Expert Report of J. William Leonard

Key Excerpts

• [T]he [security clearance] process is always based upon the personal conduct of the relevant individual. That is one of the fundamental hallmarks of the security-clearance review process; Person A is never held accountable for the conduct of Person B, let alone are Persons 1 through 2,500 held accountable for the conduct of formerly-associated Person 2,501.
• Simply put, a blanket suspension of all security clearances at a law firm of 1,200+ lawyers and 1,200+ business professionals is unprecedented in its scope and fundamentally inconsistent with existing authority addressing the processing, granting and revocation of security clearances.
• The arbitrary directive of immediate suspension of security clearances not for any personal conduct by any clearance holder but rather simply for that individual’s association with a law firm is no different analytically than if a directive were issued to immediately suspend the security clearances of all Jews or Muslims, all members of the LGBTQ+ community, all women, or all registered Democrats or Republicans. These types of non-individualized, mass suspensions of security clearances targeted at groups of individuals threaten to harm our national security efforts.