Title: Updated Gov Wit List with Explanations, 15 Oct 12

Release Date: 2014-03-20

Text: UNITED STATES OF AMERICAv. Updated Prosecution Witness ListPFC, U.S. Army,HHC, U.S. Army Garrison,Joint Base Myer-Henderson HallFort Myer, Virginia 22211Manning, Bradley E. 15 October 2012The prosecution may call the below witnesses to testify on the merits at trial and/or duringthe presentencing phase' of the above-captioned court-martial. After each witness name is abrief description of the general substance of witness testimony, including whether theprosecution currently intends to elicit classi?ed information during their testimony.I. CDR Youssef Aboul-Enein, Defense intelligence Agency, Bolling AFB, DC, 20032,He will testify about enemies of the United States, including classi?edinformation.2. SFC Paul Adkins, 10th Mountain Division Fort Drum, - He will testify about the accused's training, activities, and duties. 5. Mr. Maxwell Allen, Central Intelligence Agency, McLean, VA, 22101, POC: Ms.Jennifer M., He will testify as to the authenticity of the OSC logs.6. SPC Mary Amiatu, Camp Arifjan, Kuwait, APO AE, 09306, DSN: She will testify as to the authenticity of the JAMMS records. 8. SFC Jose Anica, Headquarters and Headquarters Company (HHC), National GroundIntelligence Center (NGIC), Charlottesville, VA, 22911,- He willtestify about the accused's intelligence systems training and the accused's activities at2/10, including potential classi?ed information.9. Mr. Peter Artale, 902d MI Group, Fort Meade, MD, 20755, He willtestify as to the authenticity of the ACIC logs, including classi?ed infomiation.As of the date of this ?ling. persons identi?ed with an asterisk are witnesses only for purposes of theHz .-.aitT 1PAGE 1 PAGE 01: mossFOR OFFICIAL USE BUT UNCLASSIFTED 10.ll.13.15.l6.l7.18.20.21.FOR USE BU1 UNCLASSIFIEDSPC Eric Baker, .He will testify about the accused's activity in his CHU and the accused's activities at2/10.SPC Kimberly Bales, Headquarters and Headquarters Company (HHC), 2nd BrigadeCombat Team (ZBCT), 10th Mountain Division (LI), Fort Drum, She will testify about her deployment with the accused and the duties of a35F, including classified information.W01 Kyle Balonek, Headquarters and Headquarters Company (HHC), Headquartersand Headquarters Battalion (HHBN), 10th Mountain Division (LI), Fort Drum, NY,13602 . He will testify about the requirements of being a 35F, theaccused's duties and work product, including classi?ed information. Mr. Joseph Benthal, Watertown, NY . He will testify about therequirements for access to government systems at 10th Mountain Division.SA Troy Bettencourt, U.S. Department of Treasury, Washington. DC, 20220,He will testify about the IA training the accused received, authenti on ofmultiple pieces of evidence, and the information that the accused leaked to Wikilreaks,including classified information.SSG Peter Bigelow, US Army NATO, Allied Forces Command South, Naples, Italy,FPO AE, 09620, He will testify about the accused's duties in thesupply room and the accused's access to computer systems.Mr. Wyatt Bora, Air Force Research Laboratory, Rome, NY, l3440_?.He will testify about the CIDNE database, its value, and how it appeared at a particulartime, including classified information. Mr. Steve Buchanan, Intclink, Fort Meade, MD, 20755, . He willtestify as to the authenticity of the Intelink logs, including classified information.BG (Ret.) Robert Carr, Defense Intelligence Agency, Bolling AFB, DC, 20032,He will testify at sentencing about the impact on the Department ofDefense, including classified information. Mr. Sean Chamberlin, 902d Ml Group, Fort Meade, MD 20755,?. Hewill testify about how the ACIC logs, including classified information.2FOR OFFICIAL USE BUT UNCLASSIFIED22.23.24.25.26.27.28.29.30.31.32.33.FOR OFFICIAL USE BUT UNCLASSIFIEDCPT Thomas Cherepko, NATO Force Command, Madrid, Spain, 28223, --2 He will testify about the 2/10 Mountain share drive and its contents, as well asthe requirements to access it.Col Julian Chesnutt, Defense Intelligence Agency, Bolling AFB, DC 20032:He will testify at sentencing about the impact on a specific AOR within theDepartment of Defense, including classi?ed information.SA Charles Clapper, Arizona Branch Office - Computer Crime Investigative Unit, FonHuachuca, AZ, 85613, He is a chain of custody witness.Mr. Domingo U. Conlu, US Army Human Resources Command, Fort Knox, KY,40122, He will testify as to the authenticity of the accused's OMPF.SGT Lorena Cooley, Headquarters and Headquarters Company (HHC), 2nd BrigadeCombat Team (2BCT), 10th Mountain Division (LI), Fort Drum, NY, 13602,She will testify about the accused's work product and the accused'swithin 2/10, including classi?ed information.tiviticsMs. Elizabeth Dibble, Principal Deputy Assistant Secretary, Bureau of Near EasternAffairs, Department of State, Washington DC, 20520, POC: Mr. Jonathan Davis?Ms. Elizabeth O'Connor, She will testify at sentencinabout the impact to Near Eastern Affairs, including classified information.Mr. Vann Van Diepen, Acting Assistant Secretary, Bureau of International Securityand Nonproliferation, Department of State, Washington DC, 20520, POC: Mr.Jonathan Davis, Ms. Elizabeth O'Connor, . He willtestify at sentencing about the impact to International Security, including classifiedinformation.RADM Kevin Donegan, Director, Naval Warfare Integration, Pentagon, Washington,DC, POC: LT Will Chapman, He will testify at sentencing about theimpact on operations within the USCENTCOM AOR, including classified information.Mr. Jim Downey, Defense Information Systems Agency, Fort Meade, MD, 20755,He will testify about Centaur logs, including potentially classifiedinformation.SA Antonio Edwards, Homeland Security Investigations, National Security Unit,Atlanta, GA 30301, He is a chain of custody witness.3FOR OFFICIAL USE BUT UNCLASSIFIED34.37.38.39.40.41.42.43.45.46.FOR OFFICIAL USE BUT UNCLASSIFIEDSA Kirk Ellis, Rock Island Fraud Resident Agency, Major Procurement Fraud Unit,Moline, IL, 61265, He is a chain of custody witness.Mr. John Feeley, Principal Deputy Assistant Secretary, Bureau of Western HemisphereAffairs, Department of State, Washington DC, 20520, POC: Mr. Jonathan Davis, - Ms. Elizabeth O'Connor, He will testify about the con of cables originating from and sent to the Western Hemisphere on the merits and theimpact to Western Hemisphere Affairs on sentencing, including classi?ed infonnation.Matthew Freeburg, Fort Sill, OK, 73503, He will testify aboutthe accused's activities while deployed.CPT Casey Fulton (formerly Martin), 2nd Brigade Combat Team (2BCT), l0thMountain Division Fort Drum, NY, 13602, . She will testify aboutthe the accused's training, duties, and work product. including classi?ed information.Mr. James Fung, Brookhaven National Laboratory, Upton, NY, I 1973-.He is a chain of custody witness.Ms. Shelia Glenn, Fort Meade, MD, 20755, She will testify about aDepartment of the Army classi?ed charged document, including classi?ed information.SA Toni Graham, Hawaii CID Of?ce, I314 l.yman Road. Building 3026, Scho?eldBarracks, HI, 96857, She will testify about the law enforcementinvestigation in Iraq.Mr. Jacob Grant, USCENTCOM, MacDill AFB, FL, 33621,testify about the USCENTCOM server logs, including potentially classi?edinformation.. He willAMB Kenneth Gross, Deputy Director, Of?ce of Career Development andAssignments, Bureau of Human Resources, Department of State, Washington DC,20520, POC: Mr. Jonathan Davis,? Ms. Elizabeth O'Connor,@He will testify at sentencing about impact to South and Central AsAffairs, including classi?ed information.CW3 Hondo llack, Joint Multinational Readiness Center, Hohenfels MilitaryCommunity, Germany, APO AE, 09173, He will testify aboutthe accused's work product, including classi?ed information. FOR OFFICIAL USE BUT UNCLASSIFIED47.48.49.50.51.52.53.FOR USE UNCLASSIFIEDVADM Robert Harward, USCENTCOM, MacDill AFB, FL, 33621, USCENTCOMOSJA, He will testify as an original classi?cation authority (OCA)that charged information was properly classi?ed, including classified information.Mr. Ben Henwood, Senior System Administrator, USCENTCOM Intelligent SoftwareSolutions, Inc., Tampa, FL, 33609_. He will testify about the CIDNEdatabase, including potentially classified information.Mr. John Hodges, Senior Technician, USCENTCOM Intelligent Software Solutions,Inc., Tampa, FL, 33609, He will testify about the CIDNE database,including potentially classi?ed information.Mr. Patrick Hoeffel, Intelligent Software Solutions, Inc., 2001 Jefferson Davis Hwy,Suite 909, Arlington, VA, 22202, . He will testify about the CIDNEdatabase, including potentially classified information.Ms. Mary Horvath, Forensic Examiner, Federal Bureau of Investigation, Washington,DC, 20535, . She will testify about her forensic analysis of digitalmedia, not belonging to the accused, including classified information.Mr. Matthew Hosburgh, Westminster. CO 80021, He will testifyabout the C3 document.L'l" (US Navy) Thomas Hoskins, USCENTCOM, MacDill AFB, FL, 33621, --2. He will testify about the content of charged documents containing J5information, including classified information. 57.58.59.Ms. Elisa K. (Rubin) Ivory, S2 OIC, 305th Military Intelligence Battalion, US ArmyIntelligence Center and Center of Excellence, Fort Huachuca, AZ, 85613, 2 She will testify concerning requirements of being a 35F.Mr. Albert J. Janek, Director, Office of Continuity, Department of State, WashingtonDC, 20520, Duty Station: U.S. Embassy, Kabul, Afghanistan, POC: Mr. JonathanDavis, Ms. Elizabeth O'Connor, He will testifyabout the authenticity and chain of custody of the server logs. FOR OFFICIAL USE BUT UNCLASSIFIED60.61.62.65.66.67.68.69.FOR OFFICIAL USE BUT UNCLASSIFIED Mr. Mark Johnson, Digital Forensics and Research Branch, Computer CrimeInvestigative Unit, Quantico, VA, 22134, (- He will testify about hisforensic analysis of the accused's digital media, including classi?ed information.AMB Patrick F. Kennedy, Under Secretary for Management, Department of State,Washington DC. 20520, POC: Mr. Jonathan Davis, Ms. ElizabethO'Connor, He will testify on sentencing about the impact to theDepartment of State, including classified information. Mr. John Kirchhofer, Chief of Enterprise Strategies, Of?ce of Counterintelligence(CI) Human Intelligence (HUMINT) Enterprise Management, DefenseCounterintelligence and Human Intelligence Center, Defense Intelligence Agency,Bolling AFB, DC, 20032, He will testify in sentencing about theimpact to the Department of Defense, including classified infonnation.AMB Michael Kozak, Senior Adviser, Bureau of Democracy, Rights and Labor,Department of State, Washington DC 20520, POC: Mr. Jonathan Davis, 2/ Ms. Elizabeth O'Connor, 1 He will testify on sentencing aboutthe impact on individuals classi?ed as persons at risk by the Department of State,including classified information. This testimony will n_ot include PII of any speci?cindividual.Mr. Adrian l.amo, Carmichael. CA 95608. . He will testify regardinghis digital chat with the accused. The United States does not intend to elicit anyclassi?ed information contained within the digital chat log.CW5 Jon I.arue, Pentagon, DC, 20310, He will testifyabout the content of the Apache Video.Mr. Danny J. Lewis, Defense Intelligence Agency, Bolling AFB, DC, 20032, He will testify about countciintelligence and the value of informati including classi?ed information.CPT Steven I.im, HQ, Army Division-East, Fort Meade, MD, 20755, --. He will testify about the Mountain share drive and its contents, theaccused's training and duties, including potentially classi?ed information. 6FOR OFFICIAL USE BUT UNCLASSIFIED70.71.72.73.74.75.76.77.78.79.80.81.FOR USE UNCLASSIFIEDMr. Randall MacRobbie, Defense Intelligence Agency, Bolling AFB, DC, 20032,He will testify at sentencing about a specific category of impact on theUnited States Government and the Department of Defense, including classifiedinformation.SGT Chad Madaras, Bravo Company (B Co), 2nd Brigade Special Troops Battalion (2BSTB), 2nd Brigade Combat Team (2 BCT), 10th Mountain Division (LI), Fort Drum,NY, 13602, He will testify about the 35F training, 2/10 pre-deployment training, and the use of his SIPRNET computers while deployed, includingpotentially classi?ed information.Mr. Brian Madrid, 21057 W. Western Dr. Buckeye, AZ, 85326,? Hewill testify about the accused's training at AIT.Ms. Tamara Mairena, Headquarters, Computer Crime lnvestigative Unit, Quanticochain of custody witness.SA Mark Mander, Washington Metro Resident Agency, Computer Crime lnvestigativeUnit, Quantico. VA, 22134, (-3. He will testify about Wikileaksoperations, the investigation of the accused, and certain enemies of the United Statesbeing in possession of information, including classified information.SGT Alejandro Mann, 800th MP Brigade, Uniondale, NY, 11553, Hewill testify about the accused's training at *Gen. James N. Mattis, Commander, USCENTCOM, MacDill AFB, FL, 3362],USCENTCOM OSJA, He will testify at sentencing about the impacton USCENTCOM, including classified information.Mr. James McCarl, Chief, Mission Integration Division, Joint IED DefeatOrganization (JIEDDO), Army Pentagon, Washington DC, 203l0,?. Hewill testify on sentencing about impact concerning IEDS, including classifiedinformation.Mr. Vince McCarron, HQDA (3-2, Washington, DC, 20310, He willtestify about the DCGS-A system, including potentially classified information. FOR OFFICIAL USE BUT UNCLASSIFIED82.83.84.85.86.87.88.89.90.92.93.FOFI OFFICIAL USE BUI UNCLASSIFIEDMajGen Kenneth McKenzie, USMC HQ Staff, Washington DC, POC: Maj ArumHan, He will testify at sentencing about the impact on strategicplanning within the USCENTCOM AOR, including classified information.Mr. James McManus, Brookhaven National Laboratory, Upton, NY, I 1973, 2 He is a chain of custody witness.COL David Miller, BDE Modernization Command, Ft. Bliss, TX, Hewill testify about the accused's misconduct and multiple investigations.Mr. Jason Milliman, 262 Jefferson Drive West, Palmyra, VA, 22963,He will testify about the accused's access to including potentially classi?edinformation.Mr. James Moore, Deputy Assistant Secretary, Bureau of South and Central AsianAffairs, Department of State, Washington DC, 20520, POC: Mr. Jonathan Davis:Ms. Elizabeth O'Connor, He will testify about the contentof cables originating from South and Central Asia on the merits, including classifiedinformation.Mr. Ken Moser, USCENTCOM, MacDilI AFB, FL, 33621, . He willtestify about the information posted to the USCENTCOM OSJA SIPRNET website,including potentially classified information.Mr. Jeffery Motes, JTF-GTMO, Guantanamo Bay, Cuba, He willtestify about the JTF-GTMO database and the contents of compromised information,including classified information.Mr. Troy Moul, US Army Intelligence Center and Center of Excellence, FortHuachuca, AZ, 85613, He will testify about instructing the accused atAIT.Mr. Kin Moy, Deputy Assistant Secretary, Bureau of East Asian and Pacific Affairs,Department of State, Washington DC, 20520, POC: Mr. Jonathan Davis,-Ms. Elizabeth O'Connor, He will testify on sentencing aboutthe impact on East Asian and Pacific Affairs, including classified information.Mr. Gerald Mundy, Information Systems Security Officer, Bureau of Intelligence andResearch, Department of State, Washington DC, 20520, POC: Mr. Jonathan Davis,I Ms. Elizabeth O'Connor, He will testify about theauthenticity and chain of custody of the firewall logs, including potentiallyclassi?ed information.8FOR OFFICIAL USE BUT UNCLASSIFIED94.95.96.97.98.99.I00.l0l.103.104.FOR OFFICIAL USE BUT UNCLASSIFIEDMr. Nicholas Murphy, Reviewer, Of?ce of Global Information Services, Bureau ofAdministration, Department of State, Washington DC 20520 (When ActuallyEmployed), POC: Mr. Jonathan Davis, Ms. Elizabeth O'Connor,6. He will testify as an OCA that Department of State information wasproperly classi?ed, including classi?ed information.MG Michael Nagata, Joint Staff, the Pentagon, Washington, DC, POC: LTC PatrickO'Hara, He will testify at sentencing about the impact on a speci?cAOR, including classi?ed information.Lt Col (R) Martin Nehring, USCENTCOM, MacDill AFB, FL, 33621, He will testify about the content of charged documents containing J3 information,including classi?ed information.CW4 Ronald Nixon, ARCYBER, Fort Belvoir, VA, He will testifyabout the USF-I GAL.SGT Daniel Padgett, Fort Leavenworth, KS, 66027, (209_ He will testifyabout the accused's training and duties and his interactions with the accused whiledeployed, including potentially classi?ed information.AMB David Pearce, Deputy Assistant Secretary and Senior Deputy SpecialRepresentative for Afghanistan and Pakistan, Bureau of South and Central AsianAffairs, Department of State, Washington DC 20520, POC: Mr. Jonathan Davis?Ms. Elizabeth O'Connor, He will testify about the co ntof cables originating from Afghanistan and Pakistan on the merits, including classi?edinformation.Mr. H. Dean Pittman, Principal Deputy Assistant Secretary, Bureau of lntemationalOrganization Affairs, Department of State, Washington DC, 20520, POC: Mr.Jonathan Davis,?/ Ms. Elizabeth O'Connor, He willtestify about the content of cables originating from International Organizations on themerits. including classi?ed information.Lt Col Robert Pope, USCENTCOM, MacDill AFB, FL, 33621, . Hewill testify on sentencing about the impact on USCENTCOM within the AOR,including classi?ed information. 9FOR OFFICIAL USE BUT UNCLASSIFIEDFOR OFFICIAL USE UNCLASSIFIEDI05.106. 107. LTC Rodney Roberts, USCENTCOM, MacDill AFB, FL, 33621,He will testify on sentencing about the impact on operations in Iraq, includingclassified information.I08. SA Calder Robertson, Europe Branch Office - Computer Crime Investigative Unit,Funari Barracks, APO AE, 09008, DSN: He will testify about hisforensic analysis of the accused's digital media, including classified information.109.I 10. SA Ronald Rock, Assistant Regional Security Officer, Diplomatic Security Service,Department of State, Washington DC, 20520, Duty Station: Consulate, Mazar-e-Shan'f,Afghanistan, POC: Mr. Jonathan Davis, Ms. Elizabeth O'Connor,. He will testify about the chain of custody of the ?rewall andserver logs, as well as the impact of the compromise on the US Embassy at Reykjavik,including classified information. I I2. CW4 Armond Rouillard, G33, US Army Network Enterprise Technology Command,Ft. Belvoir, VA, 22060?. He will testify about the US Army computersystems, including their values, including potentially classified information.I I3. SGT David Sadtler, 709th Ml BN, Harrogate, UK, APO AE, 09468, DSN:- He will testify about his interactions with the accused at 2/10 Mountain and theaccused's activities during their deployment, including potentially classi?ed material.1 14. Mr. Doug Schasteen, Wilco Technologies, lnc., 4125 Broadway, Suite 200, KansasCity, MO, 64106, He will testify about the authenticity of theaccused's annual Information Awareness training.I 15. Ms. Jacqueline Scott, USCENTCOM, MacDill AFB, FL, 33621, _Shewill testify about the response to the FOIA request for the Apache video, includingpotentially classified material.I I6. AMB Stephen Seehe, Deputy Assistant Secretary, Bureau of Near Eastern Affairs,Department of State, Washington DC, 20520, POC: Mr. Jonathan Davis,2/ Ms. Elizabeth O'Connor, He will testify about the content ofcables originating from the Near East on the merits, including classified information.I0FOR OFFICIAL USE BUT UNCLASSIFIEDFOR USE BUT UNCLASSIFIED1 17. SA David Shaver, US. Department of Treasury, Washington DC 20220, --2 Ile will testify about his forensic analysis of the accused's digital media andinformation posted to WikiLeaks, including classified information.I 18. Ms. Jihrleah Showman . She will testify aboutthe training the accused received before deployment, the accused's statements andactivities before deployment, their duties during deployment and the accused's activitiesduring deployment, including potentially classi?ed information.119. 120. SA Thomas Smith, USACIDC, Fort Gordon, GA, 30905, He willtestify about the investigation in Iraq.121.122. I23.I24.125. Ms. Strobl, Central Intelligence Agency, McLean, VA 2210], POC: Ms.Jennifer M., She will testify to the authenticity of the CIA Wire logs.I26. Ms. Susan Swart, former Chief Information Officer, Bureau of Information ResourceManagement, Department of State, Washington DC 20520. POC: Mr. Jonathan Davis,Ms. Elizabeth O'Connor, She will testify atsentencing about the impact to information systems at the Department of State,including potentially classified information.127. I28. Ms. Tasha Thian, Agency Records Officer, Office of Global lnfomiation Services,Bureau of Administration, Department of State, Washington DC 20520, POC: Mr.Jonathan Davis, Ms. Elizabeth O'Connor, -. She will11FOR OFFICIAL USE BUT UNCLASSIFIED129.130.131.I32.I33.I35.136.137.138.I39.FOR USE BUT UNCLASSIFIEDtestify to the authenticity of Department of State documentation, including potentiallyclassified information.SSG Robert Thomas, Headquarters and Headquarters Troop, Support Squadron, 3dACR, Fort Hood, TX, He will testify about the training received atAIT..HeMs. Louis Travieso, USCENTCOM, MacDill AFB, FL, 3362],will testify about the content of charged documents containing J2 information,including classi?ed information. AMB Shari Villarosa, U.S. Ambassador to Mauritius, Department of State,Washington DC, 20520, Duty Station: U.S. Embassy Port Louis, Mauritius, POC: Mr.Jonathan Davis?/ Ms. Elizabeth O'Connor, She willtestify on sentencing about impact to the counter terrorism effort, including classifiedinformation. . Mr. Greg Weaver, Compliance Branch Chief, US Army Cyber Command, Ft. Belvoir,VA, 22060 G36 Compliance Division, He will testify aboutinformation assurance.Ms. lorinda White, CERDEC Software Engineering Directorate. Aberdeen ProvingGround, MD, 21005, She will testify to the authenticity of documentation.SA John Wilbur, Department of Treasury, Washington, DC, 20220, He is a chain of custody witness.SA Alfred Williamson. Digital Forensics and Research Branch, Computer CrimeInvestigative Unit, Quantico, VA, 22134, He will testify about hisforensic analysis of the accused's digital media.Mr. Charlie Wiseean/er, Bureau of lnfomiation Resource Management, Department ofState, Washington DC, 20520 (When Actually Employed), POC: Mr. Jonathan Davis,Ms. Elizabeth O'Connor, . He will testify about theNCD system, including potentially classi?ed information.Mr. Alex Withers, Brookhaven National Laboratory, Upton, NY, I I973, (-2. He is a chain of custody witness.12FOR OFFICIAL USE BUT UNCLASSIFIEDFOR USE UNCLASSIFIED140. RADL David Woods, Commander, JTF-GTMO, Guantanamo Bay, Cuba, POC: CDRT. Welsh. -. He will testify as an OCA that JTF-GTMO information wasproperly classi?ed, including classi?ed information.14]. AMB Don Yamamoto, Principal Deputy Assistant Secretary, Bureau of AfricanAffairs, Department of State, Washington DC, 20520, POC: Mr. Jonathan Davis, rgMs. Elizabeth O'Connor, He will testify about the coof cables originating from Africa on the merits, including classi?ed information.142. Mr. Garon Young, Headquarters, Computer Crime Investigative Unit, Quantico, VA,22134, He is a chain of custody witness.143. AMB Marie Yovanovitch, Principal Deputy Assistant Secretary, Bureau of EuropeanAffairs, Department of State, Washington DC, 20520, POC: Mr. Jonathan Davis,-Ms. Elizabeth O'Connor, She will testify about the contentof cables originating from or sent to Europe or Eurasia on the merits, includingclassi?ed infonnation.I44. Mr. Joseph Yun, Principal Deputy Assistant Secretary, Bureau of East Asian Affairs,Department of State, Washington DC, 20520, POC: Mr. Jonathan Davis, Kl Ms. Elizabeth O'Connor. He will testify about the content ofcables originating from East Asia and the Pacific on the merits, including classifiedinformation.Several of these witnesses may become unnecessary depending on the outcome ofsubsequent Court rulings. The prosecution may add witnesses to this list, depending on theoutcome of subsequent Court rulings, to include those relating to Military Rule of Evidence(MRE) 505 and any witnesses relating thereto. The prosecution may replace witnesses on thislist, should it become necessary due to a Pennanent Change of Station, job relocation, change injob position, or change in level of security clearance of a listed witness.The prosecution acknowledges an ongoing obligation to provide the defense promptnotice of any other potential witnesses that come to its attention and will adhere to the localrules. The prosecution will communicate its final witness list according to Rule 2.1.8 of theRules of Practice before Army Courts-Martial (2012) and the Court's order.If the defense intends to produce a witness who is listed above, the defense must providea separate, appropriate request for that witness in accordance with Rule for Courts-Martial(RCM) 703 and the standard aniculated in United States v. Rockwood, 52 M.J. 98, 105 (1999)that a witness request include a ?synopsis of expected testimony,? not merely a list of topics tobe covered. If necessary for a particular witness employed by the United States Government, thedefense shall also comply with 5 U.S.C. 301 and Touhy v. Ragen, 340 U.S. 462 (I951).13FOR OFFICIAL USE BUT UNCLASSIFIED FOR OFFICIAL USE UNCLASSIFIEDASHDEN INMAJ, ATrial CounselEnclosureClassi?ed Supplement to Witness ListI certify that I served or caused to be served a true copy of the above on Mr. DavidCoombs, Civilian Defense Counsel via electronic mail, on 15 October 2012.klASHDEN FEINMAJ, ATrial Counsel14FOR OFFICIAL USE BUT UNCLASSIFIED

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