### VIII. DISCOVERY AGAINST THE CIA

> Unlike other litigants, the CIA has an almost unlimited capacity to conceal probative evidence and to assert privileges against disclosure with little judicial intervention. In the Canadian brainwashing case, getting the truth about what happened was all the more difficult because two decades of concealment were continued into the 1980s with unwarranted claims of national security privilege. Nonetheless, the discovery and trial preparation process did yield new evidence further demonstrating the CIA's negligence in the MKULTRA program in general and in the Montreal experiments in particular.

> A. CIA Concealment of the Facts

> Five means of concealing the truth hindered our investigation of the CIA's negligence -- documentary evidence about MKULTRA was destroyed, the details of the MKULTRA Program were restricted to a handful of CIA employees, witnesses who did know about MKULTRA were prevented from testifying, witnesses who did testify told as little as possible, and "national security" claims were groundlessly invoked to prevent disclosure of information embarrassing to the CIA.

> Oliver North was not the Government's first shredder; most of the documentary evidence about the Montreal experiments had been destroyed in 1973. At that time, CIA Director Richard Helms and Sidney Gottlieb, who were both planning to leave the Agency, joined in ordering the destruction of all MKULTRA files.21 This loss was particularly significant because it denied us a documentary basis for cross-examining Mr. Helms, whose lack of credibility had been established when he committed perjury in testimony before Congress in the mid-1970s.

> In the early 1970s, Helms categorically denied under oath before the Senate Foreign Relations Committee that the CIA was trying to overthrow the Marxist Allende Government in Chile, when he had, in fact, directed massive covert efforts to do just that.22 Moreover, Helms went out of his way to lie, for the false testimony came not at some Senate hearing where he was defending the CIA's reputation, but at a hearing where he was personally seeking confirmation as Ambassador to Iran. The honorable course would have been to refuse to discuss the Chilean incident with the Committee and to take his chance of losing the ambassadorship. It was not any secrecy oath that Helms had with the CIA that was at stake, it was his nomination as Ambassador to Iran. Faced with the alternatives, Helms lied.

> Although this was clearly perjury, when angry Senators forced a prosecution, the Washington establishment rallied around Helms, who was allowed to escape justice by pleading to a single violation of 2 U.S.C. section 192, a statute that requires witnesses to answer questions before Congress. This was the sweetheart deal Helms got.

> In order to relieve Mr. Helms of pleading to a felony charge of perjury, the Justice Department created a special misdemeanor to which he was permitted to plead "no contest." The Department of Justice charged Helms with, Helms pleaded to, and the Judge sentenced him for, a crime that doesn't exist. The Department of Justice was so anxious to strike a bargain with the defense that it manufactured a "crime" for the occasion.

> Mr. Helms was charged with the misdemeanor of failing to testify "fully, completely and accurately" before a Senate Committee. There is no such crime. There is a felony statute of perjury before Congress and a misdemeanor statute of contempt of Congress for a "refusal to answer." Helms was charged under the latter statute. But he did the exact opposite. He did not refuse to answer; he answered and did so falsely. This is not a crime under the "refusal to answer" contempt misdemeanor statute.

> Yielding to the Government's intense pressure to accept the "no jail" plea bargain, Judge Barrington Parker assessed only a $2,000. A group of 400 retired CIA intelligence officers promptly donated funds to pay Helms' fine at an impromtu victory party at the Kenwood Country Club following his sentence.23 As Joseph Rauh wrote in the November 9, 1977 edition of the Washington Post, "The CIA now knows that the law is only peripherally for them."

> The problem that Helms presented was typical of those we would face with the covert operators at the CIA. Here was a man who had lied to Congress and gotten away with it. Was there any reason to expect him to do less in a private litigation? The 1973 destruction of MKULTRA documents virtually guaranteed that Helms would have free rein to concoct any story at all when we questioned him.

> As the Helms perjury incident demonstrates, senior CIA officials can seemingly lie with impunity, and documentary evidence is therefore all the more critical in getting the truth. The lost documents would also have been a great aid in questioning Sidney Gottlieb, who had earlier demanded immunity from prosecution before testifying about his role in CIA assassination plots (including one in which he had personally carried anthrax toxins to the Congo in an abortive effort to eliminate Patrice Lumumba). Without documents to force their testimony, Helms and Gottlieb would be free to forget and thus to evade whatever they wished.24

> To conceal further its role in brainwashing experi-mentation, in the early 1950s the CIA established a front organization, "the Society for the Investigation of Human Ecology" (sometimes abbreviated SIHE), at the Cornell University Medical School in New York City. As CIA officer John Gittinger confirmed, the Society served "as a 'conduit for brainwashing research'." Since the program operated under cover, people outside the CIA were prevented from knowing anything about MKULTRA -- there would be no witnesses outside the Agency.

> The MKULTRA Program also operated outside the normal CIA administrative channels without "the usual contractual arrangements," and was concealed even inside the CIA under a practice called "compartmentation." As the more recent CIA Director, Stansfield Turner, explained at his deposition, in MKULTRA CIA employees "used compartmentation to so narrow who knows a thing," that there was "virtually no check or very little check on their activities." Compartmentation thus ensured that there would be no witnesses aside from Helms, Gottlieb and their assistants.25

> When former CIA employees were subpoenaed and did testify, lawyers for the Agency prevented full answers to our questions. This practice took the form of rather blatant intimidation -- for example, at a meeting to prepare his testimony one day prior to deposition, John Gittinger was told by counsel for the CIA that he "would be liable for prosecution if [he] began to talk about some of that." Furthermore, although the CIA counsel present at the deposition did not represent Gittinger and would have had a conflict of interest had he done so, he nonetheless directed Gittinger not to answer a number of questions (a practice authorized neither by statute nor rule of the court). In subsequent depositions CIA lawyers simply ignored their conflicts of interest, and claimed to represent both the CIA and its former employees when they decided that a question should not be answered. In this way, even a former employee who wanted to tell all could be prevented from doing so.

> The testimony that we did obtain from former CIA officials was often less than candid. A central axiom of clandestine activities, such as the MKULTRA Program, is that CIA must maintain "plausible deniablity." This means that layer upon layer of cover stories are available to conceal Agency involvement, and that Agency operatives are schooled in telling half-truths or out-right lies to minimize disclosures. There were many examples of this practice in the revelations of MKULTRA. CIA agent James Monroe erroneously told the New York Times that the Society for the Investigation of Human Ecology, which he ran, received "only 25 to 30 percent" of its budget from the CIA with the bulk coming from other foundations and private donors. The truth is that over 95% of the Society's funds came from the CIA. When that cover story failed and the Canadian victims presented their claims, efforts to minimize CIA responsibility included the completely inaccurate claim to the Canadian Government and plaintiffs' counsel that Dr. Cameron applied for funds "unsolicited." 26 Against this backdrop of institutionalized lying, we were never sure that we had gotten everything that a witness knew.

> Finally, throughout the litigation, the CIA repeated ad nauseam its claim of secret intelligence "sources and methods" to keep us from uncovering the full facts. While it is difficult to understand how information concerning a program that ended some twenty or more years ago could threaten our national security, it is easy to see how the broad sources and methods privilege ratified by the Supreme Court in CIA v. Sims, 27 could be exploited to hide evidence of CIA wrongdoing. The pernicious Sims doctrine isparticularly damaging, because the vast majority of secret material is classified not to protect our security, but to prevent official embarrassment. And, even where there was some legitimate security concern in the beginning, the privilege continues to be asserted many years later when there is no need for secrecy.

> The prevalence of the assertion of national security privileges to avoid political embarrassment by the intelligence community was documented in a column by former Solicitor General Erwin Griswold. 28 As Dean Griswold recounts from his experience when representing the Nixon administration during its unsuccessful effort to prevent publication of the Pentagon Papers:29

> > It quickly becomes apparent to any person who has considerable experience with classified material that there is massive overclassification and that the principal concern of the classifiers is not with national security, but rather with governmental embarrassment of one sort or the another. There my be some basis for classification while plans are being made, or negotiations are going on, but apart from details of weapons systems, there is very rarely any real risk to current national security from the publication of facts relating to transactions in the past, even the fairly recent past.

> Under this fallacious national security rubric, as expanded and ratified by the Burger Court's Sims decision, identities of key witnesses were concealed from us, documents were withheld, and on one occasion we were personally threatened with prosecution under the Espionage Act if we did not agree to excise information from the deposition of Richard Helms.30 Most importantly, as we detail below, even though the two CIA Station Chiefs in Canada in August 1977, Stacey B. Hulse and John Kenneth Knaus, had been publicly identified as such, we were prevented from obtaining their deposition testimony concerning their briefings by the CIA on the Cameron experiments and what they told the Canadian Government on the Agency's behalf when the story broke in Canada.

> B. Additional Facts from Discovery and Trial Preparation Underscore CIA Negligence

> Despite the unique problems in conducting discovery against the CIA, we were able to obtain important new evidence of the Agency's negligence in each of the three facets of the case. The story of the Olson death, and the CIA's eventual acceptance of responsibility in 1975 was even more compelling when recounted by his widow, who we eventually hoped to use as our first witness at trial. The CIA's negligence in funding Cameron, a reckless loose cannon, was confirmed by his contemporaries in Montreal. The CIA's negligence in failing to ensure the safety and consent of Cameron's patients was admitted in deposition testimony by CIA officers. A group of psychiatrists who evaluated our clients' experiences under Cameron's care confirmed the bizarre and injuriousnature of the CIA-funded brainwashing experiments. Finally, during discovery we had obtained important admissions of culpability on the part of the CIA and the U.S. Government.

> 1. New Evidence about the Olson Death.

> One of the most courageous people to join in this fight was the widow of Dr. Frank Olson, Alice W. Olson. Despite the pain and anguish caused to her by recounting the details of the tragic CIA experiment upon her husband, Mrs. Olson agreed to appear as a witness for the plaintiffs and was prepared to offer testimony concerning her husband's death. As Mrs. Olson explained in her affidavit to the Court:

> > In 1953 my husband was a distinguished biochemist working as a civilian employee of the United States Army at Camp Detrick, Maryland. My husband and three of his colleagues were given LSD, without warning, by CIA officials Sidney Gottlieb, Chief of CIA's TSS Chemical Division and his Deputy, Robert Lashbrook, as part of the CIA experimental brainwashing program designated as MKULTRA and operating under the direction of Richard Helms, Chief of Staff of CIA's Clandestine Services. Gottlieb and Lashbrook fed the LSD to my husband and the others in their after-dinner liqueur without telling them that there was LSD in the cointreau glass, nor that they were the subject of CIA experiments.

> Mrs. Olson next describes the negligent and reckless behavior of Gottlieb and Lashbrook after the injurious effects of that LSD experiment became apparent:

> > When Frank came home on the Saturday following the CIA experiment, he was uncharacteristically moody and depressed. He was in great distress and in obvious need of help. But, instead of being taken to a psychiatrist in Washington or Maryland, Gottlieb and Lashbrook took him to an allergist in New York City, Dr. Harold Abramson, who was working with the CIA on its LSD experiments. Frank had two sessions with Abramson. After the first session he returned to this area, but when he got as far as Bethesda, he told me on the telephone that he was afraid to return home because he might do something wrong in front of the children. So he and Lashbrook returned to New York for a second session with Abramson. That night he jumped from a window of a tenth story hotel room in New York in which he was staying with Lashbrook.

> Finally, Mrs. Olson explains the direct link between the LSD and her husband's death:

> > My husband was a remarkably stable man. He had never had any psychiatric problems before he was fed the LSD in 1953. As President Ford put it when he signed legislation in 1975 providing $750,000 recompense to our family, the CIA's drug experiments were "the proximate cause of his death." There is no doubt that CIA-administered LSD is what caused Frank's death.

> Mrs. Olson's personal recollections of the tragedy would not only underscore the magnitude of the negligence and incompetence of CIA officers Gottlieb and Lashbrook, but would also show the Court that the government had already accepted responsibility for their misdeeds. There were even public admissions of responsibility from the highest levels of our government that Mrs. Olson could describe in Court.

> When the Olson story finally became known despite the CIA's efforts at concealment, then President Gerald Ford met with Mrs. Olson and her children on July 21, 1975 and, according to a White House Press Release, "expressed the sympathy of the American people and apologized on behalf of the U.S. Government for the circumstances of Dr. Frank Olson's death in November 1953." And in a July 24, 1975 letter to Mrs. Olson, then CIA Director William E. Colby apologized for the CIA:

> > I wish to join with President Ford in expressing my deepest personal sympathy and hope that you and your family will also accept my sincere apologies on behalf of the Central Intelligence Agency for the suffering you and your family have endured as a result of the untimely loss of your husband in 1953. The uniform reaction of the employees of the Agency to this disclosure has been dismay and regret that this could have occurred. I can find no explanation for why you were not fully informed of the circumstances at the time and apologize equally for that omission...

> On October 12, 1976 President Ford signed legislation providing $750,000 recompense to the survivors of Dr. Olson and, after stating that the LSD "would appear to have been the proximate cause of his death," went on:

> > The approval of this bill underscores the basic principle that an individual citizen of this Nation should be protected from unreasonable transgressions into his personal activities. There should be no doubt that my administration is opposed to the use of drugs, chemicals, or other substances without the prior knowledge and consent of the individual affected. At the request of the family of Dr. Olson, I take this opportunity to highlight this continuing policy.

> These contrite apologies from the highest level of our government made it clear that there had once been a decision that those injured in MKULTRA should be compensated.

> In addition, we now had obtained additional CIA documents demonstrating that in the wake of the Olson death, CIA Director Dulles ordered that a Review Board be created to oversee and control TSS research and experiments. But the Dulles order was not carried out and no other steps were taken to ensure that there would be no repetition of the reckless and negligent conduct in the Olson death. Despite the Dulles order, Gottlieb and Lashbrook were left in charge of MKULTRA without even a reprimand.31 In that capacity they approved the funds for brainwashing experiments performed by Dr. Cameron without the review and oversight of the special Review Board ordered by Director Dulles and with the same recklessness they had exhibited in the Olson death.

> 2. New Evidence of CIA Negligence in its Relation to Cameron

> One of Gottlieb and Lashbrook's assistants was John Gittinger, who learned of the work of Dr. Cameron in the brainwashing field by reading an article appearing in the American Journal of Psychiatry in January of 1956. In preparing our case we consulted Dr. Robert Jay Lifton, an internationally recognized expert on brainwashing who had conducted one of the seminal studies of Chinese Communist practices during the Korean War. Dr. Lifton agreed to review that 1956 Cameron article and to testify in Court concerning the similarities between Cameron's techniques and the brainwashing procedures of the Communist Chinese.

> In Dr. Lifton's expert opinion, the 1956 Cameron article "described non-therapeutic and potentially dangerous techniques of repetition and isolation which were extensions of the totalistic methods of 'thought reform' or 'brainwashing' used in China and elsewhere." Lifton's view was subsequently corroborated by Cameron himself. In pre-1956 papers Cameron had admitted that he conducted experiments with "sleeplessness, disinhibiting agents and hypnosis" in an attempt to exploit the methods used to achieve "the extraordinary political conversions which we have seen, particularly in the iron curtain countries."32

> We also asked Doctors Lifton and Salzman to study the Cameron application and to be prepared to testify about their opinions of it. They were in complete agreement that the Cameron application showed on its face that CIA funds would be used to conduct extremely dangerous brainwashing experiments. As Dr. Lifton concluded in his affidavit to the Court, "it is clear from the Cameron application, itself, that these procedures were experimental and deviated from standard and customary psychiatric therapies in use during the 1950s"; the procedures in the Cameron application "closely parallel the techniques of 'thought reform' or 'brainwashing' used in Chinese prisons and elsewhere, and represent a mechanized extension of those 'brainwashing' methods." In short, "the Cameron application was a transparent proposal to conduct experiments with 'thought reform' or 'brainwashing' procedures extrapolated from methods documented in the academic literature, and would have been seen as such by anyone reviewing it during the 1950s."

> Dr. Salzman likewise concluded in his affidavit:

> > The Cameron application proposed a mind control research project with no safeguards, no discussion of risks, dangers and potential destructiveness ... This is clearly outrageous; callous insensitive, inhuman pursuit of an idea with no concern for possible destructive effects. It would be beyond any reasonable doubt that a foundation which supported such a project could not have had therapeutic expectations from the grant application.

> These conclusions were important parts of our case because the dangerous brainwashing experimentation described in Cameron's application clearly required some investigation of Cameron's competence and some provision for safeguards to protect the experimental subjects. As subsequent discovery confirmed, the CIA made no investigation of Cameron or his experimental procedures before making the grant, despite the obvious dangers to the human beings who were to be experimented upon with CIA funds. This is a prime example of the negligent failures to exercise reasonable care in the MKULTRA program that formed the basis for our second cause of action.

> We had found, moreover, dramatic evidence of the ease with which such an investigation could have been made. From 1947 through 1956, the CIA was in close touch with Dr. Omond M. Solandt, Chairman of the Canadian Defence Research Board during that time period. We contacted Dr. Solandt who provided us with an affidavit confirming that CIA had never bothered to contact him for his opinion "about Cameron's competence, the depatterning and other experimental procedures used by Cameron, or whether it was appropriate to fund the experimental procedures used by Cameron."

> Dr. Solandt agreed to appear and to testify concerning the fact that he had disapproved of Cameron's destructive experiments and made his views known. Again, his affidavit summarized these views:

> > I knew of the experimental depatterning procedures used by D. Ewen Cameron. In the early 1950s, the wife of one of my associates sought medical treatment from Cameron at the Allan Memorial Institute. She was depatterned and after seeing her I knew that this kind of work was something the Defence Research Board would have no part in. It was my view at the time and continues to be that Cameron was not possessed of the necessary sense of humanity to be regarded as a good doctor. My views of Cameron and the depatterning procedures were known to him, and I let it be known through Dr. Morton that I would not look favorably upon any application by Cameron to the Defence Research Board for psychiatric research. Cameron never applied for Defence Research Board grants to fund psychiatric research and would never have received such support had he applied.

> In addition, Dr. Solandt was prepared to testify that there was a close relationship between himself and the CIA:

> > During the 1950s, the United States Central Intelligence Agency had a resident representative at the United States Embassy in Ottawa who was publicly introduced as such. The CIA representative was liaison with the Royal Canadian Mounted Police and was free to attend Defence Research Board staff and committee meetings where defence research programs were discussed. Formal information exchanges with the CIA were made by the RCMP, and the CIA and Canada exchanged all research information of mutual interest during this time. The security clearances issued by the Canadian Defence Department during the 1950s were accepted by any United States agency working in Canada, including the Central Intelligence Agency.

> Dr. Solandt also noted in his affidavit to the Court that there was another knowledgeable expert, Dr. Donald O. Hebb, who had been readily available to the CIA in 1956 and early 1957 when Cameron's application was being solicited and approved. Dr. Hebb, the highly respected Chairman of the Psychology Department of McGill University during the 1950s, had worked closely with Canadian and U.S. intelligence,33 and had an equally discrediting opinion of Cameron's brainwashing experiments.

> Unfortunately Hebb had died before we could take his deposition. Because Dr. Hebb's testimony bore on Cameron's reputation, however, we were able to offer sworn statements of others about what Hebb had said without violating the hearsay rule. These statements relating to Hebb's opinions would not be offered as evidence of the truth of what Hebb had said, but as evidence that he had said it and would have warned the CIA to stay away from Cameron or at least make a full investigation of him and his work. In this way we could avoid the potential bar of the hearsay rule to introduce the following sworn statement by Solandt concerning Hebb's "very low opinion" of Cameron and his "prudence" in dealing with subjects:

> > I know by my discussions both directly with Dr. Hebb and indirectly through Dr. Morton that during the 1950s, Dr. Hebb had a very low opinion of the depatterning and other experimental procedures used by Cameron and of Cameron's prudence in dealing with research subjects.

> Further evidence of Hebb's low opinion of Cameron's competence and prudence was provided to us by Ronald Blumer, a documentary film writer and producer who interviewed Hebb shortly before his death. In their interview, Dr. Hebb stressed to Blumer that Cameron was "irresponsible" and "criminally stupid":

> > Cameron's experiments were done without the patient's consent. Cameron was irresponsible -- criminally stupid, in that there was no reason to expect that he would get any results from the experiments. Anyone with any appreciation of the complexity of the human mind would not expect that you could erase an adult mind and then add things back with this stupid psychic driving. He wanted to make a name for himself - so he threw his cap over the windmill....
> > Cameron stuck to the conventional experiments and paper writing for most of his life but then he wanted that breakthrough. That was Cameron's fatal flaw - he wasn't so much driven with wanting to know - he was driven with wanting to be important - to make that breakthrough - it made him a bad scientist. He was criminally stupid.

> Blumer summarized Hebb's statements about Cameron as "completely scathing", with Dr. Hebb referring to Cameron and his methods several times as "criminally stupid."

> Final corroboration of Hebb's view of Cameron came from Jay Peterzell, a research associate with the Center for National Security Studies, who had made an exhaustive review of the CIA's MKULTRA program. Peterzell interviewed Hebb in the summer of 1978 and provided us with an affidavit based on his detailed notes of that interview:

> > Dr. Hebb: "Look, Cameron was no good as a researcher. He was terrible. He did not have the faintest notion of how to go about doing experiments or doing research. But he thought he did."
> > Dr. Hebb: "He was eminent on the basis of politics, psychiatric politics and university politics. But not on the basis of research."
> > Dr. Hebb: "Well, that was an awful set of ideas that Cameron was working with. It had no intellectual demand, it called for no intellectual respect. If you actually look at what he was doing, and what he wrote, his proposals, it would make you laugh, that is what I meant being awful, if I had a graduate student who talked like that I'd throw him out."

> If Hebb felt this strongly in talking to strangers, we argued, it is clear what he would have said to the CIA if they had not treated this matter too casually to warrant interviewing him or anyone else. Indeed the CIA formally admitted in court papers that, despite its close ties with Dr. Hebb, the Agency never bothered to ask him about Cameron. Moreover, since Solandt and Hebb were both working with the CIA in the 1950s, there can be no suggestion of secrecy reasons for not inquiring of them, only reckless and negligent indifference to the safety of the subjects of experimentation.

> In addition we developed evidence that even casual inquiries of those in Montreal who knew of the controversial experiments being performed by Cameron would have revealed to the CIA the risks of injury and averted the tragic events subsidized by that agency. Dr. Paul E. Termansen, a Vancouver psychiatrist who was treating plaintiff Logie, had been at McGill in the early 1960s and provided us with a sworn statement that during his time at McGill there had been considerable controversy about Cameron's experimental activities, which were promptly terminated by his successor Robert A. Cleghorn. Dr. Solandt also confirmed that "[d]uring the 1950s, there was considerable controversy in the Montreal and Canadian psychiatric and academic communities about the depatterning and other experimental procedures used by Cameron at the Allan Memorial Institute." As these affidavits made clear, there was tremendous controversy surrounding Cameron and the experiments he performed, which would have alerted the CIA to the dangers of funding human experimentation at Allan Memorial.

> The CIA's lack of care in failing to make any investigation whatever of Cameron was equalled only by its callous failure to ensure safety and consent of the subjects -- victims of the subsidized experiments.

> 3. New Evidence of CIA Negligence in Failing to Ensure Safety and Consent of Subjects

> From documentary discovery we had found no provision at the time of the approval of the grant or later to ensure that the experimentation was safe or that only consenting volunteers were used as experimental subjects. We confirmed that no precautions of any sort had been taken through the deposition testimony of John Gittinger, the CIA Project Monitor for the Montreal experiments; Sidney Gottlieb, the Director for the MKULTRA Program and Gittinger's supervisor; and Robert Lashbrook, Gottlieb's deputy.

> All three of these major actors in the funding of Cameron testified on deposition that the CIA took no steps whatsoever to ensure that experimental subjects would not be injured or that the CIA-funded experiments would be conducted in an ethical fashion. Gittinger admitted that he "never really thought very much about his [Cameron's] actions anytime because I wasn't interested" and that he "was really not interested in his [Cameron's] patients." Gittinger continued:

> > Q. You didn't have the slightest interest in Cameron?
> > A. That is absolutely true, sir.
> > * * * * *
> > Q. You didn't feel responsibility to find out what Cameron did to the subjects of the CIA funded experiments?
> > A. No sir.

> Sidney Gottlieb likewise admitted that he had not evaluated the experimental protocols for the research Cameron would conduct with CIA funding; that he had not determined whether the procedures would injure experimental subjects; and that he didn't even know whether anyone at the CIA had done so. Robert Lashbrook was equally uninterested in the safety of the subjects of the experiments he was helping to fund:

> > Q. Did you at any time make any suggestions on any projects on how to safeguard the experimentees?
> > A. ...it wasn't felt necessary really to go into a lot of detail as to exactly how they were handling the subjects... In general patients would be of low interest.

> Gottlieb, Lashbrook and Gittinger each also admitted that no effort was made to ensure that Cameron's patients would be told that they were undergoing experimental procedures. Gottlieb failed to determine whether Cameron was going to tell patients and their families that the experiments were new and untested and that other accepted therapeutic procedures were available for mental illness; and he had no recollection of instructing Gittinger concerning the CIA-funded experiments. Gittinger admitted that patients in a psychiatric hospital often exercise impaired judgment and that it was particularly important that they be told that they were participating in experiments. Yet he too felt no obligation to protect the psychiatric patients who would be used in the Montreal experiments and, indeed, failed even to instruct Colonel Monroe to obtain reports on the condition of those patients after the experimental procedures.

> In short, Gottlieb's deposition testimony was:

> > Q. It is correct, is it not, that Cameron had complete discretion as to what he would tell the patients in the experiments that were funded by the CIA?
> > Witness and counsel confer)
> > A. That is correct.

> At his deposition Gittinger, too, displayed a total lack of interest in the subjects of the Montreal experiments:

> > Q. Did you ever make a check on whether Doctor Cameron was doing it unwittingly?
> > A. I certainly did not, because I had absolutely no interest in that area, as far as he was concerned.
> > Q. You weren't interested a Canadian citizen might be unwittingly given LSD, with USA money?
> > A. I was not.

> Lashbrook was equally unconcerned:

> > Q. Did you ever at any time hear a conversation at the CIA concerning the questions whether the persons who were experimented on must be told that they were being experimented on?...
> > A. Not that I recall.

> Indeed, Lashbrook admitted he had not heard "one single thing" about Cameron's operation after he, Lashbrook, "directed the sending of the money to them."

> After CIA funds were forwarded to Cameron, the CIA officers failed to supervise Cameron's experimentation in any way. Gittinger admitted that he never saw a report from Cameron; that he never visited Cameron in Montreal; and that he never asked Monroe to report to him on what Cameron was doing. Yet, despite his ignorance concerning Cameron's CIA-funded experiments, Gittinger nonetheless certified as Project Monitor that Cameron's progress was "satisfactory" on the basis that "we just were given word that they were having no problems."

> Gottlieb admitted that he "did not know anything about" the experiments Cameron performed with CIA funds, that he didn't know what experimental subjects were told about the CIA-funded research at McGill, and that he had no recollection of anyone at the CIA telling him the details about Cameron's experiments with intensive electroshock, LSD, sensory deprivation, depatterning, psychic driving, or prolonged drug induced sleep.

> The significance of these admissions by the key CIA officers involved in the Montreal experiments was driven home by the affidavit of David J. Rothman, Ph.D., a eminent social historian at Columbia University's College of Physician and Surgeons. Dr. Rothman was prepared to provide testimony at trial detailing the history of consent from the Hippocratic Oath through the Nuremberg Code and its aftermath. As detailed in his affidavit to the Court, Dr. Rothman's conclusions left no doubt that the conduct of Gottlieb, Lashbrook, Gittinger and, ultimately Cameron, was unethical:

> > ...during the 1950s there was a recognized obligation on the part of entities financing, sponsoring or conducting medical experiment-ation to adopt ethical standards reflecting the principles set out in the Nuremberg Code, particularly the informed consent requirement; and to make inquiry and to ascertain the competence and prudence in dealing with research subjects of those conducting medical experimentation on their behalf ... by the 1950s it was clearly irresponsible for a physician to conduct experiments upon patients without obtaining their voluntary consent to be research subjects.

> As the deposition testimony of Gottlieb, Lashbrook and Gittinger made clear, these ethical principles were mocked by the CIA's conduct in the MKULTRA program, and the Agency's subsidies to the experimentation performed upon our clients.

> 4. New Evidence -- Expert Evaluations of the Damaging Effects of Cameron's Experimentation upon Plaintiffs

> In addition to Leon Salzman and Robert Jay Lifton, four other psychiatrists agreed to appear as expert witnesses for our clients -- Paul Termansen, David Joseph, Brian Doyle and Harvey Weinstein. After reviewing the medical records, and later interviewing the former Cameron patients, each of these experts provided compelling testimony of the damaging impact of the CIA-funded experiments.34

> Concerning plaintiff Robert Logie, Dr. Termansen provided that following assessment in his sworn affidavit to the Court:

> > Instead of standard treatment, Mr. Logie underwent a series of experimental, highly controversial, procedures ... Mr. Logie was not a suitable subject for any one of the experimental procedures he was subjected to, if, indeed, anyone would be suited for such procedures. Most certainly, no one would be suitable to the type of experimental procedures used at Allan Memorial Institute at that time, unless they had volunteered to undergo those experimental procedures.

> As Dr. Termansen explained, after the experiments Mr. Logie's "existence could best be termed marginal ... he managed to function, work, and exist, but barely." And the injurious effects continue to this day; "It may be there is some basic disturbance of his sleep mechanism, or it appears more likely that, after the very traumatic treatments he experienced while asleep, he has an unconscious resistance to sleep."

> Concerning plaintiff Lyvia Stadler, Dr. Joseph concluded that "the 'depatterning' with intensive electroshock, 'psychic driving,' prolonged drug induced sleep, and the administration of nitrous oxide that Mrs. Stadler underwent were not accepted forms of treatment, then or now, but were clearly experimental" and that those procedures "would have resulted in significant disorganization, confusion and psychological impairment ...." Dr. Joseph also concluded that plaintiff Janine Huard was exposed to non-standard experimental procedures, and that "the combination of experimental procedures that Mrs. Huard was exposed to at the Allan Memorial Institute would have resulted in significant disorganization, confusion and psychological impairment...." And, as to both plaintiffs Huard and Stadler, Dr. Joseph concluded it "was clearly irresponsible and unethical, both then and now, to use procedures ... without obtaining a separate voluntary consent to undergo experimental procedures."

> Dr. Doyle concluded concerning plaintiff Jean-Charles Pagé, that "[n]othing in Mr. Pagé's medical records indicates that he was a candidate for any of these procedures" which were "not accepted forms of treatment but were clearly experimental procedures...." Dr. Doyle continued in his affidavit, "the harsh physical procedures, high doses of drugs and the experimental techniques used on Mr. Pagé would inevitably cause injury to his mental and physical health."

> Dr. Doyle also reviewed the case of plaintiff Rita Zimmerman, who was "depatterned" through a total of 30 electroshocks; underwent 56 days of prolonged drug-induced sleep, received 14 days of negative "psychic driving," and 18 days of positive "psychic driving." He concluded that:

> > Mrs. Zimmerman was not a candidate for electroshock therapy, much less the intensive "depatterning" procedures that were so disruptive as to leave her incontinent as to bladder and bowel ... the intensive electro-shocks that were used to "depattern" Mrs. Zimmerman were clearly experimental, as was the entire "depatterning" procedure that was carried to an extreme in her case. The nearly two months of drug-induced sleep and over one month of "psychic driving" Mrs. Zimmerman underwent were equally extreme applications of clearly experimental procedures ... the experimental "depatterning," prolonged drug induced sleep and "psychic driving" procedures used on Mrs. Zimmerman would inevitably cause injury to her mental and physical health.

> As to plaintiff Florence Langleben, who was "depatterned" with intensive electroshocks and LSD, underwent 43 days of prolonged drug-induced sleep, and received 32 days of negative "psychic driving" and 11 days of positive "psychic driving," Dr. Doyle reached similar conclusions:

> > Mrs. Langleben was not a candidate for electroshock therapy, much less the intensive "depatterning" procedures ... the intensive electroshocks that were used to "depattern" Mrs. Langleben were clearly experimental, as was the entire "depatterning" procedure. The six weeks of drug-induced sleep and six weeks of "psychic driving" Mrs. Langleben underwent were equally extreme applications of clearly experimental procedures ... the experimental "depatterning," prolonged drug induced sleep and "psychic driving" procedures used on Mrs. Langleben would inevitably cause injury to her mental and physical health.

> Finally, as to plaintiffs Pagé, Langleben and Zimmerman, Dr. Doyle concluded that "[i]t was clearly irresponsible and unethical, both then and now, to use experimental procedures ... without obtaining a separate voluntary consent to undergo experimental procedures."

> In Dr. Salzman's opinion, the standard treatment alternatives in the 1950s for the depression that plaintiff Val Orlikow suffered were verbal psychotherapy and the possible use of low doses of tranquilizing drugs. The use of LSD and the "psychic driving" that Mrs. Orlikow underwent were not accepted forms of treatment, and in Dr. Salzman's opinion, the combination of those experimental procedures "would cause her to suffer significant and continuing psychological impairment."

> Concerning plaintiff Mary Morrow, Dr. Salzman found no basis for Cameron's diagnosis of schizophrenia, and concluded that even "had that diagnosis been correct, standard treatment alternatives at that time would have included low to moderate doses of anti-psychotic medications, verbal psychotherapy, and the possible use of electroshock in limited therapeutic dosage if other means of treatment were not successful." Dr. Salzman continued in his sworn affidavit:

> > The use of prolonged drug-induced sleep and the "depatterning" with intensive electroshocks that Dr. Morrow underwent were not accepted forms of treatment, then or now. The use of such extreme measures reflects an experimental orientation derived from "brainwashing" through "depatterning" or "wiping the mind clear" to be followed by "repatterning" or indoctrination ... the combination of experimental procedures that Dr. Morrow was exposed to at the Allan Memorial Institute would cause her to suffer significant and continuing psychological impairment, as well as likely causing continuing memory deficits and cognitive impairments....

> Finally, in Salzman's opinion as to both Mrs. Orlikow and Dr. Morrow, "[i]t was clearly irresponsible and unethical as well as callous and inhumane, both then and now, to use experimental procedures ... without obtaining a separate voluntary consent to undergo experimental procedures."

> Possibly the most distressing story of all was that of plaintiff Louis Weinstein as told by his son, psychiatrist Harvey M. Weinstein. After his father's experiences at the Allan Memorial Institute, Harvey entered medical school and studied psychiatry in part to try to understand what had happened to his father. More than anyone else, Harvey understood the magnitude of his father's loss. Using the full barrage of brainwashing procedures, including intensive electroshock and LSD, Cameron had "depatterned" Louis Weinstein and then attempted to "reprogram" his behavior with psychic driving messages. These intrusive physical procedures caused an organic brain syndrome in Louis Weinstein, from which he would never recover. Drawing on his observations as a son and, because his father no longer trusted psychiatrists, as a treating physician, Harvey Weinstein was prepared to provide trial testimony of minor psychiatric ailments being exacerbated and compounded by the CIA's experiments. Dr. Weinstein's sworn affidavit to the Court bore witness to the harrowing experiments and their tragic aftermath, which converted a life of success, happiness and family warmth into so much human wreckage. Foreseeing an effort to exclude Dr. Weinstein's testimony on grounds of bias, we asked Doctors Joseph and Doyle to review his findings, which they were able to corroborate wholeheartedly.

> * * * * *

> Toward the end of the CIA funding, Dr. Cameron wrote a letter to the Agency front, the Society for the Investigation of Human Ecology, acknowledging his "great indebtedness" to the Society, describing the assistance rendered by the Society as "invaluable", and expressing a "considerable sense of indebtedness" for the funding he had received. Four years later Dr. Cameron left the Allan Memorial Institute and his successor, Dr. Robert A. Cleghorn, immediately terminated the experimentation Cameron had conducted. At Cleghorn's request Dr. Termansen and a colleague conducted a scientific study of the results of Cameron's depatterning experiments. Dr. Termansen was now prepared to testify about his study at trial, in particular the following conclusions:

> > After interviewing and testing patients selected from a sample of 79 persons who had undergone the "depatterning" procedure, we concluded that the incidence of memory loss attributable to the intensive electroshock was higher than that encountered with standard therapeutic electroshock, and that the "depatterning" procedure, therefore, was not an acceptable form of therapy. We found that frequent electroshock as used in "depatterning" was associated with poor clinical outcome, and that the shorter the interval between electroshocks, the greater was the current memory impairment as seen on the Wechsler Memory Scale. "Depatterning" is no longer used because of its damaging effects on cognitive functioning and because it would appear to have little to offer in terms of improvement over conventional therapeutic electroshock.

> 5. New Evidence -- CIA Admissions of Culpability

> Even before our clients' suit was filed there had been admissions by the CIA in Congressional testimony that there was a responsibility on the part of the Agency toward the MKULTRA victims. Thus, at an August 3, 1977 hearing, Senate Intelligence Committee Chairman Inouye asked CIA Director Turner, to "report back to this committee in 3 months on what the Agency has done to notify these individuals and institutions, and furthermore, to notify us as to what steps have been taken to identify victims, and if identified, what you have done to help them, monetarily or otherwise." Admiral Turner responded, "All right, sir, I will be happy to." At that same August 3, 1977 hearing, Senator Kennedy asked CIA Director Turner, "It is your intention to notify the individuals who have been the subject of the research, is that right, Admiral Turner? Do you intend to notify those individuals?" To which, Admiral Turner replied, "Yes."

> During the course of documentary discovery we uncovered new admissions made during the late 1970s by the CIA and the Justice Department. A July 17, 1978 Memorandum prepared by the Office of Legal Counsel at the Justice Department was important because it concluded that the CIA had a legal duty to find and notify persons used as unwitting experimental subjects in MKULTRA:

> > The first question we have addressed is whether there is a legal duty to notify those MKULTRA subjects who can be reasonably determined to have a continuing risk of adverse effects on their health as a consequence of their earlier involvement. While there is no legal authority specifically addressing this question, we believe that, under the best view of general legal principles and analogous case law, a duty to notify such individuals exists in this instance. As a general matter of tort law, the courts and other legal authorities have found a duty to exist where one party puts another in danger; even if the former party's conduct is without fault, he is under a duty to give assistance and to prevent further harm.... As applied here, this principle would appear to require the CIA, having created the harm or risk thereof, to notify the individuals as an effort directed at rendering assistance and preventing further harm.

> Despite Admiral Turner's earlier promise and the just quoted authoritative Justice Department legal opinion, the CIA failed to notify any of our clients of their unwitting participation in the CIA-funded experiments at Allan Memorial.

> An even more important set of admissions was also secured in documentary discovery -- an October 31, 1978 memorandum by Assistant CIA General Counsel William Allard, which specifically assessed the Agency's involvement in the Montreal experiment and concluded:

> > ...the substantial funds flowing from this Agency to McGill in support of the project subsequent to 1956 would appear to preclude the determination that this Agency was minimally involved within the meaning of the Department of Justice guidance on this point. The use of the drugs identified and "particularly intensive electroshocks" as part of the methodology suggests that long-term after-effects may have been involved. Also, because the patients selected "were almost entirely those suffering from extremely long-term and intractable psychoneurotic conditions" it is doubtful that any meaningful form of consent is involved in this case.

> But even more productive were oral depositions. Thus, on January 19, 1983 John Gittinger testified concerning the CIA involvement with Cameron as follows: "Now that was a foolish mistake. We shouldn't have done it ... as I said, I'm sorry we did it. Because it turned out to be a terrible mistake." Gittinger concluded that if he had it to do over again, "I would refuse to support him or be interested in him."

> Similarly, at his December 13, 1983 deposition, Stansfield Turner, who was the CIA Director at the time of the first revelations of the Agency's Montreal experiments, recounted his "dismay at discovering" the MKULTRA activity, which "seems entirely bizarre." Admiral Turner continued that the program was "one of the kinds of errors that we must be sure to find a way to prevent recurring," and that the MKULTRA experiments on unwitting individuals were unethical and left him "aghast" when he learned of those activities. In addition, Admiral Turner offered the view at his deposition that the MKULTRA program was the product of excessive "compartmentation." Finally, in a key admission for purposes of our allegation that there was a negligent failure to supervise Gottlieb and Lashbrook, Admiral Turner attributed their excesses to "inadequate supervision." As he stated it in the original manuscript for his book, Secrecy and Democracy: The CIA in Transition:

> > How could this have happened? I believe compartmentation was responsible. Because of compartmentation there was inadequate supervision of those who, with good intent, concocted this absurd scheme. The unit conducting the experiment simply had such autonomy that not many outsiders could look in and ask what was going on. In all walks of life people get too close to their work and need someone with a somewhat detached viewpoint to take an occasional look at where they are going. In this case the system just could not provide that kind of detached critical review and a few well-intentioned, but terribly misguided, individuals badly abused the CIA's privilege of keeping secret so much of what it does.

> The most significant admissions, however, were the apologies the CIA tendered to the Canadian Government. At the time of the initial public disclosure in August of 1977 that the CIA had financed Cameron's experiments in Montreal, opposition Member of Parliament Andrew Brewin asked questions about this American interference in the internal affairs of Canada. 35 As a result of these inquiries, official protests by Canada were lodged with the United States Embassy in Ottawa and the CIA Chiefs of Station resident there. While we were working on the court fight in Washington, we asked David Orlikow, the M.P. husband of plaintiff Val Orlikow, to pursue these protests and the U.S. response in Ottawa. In reply to David's inquiries, the Canadian Government stated that as a result of its protests, unnamed U.S. representatives had "expressed regret" for the CIA funding of Cameron and had offered assurances that such activities would not occur again.

> These apologies could potentially break the case wide open. As official statements by diplomatic representatives of the United States, they were clearly authoritative admissions that could be used in court. Politically, the apologies also put the CIA in an untenable situation in Canada. How could the U.S. contrition expressed in the apologies be reconciled with the CIA's refusal to aid its Canadian victims when they later came forward? Additionally, the information that David Orlikow had secured was obviously only part of the story of the apologies. The U.S. representatives in Ottawa had obviously been briefed on the MKULTRA Program and told what to say. Both sides doubtless had notes, correspondence and memoranda concerning their discussions. All of these were potential sources of additional, detailed admissions that could bring the case to a rapid conclusion.

> Faced with further damaging admissions, the CIA response was to suppress the additional documentation of the apologies by asserting that disclosure would damage U.S. national security, and to fight disclosure of Canadian documents through diplomatic channels. The few sanitized U.S. State Department documents we obtained in discovery and those of the Canadian Government that David Orlikow helped us secure through the Canadian Access to Information Act confirmed that from 1977 to 1979 there had been a series of discussions between Canada and the United States in which the apologies were made.36 It was also increasingly clear that the unnamed U.S. representatives in Ottawa who had apologized included the CIA Chiefs of Station at our Embassy there. This made the apologies even more valuable coming as they did from the CIA itself.

> Jay Peterzell soon provided public identifications of these CIA officers in Canada. Published press articles had years ago revealed that Stacey B. Hulse was the CIA's Ottawa Chief of Station in 1977 and that he had been succeeded by John Kenneth Knause in 1978. Both men had since returned to the Washington area. We contacted both Hulse and Knause, told them about the suit by the Canadian victims of MKULTRA, and asked them to schedule a deposition. Neither man objected to appearing and testifying, although the now retired Hulse, whose deposition we wanted to take first, stated that he was undergoing an oral biopsy in the next few days, and asked if he could contact us in a few weeks to schedule the deposition after he had recovered and had received the results of his medical tests. We agreed to this request, and about two weeks later Hulse called to schedule the deposition, volunteering that he was willing to appear as soon as the next day. It looked like the whole story about the apologies was within reach.

> The CIA's desperate scramble to prevent this deposition was a monumental confirmation of the renewed arrogance of the Agency. Upon receiving the notice for the agreed upon deposition, the CIA intervened, forced its representation upon Hulse and, in violation of normal court rules, instructed him that he was not to appear. The result was the same when we subpoenaed Knause. Over the succeeding months we unsuccessfully sought a Court Order compelling the testimony of these publicly identified CIA Officials. Refusing even to confirm or deny the published facts that Hulse and Knause had worked for the Agency, the CIA asserted that there was no question that we could ask either man that was not shielded by the national security privilege. With the CIA offering in camera ex parte affidavits that we were not allowed to see, much less rebut, our effort to obtain this potentially critical testimony failed.37

> Despite the refusal of the Agency to allow depositions of the officials who delivered the apologies, after questions were raised in Parliament by our allies, Prime Minister Brian Mulroney agreed that we would be allowed to take the testimony of the Canadian official who received the apologies. John G. Hadwen, Director General of the Canadian Bureau of Security and Intelligence Liaison, testified that on September 26, 1977, he received an apology for the Agency's actions. But, when the CIA lawyers in attendance objected to our further questions, the Canadian Justice Department attorney for Hadwen instructed him not to confirm that Stacey Hulse had made the apologies or provide any information of any sort. This Canadian government acquiescence in the CIA's cover-up of the apologies produced a farcical deposition transcript that was of limited evidentiary value. At one point in response to our questions, Hadwen was reduced to reading statements made by his Minister in the Canadian House of Commons. After hours of questioning, Hadwen testified that "Mr. Anonymous," had "expressed regret that this should have happened without the knowledge of the Canadian government" and "he expressed regret at the nature of the program." No matter what we asked, that was all Hadwen was permitted to say. The Canadian Government allowed pressure from the CIA to outweigh the interests of its own citizens, even a Member of Parliament.

> __________
> 21 That the MKULTRA records were destroyed to conceal the wrongdoing of Helms and Gottlieb was confirmed by the fact the others in the Agency -- Gottlieb's deputy and the Chief of the CIA Records Center -- had tried unsuccessfully to prevent the destruction. Our efforts to learn the identities of these individuals and to obtain their testimony were defeated by the CIA's refusal to allow depositions on spurious national security grounds.

> 22 At a February 7, 1973 hearing Helms was a sworn witness and gave the following testimony:

> > Senator Symington: Did you try in the Central Intelligence Agency to overthrow the government of Chile?
> > Mr. Helms: No, sir.
> > Senator Symington: Did you have money passed to the opponents of Allende?
> > Mr. Helms: No, sir.
> > Senator Symington: So the stories you were involved in that war are wrong?
> > Mr. Helms: Yes, sir. I said to Senator Fulbright many months ago that if the Agency had really gotten in behind the other candidates and spent a lot of money and so forth the election might have come out differently.

> Allende was shot to death in the coup d'etat that installed the murderous Pinochet dictatorship.

> 23 This celebration, where Helms was greeted with a standing ovation, is recounted in Thomas Powers' comprehensive, although unauthorized, biography of Richard Helms. T. Poweres, The Man who Kept the Secrets: Richard Helms & the CIA 304-06 (1979).

> 24 Others outside the CIA completed the destruction of documents. For example, when we deposed attorney Duncan Cameron, he admitted destroying certain files which his father had taken when leaving Allan Memorial, even though lawsuits were pending against Dr. Cameron's estate at that time. Our research likewise detected no trace of Cameron's CIA connection in the records of the Allen Memorial Institute or the Archives of the Cornell University Medical Center (which provided cover for the front organization that served as a conduit for the Agency's funding of the experimentation at the Allan Memorial Institute).

> 25 Concealment was so total even inside the CIA that Gottlieb's assistant John Gittinger swore at his deposition that he was not informed of the Olson death, and therefore was not in a position to warn Cameron of the dangers inherent in experimenting with LSD.

> 26 The U.S. Embassy in Ottawa was similarly deceived by the CIA, which stated in a February 1979 cable that there was "no evidence the SIHE [the Society] or Agency officers gave any hint to McGill or Cameron that a request for funds would be met with a favorable response." The truth, of course, was the exact opposite.

> 27 471 U.S. 181 (1985).

> 28 E. Griswold, Secrets not Worth Keeping, Washington Pose, Feb. 15, 1989.

> 29 New York Times v. United States, 403 U.S. 713 (1971).

> 30 At his deposition, Helms committed a "slip" and disclosed the location of an unacknowledged CIA facility on the record. Although there were four CIA lawyers in the room at the time, not one of them objected, called the "slip" to our attention or sought to mark the record. Instead, weeks later when the written transcript of Helms' deposition was ready for filing in Court, the CIA insisted that this information be excised from his testimony. When we objected to the obliteration of anything in Helms testimony on the public record, a letter was delivered to our office late one night "directing" us to return our copies of the Helms "slip" to the CIA and threatening both of us with prosecution under the Espionage Act if we failed to do so. We of course refused to be intimidated and informed the Agency that we didn't take any orders from it. The CIA promptly seized upon this as a means to attempt to influence the Judge hearing our case and, after a lengthy series of briefs in which we were portrayed as irresponsible for having asked Helms questions that led to his "slip", succeeded in securing a Court Order protecting this sensitive and vital "secret." We later learned that this same "secret" information had been published in the Washington Post several years earlier.

> 31 CIA documents showed that Gottlieb received a letter from Dulles saying he had used "poor judgment," which Helms was instructed to hand carry to Gottlieb and to tell him the letter was "not a reprimand and no personnel file notation was being made." Lashbrook did not even receive this slap on the wrist.

> 32 This admission, which was truly a "smoking gun" that directly tied Cameron's experimentation to Communist "brainwashing" methods, was unearthed by Dr. Harvey Weinstein, the son of plaintiff Louis Weinstein, while reviewing Cameron's papers at the Archives of the American Psychiatric Association.

> 33 We corroborated Hebb's close relationship with the CIA by obtaining in discovery a special CIA security clearance issued to him in the early 1960s.

> 34 We were impressed by the willingness of these prominent psychiatrists to assist largely without payment.

> 35 In the Canadian Parliamentary system there is a daily "question period" during which Members from all parties can query Cabinet Ministers of the Government. The Ministers must answer. Over the years, this mechanism (especially when employed by New Democratic Party Leader Ed Broadbent and his colleague from Vancouver, Svend Robinson) proved to be one of the few effective means of pressing the Ottawa government to support the CIA's Canadian victims.

> 36 We also had evidence, through an affidavit provided to us by the Canadian Secretary of State for External Affairs, that additional apologies were subsequently tendered by U.S. representatives.

> 37 That the CIA's assertion that some secrecy concern required the concealment of Mr. Hulse's identity as a retired CIA officer was completely ludicrous was confirmed when he died several years later. His lengthy and prominent Washington Post obituary began by repeating the common knowledge that had been published years earlier; Stacey Hulse had been the CIA Chief of Station in Ottawa in the late 1970s.

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