Sensitive Informant Program
which is used by the Bureau to recruit and/orplace informants on the staffs of members of the United States Congress andperhaps even federal judges, in the national media,
within other federal agenciesas well as the White House, on defense teams in high profile federal and/or statecriminal prosecutions,
inside state and local law enforcement agencies, and evenamong the clergy of organized religions.In response to Plaintiff’s
Freedom of Information Act
”) request forthe policies, rules, protocols and/or procedures (collectively the “
”)governing the FBI’s recruitment and use of such informants in this secretsurveillance program, the FBI acknowledged the existence of this program andproduced to Plaintiff a small portion of the
, which was heavily redacted.
But the FBI also withheld from Plaintiff what appear to be hundreds of pages from
Plaintiff further certifies that he and counsel for the FBI have conferred in goodfaith to resolve this discovery dispute but, despite those efforts, they have beenunsuccessful.
The FBI’s use of
in the national news media is welldocumented in the record of this case.
, Exhibits 1, 2 and 3, hereto.
As patently unconstitutional as the use of such informants would be, there isevidence that the FBI had such an informant with access to members of the defense teamin the prosecution of Timothy McVeigh.
Exhibit 4 hereto.
Exhibit 5 hereto
. See also
Doc. Nos. 14-8, 14-9 and 14-10.
Case 2:12-cv-00974-DAK Document 22 Filed 01/28/13 Page 2 of 19