EFTA00173373.pdf

UNCLASSIFIED/MOM 01/26/2024 New York, NY , having been duly sworn by Supervisory Special Agent (SSA) ., hereby make the following statement to and on 01/26/2024, and on 08/08/2024, and and on 10/07/2024, whom I know to be SSAs of the Federal Bureau of Investigation (FBI), assigned to the Inspection Division (INSD) at the time of my statement. My attorney, Richard J. Roberson, Jr., was present during my statement all occasions, via telephone. This statement took place over a three-day period. The statement initiated on 01/26/2024, and again on 08/08/2024, after additional allegations were added: I entered on duty (EOD) on 02/21/2006, as an Intelligence Analyst (IA). I EOD on 10/08/2008, as a Special Agent (SA) and I am currently assigned to the New York Field Office (NYFO) in that capacity. I understand that this is an internal investigation regarding an allegation that Special Agent improperly stored digital evidence at his residence in violation of 1.6- Investigative Deficiency- Improper Handling of Property in the Care, Custody, or Control of the Government. On 10/30/2023 the following expanded allegations were added: Special Agent improperly handled, documented, and stored digital evidence and failed to secure CSAM within policy, resulting in a cyber intrusion in violation of 1.6- Investigative Deficiency- Improper Handling of Property in the Page 1 of 106 UNCLASSIFIED//FOUO EFTA00173373  UNCLASSIFIED//FOLIO 01/26/2024 New York, NY Care, Custody, or Control of the Government and 5.17- Security (9 4 Violation- Failure to Secure sensitive Equipment/ Materials. On 02/07/2024 the following expanded allegations were added: Special Agent exceeded the limits of his authority by contracting an outside company to develop computer software on behalf of the FBI in violation of 2.6 Misuse of Position and 5.23 Violation of Miscellaneous Rules/Regulations. I have been further advised of my rights and responsibilities in connection with this inquiry as set forth on a "Warning and Assurance to Employee Required to Provide Information" form FD-645 which I have read and signed. I understand from my review of the FD-645 that should I refuse to answer or fail to reply fully and truthfully during this interview, I can expect to be dismissed from the rolls of the FBI. I have been advised by INSD not to provide the details of a whistleblower complaint I have filed with the Department of Justice in which I assert that these allegations are some of many retaliatory actions taken against me by the FBI that stem from a 2023 cyber intrusion of the NYFO's child exploitation forensic lab. While I will not go into details, I believe this is important to mention here given the very genesis of these allegations were derived from a directive to make me a scapegoat for the intrusion. I am happy to elaborate if requested, but in sum I was retaliated against for my having made numerous protected disclosures over the years that went unaddressed,l0 Page 2 of 106 UNCLASSIFIED//FOUO EFTA00173374  UNCLASSIFIED//FOUO 01/26/2024 New York, NY 8 which likely would have prevented the intrusion from happening. When the intrusion occurred, these disclosures, which I made again, caused FBI Executive Management (EM) to fear repercussions of their own failure to address the issues I presented before an incident like the intrusion could occur. I have proof upon proof that I was then targeted by FBI management as an attempt to make it appear that I and my squad mates were responsible. I know that INSD is in possession of the first of my submitted whistleblower complaints, but there are several other amendments as well as supporting documents that I can provide upon request. I am currently assigned to CT-25, a Domestic Terrorism squad, but assigned to an Enterprise Investigation that is a hybrid of Domestic Terrorism and Child Exploitation squad. I was assigned to squad CY-3 in May 2010 and officially named on the squad in July 2010. This was when the FBI's child exploitation program was referred to as "Innocent Images" and fell under the Cyber Division, while Squad. C-20 was the Human Trafficking (HT) squad at the time. I believe it was 2015 when Violent Crimes Against Children (VCAC) and HT programs were combined under the FBI's Criminal Division, which led to the merger of the violations in the NYFO under squad C-20. The squad is split and has the HT side and the VCAC side, and I was a VCAC Agent. Agents primarily work their assigned viol tions, but we come together as a squad for operations. Q9 1) Page 3 of 106 UNCLASSIFIED//F0130 EFTA00173375  UNCLASSIFIED//FOOD 01/26/2024 0 New York, NY I have been with the FBI for over 18 years, having spent the last 16 years as an Agent. I have been one of the FBI's leading Agents in Child Exploitation investigations and to this day, I believe that I am one of, if not the only, Court- certified expert witness for the entire FBI for child exploitation. I have personally accounted for over 60 arrests, 150 search warrants, and have been responsible for rescuing several hundreds of children. As is elaborated on in my Curriculum Vitae, which I have provided to INSD and has been introduced to certify me in Court as an expert witness, I also have received numerous awards and accolades, including but not limited to being a two-time recipient of the FBI's Medal of Excellence and the Southern District of New York's (SDNY) prestigious McCabe Award. I have an incredible reputation around the FBI and am seen as one of the hardest working and driven Agents in the FBI. In demonstrating the support I received, after the intrusion when FBI Headquarters (HQ) had begun its efforts to retaliate against me, the NYFO went to great lengths to push-back. Now retired Assistant Director in Charge (ADIC) defied orders from Assistant Directors (AD) and the Deputy Director (DD) to have me punished. This defiance led the DD to order charges against me, and months later I received the first of the referenced charges. The NYFO however still showered me with their support, with singing my Page 4 of 106 UNCLASSIFIED//FOUO EFTA00173376  UNCLASSIFIED//FOOD 01/26/2024 New York, NY e:yraises to , stating that he would rather have one " than 10 other Agents. The NYFO also nominating me for the second of the FBI Medal of Excellence awards I would receive in December 2023. Just months ago, in 2024, I was nominated for, but did not receive, the Director's Award, however at the same time I was nominated for an award from the Federal Law Enforcement Foundation and on 10/22/2024, I was informed I am receiving it. I can expand at length on the accolades and praise I have received from Agents, Analysts, management, HQ, Assistant United States Attorney's (AUSA's), local law enforcement, and more over the years. Even despite my current situation I continue to receive praise and support from all ranks and from AUSAs. Last month, in September 2024, the SDNY Project Safe-Childhood Coordinator (PSC) requested I assist her in providing child exploitation training to SDNY AUSAs. The PSC is aware I am no longer on the child exploitation squad, and finds the actions taken against me to be disgraceful. She also stated that despite it all, she considers me to be the best in the FBI. Regarding the allegations against me, it is my understanding that they stem, in whole or in part, from interviews conducted by the FBI's INSD in March 2023. Specifically, the statements I made during those interviews ..,•) Page 5 of 106 UNCLASSIFIED//FOUO EFTA00173377  UNCLASSIFIED//FOUO 01/26/2024 New York, NY ppear to have been the basis for the observations outlined in the subsequent INSD report, which the FBI has reported to be the foundation of these charges. I have since learned that this report was authored by someone two or three levels removed from me, relying on secondhand interpretations of my statements from the notes of the interviewers. I know what I said during the interviews, and the references in the INSD report do not accurately reflect my actual words. The INSD initially published a draft report around May or June 2023, which included observations closely mirroring the allegations against me. Both I and the NYFO leadership, including my former ADIC, countered these observations as we believed them to be inaccurate. These inaccuracies were discussed in detail during meetings with and FBI EM, and we later submitted a formal written rebuttal. However, the final INSD report, published in July 2023, failed to incorporate our responses. The observations based on my statements were neither revised to align with my rebuttal nor updated to reflect supporting evidence. I have also learned that the interviewers themselves were not provided with either the draft or final versions of the INSD report, nor were the interviewers informed of the responses submitted by me or the NYFO. Instead, the report's author relied Page 6 of 106 UNCLASSITIED//FOUO EFTA00173378  UNCLASSIFIED//FOLIO 01/26/2024 New York, NY solely on the interviewers' notes, which were not a verbatim transcription of the interview, and the interview itself was not recorded. This left critical context about my statements subject to the author's interpretation. Similarly, the rebuttals submitted to challenge the observations were not addressed. As a result, the final report left the original observations largely unchanged. In the interest of transparency, I am including the NYFO's final response to the INSD's draft report. This response was a collaborative effort between myself, my SSA, my Assistant Special Agent in Charge (ASAC), and the NYFO's Information System Security Officer (ISSO). It was formally submitted as a rebuttal to the draft observations. Unfortunately, the final INSD report failed to incorporate these responses, leaving the contested observations intact. This is deeply troubling, as the allegations were contested from the outset with the full support of the NYFO chain of command. After reviewing the draft INSD report, the NYFO was afforded an opportunity to respond in writing to both the INSD "observations" and "findings". The following is the last version of the NYFO's response that had been drafted by III , and Office of the Chief Information Officer (OCIO) . In the "NY's Clarifications to the Page 7 of 106 UNCLASSIFIED//FOUO EFTA00173379  UNCLASSIFIED//FOOD 01/26/2024 New York, NY Si Inspection Report's Observations" section you will see listed the "Observation", which was identified by INSD, then the subsequent "Clarification of Facts", which was the NYFO's rebuttal to the observations. Following this section, you will see the "NY's Responses to the Inspection Report's Findings" section. Similarly, you will see listed the "Instruction", which was identified by INSD, then the subsequent "Response", which was the NYFO's rebuttal to the instruction. NY's Clarifications to the Inspection Report's Observations Observation 1: NY was operating a device providing Internet access through wireless connectivity in FBI secured space. Clarification of Facts: NY received authorization from Security Division in 2018 to utilize Wi-Fi devices within FBI space, as long as the device connected to the Wi-Fi was 10 feet from an Enterprise computer. Regardless, because C20 did not request the particular Wi-Fi modem/router which was in the lab at the time of the intrusion, the wireless features were never utilized and presently there are no wireless devices in FBI space. Page 8 of 106 UNCLASSIFIED//FOOD EFTA00173380  UNCLASSIFIED//FOLIO 01/26/2024 New York, NY Observation 2: NY was connecting overtly and covertly purchased IT on the IS. Clarification of Facts: Axiom, Cellebrite and GrayKey are LE tools purchased by CACHTU and used by DExT examiners in the Field. CACHTU advised the field to utilize UCO funds to make purchases of new equipment to support the tools. Observation 3: NY was storing DE overnight in an unapproved storage facility. Clarification of Facts: The previous practice utilized by was to image the Original Digital Evidence on the Network Attached Storage, place such in Evidence Control, and then copy the Original Imaged Evidence, creating a Master Working Copy. During specific times in 2020, created a copy of specific files/documents from the Master Working Copy and brought these limited working copy items home via his work laptop to perform work related tasks. The copies he took home to work on were copies of copies and were limited to specific files from the larger forensic images. The files/documents were not Page 9 of 106 UNCLASSIFIED//FOLIO EFTA00173381  UNCLASSIFIED//FOUO 01/26/2024 New York, NY , or sens itive contraband, classified material, CSAM material. Further, in 2020, FBI Management was to work from authorizing and encouraging employees the office. home to limit the spread of COVID 19 in Once did not store any files at his house. the electronic he completed his analysis he brought appropriately files/documents back to the office and disposed of same. y image DE. Observation 4: NY did not appropriatel e C-20 has Clarification of Facts: This is an issu inely aske d for raised for years with HQ and has rout policy, but hard drives in order to comply with the they would have has been denied and C-20 was advised , HQ would not to pay for the drives. At the same time to purchase those supply C-20 with the funds in order same hard drives. the outdated Additionally, C-20 takes issue with onto an process of creating derivative evidence me of data that is additional hard drive. As the volu nentially over time, being collected has increased expo drives is the amount and cost of using hard ests the use of impractical and costly. C-20 sugg Page 10 of 106 UNCLASSIFIED//FOUO EFTA00173382  UNCLASSIFIED//FOUO 01/26/2024 New York, NY 13) servers or cloud storage as a means to store derivative copies of evidence, which can be reused at the conclusion of an investigation and when the evidence (and derivative evidence) is destroyed. Observation 5: NY did not appropriately verify analyzed images of acquired DE. Clarification of Facts: NY in fact did appropriately verify analyzed imaged of acquired DE by generating an FD-302 which documented in the substantive case file as well as at 305A-HQ-1654544- DEXT to account for the work performed. Any issues or discrepancies would be documented in the FD-302. A hash verification log was also generated and stored with the DE on the Network Attached Storage, which could be accessed at any time. Going forward, the hash value verification log will be attached to the FD-302 to ensure compliance with policy. Observation 6: NY was not appropriately documenting and storing ELSUR records in relation to undercover communications. Clarification of Facts: NY appropriately places OCE/UCE communications in Subfile G of the UCO, which Page 11 of 106 UNCLASSIFIED//FOUO EFTA00173383  UNCLASSIFIED//FOUO 01/26/2024 New York, NY is where CACHTU policy mandates these communications be placed. Observation 7: NY did not document meetings between UCE/OCE and SSA every 90 days and the SAC/ASAC every six months. Clarification of Facts: While the SSA and ASAC met with the OCE/UCE's connected to the UCO on a regular basis, primarily in the squad area and via the file review and CUROC process, NY will draft ECs documenting same in accordance with policy going forward. Observation 8: NY did not utilize covert methods to procure covertly purchased goods. Clarification of Facts: The items which were purchased are Law Enforcement only. NY was provided funding from HQ via the UCO to make this purchase with the understanding that it's a restricted purchase. Going forward, NY will ensure if a purchase needs to be made overtly, covert funding will be converted to overt funding by an approved FBI purchaser. Page 12 of 106 UNCLASSIFIED//FOUO EFTA00173384  UNCLASSIFIED//FOOO 01/26/2024 New York, NY Observation 9: NY was not documenting financial appropriate CE records relating to IMO activity to the subfile. Clarification of Facts: NY submits a monthly BlueSlip that contains all of the financial ncial documentation for the prior month's fina activity. The same information that is required to be d in the submitted to the CE subfile is containe BlueSlip. NY changed the individual who performs the l and, accounting over time on a field office leve it was not put while the information was recorded, into the CE subfile. rt a Observation 10: NY did not properly repo security incident within SIRS. rred Clarification of Facts: The incident occu 2023. In the during the night of Sunday, February 12, noticed his morning of Monday, 2/13/23, and began trouble Talino was not operating correctly Upon determining a shooting with the company and HQ. rred, potential intrusion may have occu notified and CACHTU on notified 2/13/23. Following notification, Page 13 of 106 UNCLASSIFIED//FOUO EFTA00173385  UNCLASSIFIED//F0130 01/26/2024 New York, NY on 2/13/23. During the week of 2/13/23, NY EM, NY Cyber there were numerous meetings between with HQ. and NY CIO, among others, in coordination occurred, III When there was an understanding of what in submitted a security incident report with SIRS on 2/17/23. yption Observation 11: NY did not implement encr on devices or data on the IS. d Clarification of Facts: There are broa to UCO IS. NY contradicting policies as it relates ent and testing requested assistance in the developm met with no the IS over the several years and was r HQ level response from OTD, CART, OCIO, and othe , entities. Going forward, recommendations from OCIO OTD, etc., are being implemented. requirements Observation 13: Policy regarding the rity for patching, ATO, use of an ISSO, secu gement, monitoring, remote access, account mana le devices, and maintenance or IT hardware, use of mobi include approval for custom HATA solutions to cy, SOPs, technical operational security, cost efficien em access architecture, accounts and access, syst Page 14 of 106 UNCLASSIFIED//FOUO EFTA00173386  UNCLASSIFIED//FOUO 01/26/2024 records, acquisitio Ne w York, NY n planning, user account guidelines, compli ance with 0655PG, and training for covert ISs is insuff icient. Clarification of Fa cts: NY has one ISSO, hi red in mid-January 2023 . NYO's ISSO is resp onsible for multiples sites. It is not feasible for one ISSO to effectively monitor and maintain IS's within the NYO. Industry standards recommend multiple individuals in different roles wi th qualifying creden tials to ensure the integrity of IS 's. Observation 15: NY st ored CSAM from multip le investigations in an effort to identify victims across multiple cases. Clarification of Fa cts: As NCMEC only maintains the "MD5s" or "hash values" of the CSAM, not the actual media itself , NY stored CSAM on the IS for facial recognition and "photo DNA." PG 1157PG requires a CVIP comparison fo r CSAM which is fa cilitated through NCMEC and do es not prohibit the creation of use of independent IS s to store and compar e CSAM across multiple cases and field offices, noted in Page 15 of 106 ONCLASSIFIED//FOU0 EFTA00173387  UNCLASSIFIED//FOUO 01/26/2024 New York, NY This should not be draft INSD Report page 7. ble through NCMEC/CVIP. prohibited as it is not availa low minimal and Observation 16: NY did not fol wide security practices for commonly accepted industry the IS. re are num erous Clarification of Facts: As the stantly changing guidance conflicting policies and con k, ls under a covert networ regarding the IS, as it fal e policies or accepted NY did not willfully violat ctices and welcomed any and industry wide security pra field offices and HQ all assistance from other sections. ended training, Guidance and funding of recomm uld be provided by HQ to internal and external, sho erprise wide IS standards. provide consistency of ent developed, maintained and Properly ensuring IS's are and retaining qualified monitored requires hiring ITS Networ k personnel such as ISSO's and Special Agents and non-ITS Specialist/Architectures. technically trained and not Professional Staff are not tem Administrators equipped to act as a Sys Page 16 of 106 UNCLASSIFIED//FOUO EFTA00173388  UNCLASSIFIED//FOU0 01/26/2024 New York, NY NYO has one ISSO wit h responsibilities spanning all Resident Agencies. The NYO's Headquarter City and d in NYO mid-January 2023. ISSO was hired and on-boarde tly have ITS Network NYO Security does not curren e Specialist/Architectures. NYO Security would requir five ITS Network a minimum of four ISSO's and ensure all IS's within NYO Specialist/Architectures to r and all IS's are securely have a System Administrato monitored. NIST and other developed, maintained and ctices require designated industry standard best pra rating unit to act in personnel outside of the ope duties is required to these roles. Separation of the IS's. retain the integrity of tion Report's NY's Responses to the Inspec Findings ll ensure all Instruction 1: ADIC NY sha h owing Internet access throug unauthorized devices all removed from FBI secured wireless connectivity are space or disabled. wireless device s in FBI Response All non-approved 1:? on(:F1 ices approved by divisi space are disconnected. Dev Page 17 of 106 UNCLASSIFIED//FOLIO EFTA00173389  UNCLASSIFIED//F000 01/26/2024 head and the AD of New York, NY SecD will remain op erational only during mission crit ical needs at this time. Communication regard ing the prohibited use of wireless devices wi thin FBI space has and will continue to be diss eminated on a regula r basis. Signage is in place referencing policies prohibiting the use of wireless de vices in FBI space. For example, signs are posted in each elev ator bank of 26 Federal Plaza. All owners of overt and covert portable electronic devices (P ED's) ar e required to regist er devices with NYO's Security unit whereu pon the user accepts the terms of use for said device s. The terms of use include but are not limited to th e prohibited use of wireless conn ectivity to include radio frequency connection s such as Wi-Fi and cellular based Mi-Fi within FBI spac e. NYO's Security unit has en gaged with NYO's Technically Trained Agents to begin rout ine sweeps within NYO's space to identify active RF's . If RF devices are identifi ed without a waiver au thorizing Page 18 of 106 UNCLASSIFIED//FOU0 EFTA00173390  UNCLASSIFIED//FOUO 01/26/2024 New York, NY use by NYO's Division Head and the AD of SecD, the /or removed from FBI space. device will be disabled and l ensure overtly and Instruction 2: ADIC NY wil used on the same IS. covertly purchased IT is not process, as Response: While this is a HQ driven lebrite and GrayKey CACHTU purchases Axiom, Cel behalf of the Field Office directly from the vendor on the Field, NY is in and provides these tools to IT meets this requirement, contact with CID to ensure or a waiver is granted. l ensure evidence is Instruction 3: ADIC NY wil and approved manner. stored in a safe, secure, Response: II =Ilk refutes the assertion he his house. NY will ensure took home and stored DE at related to storage of that appropriate policies evidence are followed. l ensure compliance to Instruction 4: ADIC NY wil ating and maintaining applicable policy when cre derivative DE. with CART and Response: NY has consulted and PG, the underlining consistent with CART SOP Page 19 of 106 UNCLASSIFIED//FOLIO EFTA00173391  UNCLASSIFIED//Fou0 01/26/2024 electronic device, as New York, NY well as the Master Copy, will be entered into eviden ce as a 1B. A furt her additional copy will be made as a working copy on wh ich the actual forensic work will be performed. NY will engage with CACHTU to obtain the appr opriate funding required to obtain the required portab le electronic storage devices to ho use the increased nu mbers of copies. Further, NY is working with NY Evidence and the Laboratory Divi sion's Field Eviden ce Program to obtain authorizatio n for standalone st orage devices to be classified as an appropriate Evidence Control Room to house Derivative Evidence. The standa lone storage device would contai n the same Derivative Evidence which would otherwis e be copied onto ha rd drives and physically checked in to evidence. The st orage device would be secured with sufficient user cred entials and maintain access logs . The Derivative Ev idence would still require an evid ence submission to generate 'Bs for the Derivative Ev idence. At the conclu sion of the case, this Derivati ve Evidence can be deleted and the space made availabl e for new Derivative Evidence to be stored, rather than co ntinuously purchase new hard drives only to have them destroyed at th e conclusion of an investigation. Cl Page 20 of 106 UNCLASSIFIED//FOLIO EFTA00173392  UNCLASSIFIED//FOUO 01/26/2024 New York, NY on 5: ADIC NY will ensu re comp liance Recommendati and maintaining to applicable policy when creating derivative DE. reviews Response: NY performs post examination A hash verification and documents them via an FD-302. log is also created. liance Instruction 6: ADIC NY will ensure comp rds in with requirements to document ELSUR reco accordance with applicable policy. ations that Response: NY ELSUR stated any communic OCE/UCE cellular occur via a covert platform (i.e an phone) is not ELSUR evidence. compliance Instruction 7: ADIC NY will ensure ings between with requirements to document meet ate SAC/ ASAC and undercover personnel and the appropri SSA. with the Response: NY will document meetings held e in the SSA/OCE and SAC or ASAC/OCE and plac appropriate subfile of the UCO via an EC. a Page 21 of 106 UNCLASSIFIED//FOUO EFTA00173393  UNCLASSIFIED//FOU0 01/26/2024 New York, NY Instruction 8: ADIC NY will ensure compliance ods to obtain with requirements to employ covert meth goods when using confidential funding. Response: NY will ensure compliance with s. NY Security requirements for making covert purchase the purchase of has implemented approval processes for t and purchase IT equipment. A review of the equipmen appropriately. method will be conducted and approved l review board NY CSO is now a member of the UCO loca purchasing, to ensure all policy is adhered to when electronic implementing and utilizing overt/covert devices and IS technology. liance Instruction 9: ADIC NY will ensure comp ment financial with requirements to maintain and docu records related to UCO activity. ncial Response: NY will ensure that all fina CE subfile. documentation will be placed in the compliance Instruction 10: ADIC NY shall ensure requirements to with security incident reporting SIRS. report security incidents within Page 22 of 106 UNCLASSIFIED//FOUO EFTA00173394  DNCLASSIFIED//FOU0 01/26/2024 Response: NY will New York, NY work with the NY CSO to ensure all security incide nts are reported within the prescribed time fr ame per policy. Instruction 11: AD IC NY shall ensure compliance with encryption re quirement for the IS . Response: While this does not apply to the UCO, NY will ensure comp liance with encryp tion policy as applicable. NY0 Se curity has engaged with OLIO to develop secure netw ork protocols base d on industry standards such as NIST to include encr yption at rest and encryption in tr ansit. Recommendation 15a: ADIC NY should no longer maintain a set of CS AM for independent analysis outside of the CV/P approved hash base d searching tools. Response: NY fulfills its re quirements to submit images of CSAM to NC MEC via the CVIP. After the final INSD re port came out, I was advised that eceived a call from II IIIIIIIIlla 111. 1 who were accusing me of making statements to the effect of having no regard for following policy. Th is is of course Page 23 of 106 UNCLASSIFIED/MOOD EFTA00173395  UNCLASSIFIED//F000 01/26/2024 New York, NY nkfully believed as categorically false and tha any r AD could or would provide much, especially when neithe re it ns such as who heard it, whe details regarding the allegatio only then being addressed. was documented, or why it was mitted the following: However, in response, I sub "Bosses, ting t I made a statement indica Regarding the assertion tha a the sake of an operation is I would violate policy for it is a gross miss- utter non-sense. Furthermore ion that was had and quite interpretation of the conversat from racter and integrity. Aside frankly an insult to my cha of words used is blatantly lacking context, the choice misleading. h context as needed, but in I'm happy to provide as muc ld never, jeopardize any short I have never, and wou ) by intentionally violating investigation (or my career to save and would do, is anything policy. What I have done, I said that has been the life of a child. What life ld do anything to save the misconstrued, was that I wou or e to ever violate policy of a child, and that if I wer nt because there was an immine the law, it would ONLY be ar and articulable except threat to life in which a cle would apply. j (ta Page 24 of 106 UNCLASSIFIED//FOU0 EFTA00173396  UNCLASSIFIED//FOUO 01/26/2024 I stand by that statement New York, NY and take great pride in my knowledge of both the law