UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLOMBIA

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP89B01356R000400700006-3
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 26
• Document Creation Date: December 27, 2016
• Document Release Date: July 11, 2013
• Sequence Number: 6
• Publication Date: November 3, 1987
• Content Type: MISC

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ACTION'
INFO
DATE
INITIAL
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DCI
DDCI
EXDIR
D/ICS
DDI
DDA
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DDO
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DDS8T
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Chm/NIC
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GC
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IG
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Compt
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D/OCA
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D/PAO
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D/PERS
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?Pb
D/Ex Staff
iSecur
ity
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SUSPENSE
Date
3637 (1081)
?
Execdtive Secretary
3 Nov '87
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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN FEDERATION OF GOVERNMENT
)
EMPLOYEES, AFL-CIO
)
80 F Street, N.W.
)
Washington, D.C. 20001
)
[phone],
and
)
)
JIM STINCHCOMB
)
107 Westerfield Drive
)
Goose Creek, S.C. 29445
)
[phone]
)
and
)
JAMES DOUGLAS
)
484 Manchester Way
)
Vacaville, Calif. 95688
)
[phone]
)
and
)
LOUIS C. BRASE
)
4112 Loop 306
)
St. Angelo, TX 76904
)
[phone]
)
Plaintiffs,
)
)
v.
)
)
STEVEN GARFINKEL, DIRECTOR
)
Information Security Oversight Office
)
General Services Administration
)
18th & F Streets, NW
)
Washington, D.C. 20405
)
and
)
TERRANCE C. GOLDEN, ADMINISTRATOR
)
General Services Administration
)
18th & F Streets, NW, Rm. 6137
)
Washington, D.C. 20405
)
and
)
FRANK CARLUCCI, DIRECTOR
)
National Security Council
)
The White House
)
Washington, D.C. 20500
)
and
)
WILLIAM WEBSTER, DIRECTOR
)
Central Intelligence Agency
)
Washington, D.C. 20505
)
and
)
1
Civil Action No. 87-2412
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CASPAR WEINBERGER,
)
Secretary of Defense
)
The Pentagon
)
Washington, D.C. 20310
)
and
)
HON. EDWARD C. ALDRIDGE
)
Secretary of Air Force
)
Washington, D.C. 20310
)
and
)
HON. JOHN 0. MARSH, JR.
)
Secretary of the Army
)
The Pentagon, Rm. 3E 718
)
Washington, D.C. 20310-0100
)
and
)
HON. JAMES H. WEBB, JR.
)
Secretary of the Navy
)
The Pentagon, Rm. 4E 686
)
Washington, D.C. 20350-1000
)
and
)
UNITED STATES OF AMERICA
)
Defendants.
)
)
COMPLAINT
(Declaratory and Injunctive Relief)
This is an action brought by the American
Federation of Government Employees, AFL-CIO and plaintiff
civilian federal employees seeking to have enjoined and
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JURISDICTION
1. Jurisdiction is conferred on this Court pursuant to 28
U.S.C. 1331, and 28 U.S.C. 1361, and 5 U.S.C. 702. This
action is commenced under 28 U.S.C. 2201 et seq. and the
First and Fifth Amendments to the United States
Constitution,
seeking to permanently restrain
implementation of Forms 189 and 4193, and a declaration
that the Forms are unconstitutional and violative of
statutory law.
VENUE
2. Venue property lies in this District Court pursuant to
28 U.S.C. 1391(e).
PARTIES
3. Plaintiff, American Federation of Government
Employees, AFL-CIO (AFGE) is a labor organization that
represents approximately 700,000 Federal Employees
worldwide, including the Department of Defense. AFGE
seeks to preserve the economic, civil and constitutional
rights of employees in its exclusive bargaining units
through collective bargaining, lobbying efforts and
litigation. AFGE is suing on its own behalf and on behalf
of Federal employees being required to sign these forms as
a condition of retention of their security clearances and
preservation of their federal employment.
4. Plaintiff Jim Stinchcomb is a WL-8 Motor Vehicle
Operator Leader (Ordinance Missile Handler) with the
3
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Polaris Missile Facility, Atlantic in Charleston, South
Carolina. Plaintiff Stinchcomb has been instructed to
sign Form 189. Plaintiff Stinchcomb has presently refused
to sign the Form 189 but has been threatened with security
clearance revocation and resultant loss of employment if
he does not sign the form.
5. Plaintiff James H. Douglas is a GS-5 Firefighter
(Structure) with the Department of Navy, Naval Weapons
Center. Plaintiff Douglas' execution of the SF 189 was
achieved only by threat of revocation of his security
clearance and the resulting loss of his employment with
the federal government.
6. Plaintiff Louis Brase is a Training Manager at
Goodfellow Air Force Base. Plaintiff Brase has signed the
SF 4193 without advice of counsel, and under coercion and
compulsion that failure to execute SF 4193 would result in
revocation of his security clearance, retention of which
is a condition of his employment. On August 4, 1987,
Plaintiff Brase refused to sign SF 189 and at that time
the sensitive compartmented information access and
clearances granted him in January, 1986, were suspended.
7. Defendant Steven Garfinkel is the
Information and Oversight Office (IS00),
Administrator of General Services and
President. As Director,
delegated
Director of the
appointed by the
approved by the
Defendant Garfinkel has been
the implementation and monitorship functions of
the information security program, including the
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responsibility to promulgate directives such as NSDD 84.
Defendant Garfinkel is sued solely in his official
capacity.
8. Defendant Terence C. Golden is the Administrator of
the General Services Administration. Defendant Golden is
responsible for implementing and monitoring the
information security program established pursuant to
Executive Order 12356. Defendant Golden is sued solely in
his official capacity.
9. Defendant Frank Carluiii is the Director of the
National Security Council. Defendant Carlucci is
responsible for approving directives, such as NSDD 84,
which are developed by the Director, ISM. Defendant
Carlucci is sued solely in his official capacity.
10. Defendant William Webster is the Director of the
Central Intelligence Agency. Defendant Webstet has been
entrusted by the Executive Order 12356 with the function
of creating special access programs to control access of
t sensitive information classified pursuant to that Order.
The Director of Central Intelligence Agency promulgated
and administers Form 4193, a nondisclosure agreement, as a
condition of access to sensitive compartmented
information. Defendant Webster is sued solely in his
official capacity.
11. Defendant Caspar Weinberger is the Secretary of
Defense,
an executive department of the Federal
Government. The Department of Defense is administering SF
189 to its federal civilian employees with or without
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security clearances and Form 4193 to those with access to
sensitive compartmentdlized information, and has
established a sample indoctrination briefing, DOD 5200.1
PH 1 (July, 1985) to implement this program. Defendant
Weinberger is sued solely in his official capacity.
12. Defendant Edward Aldridge is the Secretary of the
Air Force. Defendant Aldridge has implemented the usage
of SF 189 and 4193, and is responsible for taking the
within-described actions against Plaintiff Brase.
Plaintiff Aldridge is sued solely in his official
capacity.
13. Defendant John Marsh is the Secretary of the
Department of the Army. Defendant Marsh has implemented
the usage of sF 189 and 4193 and is being sued solely in
his official capacity.
14. Defendant James H. Webb, Jr. is the Secretary of
the Department of Navy. Defendant webb has implemented
?the usage of SF 189 and 4193 and is being sued solely in
his official capacity.
BACKGROUND
15. By Executive Order No. 12356, dated April 2, 1982,
President Reagan prescribed a uniform system for
classifying, declassifying and safeguarding national
security information. The Executive Order acknowledged
the essential right of the public to be informed
concerning the activities of the government, but provided
that certain information be protected against unauthorized
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disclosure. Pursuant to that Order, the National Security
Council is entrusted with providing overall policy
direction for the information security program. The
Administrator of GSA is given the responsibility for
implementing and monitoring the classification program and
delegating the implementation and monitorship functions to
the Director of the Information Security Oversight Office
(ISOO). The Director of ISOO is authorized to develop, in
consultation with agencies, and promulgate, subject to the
approval of the National Security Council, directives for
the implementation of the Order, which are binding on the
agencies.
16. On March 11, 1983, the Director of ISOO issued
National Security Decision Directive (NSDD) 84, which was
signed by the President. It provides that its terms are
"in addition to the requirements set forth in Executive
Order 12356." Paragraph la of NSDD 84 requires that all
persons with authorized access to classified information
shall be required to sign a nondisclosure agreement as a
condition of access. Paragraph lb of the Directive
required all persons with access to Sensitive
Compartmented Information (SCI) to sign a nondisclosure
agreement (SF 4193) providing for mandatory life-long
prepublication review as a condition of access to SCI and
other classified information. In Paragraph lc of the
Directive, the Director of ISOO is assigned the
responsibility of developing standardized forms that
satisfy the requirements of paragraph la and lb of the
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Directive.
17. On or about August 24, 1983, ISOO developed
Standard Form 189 entitled "Classified Information
Nondisclosure Agreement." Pursuant to 32 C.F.R. 2003.20,
this form is required to be executed by all employees of
executive branch departments and independent agencies as a
condition of access to classified information.
18. SF 189 provides that in consideration for being
granted access to classified information, specified as
information that is either classified or classifiable
under the standards of Executive Order 12356, execution of
and acceptance of the obligations of the Form are
required. Employees are advised by this Form that breach
of the agreement may result in termination of security
clearances, removal from positions of trust and
termination of their employment, as well as criminal
prosecution. The Form requires acknowledgment that all
information to which an employee may obtain access by
signing the Agreement is now and will forever remain the
property of the U.S. Government, and an assignment of all
royalties and remunerations that have resulted or may
result from any disclosure, publication or revelation not
consistent with the terms of the Agreement. Employees are
assured that all questions have been answered to their
satisfaction prior to signing the form.
19. Classifiable information has been defined by 'SOO
as information which would have been marked as classified
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"but which as a result of negligence, time constraints,
error, lack of opportunity or oversight, has not been
marked as classified information." Moreover, ISO()
maintains that a party to SF 189 would "violate its
nondisclosure provisions only if he or she disclosed
without authorization classified information or
information that he or she knew or reasonably should have
known was classified, although it did not yet include
required classification markings." The government
reserves the right to retroactively reclassify information
for a period of up to fifty years.
20. Individually named Plaintiffs and employees
represented by Plaintiff AFGE have been compelled to sign
SF 189 as a condition of retention of their security
clearances and maintenance of their federal employment.
Plaintiff Stinchcomb and other employees who refuse to
sign the SF 189 are subject to the revocation of their
security clearance and the termination of their
employment.
21. On or about August 24, 1983, the federal
government also issued SF 4193, entitled "Sensitive
Compartmented Information Nondisclosure Agreement." By
its terms, this Agreement required employees who have been
granted access to information known as Sensitive
Compartmented Information (SCI) to submit for
prepublication review all materials, including works of
fiction that he or she contemplates disclosing to any
person not authorized to have such information or that is
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prepared for public disclosure, which contains any SCI;
classified information from intelligence reports Or
estimates;
activities,
or any information concerning intelligence
sources or methods.
22. In the early part of 1984, President Reagan
withdrew and deleted paragraph 1(b) of the NSDD 84.
Consequently, the 1983 version of the SF 4193 form was no
longer operative. However, a virtually identical version
of the SF 4193 in existence since December 1981 remains
operational, and its execution remains as a required
condition to access to SCI and retention of positions
requiring that access. That 1981 version of Form 4193,
also contains a lifelong prepublication review component.
It provides that SCI involves or derives from intelligence
sources or methods and is classified or classifiable. It
provides further that any information to which an employee
may obtain access is now and will forever remain the
property of the U.S. Government, and that the employee
assigns to the U.S. Government all rights, title,
interests and remunerations that have resulted or may
result from any disclosure, publication or revelation not
consistent with the terms of this Agreement.
VIOLATIONS OF LAW
COUNT I
23. Execution of SF 189 and 4193 are compelled due to
the real threat of revocation of security clearance and
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consequential loss of employment. In many instances the
forms have already been signed, coerced under the
circumstances. The required execution of the forms with
the vague, overlybroad and wholly ambiguous proscription
for the release of "classifiable" information is violative
of the First Amendment to the United States Constitution's
protection against abridgement of freedom of speech and
the right to petition Congress.
24. The prohibition against disclosure of information
not presently classified by authorized officials, but
which May subsequently be construed as classified,
presents an unreasonably inhibiting and chilling effect
upon the free exchange of legitimate matters of public
discussion.
25. The SF 189, in violation of the First Amendment,
exposes an employee to liability for releasing information
from public sources which become classified after sources
were published, or even declassified information that has
entered the public domain.
26. The lifetime prepublication review requirement for
employees with SCI access contained in Form 4193
constitutes an unlawful prior restraint on the exercise of
First Amendment rights and a virulent scheme of licensing
and censorship.
27. Department of Defense in DOD 5200: 1-PH 1 has
indicated that some agency regulations in effect before
March 1983 require employees with any clearance to submit
any and all materials for prepublication review. This
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constitutes an impermissible prior restraint on the
exercise of First Amendment rights.
28. The suspension on August 4, 1987 of Plaintiff
Brase's SCI clearance and the removal from his position as
Training Manager at Goodfellow Air Force Base because of
his refusal to sign the SF 189 is an unlawful interference
with his First Amendment right of free speech.
COUNT II
29. Plaintiffs reallege and incorporate by reference
the allegations contained in paragraphs 1 through 28.
30. Requiring execution of SF 189 and 4193 is
violative of the employees Fifth Amendment protections
against deprivation of liberty and property, without due
process of law.
31. The terms in SF 189 and 4193 "classifiable," and
"indirect unauthorized disclosure," are unconstitutionally
vague. The spectre of termination from employment and
civil and criminal liability for disclosure under these
circumstances renders the forms constitutionally defective
under the Fifth Amendment. The absence of prior notice or
hearing to determine what is "classifiable" information
subjects employees to revocation of security clearances
and termination of employment in violation of the due
process clause.
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32. The suspension on August 4, 1987 of Plaintiff
Brase's SCI clearance and the removal from his position as
Training Manager at Goodfellow Air Force Base because of
his refusal to sign the SF 189 constitutes an unauthorized
interference with liberty, property and dignitary
interests guaranteed him by the Fifth Amendment.
COUNT III
33. Plaintiffs reallege and incorporate by reference
the allegations contained in paragraphs 1 through 32.
34. Requiring execution by Plaintiff Federal Employees
of Forms 189 and 4193 deprives them of equal protection of
the law as guaranteed by the Fifth Amendment of the United
States Constitution.
35. Private entrepeneurs who are awarded federal
government contracts are required to sign SF 189A. Unlike
federal employees, private contractors may only be subject
to loss of security clearance for disclosure of classified
information, not classifiable information. This disparate
treatment of Plaintiff federal employees caused by
imposition of this vague "classifiable" standard which
makes it impossible for an employee to govern his or her
conduct, is not rationally related to any legitimate
government purpose and is unconstitutional.
COUNT IV
36. Plaintiffs reallege and incorporate by reference
the allegations contained in paragraphs 1 through 35.
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37. Section 2302(b)(8)(A) of Title 5 U.S.C., Civil
Service Reform Act, protects the rights of federal
employees to disclose to the public information which the
employee reasonably believes evidences a violation of any
law, rule or regulation, or mismanagement, a gross waste
of funds, an abuse of authority or a substantial and
specific danger to public health or safety, if such
disclosure is not specifically prohibited by law and if
such information is not specifically required by Executive
Order to be kept secret in the interest of national
defense or the conduct of foreign affairs.
38. Section 2302(b)(8)(B) provides similar protection
for like disclosures to the Special Counsel of the Merit
System Protection or the Inspector General of an agency or
agency head designee, without limitation by other laws or
Executive Orders compelling secrecy in the interest of
national defense.
39. SF 189 and 4193 are not laws or Executive Orders
which may constrain the availability of these
whistleblower protection, with respect to general
disclosures to the public. Nor is NSDD 84 a law or
executive order within the contemplation of 5 U.S.C.
2302(b)(8)(A),
as NSDD 84 clearly delineates that its
terms are in addition to Executive Order 12356. Nothing
in Executive Order 12356 requires nondisclosure agreements
of this sort for implementation, contractual or otherwise.
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40. The imposition of SF 189 and 4193 has the effect
of inhibiting the disclosure of violations of law, waste
of funds, abuse of authority and specific dangers to
public health or safety, by eliminating the whistleblower
protections provided by statute. These compelled
authorizations to revoke security clearances, terminate
employment and take other disciplinary action for lawful
disclosures of non classified, but potentially
classifiable information, of this important _nature,
are violative of the anti-reprisal protections of the
Civil Service Reform Act.
COUNT V
41. Plaintiffs reallege and incorporate by reference
the allegations contained in paragraphs 1-40.
42. Section 7211 of Title 5 provides that the right of
Federal employees to petition members of Congress or to
furnish information to either House of Congress or to a
Committee or member thereof, may not be interfered with or
denied.
43. The blanket prohibitions in SF 189 and 4193
against disclosing potentially "classifiable"
information, albeit presently unclassified, is in direct
contravention of 5 U.S.C. 7211.
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COUNT VI
44. Plaintiffs reallege and incorporate by reference
the allegations contained in paragraphs 1-43.
45. Public Law 96-303, entitled the Code of Ethics for
Government Service, requires any person in government
service to "expose corruption whenever discovered."
46. Imposition of the terms of SF 189 and 4193,
requiring that a federal employee not disclose information
that is "classifiable," is inconsistent with the terms of
Public Law 96-303 and is violative of that statute.
COUNT VII
47. Plaintiffs reallege and incorporate by reference
the allegations contained in paragraphs 1-46.
48. The Administrative Procedure Act prohibits agency
action which is arbitrary, capricious or an abuse of
discretion. 5 U.S.C., Sec. 706(2)(A).
49. The requirement that Plaintiffs execute SF 189 and
4193 with its speculative "classifiable" determination is
arbitrary, capricious, and an abuse of discretion.
Requiring Plaintiffs to exercise the authority reserved by
Executive Order to prescribed individuals specifically
trained and fully conversant with classification standards
and .designations, unduly exposes them to risk of loss of
employment and criminal liability.
50. ISO() exceeded its authority and abused its
discretion by mandating that individual Plaintiffs agree
not to disclose "classifiable" information as a condition
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of retention of security clearance and employment.
COUNT VIII
51. Plaintiffs reallege and incorporate by reference
the allegations contained in paragraphs 1-50.
52. Defendants have exceeded their authority by their
continued usage of SF 4193, in violation of 5 U.S.C.
706(2)(C).
53. In the latter part of 1984, President Reagan
specifically withdrew paragraph 1(b) from NSDD 84 and
declared an intent not to reinstate that paragraph and
place a moratorium on nondisclosure agreements with
prepublication review. Paragraph 1(b) of NSDD 84 was the
purported authority for the CIA's establishment and
utilization of the nondisclosure agreement as a condition
of access to sensitive compartmentalized information. The
Defendants continued use of the prior 1981 version of this
agreement (Form 4193) is without statutory or executive
authority and operates in clear excess of any delegated
authority.
COUNT IX
54. Plaintiffs reallege and incorporate by reference
the allegations contained in paragraphs 1-53.
55. The Copyright Clause of the United States
Constitution, Article I, Section 8, Clause 8, confers upon
Congress alone the authority to secure exclusive rights to
particular writings and discoveries.
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a
56. The Copyright Act specifically bars any copyright
claim by any government official using government
information.
57. The declaration and required acknowledgment of a
property right inuring to the Government by execution of
SF 189 and 4193 for the writings and works of federal
employees is an unlawful accession of the function of
Congress and is contrary to the Constitution and copyright
laws.
58. The taking of property without just compensation
and without an independent grant of Congressional
authority is violative of the Fifth Amendment and Article
I of the United states Constitution.
COUNT X
59. Plaintiffs allege and incorporate by reference the
allegations contained in paragraphs 1-58.
60. The Freedom of Information Act (FOIA), 5 U.S.C.
552(b)(1) permits the withholding of national security
information if it is so required by Executive Order to be
kept secret and is "in fact properly classified pursuant
to such Executive Order."
61. The prohibition in SF 189 and 4193 of disclosure
of "classifiable information" is in contravention of the
terms of FOIA which require an actual classification prior
to any withholding of information.
62. The SF 189 and 4193 do not take into account the
propriety or accuracy of the classification, and thus
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compel withholding of information that has not "in fact"
been properly classified pursuant to Executive Order.
COUNT XI
63. Plaintiffs reallege and incorporate by reference
the allegations contained in paragraphs 1-62.
64. Defendants have required federal employees in
Defense departments, without any security clearances, to
execute SF 189.
65. Requiring execution of SF 189 compels the :
misrepresentation of certain facts, such as having
received a security indoctrination, having been granted a
security clearance, and having been authorized access to
classified information.
66. There is no consideration for the nondisclosure
agreement with respect to employees without security
clearances and it is thus unenforceable.
67. The requirement to sign SF 189 imposed upon
Federal employees without security clearances constitutes
a prior restraint on freedom of speech and right of
expression guaranteed by the First Amendment and a
violation of the Fifth Amendment.
COUNT XII
68. Plaintiffs reallege and incorporate by reference the
allegations contained in paragraphs 1-67.
19
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69. As contracts the SF 189 and 4193 are void or
voidable because they impose unconstitutional conditions
on the continued employment of federal employees; are
unsupported by legal consideration; are not authorized by
Congress or any lawful exercise or authority delegated by
Congress to the Executive Branch; and are not executed by
duly appointed and authorized contracting officers (or
appointment authorities) of the United States.
70. SF 189 and 41S:3 are masked
formulate national legislation by
to skirt the regulatory process.
and unlawful
means of a
attempts to
contract, and
71. SF 189 and 4193 are illusory contracts of adhesion
induced by the exercise of undue influence, economic
duress, and unconscionable coercion.
72. As SF 4193 applies beyond one's employment and in
perpetuity, it exceeds any purported Executive dominion
over an employment relationship and suffers from fatal
overreaching.
73. SF 189 and 4193 are enforced by a process that
deprives federal employees of the safeguards to the
liberty, property and dignitary interest that attach to
their tenured positions and that are guaranteed by the
Constitution, the Civil Service Reform Act and the
traditions and laws of the United States Civil Service.
20
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Wherefore, Plaintiffs pray that this Honorable Court enter
an order:
A. Declaring that Plaintiffs rights, including
First and Fifth Amendment guarantees have
been violated by Defendants usage of SF 189
and 4193.
B. Declaring that Defendants promulgation and
reliance on SF 189 and 4193 is arbitrary,
capricious, and in excess of statutory and
excecutive authority.
C. Declare unlawful Defendants actions in
compelling the execution of SF 189 and 4193,
as applied, in contravention of the Freedom of
Information Act, the whistleblower
protections and right to Petition Congress
guarantees of the Civil Service Reform Act,
the Code of Ethics for Government Service,
the copyright laws and the State Department
Authorization Act.
D. Permanently restrain, and enjoin Defendants
and all their officers, agents, employees and
successors from implementing SF 189 and 4193
as presently constructed.
E. Compelling Defendants to publish a notice in
the Federal Register and a notice to all
affected employees that SF 189 and 4193 have
been canceled, and that all executed forms
will be withdrawn and rescinded.
F. Compelling the Secretary of Air Force to
reinstate Plaintiff Brase's SCI clearance.
G. Compelling the Secretary of Air Force to
reinstate Plaintiff Brase to his position as
Training Manager, from which he was removed
on August 4, 1987, or to place him in a
functionally equivalent position.
H. Granting Plaintiffs attorney fees and costs
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I. Granting such other and further relief as the
Court finds proper.
Re pectfully submitted,
444.04
Stuart A. Kirs
Staff Counsel
American Federation of
Government Employees, AFL-CIO
510 Plaza Drive, Suite 2510
College Park, GA 30349
[phone]
Bar #26600-7
(Counsel of Record)
OLIAA /14 .c g.k
j ?
Mark Roth
Staff Counsel
American Federation of
Government Employees
80 F Street, NW
Washington, D.C. 20001
[phone]
Bar #235473
(Local Counsel)
oseph B. Kennedy
General Counsel
Government Accountability Project
25 E. Street, N.W., Suite 100
Washington, D.C. 20001
[phone]
Bar 0042408
22
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a
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing
First Amended Complaint (Declaratory and Injunctive
Relief) has been served by regular mail this c:271 day
of October, 1987, upon the following:
U.S. Attorney
555 4th Street, N.W.
Judiciary Square Building
?4th Floor
Washington, D.C. 20001
Attention: Secretary to Chief of Civil Division
Steven Garfinkel, Director
Information Security Oversight Office
General Services Administration
18th and F Streets, NW
Washington, D.C.
Terrance C. Golden, Administrator
General Services Administration
18th & F Streets, NW, Rm. 6137
Washington, D.C. 20405
Frank Carlucci, Director
National Security Council
The White House
Washington, D.C. 20500
William Webster, Director
Central Intelligency Agency
Washington, D. C. 20505
Caspar Weinberger
Secretary of Defense
The Pentagon
Washington, D.C. 20310
Edward C. Aldridge
Secretary of Air Force
Washington,D.C. 20310
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SERVICE SHEET CONT'D
Hon. John 0. Marsh, Jr.
Secretary of the Army
Department of Army
The Pentagon
Room 3E 718
Washington, D.C. 20310-0100
Hon. James H. Webb, Jr.
Secretary of the Navy
Department of Navy
The Pentagon
Rm. 4E 686
Washington, D.C. 20350-1000
Edwin Meese, III
Attorney General
9th and Pennsylvania Ave., N.W.
Washington, D.C. 20530
vuziti
Stuart A. Kirsch
Staff Counsel
American Federation of
Government Employees, AFL-CIO
510 Plaza Drive, Suite 2510
College Park, GA 30349
[phone]
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