UNITED STATES OF AMERICA
v.

Manning, Bradley E.
PFC, U.S. Army,
HHC, U.S. Army Garrison,
Joint Base Myer-Henderson Hall
Fort Myer, Virginia 22211

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STIPULATION OF
EXPECTED TESTIMONY
Ms. Debra Van Alstyne

illJune 2013

It is hereby agreed by the Accused, Defense Counsel, and Trial Counsel,that if Ms.

Debra Van Alstyne were present to testify during the merits phase of this court-martial, she
would testify substantially as follows:
I. I am the Aunt ofPFC Bradley E. Manning. Brad came to live with my family in the summer

of2006. Brad uses my home as his home of record and spends his leave and holidays with us.
When Brad came back from Iraq for his mid-tour leave in January of2010,he stayed with us at
my house. Brad came home on Sunday,the24th of January. On the night of the25th of January
he went to Boston to visit his friends. Brad returned from Boston on Monday, the 1st of
February and came back to stay with us for the remainder of his time. When Brad returned, we
got hit with a big snow storm onFriday night,the 5th ofFebmary, so we ended up not doing
very much other than playing board games. After the snow storm, we were without power until
Sunday,the 7th ofFebmary. I recall Brad leaving during this time by walking out to the main
road and telling me that a friend was going to pick him up. I do not know where he went,as it
was not my usual practice to ask him where he was going. Brad left for Iraq on the morning of
the 9th ofFebmary.
2. On November2nd,2010, Special Agent (SA) Mark Mander searched my house in connection
with this case. I willingly consented to this search. P rior to the search,I identified items
belonging to Brad and allowed SA Mander to search Brad's room in the basement. I also
identified Brad's possessions and several boxes that contained Brad's possessions. These boxes
and the surrounding area only contained Brad's possessions. One of the boxes was a box that
Brad had sent to me in April of2010 from Iraq. The box contained two soft cover books, two
Maryland T-shirts and oneFOB Hammer Iraq T-shiti. After SA Mander finished his search, he
set aside a number of items on Brad's bed and asked me whether any of the items belonged to
me or anyone else, and not Brad. I identified all the items as belonging to Brad. I am familiar
with the items that were collected by SA Mander. He collected several of Brad's personal items
like books,packages, and digital media.
3. SA Mander, SA John Wilbur, SA Ronald Rock, and SA Ezio Veloso came to interview me on

June 18th,2010.

The agents asked me several questions. One of the agents asked me about

how Brad felt about the Army. Based upon our discussions,I knew that Brad was proud of his
job and of being in the Army. However, Brad seemed to be very quiet when he returned from
Iraq for his mid-tour leave. He also seemed depressed to me. The agents also asked me about
the various email accounts that I had used over the years and that Brad had used over the years
n

identificatio
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and hisFacebook account. I am familiar with Brad's email accounts. The account names that

Brad used in communications with me are "bradley.e.manning@gmail.com" and

"brad405 @emihlink.net". I also told the agents the five different email addresses that I had used

with Brad over the years. Most of those email addresses were either Gmail or EarthLink

addresses. I am also familiar with Brad'sFacebook account, as I followed Brad onFacebook
and also posted a message to hisFacebook page on his request after his an?est. Brad called me
:fi?om Kuwait after his atTest. During our conversation,he asked me if I had seen the apache
helicopter video. When I said that I had not, Brad asked me to do a search for "Collateral
Murder." Brad believed the video was going to be "big news" and that it would make a "big
splash" in America. As part of this conversation,Brad asked me to post a message to his
Facebook account to let others know that he was alive and why he was arrested. I posted the
following message for Brad: "Some of you may have heard that I have been atTested for
disclosure of classified information to unauthorized persons See http://collateralmurder.com/."
4. I recognize the picture marked as Prosecution Exhibit (PE) 40 for Identification. PE 40
for ID is a picture of Brad in his room of taken while he was on his mid-tour leave. I know this

because the picture captures how Brad and his room looked around that time period.

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j?? j.1-Ut;o
THOMASF. HVRLEY

D

MAJ,JA

PFC,USA

Trial Counsel

Military Defense Counsel

Accused

ASHDENFEIN
MAJ,JA

2

EYE.

?