u.s. Department ofJustice

Officeofthe InspectorGeneral

A Review of the FBI'sActions in

ConnectionWithAllegations Raised

By ContractLinguist Sibel Edmonds

UNCLASSIFIED SUMMARY

Office of the Inspector General

Office of Oversight and Review

January 2005
I. INTRODUCTION

This report describes the Office of the Inspector General's (OIG)

investigation of allegations raised by Sibel Edmonds, a former Contract

Linguist (CL) for the Federal Bureau ofInvestigation (FBI). Edmonds worked

for the FBI from September 20,2001, until March 2002, when her services as a

CL for the FBI were terminated. Before that termination, she had raised a

series of allegations regarding the FBI's CL program, including security

concerns about actions by a co-worker related to potential espionage.

Our review found that Edmonds had written several memoranda to her

supervisors raising her concerns about the co-worker. Edmonds prepared one

of her memoranda, dated February 8,2002, on her home computer, after first

obtaining a supervisor's permission to write it at home. According to the FBI,

that memorandum contained classified information, and Edmonds' use of her

home computer to process classified information was a security violation.

Edmonds' supervisor referred Edmonds' February 8 memorandum

containing her allegations to a Security Supervisor. The Language Supervisor

also reported Edmonds' security violation to the Security Supervisor. After a

cursory investigation of Edmonds' allegations, the Security Office concluded

that Edmonds' allegations against the co-worker were unsubstantiated and

that Edmonds' security violation was inadvertent.

Edmonds continued to complain about the co-worker, and asserted that

FBI supervisors were protecting the co-worker. Edmonds also raised her

concerns to higher-level officials in the FBI, to the OIG, and to Congress. In

addition, Edmonds raised other allegations regarding the language program to

the bIG. For example, Edmonds made allegations of travel voucher fraud and

time and attendance abuse. Edmonds also alleged that the FBI had hired

unqualified personnel and used one of them to translate military interviews

despite that person's weak language skills.

On March 22, 2002, the FBI stopped using Edmonds' translation

services, and on March 26 the FBI terminated her contract. Edmonds

complained that the termination was in retaliation for her complaints, and the

OIG agreed to investigate this matter.

II. SCOPE OF OIG INVESTIGATION

During the course of our investigation, the OIG interviewed more than 50

individuals, including FBI employees, contractors, and Department of Justice

(DOJ) officials. The OIG interviewed Edmonds on three separate occasions, in

April, June, and November of 2002. On January 28, 2004, the OIG wrote to

Edmonds' attorney offering to meet with Edmonds again if she had additional
relevant information to provide to the OIG. Her attorney said that Edmonds

did not believe she had anything additional to provide the OIG, and the

attorney did not request an additional meeting.

In addition, the OIG obtained and reviewed thousands of pages of FBI

documents relating to Edmonds' allegations, including e-mails, notes, and

other records. We also sought expert assistance with translations and other

matters from another federal government agency outside the DOJ.

We closely examined nearly a dozen separate allegations by Edmonds

against the co-worker which, when viewed together, amounted to accusations

of possible espionage. We sought to determine, with respect to each individual

allegation, whether the facts supported or refuted the allegation. However, the

ultimate determination as to whether the co-worker engaged in espionage, as

Edmonds' allegations implied, was beyond the scope of the OIG's investigation.

We communicated to the FBI during our review that the OIG was not making

such a determination, and that the potential espionage issue should be

addressed by the FBI, not the OIG. Instead, our investigation focused on the

FBI's response to the complaints Edmonds raised about her co-worker and

other language translation issues.

According to some media accounts, Edmonds made additional

allegations relating to the September 11 terrorist attacks and the allegedly

inappropriate reaction by other FBI linguists to those attacks. However,

Edmonds never raised those allegations to the OIG, and we did not investigate

them in our review. Rather, we understand that staff from the National

Commission on Terrorist Attacks Upon the United States (9/11 Commission)

interviewed Edmonds regarding these claims. Our review focused on the

allegations made by Edmonds to the OIG, particularly Edmonds' allegations

regarding the FBI's handling of the concerns about the co-worker, her

allegations about inappropriate practices in the language program, and her

allegation that the FBI retaliated against her for raising those allegations.

This report is an unclassified version of the OIG's full 100-page report on

Edmonds' allegations. The OIG completed the full report in July 2004 and

provided copies of it to the 9/ 11 Commission and several congressional

committees that have oversight of DOJ. Subsequently, two members of the

Judiciary Committee specifically requested that the OIG create a declassified

version of the report for public release. The letter stated that releasing a

"declassified" version of the report, "or at least portions or summaries, would

serve the public's interest, increase transparency, promote effectiveness and

2
efficiency at the FBI, and facilitate Congressional oversight." In response, the

OIG created this unclassified summary of the full report. 1

This report describes the results of our investigation. In Part III of the

report, we provide background information on Edmonds and relevant FBI

components and procedures. In Part IV, we assess the factual basis underlying

Edmonds' allegations against the co-worker. In Part V we provide a factual

chronology of relevant events and an analysis of the FBI's handling of the

allegations as they arose. In Part VI, we examine some of Edmonds' additional

allegations, including concerns about travel voucher fraud and time and

attendance abuse. In Part VII, we address the allegation that the FBI decided

to stop using Edmonds as a linguist in retaliation for her allegations. Finally,

in Part VIII, we make systemic recommendations to the FBI in an attempt to

help it improve its foreign language translation program.2

III. BACKGROUND

In this section of the report, we provide brief background information on

Edmonds. We also describe the FBI's Language Services Section (LSS), which

manages the FBI's language program and its linguists. We then describe some

of the procedures regarding FBI language translations that are relevant to this

case.

1 The FBI conducted a classification review of the full version of this report and

classified it at the Secret level. Because the information was from the FBI, the OIG did not

have the authority to declassify or publicly release the report on its own. We conferred with the

FBI and the DOJ Civil Division in the creation of this unclassified summary of the report. We

believe this unclassified version summarizes the core of the OIG report, although it does not

include all of the facts in the full report or even all of the allegations addressed in the full

report. Moreover, we recognize that, in some instances, it is difficult to understand this version

of the report fully because much of the information from the full report remains classified and

cannot be included here. However, this version is the maximum that the FBI and the DOJ

Civil Division agreed was unclassified and allowed to be released publicly.

2 It is important to note that the OIG completed a broader audit regarding the FBI's foreign

language translation program. That audit is entitled "The Federal Bureau of Investigation's

Foreign Language Program Translation of Counterterrorism and Counterintelligence Foreign

Language Material." In it, the OIG examined the FBI's ability to translate critical foreign language

material, its success at meeting linguist hiring goals, and whether the FBI's procedures ensure the

appropriate prioritization of work, accurate and timely translations of pertinent information, and

adequate pre- and post-hire security screening of linguists. The audit report was completed in

July 2004 and classified by the FBI at the Secret level. Like the full Edmonds report, that audit

report was provided to several Congressional committees and the 9/11 Commission. The OIG

released an unclassified summary of the audit report in July 2004. It is available on the OIG's

website at http:/ hvww.usdoi.gov/oig/audit/FBI/0425/index.htm.

3
A. Edmonds

Edmonds, who was born abroad and speaks English fluently, moved to

the United States in 1991 to attend college. She married an American citizen

in 1992. Before joining the FBI, Edmonds worked as a volunteer at a local

courthouse, as a court-appointed special advocate for children, and for the

Rostropovich foundation, a non-profit organization that delivers medical

supplies and food to a children's hospital. In addition, Edmonds served as a

corporate officer (Secretary) for her husband's consulting business.

Edmonds applied to the FBI on March 10, 1997, for a linguist position.

After she took the requisite language tests, by letter dated May 6, 1998, the FBI

offered Edmonds a position as a CL. The offer was contingent upon Edmonds

receiving a Top Secret security clearance.

Pursuant to instructions in the offer letter, Edmonds completed, on June

4, 1998, an SF-86 Questionnaire for National Security Positions - the standard

form used by the federal government to collect information for background

investigations of persons q.pplying for positions that require a security

clearance. As part of the background investigation, Edmonds was polygraphed

on December 4, 1998. The FBI also conducted a Personnel Security Interview

(PSI) of Edmonds on December 16, 1998. Her security file does not reflect any

activity on her background investigation during 1999. It appears that through

a series of oversights and lack of follow through, the FBI did not take action on

her background investigation, and therefore Edmonds did not begin work as a

CL during this time period.

In February 2000, the FBI asked Edmonds to submit another SF-86. In

April 2001, LSS wrote a memorandum requesting that the PSI be updated, and

asking that the necessary work be done to complete the background

investigation. The FBI conducted supplemental PSIs of Edmonds on May 1,

2001, and July 19,2001. On September 13,2001, four years after she first

submitted her application, the FBI granted Edmonds a "Top Secret" clearance.

No job interview was conducted other than the PSIs.

Edmonds began ,¥orking for the FBI on September 20,2001, first as a

Contract Monitor (CM), and shortly thereafter as a CL.3 As we describe below,

on March 22, 2002, the FBI stopped using Edmonds' translation services.

3 The various linguist positions in the FBI are described more fully in the next section

of this report. In brief, a CM can provide summary translations of oral and written

communications, and analyses of those translations, for internal dissemination. In addition to

those services, CLs also can act as interpreters in FBI interviews, review material produced by

other linguists, produce written communications for internal and court dissemination, and

testify as expert witnesses in federal court. A CL can perform the same duties as a Language

Specialist, which is the term for a linguist who is a permanent employee of the FBI.

4
B. The FBI's Language Services Section

1. Organiza~ion

In the early 1980s, the FBI began hiring linguists for translation,

interpretation, and other language services necessary for the FBI's work.

Before that, the FBI used Special Agents to perform such services. The number

of linguists hired by the FBI grew from a mere handful in 1983 to over 1,100 by 2002.

Through its Foreign Language Program (FLP), the FBI seeks to ensure

that the language needs of its field offices and Headquarters units are met.

The FLP and the personnel who perform language services for the FBI are

directed by the LSS. LSS personnel handle approximately 60 languages

covering 95 percent of the world's population. Since March 2002, the LSS has

been placed within the Office of International Operations at FBI Headquarters,

which is under the jurisdiction of the FBI's Director for Law Enforcement

Services. Immediately before the March 2002 reorganization, LSS was part of

the Investigative Services Division.4 A copy of the FBI's organizational chart,

dated March 4,2004, is attached as Appendix A.

During the early part of 2002, the time relevant to this review, LSS was

composed of three units. The Language Training and Assessment Unit (LTAU)

was responsible for developing and conducting language assessments of FBI

applicants and personnel. The LTAU also provided foreign language and

cultural training to FBI personnel. The Translation and Deployment Unit

(TDU) managed national translation and interpreting resources in support of

the FBI's investigative and administrative priorities. The TDU ensured that

linguists were assigned to offices requesting their services or that a requesting

office's work was sent to available linguists. The Language Administration and

Acquisition Unit (LAAU) handled the administrative functions of the FLP. The

LAAU also was responsible for hiring linguists and for researching, acquiring,

and integrating language-related technologies. An organizational chart for the

LSS, dated November 13,2001, is attached as Appendix B.

2. Types of Linguists

The FBI uses three types of linguists. First, the FBI has permanent

employees known as Language Specialists (LS). LSs provide translations of

written or oral communications and analyze those translations. They also can

act as interpreters in FBI interviews, review material produced by other

linguists, produce written communications for internal and court

dissemination, and testify as expert witnesses in federal court.

4 Before that, LSS had been placed, at various times, in the Laboratory Division and

the Criminal Investigative Division.

5
In addition, the FBI uses contract employees as linguists. The Contract

Linguist Program (CLP), which is administered by the LAAU, enables the FBI to

acquire linguist resources without adding permanent employees. It also gives

the FBI the opportunity to recruit permanent LSs from linguists who already

have been evaluated through the CLP. The FBI uses two types of contractors

with different ski11levels, CLs and CMs. Linguists' designation as CL or CM

depends upon their performance on language tests administered by the LSS.5

According to an LSS Operational Manual, CLs perform translation duties

"similar to those of Language Specialists." CLs provide translations of written

or oral communications and analyze those translations. They also act as

interpreters in FBI interviews, review material produced by other linguists,

produce written communications for internal and court dissemination, and

testify as expert witnesses in federal court.

The FBI created the additional position of CM in response to a critical

need for linguists and the inability to find a sufficient number of linguists who

qualify for LS or CL positions. A CM can provide summary translations of oral

communications and analyses of those translations, and written

communications for internal dissemination. An FBI memorandum explains

that the CM position was proposed to address a critical need for linguists to

perform summarization work. The memorandum explained that a CM's work

may require some additional clarification and review. It stated that CMs

should not be asked to write foreign language transcriptions, nor should they

testify regarding the accuracy of their translations. In addition, according to

the memorandum, a CM's work should be reviewed by a fully qualified linguist

before it is used for other than internal use. Moreover, the memorandum

recommended that the CMs not be given assignments in offices where they are

the only speakers of the language in question.

Thus, CMs are more limited in their duties than CLs. For example, a CL

is qualified to provide a verbatim translation. A CM, in contrast, is not

approved for verbatim translations of documents, but may provide summary

translations. However, in order to cope with these limitations, the FBI often

has CMs do verbatim translations and then has the translations reviewed by CLs.

LSS directs from FBI Headquarters all of the linguists in the FLP. The

linguists themselves generally are assigned to assist FBI agents in their work,

and the linguists generally are grouped according to language. FBI linguists

5 In this report, the generic terms "linguist" and "translator" refer to any of the three

categories - LS, CL, and CM.

6
translate a wide variety of materials, including recordings, written documents,

and audio recordings of interviews.

3. Language Services Section Computer System and

Training

As discussed more fully in the OIG's foreign language translation audit,

(cited at footnote 2), an FBI computer network links FBI offices and permits

large quantities of material to be moved between offices for translation, to

better utilize FBI linguistic resources.

More than one linguist may be assigned to a particular task, due to

resource issues. The FBI's computer system only keeps a record of the last

person to work on a particular task; it does not maintain records of any other

linguist's prior access. In addition, the work does not remain on the computer

system for long because of space limitations. Material may be removed from

the system in as little at three days, whether or not a linguist has reviewed it.

Once material is removed from the local network, it is stored, or archived, so it

can be reviewed later. However, information about who reviewed the material

is not retained in this archiving process, though material that has been

archived can be retrieved. The FBI attempts to ensure that reviewed material is

removed before un reviewed material. A senior LSS supervisor told the OIG that

a "conscientious" supervisor can "protect" unreviewed material by specially

marking it so that it will not be deleted from the system.6

Documents created by linguists are automatically shifted from an

individual linguist's computer directory to the agents' computer directory on a

scheduled basis. A linguist can prevent a document from being automatically

moved only by taking steps to prevent this automatic feature from activating.

General training for linguists is handled by LSS, not by the agents the

linguists will be assisting. The linguists are assigned to assist the Special

Agents with respect to the subject matter of their cases. The Special Agents

instruct the linguists as to what they do and do not want them to translate. A

Special Agent told the OIG that he also briefs the linguists on guidelines they

need to know to do their work. This Special Agent said that, for the first six

months to a year, he does not expect much from the linguists because they are

still learning what is important and how to do the work.

6 This senior supervisor noted that if a linguist is out of the office when material is

removed, the linguist may not even be aware of the removal. He described this as a "huge problem."

7
c. FBI Security Procedures

Linguists must obtain security clearances to work for the FBI. Edmonds

and the co-worker went through this process. The adequacy of the co-worker's

securi ty review was a significant issue in this case.

1. Personnel Security Interview

In addition to completing the required forms for a national security

position, an individual whose background is being investigated by the FBI must

undergo a PSI.7 According to the instructions on the SF-86, the interview is an

"opportunity to update, clarify, and explain information on your form more

completely." According to the FBI's Manual of Investigative Operations and

Guidelines (MIOG), the interview must be conducted at the "inception of the

[background] investigation with the purpose of obtaining information to

facilitate our investigative efforts," and "to ensure that complete (current and

accurate) information is available concerning the candidate." MIOG, Part 2,

Section 17-5.6.

According to the MIOG and a relevant FBI Electronic Communication

(EC), areas to be covered in the background investigation include personal and

business credit issues, denials and dismissals from employment, business

circumstances that could lead to conflict-of-interest allegations, membership or

involvement in organizations that are discriminatory and organizations that

advocate activities against the interest of the United States, and concealment of

any activity that could be used to compromise the applicant or have an adverse

effect on their character. MIOG, Part 2, Section 17-5.6.

2. Pre-employment Polygraph

All applicants for employment with the FBI, including CLs, also must

undergo a pre-employment polygraph examination. Manual of Administrative

Operations and Procedures (MAOP), Part 1, Section 22-9.1. The examination

focuses on national security issues, use or sale of illegal drugs, and

completeness of the Application for Employment. MIOG, Part 2, Section 13-

22.12. An expanded polygraph examination may be requested regarding any

national security concerns remaining after the PSI.

7 Not all federal agencies use the FBI to conduct background investigations. However,

because the FBI conducts background investigations on Contract Linguists such as Edmonds

and the co-worker, this section addresses the FBI policies and procedures for conducting

background investigations on its applicants and employees.

8
3. Security Clearance

The LSS conducts the background investigation and the pre-employment

polygraph to ensure that the candidate is suitable for employment. The

applicant's file is then passed to the Initial Clearance and Access Unit (ICAU) in

the Personnel Security Section within the FBI's Security Division.8 ICAU's

function is to determine if the applicant will be granted a security clearance.

The adjudicators within ICAU may request that a risk assessment be

performed. A risk assessment is meant to address any security concerns that

surface during the applicant's background investigation, including those that

might indicate the applicant's vulnerability to coercion.

The risk assessment is initiated by sending a lead to the relevant

operational division at FBI Headquarters.9 A Special Agent or analyst who has

the expertise for that specific area completes the risk assessment. According to

the ICAU Unit Chief, the decision to conduct a risk assessment for an applicant

depends on the specific circumstances of the case.IO He stated that as of

March 2004, risk assessments are completed for approximately 95 percent of

applicants for CL positions.

If the ICAU determines that a potential contractor should be granted a

security clearance, a Security Officer gives that person a security briefing.II

The purpose of the briefing is to inform individuals that they may not disclose

sensitive or classified information obtained while working for the FBI, and to

inform the individuals of the consequences for unauthorized disclosure.

At the briefing, new contractors sign a Security Acknowledgement Form

in which they acknowledge that they understand the information provided in

8 Before the creation of the Security Division in December 2001, these duties were

performed by the Industrial Security Unit within the FBI's National Security Division.

9 When an FBI field office needs assistance or information from another office or from

FBI Headquarters, it "sets a lead" for the assistance. Leads are initially written out in ECs,

hard copies of which are mailed to the appropriate offices.

10 Throughout this report, individuals are identified using the title they held at the time

of the event or action under examination.

11 The Special Agents who serve as Security Officers are responsible for processing

administrative paperwork for FBI employees, contractors, and others who need security

clearances, country clearances, and travel warnings. They also pass clearances to other

organizations. The Security Officer also provides security briefings and covers leads for

background investigations.

Security Officers also conduct investigations of reported and suspected security

violations. The types of violations they investigate include using home computers to process

classified information, processing Top Secret information on the internal FBI Secret network,

unauthorized access to FBI files, and sharing computer passwords.

9
the briefing and agree to adhere to instructions printed on the form for

handling classified information. They also sign a Classified Information

Nondisclosure Agreement. The Agreement is an II-point agreement between

the individual and the United States government stating that the individual

possesses a security clearance for access to classified information, has been

briefed about security responsibilities, and will not improperly divulge

classified information. The Agreement also sets forth the potential

punishments for improperly divulging classified information. Until the form is

signed, the individual does not have clearance and cannot have access to

national security information.

IV. THE OIG'S EXAMINATION OF EDMONDS' ALLEGATIONS AGAINST A

CO-WORKER

In this section, we examine the allegations Edmonds made against her

co-worker. In the classified version of the report, we fully described and

evaluated the evidence underlying nearly a dozen separate allegations

Edmonds made regarding the co-worker which, when viewed together,

amounted to an accusation against the co-worker of possible espionage. With

respect to each individual allegation, we analyzed the facts supporting or

refuting the allegation. We did not attempt to reach a definitive conclusion on

the truth of each allegation or whether the implication of espionage was

supported. Rather, given the available evidence, we assessed whether the FBI

treated each allegation appropriately. Because the facts underlying each

allegation remain classified, we cannot include our detailed description and

analysis of each individual allegation in this unclassified summary. Instead,

we describe our evaluation of Edmonds' allegations in general terms.

We found that many of Edmonds' core allegations relating to the coworker were supported by either documentary evidence or witnesses other than

Edmonds. Moreover, we concluded that, had the FBI performed a more careful

investigation of Edmonds' allegations, it would have discovered evidence of

significant omissions and inaccuracies by the co-worker related to these

allegations. These omissions and inaccuracies, in turn, should have led to

further investigation by the FBI. In part, we attributed the FBI's failure to

investigate further to its unwarranted reliance on the assumption that proper

procedures had been followed by the FBI during the co-worker's hiring and

background investigation, which did not include a risk assessment, contrary to

FBI practice. We also found that Edmonds was justified in raising a number of

these concerns to her supervisors. For example, with respect to an allegation

that focused on the co-worker's performance, which Edmonds believed to be an

indication of a security problem, the evidence clearly corroborated Edmonds'

allegations.

10
With regard to some of Edmonds' allegations, the OIG did not find

evidence to support her allegation or the inferences that she drew from certain

facts. However, Edmonds' assertions regarding the co-worker, when viewed as

a whole, raised substantial questions and were supported by various pieces of

evidence. While there are potentially innocuous explanations for the coworker's conduct, other explanations were not innocuous. Although the exact

nature and extent of the co-worker's security issues are disputed, it is clear

from the OIG's investigation that the facts giving rise to Edmonds' concerns

could have been uncovered had the FBI investigated Edmonds' allegations

further. We believe that the FBI should have investigated the allegations more

thoroughly. We also believe the FBI's handling of these allegations reflected an

unwarranted reluctance to vigorously investigate these serious allegations or to

conduct a thorough examination of Edmonds' allegations. As will be discussed

in the next section, the FBI did not, and still has not, conducted such an

investigation.

Finally, as we discuss in Part V, rather than investigate Edmonds'

allegations vigorously and thoroughly, the FBI concluded that she was a

disruption and terminated her contract. We concluded that the FBI could not

show, by clear and convincing evidence, that it would have terminated

Edmonds' services absent her disclosures.

v. FACTUAL CHRONOLOGY RELATED TO EDMONDS' ALLEGATIONS

AGAINST A CO-WORKER

In this section of the report, we provide a chronological summary of

relevant events and issues pertaining to Edmonds' allegations against the coworker.12 We also examine the FBI's handling of the allegations against the coworker.

A. Edmonds' Initial Allegations

Edmonds began contract work at the FBI on September 20, 2001. At her

request, she worked part-time for approximately 20 hours per week. Edmonds

initially was assigned as a CM, and shortly thereafter as a CL. Edmonds and

her colleagues were assigned to assist agents with translations on various

operational matters.

Toward the end of 2001, Edmonds became suspicious of a co-worker for

various reasons. In Edmonds' view, information she learned about the coworker's background, coupled with certain of the co-worker's actions with

12 This version of the report uses male pronouns throughout for individuals who are

not named, regardless of gender.

11
regard to the co-worker's work at the FBI, raised a security concern. Edmonds

told the OIG that a series of events in December 2001 and January 2002

formed the initial basis for her complaints to her supervisors and to the OIG.

First, Edmonds told the OIG that her conversations with the co-worker and her

observations of the co-worker's conduct made Edmonds uneasy about the coworker from a security standpoint. Edmonds also told the OIG that in early

January 2002, she saw documents that increased her suspicion about the coworker. Also in early January, according to Edmonds, documents began to

disappear from her work space, and she became suspicious due to revisions in

the distribution of work assignments that recently had been implemented. On

January 22,2002, Edmonds documented some of her concerns and provided

them to her supervisor. As a result of Edmonds' written concerns, on January

25, 2002, meetings were held to address the issues she raised. After the

meetings, the FBI took a number of steps in response to the information

Edmonds had provided. In addition, although her Language Supervisor told an

FBI manager about the allegations, no one reported the matter to the Security

Office at that time.

We concluded that the actions taken by the FBI after Edmonds raised

concerns in writing on January 22,2002, and orally on January 25,2002,

were insufficient and did not address fully the concerns raised. Moreover, we

found that the approach taken by the FBI in response to Edmonds' allegations

compromised, in certain respects, its opportunities to investigate further.

Several FBI witnesses told the OIG that allegations suggesting potential

espionage by one FBI employee against another are exceedingly rare. This

allegation was extremely serious - even if the evidence was not clear. Once

Edmonds submitted her detailed written complaints about her colleague, a

sufficient basis existed to justify a thorough inquiry by the FBI. However, as

will be described below, the FBI's inquiry was seriously deficient. 13

B. Edmonds Documents Additional Complaints in a February 8

Memorandum Written on Her Home Computer

In the two weeks following the January 25 meetings, Edmonds made

additional complaints, including assertions that the co-worker was being

13 As demonstrated by the espionage of former FBI Agent Robert Hanssen, the FBI

must take seriously allegations suggesting security,breaches, even if the evidence is not c1earcut. The Hanssen case demonstrates that an individual reporting a security-related concern

about another employee may not have the whole story, but may provide sufficient information

to focus attention on a person deserving of further scrutiny. See the OIG's report entitled "A

Review of the FBI's Performance in Deterring, Detecting, and Investigating the Espionage

Activities of Robert Philip Hanssen," August 2003. It is available on the OIG's website at

http://www.usdoi.gov/oig/ speciall0308/final.pdf.

12
protected inappropriately by a supervisor. 14 Edmonds also alleged that the coworker threatened her. Ultimately, Edmonds was asked to provide the details

of her complaints in writing. Edmonds asked if she could write them up at

home due to her concerns about items being removed from her computer, and

the Language Supervisor agreed to the request. Using her home computer,

Edmonds wrote a memorandum about her complaints dated February 8, 2002.

Edmonds provided the memorandum to the Language Supervisor on

February 9, 2002. That day, the Language Supervisor sent a copy of the

memorandum to the Chief of the LAAU. Initially, the Language Supervisor

expressed no concern to the LAAU Chief about whether Edmonds'

memorandum contained any classified information, nor did the Language

Supervisor indicate that he would contact the Security Office. The Language

Supervisor explained to the LAAU Chief that a copy of Edmonds' memorandum

was provided to others for response. In addition, the Language Supervisor

spoke to the Special Agent who Edmonds assisted and asked him to conduct

some follow-up on Edmonds' memorandum. In addition, the Language

Supervisor decided to begin supervising Edmonds directly. The Language

Supervisor also notified his superior about Edmonds' allegations.

The OIG found problems with the manner in which the FBI initially

handled Edmonds' February 8 memorandum. In response to Edmonds'

February 8 memorandum, the Language Supervisor provided a copy to a

person (other than the co-worker) who was discussed in the memorandum, for

his response, even though this created a risk that the investigation could be

compromised. In addition, the Language Supervisor spoke to the Special Agent

who Edmonds assisted and asked him to conduct certain follow-up, although

this also could have compromised any investigation. Edmonds had raised an

extremely serious allegation that deserved to be handled more carefully. The

Language Supervisor's requested follow-up action was not a prudent step,

given the possible consequences if Edmonds' allegations were true.

c. Security Office Investigation

On February 11, 2002, the Language Supervisor gave a Security Officer a

copy of Edmonds' February 8 memorandum and called his attention to the

security concerns related to the co-worker. The Security Officer told the OIG

that the Language Supervisor stated that Edmonds had included some

classified information in the memorandum that she had written on her home

computer. The Security Officer was assigned to investigate the matter.

14 The OIG's examination of FBI records did not substantiate the allegation that the coworker was being inappropriately protected.

13
On February 12,2002, the Security Officer interviewed Edmonds.

Edmonds told the Security Officer she had written the memorandum on her

home computer because of her concerns about documents being taken from

her office, and said she had done so with the Language Supervisor's

permission. Edmonds acknowledged that her husband used the home

computer for work, including faxing documents and sending e-mail. Edmonds

said that her husband did not look at her documents. Edmonds also repeated

her concerns about the co-worker to the Security Officer.

The Security Officer told the OIG that he believed Edmonds was credible.

The Security Officer said that based on this interview, he was primarily

concerned about two things: Edmonds' allegation that she was threatened by

the co-worker and the fact that classified information was on Edmonds' home

computer.

The next day, the Security Officer interviewed the co-worker. The

Security Officer asked the co-worker questions pertaining to the allegations

raised by Edmonds, and the co-worker denied Edmonds' allegations. The

Security Officer told the OIG he also found the co-worker to be credible, which

he said undermined his confidence in Edmonds. However, we found the

Security Officer did not challenge the co-worker with respect to any information

the co-worker provided, although that information was not consistent with FBI

records. In addition, while the Security Officer reviewed some records, he did

not review other crucial FBI records, which would have supported some of

Edmonds' allegations.

On February 13, with Edmonds' consent, the FBI seized her home

computer. That same day, Edmonds also wrote to a higher-level FBI official

about her allegations and requested to meet with him regarding her concerns.

On February 14, the Security Officer observed while a member of the

FBI's Computer Analysis Response Team analyzed Edmonds' computer to

determine what information had been processed on it. The Security Officer

said that there appeared to be another version of the February 8,2002,

memorandum on the computer. The FBI removed the classified information

from the computer and returned the computer to Mr. Edmonds on

February 15.

On February 20, the Security Officer conducted an interview of a

potential witness to the co-worker's alleged threat to Edmonds. After the

interview, the Security Officer reported up his supervisory chain that he

believed that Edmonds' allegations were unfounded. This assessment was, in

turn, reported to a manager higher up the supervisory chain.

On February 25, the Security Officer requested polygraph examinations

of Edmonds and the co-worker in connection with this matter.

14
We concluded that once the Security Officer was notified on February 11

of Edmonds' potential security violation, he took swift action with respect to the

security violation Edmonds committed. The Security Officer quickly took

custody of Edmonds' home computer and analyzed it. The Security Officer also

deleted classified information from the computer and returned the computer to

Edmonds.

By contrast, we believe that the Security Officer's investigation of

Edmonds' claims against the co-worker was significantly flawed. The Security

Officer neither adequately prepared for nor adequately followed up on

information obtained during the course of the investigation. The Security

Officer also failed to memorialize adequately crucial information derived during

the course of the investigation. While an investigator's impressions of the

witnesses are significant in any investigation, in this case the absence of any

effort by the Security Officer to corroborate information provided by witnesses

with independent evidence suggests that he relied unduly on his subjective

impressions of the witnesses.IS Moreover, the Security Officer over-relied on

the absence of corroboration of the threat allegation, which the Security Officer

believed to be the most serious aspect of Edmonds' allegations. This

overreliance resulted in a premature conclusion that Edmonds' security

concerns lacked merit.

In addition, the Security Officer failed to perceive as a security issue

what he considered were merely performance issues. He did not, therefore,

adequately address these issues and, as will be discussed later, deferred to

others completely for an evaluation of this aspect of the case. We believe it was

the Security Officer's responsibility to gather all the facts related to these

allegations, many of which the Language Supervisor would not have known,

and it was inappropriate for the Security Officer to defer to the Language

Supervisor or others on certain critical questions.

In sum, the Security Officer conducted a superficial investigation that

focused almost entirely on Edmonds' allegation regarding a threat to her. The

Security Officer seemed not to appreciate or investigate the allegation that a coworker may have been committing espionage. Nor did the Security Officer refer

the allegations of potential espionage elsewhere in the FBI. The Security

Officer told the OIG that he believed, based on the amount of evidence at hand,

a referral would have been pointless. Our review revealed that a thorough

investigation by the Security Office would have shown otherwise.

15 In an e-mail dated February 14, 2002, three days after the Security Office was

notified of these allegations, the Language Supervisor wrote that it was his opinion and the

opinion of the Security Officer and the Special Agent who Edmonds assisted that Edmonds was

trying to get the co-worker "fired." The Security Officer denied expressing that opinion by that

date.

15
D. Follow-up by the Language Supervisor

On February 14, the Language Supervisor sent an e-mail to the LAAU

Chief and another FBI manager providing an update on the case. In the

e-mail, the Language Supervisor asserted that there was no basis for Edmonds'

concerns. In response to the Language Supervisor's e-mail, the LAAU Chief

wrote an e-mail dated February 15 stating that he was "still concerned" about

Edmonds' allegations. The LAAU Chief stated that crucial FBI records (those

that the Security Officer never personally reviewed) did not resolve a significant

aspect of Edmonds' allegations. He asked that the matter be looked into

further. He also urged that the matter be addressed quickly and fairly to avoid

losing any "precious linguistic resources" due to "morale problems." ,

On February 21,2002, the Language Supervisor sent an FBI manager

and the LAAU Chief an EC summarizing his actions in connection with

Edmonds' allegations. In the EC, the Language Supervisor stated that the

security allegations related to the co-worker had been referred to the Security

Office. With respect to some of Edmonds' allegations, the Language Supervisor

wrote that the matter would be addressed by him and others in his office as a

"performance and management issue." The Language Supervisor added that it

could be a "training issue" and that language translators had voiced concerns

about their inadequate training. He stated that he would hold appropriate

persons responsible for any problem of that nature and he would continue to

address the matter in a mid-year performance review. In addition, the

Language Supervisor described his efforts to determine whether certain of

Edmonds' other allegations were true.

The Language Supervisor also stated in the EC that he had put Edmonds

under his supervision. In addition, he wrote that on February 11 Edmonds

told him that she was considering going public and bringing criminal charges.

Finally, the Language Supervisor reported that on February 19, despite the fact

that Edmonds was told that the matter was being investigated and she should

be patient, Edmonds said she had retained a lawyer and had written letters to

"high level" officials within the FBI. The Language Supervisor said he

cautioned Edmonds on both occasions not to reveal classified information.

E. Edmonds Meets with FBI Management

On February 22, Edmonds met with FBI management. An FBI manager

told the OIG that his purpose in holding the meeting was to try to reduce

Edmonds' anxiety and to find out from her if there were other facts that would

support her allegations. He said he told Edmonds that the Security Office

investigation had not borne out the most serious aspect of her security

concerns. He said he explained to Edmonds that he had also contacted others

within the FBI and no basis for that aspect of her security concerns existed. At

16
the meeting, Edmonds asked this manager to put his statements to her in

writing. He declined.

Edmonds described this meeting to the OIG as confrontational and

hostile. The FBI manager denied that and said his impression of Edmonds

after the meeting was that she was "very bright" and "aggressive." He said that,

at the time, he did not believe she was fabricating her allegations. Immediately

after the meeting, however, the manager began to explore whether the FBI had

the option to cease using Edmonds as a CL.

F. Follow-up by the Special Agent who Edmonds Assisted

On February 26, an FBI Special Agent wrote an EC analyzing the

additional information the Language Supervisor had requested as a result of

Edmonds' allegations of deficient performance by the co-worker. The Special

Agent believed that a remedial measure would adequately address the

performance aspect of Edmonds' allegations. The remedial measure was then

implemented. No other action was taken as a result of the review. However,

the remedial measure was rescinded, at the request of this Special Agent, less

than three weeks later, and Edmonds questioned the decision to rescind the

remedial measure.

G. Polygraph Examinations

The Security Office decided that polygraph examinations would be

helpful in making determinations about Edmonds' security allegations and the

security violation committed by Edmonds. In a four-page request for

polygraphs, drafted on February 25, 2002, the Security Officer stated that

"preliminary investigation" indicated that the co-worker had not made any

threats to Edmonds, but the polygraph was needed to thoroughly pursue these

issues and determine whether or not the co-worker posed a security risk. The

Security Officer also noted that "preliminary investigation" indicated that

Edmonds had written, on her home computer, multiple memoranda containing

classified information, had retained an attorney, and had threatened to go to

the press. The Security Officer asked that a polygraph be conducted of

Edmonds to determine whether she had written additional memoranda on her

home computer or whether she released classified information to unauthorized

parties. 16

16 Once Edmonds was notified of the polygraph, she began writing letters to FBI

managers requesting a written explanation of why she was being polygraphed and what

questions she would be asked. The FBI declined to provide her with anything in writing on

that subject.

17
Based on the Security Officer's request of February 25, which was

approved by the FBI, polygraph examinations of Edmonds and the co-worker

were scheduled for March 2002. The Chief of the FBI's Polygraph Unit

e-mailed an FBI manager to say that the focus of the polygraph examinations

would be to determine if classified or confidential material had been passed to

any unauthorized individuals. He also stated that the polygraph examinations

would focus on broad security concerns, rather than the threat that had been

alleged by Edmonds.

On March 7, the day before her polygraph, Edmonds met with a higherlevel FBI official who listened to Edmonds repeat her allegations and then

thanked her for the information. This official then contacted a manager in

Edmonds' supervisory chain, who told the official that the matter was being

looked into by the FBI, including by the FBI's Office of Professional

Responsibility (OPR).17 The official with whom Edmonds met took no further

action.

On March 8, Edmonds took the polygraph examination. The polygraph

questions asked of her related to whether she had disclosed classified

information to unauthorized persons and whether she was maintaining

classified information outside FBI office space. She denied those charges, and

the polygrapher concluded that she was not deceptive in her answers.

The co-worker was polygraphed on March 21. The co-worker was asked

about her activities. The co-worker denied having engaged in inappropriate

activities. The polygrapher concluded that the co-worker was not deceptive in

these answers.

The Security Officer and other FBI managers later expressed

disappointment with the questions asked in the polygraphs. The Security

Officer said the questions were not responsive to the allegations raised by

Edmonds. An FBI manager said that the polygraphs should have been

"customized" to obtain optimal results and that he was hoping the polygraphs

would be more conclusive in the investigation of these allegations. The Chief of

the Polygraph Unit later told the analyst that more precise questions could

have been asked.

We also concluded that the polygraph examinations of Edmonds and the

co-worker were not ideal. In addition, we found that despite the concerns

about the polygraph, the FBI never considered doing any additional polygraphs

17 That same day, Edmonds contacted FBI OPR and the OIG to report her allegations.

Because the OIG opened its investigation shortly after FBI OPR was contacted, FBI OPR did not

pursue the matter further.

18
and continued to rely on the polygraph as support for its position that

Edmonds' allegations were unfounded.

H. Additional Complaints

Between February 8 and March 22 (the day the FBI stopped using her

services), Edmonds' relationship with FBI management deteriorated

significantly. By the end of February, the Language Supervisor was becoming

increasingly frustrated with Edmonds' allegations. For example, on March 5

the Language Supervisor began taking detailed notes of all his interactions with

Edmonds.

At the same time, Edmonds seemed to become increasingly frustrated.

In addition to meeting frequently with the Language Supervisor about her

suspicions, Edmonds wrote numerous e-mails and memoranda raising

additional complaints. Edmonds also warned the Language Supervisor of the

penalties for retaliation against a Whistleblower. Edmonds also requested

information about any allegation made against her. The Language Supervisor

declined to provide the information requested by Edmonds.

On March 8, Edmonds complained that work she had been asked to

translate had not been loaded properly onto her computer, and that FBI

Special Agents had been waiting for the translations for three weeks. The

Language Supervisor responded that since February 22, 2002, Edmonds had

only worked one day, on March 8,2002. The Language Supervisor also stated

that Edmonds did not indicate which work she was referring to until March 5,

2002, when she was in the office briefly. In response, Edmonds repeatedly

complained to the Language Supervisor about the fact that she never was

provided information about the polygraph or the allegations against her.

On March 15, the relationship between the Language Supervisor and

Edmonds became even more tense. Edmonds asked the Language Supervisor

why the Special Agent who she assisted had not been in contact with her in

over a month. Edmonds also inquired about her work assignments. The

Language Supervisor responded that he did not know why the Special Agent

had not met with Edmonds and that, due to Edmonds' limited work hours and

the need to have certain work assignments completed, he had requested that

linguistic resources be reallocated. In response, Edmonds stated that in the

past few weeks, "coincidental" to her reports of wrongdoing, she had received

no new assignment and no offers of temporary duty (TDY) assignments.

Later that day, the Language Supervisor informed Edmonds that he

would not submit for payment an invoice of Edmonds' that included 5.25 hours

spent in meetings related to her allegations. Before advising Edmonds that he

would not submit the invoice, the Language Supervisor consulted with the FBI

contracting office and was told that CLs are paid only for "actual hours

19
worked." Edmonds ultimately disputed this decision, and the FBI relented and

paid her for the time.

Also on March 15, Edmonds made a claim to the Language Supervisor

about time and attendance abuse by the co-worker. The Language Supervisor

subsequently found no abuse, but sent out an e-mail reminding the linguists to

sign out as they leave for the night, rather than annotating it the next day.

In addition, Edmonds reiterated a number of her security concerns and

asserted that she was being obstructed and retaliated against for her

complaints. She also alleged that documents had "disappeared" from the

location where she kept her work papers. The Language Supervisor asked for a

list of the missing items. Edmonds requested a secure location for her

documents, commenting that requiring her to keep her documents in a location

accessible by those whom she had accused of wrongdoing ~as ridiculous.

Edmonds also wrote that the Language Supervisor had told her that the

Special Agent was unhappy with her performance and personality and he did

not want to deal further with Edmonds. Edmonds requested a IS-minute

meeting with the Special Agent and the Language Supervisor to iron out any

issues and re-establish a proper working relationship.

In a lengthy EC the Language Supervisor wrote on March 19 to an FBI

manager and the Security Office, the Language Supervisor denied ever telling

Edmonds that the Special Agent was unhappy with her work. However, the

Language Supervisor also said that the Special Agent would not meet with

Edmonds because he had been instructed not to do so due to Edmonds'

fabrications.

On March 19, a Supervisory Special Agent wrote that he did not want to

use Edmonds' translation services anymore because she had been a complete

disruption to the office, often making groundless accusations. The Supervisory

Special Agent said that he already had devoted too much time to the matter,

and he had lost faith in Edmonds' ability to carry out her assignments. He

cited her security violation and recommended that Edmonds be removed from

working his assignments in light of security concerns and some other "agenda"

she was pursuing.

Tension between Edmonds and her colleagues also increased during this

period. On March 20, the Language Supervisor noted that he had to act as an

intermediary of behalf of Edmonds with others due to these tensions. The

Language Supervisor also expressed frustration with Edmonds' impatience at

the time it took to resolve her allegations, writing that Edmonds did not seem

to the Language Supervisor to understand that he had more pressing issues to

deal with at times.

20
Edmondsagain wrote to the Language Supervisor on March 22 alleging

that the co-worker had cheated on the co-worker's timesheet. In fact, the coworker was out of the office for her polygraph examination during the time

period Edmonds questioned. The Language Supervisor told Edmonds via

e-mail that Edmonds did not have all the facts and instructed Edmonds not to

mark on anyone's time sheet but her own.

I. FBI's Decision to Stop Using Edmonds' Services

As described above, after the February 22 meeting with Edmonds, an FBI

manager began inquiring about the FBI's options with respect to the "use/nonuse" oflinguist contractors. On February 26, the FBI Contracting Officer for

the General Contracting Unit of the Finance Division informed this manager

that, if it was determined that a CL was "unsuitable," the FBI would have

sufficient reason to terminate her contract.

By March 20, the FBI manager had drafted an EC recommending that

his office discontinue using Edmonds' services. In the introductory paragraph

he mentioned that Edmonds had raised issues concerning security,

performance, and favoritism. Without further discussion of Edmonds'

individual allegations, he wrote that the Security Office's inquiry had concluded

that some allegations of Edmonds were not substantiated and that she had not

been completely forthcoming about the extent of the sensitive and classified

information on her home computer. In the EC, the manager said he found it

most telling that Edmonds had written to other high-level FBI officials nine

days before his first meeting with her, and he commented that Edmonds

seemed inclined to put forth additional complaints, as the discussion

continued, that were not mentioned previously. He wrote that she had a

propensity to inflate and misstate facts, and he described the tone of her letters

to the Language Supervisor as condescending and somewhat threatening. The

manager also noted in the EC his frustration at the pace of efforts by the

Security Office to resolve the matter in a clear-cut manner [i.e., to revoke

Edmonds' security clearance]. He remarked that Edmonds was using her

newly claimed whistle blower status as a "club" against her supervisors. He

concluded that no action taken by his office would be satisfactory to Edmonds.

He recommended that LSS immediately discontinue using her as a linguist,

and that her FBI access badge be cancelled and taken until "this situation" was

resolved. The manager e-mailed the draft of his EC on March 20 to the LAAU

Chief and others.

The following day, the FBI manager issued the final EC, which was

substantially less harsh in tone, and to which he had added the statement that

Edmonds had a "disruptive effect" on operational matters. The final EC also

omitted the manager's earlier comments that Edmonds was not completely

forthcoming about the extent of the sensitive and classified information on her

home computer, that she had a propensity to inflate and misstate facts, and

21
that she was using her Whistleblower status as a "club." He also removed the

comment he had made about her appeals to other FBI officials.

The final EC also contained additional recommendations. First, the

manager recommended that Language Supervisors and higher-level Security

officials be apprised of the actions being taken. Second, he recommended that

Edmonds be debriefed regarding her future responsibility not to disclose

classified information and the criminal penalties that apply to such

disclosures, and that her clearance be re-adjudicated. Third, he recommended

that the Security Office complete its pending investigation and refer any

findings for administrative or disciplinary action, or for further substantive

investigation.

On March 22, FBI managers met with Edmonds and told her that her

services would no longer be used by the FBI. One manager reminded her of the

requirements of the Security Acknowledgement Form. Edmonds told the OIG

that the meeting was hostile and that one manager threatened her with jail.

FBI managers denied that the meeting was hostile or that Edmonds was

threatened with jail. 18

Prior to being escorted out of the building, Edmonds gave the Language

Supervisor and Security Officer a memorandum that documented additional

performance problems related to the co-worker, which Edmonds considered to

be additional support for her underlying security concerns. 19

Edmonds was then escorted out of the building by FBI personnel and her

access badge was taken.

J. Security Office's Damage Assessment

Shortly after her termination, additional allegations of security violations

were made against Edmonds, including an allegation that Edmonds had

discussed classified information outside the FBI with unauthorized persons at

a social setting, and that Edmonds put a copy of the March 22 memorandum

she gave to the Language Supervisor into an envelope for delivery to the OIG

18 When the GIG asked the manager whether anyone at any time during the meeting

told Edmonds she could go to jail, he said he thought it was implied in the Security

Acknowledgement Form. However, he denied telling Edmonds, as she alleged, that the next

time they saw her it would be in jail. Another manager denied that there was any discussion of

Edmonds possibly going to jail.

19 The Language Supervisor subsequently requested verification of the facts Edmonds

put into this memorandum. The follow-up confirmed that Edmonds' description of the facts

was accurate, but the Language Supervisor took no further action.

22
and OPR, although neither the memorandum nor the envelope contained the

required classification markings.

On March 26, the Security Officer drafted an EC with the heading,

"Damage assessment conducted and provided to FBIHQ regarding the

processing of classified information on the home computer of a contract

linguist." He recommended revocation of Edmonds' security clearance. The

Security Officer wrote that the Security Office considered it a threat to national

security to continue to allow Edmonds access to classified information.

The Security Officer's EC was not finalized until May 2,2002, because he

and his supervisor disagreed about its contents. According to the Security

Officer, the supervisor took the position that Edmonds' security clearance

should be "re-adjudicated" by the proper authorities at FBI Headquarters. The

final version of the EC stated that the Security Office "questions" Edmonds'

trustworthiness with sensitive national security information, based on her

having processed classified information on her home computer and because

she was seen putting a memorandum containing classified information into an

envelope for delivery to the OIG and OPR, without the proper markings. The

EC recommended that she not be used for classified translation duties with the

FBI and that her clearance be re-adjudicated.2O

K. SubsequentReview by FBI Security Officials

In May 2002, after the media and Congress began making inquiries

about Edmonds' allegations, the Section Chief of the Personnel Security

Section in the FBI Security Division asked one of his unit chiefs to take a look

at this matter. The unit chief assigned an Investigative Analyst Consultant

with the Security Division to gather information about the case.

During the course of the analyst's work, he wrote two memoranda. The

first, written June 4,2002, stated that Edmonds had been "suspended" and

that she had committed three security violations: the two classified

memoranda written on her home computer (the February 8 memorandum and

the memorandum found during the analysis of Edmonds' computer) and the

discussion of classified information outside the FBI with unauthorized persons

at a social setting. However, the analyst's memorandum noted that she was

not fired for security reasons and her clearance had not been revoked. The

memorandum then summarized the allegations against Edmonds, Edmonds'

allegations against the co-worker, and the Security Officer's investigation.

20 The Security Office's May 2 EC recommending re-adjudication of Edmonds' clearance

failed to point out that the polygraph results undercut the claim that she had discussed

classified information outside the FBI with unauthorized persons at a social setting.

23
The analyst conducted additional investigation and found substantial

flaws in the Security Officer's investigation. In a second memorandum, dated

June 14, 2002, the analyst described the inaccuracies and flaws in the

Security Officer's investigation. As a result, another Security Officer

interviewed the co-worker again. The co-worker stated that the co-worker was

mistaken about some facts in the original interview, but the co-worker also

disputed the accuracy of a portion of the write-up of the initial interview.

The analyst's review also noted that the polygraphs were not as precise

as they could have been because the polygraphs focused on broad security

concerns, rather than the precise issues Edmonds had raised. The analyst

reported that the Polygraph Unit Chief admitted that questions directly on

point could have been asked but were not. However, the Polygraph Unit Chief

asserted to the analyst that the more generic question "would have elicited a

discernible reaction."

Despite the fact that the analyst's review unearthed these problems with

the Security Officer's investigation, FBI Security officials did not request any

further review or re-investigate Edmonds' allegations.21 We found that the

analyst's review revealed substantial infirmities in the Security Officer's

investigation at that time. Nevertheless, higher-level FBI Security officials

failed to initiate a more thorough investigation. As noted above, we believe

ample basis existed for such a review.

In sum, we believe the FBI's initial inquiries in response to Edmonds'

allegations were seriously deficient. Had they been more thorough, an

appropriately focused analysis could have been conducted much earlier.

Moreover, even when the FBI was notified of additional information, the FBI

still did not promptly document and act on the information provided. The

remedial action taken to address one aspect of Edmonds' concerns was not

sufficiently thorough, and the FBI reversed itself prematurely. This was an

inadequate response under the circumstances.

We also note that, at the time of these events, the FBI had no protocol for

the receipt and investigation of derogatory information provided by someone

within the FBI about a co-worker. In May 2002 (after Edmonds was

terminated), in response to the Hanssen case, the FBI created a new

counterespionage section, CD-4, to investigate allegations of espionage,

including all allegations of penetrations of the U.S. Government. According to

21 The analyst's two memoranda later were used as the basis for talking points provided

to the head of the Security Division, who briefed several Congressional staff members about the

Edmonds case on June 17, 2002. The briefing was unclassified because a staffer at the

briefing lacked the appropriate security clearance. During the course of the briefing, the

Security Section Chief inadvertently revealed what the FBI considered to be classified

information.

24
the Chief of CD-4, however, if Edmonds' allegations were made today, they

might still be investigated by the Security Office. But he said that at a

minimum the Security Office should consult with CD-4 during the

investigation.

VI. OTHER ALLEGATIONS

Edmonds made additional allegations to the OIG regarding the foreign

language translation program. She claimed, for example, that she was directed

to slow down the pace of her work so that material would pile up and the FBI

would have a basis to request more translators. Edmonds alleged that the FBI

hired an unqualified translator because of his connection to FBI Headquarters'

personnel and subsequently sent him to translate military interviews despite

his weak language skills. In addition, Edmonds claimed that travel voucher

abuse was condoned and that supervisors improperly received gifts from

subordinates. In our full report, we reviewed the facts and conclusions

regarding these and additional allegations. In this section, we briefly

summarize our core findings.

A. Alleged Slow Down of Work

Edmonds alleged that shortly after she began work for the FBI, linguists

were directed to slow the pace of their work so that the material to be

translated would "pile up" and the FBI would have a basis to request more

translators. Edmonds also said that she was reprimanded for working too

quickly. Edmonds provided the OIG with the names of several linguists whom

she believed had heard these instructions.

The persons supervising Edmonds denied ever telling Edmonds or any

other linguist to slow down so that more linguists would be hired. Instructions

to slow down, the OIG was told, only were given if a linguist's pace was

adversely affecting the quality of the linguist's work. The OIG was told that

such an instruction was never given to Edmonds because the quality of her

work was good.

The OIG interviewed ten linguists who were either named by Edmonds in

her allegations or were named by Edmonds as having information relevant to

her allegations, including those whom Edmonds specifically stated could

corroborate her allegation regarding the alleged instruction to slow down. Only

three of these linguists stated that they recalled hearing about the alleged

instruction to slow down. Two said they heard the allegation only from

Edmonds. The third said that she had heard about the slow down instruction

from others in addition to hearing about it from Edmonds, but said she could

not recall who those others were. The other seven denied ever hearing about

such an instruction.

25
We found insufficient evidence to substantiate Edmonds' allegation that

such time and attendance abuse was condoned or occurred. Moreover, given

the backlog of translation work at the FBI, we do not believe the FBI would

need to intentionally slow down the linguists' work to support hiring additional

translators.

B. Hiring and Assignment of an Unqualified Translator

Edmonds told the GIG that the FBI hired a contract monitor based on

the person's personal connections to the FBI, even though he had not scored

high enough on the language tests to qualify for the position. Edmonds also

questioned the fact that this CM was assigned to translate military interviews

despite weak language skills.

The GIG concluded that the CM was hired and assigned to translate

military interviews even though he did not meet the minimum passing score for

the position. The FBI took this action without following appropriate written

procedures, and without notifying appropriate officials who supervised the

CM's work, and in a manner that created the appearance of a conflict of

interest. Although the CM ultimately demonstrated that he could meet the

minimum requirements, we found that he clearly had difficulties with his

written translation work for the FBI. However, it appears that those

supervising the military interviews he helped to translate were satisfied with

his translation work.

c. Travel Voucher Fraud

Edmonds alleged that a supervisor made arrangements for two linguists

to "switch" work locations, at FBI expense. FBI travel records reflect that on at

least three occasions, two linguists who translate the same language did

"swap" work locations at FBI expense. These three "temporary duty"

assignments cost the FBI over $35,000 in travel reimbursements.

After initially asserting that the swap was necessary for proper coverage

of the translation work of the office, the FBI supervisor could not explain why it

was necessary to have both linguists travel at such expense, when the

translation work of the two linguists could have been moved from one location

to the other over the FBI's computer system. He provided to the GIG an EC in

which, he stated, his supervisor approved this arrangement. The document,

however, is dated many years earlier and refers to one 60-day temporary duty

assignment for a linguist who had been working on the same project years earlier.

Edmonds alleged that this "swapping" arrangement was due in part to

favoritism on the part of the supervisor. One linguist told the OIG that he had

26
also heard rumors of favoritism. The supervisor adamantly denied any

favoritism towards any of the linguists. No other witness stated that he heard

similar rumors, and the OIG found no other evidence of any such favoritism.

We believe that the arrangement was wasteful. At the time these two

linguists swapped places, other linguists were available to handle this work in

both locations. We do not believe the EC provided to us by the supervisor

applies to the time period in which we found evidence of wasteful travel.

Moreover, the supervisor provided no explanation for the failure to use the

FBI's computer system to send the work electronically between offices.

D. Additional Travel-Related Allegations

Edmonds made additional allegations related to misuse of travel

vouchers. She claimed, for example, that some linguists had gone to a distant

location to attend a concert and had been improperly reimbursed by the FBI for

this travel. She did not identify the particular linguists. The OIG examined

FBI travel records and found that only one linguist traveled at FBI expense to

the location of the concert during the relevant time period, but this linguist

stated that he did not attend the performance. We reviewed documentation

that supported this linguist's assertion that this was a legitimate business trip.

Edmonds also alleged that a supervisor traveled to particular cities at

FBI expense in order to attend a seminar, visit a sick relative, and visit other

family members. The OIG reviewed the supervisor's travel records dating back

to October 1, 1999, and found no trips to the cities mentioned by Edmonds.

Edmonds also claimed that when another linguist traveled to perform

translation work, a supervisor permitted him to stay through the weekend at

FBI expense so that he could do some personal shopping and bring items back

for the supervisor. FBI travel documents reflect that at the time Edmonds

made her allegations, the linguist in question had made two trips to the

location Edmonds cited, at FBI expense. On one of those trips, the linguist

stayed over on a Friday night and returned the next day. The FBI paid for the

hotel on Friday night. FBI records show that the linguist worked until 5:00

p.m. If he had returned that day, he would have arrived late in the evening.

He therefore stayed overnight and returned on Saturday. He acknowledged

buying gifts while he was on the trip to give to the supervisor and other friends

and co-workers.22 However, the linguist denied staying overnight on Friday for

the purpose of shopping for himself or the supervisor. The supervisor denied

sending the linguist on travel to shop. '

22 The gifts he purchased are discussed in the next section.

27
In sum, we found the allegations regarding travel for concerts, shopping,

or family visits were unsubstantiated.

E. Improper Receipt of Gifts by Supervisors

Edmonds alleged that FBI language supervisors received expensive gifts

from subordinates. The only specific example she provided to the GIG was

that, on his return, the same linguist who she said had been permitted to stay

on travel so that he could shop brought back sets of ladies' and men's watches

for the supervisors. Edmonds said the linguist had told her that the watches

cost him $135, and that the supervisor who approved the extension of the

travel asked the linguist to give the same sets of watches to the other

supervisors so that "no one will ever talk." Edmonds said that the linguist also

gave her a set of the watches, but she returned them.

The linguist told the GIG that he bought several sets of the watches while

he was on the trip, for $10 each, and that he gave the sets to Edmonds, three

supervisors, and a Special Agent. He denied telling Edmonds that the watches

cost $135, and denied saying that a supervisor instructed him to give the same

gift to other supervisors so that no one would talk.

The GIG was unable to determine the specific value of the watches, but

they do not appear to be expensive watches. We found that the same brand of

watches was advertised on the Internet for $4.90 per set. In addition, ajeweler

told the GIG that the watches do not contain a karat mark, indicating that they

do not contain any gold. The jeweler said that he had seen similar watches for

sale by street vendors. He estimated that the watches could be worth

anywhere from $20 to $100.

The GIG interviewed ten linguists and four supervisors who work in the

same office. None told the GIG that subordinates gave "expensive" gifts to

supervisors. Several witnesses stated, however, that linguists frequently gave

their supervisors and colleagues small food items or trinkets that they had

purchased while traveling on FBI business. A supervisor told the GIG that he

had received from the linguists under his supervision many such items,

including key chains, shot glasses, worry beads, brass plates, coffee mugs, a

clock, and a stone from the Berlin Wall. The supervisor told the GIG that he

always tells the linguists that he cannot accept a gift worth more than $20.

Another supervisor told the GIG that he had accepted small gifts from the

linguists because to refuse them would be a "cultural affront" and the linguists

are aware that the gifts must cost less than $10.

The FBI MAGP provides that a supervisor may not accept a gift from a

subordinate employee who receives less pay than the supervisor. A supervisor

may accept from subordinates voluntary gifts of a nominal value made on a

special occasion such as marriage, illness, or retirement. A supervisor may

28
also accept gifts worth less than $10 on "on an occasional basis, including any

occasion on which gifts are traditionally given or exchanged," such as holidays.

MAOP, Part 1, Section 13.1. This provision of the MAOP is the same as the

DOJ regulation prohibiting gifts from subordinates to supervisors.

5 C.F.R. § 2635.302 and 304.

We found insufficient evidence to substantiate Edmonds' allegation that

a supervisor received expensive gifts from subordinates. We also found that

the practice of giving gifts to supervisors was widespread in LSS, was not

limited to special occasions such as marriage, illness, or retirement, and

occurred on more than "an occasional basis." Although we found no proof that

supervisors received items worth more than $10 on any occasion, we believe

the commonplace acceptance of gifts from subordinates violates the FBI MAOP.

Indeed, the commentary to the DOJ regulation upon which the MAOP provision

is based specifically states that an employee "whose job responsibilities require

frequent travel may not bring her supervisor, and her supervisor may not

accept, souvenir coffee mugs from each of the cities she visits in the course of

performing her duties, even though each of the mugs costs less than $5. Gifts

given on this basis are not occasional." 26 C.F.R. § 2635.304(a), Example 2.

Accordingly, we believe the FBI should instruct supervisors and linguists to

stop the practice of supervisors accepting gifts from linguists.

F. Unauthorized Disclosure of Information to Congress

The OIG also received an allegation from the FBI of a possible

"unauthorized disclosure of classified information to a congressional staffer."

The OIG found that on June 17,2002, the Section Chief of the Personnel

Security Section in the Security Division conducted a briefing regarding

Edmonds' allegations for congressional staff members. Because one of the

congressional staff members present lacked the appropriate security clearance,

the briefing was unclassified. The Security Section Chief inadvertently used a

term which, according to the FBI, could have the effect of revealing classified

information. 23

We found that the Security Section Chiefs use of the term during the

briefing was inadvertent. However, we believe this incident demonstrates the

problems inherent in attempting to "talk around" classified information.

23 This briefing recently has become the subject of congressional complaints regarding

retroactive classification of information by the DOJ.

29
VII. EDMONDS' CLAIM OF RETALIATION

As described in this report, on March 22,2002, an FBI manager notified

Edmonds that her translation services would no longer be needed and took her

access badge from her. On April 2, the FBI sent a letter to Edmonds

terminating her contract as of March 26. Edmonds has claimed that her

termination was in retaliation for her raising allegations of misconduct to the

FBI.

Edmonds does not qualify for "Whistle blower" status under the FBI

Whistleblower regulations because she was a contractor, not an FBI employee.

See 28 C.F.R. § 27.1(a). However, in examining the question of whether the

FBI retaliated against Edmonds because of her allegations of misconduct, we

used the principles underlying these regulations.

Pursuant to these regulations, the FBI cannot take a personnel action

against an employee in retaliation for any "protected disclosure" the employee

has made. 28 C.F.R. § 27.2. For a disclosure to be "protected" under the

regulations, it must be made to the OIG, DOJ OPR, FBI OPR, the Attorney

General, the Director of the FBI, the Deputy Director of the FBI, or the highest

ranking official in any FBI field office. 28 C.F.R. § 27.1(a). In addition, the

employee making the disclosure must reasonably believe the disclosure

evidences a violation of law, rule, or regulation; mismanagement, a gross waste

of funds, an abuse of authority; or a substantial and specific danger to public

health or safety. 28 C.F.R. § 27.1 (a). The complainant has the burden of

showing by a preponderance of the evidence that her protected disclosure was

a contributing factor in the decision to take the personnel action. Once that

showing is made, the burden shifts to the agency to show by clear and

convincing evidence that it would have taken the personnel action against the

complainant in the absence of the protected disclosure. Id. at § 27.5(e)(2).

Edmonds' allegations would clearly qualify as protected disclosures

under the FBI Whistleblower regulations. Thus, the key issue would be

whether her disclosures were a "contributing factor" in the termination of her

services. Under the Whistleblower regulations, the FBI would have to prove by

clear and convincing evidence that it would have taken the same action absent

her disclosures.

We believe the evidence indicates that the FBI could not show, by clear

and convincing evidence, that at the time the decision was made it would have

terminated Edmonds' contract absent her disclosures. According to an EC

from an FBI manager that summarizes the reasons for terminating Edmonds'

services, the FBI's primary reasons were that she represented a "disruptive

effect" on operational matters and her "documented" mishandling of classified

information at her residence.

30
The mishandling of classified information on her home computer related

to Edmonds' writing, at her supervisor's request, a memorandum describing

her allegations of misconduct and including classified information in that

memorandum. However, a Security Official told the OIG that he did not believe

the Security Office had enough information to "fire" Edmonds based on her

security violation of processing classified information on her home computer.

Similarly, the Security Officer who conducted the investigation told the OIG he

did not view Edmonds' security breach as intentional and said the FBI did not

intend to pursue administrative charges against Edmonds for the violation.

Rather, the primary reason for the FBI's termination of Edmonds related

to the claim that she had a "disruptive effect" on operational matters. This

disruption related primarily to Edmonds' aggressive pursuit of her allegations

of misconduct, which the FBI did not believe were supported and which it did

not adequately investigate. In fact, as we described throughout our report,

many of her allegations had bases in fact and should have been more

thoroughly investigated by the FBI. We believe that the FBI's failure to handle

her allegations adequately contributed to Edmonds' increasingly vociferous

complaints, which ultimately led to the termination of her services.

We also recognize that Edmonds was not an easy employee to manage,

and that some of her complaints, based on her self-initiated reviews, were

unsupported and a distraction to her supervisors. Edmonds also aggressively

asserted her opinions about the management of the translation program, which

was frustrating to her supervisors. But we believe that many of her allegations

were supported, that the FBI did not take them seriously enough, and that her

allegations were, in fact, the most significant factor in the FBI's decision to

terminate her services.

In addition, the FBI has not asserted that Edmonds' contract was

terminated because it had no further need of her services. In fact, the Chief of

LSS told the OIG that there has been no reduction in the need for linguists to

translate the language Edmonds translated. Indeed, at the time Edmonds'

services were terminated, there remained a need for such services.

We also believe the FBI could have handled the matter much more

effectively than it did. For example, as an LSS Unit Chief suggested, the FBI

could have moved Edmonds to another location while it pursued a thorough

investigation of Edmonds' allegations. Had it done so, the "disruptive effect" on

operational activities created by Edmonds' persistent complaints could have

been avoided or at least minimized.

In sum, while Edmonds does not fall within the protection of the FBI's

Whistleblower regulations, we believe that the FBI significantly mishandled this

matter. The FBI should not discourage employees or contractors from raising

good-faith allegations of misconduct or mismanagement. By terminating

31
Edmonds'services, in large part because of her allegations of misconduct, the

FBI's actions also may have the effect of discouraging others from raising

concerns.24

VIII. OIG RECOMMENDATIONS

In light of the issues that we examined in this case, particularly the

issues relating to Edmonds allegations regarding the co-worker, we are

providing systemic recommendations to the FBI in an attempt to help it

improve its foreign language translation program.25

3.

1. The FBI should consider having an employee from the LSS or a

case agent from the relevant squad interview CLs before they

are hired by the FBI. The FBI's hiring process for CLs includes

both language testing and a full background investigation.

Although the background investigation includes a Personnel

Security Interview designed to obtain information relevant to the

security clearance, CLs are not interviewed by employees from the

LSS or operational agents before being hired. As a result, the

supervisors of CLs or CMs never have an opportunity to meet with

the linguist and explore any issues relating to their qualifications

and background. While we recognize that these linguists are used

on a contract basis only, we believe the FBI should consider

including an interview during the hiring process for CLs and CMs.

Such an interview could include the applicant's future supervisor

or a case agent from a relevant operational squad.

2. The FBI should establish written guidelines for when risk

assessments should be performed in background

investigations. The FBI failed to conduct a risk assessment of

the co-worker during her background investigation. We believe

the FBI should create written guidelines that clearly state the

factors to be weighed when deciding whether a risk assessment is

necessary in a particular case.

The FBI should provide written guidelines to linguists to assist

them in reviewing materials. The CLs we interviewed said they

received oral training from case agents and other linguists.

However, they did not receive any written guidance regarding

24 In response to a draft of this report, the FBI expressed disagreement with this

conclusion. A copy of the FBI's response to the OIG is attached as Appendix C.

25 One recommendation was removed in its entirety because it contained classified

information.

32
reviewing materials. We recognize that many cases are different,

and what applies to one case may not apply to another, but we

believe that generalized guidance would be useful to help ensure

that CLs have a common understanding of their work

requirements when reviewing materials. We recommend that

general guidelines be provided to all linguists, in writing, when

they are hired by the FBI.

4. The FBI should ensure that supervisors determine the

assignment of material that linguists will review. The FBI

should ensure that supervisors assign material for linguists to

review. Failure to assign material creates potential security risks

and also contributed to the conflict that arose between linguists in

this case. We were told by Language Services Section supervisors

that these decisions should not be left to the linguists.

5. The FBI should establish a uniform policy with regard to work

assignment sheets for linguists. In the LSS, work assignment

sheets that should contain the signatures of the translator,

reviewer, and editor who worked on a particular translation are

destroyed after the information is entered into a database. We also

were told that the practice with respect to the signatures on these

forms is not uniform. For example, some individuals only put a

checkmark by their name when they complete the assignment,

while others simply forward the sheet without marking it in any

way . We recommend that the FBI establish and enforce a uniform

policy requiring signatures on work assignment sheets, and that it

maintain those sheets for a reasonable period of time so that

issues relating to a particular translation can be addressed

adequately.

6. The FBI should implement a system to track which linguist

reviews which material. We found that, because of resource

issues, more than one linguist may be assigned to a particular

task. While the LSS computer system keeps track of the last

person to work on a particular task, that information may be

overwritten or lost if a second person later works on the same task.

Although the work product of an individual linguist provides some

indication of which tasks that linguist carried out, there is no

method to establish, with certainty, which linguist reviewed which

material.

A Language Services supervisor stated that one of the linguists he

supervises had developed a practice of keeping track of all the

material he reviews. The supervisor said that when the linguist

finishes work each day, he transfers this information to the

33
relevant case agents along with the other work completed. In this

manner, the agents have a clearer picture of the case. In addition,

the supervisor said that extending this practice might cause less

attentive linguists to take more care in their work. We recommend

that the FBI consider implementing this or some other practice to

ensure that the FBI has a record of work completed on a particular

task. In addition, the FBI should evaluate the feasibility of

installing audit trails to preserve a record of each person who

worked on a particular task.

7. The FBI should reinforce ethics rules regarding gifts to

supervisors. We found that the practice of giving small gifts to

language supervisors was widespread, and was not limited to

special occasions such as marriage, illness, or retirement. We

believe the FBI should reiterate the ethics rules regarding gifts and

specifically instruct language supervisors and linguists to stop the

practice of supervisors regularly accepting gifts from linguists.

IX. CONCLUSION

The majority of the allegations raised by Edmonds related to the actions

of a co-worker. The allegations raised serious concerns that, if true, could

potentially have extremely damaging consequences for the FBI. These

allegations warranted a thorough and careful review by the FBI.

Our investigation concluded that the FBI did not, and still has not,

adequately investigated these allegations. Our review also found that many -

although not all - of Edmonds' allegations about the co-worker had some basis

in fact. This evidence does not prove, and we are not suggesting, that there is

sufficient evidence to conclude that espionage or any improper disclosures of

FBI information occurred. However, we believe the FBI should have taken

Edmonds' allegations more seriously and investigated them more thoroughly.

As discussed in this report, the FBI's investigation of the information regarding

the co-worker was significantly flawed. Had the FBI investigated the claims

thoroughly, it would have found that many of Edmonds' allegations regarding

the co-worker were supported by documentary evidence or other witnesses.

Instead, the FBI seems to have discounted Edmonds' allegations, believing she

was a disruptive influence and not credible, and eventually terminated her

services. Even now, the FBI has not carefully investigated the allegations

about the co-worker to determine if the co-worker compromised any FBI

information. In light of the need for FBI vigilance about security issues, as

demonstrated by the Hanssen case, we believe the FBI should have

investigated these serious allegations more thoroughly.

34
Edmonds also alleged that the FBI retaliated against her by terminating

her services as a CL. We concluded that Edmonds' allegations were at least a

contributing factor in why the FBI terminated her services. We recognize that

the FBI Whistle blower regulations do not apply to Edmonds because she was a

contractor rather than an FBI employee. We also recognize that her varied and

insistent allegations of misconduct may have been frustrating, and that not all

of her allegations were true. However, many of her allegations had a basis in

fact, and the way the FBI responded to her allegations contributed to her

persistent claims. Moreover, we believe the FBI should not discourage

employees or contractors from raising good-faith allegations of misconduct or

mismanagement and the FBI's termination of Edmonds' services may

discourage others from raising such concerns.

With regard to Edmonds' other allegations of misconduct, most were not

supported by the evidence we reviewed. However, she did raise a valid concern

about unnecessary travel for certain linguists.

Finally, our review also found problems in the oversight of FBI CLs. The

FBI needs to more carefully oversee and monitor their work. Towards this end,

we made several recommendations regarding the FBI's hiring and oversight of

CLs. We believe that the FBI should carefully consider these

recommendations, which we believe could help improve the operation of the

FBI's language translation program.

35
FEDERAL BUREAU OF INVESTIGATION

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Appendix B

FBI LANGUAGE SERVICES SECTION

LANGUAGE SERVICES

ASSISTANT

LANGUAGE SPECIALIST

PROGRAM

SPECIAL AGENT LINGUIST

PROGRAM

LANGUAGE SERVICES

TRANSLATION CENTER

Superviso<y Translator

DEPLOYMENT PROGRAM

TRANSLATION STAFF

CONTRACT LINGUISTS

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SECTION CHIEF

APPLIED LINGUISTS

LANGUAGE TRAINING

PROGRAM

FOREIGN LANGUAGE

RESOURCE CENTER

ASSESSMENT, RESEARCH

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Program Manager

ASSESSMENT AND RESEARCH

FOREIGN LANGUAGE TESTING

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TEST ADMINISTRATION

TEST ADMINISTRATION

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CONTRACT LINGUIST PROGRAM

FINANCIAL MNGT

BOAs, WORK ORDERS,

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CL INVOICE VOUCHER

PROCESSING; OVERTIME

REOUESTS; ADMIN SUPPORT

PROGRAM SUPPORT

RESOURCE ENHANCEMENT

& STRATEGIC PLANNING

PROGRAM MANAGER

CL RECRUITMENT

& BACKGROUND PROCESSING

LANGUAGE AUTOMATION

SUPPORT & OUTREACH
Appendix C

U.S. Department of Justice

Federal Bureau of Investigation

Washington, D. C. 20535-000 I

June 30, 2004

Honorable Glenn A. Fine

Inspector General

Department of Justice

Room 4322 Main

950 Pennsylvania Avenue, Northwest

Washington, D.C. 20530

Dear Mr. Fine:

This letter is in response to your draft report on Sibel Edmonds. First, I disagree

with your conclusion that Edmonds, a private contractor, was retaliated against for her making allegations of misconduct or mismanagement. Edmonds was terminated from the FBI because

she committed security violations and was a disruption to her office. Second, the FBI thoroughly investigated this matter and determined that retaliation was not the basis of her termination.

Your report makes reference to her "increasingly vociferous complaints," and found "insufficient

evidence" to substantiate multiple additional allegations made by Edmonds. Under the totality of

the facts and circumstances, the FBI wasjustified to terminate her contract and did not retaliate

against her.

The Director has testified before Congress, and has communicated to all

employees in the FBI, that he will not tolerate retaliation.

Please feel free to contact me at I should you require additional information.

Sincerely yours,

S-C ~ ('a/\.-.

Steven C. McCraw

Assistant Director

Inspection Division