Law professor (John Yoo) brushes off accusations over terror memo

[UpInArms]

http://www.macon.com/mld/macon/news/nation/8902148.htm

BERKELEY, Calif. - (KRT) - University of California-Berkeley law professor and former Bush administration official John Yoo, target of protests by law students, says he is not responsible for the abuse of prisoners at Iraq's Abu Ghraib prison.

"I think the calls for my resignation are misguided and don't show an understanding of the job of a lawyer," he said in an interview.

Working in the office of legal counsel for Attorney General John Ashcroft from 2001 to 2003, Yoo co-wrote two now-controversial legal memos advising the Bush administration that the restrictions of the War Crimes Act and the Geneva Conventions don't apply in the fight against al-Qaida and the Taliban.

Furthermore, Yoo advised, prisoners held by the U.S. military at Guantanamo Bay, Cuba, have no legal right to have their cases reviewed in U.S. courts. As enemy combatants, he wrote, they may be held indefinitely without charges.

<snip>

As a result, they concluded, detainees did not qualify for the protections provided prisoners of war under the Geneva Conventions - although the president could offer such protections if he chose.

Moreover, they concluded, customary international law "does not bind the president, or restrict the actions of the United States military."

...more...

[David Dunham]

1. Sue him, big time, for human rights abuses.

[displacedtexan]

2. When you work for Satan...

expect to get burned, Mr. Yoo.

[Just Me]

3. Ahhhh,...yet another potential co-conspirator.

It's sad how many compromise their souls for favors.

[gottaB]

4. You ain't a lawyer anymore, Dave.

You ain't a lawyer anymore, Dave. You a ganster now, you on the other side. Whole new ballgame. And you won't learn about it in any classroom.

[natrat]

25. no doubt --headlines read "Professor you spotted in Oakland

sporting conservative gang colors

[daleo]

5. This "lawyer's" advice amounted to:

The president can break any law he feels like, if he says there is a war on an emotion going on. Law has moved on since the middle ages and the divine right of kings.

[Justice]

6. He Should Not Be Fired For Taking a Particular View

He should be fired for being incompetent in his legal analysis.

[banana republican]

7. DITTO

And I want my tax dollars back...

[Miss Authoritiva]

8. Yoo's comments raise several interesting points.

(1) Agree or disagree with Yoo's conclusions, he makes it explicit that the memo he worked on applied only to AQ and the Taliban, not Iraqi citizens and soldiers.

(2) He noted that the Bush administration agreed to abide by the Geneva Conventions in the Iraq war. However, "From the pictures that we've all seen from Iraq, it would appear that those are clearly in violation of the Geneva Conventions," Yoo said.

Professor Yoo, please zip an e-mail by Ashcroft on that one.

(3) It's Yoo's belief that the enemy combatants scattered throughout Gitmo, Iraq, Afghanistan, and elsewhere will be released after the war:

"Enemy combatants are being held not as punishment, but to keep them out of action 'until the end of the war,' he said."

Well, it's nice that Yoo believes this, but he doesn't explain what he based this belief on. And this is a tricky point anyway: Since war was never officially declared, how can it be declared officially over -- and by whom? And if it is never declared officially over, then will the US keep the detainees in custody until they die, presumably of natural causes?

(4) Finally, the memo Yoo worked on reached a completely different conclusion regarding jurisdictional boundaries recently argued before the Supreme Court. Typical of the Bush Administration. See Froomkin's analysis at http://www.discourse.net/archives/2004/06/apologia_pro_tormento_analyzing_the_first_56_pages_of_the_walker_working_group_report_aka_the_torture_memo.html

[Disturbed]

9. The unoffical War On Terror.

"'until the end of the war".

Terrorism is a tactic not an entity. If these "enemy combatents" can be imprisoned until 'until the end of the war,' then it seems that this means until the die in prison. This Law Professor is a lackey of the Right Wing and was paid to come up with bogus legaleese to justify torture. Does anyone wonder why lawyers have a reputation of being Sociopaths?

[Hoping4Change]

10. Very informative post. Do you think that Yoo any way has

jeopardized his career? Are there grounds for the university to fire him?

[Robbien]

11. And how is one supposed to know?

Your point number one:

Agree or disagree with Yoo's conclusions, he makes it explicit that the memo he worked on applied only to AQ and the Taliban, not Iraqi citizens and soldiers

If an angry neighbor (angry because your dog peed on his lawn) tells the US authorities you are AQ or the Taliban, then as suspected AQ/Taliban, the US has the right (according to Yoo) to torture you.

How are our torturers supposed to know if you are really AQ/Taliban? The minute Yoo said torture was okay for a sub-set of the population, he opened the gate for torture of anyone.

[Miss Authoritiva]

14. I absolutely agree with you.

Yoo and fellow memo writers were the ones devising the subset population, and their reasoning was that the AQ and the Taliban were not nation-states and were not signatories to any of the conventions and treaties regarding torture.

That's their reasoning, not mine.

The big problem, as you point out, is how to distinguish between AQ and Taliban members from the rest of the population (shades of Vietnam here: trouble with clearly identifying the "enemy"). Well, apparently for the most part, the coalition forces haven't been able to. I guess the US government just counts the unfortunate innocent souls who wind up in Gitmo or Abu Ghraib as so much collateral damage.

[pinto]

22. great points Robbien and Miss Authoritiva, who are al Qaeda?

In the DOJ's convoluted logic I fully expect to hear the corollary: Al Qaeda are any of those being detained.

[TahitiNut]

12. We can no more wage a 'war' on an emotion than paint farts red.

The incredible, fucking, idiocy of the people who utter these imbecilic nonsense phrases is only surpassed by those who swallow this fallacious fecal matter.

By invading Afghanistan, we waged war on Afghanistan! How obvious does it have to get?

By invading Iraq, we waged war on Iraq! How obvious does it have to get?

Because we occupy Afghanistan, the war against Afghanistan has ended. (Remember VE Day?)

Because we occupy Iraq, the war against Iraq has ended. (Remember VJ Day?)

We are now, like it or not, the occupation force and still subject to the Geneva Conventions, now regarding occupying military forces.

World War II was over when Germany and Japan (and Italy) were invaded and occupied and their governments ceased to exist. After that, it was called "occupation." We didn't fucking engage on a "War On Fascism" no matter what the demagogues may have said using heated rhetoric. Such rhetoric is legally meaningless!

It is totally meaningless, insofar as the Geneva Conventions are concerned, whether a person is alleged to be a member of al-Qaeda or a member of the Taliban. I don't fucking care whether they're members of the Lions' Clubs, either. They're citizens of Afghanistan, Iraq, or of several other nations, all of which are signatories to the Geneva Conventions.

The United States is an outlaw nation under the control of an outlaw government. We are not the "good guys" no matter how it's spun.

We are outlaws.
The people who've done this have no honor, no integrity, and no "patriotism."
They deserve to be jailed for the rest of their lives.

[Miss Authoritiva]

15. Yup.

The United States is an outlaw nation under the control of an outlaw government. We are not the "good guys" no matter how it's spun.

[MasonJar]

17. Excuse me. Either we are the America of the Constitution and the

Bill of Rights or we are a group of abisers amd torturers. The country I want to live in does not sanction torture period. If you lose your soul, what right have you to condemn anyone for anything.

[Miss Authoritiva]

18. I don't want to live in a country that sanctions torture either.

Unfortunately, Switzerland keeps denying me a resident visa.

Also, unfortunately, it appears that the Bush Administration has made us the America of the Constitution and the Bill of Rights and a group of abusers and torturers. At least, the Department of Justice and the Department of Defense and the Department of Homeland Security seem confident that they've finessed most of the contradictions and can distract us from the remaining ones by yelling "national security," or "terror" or "war changes everything."

[Edmond Dantes]

19. "I love my country....."

".....but I think it's time we started seeing other people."

---Bumper sticker spotted last night in Georgetown area of DC

[DoYouEverWonder]

24. Good one

It is way past time, for this misadministration to be removed from power, and for our society to decide that Americans do not do this to other people, and it will not be tolerated. Just say no to torture.

[berry]

33. WOW--the Froomkin thread you linked to is *amazing*

It took a while to read, but it is worth every minute. Someone named Jason has some entries towards the bottom of the thread that are especially interesting (and chilling) about what may be going on re the leaking of these torture memos.

So, anyway, thank you for that link. I've already sent it on to friends, and I'll be going back to that site.

[TahitiNut]

37. I heartily agree.

I also agree that "Jason" makes the most seminal in chilling points.

I'm disappointed in only one respect. The memorandum attempts to place members of al-Qaeda and the Taliban outside the protections of the Geneva Convention by claiming that neither al-Qaeda nor the Taliban are "high signing authorities".

This is such specious nonsense as to offend any sane person's reasoning processes. It's an appalling 'argument' that pretends to place such organizations on a level with the nations of the world.

Could a President declare "war" on the Lion's Clubs?
Could a President declare "war" on the Green Party? (From what I read on DU, there are many here who might even condone this.)

Would members of the Lion's Clubs or the Green Party then be exempt from the protections of the Geneva Conventions?

Is their citizenship made immaterial? Is the fact that the US, being a "high signing authority," is bound by the provisions of the Geneva Convention immaterial?

[berry]

46. Your inspired examples make the absurdity inescapable.

Not that I have any desire to deny the absurdity of claiming that a postulated (unproven) membership in an organization (say, the Lion's Club-heh, or al Qaeda) must nullify citizenship in a country.

It occurs to me that it would be very interesting to see the full correspondence between the US and all the countries who had citizens (or at least residents) snatched--many of them Western democracies: England, Germany, Sweden, Norway, Australia I know for sure. The US can *claim* all sorts of rights to treat them badly, but surely there were laws covering jurisdiction, etc. What kind of US bullying was going on diplomatically?

Not that I think *any* country would fail to object. But I have NO doubt there was serious bullying of countries like Egypt, Saudi Arabia, Syria, Jordan, Pakistan, et al. And they may have been on the defensive for various reasons. Or more easily bribed or threatened with economic carrots and sticks. Afghanistan and Iraq, of course, had no chance to object.

The power Bush* took upon himself to name anyone an enemy at whim is every bit as scary and dangerous to our democracy as the power to "legally" torture these "non-persons".

I think what made that thread so compelling too was the absolute seriousness with which people who *know* Constitutional law say that they are scared.

I read somewhere else that most of these Bush* lawyers (like Yoo) were drawn from the Federalist Society. I've known about them, but never before wondered what they would do to the Constitution if they had free rein. I had assumed they were "strict constructionists"--but that is their own self-label, and could very well be cover for a very different agenda.... I thought they were like the Judicial Watch people, with odd obsessions, but occasionally in agreement with reasonable people. (I really don't know what to make of JW either.)

I'm finding it impossible these days to believe that anyone on the Bush* team is acting in good faith. And all this parsing of legal terms to worm around the law--by the holier-than-thous who claim to be "better" than the much-hated trial lawyers!! Augh.

[DoveTurnedHawk]

13. This Guy Is a Chump

I met him several times. Total asshat, totally full of himself.

I'm embarrassed that he's a member of the tribe. Maybe we can revoke his membership.

:evilgrin:

DTH

[bloom]

16. I think it's legal malpractice....n/t

[pinto]

20. Mr. Yoo's argument(s) seem an awfully slippery slope.

saying that "customary international law does not bind the President" leaves a loop hole big enough for any unilateral international operation the Executive deems appropriate.

And, "Enemy combatants are being held not as punishment, but to keep them out of action 'until the end of the war' " begs the question...when is the war over? And to what war is he referring?

[zanana]

21. But they weren't all terrorists, were they?

Am I missing something here? From what I've heard, these prisoners were rounded up in raids of entire neighborhoods.
In fact, some of the prisoners who were tortured have since been released. So if they weren't all terrorists, the U.S. has acted illegally even by Mr. Yoo's standards.

[Spazito]

23. One would think a lawyer of his "stature" would know his responsibility...

is to ensure that his clients know the law and work within it instead of advising ways to circumvent and breach it. His focus was on how to breach US and International laws without being charged for breaching them. What a slimeball, imo.

[Edmond Dantes]

34. You are exactly right.

DOJ's Office of Legal Counsel does not always provide objective legal advice. OLC is packed with carefully chosen right-wing idealogues who contrive legal justifications for whatever action the Executive Branch desires to take. As long as OLC can spin out a "legally defensible" legal theory in support of the contemplated executive action, the Executive Branch feels free to take that action. OLC gives the President the "green light" when it says "yessirree, you have the constitutional authority to do A, B or C."

And the worst of it? Stop and think about the "legally defensible" standard. "Legally defensible" means--in essence--"one step short of completely meritless." This standard effectuates a massive shift of lawmaking power from the Legislative Branch to the Executive Branch. And the Executive Branch has been getting away with it by making the surfacially reasonable assertion that "we are free to interpret the law for ourselves as we go about our constitutionally-mandated duty to faithfully execute the laws."

These are the President's lawyers--his outside counsel, to be precise. And by and large they tell the President exactly what he wants to hear. It's good for their career advancement. Most OLC lawyers only stay for a year or two. With the exception of the OLC Special Counsels (e.g., Yoo's coauthor, Robert Delahunty) OLC attorneys are generally quite young and malleable! Yoo himself was only 9 years out of law school and had spent most of his time in academia or clerking for judges.

I hope this makes sense. (I may need more coffee.....)

[fishnfla]

26. Another Harvard/Yale graduate

Just what are they teaching people at those universities? Courses in superiority?

[whosinpower]

27. Question for John Yoo

If International law does not bind the president or the actions of the US military....then why would it bind the actions of Saddam Hussein's army????? Or any other for that matter??????????

If laws are only applicable to everyone else EXCEPT the US - then they are forfeit, IMHO.

[Edmond Dantes]

28. Yoo's e-mail address

according to Berkeley website is [e-mail]

Let us know if he responds to your question! ;-)

[struggle4progress]

30. I certainly have a lot of questions I'd like to ask Yoo.

[struggle4progress]

29. A song for Yoo: "Sittin in the dock at the Hague ..."

Looks to me like the SOB was part of a conspiracy to commit war crimes.

[Edmond Dantes]

31. Song by DU2: With or Without Yoo

See the pain seared in their eyes
The Abu Ghraib thorn shreds their sides
Thanks to Yoo

With legal map he seals their fate
We bite our nails now as we wait
We wait for Yoo

With or without Yoo
With or without Yoo

Through false war, we sought their oil
We crushed their hearts, their spirits roiled
Thanks to Yoo

With or without Yoo
With or without Yoo
They can't live
With or without Yoo

And Yoo gave himself away
And Yoo gave himself away
And Yoo gave
And Yoo gave
And Yoo gave himself away

Their hands are bound,
Naked bodies' bruised, Yoo made sure they had
Nothing to win and
Nothing left to lose

And Yoo gave himself away
And Yoo gave himself away
And Yoo gave
And Yoo gave
And Yoo gave himself away

With or without Yoo
With or without Yoo
They can’t live
With or without Yoo

Without Yoo
Without Yoo
We can live
Without Yoo
Without Yoo

:cry:

I know. It needs work. DU Collective, feel free to edit as our song for Yoo.

[struggle4progress]

32. Thanks for this!

[Edmond Dantes]

35. Yoo's latest BS: "Nothing illegal about Bush's policy on torture"

This unethical, morally-bankrupt ball of slime still doesn't "get it." He thinks it's OK for the U.S. to HAVE a torture policy that allows torture in some circumstances. OUTRAGEOUS!!!

http://www.chron.com/cs/CDA/ssistory.mpl/editorial/outlook/2627124

[TahitiNut]

36. The OLC position: "Torture is a 'legal order'"

If the defense attorney for any of the charged enlisted personnel were to cite the memorandums from the OLC, it seems to me the very question of what constitutes a "legal order" could be placed directly on the doorstep of the White House. It's not the 'job' of any enlisted person to verify that any order received from a superior who is, in successive turns, subordinate to the "Commander in Chief" is truly acting pursuant to an order from that "Commander in Chief" consistent with the content of these memorandums. Nor would it be necessary for the defendant to even be aware of the mere existence of these memorandums - since these memorandums directly address the very meaning of "legal order" in a way that exonerates enlisted personnel acting in ways the fit within the latitudes it provides.

More simply stated: These memorandums make it clear that a "controlling legal authority" (far, far above any enlisted person's ability) obviates the assertion that performing torture is, per se, not a 'legal order' on its face. If the OLC can justify this behavior as within a 'legal order' then how can any enliste person not agree?

[sendero]

38. This is simple...

... if I ask a lawyer "can I shoot Johnny dead?" and he comes up with some tortured analysis that says "yes" - if I shoot Johnny dead I have still broken the law and will be held accountable.

The Bush* administration hired another sycophant to provide cover for their illegal activities. That strategy has never worked and it won't work this time either, except possibly in the court of public opinion.

[Edmond Dantes]

42. You know, it's an interesting thing....

In the federal government, one occasionally finds oneself in the position of needing ethics advice--not legal ethics, but GOVERNMENT ethics (think: U.S. Office of Government Ethics, which enforces the Hatch Act, among other things). Every government office in every department/agency has a person referred to as a "Deputy Designated Agency Ethics Officer" (DDAEO) who is supposed to provide such advice to any federal employee who requests it. But here's the interesting thing:

Assume (hypothetically) that I am a high-level political appointee, and I want to hire my sister to be my special assistant. I seek ethics advice from a DDAEO and he/she tells me that I CAN hire my sister without violating the rules of government ethics prohibiting nepotism. So I hire my sister based on that advice. Later, it turns out that the advice was wrong. Guess what? I cannot be disciplined.

Certainly, it makes sense that I not be punished for someone else's error if the error is an honest one.

But, WHAT IF that DDAEO and I have a tacit understanding tantamount to a quid pro quo? If the DDAEO gives me the ethics advice that will enable me to hire my sister with impunity, then I just might reward that DDAEO by granting him/her free parking privileges, or giving him/her a bonus, or promoting him/her, or even recommending that he/she be nominated for the federal bench. Conversely, if the DDAEO does NOT provide me with the legal cover I seek, I will make sure that DDAEO gets the worst office space, the worst substantive work assignments and is generally ostracized in the workplace. If the DDAEO continues to resist, I may even contrive a reason to replace him/her--perhaps with a DDAEO who doesn't have a law degree and won't feel quite so obligated to take a principled stand inconsistent with my goals.

Now I have never heard it said that an OLC legal opinion--whether analytically flawed or analytically sound--provides blanket protection to the government official who sought the legal advice in the first instance. But I am wondering whether this current crop of neocon thugs is operating on the assumption that they can EXTEND the erroneous ethics advice protection into a whole new realm: erroneous LEGAL advice protection.

Just a thought I throw out for your consideration.....

[young_at_heart]

39. "The president can do whatever he wants"?

Is Yoo basically saying that Bush "is not bound" by customary international law? Where is the outrage?

[UTUSN]

40. Let's Get All the Names Out There

*******QUOTE*******

.... Yoo, a former newspaper reporter, first joined the University of California-Berkeley's Boalt Hall faculty in 1993. He graduated from Harvard before earning his law degree from Yale. He has served as general counsel of the Senate Judiciary Committee and clerked for U.S. Supreme Court Justice Clarence Thomas. ....

In December 2001, while U.S. troops were pursuing al-Qaida and Taliban forces in Afghanistan, Yoo was asked to write a memo about Guantanamo Bay for William Haynes, the general counsel of the Defense Department.

Yoo, along with another lawyer, Patrick Philbin, wrote that U.S. courts had no jurisdiction outside the United States, including the military base in Cuba. They acknowledged, however, that the case was not airtight.

Less than two weeks later, on Jan. 9, 2002, Yoo and special counsel Robert Delahunty wrote a 42-page memo, again for Haynes, titled, "Application of Treaties and Laws to Al-Qaida and Taliban Detainees." White House counsel Alberto Gonzales cited the Justice Department "formal legal opinion" in a Jan. 25, 2002, memo for President Bush.

The Gonzales memo has been criticized as providing a legal justification for interrogation techniques approaching torture. ....

********UNQUOTE*******

[saigon68]

44. techniques approaching torture.

If Saddam had done this to USA POWs the DEATH PENALTY would be in play

But Pray tell, How could Saddam top this ???

When the POW had a PLASTIC FLASHLIGHT RAMMED UP HIS RECTUM ???

When a GERMAN SHEPHERD DOG BIT HIM IN THE TESTICLES ???

When the POW had a 220 Volt wire attached with a clip to the TIP OF HIS PENIS ???

When Lynndie England was encouraged to help the POWs obtain erections so they could perform
ORAL SEX ACTS ON EACH OTHER and the PERKY PRINCESS OF ABU GHRAIB
PRISON COULD SHOUT "HE'S GETTING HARD"???

When a POW was beaten to death, HIS BODY PACKED IN ICE and TAKEN OUT IN THE
DESERT AND DUMPED Or the Photos of Graner and Lynndie’s sidekick the Lovely Sabrina
Harman smiling over the dead corpse.

When Lynndie apparently on Orders collected a number of Dirty Used KOTEX MAXI-PADS to
be worn and tied to the Heads of POWs, Or when Graner made POW’s eat food thrown in
Toilets and then commented that the Prison Guard part of him said he loved to see them “PISS
THEMSELVES”

When Four U.S. soldiers from the 3rd Brigade Combat Team will be reprimanded for forcing
two Iraqi detainees to jump off a bridge into the Tigris River killing one of them.

How about interrogators torturing children and the presenting them to the parents to get them to
reveal WHATEVER?

When soldiers themselves admit dogs were used and when Spec. Sabrina D. Harman, recalled for
Army investigators an episode "when two dogs were brought into 1A to scare an
inmate. He was naked against the wall, when they let the dogs corner him. They pulled them back
enough, and the prisoner ran . . . straight across the floor. . . . The prisoner was cornered and the
dog bit his leg. A couple seconds later, he started to move again, and the dog bit his other leg."





When photos show a Naked man covered in Feces beaten in the head by a THUG holding a police
Baton?



When a Civilian Interrogator ANALLY RAPED A 15 YEAR OLD BOY IN FRONT OF GI WITNESSES ( who apparently used a camcorder to memorialize the child’s screams as his ANUS was savagely attacked) and the RAPIST is going to get a free pass because he was under NO ONES JURISDICTION ???

[UTUSN]

45. Comrade, I Salute You.

Thanks for all the work in getting your post together.

[Tracer]

41. I've seen this guy several times on Lehrer.

And a more oily apologist for the Bushistas, you'll hardly ever find.

[lostnfound]

43. Houston Chron carried his op-ed today w/o identifying him as memo writer

They let him recite the spin of the day (not torture, most Americans would agree with torture in certain circumstances, etc.) WITHOUT identifying him as the memo-writer, up to his eyeballs in it and obviously with a personal stake it it. They identified him only as "a law professor at the University of California, Berkeley, worked from 2001 to 2003 at the Justice Department, where he analyzed the Geneva Convention's applicability to terrorism detainees."

http://www.chron.com/cs/CDA/ssistory.mpl/editorial/outlook/2627124

Nothing illegal about Bush's policy on torture
By JOHN C. YOO

OFFICIAL Washington, D.C., has been struck by a paroxysm of leaking. It involves classified memos analyzing how the Geneva Convention, the 1994 Torture Convention and a federal law banning torture apply to captured al-Qaida and Taliban fighters. Critics suggest that the Bush administration sought to undermine or evade these laws. Sen. Dianne Feinstein, D-Calif., claimed last week that the analyses appeared "to be an effort to redefine torture and narrow prohibitions against it."

This is mistaken. As a matter of policy, our nation has established a standard of treatment for captured terrorists. In February 2002, President Bush declared that the detainees held at Guantanamo Bay, Cuba, would be treated "humanely and, to the extent appropriate and consistent with military necessity, consistent with the principles (of the Geneva Convention)." Detainees receive shelter, food, clothing, health care and the right to worship.

This policy is more generous than required. The Geneva Convention does not apply to the war on terrorism. It applies only to conflicts between its signatory nations. Al-Qaida is not a nation; it has not signed the convention; it shows no desire to obey the rules. Its very purpose — inflicting civilian casualties through surprise attack — violates the core principle of laws of war to spare innocent civilians and limit fighting to armed forces. Although the convention applies to the Afghanistan conflict, the Taliban militia lost its right to prisoner-of-war status because it did not wear uniforms, did not operate under responsible commanders and systematically violated the laws of war.
<snip>

[Edmond Dantes]

47. Dontcha love the 1st coupla sentences?

Let's shift the focus to the LEAKING of CLASSIFIED memoranda (and forget about the heinous content).

The OLC memoranda weren't classified, to my knowledge. They were confidential, as in "privileged attorney-client communications." That's what I thought I heard Ashcroft tell the Senate Judiciary Committee, anyway.

The policy is "more generous than required"? Puhhhllleeeeeeeeez!!!!!

[lostnfound]

48. I'm annoyed the Chronicle would slip him in..

without warning readers that he is the AUTHOR of one of the memos.

Yes, 'more generous than required' was revolting.