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a.) XXXXXXXXXX [ JAMES CULKY (sp.), 4TH CALVARY DIVISION, BRIGADE S2 ] He will testify about his classification review of the three Apache gun videos that were sent to his Division by FORSCOM. Specifically, he will testify that the videos were not classified at the time of their alleged release. However, he will testify that he believes that videos should have been classified. He will also testify regarding his classification determination. The requested deposition is needed due to the Article 32 Investigating Officer's [ Lt. Col. Paul Almanza ] improper determination that XXXXXXXXXX [ JAMES CULKY (sp.), 4TH CALVARY DIVISION, BRIGADE S2 ] was not reasonably available at the Article 32 hearing. XXXXXXXXXX [ JAMES CULKY (sp.), 4TH CALVARY DIVISION, BRIGADE S2 ] was an essential witness and should have been produced in person at the Article 32 hearing. Additionally, given the fact XXXXXXXXXX [ JAMES CULKY (sp.), 4TH CALVARY DIVISION, BRIGADE S2 ] believes the matter that the Defense wishes to discuss with him is classified, the government needs to arrange for a proper location for the deposition. The Defense requests that an oral deposition be conducted.
b.) XXXXXXXXXX[ REAR ADMIRAL KEVIN DONEGAN, DIRECTOR OF OPERATIONS, USCENTCOM ]. XXXXXXXXXX[ REAR ADMIRAL KEVIN DONEGAN, DIRECTOR OF OPERATIONS, USCENTCOM ] conducted classification reviews on two PowerPoint slide presentations of official reports originated by USCENTCOM. The PowerPoint presentations are the subject of Specification 10 of Charge II. XXXXXXXXXX [ REAR ADMIRAL KEVIN DONEGAN, DIRECTOR OF OPERATIONS, USCENTCOM ] will testify regarding his classification determination and his belief of the impact on national security due to the release of the information. The requested deposition is needed due to the Article 32 Investigating Officer's [ Lt. Col. Paul Almanza ] improper determination that XXXXXXXXXX [ REAR ADMIRAL KEVIN DONEGAN, DIRECTOR OF OPERATIONS, USCENTCOM ] was not reasonably available at the Article 32 hearing. XXXXXXXXXX [ REAR ADMIRAL KEVIN DONEGAN, DIRECTOR OF OPERATIONS, USCENTCOM ] was essential witness and should have been produced in person at the Article 32 hearing. Additionally, given the classified nature of his testimony, the government needs to arrange for a proper location for the deposition. The Defense requests that an oral deposition be conducted.
c.) XXXXXXXXXX [MR. BETTS, CHIEF CLASSIFICATION OFFICER, US CYBER COMMAND ]. XXXXXXXXXX [ MR. BETTS, CHIEF CLASSIFICATION OFFICER, US CYBER COMMAND ] will testify about his classification determination concerning XXXXXXXXXX [ THE ALLEGED CHAT LOGS BETWEEN ADRIAN LAMO AND BRADLEY MANNING ]. Specifically, he will testify about his classification assessment of information discussed in XXXXXXXXXX [ THE ALLEGED CHAT LOGS ]. The requested deposition is needed due to the Article 32 Investigating Officer's [ Lt. Col. Paul Almanza ] improper determination that XXXXXXXXXX [ MR. BETTS, CHIEF CLASSIFICATION OFFICER, US CYBER COMMAND ] was not reasonably available at the Article 32 hearing. XXXXXXXXXX [ MR. BETTS, CHIEF CLASSIFICATION OFFICER, US CYBER COMMAND ] was an essential witness and should have been produced in person at the Article 32 hearing. Additionally, given the classified nature of his testimony, the government needs to arrange for a proper location for the deposition. The Defense requests that an oral deposition be conducted.
d.) XXXXXXXXXX [ ROBERT E. SCHMIDLE, DEPUTY COMMANDER, US CYBERCOM ]. XXXXXXXXXX [ ROBERT E. SCHMIDLE, DEPUTY COMMANDER, US CYBERCOM ] is the Original Classification Authority (OCA) over the information discussed by XXXXXXXXXX [ MR. BETTS, CHIEF CLASSIFICATION OFFICER, US CYBER COMMAND ]. XXXXXXXXXX [ ROBERT E. SCHMIDLE, DEPUTY COMMANDER, US CYBERCOM ] will testify that he concurs with the classification determination and impact statements made XXXXXXXXXX [ MR. BETTS, US CYBER COMMAND ]. The Defense would like to question him regarding his declaration and the basis of his belief. The requested deposition is needed due to the Article 32 Investigating Officer's [ Lt. Col. Paul Almanza ] improper determination that XXXXXXXXXX [ ROBERT E. SCHMIDLE, DEPUTY COMMANDER, US CYBERCOM ] was not reasonably available at the Article 32 hearing. XXXXXXXXXX [ ROBERT E. SCHMIDLE, DEPUTY COMMANDER, US CYBERCOM ] was an essential witness and should have been produced in person at the Article 32 hearing. Additionally, given the classified nature of his testimony, the government needs to arrange for a proper location for the deposition. The Defense requests that an oral deposition be conducted.
e.) XXXXXXXXXX [ VICE ADMIRAL ROBERT S. HARWARD, DEPUTY COMMANDER, US CENTRAL COMMANDER, US CENTRAL COMMAND (USCENTCOM) ]. XXXXXXXXXX [ VICE ADMIRAL ROBERT S. HARWARD, DEPUTY COMMANDER, US CENTRAL COMMANDER, US CENTRAL COMMAND (USCENTCOM) ] will testify concerning his classification review and classification determination concerning the CIDNE Afghanistan Events, CIDNE Iraq Events, other briefings and the BE22PAX.wmv video [Garani Air Strike Video]. Specifically, XXXXXXXXXX [ VICE ADMIRAL ROBERT S. HARWARD, DEPUTY COMMANDER, US CENTRAL COMMANDER, US CENTRAL COMMAND (USCENTCOM) ] will testify concerning his classification determination and his belief of the impact on national security from having this information released to the public. The requested deposition is needed due to the Article 32 Investigating Officer's [Lt. Col. Paul Almanza] improper determination XXXXXXXXXX [ VICE ADMIRAL ROBERT S. HARWARD, DEPUTY COMMANDER, US CENTRAL COMMANDER, US CENTRAL COMMAND (USCENTCOM) ] was not reasonably available at the Article 32 hearing. XXXXXXXXXX [ VICE ADMIRAL ROBERT S. HARWARD, DEPUTY COMMANDER, US CENTRAL COMMANDER, US CENTRAL COMMAND (USCENTCOM) ] was an essential witness and should have been produced in person at the Article 32 hearing. Additionally, given the classifed nature of his testimony, the government needs to arrange for a proper location for the deposition. The Defense requests that an oral deposition be conducted.
f.) XXXXXXXXXX [ PATRICK F. KENNEDY, UNDER SECRETARY, MANAGEMENT, DEPARTMENT OF STATE ]. XXXXXXXXXX [ PATRICK F. KENNEDY, UNDER SECRETARY, MANAGEMENT, DEPARTMENT OF STATE ] will testify concerning his review of the disclosure of Department of State Diplomatic Cables stored within the Net-Centric will testify concerning his Diplomacy server and part of SIPDIS. XXXXXXXXXX [ PATRICK F. KENNEDY, UNDER SECRETARY, MANAGEMENT, DEPARTMENT OF STATE ] will testify concerning his classification determination and the impact of the release of the information on national security. The requested deposition is needed due to the Article 32 Investigating Officer's [ Lt. Col. Paul Almanza ] improper determination that XXXXXXXXXX [ PATRICK F. KENNEDY, UNDER SECRETARY, MANAGEMENT, DEPARTMENT OF STATE ] was not reasonably available for the Article 32 hearing. XXXXXXXXXX [ PATRICK F. KENNEDY, UNDER SECRETARY, MANAGEMENT, DEPARTMENT OF STATE ] was an essential witness and should have been produced in person hearing. Additionally, given the classified nature of his testimony, the government needs to arrange for a proper location for the deposition. The Defense requests that an oral deposition be conducted. |
