The version of the Clause adopted by the Founders closely resembles the language adopted in the English Bill of Rights of 1689, which came out of the long struggle for governmental supremacy between the English monarchs and the Parliament, during which the criminal and civil law were used to intimidate legislators. 1. 783, 95 L.Ed. On July 11, 2006, Congressman Jefferson filed a notice of appeal and a motion for a stay pending appeal. WebWashington, DC Office. When all of the brush is cleared away, this case presents a simple question: can Executive Branch personnel-here, special agents of the Federal Bureau of Investigation-execute a search warrant directed to the congressional office of a Member of the Congress (Member) without doing violence to the Speech or Debate Clause (Clause) set forth in Article I, Section 6, Clause 1 of the United States Constitution? 6. Washington, DC 20515 2059 Rayburn House Office Building Washington, D.C. 20515 Rayburn House Office Building - Main entrance, horseshoe drive off South Capitol Street. Cf. There is no indication that the Executive did not act based on a good faith interpretation of the law, as reflected in the district court's prior approval and later defense of the special procedures set forth in the warrant affidavit. Indeed, the Congressman, his attorney, and counsel for the House of Representatives were denied entry into Room 2113 once the FBI arrived. [6] The legality of the raid was challenged in court, where a federal appeals court ruled that the FBI had violated the Speech or Debate clause of the United States Constitution by allowing the executive branch to review materials that were part of the legislative process.[7]. July 28, 2006). Complete Directory . Statuary Hall The question remains what the appropriate remedy is under Rule 41(g) for a violation of the Speech or Debate Clause. The cornerstone was laid in May 1962, and full occupancy began in February 1965. at 421 (quoting MINPECO, 844 F.2d at 859 (quoting Eastland v. U.S. Servicemen's Fund, 421 U.S. 491, 503, 95 S.Ct. Id. (former counsel to the U.S. House of Representatives and the Senate and scholars) at 28-29 (same). Steak n Shake is located adjacent to the Rayburn Cafeteria. Earlier efforts to provide space for the House of Representatives had included the construction of the Cannon House Office Building and the Longworth House Office Building. Phone: (202) 225-2915 WebRayburn House Office Building. Some site content requires additional applications or browser plug-ins. Washington, D.C. Today, Congressman and Congressional Valley Fever Task Force Co-Chair Kevin McCarthy, U.S. Web2216 Rayburn House Office Building Washington, DC 20515 Phone: 202-225-4151 Fax: Studio B 3. at 660, my colleagues first acknowledge that Brown & Williamson involved civil litigation, id. In re 3021 6th Ave. N., Billings, MT v. United States, 237 F.3d 1039, 1041 (9th Cir.2001). This court, upon consideration of the Congressman's emergency motion for a stay pending appeal filed on July 20, 2006, enjoined the United States, acting through the Executive, from resuming its review of the seized materials. at 13-22; U.S. Const. 749, 15 L.Ed.2d 681 (1966). The following day, the President of the United States directed the Attorney General, acting through the Solicitor General, to preserve and seal the records and to make sure no use was made of the materials and that no one had access to them; this directive would expire on July 9, 2006. We agree with the Ninth Circuit's holding that the 1989 amendment to Rule 41, eliminating the coupling of a motion for the return of property under Rule 41 and a motion to exclude evidence at trial, Fed.R.Crim.P. On June 4, 2007, the grand jury returned a sixteen-count indictment against Congressman Jefferson in the Eastern District of Virginia. 334 CHOB (Veterans' Affairs Committee) Unlike the Brown & Williamson dicta, Gravel's discussion of the Clause's applicability to Members should direct our analysis. See infra pp. It was completed in 1965 and at 2.375 million square feet (220,644 m2) is the largest congressional office building and the newest House office building (the only newer congressional office building is the Hart Senate Office Building, completed in 1982). Here, the warrant sought only fruits, instrumentalities and evidence of violations of various federal bribery and fraud statutes involving Rep. Jefferson,4 see Warrant Aff., reprinted in Joint Appendix (JA) at 7; Sealed Appendix (SA) 18-25, which plainly are outside the bounds of protected legislative activities, see Brewster, 408 U.S. at 526, 92 S.Ct. (bribery of foreign official) and 18 U.S.C. Web2229 Rayburn House Office Building. On May 18, 2006, the Department of Justice filed an application for a search warrant for Room 2113 of the Rayburn House Office Building, the congressional office of Congressman William J. Jefferson. There would appear to be no reason why the Congressman's privilege under the Speech or Debate Clause cannot be asserted at the outset of a search in a manner that also protects the interests of the Executive in law enforcement. at 10. 1962(c). United States v. Jefferson, No. at 1. Id. Id. Capitol - Public tours enter through the Capitol Visitor Center; Official House business enters on the south side of the Capitol; Official Senate business enters on the north side of the Capitol.. Leader McCarthy and Congressman Schweikert Host Valley Fever Roundtable, McCarthy and Schweikert Introduce Historic Valley Fever Legislation, McCarthy, Schweikert Request FDA Action on Valley Fever Drug and Vaccine Development, Valley Fever Task Force Co-Chairs Schweikert, McCarthy Celebrate Valley Fever Awareness Week in AZ, Rep. McCarthy, Sen. McSally, Rep. Schweikert, and Bipartisan, Bicameral Leaders Introduce FORWARD Act to Combat Valley Fever, Leader McCarthy and the House Valley Fever Task Force Support Immuno-Mycologics, Inc.s Bid for Grant Funding. The United States Capitol Police has a strong partnership with DCs Homeland Security and Emergency Management Agency (HSEMA). See infra pp. According to Brewster, a Member of Congress may be prosecuted under a criminal statute provided that the Government's case does not rely on legislative acts or the motivation for legislative acts. Id. See Amicus Br. However, this court has. 1153 (1952) (Jackson, J., concurring)). CVC-200 (Congressional Auditorium), Cannon Rotunda 2531. Dirksen Senate Office Building - First Street and C Street entrance. The Congressman has suggested no other reason why return of the non-privileged documents is required pursuant to Rule 41(g), and, in any event, it is doubtful that the court has jurisdiction to entertain such arguments following the return of the indictment. Capitol Hill Facts - Rayburn House Office Building | Architect of The Ca Nor has the Congressman argued that his assertions of privilege could not be judicially reviewed, only that the warrant procedures in this case were flawed because they afforded him no opportunity to assert the privilege before the Executive scoured his records. Fax: (202) 225-2908 378, 136 L.Ed.2d 1 (1996). Pedestrian tunnels also connect the Rayburn building to the Capitol and to the Longworth House Office Building. Moreover, the FBI agents responsible for the search of Rep. Jefferson's congressional office went to great lengths to minimize disruption8 by, inter alia, executing the warrant when the Congress was not meeting, imaging computer hard drives rather than searching the computers, using specific search terms for both paper and electronic records and, most important, creating Filter Teams-one for paper records and one for electronic records-and ensuring subsequent in camera judicial review to minimize exposure to privileged records. Kevin was first elected to Congress in 2006 and is a native of Bakersfield and a fourth-generation Kern County resident. Congressman Jefferson argued in the district court that he has suffered irreparable harm with no adequate remedy available at law because the violation of his constitutional rights cannot be vindicated by an action at law or damages or any other traditional relief.7 On appeal, however, the Congressman makes no claim that the functioning of his office has been impaired by loss of access to the original versions of the seized documents; the Remand Order directed that he be given copies of all seized documents. In the district court's view, the Speech or Debate Clause was not implicated by execution of the search warrant because a seizure of documents did not involve a testimonial element. Accordingly, while I concur in the judgment which affirms the district court's denial of Representative William J. Jefferson's (Rep.Jefferson) Rule 41(g) motion, I do not agree with the majority's reasoning and distance myself from much of its dicta. 3090 (quoting Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579, 635, 72 S.Ct. The Executive and the district court appear to have proceeded on the premise that the scope of the privilege narrows when a search warrant is at issue. Capitol Rotunda 2167 RHOB (Transportation and Infrastructure Committee) In re Search of Rayburn House Ofice Bldg. Quite the contrary is true. Gravel v. United States, 408 U.S. 606, 626, 92 S.Ct. 62 F.3d at 419-20 (distinguishing Gravel's criminal context from civil subpoena). Yet, to the extent the majority reads Brown & Williamson to limit Gravel to process served on a congressional aide during a criminal investigation of a third party, that reading mischaracterizes both Brown & Williamson and Gravel. Longworth House Office Building - Main entrance, Independence and New Jersey Avenues. 9. At trial Rep. Jefferson may assert Speech or Debate Clause immunity to bar the use of records he claims are privileged. The Executive's search of the Congressman's paper files therefore violated the Clause, but its copying of computer hard drives and other electronic media is constitutionally permissible because the Remand Order affords the Congressman an opportunity to assert the privilege prior to disclosure of privileged materials to the Executive; the Executive advises, see Appellee's Br. The execution of a valid search warrant is an exercise of executive power, United States v. Grubbs, 547 U.S. 90, 126 S.Ct. P. 41(g). at 421. See id. Rayburn has a five-acre footprint, and looming four stories over the Hill it is larger than the nearby Capitol building. While the Executive characterizes what occurred as the incidental review of arguably protected legislative materials, Appellee's Br. H-137 Hallway 654; it is of no moment that the indictment was filed in another district, id. 138, and they shall not be involved in the pending prosecution or other charges arising from the investigation described in the warrant affidavit other than as regards responsiveness, id. o Longworth Take elevators to the basement level and follow signs to Cannon or Rayburn. Rayburn was completed in early 1965 and is home to the offices of 169 representatives. Earlier efforts to provide space for the House of Representatives had included the construction of the Cannon House Office Building and the Longworth House Office Building. 2531. The FBI agents' execution of the warrant on Rep. Jefferson's congressional office did not require the latter to do anything and accordingly falls far short of the question[ing] the court in Brown & Williamson found was required of a Member in response to a civil subpoena. Clearly a remedy in this case must show particular respect to the fact that the Speech or Debate Clause reinforces the separation of powers and protects legislative independence. Fields v. Office of Eddie Bernice Johnson, 459 F.3d 1, 8 (D.C.Cir.2006) (en banc) (collecting cases). HVC-215 A&B UNITED STATES v. RAYBURN HOUSE OFFICE BUILDING ROOM 2113 WASHINGTON 20515. Open 7:30a.m. 5:00 p.m. daily, including all weekends and holidays. The Clause provides that for any Speech or Debate in either House [t]he Senators and Representatives shall not be questioned in any other Place. U.S. Const. While the House attempts to ensure the correctness and suitability of information under House control and to correct errors brought to our attention, no representation or guarantee can be made as to the correctness or suitability of that information or any other linked information presented, referenced, or implied. Id. The special procedures outlined in the warrant affidavit would not have avoided the violation of the Speech or Debate Clause because they denied the Congressman any opportunity to identify and assert the privilege with respect to legislative materials before their compelled disclosure to Executive agents. at 660, the government expressly argues that [t]he execution of a search warrant is far removed from the core concerns animating the Clause, Appellee's Br. As [d]iscovery procedures can prove just as intrusive as naming Members or their staffs as parties to a suit, id. Instead, the search must first meet the requirements of the Fourth Amendment via the prior approval of a neutral and detached magistrate, Johnson v. United States, 333 U.S. 10, 14, 68 S.Ct. at 26. 78dd-2(a); Counts 12-14, Money Laundering, 18 U.S.C. 06-3105 (D.C.Cir. 6562, the bipartisan FORWARD Act with fellow Co-Chairman Congressman David Schweikert (AZ-6) and Task Force Members Congresswoman Martha McSally (AZ-2), Congresswoman Karen Bass (CA-37), and Congresswoman Kyrsten Sinema (AZ-9). Still, the speech or debate privilege was designed to preserve legislative independence, not supremacy. United States v. Brewster, 408 U.S. 501, 508, 92 S.Ct. 371 (conspiracy to commit bribery, wire fraud and bribery of foreign official). Moreover, as the majority recognizes, see Maj. Op. Open dawn to dusk, daily, including all weekends and holidays. By creating the Filter Teams and [b]y requiring judicial approval before any arguably privileged documents could be shared with the prosecution team, the search procedures as a whole eliminated any realistic possibility that evidence of Rep. Jefferson's legislative acts would be used against him. Appellee's Br. Congressman Jim Saxton was reportedly the source of the false alarm, after he mistook construction sounds in the garage for gunfire.[8]. The Speech or Debate protected by the Constitution includes only legitimate legislative activity, see, e.g., Tenney v. Brandhove, 341 U.S. 367, 376, 71 S.Ct. This roundtable brought optimism and excitement for a vaccine to cure Valley Fever in dogs within the next three years, and later a cure for humans. Although the presence of FBI agents executing a search warrant in a Member's office necessarily disrupts his routine, the alternative procedure proposed by Rep. Jefferson-sealing the office and permitting him to first label his records (paper and electronic) as privileged and unprivileged-would no doubt take much more of his time. Further, the court noted, citing Eastland, 421 U.S. at 509, that when the privilege applies it is absolute. 657-58. at 419, the court concluded that document production threatened to distract the two Members from their legislative duties, see id. 919 (1913) (under Fifth Amendment [a] party is privileged from producing the evidence, but not from its production). 3090, 41 L.Ed.2d 1039 (1974); Moody v. IRS, 654 F.2d 795, 799 (D.C.Cir.1981). 119 D Street, NE On July 10, 2006, the district court denied the Congressman's motion for return of the seized materials. 2118 RHOB (Armed Services Committee) Any questions should be directed to the administrators of this or any other specific sites. 654; see, e.g., In re 3021 6th Ave. N., 237 F.3d at 1041. Compare Amicus Br. 2154 RHOB (Oversight and Government Reform Committee) 2020 RHOB (Ways and Means Committee) This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. Leader McCarthy and Congressman Schweikert spoke with Valley Fever Researchers and patients to receive an update on the spreading fungal disease. The court ordered expedition of this appeal, id., and oral argument was heard on May 15, 2007. As our court has noted, the touchstone of the Clause is interference with legislative activities, see Brown & Williamson, 62 F.3d at 421; the Clause is therefore designed to protect Congressmen not only from the consequences of litigation's results but also from the burden of defending themselves' for their legislative actions, Helstoski v. Meanor, 442 U.S. 500, 508, 99 S.Ct. The 1989 Advisory Committee Notes to Rule 41(e)6 state: No standard is set forth to govern the determination of whether property should be returned to a person aggrieved either by an unlawful seizure or by deprivation of the property If the United States has a need for the property in an investigation or prosecution, its retention of the property generally is reasonable. at 709. HVC-210 (Speaker's Hearing Room) Webthe building and one in the southwest corner of the building. Applying these principles, we conclude that the Congressman is entitled, as the district court may in the first instance determine pursuant to the Remand Order, to the return of all materials (including copies) that are privileged legislative materials under the Speech or Debate Clause. Accordingly, we hold that a search that allows agents of the Executive to review privileged materials without the Member's consent violates the Clause. Presidents are identified in bold. At the same time, the remedy must give effect not only to the separation of powers underlying the Speech or Debate Clause but also to the sovereign's interest under Article II, Section 3 in law enforcement. The Filter Teams consisted of FBI agents with no prior role or connection to the investigation of Rep. Jefferson and whose roles in the investigation [were] confined to review [ing] the records seized from the Office to validate that they are responsive to the list contained in the warrant. Please visit https://www.loc.gov/visit for more information on visiting the Library of Congress. Please vist Alert DC at alert.dc.gov to sign up. 371; Counts 3 & 4, Solicitation of Bribes by a Public Official, id. House Galleries: When the House is in session, the Galleries will be open to Members of Congress who personally escort guests to the Galleries. To the extent the majority suggests that-if a Member can show disruption of his legislative activities-the government may be required to return non-privileged material to remedy a violation of the Clause, Maj. Op. Maj. Op. We hold that the compelled disclosure of privileged material to the Executive during execution of the search warrant for Rayburn House Office Building Room 2113 violated the Speech or Debate Clause and that the Congressman is entitled to the return of documents that the court determines to be privileged under the Clause. at 659. RAYBURN HOUSE OFFICE BUILDING, ROOM 2113, WASHINGTON, D.C. 20515, Appellant. Services include, but are not limited to, wheelchair loans, sign language interpreting services, and adaptive tours. Va. indictment filed June 4, 2007). 201 (bribery of public official), 18 U.S.C. In March 1955, House Speaker Sam Rayburn introduced an amendment for a third House office building, although no site had been identified, no architectural study had been done, and no plans prepared. 1619, 48 L.Ed.2d 71 (1976). "[2] at 81 (describing filtering procedures for paper records); id. The Office of Congressional Accessibility Services (OCAS) provides a variety of services for individuals with disabilities. For construction of the Rayburn House Office Building, the Congressional bill appropriated $2 million plus "such additional sums as may be necessary." To the extent the Executive expresses concern about the burdens placed upon the district court and attendant delay during judicial review of seized materials, the Remand Order illustrates a streamlined approach by narrowing the number of materials the district court may be required to review. Art. As we note below, this possibility is not applicable to the present case. at 660. 1425, 18 L.Ed.2d 577 (1967)); see also Johnson, 383 U.S. at 179, 86 S.Ct. United States v. Albinson, 356 F.3d 278, 279 n. 1 (3d Cir.2004). 1813, 44 L.Ed.2d 324 (1975)), the court rejected the view that the testimonial immunity of the Speech or Debate Clause applies only when Members or their aides are personally questioned: Documentary evidence can certainly be as revealing as oral communications-even if only indirectly when, as here, the documents in question do not detail specific congressional actions. at 37. Thus, our opinion in Brown & Williamson makes clear that a key purpose of the privilege is to prevent intrusions in the legislative process and that the legislative process is disrupted by the disclosure of legislative material, regardless of the use to which the disclosed materials are put. Stay up-to-date with how the law affects your life. 201(b)(2)(A); Counts 5 to 10, Scheme to Deprive Citizens of Honest Services by Wire Fraud, id. Opinion concurring in the judgment filed by Circuit Judge HENDERSON. [T]he physical search of the Office [was] conducted by Special Agents [with] no substantive role in the investigation of Rep. Jefferson. See Order of July 25, 2006. The warrant was lawfully issued because it does not seek evidence of [a] legislative act generally done in Congress in relation to the business before it, United States v. Brewster, 408 U.S. 501, 512, 92 S.Ct. The public entrance to the U.S. Capitol is through the U.S. Capitol Visitor Center. U.S. Const. In drafting the Speech or Debate Clause, the Framers drew upon English history and the long struggle for parliamentary supremacy against Tudor and Stuart monarchs during which successive monarchs utilized the criminal and civil law to suppress and intimidate critical legislators from publicly opposing the Crown. at 420. 3090, 41 L.Ed.2d 1039 (1974) (citing Speech or Debate Clause cases to illustrate judicial power to define scope of executive privilege); cf. See In re 3021 6th Ave. N., 237 F.3d at 1041 (citing DiBella v. United States, 369 U.S. 121, 131-32, 82 S.Ct. They include 18 U.S.C. To go to Rayburn, you must take the escalator down to the Rayburn sub-basement. Studio A But, if the United States' legitimate interests can be satisfied even if the property is returned, continued retention of the property would become unreasonable. Committees Committee and Subcommittee Assignments. The Supreme Court has not spoken to the precise issue at hand. 572, 57 L.Ed. 1813 (citing Doe v. McMillan, 412 U.S. 306, 314, 93 S.Ct. 2531 (emphasis added). The Architect of the Capitol, J. George Stewart, with the approval of the House Office Building Commission, selected the firm of Harbeson, Hough, Livingston & Larson of Philadelphia to design a stripped-down classical building in architectural harmony with other Capitol Hill structures. 137-38, the FBI agents who executed the search warrant shall continue to be barred from disclosing the contents of any privileged or politically sensitive and non-responsive items, id. TTY: 202-225-1904. [3], On May 20, 2006 FBI agents raided the Rayburn Building office of Democratic Congressman William J. Jefferson in connection to an ongoing bribery investigation, marking the first time the FBI had raided the office of a sitting congressman. 8. I, 6, cl. at 665-66, thereby potentially depriving the Executive Branch of records bearing on criminality, it is a suggestion I categorically reject. See Appellant's Br. United States Capitol Police 4. Neoclassical architecture in Washington, D.C. All articles with bare URLs for citations, Articles with bare URLs for citations from March 2022, Articles with PDF format bare URLs for citations, All Wikipedia articles written in American English, Infobox mapframe without OSM relation ID on Wikidata, Creative Commons Attribution-ShareAlike License 3.0, This page was last edited on 8 September 2022, at 22:26. Its shield does not extend beyond what is necessary to preserve the integrity of the legislative process, Brewster, 408 U.S. at 517, and it does not prohibit inquiry into illegal conduct simply because it has some nexus to legislative functions, id. 5. at 37; see also Rayburn, 432 F.Supp.2d at 110 (Carried to its logical conclusion, this argument would require a Member to be given advance notice of any search of his property, including property outside of his congressional office, such as his home or car, and further that he be allowed to remove any material he deemed to be covered by the legislative privilege prior to a search.). The filter team would determine: (1) whether any of the seized documents were not responsive to the search warrant, and return any such documents to the Congressman; and (2) whether any of the seized documents were subject to the Speech or Debate Clause privilege or other privilege. This court's jurisdiction of the Congressman's appeal rests on the collateral order doctrine. The parties disagree on precisely when that should occur and what effect any violation of the Member's Speech or Debate rights should have. 5. In order to maximize accessibility, this site has been designed to conform with: House.gov includes code and content provided by third parties. 1100 LHOB (Ways and Means Committee) of Scott Palmer, Elliot S. Berke, and Reid Stuntz, and Philip Kiko (former senior congressional staffers) at 26. of Stanley M. Brand et al. The FBI agents were to review and seize paper documents responsive to the warrant, copy all electronic files on the hard drives or other electronic media in the Congressman's office, and then turn over the files for review by a filter team consisting of two Justice Department attorneys and an FBI agent. That holding prohibited the production of certain records in a congressional subcommittee's possession in response to a civil subpoena. See 62 F.3d at 419. Rather he contends legislative and executive interests can be accommodated without such notice, as urged, for example by the Deputy Counsel to the House of Representatives: We're not contemplating advance notice to the [M]ember to go into his office to search his documents before anyone shows up, but rather that [t]he Capitol [P]olice would seal the office so that nothing would go out of that office and then the search would take place with the [M]ember there. Tr. 137-38. at 660, amounts to prohibited question[ing] because the Clause embodies a broad non-disclosure privilege, Maj. Op. WebIf you are looking for our District Office contact information, you can view our Offices page. WebRayburn House Office Building Horseshoe drive off South Capitol Street or entrance on Task Force Co-chairs Leader McCarthy and Rep. Schweikert hold press conference to announce NIH trial studying the efficacy of Fluconazole in treating Valley Fever at Banner University Medical Center in Phoenix, Arizona on October 17, 2016. Id. 2018, 36 L.Ed.2d 912 (1973)), recognizing that the privilege is absolute once it attaches begs the question whether the Clause attaches to begin with.10 Significantly, in Brown & Williamson we expressly recognized that the Clause's testimonial privilege might be less stringently applied when inconsistent with a sovereign interest, such as the conduct of criminal proceedings. Cf. at 36. 2359 RHOB (Appropriations). Indeed, the application accompanying the warrant contemplated it. WebThe entrance to the Rayburn House Office Building is on Independence Avenue. 1310 LHOB (House Administration Committee) Washington, DC 20515. Learn more about FindLaws newsletters, including our terms of use and privacy policy. Copyright 2023, Thomson Reuters. Also in the third floor basement is a shooting range run by the U.S. Capitol Police and a basketball court. WASHINGTON, DC Today, Co-Chairs of the Congressional Valley Fever Task Force David Schweikert (AZ-06) and Kevin McCarthy (CA-23) joined in celebrating Valley Fever Awareness Week in Arizona. Having found probable cause to believe that Rep. Jefferson's congressional office contains property constituting evidence of the commission of bribery of a public official, wire fraud[,] bribery of a foreign official [and] conspiracy to commit these crimes and having issued a search warrant aimed solely at such evidence, see Warrant Aff. at 659-61 (relying on Brown & Williamson because [t]he Supreme Court has not spoken).2 But Brown & Williamson's brief comments regarding the Clause in the criminal context-which comments importantly acknowledge the Clause's less categorical scope in that context3 -REMAIN DICTA NO MATter how profound. maj. op. Currently, Immuno-Mycologics, Inc. 2059 Rayburn House Office Building R. Crim. 2614.7 Nevertheless, my colleagues conclude that the holding in Brown & Williamson, see 62 F.3d at 418-21, establishes that the disclosure of legislative material during the execution of a search warrant, Maj. Op. Find event and ticket information. The U.S. House of Representatives is fully accessible to people with disabilities. In the meantime, the court enjoined the Executive from reviewing any of the seized documents pending further order of this court. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web.
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