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diplomacy



I sure hope the following was diplomatic enough.

NSA exhibited NO SENSE OF HUMOR when I pointed out
'deficiencies' in its crypto algorithm work.  But, too,
the agrieve Islamic fundamentalists may not have too good
senses of humor.

But with that experience, my sensitivities are hightened.

Later, guys.

Back to POSTCARD COMMUNICATIONS!

Sunday 1/18/98 6:24 AM

Jim Allen

Thanks for the call on Friday night.

You said that there might be a problem in the way the interrupts
were turned on.

I told you I would give this some thought.

Here is the routine to turn on the interrupts

;*	Call DasIntOn(IoPointer&, ErrorFlag&, SystemState&, IoData&(0, 0),
;*	IoParm&(0, 0), LgradThres) from Visual Basic.

DasIntOn	PROTO FAR, VBIoPointer:dword, VBErrorFlag:dword,
VBSystemState:dword,
			   VBIoData:dword, VBIoParm:dword, VBLGradThres:dword

DasIntOn	PROC FAR EXPORT, VBIoPointer:dword, VBErrorFlag:dword,
VBSystemState:dword,
				  VBIoData:dword, VBIoParm:dword, VBLGradThres:dword
                Prolog

;* Stage 1	Get addresses of IOPointer, ErrorFlag, SystemState,
;*		IoData, IoParm, LGradThres which point back into VB static array.

		mov eax, VBIoPointer	; get VB IoPointer address
		mov IoPointer, eax	; move it to asm
                mov eax, VBErrorFlag    ; get VB ErrorFlag address
		mov ErrorFlag, eax	; mov it to asm
	        mov eax, VBSystemState  ; get VB SystemState address
		mov SystemState, eax	; move it to asm
                mov eax, VBIoData       ; get VB IoData address
                mov IoData, eax      	; move it to asm
		mov eax, VBIoParm	; get VB IoParm address
		mov IoParm, eax		; move it to asm
		mov eax, VBLGradThres	; get VB LGradThres address
		mov LGradThres, eax	; move it to asm

;* Stage 2	zero the interrupt counter and system state

		mov IntCount, 0
                            mov LocalSysState, 0

;* Stage 3  install dummy interrupt vector

		call SetDummyIntVector	  ; Set dummy IrqLevel interrupt

;* Stage 4  make sure interrupt is masked on the das board

		call DisableDasInt

;* Stage 5  Set up Irq level in bits 4-6 of register 9

		call SetDasIrqLevel

;* Stage 6  set up counter 0 with number of rows AND enable
;* hardware trigger.  This is done in Counter0SetUp.

		call Counter0SetUp

;* Stage 7  Enable interrupt on 8259a

		call EnableIrqMask

;* Stage 8  Set Irq 5 highest prority in 8259a - didn't seem to
;* make any difference in performance

	     ;	call Irg5HighestPriority

;* Stage 9  Burst length set-up

		call EnableDasBurstMode

;* Stage 10  - clear fifo

		call InitDasFifo  ; read and discard 256 fifo words

;* Stage 11  Set application interrupt vector

		call SetDasIntVector	  ; Set IrqLevel interrupt vector

;* Stage 12  Set LocalIop to DataRows - 1.

		MOV ax, DataRows - 1	; set LocalIop = DataRows
		mov LocalIop, ax	;
		les bx, IoPointer	; get address IoPointer%
		mov es:[bx], ax 	; also set VB IoPointer% = 0

;* Stage 13  Set hardware trigger

		call SetHardwareTrigger

;* Stage 14  Clear flip-flop on Pin 25

		call ClearDasPin25

;* Stage 15   Enable interrupt on das board

		call EnableDasInt

		Epilog
		ret 24
DasIntOn        ENDP

This got a bit complicated. 

The ComputerBoard clone of the Keithly-Metrabyte a/d
converter powers-up in an UNKNOWN state.  Or at least
partially UNKNOWN.

One of the random states includes triggering spurious 
interrupt. So a dummy handler had to be inserted to
possibly field bad data.

The attempt was made to interface directly to hardware
without a microcontoller buffer was partially successful.

Sampling at the 1 Khz rate revealed that Windows
occasionally �did its own thing� as a result of a task
switch and, therfore, interrupts were missed.

To detect when this happened we modified the 
ComputerBoards das 1400 board so that a hardware
count of interrupts received could be compared to
the software count.

Since the a/d values were buffered a FIFO, the FAST
Pentium could catch up.

But this caused the interrupt handler to increase in size
from about 1 K lines, including white space and comments, 
to 2 K lines.
 
Naturally we wish to be in the problem solving, as 
opposed to problem creating, or assignation of blame.

I think we have to consider all possible problem sources.

I am looking at the AC POWER INTERFACE LS SOV
Schematic dated 11-8-96.

I see that the power to the analog and digital cards was
run via a serial port db 25 cable and connector.

Pin assignment are 

   	Pin		Function
   	1		-15 G
	2		+15 GS
	3		+5 G
	4		+15 G
	5		5 GS
	6		tied to pin 7
	7		+15S
     	8		15 S
	9		5
	10		tied to pin 10
	11		+15
	12		tied to pin 11
	13		15 S
	14		tied to pin 1
	15		+5 GS
	16		tied to pin 3
	17		nc
	18		tied to pin 5
	19		+24 ground
	20		tied to pin 19
	21		+5 S
	22		tied to pin 9
	23		tied to pin 22
	24		+24 volts
	25		tied to pin 24

The +24 volts runs to solenoids.

The remaining power runs to both digital and analog Ics.

While some are left wondering why engineers had not
thought of running analog, digital and solenoid power 
down an inexpensive 24 pin PC serial port cable before,
perhaps, we might all guess, other engineers lack 
sufficient innovative audacity.

One engineer opined last summer, when I was working
in the shop on the digital FX, that the PC Data System 
boards may have to be redesigned.

Let�s hope that such a major revision is not required.

Naturally, me being a TOTAL CONSERVATIVE [as
evidenced by Morales and my genocide court filing], 
I plan to physically separate the analog and digital
IC s on the digital FX.  

And I am thinking about on-board power regulation to 
keep the 80c32, analog, and digital chips super-happy.
In the field, of course.

I will leave in several hours.  In my grey rabbit.

Air travel safety worries me more now.  

Especially after publication of last book.

Just in case, I will bring my passport.  

The thought of two machines located 180 miles NW
of Edmonton not working well is, of course, 
chilling.

I sure glad the 8051 version of PC Data System is
working fairly well. And is MAKING money for
Metriguard.

See you on Tuesday,  Allah willing.

Later
bill
Title: Payne/Morales v. NSA -- Defendant's Response to Motion for Summary Judgment

16 January 1998
Source: William H. Payne

See related files: http://jya.com/whpfiles.htm


                                                 U.S. Department of Justice
United States Attorney
District of New Mexico
__________________________________________________________
Post Office Box 607
Albuquerque, New Mexico 87103
505/766-3341
505/766-2868
FAX 505/766-8517

				January 5, 1998


W.H. Payne
P.O. Box 14838
Albuquerque, New Mexico 87191

     Re: Payne & Morales v. Minihan
     USDC NM CIV 97-0266 SC/DJS


Dear Mr. Payne:


     Enclosed is a court-endorsed copy of Defendant's Response to 
Plaintiffs' Motion for Summary Judgment Based on Evidence from 
Admissions.

				Sincerely,

				JOHN J. KELLY
				United States Attorney

				[Signature]

				JAN ELIZABETH MITCHELL
				Assistant U. S. Attorney

JEM/yh
Enclosure
cc/enc: Arthur R. Morales


[Stamp] FILED United States District Court District of New Mexico 98 JAN -5 PM 3:46 Robert M. Marsh District Clerk IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO WILLIAM H. PAYNE ) ARTHUR R. MORALES ) ) Plaintiffs, ) ) vs. ) CIVIL NO. 97-026 SC/DJS ) LT GEN KENNETH A. MINIHAN ) USAF Director, National Security ) Agency, ) ) Defendant. DEFENDANT'S RESPONSE TO PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT BASED ON EVIDENCE FROM ADMISSIONS Defendant Minihan responds to Plaintiff's Motion for Summary Judgment Based On Evidence From Admissions1 as follows: 1. Commencing in October, 1997, Plaintiffs served numerous sets of Requests for Admissions on various employees of the National Security Agency and on current and past employees of the Sandia National Laboratory. 2. Counsel for Defendant was not served with copies of any of said Requests for Admissions until sometime after the individuals had been served.2 ____________________ 1 It should be noted that the instant Motion for Summary Judgment constitutes Plaintiffs' second motion for summary judgment. Plaintiffs filed an initial Motion for Summary Judgment on June 4, 1997 to which Defendant responded on June 19, 1997, and Plaintiffs filed a Reply on July 1, 1997. Said initial Motion for Summary Judgment has not been ruled upon. In addition, Defendant filed a Motion to Dismiss Plaintiff Arthur R. Morales on September 23, 1997, and a Motion seeking dismissal of Plaintiff William Payne's Freedom of Information Act action on October 3, 1997. All briefing by all parties has been completed on those Motions. 2 On October 13, 1997, Plaintiffs mailed a First Set of Admissions to Kenneth Minihan. However, not until November 3, 1997, did Plaintiffs mail a copy of said First Set of Request for
3. Upon becoming aware that Plaintiffs had served Requests for Admissions on a number of individuals, on October 23, 1997, Counsel for Defendant filed a Motion and Memorandum To Strike Any And All Of Plaintiffs' First Set of Requests For Admissions To Various Employees Of The National Security Agency And To Various Employees Of Sandia National Laboratory, (hereinafter "Motion and Memorandum.") 4. As grounds for the Motion and Memorandum, Defendant argued that Plaintiffs had blatantly disregarded this Court's Order pertaining to the conduct of discovery and the deadline for discovery in this Freedom of Information Act action. 5. In Defendant's Motion and Memorandum, Counsel for Defendant also objected to Plaintiffs' sua sponte decision to modify the Court's June 11 Order to reflect the delay of the Court's October 7 Order and the establishment, without leave of this Court, of new deadlines for discovery, motions practice, and the filing of the PreTrial Order. (Motion and Memorandum ¶ 9, at 4.) 6. In the Motion and Memorandum, Defendant requested that this Court strike any and all "First Set of Request for Admission" propounded by Plaintiffs. (Motion and Memorandum, at 5.) 7. Plaintiffs responded to the Motion and Memorandum on November 5, 1997, specifically seeking that this Court "take no action in this case until Supreme court takes action on writs on ____________________ Admissions to Counsel for Defendant. Counsel for Defendant was not provided with copies of any other Requests for Admissions sent to employees of NSA or employees of the Sandia National Laboratory. 2
mandamus, prohibition, and criminal complaint affidavits filed against judges Svet and Campos and US Attorney Mitchell." (Plaintiffs' Response to Motion And Memorandum To Strike Any And All Of Plaintiffs' First Set Of Request For Admissions To Various Employees Of The National Security Agency And To Various Employees Of Sandia National Laboratories, ¶ 11, at 10.) 8. To date, no order has been issued by this Court on the matters raised in the Motion and Memorandum, nor has any other court issued any orders concerning Plaintiffs' cause of action and various complaints. 9. By their own request, Plaintiffs sought to stay a ruling on the Defendant's Motion and Memorandum. Absent any ruling on either the Motion and Memorandum or Plaintiffs' Response, Defendant Minihan, employees of NSA, and employees of Sandia National Laboratory, were not obligated to respond to the Requests for Admissions as provided by Fed.R.Civ.P. 36.3 For Plaintiffs to now assert in their "Motion for Summary Judgment On Based On Evidence From Admissions" that because the individuals have not responded to the Requests for Admissions they are deemed admitted, flies in the face of their own prayer to this Court to stay a ruling on the Defendant's Motion to strike the Requests for Admissions until the Supreme Court takes action. ____________________ 3 Despite the fact that Defendant's employees and other individuals are not required to respond to the Requests for Admissions based upon the outstanding pleadings which have yet to be ruled on by this Court, Plaintiffs characterize that all admissions are admitted and then publish those admissions on the Internet. 3
10. Defendant requests that this Court either rule upon Defendant's Motion and Memorandum granting the request to strike the Requests for Admissions, or grant Plaintiffs' request to stay this action pending the issuance of the order sought by Plaintiffs in another forum. Should this Court deny Defendant's Motion and Memorandum, Defendant respectfully requests that the individuals to whom Requests for Admissions are appropriate in this action be given the thirty days to respond to said admissions as provided by the Federal Rules of Civil Procedure. 11. Plaintiffs requested a stay. Absent a ruling from this Court denying their request, they cannot proceed to assert that the Requests for Admissions are deemed admitted. Accordingly, Plaintiffs' "Motion For Summary Judgment On Based On Evidence From Admissions" must be denied. Respectfully submitted, JOHN J. KELLY United States Attorney [Signature] JAN ELIZABETH MITCHELL Assistant U.S. Attorney P.O. Box 607 Albuquerque, New Mexico 87103 (505) 766-3341 I HEREBY CERTIFY that a true copy of the foregoing pleading was mailed to PRO SE PLAINTIFFS, this 5th day of January, 1998. [Signature] JAN ELIZABETH MITCHELL Assistant U. S. Attorney 4
		 UNITED STATES DISTRICT COURT
           FOR THE DISTRICT OF NEW MEXICO


William H. Payne        	   	            )
Arthur R. Morales                           )
                                            )
                Plaintiffs,                 )
                                            )
v                                           )	CIV NO 97 0266 
					                 )	SC/DJS
			                            )
Lieutenant General Kenneth A. Minihan, USAF )
Director, National Security Agency	       )
National Security Agency		            )
                                            )
                Defendant                   )


  REPLY TO DEFENDANT'S RESPONSE TO PLAINTIFFS' MOTION FOR 
  SUMMARY JUDGMENT BASED ON EVIDENCE FROM ADMISSIONS

1  COMES NOW plaintiffs Payne [Payne] and Morales [Morales] 

[Plaintiffs], pro se litigants to exercise their rights 

guaranteed under the Constitution, Rules of Civil  Procedure, 

and Local Civil Rules to respond to Defendant's MOTION filed

on 98 JAN-5 within the 14 days allowed by local rule 7.3(b)(4).

2  US Attorney Mitchell [Mitchell]  writes,

  Counsel for Defendant was not served with copies of any of  
  said Requests for Admissions until sometime after the
  individuals had been served.2

Mitchell WAS SERVED

  PLAINTIFFS' FIRST SET OF REQUEST FOR ADMISSION  TO  
  NSA DIRECTOR KENNETH MINIHAN 

  I HEREBY CERTIFY that a copy of the foregoing request for   
  admissions was mailed to Jan Elizabeth Mitchell, Assistant US 
  Attorney, 525 Silver SW, ABQ, NM 87102 this  Monday November 
  3, 1997. 

Michell was not served with any other admissions since

Mitchell is not representing others.

Plaintiffs' served Defendant Minihan properly.  And Minihan

failed to respond to Minihan's admissions within the time

allotted by law.

3 US Attorney Mitchell writes,

  As grounds for the Motion and Memorandum, Defendant
  argued that Plaintiffs had blatantly disregarded this Court's   
  Order pertaining to the conduct of discovery and the deadline 
  for discovery in this Freedom of Information Act action.

Judges Svet and Campos willfully violated Plaintiffs' right

to Discovery.  And thereby earned criminal complaint affidavits

filed with judge Scalia of the Supreme Court.


4 US Attorney Mitchell writes,

  In Defendant's Motion and Memorandum, Counsel for Defendant 
  also objected to Plaintiffs' sua sponte decision to
  modify the Court's June 11 Order to reflect the delay of the
  Court's October 7 Order and the establishment, without leave   
  of this Court, of new deadlines for discovery, motions   
  practice, and the filing of the PreTrial Order. (Motion and   
  Memorandum  9, at 4.)

Judge Svet and Campos attempt to deny Plaintiffs' right to 

Discovery, again, earned Svet and Campos criminal complaint

affidavits.

Plaintiffs exercise their right under the Federal Rules of 

Civil Procedure and the Constitution to conduct Discovery

WITHOUT LEAVE OF COURT!

5 US Attorney Mitchell writes,

   By their own request, Plaintiffs sought to stay a ruling on 
  the Defendant's Motion and Memorandum. Absent any ruling on 
  either the Motion and Memorandum or Plaintiffs' Response,
  Defendant Minihan, employees of NSA, and employees of 
  Sandia National Laboratory, were not obligated to respond to 
  the Requests for Admissions as provided by Fed.R.Civ.P. 36.3 
  For Plaintiffs to now assert in their "Motion for Summary 
  Judgment On Based On Evidence From Admissions" that because   
  the individuals have not responded to the Requests for 
  Admissions they are deemed admitted, flies in the face of   
  their own prayer to this Court to stay a ruling on the 
  Defendant's Motion to strike the Requests for Admissions until 
  the Supreme Court takes action.

Plaintiffs' have REPEATEDLY asked judge Svet and Campos to

disqualify themselves from any rulings on this case because

Campos and Svet do NOT obey the Federal Rules of Civil 

Procedure.

  Replace judges Svet and Campos because these judges
  have demonstrated, IN WRITING, they do not follow the 
  Federal Rules of Civil Procedure.

Plaintiffs' pleas are directed a replacement judge[s].  Not

Svet and Campos.

Therefore, Svet and Campos' failure to remove themselves does 

not stop the legal process. 

Mitchell cites NO law to support her claim that time 

constraints imposed under Fed.R.Civ.P. 36.3 are inapplicable

as a result of Svet's and Campos' failure to remove themselves.

6 US Attorney Mitchell writes,

  Defendant requests that this Court either rule upon
  Defendant's Motion and Memorandum granting the request to   
  strike the Requests for Admissions, or grant Plaintiffs' 
  request to stay this action pending the issuance of the order 
  sought by Plaintiffs in another forum. Should this Court deny 
  Defendant's Motion and Memorandum, Defendant respectfully 
  requests that the individuals to whom Requests for Admissions 
  are appropriate in this action be given the thirty days to 
  respond to said admissions as provided by the Federal Rules of 
  Civil Procedure.

REPLACEMENT JUDGES of the Court should realize the outcome

of the lawsuit has attained international interest as a result

of the

  1  bungled NSA spy sting on Iran 
  2  US government agencies NSA, NIST, and the FBI's
     attempt to control cryptography.

Mitchell's 
  
  DEFENDANT'S RESPONSE TO PLAINTIFFS' MOTION FOR 
  SUMMARY JUDGMENT BASED ON EVIDENCE FROM ADMISSIONS

was posted on Internet at jya.com, click cryptome

  nsasuit8.htm  USA/NSA Responds to Payne/Morales Motion            
                January 16, 1998

Importance of this posting is summed-up in the Toronto Sun, 

Jan. 11, 1998

  US, Iran Need Each Other 
 
  by Eric Margolis 
 
  Iran launched a surprise charm offensive last week, 
  throwing Washington into serious confusion.  

  In a lengthy interview on CNN, Iran's new president, Mohammad   
  Khatami, skillfully analyzed the bitter relations between the   
  two nations and cautiously extended an olive branch to 
  Washington, calling for an end to their 19-year cold war. 
 
  Khatami's diplomatic ju-jitsu flummoxed the Clinton   
  administration, which was busy trying to rally international 
  support against Tehran - and to overthrow Iran's elected 
  government.  
 
  Both capitals are split over the question of relations.  

  In Washington, the military establishment and conservative   
  Republicans have inflated Iran into a bogeyman to 
  justify military budgets and keep U.S. forces in the Mideast.  
  ...

  America incited Iraq to invade Iran in 1980. They did this to 
  crush the Islamic revolution, then provided massive war aid to 
  Saddam Hussein. Half a million Iranians died.  
 
The US got caught involved in genocide.  Using high tech.

This is one subject of this lawsuit.

Albuquerque Journal Tuesday 1/13/98 carried the editorial.
  
  Khatami Move Is Profile in Courage
  Richard Reeves
  Syndicated Columnist

  LOS ANGELES -  If an American leader had done what
  Iranian President Mohammed Khatami did last Wednesday,
  it would have been hailed as a profile in courage. ...

  Miscalculation!  We armed and pampered Saddam Hussein in
  the hope that Iraq would destroy Iran.  Now that's policy and
  behavior to think about. Here is something to think about: If
  Presidents Eisenhower and Kennedy had pursued any kind of
  sensible policy toward Cuba and Fidel Castro - opposed to
  the policy of trying to assassinate him - there never would 
  have been a Cuban missile crisis.

    I think Iranians have financed and encouraged terrorism
  against the interests of the United States and Israel.  I   
  would not be surprised at all if something like proof emerges 
  soon, perhaps anonymously, from the CIA and other government 
  agencies, where many officials have built their careers on 
  sanctioning and isolating Iran, to try to straighten the 
  backbones of the president and people of the United States.

    If they succeed, America fails.  What would be more 
  effective in closing down Iranian terrorism?  More hostility, 
  sanctions and charges?  Or beginning the process toward more 
  normal relations with a country positioned and born to be   
  great? ...

Clearly genocide fits into

  Now that's policy and behavior to think about.

The wired world is watching what this Court, hopefully

minus judges Svet and Campos, will do.

What is there to be?  A series of possibly unfortunate

events?  

Or does this Court order release the lawfully requested 

documents to help settle this American tragedy?


WHEREFORE.

7 Have replacement judges of this Court DENY Mitchell's

  Plaintiffs requested a stay. Absent a ruling from
  this Court denying their request, they cannot proceed to 
  assert that the Requests for Admissions are deemed admitted. 
  Accordingly, Plaintiffs' "Motion For Summary Judgment On Based 
  On Evidence From Admissions" must be denied.

for reason that Mitchell's request to subvert both the Discovery

processes and its time limits have no basis in law.  And appears 

to plead to judges who do not obey the Federal Rules of Civil

Procedure.

9  IMMEDIATELY ORDER Defendant to release the requested 

documents in the interest of national safety so that this 

matter can be settled. 

Aggrieved victims of  US genocide are reading these pleadings.

                    Respectfully submitted, 
 
 
                    _________________________ 
                    William H. Payne             	   	     
                    13015 Calle de Sandias NE          	     
                    Albuquerque, NM 87111              	     
 
 
                    _________________________				 
                    Arthur R. Morales                            
                    1024 Los Arboles NW                         
                    Albuquerque, NM 87107                        
 
                    Pro se litigants 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that a copy of the foregoing memorandum
was mailed to Lieutenant General Kenneth A. Minihan, USAF, 
Director,  National Security Agency, National Security Agency, 
9800 Savage Road, Fort George G. Meade, MD 20755-6000 
and hand delivered to  John J. Kelly, US Attorney, 525 Silver 
SW, ABQ, NM 87102 this  Tuesday January 20, 1997. 




5



Title:

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