The Case Against John Bolton & My Lawsuit Against the White House (LegalEagle's Law Review)

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I like LegalEagle and I'm interested in seeing where this goes, but I'd hardly call him leftist. Helping hbomberguy with some issues does not a leftist make.

👍︎︎ 11 👤︎︎ u/ant_guy 📅︎︎ Jun 25 2020 đź—«︎ replies
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- Donald Trump's law firm, and by that I of course mean the US Justice Department, is suing to block the publication of John Bolton's book "The Room Where it Happened." Yes for the title of the book, Bolton and his publisher ripped off the lyrics from the musical Hamilton. Whereas Hamilton tells the inspiring story of the founding of America, Bolton's book tells the tale of a mustachioed government official who has damning information about the President of the United States, but writes a book instead of testifying at the president's impeachment trial. Now with a book being released, President Trump is calling Bolton names while Bolton is doing dumb things that will probably make it impossible for him to get paid from proceeds of the book. - There really isn't any guiding principle that I was able to discern other than what's good for Donald Trump's reelection. - Which makes one wonder why he didn't testify in the impeachment trial at all, and instead waited to put it all into a book itself. There are no heroes here in the story, but there are important questions at the heart of this dispute. Did Bolton willfully disclose classified information that could compromise national security? Or did the Trump administration abuse the classification process to protect Trump's personal interests? Or is the answer both? We simply don't know exactly what happens during the pre-publication review process of Bolton's book. And as I explained in another video, that's exactly why Legal Eagle has filed a FOIA request for information about the pre-publication review of Bolton's book, and that's also why I'm filing suit against the White House. Because the public has a right to know what happened and we hope to shed some light on it through the public records requests. But in this video, I wanna break down the DOJ's lawsuit and the motion it filed for an injunction to stop publication of John Bolton's book. And I'll also let you in on a big secret. I also filed a petition asking the government to declassify all of the things they just told the court our government secrets. Hey Legal Eagles, it's time to think like a lawyer because John Bolton is trying to tell his story and the government is trying to stop him. The first legal question posed by the DOJ's lawsuit is whether John Bolton violated his non-disclosure agreements by disclosing classified and sensitive information. The government wants two things from this lawsuit. Number one, it wants an injunction against the planned June 23rd publication of Bolton's book "The Room Where it Happened: A White House Memoir". And two, a constructive trust that would give the United States the right to all of Bolton's profits from this book. So let's break this down piece by piece. First, let's talk about the NDAs, the non disclosure agreements. The government is suing Bolton for breach of contract. According to the complaint, the contracts in question are non-disclosure agreements, otherwise known as NDAs that Bolton signed on April 5th 2018, when he entered government service as the National Security Advisor. Despite what you may have read, it's not unusual for National Security employees to sign NDAs. In fact, it's generally required. The government started requiring employees to sign secrecy agreements in 1947. Today, every US intelligence agency imposes a lifetime pre-publication review requirement on at least some subset of former employees. The agreements have generally prohibited employees from publishing manuscripts without first obtaining the agency's consent. In 1988, divided Supreme Court decided Snepp versus United States which affirmed the imposition of a constructive trust on proceeds earned by a former CIA officer who would publish the book without submitting it for review. So when a former employee wants to write a book, they have to go through this pre-publication review. They have to give the manuscript to the government so that they can review it for potentially sensitive or classified information. And when a person secures pre-publication clearance, he or she can publish without liability and keep all the profits from that book. But in a situation where someone like Bolton publishes without clearance, the government can ask that the courts establish a constructive trust, meaning that the government gets all of the money that the person would have made because of the publication. Bolton signed two agreements which are now the subject of this lawsuit. In the first NDA, Standard Form 312, Bolton agreed that he must never quote, divulge classified information to anyone, end quote, unless he either quote, officially verifies that the recipient has been properly authorized by the United States government to receive it, or he's received prior written notice of authorization to divulge it from the United States government. Specifically the entity responsible for that information's classification, which sometimes can get dicey when you have people in different departments, all of those different departments may have to conduct some sort of pre-publication review. And generally speaking, that means that the employee needs permission first. The second NDA, Form 4414, covers Bolton's access to a more sensitive subset of classified information, commonly known as sensitive compartmented information or SCI. You can imagine that as the National Security Advisor, Bolton had access to the most sensitive government information available. The terms of his NDA require Bolton to submit to a security review by the National Security Council, any writing that contains SCI or activities that relate to SCI. Bolton also agreed that he would quote, not disclose the contents of any SCI-related material with anyone who is not authorized to have access to it until he received written authorization from the quote, department or agency that last authorized my access to SCI that such disclosure is permitted. Okay, so now that we know Bolton has to go through this pre-publication review before he can disclose anything that is classified or that is SCI or even related to SCI to anyone, what did he do with his manuscript? Well, when Bolton left his employment in September of 2019, he wrote a manuscript which he believed did not contain classified information. On December 30th 2019, Bolton's lawyer submitted the manuscript for pre-publication review. The manuscript was sent to Ellen Knight, the NSC Senior Director for Records Access and Information Security Management. This is the NSC entity that usually does classification and pre-publication reviews for the National Security Council. Less than a month later, Knight sent the manuscript back to Bolton having identified a number of things that she claimed were classified. This started a three-month process between Bolton and Knight in which they negotiated many of the changes to the manuscript in order to assure that in Knight's view, it wouldn't contain any classified information. And one of the quirks about the pre-publication review process is that you're technically not even allowed to show the manuscript to your lawyer. I mean, you can but you're not supposed to, they don't have the same kind of clearances, and you can get in big trouble if the lawyer is the one that's negotiating it instead of the client. So often, these people are completely unrepresented, as they are going back and forth in negotiating things with the government. And in this case, Bolton and Knight met several times and also corresponded in writing. By April 27 2020, Knight quote, had completed her review and was of the judgment that the manuscript draft did not contain classified information. Knight told Bolton her review was final and all they were waiting for was the official letter confirming the end of the pre-publication review. But then the current National Security Advisor, Robert O'Brien became concerned that the manuscripts still contain classified information even after Knight's review. O'Brien allegedly asked Michael Ellis, the NSC's Senior Director for Intelligence, to do another review of the manuscript. Unlike Knight, Ellis is a political appointee. Ellis was also allegedly involved in the decision to classify President Trump's July 25th 2019 call with Ukrainian President Volodymyr Zelensky in the White House's most secure classified computer system. Remember that whole thing about the Ukrainian scandal? Apparently Ellis was involved in potentially corrupt action to hide the transcript of that call with other members of the administration. It feels like a lot has happened since then but you might recall that that call with Zelensky later became an issue in President Trump's impeachment trial. At any rate, by June 8th, the government had reversed course and informed Bolton that the manuscripts still contain classified information. But the government did not identify the information that it contended was secret. On June 10th, Bolton's lawyer told the government that in Bolton's opinion, it did not continue any prohibited information and that the book had been printed and shipped to distributors. On June 16th 2020, the NSC sent Bolton a marked copy of the current version of the manuscript identifying passages that Ellis thought appeared to contain classified information. The book as of the time of this video, was scheduled for publication on June 23th 2020. So given that John Bolton is trying to publish his book before the end of the pre-publication review process, whether that process was conducted in good faith or not, it's not surprising that the Department of Justice is suing Bolton for breaching the two NDAs. And the government is asking for four kinds of relief. Number one, enjoining Bolton from taking any steps towards publicly disclosing the information in "The Room Where it Happened" without first obtaining written permission. Two, requiring Bolton to delay publication and instruct his publisher to do the same. Three, imposing a constructive trust that would give the United States the right to all the profits that Bolton gets from his book. And four, declaring that the court's order prohibiting disclosure of the information will bind the publisher, Simon & Schuster, and any other party in the commercial distribution chain, even if they aren't actually named in the lawsuit. Now, violating an NDA creates a breach of contract claim, and a breach of contract claim in the national security context is a lot more complicated than when a company sues an ex-employee for violating an NDA. But what they do have in common is the need to determine what information is within the scope of the agreement. The government has the burden of proving that the book contains information that was within the scope of the NDA. And pre-publication review covers more than just classified information. Many agencies require unclassified information to be redacted as well. And since the National Security Council just does this on an ad hoc basis, there's no reason to believe that they limited their redactions to simply classified information, so who knows what they required John Bolton to remove from his book. But under Executive Order 13526, what is covered by the NDA is incredibly expansive. Under Section 1.1, the government must show that the unauthorized disclosure of information in Bolton's book, quote reasonably could be expected to result in damage to the national security, end quote. This means that the government must prove that the information has been properly classified. And the term national security is defined to include the national defense or foreign relations of the United States. This is a pretty vague term that could encompass almost anything and the court in the Bolton case will need to review the information to determine if the agency was acting in good faith when it classified that material. But according to a case from the Fourth Circuit Court of Appeals, a court will give deference to the government but at the same time, it has to review the material to ensure that the reviewing agency had a good reason to classify that particular information. The court observed in that case that courts should require that agency explanations justify censorship with reasonable specificity, demonstrating a logical connection between the deleted information and the reasons for classification. They should not rely on a presumption of regularity if such rational explanations are missing. The court anticipated that in camera review of affidavits, followed if necessary by further judicial inquiry, will be the norm. Courts must assure themselves that the reasons for classification are rational and plausible ones. And in a footnote to that decision, the court suggested that the government may be held to a higher standard if an agency seeks an injunction against publication of the censored items. For better or worse, no court has considered the injunction issue yet and generally speaking, courts are loath to give what's called a prior restraint, where the government prevents speech from being made before that speech has made. That generally carries with it the highest burden under the First Amendment. But can the government prove that it made a rational and plausible classification decision in Bolton's case? It's possible. The biggest factor against the government is that Knight told Bolton that the book did not contain classified material. However, at that time, he hadn't received final clearance for publication and sometimes government employees, sometimes even the same ones, change their mind about these things. And so let's look to the actual terms of the NDAs that Bolton agreed to sign on to. When Bolton signed Form 312, he agreed that he was uncertain about the classification status of any information and therefore, he must get agency clearance before disclosing it. Bolton will argue that he was not uncertain about the classification status of the material in his book. Number one, because he knows the material, number two, he got the green light from Knight. However, this presents a problem for Bolton because the government alleges that Bolton is the one who decided to classify some of the material that he now discloses in his book. It's possible that Bolton will argue that he actually improperly classified some of that information which of course makes him look pretty bad. But if the government is correct, then Bolton breached his obligations under Form 312, not to disclose material without pre-publication review and authorization. But it's also possible that the pre-publication review process was a complete sham done by political appointees for political reasons to punish Bolton as opposed to protecting the disclosure of actually classified information. But turning to Form 4414, Section Five of the NDA states, I understand that the purpose of the review described in paragraph four is to give the United States a reasonable opportunity to determine whether the preparation submitted pursuant to paragraph four sets forth any SCI. He also must get pre-clearance of any writing that describes activities that relate to SCI. Since Bolton did not get written authorization before publishing, the government has a good argument for constructive trust. And constructive trust is a lot easier to get instead of actually censorship of the material itself. It's a lot easier for the government simply to punish people for disclosing the information than it is to prevent that information from getting out in the first place. So that takes us to the government's emergency motion. The second legal question in this case is whether President Trump can stop Bolton's book from being published. The DOJ filed an emergency motion for an injunction against publication of the Bolton book on the basis that it contains classified information, this is otherwise known as a temporary restraining order. Tellingly, the lawsuit was filed against Bolton and not the publisher of the book Simon & Schuster. But the government cites Federal Rule of Civil Procedure 65d, which states that an injunction binds not only the parties, but also the officers, agents, servants, employees and attorneys and all the persons who are in contact into actual notice of the injunction. The DOJ contends that if the court grants the injunction, that it should also bind the publishers and ultimately the booksellers, and probably everyone else including journalists as well. So let's talk about the law of prior restraint because this is coming up fairly often. In First Amendment law, prior restraint is government action that prohibits speech and other expression before the speech actually happens. It's considered the most serious form of government censorship and therefore the government bears a heavy burden when it seeks to stop something from being published. And at first glance, the motion here appears to be based on the standards set forth in the Pentagon Papers case which played a role in Watergate, and I've covered that case many times on this channel. But in quick summary, the Pentagon Papers was the name given to a top secret Department of Defense study of the US political and military involvement in Vietnam from 1945 to 1967. The government military analyst, Daniel Ellsberg, who had worked on the study came to oppose the war and decided that the information contained in the Pentagon Papers should be available to the American public. So he photocopied the report and in March of 1971, gave a copy of the Pentagon Papers to the New York Times, which then published a series of scathing articles based on the contents. The Pentagon Papers showed that the Vietnam War was unwinnable and that Nixon, Johnson, Kennedy, Eisenhower and Truman had all misled the public about America's role in Vietnam. In that case, the DOJ sued to stop further publication of the classified material. But the Washington Post and the New York Times fought the DOJ and Supreme Court ruled that the government had failed to prove harm to national security, and that publication of the papers was justified under the First Amendment's protection of freedom of the press. In that case, the government could not overcome the heavy presumption against prior restraint of the press. And justices Black and Douglas argued that the vague word security should not be used to abrogate the fundamental law embodied in the First Amendment. And the Supreme Court stated, "The guarding of military and diplomatic secrets "at the expense of informed representative government "provides no real security for our republic. "The framers of the First Amendment fully aware "of both the need to defend a new nation "and the abuses of the English and colonial governments "sought to give this new society strength and security "by providing that freedom of speech, press, religion "and assembly should not be abridged." And because of those principles and that language, there's only been one significant example of a successful government injunction, and that was in 1979, where the US Department of Energy sued The Progressive magazine to prevent an article written by an activist that revealed how to make a hydrogen bomb. Although the government did not allege that the article posed immediate or inevitable danger, the Department of Energy did say that the article would increase the risk of thermonuclear proliferation. And that was enough for a US District Court to find that the security of the US and the world would be at risk, stating that, a mistake in ruling against the United States could pave the way for thermonuclear Armageddon for us all. In that event, our right to life is extinguished and the right to publish becomes moot. And therefore, publication could indeed cause quote, grave, direct, immediate and irreparable harm to the United States. Thereby meeting the test, the Supreme Court had enunciated in the Pentagon Papers case. And although the government got its injunction at the district court level, the trial court, it abandoned the case when it appealed because it turns out the information about how to build an H-bomb was already known and widely disseminated. And so if there was no secret, then there was no reason for the censorship. So does anything in Bolton's book rise to the level of national security secret established by the Pentagon Papers case or the hydrogen bomb case? Well, the government says yes, quote, unlike ordinary confidential information the government holds, the information at stake here is classified including some instances at the secret or top secret SCI levels, which means by definition that its disclosure reasonably could be expected to cause serious damage or exceptionally grave damage to the national security of the United States. That comes from the Ellis Declaration sworn under penalty of perjury that was filed with the court. And in Mr. Ellis's judgment, certain passages, if disclosed, quote, will damage the national security of the United States. In support of equating John Bolton's disclosures with an H-bomb, the DOJ filed several declarations from Ellis and other officials, explaining that the consequences of disclosure would be quote, grave. The Department of Justice filed several classified in-camera declarations describing the supposedly classified portions of Bolton's manuscript. But they did not file a declaration from Ellen Knight, the first official who reviewed John Bolton's book and allegedly said that it didn't contain any classified or prohibited information. We don't have any testimony from her under oath, and this is telling. That takes us to an interesting quirk known as Mandatory Declassification Review. It's probably good in this case to be skeptical of the government's declaration that all secrets pose grave threats to national security, regardless of whether the President is Donald Trump or Joe Biden or somebody else. And in these circumstances, courts should hold the government to a very heavy burden before restraining freedom of the press, especially in a case like this, where the horse has already left the barn. And newspapers are already publishing information from Bolton's book and he's already taped a TV interview. - I don't think he's fit for office, I don't think he has the competence to carry out the job. - And remember, if there's no secret, there's generally no justification for censorship, putting aside the issue of getting all of Bolton's profits. And this is just one of the reasons why I personally, through Legal Eagle, has filed for a Mandatory Declassification Review of the classified declarations filed by the government on June 17th. Mandatory Declassification Review, also known as MDR, is a means by which any individual or entity can request any federal agency to review classified information for declassification, subject to certain limitations. The request has to describe the document or material containing the information with sufficient specificity to enable the agency to locate it with a reasonable amount of effort. And thankfully for us, the DOJ has made that really easy, since all the agency has to do is go through the same material that it just filed in support of the temporary restraining order. This will probably take some time and could involve a lawsuit and an appeal of whatever decision the DOJ makes, but Legal Eagle is committed to seeing this project through, including through litigation. So if President Trump's administration is playing games with classification, and there has been plenty of indication of this in the past, then I think we ought to know about it. President Trump recently claimed that every conversation with him is classified. - Even conversations with me, they're highly classified, I told that to the Attorney General before. I will consider every conversation with me as President, highly classified. - And this is absolutely not the way any of this works. And as for what happens next, the court is going to review the classifications and determine if it had good reason to classify and therefore censor the material at issue. So with that background of the entire John Bolton saga, let's talk about the government's emergency motion for a temporary restraining order, because we now know how this at least preliminary portion of this case ends. Now, a TRO is a court order to do or not do something for a short amount of time, generally only for a few days or a few weeks until the court can have a full hearing on what's called the preliminary injunction. A preliminary injunction is a similar order that generally lasts throughout the entire length of the particular case, and at the end of the case, there is a permanent order that orders the parties to do something or not do something. Now, a TRO, because it is an emergency motion with a very, very short timeline, generally has the highest burden of all of those different injunctions. Because you don't get much time to present evidence, you don't get much time to show that things are such an emergency that they require this temporary restraining order. So in order to get a TRO, you need to do four things. You have to show, one, a substantial likelihood of success on the merits, that means that you're likely to win the case when it actually gets to the merits of the case. Number two, you have to show that you would suffer irreparable injury if the injunction is not granted. Now, generally, money damages are not irreparable injury, you have to show something that absolutely cannot be properly compensated in the absence of this injunction. Number three, you have to show that the injunction will not substantially injure other interested parties. And number four, you have to prove that the public interest will be furthered by the injunction. Now, that is a very, very high burden, especially on just a couple of days notice which is generally what happens when you ask for a TRO. And here, the judge in this particular case, Judge Lamberth, decided that the government was likely to win on the NDA issue. The judge thought that it was likely, though certainly not certain, that John Bolton had published classified information. And that was after an in-camera review, meaning that the court behind closed doors actually looked at the evidence that was presented to the judge in this particular case, and the judge thinks that Bolton probably published classified information. The judge also found that the NDAs prohibit disclosure of this kind of classified information and thinks that Bolton likely violated those NDAs by publishing his book. But that's just the first factor of the TRO, that the government is likely to succeed on at least a portion of the merits going forward. But a single factor isn't enough to get a TRO and here, the judge went on to the second factor and found that the government had not proved irreparable harm. In a case like this, the information is already out there, the information has been published. The book is out there, it's in the hands of a whole bunch of reviewers and the news media has access to the book, you can get access to it. So because the information is already out there, the harm has already occurred and an injunction isn't going to solve anything and the government isn't likely to suffer irreparable harm as a result of not granting a temporary restraining order. So the judge denied the TRO and this case will go on, eventually there will be a hearing on the preliminary injunction and eventually there will be a full hearing on the merits of the case, which is going to be a complicated trial about what John Bolton knew, what information is classified, whether the information itself that Bolton included in his book was classified or not. And interestingly, the judge specifically left open the possibility of criminal charges against Bolton, the judge is not screwing around in this particular case. So let's talk about those potential criminal charges. Well, the restraining order against Bolton is a civil case. He could in fact face criminal charges if the DOJ decides to prosecute him over the information he's included in his book. There are many different laws prohibiting mishandling or disclosure of classified material, for example, 18 USC 1924 which states, "Whoever being an officer, employee, contractor "or consultant of the United States, "and by virtue of his office, "employment position or contract "becomes possessed of documents "or materials containing classified information "of the United States, "knowingly removes such documents or materials "without authority and with the intent "to retain such documents or materials "at an unauthorized location shall be fined under this title "or imprisoned for not more than five years or both." And this has happened before. Former CIA Director, David Petraeus, pleaded guilty to mishandling classified information simply because he gave it to his biographer, even though she didn't use the information in his book. And Bolton made a major faux pas in how he dealt with the pre-publication process, because the government's complaint alleges that Bolton violated his obligations under the NDAs by sharing classified information, quote, numerous times before his book was published and printed, just by discussing it with his lawyer, publisher and members of the news media. It's kind of crazy that these laws exist, but those laws do exist. And publication can mean giving potentially classified information to anyone the government has not pre-approved to receive it. And Bolton's lawyer admitted to reviewing the information in an article that he wrote for various newspapers. And the NDAs don't allow Bolton to share classified material with anyone, not a publisher, not a lawyer, not as friends and not the media. So in this case, what should Bolton have done? Well, we're going to find out and I'm actually going to make sure of that because this is the first time that Legal Eagle is branching out into activism. Because these are unprecedented times and the information that Bolton knows and tried to publish may strike at the heart of the impeachment trial and what President Trump was accused of doing with respect to potentially using taxpayer money in order to extort a foreign power to help him in an election. And because this is so important, Legal Eagle filed FOIA request with the government and the government has so far stonewalled us, which has caused us to file suit against the government. Now, if you wanna know more about the FOIA requests and the suit that I filed against the government concerning John Bolton and this whole affair, I will drop a link in the description to that video, I'll go into more depth about that particular video. But like any good lawyer, I'm getting help from the best. And this would not be possible if it weren't for the National Security Counselors and Executive Director of the National Security Counselors, Kell McClanahan, who are some of the best national security lawyers in the country. They're going to be handling this litigation on Legal Eagle's behalf. I am not a national security lawyer so I teamed up with the people who are. And the National Security Counselors is a 501c3, so if you'd like to see this litigation through, it would mean the world to us if you would consider donating to the firm. Lawyers and litigation are expensive and we are committed to taking this litigation to the mat. There's a link in the description to a place where you can donate to the National Security Counselors. And hopefully this won't be a one-off piece of litigation. If it becomes necessary again, it would be great to have the infrastructure in place to file a similar lawsuit in the future. And any donations that are made above the cost of this litigation will go towards the other charitable work of the National Security Counselors, which includes not just representing YouTubers and YouTube channels, but also goes towards representing whistleblowers, representing other journalists who are making FOIA requests and enforcing those FOIA requests, suing to strike down anti-transparency policies and practices and advocating for pro-transparency and accountability in the government. So if you would consider donating, I would greatly appreciate it, the donation is tax deductible. And I think this is important because sunlight is the best disinfectant and there might be really important information that really should see the light of day. So check out that link, check back on the channel for updates about my lawsuit against the government, including the White House, the CIA, the Department of Justice, the Department of Defense and a whole bunch of others. And it's my hope that together, we can actually make a difference on this thing and expose information that the government doesn't want us to see in this particular case.
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Channel: LegalEagle
Views: 974,973
Rating: 4.8795471 out of 5
Keywords: Legaleagle, legal eagle, breaking news, case, congress, court case, crime, guilty, jury, latest news, news, not guilty, political, politics, politics news, scotus, supreme court, the trial, trial, Verdict, copyright, law advice, legal analysis, lawyer, attorney, Real lawyer, Real law review, Bolton, suing, sued, white house, cia, doj, I sued, I’m suing, FOIA, bolton book, bolton interview
Id: D8a2SDw5PYo
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Length: 29min 22sec (1762 seconds)
Published: Thu Jun 25 2020
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