Executive Power with Regard to the Libyan Situation

[The following memorandum reviews the significant statutory authorities available to the

President and other executive officials in dealing with a foreign policy crisis.]

December 23, 1981

MEMORANDUM OPINION FOR TH E ATTORNEY GENERAL, 

TH E DEPUTY ATTORNEY GENERAL, AND THE ASSOCIATE 

ATTORNEY GENERAL

To assist you in deliberations regarding Libya, we are providing a 

general memorandum concerning statutes likely to be significant.

A. The International Emergency Economic Powers Act

The President has wide-ranging power to regulate property and 

transactions in which a foreign country has an interest under the International Emergency Economic Powers Act (IEEPA), 50 U.S.C. 

§§ 1701-1706 (Supp. Ill 1979), enacted in 1977. IEEPA was used 

during the Iran hostage crisis: (1) to block Iranian government property 

in this country; (2) to limit exports and imports to Iran; (3) to restrict 

transactions with any foreign person or entity relating to travel to Iran; 

and (4) to make the required transfers of funds in connection with the 

agreement ending the hostage crisis. Dames & Moore v. Reagan, 453 

U.S. 654 (1981); e.g., Exec. Order No. 12,170, 44 Fed. Reg. 65,729

(1979); Exec. Order No. 12,205, 45 Fed. Reg. 24,099 (1980); Exec. 

Order No. 12,211, 45 Fed. Reg. 26,685 (1980). It continues to be used 

today to implement various financial aspects of the settlement with 

Iran.

The IEEPA provides broad powers to the President in the event of 

any:

unusual and extraordinary threat, which has its source in 

whole or substantial part outside the United States, to the 

national security, foreign policy, or economy of the 

United States, if the President declares a national emergency with respect to such threat.

50 U.S.C. § 1701. If such an emergency is declared, the President may:

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under such regulations as he may prescribe, by means of 

instructions, licenses, or otherwise—

(A) investigate, regulate, or prohibit—

(i) any transactions in foreign exchange,

(ii) transfers of credit or payments between, by, 

through, or to any banking institution, to the extent that 

such transfers or payments involve any interest of any 

foreign country or a national thereof,

(iii) the importing or exporting of currency or securities; and

(B) investigate, regulate, direct and compel, nullify, void, prevent or prohibit, .any acquisition, holding, withholding, use, 

transfer, withdrawal, transportation, importation or exportation 

of, or dealing in, or exercising any right, power, or privilege 

with respect to, or transactions involving, any property in which 

any foreign country or a national thereof has any interest;

by any person, or with respect to any property, subject to 

the jurisdiction of the United States.

50 U.S.C. § 1702(a)(1).:Under these provisions, once the President 

declares a national emergency, he may control all foreign assets subject to 

the jurisdiction of the United States, regulate or prohibit movements of 

foreign or domestic currency or credit in and out of the country, and 

prohibit all transactions involving any property in which the foreign 

country or any national thereof has an interest.

If a decision is made to invoke IEEPA, certain steps must be taken 

immediately under that Act and the National Emergencies Act, 50 

U.S.C. §§ 1601-1651. The latter Act confers no separate authority, but 

imposes procedural requirements.

(1) Consultation with Congress: The President, “in every possible instance,” shall consult with Congress before exercising authorities under 

the IEEPA. 50 U.S.C. § 1703(a). There is no formal procedure for this. 

It has usually been done with only a small group of congressional 

leaders.

(2) Declaration of a national emergency: A proclamation of national 

emergency is necessary to use the powers available under IEEPA. 50 

U.S.C. § 1701. The President is authorized to declare an emergency 

pursuant to the National Emergencies Act. 50 U.S.C. § 1621. For purposes of IEEPA, such an emergency may be declared with respect to 

any unusual and extraordinary threat to the national security, foreign 

policy, or economy of the United States which has its source outside 

this country. 50 U.S.C. § 1701. This language was left broad to provide 

necessary discretion. H.R. Rep. No. 459, 95th Cong., 1st Sess. 10 

(1977).

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A presidential declaration of emergency under IEEPA can be short 

and to the point. In the Iran crisis, the President stated: “I find that the 

situation in Iran constitutes an unusual and extraordinary threat to the 

national security, foreign policy and economy of the United States and 

hereby declare a national emergency to deal with that threat.” Exec. 

Order No. 12,170, supra, 44 Fed. Reg. 65,729. The courts will not 

review a determination so peculiarly within the province of the President. See 42 Op. Att’y Gen. at 370.

Under the Act, Congress is authorized to terminate a declared emergency through adoption of a concurrent resolution. 50 U.S.C. § 1706(b) 

(Supp. Ill 1979). It is our position that a concurrent resolution, because 

it would not be subject to the President’s veto, would be constitutionally insufficient to terminate a declared emergency.

(3) Designation o f Act: The National Emergencies Act declares that in 

the same proclamation or by contemporaneous or subsequent executive 

orders, the President must designate the particular emergency statute he 

wishes to invoke, e.g., IEEPA. The 1979 Iranian blocking order and 

emergency declaration appeared in the same document. Exec. Order 

No. 12,170, supra, 44 Fed. Reg. 65,729.

(4) Delegation: Since IEEPA vests powers directly in the President, 

an executive order should delegate power to an appropriate official. 3 

U.S.C. § 301. This could be the Secretary of the Treasury, who already 

administers similar programs. The President could declare a sanction in 

general terms and delegate to an appropriate official the powers to 

administer the sanction and enforce the Act. This was done with the

1979 Iranian blocking order; doing so would avoid any enforcement 

gap between the issuance of the proclamation and implementation of 

the regulations by Treasury.

(5) Publication and transmittal to Congress: The National Emergencies 

Act requires that the emergency proclamation be immediately transmitted to Congress and published in the Federal Register. 50 U.S.C. 

§ 1621.

(6) Report to Congress: Following the issuance of the order, the 

President shall “immediately” transmit a report to the Congress specifying:

(1) the circumstances which necessitate such exercise of 

authority;

(2) why the President believes those circumstances constitute an unusual and extraordinary threat, which has its 

source in whole or substantial part outside the United 

States, to the national security, foreign policy, or economy of the United States;

(3) the authorities to be exercised and the actions to be 

taken in the exercise of those authorities to deal with 

those circumstances;

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(4) why the President believes such actions are necessary to deal with those circumstances; and

(5) any foreign countries with respect to which such 

actions are to be taken and why such actions are to be 

taken with respect to those countries.

50 U.S.C. § 1703(b).

The legislative history indicates that this requirement was not to 

impede use of emergency power. The House report notes:

Nothing in this section should be construed as requiring 

submission of a report as a precondition of taking action 

where circumstances require prompt action prior to or 

simultaneously with submission of a report.

H.R. Rep. No. 459, supra, at 16.

The Department of State is currently drafting appropriate report 

language which, once approved by concerned agencies, can be incorporated immediately into final documents.

IEEPA provides for prison sentences of up to 10 years and fines up 

to $50,000. Officers, directors, and agents of corporations are specifically covered by this provision if they knowingly participate in violations. Civil fines of up to $10,000 may also be imposed.

B. The Trading With the Enemy Act

The Trading with the Enemy Act, as amended in 1977, is available 

only during a war. 50 U.S.C. App. § 5(b) (Supp. Ill 1979). The key 

language of IEEPA quoted above (describing the powers available to 

the President) was based on the Trading with the Enemy Act, which 

retains comparable provisions. In addition, broader powers are available 

under the Trading with the Enemy Act, including the authority to vest 

enemy property (a process by which the government seizes and takes 

title to it) and to control wholly domestic transactions. 50 U.S.C. App. 

§ 5(b).

C. Passport Restrictions

The Passport Act, as amended in 1978, deals with the power of the 

Secretary of State to restrict the use of passports. It provides:

Unless authorized by law, a passport may not be designated as restricted for travel to or for use in any country 

other than a country with which the United States is at 

war, where armed hostilities are in progress, or where 

there is imminent danger to the public health or the physical safety of United States travellers.

22 U.S.C. § 211a (Supp. Ill 1979).

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The amendment followed a Supreme Court decision holding that the 

President had authority to refuse to validate passports for travel to 

Cuba. Zem el v. Rusk, 381 U.S. 1 (1965). The Senate committee that 

added the amendment said that it intended to make “the freedom-oftravel principle . . . a matter of law.” S. Rep. No. 842, 95th Cong., 2d 

Sess. 14 (1978). Nevertheless, the Supreme Court has recently confirmed that the President has broad power over the issuance and revocation of passports. Haig v. Agee, 453 U.S. 280 (1981).

The President’s power has been delegated to the Secretary of State 

pursuant to Executive Order No. 11,295, 31 Fed. Reg. 10,603 (1966). 

On December 9, 1981, Acting Secretary of State Clark restricted the 

use of United States passports for travel in Libya by placing a notice to 

that effect in the Federal Register. 46 Fed. Reg. 60,712 (1981). The 

notice said that the action was required by the unsettled state of 

relations with Libya, and the increased threat of hostile acts against 

Americans. It noted that the American Embassy in Libya remains 

closed and that the U.S. government is not in a position to provide 

diplomatic protection or consular assistance to Americans in Libya. 

Therefore there was an imminent danger to the physical safety of 

Americans travelling to or present in Libya.

In April, 1980, shortly before the rescue mission to Iran, President 

Carter authorized the restriction of the use of passports for travel to 

Iran. Exec. Order No. 12,211, supra, 45 Fed. Reg. 26,685 (1980). This 

restriction was lifted at the time of the hostage release agreement in 

January, 1981. The order did not prove to be successful in deterring 

some Americans from traveling to Iran. On May 31, 1980, while the 

hostages were being held and the travel restriction was in effect, former 

Attorney General Ramsey Clark led a group of ten U.S. citizens to Iran 

to participate in an international conference. The Attorney General 

decided earlier this year not to litigate the question of whether this 

group had violated various federal laws.

The Passport Act itself provides no penalty for its violation. It is a 

crime “to use any passport in violation of the conditions or restrictions 

therein contained . ...” 18 U.S.C. § 1544. It is, however, difficult to 

enforce this law. It appears that, in order to have a successful prosecution, the government must prove that a U.S. passport that was geographically restricted was used to enter the country to which travel 

was restricted. Persons traveling to geographically restricted areas generally work out arrangements with the country of destination to admit 

them without presentation of the passport; if the passport is not used, 

no violation occurs. Even if the passport is used, evidence on this point 

is not likely to be available to prosecutors in the United States. State 

Department regulations do not list violation of area restrictions as a 

basis for revoking or denying a passport. 22 C.F.R. §§ 51.70—.71 (1981). 

It appears that the regulations could be amended so that violation of an

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area restriction would be a ground for revocation. The problems of 

proof described for the criminal law would, however, apply here as 

well.

D. Export Administration Act

The Export Administration Act of 1979, 50 U.S.C. App. §§2401- 

2413 (Supp. Ill 1979), contains three separate grants of power to the 

President to prohibit or curtail the export of goods and technology 

subject to the jurisdiction of the United States: national security controls, foreign policy controls, and short supply controls. 50 U.S.C. App. 

§§ 2404, 2405, 2406.

The provision likely to be most pertinent relates to foreign policy 

controls.1 On October 23, 1981, foreign policy controls were imposed 

on exports of aircraft and aircraft parts to Libya. 46 Fed. Reg. 53,023 

(1981) (to be codified at 15 C.F.R. §§ 376, 385, 399). Previously, offhighway tractors were restricted for sale to Libya under this section. 15

C.F.R. § 385.4(e) (1981).

This Act was not employed against Iran, but was recently used to 

restrict exports to the Soviet Union in 1980 following the invasion of 

Afghanistan. 45 Fed. Reg. 1883 (1980) (to be codified at 15 C.F.R. 

§§ 376, 386, 399) (Restriction on the Export of Agricultural Commodities and Products to the U.S.S.R.); 45 Fed. Reg. 21,612 (1980) (to be 

codified at 15 C.F.R. §§ 371, 379, 385, 399) (Controls on Goods and 

Technology for Moscow Olympics).

The President may prohibit exports “to the extent necessary to further significantly the foreign policy of the United States or to fulfill its 

declared international obligations.” 50 U.S.C. App. § 2405(a)(1). One of 

the expressly permitted purposes of foreign policy controls is discouraging the provision of aid or sanctuary to international terrorists. 50 

U.S.C. App. § 2402(8).

The President’s authority to impose foreign policy controls has been 

delegated to the Secretary of Commerce. Exec. Order No. 12,214, 45 

Fed. Reg. 29,783 (1980). It must be exercised, however, in consultation 

with the Secretary of State. 50 U.S.C. App. § 2405(a) (Supp. Ill 1979).

1 National security controls may be imposed in order to restrict the export of goods and technology 

which would make “a significant contribution to the military potential of any other country,” which 

would prove detrimental to the United States, 50 U.S.C. App. § 2402(2)(B), and which pertain to 

“militarily critical goods and technologies,” 50 U.S.C. App. § 2404(d)(1). The Secretary cannot require 

a validated license unless (A) the export is restricted under a multilateral agreement; (B) with respect 

to the export, other nations do not possess capabilities comparable to those of the United States; or (C) 

the United States is seeking agreement of other suppliers to apply comparable controls 50 U.S.C. 

App. § 2404(e)(2). If the President determines that goods or technology are available from foreign 

sources so that a specific licensing requirement would be ineffective, he may still impose controls if he 

finds that “the absence of export controls . would prove detrimental to the national security of the 

United States ” 50 U.S.C. App. § 2404(f)(1).

Short supply controls are used “to restrict the export of goods where necessary to protect the 

domestic economy from the excessive drain of scarce materials and to reduce the senous inflationary 

impact of foreign demand ” 50 U.S.C. App. § 2402(2)(C)

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Certain criteria must be considered when imposing or expanding such 

controls. They include:

(1) The probability that they will achieve their purpose;

(2) Compatibility with foreign policy including the 

effort to counter terrorism;

(3) The reaction of other countries;

(4) The impact on the ability of the United States to 

compete economically including the effect on existing 

contracts;

(5) Ability to enforce the controls effectively; and

(6) The foreign policy consequences of not imposing 

controls.

50 U.S.C. App. § 2405(b).

The Secretary of Commerce must, in addition, take the following 

steps:

(a) Consult with afTected industries concerning items (1) 

and (4), supra;

(b) Determine that reasonable efforts have been made 

to achieve the purposes of the controls through negotiations or other alternative means;

(c) Consult “in every possible instance” with the Congress;

(d) Notify Congress of the action taken; and

(e) Submit a report on items (1) through (6), supra, and 

on alternative means attempted or the reason for imposing 

the control without attempting alternative means. The 

report must also indicate how such controls will significantly further the foreign policy of the United States or 

will further its international obligations.

(0 Take all feasible steps to initiate and conclude negotiations with appropriate foreign governments to control 

exports by them of comparable goods or technology.

50 U.S.C. App. § 2405(c), (d), (e).

Criminal violators of restrictions issued for foreign policy purposes 

can be punished by a fine of five times the value of the export or 

$100,000, whichever is greater, and imprisoned for up to 10 years. 

Officers of corporations are not specifically covered by the penalty 

provision but under general principles of law can be prosecuted as 

violators. 18 U.S.C. §2. Wood v. United States, 204 Fed. 55 (4th Cir. 

1913), cert, denied, 229 U.S. 617. In addition, civil fines of up to $10,000 

may be imposed by the Commerce Department. Administrative sanctions are also available including revocation of the authority to export 

goods or technology. 50 U.S.C. App. § 2410(b), (c).

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E. The War Powers Resolution

The War Powers Resolution, 50 U.S.C. §§ 1541-1548, deals with the 

procedures which must be followed in the use of our armed forces. It 

includes requirements to consult with and report to Congress.

1. Consultation. The consultation requirement focuses on use of 

troops in hostile situations:

The President in every possible instance shall consult 

with Congress before introducing United States Armed 

Forces into hostilities or into situations where imminent 

involvement in hostilities is clearly indicated by the circumstances, and after every such introduction shall consult regularly with the Congress until United States* 

Armed Forces are no longer engaged in hostilities or have 

been removed from such situations.

50 U.S.C. § 1542.

On its face, consultation is required with “Congress.” This language 

replaced an earlier version which merely required consultation with the 

leadership and appropriate committees of Congress. H.R. Conf. Rep. 

No. 547, 93rd Cong., 1st Sess. 8 (1973); H.R. Rep. No. 287, 93rd Cong., 

1st Sess. 6 (1973). Nevertheless, as a practical matter consultation with 

any more than a select group of congressional leaders has never been 

attempted.

In requiring consultation in “every possible instance,” Congress 

meant to be firm yet flexible. H.R. Rep. No. 287, supra, at 6. The 

House report noted:

The use of the word “every” reflects the committee’s 

belief that such consultation prior to the commitment of 

armed forces should be inclusive. In other words, it 

should apply in extraordinary and emergency circumstances—even when it is not possible to get formal congressional approval in the form of a declaration of war or 

other specific authorization.

At the same time, through use of the word “possible” it 

recognizes that a situation may be so dire, e.g„ hostile 

missile attack underway, and require such instantaneous 

action that no prior consultation will be possible.

Id.

President Carter determined that consultation was not “possible” 

prior to the Iran rescue mission because of the great need for secrecy. 

He indicated, however, that if the mission had not been aborted in its

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first phase, he planned to advise appropriate congressional leaders 

before the next phase, the actual rescue, took place.2

Consultation is only required prior to the actual “introduction” of 

forces into hostilities. Thus, it is not required during planning or preparation stages as long as forces have not been committed.

A determination must also be made as to when hostilities exist that 

require consultation. President Ford took the position, for example, that 

no consultation was legally required at the Danang or Lebanon evacuations because hostilities were not involved. Franck, After the Fall: The

New Procedural Framework for Congressional Control Over the War

Power, 71 Am. I. Int’l L. 605, 615 (1977). The State and Defense 

Departments have said that “hostilities” mean a situation in which 

American forces are actively exchanging fire with opposing units and 

“imminent hostilities” mean a situation where there is a serious risk 

from hostile fire to the safety of U.S. forces. Neither term was thought 

to encompass irregular or infrequent violence which may occur in a 

particular area. War Powers: A Test o f Compliance, Relative to the

Danang Sealift, the Evacuation o f Phnom Penh, the Evacuation o f Saigon,

and the Mayaguez Incident, Hearings Before the Subcomm. on Int'l Security and Scientific Affairs o f the House Comm, on Int'l Relations, 94th 

Cong., 1st Sess. 38-39, 85-86 (1975).

2. Reporting requirements. The reporting requirements apply to situations not only where hostilities are taking place or imminent (which 

requires consultation) but where armed forces are sent to a foreign 

country equipped for combat. 50 U.S.C. § 1543. The report must be 

filed within 48 hours. This has been interpreted as meaning 48 hours 

from the time that they are “introduced” into the situation triggering 

the requirement and not from the time that the decision to dispatch 

them is made. E.g., Franck, supra, at 615. The report must include:

(1) The circumstances necessitating the introduction of 

United States Armed Forces;

(2) The constitutional or legislative authority under 

which such introduction took place; and

(3) The estimated scope and duration of the hostilities 

or involvement.

Franck, supra, at 614-15.

Reports filed in the past have been brief and to the point; they have not 

run more than one or two pages. The discussion of legal authority in the 

reports has been limited to a brief reference to the constitutional power of 

the President as Commander-in-Chief and Chief Executive. This Admin2 Statement of Acting Secretary o f State Christopher, May 8, 1980, to Senate Foreign Relations 

Comm., p. 5. Although the Acting Secretary’s statement was phrased in statutory terms, the consultation requirement raises a constitutional question as to a possible limit on the President’s independent 

power. Testimony o f State Department Legal Adviser Monroe Leigh in War Powers: A Test o f

Compliance, supra, at 100

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istration took the position that the incident earlier this year where two 

Libyan planes were shot down over the Mediterranean did not implicate 

either the consultation or reporting provisions.

The resolution includes in its statement of purpose and policy a list of 

situations in which the President is authorized to introduce the Armed 

Forces into hostilities or situations of imminent hostility. This may be 

done: (1) pursuant to a declaration of war; (2) under specific statutory 

authorization, or (3) in a national emergency created by an attack upon 

the United States, its territories or possesions or its armed forces. 50 

U.S.C. § 1541(c). We do not believe, however, that the purpose and 

policy statement should be construed to constrain the exercise of the 

President’s constitutional power. The Resolution’s policy statement is 

not a comprehensive or binding formulation of the President’s powers 

as Commander-in-Chief. See H.R. Conf. Rep. 547, 93rd Cong., 1st Sess. 

8 (1973) (stating that subsequent sections of the Resolution are not 

dependent on the policy statement). The Resolution itself disclaims any 

intent to alter the constitutional power of the President. 50 U.S.C. 

§ 1547(d)(1).

Finally, the Resolution provides that Congress may, by concurrent 

resolution, force the withdrawal of our armed forces from abroad. 50 

U.S.C. § 1544(c). This “legislative Veto” device is, in our view, unconstitutional. See Veto of the War Powers Resolution, 1973 Pub. Papers 

of Richard Nixon 893 (Oct. 24, 1973).

F. Powers Relating to Libyan Nationals

The Immigration and Nationality Act, 8 U.S.C. §§ 1101-1525 (1976 

ed. and Supp. Ill 1979), provides the Executive with broad powers to 

restrict the entry of aliens into the United States and to deport them.

The President may issue regulations governing the entry and departure of aliens from the United States. It is unlawful

for any alien to depart from or enter or attempt to depart 

from or enter the United States except under such reasonable rules, regulations, and orders, and subject to such 

limitations and exceptions as the President may prescribe ....

8 U.S.C. § 1185(a)(Supp. Ill 1979). In addition, the President may 

suspend the entry of aliens by designated classes:

Whenever the President finds that the entry of any 

aliens or of any class of aliens into the United States 

would be detrimental to the interests of the United States, 

he may by proclamation, and for such period as he shall 

deem necessary, suspend the entry of all aliens or any 

class of aliens as immigrant or nonimmigrants, or impose

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on the entry of aliens any restrictions he may deem to be 

appropriate.

8 U.S.C. § 1182(0-

In the Iran crisis, the President delegated to the Secretary of State 

and the Attorney General the powers of the President under 8 U.S.C. 

§ 1185 to prescribe limitations respecting visas issued to Iranians. Exec. 

Order No. 12,172, 44 Fed. Reg. 67,947 (1979), as amended by Exec. 

Order No. 12,206, 45 Fed. Reg. 24,101 (1980). Under this order, the 

State Department issued regulations requiring all outstanding visas of 

Iranian nationals to be re-endorsed and for new visas to be issued only 

under strict standards. 22 C.F.R. §46.8 (1981). Sections 1182 and 1185 

were the authority for Proclamation 4865, 46 Fed. Reg. 48,107 (1981), 

and Executive Order No. 12,324, 46 Fed. Reg. 48,109 (1981) concerning interdiction of aliens on the high seas.

In addition, the Attorney General can issue regulations to carry out 

the immigration laws, 8 U.S.C. § 1103(a), and is charged with insuring 

that aliens who have not maintained their status under the law depart 

from the United States, 8 U.S.C. § 1184(a). These powers are delegated 

to the Commissioner of Immigration and Naturalization. 28 C.F.R. 

§0.105 (1981). In 1979 the Immigration and Naturalization Service 

(INS) issued regulations requiring Iranian students to report to the INS 

and submit evidence that they had maintained eligibility as students 

under the immigration laws. 8 C.F.R. §214.5 (1981). Subsequently, the 

INS provided for the accelerated departure of all Iranians who were 

judged deportable by limiting the amount of time permitted for departure. 8 C.F.R. §242.5 (1981). These INS regulations were upheld in 

subsequent litigation as a valid exercise of the Attorney General’s 

statutory power. The courts held that the regulations had a rational 

basis and did not therefore deprive Iranians of equal protection of the 

laws. Narenji v. Civiletti, 617 F.2d 745 (D.C. Cir. 1979), cert, denied, 446 

U.S. 957 (1980); Malek-Marzban v. INS, 653 F.2d 113 (4th Cir. 1981); 

cf. Yassini v. Crosland, 618 F.2d 1356 (9th Cir. 1980).

Apart from the statute below dealing with enemy aliens, there is no 

law which specifically provides the power to expel aliens who are in 

this country lawfully as permanent residents or nonimmigrants and who 

are not otherwise subject to deportation.

The President has statutory authority to intern or expel enemy aliens. 

This power is available, however, only in time of war, invasion, or 

predatory incursion. 50 U.S.C. §21. The Supreme Court has held this 

provision constitutional. Ludecke v. Watkins, 335 U.S. 160 (1948).

For your information, we are attaching: (1) examples of orders which 

have been issued in the past; and (2) a listing of major opinions, 

including subject headings issued by this Office during the Iranian

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crisis. The latter attachment demonstrates the broad range of actions 

which were considered during that crisis.

T h e o d o r e B. O lso n

Assistant Attorney General

Office o f Legal Counsel

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