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Tuesday 2/3/98 7:22 PM
Jim
Let's get this settled.
I have not read
cylinked.htm Latest: Cylinked to Organized Crime?
January 29, 1998
YET.
Hope you liked the SAND report, now posted at jya.com, I sent
you in 1992.
I listened carefully at the breakfast you, I, Lou {lew?} Morris
had.
Later
bill
Title: Cryptome
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_______________________________________________________________________________________ File Topic Date _______________________________________________________________________________________ In Athena's Camp Preparing for Conflict in the Info Age (offsite) February 3, 1998 cylink-sins.htm Cylink Secures SINS February 3, 1998 pg-get-MSkey.htm Update: How to Recover Private Keys for MS Wares February 3, 1998 bxa020398.txt Exports of High Performance Computers February 3, 1998 sib.htm Scientists in Black February 3, 1998 CAP The Cryptographic Analysis Program (offsite) February 2, 1998 Arne Beurling The Geheimschreiber Secret (offsite) February 2, 1998 Army Stegano US Army Steganography (offsite) February 2, 1998 Colossus Rebuilding Colossus (offsite) February 2, 1998 Frode Crypto Cryptology Papers (offsite) February 2, 1998 jimbell9.htm Jim Bell Update February 2, 1998 echelon-boost NSA Surveillance System Boosted (offsite) February 2, 1998 cn020298.txt Crypto News February 2, 1998 bxa020298.txt BXA Meet on Export Rules and Procedures February 2, 1998 cs020298.txt Rules to Challenge Customs Seizures (63K) February 2, 1998 usg020298.txt USG Secret Meets February 2, 1998 echelon.htm NSA Global Surveillance System February 2, 1998 cathedral.htm The Cathedral and the Bazaar February 1, 1998 natsec-rule.htm Protection of National Security Information February 1, 1998 47cfr216.txt National Communications Issuance System (106K) February 1, 1998 47cfr213.txt Emergency Telecomms Precedence System (17K) February 1, 1998 47cfr202.txt National Security Emergency Plans & Ops (27K) February 1, 1998 47cfr201.txt Policy for Telecomms During Emergencies (12K) February 1, 1998 44cfr336.txt Facilities for National Security Emergency (14K) February 1, 1998 44cfr334.txt FEMA Graduated Mobilization Response (14K) February 1, 1998 32cfr322.txt Privacy Act Exemption for NSA Records (40K) February 1, 1998 32cfr299.txt National Security Agency FOIA Program (8K) February 1, 1998 32cfr2101.txt National Security Council FOIA Requests (24K) February 1, 1998 32cfr185.txt Military Support to Civil Authorities (52K) February 1, 1998 31cfr9.txt Effects of Imported Articles on National Security February 1, 1998 22cfr124.txt Contracts, Off-Shore Buys, Defense Services (42K) February 1, 1998 22cfr123.txt Licenses for the Export of Defense Articles (51K) February 1, 1998 22cfr121.txt United States Munitions List (92K) February 1, 1998 _______________________________________________________________________________________ ntia-dnsdrft.htm Draft Proposal for New Domain Name System January 30, 1998 korczak.txt Boris Korczak: CIA Agent Seeks Payment January 30, 1998 pm87.txt Prez on Terrorist Threat to Middle East Peace January 30, 1998 leahy-wipo.txt Senator Leahy on Ratifying WIPO Treaties January 30, 1998 32cfr147.txt DoD: Policies for Access to Classified Info January 30, 1998 32cfr148.txt DoD: Facilities for Storing Classified Info January 30, 1998 32cfr149.txt DoD: National Policy on Technical Surveillance January 30, 1998 ntia012798.htm RFC: Self-Regulation for Privacy Protection January 30, 1998 cylinked.htm Latest: Cylinked to Organized Crime? January 29, 1998 websoft-warn.htm Web Software Warning January 29, 1998 scant-peril.htm U.S. Spy Agencies Pauline Peril January 29, 1998 mossburg.htm E-Comm Forum on E-Authentication and DigSig January 29, 1998 pollard.htm Bankers O Table on E-Authentication and DigSig January 29, 1998 brown.htm Secret Service on Financial Instruments Fraud Janaury 29, 1998 rpk-hack.htm Invite to Hack RPK InvisiMail January 29, 1998 nrc012998.txt Generic Letter on Y2K Readiness for Nuke Plants January 29, 1998 fc012998.txt FinCEN RFC on Information Collection January 29, 1998 dtc012998.txt Arms Export to Saudi Arabia January 29, 1998 nsa-etc-nf.htm NSA, Echelon, Trade & Crypto/Netscape & Fortify January 28, 1998 dod012898.txt DoD Blacklist of Higher Education January 28, 1998 47usc1002.txt Interception of Digital and Other Communications January 28, 1998 cn012898.txt Crypto News January 28, 1998 cn012798.txt Crypto News January 27, 1998 bxa-fy98.txt BXA Funding FY 1998 January 27, 1998 cia-tsang.htm CIA Concedes Spying on Americans January 26, 1998 atpc.htm EU-Parliament: Technologies of Political Control January 26, 1998 us-crypto.htm US Crypto Policy January 25, 1998 pg-nzcrypto.htm New Zealand Crypto Policy January 24, 1998 ra-ukcrypto.htm UK Crypto Policy January 24, 1998 whp012398.htm Payne/Morales vs. NSA: Reply to Defendant January 23, 1998 kellner.htm Intellectuals and New Technologies (66K) January 23, 1998 bxa012398.txt BXA Penalizes Export Violator January 23, 1998 osd012398.txt Compensation of North Viet-Imprisoned Operatives January 23, 1998 dod012398.txt Defense Dept Secret Meets January 23, 1998 walton-pk.htm GCHQ: The Pre-History of Public Key Cryptography January 22, 1998 primer The Proliferation Primer (offsite) January 22, 1998 sh105-238.txt Proliferation and US Export Controls (196K) January 22, 1998 sh105-267.txt Safety and Reliability of US Nukes (347K) January 22, 1998 acda012298.txt Arms Control Secret Meet January 22, 1998 pd012298.txt Prez Notice on Mideast Terrorism Emergency January 22, 1998 bia012298.txt Rule on Indian Casinos January 22, 1998 cn012198.txt Crypto News January 21, 1998 fc98.htm Financial Cryptography '98 January 20, 1998 doj-ssgsup.htm Supplement to Fed Guide for Seizing Computers January 20, 1998 cn-netreg.htm New Chinese Internet Regulations January 20, 1998 ietf-dea-97.htm IETF Draft Encryption Algorithms 1997 January 20, 1998 radio-rec.htm Update: Locating Radio Receivers; Encoder Stolen January 20, 1998 pipenet.htm PipeNet Description January 20, 1998 dod012098.txt Defense Dept Secret Meets January 20, 1998 bernstein12.htm Transcript of Bernstein Hearing January 19, 1998 fbi-umbc.htm Barry Smith (FBI) to Speak on Encryption Policy January 18, 1998 de-snoop.htm Update: German Surveillance State January 17, 1998 bxa-wa-rule.htm Update 2: BXA Rule on the Wassenaar Arrangement January 16, 1998 pd98-10.htm Prez OKs China's Nuclear Controls January 16, 1998 tcryptol Theory of Cryptography Library (offsite) January 16, 1998 cn011698.htm Crypto News January 16, 1998 nsasuit8.htm USA/NSA Responds to Payne/Morales Motion Janaury 16, 1998 dod011698.txt Defense Dept Secret Meets January 16, 1998 bxa011398.txt Materials Advisory Meet January 15, 1998 crypto-kong.htm Announcing Crypto Kong January 15, 1998 occ-dstc.htm OCC OKs CA as Authorized Banking Activity January 14, 1998 aes-980820 Advanced Encryption Standard Conference (offsite) January 14, 1998 ustr010898.txt Update: Telecommunications Trade Agreements January 14, 1998 rc2.htm Rivest Describes RC2 Encryption Algorithm January 13, 1998 fc011398.txt FinCEN Regulates Card Clubs January 13, 1998 ta011298.txt Key Management Infrastructure Meet January 12, 1998 nist011298.txt Transmission-Electron Microscopy Meet January 12, 1998 doa011298.txt Army Hazard Containment Invention January 12, 1998 gps-jam.htm GPS Jamming January 11, 1998 arthur.htm The Force of An Idea: Theory of USA v. Microsoft January 10, 1998 RSA-stego.htm Batch RSA for Stego Data January 9, 1998 batch-DSA.htm Batch DSA January 9, 1998 cell-track.htm Update 2: Mobile Cell Phone Surveillance January 9, 1998 fiat-rsa.htm Fiat's Batch RSA January 9, 1998 aes010798.htm Update: Advanced Encryption Standard January 9, 1998 doj010998.txt RFC: USA v. IBM/STK Antitrust Suit January 9, 1998 bmd010898.txt Ballistic Missile Defense Secret Meet January 9, 1998 nih010898.txt Commercialization of Medical Data January 9, 1998 fas-pde Prez Directives/Executive Orders (offsite) January 7, 1998 ussc-ecopy.htm Sentencing for Electronic Copyright Violations January 6, 1998 ussc010698.txt RFC: US Sentencing Guidelines (254K) January 6, 1997 mercier.htm Terrorists, WMD, and the US Army Reserve January 6, 1998 terror-rnd.htm US Counterterrorism R&D Program January 6, 1998 belet Bob East Letter on AP/Jim Bell/IRS (offsite) January 6, 1998 pitfalls Schneier: Security Pitfalls in Crypto (offsite) January 5, 1998 dsb010598.txt Defense Science Board Secret Meets January 5, 1998 ntia010598.txt Funds for Public Telecommunications January 5, 1998 cn010598.txt Electronic Surveillance News January 5, 1998 csda.htm Cypherpunks Smartcard Developer Association January 4, 1998 aimd-98-21.htm Executive Guide: Info Security Management (139K) January 3, 1998 blast-mono.htm Blast Resistant Doors Monograph January 3, 1998 tempest-door.htm Electromagnetic Shielding/TEMPEST Door January 3, 1998 ehj.htm Banned Basque Video: Democratic Alternative January 3, 1998 fda010298.htm Policy for External Penile Rigidity Devices January 2, 1998 doe010298.htm Defense Nuclear Facilities Safety Plan January 2, 1998 dos010298.txt Meet on Global Communications and Info Policy January 2, 1998 doa010298.txt Army Science Board Meet January 2, 1998 _______________________________________________________________________________________
• • • •
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23 January 1998
Source: William H. Payne
See related documents: http://jya.com/whpfiles.htm
FILED
UNITED STATES DISTRICT COURT
DISTRICT OF NEW MEXICO
98 JAN 20 AM11:26
ROBERT M. MARSH
CLERK/ALBUQUERQUE
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
1
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.
2
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[t] 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
3
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
4
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 [missing text]
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.
[No 8]
9 IMMEDIATELY ORDER Defendant to release the requested
documents in the interest of national safety so that this
5
matter can be settled.
Aggrieved victims of US genocide are reading these pleadings.
Respectfully submitted,
[Signature]
_________________________
William H. Payne
13015 Calle de Sandias NE
Albuquerque, NM 87111
[Signature]
_________________________
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.
[Arthur R. Morales signature]
6
[End]
Title: Cylink Corporation
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