From: bill payne <billp@nmol.com>
To: jy@jya.com
Message Hash: 37eef120f9cb6e74df170aeddec76ac9a5b82ed20635f939b06160ca5202140a
Message ID: <34C21266.142B@nmol.com>
Reply To: N/A
UTC Datetime: 1998-01-18 15:35:29 UTC
Raw Date: Sun, 18 Jan 1998 23:35:29 +0800
From: bill payne <billp@nmol.com>
Date: Sun, 18 Jan 1998 23:35:29 +0800
To: jy@jya.com
Subject: diplomacy
Message-ID: <34C21266.142B@nmol.com>
MIME-Version: 1.0
Content-Type: text/plain
I sure hope the following was diplomatic enough.
NSA exhibited NO SENSE OF HUMOR when I pointed out
'deficiencies' in its crypto algorithm work. But, too,
the agrieve Islamic fundamentalists may not have too good
senses of humor.
But with that experience, my sensitivities are hightened.
Later, guys.
Back to POSTCARD COMMUNICATIONS!
Sunday 1/18/98 6:24 AM
Jim Allen
Thanks for the call on Friday night.
You said that there might be a problem in the way the interrupts
were turned on.
I told you I would give this some thought.
Here is the routine to turn on the interrupts
;* Call DasIntOn(IoPointer&, ErrorFlag&, SystemState&, IoData&(0, 0),
;* IoParm&(0, 0), LgradThres) from Visual Basic.
DasIntOn PROTO FAR, VBIoPointer:dword, VBErrorFlag:dword,
VBSystemState:dword,
VBIoData:dword, VBIoParm:dword, VBLGradThres:dword
DasIntOn PROC FAR EXPORT, VBIoPointer:dword, VBErrorFlag:dword,
VBSystemState:dword,
VBIoData:dword, VBIoParm:dword, VBLGradThres:dword
Prolog
;* Stage 1 Get addresses of IOPointer, ErrorFlag, SystemState,
;* IoData, IoParm, LGradThres which point back into VB static array.
mov eax, VBIoPointer ; get VB IoPointer address
mov IoPointer, eax ; move it to asm
mov eax, VBErrorFlag ; get VB ErrorFlag address
mov ErrorFlag, eax ; mov it to asm
mov eax, VBSystemState ; get VB SystemState address
mov SystemState, eax ; move it to asm
mov eax, VBIoData ; get VB IoData address
mov IoData, eax ; move it to asm
mov eax, VBIoParm ; get VB IoParm address
mov IoParm, eax ; move it to asm
mov eax, VBLGradThres ; get VB LGradThres address
mov LGradThres, eax ; move it to asm
;* Stage 2 zero the interrupt counter and system state
mov IntCount, 0
mov LocalSysState, 0
;* Stage 3 install dummy interrupt vector
call SetDummyIntVector ; Set dummy IrqLevel interrupt
;* Stage 4 make sure interrupt is masked on the das board
call DisableDasInt
;* Stage 5 Set up Irq level in bits 4-6 of register 9
call SetDasIrqLevel
;* Stage 6 set up counter 0 with number of rows AND enable
;* hardware trigger. This is done in Counter0SetUp.
call Counter0SetUp
;* Stage 7 Enable interrupt on 8259a
call EnableIrqMask
;* Stage 8 Set Irq 5 highest prority in 8259a - didn't seem to
;* make any difference in performance
; call Irg5HighestPriority
;* Stage 9 Burst length set-up
call EnableDasBurstMode
;* Stage 10 - clear fifo
call InitDasFifo ; read and discard 256 fifo words
;* Stage 11 Set application interrupt vector
call SetDasIntVector ; Set IrqLevel interrupt vector
;* Stage 12 Set LocalIop to DataRows - 1.
MOV ax, DataRows - 1 ; set LocalIop = DataRows
mov LocalIop, ax ;
les bx, IoPointer ; get address IoPointer%
mov es:[bx], ax ; also set VB IoPointer% = 0
;* Stage 13 Set hardware trigger
call SetHardwareTrigger
;* Stage 14 Clear flip-flop on Pin 25
call ClearDasPin25
;* Stage 15 Enable interrupt on das board
call EnableDasInt
Epilog
ret 24
DasIntOn ENDP
This got a bit complicated.
The ComputerBoard clone of the Keithly-Metrabyte a/d
converter powers-up in an UNKNOWN state. Or at least
partially UNKNOWN.
One of the random states includes triggering spurious
interrupt. So a dummy handler had to be inserted to
possibly field bad data.
The attempt was made to interface directly to hardware
without a microcontoller buffer was partially successful.
Sampling at the 1 Khz rate revealed that Windows
occasionally 'did its own thing' as a result of a task
switch and, therfore, interrupts were missed.
To detect when this happened we modified the
ComputerBoards das 1400 board so that a hardware
count of interrupts received could be compared to
the software count.
Since the a/d values were buffered a FIFO, the FAST
Pentium could catch up.
But this caused the interrupt handler to increase in size
from about 1 K lines, including white space and comments,
to 2 K lines.
Naturally we wish to be in the problem solving, as
opposed to problem creating, or assignation of blame.
I think we have to consider all possible problem sources.
I am looking at the AC POWER INTERFACE LS SOV
Schematic dated 11-8-96.
I see that the power to the analog and digital cards was
run via a serial port db 25 cable and connector.
Pin assignment are
Pin Function
1 -15 G
2 +15 GS
3 +5 G
4 +15 G
5 5 GS
6 tied to pin 7
7 +15S
8 15 S
9 5
10 tied to pin 10
11 +15
12 tied to pin 11
13 15 S
14 tied to pin 1
15 +5 GS
16 tied to pin 3
17 nc
18 tied to pin 5
19 +24 ground
20 tied to pin 19
21 +5 S
22 tied to pin 9
23 tied to pin 22
24 +24 volts
25 tied to pin 24
The +24 volts runs to solenoids.
The remaining power runs to both digital and analog Ics.
While some are left wondering why engineers had not
thought of running analog, digital and solenoid power
down an inexpensive 24 pin PC serial port cable before,
perhaps, we might all guess, other engineers lack
sufficient innovative audacity.
One engineer opined last summer, when I was working
in the shop on the digital FX, that the PC Data System
boards may have to be redesigned.
Let's hope that such a major revision is not required.
Naturally, me being a TOTAL CONSERVATIVE [as
evidenced by Morales and my genocide court filing],
I plan to physically separate the analog and digital
IC s on the digital FX.
And I am thinking about on-board power regulation to
keep the 80c32, analog, and digital chips super-happy.
In the field, of course.
I will leave in several hours. In my grey rabbit.
Air travel safety worries me more now.
Especially after publication of last book.
Just in case, I will bring my passport.
The thought of two machines located 180 miles NW
of Edmonton not working well is, of course,
chilling.
I sure glad the 8051 version of PC Data System is
working fairly well. And is MAKING money for
Metriguard.
See you on Tuesday, Allah willing.
Later
bill
Title: Payne/Morales v. NSA -- Defendant's Response to Motion for Summary
Judgment
16 January 1998
Source: William H. Payne
See related files:
http://jya.com/whpfiles.htm
U.S. Department of Justice
United States Attorney
District of New Mexico
__________________________________________________________
Post Office Box 607
Albuquerque, New Mexico 87103
505/766-3341
505/766-2868
FAX 505/766-8517
January 5, 1998
W.H. Payne
P.O. Box 14838
Albuquerque, New Mexico 87191
Re: Payne & Morales v. Minihan
USDC NM CIV 97-0266 SC/DJS
Dear Mr. Payne:
Enclosed is a court-endorsed copy of Defendant's Response to
Plaintiffs' Motion for Summary Judgment Based on Evidence from
Admissions.
Sincerely,
JOHN J. KELLY
United States Attorney
[Signature]
JAN ELIZABETH MITCHELL
Assistant U. S. Attorney
JEM/yh
Enclosure
cc/enc: Arthur R. Morales
[Stamp]
FILED
United States District Court
District of New Mexico
98 JAN -5 PM 3:46
Robert M. Marsh
District Clerk
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW MEXICO
WILLIAM H. PAYNE )
ARTHUR R. MORALES )
)
Plaintiffs, )
)
vs. ) CIVIL NO. 97-026 SC/DJS
)
LT GEN KENNETH A. MINIHAN )
USAF Director, National Security )
Agency, )
)
Defendant.
DEFENDANT'S RESPONSE TO PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT
BASED ON EVIDENCE FROM ADMISSIONS
Defendant Minihan responds to Plaintiff's Motion for
Summary Judgment Based On Evidence From Admissions1 as follows:
1. Commencing in October, 1997, Plaintiffs served
numerous sets of Requests for Admissions on various employees of
the National Security Agency and on current and past employees of
the Sandia National Laboratory.
2. Counsel for Defendant was not served with copies of
any of said Requests for Admissions until sometime after the
individuals had been served.2
____________________
1 It should be noted that the instant Motion for Summary
Judgment constitutes Plaintiffs' second motion for summary
judgment. Plaintiffs filed an initial Motion for Summary Judgment
on June 4, 1997 to which Defendant responded on June 19, 1997, and
Plaintiffs filed a Reply on July 1, 1997. Said initial Motion for
Summary Judgment has not been ruled upon. In addition, Defendant
filed a Motion to Dismiss Plaintiff Arthur R. Morales on September
23, 1997, and a Motion seeking dismissal of Plaintiff William
Payne's Freedom of Information Act action on October 3, 1997. All
briefing by all parties has been completed on those Motions.
2 On October 13, 1997, Plaintiffs mailed a First Set of
Admissions to Kenneth Minihan. However, not until November 3,
1997, did Plaintiffs mail a copy of said First Set of Request for
3. Upon becoming aware that Plaintiffs had served
Requests for Admissions on a number of individuals, on October 23,
1997, Counsel for Defendant filed a Motion and Memorandum To Strike
Any And All Of Plaintiffs' First Set of Requests For Admissions To
Various Employees Of The National Security Agency And To Various
Employees Of Sandia National Laboratory, (hereinafter "Motion and
Memorandum.")
4. As grounds for the Motion and Memorandum, Defendant
argued that Plaintiffs had blatantly disregarded this Court's Order
pertaining to the conduct of discovery and the deadline for
discovery in this Freedom of Information Act action.
5. In Defendant's Motion and Memorandum, Counsel for
Defendant also objected to Plaintiffs' sua sponte decision to
modify the Court's June 11 Order to reflect the delay of the
Court's October 7 Order and the establishment, without leave of
this Court, of new deadlines for discovery, motions practice, and
the filing of the PreTrial Order. (Motion and Memorandum 9, at
4.)
6. In the Motion and Memorandum, Defendant requested
that this Court strike any and all "First Set of Request for
Admission" propounded by Plaintiffs. (Motion and Memorandum, at 5.)
7. Plaintiffs responded to the Motion and Memorandum on
November 5, 1997, specifically seeking that this Court "take no
action in this case until Supreme court takes action on writs on
____________________
Admissions to Counsel for Defendant. Counsel for Defendant was not
provided with copies of any other Requests for Admissions sent to
employees of NSA or employees of the Sandia National Laboratory.
2
mandamus, prohibition, and criminal complaint affidavits filed
against judges Svet and Campos and US Attorney Mitchell."
(Plaintiffs' Response to Motion And Memorandum To Strike Any And
All Of Plaintiffs' First Set Of Request For Admissions To Various
Employees Of The National Security Agency And To Various Employees
Of Sandia National Laboratories, 11, at 10.)
8. To date, no order has been issued by this Court on
the matters raised in the Motion and Memorandum, nor has any other
court issued any orders concerning Plaintiffs' cause of action and
various complaints.
9. By their own request, Plaintiffs sought to stay a
ruling on the Defendant's Motion and Memorandum. Absent any ruling
on either the Motion and Memorandum or Plaintiffs' Response,
Defendant Minihan, employees of NSA, and employees of Sandia
National Laboratory, were not obligated to respond to the Requests
for Admissions as provided by Fed.R.Civ.P. 36.3 For Plaintiffs to
now assert in their "Motion for Summary Judgment On Based On
Evidence From Admissions" that because the individuals have not
responded to the Requests for Admissions they are deemed admitted,
flies in the face of their own prayer to this Court to stay a
ruling on the Defendant's Motion to strike the Requests for
Admissions until the Supreme Court takes action.
____________________
3 Despite the fact that Defendant's employees and other
individuals are not required to respond to the Requests for
Admissions based upon the outstanding pleadings which have yet to
be ruled on by this Court, Plaintiffs characterize that all
admissions are admitted and then publish those admissions on the
Internet.
3
10. Defendant requests that this Court either rule upon
Defendant's Motion and Memorandum granting the request to strike
the Requests for Admissions, or grant Plaintiffs' request to stay
this action pending the issuance of the order sought by Plaintiffs
in another forum. Should this Court deny Defendant's Motion and
Memorandum, Defendant respectfully requests that the individuals to
whom Requests for Admissions are appropriate in this action be
given the thirty days to respond to said admissions as provided by
the Federal Rules of Civil Procedure.
11. Plaintiffs requested a stay. Absent a ruling from
this Court denying their request, they cannot proceed to assert
that the Requests for Admissions are deemed admitted. Accordingly,
Plaintiffs' "Motion For Summary Judgment On Based On Evidence From
Admissions" must be denied.
Respectfully submitted,
JOHN J. KELLY
United States Attorney
[Signature]
JAN ELIZABETH MITCHELL
Assistant U.S. Attorney
P.O. Box 607
Albuquerque, New Mexico 87103
(505) 766-3341
I HEREBY CERTIFY that a true copy
of the foregoing pleading was mailed
to PRO SE PLAINTIFFS,
this 5th day of January, 1998.
[Signature]
JAN ELIZABETH MITCHELL
Assistant U. S. Attorney
4
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW MEXICO
William H. Payne )
Arthur R. Morales )
)
Plaintiffs, )
)
v ) CIV NO 97 0266
) SC/DJS
)
Lieutenant General Kenneth A. Minihan, USAF )
Director, National Security Agency )
National Security Agency )
)
Defendant )
REPLY TO DEFENDANT'S RESPONSE TO PLAINTIFFS' MOTION FOR
SUMMARY JUDGMENT BASED ON EVIDENCE FROM ADMISSIONS
1 COMES NOW plaintiffs Payne [Payne] and Morales [Morales]
[Plaintiffs], pro se litigants to exercise their rights
guaranteed under the Constitution, Rules of Civil Procedure,
and Local Civil Rules to respond to Defendant's MOTION filed
on 98 JAN-5 within the 14 days allowed by local rule 7.3(b)(4).
2 US Attorney Mitchell [Mitchell] writes,
Counsel for Defendant was not served with copies of any of
said Requests for Admissions until sometime after the
individuals had been served.2
Mitchell WAS SERVED
PLAINTIFFS' FIRST SET OF REQUEST FOR ADMISSION TO
NSA DIRECTOR KENNETH MINIHAN
I HEREBY CERTIFY that a copy of the foregoing request for
admissions was mailed to Jan Elizabeth Mitchell, Assistant US
Attorney, 525 Silver SW, ABQ, NM 87102 this Monday November
3, 1997.
Michell was not served with any other admissions since
Mitchell is not representing others.
Plaintiffs' served Defendant Minihan properly. And Minihan
failed to respond to Minihan's admissions within the time
allotted by law.
3 US Attorney Mitchell writes,
As grounds for the Motion and Memorandum, Defendant
argued that Plaintiffs had blatantly disregarded this Court's
Order pertaining to the conduct of discovery and the deadline
for discovery in this Freedom of Information Act action.
Judges Svet and Campos willfully violated Plaintiffs' right
to Discovery. And thereby earned criminal complaint affidavits
filed with judge Scalia of the Supreme Court.
4 US Attorney Mitchell writes,
In Defendant's Motion and Memorandum, Counsel for Defendant
also objected to Plaintiffs' sua sponte decision to
modify the Court's June 11 Order to reflect the delay of the
Court's October 7 Order and the establishment, without leave
of this Court, of new deadlines for discovery, motions
practice, and the filing of the PreTrial Order. (Motion and
Memorandum 9, at 4.)
Judge Svet and Campos attempt to deny Plaintiffs' right to
Discovery, again, earned Svet and Campos criminal complaint
affidavits.
Plaintiffs exercise their right under the Federal Rules of
Civil Procedure and the Constitution to conduct Discovery
WITHOUT LEAVE OF COURT!
5 US Attorney Mitchell writes,
By their own request, Plaintiffs sought to stay a ruling on
the Defendant's Motion and Memorandum. Absent any ruling on
either the Motion and Memorandum or Plaintiffs' Response,
Defendant Minihan, employees of NSA, and employees of
Sandia National Laboratory, were not obligated to respond to
the Requests for Admissions as provided by Fed.R.Civ.P. 36.3
For Plaintiffs to now assert in their "Motion for Summary
Judgment On Based On Evidence From Admissions" that because
the individuals have not responded to the Requests for
Admissions they are deemed admitted, flies in the face of
their own prayer to this Court to stay a ruling on the
Defendant's Motion to strike the Requests for Admissions until
the Supreme Court takes action.
Plaintiffs' have REPEATEDLY asked judge Svet and Campos to
disqualify themselves from any rulings on this case because
Campos and Svet do NOT obey the Federal Rules of Civil
Procedure.
Replace judges Svet and Campos because these judges
have demonstrated, IN WRITING, they do not follow the
Federal Rules of Civil Procedure.
Plaintiffs' pleas are directed a replacement judge[s]. Not
Svet and Campos.
Therefore, Svet and Campos' failure to remove themselves does
not stop the legal process.
Mitchell cites NO law to support her claim that time
constraints imposed under Fed.R.Civ.P. 36.3 are inapplicable
as a result of Svet's and Campos' failure to remove themselves.
6 US Attorney Mitchell writes,
Defendant requests that this Court either rule upon
Defendant's Motion and Memorandum granting the request to
strike the Requests for Admissions, or grant Plaintiffs'
request to stay this action pending the issuance of the order
sought by Plaintiffs in another forum. Should this Court deny
Defendant's Motion and Memorandum, Defendant respectfully
requests that the individuals to whom Requests for Admissions
are appropriate in this action be given the thirty days to
respond to said admissions as provided by the Federal Rules of
Civil Procedure.
REPLACEMENT JUDGES of the Court should realize the outcome
of the lawsuit has attained international interest as a result
of the
1 bungled NSA spy sting on Iran
2 US government agencies NSA, NIST, and the FBI's
attempt to control cryptography.
Mitchell's
DEFENDANT'S RESPONSE TO PLAINTIFFS' MOTION FOR
SUMMARY JUDGMENT BASED ON EVIDENCE FROM ADMISSIONS
was posted on Internet at jya.com, click cryptome
nsasuit8.htm USA/NSA Responds to Payne/Morales Motion
January 16, 1998
Importance of this posting is summed-up in the Toronto Sun,
Jan. 11, 1998
US, Iran Need Each Other
by Eric Margolis
Iran launched a surprise charm offensive last week,
throwing Washington into serious confusion.
In a lengthy interview on CNN, Iran's new president, Mohammad
Khatami, skillfully analyzed the bitter relations between the
two nations and cautiously extended an olive branch to
Washington, calling for an end to their 19-year cold war.
Khatami's diplomatic ju-jitsu flummoxed the Clinton
administration, which was busy trying to rally international
support against Tehran - and to overthrow Iran's elected
government.
Both capitals are split over the question of relations.
In Washington, the military establishment and conservative
Republicans have inflated Iran into a bogeyman to
justify military budgets and keep U.S. forces in the Mideast.
...
America incited Iraq to invade Iran in 1980. They did this to
crush the Islamic revolution, then provided massive war aid to
Saddam Hussein. Half a million Iranians died.
The US got caught involved in genocide. Using high tech.
This is one subject of this lawsuit.
Albuquerque Journal Tuesday 1/13/98 carried the editorial.
Khatami Move Is Profile in Courage
Richard Reeves
Syndicated Columnist
LOS ANGELES - If an American leader had done what
Iranian President Mohammed Khatami did last Wednesday,
it would have been hailed as a profile in courage. ...
Miscalculation! We armed and pampered Saddam Hussein in
the hope that Iraq would destroy Iran. Now that's policy and
behavior to think about. Here is something to think about: If
Presidents Eisenhower and Kennedy had pursued any kind of
sensible policy toward Cuba and Fidel Castro - opposed to
the policy of trying to assassinate him - there never would
have been a Cuban missile crisis.
I think Iranians have financed and encouraged terrorism
against the interests of the United States and Israel. I
would not be surprised at all if something like proof emerges
soon, perhaps anonymously, from the CIA and other government
agencies, where many officials have built their careers on
sanctioning and isolating Iran, to try to straighten the
backbones of the president and people of the United States.
If they succeed, America fails. What would be more
effective in closing down Iranian terrorism? More hostility,
sanctions and charges? Or beginning the process toward more
normal relations with a country positioned and born to be
great? ...
Clearly genocide fits into
Now that's policy and behavior to think about.
The wired world is watching what this Court, hopefully
minus judges Svet and Campos, will do.
What is there to be? A series of possibly unfortunate
events?
Or does this Court order release the lawfully requested
documents to help settle this American tragedy?
WHEREFORE.
7 Have replacement judges of this Court DENY Mitchell's
Plaintiffs requested a stay. Absent a ruling from
this Court denying their request, they cannot proceed to
assert that the Requests for Admissions are deemed admitted.
Accordingly, Plaintiffs' "Motion For Summary Judgment On Based
On Evidence From Admissions" must be denied.
for reason that Mitchell's request to subvert both the Discovery
processes and its time limits have no basis in law. And appears
to plead to judges who do not obey the Federal Rules of Civil
Procedure.
9 IMMEDIATELY ORDER Defendant to release the requested
documents in the interest of national safety so that this
matter can be settled.
Aggrieved victims of US genocide are reading these pleadings.
Respectfully submitted,
_________________________
William H. Payne
13015 Calle de Sandias NE
Albuquerque, NM 87111
_________________________
Arthur R. Morales
1024 Los Arboles NW
Albuquerque, NM 87107
Pro se litigants
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing memorandum
was mailed to Lieutenant General Kenneth A. Minihan, USAF,
Director, National Security Agency, National Security Agency,
9800 Savage Road, Fort George G. Meade, MD 20755-6000
and hand delivered to John J. Kelly, US Attorney, 525 Silver
SW, ABQ, NM 87102 this Tuesday January 20, 1997.
5
Title:
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