In part from Conservative Review: Next Tuesday, June 28, Sen. Ted Cruz (R-TX), who chairs the Judiciary Subcommittee on Oversight, Agency Action, Federal Rights and Federal Courts, will conduct a hearing investigating the willful blindness on the part of the relevant law enforcement agencies to domestic Islamic terror networks. The subject of the hearing is “Willful Blindness: Consequences of Agency Efforts To Deemphasize Radical Islam in Combating Terrorism.”
Attorney General Loretta Lynch announced at a press conference that the motives of the Orlando jihadist might never be known and that “our most effective response to terror…is unity and love.” This comes on the heels of the government’s attempt to redact any mention of Islamic rhetoric in the 911 call and DHS releasing another internal document scrubbing all references to Islamic terror. Just this week, the Council on American-Islamic Relations (CAIR), a front group for Hamas, was allowed to sit in on FBI interviews with members of the Fort Pierce mosque. The FBI was supposed to cut ties with CAIR, and DOJ was supposed to prosecute them in 2009 following the Holy Land Foundation trial, in which CAIR was implicated as a co-conspirator, yet they are granted full access to FBI counter-terrorism investigations.
This hearing will likely focus on which figures within the federal government worked to squelch any research connecting the dots between local Muslim Brotherhood officials, these individual terrorists, and foreign terror networks. Senators on the committee now have an opportunity to expose the Muslim Brotherhood influence within DHS and the FBI, their invidious “Countering Violent Extremism” Agenda, and their hand in covering up counter-terrorism investigations. They can demonstrate how the federal government has hamstrung local law enforcement by refusing to cooperate and share information regarding jihadists living in their communities.
Most importantly, this is the first opportunity to finally change the narrative from the false discussion about guns, which has nothing to do with Islamic Jihad. Hopefully, this committee hearing will be the beginning of a concerted effort for the legislative branch to actually engage in some critical oversight of the perfidious actions within the top echelons of federal law enforcement. The fact that GOP leaders in the House and Senate are not pushing multiple hearings and legislation dealing with this issue is scandalous, but unfortunately, not unexpected. Full story and audio is found here from Conservative Review.
“Based on open-source research conducted on a list provided by the Department of Justice, the Subcommittee on Immigration and the National Interest has determined that at least 380 of the 580 individuals convicted of terrorism or terrorism-related offenses between September 11, 2001 and December 31, 2014, were born abroad.” More here.
Further: In June 2016, CIA Director John Brennan testified that ISIS “is probably exploring a variety of means for infiltrating operatives into the West, including in refugee flows, smuggling routes and legitimate methods of travel.”
· In March 2016, the top U.S. military commander in Europe—Air Force General Philip Breedlove—told a Senate Committee that ISIS is infiltrating the ranks of refugees entering Europe, and that terrorists, returning foreign fighters and criminals are now part of the “daily” refugee flow.
· In September 2015, when asked if ISIS could infiltrate the refugees, Obama’s former top envoy on the coalition to defeat ISIS, General John Allen told ABC News, “I think we should watch it. We should be conscious of the potential that Daesh (aka ISIS) may attempt to embed agents within that population.”
· In October 2015, FBI Director James Comey said during a House Committee on Homeland Security hearing that the federal government does not have the ability to conduct thorough background checks on all of the 10,000 Syrian refugees that the Obama administration says will be allowed to come to the U.S.
In September 2015, the US Director of National Intelligence, James Clapper said “We don’t obviously put it past the likes of ISIL to infiltrate operatives among these refugees.”
· In September 2015, State Department Spokesman John Kirby admitted it’s “possible” for those with ISIS ties to sneak in the US through the refugee program.
· In February 2015, when asked by Rep. Michael McCaul if bringing in Syrian refugees could pose a risk to Americans, Deputy Director of the National Counterterrorism Center Nicholas Rasmussen said “It’s clearly a population of concern.”
· In February 2015 assistant director for the FBI, Michael Steinbeck said in a House Homeland Security hearing that he was “concerned” that bringing in Syrian refugees could pose a greater risk to Americans.
· In April 2015 House Homeland Security Committee Chairman, Rep. Michael McCaul said, “The intelligence community has briefed me that [terrorists] want to exploit the refugees — [that] terrorists want to exploit the refugee program to infiltrate and get in.”
Category Archives: Presidential campaign
DoJ: National Healthcare Fraud Takedown
In what the Justice Department is calling the largest takedown of healthcare fraud in U.S. history, federal authorities on Wednesday brought charges against 301 people for $900 million in false billings.
Among those charged includes 61 doctors, nurses, and other licensed medical professionals who, among other crimes, allegedly committed money laundering, identity theft, and Medicare Part D pharmacy fraud. Across the country, 23 states and 36 federal districts coordinated with the Justice Department and the Department of Health and Human Services to go after the alleged fraud schemes.
The defendants allegedly submitted Medicare and Medicaid claims the Justice Department said “were medically unnecessary and often never provided.” Some of the defendants were paid kickbacks for providing information for fraudulent bills. At least 28 doctors were among those charged on Wednesday. More from Atlantic.
Lynch/Justice Department: Good morning everyone and thank you all for being here. I am joined by several key leaders in our nation’s efforts to address health care fraud: Department of Health and Human Services Secretary [Sylvia] Burwell; Assistant Attorney General for the Criminal Division [Leslie] Caldwell; United States Attorney [Wifredo] Ferrer of the Southern District of Florida; FBI Associate Deputy Director [David] Bowdich; HHS Deputy Inspector General for Investigations [Gary] Cantrell; DCIS Acting Director [Dermot] O’Reilly; and [Shantanu] Agrawal, Deputy Administrator and Director of the Center for Program Integrity at the Centers for Medicare and Medicaid Services.
We are here today to announce a significant step in the federal government’s ongoing work to keep our nation’s health care system free of fraud and exploitation and to ensure that taxpayer dollars are used lawfully and appropriately. Over the last three days, the Medicare Fraud Strike Force – a joint effort between the Department of Justice and the Department of Health and Human Services – executed a significant nationwide health care fraud takedown. This action involved charging or unveiling charges against approximately 300 defendants in 36 federal districts for their alleged participation in a variety of schemes involving more than $900 million in fraudulent billings, making this the largest takedown in the Strike Force’s nine-year history.
The defendants named in these charges include doctors, nurses, pharmacists, physical therapists and home health care providers. They are accused of a wide range of serious crimes, from conspiring to commit health care fraud to making false statements and from bribery to money laundering. They submitted dishonest claims, charged excessive fees and prescribed unnecessary drugs. One group of defendants controlled a network of clinics in Brooklyn that they filled with patients through bribes and kickbacks. These patients then received medically unnecessary treatment, for which the clinic received over $38 million from Medicare and Medicaid – money that the conspirators subsequently laundered through more than 15 shell companies. In another case, a Detroit clinic billed Medicare for more than $36 million, even though it was actually a front for a narcotics diversion scheme. And yet another defendant took advantage of his position in a state agency in Georgia by accepting bribes and recommending the approval of unqualified health providers. These are just a few examples of the criminals that we targeted in this operation and although the specific nature of their wrongdoing varied from case to case, all of them betrayed the basic principles of their professions.
In addition to the usual patterns of fraud and deception that we’ve encountered in the past, we also saw new trends emerging in this year’s charges. For instance, in a number of cases involving the Medicare prescription drug benefit program known as Part D, we saw new evidence of identity theft, including the use of stolen doctors’ IDs to prepare fake prescriptions. We have also seen a growing number of cases involving compounded medications, which are combinations of two or more drugs prepared by a licensed professional. In recent years, the cost of these drugs has grown exponentially, making them a more attractive target for criminals looking to exploit them for profit.
As this takedown should make clear, health care fraud is not an abstract violation or benign offense. It is a serious crime. The wrongdoers that we pursue in these operations seek to use public funds for private enrichment. They target real people – many of them in need of significant medical care. They promise effective cures and therapies, but they provide none. Above all, they abuse basic bonds of trust – between doctor and patient; between pharmacist and doctor; between taxpayer and government – and pervert them to their own ends. The Department of Justice is determined to continue working to ensure that the American people know that their health care system works for them – and them alone.
In tackling these challenges, the Medicare Fraud Strike Force relies on close cooperation between the federal, state and local, governments. Since 2014, the Justice Department’s Criminal Division has organized an annual National Health Care Fraud Training Conference for Assistant U.S. Attorneys and state and federal law enforcement officers, which has substantially expanded the reach of our actions. More than 20 non-Strike Force U.S. Attorney’s Offices participated in this year’s takedown, helping us to combat health care fraud in a total of 30 federal districts nationwide, from Alaska to Florida. We were also assisted by approximately 20 state Medicaid Fraud Control Units, a reflection of the close partnership between state and federal authorities in combatting health care fraud – a partnership that we will continue to strengthen in the days ahead.
I want to thank my colleagues in the FBI, the Criminal Division and U.S. Attorneys’ Offices for their ongoing efforts to combat health care fraud. I want to thank all of the state and local law enforcement officers across the country who participated in this complex and fast-moving takedown. And I look forward to continuing our work together in the days ahead.
At this time, I’d like to turn things over to Secretary Burwell, who has been a dedicated leader and indispensable partner in this critical work and who will provide additional details on today’s announcement.
Brazil/Olympics Under Islamic State Threat
TRAC: South America has not historically been considered a high priority target for Islamic State for reasons ranging from practical to ideological. It has instead been used for remote finance and small-scale recruitment operations by Shia groups and IS’ predecessor, al-Qaeda. It would appear, however, that Islamic State has recognized that political and economic turmoil in countries like Brazil, Venezuela, and Mexico have presented opportunity in the Western Hemisphere.
A sample of recent activity documented by TRAC includes:
- A small, but effective, Islamic State financing ringin Brazil • A new Portuguese-language Nashir IS-news Telegram channel • A former Guantanamo detainee, Jihad Ahmed Mustafa Dhiab, believed now to be in Brazil
Image: A map of the particularly vulnerable border region referred to as the Triple Frontier.
All of this activity, combined with the backdrop of border insecurity at the Triple Frontier, IS recruitment in Mexico, and an active cell in São Paulo present terrorists with copious soft targets in South America, highlighted by the 2016 Olympics.
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Based on the information currently available, the threat of an IS-directed attack on the Olympics remains low, though the possibility of an IS-inspired small scale assault always looms. Preventing such an attack will rely on security arrangements at the venue, hotels, and transportation facilities where crime has already been listed as a high risk concern.
Never a High Priority Target
South America has not historically been considered a high priority target for Islamic State or other Sunni jihadist groups for many reasons, ranging from the practical to the ideological. Unlike many European nations, some of whom have a long history of interests in in the Middle East, South American countries are not typically viewed by Sunni militants as potent allies of the US. Instead, Brazil (among others) has served as a place to base remote finance and small-scale recruitment operations.
Outside Historical Caliphate Lands
Central and South America are not part of the lands claimed by historic Islamic conquest and thus fall outside the scope of Islamic State’s ideological priority of extending the Caliphate to the lands that at one time or another were considered belonging to the Umma. (Even the world maps created for Islamic State propaganda don’t bother to identify South America.)
New Focus on Portuguese & Spanish Speakers
This de-emphasis of targets south of the US may be coming to an end, however, on the part of Islamic State. ISIS has recognized the importance of shifting focus from its loses and struggles to new frontiers and opening linguistic doors to recruitment candidates. Following the 11/13 Paris Attacks a tweet attributed to Maxime Hauchard named Brazil as “our next target,” although TRAC has not been able to find a primary source record of this threat. In Spring 2016, Dabiq announced ISIS’ desire to proselytize Mayas with an “anti-colonial” message. Additionally, the approaching 2016 Olympics present an opportunity for Islamic State focus its narrative in a South American nation where it has already seen some support: Brazil.
- TRAC has documented a small, but effective, Islamic State financing ring out of Brazil
- New all Portuguese Speaking Nashir Channel
- Former Guantanamo detainee Jihad Ahmed Mustafa Dhiab
Images: Jihadi Jean Luc identified as Steve Duarte. A Luxemburger of Portuguese descent, Duarte was featured in major Islamic State video release as a French-Speaking executioner. In the video he refers to Andalusia and its Muslim cities, threatening Spain. For More on (Video) Islamic State : Filtering Apostates – Five Simultaneous Executions Featuring French Speaking Executioner Wilayat Nineveh
Political Context
- In the final week of February 2016, Brazil’s legislature approved a controversial anti-terrorism law after months of debate.
- President Rousseff signed to enact the law in the final week of March 2016.
- Allows for sentences of 12-30 years.
- Opponents consider it a tool for restraining and silencing Brazil’s political dissident movements.
- With Brazil’s corruption rankings plummeting and successful Olympics on the line, there is reason to believe some in power seek to silence opposition groups.
- The law’s advocates, however, seek not only to avoid sanction but to have additional tools ready to combat global jihad.
- Specific wording: “the practice by one or more individuals of acts for the reason of xenophobia, discrimination or prejudice of race, color, ethnic group or religion with the aim to generate social or generalized terror, endangering people, assets, the public peace or safety.”
- Israeli officials heralded the law citing years of exploitation of Brazil by Iran and Iranian proxy Hezbollah
Recruitment of Portuguese Speakers
Islamic State Messaging
On 03 June 2016 Telegram IS affiliated channel “Online Dawah Operations” shared a general post in English calling for Spanish and Portuguese speakers:
Reads: “Dear brothers and sisters, we are in need of brothers and sisters who can speak either Portuguese or Spanish to help us on our project in’shaa Allah. If you speak one of those languages and you are willing to join our translation team please Wickr me: ismailbrazili.”
Islamic State Nashir channel in Portuguese appeared on Telegram 29 May 2016:
Five days before Islamic State member Ismail Brazili called for Portuguese speakers on a general Telegram channel, a Nashir Portuguese channel appeared on Telegram. It was created 29 May 2016 but did not make its first post until 02 June 2016. Though the posts are merely reprints of the main Nashir Arabic Channel, its important to recognize the out-reach to get news from IS controlled areas and IS Wilayats to Portuguese speakers.
Important Hashtags
Islamic State relies on hashtags to spread news on both Telegram and Twitter. In almost all the Portuguese Telegram posts the following hashtags are used to spread the propaganda:
#ReportagemFotográfica
#EstadoIslâmico
#CalifadoPT
Plus the hashtag of the specific Wilayat that is being propagated.
Examples of Portuguese claims of credit
Posted 19 June 2016
Posted 20 June 2016
Posed 08 June 2016
The red over blue claims of credit (as well as light blue over darker blue) are very typical of traditional Islamic State claims, however the Portuguese are slightly different: the Wilayat appears to the left (opposed to the right) and each are marked “Urgente” which the Islamic State does not print on the claims of credit in Arabic or other languages.
Former GITMO detainee latest Lebanese immigrant to raise alarm in Brazil
The announcement that former Guantanamo detainee Jihad Ahmed Mustafa Dhiab may have legally traveled to Brazil has recently recast Brazil into the spotlight for concerns of jihadist activity. After being transferred to Uruguay in December 2014, Dhiab — whose mother is Argentine –reportedly attempted to travel legally to Brazil, but was denied entrance, according to the statement of an official in Uruguay. Contrary to these reports, another official responsible for working with the Uruguay resettlement, Christian Mirza, said Dhiab traveled legally first to Argentina (in 2015) and then to Brazil, but that his whereabouts are unknown. Dhiab also apparently walks with crutches as a result of poor health, making an undocumented, illegal border crossing more difficult, but not impossible with assistance. On the other hand, Uruguay did not agree to the US request to retain for two years the six resettled detainees.
Jihad Ahmed Mustafa Dhiab.
Dhiab is not the fist Lebanese Sunni to make headlines in Brazil. A suspected ISIS-finance cell associated with an Egyptian jihadist in São Paulo has been profiled by TRAC and is available here:
Islamic State Brazil : São Paulo Cell — (Islamic State / ISIS) — CELL PROFILE
In an operation called Menzad, 18 search warrants were issued to halt the Alameddine family’s fraudulent activity in money transfers suspected of supporting ISIS. It included the arrest of Egyptian Hesham Eltrabily, accused by Egypt of involvement in the 1997 Luxor Massacre.
Khaled Hussein Ali is yet another Lebanese transplant to Brazil of great concern in light of Islamic State’s growing influence. Although his affiliation with Al Qaeda reaches high into the organization, it is likely that his role in spreading propaganda and operating internet cafes in Vila Matilde has created fallow ground for Islamic State’s message in São Paulo and beyond.
Border Security and Soft Targets Concern
Border security has long been problematic for Brazil and its neighbors dealing with drug trafficking and militias. Additionally, the Rio Olympics present copious soft target opportunities for jihadist and other groups. Below are a map of the particularly vulnerable border region referred to as the Triple Frontier:
This area is relatively under-policed and concerns are that exploitation by Sunni jihadists would create fall-out with the Shia community, whose large mosques dot the Brazilian border facing Paraguay.
Loretta Lynch Fully Opposes Obama on Gitmo
Say it isn’t so…pigs flying? Video calls between soccer or basketball games?
The Obama White House has a habit of altering assessments and reports especially noted by the CENTCOM scandal. The Obama regime also did the same with the assessment profiles of those forcibly released to other countries in an effort to close Gitmo. One such country that was betrayed by the Obama administration was Ghana.
What is mind boggling is whether we should trust our President or the external people who are proving him wrong. According to US pundits, the said description as given by our leaders isn’t true for either of the men. Bin Atef in particular is a cause of concern. Long before his transfer, the intelligence analysts at Joint Task Force Guantanamo assessed him as a ‘high risk’ and ‘likely to pose a threat to the US, its interest and allies’. Atef is actually a fighter in Usama bin Laden’s former 55th Arab Brigade and an admitted member of the Taliban.
This is in sharp contrast to the claim by Mahama, who portrays the deal as an act of humanitarian assistance, likening the Yemeni men to non-threatening refugees who have been cleared of any involvement in terrorist activities. More here.
Those former detainees released to Uruguay were to be managed and controlled by the government under the Memorandum of Understanding and release. Well, at least one has fled, allegedly to Brazil.
Exclusive: Justice Department opposes new Obama proposal on Guantanamo
Reuters: President Barack Obama is again facing dissent from within his administration – this time from Attorney General Loretta Lynch – over his plans to shutter the Guantanamo Bay military prison, according to senior administration officials.
Lynch, a former federal prosecutor whom Obama appointed to head the Justice Department two years ago, is opposing a White House-backed proposal that would allow Guantanamo Bay prisoners to plead guilty to terrorism charges in federal court by videoconference, the officials said.
Over the past three months, Lynch has twice intervened to block administration proposals on the issue, objecting that they would violate longstanding rules of criminal-justice procedure.
In the first case, her last-minute opposition derailed a White House-initiated legislative proposal to allow video guilty pleas after nearly two months of interagency negotiations and law drafting. In the second case, Lynch blocked the administration from publicly supporting a Senate proposal to legalize video guilty pleas.
“It’s been a fierce interagency tussle,” said a senior Obama administration official, who supports the proposal and asked not to be identified.
White House officials confirmed that President Obama supports the proposal. But the president declined to overrule objections from Lynch, the administration’s top law-enforcement official.
“There were some frustrations,” said a White House official who spoke on condition of anonymity. “The top lawyer in the land has weighed in, and that was the DOJ’s purview to do that.”
If enacted into law, the Obama-backed plan would allow detained terrorism suspects who plead guilty to serve their sentences in a third-country prison, without setting foot on U.S. soil. The plan would thus sidestep a Congressional ban on transferring detainees to the United States, which has left dozens of prisoners in long-term judicial limbo in Guantanamo, the American military enclave in Cuba.
Obama has vowed to close the prison on his watch. But while he has overseen the release of some 160 men from the prison, the facility still holds 80 detainees.
The video plea plan has broad backing within the administration, including from senior State Department and Pentagon officials. A Defense Department spokesman declined to comment.
The most enthusiastic backers of the plan have been defense lawyers representing up to a dozen Guantanamo Bay detainees who are eager to extricate their clients from seemingly indefinite detention.
Republicans in Congress have opposed the president’s plans to empty the prison, on the grounds that many of the detainees are highly dangerous. But there is some bipartisan support for the proposal as well, a rarity in the Guantanamo debate.
Kevin Bishop, a spokesman for Senator Lindsey Graham, a leading Republican voice on defense and national security issues, said Graham was “intrigued” by the proposal.
While support from a Republican senator would by no means guarantee the votes needed to pass, it does give the proposal a better chance than schemes that would transfer detainees from the Cuban enclave to the United States.
Obama views the video feed proposal as a meaningful step toward closing the facility and making good on one of his earliest pledges as president, administration officials said.
Of the 80 prisoners remaining in Guantanamo, roughly 30 have been approved for transfer to third countries by an interagency review board. Most of those 30 men are expected to be released from Guantanamo in coming weeks, according to administration officials.
The officials said they think that as many as 10 more prisoners could be added to the approved-for-transfer list by the review board. Finally, another 10 detainees are standing trial in military commissions.
That leaves roughly 30 detainees whom the government deems too dangerous to release but unlikely to be successfully prosecuted in court. As a result, those men would likely have to be transferred to detention in the United States if the prison were closed.
Administration officials say that allowing video feeds could reduce that number to somewhere between 10 and 20. The administration believes that with such a small number of prisoners requiring transfer to the United States, it would be easier to win support for closing the facility, which is run by a staff of 2,000 military personnel.
“This is the group that gives the president the most heartburn,” said the senior administration official.
Lynch and her deputies at the Justice Department argued that the laws of criminal procedure do not allow defendants to plead guilty remotely by videoconference.
Even if Congress were to pass the law, Lynch and her aides have told the White House that federal judges may rule that such pleas are in effect involuntary, because Guantanamo detainees would not have the option of standing trial in a U.S. courtroom.
A defendant in federal court usually has the option to plead guilty or face a trial by jury. In the case of Guantanamo detainees, the only option they would likely face is to plead guilty or remain in indefinite detention.
“How would a judge assure himself that the plea is truly voluntary when if the plea is not entered, the alternative is you’re still in Gitmo?” said a person familiar with Lynch’s concerns about the proposal. “That’s the wrinkle.”
Lawyers for Guantanamo detainee Majid Khan, a 36-year-old Pakistani citizen, first proposed allowing Khan to plead guilty by videoconference in a legal memo submitted to the Department of Justice in November. In 2012, Khan confessed in military court to delivering $50,000 to Qaeda operatives who used it to carry out a truck bombing in Indonesia, and to plotting with Khalid Shaikh Mohammed, the mastermind of the Sept. 11 attacks, on various planned strikes.
Senate investigators found internal CIA documents confirming that Khan’s CIA interrogators subjected him to forced rectal feedings. Khan’s lawyers say the experience amounted to rape. He was also water-boarded.
That treatment makes it difficult for the Department of Justice to successfully prosecute Khan in federal court, according to administration officials.
When White House officials learned that Khan and other detainees were ready to plead guilty to terrorism charges in federal court, they thought they had found a solution.
Efforts to try detainees, including Mohammed and other Sept. 11 suspects, in military tribunals at Guantanamo have bogged down over legal disputes. Only eight defendants have been fully prosecuted. Three verdicts have been overturned.
“The beauty of a guilty plea is you don’t need a trial,” said the senior administration official who supports the video plea proposal.
In February, senior Obama aides proposed pushing ahead with video guilty pleas at an interagency meeting at the White House on the closure of Guantanamo, according to officials briefed on the meeting.
Justice Department officials said they opposed video guilty pleas. Matthew Axelrod, the chief of staff to Deputy Attorney General Sally Yates, said the proposal would violate laws of criminal procedure, according to the officials.
The meeting ended with an agreement to pursue new legislation allowing the guilty pleas, the officials said, which the Department of Justice supported.
One week later, President Obama rolled out his plan to close the prison in a nationally televised announcement from the Roosevelt Room. Obama’s plan included seeking “legislative changes … that might enable detainees who are interested in pleading guilty” in U.S. federal courts.
Administration officials spent much of the next two months drafting the new law. On a Friday afternoon in mid-April, White House staff emailed all the involved agencies with a final draft of the bill, according to the officials. The bill would be submitted to Congress the following Monday, the White House email said.
That weekend, Lynch intervened unexpectedly and said the Justice Department opposed the bill. The eleventh-hour move frustrated White House staff. Deciding again to not overrule Lynch, the White House shelved the bill.
In late May, White House officials found a sympathetic lawmaker who inserted language authorizing video pleas into the annual defense spending bill. The White House drafted a policy memo publicly supporting the proposal, which is known as a Statement of Administration Policy, or SAP.
Lynch opposed the idea, according to administration officials, sparking renewed tensions between the Justice Department and White House.
A SAP is the president’s public declaration on the substance of a bill, according to Samuel Kernell, a political science professor at the University of California at San Diego. Without one, it’s often more difficult to get lawmakers on the fence to vote the way the White House wants.
The White House again bowed to Lynch’s objections and declined to issue the SAP.