Looking at the

Michelle Parrini and Charles F. Williams

The recent London subway “There is always a possibility that at preventing the exercise of bombings drew renewed attention a secret police may become a First Amendment rights of to the difficulties facing government menace to free government and speech and association, on attempts to uncover and intercept ter- free institutions because it carries the theory that preventing the ror plots; though there may now be with it the possibility of abuses of growth of dangerous groups more awareness of the issue, nations power which are not always quick- and the propagation of dan- have been trying to learn their enemy’s ly apprehended or understood.” gerous ideas would protect the secrets since the beginning of recorded national security and deter vio- history. Spies appear in Homer’s Greek — The Church Committee lence…Many of the techniques epic, the Iliad. Ancient Roman writ- Report, 1976.1 used would be intolerable ings are filled with accounts of intrigue in a democratic society even and assassination plots. Caesar’s secret gence on other countries increased 39 if all of the targets had been agents looked out for his interests in percent between 1998-2002.2 Public involved in violent activity, Rome. Sun Tzu’s The Art of War (500 and congressional opinion about the but COINTELPRO went far BC) describes espionage and the use appropriate scope of covert govern- beyond that. The unexpressed of human intelligence as key to suc- ment activities, and perceptions that major premise of the programs cessful warfare. An extensive political intelligence practices have at times was that a law enforcement intelligence system served Elizabeth I. been excessive, have also influenced agency has the duty to do what- And both British and American forces voters’ support for intelligence meth- ever is necessary to combat per- employed secret agents, ciphers, and ods. For instance, in the mid-seventies, ceived threats to the existing codes, during the Revolutionary War. congressional inquiries uncovered the social and political order.3 George Washington’s coordination of FBI’s COINTELPRO (an acronym for spies and evaluation of their intelli- “COunter INTELligence PROgram”) Congressional investigations also gence information is credited with giv- and the CIA’s “Operation CHAOS” revealed CIA covert operations to help ing the Americans the strategic advan- domestic intelligence practices, mar- overthrow elected left-wing governments tage to overcome the superior military ring the reputation of both agencies. in Guatemala (1954) and Chile (1973). power of the British. According to the congressional report U.S. intelligence agencies were allegedly However, it wasn’t until the twen- known as the Church Report: involved in attempts to assassinate for- tieth century that the eign leaders, including Patrice Lumumba established a single independent gov- COINTELPRO began in 1956, (Congo), (), Rafael ernment agency devoted to gathering in part because of frustration Trujillo (Dominican Republic), and Ngo human intelligence. American support with Supreme Court rulings Dinh Diem (). According to the for both intelligence and counterintel- limiting the Government’s Church Report: ligence efforts has waxed and waned, power to proceed overtly depending on the perceived national- against dissident groups; it • The CIA illegally opened and security threats. A poll by the ended in 1971 with the threat photographed mail to or from Council on Foreign Relations and the of public exposure. In the inter- American citizens for 20 years German Marshall Fund of the United vening 15 years, the Bureau (1953–1973), generating a com- States found that public support for conducted a sophisticated vigi- puter database of 1.5 million increased spending to gather intelli- lante operation aimed squarely names.

S o c i a l E d u c a t i o n 250 • The National Security Agency (NSA) received copies of all pri-

This is a rare photograph of Allen W. (AP Photo) vate cables sent or received from Dulles, then-director of the U.S. Central abroad by Americans between IntelligenceIntelligence Agency,Agency, inin hishis Washington,Washington, 1947 and 1975. D.C., office on July 28, 1954. Here in this office, a setting where few photogra-- • For more than 30 years, U.S. phers had access, Dulles directed the intelligence agencies wiretapped super-secret CIA organization whose and bugged U.S. citizens without lineslines ofof espionageespionage andand informationinformation warrants. spread around the world and pen-- etrated behind the Iron Curtain. Behind • Army intelligence investigated him is a map which he often consulted, 100,000 U.S. citizens during the showing North America and the Soviet .4 Union at top.

Some commentators maintain that public support for intelligence in gen- eral and human intelligence in particular diminished after these revelations, and that this public distrust of covert govern- ment activities grew stronger still after Watergate and the Iran-Contra affair of the 1980s.5 Critics also say the govern- ment sought to avoid controversy by neglecting the recruitment of covert agents and increasingly relying on spy satellites and electronic intercepts—valuable tools for spying on governments and traditional militaries, but less useful in divining the plans of small terrorist cells.

The Age of Terror On February 26, 1993, a huge truck bomb was detonated in the garage directly beneath the World Trade Navy destroyer while it was refueling United States Regarding Weapons of Center in New York City. The explo- in Yemen. Then came the coordinated Mass Destruction. Acting on the recom- sion failed to topple the twin towers but attacks of September 11, 2001, that mendations contained in the latter com- succeeded in injuring more than 1,000 killed nearly 3,000 Americans. That mission’s March 2005 report, President people and killing six. Three years later, atrocity—like each of the attacks that Bush established an office to manage all on June 25, 1996, another truck bomb preceded it over an eight-year span— “human intelligence collection overseas” killed 19 Americans and wounded hun- achieved complete tactical surprise. for all government agencies, including dreds more near a U.S. military base in As in the wake of Pearl Harbor a gen- the CIA, the Army and the FBI. The new Saudi Arabia; in August of that year, eration ago, the government launched a office was established partly because the Al Qaeda leader Osama bin Laden slew of investigations and commissions to new National Counterterrorism Center issued the first in a series of public find out why we were caught unawares. The (established by Executive Order on fatwas—religious rulings—against the National Commission on Terrorist Attacks August 27, 2004) had already been found United States. Other attacks followed: upon the United States was formed in late lacking in its coordination of CIA, FBI, simultaneous explosions killed 264 2002 to investigate the circumstances Pentagon, Homeland Security, and other people at the U.S. embassies in Nairobi, surrounding the attacks and to provide agency efforts. Under the plan, the CIA Kenya, and Dar es Salaam, Tanzania, in recommendations for guarding against will coordinate all spying overseas for all 1998; seventeen American sailors were future surprise attacks. Another probe was agencies.6 Spurred by these new anti-ter- killed aboard the USS Cole in 2000 launched by the president’s Commission rorism efforts, intelligence gathering and when a bomb detonated next to the on the Intelligence Capabilities of the spying in other countries has increased.

S e p t e m b e r 2 0 0 5 251 Keeping Secrets transport these suspects to other coun- Mustafa Osama Nasr, also known as The new spy era has brought fresh tries.8 Subsequently, a series of Op Eds Abu Omar, from Italy. Omar, who is pur- challenges as well. Recent news sto- appeared in the Times denouncing the ported to have been a former CIA infor- ries have recounted a practice known paper for deliberately “blowing the mant, was supposedly taken to Egypt. as “extraordinary renditions.” These cover” of the CIA’s covert air opera- Italian prosecutors issued 13 warrants renditions are part of a CIA program tion and contending that publishing for 13 of the 19 CIA officials involved in that involves capturing suspected the information will hamper the war the rendition, marking the first known terrorists and transporting them for on terror. One writer countered with, instance of one government charging a interrogation to other countries, often “I remember when we were proud of foreign government with committing a countries that have been known to Seymour M. Hersh’s stories disclosing crime as a part of its covert intelligence use torture as an interrogation tool.7 CIA plots to assassinate people.”9 operation. One of the 19 individuals is One New York Times account revealed In addition, in recent weeks, news- reportedly a CIA operative and report- the CIA’s use of certain shell com- papers have extensively covered the ing indicates that other CIA officials panies (companies that exist in name story of an alleged February 2003 CIA were allegedly involved.10 only) and private charter companies to rendition of an Egyptian cleric, Hassan

Early U.S. Intelligence Activities Selective Service, and Sabotage acts, and for seeking out enemy aliens. Aided by double agent William Sebold, the For much of the nineteenth century, the U.S. did not allocate FBI prosecuted the German spy ring headed by Frederick many resources to intelligence gathering. Many Americans Duquesne (1942). And from 1940 to 1946, it headed up were wary of espionage, partly because of the disrepu- the Special Intelligence Service, a special division of covert table association of espionage with the Pinkerton National agents stationed in Central and South America. Similarly, Detective Agency, the nation’s first private detective and the Military Department’s G-2, or Intelligence Division, and police agency. Although the Pinkertons the Office of Naval Intelligence conducted discovered an assassination plot against intelligence work, and the Army and Navy Lincoln in 1850 and subsequently pro- had separate bureaus monitoring foreign vided intelligence to the North during the communication. In the 1930s, with conflict Civil War, the agency later worked exten- escalating in Europe, and frustrated by sively for industrialists as strike breakers lack of coordination, President Roosevelt in conflicts that turned bloody, infiltrating created the Coordinator of Information, a and spying on fledgling labor unions. In civilian agency, further duplicating many addition, secretive executive diplomacy, existing efforts. Scattershot coordination such as the overthrow of the Hawaiian followed America’s entry into World War courtesy of the Library of Congress Queen Lili’uokalani to secure colonial II, and two new offices were created—the Hawaii, contributed to existing distrust of Office of War Information and Office of covert undertakings among some mem- Strategic Services (OSS). 20 bers of Congress. This distrust carried At the conclusion of the war, the OSS over into the early twentieth century. For Allan Pinkerton, founder of Secret Intelligence Branch ran extensive instance, Secretary of State Henry Stimson the first private detective operations in Asia, Europe, and the Middle dismantled the country’s first code-break- agency in the United States. East. Furthermore, by 1945, in addition ing operation, MI8, in 1929, which was run to running operations in foreign capitals, by the State Department and Army. “Gentlemen,” he said, such as Bern, Switzerland, 200 agents had been “dropped” “don’t read each other’s mail.” into Nazi Germany and were gathering information from In the realm of twentieth-century counterintelligence, a Berlin to Munich and Vienna. Although the successes of the variety of government departments responsible for foreign OSS are celebrated, throughout the war intelligence efforts policy initially engaged in discrete espionage operations remained fragmented and interagency infighting persist- with little cross-agency coordination. The FBI, formed in ed.21 The surprise attack on Pearl Harbor on July 7, 1941, 1908, originally served solely as the investigative arm of the underscored the need for coordinated U.S. intelligence Justice Department. For much of its history the FBI investigat- efforts. As a result, the CIA and National Security Council ed political dissidents and criminal cases. During World War I, were established in 1947, from the World War II Office of the FBI was responsible for the mandates of the Espionage, Strategic Services.

S o c i a l E d u c a t i o n 252 Meanwhile, columnist Robert Amendment implications of this sec- lomat was also allegedly the target of an Novak’s decision to name CIA agent tion, 421 (c), which described disclo- unsuccessful attack after being named Valerie Plame who was (at least at one sures by individuals who never had in Covert Information Bulletin.18 point) a covert operative, led to the access to classified information. It was Accounts of the Allies’ World War appointment of an independent coun- widely thought that II counterintelligence efforts feature sel who is now investigating whether such triumphs as cracking the code used any were broken by leakers in Those who republish previous by the Nazi cipher machine Enigma. the . Novak identified disclosures and critics of U.S. stories, by contrast, often Plame as an “operative on weapons of intelligence would all stand describe the morally murky world of mass destruction” in his July 14, 2003, beyond the reach of the law if infiltrations, subversions, and attempt- syndicated column.11 Plame’s husband, they did not engage in a pattern ed assassinations. The Cold War spy, former ambassador Joseph Wilson IV, of activities intended to identify mole, or “sleeper” has been roman- claimed the leak was in retaliation for and expose covert agents.15 ticized, vilified and sometimes paro- his criticism of the Bush administration. died in countless novels, as in Graham Wilson had reproached the administra- To date, Novak has not been Greene’s Our Man in Havana. Real- tion for ignoring his fact-finding mis- charged with a crime, but two other life double agents, such as Aldridge sion to Niger—where he said he found reporters, Judith Miller of The New Ames, who spied for the Soviets for 11 no evidence that Saddam Hussein had York Times, and Matthew Cooper of years, and a recent spate of spy mem- sought to buy uranium from that coun- Time Magazine were charged with oirs, provide more realistic pictures of try—when the president stated in his contempt of court for refusing to reveal spying in Poland, Czechoslovakia, and 2003 State of the Union Address that their confidential sources to a grand Hungary, and CIA operations in Laos the British government had learned jury. Cooper had written an article and the Congo.19 Saddam Hussein had recently sought after the Novak column was published, At home, FBI agent Robert significant quantities of uranium from “raising questions about government Philip Hanssen was uncovered as a Africa.12 officials trying to discredit Wilson’s Soviet mole in February 2001after he Administration defenders claim the claims.” Miller conducted interviews, left classified documents at a “dead leak was likely merely intended to alert but did not publish an article. The drop” in Foxstone Park, Virginia. reporters that Wilson had not been sent Supreme Court declined to hear the Counterintelligence investigators even- to Niger at the administration’s request, journalists’ appeals.16 Time magazine tually learned that he had been secretly as he implied, but had actually been handed over all documents related to spying for the Russians for more than given the mission at the behest of his the case, which indicated that White 15 years. wife, who worked at the CIA. The spe- House Deputy Chief of Staff Karl cial prosecutor has been trying for two Rove was one of his sources, and on The Spy Who Petitioned for years to uncover the sources of the leak. July 11, 2005, Cooper agreed to testify Judicial Review Under the 1982 Intelligence Identities after his source waived any claim to America also tries to recruit such moles, and Protection Act, it’s a felony for a confidentiality.17 but the rules governing such schemes are government official with access to clas- If someone is indicted as the result hazy. Unlike most government activities, sified information to knowingly reveal of these investigations it would be the spying is largely free from judicial over- to an unauthorized person a covert first attempt to bring a prosecution sight, first because the courts aren’t told agent’s identity while the United States under the 1982 act, which was passed what the agencies are doing and second, is “taking affirmative measures” to con- after former CIA agent Philip Agee as illustrated by a case decided in the ceal the agent’s identity.13 Additionally, co-edited “Dirty Work: The CIA in Supreme Court last term, they are loathe the covert agent must have been work- Western Europe,” which revealed the to ask. ing outside the United States in the past names of numerous alleged CIA offi- The lawsuit underlying Tenet et five years for the law to apply. cers. Around the same time, a publica- al. v. Doe et ux., No. 03-1395 (2005), The law also includes provisions tion called Covert Action Information was brought by a couple using the fic- for prosecution of nongovernmental Bulletin included a section called titious names of John and Jane Doe. employees who disclose informa- “Naming Names” and may have dis- According to the Does—the CIA tion “in a course of pattern of activi- closed as many as 2,000 names. After refused to confirm or deny any aspect ties intended to identify and expose his name was published in Covert of their story—John Doe was a high- covert agents.”14 At the time, the Senate Action and in another publication, ranking diplomat for a country in the Judiciary and Conference Committee Counterspy, Richard Welch, the CIA former Soviet bloc when he sought members considering the law were station chief in Athens, Greece, was to defect to the United States. The mostly concerned about the First killed. An unidentified American dip- CIA, however, talked him into remain-

S e p t e m b e r 2 0 0 5 253 †he Shadow War | Teaching Activities 1. Provide students with relevant facts on the investiga- suit in a court of justice, the trial of which would tion into the exposure of Valerie Plame as an “operative inevitably lead to the disclosure of matters which on weapons of mass destruction,” either as presented the law itself regards as confidential, and respect- in this article or in more recent news accounts. Divide ing which it will not allow the confidence to be students into small groups. Ask each group to analyze the violated. Intelligence Identities Protection Act (50 U.S.C. § 421) and to determine who, if anyone, could be indicted under the Break students into small groups. Ask them to write a bill act. After the groups reconvene and present their findings, outlining circumstances under which covert agents may ask students if they believe the law as it stands is sufficiently bring suits in federal court. Remind them that the bill must explicit and comprehensive to deter individuals from contain procedures to address national security concerns revealing the identity of covert agents. If not, ask them to that could arise in these cases. Note that the Supreme indicate which sections of the law should be changed, and Court’s opinion in Tenet (available at www.supremecour- how. Ask students to give their reasons. Finally, ask students tus.gov) mentions two such procedures: (1) “in camera” to craft new language for the revisions. Note: Text of the review of evidence, whereby a judge could review sensi- law is available on the web from many sources. tive evidence in chambers before deciding whether it should be admissible; and (2) use of the “state secrets 2. In his concurrence in Tenet et al. v. Doe et ux., Justice privilege,” which a government lawyer could invoke by Stevens, joined by Justice Ginsburg writes, objecting every time a plaintiff tried to introduce evidence There may be situations in which the national interest that would jeopardize national security. (The state secrets would be well served by a rule that permitted simi- privilege is an “absolute privilege” that renders the chal- lar commitments made by less senior officers to be lenged information unavailable in litigation. According to enforced in court, subject to procedures designed to the Justice Department, this privilege has been recognized protect sensitive information. If that be so, Congress by U.S. courts as far back as the nineteenth century, and can modify the federal common-law rule announced allows the executive branch to “safeguard vital information in Totten. regarding the nation’s security or diplomatic relations.”) Explain to students that in Totten v. United States, 92 The first part of the bill should describe the problems U.S. 105 (1876), the Court held that an alleged oral agree- that the legislation is intended to address. While students ment between a deceased Civil War spy and President present their legislation, note features of each on the board. Lincoln was unenforceable. Give them this quote from Next, note similarities and differences in each bill. As a the decision: class, come to a consensus about desirable features for such …It may be stated as a general principle, that legislation. Craft a final model bill. public policy forbids the maintenance of any

Resources U.S. House of Representatives Permanent Committee on Intelligence—intelligence.house.gov/ This site houses an “Intelligence Library” with current and past commit- Federation of American Scientists—www.fas.org/main/home.jsp tee reports as well as Intelligence Authorization Act Committee Reports This website has an extensive section on intelligence with current intelli- and Intelligence Authorization Act Conference Reports. gence news, links to congressional material on intelligence, Congressional Research Service Reports, a collection of official government documents, National Commission on the Terrorist Attacks Upon links to world intelligence organizations, and more. the United States—www.9-11commission.gov/ Although no new information has been added to this site since U.S. Senate Select Committee on Intelligence September 2004, it houses the 9/11 Commission final report in pdf and —intelligence.senate.gov/ html format. Committee publications and reports, as well as information on intelli- gence legislation, are available on this site, as well as links to the CIA, FBI, Central Intelligence Agency—www.cia.gov/index.html National Security Agency, and the Defense Intelligence Agency. The publications section of the CIA website houses a number of acces- sible “histories” of intelligence, including “Intelligence in the War on Independence,” and “Black Dispatches: Black American Contributions to Union Intelligence During the Civil War.”

S o c i a l E d u c a t i o n 254 Abroad,” The Washington Post, (June 29, 2005); ing in his job where he could spy for “unacceptable” risk of revealing espio- “An End to Spy v. Spy,” Los Angeles Times (July 5, America. In return for this dangerous nage relationships. It said it also feared 2005). work, he says, the CIA promised to that forcing the government to litigate 7. Jane Mayer, “Outsourcing Torture: The Secret History of America’s ‘’ bring him and his wife to the United these claims would make it vulner- Program,” The New Yorker (February 14, 2005) also States and ensure their “financial and able to “graymail” in which individual available online at www.newyorker.com/fact/ personal security for life.” According lawsuits could be brought “to induce content/?050214fa_fact6. 8. Scott Shane, “CIA Expanding Terror Battle under to the Does, the CIA eventually did the CIA to settle a case (or prevent Guise of Charter Flights,” bring them to America. It gave them its filing) out of fear that any effort to (May 31, 2005). 9. Anthony Lewis, “Letters to the Public Editor; Other new names and false backgrounds, and litigate the action would reveal classi- Voices: When the Times Writes about Covert helped John Doe find a job in the state fied information that may undermine Operations,” The New York Times (June 20, of Washington. Doe says he agreed to ongoing covert operations.” 2005). 10. Jim Hoagland, “Pricey Rendition,” The Washington accept reductions in his CIA stipend as The result is that the judicial Post (July 3, 2005); Associated Press, “Report: his salary increased until the stipends branch has now positioned itself so as Egyptian Iman Was a CIA Informant,” The Washington Post (July 2, 2005); Craig Whitlock and stopped altogether. to play a minimal role when the execu- Dafna Linzer “Italy Seeks Arrests of 13 in Alleged But then, after having enjoyed the tive branch demands that a case be Rendition,” The Washington Post (June 25, benefits of capitalism, in 1997 Doe dismissed on national security grounds. 2005). 11. See Petitions for a Writ of Certiorari to the United experienced the downside when he In other words, if the pendulum of States Court of Appeals for the District of Columbia was laid off after a corporate merger. trust in our spy agencies swung far in Circuit, and Brief for the United States in Opposition in Miller v. United States of America and Matthew He said that, unable to find a new job the direction of skepticism after the Cooper, and Time Inc., v. United States of America, as the result of CIA restrictions on the abuses during the 1960s and 1970s, it Nos. 04-1507 and 04-1508. type of jobs he could hold, he asked would seem to have swung quite far in 12. Scott Shane, “Private Spy and Public Spouse Live at Center of Leak Case,” The New York Times (July the CIA to renew its financial assis- the other direction after September 11, 5, 2005); Carol Leonnig, “Time Magazine to tance, but the agency turned him down. 2001. Cooperate in Plame Case Probe,” The Washington At that point the Does turned to the Post (June 30, 2005). 13. Intelligence Identities Protection Act of 1982, 50 courts for help, arguing that the CIA Notes U.S.C. § 421 et seq. had violated their due process rights 1. “Intelligence Activities and the Rights of Americans 14. Id., 50 U.S.C. § 421(c). Book II,” in Final Report of the Select Committee by denying them support and failing to to Study Governmental Operations with Respect 15. “Intelligence Identities Protection Act,” Congressional Research Service Report for Congress provide them with a fair internal pro- to Intelligence Activities (, Together with Additional, Supplemental, and by Elizabeth B. Bazan (October 3, 2003), 5. cess for reviewing their claims. Separate Views, April 26 [legislative day, April 14, Available at the Federation of American Scientists’ The CIA replied that it did not 1976]). website www.fas.org/sgp/crs/intel/index.html. 16. Carol D. Leonnig, “Reporters Lose Appeal, Face have to respond to the allegations (or 2. Chicago Council on Foreign Relations and the German Marshall Fund of the United States, Jail Time,” The Washington Post (June 28, 2005). confirm or deny that the petitioner had Worldview 2002: A World Transformed: Foreign 17. Adam Liptak, “For Time, Inc. Reporter, a Frenzied worked for the agency at all) and that Policy Attitudes of the U.S. Public after Decision to Testify,” The New York Times (July 11, September 11. 2005). the case should be dismissed. In the 3. “Supplementary Detailed Staff Reports on 18. According to Bazan’s Congressional Research agency’s view, a 129-year-old Supreme Intelligence Activities and the Rights of Americans, Service report, no published accounts of prosecu- Book III,” in Final Report of the Select Committee tions under the Intelligence Identities Protection Act Court case had already established that to Study Governmental Operations with Respect could be found, pgs. 2-5; Mitchell J. Michalec, the courts were barred from consider- to Intelligence Activities (United States Senate, April “Notes: The Classified Information Protection Act: ing such due process and tort claims. 23 [Under Authority of the Order of April 14] Killing the Messenger or Killing the Message?” 50 1976). Clev.St.L.Rev. 455 (2002/2003). In Totten v. United States, 92 U.S. 105 4 “Intelligence Activities and the Rights of Americans 19. Tim Weiner, “Chronicle/CIA Memoirs; The Spying (1876), the agency pointed out, the Book II,” United States Senate. Game,” The New York Times (April 10, 2005). Court had held that an alleged oral 5. During the (1972-1974), President 20. Office of Strategic Services: America’s First Nixon and his chief of staff, H.R. Haldeman, were Intelligence Agency, Public Affairs, Central agreement between a deceased Civil audio taped in the Oval Office discussing whether Intelligence Agency, www.cia.gov/cia/publications/ War spy and President Lincoln was to ask the CIA to obstruct the FBI’s investigation of oss/index.htm. a series of break-ins at the Democratic National 21. Ibid. unenforceable. Committee headquarters, orchestrated by the The Supreme Court agreed, citi- Committee to Re-elect the President. The Senate The ABA Division for Public investigation requested the Nixon tapes, and Nixon Education offers handbooks, ing the possibility that allowing suits refused to turn them over, citing executive privilege instructional materials, and such as the Does’ to proceed posed an and national security concerns. The U.S. Supreme many other learning tools for Court in United States v. Nixon, 418 U.S. 683 (1974), educators, students, and community members decided that Nixon must turn over the tapes. Nixon interested in increasing their understanding of resigned the presidency on August 8, 1978. the law and legal system, and their ability to The Iran-Contra Affair involved a secret sale become productive contributors to the civic Michelle Parrini is program manager with the of arms to Iran in exchange for Iranian efforts to life of communities. For more information ABA Division for Public Education, and Charles F. secure the release of American hostages being held about these services contact the ABA Division Williams is the editor of Preview of United States in Lebanon. Proceeds from the sale were secretly for Public Education, 321 N. Clark Street, Chicago, Supreme Court Cases, a publication of the Division diverted to anti-Sandinista guerillas rebelling against Illinois, 60610; Phone: 312-988-5735; Email: [email protected] for Public Education. the left-wing Sandinista government of Nicaragua. 6. Walter Pincus, “New Office to Oversee Intelligence www.abanet.org/publiced

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