UNITED STATES OF AMERICA v. BOLTON

Filing 1

COMPLAINT against JOHN R. BOLTON (Fee Status:Filing Fee Waived) filed by UNITED STATES OF AMERICA. (Attachments: #1 Exhibit A (Security Agmts.), #2 Exhibit B (Memo. of 9/13/2019), #3 Exhibit C (Letter of 9/10/2019), #4 Exhibit D (Letter of 12/30/2019), #5 Exhibit E (Letter of 1/23/2020), #6 Exhibit F (NY Times Article of 1/26/2020), #7 Exhibit G (Wash. Post Article of 1/27/2020), #8 Exhibit H (Letter of 2/7/2020), #9 Exhibit I (Letter of 2/24/2020), #10 Exhibit J (CNN Article of 3/3/2020), #11 Exhibit K (Email of 3/27/2020), #12 Exhibit L (Politico Article of 4/29/2020), #13 Exhibit M (Email of 5/7/2020), #14 Exhibit N (Wash. Post Article of 6/7/2020), #15 Exhibit O (Letter of 6/8/2020), #16 Exhibit P (Letter of 6/10/2020), #17 Exhibit Q (Letter of 6/11/2020), #18 Civil Cover Sheet, #19 Summons)(Van Horn, Daniel)

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Case 1:20-cv-01580 Document 1-1 Filed 06/16/20 Page 1 of 7 Exhibit A ____ Case 1:20-cv-01580 Document 1-1 Filed 06/16/20 Page 2 of 7 CLASSIFIED iNFORMATION NONDISCLOSURE-AGREEMENT — AN AGREEMENT BETWEEN John Robed Bolton AND THE UNITED.STATES (Name of IrsrfMdual Printed or typed) I Intending to- be legally bound I hereby accept the obligations contained in this eernen-ironsideiation of my being granted access to dassifled information As used in this Agreement, dassifled information is made[cr unmarked dassifled infornatjon mddlng oral comrnunftatlons that is classified under the standards of Executive Order l3526ocunder any other Executive order or statute that p ohtIts the unauthorized disclosure of information in the nteresf of nationá arid unclassified infomiation that meesthestandardsfordasstionandle1ntheproceesofacflcatondeteaborovidedpnsectionsf1 I 2,l3and 1 4(e) of Execufive Order 13526 or under any other Executive order or statute that requTpection icr such Information in the interest of naIiànal security I understand and accept that by being granted access f dflT’1fomtaticn special contidence arid frust all be placed In me-bythe.United States Government: - 2. I hereby acknowledge that I have received a security indoctrination concerning the nature ancLprotection of classified Inforniation, induding the procedutes to be foIlod in ascertaining whether other persons to whom I contempLate disclosing this information have been approved for access to it, and thlI understand these procedures. 3.1 have, been advised that the unauthorized .disosure, unauthorized reten on, or negligent handling of classified information by me could cause damage or irreparable mjury to the United States or cored be used to advantage by a foreign nation I hereby agree that I wfll never.divulge classified Inform ationtà anyone unless: (a) I have officially verified thatthé recipient has been property uthôrized by the United States Government to receive it, or (b) I have been given prior written notice of authorization from the United States Government Department or Agency (hereinafter Department or Agency) responsible for the classification of information or last granting me a security clearance that such disclosure is psmiitted understand thai Lf I am uncertain about the classification status of information I am required to confirm from an authorized official that the informaflon is unclassified before I may disclose it except to a person as provided in (a) or (b) above I further understand that I am obligated to compty with laws and regulations that prohibit the unauthorized disclosure of classified information — 4 I have been advised That any breach of this Agreement may result ri the termination of any security clearances I hold removal from any position of special confidence and trust requiring such clearances ortermiriation of my employment or other relationships with the Departments or Agencies that granted my security clearance or clearances In addition I have been advised that any unauthorized disclosure of classified information by me may constitute a violation or violations of United States criminal laws including the provisionsof sections 641, 793, 794, 798, ‘952 and 1924, title 18, United States Cede; ‘the provisions of section 783(b), title 50, United States Code and the provisions of the Intelligence Identities Protection Act of 1982 I recognize that nothirig in this Agreement constitut a walver by the United States of the iight to prosecUte me for any-statutory violation. 5. 1 herebyassign to the United States Government all royalties, remunerations, arid emolumentsthat have res(itted, will result or may result from any disclosure, Publication, or revelation of classified information riotóônsisteht with the terms of this Agreement 6. I understand that the United States Government may seek any remedyavaIable to it to enfor ethis Agreement including, but not limited to1 application for acourtorder prohibiting disclosure of information in breach of this Agreement. 7 I understand that afl classified information to Which I have access or may obtain access by signing this Agreement Is now arid will remain the property of or under the control of the United States Government unless and until otherwise determined by an authorized official or final wfing of a court of law I agree that I shall return all classified materials which have or may come Into my possession or for which I sin responsible because of such access (a) upon demand by an authonzjpresentative of the United States Government (b upon the conclusion of my employment or other relationship with the De rii or Agency that last granted me a security clearance or-that provided me access to classified information or (c) upn tlie conclusion of my employment or other relationship that req,urres access to classified information If I do not return such materials upon raiest, 1 understand that this may be a violation ofsecticnslø3 anidlor1924, title 18, United States Code, a United States crtrnlnáI1aw.--- 8 Unless end untiii released in writing by an authorized representative of tije U1t Government I understand that all conditions and óbllällons imposed upon me by this Agreement apply dunng the te I aib granted access to classified information, and at all time&theröér, - 9 Each p Stoi’ofHI,s Agreement is severable tta court should find any provslanifthA.jiuont to be unenforceable all other provisions ofihhLAgteementshall remain iii fufi force arid effect. 10. These provi&ons are consistent with and do not supersede, conflict with, ortherwise-atterthe employee obllgations,.nights, or liabilities created by existing statute or Bxecutive order relating to (1) classified information (2) communications to Congress (3) the reporting to an Inspector General of a violation of any law rule or regulation or rritsmanagement,-a gross waste of funds, an abuse of authority or a substantial and specific danger to public health or safety or (4) any other whistleblower protection The definitions requiremen obligations nghts sanctions and riabrties created by controlling Executive orders and statutory provisions are incorpatedintothiaagreeñ,ent arid are cbntioIflng. - NSN 7540-Oi-Z5O-5459 preouaeItIiiotusbie. (Continue tin reverse.) STANDARD FOR14312 ,7-2O1l _rrPrHc1bedbyPOl 2CrRPART 2001.80 E.O. t3526 Case 1:20-cv-01580 Document 1-1 Filed 06/16/20 Page 3 of 7 Ii. These restrictions are orisistent With and do not supersede, conflict with, or therwlae afl the mployee obhgations, rights, or liabilities cieated by Executive OrderNo. 13526 (75 Fed. Reg. 707), or any successor thereto sectlon 7211 of title5, United States Code (governing disclosures to Congress) section 1034 of tTtle 10 United States Code as amended by the Military ViThIst)eblower ProtectionAct (governing disclosure to Congress ty members of the mItary); section 2302 )(ofUUe 5, tJn led States Code, as healti’i or amended by the Whistieblower Protection Act of 1989 (governIng disclosures of lUegaty waste fraud abuse or pUbflc disdowres that coU’d expose safety Ifireato): the lnte$fgence Identifies Protection Act of 1982 (50 U.SC. 421 et seq.) and SM the Inspector General Act of 1978{&U.SC App) (relating to disdosures confidential Government agents) sections [ti3H(g)(3) of the National Security an inspector general. the Wispectors general of the lnteThgence Community and Congress), s (relating to dieclisuresto thS inspector general of the IntelUgnce Comrnunit); sectioris 17(d)(5) Act of 1947 (50 U.S.C. 403-3h(gX3) and 17(e)(3) of the Central lntefllgence Agency Act of 194 (50 U $ C 403g(d)(5) and 40qJ3)) (relating to disclosures to the Inspector General of the Central Intelligence Agency and Congress) nd the statutes which protect against disclosure that may compromiseThe national security, including sections 641, 793, 794, 798, *952and 1924of tItle 18, United States Code, and,*section 4 obUgations rights (la) of the Subversive Activities Control At of 1950 (50 U S C section 763(b)) The definitions are incorporated into this agreement and are controlling sanctions, and rbhties created by said Executive Order and listed (governing to of 7(c) requirements statutes That the briellng oflloer has hdve read this Agreement carefully and my questlons, if any, have been answered. I acknowledge and its implementing regulation (32 CFR Part made available to me the Executive Order and statutes referenced in this agreement if I so choose. 2001 section 2001 8(d)(2) ) so that I may read themat this 12. ‘ NOT P,PPLICP,BLETO NON-GOVERNMENT PEfSONNEL SIGNING ThIS AGREEMENT. soclAksacultrry NUMBER (Se8 Nolice bciai) DATE SIGNATURE G410512018 ORGANIZATION (iF COIrrR OR LICENSEE. GIANTEE OR AGEI4T PRCMDE NAME. ADDRESS AND IF A 6t.E1DERAL SuPPLY COO! NUMBER) fTj,eopjftijJ EOPJWHO I WiTNESS HE EXECUTiON OF THiS AGREEMENT WAS WITNESSED BY THE UNDERSIGNED. DATE SIGNATURE ACCEPTANCE THE UNDERSIGNED:ACCEPTED THISAOREMENT ON BEHALF OF ThE UNED STATE GOVERNMENTS DATE SIGNATURE 04105/2018 NAME AND ADDRESS (Type ocp,iht) 0410512018 NP’MEANL3ADDRESS (Type or1atnt) Carl 1. Kline 7Z5l7thSfreet,NW Carl L. Kline 725l7thStreet,NW Washington, DC 20503 V Washington, DC 20503 -. V SECURITY DEBRIEFING ACKNOWLEDGEMENTappcable to the safeguarding of classWeø I reaffirm that the pro’tIsions, of the espionage lai, other federal crininal Ia and have been made available to me that I have returned ati olassi5ed information wi my custody that I wfll an the FedESiau of Investigation classified information to any unauthorized person or orgarzat1on that I wI promptly unsuthotherl to soUcit dassfied information and that I (have) (have not) (strike out inappropriate word orwords) receIved a security debriefing executive orders not commurNoate or transmit iforrnaUon report any to attempt by person - S1GNA’WRE OEEMPL-OYEE NAMEOFVWTNESS NOTICE: The Erivacy V eorrfnt Act, U.S.C. 52a requft SiNA19JREOFVijTNESb that federal agencies infon individuals, at the urre Intormnauon Is solicited Tram them, whether the disclosure is mandatory or volimlary, by w atauthority such infomiatlon Is sotcited, andwlIat uses wifl be niade of The infvrmaon. You are herlfby advised that authoMy foi soliciting your Soaal Security Number (SSN) is PubSo Law 104-134 (Apr11 245).Your SSN wSl be used to identify you necesy to ceulify that you have access to the information indicated above or to determine that your access to the a,foniiation indicated has L’een minafed Furnishing your Social Security Number as well as other data is voluntanj but failure to do so may delay or prevent you V being granted access to classified information. STANDARD FORM 512 BACK (Rev. 7-201) Case 1:20-cv-01580 Document 1-1 Filed 06/16/20 Page 4 of 7 Case 1:20-cv-01580 Document 1-1 Filed 06/16/20 Page 5 of 7 Case 1:20-cv-01580 Document 1-1 Filed 06/16/20 Page 6 of 7 Case 1:20-cv-01580 Document 1-1 Filed 06/16/20 Page 7 of 7

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