False flag
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False flag operations are covert operations designed to deceive as to who has carried them out. The name is derived from the military concept of flying false colors; that is flying the flag of a country other than one's own. False flag operations are sometimes used in commerce and politics.
Contents
The practice has generally been considered acceptable in naval warfare, provided the false flag was lowered and the national flag raised before engaging in battle. Auxiliary cruisers operated in such a fashion in both World Wars, as did Q-ships, while merchant vessels were encouraged to use false flags for protection. One of the most notable examples was in World War II when the German commerce raider Kormoran, disguised as a Dutch merchant ship, surprised and sank the Australian light cruiser HMAS Sydney in 1941, causing the greatest recorded loss of life on an Australian warship. The Kormoran was also fatally crippled in that encounter and its crew was captured, but it was a considerable psychological victory for the Germans.[1]
The British used a Kriegsmarine Ensign in the St Nazaire Raid and captured a German code book. The old destroyer HMS Campbeltown (I42), which the British planned to sacrifice in the operation, was provided with cosmetic modifications, cutting the ship's funnels and chamfering the edges to resemble a German Möwe-class destroyer. The British were able to get within two miles of the harbour before the defences responded, where the explosive-rigged Campbeltown and commandos successfully disabled or destroyed the key dock structures of the port.[2][3]
Air warfare
In December 1922-February 1923, Rules concerning the Control of Wireless Telegraphy in Time of War and Air Warfare, drafted by a commission of jurists at the Hague regulates:[4]
- Art. 3. A military aircraft must carry an exterior mark indicating its nationality and its military character.
- Art. 19. The use of false exterior marks is forbidden.
This draft was never adopted as a legally binding treaty, but the ICRC states in its introduction on the draft that "To a great extent, [the draft rules] correspond to the customary rules and general principles underlying treaties on the law of war on land and at sea",[5] and as such these two non controversial articles were already part of customary law.[6]
Land warfare
In land warfare, the use of a false flag is similar to that of naval warfare. The most widespread assumption is that this practice was first established under international humanitarian law at the trial in 1947 of the planner and commander of Operation Greif, Otto Skorzeny, by the military court at the Dachau Trials. In this trial, the court did not find Skorzeny guilty of a crime by ordering his men into action in American uniforms. He had passed on to his men the warning of German legal experts, that if they fought in American uniforms, they would be breaking the laws of war, but they probably were not doing so just by wearing the uniform. During the trial, a number of arguments were advanced to substantiate this position and the German and U.S. military seem to have been in agreement on it. In the transcript of the trial[7] it is mentioned that Paragraph 43 of the Field Manual published by the War Department, United States Army, on October 1, 1940, under the title "Rules of Land Warfare", says:
- "National flags, insignias and uniforms as a ruse - in practice it has been authorized to make use of these as a ruse. The foregoing rule (Article 23 of the Annex of the IVth Hague Convention (1899 and 1907), does not prohibit such use, but does prohibit their improper use. It is certainly forbidden to make use of them during a combat. Before opening fire upon the enemy, they must be discarded".
- Also The American Soldiers' Handbook, was quoted by Defense Counsel and says:
- "The use of the enemy flag, insignia, and uniform is permitted under some circumstances. They are not to be used during actual fighting, and if used in order to approach the enemy without drawing fire, should be thrown away or removed as soon as fighting begins".
The outcome of the trial has been codified in the 1977 Protocol Additional to the Geneva Conventions of 12 August 1949 (Protocol I):
Article 37.-Prohibition of perfidy
- 1. It is prohibited to kill, injure, or capture an adversary by resort to perfidy. Acts inviting the confidence of an adversary to lead him to believe that he is entitled to, or is obliged to accord, protection under the rules of international law applicable in armed conflict, with intent to betray that confidence, shall constitute perfidy. The following acts are examples of perfidy:
- (a) The feigning of an intent to negotiate under a flag of truce or of a surrender;
- (b) The feigning of an incapacitation by wounds or sickness;
- (c) The feigning of civilian, non-combatant status; and
- (d) The feigning of protected status by the use of signs, emblems or uniforms of the United Nations or of neutral or other States not Parties to the conflict.
- 2. Ruses of war are not prohibited. Such ruses are acts which are intended to mislead an adversary or to induce him to act recklessly but which infringe no rule of international law applicable in armed conflict and which are not perfidious because they do not invite the confidence of an adversary with respect to protection under that law. The following are examples of such ruses: the use of camouflage, decoys, mock operations and misinformation.
Article 38.-Recognized emblems
- 1. It is prohibited to make improper use of the distinctive emblem of the red cross, red crescent or red lion and sun or of other emblems, signs or signals provided for by the Conventions or by this Protocol. It is also prohibited to misuse deliberately in an armed conflict other internationally recognized protective emblems, signs or signals, including the flag of truce, and the protective emblem of cultural property.
- 2. It is prohibited to make use of the distinctive emblem of the United Nations, except as authorized by that Organization.
Article 39.-Emblems of nationality
- 1. It is prohibited to make use in an armed conflict of the flags or military emblems, insignia or uniforms of neutral or other States not Parties to the conflict.
- 2. It is prohibited to make use of the flags or military emblems, insignia or uniforms of adverse Parties while engaging in attacks or in order to shield, favour, protect or impede military operations.
- 3. Nothing in this Article or in Article 37, paragraph 1 ( d ), shall affect the existing generally recognized rules of international law applicable to espionage or to the use of flags in the conduct of armed conflict at sea.
As pretexts for war
The Wikipedia page here covers a few incidents.
If you have published evidence of further cases rejected at Wikipedia by bias, please add them. (You may wish to populate this section from the current Wikipedia entry at the same time).
Wikispooks admins will not interfere without good reason as long as this notice is in place.
Pseudo-operations
Pseudo-operations are those in which forces of one power disguise themselves as enemy forces. For example, a state power may disguise teams of operatives as insurgents and, with the aid of defectors, infiltrate insurgent areas.[8] The aim of such pseudo-operations may be to gather short or long-term intelligence or to engage in active operations, in particular assassinations of important enemies. However, they usually involve both, as the risks of exposure rapidly increase with time and intelligence gathering eventually leads to violent confrontation. Pseudo-operations may be directed by military or police forces, or both. Police forces are usually best suited to intelligence tasks; however, military provide the structure needed to back up such pseudo-ops with military response forces. According to US military expert Lawrence Cline (2005), "the teams typically have been controlled by police services, but this largely was due to the weaknesses in the respective military intelligence systems."
The State Political Directorate (OGPU) of the Soviet Union set up such an operation from 1921 to 1926. During Operation Trust, they used loose networks of White Army supporters and extended them, creating the pseudo-"Monarchist Union of Central Russia" (MUCR) in order to help the OGPU identify real monarchists and anti-Bolsheviks.
An example of a successful assassination was United States Marine Sergeant Herman H. Hanneken leading a patrol of his Haitian Gendarmerie disguised as enemy guerrillas in 1919. The Patrol successfully passed several enemy checkpoints in order to assassinate the guerilla leader Charlemagne Péralte near Grande-Rivière-du-Nord. Hanneken was awarded the Medal of Honor and was commissioned a Second Lieutenant for his deed.
During the Mau Mau uprising in the 1950s, captured Mau Mau members who switched sides and specially trained British troops initiated the pseudo-gang concept to successfully counter Mau Mau. In 1960 Frank Kitson, (who was later involved in the Northern Irish conflict and is now a retired British General), published Gangs and Counter-gangs, an account of his experiences with the technique in Kenya; information included how to counter gangs and measures of deception, including the use of defectors, which brought the issue a wider audience.
Another example of combined police and military oversight of pseudo-operations include the Selous Scouts in former country Rhodesia (current Zimbabwe), governed by white minority rule until 1980. The Selous Scouts were formed at the beginning of Operation Hurricane, in November 1973, by Major (later Lieutenant Colonel) Ronald Reid-Daly. As all Special Forces in Rhodesia, by 1977 they were controlled by COMOPS (Commander, Combined Operations) Commander Lieutenant General Peter Walls. The Selous Scouts were originally composed of 120 members, with all officers being white and the highest rank initially available for Africans being colour sergeant. They succeeded in turning approximately 800 insurgents who were then paid by Special Branch, ultimately reaching the number of 1,500 members. Engaging mainly in long-range reconnaissance and surveillance missions, they increasingly turned to offensive actions, including the attempted assassination of ZIPRA leader Joshua Nkomo in Zambia. This mission was finally aborted by the Selous Scouts, and attempted again, unsuccessfully, by the Rhodesian Special Air Service.[9]
Some offensive operations attracted international condemnation, in particular the Selous Scouts' raid on a ZANLA (Zimbabwe African National Liberation Army) camp at Nyadzonya Pungwe, Mozambique in August 1976. ZANLA was then led by Josiah Tongogara. Using Rhodesian trucks and armored cars disguised as Mozambique military vehicles, 84 scouts killed 1,284 terrorists in the camp, the camp was registered as a refugee camp by the United Nations (UN). Even according to Reid-Daly, most of those killed were unarmed guerrillas standing in formation for a parade. The camp hospital was also set ablaze by the rounds fired by the Scouts, killing all patients.[10] According to David Martin and Phyllis Johnson, who visited the camp shortly before the raid, it was only a refugee camp that did not host any guerrillas. It was staged for UN approval.[11]
According to a 1978 study by the Directorate of Military Intelligence, 68% of all insurgent deaths inside Rhodesia could be attributed to the Selous Scouts, who were disbanded in 1980.[12]
If the action is a police action, then these tactics would fall within the laws of the state initiating the pseudo, but if such actions are taken in a civil war or during a belligerent military occupation then those who participate in such actions would not be privileged belligerents. The principle of plausible deniability is usually applied for pseudo-teams. (See the above section Laws of war). Some false flag operations have been described by Lawrence E. Cline, a retired US Army intelligence officer, as pseudo-operations, or "the use of organized teams which are disguised as guerrilla groups for long- or short-term penetration of insurgent-controlled areas."
Pseudo Operations should be distinguished, notes Cline, from the more common police or intelligence infiltration of guerrilla or criminal organizations. In the latter case, infiltration is normally done by individuals. Pseudo teams, on the other hand, are formed as needed from organized units, usually military or paramilitary. The use of pseudo teams has been a hallmark of a number of foreign counterinsurgency campaigns."[8]
Espionage
In espionage the term "false flag" describes the recruiting of agents by operatives posing as representatives of a cause the prospective agents are sympathetic to, or even the agents' own government. For example, during the Cold War, several female West German civil servants were tricked into stealing classified documents by agents of the East German Stasi intelligence service, pretending to be members of West German peace advocacy groups (the Stasi agents were also described as "Romeos," indicating that they also used their sex appeal to manipulate their targets, making this operation a combination of the false flag and "honey trap" techniques).[13]
The technique can also be used to expose enemy agents in one's own service, by having someone approach the suspect and pose as an agent of the enemy. Earl Edwin Pitts, a 13-year veteran of the FBI and an attorney, was caught when he was approached by FBI agents posing as Russian agents.
“ | It was obvious that if the case were to be kept going a faked act of sabotage would have to be committed | ” |
— MI5 file on Mutt and Jeff (spies)[14] |
British intelligence officials in World War II allowed double agents to fire-bomb a power station and a food dump in the UK to protect their cover, according to declassified documents. The documents stated the agents took precautions to ensure they did not cause serious damage. One of the documents released also stated: "It should be recognised that friends as well as enemies must be completely deceived."[15]
Dirty War
During a 1981 interview whose contents were revealed by documents declassified by the CIA in 2000, former CIA and DINA agent Michael Townley explained that Ignacio Novo Sampol, member of CORU, an anti-Castro organization, had agreed to commit the Cuban Nationalist Movement in the kidnapping, in Buenos Aires, of a president of a Dutch bank. The abduction, organized by civilian SIDE agents, the Argentine intelligence agency, was to obtain a ransom. Townley said that Novo Sampol had provided six thousand dollars from the Cuban Nationalist Movement, forwarded to the civilian SIDE agents to pay for the preparation expenses of the kidnapping. After returning to the US, Novo Sampol sent Townley a stock of paper, used to print pamphlets in the name of "Grupo Rojo" (Red Group), an imaginary Argentine Marxist terrorist organization, which was to claim credit for the kidnapping of the Dutch banker. Townley declared that the pamphlets were distributed in Mendoza and Córdoba in relation with false flag bombings perpetrated by SIDE agents, which had as their aim to accredit the existence of the fake Grupo Rojo. However, the SIDE agents procrastinated too much, and the kidnapping ultimately was not carried out.[16]
Non-state operatives, terrorism
False flag tactics were also employed during the Algerian civil war, starting in the mid-1994. Death squads composed of DRS (Département du Renseignement et de la Sécurité) security forces disguised themselves as Islamist terrorists and committed false flag terror attacks. Such groups included the OJAL (Organisation of Young Free Algerians) or the OSSRA (Secret Organisation for the safeguard of the Algerian Republic)[17] According to Roger Faligot and Pascal Kropp (1999), the OJAL reminded of "the Organization of the French Algerian Resistance (ORAF), a group of counter-terrorists created in December 1956 by the Direction de la surveillance du territoire (Territorial Surveillance Directorate) whose mission was to carry out terrorist attacks with the aim of quashing any hopes of political compromise." [18]
The Russian apartment bombings in the Russian cities of Buynaksk, Moscow and Volgodonsk in September 1999 which killed nearly 300 people, was described by Yury Felshtinsky, Alexander Litvinenko, David Satter, Boris Kagarlitsky, Vladimir Pribylovsky, Anna Politkovskaya, filmmaker Andrei Nekrasov, investigator Mikhail Trepashkin, Russian politician Alexander Lebed as a false flag attack coordinated by the Federal Security Service, the main domestic security agency of the Russian Federation.[19][20][21][22][23][24][25][26][27][28][29]
On the night of February 27, 1933, the Reichstag building was set on fire. At the urging of Hitler, Hindenburg responded the next day by issuing an emergency decree "for the Protection of the people and the State," which stated: "Restrictions on personal liberty, on the right of free expression of opinion, including freedom of the press; on the rights of assembly and association; and violations of the privacy of postal, telegraphic and telephonic communications and warrants for house searches, orders for confiscations as well as restrictions on property, are also permissible beyond the legal limits otherwise prescribed." The question of who actually started the Reichstag fire is still unknown and occasionally debated.
Elections
In 2008 there was a shooting against two minibuses driving along in a volatile area right on the border between Abkhazia and the republic of Georgia. The buses were carrying Georgians who lived in Abkhazia and wanted to cross the border so they could go and vote in the parliamentary election that day.
The country had been experiencing internal political turmoil for the last year, and in an attempt to calm the situation, president Mikheil Saakashvili moved forward both presidential and parliamentary elections. However the presidential election in January that year was strongly contested, with hundreds of thousands attending protest rallies. When the parliamentary election came up in May, the mood was still tense.
On mid day May 21 the two minibuses came under attack with small arms and grenades, and though there were no casualties, three people were taken to a hospital in Zugdidi, where president Saakashvili later arrived and was filmed by TV at the patients's bedside.
In his comments on TV, which dominated the news during election day, Saakashvili indicated that the attack had been an attempt to disrupt the election, implying that it had been Abkhaz or Russian forces who had been behind it. This provided for a favorable opportunity for the president to focus the nation's attention on an external enemy, thereby leading attention away from his domestic critics, as well as making use of his position as leader to rally the Georgians around his candidates in the election.
However a United Nations investigation[30] later found, based on empty cartridges and the position of traces left by grenade launchers on the ground, that the attack had originated from a patch of land under control of Georgians and with weapons used by Georgian forces, indicating that the attack had been staged.
A Georgian investigative TV documentary later found that camera crew from the government-friendly channel Rustavi 2 had been in position with their equipment before the shooting took place.
Civilian usage
While false flag operations originate in warfare and government, they also can occur in civilian settings among certain factions, such as businesses, special interest groups, religions, political ideologies and campaigns for office.
Businesses
In business and marketing, similar operations are being employed in some public relations campaigns (see Astroturfing). Telemarketing firms practice false flag type behavior when they pretend to be a market research firm (referred to as "sugging"). In some rare cases, members of an unsuccessful business will destroy some of their own property to conceal an unrelated crime (e.g. safety violations, embezzlement, etc.) but make it appear as though the destruction was done by a rival company.
Political campaigning
Political campaigning has a long history of this tactic in various forms, including in person, print media and electronically in recent years. This can involve when supporters of one candidate pose as supporters of another, or act as "Straw man|straw men" for their preferred candidate to debate against. This can happen with or without the candidate's knowledge. The Canuck letter is an example of one candidate creating a false document and attributing it as coming from another candidate in order to discredit that candidate.
In 2006, individuals practicing false flag behavior were discovered and "outed" in New Hampshire[31][32] and New Jersey[33] after blog comments claiming to be from supporters of a political candidate were traced to the IP address of paid staffers for that candidate's opponent.
On February 19, 2011, Indiana Deputy Prosecutor Carlos Lam sent a private email to Wisconsin Governor Scott Walker suggesting that he run a "'false flag' operation" to counter the protests against Walker's proposed restrictions on public employees' collective bargaining rights.
"If you could employ an associate who pretends to be sympathetic to the unions' cause to physically attack you (or even use a firearm against you), you could discredit the unions," read the email. It went on to say that the effort "would assist in undercutting any support that the media may be creating in favor of the unions." The press had acquired a court order to access all of Walker's emails and Lam's email was exposed. At first, Lam vehemently denied it, but eventually admitted it and resigned.[34]
Ideological
Political or religious ideologies have sometimes used false flag tactics. In retaliation for writing The Scandal of Scientology, the Church of Scientology stole stationery from author Paulette Cooper's home and then used that stationery to forge bomb threats and have them mailed to a Scientology office. The Guardian's Office also had a plan for further operations to discredit Cooper known as Operation Freakout, but several Scientology operatives were arrested in a separate investigation and the plan failed.[35]
See also
Concepts:
- Black propaganda
- Casus belli
- Covert operation
- Front organization
- Inside job
- Joe job, a similar online concept
- Mimicry
- State terrorism
Examples:
- Bloed, Bodem, Eer en Trouw (Flemish neo-Nazi group preparing false flag attacks)
- Bologna massacre
- Canuck letter
- Celle Hole
- CIA Operation Ajax (USA overthrowing of Mohammed Mossadeq, Prime Minister of Iran, in 1953)
- CIA Operation Northwoods was a Plan to blame Cuba for a Terrorist attack in order to get a pretext for 'justified' War of aggression after USA funded and organized failed Terrorist attack known as CIA Operation Mongoose.
- CIA PBSUCCESS ([USA]) Operation for overthrowing the Arbenz government in Guatemala in 1954
- CIA Project Cherry (USA non-stop assassination project to kill Norodom Sihanouk, Prince, and later King of Cambodia)
- Gleiwitz incident - 3rd Reich Nazis Operation Himmler in order to get pretext for 'justified' war of aggression against Poland with USSR day after that - named Fall Weiß
- Kommandoverband Jaguar German army unit conducting deep reconnaissance in Soviet uniforms
- Lavon Affair Israeli attempt to plant bombs in Western targets in Egypt, in blaming Arab elements
- Marxist-Leninist Party of the Netherlands (fake party set up by the Dutch security service)
- Masada Action and Defense Movement ("Zionist" group bombing Arab targets in France, really French white supremacists)
- Operation Jaque
- Reichstag Fire, which led to the Reichstag Fire Decree which suspended the Weimar Constitution until the end of the Third Reich
- Shelling of Mainila by Joseph Stalin and USSR in order to get pretext for 'justified' war of aggression named Winter War
- SIS (MI6) Operation Boot (UK Operation for overthrowing of Mohammed Mossadeq, Prime Minister of Iran, in 1953 with Americans)[36]
- Special Activities Division
- The Plaza Miranda Bombings in the Philippines, which led to Ferdinand Marcos's suspension of the writ of habeas corpus.
- The strategy of tension in Italy during the 1970s, when right-wing Italian, Spanish, Greek, and CIA agents caused various terrorist acts in Italy, which were publicly laid to Communist terrorist groups that were actually fakes, and to the Red Brigades who were actually innocent of these particular crimes
Notes
- ↑ Squires, Nick. "HMAS Sydney found off Australia's west coast", The Daily Telegraph (Australia), 2008-03-17.
- ↑ Guinness World Records (2009), p.155
- ↑ Young, P (Ed) (1973) Atlas of the Second World War (London: The Military Book Society)
- ↑ The Hague Rules of Air Warfare, 1922-12 to 1923-02, this convention was never adopted' (backup site)
- ↑ Rules concerning the Control of Wireless Telegraphy in Time of War and Air Warfare. Drafted by a Commission of Jurists at the Hague, December 1922 - February 1923.: Introduction ICRC
- ↑ Gómez, Javier Guisández (20 June 1998). "The Law of Air Warfare". International Review of the Red Cross. nº 323: 347–63.Page Module:Citation/CS1/styles.css must have content model "Sanitized CSS" for TemplateStyles (current model is "Scribunto").
- ↑ Source: Law Reports of Trials of War Criminals. United Nations War Crimes Commission. Vol. IX, 1949: Trial of Otto Skorzeny and others General Military Government Court of the U.S. zone of Germany August 18 to September 9, 1947
- ↑ a b Cline, Lawrence E. (2005) Pseudo Operations and Counterinsurgency: Lessons from other countries, Strategic Studies Institute, read here
- ↑ Cline (2005), p. 11.
- ↑ Cline (2005), quoting Reid-Daly, Pamwe Chete: The Legend of the Selous Scouts, Weltevreden Park, South Africa: Covos-Day Books, 1999, p. 10 (republished by Covos Day, 2001, ISBN 978-1919874333)
- ↑ Cline (2005), who quotes David Martin and Phyllis Johnson, The Struggle for Zimbabwe: the Chimurenga War, New York: Monthly Review Press, 1981, pp. 241-242.
- ↑ Cline (2005), p. 8-13. For 1978 study, quotes J. K. Cilliers, Counter-insurgency in Rhodesia, London: Croom Helm, 1985, pp. 60-77. Cline also quotes Ian F. W. Beckett, The Rhodesian Army: Counter-Insurgency 1972-1979 at selousscouts
- ↑
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- ↑ "Britain 'bombed itself to fool Nazis'" BBC. 2002-02-28
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- ↑ Visit by Guillermo Novo Sampol to Chile in 1976, 1 and 2, on the National Security Archive website
- ↑ Lounis Aggoun and Jean-Baptiste Rivoire (2004). Françalgérie, crimes et mensonges d’Etats, (Franco-Algeria, Crimes and Lies of the States). Editions La Découverte. ISBN 2-7071-4747-8. Extract in English with mention of the OJAL available here.
- ↑ Luonis Aggoun and Jean-Baptiste Rivoire, ibid., quoting Roger Faligot and Pascal KROP, DST, Police Secrète, Flammarion, 1999, p. 174.
- ↑ Boris Kagarlitsky, a member of the Russian Academy of Sciences Institute of Comparative Politics, writing in the weekly Novaya Gazeta, says that the bombings in Moscow and elsewhere were arranged by the GRU
- ↑ David Satter - House committee on Foreign Affairs
- ↑ Harvnb, Felshtinsky, Pribylovsky. 2008 pp=105-111
- ↑ [youtube|PnkYo9TuBIQ In Memoriam Aleksander Litvinenko] Jos de Putter, Tegenlicht documentary VPRO 2007, Moscow, 2004 Interview with Anna Politkovskaya
- ↑ Russian Federation: Amnesty International's concerns and recommendations in the case of Mikhail Trepashkin - Amnesty International
- ↑ Bomb Blamed in Fatal Moscow Apartment Blast, Richard C. Paddock, Los Angeles Times, September 10, 1999
- ↑ At least 90 dead in Moscow apartment blast, from staff and wire reports, CNN, September 10, 1999
- ↑ Harvnb, Evangelista, 2002 p=81
- ↑ Did Putin's Agents Plant the Bombs?, Jamie Dettmer, Insight on the News, April 17, 2000.
- ↑ ’’The consolidation of Dictatorship in Russia’’ by Joel M. Ostrow, Georgil Satarov, Irina Khakamada p.96
- ↑ McCain decries "New authoritarianism in Russia", November 4, 2003
- ↑ "Report of the Secretary-General on the situation in Abkhazia, Georgia". United Nations Security Council. 2008-07-23. Retrieved 2008-08-21.Page Module:Citation/CS1/styles.css must have content model "Sanitized CSS" for TemplateStyles (current model is "Scribunto").
- ↑ Steele, Allison, "Bass staffer in D.C. poses as blogger: Bogus posts aimed at his political opponent", Concord Monitor, September 26, 2006 (URL last accessed October 24, 2006).
- ↑ Saunders, Anne, "Bass aide resigns after posing as opponent's supporter online", The Boston Globe, September 26, 2006 (URL last accessed October 24, 2006).
- ↑ Miller, Jonathan, "Blog Thinks Aide to Kean Posted Jabs At Menendez", New York Times, September 21, 2006 (URL last accessed October 24, 2006).
- ↑ Indiana prosecutor resigns for encouraging fake attack on Wisconsin governor CBS News March 25, 2011
- ↑ United States of America v. Jane Kember, Morris Budlong, Sentencing Memorandum; pp. 23-25.
- ↑ Garretwilson.com