The Law Office of

David E. Coombs
John NtcHugh Secretary of the Army 101 Army Pentagon \Tashington, DC 2031 0-01 01
N,{.

President Barack F{. Obama Through the Pardon Attorney

Department ofJustice Washington, D.C. 20530

Septembet 3,2073

Deat President Obama:

this letter to present Private Btadley Manning's petition fot commutation of his sentence. Pdvate Manning requests that you consider the following documentation when this fequest:

I am wdting

^clrrgupon a) Petition for Commutation of Sentence dated 21, August 2013 b) Guilty Plea Inquiry from unauthenticated record of ttial dated 28 February 2073 c) Letter from Amnesty International dated 23 Augast201.3 d) Testimony of retfued Sergeant First Class Paul Adkins dated 13 August 2013 e) Counseling Statement of Master Sergeant Adkins datedT June 2010 I E-mail ftom Pdvate Manning to Master Sergeant Adkins dated24 Aprl,
201.0

g) Memorandum fot
Decembet 2009
2010

Record written by Master Setgeant Adkins dated21,

Sergeant Adkins dated 26

h) Memorandum fot Recotd written by Master

April

i) Memorandum for Record wdtten by Mastet Sergeant Adkins dated 8 May 201,0 j) Testimony of Captain Michael lTorsley dated 14 August 2013
k) Testimony of Lieutenant Commandet David Moulton
dated 14 August 2013

l)

Redacted Sanity Board Evaluation of Private Manning dated22 Aprn 2011

On21. August 2013,Pivate Manning was sentenced to 35 years in pdson fot giving information to a journalist. The length of Pdvate Manning's sentence is one that we would expect for someone who disclosed information in order to harm the United States or who disclosed information for monetary gain. Private Manning did neithet. Instead, he disclosed information that he believed could spark a meaningfrrl public debate on the costs of war, and specifically on how we value human life.

II SOUTHANGELL

ST.

#317

PRovrDENcE, RI02906

TEL: (508) 689-4616

o FAX: (508) 689-9282

Although the govemment is entided to protect sensitive infotmation, the documents ptotection. Many of the documents teleased by Private Manning were either unclassified or contained information that the public had a right to know. None of the disciosed documents caused any rcal damage to the United States. Instead, these documents simply embattassed our country by revealing misconduct by the Departrnent of Defense and unethical practices by the Department of State.

in this

case did not medt

rely upon whisdeblowers, even in those instances that might cause embarassment, to keep out government accountable to its people. Private Manning is a military whistleblower. He disclosed documents that were vital fot a healthy public debate about our conduct in Iraq and Afghanistan, our detention policies at Guantanamo, and out diplomatic activities around the world. The sentence given to him by the military judge grossly exaggerates the setiousness of his conduct. The sentence was disptoportionate to both the offense and the offender. It will undoubtedly have a chilling effect on future whisdeblowers and damage the public's perception of military justice.
Sevetal civil dghts organszaions have criticized the harsh sentence given to Ptivate Manning. Lisa Goitein, who co-directs the Brennan Center forJustice's Liberty and National Security Program, called the 35 year sefltence "unprecedented" and stated "it is dtamatically longet than the longest senteflce evet served fot disclosing classified information to the media, which was two years." Ben Wiznet, the directot of the American Civil Liberties Union's Speech, Privacy, and Technology Ptoject, said "alegal system that doesn't distinguish between leaks to the press in the public intetest and tteason against the nation will not only produce unjust results, but will deprive the public of critical information that is necessa{y for democratic accountability." Anne FitzGerald, the director of Amnesty Intemational's Reseatch and Crisis Response, said "Bradley Manning should be shown clemency in tecognition of his motives for acting as he did, the treaffnent he endured in his eady pte-trial confinement, and the due process shottcomings during his ftial."

'$7e

Pdvate Manning has already pal.d aheavy pdce for his conduct. He has been held for more than thtee years in military conf,nement. A substantial portion of that confinement was spent in unlawful solitary confinement at Marine Corps Base Quantico. He endured a thtee-year protracted legal process and faced a meritless the enemy offense. I urge "iditg you to consider this mattet closely and to take a positive step towards protecting whistleblowers who telease infotmation to the rnedia fot the public good by eithet teducing Private Manning's sentence to time served, or by granting him a frrll pardon.

I
DAVID
E,.

COOMBS

11

SoUTH ANGELL ST. #3L7

PRovIDENcE, RI 02906

TEL: (508) 689-4616

o FAX: (508) 689-9282

Petition for Commutation of Sentence

Please read the accompanying instntctions carefully before contpleting the applicalion. Type or print the anst'ers in ink. Each question mus! be ansu,ered.fully, truthfulll,and accurately. If the space.for any ansv'er is insufficienl, \,ou may

completetheansv,eronaseparatesheetofpapet'andattachittothepetition. I'oumayattachant644,,,orol documenntiott thatyoubeliet'eisrele'r'anttoyourpelition. Thesubmissionofanymaterial,.falseinformalionispunishablebyuptofir,e

years'imprisonment and artne of not more than $250,000. 18 L/.SC. $$ 100l and 3571.

Relief sought:

@heck one)

in

Reduction of Prison Sentence Only

iH Remission of Fine and/or Restitution Only To The President of the United States:

Reduction of Prison Sentence and Remission Other Pardon/Commutation of Sentence

The undersigned petitioner, a Federal prisoner, prays for commutation of sentence and in support thereof states as follows:
1.

Full name: Bradle

Reg.

E,dward

Mannin

No. 89289

Social Securitv No. XXX-XX-XXXX

Confined in the Federal Institution at United States Disciplinary Barracks Date and place of birth: December
I7

987 in Crescent Oklahoma

Are you a United States citizen?

lf you are nol a L,'.5. citi:en, indicate your counlry
o.f

iQI ,vesiBno

citi:enship

Have you ever applied for commutation of sentence before?

Ayes, state the date(s) on which you applied, and lhe date(s) v,hen you v'ere nolified of the petition(s).

if,

yesi'[Zlno

final decision on 7;671v

2.

I was convicted on a plea

of
etc.

mixed
(guiln,, not

gt

plea

in the United States District Court

First Circuit
(identifi'state)

ln, nolo contendere)

for the U.S. Army Court Martial District of

(lt orthe

rn, Il'estet'n,

of the crime of:

United States Departntent of Justice

Januarr'2002

Ofiice of the Pardon Attot'net'

Ll'ashington, D.C. 20530

(State specifc offense(s), prot'ide citation ofstatute(s) t'iolated,

ifknotrn)

I was sentenced

08121 2013 on (monthidat) to imprisonment for (yeor)

,

35

(length ofsentence)

vears

to pay

E a fine of $

(do not include special assessntent)

restitution of $

, and to

supervised release or
(length of sentence)

sp"cial parole for

, andlor to probation for

years of age when the offense was committed.

.Iwas

22

3.

I began service of the sentence of imprisonment on 07127 2010 .and I am projected to

(month'day)
6'ear)

be released from confinement

on

Are you eligible for

lf yes, indicate the date
granted or denied

parole?

TBD (nontludal)
for

6'ear)

iElyeslEl,no
release, and state v'hether your application Jbr parole u'as

v,hen you became eligible

Have you paid in full any fine or restitution imposed on you?

lf'thefine or restitution has not
been

itr yeqEno

paid in.full, state lhe remaining balance.

4.

Not applicable. Did you appeal your conviction or sentence to the United States Court of Appeals?
Is your appeal concluded? lf yes, indicate v'hether your cont,iclion or senlence vas aflirnted or retersed,

if, ve$Eno

i[J -"*eni[Ztto the date of the decisiott, and the citalion(s) to any published court opinions- Proyide copies ofany unpublished cotul decisions concerning such appeals, if they are available to you.

I will appeal my conviction and sentence to the Army Court of Criminal Appeals once my record of trial is complete. My appeal, however, is not expected to be filed before the end of 20r4.

Did you seek review by the Supreme Court?

Is your appeal concluded?
lf yes, indicate y,hether your petition vas g'anted or denied and the date of the decision.

iU vesiUltro

itr ye$Eno

Petition

for Conrntutatiotl of Sentence

Puge 2

Have you filed a challenge to your conviction or sentence under 28 U.S.C. $ 2255 (habeas i[f ye$Vlno

corpus)?

Is your challenge

concluded?

lflyeslHno

Ifyes, indicate v'hether your motion u,as granted or denied, the date of the decision, and the citation(s) to any published cotrrt opinions, if knov'n. Provide copies of any unpublished court decisions concerning urch motions, theyareayailabletoyou. Ifyouha,"efiledmorethanonepost-convictionnotion,providetherequesledinformalion
.for each such molion.

if

licable.

J.

Provide a complete and detailed account of the offense for which you seek commutation, including the full extent of your involvement. If you need more space, you may complete your answer on a separate sheet of paper and attach it to the petition. I have attached my suilty plea inquiry from my court-martial which provides a detailed account of the offenses for which I am seekins a Dardon and commutation. I have also attached other
relevant excerpts from the unofficial record of trial which captures selected testimony for your

consideration. This testimony discusses both rny acceptance of responsiblity and the factors
that impacted the decisions that I made to disclose information to the American public.

P eIiti

on fo

C onunutat

on of Sent e n ce

Page 3

6.

Aside from the offense for which commutation is sought, have you ever been arrested or taken into custody by any law enforcement authority, or convicted in any court, either as a juvenile or an adult, for any other incident? iHyesiBno
Foreachsuchincident,provide: thedate,thenatureofcharge,thelavenforcementauthorilyinvolved,andthe

final dispositionoftheincident. r'ounrustliste,tetyt,iolation,includingtrffictiolalionsthatresultedarreslorin

an criminal charge, such as driving under the influence.

Arrests:

Convictions:

etit i on

for

onmrutat i on of

Se

ntence

Page

7.

State your reasons for seeking commutation of sentence. If you need more space, you may complete your answer on a separate sheet of paper and attach it to the petition.

The decisions that I made in 2010 were made out of a concern for my country and the world that we

live in. Since the trasic events of 9-l l. our country has been at war. We have been at war with an

military reports on a daily basis that I started to question the morality of what we were doing. It was
at this time that I realized that in our efforts to meet the risks posed to us by the enemy, we had

bv the al-Maliki government: and we stomached countless other acts in the name of our war on terror.

When these cries of patriotism drown out any loeically based dissention, it is usually the American Soldier that is eiven the order to carrv out some ill-conceived mission. Our nation has had similiar dark

9-11

will

one day be viewed in a similar

lieht. As the late Howard Zinn once said "There is not a flag

larqe enouqh to cover the shame of

killine innocent Deople." I understand that my actions violated the

law. I resret if mv actions hurt anvone or harmed the United States. It was never mv intent to hurt
anyone. I only wanted to help people. When I chose to disclose classified information, I did so out of
a love for my country and a sense of dutv to others.

If you deny my request for a pardon, I will serve

my time knowing that sometimes vou have to Dav a heavv price to live in free society.

I will eladlv oay that price if it means we could have a country that is truly "conceived in libertv, and

e ti

ti on

for

C omnnttat

ion of

Se nte

nce

Page 5

I hereby certiff that all answers to the above questions and all statement contained herein are true and correct to the best of my knowledge, information, and belief. I understand that any intentional misstatements of material facts contained in this application form may cause adverse action on my petition for executive clemency and may subject me to criminal prosecution.

Respectfully submitted this

21st

day

of August , (month)

2013
(year)

S ignature

of

Pe titione

P e tition

for

C ommutat i on

of

Se

ntence

Page 6