- office of the Secretary of Defense S'U•S t·SSZ Chief ROD ESD WHS tDate c r h 't Autho_rity 0 13526 De¢lassify Deny m Full _ __ Declassify in Part - -Reason DECLASSIFIED IN FIHJ Authority EO 13526 Chief Records Declass Oiv WHS Date OCT 2 6 2012 3·Xb C j f MDR n _-M- '2 7wf t UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLU IA EO 13526 3 3 b 1 25Yrs UNITED STATES OF AMERICA v Criminal No 96-0207 _ Camara JONATHAN J POLLARD DEFENDANT JONATHAN J POLLARD'S FIRST MEMORANDUM IN AID OF SENTENCING Defendant Jonathan J Pollard by •· -- --- -·· -- ·- -·· ·- -- - · '·- - co m e L I'espec tful ly_ submits his version of the offense in aid of sentencing by the Court Mr Pollard originally wrote his version in longhand last August in anticipation of sentencinq in October For he convenience of the Court the written version has been typed and the original is attached hereto following the typed copy Because of a reasonable assumption that Mr Pollard's version of the offense contains classified information the version was not submitted to the u s Probation Office for incorporation in its pre-sentence report rndeed the Court classification officer has reviewed the docull' ent and found several passagea to be classified These passaqes have been redacted from a copy which is being filed with the Court's public docket Mr Pollard is also filing for the Court's review a second memorandum in aid of sentencing After review and redaction this document also will be filed with the Court's public docket DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Div WHS Date OCT 2 6 2012 ANDERSON HIBEY NAUHEil f BLAIR New--Hampshire- Ave id tr ww · - - Washington D C 20009 202 483-1900 Attorneys for defendant Jonathan r Pollard I - - tP 71 r u Is SEC e-1 SEf lET DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Div WHS Date OCT 2 6 2012 MEMORANDUM TO Richard A Hibey FROM Jonathan J Pollard DATE August 20 1986 SUBJECT Defendant's Version of the Offense I understand that I am supposed to submit a written version -------------- ---------------·-··· of the offense The following constitutes my statement which I understand you will present to the court Issues addressed in this statement include 1 The motives and intentions that prompted my involvement with the Israeli Government 2 The nature and extent of the knowledge of the Israeli Government concerning my operation 3 The pernicious effects that payments made by the Israeli Government had upon me 4 The remorse I sincerely feel for what has occurred1 1 ----- -------------·-·r ------------------ -----------·· ------------ -- --------------- ------- DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declass Div _WHS Date OCT 2 6 2812 - tc · - f _ 5 My future plans to mitigate whatever perceived damage I have caused to the special relationship between Israel and the United States It is my hope that this effort will demonstrate to the court that my ideological convictions although subsequently corrupted were genuine and that at no time did I consider undertaking any actions which were directed against the United States Government I t i s m y b e l i e f t h a t t h e - G o v _ e r n m e n t o f _ _ I s r a e l _ w _ _ _ a s ___ f --u l -1Y aw a r e o _f ------------- both my assistance to its intelligence services as well as my true motives in this affair official denials notwithstanding Having said this I must nevertheless take full responsibility for the offense that I committed and offer the following information more as an explanation for my behavior rather than an excuse I If the past is prologue to the future then a review of my background would provide a useful insight into the political values and emotional experiences which have shaped my view of the world For as long as I can remember Israel has figured prominently in my life both as an object of religious commitment as well as a source of personal strength The first flag I could recognize in my early youth was_that of Israel and for years our family took quiet pride in my late uncle's decision to provide 2 r· ···-·- - ·--- ------ -·· DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Div WHS Date OCT 2 6 2012 the fledgling Israeli Army in 1948 with military boots and medical supplies liberated from the American Hospital in Paris which he commanded at the time In addition many of the leading members of the local Jewish community I met while growing up in Texas were also known to have participated in other types of activities that were of critical importance to Israel during its War of Independence which ranged from the organization of munitions shipments to the acquisition of surplus bombers For these people the death of _Colonel Micky Marcue '· a_ much decorated West Point graduate was considered to be emblematic of the lengths to which American Jews should hold themselves personally accountable for Israel's security It was always stressed though that this extraordinary sacrifice had only been justified by our people's recent trauma during the Holocaust which suggested that a high level of vigilance and individual commitment was expected from Jews in general and Zionists in particular in order to ensure the maintenance of Israel's national defense Everyone I respected in my adolescence emphasized that American Jews had a special obligation to provide Israel with help because it represented our only insurance against a repetition of the Holocaust in which so many European Jews were trapped without a refuge that would accept them Indeed given a recurrent fear within the Jewish community that under the right economic conditions another catastrophe was conceivable even here the survival of Israel was viewed as nothing less than a -----1 ·_· DECLASSIFIED IN FULL racial imperative Authority EO 13528 Chief Records Dec1a11 Ofv WHS Date OCT 2 6 2012 This apocalyptic view was constantly reinforced by relatives who having somehow escaped the death camps reminded us that the minute we took the Third Jewish Commonwealth and our acceptance in the Diaspora for granted it was the beginning of the end A type of subliminal siege mentality was therefore created in which the survival of Israel was portrayed as being essential to our own ethnic security in the United States Although this visceral concern felt by American Jews towards Israel usually manifested itself through such legal mechanisms as the donation of money promotion of emigration or participation in political lobbying efforts on behalf of the Jewish state in Washington it was also implicitly recognized that a Zionist could be faced with a situation in which something less overt and possibly of a confidential nature would be expected from him But just exactly what this might involve was never openly discussed For example Jewish homes were expected to be made available for visiting Israelis who were not to be disturbed for days on end while Jewish businessmen were routinely used to quietly broker the transfer of sensitive material or processes needed by the Israeli armaments industry Despite the cloak and dagger impression left by these descriptions American Jews were never encouraged or expected to betray the United States or do anything which could possibly hurt this country It was simply out of the question because American Jews were aware of the -------- -- --- -------DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declaaa Div WHS Date OCT 2 6 2012 indisputable benefits conferred upon them by the vitality of America's pluralistic traditions and global military strength My parents never ceased in their efforts to portray this land as a Godsend for Jews who throughout the course of our long often tortuous history in the Diaspora had never experienced a country so full of opportunities It was constantly stressed by every responsible Zionist I encountered that Israel would simply cease to exist in the absence of a democratically secure and geopolitically ascendent United States which was therefore in the collective self-interest of the various Jewish Diasporic communities to ensure -- To the extent -------- ------- then that Israel's continued viability was inexorably bound up with the fortunes of America Zionism as far as I was concerned did not involve choosing one country over the other It seemed that an American Zionist could successfully live under the discipline of two nationalisms without facing any potential moral or professional dilemma This symbiotic view of two parallel albeit compatible political ideologies I was later to discover was critically flawed and was far easier to accept in theory than it was in actuality The first indication I had that life would be an agonizing struggle between competing values rather than one of coherent academic absolutes occurred when my family moved to Indiana where I suddenly found myself confronting a community in which racism and bigotry were acceptable social practices The Ku Klux --- --··--··· DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declass Div WHS Date OCT 2 6 2012 Klan was well organized in my city having found the climate and soil receptive to its extremist blandishments following a terrible regional economic depression in the early 1960's Given the rather unwholesome characteristics of this environment I was never able to establish friendships in my neiqhborhoods and was compelled to spend most of my time around the city's Hebrew Day School where I felt at least physically safe and emotionally protected This association lasted 6 days a week for 10 years and involved a highly concentrated ' lrriculum of re_lig- us _a Zionist indoctrination that regularly stressed the advisability of aliya or emiqration to Israel _Of the SO children I knew at the school roughly half left for Israel which is a rate much hiqher than the national average but fully understandable within the context of a community that held us collectively responsible for an unemployment rate not of our making Jewish children I saw grew up angry and alienated wishing only to leave and never return Whatever political conclusions I was forming at the time in terms of our dependence upon the State of Israel for racial survival tended to be confirmed and maqnified by my own physical reliance upon such local Jewish institutions and population that existed Everything finally came to a climax durinq the Six Day War in 1967 when I saw for the first time a strong Jewish state successfully defending itself-and not simply playing the role of victim During the days precedinq the onset of hostilities though our small community was in the grip of depression ·······-·· ··- r DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declass Dlv WHS Date OCT 2 6 2012 9EfctET fearful that this time Israel's luck like that of so many other Diasporic groups had finally run its course Yet poised on the brink of annihilat on Israel had suddenly exploded across her threatened borders in what appeared to us to be a blinding flash of biblical decisiveness astounded us all The result of this absolutely the sight of Jewish tanks encamped on the banks of the Suez canal and our paratroopers praying at the newly liberated Western Wall in Jerusalem was emotionally intoxicating especially upon those of us who were seriously considering emigration as a viable means of asserting our self worth The effect this victory had on me in particular can only be imagined and further served to emphasize in my mind the advisability of leaving for Israel where I coUld put all the humiliations of my adolescence behind me But my parents were quick to point out that we had as much right to live and work in this country as the next person and that I should not run at the first hint of trouble -- they certainly had endured far more institutionalized racism in their lifetime than I had and were able to rise above it becoming respected members of a sympathetic community However as far as I was concerned this academic retreat was only an artificial island of calm in a rather inhospitable sea To their credit though my parents persisted and argued that I should stay here contribute something positive to American society and then decide at some later date about whether I genuinely wanted to emigrate to Israel equipped with professional skills that would be of use to IE t-· ·-· A _ ' ' 1 7 DECLASSIFIED IN FULL the state Authority EO 13526 · Chief Records Dtcla11 Div WHS Date OCT 2 6 2012 This was sound advice but for an impatient child eager to avenge his humiliations all this did was delay a crisis which was slowly building into monumental proportions I think it would be accurate to say that this moment was the genesis of my current predicament An incredibly poignant visit I paid to Dachau later that summer did nothing to help me resolve this dilemma As I walked through the camp all I kept thinking about was the similar -it ' of the German Jewish community which all but vanished in the ovens of that facility with that of my own back in the ·united States Despite the unique historical conditions that contributed to the rise of the Nazi phenomenon the German Jews were as culturally assimilated politically influential and financially secure as the American Jewish community appeared to be but had still evaporated within the course of 10 years When I asked myself whether such a genocide could in fact happen in America everything I'd experienced growing up tended to confirm my worst fears while all the books on the Holocaust I'd read by such writers as Elie Wiesel Andre Schwartzbart Hanna Arendt and Primo Levi were equally pessimistic about man's ability to refrain from such barbaric behavior in the future As I stood in the ruins of the crematoria it slowly dawned on me that every Jew had a responsibility an obligation if you will to ensure that this nightmare would never happen again B ····· ··-·· I -· -- ·---- ----·----------- DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declasa Div WHS Date QCT 2 6 2012 Emiqration certainly seemed to satisfy the requirements of that obligatory service to our race since standing guard on the Golan Heights or along the Jordan River would obviously further the chances of Israel's survival albeit in a rather small tactical scale way aut the Holocaust was a macroscopic event which had occurred in the Diaspora Clearly our communities there demanded protection as well which no Israeli Army however large could adequately provide There had however been a perceptible change in the attitude of the non-Jewish world - --- - -·-----·---· - --· towards the Diaspora in the wake of the 1967 victory which seemed to imply that respect and security could be acquired for our dispersed communities assuming Israel remained militarily - - supreme in the Middle East ··--·--···---- ----····----··---- - - - - - - - - - - - - - - - · - - · -- I would have left the camp utterly confused and undecided about the future had I not come to at least one tentative conclusion concerning the contradictory lessons of Dachau and the Six Day War the only apparent way to prevent the former was to guarantee the latter My self-imposed obligatory service then would be associated with ensuring Israel's security however ill-defined and nebulous the exact means to that end were at the time Unfortunately during the following years my internal struggle over the question of emigration intensified because of my inability to discover a significant way of contributing to Israel's defense while living in the United States However I had slowly begun to appreciate the critical role that American Jews played in representing Israel's strategic interests before ------------- -----· -· ·-·---------- --·-- ···----- ---- DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Di WHS Date OCT 2 6 2012 Washington decisionmakers and also recognized that my own political horizons were broadening to include a more balanced view of America's global importance While visiting Czechoslovakia in the wake of the Soviet invasion that ended -eubcek's experiment with humanistic communism I had graphically seen what alternatives there were to the United States and came away absolutely convinced that if the Russians ever succeeded in supplanting America as the premier world power there would be no future for either Israel or our Diasporic communities Once I had developed a more cosmopolitan and less racially myopic understanding of how the world worked I clearly saw that Israel's ultimate security was a function of how effectively the United States could play the balance of power game with the soviets The Russians who had long been considered evil incarnate by Eastern European Jews were evidently a common enemy of both the Zionistic movement and America which tended to reinforce my symbiotic view of the two political philosophies Therefore to help Israel was to assist the United States and vice versa How could it be otherwise The United States was home to six million of my co-religionists The thought of doing anything which would in any way jeopardize their security was totally out of the question Likewise Israel appeared to be America's only dependable ally in the Middle East and was committed to serving as a strategic bulwark against the further spread of Russian influence in that important region of the globe As a sister democracy Israel's value as a role model for the Third World was both indisputable and a source of --------- ·····- - · ---- ··- DECLASSIFIED IN FULL Authority EO 13528 Chief Records DeCIIII DIY WHS Date CT 2 6 2012 justifiable pride for American Jews whenever they discussed the basis of the special relationship between Washington and Jerusalem But of course it was always the military strengths of the Jewish state that people in this country seemed to respect and take for granted if a dependable ally were needed in the Levant to fight either the Russians or their proxies Israel's military superiority though seemed to be a very precarious thing indeed upon closer inspection As I gradually developed an expertise in national defense matters at Stanford and The Fletcher School my understanding of just how much Israel's alleged superiority was dependent upon the availability of timely intelligence was underscored by the surprise attack launched by Egypt and Syria in the autumn of 1973 If the Six Day War established in my mind that Jews could make good warriors the Yom Kippur war demonstrated just how dangerous a failure of our intelligence services could become In the space of several hours Syrian armored units had penetrated the Golan defenses and were within shelling range of Tiberias a Galilee town with a population of 26 000 Jews some of whom were related to me Unlike the experiences of 1967 all we kept hearing on the news here was how precarious the margin of Israeli success was and that the casualty lists were growing to alarming heights A call for volunteers went out to permit able bodied men to be transferred from Kibbutzim to the fronts but the group I was in En ·ll ··7 '' 4 ii DECLASSIFIED IN FULL Authority EO 13528 Chief Records Doclasa Div WHS I I Date OCT 2 6 2012 ' I I spent 5 frustrat'ing days waiting for an EL AL flight in Los Angeles before we were told the need for us had passed with ·I i Sharon's crossing of the Suez Although we had won after all the price had been appalling and I had spent the whole time sitting in an airport terminal 15 000 miles from Israel unable to do anything more than think It was during this vigil that I decided the intelligence field would provide me with a skill which would be well received in Israel once I emigrated- Like Colonel Marcus I was ready to serve the United States faithfully and then once I had contributed something to the national defense effort would leave for Israel The problem with long range plans though is that they very often are overtaken and invalidated by unanticipated events In my case I quite simply began to enjoy living in the United States and could almost admit that perhaps I would stay here after all Intellectually at least I realized that the same effort I expended have to fight the Russians would also indirectly assist Israel On the other hand I was utterly lost emotionally since I had prepared myself for so long to emigrate that the thought of remaining and never committing myself physically to the state was incredibly traumatic So I continued to be in a moral dilemma as to what I should do to help Israel directly M_erely recognizing that a contiguity of interests existed between our homeland and the United States was not sufficient to • DECLASSIFIED IN FULL St JeliEf Authority EO 13526 Chief Records Declass Div1 WHS Date OCT 2 6 2012 quiet the doubts in my mind about the propriety of living safely in the materialistically affluent west while the Israelis were sacrificing their hard won economic gains on the altar of Mars I still harbored desires to emigrate immediately but did not want to callously abandon my parents who had tried so desperately to provide me with an alternative perspective on the Diaspora My dilemma took on the characteristics of an obsession and the harder I tried to resolve it the more elusive a solution became This inner turmoil intruded into my social ande1ca emic life to such an extent that at times I just wanted to pack my bags and move to Israel on several occasions I did make preparations to emigrate but the thought of what this would do to my parents eventually stopped me The net results of this unstable situation were incomplete studies fantasies a failed engagement and a totally unjustified belief that my parents bore some of the responsibility for my problems since they didn't encourage emigration I seemed to be stuck between my passion for Israel and my very real love for this country which suddenly appeared as two mutually exclusive beliefs Although I finally made a tentative compromise to remain in the United States in order to rationalize my indecision as time passed I just continued to sink ever deeper into a spiritual no-man's land And as with all borders be they physical or cerebral it is the sense of conflicting allegiances that causes the most confusion for an individual who feels he might be living under the burden of a double standard The psychological DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declass Dlvj WHS Date OCT 2 6 2012 hallmarks of divided loyalties were certainly there for ali to see the uneasy conscience the sense of personal failure I was becoming a weak man with good intentions and doomed by pride which was a condition that perhaps had more in common with classical tragedy than with Jewish melodrama However self pity was something I don't think I ever knowingly cultivated at that time because it denied the possibility of a solution to roy crisis Despair though was the price I paid for setting myself an impossible aim It is I was once told the unforgivable sin but it is a sin I believe that the corrupt or evil man never practices He either has hope or a very short memory Unfortunately my level of desperation increased dramatically when I started working for naval intelligence 7 years ago Although I had been cautioned by many of my Jewish friends about the unhealthy atmosphere which reportedly permeated the office I was totally unprepared for the level and extent of the anti-semitism which was tolerated within the organization tried many times to unde stand I what was behind the deprecating comments and the biased stereotypes but in the end I came to the conclusion that the u s Navy like many other naval establishments around the world was the last refuge of the patrician bigot People were routinely expressing attitudes towards Israel which were barely distinguishable from those I had heard about Jews while growing up in Indiana without being reprimanded or even cautioned DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declass Dlv WHS Date OCT 2 6 2012 Moreover despite the commonly held belief that the U S provides -everything• to the Israelis the intelligence exchange from the navy at any rate is anything but equitable I participated in two official intelligence conferences with the Israelis and was amazed to see how high level directives about releasing certain types of information to Jerusalem were routinely shelved by the men in the trenches who felt that the Jews• didn't need to know anything For example our analyst when asked for releasable information on Soviet chemical warfare - -- - - -- ···-··- · - -- - -- --- - · - ------ agents turned to me laughing and said that he thought the Jews were overly sensitive about gas due to their experiences during the Second World War and suggested tbat they should just calm down a bit The underlying attitude of many of the American participants in these meetings was overtly racist which produced a corresponding degree of anger and distrust on the part of the Israelis most of whom felt that their country's security concerns were being totally overlooked The principal instruction I received from my supervisor was that we should only be prepared to give the Israelis enough information to get them paranoid but not enough say to let them figure out a countermeasure to a newly identified soviet weapon system When I carefully asked how they were expected to cope with all the state-of-the-art Russian equipment pouring into the region the response was that all they had to do was lose a few planes and then they'd know what radar frequencies to jam As can be imagined it was very difficult for me to work in this S£t ·· -· 15 •' ·ra ' ------ ----------------------- - ------- - ---·---- --· DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declass Dlv WHS Date OCT 2 6 2012 kind of atmosphere and not become frustrated at what I thought was an unbelievably cynical view towards Israel's survival The Israelis were providing everything they had acquired at great personal risk to many of their agents and the navy bureaucrats couldn't care less about reciprocating in an equally open handed manner as per their instructions Even Judge Sofaer head of the State Department's legal affairs department remarked during one of his recent trips to Israel that there had apparently been a rather large discrepancy between the amount of information which had been authorized for release to Israel and what had actually been made available In retrospect if I had only reported what I'd seen to the Navy's Inspector General this anomalous situation might have been rectified through channels without me feeling compelled to take matters into my own hands Instead I watched the threats to Israel's existence grow and gradually came to the conclusion that I had to do something the Iraqis were secretly manufacturing nerve gas specifically for use against Israeli urban areas the Syrians were in the process of receiving covert shipments of new surface-to-surface missiles that were accurate enough to knock out Israeli air bases for the first time and a veritable flood of other Soviet equipment was quietly entering the region unnoticed by the Israelis who were depending upon the such activity u s intelligence community for warning of Then the bombing of the barracks in Beirut took place u s Marine Corps As I stood in the back of National Cathedral listening to the memorial service for the 16 DECLASSIFIED IN PART '· • Authority EO 13521' · • Chief Records I Decla11 Date OCT 2 6 201Z · fallen· soldiers it all seemed so senseless -- over 200 dead men and all the u s Government could do was respond with an ineffegtua air raid-in which more Americans were killed while erers who we knew about slipped away t intd sy i 1 i# ha1d terri tory and safety Cli 3· 3 b J The thouqht struck me that if the qovernment were unwillinq to defend its own interests in the Middle East aqainst a type of cou-ld- be-- targeted- with- public-- support - then-- 1 t-woulcr·-- threa -wh-ich- be unreasonable to assume that the Israelis could be assured of adequate assistance in the event the tide of battle turned against them ----------- I had already seen how one branch of the ------- ---·--- · - - - ·----------- intelligence community was consistently undermining Israel's ability to prepare for war while the various Arab powers were receiving what seemed to be a constant stream of Soviet Bloc and Western European military equipment and intelliqence information about Israel The situation had all the characteristics of a sell out in which Israel would face the combined power of her numerous opponents alone without the benefit of even one reliable ally ·' What I couldn't understand was why people didn't see that without Israel the u s strateqic position in the Eastern Mediterranean was completely untenable and would deteriorate if a war erupted over the area's oil resources with the Soviets However assuminq Israel's military position could be assured not only would my homeland be preserved but the united States DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Div WHS Dale OCT 2 6 2012 would benefit directly by having a secure regional base of operations which the Russians could never hope to match In this rather emotionally overheated atmosphere I walked out of the memorial service committed to doing something that would guarantee Israel's security even though it might involve a degree of potential risk and personal sacrifice I knew what I was contemplating was wrong but at the time all I could see was that the ends justified the means As with many cases of situational ethics the individual's most difficult hurdle is to accept the fact that the contemplated action while apparently compelled by a power beyond his control was still a matter for which he would be held personally accountable -- - - - ---·--- ---- --··-------- ---'-· --- _ ----· ----- --· -- There could never be any - ------ - ----- excuse which would absolve him of quilt only explanations which might provide a motivational guide to his crime Having made this decision I could admit to its blatant dishonesty but never its disloyalty What I thought I'd done was resolve my dilemma in a way which would permit me to work in the Diaspora against the Russian menace while helping Israel at the same time When I walked through Yad Vashem the memorial to the Holocaust in Jerusalem last summer I was able to look into those countless lost faces staring out of the faded pictures and know for once that I had kept faith with them Nobody will convince me that I had to become a traitor in order to feel this way With my eyes shut and not fully aware of the consequences I entered the territory of lies without a passport for return '9 tr t we 18 -- -- •• • -·· r •• DECLASSifiED IN fULL Authority EO 13526 Chief Records Declass Div WHS oateecr 2 a 2012 From the start of this affair I never intended or agreed to spy against the United States A review of the documents collected as well as the results of FBI polygraphs bear out this state ent It was my plan to provide such information on the Arab powers and the Soviets that would permit the Israelis to avoid a repetition of the Yom Kippur war in which they were confronted with nothing less than a technological Pearl Harbor I I Given the nature of Israeli defense planning a situation comparable to 1973 will not be tolerated and in the absence of reliable intelligence identifying the actual capabilities of newly-introduced Eastern Bloc equipment could result in a very destructive preventive war It should be realized that for a country like Israel which is acutely sensitive to casualties constrained by limited resources and saddled with highly vulnerable borders the appearance of a new enemy weapon system on the frontier could mean the difference between a quick surqical campaign and a Pyrrhic victory Therefore the earlier Israeli military planners know the technical parameters of a given system the faster they can apportion scarce funds to determine suitable countermeasures many of which are subsequently turned over to the United States for its own use The key to this rational approach to national defense is to have a sufficiently long lead time for the various research establishments production plants intelligence agencies and operations bureaus to create the requisite hardware and applicable tactics needed to defeat say a new Soviet C f · '_ c I J 19 ------- __ _ DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declaat Dlv WHS Date OCT 2 6 2012 surface-to-air missile SAM system • t u s While it is true that the is providing a great deal of highly classified material to the Israelis particularly on these weapons the information is not detailed enough to allow the Israelis to truly understand the nature of the future threat facing them Without this type of information there could be a possibility that the Israeli Air Force might not have indisputable command of the air in the opening days of a war on the Golan Heights and with the distances so short to Israeli population centers ground forces would have to be left alone to fight costly blocking actions until that time when the air force could decisively intervene Forthis reason much of the material 1 passed to the Israelis ----- ---------'· ·-- -------------- --- -- -- concerned both current and projected Soviet SAM technology its associated electronic warfare devices and command control communications systems I Of all the threats which Israel is currently facing those represented by the Soviets and their Syrian allies are by far the greatest due to the unpredictable nature of the Assad regime and the publicly-acknowledged promise made by Moscow to guarantee Syria's strategic parity with Israel The undisclosed objective of that parity though is to allow the Syrian armed forces to mount an unannounced •standing start• offensive designed to wrest control of the Golan Heights and Galilee before the Israelis can mobilize At the very least the information I provided the Israelis should permit them to cope with most of the all-important Soviet air defense weaponry that the Syrians are - ------· --- - ---·· DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declasa Drv WHS Date QCT 2 6 2012 relying upon to provide their invasion forces with a mobile umbrella against Israeli air attack can be quickly neutrali ed Assuming those air defenses the Israelis should be able to contain the Syrian attack as close to the frontier as possible It should also be remembered that those same Syrian air defenses shot two u s Navy jets out of the sky 4 years ago over Lebanon and are the main reason why the current administration would avoid retaliating against Damascus even if the smoking qun of a terrorist incident could be traced back to Mr Assad's office Moreover in the event that the 6th Fleet does require Israeli assistance for additional air support in the eastern Mediterranean against the Russians or Syrians it's going to be -----very thankful that the Israeli Air Force will be able to handle ------- the threat environment -- without the waste of time associated with losing a few planes first Apart from Syria I also provided the Israelis with critical strategic information pertaining to their outer ring of enemies namely Libya Algeria Iraq and Pakistan The threats represented by these rejectionist front states are no less real than those from Syria and involve such matters as nuclear weapons development chemical warfare agent production and conventional military reinforcement to the front line Arab states during a war with Israel Although I was rather surprised at the degree of assistance the Israelis needed it taught me a very good lesson about how the popularly-held perceptions of Israel's intelligence collection capabilities can be totally misleading 1 • l ' ' · They are_ not by any means an all-knowing giant straddling the Middle Bast and have been forced to concentrate their best human t chnic al and assets against Syria which represents the most immediat•t reat to their survival OSD 3 3 b - As I slowly came to appreciate the fact that I_ was providinq the bulk of the information reaching Israel on ita distant opponents the_maqnitude of thei precarious position dawned on ------------- -- --met-- the J tacrno-- tdetthe-rraqrs-werrconnderthJ tlf•--aeploytlren-e- ·- --- -- ----- of an · i fionary force half tlie_ size of the n iJ a _ Syrian army · ·' •• • • • • • uuJt cua __ ' ' •· • '• • • ' • ' ' -- '$ in· the evE nt of waJtlii- otthatt th$ ' • • · · c- t - - waa· t - d4fti i0 stone·· 'on· top ' _ · • · ' - • • · • o mara' desperately ' ' ' l ' tryinc to t · -' rem tin afloat ln shark-infested wat rs and as each new revelation confronted them with seeminqly insurmountable problema another one arose to replace it At times it seemed as if I were bec ming the traditional messenger of bad tidings sowinq the intelligence equivalents of the proverbial dragon's teeth But their needs were understandably insatiable and as the urgency of their requests took on an almost infectious quality my whole life seemed to be driven by a fear of overlooking something that might ultimately prove catastrophic Literally everything I showed them set off alarm bells particularly those thinC1apertaininq to nuclear and chemical warfare advances in the Arab world With the Iraqis employing nerve agents with impunity in the Persian Gulf War the-Israelis were justifiably concerned DECLASSIFIED IN FULl Authority EO 13526 Chief Records Declass Dlv WHS Date ocr 2 6 2012 about the Syrians' intentions to use such weapons on the Golan Heights -- as it now seems likely they will Needless to say it takes years to prepare troops and civilian population centers to exist in this type of battlefield environment and the Israelis usually operate on a much shorter time frame than that Despite the frenetic pace of the collective effort though I appreciated why it was so important to provide as much material as possible -- I was quite literally Israel's eyes and ears over an immense geographic area stretching from the Atlantic to the Indian Ocean Although my responsibility was overwhelming at times I was more than adequately motivated both by my ideological convictions and sense of outrage over terrorist incidents which the world seemed to accept with equanimity as long as the only casualties were Jews The reaction in my office to the Achille Lauro incident in which an elderly Jewish man who also happened to be an American citizen was brutally murdered bordered on the comic Perhaps the most direct role I played in helping to eradicate this terrorist threat to humanity occurred in the fall of 1985 when the Israelis decided to raid Yasser Arafat's headquarters outside Tunis As I understand it the retaliation was targeted specifically against the PLO's Force 1 group which had been responsible for the murder of three defenseless Israeli civilians at a marina located in the Cypriot port of Lornaca spent two hectic weeks collecting information pertaining to •S C _ 23 I ' ' f i - ·· - · t NE · er ·· • · • •··· • •tet OCJ a6 2012 0 Pt O' •·· 'I Y 'WHs · t ' ' Lilil'a '' l# a t l ita reporting systeai· a nd · th diSpoai tion of a t l -i - apc nS Which evidentl contributed ' significantly - Je 1f ·1·J' i $1FIE II 0 '' - Eeb El '· Acuhtlh rlRty EdG1135D281 Dl- ·- · · · _b · 'it' ecor s ec ass t·- L f ··· J •·' ·· itU ·- _ •' _ •' · - ' z · - --- _%- c - ' ' ' · to'th ·mis' aiob •s success sam d i ·- afso It should be kept in mind that the i u s · killed ove Ambassador the· past - da c·ac - '1 th· t oii l l· impunity and was in the prod-sa of organizing · - - · - ' _-· - - ' ' addti it ti•L texror ist acts' t gai nst ·American dipl matic interests ' - · - _ _ ' -- - · - ___ - - - - i abroad wbem - ·-' ' the - - · _ _ org p zation ·- ' __ -- ' ' - _ - ' Israel air strUte deatroyed tts command - ' · _ ' ·- A tar as I waa· eonceined tbis constituted a --'- --- ·-- '---- pert exampt wh6re-' r t o gb miac io tt r o-t S rvic to-- _ ----- - -- - ' - r - · bothl' tsrael and· the_ tlnit« d State unabf s Olf _ · nwiJ ling - - · - - ' · which to protect' lts Owtl' · ' at thi tlme _ seemed citizens abroad· - -- - oso 3 3 b l_ - Cn additlott to my •conveJ lonai• intelligel lce qatherinCJ actiy i tiesf oti S ftalf of the Israelis - x·_ was· also· asked· for advice ' ' · ' ' ' ' ' 1 -A 3 - t ' ·'' With· respec-t to the latter ·· it _I • '· · · · · 1 sboui bf hdeJ t d that' even thou h Iran's clerical leaders ip i ·' - itdal lantly opposed to Israel's existence the defeat · • • of the Iranian armed forces in the current Pers lan Gulf war would - leave Iraq free to redeploy ·a larqe number of units- either to the Golan Heights or Jordan River_ valley thereby compounding the threat to Israel's eastern border Put in more biblical terms 8ECi'' · r • - Z-t ' - DECLASSIFIED IN PARt ' 'Authority EO 13528 ' Chret Records Declass Date OCT 2 6 2012'' ····· Israel's interest in Iran's continued viability is a modern day versi n of •the enemy of my enemy is my friend • Although this line of reasoning may not on first sight seem acceptable to many Americans who are accusto ed to a more idealistic foreiqn policy it is a little known tenet of u s strategic pOlicy that the territorial integrity of Iran must be maintained so as to prevenua vacuum from arising which could facilitate a Soviet advance to the Indian Ocean I'm sure churchill no more enjoyed ·----deuincr-wi Sta1J nc-du in«J -the-Seoon _Wo ld- Wa han-·1- did---- ------·- ····- · · · --- recoi'MIIending appropriate defense• armaments for Ir a but the loqic f of realpolitik of teD requires a person to choose between the tEisseb · of twcr evils --- roi me the need to Jeeep-theti aqi regime preocqupied fighting a militarily strong Iran on battlefield far removed from the Israeli frontier was paramount if ·the delicate strategic balance between Damascus and Jerusalem were to be maintained C rJl 3· 3ib J Finally lest there be any confusion over why I provided information on Saudi Arabia and Egypt it should be appreciated that both countries represent latent threats to-Israel which no The little known - -i - Liby as the Egyptian Ministry of PortiJign Affairs would have UIJ believe The diplomats might have signed· the Camp David Accord - ' ' but thtl Bqyptian General ·staff is still calculating ow best to figbt ' _ wa t in the desert wasteland o_f the Sinai Penins11 a fo Riy dht apart fraU the incredibl tl' As of tha 'l'abu1G £'-' u s -saudi militci ·exercises diplomatic agreements or· secret - · · · c r ' 3• lb LI military eontingency·plans -- stat d As I previously --- - -----' -· - ·-- ----- · ---··· -·- ---- ---· -· - -· I had · 8bsolut ely no intention of · spyinq on the United States or to provide any critical national defense informa ion to a_belligerent compromise the names of any did I ever reveal any u s u s At no time did I ever agents operating overseas nor ciphers codes encipherment devices classified military technology the disposition and orders of u s forces war fighting plana secret diplomatic initiatives and obligations classified organizational writing diagrams or phon books vulnerabilities of nuclear stockpiles or co ications security procedures In addition I did not put any u s· covert activity in jeopardy which might if compromised either be used to embarrass the administration or cause ·a rupture in relations with a foreign government One has to keep in mind the fact that mysole objective in this affair was to provide DECLASSIFIED IN FUU Authority EO 13526 ' Chief Records Declass Dlv WHS Date OCT 2 6 2012 Israel with information concerning threats to its existence of which the United States is clearly not one The collection effort was clearly directed against the Soviets and those Arab states which pose a clear and present danger to Israel's security On the other hand if I had intended to harm the United States I don't think there was anything preventing me from doing so Although I was ideally placed to acquire nearly any type of information which would be of importance to a belligerent this thought never crossed my mind The notion that I was a traitor or working on something which would harm the United States never arose since the agreed-upon ground rules of the operation clearly stipulated that I would never be asked to provide material which would put my loyalty to this country in question This point was repeatedly stressed by all the Israelis with whom I was associated except Rafi Eitan who did press me for information pertaining to the activity of the National Security Agency in Israel and the names of all the Israelis who were providing classified material to the United States I never provided this type of information and was later told by my chief handler Yosef Yagur that the material Eitan wanted was totally off-limits outside the scope of the operation and if provided would be grounds for immediately terminating our relationship In the final analysis the value of the material I provided the Israelis actually goes far beyond the imnJediate tactical DECLASSIFIED IN FUL4 _ I Authority EO 13528 Chief Records Declass DiYJ WHS Date OCi 2 6 2012 I l ' advantage it will confer upon their field commanders by givi g high level Israeli defense planners a detailed look at the nature of their future threat environment it permits the country's political leadership to articulate an external policy based on certainties rather than debatable risks This advantage would tend to work as a stimulant for the peace process since no responsible Israeli government could ever consider yielding valuable territory unless it had an accurate assessment of what the potential loss to the nation's military security would be from such a decision Although I'd be the first one to overstate the degree of danger Israel is currently facing I also appreciate the fact that a time for peace even an imperfect cold one must inevitably be accepted before the state is transformed into a Russian clone I am satisfied that what I did will hasten the day that peace can be reached in the region because without much of the information I provided the Israeli military establishment would be less inclined to trust the assurances of its own political leadership let alone those of a traditional enemy In conclusion during the course of this affair I tried to remain true to my ideological convictions -- as imperfect and flawed as they might have been in retrospect In my mind assisting the Israelis did not involve or require betraying the United States I never thought for a second that Israel's gain would necessarily result in America's loss How could it states are on the same side of the geopolitical barricade Both II DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declasa Div WHS Date OCT 2 6 2012 one of the most controversial aspects of this case has been the assertion by the Israeli Government that it had no prior knowledge either of my activities on their behalf or the allegedly unauthorized behavior of their own intelligence operations Before addressing this contention it should be pointed out that whereas a state's decision to conduct espionage operations against a belligerent is a routine phenomenon this affair represents a highly unusual situation involving two closely aligned nations one of which felt compelled to spy indirectly on its enemies through the services of an allied national Although this embarrassing type of discovery has previously occurred both parties very often resolved their differences quietly through diplomatic or administrative channels neither state wishing to precipitate a cause celebre which might put at risk more substantive aspects of their relationship It is my belief that if this imbroglio had been managed in such a discrete manner the Israeli Government might have been more inclined to act responsibly from the start and to quickly admit their culpability Candor however is a rather scarce commodity in shaky coalition governments particularly one just waiting for a crisis to disintegrate -- and this case was a crisis of monumental proportions for Israel comparable in some respects to the Lavon affair over 25 years ago In response to the blistering public denunciations which were directed at it DECLASSIFIED IN FULL Authority EO 13528 · Chief Records Declass Div WHS Date OCT 2 6 2012 the Israeli government acted predictably by attempting to limit the damage to itself by retreating behind a plausible denial screen in which the scandal was purportedly precipitated by a group of renegade intelligence officers acting without authorization Once having engaged in this self-defeating approach to the problem the Israelis were vulnerable to additiqnal embarrassments as each new uncontested revelation was prominently displayed in the American media Perhaps sometime in the future a more politically secure Israeli government able to set the record straight with the u s w_il be Department of Justice but until that day arrives it will be more expedient for Israel's fractured leadership to stonewall and deny any official involvement with my activities However having said this the following represents my understanding of the government's knowledge of the operation First of all the number and type of Israelis who were associated with this affair suggest a high degree of government awareness if not intimate supervision of their behavior Given both the comparatively small size of the Israeli intelligence community as well as its notorious intra-service volubility the plausibility that seven members could carry out a renegade operation unbeknownst to security and fiscal management personnel is beyond reason Even with the availability of a bureaucratically unaccountable slush fund the expenses of this operation could not have passed unnoticed by the inner cabinet's intelligence auditor who has an extremely broad mandate for E il r I t- · r·· 30 DECLASSIFIED IN FULL seertEf regulating these sensitive financial outlays Authority EO 13528 Chief Records Declass Div WHS Date OCT 2 6 2012 Furthermore if one takes into account both the quality and highly specialized performance expertise of the personnel who were involved in this affair it seems unlikely that their collaboration could have been the product of random selection a near famous ex-Mossad assistant chief of operations then assigned as a special advisor to the Prime Minister a highly decorated member of the air force two senior science attaches and a leading international arms broker do not coalesce out of thin air Secondly the type of collection guidance I received suggested a highly-coordinated effortbetween the naval army and air force intelligence services At the end of each month I was given an extremely detailed list of material which was needed by the various organizations that included an explanation of why the information officially transferred did not satisfy their requirements Although the acquisition lists appeared to have been submitted by each service separately since dissimilar paper and formats were used by the three organizations there was always one prioritized list which had evidently been agreed upon the respective military chiefs of intelligence and bore their combined seal While it is possible that the Mossad considered this affair to have been unauthorized because they were evidently never a party to it the same cannot be said of the General Staff which was intimately involved with identifying which type of scientific and technical intelligence was to be the object of my activity From what I could see Rafi Eitan only 31 DECLASSIFIED IN PART Authority EO 13528 Chief Records Daclass Dl Dater OCT 2 6 2012 served as the individual responsible fox manag nq the covert side • i of this uniformed service operation Thirdly _I was routinely provided with finished technical assessmen ts ·of the material which had-be n· passed to the Israelis The turnaround time-for these assessments was very quick and when I inquired how this was accomplished I ·' was told ' that a special team of analysts had been established back in I sra l-j usif- fol -- the- purpose --of- evaluatinCT tha-- opera tiona-1--- -' applicability of all the new information collected·• Given the unique nature• of this material such as· satellite photography and SIGIN't deriveo studiea of team was not only · fully aware· of where being acquired but was also cognizant that it· was not beinCJ transferred through official channels Although I was never told how large this group was it had to have been rather well staffed with extremely competent scientists in light of the volume and diversity of the material I collected I Fourthly there were three occasions on which I was told that the highest levels of the Israeli government had purportedly extended their collective thanks for the assistance I had provided the state detailed After I had supplied Yosef Yaqur with a very · tudy of Paki he informed me that a specia tudies committee directly subordinate to the Prime Minister's office had presented its conclusions to the Cabinet on the growing dangers of the OSD 3 3 b I c G1 3 30o N'eiiiPCJns effort ana hac l emphasized te l qetnce material obtained roa a •special source• had been c_ritic al to its evaluation I was also congratulated by Yagd afte · a1l Israeli dronti 1 or unm ned reconriaissaric t airc afh had been abl tc 'successfully n qqtiaia· its way through the ehtir« Syrian· air defense systeaf·J l98 5 · Aeco rd inq' to the ' - - -- · _ ' • l• ' · · •• • isr ii Ai Force thili ······· lc-au•ar _ ' ' ' a an ta renten r · · i ·''· · mater talil-i·li Drlov tCIE ci • • · ••• -- 0 ··-' -··------· ------ stressed the fact op r t nso once agafn reCerenc4t tsr •1• s de dence eo upon a •special'' source• was reportedly mentioned at the pre-strike presentation made before the Cabinet · Fifthly sinctt-Bitan was physicalfly located in the Prime Minister's office and was evidently invo ved in some type of intense bureaucratic competition with the Massad it is very likely that he provided· both my name and position to the select group of Israeli politicians and General Staff representatives who would have been briefed on the agel'J t intelligence coupa as the pho _os of aerial romp over Syria and the raid African headquarters know who provid d The inner Cabinet would havewanted'to this information and Bitan could never have oso 3 3 b t o ' c ra · b f DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declass Div WHS Date OCT 2 6 2012 resisted the opportunity to ·score points against the Mossad in front of the government Yagur mentioned several times that specific documents had been used by Eitan to embarrass the Chief of Massad at Cabinet meetings and as stated earlier the material was so unique that anyone present at the carefully-orchestrated confrontations would have known about the existence of an agent working in the American intelligence establishment For whatever reason a Cabinet level decision had to have been made with the concurrence of the General Staff that the gains associated with my activities far outweighed anypoteritial risks that might result if I were compromised After all incidents had happened in the past and there was no reason to believe that the American government would react any differently in my case especially as I was not spying on the United States The opinion that I had nothing to fear in the event of capture was stressed to me by both Yaqur and Eitan so often that it seemed as if they were repeating official doqma It is my opinion that they were but that with the affair exploding out of control following my arrest the opportunity was seized by certain factions in the Cabinet and the Israeli intelligence community to repudiate the operation by casting Eitan in the role of a renegade I don't know whether anyone in the Israeli leadership was aware of the fact that Eitan had unsuccessfully attempted to have me collect political blackmail on members of the Cabinet but assuming someone did there would have been an eee ·r · I 34 Iii DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declass Div WHS Dateocr 2 6 2012 incentive to publicly discredit both him as well as myself before he had a chance to leak such inflammatory information Politics in Israel has certain Byzantine characteristics which to the outsider may appear to be self-destructive It is indeed unfortunate that this political trait has also served to destroy an otherwise loyal Zionist and discredit the reputation of a sitting Israeli government III Of all the corruptive influences which are popularly viewed - - - - - - - - - - - - - - - - - - - - - - - - - - - - ----------------------------··· -------------- - - - - - - - - - - - - ---- as being decisive in prompting an otherwise law-abiding man to become a spy for a foreign government sex drugs and money are considered to be the most potent • The fact that this trinity of evil has been evident in many of the espionage cases which have come to light over the past few years makes any claim of ideological conviction by me to appear self-serving at best and irrelevant at worst However the minute one automatically ascribes greed as the principal motive in affairs such as mine it tends to obscure the more fundamental issues which can render a person vulnerable to his ideological obsessions Although I never sold my soul to Mammon it is extremely frustrating for me to see that only the financial aspects of my involvement with the Israelis seem to have captured center stage particularly in terms of our alleged lifestyle trips and subsidies Contrary to what the novelists may say is the spark of deceit money was ·------ ----·· --·- DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declass Div WHS Date OCT 2 6 2012 a corruptive secondary by-product of my activities and was certainly not the precipitating or causative agent When I first made contact with Colonel Sella and offered my services to the Israelis I never intended to establish a business relationship with them My sole objective was to provide the Israeli Defense Forces with enough information to prepare for the next generation of Soviet military technology which had been scheduled for export to the Middle East Accordingly I worked as an Israeli agent fer nearly 6 months without receiving any monetary compensation and was content to continue this arrangement until the issue of salary was raised-by Colonel Sella At first I didn't know how to respond to this situation since I hadn't planned on being paid for my assistance believing instead that if I were to successfully complete the transfer of intelligence data the Israelis would permit me to work for one of their defense industries in the United States or Europe such as Israel Military Industries Tadiran or Israel Aircraft Industries -- where I could continue to aid the state as an armaments marketing strategist However seeing to the fact that I wasn't even familiar with the type of salary an agent could reasonably expect some ridiculous amounts were initially discussed until I understood that Eitan intended to pay me as if I were a regular agent operating in friendly territory As he explained it nobody would question a CIA operative living off two salaries when he's employed overseas by an unknowing firm as DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declass Div WHS Date OCT 2 6 2012 deep cover and the same logic applied for me as an Israeli operative I still didn't like the situation that was developing and discussed alternative forms of compensation with Sella Yagur and Eitan while in Paris during the winter of 1984 I suspect that the best way of characterizing the way I felt at the time was extremely dirty which was not how I envisioned feeling as a result of helping the Israelis This was an ideological -- --- ----- operation that was slowly being turned into a banking expedition by Eitan Both Yagur and Sella privately agreed with me that the payments would be misinterpreted and look terrible if I were arrested and suggested to Eitan that Anne be employed by a sympathetic public relations firm i_nstead Eitan predictably adamantly refused to consider anything other than a salary and emphasized that as an Israeli working for him I was expected to follow orders and proceed with my collection activity Every time Yaqur passed money to me a silence would descend over our discussions and a rather pained look would appear on his face There was one occasion where I did refuse to accept the money but Yagur pointed out that it was not up to me to lecture a man like Eitan on ethics -- what we were involved with was a matter of critical importance for our homeland and insubordination in the field would not be tolerated There was no denying the fact though that neither one of us fully enjoyed the salary aspect of our operation which conveniently hung like a sword of Damocles over my head 37 DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declass DIY WHS Date OCT 2 6 2012 In spite of this disquieting aspect of my case I never considered myself to be a mercenary no matter how corrosive the payments were on my sense of personal integrity Luckily my ideology prevented- me from descending to a level where I would reflexively respond to Eitan's commands like some type of Pavlovian dog As I've previously mentioned when he requested information which I considered to be incompatible with my objectives and intentions I simply did not provide the material It might be instructive to remember tha·t unlike most ---· - ·-· --- · ·· · - · ·· -- '---- · -· ----·---·- mercenaries I had no blackmail threat which could be directed against me In fact the classical roles of compromised agent and manipulative handler were actually reversed in this affair '' - ---·----------··------- - -- and if any party were vulnerable to extortion it was the Israeli Government which politically had a great deal to lose if my activities were discovered Therefore if I were simply motivated by greed I should have exacted a King's ransom for my services each time a delivery was made to the Israelis That I did not demand an increasing amount of money during this operation should indicate that my ideological convictions were fundamentally genuine When all is said and done though I did accept money for my services That fact has a way of suggesting the worst kind of motives in a spy a species not generally well regarded to begin with Yet even idealistically-inclined spies cannot exist on altruism or sheer stamina for very long because of the rate at which they tend to deteriorate from fear exhaustion and a DECLASSifiED IN FULL Authority EO 13526 Chief Records Declass Dlv WHS Date OCT 2 6 2012 guilty conscience Unlike an agent operating behind enemy lines I knew what I was doing was wrong and constantly tried to keep my spirits up by reminding myself that the information I was providing Israel was essential to its survival But in the absence of any conventional yardstick by which I could determine my absolute worth to the state I accepted the payments as a reflection of how well I was doing my job By the - spring of 1985 Eitan felt that it was time to recog-·- -· -·· nize the quality of the material being collected and awarded me a salary increase which I received without any discussion handed me an envelope like a prostitute we Yagur shook hands he apologizecfand I felt Finally after a year of rising emotional distress over this financial stigma I informed Eitan that I not only intended to repay all the money I'd received but also was going to establish a chair at the Israeli General Staff's Intelligence Training Center outside Tel Aviv When I later apprised Colonel Sella about my decision he smiled and said that Eitan would very likely have a case of apoplexy upon receipt of the message since he couldn't stand agents who suffered from morality attacks Ironically the only response I ever got from Eitan was transmitted through the Jerusalem Post shortly after my arrest where he evidently felt obliged to characterize me as a mercenary Like the 18th century Bourbons Mr Eitan seems to know the price of everything and the value of nothing I am at least relieved to know though that Yagur has refuted this spiteful comment as being totally inaccurate S Y r DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Dfv WHS Date JlCT 2 6 2012 When I was first asked how the money provided by the Israelis affected our lifestyle I could only respond by pointing out that we didn't acquire such ostentatious items as property cars furniture electronic equipment furs paintings gold stock boats racing horses or for that matter a drug habit Before I became involved with the Israelis we were meeting our rent payments and other household expenses while the apartment was fully furnished and the car was paid off This financial situation would have continued indefinitely seeing to the fact · ·------ -- ·-- · that we were managing our money responsibly and were not profligate in our spending patterns The extra funds did however permit us to travel to Europe on two occasions during which time I also met with my Israeli contacts for debriefing sessions The hotels we stayed at the restaurants we enjoyed and our modes of transportation were well beyond what a couple on our salaries could normally have afforded Some aspects· of these trips were subsidized immediately by the Israelis while other portions were to be paid off slowly over the course of a year with funds taken from my monthly payments There was also the matter of Anne's ring which was part of the plan to convince her that a wealthy relative was underwriting our trip to Europe at the time -- it was certainly not meant to be a recurrent aspect of my relationship with the Israelis As far as the Swiss bank account was concerned that was presented to me by Eitan as a means of addressing my stated concern over his lack of adequate security precautions ' • ' J 40 It was DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Dlv WHS Date OCT 2 6 2012 his contention that even though I had absolutely nothing to fear ' I' 1 ' in the event of compromise the bank account would serve as a safety net in the unlikely event we had to relocate overseas at the end of 10 years It was definitely not established to supplement my monthly payments and could not even be accessed without authorization from Yagur who had opened the account in my Israeli name The ten year time period was Eitan's invention and was clearly unreasonable since I had already made the decision to terminate my activities at the end of 1995 When I broached this matter with both Yagur and Sella they each recognized that 10 years was untenable because of my growing dissatisfaction with Eitan's reduction of everything in the relationship to an accounts ledger The possibility of me actually working for Eitan long enough to collect $300 000 was therefore a non-starter and simply never would have occurred It may be relevant to place the recovered letter to Yossi I wrote within the context of this financial section As previously alluded to Israel is committed to maintaining Iran's conventional military capabilities in order to assure a stalemate in the Persian Gulf War Since the u s has repeatedly warned Israel in the past against openly shipping arms to Iran the Israelis have very conveniently delegated this activity to trusted private brokers who can also be repudiated if exposed The policy decision communicated to me involved the following issue which Uzi had been assigned to expedite Kharg Island's defenses were to be improved before Iran opted to close the DECLASSIFIED IN FULL ' ' Authority EO 13528 Chief Records DeCIIII DIY WHS Date OCT 2 6 2012 entire Persian Gulf flow off in retaliation for Iraq's increased number of air strikes against the facility My suggestions were solicited as to how that objective could be realized given the fact that I was in the best position to know exactly what weapons the Iraqi Air Force was using to interdict the oil loading complex The understanding was that since I would eventually be employed either in the official or gray arms market this assignment could be viewed as my initiative commission and all This proposed sale of military equipment to Iran was no more an isolated •roque• affair than was the operation in which I was involved -- both were authorized activities which formed an essential part of IsraeT's · survivaT oriE mted strategy The commission was unanticipated and had no affect on my predisposition to provide the information Israel needed to successfully conclude an arms deal with Iran --· the objective of this endeavor was always of foremost importance to me not the profit With respect to our alleged penchant for frequenting expensive Washington restaurants many of the meals were taken with friends who would reimburse us later for their having used our credit cards and we were always careful to eat during those hours when prix fixe i e pre-theater savings were available I can't remember one occasion when we ordered wine or offered to pick up the entire tab for a meal involving our friends In fact most of our favorite restaurants were small Greek Italian or Vietnamese establishments which were modestly priced and 42 DECLASSIFIED IN FULL Authority EO 13526 Chief Records Decla11 Div WHS Date OCT 2 6 2012 provided us the opportunity of quick inexpensive meals after very long exhausting days at work Anne and I patronized those restaurants long before I started working for the Israelis and would have continued doing so even without an additional monthly paycheck Although Anne's job required her to be dressed appropriately I can't recall a single time she ever purchased anything that wasn't on sale Moreover due to her frequent and painful weight problems caused by a number of gastrointestinal disorders she was forced to buy clothes that would fit her properly across a broad spectrum of sizes A certain percentage of the money was used for educational expenses prescription medications and books for which I will be the first to admit I have an incurable addiction The extra money also permitted us to attend two weddings in Portland Maine and Tampa Florida which I don't think we would otherwise have been in a position to afford Although in retrospect our way of life was not dramatically changed because of the Israeli subsidy it was nevertheless significantly improved to the degree that we could do certain things and purchase a few items that were previously beyond our financial reach This ability did not by any means turn us into unbridled sybarites or permit a degree of consumption that would be considered unseemly Perhaps the most significant impact my additional funds had on our life was that it provided me with the resources to co-opt DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Div WHS Date OCT 2 6 2012 a highly placed Saudi bureaucrat His potential utility for my eventual plan to leave the navy and initiate a covert penetration of the Saudi Ministry of Foreign Affairs was incalculable A great deal of money was spent on this project which would have resulted in a tremendous opportunity for me to work as this bureaucrat's private representative in London and Brussels Beyond the evident intelligence value of this relationship it would have allowed me to end my operation in this country which Yagur had told me in October of Israeli a ed pr yidec J he forces with enough information to probably win the next Middle East war commission 9 hB c 1Ci re dy Ironically it was money taken from a earned brokering an oil contract on behalf of the ----- - ···--·-··· Saudi with which I intended to repay the Israelis for all the funds I had received from them This act would not have totally erased the stigma I felt by having accepted their money in the first place but it would have constituted the first step on the road to my personal redemption I never imagined that Eitan could have insisted upon these payments as a precautionary move designed to cast me in the unlikely role of a mercenary in case the operation was compromised It seems that Lucretia Borgia couldn't have recommended a more potent way of poisoning my motives Luckily my ideological convictions held fast in spite of the money and prevented me from giving Eitan any information which I considered to be outside the scope of our operation 44 Although the money may DECLASSIPifD IN FULL Authority EO 13526 Chief Records Declass Div WHS Date OCT 2 6 2012 have corrupted me by contact it did not form the basis of my decision to help Israel IV A question I've repeatedly asked myself over the past 9 months is whether I would ever become involved with such an operation again assuming I would not get caught this question is an unqualified no The answer to I believe that if I had spent the time to sit down and think about what I was jeopardizing by spying for Israel I would never have become involved with this type of activity in the first place But the consequences of one's actions are sometimes difficult to perceive in the heat of the moment and the thought of doing something of decisive importance for Israel blinded me as to what this act could potentially cost my wife family the American ·Jewish community and the special relationship between Israel and the United States While I may have guaranteed Israel's victory in the next war the price has been unacceptably steep in terms of the incredible pain and anguish my wife and family have been forced to endure on account of my misguided ideological convictions My dream of service to Israel has turned into a living nightmare of personal defeat professional disgrace and emotional despair At times I feel as if I have metamorphosized into a twisted Zionist version of Alcibiades never again to know 45 o·eciJssi u · · FULL SEGf ET the comfort of a homeland and spiritual refuge Authority EO 13528 Chief Records Declass DIY WHS Date OCT 2 6 2012 I would seem to have strangled my dreams on the altar of unbridled hubris Being separated from my wife has been the single most traumatic event that has ever happened to me Anne is the most important person in my life and to say that I am totally lost without her is an understatement of monumental proportions Apart from my parents' relationship I've never seen a more perfect constructive andimmensE Y lifetime than the one we enjoy satisfying maZ'riage in my my wife's victories are my victories and her defeats I share willingly as if they were my own -- and this emotioncil equity is more than reciprocated by her I have unbounded respect for Anne as a person who has mastered the complexities of an extremely difficult profession largely on her own initiative without having lost either her sense of compassion or humor She is the only woman in the world with whom I would ever want to have a family and believe as much as any man can that she would make a wonderful mother for our children Unlike the case with many other couples her terrible medical problems have only served to drive us closer together and to confirm in my mind that guaranteeing Anne's physical and emotional welfare is of paramount importance to me -- eclipsing any other issue that I could ever imagine Having said this it should come as no surprise that I have suffered profoundly from the realization that due to my indiscretions she had t l lr' o the unmitigated hell of 46 DECLASSIFIED IN FULL Authority EO 13526 Chief Recollls Declass Dlv WHS Date OCT 2 6 2012 D C Jail Isolated surrounded by degenerates and deprived of adequate medical attention she was confined to a facility which could be unfavorably compared to such notorious prisons as Dartmoore Lubianka Robbins Island and the Czarist Fortress of St Peter and St Paul The culpability in this affair rests squarely on my head her only crime being that of a loyal wife who was swept into the vortex of my ideological passion She never participated in the operation at any level of involvement and tried vainly to have me cease that I could possibly recount activities on more occasions In addition my wife never asked me to provide any classified material for her business undertakings -- I brought·· the documents home on my own initiative thinking that they would prevent her from inadvertently dealing with the wrong people at the PRC Embassy I pray that the court realizes that punishing Anne further for a crime that was my fault could not possibly serve the ends of Justice When I think of how sick she is and how much she needs me to be by her side I can't understand how I let the abstractions of a mere political ideology step between us I desperately long to rejoin my wife and have our lives return to some sense of normality All I think about is how I wish I could have had the strength to resign first from the navy and then assist Israel in a manner consistent with both the laws of this land and my obligations to Anne I am reminded about the seriousness of what I've done every night I go to sleep and every morning I awake without being next to her which has an effect on -·-· ---- o ----- DECLASSIFIED IN FULL Authority EO 13526 Chief Rgrds Declass Dlt WHS Date Ot t 2 6 2012 ' me little different from spending time on the cross Remorse in this context is felt down to the very marrow of my soul and increases with each second I am away from my wife As far as my parents are concerned what can an errant son do or say to make up for all the public humiliation he has caused two people who deserve so much better at this time in their lives In return for all their efforts on my behalf including a loving home environment extensive international travel intellectual stimulation and every educational opportunity a child could hope for I have burdened them with a crushing legal debt and a son whose i nd iscretions may yet obscure-his father's lifetime of service to the United States At the height of the Vietnam War when it was socially acceptable for University professors to send their sons to safety across the border in Canada my father very simply pointed to his four Presidential Citations from World war II and emphasized the fact that if drafted I·would serve because each generation of Jews had a civic obligation to repay America for our liberty Although I didn't disagree with him then on this point and basically still don't today I am nevertheless ashamed of what I've done to his concept of duty to the United States a spy for a son regardless as to what his ulterior motives might have been or for whom he was working is still nothing to be proud of Despite the tacit sympathy of the Jewish community I have undeniably broken the social contract in a way which brings DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declasa Div WHS Date OCT 2 6 2012 upon my family I suspect that no father or mother lose a child particularly when the sacrifice was a one unjustified in light of the existence of viable a ternative courses of action If I had been willing to view I rael's security needs in a less melodramatic way I undoubtedly c uld have satisfied my father's concept of communal ethics while s multaneously keeping faith with my sense of racial obligation my father always stressed that the minute these two issues a peared to be in conflict with each other it was time to r formulate one's opinions From my current perspective it is than evident that he was right and that my sin such as it w also involves a case of blatant intellectual laziness Although some individuals in my current predicament might a tempt to explain away their actions as a product of parental ditioning I can't do that All my parents ever wanted for h Anne and myself was that we should succeed in our respective professions live decent law-abiding lives and raise a family I hope to God I may yet be able to accomplish these goals for while they will not undo all the pain and suffering I have caused myl family they will at least give us all a better future to look fo ward to Until this happens I cannot look into my parents• eyes without feeling that I have robbed them of the peaceful autumn that they richly deserve One of the more excruciating aspects of this scandal has been the embarrassing effect it has had on the American Jewish 91W·ema y 49 DECLASSIFIED IN FULL Authority EO 13526 Chief Records Dectasa Dlv WHS Date OCT 2 6 2012 community To the extent that my actions have allowed the bigots to emerge from their closets wrapped in the respectability of the flag I have called into question the dependability of a group of Americans who have demonstrated on numerous occasions their dedication and loyalty to this country The accusation that Jews in general are a people who are not entirely reliable due to their emotional attachment to Israel is at best a debatable point and at worst an unsubstantiated and unwarranted indictment of an entire race While it is true that many Jews may indeed privately empathize witif my morar dilemma that does not imply that those same individuals either condone what I've done or for that matter would have committed the same act had they been in my position And although I stand accused of a crime for which I alone am responsible I fear that I may have also condemned my co-religionists through the well intentioned but misguided actions of one of its members This possibility has come as a sickening realization to me since one of the principal objectives I hoped to accomplish through my activities was the strengthening of this same Oiasporic community Unfortunately in addition to the problem I've risked creating between the American Jewish community and its government my activities may also have raised an equally serious question about the proper relationship between the Israeli Government and the local Diasporic community Given the evident willingness of the Israeli leadership to accept a level of sacrifice and attrition SFcr j ' n t' ' so --------------------------- ------- DECLASSIFIED IN FULL Authority EO 13528 Chief Records Dectass Dlv WHS Date OCT 2 6 2012 within the ranks of American Jewry that it would never tolerate within its own population a reappraisal of just what type of moral claim Israel has over us may have to be addressed I am deeply ashamed that this controversial debate will be forever associated with my name however important it might ultimately prove to be for those individuals who feel trapped between their sense of racial obligation to Israel and their allegiance to the United States My own conclusion from this tragedy is that as long as an American Zionist abides by the law he can serve the best interests of both Israel and the United States If a Zionist ------------·---- were to ask me in the future what he should do if approached by Israeli intelligence operatives to help them circumvent technology export controls for example my response will be that he should lobby to have the pertinent restrictions lifted That way not only can he directly assist Israel with a clear conscience but he can also reinforce the necessarily high degree of trust that must be maintained between Jerusalem and Washington if the alliance is to survive It simply does no good over the long run to help Israel illegally acquire technology and classified information if by doing so will only reduce the willingness of the u s Government to assist Israel in equally important strategic and diplomatic areas The Israelis have an understandable way of portraying a everything they need as a matter of life and death S E• 51 Although I DECi ASSiFiED IN-FULL----- -- Authority EO 13528 Chief Records DtCIIII DIY WHS Date OCT 2 6 2012 would not under any conditions downgrade the degree of risk they live with on a daily basis it is still important for Diasporic Jews by virtue of their objectivity and distance from the battlefields to add political perspective and ethical proportion to this near hysterical way of thinking If one casually discards the rule of law in pursuit of things that could just as easily be obtained through negotiation or other legal processes · then the first to suffer will be the very minorities whose only real protection in a democracy are those same laws and regulations hard way Unfortunately I have had to learn this fact the Despite my love for this country and the principles that it stands for I have somehow cheapened the value of our democratic traditions by assuming to be above the law however noble my objectives might have been In retrospect I should have either emigrated or joined a pro-Israeli think tank here rather than compromise the public's trust that was embodied in my security clearance I sincerely believe that one could successfully live under the discipline of two nationalisms without ever really thinking about what the consequences of a divided loyalty might involve namely an inability to recognize the existence of an absolute concept of personal accountability that transcends any narrowly-defined racial or ideological allegiance Because of this oversight I have helped to precipitate one of the most embarrassing diplomatic incidents between this country and its principal Middle Eastern ally In light of what I had intended to I 1 52 - ----- -··-· DECLASSIFIED IN FULL Authority EO 13528 Chief Records DICIIII Dlv WHS Date OCT 2 6 2012 accomplish by my actions remorseful seems to be the least appropriate way of describing how absolutely devastated I feel right now My only consolation is that I never contemplated undertaking any steps detrimental to the security of the United States and despite my very evident dishonesty was never quilty of disloyalty I admit to having been reckless and criminally irresponsible but never traitorous Although I was no ----· mercenary I let myself believe that Eitan's •salary• was a relatively benign cancer which could in no way call into question my true motives and ideals Well the assumption was wrong and that money has somehow metastasized into a disease of such ugliness that I fear it may yet overwhelm my natural defenses as indeed it was meant to do in the first place The only chance I have of redirecting the focus of this case back to its ideological origins and refuting the unjustified allegations of Eitan is to carry through with my previous intention of repaying the money back in full -- but this time to the United States Government If the offer to Eitan had been prompted by a genuine need to purge my system of its apparent corruption my desire to do so now is motivated by no less a sentiment With regard to the prospect of further incarceration the court should realize that my prison experience has to date been a sobering reminder of how totally helpless an individual can become once stripped of his freedom - i a 53 I feel like a person who ---- DECLASSIFIED IN FULL SEct Authority EO 13526 Chief Records Declaa1 Div WHS Date OCi 2 6 2012 has been exiled to a wasteland in which no one speaks his language and where he is viewed as a potentially dangerous foreigner to be treated with a combination of suspicion and racial animosity There has been no one with whom I could conduct a decent conversation for months and the ceaseless cacophony of noise that fills my ears day and night involves subject matter which is remarkable for its scatological content violence and utter amorality Although these observations may seem rather banal for those who have been professionally involved with the prison system I have felt like a lost explorer who has suddenly stumbled across a veritable hidden civilization of barbarians Whereas before r had my wife and a diversiffE d group of friends with whom I could strike up intellectually satisfying discussions at a moment's notice my close associates now represent the permanent underclass of thieves murderers kidnappers child molesters extortionists pimps and drug pushers who are hardly the type of people with whom I can easily coexist I truly miss coming home and being able to talk to my wife for hours about matters that required deep thought and reflection because I felt so alive at moments like that In contrast to this mentally stimulating environment the silence which has descended over my mind since having been imprisoned tends to numb one•s awareness of the world to such an extent that punishment seems barely distinguishable from non-existence If this is the objective of incarceration then it has more than successfully accomplished its purpose in my case -- each day is a struggle just to maintain my sanity and civility DECLASSIFIED IN FULL Authority EO 13528 Chief Rec grds Decta11 DIY WHS Date OC I 2 6 2012 Impressionistically I seem to have heen cast headlong down a pit of my own making the bottom of which I can only simply perceive Left alone to ponder the fate which awaits me I pray that the court will take into consideration the fact that I did not operate beyond the pale in a manner designed to hurt this country My dreams simply outstripped my ability or willingness to cope with them in a responsible way Every day I've spent in prison has reminded me that it is not up to any one indb idual in society to unilaterally write his 7 own set of civil ethics no matter how idealistically pure they might be If this occurs society wi exactits punishment more out of a sense of self-preservation than vengeance Obviouslv if more people were to behave as I did the country could descend into an anarchic condition in which each ethnic group believed itself to have extra-legal rights and superseding obligations to its respective homeland I didn't stop to think that the current Lebanese malaise may have had its roots in just this type of ethnic arrogance and that is a national tragedy which I would never on my life wish to see duplicated here Sitting in prison has clearly forced me to address and come to terms with many aspects of this case which I had previously either been unwilling or unable to appreciate One of the issues I've thought about is how my imprisonment has affected those of my co-religionists who might be inclined to commit a similar act of espionage for the Israelis in the future 55 Like me these DECLASSIFIED IN FULL Authority EO 13528 Chief Records DIOIIII DIY WHI Date OtT 2 6 2012 people are not criminals in the conventional sense of the word i e sociopathic and would not view the prospect of spending any amount of time in prison with equanimity -- it represents nothing short of the end of the world the border between life and something more ominous for them Enduring the public disgrace associated with having gone to prison is not something that we've been trained to accept as part of our obligation to Israel To the contrary we've always asst ed that imprisonment was a risk which only the Russian Jews faced in their attempt to emigrate OVer the years though I think some of us lulled ourselves into believing that due to the nature of our society and the unique st-rategic relationship that exists with rsraer '- - ---------- - anything done for the latter would somehow be implicitly condoned here As I sit in my cell right now the absolute legal and political bankruptcy of this line of thinking could not be more abundantly self-evident I'm quite sure that this point has also been recognized within the community and will stand as an effective deterrent to further ca_ses of misguided altruism By far and away the most serious loss I've suffered from throughout my imprisonment has been the separation from my wife without whom my life ceases to have any importance or meaninq I love and care for her more than I can adequately describe in mere words and feel devastated that my actions have inflicted such pain and suffering on her At a time when I should be bv her side helping her through a plethora of medical problems I've· obliged her to travel for hours each week in near tropical heat DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Dl WHS Date OCT 2 6 2012 t i to be with me down in Petersburg In spite of the incredible physical discomfort involved with these trips which forced her into a local emergency room on one occasion I am told by prison officials that she has appeared more times than any other wife that they can remember Although she has put on a stoic face for me I can still see what the accumulated tell from this ordeal has done to her If prison can force a man to concentrate on what he feels is the single most important thing he's lost by the commission of a crime then clearly the elimination of our emotional and physical intimacy is something that never ceases to underscore the unconscionable stupidity of what I've done wake up at- night totally-perplexed at -· - how I I could have sacrificed --- - - -·--··· ----- our-·rrfe together on the ··al-tar· of some elusive racial obligation Anne has already endured so much on my account that the thought of her going to prison agai n fills me with a sense of absolute despair and anxiety If the court is moved to be merciful in its sentencing I pray to God that Anne will be spared the trauma of additional incarceration and be permitted to reconstitute her life in preparation for our reunion V Although I realize that my case has created quite a strain in the relations between Israel and the United States by cooperating as fully as possible with the u s Attorney's Office I have attempted to conduct myself in a manner designed to reduce SEt ttt ·l 57 DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Dlv WHS Data OCi 2 6 2012 the long term embarrassment to both governments I felt that the sooner it was known to the authorities here that the operation was not directed against the United States the easier it would be for the Israelis to admit their official involvement and explain the true nature of mv activities The fact that this failed to occur does not in any way call into question the propriety of my decision I had hoped that to the extent the government could be quickly assured that no damage was sustained by the intelligence community's clandestine agent nets and communications security the faster everyone could relax and proceed with both a more restrained debriefing process and diplomatic demarche with the Israelis In addition I had also assumed that my candor would be immediately matched by that of Israel in order to prevent the scandal from escalating into a media event which would benefit no one except our common enemies Unfortunately this too did not happen In light of my apparent abandonment I feel that I have a special responsibility to ensure that this type of debacle does not happen again I will not sit idly by and watch yet another well-meaning but misguided American Jew blindly offer his services to the Israelis under the naive assumption that he can break the law with impunity because the Israelis will intercede on his behalf If there is a potentially constructive side to this affair it is that I can now speak out decisively on how the only obligations American Jews have to Israel while citizens of this country at least are to police our own backyard with regard 58 DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declass DIY WHS Date OCi 6 2012 nationalism issue is resolved in favor of the needs of the Diasporic community I pray that the court will understand my true motives in this case and will facilitate my early return to society where I believe I can contribute something positive to the future course of u s -Israeli relations In the final analysis I do not want to qo down in history as anything other than what I am a misguided idealist who engulfed by moral ambiguities made an egregious error of judgment broke the law paid the consequences and attempted to set matters right DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Dlv WHS Date OCi 2 6 2012 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document was delivered to Charles S Leeper Esq and David Geneson Esq Assistant u s Attorneys this 27th day of February 1987 by depositing a copy with the Court Security Officer pursuant to the Protective Order dated October 24 1986
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