F. July 2007 OLC Memorandum Relics on Inaccurate CIA Representations Regarding CIA Interrogations and the Effectiveness of the CIA's Enhanced Interrogation Techniques; CIA Misrepresents Congressional Views to the Department of Justice

¶On July 20, 2007, the OLC issued a memorandum applying the War Crimes Act, the Detainee Treatment Act, and Common Article 3 of the Geneva Conventions to the CIA's enhanced interrogation techniques. The memorandum noted that, while the Hamdan decision "was contrary to the President's prior determination that Common Article 3 does not apply to an armed conflict across national boundaries with an international terrorist organization such as al Qaeda," this challenge to the CIA program was resolved by the Military Commissions Act, which "left responsibility for interpreting the meaning and application of Common Article 3, except for the grave breaches defined in the amended War Crimes Act, to the President."²⁴¹⁸²⁴¹⁸ Memorandum for John A. Rizzo, Acting General Counsel, Central Intelligence Agency, from Steven G. Bradbury, Principal Deputy Assistant Attorney General, Office of Legal Counsel, July 20, 2007, Re: Application of the War Crimes Act, the Detainee Treatment Act, and Common Article 3 of the Geneva Conventions to Certain Techniques that May Be Used by the CIA in die Interrogation of High Value al Qaeda Detainees (DTS #2009-1810, Tab 14).Show full note

¶The OLC memorandum determined that six proposed interrogation techniques were legal: dietary manipulation, extended sleep deprivation, the facial hold, the attention grasp, the abdominal slap, and the insult (or facial) slap. The memorandum accepted the CIA's representation that, over the life of the program, the CIA had detained 98 individuals, of whom 30 had been subjected to the CIA's enhanced interrogation techniques.²⁴¹⁹²⁴¹⁹ Memorandum for John A. Rizzo, Acting General Counsel, Central Intelligence Agency, from Steven G. Bradbury, Principal Deputy Assistant Attorney General, Office of Legal Counsel, July 20, 2007, Re: Application of the War Crimes Act, the Detainee Treatment Act, and Common Article 3 of the Geneva Conventions to Certain Techniques that May be Used by the CIA in the Interrogation of High Value Al Qaeda Detainees (DTS #2009-1810, Tab 14).Show full note At the time of the OLC memorandum the CIA had detained at least 119 individuals, of whom at least 38 had been subjected to the CIA's enhanced interrogation techniques.²⁴²⁰²⁴²⁰ Although all 119 known CIA detainees had entered CIA custody by July 20, 2007, Muhammad Raliim, the last detainee, had not yet been subjected to the CLA's enhanced interrogation techniques by the time of the OLC memorandum. Muhammad Raliim was rendered to CIA custody on July [Redacted] 2007. (See [Redacted] 6439 ( [Redacted] [Redacted] 7516 ( [Redacted] ) Interrogators began using the CIA's enhanced interrogation techniques on Rahim on July 21, 2007; the day after die OLC Memorandum was issued. See [Redacted] 2467 (211341Z JUL 07).Show full note The inaccurate statistics provided by the CIA to the OLC were used to support OLC's conclusion that the program was "proportionate to the government interest involved," as required by the "shocks the conscience" test. The OLC also noted that "careful screening procedures are in place to ensure that enhanced techniques will be used only in the interrogations of agents or members of al Qaeda or its affiliates who are reasonably believed to possess critical intelligence that can be used to prevent future terrorist attacks against the United States and its interests."²⁴²¹²⁴²¹ Memorandum for John A. Rizzo, Acting General Counsel, Central Intelligence Agency, from Steven G. Bradbury, Principal Deputy Assistant Attorney General, Office of Legal Counsel, July 20, 2007, Re: Application of the War Crimes Act, the Detainee Treatment Act, and Common Article 3 of the Geneva Conventions to Certain Techniques that May be Used by the CIA in the Interrogation of High Value Al Qaeda Detainees (DTS #2009-1810, Tab 14). ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ 11 ii 11111 [Redacted] i II i HIShow full note In practice, numerous individuals had been detained by the CIA and subjected to the CIA's enhanced intenogation techniques, despite doubts and questions surrounding their knowledge of terrorist threats and the location of senior al-Qa'ida leadership. Examples include, among others: Asadullah,²⁴²²²⁴²² Interrogators had asked CIA Headquarters for the assessments supporting the decision to subject Asadullah to the CIA's enhanced interrogation techniques, noting that "it would be of enormous help to the interrogator to know wh at i ^ o n o j e t e f o c t a n d w h a t i s good analysis." (See [Redacted] 33963 [Redacted] also [Redacted] 34098 [Redacted] [Redacted] [Redacted] In response, ALEC Station acknowledged that "[t]o be sure, our case that Asadullah should have a good sense of bin Ladin's location is circumstantial." (See A L E [Redacted] [Redacted] [Redacted] The following day, interrogators commented that "it may be that he simply does not know the [locational information on AQ leaders]." See [Redacted] [Redacted] 343101 ^ ^ ^ ^ ^Show full note Mustafa al-Hawsawi,²⁴²³²⁴²³ Following al-Hawsawi's first interrogation session, Chief of Interrogations [Redacted] asked CIA Headquarters for information on what al-Hawsawi actually "knows," saying: "he does not appear to the [sic] be a person that is a financial mastermind. However, we lack facts with which to confront [al-Hawsawi], What we need at this point is substantive information vice supposition." See ^ ^ ^ H i ^ ^ l ^ H I [Redacted] 34757 (101742Z MAR 03).Show full note Abu Hudhaifa,²⁴²⁴²⁴²⁴ Although CIA records include no requests or approval cables, Abu Hudhaifa was subjected to ice water baths and 66 hours of standing sleep deprivation. He was released because the CIA discovered he was likely not the person he was believed to be. See WASHINGTON DC [Redacted] [Redacted] [Redacted] [Redacted] 513031 [Redacted] Arsala Khan,²⁴²⁵²⁴²⁵ CIA Headquarters initially resisted approving Arsala Khan's capture because of a lack of information confirming that he was a "continuing tiireat." (See [Redacted] 169986 [Redacted] email from: [Redacted] to: [Redacted] [Redacted] and Approval to Capture i il 11 Inn III [Redacted] 111 I"1' Iiim|11 that Arsala Khan was the individual sought by the CIA, interrogators subjected him to the CIA's enhanced interrogation techniques "to make a better assessment regarding [his] willingness to start talking, or assess if our subject is, in fact the man we are looking for." See [Redacted] 1373 [Redacted]Show full note ABU TALHA AL-MAGREBI and ABU BAHAR AL-TURKI,²⁴²⁶²⁴²⁶ The true names of diese detainees have been replaced with the capitalized pseudonyms AL-MAGREBI and AL- TURKI. At the time the two detainees were rendered to CIA custody, the CIA was aware that they were then working for a foreign partner government. (See ALEC [Redacted] [REDACTED]; [REDACTED] 43773 [REDACTED].) They were subjected to sleep deprivation and dietary manipulation until the CIA confirmed that the detainees had been trying to contact the CIA for weeks to inform the CIA of what they believed were pending al- Qa'ida terrorist attacks. (See [Redacted] 2227 [REDACTED]; [Redacted] 2233 [REDACTED]; [Redacted] HEADQUARTERS[Redacted]^DACrF.D]; 12232 [Redacted] [REDACTED].) After the CIA had determined that AL-MAGREBI and AL- TURKI should not be in CIA custody, the two detainees were held for [Redacted] additional months before they were released. See [REDACTED] 2025 [REDACTED].Show full note Janat Gul,²⁴²⁷²⁴²⁷ The case of Janat Gul is described above in the context of OLC advice in 2004 and afterwards. As Gul's interrogators noted, "Team does not believe [Gul] is withholding imminent threat information, however team will continue to press [Gul] for that during each session." See [Redacted] ' ^74 ( [Redacted] 04).Ahmed Ghailani,²⁴²⁸²⁴²⁸ The CIA's assessment of Ghailani's knowledge of terrorist threats was speculative. As one official noted, "[ajlthough Ghailani's role in operational planning is unclear, his respected role in al-Qa'ida and presence in Shkai as recently as October 2003 may have provided him some knowledge about ongoing attack planning against the United States homeland^ndtheoperatives involved." See email from: [Redacted] CTC/UBLD [Redacted] (formerly A L E [Redacted] to: [REDACTED], [REDACTED], [REDACTED], [REDACTED]; subject: derog information for ODDO on Talha, Ghailani, Hamza Rabi'a and Abu Faraj; date: August 10, 2004.Show full note Sharif al-Masri,²⁴²⁹²⁴²⁹ As noted above, the credibility of the source implicating Sharif al-Masri, Janat Gul, and Ghailani's connections to a pre-election plot was questioned by CIA officials prior to the application of the CIA's enhanced interrogation techniques against them. The source was later determined to have fabricated the information. and Sayyid Ibrahim.²⁴³⁰²⁴³⁰ Five days after interrogators began using enhanced interrogation techniques against Sayyid Ibrahim, interrogators cabled CIA Headquarters requesting information that would "definitively link [Ibrahim] to nefarious [Redacted]

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¶T h e July 20, 2007, OLC memorandum also stated that the CIA's enhanced interrogation techniques "are not the first option for CIA interrogators confronted even with a high value detainee."²⁴³¹²⁴³¹ The OLC further stated that "enhanced techniques would be used only as less harsh techniques fail or as interrogators ran out of time in the face of an imminent threat, so that it would be unlikely that a detainee would be subjected to more duress than is reasonably necessary to elicit the information sought." See Memorandum for John A. Rizzo, Acting General Counsel, Central Intelligence Agency, from Steven G. Bradbury, Principal Deputy Assistant Attorney General, Office of Legal Counsel, July 20,2007, Re: Application of the War Crimes Act, the Detainee Treatment Act, and Common Article 3 of the Geneva Conventions to Certain Techniques that May be Used by the CIA in the Interrogation of High Value Al Qaeda Detainees (DTS #2009-1810, Tab 14).Show full note As described in this summary, numerous CIA detainees were subjected to the CIA's enhanced or "standard" interrogation techniques on their first day of CIA custody,²⁴³²²⁴³² See Volume 111 for additional details. while other detainees provided significant information prior to the use of the CIA's enhanced interrogation techniques. The OLC memorandum also accepted the CIA representation that "[t]he CIA generally does not ask questions during the administration of the techniques to which the CIA does not already know the answers," that the CIA "asks for already known information" during the administration of the CIA's enhanced interrogation techniques, and that when CIA personnel believe a detainee will cooperate, "the CIA would discontinue use of the techniques and debrief the detainee regarding matters on which the CIA is not definitely informed." As the memorandum concluded, "[t]his approach highlights the intended psychological effects of the techniques and reduces the ability of the detainee to provide false information solely as a means to discontinue their application."²⁴³³²⁴³³ Memorandum for John A. Rizzo, Acting General Counsel, Central Intelligence Agency, from Steven G. Bradbury, Principal Deputy Assistant Attorney General, Office of Legal Counsel, July 20, 2007, Re: Application of the War Crimes Act, the Detainee Treatment Act, and Common Article 3 of the Geneva Conventions to Certain Techniques that May be Used by the CIA in the Interrogation of High Value Al Qaeda Detainees (DTS #2009-1810, Tab 14).Show full note This description of the program was inaccurate. As described in this summary, and in more detail in the full Committee Study, CIA interrogators always questioned detainees during the application of the CIA's enhanced interrogation techniques seeking new information to which the CIA did not have answers, and numerous detainees fabricated information while being subjected to the interrogation techniques.

¶The July 20, 2007, OLC memorandum repeated CIA representations that "many, if not all, of those 30 detainees" who had been subjected to CIA's enhanced interrogation techniques received counterinterrogation training, and that "al Qaeda operatives believe that they are morally permitted to reveal information once they have reached a certain limit of discomfort."²⁴³⁴²⁴³⁴ Memorandum for John A. Rizzo, Acting General Counsel, Central Intelligence Agency, from Steven G. Bradbury, Principal Deputy Assistant Attorney General, Office of Legal Counsel, July 20, 2007, Re: Application of the War Crimes Act, the Detainee Treatment Act, and Common Article 3 of die Geneva Conventions to Certain 11ii 1111 i [Redacted] m m Bradbury, Principal Deputy Assistant Attorney General, Office of Legal Counsel, July 20, 2007, Re: Application of the War Crimes Act, the Detainee Treatment Act, and Common Article 3 of the Geneva Conventions to Certain Techniques that May be Used by the CIA in the Interrogation of High Value Al Qaeda Detainees (DTS #2009-1810, Tab 14).Show full note Neither of these representations is supported by CIA records.

or knowledge by [Ibrahim] of known nefarious activities of al-Qa'ida members, if this is possible." (See [Redacted]EB [Redacted] 11324 04).) Without recei ving a response, they continued to subject Ibrahim to the

¶CIA's enhanced interrogation techniques. CIA Headquarters, which rejected an assessment from two debriefers that Ibrahim was, "at best... a low-level facilitator," would later indicate that it was "uncertain" he would meet the requirements for U.S. military or [Redacted] detention. See HEADQUARTERS [Redacted] [Redacted] HEADQUARTERS [Redacted] [Redacted] .

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¶The memorandum also repeated CIA representations that interrogators were "highly trained in carrying out the techniques," and "psychologically screened to minimize the risk that an interrogator might misuse any technique." These presumptions were central to the OLC's determination that the limitations on interrogations contained in the Army Field Manual were not "dispositive evidence" that the CIA's interrogation program fell outside "traditional executive behavior and contemporary practice," an analysis required as part of the substantive due process inquiry. Specifically, the OLC distinguished U.S. military interrogations from the CIA program by stating that the CIA program "will be administered only by trained and experienced interrogators who in turn will apply the techniques only to a subset of high value detainees."2435 As described in this summary, and in greater detail in the full Committee Study, the CIA's representations to the OLC were incongruent with the history of the CIA's Detention and Interrogation Program with regard to the training, screening, and experience of interrogators, and the detainees against whom the CIA used its enhanced interrogation techniques.

¶The July 2007 OLC memorandum based its legal analysis related to the six interrogation techniques under consideration on CIA representations that were incongruent with the operational history of the program. In reviewing whether standing sleep deprivation was consistent with the War Crimes Act, the OLC noted that its understanding that the technique would be discontinued "should any hallucinations or significant declines in cognitive functioning be observed" was "crucial to our analysis." The memorandum repeated CIA representations that diapers employed during standing sleep deprivation "are used solely for sanitary and health reasons and not to humiliate the detainee," and that, more generally, "[t]he techniques are not intended to humiliate or to degrade."²⁴³⁶²⁴³⁶ Memorandum for John A. Rizzo, Acting General Counsel, Central Intelligence Agency, from Steven G. Bradbury, Principal Deputy Assistant Attorney General, Office of Legal Counsel, July 20, 2007, Re: Application of the War Crimes Act, die Detainee Treatment Act, and Common Article 3 of the Geneva Conventions to Certain Techniques that May be Used by the CIA in the Interrogation of High Value Al Qaeda Detainees (DTS #2009-1810, Tab 14). ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^Show full note The OLC's understanding, which, as described, was not consistent with the operational history of the CIA program, was part of its analysis related to the prohibition on "outrages upon personal dignity" under Common Article 3.

¶A s i n the May 30, 2005 OLC memorandum, the July 20, 2007, OLC memorandum conducted an analysis of the "shocks the conscience" test under the Fifth Amendment of the U.S. Constitution, emphasizing the fact-specific nature of the analysis. Citing both the CIA's March 2005 "Effectiveness Memo" and the president's September 6, 2006, speech describing the interrogation program, the July 2007 OLC memorandum repeated the CIA assertion that the CIA's enhanced interrogation techniques produced "otherwise unavailable intelligence." It also repeated CIA representations related to KSM's reporting on the "Second Wave" plotting and Abu Zubaydah's reporting on Jose Padilla, both of which were inaccurate.²⁴³⁷²⁴³⁷ Memorandum for John A. Rizzo, Acting General Counsel, Central Intelligence Agency, from Steven G. Bradbury, Principal Deputy Assistant Attorney General, Office of Legal Counsel, July 20, 2007, Re: Application of the War Crimes Act, the Detainee Treatment Act, and Common Article 3 of die Geneva Conventions to Certain Techniques that May be Used by the CIA in the Interrogation of High Value Al Qaeda Detainees (DTS #2009-1810, Tab 14).Show full note The OLC memorandum also stated that the use of the CIA's enhanced interrogation techniques had "revealed plots to blow up the Brooklyn Bridge and to release mass biological agents in our Nation's largest cities."²⁴³⁸²⁴³⁸ •pj1js js a r e f e r e n c e to the CIA's representation that KSM, "as a result of EITs," provided critical and unique reporting on Iyman Faris and Majid Khan. As described briefly in this summary, and in greater detail in the full Committee Study, Iyman Faris was already under investigation, and Majid Khan was already in custody, before KSM mentioned them. Khan himself revealed a discussion about poisoning reservoirs prior to his rendition to CIA custody. (See ALEC [Redacted] (210015Z MAR 03).) When Faris, who was likewise not in CIA custody, discussed a plot against the Brooklyn Bridge, the former chief of CTC's Bin Ladin Unit described it as "half-baked," and "more to: of a nuisnance [sic] than a threat." See W H D C [Redacted] 2 4 2 2 2 6 Z MAR 03) and email [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [REDACTED]; attacks in conus; date: March 25, 2003, at 6:19:18 AM). '' Memorandum for John A. Rizzo, Acting General Counsel, Central Intelligence Agency, from Steven G. Bradbury, Principal Deputy Assistant Attorney General, Office of Legal Counsel, July 20, 2007, Re: Application of the War Crimes Act, the Detainee Treatment Act, and Common Article 3 of the Geneva Conventions to Certain Techniques that May be Used by the CIA in the Interrogation of High Value Al Qaeda Detainees (DTS #2009-1810, Tab 14).Show full note

¶Techniques that May be Used by the CIA in the Interrogation of High Value Al Qaeda Detainees (DTS #2009-1810, Tab 14). 2433

¶Memorandum for John A. Rizzo, Acting General Counsel, Central Intelligence Agency, from Steven G. Finally, the July 20, 2007, OLC memorandum asserted—based on CIA representations—that members of Congress supported the CIA interrogation program, and that, by subsequently voting for the Military Commissions Act, those members effectively endorsed an interpretation of the Act that would be consistent with the continued use of the CIA's enhanced interrogation techniques. This interpretation of congressional intent also supported the OLC's constitutional analysis, which stated that there could be "little doubt" that the Act "reflected an endorsement" from Congress that the CIA program "was consistent with contemporary practice, and therefore did not shock the conscience."2439 Specifically, the OLC memorandum noted that according to CIA representations, prior to the passage of the Military Commissions Act, "several Members of Congress, including the full memberships of the House and Senate Intelligence Committees and Senator McCain, were briefed by General Michael Hayden, director of the CIA, on the six techniques," and that "in those classified and private conversations, none of the Members expressed the view that the CIA interrogation program should be stopped, or that the techniques at issue were inappropriate."²⁴⁴⁰²⁴⁴⁰ Memorandum for John A. Rizzo, Acting General Counsel, Central Intelligence Agency, from Steven G. Bradbury, Principal Deputy Assistant Attorney General, Office of Legal Counsel, July 20, 2007, Re: Application of the War Crimes Act, the Detainee Treatment Act, and Common Article 3 of the Geneva Conventions to Certain Techniques that May be Used by the CIA in the Interrogation of High Value Al Qaeda Detainees (DTS #2009-1810, Tab 14).Show full note This representation was inaccurate. For example, according to CIA records, during a briefing on September 11, 2006, Senator John McCain informed the CIA that he believed the CIA's enhanced interrogation techniques, including sleep deprivation and the waterboard, were "torture."²⁴⁴¹²⁴⁴¹ Email from: [Redacted] [Redacted] cc: [Redacted] [REDACTED], [REDACTED], [REDACTED], [REDACTED ] ! [Redacted] D A C T E D ] , [REDACTED], [REDACTED], [REDACTED], [REDACTED], [REDACTED], [REDACTED]; subject: Briefing for Senator John S. McCain (R-AZ); date: September 11, 2006, at 5:51 PM ("[Senator McCain] asked if I thought 'sleep deprivation' was torture. I responded that I did not and he then added that he had talked with a Marine Colonel friend of his and the Colonel had indicatedShow full note On September 27, 2006, Senator Dianne Feinstein, a member of the Senate Select Committee on Intelligence, wrote a letter to CIA Director Hayden stating that she was "unable to understand why the CIA needs to maintain this program."²⁴⁴²²⁴⁴² Letter from Senator Dianne Feinstein to Director Hayden, September 27, 2006 (DTS #2006-3717). On September 6, 2006, when the CIA provided its first and only briefing to the full Committee on the CIA program prior to the vote on the Military Commissions Act, Committee staff access was limited to the two Committee staff directors.²⁴⁴³²⁴⁴³ Transcript of hearing of the Senate Select Committee on Intelligence, September 6, 2006 (DTS #2007-1336). In May 2007, shortly after the CIA allowed additional Committee staff to be briefed on the program, other members of the Committee prepared and provided letters to Director Hayden. On May 1, 2007, Senator Russ Feingold wrote that "I cannot support the program on moral, legal or national security grounds."²⁴⁴⁴²⁴⁴⁴ Letter from Senator Russ Feingold to Director Hayden, May 1, 2007 (DTS #2007-1858). On May 11, 2007, Senators Chuck Hagel, Dianne Feinstein, and Ron Wyden wrote a letter expressing their long-standing concerns with the program and their "deep discomfort with the use of EITs."²⁴⁴⁵²⁴⁴⁵ Letter from Senators Chuck Hagel, Di "" ' "" ' 1 , 2 0 0 7 (DTS #2007-2102). it was and he believed his friend."). In another exchange, the officer who briefed Senator McCain was asked about the Senator's position. CIA officer [Redacted] "so, is the senator on board?..." CIA officer [Redacted] "not totally." [Redacted] "if he's moved in our direction at all, you are a miracle worker... was it painful?"

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¶[Redacted] "Very much [Redacted] the issue the EITs still?" [Redacted] "Yep." (See Sametime communication between [Redacted] a n d [Redacted] 11/Sep/06,15:47:27 to 18:43:29.) The OLC specifically cited statements from Senator McCain that the Military Commissions Act "will allow the CIA to continue interrogating prisoners within the boundaries established in the bill." Memorandum for John A. Rizzo, Acting General Counsel, Central Intelligence Agency, from Steven G. Bradbury, Principal Deputy Assistant Attorney General, Office of Legal Counsel, July 20, 2007, Re: Application of the War Crimes Act, the Detainee Treatment Act, and Common Article 3 of the Geneva Conventions to Certain Techniques that May be Used by the CIA in the Interrogation of High Value Al Qaeda Detainees (DTS #2009-1810, Tab 14). The OLC did not mention that McCain had specifically objected to the use of sleep deprivation.

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VI. Review of CIA Representations to the Congress

A. After Memorandum of Notification, the CIA Disavows Torture and Assures the Committee Will Be Notified of Every Individual Detained by the CIA

¶Following the September 11, 2001, terrorist attacks and the signing of the September 17, 2001, Memorandum of Notification (MON), the Senate Select Committee on Intelligence ("the Committee") held a series of hearings and briefings on CIA covert actions, including the new authority to detain terrorists. At a November 13, 2001, briefing for Committee staff, [Redacted] Legal, [Redacted] described the CIA's new detention authorities as "terrifying" and expressed the CIA's intent to "find a cadre of people who know how to run prisons, because we don't."²⁴⁴⁶²⁴⁴⁶ Transcript of Senate Select Committee on Intelligence staff briefing, November 13, 2001 (DTS #2002-0629). Deputy Director of Operations (DDO) James Pavitt assured the Committee that it would be informed of each individual who entered CIA custody. Pavitt disavowed the use of torture against detainees while stating that the boundaries on the use of interrogation techniques were uncertain—specifically in the case of having to identify the location of a hidden nuclcar weapon.²⁴⁴⁷²⁴⁴⁷ "We're not going to engage in torture. But, that said, how do I deal with somebody I know may know right now that there is a nuclear weapon somewhere in the United States that is going to be detonated tomorrow, and I've got the guy who I know built it and hid it? I don't know the answer to that." (See transcript of Senate Select Committee on Intelligence MON briefing, November 7, 2001 (DTS #2002-0611); see also transcript of Senate Select Committee on Intelligence staff briefing, December 11, 2001 (DTS #2002-0615).Show full note

¶LI meetings with the CIA in February 2002, the month before the capture and detention of Abu Zubaydah, Committee staff expressed concern about the lack of any legal review of the CIA's new detention authorities. [Redacted] noted that the discussion with Committee staff was "the only peer review" the CIA lawyers had engaged in with regard to the MON authorities, and that the discussion helped refine the CIA's understanding of what MON-authorized activity was in fact legally permissible and appropriate.²⁴⁴⁸²⁴⁴⁸ Email f r a n [Redacted] SSCI Staff; to: [Redacted] Cleared SSCI staff; subject: Meeting yesterday with CIA lawyers on [Redacted] F e b r u a r y 26, 2002 (DTS #2002-0925).