Exhibit OSD MDR Case 12-M-2766 see·'RET -----T ssz Office oftheSecreta ryofDefcnse V·S· ' Chief PD ESD WHS Date kb C T'Ze 2 Authonty EO 13526 · Deny in Full 1 · silli D as· '1 ' art· - - - UNITeD STATES DISTRICT COURT i tfyj yp d c FOR THE DISTRICT OP COLUMBIA MDR lk _-M- 'l t Q UNITED STATES OF AMERICA v JONATHAN JAY POLLARD Criminal No 86-0207 RECOMMEND PARTIAL RELEASE 25X1 GOVERNMENT'S REPLY TO DEFENDANT'S SENTENCING MEMORANDUM The United States Attorney States by and for District of the Defendant JONATHAN J tenclng hereinafter JONATHAN J through its attorney Columbia hereby POLLARD's First Memorandum Defendant's POLLARD'S second United replies in Aid of to Sen- First Memorandum and Defendant Memorandum in hereinafter Defendant's Second Memorandum• Reply the government submits the following Aid of Sentencing In support of its DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Oiv WHS Date OCT 2 6 2012 INTRODUCTION It would not be possible for the government time remaining the in the limited before sentencing to specifically respond to each contention contained in the voluminous pleadings filed by defendant only five days before the scheduled hearing Although defendant's First Memorandum was ostensibly prepared in August 1986 and could have been submitted for classification review at any point thereafter no explanation has been offered for its belated filing government llill however attempt herein to -• It Jw tO • I' ·I 'Wif v ·· ·· - briefly The cite Eor the ALL FBI I lfOrufATION COZITAHIED HEREIN IS UNCLASSIFIED DATE 10-17-2012 BY 60324 UC BA SAB sab DECLASSIFIED IN FULl Authority EO 13526 Chief Records Declass Div WHS Date OCi 2 6 2012 -2- Court's consideration examples of the deceptive statements and distorted analysis which are characteristic of defendant's pleadings and which evidence defendant's calculated effort to obtain a polltical solution to these criminal proceedings 1 Calculated Effort to Obtain Political Solution Defendant's pleadings reinforce the tactic which he has re- lentlessly pursued during recent months -- to garner support for a political solution this Court to the criminal proceedings pending before Defendant continues to express his hope that his in- carceration may be cut-short by a diplomatic or administrative solution Although this embarrassing type of discovery Israeli espionage against the United States has previously occurred both parties very often resolved their differences quietly through diplomatic or administrative channels neither state wishing to prec1p1tate 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 inclined to act responsibly from the start and to quickly admit their culpability Defendant's First Memorandum at 29 Emphasis added DECLASSIFIED IN FULl Authority EO 13526 Chief Records Dec lass Div WHS Date OCi 2 6 2012 -3- Indeed defendant admits that his decision to cooperate with U s authorities was prompted by an expectation that diplomatic dis- cussions regarding the resolution of his casg would ensue I had hoped that to the extent the U S government could be quickly assured that no damage was sustained by the intelligence community's clandestine agents nets and communications security the faster everyone could relax and proceed with both a more restrained debriefing process and diplomatic demarche with the Israefis Emphasis - - r - J ---adueu 1 --n r -at58- Defendant has done more than merely express a hope for a political solution In recent months he has repeatedly made statements designed to obtain popular support in Beginning with his November 20 published the 1986 interview with Wolf Blitzer following day in the solicited po 1 it ical efforts by Israel for such an effort Jerusale Israel Post defendant has to obtain his release ''I feel the same way that one of Israel's pilots would feel if after he was shot down avoiding the issue nobody made an effort to get him out • By Israel is leaving an unhuried body to rot and stink and foul the air copy attached as Exhibit A to Government's Memorandum in Aid of Sentencing Similarly in a lengthy letter authored by defendant and published in the Jerusalem Post on January 27 1987 defendant attempts to glorify his actions I am neverthless confident that what I did • • • will make a significant contribution to Israel's military capabilities complains of the DECLASSIFIED IN FULL Authority EO 13528 Chief Records Declass Div WHS Data OCT 2 6 2012 -4 painfully slow process of judicial crucifixion and laments that w e fully expect the worst because no one has summoned the Jewish community to put a stop to this ordeal copy of January 27 1987 Jerusalem Post article attached hereto as Exhibit A These public relations efforts recently culminated in yet another newspaper article designed to glorify defendant's actions and minimize the public percept ion of harm resulting from defendant's espionage activities However unlike the prior instances of in- terviews and public dissemination of information by defendant which canst i tuted technical violations of defendant's obligations under the plea agreement on this most recent occasion defendant's dis- closures to the press constituted unauthorized dissemination of classified information as well as a violation of this u s Court's protective Order On February 15 Reporter Wolf 1987 an article authored Blitzer and entitled Pollard by Jerusalem Post Not a Bumbler But Israel's Master Spy appeared in the washington Post copy attached hereto as Exhibit B In the initial portion of the article six categories of information are described according to the article these categories constitute a portion of the classified information delivered by defendant to Israel The ·author of the article of course did not identify the source which revealed that this speci Eic information had information was been compromised attributed Sources including to a by defendant number of Israeli one American with firsthand Pollard case Exhibit Bat p 1 Rather the and American knowledge of the DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Div WHS Date OCi 2 6 20 2 -5- As explained in the Government's Memorandum in Aid of Sentencing government counsel previously learned that defendant was the source for information previously published by Wolf Blitzer in the a p- - Post on November 21 1986 obtained during an interview with defendant at Petersburg Federal Corrections Institution FCI the preceding day See Government's Memorandum in Aid of Sentenc- ing at and pp 52-53 Exhibit A At thereto that time the government set forth its view that the provision of information by defendant for publication is in direct contravention to paragraph 9 of the plea agreement executed by defendant quires defendant to submit all information that paragraph re- prior to publication for a classification review by the Director of Naval Intelligence Id at n l3 In view of defendant's prior circumvention of paragraph 9 of the plea agreement information he and sold to given his Israel investigation to determine FCI and learned Wolf Blitzer on First government counsel with the commenced an the publication of the February government counsel contacted Petersburg that defendant had January familiarity if defendant had again provided in£or- mation to Wolf Blitzer following 15 1987 article singular 29 1987 publication of the attached article again only agreed to a two weeks visit prior to from the With this discovery govern- ment counsel along with agents of the FBI conducted an interview of defendant in the presence of his attorney on February 18 1987 DECLASSIFIED IN FUll Authority EO 13526 Chief Records Declass Div WHS Date OCi 2 6 2012 ' -6- At that time defendant was shown a copy of the attached February 15 article whereupon defendant specifically denied providing Wolf Blitzer with any of the categories described in U s the information In article contained fact in the defendant six stated that he did not even confirm for Blitzer that any of the six descriptions were defendant he intended to subject At accurate and his conduct a counsel the outset were of this interview advised that the with government polygraph examination of defendant on this After he had denied that he provided the information to Blitzer defendant was again advised of our intent to measure the veracity of his responses by polygraph examinations Defendant was given the opportunity to reflect upon his answers and consult with counsel after doing so he again denied any role in providing the information contained in this article On the morning of February 25 1987 defendant was transported to the Washington Field Office of the FBI There Special Agent Barry Colvert the polygrapher who has conducted all of the examinations of defendant in connection with this case informed defendant that he would be polygraphed specific categories of u s washington Post article the opportunity to on nine questions to the information contained in this attached At this time defendant consult relating with his counsel was again given After doing so defendant informed Special Agent Colvert that he was now prepared to tell the truth about his role in the preparation of the attached article Defendant proceeded to admit that on January 29 1987 at u t t •• CD 3 1 C DECLASSIFIED IN PART -BESREf OSD 3 3 b J t g Authority EO 13528 Chief Records Declass DIY WHS Date -1- OCT 2 8 2812 Petersburg FCI defendant in fact discussed with Wolf Blitzer each of the six categories of classified information described in the article Special Set forth below are Agent· Colvert as the admissions defendant made to to each category of information lities Wheri Blitzer asked for a description of the which defendant confirmed that had provided he had Israel delivered to satellite photos and maps of c on this Israel u s information subject the defendant u s classified chemical-warfare facilities u s Assessment of a PLO Unit Blitzer asked defendant if he had provided Israel with classified information about a PLO unit named Force 17 firmed that he had followed Defendant con- u s classified intelligence assess- ments about this PLO unit and provided such information to Israel d Soviet Arms Shipments to Arab States Blitzer asked defendant classified information about if he had provided Israel Soviet arms with u s shipments to Syria and DECLASSIFIED IN PART Authority EO 13528 Chief Records Declass Dlv WHS Date OCT 2 6 2012 -8other Arab states information When Bli tzar inquired if classified information was provided regarding SS-21 and e Defendant confirmed that he had provided such the two particular defendant SA-5 soviet missile answered in systems -- the the affirmative Soviet-Made Fighters When defendant was discussing with Blitzer the information regarding the above-mentioned Soviet u s classified arms shipment defendant volunteered that he had also provided to the Israelis u s classified intelligence assessments of a particular Soviet fighter Defendant admitted to Special Agent Colvert that the description of this subject contained in Blitzer's article is a verbatim recitation of the f Blitzer's ised u s sources classified analyses of a Defendant confirmed that this was true classified satellite in his discussions with Wolf photos of There can be no dispute that Blitzer defendant revealed sensitive Defendant's knowledge of the u s information classified information revealed during this documents which defen- OSD 3 3 b I 1 Jft 3· 3 k DECLASSIFIED IN PART Authority EO 13528 Chief Rec 9rds Declass Dlv WHS Date OC I 2 6 2012 OSD 3 3 b l 1 Co Cf4 S·3 -9- the fact that the u s has used its reconnaissance satellites to authorized to receive it such as Blitzer is not only a breach of the plea agreement but is also a serious violation of the laws designed to protect our national security se u s c 18 S 793 d The gravity of defendant's conduct is compounded by the fact that he understood and intended that the information he disclosed would be published Defendant admitted to Special Agent Colvert that he was motivated to disclose this classified information by the-- anger-wtrictr he-- fee·ls- towards-government- counsel-• Moreover all of defendant's in particular those ost statements to previously made to on November 21 for defendant • s the press Blitzer and including reported in this Jerusalem 1986 have been designed to invoke smypathy cause Thus it is evident that defendant's dis- closures to Rlitzer were both calculated and vengeful It is also clear that even though he is incarcerated defendant continues to wreak damage to u s national security According to U s diplomatic and intelligence officials the February 15 1987 article published by Blitzer contains u s classified information which endangers our relations with countries such as While we cannot be certain that this article would not published but for defendant's disclosures the publication of this article only two weeks 4- - A 1 n L - J after 'J the interview with DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Div WHS Date OCT 2 6 2012 -10defendant cannot be mere coincidence Certainly defendant's dis- closures resulted in mote specificity in the article and thereby more potential for damage to Equally invidious u s national security is defendant's unauthorized disclosure to Wolf Blitzer of information contained in the Weinberger Declaration When interviewed by government counsel and FBI agents on February 18 1986 defendant was shown the description of the TOP SECRET Codeword Weinberger Declaration reported in the Blitzer article whereupon defendant specifically denied discussing the document with Blitzer However during the February 25 1987 pre-polygraph examination interview with special Agent Colvert defendant acknowledged that the description of the content of Secretary Weinberger's Declaration reported by Blitzer was a verbatim recitation of information revealed by defendant Defendant admitted that when Blitzer inquired if the Weinberger Declaration concluded that u s national security had been defendant provided harmed the by defendant's patently espionage self-serving activities description of the Secretary's damage assessment which appears in Blitzer's article The Weinberger Declaration was made available to defendant and his counsel 1987 immediately upon its filing in camera on January 9 Defendant was granted access to this classified government pleading pursuant to the Protective Order entered by this Court on October 24 1986 That Order provides in pertinent part DECLASSIFIED IN FULl Authority EO 13526 Chief Records Declass Dl WHS Date OCT 2 6 2012 -11- The purpose of this Protective order is to insure that thoseLnamed hereif 'l · tncluding defendant will never divulge the classified information or documents disclosed to them to anyone who is not authorized to receive it and without prior written authorization from the originating agency and in conformity with this Order October 24 1986 Protective Order at p 12 On November 12 1986 defendant expressly acknowledged his obligations under the Protective Order in executing under oath the required Memorandum of Understanding copy attached hereto as Exhibit C It is clear however that defendant is no more willing to honor his sworn representations to this Court than the numerous non-dis closure agreements he executed and subsequently breached during his employment with the u s Navy see examples of non- disclosure agreements executed by defendant attached as exhibits to Weinberger Declaration Defendant's public disclosure of sensitive information which he directly attributes to the TOP SECRET Codeword Declaration of the Secretary of Defense was a calculated effort to minimize the public perception of damage caused by defendant's espionage activities It therefore cannot be explained away as a mere thoughtless or negligent act the tactic which Rather this act ion was wholly cons is tent with defendant has relentlessly pursued throughout recent months -- to garner support for a political solution to his incarceration ··· t 'l- t· · DECLASSIFIED IN FULL Authority EO 13528 Chief Records DecJass Div WHS Date OCi 2 6 2012 -12- This pattern of public relations gambits undertaken by defendant belies the image which his counsel have sought to present of a defendant who while submits himsel E to the frustrated mercy of and the desperate Court respectfully Rather defendant's recent conduct has demonstrated that he is as contemptuous of this Court's authority as the laws and u s semination of defendant 1 s guilty classified plea and regulations information sentencing could have demonstrated remorse and a conduct to the law Instead has governing the disThe period between t irne when he been a willingness to defendant has proven conform his through con- tinued violations of the plea agreement and the Court's Protective Order that he is a recidivist and unworthy of trust 2 Deceptive and Misleading Statements It is 1 of course 1 true that the through use of polygraph examinations the roles of government has confirmed defendant's description of Israeli co-conspirators in this espionage operation Defendant has sought to exploit this fact by indiscriminate claims throughout his pleadings that the polygraph has confirmed his selfserving version of events While defendant could have recited the precise polygraph question asked to support his does defendant polygraph question point to a specific assertedly answered truthfully claim only once which he In fact in the instance cited the polygraph actually exposed defendant's eception - DECLASSIFIED IN FULL Authority EO 13526 Chief Records Decrass Dlv WHS Date OCi 2 6 2012 -13- In defendant's Second Memorandum he contends that the government's • • polygrapher specifically interrogated Mr Pollard on his motivations f or providing information to Israel The polygraph operator found no deception when Mr Pollard stated that he acted_ £E_imarily for ideological reasons atp 27 Defendant was never found to be non-deceptive in his claim that he acted primarily for ideological reasons In fact only two polygraph questions were posed to defendant on this subject and his responses to both questions were determined to be deceptive earlier interviews of defendant was asked defendant financial to me with providing classified by the polygrapher Did you provide classified material to the Israelis solely for personal intentionally lied conducted In one of the material regard to the gain tt and to your 2 true Israeli Have you reasons government for When defendant answered these questions no his responses were determined by the polygraph to be deceptive These specific questions were selected by the polygrapher at the outset of the polygraph examination as Such control questions are intended among control other questions reasons to obtain a reading on answers which because of information already related by the subject early stage of the polygraph examination defendant had conceded that money had played an pionage activites increasingly important role in his es- Given the strong deceptive responses to these control questions defendant again are known to be deceptive Even at this the polygrapher never posed the question to Moreover defendant never requested that he be DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Dlv WHS Date OCi 2 6 2011 -14- tested on this subject after the control question exposed his 1 deception Because the evidence of defendant's financial excesses revealed by the government's investigation is in our view overwhelming reference in our previously filed sentencing memorandum to defendant's inability to survive polygraph inquiry of his ideological defense seemed unnecessary overkill the government's restrained that he truthfully answered a Inexplicably defendant responded to approach to this issue by asserting polygraph question about his motives which the record shows he was never asked There are several other examples of defendant's dissembling which can be briefly addressed In defendant's First Memorandum he now claims that it was Rafi Eitan to whom defendant addressed his offer to repay all establish a at 39 at an Israeli from the Israelis and to intelligence training center This is at least the third version of this story defendant has told FBI and chair the money received During a debriefing on September 4 1986 defendant told NIS agents that he had written a letter to Joseph Yagur offering to repay his espionage proceeds and fund an Israeli intelligence chair On October 1 1986 during a pre-polygraph examination 7 In-subsequent interviews with the polygraph examiner defendant admitted that his motives in conducting espionage were mixed He explained that while he commenced his activities for Israel for ideological reasons he was quickly corrupted by the monies he was paid Moreover defendant never informed the polygrapher that he resisted the Israelis payments Indeed defendant acknowledged that by the summer of 1985 he developed an addict ion to money The polygrapher accepted this explanation as has the government in its Memorandum in Aid of Sentencing we are prepared to have the Court sentence defendant on this basis - J• - · a • ut -· • DECLASSIFIED IN FULL Authority EO 13526 Chief Records Declass Div WHS Date 'OCi 2 6 2012 ' tt -15interview regarding this and other subjects defendant admitted to FBI polygrapher Barry Colvert that he never had written a letter on this subject to Yagur but instead asked Irit Erb to inform 2 Yagur of defendant's aspect common to intent each of in this regard these three versions About the only is that defendant repaid none of the money received all of which had been spent by the time of his arrest Another example of defendant's false exculpatory explanations is his claim that he never would have received all of the money promised him by the Israelis in particular the annual $30 000 deposit into a foreign bank account because he had already made the decision to terminate his activities at tl1e end of 1985 defendant's First Memorandum at 41 Defendant also now claims that he never saw any proof the foreign bank account existed and that the United States has determined that the account was devoid of funds Defendant's Second Memorandum at 29-30 During all of his prior debriefings and interviews defendant has never revealed activities at the informed government this decision end of 1985 to terminate his espionage Instead def endant has previously investigators that in October 1986 after he had been promised an additional $30 000 each year for ten years defendant executed into which the signature money was to cards be for the deposited foreign The bank account government has v-Tnfslast- version is repeated in defendant I 9 Second Memorandum at 26 n 5 and is also at odds with the above-mentioned version appearing in defendant's First Memorandum at 39 Thus defendant has been unable to keep his versions on this subject consistent even as between his two pleadings DECLASSIFIED IN FULL Authority EO 13526 Chief Records Dec lass Dlv WHS Date OCi 2 6 2012 -16- obtained confirmation that the foreign account was in fact established for defendant by Joseph Yagur and monies deposited therein Defendant certainly did additional monies and not has refuse never conclude the espionage ope rat ion the Israeli before within claimed offer any two months of these intent to of executing these signature cards In any event further financial if defendant's point gain from Israel is that he expected after 1985 himself in the very next paragraph of his pleading acknowledges that whenever he ceased his the U s he no contradicts There defendant espionage activities in it was understood that he would remain on the Israeli payroll The understanding was that since I would eventually be employed either in the official or gray arms market this assignment advising Yagur on arms sales could be viewed as my initiative commission and all defendant's First Memorandum at 42 It is therefore obvious defendant well understood that his ability to profit from his clandestine relationship with Israel was not limited to a short-term period of time Despite the fact that defendant's veracity regarding his claimed ideological motives has heen seriously undermined he sees fit to challenge the veracity and motives of certain u s citizens to whom defendant disclosed classified information and who have cooperated in the government's investigation Defendant asserts that these individuals should be disbelieved because the government did not charge them with law violations and did not subject them to a polygraph examination First it should be noted that each of these - ' DECLASSIFIED IN FULL Authority EO 13526 Chief Res ardJ Declass Div WHS Date Ut I 2 6 2012 -17- individuals unlike defendant immediately and completely described their receipt of classified government investigators information lenges only the first contacted by second after some dissembling responses defendant eventually confirmed these defendant's unauthorized when disclosures individuals 1 descriptions Since defendant characterization of his motives now of chal- in providing the information there was and is no need to subject these cooperating individuals to a polygraph Finally in criticizing the government's decision not to charge these individuals defendant has lost sight of the fact that it was he not the cooperating individuals who violated a 3 ancial gain- 2 sworn Distorted laims non-disclosure oath in expectation of fin- Regarding_ Lack of Harm_ to u s Security Defendant begins his argument with the groundless suggestion that Secretary Weinberger signed his Declaration in ignorance of its contents defendant's second Memorandum at n l Secretary insisted as early as May 1986 that he In fact the be personally 3 In defendant's Second Memorandum he also attempts to explain his unauthorized disclosure of u s information classified SECRET NO FOREIGN DISSEMINATION to Australian Naval Attache Peter Mole • In this respect defendant claims for the very first time that he was authorized by his superiors to give Mole the information In defendant's November 19 1985 written statement to the FBI he said The only other non-authorized individuals I passed classified information to was LCDR Peter Mole Royal Australian Navy in the Spring of 1985 at p 10 In all subsequent statements to investigators defendant continued to acknowledge that this disclosure was unauthorized and made without the approval of or notice to his superiors DECLASSIFIED IN FULl Authority EO 13526 Chief Records Declass Div WHS Date OCi 2 6 2012 -18- involved in describing for the Court the damage caused by defendant's _ crimes Beyond this frivolous assertion about the Secretary's familiarity with the case defendant offers no authority to refute the detailed description of damage submitted i this case in camera Rather defendant is asking the Court to disregard the u s classified information disclosure policies implemented by the President and his predecessors over the last forty years and to accept those formulated by defendant instead We believe it is critical in this regard for the Court to focus upon a statement which defendant has made in his pleadings that I'd be the first one to is currently 28 facing This statement Verstate the degree of danger Israel Defendant's First Memorandum at is true without a doubt as is the logical corollary of this statement -- that defendant would be the first one to understate the degree of damage to u s security caused by his unlawful activities It is with reference to these related truisms that we ask the Court to measure defendant's self-serving distortion of the Weinberger Declaration Defendant's counsel join their client in criticizing the Secretary's participation in the sentencing phase of this case by arguing that the damage assessments in another espionage case in which they are counsel were not signed by the secretary of Defense That case United States v Zettl et al does not involve espionage but ratller the unauthorlZed dis closure of classified in format ion contained primarily in a single document to u s defense contractors The security clearances counsel had been granted in that case were for a much lower classific tion level and would have authorized access to only a small portion of the information involved here The Secratary' s participation in this case is therefore clearly appropriate defendant's counsels' continued efforts to divert attention to other cases is not ' DECLASSIFIED IN FULl Authority EO 13526 Chief Records Declass Dtv WHS - Date OC1 2 6 2n'2 - -------- ·rg- -· First defendant faults the Weinberger Declaration ' assessment of damage both actual and potential aspect of the damage analysis defendant u s its As to the latter argues should disregard the reasoned concerns of a for that the Court Cabinet member as to the real potential for further injury resulting from defendant's crimes In short defendant state with certainty that says all the that if the government damage which could cannot reasonably occur in fact has occurred before sentencing an espionage defendant should not be held accountable for potential harm which he alone has wrought In support that the of this government assessment has argument had defendant fifteen erroneously observes months to conduct damage Defendant did not reveal the specific documents which he had compromised until after his plea in June 1986 1986 defendant had identified thousands of and messages a which he had sold to u s Israel By September classified documents and acknowledged that there were many more which he could not specifically recall process of making even a preliminary assessment of the The resultant da1nage could not possibly be done in the following few months and in fact will take years to complete Although the ments for analysis government in selected twenty representative docu- the Weinberger Declaration not even address the speci fie defendant does reasoned project ions of damage re- sulting from the compromise of these documents which the Weinberger Declaration contains Instead defendant resorts to arguing that DECLASSIFIED IN PART Authority EO 13528 Chief Records Declass DIY WHS OSD 3 3 b f Date OCi 2 6 2012 -20- CfA 3·3Lb l such as the use of these potential risks u s classified infer- mat ion by Israel against third countries the provision by Israel of u s classi fed information to third countries adverse to the u s or the further compromise of u s classified information to hostile countries -- would not likely occur since Israel is a close and careful ally The short and dispositive answer to this argument is that it was this close and careful ally who by defendant's own account mounted a large-scale espionage operation against the United States In doing so it demonstrated contrary to defendant's claims that Israel considers its own interests paramount to those of the United States obtain The purpose of u s this Israeli espil nage operation was to classified information that successive administrations both Republican and Democrat porters at least defendant have as ardent comprised of many pro-Israeli and determined certainly more should These non-disclosure policies not were and or U s be grounded sup- experienced than disclosed in the to Israel reasoned and interests would not otherwise be served In defendant's myopic view notwithstanding this forty-year old policy he remains best equipped to determine what Israel needs and is capable of protecting Three representations in his plead- ings point up the folly of this position Pirst defendant says the u s policy of sharing some information with Israel demonstrates our willingness to assume the risk of a hostile country infiltrating 5 3 3Gb Ct oso 3 3 b ' Co CJJ1 DECLASSIFIED IN PART Authority EO 13528 Chief Records Declasa Dlv Date OCT 2 6 2012 -21- 3-3tb J the Israeli at 11 intelligence community defendant's second Memorandum The obvious fact pared to assume the is that although the U s may be pre- risk that the less sensitive information we authorize for d is closure to Israel might be compromised the U s is unwillin to put at risk the more highly classified information 5 which defendant stole in contravention of u s disclosure policies Second defendant describes secretary Weinberger's determination of Israel's military and intelligence needs as facile C Id However it of was defendant's uninformed assessment at 12 Israel's needs which was easily made since he was not burdened by considerations of countervailing benefits to the United States In con- trast the assessments of Israel's needs made by Secretary Weinberger and all of his predecessors have whether those needs were included an analysis of consistent with u s national security Finally defendant states that it is inconsistent for the Secretary of Defense to describe the damage caused by Israeli espionage This argument demonstrates above all others defendant's complete loss of any perspective consistent with our national security 1 It is a sign of defendant's desperation that he seeks to Defendant also attempts to excuse his conduct by claiming the u s was holdi ssified information which should been disclo ac now se exc ange nts and he along with his been given the opportunity to review the entire list of documents compromised by defendant Yet he has not identified a single document of thousands compromised that wa • o i thheld b the U s l · · - · · · · · • DECLASSIFIED IN FULl Authority lO 13526 Chief Records Dec lass Dlv WHS Date OCi 2 6 2012 -22excuse his traitorous conduct by noting the u s spys too While the distinction may have been lost on defendant we are confident that it remains clear to virtually any other citizen of the United States 3 Distortion Regardi_Q_q Exte_nt and Valuf of Cooperation Defendant challenges the description of his cooperation pro- vided in the Government's sets forth nineteen 19 Classified Sentencing Memorandum areas of cooperation which and he states should be weighed heavily by the Court defendant's second Memorandum at pp 37-40 As explained briefly hereinbelow the extent and value of this cooperation is grossly exaggerated by defendant As the government has previously acknowledged defendant has provided information about which he has personal knowledge regarding the activities of his co-conspirators and the methods as well as the facilities used by them to receive the classified information compromised by defendant This cooperation is required by the plea agreement and in our view is the very least to be expected of a defendant pending sentencing on an espionage charge See defendant's Second Memorandum at 37-38 1 2 8 9 10 11 16 However defendant's description of this aspect of his cooperation has been embellished to u s For example defendant describes his revelation investigators that he briefly observed a large xerox machine and camera at the Irit Erb's apartment building as document duplication technology Defendant also and electronic describes ' the ' emissions instructions he control methods received from his DECLASSIFIED IN PART Authority EO 13528 Chief Records Declall Dlv WHl Date OCT 2 6 2012 -23- •handlers• about where to travel for meetings as detailed insight into Israeli clandestine modus operandi which included •• • international travel arrangements and command control networks Id at 37 This hyperbole should not be mistaken for cooperation of value The information defendant says he provided about high-level Israeli government policies and activities Defendant's Second Memorandum at 38-39 4 5 12 13 14 18 and Israeli intelligence activities not specifically related to defendant's espionage activities Id at 3 6 15 19 was in fact based upon second or third hand information obtained from defendant's handlers and has not 6 indeed cannot be verified - significantly while defendant • s description of his cooperation implies to the contrary defendant has not provided U s investigators with verifiable information about other specific Israeli espionage activities in the u s Finally defendant expounds upon the briefings he was asked to give intelligence officers on various subjects including some ''beyond the realm of his activities for Israel Defendant's Second Memorandum at 41 ice NIS The fact that FBI and Naval Investigative Serv- agents 1 istened politely while defendant deviated from the subject of his espionage activities and the agents then closed the interview with a courteous thank you has been misinterpreted by defendant as an acknowledgement that defendant's excursions into unrelated areas were of value In its Classified Sentencing defendant claims Israeli Cabinet p su scuss ons source Joseph Yagur Defendant's information regarding arms sales to Iran and the Afghanistan Mujaheddin concerned only fragmented discussions with Yagur OSD 3 3 b l 1 DECLASSIFIED IN FUll Authority EO 13526 Chief Records Declass DIY WHS Date OCi 2 6 2012 -24Memorandum the to U s government investigators cooperate which has has described the information imparted by defendant pursuant to his agreement to been of value to this investigation We believe that description is the only fair and accurate one which has been presented to the Court Conclusion The expressions of remorse contained in defendant's pleadings are both belated and hollow we suggest that the Court is now told defendant is remorseful only because the government has previously informed the Court of defendant's February 1986 statement to the FBI that he would commit espionage for chance In fact himself from that inmate's defendant began the process of trying to distance this another inmate Israel again if given the at candid admission Petersburg offense and FCI when make realized a in July similar how damaging 1986 he heard statement about such a remark could be at sentencing Moreover all of defendant's statements of remorse are grounded in the fact he was caught and not in recognition of the wrongfulness of his actions Defendant complains primarily of the restrictions placed upon his freedom by incarceration He disdainfully describes the thieves murderers kidnappers child molestors extortionists pimps and drug-pushers with whom defendant has been incarcerated and professes amazement that these individuals view defendant as 7 potentially dangerous defendant's First Memorandum at 54 - That 1 TWhfle-tfie·--deprivations suffered by any defendant in jail are harsh defendant has chosen to make this point both during press interviews and in his pleadings through denigrating descriptions of the fellow human beings with whom he has been incarcerated This attitude we submit is another example of the arrogance which characterizes the conduct and judgment of this defendant DECLASSIFIED IN FULl Authority EO 1352 Chief Records Declass Div WHS Date OCT 2 6 2012 -25- defendant's fellow inmates consider him to be dangerous may be surprising to defendant but it is a view which is entirely consistent with the self-evident proposition that espionage is one of the most heinous of crimes in a case three year cited This view was adopted by the sentencing judge by defendant sentence was classified photograph the proposition that meant nothing a more United States imposed v Morison where a for the publication of a single Defendant refers the Court to that case for the volume defendant's accurate analysis of of Second the the compromised Memorandum at information However 5 Morison sentencing rationale is that three years is the appropriate penalty for an isolated incident of unauthorized disclosure of classified information to a publisher or newspaper In the present espionage for pay case defendant has and his engaged in a pattern of unauthorized disclosure of classified information has continued even after his arrest and incarceration The evidence has revealed defendant's perception and belief that he need not conform his conduct to long-established information disclosure policies U s espionage laws plea sworn agreements u s non-disclosure or orders of classified agreements this Court _ _ '· ·- L -26- DECLASSIFIED IN FUll Authority EO 13526 Chief Records Declass Div WHS Date OCi 2 6 20t2 Accordingly we ask the Court to impose a sentence which reflects both the damage already inflicted by defendant upon the national security as well as the continuing risk of disclosure posed by this defendant Respectfully submitted - -- L c--t c c - '-1 - c l I JOSEPH E DIGENOVA United States Attorney C 7 'L tt- 1 ___ t ' ' · t -L-LEEPgR _ _ __ CHARLES S Assistant United States Attorney States Attorney CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing Government's Reply to Defendant's Sentencing Memorandum has been by hand to counsel for defendant Richard A Hibey Esquire and James F Hibey Esquire at the Department of Justice Security Center this 3rd day of March 1987 t United s ·r- -States Attorney Assistant ·f • ' •'''i li ' JJ tl ' 1·· ·•' ' - ·l p '· ' t -· ·I ' _ ' J'··' i 'l · ' ·1· ·····1 '· 'lllt '····•· • t - J ' h I ··-· ''I· ' A 1 fJI l Ni IJ J Pagel ---- Vol LV No 164Jl TIIUdaJ Jaouall' ' l7 1 187 • Tncal6 5747 • JonaadaAwal 1407 ·mso ao Ei1MtNIS0 70 ---- ------------------------------------------------- - re ci f dRtoo e is'assitied In a letter to a concerned well-wisher Pollard describes his 'judicial crucifix1t fi c¥cgo 12 Jer lcm P Rcportt'r duri•l war or by the pn vc ntion of one thlough the strengthen- _Jvn l lrtm Pollard btllf lt'J 1hot lams ro l frtJ s long-ttr n ing or Israel's c l terrent capacity'theq at leait something good u ll lfl · eretndtt cl wonh lilt f Sk t tlloullf' umf hs tu r lOok Ill WJII h we come from thas tragedy pm' ' d lJJJ ird U S ua uflm t on lo hm l You ould understand rllatl was raised with the notion th t In •1 Inter I11 H month to Julum U11gur-Sargun ·I do ·tor who each und every Diaspore Jew hus an absolute oblig11tion to acq · ·' •'ar PJultJdriphu Pollard wmtt' lllill the III OrtiiiiiWII ht• as cme uf the tones so to speak whic h comprise the modern contrived sen ol ltionali urroundingthc ca hoth my ffiiJlivc s and instr ctior1s have been utterly d lorte bt y n d re o i· lion leavmg tht Amenc- Jil public walh the mL Iukcn uupres o aon that lsnu l hatlc mpfoyed i merc enary to umJen allt ac th·itie designed to damage the national secunry of the Unitc d States l espite the remote possibility that th grotesque rni reprc· cutll u cruJs Jh rd tllut u · off' 11cw gwa uor of uluu· sentatiOil of the operation may have been cau Cc l in part by the wpJumctJJed mllllury qu pmetlf was qwecly bt u•g mtrodu t'd 1l uu 11 on 1 o l u• t lr' hystcrill a5MlciH Cd with the $pate of Soviet pi llrrt stc J th t m1v ·lridl arsen_aLr rthout Jra f hemg fo twflrntd b v her ca u IU a cc Offt T l fWt 1 s 1 year 1 can't help but come to the c ondu i« 1 1111 cerllun oll ·nHhly Jo 'al all1es ' t y adla• IUf1W lt4uJf 'to k t Of J Mll CA U Ji'w · C M 11 political clements opposed to the extraordinari4 duM rc la· ' 'I'd JCVf'tl pll t lf'trer •w r ' r •pmrst I J u JIWrT ' 10''' u·m T 1t W _ _ II d fy d tionship between Jcru alem and Washington IJ- ' _c en u o mg 0 ' b rUnRttr· u gon ftl nut mmulll trxo wq•w•''l 11bow Jus c Mu l- I' 'j X U -1 J ru IIIICOt a pq u wt UA this case as a means of cmbarru5ing the Amerl' n J w15h ht llth qn l currtnt Jtare of A » h ul -a do fi · au· Ul'IJJ- gl tfv t community Israel and its allies within the goverimerjl Th ctor w otc to Pollard ou1 oft·mJCa rhat tilt J wJ h f· As I've rt pclltcdly nated both on and off tbC fd I am uJinmuJriQI had wnnen hm1 off cnmmtJ mortified that my actions have inadvertent y o'lli 1d th - -e Fol rg IS ilu lut of Pollard sltller S11tau JocaJ anti·Semites with an opportunity to wr p dYeS • n 1 Oc en1ber 17 IIJI o j fat the flag of respectability and to emerge from IJe la tbe r -·Petershurg VJ · rocks I can only hope that 'with the evcntuall li ail of he Do 01r D ngar·Sargon truth wharever perceived damage has been donc to lh stan dang t _ day uuter baltlemenu of Zion Althougb this cumm1tmcnt American Jcwi community and Israel w1ll be rc paucd Ju t I Mt't tell you how mu h I tpprecwtc d rerdvir g your letter usually m11nifesu itself through such conventional mechanisms please acc ept my word that the gain tu lsra l's long tc rm nf 'up pori Att r havinl bec n hdd in uch • ulati•Jn for ovo r a as aliya rinancial support to and political lobbying on behalf of security were iudccd worth the riikl and th ll I would nev' r ·ar a no hc Jieving that the mire Jewish o nn1munity had simply hrac lthere may be other highlyunU$ual circumstances in whlcb have jeopardized either my life or my wrfe· health tf I hadn t ' ' ollcn about my ase the i hl or your me sag- produc d a a Jew i for ed lo apply tuational cthi as agui lc to his or her thought the tuation dcmantletl it f' rhap you an bel cr ' 'e o l in lescribabJ joy within me Hopefully God willing action Jn my case this complex and often ilgoni ing intellec· undcrst tnd my position in light of a ltc lu w c pre oton whrch 1111 flo nd l will he ahle tu cxpr s our int'Ch' rulitude to yuu tual pr• t ss was somewhat implified by the re tlization Ihal the has long been u Cd ru describe our rnoral c hOJcc when 11 cor nc s ' jl r ··n when and if we arc pcrmillc d to rcLnn ritute our lives trt nt thc ning or Jsrat l woukl unquc lionably improve Amcr· to the bsuc u Jewish $UCviviil c•m·btruul - no alrcrnatJ ·e · • ' 'r In the meantime lhou h ple se rc t Nun d that your icil uategi po ition throughout the Middle E st In other God hvw I wish it hull bc c n utherwise butrt would llavc bcc n Hlrnr ' ''n fur our Wt·flart' h Js ht t n orw •f the few bright ' ' b rad' g01in W uh l in no way be Amcrl 'll· loss- quite an outright hctw al uf my hcrililgc my pcr onal mtc t nt · tnt lll l'h tn urotherwhc 11 rumatil' lite the · •ntr ary I r an also a sure you thlll Ihi perspective was an entire lilluily luM in thcm·cnsclftbt tJulocau tfl had Mmply In 'J'IIc ••trho lactthal I h01v been p ' •th lwuhlcu uYo r hllw 1 h01rc•l hy all the Israelis with whom I h ad 1hc honour to work tilk en the •afc rouh rod du cl lmy cyu ltl wh111 b uJ tone tluno · th-- -hole aft tll has been mi haru llcd h1 huth the hr tch anll Giv u the special relulionl hip between lht two ountries and 'm quito un lh••• you c cn apprcc iale the prec riou narurc m 'llr m r ' l 'IO I am nt·Yt rthl'lt' l'rlllhll•·nlthat what lh•· unparallerl nppclrtunities this cuuntry b s our lo cal of -lratqLIC in lh e f a ' or I lohd h'' ·'r' 11l·a va j u wils m ICth' PI'l·t wrll make a Jt''' hcummunuy hdwcoult J myAmc ncanZrom teventhmk unanllcrparcJtbreat t llhc l ru •s ul ·r alcanmatcu ahlc 1 ' rapidly with u ntuld II CijU 'nCc tin c' 1'1 11•··· '' mlr · '' Gmtnbullon lo hrud' militur Ciljlilhilitics From f l1•ir'g M m thing h trmfultc•wanb 1hc United StillCli7 '' l '• l' 'lllh' •f this results i n the avmgof Jewis live10 eithl r ll t in M id this it i indeed unfortunate tb- t due to all the tCOCIIInlleGIIIII'aa- 6 r-- cJ l 1 I '' ntenr p ova c led lsr « 'l's ituation 1h Mrd k E o t u II r ' I II - fi Economic package 'to h i nPil tor1 v' - ' ' •·· t ' t· Jl • ·- - f '• ·f • · I j · · '· Levy sees 'consn1 r 1 r''' ll jl j • I p0 uard'S '•JU d lCla • 1cruel 1 lXIOll • ' tl uau mafrucarqcOucl ace tn aties • confidencc buildmg ·understandLngi ana great powe_r llSSura ces of cimdy illppor1 Jlace publici ' While it ts true thai notwathslilllda g When 1 comcJ n to the ware and be uon dice war are rolled a Ludendorff s mJ we stund ulm1c- illld any_one who he les to the contnry · e ehcr unaccountabl_y or ant of h tory ur cron tnally n uvc rhus w M n rci ll· that a whole new gl nerauon of uhu-soph ticated military c qu1pmcnt quietly being inuoduccll tnto he arlioenal of our most implacc bk enemao s without l rael ing re ar cd by her ostensively loy l alhcs lt was t_llY fea thatthe cond1taons were bcmg laad for 11 IP#ecbnologacal Peart Harbor of sucb i that the_ Yom Kippur l k pale In COmp4ilriiK n • an partJCillar able to oommenre hostilities at a moments I really didn't know wbcther observmg a short-fused lime or metbin more manageAll I could y for ccrt Un _ was that time of whatever duration ultimately transla ed oul In ter11_1s ut IHaeli lives and acted I accordmgly When my wife Anne • and 1 vililtcd the Golan Heights 1n the summer of 1985 it was with a senK of guarded optimi$m that we looked acros s thatforbadding es carpment at he distant Syrian positions and realw d that ' VC had at lc ut auempted however •mpertectly k uarantee ucunty of thotie exposed fron i Cttlements behind Ui How the can tum around and t at thi behaviour $ugg mantfestat on of an undcrlymg amoral mc ntahty on our part is extremely dtfficult for me to understand But then again m0$t of this case has been nothing ihort of a Kafkae uc nigbtmuc for u Regrettably the issue of money has served to obscure my true moti _es i' t is af aiJ hH h until Mr Blitzer s ntervaew tn Tlat J rusoltm Post 1 had llOt been abk to articu- money did play a Crl ul 10 io operational a pet 1S uf my unucrcak- ing thi i nut to lid ' th ul simply oohl my soul to Mammon A' ynu u undouhtedly awilrc aff nrs such a' the ncce rily rc'luirc ilj r tl c Jc 01 1 of logistic support which i a fact nl life not e x1ctly sell-evident tu tlw average person on the strc t Moreover given the nrtber j41llctJ expectations of a society long grown accustomed to one dimensional vel· lains it as been far _easier for th prose ullon to attnbute lilmplc pecumary mocives to a ewi h PY ather than complex ideological ones hose significance lies well beyond l pathc tl al y limiled poWt f o comprehens-ion In spite of having d evidence which explains this artieularly vexing aspect of the the Justice Department can't em able to appreciate the fact tbal attempted to repay my Israeli control without success- which is hardly the behaviour of a cold blooded mercenary The prosecution is c Jc termined thouJh to overlook this a5pCCl of my behaviur and pound way at my alleged moral conill4ltion Oosely Jdated to this line uf dlaracter asa auination has been the cqLta11y channina piece of outright diwnformation concerning my reported mental instability which hit S been conveniently discovered by a prosecution trying desperately to discredit me Efforts by my defcnK attorney to gain ac to thc e records have been reportedly denied and now we've been told that many iUC 1ni5l ing Well perhaps with iime and access to tbe Juers the attitude or should I say malleability of the press will change with regard to my personal integrity In the interim though I almost feel like one of the Refuseniks wllo after being told that he llWil be insane for wanting to c4 vc the iit paradilic j promptly thrown into tn ylum tnd urj uth n about When n rtain ju•- 11ce officiilb uld me thatth« y would rn •kc it impmsihle fm any Amaican J w lu 'I'ICill ••ut in m · Jckns I IIC 'cr r ahzcll th 1t till· '·crc walhnl t•• h u k up tlu t hr_eat h aim a 1'·11 0 lrllm tho K til f UUI I shuuld h VC l nown hcl l r · theso w rc the sotnh • lfic 1aL' who nlildt UfC my Wile and I pll aUt O 0111 ' li1y hdon a lluu c vole wa sdle · dul d lu dt 1d whcth•·r or not lu tppruvc a Saudi arms package In many respe ts nowever Anne li ord nl has been far w rse than m ne swce her severe phys cal prnhlems wc re greatly complicated by lh dcmal Of propo r medt J attenuon whtlc she '-'as bemg held at lhe District of Columbia Jail - an institutional mahgnanC that could be unfavourably compared to such notorious prisons as Lu yanka _and Dartrnoor You would never behevc a detention facility like Utis actually exists in the United States unless you'd experienced i first band rats snakes swarm of msects no heat nu light no bl nkets or sheets ince lillnt no se totlets that nc ver work the constant prese-nce of sewer gas unpotabl water piithologi_' al guuds untreated AIDs earners handlin food lrays and an inmate populataon that rcfle ts the most degenerate group of sub uman tnd - v1dLtal' ever collected under me roof It is quite lit erally a level_ of hell that could have fagured prommantly in Dante's ln trllo After t r e months of etng ubmcrged wtthJO thas net rollc envaronment watho_ut even bemg tble to breathe fr h au or see the light of day or recerve her m dic tions u till startc -d · peraung my wafc was con tbon lly rel ased due to her rap_ dly dc teraoraung health Durang th1s period uf time Anne aud I were not all wed to even s ee each other whtcb for a couple as clo e as we are Uo lllllll ' IIIII ol ot lUh' •nly lltl news which I wa p rmitt t l to hear about her w•• that 1 1 • •mafi Brotherhood had 1nstruc11 u their fl male counterparts to kill her if the uppcmunity presentc l l itself Apart from our cunlinued W parauon which hilS hcc1l cKcruciiltlllj hie fur Anne h 1 hl ctt pretty hard f ivcn her recurrent mcdical pmhl m the uno crt intv of our futun and the horrendous allcgatitm about our life style wh1ch have cvilkntly been l igncd to destroy what rcntain t of our rcpulations Nec dle s to say we are both extremely tire right now and are trying as best we can to prepare ourselves for 11 Kntencing sc ion which might result in our destruction as a couple l can't even begin to adequately dc cribc what kind of emotional pressures are produced by thi painfully slow process of juridical crucifixion ln A nse Anne and I feel as if we're aboard one of those cattle CAT$ pulling up to the separation platform at Auschwitz while all about us the Jewish community jus t sits like mute spec tatolli awaiting the fall of the axe Perhaps you can now understand how important the receipt of your letter was to us - it represc nteO the firu oven sig11 that somebody cares AssuP'i the court is merciful W mayyl Hive to reildl Israel but the present time the prosecution is demanding our heads as an object lesson for others who might be similarly inclined to help Israel We fully expc a the wont because no one has summoned tbe community to put a stop to this ordeal bt the prelioenc e of such limidity tho le Jusuce officials who view thts case as an opportunity to put lst11cl in her place by equating my actions with those of a Soviet spy will carry the day Anne tnd I pray to God that somewhere a penon will do for us what we tried to do for our people- give them life I L Ll •• · _ at '¥ o- o-o D Ql C» c - OCt •• 1'1'1 c · Ql o eca co t c n c nn' ' _ 3 0 a -·-· Ql ' -e g o_ -c llo 0 P cr g Eo Sincerely Jonathan Pollard z c u g I ' Coot i» tn tn ·-·· r- • r r '· · ' 1 ' f a'r ' f ' ' •i d' 1 - _ · I· I• I' l • · ' ' ·· t'· •t i •• 1· J • -- r i · ·· a f· -a j·· ' II r j 1 1 1 w 1 • · di i ·t 1 ' iL ' ' • ' • '· •· ' • • •• ' F • •• ·' J '• •• ' ' Ci' n h h ·i j ' ' 1·'•'' •t•lll 1 i tH I ' ' i ' f i • • 't ca I' f r ·i l•l '· ined to be Unclassi ed erm Page det Uij -J D091 Pollardi A Bumbler But Israels Master Spy By Wei 85W telliueace analyst lumen Jay Pollard min or lmel one Ignition hp mauled alum every- one about mm with '1 much almdy eluted What ewld Pollard have M ROM THE FIRST revelation that US Navy in- yur mintenbwinidmudU a hne olfk curityeitheSuudI-rad can-vacuum sounlmdiand mm- The Pobhrdase The'ntelligence WWI-flaw I I I meenmmw - areas lune I etc has been a particuhdy dramatic naming a with m pun wm db piiuhl oi when in rem Since they bum by 1 01mm in the United Slates Io Emilie- 0 ms PM w-W Section 3 5 2 6 2012 00 Reviewed Chief RDD WHS IAW E0 13526 Date 3 peodem Children they are at market if they are under a reason that the mni 1131919 hasheendn er amend Mmiu u imlnid II Mather the fact the Ram cuts um - including detailed mew pinata Ind mu slam - Mediumstruckuthe urhiugpuoruthez mathem arepow mm mde ciIhvhomm byml- - roupinwhich mien ueanabrmponm 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filltt t Ia Ft tl fl a fltll 1 n h ' fU I 4 u s -- r 'Jfl ' flll i' - r 11 1111 J'lll iJ if fa i lfii a II rr lr fi JJ _· •· -1 r u-•tlt t i - • 1 •a a •itJ r t· u ll l1 1 i•t tllfit fli MiHl J·JI i tfl · trrt i11ti a I1 1 1i illifli 1JtJJ tffll fllft t lilfflrl if Jft ll llif l iliiilt fJ-lifaf Jt r ·· rltl• l mlif nJIJi i UtHh ii i UU Jl r'fl I f J r I ll_ ll g J l f if r• t tw•lt jjJj IJ '· v a rfr rl tl a lfl fJ l l i 'fi''il IS' cJ a 1 11§ ' p-if ' - li 1 • li 'i'a li- - 4 td tffflsl •'t 1 IiflilJI J f lf s-'llll ttf r ll 1 • tt tl Ill• 1 lL• o - 1 1 1 i 3 llf f a f th tltli ·1IU 111·ifl 1bttJ iJ l tlll rl a •lt •ritl f' l 'II I'• '•It'll 1 1 -' 1 ttlilllrt il1i trll I·• ljr ltaiJ E•ll11 Jliitl11 rJI 1 tJ 1 1 fjljiiii·J·tle llr lll lllt rrl fta rJ 1 111rriJ li9 l 1 I I i s'I ' - fla l l t·r I t l tlf itfl fit r tllitl ·1if f l t l · J sjiJrJJii ri i iJfi a la ltllt flf ·r tile k o • ' --- - - 1 Page determined to be Unclassi1ied Reviewed Chief RDD WKS lAW EO 13528 Sactlon 3 1 Date OC1' 2 6 2012 aq1 Sf 'fJ911 SC o Lb'V c n A lOJ • 186 ' i UII' DECLASSIFIED IN FULL Authority EO 13526 ATTACHMENT B Chief Records Declass Dlv WHS Date oCT 2 6 Wl MEMORANDUM OF UNDERSTANDING 1 Having familia izec myself w h applicable espionage laws I understand that I may be the recipient of information and documents that concern the present and future security of the United States and belong o the United States and that such infor mation and documents tocrether w h the methods of collecting national securi y informatio are classi ied according to security standards set by he United States Government 2 I agree that I shall never divulge publish or reveal either by word conduct or any other means such classified information or documents unless specifically authorized in writing to do so by an authorized representative of the U S Government as required by CIPA as otherwise ordered by the Cour or as provided for in the Protective Order entered in this case United States v Jonathan J Pollard Criminal No 86-0207 United States District Court for the District of Columbia 3 I understand that this agreement will remain binding upon me after the conclusion of these proceedings 4 I have received read and understand the Protective Order entered by the United States Dis rict Court for the District of Columbia on JJ IJovew lt 1986 in the aforesaid case rela ing to classified information and I agree to comply with the provisions thereof Date Sworn to and subscribed before me h4 c t J Parole d---tt-- 0 Oftice Authorized by the t ct d July 7 1955 to admir is r r oaths 18 U S C 4004 •a-I I IIIIJI_ II II II S - - -