DONALD RAY WOOLBRIGHT, PLAINTIFF, V. FEDERAL BUREAU OF INVESTIGATION, CENTRAL INTELLIGENCE AGENCY, DEFENDANTS.

• Document Type: FOIA
• Collection: FOIA Collection
• Document Number (FOIA) /ESDN (CREST): 06763947
• Release Decision: RIFPUB
• Original Classification: U
• Document Page Count: 3
• Document Creation Date: March 9, 2023
• Document Release Date: January 13, 2020
• Case Number: F-2018-02241
• Publication Date: May 11, 1978

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Ant Gproved for Release: 2019/11/22 C067639a .1 I _ _
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WILLIAM D. KELLER
untuo st2tes A ttprr,key
FRnERICK M. BROSIO, JR
Assistant U.S. Attorney
Chief, Civil Division
STEPHEN D. PETERSEN
Assistant U.S. Attorney
1100 U.S. Court House
312 North Spring Street
Los Angeles, Cali(ornia 90.012
Telephone: [phone]
Attorneys for Defendants
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT. OF CALIFORNIA
DONALD RAY WOOLBRIGHT, )
)
Pfaintiff, )
)
v. ) NO. CV 76-2448-LEW
)
FEDERAL BUREAU OF INVESTIGATION, )
CENTRAL INTELLIGENCL: AGENCY, )
)
Defendants. )
)
)
AFFIDAVIT.
STANSFIELD TURNER, being first duly sworn, does hereby depose and say:
1. I am the Director of Central Intelligence and he executive head of the Cen-
tral Intelligence Agency (CIA). 1 have served in this position since 9 March 1977..
2. Pursuant to the National Security Act of 1947, the-CIA is responsible for,.
among other things, advising the National Security Council (N.SC) in matters con-
cerning such U.S. intelligence activities as relate to national security; making
recommendations, to the NSC for the coordination of U.,S. intelligence activities;
_
correlating, evaluating and disseminating intelligence relating to national security;
and performing other functions and duties at the direction of the NSC. As Director
of Central Intelligence, I am responsible under the National Security Act of 1947 for
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set forth the duties and responsibilities of the Director of Central Intelligence and
the Ccntr:.1 Intelligence Agency 2re sahr.nitted herewith as Attachment A to this _
affidavit.
4. I am familiar with the contents of the complaint in the captioned
case. I have also been informed of the history of the captioned litigation
and I make the following statements based upon my personal knowledge, upon
facts obtained by me in my official capacity, and upon conclusions reached in
accordance therewith.
5. The Hughes .Glomar Explorer (HGE) Project was specifically authorized
by an appropriate committee of the NSC. The Project involved the design, con-
struction, operation arbil.use of a ship which came to be known as the Hughes
Glomar Explorer.. Information concerning the background, precise purpose and
details of implementation of the HGE Project remains classified because public
disclosure of such information', in my judgment, could reasonably be expected to
result in damage to the national security. The Secretary of State has stated an
identical judgment in similar litigation. A certified true copy of Mr. Vance's
affidavit in the litigation Military Audit Project, et al. v. Central Intelligence
Agency, Civil Action No. 75-2103, United States District Court for the District of
Columbia is submitted herewith as Attachment B to this affidavit.
6. The action responsibility for the HGE Project was assigned to the CIA
pursuant to its statutory authority to conduct certain intelligence activities free
from requirements of public disclosure. At the time of theinception of the HGE
Project, it had been determined that all information concerning the Project which
would reveal its intelligence purposes including, specifically, any information
which would disclose United States Government involvement in .the Project would
be classified in the interest of national security. Consequently, arrangements
were made by CIA with private corporations, including Summa Corporation,
Hughes Tool Company, and Global Marine, Inc.. to provide a commercial facade
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CIA's involvement in the HOE Project could not be disclosed for reasons of
national security. In the spring of 1977. after I was appointed by President
Carter, I caused this position to be reexamined. and determined, with the con-
currence of Dr. Zbigniew Brzezinski, the Assistant to the President for
National Security Affairs, that CIA's involvement in. the HGE Project could now
be acknowledged without incurring the risk of undue harm to the national security.
8. Consequently, I instructed Appropriate officials of the CIA to search for
all documents responsive to the plaintiff's Freedom of Information request and to
effect the redactions required pursuant to my statutory responsibility as Director
of Central Intelligence to protect intelligence sources and methods and to protect
information which if disclosed could reasonably be expected to damage the national
.defense and foreign relations. I have reviewed the Affidavits of Ernest J. Zellmer,
Associate Deputy Director of the Directorate of Science and Technology, and
Robert W. Gambino, Director of Security, wherein the actual redactions and reasons
therefore are set forth with specificity and do hereby concur and ratify same.
TANSFIELD T
CITY OF WASHINGTON
DISTRICT OF COLUMBIA �
Subscribed and sworn to before me this lltd4ay of May 1978.
My commission expires;
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