Category Archives: Barack Obama

Barack Obama

Julian Assange mom deleted Twitter Tweets, Mrs. Christine Assange, Wikileaks leaked DNC docs, “Its the duty of media to inform citizens about corruption”

Julian Assange mom deleted Twitter Tweets, Mrs. Christine Assange, Wikileaks leaked DNC docs, “Its the duty of media to inform citizens about corruption”

“Let me tell you something. They were all over that woman,”
“And it was the type of stuff we ran into with the outfit (the Chicago mob). Intimidation just by watching her, making their presence known. … Just to let her know ‘We can do what we want.’ ”…Attorney David Schippers, Clinton investigator

“I know that Seth Rich was involved in the DNC leak.”…Kim Dotcom

“Burkman said in an interview that he considered Selig like a brother and was badly shaken by his friend’s death.”
“The tragically ironic part is Glenn’s last words to me were, ‘Be careful,’” Burkman said. “It’s just a tragedy — terrible.””…Politico Jan. 24, 2018

 

The reader can draw their own conclusions.

Google search:

@assangemrs Its the duty of media to inform citizens about corruption

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Clicked on cached.

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Judge Amit Mehta ruling FBI Steele Dossier, James Madison Project v Department of Justice, Nunes and Schiff Memos constitute public acknowledgement of existence of records

Judge Amit Mehta ruling FBI Steele Dossier, James Madison Project v Department of Justice, Nunes and Schiff Memos constitute public acknowledgement of existence of records

“If This Story Gets Out, We Are Screwed”…Wikileaks: Doug Band to John Podesta

“James Comey’s decision to revive the investigation of Hillary Clinton’s email server and her handling of classified material came after he could no longer resist mounting pressure by mutinous agents in the FBI, including some of his top deputies, according to a source close to the embattled FBI director.”…Daily Mail October 30, 2016

“We are being lied to on a scale unimaginable by George Orwell.”…Citizen Wells

 

 

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
_________________________________________
)
JAMES MADISON PROJECT, et al., ))
Plaintiffs, ))
v. ) Case No. 17-cv-00144 (APM)
)
DEPARTMENT OF JUSTICE, et al., ))
Defendants. )
_________________________________________ )
INDICATIVE RULING AND ORDER AS TO PLAINTIFFS’
MOTION FOR RECONSIDERATION
Once more, this court is called upon to opine on the legal consequences of President Donald J. Trump’s declassification of information concerning the “Dossier”—the 35-page compilation of memoranda prepared by former British intelligence officer Christopher Steele concerning Russian efforts to influence the 2016 presidential election and alleged ties between Russia and then
candidate Trump. Cf. BuzzFeed, Inc. v. U.S. Dep’t of Justice, Case No. 17-mc-02429-APM, 2018 WL 3719231 (D.D.C. Aug. 3, 2018). In this case, the court must decide whether the February 2018 public release of two congressionally drafted memoranda—popularly known as the “Nunes Memo” and the “Schiff Memo”—vitiates Defendants’ Glomar responses to Plaintiffs’ demand for
records concerning a “two-page synopsis” of the Dossier.

The court initially granted summary judgment in favor of Defendants. See generally James Madison Project v. Dep’t of Justice (“James Madison I”), 302 F. Supp. 3d 12 (D.D.C. 2018), appeal docketed, No. 18-5014 (D.C. Cir. Jan. 25, 2018). It held that neither the President’s tweets and other public statements, nor the public statements of other high-ranking government officials,
constituted a public acknowledgment that the documents sought by Plaintiffs James Madison Case 1:17-cv-00144-APM Document 49 Filed 08/16/18 Page 1 of
2
Project and Josh Gerstein in fact exist and are possessed by Defendant agencies. See id. Plaintiffs then filed a notice of appeal, but shortly after moved for reconsideration in light of the Nunes Memo’s release. Plaintiffs’ notice of appeal, however, divested the court of jurisdiction over this matter. See United States v. DeFries, 129 F.3d 1293, 1302 (D.C. Cir. 1997) (per curiam) (“The
filing of a notice of appeal . . . ‘confers jurisdiction on the court of appeals and divests the district court of control over those aspects of the case involved in the appeal.’” (quoting Griggs v. Provident Consumer Disc. Co., 459 U.S. 56, 58 (1982)). Accordingly, Plaintiffs now ask the court to indicate, under Federal Rule of Civil Procedure 62.1, that it would grant their Motion upon remand. See Fed. R. Civ. P. 62.1(a)(3). Defendants assert that reconsideration is not warranted
and urge the court to deny the Motion.

For the reasons that follow, the court finds that the disclosures contained in the Nunes and Schiff Memos do constitute a public acknowledgement of the existence of the records sought by Plaintiffs from Defendant Federal Bureau of Investigation (“FBI”) and that the FBI therefore may no longer maintain its Glomar responses. Accordingly, the court indicates that, upon remand, the
court would grant Plaintiffs’ pending Motion for Reconsideration as to the FBI. Plaintiffs’ Motion as to the remaining agency Defendants, however, is denied.

I.
The court already has written extensively about this matter, and so only will summarize the relevant facts and procedural history here.
A.
In January 2017, Plaintiffs submitted a Freedom of Information Act (“FOIA”) request to four federal agencies—the Office of the Director of National Intelligence, the Central Intelligence Case 1:17-cv-00144-APM Document 49 Filed 08/16/18 Page 2 of 13
3
Agency, the National Security Agency (collectively, “Intelligence Community Defendants”), and the FBI—for the following information:
(1) The two-page “synopsis” provided by the U.S. Government to
President-Elect Trump with respect to allegations that Russian
Government operatives had compromising personal and financial
information about President-Elect Trump (“Item One”);
(2) Final determinations regarding the accuracy (or lack thereof) of
any of the individual factual claims listed in the two page synopsis
(“Item Two”); and
(3) Investigative files relied upon in reaching the final
determinations referenced in [Item Two] (“Item Three”).
James Madison I, 302 F. Supp. 3d at 17. These responses remained unanswered at the time Plaintiffs filed this action. See id. 17–18.

Thereafter, within the context of this litigation, Defendants responded to Plaintiffs’ FOIA demands. All Defendants asserted Glomar responses as to Items Two and Three—that is, they refused to admit or deny whether any responsive records even exist. See id. at 18. As to Item One, only the FBI advanced a Glomar response, while the Intelligence Community Defendants admitted the existence and their possession of the “two-page ‘synopsis’” but invoked FOIA Exemptions 1
and 3 to justify withholding the document in its entirety. See id. Defendants then moved for summary judgment, which the court granted in full on January 4, 2018. See id. at 17. The court held that: (1) Defendants’ Glomar responses to Items Two and Three were proper, see id. at 31–35; (2) the FBI’s Glomar response to Item One was appropriate, see id. at 29–31; and (3) the
Intelligence Community Defendants’ withholding of the two-page synopsis was justified, see id. at 35–36. Plaintiffs then noticed an appeal from the court’s ruling. See Notice of Appeal, ECF No. 38.
Case 1:17-cv-00144-APM Document 49 Filed 08/16/18 Page 3 of 13

B.
But then the ground shifted. On February 2, 2018, President Trump authorized release of a memorandum prepared by the majority staff of the House Permanent Select Committee on Intelligence, commonly referred to as the Nunes Memo. See Pls.’ Mot. for Recons., ECF No. 40
[hereinafter Pls.’ Mot.], Ex. 1, ECF No. 40-1 [hereinafter Nunes Memo]. Among other things, the Nunes Memo revealed that former British intelligence operative Christopher Steele drafted the Dossier; that, in October 2016, the FBI relied in part on portions of the Dossier’s contents to secure a Foreign Intelligence Surveillance Act (“FISA”) warrant as to Carter Page, a former campaign
advisor to then-candidate Trump; that, in parallel with pursuing the Page FISA warrant, the FBI was undertaking efforts to corroborate the allegations contained within the Dossier; and, critically for this case, that “in early January 2017, Director Comey briefed President-elect Trump on a summary of the Steele dossier.” See id. at 4–6.1

A few weeks later, the President authorized the declassification and release of even more information about the Dossier’s origin and use. On February 24, 2018, a rebuttal to the Nunes Memo, written by the minority staff of the House Permanent Select Committee on Intelligence, became public. See Pls.’ Notice of Suppl. Info., ECF No. 41, Ex. 1, ECF No. 41-1 [hereinafter Schiff Memo]. The rebuttal, better known as the “Schiff Memo,” revealed, among other things,
that Steele shared his “reporting . . . with an FBI agent . . . through the end of October 2016”; and, importantly for this case, that “[t]he FBI has undertaken a rigorous process to vet allegations from Steele’s reporting.” Id. at 5, 8. As a result of the release of the Nunes and Schiff Memos, there is now in the public domain meaningful information about how the FBI acquired the Dossier and
how the agency used it to investigate Russian meddling in the 2016 presidential election.
1 Citations to both the Nunes and Schiff Memos are to the page numbers electronically generated by CM/ECF.
Case 1:17-cv-00144-APM Document 49 Filed 08/16/18 Page 4 of 13

Not surprisingly, after the release of the Nunes Memo, Plaintiffs asked this court to reconsider the validity of Defendants’ Glomar responses. See generally Pls.’ Mot. Moving under Rule 60(b)(2) of the Federal Rules of Civil Procedure, Plaintiffs argued that the information contained in the Memos “undoubtedly would have conclusively and substantively changed the outcome of the present case if it had been available prior to this Court’s” summary judgment ruling.
Id. at 6. Defendants opposed Plaintiffs’ motion, arguing that “nothing to which [Plaintiffs] refer in the Nunes Memo or in the Schiff Memo addresses the two-page synopsis that is the subject of plaintiffs’ request.” Defs.’ Opp’n to Pls.’ Mot., ECF No. 43 [hereinafter Defs.’ Opp’n], at 2. As Defendants put it: “The Schiff Memo, like the Nunes Memo, is devoid, in fact, of any reference
to the two-page synopsis” and thus “[n]o waiver of the Glomar responses . . . results[.]” Id. at 3.

In view of the parties’ positions, the issue before the court is: Does the President’s approved release of the information contained in the Nunes and Schiff Memos constitute an official acknowledgement of the existence of records requested by Plaintiffs, such that Defendants’ Glomar responses are now invalid? The court turns now to answer that question.

II.
A.
Rule 60(b)(2) allows for relief from a final judgment, order, or proceeding based on “newly discovered evidence that, with reasonable diligence, could not have been discovered in time to move for a new trial.” Fed. R. Civ. P. 60(b)(2). In order for evidence to meet the requirements of Rule 60(b)(2), the following criteria must be met:
(1) the newly discovered evidence is of facts that existed at the time
of trial or other dispositive proceeding; (2) the party seeking relief
was justifiably ignorant of the evidence despite due diligence;
(3) the evidence is admissible and is of such importance that it
Case 1:17-cv-00144-APM Document 49 Filed 08/16/18 Page 5 of 13

probably would have changed the outcome; and (4) the evidence is
not merely cumulative or impeaching.
West v. Holder, 309 F.R.D. 54, 57 (D.D.C. 2015) (citation omitted).
There is no dispute here that both the Nunes and Schiff Memos satisfy the first, second, and fourth prongs for purposes of Rule 60(b)(2). See Bain v. MJJ Prods., Inc., 751 F.3d 642, 647 (D.C. Cir. 2014) (defining “newly discovered evidence”). Thus, the sole question for the court is whether those Memos are “of such importance that it probably would have changed the outcome” of the court’s summary judgment ruling. West, 309 F.R.D. at 57; see also In re Korean Air Lines Disaster of Sept. 1, 1983, 156 F.R.D. 18, 22 (D.D.C. 1994) (noting that evidence is “newly discovered” under Rule 60(b)(2) if it is “of such a material and controlling nature as will probably change the outcome” (citing Goland v. CIA, 607 F.2d 339, 371 n.12 (D.C. Cir. 1978)).
B.
It is helpful to start with a recap of the principles that govern how to evaluate a Glomar response. To overcome a Glomar response, the plaintiff can either challenge the agency’s position that disclosing the existence of a record will cause harm under the FOIA exemption asserted by the agency, or the plaintiff can show that the agency has “officially acknowledged” the existence
of records that are the subject of the request. See James Madison I, 302 F. Supp. 3d at 20. If the requester takes the second route—as Plaintiffs do here—she “must pinpoint an agency record that both matches the plaintiff’s request and has been publicly and officially acknowledged by the agency.” Id. at 21 (emphasis omitted) (quoting Moore v. CIA, 666 F.3d 1330, 1333 (D.C. Cir. 2011)).2
2 Although drafted by Legislative Branch staff, Defendants here do not dispute that the Nunes and Schiff Memos constitute official public statements of the President that could give rise to a Glomar waiver. Cf. James Madison I,
302 F. Supp. 3d at 24 (The D.C. Circuit has recognized that ‘[a] disclosure made by the President, or by [an] advisor acting as “instructed” by the President,’ is attributable to executive branch agencies for purposes of the official
acknowledgement doctrine.” (quoting Am. Civ. Liberties Union (ACLU) v. CIA, 710 F.3d 422, 429 n.7 (D.C. Cir. Case 1:17-cv-00144-APM Document 49 Filed 08/16/18 Page 6 of 13

Generally speaking, there are two ways in which a plaintiff can establish that a public statement officially acknowledges the existence of a document. The plaintiff can either (1) identify a statement that “on [its] face” constitutes an official acknowledgement of a document’s existence, or (2) point to a statement that, when combined with the “context in which it is made,” leads to an
“inescapable inference that the requested record[ ] in fact exist[s].” See James Madison I, 302 F. Supp. 3d at 22. Under either approach, the “official acknowledgement” doctrine must be construed “strictly.” Id. at 23 (quoting Moore, 666 F.3d at 1333). And, “whether expressly or by inference, the official statement must render it ‘neither logical nor plausible’ for the agency to
justify its position that disclosure would reveal anything not already in the public domain.” Id. at 24 (quoting Am. Civ. Liberties Union (ACLU) v. CIA, 710 F.3d 422, 430 (D.C. Cir. 2013)).

III.
Plaintiffs argue that the Nunes and Schiff Memos, both directly and by way of inference, “pinpoint” the existence of agency records that “match” their FOIA requests. They contend that both Memos disclose the FBI’s efforts to verify or refute the accuracy of the Dossier’s allegations, and note that the Nunes Memo expressly mentions “a source validation report conducted by an
independent unit within [the] FBI [that] assessed Steele’s reporting as only minimally corroborated.” Nunes Memo at 6 (emphasis added); see Pls.’ Mot. at 2–3. The referenced “source validation report,” they assert, “matches” their requests for “final determinations regarding the accuracy (or lack thereof) of the allegations summarized in the two-page synopsis, as well as 2013)). In fact, the Nunes Memo’s release caused the Department of Justice to withdraw its Glomar response in a different FOIA case before this court, involving a demand for records relating to the Carter Page FISA warrant application. See James Madison Project v. U.S. Dep’t of Justice, Case No. 17-cv-00597-APM (D.D.C.), Def.’s Resp. to Order, ECF No. 32, at 1 (“Defendant withdraws the Glomar response as to the existence of the Page FISA applications and orders identified in the Nunes Memo.”). Case 1:17-cv-00144-APM Document 49 Filed 08/16/18 Page 7 of 13

investigative files (if any) relied upon in rendering those final determinations.” Pls.’ Mot. at 2–3 (internal quotation marks omitted); see also James Madison I, 302 F. Supp. 3d at 17.

Defendants’ response is straightforward. Distinguishing the Dossier from the two-page synopsis, they concede that both Memos disclose the FBI’s efforts to corroborate the Dossier’s allegations, but assert that nothing in the Memos “addresses the two-page synopsis that is the subject of plaintiffs’ requests.” Defs.’ Opp’n at 2. In other words, they argue, neither the Nunes Memo nor the Schiff Memo contains reference to any document that matches the “final
determinations” or “investigative files” about the synopsis that Plaintiffs seek, so their Glomar responses remain on firm ground.

Plaintiffs have the better of the argument.
A.
Item One: The Two-Page Synopsis. Recall, only the FBI asserted a Glomar response to Plaintiffs’ demand for a copy of the two-page synopsis presented to President-elect Trump. James Madison I, 302 F. Supp. 3d at 18. The Nunes Memo makes the FBI’s position no longer tenable because it expressly refers to the document Plaintiffs seek. Specifically, the Nunes Memo states:
“[I]n early January 2017, [FBI] Director Comey briefed President-elect Trump on a summary of the Steele dossier, even though it was—according to his June 2017 testimony—‘salacious and unverified.’” Nunes Memo at 6 (emphasis added). Read in context, the Nunes Memo’s reference to “a summary of the Steele dossier” presented to President-elect Trump in “early January 2017”
matches Plaintiffs’ first demand: a “two-page ‘synopsis’ provided by the U.S. Government to President-Elect Trump with respect to allegations that Russian Government operatives had compromising personal and financial information about President-Elect Trump.”
Case 1:17-cv-00144-APM Document 49 Filed 08/16/18 Page 8 of 13

To begin with, the phrase “a summary of the Steele dossier” clearly refers to a written summary. Interpreting that phrase to refer to an oral summary would be grammatically unnatural.

The Nunes Memo uses the past tense of the verb “brief,” the preposition “on,” and the article “a” before “summary” to describe what Director Comey did with respect to “a summary of the Steele Dossier.” Reading those terms together conveys that Director Comey dispensed information as to some tangible object—a briefing “on” “a summary.” To say that the Director “briefed” the
President-elect “on” “an” oral summary would make little sense. If the briefing concerned only an oral summation, then the phrase “a summary of” to modify “the Steele Dossier” would be entirely unnecessary (“Director Comey briefed President Trump on . . . the Steele Dossier”). Thus, understanding “summary” to refer to a “written summary” is the natural reading.

Context supplies other evidence of a match between Plaintiffs’ Item One request and the Nunes Memo’s reference to “a summary of the Dossier.” The terms “synopsis”—used by Plaintiffs—and “summary”—used by the Nunes Memo—are, of course, synonyms. The interchangeability of those words points to the same document. Additionally, Plaintiffs’ demand for a document pertaining to “allegations that Russian Government operatives had compromising
and personal financial information about President-Elect Trump” is an unmistakable reference to what the Nunes and Schiff Memos identify as the Dossier. See Nunes Memo at 5 (stating that the “‘dossier’ [was] compiled by Christopher Steele” who was tasked with “obtain[ing] derogatory
information on Donald Trump’s ties to Russia”); cf. Schiff Memo at 3–4 (“DOJ’s applications did not otherwise rely on Steele’s reporting, including any ‘salacious’ allegations about Trump, and the FBI never paid Steele for this reporting.”). And the Nunes Memo’s description of what Director Comey did with the “summary” is consistent with a January 10, 2017, CNN article that
Plaintiffs incorporated in their FOIA request to the agencies “for context.” See Answer, ECF No.
Case 1:17-cv-00144-APM Document 49 Filed 08/16/18 Page 9 of 13

8, Ex. A, ECF No. 8-1 [hereinafter FOIA Request], at 2; Defs.’ Mot. for Summ. J., ECF No. 14, Ex. G, ECF No. 14-14 [hereinafter CNN Article]. The CNN article reported that allegations regarding Russian possession of “compromising personal and financial information” about the President-elect were “presented” in a two-page synopsis to President-elect Trump during the first
week of January 2017 by “four of the senior-most US intelligence chiefs,” including FBI Director Comey. CNN Article at 1–2; see also FOIA Request at 3 (stating the “two page synopsis included allegations derived from a 35 page ‘dossier’ allegedly compiled by a former British intelligence
operative” and published by BuzzFeed). The Nunes Memo confirms this description of events.

It places Director Comey in a briefing of President-elect Trump regarding a summary of the Dossier in January 2017. These parallels lead the court to conclude that the “synopsis” sought by Plaintiffs is in fact the “summary” acknowledged by the Nunes Memo.

It is true that the Nunes Memo does not use the word “synopsis.” But that is not fatal. The context in which the official acknowledgement was made leads to the obvious inference that the FBI possesses the two-page synopsis Plaintiffs seek. Is it reasonable to conclude that the synopsis does not exist or that the FBI does not possess it, even though the FBI has, in the words of the Nunes Memo, undertaken a “rigorous process to vet allegations from Steele’s reporting”? Of
course not. No reasonable person would accept as plausible that the nation’s top law enforcement agency does not have the two-page synopsis in light of these officially acknowledged facts of its actions. As the D.C. Circuit observed in ACLU, “[t]he Glomar doctrine is in large measure a judicial construct, an interpretation of FOIA exemptions that flows from their purpose rather than their express language.” 710 F.3d at 431. To accept the FBI’s Glomar response as to Item One in this case would “stretch that doctrine too far.” Id.
Case 1:17-cv-00144-APM Document 49 Filed 08/16/18 Page 10 of 13

By authorizing the release of the Nunes Memo to make known the existence of the “summary” of the Dossier on which he was briefed, the President has publicly acknowledged the existence of the two-page synopsis in Director Comey’s possession. The FBI therefore can no longer assert a Glomar response to Plaintiffs’ demand for that record.
B.
Items Two and Three: Final Determinations and Investigative Files. For much the same reasons already discussed, it remains no longer logical nor plausible for the FBI to maintain that it cannot confirm nor deny the existence of documents responsive to Plaintiffs’ second and third requests: (1) “[f]inal determinations regarding the accuracy (or lack thereof) of any of the individual factual claims listed in the two page synopsis” and (2) the “[i]nvestigative files relied
upon in reaching [such] final determinations.”

The Memos reveal that the FBI has undertaken substantial efforts to confirm the accuracy of the Dossier’s reporting. The Nunes Memo expressly acknowledges the existence of “a source validation report,” conducted by an “independent unit within [the] FBI,” which “assessed Steele’s reporting as only minimally corroborated.” Nunes Memo at 6. The Schiff Memo takes a more
favorable view of a portion of Steele’s reporting, and provides even more information about the FBI’s efforts. It explains that “Steele’s information about [Carter] Page was consistent with the FBI’s assessment of Russian intelligence efforts to recruit him and his connections to Russian persons of interest,” Schiff Memo at 6, and that the FBI had reached a sufficient level of confidence
in Steele’s reporting about Carter Page’s alleged coordination with Russian officials to include that information in a FISA warrant application, id. at 8. Additionally, the Schiff Memo states:
“The FBI has undertaken a rigorous process to vet allegations from Steele’s reporting, including with regard to Page.” Id. at 8. Unless the court is to believe that the FBI undertook these efforts Case 1:17-cv-00144-APM Document 49 Filed 08/16/18 Page 11 of 13

without creating any memoranda or other papers containing assessments about Steele’s reporting and did not gather files for that purpose—a wholly implausible proposition—the Nunes and Schiff Memos are “tantamount to an acknowledgment that the [FBI] has documents on [those] subject[s].” ACLU, 710 F.3d at 431.
Defendants counter that the absence of any express reference in the Memos to efforts to validate the synopsis, as opposed to the Dossier, allows them to stand on Glomar responses as to Items Two and Three. But that position defies logic. As a “summary” of the Dossier, Nunes Memo at 6, the synopsis undeniably contains some subset of the Dossier’s allegations. It is simply not plausible to believe that, to whatever extent the FBI has made efforts to verify Steele’s
reporting, some portion of that work has not been devoted to allegations that made their way into the synopsis. After all, if the reporting was important enough to brief the President-elect, then surely the FBI thought enough of those key charges to attempt to verify their accuracy. It will be up to the FBI to determine which of the records in its possession relating to the reliability of the
Dossier concerns Steele’s reporting as discussed in the synopsis. Accordingly, the FBI has waived its Glomar responses as to Items Two and Three of Plaintiffs’ FOIA request.

The same cannot be said, however, about the Intelligence Community Defendants. Neither the Nunes Memo nor the Schiff Memo makes any reference to any effort by the Intelligence Community Defendants to determine the accuracy (or lack thereof) of any of the individual factual claims contained in the synopsis. Although an official presidential statement can vitiate a Glomar
response for an executive branch agency, see ACLU, 710 F.3d at 429 n.7, the court does not read Circuit precedent to go so far as to say that the President’s acknowledgment of the existence of records by one agency categorically precludes every part of the Executive Branch from asserting a Glomar response. Rather, if an official presidential acknowledgement is limited to a single
Case 1:17-cv-00144-APM Document 49 Filed 08/16/18 Page 12 of 13

component of the Executive Branch, as is the case here, other unrelated components may still invoke Glomar. The court’s conclusion is consistent with the principle that, when the President makes an official acknowledgment as to a particular agency, in that capacity he acts solely as the “parent” of that agency and that agency alone—not the entire Executive Branch. Cf. id. (explaining
that the rule that one agency’s waiver of a Glomar response does not bind another, unrelated agency “does not apply . . . where the disclosures are made by an authorized representative of the agency’s parent. A disclosure made by the President, or by his counterterrorism advisor acting as ‘instructed’ by the President, falls on the ‘parent agency’ side of that line.” (internal citations
omitted)). To adopt the contrary rule would have far-reaching consequences that this court is not prepared to accept, in the absence of clear guidance from the Circuit. Accordingly, the court finds that disclosures contained in the Nunes and Schiff Memos are not official acknowledgements that preclude the Intelligence Community Defendants from maintaining Glomar responses as to Items
Two and Three of Plaintiffs’ request.

IV.
For the foregoing reasons, consistent with Rule 62.1, the court states that, on remand, the court would grant Plaintiffs’ Motion for Reconsideration as to all of the FBI’s Glomar responses.
The court, however, denies the Motion for Reconsideration as to the Intelligence Community Defendants’ Glomar responses to Plaintiffs’ second and third FOIA requests. See Fed. R. Civ. P. 62.1(a)(2).

Dated: August 16, 2018 Amit P. Mehta
United States District Judge
Case 1:17-cv-00144-APM Document 49 Filed 08/16/18 Page 13 of 13

https://www.scribd.com/document/386451281/FBI-Foia-Ruling#download&from_embed

 

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John Brennan Obama’s top terrorism and intelligence adviser Analysis Corp. employee cauterized Obama passport data, Article “scrubbed”, Fake news defends Brennan attacks Trump

John Brennan Obama’s top terrorism and intelligence adviser Analysis Corp. employee cauterized Obama passport data, Article “scrubbed”, Fake news defends Brennan attacks Trump

“Why has Obama employed numerous private and government attorneys to avoid presenting a legitimate birth certificate and college records?”…Citizen Wells and millions of concerned Americans

“Vivek Kundra, who was tapped as the White House technology czar
March 5, oversaw technology projects and budgets for 86 D.C.
government agencies as head of the District’s Office of the Chief
Technology Officer.”
“Yusuf Acar, 40, who has worked in the technology office since
2004, was charged with bribery, conspiracy, money laundering and
conflict of interest.”
“Acar also told the informant that he could use computers to
create fake D.C. birth certificates, Hibarger said.”…Citizen Wells from pre rectified Washington Post article dated March 13, 2009

“The past, he reflected, had not merely been altered, it had
actually been destroyed. For how could you establish, even
the most obvious fact when there existed no record outside
your own memory?”…George Orwell, “1984″

 

 

Citizen Wells the anti Orwellian Fake News alternative.

Citizen Wells and other sites such as Info Wars, linked to a January 12, 2009 NewsMax article about the John Brennan’s Analysis Corp. employee who cauterized Obama’s passport data.

John Brennan, like Robert Bauer, former Perkins Coie employee and Tony West, were rewarded in Chicago pay to play style for helping Obama keep his records hidden.

The NewsMax article apparently was “scrubbed”, i.e., the former link does not work and there is no indication of the article on the NewsMax site or via a internet search.

My niche is fighting Orwellian efforts to rewrite history so I resurrected the article.

“Obama’s Intelligence Adviser Involved in Security Breach”

“Obama’s top terrorism and intelligence adviser, John O. Brennan, heads a firm that was cited in March for breaching sensitive files in the State Department’s passport office, according to a State Department Inspector General’s report released this past July.

The security breach, first reported by the Washington Times and later confirmed by State Department spokesman Sean McCormack, involved a contract employee of Brennan’s firm, The Analysis Corp., which has earned millions of dollars providing intelligence-related consulting services to federal agencies and private companies.

During a State Department briefing on March 21, 2008, McCormack confirmed that the contractor had accessed the passport files of presidential candidates Barack Obama, Hillary Rodham Clinton, and John McCain, and that the inspector general had launched an investigation.

Sources who tracked the investigation tell Newsmax that the main target of the breach was the Obama passport file, and that the contractor accessed the file in order to “cauterize” the records of potentially embarrassing information.

“They looked at the McCain and Clinton files as well to create confusion,” one knowledgeable source told Newsmax. “But this was basically an attempt to cauterize the Obama file.”

At the time of the breach, Brennan was working as an unpaid adviser to the Obama campaign.

“This individual’s actions were taken without the knowledge or direction of anyone at The Analysis Corp. and are wholly inconsistent with our professional and ethical standards,” Brennan’s company said in a statement sent to reporters after the passport breach was made public.

The passport files include “personally identifiable information such as the applicant’s name, gender, social security number, date and place of birth, and passport number,” according to the inspector general report.

The files may contain additional information including “original copies of the associated documents,” the report added. Such documents include birth certificates, naturalization certificates, or oaths of allegiance for U.S.-born persons who adopted the citizenship of a foreign country as minors.

The Obama campaign acknowledged at its “Fight the Smears” Web site that Obama was a foreign national until the age of 18, by virtue of his father’s British then Kenyan citizenship.

“Since Sen. Obama has neither renounced his U.S. citizenship nor sworn an oath of allegiance to Kenya, his Kenyan citizenship automatically expired on Aug. 4,1982,” the Web site stated.

“Fight the Smears” attempted to debunk rumors that Obama was not a U.S. citizen by producing a 2007 computer-generated copy of his certification of live birth.

“The truth is, Barack Obama was born in the state of Hawaii in 1961, a native citizen of the United States of America,” the Web site states.

However, “native citizen” is a colloquialism, not a legal term. It is not the same as “natural-born citizen,” the requirement to be president set out in Article 2, Section 1 of the Constitution.

Chief Justice John Roberts has scheduled a Supreme Court conference on Jan. 23 on Lightfoot v. Bowen, one of several cases alleging that Obama is not a “natural born” citizen because of his birthright British citizenship.

The State Department chalked up the passport file snooping discovered in March 2008 to “imprudent curiosity” by contract employees hired to help process passport applications.”

Read more:

http://citizenwells.net/2018/08/16/obamas-intelligence-adviser-involved-in-security-breach-john-brennan-analysis-corp-employee-cauterized-obama-file-newsmax-january-12-2009/

 

 

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http://citizenwells.net/

 

Justice Dept. enema required, Strzok firing not enough, J Christian Adams warning, Attorney Ty Clevenger FOIA requests and Transparency Project, DOJ blocking Set Rich info release

Justice Dept. enema required, Strzok firing not enough, J Christian Adams warning, Attorney Ty Clevenger FOIA requests and Transparency Project, DOJ blocking Set Rich info release

“Why was Tony West, who helped Obama keep his records hidden at taxpayer expense, promoted to Acting Associate Attorney General, the third highest official at the Justice Department?”…Citizen Wells

“Why has the Department of Justice not been cleansed (given an enema)?”…Citizen Wells

“I know that Seth Rich was involved in the DNC leak.”…Kim Dotcom

 

J. Christian Adams, former Justice Department attorney, warned us in 2010.

“On the day President Obama was elected, armed men wearing the black berets and jackboots of the New Black Panther Party were stationed at the entrance to a polling place in Philadelphia. They brandished a weapon and intimidated voters and poll watchers. After the election, the Justice Department brought a voter -intimidation case against the New Black Panther Party and those armed thugs. I and other Justice attorneys diligently pursued the case and obtained an entry of default after the defendants ignored the charges. Before a final judgment could be entered in May 2009, our superiors ordered us to dismiss the case.

The New Black Panther case was the simplest and most obvious violation of federal law I saw in my Justice Department career. Because of the corrupt nature of the dismissal, statements falsely characterizing the case and, most of all, indefensible orders for the career attorneys not to comply with lawful subpoenas investigating the dismissal, this month I resigned my position as a Department of Justice (DOJ) attorney.”
“Based on my firsthand experiences, I believe the dismissal of the Black Panther case was motivated by a lawless hostility toward equal enforcement of the law. Others still within the department share my assessment. The department abetted wrongdoers and abandoned law-abiding citizens victimized by the New Black Panthers. The dismissal raises serious questions about the department’s enforcement neutrality in upcoming midterm elections and the subsequent 2012 presidential election.”

https://citizenwells.com/2014/06/09/j-christian-adams-explains-obama-use-of-alinsky-rules-for-radicals-challengers-to-obama-labeled-marginalized-compartmentalized-birthers-impeachment-proponents-made-to-look-crazy/

I have probably spent the greatest amount of time researching relative to reporting on the Seth Rich murder.

I vowed I would not forget it.

We deserve the truth.

There have been a number of FOIA requests for release of information regarding the Seth Rich murder and “investigations.”

I kept looking for a followup on the Judicial Watch request.

Attorney Ty Clevenger has made a number of FOIA requests as well as filing lawsuits and provided updates.

http://lawflog.com/wp-content/uploads/2017/10/2017.09.01-Seth-Rich-FOIA-request.pdf

“Federal lawsuit seeks records about Seth Rich murder”

“This morning I filed a Freedom of Information Act lawsuit that asks a federal judge in Brooklyn to order the FBI and U.S. Department of Justice to release records concerning the murder of former Democratic National Committee employee Seth Rich.

Back in October, I wrote about the U.S. Department of Justice ordering the U.S. Attorney’s Office in D.C. to release records about the murder, but since that time not a single record has been produced.  Around the same time, the FBI refused to search for records in its Washington Field Office, even though that is where the records are most likely to be found.  The lawsuit notes that the FBI has a history of trying to hide records from FOIA requestors and Congress.

I also asked the court to order the National Security Administration to release all of its communications with members of Congress regarding Seth Rich, Julian Assange, and Kim Dotcom, among others.

As you are probably aware, Mr. Rich’s parents filed suit this week against Fox News, producer Malia Zimmerman, and frequent guest Ed Butowsky.  I think that was a serious tactical error.  All of the defendants now have the legal right to subpoena documents and witnesses, and you can be sure they will use that power aggressively.

THE TRANSPARENCY PROJECT

With help from several supporters, I’ve organized The Transparency Project, a nonprofit corporation headquartered in Texas. If you want to support the Seth Rich litigation, you can find out how at Tproject.org. The website is a little primitive, but I plan to update it soon.”

Read more:

http://lawflog.com/?p=1912

The Transparency Project

“The Transparency Project is a nonprofit organization that fights political corruption, particularly in the judiciary and the legal profession. TTP was organized by Ty Clevenger, an attorney who grew tired of watching judges and lawyers get away with things that would send most people to prison.  Ty has forced two federal judges into retirement, triggered a grand jury investigation of the Texas Attorney General (who was subsequently indicted), prompted the indictment and conviction of a corrupt district attorney, and sued bar prosecutors to force them to investigate Hillary Clinton’s lawyers for their roles in destroying email evidence.  TTP intends to purse similar cases.”

Read more:

http://tproject.org/

 

 

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https://citizenwells.com/

http://citizenwells.net/

 

James A. Lyons Jr. retired US Navy admiral Seth Rich article scrubbed?, Washington Times sued by Aaron Rich, False theories about unsolved murder?, First amendment rights?, Many questions unanswered

James A. Lyons Jr. retired US Navy admiral Seth Rich article scrubbed?, Washington Times sued by Aaron Rich, False theories about unsolved murder?, First amendment rights?, Many questions unanswered

“I know that Seth Rich was involved in the DNC leak.”…Kim Dotcom

“Burkman said in an interview that he considered Selig like a brother and was badly shaken by his friend’s death.”
“The tragically ironic part is Glenn’s last words to me were, ‘Be careful,’” Burkman said. “It’s just a tragedy — terrible.””…Politico Jan. 24, 2018

“As soon as all the corrections which happened to be necessary in any particular number of the Times had been assembled and collated, that number would be reprinted, the original copy destroyed, and the corrected copy placed on the files in it’s stead. This process of continuation alteration was applied not only to newspapers, but to books, periodicals, pamphlets, posters, leaflets, films, sound tracks, cartoons, photographs–to every kind of literature or documentation which might conceivably hold any political or ideological significance. Day by day and almost minute by minute the past was brought up to date. In this way every prediction made by the Party could be shown by documentary evidence to be correct; nor was any item of news, or expression of opinion, which conflicted with the needs of the moment, ever allowed to be on record.”…George Orwell, “1984″

 

Yesterday was George Orwell’s (Eric Blair) birthday.

Winston’s job in “1984” was to rectify articles, scrub and rewrite.

So it apparently is with a Washington Times article written by James A. Lyons Jr., retired US Navy admiral, on March 1, 2018. about the Seth Rich murder. Pressure from the lawsuit?

The article has been oft quoted.

The link to the Washington Times article did not work nor did a search on their site.

I found the article on the Wayback Machine.

I assure you, in this case and all others, I want the truth, the whole truth and nothing but the truth.

The Washington Times article is listed under commentary and is tagged as Analysis/Opinion. Perhaps there should have been more ? marks and “alleged” notations.

“More cover-up questions

The curious murder of Seth Rich poses questions that just won’t stay under the official rug”

“ANALYSIS/OPINION:

“With the clearly unethical and most likely criminal behavior of the upper management levels of the Department of Justice (DOJ) and the Federal Bureau of Investigation (FBI) exposed by Chairman Devin Nunes of the House Intelligence Committee, there are two complementary areas that have been conveniently swept under the rug.

The first deals with the murder of the Democratic National Committee (DNC) staffer Seth Rich, and the second deals with the alleged hacking of the DNC server by Russia. Both should be of prime interest to special counsel Robert Mueller, but do not hold your breath.

The facts that we know of in the murder of the DNC staffer, Seth Rich, was that he was gunned down blocks from his home on July 10, 2016. Washington Metro police detectives claim that Mr. Rich was a robbery victim, which is strange since after being shot twice in the back, he was still wearing a $2,000 gold necklace and watch. He still had his wallet, key and phone. Clearly, he was not a victim of robbery.

This has all the earmarks of a targeted hit job. However, strangely no one has been charged with this horrific crime, and what is more intriguing is that no law enforcement agency is even investigating this murder. According to other open sources, Metro police were told by their “higher ups” that if they spoke about the case, they will be immediately terminated. It has been claimed that this order came down from very high up the “food chain,” well beyond the D.C. mayor’s office. Interesting.”

“With regard to the alleged Russian hacking of the DNC server, Mr. Assange also offered information to the Trump administration to prove Russia didn’t hack the DNC server, as the DNC claimed. Mr. Assange also met with Orange Country Rep. Dana Rohrabacher, California Republican, and gave him information to present to the Trump administration to prove no one hacked the DNC server.

However, with the Obama holdovers in key positions, it is not surprising that no one from the Trump administration would meet with the congressman or Mr. Assange. New Zealand tech expert Kim DotCom said he has proof that both he and Seth Rich were involved in passing the emails to Wikileaks, but he has been ignored as well.

The FBI opened an investigation into the theft of the DNC emails in July 2016. However, the FBI has not inspected the DNC server because the DNC won’t give permission. Is the FBI an extension of the DNC? That’s why we have subpoenas. Instead, the FBI relied on an assessment by a cyber security firm, Crowd Strike, hired by the Hillary Clinton campaign and DNC’s law firm Perkins Coie as proof that Russia was the hacker. Incompetence is an understatement. Corruption at the highest levels of the DOJ/FBI is clear.

The Trump administration must take charge and get a competent attorney general to pursue these crimes.

• James A. Lyons, Jr., a retired U.S. Navy admiral, was commander in chief of the U.S. Pacific Fleet and senior U.S. military representative to the United Nations.”

Read more:

https://web.archive.org/web/20180317141023/https://www.washingtontimes.com/news/2018/mar/1/more-cover-up-questions/

“Seth Rich’s brother sues conservative media figures for defamation”

“Aaron Rich, the brother of a Democratic National Committee staffer who was killed in 2016, is suing conservative media figures and The Washington Times for defamation, alleging in a lawsuit filed Monday that they spread false theories about the unsolved murder of Seth Rich.”

Read More:

https://www.politico.com/story/2018/03/27/seth-rich-brother-sues-conservative-media-487827

 

More here:

https://citizenwells.com/

http://citizenwells.net/

“Get ready for Obamacare sticker shock” Orwellian lie from Charlotte Observer repeated by Greensboro News Record, Narrative for election, Shift blame to Republicans, Shock and lies began in 2009, Premiums deductibles policy losses job losses health care losses, Tell big lie and repeat

“Get ready for Obamacare sticker shock” Orwellian lie from Charlotte Observer repeated by Greensboro News Record, Narrative for election, Shift blame to Republicans, Shock and lies began in 2009, Premiums deductibles policy losses job losses health care losses, Tell big lie and repeat

“Nearly half of U.S. companies are reluctant to hire full-time employees because of the ACA. One in five firms indicates they are likely to hire fewer employees, and another one in 10 may lay off current employees in response to the law.

Other firms will shift toward part-time workers. More than 40 percent of CFOs say their companies will consider switching some jobs to less than 30 hours per week or targeting part-time workers for future employment.”…Duke University Fuqua School of Business December 11, 2013

“If you like your plan, you can keep it.”…Barack Obama

“millions of Americans are getting or are about to get cancellation letters for their health insurance under Obamacare, say experts, and the Obama administration has known that for at least three years.”…NBC News October 29, 2013

 

The Obamacare debacle, sticker shock and tragedy began long before Donald Trump ran for office.

This was the doing of Barack Obama and the Democrats.

As predicted by their behavior  patterns, they screw things up and then create a narrative to shift the blame to Republicans.

They have had great success in the past due to their dumbed down sheeple followers.

From the Charlotte Observer May 9, 2018.

“Get ready for Obamacare sticker shock”

“States across the country, including North Carolina, can expect similar proposed hikes in coming months. Obamacare sticker shock is coming, and it’s going to hit rural areas especially hard.”

“When Republicans repealed Obamacare’s individual mandate, they changed the economic viability of the Affordable Care Act, which counted on healthy people’s premiums defraying some of the cost of insuring the less than healthy. In addition, the Trump administration scrapped subsidies to insurers and gave healthy folks more reason to leave the exchanges by allowing insurers greater room to offer thinner policies that cost less money.”

” It will be an election issue in November, and voters should remember this: Obamacare needed tweaks, but it was working, despite what the president and Republicans have long claimed. Millions more Americans had health care coverage. That coverage included benefits that insurance companies largely didn’t offer before Obamacare. Also, insurance premiums were rising at a rate lower than the years before the Affordable Care Act was enacted.

Now, for many, those premiums are about to go way up, and insurers are being given more leeway to offer less. What’s old is new again. And it’s exactly what Republicans wanted.”

http://www.charlotteobserver.com/opinion/article210686554.html

You notice right off that the Orwellian weasles state “get ready” to shift the narrative out of the past to the future.

“they changed the economic viability of the Affordable Care Act” It was never viable!

“Now, for many, those premiums are about to go way up” NOW???

The Greensboro News Record, predictably, repeats the big lie.

“ACA sticker shock is coming”

“For many, those premiums are about to go way up, and insurers will be able to offer less. And it’s exactly what Republicans wanted.”

http://www.greensboro.com/opinion/columns/other-opinions-aca-sticker-shock-is-coming/article_8fed46ac-f056-5ecb-adb0-12f20a397550.html

As I recall, a repeal of Obamacare was what the Republicans wanted. The Democrats blocked it.

From the Citizen Wells archives. Not erased and not rectified.

August 1, 2009.

“This YouTube video reveals the hidden truth that Obama, Nancy Pelosi and the democrat congress are hiding from the American public.”

https://citizenwells.com/2009/08/01/obama-health-care-obamacare-hidden-truth-youtube-video-nancy-pelosi-shutting-out-public-abuse-of-power/

December 7, 2009.

“Another day, another study confirming that ObamaCare will increase the price of health insurance. The Blue Cross Blue Shield Association has found that premiums in the individual market will rise on average by 54% over the status quo, which translates into an extra $3,341 a year for families and $1,576 for singles. The White House denounced the report as a “sham” before it was even released, which shows how seriously it takes such concerns.”

https://citizenwells.com/2009/12/07/blue-cross-blue-shield-rate-increase-obama-lies-blue-cross-blue-patients-obamacare-study-premiums-rise-54-congressional-budget-office-pelosi-and-reid-lies/

March 16, 2012.

“The latest revelation, reported at The Hill, is that ObamaCare could cause up to 20 million Americans to lose their health care coverage. There is a “tremendous amount of uncertainty” in the forecast, which is just what our fragile Obamanized economy needs right now, but 20 million is the CBO’s worst-case estimate. Maybe it will only be 3 to 5 million people.

https://citizenwells.com/2012/03/16/cbo-real-truth-team-unemployment-rate-15-percent-obama-deficits-1-2-trillion-2012-obamacare-costs-rise-and-causes-millions-to-lose-employer-insurance/

June 28, 2012.

“I absolutely reject that notion [mandate is a tax].”…Barack Obama

“The US Supreme Court today, June 28, 2012, in their ruling today effectively called Obama a liar.”

https://citizenwells.com/2012/06/28/us-supreme-court-declares-obama-a-liar-obamacare-is-a-tax-obama-lied-about-tax-increases-obama-fraud-and-taxes-have-devastated-economy-and-job-market/

September 4, 2012.

“Our student health insurance policy premium has been substantially increased due to changes required by federal regulations issued on March 16, 2012 under the Affordable Care Act.”…Guilford College student

“Can we stop calling ObamaCare the Affordable Care Act now?”…Ron Meyer

“I just spoke with a young man a few minutes ago who attends Greensboro College, a private college in NC. He mentioned that his health care costs had just almost doubled. Recently, reported here, was a report that the UNC system, NC public colleges, had almost doubled the health care costs for students and the reason was provisions in Obamacare.”

“Health Insurance Costs Skyrocket For College Students Due To ObamaCare”

“Can we stop calling ObamaCare the Affordable Care Act now?

A Young America’s Foundation activist forwarded an email from the Vice President for Finance at his school, Guilford College (Greensboro, NC), informing him that, “For the 2012-13 academic year, the annual cost of the student health insurance is increasing from $668 to $1,179. This insurance premium has been charged to your student account.”

Why the increase? “Our student health insurance policy premium has been substantially increased due to changes required by federal regulations issued on March 16, 2012 under the Affordable Care Act.”

“Student healthcare choice has been replaced with expensive ObamaCare mandates.”

https://citizenwells.com/2012/09/04/dnc-convention-september-4-2012-obama-cares-with-obamacare-obamacare-doubles-nc-college-student-health-care-in-2012-lies-lies-more-obama-lies/

September 26, 2012.

“Premiums for employer-provided family coverage rose $3,065 — 24% — from 2008 to 2012, the Kaiser survey found. Even if you start counting in 2009, premiums have climbed $2,370.

What’s more, premiums climbed faster in Obama’s four years than they did in the previous four under President Bush, the survey data show.”

https://citizenwells.com/2012/09/26/health-premiums-up-3000-obama-promised-2500-cut-student-health-care-doubles-triples-and-more-obamacare-another-obama-lie-kaiser-survey/

March 4, 2013.

“However … health insurance rates and benefit coverage plan costs have continued to increase. As a result of those increases, county employees have experienced a pay decrease that has grown larger each year.”…Guilford County Interim Manager Sharisse Fuller

“The county has cut costs for the past two years by increasing co-pays,
deductible amounts and out-of-pocket maximums for employees.

“Over the last four years, no merit increases have been awarded to
Guilford County employees,” Fuller said Friday in an email. “However
… health insurance rates and benefit coverage plan costs have
continued to increase. As a result of those increases, county
employees have experienced a pay decrease that has grown larger each
year.””

““It looks to me like Obamacare is causing prices to go up and will
continue to make prices go up,” Henning said. “That’s something we’re
going to have to deal with, like everyone else in this economy.”

https://citizenwells.com/2013/03/04/guilford-county-nc-healthcare-cost-increases-may-cause-benefit-cuts-obamacare-costs-no-pay-raises-in-4-years-obamacare-is-causing-prices-to-go-up/

March 15, 2013.

“The nation’s big health insurers say they expect premiums — or the
cost for insurance coverage — to rise from 20 to 100 percent for
millions of people due to changes that will occur when key provisions
of the Affordable Care Act roll out in January 2014.

Mark Bertolini, CEO of Aetna Inc., one of the nation’s largest
insurers, calls the price hikes “premium rate shock.”

“Grace-Marie Turner is president of the Galen Institute and one of the
leading policy-based critics of Obamacare.

She said House Republicans are right to keep pushing for the repeal of
Obamacare because of the myriad ways it afflicts the nation’s fiscal
health.

“When you look at the overall impact of this law on the economy, we
know that it’s hugely important in depressing job creation,” she said.
“It’s forcing companies to put people on part-time when they need
full-time workers. The incredible number of new taxes, a trillion
dollars in new taxes in this law just in its own right. It is one of
the major factors that is depressing economic growth. When you have
economic growth depressed, you don’t have the tax revenue that you
need.””

https://citizenwells.com/2013/03/15/obamacare-sticker-shock-skyrocketing-health-care-costs-job-killer-millions-to-pay-20-to-100-percent-more-in-january-2014-obamacare-set-to-implode/

YOU GET THE PICTURE!

Search on Obamacare on this site for many more examples.

Obamacare imploding and damaging our health care system and economy.

 

 

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