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In the United States District Court for the District of Columbia
Case 1:13-cv-00825-ABJ Document 73 Filed 10/15/15 Page 1 of 26 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) GILBERTE JILL KELLEY, et al., ) Plaintiffs, ) ) v. ) Civil Action No. 13-cv-825 (ABJ) ) THE FEDERAL BUREAU OF ) INVESTIGATION, et al., ) ) Defendants. ) ) DEFENDANT FBI’S MOTION FOR A PROTECTIVE ORDER Defendant the Federal Bureau of Investigation (“FBI” or “the Bureau”), by and through undersigned counsel, and pursuant to Federal Rules of Civil Procedure 30(d)(3) and 26(c), respectfully moves the Court for a protective order: (a) Limiting the September 2, 2015, deposition of FBI Supervisory Special Agent Adam Malone (to the extent the deposition remains open and continued) on the Rule 30(d)(3) ground that certain portions of the deposition were “conducted in bad faith or in a manner that unreasonably annoys, embarrasses, or oppresses” the witness or the FBI pursuant to Fed. R. Civ. P. 30(d)(3); and (b) Restricting, pursuant to Rule 26(c), any further FBI-related discovery to the discovery of (1) facts sufficient to show disclosure(s) to the media by one or more FBI employees in a manner violating the Privacy Act, and (2) facts relating to the governments’ defenses to the plaintiffs’ remaining claims. Co-defendant the Department of Defense (“DoD”) concurs with the motion. Pursuant to Local Civil Rule 7(m), counsel for defendants have met and conferred with counsel for plaintiffs. Plaintiffs oppose this motion. For the reasons stated in the accompanying Statement of Points and Authorities and the FBI’s proposed Under Seal Supplement, the Court should grant the instant motion. -
News Magazine Coverage of the Petraeus/Broadwell Affair: The
Research In Depth News Magazine Coverage of the Petraeus/Broadwell Affair: The Disjunction between Power and Agency By Tetyana Lokot, Antonio Prado, become more likely to think that off-hours morality Boya Xu, and Linda Steiner and marital infidelity are relevant to the career as- sessment of those political figures, potentially forc- All four authors are in the Philip Merrill College of Jour- ing the resignation or firing of a scandalous figure. nalism at the University of Maryland. No wonder, then, that the extramarital affair be- tween General David Petraeus (Ret), then Director Tetyana Lokot is a doctoral candidate whose research inter- of the Central Intelligence Agency (CIA), and his ests include augmented dissent and the use of digital me- biographer Paula Broadwell aracted significant dia and social networks in protests in post-Soviet coun- media aention in November and December 2012, tries. dominating front pages and leading broadcast news shows. Admiing his sexual relationship with Antonio Prado is a doctoral candidate whose research in- Broadwell, Petraeus resigned as the CIA Director terests include collective contemplation enabled by con- aer major FBI investigations. temporary communications technology, news portrayals of The FBI and Justice Department recom- people with disabilities, and convergence culture. mended bringing felony charges against Petraeus, saying that while CIA director, he provided classi- Boya Xu is a doctoral candidate whose research interests fied information to Broadwell, whom the New York include media effects, audience studies, public sphere in Times described as his lover and mistress. Ultimate- the digital era, and political communication. ly, Petraeus was convicted of non-felony mishan- dling of classified materials. -
Spring/Summer 2017 • Image
SPRING/SUMMER 2017 • IMAGE Publisher — OCA - Asian Pacific American Advocates Executive Editor — Miriam Yeung Managing Editor — Nick Lee Contributors — Ezra Calado, Roland Hwang, Daphne Kwok, Nick Lee, Morales Lo, Elizabeth OuYang, Linda Ching Sledge, Medona Samuel, Lavinia Clara Tamoepeau-Latu, About OCA – Asian Susie Y. Wong Contact: IMAGE with comments or sponsorship inquiries: Pacific American OCA - Asian Pacific American Advocates ATTN: IMAGE magazine Advocates 1322 18th St NW Washington, DC 20036 OCA - Asian Pacific American Advocates is a national membership-driven organization of community Telephone: 202.223.5500 advocates dedicated to advancing the social, political, Fax: 202.296.0540 and economic well-being of Asian Pacific Americans Email: [email protected] (APAs) in the United States. Website: www.ocanational.org To fulfill its mission, OCA has adapted the following OCA Executive Council goals to: President — Leslie Moe-Kaiser Advocate for social justice, equal opportunity and Executive Vice President — Edward Lew fair treatment; Treasurer — Astria Wong Promote civic participation, education, and Secretary — Michael Head leadership; Advance coalitions and community building; and Vice Presidents of: Foster cultural heritage Communications — Miriam Yeung Chapter Development — Eric Lin Founded as Organization of Chinese Americans in Economic Development — Linda Ng 1973, OCA has since grown to a robust national Education and Culture — Stan Lou advocacy organization to advance the civil rights of Finance — William (Bill) Kaung Public Affairs — Vicki Shu Asian Pacific Americans and aspiring Americans. The Membership Services — Thong Tarm organization presently has over 100 chapters, affiliates, Immediate Past President — Sharon Wong and partners, impacting more than 35,000 individuals General Counsel — Ada Loo all across the country through local and national programming. -
Kelley.V..Fbi.Amended.11-22-13.Pdf
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Gilberte Jill Kelley, and ) Scott Kelley, M.D. ) 1005 Bayshore Blvd. ) Tampa, Florida 33606 ) ) Plaintiffs, ) Civil Action No: 13-cv-825 (ABJ) ) v. ) ) The Federal Bureau of Investigation, ) 935 Pennsylvania Avenue, N.W. ) Washington, D.C., 20535-0001, ) ) United States Department of Defense ) 1400 Defense Pentagon ) Washington, D.C., 20301, ) ) United States Department of State ) 2201 C Street NW ) Washington DC, 20520 ) ) The United States of America ) 950 Pennsylvania Ave., NW ) Washington DC, 20530, ) ) Leon Edward Panetta ) ) Sean M. Joyce ) ) George E. Little ) ) Steven E. Ibison ) ) Adam R. Malone ) ) John and Jane Does 1 through 10 ) individually, ) 1 Defendants. ) 1 By agreement with counsel for the FBI, DOD State Department and United States, home addresses for the individual defendants have been suppressed out of respect for the privacy and security of the current and former government officials named. 1 VERIFIED FIRST AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL 1. Plaintiffs Mrs. Gilberte Jill Kelley and Scott Kelley, M.D., bring this action to vindicate their legal rights to privacy and dignity that were infringed by the government’s improper searches, maintenance, and disclosures of their personal, private, and confidential information. While the government’s investigation led to the resignation of Central Intelligence Agency (“CIA”) Director David Petraeus (“Director Petraeus”) and abrupt retirement of General John Allen, the government was not legally entitled to treat the Kelleys’ like criminals, pry into and disclose their personal communications, violate their privacy, and disseminate confidential records as well as false information about them. 2. Therefore, Mrs. -
Syllabus Principles and P
“I wish I’d had the courage to live a life true to myself, not the life others expected of me.” Bronnie Ware, The Top Five Regrets of the Dying http://www.inspirationandchai.com/Regrets-of-the-Dying.html SYLLABUS PRINCIPLES AND PRACTICES OF EFFECTIVE LEADERSHIP Fall 2014 Faculty: Howard T. Prince II Course Number: PA 388L Unique Number: 63640 Meeting Time: Wednesday, 2:00pm-5:00pm Location: SRH 3.316 TABLE OF CONTENTS I. Office Hours/Introduction: p. 2 II. The Learning Plan, p. 3 A. Learning Outcomes: p. 3 B. Required Books, p. 3 C. Reserve Reading, p. 4 D. Use of Class Time, p. 4 E. Attendance Policy, p. 5 H. Use of cell phones and laptops in class policy, p. 6 I. Academic Honesty, p. 6 J. Grading, p. 7 K. Course Requirements, p. 8 L. Schedule of Due Dates for Requirements, p. 11 M. Class Calendar, p. 13 III. Lesson Assignments, p. 18 IV. Appendices Appendix 1, p. 25 Appendix 2A, p. 27 Appendix 2B, p. 32 Appendix 3, p. 36 Appendix 4, p. 37 Return to Table of Contents 2 “Your job is not to be the smartest guy in the room. It is to make everyone else think they are the smartest person in the room and develop them so they really are.” The Talent Masters, Bill Conaty and Ram Charan SYLLABUS PRINCIPLES AND PRACTICES OF EFFECTIVE LEADERSHIP Fall 2014 Faculty: Howard T. Prince II Course Number: PA 388L Unique Number: 62700 Meeting Time: Wednesday, 2:00pm-5:00pm Location: SRH 3.316 Office: SRH 3.267 Office Hours: Wednesday 10:00-12:00 AM or by appointment Office Phone: 512-471-4303 E-mail: [email protected] Course Assistant: Tomas Gomez, SRH 3.280, Tel. -
The Army Lawyer, July 2012
THE ARMY LAWYER Headquarters, Department of the Army July 2012 ARTICLES A Justi ce Manager’s Guide to Navigati ng High Profi le Cases Major Nathan J. Bankson TJAGLCS FEATURES Lore of the Corps An Offi cer Candidate School for Army Lawyers? The JAG Corps Experience (1943–1946) USALSA REPORT Trial Judiciary Note A View from the Bench: Claiming Privilege Against Self-Incriminati on During Cross-Examinati on Lieutenant Colonel Fansu Ku BOOK REVIEWS The Good Soldiers Reviewed by Major Thomas L. Clark CLE NEWS CURRENT MATERIALS OF INTERESTS Department of the Army Pamphlet 27-50-470 Editor, Captain Takashi Kagawa Technical Editor, Charles J. Strong The Army Lawyer (ISSN 0364-1287, USPS 490-330) is published monthly The Judge Advocate General’s School, U.S. Army. The Army Lawyer by The Judge Advocate General’s Legal Center and School, Charlottesville, welcomes articles from all military and civilian authors on topics of interest to Virginia, for the official use of Army lawyers in the performance of their military lawyers. Articles should be submitted via electronic mail to legal responsibilities. Individual paid subscriptions to The Army Lawyer are [email protected]. Articles should follow The available for $45.00 each ($63.00 foreign) per year, periodical postage paid at Bluebook, A Uniform System of Citation (19th ed. 2010) and the Military Charlottesville, Virginia, and additional mailing offices (see subscription form Citation Guide (TJAGLCS, 17th ed. 2012). No compensation can be paid for on the inside back cover). POSTMASTER: Send any address changes to The articles. Judge Advocate General’s Legal Center and School, 600 Massie Road, ATTN: ALCS-ADA-P, Charlottesville, Virginia 22903-1781. -
1 UNITED STATES DISTRICT COURT for the DISTRICT of COLUMBIA Gilberte Jill Kelley, and Scott Kelley, M.D. 1005 Bayshore Blvd
Case 1:13-cv-00825 Document 1 Filed 06/03/13 Page 1 of 65 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Gilberte Jill Kelley, ) and ) Scott Kelley, M.D. ) 1005 Bayshore Blvd. ) Tampa, Florida 33606 ) ) Civil Action No: _______ Plaintiffs, ) ) v. ) ) The Federal Bureau of Investigation, ) and Robert S. Mueller, III, in his official ) capacity as the Director of the Federal ) Bureau of Investigation, ) 935 Pennsylvania Avenue, N.W. ) Washington, D.C., 20535-0001, ) ) United States Department of Defense ) 1400 Defense Pentagon ) Washington, D.C., 20301, ) ) The United States of America ) 950 Pennsylvania Ave., NW ) Washington DC, 20530, ) ) FBI John and Jane Does 1 through 10 ) individually, ) ) DOD John and Jane Does 1 through 10 ) individually, and ) ) USG John and Jane Does 1 through 10 ) individually, ) ) Defendants. ) ) VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL 1. Plaintiffs Mrs. Gilberte Jill Kelley and Scott Kelley, M.D., bring this action to 1 Case 1:13-cv-00825 Document 1 Filed 06/03/13 Page 2 of 65 vindicate their legal rights to privacy and dignity that were infringed by the government’s improper disclosures of their personal, private, and confidential information. While the facts ultimately leading to the resignation of Central Intelligence Agency (“CIA”) Director David Petraeus (“Director Petraeus”) and abrupt retirement of General John Allen are by now very well known, there was no legally acceptable reason for the government to disclose confidential information about the Kelleys and thereby make them part of the public scandal. 2. Therefore, Mrs. Kelley and Dr. Kelley make this complaint against the Federal Bureau of Investigation, and Robert S. -
Overexposed-Project
Overexposed Profiles and photos of Overexposed artwork series. Research assembled by Paolo Cirio, 2014-2015. http://paolocirio.net/work/hd-stencils/overexposed Keith Alexander Keith seems excited for this selfie taken by Corrie Becker, a mysterious acquaintance of his whom he shares no apparent social connection with. He has his neck tucked into his collar and an awkward smile plastered across his face. He and Corrie appear to be close and intimate, having fun with the selfie. The location where this photo was taken and how these two met each other is unclear. Corrie stated on her Facebook post, “Look who takes a great #Selfie - General Keith Alexander, the Cowboy of the NSA.” The photo was obtained from Facebook via Corrie Becker's account. Dated May 27th, 2014.1 Keith Brian Alexander served as Director of the National Security Agency (NSA) until 2013 and is now a retired four-star general. He was also Chief of the Central Security Service (CHCSS) and Commander of the U.S. Cyber Command. Alexander held key staff assignments as Deputy Director, Operations Officer, and Executive Officer both in Germany and during the Persian Gulf War in Operation Desert Shield and Operation Desert Storm. He also served in Afghanistan on a peacekeeping mission for the Army Deputy Chief of Staff for Intelligence. In Saudi Arabia he presided over the Navy’s 10th Fleet, the 24th Air Force, and the Second Army. Among the units under his command were the military intelligence teams involved in torture and prisoner abuse at Baghdad’s Abu Ghraib prison.2 Two years later, Donald Rumsfeld appointed Alexander director of the NSA. -
1 Apologia Speech and Analysis: General Petraeus and CIA Scandal
1 Apologia Speech and Analysis: General Petraeus and CIA Scandal By: Lauralee Gilkey and Drusilla Muraibto Background On November 9, 2012 General Petraeus resigned from his position as Director of the CIA following a FBI investigation that revealed he had an affair with his biographer, Paula Broadwell. Shortly after Petraeus resigned, it was revealed that the FBI had been investigating Petraeus for some time. There were concerns about possible security leaks, which have lead to further investigations. Petraeus was a four-star general who led the military through the Afghanistan and Iraqi wars. In 2010 he retired from the military after 37 years of service and assumed the position of director of the CIA. Paula Broadwell was a fellow West Point graduate, Harvard graduate and had served the U.S. Army for 15 years. The pair met in 2006 when Petraeus addressed Broadwell’s class at Harvard. Later, she approached him about composing a book based on his wartime leadership. He agreed and by 2010 he had granted her free access, including lodging at his base in Kabul when he took control of Afghanistan. The investigation started when harassment allegations had been made against Broadwell. Broadwell was suspected of sending emails to Jill Kelley, a family friend of Petraeus, accusing her of engaging in an inappropriate relationship with him. The investigation began with a warrant to search through Broadwell’s emails. There the FBI found details of Petraeus and Broadwell’s affair. Both Petraeus and Broadwell were interviewed separately by the FBI in October and admitted to the affair. Both Petraeus and Broadwell were married at the time of the affair. -
Reviews the Human Experience of War
Reviews The Human Experience of War Inferno: The World at War, 1939– covers the major high-level aspects of The striking feature of the book is its 1945. Max Hastings. Random House. the war; Andrew Roberts’ The Storm of use of hundreds of vivid personal testi- 729 pages; black-and-white photographs; War: A New History of the Second World monies to brilliantly illustrate its theme. maps; notes; index; $35. War, which focuses on the German The opening pages describe the enthu- side of the war; and other works that siasm of a young Polish fighter pilot in By COL Stanley L. Falk analyze strategy and tactics or key de- the first days of war: “We wanted to U.S. Army retired cision making. Hastings’ long, sweep- fight, it excited us, and we … didn’t be- ing panorama covers most events of lieve that something bad could really orld War II has been over for World War II but concentrates on happen.” A euphoric young German Wnearly 67 years, yet interest in those ordinary individuals whose spe- expressed this “wonderful feeling” to the great conflict is still as strong as cific experiences are often overlooked be marching into Poland, but then, as ever. New books, from small battle in more general studies. German bombs killed women and chil- studies to large overall accounts, con- dren, a nurse saw a “procession of tinue to appear and flourish. One of wounded, … an unending march of the latter, and certainly one of the best, death,” and a senior British observer is Max Hastings’ Inferno: The World at wrote bitterly that “I saw the very face War, 1939–1945, an in-depth examina- of war change—its glory shorn … tion of the human side of the war. -
Conflicts of Interest in the Syria Debate
Conflicts of interest in the Syria debate An analysis of the defense industry ties of experts and think tanks who commented on military intervention October 2013 About the Public Accountability Initiative The Public Accountability Initiative (PAI) is a non-profit, non-partisan research and educational organization focused on corporate and government accountability. In addition to publishing research on critical public accountability issues, PAI maintains LittleSis.org, an involuntary facebook of powerful people and tool for power research that was used to compile data for this report. PAI’s work is funded by a variety of non-profit sources (all funding sources are listed at http://public- accountability.org/about/funding). This report was authored by PAI research analysts Gin Armstrong and Whitney Yax, and PAI director Kevin Connor. Introduction During the public debate around the question of whether to attack Syria, Stephen Hadley, former national security adviser to George W. Bush, made a series of high-profile media appearances. Hadley argued strenuously for military intervention in appearances on CNN, MSNBC, Fox News, and Bloomberg TV, and authored a Washington Post op-ed headlined "To stop Iran, Obama must enforce red lines with Assad." In each case, Hadley's audience was not informed that he serves as a director of Raytheon, the weapons manufacturer that makes the Tomahawk cruise missiles that were widely cited as a weapon of choice in a potential strike against Syria. Hadley earns $128,500 in annual cash compensation from the company and chairs its public affairs committee. He also owns 11,477 shares of Raytheon stock, which traded at all-time highs during the Syria debate ($77.65 on August 23, making Hadley’s share’s worth $891,189). -
The Collapse of Parenting October 2016 Leonard Sax MD Phd
The Collapse of Parenting October 2016 Leonard Sax MD PhD www.leonardsax.com Please note: this hand-out is intended as a supplement to the presentation, not as a substitute for the presentation. This handout is NOT intended to be read separately from the presentation; it cannot “stand alone.” If you would like to get a sense of the presentation but did not have the opportunity to attend, please read my second book Boys Adrift, especially chapters 3 and 8; also my third book Girls on the Edge, especially chapters 1, 2, and 3; and my most recent book The Collapse of Parenting. You can reach me at [email protected] but please also send a copy to my personal email [email protected]. Jean Twenge and colleagues, “Birth cohort increases in psychopathology among young Americans, 1938–2007: A cross-temporal meta-analysis of the MMPI”, Clinical Psychology Review, 30:145-154, 2010. Full text online at http://www.selfdeterminationtheory.org/SDT/documents/MMPIchangeCPR.pdf. Jean Twenge’s research on the rise in anxiety among teenagers over the past five decades is presented in an accessible format in her books Generation Me (Free Press, 2007) and The Narcissism Epidemic (Free Press, 2010). In the past ten years, the social media have displaced the diary. It is now unusual to find a child or teenager who regularly writes in their diary. Mike Stefanone: girls post 5 times more photos on their Facebook page than boys do; and the girls are more likely to point the camera at themselves. Michael A. Stefanone, Derek Lackaff, and Devan Rosen, “Contingencies of self-worth and social-networking-site behavior,” Cyberpsychology, Behavior, and Social Networking, 14:41-49, 2011.