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To: Cboldt
The demand for discovery of information does not necessarily have to be admissible as long as it may have a tendency to lead to admissible evidence.

The documents sought by this motion are just as important to Mr. Libby’s defense. Here, we request documents concerning former Ambassador Joseph Wilson’s Case 1:05-cr-00394-RBW Document 68-1 Filed 03/17/2006 Page 5 of 39 2 trip to Niger, and his wife’s involvement with that trip, ie:2. All documents or communications reflecting any possible attempt or plan by any government official to punish or seek revenge against Mr. Wilson or Ms. Wilson. 3. All documents reflecting Mr. Wilson’s communications with officials at the State Department or other government agencies concerning his trip to Niger or the “sixteen words.”

The prosecution has an interest in continuing to overstate the significance of Ms. Wilson’s affiliation with the CIA. Doing so makes it easier to suggest that Mr. Libby would not have forgotten or confused his conversations concerning Ms. Wilson and has therefore intentionally lied. The defense has requested: 2. All documents or information concerning the identity of any government official outside the CIA who was aware prior to July 14, 2003 that Ms. Wilson worked for the CIA.

The defense's case:

Mr. Libby had no intent to lie because he did not believe that Ms. Wilson’s employment status was classified. Second, Mr. Libby was not part of a conspiracy to harm Mr. Wilson by disclosing his wife’s CIA affiliation and thus had no reason to cover up such involvement. Third, Mr. Libby did not believe anyone who worked closely with him had done anything wrong and thus had no motive to lie to protect anyone else.

35 posted on 03/20/2006 8:38:35 AM PST by street_lawyer (Conservative Defender of the Faith)
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To: street_lawyer
Mr. Libby had no intent to lie because he did not believe that Ms. Wilson's employment status was classified.

LOL. I find that assertion to be laughable. The President says "This is a serious leak and the leaker will be punished," and Libby says "IF she wasn't covert, I had no motive to lie."

Fitzgerald says that there is no evidence that Libby knew or thought Plame was covert, FWIW - that is, Libby and Fitz actually AGREE on this point.

Second, Mr. Libby was not part of a conspiracy to harm Mr. Wilson by disclosing his wife's CIA affiliation and thus had no reason to cover up such involvement.

Methinks he protests too particularly here. There is no charge of an attempt to damage Wilson's credibility, hence no conspiracy to provide cover for.

56 posted on 03/20/2006 9:36:13 AM PST by Cboldt
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