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Valerie Plame

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Valerie Plame (born 1963) is a former American Central Intelligence Agency employee who was identified as a CIA "operative" in a newspaper column by Robert Novak on 14 July 2003. This created a political controversy and eventually led to a Justice Department investigation into possible violation of U.S. criminal law regarding exposure of covert government agents. As of April 2005 the investigation continued without apparent result.

Contents

Known background

Plame's life history has been documented in the January 2004 Vanity Fair article *"Double Exposure." (http://www.jimgilliam.com/2004/01/vanity_fairs_profile_on_joseph_wilson_and_valerie_plame.php) But little is known of Plame's professional career. She has described herself as an energy analyst for the private company Brewster Jennings & Associates, which was subsequently acknowledged by the CIA as a front. It has been reported (http://www.boston.com/business/globe/articles/2003/10/10/apparent_cia_front_didnt_offer_much_cover/) that this cover was not executed very convincingly.

Plame is the wife of former Ambassador Joseph C. Wilson IV. Wilson is her second husband. Plame met him at a Washington party in early 1997. She was able to reveal her CIA role to him while they were dating because he held a high-level security clearance. At the time Wilson was married to, but separated from, his second wife Jacqueline, a former French diplomat. Wilson and Plame are the parents of three-year-old twins.

Exposure of Plame by Novak

Plame was identified as a CIA "operative" in Novak's column, which read in part: "Wilson never worked for the CIA, but his wife, Valerie Plame, is an Agency operative on weapons of mass destruction. Two senior administration officials told me Wilson's wife suggested sending him to Niger to investigate" the allegation.[1] (http://www.townhall.com/columnists/robertnovak/printrn20030714.shtml)

According to Novak, administration sources claimed that it had been at Plame's suggestion that the CIA sent her husband to Niger in 2002 to investigate the Yellowcake Forgery, documents implying that Iraq had attempted to illegally purchase uranium from that country. This appeared to contradict Wilson's claim that he was sent to Niger at the request of Vice President Cheney. Cheney has denied any knowledge of Wilson's Niger visit.

Wilson charged that his wife's CIA association had been deliberately exposed by the White House in order to destroy her career, in retaliation for his public charge that the Bush administration had lied to the American people about U.S. intelligence concerning weapons of mass destruction in Iraq. In an article in The New York Times on 6 July 2003, Wilson denounced the Bush administration, saying that "some of the intelligence related to Iraq's nuclear program was twisted to exaggerate the Iraqi threat."

Possible illegality of exposure

Under certain circumstances, the exposure of a covert government agent would violate the Intelligence Identities Protection Act, carrying a maximum sentence of 10 years. The act applies itself to a person who "learns the identity of a covert agent and intentionally discloses any information identifying such covert agent to any individual not authorized to receive classified information, knowing that the information disclosed so identifies such covert agent and that the United States is taking affirmative measures to conceal such covert agent's intelligence relationship to the United States." [2] (http://caselaw.lp.findlaw.com/casecode/uscodes/50/chapters/15/subchapters/iv/sections/section_421.html) The Novak column did describe Plame as an "operative", but did not use the description "covert". Novak has claimed that the CIA made "a very weak request" that he not name Plame publicly. WSJ.com columnist James Taranto suggests that this would indicate the absence of "affirmative measures to conceal" necessary for a violation of the law. [3] (http://www.opinionjournal.com/best/?id=110005343) The CIA has disputed Novak's claim and indicated that he was told revealing the information could cost agents their lives.

Justice Department Investigation

The matter is currently under investigation by the Justice Department and the FBI. Attorney General John Ashcroft recused himself from the investigation in December 2003. U.S. Attorney Patrick Fitzgerald currently heads the investigation. Because the Justice Department is a part of the executive branch, some critics of the Bush administration contend that the absence of rapid and effective action has been deliberate.

In March 2004, the independent counsel subpoenaed the telephone records from Air Force One.

On April 7, 2005 the Washington Post reported [4] (http://www.washingtonpost.com/wp-dyn/articles/A32380-2005Apr6.html) that unnamed sources indicated Fitzgerald was not likely to seek an indictment for the alleged crime of knowingly exposing a covert officer (which prompted the inquiry), although he may possibly charge a government official with perjury for giving conflicting information to prosecutors during the investigation.

Immediate Internet reaction

David Corn had predicted (http://www.thenation.com/capitalgames/index.mhtml?bid=3&pid=888) that the investigation would die in the CIA -- that George J. Tenet would protect the Bush White House through his purported loyalty to it. Anonymous political weblog Just One Minute (http://justoneminute.typepad.com/) (JOM) writes (http://justoneminute.typepad.com/main/2003/09/valerie_plame_w_2.html): "Evidently not. One guess - Mr. Tenet, pondering Bush's declining poll numbers and faced with in-house annoyance, decided to do the right thing. One presumes that, with Congress back in town, Mr. Tenet checked with his supporters on both sides of the aisle before proceeding." Both Mark Kleiman (http://www.msnbc.com/news/937524.asp?0cv=CB10&cp1=1) and Josh Marshall (http://talkingpointsmemo.com/sept0304.html#0926031103pm) have made recent comments on the matter, according to JOM.

Novak's response

Novak's initial column identified Plame as "an Agency operative on weapons of mass destruction." He has since stated that he believed Plame was merely an analyst at the CIA, not a covert operative—the difference being that analysts are not undercover, so identifying them is not a crime. Critics contend that after decades as a Washington reporter Novak was well aware of the difference and would be unlikely to make such a mistake. Novak has also claimed that Plame's CIA employment was an open secret in Washington, indicating that effective "affirmative measures" to conceal her relationship to the CIA were not being taken. Several ex-CIA operatives who knew Plame have disputed this and indicated that she was at one time a NOC (nonofficial cover) covert operative.

In his October 1, 2003 article "The CIA Leak" (http://www.townhall.com/columnists/robertnovak/rn20031001.shtml) Novak states this explanation for the two "senior administration officials" and the "CIA official" referenced in his June 14 article:

"During a long conversation with a senior administration official, I asked why Wilson was assigned the mission to Niger. He said Wilson had been sent by the CIA's counterproliferation section at the suggestion of one of its employees, his wife. It was an offhand revelation from this official, who is no partisan gunslinger. When I called another official for confirmation, he said: "Oh, you know about it." The published report that somebody in the White House failed to plant this story with six reporters and finally found me as a willing pawn is simply untrue.
At the CIA, the official designated to talk to me denied that Wilson's wife had inspired his selection but said she was delegated to request his help. He asked me not to use her name, saying she probably never again will be given a foreign assignment but that exposure of her name might cause "difficulties" if she travels abroad. He never suggested to me that Wilson's wife or anybody else would be endangered. If he had, I would not have used her name. I used it in the sixth paragraph of my column because it looked like the missing explanation of an otherwise incredible choice by the CIA for its mission."

In other interviews Novak confirmed that his sources warned him not to use the name, advice he disregarded. His motivation is suggested by this comment in "The CIA Leak:" "I was curious why a high-ranking official in President Bill Clinton's National Security Council (NSC) was given this assignment." Just four days before he revealed Plame's name Novak wrote, "Bush's Enemy Within." (http://www.townhall.com/columnists/robertnovak/rn20030710.shtml) Therein Novak excoriates the Bush Administration's appointment of Frances Fragos Townsend to an important national security post explaining she could later betray Bush because two of her former superiors were liberal democrats and she had served in the US Attorney's office in Manhattan. According to Novak this office was "notoriously liberal laden."

Wilson had worked in the Clinton Administration. Novak's dismissal of his sources' warnings may have been motivated not by personal feelings about Wilson or the Iraq war but by his peculiar concern that the Bush Administration was hiring Democrats or liberals. In this scenario the interpretation by Wilson and others that the "leak" was designed to hurt Wilson or subvert Wilson's repeated denials that his wife recommended him for his trip would be erroneous. The officials who revealed Plame's name would theoretically have done so without ill intent and with the assumption their warnings would be heeded.

Although there have been many discussions about government and journalistic ethics promulgated by the Valerie Plame matter there has been little or no attention given to possible ethical breaches committed by Novak in foregoing his sources' warnings not to reveal Plame's name.

  • February 12, 2004 (http://www.prospect.org/webfeatures/2004/02/waas-m-02-12.html) Murray S. Waas for the American Prospect wrote that two "administration officials" spoke to the FBI and challenged Novak's account about not receiving warnings not to publish Plame's name. According to one of the officials, "At best, he is parsing words... At worst, he is lying to his readers and the public. Journalists should not lie, I would think."

Timeline

February 2002

Wilson travels to Niger at the request of the CIA

January 2003

On January 29 President George W. Bush gives his State of the Union speech. (http://www.cnn.com/2003/ALLPOLITICS/01/28/sotu.transcript/) Toward the end of the speech he says, "The British government has learned that Saddam Hussein recently sought significant quantities of uranium from Africa."

May 2003

Wilson becomes a foreign policy advisor for the John Kerry for President campaign.

July 2003

"Administration officials told columnist Robert D. Novak then that Wilson, a partisan critic of Bush's foreign policy, was sent to Niger at the suggestion of Plame, who worked in the nonproliferation unit at CIA. The disclosure of Plame's identity, which was classified, led to an investigation into who leaked her name.

The report may bolster the rationale that administration officials provided the information not to intentionally expose an undercover CIA employee, but to call into question Wilson's bona fides as an investigator into trafficking of weapons of mass destruction. To charge anyone with a crime, prosecutors need evidence that exposure of a covert officer was intentional."

  • 6 July 2003 (http://www.nytimes.com/2003/07/06/opinion/06WILS.html?ex=1065240000&en=884e266ea9a2bef2&ei=5070): Wilson's Op-Ed article "What I Didn't Find in Africa" published in New York Times.
  • 12 July 2003 (http://www.whitehouse.gov/news/releases/2003/07/20030712-11.html): Press Gaggle with Ari Fleischer at The National Hospital in Abuja, Nigeria: (Fleischer) [Saddam Hussein] "had previously obtained yellow cake from Africa. In fact, in one of the least known parts of this story, which is now, for the first time, public -- and you find this in Director Tenet's statement last night (http://www.usembassy.it/file2003_07/alia/a3071307.htm) -- the official that -- lower-level official sent from the CIA to Niger to look into whether or not Saddam Hussein had sought yellow cake from Niger, Wilson, he -- and Director Tenet's statement last night states the same former official, Wilson, also said that in June 1999 a businessman approached him and insisted that the former official, Wilson, meet an Iraqi delegation to discuss expanding commercial relations between Iraq and Niger. The former official interpreted the overture as an attempt to discuss uranium sales. ... This is in Wilson's report back to the CIA. Wilson's own report, the very man who was on television saying Niger denies it, who never said anything about forged documents, reports himself that officials in Niger said that Iraq was seeking to contact officials in Niger about sales."


  • 13 July 2003 (http://www.time.com/time/archive/preview/0,10987,464405,00.html): "A Question of Trust" is published at Time Magazine's website, publication date for the magazine being July 21. Journalist Matthew Cooper contributed to this article. This article and the subsequent 17 July 2003 "A War On Wilson?" are the subject matters of the Plame investigations, as indicated in the 15 February 2005 United States Circuit Court opinion ordering Cooper and New York Times journalist Judith Miller to respond to grand jury subpenas. "A Question of Trust" traces the controversy surrounding President Bush's 2003 State of the Union speech and the African uranium controversy. Anonymous sources of information are attributed to "two senior Administration officials," "another official," and "an intelligence official."
  • 14 July 2003 (http://www.townhall.com/columnists/robertnovak/rn20030714.shtml): "Mission to Niger" by Robert Novak: "Wilson never worked for the CIA, but his wife, Valerie Plame, is an Agency operative on weapons of mass destruction. Two senior administration officials told me Wilson's wife suggested sending him to Niger.... The CIA says its counter-proliferation officials selected Wilson and asked his wife to contact him."
  • 17 July 2003 (http://www.time.com/time/nation/article/0,8599,465270,00.html): "A War on Wilson" is published at Time Magazine's web site as a web exclusive. Matthew Cooper is listed as lead journalist. The article indicates that some of the sources for "A Question of Trust" had informed at least one Time journalist about Valerie Plame's status. "And some government officials have noted to TIME in interviews, (as well as to syndicated columnist Robert Novak) that Wilson's wife, Valerie Plame, is a CIA official who monitors the proliferation of weapons of mass destruction. These officials have suggested that she was involved in her husband's being dispatched Niger to investigate reports that Saddam Hussein's government had sought to purchase large quantities of uranium ore, sometimes referred to as yellow cake, which is used to build nuclear devices."
  • 21 July 2003 (http://foi.missouri.edu/voicesdissent/columnistnames.html) Another article displaying intelligence leaks is Newsday's July 21 piece, "Columnist Names CIA Iraq Operative." The authors are Timothy M. Phelps and Knut Royce. Both have been subpenaed in the Plame investigation. They attribute intelligence information independenyly leaked to them about Plame as coming from "intelligence officials" and a "senior intelligence official."
  • 30 July 2003 (http://www.hillnews.com/marshall/073003.aspx): When pressed, Scott McClellan told reporters: “I’m saying no one was certainly given any authority to do anything of that nature, and I’ve seen no evidence to suggest there’s any truth to it.” ... To date, Sens. Dick Durbin (D-Ill.) and Charles Schumer (D-N.Y.) have called for investigations and any number of other senators have told reporters that some sort of inquiry is probably in order.

August 2003

  • 8 August 2003 (http://www.nytimes.com/2003/08/08/national/08WEAP.html?ex=1065240000&en=ebdb9bc720f8d4c2&ei=5070): Days after Wilson "publicly voiced doubts about a reported Iraqi weapons program," Wilson says he became "a target of a campaign to discourage others like him from going public.... [and] Wilson's wife was identified by name as a covert C.I.A. operative in a column (http://www.townhall.com/columnists/robertnovak/rn20030714.shtml) by the conservative columnist Robert Novak, a disclosure that Mr. Novak has attributed to senior administration officials."
  • 26 August 2003 (http://www.calpundit.com/archives/002009.html): Wilson participated in a "public panel in Washington" on Thursday, August 21st, and is quoted as having said "At the end of the day, it's of keen interest to me to see whether or not we can get Karl Rove frog-marched out of the White House in handcuffs. And trust me, when I use that name, I measure my words." See transcript of August 21st panel discussion (http://www.pacificviews.org/archives/000094.html).

September 2003

  • 29 September 2003 (http://www.washingtonpost.com/wp-dyn/articles/A16860-2003Sep29.html): White House Press Secretary Scott McClellan on Karl Rove: "He wasn't involved,... The president knows he wasn't involved. ... It's simply not true."
  • 29 September 2003 (http://asia.reuters.com/newsArticle.jhtml?type=politicsNews&storyID=3527663): "'Nobody in the Bush administration called me to leak this,' Novak said, saying the information was disclosed to him while he was interviewing a senior Bush administration official.... Novak said the administration official told him in July that Wilson's trip was 'inspired by his wife,' and that the CIA confirmed her 'involvement in the mission for her husband.' ... 'They asked me not to use her name, but never indicated it would endanger her or anybody else,' he said, adding that a source at the CIA told him Plame was 'an analyst -- not a covert operator and not in charge of undercover operators.'"
  • 1 October 2003 (http://abcnews.go.com/sections/nightline/US/CIAleak031001.html): Wilson told Ted Koppel on Nightline that "Washington reporters told him that senior White House adviser Karl Rove said his wife was 'fair game'." Wilson "plans to give the names of the reporters to the FBI, which is conducting a full-blown investigation of the possible leak."
  • 1 October 2003 (http://seattlepi.nwsource.com/opinion/141956_wilsoned.html): "While Novak's decision to use Plame's name begs a journalism ethics debate, releasing her name to him or any reporter may well constitute a felony. Sunday [29 September 2003], The Washington Post said that White House officials had contacted six Washington reporters to disclose Plame's CIA identity."

October 2003

  • 1 October 2003 (http://www.townhall.com/columnists/robertnovak/printrn20031001.shtml): Novak explains: "My role and the role of the Bush White House have been distorted and need explanation." Wilson identifies the first "senior administration official" who informed about Plame as "no partisan gunslinger." The second later said to Novak "Oh, you know about it." As for the CIA official Novak spoke to, Novak claims that officer asked him not to reveal Plame's name, but not strenuously enough from Novak's point of view.
  • October 22, 2003. John Kerry for President, Inc. registers the domain for Wilson's website www.RestoreHonesty.com cached here. (http://www.thebluesite.com/restorehonestycom.htm)

2004

  • June 3, 2004 (http://www.nytimes.com/2004/06/05/national/05sharp.html?ei=5007&en=e28dd29b89884feb&ex=1401768000&adxnnl=1&partner=USERLAND&adxnnlx=1089767264-A5mvafHuL0BglOlsUeUimA) President Bush announces he will hire attorney James E. Sharp if questioned by the investigation.
  • June 24 2004 (http://www.washingtonpost.com/wp-dyn/articles/A3668-2004Jun24.html): President Bush is interviewed for more than an hour regarding the incident.
  • July 2004: In response to the Senate Intelligence Panel's Bipartisan Report Wilson withdraws from his advisory role to the John Kerry campaign. The campaign removes the www.restorehonesty.com website.

2005

  • 15 February 2005 : "A unanimous three-judge panel of the federal appeals court in Washington ... held that the reporters, Judith Miller of The New York Times and Matthew Cooper of Time magazine, may have witnessed a federal crime - the disclosure by government officials of the (CIA) officer's identity. The First Amendment, the panel ruled, does not give reporters the right to refuse to cooperate with grand juries investigating such crimes."

Reaction/response to Plame "leak"

September 30, 2003

  • 30 September 2003: "White House Counsel's Memo on Leak Probe", New York Times: "Text of an e-mail to White House staff Tuesday from counsel Alberto R. Gonzales about the Justice Department's investigation about the leak of a CIA officer's identity."
  • 30 September 2003 (http://biz.yahoo.com/prnews/030930/dctu064_1.html): "Remarks by President Bush to the Travel Pool After Meeting with Business People" in Chicago, IL:
"I know of nobody -- I don't know of anybody in my administration who leaked classified information. If somebody did leak classified information, I'd like to know it, and we'll take the appropriate action. And this investigation is a good thing.
"And again I repeat, you know, Washington is a town where there's all kinds of allegations. You've heard much of the allegations. And if people have got solid information, please come forward with it. And that would be people inside the information who are the so-called anonymous sources, or people outside the information -- outside the administration. And we can clarify this thing very quickly if people who have got solid evidence would come forward and speak out. And I would hope they would.
"And then we'll get to the bottom of this and move on. But I want to tell you something -- leaks of classified information are a bad thing. And we've had them -- there's too much leaking in Washington. That's just the way it is. And we've had leaks out of the administrative branch, had leaks out of the legislative branch, and out of the executive branch and the legislative branch, and I've spoken out consistently against them and I want to know who the leakers are."
  • 30 September 2003 (http://wyethwire.blogspot.com/): "Heads-Up-Gate" by Wyethwire bloggers: "The first rule of scandal is that the cover-up is worse than the crime. With that in mind, we ought to be looking to see if any effort was made to prevent the CIA from requesting a Justice Department investigation. And we ought to find out who warned the White House Counsel that something was up, so that Alberto Gonzalez could warn the White House staff in his now famous e-mail (http://www.washingtonpost.com/wp-dyn/articles/A21505-2003Sep30.html)."

October 2003

  • 1 October 2003 (http://www.townhall.com/columnists/robertnovak/rn20031001.shtml): "The CIA leak" by Robert Novak, Townhall.com.
  • 1 October 2003 (http://www.philly.com/mld/inquirer/news/front/6901387.htm): "Probe targets White House. Bush ordered his staff to cooperate as the Justice Dept. announced a full-scale inquiry into the CIA leak. Justice left open the possibility of a special counsel by Ron Hutcheson and Shannon McCaffrey, Philadelphia Inquirer: "The developments raised the prospect of a full-blown White House scandal while Bush is sinking in job-approval polls, struggling to win international help in Iraq, and grappling with Congress over his request for $87 billion more in war-related spending."
  • 1 October 2003 (http://www.sunspot.net/news/printedition/bal-te.cheney01oct01,0,7882975.story?coll=bal-pe-asection): "Iraq puts Cheney in harsh spotlight. Role: His broad influence on White House policy makes the low-profile vice president a high-profile target for Democrats" by Susan Baer, SunSpot.net: "CIA Director George J. Tenet says Dick Cheney was not briefed on Wilson's conclusions. Nor has Cheney been tied to accusations that the White House punished Wilson for his role in forcing the retraction by blowing his wife's cover as a CIA operative."
  • 1 October 2003 (http://www.philly.com/mld/inquirer/news/nation/6901402.htm): "Leak inquiry is a chink in Bush's moral armor" by Warren P. Strobel, Philadelphia Inquirer: "...revelation of a Justice Department criminal investigation into whether administration officials - believed to be at the White House - leaked the name of a CIA officer to get at a Bush opponent."
  • 2 October 2003 (http://www.nytimes.com/2003/10/02/opinion/02THU1.html?8br): "Investigating Leaks," Op-Ed New York Times: "Attorney General John Ashcroft has put himself and the president in a very dangerous position with his handling of the Justice Department's investigation into how Robert Novak got the name of a C.I.A. operative for publication in his syndicated column. After career lawyers conducted a preliminary investigation into the leaking of the officer's name, Mr. Ashcroft chose to proceed with a full investigation within the Justice Department. He did so despite department guidelines that would have permitted him to appoint an outsider, who would serve at Mr. Ashcroft's discretion but could make independent decisions. Instead, Mr. Ashcroft has decided to leave the investigation under the authority of the department's counterespionage office. That office employs career lawyers who routinely investigate this sort of leak and have the security clearances to do so with dispatch."
  • 2 October 2003 (http://www.nytimes.com/2003/10/02/politics/02ASHC.html?th=&adxnnl=1&adxnnlx=1065089516-YjiAq0uosIQg3QeUh3/C0g): "Attorney General Is Closely Linked to Inquiry Figures" by Elisabeth Bumiller and Eric Lichtblau, New York Times: "Deep political ties between top White House aides and Attorney General John Ashcroft have put him into a delicate position as the Justice Department begins a full investigation into whether administration officials illegally disclosed the name of an undercover C.I.A. officer." Names of inquiry figures associated with Ashcroft are: Karl Rove and Jack Oliver.
  • 2 October 2003 (http://story.news.yahoo.com/news?tmpl=story&u=/ap/20031002/ap_on_go_pr_wh/cia_leak&cid=544&ncid=716): "FBI Narrowing List of CIA Leak Suspects" by Curt Anderson, AP.
  • 2 October 2003 (http://story.news.yahoo.com/news?tmpl=story&u=/ap/20031002/ap_on_go_pr_wh/cia_leak&cid=544&ncid=716): "FBI Creates Team to Investigate CIA Leaks", AP: "Overseeing the investigation is John Dion, a 30-year career prosecutor who has headed the counterespionage section at the Justice Department since 2002."
  • 2 October 2003 (http://story.news.yahoo.com/news?tmpl=story&u=/washpost/20031002/pl_washpost/a29560_2003oct1): "Outside Probe of Leaks Is Favored" by Dana Milbank and Mike Allen, Washington Post: "Confronted with little public support for the White House view that the investigation should be handled by the Justice Department, Bush aides began yesterday to adjust their response to the expanding probe. They reined in earlier, broad portrayals of innocence in favor of more technical arguments that it is possible the disclosure was made without knowledge that a covert operative was being exposed and therefore might not have been a crime.... At the same time, administration allies outside the White House stepped up a counteroffensive that seeks to discredit the administration's main accuser, former ambassador Joseph C. Wilson IV, whose wife was named as a CIA operative. Republican National Committee Chairman Ed Gillespie gave a string of television interviews with the three-part message that the Justice Department is investigating, that the White House is fully cooperating and that Wilson has a political agenda and has made 'rash statements'."
  • 3 October 2003 (http://www.salon.com/opinion/feature/2003/10/03/dean/index_np.html): "More vicious than Tricky Dick" by John Dean: "I thought I had seen political dirty tricks as foul as they could get, but I was wrong. In blowing the cover of CIA agent Valerie Plame to take political revenge on her husband, Ambassador Joseph Wilson, for telling the truth, Bush's people have out-Nixoned Nixon's people. And my former colleagues were not amateurs by any means."
  • "Regardless of whether or not a special prosecutor is selected, I believe that Ambassador Wilson and his wife -- like the DNC official once did -- should file a civil lawsuit, both to address the harm inflicted on them, and, equally important, to obtain the necessary tools (subpoena power and sworn testimony) to get to the bottom of this matter. This will not only enable them to make sure they don't merely become yesterday's news; it will give them some control over the situation."[5] (http://www.democrats.com/preview.cfm?term=Valerie%20Plame)
  • 10 October 2003 (http://writ.news.findlaw.com/dean/20031010.html): "Why the Federal Conspiracy and Fraud Statutes May Apply Here" by John Dean.

2004

  • 4 June 2004 (http://writ.news.findlaw.com/dean/20040604.html): "The Serious Implications Of President Bush's Hiring A Personal Outside Counsel For The Valerie Plame Investigation" by John Dean.

See also

External links

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