INSPECTOR GENERAL DEPARTMENY or DEFENSE Am MARK CENTER DRIVE ALEXANDRIA. VIRGINIA 22150-'500 December II, 2018 Ref: MDR-2013-00159 WHS RFD No. 12-M-0084 MrrJ' Dear Mr. Leopold: While processing your October 6, 201 l, mandatory declassificntion review (MDR) request for "Review ofthe Joint Task Force Guentanamo's Inclusion of Mental Health information in Intelligence Reports (up the Washington Headquarters Services Records Privacy, and Division (WI-IS RPD) detennincd that this report originated with the Department of Defense. Office of Inspector General and referred your request to this Office for processing and direct response to you, We received your request and assigned it case number MDR-2013-00159. For your-reference, the WHS RPD file number associated with this request is 12-M-0084. The Office of the Deputy Inspeolor General for Intelligence and Special Program Assessments conducted a search and found the enclosed document responsive to your request. Afler coordinating a review of the report with the Central Intelligence Agency (CIA), Defense Intelligence Agency (DIA), Office of the Director ol'NationaI Intelligence (ODNI), Office of the Secretary Staff and United States Southern Command (SOUTHCOM), we determined that the redacted portions of the documenl are currently and properly classified in accordance with Executive Order 13526, Sections and The information is also protected under the Freedom of Information Act (FOIA) pursuant to: . 5 use ?552 09(3), which penains to information exempted from release by statute, in this instance 50 use 403(c)(6); - 5 U.S.C. 552 which pertains to certain inter-and intro-agency communications protected by the deliberative process privilege; and - 5 552 (bxe), which pertains to information, the release of which would constitute a clearly unwan-antcd invasion of personal privacy. lfyou consider this an adverse determination, you may submit an appeal. Your appeal, if any. must be postmarked within 60 days orthe date ofthis letter, should clenrly identity the determination that is being appealed, and should reference ure tile number above. Send your appeal to the Department of Defense, Office of lnspector General, ATTN: FOIA Appellate Authority, Suite 10824, 4800 Mark Center Drive, Alexandria, VA 22350.1 500. We recommend CI: ul? Report No. May 4, 2010 Inspector General United States Department 3/ Defense 3" INSPECTOR GENERAL FOR INTELLIGENCE 4 ntal Health Information in Intelligence Information FSView of Joint Task Force Guantanamo's Inclusion '7 - Reports (U) (U) Additional Information and Copies (U) To request copies ofthis report, contact the office of the Inspector General (703) 604?8841 or (DSN 664-884 I). (U) Suggestions for Audits and Evaluations (U) To suggest ideas for, or to request future audits and evaluations, contact the Of?ce of the Deputy Inspector General for Intelligence at (703) 604-8800 (DSN 664-8800) or UNCLASSIFIED fax (703) 604-0045. Ideas and requests can also be mailed to: ODIG-INTEL (ATTN: Intelligence Suggestions) Department of Defense Inspector General 400 Army Navy Drive (Room 703) Arlington. VA 22202-4704 To nun. mismanagement, and Ibuu of authority. Send written complaints to:- Oriana Hotline The Pemgm. Wm DC 20301-1000 we mean: email: new (U) Acronyms and Abbreviations BSCT Behavioral Science Consultation Team CIA Central Intelligence Agency DIA Defense Intelligence Agency DNI Director of National Intelligence HUMINT Human Intelligence ICPM Intelligence Community Policy Memorandum IIR intelligence Information Report IP Interrogation Plan JTF Joint Task Force .ITF GTMO Joint Task Force Guantanamo MFR Memorandum for Record NHMD National HUMINT Management Directive OIG Of?ce ofthe Inspector General SIR Summary Interrogation Report I. i In I .. II. INSPECTOR GENERAL DEPARTMENT OF DEFENSE 400 ARMY NAVY DRIVE ARLINGTON. VIRGINIA 22202-4704 MEMORANDUM FOR UNDER SECRETARY DEFENSE FOR INTELLIGENCE DIRECTOR. DEFENSE AGENCY DIRECTOR. JOINT STAFI SUBJECT: Review ofJoint Task Force Inclusion of Mental I lealth Information in Intelligence Information Reports (Report No. IO-INTEI (U) (U) We are proviclint:l this report for your information and use. This project is the result of in?ormntittn developed during the. investigation into the Alleged L'w of Mind :literr?ng an Detainees; by Pemunwi for the Purpose oj'lmermgun'rm. Report No. We considered management comments on El draft of the report in preparing the ?nal report. (U) Comments on the draft of this report conformed to the requirements of Directive 7650.3 and left no issues. Therefore. we do not require an) additional comments. II I) We up reciate the courtesies extended to the staff. Please direct UL'rilIilIIhi to me at (703) 604 . DEN 664-?. or at (7H3) 6itI-I- DHN 664- (gag/rm Depot Inspector General for Intelligence Report No. (Project No. Reports (U) May 4, 2010 Results in Brief: Review of Joint Task Force Guantanamo?s Inclusion of Mental Health Information in Intelligence Information (U) What We Did During a prior investigation into allegations that detainees were administered mind-altering drugs to facilitate interrogations, we found that some detainees received ongoing medication with drugs (for treatment ofdiagnosed medical conditions) which could impair an individual?s ability to provide accurate intelligence. (UHFQ-H-EH This review was conducted to determine whether DOD Intelligence Information Reports (Ile) published by Joint Task Force Guantanamo (JTF GTMO) included information regarding the mental health status of sources or their history of medication with substances and to determine the possible effect on ?nished intelligence. (U) What We Found (U) Present regulatory guidance authorizes health-care providers to share detainee medical infortnatipn with interrogators. but does not provide speci?c guidance result, execution of these policies at Guantanamo has been inconsistent, resulting in confusion for both health-care providers and interrogation elements. - [Pi-l] (IJHI) Set (MU) (lmi) (la) Set 4!?th Sec life] 05]) (but) Stu Hit-t (him [111(8) sot (bill) See I 4mm Sty l-llL') (U) Client Actions in Response to Recommendations (U) The Vice Director, Joint Staff. concurred with Finding A and proposed that corrective measures should be expanded by updating JCS policy and doctrine to effect training modi?cations for the more ef?cient conduct of incorporating essential medical information into interrogation operations. mitt (but) Sm I (him (hue) (hull Sut- Hm (U) The Director, Defense Intelligence Agency, concurs with Recommendation in Finding C. DIA initiated coordination with United States Southern Command to begin the process of reviewing reporting derived from the 20 speci?ed detainees in this report. Additionally. DIA endorsed the recommendation in Finding A for the Joint Staff to issue guidance. Recommendations Table Client Recon: meuda?une No Additional Comments Requiring Comment Required Director. Joint Staff Nnne A Under Secretary of Defense for None Intelligence Directer, DIA Nune (i Table of Contents (U) Introduction Objective Background Scope and Methodology Prior Coverage (U) Finding A. Policy on Access to Medical Information Policies and Guidance Conclusion Recommendation (U) Finding B. Inclusion: of Information in Intelligencelnformation Reports Guidance Methodology Lack of Reporting interviews Recommendation (U) Finding C. Impact of Information on Finished Intelligence Policy Review of Documents Analyst Evaluations Recommendation (U) Client Comments Vice Director, Joint Staff Deputy Under Secretary of Defense for Human Intelligence Director, Defense ntelligence Agency thwoa(U) This page intentionally left blank (U) Introduction (U) Objective (UAW) This review was conducted to determine whether Dot") Intelligence Information Reports (Ile) published by Joint Task Force Guantanamo GTMO) and its predecessor organizations included information regarding the mental health status of sources or their history of medication with substances and to determine the possible effect on ?nished intelligence. (U) Background t-tgH-H-t-i In a previously published report entitled. "investigation of Allegations ot?the Use ofMind?Alterin't muss to Facilitate Interrogations ofDetainces."? we found that [Hit tl-Jtli Sn. llx'l (Um-?Hm Concerns regarding the reliability of sources and source validation procedures have received attention from Congress since the start of the lraq War. For instance, the Senate Select Committee on Intelligence in the September 2008 report. "'The Use by the Intelligence Community of Information Provided by the lraqi National Congress," concluded that uncertainties about reliability ofsources should be taken into account and should use such information with caution. If, however, are unaware of concerns related to particular sources? reliability. they may put too much confidence in the information reported. would be better served by being noti?ed of such reliability concerns so that they may re-double their efforts to ?nd corroborating reports. Consequently. we sought to ?nd out I) what guidance. ifany. allows interrogators to access detainee medical information. (2) ifinterrogators in fact had access to information about the mental health of these setrrces. (3) if interrogators communicated that information to consumers of intelligence reports. and (4) if the information from these sources was used in ?nished intelligence. "tUt General Report No dated September 23, .3009 Elli'tillil (U) Scope and Methodology (U) We conducted this review from June 2009 through January 2010 in accordance with the Council oftlte inspectors General on integrity and Ef?ciency Quality Standards for inspections. Our focus was on detainee interrogations from September 2001 through October 2009. Our review encompassed human intelligence policy and procedures; medical policy, procedures. and records; interrogation operations; and intelligence analysis. We conducted interviews with subject matter experts including health care professionals, intelligence former Commanders ofthe Joint Medical Group and Joint intelligence. Group, JTF GTMO, the Defense intelligence Agency (DIA), and other organizations. We also spoke with the Acting Deputy Assistant Secretary of Defense (Clinical and Program Policy) in the Of?ce of the Assistant Secretary of Defense (Health Affairs); the Human intelligence Director in the Under Secretary of Defense for Intelligence; the Deputy Director for Human intelligence, and the Vice- Deputy Director for Analysis, We reviewed GTMO behavioral health service reports, interrogation plans, interrogation logs, summary interrogation reports, memoranda for record, and HR evaluations. Finally, we sent surveys to intelligence and interrogators and issued data calls to the appropriate and non-Dot) components. (U) Prior Coverage (U) We discovered no previous reviews addressing the inclusion of mental health information in ?Rs over the last 5 years. (U) Finding A. Policy on Access to Medical Information (U) Present regulatory guidance authorizes health-care providers to share detainee medical informatioo with interrogators. but does not provide speci?c guidance result, execution ofthese policies at Guantanamo has been incensistent, resulting in confusion for both health~care providers and interrogation elements. (U) Policies and Guidance (UIW DOD Policy. policy governing the privacy of personal records, including medical records, at the commencement of Operation Enduring Freedom, was contained in 5400.] laR, Privacy Program,? August 1983. Paragraph C4.2.1.l ofthe regulation provides that records pertaining to an individual may be disclosed without the consent ofthe individual to any official who has a need for the record in the performance of his or her of?cial duties. The Assistant Secretary of Defense (Health Affairs) issued HA Policy 02?005 on April It], 2002. which provided guidance for the medical care for enemy detainees under U.S. control. The policy memorandum speci?cally stated that the health of each detainee shall be monitored and medical records maintained in accordance with the multi-Service regulation, ?Enemy Prisoners of War. Retained Personnel, Civilian internees and Other Detainees," October J, 1997. DOD Guidance. guidance governing the con?dentiality of medical records was expanded in response to implementation ofthe Health Insurance Portability and Accountability Act, Public Law l04-I9] and issued in Health Information Privacy Regulation.? January 24, 2003. Paragraph C7.l 1.4 ol?this regulation provided that a military health facility may disclose protected health in formation to authorized and other Federal of?cials for the conduct of lawful intelligence and national security activities. Authority for the disclosure of medical information for national security purposes was reiterated by Instruction 23l0.08E, "Medical Program Support for Detainee Operations,? June 6, 2006. Further, .loint Publication in 63, ?Detainee Operations," May 30. 2008, directs combatant commanders to "plan, execute, and oversee detainee operations" and speci?cally assigns to medical officers the responsibility ?to identify the process for notifying interrogators of detainee medical limitations.? . ?hi1 Hill l. I-lt?. tlt'll" 3w I lit). Joint Chie? 0fStaf/I Chairman, Joint Chiefs of Staff Instruction 3290.01 C, "Program For Detainee Operations," June 20, 2008, assigns to the Director of Operations (J3) responsibility for reviewing operational plans of combatant commanders to ensure conformance with the standards contained in the Detainee Program. The format for operational planning documents is governed by CJCS Manual 3122.0l Joint Operation Planning and Execution System, Volume I. CJCS Manual 3 Joint Operation Planning and Execution System, Volume ii, August 17, 2007, established the format for such plans. Annex provided the ?format for human intelligence (HUMINT) operations, including the exploitation of prisoners. Annex Q. Medical Services, was established to provide planning data for medical services to outline health care and support for prisoners. United States Southern Command. United States Southern Command (USSOUTHCOM) issued guidance directly applicable to detainee operations at Guantanamo in Policy Memorandum 8?02, August 6, 2002. Paragraph 4.d. ofthe policy memorandum stated that communications between detainees and health-care providers are not con?dential. The policy memorandum further charged medical personnel to convey any information concerning the accomplishment oi?a military or national security mission. United States Southern Command issued additional guidance in a memorandum dated August 9, 2004. This policy statement contained guidance that medical information couid be made available to appropriate militaiy authorities and released by the HT GTMO surgeon or the United States Southern Command Surgeon. TF Guantanamo. Prior to issuance ofthe poiicy of August 9, 2004, the Detention Hospital at Guantanamo published Standard Operating Procedure (SOP) No. 013, ?Patient Administration Department,? dated June I l, 2003, which stipulated that intelligence and law enforcement personnel were not allowed to check out medical records or to view medical records in clinical areas. Only members ol? 4 the Behavioral Science Consultant Team (BSCT) 3 were permitted to view medical records. This procedure was ampli?ed by two additional SOPs issued the following year. Joint Medical Group SOP No. .IMG (lOl. ?Request for Medical Information," March l. 2005. directed that no medical or dental information was to be used for the purposes of furthering intelligence gathering and that all release of medical or dental information must have the written approval ofthe Surgeon General or his deputy. JMG SOP No. 009, ?Custody and Control of Mediealfl)cntal June 1. 2005. reiterated that at no time would active detainee medical or dental records leave the custody of the detention medical staff. (U) Summary of Analysis (Lift-F669) policies for both medical support to detainees and interrogation have evolved overtime. Health?care providers and interrogation staff described an evolving information-sharing environment ranging from unrestricted access to medical records by interrogators to an almost total restriction on the disclosure of medical information in support of interrogations. An interview with a former commander of the Joint Medical Group, JTF GTMO. an survey from a former interrogator, and the Admiral Church investigation of detention operations indicate that from the commencement of detainee operations at Guantanamo, interrogators reportedly had unrestricted access to detainee medical records. in April 2003. the JTF Surgeon designated BSCT personnel as intermediaries to review detainee medical records on behalf of interrogators. in June 2003., access to detainee medical records by personnel became subject to review by the JTF Judge Advocate General. In June 2004. the Surgeon updated local policy and prohibited BSCT personnel from accessing detainee medical records without the JTF Surgeon?s express approval. The majority of interrogation supervisors and interrogators we surveyed (covering the period of 2002 to 2008) con?rmed that they did not have access to detainee medicalfmental health records. However. as will be discussed in Finding B, the interrogation staff clearly had access to mental health If not the actual records. Furthermore in spilt: ofthe obstacles placed on interrogators? direct access to detainee medical records we discovered no policy prohibiting the shat mg of detainee medical intormation with intelligence components for interrogation purposes. (U) 016 review ofdetaince medical records at the Joint Medical Group and interviews with senior health-care of?cials and intelligence of?cers determined that there is a valid need for interrogation components to have medical information relative to the physiological and state ofdetainees to be interrogated. interrogators should be aware that a detainee may have a communicable disease to protect personnel and should also be informed of medical diagnoses and medications that may affect interrogation approaches or the reliability of information provided by the detainee. health-care providers have a primary responsibility for the welfare of their detainee patients. However, it is the responsibility of the respective command surgeon to (U) This team is comprised ofhealth- -caIe personnel quali?ed in behavioral sciences who are assigned exclusively to provide consultative services to support authorized law enforcement or intelligence HCIIVJIIES . so 1 incorporate criteria and processes for the disclosure of medical information in Annex of operational planning documents. Absent de?nitive command approved procedures on the provision and use of mental health information in intelligence reporting. intelligence and the broader intelligence consumer community will be deprived ot?cmcial information necessary to make informed national security judgments and decisions. (U) Recommendations, Client Comments, and Our Response. (U) A. We recommend that the Director, Joint Staff issue guidance requiring that the Combatant Commands when preparing contingency plans and operations plans for staffing through the Joint Operations Planning and Execution System: (U) l. Specify in Annex (Medical Services) the medical information to be provided in support of interrogation activities. (U) 2. Include in Annex the process for sharing medical information with interrogation components. (U) 3. Specify in Annex (Intelligence) how interrogation elements obtain medical information. (U) 4. Specify in Annex how interrogation elements include medical information in intelligence reporting. (U) Management Comments. The Vice Director, Joint Staff, concurred with Finding A and proposed that corrective measures should be expanded by updating JCS policy and doctrine to effect training modifications for the more ef?cient conduct of incorporating essential medical inibrmation into interrogation Operations. (U) Evaluator Response. We concurred with the Vice Director. Joint Staff comments. (U) Finding B. Inclusion of Information in Intelligence Information Reports USI) (bull So; (buff) thi) (NH) 50: 1 4(a) 318m: l-llcl (U) Guidance (.151) (lull). Sec I-llc): (hm) (bll5l Sec INC) Sec (bll?) mill (bull Sec (bH3l (bllil SW leS?) 1N) (hm) Sec (law) (him (U) Methodology (U) The 010 Senior Medical Evaluator described possible criteria for developing a mental illness threshold for our analysis. The criteria would assist in determining an individual?s potential reliability based on medical diagnosis and subSequent treatment (Figure I). Figure 1 Reliability Criteria ant-I 1 Dll?nnlh "Idle-lion. Mag-nu: Dopmnion 533333.33: H'm' (BI-Polar) . 3? Alwun Zeraqual {Duproulon also-mm) 20m" . w, 1- Mum ?5mm Dolmen: razme, order Line Olanzaplne Pomonuh Dlaurua: Bull-?Jan mo "realms! opinion of ma or Duran-a (Don), O?ma of inipncl?ar (Eduard Senior Medical Evaluator. tilk'l! Sec lite] ([5115] [Mill Sac I-ilcl (hull 4ch (HMS) (th) (bill) (171(6) (U) Lack of Reporting Sec 4(cl (MU) Sec Figure 2 UNCLASSIFIED Source Reliability Statements in 443 lle FReliable, 44. 10% I, Unreliable, 17, 4% Not AddressedINot Determined. 382. 86% Sm? I-ltcl (hHSl thh) (hill) Sec l-Ilc) (U) The 20 detainees were not meant to be representative of all of the detainees seen by the Behavioral Health Unit at . 1 a 051) Sec 4ch (bub) (IJHH Su? INC) Table 1 1m: rlul?n mun hu- I [In U?h warn you. l-Hcr Hmj) "?it-1r n l 45n Hm 011. up {Ni {hulk Ru; I-IM. Sui. Illt'UM mm my 135!) (NH) SO: I (IMF): 5K I 'Hl'l ll?. [hilqi {hilhl I-lln (U) Interviews Analyst Interviews. W: #761: Deputy Director for A nulysis, DM. We interviewed the Vice Direcun' for Analysis, INA. to obtain his perspective on the inclusion of mental inl'urmininn in rcliahilit Deputy Director ofl?lumrm Intelligence, DIA. When we interviewed the Deputy Director of I lumen we. pointed out that in many mam the lr'i 115:!) chulrSw I-IM lhult Hum 41mm (U) Recommendations, Client Comments and Our Response B. 1'35? (hill) Sm" ?Management Comments. The Deputy Under Secretary of Defense for Human Intelligence C?ounter Intelligence and Security concurred with the all ofthe So; (hm [blm IMlh) (U) Evaluator Response. We concur with the guidance issued by the Deputy Under Secretary of Defense for Human Intelligence, Counter Intelligence and Security. (U) Finding C. Impact of Information on Finished Intelligence . Ho. Hm (lu?LSlH Hm I llk'l (U) Policy Sec (but?) mm (mm HM (mm ml:- (mu) SL1- Hm (him (U) Review of Documents 1 Sec lb)(5) Sec (U) Finished intelligence is the ?nal precinct ol'the intelligence cycle ready to be dinxeminatcd. The three types of ?nished intelligence um basic. current. and estimativc. USU (hill) Su- Hie) th?) (bitl) Sec I-Ilc) (Ll/m Data Call Submissions. On August l2, 2009. we sent a data call to the Central Intelligence Agency National Ground Intelligence Center; National Security Agency: Army (.?ounterintelligence Center". Office of'the Director of National Intelligence Bureau of Intelligence and Research; ot?State; United States Southern Command: United States European Command; United States Special Operations Command; United States Central Command; United States Northern Command; United States Strategic Command; and United States Paci?c Command. We requested they provide copies ofall finished intelligence products (brie?ngs, assessments. estimates. reports. etc.) attributed in part or in whole to any ot'our 20 selected detainees. We also requested copies oi'all analyst or consumer evaluations of reports attributed to our 20 selected detainees. Our data call requests yielded three reports from the CIA Counterterrorism Center?s Of?ce of Terrorism Analysiss and two briefings. three intelligence reports. and multiple Annual Review Board Assessments From INA. During the interview process. a IJIA analyst provided us with an additional brie?ng and three additional intelligence reports. (Uriel-'Q-Ht-H The Administrative Review Board Assessments submitted by included summaries for 8 of our 20 selected detainees. The detainee Administrative Review Board Assessment is managed by the Of?ce for the Administrative Review for the Detention of Enemy Combatants to determine whether a GTMO detainee is repatriated. The Administrative Review Board reviews assessments of detainees from JTF and the concerned combatant con'unand to determine whether to recommend release. transfer. or continued detention at GTMO. The majority ofthe information contained in the summaries was derived from information that the detainees provided about themselves. Information from the ?nished intelligence products DIA provided can be seen in Table 2. Table 2 (JSD (thl) See Htc) (liHb) DIA (thl) Sex? See I-Itc) HRH Mm SN I Mu) Hull: Sun; I mm.- i mu; HM Ill-mi; (U) Anaiyst Evaluations (ll/W Our data rcqucm for copies nl?ail analyst or consumer HR evalumh?ms of reports; attributed in mm '20 Helcc?lcd detainees yielded 42 muhmtinns. [hasc 4i) cvnluulinm reporting f?rnm u] the 2H schujlcd dctninccs Wu Suhsuquunlly? interviewed and distributed questionnaires to 22 DOB intelligence to better understand the value and utility of the information reported by the 20 selected detainees. We also asked these to describe how they used the information. As shown in Figure 3, 96 percent of rated the MRS from the 13 sources ?of value? 0r ofuhi valui?.? llL:l than 'u Figure 3 UNCLASSIFIED IIR Evaluation Ratings Value. 0.00% Low Value. 1.8% High Value, 38.2% Of Vatue, 58.2% (U) Recommendations, Client Comments and Our Response (U) C. We recommend that the Director, DIA, review the ?nished intelligence products derived from the 20 selected sources to determine if any corrective action, such as retraction or revision, needs to be taken. Management Comments. The Director, DIA, concurs with our recommendation. 3?5? 59!: (U) Evaluator Response. We concur with the Director. comments. Director, Joint Staff (U) JOINT STAFF wumuaron. In: Reply ZIP Code; 0244 [0 2031872000 Apnl 2010 FOR THE DEPUTY ASSISTANT 1NSPECTOR GENERAL FDR Subject Review 0 Joint Task Force Enclrimnn ol Mrnlal Health information in Intelligcnu: Information Report: luwuamm?u1.0201000; I. Thank you [or the upwl?lunllv to renew and un :hnlrafl rcpurl pertaining to the subject issue Whlle the Jnim Sm" "green will) 1hr mm to address sharing pertinent medical information with interrogators. not evcrv plan includes a dervn?rm misuim: and um ulrlemmn operatiun will be cambhahed through an op?alimml or contingency plan. In fact. was; throng!) an execute order. nm a plan Thua. we belwvr ma: instead 01 luninng the Jam! corrective measures (a planning, we need Ir; update pulluv and Llucm'nc to elk-c: lraiump, mmli?calimm 2 As corrective amona. we pmp?se Elsa! [hr uloiau Stall Ll'rreuslomtr lar lntellmentr l-J 2 Updalc CJCS Manual 3314.0! Series. IEnclasurr and Jain! ?2:0 I .2, and Human :n .luinl i?Jpcranona? :linrln?urc address 1hr fur and nmliml supem-mrs In rl?rnuon laciliIm and ntablish procedures fur medical Information ID: uaagr. Ball; of these publicationu are bung Updnlul. -l~2 w?l aim \wrk and Semen lo enwrc that the ceniz'vmg mun-ms Include [hm rcqurremcm in their (curricula. Addressing lhil'i Mlle mlicy and dortranv will ensure not only that the procedure :9 getting down to the lowest lxu?l. lam that it is incurwralcd walnut; curricula. We alau tut-11m: 11141 .ITF rumnundms rcqulrr mr. eutabiash local fur 1hr exchange of medutai mlormalmn. 2] 4 'hnmm Sun punmfumm- .- Emu. "ff-1mm; B. 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