Audit
FBI clearances — 25 September 2024
On this page6 sections
Frame
On 25 September 2024, the House Select Subcommittee on the Weaponization of the Federal Government, under the Committee on the Judiciary, held a hearing titled Hearing on the Weaponization of the Federal Government.1 Chairman Jim Jordan's 23 September invitation asked the witness to appear at 10:00 a.m. in Room 2141 of the Rayburn House Office Building.2 Inspector General Michael E. Horowitz's written statement is captioned Oversight of the Department of Justice's Handling of Security Clearances for Whistleblowers and is addressed to Chairman Jordan, Ranking Member Plaskett, and members of the Committee.3
The congress.gov event listing names four witnesses: Michael Horowitz (Inspector General, U.S. Department of Justice); Marcus Allen; Tristan Leavitt (President, Empower Oversight); and Glenn Kirschner (former homicide prosecutor, United States Attorney's Office).1 Horowitz's written statement, Allen's written statement, and Leavitt's written statement were opened. Kirschner's written testimony, posted with the event listing, was also opened. So was the printed GPO hearing transcript (Serial No. 118-100). From the transcript, this reconstruction quotes only Ranking Member Plaskett's opening statement and one Kirschner answer.
This is a signed reconstruction from those opened writings and from DOJ OIG Management Advisory Memorandum 24-067 (9 May 2024; press release 14 May 2024).4 5 It is the sequel, on the Allen clearance arc and the Inspector General's MAM, to the 18 May 2023 FBI whistleblower hearing, where Allen first testified publicly about his clearance suspension. Where testimony is referenced, it is a character-exact extract from the opened primary identified in the footnote. Oral hearing lines are quoted only from the GPO transcript.
What the record shows
The opened writings
Horowitz's written statement is the only opened institutional account of the OIG's work on clearance suspensions and of the closed Allen reprisal file.3 He states that employees with a security clearance are "particularly vulnerable to retaliation" because due-process and appeal rights on a clearance action are more limited than on ordinary employment actions, "by design," so that access to classified information can be restricted when a "legitimate security concern arises."6
The written statement treats one case as discussable. "With one exception, I am unable to speak to these matters today, both for investigative and privacy reasons. The one exception is the matter involving now former FBI Staff Operations Specialist Marcus Allen."7 Horowitz writes that Allen's counsel advised the OIG that Allen waived Privacy Act rights or restrictions and supported public discussion of the closed investigation.8
Allen's opened written statement frames the same case as retaliation: "I am here to speak with the committee about how the FBI weaponized the security clearance process to retaliate against me for protected whistleblower activity."9 Leavitt's opened written statement states that Empower Oversight represents Allen and that, after the May 2023 hearing, "the FBI reinstated his security clearance and agreed to restore 27 months of backpay."10 Kirschner's written testimony is summarized below.
The statutory gap and the May 2024 MAM
Horowitz writes that 50 U.S.C. § 3341 requires procedures allowing employees to appeal a clearance revocation or a suspension lasting longer than one year, and that Security Executive Agent Directive 9 requires an Inspector General review of a reprisal allegation in those cases.11 Section 3341 also requires agencies, to the extent practicable, to "permit[s] … individuals … [with a retaliation claim] to retain their government employment status while [the security clearance review] is pending."12
MAM 24-067, addressed to Deputy Attorney General Lisa Monaco on 9 May 2024, found that DOJ Instruction 1700.00.01 (March 2018) provided an OIG appeal after a revocation or denial, but "does not include an OIG appeal process for employees whose security clearance has been suspended for more than 1 year and who allege retaliation, as required by SEAD 9."13 The MAM found that the instruction also lacked a process enabling employees claiming retaliation, to the extent practicable, to retain employment status pending review.13 It stated that existing DOJ practice "is inconsistent with the intent of Section 3341" and "creates the risk that the security process could be misused, as part of an inappropriate effort to encourage an employee to resign".14 The MAM added that its procedural findings "should not be read as a determination on the merit, or lack of merit, of any individual reprisal claim submitted to the OIG."15 The Department concurred with the MAM's four recommendations.16 The 14 May 2024 press release restated the missing one-year OIG appeal and the unpaid-suspension tension with the retention-of-status requirement.5
Horowitz writes that Allen's unpaid leave "helped inform the findings in our May 2024 MAM".17 He also writes that the Department then revised its security clearance appeals directive to require: (1) notice to employees of the right to file an OIG retaliation complaint if a suspension lasts longer than one year; (2) that components identify, if practicable, positions that do not require a clearance so a suspended employee "can remain on paid status during a security investigation"; and (3) that components inform DOJ's Justice Management Division of clearance investigations lasting longer than six months and justify the continued suspension.18
The MAM asked the FBI for suspension-length data regardless of whether the employee had alleged retaliation. "in the last 5 years, 106 employees have had their clearances suspended for 6 months or longer."19 For those 106 employees, "the average time between suspension and a decision to revoke or reinstate the clearance, or for the employee’s separation during suspension, was 527 days, which is about 17.5 months."20
The Allen clearance arc, as Horowitz wrote it
The FBI hired Allen as a Staff Operations Specialist in the Charlotte Field Office in 2015. Horowitz writes that Allen consistently received strong performance appraisals and was named the Charlotte Field Office's 2019 Employee of the Year, is a Marine Corps veteran who served two tours in Iraq, and "held a Top Secret security clearance from 2001 to 2021 without incident" before the events below.21 He worked on the Charlotte Joint Terrorism Task Force gathering open-source material, including work on January 6 investigations, and was credited in his 2021 appraisal for intelligence products on those matters.22
On 29 September 2021, Allen emailed JTTF colleagues, including his supervisors: "There is a significant counter-story to the events of 6 January 2021 at the US Capitol. There is a good possibility the DC elements of our organization are not being forthright about the events of the day or the influence of government assets (e.g. Russia collusion investigation, Larry Nassar debacle, COINTELPRO)." The email linked a video and a New York Times article alleging FBI confidential human sources at the Capitol, and it recommended "extreme caution and discretion" on January 6 leads.23 Horowitz notes that a disclosure need not be correct to be protected; the employee need only have a reasonable belief that it evidenced misconduct or a violation of law, rule, or regulation.24 Charlotte management called a counseling session; a senior official described Allen's further explanation of the Director's testimony as "reasonable", and Allen was told not to send further emails like those. He complied.25
Unknown to Allen, a Charlotte official forwarded the emails to FBI Office of General Counsel, which forwarded them to Security Division (SecD) management. SecD opened a security investigation on that basis.26 Allen's Top Secret clearance had been "favorably re-adjudicated" on 1 October 2021, the day after the emails, with "no derogatory information".27 A SecD employee later told the OIG that management's directive to open the investigation departed from SecD "best practices".28
The FBI Insider Threat Office draft assessment said Allen "may pose" an insider threat and cited, among other messages, hesitation about the COVID-19 vaccine.29 The assigned SecD investigator (Investigator 1) asked the Electronic Security Operations Center for a fuller review. The ESOC report "concluded there was ‘no information validating’ the security predicate SecD used to open the investigation of Mr. Allen" and stated that his January 6 communications "did not appear to be hostile or inflammatory in nature."30 Investigator 1 then interviewed four Charlotte managers. None had seen behavior causing them to believe Allen was disloyal, advocated violence, lacked objectivity aside from the 29 September email, or resisted January 6 work. They agreed it was "not unusual for Allen to send emails with links to open source information, including links which offered alternative viewpoints", and that he "has been, and remains, a high performer".31
Investigator 1 concluded that Allen had "arguably made a protected disclosure" and that Charlotte had no allegiance or violence concerns. SecD management nonetheless directed a Guideline A ("Allegiance to the United States") suspension, citing the InTO assessment and a manager's concern about continued access to domestic-terrorism files.32 Investigator 1 believed edits to the suspension memorandum "grossly mischaracterized" Allen's communications. One supervisor signed "with ‘some hesitancy’"; another called Guideline A "a very hard stretch."33
In January 2022 Allen received written notice that his Top Secret clearance was suspended under Guideline A. The notice's one substantive paragraph stated that SecD had "learned you have espoused conspiratorial views both orally and in writing and promoted unreliable information which indicates support for the events of January 6th."34 On 17 February 2022 he was "indefinitely suspended without pay."35 A new investigator (Investigator 2) first interviewed Allen in May 2022.36 A June 2022 ESOC follow-up found activity "aligned with ALLEN’s job role" and no unauthorized searches or suspicious downloads.37
In January 2023 the assigned adjudicator (Adjudicator 1) wrote his supervisor questioning the InTO evidence and listing mitigators, including the second ESOC review, the Charlotte interviews, an unremarkable 1 October 2021 Top Secret adjudication, a 9 October 2019 polygraph with "No Deception Indicated", and Inspection Division's decision not to open a misconduct investigation.38 The revocation memorandum was finalized in May 2023. It dropped the InTO assessment that had been the stated basis for suspension and added two later specifications: a supervisor's later claim that Allen had previously been admonished about emails — which Horowitz notes conflicted with the initial Charlotte interviews — and a conclusion that Allen had "deliberately failed" to find open-source information for a case agent, though the case agent "did not allege that Mr. Allen had intentionally failed to find the information".39 Revocation was placed under Guideline A and Guideline E (Personal Conduct).39 The FBI did not give Allen the supporting file until 20 September 2023, past the directive's 30-day mark; he requested reconsideration on 20 October 2023.40
A new adjudicator (Adjudicator 2) concluded that Allen had "explained, mitigated and/or refuted the security concerns which were included as a basis for his revocation", recommended reinstatement in March 2024, and in April 2024 "was reassigned from her position in the adjudication division and taken off of the Allen case."41
On 31 May 2024, "following settlement negotiations between the FBI and counsel for Mr. Allen, the FBI reinstated Mr. Allen’s security clearance, and informed him that the various security concerns alleged against him had been ‘sufficiently mitigated.’" On 1 June 2024, "the FBI and Mr. Allen entered into a settlement to resolve his pending retaliation complaint."42 Pursuant to that settlement, Allen withdrew the 2023 OIG retaliation complaint. The OIG closed the investigation. "[B]ecause Mr. Allen withdrew his complaint and entered into a settlement agreement with the FBI, we did not complete our investigation and therefore did not make a finding regarding his retaliation claim."43
Horowitz writes that "this started with his clearance suspension notice in January 2022, and did not end until the reinstatement of his clearance and settlement with the FBI in June 2024", and that "the 29 months that Mr. Allen remained on unpaid leave" informed the MAM.44 Under the prior policy he had "no process for challenging a clearance suspension", remained subject to outside-employment and gift rules, and was limited in taking other work or accepting online donations.45
What Allen and Leavitt wrote
Allen's written statement says the 29 September 2021 emails were "literally one of my job duties", that the FBI accused him of promoting "conspiratorial views" and "unreliable information", and that "[t]he suspension ultimately lasted for 27 months."46 He calls restoration of the clearance "absolute vindication."47 He writes that "Garret O’Boyle and his family are still suffering in the same limbo we were".48
Leavitt writes that when Allen "sat here 16 months ago, the FBI had publicly smeared him with the lie that he was a threat to our national security."49 He treats the reinstatement and "27 months of backpay" as "an official admission by the FBI that claims about his disloyalty to the U.S. were false."50 He writes that each line-level employee who worked the review believed Allen should retain the clearance, and that "[h]igh-level officials" overruled them.51
Those are their written characterizations. They are not OIG findings.
The majority framing that opened
Chairman's invitation letter of 23 September 2024 states the hearing "will examine the Federal Bureau of Investigation’s (FBI) misuse of its security clearance adjudication process to retaliate against whistleblowers" and "the role of the Justice Department’s Office of Inspector General in ensuring that the Department complies with all relevant statutory whistleblower protections."52 Allen and Leavitt's opened writings take that retaliation frame. Ranking Member Plaskett and Kirschner, below, disputed the subcommittee's premise. The May 2023 sister reconstruction records the standing minority counter-frame: that the clearance actions were national-security determinations, not retaliation.
The minority positions that opened
Ranking Member Plaskett's opening statement in the GPO transcript does not mention Allen or security clearances. It disputes the premise of the subcommittee's work. She said "there has been no evidence to show that the Federal Government and particularly the Federal Bureau of Investigation, the FBI, or the Department of Justice has been wholly weaponized against the right."53 She said "there is no conspiracy in the whole of the FBI to root out conservatives in that agency." She continued: "What we do have is sustained campaign pushed forward by a single entity and a group of disgruntled former FBI employees who are known to have committed to attacking, smearing, and degrading career civil servants."54 After describing Project 2025 proposals for the Justice Department, she said "This is the true weaponization of the Federal Government".55
Kirschner's written testimony does not mention Allen, security clearances, or whistleblowers. It argues that Project 2025 would end the Justice Department's independence. Responding to Project 2025's description of the Department, he writes: "I spent 24 years in the DOJ – this characterization is dead wrong and is untrue."56 He concludes that "Project 2025’s determination to extinguish the independence of the Department of Justice looks a lot like a blueprint for dictatorship."57 In an exchange with Representative Garcia about Allen's case, he said "Let me go on record of saying I support whistleblowers" and that "retaliation against them needs to be stamped out."58
Those are their positions. They are not OIG findings, and neither Plaskett's opening nor Kirschner's written testimony addresses the facts of the Allen file.
What remains contested
Retaliation versus national-security process
The majority invitation frames the hearing as an examination of clearance "misuse" to "retaliate against whistleblowers".52 Allen writes that the FBI "weaponized the security clearance process to retaliate".9 Leavitt writes that reinstatement was "an official admission" that disloyalty claims "were false."50 On the minority side, Ranking Member Plaskett said there was "no conspiracy in the whole of the FBI to root out conservatives",54 and Kirschner said "retaliation against them needs to be stamped out."58 Neither addressed whether the Allen clearance action was retaliatory.
Horowitz's opened statement does not adopt that conclusion. The OIG "did not complete our investigation and therefore did not make a finding regarding his retaliation claim."43 The MAM's due-process findings "should not be read as a determination on the merit, or lack of merit, of any individual reprisal claim".15 Reinstatement with concerns "sufficiently mitigated", and a settlement that withdrew the OIG complaint, are established. They are not an OIG finding that the 2022 suspension or the 2023 revocation was retaliatory.
The minority national-security-process reading from the May 2023 hearing therefore remains a live contest. The 25 September 2024 minority opening disputes the subcommittee's premise but does not address the Allen file, and the opened set has no FBI institutional testimony against which to test it.
Twenty-seven months versus twenty-nine
Horowitz writes of "the 29 months that Mr. Allen remained on unpaid leave", and separately writes that the process ran from the January 2022 suspension notice to the June 2024 reinstatement and settlement.44 Allen writes that "[t]he suspension ultimately lasted for 27 months."46 Leavitt writes that the FBI "agreed to restore 27 months of backpay."10 The opened writings do not reconcile the two figures. Horowitz separately dates unpaid suspension to 17 February 2022 and clearance-suspension notice to January 2022.35 44 This reconstruction leaves the 27-month and 29-month counts attributed to their sources.
What the line-level record shows, and what it does not
Horowitz's written statement establishes line-level resistance inside SecD: Investigator 1's protected-disclosure conclusion and "grossly mischaracterized" complaint; supervisor hesitancy on Guideline A; Adjudicator 1's mitigators; Adjudicator 2's reinstatement recommendation and subsequent reassignment; and ESOC's "no information validating" the opening predicate.33 30 41 Leavitt's stronger claim — that "each and every one of the line-level employees who worked on the review believed Marcus should retain his clearance" and that named managers imposed a politicized climate — is his written allegation. Except where Horowitz independently states the same fact, those further names and anecdotes are not bound here.
O'Boyle and other cases
Allen writes that O'Boyle remained in unpaid limbo as of the hearing date.48 No opened 25 September primary from O'Boyle or from the FBI confirms that status. Horowitz says he cannot discuss other pending matters.7
Limits
Transcript quoted narrowly. Congress.gov event 117688 opened for sitting identity, witness list, and posted witness files. The GPO hearing transcript (Serial No. 118-100) opened. This reconstruction quotes from it only Ranking Member Plaskett's opening statement and one Kirschner answer. Other oral lines — including Chair Jordan's opening and the oral testimony and answers of Allen, Leavitt, and Horowitz — are not quoted.
Kirschner written statement. The file is posted on congress.gov under a biography file name (HHRG-118-FD00-Bio-KirschnerG-20240925-U9.pdf) but is titled "Written Testimony of Glenn Kirschner". It concerns Project 2025 and does not address the Allen file.
No FBI institutional response in the opened set. The opened Horowitz statement recounts what the OIG learned from SecD, Charlotte, InTO, and ESOC files. It is not testimony by FBI officials defending the suspension or revocation.
No classified adjudication file. Clearance files often contain classified material. This reconstruction uses only the public OIG narrative, the MAM, and the opened witness writings.
Settlement without a completed OIG finding. Withdrawal of the complaint closed the reprisal investigation. The OIG record that opened is a factual narrative of a closed, incomplete investigation, not a merits determination.
What was established versus what remained open
The opened OIG written record establishes the Allen timeline: clearance-suspension notice in January 2022; unpaid indefinite suspension on 17 February 2022; revocation memorandum in May 2023; supporting file produced 20 September 2023; reconsideration requested 20 October 2023; Adjudicator 2 reinstatement recommendation in March 2024; clearance reinstated 31 May 2024 with concerns "sufficiently mitigated"; settlement 1 June 2024; OIG complaint withdrawn; investigation closed without a retaliation finding. It establishes ESOC's "no information validating" the SecD opening predicate. It establishes that Allen's unpaid leave lasted, on Horowitz's count, 29 months, and that this duration helped inform MAM 24-067.
The opened MAM establishes that DOJ policy, as of May 2024, lacked the OIG appeal required by 50 U.S.C. § 3341 and SEAD 9 for suspensions longer than one year; that unpaid indefinite suspension sits in tension with the statute's retention-of-status language; that 106 FBI employees had been suspended six months or longer in the prior five years, averaging 527 days to a decision or separation; and that the Department concurred with the recommended revisions. Horowitz's written statement establishes that DOJ then revised the appeals directive to add one-year OIG-notice, alternative paid positions where practicable, and six-month justifications.
The opened Allen and Leavitt writings establish their retaliation frame and their 27-month figures. They do not convert the settlement into an OIG finding.
The opened minority record establishes Ranking Member Plaskett's position that there was no evidence the FBI or the Department had been "wholly weaponized against the right", Kirschner's written argument about Project 2025, and his stated support for whistleblowers. Neither addresses the Allen file.
What remained open is the question the May 2023 hearing also left open: whether the Allen clearance action was retaliation, a national-security process that later mitigated, or some contested middle. The OIG did not decide it. Oral hearing lines that might have pressed that question are not quoted here.
Sources
Michael E. Horowitz, Inspector General, U.S. Department of Justice, written statement before the House Committee on the Judiciary, Oversight of the Department of Justice's Handling of Security Clearances for Whistleblowers, 25 September 2024. https://oig.justice.gov/sites/default/files/2024-09/09.25.24.pdf (HTML mirror: https://oig.justice.gov/news/testimony/statement-michael-e-horowitz-inspector-general-us-department-justice-committee)
U.S. Department of Justice, Office of the Inspector General, Management Advisory Memorandum 24-067, The Department of Justice's Compliance with Whistleblower Protections for Employees with a Security Clearance, 9 May 2024. https://oig.justice.gov/sites/default/files/reports/24-067.pdf
U.S. Department of Justice, Office of the Inspector General, press release, 14 May 2024. https://oig.justice.gov/sites/default/files/2024-05/5-14-2024.pdf
U.S. Congress, Hearing on the Weaponization of the Federal Government, 25 September 2024, event 117688. https://www.congress.gov/event/118th-congress/house-event/117688
Marcus Allen, written statement, 25 September 2024. https://www.congress.gov/118/meeting/house/117688/witnesses/HHRG-118-FD00-Wstate-AllenM-20240925-U3.pdf
Tristan Leavitt, written statement, 25 September 2024. https://www.congress.gov/118/meeting/house/117688/witnesses/HHRG-118-FD00-Wstate-LeavittT-20240925-U5.pdf
U.S. House of Representatives, Committee on the Judiciary, Select Subcommittee on the Weaponization of the Federal Government, Hearing on the Weaponization of the Federal Government, 25 September 2024, Serial No. 118-100 (GPO transcript). https://www.govinfo.gov/content/pkg/CHRG-118hhrg56926/pdf/CHRG-118hhrg56926.pdf
Glenn Kirschner, written testimony, 25 September 2024. https://www.congress.gov/118/meeting/house/117688/witnesses/HHRG-118-FD00-Bio-KirschnerG-20240925-U9.pdf
Jim Jordan, Chairman, invitation letter to Glenn Kirschner, 23 September 2024, in the Kirschner hearing packet. https://www.congress.gov/118/meeting/house/117688/witnesses/HHRG-118-FD00-TTF-KirschnerG-20240925-U10.pdf
Predecessor analysis: FBI whistleblowers — 18 May 2023.
This is a signed reconstruction from the opened OIG written record, the MAM, the MAM press release, the congress.gov event listing, the opened Allen, Leavitt, and Kirschner written statements, and the GPO hearing transcript. All quoted material is character-exact from those primaries. This analysis does not claim access to sealed personal filings, classified security-clearance adjudication records, FBI personnel files, or unpublished committee materials.
Footnotes
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U.S. Congress, Hearing on the Weaponization of the Federal Government, House Judiciary / Select Subcommittee on the Weaponization of the Federal Government, 25 September 2024, event 117688. https://www.congress.gov/event/118th-congress/house-event/117688 ↩ ↩2
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Jim Jordan, Chairman, invitation letter to Glenn Kirschner, 23 September 2024, in the Kirschner hearing packet posted to congress.gov event 117688. https://www.congress.gov/118/meeting/house/117688/witnesses/HHRG-118-FD00-TTF-KirschnerG-20240925-U10.pdf ↩
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Michael E. Horowitz, Inspector General, U.S. Department of Justice, Statement before the Committee on the Judiciary, U.S. House of Representatives, Concerning Oversight of the Department of Justice's Handling of Security Clearances for Whistleblowers, 25 September 2024, cover and opening address. https://oig.justice.gov/sites/default/files/2024-09/09.25.24.pdf ↩ ↩2
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U.S. Department of Justice, Office of the Inspector General, Management Advisory Memorandum 24-067, The Department of Justice's Compliance with Whistleblower Protections for Employees with a Security Clearance, 9 May 2024. https://oig.justice.gov/sites/default/files/reports/24-067.pdf ↩
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U.S. Department of Justice, Office of the Inspector General, press release, 14 May 2024. https://oig.justice.gov/sites/default/files/2024-05/5-14-2024.pdf ↩ ↩2
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Horowitz written statement, p. 2. https://oig.justice.gov/sites/default/files/2024-09/09.25.24.pdf ↩
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Ibid., p. 4. ↩
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Marcus Allen, written statement, House Select Subcommittee on the Weaponization of the Federal Government, 25 September 2024. https://www.congress.gov/118/meeting/house/117688/witnesses/HHRG-118-FD00-Wstate-AllenM-20240925-U3.pdf ↩ ↩2
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Tristan Leavitt, President, Empower Oversight, written statement, 25 September 2024. https://www.congress.gov/118/meeting/house/117688/witnesses/HHRG-118-FD00-Wstate-LeavittT-20240925-U5.pdf ↩ ↩2
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Horowitz written statement, p. 2. ↩
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Ibid., p. 2, quoting 50 U.S.C. § 3341. ↩
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Ibid., p. 3. ↩
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Ibid., p. 5. ↩
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Horowitz written statement, p. 12. ↩
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Ibid., p. 3. ↩
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MAM 24-067, pp. 4–5. ↩
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Ibid., pp. 4–5. ↩
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Horowitz written statement, p. 5. ↩
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Ibid., p. 5. ↩
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Ibid., p. 6. ↩
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Ibid., p. 6. ↩
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Ibid., p. 6. ↩
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Ibid., p. 6. ↩
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Ibid., pp. 6–7. ↩
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Ibid., p. 7. ↩
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Ibid., p. 7. ↩
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Ibid., pp. 7–8. ↩
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Ibid., p. 8. ↩
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Ibid., p. 8. ↩
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Ibid., p. 9. ↩
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Ibid., p. 9. ↩
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Ibid., pp. 9–10. ↩
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Ibid., p. 11. ↩
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Ibid., p. 12. ↩
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Ibid., p. 5. ↩
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Ibid. ↩
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Leavitt written statement. ↩
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Ibid. ↩
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Ranking Member Plaskett, opening statement, Hearing on the Weaponization of the Federal Government, Serial No. 118-100 (GPO transcript), p. 3. https://www.govinfo.gov/content/pkg/CHRG-118hhrg56926/pdf/CHRG-118hhrg56926.pdf ↩
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Ibid., p. 5. ↩
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Glenn Kirschner, written testimony, 25 September 2024, p. 3. https://www.congress.gov/118/meeting/house/117688/witnesses/HHRG-118-FD00-Bio-KirschnerG-20240925-U9.pdf ↩
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Ibid., p. 4. ↩
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Serial No. 118-100 (GPO transcript), p. 52. https://www.govinfo.gov/content/pkg/CHRG-118hhrg56926/pdf/CHRG-118hhrg56926.pdf ↩ ↩2
About the author
Paul Stephen
Founder, Apatheia Labs
Evidence-governed research publication — Prosoche applied in the open.
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