The Lacuna Project

lacuna (n.) a gap in a record where something should be

Independent research. Not affiliated with any government, agency, or company.

The Lacuna Project

Exhibit register

Every document the report relies on, numbered in the order it was registered. Findings cite exhibits by number. Exact quotations appear only where the wording has been checked against the source.

Exhibit 001 · Consensus report

The Childhood Immunization Schedule and Safety

No studies have compared the differences in health outcomes that some stakeholders questioned between entirely unimmunized populations of children and fully immunized children.

Found that no study had examined the cumulative effect of the entire childhood schedule or compared fully unvaccinated children. Recommended using existing data systems such as the Vaccine Safety Datalink for that comparison, and judged a new randomized trial of the schedule unethical.

Source
Institute of Medicine (National Academies)
Date
2013
Quoted from
IOM, The Childhood Immunization Schedule and Safety (2013), Summary, pp. 5-6 (NAP online reader, chapter 2; text runs across the page break)
Grade
Primary record
Document
https://nap.nationalacademies.org/read/13563/chapter/2
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 002 · Statute

Mandate for safer childhood vaccines, 42 U.S.C. § 300aa-27

Directs the Secretary of Health and Human Services to promote safer childhood vaccines and to transmit to the House Committee on Energy and Commerce and the Senate Committee on Labor and Human Resources, within 2 years after 22 December 1987 and periodically thereafter, a report describing the actions taken, covering the preceding 2-year period.

Source
United States Congress (National Childhood Vaccine Injury Act of 1986)
Date
1986
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/42/300aa-27
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 003 · Court record

Stipulated order, ICAN v. U.S. Department of Health and Human Services

The [Department]’s searches for records did not locate any records responsive to your request.

Following a Freedom of Information Act request filed 25 August 2017 for the biennial reports required by § 300aa-27, the order records that HHS had no such reports.

Source
U.S. District Court, Southern District of New York
Date
July 2018
Quoted from
Stipulation, ICAN v. HHS, No. 1:18-cv-03215-JMF (S.D.N.Y.), Doc. 18, filed 9 July 2018, p. 2 (quoting HHS's 27 June 2018 FOIA response)
Grade
Primary record
Document
https://icandecide.org/government/ICAN-HHS-Stipulated-Order-July-2018.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Complaint: https://s3.documentcloud.org/documents/4405382/NYS-1-2018cv02000-complaint.pdf

Exhibit 004 · Agency statement

ICAN complaint alleging that the Task Force on Safer Childhood Vaccines was disbanded in 1998

The plaintiffs' complaint in ICAN and Institute for Autism Science v. Becerra, No. 1:21-cv-04134 (S.D.N.Y., filed 7 May 2021), alleges that the Task Force required by 42 U.S.C. 300aa-27(b) was disbanded in 1998 and that the Secretary has not prepared or filed a biennial vaccine safety report. The attached citizen petition repeats that 'HHS finally admitted that the Task Force was disbanded in 1998.' No HHS document in the file states the date.

Source
U.S. Department of Health and Human Services, as quoted in later litigation
Date
7 May 2021
Grade
Reported
Document
https://www.sirillp.com/wp-content/uploads/2021/06/001-Complaint-with-Exhibits.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Plaintiffs' allegation.

Exhibit 005 · Product label

Gardasil 9 prescribing information, clinical studies

The pivotal efficacy trial (Study 1, 14,204 women) was an active comparator-controlled, double-blind, randomized clinical trial against Gardasil. The label also reports Study 4, a safety study in which 608 participants received Gardasil 9 and 305 received saline placebo; all had previously received three doses of Gardasil.

Source
Merck Sharp & Dohme / U.S. Food and Drug Administration
Date
2014 onward
Grade
Primary record
Document
https://www.fda.gov/media/90064/download
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 006 · Product label

Gardasil prescribing information, clinical studies

In 7 clinical trials (5 Amorphous Aluminum Hydroxyphosphate Sulfate [AAHS]-controlled, 1 saline placebo-controlled, and 1 uncontrolled)

Most control recipients in the licensure trials received a "placebo" containing the vaccine’s aluminum adjuvant (amorphous aluminum hydroxyphosphate sulfate). A smaller group received a non-aluminum placebo.

Source
Merck Sharp & Dohme / U.S. Food and Drug Administration
Date
2006 onward
Quoted from
Package insert, section 6.1 Clinical Trials Experience (revision 04/2015, p. 3-4); same section: AAHS control N = 13,023, saline placebo N = 594
Grade
Primary record
Document
https://www.fda.gov/media/74350/download
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 008 · Journalism citing trial record

Placebo-controlled trials in the vaccine record

The polio vaccine field trials of 1954 included more than 600,000 children randomly assigned to get either the new vaccine or a placebo.

Science News, citing Susan Ellenberg, reports that the 1954 polio vaccine field trials included more than 600,000 children randomly assigned to receive either the new vaccine or a placebo. The article names polio, measles and chickenpox as childhood vaccines tested against placebos and says HPV vaccines were compared with hepatitis vaccines, an active control.

Source
Science News (with Paul Offit and Susan Ellenberg)
Date
2025
Quoted from
Article of 14 May 2025, near the end of the section on the history of placebo trials (Susan Ellenberg)
Grade
Reported
Document
https://www.sciencenews.org/article/hhs-cdc-fda-vaccine-test-placebo-safety
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 009 · Ethics code

Declaration of Helsinki, use of placebo

The benefits, risks, burdens, and effectiveness of a new intervention must be tested against those of the best proven intervention(s), except in the following circumstances:

The Declaration of Helsinki (October 2024 version) states that the benefits, risks, burdens and effectiveness of a new intervention must be tested against those of the best proven intervention, except where no proven intervention exists or, for compelling and scientifically sound methodological reasons, where participants receiving placebo or no intervention face no additional risk of serious or irreversible harm.

Source
World Medical Association
Date
1964, as amended
Quoted from
Declaration of Helsinki, October 2024 version, section "Use of Placebo" (paragraph number not shown in the saved copy)
Grade
Primary record
Document
https://www.wma.net/policies-post/wma-declaration-of-helsinki/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 010 · Unpublished manuscript

Impact of Childhood Vaccination on Short and Long-Term Chronic Health Outcomes in Children: A Birth Cohort Study

Our preliminary findings cannot prove causality and warrant further investigation.

Unpublished manuscript by Henry Ford Health authors comparing health outcomes in vaccinated and unvaccinated children in the Henry Ford health plan, dated about 2020 and entered into the U.S. Senate hearing record on 9 September 2025. The manuscript states that its preliminary findings cannot prove causality and warrant further investigation. Henry Ford Health states that the draft was not submitted for publication after its first internal review.

Source
Lamerato, Zervos, Chatfield, Tang (Henry Ford Health); entered into the U.S. Senate hearing record
Date
c. 2020; entered 9 September 2025
Quoted from
Manuscript, discussion
Grade
Primary record
Document
https://www.hsgac.senate.gov/wp-content/uploads/Entered-into-hearing-record-Impact-of-Childhood-Vaccination-on-Short-and-Long-Term-Chronic-Health-Outcomes-in-Children-A-Birth-Cohort-Study.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The abstract, results text and Table 3 report slightly different values for four hazard ratios; none is reproduced in this register.

Exhibit 011 · Institutional statement

Henry Ford Health response on the unpublished study

They said there are fatal flaws in that study. And accordingly, this is not going to move forward,

Henry Ford Health said senior scientists found "fatal flaws": incomplete data, significantly different groups and incorrect analysis. The study was not submitted for publication. Henry Ford sent a cease-and-desist letter to the makers of a film about it.

Source
Henry Ford Health, reported by Michigan Public
Date
6 November 2025
Quoted from
Michigan Public, 6 Nov 2025, section "Henry Ford's side", quoting Dr. Adnan Munkarah
Grade
Reported
Document
https://www.michiganpublic.org/health/2025-11-06/henry-ford-health-didnt-publish-a-vaccine-study-was-it-buried-or-just-rejected-science
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 012 · Congressional testimony

Testimony of Aaron Siri

Siri testified to a Senate subcommittee that the authors of the Henry Ford vaccinated-versus-unvaccinated study regarded it as well done and declined to submit it for publication for stated personal reasons. The testimony is Siri's account of private conversations.

Source
U.S. Senate Homeland Security and Governmental Affairs, Permanent Subcommittee on Investigations
Date
9 September 2025
Grade
Reported
Document
https://www.hsgac.senate.gov/wp-content/uploads/Siri-Testimony-1.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 013 · Cohort study

Vaccine aluminum exposure before 24 months and persistent asthma

While recognizing the small effect sizes identified and the potential for residual confounding, additional investigation of this hypothesis appears warranted.

In roughly 326,000 children, higher cumulative vaccine aluminum before age two was associated with persistent asthma at ages two to five. The authors described it as a signal requiring further study.

Source
Daley et al., Academic Pediatrics (Vaccine Safety Datalink, CDC-funded)
Date
2023
Quoted from
Acad Pediatr 2023;23(1):37-46, abstract, Conclusion
Grade
Peer-reviewed
Document
https://pubmed.ncbi.nlm.nih.gov/36180331/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 014 · Registry cohort

Aluminum-adsorbed vaccines and chronic disease in Danish children

In 1,224,176 Danish children, found no consistent association between vaccine aluminum and 50 chronic conditions. The design compared more versus less aluminum, per 1-mg increase in exposure; it contained no unexposed group. The abstract states that small effects for rarer disorders could not be excluded. An erratum was published (Ann Intern Med 2025;178(10):1527).

Source
Andersson et al., Annals of Internal Medicine
Date
July 2025
Grade
Peer-reviewed
Document
https://pubmed.ncbi.nlm.nih.gov/40658954/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 015 · Cohort study

DTP vaccination and child mortality in rural Guinea-Bissau, 1984–87

children receiving DTP at 2-8 months of age had higher mortality over the next 6 months, the mortality rate ratio (MR) being 1.92 (95% CI: 1.04, 3.52) compared with DTP-unvaccinated children

Among 1,657 children aged two to eight months, those vaccinated with DTP had a mortality ratio of 1.92 (95% CI 1.04–3.52) compared with unvaccinated children.

Source
Aaby et al., Tropical Medicine and International Health
Date
2004
Quoted from
Int J Epidemiol 2004;33(2):374-80, abstract, Results
Grade
Peer-reviewed
Document
https://pubmed.ncbi.nlm.nih.gov/15082643/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 016 · Natural experiment

The introduction of DTP and OPV among children in urban Guinea-Bissau

Among 3–5-month-old children, having received DTP (± OPV) was associated with a mortality hazard ratio (HR) of 5.00 (95% CI 1.53–16.3) compared with not-yet-DTP-vaccinated children.

Vaccination timing was set by birthday relative to quarterly weighing sessions. Infants aged three to five months who had received DTP died at five times the rate of not-yet-vaccinated infants (HR 5.00, 95% CI 1.53–16.3), based on 11 and 5 deaths.

Source
Mogensen et al., EBioMedicine
Date
2017
Quoted from
Abstract, Results; Table 3 gives 11 deaths (DTP) vs 5 (unvaccinated)
Grade
Peer-reviewed
Document
https://pmc.ncbi.nlm.nih.gov/articles/PMC5360569/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 017 · Systematic review

Association of BCG, DTP, and measles vaccines with all-cause mortality in children: systematic review

Although efforts should be made to ensure that all children are immunised on schedule with BCG, DTP, and MCV, randomised trials are needed to compare the effects of different sequences.

BCG and measles vaccines were associated with lower all-cause mortality. DTP was associated with a pooled relative risk of 1.38 (95% CI 0.92–2.08) from ten studies, all at high risk of bias. Recommended randomized trials of vaccine sequence; recommended no change to the schedule.

Source
Higgins et al., BMJ (commissioned by WHO SAGE)
Date
2016
Quoted from
BMJ 2016;355:i5170, abstract, Conclusions
Grade
Peer-reviewed
Document
https://pubmed.ncbi.nlm.nih.gov/27737834/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 018 · Reanalysis

Independent reanalysis of Bandim randomized trials of non-specific vaccine effects

only one of the 13 randomized trials demonstrated the effect it was designed to detect

Re-examined 13 Bandim randomized trials reported across 26 articles.

Source
Støvring et al., Vaccine; Aarhus University
Date
2025
Quoted from
Aarhus University press release
Grade
Peer-reviewed
Document
https://clin.au.dk/display/artikel/randomized-trials-show-no-evidence-of-non-specific-vaccine-effects
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 019 · Research article

Non-emerging primary trial results from the Bandim health project

Støvring and colleagues report in Vaccine (March 2026) on registered trials of the Bandim Health Project whose primary results had not been published. The register records ten such trials, including a DTP-related trial (NCT00244673) reported to have enrolled 6,534 children.

Source
Vaccine
Date
2026
Grade
Peer-reviewed
Document
https://doi.org/10.1016/j.vaccine.2026.128302
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 020 · Regulatory action

FDA approval letter for Comirnaty, 2025, listing Pfizer's postmarketing commitments

FDA's 2025 approval letter for Pfizer's COVID-19 vaccine acknowledges Pfizer's written commitments of 26 August 2025, including a randomized, double-blind, placebo-controlled study in healthy adults aged 50 to 64. The letter's postmarketing requirements (PMR 1 and 3, from a 15 August 2025 letter) were pediatric studies.

Source
U.S. Food and Drug Administration, reported by Managed Healthcare Executive
Date
2025
Grade
Reported
Document
https://www.fda.gov/media/188439/download
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 021 · Regulatory action

FDA releases Pfizer from the placebo-controlled postmarketing study

FDA letter releasing Pfizer from postmarketing commitment 4 of the 2025 approval, 'a prospective, exploratory, placebo-controlled, randomized study to evaluate detection of circulating SARS-COV-2 spike antigen and self-reported symptoms of post-COVID-19 vaccination syndrome or Long COVID symptoms.' The letter replaces it with a nonclinical biodistribution study and a retrospective integrated analysis. It does not mention the commitment to a placebo-controlled study in adults aged 50 to 64.

Source
U.S. Food and Drug Administration, as reported
Date
September 2026
Grade
Reported
Document
https://www.fda.gov/media/194509/download
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The FDA letter is the primary document. Press reports of a halted adults 50-64 trial are separate and not part of this exhibit.

Exhibit 022 · Regulatory action

Moderna mRNA influenza vaccine: advisory committee review and relative efficacy

A prospective influenza vaccine passed an FDA advisory committee meeting last month with a Prescription Drug User Fee Act goal date of August 5, 2026, after the committee initially refused to review the vaccine application in early February.

AJMC reported that a prospective influenza vaccine passed an FDA advisory committee meeting with a Prescription Drug User Fee Act goal date of 5 August 2026, after the committee initially refused to review the application in early February. In a randomized trial of 40,703 participants, Moderna's mRNA influenza vaccine had 26.6 percent relative efficacy (95% CI 16.7–35.4) against a licensed standard-dose influenza vaccine. The comparator was a licensed vaccine.

Source
U.S. Food and Drug Administration; VRBPAC; reported by AJMC and CIDRAP
Date
February 2026
Quoted from
AJMC article, first paragraph
Grade
Reported
Document
https://www.ajmc.com/view/fda-advisory-committee-supports-moderna-mrna-flu-vaccine-review
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 023 · Archive institutional history

John D. Rockefeller Sr.

In 1901 JDR founded the Rockefeller Institute for Medical Research (now The Rockefeller University) for the purpose of discovering the causes, manner of prevention, and the cure of disease.

The Rockefeller archive's account of the founder's philanthropy. It states that Rockefeller founded the Rockefeller Institute for Medical Research in 1901, with the advice of Frederick T. Gates and John D. Rockefeller Jr.

Source
Rockefeller Archive Center
Date
Undated web resource
Quoted from
Section "The Rockefeller Institute for Medical Research"
Grade
Primary record
Document
https://rockarch.org/resources/about-the-rockefellers/john-d-rockefeller-sr/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 024 · Archive institutional history

Public Health: How the Fight Against Hookworm Helped Build a System

In 1909, John D. Rockefeller established the Rockefeller Sanitary Commission for the Eradication of Hookworm Disease (RSC) with a gift of $1 million.

The archive's history of the Rockefeller Sanitary Commission for the Eradication of Hookworm Disease. It dates the Commission and its $1 million founding gift to 1909, describes infected parents as "often unable to work," and records that Wickliffe Rose moved from the Commission to direct the Rockefeller Foundation's international health program from 1915.

Source
Rockefeller Archive Center
Date
Undated web resource
Quoted from
Section "Philanthropy and the South"
Grade
Primary record
Document
https://resource.rockarch.org/story/public-health-how-the-fight-against-hookworm-helped-build-a-system/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 025 · Meeting minutes

Minutes of the Council on Medical Education, New York, 28 December 1908

Records a meeting of the Council with Henry S. Pritchett and Abraham Flexner. The Council agreed to put its data at the Carnegie Foundation's disposal. The minutes record that "the Foundation would be guided largely by the Council's investigations, but to avoid the usual claims of partiality no more mention should be made in the report of the Council than any other source of information."

Source
American Medical Association, Council on Medical Education
Date
28 December 1908
Grade
Primary record
Document
https://files.eric.ed.gov/fulltext/ED104308.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Known through James Monahan, "The Flexner Report: A Study in Polemics" (paper to the American Educational Research Association, 2 April 1975; ERIC ED104308), typescript pp. 5–6 and note 14. Monahan cites "Minutes of the Business Meetings of the Council on Medical Education, 1908–1917," pp. 6–7, bound transcripts at AMA headquarters, Chicago.

Exhibit 026 · Foundation report

Medical Education in the United States and Canada (Bulletin Number Four)

A well-taught negro sanitarian will be immensely useful; an essentially untrained negro wearing an M.D. degree is dangerous.

Flexner's survey of the 155 medical schools of the United States and Canada. It recommends reducing them to 31 (p. 154). It judges five of the seven medical schools for Black students "ineffectual" and names only Howard and Meharry as "worth developing" (pp. 180–181). It says women "show a decreasing inclination" to enter medicine and recommends coeducational schools over separate schools for women (pp. 178–179). Pritchett's introduction, dated 16 April 1910, thanks Simon Flexner "of the Rockefeller Institute," Arthur D. Bevan as chairman of the AMA council, and the council's secretary, N. P. Colwell (p. xvii).

Source
Carnegie Foundation for the Advancement of Teaching (Abraham Flexner)
Date
1910
Quoted from
Chapter XIV, "The Medical Education of the Negro," p. 180
Grade
Primary record
Document
https://archive.org/details/medicaleducation04flexuoft
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 027 · Correspondence

Henry S. Pritchett to Arthur Dean Bevan, 4 November 1909

The Carnegie Foundation's president writes to the chairman of the AMA Council on Medical Education, seven months before the report's publication: "In all this work of the examination of the medical schools we have been hand in glove with you and your committee." He adds: "When our report comes out, it is going to be ammunition in your hands."

Source
Carnegie Foundation for the Advancement of Teaching
Date
4 November 1909
Grade
Primary record
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), p. 151; wording checked against Brown. Archival locator from Brown's note 52 (p. 258): correspondence with AMA, Carnegie Foundation files.

Exhibit 028 · Correspondence

Henry S. Pritchett to Arthur Dean Bevan, undated (quoted by Brown)

In a sentence Brown reports Pritchett privately added to a letter to Bevan before the report's publication, Pritchett writes: "It is desirable ... to maintain in the meantime a position which does not intimate an immediate connection between our two efforts."

Source
Carnegie Foundation for the Advancement of Teaching
Date
Undated; before the 1910 report
Grade
Primary record
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), p. 152; wording matches Brown. Brown gives no date in the text; the nearest note is Pritchett to Bevan, 4 November 1909 (Brown n. 52). Secondary: the archival document is not in the record.

Exhibit 029 · Archive institutional history

The General Education Board, 1903–1964

The GEB program of medical education existed from 1913 to 1929 and distributed $94 million to 25 medical schools.

The archive's history of the General Education Board. It records Rockefeller Sr.'s initial $1 million commitment, his gifts of $43 million by 1907, and the board's medical education program, led by Abraham Flexner as Secretary.

Source
Rockefeller Archive Center
Date
Undated web resource
Quoted from
Section on medical education
Grade
Primary record
Document
https://resource.rockarch.org/story/the-general-education-board-1903-1964/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 030 · Archive institutional history

Early 20th Century Reforms of Medical Education Worldwide

Directing the medical education program was Flexner, who became Secretary of the GEB in 1913.

Records that Abraham Flexner became Secretary of the General Education Board in 1913 and directed its medical education program, that the first grants went to Johns Hopkins in 1913 for its clinical departments, and that Rockefeller Sr. then earmarked "a further $45,000,000 for the GEB's program in medical education." Also records GEB support for Meharry Medical College from 1916.

Source
Rockefeller Archive Center
Date
Undated web resource
Quoted from
Section on the General Education Board
Grade
Primary record
Document
https://resource.rockarch.org/story/early-20th-century-reforms-of-medical-education-worldwide/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 031 · Grant contract

General Education Board full-time clinical contracts

The GEB's contracts with universities for the full-time clinical plan provided that if the plan "shall, without the consent of the said General Education board, be abandoned, substantially modified or departed from, the said university will, upon demand of said board, return said securities or any securities representing their reinvestment."

Source
General Education Board
Date
1913–1925
Grade
Primary record
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), p. 172; wording checked against Brown. Brown takes the clause from Raymond B. Fosdick, Adventure in Giving: The Story of the General Education Board (1962), p. 164 (note 108).

Exhibit 032 · Correspondence

Wallace Buttrick to Harry Pratt Judson, 26 December 1914

The GEB's chief executive writes to the president of the University of Chicago: "We have never asked any institution to adopt the plan." He attributes the Johns Hopkins proposal to William H. Welch.

Source
General Education Board
Date
26 December 1914
Grade
Primary record
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), p. 173; wording checked against Brown. Archival locator from Brown's note 117 (p. 262): GEB files, Rockefeller Foundation Archives.

Exhibit 033 · Correspondence

Henry S. Pritchett to Wallace Buttrick, 11 November 1919

Pritchett objects to the GEB's full-time contracts: "Such a contract binding a university to a fixed policy laid down by the giver of money seems to me a dangerous thing." He adds: "If these contracts were made public, I am sure it would bring down on all educational foundations no less than on the universities themselves severe criticism."

Source
Carnegie Foundation for the Advancement of Teaching
Date
11 November 1919
Grade
Primary record
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), p. 173; wording checked against Brown. Archival locator from Brown's note 115 (p. 261): correspondence with GEB, Carnegie Foundation files.

Exhibit 034 · Correspondence

Thomas M. Debevoise to Frederick T. Gates, 7 October 1925

Thomas Debevoise, counsel to the General Education Board, writes to Frederick Gates that binding contracts are unnecessary: "Most of the schools which receive money from the board come back at least a second time, and the possibility of their needing additional help should lend all the inducement necessary to make them follow the ideas of the board."

Source
General Education Board (counsel)
Date
7 October 1925
Grade
Primary record
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), p. 174; wording checked against Brown. Archival locator from Brown's note 120 (p. 262): GEB files, Rockefeller Foundation Archives.

Exhibit 035 · Meeting minutes

Minutes of the General Education Board, 26 February 1925, and of its Executive Committee, 30 September 1925

According to E. Richard Brown's Rockefeller Medicine Men, on 26 February 1925 the General Education Board approved a University of Chicago contract that barred full-time clinical faculty from taking fees in the university's hospitals but allowed them to continue private practice outside those hospitals, with Gates dissenting. At the end of September 1925 the executive committee allowed Johns Hopkins, Vanderbilt, Washington University and Yale to modify their full-time contracts. Gates asked to have his negative vote recorded.

Source
General Education Board
Date
1925
Grade
Primary record
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), pp. 174–175. Archival locators from Brown's notes 122–123 (p. 262): GEB files, Rockefeller Foundation Archives.

Exhibit 036 · Correspondence

Frederick T. Gates to John D. Rockefeller Sr., 12 December 1910

Gates explains lower cotton-mill output in heavily infected counties: "the inefficiency in the labor is due to the infection by the hookworm which weakens the operatives." He calculates: "It takes, by actual count, about 25 percent more laborers to secure the same results in the counties where the infection is heavier." He adds that this is "why the stocks of such mills are lower and the profits lighter."

Source
Office of John D. Rockefeller (Frederick T. Gates)
Date
12 December 1910
Grade
Primary record
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), p. 116; wording checked against Brown. Archival locator from Brown's note 37 (p. 254): Rockefeller Family Archives, record group 2.

Exhibit 037 · Address

Frederick T. Gates, Address on the Tenth Anniversary of the Rockefeller Institute

Gates describes the Rockefeller Institute as a "theological seminary, presided over by the Rev. Simon Flexner, D.D.," and says scientific medicine is promulgating "new moral laws and new social laws, new definitions of what is right and wrong in our relations with each other."

Source
Frederick T. Gates
Date
1911
Grade
Primary record
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
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Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), p. 125; wording checked against Brown. Archival locator from Brown's notes (p. 255): Gates collection, Rockefeller Foundation Archives.

Exhibit 038 · Memorandum

Frederick T. Gates, "Philanthropy and Civilization"

Gates writes that disease "is the main source of almost all other human ills, poverty, crime, ignorance, vice, inefficiency, hereditary taint, and many other evils."

Source
Frederick T. Gates
Date
1923
Grade
Primary record
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
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Findings citing this exhibit
Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), pp. 128–129; wording checked against Brown (the scan's text layer displaces one word across a line break). Archival locator from Brown's note 65 (p. 256): Gates collection, Rockefeller Foundation Archives.

Exhibit 039 · Memorandum

Frederick T. Gates, "Concerning Private Gifts to States and a Medical Policy"

Gates tells the GEB trustees that physicians' fee-setting "is the greatest present American obstruction to the usefulness of the science of medicine. For it confines the benefits of the science too largely to the rich." In the same memo he writes that big business sponsors preventive medicine "because health is found in a variety of ways to be profitable."

Source
Frederick T. Gates, memorandum to the General Education Board
Date
26 February 1925
Grade
Primary record
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
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Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), pp. 113 and 158; wording checked against Brown. Archival locator from Brown's notes 29 and 31 (p. 254) and 68 (p. 260): Gates collection, Rockefeller Foundation Archives.

Exhibit 040 · Memoir manuscript

Frederick T. Gates, Autobiography (unpublished typescript)

Gates writes that "the hookworm work is done in every state under the guise of the State Health Boards, while it is in fact minutely directed by Mr. Rockefeller's staff and paid for with Mr. Rockefeller's money."

Source
Frederick T. Gates
Date
1928
Grade
Primary record
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
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Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), pp. 181–182; wording checked against Brown (the scan's text layer displaces the word "staff" across a page break). Archival locator from Brown's note 145 (p. 263): Gates, Autobiography, typescript pp. 456–57, 463–64, Gates collection, Rockefeller Foundation Archives.

Exhibit 041 · Foundation report

The Rockefeller Foundation: A Review of Its War Work, Public Health Activities, and Medical Education Projects in 1917

some advantages over machine guns

Writing of a Rockefeller-supported hospital ship for the Moro population of the Philippines, the Foundation's president says medical care has "some advantages over machine guns." A Foundation newsletter of 15 August 1916 called the ship's work "an entering wedge for permanent civilizing influences."

Source
Rockefeller Foundation (George E. Vincent, president)
Date
1918
Quoted from
George E. Vincent, The Rockefeller Foundation: A Review for 1917 (1918), section "Medicine versus Machine Guns," pp. 31-32 (Brown n. 50)
Grade
Primary record
Document
https://archive.org/details/rockefellerfound00rock
Accessed
2026-11-09
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Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), p. 124; wording checked against Brown. Locators from Brown's notes 49–50 (p. 255): Vincent, Review for 1917, pp. 31–32; "Hospital Ship for the Sulu Archipelago," Rockefeller Foundation newsletter, 15 August 1916.

Exhibit 042 · Correspondence

John D. Rockefeller Sr. to Starr J. Murphy, 29 December 1916

According to E. Richard Brown's Rockefeller Medicine Men, John D. Rockefeller Sr. wrote to Starr J. Murphy on 29 December 1916 that he was a homeopathist and wanted homeopaths to receive fair, courteous and liberal treatment from the medical institutions to which the family contributed.

Source
John D. Rockefeller Sr.
Date
29 December 1916
Grade
Primary record
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
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Note
Known through E. Richard Brown, Rockefeller Medicine Men (1979), p. 109; wording checked against Brown. Archival locator from Brown's note 18 (p. 253): Rockefeller Family Archives, record group 2.

Exhibit 043 · Scholarly monograph

Rockefeller Medicine Men: Medicine and Capitalism in America

The rate of consolidation and elimination of medical schools was as rapid before the report as after.

Archival history of the Rockefeller and Carnegie medical programs, drawn from the Rockefeller Family Archives, the Gates collection and GEB files, and the Carnegie Foundation's AMA correspondence. Brown documents the AMA–Carnegie collaboration (pp. 142–152), the GEB full-time plan and its contracts (pp. 156–176), and Gates's productivity and social-order rationale (pp. 106–133). He gives school counts of 166 (1904), 133 (1910), 104 (1915) and 76 (1929) (p. 85), and the council's 1907 ratings of 160 schools as 82 class A, 46 class B and 32 class C (p. 140). He records that the five disapproved Black schools closed and that women stayed under 5 percent of graduates from 1900 to the Second World War (p. 154). He denies an investment motive: "The Rockefellers did not have any significant investment in Southern textile mills" (p. 116).

Source
E. Richard Brown (University of California Press)
Date
1979
Quoted from
p. 154
Grade
Peer-reviewed
Document
https://archive.org/details/rockefellermedic00browrich
Accessed
2026-11-09
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Findings citing this exhibit
Note
Brown labels his account of Simon Flexner proposing his brother as an inference (p. 144; note 24, p. 257). His GEB totals vary by page and basis: some $50 million contributed by 1928, more than $78 million appropriated by 1929, more than $82 million applied by 1930 (pp. 57, 155, 193).

Exhibit 044 · Peer-reviewed article

Abraham Flexner and the Era of Medical Education Reform

The number of medical schools already had begun to decrease, dropping from 160 in 1905 to 133 in 1910.

Gives 160 medical schools in 1905, 133 in 1910 and 85 in the decade after the report. Flexner drew heavily on standards already set by the AMA, the Association of American Medical Colleges and state boards. State licensing boards' refusal to recognize poor schools sealed their fate.

Source
Barbara Barzansky, Academic Medicine 85 (supplement): S19–S25
Date
2010
Quoted from
Abstract (Acad Med 85(9 Suppl): S19-25; PMID 20736546)
Grade
Peer-reviewed
Document
https://doi.org/10.1097/ACM.0b013e3181f12bd1
Accessed
2026-11-09
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Exhibit 045 · Peer-reviewed article

Medical Education Reform Efforts and Failures of U.S. Medical Schools, 1870–1930

Miller and Weiss report that homeopathic and eclectic students fell from 17 percent of all medical students in 1880 to 6 percent in 1910, and that by 1909 allopathic schools averaged 180 students, homeopathic schools 78 and eclectic schools 48.

Source
Miller and Weiss, Journal of the History of Medicine and Allied Sciences 63(3)
Date
2008
Grade
Peer-reviewed
Document
https://doi.org/10.1093/jhmas/jrn002
Accessed
2026-11-09
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Note
Figures known through Constellations (University of Alberta), "The Impact of the Flexner Report on Sectarian Medical Schools," which cites this article.

Exhibit 046 · Peer-reviewed article

Medical education reforms and the origins of the rural physician shortage

These findings suggest that the medical education reforms of the early twentieth century contributed to the urban–rural disparity in access to physician care.

Finds that graduates of more rigorous medical schools were less likely to practice in rural areas, and that the chance a new graduate located in a rural area fell 40 percent between 1900 and 1920, contributing to the early urban-rural gap in access to physicians. The paper concerns where graduates set up practice.

Source
Moehling, Niemesh, Thomasson and Treber, Cliometrica 14(2):181–225
Date
2020
Quoted from
Cliometrica 14, 181-225 (2020), abstract (Springer preview; full text paywalled)
Grade
Peer-reviewed
Document
https://doi.org/10.1007/s11698-019-00187-w
Accessed
2026-11-09
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Exhibit 047 · Working paper

Medical School Closures, Market Adjustment, and Mortality in the Flexner Report Era

Nearby medical school closures (within 300 miles) led to a 4% reduction in physicians per capita, even after physician market adjustment through physician migration and postponed retirement.

Finds that the closure of a medical school within 300 miles, mostly between 1905 and 1915, reduced physicians per capita by 4 percent after allowing for migration and delayed retirement. Also reports effects on mortality.

Source
Clay, Miller, Portnykh and Schmick, National Bureau of Economic Research Working Paper 33937
Date
2025
Quoted from
NBER Working Paper 33937 (June 2025), abstract
Grade
Reported
Document
https://www.nber.org/papers/w33937
Accessed
2026-11-09
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Note
NBER working paper, not yet peer reviewed.

Exhibit 048 · Archive history

The Start of Something Big: the Rockefeller Foundation's twentieth-century global fight against disease

Furthermore, the legacy of the IHD influenced the WHO in many concrete ways, especially the WHO’s Global Malaria Eradication Program, begun in 1955.

The International Health Commission was created on 27 June 1913, became the International Health Board in 1916 and the International Health Division in 1927, and was folded into the Foundation's Division of Medicine and Public Health in 1951. It started programs in more than 80 countries and by its end had allocated over $94 million. Hookworm, tuberculosis, yellow fever and malaria took 90 percent of its disease budget. The Archive states that the IHD legacy influenced the WHO's Global Malaria Eradication Program, begun in 1955. Its stated principles were that public health is a government function, that IHD aid is temporary, and that all aid should strengthen government health agencies. By 1924 hookworm campaigns had been adopted in 52 countries on six continents.

Source
Rockefeller Archive Center (Teresa Iacobelli)
Date
n.d.
Quoted from
Rockefeller Archive Center REsource story by Teresa Iacobelli, section "Passing the Torch"
Grade
Primary record
Document
https://resource.rockarch.org/story/the-rockefeller-foundations-20th-century-global-fight-against-disease/
Accessed
2026-11-09
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Exhibit 049 · Peer-reviewed archival history

Backstage: the relationship between the Rockefeller Foundation and the World Health Organization, Part I: 1940s–1960s

the RF remained the LNHO’s lifeline, eventually funding almost half its personnel.

Archival history of Rockefeller influence on international health from the League of Nations to the early WHO. The Foundation was the League of Nations Health Organisation's lifeline and eventually funded almost half its personnel. IHD veterans planned and led UNRRA's health work. Many delegates to the 1946 International Health Conference were IHD fellows. The Foundation paid Fred Soper's first-year salary at the Pan American Sanitary Bureau and kept him on staff for his first four years there. Soper's moves forced the WHO into a regional structure. Director-General Marcolino Candau had been an RF fellow. Birn concludes that because the Foundation's approach was firmly in place at the WHO, its presence became superfluous.

Source
Anne-Emanuelle Birn, Public Health 128(2): 129–140
Date
February 2014
Quoted from
Public Health 128(2):129-140, p. 130 (left column wraps; sentence begins "Even though few IHD staff shared Rajchman’s views")
Grade
Peer-reviewed
Document
https://doi.org/10.1016/j.puhe.2013.11.010
Accessed
2026-11-09
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Note
Quotations in Chapter 2 were taken from that copy; page locators still to be added before a quote field is registered.

Exhibit 050 · Library history

The Yellow Fever Laboratory: Rockefeller Foundation, 1928–1937

By late 1936, they had produced an attenuated yellow fever virus, which they called 17D.

The National Library of Medicine's history of the Rockefeller Foundation yellow fever laboratory states that by late 1936 the laboratory team had produced an attenuated yellow fever virus, which it called 17D, and that the first field trials in Brazil started early in 1937.

Source
U.S. National Library of Medicine
Date
n.d.
Quoted from
Page text, paragraph beginning 'From 1934 to 1936, the team cultured several strains'
Grade
Reported
Document
https://mhm.nlm.nih.gov/spotlight/lw/feature/yellowfeverlab
Accessed
2026-11-09
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Findings citing this exhibit
Note
Theiler and H. H. Smith, 'The use of yellow fever virus modified by in vitro cultivation for human immunization', Journal of Experimental Medicine 65(6): 787–800 (1937), https://doi.org/10.1084/jem.65.6.787.

Exhibit 051 · Archive history

Eradication or Control? The Rockefeller Foundation's global anti-malaria campaigns

Ten thousand tons of DDT were deployed in Sardinia by 32,000 sprayers.

RF officer Fred Soper led the eradication of Anopheles gambiae from the invaded area of northeast Brazil, completed in 1940, with the larvicide Paris green, at a cost of $430,000 over three years. In Sardinia, run from 1946 through the agency ERLAAS, ten thousand tons of DDT were deployed by 32,000 sprayers, and officials cited a 99.9 percent success rate against the mosquito. The first superintendent, John Austin Kerr, questioned the feasibility of eradication in June 1946 and resigned about a year later.

Source
Rockefeller Archive Center
Date
n.d.
Quoted from
Section 'The Sardinian Experiment', second paragraph
Grade
Primary record
Document
https://resource.rockarch.org/story/eradication-or-control-the-rockefeller-foundations-global-anti-malaria-campaigns/
Accessed
2026-11-09
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Exhibit 052 · Peer-reviewed history

Program to Eradicate Malaria in Sardinia, 1946–1950

The interruption of malaria transmission did not require vector eradication, but with a goal of developing a new strategy to fight malaria, the choice was made to wage a rapid attack with a powerful new chemical. Costing millions of dollars, 267 metric tons of DDT were spread over the island. Although malaria was eliminated, the main objective, complete eradication of the vector, was not achieved.

Describes the 1946–1950 Rockefeller Foundation experiment in Sardinia to test whether an indigenous vector species could be eradicated. Malaria was eliminated; the mosquito was not.

Source
Eugenia Tognotti, Emerging Infectious Diseases 15(9)
Date
September 2009
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://wwwnc.cdc.gov/eid/article/15/9/08-1317_article
Accessed
2026-11-09
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Note
Tognotti gives 267 metric tons of DDT; the Rockefeller Archive Center gives ten thousand tons. Neither source reconciles the figures.

Exhibit 053 · Agency web page

Contributors: The Rockefeller Foundation

The Foundation participated as an observer at the first International Health Conference in June 1946, where WHO’s constitution was signed and the Organization became the first specialized agency of the United Nations.

The WHO states that the Rockefeller Foundation attended the first International Health Conference in June 1946 as an observer, that the partnership goes back to the WHO's beginnings, and that the Foundation's contributions total more than US$25.6 million since 2000. The Foundation was admitted as a non-State actor in official relations with the WHO in January 2022.

Source
World Health Organization
Date
n.d. (current page)
Quoted from
WHO contributor page, "Celebrating over 70 years of collaboration" (content last updated 20 April 2022)
Grade
Primary record
Document
https://www.who.int/about/funding/contributors/the-rockefeller-foundation
Accessed
2026-11-09
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Exhibit 054 · Peer-reviewed review by WHO staff

From malaria control to eradication: The WHO perspective

Thus, in 1969, the goal of malaria eradication was abandoned in favour of malaria control.

WHO launched the Global Malaria Eradication Programme in 1955, when DDT and chloroquine became available, and aimed to interrupt transmission everywhere outside tropical Africa. Thirty-seven of 143 endemic countries were free of malaria by 1978. Failure to sustain the programme led to resurgence, and the eradication goal was abandoned in 1969. Parasite resistance to chloroquine, mosquito resistance to DDT and dwindling investment followed.

Source
K. Mendis, A. Rietveld, M. Warsame, A. Bosman, B. Greenwood, W. H. Wernsdorfer (WHO Global Malaria Programme), Tropical Medicine and International Health 14(7)
Date
July 2009
Quoted from
p. 2 (WHO AFRO PDF copy)
Grade
Peer-reviewed
Document
https://doi.org/10.1111/j.1365-3156.2009.02287.x
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
WHO-hosted copy: https://www.afro.who.int/sites/default/files/2017-06/mal-From-malaria-control-to-eradication-WHO-perspective.pdf

Exhibit 055 · Peer-reviewed history

The origins of primary health care and selective primary health care

the Rockefeller Foundation sponsored in 1979 a small conference entitled “Health and Population in Development” at its Bellagio Conference Center in Italy.

In 1979 the Rockefeller Foundation sponsored the conference 'Health and Population in Development' at its Bellagio Center. Participants included Robert McNamara of the World Bank, David Bell of the Ford Foundation, John Gilligan of USAID, WHO Director-General Halfdan Mahler and James Grant, later head of UNICEF. The meeting built on Walsh and Warren's 1979 paper on selective primary health care, a package of low-cost technical interventions against the main diseases of poor countries. The package became UNICEF's GOBI program under Grant.

Source
Marcos Cueto, American Journal of Public Health 94(11): 1864–1874
Date
November 2004
Quoted from
Am J Public Health 94(11):1864-1874, section "Selective Primary Health Care" (p. 1868 in print; PDF p. 5)
Grade
Peer-reviewed
Document
https://doi.org/10.2105/AJPH.94.11.1864
Accessed
2026-11-09
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Exhibit 056 · Peer-reviewed comparative history

Philanthrocapitalism, past and present: The Rockefeller Foundation, the Gates Foundation, and the setting(s) of the international/global health agenda

It concludes that the Gates Foundation’s pervasive influence is nonetheless of grave concern both to democratic global health governance and to scientific independence

Compares how the Rockefeller and Gates foundations set the international health agenda. Concludes that the Gates Foundation's pervasive influence is of grave concern to democratic global health governance and to scientific independence.

Source
Anne-Emanuelle Birn, Hypothesis 12(1)
Date
2014
Quoted from
Abstract (Hypothesis 12(1)); Wayback copy of 2017-08-07
Grade
Peer-reviewed
Document
http://www.hypothesisjournal.com/?p=2503
Accessed
2026-11-09
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Note
Open copy: https://archive.wphna.org/wp-content/uploads/2015/04/2014-11-Hypothesis-Anne-Emanuelle-Birn-Rockefeller-and-Gates.pdf

Exhibit 057 · Peer-reviewed study

Who's leading WHO? A quantitative analysis of the Bill and Melinda Gates Foundation's grants to WHO, 2000–2024

All the 640 grants are earmarked for specific purposes.

Built a dataset of Gates Foundation grants to the WHO from the foundation's own website. The foundation made 640 grants worth $5.5 billion between 2000 and 2024 and supplied 9.5 percent of WHO revenues in 2010–2023. Of the $5.5 billion, $4.5 billion (82.6 percent) went to infectious diseases, $3.2 billion (58.9 percent) to polio, and $2.9 billion (53.3 percent) to vaccine programs.

Source
J. Kennedy and R. Thakrar, BMJ Global Health 10(10)
Date
28 October 2025
Quoted from
Findings, first paragraph
Grade
Peer-reviewed
Document
https://doi.org/10.1136/bmjgh-2024-015343
Accessed
2026-11-09
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Exhibit 058 · Data compilation

Largest voluntary contributors to the WHO, 2024–2025

Ranks the Gates Foundation as the largest contributor to the WHO in 2024-2025, with around 761 million U.S. dollars in voluntary contributions (data updated to December 2025).

Source
Statista, compiling WHO contribution data
Date
2025
Grade
Reported
Document
https://statista.com/statistics/1456464/largest-donors-who
Accessed
2026-11-09
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Exhibit 059 · Institutional web page

Donor profile: Gates Foundation

Its initial US$ 750 million commitment in 2000 was catalytic in establishing Gavi and mobilising support from other donors.

Gavi describes the Gates Foundation as one of its most influential supporters since its inception and lists a US$1.6 billion pledge for 2026–2030.

Source
Gavi, the Vaccine Alliance
Date
n.d. (current page)
Quoted from
Profile overview, first paragraph
Grade
Primary record
Document
https://www.gavi.org/investing-gavi/funding/donor-profiles/gates-foundation
Accessed
2026-11-09
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Exhibit 060 · Company press release

BioNTech announces new collaboration to develop HIV and tuberculosis programs

This partnership includes an initial equity investment of $55 million, which is expected to close within the next week.

The Gates Foundation made a $55 million equity investment in BioNTech, tied to HIV and tuberculosis programs, with total collaboration funding of up to about $100 million.

Source
BioNTech SE
Date
September 2019
Quoted from
BioNTech press release, 4 September 2019 (headline subtitle: collaboration "could reach up to $100 million in total funding")
Grade
Primary record
Document
https://www.biontech.com/us/en/home/mediaroom/news/press-releases/2019/09/biontech-announces-new-collaboration-develop-hiv-and.html
Accessed
2026-11-09
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Note
ImpactAlpha reports that the investment predated BioNTech's COVID-19 work and that the foundation gave no direct support to the Pfizer–BioNTech vaccine candidate: https://impactalpha.com/gates-foundations-role-in-pfizers-promising-covid-vaccine-is-part-of-a-strategy-not-a-conspiracy/

Exhibit 062 · Scenario report

Scenarios for the Future of Technology and International Development

Importantly, scenarios are not predictions. Rather, they are thoughtful hypotheses that allow us to imagine, and then to rehearse, different strategies for how to be more prepared for the future

Four hypothetical scenarios built on two axes, political and economic alignment and adaptive capacity: Lock Step, Clever Together, Hack Attack and Smart Scramble. Lock Step imagines a 2012 influenza pandemic followed by authoritarian top-down control. The report states that its scenarios are not predictions. The 'Rockefeller Playbook' and three-phase 'Operation Lockstep' texts circulated since 2020 do not appear in it.

Source
The Rockefeller Foundation and Global Business Network
Date
May 2010
Quoted from
Introduction, 'Why Scenarios?', printed p. 9
Grade
Primary record
Document
https://www.nommeraadio.ee/meedia/pdf/RRS/Rockefeller%20Foundation.pdf
Accessed
2026-11-09
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Exhibit 063 · Exercise documentation

Event 201: About

Event 201 was supported by funding from the Open Philanthropy Project.

A 3.5-hour pandemic tabletop exercise held on 18 October 2019 at The Pierre hotel, New York, hosted by the Center with the World Economic Forum and the Bill & Melinda Gates Foundation. Fifteen business, government and public health leaders played. The page names Clade X, Dark Winter and Atlantic Storm as the Center's previous exercises.

Source
Johns Hopkins Center for Health Security
Date
October 2019
Quoted from
About page, closing line
Grade
Primary record
Document
https://www.centerforhealthsecurity.org/event201/about
Archived
https://web.archive.org/web/20191226175027/http://www.centerforhealthsecurity.org/event201/about
Accessed
2026-11-09
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Exhibit 064 · Exercise documentation

Event 201: Scenario

The scenario ends at the 18-month point, with 65 million deaths.

The exercise modeled a fictional novel coronavirus transmitted from bats to pigs to people, beginning on pig farms in Brazil and modeled largely on SARS. In the scenario no vaccine is available in the first year, and the exercise ends at 18 months with 65 million deaths.

Source
Johns Hopkins Center for Health Security
Date
October 2019
Quoted from
Event 201 scenario page, first paragraph
Grade
Primary record
Document
https://www.centerforhealthsecurity.org/event201/scenario.html
Archived
https://web.archive.org/web/20200123144533/http://www.centerforhealthsecurity.org/event201/scenario.html
Accessed
2026-11-09
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Exhibit 065 · Policy recommendations

Public-private cooperation for pandemic preparedness and response: a call to action

Governments and the private sector should assign a greater priority to developing methods to combat mis- and disinformation prior to the next pandemic response. Governments will need to partner with traditional and social media companies to research and develop nimble approaches to countering misinformation. This will require developing the ability to flood media with fast, accurate, and consistent information. … For their part, media companies should commit to ensuring that authoritative messages are prioritized and that false messages are suppressed including though the use of technology.

Seven joint recommendations: plan the use of corporate capabilities in a pandemic; expand international countermeasure stockpiles with CEPI, Gavi and the WHO; maintain travel and trade, criticizing past 'unjustified border measures' and 'the closure of customer-facing businesses'; fund surge manufacturing of vaccines, therapeutics and diagnostics; enlist business advocacy; expand pandemic finance; and combat mis- and disinformation.

Source
Johns Hopkins Center for Health Security, World Economic Forum and Bill & Melinda Gates Foundation
Date
November 2019
Quoted from
Recommendation 7
Grade
Primary record
Document
https://www.centerforhealthsecurity.org/event201/recommendations.html
Archived
https://web.archive.org/web/20200122093208/http://www.centerforhealthsecurity.org/event201/recommendations.html
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2026-11-09
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Exhibit 066 · Institutional statement

Statement of clarification on Event 201

We are not now predicting that the nCoV-2019 outbreak will kill 65 million people. Although our tabletop exercise included a mock novel coronavirus, the inputs we used for modeling the potential impact of that fictional virus are not similar to nCoV-2019.

The Center states that it and its partners did not make a prediction during the exercise, that it is not predicting the nCoV-2019 outbreak will kill 65 million people, and that the inputs used to model the fictional virus are not similar to nCoV-2019.

Source
Johns Hopkins Center for Health Security
Date
24 January 2020
Quoted from
Statement about nCoV and our pandemic exercise, 24 Jan 2020, final paragraph
Grade
Primary record
Document
https://www.centerforhealthsecurity.org/newsroom/center-news/2020-01-24-Statement-of-Clarification-Event201.html
Archived
https://web.archive.org/web/20200125055553/http://centerforhealthsecurity.org/newsroom/center-news/2020-01-24-Statement-of-Clarification-Event201.html
Accessed
2026-11-09
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Exhibit 067 · Court opinion

Murthy v. Missouri, 144 S. Ct. 1972 (2024)

Because no plaintiff has carried that burden, none has standing to seek a preliminary injunction.

By 6–3, the Court reversed the Fifth Circuit's injunction against federal communications with social media platforms because no plaintiff had standing. It did not decide the First Amendment merits. The Fifth Circuit had found that the White House, the Surgeon General's office, the CDC and the FBI likely coerced or significantly encouraged the platforms' moderation decisions.

Source
Supreme Court of the United States
Date
26 June 2024
Quoted from
Murthy v. Missouri, 603 U.S. ___ (2024), No. 23-411, slip op., Syllabus p. 1 (June 26, 2024)
Grade
Primary record
Document
https://www.supremecourt.gov/opinions/23pdf/23-411_3dq3.pdf
Accessed
2026-11-09
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Note
Biden, No. 23-30445.

Exhibit 068 · Agency fact sheet

Fact sheet: U.S. withdrawal from the World Health Organization

In fulfillment of this directive and following the required one-year notice period, the United States Government formally exited from WHO on January 22, 2026.

Executive Order 14155, signed 20 January 2025, gave notice of United States withdrawal from the WHO. The withdrawal took effect on 22 January 2026, one year after notice.

Source
U.S. Department of Health and Human Services
Date
January 2026
Quoted from
HHS Fact Sheet "U.S. Withdrawal from the World Health Organization" (content last reviewed January 22, 2026), first section
Grade
Primary record
Document
https://www.hhs.gov/press-room/fact-sheet-us-withdrawal-from-the-world-health-organization
Accessed
2026-11-09
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Exhibit 069 · Agency news release

Seventy-ninth World Health Assembly, daily update, 19 May 2026

The World Health Assembly decided to continue the drafting and negotiation of the Pathogen Access and Benefit Sharing (PABS) Annex under the Intergovernmental Working Group (IGWG) on the WHO Pandemic Agreement.

The World Health Assembly decided to continue drafting and negotiating the Pathogen Access and Benefit Sharing (PABS) Annex of the WHO Pandemic Agreement under the Intergovernmental Working Group, and to submit the outcome to the Eightieth World Health Assembly.

Source
World Health Organization
Date
19 May 2026
Quoted from
WHO news item, Seventy-ninth World Health Assembly daily update, 19 May 2026, section "WHO Member States extend negotiations on Pathogen Access and Benefit Sharing system"
Grade
Primary record
Document
https://www.who.int/news/item/19-05-2026-seventy-ninth-world-health-assembly---daily-update--19-may-2026
Accessed
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Note
WHO's Pandemic Agreement Q&A states that the Agreement opens for signature after the Assembly adopts the PABS Annex: https://www.who.int/news-room/questions-and-answers/item/pandemic-prevention--preparedness-and-response-accord

Exhibit 070 · Court opinion

Gottsdanker v. Cutter Laboratories, 182 Cal.App.2d 602

from a preponderance of the evidence concluded that the defendant, Cutter Laboratories, was not negligent either directly or by inference.

Children paralyzed after receiving Cutter's 1955 Salk vaccine sued the manufacturer. At the 1958 trial the jury found Cutter not negligent and found it liable for breach of implied warranty. The appellate court affirmed, extending to vaccines the rule that allowed recovery without privity for defective food.

Source
California Court of Appeal, First District
Date
1960
Quoted from
Gottsdanker v. Cutter Laboratories, 182 Cal. App. 2d 602 (Cal. Ct. App. July 12, 1960), para. [16] (jury statement); disposition [50]-[51] "Judgments for plaintiffs affirmed"
Grade
Primary record
Document
https://biotech.law.lsu.edu/cases/vaccines/gottsdanker.htm
Accessed
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Exhibit 071 · History

The Cutter Incident: How America's First Polio Vaccine Led to the Growing Vaccine Crisis

About 120,000 doses of Cutter's April 1955 vaccine contained live poliovirus. Among vaccinated children, 56 developed paralytic polio, 51 of them permanently paralyzed, and 5 died. The resulting community spread paralyzed 113 family and community contacts and killed 5. Offit argues that liability without fault after Cutter drove manufacturers out of vaccine production.

Source
Paul A. Offit, Yale University Press
Date
2005
Grade
Reported
Document
https://yalebooks.yale.edu/book/9780300108644/the-cutter-incident/
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Note
Figures known through secondary summaries of the book.

Exhibit 072 · Surveillance report

Poliomyelitis Surveillance Unit, Special Report No. 2 (May 1955)

An eight-page working document marked 'not for publication / for official use only', prepared for the Public Health Service Expert Committee on Poliomyelitis. As of 13 May 1955 it counts 59 accepted cases among children vaccinated with Cutter's vaccine and 9 contact cases, dates the first reports to 27 April, and associates the cases with that manufacturer's vaccine; it finds nothing but coincidence for Wyeth or Lilly vaccine and no association for Pittman-Moore or Parke-Davis. It names Tennessee and Georgia. Its incubation table is monkey data.

Source
Communicable Disease Center, U.S. Public Health Service
Date
May 1955
Grade
Primary record
Document
https://stacks.cdc.gov/view/cdc/42228/cdc_42228_DS1.pdf
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Note
A companion report: https://stacks.cdc.gov/view/cdc/43902/cdc_43902_DS1.pdf

Exhibit 073 · Statute

Petitions for compensation, 42 U.S.C. § 300aa-11

No person may bring a civil action for damages in an amount greater than $1,000 or in an unspecified amount against

Bars any civil action for damages above $1,000, or in an unspecified amount, against a vaccine administrator or manufacturer for a vaccine-related injury unless the claimant has first filed a petition under the National Vaccine Injury Compensation Program and either received a judgment and elected to sue or withdrawn the petition.

Source
United States Congress (National Childhood Vaccine Injury Act of 1986)
Date
1986
Quoted from
§ 300aa-11(a)(2)(A)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/42/300aa-11
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Exhibit 074 · Court opinion

Needham v. Merck & Co., No. 24-1828, 151 F.4th 178

We hold that the addition of Gardasil to the Vaccine Table via 42 U.S.C. § 300aa-14(e) didn’t violate the constitution.

Affirmed dismissal of a Gardasil injury suit on Vaccine Act grounds of timeliness and exhaustion of the compensation program, and rejected a constitutional challenge to the addition of HPV vaccine to the Vaccine Injury Table. HPV vaccines have been covered by the program since 2007. The court did not decide preemption.

Source
U.S. Court of Appeals for the Fourth Circuit
Date
4 September 2025
Quoted from
In re Gardasil Prods. Liab. Litig. (Needham v. Merck), No. 24-1828 (4th Cir. Sept. 4, 2025) (published; Diaz, C.J.), introduction, slip op. pp. 10-11
Grade
Primary record
Document
https://www.ca4.uscourts.gov/opinions/241828.P.pdf
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Note
A petition for certiorari (No. 25-924) was filed 2 February 2026; its denial is reported only in secondary sources.

Exhibit 075 · Court order

In re Gardasil Products Liability Litigation, MDL No. 3036: order granting summary judgment on preemption

Granted Merck's Motion for Summary Judgment Based on Implied Preemption (Doc. 188) as to the bellwether plaintiffs, whose claims involved POTS and POI, on their state-law failure-to-warn claims. The court held that Merck could not have added the requested warnings to the FDA-approved label without newly acquired information. The order is to apply to other MDL plaintiffs by prior orders or agreement. Signed 10 March 2025; filed 11 March 2025.

Source
U.S. District Court, Western District of North Carolina (Judge Kenneth D. Bell), as reported
Date
11 March 2025
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/USCOURTS-ncwd-3_22-md-03036/pdf/USCOURTS-ncwd-3_22-md-03036-25.pdf
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2026-11-09
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Note
Order in In re Gardasil Products Liability Litigation, MDL No. 3036 (W.D.N.C.), govinfo docket USCOURTS-ncwd-3_22-md-03036, document 25.

Exhibit 076 · Journalism

Merck Form 10-Q for the quarter ended 30 June 2026 (Gardasil litigation)

Merck's quarterly report states that the Gardasil settlement agreement was first entered in October 2025 and that its conditions were met by the filing date. It gives no dollar amount or case count and describes the total payment as considerably less than Merck's anticipated costs of defense and not material to Merck. It states that the March 2025 preemption ruling covered 16 bellwether cases and that plaintiffs appealed to the Fourth Circuit. A Bloomberg headline of 4 June 2026 reported that Merck would settle the bulk of Gardasil suits for about $50 million; the figure is not in Merck's filing.

Source
Bloomberg News
Date
August 2026
Grade
Reported
Document
https://www.sec.gov/Archives/edgar/data/310158/000031015826000212/mrk-20260630.htm
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2026-11-09
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Note
The $50 million and 200-case figures remain press-reported only.

Exhibit 077 · Court opinion

Monsanto Co. v. Durnell, No. 24-1068, 609 U.S. ___

FIFRA expressly preempts Durnell's state-law failure-to-warn claim because the claim would require Monsanto to add a cancer warning to Roundup's label.

Held 7–2 (Kavanaugh, J., for the Court; Jackson, J., dissenting, joined by Gorsuch, J.) that FIFRA expressly preempts a state failure-to-warn claim that would require a cancer warning on Roundup's EPA-approved label. Reversed a Missouri verdict of more than $1 million. The opinion's account of EPA's cancer conclusions cites the Ninth Circuit's 2022 decision vacating EPA's 2020 glyphosate decision.

Source
Supreme Court of the United States
Date
25 June 2026
Quoted from
Slip opinion, syllabus, p. 1
Grade
Primary record
Document
https://www.supremecourt.gov/opinions/25pdf/24-1068_n7ip.pdf
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Exhibit 078 · Court filing

Brief for the United States as amicus curiae, Monsanto Co. v. Durnell (petition stage)

In light of the Third Circuit’s intervening decision in Schaffner and the change in Administration, the United States has reexamined the arguments it pressed before this Court in Hardeman and has returned to its previous position as to the scope of FIFRA preemption.

Urged the Court to grant review and argued that FIFRA preempts the failure-to-warn claim. Records that in Monsanto v. Hardeman (No. 21-241) the government had argued against preemption and against review, after arguing for preemption in the court of appeals in the same case.

Source
U.S. Department of Justice, Office of the Solicitor General (D. John Sauer)
Date
December 2025
Quoted from
Brief, pp. 10–11
Grade
Primary record
Document
https://www.supremecourt.gov/DocketPDF/24/24-1068/386073/20251201170732560_24-1068%20--%20Monsanto%20v.%20Durnell.pdf
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Exhibit 079 · Court opinion

Natural Resources Defense Council v. EPA, No. 20-70787, 38 F.4th 34

We VACATE the human health portion of the Interim Decision and REMAND for further consideration.

Vacated the human-health portion of EPA's January 2020 interim registration review decision for glyphosate, finding the conclusion that glyphosate is not likely to be carcinogenic inconsistent with EPA's own cancer guidelines, and remanded.

Source
U.S. Court of Appeals for the Ninth Circuit
Date
17 June 2022
Quoted from
NRDC v. EPA, No. 20-70787 (9th Cir. June 17, 2022), final section (PDF p. 54 of 55); cancer-guideline analysis around PDF pp. 24-27
Grade
Primary record
Document
https://cdn.ca9.uscourts.gov/datastore/opinions/2022/06/17/20-70787.pdf
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Exhibit 080 · Agency notice

EPA withdraws glyphosate interim decision

EPA’s underlying scientific findings regarding glyphosate, including its finding that glyphosate is not likely to be carcinogenic to humans, remain the same.

EPA withdrew the entire 2020 interim registration review decision for glyphosate and set 2026 as the target for a final decision. Glyphosate products remained on the market.

Source
U.S. Environmental Protection Agency
Date
September 2022
Quoted from
Release of 23 September 2022, paragraph 6
Grade
Primary record
Document
https://www.epa.gov/pesticides/epa-withdraws-glyphosate-interim-decision
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2026-11-09
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Exhibit 081 · Journalism

EPA and HHS announce new scientific partnership to strengthen glyphosate review

On 23 September 2026 EPA and HHS announced a memorandum of understanding for a scientific partnership to strengthen the glyphosate review. EPA states that the new decision is expected in early 2027 and that the agreement 'does not predetermine or direct the outcome.'

Source
EHS Leaders, reporting an EPA–HHS memorandum of understanding
Date
23 September 2026
Grade
Primary record
Document
https://www.epa.gov/newsreleases/epa-and-hhs-announce-new-scientific-partnership-strengthen-glyphosate-review
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Note
The memorandum of understanding itself would add the agreement's text.

Exhibit 082 · Executive order

Executive Order 14387: Promoting the National Defense by Ensuring an Adequate Supply of Elemental Phosphorus and Glyphosate-Based Herbicides

This order confers all immunity provided for in section 707 of the Act (50 U.S.C. 4557).

Invokes section 101 of the Defense Production Act and delegates prioritization and allocation authority over elemental phosphorus and glyphosate-based herbicides to the Secretary of Agriculture. Directs that no order under it place the corporate viability of a domestic producer at risk. Requires domestic producers to comply under 7 CFR part 789. Its findings concern defense supply and agriculture; it makes no finding on the health effects of glyphosate.

Source
The White House (Federal Register, Vol. 91, No. 35, pp. 8703–8705)
Date
18 February 2026
Quoted from
Sec. 3
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2026-02-23/html/2026-03628.htm
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Exhibit 083 · Roll-call vote

Roll Call 148: Luna amendment to H.R. 7567 (farm bill)

The House agreed 280–142 to the Luna amendment (Part B Amendment No. 28), which struck the bill's pesticide labeling-uniformity and preemption provisions, including Section 10205. The House then passed the farm bill 224–200.

Source
Clerk of the U.S. House of Representatives
Date
30 April 2026
Grade
Primary record
Document
https://clerk.house.gov/Votes/2026148
Accessed
2026-11-09
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Note
The content of the amendment is described in farmdoc daily and E&E News coverage: https://farmdocdaily.illinois.edu/2026/04/chemical-collision-the-pesticide-provisions-that-nearly-derailed-the-house-bill.html

Exhibit 084 · Journalism

Legal immunity for pesticide companies removed from EPA funding bill

The provision, referred to as Section 435, would have made it harder for individuals to sue pesticide manufacturers over alleged health harms.

Appropriators removed a pesticide labeling-immunity provision from the fiscal year 2026 EPA funding bill.

Source
Civil Eats
Date
6 January 2026
Quoted from
Civil Eats (Lisa Held), 6 January 2026, paragraph 3 (live fetch; the page is partly member-gated but this text was shown)
Grade
Reported
Document
https://civileats.com/2026/01/06/legal-immunity-for-pesticide-companies-removed-from-epa-funding-bill/
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Exhibit 085 · State statute

North Dakota HB 1318, relating to pesticide labeling

AN ACT to create and enact a new section to chapter 28-01.3 of the North Dakota Century Code, relating to pesticide labeling.

Adds a pesticide-labeling section to chapter 28-01.3 of the North Dakota Century Code. Passed the House 88–0 and the Senate 29–18 and was signed by Governor Kelly Armstrong in late April 2025, the first state law of its kind.

Source
North Dakota Legislative Assembly
Date
April 2025
Quoted from
Bill overview page, 'Title'
Grade
Primary record
Document
https://ndlegis.gov/assembly/69-2025/regular/bill-overview/bo1318.html
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2026-11-09
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Exhibit 086 · Journalism

Georgia becomes second US state to shield maker of Roundup from some cancer claims

The new Georgia law is to take effect Jan. 1. That means it won’t effect existing cases

Governor Brian Kemp signed SB 144 in May 2025, making Georgia the second state to shield pesticide makers from some cancer failure-to-warn claims. The law does not apply to existing cases.

Source
WABE / Associated Press
Date
May 2025
Quoted from
AP story, May 12, 2025, paragraph beginning 'The new Georgia law'
Grade
Reported
Document
https://www.wabe.org/georgia-becomes-second-us-state-to-shield-maker-of-roundup-weed-killer-from-some-cancer-claims/
Accessed
2026-11-09
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Note
Sources disagree on the effective date.

Exhibit 087 · Journalism

Report on the first St. Louis Roundup trial after Durnell

involves three women who are not participating in the proposed settlement and are pursuing claims that Roundup was defectively designed and unsafe for sale, legal theories that the Supreme Court’s June ruling did not directly address.

A St. Louis trial on design-defect claims by plaintiffs outside the class settlement began on 29 September 2026. Design-defect and negligence theories were not reached by Durnell.

Source
Insurance Journal
Date
1 October 2026
Quoted from
Reuters article by Dietrich Knauth, 1 October 2026, paragraph 3
Grade
Reported
Document
https://www.insurancejournal.com/news/national/2026/10/01/887450.htm
Accessed
2026-11-09
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Exhibit 088 · Interview

The Joe Rogan Experience #2578, Calley Means

Means, a former White House adviser, said that liability protection would make glyphosate the second product after vaccines that cannot be sued over (26:42; repeated at 33:34).

Source
Calley Means, on The Joe Rogan Experience
Date
November 2026
Grade
Reported
Document
https://www.youtube.com/watch?v=dMBBOawFy_4
Accessed
2026-11-09
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Note
Wording taken from auto-generated captions; not quoted on the site for that reason.

Exhibit 089 · Record comparison and meta-analysis

Selective publication of antidepressant trials and its influence on apparent efficacy

According to the published literature, it appeared that 94% of the trials conducted were positive. By contrast, the FDA analysis showed that 51% were positive.

Compared FDA reviews of 74 trials of 12 antidepressants (12,564 participants) with the published literature. FDA judged 38 trials positive; 37 were published as positive and one was unpublished. Of 36 trials FDA judged negative or questionable, 22 were unpublished, 11 were published as positive and 3 were published conveying a negative result. Published trials appeared positive in 48 of 51 cases (94%), against 38 of 74 (51%) in FDA review. The 23 unpublished trials enrolled 3,449 participants. Published data inflated the pooled effect size by 32%. The authors could not determine whether sponsors, authors or journals caused the missing publications.

Source
Turner et al., New England Journal of Medicine
Date
2008
Quoted from
Abstract (PubMed PMID 18199864), Results
Grade
Peer-reviewed
Document
https://pubmed.ncbi.nlm.nih.gov/18199864/
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Note
PubMed record: https://pubmed.ncbi.nlm.nih.gov/18199864/.

Exhibit 090 · Record comparison and meta-analysis

Selective publication of antidepressant trials, newer drugs: follow-up comparison with FDA records

Within negative trials, transparent reporting increased from 11% to 47%.

Examined 30 trials of four newer antidepressants (13,747 participants). All 15 FDA-positive trials were transparently published. Of 15 negative trials, seven were transparently published, six were unpublished and two were presented as positive. Transparent publication of negative trials rose from 11% in the authors' older comparison to 47%. Standardized effect size was 0.24 in FDA records and 0.29 in journals. The study covered efficacy outcomes and a small drug sample; it did not establish equivalent improvement in safety reporting.

Source
Turner et al., PLOS Medicine
Date
2022
Quoted from
Abstract-level summary (Methods and findings), PLOS Medicine 2022
Grade
Peer-reviewed
Document
https://journals.plos.org/plosmedicine/article?id=10.1371/journal.pmed.1003886
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Exhibit 091 · Randomized trial report

Efficacy of paroxetine in the treatment of adolescent major depression: a randomized, controlled trial (Study 329)

generally well tolerated and effective for major depression in adolescents

Reported an eight-week, randomized, double-blind comparison of paroxetine, imipramine and placebo in 275 adolescents with major depression. The favorable results emphasized particular symptom measures. PubMed now links the article to a 2025 expression of concern.

Source
Keller et al., Journal of the American Academy of Child and Adolescent Psychiatry
Date
2001
Quoted from
Abstract, conclusions
Grade
Peer-reviewed
Document
https://pubmed.ncbi.nlm.nih.gov/11437014/
Accessed
2026-11-09
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Exhibit 092 · Independent reanalysis

Restoring Study 329: efficacy and harms of paroxetine and imipramine in treatment of major depression in adolescence

The efficacy of paroxetine and imipramine was not statistically or clinically significantly different from placebo for any prespecified primary or secondary efficacy outcome.

Reanalyzed Study 329 using the original protocol and underlying trial records. Neither paroxetine nor imipramine showed superiority over placebo on the prespecified efficacy variables. Patients with suicidal or self-injurious behaviors on paroxetine (n=93), imipramine (n=95) and placebo (n=87): 5, 3 and 1 in the original publication; 7, 3 and 1 in the sponsor's acute-phase report; 11, 4 and 2 in the reanalysis, which covered the acute and taper phases and included one possible case in each comparator group. The authors acknowledged that different coding and phase assignments change the counts.

Source
Le Noury et al., BMJ (Restoring Invisible and Abandoned Trials initiative)
Date
September 2015
Quoted from
Abstract, Results
Grade
Peer-reviewed
Document
https://www.bmj.com/content/351/bmj.h4320
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2026-11-09
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Note
Full published PDF hosted by the authors: https://study329.org/wp-content/uploads/2015/09/Study-329-Final.pdf (safety counts at Table 6, p. 10).

Exhibit 093 · Correspondence

Response from the authors of the original Study 329

The original investigators stated that the secondary measures were added before the blind was broken, by the academic authors, because the original depression scale measured adolescents' symptoms poorly; that their article distinguished negative primary outcomes from favorable secondary results; and that the reanalysis was biased and its RIAT method undocumented.

Source
Keller et al., BMJ rapid response
Date
2015
Grade
Reported
Document
https://www.bmj.com/content/351/bmj.h4320/rr-27
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Note
Full BMJ rapid-response page (rr-27). Wording as reported in the secondary copy: These secondary outcomes were clearly reported as separate from the negative primary outcomes.

Exhibit 094 · Journal notice

Expression of concern: Efficacy of paroxetine in the treatment of adolescent major depression

The Journal of the American Academy of Child and Adolescent Psychiatry attached an expression of concern to the 2001 Study 329 article (online 30 September 2025; 2026 Jun;65(6):852; PMID 41925712). An expression of concern is not a retraction.

Source
Journal of the American Academy of Child and Adolescent Psychiatry
Date
Online 30 September 2025; June 2026 issue (vol. 65, no. 6, p. 852)
Grade
Primary record
Document
https://doi.org/10.1016/j.jaac.2025.09.032
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Exhibit 095 · Cohort study

Compliance with legal requirement to report clinical trial results on ClinicalTrials.gov: a cohort study

4209 trials were due to report results; 1722 (40·9%; 95% CI 39·4-42·2) did so within the 1-year deadline.

Of 4,209 trials due to report results under the FDA Amendments Act Final Rule, 1,722 (40.9%) had submitted results on time by the 16 September 2019 cutoff, and 2,686 (63.8%) had submitted by that date, counting submissions under quality review. Trials not yet due, outside the rule, or granted a delay were excluded. Industry sponsors had higher adjusted odds of compliance than non-industry, non-US-government sponsors (OR 3.08, 95% CI 2.52–3.77).

Source
DeVito et al., The Lancet
Date
2020
Quoted from
Abstract, Findings (PubMed PMID 31958402; Lancet 2020;395:361-369)
Grade
Peer-reviewed
Document
https://doi.org/10.1016/S0140-6736(19)33220-9
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Note
Author-institution abstract: https://www.bennett.ox.ac.uk/papers/172/.

Exhibit 096 · Agency register

ClinicalTrials.gov notices of noncompliance

If a responsible party does not take adequate corrective action within 30 calendar days after receiving a Notice of Noncompliance, FDA has authority to pursue regulatory or enforcement actions, which could include civil money penalties, injunctions, and/ or criminal prosecution.

FDA's table of ClinicalTrials.gov notices of noncompliance lists 12 notices, the oldest being Acceleron Pharma (NCT01727336), notice dated 27 April 2021, response dated 13 December 2021, and the latest Duchesnay on 19 October 2026. The table records no penalty outcomes.

Source
U.S. Food and Drug Administration
Date
April 2021 onward
Quoted from
FDA Notices of Noncompliance page (content current as of 10/30/2026), paragraph 3
Grade
Primary record
Document
https://www.fda.gov/science-research/fdas-role-clinicaltrialsgov-information/clinicaltrialsgov-notices-noncompliance
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First-notice announcement: https://content.govdelivery.com/accounts/USFDA/bulletins/2d64939 (28 April 2021).

Exhibit 097 · Oversight report

Delays in confirmatory trials for drug applications granted FDA's accelerated approval raise concerns

Of those 104, 34 percent (35 of 104) have at least one trial past its original planned completion date.

Identified 278 accelerated approval applications through December 2021. Of 104 with incomplete confirmatory trials, 35 had at least one trial past its original planned completion date, with trial status as of 5 May 2022. Medicare and Medicaid spent more than $18 billion from 2018 to 2021 on the 18 drugs corresponding to those 35 applications. The figure is total spending on those drugs, not spending after deadlines or proven waste.

Source
U.S. Department of Health and Human Services, Office of Inspector General
Date
2022
Quoted from
OIG report page (OEI-01-21-00401), 'What we found', paragraph 1
Grade
Primary record
Document
https://oig.hhs.gov/reports/all/2022/delays-in-confirmatory-trials-for-drug-applications-granted-fdas-accelerated-approval-raise-concerns/
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Further quotation: “Of all 278 drug applications granted accelerated approval, 104 have incomplete confirmatory trials.” (HHS-OIG report page, 'What We Found'; the page gives 'Issued on 09/29/2022 | Posted on 09/29/2022 | Report number: OEI-01-21-00401'). Same paragraph: 'Furthermore, since the inception of the pathway, 13 percent of all accelerated approval drug applications have been withdrawn, half of which were withdrawn since January 2021.' The OIG full-report PDF (oig.hhs.gov/documents/evaluation/10120/OEI-01-21-00401.pdf) did not load; only the report web page was read.

Exhibit 098 · Regulatory cohort study

Clinical benefit and regulatory outcomes of cancer drugs receiving accelerated approval

Among 46 indications with more than 5 years of follow-up (approved 2013-2017), approximately two-thirds (29, 63%) were converted to regular approval, 10 (22%) were withdrawn, and 7 (15%) remained ongoing after a median of 6.3 years.

Followed 46 cancer drug–indication pairs granted accelerated approval in 2013–2017, with records through 2023. Twenty demonstrated overall-survival or quality-of-life benefit; nine converted to regular approval without demonstrating either; ten were withdrawn; seven remained pending.

Source
Liu, Kesselheim and Cliff, JAMA
Date
2024
Quoted from
Abstract, Results (JAMA 2024;331(17):1471-1479; PubMed PMID 38583175)
Grade
Peer-reviewed
Document
https://jamanetwork.com/journals/jama/fullarticle/2817337
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2026-11-09
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Note
DOI 10.1001/jama.2024.2396.

Exhibit 099 · Oversight report

How FDA used its accelerated approval pathway raised concerns in 3 of 24 drugs reviewed (OEI-01-21-00400)

This review focused on a sample of 24 drugs that went through the accelerated approval pathway; it is not a compliance review. We did not independently assess the appropriateness of the decisions made by FDA.

Reviewed 24 accelerated approvals, ten selected purposively and fourteen at random. Found unplanned analyses, internal disagreements or incomplete meeting documentation in three: aducanumab, hydroxyprogesterone caproate and eteplirsen. OIG stated the work was not a compliance review and did not independently judge the appropriateness of FDA's decisions. The recommendation tracker records on 18 May 2026 that the documentation recommendation was implemented and the recommendation on council referral criteria was not.

Source
U.S. Department of Health and Human Services, Office of Inspector General
Date
2025
Quoted from
OEI-01-21-00400 (January 2025), Background, Methodology (printed pp. 7-8)
Grade
Primary record
Document
https://www.oig.hhs.gov/documents/evaluation/10160/OEI-01-21-00400.pdf
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2026-11-09
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Note
Summary page and recommendation tracker: https://www.oig.hhs.gov/reports/all/2025/how-fda-used-its-accelerated-approval-pathway-raised-concerns-in-3-of-24-drugs-reviewed/ (methodology at printed pp. 7–9).

Exhibit 100 · Draft guidance

Accelerated approval and considerations for determining whether a confirmatory trial is underway (draft guidance)

may require, as appropriate, a study or studies to be underway prior to approval, or within a specified time period after the date of approval, of the applicable product.

Draft guidance that, when finalized, will describe FDA's interpretation of when a confirmatory trial is 'underway' under the authority granted by the Consolidated Appropriations Act, 2023, under which FDA may require a confirmatory trial to be underway before accelerated approval or within a specified period afterward. The page is marked 'Draft. Not for implementation. Contains non-binding recommendations'; its content is current as of 6 January 2025.

Source
U.S. Food and Drug Administration
Date
January 2025
Quoted from
FDA guidance page (Oncology Center of Excellence, January 2025, docket FDA-2024-D-3334), summary paragraph, quoting section 506(c) as amended by the CAA 2023
Grade
Primary record
Document
https://www.fda.gov/regulatory-information/search-fda-guidance-documents/accelerated-approval-and-considerations-determining-whether-confirmatory-trial-underway
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Exhibit 101 · Journal notice

Retraction notice: Williams, Kroes and Munro, Safety evaluation and risk assessment of the herbicide Roundup and its active ingredient, glyphosate, for humans (2000)

Retraction Watch reports that the retraction notice, posted online in November 2025 and running over 1,000 words, cites Monsanto employees' 'apparent contributions' as co-writers without acknowledgment and reliance on unpublished Monsanto studies although other studies existed. It quotes a Monsanto email from toxicologist William Heydens, written about a later paper: 'Recall this is how we handled Williams Kroes & Munro 2000.' It reports that New York Medical College told Science in 2017 it had found no evidence that Williams violated its ghostwriting policy, and that Kroes died in 2006 and Munro in 2011.

Source
Regulatory Toxicology and Pharmacology (Elsevier), reported by Retraction Watch
Date
November 2025
Grade
Reported
Document
https://retractionwatch.com/2025/12/04/glyphosate-safety-article-retracted-elsevier-monsanto-ghostwriting
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2026-11-09
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Note
Additional report: https://www.thenewlede.org/2025/12/citing-serious-ethical-concerns-journal-retracts-key-monsanto-roundup-safety-study/

Exhibit 102 · Journal correction

Correction to the 2016 Intertek expert panel overview paper on glyphosate

The 2018 correction to the overview paper of the Intertek expert panel (10.1080/10408444.2016.1214677), published in a 2016 supplement of Critical Reviews in Toxicology, adds the contributions of Barry Lynch (Intertek) and William Heydens (Monsanto) to the acknowledgments. The corrections state that Monsanto funded Intertek.

Source
Critical Reviews in Toxicology (Taylor & Francis)
Date
2018
Grade
Primary record
Document
https://doi.org/10.1080/10408444.2018.1522175
Accessed
2026-11-09
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Note
2016 supplement: https://doi.org/10.1080/10408444.2016.1214680. A separate corrigendum, 10.1080/10408444.2018.1522784, adds only Barry Lynch as writer of the Introduction to the carcinogenicity bioassay panel paper (10.1080/10408444.2016.1214679) and does not name Heydens.

Exhibit 103 · Journalism reporting an agency document

EPA Inspector General memo on Monsanto's role in Kier and Kirkland (2013)

An EPA OIG memo, from an inquiry opened in 2017, concluded that Monsanto's David Saltmiras made substantive contributions to Kier and Kirkland's 2013 genotoxicity review in Critical Reviews in Toxicology while credited only in the acknowledgments, which the memo calls a form of research misconduct. 2012 emails show Kirkland rejecting co-authorship for Saltmiras because it would undermine the review's independent status. EPA's 2020 glyphosate assessment relied on the review for data and for summaries of 16 other studies; EFSA cited it in 2023. EPA knew of the OIG finding and did not disclose it. Kirkland denies ghostwriting; Bayer says the memo used limited documents. Taylor & Francis opened an investigation after Oreskes and Kaurov requested retraction.

Source
Mother Jones, reporting an EPA Office of Inspector General memo
Date
23 June 2026
Grade
Reported
Document
https://www.motherjones.com/environment/2026/06/epa-roundup-glyphosate-monsanto-ghostwritten-herbicide-cancer-bayer/
Accessed
2026-11-09
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Exhibit 104 · Internal corporate document

Monsanto public relations plan for the IARC glyphosate decision

A Monsanto plan from a February 2015 memo, written before IARC's March 2015 decision, set the goal 'Orchestrate Outcry with IARC Decision—Industry conducts robust media/social media outreach on process and outcome' and named the Genetic Literacy Project among three industry partners.

Source
Monsanto, as published by U.S. Right to Know
Date
February 2015
Grade
Reported
Document
https://usrtk.org/pesticides/how-monsanto-manufactured-outrage-at-iarc-over-cancer-classification/
Accessed
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Note
Advocacy-organization publication. Plaintiffs' exhibit PTX 0379 is a different draft of 12 February 2015 ('Key Points Following IARC Decision') that refers to 'the orchestrated outcry that could occur following the March 3-10 IARC monograph expert meeting'; it has no tier list.

Exhibit 105 · Commissioned legal review

Report on behalf of Bayer AG on Monsanto stakeholder lists

Sidley Austin's report for Bayer on FleishmanHillard's stakeholder lists for Monsanto reports that 1,475 individuals were notified, and that 14 list documents held 1,208 names covering France, Germany, Italy, the Netherlands, Poland, Spain, the United Kingdom and EU-institution lists. Sidley found no support for the allegation of illegality.

Source
Sidley Austin LLP for Bayer AG
Date
5 September 2019
Grade
Primary record
Document
https://www.bayer.com/sites/default/files/SA_Report%20on%20Behalf%20of%20Bayer%20AG%20%285%20September%202019%29.pdf
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Note
Context for the French list, the Le Monde complaint and the agency's suspension: https://corporateeurope.org/en/2019/09/fleishmanhillards-secret-lobby-campaign-monsanto; https://www.ecowatch.com/bayer-pr-firm-investigation-monsanto-file-2637187810.html. Those details are not in the report and are not exhibits yet.

Exhibit 106 · Laboratory test record, known secondhand

Bernice Eddy's safety tests of Cutter polio vaccine lots

Eddy, a scientist at the NIH Laboratory of Biologics Control, tested Cutter Laboratories' Salk vaccine in monkeys and found that three of six lots paralyzed them, showing live poliovirus. She reported the results to the laboratory's chief, William Workman. The results were not passed to the vaccine licensing advisory committee, which recommended Cutter for licensure on 12 April 1955. On 29 April 1955 NIH director William Sebrell chaired a meeting on the incident that produced no conclusion on what Cutter should change in its manufacturing.

Source
Laboratory of Biologics Control, National Institutes of Health; known through Wikipedia, "Bernice Eddy"
Date
1954 or spring 1955 (accounts differ)
Grade
Reported
Document
https://en.wikipedia.org/wiki/Bernice_Eddy
Accessed
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Note
Secondary. Accounts disagree on the test date: Wikipedia has given 1954; other accounts place the tests in spring 1955, before licensure. Some accounts say NIH director William Sebrell also disregarded the results and that Eddy's photographs of paralyzed monkeys were not returned.

Exhibit 107 · Archival finding aid

Oral history interview with Bernice Eddy, 4 December 1986 (finding aid)

Cutter scandal; William Sebrell, James Shannon, Joseph Smadel; holding back her polio vaccine research

The National Library of Medicine holds an NIH/NCI oral-history interview with Bernice Eddy. The finding aid lists its topics as including "the Cutter scandal; William Sebrell, James Shannon, Joseph Smadel; holding back her polio vaccine research."

Source
National Library of Medicine; NIH/NCI oral history program
Date
4 December 1986
Quoted from
NLM finding aid, Scope and Contents (OH 136, Box 1, Folder 5; interview 4 Dec 1986)
Grade
Primary record
Document
https://findingaids.nlm.nih.gov/repositories/4/archival_objects/30845
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Note
The finding aid lists topics only.

Exhibit 108 · Reference summary

Oversight findings and departures of officials after the Cutter incident

Cutter was among the manufacturers recommended for a license on 12 April 1955, the day the Francis field-trial results were announced. A June 1955 congressional hearing concluded that the problem was primarily a lack of scrutiny by the NIH Laboratory of Biologics Control. Secretary of Health, Education, and Welfare Oveta Culp Hobby stepped down and NIH director William H. Sebrell Jr. resigned.

Source
Wikipedia, "Cutter Laboratories", citing the June 1955 congressional hearing and Offit (2005)
Date
1955
Grade
Reported
Document
https://en.wikipedia.org/wiki/Cutter_Laboratories
Accessed
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Note
Secondary. No source found that Surgeon General Leonard Scheele was dismissed.

Exhibit 109 · Research article

The vacuolating virus, S.V.40

Vacuolating virus strains S207, S211 and S215 were derived from types 1, 2 and 3, respectively, of Dr. Albert Sabin’s live attenuated poliomyelitis vaccine.

Merck researchers isolated and named simian virus 40, a vacuolating virus present in the rhesus monkey kidney cell cultures used to make polio vaccine. Several of their isolates came from seed strains of Sabin's live oral polio vaccine.

Source
Ben H. Sweet and Maurice R. Hilleman, Merck Institute for Therapeutic Research; Proceedings of the Society for Experimental Biology and Medicine 105:420–427
Date
November 1960
Quoted from
Sweet & Hilleman, Proc Soc Exp Biol Med 105:420-427 (1960), Results, 'Recovery of strains of vacuolating virus', p. 421 (Table I)
Grade
Peer-reviewed
Document
https://doi.org/10.3181/00379727-105-26128
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Note
The article itself was not opened; citation and description come from bibliographic records and the IOM report's attribution.

Exhibit 110 · History

The Virus and the Vaccine: The True Story of a Cancer-Causing Monkey Virus, Contaminated Polio Vaccine, and the Millions of Americans Exposed

On 6 July 1960 Bernice Eddy reported to her chief, Joseph Smadel, that extracts of the monkey kidney cells used to make polio vaccine caused cancers in hamsters. After she presented the work at a New York cancer meeting in October 1960, she was denied permission to attend scholarly conferences, her papers were held up, and she was removed from vaccine research. In 1961 federal officials ordered manufacturers to screen new vaccine for SV40 and did not recall existing stocks. Appendix B reproduces correspondence among Eddy, Smadel and Division of Biologics Standards chief Roderick Murray.

Source
Debbie Bookchin and Jim Schumacher, St. Martin's Press
Date
2004
Grade
Reported
Document
https://wellcomecollection.org/works/k43rsvss
Accessed
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Note
The authors' account of why officials did not announce the discovery is their interpretation; no internal memo stating a motive was found.

Exhibit 111 · Congressional hearing transcript

The SV-40 Virus: Has Tainted Polio Vaccine Caused an Increase in Cancer? (Serial No. 108-85)

They did contain SV-40 because there are test results that I have, which now the committee has, that show the positive vacuolating agent in released product.

James Goedert of the National Cancer Institute testified that in 1961 Bernice Eddy detected cancer in newborn hamsters injected with the vaccine preparation, and that "since 1963 every lot of vaccine has been tested and certified as free of SV-40." He testified that Howard Strickler was a former postdoctoral fellow from his branch with whom the branch had collaborated until recently. Barbara Loe Fisher testified that contaminated Salk stocks continued to be given to American children until early 1963, and that the major oral vaccine maker did not adequately test its master seed stocks. Attorney Stanley Kops testified that Wyeth-Lederle held 84 percent of the oral polio vaccine market in 1964–67 and that test results in his possession showed SV40 in released product.

Source
U.S. House of Representatives, Committee on Government Reform, Subcommittee on Human Rights and Wellness
Date
10 September 2003
Quoted from
House Government Reform Committee hearing (CHRG-108hhrg91047), 10 September 2003, testimony of Stanley P. Kops, second panel
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/CHRG-108hhrg91047/html/CHRG-108hhrg91047.htm
Accessed
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Testimony by witnesses other than federal officials is graded as reported where a finding rests on it.

Exhibit 112 · Agency web page

Historical Vaccine Safety Concerns: Simian virus 40

From 1955 to 1963, an estimated 10-30% of polio vaccines administered in the US were contaminated with simian virus 40 (SV40).

CDC states that from 1955 to 1963 an estimated 10–30% of polio vaccines administered in the United States were contaminated with SV40, mostly inactivated vaccine but also oral vaccine. It states that after the contamination was discovered the government set testing requirements to verify that all new lots were free of SV40, that most studies are reassuring and find no causal association with cancer, and that no vaccine used today contains SV40.

Source
Centers for Disease Control and Prevention
Date
Current page, accessed 2026
Quoted from
CDC 'Historical Vaccine Safety Concerns', section 'Simian Virus 40 (SV40): 1955 - 1963', paragraph 1
Grade
Primary record
Document
https://www.cdc.gov/vaccine-safety/historical-concerns/
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Exhibit 113 · Agency fact sheet, archived

Cancer, Simian Virus 40 (SV40), and Polio Vaccine Fact Sheet (archived)

it has been estimated that 10 - 30 million Americans could have received an SV40 contaminated dose of vaccine.

A CDC fact sheet on SV40 and polio vaccine described the contamination and estimated that 10–30 million Americans may have received a contaminated dose. The page no longer appears on CDC's site. Copies survive in the University of North Texas end-of-term web archive (2008) and the Internet Archive (2011).

Source
Centers for Disease Control and Prevention
Date
2007; archived copies 2008 and 2011
Quoted from
CDC NIP fact sheet 'Simian Virus 40 (SV40), Polio Vaccine, and Cancer', 'What You Should Know', bullet 3 (UNT End of Term capture of 28 Oct 2008)
Grade
Primary record
Document
https://webarchive.library.unt.edu/eot2008/20081028051234/http://www.cdc.gov/nip/vacsafe/concerns/cancer/sv40-polio-cancer-facts.htm
Accessed
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Note
Snopes describes the material as moved and updated rather than deleted. The date of removal is unverified.

Exhibit 114 · Consensus report

Immunization Safety Review: SV40 Contamination of Polio Vaccine and Cancer

The committee found the evidence 'inadequate to accept or reject a causal relationship' between SV40-containing polio vaccines and cancer. It rated as strong the evidence that SV40 is a transforming virus and that some polio vaccine of 1955 to 1963 was contaminated, and as moderate the evidence that vaccine exposure caused human SV40 infection. It judged the epidemiological studies too flawed to settle causation, because they assigned exposure by birth cohort and contamination was uneven. It recommended a Vaccine Contamination Prevention and Response Plan and serologic tests, and no policy review of current polio vaccine because it is free of SV40.

Source
Institute of Medicine, Immunization Safety Review Committee
Date
October 2002 (published 2003)
Grade
Primary record
Document
https://nap.nationalacademies.org/catalog/10534
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Exhibit 115 · Cohort study

Contamination of poliovirus vaccines with simian virus 40 (1955–1963) and subsequent cancer rates

Last, mesotheliomas were not significantly associated with exposure, although the cohorts studied have not yet reached the age at which these tumors tend to occur.

Using SEER registry and national mortality data, the study compared birth cohorts likely to have received contaminated vaccine with unexposed cohorts. It found no significant excess of ependymoma, other brain cancers, osteosarcoma or mesothelioma. Exposure was assigned by birth year; the study had no individual vaccination records.

Source
Howard D. Strickler, Philip S. Rosenberg, Susan S. Devesa, Joan Hertel, Joseph F. Fraumeni Jr., James J. Goedert; JAMA 279(4):292–295
Date
28 January 1998
Quoted from
Abstract, Results (JAMA 1998;279(4):292-5; PubMed PMID 9450713)
Grade
Peer-reviewed
Document
https://doi.org/10.1001/jama.279.4.292
Accessed
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Exhibit 116 · Agency debarment decision

Notice of Debarment and Action Referral Memorandum for Final Debarment, EcoHealth Alliance, Inc.

NIAID awarded grant 1R01AI110964, 'Understanding the Risk of Bat Coronavirus Emergence,' to EcoHealth Alliance on 27 May 2014 (project period 1 June 2014 to 31 May 2019), with the Wuhan Institute of Virology as a consortium participant. From 2018 the award required immediate notification of any experiment producing virus growth more than 1 log above wild type. EcoHealth submitted its Year 5 progress report on 3 August 2021, nearly two years after it was due; NIH found that an experiment in it had possibly produced a greater than 1 log increase and that EcoHealth had not notified NIAID. HHS suspended EcoHealth on 15 May 2024 and debarred it for five years, through 14 May 2029, finding debarment necessary to protect the Federal Government's interests. The memorandum (para 35) says the experiments led to 'substantially greater mortality rates.' It lists as grounds the failure to follow the immediate-reporting requirement, the late progress report, an inaccurate claim that the Year 4 and Year 5 experiments were the same, failure to take active steps to obtain records from the Wuhan Institute of Virology, and the claim that a computer lockout caused the delay; NIH's forensic review contradicted the lockout claim (para 44). EcoHealth ended Peter Daszak's employment effective 6 January 2025.

Source
U.S. Department of Health and Human Services, Suspension and Debarment Official
Date
17 January 2025
Grade
Primary record
Document
https://oversight.house.gov/wp-content/uploads/2025/01/ARM_EHA_1.17.2025_Redacted.pdf
Accessed
2026-11-09
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HHS document as released, redacted, by the House Committee on Oversight. The memorandum carries no date of its own; 17 January 2025 comes from the file name and the Committee's release. Parallel notice for Peter Daszak: https://oversight.house.gov/wp-content/uploads/2025/01/Dr.-Peter-Daszak-HHS-Notice_Jan-17-2025_Redacted.pdf; notice to EcoHealth: https://oversight.house.gov/wp-content/uploads/2025/01/Notice-_EHA_1.17.2025_Redacted.pdf

Exhibit 117 · Agency correspondence, known secondhand

NIH letter to Congress on the EcoHealth Alliance grant (Tabak letter)

FactCheck.org quotes an NIH letter to Congress of 20 October 2021, stating that in a 'limited experiment' under the EcoHealth grant, laboratory mice infected with the chimeric SHC014/WIV1 bat coronavirus became sicker than mice infected with WIV1, and that EcoHealth failed to report the finding right away as the grant required. FactCheck.org reports that NIH maintained that the work did not meet its P3CO definition of enhanced potential pandemic pathogen research.

Source
Lawrence Tabak, Principal Deputy Director, National Institutes of Health; reported by FactCheck.org
Date
20 October 2021
Grade
Reported
Document
https://www.factcheck.org/2021/10/scicheck-republicans-spin-nih-letter-about-coronavirus-gain-of-function-research/
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2026-11-09
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The October 20, 2021 NIH letter to EcoHealth is listed in the HHS debarment record (hhs-2025-ecohealth-debarment).

Exhibit 118 · Surveillance report

Use of mRNA COVID-19 Vaccine After Reports of Myocarditis Among Vaccine Recipients: Update from the Advisory Committee on Immunization Practices — United States, June 2021

Myocarditis reporting rates were 40.6 cases per million second doses of mRNA COVID-19 vaccines administered to males aged 12−29 years and 2.4 per million second doses administered to males aged ≥30 years

VAERS reports showed myocarditis within seven days of the second mRNA dose at about 40.6 cases per million doses in males aged 12–29, against 2.4 per million in males 30 and older.

Source
Centers for Disease Control and Prevention, MMWR 70(27):977–982
Date
9 July 2021
Quoted from
MMWR 2021;70(27):977-982 (published 9 July 2021), Results, VAERS paragraph
Grade
Primary record
Document
https://www.cdc.gov/mmwr/volumes/70/wr/mm7027e2.htm
Accessed
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Exhibit 119 · Regulatory action

FDA Approves Required Updated Warning in Labeling of mRNA COVID-19 Vaccines Regarding Myocarditis and Pericarditis

the estimated unadjusted incidence of myocarditis and/or pericarditis during the period 1 through 7 days following administration of the 2023-2024 Formula of mRNA COVID-19 vaccines was approximately 8 cases per million doses in individuals 6 months through 64 years of age and approximately 27 cases per million doses in males 12 through 24 years of age.

FDA required Pfizer and Moderna to update the myocarditis and pericarditis warning in the Comirnaty and Spikevax labels. The warning now states that risk has been highest in males 12 through 24 and gives estimated incidences of about 8 cases per million doses in people aged 6 months to 64 years and about 27 per million in males 12 through 24. FDA cited a study it funded, published in September 2024, in which abnormal cardiac MRI findings commonly persisted at about five months. FDA states that myocarditis information has been in the labeling since 2021.

Source
U.S. Food and Drug Administration
Date
25 June 2025
Quoted from
FDA Safety Communication, 25 June 2025, 'Updated Warning for Myocarditis and Pericarditis', labeling text paragraph
Grade
Primary record
Document
https://www.fda.gov/vaccines-blood-biologics/safety-availability-biologics/fda-approves-required-updated-warning-labeling-mrna-covid-19-vaccines-regarding-myocarditis-and
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Exhibit 120 · Journal article by agency officials

US FDA Safety Labeling Change for mRNA COVID-19 Vaccines

The FDA's vaccine chief and commissioner described the evidence for the June 2025 labeling change. An FDA-sponsored retrospective study included 333 patients hospitalized with myocarditis after COVID-19 vaccination. Of cases evaluated by cardiac MRI, 82% (177/216) showed late gadolinium enhancement, a marker of myocardial injury; of those with initial enhancement, 60% (98/161) still showed it at a median of 159 days. The authors wrote that the labeling change should not be seen as a final resolution of the concern.

Source
Vinay Prasad and Martin A. Makary, U.S. Food and Drug Administration; JAMA 334(11):945–946
Date
2025 (JAMA 2025;334(11):945-946)
Grade
Primary record
Document
https://doi.org/10.1001/jama.2025.12675
Accessed
2026-11-09
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Exhibit 121 · Journalism

FDA memo attributes child deaths to COVID vaccines

Prasad claims that agency staff determined that “no fewer than 10” of 96 child deaths reported to the Vaccine Adverse Event Reporting System, or VAERS, between 2021 and 2024 were “related” to Covid vaccination.

NBC News reports that a November 2025 memo to FDA staff from Vinay Prasad stated that at least 10 of 96 child deaths reported to VAERS from 2021 to 2024 were related to COVID-19 vaccination, and that the memo 'did not include the children's ages or medical histories, timelines or documentation for the deaths.' NBC also quotes the memo: 'This is a profound revelation ... For the first time, the U.S. FDA will acknowledge that COVID-19 vaccines have killed American children.' Outside experts criticized the memo.

Source
NBC News, reporting an internal memo by Vinay Prasad, FDA
Date
November 2025
Quoted from
NBC News report on the memo, paragraph 2 (memo 'sent Friday')
Grade
Reported
Document
https://www.nbcnews.com/health/health-news/fda-covid-vaccines-children-deaths-rcna246437
Accessed
2026-11-09
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Note
The memo is known through press reports.

Exhibit 122 · Journalism

FDA review of child deaths reported after COVID-19 vaccination

After reviewing the cases, the FDA reported that no cases were “certain” to be linked to Covid vaccination.

An FDA review of the child deaths found none "certain" to be linked to vaccination, rated 5 "possible" and 2 "probable," and stated that these categories do not establish causation.

Source
NBC News, reporting an FDA report
Date
May 2026
Quoted from
NBC News report dated 22 May 2026, paragraph 'After reviewing the cases...'
Grade
Reported
Document
https://www.nbcnews.com/health/health-news/no-child-deaths-definitively-linked-covid-shots-fda-says-rcna346514
Accessed
2026-11-09
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Exhibit 123 · Agency statement, known secondhand

Health Canada answer to Order Paper Question Q-1954 on the SV40 sequence in Pfizer's plasmid (Hansard, 29 January 2024)

Health Canada's answer states that Pfizer provided the full plasmid sequence at its initial filing, that the SV40 promoter-enhancer fragment 'is inactive, has no functional role,' and that Health Canada sent Pfizer a clarification request in July 2023. The answer does not say Pfizer 'did not specifically identify' the SV40 element. That wording appears in reports by The Epoch Times and advocacy outlets of an email from Health Canada.

Source
Health Canada, as reported by the Western Standard relaying The Epoch Times
Date
29 January 2024
Grade
Reported
Document
https://openparliament.ca/debates/2024/1/29/brad-vis-2/?page=9
Accessed
2026-11-09
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Ourcommons.ca Hansard is the official copy of the answer.

Exhibit 124 · Randomized trial report

The toxicity of azidothymidine (AZT) in the treatment of patients with AIDS and AIDS-related complex: a double-blind, placebo-controlled trial

Twenty-one percent of AZT recipients and 4 percent of placebo recipients required multiple red-cell transfusions (P less than 0.001).

The companion toxicity report to the pivotal AZT trial, published in the same issue. Multiple red-cell transfusions were needed by 21% of AZT recipients and 4% of placebo recipients; hemoglobin fell below 7.5 g/dL in 24% and 4%; neutropenia occurred in 16% and 2%.

Source
Douglas D. Richman et al., New England Journal of Medicine 317(4):192–197
Date
23 July 1987
Quoted from
Abstract (N Engl J Med 1987;317:192-7)
Grade
Peer-reviewed
Document
https://doi.org/10.1056/NEJM198707233170402
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Exhibit 125 · Agency press announcement

FDA Approves First Treatment for COVID-19

The median time to recovery from COVID-19 was 10 days for the Veklury group compared to 15 days for the placebo group, a statistically significant difference.

FDA approved remdesivir (Veklury) for hospitalized COVID-19 patients. The announcement reported that in ACTT-1 the median time to recovery was 10 days on remdesivir and 15 days on placebo. It did not report ACTT-1's mortality result.

Source
U.S. Food and Drug Administration
Date
22 October 2020
Quoted from
FDA news release, 22 Oct 2020, paragraph on ACTT-1
Grade
Primary record
Document
https://www.fda.gov/news-events/press-announcements/fda-approves-first-treatment-covid-19
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Exhibit 126 · Randomized trial report

Remdesivir for the Treatment of Covid-19 — Final Report

The Kaplan-Meier estimates of mortality were 6.7% with remdesivir and 11.9% with placebo by day 15 and 11.4% with remdesivir and 15.2% with placebo by day 29 (hazard ratio, 0.73; 95% CI, 0.52 to 1.03).

NIAID's trial randomized 1,062 hospitalized patients. Median recovery was 10 days on remdesivir and 15 on placebo (rate ratio 1.29, 95% CI 1.12–1.49). Day-29 mortality was 11.4% and 15.2% (hazard ratio 0.73, 95% CI 0.52–1.03), a difference that was not statistically significant. Serious adverse events were less frequent on remdesivir (24.6% vs 31.6%).

Source
John H. Beigel et al. (ACTT-1 Study Group), New England Journal of Medicine 383(19):1813–1826
Date
5 November 2020
Quoted from
Abstract, Results (N Engl J Med 383:1813-26)
Grade
Peer-reviewed
Document
https://doi.org/10.1056/NEJMoa2007764
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2026-11-09
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Exhibit 127 · Agency financial report

Financial Report to Congress, Prescription Drug User Fee Amendments, FY 2024

PDUFA user fees are not a fee for service. User fees are pooled and may be used for the allowable activities as defined in the FD&C Act.

FDA's statutory annual financial report on the PDUFA program. Table 11 (p. 16) gives user-fee obligations of $1,377,172,919 against total PDUFA program obligations of $1,772,198,497 in FY 2024, printed as 77 percent; the user-fee share was 73 percent in FY 2020, 74 in FY 2021, 76 in FY 2022 and 75 in FY 2023. Non-user-fee appropriations obligated for the program were $395,025,578, above the statutory spending trigger of $278,545,507 (p. 16). Fees are assessed on applications and annually on approved products, and are pooled (p. 5).

Source
U.S. Food and Drug Administration
Date
Fiscal year 2024 (1 October 2023 to 30 September 2024)
Quoted from
Report Overview, section C, p. 5
Grade
Primary record
Document
https://www.fda.gov/media/185331/download
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Findings citing this exhibit
Note
Dividing the Table 11 dollar figures gives 77.7 percent; the report prints 77 percent. The denominator is the PDUFA human drug review program, not FDA's total budget.

Exhibit 128 · Inspector general evaluation

How FDA Used Its Accelerated Approval Pathway Raised Concerns in 3 of 24 Drugs Reviewed (OEI-01-21-00400)

Removing HPC from the market took 3 years, during which time patients had access to and were paying for the drug.

Reviewed 24 of the 278 drugs CDER approved through accelerated approval from 1992 through December 2021: 10 chosen purposively as approvals stakeholders called concerning, 14 at random. Found concerns in three (aducanumab, hydroxyprogesterone caproate and eteplirsen): analyses outside the sponsor's original plan, approval over objections from FDA reviewers or advisory committees, and incompletely documented sponsor meetings. Two of the three left the market and the third's confirmatory trial, due in 2021, is delayed. States that it is not a compliance review and did not assess the appropriateness of FDA's decisions. Summarizes the 2022 companion report (OEI-01-21-00401): more than one-third of accelerated approval applications with incomplete confirmatory trials were past their planned completion dates, and Medicare and Medicaid spent more than $18 billion from 2018 to 2021 on such drugs. FDA concurred with the documentation recommendation and did not concur with the recommendation to define when its accelerated approval council must advise.

Source
U.S. Department of Health and Human Services, Office of Inspector General
Date
January 2025
Quoted from
Findings, printed p. 16 (PDF p. 18)
Grade
Primary record
Document
https://www.oig.hhs.gov/documents/evaluation/10160/OEI-01-21-00400.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
OIG's recommendation tracker (https://www.oig.hhs.gov/reports/all/2025/how-fda-used-its-accelerated-approval-pathway-raised-concerns-in-3-of-24-drugs-reviewed/) recorded closure on 18 May 2026: the documentation recommendation implemented, the council recommendation not.

Exhibit 129 · Peer-reviewed study

Clinical Benefit and Regulatory Outcomes of Cancer Drugs Receiving Accelerated Approval

Among 46 indications with more than 5 years of follow-up (approved 2013-2017), approximately two-thirds (29, 63%) were converted to regular approval, 10 (22%) were withdrawn, and 7 (15%) remained ongoing after a median of 6.3 years.

Followed 46 cancer drug–indication pairs granted accelerated approval in 2013–2017 for more than five years. Twenty showed an overall survival or quality-of-life benefit in confirmatory trials. Nine were converted to regular approval without either, ten were withdrawn, and seven remained pending at the data cutoff.

Source
Ian T. T. Liu, Aaron S. Kesselheim and Edward R. Scheffer Cliff, JAMA
Date
April 2024
Quoted from
Abstract, Results (JAMA 2024;331(17):1471-1479; PubMed PMID 38583175)
Grade
Peer-reviewed
Document
https://doi.org/10.1001/jama.2024.2396
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The counts are drug–indication pairs, not distinct molecules.

Exhibit 130 · Institutional statement

PATH's Chief Scientific Officer accepts role with FDA agency, CBER

Prior to joining PATH, he was a Vice President of Vaccines and Infectious Disease at Merck Research Laboratories, while serving in key advisory positions with MVI and the Bill & Melinda Gates Foundation.

David C. Kaslow, PATH's chief scientific officer, was named director of the Office of Vaccines Research and Review in FDA's Center for Biologics Evaluation and Research, effective 11 October 2022, succeeding acting director Peter Marks. Before joining PATH in 2012 he was vice president of vaccines and infectious disease at Merck Research Laboratories.

Source
PATH
Date
8 September 2022
Quoted from
PATH press release of 8 September 2022, paragraph 3 of the biography
Grade
Primary record
Document
https://www.path.org/our-impact/media-center/paths-chief-scientific-officer-accepts-role-with-fda-agency-cber/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 131 · Institutional statement

United Soybean Board announces Courtney Knupp as incoming CEO

Knupp will remain a federal employee until early September and has recused herself from soybean matters.

Named Courtney Knupp, director of global supply chain at the National Security Council, as chief executive effective 1 October 2026. She had earlier been senior policy adviser to the Secretary and Deputy Secretary of Agriculture and held chief-of-staff roles at USDA. She would remain a federal employee until early September and had recused herself from soybean matters. USB describes itself as the farmer-led soybean checkoff, overseen by USDA's Agricultural Marketing Service under the Soybean Promotion, Research and Consumer Information Act.

Source
United Soybean Board
Date
21 July 2026
Quoted from
United Soybean Board press release of 21 July 2026, paragraph 7
Grade
Primary record
Document
https://www.soycheckoff.org/news-and-stories/united-soybean-board-announces-courtney-knupp-as-incoming-ceo
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 132 · Data compilation

Bayer federal lobbying, 2025 (USRTK lobby tracker, as cited by Marion Nestle)

Federal disclosures show Bayer reported spending $9.19 million on lobbying Congress and the executive branch in 2025, which includes fees paid to at least 13 outside lobbying firms.

USRTK's tracker puts Bayer's 2025 federal lobbying at $9.19 million, using at least 13 outside firms.

Source
U.S. Right to Know, via Food Politics
Date
Calendar year 2025
Quoted from
USRTK Bayer Lobby Tracker page, opening paragraph
Grade
Reported
Document
https://usrtk.org/pesticides/bayer-lobby-tracker/
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Advocacy compilation known through a secondary post.

Exhibit 133 · Journalism

Top ten lobbying firms by revenue, third quarter 2026

Punchbowl reported Ballard Partners at $98 million in lobbying revenue through the third quarter of 2026, first among firms in the quarter with $34.8 million. Lobbying Disclosure Act filings give $97.27 million for the nine months and $34.89 million for the quarter, with BGR at $22.57 million (Exhibit 1288).

Source
Punchbowl News
Date
October 2026
Grade
Reported
Document
https://punchbowl.news/article/washington/punchbowl-top-ten-lobbying-oct-2026/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 135 · Commission report

Make Our Children Healthy Again: Assessment

In experimental animal and wildlife studies, exposure to another herbicide (atrazine) can cause endocrine disruption and birth defects.

The commission's assessment of childhood chronic disease. Its chemical-exposure section names glyphosate and atrazine and cites studies of their possible health effects, alongside federal residue-compliance data and federal reviews that did not establish a direct link between labeled herbicide use and adverse outcomes.

Source
President's Make America Healthy Again Commission
Date
22 May 2025
Quoted from
PDF p. 44
Grade
Primary record
Document
https://www.whitehouse.gov/wp-content/uploads/2025/05/WH-The-MAHA-Report-Assessment.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Quoted from the version posted on 9 November 2026. The White House replaced citations after the original release; see undark-2025-maha-citations.

Exhibit 136 · Commission report

Make Our Children Healthy Again: Strategy Report

EPA, partnering with food and agricultural stakeholders, will work to ensure that the public has awareness and confidence in EPA’s pesticide robust review procedures and how that relates to the limiting of risk for users and the general public and informs continual improvement.

The strategy required by Executive Order 14212, based on the May 2025 assessment. The text contains neither the word glyphosate nor the word atrazine. Its pesticides item commits EPA, with food and agricultural stakeholders, to public awareness of and confidence in EPA's pesticide reviews.

Source
President's Make America Healthy Again Commission
Date
9 September 2025
Quoted from
Pesticides, PDF p. 16
Grade
Primary record
Document
https://www.whitehouse.gov/wp-content/uploads/2025/09/The-MAHA-Strategy-WH.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 137 · Journalism

Report on reaction to the September 2025 MAHA strategy

Reports that the September 2025 strategy omits glyphosate and that 'Several sections of the new report adopted policy language sought by CropLife America.' It quotes the strategy's statement on EPA's confidence in its pesticide reviews. Critics it names include Moms Across America, the Center for Food Safety and U.S. PIRG.

Source
The New Lede
Date
September 2025
Grade
Reported
Document
https://www.thenewlede.org/2025/09/maha-report-draws-fire/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 139 · Journalism

Report on nonexistent studies cited in the May 2025 MAHA assessment

Reports NOTUS's finding that seven sources cited in the May 2025 MAHA assessment, among more than 500 studies and other sources, did not exist, and that dozens more citations had more mundane errors. An update states that a new version replaced the fabricated citations, five with different references and two with real studies by the same authors.

Source
Undark
Date
29 May 2025
Grade
Reported
Document
https://undark.org/2025/05/29/maha-report-studies/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 140 · Journalism

Report on food-company lobbying over the federal ultra-processed food definition

Reports, on anonymous sourcing, that food-company executives lobbied the Trump administration to delay or block release of a proposed definition of ultra-processed food, that the white paper had not been cleared by the White House budget office, that an HHS spokesperson called the policy under interagency review and not finalized, and that an administration official said the effort remains on track. Does not report that a release was cancelled.

Source
The Philadelphia Inquirer
Date
10 August 2026
Grade
Reported
Document
https://www.inquirer.com/business/ultra-processed-food-definition-ceos-delay-industry-costs-litigation-business-white-house-20260810.html
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 141 · Journalism

Report on the stalled federal ultra-processed food definition

More than 80 nutrition researchers and experts are calling on the White House to release the federal government’s proposed definition of ultra-processed foods, after its unveiling in August was canceled at the last minute under pressure from major food companies.

Reports that the planned release of the definition was canceled at the last minute, that the definition remained unreleased in October 2026, that more than 80 nutrition researchers urged its release, and that Tufts nutrition scientist Dariush Mozaffarian attributed the delay to industry pressure, which industry disputes.

Source
STAT
Date
22 October 2026
Quoted from
STAT, Sarah Todd, 22 Oct. 2026, first paragraph (STAT+ paywall; only the opening is readable)
Grade
Reported
Document
https://www.statnews.com/2026/10/22/ultra-processed-food-definition-maha-white-house/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 142 · Agency guidance

Enforcement Priorities for Certain New Tobacco Products Marketed Without Premarket Authorization: Guidance for Industry

FDA lacks the resources to pursue enforcement against every product that has not received authorization.

States that all new tobacco products marketed without authorization are illegally marketed, then sets out that FDA generally does not intend to prioritize enforcement against unauthorized e-cigarettes and nicotine pouches whose applications have been accepted and filed, or whose supplemental applications have been pending for more than 180 days. Non-tobacco-flavored e-cigarettes qualify if FDA has determined the application contains the data needed for public-health review. Products with youth-appealing features or greater safety concerns remain enforcement priorities. FDA will publish a list of the products it does not intend to prioritize.

Source
U.S. Food and Drug Administration, Center for Tobacco Products
Date
May 2026
Quoted from
Section II, p. 4
Grade
Primary record
Document
https://www.fda.gov/media/192403/download
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 143 · Institutional statement

Public health groups, pediatricians and parents sue FDA over policy allowing the marketing of unauthorized e-cigarettes and nicotine pouches

A coalition of public health organizations, pediatricians and parents today filed a federal lawsuit challenging the Food and Drug Administration’s new enforcement policy that allows e-cigarette and nicotine pouch products to be marketed and sold without the scientific review and marketing authorization required by federal law.

Announces a suit filed in federal court in Maryland by the American Heart Association, the American Academy of Pediatrics, the American Lung Association, Truth Initiative and others, challenging FDA's May 2026 enforcement guidance under the Tobacco Control Act and the Administrative Procedure Act.

Source
American Heart Association
Date
14 July 2026
Quoted from
AHA press release dated 14 July 2026, first paragraph; filed in U.S. District Court for the District of Maryland (paragraph 7)
Grade
Primary record
Document
https://newsroom.heart.org/news/public-health-groups-pediatricians-and-parents-sue-fda-over-policy-allowing-the-marketing-of-unauthorized-e-cigarettes-and-nicotine-pouches
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 144 · Agency notice

Schedules of Controlled Substances: Temporary Placement of 7-Hydroxymitragynine Above a Specified Threshold in Schedule I (Docket No. DEA-1570)

contains more than 0.050 percentage of 7-hydroxymitragynine on a dry weight basis

Notice of intent to place 7-hydroxymitragynine (7-OH) above a specified threshold temporarily in Schedule I. The threshold, adapted from an HHS definition sent to DEA on 28 July 2025, is more than 0.050 percent 7-OH by dry weight in botanical kratom, with parallel 0.050 percent limits for synthetic and processed products.

Source
Drug Enforcement Administration
Date
6 July 2026 (Federal Register)
Quoted from
Public inspection copy, p. 2, threshold (A)
Grade
Primary record
Document
https://public-inspection.federalregister.gov/2026-13580.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 145 · Agency news release

Schedules of controlled substances: temporary placement of 7-hydroxymitragynine and mitragynine (proposed amendment; notice of intent, Federal Register, 14 October 2026)

HHS recommended scheduling thresholds of more than 1 mg of 7-OH per gram in solids or 1 mg per mL in liquids, with a ratio test. On 14 October 2026 DEA published a proposed amendment, a notice of intent, that withdraws its July 2026 notice of intent and uses those thresholds. On a solids basis 1 mg/g is 0.1 percent, twice the 0.050 percent w/w in the July notice.

Source
U.S. Department of Health and Human Services
Date
October 2026
Grade
Primary record
Document
https://www.federalregister.gov/documents/2026/10/14/2026-20943/schedules-of-controlled-substances-temporary-placement-of-7--hydroxymitragynine-and-mitragynine
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
HHS release of 9 October 2026 (hhs.gov) is a second source; the Federal Register gives the HHS letter as 8 October.

Exhibit 146 · Company press release

American Kratom Association statement disputing New York Times reporting on DEA scheduling

clarify that the October action remains a Notice of Intent rather than an effective final order

The kratom trade association disputes a 28 October 2026 New York Times account that DEA backed down on 7-OH scheduling after kratom-industry lobbying.

Source
American Kratom Association, via Fortune press releases
Date
30 October 2026
Quoted from
Paragraph beginning "AKA Demands Prominent Correction", AKA press release 30 Oct 2026 (EZ Newswire, Fortune "Paid Content")
Grade
Reported
Document
https://fortune.com/press-releases/aka-demands-correction-retraction-nyt-dea-opioid-scheduling-2026-10-30/
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Add the New York Times article of 28 October 2026 as the primary record of the reported account.

Exhibit 147 · Journalism

Report on Calley Means’s resignation from the White House

Calley Means, whom STAT calls a top Make America Healthy Again adviser and a driving force behind many MAHA policy efforts, resigned on 22 October 2026. His statement gave no reason; STAT attributes to POLITICO's reporting the account that the stalled ultra-processed food definition was behind his departure.

Source
STAT
Date
22 October 2026
Grade
Reported
Document
https://www.statnews.com/2026/10/22/calley-means-resigns-white-house-adviser-maha-movement/
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Other reporting (New York Times, Reuters) says his term as a special government employee had expired.

Exhibit 148 · Journalism

Report on responses to Calley Means’s allegations against White House staff

A spokesperson for chief of staff Susie Wiles called Means's accusations outrageous, defamatory and provably false. Attorney General Todd Blanche called him a disgruntled former administration official. James Blair disputed the account. Incoming House Oversight chair Robert Garcia said he would examine the claims.

Source
Axios
Date
8 November 2026
Grade
Reported
Document
https://www.axios.com/2026/11/08/todd-blanche-calley-means-susie-wiles-maha-allegations
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 149 · Congressional statement

Sen. Schiff, Rep. Auchincloss demand answers on top Trump administration health advisers' conflicts of interest

Senator Schiff and Representative Auchincloss wrote that Calley Means had financial interests in TrueMed, an HSA/FSA reimbursement company, while advising HHS, and asked HHS for any written waiver under 18 U.S.C. 208(b) or recusal memorandum (questions c and d under Ethics Requirements).

Source
Office of Senator Adam Schiff
Date
2025
Grade
Primary record
Document
https://www.schiff.senate.gov/news/press-releases/news-sen-schiff-rep-auchincloss-demand-answers-on-top-trump-administration-health-advisors-conflicts-of-interest/
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
See also the Auchincloss letter of 16 June 2025 (https://auchincloss.house.gov/imo/media/doc/auchincloss_letter_to_calley_means.pdf). An OGE filing or waiver would settle the question.

Exhibit 150 · Registry analysis

Trends in cancer incidence and mortality rates in early-onset and older-onset age groups in the United States, 2010–2019

Out of 33 cancer types occurring among 15-49-year-olds considered in this analysis, fourteen cancer types had significantly increasing incidence rates in the most recent time period in at least one early onset age group, and 18 cancer types had significantly decreasing incidence rates

NCI researchers estimated US cancer incidence for 2010–2019 and mortality for 2010–2022 across 33 cancer types. Incidence rose for 14 types in at least one early-onset age group (15–29, 30–39 or 40–49) and fell for 18. The largest absolute increases in 2019 over the numbers expected from 2010 rates were in female breast (4,834 additional cancers), colorectal (2,099), kidney (1,793) and uterine cancer (1,209). Mortality did not rise for most cancers; colorectal, uterine and testicular cancer mortality rose in early-onset groups. The authors wrote that the drivers could include established and new causes and increased detection. The databases held no risk-factor data.

Source
Meredith S. Shiels et al., National Cancer Institute; Cancer Discovery
Date
8 May 2025 (online)
Quoted from
Results, "Overall trends in early onset cancer incidence rates" (author manuscript text via NCBI PMC, PMC12226221)
Grade
Peer-reviewed
Document
https://doi.org/10.1158/2159-8290.CD-24-1678
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The count of 33 types and the absence of risk-factor data come from the NIH release and its coverage.

Exhibit 151 · Registry analysis

Colorectal cancer incidence trends in younger versus older adults: an analysis of population-based cancer registry data

Early-onset colorectal cancer incidence rates are rising in 27 of 50 countries and territories examined

Using IARC's Cancer Incidence in Five Continents Plus data through 2017 for 50 countries and territories, the study found that over the most recent ten years incidence of colorectal cancer at ages 25–49 rose in 27 and was stable in 23. The largest annual increases were in New Zealand (3.97%), Chile (3.96%), Puerto Rico (3.81%) and England (3.59%). In 14 of the 27, incidence at ages 50–74 was stable or falling. Twenty-three of the 50 registries cover only part of their country.

Source
Hyuna Sung, Rebecca L. Siegel, Freddie Bray, Ahmedin Jemal et al., American Cancer Society and IARC; The Lancet Oncology 26(1):51–63
Date
12 December 2024 (online); January 2025 (print)
Quoted from
Abstract, Interpretation (Lancet Oncol 2025;26(1):51-63; open-access copy PMC11695264)
Grade
Peer-reviewed
Document
https://doi.org/10.1016/S1470-2045(24)00600-4
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The subnational-coverage figure comes from coverage of the paper.

Exhibit 152 · Genomic study

Geographic and age variations in mutational processes in colorectal cancer

SBS88 and ID18 were also enriched in early-onset colorectal cancers, being 3.3 times more common in individuals who were diagnosed before 40 years of age than in those over 70 years of age, and were imprinted early during colorectal cancer development.

Whole-genome sequencing of 981 colorectal cancers from 11 countries found mutational signatures SBS88 and ID18, caused by colibactin, a mutagen made by certain bacteria, 3.3 times more often in patients diagnosed before age 40 than in those over 70. The signatures were imprinted early in tumor development; press accounts of the authors' timing analysis place exposure in the first decade of life. The authors wrote that early-life exposure to colibactin-producing bacteria may contribute to the rise in early-onset colorectal cancer, and that the reasons for the rise are unknown. Senior author Ludmil Alexandrov described the finding to the press as an association.

Source
Marcos Díaz-Gay, Ludmil B. Alexandrov et al.; Nature 643:230–240
Date
23 April 2025 (online)
Quoted from
Abstract (Nature 643:230-240)
Grade
Peer-reviewed
Document
https://doi.org/10.1038/s41586-025-09025-8
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The first-decade timing and Alexandrov's remarks come from ScienceDaily and The Scientist.

Exhibit 153 · Registry analysis

Trends in childhood cancer: incidence and survival analysis over 45 years of SEER data

The incidence of childhood cancer increased from 14.23 cases per 100,000 children in 1975-1979 to 18.89 in 2010-2019, with an average annual percent change of 0.73.

Using NCI's SEER registry data for 1975–2019, the study found US childhood cancer incidence rising from 14.23 per 100,000 in 1975–1979 to 18.89 in 2010–2019, an average annual increase of 0.73 percent. Age-adjusted childhood cancer mortality fell from 4.9 to 2.3 per 100,000. Five-year survival rose from 63.1 to 85.2 percent.

Source
Iyad Sultan, Ahmad S. Alfaar, Yaseen Sultan, Zeena Salman, Ibrahim Qaddoumi; PLoS ONE
Date
3 January 2025
Quoted from
Abstract, Results (PLoS ONE 20(1):e0314592)
Grade
Peer-reviewed
Document
https://doi.org/10.1371/journal.pone.0314592
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
A 2024 Frontiers in Pediatrics analysis of SEER 1975–2018 reports a consistent annual increase of 0.8 percent (https://doi.org/10.3389/fped.2024.1357093).

Exhibit 154 · Classification summary

Carcinogenicity of tetrachlorvinphos, parathion, malathion, diazinon, and glyphosate

For the herbicide glyphosate, there was limited evidence of carcinogenicity in humans for non-Hodgkin lymphoma.

A working group of 17 experts from 11 countries, meeting at IARC on 3–10 March 2015, classified glyphosate as probably carcinogenic to humans (Group 2A), on limited evidence in humans for non-Hodgkin lymphoma and sufficient evidence in experimental animals. The full evaluation appeared as IARC Monographs Volume 112.

Source
International Agency for Research on Cancer Monograph Working Group (Kathryn Z. Guyton et al.); The Lancet Oncology 16(5):490–491
Date
20 March 2015 (online)
Quoted from
IARC Monographs Volume 112 Q&A/press release, 20 March 2015, "What were the results of the IARC evaluations?"
Grade
Primary record
Document
https://www.iarc.who.int/wp-content/uploads/2018/07/MonographVolume112-1.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The summary has no abstract and was not opened; citation and content come from the IARC Volume 112 reference list, Europe PMC metadata and consistent secondary accounts.

Exhibit 155 · Meta-analysis

Exposure to glyphosate-based herbicides and risk for non-Hodgkin lymphoma: a meta-analysis and supporting evidence

Using the highest exposure groups when available in each study, we report the overall meta-relative risk (meta-RR) of NHL in GBH-exposed individuals was increased by 41%

Pooling the 2018 Agricultural Health Study update with five case-control studies and using the highest exposure group in each, the authors found a meta-relative risk of non-Hodgkin lymphoma of 1.41 (95% CI 1.13–1.75). Using the 2005 Agricultural Health Study report instead gave 1.45 (1.11–1.91). Sheppard served on EPA's 2016 FIFRA Scientific Advisory Panel on glyphosate.

Source
Luoping Zhang, Iemaan Rana, Rachel M. Shaffer, Emanuela Taioli, Lianne Sheppard; Mutation Research/Reviews in Mutation Research 781:186–206
Date
10 February 2019 (online)
Quoted from
Abstract (Mutat Res Rev Mutat Res 781:186-206)
Grade
Peer-reviewed
Document
https://doi.org/10.1016/j.mrrev.2019.02.001
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 156 · Cohort study

Glyphosate use and cancer incidence in the Agricultural Health Study

no association was apparent between glyphosate and any solid tumors or lymphoid malignancies overall, including NHL and its subtypes. There was some evidence of increased risk of AML among the highest exposed group that requires confirmation.

A prospective cohort of 54,251 licensed pesticide applicators, 82.8 percent of whom used glyphosate, with cancer incidence followed through 2012–2013. Glyphosate was not significantly associated with cancer at any site in unlagged analyses. In the highest exposure quartile the risk of acute myeloid leukemia was 2.44 times that of never users (95% CI 0.94–6.32); with a 20-year lag the highest tertile reached 2.04 (1.05–3.97). Critics note the study's imputation of missing exposure data and a reference group that included low-exposure users.

Source
Gabriella Andreotti, Laura E. Beane Freeman et al.; Journal of the National Cancer Institute 110(5):509–516
Date
9 November 2017 (online); May 2018 (print)
Quoted from
Abstract, Conclusions
Grade
Peer-reviewed
Document
https://doi.org/10.1093/jnci/djx233
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 157 · Animal carcinogenicity study

Carcinogenic effects of long-term exposure from prenatal life to glyphosate and glyphosate-based herbicides in Sprague–Dawley rats

Most of these involved tumors that are rare in SD rats (background incidence < 1%) with 40% of leukemias deaths in the treated groups occurring before 52 weeks of age

Male and female Sprague–Dawley rats were given glyphosate, Roundup BioFlow or RangerPro in drinking water from gestational day 6 to 104 weeks of age, at 0.5 mg/kg/day (the EU acceptable daily intake), 5 mg/kg/day and 50 mg/kg/day (the EU no-observed-adverse-effect level). In all three dose groups the authors observed statistically significant dose-related trends or increased incidences of benign and malignant tumors at multiple sites, including leukemia, liver, thyroid, nervous system, mammary gland and kidney, in both sexes. Most were tumors rare in this strain (background incidence under 1 percent), and 40 percent of leukemia deaths in treated groups (6 of 15 leukemia-bearing animals) occurred before 52 weeks of age.

Source
Simona Panzacchi et al., Ramazzini Institute (Global Glyphosate Study); Environmental Health 24:36
Date
10 June 2025
Quoted from
Abstract, Results (Environ Health 24:36)
Grade
Peer-reviewed
Document
https://doi.org/10.1186/s12940-025-01187-2
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The study has not been independently replicated.

Exhibit 158 · National biomonitoring study

Exposure to glyphosate in the United States: data from the 2013–2014 National Health and Nutrition Examination Survey

These first nationally representative data suggest that over four-fifths of the U.S. general population ≥ 6 years experienced recent exposure to glyphosate.

CDC scientists measured glyphosate in 2,310 stored urine samples from a representative one-third subsample of NHANES 2013–2014 participants aged six and older. The weighted detection frequency was 81.2 percent, with a limit of detection of 0.20 µg/L and a maximum of 8.13 µg/L. The authors concluded that these first nationally representative data suggest over four-fifths of the US population aged six and older had recent exposure to glyphosate.

Source
Maria Ospina, Antonia M. Calafat et al., Centers for Disease Control and Prevention; Environment International 170:107620
Date
November 2022
Quoted from
Abstract, Conclusions (Environ Int 170:107620; open-access copy PMC10240384)
Grade
Peer-reviewed
Document
https://doi.org/10.1016/j.envint.2022.107620
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 159 · Dataset codebook

NHANES 2013–2014 codebook: urinary glyphosate (SSGLYP_H)

CDC's codebook for the NHANES 2013–2014 glyphosate urine data file (SSGLYP_H) lists 2,310 results: 1,885 at or above the detection limit and 425 below it. The detected share is 81.6 percent of samples (1,885 of 2,310; a division the codebook does not print). The sample includes children and adults.

Source
CDC National Center for Health Statistics
Date
9 July 2022
Grade
Primary record
Document
https://wwwn.cdc.gov/Nchs/Data/Nhanes/Public/2013/DataFiles/SSGLYP_H.htm
Accessed
2026-11-09
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Exhibit 160 · Journalism

Report on the 2026 Cancer in Iowa report

Reports that the Iowa Cancer Registry's 2026 Cancer in Iowa report puts Iowa second among US states in cancer incidence, behind Kentucky, and describes its rate as the fastest rising in the country. The registry's 2026 Cancer in Iowa report would replace this exhibit.

Source
The Gazette (Cedar Rapids), reporting the Iowa Cancer Registry
Date
2026
Grade
Reported
Document
https://www.thegazette.com/?p=394603
Accessed
2026-11-09
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Exhibit 161 · Journalism

The 10 states with the highest cancer rates

According to MDLinx, citing NCI and CDC State Cancer Profiles data for 2018–2022, age-adjusted cancer incidence was 519.0 per 100,000 in Kentucky and 498.8 in Iowa, the two highest state rates, against 448.6 nationally. The NCI/CDC State Cancer Profiles incidence table (https://statecancerprofiles.cancer.gov/) would replace this exhibit.

Source
MDLinx, citing NCI and CDC State Cancer Profiles, 2018–2022
Date
Undated; data 2018–2022
Grade
Reported
Document
https://www.mdlinx.com/article/the-10-states-with-the-highest-cancer-rates/64Czw45dlCipMH6jJ9XXNd
Accessed
2026-11-09
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Exhibit 162 · Journalism

As cancer rates continue to climb in Iowa, study finds fewer cases among farmers

Iowa farmers had 13% fewer cancers than the general Iowa population between 1994 and 2015.

Reports a study finding that Iowa farmers had 13 percent fewer cancers than the general Iowa population between 1994 and 2015, and farmers' spouses 10 percent fewer. It credits lower smoking and drinking among farmers and the healthy-worker effect for the farmer gap. A quoted researcher says: "it isn't one thing here that's causing all the cancer. It's multiple things." The study itself would replace this exhibit.

Source
Daily Bulletin and Review (dbrnews.com)
Date
Undated e-edition page
Quoted from
Gazette article by Vanessa Miller, 14 Mar 2026, first paragraph
Grade
Reported
Document
https://dbrnews.com/eedition/page_ff14fda7-086f-5034-ab92-5008e71c9799.html
Accessed
2026-11-09
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Exhibit 163 · Case-control laboratory study

Association between simian virus 40 and non-Hodgkin lymphoma

Polyomavirus T antigen sequences, all of which were SV40-specific, were detected in 64 (42%) of 154 non-Hodgkin lymphomas, none of 186 non-malignant lymphoid samples, and none of 54 control cancers.

SV40-specific T-antigen DNA sequences were detected in 64 of 154 non-Hodgkin lymphomas (42 percent), in none of 186 non-malignant lymphoid samples and in none of 54 colon and breast cancers used as controls. The pattern was similar in HIV-infected and uninfected patients. A separate study by Shivapurkar and colleagues in the same issue reported 43 percent.

Source
Regis A. Vilchez, Janet S. Butel et al.; The Lancet 359:817–823
Date
9 March 2002
Quoted from
Abstract, Findings (Lancet 359:817-823)
Grade
Peer-reviewed
Document
https://doi.org/10.1016/S0140-6736(02)07950-3
Accessed
2026-11-09
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Exhibit 164 · Laboratory study

Evidence against a role for SV40 infection in human mesotheliomas and high risk of false-positive PCR results owing to presence of SV40 sequences in common laboratory plasmids

The risk of false-positive results due to contamination by common laboratory plasmids containing SV40 sequences has been underestimated.

In 71 mesotheliomas, two PCR primer sets gave positive results at rates similar to earlier positive studies (56–62 percent), but those primers lay in a region of the SV40 T-antigen gene present in common laboratory plasmids. The SV40 sequences found carried a deletion present only in plasmids. All 71 tumors were negative for T-antigen transcripts and T-antigen protein. The authors concluded that the risk of false-positive results from plasmid contamination had been underestimated.

Source
Fernando López-Ríos, Peter B. Illei, Valerie Rusch, Marc Ladanyi; The Lancet 364:1157–1166
Date
25 September 2004
Quoted from
Abstract, Interpretation
Grade
Peer-reviewed
Document
https://doi.org/10.1016/S0140-6736(04)17102-X
Accessed
2026-11-09
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Exhibit 165 · Cohort study

1-year risks of cancers associated with COVID-19 vaccination: a large population-based cohort study in South Korea

Data from 8,407,849 individuals between 2021 and 2023 were obtained from the Korean National Health Insurance database.

Using Korean National Health Insurance data on 8,407,849 Seoul residents for 2021–2023, the study reported significantly higher hazard ratios one year after COVID-19 vaccination for thyroid, gastric, colorectal, lung, breast and prostate cancer. Critics noted that the incidence gap was already present one month after vaccination (2.91 against 1.63 per 100,000), a timing that points to detection or selection bias rather than causation, and that the two groups were assigned different index dates.

Source
Hong Jin Kim, Min-Ho Kim, Myeong Geun Choi, Eun Mi Chun; Biomarker Research 13:114
Date
26 September 2025
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1186/s40364-025-00831-w
Accessed
2026-11-09
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Note
The one-month figures and critiques come from Science Feedback and a Frontiers in Public Health commentary.

Exhibit 166 · Interrupted time-series study

Impact of SARS-CoV-2 vaccination on cancer trends: a nationwide interrupted time series study

The national SARS-CoV-2 vaccination rollout in South Korea was not accompanied by a detectable short-term, population-level change in cancer incidence trends over the 50 months that followed.

An interrupted time-series analysis of Korea National Health Insurance Service data for 36,024,394 people born between 1955 and 2004, from February 2011 to September 2025, with August 2021 as the intervention point. Of the population, 89.3 percent received at least one dose. No immediate level change or trend change reached significance for any of 13 cancer categories or for stomach, colorectal, lung or prostate cancer. The design does not compare vaccinated with unvaccinated individuals. The authors call for long-term monitoring.

Source
Y. Na, M. Radnaabaatar, Jae-hun Jung, Korea University College of Medicine; Biomarker Research
Date
22 October 2026
Quoted from
Abstract, Conclusions
Grade
Peer-reviewed
Document
https://doi.org/10.1186/s40364-026-01027-6
Accessed
2026-11-09
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Exhibit 167 · Consensus report

To Err Is Human: Building a Safer Health System

When extrapolated to the over 33.6 million admissions to U.S. hospitals in 1997, the results of the study in Colorado and Utah imply that at least 44,000 Americans die each year as a result of medical errors.

Estimated that medical errors cause 44,000 to 98,000 deaths a year among patients in US hospitals, extrapolating from two earlier adverse-event studies. Later literature cites the range as the common estimate of preventable inpatient deaths.

Source
Institute of Medicine (National Academies)
Date
1999
Quoted from
Executive Summary, opening section (National Academies Press, To Err Is Human)
Grade
Primary record
Document
https://nap.nationalacademies.org/read/9728/chapter/2
Accessed
2026-11-09
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Note
Figure and method taken from Rodwin et al. (2020), which restates the range in its abstract.

Exhibit 168 · Peer-reviewed meta-analysis

Incidence of adverse drug reactions in hospitalized patients: a meta-analysis of prospective studies

We estimated that in 1994 overall 2216000 (1721000-2711000) hospitalized patients had serious ADRs and 106000 (76000-137000) had fatal ADRs, making these reactions between the fourth and sixth leading cause of death.

Pooled 39 prospective studies from US hospitals (1966–1996). Excluded errors in drug administration, noncompliance, overdose, drug abuse, therapeutic failures and possible reactions, so the count covers reactions to drugs used as prescribed. Serious reactions occurred in 6.7 percent and fatal reactions in 0.32 percent of hospitalized patients. Estimated that in 1994, 2,216,000 hospitalized patients had serious reactions and 106,000 (76,000–137,000) had fatal ones, placing drug reactions between the fourth and sixth leading cause of death.

Source
Lazarou, Pomeranz and Corey, JAMA 279(15):1200–1205
Date
15 April 1998
Quoted from
Abstract, Data Synthesis (JAMA 279(15):1200-1205)
Grade
Peer-reviewed
Document
https://doi.org/10.1001/jama.279.15.1200
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Exhibit 169 · Journal commentary

Is US health really the best in the world?

These total to 225 000 deaths per year from iatrogenic causes.

Summed published US estimates of deaths from medical care: 12,000 a year from unnecessary surgery, 7,000 from medication errors in hospitals, 20,000 from other errors in hospitals, 80,000 from nosocomial infections in hospitals and 106,000 from non-error adverse effects of medications, a total of 225,000. Noted that most data came from hospitalized patients, that the figures counted deaths only, and that using the IOM's higher error estimates gave 230,000 to 284,000. Called 225,000 the third leading cause of death in the United States, after heart disease and cancer. Cited a separate outpatient analysis estimating 199,000 additional deaths.

Source
Barbara Starfield, JAMA 284(4):483–485
Date
26 July 2000
Quoted from
JAMA 284(4):483-485, p. 483 (Commentary), following the list of five estimates
Grade
Peer-reviewed
Document
https://jamanetwork.com/journals/jama/fullarticle/192908
Accessed
2026-11-09
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Note
Components checked against the JAMA reprint hosted at https://lakeslab.ep.wisc.edu/iatrogenic.pdf (p. 484). The published breakdown includes the 80,000 hospital-infection deaths; one secondary account that says the total excludes them is contradicted by the commentary.

Exhibit 170 · Journal analysis

Medical error—the third leading cause of death in the US

Makary and Daniel's BMJ paper estimates 251,454 deaths a year from medical error in US hospitals, which Shojania and Dixon-Woods report was derived by averaging four estimates. The paper states the figure as 9.5 percent of US deaths, derived by applying the pooled rates of four studies (data from 2000–2008) to 35,416,020 US hospitalizations in 2013. It argues that error would rank third among causes of death and that death certificates, coded to the International Classification of Diseases, cannot capture it.

Source
Makary and Daniel, BMJ 353:i2139
Date
3 May 2016
Grade
Peer-reviewed
Document
https://doi.org/10.1136/bmj.i2139
Accessed
2026-11-09
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Note
Known through STAT and AJMC coverage and the Shojania and Dixon-Woods critique.

Exhibit 171 · Journal analysis

Estimating deaths due to medical error: the ongoing controversy and why it matters

Makary's and Daniel's estimate that over 250 000 of those are preventable implies that around a third (or more) of inpatient deaths result from medical error or preventable adverse events.

Around 700,000 deaths occur in US hospitals annually, so Makary and Daniel's estimate that over 250,000 of those are preventable implies that around a third (or more) of inpatient deaths result from medical error or preventable adverse events. Three of the studies behind the figure contained 14, 12 and 9 deaths, and the authors write that Makary and Daniel "did not apply any established methodology for quantitative synthesis." The authors re-estimate preventable deaths at something like 25,000 a year, at a 3.6 percent preventable rate, refer in closing to "implausible estimates," and write that the narrow focus on preventable death "risks distracting attention" from non-fatal harm.

Source
Shojania and Dixon-Woods, BMJ Quality & Safety 26(5):423–428
Date
May 2017 (online October 2016)
Quoted from
Section "Why the fuss? What harm could come from estimating so many deaths due to medical error?"; preceding sentence: "Around 700 000 deaths occur in US hospitals annually."
Grade
Peer-reviewed
Document
https://doi.org/10.1136/bmjqs-2016-006144
Accessed
2026-11-09
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Note
Known through PSNet, McGill OSS and abstract-level summaries.

Exhibit 172 · Peer-reviewed meta-analysis

Rate of preventable mortality in hospitalized patients: a systematic review and meta-analysis

our estimates equate to approximately 22,165 preventable deaths annually and up to 7150 preventable deaths among patients with greater than 3 months life expectancy.

Pooled eight studies in which physicians reviewed 12,503 consecutive or randomly selected adult hospital deaths. The pooled rate of preventable death was 3.1 percent (95% CI 2.2–4.1), corresponding to about 22,165 US deaths a year, and about 7,150 among patients expected to live more than three months. All pooled studies came from Canada and Europe. The authors note that hospital mortality rates are used for quality measures and reimbursement, and call for a direct US study of preventable hospital deaths.

Source
Rodwin et al., Journal of General Internal Medicine 35(7):2099–2106
Date
July 2020 (online 21 January 2020)
Quoted from
Discussion, first paragraph (J Gen Intern Med 35(7):2099-2106)
Grade
Peer-reviewed
Document
https://doi.org/10.1007/s11606-019-05592-5
Accessed
2026-11-09
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Exhibit 173 · Peer-reviewed cohort study

The safety of inpatient health care

In a random sample of 2809 admissions, we identified at least one adverse event in 23.6%. Among 978 adverse events, 222 (22.7%) were judged to be preventable

Random sample of 2,809 admissions to 11 Massachusetts hospitals in 2018, screened by trained nurses with a trigger method and adjudicated by physicians. At least one adverse event occurred in 23.6 percent of admissions. Of 978 events, 222 (22.7 percent) were preventable and 316 (32.3 percent) were serious or worse. Preventable events affected 6.8 percent of admissions. Drug events were 39.0 percent of events, surgical or procedural 30.4, patient-care (including falls and pressure ulcers) 15.0, and health care-associated infections 11.9. Seven deaths occurred, one judged preventable. Funded by the Controlled Risk Insurance Company and the Risk Management Foundation of the Harvard Medical Institutions.

Source
Bates et al., New England Journal of Medicine 388(2):142–153
Date
12 January 2023
Quoted from
Abstract, Results (N Engl J Med 388(2):142-153)
Grade
Peer-reviewed
Document
https://doi.org/10.1056/NEJMsa2206117
Accessed
2026-11-09
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Exhibit 174 · Book

Medical Nemesis: The Expropriation of Health

This cultural iatrogenesis, which I shall discuss in Part III, is the ultimate backlash of hygienic progress and consists in the paralysis of healthy responses to suffering, impairment, and death.

Argues that professional medicine damages health at three levels: clinical iatrogenesis (Part I), social iatrogenesis or 'the medicalization of life' (Part II) and cultural iatrogenesis (Part III). Names the self-reinforcing loop among them 'medical nemesis' and proposes a political remedy, the recovery of lay self-care and legal limits on the professional monopoly of physicians. Credits immunization against polio, whooping cough and measles, smallpox vaccination of infants, antibiotics and oral rehydration, while arguing that effective interventions are few and cheap and that medical treatment is not significantly related to the population-level fall in disease.

Source
Ivan Illich (Pantheon Books, New York)
Date
1976 (British text copyright 1975)
Quoted from
Part I, ch. 1 'The Epidemics of Modern Medicine', section 'Defenseless Patients'
Grade
Primary record
Document
https://archive.org/details/medicalnemesisex00illi
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Exhibit 175 · Book

Limits to Medicine. Medical Nemesis: The Expropriation of Health

The medical establishment has become a major threat to health.

The British edition, described by its publisher as the definitive version of Medical Nemesis. Its Introduction opens with the sentence most often quoted from the book. The Pantheon US edition of the same year does not contain that sentence and opens its first chapter on the decline of polio, diphtheria and tuberculosis.

Source
Ivan Illich (Calder & Boyars, London; reprinted by Marion Boyars)
Date
1976 (preface dated 27 February 1976)
Quoted from
Introduction, first sentence
Grade
Primary record
Document
https://archive.org/details/limitstomedicine0000illi
Accessed
2026-11-09
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Exhibit 176 · Journal article

The McKeown thesis: a historical controversy and its enduring influence

in spite of his conclusions' having been largely discredited by subsequent research

Reviews the reception of Thomas McKeown's thesis about the historical fall in mortality. The abstract states that the thesis has remained influential in spite of McKeown's conclusions having been largely discredited by subsequent research.

Source
James Colgrove, American Journal of Public Health 92(5):725–729
Date
May 2002
Quoted from
Abstract (Am J Public Health 92(5):725-729)
Grade
Peer-reviewed
Document
https://doi.org/10.2105/ajph.92.5.725
Accessed
2026-11-09
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Exhibit 177 · Research brief

The Health Insurance Experiment: a classic RAND study speaks to the current health care reform debate

participants (including both adults and children) with cost sharing made one to two fewer physician visits annually and had 20 percent fewer hospitalizations than those with free care

RAND's summary of its Health Insurance Experiment, which ran between 1971 and 1982 and randomly assigned families to plans from free care to 95 percent coinsurance. Families with 25 percent coinsurance spent about 20 percent less than families with free care, and those with 95 percent coinsurance about 30 percent less. Cost sharing reduced physician visits by one to two a year and hospitalizations by 20 percent, and had no adverse effect on health for the average participant. For people with poor vision and for low-income people with high blood pressure, free care brought an improvement.

Source
RAND Corporation (Research Brief RB-9174)
Date
2006
Quoted from
RAND Research Brief RB-9174, "Effects on Use of Health Services"; the 25 percent and 95 percent coinsurance spending figures (20 and about 30 percent less) are in the next paragraph
Grade
Primary record
Document
https://www.rand.org/pubs/research_briefs/RB9174.html
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Exhibit 178 · Peer-reviewed trial report

Health insurance and the demand for medical care: evidence from a randomized experiment

The per capita expenses on the plan with no out-of-pocket costs are 45 percent higher than those on the plan with a 95 percent coinsurance rate, subject to an upper limit on out-of-pocket expenses of $1,000 per year.

The principal analysis of spending in the RAND Health Insurance Experiment. Per-capita expenses on the free plan were about 45 percent higher than on the 95 percent coinsurance plan, which capped out-of-pocket spending at $1,000.

Source
Manning et al., American Economic Review
Date
1987
Quoted from
Abstract of RAND report R-3476 (Manning, Newhouse, Duan et al.), as reproduced on the Harvard Health Care Policy page
Grade
Peer-reviewed
Document
https://hcp.hms.harvard.edu/publication/health-insurance-and-demand-medical-care-results-randomized-experiment
Accessed
2026-11-09
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Note
Known through a Harvard listing and a mirrored PDF.

Exhibit 179 · Randomized study

The Oregon experiment—effects of Medicaid on clinical outcomes

This randomized, controlled study showed that Medicaid coverage generated no significant improvements in measured physical health outcomes in the first 2 years

Oregon's 2008 Medicaid lottery drew approximately 30,000 names from a waiting list of almost 90,000 people. Roughly two years later the authors compared 6,387 adults selected in the lottery with 5,842 not selected. Coverage had no significant effect on hypertension, high cholesterol or average glycated hemoglobin. It increased diabetes diagnosis and medication use, lowered positive depression screens by 9.15 percentage points (95% CI −16.70 to −1.60), increased preventive care and nearly eliminated catastrophic out-of-pocket spending. The authors concluded that coverage generated no significant improvements in measured physical health outcomes in the first two years.

Source
Baicker et al., New England Journal of Medicine 368(18):1713–1722
Date
2 May 2013
Quoted from
Abstract, Conclusions (N Engl J Med 368(18):1713-1722)
Grade
Peer-reviewed
Document
https://doi.org/10.1056/NEJMsa1212321
Accessed
2026-11-09
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Exhibit 180 · Peer-reviewed cohort study

The implications of regional variations in Medicare spending. Part 1: the content, quality, and accessibility of care

patients in higher-spending regions received approximately 60% more care

Medicare patients hospitalized in 1993–1995 for hip fracture, colorectal cancer or acute myocardial infarction, and a survey sample, had similar baseline health across regions. Patients in higher-spending regions received about 60 percent more care, chiefly more inpatient visits and consultations, tests, minor procedures, specialist care and hospital and intensive-care days. Quality was no better on most measures and worse for several preventive measures, and access was no better or worse.

Source
Fisher et al., Annals of Internal Medicine 138(4):273–287
Date
18 February 2003
Quoted from
Abstract, Results (Ann Intern Med 138(4):273-287)
Grade
Peer-reviewed
Document
https://doi.org/10.7326/0003-4819-138-4-200302180-00006
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2026-11-09
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Exhibit 181 · Peer-reviewed cohort study

The implications of regional variations in Medicare spending. Part 2: health outcomes and satisfaction with care

Medicare enrollees in higher-spending regions receive more care than those in lower-spending regions but do not have better health outcomes or satisfaction with care.

Same cohorts as Part 1 (hip fracture 614,503; colorectal cancer 195,429; acute myocardial infarction 159,393; survey sample 18,190). Each 10 percent increase in regional end-of-life spending was associated with a five-year relative risk of death of 1.003 (hip fracture), 1.012 (colorectal cancer, CI 1.004–1.019), 1.007 (myocardial infarction, CI 1.001–1.014) and 1.01 (survey sample). Functional decline and satisfaction did not differ consistently. Higher-spending regions did not have better outcomes or satisfaction.

Source
Fisher et al., Annals of Internal Medicine 138(4):288–298
Date
18 February 2003
Quoted from
Abstract, Conclusions (Ann Intern Med 138(4):288-298)
Grade
Peer-reviewed
Document
https://doi.org/10.7326/0003-4819-138-4-200302180-00007
Accessed
2026-11-09
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Exhibit 182 · Peer-reviewed cohort study

Changes in hospital adverse events and patient outcomes associated with private equity acquisition

After private equity acquisition, Medicare beneficiaries admitted to private equity hospitals experienced a 25.4% increase in hospital-acquired conditions compared with those treated at control hospitals

Compared 51 hospitals acquired by private equity with 259 matched controls in Medicare claims, 2009–2019, using a difference-in-differences design. Hospital-acquired conditions rose by 4.6 per 10,000 admissions after acquisition (95% CI 2.0–7.2), a 25.4 percent increase over a baseline of 18.1. The composite sums conditions, so one admission can contribute several. Falls stayed at 6.8 per 10,000 in acquired hospitals while controls improved from 8.7 to 6.9. Thirty-day mortality showed no differential change. Staffing cuts were proposed as an explanation and not tested.

Source
Kannan, Bruch and Song, JAMA 330(24):2365–2375
Date
26 December 2023
Quoted from
Abstract, Results (JAMA 330(24):2365-2375; PMC10751598)
Grade
Peer-reviewed
Document
https://doi.org/10.1001/jama.2023.23147
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2026-11-09
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Exhibit 183 · Peer-reviewed study

Owner incentives and performance in healthcare: private equity investment in nursing homes

after instrumenting for the patient-nursing home match, we find that PE ownership increases mortality by 11%

Estimated an 11 percent relative increase in mortality among nursing-home patients after private equity acquisition, adjusting for the lower measured risk of patients the acquired homes admitted. Combined differences over time with an instrument based on relative distance to private equity and other nursing homes, so the estimate applies to patients whose placement responds to that instrument. Reported declines in patient well-being, staffing and compliance with care standards.

Source
Gupta et al., The Review of Financial Studies 37(4):1029
Date
April 2024
Quoted from
Abstract, as deposited by the publisher in Crossref (Rev Financ Stud 37(4):1029-1077)
Grade
Peer-reviewed
Document
https://doi.org/10.1093/rfs/hhad082
Accessed
2026-11-09
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Note
A 2021 Becker Friedman Institute summary of the earlier working paper reported 1.7 percentage points (about 10 percent) and an extrapolation of 20,150 deaths over twelve years; those figures belong to the earlier version.

Exhibit 184 · Peer-reviewed cohort study

Association between hospital private equity acquisition and outcomes of acute medical conditions among Medicare beneficiaries

a greater decrease in 30-day mortality (difference, -1.41 percentage points; 95% CI, -2.26 to -0.56 percentage points) was found at acquired vs nonacquired hospitals

Examined more than 21 million Medicare records for five acute conditions, 2001–2018, with a generalized difference-in-differences design. Acquisition was associated with lower heart-attack mortality: −1.14 percentage points in hospital and −1.41 points within 30 days (95% CI −2.26 to −0.56). Mortality for stroke, heart failure, COPD exacerbation and pneumonia did not change significantly, and readmissions and 30-day spending did not differ. Follow-up extended three years after acquisition.

Source
Cerullo et al., JAMA Network Open 5(4):e229581
Date
1 April 2022
Quoted from
Abstract, Results (JAMA Netw Open 5(4):e229581)
Grade
Peer-reviewed
Document
https://doi.org/10.1001/jamanetworkopen.2022.9581
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2026-11-09
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Exhibit 185 · Systematic review

Evaluating trends in private equity ownership and impacts on health outcomes, costs, and quality: systematic review

No consistently beneficial impacts of PE ownership were identified.

Reviewed 55 empirical studies, 47 from the United States, of which 32 assessed impacts. Nine of twelve studies found higher costs to patients or payers, three found no difference and none found lower costs. Quality results were mixed but more often adverse. Health outcomes had too few studies for a general conclusion. Narrative synthesis; no pooled mortality effect.

Source
Borsa et al., BMJ 382:e075244
Date
19 July 2023
Quoted from
Abstract, Results (BMJ 382:e075244)
Grade
Peer-reviewed
Document
https://doi.org/10.1136/bmj-2023-075244
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2026-11-09
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Exhibit 186 · Agency fact sheet

Disclosures of ownership and additional disclosable parties information for skilled nursing facilities and nursing facilities (final rule fact sheet)

Announces a final rule requiring nursing homes to disclose additional owners and managers, including parties with financial control, property lessors and providers of administrative or cash-management services, and describes identifying private equity and real estate investment trust ownership in enrollment records. The rule was published in the Federal Register on 17 November 2023.

Source
Centers for Medicare & Medicaid Services
Date
15 November 2023
Grade
Primary record
Document
https://www.cms.gov/newsroom/fact-sheets/disclosures-ownership-additional-disclosable-parties-information-skilled-nursing-facilities-nursing
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Note
Records the disclosure requirement only; implementation and enforcement were not reviewed.

Exhibit 187 · Research article

Reasons for the decline of mortality in England and Wales during the nineteenth century

McKeown and Record's 1962 Population Studies paper on the decline of mortality in England and Wales during the nineteenth century. Illich cites it for his statement that the environment is the primary determinant of the state of general health of any population.

Source
Thomas McKeown and R. G. Record, Population Studies 16(2): 94–122
Date
November 1962
Grade
Peer-reviewed
Document
https://doi.org/10.1080/00324728.1962.10414870
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2026-11-09
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Exhibit 188 · Research article

The Importance of Social Intervention in Britain's Mortality Decline c.1850–1914: a Re-interpretation of the Role of Public Health

Szreter's 1988 article re-interprets the role of public health in Britain's mortality decline between 1850 and 1914 and argues for the importance of social intervention.

Source
Simon Szreter, Social History of Medicine 1(1): 1–38
Date
1988
Grade
Peer-reviewed
Document
https://doi.org/10.1093/shm/1.1.1
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2026-11-09
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Exhibit 189 · Commentary

Rethinking McKeown: the relationship between public health and social change

From the 1870s they had worked tirelessly throughout the country, leading forward the foot soldiers under their command: humble employees of local government such as sanitary inspectors, housing officers, lady health visitors, trained midwives, and school medical officers.

Szreter's restatement of his critique of McKeown. He credits Medical Officers of Health and the local-government staff they directed from the 1870s, including sanitary inspectors, housing officers, health visitors, trained midwives and school medical officers, and argues that McKeown understated organized social intervention.

Source
Simon Szreter, American Journal of Public Health 92(5): 722–725
Date
May 2002
Quoted from
Am J Public Health 92(5):722-725, paragraph on Medical Officers of Health
Grade
Peer-reviewed
Document
https://pmc.ncbi.nlm.nih.gov/articles/PMC1447152/
Accessed
2026-11-09
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Exhibit 190 · Agency reference text

Epidemiology and Prevention of Vaccine-Preventable Diseases (Pink Book), Chapter 13: Measles

In the years following licensure of vaccine in 1963, the incidence of measles decreased by more than 95%, and 2- to 3-year epidemic cycles no longer occurred.

CDC's Pink Book states that before 1963 about 500,000 measles cases and 500 measles deaths were reported in the United States each year, with an estimated 3 to 4 million actual infections, and that after vaccine licensure in 1963 incidence fell by more than 95 percent and the two- to three-year epidemic cycles stopped.

Source
Centers for Disease Control and Prevention
Date
Current edition
Quoted from
Pink Book, Measles chapter, Epidemiology section
Grade
Primary record
Document
https://www.cdc.gov/pinkbook/hcp/table-of-contents/chapter-13-measles.html
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Exhibit 191 · Research article

HPV Vaccination and the Risk of Invasive Cervical Cancer

After adjustment for all covariates, the incidence rate ratio was 0.12 (95% CI, 0.00 to 0.34) among women who had been vaccinated before the age of 17 years and 0.47 (95% CI, 0.27 to 0.75) among women who had been vaccinated at the age of 17 to 30 years.

Swedish registry cohort of 1,672,983 girls and women aged 10 to 30, followed from 2006 to 2017. Cumulative incidence of invasive cervical cancer was 47 per 100,000 among the vaccinated and 94 per 100,000 among the unvaccinated. The adjusted incidence rate ratio was 0.12 for vaccination before age 17 and 0.47 for vaccination at ages 17 to 30. The vaccine was quadrivalent.

Source
Lei et al., New England Journal of Medicine 383: 1340–1348
Date
1 October 2020
Quoted from
Abstract, Results
Grade
Peer-reviewed
Document
https://www.nejm.org/doi/full/10.1056/NEJMoa1917338
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Note
Observational design.

Exhibit 192 · Research article

Invasive cervical cancer incidence following bivalent human papillomavirus vaccination: a population-based observational study of age at immunization, dose, and deprivation

No cases of invasive cancer were recorded in women immunized at 12 or 13 years of age irrespective of the number of doses.

Population-based study of Scottish women born 1988 to 1996. No cases of invasive cervical cancer occurred among women immunized at ages 12 to 13, regardless of the number of doses. Women vaccinated at 14 to 22 with three doses had 3.2 cases per 100,000 against 8.4 per 100,000 in unvaccinated women. The vaccine was bivalent.

Source
Palmer et al., Journal of the National Cancer Institute 116: 857–865
Date
22 January 2024
Quoted from
Abstract, Results
Grade
Peer-reviewed
Document
https://doi.org/10.1093/jnci/djad263
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Exhibit 193 · Health E-Stat report

Prevalence of Overweight, Obesity, and Severe Obesity Among Children and Adolescents Aged 2–19 Years: United States, 1963–1965 Through 2021–2023

In August 2021–August 2023, an estimated 21.1% of U.S. children and adolescents ages 2–19 years had obesity, including 7.0% with severe obesity and another 15.1% who were overweight.

NCHS Health E-Stat on the August 2021–August 2023 NHANES cycle: an estimated 21.1 percent of US children and adolescents aged 2 to 19 had obesity, including 7.0 percent with severe obesity, and another 15.1 percent were overweight. Table 1 gives 5.2 percent obesity and about 1 percent severe obesity in 1971–1974.

Source
CDC National Center for Health Statistics
Date
NHANES cycle August 2021–August 2023
Quoted from
NCHS Health E-Stat (Prevalence of Overweight, Obesity, and Severe Obesity Among Children and Adolescents Aged 2-19 Years, 1963-1965 through Aug 2021-Aug 2023), p. 1 text under the title
Grade
Primary record
Document
https://www.cdc.gov/nchs/data/hestat/hestat112.pdf
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Exhibit 194 · Research article

Trends in incidence of youth-onset type 1 and type 2 diabetes in the USA, 2002–18: results from the population-based SEARCH for Diabetes in Youth study

a significant upward trend in the age-, sex- and race/ethnicity-adjusted incidence was observed from 19·5 cases per 100,000 youths per year in 2002–2003 to 22·2 cases per 100,000 youths per year in 2017–2018, with an annual rate of increase of 2·02%, (95% CI 1·54, 2·49%)

Youth type 1 diabetes incidence rose 2.02 percent a year (95% CI 1.54–2.49), from 19.5 to 22.2 per 100,000 between 2002–03 and 2017–18. Type 2 incidence rose 5.31 percent a year, from 9.0 to 17.9 per 100,000. The steepest type 1 rise was among Asian and Pacific Islander youth, 4.84 percent a year.

Source
Wagenknecht et al., Lancet Diabetes & Endocrinology 11: 242–250
Date
2023
Quoted from
Results, first paragraph (author manuscript, PMC10091237)
Grade
Peer-reviewed
Document
https://pmc.ncbi.nlm.nih.gov/articles/PMC10091237/
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Exhibit 195 · Peer-reviewed study (abstract)

Guidelines for Early Food Introduction and Patterns of Food Allergy

Electronic-health-record study of children aged 0 to 3. Peanut IgE-mediated food allergy was 0.79 percent before early-introduction guidelines, 0.53 percent after the 2015 guidance (hazard ratio 0.65) and 0.45 percent after the 2017 addendum guidelines (hazard ratio 0.55). Any IgE-mediated food allergy fell from 1.46 to 1.02 to 0.93 percent. The Associated Press, reporting the study, wrote that about 8 percent of US children have a food allergy, more than 2 percent a peanut allergy, and that overall food allergy among US children has not declined.

Source
Pediatrics (American Academy of Pediatrics)
Date
October 2025
Grade
Peer-reviewed
Document
https://doi.org/10.1542/peds.2024-070516
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Note
Rates are from the abstract.

Exhibit 196 · Institutional history

Determination of the cause of Minamata disease

Chisso, which by 1959 had realized that the wastewater out of its factory was the cause, continued letting it flow out.

Records the investigation, Chisso’s knowledge by 1959, and continued wastewater discharge.

Source
National Institute for Minamata Disease
Date
Undated
Quoted from
Investigation of the Cause of Minamata Disease, third paragraph
Grade
Primary record
Document
https://nimd.env.go.jp/archives/english/minamata_disease_in_depth/cause_investigation/
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Exhibit 197 · Government report

Annual Report on the Environment in Japan 2006: Fifty Years of Minamata Disease

The mass media reported that the equipment would purify wastewater, but it was not designed to remove mercury, failing to remove water-soluble methyl mercury compounds.

Describes ineffective wastewater equipment, delayed government action, and continuing victim claims.

Source
Ministry of the Environment, Japan
Date
2006
Quoted from
Overview 2, Section 2 "Emergence and Expansion of Minamata Disease", p. 21 (parenthetical)
Grade
Primary record
Document
https://www.env.go.jp/content/900457263.pdf
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Exhibit 198 · Government chronology

Minamata Disease: The History and Measures — Chronology

Chisso Co., Ltd., stopped manufacturing of acetaldehyde. The collective view of the government on the cause of Minamata Disease announced.

Dates production changes, government recognition, court decisions, and compensation.

Source
Ministry of the Environment, Japan
Date
2002
Quoted from
Chronology Related to Minamata Disease, entry for 1968
Grade
Primary record
Document
https://www.env.go.jp/en/chemi/hs/minamata2002/refer.html
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Exhibit 199 · Enforcement announcement

EPA Settles PFOA Case Against DuPont

The violations resolved in this settlement consist of multiple failures to report information to EPA about substantial risk of injury to human health or the environment that DuPont obtained about PFOA from as early as 1981 and as recently as 2004.

EPA announces settlement of eight counts. Seven are failures to report to EPA information about substantial risk of injury to human health or the environment (TSCA Section 8(e)) that DuPont obtained about PFOA from as early as 1981 and as recently as 2004; the eighth is a RCRA permit count. The settlement carries a $10.25 million penalty and $6.25 million in supplemental projects.

Source
Environmental Protection Agency
Date
14 December 2005
Quoted from
EPA news release, 14 Dec 2005, paragraph 8
Grade
Primary record
Document
https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/fdcb2f665cac66bb852570d7005d6665.html
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Exhibit 201 · Document analysis

The Devil they Knew: Chemical Documents Analysis of Industry Influence on PFAS Science

Further, the industry used several strategies that have been shown common to tobacco, pharmaceutical and other industries to influence science and regulation – most notably, suppressing unfavorable research and distorting public discourse.

Analyzes internal DuPont and 3M documents for suppression of unfavorable findings and distortion of public disclosure.

Source
Nadia Gaber, Lisa Bero, and Tracey J. Woodruff; Annals of Global Health
Date
1 June 2023
Quoted from
Abstract, Results
Grade
Peer-reviewed
Document
https://annalsofglobalhealth.org/articles/10.5334/aogh.4013
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Exhibit 202 · Institutional history

The Rise and Fall of Lead in the Workplace

In the 1920's, the other major use of lead in the U.S. captured national attention when the production of TEL gasoline led to 15 worker fatalities, with many more succumbing to psychotic episodes due to lead exposure.

Recounts early tetraethyl-lead worker deaths and industry-sponsored research downplaying danger.

Source
National Institute for Occupational Safety and Health
Date
25 October 2021
Quoted from
Section "Leaded Gasoline: Poisonous Fuel", first paragraph
Grade
Primary record
Document
https://www.cdc.gov/niosh/bulletin/2021/lead.html
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Exhibit 203 · Regulatory announcement

EPA Requires Phase-Out of Lead in All Grades of Gasoline

leaded gasoline is also a significant source of exposure which can be readily controlled.

Announces refinery lead limits and identifies gasoline as a controllable source of population exposure.

Source
Environmental Protection Agency
Date
28 November 1973
Quoted from
EPA press release, 28 Nov 1973, paragraph 4
Grade
Primary record
Document
https://www.epa.gov/archive/epa/aboutepa/epa-requires-phase-out-lead-all-grades-gasoline.html
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Exhibit 204 · Population survey analysis

The decline in blood lead levels in the United States: NHANES

The mean blood lead level of persons aged 1 to 74 years dropped 78%, from 0.62 to 0.14 mumol/L (12.8 to 2.8 micrograms/dL).

Reports a 78 percent decline in mean blood lead between the two national survey periods.

Source
James L. Pirkle and colleagues; JAMA
Date
27 July 1994
Quoted from
Abstract, Results (JAMA 1994;272:284-91; NHANES II 1976-80 vs NHANES III phase 1 1988-91)
Grade
Peer-reviewed
Document
https://pubmed.ncbi.nlm.nih.gov/8028141/
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Exhibit 205 · Regulatory announcement

EPA Takes Final Step in Phaseout of Leaded Gasoline

Effective January 1, 1996, the Clean Air Act banned the sale of the small amount of leaded fuel that was still available in some parts of the country for use in on-road vehicles. EPA said fuel containing lead may continue to be sold for off-road uses, including aircraft, racing cars, farm equipment, and marine engines.

Records the January 1996 on-road fuel ban and continuing exceptions for other uses.

Source
Environmental Protection Agency
Date
29 January 1996
Quoted from
EPA press release, 29 Jan 1996, fourth paragraph
Grade
Primary record
Document
https://www.epa.gov/archive/epa/aboutepa/epa-takes-final-step-phaseout-leaded-gasoline.html
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Exhibit 206 · Judicial opinion

United States v. Philip Morris USA Inc.: Amended Final Opinion

the Government has established that Defendants (1) have conspired together to violate the substantive provisions of RICO, pursuant to 18 U.S.C. § 1962 (d), and (2) have in fact violated those provisions of the statute, pursuant to 18 U.S.C. § 1962 (c).

Finds a tobacco-industry racketeering conspiracy and reconstructs its public statements and internal practices.

Source
U.S. District Court for the District of Columbia; Judge Gladys Kessler
Date
17 August 2006; amended opinion filed 8 September 2006
Quoted from
Amended Final Opinion, Part I.A Overview, p. 2 (PDF p. 32 of 1682)
Grade
Primary record
Document
https://www.justice.gov/civil/cases/tobacco2/amended%20opinion.pdf
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Note
Further exact wording (Findings of Fact, paragraph 726, from an internal Brown & Williamson document titled 'Smoking and Health Proposal'): 'Doubt is our product since it is the best means of competing with the 'body of fact' that exists in the mind of the general public. It is also a means of establishing a controversy.'

Exhibit 207 · Judicial order

United States v. Philip Morris USA Inc.: Final Judgment and Remedial Order

It is hereby Ordered that Final Judgment is entered for the Plaintiff, the United States of America, on Counts 3 and 4 of the Complaint, imposing liability under Sections 1962(c) and (d) of the Racketeer Influenced and Corrupt Organizations Chapter of Title 18 of the United States Criminal Code.

Imposes RICO liability and orders corrective statements, restrictions on deception, and document access.

Source
U.S. District Court for the District of Columbia; Judge Gladys Kessler
Date
17 August 2006
Quoted from
Order #1015, Section I (Judgment), p. 1; signed 17 August 2006
Grade
Primary record
Document
https://www.justice.gov/civil/cases/tobacco2/ORDER_FINAL.pdf
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Exhibit 208 · Enforcement announcement

Court Issues Order Requiring Cigarette Companies to Post Corrective Statements

This point-of-sale corrective statements remedy is the only remedy issued by the trial court that has not yet been implemented.

Explains the final retail-display remedy and the intervening appeals and implementation delays.

Source
U.S. Department of Justice
Date
6 December 2022
Quoted from
DOJ press release 22-1307, 6 Dec 2022, paragraph 10
Grade
Primary record
Document
https://www.justice.gov/archives/opa/pr/court-issues-order-requiring-cigarette-companies-post-corrective-statements-resolves-historic
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Exhibit 209 · Agency fact sheet

Diethylstilbestrol (DES) Exposure and Cancer

Soon after, the Food and Drug Administration (FDA) notified health care providers throughout the country that DES should not be prescribed to pregnant women

NCI fact sheet. It records that use of DES declined after studies in the 1950s showed it was not effective in preventing pregnancy complications, that researchers linked prenatal DES exposure to cancer in 1971, that the FDA soon afterward notified health care providers throughout the country that DES should not be prescribed to pregnant women, and the specific long-term health risks of exposure.

Source
National Cancer Institute
Date
Undated; accessed 9 November 2026
Quoted from
Introductory paragraph ("In 1971, researchers linked prenatal DES exposure ... Soon after, ...")
Grade
Primary record
Document
https://www.cancer.gov/about-cancer/causes-prevention/risk/hormones/des-fact-sheet
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Exhibit 210 · Case-control study

Adenocarcinoma of the Vagina: Association of Maternal Stilbestrol Therapy with Tumor Appearance in Young Women

Most significantly, seven of the eight mothers of patients with carcinoma had been treated with diethylstilbestrol started during the first trimester. None in the control group were so treated (p less than 0.00001).

Compares eight young cancer patients with matched controls and identifies prenatal DES exposure.

Source
Arthur L. Herbst, Howard Ulfelder, and David C. Poskanzer; New England Journal of Medicine
Date
22 April 1971
Quoted from
Abstract (N Engl J Med 1971;284:878-881)
Grade
Peer-reviewed
Document
https://www.nejm.org/doi/full/10.1056/NEJM197104222841604
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Exhibit 211 · Cohort study

Adverse Health Outcomes in Women Exposed In Utero to Diethylstilbestrol

In utero exposure of women to DES is associated with a high lifetime risk of a broad spectrum of adverse health outcomes.

Tracks reproductive and cancer outcomes decades after prenatal exposure.

Source
Robert N. Hoover and colleagues; New England Journal of Medicine
Date
6 October 2011
Quoted from
Abstract, Conclusions (N Engl J Med 2011;365:1304-1314)
Grade
Peer-reviewed
Document
https://www.nejm.org/doi/full/10.1056/NEJMoa1013961
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Exhibit 212 · Agency history

The Origins of the Agent Orange Act of 1991

At the time, only chloracne, a rare skin condition, had been scientifically linked to dioxin exposure. If Veterans claimed that contact with herbicides was the cause for any other illnesses, VA ultimately denied their medical claims due to the lack of scientific evidence.

VA retrospectively describes claims denials and policy changes.

Source
Department of Veterans Affairs
Date
21 August 2025
Quoted from
Section on claims, 1977-1980s (page by Jordan McIntire, 21 Aug 2025)
Grade
Primary record
Document
https://department.va.gov/history/the-origins-of-the-agent-orange-act-of-1991/
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Exhibit 213 · Statute

Agent Orange Act of 1991, Public Law 102-4

shall be considered to have been incurred in or aggravated by such service, notwithstanding that there is no record of evidence of such disease during the period of such service.

Establishes presumptions and a scientific-review process for herbicide-associated diseases.

Source
United States Congress
Date
6 February 1991
Quoted from
Sec. 2(a), new 38 U.S.C. § 316(a)(1), 105 Stat. 11
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/STATUTE-105/pdf/STATUTE-105-Pg11.pdf
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Exhibit 214 · Government project announcement

VN, US start dioxin cleanup project at biggest hotsport

The United States Agency for International Development (USAID) and Viet Nam’s Air Defense Airforce Command (ADAFC) on April 20 launched the dioxin remediation project at Bien Hoa Airbase, the largest remaining hotspot of dioxin contamination in Viet Nam.

Records the Bien Hoa remediation launch and preceding Da Nang cleanup.

Source
Government of Vietnam
Date
20 April 2019
Quoted from
VGP news item dated 20 April 2019, first paragraph
Grade
Primary record
Document
https://en.baochinhphu.vn/vn-us-start-dioxin-cleanup-project-at-biggest-hotsport-11134987.htm
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Exhibit 215 · Audit report

Defense Health Care: Activities Related to Past Drinking Water Contamination at Marine Corps Base Camp Lejeune, GAO-07-276

By 1985, 10 wells that were determined to be contaminated with VOCs had been removed from service.

Reconstructs contamination detection, well closures, and subsequent federal investigations.

Source
Government Accountability Office
Date
11 May 2007
Quoted from
GAO-07-276 (11 May 2007), letter, first page; Table 3 lists the dates wells were removed from service in 1984 and 1985
Grade
Primary record
Document
https://www.gao.gov/assets/a260487.html
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Exhibit 216 · Congressional testimony

ATSDR Activities at U.S. Marine Corps Base Camp Lejeune: testimony of Christopher Portier

ATSDR removed the PHA from its website in 2009 and plans to reassess the drinking water pathway and revise the PHA when water modeling analyses are completed.

Testimony of ATSDR's Christopher Portier to the House Committee on Science and Technology on 16 September 2010. ATSDR removed the 1997 public health assessment from its website in 2009 and plans to reassess the drinking water pathway and revise it when water modeling is completed. The testimony cites new information that Holcomb Boulevard residents were exposed longer than known in 1997 and that Hadnot Point benzene levels were higher.

Source
Agency for Toxic Substances and Disease Registry; House Committee on Science and Technology
Date
16 September 2010
Quoted from
Testimony of Christopher Portier, 16 Sept 2010, p. 4
Grade
Primary record
Document
https://science.house.gov/sites/republicans.science.house.gov/files/documents/hearings/091610_Portier.pdf
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Exhibit 217 · Agency assessment history

Drinking Water PHA

The 1997 PHA was removed from the ATSDR website in 2009 and is being replaced with an updated PHA.

Confirms the 1997 hazard assessment and its 2009 withdrawal.

Source
Agency for Toxic Substances and Disease Registry
Date
12 November 2024
Quoted from
Overview section, updated 12 Nov 2024
Grade
Primary record
Document
https://www.atsdr.cdc.gov/camp-lejeune/php/public-health-assessments/drinking-water-pha.html
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Exhibit 218 · Agency settlement announcement

Justice Department and Department of the Navy Announce Voluntary Elective Option for More Efficient Resolution of Camp Lejeune Justice Act Claims

The Elective Option provides similar settlement offers to claimants with similar exposures and injuries with similar evidence of causation.

Describes the statutory remedy and diagnosis-based elective settlement process.

Source
Department of Justice; Department of the Navy
Date
6 September 2023
Quoted from
DOJ press release, 6 Sep 2023, fourth paragraph
Grade
Primary record
Document
https://www.justice.gov/archives/opa/pr/justice-department-and-department-navy-announce-voluntary-elective-option-more-efficient
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Exhibit 219 · Congressional audit testimony

Gulf War Illnesses: DOD's Conclusions About U.S. Troops' Exposure Cannot Be Adequately Supported, GAO-04-821T

The models were not fully developed for analyzing long-range dispersion of CW agents as an environmental hazard.

Challenges exposure modeling and health conclusions derived from it.

Source
General Accounting Office
Date
1 June 2004
Quoted from
GAO-04-821T, Highlights, "What GAO Found", paragraph 1
Grade
Primary record
Document
https://www.gao.gov/assets/a110990.html
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Exhibit 220 · Research advisory report

Gulf War Illness and the Health of Gulf War Veterans: Research Update and Recommendations, 2009–2013

The research reviewed in this report supports and reinforces the conclusion in the 2008 RACGWVI report that exposures to pesticides and pyridostigmine bromide are causally associated with Gulf War illness. Evidence also continues to demonstrate that Gulf War illness is not the result of psychological stressors during the war.

Attributes Gulf War illness to hazardous exposures, including pesticides and pyridostigmine bromide.

Source
Research Advisory Committee on Gulf War Veterans’ Illnesses
Date
2014
Quoted from
Findings in Brief, p. 3 (PDF p. 9)
Grade
Primary record
Document
https://www.va.gov/RAC-GWVI/RACReport2014Final.pdf
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Exhibit 221 · Consensus report

Gulf War and Health, Volume 10: Summary

Indeed, the constellation of symptoms and symptom clusters referred to as Gulf War illness (e.g., fatigue, muscle and joint pain, and cognitive problems) is the signature adverse health outcome of having served in the Persian Gulf region.

Recognizes deployment-associated illness and limits from missing individual exposure information.

Source
National Academies of Sciences, Engineering, and Medicine
Date
2016
Quoted from
Summary chapter (chapter 2), conclusions on deployment and health outcomes
Grade
Primary record
Document
https://www.nationalacademies.org/read/21840/chapter/2
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Exhibit 222 · Federal inquiry report

Advisory Committee on Human Radiation Experiments: Executive Summary

Even after this extraordinary effort, the historical record remains incomplete.

Summarizes experimentation, consent failures, record gaps, and recommendations.

Source
Advisory Committee on Human Radiation Experiments
Date
1995
Quoted from
Executive Summary, introduction (paragraph on documents retrieved)
Grade
Primary record
Document
https://ehss.energy.gov/ohre/roadmap/achre/summary.html
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Exhibit 223 · Federal inquiry report

Human Radiation Experiments, Chapter 13: The Practice of Secrecy

Through as late as 1949, the declassification of reports on human experiments involved their review for public relations and legal liability implications.

Documents concealment motivated by public-relations and legal-liability concerns.

Source
Advisory Committee on Human Radiation Experiments
Date
1995
Quoted from
Chapter 13, "The AEC Addresses Secret Manhattan Project Experiments", first paragraphs
Grade
Primary record
Document
https://ehss.energy.gov/ohre/roadmap/achre/chap13_3.html
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Exhibit 224 · Agency historical reconstruction

Human Radiation Experiments: The Department of Energy Roadmap to the Story and the Records, Chapter 1

Over the next 2 years, 17 other people also received plutonium injections.

Describes the plutonium-injection program and subsequent recovery of records.

Source
Department of Energy
Date
1995
Quoted from
Chapter 1, Introduction, first paragraph
Grade
Primary record
Document
https://ehss.energy.gov/ohre/roadmap/roadmap/part1.html
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Exhibit 225 · Federal response report

Building Public Trust: Actions to Respond to the Report of the Advisory Committee on Human Radiation Experiments, Part 3

For most experiments, names are unavailable.

Part 3 of the interagency working group's response to the Advisory Committee on Human Radiation Experiments. It states that for most experiments names are unavailable and that, even where more detailed records survive, information about individuals is generally fragmentary and does not include their current whereabouts. It sets out criteria for notifying subjects and records disputes about redress.

Source
Human Radiation Interagency Working Group
Date
1997
Quoted from
Part 3, notification section, Administration response
Grade
Primary record
Document
https://ehss.energy.gov/ohre/roadmap/whitehouse/part3.html
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Exhibit 226 · Congressional hearing

Project MKULTRA, the CIA's Program of Research in Behavioral Modification

Until the recent discovery, it was believed that all of the MKULTRA files dealing with behavioral modification had been destroyed in 1973 on the orders of the then retiring Chief of the Office of Technical Service, with the authorization of the then DCI, as has been previously reported.

Records unwitting drug experiments, document destruction, and recovered financial records.

Source
United States Senate
Date
3 August 1977
Quoted from
Joint hearing, 3 Aug 1977, statement of Adm. Stansfield Turner, PDF p. 8
Grade
Primary record
Document
https://www.intelligence.senate.gov/wp-content/uploads/2024/08/sites-default-files-hearings-95mkultra.pdf
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Exhibit 227 · Original research: publisher extract

Effects of Repetition of Verbal Signals Upon the Behaviour of Chronic Psychoneurotic Patients

Studies of the effects of the repetition of statements, i.e., verbal signals, upon the behaviour of chronic psychoneurotic patients have been carried out in the Allan Memorial Institute continuously since 1953 (1).

The authors date their verbal-repetition research to 1953. Only the publisher extract is used.

Source
D. Ewen Cameron, Leonard Levy, and Leonard Rubenstein; Journal of Mental Science
Date
April 1960
Quoted from
Publisher extract, first sentence; J Ment Sci 106(443): 742-754
Grade
Peer-reviewed
Document
https://www.cambridge.org/core/journals/journal-of-mental-science/article/abs/effects-of-repetition-of-verbal-signals-upon-the-behaviour-of-chronic-psychoneurotic-patients/BCC3F6AC52792C06D44828B66404A70D
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Exhibit 228 · Parliamentary committee debate

Standing Committee on Justice, Human Rights, Public Safety and Emergency Preparedness: Evidence, Meeting 56

In this particular case, 332 applications were received, including an application on behalf of Lloyd Schrier, and 77 of the 332 were deemed acceptable.

Debates the Cameron compensation program and exclusion of a claimant exposed in utero.

Source
House of Commons of Canada
Date
27 October 2005
Quoted from
Evidence, Meeting 56, statement of Hon. Paul Harold Macklin
Grade
Primary record
Document
https://www.ourcommons.ca/DocumentViewer/en/38-1/JUST/meeting-56/evidence
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Exhibit 229 · Public inquiry report

Infected Blood Inquiry: Volume 1, Overview and Recommendations

I have to report that it could largely, though not entirely, have been avoided. And I have to report that it should have been.

Concludes that the infections were largely avoidable and estimates more than 3,000 attributable deaths.

Source
Infected Blood Inquiry, Sir Brian Langstaff
Date
20 May 2024
Quoted from
Volume 1, 1.1 Summary (PDF p. 5)
Grade
Primary record
Document
https://www.infectedbloodinquiry.org.uk/sites/default/files/Volume_1.pdf
Accessed
2026-11-09
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Note
Printed pp. 2–7; distinguish the inquiry's factual findings from individual criminal liability.

Exhibit 230 · Public inquiry report

Infected Blood Inquiry: Volume 2, People's Experiences and Treloar's

Parents were not given details, nor even core information, about their children’s treatment at Treloar’s for haemophilia.

Volume 2 of the Infected Blood Inquiry report. At Treloar's, parents were not given details, nor even core information, about their children's treatment for haemophilia. The inquiry concluded that the pupils were often regarded as objects for research, rather than first and foremost as children whose treatment should be firmly focused on their individual best interests alone, and that this was unethical and wrong. Volume 2 also records witness accounts of parents not told of infection risks.

Source
Infected Blood Inquiry, Sir Brian Langstaff
Date
20 May 2024
Quoted from
Volume 2, 2.2 Treloar's (PDF p. 209); summary conclusion at PDF p. 216
Grade
Primary record
Document
https://www.infectedbloodinquiry.org.uk/sites/default/files/Volume_2.pdf
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Note
Printed pp. 167–169 and 209–216.

Exhibit 231 · Public inquiry report

Infected Blood Inquiry: Volume 3, What Happened and Why?

Competitive mass production led to commercial products being manufactured in the US and in Europe from pools which consisted of several thousand individual donations (“large pool concentrates”).

Examines contemporaneous knowledge of infection risks and the increase in plasma pool sizes used for factor concentrates.

Source
Infected Blood Inquiry, Sir Brian Langstaff
Date
20 May 2024
Quoted from
Volume 3, early chapter on blood products (PDF p. 43)
Grade
Primary record
Document
https://www.infectedbloodinquiry.org.uk/sites/default/files/Volume_3.pdf
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Note
Chapters 3.5–3.8 and 3.15; especially printed pp. 458–466.

Exhibit 232 · Contemporaneous surveillance report

Pneumocystis carinii Pneumonia among Persons with Hemophilia A

CDC recently received reports of three cases of Pneumocystis carinii pneumonia among patients with hemophilia A and without other underlying disease.

Reports three patients with hemophilia A and severe immune deficiency; all had received Factor VIII concentrate.

Source
Centers for Disease Control, MMWR
Date
16 July 1982
Quoted from
MMWR Epidemiologic Notes and Reports, opening paragraph
Grade
Primary record
Document
https://www.cdc.gov/mmwr/preview/mmwrhtml/00001126.htm
Accessed
2026-11-09
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Exhibit 233 · Public inquiry report

Infected Blood Inquiry: Volume 7, Response of Government

Hiding the truth includes not only deliberate concealment (which the words “cover-up” often imply to the exclusion of more subtle processes) but also a lack of candour; the retelling of half-truths

Finds concealment and misleading official responses. Separately assesses missing records, deliberate destruction, and limits on attributing responsibility.

Source
Infected Blood Inquiry, Sir Brian Langstaff
Date
20 May 2024
Quoted from
Volume 7, 7.9 Commentary on the Government Response, "Cover-up" (PDF p. 289)
Grade
Primary record
Document
https://www.infectedbloodinquiry.org.uk/sites/default/files/Volume_7.pdf
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2026-11-09
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Note
Printed pp. 60–61, 130–178, 286–299. The document-destruction conclusion is expressly tentative and probabilistic.

Exhibit 234 · Statement to Parliament

Prime Minister's Statement on the Infected Blood Inquiry

And third, to apologise for the institutional refusal to face up to these failings – and worse, to deny and even attempt to cover them up.

Apologizes for avoidable infections, institutional denial, concealment, destruction of records, and the delay in securing an inquiry.

Source
Rishi Sunak, Prime Minister's Office
Date
20 May 2024
Quoted from
Statement to the House of Commons, 20 May 2024, apology paragraphs
Grade
Primary record
Document
https://www.gov.uk/government/speeches/pm-statement-on-the-infected-blood-inquiry-20-may-2024
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Exhibit 235 · Public inquiry report

Infected Blood Inquiry: Additional Report on Compensation

The position of people bereaved after 31 March 2025 who will have no entitlement to ongoing support payments (in contrast to the position of people bereaved on or before 31 March) is examined in Chapter 8 Bereavement after 31 March 2025.

Returns to compensation implementation, participation, delay, and a support-payment gap for newly bereaved partners.

Source
Infected Blood Inquiry, Sir Brian Langstaff
Date
9 July 2025
Quoted from
Overview, PDF p. 8; report dated 9 July 2025 (HC 1167)
Grade
Primary record
Document
https://www.infectedbloodinquiry.org.uk/sites/default/files/2025-06/Infected%20Blood%20Inquiry%20Additional%20Report%20on%20Compensation.pdf
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2026-11-09
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Note
Printed pp. 2–5, 29–32, 172–175. Describes the scheme at the report date, not its current rules.

Exhibit 236 · Researcher's first-person historical account

Lyme Arthritis: A 50-Year Journey

At their appointment, I met with the mother of the family, Polly Murray, and reviewed her notebook with information about children and adults with arthritis that she knew of in Lyme.

Recalls the mothers' reports and Polly Murray's notebook that helped initiate the 1975 Connecticut investigation.

Source
Allen C. Steere, Journal of Infectious Diseases
Date
2024
Quoted from
Opening narrative before "Epidemiologic Investigation" (Steere, J Infect Dis 2024)
Grade
Peer-reviewed
Document
https://pmc.ncbi.nlm.nih.gov/articles/PMC11322885/
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Note
Opening narrative and Epidemiologic Investigation. A retrospective account by a participant, not a contemporaneous 1975 record.

Exhibit 237 · Original clinical investigation

Lyme Arthritis: An Epidemic of Oligoarticular Arthritis in Children and Adults in Three Connecticut Communities

The authors studied 51 residents of three contiguous Connecticut communities—39 children and 12 adults—who developed an illness characterized by recurrent attacks of asymmetric swelling and pain in a few large joints, especially the knee.

Describes 51 patients in three Connecticut communities and an illness characterized by recurrent large-joint inflammation.

Source
Allen C. Steere and colleagues, Arthritis & Rheumatism
Date
January–February 1977
Quoted from
Abstract (Arthritis Rheum 1977;20:7-17)
Grade
Peer-reviewed
Document
https://doi.org/10.1002/art.1780200102
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2026-11-09
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Note
Abstract inspected; full paper not obtained.

Exhibit 238 · Attorney general's release preserved in legislative record

Attorney General's Investigation Reveals Flawed Lyme Disease Guideline Process

The IDSA failed to conduct a conflicts of interest review for any of the panelists prior to their appointment to the 2006 Lyme disease guideline panel;

Announces process findings involving conflicts and excluded viewpoints, plus an agreement for an independently screened review panel.

Source
Connecticut Attorney General Richard Blumenthal; reproduced in the Congressional Record
Date
1 May 2008 (reprinted 27 September 2008)
Quoted from
Congressional Record (House), 27 Sept 2008, H10174, reproducing the Connecticut AG press release of 1 May 2008 ("Blumenthal's findings include the following")
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/CREC-2008-09-27/pdf/CREC-2008-09-27.pdf
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Note
Congressional Record, pp. H10174–H10175. An investigative announcement, not a court judgment or finding of treatment efficacy.

Exhibit 239 · Guideline review report

Final Report of the Lyme Disease Review Panel

Based on its review of all the evidence and information provided, the Review Panel determined that no changes or revisions to the 2006 Lyme Guidelines are necessary at this time (8-0).

Records the external conflict screening and public hearing, and retains the 2006 guideline recommendations after review.

Source
Infectious Diseases Society of America
Date
22 April 2010
Quoted from
Section "Review Panel Vote on Overall Guidelines"; report dated 22 April 2010
Grade
Primary record
Document
https://www.idsociety.org/globalassets/idsa/topics-of-interest/lyme/idsalymediseasefinalreport.pdf
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Note
Printed pp. 1–5 and individual recommendation votes. Primary evidence of the review's process and conclusions.

Exhibit 240 · Clinical practice guideline

AAN/ACR/IDSA 2020 Guidelines for the Prevention, Diagnosis and Treatment of Lyme Disease

For patients who have persistent or recurring nonspecific symptoms such as fatigue, pain, or cognitive impairment following recommended treatment for Lyme disease, but who lack objective evidence of reinfection or treatment failure, we recommend against additional antibiotic therapy

Section XXV distinguishes persistent nonspecific symptoms from objective evidence of reinfection or treatment failure in its recommendation against additional antibiotics.

Source
IDSA, American Academy of Neurology, American College of Rheumatology
Date
30 November 2020
Quoted from
Recommendation XXV
Grade
Primary record
Document
https://www.idsociety.org/practice-guideline/lyme-disease/
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Exhibit 241 · Research funding announcement

NIH Awards Will Fund Post-Treatment Lyme Disease Syndrome Research

The new NIAID awards for PTLDS, which will total approximately $3.2 million in first-year funding, will support work on possible causes of persistent PTLDS symptoms for five years.

Announces five projects on persistent symptoms, including bacterial fragments, immune biomarkers, and autoantibodies; approximately $3.2 million in first-year funding.

Source
National Institutes of Health / National Institute of Allergy and Infectious Diseases
Date
21 July 2023
Quoted from
NIH news release, 21 July 2023, paragraph beginning 'The new NIAID awards'
Grade
Primary record
Document
https://www.nih.gov/news-events/news-releases/nih-awards-will-fund-post-treatment-lyme-disease-syndrome-research
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Exhibit 242 · Agency patient-information page

Chronic Symptoms and Lyme Disease

The condition where patients experience prolonged symptoms due to Lyme disease is called Post-Treatment Lyme Disease Syndrome (PTLDS) and its cause is currently unknown.

Recognizes persistent symptoms after treatment, states that their cause is unknown, and distinguishes PTLDS from a claim of ongoing bacterial infection.

Source
Centers for Disease Control and Prevention
Date
26 June 2026
Quoted from
CDC page dated 26 June 2026, section 'Recommended terminology'
Grade
Primary record
Document
https://www.cdc.gov/lyme/signs-symptoms/chronic-symptoms-and-lyme-disease.html
Accessed
2026-11-09
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Exhibit 243 · Research paper (not peer reviewed)

The U.S. Budgetary Costs of the Post-9/11 Wars

There has been no single U.S. government estimate for the total costs of the post-9/11 wars.

Table 1 sums DoD and State OCO ($2,101B and $189B), interest on OCO borrowing ($1,087B), a war-driven increase to the DoD base budget ($884B), veterans' care through FY2022 ($465B) and homeland security ($1,117B) to $5,843B, plus about $2,200B in future veterans' obligations (Bilmes) for $8,043B in current dollars. Excludes state and local spending, allied spending, future interest after FY2023 and some aid. Cites DoD's March 2021 figure of $1.596 trillion through FY2020.

Source
Costs of War Project, Watson Institute, Brown University (Neta C. Crawford)
Date
1 September 2021
Quoted from
p. 2
Grade
Primary record
Document
https://costsofwar.watson.brown.edu/sites/default/files/papers/Costs-of-War_US-Budgetary-Costs-of-Post-9-11-Wars.pdf
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Exhibit 244 · Project web page

U.S. Federal Budget (Costs of War research page, updated June 2025)

Of the $8 trillion total, about $2.3 trillion were spent on the budget category for post-9/11 military operations, “Overseas Contingency Operations.”

States the $8 trillion estimate through FY2022 ($5.8 trillion appropriations plus at least $2.2 trillion veterans' obligations), more than $1 trillion in interest, a base-budget increase of about $900 billion and over $1.1 trillion of DHS spending.

Source
Costs of War Project, Watson Institute, Brown University
Date
June 2025
Quoted from
Key Findings, Spending on the Post-9/11 Wars
Grade
Primary record
Document
https://costsofwar.watson.brown.edu/costs/economic/us-federal-budget
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Exhibit 245 · Agency report to Congress

Estimated Cost to Each U.S. Taxpayer for the Wars in Afghanistan, Iraq and Syria, and Ukraine (Section 1090 Report)

These amounts exclude non-Department of Defense classified programs.

Cumulative war-related costs FY2001 to FY2023: Afghanistan $881,941 million, Iraq and Syria $799,318 million, Ukraine $48,657 million, total $1,729,916 million ($8,702 per taxpayer).

Source
U.S. Department of Defense, Office of the Comptroller
Date
April 2024
Quoted from
Table footnote 1/
Grade
Primary record
Document
https://comptroller.defense.gov/Portals/45/documents/Section1090Reports/Estimated_Cost_to_Each_US_Taxpayer_of_Each_Wars_in_Afghanistan_Iraq_and_Syria_and_Ukraine_dated_June_2024.pdf
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Exhibit 246 · Think-tank report

America's Military Spending and the Uncertain Costs of its Wars: The Need for Transparent Reporting

some outside efforts to estimate the total cost of U.S. conflicts may sharply overestimate total costs

Reviews OCO and DoD cost-of-war reporting and analyzes an earlier Crawford estimate. Says some outside estimates may overestimate costs, that the OCO line is partly inflated by low-level operations and by non-war items Congress allowed to avoid Budget Control Act limits, and that government reporting on war costs is inadequate.

Source
Center for Strategic and International Studies (Anthony H. Cordesman)
Date
23 January 2019
Quoted from
Summary
Grade
Primary record
Document
https://www.csis.org/analysis/americas-military-spending-and-uncertain-costs-its-wars-need-transparent-reporting
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Exhibit 247 · Agency report

Funding for Overseas Contingency Operations and Its Impact on Defense Spending

CBO estimates that in each year since 2006, more than $50 billion, on average, of the total funding designated for OCO has been used to support enduring activities rather than the temporary costs of overseas operations.

Nonbase funding since 2001 totaled about $2.2 trillion, about 20 percent of DoD appropriations, 98 percent of it OCO. Of $86 billion appropriated for OCO in 2017, 22 percent was used for base-budget needs.

Source
Congressional Budget Office
Date
October 2018
Quoted from
Summary, p. 1
Grade
Primary record
Document
https://www.cbo.gov/publication/54219
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Exhibit 248 · Audit report

Overseas Contingency Operations: OMB and DOD Should Revise the Criteria for Determining Eligible Costs and Identify the Costs Likely to Endure Long Term, GAO-17-68

Further, the amount of OCO appropriations DOD considers as non-war increased from about 4 percent in fiscal year 2010 to 12 percent in fiscal year 2015.

DoD's internal estimate of enduring costs funded in OCO was $20 to $30 billion, as much as 46 percent of the FY2017 OCO request, not finalized or reported outside DoD because statutory caps limited base-budget increases. GAO recommended revised criteria and a reliable enduring-cost estimate; DoD concurred with the first and partially with the second.

Source
U.S. Government Accountability Office
Date
January 2017
Quoted from
Highlights, What GAO Found
Grade
Primary record
Document
https://www.gao.gov/products/gao-17-68
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Exhibit 249 · Audit report

Defense Budget: Obligations of Overseas Contingency Operations Funding for Operation and Maintenance Base Requirements, GAO-18-202R

On occasion, Congress has directed that O&M OCO appropriations be used to support base requirements.

The FY2016 NDAA authorized $9.1 billion of O&M OCO funds for base requirements; in FY2015 Congress directed $1 billion of O&M OCO to readiness. GAO notes DoD concurred with its 2017 recommendations but had taken no steps to implement them.

Source
U.S. Government Accountability Office
Date
10 January 2018
Quoted from
p. 1
Grade
Primary record
Document
https://www.gao.gov/products/gao-18-202r
Accessed
2026-11-09
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Exhibit 250 · Research paper (not peer reviewed)

The Long-Term Costs of United States Care for Veterans of the Afghanistan and Iraq Wars

Between 2001 and 2050, the total costs of caring for veterans of the post-9/11 wars are estimated to reach between $2.2 and $2.5 trillion.

Projection built from VA VetPop actuarial tables and BLS data; double the author's 2011 and 2013 projections; more than 40 percent of post-9/11 veterans already approved for lifetime disability benefits. Published before the PACT Act (August 2022), so it does not include PACT-driven changes.

Source
Costs of War Project (Linda J. Bilmes, Harvard Kennedy School)
Date
18 August 2021
Quoted from
Summary, p. 1
Grade
Primary record
Document
https://costsofwar.watson.brown.edu/sites/default/files/papers/Costs-of-War_Bilmes_Long-Term-Costs-Care-Vets_Aug-2021.pdf
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Exhibit 251 · Consensus report release

Evidence Inconclusive About Long-Term Health Effects of Exposure to Military Burn Pits (news release for Long-Term Health Consequences of Exposure to Burn Pits in Iraq and Afghanistan)

Insufficient data on service members' exposures to emissions from open-air burn pits for trash on military bases in Iraq and Afghanistan is one of the reasons why it is not possible to say whether these emissions could cause long-term health effects

Release for the VA-sponsored report (nap.nationalacademies.org/catalog/13209). Committee found most pollutant levels at Joint Base Balad not higher than other polluted sites, found surrogate-population research did not indicate increased risk for most outcomes, and said gaps prevented firm conclusions. Recommended a long-term health study of Balad service members.

Source
Institute of Medicine (National Academies)
Date
31 October 2011
Quoted from
Release, first paragraph
Grade
Primary record
Document
https://www.nationalacademies.org/news/2011/10/evidence-inconclusive-about-long-term-health-effects-of-exposure-to-military-burn-pits
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Exhibit 252 · Statute

Public Law 117-168, Sergeant First Class Heath Robinson Honoring our Promise to Address Comprehensive Toxics (PACT) Act of 2022

notwithstanding that there is no record of evidence of such disease during the period of such service

Adds 38 U.S.C. 1119 (presumption of exposure for covered veterans at listed Gulf War and post-9/11 locations unless affirmative evidence shows no exposure) and 1120 (presumptive service connection for asthma, listed cancers, COPD, bronchitis, lung diseases, sinusitis, rhinitis and glioblastoma, phased in through October 1, 2025). Sec. 805 creates the Cost of War Toxic Exposures Fund; Sec. 808 requires burn-pit transparency reports.

Source
U.S. Congress
Date
10 August 2022
Quoted from
136 Stat. 1784, new 38 U.S.C. 1120(a)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-117publ168/html/PLAW-117publ168.htm
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Exhibit 253 · Agency web page

The PACT Act and your VA benefits

The PACT Act is perhaps the largest health care and benefit expansion in VA history.

VA's own description of the PACT Act: expands health-care eligibility, adds 20-plus presumptive conditions for burn pits, Agent Orange and other exposures, requires toxic-exposure screening.

Source
U.S. Department of Veterans Affairs
Date
Page accessed 2026-11-09
Quoted from
Page text, section 'What's the PACT Act'
Grade
Primary record
Document
https://www.va.gov/resources/the-pact-act-and-your-va-benefits/
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Exhibit 254 · Cost estimate

Estimated Budgetary Effects of H.R. 3967, Honoring our PACT Act of 2021, as Passed by the House and as Amended by the Senate Committee on Veterans' Affairs

At the direction of the Senate Committee on the Budget and in keeping with section 805 of this act, CBO has classified those expenses as direct spending.

Table: total direct spending outlays $667.0 billion for 2022 to 2031, including $390.3 billion of current-law discretionary spending reclassified as direct and $113.0 billion of discretionary spending classified as direct; compensation $151.7 billion over 2022 to 2031. Scores a committee version, not the enacted text.

Source
Congressional Budget Office
Date
6 June 2022
Quoted from
Table footnote f, p. 3
Grade
Primary record
Document
https://www.cbo.gov/system/files/2022-06/hr3967_senate_version.pdf
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Exhibit 255 · Baseline projection

Baseline Projections: Toxic Exposures Fund

The Honoring our PACT Act of 2022 established the Toxic Exposures Fund (TEF) to provide mandatory funding for benefits for veterans who have been exposed to toxic substances or environmental hazards.

TEF estimated budget authority $52.7 billion in 2026; $758.3 billion budget authority and $746.2 billion outlays for 2027 to 2036.

Source
Congressional Budget Office
Date
February 2026
Quoted from
p. 1
Grade
Primary record
Document
https://www.cbo.gov/system/files/2026-02/60044-2026-02-tef.pdf
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2026-11-09
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Exhibit 256 · Budget document

Budget of the U.S. Government, Fiscal Year 2027: Department of Veterans Affairs

The Budget provides a total for medical care of $175.5 billion in 2027. This is comprised of $123.4 billion in discretionary medical care funding and $52.1 billion in mandatory funding from the Toxic Exposures Fund.

FY2027 request: $144.9 billion discretionary budget authority for VA; $175.5 billion medical care including $52.1 billion mandatory from the Toxic Exposures Fund.

Source
Office of Management and Budget
Date
2026
Quoted from
p. 55
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/BUDGET-2027-BUD/pdf/BUDGET-2027-BUD-18.pdf
Accessed
2026-11-09
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Exhibit 257 · Congressionally mandated report

2026 National Veteran Suicide Prevention Annual Report

Of note, there is not a single comprehensive roster of the Veteran population and source records may be incomplete or contain errors.

2001 to 2024: 159,980 veteran suicides. 2024: 6,488 (17.7 a day); firearms in 74.3 percent; age-adjusted rate 56.5 percent higher for male veterans and 99.9 percent higher for female veterans than non-veteran adults; 55.8 percent of 2024 decedents had VA contact in 2024 or the prior five years, 44.2 percent did not; suicide rate with a recent TBI diagnosis 80.1 per 100,000 against 38.0 without. Says it is not an evaluation of risk factors or program impact (footnote 3, p. 8).

Source
U.S. Department of Veterans Affairs
Date
September 2026
Quoted from
Limitations, p. 105
Grade
Primary record
Document
https://www.mentalhealth.va.gov/MENTALHEALTH/docs/data-sheets/2026/CMR_2026_National_Veteran_Suicide_Prevention_Annual_Report.pdf
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2026-11-09
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Exhibit 258 · Research paper (not peer reviewed); page read, full paper not read

High Suicide Rates among United States Service Members and Veterans of the Post-9/11 Wars

at least four times as many active duty personnel and war veterans of post-9/11 conflicts have died of suicide than in combat

Uses governmental data, secondary literature and interviews to estimate 30,177 suicides among post-9/11 active-duty personnel and veterans versus 7,057 killed in war operations; names IED exposure, TBI and repeated deployment among factors.

Source
Costs of War Project (Ben Suitt)
Date
21 June 2021
Quoted from
Paper abstract on project page
Grade
Primary record
Document
https://costsofwar.watson.brown.edu/paper/high-suicide-rates-among-united-states-service-members-and-veterans-post-911-wars
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2026-11-09
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Exhibit 259 · Agency surveillance data

DOD TBI Worldwide Numbers (with 2000-2025 Q4 report)

If a service member has had more than one TBI, only one of their injuries is counted for the purpose of this reporting.

The 2000 to 2025 Q4 report (as of 8 June 2026; /Reference-Center/Reports/2026/09/15/2000-2025-Q4-DOD-Worldwide-Numbers-for-TBI) totals 541,032 diagnoses: mild 442,538 (81.8 percent), moderate 66,824, severe 5,109, penetrating 5,959, not classifiable 20,602. Counts first diagnosed encounter anywhere U.S. forces are located, including the continental United States; the annual chart peaks near 33,000 in 2011.

Source
Defense Health Agency, Traumatic Brain Injury Center of Excellence
Date
15 September 2026
Quoted from
About the Data, FAQ
Grade
Primary record
Document
https://health.mil/Military-Health-Topics/Centers-of-Excellence/Traumatic-Brain-Injury-Center-of-Excellence/DOD-TBI-Worldwide-Numbers
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2026-11-09
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Exhibit 260 · Audit report

Defense Health Care: DOD Should Assess Its Needs for Managing Potential Brain Health Effects from Weapons Blast Exposures, GAO-26-107829

There is growing evidence that using certain weapons that produce high levels of what is called blast overpressure (the sudden onset of a pressure wave) can affect service members’ brain health.

DoD's August 2024 memorandum requires baseline cognitive assessments and exposure tracking; components reported insufficient staff and technology for assessments and a lack of industrial hygiene personnel for exposure tracking. GAO recommended comprehensive resource assessments; DoD agreed.

Source
U.S. Government Accountability Office
Date
18 August 2026
Quoted from
Highlights, Why GAO Did This Study
Grade
Primary record
Document
https://www.gao.gov/products/gao-26-107829
Accessed
2026-11-09
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Exhibit 261 · Project web page

Human (Costs of War research page)

An estimated over 940,000 people were killed by direct post-9/11 war violence in Iraq, Afghanistan, Syria, Yemen, and Pakistan between 2001-2023.

Headline human totals. The civilians page (/costs/human/civilians-killed-displaced, updated August 2026) separately says at least 408,749 civilians died as a direct result and 'Precise mortality figures remain unknown.'

Source
Costs of War Project, Watson Institute, Brown University
Date
Page accessed 2026-11-09
Quoted from
Page text
Grade
Primary record
Document
https://costsofwar.watson.brown.edu/costs/human
Accessed
2026-11-09
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Exhibit 262 · Research paper (not peer reviewed)

Human Cost of Post-9/11 Wars: Direct War Deaths in Major War Zones

Sources tend to be conservative, only counting deaths which researchers have verified through two or more independent sources.

Tally of 897,150 to 928,558 direct deaths through August 2021, including 7,052 U.S. military, 8,189 contractors and 363,939 to 387,072 civilians; says counts are approximations from several sources and that categories are disputed.

Source
Costs of War Project (Neta C. Crawford and Catherine Lutz)
Date
1 September 2021
Quoted from
Table footnote 1
Grade
Primary record
Document
https://costsofwar.watson.brown.edu/sites/default/files/papers/Costs-of-War_Direct-War-Deaths_9-1-21.pdf
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2026-11-09
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Exhibit 263 · Research paper (not peer reviewed)

How Death Outlives War: The Reverberating Impact of the Post-9/11 Wars on Human Health

These experts suggested that a reasonable, conservative average estimate for any contemporary conflict is a ratio of four indirect deaths for every one direct death.

Estimates 3.6 to 3.8 million indirect deaths by applying the Geneva Declaration Secretariat's 2008 ratio of four indirect to one direct death to 905,000 to 940,000 direct deaths; total 4.5 to 4.7 million. States the precise figure is unknown and the impacts are 'unquantifiable.'

Source
Costs of War Project (Stephanie Savell)
Date
15 May 2023
Quoted from
p. 10
Grade
Primary record
Document
https://costsofwar.watson.brown.edu/sites/default/files/papers/How-Death-Outlives-War.pdf
Accessed
2026-11-09
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Exhibit 264 · Research paper (not peer reviewed)

Creating Refugees: Displacement Caused by the United States' Post-9/11 Wars

37 million is a very conservative estimate.

Estimates at least 37 million displaced in eight wars, possibly 48 to 59 million; excludes disaster IDPs. A 19 August 2021 update on the project site gives 38 million.

Source
Costs of War Project (David Vine and others)
Date
21 September 2020
Quoted from
Major Findings, p. 2
Grade
Primary record
Document
https://costsofwar.watson.brown.edu/sites/default/files/papers/Vine-et-al-Displacement.pdf
Accessed
2026-11-09
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Exhibit 265 · Agency plan

Civilian Harm Mitigation and Response Action Plan

The U.S. military has not maintained an enterprise-wide, comprehensive database for civilian harm operational reporting and data management.

Eleven objectives. Objective 7 background says assessments and investigations 'have been applied inconsistently across DoD.'

Source
U.S. Department of Defense
Date
25 August 2022
Quoted from
Objective 6, Background
Grade
Primary record
Document
https://media.defense.gov/2022/Aug/25/2003064740/-1/-1/1/CIVILIAN-HARM-MITIGATION-AND-RESPONSE-ACTION-PLAN.PDF
Accessed
2026-11-09
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Exhibit 266 · Agency report to Congress (Section 1057, FY2018 NDAA)

Annual Report on Civilian Casualties in Connection With United States Military Operations in 2022

DoD has assessed that U.S. military operations in 2022 resulted in no civilian casualties.

Counts only casualties attributed to U.S.-operated weapons and only where 'more likely than not'; DoD made no ex gratia payments in Calendar Year 2022. The statute set a May 1 deadline; the document was generated 12 March 2024.

Source
U.S. Department of Defense
Date
March 2024 (published April 2024)
Quoted from
Section I, p. 5
Grade
Primary record
Document
https://media.defense.gov/2024/Apr/25/2003449887/-1/-1/0/CY2022-ANNUAL-REPORT-ON-CIVILIAN-CASUALTIES-IN-U.S.-MILITARY-OPERATIONS.PDF
Accessed
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Exhibit 267 · Agency report to Congress (Section 1057)

CY2023 Annual Report on Civilian Casualties in Connection With U.S. Military Operations

DoD has assessed that U.S. military operations in 2023 resulted in one civilian killed and one civilian injured.

Copy hosted by ecoi.net; official copy listed on policy.defense.gov. States DoD made two ex gratia payments in Calendar Year 2023 and that in some cases DoD has not been able to assess a report 'due to insufficient information provided or because related reports are still pending review.'

Source
U.S. Department of Defense
Date
2024
Quoted from
Section I
Grade
Primary record
Document
https://www.ecoi.net/en/file/local/2123499/CY2023-ANNUAL-REPORT-ON-CIVILIAN-CASUALTIES-IN-CONNECTION-WITH-U.S.-MILITARY-OPERATIONS.pdf
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2026-11-09
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Exhibit 268 · Inspector general evaluation

DODIG-2021-084: USCENTCOM targeting and civilian casualty (CIVCAS) processes evaluation (public redacted version)

We determined that for the period of June 2015 through November 2019, USCENTCOM, CJTF-OIR, and USFOR-A officials acted in accordance with JP 3-60 and CENTCOM authorities, policies and directives, and appropriately followed pre-strike targeting and kinetic strike approval procedures when identifying potential targets.

Objective: whether CENTCOM followed policies for targeting and for identifying, reviewing and reporting civilian-casualty allegations. Found pre-strike targeting followed doctrine; most findings and recommendations are redacted.

Source
DoD Office of Inspector General
Date
18 May 2021 (public release December 2021)
Quoted from
Finding A (PDF p. 19 of 44)
Grade
Primary record
Document
https://media.defense.gov/2021/Dec/10/2002907413/-1/-1/1/DODIG-2021-084%20(REDACTED).PDF
Accessed
2026-11-09
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Exhibit 269 · Audit report (public version of a classified report)

DOD Law of War Policies: Actions Needed to Ensure Proper Reporting and Retention of Alleged Violations, GAO-24-107217

DOD lacks comprehensive records of alleged law of war violations.

GAO obtained records of 47 alleged law-of-war violations by U.S. personnel in AFRICOM and CENTCOM, January 2012 to December 2022; not all entities could provide complete records. DoD concurred with both recommendations.

Source
U.S. Government Accountability Office
Date
February 2024
Quoted from
Highlights, What GAO Found
Grade
Primary record
Document
https://www.gao.gov/products/gao-24-107217
Accessed
2026-11-09
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Exhibit 270 · Audit report

Civilian Harm: DOD Should Take Actions to Enhance Its Plan for Mitigation and Response Efforts, GAO-24-106257

However, DOD has not addressed two key challenges as it has begun to implement the action plan.

The Action Plan captures 61 of 68 recommendations from nine studies; DoD did not concur with GAO's recommendation to set performance goals and measures.

Source
U.S. Government Accountability Office
Date
March 2024
Quoted from
Highlights, What GAO Found
Grade
Primary record
Document
https://www.gao.gov/products/gao-24-106257
Accessed
2026-11-09
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Exhibit 271 · Inspector general evaluation

Evaluation of the DoW's Implementation of the Civilian Harm Mitigation and Response Action Plan, DOWIG-2026-084

However, DoW Components did not fully implement any of the CHMR-AP objectives by the end of FY 2025.

DoD made progress (Steering Committee, hires, policies, Civilian Protection Center of Excellence) but components ended funding for the data management platform, stopped Steering Committee meetings and lost personnel; both recommendations unresolved.

Source
Department of Defense Office of Inspector General (secondary title Department of War OIG)
Date
13 May 2026
Quoted from
Results in Brief, p. i
Grade
Primary record
Document
https://www.oversight.gov/sites/default/files/documents/reports/2026-05/DOWIG-2026-084_Redacted%20SECURE.pdf
Accessed
2026-11-09
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Exhibit 272 · News investigation

Hidden Pentagon Records Reveal Patterns of Failure in Deadly Airstrikes (The Civilian Casualty Files)

To date, The Times has received 1,311 out of at least 2,866 reports — known as credibility assessments — examining airstrikes in Iraq and Syria between September 2014 and January 2018.

Based on 1,311 of at least 2,866 CENTCOM credibility assessments (Iraq and Syria, September 2014 to January 2018) obtained under FOIA and litigation. Reports 216 deemed credible; of the 1,311, one site visit and two witness interviews; military count of 1,417 civilians killed in Iraq and Syria and at least 188 in Afghanistan since 2018.

Source
The New York Times (Azmat Khan)
Date
18 December 2021
Quoted from
Article text, paragraph on the records
Grade
Reported
Document
https://www.nytimes.com/interactive/2021/12/18/us/airstrikes-pentagon-records-civilian-deaths.html
Accessed
2026-11-09
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Note
DoD, or DoD's Section 1057 reports.

Exhibit 273 · Court filing

Complaint, Khan v. U.S. Department of Defense and U.S. Central Command, No. 1:18-cv-05334 (S.D.N.Y.)

Ms. Khan’s FOIA requests seek specific records concerning allegations of civilian casualties and related reporting procedures from the U.S.-led operation in Iraq and Syria known as “Operation Inherent Resolve.”

FOIA complaint over three requests for CENTCOM records on civilian-casualty allegations in Operation Inherent Resolve; the lawsuit is a source of the records the Times analyzed.

Source
U.S. District Court, Southern District of New York (plaintiff Azmat Khan)
Date
13 June 2018
Quoted from
Complaint para. 1, p. 1
Grade
Primary record
Document
https://www.rcfp.org/wp-content/uploads/2022/01/2018-06-13-Khan-v.-DoD-Complaint.pdf
Accessed
2026-11-09
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Exhibit 274 · Peer-reviewed study

Use of Combat Casualty Care Data to Assess the US Military Trauma System During the Afghanistan and Iraq Conflicts, 2001-2017

CFR decreased in Afghanistan (20.0% to 8.6%) and Iraq (20.4% to 10.1%) from early stages to later stages of the conflicts.

Analysis of 56,763 battle casualties: case-fatality rate fell in Afghanistan from 20.0 to 8.6 percent and in Iraq from 20.4 to 10.1 percent; tourniquets, transfusion and transport times accounted for 44.2 percent of the estimated mortality reduction.

Source
JAMA Surgery (Howard JT and others)
Date
2019
Quoted from
Abstract, Results
Grade
Peer-reviewed
Document
https://doi.org/10.1001/jamasurg.2019.0151
Accessed
2026-11-09
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Exhibit 275 · Inspector general report

Understanding the Results of the Audit of the DoD FY 2018 Financial Statements

On November 15, 2018, the DoD OIG issued a disclaimer of opinion on the DoD financial statements.

Report on the first full DoD financial statement audit. Of 21 reporting entities, 5 received unmodified opinions, 1 qualified, 13 disclaimers and 2 audits were incomplete. 20 agency-wide material weaknesses and more than 2,400 notices of findings. Lists a 'Journal Vouchers' weakness: over 1,200 journal vouchers totaling over $175 billion not fully supported.

Source
DoD Office of Inspector General
Date
8 January 2019
Quoted from
PDF p. 3
Grade
Primary record
Document
https://media.defense.gov/2019/Jan/08/2002077454/-1/-1/1/UNDERSTANDING%2520THE%2520RESULTS%2520OF%2520THE%2520AUDIT%2520OF%2520THE%2520DOD%2520FY%25202018%2520FINANCIAL%2520STATEMENTS.PDF
Accessed
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Exhibit 276 · Inspector general report

Understanding the Results of the Audit of the DoD FY 2019 Financial Statements

In FY 2019, the DoD OIG issued a disclaimer of opinion on the Agency‑Wide Basic Financial Statements

FY2019: disclaimer; 25 agency-wide material weaknesses; of 23 reporting entities, 7 unmodified, 1 qualified, 15 disclaimers (PDF p. 22).

Source
DoD Office of Inspector General
Date
28 January 2020
Quoted from
PDF p. 17
Grade
Primary record
Document
https://media.defense.gov/2020/Jan/30/2002241083/-1/-1/1/UNDERSTANDING%20THE%20RESULTS%20OF%20THE%20AUDIT%20OF%20THE%20DOD%20FY%202019%20FINANCIAL%20STATEMENTS.PDF
Accessed
2026-11-09
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Note
Further quotation: “On November 15, 2019, the DoD OIG issued a disclaimer of opinion on the FY 2019 Agency‑Wide Basic Financial Statements” (PDF p. 17 (the FY 2019 Agency-Wide Audit Results panel)).

Exhibit 277 · Inspector general report

Understanding the Results of the Audit of the DoD FY 2020 Financial Statements

In FY 2020, the DoD OIG issued a disclaimer of opinion on the Agency–Wide Basic Financial Statements

FY2020: disclaimer; 26 agency-wide material weaknesses; of 24 reporting entities, 9 unmodified, 1 qualified, 14 disclaimers (PDF p. 24).

Source
DoD Office of Inspector General
Date
23 February 2021
Quoted from
PDF p. 20
Grade
Primary record
Document
https://media.defense.gov/2021/Feb/25/2002588406/-1/-1/1/UNDERSTANDING%20RESULTS%20OF%20AUDIT%20OF%20FY%202020%20FINANCIAL%20STATEMENTS.PDF
Accessed
2026-11-09
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Note
Further quotation: “On November 16, 2020, the DoD OIG issued a disclaimer of opinion on the FY 2020 Agency–Wide” (PDF p. 20 (the FY 2020 Agency-Wide Audit Results panel; the sentence continues 'Basic Financial Statements' in a second text column)).

Exhibit 278 · Inspector general report

Understanding the Results of the Audit of the FY 2021 DoD Financial Statements

Ernst & Young determined that although the Navy’s Inventory records showed eight guided missile fin assemblies at the contractor’s site, a physical count revealed only two at the site.

FY2021: disclaimer issued 15 November 2021; 28 material weaknesses and 4 significant deficiencies; of 26 reporting entities with stand-alone audits, 8 clean, 1 qualified, 17 disclaimers (PDF p. 38). Inventory section reports a physical count at a Navy contractor site found 2 of 8 recorded guided missile fin assemblies.

Source
DoD Office of Inspector General
Date
18 May 2022
Quoted from
PDF p. 28 (Inventory and Related Property)
Grade
Primary record
Document
https://media.defense.gov/2022/Jun/01/2003009509/-1/-1/1/UNDERSTANDING%20THE%20RESULTS%20OF%20THE%20FY%202021%20AUDIT_FINAL.PDF
Accessed
2026-11-09
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Note
Further quotation: “On November 15, 2021, the DoD OIG issued a disclaimer of opinion on the FY 2021 Agency-Wide Financial” (The FY 2021 Agency-Wide Audit Results panel (page marked 12 in the text layer; the sentence continues 'Statements' in the next text column)).

Exhibit 279 · Inspector general report

Understanding the Results of the Audit of the FY 2022 DoD Financial Statements (DODIG-2023-070)

received 9 unmodified (clean) opinions, 1 qualified opinion, and 16 disclaimers of opinions.

FY2022: disclaimer; 28 agency-wide material weaknesses and 3 significant deficiencies; final entity count 9 clean, 1 qualified, 16 disclaimers.

Source
DoD Office of Inspector General
Date
16 May 2023
Quoted from
PDF p. 20
Grade
Primary record
Document
https://media.defense.gov/2023/May/17/2003224388/-1/-1/1/DODIG-2023-070.PDF
Accessed
2026-11-09
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Exhibit 280 · Press release

Press release: Independent Auditor's Report on the DoD FY 2022 and FY 2021 Basic Financial Statements

issued a disclaimer of opinion—meaning that the auditors could not obtain sufficient, appropriate audit evidence to support an opinion.

Announces the FY2022 disclaimer, 28 material weaknesses, 3 significant deficiencies and 7 instances of noncompliance. Preliminary entity count: 6 clean, 1 qualified, 16 disclaimers, 2 audits ongoing (later final: 9 clean).

Source
DoD Office of Inspector General
Date
16 November 2022
Quoted from
PDF p. 1
Grade
Primary record
Document
https://www.dodig.mil/Portals/48/Press%20Release%20on%20the%20Audit%20of%20the%20DoD%20FY%202022%20and%20FY%202021%20Basic%20Financial%20Statements.pdf
Accessed
2026-11-09
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Exhibit 281 · Inspector general report

Understanding the Results of the Audit of the FY 2023 DoD Financial Statements (DODIG-2024-114)

On November 15, 2023, the DoD OIG issued a disclaimer of opinion on the FY 2023 DoD Agency‑Wide Financial Statements.

FY2023: disclaimer issued 15 November 2023; 28 material weaknesses, 3 significant deficiencies; 10 clean, 1 qualified, 18 disclaimers; Marine Corps first clean opinion.

Source
DoD Office of Inspector General
Date
8 August 2024
Quoted from
PDF p. 22
Grade
Primary record
Document
https://media.defense.gov/2024/Aug/12/2003521744/-1/-1/1/DODIG-2024-114.PDF
Accessed
2026-11-09
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Exhibit 282 · Inspector general report

Part 1. Understanding the Results of the Audit of the FY 2024 DoD Financial Statements (DODIG-2025-074)

comparing the number of material weaknesses from year to year is not a reliable way to measure progress towards a clean financial statement opinion.

FY2024: seventh consecutive disclaimer; 28 agency-wide material weaknesses (20, 25, 26, 28, 28, 28, 28 for FY2018-2024); 11 clean, 1 qualified, 12 disclaimers; 151 material weaknesses and 2,848 NFRs across components.

Source
DoD Office of Inspector General
Date
28 February 2025
Quoted from
PDF p. 25 (printed p. 21)
Grade
Primary record
Document
https://www.oversight.gov/sites/default/files/documents/reports/2025-03/DODIG-2025-074_SECURE.pdf
Accessed
2026-11-09
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Exhibit 283 · Inspector general report

The FY 2025 DoW Financial Statement Audit Explained (DOWIG-2026-081)

The audit identified 26 material weaknesses, representing significant deficiencies that increase the risk of undetected errors.

FY2025: disclaimer issued 18 December 2025; 26 agency-wide material weaknesses; of 22 stand-alone entities, 21 got opinions (11 clean, 1 qualified, 9 disclaimers); 121 entity-level weaknesses (21 fewer); 2,485 NFRs (427 fewer); 297 financial systems; unsupported accounting adjustments over $859 billion in last two quarters; plans substantive testing of physical assets in FY2026; 929 NFRs have no remediation date. Defines unsupported accounting adjustments (PDF p. 21): 'Changes made to accounting records without the proper documentation to show why the change was needed or correct.' The DoW's adjustments totaled more than $859 billion in the last two quarters of FY2025.

Source
Department of War (DoD) Office of Inspector General
Date
11 May 2026
Quoted from
PDF p. 3 (printed p. i)
Grade
Primary record
Document
https://www.oversight.gov/sites/default/files/documents/reports/2026-05/DOWIG2-2026-081%20SECURE.pdf
Accessed
2026-11-09
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Exhibit 284 · Inspector general report

Army General Fund Adjustments Not Adequately Documented or Supported (DODIG-2016-113)

Amounts are not cumulative and should not be added together.

Found that the Army and DFAS Indianapolis did not adequately support $2.8 trillion in third-quarter and $6.5 trillion in year-end journal voucher adjustments to FY2015 Army General Fund data. DFAS's own count: 138,887 of 142,355 year-end adjustments unsupported ($4.44 trillion), and the IG found 170 of 194 sampled 'supported' adjustments ($2.1 trillion) were in fact unsupported. 137,618 unsupported adjustments, $4 trillion, were system-generated. Footnote 2: amounts are not cumulative. The DFAS Director said the values were a misrepresentation because 22 adjustments totaling $1.4 trillion were counted in both periods; the IG disagreed (PDF p. 21-22). Example effect: net unsupported adjustment of $99.8 billion to a $0.2 billion intragovernmental receivable balance.

Source
DoD Office of Inspector General
Date
26 July 2016
Quoted from
PDF p. 3 (footnote 2) and p. 4
Grade
Primary record
Document
https://media.defense.gov/2016/Jul/26/2001714261/-1/-1/1/DODIG-2016-113.pdf
Accessed
2026-11-09
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Exhibit 285 · Hearing transcript

Department of Defense Update on the Financial Improvement and Audit Remediation Plan, H.A.S.C. No. 115-64

It is not the same thing as not being able to account for money that Congress has given you to spend, but it is still a problem that needs to be fixed.

Rep. Walter Jones asked about the IG's report that the Army made $2.8 and $6.5 trillion in adjustments. Under Secretary (Comptroller) David Norquist answered that journal vouchers occur after money is spent, that entries are written from the property book into the general ledger, and that an entry without adequate support is wholly 'unsupported'.

Source
House Committee on Armed Services
Date
10 January 2018
Quoted from
Norquist reply to Mr. Jones, govinfo HTML text (printed page not yet recorded)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/CHRG-115hhrg28967/html/CHRG-115hhrg28967.htm
Accessed
2026-11-09
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Exhibit 286 · GAO report

High-Risk Series: Heightened Attention Could Save Billions More and Improve Government Efficiency and Effectiveness (GAO-25-107743)

it has not yet received an audit opinion on its annual department-wide financial statements because it has been unable to accurately account for and report on its spending or physical assets.

DOD financial management section: hampered by ineffective processes, aging systems, inadequate controls, incomplete corrective action plans; fraud risk management added in 2025; DoD needs better accountability for global spare parts for the Joint Strike Fighter and must address the Government Furnished Property weakness.

Source
U.S. Government Accountability Office
Date
25 February 2025
Quoted from
Report PDF p. 178 (GAO printed p. 165)
Grade
Primary record
Document
https://www.gao.gov/products/gao-25-107743
Accessed
2026-11-09
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Exhibit 287 · GAO testimony

DOD Financial Management: Questions Associated with New Financial Audit Approach (GAO-26-109115)

DOD would be deprioritizing remediating key internal control deficiencies for two or more years.

Testimony before the House Oversight Government Operations Subcommittee. DoD is the only one of 24 CFO Act agencies never to obtain a clean opinion; on High-Risk List since 1995; FY2018 had 24 stand-alone audits (16 disclaimers, 6 clean, 2 qualified); FY2025 26 material weaknesses; 17 scope-limiting weaknesses of which one resolved; revised approach would deprioritize control remediation for two or more years; NDAA FY2010 and FY2018 history in footnotes.

Source
U.S. Government Accountability Office
Date
13 May 2026
Quoted from
PDF p. 22
Grade
Primary record
Document
https://files.gao.gov/assets/gao-26-109115.pdf
Accessed
2026-11-09
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Exhibit 288 · GAO report

DOD Financial Management: Insights into the Auditability of DOD's Fiscal Year 2024 Balance Sheet (GAO-25-108052)

nearly all of DOD’s total reported assets attributable to components with clean opinions related to the Military Retirement Fund.

Eleven components with clean opinions held 42.8 percent of reported assets, nearly all of it the Military Retirement Fund; disclaimers relate to Army, Navy and Air Force.

Source
U.S. Government Accountability Office
Date
September 2025
Quoted from
PDF p. 2
Grade
Primary record
Document
https://www.gao.gov/assets/gao-25-108052.pdf
Accessed
2026-11-09
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Exhibit 289 · GAO snapshot

DOD Financial Management: FY 2023 Financial Statement Audit Progress and Challenges (GAO-24-107478)

18 of 29 components received disclaimers

FY2023: 18 of 29 components disclaimers, 10 clean; FY2022 9 clean, 1 qualified, 16 disclaimers; DoD officials said remediation rate fell because it first addressed less-complex issues; audits identified assets it did not know existed (Navy added nearly $2.4 billion in FY2020).

Source
U.S. Government Accountability Office
Date
July 2024
Quoted from
PDF p. 1
Grade
Primary record
Document
https://www.gao.gov/products/gao-24-107478
Accessed
2026-11-09
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Exhibit 290 · GAO report

DOD Financial Management: Air Force Needs to Properly Account for All General Equipment That Contractors Hold (GAO-26-107442)

GAO could not locate 18 of the 96 sampled items at the Reliance Test & Technology facility at Eglin Air Force Base in Valparaiso, Florida.

At the Eglin facility GAO could not locate 14 of 58 items in a generalizable sample (about 24 percent); at Standard Aero 58 of 104 sampled. GAO also verified all 187 pod records at a Raytheon facility and all sample items in the Defense Property Accountability System. Air Force partially concurred with one recommendation and concurred with the other.

Source
U.S. Government Accountability Office
Date
February 2026
Quoted from
Highlights, PDF p. 2
Grade
Primary record
Document
https://www.gao.gov/assets/gao-26-107442.pdf
Accessed
2026-11-09
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Note
Highlights give 18 of 96; the body reports 14 of 58 for the generalizable sample; the writer must state which sample.

Exhibit 291 · Inspector general report

Management Advisory: DoD's Ability to Financially Report Joint Strike Fighter Inventory (DODIG-2023-096)

Our test determined that 41 (19 percent) of the 217 part numbers we reviewed had at least one existence or completeness error.

The F-35 program office lacked a valid population of JSF inventory; DoD reported no JSF inventory values in FY2022 statements.

Source
DoD Office of Inspector General
Date
21 July 2023
Quoted from
PDF p. 3
Grade
Primary record
Document
https://www.oversight.gov/sites/default/files/oig-reports/DoD/DODIG-2023-096.pdf
Accessed
2026-11-09
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Exhibit 292 · CRS In Focus

Defense Primer: FY2025 Department of Defense Audit Results (IF12627)

DOD received a disclaimer of opinion for the eighth time

Summarizes CFO Act requirement, GAO high-risk status since 1995, FY2025 disclaimer, entity counts (26 entity-level audits; disclaimers account for 43% of assets and at least 64% of budgetary resources), NDAA FY2024 secs. 920, 1004, 1005, FY2025 sec. 1007, FY2026 sec. 1002, and DoD-reported benefits ($4.3 billion in untracked Navy equipment).

Source
Congressional Research Service
Date
28 April 2026
Quoted from
PDF p. 1
Grade
Primary record
Document
https://www.everycrsreport.com/files/2026-04-28_IF12627_5d29961262bb4125bc8b14826a35079b467a53f2.pdf
Accessed
2026-11-09
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Exhibit 293 · Statute

National Defense Authorization Act for Fiscal Year 2010, Pub. L. 111-84, sec. 1003

ensuring the financial statements of the Department of Defense are validated as ready for audit by not later than September 30, 2017

Requires a Financial Improvement and Audit Readiness Plan and semiannual reports.

Source
U.S. Congress
Date
28 October 2009
Quoted from
Sec. 1003(a)(2)(A)(ii), 123 Stat. 2439-40
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-111publ84/html/PLAW-111publ84.htm
Accessed
2026-11-09
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Exhibit 294 · Statute

National Defense Authorization Act for Fiscal Year 2014, Pub. L. 113-66, sec. 1003

upon the conclusion of fiscal year 2018, the Secretary of Defense shall ensure that a full audit is performed on the financial statements of the Department of Defense for such fiscal year.

Requires a full audit of FY2018 statements, results to Congress by 31 March 2019.

Source
U.S. Congress
Date
26 December 2013
Quoted from
Sec. 1003(a), 127 Stat. 842
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-113publ66/html/PLAW-113publ66.htm
Accessed
2026-11-09
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Exhibit 295 · Statute

National Defense Authorization Act for Fiscal Year 2018, Pub. L. 115-91, sec. 1002

The Secretary of Defense shall ensure that a full audit is performed on the financial statements of the Department of Defense for each fiscal year as required by section 3521(e) of title 31.

Creates 10 U.S.C. chapter 9A and the annual audit requirement; repeals the FY2014 provision.

Source
U.S. Congress
Date
12 December 2017
Quoted from
Sec. 1002(b), 131 Stat. 1538
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-115publ91/html/PLAW-115publ91.htm
Accessed
2026-11-09
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Exhibit 296 · Statute

National Defense Authorization Act for Fiscal Year 2024, Pub. L. 118-31, secs. 920, 1004, 1005

each component of the Department of Defense shall be subject to an independent audit. Any such component that fails to be subject to such an audit during any fiscal year shall have 1.5 percent of unobligated amounts available for the component be cancelled and returned to the general fund of the Treasury for deficit reduction

Sec. 1005 requires an unqualified opinion by 31 December 2028; sec. 1004 requires each component to be independently audited in FY2024 and nine fiscal years after, on pain of cancellation of 1.5 percent of unobligated amounts (military personnel and Defense Health Program accounts excluded); sec. 920 requires audit-remediation metrics by 30 April 2025 and evaluation of using them in performance evaluations of senior officers and SES.

Source
U.S. Congress
Date
22 December 2023
Quoted from
Sec. 1004(a), 137 Stat. 379
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-118publ31/html/PLAW-118publ31.htm
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Exhibit 297 · Statute

National Defense Authorization Act for Fiscal Year 2026, Pub. L. 119-60, secs. 1002 and 1005

a ranking of all of the military departments and Defense Agencies in order of how advanced each is in achieving auditable financial statements

Sec. 1002 requires a funding estimate for corrective action plans, a ranking of components by auditability, and bottom-quartile annual reports (weaknesses, causes, plan, NFR counts). Sec. 1005 extends the component audit requirement to 2035.

Source
U.S. Congress
Date
December 2025
Quoted from
Sec. 1002(a)(2)(A)-(B), 139 Stat. 1026-27
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-119publ60/html/PLAW-119publ60.htm
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Exhibit 298 · News report

Pentagon fails (another) audit, restates 2028 goal to finally pass

the Department of War will not reach its goal of achieving a clean financial statement audit without a significant acceleration of its efforts

Reports a letter from the acting comptroller Jules Hurst that the department 'will not reach its goal' of a clean audit by 2028 'without a significant acceleration of its efforts' and a revised strategy in FY2026.

Source
Breaking Defense (Valerie Insinna)
Date
19 December 2025
Quoted from
Valerie Insinna, 19 Dec 2025, quotation from Jules Hurst's letter
Grade
Reported
Document
https://breakingdefense.com/2025/12/pentagon-fails-another-audit-restates-2028-goal-to-finally-pass/
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Exhibit 299 · Congressional report

COINTELPRO: The FBI's Covert Action Programs Against American Citizens (Church Committee, Book III)

In these programs, the Bureau went beyond the collection of intelligence to secret action designed to "disrupt" and "neutralize" target groups and individuals.

Staff study of more than 20,000 pages of FBI documents. Records five domestic programs (1956-71), 2,370 approved actions, the August 1967 and March 1968 Black Nationalist directives, and that no one outside the Bureau was informed of three of the programs.

Source
United States Senate, Select Committee to Study Governmental Operations
Date
23 April 1976
Quoted from
Book III, COINTELPRO report, Part I, p. 3 (PDF p. 7)
Grade
Primary record
Document
https://www.intelligence.senate.gov/wp-content/uploads/2024/08/sites-default-files-94755-iii.pdf
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Exhibit 300 · Agency memorandum (quoted)

FBI letter to 23 field offices, Black Nationalist-Hate Groups program, as quoted in Church Committee Book III

to expose, disrupt, misdirect, discredit, or otherwise neutralize the activities of black nationalist, hate-type organizations and groupings, their leadership, spokesmen. membership, and supporters, and to counter their propensity for violence and civil disorder.

FBI headquarters letter opening the Black Nationalist-Hate Groups COINTELPRO, as quoted by the Church Committee.

Source
Federal Bureau of Investigation (quoted by the Church Committee)
Date
25 August 1967
Quoted from
Book III, COINTELPRO report, Part II.B.5, p. 20 (PDF p. 24); quoting FBI letter of 8/25/67
Grade
Reported
Document
https://www.intelligence.senate.gov/wp-content/uploads/2024/08/sites-default-files-94755-iii.pdf
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Note
Known through the Committee's quotation.

Exhibit 301 · Congressional report

Dr. Martin Luther King, Jr., Case Study (Church Committee, Book III)

You are done. There is but one way out for you. You better take it before your filthy fraudulent self is bared to the nation.

Case study of the FBI campaign against King from December 1963 to 1968, including the November 1964 tape mailing and the draft note found in William Sullivan's office files.

Source
United States Senate, Select Committee to Study Governmental Operations
Date
23 April 1976
Quoted from
Book III, MLK Case Study, Part VI.B (PDF p. 174), quoting the FBI-supplied draft letter found in Sullivan's files; the Committee says Young stated the last paragraph matched the letter sent to SCLC
Grade
Primary record
Document
https://www.intelligence.senate.gov/wp-content/uploads/2024/08/sites-default-files-94755-iii.pdf
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Exhibit 302 · Congressional report

Intelligence Activities and the Rights of Americans (Church Committee, Book II), S. Rep. 94-755

The Committee's fundamental conclusion is that intelligence activities have undermined the constitutional rights of citizens and that they have done so primarily because checks and balances designed by the framers of the Constitution to assure accountability have not been applied.

Findings, conclusions and 96 domestic recommendations, with Separate Views of Senators Tower, Baker, Goldwater and Mathias. Includes the media manipulation findings on the FBI and the recommendation for judicial warrants.

Source
United States Senate, Select Committee to Study Governmental Operations
Date
26 April 1976
Quoted from
Book II, Part IV.A, p. 289 (PDF p. 302)
Grade
Primary record
Document
https://www.intelligence.senate.gov/wp-content/uploads/2024/08/sites-default-files-94755-ii.pdf
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Exhibit 303 · Congressional report

Separate Views of Senator John G. Tower, Vice Chairman (Church Committee, Book II)

I believe that the 183 separate recommendations proposing new detailed statutes and reporting procedures not only exceed the number and scope of documented abuses, but represent over-reaction.

Vice Chairman's dissent from the breadth of the recommendations.

Source
United States Senate
Date
26 April 1976
Quoted from
Book II, Separate Views of Senator Tower, p. 369 (PDF p. 378)
Grade
Primary record
Document
https://www.intelligence.senate.gov/wp-content/uploads/2024/08/sites-default-files-94755-ii.pdf
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Exhibit 304 · Congressional report

Individual Views of Senator Goldwater (Church Committee, Book II)

the clamor for statutes is premature and ill-advised.

Dissent arguing the report overreaches and prefers statute to executive order.

Source
United States Senate
Date
26 April 1976
Quoted from
Book II, Individual Views of Senator Goldwater, p. 390 (PDF p. 398)
Grade
Primary record
Document
https://www.intelligence.senate.gov/wp-content/uploads/2024/08/sites-default-files-94755-ii.pdf
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Exhibit 305 · Congressional report

Foreign and Military Intelligence (Church Committee, Book I), S. Rep. 94-755: Covert Relationships with the United States Media

Until February 1976, when it announced a new policy toward U.S. media personnel, the CIA maintained covert relationships with about 50 American journalists or employees of U.S. media organizations.

Documents about 50 CIA relationships with U.S. journalists or media employees as of February 1976, the CIA's February 1976 policy, more than a thousand books produced or subsidized before 1967, and CIA acknowledgement that propaganda 'fallout' in the United States cannot be prevented.

Source
United States Senate, Select Committee to Study Governmental Operations
Date
26 April 1976
Quoted from
Book I, Part B, Covert Relationships with the United States Media, p. 192 (PDF p. 195)
Grade
Primary record
Document
https://www.intelligence.senate.gov/wp-content/uploads/2024/08/sites-default-files-94755-i.pdf
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Exhibit 306 · Congressional Record

S. Res. 400, 94th Cong., debate and rollcall (creation of the Senate Select Committee on Intelligence)

The result was announced—yeas 72, nays 22

Congressional Record excerpt of the vote on Senate Resolution 400, 72 yeas to 22 nays.

Source
United States Senate
Date
19 May 1976
Quoted from
Congressional Record, Senate, 19 May 1976, p. 14673, col. 1 (Rollcall Vote No. 181)
Grade
Primary record
Document
https://www.senate.gov/about/resources/pdf/church-committee-sres400-ssci.pdf
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Exhibit 307 · Statute

Foreign Intelligence Surveillance Act of 1978, Pub. L. 95-511, 92 Stat. 1783

The Chief Justice of the United States shall publicly designate seven district court judges from seven of the United States judicial circuits

Authorizes court orders for foreign-intelligence electronic surveillance; Section 103 creates a seven-judge court; Section 108 requires semiannual reporting to the House and Senate intelligence committees.

Source
United States Congress
Date
25 October 1978
Quoted from
92 Stat. 1783, Sec. 103(a)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/STATUTE-92/pdf/STATUTE-92-Pg1783.pdf
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Exhibit 308 · Independent counsel report

Final Report of the Independent Counsel for Iran/Contra Matters, Vol. I

The investigations and prosecutions have shown that high-ranking Administration officials violated laws and executive orders in the Iran/contra matter.

Records the conclusions, 14 prosecutions, and the December 1992 pardons. HTML copy has no printed page numbers; locators are by section.

Source
Office of Independent Counsel Lawrence E. Walsh
Date
4 August 1993
Quoted from
Executive Summary, Overall Conclusions
Grade
Primary record
Document
https://fas.org/irp/offdocs/walsh/
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Note
HTML copy has no printed page numbers; locators are by section.

Exhibit 309 · Independent counsel report

Walsh, Summary of Prosecutions

14 persons were charged with criminal offenses. Eleven persons were convicted, but two convictions were overturned on appeal.

Per-defendant record of charges, pleas, convictions, vacatur and pardons.

Source
Office of Independent Counsel Lawrence E. Walsh
Date
4 August 1993
Quoted from
Summary of Prosecutions, opening paragraph
Grade
Primary record
Document
https://fas.org/irp/offdocs/walsh/summpros.htm
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Note
HTML copy has no printed page numbers; locators are by section.

Exhibit 310 · Independent counsel report

Walsh Final Report, Chapter 28, George Bush

The Weinberger pardon marked the first time a President ever pardoned someone in whose trial he might have been called as a witness, because the President was knowledgeable of factual events underlying the case.

Chapter on Bush's knowledge, his late-produced diary and the Weinberger pardon.

Source
Office of Independent Counsel Lawrence E. Walsh
Date
4 August 1993
Quoted from
Chapter 28, footnote 1
Grade
Primary record
Document
https://fas.org/irp/offdocs/walsh/chap_28.htm
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Note
HTML copy has no printed page numbers; locators are by section.

Exhibit 311 · Presidential proclamation

Proclamation 6518, Grant of Executive Clemency

The prosecutions of the individuals I am pardoning represent what I believe is a profoundly troubling development in the political and legal climate of our country: the criminalization of policy differences.

Pardons Abrams, Clarridge, Fiers, George, McFarlane and Weinberger.

Source
President George Bush
Date
24 December 1992
Quoted from
107 Stat. 2607, Proclamation 6518
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/STATUTE-107/pdf/STATUTE-107-Pg2606.pdf
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Exhibit 312 · Congressional report

Drugs, Law Enforcement and Foreign Policy, S. Prt. 100-165 (Kerry Committee report)

Payments to drug traffickers by the U.S. State Department of funds authorized by the Congress for humanitarian assistance to the Contras, in some cases after the traffickers had been indicted by federal law enforcement agencies on drug charges, in others while traffickers were under active investigation by these same agencies.

Subcommittee report on drug trafficking and foreign policy, including the State Department payments to four companies and the finding that Contra leaders were not found personally involved in trafficking.

Source
United States Senate, Subcommittee on Terrorism, Narcotics and International Operations
Date
1989
Quoted from
S. Prt. 100-165, p. 37
Grade
Primary record
Document
https://archive.org/download/KerryCommitteeReport/Kerry%20Committee%20Report.pdf
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Exhibit 313 · Congressional report

Kerry Committee report, table of State Department payments to four suppliers

The State Department selected four companies owned and operated by narcotics traffickers to supply humanitarian assistance to the Contras.

Table lists SETCO $185,924.25; DIACSA $41,120.90; Frigorificos de Puntarenas $261,932.00; Vortex $317,425.17; printed total $806,401.20. The four line items sum to $806,402.32 (checked against the page image).

Source
United States Senate, Subcommittee on Terrorism, Narcotics and International Operations
Date
1989
Quoted from
Kerry Committee report (Senate Foreign Relations Subcommittee on Narcotics, Terrorism, and International Operations, Dec. 1988/1989 print), Part V 'U.S. Government Funds and Companies with Drug Connections', printed p. 44 (PDF p. 52)
Grade
Primary record
Document
https://archive.org/download/KerryCommitteeReport/Kerry%20Committee%20Report.pdf
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Note
The four line items sum to $806,402.32, which is $1.12 more than the printed total of $806,401.20.

Exhibit 314 · Inspector general report

Report of Investigation: Allegations of Connections Between CIA and the Contras in Cocaine Trafficking to the United States, Vol. I, The California Story (96-0143-IG)

A CIA cable indicates that approximately $36,000 seized from Zavala at the time of his arrest was returned to Zavala--based on the claim they were Contra funds--by the prosecutors at CIA's request.

Overview of Volume I; team of 17 reviewed 250,000 pages and conducted over 365 interviews; found no CIA relationship with Ross, Blandon or Meneses, and that $36,000 seized from Zavala was returned at CIA's request per a CIA cable while prosecutors gave other reasons.

Source
CIA Office of Inspector General
Date
29 January 1998
Quoted from
Vol. I Overview, Conclusions
Grade
Primary record
Document
https://irp.fas.org/cia/product/cocaine/overview.html
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Exhibit 315 · Inspector general report

Report of Investigation, Vol. II, The Contra Story (98-0001-IG, unclassified 8 Oct 1998)

No information has been found to indicate that CIA as an organization or its employees conspired with, or assisted, Contra-related organizations or individuals in drug trafficking to raise funds for the Contras or for any other purpose.

Executive Summary and Conclusions. Volume II reviews CIA records on hundreds of Contra organizations and individuals and finds several dozen Contra-related individuals and one Contra organization (the ADREN '15th of September' group) subject to drug-trafficking allegations or information. It finds no information that CIA or its employees conspired with or assisted Contra-related drug trafficking to raise funds, and also finds that CIA acted inconsistently when it received such allegations, did not inform Congress of eight of ten Contra-related individuals during the period of the FY 1987 statutory prohibition, and had no published regulations on contacts with suspected traffickers outside counternarcotics operations. States that the investigation was not intended to prove or disprove the allegations.

Source
CIA Office of Inspector General
Date
8 October 1998
Quoted from
Vol. II, Executive Summary and Conclusions, Key Findings
Grade
Primary record
Document
https://irp.fas.org/cia/product/cocaine2/intro.html
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Introduction: 'The investigation on which Volume II is based was not intended to prove or disprove the allegations or information received by the Agency concerning possible drug trafficking by specific individuals or organizations.' The report also states: 'No information has been found to indicate that the non-inclusion of narcotics violations by assets in the crimes reporting requirements of the 1982 DoJ-CIA MOU was intended to protect Contra activities.' The 'acted inconsistently' finding is carried by exhibit cia-oig-1998-vol2-handling. FAS copy; the original CIA reading room copy should replace it.

Exhibit 316 · Inspector general report

CIA OIG Vol. II, conclusion on handling of allegations

CIA acted inconsistently in handling allegations or information indicating that Contra-related organizations and individuals were involved in drug trafficking.

Finds CIA acted inconsistently; did not inform Congress of 8 of 10 Contra-related individuals during the FY1987 prohibition; 11 individuals not reported to law enforcement.

Source
CIA Office of Inspector General
Date
8 October 1998
Quoted from
Vol. II, Conclusions, CIA Policies and Practices
Grade
Primary record
Document
https://irp.fas.org/cia/product/cocaine2/intro.html
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Exhibit 317 · Congressional testimony

Statement of Frederick P. Hitz, Inspector General, CIA, before HPSCI

There are instances where CIA did not, in an expeditious or consistent fashion, cut off relationships with individuals supporting the Contra program who were alleged to have engaged in drug trafficking activity or take action to resolve the allegations.

Statement on Volume I; notes six former employees and a former DEA agent declined interviews; previews Volume II.

Source
CIA Office of Inspector General
Date
16 March 1998
Quoted from
Statement, concluding section (Volume II preview)
Grade
Primary record
Document
https://fas.org/irp/congress/1998_hr/980316-ps.htm
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Exhibit 318 · Congressional report

The BCCI Affair, S. Prt. 102-140 (Kerry and Brown)

Justice Department personnel in Washington, Miami and Tampa obstructed and impeded attempts by New York District Attorney Robert Morgenthau to obtain critical information concerning BCCI in 1989, 1990, and 1991, and in one case, a federal prosecutor lied to Morgenthau's office concerning the existence of such material.

Executive Summary, Findings 4 and 7 on Justice Department handling and the CIA.

Source
United States Senate, Committee on Foreign Relations
Date
December 1992
Quoted from
Executive Summary, Finding 4
Grade
Primary record
Document
https://fas.org/irp/congress/1992_rpt/bcci/
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Exhibit 319 · Congressional report

The BCCI Affair, Finding 7 (CIA)

After the CIA knew that BCCI was as an institution a fundamentally corrupt criminal enterprise, it continued to use both BCCI and First American, BCCI's secretly held U.S. subsidiary, for CIA operations.

CIA knowledge of BCCI by early 1985 and continued use of BCCI and First American.

Source
United States Senate, Committee on Foreign Relations
Date
December 1992
Quoted from
Executive Summary, Finding 7
Grade
Primary record
Document
https://fas.org/irp/congress/1992_rpt/bcci/01exec.htm
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Exhibit 320 · Congressional report

Joint Inquiry report, Part Four: Finding, Discussion and Narrative Regarding Certain Sensitive National Security Matters (declassified in part 15 July 2016)

It should be clear that this Joint Inquiry has made no final determinations as to the reliability or sufficiency of the information regarding these issues that we found contained in FBI and CIA documents.

Part Four of the Joint Inquiry report, pages 415-443; finding 20 is on its opening page. Committee-hosted scan of the declassified text. Part Four states that the Inquiry 'has made no final determinations' on the reliability or sufficiency of the FBI and CIA information it found, and presents the Saudi-linked connections, including one sentence from a redacted source dated 2 July 2002 that uses the words 'incontrovertible evidence', alongside 'legitimate, and innocent, explanations'.

Source
U.S. Senate Select Committee on Intelligence and House Permanent Select Committee on Intelligence
Date
December 2002 (declassified 15 July 2016)
Quoted from
Joint Inquiry report, Part Four, printed p. 421, first full paragraph (34-page scan; checked against the page image)
Grade
Reported
Document
https://intelligence.house.gov/uploadedfiles/declasspart4.pdf
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2026-11-09
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The 15 July 2016 declassification date is not in the document; it comes from the ODNI statement (odni-2016-part4-statement).

Exhibit 321 · Commission report

The 9/11 Commission Report

we have found no evidence that the Saudi government as an institution or senior Saudi officials individually funded the organization.

Chapter 5 on funding and chapter 7 on Bayoumi.

Source
National Commission on Terrorist Attacks Upon the United States
Date
22 July 2004
Quoted from
9/11 Commission Report, p. 171
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/GPO-911REPORT/pdf/GPO-911REPORT.pdf
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Further quotation: “We believe the 9/11 attacks revealed four kinds of failures: in imagination, policy, capabilities, and management.” (Chapter 11, Foresight—and Hindsight, opening section, printed p. 339 (PDF p. 357)). Further quotation: “The current position of Director of Central Intelligence should be replaced by a National Intelligence Director with two main areas of responsibility” (Chapter 13, How To Do It?, recommendation, printed p. 411 (PDF p. 429)). The sentence continues '(1) to oversee national intelligence centers on specific subjects of interest across the U.S. government and (2) to manage the national intelligence program and oversee the agencies that contribute to it.'

Exhibit 322 · Agency statement

ODNI statement on declassification of Part Four of the 2002 Joint Inquiry report

The decision to authorize the release of this information is not an endorsement of, or concurrence in, its accuracy or reliability.

The ODNI original on dni.gov should replace it. States Part Four was withheld in full in 2002, that the Executive Branch released portions in 2016 with redactions, and that release is not an endorsement of accuracy; cites the 9/11 Commission and the 2013-directed FBI 9/11 Review Commission.

Source
Office of the Director of National Intelligence
Date
15 July 2016
Quoted from
ODNI statement, 15 July 2016, paragraph 1 (as reprinted)
Grade
Reported
Document
https://intelligencecommunitynews.com/odni-issues-statement-on-declassification-of-part-four-of-hpsci-and-sscis-2002-joint-inquiry-report/
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2026-11-09
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Known through a trade-news reprint.

Exhibit 323 · Intelligence community assessment

Executive Summary, joint FBI-CIA report on the nature and extent of Saudi Government support for terrorism (cover letters 1 September 2005; declassified 15 July 2016)

There is no evidence that either the Saudi Government or members of the Saudi royal family knowingly provided support for the attacks of 11 September 2001

Executive summary released by ODNI in 2016. Finds no evidence the Saudi government or royal family knowingly supported the attacks, evidence that official Saudi entities and associated NGOs funded individuals tied to terrorism, and no information that al-Bayoumi or Basnan wittingly supported the hijackers.

Source
FBI and CIA
Date
1 September 2005
Quoted from
Executive Summary, first bullet (OCR of scan; recheck against official copy)
Grade
Reported
Document
https://documents.theblackvault.com/documents/terrorism/Executive_Summary_of_Joint_FBI-CIA_Report_on_Extent_of_Saudi_Government_Support_for_Terrorism.pdf
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Exhibit 324 · Declassified agency record

FBI 9/11 document release no. 1, 16-page investigative record on Saudi-linked contacts (11 September 2021)

BAYOUMI’s logistic support to HAZMI and MIDHAR included translation, travel assistance, lodging and financing.

Per the coverage, the heavily redacted record describes assistance by Omar al-Bayoumi and contacts of Fahad al-Thumairy and does not state that the Saudi government was complicit.

Source
Federal Bureau of Investigation
Date
11 September 2021
Quoted from
FBI Electronic Communication of 4 Apr. 2016 (Operation Encore), printed p. 8, first paragraph (PDF p. 9)
Grade
Reported
Document
https://vault.fbi.gov/9-11-attacks-investigation-and-related-materials/9-11-material-released-in-response-to-executive-order-14040/april-4-2016-electronic-communication-part-01-of-01/at_download/file
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Exhibit 325 · Resolution

H. Res. 658, 95th Cong. (creating the Permanent Select Committee on Intelligence)

to establish a new permanent select committee of the House, to be known as the Permanent Select Committee on Intelligence, to oversee and make continuing studies of the intelligence and intelligence-related activities and programs of the United States Govern- ment

Resolution establishing the House Permanent Select Committee on Intelligence to oversee intelligence activities; considered, amended and agreed to 14 July 1977.

Source
U.S. House of Representatives
Date
14 July 1977
Quoted from
H. Res. 658 as passed, lines 1-6 of the resolution text (OCR; line-break hyphen retained)
Grade
Primary record
Document
https://intelligence.house.gov/UploadedFiles/H.Res_658_passed_14_July_1977.pdf
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Exhibit 326 · Agency press release

Federal Court Releases $393 Million for BCCI Victims (DOJ press release #465)

The order marks the first time that the funds forfeited in 1992 are being made available to the government and the worldwide victims' fund under a plea agreement by the bank in 1991.

Reports the 1991 plea agreement by BCCI, the 1992 forfeiture order, and release of more than $393 million, $223 million to a victims' fund and $10 million to New York.

Source
U.S. Department of Justice
Date
1 September 1995
Quoted from
DOJ press release 95-465, paragraph 2
Grade
Primary record
Document
https://www.justice.gov/archive/opa/pr/Pre_96/September95/465.txt.html
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Exhibit 327 · Presidential address

Farewell Radio and Television Address to the American People

In the councils of government, we must guard against the acquisition of unwarranted influence, whether sought or unsought, by the military-industrial complex.

Eisenhower's farewell address describing a permanent armaments industry and warning against unwarranted influence by the military-industrial complex.

Source
Dwight D. Eisenhower (National Archives milestone document)
Date
17 January 1961
Quoted from
Paragraph beginning 'In the councils of government' (transcript is not paragraph-numbered)
Grade
Primary record
Document
https://www.archives.gov/milestone-documents/president-dwight-d-eisenhowers-farewell-address
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Exhibit 328 · Statute

Public Law 87-653 (76 Stat. 528)

Prior to the award of any negotiated prime contract under this title where the price is expected to exceed $100,000;

Added the requirement that contractors submit and certify cost or pricing data for negotiated prime contracts expected to exceed $100,000; later codified and renamed the Truthful Cost or Pricing Data statute.

Source
United States Congress
Date
10 September 1962
Quoted from
76 Stat. 528, new section 2306(f)(1)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/STATUTE-76/pdf/STATUTE-76-Pg528.pdf
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Exhibit 329 · Regulation

FAR 15.403-4 Requiring certified cost or pricing data

The threshold for obtaining certified cost or pricing data is $950,000 for prime contracts awarded before July 1, 2018, and $2.5 million for prime contracts awarded on or after July 1, 2018.

Sets the threshold for certified cost or pricing data.

Source
Federal Acquisition Regulatory Council (FAC 2026-01)
Date
2026-03-13
Quoted from
FAR 15.403-4(a)(1)
Grade
Primary record
Document
https://www.acquisition.gov/far/15.403-4
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Exhibit 330 · GAO report

Federal Contracting: Implementation of Changes to Cost or Pricing Data Requirements (GAO-22-105307)

During this review, DOD and NASA officials told GAO they have not formally analyzed the effects of section 811.

Section 811 of the FY2018 NDAA raised the certified cost or pricing data threshold from $750,000 to $2 million, effective 1 July 2018; DoD and NASA had not formally analyzed the effect.

Source
U.S. Government Accountability Office
Date
April 2022
Quoted from
GAO-22-105307 product page, Highlights, 'What GAO Found'
Grade
Primary record
Document
https://www.gao.gov/products/gao-22-105307
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2026-11-09
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Note
Summary of the report's findings; no wording is quoted.

Exhibit 331 · Congressional testimony

Statement of Theresa S. Hull, Deputy Inspector General, on the audit of TransDigm (DODIG-2022-043)

we determined that for these 107 spare parts, which cost the DoD $38.3 million, TransDigm earned $20.8 million in excess profit on 105 spare parts.

IG summary of its audit: 107 parts, 153 contracts, $38.3 million cost to DoD, $20.8 million excess profit above a 15 percent benchmark on 105 parts; TransDigm refused cost data on 25 of 27 requests.

Source
DoD Office of Inspector General
Date
19 January 2022
Quoted from
p. 8
Grade
Reported
Document
https://oversightdemocrats.house.gov/sites/evo-subsites/democrats-oversight.house.gov/files/Hull%20Testimony.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Testimony in a House hearing record, not the Inspector General's report.

Exhibit 332 · Hearing record

DOD Inspector General Report on Excess Profits by TransDigm Group, Inc. (Hearing, Serial No. 116-22)

In total, we determined that for these 46 parts, which cost the DOD $26.2 million, TransDigm earned $16.1 million in excess profit.

Testimony of the DoD IG on DODIG-2019-060 ($16.1 million excess profit on 46 of 47 parts) and of TransDigm's CEO and chairman.

Source
House Committee on Oversight and Reform
Date
15 May 2019
Quoted from
Statement of Theresa S. Hull
Grade
Reported
Document
https://www.govinfo.gov/content/pkg/CHRG-116hhrg36511/html/CHRG-116hhrg36511.htm
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Testimony in a House hearing record, not the Inspector General's report. The record also carries TransDigm's testimony.

Exhibit 333 · Hearing record

Price Gouging in Military Contracts: New Inspector General Report Exposes Excess Profit Obtained by TransDigm Group (Hearing, Serial No. 117-60)

This limit does not exist in law or policy.

Includes TransDigm CEO Kevin Stein's response to the IG audit: objects to the 15 percent standard, the exclusion of taxes and interest, and the IG's treatment of commercial pricing.

Source
House Committee on Oversight and Reform
Date
19 January 2022
Quoted from
Statement of Kevin Stein, Ph.D.
Grade
Reported
Document
https://www.govinfo.gov/content/pkg/CHRG-117hhrg46681/html/CHRG-117hhrg46681.htm
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Testimony by TransDigm's chief executive, recorded in a House hearing record. It states the company's position on the Inspector General's findings and is cited as the company's response.

Exhibit 334 · Committee press release

Chairwoman Maloney and Senator Grassley call on TransDigm to repay millions

TransDigm has not repaid DOD a single dollar or indicated that it intends to do so.

Reports that TransDigm repaid the $16.1 million after the 2019 hearing and that DoD stated TransDigm had not repaid the $20.8 million.

Source
House Committee on Oversight and Reform
Date
18 April 2022
Quoted from
Paragraph 1 (quoting DoD)
Grade
Reported
Document
https://oversightdemocrats.house.gov/news/press-releases/chairwoman-maloney-and-senator-grassley-call-on-transdigm-to-repay-millions-it
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
A committee press release relaying DoD's statement and the committee's account of TransDigm's repayment.

Exhibit 335 · GAO report

Weapon Systems Annual Assessment: Requiring Mature Technologies Could Enable Shift to Rapid Delivery (GAO-26-108457)

Among the 72 MDAPs for which cost data was available, over half of the programs (46 of 72) reported cost increases totaling $122.08 billion.

24th annual assessment: portfolio of 104 programs exceeds $2.4 trillion; 46 of 72 MDAPs reported cost increases of $122.08 billion; average delivery time over 12 years.

Source
U.S. Government Accountability Office
Date
July 2026
Quoted from
p. 14
Grade
Primary record
Document
https://www.gao.gov/products/gao-26-108457
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 336 · GAO report

Weapon Systems Annual Assessment (GAO-25-107569)

Combined total cost estimates increased by $49.3 billion

Combined total cost estimates for 30 MDAPs rose $49.3 billion (8.3 percent) in a year; Sentinel accounted for over $36 billion.

Source
U.S. Government Accountability Office
Date
June 2025
Quoted from
Highlights / assessment text
Grade
Primary record
Document
https://www.gao.gov/products/gao-25-107569
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 337 · GAO report

F-35 Sustainment: Costs Continue to Rise While Planned Use and Availability Have Decreased (GAO-24-106703)

DOD estimates the F-35 program will cost over $2 trillion to buy, operate, and sustain over its lifetime.

DoD estimates over $2 trillion to buy, operate and sustain the F-35; sustainment estimate rose 44 percent from 2018 to 2023.

Source
U.S. Government Accountability Office
Date
15 April 2024
Quoted from
p. 2
Grade
Primary record
Document
https://www.gao.gov/products/gao-24-106703
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Further quotation: “The F-35 fleet’s overall availability has trended downward considerably over the past 5 years, and none of the variants are meeting availability goals” (Key Takeaways, PDF p. 2). Page 1: 'DOD operates and sustains about 630 F-35 aircraft and plans to procure about 2,500 total by the mid-2040s.' Key Takeaways also state that since 2014 GAO had made 43 recommendations and that 30 (about 70 percent) remained unimplemented. Report date 15 April 2024. Read from a Wayback capture of gao.gov/assets/gao-24-106703.pdf.

Exhibit 338 · CRS report

Defense Primer: Department of Defense Contractors (IF10600)

received 30% of departmental contract obligations

FY2024 DoD contract obligations $445 billion; five companies received 30 percent. The earlier May 2024 edition (FY2022 data) listed the same five at about $122.5 billion of $415 billion, about 30 percent.

Source
Congressional Research Service
Date
6 February 2026
Quoted from
p. 1, Contractors as Entities
Grade
Primary record
Document
https://www.congress.gov/crs_external_products/IF/PDF/IF10600/IF10600.19.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 339 · Research paper

Profits of War: Corporate Beneficiaries of the Post-9/11 Pentagon Spending Surge

Pentagon spending has totaled over $14 trillion, one-third to one-half of which went to defense contractors.

Estimates one-third to one-half of more than $14 trillion in Pentagon spending since 2001 went to contractors, derived from the DoD Green Book and CRS; five firms received one-quarter to one-third of contracts; cites $2.5 billion lobbying (Center for Responsive Politics).

Source
William D. Hartung, Costs of War Project, Watson Institute, Brown University
Date
13 September 2021
Quoted from
p. 2, Introduction
Grade
Reported
Document
https://costsofwar.watson.brown.edu/sites/default/files/papers/Profits-of-War_Hartung_Costs-of-War.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Project paper by a think-tank fellow, not peer reviewed. Footnote 2 derives the range from DoD's National Defense Budget Estimates for FY 2021 and CRS IF10600; this project did not re-derive it. The $2.5 billion lobbying figure cites the Center for Responsive Politics and was not re-derived.

Exhibit 340 · Dataset query

USAspending query: DoD contract obligations by recipient, FY2019 to FY2025

Source: USAspending.gov API (U.S. Department of the Treasury), endpoint spending_by_category/recipient, run 9 November 2026. Query: POST with awarding toptier agency Department of Defense, award type codes A to D (contracts), fiscal-year periods FY2019 to FY2025, top 400 recipients per year. The DoD total per year comes from the awarding_agency endpoint with identical filters; the FY2024 total of $492.33 billion matches the agency obligations endpoint. The project rolled recipients up to five parent companies by name pattern (Lockheed Martin including Sikorsky; RTX including Raytheon, Pratt & Whitney and Collins; Boeing; General Dynamics including Electric Boat, Bath Iron Works, NASSCO and GDLS; Northrop Grumman). Joint ventures (such as Javelin, Bell Boeing and Boeing Sikorsky) were excluded from all parents to avoid double counting, so the roll-up is approximate. Figures are net obligations by action date, including deobligations. The top-five share of DoD contract obligations was 27.4 to 36.6 percent across the seven years. The shares are the project's computation from returned rows, not figures the dataset returns directly.

Source
U.S. Department of the Treasury (USAspending.gov API)
Date
2026-11-09
Grade
Reported
Document
https://api.usaspending.gov/api/v2/search/spending_by_category/recipient/
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The CRS figure for FY2024 uses SAM.gov data and a different base; the two agree within about one point.

Exhibit 341 · Dataset query

SEC XBRL company facts for Lockheed Martin, RTX, Boeing, General Dynamics, Northrop Grumman

Source: SEC data.sec.gov XBRL company facts for Lockheed Martin (CIK 936468), RTX (101829), Boeing (12927), General Dynamics (40533) and Northrop Grumman (1133421), fetched 9 November 2026. Facts: share repurchases, dividends paid and company-funded research and development from annual 10-K filings, FY2018 to FY2025. Figures are company-wide, including commercial work. FY2021 to FY2025 totals in billions of dollars (buybacks, dividends, R&D): Lockheed Martin 24.7, 15.2, 8.3; RTX 18.5, 16.1, 14.0; Northrop Grumman 10.8, 5.6, 5.7; General Dynamics 5.6, 7.2, R&D not tagged; Boeing none tagged, 0.3, 15.9. Five-year totals are the project's arithmetic over the annual facts.

Source
U.S. Securities and Exchange Commission (data.sec.gov)
Date
2026-11-09
Grade
Primary record
Document
https://data.sec.gov/api/xbrl/companyfacts/CIK0000936468.json
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Annual values are as tagged in the filings. Boeing and General Dynamics are left out of the comparison: Boeing reported no tagged buybacks after 2019 and net losses in FY2019 to FY2024, and General Dynamics' R&D is not tagged. Other company facts URLs follow the same pattern with the CIK padded to ten digits.

Exhibit 342 · Dataset query

Lobbying Disclosure Act query: quarterly reports naming five prime contractors, 2019 to 2025

Source: Lobbying Disclosure Act database, lda.gov API (the older lda.senate.gov address showed a maintenance page), run 9 November 2026. Query: filing_year for each of 2019 to 2025 and client_name substring (Lockheed Martin; Raytheon, RTX Corp and United Technologies; Boeing; General Dynamics; Northrop Grumman); original quarterly reports Q1 to Q4 only, so amended filings are excluded and superseded figures are not corrected. Amount is the income field (outside firms) or the expenses field (in-house). Figures are company-wide, all issues, not defense-only. The five companies sum to $519.7 million over 2019 to 2025, between $68.9 million and $81.2 million a year. The sums are the project's aggregation of filings matched by name.

Source
U.S. Congress (Lobbying Disclosure Act database, lda.gov)
Date
2026-11-09
Grade
Reported
Document
https://lda.gov/api/v1/filings/
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The RTX 2019 row includes United Technologies filings. Not done: sector-wide total, issue-code subset, lobbyist counts.

Exhibit 344 · Agency study

Department of Defense Contract Finance Study Report

In 8 of 9 key financial metrics, defense contractors out-performed commercial counterparts.

Finds the defense industry financially healthy; contractors outperformed commercial counterparts on 8 of 9 financial metrics while margins are somewhat lower; reports cash paid to shareholders rose 73 percent in 2010-2019 versus 2000-2009 while the IR&D share declined.

Source
Office of the Under Secretary of Defense for Acquisition and Sustainment, Defense Pricing and Contracting
Date
April 2023
Quoted from
p. 18
Grade
Primary record
Document
https://www.acq.osd.mil/asda/dpc/pcf/docs/finance-study/FINAL%20-%20Defense%20Contract%20Finance%20Study%20Report%204.6.23.pdf
Accessed
2026-11-09
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Exhibit 345 · GAO report

Government Contracting: Assessment of the Study of Defense Contractor Profitability (GAO/NSIAD-87-50)

GAO found that the use of conventional methodology results in the conclusion that during the entire period the profitability of defense business was substantially greater than commercial business.

GAO review of DoD's DFAIR profit study; concludes by conventional methodology defense profitability was substantially greater than commercial across the period examined since 1970 and takes no position on what profits should be.

Source
U.S. General Accounting Office
Date
23 December 1986
Quoted from
Executive Summary, Results in Brief, p. 2 (OCR text)
Grade
Primary record
Document
https://www.gao.gov/assets/nsiad-87-50.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 346 · GAO report

F-35 Sustainment: Actions Needed to Ensure Updated Strategy Improves Persistent Readiness Challenges (GAO-26-108113)

sustainment costs for the United States estimated at $1.6 trillion for the life of the program to 2088, as of 2024.

U.S. F-35 sustainment costs estimated at $1.6 trillion to 2088 as of 2024; mission capable rate fell from 67 to 44 percent FY2021-FY2025; $13.7 billion more needed through FY2031.

Source
U.S. Government Accountability Office
Date
June 2026
Quoted from
Letter, p. 1
Grade
Primary record
Document
https://www.gao.gov/products/gao-26-108113
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Further quotation: “To achieve GSS Reset goals, JPO estimated in October 2025 that the U.S. military services will need to increase funding for F-35 sustainment by roughly $13.7 billion over previously planned spending from fiscal year 2026 to fiscal year 2031.” (Printed p. 13 (PDF p. 18)). Report dated June 2026. JPO is the F-35 Joint Program Office; GSS Reset is its Global Support Solution Reset. Same page: about 50 percent ($7.3 billion) for additional spare parts and material, about $3.1 billion for procurement including depot activations, about $3.3 billion for operation and maintenance. Letter, PDF p. 2: 'DOD operates and sustains over 800 U.S. F-35s and plans to buy about 1,700 more aircraft by the mid-2040s.' Read from a Wayback capture.

Exhibit 347 · Regulation

FAR 16.301-2 Use

The contracting officer shall use cost-reimbursement contracts only when- (1) Circumstances do not allow the agency to define its requirements sufficiently to allow for a fixed-price type contract (see 7.105); or (2) Uncertainties involved in contract performance do not permit costs to be estimated with sufficient accuracy to use any type of fixed-price contract.

Limits cost-reimbursement contracts to cases where requirements cannot be defined well enough for a fixed-price contract or where costs cannot be estimated accurately enough to use one.

Source
Federal Acquisition Regulatory Council
Date
Current text, accessed 9 November 2026
Quoted from
FAR 16.301-2(a)
Grade
Primary record
Document
https://www.acquisition.gov/far/16.301-2
Accessed
2026-11-09
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Exhibit 348 · Regulation

FAR 16.405-1 Cost-plus-incentive-fee contracts

A cost-plus-incentive-fee contract is appropriate for services or development and test programs when-

Describes when a cost-plus-incentive-fee contract is appropriate, including development and test programs where a cost-reimbursement contract is necessary.

Source
Federal Acquisition Regulatory Council
Date
Current text, accessed 9 November 2026
Quoted from
FAR 16.405-1(b)(1)
Grade
Primary record
Document
https://www.acquisition.gov/far/16.405-1
Accessed
2026-11-09
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Exhibit 349 · Statute

Restrictions on former officers, employees, and elected officials, 18 U.S.C. § 207

within 1 year after the termination of his or her service or employment as such officer or employee, knowingly makes, with the intent to influence, any communication to or appearance before any officer or employee of the department or agency in which such person served within 1 year before such termination

Permanent bar on representation in matters handled personally and substantially; two-year bar on matters under official responsibility; one-year bar for senior personnel on contacts with their former agency; two-year bar for very senior personnel; two-year (Senators) and one-year (House Members) bars on lobbying Congress. Does not bar employment or behind-the-scenes work.

Source
United States Congress
Date
Current text
Quoted from
18 U.S.C. § 207(c)(1)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/18/207
Accessed
2026-11-09
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Findings citing this exhibit

Exhibit 350 · Statute

Prohibition on former official's acceptance of compensation from contractor, 41 U.S.C. § 2104 (with § 2103 employment-contact reporting)

A former official of a Federal agency may not accept compensation from a contractor as an employee, officer, director, or consultant of the contractor within one year after the official

Bars certain contracting officials from taking compensation from the contractor for one year on contracts over $10 million; permits pay from a division that does not produce the same or similar products. Section 2103 requires an official who is contacted by an offeror about non-Federal employment to report it in writing.

Source
United States Congress
Date
Pub. L. 111-350 (2011), from 1988-1996 enactments
Quoted from
41 U.S.C. § 2104(a)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/41/2104
Accessed
2026-11-09
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Exhibit 351 · Statute

National Defense Authorization Act for Fiscal Year 2008, sec. 847 (ethics opinions for senior DoD officials seeking contractor employment)

A Department of Defense contractor may not knowingly provide compensation to a former Department of Defense official described in subsection (c) within two years after such former official leaves service in the Department of Defense

Covered officials must request a written ethics opinion before accepting contractor compensation within two years of leaving; contractors may not knowingly pay them without checking; DoD must keep the opinions in a central database for at least five years; DoD IG must review.

Source
United States Congress
Date
28 January 2008
Quoted from
Pub. L. 110-181, sec. 847(a)(4), 122 Stat. 243
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-110publ181/html/PLAW-110publ181.htm
Accessed
2026-11-09
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Exhibit 352 · Statute

National Defense Authorization Act for Fiscal Year 2018, sec. 1045 (lobbying prohibition for former senior DoD personnel)

An individual described in paragraph (2) may not engage in lobbying activities with respect to the Department of Defense during the two-year period beginning on the date of retirement or separation from service in the Armed Forces or the date of retirement or separation from service with the Department, as applicable.

Two-year bar on lobbying activities with respect to DoD for officers O-9 and above and civilian equivalents; one-year bar for O-7 and O-8. Defines terms by reference to the Lobbying Disclosure Act.

Source
United States Congress
Date
12 December 2017
Quoted from
Pub. L. 115-91, sec. 1045(a)(1), 131 Stat. 1555
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-115publ91/html/PLAW-115publ91.htm
Accessed
2026-11-09
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Exhibit 353 · Government report

Defense Contracting: Post-Government Employment of Former DOD Officials Needs Greater Transparency (GAO-08-485)

contractor data provided to us showed they employed 1,263 individuals in 2006 who matched our criteria as former DOD senior and acquisition officials, while our analysis of IRS data showed the contractors employed 2,435 former DOD senior and acquisition officials in 2006, or almost twice as many

In 2006, 52 contractors employed 2,435 former DoD senior and acquisition officials; seven employed 1,581. Contractors reported 1,263. Sample extrapolation: at least 422 could have worked on contracts under their former agency's responsibility and at least nine on the same contracts they oversaw. GAO says it found no violations. DoD concurred with the recommendation.

Source
U.S. Government Accountability Office
Date
21 May 2008
Quoted from
GAO-08-485, Results in Brief, p. 5
Grade
Primary record
Document
https://www.gao.gov/products/gao-08-485
Accessed
2026-11-09
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Exhibit 354 · Government report

Post-Government Employment Restrictions: DOD Could Further Enhance Its Compliance Efforts Related to Former Employees Working for Defense Contractors (GAO-21-104311)

the 10 contractors that provided personnel data reported they employed 816 potentially covered former DOD officials in 2019, while our analysis of DOD and IRS data for those contractors identified 1,149 individuals. We were unable to reconcile the differences

14 contractors employed 1,718 former senior and acquisition officials in 2019 (1,616 acquisition, 102 senior). Contractors that supplied data reported 816 against GAO's 1,149. DoD had not considered adding the lobbying ban to its acquisition regulation; DoD concurred with the recommendation.

Source
U.S. Government Accountability Office
Date
9 September 2021
Quoted from
GAO-21-104311, p. 15
Grade
Primary record
Document
https://www.gao.gov/products/gao-21-104311
Accessed
2026-11-09
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Exhibit 355 · Inspector general evaluation

Section 847 Ethics Requirements for Senior Defense Officials Seeking Employment with Defense Contractors (DODIG-2014-050)

As a result, we concluded that AGEAR was of marginal value as a management control system, and that DoD may not have fully complied with the intent of the law.

DoD did not retain all required sec. 847 records in AGEAR; more than 80 percent of the 379 recorded activities came from Army, Navy and OSD.

Source
DoD Office of Inspector General
Date
31 March 2014
Quoted from
DODIG-2014-050, p. 13
Grade
Primary record
Document
https://media.defense.gov/2014/Mar/31/2001713351/-1/-1/1/DODIG-2014-050.pdf
Accessed
2026-11-09
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Exhibit 356 · Inspector general evaluation

Report of Investigation: Mr. Patrick M. Shanahan, Acting Secretary of Defense (DODIG-2019-082)

We did not substantiate any of the allegations. We determined that Mr. Shanahan fully complied with his ethics agreements and his ethical obligations regarding Boeing and its competitors.

Investigation of allegations that Shanahan promoted Boeing. Interviewed Shanahan and 33 witnesses under oath. Records Shanahan's Boeing career (March 1986 to June 2017), his 7 June 2017 recusal letter and the screening arrangement. Did not substantiate any allegation.

Source
DoD Office of Inspector General
Date
25 April 2019
Quoted from
DODIG-2019-082, p. 5
Grade
Primary record
Document
https://media.defense.gov/2019/Apr/25/2002120583/-1/-1/1/DODIG-2019-082.PDF
Accessed
2026-11-09
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Exhibit 357 · Oversight report

Brass Parachutes: Defense Contractors' Capture of Pentagon Officials Through the Revolving Door

There were 645 instances of the top 20 defense contractors in fiscal year 2016 hiring former senior government officials, military officers, Members of Congress, and senior legislative staff as lobbyists, board members, or senior executives in 2018

645 instances of top-20 FY2016 contractors employing former senior officials, officers, Members of Congress and senior staff (562 lobbyists, 41 executives, 42 directors); at least 380 high-ranking DoD officials and officers; 95 at the top five contractors. Built from public sources and FOIA. Table sums re-derived; underlying lobbying filings not.

Source
Project On Government Oversight
Date
5 November 2018
Quoted from
Major Findings, p. 9
Grade
Reported
Document
https://docs.pogo.org/report/2018/POGO_Brass_Parachutes_DoD_Revolving_Door_Report_2018-11-05.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The 645 figure is POGO's, published 5 November 2018. The report counts each person once per company, states that the vast majority of the individuals identified did not violate any law or regulation, and thanks the Charles Koch Foundation and Philip A. Straus Jr.

Exhibit 358 · Oversight report

Pentagon Alchemy: How Defense Officials Pass Through the Revolving Door and Peddle Brass for Gold

This analysis identified 672 cases in 2022 in which the top 20 defense contractors had former government officials, military officers, Members of Congress, and senior legislative staff working for them as lobbyists, board members, or senior executives.

672 cases in 2022 at the top 20 contractors (613 lobbyists, 25 executives, 34 directors); 91 percent registered lobbyists. The staff list is described in the report as non-exhaustive. The table includes COVID-era DoD contractors such as Pfizer and Moderna.

Source
Senator Elizabeth Warren (staff report)
Date
April 2023
Quoted from
Section III.A, pp. 2-3
Grade
Reported
Document
https://www.warren.senate.gov/imo/media/doc/DoD%20Revolving%20Door%20Report.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
This is Senator Warren's own report; the 645 figure belongs to POGO (Exhibit for 5 November 2018), and no Warren report of 2018 was located. In Table 1 the Pfizer row prints a total of 73 although its parts (71 + 1 + 2) sum to 74; the printed column totals are 613, 25, 34 and 672.

Exhibit 359 · Congressional hearing transcript

Transcript: Warren questions Defense Secretary nominee Mark Esper on Raytheon recusal (SASC, 16 July 2019)

Uh, no Senator, I won't.

Warren asks Esper to extend his Raytheon recusal for his full tenure and to agree not to seek waivers. Esper declines both, citing Pentagon ethics advice and a SOCO letter saying he never sought or received a waiver.

Source
Senator Elizabeth Warren (posted transcript of Senate Armed Services Committee hearing)
Date
16 July 2019
Quoted from
Transcript, Warren-Esper exchange
Grade
Reported
Document
https://www.warren.senate.gov/newsroom/press-releases/warren-questions-defense-secretary-nominee-mark-espers-refusal-to-fully-recuse-himself-from-matters-involving-his-former-employer-raytheon/
Accessed
2026-11-09
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Exhibit 360 · Correspondence

Ethics agreement of Mark T. Esper, nominee for Secretary of the Army

For a period of one year after my resignation from Raytheon, I will not participate personally and substantially in any particular matter involving specific parties in which I know Raytheon is a party or represents a party

Esper resigns from Raytheon on confirmation, forfeits unvested restricted stock, divests Raytheon stock within 90 days, keeps participation in Raytheon's deferred compensation plan and recuses from matters affecting it, and recuses one year from matters in which Raytheon is a party.

Source
Mark T. Esper to DoD Alternate Designated Agency Ethics Official; posted by U.S. Office of Government Ethics
Date
26 July 2017
Quoted from
Letter p. 1
Grade
Primary record
Document
https://extapps2.oge.gov/201/Presiden.nsf/PAS+Index/26BF12099203D918852581710026F5E2/%24FILE/Esper,%20Mark%20T.%20%20finalEA.pdf
Accessed
2026-11-09
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Exhibit 361 · Correspondence

Ethics agreement of James N. Mattis, nominee for Secretary of Defense

Within 90 days of my confirmation, I will divest all of my General Dynamics stock and vested stock options.

Mattis resigns from General Dynamics on confirmation, recuses one year, forfeits unvested stock and options, divests stock and vested options within 90 days. Keeps Theranos stock with recusal while held.

Source
James N. Mattis to DoD Designated Agency Ethics Official; posted by U.S. Office of Government Ethics
Date
5 January 2017
Quoted from
Letter p. 1
Grade
Primary record
Document
https://extapps2.oge.gov/201/Presiden.nsf/PAS+Index/2EB12A932B2A7958852580A1002C7CAB/$FILE/MATTIS%20James%20%20Ethics%20Agreement.pdf
Accessed
2026-11-09
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Exhibit 362 · Correspondence

Letter from William J. Lynn III to Senator John McCain on lobbying for Raytheon

Lynn states he was a registered lobbyist for Raytheon through the first quarter of 2008 and lists six programs he lobbied Congress on; he lobbied DoD only on the Multiple Kill Vehicle. If confirmed he will not seek authorization to participate in those six programs for one year.

Source
William J. Lynn III
Date
January 2009
Grade
Primary record
Document
http://pogoarchives.org/m/gc/lynn-letter-20090130.pdf
Accessed
2026-11-09
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Findings citing this exhibit
Note
NBC News (Jan 2009) reports the six programs and the one-year recusal but dates Lynn's letter to McCain 28 January, not 30 January, so there may be two letters. The Senate Armed Services Committee nomination record would settle the date.

Exhibit 363 · Memorandum

Secretary of Defense memorandum: Ethics Obligations and Updated Screening Arrangement

For Four Years from the date of my appointment as the Secretary of Defense:

Austin states recusal periods: four years from appointment for Raytheon Technologies; two years for Booz Allen Hamilton, Austin Strategy Group, Tenet, Pine Island Capital Partners, Nucor, Guest Services, Carnegie Corporation, Auburn University, Fidelity and JPMorgan.

Source
Secretary of Defense Lloyd J. Austin III
Date
6 May 2021
Quoted from
Memorandum p. 1
Grade
Primary record
Document
https://www.esd.whs.mil/Portals/54/Documents/FOID/Proactive_disclosures/Secretary_of_Defense_Lloyd_Austin_Screening_Arrangement_(May_6_2021).pdf
Accessed
2026-11-09
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Note
The underlying ethics agreement was not opened.

Exhibit 364 · Company press release

General Lloyd J. Austin III, Former Commander of U.S. Central Command, to Join United Technologies Board of Directors (Form 8-K, Ex. 99.1)

Retired U.S. Army Gen. Lloyd J. Austin III, former commander of U.S. Central Command, today was elected to the United Technologies Corp. (NYSE: UTX) Board of Directors, effective Sept. 1, 2016.

Austin, retired from the Army in May 2016, elected to UTC's board effective 1 September 2016.

Source
United Technologies Corporation
Date
8 June 2016
Quoted from
Ex. 99.1, first paragraph
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/101829/000010182916000069/a2016-06x08exhibit991.htm
Accessed
2026-11-09
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Exhibit 365 · Agency register

Raytheon Technologies Form 8-K, Item 5.02 (resignation of director)

Following his confirmation by the U.S. Senate to serve as the United States Secretary of Defense on January 22, 2021, Lloyd J. Austin III notified Raytheon Technologies Corporation (the “Company”) that he was resigning, effective January 22, 2021, from the Company’s Board of Directors.

Reports that Austin resigned from the board effective 22 January 2021, after his Senate confirmation as Secretary of Defense.

Source
Raytheon Technologies Corporation
Date
25 January 2021
Quoted from
Item 5.02(b)
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/101829/000010182921000002/rtx-20210122.htm
Accessed
2026-11-09
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Exhibit 366 · Company press release

General Dynamics press release: elects James N. Mattis to Board of Directors (Form 8-K Ex. 99.1)

Mattis retired from the Marine Corps in May 2013.

Mattis elected a director effective 7 August 2013; the release states he retired from the Marine Corps in May 2013.

Source
General Dynamics Corporation
Date
7 August 2013
Quoted from
Ex. 99.1
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/40533/000119312513326575/d581265dex991.htm
Accessed
2026-11-09
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Exhibit 367 · Agency register

General Dynamics Form 8-K, Item 5.02 (10 January 2017)

On January 5, 2017, Mr. Mattis announced that he would resign from the company’s Board of Directors upon confirmation as Secretary of Defense.

On 5 January 2017 Mattis announced he would resign from the board upon confirmation as Secretary of Defense.

Source
General Dynamics Corporation
Date
10 January 2017
Quoted from
Item 5.02
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/40533/000119312517006634/d309868d8k.htm
Accessed
2026-11-09
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Exhibit 368 · Agency register

General Dynamics Form 8-K, Item 5.02 (7 August 2019)

On August 7, 2019, the board of directors of General Dynamics Corporation elected James N. Mattis as a member of the board of directors, effective immediately.

General Dynamics' board elected Mattis a director effective 7 August 2019, to the Audit and Nominating and Corporate Governance committees.

Source
General Dynamics Corporation
Date
7 August 2019
Quoted from
Item 5.02
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/40533/000004053319000050/gd-201908078k.htm
Accessed
2026-11-09
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Exhibit 369 · Company press release

Raytheon Company Form 8-K and press release: Robert O. Work elected to Board

Work, 64, was appointed the 31 st Deputy Secretary of Defense by President Barack Obama in 2014, a position he held through July 2017.

Work, Deputy Secretary of Defense from 2014 'through July 2017', elected a Raytheon director on 14 August 2017. Also records his CNAS chief executive role 2013 to 2014.

Source
Raytheon Company
Date
14 August 2017
Quoted from
Ex. 99.1, first paragraph
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1047122/000104712217000152/rtn-081417xexhibit991x8k.htm
Accessed
2026-11-09
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Exhibit 370 · Company press release

Raytheon Company press release: Ellen M. Pawlikowski elected to board (Form 8-K Ex. 99.1)

Pawlikowski, 61, retired as Commander, U.S. Air Force Materiel Command, Wright-Patterson Air Force Base, Ohio, on September 1, 2018.

General Pawlikowski retired as Commander of Air Force Materiel Command on 1 September 2018 and was elected a Raytheon director on 6 September 2018.

Source
Raytheon Company
Date
6 September 2018
Quoted from
Ex. 99.1
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1047122/000104712218000209/rtn-09102018exhibit991.htm
Accessed
2026-11-09
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Exhibit 371 · Research advisory report

Effects of Certain Ethics Requirements on DOD Hiring, Retention, and Operations (IDA Product 3001788)

IDA’s analysis shows that well under one percent of these retired officials are registered lobbyists for top 100 defense contractors.

Congressionally required review of sec. 1045, sec. 1117 (FY2022), 10 U.S.C. 988 and sec. 847. No measurable effect of the restrictions on recruitment and retention; sec. 1045 judged 'most problematic'; well under one percent of retired senior officials are registered lobbyists for top-100 contractors; removal of the provisions unlikely to affect arms-length contracting given other safeguards.

Source
Institute for Defense Analyses (for DoD Standards of Conduct Office)
Date
April 2024
Quoted from
Executive Summary, p. v
Grade
Primary record
Document
https://ida.org/-/media/feature/publications/e/ef/effects-of-certain-ethics-requirements-on-dod-hiring-retention-and-operations/3001788.ashx
Accessed
2026-11-09
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Note
Sponsor-commissioned: IDA is an FFRDC paid by the DoD office whose rules it reviewed.

Exhibit 372 · Institutional web page

CSIS Our Donors: Corporations (Fiscal Year 2025)

you will find a list of our supporters for Fiscal Year 2025 (October 1, 2024–September 30, 2025) who gave generous gifts of $5,000 or more

Corporate donors by band. $250,000 and up: General Atomics, General Dynamics, Lockheed Martin, Northrop Grumman. $100,000-$249,999: Boeing, Leonardo DRS, RTX, Bechtel, Sierra Nevada. $50,000-$99,999: BAE Systems, Peraton, Thales.

Source
Center for Strategic and International Studies
Date
FY2025 (1 October 2024 to 30 September 2025)
Quoted from
CSIS 'Our Donors' page, introductory paragraph (the Corporations sub-page itself carries no year label)
Grade
Primary record
Document
https://www.csis.org/about/financial-information/donors
Accessed
2026-11-09
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Note
Bands as printed on the donor page for fiscal year 2025; no amounts are published.

Exhibit 373 · Institutional web page

CNAS Supporters (contributions 1 October 2024 to 30 September 2025)

Contributions from October 1, 2024 to September 30, 2025:

Supporters by band. $500,000 and above: Northrop Grumman Systems Corporation. $100,000-$249,999: Lockheed Martin, RTX, Anduril, Leidos. $50,000-$99,999: BAE Systems, The Boeing Company. $25,000-$49,999: General Dynamics.

Source
Center for a New American Security
Date
FY2025
Quoted from
CNAS Supporters page, heading above the donor bands
Grade
Primary record
Document
https://www.cnas.org/support-cnas/cnas-supporters
Accessed
2026-11-09
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Note
Bands as printed on the supporter page for fiscal year 2025; no amounts are published.

Exhibit 374 · Research brief

Big Ideas and Big Money: Think Tank Funding in America (Quincy Brief No. 68)

Since 2019, top Pentagon contractors have contributed more than $34.7 million to the 50 U.S. think tanks included in this study. Of the think tanks that publish a donor roll, 62 percent (20 of 32) received funding from those contractors

Reports more than $34.7 million from top Pentagon contractors to 50 think tanks since 2019 and that 20 of 32 donor-publishing think tanks received contractor money. Based on the tanks' self-reported donor lists, lower ends of ranges summed.

Source
Quincy Institute for Responsible Statecraft (Ben Freeman, Nick Cleveland-Stout)
Date
3 January 2025
Quoted from
Section 'Pentagon contractor funding of think tanks'
Grade
Reported
Document
https://quincyinst.org/research/big-ideas-and-big-money-think-tank-funding-in-america
Accessed
2026-11-09
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Exhibit 375 · Peer-reviewed article

The value of the revolving door: Political appointees and the stock market

We also find positive abnormal returns for corporate appointments and positive effects of political connections on procurement volume.

Using Senate-confirmed DoD appointees across six administrations, reports positive abnormal stock returns for the firms involved. The abstract also reports positive abnormal returns for corporate appointments and positive effects of political connections on procurement volume.

Source
Simon Luechinger and Christoph Moser, Journal of Public Economics 119: 93-107
Date
2014
Quoted from
Abstract (J Public Econ 119: 93-107), via EconPapers/RePEc
Grade
Peer-reviewed
Document
https://doi.org/10.1016/j.jpubeco.2014.08.001
Accessed
2026-11-09
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Exhibit 376 · Agency historical study

Skunks, Bogies, Silent Hounds, and the Flying Fish: The Gulf of Tonkin Mystery, 2-4 August 1964

This was an active effort to make SIGINT fit the claim of what happened during the evening of 4 August in the Gulf of Tonkin.

NSA historian's SIGINT account of 2-4 August 1964. Concludes the 2 August attack on the Maddox occurred and the 4 August attack did not; that about 90 percent of relevant SIGINT was kept out of NSA summaries and the October 1964 report; that the handling was not conspiratorial; and that NSA staff believed an attack had occurred. PDF stamped 'Approved for Release by NSA on 14-03-2005, FOIA Case # 43933'. NSA's own copy URL returned Access Denied to a script; the NSA Archive copy is used.

Source
National Security Agency (Robert J. Hanyok, Cryptologic Quarterly)
Date
Winter 2000/Spring 2001; declassified 1 December 2005
Quoted from
p. 49 (printed page number; scanned PDF page 50)
Grade
Primary record
Document
https://nsarchive2.gwu.edu/NSAEBB/NSAEBB132/relea00012.pdf
Accessed
2026-11-09
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Note
Scanned image PDF; no text layer. Key limits at p. 3 ('not done in a manner that can be construed as conspiratorial') and p. 49 (pressure explanation 'cannot be supported').

Exhibit 377 · Press release / briefing book

Tonkin Gulf Intelligence 'Skewed' According to Official History and Intercepts (Electronic Briefing Book No. 132 update)

the National Security Agency, today declassified over 140 formerly top secret documents -- histories, chronologies, signals intelligence [SIGINT] reports, and oral history interviews -- on the August 1964 Gulf of Tonkin incident.

Describes the 1 Dec 2005 NSA declassification of more than 140 Tonkin documents, the April 2004 FOIA request by Matthew Aid, and NSA officials' earlier resistance to release.

Source
National Security Archive, George Washington University
Date
1 December 2005
Quoted from
para 1
Grade
Reported
Document
https://nsarchive2.gwu.edu/NSAEBB/NSAEBB132/press20051201.htm
Accessed
2026-11-09
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Findings citing this exhibit
Note
Reported: an NGO's account. Dates and counts are replaced by the NSA release stamp on the Hanyok PDF and NSA's declassified-documents index (not reached).

Exhibit 378 · News report

Vietnam Study, Casting Doubts, Remains Secret (excerpt)

fearful that it might prompt uncomfortable comparisons with the flawed intelligence used to justify the war in Iraq, according to an intelligence official familiar with some internal discussions of the matter.

Reports that NSA kept Hanyok's finding secret since 2001, that Hanyok concluded mid-level officers deliberately skewed evidence to cover earlier errors, and that higher NSA officials feared comparisons with Iraq intelligence.

Source
New York Times (Scott Shane), via History News Network
Date
31 October 2005
Quoted from
HNN excerpt of Shane, NYT, 31 Oct 2005, paragraph 3
Grade
Reported
Document
https://hnn.us/roundup/entries/17620.html
Accessed
2026-11-09
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Note
Attributes the motive to an unnamed intelligence official.

Exhibit 379 · Presidential address

Radio and Television Report to the American People Following Renewed Aggression in the Gulf of Tonkin

The initial attack on the destroyer Maddox, on August 2, was repeated today by a number of hostile vessels attacking two U.S. destroyers with torpedoes.

Johnson's 11:36 p.m. EDT address announcing that U.S. destroyers had been attacked again and that air action was under way; announces a request for a congressional resolution.

Source
Lyndon B. Johnson (President)
Date
4 August 1964
Quoted from
opening paragraph (Public Papers of the Presidents 1963-64, Book II, pp. 927-928)
Grade
Primary record
Document
https://www.presidency.ucsb.edu/documents/radio-and-television-report-the-american-people-following-renewed-aggression-the-gulf
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2026-11-09
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Exhibit 380 · Edited document compilation

Editorial Note (Gulf of Tonkin, 4 August 1964)

a review of the action makes many reported contacts and torpedoes fired 'appear doubtful'.

Editorial note quoting the 28 August 1964 chronology: the Maddox's report that reported contacts appeared doubtful, and the 4:47 p.m. meeting of McNamara, Vance and the JCS that concluded an attack had occurred on the basis of five listed factors.

Source
U.S. Department of State, Office of the Historian, Foreign Relations of the United States 1964-1968, Vol. I, Vietnam 1964, Doc. 276
Date
4 August 1964 events; published FRUS
Quoted from
FRUS 1964-68 vol. I, Doc. 276, p. 609
Grade
Primary record
Document
https://history.state.gov/historicaldocuments/frus1964-68v01/d276
Accessed
2026-11-09
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Note
The Maddox words are the editors' quotation of the 28 Aug 1964 chronology (message 041727Z); pages 608-610.

Exhibit 381 · Joint resolution

Joint Resolution to promote the maintenance of international peace and security in southeast Asia (Tonkin Gulf Resolution, H.J. Res. 1145, Public Law 88-408)

the Congress approves and supports the determination of the President, as Commander in Chief, to take all necessary measures to repel any armed attack against the forces of the United States and to prevent further aggression.

Text of the resolution approving the President's determination to take all necessary measures to repel armed attack, with Section 2 on use of armed force to assist Southeast Asia Collective Defense Treaty states. The Senate passed it with two dissenting votes (Hanyok p. 46-47).

Source
U.S. Congress
Date
7 August 1964
Quoted from
Section 1
Grade
Primary record
Document
https://avalon.law.yale.edu/20th_century/tonkin-g.asp
Accessed
2026-11-09
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Exhibit 382 · Court opinion

New York Times Co. v. United States, 403 U.S. 713

held that the Government had not met that burden. We agree.

Court refuses to enjoin the Times and Post from publishing the classified Defense Department study 'History of U.S. Decision-Making Process on Viet Nam Policy'; separate opinions from nine Justices. Stewart (with White) accepted that the Executive was correct about some documents but could not find sure, direct, immediate and irreparable damage.

Source
U.S. Supreme Court (per curiam)
Date
30 June 1971
Quoted from
per curiam, para 2 (Cornell numbering); 403 U.S. at 714
Grade
Primary record
Document
https://www.law.cornell.edu/supremecourt/text/403/713
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2026-11-09
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Note
Stewart, J., concurring: 'I cannot say that disclosure of any of them will surely result in direct, immediate, and irreparable damage to our Nation or its people.' (Cornell para 49).

Exhibit 383 · Archival release page

Pentagon Papers (Report of the Office of the Secretary of Defense Vietnam Task Force)

Approximately 34% of the report is available for the first time.

NARA describes the study commissioned by McNamara in 1967, presented to Secretary Clifford on 15 January 1969 and leaked in June 1971, and its complete release: 48 boxes, about 7,000 pages, with Part V.A (public statements) and Part V.B (internal documents).

Source
National Archives and Records Administration
Date
2011 (40th anniversary of the 1971 leak)
Quoted from
release description, paragraph 1
Grade
Primary record
Document
https://www.archives.gov/research/pentagon-papers
Accessed
2026-11-09
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Note
Release day (13 June 2011) is not on the page read.

Exhibit 384 · Internal policy paper

Paper Prepared by the Assistant Secretary of Defense for International Security Affairs (McNaughton)

70%—To avoid a humiliating US defeat (to our reputation as a guarantor).

McNaughton's paper 'Action for South Vietnam' lists U.S. aims by percentage and options for escalation. A near-identical text appears in the Pentagon Papers.

Source
U.S. Department of State, Office of the Historian, FRUS 1964-1968, Vol. II, Vietnam January-June 1965, Doc. 193
Date
10 March 1965
Quoted from
Doc. 193, paragraph 1
Grade
Primary record
Document
https://history.state.gov/historicaldocuments/frus1964-68v02/d193
Accessed
2026-11-09
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Exhibit 385 · National Intelligence Estimate

National Intelligence Estimate 2002-16HC: Iraq's Continuing Programs for Weapons of Mass Destruction

INR considers the available evidence inadequate to support such a judgment.

Key judgments with the Energy Department, State/INR and Air Force dissents, and the confidence levels table assigning low confidence to whether Saddam would share chemical or biological weapons with al-Qa'ida.

Source
National Intelligence Council (U.S. intelligence community)
Date
October 2002 (released copy marked April 2004)
Quoted from
State/INR Alternative View, pp. 8-9 (printed)
Grade
Primary record
Document
https://nsarchive2.gwu.edu/NSAEBB/NSAEBB129/nie.pdf
Accessed
2026-11-09
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Note
Redacted release (MORI DocID 1075566). Key judgment quoted in notes: p. 5.

Exhibit 386 · Congressional committee report

Report on the U.S. Intelligence Community's Prewar Intelligence Assessments on Iraq, S. Rpt. 108-301

either overstated, or were not supported by, the underlying intelligence reporting.

Phase I report. Conclusion 1: major key judgments of the Oct 2002 NIE overstated or unsupported. Conclusions 83 and 102: no evidence of pressure on analysts. Conclusions 85-87: the unclassified white paper dropped the estimate's caveats and dissenting agencies. Approved unanimously per additional views.

Source
U.S. Senate Select Committee on Intelligence
Date
9 July 2004
Quoted from
Conclusion 1, p. 14
Grade
Primary record
Document
https://www.intelligence.senate.gov/sites/default/files/publications/108301.pdf
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2026-11-09
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Note
Conclusion 83 at p. 284; Conclusion 85 at p. 295.

Exhibit 387 · Congressional committee report

Report on Whether Public Statements Regarding Iraq by U.S. Government Officials Were Substantiated by Intelligence Information, S. Rpt. 110-345

Statements and implications by the President and Secretary of State suggesting that Iraq and al-Qa'ida had a partnership, or that Iraq had provided al-Qa'ida with weapons training, were not substantiated by the intelligence.

Phase II report approved 10-5 on 1 April 2008. Reviews five major speeches and further statements. Most conclusions find statements substantiated; several find that statements omitted disagreement or certainty limits; Conclusion 12 (Iraq-al-Qa'ida partnership) not substantiated; Conclusion 15 (Saddam giving WMD to terrorists) contradicted. Includes minority views of Bond, Chambliss, Hatch and Burr (pp. 100-101) and views of Warner, Hagel, Snowe and others.

Source
U.S. Senate Select Committee on Intelligence
Date
5 June 2008
Quoted from
Conclusion 12, p. 71 (heading text)
Grade
Primary record
Document
https://www.intelligence.senate.gov/sites/default/files/publications/110345.pdf
Accessed
2026-11-09
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Exhibit 388 · Presidential commission report

Report to the President of the Commission on the Intelligence Capabilities of the United States Regarding Weapons of Mass Destruction

We conclude that the Intelligence Community was dead wrong in almost all of its pre-war judgments about Iraq's weapons of mass destruction.

Bipartisan commission established by Executive Order 13328. Finds the intelligence community 'dead wrong' in almost all prewar judgments, no indication of distortion, and no analytic judgment changed in response to political pressure (Conclusion 26).

Source
Commission on the Intelligence Capabilities of the United States Regarding WMD (Silberman-Robb)
Date
31 March 2005
Quoted from
transmittal letter, 31 March 2005, p. 1
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/GPO-WMD/pdf/GPO-WMD.pdf
Accessed
2026-11-09
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Note
Conclusion 26 is at scanned PDF p. 200.

Exhibit 389 · Official minute of a meeting (leaked; published 1 May 2005)

Iraq: Prime Minister's meeting, 23 July (minute from Matthew Rycroft to David Manning)

But the intelligence and facts were being fixed around the policy.

Record of a meeting at which 'C' reported on talks in Washington. First published by the Sunday Times on 1 May 2005. The copy read is PBS NewsHour's reproduction.

Source
UK Prime Minister's Office (Matthew Rycroft)
Date
23 July 2002
Quoted from
paragraph beginning 'C reported on his recent talks in Washington'
Grade
Reported
Document
https://www.pbs.org/newshour/nation/middle_east-jan-june05-memo_06-16
Accessed
2026-11-09
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Note
Reported: copy of a leaked document.

Exhibit 390 · Public inquiry report

The Report of the Iraq Inquiry, Section 3.4 (Sir Richard Dearlove's account of the 23 July 2002 meeting)

In relation to his “alleged comment” about the intelligence being fixed around the policy, Sir Richard told the Inquiry that this was really a reference to the attempts “to join up terrorism and Iraq” with which he “radically disagreed”.

Records Dearlove's evidence (paras 349-356): his remark concerned attempts to link terrorism and Iraq, he might have used the word 'fitted', and he sought an amendment to the minute.

Source
The Iraq Inquiry (Chilcot)
Date
6 July 2016
Quoted from
Report of the Iraq Inquiry, Volume II, Section 3.3 ('Development of UK strategy and options, April to July 2002'), para. 351
Grade
Primary record
Document
https://assets.publishing.service.gov.uk/media/5a80b6a640f0b62302695161/The_Report_of_the_Iraq_Inquiry_-_Volume_II.pdf
Accessed
2026-11-09
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Note
Mirror site, not the official PDF.

Exhibit 391 · Press briefing transcript

Press Briefing by Dana Perino

That does not mean that anybody purposefully lied.

Press Secretary's response to the Senate Intelligence Committee's Phase II report on the day it was released.

Source
The White House (Press Secretary Dana Perino)
Date
5 June 2008
Quoted from
answer to the first question on the Senate report
Grade
Primary record
Document
https://georgewbush-whitehouse.archives.gov/news/releases/2008/06/20080605-5.html
Accessed
2026-11-09
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Note
Same briefing: 'The majority report today is a selective view.'; 'That dissent, amongst experts within the intelligence community at some levels, did not reach the President.'

Exhibit 392 · Court filing

Complaint, Washington Post Co. v. Special Inspector General for Afghanistan Reconstruction, No. 1:18-cv-02622 (D.D.C.)

On August 24, 2016, Post reporters Greg Miller and Craig Whitlock submitted a FOIA request to SIGAR seeking records of any interviews conducted by the Lessons Learned Program with Lt. Gen. Michael Flynn (U.S. Army, ret.), who at the time was a top national security advisor to Republican presidential nominee Donald Trump.

Complaint with the Post's account of the prior Flynn-interview FOIA request (24 Aug 2016), SIGAR's January 2017 denial, the October 2017 suit (1:17-cv-2114) and the production to date. Allegations of the plaintiff, not findings.

Source
Washington Post Company (plaintiff)
Date
14 November 2018
Quoted from
Complaint, Doc. 1 in No. 1:18-cv-02622 (D.D.C., filed 14 Nov. 2018), para. 14 (pp. 4-5)
Grade
Primary record
Document
https://cases.justia.com/federal/district-courts/district-of-columbia/dcdce/1:2018cv02622/201632/1/0.pdf
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2026-11-09
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Note
Paragraphs 14-17 give the Flynn chronology; paragraph 43 gives the release counts.

Exhibit 393 · Court opinion

Memorandum Opinion, Washington Post Co. v. Special Inspector General for Afghanistan Reconstruction, No. 18-2622 (ABJ), Dkt. 44

full, unedited transcripts and complete audio recordings of all interviews conducted for the Lessons Learned program

States undisputed facts: the 23 March 2017 request, the 14 November 2018 suit, production of hundreds of records by June 2019, and rulings on FOIA Exemptions 1, 3, 5, 6, 7(C) and 7(D) (identities of low-ranking officials, private citizens and foreign nationals withheld; deliberative-process withholding rejected).

Source
U.S. District Court for the District of Columbia (Judge Amy Berman Jackson)
Date
30 September 2021
Quoted from
p. 1
Grade
Primary record
Document
https://cases.justia.com/federal/district-courts/district-of-columbia/dcdce/1:2018cv02622/201632/44/0.pdf
Accessed
2026-11-09
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Note
Earlier opinion at 486 F.

Exhibit 394 · Congressional research report

The Washington Post's 'Afghanistan Papers' and U.S. Policy: Main Points and Possible Questions for Congress, R46197

At least four of the named interviewees have contested the views attributed to them by SIGAR.

Summarizes the interviews (428 interviews; 62 identified), FOIA history, the themes, and the reactions of Pentagon officials, SIGAR and observers.

Source
Congressional Research Service (Clayton Thomas)
Date
28 January 2020
Quoted from
'Main Themes', first paragraph
Grade
Primary record
Document
https://www.everycrsreport.com/files/20200128_R46197_5f44e3287c5c247df4fbe91e9d61b54961a4b65a.html
Accessed
2026-11-09
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Exhibit 395 · Congressional hearing record

The Afghanistan Papers: Costs and Benefits of America's Longest War, S. Hrg. 116-203

We were devoid of a fundamental understanding of Afghanistan--we didn't know what we were doing.

Hearing with Sopko, Lute, Boucher and Lt. Col. Daniel Davis. Senators Paul and Lee quote Lute, Boucher and Crowley from SIGAR interviews; Sopko testifies on the interview program and on metrics being classified.

Source
U.S. Senate Homeland Security and Governmental Affairs Subcommittee on Federal Spending Oversight and Emergency Management
Date
11 February 2020
Quoted from
Sen. Paul, opening statement quoting Lute's 2015 SIGAR interview, p. 2
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/CHRG-116shrg40386/html/CHRG-116shrg40386.htm
Accessed
2026-11-09
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Note
Boucher quoted at p. 3; Crowley (as quoted by Sen. Lee) at p. 32; Sopko on the Post stories at pp. 5-6 and on classified metrics at p. 13.

Exhibit 396 · Military planning memorandum

Justification for US Military Intervention in Cuba (TS) (Operation Northwoods memorandum)

We could blow up a US ship in Guantanamo Bay and blame Cuba.

Top Secret JCS memorandum forwarding, as a preliminary submission for planning, a list of pretexts to justify military intervention in Cuba, in response to a request from the Chief of Operations, Cuba Project (Lansdale). Declassified through the Assassination Records Review Board in 1997; NARA record 202-10002-10104.

Source
Joint Chiefs of Staff (L. L. Lemnitzer, Chairman) to the Secretary of Defense
Date
13 March 1962
Quoted from
Annex to Appendix to Enclosure A, p. 8, para 3a (PDF p. 11)
Grade
Primary record
Document
https://nsarchive2.gwu.edu/news/20010430/northwoods.pdf
Accessed
2026-11-09
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Note
A proposal only; the paper says it is 'a preliminary submission suitable only for planning purposes.' NARA copy (212 pages, RIF 202-10002-10104): https://www.archives.gov/files/research/jfk/releases/2018/202-10002-10104.pdf.

Exhibit 397 · Memorandum for the record

Memorandum for the Record: Meeting with President, 16 March 1962

The President said bluntly that we were not discussing the use of U.S. military force

Records a White House meeting with the President, Taylor, the Attorney General, Bundy, Gilpatric, Lemnitzer, McCone, Alexis Johnson and Lansdale. Lemnitzer mentions plans for 'plausible pretexts to use force'. The President says no decision on the use of U.S. military force can be made.

Source
Office of the Secretary of Defense (Brig. Gen. Edward Lansdale)
Date
16 March 1962
Quoted from
p. 3, paragraph 1
Grade
Primary record
Document
https://nsarchive.gwu.edu/sites/default/files/documents/5754594/National-Security-Archive-Doc-06-Memorandum-for.pdf
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Note
Lemnitzer's remark is at p. 2. The record does not name Northwoods or state a rejection of that paper; no approval appears in the records read.

Exhibit 398 · Academic disputation (theses)

Disputation of Doctor Martin Luther on the Power and Efficacy of Indulgences (the Ninety-Five Theses)

Why does not the pope, whose wealth is to-day greater than the riches of the richest, build just this one church of St. Peter with his own money, rather than with the money of poor believers?

Ninety-five propositions for academic debate. Theses 27-28, 42-51, 56-57, 66-67 and 82-86 address money: the sale of pardons, the poor, the preachers and the pope's wealth. English translation by Jacobs and Spaeth, Works of Martin Luther (Philadelphia: A. J. Holman, 1915), vol. 1, pp. 29-38.

Source
Martin Luther, University of Wittenberg
Date
31 October 1517
Quoted from
Thesis 86 (Holman/Jacobs-Spaeth transl., 1915, vol. 1, pp. 29-38)
Grade
Primary record
Document
https://www.gutenberg.org/cache/epub/274/pg274.txt
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Exhibit 399 · Letter

Luther's letter to Archbishop Albert of Mainz

Papal indulgences for the building of St. Peter's are circulating under your most distinguished name

Luther tells Albert that indulgences for St. Peter's circulate under his name, reports what the people believe about them, quotes the Instruction to the Commissaries issued under Albert's name, and asks him to withdraw that instruction. English translation in Works of Martin Luther (Holman, 1915), vol. 1, pp. 39-42 (Wikisource transcription).

Source
Martin Luther
Date
31 October 1517
Quoted from
Letter to Albrecht, para. 2 (Holman ed., vol. 1)
Grade
Primary record
Document
https://en.wikisource.org/wiki/Works_of_Martin_Luther,_with_introductions_and_notes/Volume_1/Disputation_on_Indulgences
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Exhibit 400 · Instruction to commissioners

Instructio Summaria ad sub-commissarios (Albert of Mainz's instruction to indulgence preachers and confessors)

Declaramus etiam quod pro dictis duabus gratiis principalibus consequendis non est opus confiteri, seu ecclesias aut altaria visitare, sed duntaxat confessionale redimere

Sets out four principal graces of the St. Peter's indulgence, a graded scale of contributions from 25 Rhenish gulden (kings, bishops, princes) down to half a florin or prayer and fasting for those without money, and a confessional letter priced at one quarter of a Rhenish florin. Excerpted in Latin in Kidd, Documents Illustrative of the Continental Reformation (Oxford, 1911), No. 6, pp. 13-17, from Gerdes (1744). Kidd's text uses ellipses; the full text should be read in Gerdes or Kohler, Dokumente zum Ablassstreit (1934).

Source
Albert of Brandenburg, Archbishop of Mainz and Magdeburg, and the Guardian of the Mainz Observant Franciscans (papal commissioners)
Date
1517
Quoted from
Kidd 1911, No. 6, p. 16 (checked against page image)
Grade
Primary record
Document
https://archive.org/details/cu31924029236458
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Exhibit 401 · Papal bull

Bull Sacrosanctis Salvatoris et Redemptoris nostri (St. Peter's indulgence for the provinces of Mainz and Magdeburg)

Appeals to the faithful of Mainz and Magdeburg to contribute to the rebuilding of St. Peter's, names Albert of Mainz and the Observant Franciscan guardian as commissioners for eight years, and grants plenary remission, a confessional letter, and dispensations in return for alms put in chests. Text read in Schulte, Die Fugger in Rom (1904), Urkunden Nr. 84, transcribed from Reg. Vat. 1196 fols. 60-64v; first printed in Kohler, Dokumente zum Ablassstreit (1934), pp. 83-93.

Source
Pope Leo X
Date
31 March 1515
Grade
Primary record
Document
https://archive.org/details/diefuggerinrom1400schuuoft
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Exhibit 402 · Papal motu proprio

Motu proprio to the Apostolic Chamber on the Mainz-Magdeburg indulgence

Records that the archbishop had granted an indulgence of eight years for St. Peter's, that half the proceeds after charges go to the building, that the archbishop had paid 10,000 ducats into the pope's hands, and that the indulgence will not be revoked or suspended and no other plenary indulgence published for eight years. The text is Schulte's German translation (Die Fugger in Rom, 1904, pp. 125-126; Urkunden Nr. 85).

Source
Pope Leo X
Date
15 April 1515
Grade
Reported
Document
https://archive.org/details/diefuggerinrom1400schuuoft
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Note
Vat.; Schulte Urkunden Nr. 85).

Exhibit 403 · Petition to the pope

Petition (Supplik) of the Brandenburg envoys for an indulgence for Mainz and Magdeburg

Asks for an eight-year indulgence for St. Peter's in the provinces of Mainz and Magdeburg, with half the proceeds to the building and half to the archbishop and the churches of Mainz, Magdeburg and Halberstadt, a payment of 10,000 ducats not deductible from the pope's half, and a guarantee against competing plenary indulgences.

Source
Envoys of Albert of Brandenburg to the Roman Curia
Date
1 August 1514
Grade
Reported
Document
https://archive.org/details/diefuggerinrom1400schuuoft
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Exhibit 404 · Debt bond

Albert of Brandenburg's debt bond to Jakob Fugger for the Mainz confirmation fees

auf Jacobi apostoli schirstkunfftig vnnd den anderen vbrigen teyl auf Michahelis nechstuolgend nach data dits briues

Debt bond of Albert of Brandenburg to Jakob Fugger, 15 May 1514, as printed by Schulte (Die Fugger in Rom, 1904, Urkunden Nr. 54, p. 94). It covers about 21,000 ducats de camera at 100 ducats = 140 gulden, plus 500 gulden for exchange; Schulte reports it was for the fees for confirming the Mainz election. The text sets one instalment at Jacobi apostoli (25 July) and the other at Michahelis (Michaelmas, 29 September) 1514. Schulte's narrative (pp. 104-105) gives the total as 29,000 Rhenish gulden, a rounded figure (21,000 x 1.4 = 29,400 before the 500), and glosses the second date as 29 October.

Source
Albert of Brandenburg; Fugger bank
Date
15 May 1514
Quoted from
Schulte, Die Fugger in Rom, Urkunden Nr. 54, p. 94 (page image checked)
Grade
Reported
Document
https://archive.org/details/diefuggerinrom1400schuuoft
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Note
Printed text of the bond in Schulte's Urkunden.

Exhibit 405 · Order

Commissioners' order of 28 May 1517 giving Jakob Fugger a key to each indulgence chest

Schulte reports, from Gudenus, Codex diplomaticus 4, pp. 587 ff., that the commissioners ordered chests opened before a notary and witnesses, with Fugger holding one key; after costs, one half went to the Fugger as the papal share and the other half to the Fugger in payment of the archbishop's debt. Die Fugger in Rom (1904), pp. 143-144.

Source
Papal commissioners for Mainz-Magdeburg
Date
28 May 1517
Grade
Reported
Document
https://archive.org/details/diefuggerinrom1400schuuoft
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Exhibit 406 · Scholarly monograph with document appendix

Die Fugger in Rom, 1495-1523, mit Studien zur Geschichte des kirchlichen Finanzwesens jener Zeit

Archival study of the Fugger bank's papal business. Shows from Vatican and Magdeburg records that the indulgence proposal came through the papal Datary, not from Albert; gives the 10,000-ducat composition, the half-and-half division, the Fugger loan and the Fugger's role as papal remitter; finds that the preachers could not have enriched themselves under the instruction; and judges the venture a poor business for Albert.

Source
Aloys Schulte (Leipzig: Duncker & Humblot)
Date
1904
Grade
Peer-reviewed
Document
https://archive.org/details/diefuggerinrom1400schuuoft
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Exhibit 407 · Conciliar decree

Council of Trent, Session 21, Decree on Reformation, chapter 9 (abolition of questors of alms)

their name and use be henceforth utterly abolished

Abolishes the name and use of questors of alms throughout Christendom and orders indulgences published by the ordinaries, aided by two chapter members who collect alms without remuneration. Waterworth translation (London: Dolman, 1848), via Hanover Historical Texts Project.

Source
Council of Trent
Date
16 July 1562
Quoted from
Session 21, Decree of reformation, ch. 9 (Waterworth 1848)
Grade
Primary record
Document
https://history.hanover.edu/texts/trent/ct21.html
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Exhibit 408 · Conciliar decree

Council of Trent, Session 25, Decree concerning indulgences

ordains generally by this decree, that all evil gains for the obtaining thereof,—whence, a most prolific cause of abuses amongst the Christian people has been derived,—be wholly abolished

Retains the use of indulgences and condemns those who call them useless. Orders that all 'evil gains' (pravos quaestus) connected with obtaining indulgences be wholly abolished, and bishops to report other abuses to the provincial synod and the pope. Latin: 'pravos quaestus omnes pro his consequendis, unde plurima in Christiano populo abusuum causa fluxit, omnino abolendos esse.' The English phrase is 'evil gains', not 'evil traffic'.

Source
Council of Trent
Date
4 December 1563
Quoted from
Session 25, Decree concerning indulgences (Schaff, Creeds of Christendom, vol. 2, Latin with English)
Grade
Primary record
Document
https://ccel.org/ccel/schaff/creeds2.v.i.i.xiii.html
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Exhibit 409 · Papal constitution

Constitution Etsi dominici gregis (revocation of indulgences carrying a questing faculty; prohibition of questing and appointment of questors)

multi quaestores ex eisdem indulgentiis lucrum temporalem tantum quaerentes

Records many complaints that questors sought temporal gain from indulgences granted to the fabric of St. Peter's and to other hospitals and churches. Revokes, cancels and annuls all indulgences, including perpetual ones, for the fabric of St. Peter's and other named and unnamed institutions that carry a questing faculty, and forbids anyone, of any rank, to quest or appoint questors without special papal licence. Bullarium Romanum, Taurinensis ed., vol. 7, pp. 535-537, constitution XLV. The brief's title 'Quam plenum' is a different constitution; see Quam plenum exhibit.

Source
Pope Pius V
Date
8 February 1567
Quoted from
Bullarium Romanum (Taurinensis) vol. 7, p. 535, sec. 1 (checked against page image)
Grade
Primary record
Document
https://archive.org/details/bullarumdiplomat07cath
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Exhibit 410 · Papal constitution

Constitution Quam plenum (abolition of letters sold by Spanish prelates granting confessors and indulgences for a price)

Addresses prelates in Spain who published letters under which, for a fixed payment, the holder could choose any confessor, receive absolution in reserved cases and indulgences, and which a table posted in churches priced. The pope abolishes those letters and indices and imposes suspension on prelates and excommunication on lesser persons. Bullarium Romanum (Taurinensis) vol. 7, constitution CXXII, repeated as CLI (1570). It concerns confessional letters in Spain, and is not the general 1567 revocation.

Source
Pope Pius V
Date
2 January 1569
Grade
Primary record
Document
https://archive.org/details/bullarumdiplomat07cath
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Exhibit 411 · Catechism

Catechism of the Catholic Church, nos. 1471-1479 (Indulgences)

An indulgence is a remission before God of the temporal punishment due to sins whose guilt has already been forgiven

States the Church's current teaching: an indulgence is a remission before God of the temporal punishment due to sins whose guilt has already been forgiven, gained under prescribed conditions through the Church. Nos. 1472-1473 distinguish eternal from temporal punishment and say forgiveness of guilt does not require an indulgence. No. 1478 says the Church wants to spur the faithful to works of devotion, penance and charity. Footnote 81 cites Paul VI, Indulgentiarum doctrina, norm 1.

Source
Catholic Church (Libreria Editrice Vaticana)
Date
1992 (1997 typical edition)
Quoted from
CCC no. 1471
Grade
Primary record
Document
https://www.vatican.va/archive/ENG0015/__P4G.HTM
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Exhibit 412 · Satirical essay

In Praise of Folly (passage on pardons and indulgences)

What shall I say of such as cry up and maintain the cheat of pardons and indulgences?

A Catholic humanist and priest ridicules those who maintain pardons and indulgences and who compute a soul's time in purgatory by the number of pardons purchased, and says a highwayman, plundering soldier or bribe-taking judge can pay part of his gains and count his sins atoned for. Gutenberg ebook 30201, English translation (translator not stated in the file; verify against the Wilson 1668 or another named edition before citing).

Source
Desiderius Erasmus
Date
1511
Quoted from
Gutenberg #30201, section on superstitions (Folly's speech)
Grade
Primary record
Document
https://www.gutenberg.org/cache/epub/30201/pg30201.txt
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Exhibit 413 · Statute

26 U.S.C. § 508 (special rules for section 501(c)(3) organizations)

Subsections (a) and (b) shall not apply to— (A) churches, their integrated auxiliaries, and conventions or associations of churches, or

New 501(c)(3) organizations must give notice that they apply for recognition (§508(a)). Subsection (c)(1) excepts churches, their integrated auxiliaries, and conventions or associations of churches, and any non-foundation with normal gross receipts of $5,000 or less. Text read at the Cornell LII copy of the U.S. Code.

Source
United States Congress (Internal Revenue Code)
Date
as in force 2026
Quoted from
26 U.S.C. § 508(c)(1)(A)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/26/508
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Exhibit 414 · Statute

26 U.S.C. § 6033 (returns by exempt organizations)

Paragraph (1) shall not apply to— (i) churches, their integrated auxiliaries, and conventions or associations of churches,

Subsection (a)(3)(A) lists mandatory exceptions from the annual information return: churches and their integrated auxiliaries and conventions or associations of churches; non-foundations with normal gross receipts of $5,000 or less; and the exclusively religious activities of any religious order. (a)(3)(B) gives the Secretary discretion to excuse other organizations. Text read at the Cornell LII copy.

Source
United States Congress (Internal Revenue Code)
Date
as in force 2026
Quoted from
26 U.S.C. § 6033(a)(3)(A)(i)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/26/6033
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Exhibit 415 · Statute

26 U.S.C. § 7611 (restrictions on church tax inquiries and examinations; Church Audit Procedures Act)

The Secretary may begin a church tax inquiry only if— (A) the reasonable belief requirements of paragraph (2), and (B) the notice requirements of paragraph (3), have been met.

Conditions for a church tax inquiry: a written reasonable belief by an appropriate high-level Treasury official (a)(2) and written notice stating the concerns (a)(3). Examination of church records only as necessary to determine tax liability, with 15 days notice and an offered conference (b). Completion within 2 years of the examination notice, or 90 days for an inquiry with no examination (c)(1). Revocation, deficiency notice or assessment requires written approval of regional counsel (d)(1). Section 7611(i) excludes criminal investigations and willful evasion. Text read at the Cornell LII copy.

Source
United States Congress (Internal Revenue Code; added by Pub. L. 98-369 § 1033, 18 July 1984)
Date
1984; as in force 2026
Quoted from
26 U.S.C. § 7611(a)(1)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/26/7611
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Exhibit 416 · Statute

26 U.S.C. § 501(c)(3) (exemption; political campaign clause, "Johnson Amendment")

does not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of (or in opposition to) any candidate for public office

The campaign-intervention clause of §501(c)(3), added in 1954 (100 Cong. Rec. 9604, as cited in the district court opinion in NRB v. Bessent). It applies to churches and other 501(c)(3) organizations alike.

Source
United States Congress (Internal Revenue Code; clause added 1954)
Date
as in force 2026
Quoted from
26 U.S.C. § 501(c)(3)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/26/501
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Exhibit 417 · Court opinion

Walz v. Tax Commission of the City of New York, 397 U.S. 664

The State has an affirmative policy that considers these groups as beneficial and stabilizing influences in community life and finds this classification useful, desirable, and in the public interest.

Upheld New York City property tax exemption for houses of worship. Rationale: the exemption covers a broad class of nonprofit properties; legislative purpose is not to establish religion; and either taxing churches or exempting them involves some contact, with exemption involving less. Chief Justice Burger for the Court.

Source
Supreme Court of the United States
Date
4 May 1970
Quoted from
397 U.S. at 673 (Part V)
Grade
Primary record
Document
https://tile.loc.gov/storage-services/service/ll/usrep/usrep397/usrep397664/usrep397664.pdf
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Exhibit 418 · Court opinion

Bob Jones University v. United States, 461 U.S. 574

Charitable exemptions are justified on the basis that the exempt entity confers a public benefit—a benefit which the society or the community may not itself choose or be able to provide, or which supplements and advances the work of public institutions already supported by tax revenues.

Held that a school with racially discriminatory policies, including one based on religious belief, did not qualify as charitable under §501(c)(3), and that denial of the exemption did not violate the Religion Clauses because of the government interest in eradicating racial discrimination in education. Chief Justice Burger for the Court; Justice Rehnquist dissented. The opinion states the general rationale for charitable exemption.

Source
Supreme Court of the United States
Date
24 May 1983
Quoted from
461 U.S. 574, 591 (Part II-A; pages 585-592 per syllabus)
Grade
Primary record
Document
https://tile.loc.gov/storage-services/service/ll/usrep/usrep461/usrep461574/usrep461574.pdf
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Exhibit 419 · Hearing

Church Audit Procedures Act, hearing on S. 1262 before the Subcommittee on Oversight of the Internal Revenue Service, Committee on Finance, S. Hrg. 98-481

The audit resulted in exoneration, but I was struck by how quickly the integrity, character, and moral foundation of small congregations could be undermined by innuendo, rumor, and press coverage during extended I.R.S. examinations.

Hearing on the bill that became §7611. Chairman Grassley said the bill was to "clarify and expedite" church audits and "minimize potential constitutional entanglements"; Treasury and the IRS Commissioner testified; witnesses included the Evangelical Council for Financial Accountability and the National Council of Churches.

Source
U.S. Senate Committee on Finance
Date
30 September 1983
Quoted from
Opening statement of Sen. Grassley, pp. 1-2
Grade
Primary record
Document
https://www.finance.senate.gov/imo/media/doc/HRG98-481.pdf
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Exhibit 420 · Conference report

Deficit Reduction Act of 1984, Conference Report, H. Rept. 98-861 (church audits, title X, sec. 1033)

No special requirements are imposed before commencing an investigation or inquiry regarding church tax liabilities.

The explanation of the church-audit provisions that became §7611: reasonable belief of a regional commissioner or higher official recorded in writing, written inquiry notice, examination limits. States that informant information "must not be known to be unreliable."

Source
U.S. House of Representatives, Committee of Conference
Date
23 June 1984
Quoted from
H. Rept. 98-861, p. 1102 (present-law statement, item 6, "Church audits")
Grade
Primary record
Document
https://www.finance.senate.gov/imo/media/doc/Conf-98-861.pdf
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Exhibit 421 · Administrative order

In the Matter of Ensign Peak Advisors, Inc. and The Church of Jesus Christ of Latter-day Saints, Exchange Act Release No. 96951, File No. 3-21306

the Church and Ensign Peak created thirteen limited liability corporations (“LLCs”), including twelve similar LLCs (the “Clone LLCs”) with addresses located throughout the U.S., for the sole purpose of filing Forms 13F and preventing public disclosure by Ensign Peak of the Church’s equity securities holdings.

Settled cease-and-desist order (respondents neither admitted nor denied the findings). Finds Ensign Peak failed to file Forms 13F in its own name from 1997 through 2019 and filed them under thirteen LLCs that misstated investment discretion; the Church approved the approach and caused the violations. Penalties: $4,000,000 (Ensign Peak) and $1,000,000 (Church). First consolidated Form 13F filed 14 February 2020 listing 1,659 securities worth about $37.8 billion.

Source
U.S. Securities and Exchange Commission
Date
21 February 2023
Quoted from
Order, Part III, Summary (p. 2)
Grade
Primary record
Document
https://www.sec.gov/litigation/admin/2023/34-96951.pdf
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Exhibit 422 · Press release

SEC Charges The Church of Jesus Christ of Latter-day Saints and Its Investment Management Company for Disclosure Failures and Misstated Filings (press release 2023-35)

The requirement to file timely and accurate information on Forms 13F applies to all institutional investment managers, including non-profit and charitable organizations.

The SEC press release accompanying the order. Enforcement Director Gurbir Grewal is quoted that the Form 13F requirement "applies to all institutional investment managers, including non-profit and charitable organizations."

Source
U.S. Securities and Exchange Commission
Date
21 February 2023
Quoted from
Press release 2023-35, 21 Feb 2023, paragraph 3 (attributed to Gurbir S. Grewal, Director, Division of Enforcement)
Grade
Primary record
Document
https://www.sec.gov/news/press-release/2023-35
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Exhibit 423 · Agency notice

SEC Whistleblower Program, Notice of Covered Action 2023-036 (Ensign Peak Advisors / the Church)

Lists File No. 3-21306 (filed 21 February 2023) as a covered action open to whistleblower award claims. It does not say who, if anyone, supplied information or that an award was made.

Source
U.S. Securities and Exchange Commission
Date
30 March 2023
Grade
Primary record
Document
https://www.sec.gov/enforcement-litigation/whistleblower-program/notice-covered-actions/award-claim-2023-036
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Exhibit 424 · Institution statement

First Presidency Statement on Church Finances

The Church complies with all applicable law governing our donations, investments, taxes, and reserves.

The Church's response to media reports of the Nielsen whistleblower complaint. States that a portion of funds is "methodically safeguarded" as a reserve and that claims in circulation are "based on a narrow perspective and limited information."

Source
The Church of Jesus Christ of Latter-day Saints
Date
17 December 2019
Quoted from
Statement, paragraph 2
Grade
Primary record
Document
https://newsroom.churchofjesuschrist.org/article/first-presidency-statement-church-finances
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Exhibit 425 · Institution statement

Church Issues Statement on SEC Settlement

We affirm our commitment to comply with the law, regret mistakes made, and now consider this matter closed.

The Church's response to the SEC order. Says Ensign Peak "received and relied upon legal counsel," that the SEC first expressed concern in June 2019, that Ensign Peak then filed a single aggregated report, and that the Church's senior leadership "never prepared or filed the specific reports at issue."

Source
The Church of Jesus Christ of Latter-day Saints
Date
21 February 2023
Quoted from
Statement, final paragraph
Grade
Primary record
Document
https://newsroom.churchofjesuschrist.org/article/church-issues-statement-on-sec-settlement
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Exhibit 426 · News report

A Cloud Of Mystery Remains Over Whistleblower Complaint Against LDS Church

He prepared a 74-page complaint with his twin brother, Lars, to send to the IRS whistleblower program.

Reports that a former Ensign Peak employee, who resigned in 2019, prepared a 74-page complaint with his twin brother to send to the IRS whistleblower program, and that an IRS spokesman in Utah could not confirm any investigation. The article states that the Washington Post and Religion Unplugged reported on the complaint in 2019.

Source
Religion Unplugged
Date
30 March 2021
Quoted from
Article, paragraph beginning "The whistleblower identified as David A. Nielsen"
Grade
Reported
Document
https://religionunplugged.com/news/2021/3/30/a-cloud-of-mystery-remains-over-whistleblower-complaint-against-lds-church
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Note
Secondhand. A primary document would be the complaint itself or an IRS response. The article does not give the date the complaint was sent, the author's job title or the date of the first report.

Exhibit 427 · Congressional staff report

Review of Tax Issues Raised by Media-Based Ministries (staff memorandum to Sen. Grassley, 61 pp.)

that organization will be invisible to the IRS and operate virtually without government oversight because no state requires religious organizations to register and file annual financial reports with the state attorney general.

Result of a three-year inquiry begun by Grassley letters of November 2007 to six media-based ministries. Staff found no Form 990 for the churches or, with very limited exception, their related organizations; did not subpoena; and recommended against requiring every church to file Form 990. Raises options: IRS advisory committee, e-postcard, exemption for churches accountable to another body. Makes no finding of tax violation.

Source
U.S. Senate Committee on Finance, minority staff
Date
6 January 2011
Quoted from
Staff memo, p. 20 (section on church exception to filing)
Grade
Primary record
Document
https://www.finance.senate.gov/imo/media/doc/SFC%20Staff%20Memo%20to%20Grassley%20re%20Ministries%2001-06-11%20FINAL.pdf
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Exhibit 428 · Press release

Grassley Releases Review of Tax Issues Raised by Media-based Ministries (press release)

The challenge is to encourage good governance and best practices and so preserve confidence in the tax-exempt sector without imposing regulations that inhibit religious freedom or are functionally ineffective

Records which ministries responded. Joyce Meyer Ministries and Benny Hinn's World Healing Center Church answered fully; Randy and Paula White, Eddie Long and Kenneth and Gloria Copeland gave incomplete responses; Creflo and Taffi Dollar declined to provide any requested information. Asks ECFA to lead a sector discussion.

Source
U.S. Senate Committee on Finance
Date
6 January 2011
Quoted from
Press release, quotation of Sen. Grassley, paragraph 6
Grade
Primary record
Document
https://www.finance.senate.gov/ranking-members-news/grassley-releases-review-of-tax-issues-raised-by-media-based-ministries
Accessed
2026-11-09
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Findings citing this exhibit

Exhibit 429 · Voluntary accreditation standards

Seven Standards of Responsible Stewardship

Every organization shall provide a copy of its current financial statements upon written request and shall provide other disclosures as the law may require.

Seven pass-fail standards for members: doctrinal statement affirming the evangelical Christian faith; board of five or more with an independent majority; financial oversight with an independent CPA; use of resources and legal compliance; transparency; compensation and related-party transactions; and stewardship of gifts. Membership is voluntary and limited to organizations affirming evangelical Christian faith.

Source
Evangelical Council for Financial Accountability
Date
read 9 November 2026
Quoted from
Standard 5 (Transparency)
Grade
Primary record
Document
https://www.ecfa.org/Content/Standards
Accessed
2026-11-09
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Findings citing this exhibit

Exhibit 430 · Organization FAQ

FAQs: How Does ECFA Accreditation and Member Accountability Work?

ECFA does not offer financial audits or other professional services for members.

States ECFA has "over 2,700" accredited churches and ministries, that membership is voluntary, that about 35 percent of applicants are accepted on first application, that members must have annual statements "audited, reviewed, or compiled by an independent CPA," and that compliance rests on application review, annual renewal affirmation, periodic check-ins and complaint-driven reviews. Says ECFA is not an auditor.

Source
Evangelical Council for Financial Accountability
Date
read 9 November 2026
Quoted from
FAQ, "Is ECFA an auditor or fraud examiner?"
Grade
Primary record
Document
https://www.ecfa.org/Content/FAQs-How-Does-ECFA-Accreditation-and-MemberAccountability-Work
Accessed
2026-11-09
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Exhibit 431 · Organization history

ECFA History

challenged them to police their own mission agencies as a "Christian Better Business Bureau" or face the potential of government intervention.

ECFA's account of its founding in 1979 after Senator Mark Hatfield challenged evangelical leaders to police their own organizations.

Source
Evangelical Council for Financial Accountability
Date
read 9 November 2026
Quoted from
ECFA History, paragraph 3
Grade
Primary record
Document
https://www.ecfa.org/Content/GeneralBackground
Accessed
2026-11-09
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Exhibit 432 · Organization page

ECFA Form 990 (page)

Although the IRS has recognized ECFA’s legal status as an association of churches exempt from the annual Form 990 filing requirements, we choose to voluntarily prepare the form

ECFA states that the IRS recognizes it as an association of churches exempt from the annual Form 990 and that it files voluntarily.

Source
Evangelical Council for Financial Accountability
Date
read 9 November 2026
Quoted from
ECFA Form 990 page, paragraph 1
Grade
Primary record
Document
https://www.ecfa.org/Content/Form990
Accessed
2026-11-09
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Findings citing this exhibit

Exhibit 433 · Voluntary reporting resolution

Resolution on Diocesan Financial Reporting (approved November 2000; renewed through November 2026)

encourages the adoption of a voluntary financial reporting system

A voluntary reporting system. Each suffragan bishop is asked to send his metropolitan archbishop a letter naming the finance council members and stating that they reviewed the audited statements. The resolution does not require public filing.

Source
United States Conference of Catholic Bishops
Date
2000; renewed 2021
Quoted from
Preamble
Grade
Primary record
Document
https://www.usccb.org/about/financial-reporting/diocesan-financial-reporting
Accessed
2026-11-09
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Exhibit 434 · Magazine research report

Research Report: How Secular Humanists (and Everyone Else) Subsidize Religion in the United States

we are fairly confident that our estimates are on the conservative end of the subsidies provided to religions by governments in the United States.

Estimates about $71 billion a year in government subsidy to religion: federal income tax $35.3 billion; state income tax $6.1 billion; property tax $26.2 billion; investment tax $41 million; parsonage $1.2 billion; Faith-Based Initiatives $2.2 billion. Method assumes top federal corporate rate on religious giving, 335,000 congregations at an average $1.7 million property value from a 47-church Tampa sample. Authors say they could not estimate local taxes, the donor deduction, sales tax, the SECA exemption or related business income. Not peer reviewed; published by a secular humanist council.

Source
Cragun, Yeager and Vega, Free Inquiry 32(4), pp. 39-46
Date
June/July 2012
Quoted from
p. 43
Grade
Reported
Document
https://www.ryantcragun.com/?p=158
Accessed
2026-11-09
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Findings citing this exhibit
Note
Published in Free Inquiry, the magazine of the Council for Secular Humanism; not peer reviewed.

Exhibit 436 · Court opinion

National Religious Broadcasters v. Bessent, No. 6:24-cv-00311 (E.D. Tex.), Opinion and Order (ECF 106)

this case is dismissed without prejudice for lack of subject-matter jurisdiction.

Held the Tax Anti-Injunction Act and the tax bar in the Declaratory Judgment Act deprive the court of jurisdiction to enter the proposed relief, even by consent. Did not reach the merits. Plaintiffs filed a notice of appeal on 22 April 2026 (ECF 108). The order of 12 December 2025 (ECF 102) denied Americans United's motion to intervene and kept it as amicus.

Source
U.S. District Court, Eastern District of Texas (Judge J. Campbell Barker)
Date
31 March 2026
Quoted from
Opinion, p. 9
Grade
Primary record
Document
https://storage.courtlistener.com/recap/gov.uscourts.txed.232590/gov.uscourts.txed.232590.106.0.pdf
Accessed
2026-11-09
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Exhibit 437 · Court opinion

Branch Ministries v. Rossotti, 211 F.3d 137 (D.C. Cir.)

for the first time in its history, it revoked a bona fide church's tax-exempt status because of its involvement in politics.

Upheld the IRS revocation of the Church at Pierce Creek's exemption after it placed full-page newspaper advertisements before the 1992 election urging Christians not to vote for Bill Clinton. Describes the Church Audit Procedures Act as special restrictions on investigating churches. Rejected the church's selective-enforcement claim, which pointed to reports of pulpit endorsements of Democratic candidates.

Source
U.S. Court of Appeals for the D.C. Circuit
Date
12 May 2000
Quoted from
Slip op., introduction
Grade
Primary record
Document
https://www.gpo.gov/fdsys/pkg/USCOURTS-caDC-99-05097/pdf/USCOURTS-caDC-99-05097-0.pdf
Accessed
2026-11-09
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Exhibit 438 · Press release

Grassley Seeks Information from Six Media-based Ministries

The allegations involve governing boards that aren't independent and allow generous salaries and housing allowances and amenities such as private jets and Rolls Royces. I don't want to conclude that there's a problem, but I have an obligation to donors and the taxpayers to find out more.

Names the six ministries written to on 5 Nov 2007. Grassley was ranking member; Baucus was chairman.

Source
U.S. Senate Committee on Finance (ranking member Grassley)
Date
6 November 2007
Quoted from
para. 2
Grade
Primary record
Document
https://webarchive.library.unt.edu/eot2008/20090103105108id_/http://finance.senate.gov/press/Gpress/2007/prg110607.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 439 · Congressional letter

Letter, Grassley to Benny Hinn (representative of the six 5 Nov 2007 letters)

Please provide the requested information on searchable disks or electronically by December 6, 2007.

Letter to Benny Hinn, one of six sent on 5 November 2007. It requests audited financial statements for 2004 to 2006, board and compensation-committee names, compensation, housing, vehicles, aircraft and related entities by 6 December 2007.

Source
U.S. Senate Committee on Finance
Date
5 November 2007
Quoted from
Letter of 5 November 2007, p. 1 (scanned PDF read by OCR)
Grade
Primary record
Document
https://www.finance.senate.gov/imo/media/doc/prg110607b.pdf
Accessed
2026-11-09
Cited by
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Exhibit 440 · Press memorandum

Memorandum: Ministries' response to Nov. 5 inquiry

For the focus of this inquiry, ministries are the same as any other non-profit organization. It's a question of abiding by tax laws just like any tax-exempt group.

Status of each ministry at the 6 Dec 2007 deadline.

Source
U.S. Senate Committee on Finance (ranking member Grassley)
Date
6 December 2007
Quoted from
para. 2
Grade
Primary record
Document
https://www.finance.senate.gov/imo/media/doc/prg120607b1.pdf
Accessed
2026-11-09
Cited by
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Exhibit 441 · Press memorandum and letters

Memorandum and release: Ministry responses; Baucus-Grassley follow-up letters of 11 March 2008

While the inquiry is not part of an enforcement action, which would properly belong to the IRS, it is within the jurisdiction of the Committee to make these inquiries.

Chairman Baucus and Ranking Member Grassley wrote to four ministries; Hinn had answered five of 28 questions.

Source
U.S. Senate Committee on Finance
Date
31 March 2008
Quoted from
11 Mar 2008 letter, para. 3
Grade
Primary record
Document
https://webarchive.library.unt.edu/eot2008/20090102235502id_/http://finance.senate.gov/press/Gpress/2008/prg033108a.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 442 · Press memorandum

Memorandum: Ministry responses, with Background Questions and Answers

The doctrine of the churches was not part of his inquiry in any way.

Committee's own characterization of each ministry's response; Q&A on church tax rules and why Congress, not the IRS, was asking.

Source
U.S. Senate Committee on Finance
Date
7 July 2008
Quoted from
Background Q&A, 'Doesn't the investigation raise constitutional issues'
Grade
Primary record
Document
https://webarchive.library.unt.edu/eot2008/20090102235502id_/http://finance.senate.gov/press/Gpress/2008/prg070708.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 443 · Press release

Grassley Releases Review of Tax Issues Raised by Media-based Ministries

The challenge is to encourage good governance and best practices and so preserve confidence in the tax-exempt sector without imposing regulations that inhibit religious freedom or are functionally ineffective.

Releases staff review; two ministries fully responded, four did not; refers issues to ECFA.

Source
U.S. Senate Committee on Finance (ranking member Grassley)
Date
6 January 2011
Quoted from
para. 9
Grade
Primary record
Document
https://www.finance.senate.gov/ranking-members-news/grassley-releases-review-of-tax-issues-raised-by-media-based-ministries
Accessed
2026-11-09
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Exhibit 444 · Staff memorandum

Memorandum to Senator Grassley: Review of Media-Based Ministries (61 pp.)

The Committee's consideration of health reform legislation, which began in the winter of 2009, ensured that we would not have the time or resources to issue and enforce the subpoenas. As a result, staff also decided against issuing subpoenas to the churches.

Staff review; why no subpoenas issued; issues for consideration (advisory committee, parsonage, filing, 4958, love offerings, electioneering). Not a committee-adopted report.

Source
U.S. Senate Committee on Finance, minority staff (Pattara and Barnett)
Date
6 January 2011
Quoted from
p. 2
Grade
Primary record
Document
https://www.finance.senate.gov/imo/media/doc/SFC%20Staff%20Memo%20to%20Grassley%20re%20Ministries%2001-06-11%20FINAL.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
A minority-staff memorandum to Senator Grassley, not a report adopted by the committee.

Exhibit 445 · Staff memorandum

Staff memo, Appendix C item 3 (IRS filing requirements)

we do not recommend completely eliminating the church exception to the filing requirements, i.e., we do not recommend requiring every church to file a Form 990.

Staff declined to recommend that every church file a Form 990.

Source
U.S. Senate Committee on Finance, minority staff
Date
6 January 2011
Quoted from
p. 32
Grade
Primary record
Document
https://www.finance.senate.gov/imo/media/doc/SFC%20Staff%20Memo%20to%20Grassley%20re%20Ministries%2001-06-11%20FINAL.pdf
Accessed
2026-11-09
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Exhibit 446 · Congressional letter

Letter, Grassley to Dan Busby, ECFA

I stated then that I believe that legislation should be the last resort.

Asks ECFA to address the staff's issues and whether they can be handled without legislation. Image checked by eye.

Source
U.S. Senate Committee on Finance
Date
5 January 2011
Quoted from
para. 4
Grade
Primary record
Document
https://web.archive.org/web/2011/http://finance.senate.gov/newsroom/ranking/download/?id=5c0f3911-8eab-4dbe-b780-888ee451af0b
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 447 · Staff review

Minority Staff Review of Eagle Mountain International Church d/b/a Kenneth Copeland Ministries

Based on constitutionally and statutorily based privacy and confidentiality concerns, the Church respectfully declines to provide the detailed accounting requested.

Quotes the ministry's 6 Dec 2007 reply declining the detailed accounting and pointing to IRS church tax inquiry procedure. Staff-derived facts rest on public records and unnamed informants.

Source
U.S. Senate Committee on Finance, minority staff (Simmons)
Date
5 January 2011
Quoted from
p. 1
Grade
Primary record
Document
https://www.finance.senate.gov/imo/media/doc/EMIC%20Copeland%2001-5-11.pdf
Accessed
2026-11-09
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Exhibit 448 · Ministry letter

Letter, Benny Hinn Ministries to Senator Grassley

I believe you and your dedicated staff will confirm that, nearly 5,000 pages of production later, we have been thorough and comprehensive in our submissions.

Ministry's own account of cooperation and reforms.

Source
Benny Hinn Ministries
Date
9 September 2008
Quoted from
Benny Hinn letter to Sen. Grassley, 9 Sep 2008, p. 1
Grade
Primary record
Document
https://web.archive.org/web/20120403034321/http://finance.senate.gov/newsroom/ranking/download/?id=8e055073-52f2-4c1f-8290-b4fc063b0f8a
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 449 · Ministry letter

Letter, Joyce Meyer Ministries to Senator Grassley

Voluntary financial audits have been performed by independent public accounting firms since 1995.

Lists governance steps (audits since 1995, independent compensation committee since 2005, majority-independent board).

Source
Joyce Meyer Ministries
Date
10 December 2008
Quoted from
Joyce Meyer Ministries letter to Sen. Grassley, 10 Dec 2008, p. 1, item 1
Grade
Primary record
Document
https://web.archive.org/web/20120403034110/http://finance.senate.gov/newsroom/ranking/download/?id=25a6a53a-789c-4467-a2b9-c847a853a3be
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 450 · Correspondence

Letter, Caplin & Drysdale (counsel for World Changers Church International) to Finance Committee staff; Grassley reply 2 July 2008

Finally, you noted that it is Senate Finance Committee’s position that the investigation does not implicate the First Amendment rights of the members of World Changers Church International.

Letter of 5 June 2008 from Marcus S. Owens (Caplin & Drysdale) to Theresa Pattara, recording counsel's account of the staff call, including the Committee's stated position on First Amendment concerns. The same packet holds Grassley's 2 July 2008 reply to Creflo and Taffi Dollar; its section 'First Amendment Concerns' begins 'There is no question in my mind about the strength of the First Amendment protections for religious liberty' (p. 3). Counsel's November 2007 and March 2008 letters are described in the packet and are not in it.

Source
Caplin & Drysdale / U.S. Senate Committee on Finance
Date
5 June 2008; 2 July 2008
Quoted from
Marcus S. Owens (Caplin & Drysdale) to Theresa Pattara, 5 Jun 2008, p. 1
Grade
Primary record
Document
https://web.archive.org/web/20120403034356/http://finance.senate.gov/newsroom/ranking/download/?id=7cc41cb9-7be6-4a42-ae58-c432a754d347
Accessed
2026-11-09
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Note
Scanned 12-page PDF. The URL is an archived copy; the issuer's original address is no longer the working copy.

Exhibit 451 · Accreditor letter

Letter, ECFA board chair Batts to Senator Grassley

In our view, churches, in general, would view annual filing with the IRS to be governmental intrusion into the most intimate recesses of church administration, including compensation practices.

Opposes requiring churches to file Form 990 or 990-N.

Source
Evangelical Council for Financial Accountability
Date
21 April 2009
Quoted from
Michael E. Batts (ECFA board chair) to Sen. Grassley, 21 Apr 2009, p. 1
Grade
Primary record
Document
https://web.archive.org/web/20111216215654/http://finance.senate.gov/newsroom/ranking/download/?id=abb25810-a26e-4329-a4ed-424e692eb34f
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 452 · Accreditor report

Enhancing Accountability for the Religious and Broader Nonprofit Sector

He specifically asked ECFA to seek solutions that rely on self-regulation and not on new burdensome legislation.

Report to Grassley on compensation, clergy housing reporting, donor engagement; notes Driscoll cert denial (Oct 2012).

Source
Evangelical Council for Financial Accountability, Commission on Accountability and Policy for Religious Organizations
Date
December 2012
Quoted from
Message from the Chairman, p. 5
Grade
Primary record
Document
https://web.archive.org/web/2013/http://www.ecfa.org/PDF/Commission-Report-December-2012.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 453 · Accreditation standards

Seven Standards of Responsible Stewardship

Every organization shall be governed by a responsible board of not less than five individuals, a majority of whom shall be independent, who shall meet at least semiannually to establish policy and review its accomplishments.

Standard 1 requires a statement of faith affirming the evangelical Christian faith; Standards 2-6 govern board, audit, transparency and compensation.

Source
Evangelical Council for Financial Accountability
Date
2024 (web page)
Quoted from
Standard 2
Grade
Primary record
Document
https://web.archive.org/web/2024/https://www.ecfa.org/Content/Standards
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The URL is an archived copy (Wayback Machine or UNT web archive); the issuer's original address is no longer the working copy.

Exhibit 454 · Statute

26 U.S.C. 107 (Rental value of parsonages)

In the case of a minister of the gospel, gross income does not include—

Excludes from a minister's gross income the rental value of a furnished home or a rental allowance capped at fair rental value.

Source
U.S. Code
Date
current
Quoted from
opening clause
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/26/107
Accessed
2026-11-09
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Exhibit 455 · Statute

26 U.S.C. 4958 (Excess benefit transactions)

there is hereby imposed on each excess benefit transaction a tax equal to 25 percent of the excess benefit.

25 percent tax on disqualified person, 10 percent on managers, 200 percent if uncorrected.

Source
U.S. Code
Date
current
Quoted from
(a)(1)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/26/4958
Accessed
2026-11-09
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Exhibit 456 · Statute

26 U.S.C. 7611 (Church tax inquiries and examinations)

if an appropriate high-level Treasury official reasonably believes (on the basis of facts and circumstances recorded in writing)

Church Audit Procedures Act: written reasonable-belief and notice requirements before an IRS church inquiry.

Source
U.S. Code
Date
current
Quoted from
(a)(2)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/26/7611
Accessed
2026-11-09
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Exhibit 457 · Court opinion

Gaylor v. Mnuchin, 919 F.3d 420 (7th Cir. 2019)

We conclude § 107(2) is constitutional. The judgment of the district court is REVERSED.

Reversed the district court and held section 107(2) constitutional under the Establishment Clause.

Source
U.S. Court of Appeals for the Seventh Circuit
Date
15 March 2019
Quoted from
p. 29
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/USCOURTS-ca7-18-01277/pdf/USCOURTS-ca7-18-01277-0.pdf
Accessed
2026-11-09
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Exhibit 458 · Warning letter

Warning Letter to The Jim Bakker Show (MARCS-CMS 604820)

In addition, it is unlawful under the FTC Act, 15 U.S.C. 41 et seq., to advertise that a product can prevent, treat, or cure human disease unless you possess competent and reliable scientific evidence, including, when appropriate, well-controlled human clinical studies, substantiating that the claims are true at the time they are made

Joint letter on silver products marketed for COVID-19. A warning letter, not a court order.

Source
U.S. Food and Drug Administration and Federal Trade Commission
Date
6 March 2020
Quoted from
FTC paragraph near end of letter
Grade
Primary record
Document
https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/jim-bakker-show-604820-03062020
Accessed
2026-11-09
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Note
The FTC took part through this joint letter. No FTC court action was found.

Exhibit 460 · Federal Register rule

SBA Interim Final Rule, Paycheck Protection Program, 85 FR 20811

except that nonprofit organizations authorized under the Act are eligible.

Eligibility includes 501(c)(3) nonprofits; ineligibility list in 13 CFR 120.110 applies 'except that nonprofit organizations authorized under the Act are eligible.'

Source
U.S. Small Business Administration
Date
15 April 2020
Quoted from
para. c, 'How do I determine if I am ineligible?'
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2020-04-15/pdf/2020-07672.pdf
Accessed
2026-11-09
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Exhibit 461 · Federal Register rule

SBA Interim Final Rule, PPP Nondiscrimination and Additional Eligibility Criteria, 85 FR 27287

SBA regulations do not bar a religious nonprofit entity from making decisions with respect to the membership or the employment of individuals of a particular religion

Religious nonprofit borrowers may make membership and employment decisions by religion.

Source
U.S. Small Business Administration
Date
8 May 2020
Quoted from
p. 27288
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2020-05-08/pdf/2020-09963.pdf
Accessed
2026-11-09
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Exhibit 462 · Federal Register proposed rule

SBA Proposed Rule, Ensuring Equal Treatment for Faith-Based Organizations, 86 FR 5036

they categorically disqualify otherwiseeligible faith-based organizations from receiving business loan funds and disaster assistance solely on account of their religious status.

Proposes removing five religious-status exclusions; recounts SBA's 3 Apr 2020 28 U.S.C. 530D letter.

Source
U.S. Small Business Administration
Date
19 January 2021
Quoted from
Background B (text as extracted)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2021-01-19/pdf/2021-00446.pdf
Accessed
2026-11-09
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Exhibit 463 · Federal Register final rule

SBA Final Rule, 13 CFR 120.110(k) removed and reserved, 87 FR 38900

paragraph (k) of section 120.110 should be removed from the Agency's regulations, and reserved

Removes the exclusion of businesses principally engaged in teaching or indoctrinating religion; effective 1 Aug 2022; keeps SBA Form 1971 religious-use worksheet.

Source
U.S. Small Business Administration
Date
30 June 2022
Quoted from
Preamble, response to comments
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2022-06-30/pdf/2022-13483.pdf
Accessed
2026-11-09
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Exhibit 464 · Statute

CARES Act, Pub. L. 116-136, section 1102

any business concern, nonprofit organization, veterans organization, or Tribal business concern described in section 31(b)(2)(C) shall be eligible to receive a covered loan

Creates PPP; makes nonprofit organizations eligible if 500 or fewer employees. Senate passed 96-0 on 25 Mar 2020 (Roll Call 80); approved 27 Mar 2020.

Source
U.S. Congress
Date
27 March 2020
Quoted from
Sec. 1102, new 7(a)(36)(D)(i)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-116publ136/html/PLAW-116publ136.htm
Accessed
2026-11-09
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Exhibit 467 · Loan-level dataset

SBA PPP FOIA loan-level data (files dated 30 Sep 2024)

Queried NAICS 813110 (Religious Organizations): 122,665 loans, $9,311,718,051.36 initial approval, $9,086,744,940.81 forgiven, among 11,468,210 file rows ($796.8 billion). Re-derived from the CSVs on 2026-11-09.

Source
U.S. Small Business Administration
Date
30 September 2024
Grade
Primary record
Document
https://data.sba.gov/dataset/ppp-foia
Accessed
2026-11-09
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Findings citing this exhibit
Note
Aggregate query only, run by this project on the CSV files dated 30 September 2024. NAICS 813110 undercounts faith-based entities. The file has 11,468,210 rows; SBA reports about 11.8 million loans.

Exhibit 468 · Survey report

Spirit and Power: A 10-Country Survey of Pentecostals

God will grant material prosperity to all believers who have enough faith.

U.S. 46 percent of respondents (n=681) agreed; Pentecostals 66, charismatics 59, other Christians 43. Fieldwork US 20 Jul-7 Sep 2006.

Source
Pew Forum on Religion & Public Life (Pew Research Center)
Date
5 October 2006
Quoted from
p. 29 (item f)
Grade
Primary record
Document
https://www.pewresearch.org/wp-content/uploads/sites/7/2006/10/pentecostals-08.pdf
Accessed
2026-11-09
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Exhibit 469 · Court opinion

Walz v. Tax Commission, 397 U.S. 664

Elimination of exemption would tend to expand the involvement of government by giving rise to tax valuation of church property, tax liens, tax foreclosures, and the direct confrontations and conflicts that follow in the train of those legal processes.

Upholds property-tax exemption for houses of worship; 'benevolent neutrality'; elimination would increase entanglement.

Source
U.S. Supreme Court
Date
4 May 1970
Quoted from
Part IV; pin cite to verify
Grade
Primary record
Document
https://www.law.cornell.edu/supremecourt/text/397/664
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Exhibit 470 · Attorney general's report

The Sexual Abuse of Children in the Roman Catholic Archdiocese of Boston

There is overwhelming evidence that for many years Cardinal Law and his senior managers had direct, actual knowledge that substantial numbers of children in the Archdiocese had been sexually abused by substantial numbers of its priests.

Attorney General's report after a 16-month investigation (grand jury, prosecutors, State Police). Reports 789 victims complaining to the Archdiocese and 250 priests and church workers accused over at least six decades; finds institutional acceptance of abuse and failure of leadership; finds no evidence sufficient to charge the Archdiocese or its senior managers under then-applicable law, noting clergy were not mandated reporters until May 2002. Copy used is a third-party host of the AG PDF.

Source
Office of the Attorney General, Commonwealth of Massachusetts (Thomas F. Reilly)
Date
23 July 2003
Quoted from
Finding No. 3, section 1, p. 25
Grade
Primary record
Document
https://www.bishop-accountability.org/resources/resource-files/reports/ReillyReport.pdf
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Exhibit 471 · Commissioned study

The Nature and Scope of Sexual Abuse of Minors by Catholic Priests and Deacons in the United States, 1950-2002

Thus, prior to 1993, only one-third of cases were known to Church officials.

Descriptive study from church records supplied by dioceses, eparchies and religious communities. Counts allegations against 4,392 priests (4.0 percent of 109,694 priests, or 4.3 percent on a CARA base) by 10,667 individuals, 1950-2002. States it cannot determine what share of actual abuse was reported; $472 million paid by the time of the surveys; 1,021 priests reported to police, 384 charged, 252 convicted. Funded by the USCCB; data stripped of identifiers through Ernst & Young.

Source
John Jay College of Criminal Justice for the U.S. Conference of Catholic Bishops (commissioned by the National Review Board)
Date
February 2004 (first printing June 2004)
Quoted from
Executive Summary, p. 5
Grade
Primary record
Document
https://www.usccb.org/sites/default/files/issues-and-action/child-and-youth-protection/upload/The-Nature-and-Scope-of-Sexual-Abuse-of-Minors-by-Catholic-Priests-and-Deacons-in-the-United-States-1950-2002.pdf
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Exhibit 472 · Commissioned study

The Causes and Context of Sexual Abuse of Minors by Catholic Priests in the United States, 1950-2010

Though more than 80 percent of cases now known had already occurred by 1985, only 6 percent of those cases had been reported to the dioceses by that time.

Second John Jay study. Finds incidents rose from the mid-1960s to the late 1970s and declined sharply after 1985; finds substantial reporting delays, institutional handling of allegations focused on the priest and not the victim, and non-transparent diocesan action; reports no single cause and attributes the rise partly to wider social change. Describes a 2006 supplementary report on the 2004 data.

Source
John Jay College of Criminal Justice (Karen J. Terry, principal investigator) for the U.S. Conference of Catholic Bishops
Date
May 2011
Quoted from
Executive Summary, p. 5
Grade
Primary record
Document
https://www.usccb.org/sites/default/files/issues-and-action/child-and-youth-protection/upload/The-Causes-and-Context-of-Sexual-Abuse-of-Minors-by-Catholic-Priests-in-the-United-States-1950-2010.pdf
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Exhibit 473 · Episcopal charter and norms

Charter for the Protection of Children and Young People (revised June 2018; adopted June 2002)

Diocesan/eparchial policy is to provide that for even a single act of sexual abuse of a minor—whenever it occurred—which is admitted or established after an appropriate process in accord with canon law, the offending priest or deacon is to be permanently removed from ministry and, if warranted, dismissed from the clerical state.

Charter adopted by the U.S. bishops in Dallas in June 2002 and revised in 2005, 2011 and 2018. Articles require dioceses to have response procedures and a review board with a lay majority, bar confidentiality settlements unless the victim requests one, require reports to public authorities, and require permanent removal for a single admitted or established act. Text read is the 2018 revision. A June 2026 revision exists.

Source
United States Conference of Catholic Bishops
Date
June 2018 (original June 2002)
Quoted from
Article 5 (2018 revision), pp. 10-11
Grade
Primary record
Document
https://www.usccb.org/resources/Charter-for-the-Protection-of-Children-and-Young-People-2018-final(1).pdf
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Exhibit 474 · Grand jury report

Report 1 of the 40th Statewide Investigating Grand Jury (interim, redacted)

Over one thousand child victims were identifiable, from the church's own records.

Grand jury report on six of Pennsylvania's eight Catholic dioceses (Allentown, Erie, Greensburg, Harrisburg, Pittsburgh, Scranton) after 24 months and review of half a million pages of diocesan documents. Reports credible allegations against more than 300 priests and over 1,000 identifiable child victims; records FBI behavioral analysts' seven recurring diocesan practices; recommends removing the criminal statute of limitations, a two-year civil window and tighter mandated reporting. Released with names of challenging petitioners redacted by order of the Pennsylvania Supreme Court. The PDF also carries diocesan and individual responses.

Source
Pennsylvania 40th Statewide Investigating Grand Jury; Office of Attorney General
Date
14 August 2018
Quoted from
Section I, Introduction, p. 1
Grade
Primary record
Document
http://media-downloads.pacourts.us/InterimRedactedReportandResponses.pdf
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Exhibit 475 · Court opinion

In re Fortieth Statewide Investigating Grand Jury (Grand Jury I), opinion of Chief Justice Saylor

an interim version of the grand jury report will be released, containing temporary redactions solely to protect the identities of those who have lodged challenges before us, pending further order of this Court.

Opinion in petitions by named priests challenging public release of Report 1. Holds that large portions can be released if challengers' identities are protected, and orders an interim report with temporary redactions limited to those who lodged challenges; states the report's targeted condemnation of named individuals is central to the constitutional analysis. 190 A.3d 560 (Pa. 2018).

Source
Supreme Court of Pennsylvania
Date
27 July 2018
Quoted from
Opinion, p. 1 [J-56A-M-2018]
Grade
Primary record
Document
https://www.pacourts.us/Storage/media/pdfs/20210610/013708-file-7211.pdf
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Exhibit 476 · Court opinion

In re Fortieth Statewide Investigating Grand Jury, opinion of Justice Todd (remedy)

we must make permanent the redaction of Petitioners' identifying information from Report 1, which we previously ordered as an interim measure, as this is the only viable due process remedy we may now afford to Petitioners to protect their constitutional rights to reputation.

Decides the remedy question left open in July 2018: concludes no other remedy is available and makes the redaction of the identifying information of the petitioners (11 of the more than 300 priests named in Report 1) permanent.

Source
Supreme Court of Pennsylvania
Date
3 December 2018
Quoted from
Opinion, p. 1 [J-56A-J & L-2018]
Grade
Primary record
Document
https://WWW.PACOURTS.US/Storage/media/pdfs/20210610/013823-file-7473.pdf
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Exhibit 477 · Institutional report

Report on the Holy See's Institutional Knowledge and Decision-Making Related to Former Cardinal Theodore Edgar McCarrick (1930 to 2017)

In June 2017, the Archdiocese of New York learned of the first known allegation of sexual abuse by McCarrick of a victim under 18 years of age, which occurred in the early 1970s.

Vatican report ordered by Pope Francis on 6 October 2018, based on archives and over ninety interviews. Documents what Holy See and U.S. officials knew from the 1990s about allegations concerning adults and young adults, a 2000 inquiry in which three of four New Jersey bishops gave inaccurate or incomplete information, and the decision to appoint him to Washington. The first known allegation of abuse of a minor reached the Archdiocese of New York in June 2017. The report states it does not examine canon-law culpability and does not publish the Acta.

Source
Secretariat of State of the Holy See
Date
10 November 2020
Quoted from
Section I.B, Executive Summary, p. 14
Grade
Primary record
Document
https://www.vatican.va/resources/resources_rapporto-card-mccarrick_20201110_en.pdf
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Exhibit 478 · Papal norms (motu proprio)

Apostolic Letter issued Motu Proprio, Vos estis lux mundi

conduct carried out by the subjects referred to in article 6, consisting of actions or omissions intended to interfere with or avoid civil investigations or canonical investigations, whether administrative or penal, against a cleric or a religious regarding the delicts referred to in letter a) of this paragraph.

Universal norms, in force 1 June 2019 for three years ad experimentum. Require dioceses to set up public reporting systems within a year; oblige clerics and religious to report to the local Ordinary; create a procedure for reports about bishops via the Metropolitan; bar retaliation and imposed silence on reporters; Art. 19 leaves reporting duties to civil authorities to state law.

Source
Pope Francis (Holy See)
Date
7 May 2019
Quoted from
Art. 1 §1(b)
Grade
Primary record
Document
https://www.vatican.va/content/francesco/en/motu_proprio/documents/papa-francesco-motu-proprio-20190507_vos-estis-lux-mundi.html
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Exhibit 479 · Papal norms (motu proprio)

Apostolic Letter issued Motu Proprio, Vos estis lux mundi (updated text)

I promulgated an Apostolic Letter issued Motu Proprio on 7 May 2019 containing norms ad experimentum for three years.

Updated text in force 30 April 2023, abrogating the 2019 letter. Extends the norms to moderators of international associations of the faithful and keeps the duty to report to the Ordinary, with an exception for information learned in the internal forum, and the saving clause for state reporting duties (Art. 20).

Source
Pope Francis (Holy See)
Date
25 March 2023
Quoted from
Preamble
Grade
Primary record
Document
https://www.vatican.va/content/francesco/en/motu_proprio/documents/20230325-motu-proprio-vos-estis-lux-mundi-aggiornato.html
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Exhibit 480 · Commission report

Final Report, Volume 16, Religious institutions, Book 1

We have concluded that there were catastrophic failures of leadership of Catholic Church authorities over many decades, particularly before the 1990s.

Religious institutions volume. Catholic claims data: 4,444 claimants in 4,756 claims to Catholic authorities (1 January 1980 to 2015); 1,880 known alleged perpetrators; 7 percent of Catholic priests who ministered 1950-2010 were alleged perpetrators on a weighted basis; $268.0 million paid on 3,057 claims. Concludes Catholic leaders were aware well before the 1990s and failed to act; reports Anglican, Salvation Army, Uniting, Jehovah's Witness, Pentecostal and Jewish institutions; states its data cannot show incidence or prevalence.

Source
Royal Commission into Institutional Responses to Child Sexual Abuse (Australia)
Date
15 December 2017
Quoted from
Executive Summary, p. 36
Grade
Primary record
Document
https://web.archive.org/web/20190204081943if_/https://www.childabuseroyalcommission.gov.au/sites/default/files/final_report_-_volume_16_religious_institutions_book_1.pdf
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Exhibit 481 · Commission case study report

Report of Case Study No. 29: The response of the Jehovah's Witnesses and Watchtower Bible and Tract Society of Australia Ltd to allegations of child sexual abuse

there is otherwise no evidence before the Royal Commission of the Jehovah's Witness organisation having reported to police or other secular authority a single one of the 1,006 alleged perpetrators of child sexual abuse recorded in the case files held by Watchtower Australia.

From about 5,000 documents Watchtower Australia produced under summons: case files on 1,006 alleged perpetrators since 1950, admissions by 579, at least 1,800 alleged victims, 401 disfellowshipped and 230 later reinstated. Finds no evidence of any report by the organisation to police of the 1,006, and views the two-witness rule as wrong in child sexual abuse cases. Records Watchtower's submissions, including that its review found 383 alleged perpetrators had been dealt with by police or secular authorities.

Source
Royal Commission into Institutional Responses to Child Sexual Abuse (Australia)
Date
October 2016 (public hearing July-August 2015)
Quoted from
Section 6.1, p. 60
Grade
Primary record
Document
https://web.archive.org/web/20250428205125if_/https://www.childabuseroyalcommission.gov.au/sites/default/files/file-list/Case%20Study%2029%20-%20Findings%20Report%20-%20Jehovahs%20Witnesses.pdf
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Exhibit 482 · Commission of investigation report

Commission of Investigation, Report into the Catholic Archdiocese of Dublin (Part 1)

The Dublin Archdiocese's pre-occupations in dealing with cases of child sexual abuse, at least until the mid 1990s, were the maintenance of secrecy, the avoidance of scandal, the protection of the reputation of the Church, and the preservation of its assets.

Examines the response of Church and State authorities to complaints about 46 priests in a representative sample, 1975-2004; 172 named priests came to the Commission's attention. States it had no remit to establish whether abuse occurred. Finds no Archbishop reported knowledge to the Gardai in the 1960s, 1970s or 1980s, names of 17 priests were first given to the Gardai in November 1995, the Archdiocese insured against abuse claims from 1987, and the Gardai and State authorities facilitated the cover-up. Notes improvement from the 1996 Framework Document.

Source
Commission of Investigation (Judge Yvonne Murphy, Ita Mangan, Hugh O'Neill), Ireland
Date
July 2009
Quoted from
Chapter 1, para 1.15, p. 4
Grade
Primary record
Document
https://web.archive.org/web/20121230172108if_/http://www.justice.ie/en/JELR/Part%201.pdf/Files/Part%201.pdf
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Exhibit 483 · Commission report (executive summary)

Report of the Commission to Inquire into Child Abuse, Executive Summary (Ryan Report)

Executive Summary of the five-volume report on industrial and reformatory schools run mostly by Catholic religious congregations. Conclusions 18-26 find sexual abuse endemic in boys' institutions, handled to avoid scandal, with congregation members not reported to the Gardai, offenders transferred, and recidivism known. URL is a UCD reproduction of the official text; the official volumes are at childabusecommission.ie and must be checked before the quote is published.

Source
Commission to Inquire into Child Abuse, Ireland
Date
20 May 2009
Grade
Primary record
Document
https://industrialmemories.ucd.ie/ryan-report/executive-summary
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Exhibit 484 · Commission report (summary)

Summary of the Final Report of the Independent Commission on Sexual Abuse in the Church (CIASE)

Over the greater part of the period studied by the CIASE, its observations show that the Church's attitude could be summarized as one of concealment, relativization or even denial, with only a very recent recognition, dating from 2015, and even then, unequally accepted by dioceses and religious institutions.

Commission set up at the request of the French bishops' and religious conferences. Estimates 216,000 child victims of clergy and religious (95 percent interval 165,000 to 270,000) from 1950 to 2020 from a survey of 28,010 adults, 330,000 including lay persons connected to the Church; estimates 2,900 to 3,200 clerical perpetrators from archives, about 3 percent as a minimum rate; places Church-related abuse beside rates in the family, schools and camps. Finds the Church's attitude was concealment, relativization or denial over most of the period.

Source
Independent Commission on Sexual Abuse in the Church (CIASE), France
Date
5 October 2021
Quoted from
Summary, section III, p. 11
Grade
Primary record
Document
https://www.ciase.fr/wordpress/wp-content/uploads/CIASE-Summary-of-the-Final-Report-5-october-2021.pdf
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Exhibit 485 · Commissioned study (summary, unauthorized translation)

Sexual abuse of minors by Catholic priests, deacons and male members of orders in the domain of the German Bishops' Conference (MHG Study), Summary

Review of 38,156 personnel records from all 27 dioceses, 1946-2014: allegations against 1,670 clerics (4.4 percent) and 3,677 children and juveniles. States the team had no access to original files (diocesan staff or law firms reviewed them), that figures underestimate the actual situation, and that files had been destroyed or manipulated. Copy is the bishops' conference secretariat's rough English translation, not authorized by the consortium; quote-check against the German study at dbk.de.

Source
Mannheim-Heidelberg-Giessen research consortium for the German Bishops' Conference
Date
25 September 2018
Grade
Primary record
Document
https://www.bishop-accountability.org/wp-content/uploads/2023/02/reports-2018-09-25-MHG-Study-English-Summary.pdf
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Exhibit 486 · Public inquiry report

The Roman Catholic Church: Investigation Report

Responses to disclosures about sexual abuse have been characterised by a failure to support victims and survivors in stark contrast to the positive action taken to protect alleged perpetrators and the reputation of the Church.

Reports over 900 complaints involving over 3,000 instances of abuse against over 900 individuals, 1970-2015 (from a Church-commissioned review), with 177 prosecutions and 133 convictions; says the true scale is likely much higher and that more than 100 allegations a year were reported since 2016. Finds the Church prioritized its reputation; records progress after the Nolan (2001) and Cumberlege (2007) reports. Copy is a diocesan host of the IICSA PDF; official copy at iicsa.org.uk.

Source
Independent Inquiry into Child Sexual Abuse (IICSA), England and Wales
Date
10 November 2020
Quoted from
Executive Summary, p. vi
Grade
Primary record
Document
https://salisburycatholics.org/sites/salisbury/files/catholic-church-investigation-report-10-november-2020.pdf
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Exhibit 487 · Public inquiry report

The Anglican Church: Investigation Report

The culture of the Church of England facilitated it becoming a place where abusers could hide.

Church of England and Church in Wales. Reports 390 convicted offenders associated with the Church from the 1940s to 2018, 449 concerns reported in 2018, and 217 insurance claims managed 2003-2018; finds a culture in which abusers could hide, senior clergy prioritizing reputation and declining to report to statutory agencies, and safeguarding that was not properly resourced until at least 2015. Page references are to the 2022 HC 646 Volume 5 reprint.

Source
Independent Inquiry into Child Sexual Abuse (IICSA), England and Wales
Date
6 October 2020
Quoted from
Executive Summary, p. vi
Grade
Primary record
Document
https://assets.publishing.service.gov.uk/media/63176fdfe90e070543c07ce4/E02733227_HC_646_IICSA_Inv_Report_Combined_Volume_5_ELAY.pdf
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Exhibit 488 · Public inquiry report

Child protection in religious organisations and settings: Investigation Report (HC 705)

Precise and reliable evidence about the scale of child sexual abuse within religious organisations and settings is not currently available.

Evidence from 38 religious organisations covering Buddhism, Hinduism, Islam, Judaism, new religious movements, non-conformist and non-trinitarian Christian organisations, Paganism and Sikhism. Finds no reliable data on the scale of abuse in religious settings, barriers to reporting in some organisations, uneven child protection policies and no effective oversight; records support among organisations for some form of mandatory reporting.

Source
Independent Inquiry into Child Sexual Abuse (IICSA), England and Wales
Date
September 2021
Quoted from
Executive Summary, p. v
Grade
Primary record
Document
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1026348/Religious-settings-IICSA-investigation.pdf
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Exhibit 489 · Independent investigation report

Report of the Independent Investigation: The Southern Baptist Convention Executive Committee's Response to Sexual Abuse Allegations and an Audit of the Procedures and Actions of the Credentials Committee

a few senior EC leaders, along with outside counsel, largely controlled the EC's response to these reports of abuse. They closely guarded information about abuse allegations and lawsuits, which were not shared with EC Trustees, and were singularly focused on avoiding liability for the SBC to the exclusion of other considerations.

288-page investigation of January 2000 to June 2021, about 330 interviews and over five terabytes of data. Finds a few senior Executive Committee leaders and outside counsel controlled the response and focused on avoiding liability; counsel advised staff not to elicit further information so the Committee would not assume a legal duty; a staff member kept a list of accused ministers from 2007 (latest version 703 names, 409 believed SBC-affiliated) with no action taken; a 2007 database proposal was rejected in 2008. Of the list, investigators found nine in active ministry or connected to ministry, two apparently with SBC churches. Copy is a Baptist state paper's host; sbc.net copy to be located.

Source
Guidepost Solutions, for the SBC Sexual Abuse Task Force
Date
22 May 2022 (cover dated 15 May 2022)
Quoted from
Executive Summary, p. 3
Grade
Primary record
Document
https://thebaptistpaper.org/wp-content/uploads/2022/05/GuidepostSolutionsIndependentInvestigationReport.pdf
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Exhibit 490 · Task force report

The Future of Abuse Reform in the SBC: The ARITF's 2024 Report & Recommendations

To date, the SBC has contributed zero funding toward the vetting of names for Ministry Check.

Task force reports on its mandate from the 2022 and 2023 annual meetings: expanded Ministry Toolkit, a Ministry Check offender website not yet launched because of Executive Committee legal and insurance concerns (about 100 names vetted, categories limited to criminal convictions and civil liability findings), and no permanent home for abuse prevention and response. Recommends the Executive Committee recommend a structure and funding and report to the 2025 meeting.

Source
Abuse Reform Implementation Task Force, Southern Baptist Convention
Date
June 2024
Quoted from
Footnote 8, p. 5
Grade
Primary record
Document
https://www.baptistpress.com/wp-content/uploads/2024/06/THE-ARITFS-2024-REPORT-RECOMMENDATIONS-.pdf
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Exhibit 491 · News report

Abuse database is no longer a priority for Southern Baptist leaders

Religion News Service reports that the Executive Committee president said at the 18 February 2025 Executive Committee meeting that the database was not a focus.

Source
Religion News Service
Date
18 February 2025
Grade
Reported
Document
https://religionnews.com/2025/02/18/abuse-database-is-no-longer-a-priority-for-southern-baptist-leaders/
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Note
Baptist Press, through Illinois Baptist (12-13 March 2025), quotes Jeff Iorg that the database is 'not so much on the back burner' and cites legality and insurance hurdles.

Exhibit 492 · News report

DOJ closes investigation of SBC

The U.S. Attorney’s Office for the Southern District of New York informed us that the investigation into the Southern Baptist Convention and Executive Committee has officially concluded

Reports that on 12 March 2025 the U.S. Attorney's Office for the Southern District of New York informed SBC attorneys that its investigation of the Southern Baptist Convention and Executive Committee had concluded without charges.

Source
Illinois Baptist (relaying statement of SBC attorneys to Baptist Press)
Date
March 2025
Quoted from
Baptist Press story, 12 Mar 2025 (updated 3/13), paragraph 4, statement by SBC attorneys Gene Besen and Scarlett Nokes
Grade
Reported
Document
https://illinoisbaptist.org/doj-closes-investigation-of-sbc/
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Exhibit 493 · Council canon (in translation)

Council of Toulouse, canon 14 (1229)

We prohibit also that the laity should be permitted to have the books of the Old or the New Testament; unless anyone from motives of devotion should wish to have the Psalter or the Breviary for divine offices or the hours of the blessed Virgin; but we most strictly forbid their having any translation of these books.

Canon 14 forbids lay people to have the books of the Old or New Testament, with an exception for a Psalter, a breviary or the Hours of the Virgin for devotion, and forbids their having translations of these books. The same council's canons 1, 6, 10 and 11 order parish searches for heretics, destruction of houses where heretics are found, and marked clothing for penitents.

Source
Council of Toulouse (provincial council, Bishop Folquet de Marselha)
Date
1229
Quoted from
Canon 14, in Peters, Heresy and Authority in Medieval Europe (Penn, 1980), no. 37, p. 195 (translation after S. R. Maitland, Facts and Documents, 1832, pp. 192-94)
Grade
Primary record
Document
https://archive.org/details/factsdocumentsil00mait
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Note
English wording is Peters's. The Latin of canon XIV is printed in Maitland's Authorities appendix (from Labbe, Concilia XI pt 1, col. 427); its second sentence reads 'in vulgari translatos', that is, translated into the vernacular. Peters p. 191 groups this council with Tarragona 1242 as 'extreme condemnations of heresy'.

Exhibit 494 · Provincial constitutions (in translation)

Constitutions of Archbishop Thomas Arundel against the Lollards (Constitutions of Oxford), 1407-1409

therefore we enact and ordain that no one henceforth do by his own authority translate any text of Holy Scripture into the English tongue or any other by way of book, pamphlet, or treatise.

Constitution 7 forbids anyone to translate a text of Scripture into English on his own authority and forbids reading any such translation, already made or to be made, until the diocesan or a provincial council approves it, under the greater excommunication. Constitution 1 requires a diocesan license to preach; constitution 6 bars Wycliffe's books from the schools; constitution 12 bars offenders from benefices for three years.

Source
Thomas Arundel, Archbishop of Canterbury, with the clergy of the Province of Canterbury
Date
1407-1409 (Oxford 1407/8; ratified at St Paul's, London, 14 January 1408/9)
Quoted from
Constitution 7 (trans. J. Johnson, 1851, rev. M. Marlowe; Latin in Wilkins, Concilia III, p. 317)
Grade
Primary record
Document
https://bible-researcher.com/arundel.html
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Note
Also printed, with the Latin of constitution 7 from Lyndwood's Provinciale and Wilkins and a modern translation, in Pollard, Records of the English Bible (1911), Record I, pp. 79-81. Dating differs between sources (1407, 1408, 1409); Pollard gives Oxford 1408 and St Paul's 14 Jan 1408-9. Further quotes read: reason ('a dangerous thing; as blessed Jerome testifies, because it is not easy to make the sense in all respects the same'), approval clause, and constitution 1's license 'gratis'. Pollard, Records of the English Bible (1911), p. 80 n. and intro p. 3, states that licenses came to be granted to specified readers and that a license could be procured; this is a 1911 editor's gloss and is not quoted.

Exhibit 495 · Statute (modern-spelling text)

Statute De heretico comburendo, 2 Henry IV c. 15

that none from henceforth anything preach, hold, teach, or instruct openly or privily, or make or write any book contrary to the catholic faith or determination of the Holy Church

Forbids preaching without the diocesan's license and making or writing books contrary to the Catholic faith, requires holders of such books to deliver them to the diocesan within forty days, lets the diocesan arrest suspects, and orders the sheriff to burn before the people anyone convicted who refuses to abjure or relapses. The statute does not mention translating Scripture.

Source
Parliament of England (Henry IV)
Date
1401
Quoted from
Statutes of the Realm II, p. 125 (text as transcribed by R. Potter; also Gee and Hardy, Documents Illustrative of English Church History, 1896, no. XL; Peters no. 44)
Grade
Primary record
Document
https://w3.ric.edu/faculty/rpotter/heretico.html
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Note
The recital gives the stated reason: heretics 'usurping the office of preaching' and holding schools, with diocesans unable 'without aid of the said royal majesty' to correct them.

Exhibit 496 · Episcopal mandate (printed in Foxe, 1563)

Bishop Tunstall's mandate calling in English New Testaments

all and singular such books conteyning the translation of the new testament in the English tongue

Orders the archdeacons to require, within thirty days, delivery to the bishop's vicar-general of all books containing the New Testament translated into English, under excommunication and suspicion of heresy, and states the reason as translators 'maintainers of Luther's sect' mixing heretical articles into the text.

Source
Cuthbert Tunstall, Bishop of London
Date
24 October 1526
Quoted from
Pollard, Records of the English Bible (1911), Record XV, p. 134 (English version printed in Foxe, Acts and Monuments, 1563, pp. 449-50)
Grade
Reported
Document
https://archive.org/details/recordsofenglish00polluoft
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Note
Known through Foxe's 1563 printing, 37 years later; Pollard corrected obvious misprints. Latin date reads 24 October; the English version reads 'xxiii'.

Exhibit 497 · Royal proclamation

Royal proclamation against erroneous books and the having of Scripture in English, French or Dutch, June 1530

the distribution of the sayd scripture, and the permyttyng or denyenge therof, dependeth onely vpon the discretion of the superiours, as they shall thynke it conuenyent

Condemns named English books printed abroad, orders delivery to the bishop within fifteen days, forbids printing English books on Scripture without the diocesan's examination and approval, states that the people need not have Scripture in English and that its distribution depends on the discretion of the superiors, and forbids having the New or Old Testament in English except persons appointed by the king and bishops for correcting the translation. Promises a translation by learned and Catholic persons if the people abandon the condemned books.

Source
Henry VIII (printed by Thomas Berthelet)
Date
June 1530
Quoted from
Pollard, Records of the English Bible (1911), Record XXII, p. 167 (copy printed by Berthelet, British Museum)
Grade
Primary record
Document
https://archive.org/details/recordsofenglish00polluoft
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Note
Pollard dates it 'Mense Junii' 1530 (22 Henry VIII); other websites give 6 May or 22 June. Pollard n., p. 165: the 24 May 1530 'Publick Instrument' (Wilkins, Concilia III, 728) condemned the books and 'the translation also of Scripture corrupted by William Tyndall'. Pollard dates it "Mense Junii" 1530; other sources give 6 May or 22 June.

Exhibit 498 · Printed preface by the translator

William Tyndale, preface to Genesis, 'W. T. To the Reader' (Pentateuch, 1530)

some that it is not lawfull for the laye people to have it in their mother tonge

Tyndale reports that opponents say it is impossible to translate Scripture into English, or not lawful for lay people to have it in their mother tongue, or that it would make them heretics; that he sought a place in the Bishop of London's house, was told it was full, and learned there was no place in England to translate the New Testament; and that he will submit his work to correction if his critics first put forth a more correct translation of their own. He also attributes the opposition to the clergy's wish to keep the people ignorant, which is his allegation.

Source
William Tyndale
Date
1530
Quoted from
Pollard, Records of the English Bible (1911), Record V, p. 93; compare p. 98 ('there was no place to do it in all englonde')
Grade
Primary record
Document
https://archive.org/details/recordsofenglish00polluoft
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Note
Tyndale's statement of his own experience and of his opponents' arguments.

Exhibit 499 · State letter

Stephen Vaughan to Henry VIII, reporting Tyndale's terms (Barroughe, 20 May 1531)

graunte only a bare text of the scriptures

Vaughan reports that Tyndale, shown Cromwell's offer of mercy if he would return, said that if the king would grant a bare text of the Scriptures to be put forth among his people, in a translation of whomever the king pleased, he would write no more and return to submit himself.

Source
Stephen Vaughan (English envoy)
Date
20 May 1531
Quoted from
Pollard, Records of the English Bible (1911), Record XXIII, pp. 170-71 (Cotton MS Galba B. x, 5; brackets in the printed text are Pollard's restorations)
Grade
Primary record
Document
https://archive.org/details/recordsofenglish00polluoft
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Note
Vaughan's report of what Tyndale said; Tyndale's own letter to Vaughan is in State Papers v. 65.

Exhibit 500 · Letter

Thomas Cranmer to Thomas Cromwell, 4 August [1537], requesting the king's license for the Matthew Bible

a license that the same may be sold and redde of euery person, withoute danger of any acte, proclamacion, or ordinaunce hertofore graunted to the contrary

Cranmer sends Cromwell an English Bible of a new translation, dedicated to the king, and asks him to obtain the king's license that it may be sold and read by every person without danger of any earlier act, proclamation or ordinance, until the bishops produce a better translation.

Source
Thomas Cranmer, Archbishop of Canterbury
Date
4 August 1537
Quoted from
Pollard, Records of the English Bible (1911), Record XXXIII A, pp. 214-15 (original in the Record Office; Letters and Papers Henry VIII xii pt 2, no. 434)
Grade
Primary record
Document
https://archive.org/details/recordsofenglish00polluoft
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Note
Pollard (introduction, p. 16) says the 'Matthew' Bible was largely the work of Tyndale and Coverdale. Quote only the letter. Cranmer's words "till a day after domesday" are at Pollard Rec. XXXIII A. Pollard, intro p. 16, states the Matthew Bible was largely Tyndale's work.

Exhibit 501 · Royal injunctions

Second Royal Injunctions of Henry VIII (Cromwell), 1538

the charges of which boke shal be ratablie born between you the parson, and the parishners aforsaid, that ys to say, the one half by yowe, and th'other half by them

Every parish must set up an English Bible of the largest volume in the church, with the cost shared half by the parson and half by the parishioners, and must not discourage anyone from reading or hearing it, while referring the explanation of obscure places to men of higher judgment.

Source
Thomas Cromwell, vicegerent for Henry VIII
Date
September-October 1538
Quoted from
Pollard, Records of the English Bible (1911), Record XLIII, p. 262 n. (from Reg. Cranmer fol. 99b; Wilkins III, 815); also Gee and Hardy no. LXIII, pp. 275-76
Grade
Primary record
Document
https://archive.org/details/recordsofenglish00polluoft
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Gee and Hardy date the Second Injunctions to 1538 (Cromwell's letter of 30 September; Cranmer's mandate of 11 October); Wilkins prints them under 1536, which Pollard calls probably two years too early. A parallel quote read: 'discorage no man pryuely or apertly from the readinge or hearing of the same Bible'.

Exhibit 502 · Royal proclamation

Royal proclamation of 16 November 1538 on importing and printing English books

Item that no persone or persons in this realme, shall from hensforth print any boke in the englyshe tonge, onles vpon examination made by some of his gracis priuie counsayle, or other suche as his highnes shall appoynte, they shall haue lycence so to do

Forbids importing English books without the king's license; forbids printing any English book, and any English book of Scripture, unless examined and admitted by the king, a privy councillor or a bishop, with the examiner's name printed; forbids marginal notes or prologues unless allowed; penalty forfeiture of goods and imprisonment at the king's pleasure.

Source
Henry VIII (printed by Thomas Berthelet)
Date
16 November 1538
Quoted from
Pollard, Records of the English Bible (1911), Record XXXVII, p. 241
Grade
Primary record
Document
https://archive.org/details/recordsofenglish00polluoft
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Note
The licensing came three weeks after the Great Bible's printing was under way in Paris; Pollard (introduction, p. 18) reads it as aimed at preventing a repeat of the 1537 episode.

Exhibit 503 · Royal proclamation

Royal proclamation of 6 May 1541 ordering the Bible of the largest volume in every church

for euery moneth that they shall lacke and want the sayde Bybles, after the same feast of Alsayntes fourty shyllynges

Orders curates and parishioners to buy a Bible of the largest volume for each church at their own cost; readers are to read humbly and not aloud during the Mass or dispute the mysteries; a parish without the Bible forfeits forty shillings a month, half to the king and half to whoever first presents the default; the price is capped at ten shillings unbound and twelve bound.

Source
Henry VIII (printed by Richard Grafton and Edward Whitchurch, 'Cum privilegio ad imprimendum solum')
Date
6 May 1541
Quoted from
Pollard, Records of the English Bible (1911), Record XLIII, p. 264
Grade
Primary record
Document
https://archive.org/details/recordsofenglish00polluoft
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Price cap: 'the pryce of ten shyllynges' unbound, 'twelue shyllynges' bound (p. 264).

Exhibit 504 · Convocation record (in abridged translation)

Convocation of Canterbury on the Great Bible (Wilkins, Concilia III, 860), 1542-43

The Archbishop, speaking for the king, told Convocation that the English Old and New Testaments needed reform; a majority resolved that the Great Bible could not be retained until duly purged and compared with the Latin Bible commonly read in the English Church; committees were set to examine it.

Source
Convocation of the Province of Canterbury
Date
January-February 1543
Grade
Primary record
Document
https://archive.org/details/recordsofenglish00polluoft
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2026-11-09
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Note
Pollard, Records of the English Bible (1911), Record XLV, pp. 272-74 (Pollard's abridged translation of Wilkins's Latin); wording not quoted.

Exhibit 505 · Statute

Act for thadvauncement of true Religion and for thabbolisshment of the contrarie, 34 & 35 Henry VIII c. 1

no woomen nor artificers prentises journeymen serving men of the degrees of yeomen or undre, husbandemen nor laborers shall reade within this Realme

Abolishes books of the Old and New Testament in English of Tyndale's translation and requires annotations in other English Bibles to be cut out; bars anyone not appointed by the king or an ordinary from reading or teaching the Bible in English in church; forbids women, artificers, apprentices, journeymen, serving men of the degree of yeomen or under, husbandmen and laborers to read the Bible or New Testament in English, privately or openly, on pain of one month's imprisonment; exempts noblemen and gentlemen householders and merchant householders; gives half of penalties to those who detect and sue.

Source
Parliament of England (Henry VIII)
Date
1543 (session 1542-43)
Quoted from
Statutes of the Realm III, pp. 894-96 (the reading clause is on p. 896; page numbers read from the OCR)
Grade
Primary record
Document
https://archive.org/details/the-statutes-of-the-realm-3
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Note
Preamble also says the king had granted 'the greate libertie ... of having ... in theyre handes the Newe and Olde Testament' and that the lower sort had abused it.

Exhibit 506 · Statute

Act for the Absolute Restraint of Annates and Election of Bishops, 25 Henry VIII c. 20

shall with all speed and celerity in due form elect and choose the said person named in the said letters missive

Ends payments of annates and first fruits to Rome; at each vacancy the king grants the chapter a license to elect with a letter missive naming the person, whom the chapter must elect and none other; if the chapter delays beyond twelve days the king nominates by letters patent.

Source
Parliament of England (Henry VIII)
Date
1534
Quoted from
Gee and Hardy, Documents Illustrative of English Church History (1896), no. LII, p. 205 (from Statutes of the Realm III, 462)
Grade
Primary record
Document
https://archive.org/details/documentsillustr00geehuoft
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Gee's headnote: the election clause was repealed by 1 Edw. VI c. 2, which substituted direct nomination.

Exhibit 507 · Statute

Act of Supremacy, 26 Henry VIII c. 1

Declares the king and his successors the only supreme head on earth of the Church of England, called Anglicana Ecclesia, with the title, honours, jurisdictions, profits and commodities of that dignity, and full power to visit, repress, redress, reform, order, correct, restrain and amend all errors, heresies, abuses, offences, contempts and enormities.

Source
Parliament of England (Henry VIII)
Date
November 1534
Grade
Primary record
Document
https://archive.org/details/the-statutes-of-the-realm-3
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2026-11-09
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Note
Gee and Hardy no. LV, pp. 243-44; Statutes of the Realm III, 492 (original spelling: 'the onely supreme [heed'] in erthe of the Churche of England callyd Anglicana Ecclesia')

Exhibit 508 · Statute

Act concerning the payment of First Fruits and an annual tenth of the possessions of the Church, 26 Henry VIII c. 3

An Acte concerninge the paiment of Firste Fruites of all dignities benefices

Title: an Act concerning the payment of first fruits of all dignities, benefices and spiritual promotions, and an annual pension of the tenth part of all the possessions of the Church, granted to the king and his heirs.

Source
Parliament of England (Henry VIII)
Date
1534
Quoted from
Statutes of the Realm III, p. 493 (title; OCR)
Grade
Primary record
Document
https://archive.org/details/the-statutes-of-the-realm-3
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Exhibit 509 · Statute

Act restoring ancient jurisdiction (Elizabethan Act of Supremacy), 1 Elizabeth c. 1

the queen's highness is the only supreme governor of this realm

Annexes ecclesiastical jurisdiction to the Crown; the queen may appoint commissioners by letters patent to exercise it; all archbishops, bishops, ecclesiastical persons, judges, mayors and everyone in royal pay must swear the queen is 'only supreme governor' in spiritual and temporal causes, on pain of losing their offices; limits what commissioners may adjudge to be heresy to what Scripture, the first four general councils, or Parliament with Convocation determine.

Source
Parliament of England (Elizabeth I)
Date
1559
Quoted from
Gee and Hardy no. LXXIX, p. 449 (oath); pp. 447-48 (commissions); p. 455 (limit on heresy)
Grade
Primary record
Document
https://archive.org/details/documentsillustr00geehuoft
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Exhibit 510 · Statute

Elizabethan Act of Uniformity, 1 Elizabeth c. 2

shall lose and forfeit to the queen's highness, her heirs and successors, for his first offence, the profit of all his spiritual benefices or promotions coming or arising in one whole year next after his conviction

Requires all ministers to use the Book of Common Prayer; a convicted minister who refuses forfeits a year's profit of his benefices and is imprisoned six months, with life imprisonment on a third offence; requires every person to attend the parish church on Sundays and holy days on pain of censure and a twelve-pence forfeit levied by the churchwardens for the poor; bishops and justices share enforcement.

Source
Parliament of England (Elizabeth I)
Date
1559
Quoted from
Gee and Hardy no. LXXX, p. 460 (from Statutes of the Realm IV pt 1, p. 355); attendance clause p. 463
Grade
Primary record
Document
https://archive.org/details/documentsillustr00geehuoft
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Exhibit 511 · Royal injunctions

Injunctions of Elizabeth, 1559

no manner of person shall print any manner of book or paper, of what sort, nature, or in what language soever it be, except the same be first licensed by her majesty by express words in writing, or by six of her privy council

Parishes must provide the whole Bible of the largest volume in English and the clergy must not discourage reading; no one may print any book or paper unless licensed by the queen, six privy councillors, or specified bishops and chancellors.

Source
Elizabeth I
Date
1559
Quoted from
Gee and Hardy no. LXXVIII, pp. 436-37 (Injunction 51; contemporary print, BM 5155.a.14)
Grade
Primary record
Document
https://archive.org/details/documentsillustr00geehuoft
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The Bible-in-church injunction is at p. 421; cost 'by the parson or proprietary and parishioners borne by equal portions' (bracketed in Gee).

Exhibit 512 · Statute

Act for the well Governing and Regulating of Corporations, 13 Charles II stat. 2 c. 1

taken the Sacrament of the Lords Supper according to the Rites of the Church of England

Requires municipal officers to take the oaths and a declaration and, afterwards, no one to be elected to those offices who has not within the year taken the sacrament of the Lord's Supper according to the rites of the Church of England; the preamble aims that the succession in corporations be 'perpetuated in the hands of persons well affected to His Majesty and the established Government'.

Source
Parliament of England (Charles II)
Date
1661
Quoted from
Statutes of the Realm V, p. 323 (OCR)
Grade
Primary record
Document
https://archive.org/details/statutes_of_the_realm_5
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Exhibit 513 · Statute

Act for restraining Non-Conformists from inhabiting in Corporations (Five Mile Act), 17 Charles II c. 2

upon forfeiture of every such offence the summe of Forty pounds of lawfull English money

Bars ministers who have not given unfeigned assent to the Book of Common Prayer from coming within five miles of any corporate town or of their former parish unless they take a non-resistance oath, on penalty of forty pounds, divided in thirds among the king, the parish poor and whoever sues.

Source
Parliament of England (Charles II)
Date
1665
Quoted from
Statutes of the Realm V (17 Car. II c. 2; page not read)
Grade
Primary record
Document
https://archive.org/details/statutes_of_the_realm_5
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Note
Page number to be added from the page image.

Exhibit 514 · Statute

Second Conventicle Act, 22 Charles II c. 1

And the other third part thereof to the Informer and Informers and to such person and persons as the said Justice, Justices or cheife Magistrate respectively shall appoint haveing reguard to their diligence and industry in the discovery, disperseing and punishing of the said Conventicles

Penalises presence, at fifth-person meetings 'under colour or pretence of any exercise of religion' other than the Church of England's liturgy, with fines of five and ten shillings, twenty pounds for a preacher or a householder who allows it, and one third of the fines to informers according to their diligence.

Source
Parliament of England (Charles II)
Date
1670
Quoted from
Statutes of the Realm V, pp. 648-49 (OCR); also Gee and Hardy no. CXIX, pp. 623-27
Grade
Primary record
Document
https://archive.org/details/statutes_of_the_realm_5
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The meeting definition quote: 'under colour or pretence of any Exercise of Religion in other manner then according to the Liturgy and practice of the Church of England'. Preamble names 'Seditious Sectaries' who 'contrive Insurrections'; repealed for those taking the oaths by the Toleration Act 1689.

Exhibit 515 · Statute

Act for preventing Dangers which may happen from Popish Recusants (Test Act), 25 Charles II c. 2

shall be ipso facto adjudged uncapeable and disabled in Law to all intents and purposes whatsoever to have occupy or enjoy the said Office

Requires all holders of civil or military office or royal pay to take the oaths of supremacy and allegiance and receive the sacrament according to the usage of the Church of England within three months, with a certificate signed by the minister and churchwarden; those who refuse are disabled from the office, and one who acts anyway is barred from suing, from guardianship and legacies and forfeits five hundred pounds.

Source
Parliament of England (Charles II)
Date
1673
Quoted from
Statutes of the Realm V, pp. 782-83 (OCR)
Grade
Primary record
Document
https://archive.org/details/statutes_of_the_realm_5
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Note
The title and preamble name popish recusants; the sacramental test applied to every officeholder.

Exhibit 516 · Statute

Toleration Act, 1 William and Mary c. 18

paying of tithes or other parochial duties, or any other duties to the church or minister, nor from any prosecution in any ecclesiastical court or elsewhere, for the same

Excuses Protestant dissenters who take the oaths and subscribe the declaration from the penalty statutes on attendance and conventicles, but saves tithes, parochial duties and prosecution in the ecclesiastical courts for them.

Source
Parliament of England (William and Mary)
Date
24 May 1689
Quoted from
Gee and Hardy no. CXXIII, pp. 657-58 (from Statutes of the Realm VI, 74)
Grade
Primary record
Document
https://archive.org/details/documentsillustr00geehuoft
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Preamble: 'some ease to scrupulous consciences in the exercise of religion may be an effectual means to unite their majesties' Protestant subjects in interest and affection'.

Exhibit 517 · Statute

Act repealing the sacramental qualification for certain offices, 9 George IV c. 17

An Act for repealing so much of several Acts as imposes the Necessity of receiving the Sacrament of the Lord’s Supper as a Qualification for certain Offices and Employments.

Repeals the parts of the 1661 Corporation Act, the 1673 Test Act and a 1743 indemnity Act that required officeholders to receive the sacrament according to the Church of England, and substitutes a declaration.

Source
Parliament of the United Kingdom
Date
9 May 1828
Quoted from
9 Geo. IV c. 17, long title (9 May 1828)
Grade
Primary record
Document
https://www.legislation.gov.uk/ukpga/Geo4/9/17/pdfs/ukpga_18280017_en.pdf
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Exhibit 518 · Statute

Act for the Commutation of Tithes in England and Wales, 6 & 7 William IV c. 71

a Sum of Money equal in Value, according to the Prices ascertained by the then next preceding Advertisement, to the Quantity of Wheat, Barley, and Oats respectively mentioned therein to be payable instead of the said Tithes, in the Nature of a Rent-charge issuing out of the Lands charged therewith

Commutes tithes in each parish into a yearly money rentcharge issuing out of the land, valued by a seven-year average to 1835 and varying with the price of wheat, barley and oats, recoverable by distress; one of the three commissioners is appointed by the Archbishop of Canterbury and two by a Secretary of State.

Source
Parliament of the United Kingdom
Date
18 August 1836
Quoted from
s. LXVII, pp. 605-06 (OCR of the King's Printer copy; margin notes interleaved in the OCR)
Grade
Primary record
Document
https://www.legislation.gov.uk/ukpga/Will4/6-7/71/pdfs/ukpga_18360071_en.pdf
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Note
The Act did not end compulsory payment. Commissioners: s. I.

Exhibit 519 · Statute

Compulsory Church Rate Abolition Act 1868, 31 & 32 Victoria c. 109

No suit shall be instituted or proceeding taken in any ecclesiastical or other court, or before any justice or magistrate to enforce or compel the payment of any church rate made in any parish or place in England or Wales.

Ends suits and proceedings to enforce or compel payment of any church rate in England and Wales.

Source
Parliament of the United Kingdom
Date
31 July 1868
Quoted from
s. 1
Grade
Primary record
Document
https://www.legislation.gov.uk/ukpga/Vict/31-32/109
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Exhibit 520 · Statute

Tithe Act 1936, 26 Geo. 5 & 1 Edw. 8 c. 43

all tithe rentcharge shall be extinguished on the second day of October, nineteen hundred and thirty-six

Extinguishes tithe rentcharge on 2 October 1936, compensates the owners with stock and charges landowners redemption annuities.

Source
Parliament of the United Kingdom
Date
31 July 1936
Quoted from
s. 1 (as enacted); Part I heading 'Extinguishment, Compensation by issue of Stock, Charge of Redemption Annuities'
Grade
Primary record
Document
https://www.legislation.gov.uk/ukpga/Geo5and1Edw8/26/43/section/1/enacted
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2026-11-09
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Exhibit 521 · Statute

Finance Act 1977, section 56 (annuities under the Tithe Acts 1936 and 1951)

as from 2nd October 1977 all annuities then charged under those Acts shall be extinguished

Doubles the 1 October 1977 payment and extinguishes all remaining tithe redemption annuities from 2 October 1977.

Source
Parliament of the United Kingdom
Date
1977
Quoted from
s. 56 (as enacted)
Grade
Primary record
Document
https://www.legislation.gov.uk/ukpga/1977/36/section/56/enacted
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Exhibit 522 · Legislative journal

Journal of the House of Delegates, 11 November 1784 (resolution on a tax for the Christian religion)

Resolved, that it is the opinion of this committee , That the people of this Commonwealth, according to their respectful abilities, ought to pay a moderate tax or contribution, annually, for the support of the christian religion

A committee-of-the-whole resolution that the people ought to pay a moderate annual tax for the support of the Christian religion or of some Christian church was agreed by 47 to 32; the same page records a Baptist petition against the marriage and vestry laws.

Source
Virginia House of Delegates
Date
11 November 1784
Quoted from
Journal of the House of Delegates (1784-1785), pp. 18-19 (Encyclopedia Virginia transcription)
Grade
Primary record
Document
https://encyclopediavirginia.org/primary-documents/tax-on-religion-an-excerpt-from-the-journal-of-the-house-of-delegates-1784/
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Exhibit 523 · Petition

James Madison, Memorial and Remonstrance against Religious Assessments

During almost fifteen centuries has the legal establishment of Christianity been on trial.

Argues against the 1784 bill establishing a provision for teachers of the Christian religion; paragraph 7 says experience shows establishments have had a contrary effect on religion.

Source
James Madison (petition to the Virginia General Assembly)
Date
20 June 1785
Quoted from
Paragraph 7 (Papers of James Madison 8:298-304)
Grade
Primary record
Document
https://press-pubs.uchicago.edu/founders/documents/amendI_religions43.html
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2026-11-09
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Advocacy text; report as his argument.

Exhibit 524 · Statute

An Act for establishing religious Freedom (Virginia Statute for Religious Freedom)

no man shall be compelled to frequent or support any religious worship, place, or ministry whatsoever

Enacts that no man shall be compelled to frequent or support any religious worship, place or ministry; declares in the preamble that compelling contributions for opinions one disbelieves is sinful and tyrannical and that forcing support of a particular teacher deprives a man of the liberty of giving to the pastor he chooses and withdraws from the ministry rewards proceeding from approbation of their conduct.

Source
Virginia General Assembly
Date
16 January 1786 (signed 19 January)
Quoted from
Enacting clause, page 2 of the enrolled bill (Library of Virginia; Encyclopedia Virginia transcription, 'some spelling has been modernized')
Grade
Primary record
Document
https://encyclopediavirginia.org/primary-documents/an-act-for-establishing-religious-freedom-1786/
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2026-11-09
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Preamble quotes also read: 'to compel a man to furnish contributions of money for the propagation of opinions which he disbelieves is sinful and tyrannical' and 'to suffer the civil magistrate to intrude his powers into the field of opinion ... is a dangerous fallacy'.

Exhibit 525 · Constitutional amendment

First Amendment to the Constitution of the United States

Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof

Forbids Congress to make a law respecting an establishment of religion or prohibiting its free exercise.

Source
United States Congress (ratified by the states 15 December 1791)
Date
15 December 1791
Quoted from
Amendment I
Grade
Primary record
Document
https://www.archives.gov/founding-docs/bill-of-rights-transcript
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Binds Congress only; state establishments persisted (see New Hampshire 1784).

Exhibit 526 · State constitution

New Hampshire Constitution of 1784, Part I, art. VI

no person of any one particular religious sect or denomination, shall ever be compelled to pay towards the support of the teacher or teachers of another persuasion, sect or denomination

Empowers the legislature to authorize towns, parishes and religious societies to make adequate provision at their own expense for public Protestant teachers, while providing that no person of one sect may be compelled to pay toward the teacher of another.

Source
State of New Hampshire (constitutional convention)
Date
1784
Quoted from
Part I, art. VI (Thorpe, Federal and State Constitutions, 1909, 4:2454-55)
Grade
Primary record
Document
https://press-pubs.uchicago.edu/founders/documents/amendI_religions42.html
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2026-11-09
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Findings citing this exhibit
Note
Shows the post-Revolution settlement was not uniform. Massachusetts (1780) and Connecticut: not yet read.

Exhibit 527 · Papal letters (in translation)

Innocent III, letters Cum ex injuncto and Sicut Ecclesiarum praelatis (to Metz), 1199

But although the desire to understand the divine Scriptures

Reports that lay men and women of Metz had Scripture and other books translated into French for their own use and met in secret to discuss and preach; says the desire to understand Scripture is not forbidden but commendable, while the secret assemblies, usurped preaching and contempt of priests are condemned; the companion letter to the bishop orders him to investigate and to warn them, noting the pope's ignorance of their faith.

Source
Pope Innocent III
Date
1199
Quoted from
Cum ex injuncto (Wikisource volunteer translation; Latin in Migne PL 214)
Grade
Primary record
Document
https://en.wikisource.org/wiki/Translation:Cum_ex_injuncto
Accessed
2026-11-09
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Note
The letters were later included in canon law.

Exhibit 528 · Printed polemical dialogue

Thomas More, A Dyaloge ... of the pestylent sect of Luther and Tyndale (1529), book 3, ch. 16

For as for other olde onys, that were before Wyclyffys days, [these] remayn lawful, and be in some folkys handys had and red.

More states that the clergy keep from the laity only translations 'not yet approued for good' or 'reproued for naught', as Wycliffe's and Tyndale's, and that older English translations before Wycliffe remain lawful and are in some hands; elsewhere he proposes translations approved by the ordinaries and delivered to the lay by the bishop.

Source
Thomas More
Date
1529
Quoted from
Pollard, Records of the English Bible (1911), Record II, p. 81 (from fol. xciii verso); Record III, pp. 84-85
Grade
Primary record
Document
https://archive.org/details/recordsofenglish00polluoft
Accessed
2026-11-09
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Note
More's own statement of the defense and his proposal; Tyndale's reply (Answere vnto Sir Thomas Mores dialoge, fol. cv, in Pollard p. 82 n.) is that the bishops could have shown which translation was lawful and let it be printed.

Exhibit 529 · Scholarly essay

Anne Hudson, 'The First Complete English Bible', Tyndale Society Journal no. 2

Orthodox owners are known: for instance the copy now found in the Bodleian Library Oxford, MS Douce 277, belonged to Henry VI

States that about 250 manuscripts of the Wycliffite translation survive; that the hierarchy tolerated translation until Arundel's Constitutions; that those Constitutions banned translation and ordered unapproved English Scriptures confiscated; that owners included Henry VI; that Arundel licensed Nicholas Love's Meditationes as a substitute; and that possession of English scriptures became evidence of heresy.

Source
Anne Hudson (historian of Lollardy)
Date
n.d. (Tyndale Society Journal no. 2)
Quoted from
Paragraph 'Despite this prohibition circulation of copies...'
Grade
Reported
Document
https://www.tyndale.org/journals/tsj02/hudson.html
Accessed
2026-11-09
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Note
Hudson's reading ('confiscated') goes beyond the text of constitution 7, which restricts reading until approval.

Exhibit 530 · Reference biography

Dictionary of National Biography, 'Tyndale, William'

No record of his trial has been found

Says Tyndale was arrested in May 1535 and taken to Vilvorde, tried for heresy, condemned and degraded from orders; that no record of the trial has been found; and that he was executed at Vilvorde on 6 October 1536, strangled and then burnt.

Source
Dictionary of National Biography (vol. 57)
Date
1899
Quoted from
Entry text, paragraph on Vilvorde
Grade
Reported
Document
https://en.wikisource.org/wiki/Dictionary_of_National_Biography,_1885-1900/Tyndale,_William
Accessed
2026-11-09
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Note
Secondhand. Primary records would be the Council of Brabant archives and Letters and Papers of Henry VIII (Vaughan to Cromwell, 13 April 1536, as cited by the DNB). Hall's Chronicle (1548) places the condemnation in September.

Exhibit 531 · Formulary

Articles of Religion of the Church of England (1571 English text), Articles XX and XXXVII

we geue not to our princes the ministring either of God's word, or of Sacraments

Article XX says the Church has power to decree rites and authority in controversies of faith but may not enforce as necessary for salvation anything besides Scripture; Article XXXVII says the Queen has the chief government of all estates, ecclesiastical or civil, and that this does not give princes 'the ministring either of God's word, or of Sacraments'.

Source
Convocation of Canterbury, with royal authority
Date
1571
Quoted from
Art. XXXVII, in Schaff, Creeds of Christendom III, pp. 512-13 (from Cawood 1571 as printed in Hardwick)
Grade
Primary record
Document
https://ccel.org/ccel/schaff/creeds3/creeds3.iv.xi.html
Accessed
2026-11-09
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Note
Used for the established church's own statement of the limits of its claim. Article XX: besides Scripture the Church 'ought it not to enforce any thing to be beleued for necessitie of saluation'.

Exhibit 532 · Statute

Act for the true payment of Tithes, 2 & 3 Edward VI c. 13

Confirms the two Henrician tithe Acts and requires every subject to pay predial tithes in kind as they arise; one who carries off produce before the tithe is set out forfeits treble value; withholding or obstructing is recoverable before the ecclesiastical judge for double value.

Source
Parliament of England (Edward VI)
Date
1548
Grade
Primary record
Document
https://archive.org/details/statutes-of-the-realm-volume-4-part-1-1547-1-edward-6-to-1584-5-27-elizabeth
Accessed
2026-11-09
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Note
Re-read from a page image before use.

Exhibit 533 · Statute

National Nutrition Monitoring and Related Research Act of 1990, sec. 301 (7 U.S.C. 5341): Dietary Guidelines for Americans

The information and guidelines contained in each report required under paragraph (1) shall be based on the preponderance of the scientific and medical knowledge which is current at the time the report is prepared.

Requires HHS and USDA to publish 'Dietary Guidelines for Americans' at least every five years, to be promoted by every federal food, nutrition or health program, and to be reviewed (sixty-day review) before any agency issues dietary guidance for the general population. The statute does not mention advisory committees, committee composition or conflicts of interest.

Source
U.S. Congress
Date
22 October 1990
Quoted from
7 U.S.C. 5341(a)(2)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/7/5341
Accessed
2026-11-09
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Exhibit 534 · Committee print

Dietary Goals for the United States, Second Edition (committee print)

decrease consumption of animal fat, and choose meats, poultry and fish which will reduce saturated fat intake.

Staff print, 95th Cong., 1st sess., Stock No. 052-070-04376-8. Records that meat and egg producers requested additional hearings (24 March and 26 July 1977) and that the National Live Stock and Meat Board submitted 24 experts (p. xxx). Replaces the first edition's 'decrease consumption of meat and increase consumption of poultry and fish' with the animal-fat wording (p. xl). Keeps a 300 mg cholesterol goal but suggests 'easing the cholesterol recommendation in order to increase egg consumption' for young children, pre-menopausal women and the elderly (p. xxxix; Suggestion 6). Supplemental forewords: Percy, Schweiker and Zorinsky list reservations about the cholesterol goal and the evidence (pp. vii-ix); Dole writes 'I am pleased that the second edition deletes language from the first edition recommending "eat less meat"' (p. xi). McGovern signs the Foreword as chairman (p. v).

Source
U.S. Senate Select Committee on Nutrition and Human Needs
Date
December 1977
Quoted from
Food Selection Suggestion No. 3, p. xl (replacing the first edition's "decrease consumption of meat and increase consumption of poultry and fish")
Grade
Primary record
Document
https://archive.org/details/CAT79715358
Accessed
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Exhibit 535 · Hearing record

Diet Related to Killer Diseases, Vol. III (Response to Dietary Goals for the U.S. - Re: Meat, 24 March 1977) and Vol. VI (Re: Eggs, 26 July 1977)

Cited in the Second Edition print of Dietary Goals (footnotes 9 and 10, p. xxx) as the hearing volumes on meat and eggs, with GPO Stock Nos. 052-070-04277-0 and 050-070-04280-0. The print's later list (p. xxxi) gives 052-070-04256-1 for Vol. III and 052-070-04277-0 for Vol. IV (Fiber), and 052-070-04280-0 for the eggs volume. The registered URL is the print, not the hearings.

Source
U.S. Senate Select Committee on Nutrition and Human Needs
Date
March and July 1977
Grade
Reported
Document
https://archive.org/details/CAT79715358
Accessed
2026-11-09
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Exhibit 536 · Congressional Research Service report

The Dietary Guidelines for Americans: Overview and Considerations for Congress (R47488)

One issue identified with the 2020-2025 DGA cycle was the composition of the DGAC and, more specifically, members with perceived conflicts of interest.

Documents the history (1977 Dietary Goals; 1980 Senate Appropriations report directing an external review; 1983 committee; 1987 House conference report re-establishing a DGAC; 1990 Act), the committee-selection process (SGE appointment, background checks, OGE 450), NASEM's 2017 recommendations and the departments' responses, the 2015 scope dispute, the 2015 cholesterol change, the 2020 conflict-of-interest critique and the departments' decision not to adopt the DGAC's added-sugars and alcohol recommendations.

Source
Congressional Research Service
Date
28 March 2023
Quoted from
Section 'Controversies in the DGA', 'The 2020-2025 DGA'
Grade
Primary record
Document
https://www.everycrsreport.com/reports/R47488.html
Accessed
2026-11-09
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Note
Page locators not captured.

Exhibit 537 · Peer-reviewed article

Food Lobbies, the Food Pyramid, and U.S. Nutrition Policy

His explanation for this decision, however, was widely disbelieved

Account of the Pyramid brochure (preparation from 1988, sent to the printer in February 1991), the April 1991 protest by the National Cattlemen's Association and other producer groups, the postponement announced by Secretary Madigan, a new $855,000 testing contract (reported), and the release one year and one day later with text emphasizing two to three daily servings of meat and dairy. Cites USDA documents and press reports for each step.

Source
Marion Nestle, International Journal of Health Services 23(3):483-496
Date
1993
Quoted from
Section 'The Food Guide Pyramid'
Grade
Peer-reviewed
Document
https://blogs.bu.edu/calandra/files/2016/06/FoodLobbiesTheFoodPyramidandU.S.NutritionPolicy.pdf
Accessed
2026-11-09
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Note
Author's characterization.

Exhibit 538 · Agency fact sheet

A Brief History of USDA Food Guides

Developed using consumer research, to bring awareness to the new food patterns

Two-page USDA chronology from 1916 to MyPlate. The 1992 entry describes the Food Guide Pyramid as developed using consumer research. The sheet does not mention the April 1991 withdrawal.

Source
USDA Center for Nutrition Policy and Promotion
Date
June 2011
Quoted from
1992 entry, p. 2
Grade
Primary record
Document
https://webarchive.library.unt.edu/web/20120913074206id_/http://www.choosemyplate.gov/food-groups/downloads/MyPlate/ABriefHistoryOfUSDAFoodGuides.pdf
Accessed
2026-11-09
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Note
Wayback/UNT web-archive copy; the choosemyplate.gov original is no longer served.

Exhibit 539 · Committee report

House Report 114-205, Agriculture, Rural Development, FDA and Related Agencies Appropriations Bill, 2016

This was the first time environmental factors impacted recommendations traditionally aimed at diet and nutrition.

Committee report to accompany H.R. 3049 (Aderholt). States that the 2015 DGAC report 'included extraneous factors and policy recommendations that are outside of the statutory requirement, such as agriculture production practices including sustainability, taxes, food labeling and marketing policies'; the bill language required NEL 'Grade I: Strong' evidence and a draft with a 90-day comment period. Minority views of Reps. Lowey and Farr oppose section 734: 'Congress should have no role deciding the level of scientific evidence required for the Dietary Guidelines for Americans (DGA).'

Source
U.S. House Committee on Appropriations
Date
14 July 2015
Quoted from
Report language, 'Dietary Guidelines for Americans' (PDF p. 60)
Grade
Primary record
Document
https://www.congress.gov/114/crpt/hrpt205/CRPT-114hrpt205.pdf
Accessed
2026-11-09
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Exhibit 540 · Statute

Consolidated Appropriations Act, 2016, P.L. 114-113, Division A, secs. 734-735

is limited in scope to nutritional and dietary information.

Sec. 734 bars use of funds to release or implement the eighth edition unless the Secretaries ensure each new or revised guideline 'is based on significant scientific agreement' and 'is limited in scope to nutritional and dietary information.' Sec. 735 directs USDA to engage the National Academy of Medicine for a study of the process used to establish the DGAC and develop the guidelines, with a panel of 'balanced representation,' and appropriates $1,000,000. The text does not use the word 'sustainability.'

Source
U.S. Congress
Date
18 December 2015
Quoted from
Div. A, Title VII, sec. 734, 129 Stat. 2280
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-114publ113/html/PLAW-114publ113.htm
Accessed
2026-11-09
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Exhibit 541 · Congressional letter

Letter from Reps. Hartzler, Conaway and other House members to Secretaries Vilsack and Burwell

not the wider policy realm of sustainability and tax policy, in which members of this committee had neither expertise, evidence, nor charter.

Seven-page signed letter. Says the DGAC 'greatly exceeded their scope' and that the DGAC's lean-red-meat recommendation 'directly contradicts years of peer reviewed scientific research.'

Source
U.S. House of Representatives (Members of Congress)
Date
31 March 2015
Quoted from
p. 1
Grade
Primary record
Document
https://agriculture.house.gov/uploadedfiles/ag_dietaryguidelineslettertosecsvilsackburwell.pdf
Accessed
2026-11-09
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Exhibit 542 · Agency blog post

2015 Dietary Guidelines: Giving You the Tools You Need to Make Healthy Choices

because this is a matter of scope, we do not believe that the 2015 DGAs are the appropriate vehicle for this important policy conversation about sustainability.

The Secretaries state that the 2015 guidelines will not include sustainability and tie that decision to the scope of the 1990 Act.

Source
Secretaries Vilsack (USDA) and Burwell (HHS)
Date
6 October 2015
Quoted from
Paragraph beginning 'In terms of the 2015 Dietary Guidelines'
Grade
Primary record
Document
https://www.usda.gov/media/blog/2015/10/06/2015-dietary-guidelines-giving-you-tools-you-need-make-healthy-choices
Archived
https://web.archive.org/web/2015/https://www.usda.gov/media/blog/2015/10/06/2015-dietary-guidelines-giving-you-tools-you-need-make-healthy-choices
Accessed
2026-11-09
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Exhibit 543 · Advisory committee report

Scientific Report of the 2015 Dietary Guidelines Advisory Committee

The 2015 DGAC will not bring forward this recommendation because available evidence shows no appreciable relationship between consumption of dietary cholesterol and serum cholesterol

DGAC (chair Barbara Millen) drops the 300 mg/day cholesterol limit, keeps a goal of less than 10 percent of calories from saturated fat (p. 6), and states that a diet higher in plant-based foods and lower in animal-based foods 'is more health promoting and is associated with less environmental impact than is the current U.S. diet' (p. 5).

Source
2015 Dietary Guidelines Advisory Committee
Date
February 2015
Quoted from
p. 58
Grade
Primary record
Document
https://odphp.health.gov/sites/default/files/2019-09/Scientific-Report-of-the-2015-Dietary-Guidelines-Advisory-Committee.pdf
Accessed
2026-11-09
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Exhibit 544 · Policy document

Dietary Guidelines for Americans 2015-2020, Eighth Edition

The Key Recommendation from the 2010 Dietary Guidelines to limit consumption of dietary cholesterol to 300 mg per day is not included in the 2015 edition, but this change does not suggest that dietary cholesterol is no longer important to consider when building healthy eating patterns.

Final eighth edition. Removes the numeric cholesterol limit while keeping a 10 percent saturated-fat ceiling and advising people to eat as little dietary cholesterol as possible.

Source
U.S. Department of Health and Human Services and U.S. Department of Agriculture
Date
7 January 2016
Quoted from
Chapter 1, p. 32
Grade
Primary record
Document
https://odphp.health.gov/sites/default/files/2019-09/2015-2020_Dietary_Guidelines.pdf
Accessed
2026-11-09
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Exhibit 545 · Journal investigation

The scientific report guiding the US dietary guidelines: is it scientific? (BMJ 2015;351:h4962)

The expert report underpinning the next set of US Dietary Guidelines for Americans fails to reflect much relevant scientific literature in its reviews of crucial topics and therefore risks giving a misleading picture, an investigation by The BMJ has found.

BMJ investigation criticizing the DGAC's evidence methods, its use of the Nutrition Evidence Library and its saturated-fat and red-meat conclusions. Competing-interests note: Teicholz is a board member of the Nutrition Coalition, and the article was 'fully funded with a grant from the Laura and John Arnold Foundation.' The copy carries an amendment note about reference URLs; the 29 September clarification, the October correction and the committee's rapid response are in the Retraction Watch exhibits.

Source
Nina Teicholz, The BMJ
Date
23 September 2015
Quoted from
BMJ 2015;351:h4962, published 23 Sept. 2015, lede paragraph, p. 1 of the 6-page PDF (Wayback copy of bmj.com PDF, snapshot 2026-05-02)
Grade
Reported
Document
https://doi.org/10.1136/bmj.h4962
Accessed
2026-11-09
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Exhibit 546 · News report

Following criticism, BMJ 'clarifies' dietary guidelines investigation

strongly disagrees with many of the statements represented as facts

Reports that BMJ issued two clarifications (the sentence should have said 'lean' meats; the share of DGAC questions with an NEL review was 63 percent of those needing a systematic review) and that the DGAC posted a rapid response.

Source
Retraction Watch
Date
29 September 2015
Quoted from
Paragraph 3, quoting the DGAC rapid response
Grade
Reported
Document
https://retractionwatch.com/2015/09/29/following-criticism-bmj-clarifies-dietary-guidelines-investigation
Accessed
2026-11-09
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Exhibit 547 · News report

BMJ corrects controversial critique of US dietary guidelines report

This statement did not aptly reflect the findings of the more authoritative of these reviews, by Hooper et al

Reproduces the BMJ's October 2015 correction (the Hooper et al. 2012 Cochrane review found an effect of saturated fat on cardiovascular events but not on cardiovascular mortality) and Teicholz's reply that the committee did not request an NEL review of saturated fat.

Source
Retraction Watch
Date
28 October 2015
Quoted from
Reproduction of the BMJ correction notice
Grade
Reported
Document
https://retractionwatch.com/2015/10/28/bmj-corrects-controversial-critique-of-us-dietary-guidelines-report/
Accessed
2026-11-09
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Exhibit 548 · Peer-reviewed article

Conflicts of interest for members of the US 2020 Dietary Guidelines Advisory Committee

Our results show that nineteen of the twenty DGAC members (95 %) had at least one tie to an industry actor.

Counts 720 instances of ties (research funding 287; board 155; speaker/honoraria 112; consultant 105; award 35; employee 20; editor 6) for the 20 members, one count per relationship-year, from publications and CVs. Member names anonymised at the journal's request. Authors state the method can over- and under-count and that mapping ties to recommendations was out of scope. Funded by The Nutrition Coalition; co-author Nina Teicholz is affiliated with it and wrote the 2015 BMJ article.

Source
Mialon, Serodio, Crosbie, Teicholz, Naik, Carriedo, Public Health Nutrition 27(1):e69
Date
21 March 2022
Quoted from
Discussion, first sentence
Grade
Peer-reviewed
Document
https://pmc.ncbi.nlm.nih.gov/articles/PMC10966930/
Accessed
2026-11-09
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Note
PMC page lists a 2024 collection date; journal publication 21 March 2022 (doi 10.1017/S1368980022000672).

Exhibit 549 · Advisory committee report

Scientific Report of the 2020 Dietary Guidelines Advisory Committee

none of the 20 committee members reported any entries on their OGE Form 450 that would prevent them from being appointed and providing the complete range of duties required of a Dietary Guidelines Advisory Committee member in full compliance with the Federal ethics rules applicable to Special Government Employees.

Part C describes the selection and conflict-of-interest process for the 2020 committee (USDA-led): nomination packages with funding sources, OGE Form 450 submitted before appointment for the first time, review by USDA ethics officials, SGE status, annual ethics training.

Source
2020 Dietary Guidelines Advisory Committee
Date
July 2020
Quoted from
Part C. Methodology, p. 7
Grade
Primary record
Document
https://www.dietaryguidelines.gov/sites/default/files/2020-07/ScientificReport_of_the_2020DietaryGuidelinesAdvisoryCommittee_first-print.pdf
Accessed
2026-11-09
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Exhibit 550 · Agency presentation

Responding to the National Academies of Sciences, Engineering, and Medicine Study on the Process to Update the Dietary Guidelines for Americans

the Departments choose not to implement this recommendation out of privacy concerns.

Slides giving the departments' response to each NASEM recommendation for the 2020 cycle: no third-party screener (cost and time); no public list of provisional appointees (privacy); OGE 450 reviewed by USDA ethics officials before selection; annual OGE 450 review and ethics training; a summary of conflict management in the report.

Source
Eve Stoody, Designated Federal Officer, 2020 DGAC (USDA CNPP)
Date
May 2019
Quoted from
Slide 8
Grade
Primary record
Document
https://www.dietaryguidelines.gov/sites/default/files/2019-05/Day%201%20Response%20to%20NASEM%20Study.pdf
Accessed
2026-11-09
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Exhibit 551 · Consensus study report

Optimizing the Process for Establishing the Dietary Guidelines for Americans: The Selection Process

This National Academies committee concludes conflicts of interest—whether actual or perceived cannot always be able to be eliminated entirely on a balanced panel of experts

Congressionally mandated (P.L. 114-113 sec. 735). Finds the DGAC selection process 'thoughtful' and within the law but lacking transparency. Recommends an external third party to screen candidates, public comment on a provisional list with biographies and known conflicts, public disclosure of how biases and conflicts are identified and managed (including a nonfinancial-interest form), and continuous improvement. Accepts that some conflicts cannot be eliminated and suggests a three-year lookback for relationships incidental to the panel's work.

Source
National Academies of Sciences, Engineering, and Medicine
Date
September 2017
Quoted from
Chapter 4, section on conflicts of interest (p. 84)
Grade
Primary record
Document
https://www.nationalacademies.org/read/24637/chapter/1
Accessed
2026-11-09
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Note
Summary quotation for the 'thoughtful' finding: 'overall, the DGAC selection process is thoughtful and works within the bounds of the relevant laws to serve USDA and HHS, as well as the American public' (Summary).

Exhibit 552 · Consensus study report

Redesigning the Process for Establishing the Dietary Guidelines for Americans

Transparency of the overall process to update the DGA needs improvement.

Second NASEM report. Recommends dividing the DGAC's functions among three groups, a public explanation when the policy document omits or accepts only parts of the scientific report, and separation of USDA Nutrition Evidence Library staff from the committee. Records that presenters raised 'the potential conflict of interest USDA might have in managing and supporting the DGA given its role in supporting U.S. agriculture' (Chapter 1).

Source
National Academies of Sciences, Engineering, and Medicine
Date
December 2017
Quoted from
Summary
Grade
Primary record
Document
https://www.nationalacademies.org/read/24883/chapter/2
Accessed
2026-11-09
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Exhibit 553 · Advocacy letter

Letter to HHS urging public disclosure of 2025 DGAC members' financial conflicts of interest

At present, the public remains in the dark.

Signed by CSPI, Corporate Accountability, Union of Concerned Scientists, Physicians Committee for Responsible Medicine, Johns Hopkins Center for a Livable Future and others. States the departments did not implement NASEM's provisional-list recommendation in 2020 and that OGE Form 450 is exempt from public disclosure. Cites the Union of Concerned Scientists (1 April 2019) and Corporate Accountability (2020) as the earlier NGO reports on the 2020 committee.

Source
Center for Science in the Public Interest and 12 other organizations
Date
27 January 2023
Quoted from
p. 3
Grade
Primary record
Document
https://www.cspi.org/sites/default/files/2023-01/COI%20DGAC%20Letter_1.27.23.pdf
Accessed
2026-11-09
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Note
The letter is the primary record of the request, not of the facts it asserts.

Exhibit 554 · Advisory committee report

Scientific Report of the 2025 Dietary Guidelines Advisory Committee

Because its work is collective, the Committee provided its disclosures collectively rather than individually.

Part C: 20 members appointed 19 January 2023 as special government employees; HHS background checks; OGE Form 450 reviewed by HHS ethics officials; voluntary ICMJE disclosure forms covering the prior 12 months, posted collectively; protocol-driven, externally peer-reviewed methods.

Source
2025 Dietary Guidelines Advisory Committee
Date
December 2024
Quoted from
Part C. Methodology, p. 6
Grade
Primary record
Document
https://www.dietaryguidelines.gov/sites/default/files/2024-12/Scientific_Report_of_the_2025_Dietary_Guidelines_Advisory_Committee_508c.pdf
Accessed
2026-11-09
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Exhibit 555 · Policy document

Dietary Guidelines for Americans, 2025-2030

These Guidelines mark the most significant reset of federal nutrition policy in our nation’s history.

Ten-page edition. Keeps 'saturated fat consumption should not exceed 10% of total daily calories,' recommends full-fat dairy with no added sugars, protein of 1.2-1.6 g per kg per day, red meat among protein sources, and lists 'butter or beef tallow' among cooking fats.

Source
U.S. Department of Health and Human Services and U.S. Department of Agriculture
Date
7 January 2026
Quoted from
Message from the Secretaries, p. 1
Grade
Primary record
Document
https://cdn.realfood.gov/DGA.pdf
Accessed
2026-11-09
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Exhibit 556 · Agency scientific report

The Scientific Foundation for the Dietary Guidelines for Americans, 2025-2030

Because this request applies only to external experts, it does not follow federal disclosure requirements for federal employees.

Replaces the DGAC report as the evidentiary base. States that the administration 'implemented an independent evidence review process to address and correct deficiencies identified in the Scientific Report of the 2025 Dietary Guidelines Advisory Committee' and cites its 'health equity' lens. Nine external reviewers (Beal, Bikman, Brenna, Goran, Layman, Leidy, Taha, Volek, Zamora) 'selected through a federal contracting process'; data compiled by Christopher Ramsden (NIH). Peer review coordinated by NIH Office of Nutrition Research, two reviewers each. Table of the DGAC's 56 recommendations marked Yes, Partial or No (my count of the checkmarks: 14, 12, 30). Self-reported disclosure table, three-year lookback: Brenna lists NCBA/Texas Beef Council consulting and a research grant, Global Dairy Platform travel and Danone/Nutricia consulting; Layman lists NCBA and National Dairy Council honoraria and consulting fees; Leidy lists NCBA, National Pork Board, General Mills Bell Institute and Novo Nordisk funding; Taha lists Fonterra, California Dairy Research Foundation and Dairy Management Inc. grants; Volek lists an equity stake in Virta Health; Beal, Bikman, Goran list other interests; Zamora lists none.

Source
U.S. Department of Health and Human Services and U.S. Department of Agriculture
Date
8 January 2026
Quoted from
Disclosure of Nutrition-Related Private Interests, p. x
Grade
Primary record
Document
https://cdn.realfood.gov/Scientific%20Report_1.8.26.pdf
Accessed
2026-11-09
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Exhibit 557 · GAO report

Dietary Guidelines for Americans: Strengthening Interagency Collaboration Could Help Inform Nutrition Research and Future Guidelines (GAO-24-106130)

The committee has taken various actions to inform nutrition research but has not fully incorporated seven of the eight leading practices identified by GAO for ensuring agencies are effectively collaborating

GAO reviewed the HHS/USDA-co-chaired Interagency Committee on Human Nutrition Research and found it had not fully incorporated seven of eight leading collaboration practices; two recommendations (HHS, USDA), open at last check. The report does not evaluate DGAC membership or conflicts of interest.

Source
U.S. Government Accountability Office
Date
18 October 2023
Quoted from
GAO-24-106130 product page, Highlights, 'What GAO Found', first paragraph (Wayback snapshot 2026-01-08)
Grade
Primary record
Document
https://www.gao.gov/products/gao-24-106130
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
No GAO report on the DGAC selection process was found.

Exhibit 558 · Statute

Food Additives Amendment of 1958 (Public Law 85-929, 72 Stat. 1784)

if such substance is not generally recognized, among experts qualified by scientific training and experience to evaluate its safety, as having been adequately shown through scientific procedures (or, in the case of a substance used in food prior to January 1, 1958, through either scientific procedures or experience based on common use in food) to be safe under the conditions of its intended use

Section 2 adds the definition of 'food additive' to section 201 of the Federal Food, Drug, and Cosmetic Act and excludes any substance generally recognized as safe by qualified experts. Section 4 adds section 409, which deems an additive unsafe unless it is covered by a regulation or exemption, and lets any person petition for a regulation. The text does not say who the experts are, how they are chosen, or that the government must be told of their conclusion.

Source
U.S. Congress
Date
6 September 1958
Quoted from
72 Stat. 1784, sec. 2 (new paragraph (s) of section 201)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/STATUTE-72/pdf/STATUTE-72-Pg1784.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Now codified at 21 U.S.C. 321(s).

Exhibit 559 · Agency web page

FDA's Approach to the GRAS Provision: A History of Processes

We believe only those chemicals should be automatically exempted from the new law which are recognized among competent experts as safe for their intended use. This would make it unnecessary, for example, to do studies on table salt, but would not approve the continued use, without proof of safety, of the synthetic emulsifiers now widely used in some fabricated foods.

FDA poster by CFSAN staff presented at the April 2006 FDA Science Forum. It gives FDA's own timeline of the GRAS provision, from the 9 December 1958 GRAS list to the 1969 removal of cyclamate and the 1997 proposal, and excerpts 1958 congressional testimony by FDA Commissioner Larrick.

Source
U.S. Food and Drug Administration, Office of Food Additive Safety
Date
2006 (poster; page accessed 2026)
Quoted from
Section 'Excerpts from Legislative History', from Commissioner Larrick's opening remarks
Grade
Primary record
Document
https://www.fda.gov/food/generally-recognized-safe-gras/fdas-approach-gras-provision-history-processes
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The page excerpts the testimony but does not cite the hearing volume.

Exhibit 560 · Federal Register proposed rule

Substances Generally Recognized as Safe, proposed rule (62 FR 18938; Docket 97N-0103)

FDA recognizes that a decision to submit a notice is voluntary.

Proposed to replace the GRAS affirmation petition with a notification procedure in which any person may notify FDA of a GRAS determination. FDA states the decision to submit a notice is voluntary and that the rulemaking-based petition process deterred many persons who independently determine a use is GRAS from informing the agency.

Source
U.S. Food and Drug Administration
Date
17 April 1997
Quoted from
62 FR 18946, section 'B. Specific Requirements' (proposed 170.36(c))
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-1997-04-17/pdf/97-9706.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
A second passage, 62 FR 18944: 'FDA believes that the lengthy rulemaking associated with the GRAS petition process deters many persons who independently determine that use of a substance is GRAS from informing the agency of such determinations.'

Exhibit 561 · Federal Register final rule

Substances Generally Recognized as Safe, final rule (81 FR 54960; Docket FDA-1997-N-0020)

We agree that we lack express statutory authority to require companies to submit GRAS notices.

Finalized the 1997 proposal as a voluntary notification procedure. FDA rejects comments that voluntariness violates the 1958 amendment, says there is no distinction in law between a conclusion submitted as a notice and one kept by its proponent (formerly called a 'self-determination'), and states that it lacks express statutory authority to require submission. It cites its 2010 caffeinated-alcohol letters as an example of enforcement without a notice.

Source
U.S. Food and Drug Administration
Date
17 August 2016
Quoted from
81 FR 54981-82 (Comment and Response 28)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2016-08-17/pdf/2016-19164.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The quoted sentence runs across the page break between 54981 and 54982. Response 1 (81 FR 54970): 'Although the FD&C Act specifically provides for our review of food additives, it is silent with respect to industry submissions to us on the use of GRAS substances.' Section on terminology (81 FR 54984): 'there would be no distinction between a conclusion of GRAS status submitted to us as a GRAS notice and a conclusion of GRAS status that remains with its proponent as an independent conclusion (formerly referred to as a “self-determination”) of GRAS status.' Effective 17 October 2016.

Exhibit 562 · GAO report

Food Safety: FDA Should Strengthen Its Oversight of Food Ingredients Determined to Be Generally Recognized as Safe (GRAS) (GAO-10-246)

FDA only reviews those GRAS determinations that companies submit to the agency’s voluntary notification program—the agency generally does not have information about other GRAS determinations companies have made because companies are not required to inform FDA of them.

Found that FDA reviews only the GRAS determinations companies submit and generally has no information about the rest, that FDA had issued no conflict-of-interest guidance for company expert panels, that FDA had not finalized its 1997 proposal, and that FDA had not systematically reconsidered GRAS substances since the 1980s. Recommended six actions, the first a strategy to require any company making a GRAS determination to give FDA basic information about it. FDA generally agreed and raised concerns about parts of several recommendations.

Source
U.S. Government Accountability Office
Date
February 2010
Quoted from
Highlights, 'What GAO Found'
Grade
Primary record
Document
https://files.gao.gov/assets/gao-10-246.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Other passages read: p. 12 ('officials representing one international marketer of food indicated the company makes about 5 GRAS determinations each year without notifying FDA'); p. 13 (about 180 companies notified FDA from 1998 through 2008; FDA cannot estimate the number of determinations it was not told of); pp. 14-15 (conflicts of interest); p. 34 (recommendations); pp. 36-37 (FDA's response). The cover date is February 2010; FDA's 2026 rule cites it as March 2010.

Exhibit 563 · Peer-reviewed study

Conflicts of Interest in Approvals of Additives to Food Determined to Be Generally Recognized as Safe: Out of Balance (JAMA Internal Medicine 173(22):2032-2036)

Between 1997 and 2012, we found that financial conflicts of interest were ubiquitous in determinations that an additive to food was GRAS.

Applied Institute of Medicine conflict-of-interest criteria to the 451 GRAS notices FDA received from 1997 to 2012. 22.4 percent were decided by a manufacturer's employee, 13.3 percent by a consultant firm's employee, and 64.3 percent by an expert panel chosen by the manufacturer or its consultant; none by a standing panel chosen by a third party. Ten people served on 27 or more of the 290 panels and one served on 128. The authors state the results do not prove the conflicts compromised any decision. Funded by Pew; three authors were Pew employees.

Source
Neltner TG, Alger HM, O'Reilly JT, Krimsky S, Bero LA, Maffini MV (Pew Charitable Trusts; University of Cincinnati; Tufts; UCSF)
Date
9 December 2013 (online 7 August 2013)
Quoted from
Discussion, first sentence
Grade
Peer-reviewed
Document
https://doi.org/10.1001/jamainternmed.2013.10559
Archived
https://web.archive.org/web/2019/https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/1725123
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The publisher page is paywalled. Limitations stated by the authors: they lacked comparable data on determinations not submitted to FDA, did not evaluate the FEMA panel, and analyzed only employment relationships. Results, 'Assessment of GRAS Safety Determinations Not Submitted to the FDA': 'From 1997 to 2012, we found only 1 instance when the agency sought to obtain a GRAS safety determination that it had not received a notification for.' That instance was FDA's 2010 letters to four companies about caffeine in alcoholic beverages; none had made a GRAS determination.

Exhibit 564 · Peer-reviewed study

Navigating the U.S. Food Additive Regulatory Program (Comprehensive Reviews in Food Science and Food Safety 10(6):342-368)

assigning the more than 10000 substances currently allowed in human food to those categories

Source of the estimate, based on interviews with food-industry staff and review of public GRAS notices and reports, that as of January 2011 more than 10,000 additives were in use, including about 1,000 human-food substances whose makers had concluded GRAS status without telling FDA. FDA's 2026 economic analysis adopts it as the low end of its own range. The estimate excludes flavors in the FEMA library and substances in common use before 1958.

Source
Neltner TG, Kulkarni NR, Alger HM, Maffini MV, Bongard ED, Fortin ND, Olson ED (Pew Health Group)
Date
25 October 2011
Quoted from
Abstract, Compr. Rev. Food Sci. Food Saf. 10(6), Nov. 2011 (Wayback snapshot of the journal page, 2023-01-09)
Grade
Peer-reviewed
Document
https://ift.onlinelibrary.wiley.com/doi/full/10.1111/j.1541-4337.2011.00166.x
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Not opened. Known through the JAMA paper (which restates the estimate), FDA's 2026 proposed rule (refs. 6-7) and FDA's 2026 PRIA (ref. 4, footnote 2).

Exhibit 565 · Peer-reviewed study

Out of balance: conflicts of interest persist in food chemicals determined to be generally recognized as safe (Environmental Health 22:59)

We found no evidence that GRAS panels have adhered to FDA’s guidance.

Assessed 403 GRAS notices FDA filed between 2015 and 2020 against FDA's guidance on convening GRAS panels. Notifiers relied on a panel in 57 percent of notices on average; seven people held 46 percent (340 of 732) of panel positions. Funded by the Environmental Defense Fund; two authors were paid by EDF as consultants. EDF was a plaintiff in the 2016-17 challenge to FDA's GRAS rule.

Source
Matouskova K, Neltner TG, Maffini MV (Environmental Defense Fund; independent consultants)
Date
6 September 2023
Quoted from
Abstract, Results
Grade
Peer-reviewed
Document
https://doi.org/10.1186/s12940-023-01004-8
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Abstract checked on PubMed (PMID 37670318); funding and panel counts read in the open-access full text (PMC10481496).

Exhibit 566 · Peer-reviewed study

Randomized Controlled-Feeding Study of Dietary Emulsifier Carboxymethylcellulose Reveals Detrimental Impacts on the Gut Microbiota and Metabolome (Gastroenterology 162:743-756)

Relative to control subjects, CMC consumption modestly increased postprandial abdominal discomfort and perturbed gut microbiota composition in a way that reduced its diversity.

Double-blind controlled-feeding study of 16 healthy adults for 11 days: 9 ate an emulsifier-free diet and 7 the same diet with 15 g per day of carboxymethylcellulose (CMC). CMC lowered gut microbiota diversity, changed the fecal metabolome and modestly increased abdominal discomfort; 2 of 7 CMC subjects showed bacteria in the normally sterile inner mucus layer. The study reports no disease outcome. Funded by NIH and the Max Planck Society, among others.

Source
Chassaing B, Compher C, Bonhomme B, et al. (Penn State; University of Pennsylvania; INSERM/Universite Paris Cite; others)
Date
November 2021 (online); March 2022 (print)
Quoted from
Abstract, Results
Grade
Peer-reviewed
Document
https://doi.org/10.1053/j.gastro.2021.11.006
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Timewar's lead cites this as 160(7), 2021; the print citation is 162(3):743-756 (2022). The authors' background states: 'Despite lack of extensive safety testing, CMC was approved in the 1960s for use in foods at concentrations up to 2% (wt/wt) by regulatory agencies, including the US Food and Drug Administration and European Commission based on the GRAS (generally regarded as safe) designation developed by these agencies.' Read in PMC9639366.

Exhibit 567 · Regulation

21 CFR 170.30, Eligibility for classification as generally recognized as safe (GRAS)

General recognition of safety based upon scientific procedures shall require the same quantity and quality of scientific evidence as is required to obtain approval of a food additive.

FDA's regulation on what general recognition of safety requires: the views of qualified experts based on scientific procedures or, for pre-1958 substances, common use in food, and 'common knowledge throughout the scientific community' that there is reasonable certainty of no harm.

Source
U.S. Food and Drug Administration
Date
In force 1 November 2026 (eCFR)
Quoted from
21 CFR 170.30(b)
Grade
Primary record
Document
https://www.ecfr.gov/current/title-21/section-170.30
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 568 · Regulation

21 CFR 182.1745, Sodium carboxymethylcellulose

This substance is generally recognized as safe when used in accordance with good manufacturing practice.

FDA's GRAS list entry for sodium carboxymethylcellulose, a regulation in part 182 of title 21. The substance is listed by FDA and was not a company's own conclusion.

Source
U.S. Food and Drug Administration
Date
In force 1 November 2026 (eCFR)
Quoted from
21 CFR 182.1745(b)
Grade
Primary record
Document
https://www.ecfr.gov/current/title-21/section-182.1745
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Date and notice of the original listing not found. The Federal Register history of the listing would date it.

Exhibit 569 · Agency press release

HHS Secretary Kennedy Directs FDA to Explore Rulemaking to Eliminate Pathway for Companies to Self-Affirm Food Ingredients Are Safe

industry can self-affirm that the use of a substance is GRAS without notifying the FDA

The Secretary directed the acting FDA commissioner to explore rulemaking to revise the GRAS final rule and eliminate the self-affirmed GRAS pathway. The release says industry can self-affirm without notifying FDA, that FDA has completed more than 1,000 GRAS notices and evaluates about 75 a year, and that HHS will work with Congress on legislation.

Source
U.S. Department of Health and Human Services
Date
10 March 2025
Quoted from
Paragraph 4
Grade
Primary record
Document
https://www.hhs.gov/press-room/revising-gras-pathway.html
Archived
https://web.archive.org/web/20251230114701/https://www.hhs.gov/press-room/revising-gras-pathway.html
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The Secretary is quoted: 'For far too long, ingredient manufacturers and sponsors have exploited a loophole that has allowed new ingredients and chemicals, often with unknown safety data, to be introduced into the U.S. food supply without notification to the FDA or the public.'

Exhibit 570 · Federal Register proposed rule

Substances Generally Recognized as Safe, proposed rule (91 FR 51834; Docket FDA-2025-N-3262; RIN 0910-AJ02)

Today, an unknown number of substances are being introduced into the market under the GRAS provision of section 201(s) of the FD&C Act.

Proposes to convert the voluntary GRAS notification program to a mandatory one, with exceptions (existing no-questions letters, substances listed in 21 CFR parts 182, 184 and 186, and others) and a one-year streamlined submission for substances already on the market. Effective 60 days after a final rule, with 18 months to comply. Noncompliance would be a factor in FDA's prioritization for post-market review; the rule creates no premarket approval. It grounds authority in sections 409(a), 409(d) and 701(a) and compares today's position to the years before 1958. Comments close 9 December 2026.

Source
U.S. Food and Drug Administration
Date
11 August 2026
Quoted from
91 FR 51838, section I (Executive Summary)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2026-08-11/pdf/2026-16296.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Other passages read: 51835 ('Under our current regulations, a person who concludes that the use of a substance is GRAS under the conditions of its intended use may, but is not required to, notify FDA of this conclusion.'); 51838 ('we find ourselves in a situation much like the years before the 1958 amendment’s enactment.'); 51842 ('Although we cannot verify the accuracy of these estimates'); 51845-46 (legal authority); 51866 (compliance date); 51870 (PRIA counts).

Exhibit 571 · Agency economic analysis

Substances Generally Recognized as Safe: Preliminary Regulatory Impact Analysis (Docket FDA-2025-N-3262)

Although the exact number of purported GRAS substances currently being used in human and animal foods is unknown, a 2011 study estimated that there were 1,000 substances being used in human food that were the subject of an independent conclusion of GRAS status

FDA's own count and estimate. 1,309 GRAS notices filed from February 1998 to March 2025 (1,234 human food, 75 animal food) by 673 notifiers; of 1,215 not pending, 961 drew a 'no questions' letter, 231 ended at the notifier's request, and 23 drew an insufficient-basis letter. FDA assumes 1,000 to 3,000 substances (primary estimate 2,000) are on the market under independent GRAS conclusions, about 1,028 firms have not filed a notice, and 1,740 substances rest on association expert-panel (FEMA) conclusions. Present value of costs about $89.6 million at 3 percent.

Source
U.S. Food and Drug Administration, Office of Economics and Analysis
Date
August 2026
Quoted from
Section II.D.2 (Independent Conclusions of GRAS Status), PRIA p. 13
Grade
Primary record
Document
https://www.fda.gov/media/194138/download
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
FDA assumes the 2011 estimate (Neltner et al.) is the low end and sets 3,000 as the high end because of the time since publication.

Exhibit 572 · CRS report

Food Additives and GRAS Substances: A Legal Framework (CRS Legal Sidebar LSB11445)

The preamble to the proposed regulations indicates that FDA would consider the failure to submit a GRAS notice as “a factor” in FDA’s prioritization of food substances for post-market review, and therefore marketed substances that are not the subject of a GRAS notice may face increased scrutiny from FDA.

Explains the statutory framework, FDA's 2016 statement that it lacks express authority to require notices, the unsuccessful challenge to the 2016 rule by the Center for Food Safety and the Environmental Defense Fund in the Southern District of New York (decided under Chevron, not appealed), the 2026 proposal, and how Loper Bright could change review of a final rule. Lists four pending bills.

Source
Congressional Research Service
Date
5 October 2026
Quoted from
p. 4
Grade
Primary record
Document
https://www.everycrsreport.com/files/2026-10-05_LSB11445_224683c645df03271d453db38ec195f31490e3cf.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Also p. 3-4: companies 'would be able to market products containing GRAS substances before submitting the notice and while FDA is reviewing the notice.' The Southern District case is named Center for Food Safety v. Becerra; docket number and decision date are not given in the Sidebar.

Exhibit 573 · Trade association statement

Let's Mow Down the GRAS Myths (one-page fact sheet)

GRAS is not a loophole; it’s a science-based regulatory pathway established by Congress and overseen by the FDA.

Industry trade group's response to the August 2026 proposal. It supports mandatory notification as part of 'a national uniform standard,' says GRAS ingredients must meet the same 'reasonable certainty of no harm' standard as approved additives, and rejects the 'loophole' description.

Source
Consumer Brands Association
Date
August 2026 (file named GRAS_Onesheet_081326)
Quoted from
'GRAS Is Just a Loophole' row
Grade
Primary record
Document
https://consumerbrandsassociation.org/wp-content/uploads/2026/08/GRAS_Onesheet_081326.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The document carries no date; the date is inferred from the file name. Second quote: 'The CPG industry has consistently supported greater transparency and welcomes GRAS reform as part of a national uniform standard for ingredient safety and transparency, including updated FDA regulations that require mandatory notification.' (first paragraph).

Exhibit 574 · Trade association web page

About the FEMA GRAS Program

While the Expert Panel has been provided with financial support by FEMA it has always maintained its full independence in its operations and GRAS determinations and follows strict conflict of interest procedures.

FEMA describes its GRAS program, begun in 1959 with an expert panel from 1960. It states that the panel has FEMA's financial support, that members have never been employees of FEMA member companies, that members are barred from consulting for member companies on flavors, that panelists do not know the applicant's identity, that the panel is self-appointed, and that all determinations and supporting information go to FDA, which does not thereby approve them.

Source
Flavor and Extract Manufacturers Association of the United States (FEMA)
Date
Page accessed 2026-11-09
Quoted from
Introduction, third paragraph
Grade
Primary record
Document
https://www.femaflavor.org/gras
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Second quote: 'Members of the Expert Panel have never been employees of FEMA member companies or employees of companies in the food industry.' (Qualified Experts).

Exhibit 575 · Federal Register notice

Ultra-Processed Foods; Request for Information (90 FR 35305; Docket FDA-2025-N-1793)

There is no single, universally accepted definition of UPFs, and the definition of such foods has varied considerably over time

Joint FDA-USDA request for data to help develop a uniform federal definition of ultra-processed food. It describes the Nova system, notes that foods such as whole-grain products or yogurt may be classed as ultra-processed, lists state proposals (Pennsylvania, California, Massachusetts, Florida, Louisiana and others) that define the term by additives, processing steps or listed ingredients, and asks six groups of questions on ingredients, processing and nutrients.

Source
U.S. Food and Drug Administration; U.S. Department of Agriculture
Date
25 July 2025
Quoted from
90 FR 35306-07, section I (Background)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2025-07-25/pdf/2025-14089.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 576 · Federal Register notice

Ultra-Processed Foods; Request for Information; Extension of Comment Period (90 FR 45229)

In response to requests for an extension, we are extending the comment period until October 23, 2025, to allow interested persons additional time to submit comments.

Extends the comment period on the July 2025 request (90 FR 35305, Docket FDA-2025-N-1793) to 23 October 2025.

Source
U.S. Food and Drug Administration; U.S. Department of Agriculture
Date
19 September 2025
Quoted from
90 FR 45229, 19 Sept. 2025, SUMMARY
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2025-09-19/pdf/2025-18169.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The 'no single, universally accepted definition' wording is in the RFI exhibit, not in this notice.

Exhibit 577 · Agency press release

HHS, FDA and USDA Address the Health Risks of Ultra-Processed Foods

Currently, there is no single authoritative definition for ultra-processed foods for the U.S. food supply.

Announces the joint request for information. States that there is no single authoritative definition, and that a uniform definition will allow consistency in research and policy. Quotes the HHS Secretary and FDA Commissioner on health risks of such foods; those statements are the officials' own and are not findings.

Source
U.S. Department of Health and Human Services
Date
23 July 2025
Quoted from
Paragraph 3
Grade
Primary record
Document
https://www.hhs.gov/press-room/hhs-fda-usda-ultra-processed-foods-definition-rfi.html
Archived
https://web.archive.org/web/20260129045435/https://www.hhs.gov/press-room/hhs-fda-usda-ultra-processed-foods-definition-rfi.html
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 578 · State statute

Assembly Bill 1264 (Gabriel), Chapter 467, Statutes of 2025: Pupil nutrition: restricted school foods and ultraprocessed foods of concern

“ultraprocessed food” or “UPF” means any food or beverage that contains a substance described in paragraph (2) and either high amounts of saturated fat, sodium, or added sugar, as described in subparagraph (A) of paragraph (3), or a nonnutritive sweetener or other substance described in subparagraph (B) of paragraph (3).

Defines 'ultraprocessed food' for school food by a substance test (any substance in FDA's Substances Added to Food database with one of eight listed technical effects, such as emulsifiers, stabilizers, colors or flavoring agents) combined with a nutrient test or a listed sweetener. The Department of Public Health must define 'ultraprocessed foods of concern' by regulation by 1 June 2028; phase-out begins by 1 July 2029 and vendor sales end 1 July 2032.

Source
State of California
Date
8 October 2025
Quoted from
Cal. Health & Safety Code sec. 104661(a)(1) (added by sec. 8)
Grade
Primary record
Document
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260AB1264
Archived
https://web.archive.org/web/20260904131500/https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260AB1264
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 579 · State statute

Senate Bill 25 (89th Legislature, Regular Session), enrolled

WARNING: This product contains an ingredient that is not recommended for human consumption by the appropriate authority in Australia, Canada, the European Union, or the United Kingdom.

Section 9 (Health & Safety Code 431.0815) requires a warning label on food containing any of 44 listed ingredients. It is a labeling law, not a GRAS rule. Section 431.0817 makes the label requirement inoperative for an ingredient once FDA or USDA prohibits it, conditions its use, or 'determines an ingredient or class of ingredients is safe.'

Source
State of Texas
Date
Signed June 2025; effective 1 September 2025
Quoted from
Tex. Health & Safety Code sec. 431.0815(b)(1)
Grade
Primary record
Document
https://capitol.texas.gov/tlodocs/89R/billtext/html/SB00025F.htm
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 580 · Court order

American Beverage Association et al. v. Paxton, No. 6:25-cv-00566 (W.D. Tex.), order on motion for preliminary injunction

The Court finds that Plaintiffs have shown that they are substantially likely to succeed on the merits of their claim that Section 9 violates the First Amendment by unconstitutionally compelling speech.

Grants a preliminary injunction against enforcement of Section 9 of SB 25 against the plaintiffs (American Beverage Association, Consumer Brands Association, National Confectioners Association, FMI) and their members, finding a substantial likelihood of success on a First Amendment compelled-speech claim.

Source
U.S. District Court, Western District of Texas (Waco Division)
Date
11 February 2026
Quoted from
Order, Part III.A (Likelihood of Success on the Merits)
Grade
Primary record
Document
https://www.wlf.org/wp-content/uploads/2025/12/TX-Order-Granting-PI-2_11_26.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Copy hosted by the Washington Legal Foundation; the docket (CourtListener/PACER) is the more primary copy. The order enjoins enforcement of Section 9 'against Plaintiffs or their members' (Part IV) and finds the preemption claims (FDCA, NLEA) not shown likely to succeed (Part III.A).

Exhibit 581 · State bill

New York Senate Bill S1239F (2025-26), Food Safety and Chemical Disclosure Act

Bill S1239F would ban Red No. 3, potassium bromate and propylparaben and would require companies to report GRAS substances to the state agriculture commissioner for a public database before sale, with exemptions for substances with an FDA no-questions letter or a federal GRAS listing and for businesses of ten or fewer employees. Passed the Senate 60-0 on 23 March 2026 and the Assembly on 21 April 2026. As of 10 November 2026 the bill page shows no delivery to the Governor, signature or veto.

Source
New York State Legislature
Date
21 April 2026 (Assembly passage)
Grade
Primary record
Document
https://www.nysenate.gov/legislation/bills/2025/S1239
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 582 · Law firm alert

More Than Research: Why the Coming Federal Definition of Ultra-Processed Foods Matters

Reports that more than 5,000 comments were filed on the 2025 request; that HHS and USDA announced on 10 August 2026 that a proposed definition had gone to OMB for final review as a white paper, not a regulation; that OMB's calendar lists Executive Order 12866 meetings on the white paper in September and October; and that the text had not been released as of 13 October 2026.

Source
Greenberg Traurig
Date
October 2026
Grade
Reported
Document
https://www.gtlaw.com/en/insights/2026/10/more-than-research-why-the-coming-federal-definition-of-ultra-processed-foods-matters
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Exhibit 583 · Government record

OIRA review record: HHS/FDA ultra-processed food whitepaper (RIN 0910-ZD60)

OIRA's review page for the HHS/FDA whitepaper 'Proposed Definition of Ultra-Processed Food' (RIN 0910-ZD60): received 3 August 2026, stage Notice, pending as of 10 November 2026. OIRA's page for the GRAS rule 'Substances Generally Recognized as Safe' (RIN 0910-AJ02) shows receipt 1 December 2025 and conclusion 31 July 2026, 'Consistent with Change' (https://www.reginfo.gov/public/do/eoDetails?rrid=1194761).

Source
Office of Information and Regulatory Affairs, reginfo.gov
Date
August 2026
Grade
Primary record
Document
https://www.reginfo.gov/public/do/eoDetails?rrid=1495413
Accessed
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Note
Food Safety Magazine (4 August 2026) reports the same two events.

Exhibit 584 · Research article

Sugar Industry and Coronary Heart Disease Research: A Historical Analysis of Internal Industry Documents

There is no direct evidence that the sugar industry wrote or changed the NEJM review manuscript; the evidence that the industry shaped the review’s conclusions is circumstantial.

Historical analysis of Sugar Research Foundation correspondence (319 documents from the Roger Adams papers, University of Illinois; 27 documents from the D. Mark Hegsted papers, Harvard Medical Library). Reports that the SRF's executive committee approved Project 226 on 13 July 1965, offered $500 to Hegsted and $1,000 to McGandy, and eventually paid $6,500 ($48,900 in 2016 dollars); that the resulting two-part review in the New England Journal of Medicine (1967) disclosed other funding of the authors but not the SRF's funding or participation; and that Hickson (SRF) told Hegsted on 30 July 1965 he would be disappointed if the sucrose aspect were 'drowned out' and on 2 November 1966 that the draft was 'quite what we had in mind'. States limitations: one trade association's papers, no interviews, no direct evidence of authorship or edits. An erratum is listed at JAMA Intern Med 2016;176(11):1729.

Source
Kearns CE, Schmidt LA, Glantz SA; JAMA Internal Medicine 176(11):1680-1685
Date
12 September 2016 (online); 1 November 2016 (print)
Quoted from
Discussion, 'Study Limitations' (NIH author manuscript, PMC5099084)
Grade
Peer-reviewed
Document
https://doi.org/10.1001/jamainternmed.2016.5394
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Exhibit 585 · Research article

Dietary fats, carbohydrates and atherosclerotic vascular disease (Part 1)

First part of the two-part literature review that Project 226 produced (N Engl J Med 277(4):186-192; PubMed 5339697). Kearns et al. (2016) describe its funding disclosure.

Source
McGandy RB, Hegsted DM, Stare FJ; New England Journal of Medicine 277(4):186-192
Date
27 July 1967
Grade
Peer-reviewed
Document
https://doi.org/10.1056/NEJM196707272770405
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Exhibit 586 · Research article

Dietary fats, carbohydrates and atherosclerotic vascular disease (Part 2)

Concluding part of the review (N Engl J Med 277(5):242-247). Kearns et al. (2016) quote its statement (p. 246) that there was 'no doubt' the only dietary intervention required to prevent coronary heart disease was reducing dietary cholesterol and substituting polyunsaturated for saturated fat.

Source
McGandy RB, Hegsted DM, Stare FJ; New England Journal of Medicine 277(5):242-247
Date
3 August 1967
Grade
Peer-reviewed
Document
https://doi.org/10.1056/NEJM196708032770505
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Exhibit 587 · Journalism

Sugar industry secretly paid for favorable Harvard research

We acknowledge that the Sugar Research Foundation should have exercised greater transparency in all of its research activities

Reports the Kearns paper and the Sugar Association's statement in response, which acknowledged that the SRF 'should have exercised greater transparency' and said it was 'challenging for us to comment on events that allegedly occurred 60 years ago, and on documents we have never seen'. Also quotes Glantz that the reviews 'helped shift the emphasis of the discussion away from sugar onto fat' and Nestle calling the findings a 'smoking gun'.

Source
STAT (Melissa Bailey)
Date
12 September 2016
Quoted from
Paragraph quoting the trade group (statement of 12 September 2016)
Grade
Reported
Document
https://www.statnews.com/2016/09/12/sugar-industry-harvard-research/
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Exhibit 588 · Journalism

50 Years Ago, Sugar Industry Quietly Paid Scientists To Point Blame At Fat

when the studies in question were published funding disclosures and transparency standards were not the norm they are today

Carries a longer version of the Sugar Association statement, including that when the studies in question were published, funding disclosures and transparency standards were not the norm they are today.

Source
NPR The Two-Way
Date
13 September 2016
Quoted from
Section headed 'Sugar lobby: Transparency standards were not the norm'
Grade
Reported
Document
https://www.npr.org/sections/thetwo-way/2016/09/13/493739074/50-years-ago-sugar-industry-quietly-paid-scientists-to-point-blame-at-fat
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Exhibit 589 · Committee print

Dietary Goals for the United States (first edition, Committee Print)

5. Reduce sugar consumption by about 40 percent to account for about 15 percent of total energy intake.

First edition of the Select Committee's Dietary Goals (chair: George McGovern). Lists six goals, the fifth being a reduction in sugar consumption. Contains the statements of Hegsted, Winikoff and Lee from the 14 January 1977 press conference; Hegsted is thanked in the text for working 'very closely and patiently' with the staff.

Source
U.S. Senate Select Committee on Nutrition and Human Needs
Date
February 1977
Quoted from
U.S. Dietary Goals, item 5, p. 12 (explanation at p. 43)
Grade
Primary record
Document
https://archive.org/details/CAT10527234
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Exhibit 590 · Congressional statement

Statement of Dr. D. M. Hegsted, Professor of Nutrition, Harvard School of Public Health (press conference, 14 January 1977)

The question to be asked, therefore, is not why should we change our diet but why not?

Hegsted's published statement on the diet of Americans, rich in 'meat, other sources of saturated fat and cholesterol, and in sugar'. Describes the diseases as having 'a complex etiology'. Contains the 'why not' passage on changing the diet, listing less saturated fat, less cholesterol and less sugar.

Source
D. Mark Hegsted, in Dietary Goals for the United States (first edition)
Date
14 January 1977
Quoted from
Statement of Dr. D. M. Hegsted, p. 3
Grade
Primary record
Document
https://archive.org/details/CAT10527234
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Same physical document as senate-1977-dietary-goals-first-edition; registered separately because it is Hegsted's own statement.

Exhibit 591 · Industry submission printed in a Senate committee print

Sucrose and Health: A Brief Submitted by the International Sugar Research Foundation to the Select Committee on Nutrition and Human Needs

"The Report" is misleading and will compound the confusion it intends to dispel

Industry brief, pp. 685-696 of the Supplemental Views (committee print, November 1977), objecting to the sucrose portions of the first edition. States that the ISRF was incorporated in 1968 as successor to the Sugar Research Foundation (founded 1943), with members in nine countries, and that it spends about $100,000 a year on research.

Source
International Sugar Research Foundation, in Dietary Goals for the United States: Supplemental Views
Date
1977
Quoted from
'General' paragraph, brief p. 685
Grade
Primary record
Document
https://archive.org/details/CAT78698154
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The submitter is the ISRF, not the Sugar Association.

Exhibit 592 · International report

Diet, Nutrition and the Prevention of Chronic Diseases (WHO Technical Report Series 916)

The Consultation recognized that a population goal for free sugars of less than 10% of total energy is controversial.

Joint expert consultation report (Geneva, 28 January-1 February 2002; published 2003). Table 6 sets a population goal for free sugars of under 10 percent of total energy. The text on free sugars says the goal is controversial and defends it by citing limits in studies that found no effect on weight.

Source
World Health Organization and Food and Agriculture Organization of the United Nations
Date
2003
Quoted from
Chapter 5, 'Free sugars', p. 56 (Table 6, p. 55)
Grade
Primary record
Document
https://www.who.int/publications/i/item/924120916X
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Note
Page numbers taken from the PDF text layer; confirm against the printed edition.

Exhibit 593 · Journalism

Sugar Lobbyists Sour On Study

One request was March 20 from a coalition of food industry groups, another March 28 from two U.S. senators, John Breaux, D-La., Larry Craig, R-Idaho.

Reports that Sugar Association president Andrew Briscoe wrote the WHO director general attacking the report; that HHS Secretary Tommy Thompson was asked to intervene, in one request on 20 March 2003 from a coalition of food industry groups and another on 28 March from Senators John Breaux (D-LA) and Larry Craig (R-ID), co-chairs of the Senate Sweetener Caucus; that the senators also wrote Agriculture Secretary Ann Veneman; and that Thompson did not respond before the 23 April release.

Source
Associated Press, via CBS News
Date
23 April 2003
Quoted from
AP via CBS News, 23 Apr. 2003, paragraph beginning 'Many governments, including the United States'
Grade
Reported
Document
https://www.cbsnews.com/news/sugar-lobbyists-sour-on-study
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CBS News hosts the AP wire text, not AP's own site. The Briscoe letter, the coalition letter and the Craig-Breaux letter are not online.

Exhibit 594 · Press release

Big sugar's "thuggish" tactics come under fire

Sugar Association president Andrew C. Briscoe III wrote that the association would ask “Congressional appropriators to challenge future funding of the U.S.’s $406 million contributions” to the WHO.

Advocacy-group release that quotes the Sugar Association's letter to WHO Director-General Brundtland: the association would ask Congress to challenge future funding of the U.S. contribution of $406 million, and attached a letter from Senators Larry Craig (R-ID) and John Breaux (D-LA) to two cabinet secretaries. Says copies of the letters were available from CSPI.

Source
Center for Science in the Public Interest
Date
21 April 2003
Quoted from
CSPI press release, updated 21 Apr. 2003, paragraph 3
Grade
Reported
Document
https://www.cspinet.org/new/200304211.html
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Note
Reported, advocacy source. Ask CSPI for the letters (contact named in the release) to replace this exhibit.

Exhibit 595 · Journalism (reprint)

Political context of the World Health Organization: sugar industry threatens to scupper the WHO

Abstract (read): the Sugar Association demanded that Congress end funding of the WHO unless the guidelines were withdrawn, and the association and six other food industry groups asked the HHS Secretary to use his influence to get the report withdrawn.

Source
Sarah Boseley (reprint of Guardian report of 21 April 2003), International Journal of Health Services 33(4):831-833
Date
2003
Grade
Reported
Document
https://doi.org/10.2190/U0MW-WM82-N5BH-E20C
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Reported; abstract only.

Exhibit 596 · Research article

Sugar industry influence on the scientific agenda of the National Institute of Dental Research's 1971 National Caries Program: a historical analysis of internal documents

Seventy-eight percent of the sugar industry submission was incorporated into the NIDR's call for research applications.

Historical analysis of cane and beet sugar industry documents, 1959-1971, on the NIDR's National Caries Program. This is the 2015 PLoS Medicine paper; it concerns tooth decay, not coronary heart disease.

Source
Kearns CE, Glantz SA, Schmidt LA; PLoS Medicine 12(3):e1001798
Date
10 March 2015
Quoted from
Abstract, Methods and Findings
Grade
Peer-reviewed
Document
https://doi.org/10.1371/journal.pmed.1001798
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Exhibit 597 · Journalism

Coca-Cola Funds Scientists Who Shift Blame for Obesity Away From Bad Diets

two universities that employ leaders of the Global Energy Balance Network disclosed that Coke had donated $1.5 million last year to start the organization

Reports that Coca-Cola provided financial and logistical support to the Global Energy Balance Network; that two universities disclosed, under open-records laws, a Coke donation of $1.5 million to start it; that Coke had given close to $4 million since 2008 to two of its founders; that gebn.org was registered to Coca-Cola headquarters; and Hill's statement that 'They're not running the show. We're running the show.' Includes Coca-Cola's statement on researcher independence.

Source
The New York Times (Anahad O'Connor)
Date
9 August 2015
Quoted from
Paragraph beginning 'Coke has made a substantial investment in the new nonprofit' (read in the Dallas Morning News syndicated copy)
Grade
Reported
Document
https://well.blogs.nytimes.com/2015/08/09/coca-cola-funds-scientists-who-shift-blame-for-obesity-away-from-bad-diets/
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Exhibit 598 · Journalism

University giving back $1M grant to Coca-Cola

the funding source has distracted attention from its worthwhile goal

Reports that the University of Colorado School of Medicine returned the $1 million Coca-Cola gift that funded the Global Energy Balance Network, that Coca-Cola said it would give the sum to the Boys & Girls Clubs of America, and that the American Academy of Pediatrics and the Academy of Nutrition and Dietetics, which had accepted $3 million and $1.7 million from Coca-Cola since 2010, ended their relationships after Coca-Cola's disclosure.

Source
Food Dive
Date
9 November 2015
Quoted from
Statement of the University of Colorado School of Medicine, as quoted
Grade
Reported
Document
https://www.fooddive.com/news/return-to-sender-university-giving-back-1m-grant-to-coca-cola/408831/
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Exhibit 599 · Journalism

Anti-obesity group funded by Coke disbanding

discontinuing operations due to resource limitations.

Reports that the Global Energy Balance Network said on its website on Monday night (30 November 2015) that it was discontinuing operations; that AP had reported emails showing Coke helped select the group's leaders, edited its mission statement and suggested website content; that Coke accepted the retirement of Rhona Applebaum, its chief health and science officer; and that Hill and Blair did not respond to requests for comment.

Source
CBS News / Associated Press
Date
1 December 2015
Quoted from
Second paragraph (statement posted by the network, 30 November 2015)
Grade
Reported
Document
https://www.cbsnews.com/amp/news/anti-obesity-group-funded-by-coke-global-energy-balance-network-disbanding
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Exhibit 600 · Research article

Evaluating Coca-Cola's attempts to influence public health 'in their own words': analysis of Coca-Cola emails with public health academics leading the Global Energy Balance Network

Coca-Cola sought to obscure its relationship with researchers, minimise the public perception of its role and use these researchers to promote industry-friendly messaging.

Thematic content analysis of 18,036 pages of Coca-Cola emails with academics at West Virginia University and the University of Colorado, obtained through state open-records requests by U.S. Right to Know in 2015-2016. Co-author Ruskin works for the group that obtained the emails.

Source
Serodio P, Ruskin G, McKee M, Stuckler D; Public Health Nutrition 23(14):2647-2653
Date
3 August 2020 (online)
Quoted from
Abstract, Conclusions
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S1368980020002098
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Exhibit 601 · Research article

Financial conflicts of interest and reporting bias regarding the association between sugar-sweetened beverages and weight gain: a systematic review of systematic reviews

Those reviews with conflicts of interest were five times more likely to present a conclusion of no positive association than those without them (relative risk: 5.0, 95% CI: 1.3–19.3).

Seventeen systematic reviews (18 conclusions). Six disclosed a food-industry financial conflict. Of 12 conclusions from reviews without a disclosed conflict, 10 (83.3 percent) found a potential risk for weight gain; of 6 conclusions from reviews with a disclosed conflict, 5 (83.3 percent) found the evidence insufficient. The authors state they cannot rule out publication bias among reviews declaring no conflict.

Source
Bes-Rastrollo M, Schulze MB, Ruiz-Canela M, Martinez-Gonzalez MA; PLoS Medicine 10(12):e1001578
Date
31 December 2013
Quoted from
Abstract, Methods and Findings
Grade
Peer-reviewed
Document
https://doi.org/10.1371/journal.pmed.1001578
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Exhibit 602 · Research article

Relationship between funding source and conclusion among nutrition-related scientific articles

Funding source was significantly related to conclusions when considering all article types (p = 0.037).

Reviews 206 articles on soft drinks, juice and milk (1999-2003). Among interventional studies, 0 percent of all-industry-funded studies had unfavorable conclusions versus 37 percent of studies with no industry funding.

Source
Lesser LI, Ebbeling CB, Goozner M, Wypij D, Ludwig DS; PLoS Medicine 4(1):e5
Date
9 January 2007
Quoted from
Abstract, Methods and Findings
Grade
Peer-reviewed
Document
https://doi.org/10.1371/journal.pmed.0040005
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Exhibit 603 · Research article

Association of Industry Sponsorship With Outcomes of Nutrition Studies: A Systematic Review and Meta-analysis

Although industry-sponsored studies were more likely to have conclusions favorable to industry than non-industry-sponsored studies, the difference was not significant.

Meta-analysis of 12 reports. Industry-sponsored nutrition studies were more likely to have favorable conclusions (risk ratio 1.31, 95% CI 0.99-1.72), a difference the authors call not significant. The authors say the findings suggest but do not establish an association.

Source
Chartres N, Fabbri A, Bero LA; JAMA Internal Medicine 176(12):1769-1777
Date
December 2016
Quoted from
Abstract, Conclusions and Relevance
Grade
Peer-reviewed
Document
https://doi.org/10.1001/jamainternmed.2016.6721
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Note
Included in this register as the closest counterweight to the sponsorship-bias findings.

Exhibit 604 · Cochrane systematic review

Reduction in saturated fat intake for cardiovascular disease (Cochrane Review CD011737)

The findings of this updated review suggest that reducing saturated fat intake for at least two years causes a potentially important reduction in combined cardiovascular events.

Fifteen randomized trials, 56,675 participants, at least 24 months. Reducing saturated fat lowered combined cardiovascular events (risk ratio 0.83, 95% CI 0.70 to 0.98, moderate-quality evidence). Little or no effect on all-cause mortality (RR 0.96, 0.90 to 1.03) or cardiovascular mortality (RR 0.95, 0.80 to 1.12).

Source
Hooper L, Martin N, Jimoh OF, Kirk C, Foster E, Abdelhamid AS; Cochrane Database of Systematic Reviews 2020(5):CD011737
Date
21 August 2020
Quoted from
Abstract, Authors' conclusions
Grade
Peer-reviewed
Document
https://doi.org/10.1002/14651858.CD011737.pub3
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Several trials gave more than saturated-fat advice.

Exhibit 605 · Scientific advisory

Dietary Fats and Cardiovascular Disease: A Presidential Advisory From the American Heart Association

replacement of saturated fat with mostly refined carbohydrates and sugars is not associated with lower rates of CVD and did not reduce CVD in clinical trials

American Heart Association advisory reviewing randomized trials and prospective cohorts. States that trials that lowered saturated fat and replaced it with polyunsaturated vegetable oil reduced CVD by about 30 percent, and that replacement with mostly refined carbohydrates and sugars is not associated with lower CVD rates.

Source
Sacks FM, Lichtenstein AH, Wu JHY, et al.; Circulation 136(3):e1-e23
Date
15 June 2017
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1161/CIR.0000000000000510
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Exhibit 606 · Cohort study

The diet and 15-year death rate in the seven countries study

Causal relationships are not claimed but consideration of characteristics of populations as well as of individuals within populations is urged in evaluating risks.

Fifteen cohorts, 11,579 men aged 40-59 at entry, 2,288 deaths in 15 years. Cohort death rates related positively to average saturated-fat share of energy and negatively to monounsaturated fat; unrelated to carbohydrate share. Cross-population comparison, 'causal relationships are not claimed'.

Source
Keys A, Menotti A, Karvonen MJ, et al.; American Journal of Epidemiology 124(6):903-915
Date
December 1986
Quoted from
Abstract, final sentence
Grade
Peer-reviewed
Document
https://doi.org/10.1093/oxfordjournals.aje.a114480
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Exhibit 607 · Opinion

Sugar review: Rewriting history to expose a non-existent conspiracy

Dr Kearns presents no evidence that McGandy, Stare and Hegsted did anything dishonest.

Opinion piece by the chief executive of an industry association whose members include grocery suppliers and one sugar refinery (her own disclosure in the piece). Argues that the SRF correspondence was 'relatively innocuous', that a single literature review could not have derailed the debate, that McGandy and Stare had no correspondence with the SRF, and that Keys and the American Heart Association dominated the field. Quotes Walter Willett on Hegsted.

Source
Katherine Rich, FoodNavigator
Date
19 September 2016
Quoted from
Section beginning 'Communications from the academics to the foundation's research director'
Grade
Reported
Document
https://www.foodnavigator.com/Article/2016/09/19/Sugar-review-Rewriting-history-to-expose-a-non-existent-conspiracy/
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Reported opinion. The strongest rebuttal found; no peer-reviewed rebuttal by 'Erickson et al. 2017' was located. Willett quote (second hand): 'I very much doubt that he changed what he believed or would conclude based on industry funding.'

Exhibit 608 · Agency research report

Concentration and Competition in U.S. Agribusiness (Economic Information Bulletin 256)

In 2019, the four largest meatpackers accounted for 85 percent of steer and heifer slaughter and 67 percent of hog slaughter.

Reviewed by ERS technical peers before release. Table 6 (p. 25) gives four-firm concentration ratios (CR4) from Packers and Stockyards Program reports: steers and heifers 36 (1980), 81 (1995), 85 (2010), 85 (2019); hogs 34, 46, 65, 67; broilers 50 (1995), 51, 53; turkeys 41 (1995), 56, 55. Table 1 (p. 11) gives seed shares. Pp. 19-23 describe the Dow-DuPont, ChemChina-Syngenta and Bayer-Monsanto reviews and the divestitures. P. 15 reports seed prices up 270 percent from 1990 to 2020 against 56 percent for commodities and says the evidence is mixed on whether concentration caused the rise. P. 32 reports the farm-to-wholesale beef spread doubled between 2015 and 2019. P. 36 concludes that concentration came mostly from larger plants rather than mergers, that pre-2010 studies found limited packer market power, and that post-2010 spreads suggest more market power. Pp. 34-35 summarize the DOJ chicken cases, including that "individual defendants were acquitted in jury trials."

Source
USDA Economic Research Service (MacDonald, Dong and Fuglie)
Date
June 2023
Quoted from
Summary page, "What Did the Study Find?", first bullet
Grade
Primary record
Document
https://www.ers.usda.gov/webdocs/publications/106795/eib-256.pdf
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Exhibit 609 · Agency annual report

Packers and Stockyards Division Annual Report 2020

Concentration in steer and heifer purchases ranged from 83 to 85 percent in the past decade.

Table 5 (p. 10) gives annual CR4 for 2010-2019: steers and heifers 83 to 85; hogs 62 to 70 (67 in 2019); broilers 50 to 54 (53 in 2019); turkeys 53 to 58 (55 in 2019). Says regional markets are more concentrated than national figures and that about 22 percent of broiler growers have one integrator in their area. This is the underlying series ERS used for Table 6.

Source
USDA Agricultural Marketing Service, Packers and Stockyards Division
Date
2020 (data through 2019)
Quoted from
p. 9, "Concentration in Meat Packing and Poultry Processing"
Grade
Primary record
Document
https://www.ams.usda.gov/sites/default/files/media/PackersandStockyardsAnnualReport2020.pdf
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Reports after the 2020 edition (2021-2024) were not retrievable; CR4 after 2019 is a gap.

Exhibit 610 · GAO report

U.S. Department of Agriculture: Additional Data Analysis Could Enhance Monitoring of U.S. Cattle Market (GAO-18-296)

Evidence of this effect alone does not imply that packers engaged in anticompetitive or improper behavior.

GAO modeled 2013-2015 fed cattle transactions. Fed cattle prices in less concentrated areas (HHI at the 25th percentile) may have been about 9 percent higher than in more concentrated areas (75th percentile). GAO found competition levels did not appear to affect the national price change in 2015, reports that the CFTC found no evidence of trading irregularities in cattle futures in 2015, and recommended that USDA review whether Packers and Stockyards staff can get daily transaction data.

Source
U.S. Government Accountability Office
Date
April 2018
Quoted from
p. 16
Grade
Primary record
Document
https://www.gao.gov/assets/gao-18-296.pdf
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2026-11-09
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Exhibit 611 · CRS report

Recent Acquisitions of U.S. Meat Companies (CRS Report RS22980)

On October 20, 2008, DOJ and 13 states filed a complaint in U.S. District Court to block the JBS buyout of National Beef Packing Company, citing concerns that it could contribute to higher consumer prices and also lower producer prices.

Records that DOJ and 13 states sued on 20 October 2008 to block JBS from buying National Beef and that DOJ declined to challenge JBS buying Smithfield Beef. ERS (EIB-256, p. 35) records that JBS then dropped the National Beef purchase.

Source
Congressional Research Service (Renee Johnson)
Date
30 October 2008
Quoted from
Abstract, p. 1
Grade
Primary record
Document
https://stuff.mit.edu/afs/sipb.mit.edu/contrib/wikileaks-crs/wikileaks-crs-reports/RS22980.pdf
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2026-11-09
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The copy read is a WikiLeaks mirror of the CRS report.

Exhibit 612 · Federal Register proposed rule

Implementation of Regulations Required Under Title XI of the Food, Conservation and Energy Act of 2008; Conduct in Violation of the Act (75 FR 35338)

The new regulations that GIPSA is proposing would describe and clarify conduct that violates the P&S Act and allow for more effective and efficient enforcement by GIPSA.

Obama-administration USDA proposal to describe conduct that violates the Packers and Stockyards Act. Only some provisions were finalized on 9 December 2011 (76 FR 76874), which said the "Other provisions listed in the June 22, 2010, proposed rule are not being finalized at this time."

Source
USDA Grain Inspection, Packers and Stockyards Administration
Date
22 June 2010
Quoted from
Federal Register abstract (Summary)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2010-06-22/pdf/2010-14875.pdf
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Exhibit 613 · Statute

Consolidated and Further Continuing Appropriations Act, 2012, Pub. L. 112-55, Division A, sec. 721

None of the funds made available by this or any other Act may be used to write, prepare, or publish a final rule or an interim final rule in furtherance of, or otherwise to implement,

Appropriations rider barring funds to write, prepare or publish a final or interim final rule implementing 75 FR 35338 unless the combined annual cost to the economy did not exceed $100,000,000, and barring funds for named proposed sections (201.2(l), 201.2(t), 201.2(u), 201.3(c), 201.210, 201.211, 201.213, 201.214). Enacted in an appropriations act that passed a Congress controlled by both parties (House Republican, Senate Democratic) and was signed by President Obama.

Source
U.S. Congress
Date
18 November 2011
Quoted from
Div. A, sec. 721
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-112publ55/html/PLAW-112publ55.htm
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Who sought the rider is not documented here; lobbying disclosures or committee records would be needed before a lobbying tag.

Exhibit 614 · Federal Register interim final rule

Scope of Sections 202(a) and (b) of the Packers and Stockyards Act (81 FR 92566)

This interim final rule reiterates USDA's longstanding interpretation that not all violations of the P&S Act require a showing of harm or likely harm to competition.

Obama-administration interim final rule clarifying that conduct can violate sections 202(a) and (b) without a finding of harm or likely harm to competition. Withdrawn on 18 October 2017.

Source
USDA Grain Inspection, Packers and Stockyards Administration
Date
20 December 2016
Quoted from
Federal Register abstract (Summary)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2016-12-20/pdf/2016-30424.pdf
Accessed
2026-11-09
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Exhibit 615 · Federal Register final rule (withdrawal)

Scope of Sections 202(a) and (b) of the Packers and Stockyards Act; withdrawal of interim final rule (82 FR 48594)

GIPSA is withdrawing the IFR because of serious legal and policy concerns related to its promulgation and implementation.

Trump-administration withdrawal. Cites decisions of the Fifth, Sixth, Tenth and Eleventh Circuits and others requiring proof of competitive harm, and says the interim rule's good-cause justification for skipping notice and comment was inadequate.

Source
USDA Grain Inspection, Packers and Stockyards Administration
Date
18 October 2017
Quoted from
Section IV, first sentence
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2017-10-18/pdf/2017-22593.pdf
Accessed
2026-11-09
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Exhibit 616 · Federal Register final rule

Undue and Unreasonable Preferences and Advantages Under the Packers and Stockyards Act (85 FR 79779)

This final rule establishes a new regulation containing criteria the Secretary of Agriculture will consider when determining whether an undue or unreasonable preference or advantage has occurred in violation of the Packers and Stockyards Act, 1921 (Act).

Trump-administration final rule (effective 11 January 2021) implementing a 2008 Farm Bill requirement. The preamble records commenters who said it left the Act "largely unenforceable for individual farmers and ranchers" because it did not restate that violations can occur without competitive injury, and says the listed criteria "are not safe harbors." The Biden White House later called the Act "systematically weakened by the Trump Administration USDA."

Source
USDA Agricultural Marketing Service
Date
11 December 2020
Quoted from
Federal Register abstract (Summary)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2020-12-11/pdf/2020-27117.pdf
Accessed
2026-11-09
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Exhibit 617 · Federal Register final rule

Inclusive Competition and Market Integrity Under the Packers and Stockyards Act (89 FR 16092)

The purpose of this rule is to promote inclusive competition and market integrity in the livestock, meats, poultry, and live poultry markets.

Biden-administration final rule (effective 6 May 2024) prohibiting undue prejudice and unjust discrimination on a prohibited basis, identifying retaliation as unjust discrimination, and identifying deceptive practices in contract formation, performance, termination and refusal. No later Federal Register action rescinding it was found in a search of documents published after 20 January 2025.

Source
USDA Agricultural Marketing Service
Date
6 March 2024
Quoted from
Federal Register abstract (Summary)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2024-03-06/pdf/2024-04419.pdf
Accessed
2026-11-09
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Exhibit 618 · Federal Register final rule (delay)

Poultry Grower Payment Systems and Capital Improvement Systems; Delay of Effective Date (91 FR 32314)

to allow time for further consideration of actions that may be taken regarding the disposition of the rule

Delays from 1 July 2026 to 31 December 2027 the effective date of the Biden-era rule published 16 January 2025 (90 FR 5146) on broiler grower tournament payments. The notice cites the explanatory statement to the Continuing Appropriations Act, 2026 (Pub. L. 119-37), which encouraged USDA to delay the rule, and describes more than 2,800 comments.

Source
USDA Agricultural Marketing Service
Date
1 June 2026
Quoted from
Federal Register abstract (Summary)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2026-06-01/pdf/2026-10880.pdf
Accessed
2026-11-09
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Exhibit 619 · White House fact sheet

FACT SHEET: The Biden-Harris Action Plan for a Fairer, More Competitive, and More Resilient Meat and Poultry Supply Chain

Four large meat-packing companies control 85 percent of the beef market.

Gives top-four shares of 85 percent (beef), 54 percent (poultry) and about 70 percent (pork). Commits $1 billion in American Rescue Plan funds to independent processing capacity, new Packers and Stockyards rules, a DOJ-USDA complaint portal and "Product of USA" labeling. States that ranchers got over 60 cents of each consumer beef dollar fifty years earlier against about 39 cents then (source of that figure not stated in the fact sheet). Says the Packers and Stockyards Act "was systematically weakened by the Trump Administration USDA." These are administration statements, not agency findings.

Source
The White House (Biden administration)
Date
3 January 2022
Quoted from
Third paragraph
Grade
Primary record
Document
https://bidenwhitehouse.archives.gov/briefing-room/statements-releases/2022/01/03/fact-sheet-the-biden-harris-action-plan-for-a-fairer-more-competitive-and-more-resilient-meat-and-poultry-supply-chain/
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Exhibit 620 · Executive order

Executive Order 14424: Promoting Fair Competition in Livestock Markets and Expanding Market Access for American Meat Producers (91 FR 57761)

avoid being overcharged by monopolistic practices by meat processors

Directs USDA to prioritize and expand Packers and Stockyards Act investigations, add staff, coordinate with DOJ under the 26 September 2025 memorandum of understanding, and report within 60 days; also directs steps to widen interstate sale of state-inspected meat and a guaranteed loan program for small and regional beef processors. Creates no enforceable rights (sec. 4(c)).

Source
The White House (Trump administration)
Date
4 September 2026 (published 10 September 2026)
Quoted from
Sec. 1 (Purpose)
Grade
Primary record
Document
https://www.federalregister.gov/documents/2026/09/10/2026-18567/promoting-fair-competition-in-livestock-markets-and-expanding-market-access-for-american-meat
Accessed
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Exhibit 621 · Memorandum of understanding

Memorandum of Understanding between the Antitrust Division, Department of Justice, and the Department of Agriculture: Cooperation with Respect to Strengthening Competition for Agricultural Inputs

committed to protecting American farmers from the burdens imposed by high and volatile input costs

Working-level MOU covering feed, fertilizer, fuel, seed, equipment and pesticides. DOJ announced it through a press release quoting Assistant Attorney General Abigail Slater (justice.gov/opa/pr/justice-department-and-usda-coordinate-protect-competition-agricultural-inputs).

Source
DOJ Antitrust Division and USDA
Date
26 September 2025
Quoted from
Paragraph 2
Grade
Primary record
Document
https://www.justice.gov/atr/media/1415501/dl
Accessed
2026-11-09
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Exhibit 622 · Congressional letter

Letter from 19 U.S. Senators to Attorney General William Barr requesting a DOJ investigation of the cattle industry

request that the DOJ investigate suspected price manipulation and anticompetitive behavior in the highly concentrated cattle industry

Signed by Republican and Democratic senators (including Doug Jones, Tina Smith and Tammy Baldwin). Reports that live cattle prices fell more than 18 percent from February while wholesale beef rose as much as 115 percent, and relays a 5 May 2020 request from eleven state attorneys general.

Source
U.S. Senators (Fischer, Crapo, Daines, Jones, Enzi, Rounds, Hoeven, Smith, Cramer, Hyde-Smith and others)
Date
12 May 2020
Quoted from
Paragraph 1
Grade
Primary record
Document
https://www.hydesmith.senate.gov/sites/default/files/2020-05/051220-DOJ%20Packers%20Investigation%20Request%20-%20Final.pdf
Accessed
2026-11-09
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Exhibit 623 · Trade association statement

Meat Institute Issues Statement on Beef Processing Sector DOJ Investigation

Despite high consumer prices for beef, beef packers have been losing money because the price of cattle is at record highs,

Industry position: packers are operating at a loss because cattle prices are at record highs, and the industry welcomes a "fact-based discussion about beef affordability." A position statement, not evidence of packer margins.

Source
North American Meat Institute
Date
7 November 2025
Quoted from
Paragraph 2
Grade
Primary record
Document
https://mail.meatinstitute.org/node/917
Accessed
2026-11-09
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Note
Date taken from search-result metadata; the page copy read does not print the date.

Exhibit 624 · Journalism

US Justice Department probes meatpackers, attorney general says (Reuters, via U.S. News)

Reports that President Trump posted on 7 November 2025 that he had asked DOJ to investigate "the Meat Packing Companies who are driving up the price of Beef through Illicit Collusion, Price Fixing, and Price Manipulation," and that Attorney General Pam Bondi replied on X that an investigation was underway. NBC News and Farm Policy News (University of Illinois) report the same events.

Source
Reuters
Date
7 November 2025
Grade
Reported
Document
https://money.usnews.com/investing/news/articles/2025-11-07/trump-says-he-asked-doj-to-investigate-meat-packing-companies-for-driving-up-beef-prices
Accessed
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Exhibit 625 · Journalism

U.S. attorney general probing beef packers seeks tips from ranchers (Capital Press)

Reports the 4 May 2026 announcement by Acting Attorney General Todd Blanche of antitrust investigations of meatpacking, with more than three million documents reviewed and whistleblower awards of up to 30 percent for criminal penalties above $1 million. DOJ lists the event on its site as the video "Acting Attorney General Blanche Announces Antitrust Investigations on Meatpacking Operations" (4 May 2026).

Source
Capital Press
Date
5 May 2026
Grade
Reported
Document
https://capitalpress.com/2026/05/05/u-s-attorney-general-probing-beef-packers-seeks-tips-from-ranchers/
Accessed
2026-11-09
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Exhibit 626 · Press release

One of the Nation's Largest Chicken Producers Pleads Guilty to Price Fixing and is Sentenced to a $107 Million Criminal Fine (Press Release 21-172)

Pilgrim’s is the first company to plead guilty for its role in a conspiracy to fix prices and rig bids for broiler chicken products.

Pilgrim's Pride pleaded guilty in D. Colo. and was sentenced to a criminal fine of $107,923,572 for a conspiracy "from as early as 2012 and continuing at least into 2017" affecting at least $361 million in its sales. Ten executives and employees at broiler producers had been charged.

Source
DOJ Antitrust Division
Date
23 February 2021
Quoted from
Paragraph beginning "Pilgrim’s is the first company"
Grade
Primary record
Document
https://www.justice.gov/archives/opa/pr/one-nation-s-largest-chicken-producers-pleads-guilty-price-fixing-and-sentenced-107-million
Accessed
2026-11-09
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Exhibit 627 · Press release

Justice Department Sues Agri Stats for Operating Extensive Information Exchanges Among Meat Processors

The Justice Department filed a civil antitrust lawsuit against Agri Stats Inc. today for organizing and managing anticompetitive information exchanges among broiler chicken, pork and turkey processors.

Complaint in United States v. Agri Stats Inc., No. 0:23-cv-03009 (D. Minn.), filed under Assistant Attorney General Jonathan Kanter, alleging Sherman Act section 1 violations through information exchanges in broiler chicken, pork and turkey. Six states later joined.

Source
DOJ Antitrust Division
Date
28 September 2023
Quoted from
DOJ Office of Public Affairs press release, 28 Sept. 2023, first paragraph (Wayback snapshot 2025-02-05)
Grade
Primary record
Document
https://www.justice.gov/opa/pr/justice-department-sues-agri-stats-operating-extensive-information-exchanges-among-meat
Accessed
2026-11-09
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Exhibit 628 · Press release

Justice Department Requires Agri Stats to End Exchange of Competitively Sensitive Information Among Nation's Largest Meat Processors (Press Release 26-453)

When companies decide certain information is too sensitive to share with the broader market, but not too sensitive to share with their closest competitors, that is a significant red flag that competition is being harmed

Proposed settlement filed in D. Minn. with California, Minnesota, North Carolina, Tennessee, Texas and Utah. If approved, Agri Stats must stop providing sales reports and non-public pricing information, stop reporting company- or facility-level production, cost and labor data, offer most other information to buyers on reasonable terms, and report to a court-approved monitor. The release says "As alleged in the complaint" the exchange reduced competition; the company's subsidiary Express Markets may continue its price reports.

Source
DOJ Antitrust Division and Office of the Attorney General
Date
7 May 2026
Quoted from
Paragraph beginning "Agri Stats is a data-sharing and consulting company" (Acting Assistant Attorney General Omeed A. Assefi)
Grade
Primary record
Document
https://www.justice.gov/opa/pr/justice-department-requires-agri-stats-end-exchange-competitively-sensitive-information
Accessed
2026-11-09
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Exhibit 629 · SEC periodic report

Tyson Foods, Inc., Form 10-Q for the quarter ended 27 June 2026 (Contingencies: Broiler, Pork and Beef Antitrust Litigation; DOJ civil investigative demands)

While we do not admit any liability as part of the settlements

Broiler classes: aggregate $221.5 million, final approvals June 2021 to April 2022; first broiler trial (direct purchasers, September-October 2023) ended in a verdict for the defendants without Tyson. Tyson self-reported to DOJ and received conditional leniency in August 2021. Pork: Tyson agreed to $50 million (direct), $85 million (consumer indirect) and $48 million (commercial and institutional indirect). Beef: $55 million (consumer indirect, paid 26 November 2025), $80 million plus $2.5 million expenses (direct), $47 million (commercial and institutional indirect, paid 2 June 2026); court granted certain class certification motions on 16 July 2026; Tyson has received civil investigative demands from DOJ about its beef business. Plaintiffs allege conspiracies from January 2008 (broilers), January 2009 (pork) and about January 2015 (beef).

Source
Tyson Foods, Inc. (SEC filing)
Date
3 August 2026
Quoted from
Note "Commitments and Contingencies," Broiler Antitrust Civil Litigation, "Settlements"
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/100493/000010049326000058/tsn-20260627.htm
Accessed
2026-11-09
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Exhibit 630 · SEC annual report

JBS S.A., Form 20-F for the fiscal year ended 31 December 2024 (Legal proceedings: Broiler, Pork and Beef Antitrust Litigation)

JBS USA has settled with three of the purported classes in the U.S. Beef Antitrust Litigation, for an aggregate amount of US$161.0 million

JBS USA: three beef classes settled for $161.0 million aggregate ($77.5 million paid 2023, $83.5 million unpaid at 31 December 2024 pending court approval); three pork classes $57.3 million, paid 2021. Pilgrim's Pride (about 83 percent owned by JBS): three broiler classes $195.5 million, paid 2021; broiler opt-out settlements recognized $582.5 million through 2024 with $512.2 million paid; grower class $100.0 million (final approval 7 January 2025). JBS says it continues to defend the remaining classes.

Source
JBS S.A. (SEC filing)
Date
26 March 2025
Quoted from
Item 8, Legal Proceedings, "Beef Antitrust Litigation"
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1450123/000101376225002376/ea0234555-20f_jbssa.htm
Accessed
2026-11-09
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Exhibit 631 · SEC periodic report

U.S. Premium Beef, LLC, Form 10-Q for the quarter ended 26 September 2026 (Note 10, Legal Proceedings, describing National Beef Packing Company)

In September 2025, NBP received notice from the DOJ that it was closing the federal investigation, and then in November 2025 the DOJ initiated a new civil antitrust investigation.

USPB holds an interest in National Beef (NBP). NBP discloses that it is subject to a DOJ and roughly 30 state attorney general investigation of fed cattle and beef packing markets; on 16 July 2026 the District of Minnesota certified four classes (fed-cattle sellers, direct purchasers, commercial and institutional indirect purchasers, consumer indirect purchasers) and denied two; the Eighth Circuit granted Rule 23(f) review; NBP "believes it has meritorious defenses"; on 28 September 2026 DOJ filed a statement of interest objecting to pending wage-fixing settlements for lack of injunctive relief.

Source
U.S. Premium Beef, LLC (SEC filing)
Date
6 November 2026
Quoted from
Note 10, Legal Proceedings
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1289237/000168316826008383/uspb_i10q-092626.htm
Accessed
2026-11-09
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Note
National Beef does not file with the SEC; this is its minority owner's disclosure.

Exhibit 632 · Agency report

More and Better Choices for Farmers: Promoting Fair Competition and Innovation in Seeds and Other Agricultural Inputs

Today, the top four (Bayer, Corteva, ChemChina and BASF) own 97% of canola, 95% of corn, 84% of soybean, 51% of wheat, and 74% of cotton IP.

Biden-administration report. Executive summary (p. 3) says "business developments arising from multiple decades of mergers and acquisitions have led to an increasingly consolidated marketplace," and records that "Many commenters agreed that a system that fairly protects IP is critical to continued innovation and investment in seed systems" (p. 4). Its own analysis (p. 42; Appendix B) counts plant variety protection certificates and patents mentioning crop names in the title or abstract from 1970 to 2022. For corn, the top four owned 41 percent in 1990 and 77 percent in 2000.

Source
USDA Agricultural Marketing Service (with USPTO), report under Executive Order 14036
Date
March 2023
Quoted from
p. 42 of 86
Grade
Primary record
Document
https://www.ams.usda.gov/sites/default/files/media/SeedsReport.pdf
Accessed
2026-11-09
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Exhibit 633 · Press release

Justice Department Requires Divestiture of Certain Herbicides, Insecticides, and Plastics Businesses in Order to Proceed with Dow-Dupont Merger

will require The Dow Chemical Company (Dow) and E.I. DuPont de Nemours & Co. (DuPont) to divest multiple crop protection and two petrochemical products to proceed with their proposed merger valued at about $130 billion

DOJ, with the Iowa, Mississippi and Montana attorneys general, sued to enjoin the merger and filed a settlement requiring divestiture of DuPont's Finesse and Rynaxypyr crop protection products and two petrochemical products.

Source
DOJ Antitrust Division
Date
15 June 2017
Quoted from
Paragraph 1
Grade
Primary record
Document
https://www.justice.gov/opa/pr/justice-department-requires-divestiture-certain-herbicides-insecticides-and-plastics
Accessed
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Exhibit 634 · Press release

Justice Department Secures Largest Merger Divestiture Ever to Preserve Competition Threatened by Bayer's Acquisition of Monsanto (Press Release 18-698)

the largest merger divestiture ever required by the United States

DOJ required Bayer to divest businesses and assets of about $9 billion to BASF as a condition of its $66 billion purchase of Monsanto, including cotton, canola, soybean and vegetable seed businesses, the Liberty herbicide business, seed treatment businesses, pipeline R&D and the digital agriculture business. Says that without the divestitures the merger "would likely result in higher prices, lower quality, and fewer choices."

Source
DOJ Antitrust Division
Date
29 May 2018
Quoted from
Paragraph 2 (Assistant Attorney General Makan Delrahim)
Grade
Primary record
Document
https://www.justice.gov/archives/opa/pr/justice-department-secures-largest-merger-divestiture-ever-preserve-competition-threatened
Accessed
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Exhibit 635 · Federal Register notice

United States v. Bayer AG et al.; Response to Public Comments (84 FR 1493)

order a retrospective study of the effects of the merger on competition two years after transfer of the divestiture assets has begun

Case No. 1:18-cv-01241 (D.D.C.). Commenters included five state attorneys general (California, Iowa, Massachusetts, Mississippi, Oregon), NRDC, the Consumer Federation of America and Syngenta. Syngenta said the decree "remedies many of the most complex and difficult anticompetitive aspects of the transaction"; a former FTC remedies official said the divestiture "appears to be as robust a divestiture as might be imagined"; the Consumer Federation argued the merged firm should have divested stronger assets. Entry date of the final judgment not found.

Source
DOJ Antitrust Division
Date
4 February 2019
Quoted from
84 FR 1497 (comment of the State Attorneys General)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2019-02-04/html/2019-00810.htm
Accessed
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Exhibit 636 · Agency report

Competition and Agriculture: Voices from the Workshops on Agriculture and Antitrust Enforcement in our 21st Century Economy and Thoughts on the Way Forward

Participants offered varied—and at times contradictory—accounts of the problems they face and the solutions they envision.

Reports on the 2010 DOJ-USDA workshops (opening remarks by Assistant Attorney General Christine Varney, 12 March 2010). Lists recurring themes including market concentration, merger enforcement, monopsony, bid rigging, market manipulation, captive supply and contracting; says the Division "has redoubled its efforts to prevent anticompetitive agricultural mergers and conduct."

Source
DOJ Antitrust Division
Date
May 2012
Quoted from
p. 1
Grade
Primary record
Document
https://www.justice.gov/atr/public/reports/283291.pdf
Accessed
2026-11-09
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Exhibit 637 · Court opinion

Bowman v. Monsanto Co., 569 U.S. 278 (2013), No. 11-796

Patent exhaustion does not permit a farmer to reproduce patented seeds through planting and harvesting without the patent holder’s permission.

Argued 19 February 2013. Indiana farmer Vernon Bowman bought commodity soybeans from a grain elevator, planted them, and saved seed from the Roundup Ready progeny for eight crops. The district court awarded Monsanto $84,456. The Court affirmed and said its holding was "limited" to the situation before it. The Court reasoned that a contrary rule would leave Monsanto's patent with "scant benefit."

Source
Supreme Court of the United States (Kagan, J., unanimous)
Date
13 May 2013
Quoted from
Syllabus, Held
Grade
Primary record
Document
https://www.supremecourt.gov/opinions/12pdf/11-796_c07d.pdf
Accessed
2026-11-09
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Exhibit 638 · Press release

FTC, States Secure Settlement with Deere & Company, Advancing Farmers' Right to Repair

By withholding these repair capabilities, the complaint alleged Deere unlawfully acquired and maintained monopoly power in markets for repair services for Deere farm equipment.

The FTC and Illinois, Arizona, Michigan, Minnesota and Wisconsin sued Deere in January 2025 (N.D. Ill.). The proposed stipulated order requires Deere, for ten years, to give farmers and independent repairers repair resources equivalent to those it gives dealers. Commission vote 2-0. A settlement, not a finding.

Source
Federal Trade Commission
Date
8 July 2026
Quoted from
Paragraph 5
Grade
Primary record
Document
https://www.ftc.gov/news-events/news/press-releases/2026/07/ftc-states-secure-settlement-deere-company-advancing-farmers-right-repair
Accessed
2026-11-09
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Exhibit 639 · Foundation press release

Bill & Melinda Gates, Rockefeller Foundations Form Alliance to Help Spur "Green Revolution" in Africa

The Alliance for a Green Revolution in Africa’s first investment of $150 million ($100 million from the Gates Foundation and $50 million from the Rockefeller Foundation) will support the Program for Africa’s Seed Systems (PASS).

Announces the Alliance for a Green Revolution in Africa. PASS budget: $43 million breeding, $20 million training, $24 million seed delivery, $37 million agro-dealers, $26 million management and evaluation.

Source
Bill & Melinda Gates Foundation and the Rockefeller Foundation
Date
September 2006
Quoted from
Paragraph beginning "The Alliance for a Green Revolution in Africa’s first investment"
Grade
Primary record
Document
https://gatesfoundation.org/media-center/press-releases/2006/09/foundations-form-alliance-to-help-spur-green-revolution-in-africa
Accessed
2026-11-09
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Note
Day of month not shown in the page copy read.

Exhibit 640 · University working paper

Failing Africa's Farmers: An Impact Assessment of the Alliance for a Green Revolution in Africa (GDAE Working Paper 20-01)

We find little evidence of widespread progress on any of AGRA’s goals

Uses national FAO and World Bank data because AGRA declined to provide its monitoring and evaluation data. Reports maize yields up 29 percent over 12 years, staple crop yields up 18 percent, and FAO undernourishment up 30 percent in AGRA's 13 countries; AGRA received about $1 billion, two-thirds from the Gates Foundation. A working paper that was not peer reviewed; the research was supported by the Rosa Luxemburg Stiftung (note 1), which also published the NGO report "False Promises."

Source
Global Development and Environment Institute, Tufts University (Timothy A. Wise)
Date
July 2020
Quoted from
Abstract, p. 1
Grade
Primary record
Document
https://bpb-us-e1.wpmucdn.com/sites.tufts.edu/dist/0/5123/files/2020/07/20-01_Wise_FailureToYield.pdf
Accessed
2026-11-09
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Note
Not peer reviewed. Grade is primary because the exhibit is the issuer's own document; the text must say it is an assessment by one research group, not an adjudication.

Exhibit 641 · NGO report

False Promises: The Alliance for a Green Revolution in Africa (AGRA)

Documentation on AGRA’s policy initiatives is scant although it claims some credit for assisting in the passing of policy reforms and regulations that advance the Green Revolution agenda.

Advocacy report built on Wise's working paper. On p. 10 it says AGRA documents its seed policy work in a report with the stated goal of "seed policy and regulatory reforms that enable investment and growth of private sector seed businesses," that AGRA supported ARIPO-aligned seed policy reforms in Burkina Faso, Ghana, Nigeria and Tanzania, and that UPOV 1991-type rules limit farmers' rights to save, exchange and sell seed. It says documentation of AGRA's policy work is scant and that other initiatives pushed the same reforms.

Source
Rosa Luxemburg Stiftung, INKOTA-netzwerk, PELUM Zambia, BIBA-Kenya, IRPAD, TABIO and others
Date
July 2020
Quoted from
RLS, False Promises: AGRA, section on AGRA's policy initiatives, PDF p. 12 (register gives p. 10 as printed)
Grade
Reported
Document
https://www.rosalux.de/fileadmin/rls_uploads/pdfs/Studien/False_Promises_AGRA_en.pdf
Accessed
2026-11-09
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Exhibit 642 · Correspondence

Letter from Andrew Cox, AGRA Chief of Staff and Strategy, to PELUM-Zambia, BIBA-Kenya and HOMEF (with the 7 September 2020 request and the 7 October 2020 reply)

Our headline goals have not changed. We do aspire to double incomes and yields, and would very much like to see this happen

AGRA's written answer to the African organizations' six questions. The critics' 7 October reply says AGRA offered no evidence of impact. Several figures in the PDF text layer are garbled and are not used.

Source
Alliance for a Green Revolution in Africa (as published by U.S. Right to Know)
Date
2020 (letter printed as 1 September 2020)
Quoted from
Cox letter, section "What are AGRA's goals and are we achieving them? What about yields?"
Grade
Reported
Document
https://usrtk.org/wp-content/uploads/2020/10/Correspondence-BIBA-and-AGRA-accountability.pdf
Accessed
2026-11-09
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Note
Hosted by an advocacy organization. The printed date (1 September 2020) precedes the 7 September request it answers, so the true date needs checking.

Exhibit 643 · SEC Form 13F

Form 13F-HR, Bill & Melinda Gates Foundation Trust, quarter ended 30 June 2010

MONSANTO CO NEW COM 61166W101 23,110 500,000 SH SOLE 500,000

The information table lists 31 positions worth $11,853,345 thousand in total, including 500,000 shares of Monsanto Co. valued at $23,110 thousand (0.2 percent of the table). The same 500,000 shares appear in the 13F filings for 30 September 2010 ($23,965 thousand), 31 December 2010 ($34,820 thousand), 31 March 2011 ($36,130 thousand), 30 June 2011 ($36,270 thousand) and 30 September 2011 ($30,020 thousand). Monsanto does not appear in the filings for 31 December 2009, 31 March 2010 or 31 December 2011. Signed by Michael Larson as authorized agent.

Source
Bill & Melinda Gates Foundation Trust (SEC filing)
Date
16 August 2010
Quoted from
Form 13F information table, Monsanto row
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1166559/000104746910007567/a2199827z13f-hr.txt
Accessed
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Note
Whitespace in the table row collapsed. The filing shows a holding and its value, not the reason for it.

Exhibit 644 · Trade press

The Land Report Newsletter, January 2021 ("Bill Gates joins the Land Report 100")

At No. 49, Microsoft co-founder Bill Gates joins the Class of 2020 with 268,984 acres in 19 states.

Reports Gates at No. 49 on the Land Report 100 with 268,984 acres in 19 states, of which 242,000 acres are farmland, with the largest concentrations in Louisiana (69,071 acres), Arkansas (47,927) and Nebraska (20,588).

Source
The Land Report
Date
January 2021
Quoted from
p. 1
Grade
Reported
Document
https://landreport.com/newsletters/LR_Newsletter_January2021.pdf
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Note
Grade reported per the never-publish list.

Exhibit 645 · Trade press

Farmer Bill (Eric O'Keefe, The Land Report)

A spokesman for Cascade Investment declined to comment on any of the details associated with these transactions or the Gateses’ holdings, other than to say that Cascade is very supportive of sustainable farming.

Says the Land Report 100 Research Team estimated 242,000 acres of farmland remained after Cascade Investment's 2017 purchase of 61 properties valued at about $500 million, and that most holdings are in Cascade entities managed by Michael Larson. States that "the Bill & Melinda Gates Foundation has no ties whatsoever to Cascade or its investments."

Source
The Land Report
Date
11 January 2021
Quoted from
Section "Sustainable Investing"
Grade
Reported
Document
https://landreport.com/2021/01/bill-gates-americas-top-farmland-owner/
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Exhibit 646 · Agency statistical report

Farms and Land in Farms: 2020 Summary

Total land in farms, at 896,600,000 acres, decreased 800,000 acres from 2019.

Total U.S. land in farms in 2020: 896.6 million acres across about 2.02 million farms. 242,000 acres is about 0.027 percent of that total.

Source
USDA National Agricultural Statistics Service
Date
February 2021
Quoted from
Summary, "Land in Farms"
Grade
Primary record
Document
https://www.nass.usda.gov/Publications/Todays_Reports/reports/fnlo0221.pdf
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Exhibit 647 · Dataset query

Farm Income and Wealth Statistics, data files, September 3, 2026 release (government payments by program, 1933 to 2026 forecast)

Source: ERS Farm Income and Wealth Statistics, file FarmIncomeWealthStatisticsData_September2026.csv in the 3 September 2026 release (zip SHA-256 90df42fe47981e9b6291ec7c3589603a544c1408b26b3b2d8c7fe8046b4bf245), run 9 November 2026. Query: State US; all series whose key begins GPAUS (government payments), net farm income (FIAUSNTFI--P), federal crop insurance indemnities (FRAUSMIINIFP) and cash receipts (CRAUS*); nominal dollars, $1,000 units; 2026 is a forecast. Result: total direct government payments of $27.89 billion in 2025 and a forecast $47.36 billion in 2026; $10.09 billion in 2024; payments were 7.9 percent of net farm income in 2024 and 29.9 percent in the 2026 forecast. In 2026 dollars, 2020 ($57.5 billion) is higher than the 2026 forecast ($47.4 billion). Market Facilitation Program payments: $5.13 billion (2018), $14.20 billion (2019), $3.78 billion (2020). Direct payments (decoupled) ranged from $4.29 billion to $6.70 billion a year in 2003 to 2013 and were about zero from 2014. Cash receipts, 2024: all crops $246.3 billion; fruit/nut plus vegetable lines $57.6 billion (23.4 percent; 20.5 percent in 2023 and 18.4 percent in 2022); corn, soybeans, wheat, cotton, rice, sorghum, peanuts, barley and oats $137.1 billion (55.7 percent; 59.6 percent in 2023 and 62.7 percent in 2022). Shares and real-dollar conversions are the project's arithmetic on the file's own deflator column.

Source
U.S. Department of Agriculture, Economic Research Service
Date
3 September 2026
Grade
Primary record
Document
https://www.ers.usda.gov/media/29517/september-3-2026-release.zip
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Note
Sums and ratios are the project's arithmetic; program-year timing follows ERS (payments recorded when received).

Exhibit 648 · Agency presentation

Webinar Transcript: Farm Income and Financial Forecasts, September 2026 Update

However, most of the forecast increase in government payments in 2026 is expected to come from Farm Bill commodity programs, where payments are triggered by lower prices or revenue.

ERS staff explain the September 2026 forecast: direct government payments forecast to rise $19.5 billion in 2026, with ARC and PLC payments of about $15 billion under the 2025 reconciliation law's higher reference prices, and ad hoc programs (Farmer Bridge Assistance, Assistance for Specialty Crop Farmers, American Relief Act of 2025 payments). ERS also reports net insurance payments and direct payments relative to net farm income: net income less these payments is forecast to fall $34 billion, or 26 percent, from 2025 to 2026.

Source
U.S. Department of Agriculture, Economic Research Service
Date
3 September 2026
Quoted from
Transcript p. 5
Grade
Primary record
Document
https://www.ers.usda.gov/sites/default/files/2026_09_03%20Webinar%20Transcript_Farm%20Income.pdf
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Exhibit 649 · Dataset query

FSA farm program payment files (Name/Address and Payment), payments dated January to December 2025: recipient distribution

Source: eleven Excel files for payment year 2025 (for example state al-id.foia_.na_.pmt25.final_.dt25365.xlsx), downloaded 9 November 2026. Fields: payee name and address, disbursement amount, payment date, accounting program code and description, program year; no customer number. Query: all 4,063,479 payment lines in all states and territories, summed by payee (name, street address, ZIP). Result: $24.386 billion to 1,030,230 payees with positive net receipts; mean $23,671, median $4,866. The top 10 percent of payees (at least $58,929 each) received 64.2 percent of dollars; the top 1 percent (at least $270,885) received 20.3 percent; the bottom 50 percent received 3.6 percent. For ARC and PLC alone ($2.12 billion, 313,603 payees) the top 10 percent received 65.0 percent; for the Emergency Commodity Assistance Program ($9.36 billion, 578,815 payees) 54.8 percent. Payees are not farms: an operation paid under several names or addresses is counted separately, and pass-through entities are not looked through, so concentration among operations is understated. The FSA file total ($24.39 billion) does not equal ERS's calendar-2025 direct payments ($27.89 billion); the difference is not reconciled.

Source
U.S. Department of Agriculture, Farm Service Agency
Date
2025 payments; files posted February 2026
Grade
Primary record
Document
https://www.fsa.usda.gov/tools/informational/freedom-information-act-foia/electronic-reading-room/frequently-requested/payment-files
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Note
Individuals' names are not recorded in project notes and are not to be published; only aggregates.

Exhibit 650 · Dataset query

RMA Summary of Business, nationwide by commodity: premium, subsidy and indemnity, crop years 2022 to 2024

Source: RMA 'Commodity Year Statistics, Nationwide Summary, By Commodity' for crop years 2022, 2023 and 2024 (crop2022.pdf, crop2023.pdf, crop2024.pdf), all 'As of: November 9, 2026'. Query: the 'CropTotal' row of every commodity (113 names in 2024), subsidy column summed by group. Result for 2024: total premium $14.08 billion, subsidy $8.89 billion (63 percent). Nine program crops (corn, soybeans, cotton, wheat, rice, grain sorghum, peanuts, barley, oats) received $7.50 billion (84.3 percent of subsidy; liability $118.8 billion); fruit, vegetable and tree-nut lines received $0.64 billion (7.2 percent; liability $18.8 billion). The program-crop share of subsidy was 87.9 percent in 2022 and 86.1 percent in 2023; the fruit, vegetable and tree-nut share 5.1 and 5.9 percent. The grouping is the project's name-pattern classification (coffee and mint lines fall in the fruit and vegetable group; under $2 million). Premium subsidy follows insured liability, which follows crop value and acreage.

Source
U.S. Department of Agriculture, Risk Management Agency (Federal Crop Insurance Corporation)
Date
9 November 2026 (as-of date of the tables)
Grade
Primary record
Document
https://pubfs-rma.fpac.usda.gov/pub/sob/current_week/crop2024.pdf
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Note
PDF copies and the parsing scripts are held privately; the as-of date means later tables may differ.

Exhibit 651 · GAO report

Crop Insurance: Update on Opportunities to Reduce Program Costs (GAO-24-106086)

In 2022, subsidies averaged about 62 percent of policyholders’ premiums and totaled $12 billion

In 2022 the federal crop insurance program cost $17.3 billion. The government paid insurance companies about $3.7 billion to deliver it ($2.2 billion in administrative and operating subsidies and $1.5 billion in underwriting gains). From 2011 through 2022 the companies' return on retained premiums averaged 16.8 percent against a market-based 10.2 percent. Premium subsidies averaged about 62 percent of premiums and totaled $12 billion. Of 460,615 policyholders, 1,341 (0.3 percent) had adjusted gross incomes of $900,000 or more and accounted for 0.5 percent of premiums; a 15-point subsidy cut for them would have saved about $15 million. USDA had no comments on the report.

Source
U.S. Government Accountability Office
Date
November 2023
Quoted from
Highlights, p. 3 of PDF
Grade
Primary record
Document
https://www.gao.gov/assets/d24106086.pdf
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Exhibit 652 · GAO report

Crop Insurance: Savings Would Result from Program Changes and Greater Use of Data Mining (GAO-12-256)

would have saved up to $1 billion in crop insurance program costs in 2011

A $40,000 limit on premium subsidies per farmer, as for other farm programs, would have saved up to $1 billion in 2011 and affected up to 3.9 percent of participating farmers, who accounted for about one-third of premium subsidies. A 10-point cut for all farmers would have saved about $1.2 billion. USDA did not agree that Congress should consider limiting premium subsidies; GAO said limits remain appropriate when farm income is at a record high.

Source
U.S. Government Accountability Office
Date
March 2012
Quoted from
Highlights, p. 2 of PDF
Grade
Primary record
Document
https://www.gao.gov/assets/gao-12-256.pdf
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Exhibit 653 · GAO report

Farm Programs: Direct Payments Should Be Reconsidered (GAO-12-640)

in 2011, the top 25 percent of payment recipients received 73 percent of direct payments

From 2003 through 2011 USDA made more than $46 billion in direct payments, fixed annual payments based on historical crop production. Cumulatively $10.6 billion, almost one-fourth, went to producers who did not grow the associated crop in a given year, which program rules allowed. In 2011 the top 25 percent of recipients received 73 percent. USDA agreed with two recommendations and disagreed with two.

Source
U.S. Government Accountability Office
Date
July 2012
Quoted from
Highlights, p. 2 of PDF
Grade
Primary record
Document
https://www.gao.gov/assets/gao-12-640.pdf
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Exhibit 654 · GAO report

Farm Program Payments: USDA Needs to Strengthen Regulations and Oversight to Better Ensure Recipients Do Not Circumvent Payment Limitations (GAO-04-407)

about 99 percent of payment recipients asserted they met eligibility requirements through active personal management

USDA's rules set no measurable standard for a significant contribution of active personal management. Of $17 billion in 2001 payments, $5.9 billion went to about 140,000 entities, and general partnerships received 45 percent of entity payments. For about one-half of operations reviewed, field offices did not use available tools to check active engagement. USDA agreed to act on most recommendations and said its regulations were sufficient for determining active engagement.

Source
U.S. Government Accountability Office
Date
April 2004
Quoted from
Highlights, p. 2 of PDF
Grade
Primary record
Document
https://www.gao.gov/assets/gao-04-407.pdf
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Exhibit 655 · GAO report

Farm Programs: Changes Are Needed to Eligibility Requirements for Being Actively Involved in Farming (GAO-13-781)

FSA regulations allow farming operation members to make contributions of management without visiting the operation

FSA compliance reviews are hindered by a broad and subjective definition of active personal management, which can be met by performing one of eight services. FSA completed on time about 24 percent of its 2009 reviews and 14 percent of its 2010 reviews. FSA said it would not change the definition without direction from Congress and concurred with the recommendation to monitor reviews.

Source
U.S. Government Accountability Office
Date
September 2013
Quoted from
Highlights, p. 2 of PDF
Grade
Primary record
Document
https://www.gao.gov/assets/gao-13-781.pdf
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Exhibit 656 · GAO report

Farm Programs: USDA Has Improved Its Completion of Eligibility Compliance Reviews, but Additional Oversight Is Needed (GAO-21-95)

USDA did not systematically monitor its performance of compliance reviews

FSA improved completion of 2015 and 2016 compliance reviews but did not systematically monitor them. Of 27 review records examined, six included interviews. Payments that required recipients to be actively engaged in farming totaled $8.4 billion, $7.4 billion and $3.1 billion for crop years 2015 to 2017. USDA generally agreed with five recommendations.

Source
U.S. Government Accountability Office
Date
October 2020
Quoted from
Highlights, p. 2 of PDF
Grade
Primary record
Document
https://www.gao.gov/assets/720/710495.pdf
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Exhibit 657 · GAO report

Farm Programs: Information on Payments (GAO-18-384R)

Being actively engaged in farming is not required for numerous USDA program benefits. For example, being actively engaged in farming is not required for payments made through USDA’s conservation and disaster assistance programs or for participation in USDA’s federal crop insurance program.

Describes the actively engaged in farming test and the $125,000 per-member limit under the 2014 farm bill, and states which programs are outside the test: conservation, disaster assistance and federal crop insurance.

Source
U.S. Government Accountability Office
Date
18 May 2018 (reissued 5 June 2018)
Quoted from
Footnote 2, p. 1
Grade
Primary record
Document
https://www.gao.gov/assets/700/691864.pdf
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Exhibit 658 · GAO report

USDA Market Facilitation Program: Information on Payments for 2019 (GAO-20-700R)

MFP payments for 2019 were about $14.4 billion

2019 MFP payments were $14,368,406,309 to 643,965 farming operations (870,427 individuals), an average of $22,312 per operation. Nonspecialty crops received about $13.5 billion (94 percent), specialty crops about $274 million (2 percent), dairy and hogs about $566 million (4 percent). The 2019 program doubled the payment limit to $250,000 per commodity type and up to $500,000 per person, producing about $519 million in additional payments. The 25 operations with the highest payments received about $37 million. Rates ranged from 56.3 percent of projected price (sorghum) to 1.1 percent (dairy).

Source
U.S. Government Accountability Office
Date
21 August 2020
Quoted from
p. 3 of PDF
Grade
Primary record
Document
https://www.gao.gov/assets/710/709030.pdf
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Exhibit 659 · GAO report

USDA Market Facilitation Program: Oversight of Future Supplemental Assistance to Farmers Could Be Improved (GAO-22-104259)

FSA also paid $163.4 million (0.7 percent) to 883 high-income farms and 1,164 farmers with adjusted gross incomes (AGI) over $900,000 per year.

MFP made payments totaling $23 billion for 2018 and 2019. Historically underserved farmers received $818.9 million (3.6 percent). FSA paid $163.4 million (0.7 percent) to 883 high-income farms and 1,164 farmers with adjusted gross incomes over $900,000; applicants above the cap were eligible if at least 75 percent of income came from farming, ranching or forestry. FSA's review of 2018 payments was limited in usefulness, and FSA discontinued its 2019 compliance review. FSA generally agreed with four recommendations.

Source
U.S. Government Accountability Office
Date
January 2022
Quoted from
Highlights, p. 2 of PDF
Grade
Primary record
Document
https://www.gao.gov/assets/gao-22-104259.pdf
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Exhibit 660 · GAO report

USDA Market Facilitation Program: Stronger Adherence to Quality Guidelines Would Improve Future Economic Analyses (GAO-22-468)

total 2019 MFP payments to corn producers were approximately $3 billion more than USDA’s estimate of trade damage to corn

USDA's trade-damage baselines for 2019 MFP were not representative and not transparently documented. County-based payment rates paid producers of the same crop differently by county, and total payments to a crop differed from USDA's own damage estimate.

Source
U.S. Government Accountability Office
Date
2022
Quoted from
Highlights, p. 3 of PDF
Grade
Primary record
Document
https://www.gao.gov/assets/gao-22-468.pdf
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Exhibit 661 · Audit report

Market Facilitation Program, Audit Report 03601-0003-31

We did not identify any issues regarding producer eligibility and certifications, except for issues with certified production and acreage amounts, which affected payment accuracy.

USDA announced trade-mitigation packages of up to $12 billion (24 July 2018) and up to an additional $16 billion (23 May 2019). Across 2018 and 2019 FSA distributed over $23 billion to more than 715,000 producers of 38 commodities ($8.65 billion for 2018 and $14.53 billion for 2019 as of 23 August 2021). OIG found no eligibility issues apart from certified production and acreage, and estimated FSA overpaid 150,313 producers by a total of more than $57.2 million (95 percent interval $24.3 million to $119.7 million). FSA concurred with all four recommendations.

Source
U.S. Department of Agriculture, Office of Inspector General
Date
9 March 2022
Quoted from
p. 4 of the report (PDF p. 11)
Grade
Primary record
Document
https://usdaoig.oversight.gov/sites/default/files/reports/2025-08/03601-0003-31FR508FOIA.pdf
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Exhibit 662 · CRS report

U.S. Farm Programs: Eligibility and Payment Limits (CRS R46248)

Also, benefits from crop insurance premium subsidies and indemnity payments on loss claims are not subject to any limits.

Explains actively engaged in farming, AGI limits and per-person payment limits. A family farm may qualify for multiple payment limits (a worked example reaches 12 limits and $1.5 million), a partnership's limit equals the single-person limit times its qualifying members, and marketing-loan benefits, crop insurance premium subsidies and indemnities are outside payment limits.

Source
Congressional Research Service
Date
7 December 2020 (first issued 3 March 2020)
Quoted from
Section 'Selected Farm Programs Without Payment Limits'
Grade
Primary record
Document
https://www.everycrsreport.com/reports/R46248.html
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Exhibit 663 · CRS In Focus

Farm Bill Primer: Budget Dynamics (CRS IF12233)

CRS estimates that the 2026 baseline for all farm bill titles is $1.374 trillion over 10 years (FY2027-FY2036)

Table 1 gives the February 2026 baseline by title for FY2027 to FY2036, in millions: Commodities 142,625; Conservation 73,004; Trade 8,280; Nutrition 985,379; Research 3,510; Energy 535; Horticulture 2,440; Crop Insurance 155,539; Miscellaneous 2,248; total 1,373,560. Comparison with the January 2025 table shows nutrition down about $132.0 billion and commodities up about $75.1 billion; CRS says the changes reflect both reconciliation and new economic conditions.

Source
Congressional Research Service
Date
1 June 2026
Quoted from
Text above Figure 1
Grade
Primary record
Document
https://www.everycrsreport.com/files/2026-06-01_IF12233_527a1727591f6861a9e9b180c7c032ba9580b6e1.html
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Exhibit 664 · CRS In Focus

Farm Bill Primer: SNAP and Nutrition Title Programs (CRS IF12255)

the Nutrition title makes up approximately 72% of farm bill mandatory spending

Describes the nutrition title and SNAP, which is authorized as open-ended mandatory spending. Table 1 lists SNAP at $103.955 billion (FY2026 funding) with 42.38 million participants in an average month in FY2025. In FY2025, 93 percent of SNAP spending was for benefits.

Source
Congressional Research Service
Date
15 April 2026
Quoted from
Section 'Funding'
Grade
Primary record
Document
https://www.everycrsreport.com/reports/IF12255.html
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Exhibit 665 · CRS report

The Farm Bill After FY2025 Budget Reconciliation: Frequently Asked Questions (CRS R48775)

Raising reference prices increases the likelihood that payments are triggered and increases the size of such payments.

Reports CBO's estimate that Title I of P.L. 119-21 reduces federal outlays by $121 billion over FY2025 to FY2034: nutrition changes reduce outlays by $187 billion and other agriculture subtitles add a net $66 billion. States that the law raised reference prices.

Source
Congressional Research Service
Date
2025
Quoted from
Section on the reconciliation law's effects
Grade
Primary record
Document
https://www.everycrsreport.com/reports/R48775.html
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Exhibit 666 · Statute

Public Law 119-21 (H.R. 1), Title I, Committee on Agriculture, Nutrition, and Forestry (sections 10101 to 10607)

For the 2025 crop year and each crop year thereafter, the Secretary shall annually adjust the amounts described in subsections (b) and (c) for inflation based on the Consumer Price Index for All Urban Consumers

Sec. 10301 sets new statutory reference prices from crop year 2025 (for example corn $4.10 a bushel, soybeans $10.00, wheat $6.35) and raises the effective reference price from 85 to 88 percent. Sec. 10302 allocates up to 30,000,000 additional base acres. Sec. 10306 extends partnership treatment to S corporations and limited liability companies as 'qualified pass-through entities'. Sec. 10307 raises the payment limit from $125,000 to $155,000 and indexes it to inflation. Sec. 10308 lifts the $900,000 adjusted gross income limit for operations with at least 75 percent of income from farming, ranching or silviculture activities for certain payments. Sec. 10502 raises the premium subsidy for area-based coverage from 65 to 80 percent and sec. 10504 raises premium support at five coverage tiers. Subtitle A changes SNAP (secs. 10101 to 10108).

Source
U.S. Congress (139 Stat. 72)
Date
4 July 2025
Quoted from
Sec. 10307, 139 Stat. 92
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
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Exhibit 667 · Agency report

The Evolving Distribution of Payments From Commodity, Conservation, and Federal Crop Insurance Programs (Economic Information Bulletin 184)

Government payments and Federal crop insurance reduce income volatility for commercial farms.

ERS (McFadden and Hoppe) states that the programs aim to mitigate financial risks of farmers and that payments have shifted to larger farms and higher-income households as production consolidated. Farms with at least $1 million in gross cash farm income received nearly 11 percent of commodity program payments in 1991 and 34 percent in 2015, shifts ERS describes as similar to the shifts in production value. Commodity programs were 89 percent of commodity, conservation and crop insurance support in 1999 and 43 percent in 2015. Peer reviewed within ERS.

Source
U.S. Department of Agriculture, Economic Research Service
Date
November 2017
Quoted from
p. 10 (PDF p. 16)
Grade
Primary record
Document
https://ers.usda.gov/media/8844/eib-184.pdf
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Exhibit 668 · Agency web page

Farmer Bridge Assistance (FBA) Program

USDA’s Farm Service Agency (FSA) is providing $11 billion through a one-time bridge payment to American farmers with an additional $1 billion available for additional commodities.

FSA is providing $11 billion in a one-time bridge payment, with $1 billion more for additional commodities, as a bridge until the 2025 reconciliation law's benefits are available, under the Commodity Credit Corporation Charter Act. Payments follow 2025 reported acres, ERS cost of production and WASDE; the limit is $155,000 per producer and producers with average AGI above $900,000 are ineligible. The page does not mention tariffs.

Source
U.S. Department of Agriculture, Farm Service Agency
Date
2026 (application closed 17 April 2026)
Quoted from
'What It Is'
Grade
Primary record
Document
https://www.fsa.usda.gov/resources/income-support/farmer-bridge-assistance-fba-program
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Exhibit 669 · Agency web page

Assistance for Specialty Crop Farmers (ASCF) Program

USDA’s Farm Service Agency (FSA) is providing $1.625 billion through a one-time bridge payment for specialty crops not covered through the previously announced Farm Bridge Assistance (FBA) program.

FSA is providing $1.625 billion through a one-time bridge payment for specialty crops not covered by the Farmer Bridge Assistance program, based on reported 2025 planted acres, under the Commodity Credit Corporation Charter Act.

Source
U.S. Department of Agriculture, Farm Service Agency
Date
2026
Quoted from
'What It Is'
Grade
Primary record
Document
https://www.fsa.usda.gov/ascf
Accessed
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Exhibit 670 · Agency report

2021 PLC, ARC-CO, ARC-IC payments by state and by commodity (as of 25 April 2023)

Table 2 lists 2021 payments on its commodity lines, total $344,305,808: barley, canola, chickpeas, corn, crambe, flaxseed, lentils, mustard, oats, peanuts, dry peas, rapeseed, rice, safflower, seed cotton, sesame, sorghum, soybeans, sunflower and wheat. No fruit or vegetable appears.

Source
U.S. Department of Agriculture, Farm Service Agency
Date
25 April 2023
Grade
Primary record
Document
https://www.fsa.usda.gov/sites/default/files/documents/2021_arc_plc_payments_2023_0504.pdf
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Exhibit 671 · Peer-reviewed article

Farm Policy and Obesity in the United States (Choices 25(3))

We show that U.S. farm subsidies have had generally modest and mixed effects on prices and quantities of farm commodities, with negligible effects on the prices paid by consumers for food and thus negligible influence on dietary patterns and obesity.

The economists examine whether farm subsidies lowered consumer food prices and raised calorie intake. They find subsidies had modest and mixed effects on commodity prices and negligible effects on consumer prices, and attribute the growth of high fructose corn syrup to sugar import policy more than to corn subsidies. Funding stated in the article: a USDA National Institute of Food and Agriculture grant and a USDA Economic Research Service cooperative agreement.

Source
J. M. Alston, B. J. Rickard and A. M. Okrent (UC Davis, Cornell, USDA Economic Research Service), published by the Agricultural and Applied Economics Association
Date
Third quarter 2010
Quoted from
Abstract paragraph, p. 1
Grade
Peer-reviewed
Document
https://www.choicesmagazine.org/UserFiles/file/article_138.pdf
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2026-11-09
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Note
J. Agric. Econ.

Exhibit 672 · Agency web page

Food Dollar: Summary Findings (2024 data)

The farm share was 11.8 cents per dollar spent by U.S. consumers on domestically produced food in 2024.

The Food Dollar's marketing bill divides consumer food spending into a farm share and a marketing share. The 2024 farm share was 11.8 cents of each dollar spent on domestically produced food; the update broadened the definition of food to include bottled water, soft drinks, coffee and tea, which lowered the 2024 farm share from 12.3 to 11.8 cents.

Source
U.S. Department of Agriculture, Economic Research Service
Date
2026 update (2024 data)
Quoted from
'The Marketing Bill'
Grade
Primary record
Document
https://www.ers.usda.gov/data-products/food-dollar/summary-findings
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Note
Used for the steelman that commodity cost is a small part of retail price.

Exhibit 673 · Dataset query

Lobbying Disclosure Act query: quarterly reports with the phrase 'farm bill' in a lobbying activity description, 2018 and 2024 to 2025

Source: Lobbying Disclosure Act database, lda.gov API (the older lda.senate.gov address showed a maintenance page), run 9 November 2026. Query: for filing_year 2018, 2024 and 2025 and each filing_type Q1 to Q4 (original quarterly reports, so amendments are excluded), filing_specific_lobbying_issues matching the phrase "farm bill", every page returned; the API returns one row per matching activity line, so rows were de-duplicated by filing_uuid and the phrase was re-checked in each retained activity description. Result: 2,087 reports from 716 clients through 477 registrants in 2018; 3,285 reports from 1,003 clients through 602 registrants in 2024; 2,450 reports from 746 clients through 446 registrants in 2025. Limiting to activity lines coded AGR (Agriculture) that contain the phrase: 1,597 reports and 534 clients in 2018, 2,558 reports and 772 clients in 2024, 1,980 reports and 608 clients in 2025. Dollar figures in a filing (income for outside firms, expenses for in-house filers) cover all of a client's issues, so no farm bill total can be read from them. The query covers every filer whose report contains the phrase, whatever its industry or leaning; it does not identify which side of any farm bill provision a client lobbied.

Source
U.S. Congress (Lobbying Disclosure Act database, lda.gov)
Date
2026-11-09
Grade
Primary record
Document
https://lda.gov/api/v1/filings/
Accessed
2026-11-09
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Note
Totals are the project's aggregation; the filing-level income or expenses figure covers all of a client's issues, not the farm bill alone.

Exhibit 674 · Subcommittee report

Repatriating Offshore Funds: 2004 Tax Windfall for Select Multinationals

After repatriating over $150 billion under the 2004 American Jobs Creation Act (AJCA), the top 15 repatriating corporations reduced their overall U.S. workforce by 20,931 jobs, while broad-based studies of all 840 repatriating corporations found no evidence that repatriated funds increased overall U.S. employment.

Majority staff report on a survey of 19 to 20 repatriating corporations. Reports $312 billion repatriated at an effective 5.25 percent rate, a JCT revenue-loss estimate of $3.3 billion over ten years (about $100 billion would have returned anyway), net U.S. job losses at the top 15 repatriators, buybacks up 16 and 38 percent, and executive pay up 27 and 30 percent. Majority-staff (Democratic) authorship: findings on policy are one party's; the printed survey figures come from company responses. Local copy sha256 13ce026e18df1a9f75950430942b6f3f52a8fc3493b68c606daabbc7d0d27639.

Source
U.S. Senate Permanent Subcommittee on Investigations (majority staff)
Date
11 October 2011
Quoted from
Report Findings, item 1 (report p. 5)
Grade
Primary record
Document
https://www.hsgac.senate.gov/imo/media/doc/RepatriatingOffshoreFundsReportOct202011wExhibitsFINAL.pdf
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Exhibit 675 · CRS report

Tax Cuts on Repatriation Earnings as Economic Stimulus: An Economic Analysis (R40178, 21 December 2012 version)

While empirical evidence is clear that this provision resulted in a significant increase in repatriated earnings, empirical evidence is unable to show a corresponding increase in domestic investment or employment.

Describes the 85 percent deduction (5.25 percent effective rate) and surveys empirical studies: repatriations rose sharply but did not raise investment or employment, and much went to stock repurchases. Notes Faulkender and Petersen found investment effects at capital-constrained firms (about 20 percent of repatriations), an industry-commissioned Sinai simulation of 614,000 jobs for a 2009 holiday, and that fungibility means buybacks may not violate the law.

Source
Congressional Research Service (Marples and Gravelle)
Date
21 December 2012
Quoted from
Summary, second paragraph
Grade
Primary record
Document
https://www.everycrsreport.com/files/20121221_R40178_32bec8a2b17deaf51debbd5755e2bf89790c1f5c.html
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Exhibit 676 · Working paper (published JoF 2011)

Watch What I Do, Not What I Say: The Unintended Consequences of the Homeland Investment Act

Repatriations did not lead to an increase in domestic investment, employment or R&D—even for the firms that lobbied for the tax holiday stating these intentions and for firms that appeared to be financially constrained.

Uses instruments for firms likely to gain most from the holiday. Finds no increase in domestic investment, employment or R&D, including at firms in the Homeland Investment Coalition and firms whose PACs gave to tax-writing committee members. Working paper reports almost $1 of shareholder payouts per $1 repatriated; the published abstract is reported by PSI as 60 to 92 cents. Defines the HIC as 'a group of firms and organizations formed with the sole purpose of lobbying to reduce the tax rate on U.S. repatriations' and cites its 21 March 2003 letter to Chairman Bill Thomas (fn. 26; letter not found).

Source
Dharmapala, Foley and Forbes (NBER Working Paper 15023, June 2009; Journal of Finance 66(3):753-787, 2011)
Date
June 2009
Quoted from
Abstract (working paper version)
Grade
Peer-reviewed
Document
https://www.nber.org/papers/w15023
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Exhibit 677 · Lobbying disclosure filings

Lobbying Disclosure Act filings: Homeland Investment Coalition, 2003 to 2006

Eight filings by registrant PricewaterhouseCoopers for client Homeland Investment Coalition (client id 114561): registration 2003-02-14; 2003 mid-year $360,000 and year-end $340,000; 2004 mid-year $620,000 and year-end $0.00; 2005 mid-year $80,000 and year-end $160,000; 2006 termination $0.00. Issue: Taxation/Internal Revenue Code. Lobbyists include Bill Archer (covered position 'HOUSE MEMBER' on the registration), Oren Penn ('LEG COUNSEL/JT TAX COMM'), Bernard Shapiro and Alan Fischl. Contacts: House, Senate, Treasury, Executive Office of the President. Sums are the project's; the 2004 mid-year filing lists a different lobbyist group and the year-end shows 0.00.

Source
U.S. Congress (Lobbying Disclosure Act database, lda.gov), filed by PricewaterhouseCoopers
Date
2003 to 2006
Grade
Primary record
Document
https://lda.gov/api/v1/filings/?client_name=homeland+investment+coalition
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2026-11-10
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Note
Filing documents at lda.gov/filings/public/filing/<uuid>/print/ should be read to confirm the 2004 reporting period.

Exhibit 678 · Dataset query

Lobbying Disclosure Act API: filing counts by year and type

Count field read from the lda.gov API on 2026-11-10: filing_year 2004 type MM 14,922; 2005 MM 16,046 and YY 16,406; 2023 Q1 18,107 (originals, per type). Anonymous access is throttled (HTTP 429, about 15 requests a minute), and the older soprweb.senate.gov quarterly zips did not respond. National dollar totals by year were not derived.

Source
U.S. Congress (Lobbying Disclosure Act database, lda.gov)
Date
2026-11-10
Grade
Reported
Document
https://lda.gov/api/v1/filings/
Accessed
2026-11-10
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Exhibit 679 · Journal article

Measuring Rates of Return for Lobbying Expenditures: An Empirical Case Study of Tax Breaks for Multinational Corporations

We find firms lobbying for this provision have a return in excess of $220 for every $1 spent on lobbying, or 22,000%.

Uses audited tax disclosures on the 2004 repatriation holiday. Abstract also reports that profitability does not predict repatriation amount, that industry and firm size do, and that cash on hand does not. The abstract does not give the paper's sample, dollar totals or method.

Source
Alexander, Mazza and Scholz, Journal of Law and Politics 25:401
Date
2009
Quoted from
Abstract (KU ScholarWorks record)
Grade
Peer-reviewed
Document
https://hdl.handle.net/1808/11410
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Exhibit 680 · University press release

Tax lobbying provides 22,000 percent return to multinational firms, KU researchers find

University of Kansas release of 9 April 2009, read in the phys.org copy. States that 843 firms repatriated over $312 billion; that the researchers examined 476 publicly traded firms that repatriated more than $298 billion; that Eli Lilly disclosed $8.52 million in lobbying in 2003 and 2004 for the provision; and that for each dollar spent on lobbying a corporation received $220 in U.S. income tax savings, a 22,000 percent average return.

Source
University of Kansas (press release, copy on phys.org)
Date
9 April 2009
Grade
Reported
Document
https://phys.org/news/2009-04-tax-lobbying-percent-multinational-firms.amp
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Exhibit 681 · Journal article

Lobbying and Taxes

Increasing registered lobbying expenditures by 1% appears to lower effective tax rates by somewhere in the range of 0.5 to 1.6 percentage points for the average firm that lobbies.

Uses all U.S. firms with public financial statements; also states that costs of lobbying-induced tax breaks appear modest for the government.

Source
Richter, Samphantharak and Timmons, American Journal of Political Science 53(4):893-909
Date
2009
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1111/j.1540-5907.2009.00407.x
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Exhibit 682 · Journal article

Corporate Lobbying and Firm Performance

We find that, on average, lobbying is positively related to accounting and market measures of financial performance.

Uses Lobbying Disclosure Act data; portfolios with the highest lobbying intensity outperform benchmarks in the three following years.

Source
Chen, Parsley and Yang, Journal of Business Finance and Accounting 42(3-4):444-481
Date
2015
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1111/jbfa.12109
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Exhibit 683 · Journal article

Academic Earmarks and the Returns to Lobbying

However, for universities with HAC or SAC representation, a 10 percent increase in lobbying yields an additional 2.8 percent or 3.5 percent increase in earmarks, respectively.

Estimates returns to university lobbying for earmarks; little or no return for universities without a House or Senate Appropriations Committee member.

Source
de Figueiredo and Silverman, Journal of Law and Economics 49(2):597-625
Date
2006
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1086/508248
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Exhibit 684 · Journal article

Meetings, Comments, and the Distributive Politics of Rulemaking

I find that meetings and comments were associated with abnormal returns in the tens of billions, yet meetings were worth more.

Event study of firm stock prices after Federal Reserve Board rule announcements under Dodd-Frank (Obama-era statute).

Source
Libgober, Quarterly Journal of Political Science 15(4):449-481
Date
2020
Quoted from
Abstract
Grade
Peer-reviewed
Document
http://dx.doi.org/10.1561/100.00018135
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Exhibit 685 · Congressional Record

Congressional Record, Senate, 24 May 2010: motion to instruct conferees on H.R. 4173 (auto dealers), roll call vote 163

There is not a single auto dealer on Wall Street--none of them, not one.

Debate and vote on Sen. Brownback's motion to instruct conferees to exempt motor vehicle dealers from the Consumer Financial Protection Bureau; Sen. Dodd opposed. Roll call 163: 60 yeas, 30 nays; the yeas list includes Democratic and Republican Senators. The enacted exemption is section 1029 of Pub.

Source
U.S. Senate (Congressional Record vol. 156, no. 79)
Date
24 May 2010
Quoted from
S4130 (Brownback)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/CREC-2010-05-24/html/CREC-2010-05-24-pt1-PgS4130-2.htm
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Exhibit 686 · Roll call vote

House roll call 509, American Jobs Creation Act conference report, 7 October 2004

Agreed 280 to 141. Republicans 207 yea, 16 nay, 4 not voting; Democrats 73 yea, 124 nay, 8 not voting.

Source
U.S. House of Representatives (Clerk)
Date
7 October 2004
Grade
Primary record
Document
https://clerk.house.gov/evs/2004/roll509
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Exhibit 688 · Working paper (published JEP 2003)

Why Is There So Little Money in U.S. Politics?

we argue that campaign contributions are not a form of policy-buying, but are rather a form of political participation and consumption.

Concerns campaign contributions, not lobbying expenditures. Reports that individuals, not special interests, are the main source of contributions and that, controlling for unobserved effects, there is little relationship between money and votes. Quote is from the working-paper abstract.

Source
Ansolabehere, de Figueiredo and Snyder (NBER Working Paper 9409; Journal of Economic Perspectives 17(1):105-130)
Date
2003
Quoted from
Abstract (NBER WP 9409)
Grade
Peer-reviewed
Document
https://www.nber.org/papers/w9409
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Exhibit 689 · Book synopsis

Lobbying and Policy Change: Who Wins, Who Loses, and Why (synopsis)

The authors find that resources explain less than five percent of the difference between successful and unsuccessful efforts.

Book not read; synopsis from the authors' site. Based on 98 issues.

Source
Baumgartner, Berry, Hojnacki, Kimball and Leech, University of Chicago Press (authors' project page)
Date
2009
Quoted from
Synopsis
Grade
Peer-reviewed
Document
https://fbaum.unc.edu/books/lobby/lobbying-synopsis.htm
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Exhibit 690 · Journal article

Revolving Door Lobbyists

Lobbyists with experience in the office of a US Senator suffer a 24 percent drop in generated revenue when that Senator leaves office.

Abstract read via EconPapers; full text and any party-split results not read.

Source
Blanes i Vidal, Draca and Fons-Rosen, American Economic Review 102(7):3731-3748
Date
2012
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1257/aer.102.7.3731
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Exhibit 691 · Journal article

Is It Whom You Know or What You Know? An Empirical Assessment of the Lobbying Process

However, we find a more consistent monetary premium for connections than expertise.

Abstract read via EconPapers.

Source
Bertrand, Bombardini and Trebbi, American Economic Review 104(12):3885-3920
Date
2014
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1257/aer.104.12.3885
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Exhibit 692 · Journal article

Lobbying as Legislative Subsidy

We model lobbying not as exchange (vote buying) or persuasion (informative signaling) but as a form of legislative subsidy—a matching grant of policy information, political intelligence, and legislative labor to the enterprises of strategically selected legislators.

Abstract read via EconPapers.

Source
Hall and Deardorff, American Political Science Review 100(1):69-84
Date
2006
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://www.cambridge.org/core/journals/american-political-science-review/article/abs/lobbying-as-legislative-subsidy/AE4B5D8AB9C2487BB78C2A51BB53E03F
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Exhibit 693 · Peer-reviewed article

Testing Theories of American Politics: Elites, Interest Groups, and Average Citizens

economic elites and organized groups representing business interests have substantial independent impacts on U.S. government policy, while average citizens and mass-based interest groups have little or no independent influence.

Tests four theories (Majoritarian Electoral Democracy, Economic-Elite Domination, Majoritarian Pluralism, Biased Pluralism) in one model on 1,779 survey-polled proposed policy changes, 1981-2002 (1,923 met four criteria; 1,779 also had income breakdowns, no constitutional amendment or Supreme Court ruling, and a clear adoption outcome). Preferences at the 50th income percentile stand for average citizens and at the 90th (about $146,000 household income in 2012 dollars) for economic elites; interest groups enter as a Net Interest-Group Alignment index built from the Fortune 'Power 25' lists plus ten high-lobbying industries. Outcome: whether the change was adopted within four years. Table 3, model 4: citizens .03 (not significant), elites .76, groups .56, R-squared .074. Table 2: citizen-elite preference correlation .78 after measurement-error correction; groups-citizens .04 (mass-based .12, business -.10). Table 4: mass-based groups .24, business groups .43, citizens .05. The authors call the test 'tentative and preliminary' (p. 564), state that their evidence 'does not indicate that in U.S. policy making the average citizen always loses out' (p. 572; see also p. 570), describe citizens as often 'coincidental beneficiaries' of elite wins (p. 573), report that narrow pro-change majorities got change about 30 percent of the time and 80 percent majorities about 43 percent (p. 573), and state the data cannot distinguish elite theories, cannot test non-economic elites, and cannot tell agenda blocking from rejection (pp. 574, 576). Journal pagination used for locators.

Source
Martin Gilens and Benjamin I. Page, Perspectives on Politics 12(3), pp. 564-581
Date
September 2014
Quoted from
Abstract, p. 564
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S1537592714001595
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Exhibit 694 · Peer-reviewed article

Relative Policy Support and Coincidental Representation

even on those issues for which the preferences of the wealthy and those in the middle diverge, policy ends up about where we would expect if policymakers represented the middle class and ignored the affluent.

Re-analyzes the Gilens data (Enns counts 1,836 survey questions). Preference gaps between income groups do not imply unequal representation when both groups rank policies similarly. Correlation of 50th and 90th percentile support is r=.94 unadjusted; r=.68 among the 18 percent of policies where the groups differ by more than 10 points. About 66 percent of predicted adoption values built from middle-income preferences fall inside the 95 percent intervals of the affluent-based values. Partisan analysis uses only surveys from 1999-2002 (policies enacted 2000-2004): strong Republicans' support predicts adoption (b=.79, se .25), strong Democrats' does not (b=.10, se .17); strong-partisan support correlates only r=.43 (r=.21 where gaps exceed 10 points). Enns notes the period was one of Republican control of Congress. He also affirms the status quo bias finding and warns against an overly sanguine portrait of inequality.

Source
Peter K. Enns, Perspectives on Politics 13(4), pp. 1053-1064 (Reflections Symposium)
Date
December 2015
Quoted from
Abstract, p. 1053
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S1537592715002315
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Exhibit 695 · Peer-reviewed reply

Reconsidering the Middle: A Reply to Martin Gilens

Scholars cannot treat preference gaps as synonymous with unequal representation.

Enns agrees with Gilens that median-income and affluent respondents 'fairly often get the policies they favor' and that 'democracy by coincidence' holds normatively; they disagree on the extent and implications. Enns cites Bashir's finding that when majorities disagree the median sees its desired outcome 47 percent of the time against 53 percent for the affluent. He notes that Gilens's 'twice as likely' figure rests on a 5.1 percent subset of the data. He concedes (note 5) that Gilens could be right if policies the middle prefers and the affluent oppose are kept off the agenda and never polled, which the data cannot test, and that the truly rich may influence policy at the expense of both groups.

Source
Peter K. Enns, Perspectives on Politics 13(4), pp. 1072-1074
Date
December 2015
Quoted from
p. 1073
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S1537592715002339
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Exhibit 696 · Peer-reviewed reply

The Insufficiency of 'Democracy by Coincidence': A Response to Peter K. Enns

There simply is not enough coincidence of policy outcomes and middle-class preferences to justify the conclusion that middle-income Americans are likely to be satisfied with the policies their government adopts.

Gilens agrees with Enns that congruence without influence is 'democracy by coincidence' and that it has political implications. He argues that the cases where policy departs from middle-class preferences are important, highly salient issues; that Enns's 'relative policy support' is vague; that Enns overlooks characteristics of the data and makes erroneous calculations; and that coincidence is no substitute for responsiveness. Only the first page (p. 1065) was read, as a page image from the publisher; pp. 1066-1071 were not available. Later literature (Elkjaer and Klitgaard 2024, p. 320) quotes p. 1070: coincidental representation is a 'pale, counterfeit, simulacrum of democracy'.

Source
Martin Gilens, Perspectives on Politics 13(4), pp. 1065-1071
Date
December 2015
Quoted from
p. 1065
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S1537592715002327
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Exhibit 697 · Peer-reviewed article

Testing Inferences about American Politics: A Review of the 'Oligarchy' Result

average Americans have received their preferred policy outcome roughly as often as elites have when the two groups have disagreed with each other.

Reproduces Gilens and Page Table 3 using the authors' AMOS input diagram and replication data, then simulates. With the enforced 50th/90th correlation of .78, a true median-income coefficient of about 0.4 is estimated as essentially zero in over 20 percent of trials; at lower correlations the problem disappears. Descriptive reanalysis of the same dataset: in 185 cases where the two income groups' majorities are on opposite sides, the median-income side gets its preferred outcome 47 percent of the time; at 80 percent-plus support for change, change is enacted 47 percent of the time for median-income support and 52 percent for elites; when neither the rich nor the average favor change, change still occurs 23 percent of the time. Bashir states that the 'oligarchy' label comes from journalistic accounts, not Gilens and Page, and that his review does not show the wealthy and business lack advantages.

Source
Omar S. Bashir, Research & Politics 2(4), October-December 2015
Date
October-December 2015
Quoted from
Abstract, p. 1
Grade
Peer-reviewed
Document
https://doi.org/10.1177/2053168015608896
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Exhibit 698 · Peer-reviewed research note

Simulating representation: The devil's in the detail

Gilens's published response to Bashir 2015 (Research & Politics, April 2016). Crossref lists Gilens as sole author, OpenAlex describes it as a response to Omar Bashir's 2015 paper, and Elkjaer and Klitgaard 2024 describe it as arguing that Bashir's critique is misplaced. Its arguments are described here only through that review.

Source
Martin Gilens, Research & Politics 3(2), April 2016
Date
April 2016
Grade
Peer-reviewed
Document
https://doi.org/10.1177/2053168016654720
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Exhibit 699 · Authors' response (opinion essay)

Critics argued with our analysis of U.S. political inequality. Here are 5 ways they're wrong

Economic elites and interest groups can shape U.S. government policy — but Americans who are less well off have essentially no influence over what their government does.

The authors' own summary of their critics and replies. Concedes the 47/53 majority-win-rate figures from Bashir and Branham et al. Argues that slim majorities should not equal overwhelming ones. Using a 75 percent / 25 percent strong-support rule: when only the affluent strongly support a change it is adopted 46 percent of the time, when only the middle class strongly supports it 24 percent; when the affluent strongly oppose and the middle class does not, 4 percent; the reverse, 40 percent. With the other group held constant, strong affluent support raises adoption by about 25 points and strong middle-class support has no positive association. The authors say their 90th-percentile proxy may attribute to the affluent influence that belongs to the truly rich, citing Page, Bartels and Seawright.

Source
Martin Gilens and Benjamin I. Page, The Washington Post (Monkey Cage), 23 May 2016
Date
23 May 2016
Quoted from
opening paragraph
Grade
Reported
Document
https://web.archive.org/web/2016/https://www.washingtonpost.com/news/monkey-cage/wp/2016/05/23/critics-challenge-our-portrait-of-americas-political-inequality-heres-5-ways-they-are-wrong/
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Opinion essay by the study authors; the primary record is the dataset and Gilens 2015/2016 replies.

Exhibit 700 · Peer-reviewed article

When Do the Rich Win?

Political Science Quarterly article, 2017. Elkjaer and Iversen 2020 (p. 257) write that when the groups disagree 'the rich win only marginally more often than the middle class'. Elkjaer and Klitgaard 2024 (p. 320) report that on the small subset where middle- and high-income preferences oppose, the rich get their way 53 percent against 47 percent, and that disagreement of that kind occurs in about 1 of 10 cases. A 2016 Washington Monthly report on a pre-publication draft gives 1,594 of 1,779 policies (about 90 percent) with rich-middle agreement and 185 splits. Gilens and Page 2016 accept the 47/53 numbers.

Source
J. Alexander Branham, Stuart N. Soroka and Christopher Wlezien, Political Science Quarterly 132(1), pp. 43-62
Date
2017
Grade
Peer-reviewed
Document
https://doi.org/10.1002/polq.12577
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Exhibit 701 · Peer-reviewed article

The Party or the Purse? Unequal Representation in the US Senate

We find that affluent influence is overstated and itself contingent on partisanship—party trumps the purse when senators have to take sides. The poor get what they want more often from Democrats. The rich get what they want more often from Republicans, but only if Republican constituents side with the rich.

Evaluates income bias and partisan bias together on 49 Senate roll-call votes, 2001-2015. Uses three measures (responsiveness, congruence, taking-sides). Per Elkjaer and Klitgaard 2024 (p. 321), the authors call the responsiveness regressions 'messy to interpret' because of multicollinearity (p. 928) and find smaller disparities with the other measures.

Source
Jeffrey R. Lax, Justin H. Phillips and Adam Zelizer, American Political Science Review 113(4), pp. 917-940
Date
November 2019
Quoted from
Abstract (publisher page citation_abstract metadata)
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S0003055419000315
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Exhibit 702 · Peer-reviewed article

The Political Representation of Economic Interests: Subversion of Democracy or Middle-Class Supremacy?

middle-class power has remained remarkably strong over time, even as inequality has risen.

Argues that models regressing policy change on preferences for change (the Gilens and Bartels set-up) can credit the rich with influence when they are only better informed about short-run fiscal policy, and shows this on simulated data. Re-tests with preferred levels of spending, using International Social Survey Programme surveys across advanced democracies including the United States and a new dataset on who gains from fiscal policy. Finds policy aligns with middle-class interests. The scope is fiscal and redistributive policy, not Gilens's full range of 1,779 issues. The authors state that the middle-class result does not mean inequality is adequately addressed, and that the poor and lower middle class depend on coalitions and the generosity of higher classes. They also write that critics elevating the middle class to a sometimes coequal with the upper class do not explain why the rich so often get their way (p. 257).

Source
Mads Andreas Elkjaer and Torben Iversen, World Politics 72(2), pp. 254-290
Date
April 2020
Quoted from
Abstract, p. 254
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S0043887119000224
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2026-11-09
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Exhibit 703 · Peer-reviewed systematic review

Economic Inequality and Political Responsiveness: A Systematic Review

Often, the preferences of income groups overlap in a way that yields roughly equal representation, and even when income groups have opposing preferences, representational disparities are limited and better explained by partisanship than affluence

Codes 1,163 responsiveness estimates from 25 studies. Finds a positive income gradient overall with large variation. The predicted probability of an extreme pro-rich result (rich coefficient positive and significant, lower-income coefficient negative; high-versus-low comparisons) is .59 for models that enter several income groups together and .08 for models run separately; 96 percent of the models producing it enter several groups together. Differentials are weaker in the United States than in other democracies in published work. In US studies both parties respond more strongly to the rich than to the poor; Democrats overrepresent the poor relative to Republicans (study-level probabilities .27 against .12); Republicans overrepresent the rich over the poor in 8 of 10 cases and Democrats in about 2 of 3. Partisanship does not change the rich-over-middle result. More than one-third of studies (9 of 25) use only multivariate income-group models. The authors conclude the degree of differential responsiveness 'remains highly contested'.

Source
Mads Andreas Elkjaer and Michael Baggesen Klitgaard, Perspectives on Politics 22(2), pp. 318-337 (online 11 October 2021)
Date
June 2024
Quoted from
p. 318
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S1537592721002188
Accessed
2026-11-09
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Exhibit 704 · Journal article (APSA)

Is the Water Rising? Reflections on Inequality and American Democracy

there is no evidence of responsiveness to the views of constituents in the bottom third of the income distribution.

Summarizes the Senate responsiveness regressions: estimates for 1989-1994 roll calls by income third show responsiveness to middle- and upper-third constituents and none to the bottom third. Notes the pattern is 'for a single governmental institution in a single six-year period'. Figure 2 and note 2 give Census-based real family income growth under presidents, 1948-2001: 2.6 percent a year at the 20th percentile and 2.1 percent at the 95th under Democratic presidents; 0.6 percent at the 20th under Republican presidents, with affluent families doing equally well under both. Bartels treats each president's influence as beginning one year after taking office. Describes Gilens's then-unpublished work as a parallel finding.

Source
Larry M. Bartels, PS: Political Science & Politics, January 2006, pp. 39-42
Date
January 2006
Quoted from
p. 40
Grade
Peer-reviewed
Document
https://apsanet.org/Portals/54/files/Task%20Force%20Reports/PSJan06Bartels.pdf
Accessed
2026-11-09
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Exhibit 705 · Working paper abstract

Economic Inequality and Political Representation (Russell Sage Foundation working paper abstract; basis of a chapter of Unequal Democracy, 2008)

The preferences of constituents near the top of the income distribution are even more influential, while those in the bottom fifth receive little or no weight, especially from Republican senators.

Abstract of the Senate analysis later published in Unequal Democracy (Princeton University Press and Russell Sage Foundation, 2008). Covers summary roll-call measures plus votes on the minimum wage, civil rights, government spending and abortion. Reports that constituents at the 75th percentile have almost three times the influence of those at the 25th on general voting patterns, that the bottom fifth receives little or no weight especially from Republican senators, and that for ideology the affluent advantage is partly explained by turnout and contact with senators while for abortion it is not.

Source
Larry M. Bartels, Princeton University, for the Russell Sage Foundation
Date
2005
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://www.russellsage.org/node/4352
Accessed
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Exhibit 706 · Working paper abstract

Partisan Politics and the U.S. Income Distribution (Russell Sage Foundation working paper abstract; basis of chapter 2 of Unequal Democracy)

On average, families at the 95th percentile of the income distribution have experienced identical income growth under Democratic and Republican presidents, while those at the 20th percentile have experienced more than four times as much income growth under Democrats as they have under Republicans.

Reports large, consistent differences in real pre-tax family income growth under Democratic and Republican presidents in the post-war United States. Families at the 95th percentile saw identical growth under both parties and families at the 20th percentile more than four times as much under Democrats. Bartels attributes the gap to unemployment (30 percent lower under Democratic presidents on average) and GDP growth (30 percent higher). This is an outcome by party of president; it does not measure whose stated preferences became policy.

Source
Larry M. Bartels, Princeton University, for the Russell Sage Foundation
Date
2005
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://www.russellsage.org/node/4351
Accessed
2026-11-09
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Exhibit 707 · Peer-reviewed article

Presidents and the US Economy: An Econometric Exploration

Rather, it appears that the Democratic edge stems mainly from more benign oil shocks, superior total factor productivity (TFP) performance, a more favorable international environment, and perhaps more optimistic consumer expectations about the near-term future.

Finds the US economy performed better under Democratic presidents on most measures. Attributes the gap mainly to more benign oil shocks, better total factor productivity, a more favorable international environment and perhaps more optimistic consumer expectations, not to more expansionary monetary or fiscal policy. Known from the EconPapers abstract page. Relevant as the strongest published qualification of how to read Bartels's party-of-president income-growth pattern.

Source
Alan S. Blinder and Mark W. Watson, American Economic Review 106(4), pp. 1015-1045
Date
April 2016
Quoted from
Abstract (Blinder and Watson, Am Econ Rev 106(4): 1015-1045), via Crossref
Grade
Peer-reviewed
Document
https://doi.org/10.1257/aer.20140913
Accessed
2026-11-09
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Exhibit 708 · Peer-reviewed article

Democracy and the Policy Preferences of Wealthy Americans

We find that they are extremely active politically and that they are much more conservative than the American public as a whole with respect to important policies concerning taxation, economic regulation, and especially social welfare programs.

Pilot interview survey of wealthy Chicago-area residents in 2011 (NORC interviewers): 104 interviews in all, 83 in the refined sample drawn from the Wealthfinder 'rank A' list (about the top 4 percent of wealth-holding households) narrowed toward the top 1 percent; response rate 37 percent; mean wealth $14,006,338, median $7,500,000; mean income $1,040,140. 58 percent identified as Republican and 27 percent as Democrat (leaners included). Wealthy Democrats were more conservative on economic issues than Democrats in the general public, and wealth and party had independent effects. It measures preferences and political activity, not policy outcomes. The authors warn of sampling error in a small pilot confined to one metropolitan area and offer the rival reading that wealthy preferences may reflect better information. Read from the Northwestern-hosted PDF.

Source
Benjamin I. Page, Larry M. Bartels and Jason Seawright, Perspectives on Politics 11(1), pp. 51-73
Date
March 2013
Quoted from
Abstract, p. 51
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S153759271200360X
Accessed
2026-11-09
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Exhibit 709 · Pre-publication book manuscript

Advocacy and Policy Change, pre-publication manuscript of Lobbying and Policy Change (19 July 2008)

If the wealthy are so certain to win, they should already have won in a previous iteration of the process.

Draft pagination, not the printed book. Reports 214 'sides' on 98 issues and 2,221 advocates (23 per case). Chapter 1 reasons that existing policy already reflects past power, so lobbying outcomes depend on changes in mobilization, not levels. Chapter 10 Table 10.5: the side with more resources won between 45 and 56 percent of the time, with no statistically significant relationship. The same chapter calls the status-quo equilibrium 'quite unfair' in many cases.

Source
Baumgartner, Berry, Hojnacki, Kimball and Leech (manuscript hosted by the authors)
Date
19 July 2008
Quoted from
draft Chapter 1, p. 32
Grade
Peer-reviewed
Document
https://fbaum.unc.edu/books/lobby/Advocacy_July_19_2008.pdf
Accessed
2026-11-09
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Exhibit 710 · Peer-reviewed article

Winner-Take-All Politics: Public Policy, Political Organization, and the Precipitous Rise of Top Incomes in the United States

they miss the profound role of government policy in creating this “winner-take-all” pattern

Argues that political science accounts of rising inequality that rest on the median voter in electoral politics miss the role of government policy and of the organizational transformation of American politics. Their own account links major policy shifts that raised the standing of those at the top to organized efforts by resourceful private interests. The companion trade book, Winner-Take-All Politics (Simon & Schuster, 2010), has chapters titled 'The Politics of Organized Combat', 'A Tale of Two Parties' and 'Democrats Climb Aboard' (table of contents as listed in a library record).

Source
Jacob S. Hacker and Paul Pierson, Politics & Society 38(2), pp. 152-204
Date
2010
Quoted from
Abstract (Hacker and Pierson, Politics & Society 38(2): 152-204), via Crossref
Grade
Peer-reviewed
Document
https://doi.org/10.1177/0032329210365042
Accessed
2026-11-09
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Note
Quote taken from the abstract as supplied by OpenAlex; confirm against the publisher page. The publisher abstract was seen only as copied by OpenAlex; no wording is quoted until checked against the publisher page.

Exhibit 711 · Peer-reviewed article

After the 'Master Theory': Downs, Schattschneider, and the Rebirth of Policy-Focused Analysis

These benefits are illustrated through brief examinations of two of the biggest changes in American politics over the last generation: asymmetric partisan polarization and the growing concentration of income at the top.

Published in the same issue as Gilens and Page 2014. Contrasts a Downsian view (elections and the median voter) with a Schattschneider view in which policy and organized groups are central. Applies the second view to asymmetric partisan polarization and to income concentration at the top.

Source
Jacob S. Hacker and Paul Pierson, Perspectives on Politics 12(3), pp. 643-662
Date
September 2014
Quoted from
Abstract (Hacker and Pierson, Perspectives on Politics 12(3): 643-662), via Crossref
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S1537592714001637
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
The publisher abstract was seen only as copied by OpenAlex; no wording is quoted until checked against the publisher page.

Exhibit 712 · SEC filing

Facebook, Inc. Form 10-K for fiscal year 2017

we recently announced changes to our News Feed ranking algorithm to help our users have more meaningful social interactions, and we expect that these changes will have the effect of reducing time spent and some measures of user engagement with Facebook, which could adversely affect our financial results.

Annual report. Advertising $39,942M of $40,653M revenue (98% of revenue per risk factors). Lists decreased user engagement, including time spent, as a risk to ad revenue, and says the announced News Feed change was expected to reduce time spent.

Source
Facebook, Inc. (SEC filing)
Date
1 February 2018
Quoted from
Item 1A, Risk Factors (user engagement risk factor)
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1326801/000132680118000009/fb-12312017x10k.htm
Accessed
2026-11-09
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Exhibit 713 · SEC filing

Facebook, Inc. Form 10-K for fiscal year 2018

We generate substantially all of our revenue from selling advertising placements to marketers.

Annual report. Advertising $55,013M of $55,838M revenue in 2018. Repeats that News Feed changes for more meaningful interactions have had the effect of reducing time spent.

Source
Facebook, Inc. (SEC filing)
Date
31 January 2019
Quoted from
Item 1, Business (Overview)
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1326801/000132680119000009/fb-12312018x10k.htm
Accessed
2026-11-09
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Exhibit 714 · SEC filing

Meta Platforms, Inc. Form 10-K for fiscal year 2024

Currently, we generate substantially all of our revenue from selling advertising placements on our family of apps to marketers

Annual report. Advertising $160,633M of $164,501M revenue in 2024 ($131,948M in 2023; $113,642M in 2022).

Source
Meta Platforms, Inc. (SEC filing)
Date
30 January 2025
Quoted from
Item 1, Business (Overview)
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1326801/000132680125000017/meta-20241231.htm
Accessed
2026-11-09
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Exhibit 715 · Company announcement

Bringing People Closer Together

With this update, we will also prioritize posts that spark conversations and meaningful interactions between people.

Announcement of the News Feed ranking change that prioritizes posts that spark conversations and meaningful interactions; warns Pages may see reach and watch time decrease.

Source
Facebook (Adam Mosseri, Head of News Feed)
Date
11 January 2018
Quoted from
Body, second section
Grade
Primary record
Document
https://about.fb.com/news/2018/01/news-feed-fyi-bringing-people-closer-together/
Accessed
2026-11-09
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Exhibit 716 · Congressional testimony (written statement)

Statement of Frances Haugen, Senate Commerce Subcommittee on Consumer Protection, Product Safety, and Data Security

The result has been a system that amplifies division, extremism, and polarization — and undermining societies around the world.

Former Facebook product manager's written statement. Characterizes Facebook leadership's choices and states that internal research confirmed the problems. A statement of her account; the underlying documents are not reproduced in it.

Source
Frances Haugen (U.S. Senate Committee on Commerce, Science, and Transportation)
Date
4 October 2021
Quoted from
p. 2
Grade
Primary record
Document
https://www.commerce.senate.gov/index.php/services/files/FC8A558E-824E-4914-BEDB-3A7B1190BD49
Accessed
2026-11-09
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Exhibit 717 · Company statement

Investments to Fight Polarization

this particular story wilfully ignored critical facts that undermined its narrative.

Facebook's response the day after the Wall Street Journal reported it shelved polarization research. Lists the 2018 News Feed change, integrity staffing, recommendation restrictions and hate-speech enforcement.

Source
Facebook (Guy Rosen, VP Integrity)
Date
27 May 2020
Quoted from
Opening paragraph
Grade
Primary record
Document
https://about.fb.com/news/2020/05/investments-to-fight-polarization/
Accessed
2026-11-09
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Exhibit 718 · Executive statement (reported)

Mark Zuckerberg's public response to the Haugen testimony, as reported

Zuckerberg's post responding to the Senate hearing. States that advertisers tell the company they do not want their ads next to harmful or angry content, and that the claim that Facebook puts profit over safety is untrue.

Source
Mark Zuckerberg, Facebook (reported by SiliconANGLE)
Date
5 October 2021
Grade
Reported
Document
https://siliconangle.com/2021/10/05/facebooks-mark-zuckerberg-denies-company-focuses-growth-safety/
Accessed
2026-11-09
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Exhibit 719 · Peer-reviewed study

Out-group animosity drives engagement on social media

we found that posts about the political out-group were shared or retweeted about twice as often as posts about the in-group.

Analysis of 2,730,215 Facebook and Twitter posts from news media and US congressional members. Out-group language was the strongest predictor of shares; authors state results are correlational.

Source
Rathje, Van Bavel, van der Linden (PNAS)
Date
23 June 2021
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1073/pnas.2024292118
Accessed
2026-11-09
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Findings citing this exhibit

Exhibit 720 · Peer-reviewed study

Emotion shapes the diffusion of moralized content in social networks

the presence of moral-emotional language in political messages substantially increases their diffusion within (and less so between) ideological group boundaries.

Twitter study on gun control, same-sex marriage and climate change messages.

Source
Brady, Wills, Jost, Tucker, Van Bavel (PNAS)
Date
26 June 2017
Quoted from
Significance statement
Grade
Peer-reviewed
Document
https://doi.org/10.1073/pnas.1618923114
Accessed
2026-11-09
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Exhibit 721 · Peer-reviewed study

How social learning amplifies moral outrage expression in online social networks

positive social feedback for outrage expressions increases the likelihood of future outrage expressions, consistent with principles of reinforcement learning.

Two preregistered observational Twitter studies (7,331 users, 12.7 million tweets) and two behavioral experiments (N = 240). Authors state the observational studies cannot support causal inference.

Source
Brady, McLoughlin, Doan, Crockett (Science Advances)
Date
13 August 2021
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1126/sciadv.abe5641
Accessed
2026-11-09
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Exhibit 722 · Peer-reviewed study

Algorithmic amplification of politics on Twitter

In six out of seven countries studied, the mainstream political right enjoys higher algorithmic amplification than the mainstream political left.

Audit using a holdout group of about 2 million accounts on a reverse-chronological feed. Right amplified more than left in six of seven countries (Germany not significant); right-leaning US news amplified marginally more; no evidence extreme groups were amplified more than moderate ones. Authors call the causal mechanism a topic for further study.

Source
Huszar, Ktena, O'Brien, Belli, Schlaikjer, Hardt (PNAS; Twitter authors)
Date
21 December 2021
Quoted from
Abstract (PMC8740571)
Grade
Peer-reviewed
Document
https://doi.org/10.1073/pnas.2025334119
Accessed
2026-11-09
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Exhibit 723 · Peer-reviewed study

Engagement, user satisfaction, and the amplification of divisive content on social media

Twitter’s engagement-based ranking algorithm amplifies emotionally charged, out-group hostile content that users say makes them feel worse about their political out-group.

Preregistered audit of Twitter's engagement-based ranking against a reverse-chronological baseline, with user surveys.

Source
Milli, Carroll, Wang, Pandey, Zhao, Dragan (PNAS Nexus)
Date
27 February 2025
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1093/pnasnexus/pgaf062
Accessed
2026-11-09
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Exhibit 724 · Peer-reviewed study

How do social media feed algorithms affect attitudes and behavior in an election campaign?

the chronological feed did not significantly alter levels of issue polarization, affective polarization, political knowledge, or other key attitudes during the 3-month study period.

Randomized experiment with Meta cooperation: consenting Facebook and Instagram users moved to reverse-chronological feeds, 3 months, 2020 election. Study window overlapped temporary Meta emergency measures (criticized in a 2024 Science eLetter).

Source
Guess, Malhotra, Pan, Barbera, Allcott, Brown et al. (Science)
Date
28 July 2023
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1126/science.abp9364
Accessed
2026-11-09
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Exhibit 725 · Peer-reviewed study

Reshares on social media amplify political news but do not detectably affect beliefs or opinions

Contrary to expectations, the treatment does not significantly affect political polarization or any measure of individual-level political attitudes.

Randomized removal of reshares from Facebook feeds during the 2020 election.

Source
Guess, Malhotra, Pan, Barbera, Allcott et al. (Science)
Date
28 July 2023
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1126/science.add8424
Accessed
2026-11-09
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Findings citing this exhibit

Exhibit 726 · Peer-reviewed study

Like-minded sources on Facebook are prevalent but not polarizing

had no measurable effects on eight preregistered attitudinal measures such as affective polarization, ideological extremity, candidate evaluations and belief in false claims.

Field experiment, 23,377 users; like-minded-source exposure cut by about one-third.

Source
Nyhan, Settle, Thorson, Wojcieszak, Barbera, Chen et al. (Nature)
Date
27 July 2023
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1038/s41586-023-06297-w
Accessed
2026-11-09
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Exhibit 727 · Peer-reviewed study

Asymmetric ideological segregation in exposure to political news on Facebook

most misinformation, as identified by Meta’s Third-Party Fact-Checking Program, exists within this homogeneously conservative corner, which has no equivalent on the liberal side.

Aggregated data for 208 million US Facebook users, 2020. Segregation rises from potential exposure to actual exposure to engagement; conservative-only news corner holds most fact-checked misinformation.

Source
Gonzalez-Bailon, Lazer, Barbera, Zhang, Allcott, Brown et al. (Science)
Date
28 July 2023
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1126/science.ade7138
Accessed
2026-11-09
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Exhibit 728 · Peer-reviewed study

The effects of Facebook and Instagram on the 2020 election: A deactivation experiment

the effects of both Facebook and Instagram deactivation on affective and issue polarization, perceived legitimacy of the election, candidate favorability, and voter turnout were all precisely estimated and close to zero.

Randomized 6-week deactivation of 19,857 Facebook and 15,585 Instagram users before the 2020 election.

Source
Allcott, Gentzkow, Mason, Wilkins, Barbera et al. (PNAS)
Date
13 May 2024
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1073/pnas.2321584121
Accessed
2026-11-09
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Exhibit 729 · Peer-reviewed study

Reranking partisan animosity in algorithmic social media feeds alters affective polarization

providing causal evidence that exposure to AAPA content alters affective polarization.

Preregistered 10-day field experiment, 1,256 participants on X during the 2024 campaign, with an independent browser-side reranking method.

Source
Piccardi, Saveski, Jia, Hancock et al. (Science)
Date
27 November 2025
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1126/science.adu5584
Accessed
2026-11-09
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Exhibit 730 · Peer-reviewed study

Examining the consumption of radical content on YouTube

We find little evidence that the YouTube recommendation algorithm is driving attention to this content.

User-trajectory data across the political spectrum, 2016-2019.

Source
Hosseinmardi, Ghasemian, Clauset, Mobius, Rothschild, Watts (PNAS)
Date
2 August 2021
Quoted from
Significance statement
Grade
Peer-reviewed
Document
https://doi.org/10.1073/pnas.2101967118
Accessed
2026-11-09
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Exhibit 731 · Peer-reviewed study

Subscriptions and external links help drive resentful users to alternative and extremist YouTube channels

YouTube’s algorithms were not sending people down “rabbit holes” during our observation window in 2020

Paired behavioral and survey data, n = 1,181, 2020.

Source
Chen, Nyhan, Reifler, Robertson, Wilson (Science Advances)
Date
September 2023
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1126/sciadv.add8080
Accessed
2026-11-09
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Exhibit 732 · Agency dataset

OpenFEC committee totals, 2016-2024 cycles: WinRed, ActBlue, campaign and party committees

FEC totals as filed: WinRed 2020 individual contributions $2,085.2M, refunded $154.7M; ActBlue 2020 $4,243.1M, refunded $97.9M. Also Trump, Biden, RNC, DNC 2020 committees. Refunds are not broken down by reason.

Source
Federal Election Commission (OpenFEC API)
Date
accessed 9 November 2026
Grade
Primary record
Document
https://api.open.fec.gov/v1/committee/C00694323/totals/
Accessed
2026-11-09
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Exhibit 733 · Agency report

Legislative Recommendations of the Federal Election Commission 2021

Commission staff are regularly contacted by individuals who have discovered recurring contributions to political committees have been charged to their credit card accounts or deducted from their checking accounts.

Asks Congress to require affirmative consent for recurring contributions, bar implied consent such as pre-checked boxes, require disclosures, and require immediate cancellation.

Source
Federal Election Commission
Date
6 May 2021
Quoted from
p. 12, Explanation
Grade
Primary record
Document
https://www.fec.gov/resources/cms-content/documents/legrec2021.pdf
Accessed
2026-11-09
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Exhibit 734 · Court opinion

WinRed, Inc. v. Ellison, 59 F.4th 934 (8th Cir. 2023), No. 22-1238

Clear and conspicuous disclaimers about auto-recurring donations might have legitimated otherwise-illegal solicitation tactics.

Affirms dismissal of WinRed's suit to block a Minnesota AG investigation of pre-checked recurring boxes. Recounts the 29 April 2021 joint letter from NY, CT, MD and MN AGs, the NYT report, and FEC matters MUR 7255 and MUR 7201. Does not find a violation.

Source
U.S. Court of Appeals for the Eighth Circuit
Date
7 February 2023
Quoted from
Slip op. Part II (PDF p. 9)
Grade
Primary record
Document
https://ecf.ca8.uscourts.gov/opndir/23/02/221238P.pdf
Accessed
2026-11-09
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Exhibit 735 · Agency enforcement file

MUR 7201 (Ted Cruz for Senate), Factual and Legal Analysis

The Complainant, who concedes she initially authorized the recurring contributions, does not appear to describe such a violation, and the Committee has confirmed that Complainant's recurring contributions have been canceled.

Single complainant alleged two monthly recurring contributions were charged after she asked to cancel in September 2016. Commission dismissed 5-0 on prosecutorial discretion; committee blamed a third-party vendor.

Source
Federal Election Commission
Date
26 January 2018
Quoted from
Factual and Legal Analysis, p. 2
Grade
Primary record
Document
https://www.fec.gov/files/legal/murs/7201/18044436233.pdf
Accessed
2026-11-09
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Exhibit 736 · Peer-reviewed study

Dark defaults: How choice architecture steers political campaign donations

We estimate that defaults increased campaign donations by over $43 million while increasing requested refunds by almost $3 million.

Staggered difference-in-differences on 14.8 million donations by 2.6 million donors using WinRed FEC data; eight campaign websites, all Republican, adopted weekly pre-checked recurring boxes in 2020.

Source
Posner, Simonov, Mrkva, Johnson (PNAS 120)
Date
2023
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1073/pnas.2218385120
Accessed
2026-11-09
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Exhibit 737 · Peer-reviewed study

Manipulative tactics are the norm in political emails: Evidence from 300K emails from the 2020 US election cycle

manipulative tactics—techniques using some level of deception or clickbait—are the norm, not the exception.

Corpus of more than 300,000 emails from over 3,000 senders including federal and state candidates and PACs across parties.

Source
Mathur, Wang, Schwemmer, Hamin, Stewart, Narayanan (Big Data & Society)
Date
January 2023
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1177/20539517221145371
Accessed
2026-11-09
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Exhibit 738 · Organization statement

The Facts the NYT Ignored

the use of which ActBlue pioneered years ago, and continues to promote today

WinRed's same-day response to the New York Times report. Says ActBlue pioneered recurring and pre-checked boxes, and that pre-checked boxes appeared on DCCC and DSCC ActBlue pages. Partisan self-description; use for WinRed's position only.

Source
WinRed
Date
3 April 2021
Quoted from
Second paragraph
Grade
Primary record
Document
https://winred.com/blog/the-facts-the-nyt-ignored
Accessed
2026-11-09
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Exhibit 739 · News report

How Trump Steered Supporters Into Unwitting Donations

The New York Times report of 3 April 2021 on the Trump campaign's pre-checked recurring boxes and refunds. The Eighth Circuit opinion in WinRed v. Ellison (exhibit 734) describes the report and press summaries describe it.

Source
The New York Times (Shane Goldmacher)
Date
3 April 2021
Grade
Reported
Document
https://www.nytimes.com/2021/04/03/us/politics/trump-donations.html
Accessed
2026-11-09
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Exhibit 740 · Published critique (eLetter, not peer reviewed)

Social media algorithms can curb misinformation, but do they? (Science eLetter)

Argues the Guess et al. control condition overlapped temporary Meta emergency measures. Guess et al. replied; Science did not request corrections.

Source
Bagchi, Menczer, Grabowicz et al. (Science eLetters)
Date
September 2024
Grade
Reported
Document
https://osome.iu.edu/research/blog/science-eletter-social-media-algorithms-can-curb-misinformation-but-do-they
Accessed
2026-11-09
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Exhibit 741 · Statute

Stop Trading on Congressional Knowledge Act of 2012, Public Law 112-105 (S. 2038)

each Member of Congress or employee of Congress owes a duty arising from a relationship of trust and confidence to the Congress, the United States Government, and the citizens of the United States with respect to material, nonpublic information derived from such person's position as a Member of Congress or employee of Congress or gained from the performance of such person's official responsibilities.

Sec. 3 directs the House and Senate ethics committees to issue guidance that members and employees may not use nonpublic information for private profit. Sec. 4 affirms that members and employees are not exempt from insider trading law. Sec. 6 adds EIGA s.103(l): a report of each covered transaction within 30 days of notification and no later than 45 days after the transaction, for Members and congressional employees among others. Sec. 7 orders a GAO report on political intelligence. Sec. 8 required public online posting of members' and staff's disclosure forms and electronic filing within 18 months.

Source
U.S. Congress
Date
4 April 2012
Quoted from
Sec. 4(b)(2), new s.21A(g)(1) of the Securities Exchange Act of 1934, 126 Stat. 292
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-112publ105/html/PLAW-112publ105.htm
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Exhibit 742 · Statute

Public Law 113-7 (S. 716), modifying online access to financial disclosure statements under the STOCK Act

section 8(a) and section 11(a) of the STOCK Act (5 U.S.C. App. 105 note) shall not be effective.

Makes sections 8(a) and 11(a) of the STOCK Act ineffective except for forms filed by the President, Vice President, Members of Congress, candidates for Congress, and Senate-confirmed Level I and II officers. Amends section 8(b) so the electronic-filing and searchable-database requirement covers Members and candidates only, and moves the deadline from 18 months after enactment to 1 January 2014. Congressional staff therefore remain subject to the s.103(l) reporting duty but their forms are not posted in the public databases. Passed the Senate 11 April and the House 12 April 2013 (legislative history on the enrolled text).

Source
U.S. Congress
Date
15 April 2013
Quoted from
Sec. 1(a)(1), 127 Stat. 438
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-113publ7/html/PLAW-113publ7.htm
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Exhibit 743 · Statute

5 U.S.C. 13106, Failure to file or filing false reports (Ethics in Government Act, former s.104)

shall, at the direction of and pursuant to regulations issued by the supervising ethics office, pay a filing fee of $200.

(a) The Attorney General may seek a civil penalty up to $50,000 for knowing and willful failure to file or falsification; knowing and willful failure to file is a crime punishable by a fine, and falsification by fine or up to 1 year. (b) Each congressional ethics committee must refer to the Attorney General any individual it has reasonable cause to believe willfully failed to file. (d) A filer more than 30 days late pays $200, and the supervising ethics office may waive the fee in extraordinary circumstances.

Source
Office of the Law Revision Counsel (via Cornell LII)
Date
Current text; codified by Pub. L. 117-286, 27 December 2022
Quoted from
s.13106(d)(1)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/5/13106
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Note
The $200 fee predates the 2022 codification (former EIGA s.104(d), 5 U.S.C. app. 104).

Exhibit 744 · Congressional report

Office of Congressional Ethics Report and Findings, Review No. 21-3355 (Rep. Pat Fallon)

The OCE also found that the Committee has been inconsistent in the manner in which it has calculated and assessed fines.

The OCE Board voted 5-0 to refer, finding substantial reason to believe Rep. Fallon (R-TX) failed to file timely PTRs; between January and December 2021 he failed to timely disclose 122 transactions. Fallon's spokesperson attributed the lapse to unfamiliarity as a freshman member. Section II.B sets out the Committee's late-fee schedule ($200 for the first late PTR; $200 per month of late transactions for the 2nd to 4th; $200 per late transaction from the 5th) and states that the OCE found some members were never directed to pay a fine and that the Committee was inconsistent in assessing fines. Findings state they do not determine whether a violation occurred. Fallon declined an interview.

Source
Office of Congressional Ethics, U.S. House of Representatives
Date
Adopted 18 February 2022; transmitted 2 March 2022
Quoted from
Findings of Fact para. 29, p. 12
Grade
Primary record
Document
https://ethics.house.gov/wp-content/uploads/2022/05/OCE-Report-and-Findings_10.pdf
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Exhibit 745 · Congressional report

Office of Congressional Ethics Report and Findings, Review No. 21-6367 (Rep. Thomas Suozzi)

all of his investments are managed by a broker

OCE Board referral to the Committee on Ethics of allegations that Rep. Suozzi (D-NY) failed to file timely PTRs. Suozzi told the OCE his investments are managed by a broker and that his office had misunderstood whether broker-managed trades required PTRs. Published by the Committee under Committee Rule 17A with its 29 July 2022 dismissal statement.

Source
Office of Congressional Ethics, U.S. House of Representatives
Date
Adopted 18 February 2022; published 29 July 2022
Quoted from
Findings of Fact para. 44
Grade
Primary record
Document
https://ethics.house.gov/wp-content/uploads/2022/07/OCE-Report-and-Findings_13.pdf
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Note
Quote is a fragment of para. 44; the sentence continues onto the next line of the report.

Exhibit 746 · Congressional report

Office of Congressional Ethics Report and Findings, Review No. 21-7423 (Rep. John Rutherford)

Rep. Rutherford’s PTR filings generally include transactions dates that are inconsistent with the date provided in his statements.

OCE Board referral to the Committee on Ethics that Rep. Rutherford (R-FL) failed to file timely periodic transaction reports.

Source
Office of Congressional Ethics, U.S. House of Representatives
Date
Adopted 18 February 2022
Quoted from
Findings of Fact para. 43, PDF p. 17 (OCE report adopted 18 February 2022, Review No. 21-7423)
Grade
Primary record
Document
https://ethics.house.gov/wp-content/uploads/2022/05/OCE-Report-and-Findings_12.pdf
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Note
Read headings and selected paragraphs only; read in full before use.

Exhibit 747 · Press release

Statement of the Chairman and Ranking Member of the Committee on Ethics regarding Reps. Fallon, Jacobs and Suozzi (Press Release 277)

The Committee concluded that there was not clear evidence that the errors and omissions in the Members’ PTRs were knowing or willful and that the Members were generally unclear on the requirements relating to PTR filings.

Chairman Deutch (D-FL) and Ranking Member Walorski (R-IN) announce that the Committee unanimously dismissed OCE referrals concerning two Republicans (Fallon, Jacobs) and one Democrat (Suozzi) over late PTRs, says each member made remedial efforts, and says the Committee is working to address programmatic issues raised by the referrals.

Source
Committee on Ethics, U.S. House of Representatives
Date
29 July 2022
Quoted from
para. 2
Grade
Primary record
Document
https://ethics.house.gov/wp-content/uploads/2022/07/Press-Release_277.pdf
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Exhibit 748 · Congressional hearing

Examining Stock Trading Reforms for Congress, hearing before the Committee on House Administration, 117th Congress, 2nd Session

I am confident that the majority, if not all of them, weren’t malicious but inadvertent

Chair Lofgren (D-CA) and Ranking Member Davis (R-IL) open a hearing on STOCK Act compliance and reform. Witnesses include Jacob Straus (CRS), Liz Hempowicz (POGO), Donald Sherman, Donna Nagy and Jennifer Schulp (Cato). In his opening statement Davis cites a press tally of members with reported violations and describes the violations as probably inadvertent. The testimony lists bills before the committee.

Source
Committee on House Administration, U.S. House of Representatives
Date
7 April 2022
Quoted from
Opening statement of Ranking Member Davis, hearing of 7 April 2022 (printed p. 9; PDF p. 15)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/CHRG-117hhrg47699/pdf/CHRG-117hhrg47699.pdf
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Exhibit 749 · Financial disclosure

Periodic Transaction Report, Hon. Nancy Pelosi (CA-11), Filing ID 20024542

Purchased 50 call options with a strike price of $200 and an expiration date of 1/17/25.

Reports two transactions with owner code SP (spouse) in Palo Alto Networks (PANW) call options, 12 February 2024 ($500,001 to $1,000,000) and 21 February 2024 ($100,001 to $250,000), each with notification date equal to transaction date, filed within the 45-day window. The form certifies that all transactions required by the STOCK Act are disclosed. A disclosure record shows trades; it does not show intent or information.

Source
Clerk of the House of Representatives
Date
Signed 23 February 2024
Quoted from
p. 1, first transaction
Grade
Primary record
Document
https://disclosures-clerk.house.gov/public_disc/ptr-pdfs/2024/20024542.pdf
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Exhibit 750 · Press release

Pelosi statement in support of congressional stock trading ban (HONEST Act)

I strongly support this legislation and look forward to voting for it on the Floor of the House.

After the Senate Homeland Security and Governmental Affairs Committee advanced the HONEST Act, Pelosi says she strongly supports the legislation and expects to vote for it on the House floor. The bill covers the President and Vice President as well as members.

Source
Office of Rep. Nancy Pelosi
Date
30 July 2025
Quoted from
Press release dated 30 July 2025, final sentence of the statement (second paragraph)
Grade
Primary record
Document
https://pelosi.house.gov/news/press-releases/pelosi-statement-support-congressional-stock-trading-ban
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Exhibit 751 · News report

Nancy Pelosi says federal lawmakers should be able to trade stock in office: 'This is a free market'

Reports Pelosi's 15 December 2021 news-conference remarks that members should be able to participate in a free market economy and that members should report their trades. Other outlets (Washington Examiner, AP) add that she says she owns no stock and has no involvement in or prior knowledge of her husband's trades.

Source
CNBC
Date
16 December 2021
Grade
Reported
Document
https://www.cnbc.com/2021/12/16/nancy-pelosi-federal-lawmakers-should-be-able-to-trade-stock.html
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Exhibit 752 · News report

Justice Department drops insider trading probes into three senators

Aides told NBC the Justice Department ended inquiries into Loeffler (R-GA), Feinstein (D-CA) and Inhofe (R-OK); the Burr inquiry continued. Loeffler's spokesman called it exoneration and the inquiry politically motivated; Feinstein's office said her assets were in a blind trust and her husband traded; Inhofe said he does not make his own trades; Burr said he relied solely on public news reports.

Source
NBC News
Date
26 May 2020
Grade
Reported
Document
https://www.nbcnews.com/politics/congress/justice-department-drops-insider-trading-probes-three-senators-n1215196
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Note
DOJ does not publish declinations. Read via summarizer.

Exhibit 753 · News report

Justice Department closes investigation into Senator Richard Burr over stock sales

Reports that the Justice Department closed its inquiry into Burr's late-January to mid-February 2020 stock sales without charges; Burr said he relied on public news reports and that the case is closed; the FBI had seized his phone in May 2020 and he stepped down as Intelligence Committee chair.

Source
CBS News / Associated Press
Date
19-20 January 2021
Grade
Reported
Document
https://www.cbsnews.com/amp/news/doj-closes-insider-trading-investigation-into-richard-burr
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Exhibit 754 · News report

Sen. Loeffler ethics inquiry dismissed

Reports a 16 June 2020 Senate Ethics Committee letter, supplied by a Loeffler spokesperson, saying the committee 'did not find evidence' the actions violated federal law, Senate rules or standards of conduct and 'has dismissed this matter'. The committee staff director did not confirm authenticity to the reporter. The Perdue campaign likewise cited a 16 June 2020 dismissal letter but released only two sentences.

Source
CQ Roll Call
Date
16 June 2020
Grade
Reported
Document
https://rollcall.com/2020/06/16/sen-loeffler-ethics-inquiry-dismissed/
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Note
Primary would be the Senate Ethics Committee letters. Committee does not publish dismissals.

Exhibit 755 · News report

Stock trades by Senator Perdue said to have prompted DoJ inquiry (New York Times report)

Reuters summary, published 25 November 2020, of a New York Times report on Senator David Perdue's trades in Cardlytics, where he had served on the board. It says the Justice Department inquiry 'has since been shut without charges' and quotes campaign spokesman John Burke calling the outcome 'exonerating evidence' and the allegations 'baseless accusations'.

Source
The New York Times via Yahoo News
Date
Late 2020
Grade
Reported
Document
https://news.yahoo.com/stock-trades-senator-perdue-said-210757617.html
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Exhibit 756 · News report

Burr probe over, no action: SEC ends insider trading investigation

Reports that retired Senator Richard Burr said the SEC had taken no action and ended its investigation.

Source
InsuranceNewsNet (wire report)
Date
7 January 2023
Grade
Reported
Document
https://insurancenewsnet.com/oarticle/burr-probe-over-no-actionburr-sec-ends-insider-trading-investigation-with-no-action
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Rests on Burr's own statement. Primary would be the SEC closing letter or Burr's statement. Placeholder wire copy.

Exhibit 757 · Press release

SEC Charges Congressman and Others in Insider Trading Scheme (Press Release 2018-151)

Christopher Collins, who served as an independent director of an Australian biotech company, Innate Immunotherapeutics Ltd., is charged with tipping Cameron Collins after receiving confidential information about negative clinical trial results for Innate’s multiple sclerosis drug.

SEC alleges Rep. Christopher Collins (R-NY), an independent director of Innate Immunotherapeutics, learned of negative clinical trial results for the company's MS drug and tipped his son Cameron, who sold shares before the announcement. The information came from his corporate board role, not from his office.

Source
U.S. Securities and Exchange Commission
Date
8 August 2018
Quoted from
SEC press release 2018-151, 8 Aug 2018, second paragraph
Grade
Primary record
Document
https://www.sec.gov/news/press-release/2018-151
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Exhibit 758 · Agency report

SEC Litigation Release No. 24687 (Collins, Collins, Zarsky settlements)

Christopher Collins consented to be permanently barred from acting as an officer or director of any public company.

Christopher Collins consented to a permanent injunction under the antifraud provisions and a permanent officer-and-director bar; Cameron Collins and Stephen Zarsky agreed to disgorge avoided losses ($634,299 and $159,880 per a secondary summary). All three pleaded guilty to related criminal charges.

Source
U.S. Securities and Exchange Commission
Date
9 December 2019
Quoted from
SEC Litigation Release LR-24687, 9 Dec 2019, paragraph beginning "The three defendants consented"
Grade
Primary record
Document
https://www.sec.gov/litigation/litreleases/lr-24687
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Exhibit 759 · News report

Congressman Chris Collins sentenced in biotech insider trading scheme

Reports a 26-month sentence for Collins after his October 2019 guilty plea to conspiracy to commit securities fraud and false statements. President Trump pardoned him in December 2020 (BioSpace).

Source
STAT
Date
17 January 2020
Grade
Reported
Document
https://www.statnews.com/2020/01/17/congressman-chris-collins-sentenced-biotech-insider-trading-scheme/
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Note
Collins, 18-cr-567, S.D.N.Y.) and the pardon warrant; justice.gov blocked automated retrieval.

Exhibit 760 · News report

Former congressman sentenced to nearly 2 years in prison for insider trading (Stephen Buyer)

Reports that a jury convicted former Rep. Stephen Buyer (R-IN) in March 2023 on four counts of securities fraud over trades in T-Mobile/Sprint and Navigant, and that Judge Berman sentenced him to 22 months. The article describes his source as his consulting work after he left Congress in 2011.

Source
NBC News
Date
September 2023
Grade
Reported
Document
https://www.nbcnews.com/politics/politics-news/former-rep-stephen-buyer-sentenced-22-months-insider-trading-rcna105927
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Buyer, 22-cr-397).

Exhibit 761 · Peer-reviewed study

Abnormal Returns from the Common Stock Investments of the U.S. Senate

We document that a portfolio that mimics the purchases of U.S. Senators beats the market by 85 basis points per month, while a portfolio that mimics the sales of Senators lags the market by 12 basis points per month.

Studies Senators' common stock trades 1993-1998. Finds Senators' purchases beat the market and their sales lagged it.

Source
Ziobrowski, Cheng, Boyd and Ziobrowski, Journal of Financial and Quantitative Analysis 39(4):661-676
Date
December 2004
Quoted from
Abstract (via Crossref)
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S0022109000003161
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Exhibit 762 · Peer-reviewed study

Abnormal Returns From the Common Stock Investments of Members of the U.S. House of Representatives

A portfolio that mimics the purchases of House Members beats the market by 55 basis points per month (approximately 6% annually).

Applies the 2004 method to more than 16,000 House transactions by about 300 members, 1985-2001. House purchases earned positive abnormal returns, smaller than the Senate's.

Source
Ziobrowski, Boyd, Cheng and Ziobrowski, Business and Politics 13(1):1-22
Date
April 2011
Quoted from
Abstract (via Crossref)
Grade
Peer-reviewed
Document
https://doi.org/10.2202/1469-3569.1308
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It found positive returns.

Exhibit 763 · Peer-reviewed study

Capitol Losses: The Mediocre Performance of Congressional Stock Portfolios

Second, we conduct the first analysis of members’ portfolio holdings, showing that between 2004 and 2008 the average member of Congress would have earned higher returns in a passive index fund.

Reinterprets the 1985-2001 studies, analyzes 2004-2008 trades, and analyzes portfolio holdings. Finds no information advantage in either period and lower returns than an index fund for the average member in 2004-2008.

Source
Eggers and Hainmueller, Journal of Politics 75(2):535-551
Date
April 2013
Quoted from
Abstract (LSE Research Online copy)
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S0022381613000194
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Exhibit 764 · Research paper (not peer reviewed)

Relief Rally: Senators as Feckless as the Rest of Us at Stock Picking (NBER Working Paper 26975)

Stocks sold following the January 24th COVID-19 briefing do underperform the market by a statistically significant 9 percent while stocks purchased during this period underperform by 3 percent.

Senators' trades 2012 to March 2020. Purchases slightly underperform industry-and-size matched stocks; no industry-specific skill tied to committees; neither party's senators show skill at buying; sales by Republican senators underperform by 50 bp over three months; sales after the 24 January 2020 briefing underperform by 9 percent.

Source
Belmont, Sacerdote, Sehgal and Van Hoek, NBER
Date
April 2020
Quoted from
Abstract
Grade
Primary record
Document
https://www.nber.org/papers/w26975
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Exhibit 765 · Peer-reviewed study

Do senators and house members beat the stock market? Evidence from the STOCK Act

We find no evidence of superior investment performance whether we look in aggregate or at Senators specifically accused of informed trading.

Trades of senators and House members, January 2012 to December 2020. Finds no superior performance in aggregate or among senators accused of informed trading.

Source
Belmont, Sacerdote, Sehgal and Van Hoek, Journal of Public Economics 207:104602
Date
March 2022
Quoted from
Abstract (RePEc copy)
Grade
Peer-reviewed
Document
https://doi.org/10.1016/j.jpubeco.2022.104602
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Exhibit 766 · Peer-reviewed study

Trading on Private Information: Evidence from Members of Congress

I also find that the positive abnormal returns disappear after the Stop Trading on Congressional Knowledge (STOCK) Act was passed in 2012.

Members' trades 2004-2010. Buy-minus-sell portfolios of powerful Republicans earn the highest abnormal returns; the returns disappear after the 2012 STOCK Act.

Source
Serkan Karadas, The Financial Review 54(1):85-131
Date
January 2019
Quoted from
Abstract (EconPapers copy)
Grade
Peer-reviewed
Document
https://doi.org/10.1111/fire.12180
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Exhibit 767 · Peer-reviewed study

Abnormal returns from joining Congress? Evidence from new members

However, these abnormal returns only accrue to those who serve on powerful committees.

Compares politicians' portfolios before and after election, 2004-2010. Finds weak and inconsistent evidence before election and abnormal returns only for members on powerful committees after two consecutive terms. States that the pre-STOCK Act data imply no wrongdoing.

Source
Hall, Karadas and Schlosky, Journal of Financial Economic Policy 9(4):450-474
Date
November 2017
Quoted from
Abstract (RePEc copy)
Grade
Peer-reviewed
Document
https://doi.org/10.1108/JFEP-12-2016-0095
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Exhibit 768 · Research paper (not peer reviewed)

'Trading' Political Favors: Evidence from the Impact of the STOCK Act (working paper)

After the passage of the Act, politicians exhibit no such informational advantage in trading or outperformance.

Uses the STOCK Act's passage as an experiment on 2010-2013 holdings and trades. Finds abnormal returns before the Act and none after.

Source
Huang and Xuan, SMU and UC Irvine
Date
2018 working paper
Quoted from
Abstract
Grade
Primary record
Document
https://business.gwu.edu/sites/g/files/zaxdzs5326/files/HuangXuan_STOCKAct.pdf
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Note
Working-paper version; locate any published version and update.

Exhibit 769 · Research paper (not peer reviewed)

"Captain Gains" on Capitol Hill (NBER Working Paper 34524)

lawmakers who later ascend to leadership positions perform similarly to matched peers beforehand but outperform them by 47 percentage points annually after ascension.

Transaction-level data on congressional trades. Finds that lawmakers who later become party leaders match peers beforehand and outperform them afterward, which the authors attribute to political influence and corporate access channels.

Source
Wei and Zhou, NBER
Date
November 2025
Quoted from
Abstract
Grade
Primary record
Document
https://www.nber.org/papers/w34524
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Exhibit 770 · Research paper (not peer reviewed)

Capital in the Capitol: Congressional Trades Resemble Uninformed Retail Trading (NBER Working Paper 35041)

We find that, on average, legislators’ portfolios underperform or, at best, match market benchmarks after the STOCK Act.

All members of Congress and immediate families, 2012-2023. Finds portfolios underperform or at best match benchmarks, positions track professional recommendations and timing follows retail sentiment.

Source
Chen and Sacerdote, NBER
Date
April 2026
Quoted from
Abstract
Grade
Primary record
Document
https://www.nber.org/papers/w35041
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Exhibit 771 · GAO report

Political Intelligence: Financial Market Value of Government Information Hinges on Materiality and Timing (GAO-13-389)

There are no laws or ethics rules that specifically govern the sale of information by a political intelligence firm.

STOCK Act s.7 report. Finds no law or ethics rule specifically governs the sale of political intelligence, that its prevalence is not known and is hard to quantify, and that materiality and timing are hard to determine. Makes no recommendations.

Source
U.S. Government Accountability Office
Date
4 April 2013
Quoted from
GAO-13-389 (April 2013), p. 5, section 'No Laws or Ethics Rules Specifically Govern Political Intelligence'
Grade
Primary record
Document
https://www.gao.gov/assets/gao-13-389.pdf
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Note
Quote after reading.

Exhibit 772 · News report

Senate quietly curtails STOCK Act reporting for staff

Reports the Senate's passage of S. 716 without committee action. Other reports (Roll Call 12 April, Nextgov, CJR) cite a National Academy of Public Administration report on security risk and the Office of Government Ethics support for delay as the rationale; Public Citizen and outside security experts disputed it.

Source
CQ Roll Call
Date
11 April 2013
Grade
Reported
Document
https://rollcall.com/2013/04/11/senate-quietly-curtails-stock-act-reporting-for-staff/
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Exhibit 773 · News report

Pelosi ripped by fellow Democrat for delaying stock-trade bill

Reports that House Democratic leaders, who had asked the House Administration Committee to draft a bill covering members, justices and spouses, did not bring it to a vote before the 2022 midterms; Rep. Spanberger criticized the delay. Insider later wrote that the ban 'ultimately died' in that Congress.

Source
Bloomberg via BNN
Date
30 September 2022
Grade
Reported
Document
https://www.bnnbloomberg.ca/pelosi-ripped-by-fellow-democrat-for-delaying-stock-trade-bill-1.1826373
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Exhibit 774 · News report

Lawmaker stock trading ban legislation advances in Senate

Reports that Senate Homeland Security and Governmental Affairs voted 8-4 on 24 July 2024 to report a revised S. 1171 (Merkley's ETHICS Act with Hawley, Peters and Ossoff-led bipartisan changes) barring members, spouses, dependents, the President and Vice President from owning individual stocks, with divestiture from 2027 and the $200 penalty raised to $500.

Source
CQ Roll Call
Date
24 July 2024
Grade
Reported
Document
https://rollcall.com/2024/07/24/lawmaker-stock-trading-ban-legislation-advances-in-senate/
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Exhibit 775 · Bill text

S. 1498, HONEST Act, reported in the Senate (Calendar No. 294)

This Act may be cited as the “Halting Ownership and Non-Ethical Stock Transactions (HONEST) Act”.

Committee-reported text of the Hawley-Peters bill. Per press reports, the committee advanced it on 30 July 2025; it bars members, the President and Vice President and spouses and dependents from holding or buying individual stocks.

Source
U.S. Senate, 119th Congress
Date
Reported 10 December 2025
Quoted from
S. 1498 as reported in the Senate (Calendar No. 294), committee amendment, Sec. 1
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/BILLS-119s1498rs/xhtml/BILLS-119s1498rs.html
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Note
Header read only; read the bill before use.

Exhibit 776 · Roll call vote

Roll call 280, H.R. 7008, Stop Insider Trading Act, On Passage

Passed 232-198. Republicans 218 yea, 0 nay. Democrats 13 yea, 198 nay, 1 not voting. Independent 1 yea.

Source
Clerk of the House of Representatives
Date
22 July 2026
Grade
Primary record
Document
https://clerk.house.gov/evs/2026/roll280.xml
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Exhibit 778 · News report

Congressional stock-trading bill passes the House

Reports the House Administration chair Bryan Steil's bill bars members, spouses and dependent children from buying new stocks, allows existing holdings with 7 to 14 days' public notice before sale, sets penalties of $2,000 or 10 percent of the transaction, exempts widely held funds, and carries an added photo-ID provision that Rep. Morelle called a poison pill.

Source
CQ Roll Call
Date
22 July 2026
Grade
Reported
Document
https://rollcall.com/2026/07/22/congressional-stock-trading-bill-passes-the-house/
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Exhibit 779 · Statute

Federal Reserve Act, Section 4 (Reserve Bank organization and directors), as published by the Board of Governors

Class A shall consist of three members, without discrimination on the basis of race, creed, color, sex, or national origin, who shall be chosen by and be representative of the stockholding banks.

Each Reserve Bank board has nine directors in three classes. Class A (three) are chosen by and represent the stockholding banks; Class B (three) are elected by the member banks to represent the public and may not be officers, directors or employees of any bank; Class C (three) are designated by the Board of Governors and may not be officers, directors, employees or stockholders of any bank. Sec. 16 has the member banks nominate and elect Class A and B directors in three groups of banks of similar capitalization.

Source
Board of Governors of the Federal Reserve System
Date
1913, as amended (page opened 10 November 2026)
Quoted from
Sec. 4, para. 10 (Class A directors), 12 U.S.C. 302, as numbered on federalreserve.gov
Grade
Primary record
Document
https://www.federalreserve.gov/aboutthefed/section4.htm
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Exhibit 780 · Statute

Federal Reserve Act, Section 5 (stock in Federal reserve banks), as published by the Board of Governors

Shares of the capital stock of Federal reserve banks owned by member banks shall not be transferred or hypothecated.

Shares are $100 each. A member bank subscribes an amount equal to 6 per centum of its paid-up capital stock and surplus, half paid in and half subject to call by the Board. Shares may not be transferred or hypothecated.

Source
Board of Governors of the Federal Reserve System
Date
1913, as amended (page opened 10 November 2026)
Quoted from
Sec. 5, para. 1 (amount of shares), 12 U.S.C. 282
Grade
Primary record
Document
https://www.federalreserve.gov/aboutthefed/section5.htm
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Exhibit 781 · Statute

Federal Reserve Act, Section 7 (division of earnings), as published by the Board of Governors

After all necessary expenses of a Federal reserve bank have been paid or provided for, the stockholders of the bank shall be entitled to receive an annual dividend on paid-in capital stock

Sec. 7(a)(1) gives stockholders a cumulative annual dividend on paid-in capital stock: the smaller of the 10-year Treasury high yield and 6 percent for stockholders with more than $10 billion in total consolidated assets (inflation-adjusted), and 6 percent for all others. Net earnings remaining after dividend claims are met go to the surplus fund and then to the Treasury.

Source
Board of Governors of the Federal Reserve System
Date
1913, as amended by Pub. L. 114-94 (page opened 10 November 2026)
Quoted from
Sec. 7(a)(1)(A), 12 U.S.C. 289(a)(1)(A)
Grade
Primary record
Document
https://www.federalreserve.gov/aboutthefed/section7.htm
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Exhibit 782 · Statute

Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law 111-203, sections 1103, 1107 and 1109

The president shall be the chief executive officer of the bank and shall be appointed by the Class B and Class C directors of the bank, with the approval of the Board of Governors of the Federal Reserve System, for a term of 5 years

Sec. 1107 amends Federal Reserve Act sec. 4 so a Reserve Bank president is appointed by the Class B and Class C directors only, with Board approval. Sec. 1103 requires disclosure of borrower names, amounts, rates and collateral for emergency credit facilities and discount window lending, one year after a facility ends. Sec. 1109(a) orders a one-time GAO audit of the 2007-2010 emergency facilities, including whether they favored particular participants and whether there were conflicts of interest; sec. 1109(b) orders the study of Reserve Bank governance.

Source
U.S. Congress
Date
21 July 2010
Quoted from
Sec. 1107, 124 Stat. 2126
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-111publ203/html/PLAW-111publ203.htm
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Note
Further quotation: “there are authorized to be appropriated to carry out the functions, powers, and duties of the Commission--” (Sec. 991(c), new Securities Exchange Act sec. 35, 124 Stat. 1954; the five paragraphs that follow list $1,300,000,000 (FY 2011), $1,500,000,000 (FY 2012), $1,750,000,000 (FY 2013), $2,000,000,000 (FY 2014) and $2,250,000,000 (FY 2015)). Authorization of appropriations, not an appropriation. Approved 21 July 2010. Sec. 915 (124 Stat. 1830) separately establishes within the Commission the Office of the Investor Advocate, and a section 932 subsection establishes an Office of Credit Ratings; the latter heading was located but its text was not read in full.

Exhibit 783 · Statute

Fixing America's Surface Transportation Act, Public Law 114-94, section 32203 (dividends of Federal reserve banks)

the rate equal to the high yield of the 10-year Treasury note auctioned at the last auction held prior to the payment of such dividend

Sec. 32203 rewrites Federal Reserve Act sec. 7(a)(1)(A), effective 1 January 2016. A stockholder with more than $10,000,000,000 in total consolidated assets receives the smaller of the 10-year Treasury high yield and 6 percent; a stockholder at or below that threshold receives 6 percent. The Board adjusts the threshold annually for the GDP price index. The Federal Reserve's 2025 statements report the threshold as $12.8 billion.

Source
U.S. Congress
Date
4 December 2015
Quoted from
Sec. 32203(a), 129 Stat. 1739-1740
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-114publ94/html/PLAW-114publ94.htm
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Exhibit 784 · GAO report

Federal Reserve System: Opportunities Exist to Strengthen Policies and Processes for Managing Emergency Assistance (GAO-11-696)

Loans outstanding for the emergency programs peaked at more than $1 trillion in late 2008.

GAO's one-time audit under Dodd-Frank sec. 1109 of Fed emergency assistance, 1 December 2007 to 21 July 2010. Highlights: loans outstanding peaked above $1 trillion in late 2008; the Reserve Banks awarded 103 vendor contracts worth $659.4 million, and 8 of the 10 highest-value contracts were awarded noncompetitively. Table 8 (p. 131) totals $16,115 billion of loans across the broad-based programs, "not term-adjusted." p. 80: JPMorgan Chase was both a borrower and a vendor while its CEO served as a Class A New York Fed director; Lehman Brothers' CEO also sat on the board. p. 81: no evidence of systemic bias toward favoring institutions. Tables 10, 11, 16, 17, 19: BlackRock fees as vendor. Seven recommendations; the Board agreed they would benefit its response to future crises.

Source
U.S. Government Accountability Office
Date
July 2011
Quoted from
Highlights, "What GAO Found," first paragraph (unnumbered front matter)
Grade
Primary record
Document
https://www.gao.gov/assets/gao-11-696.pdf
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Exhibit 785 · GAO report

GAO-11-696, p. 130: method note for Table 8 (total loans not adjusted for term)

Table 8 aggregates total dollar transaction amounts by adding the total dollar amount of all loans but does not adjust these amounts to reflect differences across programs in the term over which loans were outstanding.

Explains why Table 8's $16,115 billion total counts every renewal of overnight Primary Dealer Credit Facility loans as new borrowing. GAO's example: a $10 billion overnight loan renewed daily for 30 business days adds $300 billion to the aggregate although the institution borrowed $10 billion over 30 days.

Source
U.S. Government Accountability Office
Date
July 2011
Quoted from
p. 130 (printed page)
Grade
Primary record
Document
https://www.gao.gov/assets/gao-11-696.pdf
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Exhibit 786 · GAO report

Federal Reserve Bank Governance: Opportunities Exist to Broaden Director Recruitment Efforts and Increase Transparency (GAO-12-18)

We identified at least 18 former and current Class A, B, and C directors from 9 Reserve Banks who were affiliated with institutions that used at least one emergency program.

GAO's Dodd-Frank sec. 1109(b) study of Reserve Bank boards. Directors have a limited role in supervision. p. 32: "in practice, most Class A directors are officers or directors of member banks in the district," and the requirement "creates an appearance of a conflict of interest" because the System supervises state-chartered member banks and holding companies. pp. 38-40: at least 18 current and former directors from 9 Reserve Banks were affiliated with institutions that used an emergency program, including 11 Class A directors who served 2008-2010. Four recommendations; the Board agreed.

Source
U.S. Government Accountability Office
Date
October 2011
Quoted from
p. 39 (printed page; the continuation page prints its footer as "Page 31")
Grade
Primary record
Document
https://www.gao.gov/assets/gao-12-18.pdf
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Exhibit 787 · Press release

New York Fed: Stephen Friedman Resigns as Chairman of the New York Fed's Board of Directors

it is my view that these purchases did not violate any Federal Reserve statute, rule or policy.

Announces the chairman's immediate resignation; the deputy chair assumes the chair's duties. General counsel Thomas C. Baxter, Jr. states his view that Friedman's December 2008 and January 2009 purchases of Goldman shares did not violate Federal Reserve statute, rule or policy. Vice Chairman Donald Kohn thanks him.

Source
Federal Reserve Bank of New York
Date
7 May 2009
Quoted from
Statement of Thomas C. Baxter, Jr., third paragraph
Grade
Primary record
Document
https://www.newyorkfed.org/newsevents/news/aboutthefed/2009/oa090507
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Exhibit 788 · Correspondence

Letter of Stephen Friedman to William C. Dudley, resigning as Class C Director and Chairman, Federal Reserve Bank of New York

although I have been in compliance with the rules, my public service motivated continuation on the Reserve Bank Board is being mischaracterized as improper.

Friedman resigns as a Class C director and chairman. He writes that after Goldman Sachs became a bank holding company he remained on the board under the Board of Governors' waiver authority, to provide continuity. Federal Reserve Act sec. 15 provides that no Class C director may be an officer, director, employee or stockholder of any bank.

Source
Stephen Friedman
Date
7 May 2009
Quoted from
Letter, second paragraph
Grade
Primary record
Document
https://www.newyorkfed.org/medialibrary/media/newsevents/news/aboutthefed/2009/oa090507.pdf
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Exhibit 789 · Press release

New York Fed: Dimon, Bollinger to Join New York Fed Board of Directors, Nooyi Reelected to Second Term

has been elected a class A director of the Federal Reserve Bank of New York for a three-year term beginning January 2007

Jamie Dimon, president and chief executive officer of JPMorgan Chase, is elected a Class A director for the term beginning January 2007.

Source
Federal Reserve Bank of New York
Date
20 November 2006
Quoted from
First paragraph
Grade
Primary record
Document
https://www.newyorkfed.org/newsevents/news/aboutthefed/2006/oa061120
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Exhibit 790 · Press release

New York Fed: Jamie Dimon and Jeffrey B. Kindler Reelected New York Fed Directors

Mr. Dimon and Mr. Kindler will be serving new three-year terms ending December 2012.

Dimon, chairman, president and CEO of JPMorgan Chase, is reelected a Class A director; the new term ends December 2012. The release states that Class A directors are drawn from the banking community and that the six Class A and B directors are elected by member banks in the Second District.

Source
Federal Reserve Bank of New York
Date
5 February 2010
Quoted from
First paragraph
Grade
Primary record
Document
https://www.newyorkfed.org/newsevents/news/aboutthefed/2010/oa100205
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Exhibit 791 · Agency web page

New York Fed: Primary Market Corporate Credit Facility (vendors section)

On March 24, 2020, the New York Fed retained BlackRock Financial Markets Advisory as a third-party vendor to serve as the investment manager for this facility.

States the retention and the reasons for selecting BlackRock, and that on 6 January 2021 the New York Fed notified BlackRock it was ending the relationship effective 5 February 2021. State Street was retained 15 April 2020 as custodian and administrator after a request for proposals. Treasury made an equity investment in the SPV (Corporate Credit Facilities LLC); the SPV returned that equity in January and September 2021 and was terminated 17 December 2021.

Source
Federal Reserve Bank of New York
Date
Page opened 10 November 2026 (facility announced 23 March 2020)
Quoted from
Vendors section
Grade
Primary record
Document
https://www.newyorkfed.org/markets/primary-market-corporate-credit-facility
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Exhibit 792 · Agency web page

New York Fed: Secondary Market Corporate Credit Facility (vendors and announcements)

On February 4, 2021, the New York Fed notified BlackRock that it would be replacing BlackRock as the cash investment manager and had identified a new vendor to perform that role going forward.

Describes the facility's purchases of corporate bonds and U.S.-listed ETFs. Lists the 5 October 2020 start of a competitive procurement for vendor roles, the 4 February 2021 notice replacing BlackRock as cash investment manager, ETF sales from 7 June 2021, completion of the portfolio sales by 31 August 2021, and the 90/10 Treasury/New York Fed split of the SPV's cash distributions in 2021.

Source
Federal Reserve Bank of New York
Date
Page opened 10 November 2026 (facility announced 23 March 2020)
Quoted from
Vendors section
Grade
Primary record
Document
https://www.newyorkfed.org/markets/secondary-market-corporate-credit-facility
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Exhibit 793 · Contract

Secondary Market Corporate Credit Facility Investment Management Agreement between Corporate Credit Facilities LLC and BlackRock Financial Markets Advisory (with exhibits)

The Manager shall treat BlackRock-sponsored ETFs on the same neutral footing as ETFs sponsored by other entities.

Published by the New York Fed (66 pages, stamped "Cleared for Release"). Sec. 1.2 (p. 2): the Manager "will act as a fiduciary to the Company." Exh. A-2 (p. 42): BlackRock-sponsored ETFs are treated on the same neutral footing as others, and if holdings exceed BlackRock's market share of the corporate bond ETF market the Manager must notify and consult FRBNY, which may direct adjustments. Exh. D (p. 54): the Manager may not charge fees on the Company's ETF holdings, including BlackRock ETFs, and reduces its fee by BlackRock revenues from BlackRock ETFs and money market funds held. Fixed fee $2,000,000 for Q2 2020, $1,000,000 for Q3 2020, $750,000 a quarter after; asset-based fee of 2.5 basis points on the first $10 billion, declining. Exh. G: information barrier and conflicts mitigation procedures. The Agreement is dated 11 May 2020; the retention was announced 24 March 2020.

Source
Federal Reserve Bank of New York
Date
11 May 2020
Quoted from
Exh. A-2 (Operating Guidelines), p. 42 of 66
Grade
Primary record
Document
https://www.newyorkfed.org/medialibrary/media/markets/SMCCF_Investment_Management_Agreement.pdf
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Exhibit 794 · Dataset

Secondary Market Corporate Credit Facility transaction-specific disclosures (Section 11(s)), workbook released 30 December 2021

Fed workbook with three sheets: bond trades, ETF trades and counterparties. Footnote: "Includes all ETFs purchased through December 31, 2020." Derived by the researcher from the ETF sheet (926 trades, 12 May to 23 July 2020): purchase amounts total $8,434,795,268; by ETF sponsor BlackRock $4.125 billion (48.9%), Vanguard $2.884 billion (34.2%), State Street $1.317 billion (15.6%), others under 1%. Largest funds: LQD $2.349 billion, VCSH $1.494 billion, VCIT $1.390 billion. Bond sheet: 2,670 trades, $5.834 billion. Local copy SHA-256 42ddce76d524cc76a3e41fd81b0bf71ae4a35c2fea472d684bb752a710579146. The sheet records purchases only.

Source
Board of Governors of the Federal Reserve System
Date
30 December 2021
Grade
Primary record
Document
https://www.federalreserve.gov/publications/files/section-11s-smccf-transaction-specific-disclosures-12-30-21.xlsx
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Note
Downloaded 10 November 2026; sums re-derivable by summing column J of sheet "Trade-level ETF" grouped by column A.

Exhibit 795 · Statute

Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Public Law 116-136, sections 4003, 4019, 4020 and 4026

no covered entity may be eligible for any transaction described in section 4003

Sec. 4003(b)(4) makes up to $454,000,000,000 of Treasury funds available for loans and investments in Fed section 13(3) facilities. Sec. 4019 (Conflicts of Interest) bars any "covered entity" (an entity in which the President, Vice President, an executive department head, a Member of Congress or a spouse, child, son-in-law or daughter-in-law holds at least 20 percent) from sec. 4003 transactions and requires certification. Sec. 4020 creates the Congressional Oversight Commission. Sec. 4026(b)(2) requires the Board to report to the Senate Banking and House Financial Services committees within 7 days of authorizing a facility and every 30 days, and to publish the reports. Sec. 4019 does not address Fed vendors.

Source
U.S. Congress
Date
27 March 2020
Quoted from
Sec. 4019(b), 134 Stat. 486
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-116publ136/html/PLAW-116publ136.htm
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Exhibit 796 · Congressional letter

Letter from Senators Cramer, Cruz and 15 Republican colleagues to Secretary Mnuchin and Chairman Powell on CARES Act implementation

BlackRock must act without regard to this or other investment policies BlackRock has adopted for its own funds.

Quotes the New York Fed's 27 March 2020 initial terms: BlackRock will act as a fiduciary to the facility, abide by conflict of interest policies and keep SMCCF staff segregated from other BlackRock engagements. The senators ask the Fed to say that BlackRock must disregard investment policies it adopted for its own funds (BlackRock had announced screens on certain companies). The worry is that those screens would disadvantage energy and transportation employers.

Source
U.S. Senate (Cramer, Cruz and 15 colleagues)
Date
7 April 2020
Quoted from
p. 2
Grade
Primary record
Document
https://www.cruz.senate.gov/files/documents/Letters/2020.04.07%20-%20Letter%20to%20Powell%20Mnuchin%20re%20CARES%20Act%20Implementation%20.pdf
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Exhibit 797 · Congressional letter

Letter from Reps. Garcia, Tlaib, Pressley and six Democratic co-signers to Secretary Mnuchin and Chairman Powell on BlackRock's contracts with the Fed

Documents pertaining to how these programs will affect BlackRock’s own ETF’s, even if BlackRock does not retain the fees from their purchase.

Asks Treasury and the Fed to appoint an inspector general, submit the full contracts for the PMCCF and SMCCF, disclose conflict policies including the list of BlackRock staff above the internal wall, and document how the programs affect BlackRock's own ETFs. Raises BlackRock's size, lobbying and revolving-door figures and the fossil fuel exposure of the facilities. The revolving-door count (more than 100 individuals) and the lobbying figure (more than $2 million a year) are the letter's own.

Source
U.S. House of Representatives (Garcia, Tlaib, Pressley and co-signers)
Date
22 April 2020
Quoted from
p. 2, request 2, fourth bullet
Grade
Primary record
Document
https://pressley.house.gov/sites/pressley.house.gov/files/Congressional%20Letter%20to%20Fed%20Treas%204_22.pdf
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Exhibit 798 · Congressional report

Select Subcommittee on the Coronavirus Crisis, "Prioritizing Wall Street: The Fed's Corporate Bond Purchases During the Coronavirus Pandemic," staff analysis

Select Subcommittee on the Coronavirus Crisis staff analyzed the Fed’s most recent disclosures about its corporate bond purchases and compared the transactions to public data on layoffs, dividend payouts, and legal violations.

Majority-staff analysis (the subcommittee was chaired by Rep. Clyburn). Reports that bonds the Fed bought through the SMCCF were issued by companies that laid off more than one million workers since March 2020, that 383 issuers paid dividends, and that fossil fuel issuers were over-weighted. Mentions BlackRock once, on its climate statement. Does not analyze BlackRock's ETF holdings or fees. A one-party staff product.

Source
House Select Subcommittee on the Coronavirus Crisis (Democratic majority staff)
Date
23 September 2020
Quoted from
p. 1, second paragraph
Grade
Primary record
Document
https://coronavirus-democrats-oversight.house.gov/sites/evo-subsites/coronavirus-democrats-oversight.house.gov/files/Staff%20Report%20(9-23-2020)_FINAL.pdf
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Exhibit 799 · Congressional hearing

Hybrid hearing with the Federal Reserve Chair Jerome H. Powell, Select Subcommittee on the Coronavirus Crisis, Serial No. 116-119

we didn’t want to be deciding which company to buy from and which not.

Chairman Clyburn puts the staff analysis to Chair Powell. Powell answers that the SMCCF bought small amounts of bonds across about 800 issuers, in the secondary market, without making loans to the companies, to avoid choosing among companies. He calls the facility a success. The transcript contains no question on BlackRock, ETFs or conflicts.

Source
U.S. House of Representatives, Select Subcommittee on the Coronavirus Crisis
Date
23 September 2020
Quoted from
Hearing transcript, Chairman Clyburn exchange, pp. 14-15
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/CHRG-116hhrg41958/pdf/CHRG-116hhrg41958.pdf
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Exhibit 800 · Press release

Senator Sanders, "The Fed Audit" (press release)

the Federal Reserve provided more than $16 trillion in total financial assistance to some of the largest financial institutions and corporations in the United States and throughout the world

Describes the GAO audit that the Sanders amendment to Dodd-Frank directed as uncovering "$16 trillion in secret loans." The $16 trillion is the sum of Table 8 of GAO-11-696 (loans not adjusted for term; see the GAO method note). The release is a senator's characterization of the GAO report, not GAO's own wording.

Source
Office of Senator Bernie Sanders
Date
21 July 2011
Quoted from
Quoted statement of Senator Sanders, second paragraph
Grade
Primary record
Document
https://www.sanders.senate.gov/press-releases/the-fed-audit/
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Exhibit 801 · Agency web page

Federal Reserve Board FAQ: Is the Fed's emergency lending audited by the Congress? Is information about the Fed's emergency lending provided to the public?

The audit found no conflicts of interest or material weaknesses in internal controls in the emergency facilities.

The Fed's own summary of the GAO audits. States the 21 July 2011 report found no conflicts of interest or material control weaknesses, notes the 19 October 2011 governance report, and lists the 1 December 2010 disclosure of borrower names, amounts, dates, rates and collateral.

Source
Board of Governors of the Federal Reserve System
Date
Page opened 10 November 2026
Quoted from
Bullet 1
Grade
Primary record
Document
https://www.federalreserve.gov/faqs/federal-reserve-lending-audited-by-congress.htm
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Note
Compare with GAO-11-696 and GAO-12-18, which describe potential conflicts and an appearance of conflict.

Exhibit 802 · Agency web page

Federal Reserve Board FAQ: Who owns the Federal Reserve?

The Federal Reserve System is not "owned" by anyone.

The Board's statement of its position: the System is not owned by anyone; the Board is a federal agency accountable to Congress; member banks hold Reserve Bank stock as a condition of membership; the Reserve Banks are not operated for profit and must transfer net earnings to the Treasury.

Source
Board of Governors of the Federal Reserve System
Date
Page opened 10 November 2026
Quoted from
First sentence of answer
Grade
Primary record
Document
https://www.federalreserve.gov/faqs/about_14986.htm
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Exhibit 803 · Press release

Federal Reserve Board announces a broad set of new rules on investment and trading by Federal Reserve policymakers and senior staff

a broad set of new rules that will prohibit the purchase of individual securities, restrict active trading, and increase the timeliness of reporting and public disclosure by Federal Reserve policymakers and senior staff

New rules bar purchases of individual securities, require 45 days' advance notice, prior approval and a one-year holding period, bar trading during periods of heightened market stress, and require Reserve Bank presidents to disclose transactions within 30 days. The FOMC adopted its policy in February 2022; the rules took effect 1 May 2022 and preclearance began 1 July 2022 (per OIG reports).

Source
Board of Governors of the Federal Reserve System
Date
21 October 2021
Quoted from
First paragraph
Grade
Primary record
Document
https://www.federalreserve.gov/newsevents/pressreleases/other20211021b.htm
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Exhibit 804 · Inspector general report

Report of Investigation on the Closing of 22-0028-I Board Trading Activity (Powell, Clarida)

we did not find evidence to substantiate the allegations that Chair Powell or Mr. Clarida violated laws, rules, regulations, or policies related to trading activities in effect at the time and as investigated by our office.

On 4 October 2021 the Board asked the OIG to review the 2020 trading of Kaplan, Rosengren and Clarida; the OIG added Chair Powell's December 2019 transactions. It found no violation by Powell or Clarida of the rules in effect, and insufficient evidence for a law-enforcement referral, while stating the rules did not sufficiently support public confidence.

Source
Federal Reserve Board Office of Inspector General
Date
18 January 2024 (closing memorandum issued 11 July 2022)
Quoted from
Case 22-0028-I, p. 2
Grade
Primary record
Document
https://oig.federalreserve.gov/releases/investigation-closing-board-trading.pdf
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Exhibit 805 · Inspector general report

Report of Investigation on the Closing of 22-0030-I Reserve Bank Trading Activity (Kaplan, Rosengren)

we found that he did not report multiple trades on his 2020 Form A.

Kaplan: no violation found, but his 2020 Form A omitted trade dates and option sales, which the OIG said created an "appearance of acting on confidential FOMC information." Rosengren: did not report multiple trades on his 2020 Form A, brokerage statements and Form A differed, and his 2020 REIT trades during the period of Fed agency MBS purchases created an appearance of a conflict. The OIG found insufficient evidence for a law-enforcement referral.

Source
Federal Reserve Board Office of Inspector General
Date
18 January 2024 (closing memorandum issued 11 July 2022)
Quoted from
Case 22-0030-I, p. 2 (Rosengren)
Grade
Primary record
Document
https://oig.federalreserve.gov/releases/investigation-closing-reserve-bank-trading.pdf
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Exhibit 806 · Inspector general report

Report of Investigation on the Closing of 23-0020-I Federal Reserve Bank of Atlanta President's Trading Activity

We found that Dr. Bostic violated

Requested by Chair Powell on 14 October 2022 for 2017-2021. The OIG found President Bostic violated the FOMC blackout rule (trades executed in managed accounts during blackout periods), the Reserve Bank disclosure statement policies (2018 to 2022), the prohibited holdings policy (Treasury holdings above $50,000, June 2021 to June 2022) and the preclearance rule (two instances). It determined there were no violations of insider trading or federal conflict-of-interest law.

Source
Federal Reserve Board Office of Inspector General
Date
4 September 2024
Quoted from
Case 23-0020-I, p. 2
Grade
Primary record
Document
https://oig.federalreserve.gov/releases/investigation-closing-frb-atlanta-trading.pdf
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Exhibit 807 · Inspector general evaluation

The Board Can Further Enhance the Design and Effectiveness of the FOMC's Investment and Trading Rules (2023-SR-B-006)

Hundreds of individuals throughout the Federal Reserve System who have access to Class I FOMC information are not subject to any of the additional controls implemented in the policy.

Evaluates the new investment and trading policy. Six recommendations; the Board concurred. Finds the policy does not reach hundreds of System staff with access to Class I FOMC information and that ethics reviews rely on trust rather than verification of the disclosures.

Source
Federal Reserve Board Office of Inspector General
Date
26 April 2023
Quoted from
Executive Summary, p. 2 of 32
Grade
Primary record
Document
https://oig.federalreserve.gov/reports/board-FOMC-investment-trading-rules-apr2023.pdf
Accessed
2026-11-09
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Exhibit 808 · Press release

Federal Reserve Board announces preliminary 2022 financial information for the Reserve Banks

in September 2022, most Reserve Banks suspended weekly remittances to the Treasury and started accumulating a deferred asset, which totaled $18.8 billion by the end of the year.

2022 net income $58.4 billion; $76.0 billion transferred to Treasury in 2022; in September 2022 most Reserve Banks suspended weekly remittances and began a deferred asset, $18.8 billion at year-end. Net income $108 million from the COVID-19 facilities.

Source
Board of Governors of the Federal Reserve System
Date
13 January 2023
Quoted from
Second paragraph
Grade
Primary record
Document
https://www.federalreserve.gov/newsevents/pressreleases/other20230113a.htm
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Exhibit 809 · Press release

Federal Reserve Board releases preliminary 2023 financial information for the Reserve Banks

In 2023, the Reserve Banks increased the deferred asset by $116.4 billion resulting in a cumulative deferred asset at year-end of $133.0 billion.

2023 expenses exceeded estimated earnings by $114.3 billion; interest expense of $281.1 billion, of which $116.3 billion was interest on reserve balances; statutory dividends $1.5 billion; deferred asset up $116.4 billion to $133.0 billion at year-end.

Source
Board of Governors of the Federal Reserve System
Date
12 January 2024
Quoted from
Bullet list, final paragraph
Grade
Primary record
Document
https://www.federalreserve.gov/newsevents/pressreleases/other20240112a.htm
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Exhibit 810 · Audit report

Federal Reserve Banks Combined Financial Statements as of and for the years ended December 31, 2025 and 2024

The deferred asset is the amount of net excess earnings the Reserve Banks will need to realize in the future before remittances to the Treasury resume

Deferred asset $243,481 million at 31 December 2025 and $215,955 million at 31 December 2024. Net loss before remittances $18,761 million (2025) and $77,621 million (2024). Dividends on capital stock $1,688 million (2025) and $1,623 million (2024). Note 3o: member banks subscribe 6 percent of capital and surplus, half paid in; shares may not be transferred or hypothecated; a member bank "is liable for Reserve Bank liabilities up to twice the par value of stock subscribed by it"; dividend threshold $12.8 billion (2025) and $12.5 billion (2024); dividend paid semiannually and cumulative.

Source
Board of Governors of the Federal Reserve System
Date
Issued March 2026
Quoted from
Note 3 (earnings remittances), paragraph 2
Grade
Primary record
Document
https://www.federalreserve.gov/aboutthefed/files/combinedfinstmt2025.pdf
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Exhibit 812 · Agency notice

Federal Reserve Bank of San Francisco, Circular 3: Results of Director Election

was re-elected by banks in Group One as a Class A director for a second three-year term ending December 31, 2024.

Reports that Greg Becker, president and CEO of SVB Financial Group and CEO of Silicon Valley Bank, was re-elected by banks in Group One as a Class A director for a second three-year term ending 31 December 2024.

Source
Federal Reserve Bank of San Francisco
Date
10 September 2021
Quoted from
Second bullet paragraph
Grade
Primary record
Document
https://www.frbsf.org/wp-content/uploads/09102021-Election-Circular-3-Results-of-Elections_final.pdf
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Exhibit 813 · Agency report

Review of the Federal Reserve's Supervision and Regulation of Silicon Valley Bank (Vice Chair for Supervision Barr)

Because Greg Becker, CEO of SVB and president and CEO of SVBFG, also served as a director on the board of the FRBSF starting on January 1, 2019, the three Regulation K prior notices (and the public welfare investments) were not eligible to be acted upon by FRBSF and instead were acted on by the Secretary of the Board (table 10).

Self-assessment overseen by Vice Chair for Supervision Michael Barr by staff not involved in the supervision of SVB. Key takeaways: SVB's board and management failed to manage risks; supervisors did not fully appreciate the vulnerabilities, did not act quickly enough, and the tailoring approach after the 2018 Economic Growth, Regulatory Relief, and Consumer Protection Act and a shift in supervisory stance reduced standards and promoted a less assertive approach. PDF p. 90 notes that SVB's CEO sat on the San Francisco Fed board.

Source
Board of Governors of the Federal Reserve System
Date
28 April 2023
Quoted from
PDF p. 90, text above fn. 118
Grade
Primary record
Document
https://www.federalreserve.gov/publications/files/svb-review-20230428.pdf
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Exhibit 814 · Inspector general evaluation

Material Loss Review of Silicon Valley Bank (2023-SR-B-013)

We believe that the CEO’s service on the FRB San Francisco board of directors created an appearance of a conflict of interest for the System.

Matter for Management Consideration (p. 46): the OIG heard of no conflicts or influence from the CEO's service on the San Francisco Fed board, learned that senior officials considered removing him after the ratings downgrade discussions and decided to keep him on the board to avoid signaling the bank's condition, and learned there is no System policy requiring removal of a bank official from a Reserve Bank board when the bank is rated less than satisfactory. It suggests the Board consider standards for Class A service and removal and encourage retired bank executives as Class A directors.

Source
Federal Reserve Board Office of Inspector General
Date
25 September 2023
Quoted from
Matter for Management Consideration, p. 46 of 53
Grade
Primary record
Document
https://oig.federalreserve.gov/reports/board-material-loss-review-silicon-valley-bank-sep2023.pdf
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Exhibit 815 · Archive institutional history

The Meeting at Jekyll Island (Federal Reserve History essay by Gary Richardson and Jessie Romero)

In November 1910, six men—Nelson Aldrich, A. Piatt Andrew, Henry Davison, Arthur Shelton, Frank Vanderlip and Paul Warburg —met at the Jekyll Island Club, off the coast of Georgia, to write a plan to reform the nation's banking system.

The Fed's own history names six attendees in November 1910: Nelson Aldrich, A. Piatt Andrew, Henry Davison, Arthur Shelton, Frank Vanderlip and Paul Warburg. It says the meeting was kept secret until the 1930s, that it is unlikely Benjamin Strong attended although Vanderlip recalls him there, and that the technical details of the 1913 Federal Reserve Act closely resembled the Aldrich plan, with the major differences in political and decision-making structures. Congress passed the Act and the President signed it in December 1913.

Source
Federal Reserve Bank of Richmond for the Federal Reserve Board (Federal Reserve History)
Date
Essay (events 20-30 November 1910)
Quoted from
Opening paragraph
Grade
Reported
Document
https://www.federalreservehistory.org/essays/jekyll-island-conference
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Exhibit 816 · Statute

Foreign Agents Registration Act of 1938, 22 U.S.C. 611 (definitions)

any activity that the person engaging in believes will, or that the person intends to, in any way influence any agency or official of the Government of the United States or any section of the public within the United States with reference to formulating, adopting, or changing the domestic or foreign policies of the United States

Sec. 611(c)(1) defines an agent of a foreign principal as a person who acts at the order, request or under the direction or control of a foreign principal and who engages in political activities, acts as public relations counsel or political consultant, solicits or disburses money, or represents the principal's interests before a U.S. agency or official. Sec. 611(o) defines political activities by intent to influence U.S. officials or the public. FARA is a registration and disclosure statute, not a ban on the activity.

Source
U.S. Congress
Date
8 June 1938 (as amended)
Quoted from
22 U.S.C. § 611(o)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/22/611
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Exhibit 817 · Statute

Foreign Agents Registration Act, 22 U.S.C. 613(h) (Lobbying Disclosure Act exemption)

Any agent of a person described in section 611(b)(2) of this title or an entity described in section 611(b)(3) of this title if the agent has engaged in lobbying activities and has registered under the Lobbying Disclosure Act of 1995

Sec. 613(h) exempts from FARA registration an agent of a person or entity described in sec. 611(b)(2) or (3) (foreign persons and entities that are not a government or political party) who has engaged in lobbying activities and registered under the Lobbying Disclosure Act of 1995 for that representation. Added by the Lobbying Disclosure Act of 1995, effective 1 January 1996.

Source
U.S. Congress
Date
19 December 1995 (Pub. L. 104-65, sec. 9(3); amended Pub. L. 105-166, 1998)
Quoted from
22 U.S.C. § 613(h)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/22/613
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Exhibit 818 · Agency web page

FARA Enforcement (NSD FARA Unit web page)

be punished by a fine of not more than $250,000 or by imprisonment for not more than five (5) years.

States the criminal penalty for willful violation or false statement in a registration (22 U.S.C. 618(a)), the continuing-offense rule for failure to register (618(e)), the Attorney General's civil injunction authority (618(f)), and the bar on public officials acting as agents of a registrable foreign principal (18 U.S.C. 219).

Source
U.S. Department of Justice, National Security Division
Date
Read 10 November 2026
Quoted from
I. Criminal Penalties (22 U.S.C. § 618(a))
Grade
Primary record
Document
https://www.justice.gov/nsd-fara/fara-enforcement
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Exhibit 819 · Inspector general report

Audit of the National Security Division's Enforcement and Administration of the Foreign Agents Registration Act, Audit Division 16-24

Between 1966 and 2015 the Department only brought seven criminal FARA cases

The audit was required by the House Appropriations Committee. It finds that active registrations peaked at 916 in 1987 and stood at 360 at the end of 2014; that DOJ brought seven criminal FARA cases from 1966 to 2015; that DOJ had not sought civil injunctive relief since 1991; that 62 percent of initial registrations were untimely and 50 percent of registrants filed at least one supplement late; that NSD does not track FARA cases declined for prosecution; and that the 1995 Lobbying Disclosure Act exemption may have contributed to the decline. The OIG made 14 recommendations, including a formal assessment of the LDA exemption. NSD agreed with all 14. The OIG could not establish a cause for the decline in registrations.

Source
U.S. Department of Justice, Office of the Inspector General
Date
September 2016
Quoted from
Executive Summary, p. i
Grade
Primary record
Document
https://www.oversight.gov/sites/default/files/oig-reports/a1624.pdf
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Exhibit 820 · GAO report

Post-Government Employment Restrictions and Foreign Agent Registration: Additional Action Needed to Enhance Implementation of Requirements, GAO-08-855

the number of staff resources in Justice’s FARA Registration Unit has significantly declined over the last 17 years from 13 (9 professional and 4 administrative) in 1990 to 8 (6 professional and 2 administrative) in 2008.

GAO reports that DOJ says it lacks clear legal authority to inspect the records of persons it believes should register and to require advance notice of exemption claims, that DOJ sought such authority in 1991 without success, and that FARA Registration Unit staff fell from 13 in 1990 to 8 in 2008. GAO suggested that Congress consider civil investigative demand authority and advance exemption notification. GAO's recommendation tracker marks the matter closed, not implemented.

Source
U.S. Government Accountability Office
Date
30 July 2008
Quoted from
p. 14
Grade
Primary record
Document
https://www.gao.gov/assets/gao-08-855.pdf
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Exhibit 821 · Agency fact sheet

Foreign Agents Registration Act Fact Sheet

In 2018 alone, more than twenty individuals and entities were criminally charged with violations involving FARA. That is more than the number of individuals and entities charged in all of the prior 50 years.

DOJ's own account of FARA enforcement after 2016. It reports more than twenty criminal charges in 2018, a May 2019 civil action (RM Broadcasting) that was the first since 1991, new-registrant counts of 45 (2010), 69 (2016) and 93 to date in 2019, and lists the Skadden settlement (17 January 2019) and the Rafiekian conviction (23 July 2019, overturned 24 September 2019).

Source
U.S. Department of Justice, National Security Division
Date
25 September 2019
Quoted from
By the Numbers, Criminal Cases
Grade
Primary record
Document
https://www.justice.gov/archives/opa/press-release/file/1205161/dl
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Exhibit 822 · Agency report to Congress

Report of the Attorney General to the Congress on the Administration of the Foreign Agents Registration Act, six months ending December 31, 2025

A total of 565 active registrants, representing 858 foreign principals, were on file during the period of July 1, 2025, through December 31, 2025.

Statistical summary: 54 new registration statements and 13 terminations; 565 active registrants representing 858 foreign principals; 349 new short-form registrations; 127 new agreements; seven books-and-records inspections; no civil causes of action and no criminal FARA cases charged in the period. Per-country listing names each registrant, principal, activities and amounts received. Pages 233 to 236 list the Qatar-related registrants; the report states that the listing includes principals with no association with a foreign government.

Source
U.S. Department of Justice
Date
2026
Quoted from
Foreword, Statistical Summary, p. 3
Grade
Primary record
Document
https://www.justice.gov/media/1467011/dl?inline
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Exhibit 823 · Dataset

FARA eFile bulk data: all registrants and all foreign principals (CSV)

Registrant and foreign-principal files with registration and termination dates. Counts derived by the researcher: new registrations 66 in 2014, 69 in 2016, 101 in 2017, 113 in 2018, 150 in 2019, 105 in 2020, 133 in 2021, 119 in 2022, 105 in 2023, 126 in 2024, 138 in 2025; registrants active at any time in the year 917 in 1987, 337 in 2014, 581 in 2025. The 1986 count of 157 new registrations and the 2014 count of 66 match the OIG audit exactly. Active counts differ from the OIG by up to 7 percent. Registrant-name searches return no entries for Brookings, the Atlantic Council or the Center for Strategic and International Studies.

Source
U.S. Department of Justice, FARA Unit
Date
Downloaded 10 November 2026
Grade
Primary record
Document
https://efile.fara.gov/bulk/zip/FARA_All_Registrants.csv.zip
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Exhibit 824 · Charging document

Superseding Criminal Information, United States v. Manafort, No. 17-cr-201 (ABJ), Doc. 419

MANAFORT arranged to pay Companies A and B over $2 million from his offshore accounts for their United States lobbying work for Ukraine.

Charges that from at least 2006 to 2015 Paul Manafort conspired with Richard Gates, Konstantin Kilimnik and others to act as unregistered agents of Ukraine. Describes the Hapsburg Group, four former European officials paid by Ukraine through Manafort's offshore accounts while appearing independent, and two unnamed Washington lobbying firms (Company A and Company B) that lobbied dozens of Members of Congress, staff and executive officials for President Yanukovych. Pages 25 and 26 describe false letters to the Justice Department in November 2016 and February 2017. The information does not name Company A or Company B.

Source
U.S. District Court for the District of Columbia (Special Counsel's Office)
Date
14 September 2018
Quoted from
para. 39, p. 23
Grade
Primary record
Document
https://www.justice.gov/archives/sco/file/1094141/dl
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Exhibit 825 · Agency letter

Letter, DOJ NSD Counterintelligence and Export Control Section to Caplin & Drysdale re Podesta Group, Inc. and the European Centre for a Modern Ukraine

we have determined that Podesta has an obligation to register under FARA.

Determines that the Podesta Group has an obligation to register under FARA for political activities in the United States for the European Centre for a Modern Ukraine, based on its engagement of 18 April 2012. Finds the Podesta Group sent strategic communications to, and arranged meetings with, U.S. officials, media and business leaders. The letter does not state who funded the Centre.

Source
U.S. Department of Justice, National Security Division
Date
31 March 2017
Quoted from
p. 1
Grade
Primary record
Document
https://www.justice.gov/nsd-fara/page/file/1282081/dl
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Exhibit 826 · Agency letter

Letter, DOJ NSD Counterintelligence and Export Control Section to Skadden Arps re Mercury Public Affairs and the European Centre for a Modern Ukraine

we have determined that Mercury has an obligation to register under FARA, which arises from political activities it undertook within the United States pursuant to its relationship with the ECFMU, a foreign principal under the Act.

Determines that Mercury Public Affairs has an obligation to register under FARA for political activities in the United States under its relationship with the European Centre for a Modern Ukraine, and refers to its earlier registration under the Lobbying Disclosure Act from April 2012 to May 2014.

Source
U.S. Department of Justice, National Security Division
Date
31 March 2017
Quoted from
DOJ National Security Division, Counterintelligence and Export Control Section, letter of 31 March 2017 to Kenneth A. Gross (Skadden), p. 1, first paragraph
Grade
Primary record
Document
https://www.justice.gov/nsd-fara/page/file/1282121/download
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Exhibit 827 · Court filing

Statement of the Offense, United States v. Flynn, No. 17-cr-232 (RC), Doc. 4

On March 7, 2017, FLYNN filed multiple documents with the Department of Justice pursuant to the Foreign Agents Registration Act (“FARA”) pertaining to a project performed by him and his company, the Flynn Intel Group, Inc. (“FIG”), for the principal benefit of the Republic of Turkey (“Turkey project”).

Stipulated facts for the plea to one count of false statements (18 U.S.C. 1001) about contacts with Russia's ambassador. Para. 5 adds that Flynn's FARA filings of 7 March 2017 about a project for the benefit of Turkey contained materially false statements and omissions about Turkey's supervision and direction of the project. The FARA conduct was not a separate charged count.

Source
U.S. District Court for the District of Columbia (Special Counsel's Office)
Date
1 December 2017
Quoted from
para. 5, p. 5
Grade
Primary record
Document
https://www.justice.gov/archives/sco/file/1015126/dl
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Exhibit 828 · Court order

Order, United States v. Flynn, No. 17-cr-232 (EGS), Doc. 310

ORDERED that the government’s consent motion to dismiss this case as moot, ECF No. 308, is GRANTED

Denies the government's Rule 48(a) motion (ECF 198) as moot and grants the government's consent motion to dismiss as moot (ECF 308).

Source
U.S. District Court for the District of Columbia
Date
8 December 2020
Quoted from
p. 1
Grade
Primary record
Document
https://storage.courtlistener.com/recap/gov.uscourts.dcd.191592/gov.uscourts.dcd.191592.310.0_11.pdf
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Exhibit 829 · Court opinion

United States v. Rafiekian, No. 22-4252, 68 F.4th 177

In 2019, a jury convicted Bijan Rafiekian of one count of acting as an unregistered agent of a foreign government and one count of criminal conspiracy.

Affirms the district court's order for a new trial for Bijan Rafiekian, a Flynn Intel Group executive convicted in 2019 of acting as an unregistered agent of Turkey and of conspiracy. Recounts Rafiekian I (991 F.3d 529, 4th Cir. 2021), which reversed the judgment of acquittal. Judge Niemeyer dissented.

Source
U.S. Court of Appeals for the Fourth Circuit
Date
18 May 2023
Quoted from
slip op. p. 3
Grade
Primary record
Document
https://www.ca4.uscourts.gov/opinions/224252.p.pdf
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Exhibit 830 · Charging document

Superseding Indictment S4, United States v. Menendez, No. 23-cr-490 (SHS), Doc. 239-1

Public officials, including Members of Congress, are prohibited by law from agreeing to be or acting as an agent of a foreign principal required to register under FARA.

Charges Senator Robert Menendez, his wife Nadine Menendez and two New Jersey businessmen with bribery-related offenses, and charges a conspiracy to have Menendez act as an agent of the Government of Egypt and Egyptian officials, a foreign principal required to register under FARA, in violation of 18 U.S.C. 219. States that neither Nadine Menendez nor Hana registered. Allegations only; the verdict is a separate exhibit.

Source
U.S. District Court for the Southern District of New York
Date
5 March 2024
Quoted from
para. 12, p. 7
Grade
Primary record
Document
https://storage.courtlistener.com/recap/gov.uscourts.nysd.606899/gov.uscourts.nysd.606899.239.1.pdf
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Exhibit 831 · Agency press release

Statement of U.S. Attorney Damian Williams on the convictions of U.S. Senator Robert Menendez and two businessmen; sentencing release

ROBERT MENENDEZ, 70, of Englewood Cliffs, New Jersey; WAEL HANA, 40, of Edgewater, New Jersey, and originally of Egypt; and FRED DAIBES, 66, of Edgewater, New Jersey, were convicted of the charges listed in the chart below.

A jury convicted Menendez on all counts, including acting as an agent of Egypt, on 16 July 2024; the office later announced a sentence of 11 years (29 January 2025).

Source
U.S. Attorney's Office, Southern District of New York
Date
16 July 2024; sentencing 29 January 2025
Quoted from
SDNY statement dated Tuesday, 16 July 2024, paragraph above the charges chart; chart counts 15 and 16 are 'Conspiracy for a public official to act as a foreign agent' and 'Public official acting as a foreign agent' (Menendez)
Grade
Reported
Document
https://www.justice.gov/usao-sdny/pr/statement-us-attorney-damian-williams-convictions-us-senator-robert-menendez-and-two
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Exhibit 832 · Agency press release

Former advisor to presidential candidate among three defendants charged with acting as agents of a foreign government (EDNY release); verdict reporting, 4 November 2022

A seven-count indictment was unsealed today in federal court in Brooklyn

The release announced a seven-count indictment of Thomas Barrack, Matthew Grimes and a UAE national for acting as agents of the UAE between April 2016 and April 2018. A Brooklyn jury acquitted Barrack and Grimes on all counts on 4 November 2022. DOJ's FARA recent-cases page also notes the acquittal.

Source
U.S. Attorney's Office, Eastern District of New York
Date
20 July 2021; acquittal 4 November 2022
Quoted from
EDNY press release dated Tuesday, 20 July 2021, opening sentence
Grade
Reported
Document
https://www.justice.gov/usao-edny/pr/former-advisor-presidential-candidate-among-three-defendants-charged-acting-agents
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Exhibit 833 · News report

Jury Finds Ex-White House Counsel Craig Not Guilty Of Lying To Government

A D.C. jury acquitted Gregory Craig, a former Obama White House counsel and Skadden partner, of one count of making false statements to the Justice Department about Ukraine work (United States v. Craig, 19-cr-125, D.D.C.).

Source
NPR
Date
4 September 2019
Grade
Reported
Document
https://www.npr.org/2019/09/04/757603189/jury-finds-ex-white-house-counsel-craig-not-guilty-of-lying-to-government
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Exhibit 834 · Statute

National Endowment for Democracy Act, 22 U.S.C. 4411 (findings and purposes), Pub. L. 98-164, title V

to facilitate exchanges between United States private sector groups (especially the two major American political parties, labor, and business) and democratic groups abroad

Finds that the Endowment is a private nonprofit corporation that is not an agency or establishment of the U.S. Government, and sets its purposes, including exchanges between U.S. groups and democratic groups abroad and participation by the two major parties, labor and business.

Source
U.S. Congress
Date
22 November 1983
Quoted from
22 U.S.C. § 4411(b)(2)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/22/4411
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Exhibit 835 · Statute

National Endowment for Democracy Act, 22 U.S.C. 4412 (grants to the Endowment)

The Endowment and its grantees shall be subject to the appropriate oversight procedures of the Congress.

Requires an annual grant to the Endowment, originally from the U.S. Information Agency and now through the State Department. Subsec. (e) set minimum amounts for fiscal years 1984 and 1985: $13,800,000 for the Free Trade Union Institute and $2,500,000 for the National Chamber Foundation. Subsec. (d) subjects the Endowment and its grantees to congressional oversight.

Source
U.S. Congress
Date
22 November 1983 (amended 1987)
Quoted from
22 U.S.C. § 4412(d)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/22/4412
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Exhibit 836 · News column

Innocence Abroad: The New World of Spyless Coups

Column on overt political action replacing CIA covert action. Allen Weinstein, then head of the Center for Democracy, agrees with the column's point that exposed covert work backfired. The column describes the National Endowment for Democracy as funded by Congress.

Source
David Ignatius, The Washington Post
Date
22 September 1991
Grade
Reported
Document
https://canada-haiti.ca/content/innocence-abroad-new-world-spyless-coups
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Note
Wording as reported in the secondary copy: "“A lot of what we do today was done covertly 25 years ago by the CIA,” agrees Weinstein." (Washington Post, 22 Sep 1991 (republished copy)).

Exhibit 837 · Audited financial statements and tax return

National Endowment for Democracy audited financial statements and Form 990, fiscal year ended 30 September 2023

substantially all of the Endowment’s revenue was related to appropriations and grants from the U.S. government.

Note 5: FY2023 congressional appropriation received from the State Department $315,000,000; total awards $333,680,861. Statement of activities: U.S. government grant revenue $362,047,237; total expenses $363,214,993. Schedule I lists grants to the four core institutes: International Republican Institute $39,199,882; National Democratic Institute $33,422,549; Solidarity Center $28,701,508 and American Center for International Labor Solidarity $7,286,496 (same EIN); Center for International Private Enterprise $24,024,205 and $9,727,120 (same EIN). Researcher's sum for the four institutes: $142,361,760, or 39.2 percent of total expenses. Whether the paired lines are separate grants is not stated.

Source
National Endowment for Democracy
Date
Fiscal year ended 30 September 2023
Quoted from
Note 6, Concentrations of Revenue
Grade
Primary record
Document
https://www.ned.org/wp-content/uploads/2025/08/National-Endowment-for-Democracy-FY-2023.pdf
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Exhibit 838 · Audited financial statements and tax return

National Endowment for Democracy Form 990 and audited financial statements, fiscal year ended 30 September 2024

FY2024 congressional appropriation received from the State Department $315,249,800; total expenses $355,484,413; U.S. government grant revenue $354,129,218 (per the FY2025 comparative column). Schedule I: International Republican Institute $35,410,575; National Democratic Institute $32,831,250; Center for International Private Enterprise $33,392,527; American Center for International Labor Solidarity (Solidarity Center) $34,259,215. Researcher's sum: $135,893,567, or 38.2 percent of total expenses.

Source
National Endowment for Democracy
Date
Fiscal year ended 30 September 2024
Grade
Primary record
Document
https://www.ned.org/wp-content/uploads/2026/04/National-Endowment-for-Democracy-FY-2024.pdf
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Exhibit 839 · Audited financial statements

National Endowment for Democracy audited financial statements, fiscal year ended 30 September 2025

Fiscal Year 2025 Congressional Annual Appropriation received from DOS $ 315,860,780

Note 5: FY2025 congressional appropriation received from the State Department $315,860,780. U.S. government grant revenue $296,324,822 (FY2024: $354,129,218); total expenses $298,423,023 (FY2024: $355,484,413). The statements report no subsequent events and do not mention the withholding litigation.

Source
National Endowment for Democracy
Date
Fiscal year ended 30 September 2025
Quoted from
Note 5, Grant Revenue - U.S. Government (PDF p. 16)
Grade
Primary record
Document
https://www.ned.org/wp-content/uploads/2026/03/2025-National-Endowment-for-Democracy-FS.pdf
Accessed
2026-11-09
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Exhibit 840 · Audited financial statements

National Endowment for Democracy audited financial statements, fiscal year ended 30 September 2022

Fiscal Year 2022 Congressional Annual Appropriation received from DOS $ 315,079,941

Note 5: FY2022 congressional appropriation received from the State Department $315,079,941; U.S. government grant revenue $321,202,997; total expenses $322,805,657.

Source
National Endowment for Democracy
Date
Fiscal year ended 30 September 2022
Quoted from
Note 5, Grant Revenue - U.S. Government (PDF p. 14)
Grade
Primary record
Document
https://www.ned.org/wp-content/uploads/2023/05/NED_22-FS_Final.pdf
Accessed
2026-11-09
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Exhibit 841 · Court opinion

Memorandum Opinion, National Endowment for Democracy v. United States, No. 25-cv-648 (DLF), Doc. 46, 795 F. Supp. 3d 63

Taken as a whole, that evidence leaves little doubt as to the defendants’ motivations

Grants NED a preliminary injunction against withholding $95 million of its fiscal 2025 appropriation. Finds that the State Department's spending plan placed unobligated funds under review for alignment with Administration priorities, that the OMB director urged Congress to defund NED because of grantees' criticism of the President's allies, and that the stated reason (reserving funds for FY2026) was not plausible. Records that the withholding left 226 approved grants, 124 recommended grants and 53 core-institute projects unfunded, and that Congress appropriated $315,000,000 for FY2024 and FY2025 at the same level. A preliminary ruling on likely success, not a final judgment.

Source
U.S. District Court for the District of Columbia (Judge Dabney L. Friedrich)
Date
11 August 2025
Quoted from
p. 7
Grade
Primary record
Document
https://storage.courtlistener.com/recap/gov.uscourts.dcd.278101/gov.uscourts.dcd.278101.46.0.pdf
Accessed
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Exhibit 842 · Court filing

Joint Status Report and Plaintiff's Motion to Withdraw Preliminary Injunction Motion, National Endowment for Democracy v. United States, Doc. 70

the State Department has obligated to the Endowment the $315 million that Congress appropriated for the Endowment in fiscal year 2026.

Reports that the State Department obligated the full FY2026 appropriation to NED and that NED drew funds on 30 March 2026, and records the government's representations that it would not interfere with drawdowns or act on the allegations of the Rogers Letter (ECF 68).

Source
U.S. District Court for the District of Columbia (parties' filing)
Date
31 March 2026
Quoted from
p. 1
Grade
Primary record
Document
https://storage.courtlistener.com/recap/gov.uscourts.dcd.278101/gov.uscourts.dcd.278101.70.0.pdf
Accessed
2026-11-09
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Exhibit 843 · Court filing

Defendants' Reply in Support of Motion to Dismiss, National Endowment for Democracy v. United States, Doc. 77

But Plaintiff’s claims are moot as NED has received the essential requested relief.

The government's position that NED's claims are moot because FY2025 and FY2026 funds have been obligated and disbursed. NED's notice of supplemental authority (Doc. 78, 9 October 2026) shows the motion to dismiss was still pending and records the FY2027 continuing resolution (Pub. L. 119-103, 2 September 2026).

Source
U.S. District Court for the District of Columbia (defendants' filing)
Date
17 July 2026
Quoted from
p. 1
Grade
Primary record
Document
https://storage.courtlistener.com/recap/gov.uscourts.dcd.278101/gov.uscourts.dcd.278101.77.0.pdf
Accessed
2026-11-09
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Exhibit 844 · Executive order

Executive Order 14169, Reevaluating and Realigning United States Foreign Aid, 90 Fed. Reg. 8619

All department and agency heads with responsibility for United States foreign development assistance programs shall immediately pause new obligations and disbursements of development assistance funds to foreign countries and implementing non-governmental organizations, international organizations, and contractors pending reviews of such programs for programmatic efficiency and consistency with United States foreign policy, to be conducted within 90 days of this order.

Sec. 3(a) pauses new obligations and disbursements of foreign development assistance for 90 days for review; OMB enforces the pause through apportionment; sec. 3(e) lets the Secretary of State waive the pause for specific programs.

Source
The White House
Date
20 January 2025 (published 30 January 2025)
Quoted from
sec. 3(a)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2025-01-30/pdf/2025-02091.pdf
Accessed
2026-11-09
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Exhibit 845 · Court order

Department of State v. AIDS Vaccine Advocacy Coalition, No. 25A269, order on application for stay, 606 U.S. 1055

This order should not be read as a final determination on the merits.

Stays a district court injunction that directed the Executive to obligate about $10.5 billion of expiring appropriated aid, of which $4 billion was proposed for rescission under the Impoundment Control Act. States a preliminary view that the Impoundment Control Act likely precludes the grantees' APA suit. Justice Kagan dissented. The order is expressly not a final merits determination.

Source
U.S. Supreme Court
Date
26 September 2025
Quoted from
p. 1
Grade
Primary record
Document
https://www.supremecourt.gov/opinions/24pdf/25a269_bp7c.pdf
Accessed
2026-11-09
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Exhibit 846 · News investigation

Foreign Powers Buy Influence at Think Tanks

Reports that since 2011 at least 64 foreign governments, state-controlled entities or officials contributed to 28 major U.S. research organizations, at least $92 million, a figure the article derives from the institutions' disclosures, government documents and foreign lobbying reports. Reports that the think tanks do not disclose agreement terms and have not registered under FARA, and that legal specialists said some arrangements appear to merit registration. Brookings and the Atlantic Council said their scholars are independent; the Center for Global Development's chief operating officer said of the registration question, 'We will absolutely seek counsel on this.' Cites Norway's $5 million agreement with the Center for Global Development and Qatar's $14.8 million four-year donation to Brookings. Archived copy of the web page.

Source
Eric Lipton, Brooke Williams and Nicholas Confessore, The New York Times
Date
6 September 2014 (web date 7 September)
Grade
Reported
Document
https://www.nytimes.com/2014/09/07/us/politics/foreign-powers-buy-influence-at-think-tanks.html
Accessed
2026-11-09
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Note
Wording as reported in the secondary copy: "The think tanks do not disclose the terms of the agreements they have reached with foreign governments." (para. 5).

Exhibit 847 · CRS report

Section 117 of the Higher Education Act: Reporting of Foreign Gifts and Contracts, CRS In Focus IF12927 (updated 25 March 2026)

From 2019 to 2021 during the first Trump Administration, ED opened 19 investigations into Section 117 noncompliance. The Biden Administration did not open any investigations.

States the reporting rule ($250,000 per source per calendar year), ED's published spreadsheets since 1986, and totals as of 23 February 2026: Qatar about $8.8 billion across about 1,300 transactions, China about $4.9 billion across about 8,000. Harvard $4.5 billion and Cornell $4.2 billion in aggregate. Enforcement: 19 investigations opened 2019 to 2021 (first Trump Administration), none under the Biden Administration, four to date under the second Trump Administration.

Source
Congressional Research Service
Date
25 March 2026
Quoted from
History of Enforcement Actions
Grade
Primary record
Document
https://www.everycrsreport.com/reports/IF12927.html
Accessed
2026-11-09
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Exhibit 848 · Congressional staff report

China's Impact on the U.S. Education System, staff report of the Permanent Subcommittee on Investigations

nearly 70 percent of U.S. schools that received more than $250,000 from Hanban failed to properly report that amount to the Department of Education.

Finds that from 2006 China directly provided over $158 million to U.S. schools for Confucius Institutes; that 33 of 48 schools (69 percent) required to report Hanban gifts above $250,000 did not; and that of $51,526,181 that should have been reported for 2012 to 2018, $36,089,456 was not. Scope is China's Hanban only.

Source
U.S. Senate Permanent Subcommittee on Investigations (Chairman Portman, Ranking Member Carper)
Date
February 2019
Quoted from
Executive Summary, pp. 2-3
Grade
Primary record
Document
https://www.hsgac.senate.gov/wp-content/uploads/imo/media/doc/PSI%20Report%20China's%20Impact%20on%20the%20US%20Education%20System.pdf
Accessed
2026-11-09
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Exhibit 849 · Agency dispatch

Countering Criticism of the Warren Report (CIA Dispatch 1035-960, to Chiefs, Certain Stations and Bases)

The aim of this dispatch is to provide material for countering and discrediting the claims of the conspiracy theorists, so as to inhibit the circulation of such claims in other countries.

Three-page dispatch with nine attachments (one classified, eight unclassified) sent to chiefs of certain stations and bases. It cites a public opinion poll in which 46 percent of Americans did not think Oswald acted alone, calls the trend a concern to the U.S. government and the Agency, and instructs addressees, where discussion is already active, to raise the matter with 'liaison and friendly elite contacts (especially politicians and editors)' and to 'employ propaganda assets to answer and refute the attacks of the critics.' It says the Agency does not recommend starting discussion where none exists. Released in full under the JFK Records Act in 1998; the NARA record number given by secondary sources is 104-10009-10022. The cover stamp reads 4/1/67; the attached background survey is dated 4 January 1967 (some metadata uses that date). Para. 1-2 cite the poll and call the trend 'a matter of concern to the U.S. government, including our organization.' Para. 3 suggests that addressees describe critics as 'wedded to theories adopted before the evidence was in,' 'politically interested,' 'financially interested,' 'hasty and inaccurate' or 'infatuated with their own theories,' and 'single out Epstein's theory for attack.'

Source
Central Intelligence Agency
Date
1 April 1967
Quoted from
Dispatch 1035-960, page 1, paragraph 2 (read from page image)
Grade
Primary record
Document
https://www.cia.gov/readingroom/document/00352448
Archived
https://archive.org/details/cia-readingroom-document-00352448
Accessed
2026-11-09
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Note
Further exact wording. Para. 1-2: 'a matter of concern to the U.S. government, including our organization'; 'Conspiracy theories have frequently thrown suspicion on our organization, for example by falsely alleging that Lee Harvey Oswald worked for us.' Para. 3: 'To employ propaganda assets to answer and refute the attacks of the critics. Book reviews and feature articles are particularly appropriate for this purpose,' with a suggestion to describe critics as 'wedded to theories adopted before the evidence was in,' 'politically interested,' 'financially interested,' 'hasty and inaccurate,' or 'infatuated with their own theories,' and to 'single out Epstein's theory for attack.' Para. 4a-g and 5 give talking points and end: 'Where possible, counter speculation by encouraging reference to the Commission's Report itself.'

Exhibit 850 · Congressional hearing

CIA's Use of Journalists and Clergy in Intelligence Operations, S. Hrg. 104-593

Simply put, the Central Intelligence Agency policy is not to use journalists accredited to American news organizations, their parent organizations, American clergy or the Peace Corps for intelligence purposes.

Hearing chaired by Sen. Arlen Specter. Director of Central Intelligence John Deutch states that CIA policy, in place for about 19 years, is not to use accredited American journalists, American clergy or Peace Corps members for intelligence purposes, and that the Agency should not be prohibited from considering their use in exceptional circumstances. He reports new classified guidelines requiring tests, prompt notice to the intelligence committees and a decision by the Director or Deputy Director. Witnesses include journalists Ted Koppel, Terry Anderson, Mortimer Zuckerman and Kenneth Adelman and representatives of religious bodies. Specter notes a House amendment (Richardson) that would require the President to decide any waiver.

Source
U.S. Senate Select Committee on Intelligence
Date
17 July 1996
Quoted from
Statement of DCI John M. Deutch, hearing pp. 6-8
Grade
Primary record
Document
https://www.intelligence.senate.gov/wp-content/uploads/2024/08/sites-default-files-hearings-ciasuseofjournal00unit.pdf
Accessed
2026-11-09
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Exhibit 851 · Agency history

Origins of the Congress for Cultural Freedom, 1949-50 (Michael Warner, Studies in Intelligence 38, no. 5)

The Congress for Cultural Freedom is widely considered one of the CIA's more daring and effective Cold War covert operations.

CIA-hosted article, an excerpt from a classified draft study of CIA involvement with anti-Communist groups (redacted for release). It states that the Congress for Cultural Freedom is widely considered one of the CIA's more daring and effective Cold War covert operations, that it published journals such as Encounter, that its Administrative Secretary Michael Josselson kept it running for almost two decades until the Agency arranged a separation in 1966, and that its CIA sponsorship was exposed in 1967.

Source
Central Intelligence Agency, Center for the Study of Intelligence
Date
1995
Quoted from
Opening paragraph (web edition)
Grade
Primary record
Document
https://www.cia.gov/resources/csi/studies-in-intelligence/archives/vol-38-no-5/origins-of-the-congress-for-cultural-freedom-1949-1950
Accessed
2026-11-09
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Note
Author's article hosted by the CIA; the page is the Agency's own publication of its history, not a leak.

Exhibit 852 · Magazine article

I'm Glad the CIA Is 'Immoral' (Thomas W. Braden), Saturday Evening Post, pp. 10, 12, 14

Money for both the orchestra's tour and the magazine's publication came from the CIA, and few outside the CIA knew about it.

First-person account by a former CIA officer who describes starting the Agency's International Organizations Division and funding labor, student and cultural groups. He says the CIA paid for the Boston Symphony tour and for Encounter, placed one agent in the Congress for Cultural Freedom and another as an editor of Encounter, and suggested raising money from 'American foundations.'

Source
The Saturday Evening Post (author Thomas W. Braden)
Date
20 May 1967
Quoted from
Page 12, column 3 (checked against page image)
Grade
Reported
Document
https://archive.org/details/im-glad-the-cia-is-immoral-by-thomas-w.-braden-the-saturday-evening-post-may-20-1967-pp.-10-12-14
Accessed
2026-11-09
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Note
Own words of a former Agency officer; a primary Agency document on the Encounter funding is not in this set.

Exhibit 853 · Magazine article

The CIA and the Media (Carl Bernstein), Rolling Stone, with the magazine's press release (copy in the National Security Archive)

journalists secretly carried out assignments for the Central Intelligence Agency, according to documents on file at CIA headquarters.

Reports, from interviews with more than 35 current and former CIA officials and from Senate staff, that more than 400 American journalists carried out assignments for the CIA over 25 years and that at least 25 news organizations provided cover. Reports that William Colby told Church Committee staff to go to the managements of news organizations, which he said were witting, and alleges that the Committee played down the extent of the relationships after CIA lobbying. Names executives and columnists as having cooperated; some named persons denied or minimized this.

Source
Rolling Stone (author Carl Bernstein)
Date
20 October 1977
Quoted from
Rolling Stone press release, p. 1 (OCR copy; the clause is the release's wording of Bernstein's count of more than 400 in 25 years)
Grade
Reported
Document
https://archive.org/details/nsia-BernsteinRollingStoneArticlesCIA
Accessed
2026-11-09
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Note
Church Book I counts about 50 relationships as of February 1976; the figures cover different periods and definitions.

Exhibit 854 · Inspector general report

Review of Matters Related to the Office of the Assistant Secretary of Defense (Public Affairs) Retired Military Analyst Outreach Activities, DODIG-2012-025

A preponderance of evidence indicates that one RMA stopped receiving invitations because he was a critic.

Reevaluation after the IG withdrew its first report (IE-2009-004, 14 January 2009). The review covered more than 25,000 documents and interviews with 63 of 74 analysts and 65 DOD officials. It found the outreach program, which began in 2002 and ran until February 2008, complied with DOD policy; found that one analyst stopped receiving invitations because he was a critic; identified 43 analysts with defense contractor affiliations and found no financial benefit through those affiliations among the 35 it asked; and recommended a written plan for such groups.

Source
Department of Defense Office of Inspector General
Date
21 November 2011
Quoted from
Introduction and Summary, Review Results, p. 2
Grade
Primary record
Document
https://media.defense.gov/2011/Nov/21/2001712365/-1/-1/1/RMATheFinalReport112111redacted.pdf
Archived
https://web.archive.org/web/20251208011917/https://media.defense.gov/2011/Nov/21/2001712365/-1/-1/1/RMATheFinalReport112111redacted.pdf
Accessed
2026-11-09
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Exhibit 855 · Legal opinion

Department of Defense - Retired Military Officers as Media Analysts, B-316443

Clearly, DOD attempted to favorably influence public opinion with respect to the Administration's war policies in Iraq and Afghanistan through the RMOs.

Legal opinion required by Pub. L. 110-417 sec. 1056. GAO finds DOD attempted to favorably influence public opinion on war policy through the analysts, but finds no evidence that DOD concealed its role, contracted with or paid the analysts for positive commentary, so the publicity-or-propaganda prohibition was not violated. Footnote 3 records that the DOD IG withdrew its January 2009 report on 5 May 2009 because its method would not reasonably yield evidence about financial advantage.

Source
U.S. Government Accountability Office
Date
21 July 2009
Quoted from
Opinion, p. 2
Grade
Primary record
Document
https://www.gao.gov/products/b-316443
Archived
https://web.archive.org/web/2020/https://www.gao.gov/assets/b-316443.pdf
Accessed
2026-11-09
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Exhibit 856 · Press briefing transcript

Defense Department News Briefing, Secretary of Defense Donald H. Rumsfeld (excerpts on the Office of Strategic Influence)

he has decided to close down the Office of Strategic Influence.

Rumsfeld announces that Under Secretary Douglas Feith has decided to close the Office of Strategic Influence, says the office could not function after the criticism, says the department does not do disinformation and has not developed a charter for the office, and says influence activities (leaflets, radio broadcasts, information operations) will continue in other offices.

Source
U.S. Department of Defense
Date
26 February 2002
Quoted from
Rumsfeld, answer to first question (FAS reproduction of the DOD transcript)
Grade
Primary record
Document
https://sgp.fas.org/news/2002/02/dod022602.html
Accessed
2026-11-09
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Exhibit 857 · News article

Behind TV Analysts, Pentagon's Hidden Hand (David Barstow), New York Times, p. A1

Internal Pentagon documents repeatedly refer to the military analysts as "message force multipliers" or "surrogates" who could be counted on to deliver administration "themes and messages" to millions of Americans "in the form of their own opinions."

Reports that the Pentagon cultivated retired officers who appeared as television and radio analysts, that most had ties to defense contractors, and that the Times obtained about 8,000 pages of e-mail, transcripts and records through a lawsuit. Quotes internal Pentagon documents that called the analysts 'message force multipliers' or 'surrogates.' Triggered the GAO and DOD IG reviews.

Source
The New York Times
Date
20 April 2008
Quoted from
Article text, page 2 of the web edition (Wayback copy of the 'pagewanted=all' version)
Grade
Reported
Document
http://www.nytimes.com/2008/04/20/washington/20generals.html
Archived
https://web.archive.org/web/2012/http://www.nytimes.com/2008/04/20/washington/20generals.html?pagewanted=all
Accessed
2026-11-09
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Exhibit 858 · Legal decision

Department of Health and Human Services, Centers for Medicare & Medicaid Services - Video News Releases, B-302710

The Centers for Medicare & Medicaid Services's (CMS) use of appropriated funds to pay for the production and distribution of story packages that were not attributed to CMS violated the restriction on using appropriated funds for publicity or propaganda purposes

Finds that CMS's use of appropriated funds for story packages in video news releases on the Medicare drug benefit, which did not identify CMS as the source and in which a person presented as a reporter had been hired by an HHS subcontractor, violated the publicity-or-propaganda restriction and the Antideficiency Act.

Source
U.S. General Accounting Office (Comptroller General)
Date
19 May 2004
Quoted from
Digest, point 1
Grade
Primary record
Document
https://www.gao.gov/products/b-302710
Archived
https://web.archive.org/web/2020/https://www.gao.gov/assets/b-302710.pdf
Accessed
2026-11-09
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Exhibit 859 · Legal decision

Office of National Drug Control Policy - Video News Release, B-303495

ONDCP's news stories constituted covert propaganda and violated publicity or propaganda prohibitions contained in its 2002, 2003, and 2004 appropriations acts.

Requested by Rep. Waxman and Rep. Olver. Examines eight video news releases from fiscal years 2002-2004 and finds the seven with prepackaged news stories covert propaganda because ONDCP did not identify itself; finds ONDCP's use of the term 'Drug Czar' is not unlawful self-aggrandizement; finds Antideficiency Act violations reportable.

Source
U.S. Government Accountability Office
Date
4 January 2005
Quoted from
Digest, point 1 (p. 17)
Grade
Primary record
Document
https://www.gao.gov/products/b-303495
Archived
https://web.archive.org/web/2020/https://www.gao.gov/assets/b-303495.pdf
Accessed
2026-11-09
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Exhibit 860 · Legal decision

Department of Education - No Child Left Behind Act Video News Release and Media Analysis, B-304228

the Department's prepackaged news story constitutes covert propaganda and violates the publicity or propaganda prohibition.

Finds a Ketchum-produced video news release on tutoring under No Child Left Behind (paid $38,421.06) covert propaganda, rejecting the Department's argument, based on a 30 July 2004 Office of Legal Counsel opinion, that a factual story need not disclose its source. Finds a media analysis (paid $96,850.99) lawful except that one report assessed whether 'the Bush Administration/the GOP is committed to education.'

Source
U.S. Government Accountability Office
Date
30 September 2005
Quoted from
Opinion, p. 5
Grade
Primary record
Document
https://www.gao.gov/products/b-304228
Archived
https://web.archive.org/web/2020/https://www.gao.gov/assets/b-304228.pdf
Accessed
2026-11-09
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Exhibit 861 · Legal decision

Department of Education - Contract to Obtain Services of Armstrong Williams, B-305368

we find that the Department contracted for Armstrong Williams to comment regularly on the No Child Left Behind Act without assuring that the Department's role was disclosed to the targeted audiences.

Requested by Sen. Lautenberg and Sen. Kennedy. Relies on the Education Inspector General's report A19-F0007 (15 April 2005). Finds the Department arranged through Ketchum for Armstrong Williams to comment regularly on No Child Left Behind without assuring disclosure of the Department's role, which was covert propaganda and an Antideficiency Act violation. The Department paid Ketchum $188,543.48 for the two task orders, of which $186,000 covered amounts Ketchum paid Williams's company, the Graham Williams Group.

Source
U.S. Government Accountability Office
Date
30 September 2005
Quoted from
Opinion, p. 1
Grade
Primary record
Document
https://www.gao.gov/products/b-305368
Archived
https://web.archive.org/web/2020/https://www.gao.gov/assets/b-305368.pdf
Accessed
2026-11-09
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Exhibit 862 · Legal decision

Environmental Protection Agency - Application of Publicity or Propaganda and Anti-Lobbying Provisions, B-326944

EPA's use of Thunderclap constituted covert propaganda, in violation of the publicity or propaganda prohibition.

Requested by Sen. Inhofe, chairman of the Senate Environment and Public Works Committee. Finds that EPA's Thunderclap campaign during the 'Waters of the United States' rulemaking was covert propaganda, that two other campaigns (#DitchtheMyth, #CleanWaterRules) did not violate the prohibition, that hyperlinks in an EPA blog post to NRDC and Surfrider pages were grassroots lobbying, and that EPA violated the Antideficiency Act. EPA argued it made no attempt to conceal its role.

Source
U.S. Government Accountability Office
Date
14 December 2015
Quoted from
Opinion, p. 11
Grade
Primary record
Document
https://www.gao.gov/products/b-326944
Archived
https://web.archive.org/web/2020/https://www.gao.gov/assets/b-326944.pdf
Accessed
2026-11-09
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Exhibit 863 · Statute

National Defense Authorization Act for Fiscal Year 2013, Pub. L. 112-239, sec. 1078 (Dissemination Abroad of Information About the United States)

No funds authorized to be appropriated to the Department of State or the Broadcasting Board of Governors shall be used to influence public opinion in the United States.

Rewrites 22 U.S.C. 1461 so that State and the Broadcasting Board of Governors may, on request and reimbursement, make materials disseminated abroad available in the United States, and amends sec. 208 of the Foreign Relations Authorization Act, FY 1986-87, to say no funds authorized for State or the Board 'shall be used to influence public opinion in the United States' while allowing domestic exposure to material made for foreign audiences. Material produced before the effective date is released to the Archivist after 12 years.

Source
U.S. Congress
Date
2 January 2013
Quoted from
Sec. 1078(c), new sec. 208(a), 126 Stat. 1958
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-112publ239/html/PLAW-112publ239.htm
Accessed
2026-11-09
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Exhibit 864 · News article

The Aspiring Novelist Who Became Obama's Foreign-Policy Guru (David Samuels), New York Times Magazine

We created an echo chamber,

Profile of Deputy National Security Adviser Ben Rhodes describing the White House effort to build support for the Iran nuclear agreement through think tanks, outside groups, social media tracking and friendly reporters. Quotes Rhodes on creating an 'echo chamber' and notes that he rejected the suggestion that the sale of the agreement was deceptive.

Source
The New York Times Magazine
Date
8 May 2016
Quoted from
Wayback copy, paragraph beginning 'As Malley and representatives of the State Department'
Grade
Reported
Document
http://www.nytimes.com/2016/05/08/magazine/the-aspiring-novelist-who-became-obamas-foreign-policy-guru.html
Archived
https://web.archive.org/web/2017/http://www.nytimes.com/2016/05/08/magazine/the-aspiring-novelist-who-became-obamas-foreign-policy-guru.html
Accessed
2026-11-09
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Note
Single-source account of a named official's own words; no White House document in this set.

Exhibit 865 · Court opinion

Missouri v. Biden, No. 3:22-cv-01213 (W.D. La.), Memorandum Ruling on Request for Preliminary Injunction, Doc. 293

The Plaintiffs have presented substantial evidence in support of their claims that they were the victims of a far-reaching and widespread censorship campaign.

155-page ruling after expedited discovery granting a preliminary injunction against officials at the White House, Surgeon General's office, CDC, FBI, CISA, NIAID and the State Department on the finding that plaintiffs were likely to succeed on the claim that the government coerced or significantly encouraged platform moderation. The court says the alleged censorship 'almost exclusively targeted conservative speech' and that the issues 'go beyond party lines,' and says the evidence at this stage 'depicts an almost dystopian scenario.' Reviewed as a preliminary ruling; the Supreme Court later held the plaintiffs lacked standing.

Source
U.S. District Court, Western District of Louisiana (Judge Terry A. Doughty)
Date
4 July 2023
Quoted from
Memorandum Ruling, p. 154
Grade
Primary record
Document
https://storage.courtlistener.com/recap/gov.uscourts.lawd.189520/gov.uscourts.lawd.189520.293.0.pdf
Accessed
2026-11-09
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Exhibit 866 · Court opinion

Missouri v. Biden, 83 F.4th 350 (5th Cir. 2023) (revised opinion), No. 23-30445

We agree, but only as to some of those officials.

Affirms in part, reverses in part, vacates and modifies the preliminary injunction: holds that the White House, Surgeon General's office, CDC and FBI likely coerced or significantly encouraged platforms and that CISA likely significantly encouraged them; the court removed NIAID and the State Department from the injunction. After the Supreme Court's decision, the Fifth Circuit vacated the injunction and remanded (26 August 2024).

Source
U.S. Court of Appeals for the Fifth Circuit
Date
3 October 2023
Quoted from
Opinion, introduction (page 2 of the slip opinion)
Grade
Primary record
Document
https://www.ca5.uscourts.gov/opinions/pub/23/23-30445-CV1.pdf
Accessed
2026-11-09
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Exhibit 867 · Congressional letter

Letter from Rep. Nancy Mace to President Biden and Vice President Harris regarding Mark Zuckerberg's 26 August 2024 letter

In 2021, senior officials from the Biden Administration, including the White House, repeatedly pressured our team for months to censor certain COVID-19 content, including humor and satire, and expressed a lot of frustration with our teams when we didn’t agree.

Quotes the Meta chief executive's 26 August 2024 letter to House Judiciary Chairman Jim Jordan.

Source
U.S. House Committee on Oversight and Accountability, Subcommittee chair Nancy Mace
Date
11 September 2024
Quoted from
Rep. Nancy Mace letter to the White House, 11 Sep 2024, p. 1, paragraph 2
Grade
Reported
Document
https://oversight.house.gov/wp-content/uploads/2024/09/Mace-ltr-to-WH-re-Zuckerberg-Ltr.pdf
Accessed
2026-11-09
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Note
The House Judiciary FBI report (30 Oct 2024) also quotes it: 'the reporting was not Russian disinformation' and 'we shouldn't have demoted the [New York Post] story.' Wording as reported in the secondary copy: "In 2021, senior officials from the Biden Administration, including the White House, repeatedly pressured our team for months to censor certain COVID-19 content, including humor and satire, and expressed a lot of frustration with our teams when we didn't agree." (Mace letter, page 1, quoting Zuckerberg to Jordan (26 Aug 2024)).

Exhibit 868 · Statute

National Defense Authorization Act for Fiscal Year 2017, Pub. L. 114-328, sec. 1287 (Global Engagement Center)

to lead, synchronize, and coordinate efforts of the Federal Government to recognize, understand, expose, and counter foreign state and non-state propaganda and disinformation efforts aimed at undermining United States national security interests.

Directs the Secretary of State to establish a Global Engagement Center. Its functions refer to narratives 'abroad' and audiences 'outside the United States.' As amended by Pub. L. 115-232 sec. 1284 (13 August 2018), the authority terminated 8 years after 23 December 2016, so on 23 December 2024 (per the note at 22 U.S.C. 2656).

Source
U.S. Congress
Date
23 December 2016
Quoted from
Sec. 1287(a)(2), 130 Stat. 2546
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-114publ328/html/PLAW-114publ328.htm
Accessed
2026-11-09
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Exhibit 869 · Agency press statement

Protecting and Championing Free Speech at the State Department (Press Statement, Secretary Marco Rubio)

this office, which cost taxpayers more than $50 million per year, spent millions of dollars to actively silence and censor the voices of Americans they were supposed to be serving.

Announces closure of the Counter Foreign Information Manipulation and Interference office (R/FIMI), formerly the Global Engagement Center, and says it spent millions of dollars to silence and censor Americans. The statement cites no document or case.

Source
U.S. Department of State
Date
16 April 2025
Quoted from
Press statement, second paragraph
Grade
Primary record
Document
https://www.state.gov/protecting-and-championing-free-speech-at-the-state-department
Archived
https://web.archive.org/web/20250417000000/https://www.state.gov/protecting-and-championing-free-speech-at-the-state-department
Accessed
2026-11-09
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Exhibit 870 · Open letter

Public Statement on the Hunter Biden Emails (open letter of 51 former intelligence officials)

we do not know if the emails, provided to the New York Post by President Trump's personal attorney Rudy Giuliani, are genuine or not and that we do not have evidence of Russian involvement

Seven-page statement signed by former officials including a former DNI, three former CIA directors and a former Secretary of Defense. It says the emails 'has all the classic earmarks of a Russian information operation' and adds that the signers do not know whether the emails are genuine and 'do not have evidence of Russian involvement.' It was issued by private individuals, not an agency.

Source
Signatories (former senior national security and intelligence officials), first published by Politico
Date
19 October 2020
Quoted from
Statement, page 1, paragraph 5
Grade
Primary record
Document
https://www.politico.com/f/?id=00000175-4393-d7aa-af77-579f9b330000
Archived
https://web.archive.org/web/2020/https://www.politico.com/f/?id=00000175-4393-d7aa-af77-579f9b330000
Accessed
2026-11-09
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Note
Count of 51 signers is from secondary sources and from Executive Order 14152; not hand-counted.

Exhibit 871 · Executive order

Executive Order 14152, Holding Former Government Officials Accountable for Election Interference and Improper Disclosure of Sensitive Governmental Information

The signatories willfully weaponized the gravitas of the Intelligence Community to manipulate the political process and undermine our democratic institutions.

Directs revocation of active security clearances held by the former intelligence officials who signed the 2020 letter and by John R. Bolton. Section 1 states that at least 51 former officials 'coordinated with the Biden campaign' to issue the letter and that the letter was sent to the CIA Prepublication Classification Review Board before release. Published in the Federal Register 29 January 2025 (90 FR 8343).

Source
Office of the President
Date
20 January 2025
Quoted from
Sec. 1, 90 FR 8343
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2025-01-29/pdf/2025-01954.pdf
Accessed
2026-11-09
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Exhibit 872 · Agency memorandum

Memorandum, Mayorkas to HSAC Co-Chairs, Initial Homeland Security Advisory Council Projects

assess how the Department can most effectively and appropriately address disinformation that poses a threat to the homeland, while increasing transparency and protecting free speech, civil rights, civil liberties, and privacy.

Asks the Homeland Security Advisory Council to assess how DHS can address disinformation that threatens the homeland 'while increasing transparency and protecting free speech, civil rights, civil liberties, and privacy,' with findings in 75 days and publication of the final report. This is the review under which the Disinformation Governance Board was assessed.

Source
U.S. Department of Homeland Security
Date
18 May 2022
Quoted from
Memorandum, page 1, paragraph 4
Grade
Primary record
Document
https://www.dhs.gov/sites/default/files/2022-06/FINAL%20S1%20APPROVED%20HSAC%20TASKING%205-18.pdf
Accessed
2026-11-09
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Exhibit 873 · Advisory committee report

Disinformation Best Practices and Safeguards Subcommittee, Final Interim Recommendation

we have concluded that there is no need for a Disinformation Governance Board.

Subcommittee co-chaired by Michael Chertoff and Jamie Gorelick, after briefings from every DHS component with a role in the mission, concludes there is no need for a Disinformation Governance Board and defers its recommendations on the Department's approach.

Source
U.S. Department of Homeland Security, Homeland Security Advisory Council
Date
18 July 2022
Quoted from
Slide 4, Interim Recommendation
Grade
Primary record
Document
https://www.dhs.gov/sites/default/files/2022-07/22_0718_ope_final-interim-recommendation-disinformation-best-practices-safeguards-subcommittee_0.pdf
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2026-11-09
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Exhibit 874 · Advisory committee report

Disinformation Best Practices and Safeguards Subcommittee, Final Report

We previously recommended to the full Council-and the Council has accepted our recommendation-that there is no need for a separate Disinformation Governance Board.

Final report to Secretary Mayorkas. Says the Council accepted the subcommittee's recommendation that there is no need for a separate Disinformation Governance Board and that the underlying work of Department components on disinformation is critical and must follow the law and best practices.

Source
U.S. Department of Homeland Security, Homeland Security Advisory Council
Date
24 August 2022
Quoted from
Recommendations, (1), page 12
Grade
Primary record
Document
https://media.reclaimthenet.org/docs/dhs-disinformation-subcommittee-final-report-08242022.pdf
Accessed
2026-11-09
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Exhibit 875 · Congressional report

Final Report of the Select Committee to Investigate Foundations and Other Organizations, H. Rept. 2514, 82d Cong., 2d sess.

Our investigation, hurried by lack of time, indicates that very few actual Communists or Communist sympathizers obtained positions of influence in the foundations.

Report of the committee created by H. Res. 561 (4 April 1952), chaired by E. E. Cox of Georgia until his death on 24 December 1952, completed under Acting Chairman Brooks Hays. Signed by all six members, including B. Carroll Reece, who appended a note asking that the inquiry be continued by the next Congress. Finds little basis for the belief that foundation funds are diverted, finds very few Communists in positions of influence, finds some foundation grants to Communists and sympathizers, and recommends a Public Accountability Act requiring public reporting by exempt organizations.

Source
U.S. House of Representatives, Select Committee to Investigate Foundations
Date
1 January 1953
Quoted from
Findings and Conclusions, p. 7
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/SERIALSET-11578_00_00-225-2514-0000/pdf/SERIALSET-11578_00_00-225-2514-0000.pdf
Accessed
2026-11-09
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Exhibit 876 · Congressional report

Tax-Exempt Foundations: Report of the Special Committee to Investigate Tax-Exempt Foundations and Comparable Organizations, H. Rept. 2681, 83d Cong., 2d sess.

There is no conclusive evidence that this interlock, this concentration of power, having some of the characteristics of an intellectual cartel, came into being as the result of an over-all, conscious plan. Nevertheless, it exists.

Majority report of 3 Republicans (Reece, Wolcott, Goodwin); Representatives Hays and Pfost, the two Democrats, cast contrary votes and filed Minority Views (pp. 417-431) saying the report 'should never be published.' The majority finds that large foundations wield patronage with 'elements of thought control,' that the interlock of major foundations 'exists' though there is 'no conclusive evidence' it was the result of an over-all plan, and that some larger foundations supported 'subversion' as the committee defines it. The majority says foundations have generally not directly supported Communism.

Source
U.S. House of Representatives, Special Committee to Investigate Tax-Exempt Foundations
Date
December 1954
Quoted from
Summary of Committee Findings, no. 4, p. 17
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/SERIALSET-11748_00_00-001-2681-0000/pdf/SERIALSET-11748_00_00-001-2681-0000.pdf
Accessed
2026-11-09
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Note
Text of the majority's 'subversion' definition is at p. 19, no. 14.

Exhibit 877 · Foundation publication

The Country School of To-Morrow (Frederick T. Gates), General Education Board Occasional Papers, No. 1

Let us, at least, yield ourselves to the gratifications of a beautiful dream that there is. In our dream, we have limitless resources, and the people yield themselves with perfect docility to our molding hand.

Essay on rural education. Page 6, under the heading 'A Vision of the Remedy,' presents an avowed dream in which the board has limitless resources and rural people yield to its molding hand, and then describes a program of agricultural, domestic and civic training for rural children 'just where they are.' The sentence is often quoted without the words before it.

Source
General Education Board (author Frederick T. Gates)
Date
1916 printing (first issue commonly dated 1913)
Quoted from
Page 6, section 'A Vision of the Remedy' (OCR of the 1916 General Education Board printing)
Grade
Primary record
Document
https://archive.org/details/countryschoolof00gate
Accessed
2026-11-09
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Exhibit 878 · Court opinion

Associated Press v. Budowich, No. 1:25-cv-00532 (D.D.C.), Memorandum Order, Doc. 46

For that editorial choice, the White House sharply curtailed the AP's access to coveted, tightly controlled media events with the President.

Grants the Associated Press a preliminary injunction against White House officials' exclusion of the AP from the press pool and some limited-access events, on the finding that the exclusion was viewpoint-based after the AP kept using 'Gulf of Mexico.' The court stayed its own order through 13 April 2025; the D.C. Circuit later stayed the injunction in part (as reported).

Source
U.S. District Court for the District of Columbia (Judge Trevor N. McFadden)
Date
8 April 2025
Quoted from
Memorandum Order, p. 1
Grade
Primary record
Document
https://clearinghouse-umich-production.s3.amazonaws.com/media/doc/158396.pdf
Accessed
2026-11-09
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Note
Court's preliminary findings. The June 2025 D.C.

Exhibit 879 · Regulation

26 CFR 1.501(c)(4)-1, Civic organizations and local associations of employees

The promotion of social welfare does not include direct or indirect participation or intervention in political campaigns on behalf of or in opposition to any candidate for public office.

Defines a social welfare organization as one 'primarily engaged' in promoting the common good and excludes campaign intervention from the definition of social welfare. Read in the Cornell LII copy.

Source
U.S. Treasury Department (T.D. 6500, 1960; amended 1990)
Date
26 November 1960
Quoted from
26 CFR 1.501(c)(4)-1(a)(2)(ii)
Grade
Primary record
Document
https://www.ecfr.gov/current/title-26/section-1.501(c)(4)-1
Accessed
2026-11-10
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Exhibit 880 · Agency guidance page

Social welfare organizations (IRS page)

However, a section 501(c)(4) social welfare organization may engage in some political activities, so long as that is not its primary activity.

IRS statement that a 501(c)(4) may engage in some political activity if it is not the primary activity.

Source
Internal Revenue Service
Date
accessed 10 November 2026
Quoted from
Paragraph beginning 'The promotion of social welfare does not include'
Grade
Primary record
Document
https://www.irs.gov/charities-non-profits/other-non-profits/social-welfare-organizations
Accessed
2026-11-10
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Exhibit 881 · Agency audit guide

Audit Technique Guide: IRC Section 501(c)(4), Civic Leagues, Social Welfare Organizations, and Local Associations of Employees

an IRC 501(c)(4) organization may intervene in political campaigns without jeopardizing its exempt status if it’s primarily engaged in other activities which further the promotion of social welfare.

IRS examiner guide: a 501(c)(4) may intervene in campaigns if primarily engaged in other social welfare activity; cites Rev. Rul. 81-95.

Source
Internal Revenue Service
Date
undated PDF (accessed 10 November 2026)
Quoted from
p. 4 (PDF page 4)
Grade
Primary record
Document
https://www.irs.gov/pub/irs-tege/atg_501c4_orgs.pdf
Accessed
2026-11-10
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Exhibit 882 · Agency report

National Taxpayer Advocate 2014 Annual Report to Congress, Vol. 1, Legislative Recommendation 5: Section 501(c)(4) political campaign activity

There is no statutory or regulatory quantification of the term “primarily” for this purpose, nor is there a statutory or regulatory “safe harbor” for determining whether an IRC § 501(c)(4) organization’s political campaign activities are within permissible limits.

Recommends Congress enact an optional numerical safe harbor for 501(c)(4) campaign activity; states that no statute or regulation quantifies 'primarily'.

Source
Taxpayer Advocate Service (IRS)
Date
December 2014
Quoted from
Vol. 1, p. 325
Grade
Primary record
Document
https://www.taxpayeradvocate.irs.gov/wp-content/uploads/2020/08/2014-ARC_VOL-1_S2_LR-5-508.pdf
Accessed
2026-11-10
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Exhibit 883 · Statute

26 U.S.C. § 6104 (publicity of information required from certain exempt organizations)

In the case of an organization which is not a private foundation (within the meaning of section 509(a)) or a political organization exempt from taxation under section 527, paragraph (1) shall not require the disclosure of the name or address of any contributor to the organization.

Public-inspection rule that exempts non-private-foundation organizations other than section 527 organizations from disclosing contributor names or addresses.

Source
United States Congress
Date
as in force 2026
Quoted from
26 U.S.C. § 6104(d)(3)(A)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/26/6104
Accessed
2026-11-10
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Exhibit 884 · Revenue procedure

Rev. Proc. 2018-38 (Schedule B contributor reporting)

These organizations are no longer required to report the names and addresses of their contributors on the Schedule B of their Forms 990 or 990-EZ.

Ends the requirement that non-501(c)(3) exempt organizations report contributor names and addresses on Schedule B; they must keep the information and give it to the IRS on request. Effective for years ending on or after 31 December 2018.

Source
Internal Revenue Service
Date
July 2018 (2018-31 I.R.B. 280)
Quoted from
Section 1 (Purpose)
Grade
Primary record
Document
https://www.irs.gov/pub/irs-drop/rp-18-38.pdf
Accessed
2026-11-10
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Exhibit 885 · Final regulation

T.D. 9898, Guidance Under Section 6033 Regarding the Reporting Requirements of Exempt Organizations (85 FR 31959)

On July 30, 2019, the United States District Court for the District of Montana set aside Rev. Proc. 2018–38 on procedural grounds because, in the court’s view, the notice and comment procedures of the Administrative Procedure Act applied and Rev. Proc. 2018–38 had not been subject to such notice and comment.

Final regulations effective 28 May 2020. The preamble recounts that Bullock v. IRS, 401 F.Supp.3d 1144 (D. Mont. 30 Jul 2019) set aside Rev. Proc. 2018-38 on notice-and-comment grounds only, then the agencies re-adopted the relief by rule.

Source
Treasury Department / IRS
Date
28 May 2020
Quoted from
85 FR 31961, Background (PDF p. 3)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2020-05-28/pdf/2020-11465.pdf
Accessed
2026-11-10
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Exhibit 886 · Dataset record

Marble Freedom Trust Form 990 (FYE April 2021), public XML: Schedule B fields

RESTRICTED

In the IRS public XML (object 202240749349301569) every donor field of IRS990ScheduleB is released as the value RESTRICTED. The same appears in AFP (TY2016, TY2020-2024), DonorsTrust and other 990 XML files read.

Source
Internal Revenue Service (TEOS e-file XML)
Date
filed 2022
Quoted from
IRS990ScheduleB: ContributorNum, BusinessNameLine1, AddressLine1, TotalContributionsAmt
Grade
Primary record
Document
https://apps.irs.gov/pub/epostcard/990/xml/2022/2022_TEOS_XML_01A.zip
Accessed
2026-11-10
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Exhibit 887 · Proposed rule

Guidance for Tax-Exempt Social Welfare Organizations on Candidate-Related Political Activities (REG-134417-13), 78 FR 71535

These timeframes are the same as those appearing in the Federal Election Campaign Act definition of electioneering communications.

Proposed to define candidate-related political activity for 501(c)(4)s, including public communications naming a candidate within 60 days of a general or 30 days of a primary election, the same windows as the electioneering-communication definition.

Source
Treasury Department / IRS
Date
29 November 2013
Quoted from
78 FR 71539, Explanation of Provisions (PDF p. 5)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2013-11-29/pdf/2013-28492.pdf
Accessed
2026-11-10
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Exhibit 888 · Statute

Consolidated Appropriations Act, 2016, Pub. L. 114-113, sec. 127 (Financial Services and General Government)

none of the funds made available in this or any other Act may be used by the Department of the Treasury, including the Internal Revenue Service, to issue, revise, or finalize any regulation, revenue ruling, or other guidance not limited to a particular taxpayer relating to the standard which is used to determine whether an organization is operated exclusively for the promotion of social welfare for purposes of section 501(c)(4)

Bars Treasury and the IRS, for fiscal year 2016, from issuing guidance on the 501(c)(4) social welfare standard, names the 2013 proposed regulations, and freezes the standard in effect on 1 January 2010.

Source
United States Congress
Date
18 December 2015
Quoted from
Sec. 127(1)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-114publ113/html/PLAW-114publ113.htm
Accessed
2026-11-10
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Exhibit 889 · Inspector general audit

Inappropriate Criteria Were Used to Identify Tax-Exempt Applications for Review (2013-10-053)

The IRS used inappropriate criteria that identified for review Tea Party and other organizations applying for tax-exempt status based upon their names or policy positions instead of indications of potential political campaign intervention.

Found the IRS selected applications by names and policy positions (Tea Party, Patriots, 9/12). Of 296 potential political cases at 17 December 2012, 108 approved, 28 withdrawn, none denied, 160 open 206 to 1,138 days; some information requests asked for lists of past and future donors.

Source
Treasury Inspector General for Tax Administration
Date
14 May 2013
Quoted from
Highlights page (What TIGTA Found); Results of Review p. 5
Grade
Primary record
Document
https://web.archive.org/web/2013/http://www.treasury.gov/tigta/auditreports/2013reports/201310053fr.pdf
Accessed
2026-11-10
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Exhibit 890 · Inspector general letter

TIGTA letter to Rep. Sander Levin on the 'Progressives' BOLO entry

In total, 30 percent of the organizations we identified with the words “progress” or “progressive” in their names were processed as potential political cases.

TIGTA: 'Progressives' sat on the Historical BOLO tab without referral instructions; 6 of 20 applications with 'progress' or 'progressive' in their names (30 percent) were processed as potential political cases, against 100 percent for Tea Party, Patriots or 9/12 names.

Source
Treasury Inspector General for Tax Administration
Date
26 June 2013
Quoted from
p. 2
Grade
Primary record
Document
https://democrats-waysandmeans.house.gov/sites/evo-subsites/democrats-waysandmeans.house.gov/files/TIGTA%20Final%20Response%20to%20Rep.%20Levin%206.26.13.pdf
Accessed
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Exhibit 891 · Inspector general audit

Review of Selected Criteria Used to Identify Tax-Exempt Applications for Review (2017-10-054)

While most of the potentially political applications that the IRS set aside for heightened scrutiny were Tea Party and conservative groups, the IRS also flagged some left-leaning tax-exempt applicants for processing.

Audited 17 criteria from 259 used 2004-2013, including Progressive, Occupy, ACORN Successors and Emerge beside Rally Patriots, We the People and Healthcare Legislation. 146 case files reviewed (Progressive 61, ACORN Successors 14, Healthcare Legislation 16). Quotes the IRS July 2012 assessment of case names.

Source
Treasury Inspector General for Tax Administration
Date
28 September 2017
Quoted from
p. 2 (quoting S. Rept. 114-119); case table Figure 4, p. 10; Progressive criterion text pp. 77-78
Grade
Primary record
Document
https://www.tigta.gov/sites/default/files/reports/2022-02/201710054fr.pdf
Accessed
2026-11-10
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Exhibit 893 · Statute

52 U.S.C. § 30104 (reporting requirements), subsections (c) and (f)

Every person who makes a disbursement for the direct costs of producing and airing electioneering communications in an aggregate amount in excess of $10,000 during any calendar year shall, within 24 hours of each disclosure date, file with the Commission a statement containing the information described in paragraph (2).

Independent-expenditure statements by non-committees (over $250) and electioneering-communication statements (over $10,000; 60 days before a general, 30 before a primary; donors of $1,000 or more disclosed only if paid from a segregated account, or from the person's own funds for subparagraph F).

Source
United States Congress
Date
as in force 2026
Quoted from
52 U.S.C. § 30104(f)(1)
Grade
Primary record
Document
https://www.law.cornell.edu/uscode/text/52/30104
Accessed
2026-11-10
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Exhibit 894 · Court opinion

Citizens United v. Federal Election Commission, 558 U.S. 310

The First Amendment protects political speech; and disclosure permits citizens and shareholders to react to the speech of corporate entities in a proper way. This transparency enables the electorate to make informed decisions and give proper weight to different speakers and messages.

5-4 that corporations may make independent expenditures; 8-1 (Thomas dissenting in part) upholding BCRA disclaimer and disclosure requirements. Cornell syllabus lists the joins.

Source
U.S. Supreme Court
Date
21 January 2010
Quoted from
Part IV-B (reporter page not verified)
Grade
Primary record
Document
https://www.law.cornell.edu/supct/html/08-205.ZO.html
Accessed
2026-11-10
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Exhibit 895 · Court opinion

Citizens United v. FEC, independent expenditures and corruption

independent expenditures, including those made by corporations, do not give rise to corruption or the appearance of corruption.

Holding premise later used in SpeechNow.

Source
U.S. Supreme Court
Date
21 January 2010
Quoted from
Part III (reporter page not verified)
Grade
Primary record
Document
https://www.law.cornell.edu/supct/html/08-205.ZO.html
Accessed
2026-11-10
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Exhibit 896 · Court opinion

SpeechNow.org v. FEC, 599 F.3d 686 (D.C. Cir. en banc)

But the public has an interest in knowing who is speaking about a candidate and who is funding that speech, no matter whether the contributions were made towards administrative expenses or independent expenditures.

Contribution limits cannot apply to groups making only independent expenditures; registration and reporting requirements upheld. This created the super PAC.

Source
U.S. Court of Appeals for the D.C. Circuit
Date
26 March 2010
Quoted from
slip op. 20
Grade
Primary record
Document
https://media.cadc.uscourts.gov/opinions/docs/2010/03/08-5223-1236837.pdf
Accessed
2026-11-10
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Exhibit 897 · Court opinion

SpeechNow.org v. FEC, contribution-limit holding

In light of the Court’s holding as a matter of law that independent expenditures do not corrupt or create the appearance of quid pro quo corruption, contributions to groups that make only independent expenditures also cannot corrupt or create the appearance of corruption.

Same opinion, separate passage.

Source
U.S. Court of Appeals for the D.C. Circuit
Date
26 March 2010
Quoted from
slip op. 14
Grade
Primary record
Document
https://media.cadc.uscourts.gov/opinions/docs/2010/03/08-5223-1236837.pdf
Accessed
2026-11-10
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Exhibit 898 · Court opinion

Van Hollen v. FEC, Civil Action 11-0766 (ABJ), Memorandum Opinion

In sum, the Court finds that Congress spoke plainly, that Congress did not delegate authority to the FEC to narrow the disclosure requirement through agency rulemaking, and that a change in the reach of the statute brought about by a Supreme Court ruling did not render plain language, which is broad enough to cover the new circumstances, to be ambiguous.

Held 11 CFR 104.20(c)(9), limiting electioneering-communication donor disclosure to donors who gave for the purpose of furthering such communications, contrary to the unambiguous statute.

Source
U.S. District Court for D.C. (Judge Amy Berman Jackson)
Date
30 March 2012
Quoted from
Conclusion, p. 31
Grade
Primary record
Document
https://www.fec.gov/resources/legal-resources/litigation/van_hollen_dc_memo_opinion.pdf
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2026-11-10
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Exhibit 899 · Agency summary of court decision

FEC Record: Van Hollen v. FEC (Appeals court 2016)

In reversing the U.S. District Court for the District of Columbia's 2014 decision, the appellate court upheld the Commission regulation as a reasonable interpretation of the disclosure provisions of the Federal Election Campaign Act (FECA).

FEC summary: on 21 January 2016 the D.C. Circuit reversed the 2014 district court decision and upheld 11 CFR 104.20(c)(9). The circuit had also reversed on 18 September 2012.

Source
Federal Election Commission
Date
1 February 2016
Quoted from
paragraph 1
Grade
Primary record
Document
https://www.fec.gov/updates/van-hollen-v-fec-appeals-court
Accessed
2026-11-10
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Exhibit 900 · Court opinion

CREW v. FEC (Crossroads GPS intervenor), No. 16-259 (BAH), Memorandum Opinion, 316 F.Supp.3d 349

subsection (vi) of 11 C.F.R. § 109.10(e)(1) is declared invalid and therefore vacated, with the vacatur stayed for 45 days

Declared 11 CFR 109.10(e)(1)(vi) invalid (vacatur stayed 45 days) and the FEC's dismissal contrary to law. Records, undisputed by Crossroads GPS, that it reported over $17 million in 2012 independent expenditures without naming donors.

Source
U.S. District Court for D.C. (Chief Judge Howell)
Date
3 August 2018
Quoted from
p. 3 (PDF page 3)
Grade
Primary record
Document
https://www.fec.gov/resources/cms-content/documents/crew16259_dc_opinion2.pdf
Accessed
2026-11-10
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Exhibit 901 · Court opinion

Citizens for Responsibility and Ethics in Washington v. FEC, No. 18-5261, 971 F.3d 340

The Rule conflicts with the FECA’s unambiguous terms twice over.

Affirmed. The rule required disclosure only of donations earmarked to a particular independent expenditure.

Source
U.S. Court of Appeals for the D.C. Circuit
Date
21 August 2020
Quoted from
slip op. 19
Grade
Primary record
Document
https://www.fec.gov/resources/cms-content/documents/cgps_185261_ac_opinion.pdf
Accessed
2026-11-10
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Exhibit 902 · Enforcement record

MUR 6396, Crossroads GPS

The Commission failed by a vote of 3-3 to: a. Find reason to believe that Crossroads Grassroots Policy Strategies violated 2 U.S.C. §§ 432, 433, and 434.

Complainants Public Citizen and others. FEC failed 3-3 to find reason to believe Crossroads GPS violated 2 U.S.C. 432, 433, 434.

Source
Federal Election Commission
Date
certification 3 December 2013
Quoted from
MUR #6396 page, Summary > Disposition
Grade
Primary record
Document
https://www.fec.gov/data/legal/matter-under-review/6396/
Accessed
2026-11-10
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Exhibit 903 · Enforcement record

MUR 6696, Crossroads GPS (complainant CREW)

The Commission failed by a vote of 3-3 to: a. Find no reason to believe that Crossroads Grassroots Policy Strategies violated 52 U.S.C. § 30104(c)(2) and 11 C.F.R. § 109.10(e)(1)(vi).

3-3 deadlocks on reason to believe and on 11 CFR 109.10(e)(1)(vi); file closed 6-0.

Source
Federal Election Commission
Date
certifications 17 December 2015 and 28 August 2018
Quoted from
MUR #6696 page, Summary > Disposition
Grade
Primary record
Document
https://www.fec.gov/data/legal/matter-under-review/6696/
Accessed
2026-11-10
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Exhibit 904 · Enforcement record

MUR 6589, American Action Network (complainant CREW)

The Commission failed by a vote of 3-3 to: a. Find reason to believe that American Action Network violated 2 U.S.C. §§ 432, 433, and 434.

FEC failed 3-3 on reason to believe that AAN was a political committee; file closed 6-0.

Source
Federal Election Commission
Date
statement of reasons 19 October 2016
Quoted from
MUR #6589 page, Summary > Disposition
Grade
Primary record
Document
https://www.fec.gov/data/legal/matter-under-review/6589/
Accessed
2026-11-10
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Exhibit 905 · Agency summary of court decision

FEC Record: CREW v. FEC (16-2255 / 18-5136), American Action Network

On March 20, 2018, the U.S. District Court for the District of Columbia concluded that the Commission's dismissal of an administrative complaint Citizens for Responsibility and Ethics in Washington (CREW) filed against American Action Network (AAN) was contrary to law.

District court held the FEC's dismissal of the AAN complaint contrary to law and remanded. Summary recites the Buckley 'major purpose' limit.

Source
Federal Election Commission
Date
20 March 2018 decision
Quoted from
FEC court-case page, Summary, first paragraph
Grade
Primary record
Document
https://www.fec.gov/legal-resources/court-cases/crew-v-fec/
Accessed
2026-11-10
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Exhibit 906 · Enforcement record

MUR 7904, Hansjorg Wyss et al. (complainant Americans for Public Trust)

The Commission failed by a vote of 2-4 to dismiss as a matter of prosecutorial discretion the allegations that Hansjörg Wyss, the Wyss Foundation, the Berger Action Fund, Inc., the New Venture Fund, and the Sixteen Thirty Fund made foreign national contributions and contributions in the name of another.

Respondents: Wyss, Berger Action Fund, Wyss Foundation, New Venture Fund, Sixteen Thirty Fund. FEC voted 6-0 to dismiss political-committee-registration allegations; failed 3-3 on no reason to believe and 2-4 on dismissal for the foreign-national and name-of-another allegations.

Source
Federal Election Commission
Date
certification 28 July 2022
Quoted from
MUR #7904 page, Summary > Disposition
Grade
Primary record
Document
https://www.fec.gov/data/legal/matter-under-review/7904/
Accessed
2026-11-10
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Exhibit 907 · Roll call vote

Senate roll call 220, S. 3628 (DISCLOSE Act), cloture on motion to proceed

Cloture Motion Rejected (57-41, 3/5 majority required)

Rejected 57-41. Democrats 56 yea 1 nay; independents 1 yea; Republicans 40 nay (1 not voting). Party counts tabulated from the vote XML member records.

Source
U.S. Senate (Secretary of the Senate roll call data)
Date
27 July 2010
Quoted from
roll call XML, element vote_result_text
Grade
Primary record
Document
https://www.senate.gov/legislative/LIS/roll_call_votes/vote1112/vote_111_2_00220.xml
Accessed
2026-11-10
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Exhibit 908 · Roll call vote

Senate roll call 240, S. 3628, cloture on reconsideration

Cloture Motion Rejected (59-39, 3/5 majority required)

Rejected 59-39. All Democrats and independents voting yea; 39 Republicans nay (2 not voting). Party counts tabulated from the vote XML member records.

Source
U.S. Senate (Secretary of the Senate roll call data)
Date
23 September 2010
Quoted from
roll call XML, element vote_result_text
Grade
Primary record
Document
https://www.senate.gov/legislative/LIS/roll_call_votes/vote1112/vote_111_2_00240.xml
Accessed
2026-11-10
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Exhibit 909 · Roll call vote

Senate roll call 179, S. 3369 (DISCLOSE Act of 2012), cloture on motion to proceed

Cloture on the Motion to Proceed Rejected (51-44, 3/5 majority required)

Rejected 51-44. Democrats 49 yea 1 nay (1 not voting); independents 2 yea; Republicans 43 nay (4 not voting). Party counts tabulated from the vote XML member records.

Source
U.S. Senate (Secretary of the Senate roll call data)
Date
16 July 2012
Quoted from
roll call XML, element vote_result_text
Grade
Primary record
Document
https://www.senate.gov/legislative/LIS/roll_call_votes/vote1122/vote_112_2_00179.xml
Accessed
2026-11-10
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Exhibit 910 · Roll call vote

Senate roll call 180, S. 3369, cloture on reconsideration

Cloture on the Motion to Proceed Rejected (53-45, 3/5 majority required)

Rejected 53-45. All Democrats and independents voting yea; 45 Republicans nay (2 not voting). Party counts tabulated from the vote XML member records.

Source
U.S. Senate (Secretary of the Senate roll call data)
Date
17 July 2012
Quoted from
roll call XML, element vote_result_text
Grade
Primary record
Document
https://www.senate.gov/legislative/LIS/roll_call_votes/vote1122/vote_112_2_00180.xml
Accessed
2026-11-10
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Exhibit 911 · Roll call vote

Senate roll call 346, S. 4822 (DISCLOSE Act of 2022), cloture on motion to proceed

Cloture Motion Rejected (49-49, 3/5 majority required)

Rejected 49-49 (60 required). Democrats 47 yea (1 not voting); independents 2 yea; Republicans 49 nay (1 not voting). Party counts tabulated from the vote XML member records.

Source
U.S. Senate (Secretary of the Senate roll call data)
Date
22 September 2022
Quoted from
roll call XML, element vote_result_text
Grade
Primary record
Document
https://www.senate.gov/legislative/LIS/roll_call_votes/vote1172/vote_117_2_00346.xml
Accessed
2026-11-10
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Exhibit 912 · Floor statement

Congressional Record, 16 July 2012, S4985-S4988 (Sen. McConnell on the DISCLOSE Act)

After Citizens United, Democrats realized they could not shut up their critics so they decided to go after the microphone instead by trying to scare off the funders.

Minority leader's stated reasons for opposing S. 3369: privacy and harassment of donors, union exemption, and prioritization.

Source
U.S. Senate
Date
16 July 2012
Quoted from
S4987
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/CREC-2012-07-16/html/CREC-2012-07-16-pt1-PgS4985-8.htm
Accessed
2026-11-10
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Exhibit 913 · Floor statement

Congressional Record, 16 July 2012, S5003 et seq. (Sen. Schumer on the DISCLOSE Act)

I hope my colleagues will join us in this modest measure, which doesn't even limit how much people can give but simply says they have to disclose; they have to tell they are giving.

Majority sponsor's stated reasons for S. 3369.

Source
U.S. Senate
Date
16 July 2012
Quoted from
S5003-S5044 (speech preceding Merkley remarks)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/CREC-2012-07-16/html/CREC-2012-07-16-pt1-PgS5003-3.htm
Accessed
2026-11-10
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Exhibit 914 · Court opinion

NAACP v. Alabama ex rel. Patterson, 357 U.S. 449

Inviolability of privacy in group association may in many circumstances be indispensable to preservation of freedom of association, particularly where a group espouses dissident beliefs.

Unanimous Court (Harlan) held that compelled production of NAACP membership lists violated members' freedom of association on an uncontroverted showing of past reprisals.

Source
U.S. Supreme Court
Date
30 June 1958
Quoted from
357 U.S. at 462
Grade
Primary record
Document
https://www.law.cornell.edu/supremecourt/text/357/449
Accessed
2026-11-10
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Exhibit 915 · Court opinion

NAACP v. Alabama, showing of reprisal

Petitioner has made an uncontroverted showing that on past occasions revelation of the identity of its rank-and-file members has exposed these members to economic reprisal, loss of employment, threat of physical coercion, and other manifestations of public hostility.

Same opinion, evidentiary basis.

Source
U.S. Supreme Court
Date
30 June 1958
Quoted from
357 U.S. at 462
Grade
Primary record
Document
https://www.law.cornell.edu/supremecourt/text/357/449
Accessed
2026-11-10
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Exhibit 916 · Court opinion

Americans for Prosperity Foundation v. Bonta, 594 U.S. ___ (No. 19-251)

California casts a dragnet for sensitive donor information from tens of thousands of charities each year

Chief Justice Roberts for the Court (6-3 on the judgment): California's demand for charities' Schedule Bs is facially invalid because not narrowly tailored; exacting scrutiny requires narrow tailoring but not the least restrictive means. Involved 501(c)(3) charities and state collection, not federal campaign disclosure.

Source
U.S. Supreme Court
Date
1 July 2021
Quoted from
slip op. 14
Grade
Primary record
Document
https://www.supremecourt.gov/opinions/20pdf/19-251_p86b.pdf
Accessed
2026-11-10
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Exhibit 917 · Court opinion

Americans for Prosperity Foundation v. Bonta, Sotomayor dissent

Today, the Court holds that reporting and disclosure requirements must be narrowly tailored even if a plaintiff demonstrates no burden at all.

Dissent of Justices Sotomayor, Breyer, Kagan.

Source
U.S. Supreme Court
Date
1 July 2021
Quoted from
Sotomayor, J., dissenting, first paragraph
Grade
Primary record
Document
https://www.supremecourt.gov/opinions/20pdf/19-251_p86b.pdf
Accessed
2026-11-10
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Exhibit 918 · Dataset

Dataset: FEC independent expenditures 2012-2024 by committee type and benefiting party

Source: independent_expenditure_YYYY.csv and cmYY.zip (committee master) from fec.gov bulk downloads. Dedupe by spe_id+tran_id keeping highest file_num; exclude spe_ids not in the committee master and rows of $100M or more (hoax filings: Committee of 300, Spirit of Reforming America, others). Possible residual double counting about 1-3 percent. Saved copy and sha256 in research/politics/money-without-names.fec-run.json.

Source
Lacuna derivation from FEC bulk files
Date
run 10 November 2026
Grade
Primary record
Document
https://www.fec.gov/data/browse-data/?tab=bulk-data
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Saved summary: research/politics/money-without-names.fec-run.json (sha256 2841ae3b6feed3453281622a96712ff4e2236e9c0fdd55870d818a0ba9986d46). The url is the FEC bulk-data landing page, not a document.

Exhibit 919 · Dataset

Dataset: FEC contributions by organizations to super PACs 2012-2024, matched to IRS EO BMF

Source: indivYY.zip filtered to entity_tp ORG or single gifts of $1M+; recipients committee types O, V, W; donor names normalized and matched to IRS EO BMF (eo1-eo4.csv). Match is by name only and is approximate; paired-c4 totals use exact organization names.

Source
Lacuna derivation from FEC bulk files and IRS EO BMF
Date
run 10 November 2026
Grade
Primary record
Document
https://www.fec.gov/data/browse-data/?tab=bulk-data
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Saved summary: research/politics/money-without-names.fec-run.json (sha256 2841ae3b6feed3453281622a96712ff4e2236e9c0fdd55870d818a0ba9986d46). The url is the FEC bulk-data landing page, not a document.

Exhibit 920 · Dataset

Dataset: IRS Form 990 e-file XML, 26 organizations, tax years 2015-2024

171 returns extracted by object ID from IRS public zips (index_YYYY.csv); fields: total revenue, contributions, total expenses, Schedule C political expenditures (PoliticalExpendituresAmt), Schedule I grants. Table saved in research/politics/money-without-names.990-run.csv (sha256 9b2af6c8d504773e53d7ce4f3d6e576ccf8d90eacb5a89932c003c197067912c).

Source
Lacuna derivation from IRS TEOS XML
Date
run 10 November 2026
Grade
Primary record
Document
https://apps.irs.gov/pub/epostcard/990/xml/2025/
Accessed
2026-11-10
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Findings citing this exhibit
Note
One return per organization per tax period, highest object id kept. The url is the IRS public XML directory.

Exhibit 921 · Form 990

Marble Freedom Trust Form 990, fiscal year ended April 2021

To maintain and expand human freedom consistent with the values and ideals set forth in the Declaration of Independence and the Constitution of the United States.

Total contributions $1,603,791,362; grants $228.6M (Rule of Law Trust $153.0M, DonorsTrust $41.1M, Schwab Charitable $18.0M, Concord Fund $16.5M). Part VII: Leonard Leo, Trustee and Chairman. Mission statement quoted in filing.

Source
Marble Freedom Trust / IRS TEOS
Date
filed 2022
Quoted from
Form 990 Part I, MissionDesc; zip member 2022Redo_cycle01_41/202240749349301569_public.xml (read by HTTP range request)
Grade
Primary record
Document
https://apps.irs.gov/pub/epostcard/990/xml/2022/2022_TEOS_XML_01A.zip
Accessed
2026-11-10
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Exhibit 922 · Advocacy research report

Dark Money Hit a Record High of $1.9 Billion in 2024 Federal Races (Anna Massoglia)

The term dark money as used in this analysis refers to election spending and contributions by nonprofits and shell companies that are not legally required to — and do not — disclose the identities of their donors.

Publishes method: FEC data, Wesleyan Media Project TV data and platform ad archives; $1.9 billion in 2024, $1 billion in 2020, at least $4.3 billion since 2010; $1.3 billion to super PACs; Democratic-benefiting about $1.2 billion, Republican about $664 million.

Source
Brennan Center for Justice
Date
7 May 2025
Quoted from
section Types of Dark Money Spending
Grade
Reported
Document
https://www.brennancenter.org/our-work/research-reports/dark-money-hit-record-high-19-billion-2024-federal-races
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Advocacy-organization tally with a published method (FEC data, Wesleyan Media Project television data, platform ad archives, shell-company classification). The television, online and shell-company components were not re-derived. The primary replacement is the underlying FEC, Wesleyan Media Project and platform-archive records.

Exhibit 923 · Journalism

How a Secretive Billionaire Handed His Fortune to the Architect of the Right-Wing Takeover of the Courts

In a statement to the Times, Leo said it was “high time for the conservative movement to be among the ranks of George Soros, Hansjörg Wyss, Arabella Advisors and other left-wing philanthropists, going toe-to-toe in the fight to defend our constitution and its ideals.”

Reports that Barre Seid gave $1.6 billion to Marble Freedom Trust, first reported by The New York Times; reports Leo's statement to the Times. Donor identity is not in the 990. Primary replacement: none public; the 990 states only the amount.

Source
ProPublica and The Lever
Date
22 August 2022
Quoted from
paragraph beginning 'Seid has left his legacy'
Grade
Reported
Document
https://www.propublica.org/article/dark-money-leonard-leo-barre-seid
Accessed
2026-11-10
Cited by
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Note
The Marble Freedom Trust Form 990 states the amount and names no donor, so the donor identity is known only through journalism. No public primary document replaces it.

Exhibit 924 · Journalism

Group steers Swiss billionaire's money to liberal causes (Brian Slodysko)

“Nearly all of the donations we receive are intended for specific projects or purposes; many donations cannot be used for electoral activities; and every contribution is used in compliance with all guidelines, regulations, and laws,” Amy Kurtz, the president of Sixteen Thirty Fund, said in a statement.

Reports Berger Action Fund gave $72 million in 2021 and $339 million since 2016, and that Sixteen Thirty Fund and New Venture Fund received $245 million from Wyss's groups since 2016 ($208 million to Sixteen Thirty). Primary replacement: Berger Action Fund Form 990 Schedule I attachments (not in IRS XML).

Source
Associated Press
Date
3 April 2023
Quoted from
paragraph beginning 'The New Venture Fund is set up'
Grade
Reported
Document
https://www.clickondetroit.com/news/politics/2023/04/03/group-steers-swiss-billionaires-money-to-liberal-causes/
Accessed
2026-11-10
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Exhibit 925 · Inspector general report

What We Need to Learn: Lessons from Twenty Years of Afghanistan Reconstruction (SIGAR 21-46-LL)

Enormous pressure to demonstrate progress to the Congress and the American and Afghan people distorted accountability systems into spin machines.

The Lessons Learned Program's capstone report on 20 years and more than $145 billion of U.S. reconstruction in Afghanistan. It states that SIGAR reviewed the public statements of senior State and Defense officials from 2011 to 2021 and found claims of imminent progress. It also finds that pressure to show progress turned accountability systems into 'spin machines.'

Source
Special Inspector General for Afghanistan Reconstruction (SIGAR)
Date
August 2021
Quoted from
Chapter 3 (Timelines), p. 32; the review of officials' public statements is at p. 18 (Chapter 2, Strategy). Read from the Wayback Machine capture of the sigar.mil PDF (the sigar.mil host did not resolve on 2026-11-10).
Grade
Primary record
Document
https://www.sigar.mil/pdf/lessonslearned/SIGAR-21-46-LL.pdf
Accessed
2026-11-10
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Exhibit 926 · National Security Council meeting record (FRUS document)

Memorandum Prepared by Boggs, 5 January 1961: Discussion at the 473rd Meeting of the National Security Council (FRUS 1961-1963, Vols. VII-IX, Microfiche Supplement, Doc. 226)

He had suffered an eight-year defeat on this question but would leave a legacy of ashes for his successor.

Marion Boggs's Top Secret record of the 473rd NSC meeting. In item 1, on whether to amend the NSC intelligence directives to give the Secretary of Defense authority over military intelligence, Eisenhower says he lost an eight-year fight over the question. A separate excerpt of the same meeting on Laos is printed as FRUS 1961-1963, vol. XXIV, Doc. 3, which does not contain the remark.

Source
U.S. Department of State, Office of the Historian (Foreign Relations of the United States); source: Eisenhower Library, Whitman File, NSC Records
Date
5 January 1961
Quoted from
Doc. 226, item 1 (NSC Intelligence Directives), Facsimile p. 4 / typeset p. 647
Grade
Primary record
Document
https://history.state.gov/historicaldocuments/frus1961-63v07-09mSupp/d226
Accessed
2026-11-10
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Exhibit 927 · Congressional report

Alleged Assassination Plots Involving Foreign Leaders: An Interim Report of the Select Committee to Study Governmental Operations with Respect to Intelligence Activities, S. Rep. No. 94-465

However, the record is unclear and serious doubt remains concerning whether assassination was authorized by the respective Presidents.

The Committee's findings on CIA plots against Castro, Lumumba, Trujillo, Diem, Schneider and others. It reports that the working papers of the CIA's 1967 internal study of the plots were destroyed on Director Helms's instructions, and that the evidence leaves unclear whether Presidents authorized assassination. It finds that the system of plausible denial left the level of authorization uncertain.

Source
United States Senate, Select Committee to Study Governmental Operations with Respect to Intelligence Activities (Church Committee)
Date
20 November 1975
Quoted from
Part IV.C, Findings and Conclusions Relating to Authorization and Control, p. 260; destroyed working papers at Introduction, p. 3
Grade
Primary record
Document
https://www.intelligence.senate.gov/sites/default/files/94465.pdf
Accessed
2026-11-10
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Exhibit 928 · Press conference transcript

Press Conference with Secretary Gates and Adm. Mullen on Leadership Changes in Afghanistan From the Pentagon

I would say, nothing went wrong, and there was nothing specific. It is -- it simply was my conviction, based on my consultations with Admiral Mullen and General Petraeus, that a fresh approach, a fresh look in the context of the new strategy, probably was in our best interest.

Gates announces that he asked for General David McKiernan's resignation as commander in Afghanistan and recommends Lieutenant General Stanley McChrystal as his replacement. Asked what McKiernan had done wrong, Gates says nothing went wrong and nothing specific prompted the decision. He gives the reason as a need for a fresh approach under the new strategy.

Source
U.S. Department of Defense (Office of the Assistant Secretary of Defense for Public Affairs)
Date
11 May 2009
Quoted from
Gates, answer to the reporter's question on what McKiernan did not do (Wayback capture of the defense.gov transcript, TranscriptID=4424)
Grade
Primary record
Document
https://web.archive.org/web/2009/http://www.defense.gov/transcripts/transcript.aspx?transcriptid=4424
Accessed
2026-11-10
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Exhibit 929 · Internal memorandum (snowflake)

Snowflake, Donald Rumsfeld to Steve Cambone, 8 September 2003 (11-L-0559/OSD/18828)

I have no visibility into who the bad guys are in Afghanistan or Iraq. I read all the intel from the community and it sounds as thought we know a great deal but in fact, when you push at it, you find out we haven't got anything that is actionable.

One-page memo from the Secretary of Defense to the Under Secretary for Intelligence, released by DoD in the Rumsfeld snowflakes FOIA litigation and posted by the National Security Archive. Rumsfeld writes that he cannot tell who the enemy is in Afghanistan or Iraq and that the intelligence community has nothing actionable. He calls the department woefully deficient in human intelligence. A handwritten note shows a response attached on 15 September.

Source
U.S. Department of Defense, Office of the Secretary of Defense
Date
8 September 2003
Quoted from
Body text, Bates 11-L-0559/OSD/18828 (read from the page image; National Security Archive page: nsarchive.gwu.edu/media/24553). The DoD's own Seventh Release PDF on esd.whs.mil returned 403 on 2026-11-10.
Grade
Primary record
Document
https://nsarchive.gwu.edu/sites/default/files/documents/qy3fic-cl4be/08.pdf
Accessed
2026-11-10
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Exhibit 930 · Congressional report

Committee Study of the Central Intelligence Agency's Detention and Interrogation Program: Foreword, Findings and Conclusions, and Executive Summary, S. Rpt. 113-288

a proposal from Senator Carl Levin to establish an independent commission to investigate U.S. detention policies and allegations of detainee abuse resulted in concern at the CIA that such a commission would lead to the discovery of videotapes documenting CIA interrogations. That concern prompted renewed interest at the CIA to destroy the videotapes.

The declassified executive summary of the Committee's study of the CIA program, with the Chairman's foreword and findings. It records that the study grew out of an investigation into the CIA's 2005 destruction of the interrogation videotapes. Section E on pages 443 and 444 states that Senator Levin's proposal for an independent commission prompted CIA concern that a commission would discover the videotapes, that the concern prompted renewed interest in destroying them, that Levin's amendment failed on 8 November 2005, and that the CIA destroyed the tapes the next day. Footnote 2488 quotes a CIA email of 31 October 2005 and a senior CIA attorney's reply. The CIA's proposed redactions to the public text are described in footnote 6 on page 10.

Source
United States Senate, Select Committee on Intelligence
Date
9 December 2014
Quoted from
Executive Summary, Findings and Conclusions, section E, p. 443 (of 499); the sentence dating the destruction is at p. 444: "Senator Levin's amendment to establish the commission failed on November 8, 2005. The CIA destroyed the CIA interrogation videotapes the following day."
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/CRPT-113srpt288/pdf/CRPT-113srpt288.pdf
Accessed
2026-11-10
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Exhibit 931 · Agency report

2025 Dietary Guidelines Advisory Committee Disclosures

When more than one member reported a relationship with the same entity, the total number of members with that relationship is noted in parentheses.

Four-page collective disclosure for the 2025 Dietary Guidelines Advisory Committee. It lists every entity with which any member reported a grant, contract, consulting or other relationship in the past 12 months, by category. Entities named include the Egg Nutrition Center, Eli Lilly, Mars Symbioscience, the National Cattlemen's Beef Association and Novo Nordisk. The list does not attribute any entry to an individual member.

Source
U.S. Department of Health and Human Services and U.S. Department of Agriculture (dietaryguidelines.gov)
Date
April 2023 (entries last updated 13 March 2023)
Quoted from
p. 1, second paragraph
Grade
Primary record
Document
https://www.dietaryguidelines.gov/sites/default/files/2023-04/2025_DGAC_Disclosures.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Sen. Grassley's release of 25 May 2023 describes this as the 'four page report' HHS released after his March 2023 letter. The PDF was created 13 April 2023, so it preceded the 25 May release by about six weeks.

Exhibit 932 · Press release

Grassley Calls on Nutrition Advisory Committee to Halt Dietary Recommendations Until Conflicts of Interest Are Resolved (press release)

these disclosures were aggregated and not attributed to individual committee members.

Grassley asks Agriculture Secretary Vilsack and HHS Secretary Becerra to release the 2025 DGAC members' OGE 450 reports and to suspend writing recommendations until the committee follows NASEM's 2017 recommendations. The release says HHS had published a four-page report of disclosures that was aggregated and not attributed to individual members. It reproduces the letter of the same date.

Source
Sen. Charles E. Grassley
Date
25 May 2023
Quoted from
paragraph 3
Grade
Primary record
Document
https://www.grassley.senate.gov/news/news-releases/grassley-calls-on-nutrition-advisory-committee-to-halt-dietary-recommendations-until-conflicts-of-interest-are-resolved
Accessed
2026-11-10
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Findings citing this exhibit
Note
Read from a Wayback Machine capture; the Senate site returned HTTP 403 to automated requests.

Exhibit 933 · Congressional letter

Letter, Sen. Grassley to Secretaries Becerra and Vilsack on the 2025 Dietary Guidelines Advisory Committee

Conflicts are specific to individual committee members, and information on these individual conflicts is needed to determine their significance.

Requests that DGAC suspend writing recommendations until it complies with NASEM's 2017 report, and again asks for the members' OGE 450 forms and any ethics waivers. The letter says the departments' link aggregates conflicts and that the Privacy Act and Ethics in Government Act do not restrict congressional oversight. It sets a response date of 8 June 2023.

Source
Sen. Charles E. Grassley
Date
25 May 2023
Quoted from
p. 1, paragraph 2
Grade
Primary record
Document
https://www.grassley.senate.gov/download/grassley-to-usda-hhs_-dgac-follow-up?download=1
Accessed
2026-11-10
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Findings citing this exhibit

Exhibit 934 · Agency statement

Ethics Review of Appointees to the Dietary Guidelines Advisory Committee (USDA Office of Ethics statement)

none of the 20 committee members reported any entries on their OGE Form 450 that would prevent them from being appointed

One-page memorandum from a USDA Office of Ethics deputy director. It says each of the 20 appointees to the 2020 DGAC filed an OGE Form 450, which he reviewed for conflicts and impartiality concerns. He concludes that no member reported entries that would prevent appointment under the rules for special government employees.

Source
USDA Office of Ethics
Date
1 March 2019
Quoted from
p. 1
Grade
Primary record
Document
https://www.dietaryguidelines.gov/sites/default/files/2019-03/DGAC%202020%20OE%20Review%20Statement.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Linked as 'see letter' from the dietaryguidelines.gov question-and-answer page. The OGE 450 forms themselves are confidential and are not part of the record.

Exhibit 935 · Agency web page

Dietary Guidelines for Americans: Most Popular Questions (2020 Advisory Committee process and ethics review)

All individuals considered to serve as members of the Advisory Committee completed a Confidential Financial Disclosure Report (the OGE Form 450) prior to being appointed

The departments' answer to how the 2020 Advisory Committee was established: staff review of nomination packages, evaluation by agency leadership, vetting by the USDA Office of the Secretary, and review by the USDA Office of Ethics. It states that every candidate filed an OGE Form 450 before appointment and that members receive ethics training annually.

Source
U.S. Department of Agriculture and U.S. Department of Health and Human Services (dietaryguidelines.gov)
Date
Archived 18 December 2020 (page undated)
Quoted from
Answer to 'What was the process USDA and HHS used to establish the Advisory Committee?'
Grade
Primary record
Document
https://web.archive.org/web/20201218013440/https://www.dietaryguidelines.gov/most-popular-questions
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The URL is an archived copy; the issuer's original address is no longer the working copy. The capture date is the only date available.

Exhibit 936 · Agency web page

Federal Reserve Board: Overview: Federal Reserve System Boards of Directors

Also by statute, Class B and A directors are elected by the member banks in their respective Federal Reserve District.

The Board's description of Reserve Bank governance: each Bank has a nine-member board in three classes of three. The Board of Governors appoints the Class C directors and designates the chair and deputy chair from among them. Member banks in the District elect the Class A directors, who represent the banks, and the Class B directors, who represent the public. Terms are three years.

Source
Board of Governors of the Federal Reserve System
Date
Last updated 5 January 2024 (page opened 10 November 2026)
Quoted from
Structure and Composition, Reserve Bank Boards
Grade
Primary record
Document
https://www.federalreserve.gov/aboutthefed/directors/about.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 937 · Agency report

Roles and Responsibilities of Federal Reserve Directors

Six of the directors are elected by the member banks of the respective Federal Reserve District (District), and three of the directors are appointed by the Board of Governors.

The Board's 52-page publication for directors. Figure 1 shows Class A and B directors elected by member banks and Class C directors appointed by the Board. The Selection Criteria section says Class A directors represent the member banks, and Class B and C directors represent the public. It states that Class A directors face no statutory or policy bar on affiliation with supervised institutions.

Source
Board of Governors of the Federal Reserve System
Date
February 2013
Quoted from
Introduction, p. 1 (PDF p. 7)
Grade
Primary record
Document
https://www.federalreserve.gov/aboutthefed/directors/pdf/roles_responsibilities_FINALweb013013.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read from a Wayback Machine capture of the Board's PDF; the Board's own server did not respond. The Board's overview page (fed-2024-board-reserve-bank-directors-overview) links to this publication as current.

Exhibit 938 · Correspondence

CDC/ATSDR final response to FOIA request #20-02002-FOIA for documents comparing health outcomes of vaccinated and unvaccinated children

The CDC has not conducted a study of health outcomes in vaccinated vs unvaccinated populations.

The CDC FOIA officer answers a request from counsel for the Informed Consent Action Network, dated 13 July 2020, for all CDC documents comparing health outcomes of children who received vaccines with children who never received any. The search found no responsive documents. The letter states that the CDC has not conducted a study of health outcomes in vaccinated versus unvaccinated populations.

Source
Centers for Disease Control and Prevention (CDC/ATSDR FOIA Office)
Date
29 July 2020
Quoted from
Letter of 29 July 2020, p. 1, second paragraph
Grade
Primary record
Document
https://icandecide.org/wp-content/uploads/2020/08/2020_08_03-20-02002-Final-Response-No-Records1.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The letter is dated 29 July 2020 on its face and carries file number 20-02002-FOIA; the ICAN-hosted PDF is named 2020_08_03 and ICAN's article gives 3 August 2020 for the response. ICAN's article places the original submission on 26 June 2020 and the narrowed wording on 13 July 2020. No copy on a CDC or court site was found; the copy is the one ICAN published.

Exhibit 939 · Court opinion

Freedom Coalition of Doctors for Choice v. Centers for Disease Control and Prevention, No. 2:23-cv-00102-Z (N.D. Tex.), memorandum order and opinion (ECF No. 40) on V-safe free-text responses

Defendants are ORDERED to produce all free-text responses, together with the registrant number, redacted personal identifying information as described in this Order, on or before January 15, 2025;

Grants the plaintiff summary judgment in a FOIA suit for about 7.8 million V-safe free-text responses, each limited to 250 characters, and denies the CDC's cross-motion. Orders production of all responses with personal identifiers redacted by 15 January 2025, on a first-in, first-out basis, at a minimum of 390,000 responses by 15 February 2024 rising to 780,000 per month from 15 August 2024. Requires quarterly joint status reports and allows the CDC to bank responses processed above its monthly quota.

Source
U.S. District Court, Northern District of Texas (Amarillo Division), Judge Matthew J. Kacsmaryk
Date
5 January 2024
Quoted from
ECF No. 40, Conclusion, p. 29
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/USCOURTS-txnd-2_23-cv-00102/pdf/USCOURTS-txnd-2_23-cv-00102-0.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Production schedule (term minimum, cumulative): 15 Feb 2024, 390,000; 15 Mar, 390,000 (780,000); 15 Apr, 390,000 (1,170,000); 15 May, 650,000 (1,820,000); 15 Jun, 650,000 (2,470,000); 15 Jul, 650,000 (3,120,000); 15 Aug, 780,000 (3,900,000); then 780,000 on the 15th of each month through 15 Jan 2025 (7,800,000). Copy from GovInfo (U.S. Government Publishing Office).

Exhibit 940 · Agency protocol

V-safe active surveillance for COVID-19 vaccine safety, protocol version 5

The purpose of v-safe surveillance is to rapidly characterize the safety profile of COVID-19 vaccines when given outside a clinical trial setting and to detect and evaluate clinically important adverse events and safety issues that might impact policy or regulatory decisions.

Protocol for V-safe, the CDC's smartphone-based system of text-message-initiated web surveys that follow vaccine recipients after vaccination, with telephone follow-up through the VAERS call center for medically attended events. It states the program's purpose and lists its limits: enrollment depends on providers and recipients, participants may differ from non-participants, vaccine type is self-reported, late enrollers may be a mixed group, and 3-, 6- and 12-month reports may suffer recall bias. It also states that a final deidentified aggregate data set would be made available through external requests or FOIA.

Source
Centers for Disease Control and Prevention
Date
18 April 2022
Quoted from
Protocol summary, p. 5 (limits at pp. 14-15)
Grade
Primary record
Document
https://web.archive.org/web/20220817233556/https://www.cdc.gov/vaccinesafety/pdf/V-safe-Protocol-V5-508.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Version 5 is the version the court cites in ECF No. 40 (item nd-tex-2024-freedom-coalition-v-cdc-vsafe-order). The cdc.gov URL is not reachable by automated fetch; the Wayback Machine capture of the CDC PDF is the copy read (the capture ends before the final attachments).

Exhibit 941 · Peer-reviewed study

Menstrual irregularities and vaginal bleeding after COVID-19 vaccination reported to v-safe active surveillance, USA in December, 2020-January, 2022: an observational cohort study

Reports of heterogeneous symptoms related to menstruation or vaginal bleeding after COVID-19 vaccination are being submitted to v-safe, although this study is unable to characterise the relationship of these symptoms to COVID-19 vaccination.

CDC authors apply a pretrained natural language inference model to V-safe free-text comments from 14 December 2020 to 9 January 2022. Among 5,975,363 female respondents aged 18 and older, 62,679 (1.0%) reported menstrual irregularities or vaginal bleeding, and respondents reporting menopausal bleeding were more likely to seek health care. The paper states that V-safe data cannot show whether the symptoms occur above baseline rates or are caused by vaccination.

Source
Wong KK, Heilig CM, Hause A, Myers TR, Olson CK, Gee J, Marquez P, Strid P, Shay DK (CDC COVID-19 Response Team); The Lancet Digital Health 4(9):e667-e675
Date
August 2022 (online 9 August 2022)
Quoted from
Summary, Interpretation
Grade
Peer-reviewed
Document
https://doi.org/10.1016/S2589-7500(22)00125-X
Accessed
2026-11-10
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Findings citing this exhibit
Note
Open access via PubMed Central (PMC9363036; PMID 35961858). The paper analyzes the V-safe free-text field; it is the only Lancet Digital Health 2022 paper with Wong as author found in a PubMed search on v-safe.

Exhibit 942 · Inspector general report

The National Institutes of Health and EcoHealth Alliance Did Not Effectively Monitor Awards and Subawards, Resulting in Missed Opportunities to Oversee Research and Other Deficiencies (A-05-21-00025)

NIH did not effectively monitor or take timely action to address EcoHealth’s compliance with some requirements.

Audit of three NIH awards to EcoHealth Alliance totaling about $8.0 million, including $1.8 million in EcoHealth subawards to eight subrecipients such as the Wuhan Institute of Virology. OIG found that NIH acted on a progress report nearly two years late, that EcoHealth did not publicly report required subaward data, and that EcoHealth claimed $89,171 in unallowable costs. It also found that the Wuhan Institute's lack of cooperation after the COVID-19 outbreak limited EcoHealth's monitoring.

Source
U.S. Department of Health and Human Services, Office of Inspector General
Date
January 2023
Quoted from
Report in Brief, What OIG Found
Grade
Primary record
Document
https://oig.hhs.gov/oas/reports/region5/52100025.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 943 · Court order

Public Health and Medical Professionals for Transparency v. Food and Drug Administration, No. 4:21-cv-1058-P (N.D. Tex.), order on the production schedule (ECF No. 35)

Accordingly, the Court concludes that this FOIA request is of paramount public importance.

Order in a FOIA suit for the data and information the FDA holds on the Pfizer vaccine under 21 C.F.R. 601.51(e), issued after the parties filed competing production schedules. The court finds the request of paramount public importance and orders the FDA to produce the more than 12,000 pages from its own proposal by 31 January 2022, then the remaining records at 55,000 pages every 30 days beginning 1 March 2022. It requires redacted versions of records withheld under any exemption and joint status reports from 1 April 2022 and every 90 days after.

Source
U.S. District Court, Northern District of Texas (Fort Worth Division), Judge Mark T. Pittman
Date
6 January 2022
Quoted from
ECF No. 35, p. 3
Grade
Primary record
Document
https://web.archive.org/web/20220120040058/https://phmpt.org/wp-content/uploads/2022/01/ORDER_2022_01_06.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Copy hosted by the plaintiff (phmpt.org), read through a Wayback Machine capture of 20 January 2022; the court's own docket (PACER/CourtListener) was not reachable. The schedule was later modified by the court's order of 2 February 2022 (ECF No. 56).

Exhibit 944 · Institutional statement

Statement from Cochrane's Governing Board - 26th September 2018

The Cochrane Collaboration’s Governing Board of Trustees voted unanimously on 25th September to terminate Professor Peter Gøtzsche’s membership of the organization, and his present position as a Member of the Governing Board and Director of the Nordic Cochrane Centre.

The Board announces that it voted unanimously on 25 September 2018 to end Peter Gøtzsche's Cochrane membership, his Board seat and his directorship of the Nordic Cochrane Centre. It cites a pattern of disruptive and inappropriate behavior over several years, repeated presentation of his personal views as those of Cochrane, and public statements that breached his confidentiality obligations as a trustee. It reports that eleven Board members voted on 13 September 2018 that he had breached the Trustees' Code of Conduct.

Source
Cochrane Collaboration, Governing Board of Trustees
Date
26 September 2018
Quoted from
Statement, first paragraph
Grade
Primary record
Document
https://web.archive.org/web/20180926133548/https://www.cochrane.org/news/statement-cochranes-governing-board-26th-september-2018
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The cochrane.org page now serves a news index; the Wayback Machine capture of 26 September 2018 carries the statement. Cochrane Russia hosts the same text.

Exhibit 945 · Legal decision

Decision of the European Ombudsman closing his inquiry into complaint 2560/2007/BEH against the European Medicines Agency

The Ombudsman therefore found that EMA's refusal to grant access to the requested documents constituted an instance of maladministration.

Researchers at the Nordic Cochrane Centre asked the European Medicines Agency on 29 June 2007 for clinical study reports and trial protocols on anti-obesity drugs, and the Agency refused on commercial-interest grounds. The Ombudsman found the refusal maladministration and issued a draft recommendation that EMA grant access or give a convincing explanation why it could not. EMA accepted the recommendation and committed to grant access, and the Ombudsman closed the inquiry on that basis.

Source
European Ombudsman (P. Nikiforos Diamandouros)
Date
24 November 2010
Quoted from
Decision, para. 84 (draft recommendation at para. 88; conclusion at Part B)
Grade
Primary record
Document
https://web.archive.org/web/20101204132101/http://www.ombudsman.europa.eu/cases/decision.faces/en/5459/html.bookmark
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The decision text is read from the Ombudsman's own page as captured by the Wayback Machine on 4 December 2010; the current ombudsman.europa.eu page (/en/decision/en/5459) loads by script and returns no text to automated fetch.

Exhibit 946 · Statute

Telecommunications Act of 1996, Pub. L. 104-104, sections 202 and 203 (broadcast ownership; term of licenses)

by eliminating any provisions limiting the number of AM or FM broadcast stations which may be owned or controlled by one entity nationally.

Section 202 directs the FCC to eliminate any national limit on the number of AM or FM stations one entity may own, to set local radio caps by market size (8 stations in markets of 45 or more, down to 5 in markets of 14 or fewer), to eliminate the national limit on the number of television stations and raise the national audience-reach limit to 35 percent, to review local television limits, and to review its ownership rules biennially. Section 203 sets broadcast licence terms of up to 8 years.

Source
United States Congress
Date
8 February 1996
Quoted from
Sec. 202(a), 110 Stat. 111
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-104publ104/html/PLAW-104publ104.htm
Accessed
2026-11-10
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Findings citing this exhibit

Exhibit 947 · Statute

Consolidated Appropriations Act, 2004, Pub. L. 108-199, Div. B, sec. 629 (national television audience-reach limit)

in section 202(c)(1)(B) by striking “35 percent” and inserting “39 percent”

Amends section 202(c)(1)(B) of the 1996 Act to change the national television audience-reach limit from 35 to 39 percent, adds a two-year divestiture period for entities that exceed it by acquisition, makes the quadrennial review under section 202(h) exclude rules on the 39 percent limit.

Source
United States Congress
Date
23 January 2004
Quoted from
Div. B, sec. 629(1), 118 Stat. 99
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-108publ199/html/PLAW-108publ199.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 948 · Agency order

Memorandum Opinion and Order, Applications for Consent to the Transfer of Control of TEGNA Inc. to Nexstar Media Inc., DA 26-267, MB Docket No. 25-331

we grant the Applicants’ request for a waiver of the Commission’s National Television Ownership Rule

Bureau-level order granting the transfer and waiving the National Television Ownership Rule. Para. 9: after the transaction Nexstar would reach 54.5% of the national audience after the 50% UHF discount. Para. 3: the full Commission previously determined the agency can modify the 39% rule and the Bureau waives it for this transaction. Para. 44: Nexstar commits to maintain an increase in local programming hours for two years, and the grant is subject to its commitments; the Bureau declined to adopt the conditions proposed in the record. Para. 45: the combination will help preserve Nexstar's ability to influence network programming through collective negotiation and to preempt network programming in favor of programming that better serves the local community. Para. 81: the Bureau quotes the Digital First Project's statement that the record contains no evidence of reduced local news output, eliminated editorial judgment or diminished viewpoint diversity, and agrees. Nexstar commits to divest six stations. Granted by the Chief, Media Bureau, without a Commission vote.

Source
Federal Communications Commission, Media Bureau
Date
19 March 2026
Quoted from
Para. 3
Grade
Primary record
Document
https://docs.fcc.gov/public/attachments/DA-26-267A1.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Para. 45 states: 'the combination provided by the Transaction will help preserve Nexstar’s ability to influence network programming through collective negotiation and to preempt network programming in favor of programming that better serves the local community.' Para. 81 is the Digital First Project's statement, quoted by the Bureau, which the Bureau agrees with; Nexstar's commitment (paras. 44, 7) concerns local programming hours, not news hours.

Exhibit 949 · Agency order · Withdrawn

Same order, para. 45 (reason for the waiver: preemption of network programming)

Withdrawn: Duplicate of exhibit 948 (fcc-2026-da-26-267-nexstar-tegna); same document.

Para. 45 lists, as part of its public-interest finding, that the combination will help preserve Nexstar’s ability to preempt network programming in favor of programming that serves the local community, and finds strict compliance with the national rule inconsistent with the public interest.

Source
Federal Communications Commission, Media Bureau
Date
19 March 2026
Quoted from
Para. 45
Grade
Primary record
Document
https://docs.fcc.gov/public/attachments/DA-26-267A1.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Same document as fcc-2026-da-26-267-nexstar-tegna; separate register line so the paragraph can be cited alone. Merge at registration if the register prefers one exhibit per document.

Exhibit 950 · Agency order

Report and Order, Amendment of Section 73.3555(e), National Television Multiple Ownership Rule, FCC 26-53, MB Docket No. 17-318 (with Gomez dissent)

Given this finding, we repeal the Commission’s national television multiple ownership rule.

The Commission repeals the national television multiple ownership rule and replaces it with case-by-case review of transactions. Appendix A amends 47 CFR 73.3555 by removing and reserving paragraph (e). The order states the Commission retains authority to change the national cap despite the 2004 statute. Chairman Carr and Commissioner Trusty issued separate statements; Commissioner Gomez dissented, writing that Congress set the cap and only Congress can change it (FCC-26-53A3).

Source
Federal Communications Commission
Date
6 August 2026 (adopted); 1 October 2026 (released)
Quoted from
Para. 7
Grade
Primary record
Document
https://docs.fcc.gov/public/attachments/FCC-26-53A1.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 951 · Agency order

Memorandum Opinion and Order, Applications of Comcast Corporation, General Electric Company and NBC Universal, Inc., FCC 11-4, MB Docket No. 10-56 (Appendix A, conditions)

C-NBCU shall continue NBCU’s policy of journalistic independence with respect to the news programming organizations of all NBCU networks and stations, and shall extend these policies to the potential influence of each of C-NBCU’s owners.

Approves the Comcast-NBCUniversal joint venture with conditions. Para. 204 records the applicants’ statement that since 1986 GE had ensured NBC’s news content was not influenced by GE’s non-media interests and that GE appointed an ombudsman. Appendix A, section XII makes journalistic independence a condition and extends it to the influence of each of C-NBCU’s owners.

Source
Federal Communications Commission
Date
18 January 2011 (adopted); 20 January 2011 (released)
Quoted from
App. A, sec. XII
Grade
Primary record
Document
https://docs.fcc.gov/public/attachments/FCC-11-4A1.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 952 · Agency order

Memorandum Opinion and Order, Applications for Consent to the Transfer of Control of Paramount Global, FCC 25-43, MB Docket No. 24-275 (with Gomez dissent)

Finally, to promote transparency and increased accountability, Skydance will have in place, for a period of at least two years, an ombudsman who reports to the President of New Paramount, and who will receive and evaluate any complaints of bias or other concerns involving CBS.

Commission order (2-1) granting the transfer to New Paramount. Records that the Center for American Rights asked for release of the complete Harris interview transcript and a viewpoint-diversity commitment and that CBS/Skydance did both (para. 35); records Skydance’s 22 July 2025 letter committing to viewpoint diversity, ending DEI initiatives and an ombudsman (paras. 58-59); leaves the news-distortion proceeding open (para. 35). Commissioner Gomez dissented. The order does not mention the Trump v. CBS settlement.

Source
Federal Communications Commission
Date
24 July 2025
Quoted from
Para. 59
Grade
Primary record
Document
https://docs.fcc.gov/public/attachments/FCC-25-43A1.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 953 · Court order

Order, In re Nexstar-TEGNA Merger Litigation, No. 2:26-cv-00976-TLN-CKD (E.D. Cal.), Dkt. 172

Nexstar must not influence the management of the held-separate TEGNA business unit.

Preliminary injunction in DIRECTV’s and eight states’ Clayton Act section 7 suits. The court finds plaintiffs likely to succeed on the section 7 claim and requires Nexstar to hold TEGNA separate, to firewall retransmission-fee information and not to influence TEGNA’s management, including newsroom personnel and programming, pending final judgment. 52 pages. The copy is hosted by the Illinois Attorney General, a plaintiff.

Source
U.S. District Court, Eastern District of California
Date
17 April 2026
Quoted from
Order p. 48, remedial para. 4
Grade
Primary record
Document
https://illinoisattorneygeneral.gov/News-Room/Current-News/Dkt%20172%20Order%20granting%20PI%20Nexstar.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Copy hosted by a plaintiff state; replace with the CourtListener or PACER docket copy before publication. Appeal reported at the Ninth Circuit (No. 26-2490); status not checked.

Exhibit 954 · Company press release

Company Objects to Talk Show Host’s Comments on Killing of Charlie Kirk (Nexstar press release)

will preempt “Jimmy Kimmel Live!” for the foreseeable future beginning with tonight’s show

Announces that Nexstar’s owned and partner ABC-affiliated stations will preempt “Jimmy Kimmel Live!” beginning that night. The release gives Nexstar’s reasons in the voice of its broadcasting division president. It does not mention the FCC, a government request, or the pending TEGNA application.

Source
Nexstar Media Group, Inc.
Date
17 September 2025
Quoted from
Para. 1
Grade
Primary record
Document
https://www.nexstar.tv/nexstar-abc-affiliates-to-preempt-jimmy-kimmel-live-indefinitely-beginning-tonight/
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 955 · News report

“We can do this the easy way or the hard way”: Trump’s FCC again uses the threat of its regulatory powers to push a critic off the air

Reports, quoting the New York Times, that FCC Chairman Brendan Carr said on Benny Johnson’s podcast on 17 September 2025 “we can do this the easy way or the hard way” about Kimmel, and that Nexstar, Sinclair and ABC acted the same day. Page was fetched through a summarizer; the Nieman page returned an error to direct download.

Source
Nieman Journalism Lab (Harvard)
Date
18 September 2025
Grade
Reported
Document
https://niemanlab.org/2025/09/we-can-do-this-the-easy-way-or-the-hard-way-trumps-fcc-again-uses-the-threat-of-its-regulatory-powers-to-push-a-critic-off-the-air
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported. Replace with the recording of the 17 September 2025 Benny Johnson interview (timestamp) and the NYT article of 17 September 2025. The quotation here was not verified against the source.

Exhibit 956 · News report

Paramount, President Trump reach $16 million settlement over “60 Minutes” lawsuit

Paramount also agreed that “60 Minutes” will release transcripts of interviews with presidential candidates in the future, “subject to redactions as required for legal or national security concerns,” the statement said.

CBS News, a Paramount unit, reports the company’s announcement that it will pay $16 million (allocated to Mr. Trump’s future presidential library and the plaintiffs’ fees and costs), that the settlement included no apology, and that “60 Minutes” will release transcripts of interviews with presidential candidates. States that FCC approval was necessary for the Skydance merger and had not been given.

Source
CBS News
Date
2 July 2025
Quoted from
Paragraph beginning “Paramount also agreed”
Grade
Reported
Document
https://www.cbsnews.com/news/paramount-trump-60-minutes-lawsuit-settlement
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported. The outlet reporting is owned by the settling party. Replace with Paramount’s statement of 1 July 2025 and the stipulation of dismissal in the N.D. Tex. docket.

Exhibit 957 · Court opinion

Memorandum Opinion and Order on summary judgment, US Dominion, Inc. v. Fox News Network, LLC, C.A. Nos. N21C-03-257 EMD and N21C-11-082 EMD

The evidence developed in this civil proceeding demonstrates that is CRYSTAL clear that none of the Statements relating to Dominion about the 2020 election are true.

The court grants Dominion summary judgment on falsity and leaves actual malice for a jury. The opinion summarizes record evidence and each side’s argument. The opinion recounts record evidence of a viewership drop and Newsmax’s rise after Fox’s 7 November 2020 projection (p. 14). It summarizes Dominion’s argument that Fox published the statements in response to viewer backlash and declining ratings and profits (p. 34) and its financial-motive argument (p. 56). Fox News Network argued that ratings did not drive revenue, citing deposition testimony that revenue from TV providers makes up the majority of revenue and is not affected by viewership (p. 62 and n. 457). The opinion states positions and cites record evidence; the court did not decide intent.

Source
Superior Court of the State of Delaware (Judge Eric M. Davis)
Date
31 March 2023
Quoted from
Slip op. p. 43
Grade
Primary record
Document
https://courts.delaware.gov/Opinions/Download.aspx?id=345820
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Page numbers are the opinion’s own pagination as read in the PDF. Settlement (reported 18 April 2023) not checked.

Exhibit 958 · Company filing

Comcast Corporation definitive proxy statement (DEF 14A), security ownership table

This information is based upon a Schedule 13G/A filing with the SEC on February 13, 2024 made by BlackRock, Inc. setting forth information as of December 31, 2023.

Class A holders above 5%: The Vanguard Group 373,581,278 (10.0%, 13G/A filed 5 June 2025 as of 30 May 2025); BlackRock 298,215,422 (7.4%, 13G/A filed 13 Feb 2024 as of 31 Dec 2023); State Street 186,826,370 (5.1%, 13G filed 9 Feb 2026 as of 31 Dec 2025). Brian L. Roberts holds all 9,444,375 Class B shares and had sole voting power over 33 1/3% of the combined voting power.

Source
Comcast Corporation
Date
24 April 2026
Quoted from
Security ownership table, note (2)
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1166691/000119312526177138/cmcsa-20260424.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 959 · Company filing

The Walt Disney Company definitive proxy statement (DEF 14A), security ownership table

Holders above 5% of 1,771,884,175 shares outstanding at 15 Jan 2026: Vanguard 151,434,588 (8.5%); BlackRock 122,883,021 (6.9%). The proxy does not state the 13G filing dates. Voting power: Vanguard reported sole voting power over no shares and shared voting power over 2,277,675 of its 151,434,588; BlackRock reported sole voting power over 109,797,441 of its 122,883,021. Also states Vanguard and BlackRock funds are options in employee plans and that both received fees (related-person section).

Source
The Walt Disney Company
Date
22 January 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1744489/000174448926000013/dis-20260122.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 960 · Company filing

Warner Bros. Discovery, Inc. definitive proxy statement (DEF 14A), security ownership table

Holders above 5% of 2,506,679,418 shares at 10 Apr 2026: BlackRock 154,407,752 (6.2%, 13G Amendment No. 1 filed 29 Jan 2024); State Street 131,075,328 (5.2%, 13G filed 9 Feb 2026). Vanguard shown as “—”; note (3) says Vanguard reported 281,212,937 shares (11.2%) on Amendment No. 16 filed 31 Oct 2025 and that on 12 Jan 2026 Vanguard went through an internal realignment, reported in Amendment No. 17 filed 27 Mar 2026.

Source
Warner Bros. Discovery, Inc.
Date
30 April 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1437107/000143710726000046/wbd-20260429.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 961 · Company filing

Nexstar Media Group, Inc. definitive proxy statement (DEF 14A), security ownership table

Holders above 5%: The Vanguard Group 3,370,415 (11.0%; 13G filed 10 Apr 2024 as of 28 Mar 2024); BlackRock 3,207,431 (10.5%; 13G/A filed 3 Apr 2025 as of 31 Mar 2025); Perry A. Sook 1,862,765 (6.1%).

Source
Nexstar Media Group, Inc.
Date
30 April 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1142417/000114241726000016/nxst-20260430.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 962 · Company filing

The New York Times Company definitive proxy statement (DEF 14A), security ownership table

According to information contained in its most recent Schedule 13G/A, filed with the SEC pursuant to the Exchange Act on February 13, 2024, as of December 29, 2023, The Vanguard Group beneficially owned 15,809,453 shares of Class A stock.

Class A holders above 5%: Vanguard 15,809,453 (9.8%; 13G/A filed 13 Feb 2024 as of 29 Dec 2023); BlackRock 14,111,319 (8.8%; 13G/A filed 25 Jan 2024 as of 31 Dec 2023); T. Rowe Price Investment Management 10,247,094 (6.4%).

Source
The New York Times Company
Date
13 March 2026
Quoted from
Beneficial ownership table, note 11
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/71691/000007169126000016/nyt-20260313.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 963 · Company filing

USA TODAY Co., Inc. (formerly Gannett Co., Inc.) definitive proxy statement (DEF 14A), security ownership table

Holders above 5% include BlackRock 10,753,112 (7.3%; 13G/A No. 6 filed 26 Jan 2024) and entities affiliated with Vanguard 8,510,313 (5.8%; 13G/A No. 11 filed 13 Feb 2024; Amendment No. 12 filed 27 Mar 2026 after Vanguard’s realignment); also Alta Fundamental Advisers 11,165,692 (7.6%).

Source
USA TODAY Co., Inc. (formerly Gannett Co., Inc.)
Date
17 April 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1579684/000157968426000022/gci-20260417.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 964 · Company filing

Fox Corporation definitive proxy statement (DEF 14A), security ownership table

As of 14 Sep 2026 Fox has non-voting Class A and voting Class B common stock. LGC Holdco, LLC holds 85,372,810 Class B shares (38.76% of Class B); State Street holds 17,474,836 Class A (8.68%) and 14,007,987 Class B (6.36%) (13G filed 7 Aug 2026 as of 30 Jun 2026 for Class A; 10 Nov 2025 as of 30 Sep 2025 for Class B); BlackRock holds 16,990,417 Class A (8.44%) and 11,421,333 Class B (5.19%) (13G/A filed 17 Apr 2025 as of 31 Mar 2025). The proxy lists no Vanguard holding above 5%. Lachlan K. Murdoch may be deemed a beneficial owner of LGC Holdco’s shares and disclaims beneficial ownership of them.

Source
Fox Corporation
Date
17 September 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1754301/000162828026062480/fox-20260917.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 965 · Company filing

News Corporation definitive proxy statement (DEF 14A), security ownership table

Does not list Vanguard, BlackRock or State Street in text searched. States that the Murdoch Family Trust held approximately 40.7% of outstanding Class B common stock before a September 2025 sale by trusts for certain beneficiaries of 14,071,293 Class B shares (about $450 million gross proceeds). Ownership table not extracted in full.

Source
News Corporation
Date
23 September 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1564708/000110465926109969/tm2624691-1_def14a.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 966 · Company filing

Pfizer Inc. definitive proxy statement (DEF 14A), security ownership table

The information is based solely on a Schedule 13G/A filed by Vanguard on February 13, 2024 (the Vanguard 13G/A).

Holders above 5%: Vanguard 506,479,807 (8.97%; 13G/A filed 13 Feb 2024); BlackRock 434,748,255 (7.70%; 13G/A filed 26 Jan 2024); State Street 287,875,814 (5.10%; 13G/A filed 29 Jan 2024).

Source
Pfizer Inc.
Date
12 March 2026
Quoted from
Beneficial ownership table, note (1)
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/78003/000007800326000033/pfe-20260312.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 967 · Company filing

Merck & Co., Inc. definitive proxy statement (DEF 14A), security ownership table

As reported on Amendment No. 14 to Schedule 13G (the “BlackRock filing”) filed with the SEC on January 26, 2024, which is the most recently filed Schedule 13G with respect to the Company.

Lists one holder above 5%: BlackRock 201,836,434 (8.17%; Amendment No. 14 to 13G filed 26 Jan 2024 as of 31 Dec 2023, “the most recently filed Schedule 13G with respect to the Company”). Vanguard and State Street are not listed.

Source
Merck & Co., Inc.
Date
8 April 2026
Quoted from
Beneficial ownership table, note (1)
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/310158/000119312526147704/d85708ddef14a.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 970 · Company filing

Eli Lilly and Company definitive proxy statement (DEF 14A), security ownership table

Holders above 5%: Lilly Endowment Inc. 192,190,516 (9.8%); Vanguard 80,952,595 (8.6%; 13G/A filed 30 Oct 2025 as of 30 Sep 2025); BlackRock 64,376,027 (6.8%; 13G/A filed 29 Jan 2024 as of 31 Dec 2023); PNC 51,153,837 (5.4%).

Source
Eli Lilly and Company
Date
20 March 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/59478/000005947826000029/lly-20260317.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 971 · Company filing

Lockheed Martin Corporation definitive proxy statement (DEF 14A), security ownership table

The number and percentage of shares held by State Street may have changed since the filing of the Schedule 13G/A.

Holders above 5%: State Street 37,056,708 (14.9%; 13G/A filed 30 Jan 2024 as of 31 Dec 2023); Vanguard 22,098,899 (8.9%; 13G/A filed 13 Feb 2024); BlackRock 18,292,313 (7.4%; 13G/A filed 26 Jan 2024).

Source
Lockheed Martin Corporation
Date
26 March 2026
Quoted from
Beneficial ownership table, note (1)
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/936468/000093646826000004/lmt-20260326.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 972 · Company filing

RTX Corporation definitive proxy statement (DEF 14A), security ownership table

Holders above 5% as of 31 Dec 2025, based on Forms 13F: Vanguard 124,986,171 (9.3%); BlackRock 104,920,146 (7.8%); State Street 91,884,588 (6.8%); Capital Research Global Investors. The proxy notes each manager’s latest Schedule 13G/A was filed in 2024.

Source
RTX Corporation
Date
9 March 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/101829/000130817926000036/rtx014050-def14a.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 973 · Company filing

Northrop Grumman Corporation definitive proxy statement (DEF 14A), security ownership table

Holders above 5%: State Street 13,860,192 (9.8%; 13G/A filed 30 Jan 2024); Vanguard 13,265,738 (9.3%; 13G/A filed 30 Apr 2025 as of 31 Mar 2025); Capital International Investors 12,385,281 (8.7%); BlackRock 10,688,475 (7.5%; as of 30 Sep 2024).

Source
Northrop Grumman Corporation
Date
3 April 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1133421/000113342126000007/noc-20260401.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 974 · Company filing

General Dynamics Corporation definitive proxy statement (DEF 14A), security ownership table

Holders above 5%: Longview Asset Management 27,060,944 (10.0%); Vanguard 24,238,215 (8.9%; 13G filed 30 Oct 2025 as of 30 Sep 2025); Newport Trust 13,576,419 (5.0%); BlackRock 14,500,792 (5.4%; 13G filed 31 Jan 2024 as of 31 Dec 2023).

Source
General Dynamics Corporation
Date
27 March 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/40533/000130817926000168/gd014595-def14a.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 976 · Dataset

Vanguard Group Inc Form 13F-HR information table for the quarter ended 31 December 2025

Form 13F-HR, accession 0000102909-26-000031, period 31 Dec 2025. 17,686 table entries; reported table value $6,897,676,080,637. Rows summed by CUSIP for the companies in INF-1.3 and 1.4 (shares, value in dollars as reported, voting authority columns). A 13F covers Section 13(f) securities the filing manager (and included managers) held on the last day of the quarter; it does not give ownership percentages or votes cast. Extraction saved as inf-1-13f-extract.json beside this note.

Source
U.S. Securities and Exchange Commission (filed by Vanguard Group Inc)
Date
29 January 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/102909/000010290926000031/13F_0000102909_20251231.xml
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Dataset exhibit: source, parameters, date run (2026-11-10) and SHA-256 of the downloaded XML are recorded in inf-1-13f-extract.json. The XML copy is in the researcher’s scratch directory, not in public/docs.

Exhibit 977 · Dataset

BlackRock, Inc. Form 13F-HR information table for the quarter ended 31 December 2025

Form 13F-HR, accession 0002012383-26-000920, period 31 Dec 2025. 50,216 table entries; reported table value $5,916,347,916,984. Rows summed by CUSIP for the companies in INF-1.3 and 1.4 (shares, value in dollars as reported, voting authority columns). A 13F covers Section 13(f) securities the filing manager (and included managers) held on the last day of the quarter; it does not give ownership percentages or votes cast. Extraction saved as inf-1-13f-extract.json beside this note.

Source
U.S. Securities and Exchange Commission (filed by BlackRock, Inc.)
Date
12 February 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/2012383/000201238326000920/form13fInfoTable.xml
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Dataset exhibit: source, parameters, date run (2026-11-10) and SHA-256 of the downloaded XML are recorded in inf-1-13f-extract.json. The XML copy is in the researcher’s scratch directory, not in public/docs.

Exhibit 978 · Dataset

State Street Corp Form 13F-HR information table for the quarter ended 31 December 2025

Form 13F-HR, accession 0000093751-26-000100, period 31 Dec 2025. 4,288 table entries; reported table value $2,980,911,055,209. Rows summed by CUSIP for the companies in INF-1.3 and 1.4 (shares, value in dollars as reported, voting authority columns). A 13F covers Section 13(f) securities the filing manager (and included managers) held on the last day of the quarter; it does not give ownership percentages or votes cast. Extraction saved as inf-1-13f-extract.json beside this note.

Source
U.S. Securities and Exchange Commission (filed by State Street Corp)
Date
13 February 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/93751/000009375126000100/XML_Infotable.xml
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Dataset exhibit: source, parameters, date run (2026-11-10) and SHA-256 of the downloaded XML are recorded in inf-1-13f-extract.json. The XML copy is in the researcher’s scratch directory, not in public/docs.

Exhibit 979 · Company filing

Nexstar Media Group, Inc. annual report (Form 10-K), revenue by source

Consolidated net revenue for 2025 ($ millions): distribution 2,727; advertising 2,121; other 85; total 4,933. Distribution is primarily retransmission, carriage and affiliation fees and spectrum leasing; advertising includes political advertising in even-numbered years.

Source
Nexstar Media Group, Inc.
Date
27 February 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1142417/000119312526078361/nxst-20251231.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 980 · Company filing

Fox Corporation annual report (Form 10-K), revenue by source

Television segment revenues for fiscal 2026 ($ millions): advertising 5,652; distribution 3,346; content and other 668; total 9,666. The filing attributes the advertising increase to the FIFA World Cup and additional NFL and MLB postseason games.

Source
Fox Corporation
Date
6 August 2026
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1754301/000162828026053960/fox-20260630.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 984 · Agency guidance

Guidance for Industry: Consumer-Directed Broadcast Advertisements

A sponsor wishing to use consumer-directed broadcast advertisements may meet the adequate provision requirement through an approach that will allow most of a potentially diverse audience to have reasonably convenient access to the advertised product’s approved labeling.

Final guidance describing one approach to meeting the “adequate provision” requirement of 21 CFR 202.1(e)(1) for broadcast prescription-drug ads, as an alternative to a brief summary: a toll-free number with labeling by mail or phone, a referenced print advertisement, a web address, and a statement that health professionals can supply information. The approach presumes the ad is not false or misleading, presents fair balance and includes a major statement of risks. Non-binding.

Source
U.S. Food and Drug Administration (CDER, CBER, CVM)
Date
August 1999
Quoted from
Part III
Grade
Primary record
Document
https://www.fda.gov/media/75406/download
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 985 · Agency notice

Guidance for Industry on Consumer-Directed Broadcast Advertisements; Availability, 64 Fed. Reg. 43197 (Docket 97D-0302)

The agency sought public comment on a draft version of this guidance, which was announced in the Federal Register of August 12, 1997.

Notice announcing the final guidance. States the draft was announced in the Federal Register of 12 August 1997 and revised after comment.

Source
U.S. Food and Drug Administration
Date
9 August 1999
Quoted from
Summary, 64 Fed. Reg. 43197
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-1999-08-09/html/99-20364.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 986 · GAO report

Prescription Drugs: Improvements Needed in FDA’s Oversight of Direct-to-Consumer Advertising, GAO-07-54

Drug company spending on DTC advertising—such as that on television and in magazines—of prescription drugs increased twice as fast from 1997 through 2005 as spending on promotion to physicians or on research and development.

Reports DTC spending of $4.2 billion in 2005, against $7.2 billion on promotion to physicians and $31.4 billion on R&D; that FDA reviews a small portion of DTC materials without documented criteria; that regulatory letters took an average of 4 months to issue from 2002 to 2005 against 2 weeks from 1997 to 2001; and that the 19 letters of 2004-2005 were issued an average of 8 months after first dissemination, by which time more than half of the materials had been discontinued. HHS disagreed with the recommendations.

Source
U.S. Government Accountability Office
Date
November 2006
Quoted from
Highlights, What GAO Found
Grade
Primary record
Document
https://www.gao.gov/assets/gao-07-54.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Exhibit id uses the report number GAO-07-54.

Exhibit 987 · Statute

Food and Drug Administration Amendments Act of 2007, Pub. L. 110-85, Title IX, sec. 901(d)(3) and (4) (clear, conspicuous and neutral major statement; civil penalties for false or misleading DTC advertisements)

the major statement relating to side effects and contraindications shall be presented in a clear, conspicuous, and neutral manner.

Amends FDCA 502(n) to require that the major statement of side effects and contraindications in TV and radio drug ads be “presented in a clear, conspicuous, and neutral manner”; directs HHS to establish standards by regulation not later than 30 months after enactment; adds civil penalties up to $250,000 for a first false or misleading DTC advertisement in 3 years and $500,000 for each later one; adds a voluntary advisory-review fee program for TV ads (sec. 104).

Source
United States Congress
Date
27 September 2007
Quoted from
Sec. 901(d)(3)(A), amending FDCA 502(n)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-110publ85/html/PLAW-110publ85.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 988 · Regulation

Direct-to-Consumer Prescription Drug Advertisements: Presentation of the Major Statement in a Clear, Conspicuous, and Neutral Manner in Advertisements in Television and Radio Format, final rule, 88 Fed. Reg. 80958

This rule is effective May 20, 2024. The compliance date of this rule is November 20, 2024.

Final rule implementing section 901(d)(3) of FDAAA. History section cites the proposed rule of 29 March 2010 (75 FR 15376). Effective 20 May 2024; compliance date 20 November 2024.

Source
U.S. Food and Drug Administration
Date
21 November 2023
Quoted from
DATES
Grade
Primary record
Document
https://www.federalregister.gov/documents/2023/11/21/2023-25428/direct-to-consumer-prescription-drug-advertisements-presentation-of-the-major-statement-in-a-clear
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 989 · Agency press release

FDA Launches Crackdown on Deceptive Drug Advertising (press release)

Today, the FDA is sending thousands of letters warning pharmaceutical companies to remove misleading ads and issuing approximately 100 cease-and-desist letters to companies with deceptive ads.

Announces thousands of letters to pharmaceutical companies, about 100 cease-and-desist letters, and rulemaking to remove the “adequate provision” option created in 1997. States that FDA once sent more than a hundred warning letters a year and that those to pharmaceutical companies fell to one in 2023 and zero in 2024. Quotes the Commissioner: drug companies spend up to 25% of their budget on advertising. Letter counts are FDA’s own and were not independently checked.

Source
U.S. Food and Drug Administration
Date
9 September 2025
Quoted from
Para. 1
Grade
Primary record
Document
https://www.fda.gov/news-events/press-announcements/fda-launches-crackdown-deceptive-drug-advertising
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 990 · Presidential memorandum

Memorandum on Addressing Misleading Direct-to-Consumer Prescription Drug Advertisements

Over time, however, the FDA's requirements have permitted drug companies to include less information, particularly in broadcast advertising, and drug manufacturer advertising has skyrocketed in recent decades.

Directs the HHS Secretary to act to increase risk information required in DTC advertisements to the extent permitted by law and the FDA Commissioner to enforce the advertising provisions of the FDCA. The Daily Compilation notes an original was not available for verification.

Source
The White House (President Donald J. Trump)
Date
9 September 2025
Quoted from
Para. 2
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/DCPD-202500906/html/DCPD-202500906.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 991 · Congressional testimony

Opening statement of Hon. Bart Stupak, “Direct-to-Consumer Advertising: Marketing, Education, or Deception?” (Subcommittee on Oversight and Investigations, House Committee on Energy and Commerce)

Nearly ten years ago, the U.S. Food and Drug Administration (FDA) relaxed its rules related to direct-to-consumer (DTC) advertisements for prescription pharmaceutical products.

Chairman’s statement opening the hearing on three TV ad campaigns (Lipitor with Robert Jarvik, Vytorin “Food and Family,” Procrit). Gives the chairman’s figures for DTC spending ($1.1 billion in 1997, $4.2 billion in 2005) and states that Merck and Schering-Plough’s Vytorin ads resulted in $5 billion in sales in 2007. A member’s statement, not a finding.

Source
U.S. House of Representatives
Date
8 May 2008
Quoted from
Statement, p. 1
Grade
Primary record
Document
https://webarchive.library.unt.edu/eot2008/20090102234502if_/http://energycommerce.house.gov/Subcommittees/OI-Stupak/050808.OI.hrg.DTC.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Archived copy of the committee’s 2008 page (UNT End of Term web archive). Hearing transcript or GPO hearing record not located.

Exhibit 992 · Peer-reviewed study

Medical Marketing in the United States, 1997-2016

DTC prescription drug advertising increased from $1.3 billion (79 000 ads) to $6 billion (4.6 million ads [including 663 000 TV commercials])

Special communication using Kantar Media advertising data and IQVIA data, 2016 dollars. DTC prescription-drug advertising rose from $1.3 billion (79,000 ads) in 1997 to $6 billion (4.6 million ads including 663,000 TV commercials) in 2016; DTC advertising of all kinds from $2.1 billion to $9.6 billion. FDA violation letters for misleading drug marketing fell from 156 to 11. The read copy is a university-hosted PDF.

Source
Schwartz LM, Woloshin S, JAMA 321(1):80-96 (Dartmouth Institute)
Date
January 2019
Quoted from
Abstract, Findings, JAMA 2019;321(1):80
Grade
Peer-reviewed
Document
https://doi.org/10.1001/jama.2018.19320
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read copy: https://csts.ua.edu/files/2025/06/jama_schwartz_2019_sc_180007.pdf. Confirm figures against the journal copy.

Exhibit 993 · Research paper (not peer reviewed)

Pharmaceutical advertising biases media reports on drug safety (manuscript)

Newspapers are less likely to mention side effects of drugs produced by their advertising clients or to report on US Food and Drug Administration alerts regarding these drugs.

Combines Kantar Stradegy daily newspaper advertising by each drug’s manufacturer with 81,656 LexisNexis newspaper articles on drugs, 1999-2012, with drug-month and newspaper fixed effects. Reports that a newspaper receiving an additional $100,000 in advertising from a drug’s maker in the prior 14 days was 9% to 20% less likely to mention that drug’s side effects (baseline 10%), and 23% to 33% less likely to cover an FDA safety alert (baseline 62%); articles were less negative in tone. Journal of publication not found.

Source
Focke F, Niessen-Ruenzi A, Ruenzi S, University of Mannheim
Date
undated (file name DTCA-2019)
Quoted from
Abstract, p. 2
Grade
Primary record
Document
https://www.bwl.uni-mannheim.de/media/Lehrstuehle/bwl/Ruenzi/Forschung/Papers/DTCA-2019.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Manuscript as hosted by the authors’ department; publication venue and peer-review status unverified. Replace with the published article if one exists.

Exhibit 994 · Research paper (not peer reviewed)

Advertising Spending and Media Bias: Evidence from News Coverage of Car Safety Recalls, NBER Working Paper 23940

Consistent with theoretical predictions, we find that newspapers provide less coverage of recalls by their advertisers, especially the more severe ones.

Matches Kantar Media advertising spending by auto manufacturers in US newspapers to newspaper coverage of car safety recalls, 2000-2014. Reports less coverage of recalls by advertisers, especially severe ones; a one standard deviation increase in prior-two-year ad spending from a large advertiser reduces recall coverage at the intensive margin by 24% for the average newspaper. Published in Management Science 67(2):698-719 (2021), DOI 10.1287/mnsc.2019.3567 (bibliographic record only; article not opened).

Source
Beattie G, Durante R, Knight B, Sen A, National Bureau of Economic Research
Date
October 2017
Quoted from
Abstract
Grade
Primary record
Document
https://www.nber.org/papers/w23940.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Working paper read; replace with the published Management Science text.

Exhibit 995 · Peer-reviewed study

Do Ads Influence Editors? Advertising and Bias in the Financial Media, Quarterly Journal of Economics 121(1):197-227

We find that mutual fund recommendations are correlated with past advertising in three personal finance publications but not in two national newspapers.

Studies mutual fund recommendations in five publications, 1997-2002, controlling for fund characteristics, total family advertising and past mentions. Finds correlation between past advertising and recommendations in three personal finance publications and none in the two national newspapers (the New York Times and the Wall Street Journal); finds the cost to readers small.

Source
Reuter J, Zitzewitz E
Date
2006 (read: August 2005 draft)
Quoted from
Abstract, Aug. 2005 draft
Grade
Peer-reviewed
Document
https://www.jonreuter.com/research/ads.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote checked against the author’s August 2005 draft, labeled forthcoming in QJE; check wording and page against the published article.

Exhibit 996 · Research report (not peer reviewed)

How News Happens: A Study of the News Ecosystem of One American City

Government, at least in this study, initiates most of the news.

Study of the 53 outlets producing local news in Baltimore for one week in July 2009 and six major storylines. Finds that eight in ten stories studied repeated or repackaged previously published information, that 95% of stories with new information came from traditional media, and that in the six storylines 63% of stories were initiated by government officials, led first by the police, and 14% by the press.

Source
Pew Research Center’s Project for Excellence in Journalism
Date
11 January 2010
Quoted from
Findings summary, report p. 4
Grade
Primary record
Document
https://www.pewresearch.org/wp-content/uploads/sites/20/2010/01/PJBaltimoreStudy2010.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
One city, one week, six storylines; the report states these limits.

Exhibit 997 · Agency report

Complete Report of the Chairman of the Committee on Public Information, 1917: 1918: 1919

We did not call it "propaganda," for that word, in German hands, had come to be associated with lies and corruptions.

Creel's report to the President. Counts 76,000 Four Minute speakers and 755,190 speeches; says the Division of News became the sole medium for issuing official war information; says the Committee supervised voluntary censorship of the press and issued an official daily newspaper. Says the Committee did not call its work propaganda. Report dates the creating executive order 14 April 1917.

Source
Committee on Public Information (George Creel); Government Printing Office
Date
1 June 1919 (GPO 1920)
Quoted from
Report letter, p. 1
Grade
Primary record
Document
https://archive.org/details/completereportof00unit
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote read in the archive.org OCR text; hyphenation at line break removed ('corrup- tions'). Other figures: Four Minute Men, p. 3; Division of News, 'sole medium for the issuance of official war information'. The report also says: 'Our work was educational and informative only.' It states that of 6,000 releases only three were questioned as to accuracy, and inquiry upheld two of these.

Exhibit 998 · Executive order

Executive Order 9182, Consolidating Certain War Information Functions Into an Office of War Information

Formulate and carry out, through the use of press, radio, motion picture, and other facilities, information programs designed to facilitate the development of an informed and intelligent understanding, at home and abroad, of the status and progress of the war effort and of the war policies, activities, and aims of the Government.

Creates OWI in the Office for Emergency Management by consolidating the Office of Facts and Figures, the Office of Government Reports and the foreign information functions of the Coordinator of Information. The Director may issue directives binding on departments, require clearance of programs and releases, and require curtailment of information services.

Source
Franklin D. Roosevelt
Date
13 June 1942
Quoted from
Sec. 4(a)
Grade
Primary record
Document
https://www.presidency.ucsb.edu/documents/executive-order-9182-consolidating-certain-war-information-functions-into-office-war
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 999 · Statute

National War Agencies Appropriation Act, 1944, ch. 228, 57 Stat. 494 (Office of War Information, 57 Stat. 531-532)

No part of this or any other appropriation shall be expended by the Office of War Information for the preparation, or publication of any pamphlet or other literature for distribution to the public within the United States.

Appropriates $33,222,504 for OWI salaries and expenses with not more than $24,000,000 for the Overseas Operations Branch and not more than $2,750,000 for the Domestic Operations Branch for listed functions; makes $5,000,000 available only for activities with military operations; bars OWI from preparing or publishing literature for distribution to the public within the United States.

Source
U.S. Congress
Date
12 July 1943
Quoted from
57 Stat. 532
Grade
Primary record
Document
https://www.govinfo.gov/link/statute/57/531
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Public Law number not read; cite by chapter and Statutes at Large page.

Exhibit 1000 · Statute

United States Information and Educational Exchange Act of 1948 (Smith-Mundt Act), Pub. L. 80-402, 62 Stat. 6

The Secretary is authorized, when he finds it appropriate, to provide for the preparation, and dissemination abroad, of information about the United States, its people, and its policies

Title V authorizes the Secretary of State to prepare and disseminate abroad information about the United States; any such press release or radio script is to be available at State for examination by U.S. press and radio representatives and to Members of Congress on request. The text read has no ban on domestic distribution.

Source
U.S. Congress
Date
27 January 1948
Quoted from
Sec. 501, 62 Stat. 9-10
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/STATUTE-62/pdf/STATUTE-62-Pg6.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1001 · Statute

Foreign Relations Authorization Act, Fiscal Years 1986 and 1987, Pub. L. 99-93, sec. 208 (Ban on domestic activities by the USIA)

no funds authorized to be appropriated to the United States Information Agency shall be used to influence public opinion in the United States, and no program material prepared by the United States Information Agency shall be distributed within the United States.

Section 208 (22 U.S.C. 1461-1a) bars USIA funds from influencing public opinion in the United States and bars distribution of USIA program material within the United States, except as provided in sec. 501 of the 1948 Act and with an exemption for exchange programs. Rewritten by Pub. L. 112-239 sec. 1078 (2013).

Source
U.S. Congress
Date
16 August 1985
Quoted from
Sec. 208, 99 Stat. 431
Grade
Primary record
Document
https://www.govinfo.gov/link/statute/99/405
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Page header on the PDF read as 99 Stat. 431; verify the exact page.

Exhibit 1002 · Agency planning document

Information Operations Roadmap

information intended for foreign audiences, including public diplomacy and PSYOP, increasingly is consumed by our domestic audience and vice-versa.

74-page classified roadmap (declassified in part). On the foreign/domestic audience line it says PSYOP is restricted by DoD policy and executive order from targeting American audiences, military personnel and news agencies or outlets, and that information intended for foreign audiences increasingly is consumed by the domestic audience and vice versa.

Source
U.S. Department of Defense (approved by the Secretary of Defense)
Date
30 October 2003; released under FOIA 26 January 2006
Quoted from
Document p. 26 (PDF p. 30)
Grade
Primary record
Document
https://nsarchive2.gwu.edu/NSAEBB/NSAEBB177/info_ops_roadmap.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Scanned PDF; read from OCR of the page image. Release context from National Security Archive Electronic Briefing Book 177.

Exhibit 1003 · Declassified memorandum (FRUS)

Paper Prepared by the Assistant Secretary of Defense for International Security Affairs (McNaughton), 'Action for South Vietnam' (Foreign Relations of the United States, 1964-1968, vol. II, doc. 193)

70%—To avoid a humiliating US defeat (to our reputation as a guarantor).

Top Secret; Sensitive draft. Lists U.S. aims 70/20/10 and an 'also' aim 'To emerge from crisis without unacceptable taint from methods used.' Its last recommended item is a contingency plan to downgrade the apparent stakes. Copies went to McGeorge Bundy, Unger, McNamara and Vance.

Source
U.S. Department of State, Office of the Historian
Date
10 March 1965
Quoted from
Doc. 193, para. 1
Grade
Primary record
Document
https://history.state.gov/historicaldocuments/frus1964-68v02/d193
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Also exact: '(d) Have a contingency plan to downgrade the apparent stakes (per para 8) to be initiated when/if necessary to confuse the issue and diffuse the blame.' The figures are widely cited to a 24 March 1965 version; FRUS dates this draft 10 March.

Exhibit 1004 · Declassified memorandum

National Security Action Memorandum No. 328, Presidential Decisions Re U.S. Policy in Vietnam (FRUS 1964-1968, vol. II, doc. 242)

The President's desire is that these movements and changes should be understood as being gradual and wholly consistent with existing policy.

Top Secret. Approves an 18-20,000 increase in support forces, two additional Marine battalions and a Marine air squadron, and a change of mission for all Marine battalions to permit more active use. Para. 11 directs that premature publicity be avoided and that official statements on the troop movements require the direct approval of the Secretary of Defense in consultation with the Secretary of State.

Source
White House (McGeorge Bundy)
Date
6 April 1965
Quoted from
Para. 11
Grade
Primary record
Document
https://history.state.gov/historicaldocuments/frus1964-68v02/d242
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Text matched between the FRUS page and the FAS copy (irp.fas.org/offdocs/nsam-lbj/nsam-328.htm). FRUS notes it is also printed in the Gravel edition, vol. III, pp. 702-703.

Exhibit 1005 · Presidential remarks

Remarks in Memorial Hall, Akron University

But we are not about to send American boys 9 or 10,000 miles away from home to do what Asian boys ought to be doing for themselves.

Campaign remarks. States there were then some 18,000 men in Viet-Nam and that 'we have a choice. We can seek a wider war.'

Source
Lyndon B. Johnson
Date
21 October 1964
Quoted from
Remarks, paragraph on Asia and China
Grade
Primary record
Document
https://www.presidency.ucsb.edu/documents/remarks-memorial-hall-akron-university
Accessed
2026-11-10
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Exhibit 1006 · Official history

Public Affairs: The Military and the Media, 1962-1968 (United States Army in Vietnam, CMH Pub. 91-13)

A low profile, achieved through restraints on the press at the scene of conflict and designed to sustain the American public's support for the war, seemed a safer course.

Army official history. Says the Johnson administration sought a low profile for the war through restraints on the press; records that Saigon correspondents called the nightly MACV briefings 'The Five O'Clock Follies' and that Rodger Bankson adjusted briefers and staffing in 1966.

Source
U.S. Army Center of Military History (William M. Hammond)
Date
1988
Quoted from
pp. 12-13
Grade
Primary record
Document
https://archive.org/details/CMHPub91-13
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Follies wording: 'newsmen called them "The Five O'Clock Follies"', p. 239. Read in the archive.org copy of the CMH book (history.army.mil refused scripted access). Verify page numbers against the print.

Exhibit 1007 · Official history

Public Affairs: The Military and the Media, 1968-1973 (CMH Pub. 91-2)

held the final session of the famous Five O'Clock Follies on 27 January, the day the accord went into effect.

Army official history. Records that the MACV Office of Information held the final session of the Five O'Clock Follies on 27 January 1973, the day the accord went into effect, with over 385 correspondents then in South Vietnam.

Source
U.S. Army Center of Military History (William M. Hammond)
Date
1996
Quoted from
p. 613-614
Grade
Primary record
Document
https://archive.org/details/CMHPub91-2-B
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
OCR text; 'O'CIock' in the OCR corrected to 'O'Clock'.

Exhibit 1008 · Presidential remarks

Remarks About an Intensified Program for Drug Abuse Prevention and Control

America's public enemy number one in the United States is drug abuse.

Remarks after a bipartisan leadership meeting. Announces a new White House organization, asks Congress for $155 million in new funds bringing the year's drug budget to over $350 million, and says the offensive will include a new educational program.

Source
Richard Nixon
Date
17 June 1971
Quoted from
Remarks, second paragraph
Grade
Primary record
Document
https://www.presidency.ucsb.edu/documents/remarks-about-intensified-program-for-drug-abuse-prevention-and-control
Accessed
2026-11-10
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Exhibit 1009 · Statute

Drug-Free Media Campaign Act of 1998, Pub. L. 105-277, div. D, title I, subtitle A (112 Stat. 2681-752 to 2681-753)

Amounts made available under section 105 should be matched by an equal amount of non-Federal funds for the national media campaign, or be matched with in-kind contributions to the campaign of the same value.

Requires the ONDCP Director to conduct a national media campaign to reduce and prevent drug abuse among young people; lists permitted uses including media time and space and 'entertainment industry collaborations'; bars use to supplant pro bono public service time or for partisan purposes; authorizes $195,000,000 for each of FY1999-2002. Repealed by Pub. L. 109-469 (2006).

Source
U.S. Congress
Date
21 October 1998
Quoted from
Sec. 103(c)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-105publ277/html/PLAW-105publ277.htm
Accessed
2026-11-10
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Findings citing this exhibit

Exhibit 1010 · GAO report

ONDCP Media Campaign: Contractor's National Evaluation Did Not Find That the Youth Anti-Drug Media Campaign Was Effective in Reducing Youth Drug Use (GAO-06-818)

the evaluation provides credible evidence that the campaign was not effective in reducing youth drug use

Reviews Westat's national evaluation. Reports $1.225 billion appropriated FY1998-FY2004 (p. 9). Finds no significant favorable effects on marijuana initiation or cessation and some unfavorable effects in subgroups. Recommends Congress consider limiting appropriations. ONDCP's written comments generally disagreed.

Source
U.S. Government Accountability Office
Date
25 August 2006
Quoted from
Highlights, 'What GAO Found'
Grade
Primary record
Document
https://www.gao.gov/products/gao-06-818
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read from the Wayback copy of gao.gov/assets/gao-06-818.pdf (page-level extraction; full-text extraction truncated). GAO also wrote 'We believe the Westat study is sound.' (Highlights). ONDCP's written comments said it was 'puzzled' that GAO made no recommendations to improve the campaign.

Exhibit 1011 · Agency journal article

Managing a Nightmare: CIA Public Affairs and the Drug Conspiracy Story

a ground base of already productive relations with journalists and an effective response by the Director of Central Intelligence's (DCI) Public Affairs Staff (PAS) helped prevent this story from becoming an unmitigated disaster.

Six-page article by a Directorate of Intelligence officer on the Public Affairs Staff's handling of the 'Dark Alliance' series (August 1996 onward). Describes calls from journalists, distribution of the DCI's letter and of critical stories to reporters and former officials, and counts of skeptical versus negative stories; credits the Washington Post, New York Times and Los Angeles Times critiques; says Public Affairs 'cannot dictate stories to the media.' Calls the series 'a genuine public relations crisis' and records the Mercury News executive editor's May 1997 apology. States that 'The growth in balanced reporting was largely due to the criticisms of the San Jose Mercury-News series by The Washington Post, The New York Times, and especially The Los Angeles Times.'

Source
Central Intelligence Agency, Studies in Intelligence (Nicholas Dujmovic)
Date
Written after December 1997; approved for release 29 July 2014
Quoted from
Opening page (reprint p. 1)
Grade
Primary record
Document
https://www.cia.gov/readingroom/document/0001372115
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Image-only PDF read by OCR. Copy used: web.archive.org/web/2020id_/https://www.cia.gov/readingroom/docs/DOC_0001372115.pdf (cia.gov redirected scripted requests). Other exact lines: 'Public Affairs cannot dictate stories to the media'; 'the PAS aims above all to inform rather than to pressure or to persuade'; 'Public Affairs made sure that reporters and news directors ... received copies of these more balanced stories.' Further exact wording (page images of the 2014 release): p. 12: 'The growth in balanced reporting was largely due to the criticisms of the San Jose Mercury-News series by The Washington Post, The New York Times, and especially The Los Angeles Times.'; p. 11: 'Public Affairs made sure that reporters and news directors calling for information—as well as former Agency officials, who were themselves representing the Agency in interviews with the media—received copies of these more balanced stories.' The article is one officer's account, not an Agency finding.

Exhibit 1012 · Legal decision

Department of State, Office of Public Diplomacy for Latin America and the Caribbean, B-229069, 66 Comp. Gen. 707

were misleading as to their origin and reasonably constituted "propaganda" within the common understanding of that term.

Requested by Reps. Brooks and Fascell. Finds S/LPD arranged articles presented as the work of persons not associated with the government (a Wall Street Journal op-ed of 11 March 1985 by a paid consultant) and visits through a cut-out, and that these violated sec. 501 of the 1985 appropriations act (publicity or propaganda). Finds the antilobbying statute not shown to be violated. Does not seek recovery of funds. Cites B-223098 (SBA editorials, 10 October 1986) and B-212069 (6 October 1983).

Source
U.S. Government Accountability Office (Comptroller General)
Date
30 September 1987
Quoted from
Opinion, p. 4
Grade
Primary record
Document
https://www.gao.gov/products/b-229069
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Also exact (p. 2, quoting a 13 March 1985 S/LPD memorandum): 'Officially, this office had no role in its preparation.' Read from the Wayback copy of the GAO PDF by OCR; p. 4 checked against the page image.

Exhibit 1013 · Legal decision

Department of Health and Human Services, Contract with Maggie Gallagher, B-304716

GAO finds the Administration for Children and Families' payment of a consultant for brochures, a presentation and a signed article did not violate the publicity-or-propaganda prohibition (not covert, self-aggrandizing or purely partisan).

Source
U.S. Government Accountability Office
Date
30 September 2005
Grade
Primary record
Document
https://www.gao.gov/products/A38960
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read as the GAO product page digest; open the PDF and add a quote.

Exhibit 1014 · Legal decision

Environmental Protection Agency, Application of Publicity or Propaganda and Anti-Lobbying Provisions to Then-Administrator's Appearance in a Trade Association's Video, B-329504

GAO finds EPA did not violate the publicity-or-propaganda, grassroots lobbying or Interior anti-lobbying provisions; the on-screen graphic identified the speaker as EPA's Administrator.

Source
U.S. Government Accountability Office
Date
22 August 2018
Grade
Primary record
Document
https://www.gao.gov/products/b-329504
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read as the GAO product page digest; open the PDF and add a quote.

Exhibit 1015 · Legal decision

Environmental Protection Agency, Application of a Publicity or Propaganda Provision to an EPA Tweet, B-330107

GAO finds an April 2018 EPA tweet on a Senate confirmation vote naming a political party was not self-aggrandizing, covert or purely partisan and did not violate sec. 718 of the FY2018 appropriations act. EPA did not respond to GAO's requests for facts and legal views.

Source
U.S. Government Accountability Office
Date
3 October 2019
Grade
Primary record
Document
https://www.gao.gov/products/b-330107
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read as the GAO product page digest; open the PDF and add a quote.

Exhibit 1016 · Legal decision

Executive Agencies, Communications about the 2019 Fourth of July Events on the National Mall, B-331262

GAO finds agency communications about the 2019 Fourth of July events did not violate the grassroots-lobbying or publicity-or-propaganda provisions (secs. 715 and 718 of the FY2019 act).

Source
U.S. Government Accountability Office
Date
17 June 2020
Grade
Primary record
Document
https://www.gao.gov/products/b-331262
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read as the GAO product page digest; open the PDF and add a quote.

Exhibit 1017 · Legal memorandum

Prepackaged News Stories, B-304272

GAO memorandum to agencies: prepackaged news stories are permissible only if the broadcast discloses that the government prepared them; telling the broadcaster is not enough; summarizes the B-302710 and B-303495 violations.

Source
U.S. Government Accountability Office
Date
17 February 2005
Grade
Primary record
Document
https://www.gao.gov/products/b-304272
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read as the GAO product page digest; open the PDF and add a quote.

Exhibit 1018 · Congressional hearing

Misleading Information from the Battlefield: The Tillman and Lynch Episodes, Hearing before the Committee on Oversight and Government Reform, House of Representatives, 110th Cong., 1st Sess., Serial No. 110-54

responsible officials failed to comply with the Army Military Award Regulation when they submitted a Silver Star recommendation that included inaccurate information and a misleading citation that implied Corporal Tillman died by enemy fire.

Witnesses include Jessica Lynch, Tillman family members, Spec. Bryan O'Neal, and Acting DoD Inspector General Thomas Gimble. Gimble reports the Army's three Tillman investigations were deficient, officials failed to notify next of kin promptly, and the Silver Star recommendation was inaccurate; and that the CENTCOM IG found no evidence the Lynch rescue was staged and that no public affairs personnel planned or filmed it. Chairman Waxman says the committee still does not know who supplied the 3 April 2003 account.

Source
U.S. House of Representatives, Committee on Oversight and Government Reform
Date
24 April 2007
Quoted from
Statement of Thomas F. Gimble, hearing pp. 74-76
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/CHRG-110hhrg42898/html/CHRG-110hhrg42898.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Other exact lines: Lynch, 'They don't need to be told elaborate lies.' (pp. 23-24; the statement also says of the early stories 'It was not true.'); Gimble, 'The Inspector General of the Central Command determined and we concur that the allegations were not substantiated. No evidence was found that the rescue was a staged media event.'; Rep. Tom Davis, 'never fed or perpetuated the Hollywood version of events' (p. 12). Page numbers from the GPO PDF page headers; spot-check.

Exhibit 1019 · Inspector general report

Review of Matters Related to the Death of Corporal Patrick Tillman, U.S. Army (IPO2007E001)

Reviews the three Army regulation 15-6 investigations, next-of-kin notification and the Silver Star documentation. Known here only through Gimble's hearing statement (see house-2007-hrg-110-54).

Source
U.S. Department of Defense Office of Inspector General
Date
26 March 2007
Grade
Primary record
Document
https://media.defense.gov/2016/Aug/09/2001774408/-1/-1/1/IPO2007E001.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Not opened (403 to scripted access). Replace with the report text and add a quote. Date per Army and press sources; DoD OIG listing shows a different date.

Exhibit 1020 · Inspector general report

Review of Pre-Iraqi War Activities of the Office of the Under Secretary of Defense for Policy (Report No. 07-INTEL-04)

While such actions were not illegal or unauthorized, the actions were, in our opinion, inappropriate given that the products did not clearly show the variance with the consensus of the Intelligence Community and were, in some cases, shown as intelligence products.

Requested by Sens. Roberts and Levin. Finds the policy office developed, produced and disseminated alternative intelligence assessments on the Iraq-al Qaida relationship. The Under Secretary of Defense for Policy did not concur; the IG's evaluation response kept the finding. The Office of Special Plans itself 'had no responsibility for and did not perform any of the activities examined.'

Source
U.S. Department of Defense Office of Inspector General
Date
9 February 2007
Quoted from
Results (as quoted in S. Rept. 110-346, Scope and Methodology, pp. 1-2)
Grade
Primary record
Document
https://www.dodig.mil/Reports/Audits-and-Evaluations/Article/1142221/review-of-pre-iraqi-war-activities-of-the-office-of-the-under-secretary-of-defe/
Accessed
2026-11-10
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Findings citing this exhibit
Note
Quote read in the Senate Intelligence Committee's quotation of the report (OCR of S. Rept. 110-346). The unclassified executive summary transcription on GlobalSecurity.org has a different second half ('given that the intelligence assessments were intelligence products and did not clearly show the variance...'). Check against the DoD OIG PDF before publication.

Exhibit 1021 · Peer-reviewed study

The Oligopoly of Academic Publishers in the Digital Era

Combined, the top five most prolific publishers account for more than 50% of all papers published in 2013.

Analysis of 45 million documents indexed in the Web of Science, 1973-2013, assigning journals to publishers by the publisher, city and country recorded for each issue and tracking mergers and acquisitions. Natural and medical sciences: the five largest publishers held little more than 20% of papers in 1973 and 53% in 2013. Social sciences and humanities: under 10% through 1990 and over 51% in 2013. Social sciences alone reach 70% from the top five; humanities stay near 20%. Reed-Elsevier 24.1%, Springer 11.9% and Wiley-Blackwell 11.3% of natural and medical science papers in 2013. Coverage is limited to journals indexed in the Web of Science.

Source
Larivière, Haustein and Mongeon, PLOS ONE 10(6): e0127502
Date
10 June 2015
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1371/journal.pone.0127502
Accessed
2026-11-10
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Exhibit 1022 · Annual report

RELX Annual Report 2025, Market segments (Scientific, Technical & Medical)

In 2025, Elsevier received more than 4.2m article submissions, which were rigorously reviewed by our in-house editorial teams in collaboration with over 37,000 editors and over 1.9m expert reviewers around the world.

RELX reports Scientific, Technical & Medical (Elsevier) 2025 revenue of GBP 2,714m and adjusted operating profit of GBP 1,035m (a 38.1% ratio, computed here from the two printed figures; adjusted profit is RELX's own non-GAAP measure). The report states that the latest available long-term comparison showed Elsevier journal articles accounted for over 18% of global research output and 29% of citations, and that Elsevier published over 795,000 articles in 2025 after more than 4.2m submissions, with over 37,000 editors and over 1.9m reviewers. It does not state how many submissions were rejected.

Source
RELX PLC
Date
2025 financial year (annual report published 2026)
Quoted from
Scientific, Technical & Medical section, p. 17 (corporate responsibility paragraph on peer review); 18% / 29% sentence p. 18; segment table (revenue 2,714; adjusted operating profit 1,035) p. 19 (printed page numbers)
Grade
Primary record
Document
https://www.relx.com/~/media/Files/R/RELX-Group/documents/reports/annual-reports/2025-ar-sections/relx-2025-market-segments.pdf
Accessed
2026-11-10
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Exhibit 1023 · SEC filing

John Wiley & Sons, Inc. Form 10-K for the fiscal year ended April 30, 2024 (Research segment, Hindawi)

Hindawi’s special issues program was suspended in the third quarter of fiscal year 2023 due to the presence in certain special issues of compromised articles.

Wiley's annual report to the SEC states that Hindawi's special issues program was suspended in the third quarter of fiscal 2023 because certain special issues contained compromised articles, that open access article output fell 23% in fiscal 2024, and that Research revenue fell 3%. The filing states what the publisher decided and its revenue effect; it does not list the articles or the reviewers involved.

Source
John Wiley & Sons, Inc.
Date
26 June 2024
Quoted from
Item 7, Research segment results, fiscal 2024 vs 2023
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/107140/000010714024000114/jwa-20240430.htm
Accessed
2026-11-10
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Exhibit 1024 · Journal notice

Expression of concern: Hydroxychloroquine or chloroquine with or without a macrolide for treatment of COVID-19: a multinational registry analysis

we are issuing an Expression of Concern to alert readers to the fact that serious scientific questions have been brought to our attention.

The journal's editors issued an expression of concern on a paper published online on 22 May 2020, stating that important scientific questions had been raised about the data and that an independent audit commissioned by authors not affiliated with the data vendor was under way.

Source
The Lancet (editors)
Date
June 2020
Quoted from
Notice text (PubMed 32504543; PMC7269709)
Grade
Primary record
Document
https://doi.org/10.1016/S0140-6736(20)31290-3
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1025 · Journal notice

Retraction: Hydroxychloroquine or chloroquine with or without a macrolide for treatment of COVID-19: a multinational registry analysis

Due to this unfortunate development, the authors request that the paper be retracted.

The retraction notice is signed by three of the four authors. It states that the authors launched an independent third-party peer review of the data vendor, that the vendor would not transfer the full dataset, that the reviewers withdrew, and that the authors request retraction. The decision recorded in the notice is the authors' request; the notice does not describe a separate editorial decision.

Source
Mehra, Ruschitzka and Patel (authors), The Lancet 395(10240):1820
Date
5 June 2020
Quoted from
Notice body (PMC7274621)
Grade
Primary record
Document
https://doi.org/10.1016/S0140-6736(20)31324-6
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1026 · Parliamentary record

Pergamon Press (Report), written answer by the Secretary of State for Trade and Industry

After very careful consideration, I have reached the conclusion that the public interest requires publication of the Inspector's Report.

The Secretary of State states that the public interest requires publication of the inspector's report on the affairs connected with Pergamon Press and associated companies, and that he intends to publish it that afternoon with only a typographical correction.

Source
UK House of Commons (Hansard), HC Deb 13 July 1971 vol 821 cc79-80W
Date
13 July 1971
Quoted from
HC Deb 13 July 1971 vol 821 cc79-80W
Grade
Primary record
Document
https://api.parliament.uk/historic-hansard/written_answers/1971/jul/13/pergamon-press-report
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The text of the 1971 report itself was not retrieved; no quotation from it is used.

Exhibit 1027 · Parliamentary record

Pergamon Press Limited, written answer on action after the inspectors' report

The Department's intention is to defend the proceedings instituted against it by Mr. Maxwell and the British Printing Corporation Limited.

The Secretary of State states that further action depends on further inspectors' reports and that the Department's intention is to defend the proceedings brought against it by Mr Maxwell and the British Printing Corporation Limited.

Source
UK House of Commons (Hansard), HC Deb 26 July 1971 vol 822 cc17-18W
Date
26 July 1971
Quoted from
HC Deb 26 July 1971 vol 822 cc17-18W
Grade
Primary record
Document
https://api.parliament.uk/historic-hansard/written_answers/1971/jul/26/pergamon-press-limited
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1028 · Parliamentary record

Company Investigations (Adverse Criticisms), oral answer

The contents of the report are the responsibility of the inspectors. The Department's responsibility is to decide what action should be taken on the report.

A minister states the Department was told on 3 February that representations might be made, replied, and received no further communication by the date of publication on 10 April. The minister states where responsibility lies between inspectors and Department.

Source
UK House of Commons (Hansard), HC Deb 22 May 1972 vol 837 cc986-987
Date
22 May 1972
Quoted from
HC Deb 22 May 1972 vol 837 c987, answer by Mr Emery
Grade
Primary record
Document
https://api.parliament.uk/historic-hansard/commons/1972/may/22/company-investigations-adverse-criticisms
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1029 · Parliamentary record

Pergamon Press Ltd., written answer on receipt of the final report

The final report of the inspectors appointed to investigate the affairs of Pergamon Press Ltd. was received on 16th August 1973. Mr. Maxwell has made to the Department representations about the report which are at present being considered.

The Secretary of State states that the inspectors' final report on Pergamon Press was received on 16 August 1973 and that Mr Maxwell had made representations to the Department about it.

Source
UK House of Commons (Hansard), HC Deb 25 October 1973 vol 861 c703W
Date
25 October 1973
Quoted from
HC Deb 25 October 1973 vol 861 c703W
Grade
Primary record
Document
https://api.parliament.uk/historic-hansard/written_answers/1973/oct/25/pergamon-press-ltd
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1030 · Parliamentary record

Mirror Group Newspapers plc: Investigation, Lords oral question

The inspectors rightly took the view that they should not undertake inquiries covering the same ground as those covered by the court cases.

The Government minister states that the inspectors' investigation into Mirror Group Newspapers (report published 30 March 2001) interviewed 180 witnesses, that the accounting inspector's team cost GBP 7 million and the legal inspector and legal costs GBP 1.5 million (GBP 8.5 million excluding VAT), and that the inspectors did not cover the same ground as the court cases.

Source
UK House of Lords (Hansard), HL Deb 8 May 2001 vol 625 cc896-899
Date
8 May 2001
Quoted from
HL Deb 8 May 2001 vol 625 c898, answer by Lord Sainsbury of Turville
Grade
Primary record
Document
https://api.parliament.uk/historic-hansard/lords/2001/may/08/mirror-group-newspapers-plc-investigation
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The 2001 DTI report itself and the Serious Fraud Office trial record (acquittals January 1996) were not retrieved; the trial outcome is known here only from news reports.

Exhibit 1031 · Court opinion

United States v. Bertelsmann SE & Co. KGaA, Memorandum Opinion (as amended), No. 21-cv-2886 (D.D.C.)

Together, the Big Five held nearly 60 percent of the market for the sale of trade books in 2021

After a bench trial the court enjoined Penguin Random House's proposed acquisition of Simon & Schuster. The background findings describe the five largest trade publishers (the 'Big Five') as holding nearly 60 percent of 2021 trade-book sales, state that agents prioritize submitting manuscripts to Big Five imprints because of their ability to pay, and state that the Big Five acquired other publishers to reach their position. The opinion concerns trade books and anticipated top-selling titles, not journals or textbooks.

Source
U.S. District Court for the District of Columbia (Judge Florence Y. Pan)
Date
15 November 2022
Quoted from
Mem. Op. (Doc. 196) p. 3, Background A
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_21-cv-02886/pdf/USCOURTS-dcd-1_21-cv-02886-2.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The government PDF is a scanned image; the quoted wording was checked against the page images (header 'Document 196 Filed 11/15/22 Page 3 of 80'). The statement that agents prioritize submitting manuscripts to Big Five imprints because of their ability to pay is on PDF page 7; the statement about acquiring other publishers is on page 4.

Exhibit 1032 · SEC filing

McGraw Hill, Inc. Form 10-K for the fiscal year ended March 31, 2026

In each state’s decision, we face significant competition and our materials are subject to approvals by state boards of education or other authorities based on an evaluation of alignment to state academic standards and other criteria.

The company describes itself as a top-two K-12 provider serving about 91% of public K-12 districts and says its market is 'fairly concentrated, with a relatively small number of large competitors', naming Houghton Mifflin Harcourt, Pearson, Savvas, Amplify, Cengage and others. It states that Florida, California and Texas have state-made predetermined procurement patterns and that its materials are subject to approval by state boards of education. Item 3 and notes describe 2025 Florida and Illinois complaints alleging pricing violations against the company and Savvas; those are allegations, not findings.

Source
McGraw Hill, Inc.
Date
11 June 2026
Quoted from
Item 1A, risk factor on state purchasing cycles
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1951070/000195107026000022/mh-20260331.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1033 · Statute

Texas Education Code section 31.022, Substantive review of instructional materials by State Board of Education

Before approving instructional material, the board may review the material and must determine that the material is free from factual error and suitable for the subject and grade level for which the material is designed

The State Board of Education reviews instructional materials, must determine before approving that the material is free from factual error and suitable for the subject and grade level, and keeps a list of approved materials and may keep a list of rejected materials. Section 31.023 lets a district, a majority of Board members or a publisher request agency review. Sections adjacent to 31.022 were repealed effective 13 June 2023 by H.B. 1605; earlier adoption procedures differ.

Source
State of Texas (Legislature)
Date
as amended by H.B. 1605 (2023); text read 10 November 2026
Quoted from
Sec. 31.022(a)
Grade
Primary record
Document
https://statutes.capitol.texas.gov/Docs/ED/htm/ED.31.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read at texas.public.law (a mirror) because the official capitol.texas.gov page renders by script; confirm wording on the official site and capture the pre-2023 text for the history.

Exhibit 1034 · Statute

California Education Code section 60200, State adoption of basic instructional materials

The state board shall adopt basic instructional materials for use in kindergarten and grades 1 to 8, inclusive, for governing boards, subject to the following provisions

The State Board of Education adopts basic instructional materials for kindergarten and grades 1 to 8 in language arts, mathematics, science, social science and other subjects it designates, and adopts at least five basic materials per subject; submissions may be made at most twice every eight years. Governing boards choose among adopted materials.

Source
State of California (Legislature)
Date
2025 version read 10 November 2026
Quoted from
Sec. 60200 (introductory clause)
Grade
Primary record
Document
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=EDC&sectionNum=60200
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
leginfo.legislature.ca.gov and cde.ca.gov block automated fetches; wording read at california.public.law. The governing-board-choice sentence and the history-social science adoptions were not read.

Exhibit 1035 · Policy page

Wikipedia:Reliable sources (content guideline)

Articles should be based on reliable, independent, published sources with a reputation for fact-checking and accuracy.

The guideline states that articles should be based on reliable, independent, published sources, that reliability depends on context, and that no source is always reliable or always unreliable for everything. It labels itself a content guideline; the sourcing policy is Verifiability. It points to the Reliable sources noticeboard for case-by-case questions.

Source
English Wikipedia (community-edited guideline)
Date
archive capture 1 January 2026
Quoted from
Overview
Grade
Primary record
Document
https://en.wikipedia.org/wiki/Wikipedia:Reliable_sources
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Policy pages are community-edited and change; cite the capture date.

Exhibit 1036 · Policy page

Wikipedia:Verifiability (policy)

Wikipedia's content is determined by published information rather than editors' beliefs, experiences, or previously unpublished ideas or information.

The policy states that content is determined by published information in a reliable source and not by editors' beliefs or unpublished ideas, even where an editor is sure something is true.

Source
English Wikipedia (community-edited policy)
Date
archive capture 1 January 2026
Quoted from
Lead, first paragraph
Grade
Primary record
Document
https://en.wikipedia.org/wiki/Wikipedia:Verifiability
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1037 · Policy page

Wikipedia:Notability (guideline)

A topic is presumed to be suitable for a stand-alone article or list when it has received significant coverage in reliable sources that are independent of the subject.

The guideline presumes a topic suitable for a stand-alone article when it has received significant coverage in reliable sources independent of the subject, and says the presumption is not a guarantee.

Source
English Wikipedia (community-edited guideline)
Date
archive capture 2 January 2026
Quoted from
General notability guideline
Grade
Primary record
Document
https://en.wikipedia.org/wiki/Wikipedia:Notability
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1038 · Policy page

Wikipedia:Reliable sources/Perennial sources (archive capture of 1 October 2026)

There is community consensus from a request for comment to deprecate the source. The source is considered generally unreliable, and use of the source is generally prohibited.

The page summarizes prior community consensus on frequently discussed sources under five statuses: generally reliable, no consensus, generally unreliable, deprecated (by request-for-comment consensus) and blacklisted (by the spam blacklist after persistent abuse, with edits blocked technically). It describes itself as non-exhaustive. Entries cite the noticeboard discussions or requests for comment that produced the status.

Source
English Wikipedia (community-edited information page)
Date
archive capture 1 October 2026
Quoted from
Status legend, Deprecated
Grade
Primary record
Document
https://en.wikipedia.org/wiki/Wikipedia:Reliable_sources/Perennial_sources
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1039 · Policy page

Wikipedia:Reliable sources/Perennial sources (archive capture of 17 January 2019)

Despite this, the source may be cited as a primary source if it is the topic of discussion, and the source may be used under WP:ABOUTSELF.

The page's definition of 'Deprecated' in January 2019 allows a deprecated source to be cited as a primary source if it is the topic of discussion; the 1 October 2026 capture does not carry that clause and adds an edit filter warning. The page was created on 28 July 2018 (first revision comment: 'Boldly creating a list of perennially discussed sources').

Source
English Wikipedia (community-edited information page)
Date
archive capture 17 January 2019
Quoted from
Status legend, Deprecated
Grade
Primary record
Document
https://en.wikipedia.org/wiki/Wikipedia:Reliable_sources/Perennial_sources
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1040 · Policy page

Wikipedia:Reliable sources/Noticeboard/Archive 220, Daily Mail RfC (closing statement)

Consensus has determined that the Daily Mail (including its online version, dailymail.co.uk) is generally unreliable, and its use as a reference is to be generally prohibited, especially when other more reliable sources exist.

A request for comment opened on 7 January 2017 closed on 8 February 2017 with a statement by three-plus volunteer closers that the Daily Mail is generally unreliable and generally prohibited as a reference. The closing statement summarizes the support arguments (poor fact checking, sensationalism, fabrication) and the three opposing arguments, and says a second RfC upheld the result in 2019. The Daily Mail entry on the perennial-sources page states that it was the first source to be deprecated. Contributor names are omitted here.

Source
English Wikipedia (reliable sources noticeboard; request for comment closed by volunteer editors)
Date
8 February 2017
Quoted from
Archive top, result
Grade
Primary record
Document
https://en.wikipedia.org/wiki/Wikipedia:Reliable_sources/Noticeboard/Archive_220#Daily_Mail_RfC
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1041 · Arbitration record

Wikipedia:Arbitration/Requests/Case/COVID-19 (resolved by motion)

The community COVID-19 general sanctions are hereby rescinded and are replaced by standard discretionary sanctions, which are authorized for all edits about, and all articles related to, COVID-19, broadly construed.

The Committee accepted a case request about COVID-19 articles and resolved it the same day by motion, passed 8 to 1 with 1 abstention, replacing community general sanctions with standard discretionary sanctions (later redesignated a contentious topic on 14 December 2022, 10 to 0). The decision page contains remedies only: no principles and no findings of fact. Statements in the request disagreed with each other on whether the biomedical sourcing guideline was applied too strictly or correctly; the Committee made no ruling on that.

Source
English Wikipedia Arbitration Committee
Date
16 June 2021
Quoted from
Motion: Discretionary sanctions (June 2021), remedy (i)
Grade
Primary record
Document
https://en.wikipedia.org/wiki/Wikipedia:Arbitration/Requests/Case/COVID-19
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Parties named in the request are omitted; no statement about any editor is used.

Exhibit 1042 · Arbitration record

Wikipedia:Arbitration/Requests/Case/Eastern European mailing list (principles and findings)

using external channels for coordination of activities that, on-wiki, would be inappropriate is also improper.

The Committee examined an archive of a private mailing list sent to it in September 2009, found the archive appeared authentic (8 to 0, 1 abstention), and found that much of the traffic involved members coordinating on three-revert-rule limits, commenting along 'party lines' and supporting each other in disputes, with tactics that included baiting and vexatious complaints. It passed a principle that using external channels to coordinate activities that would be inappropriate on-wiki is improper (9 to 0) and imposed bans and restrictions on named editors. Names are omitted here.

Source
English Wikipedia Arbitration Committee
Date
22 December 2009
Quoted from
Principles, 9 (Off-wiki communication); passed 9 to 0
Grade
Primary record
Document
https://en.wikipedia.org/wiki/Wikipedia:Arbitration/Requests/Case/Eastern_European_mailing_list
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The case records the authenticity of leaked list archives by the Committee itself, not a court or regulator; the page uses only the Committee's principles. No claim about any member's identity or motive is made.

Exhibit 1043 · Correspondence

Letter from Cooley LLP (for the Wikimedia Foundation) to Wiki-PR, "Wiki-PR and Paid Advocacy Editing"

recently banned Wiki-PR and its agents from further editing the Wikipedia site. The ban, adopted on October 25, 2013, reads as follows:

Three-page letter published by the Foundation. Counsel states an opinion, based on evidence to date, that agents of the company used sockpuppets or meatpuppets to make articles appear written by unbiased sources, and that this violates the Terms of Use. The letter reproduces the community ban adopted on 25 October 2013 and states that the community consists of volunteers operating separately from the Foundation. The letter states counsel's position and potential claims; it is not a court finding.

Source
Cooley LLP on behalf of the Wikimedia Foundation
Date
19 November 2013
Quoted from
Page 2, paragraph 3
Grade
Primary record
Document
https://upload.wikimedia.org/wikipedia/foundation/6/6b/2013-11-19_C%26D_letter_to_WikiPR_from_Cooley.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The PDF is an image; the quoted wording was checked against the page images. The counsel's opinion sentence, the Terms of Use statement and the statement that the community consists of 'independent volunteers operating separately from the Wikimedia Foundation' are also on page 2.

Exhibit 1044 · Institutional statement

Making a change to our Terms of Use: Requirements for disclosure (Wikimedia blog)

If you are paid to edit, you will need to disclose your paid editing to comply with the new Terms of Use.

The Foundation announces a new Terms of Use subsection, 'Paid Contributions without Disclosure', requiring paid editors to disclose their employer, client and affiliation. It says the proposal drew 320,000 words of discussion and 6.3 million views, that the discussion was overwhelmingly supportive, and that individual projects may adopt alternative disclosure policies.

Source
Wikimedia Foundation (General Counsel)
Date
16 June 2014
Quoted from
"What's changing?" bullet list
Grade
Primary record
Document
https://blog.wikimedia.org/2014/06/16/change-terms-of-use-requirements-for-disclosure/
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1045 · Institutional statement

Hundreds of "black hat" English Wikipedia accounts blocked following investigation (Wikimedia blog)

After weeks of investigation, volunteer editors on English Wikipedia announced today that they blocked 381 user accounts for “black hat” editing.

The Foundation reports that volunteer editors blocked 381 accounts and deleted 210 articles after an investigation (called 'Orangemoody' by editors) into undisclosed paid advocacy. It says the edits were similar enough that the community believes one coordinated group made them, recalls the October 2013 blocks of Wiki-PR accounts and the cease and desist letter, and says not all paid editing violates policy where affiliations are disclosed. The Foundation states the volunteers made the blocks; it names no individual.

Source
Wikimedia Foundation
Date
31 August 2015
Quoted from
First paragraph
Grade
Primary record
Document
https://blog.wikimedia.org/2015/08/31/wikipedia-accounts-blocked-paid-advocacy/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Orangemoody was a community sockpuppet investigation with the Foundation commenting, not an Arbitration Committee case.

Exhibit 1046 · Research paper (not peer reviewed)

Wikipedia: A quantitative analysis (doctoral thesis summary)

The Gini coefficient (as well as other well-known inequality metrics) shows that less than 10% of the total number of logged editors in each language version is performing more than 90% of the total number of edits.

Quantitative analysis of logged-in authors in the ten largest Wikipedia language editions. Per-author edit counts follow Pareto-like distributions; the inequality analysis reports that less than 10% of logged editors per language version make more than 90% of edits, with monthly Gini coefficients of 80 to 85% since 2004. The companion HICSS 2008 paper (Ortega, Gonzalez-Barahona and Robles, doi 10.1109/HICSS.2008.333) was not read. Logged-in authors only; anonymous edits and bots are outside the analysis.

Source
Felipe Ortega, Universidad Rey Juan Carlos
Date
29 July 2009
Quoted from
Section on inequality of the distribution of edits among authors, p. 8
Grade
Primary record
Document
https://www.gwern.net/doc/wikipedia/2009-ortega.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Sentence spans a line break in the source PDF.

Exhibit 1047 · Research paper (not peer reviewed)

Research:Contribution Inequality (Wikimedia Research project page)

contribution has become increasingly skewed for the two project namespaces (NS 4, Wikipedia, and NS 5, Wikipedia Talk), starting from values around 60% in 2001 up to more than 90%

Project page by a Wikimedia Summer of Research fellow measuring the Gini coefficient of edits per user by namespace and year, and the year-to-year overlap (Jaccard index) of the top 100 and top 1,000 contributors. It reports article-namespace inequality near 90% and project-namespace inequality rising from about 60% in 2001 to above 90% around 2009, and one-year overlap of top contributors rising from about 20% to about 45%.

Source
Wikimedia Foundation research program (Meta-Wiki, supported by WMF)
Date
August 2011
Quoted from
Results paragraph
Grade
Primary record
Document
https://meta.wikimedia.org/wiki/Research:Contribution_Inequality
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Page is a Meta-Wiki research page and can be edited; no archive capture taken.

Exhibit 1048 · Peer-reviewed study

The Rise and Decline of an Open Collaboration System: How Wikipedia's Reaction to Popularity Is Causing Its Decline

Specifically, the restrictiveness of the encyclopedia’s primary quality control mechanism and the algorithmic tools used to reject contributions are implicated as key causes of decreased newcomer retention.

Analysis of English Wikipedia revision histories, including deleted revisions, and a hand-coded random sample of newcomers. The authors report that the share of good-faith newcomers whose edits were reverted rose, that tool-assisted reverting (for example with the Huggle program) produced far lower response rates (7%) than manual reverts, and that the formal norm-setting processes calcified against changes proposed by newer editors.

Source
Halfaker, Geiger, Morgan and Riedl, American Behavioral Scientist 57(5): 664-688
Date
2013
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1177/0002764212469365
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read from the authors' open-access copy at stuartgeiger.com; read abstract and the tool-use section, not the full results.

Exhibit 1049 · Dataset query

Wikimedia Analytics API: editors by activity level and edits, en.wikipedia, content pages, September 2025

Query: /metrics/editors/aggregate/en.wikipedia.org/user/content/{5..24-edits | 25..99-edits | 100..-edits}/monthly. September 2025 results: 19,286 editors with 5-24 edits, 6,513 with 25-99 edits, 4,045 with 100 or more edits (total 29,844 active editors on content pages; 13.6% in the 100+ band). October 2025: 20,133, 6,623 and 4,136. Edits to content pages in September 2025: 2,462,933 by registered users and 3,562,148 by all editor types. The API does not give the share of edits made by the 100+ band.

Source
Wikimedia Foundation (Analytics REST API)
Date
run 10 November 2026
Grade
Primary record
Document
https://wikimedia.org/api/rest_v1/metrics/editors/aggregate/en.wikipedia.org/user/content/100..-edits/monthly/20250101/20261001
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Shares of edits by band need the Wikimedia dumps or the Data Lake; see gaps. Registered-user counts only (editor-type user).

Exhibit 1050 · Dataset query

Tally of statuses in Wikipedia:Reliable sources/Perennial sources, derived from the MediaWiki parse API on 10 November 2026

Method: fetched the rendered page through the MediaWiki parse API and counted table rows by the alt text of the status icon in each row. Of 472 rows with a status icon, 156 were generally reliable, 112 no consensus, 148 generally unreliable and 56 deprecated; a further 25 rows carry a Blacklisted icon, so 472 status rows plus 25 blacklisted rows equal 497. The deprecated rows include state-run outlets (for example RT, Sputnik and Global Times), sources described as left, right and non-partisan (for example the Daily Caller and Occupy Democrats), and non-news sites (for example genealogy, music and travel sites). Counts change with every edit.

Source
Lacuna Project derivation from English Wikipedia
Date
run 10 November 2026
Grade
Primary record
Document
https://en.wikipedia.org/w/api.php?action=parse&page=Wikipedia:Reliable_sources/Perennial_sources&prop=text&format=json&formatversion=2
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The tally is the project's own derivation of a live page, not a count published by Wikipedia. The page had 497 anchored rows: 472 status rows plus 25 blacklisted rows; the counts by status are exact for the capture date. Vault a saved copy and hash before publication.

Exhibit 1051 · Institutional statement

Promote ideas, protect people (Reddit blog)

Because of this, we are changing our practices to prohibit attacks and harassment of individuals through reddit with the goal of preventing them.

Reddit announces a change to prohibit harassment of individuals, defines harassment, says volunteer moderators determine and uphold rules in their subreddits, cites a survey of over 15,000 redditors, and states the change would have no immediately noticeable impact on more than 99.99% of users.

Source
Reddit, Inc.
Date
14 May 2015
Quoted from
Body, paragraph beginning "Because of this"
Grade
Primary record
Document
https://redditblog.com/2015/05/14/promote-ideas-protect-people/
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1052 · Policy page

Reddit Content Policy (archive capture of 11 September 2015)

Reddit provides tools to aid moderators, but does not prescribe their usage.

The policy lists unwelcome content and prohibited behavior and lists enforcement options including 'Adding restrictions to Reddit communities, such as adding NSFW tags or Quarantining' and 'Banning of Reddit communities'. It states that communities may have their own rules and moderators.

Source
Reddit, Inc.
Date
archive capture 11 September 2015
Quoted from
Paragraph 7, Moderation within communities
Grade
Primary record
Document
https://www.reddit.com/help/contentpolicy/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The 5 August 2015 r/announcements post that introduced quarantining was not read: the archived copy is a script shell. Replace with that post or a text capture.

Exhibit 1053 · Institutional statement

Update to Our Content Policy (r/announcements)

Alongside the change to the content policy, we are initially banning about 2000 subreddits, the vast majority of which are inactive. Of these communities, about 200 have more than 10 daily users. Both r/The_Donald and r/ChapoTrapHouse were included.

Reddit announces a Rule 1 against promoting hate based on identity or vulnerability, and states it is initially banning about 2000 subreddits, mostly inactive, including r/The_Donald and r/ChapoTrapHouse. It gives its reasons for each in terms of rule-breaking content and moderators' refusal to meet expectations, and says it does not generally link to banned communities.

Source
Reddit, Inc. (post by the company's chief executive account)
Date
29 June 2020
Quoted from
Body, paragraph beginning "Alongside the change"
Grade
Primary record
Document
https://www.reddit.com/r/announcements/comments/hi3oht/update_to_our_content_policy/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Date taken from the capture of 2 July 2020, in which the post is "2 days ago"; confirm 29 June 2020 on the post page.

Exhibit 1054 · Institutional statement

Addressing the community about changes to our API (r/reddit)

Reddit needs to be a self-sustaining business, and to do that, we can no longer subsidize commercial entities that require large-scale data use.

Reddit states that on 18 April it announced changes to API access, that updated Data API Terms replaced the old terms on 19 June 2023, that free access is 100 queries per minute with OAuth and 10 without from 1 July 2023, that higher usage costs $0.24 per 1,000 calls, that third-party apps Apollo, Reddit is Fun and Sync would close, and that moderation tools such as RES, ContextMod and Toolbox keep free access.

Source
Reddit, Inc. (post by the company's chief executive account)
Date
9 June 2023
Quoted from
Second paragraph
Grade
Primary record
Document
https://www.reddit.com/r/reddit/comments/145bram/addressing_the_community_about_changes_to_our_api/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The 18 April 2023 announcement and the blackout participation counts were not read.

Exhibit 1055 · SEC filing

Reddit, Inc. Form S-1 registration statement (risk factors and business description)

For example, in response to certain changes to our API policies in June 2023, moderators of certain communities inhibited normal operations of the communities they operate, in many cases in violation of our site-wide rules.

The company states that it relies on volunteer moderators, that in December 2023 it had an average of over 60,000 daily active moderators, that moderators of certain communities inhibited normal operations in June 2023 in many cases in violation of site-wide rules, that this has not historically had a material impact, and that some moderators who moderate large communities or many communities may be able to leverage influence to disrupt their communities or others. It states that its Data API terms changed in 2023 to enforce rate limits.

Source
Reddit, Inc.
Date
22 February 2024
Quoted from
Risk Factors, "We rely on an approach to content moderation that depends on Redditors who volunteer to be moderators", p. 33
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/1713445/000162828024006294/reddits-1q423.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1056 · Institutional statement

Transparency Report: July to December 2023

From July to December 2023, 3.7% of the total content created on Reddit was removed across all content types (1.9% by mods and 1.8% by admins).

Reddit reports that 3.7% of content created was removed (1.9% by moderators, 1.8% by admins); that admins performed about 22.3% of removals excluding spam; that admins banned 640,685 communities, 456,849 (71%) of them for spam and 183,836 for non-spam violations, 92% of the non-spam bans because the community was unmoderated; and that 434 Moderator Code of Conduct investigations led to 1,711 outreach messages and 7,118 enforcement actions including 92 community bans. Moderator removals include removals under each community's own rules and are not comparable to admin removals, which cover only the Content Policy.

Source
Reddit, Inc.
Date
April 2024 (report period July-December 2023)
Quoted from
Content removals, Chart 2 text
Grade
Primary record
Document
https://www.redditinc.com/policies/transparency-report-july-to-december-2023
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1057 · Peer-reviewed study

All That's Happening behind the Scenes: Putting the Spotlight on Volunteer Moderator Labor in Reddit

Across subreddits, the share of invisible work for human moderators ranges from 9% to 94% with a median of 43%.

Analysis of private moderator logs for 126 subreddits and over 900 moderator accounts (3 million actions; 39 of 967 accounts classified as bots, which did 73% of 25,812 daily actions). Visible-only analysis understates human moderation labor.

Source
Li, Hecht and Chancellor (arXiv 2205.14529; published at ICWSM 2022 per the authors' listing, venue to be confirmed)
Date
2022
Quoted from
Results, RQ on invisible work
Grade
Peer-reviewed
Document
https://arxiv.org/abs/2205.14529
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Subreddits were those whose moderators volunteered logs; not a random sample.

Exhibit 1058 · Peer-reviewed study

Quarantined! Examining the Effects of a Community-Wide Moderation Intervention on Reddit

new user influx to TRP and TD decreased by 79.5% and 58%, respectively.

Two case studies of r/TheRedPill and r/The_Donald using over 85 million posts and causal inference methods. The quarantine reduced new-user influx while existing users' misogyny and racism levels did not change.

Source
Chandrasekharan, Jhaver, Bruckman and Gilbert (arXiv 2009.11483; ACM CSCW 2020 per the authors' listing, venue to be confirmed)
Date
2020
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://arxiv.org/abs/2009.11483
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1059 · Peer-reviewed study

You Can't Stay Here: The Efficacy of Reddit's 2015 Ban Examined Through Hate Speech

Study of what happened to users of two subreddits banned in 2015 under Reddit's anti-harassment policy, using hate-speech lexicons and causal inference on Reddit comment data. The authors report that many users left and that those who stayed reduced hate speech.

Source
Chandrasekharan, Pavalanathan, Srinivasan, Glynn, Eisenstein and Gilbert, Proc. ACM Hum.-Comput. Interact. 1(CSCW)
Date
2017
Grade
Peer-reviewed
Document
https://doi.org/10.1145/3134666
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Known through search summaries only; abstract and figures not read. Replace with the paper text before use.

Exhibit 1060 · Dataset query

RedditMods: moderators of the 25,814 largest subreddits (public dataset, collected 6 February 2024), and overlap computation

Method: read moderators.csv (125,812 subreddit-moderator pairs, usernames SHA256-hashed, bots removed by the dataset author's heuristic; file SHA-256 d41dff3ee13757204380f3ee2c2bf67ee81f08d216433bc32470acc7c399a31f) and counted pairs per hashed moderator. Result: 93,115 moderator accounts on 25,814 subreddits; median 1 subreddit per moderator; 13,680 (14.7%) moderate two or more; 1,732 (1.9%) five or more; 435 (0.47%) ten or more; 37 fifty or more; 10 a hundred or more (maximum 241). The top 1% of accounts (931) hold 10.9% of all pairs; the 435 accounts with ten or more subreddits sit on 4,504 subreddits (17.4%). 3,990 subreddits list one moderator; median team size is 4. Gini coefficient of subreddits per moderator is 0.24. No account is identified.

Source
Dataset by A. Mayor (GitHub almayor/reddit-mods-dataset); computation by the Lacuna Project
Date
collected 6 February 2024; computed 10 November 2026
Grade
Reported
Document
https://github.com/almayor/reddit-mods-dataset
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Third-party scrape of public moderator lists, so graded reported. Hidden or suspended moderators and the Feb 2024 snapshot date limit it. Replace with Reddit's own moderator lists captured directly, or a peer study with a named method.

Exhibit 1061 · Inspector general report · Withdrawn

Report of Investigation: Allegations of Connections Between CIA and the Contras in Cocaine Trafficking to the United States (96-0143-IG), Volume I: The California Story (Summary)

Withdrawn: Duplicate of exhibit 314 (cia-oig-1998-vol1); same document.

Volume I answers whether CIA knew of narcotics trafficking by Ricky Ross, Norwin Meneses and Danilo Blandon in Southern California, and covers Julio Zavala and Carlos Cabezas in Northern California. A 17-person team was formed after DCI Deutch asked the Inspector General to investigate on 3 September 1996. It finds no CIA employee or agent dealings with the three named traffickers and no CIA role in their prosecutions, and says CIA asked prosecutors to return about $36,000 seized from Zavala on a claim that it was Contra money.

Source
Central Intelligence Agency, Office of Inspector General
Date
29 January 1998 (unclassified release; classified version issued 17 December 1997)
Quoted from
Summary, 'Conclusions: Volume I', first question
Grade
Primary record
Document
https://irp.fas.org/cia/product/cocaine/summary.html
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Mirror of the CIA's own release (FAS, CIA Products and Documents). The cia.gov original path is www.cia.gov/library/reports/general-reports-1/cocaine/ (Wayback capture linked). Replace url with the cia.gov capture of the Volume I summary page before publication.

Exhibit 1062 · Inspector general report · Withdrawn

Report of Investigation: Allegations of Connections Between CIA and the Contras in Cocaine Trafficking to the United States (96-0143-IG), Volume II: The Contra Story

Withdrawn: Duplicate of exhibit 315 (cia-oig-1998-vol2); same document.

Volume II reviews CIA records on hundreds of Contra organizations and individuals and finds several dozen Contra-related individuals and one Contra organization (the ADREN '15th of September' group) subject to drug-trafficking allegations or information. It finds no information that CIA or its employees conspired with or assisted Contra-related drug trafficking to raise funds, and also finds that CIA acted inconsistently when it received such allegations, did not inform Congress of eight of ten Contra-related individuals during the period of the FY 1987 statutory prohibition, and had no published regulations on contacts with suspected traffickers outside counternarcotics operations. States that it was not intended to prove or disprove the allegations.

Source
Central Intelligence Agency, Office of Inspector General
Date
8 October 1998 (classified version issued 27 April 1998)
Quoted from
Executive Summary and Conclusions, 'CIA Policies and Practices'
Grade
Primary record
Document
https://irp.fas.org/cia/product/cocaine2/intro.html
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Second quote for the other direction, same section 'Key Findings': 'No information has been found to indicate that CIA as an organization or its employees conspired with, or assisted, Contra-related organizations or individuals in drug trafficking to raise funds for the Contras or for any other purpose.' Introduction: 'The investigation on which Volume II is based was not intended to prove or disprove the allegations or information received by the Agency concerning possible drug trafficking by specific individuals or organizations.' Mirror copy; the IRP text has OCR-style garbling in the 'six cases' sentence, so read that sentence in the cia.gov capture before quoting.

Exhibit 1063 · Agency journal article · Withdrawn

Managing a Nightmare: CIA Public Affairs and the Drug Conspiracy Story (Studies in Intelligence article, six-page release)

Withdrawn: Duplicate of exhibit 1011 (cia-1997-dujmovic-managing-a-nightmare); same document.

A CIA officer's account, in the Agency's own journal, of how CIA Public Affairs handled the 1996 'Dark Alliance' series. It calls the series 'a genuine public relations crisis,' says the Agency was limited in its response during the IG review, credits 'a ground base of already productive relations with journalists' and the Public Affairs Staff, says the Los Angeles Times, Washington Post and New York Times criticism produced 'balanced reporting,' says Public Affairs gave reporters and news directors copies of the Post's critical articles, and records the Mercury News executive editor's May 1997 apology. It also states that Public Affairs 'cannot dictate stories to the media.' Pages 9-14 of the journal issue (issue number not shown in the release).

Source
Central Intelligence Agency (Studies in Intelligence); author's name redacted in the release
Date
Written after late 1997; released 18 September 2014 (stamped Approved for Release 2014/07/29, C01372115)
Quoted from
Journal p. 9 (release page 1), first column, after the opening paragraph
Grade
Primary record
Document
https://www.cia.gov/readingroom/docs/DOC_0001372115.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read from page images of the 2014 release. Further exact wording: p. 12: 'The growth in balanced reporting was largely due to the criticisms of the San Jose Mercury-News series by The Washington Post, The New York Times, and especially The Los Angeles Times.' (footnote mark 13 omitted); p. 11: 'Public Affairs made sure that reporters and news directors calling for information—as well as former Agency officials, who were themselves representing the Agency in interviews with the media—received copies of these more balanced stories.'; p. 12: 'Public Affairs cannot dictate stories to the media—nor would we want to live in a society where that was possible.'; p. 10: 'Webb ... would later claim ... that he tried to call the Agency but was unsuccessful: "Essentially, our trail stopped at the door of the CIA. They wouldn't return my phone calls."' (check exact punctuation on p. 10 before quoting). The Intercept (25 September 2014) identified the author and reports he confirmed authorship; the release redacts the name. The article is one officer's account, not an Agency finding.

Exhibit 1064 · Newspaper article

Tracking the Genesis of the Crack Trade (first article of the Times series 'The Cocaine Trail')

It was not orchestrated by the Contras or the CIA or any single drug ring.

First of the Times's three-part answer to the Mercury News series, published two months after it. States that the crack epidemic 'was not orchestrated by the Contras or the CIA or any single drug ring,' that Blandon 'was not "the Johnny Appleseed of crack in California",' and that less than $50,000 went to the rebel cause. Also says it is 'unclear what, if anything, the U.S. government may have known about this trade.'

Source
Los Angeles Times (Jesse Katz)
Date
20 October 1996
Quoted from
Opening paragraph (full article text via the Times archive page's structured data)
Grade
Reported
Document
https://www.latimes.com/archives/la-xpm-1996-10-20-mn-59169-story.html
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Grade reported: the article is the record of what the Times published. Second exact sentence for the open-question side: 'Although it's unclear what, if anything, the U.S. government may have known about this trade, a few truths are clear:'. The CIA's 'Managing a Nightmare' article (p. 12) cites the three-part series by date (20-22 October 1996).

Exhibit 1065 · Newspaper article

The CIA and Crack: Evidence Is Lacking of Alleged Plot (Nicaraguans Had Limited Role in Bringing Drug to U.S. Cities)

A Washington Post investigation into Ross, Blandon, Meneses and the U.S. cocaine market in the 1980s found that the available information does not support the conclusion that the CIA-backed contras--or Nicaraguans in general--played a major role in the emergence of crack as a narcotic in widespread use across the United States.

The Post's first investigation of the Mercury News series. Reports that the articles 'did not say directly that the spy agency knew about the two Nicaraguans' drug dealing, although the stories hinted strongly at CIA involvement,' and that its own investigation found the available information does not support a major Contra or Nicaraguan role in the crack epidemic. Also reports that no evidence of specific transactions or explicit financial links backed Blandon's and Meneses's claims of sending money to the rebels, and quotes the 1989 Kerry committee's finding that there were 'serious questions' whether U.S. officials failed to address the drug issue.

Source
The Washington Post (Roberto Suro and Walter Pincus), front page
Date
4 October 1996
Quoted from
Article text, paragraph 6 (copy hosted at Duke; line breaks removed)
Grade
Reported
Document
https://people.duke.edu/~ldbaker/clippings/cia.html
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The URL is a Duke course-clippings copy of the article. Replace with the washingtonpost.com archive URL before publication.

Exhibit 1066 · Wire report

Newspaper: Problems in story linking CIA, crack ('We fell short at every step', editor writes in letter to readers)

I believe that we fell short at every step of our process - in the writing, editing and production of our work.

AP report on the 11 May 1997 open letter by San Jose Mercury News executive editor Jerry Ceppos. The letter says the paper solidly documented a Contra-associated drug ring selling large quantities of cocaine in Los Angeles with some profits going to the Contras, and also that the series omitted conflicting information, presented estimates as fact and implied CIA knowledge it could not prove. AP says Webb disagreed with the paper's re-examination.

Source
Associated Press, as carried by the Spokesman-Review
Date
12 May 1997 (letter published 11 May 1997)
Quoted from
AP text, quoted from the letter
Grade
Reported
Document
https://www.spokesman.com/stories/1997/may/12/newspaper-problems-in-story-linking-cia-crack-we
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Grade reported (AP quoting the letter). Primary replacement: the 11 May 1997 column in the San Jose Mercury News (sjmercury.com/drugs, archived), not retrieved. Second exact sentence: 'We also did not include CIA comment about our findings, and I think we should have.'

Exhibit 1067 · Congressional report

Report of the Select Committee on Assassinations, U.S. House of Representatives, Findings (Section I)

The committee believes, on the basis of the evidence available to it, that President John F. Kennedy was probably assassinated as a result of a conspiracy.

Final report. Finds that Oswald fired three shots, two of which struck President Kennedy; that acoustical evidence established a high probability that two gunmen fired; that the President was probably assassinated as a result of a conspiracy whose other gunman and extent the committee could not identify; that the Soviet and Cuban governments, anti-Castro Cuban groups as groups, the national syndicate of organized crime as a group, the Secret Service, the FBI and the CIA were not involved; and that the investigation into the possibility of conspiracy was inadequate while the investigation of Oswald was thorough and reliable.

Source
U.S. House of Representatives, Select Committee on Assassinations
Date
1979
Quoted from
Section I.C (National Archives table of findings)
Grade
Primary record
Document
https://www.archives.gov/research/jfk/select-committee-report
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Also quote-checked: I.A 'Lee Harvey Oswald fired three shots at President John F. Kennedy. The second and third shots he fired struck the President. The third shot he fired killed the President'; I.D '...The investigation into the possibility of conspiracy in the assassination was inadequate.' The acoustical finding was later reviewed by a 1982 National Research Council panel (not read; see Gaps).

Exhibit 1068 · Federal advisory panel report

Final Report of the Tuskegee Syphilis Study Ad Hoc Advisory Panel

In retrospect, the Public Health Service Study of Untreated Syphilis in the Male Negro in Macon County, Alabama, was ethically unjustified in 1932.

Panel appointed in 1972 under Assistant Secretary Merlin DuVal's office and chaired by Broadus Butler. The majority judges the Public Health Service study ethically unjustified in 1932 and finds no evidence of consent. Separate statement by Jay Katz quotes the transcript of a February 1969 CDC review committee: one of five members repeatedly stressed an obligation to treat, and the committee 'seemed to be reassured' that good liaison with the local medical society meant 'no need to answer criticism.' Katz also notes an October 1972 Southern Medical Journal editorial that exonerated the study and chastised the 'irresponsible press.'

Source
U.S. Department of Health, Education, and Welfare, Public Health Service (Ad Hoc Advisory Panel)
Date
28 April 1973
Quoted from
Report on Charge I, 'Panel Judgments on Charge 1-A', item 1, printed p. 7 (PDF p. 10)
Grade
Primary record
Document
https://biotech.law.lsu.edu/cphl/history/reports/tuskegee/complete%20report.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Second quote-checked passage (Katz, 'Reservations about the Panel Report on Charge I', item 6, printed p. 14, PDF p. 17): 'Instead the Committee, which was in part concerned with the possibility of adverse criticism, seemed to be reassured by the observation that "if we established good liaison with the local medical society, there would be no need to answer criticism."' The 1969 committee's own summary (majority report, PDF p. 14): 'More contact should be established between PHS and Macon County Health Department and Medical Society so they would cooperate in the continuance of the study.' Third (Katz, printed p. 15, PDF p. 18): 'One lengthy editorial appeared in the October 1972 issue of the Southern Medical Journal which exonerated the study and chastised the "irresponsible press" for bringing it to public attention.' The report is a scan; read from page images.

Exhibit 1069 · Congressional report

The FBI informant program, Philadelphia Field Office memorandum of 16 September 1970 (Church Committee, Book III)

The expanded campus coverage called for by FBI Headquarters was quickly implemented at the Field Office level as part of the FBI's effort to have New Left campus groups think "there is an FBI agent behind every mailbox."

In its section on campus informants, the committee reports the FBI's September 1970 lifting of the age restriction on student informants and quotes the Philadelphia Field Office's 16 September 1970 memorandum to Headquarters, which relays a conference consensus that more interviews 'will further serve to get the point across there is an FBI agent behind every mailbox.' Book II (PDF p. 33) repeats the phrase.

Source
United States Senate, Select Committee to Study Governmental Operations
Date
23 April 1976
Quoted from
Book III, informant program section, PDF p. 271 (footnote 173 cites Memorandum from Philadelphia Field Office to FBI Headquarters, 9/16/70)
Grade
Primary record
Document
https://www.intelligence.senate.gov/wp-content/uploads/2024/08/sites-default-files-94755-iii.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Same PDF as church-1976-book3-cointelpro (exhibit 299), different part of Book III. Add as a second locator on exhibit 299 if the register prefers one exhibit per volume.

Exhibit 1070 · Internal FBI newsletter (document from the 1971 Media, PA burglary)

New Left Notes - Philadelphia, Edition #1, 16 September 1970, 'An Agent Behind Every Mailbox' (document taken from the FBI resident agency at Media, PA)

There was a pretty general concensus that more interviews with these subjects and hangers-on are in order for plenty of reasons, chief of which are it will enhance the paranoia endemic in these circles and will further serve to get the point across there is an FBI Agent behind every mailbox.

Internal Philadelphia newsletter reporting a Bureau conference at SOG on 10-11 September 1970. Records a 'pretty general concensus' that more interviews of New Left subjects were in order because they would 'enhance the paranoia endemic in these circles' and 'further serve to get the point across there is an FBI Agent behind every mailbox.'

Source
Federal Bureau of Investigation, Philadelphia Field Office; published in 'The Complete Collection of Political Documents Ripped Off from the FBI Office in Media, PA, March 8 1971' (WIN, March 1972)
Date
16 September 1970; compilation March 1972
Quoted from
Compilation PDF p. 28 (read from page image; 'enhance' is hyphenated across a line break in the print)
Grade
Reported
Document
https://archive.org/details/the-complete-collection-of-political-documents-ripped-off-from-the-fbi-office-in
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Leaked-document rule (EDITORIAL INF list): authenticity is established by the Church Committee, whose Book III quotes the same Philadelphia memorandum of 16 September 1970 and the phrase 'there is an FBI agent behind every mailbox' (exhibit church-1976-book3-informants-mailbox). The words 'enhance the paranoia endemic in these circles' appear only in this compilation copy, not in the Church text. Say how the material reached the public: taken in the 8 March 1971 burglary of the FBI's Media, PA office and mailed to newspapers; the burglars were not identified until 2014. Replace with the FBI Vault MEDBURG copy if it carries the page.

Exhibit 1071 · Platform policy statement

An Update on Our Work to Keep People Informed and Limit Misinformation About COVID-19 (Guy Rosen; page updated 8 February and 26 May 2021)

In light of ongoing investigations into the origin of COVID-19 and in consultation with public health experts, we will no longer remove the claim that COVID-19 is man-made or manufactured from our apps.

The same page carries both policy statements. The 8 February 2021 update adds 'COVID-19 is man-made or manufactured' to the claims Meta will remove, listing it among 'debunked' claims after consultations with leading health organizations including the WHO. The 26 May 2021 update says Meta will no longer remove that claim.

Source
Meta (Facebook), Newsroom
Date
16 April 2020; updates 8 February 2021 and 26 May 2021
Quoted from
'Update on May 26, 2021 at 3:30PM PT' (top of page)
Grade
Primary record
Document
https://about.fb.com/news/2020/04/covid-19-misinfo-update/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Archive capture of 11 February 2021 (web.archive.org/web/20210211002342/https://about.fb.com/news/2020/04/covid-19-misinfo-update/) shows the 8 February list including 'COVID-19 is man-made or manufactured'; capture of 2 June 2021 (linked above) shows the 26 May update. Exact 8 February wording: 'Today, following consultations with leading health organizations, including the World Health Organization (WHO), we are expanding the list of false claims we will remove to include additional debunked claims about the coronavirus and vaccines. This includes claims such as: COVID-19 is man-made or manufactured'. One page, two statements; register as one exhibit with two locators.

Exhibit 1072 · Presidential statement

Statement by President Joe Biden on the Investigation into the Origins of COVID-19

As of today, the U.S. Intelligence Community has “coalesced around two likely scenarios” but has not reached a definitive conclusion on this question.

States that the Intelligence Community 'coalesced around two likely scenarios' (animal contact or laboratory accident) without a definitive conclusion, with two elements leaning one way and one the other, each with low or moderate confidence, and directs a 90-day follow-up report. Issued the same day as the Facebook policy update.

Source
The White House
Date
26 May 2021
Quoted from
Statement, third paragraph
Grade
Primary record
Document
https://bidenwhitehouse.archives.gov/briefing-room/statements-releases/2021/05/26/statement-by-president-joe-biden-on-the-investigation-into-the-origins-of-covid-19/
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1073 · Declassified intelligence assessment

Updated Assessment on COVID-19 Origins

All agencies assess that two hypotheses are plausible: natural exposure to an infected animal and a laboratory-associated incident.

Key Takeaways: the IC judges the virus was not developed as a biological weapon; most agencies assess with low confidence that it probably was not genetically engineered (two agencies say evidence is insufficient); four IC elements and the National Intelligence Council assess with low confidence a natural origin; one element assesses with moderate confidence a laboratory-associated incident; the rest cannot choose. Both hypotheses are plausible to all agencies.

Source
Office of the Director of National Intelligence
Date
29 October 2021 (information through August 2021)
Quoted from
Key Takeaways, p. 1, second paragraph
Grade
Primary record
Document
https://www.dni.gov/files/ODNI/documents/assessments/Declassified-Assessment-on-COVID-19-Origins.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Same page, label-correct side: 'We judge the virus was not developed as a biological weapon. Most agencies also assess with low confidence that SARS-CoV-2 probably was not genetically engineered; however, two agencies believe there was not sufficient evidence to make an assessment either way.' PDF creation date 29 October 2021; later agency assessments (FBI, DOE 2023; CIA January 2025) not read in primary form, see Gaps.

Exhibit 1074 · Journal correspondence

Statement in support of the scientists, public health professionals, and medical professionals of China combatting COVID-19 (Correspondence)

We stand together to strongly condemn conspiracy theories suggesting that COVID-19 does not have a natural origin.

Letter from 27 public health scientists supporting Chinese colleagues and condemning 'rumours and misinformation' about origins. States that scientists 'overwhelmingly conclude that this coronavirus originated in wildlife.' Declares no competing interests. The Lancet's editors published an addendum on 21 June 2021 (Lancet 397:2449-50) stating that some readers questioned the disclosure and that the editors had invited the authors to re-evaluate their competing interests.

Source
The Lancet (27 co-authors; Calisher et al.)
Date
February 2020 (The Lancet 2020;395:e42-e43; exact online date to confirm)
Quoted from
Letter, second paragraph
Grade
Primary record
Document
https://pmc.ncbi.nlm.nih.gov/articles/PMC7159294/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Addendum text read at PMC8215723: 'The Lancet invited the 27 authors of the letter to re-evaluate their competing interests.' Report only the documents; no inference about any author's motives.

Exhibit 1075 · Fact-check

Archived fact-check: Tucker Carlson guest airs debunked conspiracy theory that COVID-19 was created in a lab

When this fact-check was first published in September 2020, PolitiFact’s sources included researchers who asserted the SARS-CoV-2 virus could not have been manipulated. That assertion is now more widely disputed.

Rated a claim by Li-Meng Yan that SARS-CoV-2 'is a man-made virus created in the lab'. On 17 May 2021 PolitiFact removed it from its database 'pending a more thorough review' and said it now considered the claim 'unsupported by evidence and in dispute,' preserving the original text.

Source
PolitiFact (Poynter Institute)
Date
16 September 2020; editor's note 17 May 2021
Quoted from
Editor's note, May 17, 2021 (top of archived page)
Grade
Primary record
Document
https://www.politifact.com/factchecks/2020/sep/16/li-meng-yan/tucker-carlson-guest-airs-debunked-conspiracy-theo/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read in the Wayback copy; politifact.com blocks scripted fetches. 'Currently, we consider the claim to be unsupported by evidence and in dispute.' is the same note.

Exhibit 1076 · Fact-check

Pa. Rep. Scott Perry airs debunked claim that Wuhan lab constructed the coronavirus

That dispute notwithstanding, the claim that COVID-19 was constructed at the Wuhan institute remains False.

Rated False the statement that the coronavirus 'was constructed in the Wuhan Institute of Virology.' The 20 May 2021 note says its sources had asserted the virus could not have been manipulated, that this assertion is now more widely disputed, and that the claim 'remains False.'

Source
PolitiFact (Poynter Institute)
Date
26 October 2020; editor's note 20 May 2021
Quoted from
Editor's note, May 20, 2021
Grade
Primary record
Document
https://www.politifact.com/factchecks/2020/oct/26/scott-perry/pa-rep-scott-perry-airs-debunked-claim-wuhan-lab-c/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read in the Wayback capture of 21 May 2021. This fact-check, unlike the Yan item, kept its rating.

Exhibit 1077 · Newspaper correction (secondhand)

Washington Post correction to its February 2020 report on Sen. Tom Cotton and the coronavirus (as reported by Yahoo News)

Yahoo reports that the Post removed 'debunked' and 'conspiracy theory' from a February 2020 article and headline about Sen. Tom Cotton's remarks on the virus's origins, with an editor's note saying there had been no determination of the origins 'then as now.' The original headline, per Mediaite and Yahoo, read 'Tom Cotton keeps repeating a coronavirus conspiracy theory that was already debunked.'

Source
The Washington Post; reported by Yahoo News
Date
Correction added about 28 May 2021; reported 1 June 2021
Grade
Reported
Document
https://news.yahoo.com/washington-post-corrected-article-described-102002630.html
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
No quote: wording was read only in the Yahoo copy. Exact editor's note as Yahoo prints it: 'Earlier versions of this story and its headline inaccurately characterized comments by Sen. Tom Cotton (R-Ark.) regarding the origins of the coronavirus. The term "debunked" and The Post's use of "conspiracy theory" have been removed because, then as now, there was no determination about the origins of the virus.' Replace with the washingtonpost.com page and its archive captures.

Exhibit 1078 · Platform policy statement · Withdrawn

More Speech and Fewer Mistakes (Joel Kaplan)

Withdrawn: Duplicate of exhibit 1146 (meta-2025-more-speech-fewer-mistakes); same document.

Announces that Meta will end its third-party fact-checking program in the United States and move to Community Notes. Says the program launched in 2016 with independent fact-checking organizations, that 'Experts, like everyone else, have their own biases and perspectives,' that too much legitimate political speech was fact-checked, and that the system attached 'intrusive labels and reduced distribution.' Says it will stop demoting fact-checked content.

Source
Meta, Newsroom
Date
7 January 2025
Quoted from
Section 'Ending Third Party Fact Checking Program, Moving to Community Notes', second paragraph
Grade
Primary record
Document
https://about.fb.com/news/2025/01/meta-more-speech-fewer-mistakes/
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1079 · Fact-checker statement

Meta Ends Third-Party Fact-Checking Partnership in the U.S.

We would like to note that these labels and the consequences of labels (like reduced distribution or demonetization) were always 100% under the control of Meta and they could have changed or removed them at any time they chose.

A Meta partner's reply to Meta's bias and censorship statements. Says it and the IFCN never received a complaint from Meta about political bias, and that the labels and their consequences were controlled by Meta.

Source
Lead Stories
Date
January 2025 (responding to Meta's 7 January 2025 announcement)
Quoted from
Section 'Censorship?', third paragraph
Grade
Primary record
Document
https://leadstories.com/analysis/2025/01/end-of-meta-partnership.html
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The page does not show a date in the text read; the 7 January 2025 date comes from the URL path (2025/01) and the Meta announcement it answers.

Exhibit 1080 · Fact-checker financial disclosure

Our Funding (FactCheck.org, itemized financial disclosure by fiscal year, FY2010-FY2026)

We do not accept funds from corporations with the exception of Meta, which provided funding as part of its initiative to debunk viral deceptions from 2017 to 2025, and Google, which provided a one-time grant to support our COVID-19 coverage in 2020 and, along with YouTube, funded a 2024-2025 grant administered by the International Fact-Checking Network.

Itemizes support each fiscal year. Facebook/Meta payments 'as part of a project to debunk viral deceptions' are listed from FY2017 ($52,283.34) through FY2025 ($258,320): FY2018 $188,881; FY2019 $242,400; FY2020 $323,745; FY2021 $389,925 plus $30,032 (NABJ fellowship program); FY2022 $201,574 plus $69,968; FY2023 $339,279 plus $4,244; FY2024 $162,800. Also lists Google and YouTube funding, including a FY2025 grant of $79,567 administered by the International Fact-Checking Network.

Source
FactCheck.org (Annenberg Public Policy Center, University of Pennsylvania)
Date
Page read 10 November 2026; covers fiscal years ending 30 June 2010-2026
Quoted from
'Our Funding', fifth paragraph
Grade
Primary record
Document
https://www.factcheck.org/our-funding/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Figures re-read from the page's per-year blocks and re-summed in the note file. The page also says: 'Neither corporation sought nor was given any control over our editorial decisions.'

Exhibit 1081 · Fact-checker funding disclosure

Who pays for PolitiFact?

Organizations that contributed more than 5 percent of total PolitiFact revenues in the previous calendar year will be listed here:

Lists organizations that contributed more than 5 percent of total PolitiFact revenue in the previous calendar year (Meta and TikTok) without giving amounts, and itemizes grants by year, including Facebook items such as $85,000 (NABJ fact-checking fellowship) and $25,000 (United Facts of America sponsorship) in the year-2021 block.

Source
PolitiFact (Poynter Institute)
Date
Archive capture of 4 January 2026
Quoted from
Funding text above the list ('Meta', 'TikTok')
Grade
Primary record
Document
https://www.politifact.com/who-pays-for-politifact/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
politifact.com blocks scripted fetches; read in the Wayback capture. The list gives names, not amounts. The Poynter Institute's audited statements or Form 990 would give amounts; not retrieved.

Exhibit 1082 · Professional code

The commitments of the Code of Principles (International Fact-Checking Network)

Signatory organizations are transparent about their funding sources. If they accept funding from other organizations, they ensure that funders have no influence over the conclusions the fact-checkers reach in their reports.

Five principles (non-partisanship and fairness; sources; funding and organization; methodology; corrections), assessed against 31 criteria by independent assessors. Principle 3 requires signatories to disclose each source of funding of 5% or more of total revenue and to ensure funders have no influence over conclusions. Principle 4 requires fact-checks to set out evidence that appears to support the claim as well as evidence that appears to undermine it.

Source
International Fact-Checking Network, Poynter Institute
Date
Current page; capture of 14 April 2024
Quoted from
Principle #3, A commitment to Transparency of Funding & Organization
Grade
Primary record
Document
https://ifcncodeofprinciples.poynter.org/know-more/the-commitments-of-the-code-of-principles
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1083 · Industry survey report

State of the Fact-Checkers Report 2025

The Meta third-party fact-checking program fell to 34.3%, down from 45.5% in 2024, a decline that reflects the program’s uncertain future, following the phaseout in the United States last year.

Survey of IFCN signatories: 141 organizations in 71 countries responded (77.5% of fact-checking outlets in the network); 137 answered the revenue question. Grants averaged 46.2% of revenue in 2025; the Meta program averaged 34.3%, down from 45.5% in 2024. Among 85 organizations in the Meta program, 37.7% said Meta supplied more than half their revenue. Self-reported, estimates acceptable.

Source
International Fact-Checking Network, Poynter Institute
Date
March 2026 (survey 3-15 February 2026; data for calendar 2025)
Quoted from
p. 4, 'Revenue sources', first paragraph (read from page image)
Grade
Primary record
Document
https://www.poynter.org/wp-content/uploads/2026/03/2026-State-of-Fact-Checkers-4.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Meta-dependence figures at p. 6 ('Platform partnerships: Meta's fact-checking program'). The IFCN is a unit of the organization that also runs PolitiFact; the survey is by the network about its own signatories.

Exhibit 1084 · Nonprofit funder disclosure

Major Funders (Poynter's Top Funding Sources)

Lists funders of $50,000 or more by category, without amounts. Under media-literacy and training support it lists Google (Gemini, Google News Initiative, YouTube), Meta ('Empowering the International Fact-Checking Network to support fact-checker signatories'), the National Endowment for Democracy (concluded 2025) and others.

Source
The Poynter Institute for Media Studies
Date
Page updated October 2026; read 10 November 2026
Grade
Primary record
Document
https://www.poynter.org/?p=484636
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read through a page summarizer, not the raw page; the page is script-rendered. Re-read the page and quote exactly before use. Amounts come from Poynter's Form 990 and audited statements (EIN 59-1630423), not retrieved.

Exhibit 1085 · Court opinion

Children's Health Defense v. Meta Platforms, Inc., No. 21-16210 (9th Cir. Aug. 9, 2024)

Specifically, Meta directs those services to review and classify content that its algorithms have identified as potentially containing “misinformation.”

Affirms dismissal of CHD's suit against Meta, Mark Zuckerberg, the Poynter Institute and Science Feedback over fact-check labels, a disabled donate button and ad restrictions, holding the alleged harm came from Meta's own policy and that CHD alleged no government coercion or agreement. The opinion describes how Meta used fact-checkers: Meta directs Poynter and Science Feedback to review content its algorithms flag; false ratings produce a grey overlay with a 'See Why' link; Meta disabled CHD's donate button and barred ads because CHD 'repeatedly posted content that has been disputed by third-party fact-checkers.' Judge Collins concurred in part and dissented in part.

Source
United States Court of Appeals for the Ninth Circuit
Date
9 August 2024
Quoted from
Slip op. p. 8
Grade
Primary record
Document
https://cdn.ca9.uscourts.gov/datastore/opinions/2024/08/09/21-16210.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The background facts in the opinion are the court's recitation of the complaint's allegations at the pleading stage. Reported separately from government-request questions (Murthy v. Missouri, exhibit 067).

Exhibit 1086 · News report quoting a platform statement

Instagram bars Robert F. Kennedy Jr. for spreading vaccine misinformation

“We removed this account for repeatedly sharing debunked claims about the coronavirus or vaccines,”

Reports the removal of Robert F. Kennedy Jr.'s Instagram account with a Facebook spokesperson's statement.

Source
NPR, via WGBH
Date
11 February 2021
Quoted from
Body text, quoting a Facebook spokesperson to NPR
Grade
Reported
Document
https://www.wgbh.org/news/national/2021-02-11/instagram-bars-robert-f-kennedy-jr-for-spreading-vaccine-misinformation
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Grade reported; primary replacement is Meta's own enforcement notice or Community Standards Enforcement record for the account, which the public record does not supply.

Exhibit 1087 · News report quoting a platform statement

RFK Jr.'s anti-vaccine group kicked off Instagram and Facebook

“We removed these accounts for repeatedly violating our policies,”

Reports Meta's removal of Children's Health Defense's Facebook and Instagram accounts with a Meta spokesman's statement.

Source
Associated Press, as carried by NBC News
Date
18 August 2022
Quoted from
Body text, quoting a Meta spokesman to the AP
Grade
Reported
Document
https://www.nbcnews.com/health/health-news/rfk-jrs-anti-vaccine-group-kicked-instagram-facebook-rcna43830
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Grade reported. Meta's statement here cites policy violations, not fact-check ratings; the February 2021 Instagram statement cites 'debunked claims.'

Exhibit 1088 · Institutional statement

Henry Ford Health Denounces Claim That System Suppressed Research, Cautions Against Dangerous Viral Disinformation and Misinformation

Henry Ford Health, a nationally recognized academic medical center and research institution, has issued a cease-and-desist letter to the makers of an upcoming “documentary” that falsely and dangerously claims the health system suppressed a draft of a research paper because of its results.

States that Henry Ford Health has issued a cease-and-desist letter to the makers of an upcoming 'documentary' and says a 2020 draft comparing vaccinated and unvaccinated children 'was immediately shelved upon the first internal peer review because of serious issues with its data and methodology.' Lists six flaws (sample differences, small unvaccinated sample, shorter follow-up, multiple vaccines versus none, no account of vaccine number or timing, changing guidance). Calls suppression claims 'patently false, defamatory and troubling' and says the draft was shared without the system's knowledge.

Source
Henry Ford Health
Date
26 September 2025
Quoted from
Paragraph 1 (DETROIT dateline)
Grade
Primary record
Document
https://www.henryford.com/news/2025/09/vaccine-study-henry-ford-health
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The cease-and-desist letter itself was not located. The draft manuscript is exhibit henry-ford-ms (Senate hearing record, 9 September 2025); the Michigan Public report is exhibit henry-ford-statement. A second Henry Ford page of the same date ('fact check') lists myths and rebuttals.

Exhibit 1089 · Fact-check review

Significant flaws in Henry Ford study used to claim childhood vaccines cause harm

Contrary to the claims of vaccine opponents, the study doesn’t provide credible evidence of a causal relationship between childhood vaccinations and certain chronic medical conditions.

Review of the unpublished Henry Ford manuscript, published four days before Henry Ford Health's statement. Cites an outside biostatistician who called baseline imbalances, utilization disparities and unequal follow-up 'fatal flaws,' and concludes the study 'doesn't provide credible evidence of a causal relationship.' Science Feedback was a defendant in Children's Health Defense v. Meta (exhibit ca9-2024-chd-v-meta) as a Meta fact-checking contractor.

Source
Science Feedback
Date
22 September 2025
Quoted from
'Conclusion' section
Grade
Primary record
Document
https://science.feedback.org/review/significant-flaws-henry-ford-study-childhood-vaccines-harm/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Science Feedback's funding page lists Facebook/Meta; amounts not retrieved.

Exhibit 1090 · News report quoting a board co-chair

Cochrane ousted researcher over improper use of letterhead, co-chair says

Gøtzsche was “baselessly undermining Cochrane’s credibility and independence,” Koster said Thursday.

Reports that Cochrane's governing board co-chair Marguerite Koster said the board's expulsion of Peter Gøtzsche rested on his use of Cochrane Nordic letterhead for personal views, including in a homicide trial, and repeated conduct that she described as baselessly undermining Cochrane's credibility; four board members resigned after the first vote.

Source
STAT (with Retraction Watch)
Date
28 September 2018
Quoted from
Paragraph after the 'Related' box
Grade
Reported
Document
https://www.statnews.com/2018/09/28/cochrane-ousted-researcher-over-letterhead-use/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Grade reported. The Board's own statement is exhibit cochrane-2018-governing-board-gotzsche-statement (exhibit 944).

Exhibit 1091 · Institutional statement

Cochrane's Editor in Chief responds to BMJ EBM article criticizing HPV review

The BMJ Evidence-Based Medicine article substantially overstated its criticisms.

Responds to the 27 July 2018 BMJ Evidence-Based Medicine article by Gøtzsche and Jefferson on Cochrane's HPV vaccine review. Says an investigation with review authors, editors and independent researchers found the review did not miss 'nearly half of the eligible trials' and that the article 'substantially overstated its criticisms.'

Source
Cochrane (Editor in Chief David Tovey)
Date
29 August 2018
Quoted from
Key findings, last bullet
Grade
Primary record
Document
https://www.cochrane.org/about-us/news/cochranes-editor-chief-responds-bmj-ebm-article-criticizing-hpv-review
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Cochrane's Board gave other grounds for the 25 September 2018 expulsion (exhibit 944). Research-side counterstatements are in the Gøtzsche library entry (response items 3-12).

Exhibit 1092 · Peer-reviewed article

Some Dare Call It Conspiracy: Labeling Something a Conspiracy Theory Does Not Reduce Belief in It

In Experiment 1, 150 participants judged a list of historical and speculative theories to be no less likely when they were labeled “conspiracy theories” than when they were labeled “ideas.”

Two online experiments (Amazon Mechanical Turk, N=150 and N=802). Items labeled 'conspiracy theories' were judged no less likely than the same items labeled 'ideas,' and fictitious corruption allegations were endorsed no less when labeled 'conspiracy theories.' The author calls the null result unexpected.

Source
Michael J. Wood, Political Psychology 37(5):695-705
Date
2016
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1111/pops.12285
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote read in the abstract as served by the OpenAlex API; confirm against the publisher page before publication.

Exhibit 1093 · Peer-reviewed article

Popper Revisited, or What Is Wrong With Conspiracy Theories?

Yet history appears to be littered with conspiracies successful and otherwise.

Philosophical argument that Popper's critique targets 'the conspiracy theory of society,' a view no sane person holds, and creates no presumption against conspiracy theories of particular events; history contains many conspiracies.

Source
Charles R. Pigden, Philosophy of the Social Sciences 25(1):3-34
Date
1995
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1177/004839319502500101
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote read in the abstract as served by the OpenAlex API; confirm against the publisher page before publication.

Exhibit 1094 · Peer-reviewed article

Misinformation and Its Correction: Continued Influence and Successful Debiasing

We look at people's memory for misinformation and answer the questions of why retractions of misinformation are so ineffective in memory updating and why efforts to retract misinformation can even backfire and, ironically, increase misbelief.

Review of why retractions often fail to remove the influence of misinformation (the 'continued influence effect') and of techniques for debunking.

Source
Lewandowsky, Ecker, Seifert, Schwarz, Psychological Science in the Public Interest 13(3):106-131
Date
2012
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1177/1529100612451018
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote read in the abstract as served by the OpenAlex API; confirm against the publisher page before publication.

Exhibit 1095 · Peer-reviewed article

Sources of the continued influence effect: When misinformation in memory affects later inferences

The results showed that Ss continued to make inferences involving discredited information when it afforded causal structure, but not when only incidentally mentioned or primed during an intervening task.

Laboratory experiments on the continued influence effect; providing a plausible causal alternative, rather than simply negating the misinformation, reduced it.

Source
Hollyn M. Johnson and Colleen M. Seifert, Journal of Experimental Psychology: Learning, Memory, and Cognition 20(6):1420-1436
Date
1994
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1037/0278-7393.20.6.1420
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote read in the abstract as served by the OpenAlex API; confirm against the publisher page before publication.

Exhibit 1096 · Peer-reviewed article

A Meta-Analytic Examination of the Continued Influence of Misinformation in the Face of Correction

on average, correction does not entirely eliminate the effect of misinformation

Meta-analysis of 32 studies (N = 6,527). Correction does not entirely eliminate the effect of misinformation; corrections are less effective if the misinformation was attributed to a credible source, repeated before correction, or if time elapsed before correction.

Source
Nathan Walter and Riva H. Tukachinsky, Communication Research 47(2):155-177
Date
2020
Quoted from
Abstract (first sentence after the study count)
Grade
Peer-reviewed
Document
https://doi.org/10.1177/0093650219854600
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote read in the abstract as served by the OpenAlex API; confirm against the publisher page before publication.

Exhibit 1097 · Peer-reviewed article

Fact-Checking: A Meta-Analysis of What Works and for Whom

Fact-checking has a significantly positive overall influence on political beliefs (d = 0.29), but the effects gradually weaken when using “truth scales,” refuting only parts of a claim, and fact-checking campaign-related statements.

Meta-analysis (k = 30, N = 20,963). Fact-checking has a significantly positive overall effect on political beliefs (d = 0.29), weaker with truth scales, partial refutations and campaign statements, and substantially attenuated by preexisting beliefs, ideology and knowledge.

Source
Walter, Cohen, Holbert and Morag, Political Communication 37(3):350-375
Date
2020
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1080/10584609.2019.1668894
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote read in the abstract as served by the OpenAlex API; confirm against the publisher page before publication.

Exhibit 1098 · Peer-reviewed article

Belief Echoes: The Persistent Effects of Corrected Misinformation

Across three separate experiments, I find that exposure to negative political information continues to shape attitudes even after the information has been effectively discredited.

Three experiments: exposure to negative political information keeps shaping attitudes after it has been discredited, including when corrected immediately.

Source
Emily A. Thorson, Political Communication 33(3):460-480
Date
2016
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1080/10584609.2015.1102187
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote read in the abstract as served by the OpenAlex API; confirm against the publisher page before publication.

Exhibit 1099 · Peer-reviewed article

The Implied Truth Effect: Attaching Warnings to a Subset of Fake News Headlines Increases Perceived Accuracy of Headlines Without Warnings

an implied truth effect, whereby false headlines that fail to get tagged are considered validated and thus are seen as more accurate.

Two MTurk experiments (n = 5,271 and 1,568) and a Bayesian model. Warnings modestly reduce perceived accuracy of tagged false headlines, but untagged false headlines are seen as more accurate; attaching verifications to some true headlines eliminates the effect.

Source
Pennycook, Bear, Collins and Rand, Management Science 66(11):4944-4957
Date
2020
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1287/mnsc.2019.3478
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Crossref abstract, retrieved 10 November 2026. Quote read in the abstract as served by the OpenAlex API; confirm against the publisher page before publication.

Exhibit 1100 · Peer-reviewed article

Fake Claims of Fake News: Political Misinformation, Warnings, and the Tainted Truth Effect

However, when informative news is wrongly labeled as inaccurate, these false warnings reduce the news’ credibility.

Experiments on retrospective misinformation warnings. Valid warnings help people discard erroneous information, though weakly; when accurate news is wrongly labeled inaccurate, the false warning reduces its credibility.

Source
Freeze, Baumgartner, Bruno, Gunderson and others, Political Behavior 43(4):1433-1465
Date
2021
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1007/s11109-020-09597-3
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote read in the abstract as served by the OpenAlex API; confirm against the publisher page before publication.

Exhibit 1101 · Peer-reviewed article

Checking how fact-checkers check

Surprisingly, only one in 10 statements was found to be fact-checked by both fact-checkers.

Compares two U.S. fact-checkers (Fact Checker and PolitiFact) by inter-rater reliability. Only one in ten statements was checked by both; agreement was lower on ambiguous ratings.

Source
Chloe Lim, Research & Politics 5(3)
Date
2018
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1177/2053168018786848
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote read in the abstract as served by the OpenAlex API; confirm against the publisher page before publication.

Exhibit 1102 · Peer-reviewed article

Fact-Checking Polarized Politics: Does The Fact-Check Industry Provide Consistent Guidance on Disputed Realities?

A content analysis of the published fact-checks addressing three disputed realties – the existence of climate change, the influence of racism, and the consequences of the national debt – suggests substantial differences in the questions asked and the answers offered, limiting the usefulness of fact-checking for citizens trying to decide which version of disputed realities to believe.

Content analysis of three major fact-check sites on three disputed realities (climate change, racism, the national debt).

Source
Marietta, Barker and Bowser, The Forum 13(4):577-596
Date
2015
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1515/for-2015-0040
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote read in the abstract as served by the OpenAlex API; confirm against the publisher page before publication.

Exhibit 1103 · Social-media thread (Twitter Files)

The Twitter Files, Part One: How and Why Twitter Blocked the Hunter Biden Laptop Story (thread, 2 December 2022)

Both parties had access to these tools. For instance, in 2020, requests from both the Trump White House and the Biden campaign were received and honored. However:

Forty-post thread by Matt Taibbi, the first Twitter Files release. Post 8 says that by 2020 'requests from connected actors to delete tweets were routine' and shows an email screenshot (read from the Wayback copy of the image, see exhibit twitter-2020-email-biden-team-review). Post 10 says requests from both the Trump White House and the Biden campaign were 'received and honored'; post 11 says the system 'wasn't balanced' because Twitter staff had more channels open to Democrats. Posts 17 to 28 describe Twitter's 14 October 2020 block of the New York Post laptop story and an internal debate over its hacked-materials basis. Post 22 says the author saw 'no evidence' of government involvement in that decision, only a 'general' warning from federal law enforcement that summer. The thread names no document for the Trump White House request it describes in post 10.

Source
Matt Taibbi (@mtaibbi), Twitter thread
Date
2 December 2022
Quoted from
Post 10 of 40 (thread of 2 Dec 2022, Thread Reader copy; the author skips numbers 13-15 in the thread)
Grade
Reported
Document
https://twitter.com/mtaibbi/status/1598822959866683394
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: internal Twitter documents as selected, screenshotted and described by the thread's author after Twitter's owner gave the writers access; no complete archive is public and the one X capture opened (Part 1) rendered as an empty shell in the Wayback Machine, so the readable copy is the Thread Reader capture linked under archive (the posts themselves were not re-opened on X). The primary documents that would replace it are the underlying emails and Slack messages, which a court, Twitter or a regulator has not produced in full.

Exhibit 1104 · Internal email (screenshot)

Twitter internal emails of 24-25 October 2020: 'More to review from the Biden team' and 'An additional report from DNC' (screenshots in Twitter Files Part 1, posts 8 and 9)

More to review from the Biden team:

Two screenshots read from Wayback copies of the images. The first shows an email of Saturday 24 October 2020, 5:39 PM, from a Twitter employee, headed 'More to review from the Biden team:' with five tweet links, and a reply at 8:28 PM reading 'handled these.' (the thread's text renders the reply as 'Handled.'). The second (https://web.archive.org/web/20261023235314im_/https://pbs.twimg.com/media/FjAuD6eWAAEFiXY.jpg) shows a 24 October 6:54 PM email 'An additional report from DNC.' with two links, and a 25 October 9:58 AM reply 'I grabbed the first one under SI... defer to Safety on the high profile second one'. Both emails are from a Twitter employee, with the sender names redacted; the screenshots do not show who sent the reports being forwarded. The screenshots do not say what action 'handled' or 'grabbed' means.

Source
Twitter, Inc. (internal email, as screenshotted by Matt Taibbi)
Date
24-25 October 2020
Quoted from
Screenshot at Twitter Files Part 1, post 8 (image FjAtMntXkAM-CZC.jpg), first line of the 24 Oct 2020 5:39 PM message; reply 8:28 PM 'handled these.'
Grade
Reported
Document
https://twitter.com/mtaibbi/status/1598822959866683394
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported and unauthenticated by a court: Twitter's owner released the documents to the writers, but no court or regulator has authenticated these two screenshots. Twitter's counsel quoted other Twitter Files emails (FBI reports, Pls.' Ex. A.30) without disputing them in a June 2023 filing (exhibit twitter-2023-opposition-trump-v-twitter). Publish only as 'reported' with the release path stated, and never for a claim that a government or a campaign instructed a removal: the emails are from a Twitter employee and the sender names are redacted.

Exhibit 1105 · Social-media thread (Twitter Files)

The Twitter Files, Part Three: The Removal of Donald Trump, October 2020 - January 6th 2021 (thread, 9 December 2022)

Examining the entire election enforcement Slack, we didn't see one reference to moderation requests from the Trump campaign, the Trump White House, or Republicans generally. We looked. They may exist: we were told they do. However, they were absent here.

Sixty-five-post thread on Twitter's election-period moderation and the January 2021 suspension of Donald Trump. Post 27 states the author's search result for requests from the Trump side: none appeared in the election enforcement Slack channel, though the author says he was told some exist. The thread also shows FBI-forwarded reports of tweets, including one naming a Republican county councilor (post 24).

Source
Matt Taibbi (@mtaibbi), Twitter thread
Date
9 December 2022
Quoted from
Post 27 (Thread Reader copy of the thread of 9 Dec 2022; the capsule index dates it 9 December)
Grade
Reported
Document
https://twitter.com/mtaibbi/status/1601352083617505281
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: internal Twitter documents as selected, screenshotted and described by the thread's author after Twitter's owner gave the writers access; no complete archive is public and the one X capture opened (Part 1) rendered as an empty shell in the Wayback Machine, so the readable copy is the Thread Reader capture linked under archive (the posts themselves were not re-opened on X). The primary documents that would replace it are the underlying emails and Slack messages, which a court, Twitter or a regulator has not produced in full.

Exhibit 1106 · Social-media thread (Twitter Files)

The Twitter Files, Part Six: Twitter, the FBI Subsidiary (thread, 16 December 2022)

Between January 2020 and November 2022, there were over 150 emails between the FBI and former Twitter Trust and Safety chief Yoel Roth.

Forty-five-post thread. It says there were over 150 emails between the FBI and Twitter's Trust and Safety chief between January 2020 and November 2022, and that a 'surprisingly high number' were FBI requests that Twitter act on election misinformation. It shows an FBI San Francisco notice of four accounts (November 2022), a list from the FBI National Election Command Post (5 November 2022), a Twitter attorney's 16 September 2022 note on a weekly meeting with DHS, DOJ, FBI and ODNI, and states that state governments, CISA-linked portals and a Stanford project also sent reports (posts 36 to 43). Post 40 shows California officials alerting Twitter, through a partner support portal, to a tweet by Donald Trump.

Source
Matt Taibbi (@mtaibbi), Twitter thread
Date
16 December 2022
Quoted from
Post 4 of 45 (Thread Reader copy of the thread of 16 Dec 2022)
Grade
Reported
Document
https://twitter.com/mtaibbi/status/1603857534737072128
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: internal Twitter documents as selected, screenshotted and described by the thread's author after Twitter's owner gave the writers access; no complete archive is public and the one X capture opened (Part 1) rendered as an empty shell in the Wayback Machine, so the readable copy is the Thread Reader capture linked under archive (the posts themselves were not re-opened on X). The primary documents that would replace it are the underlying emails and Slack messages, which a court, Twitter or a regulator has not produced in full.

Exhibit 1107 · Social-media thread (Twitter Files)

Twitter Files Part 7: The FBI & the Hunter Biden Laptop (thread, 19 December 2022)

I am happy to report we have collected $3,415,323 since October 2019!

Fifty-post thread on FBI and intelligence-community contacts with Twitter before and after the 14 October 2020 New York Post story. Post 7 says Special Agent Elvis Chan sent ten documents to Twitter's head of site integrity through the one-way Teleporter channel on 13 October 2020. Post 34 quotes Yoel Roth on 14 October 2020 that the story 'isn't clearly violative of our Hacked Materials Policy'. Post 46 quotes an email giving a total of $3,415,323 collected 'since October 2019'. A correction at the end of the thread says the Aspen Institute exercise described in post 30 occurred on 25 June 2020, not in September. Already audited in research/library/audits/twitter-files-2022-murthy-v-missouri.json; registered here so findings can cite it.

Source
Michael Shellenberger (@ShellenbergerMD), Twitter thread
Date
19 December 2022
Quoted from
Post 46 of 50 (quoting an early-2021 email by an associate of Jim Baker; Thread Reader copy of the thread of 19 Dec 2022)
Grade
Reported
Document
https://twitter.com/ShellenbergerMD/status/1604871630613753856
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: internal Twitter documents as selected, screenshotted and described by the thread's author after Twitter's owner gave the writers access; no complete archive is public and the one X capture opened (Part 1) rendered as an empty shell in the Wayback Machine, so the readable copy is the Thread Reader capture linked under archive (the posts themselves were not re-opened on X). The primary documents that would replace it are the underlying emails and Slack messages, which a court, Twitter or a regulator has not produced in full.

Exhibit 1108 · Social-media thread (Twitter Files)

Twitter Files Part 8: How Twitter Quietly Aided the Pentagon's Covert Online PsyOp Campaign (thread, 20 December 2022)

In 2017, a U.S. Central Command (CENTCOM) official sent Twitter a list of 52 Arab language accounts “we use to amplify certain messages.” The official asked for priority service for six accounts, verification for one & “whitelist” abilities for the others.

Twenty-two-post thread. A government agency asked Twitter for special treatment of its own accounts: in 2017 a U.S. Central Command official sent Twitter a list of 52 Arabic-language accounts and asked for priority service, verification and 'whitelist' status; Twitter applied a whitelist tag the same day. The thread says Twitter executives knew in 2020 that Pentagon accounts used covert identities and did not suspend some of them until May 2022 or later. The author states Twitter 'had no input' into his reporting and that a Twitter attorney ran the searches, so what he saw could be limited. A Stanford Internet Observatory and Graphika report of August 2022 is cited for the network.

Source
Lee Fang (@lhfang), Twitter thread
Date
20 December 2022
Quoted from
Post 4 of 22 (Thread Reader copy of the thread of 20 Dec 2022)
Grade
Reported
Document
https://twitter.com/lhfang/status/1605292454261182464
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: internal Twitter documents as selected, screenshotted and described by the thread's author after Twitter's owner gave the writers access; no complete archive is public and the one X capture opened (Part 1) rendered as an empty shell in the Wayback Machine, so the readable copy is the Thread Reader capture linked under archive (the posts themselves were not re-opened on X). The primary documents that would replace it are the underlying emails and Slack messages, which a court, Twitter or a regulator has not produced in full.

Exhibit 1109 · Social-media thread (Twitter Files)

The Twitter Files: Twitter and "Other Government Agencies" (thread, 24 December 2022)

Our window on that is closing, given that government partners are becoming more aggressive on attribution.

Fifty-eight-post thread on the FBI Foreign Influence Task Force meetings and intelligence reports sent to Twitter. It says an 'OGA' (other government agency) attended meetings, that FBI San Francisco forwarded domestic requests from state governments and local police, and that Twitter staff repeatedly found no evidence for foreign-influence claims. Post 40 quotes a Twitter executive's email that the company's 'window' for independent attribution was closing as government partners became more aggressive. The author states Twitter had no input and that third parties ran the searches. The 'OGA' reading as the CIA is the author's, attributed to former officials.

Source
Matt Taibbi (@mtaibbi), Twitter thread
Date
24 December 2022
Quoted from
Post 40 of 58 (quoting an email of a Twitter executive, undated in the thread; Thread Reader copy of the thread of 24 Dec 2022)
Grade
Reported
Document
https://twitter.com/mtaibbi/status/1606701397109796866
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: internal Twitter documents as selected, screenshotted and described by the thread's author after Twitter's owner gave the writers access; no complete archive is public and the one X capture opened (Part 1) rendered as an empty shell in the Wayback Machine, so the readable copy is the Thread Reader capture linked under archive (the posts themselves were not re-opened on X). The primary documents that would replace it are the underlying emails and Slack messages, which a court, Twitter or a regulator has not produced in full.

Exhibit 1110 · Social-media thread (Twitter Files)

The Twitter Files: How Twitter Let the Intelligence Community In (thread, 3 January 2023)

identified by the U.S.. intelligence community as a state-sponsored entity conducting cyber-operations.

Thirty-four-post thread on the second half of 2017. It describes Twitter's internal review of Russia-linked accounts, an October 2017 conclusion that few were connected to Russia, a September 2017 press conference by Senator Mark Warner calling Twitter's report 'frankly inadequate on every level', and a Twitter policy director's note on legislation that Senators Warner, Klobuchar and McCain would introduce. Post 31 says Twitter settled on removing content 'at our sole discretion' in public while privately agreeing to off-board accounts identified by the U.S. intelligence community as state-sponsored cyber operations.

Source
Matt Taibbi (@mtaibbi), Twitter thread
Date
3 January 2023
Quoted from
Post 31 of 34 (Thread Reader copy of the thread of 3 Jan 2023; the double period is in the copy)
Grade
Reported
Document
https://twitter.com/mtaibbi/status/1610372352872783872
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: internal Twitter documents as selected, screenshotted and described by the thread's author after Twitter's owner gave the writers access; no complete archive is public and the one X capture opened (Part 1) rendered as an empty shell in the Wayback Machine, so the readable copy is the Thread Reader capture linked under archive (the posts themselves were not re-opened on X). The primary documents that would replace it are the underlying emails and Slack messages, which a court, Twitter or a regulator has not produced in full.

Exhibit 1111 · Social-media thread (Twitter Files)

The Twitter Files: Twitter and the FBI "Belly Button" (thread, 3 January 2023)

When the State Department/GEC – remember this was 2020, during the Trump administration – wanted to publicize a list of 5,500 accounts it claimed would “amplify Chinese propaganda and disinformation” about COVID, Twitter analysts were beside themselves.

Forty-post thread on 2020 to 2022. It says the State Department's Global Engagement Center (GEC) sought in 2020 to publicize a list of 5,500 accounts, that Twitter, Facebook and Google opposed adding the GEC to the FBI-DHS industry calls, and that FBI agent Elvis Chan proposed the FBI act as the 'belly button of the USG'. Posts 26 to 28 show requests from Treasury, NSA, states and HHS and a request from the office of Representative Adam Schiff, as House Intelligence Committee chair, to suspend a journalist, which the thread says Twitter declined. The thread marks the GEC episode as occurring 'during the Trump administration'.

Source
Matt Taibbi (@mtaibbi), Twitter thread
Date
3 January 2023
Quoted from
Post 10 of 40 (Thread Reader copy of the thread of 3 Jan 2023)
Grade
Reported
Document
https://twitter.com/mtaibbi/status/1610394197730725889
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: internal Twitter documents as selected, screenshotted and described by the thread's author after Twitter's owner gave the writers access; no complete archive is public and the one X capture opened (Part 1) rendered as an empty shell in the Wayback Machine, so the readable copy is the Thread Reader capture linked under archive (the posts themselves were not re-opened on X). The primary documents that would replace it are the underlying emails and Slack messages, which a court, Twitter or a regulator has not produced in full.

Exhibit 1112 · Social-media thread (Twitter Files)

Twitter Files Supplemental: More Adam Schiff Ban Requests, and "Deamplification" (thread, 13 January 2023)

Twitter also refused requests for bans of content about Schiff and his staff

Ten-post thread. It says staff of Representative Adam Schiff, then chair of the House Intelligence Committee, and the Democratic National Committee asked Twitter to remove a doctored parody image of Joe Biden that Donald Trump had retweeted, that Twitter's Trust and Safety chief refused, and that Twitter also refused requests to suppress all search results about committee staffers. It reproduces a Schiff office message thanking Twitter for 'deamplification' while asking that it not hinder law enforcement searches.

Source
Matt Taibbi (@mtaibbi), Twitter thread
Date
13 January 2023
Quoted from
Post 5 of 10 (Thread Reader copy of the thread of 13 Jan 2023)
Grade
Reported
Document
https://twitter.com/mtaibbi/status/1613932017716195329
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: internal Twitter documents as selected, screenshotted and described by the thread's author after Twitter's owner gave the writers access; no complete archive is public and the one X capture opened (Part 1) rendered as an empty shell in the Wayback Machine, so the readable copy is the Thread Reader capture linked under archive (the posts themselves were not re-opened on X). The primary documents that would replace it are the underlying emails and Slack messages, which a court, Twitter or a regulator has not produced in full.

Exhibit 1113 · Social-media thread (Twitter Files)

Twitter Files #16: Comic Interlude: A Media Experiment (thread, 18-19 February 2023)

The below are some Russian controlled accounts that I think you will want to look into and delete.

Seventeen-post thread. It publishes two requests to Twitter from public officials of different affiliations: a list of accounts that Senator Angus King's office called 'suspicious' (with reasons such as 'Mentions immigration'), and a message from Mark Lenzi, a State Department official the thread calls a Republican, asking Twitter to 'look into and delete' 14 accounts. The thread says the House testimony about a Trump request to remove a Chrissy Teigen tweet (see engadget-2023-trump-white-house-teigen-request) prompted it. The Thread Reader copy dates the thread 19 February 2023; the capsule index dates it 18 February.

Source
Matt Taibbi (@mtaibbi), Twitter thread
Date
18 February 2023
Quoted from
Post 10 of 17 (quoting Lenzi's message; Thread Reader copy)
Grade
Reported
Document
https://twitter.com/mtaibbi/status/1627098945359867904
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: internal Twitter documents as selected, screenshotted and described by the thread's author after Twitter's owner gave the writers access; no complete archive is public and the one X capture opened (Part 1) rendered as an empty shell in the Wayback Machine, so the readable copy is the Thread Reader capture linked under archive (the posts themselves were not re-opened on X). The primary documents that would replace it are the underlying emails and Slack messages, which a court, Twitter or a regulator has not produced in full.

Exhibit 1114 · Social-media thread (Twitter Files)

Twitter Files #17: New Knowledge, the Global Engagement Center, and State-Sponsored Blacklists (thread, 2 March 2023)

Here are 5500 names GEC told Twitter it believed were “Chinese… accounts” engaged in “state-backed coordinated manipulation.”

Forty-eight-post thread on the State Department Global Engagement Center (GEC). It says the Atlantic Council's Digital Forensic Research Lab, which the thread says the GEC funds, sent Twitter about 40,000 accounts on 8 June 2021 (Twitter's Trust and Safety chief found 'virtually all appear to be real people'), and that the GEC sent Twitter lists of 5,500 'Chinese' accounts and 499 Iranian accounts that Twitter staff disputed. It cites an inspector general report for $98.7 million obligated to the GEC. A note says the Lab's director wrote that the 40,000-name list was not published because of low confidence in it.

Source
Matt Taibbi (@mtaibbi), Twitter thread
Date
2 March 2023
Quoted from
Post 14 of 48 (Thread Reader copy of the thread of 2 Mar 2023)
Grade
Reported
Document
https://twitter.com/mtaibbi/status/1631338650901389322
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: internal Twitter documents as selected, screenshotted and described by the thread's author after Twitter's owner gave the writers access; no complete archive is public and the one X capture opened (Part 1) rendered as an empty shell in the Wayback Machine, so the readable copy is the Thread Reader capture linked under archive (the posts themselves were not re-opened on X). The primary documents that would replace it are the underlying emails and Slack messages, which a court, Twitter or a regulator has not produced in full.

Exhibit 1115 · Social-media thread (Twitter Files)

The Twitter Files: How Twitter Rigged the Covid Debate (thread, 26 December 2022)

Internal files at Twitter that I viewed while on assignment for @TheFP showed that both the Trump and Biden administrations directly pressed Twitter executives to moderate the platform’s pandemic content according to their wishes.

Forty-one-post thread. Post 5 says internal files showed that both the Trump and Biden administrations pressed Twitter executives over pandemic content. Posts 6 and 7 describe early-pandemic meeting notes in which the Trump administration, with Google, Facebook and Microsoft also attending, asked for 'help from the tech companies to combat misinformation' about runs on grocery stores. Posts 8 to 12 say one of the Biden administration's first meeting requests to Twitter concerned 'anti-vaxxer accounts', especially Alex Berenson, and that a summary by Twitter's head of U.S. public policy said the Biden team was 'very angry' that Twitter had not deplatformed more accounts (the thread dates that summary December 2022, as printed). Post 13 says Twitter executives 'did not fully capitulate'. The thread's conclusions about bias (posts 17 to 38) are the author's.

Source
David Zweig (@davidzweig), Twitter thread
Date
26 December 2022 (posted 14:10 UTC per the post ID; the capsule index lists 28 December)
Quoted from
Post 5 of 41 (Thread Reader copy; the copy displays 26 Dec 2022)
Grade
Reported
Document
https://twitter.com/davidzweig/status/1607378386338340867
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: internal Twitter documents as selected, screenshotted and described by the thread's author after Twitter's owner gave the writers access; no complete archive is public and the one X capture opened (Part 1) rendered as an empty shell in the Wayback Machine, so the readable copy is the Thread Reader capture linked under archive (the posts themselves were not re-opened on X). The primary documents that would replace it are the underlying emails and Slack messages, which a court, Twitter or a regulator has not produced in full.

Exhibit 1116 · Deposition transcript

Deposition of Elvis Chan (FBI San Francisco), Missouri v. Biden, No. 3:22-cv-01213 (W.D. La.), Doc. 204-1

I would not say it was 100 percent success rate. If I had to characterize it, I would say it was like a 50 percent success rate. But that's just from my recollection.

Sworn testimony of the FBI San Francisco special agent who ran FBI contact with Twitter, Facebook, Google and others. He dates quarterly FBI-company meetings to 2017 (p. 89), describes a 4 September 2019 Facebook-hosted election-security meeting with FBI, DHS and ODNI at which 'the social media companies' discussed removing disinformation and 'the FBI did not' (pp. 151-154), says Twitter announced the takedown of 3,613 accounts in 2018 and 422 accounts in 2019 (pp. 132-134, 149), gives his opinion that congressional pressure was a contributing factor in platform policy changes (p. 132), and puts the share of flagged items that led to action at about half (p. 167). He says FBI San Francisco relayed time, place or manner and foreign-influence reports to the companies on election day and accepted referrals from them (p. 168). Transcript pages are cited; ECF page numbers equal transcript page numbers up to the cover pages (ECF p. 167 of 386 is transcript p. 167).

Source
U.S. District Court, W.D. La. (deposition taken by plaintiffs, 29 November 2022; filed 3 March 2023)
Date
29 November 2022
Quoted from
Chan Dep. 167:5-8 (ECF p. 167 of 386)
Grade
Primary record
Document
https://storage.courtlistener.com/recap/gov.uscourts.lawd.189520/gov.uscourts.lawd.189520.204.1.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1117 · Deposition transcript

Deposition of Brian J. Scully (CISA), Missouri v. Biden, No. 3:22-cv-01213 (W.D. La.), Doc. 209-1

obviously, you know, in 2020 we did some switchboard work on behalf of election officials.

Sworn testimony of the head of CISA's mis-, dis- and malinformation team. He says CISA's work included 'switchboard work' for election officials in 2020 (p. 16), defines it as an election official forwarding material they judged to be disinformation to CISA, which shared it with the appropriate platforms so the platforms could 'make decision on the content ... based on their policies' (p. 17), says CISA held regular government-industry sync meetings with Facebook as the industry lead (p. 21), and, asked about the period since September 2022, says CISA did not switchboard in 2022 (p. 21). The Supreme Court's Murthy opinion describes CISA's switchboarding as running until mid-2022 (slip op. p. 5); the testimony and the opinion differ on 2022, and the record does not reconcile them.

Source
U.S. District Court, W.D. La. (deposition taken 12 January 2023; filed 4 March 2023)
Date
12 January 2023
Quoted from
Scully Dep. 16:22-25 (ECF p. 16 of 456)
Grade
Primary record
Document
https://storage.courtlistener.com/recap/gov.uscourts.lawd.189520/gov.uscourts.lawd.189520.209.1.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1119 · Declaration filed with a regulator

Declaration of Yoel Roth (Twitter Head of Site Integrity), 17 December 2020, Exhibit A to Twitter's response in FEC MUR 7821 / MUR 7827

Twitter's Trust & Safety leadership determined that the New York Post articles violated the Distribution of Hacked Materials Policy and the Private Information Policy and instructed the Site Integrity Team to execute enforcement of those policies.

A declaration made 'upon my personal knowledge and belief' and filed with the Federal Election Commission in a complaint that Twitter's block of the New York Post links was an in-kind contribution. Paragraph 10 says he had regular meetings 'since 2018' with ODNI, DHS, the FBI and industry peers about election security; paragraph 11 says federal law enforcement agencies expected state-actor hack-and-leak operations, likely in October 2020, and that he learned rumors a hack-and-leak operation would involve Hunter Biden. Paragraphs 16 and 17 say Twitter's Trust & Safety leadership determined the articles violated the Distribution of Hacked Materials Policy and the Private Information Policy and the Site Integrity Team executed that enforcement at about 10:20 a.m. Pacific on 14 October 2020. Paragraphs 18 and 19 say neither he nor, to his knowledge, any Twitter employee communicated with Biden for President, the Democratic National Committee or their agents about the articles before enforcement. Pages MUR782700051-54 of the Commission's file.

Source
Twitter, Inc. (counsel Covington & Burling) to the Federal Election Commission
Date
17 December 2020 (response letter of 21 December 2020)
Quoted from
Roth Decl. para. 16 (MUR782700053)
Grade
Primary record
Document
https://eqs.fec.gov/eqsdocsMUR/7827_08.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The FEC file is public. The declaration is Twitter's own statement to a regulator, made before the Twitter Files; it is the platform's account of its decision, not proof that no other contact occurred. The 2023 Judiciary Committee and the Twitter Files threads contest the FBI's part, not paragraph 18. A copy sits in the Missouri v. Biden record (Doc. 204-5 per the earlier audit, not opened).

Exhibit 1120 · Court filing (brief)

Defendants' Opposition to Plaintiffs' Motion for Indicative Ruling under Fed. R. Civ. P. 60, Trump v. Twitter, No. 21-cv-08378-JD (N.D. Cal.), Doc. 195

The emails were phrased in advisory terms, flagging accounts they believed may violate Twitter's policies—and Twitter employees received them as such, independently reviewing the flagged Tweets.

Twitter's answer to plaintiffs' argument that the Twitter Files showed government coercion of Twitter. Twitter argues the FBI emails cited by plaintiffs contain no specific demand to remove content and no threat of sanction, that Twitter employees reviewed the flagged tweets independently, that the FBI payments were reimbursements under 18 U.S.C. 2706 for legal process, and in footnote 6 that the bulk of the FBI communications cited took place before the 2020 elections, 'while Trump was still in office'. It quotes an FBI San Francisco email sending Twitter a report of 207 tweets 'they believe may be in violation of our policies' (Pls.' Ex. A.30). A litigation position taken by a party opposing the motion, not a finding; the district court and Ninth Circuit rulings on the motion are separate.

Source
Twitter, Inc. and Jack Dorsey (WilmerHale), filed in the U.S. District Court, N.D. Cal.
Date
1 June 2023
Quoted from
Opp'n at 12 (ECF p. 16 of 19)
Grade
Primary record
Document
https://storage.courtlistener.com/recap/gov.uscourts.cand.387133/gov.uscourts.cand.387133.195.0.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1121 · Court opinion

O'Handley v. Weber, 62 F.4th 1145 (9th Cir. 2023), No. 22-15071

In the aftermath of the 2020 election, the OEC touted that it had flagged for Facebook and Twitter nearly “300 erroneous or misleading social media posts” and that “98 percent of those posts were promptly removed for violating the respective social media compan[ies’] community standards.”

Holds that Twitter's moderation of a user's post after California's Office of Elections Cybersecurity (OEC) flagged it was not state action. The opinion records that Twitter gave election officials in at least 38 states access to a Partner Support Portal and that California's Secretary of State formed the OEC in 2018. It quotes the OEC's own statement that after the 2020 election it had flagged nearly 300 posts for Facebook and Twitter and that 98 percent were promptly removed. It holds that even if the OEC's message was a request to remove the post, compliance 'was purely optional' with 'no intimation that Twitter would suffer adverse consequences'.

Source
U.S. Court of Appeals for the Ninth Circuit
Date
10 March 2023
Quoted from
Opinion, Background (slip op. p. 7)
Grade
Primary record
Document
https://cdn.ca9.uscourts.gov/datastore/opinions/2023/03/10/22-15071.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1122 · Court opinion

Judicial Watch, Inc. v. U.S. Department of Justice, No. 23-3004 (JEB) (D.D.C.), Memorandum Opinion, Doc. 27

The Federal Bureau of Investigation uses legal process to request information from tech platforms and reimburses them for the cost of complying.

FOIA suit for FBI records of payments to Twitter. The court holds the FBI's quarterly payment totals to Twitter, 2016 to 2023, fall within FOIA Exemption 7(E) and grants DOJ summary judgment. The opinion describes the payments as reimbursements the FBI makes, under 18 U.S.C. 2706(a), for the cost of complying with legal process for online evidence. The opinion's totals remain withheld, so the $3,415,323 figure in Twitter Files Part 7 is not confirmed or contradicted by any court record.

Source
U.S. District Court for the District of Columbia (Chief Judge Boasberg)
Date
4 February 2026
Quoted from
Mem. Op. at 1 (ECF p. 1 of 13)
Grade
Primary record
Document
https://docs.reclaimthenet.org/judicial-watch-v-doj-fbi-twitter-foia-opinion-2026.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The url is a Reclaim The Net mirror of the court's opinion; replace it with the CourtListener or PACER copy of Doc. 27 before publication.

Exhibit 1123 · Court opinion

NetChoice, L.L.C. v. Paxton, No. 21-51178 (5th Cir.), order on remand from the Supreme Court

Because these are fact-intensive questions that must be answered by the district court in the first instance after thorough discovery, we remand.

After Moody v. NetChoice, remands the challenge to Texas House Bill 20 to the district court because the facial-challenge record is underdeveloped: who the law covers, which activities, how covered actors moderate, and how the explanation requirement burdens them.

Source
U.S. Court of Appeals for the Fifth Circuit (Judge Oldham)
Date
7 November 2024
Quoted from
Opinion at 2
Grade
Primary record
Document
https://www.ca5.uscourts.gov/opinions/pub/21/21-51178-CV1.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1124 · Court opinion

Moody v. NetChoice, LLC, 603 U.S. 707 (2024) (Nos. 22-277 and 22-555)

But a State may not interfere with private actors' speech to advance its own vision of ideological balance.

Vacates and remands the Eleventh Circuit and Fifth Circuit judgments on Florida SB 7072 and Texas HB 20 because neither court did the required facial analysis. The majority also states how the First Amendment applies to platforms' content moderation and says the Fifth Circuit's decision rested on 'a serious misunderstanding of First Amendment precedent and principle' (Syllabus p. 3). It quotes Texas's main sponsor ('West Coast oligarchs' who were 'silenc[ing] conservative viewpoints and ideas') and the Governor's signing remark about 'silenc[ing]' conservatives as the stated purpose of HB 20, and states the principle in the quotation below.

Source
Supreme Court of the United States (Justice Kagan for the Court)
Date
1 July 2024
Quoted from
Opinion of the Court, slip op. p. 27 (also Syllabus p. 5)
Grade
Primary record
Document
https://www.supremecourt.gov/opinions/23pdf/22-277_d18f.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1125 · State statute

Texas House Bill 20 (2021), Tex. Civ. Prac. & Rem. Code ch. 143A and Tex. Bus. & Com. Code ch. 120 (enrolled text)

A social media platform may not censor a user, a user's expression, or a user's ability to receive the expression of another person based on: (1) the viewpoint of the user or another person;

Bars a social media platform with more than 50 million active U.S. users a month from censoring a user or a user's expression based on viewpoint, and requires public disclosures and a complaint-and-appeal process. The Supreme Court in Moody v. NetChoice (2024) quotes the law's sponsor and the Governor on its purpose.

Source
Texas Legislature, 87th Legislature, Second Called Session
Date
2021
Quoted from
Sec. 143A.002(a)(1)
Grade
Primary record
Document
https://capitol.texas.gov/tlodocs/872/billtext/pdf/HB00020F.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The enrolled-bill PDF text layer inserts 'AA' characters; the wording above was checked with those removed. The date of the Governor's signature is not in this PDF.

Exhibit 1126 · State statute

Florida Senate Bill 7072 (2021), Chapter 2021-32, Laws of Florida

A social media platform may not willfully deplatform a candidate for office who is known by the social media platform to be a candidate, beginning on the date of qualification and ending on the date of the election or the date the candidate ceases to be a candidate.

Creates section 106.072, Florida Statutes, barring a social media platform from willfully deplatforming a candidate for office, with fines, and section 501.2041 on notice, consistency and appeal duties for platforms above stated size thresholds (annual gross revenue over $100 million or more than 100 million monthly active users, as the Supreme Court describes them in Moody).

Source
Florida Legislature
Date
24 May 2021 (approved by the Governor; effective 1 July 2021)
Quoted from
s. 106.072(2), as created by Ch. 2021-32, section 1
Grade
Primary record
Document
https://laws.flrules.org/files/Ch_2021-032.pdf
Accessed
2026-11-10
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Exhibit 1127 · Court opinion

X Corp. v. Bonta, No. 24-271 (9th Cir.) (California Assembly Bill 587)

At minimum, the Content Category Report provisions likely fail under strict scrutiny because they are not narrowly tailored.

Reverses denial of a preliminary injunction against the content-category reporting provisions of California AB 587, which required large platforms to report whether and how they define six categories of content, including 'disinformation or misinformation' and 'foreign political interference', and holds they likely violate the First Amendment. The case is the California counterpart to the Texas and Florida statutes: a state law reaching platform moderation decisions, challenged by a platform and held likely unconstitutional.

Source
U.S. Court of Appeals for the Ninth Circuit (Judge M. Smith)
Date
4 September 2024
Quoted from
Opinion, Part III.B (pdf p. 26)
Grade
Primary record
Document
https://cdn.ca9.uscourts.gov/datastore/opinions/2024/09/04/24-271.pdf
Accessed
2026-11-10
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Exhibit 1128 · Court order

Supremo Tribunal Federal, Pet 12.404/DF, Decision of Justice Alexandre de Moraes (suspension of X in Brazil), 30 August 2024

A SUSPENSÃO IMEDIATA, COMPLETA E INTEGRAL DO FUNCIONAMENTO DO “X BRASIL INTERNET LTDA” em território nacional, até que todas as ordens judiciais proferidas nos presentes autos sejam cumpridas, as multas devidamente pagas e seja indicado, em juízo, a pessoa física ou jurídica representante em território nacional.

Portuguese-language decision in a criminal investigation opened on a Federal Police report (obstruction of criminal-organization investigations; incitement to crime) into the exposure and threatening of federal police delegates and their families. It recounts the 7 August 2024 order that Twitter Inc. block the listed accounts within two hours or pay R$50,000 a day, and orders the 'immediate, complete and full' suspension of X Brasil Internet Ltda. in Brazil until all orders are met, fines paid and a legal representative named in Brazil, with ANATEL to carry it out, and orders Apple and Google to remove the X app and VPN apps and imposes a R$50,000 daily fine on users who use VPNs to keep using X (p. 50). The decision lifts secrecy on itself. The Court later (27 September, 1 and 8-9 October 2024) found the accounts blocked, a representative named and fines paid, and authorized X to resume (per the Columbia case summary, exhibit columbia-2024-x-ban-brazil).

Source
Supremo Tribunal Federal (Brazil), Justice Alexandre de Moraes (rapporteur); joined by the First Panel on 2-3 September 2024
Date
30 August 2024
Quoted from
Decision, dispositive paragraph (1), p. 49 (document p. 49 of 51)
Grade
Primary record
Document
https://globalfreedomofexpression.columbia.edu/wp-content/uploads/2024/10/1-Decision-08.30-Portuguese-MAIN-DECISION.pdf
Accessed
2026-11-10
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Findings citing this exhibit
Note
Source is the Columbia Global Freedom of Expression copy of the STF decision; replace with the STF portal copy (code 464B-AE3A-9603-87AD per the document's authentication stamp). Portuguese original; English wording in the summary is the researcher's translation.

Exhibit 1129 · Case summary

The Case of the X Ban in Brazil (Columbia Global Freedom of Expression case page)

Despite our numerous appeals to the Supreme Court not being heard, the Brazilian public not being informed about these orders and our Brazilian staff having no responsibility or control over whether content is blocked on our platform, Moraes has chosen to threaten our staff in Brazil rather than respect the law or due process.

Case summary of the STF proceedings of 7 August to 9 October 2024. It quotes a post by X's Global Government Affairs account (the page places Musk's statement on 17 August 2024) saying X would close its Brazil operation because of 'demands' by Justice Moraes, and records the 18 August asset freeze, the 28 August notice to Elon Musk, the 30 August suspension, X's compliance on 18 September and the authorization to resume on 9 October 2024 after payment of BRL 28,600,000 in fines. Links the STF decisions of 30 August, 18 September, 27 September, 1 October and 8 October 2024.

Source
Global Freedom of Expression, Columbia University
Date
October 2024
Quoted from
Facts section, quoting the X Global Government Affairs post (undated on the page)
Grade
Reported
Document
https://globalfreedomofexpression.columbia.edu/cases/the-case-of-the-x-ban-in-brazil/
Accessed
2026-11-10
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Findings citing this exhibit
Note
Reported: X's statement is known through this case summary; replace with a capture of the X Global Government Affairs post. The summary's dates were checked only against the STF decision of 30 August 2024.

Exhibit 1130 · Court filing (complaint)

Amended Complaint, Aaron v. Bondi, No. 1:25-cv-04250-DLF (D.D.C.), Doc. 22

We reached out to Apple today demanding they remove the ICEBlock app from their App Store — and Apple did so.

Allegations by the maker of the ICEBlock app that in October 2025 the Attorney General and other officials coerced Apple into removing it. It quotes the Attorney General's statements (2 October 2025 on Fox News, 7 October 2025 before the Senate Judiciary Committee, 8 October 2025 in a speech) and Apple's public statement of 2 October 2025 that, 'Based on information we've received from law enforcement about the safety risks associated with ICEBlock, we have removed it and similar apps'. These are plaintiffs' allegations, not findings. The defendants moved to dismiss; as of a notice filed 21 August 2026 (Doc. 30) that motion was pending.

Source
Joshua Aaron and All U Chart, Inc. (plaintiffs; Sher Tremonte LLP), filed in the U.S. District Court for the District of Columbia
Date
16 March 2026
Quoted from
Am. Compl. para. 115, quoting the Attorney General on Fox News, 2 October 2025
Grade
Primary record
Document
https://www.eff.org/files/2026/04/30/amended_complaint_-_d.d.c._25-cv-04250_dckt_000022.pdf
Accessed
2026-11-10
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Note
Reported through a complaint: the Attorney General's words are quoted from the plaintiffs' pleading. Replace with the Fox News broadcast and the Senate Judiciary Committee hearing transcript of 7 October 2025. The complaint also alleges Google and Meta acted on federal contacts; those paragraphs were not checked.

Exhibit 1131 · Court filing (brief)

Defendants' Reply in Support of Their Motion to Dismiss, Aaron v. Bondi, No. 1:25-cv-04250-DLF (D.D.C.), Doc. 28

As Plaintiffs themselves acknowledge in their operative complaint, Apple removed Plaintiffs' App because—as Apple itself stated—ICEBlock violated the App Store Guidelines.

The federal defendants' position: Apple removed the app 'as Apple itself stated' because it violated App Store Guidelines; the complaint does not trace the removal to government communications rather than to Apple's 'independent incentives to moderate content', quoting Murthy v. Missouri; and it does not allege the ongoing pressure campaign Murthy requires for prospective relief. The brief states Todd Blanche has been substituted as Acting Attorney General and Markwayne Mullin as Secretary of Homeland Security. A litigation position, not a finding.

Source
U.S. Department of Justice for the federal defendants, filed in the U.S. District Court for the District of Columbia
Date
24 April 2026
Quoted from
Reply, Introduction (ECF p. 5 of 25)
Grade
Primary record
Document
https://storage.courtlistener.com/recap/gov.uscourts.dcd.287435/gov.uscourts.dcd.287435.28.0.pdf
Accessed
2026-11-10
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Exhibit 1132 · Congressional staff report

The Weaponization of CISA: How a "Cybersecurity" Agency Colluded with Big Tech and "Disinformation" Partners to Censor Americans (interim staff report)

By 2020, CISA routinely reported social media posts that allegedly spread “disinformation” to social media platforms.

Majority staff report on CISA and platform content reports, 2018 to 2022, drawing on the Scully deposition (Doc. 209) and CISA advisory-committee documents. It states that CISA's switchboarding to platforms existed by 2020 and a formal mis-, dis- and malinformation team by 2021, and that CISA outsourced reporting to a nonprofit in 2022 after suit was filed. CISA rejected the findings (per press reports, not read). Characterizations ('metastasized', 'duplicitously') are the Committee's; the underlying testimony is cited separately.

Source
House Committee on the Judiciary and Select Subcommittee on the Weaponization of the Federal Government (majority staff)
Date
26 June 2023
Quoted from
Executive Summary, p. 1
Grade
Primary record
Document
https://judiciary.house.gov/sites/evo-subsites/republicans-judiciary.house.gov/files/evo-media-document/cisa-staff-report6-26-23.pdf
Accessed
2026-11-10
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Findings citing this exhibit
Note
A majority staff report is the Committee's own document: primary for what the Committee states, not for the facts it characterizes. Cite the deposition or the document the report quotes for any fact.

Exhibit 1133 · Congressional staff report

The Censorship-Industrial Complex: How Top Biden White House Officials Coerced Big Tech to Censor Americans, True Information, and Critics of the Biden Administration (interim staff report)

[H]e was outraged – not too strong of a word to describe his reaction – that we did not remove this post.

Majority staff report built on subpoenaed internal company emails from Meta, Alphabet and Amazon. It reproduces a Meta executive's April 2021 email describing a call with a White House senior adviser who was 'outraged' that Meta had not removed a post, and states that by the end of 2021 Facebook, YouTube and Amazon changed content-moderation policies 'in ways that were directly responsive to criticism from the Biden Administration'. That last sentence is the Committee's characterization. The report also says that Facebook and Amazon referred to the White House's efforts as 'pressure'.

Source
House Committee on the Judiciary and Select Subcommittee on the Weaponization of the Federal Government (majority staff)
Date
1 May 2024
Quoted from
Executive Summary, p. 1 (epigraph quoting a Meta email of April 2021)
Grade
Primary record
Document
https://judiciary.house.gov/sites/evo-subsites/republicans-judiciary.house.gov/files/evo-media-document/Biden-WH-Censorship-Report-final.pdf
Accessed
2026-11-10
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Findings citing this exhibit
Note
The epigraph is the Committee's rendering of a Meta internal email produced under subpoena (authentic as a Meta document by its production). The report's appendix PDF (Censorship-Industrial-Complex-WH-Report_Appendix.pdf) was not opened.

Exhibit 1134 · Congressional staff report

The Foreign Censorship Threat: How the European Union's Digital Services Act Compels Global Censorship and Infringes on American Free Speech (interim staff report, with appendix of exhibits)

Nonpublic documents reveal that European regulators use the DSA: (1) to target core political speech that is neither harmful nor illegal; and (2) to pressure platforms, primarily American social media companies, to change their global content moderation policies in response to European demands.

Majority staff report on subpoenaed communications between nine technology companies and European regulators. It reproduces as exhibits the Commission's letters: Commissioner Breton's 12 August 2024 letter to X (Ex. 16, see ec-2024-breton-letter-to-musk), Chairman Jordan's reply of 15 August (Ex. 17), Breton's reply of 21 August (Ex. 18) and Executive Vice-President Virkkunen's 18 February 2025 letter (Ex. 21, see ec-2025-virkkunen-letter-to-jordan). The report's conclusions are the Committee's; the Commission's reply says the DSA 'applies exclusively within the European Union'. House Judiciary Democrats published a rebuttal ('Debunking Republicans' Misleading Report on the EU's Digital Services Act (DSA)'; located, not read).

Source
House Committee on the Judiciary (majority staff)
Date
25 July 2025
Quoted from
Executive Summary, p. 1
Grade
Primary record
Document
https://judiciary.house.gov/sites/evo-subsites/republicans-judiciary.house.gov/files/2025-07/DSA_Report%26Appendix%2807.25.25%29.pdf
Accessed
2026-11-10
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Exhibit 1135 · Congressional staff report

The Foreign Censorship Threat, Part II: Europe's Decade-Long Campaign to Censor the Global Internet and How It Harms American Speech in the United States (interim staff report)

The European Commission, in a comprehensive decade-long effort, has successfully pressured social media platforms to change their global content moderation rules, thereby directly infringing on Americans’ online speech in the United States.

Second majority staff report, on thousands of internal documents and communications that ten technology companies produced under subpoena. It describes 2020 emails between the European Commission and platforms (Spotify, TikTok) about COVID-19 vaccine content and the Commission's codes of conduct, and states conclusions about a decade of Commission pressure. The conclusions are the Committee's.

Source
House Committee on the Judiciary (majority staff)
Date
3 February 2026
Quoted from
Executive Summary, p. 1
Grade
Primary record
Document
https://judiciary.house.gov/sites/evo-subsites/republicans-judiciary.house.gov/files/2026-02/THE-FOREIGN-CENSORSHIP-THREAT-PART-II-2-3-26.pdf
Accessed
2026-11-10
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Exhibit 1136 · Congressional committee report

The Mechanics of Government Censorship: How the Biden Administration Converted the Cybersecurity and Infrastructure Security Agency into the Thought Police (report)

In March 2018, DHS created the Countering Foreign Influence Task Force to “focus on the 2018 midterm elections” and election infrastructure disinformation.

Majority report on CISA's election-content work. It places the origin of the work in March 2018, when DHS created the Countering Foreign Influence Task Force for the 2018 midterms, notes the CISA Act was passed unanimously and signed by President Trump on 16 November 2018, and describes 'switchboarding' in the 2020 election, including a Maryland example in which an election official's emailed tweets were forwarded to Twitter, which replied the tweets 'have been actioned for violations of our policies'. It argues Congress should legislate on federal contacts with platforms because, 'regardless of who occupies the White House', agencies have outsized power. The report uses the House Judiciary report and the Scully deposition as sources. Characterizations are the majority's.

Source
U.S. Senate Committee on Commerce, Science, and Transportation (Chairman Ted Cruz, majority)
Date
September 2025
Quoted from
Part II.A, p. 8
Grade
Primary record
Document
https://www.commerce.senate.gov/services/files/BFE7787E-0C18-47DF-B781-D6B92613DDC3
Accessed
2026-11-10
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Exhibit 1137 · Congressional testimony (written)

Testimony of Neil Potts, Vice President, Public Policy, Meta Platforms Inc., before the Senate Committee on Commerce, Science, and Transportation ("Shut Your App ... Part II")

Ultimately, it was our decision whether or not to take content down, and we own our decisions, including changes we made to our COVID-19-related enforcement in the wake of this pressure.

Meta's statement to the Senate committee that, as its chief executive acknowledged, in 2021 senior Biden administration officials repeatedly pressured its teams to censor COVID-19 content, that the decision to remove content was Meta's, and that Meta's content-moderation changes of 2025 (ending U.S. third-party fact-checking, fewer demotions, higher confidence thresholds) were meant to allow more speech. Google's witness (Markham Erickson) testified at the same hearing; his testimony was not retrieved.

Source
Meta Platforms, Inc. (written testimony)
Date
29 October 2025
Quoted from
Testimony, PDF p. 2 (paragraph beginning 'As our CEO has acknowledged')
Grade
Primary record
Document
https://www.commerce.senate.gov/services/files/0D8A8F4B-BB3C-4656-B1ED-A744ADB6D3C8
Accessed
2026-11-10
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Exhibit 1138 · Letter to a congressional committee

Letter from Mark Zuckerberg (Meta Platforms) to Chairman Jim Jordan, House Committee on the Judiciary

Ultimately, it was our decision whether or not to take content down, and we own our decisions, including COVID-19-related changes we made to our enforcement in the wake of this pressure.

Two-page letter, on Meta letterhead and signed '/s/ Mark Zuckerberg', copied to the Ranking Member. It says senior Biden administration officials 'repeatedly pressured' Meta's teams in 2021 over certain COVID-19 content 'including humor and satire', that the decision to take content down was Meta's, that 'the government pressure was wrong', and that the FBI warned Meta about a potential Russian disinformation operation about the Biden family and Burisma before the 2020 election, after which Meta sent the New York Post story to fact-checkers and 'temporarily demoted' it. It says Meta no longer demotes content in the U.S. while fact-checks are pending. The White House replied (as reported by AFP) that the administration 'encouraged responsible actions to protect public health and safety'.

Source
Meta Platforms, Inc.
Date
26 August 2024
Quoted from
Letter, third paragraph of text, p. 1
Grade
Primary record
Document
http://web.archive.org/web/20241102111822/https://www.dailysignal.com/wp-content/uploads/2024/08/meta-letter-082024.pdf
Accessed
2026-11-10
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Note
The letter was released by House Judiciary Republicans on 26 August 2024 and published by the Daily Signal; the url is the Wayback copy of that PDF (SHA-256 of the PDF as downloaded: 9d7e28da427d1f6b006be53c7281565039cc6cb4c3c4a1e967b3311c5d2e6792). The Committee's own copy was not found. Authenticity: the named party's public statements and its later Senate testimony (exhibit potts-2025-senate-commerce-testimony) adopt the letter. The existing exhibit mace-2024-letter-to-white-house-zuckerberg quotes the same letter at reported grade and can be upgraded to this copy.

Exhibit 1139 · Letter to a congressional committee

Letter from Daniel F. Donovan (King & Spalding, counsel for Alphabet Inc. and YouTube) to Chairman Jim Jordan, House Committee on the Judiciary

Senior Biden Administration officials, including White House officials, conducted repeated and sustained outreach to Alphabet and pressed the Company regarding certain user-generated content related to the COVID-19 pandemic that did not violate its policies.

A 'statement of facts' in 28 numbered paragraphs submitted in response to House Judiciary subpoenas of 15 February 2023 and 6 March 2025. Paragraph 8 says senior Biden administration officials 'conducted repeated and sustained outreach' and 'pressed the Company' regarding COVID-19 content that 'did not violate its policies', while the company 'continued to develop and enforce its policies independently'. Paragraph 17 says YouTube never had guidelines prohibiting discussion of the origins of COVID-19, ended several COVID-19 policies in 2023 and the remainder by December 2024; paragraph 23 says it terminated channels for repeated violations of COVID-19 policies through 2024 and will let those creators rejoin; paragraph 25 says Alphabet publishes quarterly transparency data on content removal requests. Paragraph 28 says the representations are not exhaustive. Signed by counsel.

Source
Alphabet Inc. and YouTube (through counsel)
Date
23 September 2025
Quoted from
Letter, para. 8, p. 2
Grade
Primary record
Document
https://judiciary.house.gov/sites/evo-subsites/republicans-judiciary.house.gov/files/evo-media-document/2025-09-23-letter-to-hjc.pdf
Accessed
2026-11-10
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Findings citing this exhibit
Note
The PDF's text layer is garbled; the wording was read from rendered page images (pages 1 to 5) and checked by eye. SHA-256 of the PDF as downloaded: 71f37d18fdc85d6db5839bb345a3a61ae54d091e94a63ead7078b542276ea720. The date and the 'statement of facts' form are the letter's own.

Exhibit 1140 · Congressional letter

Letter from Ranking Member Jamie Raskin (House Judiciary Committee Democrats) to YouTube CEO Neal Mohan

Yet this belated confession is impossible to square with the detailed testimony of 20 Alphabet employees, who all explained, under penalty of 18 U.S.C. § 1001 for False Statements to Congress, that the Biden Administration never sought to force YouTube to remove content.

The minority's response to the Alphabet letter. It says the committee interviewed 20 Alphabet employees and that 'not a single one' testified about coercion or undue pressure from the Biden administration, quotes a June 2025 exchange with a YouTube vice president of product management, and asks what Alphabet was 'promised or threatened with' before sending the letter. It lists 2025 settlements between the administration's targets and the president as context. The letter characterizes transcripts that are not public; the question about promises or threats is a question, not a finding.

Source
House Committee on the Judiciary, Democratic staff (Ranking Member Jamie Raskin)
Date
30 October 2025
Quoted from
Letter, p. 1
Grade
Primary record
Document
https://democrats-judiciary.house.gov/sites/evo-subsites/democrats-judiciary.house.gov/files/evo-media-document/2025-10-30-raskin-to-mohan-youtube-re-coercion-1.pdf
Accessed
2026-11-10
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Findings citing this exhibit
Note
Reported as to the transcripts: the 20 interview transcripts were not opened. Replace with the transcripts if the Committee releases them.

Exhibit 1141 · Congressional testimony (written)

Testimony of Jack Dorsey (Twitter, Inc.) before the Senate Judiciary Committee, 'Breaking the News: Censorship, Suppression, and the 2020 Election'

This policy was informed by conversations with the US government about foreign state misinformation and disinformation and the use of hacked materials or materials of dubious origin being used to manipulate the electorate and influence the outcome of an election.

Twitter's own account, made in the Trump administration's last weeks, of why it blocked New York Post links. It says Twitter created its hacked-materials policy in 2018, that the policy 'was informed by conversations with the US government' about foreign state misinformation and the use of hacked materials, that those government warnings 'were also repeated in advance of' the 2018 and 2020 elections, that Twitter enforced the policy against the Post's links and then narrowed the policy after hearing from journalists. The hearing was chaired by Senator Lindsey Graham. Dorsey also testified to the Senate Commerce Committee on 28 October 2020 (Chairman Wicker); that testimony concerns Section 230 and was not used.

Source
Twitter, Inc. (written testimony to a Republican-chaired Senate committee)
Date
17 November 2020
Quoted from
Testimony, p. 2
Grade
Primary record
Document
https://www.judiciary.senate.gov/download/dorsey-testimonypdf
Accessed
2026-11-10
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Exhibit 1142 · Congressional testimony (written)

Opening statement of Yoel Roth, House Committee on Oversight and Accountability hearing 'Protecting Speech from Government Interference and Social Media Bias, Part 1: Twitter's Role in Suppressing the Biden Laptop Story'

Twitter decided to follow a strict interpretation of the policy, and removed the New York Post’s Tweets.

The former Twitter official's account of the 14 October 2020 decision: Twitter decided 'to follow a strict interpretation of the policy' after he recommended a milder step (removing amplification instead of blocking), and 'Twitter erred' because it wanted to avoid repeating the mistakes of 2016. He also says Twitter's government-relations staff, whom the Twitter Files show answering emails from campaign staff and members of Congress, 'did not have any kind of decision-making authority over policy enforcement', and that the Files show discussions 'with political staff on both sides of the aisle'.

Source
Yoel Roth (former Twitter Head of Trust and Safety), as posted by the Committee's Democratic staff
Date
8 February 2023
Quoted from
Statement, PDF p. 4 (discussion of the Distribution of Hacked Material Policy)
Grade
Primary record
Document
https://oversightdemocrats.house.gov/imo/media/doc/Roth-House-Oversight-opening-statement-V4-Final.pdf
Accessed
2026-11-10
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Exhibit 1143 · News report

Trump White House asked Twitter to take down Chrissy Teigen's mean tweet about him (Engadget, 8 February 2023)

reached out to ask that this tweet be removed

Reports that a former Twitter senior safety-policy member testified at the 8 February 2023 House Oversight hearing that in 2019 someone from the Trump White House asked Twitter to remove a tweet by Chrissy Teigen insulting the president, that her team judged whether it violated the insults policy, and that it did not and stayed up. The only record held is this report; it also reports her testimony that Twitter removed a moderation-guidance example after a Trump tweet used similar words.

Source
Engadget (Karissa Bell), reporting testimony of Anika Collier Navaroli to the House Oversight Committee
Date
8 February 2023
Quoted from
Article, paragraph 3 of the body, quoting Navaroli's testimony
Grade
Reported
Document
https://www.engadget.com/donald-trump-white-house-twitter-chrissy-teigen-tweet-201406093.html
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: replace with the Committee's transcript or video of the 8 February 2023 hearing (Navaroli's answer to Rep. Connolly). Navaroli's written statement was read and does not mention the Teigen request. The thread Twitter Files #16 says the press covered the request while ignoring the Schiff and King requests; that is the author's comparison.

Exhibit 1144 · Platform policy

Distribution of hacked material policy (Twitter Help Center, version of March 2019)

Under this policy, you can’t directly distribute hacked materials.

The rule Twitter applied on 14 October 2020. It prohibits directly distributing content obtained through hacking that contains private information, may endanger people or contains trade secrets, including posting it and linking to it on other sites, and says discussing a hack or sharing press coverage of one is allowed without including private information. Twitter changed the policy in October 2020 after the block (Dorsey testimony; Roth statement).

Source
Twitter, Inc.
Date
March 2019 (Wayback capture of 17 July 2019)
Quoted from
Policy page, 'What is in violation of this policy?'
Grade
Primary record
Document
http://web.archive.org/web/20190717143909/https://help.twitter.com/en/rules-and-policies/hacked-materials
Accessed
2026-11-10
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Exhibit 1145 · Company statement

How We're Taking Action Against Vaccine Misinformation Superspreaders (Meta newsroom)

Since the beginning of the pandemic across our entire platform, we have removed over 3,000 accounts, Pages and groups for repeatedly violating our rules against spreading COVID-19 and vaccine misinformation and removed more than 20 million pieces of content for breaking these rules.

Meta's public answer to criticism by Biden administration officials of vaccine misinformation on Facebook. It says Meta had worked with health organizations 'since January 2020' to identify and remove COVID-19 misinformation, gives its own removal totals, and says 12 people were responsible for about 0.05 percent of views of vaccine-related content.

Source
Meta Platforms, Inc. (Facebook)
Date
18 August 2021
Quoted from
Post of 18 August 2021, paragraph beginning 'Focusing on these 12 individuals'
Grade
Primary record
Document
https://about.fb.com/news/2021/08/taking-action-against-vaccine-misinformation-superspreaders/
Accessed
2026-11-10
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Exhibit 1146 · Company statement

More Speech and Fewer Mistakes (Meta newsroom, Joel Kaplan)

In recent years we’ve developed increasingly complex systems to manage content across our platforms, partly in response to societal and political pressure to moderate content.

Meta announces it will end its U.S. third-party fact-checking program for a Community Notes model, lift restrictions on some topics and focus enforcement on illegal and high-severity violations. It attributes its content-moderation systems partly to pressure ('societal and political pressure to moderate content') and says that approach 'has gone too far'. Posted 13 days before the inauguration of the next administration. Says the program launched in 2016 with independent fact-checking organizations and that 'Experts, like everyone else, have their own biases and perspectives.' Says the system attached 'intrusive labels and reduced distribution,' and that 'A program intended to inform too often became a tool to censor.'

Source
Meta Platforms, Inc.
Date
7 January 2025
Quoted from
Post of 7 January 2025, third paragraph of text
Grade
Primary record
Document
https://about.fb.com/news/2025/01/meta-more-speech-fewer-mistakes/
Accessed
2026-11-10
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Findings citing this exhibit
Note
Section 'Ending Third Party Fact Checking Program, Moving to Community Notes': 'Our system then attached real consequences in the form of intrusive labels and reduced distribution. A program intended to inform too often became a tool to censor.' The phrase 'Experts, like everyone else, have their own biases and perspectives' appears in the same section.

Exhibit 1147 · Company statement

Managing harmful vaccine content on YouTube (YouTube Official Blog)

Since last year, we’ve removed over 130,000 videos for violating our COVID-19 vaccine policies.

YouTube expands its medical-misinformation policy to cover approved vaccines generally and states it has removed over 130,000 videos for violating its COVID-19 vaccine policies 'since last year', after building ten COVID-19 policies 'at the onset' of the pandemic with health authorities.

Source
YouTube (Alphabet Inc.)
Date
29 September 2021
Quoted from
Post of 29 September 2021, paragraph 4
Grade
Primary record
Document
https://blog.youtube/news-and-events/managing-harmful-vaccine-content-youtube/
Accessed
2026-11-10
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Findings citing this exhibit

Exhibit 1148 · Platform transparency data

Government requests to remove content (Google Transparency Report), data download of 1 July to 31 December 2025 edition

We also include government requests to review content to determine if it violates our own product community guidelines and content policies.

Counts requests from courts and government agencies in six-month periods since 2011 (603,116 requests and 7,839,386 items named for removal as of the December 2025 data). The U.S. rows of the downloadable CSV (government-removals_2025-7-1_2025-12-31_en_v1.zip, SHA-256 3196b7d5755a9c1e141b6b0c6e6e27c5b6f670aa32e0d975e816736179e79a71) give, by calendar year, requests / items named: 2017 1,819 / 32,222; 2018 1,523 / 45,202; 2019 852 / 118,007; 2020 596 / 9,482; 2021 717 / 6,991; 2022 544 / 3,195; 2023 788 / 7,021; 2024 660 / 5,207; 2025 539 / 2,690. In 2021 the U.S. reasons were defamation 332, trademark 127, privacy and security 89, bullying and harassment 47, other 45, copyright 23, and smaller categories; the report's reason list has no category for misinformation, and its only U.S. 'national security' rows in 2021 total 2 requests. The requester categories were reorganized in 2019 (README: 'Judicial' and 'Executive' through 2018; court orders directed at Google or third parties, police, government officials, military and others from 2019), so court-order and agency shares are not comparable across that line. The report states it counts requests from courts and government agencies, including court orders not directed at Google.

Source
Google LLC (Alphabet Inc.)
Date
Data through 31 December 2025; accessed 10 November 2026
Quoted from
Report page, introduction to 'Government removal requests by the numbers'
Grade
Primary record
Document
https://transparencyreport.google.com/government-removals/government-requests
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Counts re-derived by the researcher from the CSV (sums of number_of_requests and items_requested for cldr_territory = US). The report's scope text says requests to review content against product policies are included; the Alphabet letter (alphabet-2025-donovan-letter-to-jordan) describes White House outreach about content that did not violate Google's policies, and no row of the report is labeled as such. A Wayback capture was requested on 10 November 2026; the page renders by script.

Exhibit 1149 · Platform transparency data

Content Restrictions Based on Local Law (Meta Transparency Center): United States page, FAQ, and CSV download

No. This report only includes content that was restricted in specific jurisdictions based on local law. When we receive reports of content that violates our policies, we remove it entirely from our platform, regardless of the source of the report.

Meta's report of content it restricts in a country because of a government or court claim that it violates local law. Its FAQ says it excludes government reports of Community Standards violations. The all-country CSV download (SHA-256 3e45983af7574cf7061fbf5e77a89af505923a816393b7f54e8ea50683cf0261) lists the United States from the first half of 2019, with totals for Facebook and Instagram of: 2019 H1 0, H2 0; 2020 H1 27, H2 12; 2021 H1 3, H2 21; 2022 H1 14, H2 3; 2023 H1 0, H2 79; 2024 H1 0, H2 0; 2025 H1 0, H2 0; 2026 H1 0. The U.S. page's changelog says that in January to June 2020, 'in response to consumer protection concerns in the wake of Covid', Meta restricted access to 12 items reported by state Attorneys General and 15 items reported by the U.S. Attorney General as allegedly price gouging, and that on review Meta reinstated those 27 items as items that 'should have been reviewed only against our Community Standards'; and that in a July to December 2023 update Meta determined it restricted 41 items in error. For comparison, Brazil's totals in the same files run from 1,014 (2019 H1) to 29,457 (2026 H1) and Germany's from 937 to 18,036.

Source
Meta Platforms, Inc.
Date
Data through the first half of 2026; accessed 10 November 2026
Quoted from
FAQ answer to 'Do you include information about government reports of content that violates the Community Standards?'
Grade
Primary record
Document
https://transparency.meta.com/reports/content-restrictions/content-violating-local-law
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Counts read from the CSV by the researcher. Government requests handled under Community Standards (including the White House and FBI contacts described in the court record) are outside this report by its own definition; no Meta report counts them. The U.S. rows begin in 2019 H1 in the files (earlier files list no U.S. row).

Exhibit 1150 · Platform transparency report

X Global Transparency Report, H1 2024

X's first global transparency report published after the 2022 acquisition, per press coverage. Its government removal table gives 72,703 removal requests worldwide with 51,487 actioned (70.82%): Turkey 9,364 (6,332 actioned), Japan 46,648 (36,731), South Korea 5,889 (4,296), the EU 2,458 (1,965) and 'All Others' 8,345 (2,163); the United States is not listed separately in the removal table and falls within 'All Others'. The same report lists 3,329 U.S. information requests with a 76% disclosure rate. Its enforcement section gives 224,129,805 user reports, 5,296,870 account suspensions and 10,675,980 posts removed or labeled in the half (policy categories: abuse, child safety, hateful conduct, violent content and others; none labeled misinformation).

Source
X Corp.
Date
September 2024 (covers January to June 2024)
Grade
Primary record
Document
https://transparency.x.com/content/dam/transparency-twitter/2024/x-global-transparency-report-h1.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
SHA-256 of the PDF as downloaded: ff3ef346ea5e5330170e35f0ed861232d0f16a83fc7d67d4081d8d7546bd7419. The government table counts requests under X's legal-demand process; the enforcement totals count X's own rule enforcement. The two are different units and are not ratios of each other.

Exhibit 1152 · Regulation

Regulation (EU) 2022/2065 (Digital Services Act)

the Commission may impose on the provider of the very large online platform or of the very large online search engine concerned fines not exceeding 6 % of its total worldwide annual turnover in the preceding financial year

Article 9 makes providers act on orders from national judicial or administrative authorities against specific illegal content. Article 34(1) requires very large platforms to assess systemic risks, which include 'any actual or foreseeable negative effects on civic discourse and electoral processes, and public security' (point (c)), and Article 35 requires mitigation measures. Article 25 prohibits deceptive interface design. Article 74(1) lets the Commission fine a very large platform up to 6 percent of total worldwide annual turnover. Article 22 gives priority to notices from certified trusted flaggers.

Source
European Parliament and Council of the European Union
Date
19 October 2022
Quoted from
Article 74(1)
Grade
Primary record
Document
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022R2065
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1153 · Agency press release

Commission fines X EUR 120 million under the Digital Services Act (press release IP/25/2934)

This is the first non-compliance decision under the DSA.

The first non-compliance decision under the DSA. The EUR 120 million fine covers three breaches: the deceptive design of the 'blue checkmark' (Article 25(1)), the advertising repository and researcher access to public data (Articles 39 and 40(12)). The release says the investigation opened on 18 December 2023 into illegal content and information manipulation continues, and that preliminary findings on the three breaches were adopted on 12 July 2024.

Source
European Commission
Date
5 December 2025
Quoted from
Press release, paragraph beginning 'The fine issued today'
Grade
Primary record
Document
https://ec.europa.eu/commission/presscorner/detail/en/ip_25_2934
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1154 · Agency press release

Commission fines Temu EUR 200 million for breaching the Digital Services Act (press release IP/26/1178)

Today, the European Commission issued a fine of €200 million to Temu under the Digital Services Act (DSA).

A DSA fine for failing to assess diligently the systemic risks of illegal products on the platform; it concerns product safety, not speech. Secondary sources found in search describe a third decision, a EUR 550 million fine of AliExpress on 20 July 2026, and the Commission's acceptance of X's action plan on 16 July 2026; those were not checked against Commission releases.

Source
European Commission
Date
28 May 2026
Quoted from
Press release, first sentence
Grade
Primary record
Document
https://ec.europa.eu/commission/presscorner/detail/en/ip_26_1178
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1155 · Agency letter

Letter from Commissioner Thierry Breton to Elon Musk (X Corp.), 12 August 2024 (Exhibit 16 to the House Judiciary report of 25 July 2025)

My services and I will be extremely vigilant to any evidence that points to breaches of the DSA and will not hesitate to make full use of our toolbox, including by adopting interim measures, should it be warranted to protect EU citizens from serious harm.

Written 'in relation to the planned broadcast on your platform X of a live conversation between a US presidential candidate and yourself', it reminds X of its DSA due-diligence duties, says the Commission is 'monitoring the potential risks in the EU' from spillovers of content that may incite violence, hate and racism around major political events, notes formal proceedings against X were already ongoing, and warns of 'interim measures'. House Judiciary Chairman Jordan replied on 15 August that the letter was a threat and an intrusion in the American democratic process (Ex. 17); Breton replied on 21 August (Ex. 18) and the Commission's later letter says the Commission 'would never interfere in the American democratic process' (Ex. 20-21).

Source
European Commission (Commissioner for the Internal Market)
Date
12 August 2024
Quoted from
Letter, penultimate paragraph (appendix page 118 of the report PDF, rendered page 119)
Grade
Primary record
Document
https://judiciary.house.gov/sites/evo-subsites/republicans-judiciary.house.gov/files/2025-07/DSA_Report%26Appendix%2807.25.25%29.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read from the rendered image of the exhibit page (text layer absent). The Commission's own copy was not retrieved; Breton posted the letter on X on 12 August 2024 per the report's footnote (https://x.com/ThierryBreton/status/1823033048109367549, not opened).

Exhibit 1156 · Agency letter

Letter from Executive Vice-President Henna Virkkunen to Chairman Jim Jordan, 18 February 2025 (Exhibit 21 to the House Judiciary report of 25 July 2025)

I want to be very clear: the DSA does not regulate speech.

The Commission's answer to the Committee's letter of 31 January 2025. It says the DSA 'applies exclusively within the European Union' and 'has no extraterritorial jurisdiction in the U.S.', that 'the DSA does not regulate speech', and that substantive rules on unlawful content are set elsewhere in national or EU law. The Committee's report disputes these claims (exhibit house-judiciary-2025-foreign-censorship-threat-part-1).

Source
European Commission
Date
18 February 2025
Quoted from
Letter, section 1 'Freedom of speech' (appendix page 137-138 of the report)
Grade
Primary record
Document
https://judiciary.house.gov/sites/evo-subsites/republicans-judiciary.house.gov/files/2025-07/DSA_Report%26Appendix%2807.25.25%29.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1157 · Executive order

Executive Order 13925, Preventing Online Censorship (85 Fed. Reg. 34079)

When large, powerful social media companies censor opinions with which they disagree, they exercise a dangerous power.

Declares it U.S. policy that large platforms that 'censor opinions with which they disagree' should be treated as content creators, and directs executive-branch action on Section 230 and platform practices (agency petition and investigation provisions not read in full here). Revoked by Executive Order 14029 on 14 May 2021.

Source
President Donald J. Trump
Date
28 May 2020 (published 2 June 2020)
Quoted from
Sec. 1, Policy, paragraph 3
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2020-06-02/pdf/2020-12030.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1158 · Executive order

Executive Order 14029, Revocation of Certain Presidential Actions and Technical Amendment (86 Fed. Reg. 27025)

The following Presidential actions are revoked: Executive Order 13925 of May 28, 2020 (Preventing Online Censorship),

Section 1 revokes a list of presidential actions including Executive Order 13925 (Preventing Online Censorship).

Source
President Joseph R. Biden, Jr.
Date
14 May 2021 (published 19 May 2021)
Quoted from
Sec. 1
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2021-05-19/pdf/2021-10691.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1159 · Executive order

Executive Order 14149, Restoring Freedom of Speech and Ending Federal Censorship (90 Fed. Reg. 8243)

ensure that no Federal Government officer, employee, or agent engages in or facilitates any conduct that would unconstitutionally abridge the free speech of any American citizen;

States that the previous administration 'trampled free speech rights' by censoring speech on platforms, 'often by exerting substantial coercive pressure on third parties, such as social media companies', and sets the policy below. Section 3(b) directs the Attorney General to investigate the prior four years and report with recommendations; no report from that directive was found. The consent decree in Missouri v. Biden recites the order (paras. 6-8).

Source
President Donald J. Trump
Date
20 January 2025 (published 28 January 2025)
Quoted from
Sec. 2(b)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/FR-2025-01-28/pdf/2025-01902.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1160 · News report

Meta CEO Zuckerberg says US pressure on Covid-19 posts was 'wrong' (AFP, 27 August 2024)

When confronted with a deadly pandemic, this administration encouraged responsible actions to protect public health and safety,

Reports Zuckerberg's letter of 26 August 2024 and the White House's reply, and a misinformation researcher's view that parts of the letter read as caving to pressure from Republicans. The only White House response held is this report of a spokesman's statement.

Source
Agence France-Presse (via TechXplore)
Date
27 August 2024
Quoted from
Article, paragraph beginning 'The White House defended its actions', quoting a White House spokesman
Grade
Reported
Document
https://techxplore.com/news/2024-08-meta-ceo-zuckerberg-pressure-covid.html
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported: replace with the White House statement itself or a transcript of the spokesman's remarks. Retrieved as the publisher's PDF print (techxplore.com/news/2024-08-meta-ceo-zuckerberg-pressure-covid.pdf).

Exhibit 1161 · Academic book (primary theory text)

The Logic of Collective Action: Public Goods and the Theory of Groups

Indeed, unless the number of individuals in a group is quite small, or unless there is coercion or some other special device to make individuals act in their common interest, rational, self-interested individuals will not act to achieve their common or group interests.

States that rational, self-interested members of a large group will not voluntarily act for the group interest absent coercion or selective incentives, and that small groups with concentrated stakes organize more easily and can shift burdens onto larger members. Chapter I sorts groups into privileged, intermediate and latent. Text read in a 20th-printing scan (copyright 1965 and 1971 editions) on an Internet Archive user upload; the publisher record is the DOI.

Source
Mancur Olson, Harvard University Press (Harvard Economic Studies vol. 124)
Date
1965
Quoted from
Introduction, p. 2 (20th printing, 2002). Same book, ch. I section D, p. 36: "the larger the group, the less it will further its common interests."
Grade
Peer-reviewed
Document
https://doi.org/10.4159/9780674041660
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: robust as logic, contested as a predictor. Olson himself limits it to groups without selective incentives; Baumgartner et al. 2009 (exhibit baumgartner-2009-lobbying-policy-change) found organized interests often fail, so cite Olson for who organizes and not for who wins. Quote was OCR text; one OCR artifact (ra'tional) corrected.

Exhibit 1162 · Academic book (primary theory text)

The Semisovereign People: A Realist's View of Democracy in America

Argues that the scope of a conflict decides its outcome, that the pressure system recruits a narrow, upper-status slice of the public, and that organization is a mobilization of bias. Full text NOT read: the only scans found are borrow-only. Known through study notes (adambrown.info) and encyclopedia entries that attribute "The flaw in the pluralist heaven is that the heavenly chorus sings with a strong upper-class accent" to p. 35; no exact wording was read in the book, so no quote is registered.

Source
E. E. Schattschneider, Holt, Rinehart and Winston
Date
1960
Grade
Peer-reviewed
Document
https://archive.org/details/semisovereignpeo00scha
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: foundational, concept not an effect size; the "upper-class bias" claim comes from mid-century U.S. conditions and needs checking against later work (for example Baumgartner et al. 2009). Replace with the borrowed or library text before any quote is used. Never-quote until read.

Exhibit 1163 · Journal article

The Theory of Economic Regulation

Regulation may be actively sought by an industry, or it may be thrust upon it. A central thesis of this paper is that, as a rule, regulation is acquired by the industry and is designed and operated primarily for its benefit.

Frames regulation as a good the political process supplies to groups able to pay in votes and resources, and argues that small, concentrated groups win it because organizing costs and free-riding fall on diffuse groups. Stigler also holds that "the truly intended effects should be deduced from the actual effects" of a policy (from his 1975 supplementary note, as quoted in Carpenter and Moss 2014 intro, p. 8), an inference Carpenter and Moss criticize. Read in a text copy (Wayback capture of an SJSU course page) that carries no page numbers.

Source
George J. Stigler, Bell Journal of Economics and Management Science 2(1):3-21
Date
Spring 1971
Quoted from
Opening section, third paragraph (original p. 3; the text copy read has no page numbers)
Grade
Peer-reviewed
Document
https://doi.org/10.2307/3003160
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: influential and testable in form, mixed in tests (Peltzman 1976 generalized it; Dal Bo 2006 reviews the record as mixed). Main criticism is Stigler's inference rule, which reads purpose off outcomes (Carpenter and Moss 2014, p. 8, citing Noll on the "lurking danger of tautology"). Lacuna's purpose-inversion frame must not lean on that rule alone.

Exhibit 1164 · Edited academic volume, introduction

Preventing Regulatory Capture: Special Interest Influence and How to Limit It, Introduction

Regulatory capture is the result or process by which regulation, in law or application, is consistently or repeatedly directed away from the public interest and toward the interests of the regulated industry, by the intent and action of the industry itself.

Defines regulatory capture, separates strong from weak capture (strong capture is where no regulation or full replacement would serve the public better), says capture is a matter of degree and often overstated, and criticizes Stigler's inference from outcomes to purpose. Full introduction read (Tobin Project copy, pp. 1-17+).

Source
Daniel Carpenter and David A. Moss (eds.), Cambridge University Press / Tobin Project
Date
2014
Quoted from
Introduction, p. 13 (definition). Strong vs. weak capture, p. 11; "Stigler's rather casual standard of causal inference has been uncritically embraced", p. 8; "Regulatory capture is not always and everywhere the devastating problem it is often made out to be", p. 2.
Grade
Peer-reviewed
Document
https://tobinproject.org/sites/tobinproject.org/files/assets/Introduction%20from%20Preventing%20Regulatory%20Capture.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: robust definition and the best frame (capture by degrees); it is itself a corrective to overclaiming. Use its definition for any Lacuna sentence that says capture, including "by the intent and action of the industry", which excludes cases where no industry action is documented.

Exhibit 1165 · Edited academic volume, chapter

Cultural Capture and the Financial Crisis

cultural because it operates through a set of shared but not explicitly stated understandings about the world; capture because it can produce the same outcome as traditional capture – regulatory actions that serve the ends of industry.

Proposes three mechanisms by which regulators come to share an industry's view of the public interest: group identification, status and relationship networks. Applies them to pre-crisis U.S. financial regulation. Kwak says cultural capture is a channel alongside traditional capture and that in most cases it cannot be proved to be the determining factor. Chapter read in the Tobin Project proof (CUP pagination).

Source
James Kwak, in Carpenter and Moss (eds.), Preventing Regulatory Capture, Cambridge University Press, ch. 3 (pp. 71-98)
Date
2014
Quoted from
p. 79 (same paragraph); "in most cases it will be impossible to prove that cultural capture is the determining factor behind regulatory outcomes", p. 79
Grade
Peer-reviewed
Document
https://www.tobinproject.org/sites/default/files/assets/Kwak%20-%20Cultural%20Capture%20and%20the%20Financial%20Crisis.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: conceptual, little direct testing; Kwak concedes it is hard to identify empirically. Cite as a mechanism hypothesis only. Do not use it to attribute belief to named regulators.

Exhibit 1166 · Book (primary theory text, public domain)

Political Parties: A Sociological Study of the Oligarchical Tendencies of Modern Democracy (English translation by Eden and Cedar Paul)

It is organization which gives birth to the dominion of the elected over the electors, of the mandataries over the mandators, of the delegates over the delegators. Who says organization, says oligarchy.

Michels argues that organization divides every party or union into a directing minority and a directed majority, and that the organization becomes an end in itself with interests of its own. The phrase "iron law" appears in the translators' chapter title (Part Six, ch. II, "Democracy and the Iron Law of Oligarchy", p. 377, and its running heads); the body formula is "the fundamental sociological law of political parties". Full text read in the Toronto scan.

Source
Robert Michels, Hearst's International Library (German original 1911)
Date
1915
Quoted from
Part Six, ch. IV ("Final Considerations"), p. 401. Also p. 32: "Organization implies the tendency to oligarchy." And pp. 389-390: the party "is created as a means to secure an end. Having, however, become an end in itself, endowed with aims and interests of its own..."
Grade
Primary record
Document
https://archive.org/details/politicalparties00michuoft
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: tendency well supported in parties and unions, "law" is not. Standard counterexample is Lipset, Trow and Coleman, Union Democracy (1956, Free Press; the International Typographical Union), bibliographic record checked, text not read. Revisions: Voss and Sherman 2000 (exhibit voss-2000-breaking-iron-law) and Leach 2005 (exhibit leach-2005-iron-law-of-what-again). State as a tendency with named exceptions. One OCR artifact (w^iich) corrected in the quote.

Exhibit 1167 · Journal article (meta-analysis)

Bad Apples, Bad Cases, and Bad Barrels: Meta-Analytic Evidence About Sources of Unethical Decisions at Work

In this meta-analysis, the authors draw from over 30 years of research and multiple literatures to examine individual ("bad apple"), moral issue ("bad case"), and organizational environment ("bad barrel") antecedents of unethical choice.

Meta-analysis of over 30 years of research that sorts antecedents of unethical choice into individual traits, features of the moral issue and the organizational environment, and finds unethical choice is multidetermined. ABSTRACT ONLY read (Penn State research record); the journal text is paywalled and no open copy was found, so effect sizes by category are not verified.

Source
Kish-Gephart, Harrison and Trevino, Journal of Applied Psychology 95(1):1-31
Date
January 2010
Quoted from
Abstract (Penn State Pure record, doi 10.1037/a0017103)
Grade
Peer-reviewed
Document
https://doi.org/10.1037/a0017103
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: robust as a synthesis but self-report and scenario studies dominate the sample, and the abstract does not rank barrels over apples; it says the three sets must be studied together. Do not cite it as proof that barrels beat apples until the full text is read.

Exhibit 1168 · Journal article

Inconsistent Regulators: Evidence from Banking

We find that regulators can implement identical rules inconsistently due to differences in their institutional design and incentives, and this behavior may adversely impact the effectiveness with which regulation is implemented.

Uses a legally set rotation that assigns federal and state bank supervisors to the same bank at fixed intervals. Federal supervisors downgrade ratings almost twice as often as state supervisors on the same banks, and state leniency is linked to later failures. The authors find no support for regulator self-interest, including revolving doors, as the reason for leniency. This is the cleanest published operator-versus-regime comparison: same bank, same rules, different regulator institution. Abstract read (Crossref).

Source
Agarwal, Lucca, Seru and Trebbi, Quarterly Journal of Economics 129(2):889-938
Date
May 2014
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1093/qje/qju003
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: robust design (rotation is exogenous). It is not a fee-funded versus appropriations-funded test, and it finds no revolving-door effect, so it cuts against the page's revolving-door ledger as a causal story. Cite it for institution design mattering and for the null on revolving doors together.

Exhibit 1169 · Journal article

Ethical Spillovers in Firms: Evidence from Vehicle Emissions Testing

When inspectors work across different organizations, they adjust the rate at which they pass vehicles to the norms of those with whom they work.

Over three million emissions tests: inspectors who work at more than one facility shift their pass rates toward the norm of the facility they are at, most at large facilities and chains, least for high-volume inspectors. The authors also conclude that employees have persistent ethics that limit the firm's influence. A person-moves-between-organizations test of operator versus barrel. Full paper read (author-hosted PDF).

Source
Pierce and Snyder, Management Science 54(11):1891-1903
Date
November 2008
Quoted from
Abstract, p. 1891
Grade
Peer-reviewed
Document
https://doi.org/10.1287/mnsc.1080.0927
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: strong design (within-inspector variation). Scope is one inspection market. Result is both-and: organization shifts behavior and personal ethics persist. Use for "replace the person and the facility norm still moves the pass rate", not for "people do not matter".

Exhibit 1170 · Journal article

Do Leaders Matter? National Leadership and Growth Since World War II

We find robust evidence that leaders matter, particularly in autocratic settings.

Uses leaders' deaths in office as exogenous turnover. Finds leaders matter for growth, especially autocrats. It is the strongest published counterweight to a pure regime account of persistence. Abstract read (OpenAlex).

Source
Jones and Olken, Quarterly Journal of Economics 120(3):835-864
Date
August 2005
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1162/003355305774268165
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: robust identification, cross-country growth outcome, leader effects concentrated where institutions are weakest. It bounds the turnover claim: persistence through turnover should be argued for constrained bureaucracies and rule-bound organizations, not for personalist regimes.

Exhibit 1171 · Journal article

The Market for Financial Adviser Misconduct

Seven percent of advisers have misconduct records, and this share reaches more than 15% at some of the largest advisory firms.

Universe of U.S. financial advisers 2005-2015. Misconduct is concentrated in particular firms, repeat offenders are rehired by firms that already have high misconduct rates ("matching on misconduct"), and firms discipline about half of offenders. Offender turnover moves people and leaves the firm-level rate. Abstract read (OpenAlex).

Source
Egan, Matvos and Seru, Journal of Political Economy 127(1):233-295
Date
February 2019
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1086/700735
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: large administrative dataset; the authors' preferred explanation is consumer sophistication, so the result is about firms specializing in misconduct for a customer base, not about institutional capture. Use for firm-level concentration only.

Exhibit 1172 · Journal article

Dishonesty and Selection into Public Service: Evidence from India

Students in India who cheat on a simple laboratory task are more likely to prefer public sector jobs.

Indian students who cheat on a laboratory task are more likely to prefer public sector jobs, and cheating predicts corrupt behavior by later civil servants. Abstract read (Crossref).

Source
Hanna and Wang, American Economic Journal: Economic Policy 9(3):262-290
Date
August 2017
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1257/pol.20150029
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: well-known and contested. Barfort et al. 2019 (next exhibit) find the opposite sign in Denmark; Dal Bo et al. 2017 find positive competence selection in Sweden. Selection depends on the setting (pay, corruption level). Cite as one side of a split literature or not at all.

Exhibit 1173 · Journal article

Sustaining Honesty in Public Service: The Role of Selection

Dishonest individuals are more pecuniarily motivated and self-select out of public service into higher-paying private sector jobs.

In Denmark, survey-experiment evidence of strong self-selection of more honest people into public service, opposite to the Indian result; higher public pay would attract more dishonest candidates. Abstract read (Crossref).

Source
Barfort, Harmon, Hjorth and Olsen, American Economic Journal: Economic Policy 11(4):96-123
Date
November 2019
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1257/pol.20170688
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: replication-in-spirit of Hanna and Wang in a low-corruption country; survey-experiment, not behavior in office. Pairs with Hanna and Wang to show selection is context dependent.

Exhibit 1174 · Journal article

Who Becomes a Politician?

First, politicians are on average significantly smarter and better leaders than the population they represent.

Sweden, entire population of municipal politicians and national legislators with cognitive and leadership test scores: politicians are on average more competent than the people they represent, and the selection holds within family background. A positive-selection counterexample to the idea that office attracts the less able. Abstract read (Crossref).

Source
Dal Bo, Finan, Folke, Persson and Rickne, Quarterly Journal of Economics 132(4):1877-1914
Date
November 2017
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1093/qje/qjx016
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: exceptional data; one country with high pay-for-politics norms and low corruption. Speaks to competence, not to honesty or capture.

Exhibit 1175 · Working paper (not peer reviewed as read)

The Revolving Door and Worker Flows in Banking Regulation

These results appear inconsistent with a "quid-pro-quo" explanation of the revolving door, but consistent with a "regulatory schooling" hypothesis.

Career data on federal and state bank regulators. Outflows to the private sector rise in booms and net flows into regulation are countercyclical; the authors say the pattern is inconsistent with a quid-pro-quo reading of the revolving door and consistent with "regulatory schooling". Abstract read (OpenAlex).

Source
Lucca, Seru and Trebbi, NBER Working Paper 20241
Date
June 2014
Quoted from
Abstract
Grade
Primary record
Document
https://doi.org/10.3386/w20241
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: descriptive flows, not an effect on enforcement. Published version not located in this pass (check JME). Use with Agarwal et al. 2014 as the revolving-door null; Lacuna's ledger documents moves, and this literature does not show the moves change outcomes.

Exhibit 1176 · Journal article (literature review)

Regulatory Capture: A Review

I also review evidence on the revolving-door phenomenon and on the impact that different methods for selecting regulators appear to have on regulatory outcomes.

Reviews theory and empirics of regulatory capture, including the Stigler-Peltzman approach, revolving doors and the effect of how regulators are selected. Abstract read (OpenAlex).

Source
Ernesto Dal Bo, Oxford Review of Economic Policy 22(2):203-225
Date
June 2006
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1093/oxrep/grj013
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: the standard review; the full text was not read, so the claim in the check files that it finds the record "mixed" is carried as the reviewer's description, not verified here.

Exhibit 1177 · Journal article

Breaking the Iron Law of Oligarchy: Union Revitalization in the American Labor Movement

This article addresses the question of how social movement organizations are able to break out of bureaucratic conservatism.

Compares U.S. union locals that changed their goals and tactics with those that did not and finds three triggers: a political crisis bringing new leadership, leaders with outside activist experience, and pressure from the international union. Abstract read (OpenAlex).

Source
Voss and Sherman, American Journal of Sociology 106(2):303-349
Date
September 2000
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1086/316963
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: qualitative comparison, interview-based. Confirms the exceptions to Michels are crisis-driven and externally supported, which fits the page's "what breaks it" list.

Exhibit 1178 · Journal article

The Iron Law of What Again? Conceptualizing Oligarchy Across Organizational Forms

The debate around Michels's “iron law of oligarchy” over the question of whether organizations inevitably become oligarchic reaches back almost a century

Concept paper: oligarchy should be defined as a concentration of illegitimate power in an entrenched minority, and a democratic structure does not guarantee its absence; studies that equate oligarchy with goal displacement miss radical organizations ruled by an elite. Abstract read (Crossref).

Source
Darcy K. Leach, Sociological Theory 23(3):312-337
Date
September 2005
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1111/j.0735-2751.2005.00256.x
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: conceptual. Use only to support "tendency, with named exceptions".

Exhibit 1179 · Working paper (not peer reviewed as read)

Funding and Incentives of Regulators: Evidence from Banking

Using a novel dataset on fees and regulatory actions, we find that firms that pay higher fees face more lenient regulation, which leads to a buildup of risk.

Uses kinks in the fee schedules of federal bank regulators (OCC and the other federal supervisors) to compare banks just above and below a fee threshold. Banks that pay higher fees face more lenient regulation, take on more risk, and later have more loan defaults and regulatory actions. It is the closest direct test of fee-funded leniency in the literature found. Abstract and introduction read; publication in a journal not confirmed.

Source
Roni Kisin and Asaf Manela, working paper (18 November 2016; SSRN 2527638)
Date
18 November 2016
Quoted from
Abstract, p. 1
Grade
Primary record
Document
https://jhfinance.web.unc.edu/wp-content/uploads/sites/12369/2016/11/2017JH_regulators20160517.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: regression kink design, identification depends on kink exogeneity. It compares fee payers with each other inside a fee-funded system, not fee-funded with appropriations-funded regulators. Cite only after checking for a published version; otherwise flag as a working paper.

Exhibit 1180 · Journal article

The Failed Promise of User Fees: Empirical Evidence from the U.S. Patent and Trademark Office

We suggest that the PTO’s reliance on prior grantees to subsidize current applicants exposes the PTO to a risk that its obligatory costs will surpass incoming fee collections.

Examines how the USPTO's reliance on fees paid after a patent is granted relates to its examination practices. The authors hypothesize and document that a budget-strained PTO extends preferential examination (higher grant rates, shorter waits) to some technologies. Lietzan (ACUS, 2024) reports an earlier Frakes and Wasserman paper (Vanderbilt Law Review 66, 2013) finding the fee schedule "biases the [US]PTO toward granting patents". Abstract read (Crossref); full text blocked (HTTP 403).

Source
Frakes and Wasserman, Journal of Empirical Legal Studies 11(4):602-636
Date
December 2014
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1111/jels.12051
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: observational with identification from fee-schedule changes; the authors say statistical bias does not settle the welfare question (Lietzan 2024, p. 406-407). A fee-dependence test at a fee-funded agency, not a fee vs appropriations comparison.

Exhibit 1181 · Journal article

Approval Times for New Drugs: Does the Source of Funding for FDA Staff Matter?

The amount of funding for FDA staff appears to be a much more important influence on NDA review time than the source of funding.

Assesses 843 new drug applications submitted 1977-2000 and finds that adding FDA staff shortens review time while the source of the money matters much less than the amount. The authors give this as evidence that PDUFA fee money mattered through staffing, not through industry influence. Abstract read (PubMed).

Source
Carpenter, Chernew, Smith and Fendrick, Health Affairs (web exclusive) 22(Suppl 1):W3-618-W3-624
Date
2003
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1377/hlthaff.w3.618
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: before/after comparison of one agency; speed was the outcome, not safety or capture. Authored by the Carpenter who edited the capture volume, so the same scholar supplies the null on fees and the framework on degrees of capture.

Exhibit 1182 · Journal article

Drug-Review Deadlines and Safety Problems

As compared with drugs approved at other times, drugs approved in the 2 months before their PDUFA deadlines were more likely to be withdrawn for safety reasons (odds ratio, 5.5; 95% confidence interval [CI], 1.3 to 27.8)

Using new molecular entities approved from 1950 to 2005, the authors find that PDUFA deadlines concentrated approvals just before the deadline and that drugs approved in the two months before a deadline were more likely to be withdrawn, get a boxed warning or have a dosage form discontinued. The test is about deadlines in a fee-funded program, not fee source. FDA authors published a critical letter (Nardinelli, Lanthier and Temple, N Engl J Med 2008;359:95-6); the letter text was not read. Abstract read (PubMed).

Source
Carpenter, Zucker and Avorn, New England Journal of Medicine 358(13):1354-1361
Date
27 March 2008
Quoted from
Abstract, Results
Grade
Peer-reviewed
Document
https://doi.org/10.1056/NEJMsa0706341
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: wide confidence intervals (small number of events); disputed by FDA staff. It tests the deadline, which is a performance term negotiated with the fee payers, not the funding source. Do not cite it as showing that user fees cause unsafe approvals.

Exhibit 1183 · Journal article

The Risk We Bear: The Effects of Review Speed and Industry User Fees on New Drug Safety

Results show that drugs receiving faster reviews are associated with increased counts of serious adverse drug reactions.

Examines drugs approved 1990-2001 and finds that faster reviews are associated with more serious adverse drug reactions, with controls for utilization, novelty and other factors. Abstract read (PubMed). Not the same author as Mancur Olson.

Source
Mary K. Olson, Journal of Health Economics 27(2):175-200
Date
March 2008
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1016/j.jhealeco.2007.10.007
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: opposite sign to Grabowski and Wang 2008 and Berndt et al. 2005 as reported by Lietzan (2024), who finds no association once novelty is controlled; the published record on PDUFA and safety is split.

Exhibit 1184 · Agency-commissioned report in a law review

User Fee Programs (report to the Administrative Conference of the United States, published in Administrative Law Review)

In this case, though, empirical studies have found that user fees do not affect the quality of drug approval decisions, at least when post-approval drug safety issues are used as a proxy for a poor quality approval decision.

Surveys user-fee programs across federal agencies and reports the empirical record on whether fees skew agency decisions: the Frakes-Wasserman USPTO finding of grant bias, and for FDA studies that find no effect on approval quality as measured by post-approval safety problems. Names Gilhooley as the main capture-side critic of FDA fees and cites Grabowski and Wang (2008) and Berndt et al. (2005) for the null; those two papers were not read here. Pages 406-408 read.

Source
Erika Lietzan, Administrative Law Review 76(2):375-
Date
2024
Quoted from
Part II.A.6, p. 407
Grade
Primary record
Document
https://administrativelawreview.org/wp-content/uploads/sites/2/2024/06/ALR-76.2_Lietzan.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: a careful legal review, not original empirics. Best single source for stating, without overclaiming, that the evidence on fee funding is mixed: one bias finding (USPTO), one leniency finding in banking (Kisin and Manela), and FDA safety nulls with dissent.

Exhibit 1185 · Journal article (advocacy review)

Institutional Corruption of Pharmaceuticals and the Myth of Safe and Effective Drugs

The authorization of user fees in 1992 has turned drug companies into the FDA's prime clients, deepening the regulatory and cultural capture of the agency.

Argues that the 1992 user-fee authorization made drug companies the FDA's prime clients and deepened regulatory and cultural capture, and recommends full public funding. Abstract read (OpenAlex). Normative argument built on selected studies.

Source
Light, Lexchin and Darrow, Journal of Law, Medicine and Ethics 41(3):590-600
Date
Fall 2013
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1111/jlme.12068
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: CONTESTED, keep in private notes. Advocacy review with causal wording the cited empirical studies do not support (see Carpenter 2003, Lietzan 2024). Do not cite on the page; use it only to show where the capture-side argument is made.

Exhibit 1186 · Journal article

Increasing Returns, Path Dependence, and the Study of Politics

particular courses of action, once introduced, can be almost impossible to reverse

Frames path dependence as a process driven by increasing returns, and argues that such processes are likely to be prevalent in politics. ABSTRACT ONLY read (Cambridge Core record); the full text is paywalled and the course-hosted copies found returned errors, so the specific increasing-returns mechanisms are not verified here.

Source
Paul Pierson, American Political Science Review 94(2):251-267
Date
June 2000
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S0003055400221023
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: standard account of institutional stickiness, mechanism-specific; not every old institution is locked in. Read the full text before attributing the four features (large set-up costs, learning effects, coordination effects, adaptive expectations) to it.

Exhibit 1187 · Academic book (primary theory text)

Exit, Voice, and Loyalty: Responses to Decline in Firms, Organizations, and States

The presence of the exit alternative can therefore tend to atrophy the development of the art of voice.

Defines exit (customers or members leave) and voice (they complain to management or others) as the two ways decline reaches an organization, and argues that an available exit option can weaken voice. Full book read in a scan hosted on a Ugandan university library server (copyright status unclear); the Internet Archive record is borrow-only.

Source
Albert O. Hirschman, Harvard University Press
Date
1970
Quoted from
Ch. 3, p. 43. Exit and voice defined in ch. 1, pp. 3-4.
Grade
Peer-reviewed
Document
https://archive.org/details/exitvoiceloyalty0000hirs
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: robust as a framework, mostly illustrative evidence (Hirschman's own examples). Criticized as loosely operationalized; later empirical work (e.g., schools, unions) is mixed. State as a mechanism and name the conditions (cost of leaving, loyalty).

Exhibit 1188 · Journal article

The Iron Cage Revisited: Institutional Isomorphism and Collective Rationality in Organizational Fields

What makes organizations so similar? We contend that the engine of rationalization and bureaucratization has moved from the competitive marketplace to the state and the professions.

Proposes that organizations in the same field become more alike through coercive pressure (law and dependence), mimetic copying under uncertainty and normative professional pressure, not through competition for efficiency. Full text read (scan hosted at gwern.net); text extraction interleaves the two columns, so only the abstract page was used for the quote.

Source
DiMaggio and Powell, American Sociological Review 48(2):147-160
Date
April 1983
Quoted from
Abstract, p. 147
Grade
Peer-reviewed
Document
https://doi.org/10.2307/2095101
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: canonical and heavily cited; theory-heavy, supported by many case and panel studies; criticized for under-explaining change and agency. It supplies the "no coordination needed" mechanism.

Exhibit 1189 · Journal article

Institutionalized Organizations: Formal Structure as Myth and Ceremony

Structures are decoupled from each other and from ongoing activities. In place of coordination, inspection, and evaluation, a logic of confidence and good faith is employed.

Argues that organizations adopt formal structures that signal conformity to institutional rules and then decouple those structures from daily work, replacing inspection with a "logic of confidence and good faith". Full text read (JSTOR copy hosted on a Brazilian university site).

Source
Meyer and Rowan, American Journal of Sociology 83(2):340-363
Date
September 1977
Quoted from
Abstract, p. 340
Grade
Peer-reviewed
Document
https://doi.org/10.1086/226550
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: canonical theory, not a causal estimate. Decoupling is documented in school and hospital studies; its link to deliberate concealment is not claimed by the authors.

Exhibit 1190 · Journal article

Persistence of Power, Elites, and Institutions

A change in political institutions alters the distribution of de jure political power, but creates incentives for investments in de facto political power to partially or even fully offset change in de jure power.

A formal model in which a change in political institutions shifts de jure power while elites invest in de facto power (lobbying, paramilitary force) to offset it, producing "captured democracy" and persistence of economic institutions. Illustrated with the U.S. South, Latin America and Liberia. Full AER paper read (Robinson's author-hosted copy); the NBER 2006 working paper has different wording.

Source
Acemoglu and Robinson, American Economic Review 98(1):267-293
Date
March 2008
Quoted from
Abstract, p. 267
Grade
Peer-reviewed
Document
https://doi.org/10.1257/aer.98.1.267
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: a formal model plus historical illustrations, not a test. The same authors' wider program is contested (Albouy, AER 2012, on the settler-mortality instrument: exhibit albouy-2012-colonial-origins-comment). Use the 2008 paper as a mechanism for "reforms change rules and leave the coalition".

Exhibit 1191 · Journal article

The Colonial Origins of Comparative Development: An Empirical Investigation: Comment

When these data issues are controlled for, the relationship between mortality and expropriation risk lacks robustness, and instrumental-variable estimates become unreliable, often with infinite confidence intervals.

Reanalyzes the settler-mortality instrument behind Acemoglu, Johnson and Robinson (2001) and finds the relationship lacks robustness once data problems are controlled for. Abstract read (Crossref).

Source
David Y. Albouy, American Economic Review 102(6):3059-3076
Date
October 2012
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1257/aer.102.6.3059
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: CONTESTED line of work; keep in private notes. The authors replied in the same issue (reply not read). Gives the reason the page should cite A&R 2008 (a model) and not the 2001 cross-country result.

Exhibit 1192 · Working paper (not peer reviewed as read)

A Conceptual Framework for Interpreting Recorded Human History (working paper; precursor to Violence and Social Orders)

Limited access orders provide order by using the political system to limit economic entry to create rents, and then using the rents to stabilize the political system and limit violence.

Authors' own earlier statement of the limited-access versus open-access framework later published as Violence and Social Orders (Cambridge University Press, 2009; book text not read). In a limited access order the elite limits entry to create rents and uses the rents to hold order. Abstract and introduction read; the book itself and the 2009 Journal of Democracy summary were not accessible.

Source
North, Wallis and Weingast, NBER Working Paper 12795
Date
December 2006
Quoted from
Abstract
Grade
Primary record
Document
https://www.nber.org/papers/w12795
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: broad historical typology, hard to falsify, criticized for functionalism and for sweeping classification of states. Use as a typology, not as evidence. Replace with the 2009 book chapter 1 text before quoting the book.

Exhibit 1193 · Magazine essay (not peer reviewed)

America in Decay: The Sources of Political Dysfunction

Political decay thus occurs when institutions fail to adapt to changing external circumstances, either out of intellectual rigidities or because of the power of incumbent elites to protect their positions and block change.

Defines political decay as institutions failing to adapt because incumbents protect their positions, and names three drivers: interest-group capture, judicialization and "vetocracy". States that the American state has been "repatrimonialized" over the past half century (pp. 14-15, section "Liberty and Privilege"; column text interleaved in extraction). Read in the issue scan hosted at gwern.net.

Source
Francis Fukuyama, Foreign Affairs 93(5):5-26
Date
September-October 2014
Quoted from
Section "Why Institutions Decay", pp. 8-9
Grade
Primary record
Document
https://www.foreignaffairs.com/united-states/america-decay
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standing note: argument by historical analogy and a single case, contested by scholars who see the U.S. state as more capable than Fukuyama allows, and by those who date decay differently. Use as a named analyst's thesis, not as a measurement.

Exhibit 1194 · Journal article

The case for motivated reasoning

There is considerable evidence that people are more likely to arrive at conclusions that they want to arrive at, but their ability to do so is constrained by their ability to construct seemingly reasonable justifications for these conclusions.

Review proposing that motives affect reasoning by biasing which beliefs and strategies a person accesses, constructs and evaluates. Separates accuracy goals from directional goals and reviews the evidence for each. The central constraint is that people reach desired conclusions only when they can build a justification an observer would find reasonable.

Source
Ziva Kunda, Psychological Bulletin 108(3): 480-498
Date
1990
Quoted from
Abstract, p. 480
Grade
Peer-reviewed
Document
https://doi.org/10.1037/0033-2909.108.3.480
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read in the full text of the open copy at fbaum.unc.edu (third-party PDF of the APA article). The DOI is the stable citation.

Exhibit 1195 · Book (participant-observation field study)

When Prophecy Fails: A Social and Psychological Study of a Modern Group that Predicted the Destruction of the World

The individual will frequently emerge, not only unshaken, but even more convinced of the truth of his beliefs than ever before.

Field study of a small group that predicted a flood on 21 December. States five conditions under which disconfirmed belief is held with more fervor: deep conviction tied to action, irrevocable commitment, specific falsifiable content, recognized disconfirmation, and social support.

Source
Leon Festinger, Henry W. Riecken and Stanley Schachter (University of Minnesota Press)
Date
1956
Quoted from
Chapter I, "Unfulfilled Prophecies and Disappointed Messiahs", p. 3
Grade
Peer-reviewed
Document
https://archive.org/details/when.prophecy.fails
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Full text read in the Internet Archive scan (djvu text). Grade peer: university-press monograph reporting a field study; it is not a peer-reviewed journal article. The 1957 A Theory of Cognitive Dissonance is access-restricted on archive.org and was not read.

Exhibit 1196 · Journal article (experiment)

Knee-deep in the big muddy: a study of escalating commitment to a chosen course of action

Results showed that persons committed the greatest amount of resources to a previously chosen course of action when they were personally responsible for negative consequences.

Role-play experiment with 240 business students deciding how to allocate research and development funds. Participants who had personally chosen the earlier course committed the most further resources after bad outcomes. Staw frames the effect as self-justification and cites the Vietnam policy record as a governmental example.

Source
Barry M. Staw, Organizational Behavior and Human Performance 16: 27-44
Date
1976
Quoted from
Abstract, p. 27
Grade
Peer-reviewed
Document
https://doi.org/10.1016/0030-5073(76)90005-2
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read in the full text (gwern.net copy of the journal PDF). Student role-play design; later replications are mixed (FORRT replication atlas lists Bialek et al. 2021 as a failed replication and Schultze and Schulz-Hardt 2022 as mixed; atlas page not read in full).

Exhibit 1197 · Commission report

Report of the Presidential Commission on the Space Shuttle Challenger Accident, vol. 1, ch. V: The Contributing Cause of the Accident (Findings, p. 104)

The Commission concluded that the Thiokol Management reversed its position and recommended the launch of 51-L, at the urging of Marshall and contrary to the views of its engineers in order to accommodate a major customer.

Chapter V finds that the decision to launch 51-L was flawed, that waivers of launch constraints were not considered at all levels, that Marshall management tended to contain serious problems internally, and that Thiokol management reversed its no-launch position at Marshall's urging. The 27 January 1986 teleconference had no safety representative.

Source
Presidential Commission on the Space Shuttle Challenger Accident (Rogers Commission)
Date
1986
Quoted from
Chapter V, Findings item 4, p. 104
Grade
Primary record
Document
https://history.nasa.gov/rogersrep/v1ch5.htm
Accessed
2026-11-10
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Findings citing this exhibit
Note
Opening statement at p. 82: "The decision to launch the Challenger was flawed." Finding 1 at p. 104 says a well-structured system emphasizing safety "would have flagged the rising doubts about the Solid Rocket Booster joint seal." NASA History Office HTML edition; page numbers are the bracketed report pages.

Exhibit 1198 · Commission report (printed testimony)

Report of the Presidential Commission on the Space Shuttle Challenger Accident, vol. 1, ch. V: testimony of Robert Lund on the 27 January 1986 Marshall-Thiokol teleconference

We had to prove to them that we weren't ready, and so we got ourselves in the thought process that we were trying to find some way to prove to them it wouldn't work, and we were unable to do that.

Robert Lund of Thiokol was asked by Mr. Mason to take off his engineering hat and put on his management hat. Asked by Chairman Rogers why he changed position, he describes a reversed burden of proof: Thiokol had to prove the motor would fail, not that it would work.

Source
Presidential Commission on the Space Shuttle Challenger Accident (testimony printed in the Commission report)
Date
1986
Quoted from
Chapter V, Lund testimony (Rogers-Lund exchange), p. 94
Grade
Primary record
Document
https://history.nasa.gov/rogersrep/v1ch5.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Boisjoly's account of the "management hat" instruction is at p. 93. Testimony is printed in the Commission's own report.

Exhibit 1199 · Commission report

Report of the Presidential Commission on the Space Shuttle Challenger Accident, vol. 1, ch. VI: An Accident Rooted in History

However, as tests and then flights confirmed damage to the sealing rings, the reaction by both NASA and Thiokol was to increase the amount of damage considered "acceptable."

Traces the joint design flaw from early tests through repeated erosion and blow-by findings. The Commission states that management first failed to recognize the joint as a problem, then failed to fix it, and then treated it as an acceptable flight risk, widening the amount of damage classed as acceptable.

Source
Presidential Commission on the Space Shuttle Challenger Accident (Rogers Commission)
Date
1986
Quoted from
Chapter VI, opening section "Early Design", p. 120
Grade
Primary record
Document
https://history.nasa.gov/rogersrep/v1ch6.htm
Accessed
2026-11-10
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Findings citing this exhibit
Note
This is the primary-record wording for what Vaughan later named the normalization of deviance. The Commission itself does not use that phrase.

Exhibit 1200 · Commission report appendix

Report of the Presidential Commission on the Space Shuttle Challenger Accident, vol. 2, Appendix F: Personal Observations on Reliability of Shuttle

For a successful technology, reality must take precedence over public relations, for nature cannot be fooled.

Feynman reports that engineers estimated the chance of a loss of vehicle at about 1 in 100 while management estimates ran to 1 in 100,000. He concludes that management exaggerated reliability "to the point of fantasy" and that technology must put reality ahead of public relations.

Source
Richard P. Feynman, in the Report of the Presidential Commission on the Space Shuttle Challenger Accident
Date
1986
Quoted from
Appendix F, closing paragraph of Conclusions, p. F5
Grade
Primary record
Document
https://history.nasa.gov/rogersrep/v2appf.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Disparity sentence at p. F1: "the management of NASA exaggerates the reliability of its product, to the point of fantasy."

Exhibit 1201 · Investigation report

Columbia Accident Investigation Board Report, vol. 1, ch. 8: History as Cause: Columbia and Challenger

In all official engineering analyses and launch recommendations prior to the accidents, evidence that the design was not performing as expected was reinterpreted as acceptable and non-deviant, which diminished perceptions of risk throughout the agency.

Chapter 8 finds that foam strikes and O-ring erosion both followed one trajectory: an anomaly outside design specifications was accepted after the first incident, and later incidents were classed as routine. It attributes both accidents to organizational system effects and names Vaughan's term "normalization of deviance" (chapter 6, p. 130).

Source
Columbia Accident Investigation Board
Date
August 2003
Quoted from
Chapter 8, section 8.2, p. 196 (printed report page)
Grade
Primary record
Document
https://ntrs.nasa.gov/citations/20030093634
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote read in the NASA NTRS full text of Volume I and cross-read in the chapter PDF mirrored at globalsecurity.org. Same chapter: "History is cause." (p. 195); "Because ill-structured problems are less visible and therefore invite the normalization of deviance, they may be the most risky of all." (p. 203).

Exhibit 1202 · Investigation report

Columbia Accident Investigation Board Report, vol. 1, ch. 7: The Accident's Organizational Causes

In the Board's view, NASA's organizational culture and structure had as much to do with this accident as the External Tank foam.

Chapter 7 states the organizational cause: history and culture, including resource constraints, schedule pressure, and reliance on past success as a substitute for engineering. Lists organizational barriers that prevented communication of safety information and stifled professional differences of opinion.

Source
Columbia Accident Investigation Board
Date
August 2003
Quoted from
Chapter 7, "Understanding Causes", p. 177 (printed report page)
Grade
Primary record
Document
https://ntrs.nasa.gov/citations/20030093634
Accessed
2026-11-10
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Findings citing this exhibit
Note
The Organizational Cause Statement is on the same page. Chapter 6, p. 130: "The acceptance of events that are not supposed to happen has been described by sociologist Diane Vaughan as the 'normalization of deviance.'"

Exhibit 1203 · Book chapter (peer-reviewed volume)

System effects: on slippery slopes, repeating negative patterns, and learning from mistake?

By structural secrecy, I mean the way that organization structure and information dependence obscured problem seriousness from people responsible for oversight.

Vaughan restates her Challenger findings through the CAIB analysis. Defines normalization of deviance as decisions that made sense to the people making them in context, and structural secrecy as the way structure and information dependence hide problem seriousness from oversight, in place of individual concealment.

Source
Diane Vaughan, in W. Starbuck and M. Farjoun (eds.), Organization at the Limit: Lessons from the Columbia Disaster (Blackwell)
Date
2005
Quoted from
p. 43 (printed chapter page)
Grade
Peer-reviewed
Document
https://raghavan.usc.edu/2020-fall-computing-and-global-change/vaughan.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Open PDF copy hosted on a USC course site. The same page says: "Individual secrecy - the classic explanation of individuals trying to keep bad news from top management - does not work here." The 1996 book The Challenger Launch Decision itself was not accessible as text; this chapter and the CAIB are the readable statements of the concepts.

Exhibit 1204 · Congressional committee report

Final Committee Report: The Design, Development & Certification of the Boeing 737 MAX

Boeing’s historic marketing success of the 737 MAX created enormous production pressure that negatively impacted its workforce and the quality and safety of the MAX program.

Majority-staff report. Lists five themes: production pressures, faulty design and performance assumptions, culture of concealment, conflicted representation, and Boeing's influence over the FAA's oversight structure. Chapter 8 documents schedule pressure, a "Countdown Clock" in a Boeing conference room and cost-driven exclusion of safety technology.

Source
House Committee on Transportation and Infrastructure, majority staff (Chair DeFazio, Aviation Subcommittee Chair Larsen)
Date
September 2020
Quoted from
Chapter 8, Investigative Findings, p. 164 (printed report page)
Grade
Primary record
Document
https://democrats-transportation.house.gov/imo/media/doc/final_boeing_737_max_report.pdf
Accessed
2026-11-10
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Findings citing this exhibit
Note
Majority staff report; the committee Republicans disputed its framing (reported in press, not read). Other quotes read: Executive Summary p. 12, "There was tremendous financial pressure on Boeing and the 737 MAX program to compete with Airbus’ new A320neo aircraft."; p. 13, "Culture of Concealment. In several critical instances, Boeing withheld crucial information from the FAA, its customers, and 737 MAX pilots." The original transportation.house.gov URL returned 404 to a script; the committee Democrats' host served the PDF. Further quotation: “The MAX crashes were not the result of a singular failure, technical mistake, or mismanaged event.” (Executive Summary, PDF p. 13 of the committee PDF (printed page not confirmed)).

Exhibit 1205 · Inspector general report

Interim Report: Review of Patient Wait Times, Scheduling Practices, and Alleged Patient Deaths at the Phoenix Health Care System (14-02603-178)

A direct consequence of not appropriately placing veterans on EWLs is that the Phoenix HCS leadership significantly understated the time new patients waited for their primary care appointment in their FY 2013 performance appraisal accomplishments, which is one of the factors considered for awards and salary increases.

Interim OIG report. Finds that Phoenix reported a 24-day average wait for 226 sampled new primary care patients while OIG measured 115 days, and that about 1,700 waiting veterans were not on the electronic wait list. Finds inappropriate scheduling practices systemic across VHA and describes the "0-day" and "fix the 14-day appointments" schemes.

Source
VA Office of Inspector General
Date
28 May 2014
Quoted from
p. 2 (printed report page)
Grade
Primary record
Document
https://www.vaoig.gov/sites/default/files/reports/2014-05/VAOIG-14-02603-178.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read in the KFF-hosted copy of the same report; the vaoig.gov URL returns the PDF (HTTP 200) and is given as the official location. Scheme #2 (supervisors told schedulers to "fix" appointments longer than 14 days) is at p. 4.

Exhibit 1206 · Inspector general report

Review of Alleged Patient Deaths, Patient Wait Times, and Scheduling Practices at the Phoenix VA Health Care System (14-02603-267)

PVAHCS’s emphasis on goals resulted in a misleading portrayal of veterans’ access to patient care.

Final OIG report. Confirms unofficial wait lists, scheduler manipulation of desired dates, and a facility emphasis on goals that produced a misleading picture of access. Reports that OIG had warned of the same data problems since 2005 and that VA reported high performance regardless. States OIG could not conclusively assert that delays caused the deaths of the veterans whose cases it reviewed.

Source
VA Office of Inspector General
Date
26 August 2014
Quoted from
Conclusion to the performance-goals section, p. 63 (printed report page)
Grade
Primary record
Document
https://www.vaoig.gov/sites/default/files/reports/2014-08/VAOIG-14-02603-267.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Same report, p. 91: "Contrary to OIG reports, VA reported high performance in the VA Performance and Accountability Reports, even after we had twice reported the scheduling system contained inaccurate, incomplete, and unreliable data." P. 92: for the 2008 VISN 3 report "VHA disagreed with the report's conclusions and all nine recommendations." P. 72 quotes VHA ethics guidance that "When leaders set unrealistic or unattainable goals they invite employees to game the system or misrepresent results." The report attributes underreporting to staffing, demand and an antiquated scheduling system as well as ethical lapses (p. 72). Summary text states that OIG was "unable to conclusively assert that the absence of timely quality care caused the deaths of these veterans."

Exhibit 1208 · Journal article

Bureaucratic Structure and Personality

Adherence to the rules, originally conceived as a means, becomes transformed into an end-in-itself; there occurs the familiar process of displacement of goals whereby "an instrumental value becomes a terminal value."

Argues that the discipline that makes a bureaucracy reliable also moves attachment from the organization's aims to its rules. Introduces the displacement of goals and, from Veblen, trained incapacity, the state in which abilities function as blind spots.

Source
Robert K. Merton, Social Forces 18(4): 560-568 (reprinted in Social Theory and Social Structure, Free Press, 1957, pp. 195-206)
Date
1940
Quoted from
Reprint text, paragraph beginning "At the moment, it suffices to observe" (1957 reprint, pp. 195-206)
Grade
Peer-reviewed
Document
https://www.d.umn.edu/cla/faculty/jhamlin/4111/Merton/Social%20Theory%20and%20Social%20Structure%20Bureaucratic%20Structure%20a.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read in the University of Minnesota Duluth reproduction of the 1957 reprint, not in the 1940 journal pagination. Check the wording and pages against Social Forces 18(4) before citing the 1940 text. Trained incapacity definition at the earlier paragraph: "Trained incapacity refers to that state of affairs in which one's abilities function as inadequacies or blind spots."

Exhibit 1209 · Journal article

Assessing the impact of planned social change

The more any quantitative social indicator is used for social decision-making, the more subject it will be to corruption pressures and the more apt it will be to distort and corrupt the social processes it is intended to monitor.

Campbell states two "pessimistic laws" about quantitative social indicators used in decisions. Illustrates with crime statistics, police complaint recording and achievement-test scores, and says the evidence is "predominantly anecdotal".

Source
Donald T. Campbell, Evaluation and Program Planning 2(1): 67-90 (1979); text read from the 1976 Occasional Paper No. 8 reprint
Date
1979
Quoted from
Section "Corrupting Effect of Quantitative Indicators", p. 34 of the Journal of MultiDisciplinary Evaluation reprint PDF
Grade
Peer-reviewed
Document
https://jmde.journals.publicknowledgeproject.org/index.php/jmde_1/article/view/297
Accessed
2026-11-10
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Findings citing this exhibit
Note
Read in the open JMDE reprint (originally Paper #8, Occasional Paper Series, Dec. 1976, Dartmouth Public Affairs Center). The 1979 Elsevier version is paywalled and was not read; confirm its page (commonly cited at p. 85) before citing it.

Exhibit 1210 · Journal article

'Improving ratings': audit in the British University system

When a measure becomes a target, it ceases to be a good measure.

Anthropological account of the audit explosion in British higher education. Gives the widely used one-line version of Goodhart's law and credits Hoskin for attaching Goodhart's name to it.

Source
Marilyn Strathern, European Review 5(3): 305-321
Date
1997
Quoted from
p. 308
Grade
Peer-reviewed
Document
https://www.gwern.net/doc/statistics/decision/1997-strathern.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
This is Strathern's wording, not Goodhart's. Goodhart's own 1975 formulation (Papers in Monetary Economics, Reserve Bank of Australia) was not accessible and no text was read.

Exhibit 1211 · Journal article

What's measured is what matters: targets and gaming in the English public health care system

We examine the robustness of the regime of targets and terror to these assumptions using evidence from the English public health service on reported successes, problems of measurement, and gaming.

Examines the English NHS regime of targets backed by sanctions, using evidence on reported successes, measurement problems and gaming. Describes the regime as targets and terror.

Source
Gwyn Bevan and Christopher Hood, Public Administration 84(3): 517-538
Date
2006
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1111/j.1467-9299.2006.00600.x
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Only the abstract (Crossref record) was read; the article is paywalled and no open full text was found. Treat evidence claims from the body as unread.

Exhibit 1212 · Journal article (formal model)

Sparks and prairie fires: a theory of unanticipated political revolution

Here is an explanation, which hinges on the observation that people who come to dislike their government are apt to hide their desire for change as long as the opposition seems weak.

Model in which people who dislike a regime hide that preference while the opposition seems weak. Public opinion can then shift abruptly after a small, visible rise in opposition, so the collapse of a regime that looked unshakeable is not forecast by observed opinion.

Source
Timur Kuran, Public Choice 61(1): 41-74
Date
1989
Quoted from
Abstract, p. 41
Grade
Peer-reviewed
Document
https://sites.duke.edu/timurkuran/files/2016/10/sparks-and-prairie-fires.original.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read in the JSTOR scan hosted by the author on his Duke site; OCR text lacks spaces, so the quote was checked with whitespace ignored. The 1995 book Private Truths, Public Lies is restricted on archive.org and was not read.

Exhibit 1213 · Journal article (four studies)

Pluralistic ignorance and alcohol use on campus: some consequences of misperceiving the social norm

Students believed that they were more uncomfortable with campus alcohol practices than was the average student.

Four studies of college students find that students believe they are less comfortable with campus drinking than the average student. Men shifted toward the norm they wrongly perceived over a semester; women did not. Perceived deviance correlated with campus alienation although it was illusory.

Source
Deborah A. Prentice and Dale T. Miller, Journal of Personality and Social Psychology 64(2): 243-256
Date
1993
Quoted from
Abstract (PubMed ID 8433272; Princeton research portal copy)
Grade
Peer-reviewed
Document
https://doi.org/10.1037/0022-3514.64.2.243
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Abstract read on the Princeton research portal; full text not accessible. The 1998 follow-up (Schroeder and Prentice, J. Applied Social Psychology 28: 2150-2180, open Stanford SPARQ copy) was read for the summary of the 1993 findings and a norm-education intervention.

Exhibit 1214 · Meta-analysis

The "spiral of silence" revisited: a meta-analysis on the relationship between perceptions of opinion support and political opinion expression

We observed a significant positive relationship ( r = .10; Zr = .10) between opinion climate and opinion expression.

Meta-analysis of 66 studies and over 27,000 participants. Finds a small positive average relationship between perceived opinion climate and expression, strongest when people talk with family, friends or neighbors about obtrusive issues.

Source
Jörg Matthes, Johannes Knoll and Christian von Sikorski, Communication Research 45(1): 3-33
Date
2018
Quoted from
Abstract
Grade
Peer-reviewed
Document
https://doi.org/10.1177/0093650217745429
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Abstract only (Crossref); full text not read. Verifies the check-B flag: the average effect is small (r = .10), with a larger effect (r = .34) in talk with family, friends or neighbors on obtrusive issues.

Exhibit 1215 · Journal article

Two faces of power

There are two faces of power, neither of which the sociologists see and only one of which the political scientists see.

Critique of both elitist and pluralist community-power studies. Argues that both research traditions miss a second face of power.

Source
Peter Bachrach and Morton S. Baratz, American Political Science Review 56(4): 947-952
Date
1962
Quoted from
First-page abstract, p. 947 (Cambridge Core)
Grade
Peer-reviewed
Document
https://www.cambridge.org/core/journals/american-political-science-review/article/abs/two-faces-of-power1/0642CFB6AFD6EBF4312DF34CF1556671
Accessed
2026-11-10
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Findings citing this exhibit
Note
Only the first-page abstract on Cambridge Core was read; the article body and the 1963 follow-up (Decisions and Nondecisions) were not. The phrase "mobilization of bias" was not read in the source.

Exhibit 1216 · Essay (primary theory text)

The Power of the Powerless

Thus the sign helps the greengrocer to conceal from himself the low foundations of his obedience, at the same time concealing the low foundations of power.

Essay on post-totalitarian Czechoslovakia. The greengrocer who displays a slogan he does not believe signals obedience; ideology lets him and the system conceal the real basis of that obedience.

Source
Vaclav Havel (translated by Paul Wilson; in John Keane (ed.), The Power of the Powerless, 1985)
Date
1978
Quoted from
Section on the greengrocer, paragraph beginning "Let us take note"
Grade
Primary record
Document
https://worldhistorycommons.org/node/1122
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read in the World History Commons reproduction (excerpted translation). The greengrocer later "steps out of living within the lie." Written about the Soviet-bloc order, so use as an analogy for institutions in open societies, not as a description of them.

Exhibit 1217 · Book chapter (primary theory text)

Legal authority with a bureaucratic administrative staff (the monocratic type of bureaucratic administration), in The Theory of Social and Economic Organization

While not peculiar to bureaucratic organizations, the concept of ‘official secrets’ is certainly typical of them. It stands in relation to technical knowledge in somewhat the same position as commercial secrets do to technological training. It is a product of the striving for power.

Weber treats bureaucratic administration as control by knowledge. He says the concept of official secrets is typical of bureaucracy and a product of the striving for power.

Source
Max Weber (trans. A. M. Henderson and Talcott Parsons, 1947)
Date
1922 (English 1947)
Quoted from
Paragraph beginning "Bureaucratic administration means fundamentally the exercise of control on the basis of knowledge"
Grade
Primary record
Document
https://cuny.manifoldapp.org/read/751b5aa0-9356-4241-9534-1325ac62d427/section/84482b92-0d5b-401f-b1dd-de1d85b65a00
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Henderson-Parsons translation. The sentence in Roth and Wittich's Economy and Society (1968) that a bureaucracy "seeks to increase the superiority of the professionally informed by keeping their knowledge and intentions secret" was not found in any text read and is not quoted.

Exhibit 1218 · Classical history (translation)

Thucydides, History of the Peloponnesian War, Book III, the Corcyraean revolution and its spread (Crawley translation)

Words had to change their ordinary meaning and to take that which was now given them.

Thucydides describes the revolution at Corcyra and its spread through the Greek cities. He states that factional struggle changed the meaning of words, that the cause of the evils was the lust for power arising from greed and ambition, and that such sufferings recur as long as human nature remains the same.

Source
Thucydides; translated by Richard Crawley
Date
c. 400 BCE (Crawley translation, 1874)
Quoted from
Book III, passage on the Corcyraean revolution (standard numbering 3.82; the Crawley text prints no section numbers), Gutenberg ebook 7142 plain text
Grade
Primary record
Document
https://www.gutenberg.org/ebooks/7142
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Standard section numbers 3.82-3.84 come from the usual citation convention, not from the Gutenberg text read. Same passage also reads: 'The cause of all these evils was the lust for power arising from greed and ambition' and 'as long as the nature of mankind remains the same'.

Exhibit 1219 · Classical history (translation)

Polybius, Histories, Book VI, the cycle of constitutions and the mixed constitution (Shuckburgh translation)

This is the regular cycle of constitutional revolutions, and the natural order in which constitutions change, are transformed, and return again to their original stage.

Polybius sets out six forms of government that change into one another in a natural cycle, and says that each unmixed form is perverted into the vice peculiar to it. He credits Lycurgus with combining the best features of the forms so that each power checks the others.

Source
Polybius; translated by Evelyn S. Shuckburgh
Date
c. 150 BCE (Shuckburgh translation, 1889)
Quoted from
Book VI, ch. 9, Gutenberg ebook 44125 (vol. 1 of 2), plain text
Grade
Primary record
Document
https://www.gutenberg.org/ebooks/44125
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Mixed-constitution remedy read at Book VI ch. 10: 'every form of government that was unmixed, and rested on one species of power, was unstable'. Polybius's own account is a hypothesis about natural change, offered with the caveat that dates may be mistaken.

Exhibit 1220 · Political essay

The Federalist No. 10, The Same Subject Continued (The Union as a Safeguard Against Domestic Faction and Insurrection)

By a faction, I understand a number of citizens, whether amounting to a majority or a minority of the whole, who are united and actuated by some common impulse of passion, or of interest, adversed to the rights of other citizens, or to the permanent and aggregate interests of the community.

Madison defines faction by common impulse of passion or interest adverse to other citizens or the community. He says the latent causes of faction are sown in the nature of man and that the most common source is the unequal distribution of property. He argues no man should be judge in his own cause.

Source
James Madison (as 'Publius')
Date
22 November 1787
Quoted from
Federalist No. 10, paragraph beginning 'By a faction' (Gutenberg ebook 1404 plain text)
Grade
Primary record
Document
https://www.gutenberg.org/ebooks/1404
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Also read in the same essay: 'No man is allowed to be a judge in his own cause, because his interest would certainly bias his judgment, and, not improbably, corrupt his integrity.' and 'But the most common and durable source of factions has been the various and unequal distribution of property.'

Exhibit 1221 · Political essay

The Federalist No. 51, The Structure of the Government Must Furnish the Proper Checks and Balances Between the Different Departments

In framing a government which is to be administered by men over men, the great difficulty lies in this: you must first enable the government to control the governed; and in the next place oblige it to control itself.

Madison argues that the separate departments must have the personal motives to resist encroachments by the others, so that ambition counteracts ambition, and that a government administered by men over men must be obliged to control itself.

Source
James Madison (as 'Publius'; authorship of No. 51 is usually assigned to Madison)
Date
6 February 1788
Quoted from
Federalist No. 51, paragraph beginning 'But the great security against a gradual concentration' (Gutenberg ebook 1404 plain text)
Grade
Primary record
Document
https://www.gutenberg.org/ebooks/1404
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Same paragraph: 'Ambition must be made to counteract ambition.' and 'If men were angels, no government would be necessary.'

Exhibit 1222 · Historical theory (translation)

Ibn Khaldun, The Muqaddimah, Chapter III, section 12: Dynasties have a natural life span like individuals (Rosenthal translation, Dawood abridgement)

However, as a rule no dynasty lasts beyond the life span of three generations.

Ibn Khaldun says a dynasty as a rule lasts no longer than three generations of about forty years. The first generation keeps desert toughness and the strength of group feeling, the second loses part of it, and in the third group feeling disappears completely.

Source
Ibn Khaldun; translated by Franz Rosenthal; abridged by N. J. Dawood (Princeton University Press, 2005)
Date
1377 (original); 2005 (abridged English edition)
Quoted from
Muqaddimah, Chapter III, section 12 (Rosenthal numbering), Princeton 2005 abridged edition, archive.org full text
Grade
Primary record
Document
https://archive.org/details/the-muqaddimah-an-introduction-to-history-2005-ibn-ibn-khaldun
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The archive.org copy is a scan of an in-copyright edition. Replace with a library copy of the Rosenthal translation (Bollingen, 1958; Princeton) before public citation. Also read: 'Group feeling disappears completely.' The Muqaddimah offers the cycle as a model for North African and Near Eastern dynasties, not a tested law.

Exhibit 1223 · Magazine essay (theory)

Up and Down with Ecology: the 'Issue-Attention Cycle'

during the time that interest was sharply focused on this problem, new institutions, programs, and policies may have been created to help solve it. These entities almost always persist and often have some impact even after public attention has shifted elsewhere.

Downs describes five stages in public attention to a domestic problem: pre-problem, alarmed discovery, recognition of the costs of progress, gradual decline of interest, and a post-problem stage. He says the institutions and programs created while attention was high almost always persist after attention moves on.

Source
Anthony Downs, The Public Interest no. 28
Date
Summer 1972
Quoted from
Stage 5 (the post-problem stage), p. 41; scanned copy with text layer
Grade
Primary record
Document
https://gwern.net/doc/sociology/1972-downs.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Downs offers the cycle from observation, not measurement. The scan breaks 'elsewhere' across a line as 'else- where'; the quote prints it joined.

Exhibit 1224 · Author's book proposal

The Politics of Disequilibrium: Agendas and Advantage in American Politics (1991 book proposal that led to Agendas and Instability in American Politics)

The American political system encourages rapid change during short bursts of activity as well as incrementalism at other times.

The authors state their model of policy change: long periods of slow, incremental change are broken by short bursts of rapid change. They say powerful economic interests build supporting institutional arrangements that last decades and then lose strength as public understanding and institutions change.

Source
Frank R. Baumgartner and Bryan D. Jones
Date
1991
Quoted from
Proposal, Overview, p. 2 of the PDF
Grade
Primary record
Document
https://fbaum.unc.edu/books/agendas/Baumgartner_Agendas_and_Instability_proposal.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
This is the authors' proposal, hosted on Baumgartner's UNC page, not the 1993 book text. The book (University of Chicago Press, 1993; 2nd ed. 2009) was not read. Replace with the book's chapter 1 before the page quotes the theory.

Exhibit 1225 · Peer-reviewed article

Focusing Events, Mobilization, and Agenda Setting

most focusing events change the dominant issues on the agenda in a policy domain, they can lead to interest group mobilization, and groups often actively seek to expand or contain issues after a focusing event.

Birkland examines how focusing events such as natural disasters and industrial accidents change policy agendas and mobilize interest groups. He says agenda setting and group politics vary with the type of event and the structure of the policy community.

Source
Thomas A. Birkland, Journal of Public Policy 18(1):53-74
Date
January 1998
Quoted from
Abstract (Cambridge University Press record and RePEc/IDEAS record)
Grade
Peer-reviewed
Document
https://doi.org/10.1017/S0143814X98000038
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Only the abstract was read; the article body is behind a paywall. The 1997 book After Disaster was not read.

Exhibit 1226 · Peer-reviewed article

Why Anticorruption Reforms Fail: Systemic Corruption as a Collective Action Problem

in thoroughly corrupt settings, corruption rather resembles a collective action problem. This, in turn, leads to a breakdown of any anticorruption reform that builds on the principal-agent framework, taking the existence of noncorruptible so-called principals for granted.

From interviews in Kenya and Uganda, the authors argue that anticorruption reforms built on a principal-agent model break down where corruption is systemic, because in those settings corruption resembles a collective action problem and there are no noncorruptible principals to enforce the reform.

Source
Anna Persson, Bo Rothstein and Jan Teorell, Governance 26(3):449-471
Date
July 2013
Quoted from
Abstract (Lund University Research Portal record, lup.lub.lu.se/record/3630113)
Grade
Peer-reviewed
Document
https://doi.org/10.1111/j.1468-0491.2012.01604.x
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Quote uses a hyphen where the abstract prints an en dash in 'principal-agent'. Abstract read only. Evidence base is an interview study in two countries. Marquette and Peiffer (Governance 2018) argue the two frameworks are complementary; not read.

Exhibit 1227 · Peer-reviewed article

Persistence of Power, Elites, and Institutions

The model can imply a pattern of captured democracy, whereby a democratic regime may survive but choose economic institutions favoring an elite.

A model in which a change in political institutions alters de jure power but invites investment in de facto power that partly or fully offsets it, so economic institutions can persist after a regime change.

Source
Daron Acemoglu and James A. Robinson, American Economic Review 98(1):267-293
Date
March 2008
Quoted from
Abstract (RePEc/IDEAS record of the AER article)
Grade
Peer-reviewed
Document
https://doi.org/10.1257/aer.98.1.267
Accessed
2026-11-10
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Findings citing this exhibit
Note
Theoretical model; abstract read only. The factual claim about any historical case (Acemoglu and Robinson cite the post-bellum US South) is not verified here.

Exhibit 1228 · Prize lecture (published in a peer-reviewed journal)

Beyond Markets and States: Polycentric Governance of Complex Economic Systems (Nobel Prize Lecture, 8 December 2009; American Economic Review 100(3), 2010)

studies confirm that robust resource systems are characterized by most of the design principles and that failures are not.

Ostrom lists the design principles of long-enduring common-pool resource institutions (clear boundaries, congruent rules, collective choice, monitoring, graduated sanctions, conflict resolution, recognized rights, nesting) and reports that a review of over 100 studies found two-thirds confirm them, with some studies reading them too rigidly.

Source
Elinor Ostrom
Date
8 December 2009
Quoted from
Section 4, printed p. 423 of the lecture as printed in Les Prix Nobel; the sentence begins on p. 422 ('Two-thirds of these') and the design-principle list is on p. 422
Grade
Peer-reviewed
Document
https://www.nobelprize.org/uploads/2018/06/ostrom_lecture.pdf
Accessed
2026-11-10
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Findings citing this exhibit
Note
Ostrom credits the review to Cox, Arnold and Villamayor-Tomas (2009; Ecology and Society 2010). Evidence is about local common-pool resources such as fisheries, forests and irrigation, not national bureaucracies. Her footnote 5 says 'design principle' confused readers and that 'best practices' might have been the better term. The AER 'Beyond Markets and States' is this lecture. Governing the Commons (1990) was not read.

Exhibit 1229 · Peer-reviewed article

Bureaucracy and Growth: A Cross-National Analysis of the Effects of 'Weberian' State Structures on Economic Growth

Using a data set on core economic agencies in 35 developing countries for 1970 to 1990, the authors build a 'Weberianness Scale' of meritocratic recruitment and predictable long-term careers and find it associated with higher economic growth after controls.

Source
Peter Evans and James E. Rauch, American Sociological Review 64(5):748-765
Date
October 1999
Grade
Peer-reviewed
Document
https://doi.org/10.1177/000312249906400508
Accessed
2026-11-10
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Note
Association across 35 developing countries, not randomized. No quote registered: the scan's text layer is badly garbled by OCR, so exact wording could not be copied. The abstract reads (through the garbling) that the Weberian characteristics 'significantly enhance prospects for economic growth, even when we control for initial levels of GDP per capita and human capital'; upgrade to quote-checked from a clean JSTOR copy. The companion paper Rauch and Evans (J. Public Economics 75(1):49-71, 2000) is registered separately.

Exhibit 1230 · Peer-reviewed article (working-paper abstract read)

Bureaucratic Structure and Bureaucratic Performance in Less Developed Countries (UC San Diego discussion paper, 1999; Journal of Public Economics 75(1):49-71, 2000)

Meritocratic recruitment is the most important structural feature for improving bureaucratic performance, followed by internal promotion and career stability.

For bureaucracies in 35 less developed countries, the authors find that merit recruitment, internal promotion and career stability predict country-risk ratings of bureaucratic performance after controls for income, education and ethnolinguistic diversity; competitive salaries could not be shown to matter.

Source
James E. Rauch and Peter B. Evans
Date
1999 (working paper); 2000 (journal)
Quoted from
Abstract of the 1999 UCSD discussion paper (RePEc/IDEAS record ucsdec/qt0sb0w38d)
Grade
Peer-reviewed
Document
https://doi.org/10.1016/S0047-2727(99)00044-4
Accessed
2026-11-10
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Note
Text read is the 1999 working-paper abstract (https://ideas.repec.org/p/cdl/ucsdec/qt0sb0w38d.html); the journal article is behind ScienceDirect and its wording was not read. Outcome measure is ratings by country-risk agencies, not measured corruption.

Exhibit 1231 · Peer-reviewed article (working paper read)

Monitoring Corruption: Evidence from a Field Experiment in Indonesia (NBER Working Paper 11753, 2005; Journal of Political Economy 115(2):200-249, 2007)

announcing an increased probability of a government audit, from a baseline of 4 percent to 100 percent, reduced missing expenditures by about 8 percentage points

A randomized experiment in over 600 Indonesian village road projects. Announcing a government audit probability of 100 percent instead of a 4 percent baseline cut missing expenditures; increasing grass-roots monitoring had little overall effect.

Source
Benjamin A. Olken
Date
November 2005 (working paper); April 2007 (journal)
Quoted from
Abstract, NBER Working Paper 11753 (November 2005)
Grade
Peer-reviewed
Document
https://www.nber.org/papers/w11753
Accessed
2026-11-10
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Findings citing this exhibit
Note
The text read is the NBER working paper; the JPE version (2007) should be checked for any change in wording or figures. One project type (village roads), one country, effect measured over the project, not over years.

Exhibit 1232 · Peer-reviewed article

Monitoring Corruptible Politicians

these municipalities do not exhibit decreased levels of corruption in subsequent audits, even while mayors in these benefit from higher reelection rates.

Using longitudinal audit data from Puerto Rico's municipalities, the authors find corruption is lower when audits arrive before an election but is not lower in later audits, and conclude audits help voters choose responsive but corruptible politicians.

Source
Gustavo J. Bobonis, Luis R. Camara Fuertes and Rainer Schwabe, American Economic Review 106(8):2371-2405
Date
August 2016
Quoted from
Abstract (RePEc/IDEAS record of the AER article)
Grade
Peer-reviewed
Document
https://doi.org/10.1257/aer.20130874
Accessed
2026-11-10
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Note
Abstract read only. This is the best direct evidence found of audit effects that do not carry forward. One jurisdiction.

Exhibit 1233 · Peer-reviewed article (working-paper abstract read)

Do Government Audits Reduce Corruption? Estimating the Impacts of Exposing Corrupt Politicians (NBER Working Paper 22443, 2016; Journal of Political Economy 126(5):1912-1964, 2018)

We find that being audited in the past reduces future corruption by 8 percent, while also increasing the likelihood of experiencing a subsequent legal action by 20 percent.

Using Brazil's random audits of municipalities, the authors find that being audited in the past reduces later corruption and raises the chance of a later legal action, and that most of the reduction comes through higher perceived non-electoral costs of corruption.

Source
Eric Avis, Claudio Ferraz and Frederico Finan
Date
July 2016 (working paper); October 2018 (journal)
Quoted from
Abstract, NBER Working Paper 22443 (July 2016)
Grade
Peer-reviewed
Document
https://www.nber.org/papers/w22443
Accessed
2026-11-10
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Note
Text read is the NBER abstract; JPE wording unchecked. The effect depends on audits leading to legal action, which links to audit with sanction.

Exhibit 1234 · Statute

An Act to regulate and improve the civil service of the United States (Pendleton Civil Service Reform Act), 22 Stat. 403

First, for open, competitive examinations for testing the fitness of applicants for the public service now classified or to be classified here- under.

Creates the three-member Civil Service Commission, requires open competitive examinations for classified positions with appointment from the highest graded, bars political contributions and service as a condition of employment, and makes violation a misdemeanor.

Source
United States Congress
Date
16 January 1883
Quoted from
Section 2, Second, First (National Archives enrolled act, NAID 5730369; transcription hyphenates 'here- under')
Grade
Primary record
Document
https://docsteach.org/document/pendleton-act/
Accessed
2026-11-10
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Note
Other text read in the National Archives transcript (OurDocuments, via NPS copy): Sec. 2, Second, Second: 'all the offices, places, and employments so arranged or to be arranged in classes shall be filled by selections according to grade from among those graded highest as the results of such competitive examinations'; Fifth: 'no person in the public service is for that reason under any obligations to contribute to any political fund, or to render any political service, and that he will not be removed or otherwise prejudiced for refusing to do so.' The act initially covered only a minority of federal positions (the proportion was not verified here).

Exhibit 1235 · Statute

National Research Act, Pub. L. 93-348, 88 Stat. 342, section 212 (Institutional Review Boards)

a board (to be known as an 'Institutional Review Board') to review biomedical and behavioral research involving human subjects conducted at or sponsored by such entity in order to protect the rights of the human subjects of such research.

Title II establishes the National Commission for the Protection of Human Subjects of Biomedical and Behavioral Research. Section 212 requires entities seeking Public Health Service research grants to have an Institutional Review Board.

Source
United States Congress
Date
12 July 1974
Quoted from
Section 212(a), adding section 474(a) to the Public Health Service Act, 88 Stat. 352-353
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/STATUTE-88/pdf/STATUTE-88-Pg342.pdf
Accessed
2026-11-10
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Exhibit 1236 · Statute

Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act, Pub. L. 107-56, section 218

Sections 104(a)(7)(B) and section 303(a)(7)(B) (50 U.S.C. 1804(a)(7)(B) and 1823(a)(7)(B)) of the Foreign Intelligence Surveillance Act of 1978 are each amended by striking "the purpose" and inserting "a significant purpose".

Section 218 amends sections 104(a)(7)(B) and 303(a)(7)(B) of the Foreign Intelligence Surveillance Act of 1978, changing the certification that foreign intelligence is 'the purpose' of the surveillance or search to 'a significant purpose'.

Source
United States Congress
Date
26 October 2001
Quoted from
Section 218, 115 Stat. 291
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/STATUTE-115/pdf/STATUTE-115-Pg272.pdf
Accessed
2026-11-10
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Note
Pairs with the 1978 text in exhibit pl-95-511-fisa-1978: 'that the purpose of the surveillance is to obtain foreign intelligence information' (Sec. 104(a)(7)(B), 92 Stat. 1789). Both are statute text. Later amendments (2008, 2012, 2018, 2024) were not read.

Exhibit 1237 · Plea agreement (court filing)

Plea Agreement, United States v. Pilgrim's Pride Corporation, No. 1:20-cr-00330-RM (D. Colo.), Document 58

through at least one of its current and/or former employees, defendant participated in a conspiracy with at least one competitor engaged in the production and sale of broiler chicken products to suppress and eliminate competition by rigging bids and fixing prices and other price-related terms for certain broiler chicken products sold in the United States.

Pilgrim's Pride agrees to plead guilty to a one-count Information charging a Sherman Act conspiracy to rig bids and fix prices for broiler chicken products. The factual basis states the conspiracy affected sales to KFC totaling at least $361 million in the period from at least as early as 2012 through at least early 2017.

Source
United States District Court for the District of Colorado (filed by the Antitrust Division and Pilgrim's Pride Corporation)
Date
23 February 2021
Quoted from
Paragraph 4(b), p. 4 of 25 (Factual Basis for Offense Charged, introduced 'Had this case gone to trial, the United States would have presented evidence sufficient to prove the following facts')
Grade
Primary record
Document
https://www.justice.gov/media/1129061/dl
Accessed
2026-11-10
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Note
Primary document behind the press release already registered as doj-2021-pilgrims-pride-plea. The plea covers one company and conspiracy with at least one competitor. Finding AGR-5.4 records that individual defendants in the DOJ broiler cases were acquitted in jury trials.

Exhibit 1238 · Statute (English translation)

Act regarding the Records of the State Security Service of the former German Democratic Republic (Stasi Records Act, StUG), Federal Law Gazette I 1991 p. 2272; English translation issued by the Federal Commissioner, 2017 version

Each individual shall have the right to enquire of the Federal Commissioner whether records exist which contain personal data about him.

Article 1 states the Act's purposes: individual access to one's own file, protection of privacy, historical, political and juridical reappraisal, and access for public and private bodies. Article 3 gives each individual the right to ask whether records exist about him and to obtain information, inspect and receive the records.

Source
German Bundestag (act); Federal Commissioner for the Records of the State Security Service (translation)
Date
20 December 1991 (act); 2017 (amended translation read)
Quoted from
Article 3(1) (BStU English translation, 2017 amended text, p. 8 of the PDF)
Grade
Primary record
Document
https://www.uni-rostock.de/storages/uni-rostock/UniHome/RIH/Sommerschulen/SARU/2019/StUG_englisch_pdf.pdf
Accessed
2026-11-10
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Note
The translation read incorporates amendments through 2017, not the 1991 enacted text; only the German text is legally binding. The 1991 enacted wording of Articles 1 and 3 should be confirmed against BGBl. I 1991 p. 2272. The Bundestag passage date is reported as 14 November 1991 in one source not read here. Later replacement of the Act (2021 transfer of the archive to the Federal Archives) is from memory and unverified. The copy is hosted by the University of Rostock; the original is on the BStU site (www.bstu.bund.de).

Exhibit 1239 · Judicial opinion

Arthur Andersen LLP v. United States, 544 U.S. 696

We hold that the jury instructions failed to convey properly the elements of a "corrup[t] persua[sion]" conviction under § 1512(b), and therefore reverse.

The Court reverses the conviction of Enron's auditor for obstruction by document destruction because the jury instructions did not require a nexus to a particular official proceeding or consciousness of wrongdoing. The opinion recounts that the firm's partner told employees that if documents were destroyed under the retention policy and litigation followed, 'that's great', and that an engagement-team email stated 'No more shredding' on 9 November 2001 after the SEC served subpoenas.

Source
Supreme Court of the United States (opinion of Chief Justice Rehnquist, unanimous)
Date
31 May 2005
Quoted from
Opinion of the Court, Part I, first paragraph (Cornell LII text)
Grade
Primary record
Document
https://www.law.cornell.edu/supremecourt/text/544/696
Accessed
2026-11-10
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Note
The Court reversed on the instructions, not on a finding that the destruction was lawful. The partner's words are quoted by the Court from 374 F.3d 281, 286 (5th Cir. 2004): '[I]f it's destroyed in the course of [the] normal policy and litigation is filed the next day, that's great. . . . [W]e've followed our own policy, and whatever there was that might have been of interest to somebody is gone and irretrievable.' Duncan's secretary: 'Per Dave— No more shredding. . . . We have been officially served for our documents.' (Cornell text, Part I). U.S. Reports page pin cites were not read from the Cornell text and are not given.

Exhibit 1240 · Board committee report

Report of Investigation by the Special Investigative Committee of the Board of Directors of Enron Corp. (Powers Report), section VII, Oversight by the Board of Directors and Management

Because Andersen declined to permit its representatives to be interviewed, we do not know what, if any, steps Andersen took in light of these observations.

The committee finds oversight of the related-party transactions by the board and management failed and that outside auditors did not bring the control failures to the Audit Committee's attention. Footnote 70 records that Andersen declined to let its representatives be interviewed.

Source
Special Investigative Committee of the Board of Directors of Enron Corp. (William C. Powers, Jr., chair; Raymond S. Troubh; Herbert S. Winokur, Jr.)
Date
1 February 2002
Quoted from
Section VII.A, footnote 70, printed p. 154 of the report
Grade
Primary record
Document
https://picker.uchicago.edu/Enron/Class6.pdf
Accessed
2026-11-10
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Note
Read in a University of Chicago course reader that reproduces Section VII of the report (printed pp. 148-). The full report is reproduced in the House Financial Services hearing 'The Enron Collapse' (Feb. 2002, appendix p. 263), but the GPO text layer read did not contain it; replace the URL with a complete official copy. Section VII opens (printed p. 148): 'Oversight of the related-party transactions by Enron's Board of Directors and Management failed for many reasons.' and 'Enron's outside auditors supposedly examined Enron's internal controls, but did not identify or bring to the Audit Committee's attention the inadequacies in their implementation.' The report states parts of Section VII are the views of Powers and Troubh alone.

Exhibit 1241 · Congressional hearing transcript

Statement of Secretary of Defense Donald Rumsfeld, Senate Armed Services Committee hearing on the treatment of Iraqi prisoners (FDCH transcript)

It's important for the American people and the world to know that while these terrible acts were perpetrated by a small number of U.S. military, they were also brought to light by the honorable and responsible actions of other military personnel.

Opening statement of the Secretary of Defense to the Senate Armed Services Committee on the Abu Ghraib abuses. He states that the events occurred on his watch and that as Secretary he is accountable and takes full responsibility, and describes the acts as perpetrated by a small number of U.S. military.

Source
Donald H. Rumsfeld, Secretary of Defense; transcript by FDCH Congressional Hearings
Date
7 May 2004
Quoted from
Rumsfeld opening statement, p. 5 of the PDF (DoD FOIA release DODDOA-010269, copy of the FDCH transcript)
Grade
Reported
Document
https://www.thetorturedatabase.org/files/foia_subsite/pdfs/DODDOA010269.pdf
Accessed
2026-11-10
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Findings citing this exhibit
Note
Grade reported because the copy is a commercial transcript (FDCH) released by DoD under FOIA; the same sentence appears in the GlobalSecurity copy of the testimony, which was also read. Same statement: 'These events occurred on my watch. As secretary of defense, I am accountable for them and I take full responsibility.' A cleaner primary copy would be the Congressional Record or the hearing volume.

Exhibit 1242 · Presidential address (transcript)

President Bush, remarks at the Army War College: President Outlines Steps to Help Iraq Achieve Democracy and Freedom

That same prison became a symbol of disgraceful conduct by a few American troops who dishonored our country and disregarded our values.

Address on Iraq strategy at the Army War College, Carlisle, Pennsylvania. In the section on a new Iraqi prison system the President refers to Abu Ghraib.

Source
George W. Bush, President of the United States (White House Office of the Press Secretary)
Date
24 May 2004
Quoted from
Third-listed step of the plan (new Iraqi prison system) in the White House transcript, paragraph beginning 'A new Iraq will also need a humane, well-supervised prison system.'
Grade
Primary record
Document
https://georgewbush-whitehouse.archives.gov/news/releases/2004/05/20040524-10.html
Accessed
2026-11-10
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Findings citing this exhibit
Note
Locator is by paragraph; the archived page has no paragraph numbers. A 6 May 2004 White House 'Global Message' summarizing the 5 May Al Arabiya and Alhurra interviews (georgewbush-whitehouse.archives.gov/news/releases/2004/05/text/20040506-1.html) reads: 'These actions of a few people do not reflect the nature of the men and women who serve our country.' That text is a White House summary, not a transcript.

Exhibit 1243 · Independent panel report

Final Report of the Independent Panel to Review DoD Detention Operations (Schlesinger Panel)

Still, the abuses were not just the failure of some individuals to follow known standards, and they are more than the failure of a few leaders to enforce proper discipline. There is both institutional and personal responsibility at higher levels.

Panel appointed by the Secretary of Defense. Finds the Tier 1 abuses were acts of brutality by individuals and a failure of leadership and discipline, finds no evidence of a policy of abuse promulgated by senior officials, and finds institutional as well as personal responsibility at higher levels, with command failures contributing directly or indirectly.

Source
Independent Panel to Review DoD Detention Operations (chair James R. Schlesinger), for the Secretary of Defense
Date
August 2004 (released 24 August 2004)
Quoted from
Executive Summary, Overview, final paragraph of the first page of the Executive Summary (PDF p. 7 of the 126-page scan; text read by OCR of the scan)
Grade
Primary record
Document
https://web.archive.org/web/2005/http://www.defense.gov/news/aug2004/d20040824finalreport.pdf
Accessed
2026-11-10
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Findings citing this exhibit
Note
Same page: 'There is no evidence of a policy of abuse promulgated by senior officials or military authorities.' Same report, 'Command Responsibilities': 'Although the most egregious instances of detainee abuse were caused by the aberrant behavior of a limited number of soldiers and the predilections of the non-commissioned officers on the night shift of Tier 1 at Abu Ghraib, the Independent Panel finds that commanding officers and their staffs at various levels failed in their duties and that such failures contributed directly or indirectly to detainee abuse.' (PDF p. 46, OCR). The scan has no printed page numbers visible in OCR; PDF page numbers are given. OCR wording of the quote should be eyeballed against the page image before publication. The dtic.mil copy (ADA428743) returned a bot-block page. Same page: “There is no evidence of a policy of abuse promulgated by senior officials or military authorities.”

Exhibit 1244 · Army investigation report

AR 15-6 Investigation of the 800th Military Police Brigade (Taguba report), certified copy

While those who perpetrated the criminal acts are individually responsible, the command climate, unclear command structure, and insufficient training created an environment conducive to the commission of these offenses.

Army investigation of detainee abuse at Abu Ghraib and the 800th MP Brigade. The Executive Summary finds that the perpetrators are individually responsible and that the command climate, unclear command structure and insufficient training created an environment conducive to the offenses. Finding 5 states the abuse was intentionally perpetrated by several members of the guard force.

Source
MG Antonio M. Taguba, Investigating Officer, Deputy Commanding General Support, Coalition Forces Land Component Command
Date
Findings completed 26 February 2004; transmittal 14 March 2004
Quoted from
Executive Summary, para. 1 (PDF p. 2 of the ACLU-RDI 209 / DODDOA-000248 release)
Grade
Primary record
Document
https://www.thetorturedatabase.org/files/foia_subsite/pdfs/DODDOA000248.pdf
Accessed
2026-11-10
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Findings citing this exhibit
Note
Findings dates from the DA Form 1574 in the same file (completed 26 February 2004) and the 14 March 2004 memorandum. Finding 5 (p. 16): 'This systemic and illegal abuse of detainees was intentionally perpetrated by several members of the military police guard force (372nd Military Police Company, 320th Military Police Battalion, 800th MP Brigade), in Tier (section) 1-A of the Abu Ghraib Prison (BCCF).'

Exhibit 1245 · Army investigation report

AR 15-6 Investigation of the Abu Ghraib Detention Facility and 205th Military Intelligence Brigade (Fay-Jones report), executive summary

Looking beyond personal responsibility, leader responsibility and command responsibility, systemic problems and issues also contributed to the volatile environment in which the abuse occurred.

Army investigation of intelligence activities at Abu Ghraib. Cites individual culpability of dozens of soldiers, and lists systemic problems (doctrine, training, shortages, unclear lines of responsibility, no clear interrogation policy, pressure to produce intelligence) as contributing to the environment.

Source
MG George R. Fay and LTG Anthony R. Jones, Investigating Officers, U.S. Army
Date
August 2004 (executive summary dated 23 August 2004)
Quoted from
Executive Summary, para. a.(4), printed p. 8 (PDF p. 42 of the 177-page copy)
Grade
Primary record
Document
https://hrlibrary.law.umn.edu/OathBetrayed/Fay-Jones%20Report.pdf
Accessed
2026-11-10
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Note
Next page (printed p. 9): the abuses 'were perpetrated or witnessed by individuals or small groups. Such abuse can not be directly tied to a systemic US approach to torture or approved treatment of detainees.' Same paragraph: 'Twenty-seven (27) were cited in this report for some degree of culpability'.

Exhibit 1246 · Congressional testimony (prepared statement)

Testimony of John Stumpf, Chairman and CEO of Wells Fargo & Co., before the Senate Committee on Banking, Housing, and Urban Affairs

I do want to make very clear that there was no orchestrated effort, or scheme as some have called it, by the company.

Prepared testimony at the hearing 'An Examination of Wells Fargo's Unauthorized Accounts and the Regulatory Response' (S. Hrg. 114-510). Apologizes, accepts responsibility for the sales practices, states there was no orchestrated effort or scheme by the company, and describes employee terminations as about 1 percent of the retail workforce a year.

Source
John Stumpf, Chairman and Chief Executive Officer, Wells Fargo & Company
Date
20 September 2016
Quoted from
Prepared testimony, p. 1, fourth paragraph
Grade
Primary record
Document
https://www.banking.senate.gov/imo/media/doc/092016_Stumpf%20Testimony.pdf
Accessed
2026-11-10
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Note
Same page: 'It is important to understand that when an employee provides a customer with a product or service that she did not request or authorize, that employee has done something flat wrong.' and 'I accept full responsibility for all unethical sales practices in our retail banking business'. Terminations passage: 'individuals were terminated over time for sales-related misconduct as a result of investigations opened from January 1, 2011 through March 7, 2016', 'approximately 1% of that workforce annually'. The same statement is in the hearing volume at govinfo.gov CHRG-114shrg23001 (also read).

Exhibit 1247 · Board investigation report (SEC filing, Schedule 14A additional materials)

Sales Practices Investigation Report of the Independent Directors of the Board of Wells Fargo & Company (10 April 2017), as filed with the SEC

There was a disinclination among the Community Bank's senior leadership, regardless of the scope of improper behavior or the number of terminated employees, to see the problem as systemic.

Independent directors' report on retail banking sales practices, based on 100 interviews and more than 35 million documents. Finds the root cause was the distortion of the Community Bank's sales culture and performance management system, with pressure on employees, and finds that senior leaders blamed individual employees.

Source
Independent Directors of the Board of Wells Fargo & Company, with Shearman & Sterling LLP
Date
10 April 2017
Quoted from
Report, Executive Summary, p. 6 (page numbers from the report's own footers as reproduced in the SEC filing)
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/72971/000119312517118654/d375947ddefa14a.htm
Accessed
2026-11-10
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Note
Other lines read: p. 5, 'It was convenient instead to blame the problem of low quality and unauthorized accounts and other employee misconduct on individual wrongdoers and poor management in the field rather than on the Community Bank's sales model.' p. 6, 'It was common to blame employees who violated Wells Fargo's rules without analyzing what caused or motivated them to do so.' p. 7, 'Employees who engaged in misconduct most frequently associated their behavior with sales pressure, rather than compensation incentives'. Overview, Principal Findings: 'The root cause of sales practice failures was the distortion of the Community Bank's sales culture and performance management system'. p. 56 quotes a May 2015 email from the then CEO ending 'This is not systemic.' The report text at that point records he acknowledged in interview that 1% was too high. The directors' report states the Board learned of the roughly 5,300 terminations on 8 September 2016. Quote above uses a straight apostrophe in place of the source's curly one. The 110-page PDF at wellsfargo.com/assets/pdf/about/investor-relations/presentations/2017/board-report.pdf returned a block page to a script.

Exhibit 1248 · Deferred prosecution agreement

United States v. The Boeing Company, Deferred Prosecution Agreement (N.D. Tex.), filed as Exhibit 10.1 to Boeing Form 8-K

the misconduct was neither pervasive across the organization, nor undertaken by a large number of employees, nor facilitated by senior management

Agreement resolving a one-count conspiracy-to-defraud charge over statements to the FAA Aircraft Evaluation Group about MCAS. Paragraph 4 lists the factors on which the Fraud Section entered the agreement, including its determination on an independent monitor. Attachment A is the Statement of Facts, which Boeing stipulated.

Source
U.S. Department of Justice Criminal Division Fraud Section and U.S. Attorney's Office, N.D. Texas, with The Boeing Company
Date
7 January 2021
Quoted from
DPA para. 4(h)(i) (SEC Exhibit 10.1 copy; printed p. 6)
Grade
Primary record
Document
https://www.sec.gov/Archives/edgar/data/12927/000001292721000003/a202001jan078kexhibit101.htm
Accessed
2026-11-10
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Note
These are the Fraud Section's stated factors, not a Boeing statement. Same para. 4(h)(ii): 'although two of the Company's 737 MAX Flight Technical Pilots deceived the FAA AEG about MCAS by way of misleading statements, half-truths, and omissions, others in the Company disclosed MCAS's expanded operational scope to different FAA personnel'. Para. 4(f) records prior matters: a 1989 conviction, a 2006 non-prosecution agreement and a 2015 FAA civil settlement. Boeing's own statement of 16 September 2020 on the House report (boeing.mediaroom.com, item 130735) was read and does not say a few individuals were responsible; it says 'We have learned many hard lessons as a company'. Boeing's 20 October 2019 statement (item 130533) refers to a former employee's message and to 'a large number of individuals at both Boeing and the FAA'. LEGAL READ NEEDED. The DPA post-dates the House report by four months.

Exhibit 1249 · Parliamentary select committee report and evidence

Culture, Media and Sport Committee, Seventh Report of Session 2006-07, Self-regulation of the press (HC 375), with oral evidence

Witnesses representing the press maintained that such practices were not, however, widespread, and that one bad apple did not mean that the whole barrel was rotten.

Committee report on press self-regulation after the Goodman and Mulcaire convictions. Records the evidence of the News International chairman on 6 March 2007 and the press witnesses' position that the practice was not widespread.

Source
House of Commons Culture, Media and Sport Committee
Date
11 July 2007
Quoted from
Report, para. 18, p. 12
Grade
Primary record
Document
https://publications.parliament.uk/pa/cm200607/cmselect/cmcumeds/375/375.pdf
Accessed
2026-11-10
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Note
Oral evidence, 6 March 2007, Q95 (Ev 40): Chairman: 'You carried out a full, rigorous internal inquiry, and you are absolutely convinced that Clive Goodman was the only person who knew what was going on?' Mr Hinton (Chairman of News International): 'Yes, we have and I believe he was the only person, but that investigation, under the new editor, continues.' Para. 21 records the committee noting the assurances of the News International chairman that Mr Goodman 'was acting wholly without authorisation'. Read via a Wayback copy of the parliament.uk PDF; the live site returned a block page.

Exhibit 1250 · Parliamentary select committee report

Culture, Media and Sport Committee, Ninth Report of Session 2009-10, Press standards, privacy and libel (HC 362), chapter on phone-hacking

The idea that Clive Goodman was a "rogue reporter" acting alone is also directly contradicted by the Judge who presided at the Goodman and Mulcaire trial.

Committee report that reopened evidence after July 2009 press reports of settlements. Records that News International had told the committee and the PCC that its inquiries showed the Goodman case was isolated, and finds that the 'rogue reporter' account is contradicted by the trial judge's summing up.

Source
House of Commons Culture, Media and Sport Committee
Date
24 February 2010
Quoted from
Chapter on phone-hacking, para. 441
Grade
Primary record
Document
https://publications.parliament.uk/pa/cm200910/cmselect/cmcumeds/362/36208.htm
Accessed
2026-11-10
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Findings citing this exhibit
Note
Para. 442: 'The newspaper's enquiries were far from 'full' or 'rigorous', as we - and the PCC - had been assured.' Para. 401 records the 2007 assurances and the Q95 exchange. Para. 440: 'Evidence we have seen makes it inconceivable that no-one else at the News of the World , bar Clive Goodman, knew about the phone-hacking.' Para. 439: 'We have seen no evidence that Andy Coulson knew that phone-hacking was taking place.' Section and summary text read via a Wayback copy; chapter file 36208.htm; the summary chapter (36203.htm) restates the finding. The report is of the committee, which in later proceedings (Leveson Inquiry) was followed by further findings not read here.

Exhibit 1251 · Newspaper article

Beating Victim Says He Obeyed Police (Tracy Wood and Faye Fiore, Los Angeles Times, 7 March 1991)

While Gates called the beating an aberration, Bradley said it points to a breakdown in leadership

Report on Rodney King's account, the district attorney's decision not to charge him and reactions of city officials to the videotaped beating.

Source
Los Angeles Times
Date
7 March 1991
Quoted from
Article text, near the end of the story (3-page scan; page number not legible)
Grade
Reported
Document
https://scalar.usc.edu/works/the-los-angeles-riots-christopher-and-webster-commissions-collections/media/Beating_victim_says_he_obeyed_police_19910307.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported grade; the Christopher Commission report (July 1991, p. 12) records the same statement: 'Chief Gates also described the incident as an aberration and expressed his hope that the public would not judge the entire Department on this one case.' Replace with the primary LAPD or Chief's statement if one is found. Speaker: Daryl F. Gates, Chief of Police; Tom Bradley, Mayor.

Exhibit 1252 · Independent commission report

Report of the Independent Commission on the Los Angeles Police Department (Christopher Commission)

The LAPD's failure to analyze and act upon these revealing data evidences a significant breakdown in the management and leadership of the Department.

Commission appointed after the King beating. Finds that a small group of 'problem' officers drew a disproportionate share of excessive-force complaints and that the Department's management failed to act on its own data. Records the Chief's initial description of the beating as an aberration.

Source
Independent Commission on the Los Angeles Police Department (chair Warren Christopher)
Date
9 July 1991
Quoted from
Foreword, printed p. iv (PDF p. 10)
Grade
Primary record
Document
https://scalar.usc.edu/works/the-los-angeles-riots-christopher-and-webster-commissions-collections/media/Independent_Commission_Report.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Chapter 1, p. 12: 'Chief Gates also described the incident as an aberration and expressed his hope that the public would not judge the entire Department on this one case.' Chapter 3, p. 32 (OCR garbled in the scan; wording to be confirmed on the page image): excessive force 'is fundamentally a problem of supervision, management, and leadership'. The commission also found force complaints 'concentrated in relatively few officers' (the 'problem group' of 44 officers), so the report supports both a small-group finding and a management finding.

Exhibit 1253 · Scholarly essay (magazine)

Police corruption: apples, barrels and orchards (Maurice Punch), Criminal Justice Matters

The defensive metaphor of the 'bad apples' conveys an image of a few reprehensible individuals who, if removed, will no longer contaminate the otherwise healthy apples.

Essay by a police-corruption scholar contrasting the 'bad apples' explanation with organizational and system-level accounts.

Source
Maurice Punch, Centre for Crime and Justice Studies (Criminal Justice Matters, edition 79)
Date
Web copy dated 26 July 2016
Quoted from
Body text, paragraph beginning 'Whole parts of a force could become routinely and systemically corrupt.'
Grade
Reported
Document
https://www.crimeandjustice.org.uk/node/3297
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Magazine essay, not the peer-reviewed article (Punch 2003, 'Rotten orchards', Policing and Society 13(2) 171-196, not read). The web page gives edition 'cjm 79' and a web date of 26 July 2016; the issue year was not read. Quote uses straight single quotes in place of the source's curly ones. Same essay: 'Typically this is group behaviour and not individual.' and 'Behind every bent cop, then, there are always others, including supervisors, who either took part or knew about it.'

Exhibit 1254 · Inspector general audit report

SEC's Oversight of Bear Stearns and Related Entities: The Consolidated Supervised Entity Program (Report No. 446-A)

it is undisputable that the CSE program failed to carry out its mission in its oversight of Bear Stearns because under the Commission and the CSE program's watch, Bear Stearns suffered significant financial weaknesses and the FRBNY needed to intervene during the week of March 10, 2008, to prevent significant harm to the broader financial system.

The SEC Inspector General audited the Commission's Consolidated Supervised Entity (CSE) program as applied to Bear Stearns. The report finds that the program did not carry out its stated mission in its oversight of Bear Stearns and identifies serious deficiencies that warrant improvements. It states that the audit does not purport to show a specific or direct connection between the program's oversight and the collapse.

Source
SEC Office of Inspector General
Date
25 September 2008
Quoted from
Audit Conclusions and Results, printed p. viii (PDF p. 8). Read from a rendered page image because the PDF text layer is imperfect OCR
Grade
Primary record
Document
https://www.sec-oig.gov/Reports/AuditsInspections/2008/446-A.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Same page, next paragraph: 'This audit was not intended to be a complete assessment of the multitude of events that led to Bear Stearns' collapse, and accordingly, does not purport to demonstrate any specific or direct connection between the failure of the CSE Program's oversight of Bear Stearns and Bear Stearns' collapse.' The 'because' in the quoted sentence is the Inspector General's, and explains why the program failed its mission, not why Bear Stearns failed. The sec.gov copy did not load; the sec-oig.gov URL was read from a Wayback capture.

Exhibit 1255 · Agency budget justification

U.S. Securities and Exchange Commission, FY 2010 Congressional Justification in Brief

The SEC's FY 2010 budget justification gives obligations by object class and a Spending Authority line of $905,313 thousand for FY 2008 (Actual), $960,000 thousand for FY 2009 (Enacted, including a $17 million reprogramming) and $1,026,000 thousand for FY 2010 (Request).

Source
U.S. Securities and Exchange Commission
Date
2009 (month not shown in the text read)
Grade
Primary record
Document
https://www.sec.gov/about/secfy10congbudgjust.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Figures in thousands of nominal dollars; FY 2008 Actual excludes $10 million in upward adjustments of prior-year obligations included in the President's FY 2010 Budget Appendix. Table on PDF p. 4. Read from a Wayback capture.

Exhibit 1256 · Agency budget justification

U.S. Securities and Exchange Commission, In Brief, FY 2012 Congressional Justification

the Act authorized an increase in the agency’s budget from the $1.11 billion appropriated in FY 2010 to $1.3 billion in FY 2011, $1.5 billion in FY 2012, and $2.25 billion by FY 2015.

The SEC's FY 2012 justification states that the Dodd-Frank Act authorized an increase in the agency's budget from the $1.11 billion appropriated in FY 2010 to $1.3 billion in FY 2011, $1.5 billion in FY 2012 and $2.25 billion by FY 2015, and gives FY 2010 total authority of $1,118,753 thousand, an FY 2011 continuing-resolution level of $1,143,855 thousand and an FY 2012 request of $1,407,483 thousand.

Source
U.S. Securities and Exchange Commission
Date
February 2011
Quoted from
Executive Summary, PDF p. 4; spending-authority table, PDF p. 15
Grade
Primary record
Document
https://www.sec.gov/about/secfy12congbudgjust.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The statute itself (Dodd-Frank sec. 991(c), adding Exchange Act sec. 35) is quoted in the supplements under congress-2010-dodd-frank-act. Read from a Wayback capture.

Exhibit 1257 · Statute

Intelligence Reform and Terrorism Prevention Act of 2004, Pub. L. 108-458, sec. 1011

There is a Director of National Intelligence who shall be appointed by the President, by and with the advice and consent of the Senate.

Section 1011 of the Act amends the National Security Act of 1947 to establish a Director of National Intelligence, appointed by the President with Senate consent, who heads the intelligence community and oversees and directs implementation of the National Intelligence Program. The Act was approved 17 December 2004.

Source
U.S. Congress
Date
17 December 2004
Quoted from
Sec. 1011, new National Security Act sec. 102(a)(1), 118 Stat. 3644
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-108publ458/html/PLAW-108publ458.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Section 102(b)(3) in the same section: 'oversee and direct the implementation of the National Intelligence Program.'

Exhibit 1258 · Agency news release

DNI Releases Budget Figure for National Intelligence Program (ODNI News Release No. 22-07)

The aggregate amount appropriated to the NIP for fiscal year 2007 was $43.5 billion.

The DNI discloses, under section 601 of Pub. L. 110-53, the aggregate amount appropriated to the National Intelligence Program for fiscal year 2007.

Source
Office of the Director of National Intelligence
Date
30 October 2007
Quoted from
Paragraph 2
Grade
Primary record
Document
http://www.dni.gov/press_releases/20071030_release.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read from a Wayback capture of the dni.gov PDF.

Exhibit 1259 · Agency news release

DNI Releases Budget Figure for 2008 National Intelligence Program (ODNI News Release No. 17-08)

The aggregate amount appropriated to the NIP for fiscal year 2008 was $47.5 Billion.

The DNI discloses the aggregate amount appropriated to the National Intelligence Program for fiscal year 2008.

Source
Office of the Director of National Intelligence
Date
28 October 2008
Quoted from
Paragraph 2
Grade
Primary record
Document
http://www.dni.gov/press_releases/20081028_release.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read from a Wayback capture of the dni.gov PDF.

Exhibit 1260 · Agency news release

DNI Releases Budget Figure for 2009 National Intelligence Program (ODNI News Release No. 33-09)

The Director disclosed that the aggregate amount appropriated to the NIP for fiscal year 2009 was $49.8 Billion.

The DNI discloses the aggregate amount appropriated to the National Intelligence Program for fiscal year 2009.

Source
Office of the Director of National Intelligence
Date
30 October 2009
Quoted from
Paragraph 1
Grade
Primary record
Document
https://irp.fas.org/news/2009/10/dni103009.html
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read on the Federation of American Scientists copy of the ODNI release (irp.fas.org). The dni.gov original was not retrieved; replace the url with it before publication.

Exhibit 1261 · Agency news release

DNI Releases Budget Figure for 2010 National Intelligence Program (ODNI News Release No. 21-10)

The aggregate amount appropriated to the NIP for Fiscal Year 2010 was $53.1 billion.

The DNI discloses, under section 364 of Pub. L. 111-259, the aggregate amount appropriated to the National Intelligence Program for fiscal year 2010.

Source
Office of the Director of National Intelligence
Date
28 October 2010
Quoted from
Paragraph 2
Grade
Primary record
Document
https://irp.fas.org/news/2010/10/dni102810.html
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read on the Federation of American Scientists copy of the ODNI release (irp.fas.org). The dni.gov original was not retrieved; replace the url with it before publication.

Exhibit 1262 · Agency statement

Statement of the Director of Central Intelligence Regarding the Disclosure of the Aggregate Intelligence Budget for Fiscal Year 1997

The DCI announces the declassification of the aggregate intelligence budget for fiscal year 1997 following a Freedom of Information Act lawsuit, and states that disclosure of future aggregate figures will be considered only after determining whether it could harm national security.

Source
Central Intelligence Agency
Date
15 October 1997
Grade
Primary record
Document
https://www.cia.gov/news-information/press-releases-statements/press-release-archive-1997-1/pr101597.html
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
The FY1997 figure ($26.6 billion) is stated in the March 1998 statement registered next. Read from a Wayback capture.

Exhibit 1263 · Agency statement

Statement by the Director of Central Intelligence Regarding the Disclosure of the Aggregate Intelligence Budget for Fiscal Year 1998

The fiscal year 1998 figure is $26.7 billion.

The DCI states that the aggregate amount appropriated for intelligence and intelligence-related activities was $26.6 billion for fiscal year 1997 and $26.7 billion for fiscal year 1998.

Source
Central Intelligence Agency
Date
20 March 1998
Quoted from
Single page, final paragraph
Grade
Primary record
Document
https://www.cia.gov/news-information/press-releases-statements/press-release-archive-1998/ps032098.html
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Basis: 'intelligence and intelligence-related activities' (in the CIA declaration of 11 Dec 1998 read at sgp.fas.org/foia/tenet1298.html, the sum of NFIP, JMIP and TIARA). The 2007 and later ODNI figures cover the National Intelligence Program only. The two series are not on the same basis and are not subtracted. Read from a Wayback capture.

Exhibit 1264 · Agency budget compendium

National Defense Budget Estimates for FY 2025 (the Green Book), Table 6-1: Department of Defense TOA by Public Law Title

Table 6-1 gives Department of Defense total obligational authority in millions of current dollars, with war and supplemental funding included: FY2018 672,960; FY2019 693,001; FY2020 725,757; FY2021 711,039; FY2022 769,467; FY2023 858,262; FY2024 817,508. The FY2024 column is marked CR*, 'FY 2024 reflects Continuing Resolution (CR) P.L. 118-15, as amended.'

Source
Office of the Under Secretary of Defense (Comptroller)
Date
April 2024
Grade
Primary record
Document
https://comptroller.defense.gov/Portals/45/Documents/defbudget/FY2025/fy25_Green_Book.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Total Current Dollars row, printed pp. 86 (FY2014-FY2022 block) and 87 (FY2023-FY2029 block); PDF pp. 93-94. The comptroller.defense.gov host refused the request and the file was read from a Wayback capture. The FY2026 Green Book is linked from the comptroller's FY2026 page but had no archive capture on 2026-11-10 and was not read; the FY2024 figure here is the CR-based figure printed in April 2024 and may differ from the enacted full-year level.

Exhibit 1265 · Inspector general lessons-learned report

Reconstructing the Afghan National Defense and Security Forces: Lessons from the U.S. Experience in Afghanistan (SIGAR 17-62-LL)

The U.S. government was ill-prepared to conduct SSA programs of the size and scope required in Afghanistan.

SIGAR lists 12 key findings on the U.S. experience building the Afghan National Defense and Security Forces. It states that the United States devoted over $70 billion (60 percent) of its Afghanistan reconstruction funds to the ANDSF through 2016 and continues to commit over $4 billion per year.

Source
Special Inspector General for Afghanistan Reconstruction
Date
September 2017
Quoted from
Summary, key finding 1, PDF p. 11
Grade
Primary record
Document
https://www.sigar.mil/pdf/lessonslearned/SIGAR-17-62-LL.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
SSA is security sector assistance. Key finding 5 on the same page reads 'The United States failed to optimize coalition nations’ capabilities to support SSA missions in the context of international political realities.' The sigar.mil host did not resolve on 2026-11-10; read from a Wayback capture.

Exhibit 1266 · Inspector general quarterly report

Quarterly Report to the United States Congress, 30 October 2017, Status of Funds

Since 2002, Congress has appropriated approximately $120.78 billion for Afghanistan relief and reconstruction.

SIGAR reports cumulative appropriations for Afghanistan relief and reconstruction since 2002 of approximately $120.78 billion, of which $101.84 billion went to seven major funds, including $68.27 billion appropriated to the Afghanistan Security Forces Fund (Table 3.2, FY 2002 to FY 2017).

Source
Special Inspector General for Afghanistan Reconstruction
Date
30 October 2017
Quoted from
Section 3, Status of Funds, Afghanistan Reconstruction Funding Pipeline, PDF p. 91
Grade
Primary record
Document
https://www.sigar.mil/pdf/quarterlyreports/2017-10-30qr.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Nominal dollars as reported by SIGAR, 'appropriated' as SIGAR defines the term in the report. Read from a Wayback capture.

Exhibit 1267 · Inspector general quarterly report

Quarterly Report to the United States Congress, 30 July 2021, Status of Funds

Since 2002, Congress has appropriated more than $144.98 billion for reconstruction and related activities in Afghanistan

SIGAR reports cumulative appropriations since 2002 of more than $144.98 billion, of which nearly $120.32 billion went to the eight largest active accounts, including $82.90 billion appropriated to the Afghanistan Security Forces Fund (Table 2.2, FY 2002 to 30 June 2021).

Source
Special Inspector General for Afghanistan Reconstruction
Date
30 July 2021
Quoted from
Section 2, Funding Pipeline, PDF p. 39
Grade
Primary record
Document
https://www.sigar.mil/pdf/quarterlyreports/2021-07-30qr.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Nominal dollars as reported by SIGAR. Read from a Wayback capture.

Exhibit 1268 · Statute

Continuing Appropriations and Ukraine Supplemental Appropriations Act, 2023, Pub. L. 117-180, Division F (FDA User Fee Reauthorization Act of 2022), sec. 1005

Sections 735 and 736 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 379g; 379h) shall cease to be effective October 1, 2027.

Division F of the Act reauthorizes the prescription drug, device, generic drug and biosimilar user fee programs. Section 1005(a) ends the prescription drug fee authority on 1 October 2027, and section 1005(c) repeals, effective 1 October 2022, the previous sunset provision in section 104 of the FDA Reauthorization Act of 2017.

Source
U.S. Congress
Date
30 September 2022
Quoted from
Div. F, sec. 1005(a)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-117publ180/html/PLAW-117publ180.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Approved 30 September 2022 (H.R. 6833).

Exhibit 1269 · Statute

Consolidated Appropriations Act, 2023, Pub. L. 117-328, Div. FF (Food and Drug Omnibus Reform Act of 2022), sec. 3210, Modernizing accelerated approval

The Secretary may require, as appropriate, a study or studies to be underway prior to approval, or within a specified time period after the date of approval, of the applicable product.

Section 3210 amends section 506(c) of the Federal Food, Drug, and Cosmetic Act. It lets the Secretary require a postapproval study to be underway before approval or within a specified period after approval, requires the Secretary to specify study conditions, including a target completion date, by the date of approval, and revises the withdrawal procedure.

Source
U.S. Congress
Date
29 December 2022
Quoted from
Sec. 3210(a)(1)(D), new sec. 506(c)(2)(D), 136 Stat. 5822
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-117publ328/html/PLAW-117publ328.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Approved 29 December 2022 (H.R. 2617). The quotation begins at 'The Secretary may require' inside new subparagraph (D), which is headed 'Studies begun before approval.'

Exhibit 1270 · Federal Register notice

Prescription Drug User Fee Rates for Fiscal Year 2022, 86 FR 45732

The final FY 2022 PDUFA target revenue is $1,200,129,000 (rounded to the nearest thousand dollars).

FDA sets the FY 2022 PDUFA target revenue under the PDUFA VI base amounts and statutory adjustments.

Source
Food and Drug Administration
Date
16 August 2021
Quoted from
Section II, Fee Revenue Amount for FY 2022
Grade
Primary record
Document
https://www.federalregister.gov/documents/2021/08/16/2021-17505/prescription-drug-user-fee-rates-for-fiscal-year-2022
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read through the Federal Register API raw-text file. Nominal dollars; target revenue to be collected from fees.

Exhibit 1271 · Federal Register notice

Prescription Drug User Fee Rates for Fiscal Year 2023, 87 FR 61063

results in the total revenue amount of $1,310,319,000 (rounded to the nearest thousand dollars)

FDA sets the FY 2023 PDUFA target revenue under the PDUFA VII base amounts and statutory adjustments.

Source
Food and Drug Administration
Date
7 October 2022
Quoted from
Section II, Fee Revenue Amount for FY 2023, final paragraph of the additional-direct-cost adjustment
Grade
Primary record
Document
https://www.federalregister.gov/documents/2022/10/07/2022-21968/prescription-drug-user-fee-rates-for-fiscal-year-2023
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read through the Federal Register API raw-text file. Nominal dollars. The notice states that for FY 2023 through FY 2027 the base revenue amounts are established by PDUFA VII.

Exhibit 1272 · Federal Register notice

Prescription Drug User Fee Rates for Fiscal Year 2024, 88 FR 48881

results in the total revenue amount of $1,422,104,000 (rounded to the nearest thousand dollars)

FDA sets the FY 2024 PDUFA target revenue under the PDUFA VII base amounts and statutory adjustments.

Source
Food and Drug Administration
Date
28 July 2023
Quoted from
Section II, Fee Revenue Amount for FY 2024
Grade
Primary record
Document
https://www.federalregister.gov/documents/2023/07/28/2023-15911/prescription-drug-user-fee-rates-for-fiscal-year-2024
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read through the Federal Register API raw-text file. Nominal dollars. A correction notice for FY 2024 rates (88 FR 51330, 3 August 2023) exists and was not read.

Exhibit 1273 · Constitutional amendment

Twentieth Amendment to the Constitution of the United States (text as published by the National Archives)

shall end at noon on the 20th day of January

Section 1 fixes the end of the terms of the President and Vice President at noon on 20 January. This is the calendar source for the dates on which each presidential term in the tables begins and ends.

Source
United States Congress; text published by the National Archives
Date
Ratified 23 January 1933
Quoted from
Amendment XX, section 1 (National Archives page, 'Amendments 11-27')
Grade
Primary record
Document
https://www.archives.gov/founding-docs/amendments-11-27
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1274 · Government record

Electoral College Results, 1952 to 2024 (one National Archives page per election year)

2020 Electoral College Results President Joseph R. Biden Jr. [D] Main Opponent Donald J. Trump [R]

Each year page names the winning candidate with party. Pages read: 1952, 1956, 1980, 1984, 1988, 1992, 1996, 2000, 2004, 2008, 2012, 2016, 2020 and 2024. They show Republican winners in 1952, 1956, 1980, 1984, 1988, 2000, 2004, 2016 and 2024 and Democratic winners in 1992, 1996, 2008, 2012 and 2020. The quote is the 2020 page; the other years' pages use the same format.

Source
National Archives, Office of the Federal Register
Date
Pages read 10 November 2026
Quoted from
archives.gov/electoral-college/2020, results header (page text as served 2026-11-10)
Grade
Primary record
Document
https://www.archives.gov/electoral-college/2020
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1275 · Statute

Chief Financial Officers Act of 1990, Pub. L. 101-576, sec. 304 (agency financial statement audits)

Each financial statement prepared under section 3515 by an agency shall be audited in accordance with applicable generally accepted government auditing standards

Requires executive agencies to prepare annual financial statements (new 31 U.S.C. 3515, from 31 March 1992) and requires each statement to be audited, by the Inspector General or an outside auditor, under government auditing standards. This is the audit requirement the DoD Inspector General cites for the annual DoD audit.

Source
United States Congress
Date
15 November 1990
Quoted from
Sec. 304(a), adding 31 U.S.C. 3521(e), 104 Stat. 2852 (govinfo scan, OCR text)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/STATUTE-104/pdf/STATUTE-104-Pg2838.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1276 · GAO report

High-Risk Series: An Overview (GAO/HR-95-1)

Defense’s financial management systems, practices, and procedures continue to be hampered by significant weaknesses

GAO's 1995 high-risk overview newly designates serious financial management weaknesses at the Department of Defense as a high-risk area. GAO's 2026 testimony (gao-2026-109115-testimony) states that GAO designated DoD financial management high-risk in 1995.

Source
U.S. General Accounting Office
Date
February 1995
Quoted from
GAO/HR-95-1, printed p. 39 (chapter 'GAO's High-Risk Focus', section 'Financial Management'); sentence is followed by footnote marker 1
Grade
Primary record
Document
https://files.gao.gov/assets/hr-95-1.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1277 · Statute

Prescription Drug User Fee Act of 1992, Pub. L. 102-571, Title I

the public health will be served by making additional funds available for the purpose of augmenting the resources of the Food and Drug Administration that are devoted to the process for review of human drug applications

Authorizes fees on human drug applications, prescription drug establishments and products, for the stated purpose of adding funds to FDA's drug application review. Signed 29 October 1992.

Source
United States Congress
Date
29 October 1992
Quoted from
Sec. 102(2), 106 Stat. 4491 (govinfo scan, OCR text)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/STATUTE-106/pdf/STATUTE-106-Pg4491.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1278 · Statute

Food and Drug Administration Modernization Act of 1997, Pub. L. 105-115, Title I, Subtitle A (first PDUFA reauthorization)

reauthorized for an additional 5 years, with certain technical improvements

Subtitle A, Fees Relating to Drugs, reauthorizes the 1992 fee program for five more years. Approved 21 November 1997.

Source
United States Congress
Date
21 November 1997
Quoted from
Sec. 101(3)(A), 111 Stat. 2298
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-105publ115/html/PLAW-105publ115.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1279 · Statute

Public Health Security and Bioterrorism Preparedness and Response Act of 2002, Pub. L. 107-188, Title V, Subtitle A (Prescription Drug User Fee Amendments of 2002)

the public health will be served by making additional funds available for the purpose of augmenting the resources of the Food and Drug Administration that are devoted to the process for the review of human drug applications and the assurance of drug safety

Title V, Subtitle A is the Prescription Drug User Fee Amendments of 2002 (PDUFA III). Approved 12 June 2002.

Source
United States Congress
Date
12 June 2002
Quoted from
Sec. 502(2)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-107publ188/html/PLAW-107publ188.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1280 · Statute

Food and Drug Administration Safety and Innovation Act, Pub. L. 112-144, Title I (Prescription Drug User Fee Amendments of 2012)

The Congress finds that the fees authorized by the amendments made in this title will be dedicated toward expediting the drug development process and the process for the review of human drug applications, including postmarket drug safety activities

Title I is the Prescription Drug User Fee Amendments of 2012 (PDUFA V). Approved 9 July 2012.

Source
United States Congress
Date
9 July 2012
Quoted from
Sec. 101(b)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-112publ144/html/PLAW-112publ144.htm
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1281 · Statute

FDA Reauthorization Act of 2017, Pub. L. 115-52, Title I (Prescription Drug User Fee Amendments of 2017)

The Congress finds that the fees authorized by the amendments made in this title will be dedicated toward expediting the drug development process and the process for the review of human drug applications, including postmarket drug safety activities

Title I is the Prescription Drug User Fee Amendments of 2017 (PDUFA VI). Approved 18 August 2017.

Source
United States Congress
Date
18 August 2017
Quoted from
Sec. 101(b)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-115publ52/html/PLAW-115publ52.htm
Accessed
2026-11-10
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Exhibit 1282 · Statute

Continuing Appropriations and Ukraine Supplemental Appropriations Act, 2023, Pub. L. 117-180, Division F, Title I (Prescription Drug User Fee Amendments of 2022)

Congress finds that the fees authorized by the amendments made by this title will be dedicated toward expediting the drug development process and the process for the review of human drug applications, including postmarket drug safety activities

Title I of the FDA User Fee Reauthorization Act of 2022, enacted inside a continuing appropriations act, is the Prescription Drug User Fee Amendments of 2022 (PDUFA VII). Approved 30 September 2022.

Source
United States Congress
Date
30 September 2022
Quoted from
Sec. 1001(b)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/PLAW-117publ180/html/PLAW-117publ180.htm
Accessed
2026-11-10
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Findings citing this exhibit

Exhibit 1283 · GAO report

Food and Drug Administration: Effect of User Fees on Drug Approval Times, Withdrawals, and Other Agency Activities (GAO-02-958)

user fees funded 7 percent of drug and biologic review obligations in fiscal year 1993, user fees accounted for nearly 50 percent of the total funds obligated for the drug and biologic review processes in fiscal year 2001.

GAO reports the share of FDA's drug and biologic review obligations paid from user fees: 7 percent in fiscal year 1993, nearly 50 percent in fiscal year 2001, and 51 percent expected for fiscal year 2002.

Source
U.S. General Accounting Office
Date
September 2002
Quoted from
GAO-02-958, printed p. 8 (section 'PDUFA Has Increased Funding and Reduced Drug Approval Time...')
Grade
Primary record
Document
https://files.gao.gov/assets/gao-02-958.pdf
Accessed
2026-11-10
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Findings citing this exhibit

Exhibit 1284 · Agency record

FDA Leadership 1907 to Today: Commissioners (term dates)

Martin A. Makary, M.D., M.P.H. 03/25/2025 - 05/13/2026

FDA's own list of Commissioners of Food and Drugs with term dates. It lists no term between 28 February 1997 and 17 January 1999, between 19 January 2001 and 14 November 2002, or after 13 May 2026; those periods are not on the list.

Source
U.S. Food and Drug Administration
Date
Content current as of 15 May 2026
Quoted from
Commissioners page, first row (page text as served 2026-11-10; content current as of 05/15/2026)
Grade
Primary record
Document
https://www.fda.gov/about-fda/fda-leadership-1907-today/commissioners
Accessed
2026-11-10
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Findings citing this exhibit

Exhibit 1285 · GAO report

Post-Government Employment Restrictions: DOD Could Further Enhance Its Compliance Efforts Related to Former Employees Working for Defense Contractors (GAO-21-104311)

Similar to what we found in 2008, DOD contractors identified fewer former DOD senior and acquisition officials in their employ than we identified using DOD personnel data and IRS tax data.

GAO's 2021 update of its 2008 report. The 14 major contractors reviewed employed 1,718 former DoD senior or acquisition officials in 2019 who left DoD service from 2014 through 2019. Ten contractors reported 816 such former officials against 1,149 in GAO's DoD and IRS data, and GAO could not reconcile the difference. The report states employment of these officials is lawful but subject to restrictions; it reports no violation counts as a finding of this sentence.

Source
U.S. Government Accountability Office
Date
September 2021
Quoted from
GAO-21-104311, printed p. 15 (section 'Contractors Identified Fewer Former DOD Senior and Acquisition Officials than We Found in Our Analysis')
Grade
Primary record
Document
https://files.gao.gov/assets/gao-21-104311.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1286 · Inspector general report

SIGAR Quarterly Report to the United States Congress, 30 July 2010 (message from the Special Inspector General)

all of SIGAR’s audits of infrastructure projects have identified operations and maintenance issues.

The Special Inspector General lists four issues impeding reconstruction: accountability and oversight by implementers, metrics, sustainability, and capacity building in Afghan institutions. The message reports that all of SIGAR's infrastructure audits to that date identified operations and maintenance issues.

Source
Special Inspector General for Afghanistan Reconstruction
Date
30 July 2010
Quoted from
Message from the Special Inspector General, PDF p. 6 (second page of the message). Read from the Wayback Machine capture of the sigar.mil PDF; sigar.mil did not resolve on 2026-11-10.
Grade
Primary record
Document
https://sigar.mil/Portals/147/Files/Reports/Quarterly-Reports/2010-07-30qr.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1287 · Inspector general report

SIGAR Quarterly Report to the United States Congress, 30 January 2019 (summary of 2018 Lessons Learned reports)

SIGAR analysis revealed that Afghanistan’s early economic gains were largely due to foreign spending and were not sustainable.

The quarterly report summarizes three Lessons Learned reports issued in 2018. Its summary of the 19 April 2018 report on private sector development states that early economic gains were largely due to foreign spending and were not sustainable.

Source
Special Inspector General for Afghanistan Reconstruction
Date
30 January 2019
Quoted from
Section 'Lessons Learned Reports Issued', item 3 (PDF p. 12). Read from the Wayback Machine capture of the sigar.mil PDF.
Grade
Primary record
Document
https://www.sigar.mil/pdf/quarterlyreports/2019-01-30qr.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit

Exhibit 1288 · Dataset query

Lobbying Disclosure Act filings: Ballard Partners (registrant 401104288), all LD-2 and registration filings, 2017 to third quarter 2026

All 6,179 filings for filing_year 2016 to 2026 read from the API (none for 2016). For each client and quarter the latest posted filing is used. Income by year in $ million: 2017 9.67; 2018 18.02; 2019 18.79; 2020 23.80; 2021 17.44; 2022 17.81; 2023 17.52; 2024 19.27; 2025 88.06; 2026 Q1 to Q3 97.27 (30.15, 32.23, 34.89). Without reports typed "No Activity": 2025 81.62; 2026 Q1 to Q3 90.40.

Source
U.S. Congress (Lobbying Disclosure Act database, lda.gov); query by Lacuna
Date
run 10 November 2026
Grade
Primary record
Document
https://lda.gov/api/v1/filings/?registrant_id=401104288
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Saved with the dataset exhibit lda-2026-top-firms-run: rows in lda-raw-slim-filings.jsonl.gz (query_file ballard-YYYY).

Exhibit 1289 · Dataset

Dataset: Lobbying Disclosure Act LD-2 income by registrant, pool of large firms, 2016, 2017, 2021, 2024, 2025 and 2026 (Q1 to Q3), with single-quarter snapshots

Method: for each year, second-quarter filings of $100,000 or more per client were pulled to find candidates; then every filing for each pool registrant (top 8 candidates plus a fixed list of large firms) was pulled by registrant_id and filing_year and summed (latest posted filing per registrant, client, quarter). Ranking is of the pool only. Top firm by exact income: Akin Gump 2016 $36.23 million and 2017 $39.08 million; Brownstein Hyatt 2021 $56.35 million and 2024 $67.88 million; Ballard Partners 2025 $88.06 million and 2026 to date $97.27 million. Registrant 401108853 reports $20 million in each 2025 quarter and is excluded from rankings. Anonymous API access limits the query; annual all-registrant totals were not derived.

Source
Lacuna derivation from the Lobbying Disclosure Act database (lda.gov REST API)
Date
run 10 November 2026
Grade
Primary record
Document
https://lda.gov/api/v1/filings/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Saved copy: research/politics-2026-ballard/lda-top-firms-dataset.json (method, pools, tables) sha256 6d5ba8cbc265f275e1e3d1e7e59a054123ca9133ded22739b885a68663f2f6e4; rows: research/politics-2026-ballard/lda-raw-slim-filings.jsonl.gz sha256 fc6927ae112d54f936bbdef2399bdd3ac49ff1c6c745e6ccf068535c7388f5c3. The url is the API endpoint, not a document.

Exhibit 1290 · Dataset query

Lobbying Disclosure Act filings naming RAI Services Company (Reynolds American) as client, 2025 and 2026

In 2025, 20 outside registrants with income reported $3.445 million for RAI Services Company, and RAI Services reported $7.26 million of its own lobbying expenses. For the first three quarters of 2026: 17 outside registrants, $2.735 million; $5.84 million of expenses. Ballard Partners reported $560,000 in 2025 and $550,000 for the first three quarters of 2026; outside registrants also include BGR, Capitol Counsel, King and Spalding, Miller and Chevalier, OnMessage Public Strategies and Williams and Jensen.

Source
U.S. Congress (Lobbying Disclosure Act database, lda.gov); query by Lacuna
Date
run 10 November 2026
Grade
Primary record
Document
https://lda.gov/api/v1/filings/?client_name=rai+services&filing_year=2025
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Results in research/politics-2026-ballard/lda-top-firms-dataset.json (rai_services_lobbying_2025_2026_q1_q3). One subcontract (Old North Strategies for Peter Damon Group) may overlap another registrant's fee.

Exhibit 1291 · Company filing

Ballard Partners LD-2 reports for client RAI Services Company, first quarter 2025 to third quarter 2026

Seven quarterly reports give the issue text "Advocated for a harm reduction approach to tobacco regulation by the Food and Drug Administration." Income was $140,000 in each 2025 quarter, $150,000 (Q1 2026), $190,000 (Q2 2026) and $210,000 (Q3 2026). The government entities listed include White House Office, Food and Drug Administration, HHS and CMS in the second quarter of 2026 (filed 2026-07-16) and White House Office, FDA and HHS in the third quarter (filed 2026-10-18); the first-quarter 2026 report lists the House only; the 2025 reports list no White House Office.

Source
U.S. Congress (Lobbying Disclosure Act database, lda.gov)
Date
filed 2025-04-19 to 2026-10-18
Grade
Primary record
Document
https://lda.gov/filings/public/filing/e9348592-f256-4f69-a341-8eba2f442b43/print/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Filing ids and entity lists are in research/politics-2026-ballard/lda-top-firms-dataset.json (ballard_filings_for_rai_services). The url is the second-quarter 2026 report.

Exhibit 1292 · Agency web page

FARA eFile records: Podesta Group, Inc. (no. 5926) and Ballard Partners (nos. 6415 and 7070)

Podesta Group, Inc.: registration 5926 dated 2009-04-01, terminated 2017-12-31, with 33 foreign principals on the foreign-principal list. Ballard Partners: registration 6415 dated 2017-04-05, terminated 2021-02-06, 12 foreign principals; registration 7070 dated 2022-01-13, active, 6 foreign principals listed active on 2026-11-10.

Source
U.S. Department of Justice, National Security Division, FARA Unit (efile.fara.gov)
Date
read 10 November 2026
Grade
Primary record
Document
https://efile.fara.gov/api/v1/Registrants/json/Terminated
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
API responses read; not stored. Terminated-list file sha256 1ba29d869f3039f5fc8e9f1aa1634a49e88cfc670846b695f4056b4731e1152d; Podesta principals file a1c8ce03fc3248cbc644aff4d26e11ad99750de678517651f16bc6858de65a20.

Exhibit 1293 · Company filing

MAGA Inc. (C00892471) Form 3X reports 2025 to April 2026: receipts from RAI Services Company, Altria Client Services and JUUL Labs

FEC-1978142 (May monthly, coverage 2026-04-01 to 2026-04-30, filed 2026-05-20) lists RAI SERVICES COMPANY, 401 N MAIN ST, WINSTON-SALEM NC, $5,000,000 dated 2026-04-30, Schedule A line 17, described "NON-CONTRIBUTION". All itemized April receipts total $9,585,145.60 including $585,145.60 bank interest. Earlier reports list RAI Services $1,000,000 on 2025-02-05, 2025-06-30 and 2025-12-29, Altria Client Services $1,000,000 on 2025-05-09 and JUUL Labs $1,000,000 on 2025-11-04.

Source
Federal Election Commission (electronic filings, docquery.fec.gov)
Date
2025-07-31 to 2026-05-20
Grade
Primary record
Document
https://docquery.fec.gov/cgi-bin/forms/C00892471/1978142/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Raw .fec files and sha256 in research/politics-2026-ballard/fec/ and research/politics-2026-ballard/fec-extracts.json. Filing ids FEC-1909741, 1930418 (amended 1930534), 1943509, 1978142; FEC-1978142 sha256 cad4bb8980bce617e80f0a200ece69e8c77498cb266bef7829a1d253db5e232f.

Exhibit 1294 · Company filing

MAHA PAC (C00821439) Form 3X reports, March and April 2026: receipts from Botanic Tonics LLC

FEC-1970348 and FEC-1978004 (amended by FEC-2004234 and FEC-2005797) list Botanic Tonics LLC $500,000 dated 2026-03-04 and $500,000 dated 2026-04-09 (aggregate $1,000,000), Schedule A line 17. No other receipt from that name appears in the committee's reports through the 2026-10-14 pre-general report.

Source
Federal Election Commission (electronic filings, docquery.fec.gov)
Date
2026-04-20 to 2026-06
Grade
Primary record
Document
https://docquery.fec.gov/cgi-bin/forms/C00821439/1978004/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Raw .fec files and sha256 in research/politics-2026-ballard/fec/ and research/politics-2026-ballard/fec-extracts.json.

Exhibit 1295 · Congressional letter

Letter, Senator Ron Wyden (Ranking Member, Senate Committee on Finance) to David Waterfield, Reynolds American

it appears that Reynolds American has successfully bribed the Trump Administration with a payment of five million dollars in exchange for a regulatory change that will greenlight the retail sale of flavored e-cigarettes and vaping devices across the country.

Six pages. Sets out a "reported chronology" (30 April donation of $5 million to MAGA, Inc.; 2 May lunch with Reynolds' general counsel and two Ballard Partners lobbyists; 8 May FDA directive; 12 May Makary resignation), sourced in footnotes to WSJ and New York Times reports, and opens an investigation. Asks six questions, including what was requested at the lunch, and two document requests, due 31 August 2026. Characterizes the sequence as bribery and "quid-pro-quo".

Source
U.S. Senate Committee on Finance, Democratic staff
Date
3 August 2026
Quoted from
p. 1, first paragraph
Grade
Primary record
Document
https://www.finance.senate.gov/imo/media/doc/20260803lettertoreynoldsamerican.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
sha256 1148f71b8e5b3bd6a7f6eb7c5447e4eaaaa081a136531a38a413d55bb1bf9db6. The quoted characterization is the Senator's, not a finding.

Exhibit 1296 · Congressional letter

Letter, Senator Ron Wyden to HHS Secretary Robert F. Kennedy, Jr.

both industries obtained the right to do so by paying millions to you and to President Trump.

Six pages. Repeats the Reynolds chronology, adds that Botanic Tonics donated $1 million to MAHA PAC and that its CEO donated $162,000 to the Secretary's presidential campaign, citing news reports, asks 14 questions and five document requests, due 31 August 2026.

Source
U.S. Senate Committee on Finance, Democratic staff
Date
3 August 2026
Quoted from
p. 1, first paragraph
Grade
Primary record
Document
https://www.finance.senate.gov/imo/media/doc/20260803lettertosecretarykennedy.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
sha256 289e9f251a67766102ee92b350163807f2ce75249742b50f37826c723319af6d. Characterization by the Senator.

Exhibit 1297 · Congressional letter

Letter, Senator Ron Wyden to Jerry Ross, Botanic Tonics

Six pages. States that a website banner reading "ANNOUNCEMENT: FDA reinforces safety of natural leaf kratom" ran until 1 July and misdescribed FDA's position, states a cabinet secretary holds a stake in the company, and asks 17 questions on contributions, meetings with officials and lobbying, due 31 August 2026.

Source
U.S. Senate Committee on Finance, Democratic staff
Date
3 August 2026
Grade
Primary record
Document
https://www.finance.senate.gov/imo/media/doc/20260803lettertobotanictonics.pdf
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
sha256 3ce38f1c52e3b32bdc3a124ed1e8ab02f3be12e3c27e400602d659fe2020201a. Kratom is outside the scope of this note.

Exhibit 1298 · Press release

Wyden Investigates Trump and RFK Jr. Corruption Favoring Big Tobacco and Kratom Companies

Announces the three letters and repeats the chronology as "the reported timeline"; sets a deadline of 31 August 2026. No response from Reynolds American, Botanic Tonics or HHS was found on the Committee's site as of 10 November 2026.

Source
U.S. Senate Committee on Finance
Date
5 August 2026
Grade
Primary record
Document
https://www.finance.senate.gov/ranking-members-news/wyden-investigates-trump-and-rfk-jr-corruption-favoring-big-tobacco-and-kratom-companies/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Page read in full by text extraction.

Exhibit 1299 · Federal Register notice

Enforcement Priorities for Certain New Tobacco Products Marketed Without Premarket Authorization; Guidance for Industry; Availability, 91 FR 25892

This guidance document describes certain enforcement policies with regard to the marketing of certain electronic nicotine delivery systems and oral nicotine pouch products that do not have premarket authorization.

Notice of availability of the final guidance, Docket No. FDA-2026-D-5083, Federal Register Volume 91, Number 91, pages 25892 to 25894, document 2026-09368. The notice announces the guidance; it does not open a comment period before issuance.

Source
U.S. Food and Drug Administration, HHS (Federal Register)
Date
12 May 2026
Quoted from
Summary, p. 25892
Grade
Primary record
Document
https://www.federalregister.gov/documents/2026/05/12/2026-09368/enforcement-priorities-for-certain-new-tobacco-products-marketed-without-premarket-authorization
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Full text sha256 a05ebb8da48f790d06e536e636efd034d9ecc43810389303bf79862bc90d231a.

Exhibit 1300 · Agency guidance

Flavored Electronic Nicotine Delivery Systems (ENDS) Premarket Applications: Considerations Related to Youth Risk (draft guidance)

Where the totality of evidence demonstrates comparatively lower youth initiation risk, FDA may consider a correspondingly lower magnitude of incremental adult benefit necessary to support an APPH determination relative to flavors with higher youth appeal.

Draft guidance, nonbinding, for comment. Sets a graduated, risk-proportionate evaluation of flavored ENDS applications and records that FDA has issued marketing granted orders for menthol-flavored ENDS.

Source
U.S. Food and Drug Administration, Center for Tobacco Products
Date
March 2026
Quoted from
p. 14, section III
Grade
Primary record
Document
https://www.fda.gov/media/191455/download
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
sha256 151e01579dd66a0a8cb66e6a2dcc71ce8ec08e9da85e95e95f5b8f90eaa6a10d. Federal Register notice and docket not retrieved.

Exhibit 1301 · Agency press release

FDA Expands Market Access, Authorizes New ENDS Products

FDA states it authorized four Glas ENDS pods (Classic Menthol, Fresh Menthol, Gold, Sapphire) under the premarket tobacco product pathway and describes it as its first authorization of non-tobacco and non-menthol ENDS.

Source
U.S. Food and Drug Administration
Date
5 May 2026
Grade
Primary record
Document
https://www.fda.gov/news-events/press-announcements/fda-expands-market-access-authorizes-new-ends-products
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read through a page summary, not word for word; no quote taken.

Exhibit 1302 · Agency letter

Marketing granted orders to Glas Inc., PM0004879.PD6 and PD8

We completed review of your PMTAs and are issuing marketing granted orders for the tobacco products identified in Appendix A.

Letter to Glas Inc. issuing marketing granted orders for the products in its Appendix A, with marketing restrictions in Appendix E. The orders' relation to the four pods in the 5 May release was not established.

Source
U.S. Food and Drug Administration, Center for Tobacco Products
Date
12 March 2026
Quoted from
p. 1
Grade
Primary record
Document
https://www.fda.gov/media/191541/download
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
sha256 67d9a5ffd763ea322f7b4314be23ddfcbe7bafcf483b1065d3de8c69409a4069. The text extraction carries a superscript footnote number after "PMTAs".

Exhibit 1303 · Agency web page

FDA leadership: Acting Commissioners (Kyle Diamantas, 15 May 2026 to present)

FDA lists Kyle Diamantas as Acting Commissioner of Food and Drugs from 15 May 2026. The page has no entry for Marty Makary. No HHS or FDA statement on Makary's departure was found.

Source
U.S. Food and Drug Administration
Date
read 10 November 2026
Grade
Primary record
Document
https://www.fda.gov/about-fda/fda-leadership-1907-today/acting-commissioners
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read through a page summary.

Exhibit 1304 · News report

FDA commissioner resigns after tumultuous tenure

Reports Makary's resignation on 12 May 2026; attributes the flavored-vape issue to an unnamed federal health official and records President Trump saying Makary "was having some difficulty" (wording from a page summary, unverified). Names Kyle Diamantas acting commissioner.

Source
Georgia Public Broadcasting (Sydney Lupkin)
Date
12 May 2026
Grade
Reported
Document
https://www.gpb.org/news/2026/05/12/fda-commissioner-resigns-after-tumultuous-tenure
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported. A primary document would be Makary's resignation letter or an HHS or White House statement.

Exhibit 1305 · News report

Susie Wiles' old lobbying firm made $186 million under Trump. Now it's caught in MAGA's feud.

Reports Ballard Partners' 2025 lobbying revenue as more than $88 million and its revenue through the third quarter of 2026 as more than $98 million, "a CBS News analysis of Senate lobbying disclosures"; reports Ballard and Wiles deny the allegations. The $186 million in the headline is not defined in the text.

Source
CBS News (Gabe Kaminsky)
Date
10 November 2026
Grade
Reported
Document
https://www.cbsnews.com/news/susie-wiles-ballard-partners-trump-maga-feud/
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Reported. Replaced by lda-2026-ballard-run: derived $88.06 million (2025) and $97.27 million (2026 Q1 to Q3).

Exhibit 1306 · Court filing

Monsanto Co. v. Durnell, No. 24-1068, docket

Docket entries: Solicitor General invited to file 2025-06-30; brief of the United States filed 2025-12-01; certiorari granted 2026-01-16; further United States amicus brief 2026-03-02; argued 2026-04-27; decided 2026-06-25.

Source
Supreme Court of the United States
Date
25 June 2025 to 25 June 2026
Grade
Primary record
Document
https://www.supremecourt.gov/search.aspx?filename=/docket/docketfiles/html/public/24-1068.html
Accessed
2026-11-10
Cited by
Findings citing this exhibit
Note
Read through a page summary.