supports theproposition that an entire corporation and all its employees can beappointed to the defense team as expert assistants. we consider theprohibition to exist in the plain language of the rule, which identifies aperson 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/rAshden02216680From: Paul Bouchard Sent: Monday, August 8, 20] I 7:37 AMTo: Fein, Ashden CPT USA SJA Cc: Subject: Re: Defense Request for hardware and softwareAshden;What if I just submit a separate expert request for the appointment of Trent Struttmann as an additional defenseexpert?I'm sure that the government has had multiple computer forensic experts at CCIU working on this case. Giventhe amount of information (8 terabytes) and the scope of work, the defense will need the services of anadditional representative from Cyber Agents. This additional expert is needed in order to perform the reviewrequired in this case, and to avoid any unnecessarily delays due to the amount of information requiredto be reviewed.Please let me know.Thanks,Paul02938160From: Fein, Ashden CPT USA SJASent: Monday, August 08, 2011 7:43 AMTo: 'Pau|BouchanfCc: Ford, Arthur D. W01 USA Overgaard, Angel M. CPT USA SJASubject: RE: Defense Request for hardware and softwarePaul,At this point, we have no objection to multiple expert assistants to furtherassist Eric Lakes and anyone else the defense requests. The only issue iswhether the convening authority has the power/authority to appoint acompany/corporation vice individual employees. we are already working anadditional 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 otherinformation we will either need or recommend changed before we take therequest to the v/rAshden02915339 From: Fein, Ashden CPT USA JFHQ-NCFUMDW SJASent: Monda Au ust 08 2011 8:25 AMTo: Don occCc: DOD Morrow Ill, JoDean, CPT USA JFHQ-NCRIMDW MIL USA OTJAGSumem: Good morning. Do we owe you anymore information regarding our Do youhave an ETA of when it will go out and the potential mechanism to track itsresponses?Thank you.v/rAshden02213031 a@osdamn>Sent: Monday, August 8, 2011 8:34 AMTo: Fein, Ashden CPT USA SJA Cm @<>sdami1>; Morrow PTUSA SJAus.anny.mil>Subject: Re: US v. PFC BM (PSR)Ashden,lt vicnt out a few weeks ago. I will send you a copy on Thursday. The sus was August 12th. I have gotten a response back fromJS and COComs. which is basically a list of they gave to ?for her search. I will send that to you onThursday as well. What is you high-side email?Vr02916403From: Fein, Ashden CPT USA SJASent: Monda ,Au ust 08, 2011 9:04 AMTo: Cc: Morrow Ill, JoDean, CPT USA Ford, Arthur D. WO1 USA JFHQ- Subject: RE: US v. PFC BMGood morning. I am the lead prosecutor For the case of US v. PFC Manning.Could you please send me an date on the Prudential Search Request wesubmitted throughi, dated 14 June 2611. Thank you.V/rAshden Fein02182650From: USACIDC ?@us.army.mil]Sent: Monday, August 08, 2011 9:38 AMTo: Fein, Ashden CPT USA SJASubject: Discovery update (UNCLASSIFIED)Attachments: JRCF Interview worksheet. 1 Aug 11.pdf; MISC483 - Registered mail labeIs.pdf; MISC484 -Miscellaneous emails.pdf; - Miscellaneous notes - SA Signed By: ?@us.army.milClassification: UNCLASSIFIEDCaveats: FOUOSome more updated discovery. I do not yet have Artie and Joe's certs so Ionly sent this to you.Washington Metro Resident AgencyComputer Crime Investigative UnitUS Army Criminal Investigation Command27130 Telegraph Road, E0233Quantico, VA 22134 Classification: UNCLASSIFIEDCaveats: FOUO02188645From ?@stateasov>Sent: Monday, August 8, 2011 10:57 AMTo: Fein, Ashden CPT USA S.l CG ?@stateas0v>Subject: FW: DeclarationAshden, re the classification review for the firewall and server logs, in the email 2 below our IT folks are asking whetherwe should put classification markings on the logs (they wouldn't have them in the normal course of business).Thoughts? SBUThis email is UNCLASSIFIED.02939132From:Sent:To:Cc:Subject:Fein, Ashden CPT USA SJAAugust 08. 2011 11:32 AMstate.gov'state.gov'; Ford, Arthur D. W01 USA Morrow JoDean,CPT USA SJARe: Declaration - we would prefer? DOS mark them so we can ensure we do not make a mistake. Thx.02924202From:SentTo:Cc:Sumem:Mr.-Thank you.Fein, Ashden CPT USA SJAMonda Au ust 08, 2011 2:10cw DISA CIV DISA GCFord, Arthur D. wo1 USA PT USA JFHQ-CIV Mr cw USARE: part In (UNCLASSIFIED)Are you available tomorrow morning for the phone call. This isvery useful information because up to this point, we (law enforcement andprosecution) have operated under much of the information being classified.I think a 15 minute chat could clarify the information.v/rCPT Fein02924192From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Monda ,Au ust08, 2011 2:26 PMTo: DISA ?cw DISA GCCc: or ur . 01 USA SJA- Morrow JoDean. CPT USA JFHQ-Subject: RE: part II (UNCLASSIFIED)To make this easier, our securit ex ert DIA is available tomeet with you in person this week. Shecan meet first thing in the morning or towards the end of the day. Are youavailable to sit down with her so she can have a Full understanding of what isand is not classified. Thank you!CPT Fein02216673From: Paul Bouchard Sent: Tuesday, August 9, 2011 8:59 AMTo: Fein, Ashden CPT USA SJA il>;Bouchard, Paul CPT MIL USA OSA Cc: Ford, Arthur D. W01 USA SJA Overgaard, Angel M. CPT USA SJASubject: Re: Defense Request for hardware and softwareCPT Fein:It was good talking to you over the phone. 1 will get this to you today -- will con?nn 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 ofone of his employees. Bottom line: Best we start from scratch, especially given that it's a new conveningauthority as compared to July of last year.Again, I'll have this product to you today.CPT Bouchard02216650From: Sent: Tuesday, August 9, 20]] 1:31 PMTo: Fein. Ashden CPT USA SJA Cc: Ford, Arthur D. WOI USA SJAOvergaard, Angel M. CPT USA JFHQ-Matthew kemkesBouchard,Pau| CPT MIL USA OSA Subject: RE: [Suspected RE: Defense Request for hardware and softwareAshden,Yes, I explored other options with Dr. Jehle. My preference was to find someone in the Leavenworth areathat 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 andhas adequate time to devote to the case. Given our track record so far with government employees, itseems that the better course is to find someone that is being paid for his time (versus adding to his dailyduties). My guess is that an expert who charges by the hour will not cite other work conflicts as a reasonto disengage.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Toll Free: 1-800-588-4156Local: (508) 689-4616Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02936279From: Fein, Ashden CPT USA SJASent: Tuesda .Au ust 09, 2011 3:20 PMTo: MIL USACc: Morrow JoDean, CPT USA Ford, Arthur D. W01 USA JFHQ-SJASubject: FW: Discovery Update (US v. PFC BM)Sir. FYSA. we sent additional discovery today. Vr Ashden--?--original From: Fein, Ashden CPT USA SJASent: Tuesday, August 09, 2011 3:19 PMTo: Cc: Matthew kemkes; Morrow JoDean, CPT USA Overgaard, Angel M. CPT USA Ford,Arthur D. N01 USA Joshua ToomanSubject: Discovery Update (US v. PFC BM)David,we sent you and Kemkes the following today in discovery (BATES 036803):Quantico Brig RecordingsYour tracking number: 7010 1060 0001 1272 6268v/rAshdenTracking:02926230From: Fein, Ashden CPT USA SJASan: 11 01720AMTo: USA Cc: Morrow JoDean, CPT USA Ford, Arthur D. W01 USA JFHQ-SJASubject: Monday MorningSir,we (Joe and I) will be at the Pentagon Monday late morning. will you beavailable to meet? Thanks.Ashden021 96580From: Ford, Arthur D. W01 USA SJASent: Thursda Au ust 11 2011 8:26 AMTo: #6/x OTJAGCc: Fein, Ashden CPT USA Morrow JoDean, CPT USA JFHQ-SJASubject: Security request for Defense Computer Forensics experts (UNCLASSIFIED)Attachments: Forensic Ex rt Securit Re uest. Follow Up Flag: Follow upFlag Status: CompletedClassification: UNCLASSIFIEDCaveats: FOUOand? are computer Forensic Experts, and they havebeen as rart of the defense team. Attached is a request for a clearanceFor and access For Both and Please let me know ifyou need anything else. Thanks.ArtArthur FordN01, JALegal AdministratorClassification: UNCLASSIFIEDCaveats: FOUO02188631From: ?@slate-gov>Sent: Thursday, August ll, 20ll 2:42 PMTo: Fein, Ashden CPT USA SJA Cc: @state.gov>; Ford, Arthur D. W01 USA SJA Morrow JoDean, CPT USA SJA Subject: RE: OGA InfoEven though only the titles to the cables are being disclosed (not thecables themselves). we've been directed to look at the underlying cablesto ensure they are unclassi?ed. and consider any other sensitivities inthe cables. In light of the below. I've gone back to our people andasked whether we can locate the cables in a way other than wewe triedso far.Separately. re the preservation and search request. we are stillconsidering ways that we can reach consensus here at State to launchthat. One way suggested was to check with DOD to see how they arehandling it. Would you mind if I touched base with your DOD contact tosee what they're doing?? Thw-SBUThis email is UNCLASSIFIED02188631SBUThis email is UNCLASSIFIED.From: Fein. Ashden CPT USA SJA!ent: Tuesday. Augusto?). 2011 12:0! PMTo: Blanck. John 1Ce: Mehta. Jason Ford. Arthur D. WOI USA MorrowJoDean. CPT USA SJASubject: Re: marking of log FilesJohn. Cd is fine. Thx.From: Blanck. John Sent: Tuesday. August 09. 2t)1l 08:57 AMTo: Fein. Ashden CPT USA SJACc? Mehta. Jason Ford, Arthur D. W01 USAomow . 0 can. CPT USA SJASubject: FW: marking of log filesbelow is an email from one of our IT supervisors explaining thedifficulties in printing out the logs. I'm wondering if we could attachthem to the affidavit in the form ofa CD or sonte other electronicmedia instead of hard copies. The jibSBUThis email is UNCLASSIFIED.From: Johnson. Margaret ASent: Tuesday. Augusto?). 201] 7:46 AMTo: Houser-Jackson. Celeste Blanck. John ICc: Yanci. Joseph Johnson. Glen Subject: marking of log filesI reviewed some of the log files today due to the tasking to portionmark printed versions of these records. We have exported the NCD logfiles from the CD so we can prim and mark them. but the Firewall logshaven't been exponed yet.The system logs for both NCD and Firewall are designed for on-linereview by system administrators and are not optimized for printing. Forexample. some of the log entries contain over 1000 characters of text onone line. I opened one of the larger NCD log [iles (there are over lot)separate NCD log files and they vary considerably in size) as aprintable document and the file constituted over l2.000 pages. Iresized the log file using an extremely small font size of 8 pi and the02188631resulting output was still almost 8.000 pages. Based on the paginationresults I found opening Files of various sizes. I estimate that printingthe NCD logs alone. even with a very small font. would yieldapproxirnately 90.000 to l00.000 printed pages.Printing and classifying this ntany pages of logs would be a Sisypheantask (I can't imagine anybody would wade tltrough pages of logs)and l'm seeking guidance as to recommended course of action.Re gards.Margaret A. Johnson SBUThis entail is UNCLASSIFIED.02914279 From:SentTo:Cc:Subject:Attachments:Importance:David,Fein. Ashden CPT USA SJAThursday. August 11. 2011 10:10 PMMorrow JoDean. CPT USA SJA: Matthew kemkes; Ford, Arthur D. W01 USA JFHQ-SJAUS v. PFC BM UpdatesAppointment of Forensic Computer Expert (ManningB).pdf; 11-Aug-10-Approval Defense Expert Forensic LCDR Moulton (ManningB).pdt; 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).pdfHighAttached are the following five actions from the Appointment of Forensic Computer ExpertsApproval for Defense Computer HardwareAppointment of Expert Forensic Approved Facility and Storage of Classified InformationExcludable Delay MemorandumLcoa Moulton may be reached at Additionally, we sent unclassified discovery (BATES: 9368e4?942866) todaywhich includes MAJ Clausen's Adverse Action. (Tracking 7910 1960 9901 12726275)v/rAshden02924618 From: Fein, Ashden CPT USA SJASent: Frida Au ust 12 2011 7:21 AMTo:Cc: Ford, Arthur D. W01 USA Morrow JoDean,CPT USA SJA: Subject: RE: OGA InfoCCed on this email is (Litigation Division, OGC, DOD). Heis our POC for the DOD PSR. Thanks.Ashden02213029From: _@osd.miI>Sent: Friday, August I2, 201] 2:40 PMTo: Fein, Ashden CPT USA SJA FW: DTRA Response: Preservation and Production of Records Relating to PFC BradleySubject:E. Manning I)DTRA has responsive documents.Vr/02213028From: osd.mi|>Sent: Friday, August 12, 2011 3:49 PMTo: Fein, Ashden CPT USA SJA Subject: FW: Preservation and Production of RecordsRelating to PFC Bradley F. ManningNGA has responsive info I told them you would contact them. I will be out next week. but will have my blackberry.Vr/02213027From: Sent: Friday. August 12. 20ll 4:07 PMTo: Fcin, CPT USA SJA Subject: RE: Preservation and Production of to PFC Bradley F. ManningI sent you the I got so far from Navy. Nothing yet from Air Force (or Anny). You can go direct to as well.Vr/02935813From:SentTo:Cc:Sumem:hnponance:Fein, Ashden CPT USA SJASu ust 14, 2011 6:59 PMMorrow ill, JoDean, CPT USA Ford, Arthur D. WO1 USA JFHQ-SJADSS Files UpdateHighCould you please send an update on when you think we will be able to get acomplete copy of the DSS files surrounding wiki and Manning? This is afollow?up to the conversations we have had after we visited in late May.Thanks.Ashden02942854From:Sent:To:Cc:. Subject: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASunda Au ust 14, 2011 8:56 PM@Dmm?JnWFord, Arthur D. WO1 USA Morrow JoDean, CPT USA JFHQ-Overgaard, Angel M. CPT USA SJAClassification of Reponswe are still Figuring out the classification issue with the reports. I don'tthink we can hold them up because of this, but we do need them properlymarked. Let chat tomorrow morning.Ashden02922949From: Fein, Ashden CPT USA SJASent To:Cc: Morrow JoDean, CPT USA SJASubject: FW: Protective OrdersGents,I am not sure whether this was relayed down to you, but we offered to use ourSeepg/minute scanner and have our paralegals scan the entire file. we assumedthat you would not want the file out of your custody, so we suggested that itbe escorted by the FBI and we will do the labor on site. ?ave 3 Week-Ashden021 86860 Sent: on ay, ugust To: - DW 31A Cc: Morrow Ill, JoDean, CPT USA SJASubject: Re: Protective Orders I am on leave this week but have no issue with this as long as we get all of the contents back at the co of the copy mission.You tnost likely would want to Bates stamp for easy ID on does you would propose using. is on travel but should beable to coordinate this upon his return. !upen'isor_v !pccial Agent (SSA)FBIWashington Field Office601 4th Street. NWWashin 0 DC 20535OfficeCell 02216616From: Sent: Monday, August 15,2011 1:50 PMTo: Fein, Ashden USA SJA Ford, Arthur D. WOI USA SJCc: Matthew kemkes Paul Bouchardos ua ToomanSubject: Dr. MoultonAshden,who does Dr. Moulton need to coordinate with in order to obtain travel orders? I believe that MDW shouldbe providing the funding for his TDY. If this is not correct, can you point us in the right direction?Thanks.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angeli Street, #317Providence, RI 02906Toll Free: 1-800-588-4156Local: (508) 689-4616Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02936023From: Fein, Ashden CPT USA SJASent: Monday, August 15, 2011 1:53 PMTo: Ford, Arthur D. W01 USA SJACc: Matthew kemkes; ?Paul Bouchard'; ?Joshua Tooman'Subject: RE: Dr. MoultonDavid,we will Figure out the process immediately. Please have Dr. Moulton send ushis DTS POC so we can coordinate the exchanges.V/rAshden02922940From: Fein, Ashden CPT USA SJASent To:Cc: Morrow JoDean, CPT USA Overgaard. Angel M. CPT USAFord, Arthur D. W01 USA SJASubject: lrolechve gaersAttachments: File Request (ManningB).pdfThank you For your assistance. Attached is our Formal request to supplementour previous requests.we are coordinating directly with WFO to get the copy. we will let you knowwhen we have it all and then the next step. I think what might be helpful forall is that we will likely import the File into Concordance and then we willbe able to export to you for redactions, etc.Thanks again.v/rAshden02922528From:Sent:To:Cc:Subject:Fein, Ashden CPT USA SJAWednesday. August 17, 2011 9:09 AMUSA DCS G-2USA Morrow JoDean, CPT USA Ford, Arthur D. W01 USA SJAQuestion Are you available to chat on the phone about an issue? Thanks.v/r-Ashden02212178From: USA DCS G-2 Eusarmymil]Sent: Wednesday, August 17, 2011 9:45 AMTo: Fein, Ashden CPT USA SJAcc: Morrow Ill, JoDean, CPT USA Ford, Arthur D. W01 USA SJASubject: U) RE: QuestionSigned By: us.army.mi|Classification: UNCLASSIFIED01? course. My number? is 02924867From: Fein, Ashden CPT USA SJASent: 011 8:23 AMTo:Cc: Ford, Arthur D. W01 USA Morrow JoDean, CPT USA JFHQ-SJASubject: Next weekOur schedule is starting to Fill up and I want to lock in a day For caseFile (and sub?fi1e) scan. when are ya'l1 available? Thanks.Ashden02187082From: _@stateisov>Sent: Thursday, August 18, 201 1 2:55 PMTo: Fein, Ashden CPT USA SJA Cc: Morrow Ill, JoDean, CPT USA SJA Ford, Arthur D. W01 USA SM Subject: RE: DSS Files UpdateHey AshderLMy has given me the files requested on 2 1 unclassi?ed and for SIPR ?les. I could probably bring these over to you all:let me know. O: Special Agent. Diplomatic Security ServiceOffice of Professional Responsibility C:This c-mail is unclassi?ed based on de?nitions provided in E.O. 12958 02187550From: ?@dia.miI>Sent: Thursday, August I8, 2011 3:24 PMTo: Fein, Ashden CPT USA Cc: Morrow Ill, .|oDean, CPT USA SJA Ford, Arthur D. won USA JFHQSubject:1 have ?nally the last D5 of materials responsive to the PSR.I will package up the results. and they may be picked up at our of?ces atyour conv ni (ZD6 I4 Pentagon), Upon arm-'al. the courier should show ouradmin his/hcr councr badge for copying and sign a release sheet.Thank you!V/r.Aicncy 02188623Fro"-= ?@state.sov>Sent: Friday, August 19, 2011 2:47 PMTo: Fein, Ashden CPT USA SJA Cc: Ford, Arthur D. WOI USA SJASJAUSA SJASubject: Request for a Meetingil>; Morrow JoDean, CPT USA JFHQ-Overgaard, Angel M. PTAshden. I touched base with--). and he is available to meet with _vou. His Mondav and Fridayaflemoons are open next week: would cnher of those work?.SBUThis email is 02216539From:Sent:To:Cc:Subject:Friday, August 19, 2011 5:46 PMFein, Ashden USA SJA l>Ford, Arthur W()l USA SJA- Matthew kemkcs Jos ua'I'oomanA JFI SJAA I Morrow Jol)ean. CPT USA JFHQ-i . ow SJA i1> Re: Protective OrdersCOL CotTman's order does not seem to include disclosure to defense experts. I am assuming that this is an oversight. and that thedefense can share materials with its experts provided the protective orders are signed.DavidSent from my Verizon Wireless BlackBem' 02922867From: Fein, Ashden CPT USA SJASent: Fnday, August 19, 2011 6:52 PMTo: Cc: Ford, Anhur D. WO1 USA Matthewkemkes; Joshua Tooman; Overgaard, Angel M. CP - Morrow JoDean, CPT USA SJASubject: RE: Protective OrdersDavid,All those on the defense team, including expert consultants and witnesses areincluded under COL Coffman's order. It was intended and briefed to the COLCoffman that paragraph 2 sub includes "technical or expert services ortestimony? for the defense. we do understand the remainder of the sentencestates "in the prosecution of the accused? but we considered that statementmore broadly to include the prosecution and defense, since the "prosecution ofthe accused" cannot occur without the defense having access to theinformation.v/rAshden 02917809From: Fein, Ashden CPT USA SJASent: Monda Au ust22, 2011 6:41 AMTo:Cc: Morrow JoDean, CPT USA Ford, Arthur D. W01 USA JFHQ-SJASubject: Two IssuesI hope you had a good weekend. It appears my SIPR email finally wentthrough. when you have some time, could you please review the document Isent and determine whether there are any State classified equities.New question: If you have some time, could we discuss what actions DS tookin Iceland after the single cable was released?Thanks.Ashden 02187735 . -From: ?@dia.miI>Sent: Thursday, February 10, 2011 12:14 PMTo: Fein, Ashden CPT USA SJA Subject: IC badges approvedAttach: IC badges approvedpdfSee attachment. Unclas e?mail sent on another network.Assistant General CounselDefense Intelligence AgencyWashinitonl DC 20340 I 02901057 aFrom: Fein. Ashden CPT USA SJASent: Thutsda February 10. 2011 7:49 PMTo:Subject: IC BadgesGood evening. Earlier today you approved IC badge issuance to me and my co?counse1, CPT JoeMorrow, as per your email to we plan on coming by the DIAC tomorrowafternoon. Do we need to bring any paperwork For the badge issuance, or just show up? Thankyou.V/rAshden FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON)02886272 From Fein, Ashden CPT USA SJASent 1?r51l?MTm SAOGCCc: USA USA MIL USA USA SJASubha: Updau:Sir,In reference to the classification issue from a meeting you were at earlier today, I receivedan updated (as of 1920hrs) from my General Counsel POC at the OGA and they are still workingon obtaining the verbal classification of the specific information that was used in thedocuments. He will not receive an answer tonight, but is confident he will by tomorrowafternoon.As for the other issue with the certain documents, I am going to send you an email on SIPRexplaining the information you requested.Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MOW)02221 853Sent: Friday. February I I, 20| I 6:43 AMTo: Fein, Ashden (7PT USA SJ A Ce:Horrow Ill. loDean, PT USA JFHQ-SJA Matthew kemkes Subject: RE. Initial plan for evaluation schedule (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCat eats: NONEPT Fein:I have considered the request for CAPT Moore to attend the interview portions of the evaluation. and I am willing to accommodate therequest specifically to increase the of the process Ideally the interview should be observed through a one minor Ibelieve this arrangement is available at Quantieo. lfa SCIF can be chosen witha one way mirror that would be ideal. but is not anabsolute requirement (just a desirable feature).We request that CAPT Moore strictly adhere to observation of the inten iews only. and not meet with the accused during breaks orotherwise interact with him during the mtemews.MAJ Benesh will begin with testing, on Tues It?. Feb Wed I7 Feb will be the first intemew at Otiantico. If you could Contact the brigfor me to anange for use of appropriate space. as I am on TDY now. I would appreciate it. The SC IF ititeniew date will be agreedupon early next week.Thank you!Michael Sweda02221850 Sent: Friday. February I l, 20l 6 49 AMTo: Fein, Ashden CPT USA SJACc= Morrow Ill, JoDean, CPT USA IFHQ-SJA Matthew kcmkes.il.ilSubject: RE: Initial plan for evaluation schedule (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONESir: contclion lo the prior. Evaluations will still be scheduled the lam and bul the intcnicxv will be on the Imli (which is aand the lcsling will be on the 17th (a Michael Swcda02900754 From: Fein. Ashden CPT USA SJASent: Monday, Febtuaty 14, 2011 8:14 AMTo: 3Cc: H2coom armycourtmama ense.com'; orrow JoDean, CPT USA Matthew kemkes: 'Haber1and, John CPT MIL Cariile. Monica SFCSubject: RE: Initial plan for evaluation schedule (UNCLASSIFIED)Dr. Sweda,Good morning. we confirmed that Quantico Brig has an area available to your team to conductthe RCM 706 with the accused. I assume you are familiar with this location because it?s thesame place other pre-trial confinees participate in their RCM 786 board. However, the Brigdoes not have an area with a one-way mirror available.For the 16th and 17th, where do you envision the interview and testing to take place If at HRAMC, is it possible to schedule both during off-set hours? we are still working onthe location of the SCIF, but it will likely be in or around Ft Belvoir, VA. Later thisweek, we will need the proposed date for the meeting in the SCIF.we will work to get another CD to your team within the next 24-hours.Thank you.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDW) 02221 844From_ Sweda. Michael Dr CIV USA MEDCOM WRAMClL>Sent: Monday. February I4, 20] I 8.43 AMTo: Fein, Ashden CPT USA Cc: Benesh. Samantha MAJ MIL USA MEDCOM MAMC.loDcan, CPT USA SJAMatthew kcmkes Haberland, John CPT Mll. USA (?arlile__ Monica SFCMIL USA OTJAGSubject: RE. Initial plan for evaluation schedule (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONEWe will do Ill: portions of the evaluatioii at Quzintico. Thank ou for getting us 1] nc\\ CDWe plan on starting the emluiilion on the l(iI|i at (ISM), allou ing for it possible due to IrnlTic. which on occasion is dilTiculI.r.Michael Swcda. Pli D. ABPP (Foicmic)Boaid-Ccnifiod Fonensic Chief. Forensic ScmceDirector. Fonemic Fellou ship Walter Reed Ami) Medical Center "The United States themselves are essentially the greatest poem.Pasi and present and rutuie are not disioincd but joined." 02896404From: Fein, Ashden CPT USA SJASent: Monday, February 14, 2011 4:12 PMTo: Cc: Morrow JoDean, CPT USA Carlile, Monica L. SFC USA JFHQ-Matthew kemkes; 'Haber1and. John CPTMIL Subject: MRE 505(h)(1)Attachments: 11-Feb-14-Memo to Defense Counsel MRE 505(h)(1) (ManningB).pdfSigned By:David,I hope you had a relaxing weekend. Attached is the Prosecution's response toyour MRE 5es(n)(1) request in context of the RCM 706 board. Please review andlet us know your updated position and way forward. Thank you.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of washington (MDW) 02215538From: Sent: Tuesday, February 15, 2011 10:54 AMTo: Fein, Ashden CPT USA SJA Cc: Morrow JoDean, CPT USA SJACarlile, Monica L. SFC USA JFHQ-Matthew kemkesHaberland,JohnHall Cassius Mr FMMC (FTMYER)Subject: [Suspected RE: MRE Ashden,Thank you for providing me with the Government's response. Based upon our earlier discussion, I believethe CA can determine the "need to know" for the board. The only exception, as you have identified, wouldbe if any of the information is ORCON. In order to determine this and ensure that PFC Manning candiscuss anything he wants with the Board on 1 March, I would like to meet with him in a SCIF on 24 Feb.I could be in D.C. by Noon and be at a SCIF anytime after 1:00.Assuming none of the information he provides to me is ORCON, then the only issue we may have is the505(h)(1) requirement. Based upon the Government's response, there appears to be an easy workaround on this issue. If the government will concede that it is waiving any right to assert 505(h)(5)penalties for the defense's failure to comply with the requirements of 505(h)(1) and (4), then I don'tbelieve we will have an issue.Please let me know if the government can arrange for the 24 Feb meeting in a SCIF and if you agree towaive the 505(h)(5) penalty for nondisclosure. Feel free to call me if you have any questions.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02221842Sweda, Michael Dr CIV USA MEDCOM WRAMCm" Sent: Tuesday, February 15, 20] ll;S6 AMTo: Moore. Kevin czxpietx Ce: Benesh, Samantha MAJ MIL USA MEDCOM MAMCMorrow JoDean, CPT USA SJA Matthew kemke Haberland, John CPT MIL USA Carlile, Monica SFCMIL USA OTJ AG l-?cin, Ashden CPT USA SJA Subject: RE 706 Evaluation (UNCLASSIFIED)Clussilicatiori; UNCLASSIFIEDCaveats: NONECAPT Moore:I gave notice yesterda) that we are planning to begin tomomow at 0830. with possible allowance for a somewhat later start ifthcBoard members are delayed by tmf?c. Please adjust your accordingly.The instructions for the obsening health professional is that there is to be no interaction by the obsencr ith the evaluee during theevaluation process. meaning the entire day that we see him for each inten icw.Thank you.Michael Sweda. Ph D. ABPP (Forensic)Board-Ceni?ed Forensic Cluef. Forensic Ps_\vcholog\ ServiceDirector. Forensic Fellowship Walter Reed Ami)? Medical Ccmer "The United States themselves are essentially the greatest poem.and present and future are not disjoined butjoined."02219519From: AImanza.PauIn>Sent: Tuesday, February 15. 201 1 2:09 PMTo: Fein, Ashden USA sm Cc: Carlile, Monica L. SFC USA SJAMorrow Ill, JoDean, CPT USA1 SJAEgan. Michael civ smSubject: RE: Article (PFC Manningread on. I know that we're still on delay pending the completion of the sanity board. 1 do. howex er. have twoquestions. which have at bit more now based on the fact that I understand l'tn going to get activated on 1 April for six I. When do you anticipate the sanity board being completed?!and2. Govemment. how long do you estitnate the hearing will take. in temLs of the presentation of evidence??'l11ank you.LTC A |tn:m7:i029091 59From: Fein, Ashden CPT USA SJASent: Tuesday, February 15, 2011 11:01 PMTo: Ahnanza,PaulCc: Cariile. Monica L. SFC USA Matthew kemkes; Morrow JoDean, CPT USA- 'chael CIV Habenand. John CPT MIL USASubject: RE: Article 32 (PFC Manning)Sir,Good evening. Currently the sanity board has a suspense of 3 March 2911. Assuming the boardadequately completes their findings by the suspense, then the United States expects theArticle 32 to be ready to start by 15 March 2611, absent any additional delays. Once thehearing starts, the United States estimates a total of three days to complete.Is your 1 April activation keeping you in the local area or is this a deployment?V/rCPT FeinAshden FeinCPT, JAChief, Military Justice -U.S. Army Military District of Washington (MON) 02896402From: Fein, Ashden CPT USA SJASent: Tuesday. February 15, 2011 11:08 PMTo: Cc: Morrow JoDean. CPT USA Carlile. Monica L. SFC USA JFHQ-Matthew kemkes; Haberiand,John MIL USASubject: RE: MRE 505(h)(1)Attachments: 11?Feb-15-Excludable Delay Memorandum (ManningB).pdfDavid,we are still working with INSCOM to secure the facility and I hope to have an answertomorrow. we will immediately start looking at your proposal for the 56S(h)(1) issue and Iwill email to setup a phone call. Prior to that phone call, I offer one proposition which isthat the security experts conducted the PCR and came back without ORCON information.Therefore we should operate from this point forward that none of the information is ORCON,unless there is evidence to the contrary. Attached is the convening authority's action on excludable delay.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN)02219516Subject:Almanza? Paul Wednesday, February 16, 2011 8:07 AMFein, Ashden CPT USA SJA Carlile, Monica L. SFC USA SJAMorrow JoDean, CPT USAEgan, Michael CIV Matthew kemkesSJASJA Re: Article 32 (PFC Manning)Thanks. CPT Fein. Assuming are met, there should be no problem.The activation will be in the local area.LTC AlmanzaOriginal Message From: Fcin. USA SJA To: Almama, PaulCc: Carlile, Monica L. SFC USA SJA Sent: Tue Feb [5 23:01:00 20llMatthew kemkesMon'ow JoDean. CPT USA SJA Subject: RE: Article 32 (PFC Manning)Sir.Good evening. the sanity board has a suspense of 3 March 201 1.Assuming the board adequately completes their ?ndings by the suspense. thenthe United States expects the Article 32 to be ready to start by 15 March2011. absent any additional delays. Once the hearing starts. the UnitedStates estimates a total of three days to complete.Is your 1 April activation keeping you in the local area or is this adeployment?v/rCPT FeinFeinCPT, JAChief. Military Justice U.S. Amiy Military District of Washington (MDW)From: Alman7;L Paul Sent: Tuesday, Febmary . 2 2:09 To: Fcin. USA SJACc: Carlile. Monica L. SFC USA Egan. Michael CIV SJA Haberiand. John02219516Matthew kemkes; Morrow Ill, JoDean. CPTUSA l; Egan Michael CIVSJ ASubject: RE: Anicle 32 (PFC Manningwas read on. I know that we're still on delay pending thecompletion of the sanity board. I do, however. have two questions, whichhave a bit more urgency now based on the fact that I understand I'm going toget activated on I April for six months:1. When do you anticipate the sanity board being completed?and2. Govemment, how long do you estimate the hearing will take, in temts ofthe govemment's presentation of evidence?Thank you.LTC Almanza?--Original Message--?From: Fein, Ashden CPT USA SJASent: Tuesday. January 25. 2011 ll:38 PMTo: Almanza. PaulCc; Carlile, Monica L. SFC USA Matthew Monow JoDcan. CPTusA sumSubject: RE: Article 32 (PFC anning)Thank you sir. MTF.Ashden FeinCPT. AChief, Military JusticeU.S. Amry Military District of Washington (MDW)?-??Original MessageFrom: Almanza. PaulSent: Tuesday, January 25. To: Fein, Ashden CPT USA SJACc: Carlile, Monica L. SFC USA IF Matthew kemkes; Morrow ioDcan, CPTUSA SJARFSubject: Re: Article 32 (PFC nmng)CPT Fein - Thank you for keeping me posted.For the read-on, I will be on travel for the lnterseivice Military Judge'sSeminar next week. I may be available, however, either early Monday or lateFriday next week. Alternatively, I'd be available the following week.02219516LTC AlmanzaOriginal Message From: Fein. Ashden CPT USA SJA0: manza, auCC: Carlilc. Monica L. SFC USA SJA ; Matthew kemkesMonow JoDean, CPT USA SJA 2 Subject: Article 32 (PFC Manning)LTC Alman7a,Good evening. The purpose of this email is to give you an update on theArticle 32 for PFC Manning. Although the RCM 706 board is still delayed. weexpect the clearance issue to be resolved shortly. With the assistance ofthe Amty G2, we are coordinating to have all foreseeable participants in theoverall court-martial process receive clearances and subsequentread-on's for the required compartments. Your clearance is cumently validand you just need to be read-on.Read-on?s will likely occur in City. I plan to give some lead timefor this and we will likely plan early morning or late in the day toaccommodate around work schedules. Assuming no critical issues in theremaining participants I anticipate the read-ons to occur nextweek and the RCM 706 to start again the following week.If you have any questions. please send them to the entire email disuibution.Also. my office added SF Monica Carlilc to the team and she is currently thededicated paralegal to all issues for this case. including providing you theneeded support as the IO. SFC Carlilc is CCed on this entail.Thank you.CPT FeinAshden FeinCPT, JAChief. Military JusticeU.S. Army Military District of Washington (MDW) 02215535From: Sent: Wednesday, February 16,2011 1:07 PMTo: Fein, Ashden CPT USA SJA Cc: Morrow JoDean, CPT USA SJACarlile, Monica L. SFC USA Matthew kemkesHaber|and,JohnSubject: Discovery RequestAttach: Discovery Request - 16 Feb 1 l.pdfAshden,Please see the attached supplemental discovery request.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896mi|fn.mNotice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02215529From: Sent: Thursday, Febmaiy 17,2011 5:05 PMAlmanzaraul Cc: Carlile, Monica L. SFC USA SJAMatthew kemkesMorrow Ill, JoDean, CPT USA Egan, Michael CIV SJAFein, Ashden CPT USA SJ ASubject: Article 32 (PFC Manning)Attach: Article 32 Compel Discovery .pdfi LTC Almanza,Please see the attached motion to compel discovery for the Article 32.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02215513From: Sent: Thursday, February 17To: Paul Almanza Cc: Carlile, Monica L. SFC USA SJ A il>; Matthew kemkesMorrow JoDean, CPT USA IF Egan, Michael CIV Subject: Article 32 (PFC Manning)Attach: Attachment A.pdf; Attachment B.pdf; Attachment Cpdf; Attachment D.pdf; AttachmentE.pdf; Attachment F.pdf LTC Almanza,Here are the attachments to the defense motion.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896rm 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02219515From: Anmamvaun ?mSent: Friday, February I8, 20] I I l:4l AMTo: Cc: Carlile, Monica L. SFC USA SJA Matthew kemkesMorrow JoDean, CPT USA Egan, Michael CIV Subject: RE: Article 32 (PFC Manning)Thank you, Mr. Coombs.Government, any response? If so, please submit by COB on 25 Feb 11.LTC AlmanzaI I I 5Sent: Thursday, February 17, 2011 5:05 PMTo: Almanza. Paul LTC Almanza,Please see the attached motion to compel discovery for the Article 32.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02215508From: Sent: Friday, February 18, 2011 4:31 PMTo: Fein, Ashden CPT USA SJA Cc: Morrow JoDean_ CPT USA SJ ACarlile. Monica L. SFC USA JFIIQ-SJA Matthew kemkesHaberland,JohnCPT MIL USASubject: Expen RequestAttach: st Expen Request.pdfAshden,Please see the attached expert request.Best,DavidDavid E. Coombs, Esq.Law Of?ce of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02885132From: Fein, Ashden CPT USA SJASent: 7:29 PMTo: SF-I Of?ce of the Staff Judge Advocate/OSJASubject: v.Sir. One more follow-up question, do you know how much longer until we get the UNCLASversion of the 15-6? It has been a while since I made the request. Thanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN) 0221 5507From: Sent: Monday, February 21, 201 1 8:50 PMTo: Fein, Ashden CPT USA SJA Cc: Morrow JoDean, CPT USA SJ ACarlile, Monica L. SFC USA JFHQ-SJA Matthew kemkesHaberland,JohnSubject: RE: Discovery RequestAshden,Can you let me know when the government will be able to coordinate a SCIF for me to meet with PFCManning? I need at least eight days notice (ideally 14 days) so that I can purchase a reasonably pricedplane ticket.Also, when do you want to speak about the MRE 50S(h)(1) disclosure issue? Since it is the government'sposition that disclosure is not required at the 706, it should not be a problem for you to waive any right toassert the MRE penalties for nondisclosure. Your thoughts?Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 324-9896Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02903817From: Fein, Ashden CPT USA SJASent: Monday, February 21. 2011 9:00 PMTo: Cc: Morrow Ill, JoDean. CPT USA Carlile. Monica L. SFC USA JFHQ-Matthew kemkes; Haber1and,John CPTMIL USASubject: RE: Discovery RequestDavid,Your MRE 505 proposal seems fair, but we are trying to determine what precedence we aresetting with such a waiver and the potential long-term impact. we will have an answer at thebeginning of this week.As for the SCIF, we have the FIU already lined-up, but based on our prior discussion, we arein the process of acquiring a non-law enforcement facility. we will be using a Facilityprovided by US Army INSCOM and they are currently staffing all the requirements so that thereis minimal to no administrative hurdles for when you, your team, the accused, and the 796board arrives at the Facility.I will contact INSCOM tomorrow to lock in a date, so you can plan your ticket.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of washington (MDW) 02886278From: Fein, Ashden CPT USA SJASent: Tuesda February 22, 2011 12:33 PMTo:cc: hm usA usAcIoc: low USA USACIDC:Morrow JoDean, CPT USA JFHQ-NCRIMDW Canile, Monica SFC MIL USA?Mr CIV USASubject: Updatehnpo?ance: Below is my updated lists of issues that ya?1l should be tracking. I elaborated next to someof them. .1. Traceroute path for data sets? Asked for this many months ago so that one of youcan get up and explain how the data was pulled and show a map of how the information moved.2. DISA request for all info on SIPR. Don?t know if we received all the info and itsincorporated into the dB3. interview. In the process of scheduling. we owe you whether we go or hecomes here. You owe me information to write a letter to his boss.4. interview (24 Feb 11 at Charlottesville, VA). Scheduled5. interview (24 Feb 11 at Charlottesville, VA) Scheduled6. training from Gordon including how he logged on and the IP helogged on from (Bettencourt - 3 Feb 11) (waiting on a copy of the information withattestation certificate)7. SIPR laptop loaner - was building a SIPR loaner for us with all the cooltools.8. Any leads from ?Mail.be? in Belgium?9. DOIM User agreements from Ft Drum. we discussed getting the actual ones when wewere up there.10. Intelligence Analyst Cheat sheet. Find it and collect into evidence, unless we alreadyhave on his SIPR box.11. Validate Forensic reports (references, etc.). THE MOST IMPORTANT. Your team goingthrough '5 reports and ensuring everything is marked properly (classification) and thereferences are accurate.12. ?Google? sipr logs. Do these exist?13. DCGS-A server logs (at hammer and at VBC). Collect both sets of logs.0288627814. CI Computer test in Fall 2898 satler). - mentioned they both took ?a test? inthe Fall. who did they test with and where is the test?15. Brig recordings. we need a copy of all the brig recordings.16. OGA Documents emailed to us. You spoke with Joe this morning about this.17. Book analysis of ISBN 978-8-9799587-1-7. I sent an email earlier today about this.18. PRIORITY: Full list of all classified evidence (added to the digital evidence list).we spoke on Friday about this.Thanks!AshdenAshden Feincor, JAChief, Military JusticeU.S. Army Military District of Washington (MDN)02907632From: Fein, Ashden cm USA JFHQ-NCRIMDW SJASent: Thursda February 24. 2011 7:35 AMTo: ?dodiismirSubject: ChatSir. Are you available to chat today. Thx.Ashden FeinCPT, JA02187733Fro-I-= ?@dodiis%miI>Sent: Thursday, Febmary 24, 2011 9:07 AM. To: Fein, Ashden CPT USA SJA 1 Subject: RE: ChatSure. What time?? 02187730From ?@dodiis?miI>Sent: Thursday, February 24, 201 1 11:25 AMTo: ein, Ashden CPT USA SJ Subject: RE: Chat"Easy," replied IRTF to your request for their team will research, and we'll pushsomething to you by the end of the day.021 87726From: ?@dodns.mu>Sent: Thursday, February 24, 201 1 3:48 PMTo: Fein, Ashden cm USA SJA Subject: FW: ChatAshden, FY SA. I don't have it yet. But they're working on it. It may not be ready until ?rsl thing Friday.02212580From: D08 6-2 _@us.army.miI]Sent: Thursday, February 24, 2011 4:30 PMTo: SJAcc: omSubject: Af?davitsSigned By: Classification: OFFICIAL USE ONLYAshden- GTMO was expecting to have their affidavit signed yesterdayafternoon. I passed along your mailing addresswith a request that they mail the original directly to you. CENTCOM wasalso to send theirs directly.Please let me know when you have them.RegardsClassification: OFFICIAL USE ONLY02912022From: Fein, Ashden CPT USA SJASent: Thursda Febmary 24. 2011 4:57 PMTo: irSubject: Re: (U) AffidavitsSir. Thank you. Hopefully they scan them first and then track them. Vr ashdenAshden FeinCPT, JA02187723 Sent: Friday, February 25, 2011 7:0l AMTo: Fein, Ashden CPT USA SJA Cc= n@ .Subject: RE: Chatcheck your JWICS this morning. I just sent you the ?le. Call if there are problems or questions-02909163From: Fein, Ashden CPT USA SJAsent: Friday, February 25. 2011 3:01 PMTo: Almanza. Paul; Cc: Canile, Monica L. SFC USA JFHQ-NCFUMDW Matthew kemkes; Morrow Ill, JoDean,CPT USA SJA: Egan, Michael CIV JFHQ-NCRIMDW Haberland, John CPT MILUSASubject: RE: Article 32 (PFC Manning)Attachments: 11-Feb-25-Govemment Response to Defense Reques1 to compel Discovery for An 32(ManningB).pdfSir,Please see attached response.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDW) 02896409From: Fein, Ashden CPT USA SJASent: Friday, February 25. 2011 3:31 PMTo: Cc: Morrow Ill, JoDean, CPT USA JFHQ-NCRIMDW Carlile. Monica L. SFC USA JFHQ-Matthew kemkes; Haber|and.John CPTSubject: RE: MRE 505(h)(1)David,Although we do not consider this a waiver because we do not believe MRE 5e5(h) applies inthis situation, we do acknowledge that by speaking with the RCM 706 board, the accused willnot be in violation of MRE 505(h); thus, the penalties under MRE would not betriggered in this situation.Based upon your request to not conduct your meetings with your client or the RCM 766interview at the FIU SCIF, we have received formal authorization to use a U.S. Army INSCOMfacility. As of today, we are scheduling a recon of.the facility for early next week andwill solidify the schedule and logistics for using this facility by the middle of next week.Please send me your schedule for the next three weeks (specifically when you will beavailable to be down in DC), so that we can determine the soonest date to schedule yourmeeting and then the RCM 766 board's interview.we are continuing to work on your multiple discovery requests. In addition, we expect tohave the additional charge sheet presented to the command in the near future for thecommander to make a determination whether to prefer additional charges or not. I do plan ontalking to you prior to the additional charge sheet being served on your client, if one is_warranted.Have a good weekend.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDH) 02215500From: Sent: Friday, February 25, 2011 9:23 PMTo: Fein, Ashden CPT USA SJA Cc: Morrow IH, oDean, CPT USA SJACarlile, Monica L. SFC USA JFHQ-Matthew kemkesHaberland,JohnCPT MIL USA Subject: [Suspected RE: MRE 505(h)(1)Ashden,Thank you for the update on the charge sheet and the clarification on the 505(h)(1) issue. Given thegovernment's position, unless the information turns out to be ORCON, the defense will not provide any505(h)(1) noti?cation prior to our client speaking with the R.C.M. 706 board.The earliest that I am available to come to D.C. would be the 7th of March. I can meet with PFC Manninganytime during that week. I anticipate needing a full day in a SCIF in order to complete our discussions.If that week does not work for the government, I can come anytime from the 22nd through the 25th ofMarch. Once you can confirm an available date, please let me know and I will make the necessary travelarrangements.With regards to the discovery request, I understand not being able to provide information until after youhave the approval to do so from the required OCA. However, once you have this approval, I do not seeany reason to delay discovery to the defense. Every member of the defense team has the requisitesecurity clearance. We are able to store classified information either at MAJ Kemkes' of?ce or with ourdefense security experts. By providing timely discovery, we can adequately prepare for trial and avoidany need for a delay.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02215497From: Sent: Friday, February 25, 2011 9:41 PMTo: Paul Almanza Cc: Carlile, Monica L. SFC USA SJA Matthew kemkesMorrow I11, JoDean, CPT USA Egan, Michael CIV l; Haber1and,John CPT MIL USAFein, Ashden CPT USA SJASubject: [Suspected RE: Article 32 (PFC Manning)LTC Almanza,The defense does not believe its discovery request is either improper or premature. The government hasrepresented that it will be prepared to proceed with the Article 32 on 15 March 2011. Given this fact, thedefense has requested necessary discovery in order to adequately prepare for the hearing.If the government's position is that it either lacks the necessary approval to provide discovery from therequired OCA or that it has been instructed to assert a privilege under M.R.E. 505(c), then the lack ofdiscovery is understandable. However, if this is not the case, then the government should provide therequested discovery. Every member of the defense team has the requisite security clearance. We are ableto appropriately store any classified information. By providing timely discovery, we can avoid any necessityfor a delay in the Article 32 hearing.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02886274From: Fein, Ashden CPT USA SJASent To:Cc: Morrow JoDean, CPT USA SJASubject: update9I hope your weekend is going well. Is it possible for us to meet next week to discuss thenext step of receiving OCA approval to use the processed information in Trial? Thanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington 02911630From: Fein, Ashden CPT USA SJASent: Saturday. February 26, 2011 4:47 PMTo: Paul AlmanzaCc: . Carlile, Monica L. SFC USA JFHQ-NCRIMDW Matthew kemkes; Morrow JoDean,CPT USA JFHQ-NCRIMDW Egan. Michael JFHQ-NCRIMDW HaberIand,John CPT USASubject: RE: [Suspected RE: Article 32 (PFC Manning)Sir,we agree with the defense-if the prosecution receives authorization to release classifieddocuments to the defense, then that information will be immediately given to the defense.The United States has not received any approvals to release classified information to thedefense, therefore it has not occurred. Although these requests have been working throughthe USG, they are not approved yet. we are aggressively pursuing each OriginalClassification Authority (OCA) for their approval and whether we must assert the MRE 505privilege over the information.Below clarifies my previous email that the "United States expects the Article 32 to be readyto start by 15 March 2011, absent any additional delays.? Currently many differentadministrative and substantive processes are occurring, including the defense's requested RCM706 board, OCA reviews, etc. Each of these play a factor in the ultimate re-start date forthe Article 32. Prior to the Article 32 proceeding, the RCM 796 board must be completed.Prior to its completion, the defense counsel requested to meet with his client in a SCIF,which was different than the SCIF previously designated by the convening authority. All ofthese factors, along with the OCA reviews, contribute to the re-start date of the Article 32.Notwithstanding all the administrative and substantive processes referenced above, the UnitedStates recognizes its duty to produce witnesses and evidence for use at an Article 32investigation in order to ensure the investigation is thorough and impartial under RCM 405.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MUN) 02885128From: Fein, Ashden CPT USA SJASent: Sunda . Febma 27. 2011 7:24 PMTo: USF-I Of?oe of the Staff Judge Advocate/OSJASubject: RE: US v. PFC BMunponance: l?ghSir. Thanks. My SJA directed me to get an estimated time. I don't know if this will help,but I originally requested the information back before the New Year and it has been bouncedbetween different personnel.All we need is the original 15-6 re-scanned on NIPR (High resolution) and sent to us. Thereis a two-page document that is classified, which is MG Garrett's approval memo. The laststep is for the Security folks review that memo and determine whether it is actuallyclassified. If so, then there will be an additional step, to follow. If not, then pleasere-send that memo on NIPR.Thanks.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MON)302911601From: Fein, Ashden CPT USA SJASent: Sunday. February 27. 2011 9:32 PMTo: Cc: Morrow JoDean, CPT USA Canile. Monica L. SFC USA JFHQ-NCRIMDW Matthew kemkes; Haberland,John CPTSubject: RE: [Suspected RE: MRE 505(h)(1)David. I assume my response to the Art 32 I0 is sufficient to answer your last point. BLUF:we agree. Once we get the approvals, you will receive or have access to the information. Itis our intent to get you as much information as soon as possible, so long as it does notviolate security rules or further harm national security.we will meet with INSCOM early this week to ensure we have the proper facility and itprovides your client with the appropriate amount of protection, both for his physicalsecurity and also shield him from the general public to minimize any potential embarrassment.we will work to get your meeting the week of 7 Mar so we can keep the RCM 766 moving.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN)02910527From:SentTo:Cc:Subject:hnponance:Fein, Ashden CPT USA SJAMonda Febma 28. 2011 7:20 AM?ew USA CIV us USA USACIDCCIV IV Morrow m, JoDean, USACarlile, Monica L. SFC USA SJAa?bi f?ghGents. One more to add to the list of priorities, in order:1. Complete list of all classified evidence or enclosures to the CID report (includingwhat OCAs we know they belong to).3. Chat logs classifications?4. Verifying the forensic reports are accurate with their reference to enclosures, etc.Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Nashington (Mow)0221 5492From: Sent: Monday, February 28, 2011 10:08 AMTo: vaunaimanmmCc: Carlile, Monica L. SFC USA SJAMatthew kemkesMorrow Ill, JoDean, CPT USA Egan, Michael CIV I-Iaberland,John CPT MIL USAFein. Ashden CPT USA SJASubject: [Suspected RE: Article 32 (PFC Manning)LTC Almanza,The defense understands that without OCA approval, the government is limited in what it can provide indiscovery. The defense, however, is unclear how this determination would impact other discoveryrequested such as the following:a) The T-SCIF accreditation packet for FOB Hammer;b) CCIU, USACID Investigative File and any subsequent case file detailing CID's investigation (wecurrently only have the ?le report from CID dated 23 June 2010);c) A complete copy of any emails or memorandums relating to the preferral of charges in this case;d) The complete IM chat logs provided by Adrian Lamo;e) Names and contact information for all government investigators who have participated or who arepresently participating in the investigation of this case;f) LTG Caslen's report submitted to the Secretary of Defense;9) Recorded audio or video footage of PFC Manning in Kuwait and Quantico;h) Other government investigations as referenced by the Secretary of Defense regarding jointinvestigations by the military, the Department of Justice, the Department of State, the Central IntelligenceAgency, and the Federal Bureau of Investigation;i) Any and all documentation related to President Barack Obama's order for a government wide-review ofhow agencies safeguard sensitive information;j) Any and all documents or observation notes by the Quantico con?nement facility relating to PFCManning;k) The results of the 15-6 investigation into the government's improper release of classi?ed informationto the defense and whether the government looked into the referenced areas of additional possiblespillage;I) Any inquiry and testimony taken by the House of Representative oversight committee led byRepresentative Darrell Issa; ANDm) The names of soldiers who have been ?agged related to this case, the nature for why they were?agged, who imposed the ?ag, and any other derogatory information in support of the flag.Obtaining the above discovery in a timely manner will aid in to overall processing of this case. It will alsoassist the defense in identifying relevant witnesses for the Article 32 hearing.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th Floor Fall River, MA 02720Of?ce: 1-800-588-4156Fax: (508) 689-9282 0221 5492mi|fn.mNotice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 021 84288From:SentTo:Cc:Subject:Signed By:Follow Up Flag:Flag Status:IV USA USACIDC Monday,'February 28, 2011 11:28 AMFein, Ashden CPT USA Morrow Ill, JoDean, CPT USA JFHQ-SJA ?:Iv IV Carlile, Monica L. sr=c USACIV us USA USACIDCRE: alibi iuNcLAssu=Ius.anny.miI Follow upCompletedClassification: UNCLASSIFIEDCaveats: FOUOAshden,Status on your need to talk.1. Complete list of all classified evidence or enclosures to the CIDreport (including what OCAs we know they belong to).I should have this done tomorrow morning.021 84288 3. Chat logs classifications?we have a proposed COA and would like to discuss at your convenience.Sooner is better than later.4. Verifying the Forensic reports are accurate with their reference toenclosures, etc.we also need to discuss this, as I am not sure which version you reviewed.Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (Mow)Classification: UNCLASSIFIEDCaveats: FOUO 02219505Nmw-a~ 980' Sent: Monday, February 28, 201 I 6:05 PMTo: Fein, Ashden CPT USA SJACc: Carlile, Monica L. SFC USA SIA Matthew kemkesMorrow .loDean, CPT USA Egan. Michael CIV Haberland,John CPT MIL USASubject: RE: Article 32 (PFC Manning)Mr. Coombs, CPT Fein -As CPT Fein has noted, I have not been provided with any evidence for consideration in this case. Other than proceduraldocuments such as my appointment memorandum and various emails since last August, the only documents I have sofar received are a charge sheet and PFC Manning's ERB. I received those documents on 4 August 2010.Until such time as I receive additional information from the Government, lwill be unable to make a preliminarydetermination of what witnesses will be produced at the hearing and what other evidence will be considered. Once Imake that determination and provide notice to the defense of the witnesses and evidence that I intend to consider via amemorandum notifying the defense oi the hearing, the defense will have the ability to request the production of otherwitnesses or evidence at the hearing and we will go from there.In one of my recent emails I informed you that was anticipating being activated on or about 1 April. That date nowappears to be on or about 25 April, although I don't yet have written orders. Additionally, I will be unavailable the weekof 18 April.Thank you.LTC Almanza02228319From: A of the Staff Judge Advocate/OSJA|raq.centcom.m|l>Sent: Wednesda March 2, 201] 12:30 PMUSA usr-1 omce of the Staff Judge @iraq.centcom.mil>To:Cc: Fein, Ashden CPT USA SJA Subject: US v. PFC BM please mention this to-tomorrow if you see him at branch chiefs.lhaks!02907823From: Fein, Ashden CPT USA SJASent: Wednesday, March 02. 2011 3:57 PMTo: Cc: Carlile, Monica L. SFC USA Matthew kemkes; Morrow Ill. JoDean,CPT USA nilSubject: Charge SheetAttachments: Additional Charge Sheet REDACTED LOW RES (ManningB).pdfhnponance: David. Attached is the charge sheet.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MOW) 11 0289181111IFrom: Fein, Ashden CPT USA SJASent: Wednesday, March 02, 2011 11:19 PMTo: Sweda, Michael Dr CIV USA MEDCOM WRAMCCc: Benesh. Samantha MAJ MIL USA MEDCOM Morrow Ill, JoDean, CPT USA Matthew kemkes Haberland. John on MIL Carlile. Monica SFC JA emp ilI.Mar|a LTC MIL USA MEDCOM BAMCSubject: RCM 706-Additional Charges (US v. PFC BM)unponance: Dr. Sweda,Also, could you please provide an estimated timeline For when the RCM 796board will be complete. The convening authority's order, dated 3 Feb 11,gave a suspense of Four weeks to complete the board. I assume because youhave not met with the accused, that you will need an extension of time. Asper the convening authority's order, please provide an extension request.v/r1Thank you.CPT Fein11Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (Mow) 0221 5474From: Sent: Thursday, March 3, 201 1 8:33 AMTo: Fein, Ashden CPT USA SJA Cc: Carlile, Monica L. SFC USA AMatthew Morrow Ill, JoDean, CPT USA ;Haberland,John MIL USASubject: Expert RequestAshden,Do you have an update for me on the latest defense expert request? I would like to have the defenseas part of the team before the R.C.M. 706 board resumes its work.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 689-9282in rm i 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02228315 From: USF-I Office of the Staff Judge iraq.centcom.mi|]Sent: Thursda March 03 2011 9:11 AMTo: USA USF-I Of?ce of the Staff Judge Advocate/OSJAcc: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASubject: RE: US v. PFC BM (UNCLASSIFIED)Signed By: ?us.arn1y.milClassification: UNCLASSIFIEDCaveats: NONEAshden,Memo is in the process of declassification, J2 has concurred andAd?Law is staffing for cos final determination. Next Cos meeting istomorrow I believe.From: Toman, Joshua Maj USA USF-I Office of the Staff Judge Advocate/OSJASent: Wednesday, March 92, 2811 8:30 PMTo: Smith, Curtis CPT USA USF-I Office of the Staff JudgeCc: Fein, Ashden CPT USA SJASubject: Fw: US v. PFC BMImportance: HighCurtis,please mention this to COL Berg tomorrow if you see him at branch chiefs.thaks!02221838From:Sent:To:Cc:Subject:Sweda, Michael Dr CIV USA MEDCOM WRAMCThursday, March 3. 201 1 2:07 PMFein. Ashden USA sm Benesh, Samantha MAJ MIL USA MEDCOM MAMC Morrow Ill,0 can, - SJA Matthew kemkcsHaberland, John PT MIL USA Carlile, Monica FCHemphill, Marla LTC MIL USAMIL USA OTJAG MEDCOM BAMC Moore, Kevin D. CAPT4 RE. RCM 706-Additional Charges (US v. PFC BM) Classi?cation: UNCLASSIFIEDCaveats: NONESir and ALCON:We have a date of I March fortlic imcnicu at the SC IF. beginning at 0830. Tell us if this will work?r.Michael Swcda. Pl: D.. ABPP (Forensic)Board-Ccni?cd Forensic (Thief. Foncnsic Sen-ice Director. Forensic P$'cholog\ Fellow ship Walter Reed Anny Medical Center"The United Slalcs themselves are essentially ihe gncalesl poem.Past and present and future arc not disjoinod buljoincd."From: Sent: Thursday, March 3, 201 I 8:55 PMTo: Fein, Ashden CPT USA SJA Cc: Carlile, Monica L. SFC USA SJA Matthew kemkesMorrow JoDean, CPT USA Subject: [Suspected SCIFAshden,Any update on when I will be able to use a SCIF to speak with PFC Manning? Also, once we identify thedate, I would like to have PFC Manning pulled out the day before to meet with me at MAJ Kemkes' office.Finally, I wanted to alert you to a couple of issues with the confinement facility. First, they are requiringManning to strip naked at the end of the day and then to stand at attention naked during the 0500 DBSreview. I can't imagine the reason for this to happen. Second, the facility has been using a wirelessheadset for his telephone conversations. Besides being insecure, the quality of the connection iscompromised.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 689-9282wmw4Mmc 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02891717From: Fein. Ashden CPT USA SJASent: Thursday, March 03, 2011 10:13 PMTo: Sweda, Michael Dr CIV USA MEDCOM WRAMCCc: Benesh, Samantha MAJ MIL USA MEDCOM Morrow JoDean. CPT USA Matthew kemkes Haberiand, John CPT MIL Cartile. Monica SFC MIL USA Hemphill, Maria LTC MIL USA MEDCOM Moore. Kevin D. CAPTSubject: RE: RCM 706-Additional Charges (US v. PFC BM) (UNCLASSIFIED)Dr. Sweda. we conducted the leader recon of the SCIF and Found the proper conference andbuilding just north of Ft. Belvoir, in Alexandria. will you and the board be able to conductthe interview on a Saturday? Although we do have access to the building during the week, wewould like to minimize PFC Manning's exposure to the public during his transportation andultimately his travel throughout a USG contracted building during the process. we would alsolike to use this building on a Saturday, so that the board and PFC Manning are more relaxedgoing to an area that will be pedestrian-free.Please let me know whether this is possible. Thank you.v/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of washington (MUN) 02889691From: Fein, Ashden CPT USA SJASent: Thursday, March 03, 2011 10:23 PMTo: Cc: Canile, Monica L. SFC USA Matthew kemkes; Morrow JoDean,CPT Subject: David. Below are answers or comments to your emails today.1. we completed the leader recon of the SCIF location and secured an ideal location. ?It'sideal because it's in a building that will provide PFC Manning with very little exposure tothird parties and is large enough to accommodate the defense team and the RCM 706 board. Thelocation is just north of Ft. Belvoir, in Alexandria. we are planning on using Saturdays forthe SCIF access to minimize the 3d party pedestrian traffic, because this facility is sharedby the USG although belonging to the US Army INSCOM. The latrines are nearby and the accessprocedures will be easier for you and your team, compared to other locations.2. we will schedule PFC Manning to be at MAJ Kemkes office the Friday before the SCIFmeeting. we expect to have the Saturday schedule tomorrow and will immediately contact you tofigure out when you will be available to come down.3. Please send us who, from the defense team, will be participating in the SCIF meetingwith PFC Manning.4. we are working on your expert request. The convening authority has been TDY and onleave, although we are in contact with him. we are working with the medical folks todetermine the availability of an expert, so that we can present the request to the conveningauthority. we expect to have an answer by the middle of next week, which should be wellbefore the RCM 786 board resumes its work- based on the SCIF arrangements.5. we will work to determine the reason for PFC Manning being required to ?strip naked atthe end of the day?.6. we will work to determine what the situation is concerning the wireless headsettelephone. Is this only when you and the defense team calls, for all his calls?AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of washington (MDH) 0221 5469From: Sent: Thursday, March 3, 2011 10:59 PMTo: Fein, Ashden USA sm Cc: Benesh,Samantha MAJ MIL USA MEDCOM MAMCMorrow JoDean, CPT USA Matthew kemkcsIIaberland,JohnCPT MIL USA Carli e,Mon1ca SFC MIL USA OTJAGHemphi|l,Marla LTC MIL USA MEDCOM BAMCMoone,Kevin D. CAPTSweda,Michael Dr CIV USA MEDCOMSubject: [Suspected RE: RCM 706-Additional Charges (US v. PFC BM)(UNCLASSIFIED)Ashden,I will need to coordinate with Mr. Ganiel and Mr. Hall, but I would prefer to have both of them at the SCIFmeeting. If scheduling conflicts prevent this from happening in a timely fashion, I will go with just one ofmy security experts. which Saturday are you looking at having access at the With regards to the wireless headset, I do not know if it is used for all of his calls. He has used it duringmy conversations with him. The first time was yesterday.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Of?ce: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02188686Fr?m= ?@statc-sov>Sent: Friday, March 4, 2011 12:56 PMTo: Fein, Ashden CPT USA SJA MorrowIll, loDcan, CPT USA SJA Cc: _43statc.sov> .Subject: OCA MemosAshden and Joe,Thanks for the meetini iesterdail and for takini the time to answer our iuestions. You can address the memos to my boss.-We had just a few requests for tweaking the language in the samples and/or adding language, if possible. They?re prirnarily aimed atclarifying some of the protections we discussed yesterday. Happy to discuss these more by phone, and let me know if any would beproblematic.Memo re: Request for Consent to Disclose Classi?ed Info to DefensePurpose can you add in two points of assurance here, so that our folks see them upfront? First would be a reference to thefact that the defense team is cleared, e. g. at the third line: ?in your department or agency to PFC Marming?s appropriatelycleared defense Second would be a reference to the protections described in paragraphs 3 and 5, e. g. after ?defenseteam". insert Use at trial Is it appropriate to say that use in trial of classi?ed infomiation turned over in discovery requires authorizationof the military judge? If so, could you say this (as a summary to the more detailed evidentiary nrles that follow) after thefirst sentence under this heading? E.g. something like: ?Conseming to the disclosure of classi?ed infomtation to defenseduring discovery does 53 authorize the use of this information or material by the defense during trial. use of such infonnation at trial would require speci?c authorization by the military judge in accordance with the following Under MRE . . Protection of Classi?ed Infomiation as we discussed, it?d be great to have the protective order attached. Just for ourknowledge, what does it mean for info to be ?tested?? (subparagraph d)Meg; 5: Rguest for Classification ReviewCould you add in a section, similar to the one in the discovery memo. describing parameters for use at trial? I see that someof this info is under ?Future requests," but think it would help to set this info out separately as it?s what our decision makerswill be most cemented about. Here, we?d want to have assurance not only that the defense must seek authorization to useclassi?ed info at trial as described in the other memo, but also that the prosecution would use classified info at trial onlysubject to closure of those portions of the court manial to the public and/or other appropriate protections consistent with theevidence?s classi?cation.Future requests the description of the request in the ?rst sentence sounds a bit open-ended. Could you tie it back here tothe Enclosures? E.g. after ?which is expected to be used at trial" say ?as set forth in Enclosures 1 and Protection of Classi?ed Infomtation could you add in the same subheading language under ?Retain Classi?cation" as inthe discovery memo? (Assuming we're right to understand that authorization to use at trial would not affect classi?cation.)thanks,U.S. De rtment of State SBUThis email is UNCLASSIFIED.0221 5466From: Sent: Friday, March 4, 20] I 4:50 PMTo: Fein, Ashden CPT USA SJA Cc: Carlile, Monica L. SFC USA SJAMatthew kemkesMorrow JoDean, CPT USA Subject: [Suspected RE: SCIFAshden,Any update on the SCIF meeting? I want to make sure I have time to coordinate the schedules of myexperts and the needed travel.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02889688From: Fein, Ashden CPT USA SJAsent: Saturday. March 05. 2011 11:48 AMTo: Cc: Carlile. Monica L. SFC USA Matthew kemkes; Morrow JoDean,CPT USA JFHQ-NCRIMDW SJASubject: an noDavid. Good morning. As per our previous conversation and emails, we received authorizationto use the SCIF on Saturdays to minimize the accused?s exposure to third parties. The SCIFis available any Saturday after today. Please look at the calendar and let us know when thesoonest Saturday you can be here, so that we can schedule the conference room, securitydetail, the accused?s meals, and the Friday before meeting at Myer. once you send thatinformation, then we will coordinate the RCM 706's meeting in the SCIF.we spoke with the Brig about the removal of the accused's underwear at night. His underwearwas taken from him because of a specific statement that he made to Papakie at the Brig.After he was served his new charges and MAJ Kemkes left the Brig, the accused asked why allof his items were taken at night with the exception of his underwear under POI status.According to the Brig officials, the accused then talked about the elastic band in hisunderwear and how that would be "probably the most dangerous piece" of clothing or words tothat effect. Papakie believed that the accused was insinuating that he could harmhimself with the elastic band on his underwear and discussed the issue with the accused.After this conversation, the Brig staff took this threat seriously and believes that theaccused may have had recent thoughts or ideas as to the uses of the elastic band from hisunderwear to harm himself. The Brig staff removed his underwear to ensure that he does notharm himself. The next time you speak with your client, please ensure that he understandsthat any comment that could be reasonably construed as an intimation that he might harmhimself, will be taken very seriously by the Brig staff, because their primary mission is toensure the accused?s well being and safety.In addition, the accused was instructed to cover himself with his blanket during the morning"stand-to.? Despite the Brig staff allowing him to cover-up during this morning process, heelects to stand naked in his cell rather than to cover himself with his blanket.COL Malone was on emergency leave the day the accused was served with additional charges;however he came back yesterday and visited with the accused. Also, COL Malone is stillworking the accused?s request to have a female mental health provider.we are still working on the portable phone issue you brought up this past week. Despite thequality of the phone call, there is no monitoring of any communications between members ofthe defense team and the accused.Ashden 02889688Ashden FeinCPT, JAChief, Military JusticeMilitary District oF Washington (MDN) 02219995From: USA Sent: Monday, March 7, 201 I 6:17 PMTo: Fein, Ashden CPT USA SJA Subject: RE: IS-6 - "Read Ahead" (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONEI an answer within the next 24-48 hours. 2COL. JA Voice - PrimaryVoice - SecondaFaxBlackbeMailing Address:901 N. Stuart Street, Suite 300Arlington, Virginia 22203-1837 ?--Original Messagc?? From: Fein, Ashden CPT USA SJASent: on y, an: To:Subject: I5-6 - "Read Ahead? (UNCLASSIFIED)Thanks sir.Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDW) 'nal Mcssa Subject: 15-6 - ASSIFIED)Classification: UNCLASSIFIEDCaveats: NONEThe prosecutors (and CCIU - Computer Crimes Investigative Unit) haverequested an "advance copy" of the 15-6 to review and prepare for thediscovery requirements in U.S. v. Manning. I see no reason they can't02219995have such a copy provided it is not officially released umil OGC andHQDA have provided a formal release to t. McNair. That said - Iam not the release authority and was wondering what you each thought.Below is the request.Thanks,- MDW Request for ?Read Ahead? Copy of the 15-6 Below Sir,The prosecution submitted througl'? a request for a full copyof LTG Caslcn's AR I5-6 investigation and all its allied documcms,along with other collateral documents. COL Bradley is planning onforwarding that request to the proper authority. Assuming that requestwill take a while to process, is it possible for the prosecution and CIDto have a copy of the ?nal investigation (without allied documents) sothat we can start reviewing and processing the many pages, inanticipation of receiving the formal copy? I do not want to delay thediscovery process and going through this investigation will take asubstantial amount of time. This copy will NOT be distributed outsideof the prosecution team or CID. Thank you.v/rFcinCPT. JAChief, Military JusticeU.S. Army Military District of Washington (MDW) - MDW Request for ?Read Ahead? Copy of the l5-6 Above --JA Voice - Primvet - om osnjraxjoswBlackbeny Mailing Address:901 N. Stuart Street, Suite 300Arlingtorg Virginia 22203-1837Classi?cation: UNCLASSIFIEDCaveats: NONEClassi?cation: UNCLASSIFIEDCaveats: NONEI 02215434From: Sent: Tuesday, March 8, 2011 9:27 AMA To: Fein, Ashden CPT USA SJA Cc: Carlile, Monica L. SFC USA SJAMatthew kemkesHaber and,John CPT MIL USASubject: Expert RequestAttach: Mitigation Expert Request .pdf; 2011 Fee Schedule (1).pdf; Juliet Current CV MARCH2011.pdfAshden,Please see the attached expert request. Feel free to call me if you have any questions.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02221832From. Sweda, Michael Dr CIV USA MEDCOM WRAMC Sent: Tuesday, March 8, 2011 ll:04 PMTo: Fein, Ashden CPT USA SJA Cc: Benesh, Samantha MAJ MIL USA MEDCOM MAMC Morrow Ill,0 can, - DW SJA Matthew kemkesllaberland, John ar I e, Momca .MIL USA OTJAG Hemphill, Marla LTC MIL USAMEDCOM BAMC Moore, Kevin D. CAPTSubject: RE: RCM 706-Additional Charges (US v. PFC BM) (UNCLASSIFIED)Classi?cation; UNCLASSIFIEDCaveats: NONESir: We would like to do the on Saturda_\' 26 March. Hus is the only Saturday muilabulity for all three board members.Hopefully CAPT Moom can make it as well.Michael Swcda02911518From:Sent:To:Cc:Subject:David,Fein. Ashden CPT USA SJAWednesday, March 09, 2011 1:22 PMCarlile. Monica L. SFC USA JFHQ-NCRIMDW Matthew kemkes; Morrow Ill. JoDean.CPT USA HabeI1and,John CPTMIL USARE: [Suspected RE: (UNCLASSIFIED)Do you still want to meet with your client before the RCM 706 interviews him in the Ifso and because you arranged for 25 and 26 Mar 11, please send a request through us to theconvening authority to delay the RCM 706, otherwise we will need to schedule the RCM 766 tomeet on 26 Mar 11, as the soonest reasonable Saturday to meet with the accused. we want toensure the RCM 706 board is diligently moving Forward and not unnecessarily delaying thisprocess, outside the scope of the convening authority's order. Thank you.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MDN) 0221 5429From: coombs@armycourtmanialdef en se. comSent: Wednesday, March 9, 201] 1:45 PMTo: Fein, USA sm Cc: Carlile, Monica L. SFC USA SJ AMatthew kemkesMorrow IH, JoDean, us?. Haberan Jo AmSubject: RE: [Suspected RE: SCIF (UNCLASSIFIED)Ashden,I don't understand your message. We have discussed the issue of the 25th and 26th being the dates thatI am meeting with PFC Manning. I sent the government several emails on this topic last month attemptingto get a con?rmed date for my visit in order to make the necessary travel arrangements.I understand, that it apparently took some time to confirm access to a SCIF. However, despite myrepeated requests, I didn't hear anything from the government until it became cost prohibitive topurchase a ticket. It was my desire to meet with PFC Manning this week as opposed to the end of themonth. The delay in the process is not due to the defense.The 706 board has indicated that the 26th is the earliest that they will be able to meet with PFC Manning.Please request the board to determine if they could see him the following week.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 689-9282rm 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02911511From: Fein, Ashden CPT USA SJAsent: Wednesday. March 09.2011 1:59 PMTo: Cc: Carlile. Monica L. SFC USA Matthew kemkes; Morrow JoDean,CPT USA Haber1and.John CPTMIL USASubject: RE: [Suspected RE: SCIF (UNCLASSIFIED)David. we determined last week that the SCIF outside of FIU would best be used on a Saturdayand on Saturday (5 Mar) you requested the meeting to occur on Saturday (12 Mar). we spentMonday morning coordinating this meeting and was able to get back to you, but not before youscheduled your flights for two weeks from now. we are cognizant of your desire to minimizecosts, but we are trying to minimize any delays. we were ready to go this weekend (12 Mar)and you asked us to push your meeting two weeks to the right.the REM 706 board is soonest available for a Saturday meeting, that weekend (26 Mar). we canrequest them to meet the Following weekend (2 Apr), but this request needs to be submitted tothe convening authority, based on his suspense to the RCM 706 board.The RCM 766 board owes the convening authority a delay request based on the suspense and Iwant to clarify with them the reason for this delay.AshdenAshden Feincpr, JAChief, Military JusticeU.S. Army Military District of Washington (MDN) 02891712From: Fein, Ashden CPT USA SJASent: Wednesday, March 09, 2011 4:30 PMTo: Sweda, Michael Dr CIV USA MEDCOM WRAMCCc: Benesh, Samantha MAJ MIL USA MEDCOM Morrow JoDean, CPT USA Matthew kemkes?; Haberiand. John CPT MIL Cariile. Monica SFC MIL USA OTJAG: Hemphill, Marla LTC MIL USA MEDCOM Moore, Kevin D. CAPTSubject: RE: RCM 706?AdditionaI Changes (US v. PFC BM) (UNCLASSIFIED)Dr. Sweda.Thank you. I do not know how long you anticipate the interview will take, but i? possible,can the board start at 1490 that Saturday? we are trying to coordinate the deFense to meetwith their client that morning be$ore the interview and to tinish the SCIF meetings as soonas possible. Please advise.Thank you.V/rCPT FeinAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of washington (MDN) 02910362 From: Fein, Ashden CPT USA SJASent: 2011 6:01 PMTo: A USCENTCOM Cc: SA OTJAGSubject: Apache Videounponance: HuhSir. Good evening. Could you please provide me with an update on the instructions ordirective that lining out of the classification marking is appropriate for classificationreview of the video? Thank you.v/rAshden. Ashden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (mu)02212529From: OTJAG Econus.army.mi|]Sent: Thursday, March 10, 2011 8:38 AMTo: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASubject: (U) RE: Apache Video (UNCLASSIFIED)Attachments: directive?2010.pdfSigned By: mus.anny.miIClassification: UNCLASSIFIEDCaveats: NONEAshden,See attached at Section 2661.25. Office of the Judge Advocate General of the Army, Pentagon 3D548 NIPR: conus.arm .m11SIPR: JNIC . ov02215392From: Sent: Thursday, March 10, 201 1 2:15 PMTo= Cc: Greer ChristopherAshden CPT USA SJAMorrow JoDean, CPT USA SJACarlile, Monica L. SFC USA Matthew kemkes l; Fein, SJA Paul Bouchard Subject: Article 138 RebuttalAttach: Rebuttal Article 138 Complaint - Quantico.pdfSir,Please see the attached Article 138 rebuttal. The defense requests that you address this issue as soon aspossible. If you have any questions, feel free to contact me at (401) 744-3007.Respectfully,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02911959From: Fein, Ashden CPT USA SJASent: Thursda March 10 2011 8:01 PMTo: USA OTJAGSubject: RE: (U) RE: Apache Vndeo (UNCLASSIFIED)Thanks sir. They are still refusing to produce the document themselves.Break.I have not heard ~From? with reference to ?documents.Can you please assist? Also, I assume the DA G2 can authorize release 0?the CI investigation involved in this case. If so, is it possible toreceive a CD of the case File so we can turn that over, once we get thediscovery approval? A1though? sent me many emails For theSecArm 1S-6, I would like to ick a ristine cc of the case file AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (Mow) 0221 2525From: USA OTJAG ?@conus.anny.mil]Sent: Friday, March 11, 2011 8:11 AMTo: Fein. Ashden CPT USA SJASubject: ache Video (UNCLASSIFIED)signed By: @us.army.mi|Follow Up Flag: Follow upFlag Status: CompletedClassification: UNCLASSIFIEDCaveats: NONE1. which entity is refusing to produce the video?2. I will get the OK on the release of the CI investigation early next weekwhen? returns From leave. Should not be a problem. we Find 15-6. Do you mean the? 15-6? Do you need a copy it? Office of the Judge Advocate General of the Army, Pentagon 3D548 02221827From:Sent:To:Cc:Subject:Sweda, Michael Dr CIV USA MEDCOM WRAMCFriday, March ll, 20]] 8.43 AMFein, Ashden us/x SJA Benesh, Samantha MAJ MIL USA MEDCOM MAMC Morrow Ill,0 can, . - DW SJA Matthew kemkesHaberland, John -CUSA OTJAG SAMEDCOM BAM -RE: RCM 706-Additional Charges (US v. PFC BM) (UNCLASSIFIED) ar i e. omcaarla LTC MIL Classi?cation: UNCLASSIFIEDCaveats: NONECPT Fein:We would like to be able to ?nish this in one day. especially given that this is occurring on a Saturday. A I400 Slil? time will clearlynot pemiit completion of the cvuhizition in one day. We can have an 0900 sum time on :1 or revert to the imemew occurringon a regular work The suggested date of 26 March should allow more than sufficient time for pre-eraluzition consultation toMichael Sweda, Ph D.. ABPP (Forensic)Board-Ceni?cd Forensic Chief. Forensic Service Director. Forensic Fellowship Walter Reed Army Medical Center"The United States themselves are essentially the greatest poem.Past and present and future are not disjoincd butjoined." 02186964Fn ay, Marc 11,2011 2:26 PMI usdo?. ov>'I I usdoj.gov>;I usdoj.gov>;(D s.army.mil>;Fein, Ashden CPT USA SJAMorrow JoDean, CPT USA JFH -From:Sent:To: SJA I I ic.fbi.gov>;I usdoj.gov>;@usdoj.gov>Subject: Meeting Wed, Mar 16, 2:00 EDVAI ic.fbi.gov>' As discussed, we will have a meeting at EDVA to provide updates on the progress and activities of CID and FBIinvestigations. FBI Washington Field Officeoffice:mobile 02907640From: Fein, Ashden CPT USA SJASent: Frida March 11 2011 6:58 PMTo: how USA us.arm .mi|Cc: Morrow m, JoDean. CPT USA Bow us USAUSACIDCSubject: RE: chathnponance: l?ghThe prosecution requests that your team conduct an admin review of all classified informationin the case file over the weekend, to include evidence and exhibits. This review shouldspecify by MFR or other documents the exact contents of all CD5, DVDs, thumb drives,including the file name and short summary of the overall contents (similar to what is alreadyprovided). This request does not include the hard drives collected into evidence.The purpose of this request is so that the prosecution can provide each OCA the exactinformation we are requesting to be discovered to the defense during the court-martialprocess. Specifically, some documents and information on removable media will be turnedover; however, some documents and information are not relevant or necessary to the case, thusnot turned over.The prosecution needs to get these requests out NLT Monday, 14 Mar 11 at 1200hours and needthe MFRS NLT 13 Mar 11, 1800hours.If you have any questions, please call and ask. We will be working this weekend to get therequests completed less the MFRs and evidence exhibit lists.Thank you.AshdenAshden FeinCPT, JAChief, Military JusticeU.S. Army Military District of Washington (MD) 02891797From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Monday, March 14. 2011 7:46 AMTo: Sweda. Michael Dr CIV USA MEDCOM WRAMCCc: Benesh. Samantha MAJ MIL USA MEDCOM Momow JoDean, CPT USA Matthew kemkes Haberiand, John CPT MIL Canile. Monlca L. SFC - emphill. Marla LTC MIL USAMEDCOM Subject: RE: RCM T06-Additional Charges (US v. PFC BM) (UNCLASSIFIED)Importance: HighDr. Sweda,Good morning. The defense counsel is planning on meeting with the accused on Saturday, 26March. will the board be available to meet on Saturday, 2 April at 0900? If not, and in aneffort to have the board complete its mission as soon as possible, we will try to findanother SCIF For the board to meet during the week, after 26 March. The command canaccommodate a weekday meeting between PFC BM and the board; however, the command can betterprovide security and privacy of the accused on a Saturday.Also, does the board require the accused's movement to HRAMC or another facility For anytesting, IAN the convening authority's order?Thank you.v/rCPT FeinAshden FeinCPT, JA02891790From: Fein, Ashden CPT USA SJASent: Monday, March 14, 2011 8:47 AMTo: Sweda, Michael Dr CIV USA MEDCOM WRAMCCc: Benesh, Samamha MAJ MIL USA MEDCOM Morrow JoDean, CPT USA Matthew kemkes; Haberland, John CPT MIL Car1ile. Monica L. SFC - Hemphill. Marla LTC MIL USAMEDCOM ISubject: RE: RCM 706-Addmona arges v. BM) (UNCLASSIFIED)Importance: HighSir,Thank you. we will start making arrangements for the board to meet in another Facility thatprovides security and privacy of the accused. Could you please send me the soonest date,after 26 March that the entire board is available.Also, does the board require the accused's movement to NRAMC or another facility for anytesting, IAN the convening authority's order?v/rCPT FeinAshden FeinCPT, JA02219499From: Armanzz-.Pau1mSent: Monday, March 14, 201 I AMTo: Fein, Ashden CPT USA SM Cc: Carlile, Monica L. SFC USA SIAMatthew kcmkesorrow Ill, JoDcan, CPT USA Egan, Michael CIV HaberIand.John CPT MIL USA Subject: RE: Article 32 (PFC Manning)All-The last information I received on potential timing regarding this matter was that there was a 3 March suspense for thesanity board being completed, and the government anticipated three days to present evidence and believed they wouldbe ready to begin on 15 March. It goes without saying that at least some of this information is no longer current.Government, recognizing you may not be in a position to provide hard estimates, I would appreciate any updates ontiming that you can provide.Thank you.LTC Almanza02221813From:Sent:To:Ce:Subject:Sweda, Michael Dr CIV USA MEDCOM WRAMCMonday, March 14, 20ll l0;34 AMFein, Ashden CPT USA SJA Benesh, Samantha MAJ MIL USA MEDCOM MAMCMorrow Ill,JoDean, CPT USA SJAMatthew kemkesl-laberland, John CPT MIL USAUSA SJAMarla LTC MIL USA MEDCOM*1RCM 706-Additional Charges (US v. PFC BM) (UNCLASSLFIED) Carlile, Monica L.Hemphill,I).Clzissi?catioii: UNCLASSIFIEDNONESir:Yes. no ill arrange for an appointment for neurological and bmin iinaging. Could you please provide several dates andtimes that PFC Manning could be seen at Also. our forensic repons are not put into AHLTA. I assume there would be no objection to the results of the neurologicalbeing placed in The brain imaging and neurological exaluation are medical and not forensic findings.Michael Swcda. Pli.D.. ABPP (Forensic)Bozird-Certi?ed Forensic PsyeliologistChief. Forensic Semee Director. Forensic Psyeliolog} Fellowship Walter Reed Amiy Medical Center"The United States tlicrnselves are essenti:ill_\ the greatest poeinPast and present and future are not disjoincd bnljoinod.?02891781From: Fein, Ashden CPT USA SJASent: Monday. March 14, 2011 10:55 AMTo: Sweda, Michael Dr CIV USA MEDCOM WRAMCCc: Benesh, Samantha MAJ MIL USA MEDCOM Morrow JoDean, CPT USA SJA: Matthew kemkes: Habenand, John CPT MIL USA:Carlile. Monica L. SFC - DW Hemphill. Maria LTC MIL USAMEDCOM Subject: RE: RCM 70&AdditionaI Chatges (US v. PFC BM) (UNCLASSIFIED)Sir,Please follow all normal procedures For capturing medical tests (including inputting theinFormation in AHLTA). The only information that needs to be removed is classifiedinformation From the interview, pursuant to the convening authority's order.we can move PFC BM any day that you schedule his appointments, so long as we are given fourduty days notice, to coordinate the move and security. Please let us know which days you planon moving him, and we will schedule.Also, because the board did not meet the suspense to complete the board, please provide arequest to the convening authority to extend the suspense with your best estimate of itscompletion date. If possible, please provide this request today so that we can getit to the convening authority.-Break-In future correspondences, please refer to PFC BM using the accused or an abbreviation, e.g.PFC BM or BM. This request is For security purposes.Thank you.v/rCPT FeinAshden FeinCPT, JA02909177From: Fein. Ashden CPT USA SJAsent: Monday, March 14, 2011 10:58 AMTo: Alrnanza, Paul; Cc: Cadile. Monica L. SFC USA JFHQ-NCRIMDW Matthew kemkes; Morrow JoDean,CPT USA Egan, Michael CIV SJA:Haber1and.John CPT USASubject: RE: Adicle 32 (PFC Manning)Sir,Good morning. The United States arranged for a SCIF to be used by the defense and sanityboard. we are still in a holding pattern until the defense and the sanity board meet withthe accused in the SCIF. Currently the defense is scheduled for 26 March 2611 and the sanityboard owes us the first available time after the 26th. Once those meetings occur, then wewill have a better estimate of when the Article 32 will re-start.-8reak-In future correspondences, please refer to PFC BM using the accused or an abbreviation, e.g.PFC BM or BM. This request is For security purposes.V/rCPT FeinAshden FeinCPT, JA02884804From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Monda ,March 14, 2011 11:00 AMTo: SF-I Of?ce of the Staff Judge -SF-I Office of the Staff Judge AdvocatelOSJACc: Morrow Ill, JoDean, CPT USA JFHQ-NCRIMDW SJAsubject: RE: US v. PFC BM (UNCLASSIFIED)Importance: Higha,Do you have an update on the status of the prosecution receiving an unclasversion 01? the 15-6? I owe my SJA an update. Thank you.v/r?AshdenAshden FeinCPT, JA022250721 From: USF-I Sent: Monday, March 14, 2011 11:10 AMTo: Fain, Ashden CPT USA USF-I Of?ce ofthe Staff Judge Advocate/OSJAcc: Morrow JoDean, CPT USA SJASubject: RE: US v. PFC BM (UNCLASSIFIEDSined By: Classification: UNCLASSIFIEDCaveats: FOUOAshden,Just received an email yesterday from the Ad-Law Chief stating they arestill waiting for declassification.V/r,02907667From: Fein, Ashden CPT USA SJASent: Manda ,March 14, 2011 1:13 PMTo: USF-I Of?ce of the Staff Judge Advocate/OSJASumed: caSir. Can you please call my BB 11" you get a chance, want to give you a heads up aboutsomething. Thanks. .AshdenAshden FeinCPT, JA02225071From. USA Office of the Staff Judge Advocate/OSJA:raq.centcom.mil>Sent: Monday, March 14, 20] I l:2O PMTo: Fein, Ashden CPT USA S. Subject: RE: chatThanks for the heads up and hope you all can get what you need soon.02221 806From:Sent:To:Subject:Sweda, Michael Dr CIV USA MEDCOM WRAMCMonday, March 14, 20]! 1:23 PMFein, Ashden CPT USA SJA Benesh, Samantha MAJ MIL USA MEDCOM MAMCMonow Ill,0 can, . . - WSJA Matthew kemkes Haberland, John SFC USA SJAMarla LTC MIL USA MEDCORE RCM 706-Additional Charges (US v. PFC BM) (UNCLASSIFIED) C|zissif'icalion; UNCLASSIFIEDCaveats: NONESir:If 26 March is not chosen. we would be available -1 April (21 Monday). or 9 April (3 Saturday v/ r.Michael Swcda. ABPP (Forensic)Boand-Ccrii?cd Forensic Chief. Forensic Ps_Vclio|ogV Dircclor. Forensic Walter Reed Anni Medical Cciucr "The United States themselves are essentially Ilic greatest poem.Past and present and future are not disjoincd buijoincd." From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Monda .March 14. 2011 2:11 PMTo: one omeCc: Morrow JoDean, CPT USA SJASubject: Chat todaySir. Are you available to chat today? Topics:1. DA 62 being the disclosure consent authority For DISA JIEDDO information?2. Classification review o? the Apache video.3. ACICA Informationa. 992d Investigation (pristine copy-on CD) 4. Classification Reviewsa. b. CENTCOMC. SOUTHCOMd. DISAThanks.AshdenAshden FeinCPT, JA02221799From:Sent:To:Ce:Subject:Sweda. Michael Dr USA MEDCOM WRAMCMonday, March I4, 20ll 2:34 PMSweda, Michael Dr USA MEDCOM WRAMCFein. Ashden CPT USA SJA Benesh, Samantha MAJ MIL USA MEDCOM MAMCmbJoDean, CPT USA SJAMatthew kemkesHaberland, John CPT MIL USASFC USA SJAMarla LTC MIL USA MEDCOM BAMCilRE: RCM 706-Additional Charges (US v. PFC BM) (UNCLASSIFIED) Carlile, Monica L.Classi?cation: NCLASSIFIEDEIVCEIISL NONESir:Another matter has been called to my attention and the April date would be pneferred ox er 4 April.Micliztel Stxedu. Plt.D.. ABPP (Forensic)Bound-Ceni?cd Forensic Chief. Forensic ServiceDirector. Forensic Fellowship Walter Reed Anny Medical Center ?The United States themselves are essentially the greatest poemPatst and present and future are not disjoinod butjoined."armycourtmartialdefense.com; Morrow 02221791From:Sent:To:Cc:Subject:Sweda, Michael Dr CIV USA MEDCOM WRAMCMonday, March 14, 201 I 2:50 PMFein. Ashden USA sm Benesh, Samantha USA MEDCOM MAMC.@armycourtmartialdefense.com; Morrow Ill,Jo can, A il>;Matthew kemkesHaberland, John MIL USA il>; Carlile, Monica USA SJAMarla LTC MIL USA MEDCOM BAMC RE: RCM 706?Additional Charges (US v. PFC BM) (UNCLASSIFIED) Classificritionz UNCLASSIFIEDNONESir:PFC BM has an MRI scheduled at WRAMC for Wed 23 March at 1330. He ill be seen LTC Margaret ;it theNeurology clinic on WD 61 at I I00 that same day.As a point of clarification in of the next scheduled both LTC and MAJ arc scheduled topresent at a training on 4 April. The actixity is only scheduled to occur once throc months. and no uould like toprescn-c that activity ifat all possible. Hence. the 9 April date (a Saturday) is preferable.r.Ph D.. ABPP (Forensic)Board-Ccni?cd Forensic Chief. Forensic Senior:Director. Forcmic Fellowship Walter Reed Anny Medical Center "The United States themselves are essential!) the greatest poem.Past and present and future are not disjoincd butjoincd." 02900401From: Fein, Ashden CPT USA SJASent: Monday, March 14. 2011 3:22 PMTo: Cc: Carlile. Monica L. SFC USA Matthew kemkes; Morrow JoDean,USA Haber1and,John MIL USASubject: Issues Updatehnponance: David. Below is a summary of on-going issues:1. Discovery. we are still working on ensuring we answer your discovery requests. As weprepare our responses, the status of the information changes and we are working to get asmuch of your requests answered, as soon as possible.2. Expert. we are still working on finding a to presentto the convening authority. Unfortunately, most of the leadership for the behavioral healthsection was out last week. we intend to get an answer by Wednesday.3. Headset at the Brig. Brig OIC ordered the headset in February to eliminate the cord fromthe base to the handset. They did not want guards to ?stare? at pretrial confinees while. talking on the phone. All max pretrial confinees will use this head set. No one ismonitoring the phone when the phone call is between the pretrial confinee and a person undera privilege. The base unit is plugged into the same land line.4. Meetings with PFC BM. we are tracking your meeting with the accused on 25 Mar at TDS,Myer and on 26 Mar at the SCIF. At least one security expert needs to be present when youmeet with your client and when your client meets with the RCM 796 board. Please share theRCM 706 re-start memo with your security experts, so they understand their left and rightlimits.5. Mitigation Expert. we are still working on the mitigation expert. we intend to get ananswer by Friday.6. RCM 706 Board. Our plan was to hold the final interview on 4 April 2011 at the however based on Dr. Sweda?s recent email, the board is not available. The final interviewwill take place on 9 April 2911 at the INSCOM SCIF. Saturdays at the INSCOM SCIF affordheightened security and the most privacy for your client (similar to the FIU).v/rAshdenAshden FeinCPT, JA02221783From:Sent:To:Subject:Attach:Sweda, Michael Dr CIV USA MEDCOM WRAMCMonday. March 14, 20] 1 3:2] PMFein, Ashden CPT USA SJA Benesh, Samantha MAJ MIL USA MEDCOM MAMC 0 can, I U.AJ - .. IDW SJAMatthew kemkesHaberland, John CPT MIL USASFC USA SJAMarla LTC MIL USA MEDCOM BAMCIRE RCM 706-Additional Charges (US v. PFC BM) (UNCLASSIFIED)PFC BM 706 extension ;Car|iIe, Monica Iiemphill,Classi?cation: UNCLASSIFIEDCaveats: NONESir?The extension request is Michael Swcda. Ph D.. ABPP (Forensic)Bottrd-Cenified Forensic Chief. Foremic ScnioeDirector. Forensic Fellow ship Walter Reed Anny Medical Center "The United States themselves are essential!) the greatest poem.and present and future are not disjoincd butjotncd coombs ,armvcourtmartialdefense.com; Morrow 02900398From: Fain, Ashden CPT USA SJASent: Tuesday. March 15, 2011 8:59 AMTo: Cc: Cariile. Monica L. SFC USA Matthew kemkes; Morrow Ill, JoDean,CPT USA JFHQ-NCRIMDW 'HaberIand,John CPTMIL Subject: RE: Issues UpdateDavid.Could you please send us your projected time requirements for the Thankyou.v/rAshdenAshden FeinCPT, JA02907666From: Fein, Ashden CPT USA SJASun: 1919AMTo: Sumem: .Sir. Are you available to chat today? Thanks.Ashden FeinCPT, JA02215390From: Sent: Tuesday, March 15, 20ll l0:lO AMTo: Fein, Ashden CPT USA SJA Cc: Carlile, Monica L. SFC USA SJA Matthew kemkesMorrow JoDean, CPT USA .il;Subject: [Suspected RE: Issues UpdateAshden,This is hard to predict. I imagine the time commitment would be greater at the start and again when weget to trial.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs45 North Main Street, 5th FloorFall River, MA 02720Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02895838From: Fein, Ashden CPT USA SJAsent: Tuesda March 15 2011 1:59 PMTo:Cc: USAOTJAG .subject: RE: New Contact InformationSir. Is there a litigation division of the OGC at DIA, if so could youplease send need to send some approvalrequests to Director, DIA (or his designee) and want to figure out the bestavenue. For most agencies within and outside we go through thelitigation section, OGC For these requests. we have coordinated with allother organizations and recently determined that we will need someauthorizations/consent from DIA. Thanks.AshdenAshden FeinCPT, JA029038891 From: Fein, Ashden CPT USA SJASent: Tuesda March 15, 2011 2:15 PMTo: 1113;; omeSubject: DISA POCSir. Do you have a POC at the OGC, Thanks. AshdenAshden FeinCPT, 3A02903923From: Fein, Ashden CPT USA SJASent: Tuesda March 15. 2011 3:47 PMTo: isaJnHsubject: DISA OGCMa?am,Good afternoon. I am the lead prosecutor For the case of US v. PFC BM (wiklleaks) and havesome information to For-mally request from DISA. Are you available to discuss this issue onthe phone? Thank you.v/r~CPT FeinAshden FeinCPT, JA02187720From= _@dia.miI1 Sent: Tuesday, March 15, 2011 2:30 PMTo: - Cc:Subject: RE: New Contact informationSigned By: DODIISMIL Tthere is but who handles it depends on what you? are asking for-. Just sendit to me and I will Figure out who will handle it over here.Defense Intelligence Agency 02895836 From: Fein, Ashden CPT USA SJAsent: Tuesda . March 15. 2011 4:07 PMeciv USA OTJAG To:Cc:Subject: RE: New Contact InformationThanks sir. Any issue with the FOR line on the memo being ?OriginalClassification Authority, Defense Intelligence Agency"Ashden FeinCPT, JA0221 9968From:Sent:To:Ce:Subject:Attach:MIL USA OTJAG Tuesday, March I5, 20l 8:33 PMCIV MIL USA OTJA us.army.mil>USA us.a.rmy.mil>; Fein, Ashden CPT USASJA MFR SecArrny I5-6 (UNCLASSLFIED)ll-Mar-15-MFR Receipt of SeeArmy 15-6 (ManningB).pdf Classi?cation: UNCLASSIFIEDCaveats: NONEMa'ain.Attached is the MFR from MDW documenting their understanding that an_\read ahead/advance copy of the I5-6 Report and Allied Docs is notsubject to further release without prior rittcn approval. Once youme the go ahead. I'll coordinate with MDW to deliver the FullReport along itli all Allicds to MDW.Thank you. Mailing A - ress: 901 N. Sruan Street. Suite 300Arlington. Virginia 22203-183702187718From: ?@dia-millSent: Wednesday, March 16, 2011 8:23 AMTo: Fein, Ashden CPT USA SJASubject: RE: New Contact InformationSigned By: we have several OCAS here so that won't be a problem. Depending on theissue, we Figure out which one it goes to.Deputy General Counsel - OperationsDefense Intelligence Agency02891763From: Fein, Ashden CPT USA SJASent: Thursday, March 17, 2011 7:57 AMTo: Sweda, Michael Dr CIV USA MEDCOM WRAMCCc: Benesh, Samantha MAJ MIL USA MEDCOM JoDean, CPT USA Matthew kemkes; Haberiand. John CPT MIL carme, Monica L. SFC USA Hemphill, Maria LTC MIL USAMEDCOM BAMCSubject: RE: RCM 706-Additional Charges (us v. PFC BM) (UNCLASSIFIED)Dr. Sweda,we will present your delay request tomorrow to the convening authority. Please have theboard plan on meeting 9 April 2611 with PFC BM. Thank you.v/rCPT FeinAshden FeinCPT, JA 02886034From: Fain, Ashden CPT USA JFHQ-NCRIMDW SJASent: Sunday. March 20. 2011 12:38 AMTo: Cc: Carlile. Monica L. SFC USA JFHQ-NCRIMDW Matthew kemkes; Morrow Ill. JoDean,USA JFHQ-NCRIMDW Habet1and,John cmMIL USASubject: Update (US v. PFC BM)Attachments: Charge Sheet DISMISSED REDACTED (ManningB).pdf; 11-Mar-18-RCM 305(9) Review (ManningB).pdf; Directive to InvestigateAdditional Charges (ManningB).pdf; 11-Mar-18-Excludabte Delay Memorandum(ManningB).pdf; Sanity Board Extension Approval (ManningB).pdfDavid,we are still working your request. we are waiting For the supervisor ofthe small pool of doctors to approve the use, so your client will get a doctor that canprovide adequate support, if approved by the convening authority. The supervisor was onleave this week. Additionally, we are still working the mitigation expert request throughcommand channels and should have an answer for you next week. I would like to discuss yourrequest before taking it to the convening authority. Are you available on Monday or Tuesday?Attached are a number of documents signed by the convening Authority yesterday with anexplanation below:1. Dismissed original charge sheet (redacted). The un-redacted original charge sheet isavailable in my office for your review.2. In light of the additional charges and the dismissal of the original charges, the reviewed PFC 8M?s continued pretrial confinement under RCM 39S(g).3. The directed the I0 to investigate the additional charges and not the dismissedoriginal charges. A separate email will go out to the I0 after this.4. The accounting of excludable delay from the previous accounting to present.5. The approved an extension of the Sanity board based on the request from the board?spresident; however as you will note, the CA gave a shorter suspense than requested. Aseparate email will go out to the board?s president after this.02886034Have a good weekend and let me know if you have any questions or concerns.AshdenAshden FeinCPT, JA02909196From:sent:To:Cc:Subject:Attachments:LTC Almanza,Fein, Ashden CPT USA SJASunday. March 20, 2011 12:43 AMAhnanza.Pau|Carlile. Monica L. SFC USA JFHO-NCRIMDW SJA: Matthew kemkes; Morrow JoDean,CPT USA SJA: Edan. Michael CIV JFHQ-NCRIMDW SJA:Haber|and,John CPT MILArticle 32 (PFC BM)Directive to Investigate Additional Charges (ManningB).pdf; 10-Jul-05-Original Charge Sheet DISMISSED REDACTED 11-Mar-01-AdditionalChange Sheet REDACTED (ManningB).pdfGood evening. Additional charges were preferred against PFC BM on 1 March 2011 and the directed you to investigate these charges. Although the alleged misconduct is substantiallysimilar between the two charge sheets, the convening authority dismissed the original chargesand directs you not to consider those charges.Please see the attachments to this email. Thank you and have a good weekend.v/rCPT FeinAshden FeinCPT, JAI 02891730From: Fein, Ashden CPT USA SJASent: Sunday. March 20. 2011 12:52 AMTo: Sweda, Michael Dr CIV USA MEDCOM WRAMCCc: Benesh. Samantha MAJ MIL USA MEDCOM Morrow JoDean, CPT USA Matthew kemkes; Habedand, John CPT MIL Carlile. Monica L. SFC USA Hemphill. Mada LTC MIL USAMEDCOM Subject: RE: RCM 706-Additional Charges v. M) (UNCLASSIFIED)Attachments: Sanity Board Extension Approval (MannIngB).pdf; 10-Jul-OS-OriginalCharge Sheet DISMISSED REDACTED 11-Mar-01-Additional Charge SheetREDACTED (ManningB).pdfDr. Sweda,Good evening. Attached is the convening authority's approval of yourextension; however note the suspense date is set for the board to becomplete no later than 16 April 2011. Please submit additional requests forextensions, to be considered by the convening authority, if you need moretime, as 16 April approaches.Also, we are scheduled to for PFC BM to move to WRAMC on 23 March 2611, forhis two appointments: (1) Neurology at 1100 (2) MRI at 1300. we are alsoscheduled For the board to meet at the SCIF in Metro Park (Alexandria) on 9April 2011. you need to schedule any other tests, please let us knowASAP so we can schedule the movements and security for PFC BM.Also, yesterday the convening authority dismissed the original chargesagainst PFC BM and directed the Article 32 investigating officer to considerthe additional charges. Attached are copies of both charge sheets, eventhough you already received the additional charge sheet from me on 2 March2011. Since the original charges were dismissed, you do not need toconsider them in your evaluation.Thank you. Have a good weekend.V/rCPT FeinAshden FeinCPT, JA.02221775From:Sent:To:Cc:Subject:Sweda. Michael Dr CIV USA MEDCOM WRAMC?iL>Monday, March 20l I 8:21 AMFein, Ashden USA SJA Benesh, Samantha MAJ MIL USA MEDCOM MAMC Morrow Ill,0 can, - .. DW Matthew kemkesHaberland, John CPT MIL USA SFC USA SJAMarla LTC MIL USA MEDCOM BAMC -RE: RCM 706-Additional Charges (US v. PFC BM) (UNCLASSIFIED) Classi?cation: UNCLASSIFIEDCaveats: NONESir:Tlumk you for the update. We plan on starting at 0900 on Saturday 9 April for intcn icw. lfyou could please the address.I would appreciate it.Michael Swcda. ABPP (Fotctisic)Board-Certi?ed Forensic Chief. Forensic Ps_vcliolog\' Director. Forensic Fellowship Walter Reed Amiy Mcdical Center"The United States themselves an: essentially the greatest pocm.Past and present and future are not disjoincd but joined.? 02909186From: Fein, Ashden CPT USA SJASent: Monday. March 21, 2011 12:53 PMTo: Almanza. Paul; Cc: Canile, Monica L. SFC USA JFHQ-NCRIMDW Matthew kemkes; Morrow JoDean,CPT USA Egan. Michael CIV SJA:Haberland,John CPT MILSubject: RE: Article 32 (PFC Manning)Sir,I apologize. On 18 March 2011, the granted an extension to the RCM 706 board with asuspense date of 16 April 2611. with that new date, I do not foresee the Article 32 kickingany earlier than 1 May 2011; although the Government should be ready to proceed once thesanity board is complete. Also, at this point, the Government anticipates one week forevidence presentation.Thank you.v/rCPT FeinAshden FeinCPT, JA02889081From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Monday, March 21, 2011 3:29 PMTo: OTJAGCc: Morrow Ill, JoDean. CPT USA SJASubject: SIPRSir. Sent you an email from OGA on your SIPR. Also, we are Finishing up the redo of the disclosure consent memo. we should have it finished and sent today. It will only be theupdated enclosure list with better specificity.Ashden FeinCPT, JA 102884697From: Fein, Ashden CPT USA SJASent: Monda March 21 2011 7:59 PMTo: bus?. OTJAGCc: Morrow Ill, USA SJASubject: US v. PFC BM Issues .Importance: HighSir. I am tracking the below issues you are assisting us with:1. Sending me a copy of the OCA consent email for my records (I never receivedyour email)2. Assisting with setting up a meeting between me, you, -, and especially in light of today?s SIPR email I sent you3. Assisting with? who has not responded to any of my emails requesting thefollowing:a. Official copy of the 902d File on SUBJECTb. Official copy and consent to use investigation on ACIC document4. OCA Consent to Disclose (I sent the updated Enclosure list with more claritytonight).5. OCA Classification Reviews for the Following entites: *if any of them need CDsof the information, we just need an address to send thema. CENTCOMb. CYBERCOMC. INSCOMd. SOUTHCOM6. FYSA, we are directly tracking OCA Consent to Disclose from the Followingorganizations:a. OGAb. DIAC. DISAd. D05e. NSAF. ODNI028846977. FYSA, we are directly tracking OCA Classification Reviews From the Followingorganizations:a. OGAb. DISAc. DOSd. NSAe. ODNIThanks.v/rAshdenAshden Feincpr, JA02884908From: Fein, Ashden CPT USA SJASent: Tuesda March 22 2011 9:58 AMTo:Subject: US v. PFC BM (DOS Actions)2, You should have both the disclosure request (sent on 14 Mar 11) and the classificationreview (sent on 18 Mar 11). Could you please confirm you received both on SIPR. Thank you.AshdenAshden FeinCPT, JA02884860From: Fein, Ashden CPT USA SJASent: Tuesda March 22, 2011 10:10 AMTo:Cc: Morrow JoDean, CPT USA Subject: us v. PFC BM (OCA Actions)- You should have received the disclosure request (sent on 21 Mar 11) on SIPR.Could you please confirm you received. If you have any questions, I am available todiscuss. Thank you.v/rAshdenAshden FeinCPT, JA02884872 From: Fein, Ashden CPT USA SJASent: Tuesda March 22, 2011 10:11 AMTo: disa.mi|Cc: orrow ean, CPT USA SJASubject: US V. PFC BM (OCA Ac1ion)Ms. -. You should have both the disclosure request (sent on 21 Mar 11) and theclassification review (sent on 18 Mar 11). Could you please confirm you received both onSIPR. Thank you.v/rAshdenAshden FeinCPT, JA02188684From ?@sta1e-s0v>Sent: Tuesday, March?22, 2011 10:23 AMTo: Fein, Ashden CPT USA SJA Cc: JoDean, CPT USA JA Subject: RE: US v. PFC BM Actions)We received both thank you. We?re processing them and hope to have a decision for you on the disclosure request thisweek.st U.S. De artment of State SBUThis email is UNCLASSIFIED. 02187717From ?@dia.miI>Sent: Tuesday, March 22. 2011 l0:49 AMTo: Fein, Ashden CPT USA SJA Subject: RE: US v. PFC BM (OCA Actions)We've got it. ?and ?will go to work on it.-Deputy General Counsel - OperationsDefense lntell? enoe Agency02884867From: Fein, Ashden CPT USA SJASent: 2011 10:59 AMTo: CIV DISA GCSubject: RE: US v. PFC BM (OCA Action) (UNCLASSIFIED)Ma'am. Just resent both emails. They should be in your inbox. Thank you.Ashden FeinCPT, JA 02188137 From: 9 c1v DISA GC Sent: ur ay, Marc 24, 2011 2:57 PMTo: Fein, Ashden CPT USA SJA Cc: Morrow JoDean, CPT USA ASubject: RE: US v. PFC BM (OCA Action) (UNCLASSIFIED)Attach: hStaff-OCAmemo24mar1 1.pdfClassi?cation: UNCLASSIFIEDCavcats: NONEAttached is a soft copy of the Chief of Staffs OCA disclosure approvalmcmo - I will hand-cany it to your facility this afternoon.SincerelEeputy ?Emu-al !ounsel, Regulatory and International LawOffice of the General Counsel (DISA Ft. Meade, Room C4A24L)Headquaners Defense Infonnation AgencyPhonc:?DSUnclas. Email: a3disa.mil02187716Sent: Monday, March 28, 201 1 2:25 PMTo: Fein, AshdenCPT USA PFC Manning Defense TeamSubject: Could you give me the names of the civilian and military defense counsel and the defense experts who will have accessto classified information? I have a meeting with_ at 1500 hours today. 02912296From: Fein, Ashden CPT USA SJAsent: nda March 28, 2011 9:33 PMTo: Mr USA USACIDCCc: orrow 0 an, op . ow PT USA'cIv IV us USAUSACIDCSubject: "Compieted" Reportswe spoke earlier today about the completed forensic reports ready for defense. we predictthat we need to be ready to provide those reports in discovery NLT 8 Apr 11. Although wemight not provide them, we need to have them ready to pull the trigger at any time. The 0CAs. - - -hope the plan to go over the reports will be executed at the end of the week, over theweekend, or at the beginning 0F next week.Thank you!AshdenAshden FeinCPT, JA02212516From: A OTJAG Sent: Wednesday, March 30, 2011 8:02 AMTo: Fein, Ashden CPT USA Morrow JoDean, CPT USA JFHQ-SJAcc: USA OTJAGSubject: FW: Information Assurance Support to Judge Advocate Genera|'s Staff (UNCLASSIFIED)Signed By: ?@us.army.mi|Follow Up Flag: Follow upFlag Status: CompletedClassification: UNCLASSIFIEDCaveats: FOUOCPT Fein,we should discuss the below email to determine if there are measuresrequired to protect your IS regarding the CM case.Office of the Judge Advocate General of the Army, Pentagon 3D548NIPR:SIPR:JNICS:Tel: 02900821From: Fein, Ashden CPT USA SJASent: 011 8:06 AMTo: USA Morrow Ill, JoDean, CPT USA SJACc: USA OTJAQ: USA SJASubject: RE: Information Assurance Suppon to Judge Advocate General's Staff (UNCLASSIFIED)Sir,Thank you. Are you available to discuss on the phone later this morning?we have already started planning for this with proposed ordering of industryleading software For our NIPR SIPR computers and blackberriesthat have the option to emails.v/rAshdenAshden FeinCPT, JA02202161From: Haberland, John CPT MIL l>Sent: Wednesday, March 30, 201 10:02 AMTo: Sweda, Michael Dr CIV USA MEDCOM WRAMCBenesh, Samantha MAJ MIL USA MEDCOMMAM Hemphill, Marla LTC MIL USA MEDCOMBAMCCc: Carlile, Monica L. SFC USA SJA Fein, Ashden CPT USA SJA Morrow JoDean, CPT USA SJAf. Matthew Cassius Mr FMMC (FTMYER)Davis, Patsy A Ms CIV USA INSCOMLease, John V. CIV PMOJoyner, Chad SSG MIL USAWilliams, Bruce A ISG MIL USA Subject: R.C.M. 706 interview of PFC (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUOALCON:The R.C.M. 706 inquiry is scheduled to begin at 0900 at the ?oor conference room on the Metro Park Facility.The address is the facility is:6359 Walker LaneAlexandria, Virginia 22310There is a parking structure located behind the building. I recommend entering through the side door of the facility (closest tothe parking garage). A security guard will meet you at the side door of the facility to let you in and direct you to the elevators totake you to the third floor. A member of the prosecution team will also be there to coordinate any last minute issues. The guardwill be at the side door of the facility between 0830 and 0900.Once you arrive on the third floor, there are signs directing you to the se4curity station where you will receive your temporarybadges and then they will escort you into the conference room where the board will be conducted. I have provided your socialsecurity numbers to the security manager at the facility and she has verified your clearances so there will not be any slowdownin entering the conference room.If anyone has any questions or concerns please let me know and we can address them.Very Respectfully,HaberlandMilitary District of Washington Legal SpokesmanClassi?cation: UNCLASSIFIEDCaveats: FOUO02212506From: _lV USA OTJAG -@conus.army.mil]Sent: Wednesday. March 30. 2011 4:02 PMTo: Fein, Ashden CPT USA Morrow Jooean, CPT USA JFHQ-NCRIMDW SJASubject: FW: (UNCLASSIFIED)Attachments: Manni Access G-2 memo.pdfsigned By: a.Follow Up Flag: Follow upFlag status: CompletedCategories: Blue CategoryClassification: UNCLASSIFIEDCaveats: NONEGents,Here you go with the disclosure authority. From: USA DCS G-2Sent: nes ay, arc 2011 2:50 PMTo: USA OTJAGSubject: (U) Access memoClassification: OFFICIAL USE ONLY- Here you are.Classification: OFFICIAL USE ONLYClassification: UNCLASSIFIEDCaveats: NONE 02200919Morrow Ill, JoDean, CPT USA SJAFrom:Sent: Thursday, April 7, 201 I 9:28 AM To: T@state.gov>Cc: Fein, Ashden cp-r USA maomca/Mow sm o;?@state?gov>Subject: disc (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: FOUO-Are you available today for a disc hand-off around lunch time? I got sidetracked yesterday by some other stuff. I'mthinking that Ashden or I could meet you in the lobby or something? Thanks!CPT Joe MorrowTrial CounselU.S. Army Military District of Washington (MDW)"h?ne= 2Classification: UNCLASSIFIEDCaveats: FOUO02188683Fro-I-= ?@state?20v>Sent: Thursday, April 7, 2011 10:14 AMTo: Morrow JoDean, CPT USA IF SJACc: Fein, Ashden CPT USA SJA 1Subject: RE: disc (UNCLASSIFIED)Sure, that works ?ne. have an 1 lam meeting, but should be back at my desk no later than I 1:45.SBUThis email is UNCLASSIFIED. 02212501From: ?usA Sent: Thursday, April 07, 2011 1:29 PMTo: Fein, Ashden CPT USA Morrow Ill, JoDean, CPT USA JFHQ-NCRIMDW SJASubject: Assurance Support to Judge Advocate Genera|'s Staff (UNCLASSIFIED)Signed By: us.army.milClassification: UNCLASSIFIEDCaveats: FOU0Ashden and Joe,Please see below and provide a POC to me for Forwarding to the Army to provide you IA support. Office of the Judge Advocate General of the Army, Pentagon 3D548NIPR: conus.army.mi1SIPR: QDA?S.army.smi1.mi1JNICS: am1. ic . govTel: 02212493From: USA OTJAG Sent: Thursda A riI 07 2011 1:46 PMTo: USA CIOIG-6Cc: Fein, Ashden CPT USA SJASubject: RE: Information Assurance Support to Judge Advocate GeneraI's Staff (UNCLASSIFIED)Signed By: ?@us.am1y.miIClassification: UNCLASSIFIEDCaveats: FOU0-JPlease contact CPT Ashden Fein For the MDW IA support.Thanks and let me know if I can assist. I may also request that certainOTJAG officials obtain IA support at a later date.r/ ice ge voca enera rmy, en agonNIPR:onus.army.mi1SIPR: QDA?S.army.smil.milJNICS: ami . ic . gov02911752From: Fein, Ashden CPT USA SJASent: 11 8:05 PMTo: USA DCS G-2Cc: Carlile Monica L. SFC USA SJA: ocsUSA OTJAGSubject: RE: (U) SSBI CompleteAttachments: 11-Apr-06-Request Personnel Access to Classified Information (ManningB).pdfhnponance: Attached is our newest request. Sorry to get it to you so late. All threeare aware and standing by ready to get their EQIP started.(USN) is assigned to a USMC billet that requires the clearance, but justto the unit this week. They could have already started her in EQIP,but she was going to tell them to hold off because we needed her for thismission. whyte and- are out of our office and are ready to jump whenthey are told for all the requirements.Thank you!AshdenAshden FeinCPT, JA02891942From: Fein. Ashden CPT USA SJAsent: Fnday. Apn'I 08. 2011 7:08 AMTo: Sweda. Michael Dr CIV USA MEDCOM Benesh, Samantha MAJ MIL USAMEDCOM Hemphiil, Mada LTC MIL USA MEDCOM BAMCCc: Haberland. John CPT MIL Cariile, Monica L. SFC USA JFHQ-NCRIMDW MorrowJoDean, CPT USA coom arm courtmai1iaIdeIense.com;Matthew kemkes; i il; HallCassius Mr FMMsubject: RE: R.C.M. 706 interview of PFC (UNCIASSIFIED)Importance: HighDr. Sweda,Good morning. In light of the looming Furlough, could you please let me know whether theBoard will still be available tomorrow to conduct its interview? we are currently verifyingwith the support staff involved with movement, security, and facilities, to ensure there areno shutdowns planned.Also, SFC Monica Carlile will be at the Metro Park facility to greet the Board and escort youto the conference room. If you have any issues tomorrow, please call my blackberry atAlso note that you will not be able to bring cell phones into the conference room,so please have my number available hard-copy. Cell phones may be stored outside of thesecurity check point.After your confirmation back to me about tomorrow, I plan on sending a final confirmation toyou no later than 1500 today.Thank you.v/rCPT FeinAshden FeinCPT, JA 02231264From: DCS G-2 Sent: Friday, April 8, 20ll 7:21 AMTo: Fein, Ashden USA sm onCc: Carlile, Monica L. SFC USA SJA USA DCS G-2us.army.m1l>; USA OTJAGJconus.anny.mil>Subject: Re: (U) SSBI CompleteAshden.The may be an issue. please have her submit her security clearance via her Conumnd Security Of?ce lod.1_s if possisblc. In themeannmc. ?ll see if I am authorized to submit for pcrsomlel and what obstacles may arise.we'll get White and- staned today. Thanks. Sent in 02231256 From: ocs Sent: Friday, April 08, 2011 9:05 AMTo: Fain, Ashden CPT USA JFHQ-NCRIMDW SJAcc: Carlile Monica L. SFC USA USA DCSUSA OTJAGsubject: RE: SSBICompletesigned By: us.army.miIClassification: OFFICIAL USE ONLYI spoke to_ (DISL), Senior Security Advisor, and shestated that this clearance should be initiated by the there areissues with the Army initiating and adjudicating a clearance for anotherservice. Not sure why the process would take any longer? Navy Security hasthe same process for submittal and can submit an expedite as well, they justneed to be aware of the urgency.can we get her correct SSN though? ?I'd like to check her in JPAS and seewhat she currently has For past investigations. Thanks.Best regards,HQDA, ODCS, G-21090 Army Pentagonwashin ton DC 20318-1699 02911740From: Fein, Ashden CPT USA SJASent: Hide A til 08 2011 9:14 AMTo: USA DCS G-2Cc: Carlile Monica L. SFC USA JFHQ-NCRIMDW ocsG-2: USA OTJAGSubject: RE: (U) SSBI CompleteAttachments: 11-Apr-06-Request Personnel Access to Classified Information (ManningB).pdfThank you.Attached is the corrected memo.Ashden FeinCPT, JA02231251 From: ocs G-2 Sent: Friday. April 03. 2011 9:34 AMTo: Fain, Ashden CPT USA SJACc: Carlile Monica L. SFC USA JFHQ-NCRIMDW USA ocsUSA OTJAGSubject: BI Completesigned By: us.army.milClassification: OFFICIAL USE ONLYThanks. 0k, has a current Secret clearance, so her SSO wouldneed to subm expedited SSBI and after her eQip is completed andfingerprints submitted, can adjudicate her For an Interim SCI basedon her Secret clearance investigation.iist riiards, 02221743From: Benesh, Samantha MAJ MIL USA MEDCOM MAMC Sent: Fnday. April 08. 2011 2:11 PMTo: Hemphill, Marla LTC MIL USA MEDCOM Fain, Ashden CPT USA JFHQ-Sweda. Michael Dr CIV USA MEDCOM WRAMCCc: Haberland. John CPT MIL Canile, Monica L. SFC USA MorrowJooean, CPT USA Matthew kemkes; HallCassius Mr FMMSubject: RE: R.C.M. 706 interview of PFC (UNCIASSIFIED)Signed By: BENESHSAMANTHAMARIE.1272647034Classification: UNCLASSIFIEDCaveats: FOUOCPT Fein,Per guidance from our Department Chief, COL Dunivin, we are good to go forthe interview tomorrow regardless of whether a furlough is in effect. Dr.Sweda and I will be there at 6900, unless we receive other guidancefrom you this afternoon by 1606. Neither Dr. Sweda nor I will have accessto our email accounts after 1690. If you need to reach us for any reason,please feel free to Contact me at my cell phone number below.Samantha M. BeneshMAJ, MS, USAForensic FellowHalter Reed Army Medical Center02891923From: Fein. Ashden CPT USA SJASent: Fn'day, April 08. 2011 2:59 PMTo: Benesh, Samantha MAJ MIL USA MEDCOM Hemphill, Maria LTC MIL USAMEDCOM Swede. Michael Dr CIV USA MEDCOM WRAMCCc: Haberland, John CPT MIL Carlile, Monica L. SFC USA MorrowJoDean. CPT USA Matthew kemkes; HallCassius Mr FMMC Subject: RE: R.C.M. 706 intewiew of PFC (UNCLASSIFIED)Board Members,we are still on for tomorrow, despite the furlough. The building will beopen and SFC Carlile will meet you at the front door at 0900. Thank you.v/rCPT FeinAshden FeinCPT, JA02907971 From: Fein, Ashden CPT USA SJASent: 1:15 PMTo: A USCENTCOM CCJAISJACc: Carlile. Monica L. SFC USA JFHQ-NCRIMDW OTJAGSumed: CD5Sir,Good afternoon. we have CDs to send to CENTCOM for the classification reviews. what addresswould you like us to send the classified information to? Thank you.v/rAshdenAshden FeinCPT, JA02884922From:Sent:To:Cc:Subject:Attachments;David,Good evening.discovery requests.Fein, Ashden CPT USA JFHQ-NCRIMDW SJATuesday. April 12. 2011 6:30 PMMatthew kemkes; Morrow Ill. JoDean, CPT USA Haber1and,John CPT MIL Canile, Monica L. SFCUSA Feito, Beatriz SGT USA JFHQ- SJAUS v. PFC BM (Discovery)11-Apr-12-Government Response to Discovery Response 29 Oct 10 (ManningB).pdf; 11-Apr-12-Govemment Response to Discovery Response 1 Nov 10 (ManningB).pdf; 11-Apr-12-Govemment Response to Discovery Response 8 Dec 10 (ManningB).pdf; 11-Apr-12-Govemment Response to Discovery Response 10 Jan 11 (ManningB).pdt; 11-Apr-12-Government Response to Discovery Response 15 Nov 10 (ManningB).pdt; 11-Apr-12-Govemment Response to Discovery Response 16 Feb 11 (ManningB).pdfAttached are the Government's responses to your Pre-Art 32This morning, we went you an CD with additionaldiscovery (BATES: 011574-12711). As we receive more information, we will bepassing the information to you and we are also preparing to give you access toclassified evidence, once we receive the approvals.If you have any questions, please call.Have a good evening.v/rAshdenAshden FeinCPT, JA02215359 From: Sent: Tuesday, April 12, 201 1 7:42 PMTo: Fein, Ashden CPT USA SJ A Cc: Matthew kemkes Morrow Ill. JoDean, CPT USASJA Bouchard, Paul CPTUSCENTCOM USF-I I-Iaberland,John CPT MIL USACarlile. Monica L. SFC USA SJAFeito, Beatriz SGT USA FHQ- ASubject: [Suspected RE: US v. PFC BM (Discovery)Ashden,Thank you for the discovery responses. I anticipate the need to revisit most of the government'sresponses after referral. I also want to inform the government of a new mailing address for my office.Please use the below address for all future correspondence. If you have already sent the CD tomy old address, I will ensure that it is forwarded to me.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02884583From: Fein, Ashden CPT USA SJASent: Friday, April 15, 2011 7:59 AMTo: Cc:coom ma Ia eenseoom; onow 0 an, CPT Matthew kemkes;Subject: US v. PFC BM-UpdateImportance: HighDr. Sweda,Good morning. The purpose of this update is determine whether the 766 boardwill be able to meet its suspense with completing the report by tomorrow (16April 2011). If not, please send an extension request with a justification.Also, is there any more testing or interviews that you need the Governmentto organize for the board?Thank you.v/rCPT FeinAshden FeinCPT, JA02221735Sweda, Michael Dr CIV USA MEDCOM WRAMCmm: Sent: Friday, April 15, 2011 9:07 AMTo: Fein, Ashden CPT USA SJA Cc: Benesh, Samantha MAJ MTL USA MEDCOM MAMCMorrow .loDean, CPT USA SJA Matthew kemkes Bouehard, Paul CPT USCENT OMUSF-I Haberland, John CPT MIL USASubject: RE: US v. PFC BM-Update (UNCLASSIFIED) Classi?cation: UNCLASSIFIEDCaveats: NONESir?I just spoke with all members of the 706 Board. We anticipate completing the report this evening, perhaps late. but this evening.r.Michael Sweda. Pli_D.. ABPP (Forensic)Board-Cenified Forensic Chief. Forensic ServiceDirector. Foremic Fellowship Walter Reed Army Medical Center "The United States themselves are essentiall) the greatest poem.Past and present and future are not disjoined butjoined." 02884576 From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Fnday. April 15. 2011 9:21 AMTo: Cc: .Morrow JoDean, CPT USA Matthew kemkes; Bouchard, Paul CPT USCENTCOM USF-I JA-T80: Subject: Re; US v. PFC BM-Update (UNCLASSIFIED)Sir,Thank you. It is not our intent to rush or move the board to be inaccurate; however if thesuspense can be met then it should. If you can not finish by tomorrow, please send an emailrequest and we will forward to the convening authority.Ashden FeinCPT, JA02221732From:Sent:To:Subject:iwidil Miihiil Dr iilV WRAMCFriday, April 15, 2011 9:42 AMFein, Ashden cm? USA SJA ?ai>Benesh, Samantha MAJ MIL USA MEDCOM MAMCcoombs Morrow JoDean, CPT USA JFHQ-NC IDW SJAMatthew kemkes Bouchard, Pau CPT CENT OMHaberland, John CPT MIL USARE: US v. PFC BM-Update (UNCLASSIFIED) Classi?cation: UNCLASSIFIEDCaveats: NONESir?We are nishod. One of the board members was out three days this week. One board member will perhaps have just enough time toreview the long report to meet the suspense today. Ifadditional time is possible. I would respectfully request an additional week. Theboard has limited availability to meet togetlcr due to leave and conflicting schedules. 98% of the long report has been ?nalired. butwe should have. ideally. more time to meet and discuss the full rcpon.I ill send a fonnal request for a one-week extension. but will continue pressing forward in case this is not approved.vlr.Michael Sweda. Pli . ABPP (Forensic)Board-Certified Forensic Chief. Forensic ServiceDirector. Forensic Fellou ship Walter Reed Amiy Medical enter "The United States themselves are essentially the greatest poem.Past and present and future are not disjoined butjoined." 02221728From:Sent:To:Cc:Subject:Attach:Sweda, Michael Dr CIV USA MEDCOM WRAMCFriday, April 15, 2011 959 AMFein, Ashden cm USA sm Benesh, Samantha MAJ MIL USA MEDCOM MAMCcoombs arm courtmartialdefensecom; Morrow Ill,1 Bouchard, Paul CPT USCENTCON USF-I Haberland, John CPT MIL USAUS v. PFC BM?Update (UNCLASSIFIED)Manning extension request 22 Apn'l.pdfClassi?cation: UNCLASSIFIEDNONEALCON:Please see extension request (attached).v/r.Michael Swcda. ABPP (Forensic)Board-Certi?ed Forensic Chief. Forensic ServiwDirector. Forcmic Walter Reed Army Medical Center5 "The United States themselves are essentially the greatest poem.Past and present zuid future are not disjoined but joined."02884578From:Sent:To:Cc:Subject:Attachments:Dr. Sweda,Fein, Ashden CPT USA SJAFn'day, April 15, 2011 5:30 PMSweda, Michael Dr CIV USA MEDCOM WRAMCBenesh. Samantha MAJ MIL USA MEDCOM Momow JoDean, CPT USA Matthew kemkes; Bouchand, Paui CPT USCENTCOM USF-I Habedand. John CPT MIL USARE: US v. PFC BM-Update (UNCUKSSIFIED)RCM 706 Extension Approval (ManningB).pdfAttached is the approval of your request.v/rCPT FeinAshden FeinCPT, JA02221 723From:Sent:To:Cc:Subject:Sweda, Michael Dr CIV USA MEDCOM WRAMCSaturday, April 16, 20] I 8:30 AMFein, Ashden CPT USA SJA Benesh, Samantha MAJ MIL USA MEDCOM MAMCcoomb Qarmycourtmartia|defense.com; Morrow JoDcan, PT A - LDW SJA Matthew kemkesUSF-I Haberland, John CPT MIL USARE: US v. PFC BM?Update (UNCLASSIFIED) Classi?cation: UNCLASSIFIEDCaveats: NONESir'I1iaink you very much. This will pcnuil adequate time for full discussionMichael Swcda 02215352From: Sent: Monday, April 18, 201 1 1:05 PMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Morrow JoDean, CPT USASJA Bouchard, Paul CPTUSCENTCOM USF-I Haberland,John CPT MIL USACarlile, Monica L. SFC USA SJAeito, Beat?z SGT USA JFHQ- Subject: US v. PFC BM (Discovery)Ashden,I received the discovery 011574-012569 and 012570-012711. Along with this discovery, the CD had twoRTF ?les dealing with Intelligence Analyst Course - 243-35F10 (dated 28 Aug 2008) alongwith the 243-35F10 Version 1 Lesson Plans. I could not open the lesson plans (the 24.5MB document). were these two documents intended to be part of the discovery?Also, with regards to the FBI Joint Intelligence Bulletin (21 Nov 2010) and NCIS Bulletindetailing the publication of an English version of Inspire Magazine (Summer 2010,Winter 2010, and November 2010) - can you tell me why these documents wereprovided in discovery? What specific discovery request by the defense were thesedocuments in response to? what was the source of these documents?Finally, my office has been contacted by a CBS correspondent who says the 706 board has completed itswork and it will be served on the defense tomorrow. Is this person correct?Best,DavidDavid E. Coombs, Esq.Law Of?ce of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02884910From: Fein, Ashden CPT USA SJASent: Monday, April 18. 2011 3:24 PMTo: Cc: Matthew kemkes; Morrow |Il, JoDean, CPT USA Bouchard, PaulCPT USCENTCOM USF-I Habenand,John CPT MIL Carlile. Monica L. SFC USA JFHQ-NCRIMDW SJA: Feito, Beatriz SGT USA JFHQ-NCRIMDW SJA .Subject: RE: US v. PFC BM (Discovery)Attachments: Unclassi?ed Discovery (012712-012720) (ManningB).pdfDavid,1. files. The two ".rtf" files were original files that we provided intheir native form. we created BATES stamped of the files on the CD.The files should open, but they are very large, thus we created the PDFs tomake them easier to understand.2. FBI NCIS Publications. They were provided as part of our UNCLAS casefile. The Government endeavors to provide the defense with as muchinformation from our case file, as authorized, even if not under an expressrequirement under RCM 405 and later under RCM 701, Brady, etc; or based on aspecific defense request. The source of the documents are the assigned to each organization producing the report.3. CBS Correspondent. we have no additional information outside the emailchain from Dr. Sweda and the approving the extension.4. PFC BM's Uniforms. It is the command's understanding that your request forthe command to assist with obtaining new ACUs for PFC BM is already beingcoordinated through his aunt and Kemkes.5. Article 138 Endorsement. Attached is a copy of the Brig's endorsement toPFC BM's letter of 16 Apr 11. This was served lastweek.v/rAshdenAshden FeinCPT, JA 02212485From: omo Sent: Monday, April 18, 201] 5:20 PMTo: Fein, Ashden CPT USA SJ A Subject: RE: IRTF (UNCLASSIFIED)Classi?cation: UNCLASSIFIEDCaveats: NONEI am back and ready to discuss. You need to bring the CD5 here to thePentagon. The G2 has established a conduit through the JCS to get theCENTCOM reviews. 02215342 From: Sent: Wednesday, April 20, 201 I 9:37 AMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkes Morrow .loDean, CPT USASJA Bouchard, Paul CPTUSCENTCOM USF-I Haberland,John CPT MIL USACarlilc, Monica L. SFC USA SJAFeito, Beatriz SGT USA JFHQ- SJ ASubject: [Suspected st RequestAttach: Expert Request 2.pdfAshden,Please see the attached request for a replacement Also, do you know how the movewill affect obtaining new set of ACUs for PFC Manning? Finally, I have contacted the JRCF commander,LTC Dawn Hilton, to request to see PFC Manning on the 27th and 28th of April. I have not yet heard backfrom her, but I would appreciate any assistance that the government could offer in facilitating such a visit.Best,DavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-9282i 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02911638From: Fein, Ashden CPT USA SJASent: Wednesday. April 20, 2011 9:39 AMTo: Cc: Matthew kemkes; Morrow Ill. JoDean, CPT USA Bouchard, PaulCPT USCENTCOM USF-I HaberIand,John CPT MIL Carlile, Monica L. SFC USA Feito, Beatriz SGT USA JFHQ-SJASubject: RE: [Suspected RequestDavid,we will start working the issues ASAP. Please route your requests through us,so that we may ensure the meeting is scheduled and the right resourcing isavailable. Are you planning on going alone, or with members of the defenseteam?V/rAshdenAshden FeinCPT, JA021 88925From ?@ic-Msov>Sent: Wednesday, April 20, 2011 2:44 PM Subject: Follow-up to meeting: FBI OGC POC lnfoCPT Fein:Wanted to establish contact after yesterday's meeting. I believe it was useful for all to hear/understand the plan moving fowvardin this process.We suspect you will continue to work very closely with our Washington Field Of?ce, particularly in the initial ?le reviews I believeyou are looking to accomplish perhaps as early as Friday. We will work with those Case Agents to be sure we all understand whatinformation you are requesting so we can assess its availability as efficiently as possible, and classification as necessary.Our ?rst objective is to provide you access to the casefile materials to assist in discovery, but also to assist, perhaps, with the casein chief as you might present it at the 32 Hearing. We understand this may include more than just the present defendant's ?le.Additionally, we are expecting in the near future to be receiving a PSR-type letter that will requst a global search of our system ofWe appreciate your candor and look forward to working with you. Communication is certainly always a challeng with these largercases. In as much as you have deadlines and you can notify us of them and expected/desired actions on our part, we appreciatereaching-out any time as far in advance as you can as our "signature authorities" often have full calendars. Thanis. We look forward to working with you 02902170From: Fein, Ashden CPT USA SJASent: 11 9:57 AMCc: orrow JoDean. CPT USA SJASubject: RE: Follow-up to meeting: FBI OGC POC InfoThank you. Your email accurately summarizes our meeting. we would like tohave the green light For the initial case File r'eview?byTuesday o~F next week, so that we may start next Wednesday, if that is goodwith the NFO.Ashden Ashden FeinCPT, JA 02886351From: Fein, Ashden CPT USA SJASent: 2011 8:52 PMTo: (FBI)Cc: Morrow m, JoDean. CPT USA Overgaard,Angel M. CPT USA JFHQ-NCRIMDW USAUSACIDCsubject: UpdateI emailed about us coming over to wF0 and starting to go through thefiles. Hopefully we get the green light soon. If ok with ya?ll, we would like to startwednesday morning. It will likely be me, Joe, and our new attorney Angel Overgaard comingover?. Joe and Angel will stay and conduct the review. Please let me know what you think.02885186From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Thursda A til 21 2011 8:56 PMTo: Cc: USA Morrow Ill, JoDean, CPT USA JFHQ-NCRIMDWSJASubject: US v. PFC BMImportance: HighGents,Good evening. Could you please confirm the SJA office received our classified mail with theCENTCOM documents for the classification review and provide the date the office received thepackage through the CENTCOM mail process?Thank you.v/rCPT FeinAshden FeinCPT, JA02221719mm cw USA MEDCOM WRAMCSent: Friday, April 22. 201 1 9:49 AMTo: Fein, Ashden CPT USA SJAMorrow Ill. -'oDean. CPT USA SJ ASubject: RE: Email (UNCLASSIFIED)Classification: UNCLASSIFIEDCaveats: NONESirs:This (us.anny.mil) also won?t work. We are still ?nalizing the reports but will have by COB today. You can send someone over. or Icould deliver to the Pentagon. I enjoy getting out of the of?ce when I can and it is on the way home.One of our board members is in Texas. 1 spoke to her and we anticipate ?nalization of the rcpon by Noon localtime.Once again. thank you for your continued patience.02183858From: may USA |mus.army.mi|]Sent: Friday, April 22, 2011 12:07 PMTo: Fein, Ashden CPT USA SJACc: Morrow Ill JoDean, CPT USA Habenand, ?cIv usA;?cIv USA cw us USA MIL USASubject: RE: us v. PFC BM Update (UNCLASSIFIED)Signed By: ?usarmymilClassification: UNCLASSIFIEDCaveats: FOUOAshden,As you know, the Computer Crime Investigative Unit (CCIU), U.S. Army CIDCommand, is the lead agency for the criminal investigation related to PFCBradley Manning.Because the investigation is ongoing, CCIU requires the ability to monitor,within applicable legal authority, all non?privileged communications to andfrom PFC Manning. Specifically, we require the ability to monitor PFCManning's conversations with visitors and communications made via telephonecalls. with regard to mail, we understand that staff routinelyinspect non?privileged letters/packages and will notify us any anything ofpotential investigative value; however, we require additional informationregarding this process and are working with to obtain it.In addition,_because of PFC Manning's level of technical expertise withcomputers, coupled with the fact that the crimes for which charges have beenpreferred include illegal and grave misuses of Army computers, wespecifically request that he not be given access to the Internet in anymanner, either via email communications, cell phone or otherwise.Thanks,Computer Crime Investigative Unitu.s. Army CID"The Army's Digital Detectives? 02889160 From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Friday. April 22, 2011 12:39 PMTo: centcom.milSubject: Shot OverPlease let me know if you receive this email.Ashden Feincpr, JA 02225022From, MIL USAF USCENTCOM CCJA-SJA@centcom.mil>Sent: Friday, April 22, 20] I PMTo: Fein. Ashden CPT USA SJA Subject: RE: Shot OverReceived!To confirm received the 3 compact discs on/about 15 April 11. 7115 S. Boundary Blvd, MacDiIl AFB, FL 33621-5101DSNCom? 02225010From: SJAJUSF-I-JA-AL Sent: Saturday. April 23. 2011 7:55 AMTo: SA JFHQ-NCRIMDW SJACc: USA USF-I subject: RE: US v. PFC Manning RFIAttachments: Unclassed Action Memo.pdfAshden,I know you have likely given up on us, but attached is the (finally!)unclassified Action Memorandum For the Manning 15-6. To my knowledge, therewere no other classified markings in the AR 15-6 investigation, making theentire record now unclassified.OSJA 02884642From: Fein, Ashden CPT USA SJASent: A Saturday, April 23. 2011 9:38 AMTo: Cc: Matthew kemkes; Morrow JoDean, CPT USA Bouchand, PaulCPT USCENTCOM USF-I Haberland,John CPT MIL Cariile, Monica L. SFC USA SJA: Feito, Beatriz SGT USA JFHQ-NCRIMDW SJASubject: US v. PFC BM UpdateAttachments: 11-Apr-22 Excludable Delay Memorandum (ManningB).pdfDavid,Good morning. we are still working on identifying a in thevicinity of Fort Leavenworth. It is our understanding that you had all thequestions below answered by LTC Hilton, except 1. we are working on determining the means to have you sit down with yourclient and access classified information. below2. we are working on getting PFC BM's uniform situation worked out with thecommand.3. Attached is the most recent Excludable Delay Memo.Following this email, I will be sending MAJ Kemkes a copy of theshort form of the RCM 766 results. we are working on determining a way tosetup for your email, so that we can freely send emails back andforth while ensuring the proper security is in place.Have a good weekend.v/rAshdenAshden FeinCPT, JA02884834From:Sent:To:Cc:Subject:Attachments:Fein, Ashden CPT USA SJASaturday, April 23, 2011 9:50 AMMATTHEW KEMKES Bouchard. Paul R. CPT uso?cDSTB CO TDS Sr ense ounseMorrow JoDean. CPT USA SJA: Haberiand, John CPT USARegimental Judge Advocate; Ca?1iIe_ Monica L. SFC USA Feito,Beatriz SGT USA JFHQ- SJAUS v. PFC BM (Shott Form)11-Apr-22 Sanity Board Results Short Form (ManningB).pdfAttached is the short Form of the RCM 766 results.v/r?AshdenAshden FeinCPT, JA 02884552From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJA sent: Satunda A n! 23 2011 10:05 AMTo: ?usm Cc: USF-I OSJAIAFZA-JA-MJ: FHQ-Morrow Ill. JoDean, CPT USA SJASubject: RE: US v. PFC Manning RFIunponance: Sir,Thank you! This is a great help. After reviewing the investigation, itappears that there is still a reference that, although not classified, ismarked "Confidential". The reference is DIAR 56-27 - Disclosure ofCollateral Military According to the SecArmy 15-6investigators, the portion included in the USF-I investigation is notclassified because an enclosure to the regulation is classified and it wasnot included. Could you please confirm that this document is NOT classifiedand provide us documentation so that we may properly line outAlso, could you please provide us a copy of the COS Declassification Memo,23 Apr 11.Thank you again.v/rAshdenAshden Feincpr, JA02225002From: USA USF-I iraq.centcom.miI]Sent: Saturday, April 23, 2011 10:44 AMTo: SJACc: USA USF-I USF-I I J2 SSOSubject: RE: US v. PFC Manning RFIAttachments: Document.pdfAshden,As the ar not legal questions you are raising, I am going to place ourSSO, on the CC line so you can work directly with them. Based upon my review of DIAR 56-27, only the enclosures carry (C) markingsand they are not a part of the investigation file. However, I will defer tothe S50 determination on this matter.Attached is the declassification approval memo.USF-I OSJADSN:SVOIPNIPR:SIPR: 02884538From: Fein, Ashden CPT USA SJASent: Saturda A n'l23 2011 12:41 PM To: USF-I Cc: Morrow JoDean, CPT USAJFHQ-NCRIMDW SJASubject: RE: US v. PFC Manning RFISir,Thank you again. After we reviewed our classified copy, we realized that weneed to ensure what we print and scan into NIPR is in fact unclassified.Pursuant to our original request below, is it possible for ya'l1 to scan(high resolution) the original investigation onto NIPR and send it to us, toensure there is no spillage and because USF-I is the originating agencyunder the Executive Order. If that is not possible, then could you pleasesend us a list of all the documents that should be included in theinvestigation that are unclassified and we will go through the more than 175pages and ensure we are looking at exactly the same pages.Thank you.v/rAshdenAshden FeinCPT, JA02217354 Hom: @iraq.centcom.mil]Sent: 12:38 AMTo: A USF-I cc: Morrow JoDean, CPT USA JFHQ-NCRIMDW USN USF-IJ2 Chancery, Rm 2229; USA JFHQ-NCRIMDW Fein, Ashden CPT USA SJASubject: RE: US v. PFC Manning RFISigned By: -@iraq.centcom.mi|Follow Up Flag: Follow upFlag Status: Completed You are correct as to the determination of the DIAR 56-27. without theenclosures, the document is UNCLASSIFIED. If the plan is to keep the DIAR56-27 without the enclosures as part of the Files then I recommend statingon the Front and last page You are notdeclassifying or downgrading with that statement just displaying the Facts.Let me know if you need any Further assistance./rSr. !ecur1! Mana ement AdvisorDSN:COMM:SVOIP: 02224991From: USA USF-I iraq.centcom.mil]Sent: Sunday, April 24, 2011 7:09 AMTo: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASubject: FW: US v. PFC Manning RFIFollow Up Flag: Follow upFlag Status: CompletedAshden,Given?' response, I do not see where you need anything furtherfrom us. The classified information in the investigation was marked assuch.we deal with classified information here in theater every single day. Ithas never once dawned upon me or my shop that it is the responsibility ofthe original classifying authority to ensure we do not mishandle thatinformation.I am sure your electronic copy represents the limits of our scanner and datatransfer abilities. whatever you print from that copy likely reflects thequality of what we have available. NIPR scanners here are not commonplaceand have bandwidth restrictions that make your high resolution requestimpracticable.If you have a specific portion you think is illegible in your copy, let meknow what it is and I will try to locate the paper original to re-scan thatparticular portion. However, I have never seen the paper original of thisinvestigation, so I cannot guarantee the original is any better. USF-I OSJA 02886354From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Monda A ril 25 2011 1:27 PMTo: Cc: Morrow Ill, JoDean, CPT USA SJA Angel M. CPT USA Subject: RE: UpdateI hope you had a good weekend. Recognizing it was a long weekend, I neverheard back from you about the below email. will wed be good? Thanks.AshdenAshden FeinCPT, JAFrom: Fein, Ashden CPT USA SJASent: Thursday, April 21, 2611 8:52 PMTo: Ellsworth, Kevin D. (FBI)Cc: Morrow JoDean, CPT USA McGonigal, Charles Overgaard, Angel M. CPT USA Bettencourt, Troy MrCIV USA USACIDCSubject: UpdateKevin,I emailed Sally and Erik Dodson about us coming over to HFO and starting togo through the files. Hopefully we get the green light soon. If ok withya?1l, we would like to start Wednesday morning. It will likely be me, Joe,and our new attorney Angel Overgaard coming over. Joe and Angel will stayand conduct the review. Please let me know what you think.we met with the National Media Exploitation Center (NMEC) this week. Theyare going to help us with determining what information is out there to show"the enemy" is in receipt of the information. In order to help us, theyasked for certain information that I think you have in the files. Can youlet me know if you have this and if so, can we get it sooner than later so Ican pass it to them?1. The different URLs associated with wikileaks and the leakeddocuments028863542. Hash values for the actual documents released by wikileaks or anyof the other organizations wikileaks passed the information (if hash valueswere created, if not then we can do it if we can have #3 below)3. Digital copies of the native version of the wikileaks releaseddocuments4. Any unique identifying information from the wikileaks version ofdocumentsThanks.AshdenAshden FeinCPT, JA 02902190From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Monda A riI25, 2011 2:57 PMTo: Cc: Morrow JoDean, CPT USA JFHQ-NCRIMDW SJASubject: Re: Foilow-up to meeting: FBI OGC POC Info- He was deemed cmpetent and mentally responsible For his alleged misconduct.will we be good to start reviewing the wFo's Files on wed morning?Thanks.AshdenAshden FeinCPT, JA02188919 Sent: on ay, pn To: Fein Ashden CPT USA JFa)ic.fbi.gov>Cc:Subject: RE: Follow-up to meeting: FBI OGC POC InfoThanks.You're good to go review WFO's ?les. Please just coordinate with? et al about having the ?les available.02885072From:Sent:To:Cc:Subject:Attachments:Importance:Sir,Fein, Ashden CPT USA SJAMonday, April 25. 2011 4:44 PMCoffman, Carl COL MIL USAMatthew kemkes; Morrow JoDean, CPT USABouchard, Paul CPT USCENTCOM USF-I Habenand.John CPT MIL Canile. Monica L. SFC USA JFHQ-NCRIMDWFeito. Beatriz SGT USA JFHQ- SJAUS v. PFC BM (Art 32 Delay Request)11-Apr-25-Government Request to Delay Article 32 (ManningB).pdfHighThe United States requests a delay of the Article 32. Please see the attachedrequest. we delivered the enclosures to you and will send the defense aseparate email with the enclosures.v/rCPT FeinAshden FeinCPT, JA02217353 From:Sent: Monday, April 25, 2011 8:13 PMTo: Fein, Ashden CPT USA SJA Cc: Matthew kemkesMorrow JoDean, CPT USA Bouchard. Paul CPT USCENTCOMUSF- - Haberland,John CPT MIL USA Carlile, Monica L. SFCUSA SJAqncr.northcom.mxl>Subject: Re: US v. PFC BM (Art 32 Delay Request)Got it.Mr. Coombs.Please provide me your feedback on the request by COB 27 April.VRCOL Cari CoffmanSent via by 02884529From: Fein, Ashden CPT USA SJASent: Tuesda A il 26 2011 3:58 PMCc: Morrow Ill. JoDean. CPT USA JFHQ-SJASubject: RE: US v. PFC Manning RFIhnponance: Sir,Thank you. Is it possible for USF-I to send us the original investigation,with the front and last page of the DIAR enclosure marked WITHOUT If you can make a copy for the records and sendus the original, there will be no issue with readability and classificationon our end. Thank you.v/rAshdenAshden FeinCPT, JA 02884558From: Fein, Ashden CPT USA SJAsent: Tu A 2011 8:16 PMTo: DOD OGCCc: SJASubject: US v. PFC Manning DiscoveryGood evening. I am the lead prosecutor for the court-martial case of U.S. v. PFC Bradley E.Manning. Since the beginning, we realized there would be a significant discovery hurdle,similar to civil litigation cases, that we will have to overcome to ensure a military judgeis satisfied that we complied with our requirements under Rules for Courts-Martial 495 and701, Article 46 of the UCMJ, Brady, Giglio, and all other applicable case law. we have beenworking with our counterparts at Main Justice (Counterespionage Section, National SecurityDivision) to develop a request that combines a preservation request with a ?prudentialsearch? request.Are you available to discuss the dissemination of this type of request to ensure that we meetour requirements under the UCMJ and applicable case law and provide us any advice on the mostefficient way to obtain the information? At this point in time, we have ?reasonable belief?that most commands, agencies, directorates, etc. within DOD, and most other Federal agencies,have documentation surrounding Manning? and/or ?wikileaks.?Thank you.v/rAshden FeinAshden FeinCPT, JAl)02215317From: Sent: Tuesday, April 26, 20| I 9:08 PMTo: Cc: Matthew kemkes Morrow ll], JoDean, CPT USA SJAUSCENTCOM USF-I Haberland,John CPT MII. USACarlile, Monica L. SFC USA SJAFeito, Beatriz SGT USA JFHQ- Bouchard, Paul CPT SJA Fein, Ashden CPT USA SJA Subject: RE: US v. PFC BM (Art 32 Delay Request)Attach: Article 32 Delay.pdf; Attachment A.pdf; Attachment B.pdf; Attachment C.pdf;Attachment D.pdf; Attachment Epdf; Attachment F.pdfSir,Please see the attached feedback regarding the Government's delay request.v/rDavidDavid E. Coombs, Esq.Law Office of David E. Coombs11 South Angell Street, #317Providence, RI 02906Office: 1-800-588-4156Fax: (508) 689-9282Notice: 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 intendedrecipient, please notify the sender and delete all copies. Unauthorized disclosure, copying or use of thisinformation may be unlawful and is 02224983From: USF-I Earaq.centcom.minSent: Wednesday. April 27. 2011 2:34 PMTo: Fain, Ashden CPT USA SJASubject: RE: US v. PFC Manning RFIAshden,I am going to take this matter up directly with I see no openAdministrative Law actions in this matter.OSJADSN:SVOINIPRSIPR From: Fein, Ashden CPT USA SJASent: Tuesday, April 26, 2011 16:58 PMTo: Poche, Charles LTC USA Cc: Marton, Andras M. LTC USA Morrow JoDean, CPT USASJASubject: RE: US v. PFC Manning RFIImportance: HighSir,Thank you. Is it possible For to send us the original investigation,with the front and last page of the DIAR enclosure marked WITHOUT If you can make a copy for the records and sendus the original, there will be no issue with readability and classificationon our end. Thank you.v/rAshdenAshden FeinCPT, JA021 88674From ?@state?sov>Sent: Thursday, April 28, 2011 11:49 AMTo: Fein, Ashden CPT USA SJA Morrow JoDean, CPT USA SJACc= ?@stateagov>Subject: call? SENSITIVE BUT UNCLASSIFIEDAshden and Joe,Do you have time for a call wit.I"nd I sometime today or tomorrow?? We have a few things to discuss on theoutstanding requests with State the OCA declaration and valuation issues.I am tied up at 3pm today and around midday tomorrow, but otherwise relatively free. U.S. Department of State SBUThis email is UNCLASSIFIED.02907458From: Fein, Ashden CPT USA JFHQ-NCRIMDW SJASent: Frida A n'|29 2011 9:01 ATo: Cc: Morrow JoDean, CPT USA JFHQ-NC AI CIV CIV USA CIV USASubject: CID Case File and UpdateAttachments: Article 32 All,Good morning. This email serves two purposes. First, an update on the monitoring at theconfinement Facility. Second, an update on evidence and report disclosures to the defense.*Confinement Monitoring*He will be integrated into the pretrial population. The JRCF staff will add additional guardpresence (24 hours a day, 7 days a week) to ensure that the staff can closely monitor(literally hear) his interactions and communications with other prisoners. The visitationarea will be modified to provide for the monitoring and recording of all non?privilegedcommunications, both in person and telephonic. This modification will allow PFC BM to seevisitors in the same room that other pretrial prisoners use for visitation. The JRCF willinspect PFC BM's mail for contraband, similar to its current procedures of inspecting allprisoner mail sent to and from the general population. Additionally, CID will review PFCBM's mail for content to ensure that PFC Manning does not send or receive inappropriatecommunications that could cause the release of classified or sensitive information. The JRCFwill provide PFC BM access to the law library, which consist of a stand-alone computer (nointernet access) and CD for legal references. The JRCF staff will provide him with a stand-alone laptop with CD for set periods and under supervision of JRCF staff. The computer willonly be used by PFC BM, will be placed in a secure storage between use, and routinely scannedfor potential communication messages that might be saved to the hard drive. CID is alsogoing to the JRCF to start interviewing any other confinees and staff members that interactedwith him over the past week.?Evidence and Report Disclosures*CID finished ?finalizing? their 2d Interim Report and the Forensic Reports. we are now atthe point where we need to turn over these documents, in a controlled fashion, to thedefense. I would like to deliver a copy of all the documents to each office today (CES,EDVA, and FBI) in order to give you the opportunity to understand what we will turn over inthe coming weeks and to get your input on what information you would like us to temporarilywithhold based on the ongoing national security-threat and law enforcement investigations.02907458Just to reiterate from previous conversations, we have an obligation under the Rules forCourt-Martial (RCM) to give the Defense a copy of the information that forms the basis of thecharges, and any information in our possession that is mitigating of the crime, etc. Iattached an excerpt of RCM 405, with relevant portions highlighted. It is our position,absent an extraordinary need to withhold information (that we can clearly articulate andwhich falls within the rules), that we turn over all the documents on the DVDs to thedefense. iAs for the classified documents, we are still waiting on the consent approvals, under theapplicable Executive Orders, to allow the defense to start viewing the information. we havereceived all but one consent (ODNI) to turn over the evidence in a classified forum.Separately, we are still working the issue with OGA, Dos, and ODNI.If someone from your office is available today, I would like to bring the DVDs over after1pm. I also ask that you can get back to us by 5pm on Monday, 9 May 11. The password forthe unclassified DVD is v. PFC Bradley Manningl? (without the quotations and includingthe spaces)Thank you.v/rAshdenAshden FeinCPT, JA02902889From: Fein, Ashden CPT USA SJASan: To: Cc: Feito, Beatriz SGT USA SJASubject: DVDsCould you please email me an acknowledgment that you received, from CPT Morrow, the followingDVDs today:CID Case 0928-10-CID221-10117Forensic ReportsDisk 1 of 3CID Case 0628-16-CID221-19117Forensic ReportsDisk 2 of 3CID Case 0628-16-CID221-18117Forensic ReportsDisk 3 of 3CID Case Classified Case FileDisk 1 OF 1Thank you.v/rCPT Fein02902889Ashden FeinCPT, JA021 86942From:Sent:To:Cc:Subject:@ic.fbi.g0vT> Friday, April 29. 20! I 9:56 AMFein. Ashden CPT USA SJA Feim Reatri7 QGT I IFHO- QlYes, received all of the below DVDs.FBI Washington Field Officeoffice:mobile02892595From: Fein. Ashden CPT USA SJASent: Frida A ril 29, 2011 11:54 AMTo: USA Marton, Andras M. LTC USA Cc: Morrow Ill. JoDean. CPT USA 'Whyte, Jeffrey CPT MIL US Overgaard, Angel M. CPT USA SJASubject: Prudential Search RequestAttachments: Policy Procedure Memo 9 29 1000O2.pdlS?gned|3y:Gents,Attached is the DAG (D03) policy and explanation on the PSR (Prudential Search Request).This is a very informative document (although explaining the case law andrequirements they have in place. we are using this as a base reference and have alreadystarted creating our own version of this document under military case law. Also, the requestwe intend to send up to NSC and the white House, out to other Executive Departments, andthroughout is a combination of this PSR and a preservation request (commonly used incivil litigation cases). we have been working with CES, D0) to craft our hybrid memo and allour Partner Agencies are waiting for the requests.I am available anytime to discuss. Thank you.v/rAshden02892595Ashden FeinCPT, JA02903200From: Fein, Ashden CPT USA SJAsent: Frida A ril 29 2011 12:01 PMTo:Cc: Morrow JoDean. CPT USA SJAsubject: Draft PSRAttachments: DRAFT PSR.pdfAttached is the DRAFT PSR and Preservation request we chatted about. I intend to get theseout by wed of next week.Thanks for the phone call today. we owe you an initial breakdown of the valuation issue andwill get that to you by wed as well.AshdenAshden FeinCPT, JA 02188671Sent: Friday, April 29, 2011 12:04 PMTo: Fein Ashden CPT USA IFH SJA @state.gov>Cc: Morrow JoDean, CPT USA SJASubject: RE: Draft PSRThanks Ashden, and thanks for walking through things with us on the call today. I?m looping ir? so that youhave his contact info and will send him the draft se arately. Joe, as I mentioned to Ashden on the hone, l?ll be starting anew position as for the next year or so. My colleague?, will be takingover my responsibilities in Its been great working with you guys over the last several months, and you the best ofluek with this case. I?msure I'll continue to follow it in my new assignment, as well.Best!ttorney !!VlS?l'Of?ce of the Legal AdviserLaw Enforcement and Intelligence U.S. Deiartment of StateSBUThis email is UNCLASSIFIED.02885063From:Sent:T