contact | about | archive | Official Record of Trial (Manning) | usvmanning.org | charges (Manning) | verdict (Manning) | usvwikileaks.org |

US v Pfc. Manning | The USG Opening Statement (Rush Transcript) on June 3, 2013

|

Below is a rush transcript of the opening statement made by Captain Joe Morrow of military prosecution on the first day of United States v. PFC Manning, taken by journalist, Alexa O'Brien, at Fort Meade, Maryland.

If you had unprecedented access to classified networks fourteen hours a day, seven days a week for eight plus months what would you do?

The evidence will show that those are the words of PFC Manning.

This is not a case about an accidental spill of classified information.

This is not a case about a few documents left in a barracks or CHU [Containerized Housing Unit].

This is not a case about a government official who made discrete targeted disclosures of classified information based on content they [missed] carefully.

This your Honor-- this is a case about a soldier who systematically harvested hundreds of thousands of documents from classified databases and then literally dumped that information onto the internet into the hands of the enemy-- material that he knew based on his training and his experience that could put the lives and welfare of his fellow soldiers at risk.

This is a case about what happens when arrogance meets access to sensitive information.

The evidence will show that beginning in November 2009-- less than two weeks after starting work in the Sensitive Compartmented Information Facility at FOB Hammer, Iraq.

PFC Manning disregarded the judgement of senior officials, the rules guarding the protection of classified information and his own acknowledged application application to safeguard our nation's secrets.

The evidence will show that PFC Manning violated the trust of his superiors to the detriment of the soldiers he served with and to the aid of our adversaries.

The evidence will show that PFC Manning used his military training to gain notoriety and fame.

In short the evidence will show that PFC Manning knew the consequences of his actions and disregarded that knowledge in his own self interest.

Over the course of approximately six months the evidence will show that PFC Manning systematically and indiscriminately harvested more than 700 thousand government records from various SIPRNet database and transmitted the information to a group who advocated for random openness without any appropriate limits.

The government will show that PFC Manning attempted to hide what he was doing from others.

He repeatedly, the evidence will show, moved CD's containing classified information from his work station in the SCIF to his containerized housing unit-- and once there the evidence will show that PFC Manning packaged the information, encrypted the information and transmitted the information using tools designed to ensure he would not be caught.

And after transmitting the information the evidence will show that PFC Manning often took painstaking steps to erase any evidence of what he had done to his computers.

The evidence will show that PFC Manning repeatedly abused his access to the SIPRnet by searching for classified information with no logical nexus to the work that he was suppose to be doing in Iraq.

The evidence will show that PFC Manning was well versed in the type of information that if disclosed to unauthorized persons could reasonably be expected to cause damage to national security.

The evidence will also show that PFC Manning did not discriminate in gathering documents.

The information will show that his interest was in gathering information in bulk-- aside from a few documents in this case your Honor.

The evidence will show that PFC Manning's actions were not calculated transmissions of documents in ones-ies and twos-ies.

These were massive-- massive downloads aided by PFC Manning's mastery of an unauthorized software program called Wget-- packaged and out the door to WikiLeaks in less than a few hours in some cases.

Finally, the evidence will show that this massive amount of information has great value to our adversaries and in particular our enemies.

On the screen your honor is the government's case in chief-- a roadmap of the government's case in chief or [missed word] case in chief.

The first several witness will discuss the investigation in Iraq.

[Missed] witness discuss PFC Manning's training at Fort Huachuca.

PFC's Manning's deployment to Iraq.

And, the government will proceed with the charges in Specifications in essentially chronological order, with forensics related to each charge's Specifications presented simultaneously as well as evidence relating to the [missed].

Your Honor, before we proceed with the Charges and Specifications, the government would like to highlight a few pieces of evidence and some terms you will hear references throughout the trial.

The key evidence in this case your Honor.

SIPRnet computers, Intelink Logs-- and when I speak of Intelink logs, your Honor.

I am talking about the evidence will show that they are logs that capture audit logs that capture activity on the SIPRnet.

CID agents collected a personal computer from PFC Manning's CHU as well as an external hard disk drive, an SD card, which is a memory card used for portable electronic devices, that was collected from PFC Manning's aunt's house in Potomac, Maryland.

The government will present evidence related to a computer recovered from Brookhaven National Laboratory New York.

CENTCOM SIPRnet SharePoint logs. The evidence will show that SharePoint, your Honor, is simply a web server that is used by staff at CENTCOM to post documents-- share documents.

And, a Supply SIPRnet computer collected because PFC Manning was removed to the Supply Annex towards the end of his deployment. AIT instructions.

PFC Manning signed Non Disclosure Agreements, and as referenced earlier your Honor, what the evidence will show to be the WikiLeaks Most Wanted List.

First your Honor, the .22 and the .40 computers.

When the government-- or when the witness refers to the .22 or .40 the evidence will show that they are referring to the last octet of the two IP addresses of the two SIPRnet computers collected [missed].

The evidence will show that PFC Manning's primary SIPRnet computer was called the .22-- and on that computer Special Agent Shaver will testify was a file-- and excel spreadsheet-- called backup.xls

This spreadsheet your honor is evidence that PFC Manning was cataloguing his downloading of the State Department cables.

In particular your Honor the evidence will show that the number at the top left, 251288 was the next number in line after the amount of cables released on WikiLeaks-- purported Department of State cables released on WikiLeaks.

The evidence will show that WikiLeaks release 251, 287.

The secondary SIPRnet computer your Honor was .40-- and Special Agent Shaver will testify that there are more than 100 thousand full base 64 encoded Department of State cables. Base 64 your Honor is simply a method of encoding information that optimizes the transmission of the information on the Internet-- and Special Agent Shaver will testify regarding this.

Intelink logs your Honor. Intellink is a SIPRnet search engine-- it is very similar to Google-- in fact it is powered by Google.

The logs collected in this case by CID agents are linked to the .22 and .40 IP addresses and those logs span the length of PFC Manning's deployment. So, approximately 1 November to the end of May 2010.

It will also show that those computers searched for WikiLeaks over 100 times on the SIPRnet.

Next your Honor PFC Manning's personal laptop. His laptop and Apple brand laptop was collected from PFC Manning's personal living space on FOB Hammer.

And Mr. Johnson one of the forensic examiners will testify that he was able to recover two different sets of chat logs.

First the chat logs that were recovered from what is called the unallocated space on a computer-- and those chat logs the evidence will show are between PFC Manning and what the evidence will show to be Julian Assange.

Next set of chat logs also recovered on his computer are between PFC Manning and Adrian Lamo. And your Honor, you will hear evidence that Adrian Lamo is the individual who brought PFC Manning to law enforcement.

Those logs are-- the chat logs between Adrian Lamo, your Honor, the evidence will show are found in the allocated space-- meaning it was actual file on the computer.

The chat log between PFC Manning and pressassociation or Julian Assange were found in the unallocated space-- and unallocated space you will hear from several witness-- specifically the forensic examiners is the space on the computer that is not being-- it is not being used with- currently used with active data-- so it might be information that is deleted or might never have been used by the computer.

In [missed] of these chat logs is that there are several admissions made by PFC Manning. First your Honor, the evidence will show that PFC Manning admitted to beginning help WikiLeaks right after the Thanksgiving time frame 2009. And when you see bradass87 your Honor, the evidence will show that bradass87 is the user name of-- or the chat log name for PFC Manning.

PFC Manning also made several admissions in the chat log relating to information that is the subject of this court-martial.

Information that he allegedly [missed]. [On the screen is displayed an excerpt of an alleged chat log. I could not get the content of the presentation and transcribe at the same time.]

The chat logs between PFC Manning who evidence will show to be dawgnetwork show a familiarity between the the dawgnetwork and pressassociation or what the evidence will show to be Julian Assange.

And again your Honor, these are chat logs recovered from the unallocated space-- so they were deleted.

And finally your Honor-- some of the chat logs will show that PFC Manning indicated what he thought WikiLeaks was. [On the screen is displayed an excerpt of an alleged chat log. I could not get the content of the presentation and transcribe at the same time.]

Also recovered from PFC Manning's computer your Honor is what forensic examiners will refer to as mounting data.

Mounting data your Honor is simply data that is created [by?] the personal laptop when a CD is inserted.

Your Honor what is on the screen now is the mounting data recovered from the deleted space of the unallocated space on PFC Manning's personal computer.

Specifically your Honor the evidence will show that the numerics there-- so see at the top 100215 underscore 0621-- you will hear testimony that that is the way that the Roxio CD burning program on PFC Manning's SIPRnet laptop date time stamps a CD when it is burned.

When this mounting data was a capture essentially the name of the CD and the evidence will show that it also captured the files on the CD as well.

As you can see your Honor, the evidence will show that 6th line down-- the document is the subject of Specification 14 of Charge II is there [Reykjavik 13]. [On the screen is displayed an slide. I could not get the content of the presentation and transcribe at the same time.]

Also collected from PFC Manning's CHU [Containerized Housing Unit] or personal living space, your Honor, were two documents of interest.

The first was a PowerPoint brief prepared-- or what the evidence will show to be PFC Manning at Advanced Individual Training at Fort Huachuca-- Mr. Brian Madrid-- the Platoon Sergeant for PFC Manning will testify that PFC Manning was required to give this outside brief as corrective training.

Additionally your Honor, forensic examiners were able to recover contact information for Julian Assange. And the evidence should show that the metadata related to that file-- shows that the file was created on 29 November 2009.

Your Honor on the screen is the actual content of the text file. CID agents also collected the SD card as I mentioned earlier your Honor.

The SD card is simply a portable memory device used for cameras and things like that. That SD card was collected from PFC Manning's aunt's house in Potomac Maryland.

And, the evidence will show that on that SD card were two complete databases-- Combined Information and Data Network Exchange-- CIDNE-Iraq SigActs database and the CIDNE Afghanistan SigAct database.

The evidence will show that the metadata related to those files shows that the Afghan database was created on January 8, 2010. The metadata found related to the Iraq database was created on 5 January 2010.

Finally your Honor you will se there a text file was also on this SD card titled 'read me' created on 9 January 2010. And, in that text file was a note. [On the screen is displayed an slide.

I could not get the content of the presentation and transcribe at the same time. It is the text file referred to at the Article 32 on December 2011, and Manning's Statement on February 28, 2013 'It's already been sanitized of any source identifying information.

You might need to sit on this information-- perhaps 90 to 100 days to figure out how best to release such a large amount of data and to protect its source. This is possibly one of the more significant documents of our time removing the fog of war and revealing the true nature of twenty-first century asymmetric warfare. Have a good day.']

This is the actual content of the text file, your Honor.

And on the SD card as well are pictures of PFC Manning. The evidence will show that this was PFC Manning's portable electronic device.

FBI and CID agents also collected a computer from Brookhaven National Laboratory New York. and the evidence will show that this work computer belonged to an individual named Jason Katz.

The evidence will also show that on this work computer was a forensic match [Special Agent Shaver said it was a different video at the Article 32] with the video charged in Specification 11 [Garani Video] the BE22 PAX. zip video was on this computer.

And, forensic examiners will testify that video was on the computer on 15 December 2009 [To clarify, Morrow means on Jason Katz's computer].

CID [missed word] also collected CENTCOM SIPRnet SharePoint logs.

And again your Honor. SharePoint logs are simply logs related to the SharePoint server at CENTCOM, where the staff and the employees of CENTCOM posted documents for collaboration. These logs show the downloading of 334 files on 10 April 2010.

Those files, the evidence will show related to an investigation into an air strike in Farah Province Afghanistan in May 2009.

The evidence will also show that none of the videos related to this investigation were downloaded on that day.

CID agents also collected a NIPRnet computer from the Supply Annex. As I stated earlier your Honor, that computer was collected because PFC Manning was moved there in early May 2010.

The evidence will show that-- that computer was used to download United States Forces - Iraq Global Address List.

And the evidence will show that the computer was used to essentially create two different files.

One file contained the emails of 74 thousand service members in Iraq. And the other file contained the personal information of approximately 74,000 service members.

Now your Honor, on the screen is a snippet of that-- the personal information file. [On the screen is displayed an slide.

I could not get the content of the presentation and transcribe at the same time.] The government is redacted or taken off the left side your Honor which are the last names of the individuals. In the full file your Honor, the evidence will show the full names [missed word].

PFC Manning also signed a number of non disclosure agreements throughout his time in the Army.

And, in these Non Disclosure Agreements the evidence will show that PFC Manning acknowledged his responsibilities upon being granted access to classified information. The evidence will show that PFC Manning acknowledged a special trust and confidence place on him by the United States government.

PFC Manning acknowledge the potential damage that could accrue from the unauthorized disclosure of classified information. PFC Manning acknowledged that classified information was the property of the Uni

ted States government. Finally, your Honor PFC Manning acknowledged that there were consequences to unauthorized disclosure. This Non Disclosure Agreement, your Honor, has already been admitted as Prosecution Exhibit 8.

just simply your honor the government notes that the evidence will show that PFC Manning acknowledged that he could be liable for criminal offenses under 18 United States Code 641 and 793.

PFC Manning signed that document on 17 September 2009. [I could not get the content of the presentation and transcribe at the same time. I believe it is the NDA he allegedly signed.]

Your Honor the evidence will show that WikiLeaks posted a Most Wanted List in 2009-- and specifically your Honor the evidence will show that PFC Manning made searches on a SIPRnet computer related to information that was also found on the Most Wanted List.

Specifically your Honor, on 28 November 2009 the evidence will show that the .40 SIPRnet computer searched for retention of interrogation videos.

And, your Honor, you have not seen this yet-- but, this is what the evidence will show to be a summary of the Intelink searches made throughout PFC Manning's deployment [I could not get the content of the presentation and transcribe at the same time.] This is an excerpt of that.

That search log. The Most Wanted List in 2009 sought information very similar.

Your Honor, the government would also like to highlight a few key witnesses to appear. Several of these witnesses you will hear from through out the trial.

First, Special Agent David Shaver lead a team of forensic examiners of the of the Digital Forensic Division [missed word] of the Army Computer Crimes. Special Agent Shaver-- the evidence will show is a leader in his field.

They conducted most if not all of the forensic examinations in this case-- as well as the examination of [missed word]. Mr. [Mark] Johnson was one of his forensic examiners he will testify regarding his examination of the personal laptop computer of PFC Manning as well as the external harddrive.

Special Agent Williamson will testify regarding his examination of the Supply Annex NIPRnet computer.

You will hear from one of PFC Manning's instructors at AIT, Mr. Mull. Mr. Mull is a retired all source intelligence analyst and he will testify that he provided training during AIT on classification of documents, handling the classified material, information security, and operational security, as well as training on the enemy's use of the Internet.

Your Honor, this is just a-- the evidence will show that this is just one of the slides PFC Manning was provided training on. [On the screen is a cartoon and a caption on the enemy's use of the Internet. I could not get the content of the presentation and transcribe at the same time.]

Now you will also hear from government officials from various agencies including the Department of Defense, Department of State, and other Government organizations. These witnesses will testify regarding the nature and the content of the charged information.

You will hear from original classification authorities from several of these agencies as well.

And they will discuss the classification of the documents that they reviewed. You will also hear from Mr. Lewis. Mr. Lewis, your Honor, the evidence will show is a Department of Defense Counterintelligence Expert with approximately 30 years of experience.

And, he will testify that there is a market for government information and specifically a market for classified information.

And he will also testify that that market is defined by thousands of dollars for just a handful of documents. Your Honor, you will also hear from several of the unit witnesses. So, witnesses that were in the S2 section and worked with PFC Manning. They will discuss the Iraq deployment.

They will testify regarding PFC Manning's work product and his skill sets and they will discuss and testify regarding the duties of an all source intelligence analyst.

During trial your Honor, the government's attempt to simplify complicated evidence by presenting evidence chronologically.

What the evidence will show is that PFC Manning arrived in Iraq 2009 or late October 2009-- began working regularly in the SCIF in mid November 2009, and then in late in November 2009-- less than two weeks after beginning work-- PFC Manning began helping WikiLeaks.

Again your Honor this is an excerpt of the chat logs of Adrian Lamo. [On the screen is displayed an slide.

I could not get the content of the presentation and transcribe at the same time.] The evidence will show that the first transmission of classified information that PFC Manning was a transmission in late November 2009.

And that transmission was the video charged in Specification 11 of Charge II [Garani video].

The evidence will show that this video was located on the CENTCOM SIPRnet SharePoint site under subfolders for CENTCOM legal, investigations, and Farah.

The evidence will show, your Honor, that this video was password protected-- meaning that it could not be opened without the password. And, you'll hear evidence from CID who traveled to CENTCOM inorder to collect the password.

You will also heard evidence your Honor that this same video-- a forensic duplicate of this video was on the work computer of Jason Katz on 15 December 2009.

This is also also an excerpt from the chat logs with Adrian Lamo, your Honor and the evidence will show that PFC Manning admitted to transmitting the Garani air strike video. [I could not get the content of the presentation and transcribe at the same time.]

This excerpt also shows your Honor that PFC Manning acknowledged that the video was already encrypted.

Jason Katz your Honor you'll hear evidence that is a-- was Department of Energy employee at Brookhaven National Laboratory in New York. And, forensic examiners will testify that password cracking software was found on this same computer.

Additionally your Honor the evidence will show that on 8 January 2010, WikiLeaks claimed that they had a copy of an encrypted video. This is evidence from WikiLeaks twitter feed that will be presented at trial.

As you can see your Honor the tweet was dated 8 January 2010.

The evidence will show your Honor that if you also click on the link there that leads to an article about the Farah or Garani air strike.

After the transmission of the single video your Honor. The evidence will show that PFC Manning moved on to much large databases-- specifically he moved on to the information charged in Specification 4 through 7, Charge II.

the evidence will show that in early January 2010, PFC Manning downloaded the entire Combined Information Data Network Exchange - Iraq database. The evidence will show that he accessed that database locally.

The evidence will also so that in this same time frame-- early January he downloaded CIDNE Afghanistan database. The evidence will show that in order to access that database he had to go through a server at CENTCOM.

You will hear testimony your Honor that both these CIDNE databases were only available on classified networks. In other words your Honor, the evidence will show that PFC Manning had to use his SIPRnet access to access these documents.

You will heard testimony that the reports identified in Specification 5 [CIDNE-I] and Specification 7 [CIDNE-A] were classified and your will hear testimony regarding the value of this information.

Your Honor you will also hear testimony from the forensic examiners relating to their examination of the SD card. And those examiners will testify that the metadata related to those files shows that the CIDNE-Iraq was packaged on 5 January and CIDNE-Afghanistan was packaged on 8 January.

Again your honor that is the metadata from the file on the SD card.

It is also helpful at this time your honor to go through sort of a timeline of early events. The evidence will show as I stated earlier that PFC Manning arrived in Iraq in November 2009.

On 21 January 2010, so approximately two weeks after the files related to the CIDNE databases were created evidence showed that PFC Manning left Iraq for R and R.

On the 24th of January 2010, the evidence will show that PFC Manning arrived in the DC area. And on the 25th of January 2010, the evidence will show that PFC Manning cleared his computer-- he wiped his computer of all the data and he reinstalled the operating system in his Apple laptop.

You will hear testimony your Honor from the forensic examiner who will discuss what wiping is-- but essentially no information on the personal computer can be recovered prior to 25 January 2010.

On the 26 of January 2010, the evidence will show that PFC Manning left DC for Boston. And, on the 31st of January 2010, the evidence will show that while in Boston, PFC Manning cleared his computer of all the data in the unallocated or free space.

The evidence will sow your Honor that that means that no data can be recovered from the deleted space prior to 31 January 2010.

Your Honor and on the first of January 2010, PFC Manning returned to DC. And, on the 11th February the evidence will show that PFC Manning returned to the Iraq created an encrypted file on his personal computer-- a strong box [missed word].

Approximately three days later your Honor, the evidence will show that PFC Manning returned to work and immediately began harvesting government information. This first day back in the SCIF your Honor, the evidence will show that PFC Manning began collecting and gathering information related to Iceland.

The evidence will show that WikiLeaks was based in Iceland, specifically Julian Assange.

The evidence will also show that on the 15 of February 2010 PFC Manning burned the document charged in Specification 14 of Charge II, the diplomatic cable Reykjavik 13. [Missed a few words] so evidence or data recovered from the unallocated space on PFC Manning's personal computer. As I stated earlier your Honor, Reykjavik 13 was on a disk inserted into PFC Manning's computer-- as well as other information related to Iceland.

In that same timeframe your Honor, the evidence will show that PFC Manning also on that same disk that contained Reykjavik 13 was the video charged in Specification 2 of Charge II commonly referred to as the Apache video [Collateral Murder].

This video your Honor the evidence will show was located on the Brigade SIPRnet shared drive-- under the SJ folder.

You will hear from a CENTCOM FOIA officer who will testify that the video was not released when CENTCOM released the investigation through FOIA related to this video.

You will also hear testimony your Honor that when the Apache video-- so when the 12 July 2007 video was initially released by WikiLeaks, it was released as an edited version and the evidence will show that PFC Manning was part of this editing process.

This email your Honor was recovered from PFC Manning's personal computer. [I could not get the content of the presentation and transcribe at the same time.]

You will also hear testimony your Honor from an Army aviator who will testify and explain how video could be useful to foreign adversaries.

Your Honor, the evidence will show that PFC Manning conducted research on WikiLeaks through out the deployment.

His first search for WikiLeaks on the SIPRnet the evidence will show was 1 December 2009. The evidence will show that prior to [missed word] 15 February 2010 PFC Manning researched WikiLeaks [missed word] on the SIPRnet.

[Missed a few words] your Honor that will be presented at trial, will show that PFC Manning conducted more than one hundred searches for WikiLeaks on the SIPRnet.

The evidence will also show your Honor that on 1 December 2009, PFC Manning first accessed the document charged in Specification 15 [2008 USACIC WikiLeaks Memo] of Charge II-- the ACIC document.

Your Honor on the screen are the excerpts from the SIPRnet search log on Intelink. [I could not get the content of the presentation and transcribe at the same time.] As you can see on 1 December the .40 computer searched for WikiLeaks.

That search your Honor, led to this report. Your Honor this is an excerpt of the document charged in Specification 15 of Charge II [2008 USACIC WikiLeaks Memo].

[On the screen is a portion of the 2008 USACIC WikiLeaks Memo. I could not get the content and transcribe at the same time.]

This report, your Honor, made several key judgements. Specifically it stated that recent unauthorized release of DoD sensitive and classified documents provide foreign intelligence services, foreign terrorists groups, insurgents, and other foreign adversaries with potentially actionable information regarding U.S. forces.

In short, your Honor the evidence of this document alone [missed word] that WikiLeaks was a source of intelligence for adversaries.

The evidence will show that this document had not been released publicly and was only available with individuals with access to the SIPRnet or higher, and additionally the evidence will show that it was marked top and bottom with classification [missed word].

In addition to the document Charged in Specification 15 of Charge II, the ACIC document. PFC Manning found another-- or other documents relating to WikiLeaks in the mid February timeframe [On the screen is a slide, the content of which I could not note, because I was transcribing but it related to the Marine Corps].

The evidence will show your Honor that this is an excerpt from the C-3 document [On the screen is a slide, the content of which I could not note, because I was transcribing but it related to the Marine Corps].

That document as well as an IIR, Intelligence Information Report, labeled WikiLeaks was on a CD inserted into PFC Manning's computer around 15 February 2010.

Again your Honor this is a excerpt of the mounting data recovered from PFC Manning's personal computer. [On the screen is a slide, the content of which I could not note, because I was transcribing.]

After this transmission of several documents, on 15 February 2010, the evidence will show that PFC Manning moved onto again or went back to large databases-- or Specifically the information charge in Specifications 8 and 9 of Charge II [GTMO Files]. On 5 March 2010 your Honor, PFC Manning attempted to download the Joint Task Force GTMO Detainee Assessment Database manually.

The evidence will show that PFC Manning stopped after downloading approximately 400 Detainee Assessments on 5 March. On 7 March the evidence will show that PFC Manning went back and downloaded the entire Detainee Assessment Database more than 750 records. The evidence will show that PFC Manning used a program named Wget to automate this process.

The chat logs with Julian Assange your Honor the evidence will show discussed this information. This excerpt from the chat log your Honor on 7 March, the evidence will show PFC Manning Julian Assange how valuable the memos are. [On the screen is a slide, the content of which I could not note, because I was transcribing.]

By the 8th of March your Honor, the evidence will show that PFC Manning already had a .csv that organized the info as much as possible.

Again, this is an excerpt from the recovered chat logs on PFC Manning's personal computer. [On the screen is a slide, the content of which I could not note, because I was transcribing.]

You will hear testimony your Honor that the Detainee Assessment was marked on the top and bottom with classification and you will hear testimony from the intelligence analyst who maintained this database and wrote many of the assessments.

He will testify that these Detainee Assessment were only available on the SIPRnet and higher and these assessments had not been released to the public.

In this same timeframe your Honor, and now I am referring Specification 2 of Charge III [adding unauthorized software to a Secret Internet Protocol Router Network computer]. The evidence will show that PFC Manning-- I'm sorry, excuse me-- this time frame is the first known use of the program named Wget.

You will hear testimony your Honor that Wget is free software available on the Internet, and it is used to rapidly download information from web servers.

And you will also hear testimony that the Acceptable Use Policy prohibited the addition of Freeware or Free Software and executables on government information systems.

As you can see your Honor that is an excerpt of the Regulation you have taken judicial notice of AR [Army Regulation] 25-2. [Displays on screen.]

And, that is an excerpt of the Acceptable Use Policy. [Displays on screen.]

In the same timeframe your Honor the evidence will show that PFC Manning with the help of what the evidence will show to be Julian Assange attempted to devise a way to browse SIPRnet anonymously.

On the screen your Honor is an excerpt of a chat log-- again these are the chat logs recovered from PFC Manning's personal computer-- and the evidence will show PFC Manning asked, 'Any good at LM hash cracking?' LM, the evidence will show, stands for Land Management.

Pressassociation responds, 'We have rainbow tables for LM.' Your Honor the evidence will show that an LM hash is essentially the way that a Windows computer stores passwords on that computer.

It doesn't store the passwords as your know, one, two, three, four, five-- it stores it as a hash value. Special Agent Shaver will testify that the hash value-- the second line from the bottom [On the screen is a slide, the content of which I could not note, because I was transcribing] is a system file on the SIPRnet computer of PFC Manning-- a system file related to the attachment for the administrator account.

Hash cracking your Honor is essentially reverse engineering the password.

And then late in March 2010-- in early May 2010 your Honor-- early April 2010, PFC Manning went back to large databases.

And in this case your Honor, the evidence will show that PFC Manning used Wget to systematically harvest more than 250,000 Department of State diplomatic cables.

The evidence will show that 251, 287 purported Department of State cables released by WikiLeaks.

This activity occurred between 28 March and early April 2010 and Special Agent Shaver will testify regarding his examination of the firewall logs related to the Department of State. And, he will testify that between PFC Manning's SIPRnet computers and the firewall logs were more than 700,000 connections in this timeframe.

250,000 diplomatic cables your Honor that is 25,000 cables a day, more than 1,000 cables an hour. And the evidence will show that this process was automated.

The evidence will show that Wget and programs like it were prohibited by the Acceptable Use Policy signed by every service member who has access to a government information system.

And what Wget does, it that it bypasses the normal mechanism for accessing these cables-- click, open, save. The evidence will show that Wget offers a technical boost for downloading large amounts of information from web servers.

The evidence will show that there was a literally-- the day after this download of information was completed-- this initial download of 250,000 cables-- PFC Manning went back to the CENTCOM SIPRnet SharePoint.

The evidence will show that the logs from this SIPRnet SharePoint site show the entire 15-6 related to Garani Air strike investigation were downloaded-- approximately 334 records.

Again your Honor, these logs also show that none of the video related to this air strike were downloaded on that same day.

And Special Agent Shaver will testify regarding log evidence.

Again, your Honor, this is an excerpts from the chat logs between PFC Manning and Adrian Lamo. [On the screen is a slide, the content of which I could not note, because I was transcribing.]

You will hear testimony your Honor that these documents were located in a folder devoted to the investigation.

The investigation was only available on SIPRnet. These documents had not been released publicly and they were marked with classifications.

On May 4, your Honor, the evidence will show that PFC Manning, was having trouble with Wget on his computer.

And so, the evidence will show that PFC Manning went back to the NIPRnet downloaded Wget again and moved it from a NIPRnet computer to SIPRnet computer in the SCIF. On the same day, your Honor, the evidence will show that PFC Manning used Wget again to download and additional approximate 11,000 cables-- again from the Department of State NetCentric Diplomacy database.

This is the excel spreadsheet that I showed you earlier your Honor. A back up that was found on PFC Manning's .22 computer.

Again, your Honor, 251, 287 cables-- purported cables were released by WikiLeaks. [On the screen is a slide, the content of which I could not note, because I was transcribing] These are the next cables in line.

And that file of Department of State cables the evidence will show was burned onto a CD in the SIPRnet and moved to PFC Manning's personal computer. Again this is the mounting data recovered from PFC Manning's personal computer. [On the screen is a slide, the content of which I could not note, because I was transcribing].

Shortly after this download, your Honor, the evidence will show that PFC Manning was moved to the Supply Annex from the SCIF. At this point, your Honor, the evidence will show that PFC Manning did not have access to the SIPRnet. He worked for the Supply Sergeant, Staff Sergeant Peter Bigelow. And on 7 May your Honor a tweet from WikiLeaks sought more information.

That tweet your Honor, released 7 May, asked for a list of 'as many .mil email addresses as possible.' [Displays.] And that tweet was release 7 May 2010.

Around 11 May 2010 the evidence will show that PFC Manning extracted the email addresses and personal information of more than 74,000 service members in Iraq.

The names, the email addresses, the ranks, the positions of everyone in the United States Forces - Iraq Global Address List.

Special Agent Williamson will testify that between the two files extracted from the GAL are more than 2,000 pages of printed material.

Again your Honor is one of the excerpts from one of the files containing personal information. [On the screen is a slide, the content of which I could not note, because I was transcribing].

And the real file your Honor, the evidence will show contains the entire name. The government has, your Honor, redacted the left.

These two files your Honor, the one file containing email address, and the other containing personal information were both moved to PFC Manning's computer.

You will hear testimony form the examiner who examined PFC Manning's computer and you will also hear testimony related to the value of this information.

Mr. Lewis, a counterintelligence expert, will testify that by providing this type of personal information you are providing foreign intelligence services with essentially a phone book.

And Chief [Phonetically 'Bre-Are'] will testify that adversaries that spearfish. So, essentially spearfishing is the act of using a targeted email to obtain financial information or other personal information from individuals, use these types of list to target individuals.

You will also hear testimony from an Information Assurance expert, who will discuss the provisions of regulations and the appropriate uses of government information systems.

Finally your Honor, the evidence will show that the accused knowingly gave intelligence to the enemy.

As discussed earlier your Honor, the evidence will show that PFC Manning searched for WikiLeaks more than 100 times on the SIPRnet.

The evidence will show that he understood the nature of the organization.

The search he made on 1 December 2009-- the search for WikiLeaks-- the evidence will show lead him to this document in particular-- the document charge in Specification 15 of Charge II [2008 USACIC WikiLeaks Memo].

The evidence will show that PFC Manning's training warned him repeatedly of the enemies use of the Internet writ large and PFC Manning's research warned him of the enemy's use of WikiLeaks.

And he was right. You will hear that enemies of the United States reviewed information provided by PFC Manning.

You will hear evidence that during the raid that killed Osama bin Laden, government officials collected several items of digital media.

On one of these items of digital media was the entire CIDNE-Afghanistan database as released by WikiLeaks as well as State Department information.

The evidence will show that bin Laden asked for this information and was in turn provided this CIDNE reports by a known member of Al Qaeda.

Your Honor the evidence will show that PFC Manning worked daily in an area and on systems devoted to protection of classified information. the evidence will show that pfc manning knew the difference between open source information and information that if release that could cause damage to national security or to the advantage of another country.

And the evidence will show that if he wasn't sure he was required to check with someone. The evidence will show that PFC Manning knew the danger of unauthorized disclosure to and organization lie WikiLeaks and he ignored those dangers.

At the close of evidence after PFC Manning acknowledged that the nature of the information is apparently-- after the court is in full appreciation of the forensic evidence revealing PFC Manning's intent, the government is confident you will find tat PFC Manning committed the remaining offenses as charged. Thank you.

Donate via WePay

Donate Bitcoins

Categories