BK NOTES: This is a White House link to Biden's June 30, 2023 Memorandum on Certifications Regarding Disclosure of Information in Certain Records Related to the Assassination of President John F. Kennedy, that Amdrew Iler and Mark Adamczyk review in their analysis.
This is a really good legal analysis of President Biden's false "final certification" of the JFK Act of 1992 and why it isn't "final" until the JFK Act is completed as Congress wrote and approved the law. Thanks to Jimmy diEugenio for posting this at his web site Kennedys and King and we look forward to Mark Adamczyk's analysis of the Judge's ruling in the MFF v. Biden and NASA case that is still active in court.
Friday, 21 July 2023
The Biden/CIA Attempt to Usurp Congress’ Authority
Over JFK Records
Written by Andrew Iler and Mark Adamczyk
Two lawyers expert on the JFK Act show us how
President Biden and the CIA have plotted to alter and negate both the spirit
and the letter of the law. You will not find a better essay on this subject
than this one. Only people who have studied the act in depth could show us in
detail how it has been neutered.
The Friday Night News Dump
In the waning hours of the evening of Friday, June
30, 2023, long after the filing deadlines of the media elite in Washington D.C.
and even longer after the most dedicated talking head had left to celebrate
their July 4th independence from tyranny in the Hamptons, the Biden
Administration issued an Executive Memorandum that is a flagrant and
illegitimate attempt to terminate an Act of Congress and usurp congressional
authority over its own processes and records. A copy of President Biden’s
Executive Memorandum is here.
It is unclear what truly prompted President Biden to
take a flamethrower to an Act of Congress that he himself voted for in 1992 as
a member of the Senate, due to bipartisan public pressure to release records
related to the 1963 assassination of President John F. Kennedy. It is further
perplexing that Biden has chosen to continue to deny the American public
transparency into the death of a much admired predecessor since he has chosen
to surround himself in the White House with artwork memorializing the Kennedys
e.g. the bust of Robert F. Kennedy in the Oval Office and the famous portrait
of JFK by Jamie Wyeth that President Biden specifically requested to be
borrowed from the Museum of Fine Arts in Boston to hang in his private White
House study.
What exactly is in Biden’s Executive Memorandum that
is so egregious? Well, it would help to briefly go back to the 1990s, when Joe
Biden was a U.S. Senator from Delaware and the Chair of the Senate Judiciary
Committee.
As a result of decades of significant controversy
caused by the government withholding millions of pages of records related to
the 1963 assassination of President Kennedy from the American public, Congress
enacted the John F. Kennedy Assassination Records Collection Act of 1992 (JFK
Records Act”). Congress was put under substantial public pressure to do
something about the continuing secrecy around records related to Kennedy’s
assassination, because 30 years after his murder, executive agencies were
holding hundreds of thousands of assassination related files secret, based on
unsubstantiated claims of “national security”. Freedom of Information Act
requests were ineffective at penetrating a completely unaccountable lock that
the U.S. security state had on these then 30-year-old records. Public outcry
after Oliver Stone’s Oscar winning film JFK tipped the balance. So
Congress passed the JFK Records Act in a rare, unanimous bi-partisan vote. The
act was signed into law by the then President George H.W. Bush, and after
numerous delays finally went into effect in 1994.
The full John F. Kennedy Assassination Records
Collection Act of 1992 can be found here.
It is worth reading.
The law mandates, among other things, that by no
later than October 26, 2017, all records related to the 1963
assassination of President John F. Kennedy had to be publicly disclosed in full,
unless for each record, the President certified that extremely
stringent criteria for postponement were met. If such postponement criteria
were satisfied based on the legal standard of clear and convincing evidence,
the President’s unclassified reasons for postponing each individual record had
to be published in the Federal Register. This way the public could at least
understand exactly which specific records were being postponed and what the
legal basis was for the postponement of each individual assassination record.
It needs to be noted that in accordance with the
provisions of both the JFK Records Act (particularly section 9(d)(1)) and the
Constitution’s separation of powers, that the President’s authority to postpone
the public disclosure of assassination records only applies to Executive Branch
records (which are records created by agencies and offices controlled by the
President e.g. CIA, FBI, Secret Service, DEA, NSA, DOD, etc…). The President
does not have legal authority over “non-executive branch records”, which
include records created by Congress and other sources not controlled by the
executive branch. Congress was very careful when drafting the JFK Records Act
to ensure that they did not grant the President authority to control their
legislative branch records.
Congress also required that for each assassination
record, that all “Government Offices” (the JFK Records Act specifically
includes the Executive Office of the President in the definition of “Government
Office”) had to issue what is called an “Identification Aid” when any action
was taken or decision made in respect to any record. These Identification Aids
were tracking forms that attached to all assassination records and recorded a
brief description of the record, including the date of the document, the
originating agency or entity, the disposition of the record and any action
taken with respect to the record, such as the particular section 6 criteria for
postponement that provided the legal justification for continuing to hold the
assassination record in secret from the public.
Further, Congress specifically mandated the
Archivist of the United States to ensure that all Identification Aids for every
postponed record form part of the Assassination Records Collection. Also, that
a publicly accessible Directory of Identification Aids be created and
maintained, so that there was full transparency for the public to understand
exactly which assassination records were continuing to be held in secret in
the Protected Collection and what the legal basis for postponement
was under section 6 of the JFK Records Act for each record.
Most importantly, Congress made it clear in the JFK
Records Act that there was a “presumption of disclosure” and the legal burden
was on an agency to prove that a specific assassination record met the legal
standard for postponement required by the Act and that clear and convincing
demonstrable evidence was required in order to deprive the public access to a
record.
In order to ensure that government agencies and
offices complied with the JFK Records Act, Congress created the Assassination
Records Review Board (“ARRB”). This 5 person citizens’ panel was tasked with
collecting, cataloging and reviewing all assassination records, with the
mandate to release all assassination records, unless a record met the exacting
criteria set out in section 6 of the Act.
The ARRB’s limited tenure ran from October 1, 1994 to
September 30, 1998.During the ARRB’s time in operation, the Board and staff
reviewed and made “final determinations” about every single assassination
record that was identified and submitted by government agencies and offices. In
the mid-1990s when the ARRB was doing its work, the JFK Records Act mandated
that only in the most rare and exceptional circumstances were assassination
records to be postponed from public disclosure.
The law also legally mandated that, based on “final
determinations” and recommendations for release made by the ARRB, all postponed
records had to be periodically reviewed under the same stringent and
exacting standards of section 6 of the Act. The purpose of the Periodic Review
process was to “downgrade and declassify” all of the records held
secret in the Protected Collection. By legally mandating this downgrading and
declassification periodic review process, the JFK Records Act makes it clear
that as time passes it should become more difficult, not easier for
executive agencies to keep assassination records secret and to deny the
American people access all the facts about the circumstances surrounding
President Kennedy’s murder.
ARRB “Final Determinations” and the Periodic Review
Process
Every assassination record currently held in the
secret Protected Collection is held as a result of an ARRB “final
determination”. As the ARRB went about its business between October 1994 and
September 1998, it created a form called the “ARRB Final Determination Form”.
These forms are not widely published and not a lot of attention has been placed
on them by anyone in the research community.
In every case where the ARRB made a Final
Determination to postpone the release of an assassination record, they filled
out one of these Final Determination Forms. These included the specific section
6 criteria which formed the legal basis on which a record was legally permitted
to continue to be held in secret. The Final Determination Form also provided
unclassified written reasons for each postponed record, along with the ARRB’s
recommendation for releasing the record (i.e. a covert agent’s death, or a
source or method no longer requiring protection).
“Final Determination Forms” are critically
important.
Judge John Tunheim, the Chair of the ARRB has
confirmed that all postponement decisions made by the ARRB are “Final
Determinations” under the Act.
The work with respect to all of the records
currently held in the Protected Collection at NARA has been completed for over
25 years. The ARRB did its job. The result is a catalog of Final Determination
Forms that state the section 6 criteria for postponement and the ARRB’s
recommended release date for each assassination record, based on the section 6
criteria.
A serious problem that occurred from September 1998
until October 26, 2017, is that virtually no Periodic Review took place in
accordance with sections 5 and 9 of the JFK Records Act. The Periodic Review
was supposed to happen based on the information and recommendations that the
ARRB recorded on their ARRB Final Determination Forms for each postponed
record.
The mandated purposes of Periodic Review were to
provide a rolling review of the postponed assassination records in accordance
with the criteria and recommendations issued by the ARRB in their ARRB Final
Determination Forms. If this had occurred as Congress mandated in the JFK Act,
by October 26, 2017, there should have been only a very small number of records
still held in the Protected Collection when the October 26, 2017 deadline came
up.
Again, according to the Law, it’s legislative
history, and legal commentary, by the time the October 26, 2017 statutory
deadline rolled around, based on the statute’s mandated program of Periodic
Review, there should have been virtually no records left in the “Protected
Collection” held at the National Archives. Because the clear purposes of the
Act were to create an accountable, transparent and enforceable process to downgrade,
declassify and ultimately fully disclose every single assassination record
to the public, so that the public itself could decide for itself what the facts
were about what happened in Dallas on November 22, 1963.
In reality, despite the law’s clear mandate, when
October 26, 2017 did come and go, there were still an undetermined number of
assassination records being either fully or partially withheld. By some
estimates, the number of withheld records totalled was quite voluminous. But an
accurate number was impossible to calculate because of the broken down and
functionally inoperable Identification Aid Program that NARA and the agencies
have failed to adequately maintain pursuant to their legal mandate.
President Biden’s Friday Night Memorandum
Now back to President Biden’s June 30, 2023
Executive Memorandum that postponed an undetermined number of unidentified
assassination records. Let that sink in for a moment…
“Maximum Transparency”
Despite the clear mandates imposed by the JFK
Records Act to establish an “accountable” and “enforceable” process for the
full disclosure of all assassination records; and the explicit requirement that
each record be accounted for with an identification aid, the President’s June
30, 2023 Memorandum does not identify or account for a single assassination
record.
President Biden stated in the opening paragraph of
his memorandum that, “As I have reiterated throughout my Presidency, I fully
support the Act’s aim to maximize transparency by disclosing all information in
records concerning the assassination, except when the strongest possible
reasons counsel otherwise.” There is an unavoidable divergence from reality in
the President’s statement, that is Orwellian in magnitude. For the simple
reason that without being able to track which assassination records were
postponed from disclosure through the mandated identification aid program, and
without providing the legally required reasons for each postponement, on a
record-by-record basis (“as required by the Act”), where is the “transparency”
and “accountability”?
When the ARRB issued final determinations on a
record-by-record basis in the mid-1990s, only the President could override such
final determinations pursuant to his authority under section 9(d)(1) of the
Act. In respect to any Presidential determination to postpone or release a
record under his 9(d)(1) authority, the President was mandated by law to:
a. apply
the standard of proof and postponement criteria required by section 6 of the
Act;
b. Provide
unclassified reasons for the postponement based on the section 6 standard of
proof and postponement criteria;
c. Have
the reasons for the postponement published in the Federal Register; and
d. Issue
an identification aid for each postponed assassination record.
The above duties, mandated to the President are what
are called statutory or “ministerial duties”. The President does not have any
wiggle room or discretion with respect to these mandated ministerial duties. If
a President does not comply with ministerial duties, the resulting decisions
may be reviewed by the courts on an application for judicial review or
mandamus. While suing the President is not made easy, there are very narrow
pathways that can be found to ensure that a President complies with the law. In
the case of the JFK Records Act, these pathways require a refined parsing of
the language of the Act to determine what specifically Congress required for a
President or other specifically named officials to do.
Neither President Trump nor President Biden complied
with any of the above ministerial duties imposed on them by section 9(d)(1) of
the JFK Records Act. They did not apply the standard of proof in section 6 to
any postponement. They did not apply the postponement criteria; they did not
provide any unclassified reasons for postponement for each record, so that the
public could understand the rationale for any of the postponements. They did
not issue any identification aids for each postponed record. And there is no
way for the public to understand which records the postponements apply to,
because there was not even a list of the postponed records published in the Federal
Register as is required under the Act.
All of these violations of the JFK Records Act, make
it difficult or impossible for the public to seek any accountability or
transparency in respect to the President’s decision-making. Further any
attempt to seek judicial review of any specific postponed record will be
extremely difficult, because no reasons were given for the postponement of any
particular record. One of the requisite elements of any final decision or order
under the principles of administrative law is that adequate or sufficient
reasons be provided to justify a decision, so that any impacted party would
understand the basis for the decision, and so that aggrieved parties would be
able to fairly appeal such decisions. These basic legal principles form part of
the foundations of our system of law and prevent “Star Chamber” justice and
abuses of authority.
The Clear and Convincing Standard of Proof
Another serious legal problem arising from President
Biden’s opening platitudes is his attempt to modify by edict the legal
standards for postponement that are the basis of the JFK Records Act. Nowhere
in the JFK Records Act do the words “except when the strongest possible reasons
counsel otherwise.”
The standards and criteria for postponement are only
found in section 6 of the JFK Act.
SEC. 6. GROUNDS FOR POSTPONEMENT OF PUBLIC DISCLOSURE OF RECORDS - 44 USC 2107
Disclosure of assassination records or particular information in assassination records to the public may be postponed subject to the limitations of this Act if there is clear and convincing evidence that -
(1) The threat to the military defense, intelligence operations, or conduct of foreign relations of the United States posed by the public disclosure of the assassination is of such gravity that it outweighs the public interest, and such public disclosure would reveal -
(A) an intelligence agent whose identity currently requires protection.......
In legal processes there are several different
standards of proof. In most criminal proceedings, the standard of proof is the
well-known “beyond a reasonable doubt”. Civil standards of proof may vary
depending on the seriousness of the process and the range of potential
consequences of a ruling. Common civil standards of proof include “balance of
probabilities”, “preponderance of evidence”, and “clear and convincing
evidence”. When a statute imposes a standard of proof, that is the standard
that parties must meet in order to successfully make their case.
Parties cannot simply ignore or change a statutory
standard of proof in order to better suit their case.
Congress decided when they enacted the JFK Records
Act that the law would impose the relatively high civil standard of proof of
“clear and convincing evidence”. There is no other standard of proof when it
comes to assessing the grounds for postponing assassination records. All
government offices, agencies and the President of the United States must
follow the law and comply with the clear and convincing standard of proof
mandated by sections 6 and 9(d)(1) of the JFK Records Act.
To be certain, “Except when the strongest possible
reasons counsel otherwise.” is not the standard of proof imposed by the JFK
Records Act. In fact…“Except when the strongest possible reasons counsel
otherwise.” is not a standard of proof anywhere in the world.
Final Certification???
The opening paragraph of President Biden’s
Memorandum presents another perplexing statement and completely non-compliant
decision by the President. “With my final certification made in this
memorandum -– the last required under the Act -– and definitive plans
for future disclosures, my Administration is fulfilling the promise of
transparency to the American people.” [Emphasis added.] From this statement,
one can be left with no other understanding: that with his June 30, 2023
Executive Memorandum, the government and the President’s legal obligations
under the JFK Records Act have been fulfilled and that the June 30, 2023
Memorandum will be the final and last word on the undetermined number of
unidentified assassination records being held in secret by the government.
The problem with this statement is that it runs
smack into section 12(b) of the Act. That section of the JFK Act is titled,
“Termination of Effect of Act”. Part (a) of the section deals with the
termination of sections of the Act pertaining to appointments to the ARRB and
the operation of the Board. Pursuant to section 12(a), all of the sections of
the Act that cover matters dealing with appointments to and operations of the
ARRB shall terminate when the ARRB’s mandate ended on September 30, 1998.
In respect to the sections of the Act that do not
deal with appointments to or the operations of the ARRB, all those sections
remain in full force and effect until every last assassination record is fully
publicly disclosed to the public and the National Archivist certifies that all
assassination records are publicly available. Section 12(b) is set out
immediately below.
Section 6 of the Act does not pertain to
appointments to the ARRB and it does not deal with any ARRB operations. In
fact, section 6 of the Act does not even mention the ARRB at all. Section 6 is
a part of the Act that is mandated to form the basis of any and all decisions
to postpone the disclosure of an assassination record by any and all government
offices (including the Executive Office of the President of the United States).
Section 12(b) legally mandates that section 6 remains in full force and effect
as operational law and is applicable to the President’s authority to postpone
disclosure of records, “as required by this Act” pursuant to sections
5(g)(2)(D) and 9(d)(1).
The JFK Records Act makes no mention or suggestion
that the President’s legal duties under the Act come to an end prior to the
full public release of every single assassination record. To the contrary, both
sections 12(b) and 9(d) make it clear that the President’s duties continue
until there are no more secret assassination records held in the Protected
Collection at NARA.
Further, pursuant to sections 5 and 9 of the Act,
the President has an ongoing statutory role in the periodic review process.
Section 5(g)(2)(D) of the Act, is the provision that contains the purported
authority pursuant to which both Presidents Trump and Biden have postponed the
release of the remaining secret assassination records. It cannot be ignored
that the title of section 5(g) of the Act is, “PERIODIC REVIEW OF POSTPONED
ASSASSINATION RECORDS”.
Section 9(d)(1) of the Act also specifically weighs
in on the President’s ongoing ministerial dutieswith respect to
postponement of assassination records. That section mandates that, after the
ARRB has made a “final determination”, regarding the release or postponement of
an assassination record, only the President has the sole and non-delegable
authority to release or postpone the release of assassination records under
the standards of section 6 of the Act. There will be more about section 9(d)(1)
later in this article.
It is therefore unclear what the legal basis is for
President Biden’s dismissive assertion that the June 30, 2023 Memorandum is the
“final certification” required by the Act. This makes no sense given the clear
duties imposed by sections 5, 6, 9 and 12, as discussed above.
“Each Assassination Record…As Required By This Act”
In section 2 of the June 30, 2023 Executive
Memorandum, President Biden states that, “The Act permits the continued
postponement of public disclosure of information in records concerning
President Kennedy’s assassination only when postponement remains necessary to
protect against an identifiable harm to the military defense, intelligence
operations, law enforcement, or the conduct of foreign relations that is of
such gravity that it outweighs the public interest in disclosure.”
It would appear that the process suggested above in
the President’s Memorandum directly conflicts with the President’s claims that
he supports the transparency and accountability provisions of the Act. Does the
JFK Records Act actually authorize the President to certify the postponement of
thousands of unidentified assassination records en masse and without
providing any reasons for each record that he certifies for postponement?
The President’s Memorandum seems to cherry-pick
words and phrases out of section 5(g)(2)(D), and omits some critically
important language from the section. The omissions drastically change the
meaning and purposes of this section as purported by the President in his
Memorandum. Let’s look at exactly what section 5(g)(2)(D) states.
5(g)(2)(D) Each assassination record shall
be publicly disclosed in full, and available in the Collection no later than
the date that is 25 years after the date of enactment of this Act, unless the
President certifies, as required by this Act, that—
i. continued
postponement is made necessary by an identifiable harm to the military defense,
intelligence operations, law enforcement, or conduct of foreign relations; and
ii. the
identifiable harm is of such gravity that it outweighs the public interest in
disclosure.
The words “Each” and “as required by this Act”, seem
to be omitted from any reference to section 5(g)(2)(D) of the JFK Records Act
made by the government. Including in all of the Presidential Memoranda of both
President’s Trump and Biden. It seems that the government is afraid to fully
quote section 5(g)(2)(D) in its complete entirety. And the government is
particularly frightened by the words “each” and “as required by this
Act”,
The rules of statutory interpretation impress on
lawyers and judges that words printed into laws must be given meaning; and that
legislators do not insert meaningless or superfluous words into statutes.
So what do the words “each” and “as required by this
Act” mean in relation to the President’s authority to postpone the public
disclosure of assassination records? The answer to this question could consume
the better part of a chapter in a book or an entire lawsuit. I will try to
provide a brief explanation of the proper interpretation of these words in the
context of section 5(g)(2)(D) and in relation to the JFK Records Act as a
whole.
When the word “each” is used at the beginning of
section 5(g)(2)(D), the rules of statutory interpretation would strongly imply
that the word modifies the following parts of the whole section. It follows
that a proper reading of this section would reasonably determine that the word
“each” acts to modify both the requirement for public disclosure of each assassination
record by no later than the statutory deadline of October 26, 2017; and “each”
modifies the alternative requirement for the certification for postponement
of each assassination record, as required by this Act. This
interpretation would militate against a holus bolus en masse certification
of an undetermined number of unidentified assassination records. This
interpretation is further supported by the purposes of the Act, as well as all
of the other sections dealing with periodic review and Presidential authority
to postpone records. It would create an absurdity of law to interpret
section 5(g)(2)(D) to mean that prior to October 26, 2017, there were more
stringent postponement criteria and public transparency requirements under the
Act than after October 26, 2017.
The words “as required by this Act” must also be
given meaning in the context of the President’s authority to certify the
postponement of assassination records. If Congress intended that section
5(g)(2)(D) be an isolated, stand-alone provision and the only provision dealing
with Presidential postponements, Congress would not have included the
additional words, “as required by this Act” in Section 5(g)(2)(D). The
inclusion of the words “as required by this Act” must therefore be read
consistently and in line with the other sections of the JFK Records Act that
pertain to the postponement of assassination records. Namely section 6 (which
mandates the standard of proof and the exclusive postponement criteria) and
with section 9(d)(1). That is the authorizing provision that grants the
President his sole and non-delegable authority under the law to postpone the
release of Executive Branch assassination records after the ARRB has rendered a
final determination about an assassination record.
Instead of addressing the words “each” and “as
required by this Act”, President Biden’s Memorandum summarily omits these words
and ignores the statutory/ministerial duties that the words legally impose on
the President in respect to decisions to continue the postponement of public
disclosure of the secret assassination records held in the Protected
Collection.
“Transparency Plans”
Let’s be blunt. The President’s “Transparency
Plans”—originated by the CIA-- are the opposite of transparent. They might as
well be called “Opacity Plans” if the truth is being told. The JFK Records Act
is one big statutory transparency plan that mandates tracking forms
(identification aids) and a directory of these aids to provide transparency for
each and every document in the Records Collection, including those documents
that are continuing to be held in the secret Protected Collection. President
Biden’s Transparency Plan seeks to do away with the Identification Aid Program
and the publicly accessible Directory of Identification Aids.
Section 6 of the Act mandates that all government
offices apply the clear and convincing standard of proof and the five exclusive
criteria pursuant to which postponements are permitted by law. Section 12(b)
states that section 6 of the Act remains in full force and effect until the
Archivist certifies that every single last assassination record is fully
publicly disclosed. The President’s Memorandum seeks to do away with all
of these truly transparency driven standards, and replace them by edict with
new, less onerous, less stringent, less accountable, and totally unenforceable
standards.
What happened to the mandate to downgrade and
declassify all of the records? How and why did it suddenly become easier
for the government to keep these assassination records secret…. not more
difficult?
President Biden’s Attempt to Seize Authority Over
Congressional Records
One aspect of both President Trump and President
Biden’s multiple memoranda that ought to have received far more resistance from
both the public and Congress, is the Presidents’ assertions of authority over
what are termed “non-executive branch records”. These records include House and
Senate records, largely originating from the House Select Committee on
Assassinations and the senate’s Church Committee. As briefly discussed above,
Congress was very careful in drafting the JFK Records Act not to cede any
authority over non-executive branch records to the President. Section 9(d)(1)
takes particular aim at this issue by explicitly limiting the President’s authority
over only executive branch records.
What impact does this have on the current state of the records held secret in the Protected Collection? It means that any Presidential postponement of a non-executive branch record is unlawful and that by law, every single record that originated from the HSCA and the Church Committee should have been fully publicly disclosed on October 26, 2017. This did not happen because both President Trump and President Biden broke the law when they authorized those records to remain held in secret. Congress should have stepped in to protect their authority over their own records and processes, but to date, Congress has failed to schedule any oversight hearing or call any official to account for the undeniable non-compliance under the Act by NARA, the agencies and the Executive Office of the President.
It seems that
no branch of the government is interested in complying with the JFK Records Act
on any level, in any meaningful way. Senate Majority Leader Chuck Schumer did
however mention the JFK Assassination Records Act last week when he suggested
that Congress ought to use the that act as a model for new legislation to
provide public transparency on the urgent and pressing issue of UFO sightings!!
Is our government trolling us?
As this article goes to print, Judge Seeborg has
just issued a decision in the case brought by the Mary Ferrell Organization in
San Francisco court. An update on this important decision will be forthcoming
next week.
Andrew A. Iler is a Canadian lawyer based in
Ontario. Andrew’s practice focuses on corporate, commercial and administrative
law.
Mark E. Adamczyk is an attorney from Naples, Florida.
Mark is a graduate of Tulane University and Florida State University College of
Law. For the past 20 years, Mark has been studying the JFK assassination
and related United States history. Mark's recent focus has been the JFK
Records Collection Act, the federal law that guarantees the public disclosure
of the history surrounding the JFK assassination. Mark is dedicated to
ensuring that the U.S. Government complies with its remaining obligations under
the JFK Records Collections Act.
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