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141-471: The commission was disbanded in March 2006, without any concrete evidence given to support the original allegations of KGB ties to Italian politicians. In five years, the commission had heard 47 witnesses, for a total cost of 1.9 million euros. Scaramella was arrested in late December 2006 and charged with libel and illegal weapons' trade , with wiretaps of phone calls between Scaramella and Guzzanti published by

282-583: A New York Times journalist early in the episode, Ledeen suggested that his book on the leadership lessons of Machiavelli had influenced Cayne, and observed that "Jimmy saw himself in Machiavelli ;... you have to get rid of failure and you have to punish lack of virtue ruthlessly and all the time." His first wife was Jenny Ledeen of St. Louis, Mo. Ledeen has three children: Simone, Gabriel, and Daniel. Simone has worked both in Iraq and Afghanistan for

423-443: A per se action: If the plaintiff proves that such a statement was made and was false, to recover damages the plaintiff need only prove that someone had made the statement to any third party. No proof of special damages is required. However, to recover full compensation a plaintiff should be prepared to prove actual damages. As with any defamation case, truth remains an absolute defence to defamation per se . This means that even if

564-419: A case the truth of the statements was no justification for the public and insulting manner in which they had been made, but, even in public matters, the accused had the opportunity to justify his actions by openly stating what he considered necessary for public safety to be denounced by the libel and proving his assertions to be true. The second head included defamatory statements made in private, and in this case

705-466: A child with a Christian man, and that this act was common. Following Osborne's anti-Semitic publication, several Jews were attacked. Initially, the judge seemed to believe the court could do nothing since no individual was singled out by Osborne's writings. However, the court concluded that "since the publication implied the act was one Jews frequently did, the whole community of Jews was defamed." Though various reports of this case give differing accounts of

846-799: A commoner in England was known as libel or slander, the defamation of a member of the English aristocracy was called scandalum magnatum, literally "the scandal of magnates". Following the Second World War and with the rise of contemporary international human rights law , the right to a legal remedy for defamation was included in Article 17 of the United Nations International Covenant on Civil and Political Rights (ICCPR), which states that: This implies

987-399: A consultant.) Also in attendance was Ghorbanifar and a number of other Iranians." Colleagues Andrew McCarthy and Mark R. Levin have defended Ledeen, writing: "Up until now, the fiction recklessly spewed by disgruntled intelligence-community retirees and their media enablers—some of whom have conceded that the claim is based on zero evidence—has been that Michael had something to do with

1128-406: A criminal offence and provide for penalties as such. Article 19 , a British free expression advocacy group, has published global maps charting the existence of criminal defamation law across the globe, as well as showing countries that have special protections for political leaders or functionaries of the state. There can be regional statutes that may differ from the national norm. For example, in

1269-408: A defamation action typically requires that a plaintiff claiming defamation prove that the defendant: Additionally, American courts apply special rules in the case of statements made in the press concerning public figures, which can be used as a defence. While plaintiff alleging defamation in an American court must usually prove that the statement caused harm, and was made without adequate research into

1410-467: A distinction between "fascism-regime" and "fascism-movement." Ledeen's political views developed to stress "the urgency of combating centralized state power and the centrality of human freedom" Ledeen continued his studies in Italian Fascism with a study of the takeover of Fiume by Italian irredentist forces under Gabriele d'Annunzio , who Ledeen argued was the prototype for Mussolini. In

1551-559: A doubt, the first name on the list was that of Prodi, especially during the period preceding the spring elections. ... Prodi was a real obsession, in spite of the fact that nothing ever came out on your Prime Minister." In a rebuke to the original Mitrokhin Commission's authenticity, Vasili Mitrokhin himself refused to meet the commission's members before his death. On 1 December 2006, several Italian newspapers published interceptions of telephone calls between Guzzanti and Scaramella, who

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1692-464: A famous trademark has been diluted through tarnishment, see generally trademark dilution , " intentional interference with contract ", and "negligent misrepresentation". In America, for example, the unique tort of false light protects plaintiffs against statements which are not technically false but are misleading. Libel and slander both require publication. Although laws vary by state; in America,

1833-515: A former executive director of American Israel Public Affairs Committee (AIPAC). Ledeen had also been part of the board of the U.S. Committee for a Free Lebanon. According to The Washington Post , quoted by Asia Times , he was the only full-time international affairs analyst regularly consulted by Karl Rove , George W. Bush 's closest advisor. Following the February 2003 speech by French Minister for Foreign Affairs Dominique de Villepin at

1974-458: A humiliating or degrading manner), et cetera. "Fama" is a generic term referring to reputation and actio iniuriarum pertaining to it encompasses defamation more broadly Beyond simply covering actions that fall within the broader concept of defamation, "actio iniuriarum" relating to infringements of a person's corpus provides civil remedies for assaults, acts of a sexual or indecent nature, and 'wrongful arrest and detention'. In Scots law , which

2115-551: A legally redressable injury. The precise legal definition of defamation varies from country to country. It is not necessarily restricted to making assertions that are falsifiable , and can extend to concepts that are more abstract than reputation – like dignity and honour . In the English-speaking world, the law of defamation traditionally distinguishes between libel (written, printed, posted online, published in mass media) and slander (oral speech). It

2256-434: A libel case in an American court, the statement must have been published knowing it to be false or with reckless disregard to its truth (i.e. actual malice ). The Associated Press estimates that 95% of libel cases involving news stories do not arise from high-profile news stories, but "run of the mill" local stories like news coverage of local criminal investigations or trials, or business profiles. An early example of libel

2397-466: A person that is included in a personal database and that one knows to be false, is punished with six months to three years in prison. When there is harm to somebody, penalties are aggravated by an extra half (Article 117 bis, §§ 2nd and 3rd). Defamation law in Australia developed primarily out of the English law of defamation and its cases, though now there are differences introduced by statute and by

2538-574: A provably false factual connotation. Subsequent state and federal cases have addressed defamation law and the Internet. American defamation law is much less plaintiff-friendly than its counterparts in European and the Commonwealth countries . A comprehensive discussion of what is and is not libel or slander under American law is difficult, as the definition differs between different states and

2679-634: A right to legal protection against defamation; however, this right co-exists with the right to freedom of opinion and expression under Article 19 of the ICCPR as well as Article 19 of the Universal Declaration of Human Rights . Article 19 of the ICCPR expressly provides that the right to freedom of opinion and expression may be limited so far as it is necessary "for respect of the rights or reputations of others". Consequently, international human rights law provides that while individuals should have

2820-505: A staffer for Senator Chuck Grassley on the Senate Judiciary Committee which was looking into Trump's Russia issue . According to FBI notes, she requested the assistance of both a defense contractor and Newt Gingrich who asked Judicial Watch for financial assistance for her efforts. Judicial Watch requested another contractor to access the "deep web and dark web". Matt Tate, a former British intelligence official,

2961-430: A statement, even if truthful, intended to harm the claimant out of malice; some have a separate tort or delict of " invasion of privacy " in which the making of a true statement may give rise to liability: but neither of these comes under the general heading of "defamation". The tort of harassment created by Singapore's Protection from Harassment Act 2014 is an example of a tort of this type being created by statute. There

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3102-503: Is 'little historical basis in Scots law for the kind of structural difficulties that have restricted English law' in the development of mechanisms to protect so-called 'rights of personality'. The actio iniuriarum heritage of Scots law gives the courts scope to recognise, and afford reparation in, cases in which no patrimonial (or 'quasi-patrimonial') 'loss' has occurred, but a recognised dignitary interest has nonetheless been invaded through

3243-471: Is 40,000 ALL to three million ALL (c. $ 25 100 ). In addition, defamation of authorities, public officials or foreign representatives (Articles 227, 239 to 241) are separate crimes with maximum penalties varying from one to three years of imprisonment. In Argentina , the crimes of calumny and injury are foreseen in the chapter "Crimes Against Honor" (Articles 109 to 117-bis) of the Penal Code. Calumny

3384-417: Is also, in almost all jurisdictions, a tort or delict of " misrepresentation ", involving the making of a statement that is untrue even though not defamatory. Thus a surveyor who states a house is free from risk of flooding has not defamed anyone, but may still be liable to someone who purchases the house relying on this statement. Other increasingly common claims similar to defamation in U.S. law are claims that

3525-815: Is an American historian and neoconservative foreign policy analyst. He is a former consultant to the United States National Security Council , the United States Department of State , and the United States Department of Defense . He held the Freedom Scholar chair at the American Enterprise Institute where he was a scholar for 20 years, and now holds the similarly named chair at the Foundation for Defense of Democracies . He

3666-566: Is clear and accessible to everyone", 2) "proven to be necessary and legitimate to protect the rights or reputations of others", and 3) "proportionate and the least restrictive to achieve the purported aim". This test is analogous to the Oakes Test applied domestically by the Supreme Court of Canada in assessing whether limitations on constitutional rights are "demonstrably justifiable in a free and democratic society" under Section 1 of

3807-431: Is closely related to Roman Dutch law, the remedy for defamation is similarly the actio iniuriarium and the most common defence is "veritas" (i.e. proving the truth of otherwise defamatory statement). Defamation falls within the realm of non-patrimonial (i.e. dignitary) interests. The Scots law pertaining to the protection of non-patrimonial interests is said to be 'a thing of shreds and patches'. This notwithstanding, there

3948-501: Is correct, we will have to pursue the war against terror far beyond the boundaries of the Middle East, into the heart of Western Europe. And there, as in the Middle East, our greatest weapons are political: the demonstrated desire for freedom of the peoples of the countries that oppose us." Jonah Goldberg , Ledeen's colleague at National Review , coined the term "Ledeen Doctrine" in a 2002 column. This tongue-in-cheek "doctrine"

4089-544: Is defined as "the false imputation to a determined person of a concrete crime that leads to a lawsuit" (Article 109). However, expressions referring to subjects of public interest or that are not assertive do not constitute calumny. Penalty is a fine from 3,000 to 30,000 pesos . He who intentionally dishonor or discredit a determined person is punished with a penalty from 1,500 to 20,000 pesos (Article 110). He who publishes or reproduces, by any means, calumnies and injuries made by others, will be punished as responsible himself for

4230-518: Is further affected by federal law. Some states codify what constitutes slander and libel together, merging the concepts into a single defamation law. New Zealand received English law with the signing of the Treaty of Waitangi in February 1840. The current Act is the Defamation Act 1992 which came into force on 1 February 1993 and repealed the Defamation Act 1954 . New Zealand law allows for

4371-617: Is likely that Indian courts would treat this principle as persuasive precedent. Recently, incidents of defamation in relation to public figures have attracted public attention. The origins of U.S. defamation law pre-date the American Revolution . Though the First Amendment of the American Constitution was designed to protect freedom of the press, it was primarily envisioned to prevent censorship by

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4512-764: Is more controversial as it involves the state expressly seeking to restrict freedom of expression . Human rights organisations, and other organisations such as the Council of Europe and Organization for Security and Co-operation in Europe , have campaigned against strict defamation laws that criminalise defamation. The freedom of expression advocacy group Article 19 opposes criminal defamation, arguing that civil defamation laws providing defences for statements on matters of public interest are better compliant with international human rights law. The European Court of Human Rights has placed restrictions on criminal libel laws because of

4653-552: Is no need to prove that specific damage or loss has occurred. However, Section 6 of the Act allows for a defamation action brought by a corporate body to proceed only when the body corporate alleges and proves that the publication of the defamation has caused or is likely to cause pecuniary loss to that body corporate. As is the case for most Commonwealth jurisdictions, Canada follows English law on defamation issues (except in Quebec where

4794-401: Is not defamation. While defamation torts are broadly similar across common law jurisdictions; differences have arisen as a result of diverging case law, statutes and other legislative action, and constitutional concerns specific to individual jurisdictions. Some jurisdictions have a separate tort or delict of injury , intentional infliction of emotional distress , involving the making of

4935-409: Is often purchased by publishers and journalists to cover potential damage awards from libel lawsuits. Roughly 3/4 of all money spent on claims by liability insurers goes to lawyers and only 1/4 goes to settlements or judgments, according to one estimate from Michelle Worrall Tilton of Media Risk Consultants. Some advise buying worldwide coverage that offers defense against cases regardless of where in

5076-461: Is that of truth. Proving the truth of an allegedly defamatory statement is always a valid defence. Where a statement is partially true, certain jurisdictions in the Commonwealth have provided by statute that the defence "shall not fail by reason only that the truth of every charge is not proved if the words not proved to be true do not materially injure the claimant's reputation having regard to

5217-509: Is the case of John Peter Zenger in 1735. Zenger was hired to publish the New York Weekly Journal . When he printed another man's article criticising William Cosby , the royal governor of Colonial New York , Zenger was accused of seditious libel . The verdict was returned as not guilty on the charge of seditious libel, because it was proven that all the statements Zenger had published about Cosby had been true, so there

5358-513: Is the main backer of the insurgency in Iraq and even supported the al-Qaida network formerly led by al-Zarqawi despite its declaration of jihad against Shi'ite Muslims . He claimed that German and Italian court documents showed Zarqawi created a European terrorist network while based in Tehran. Ledeen was a board member of the "Coalition for Democracy in Iran" (CDI), founded by Morris Amitay ,

5499-681: Is treated as a civil wrong ( tort , delict ), as a criminal offence , or both. Defamation and related laws can encompass a variety of acts (from general defamation and insult – as applicable to every citizen –‍ to specialized provisions covering specific entities and social structures): Defamation law has a long history stretching back to classical antiquity. While defamation has been recognized as an actionable wrong in various forms across historical legal systems and in various moral and religious philosophies, defamation law in contemporary legal systems can primarily be traced back to Roman and early English law. Roman law

5640-492: Is typically regarded as a tort for which the offended party can take civil action . The range of remedies available to successful plaintiffs in defamation cases varies between jurisdictions and range from damages to court orders requiring the defendant to retract the offending statement or to publish a correction or an apology. Modern defamation in common law jurisdictions are historically derived from English defamation law . English law allows actions for libel to be brought in

5781-585: Is usually summarized as " Every ten years or so, the United States needs to pick up some small crappy little country and throw it against the wall, just to show the world we mean business, " which Goldberg remembered Ledeen saying in an early 1990s speech. Ledeen has also advocated that U.S. leaders take a stronger rhetorical stance in wars on Islamic regimes and militant groups. For instance he has recommended in public talks that U.S. leaders question or challenge defeated Islamic militaries or forces regarding

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5922-528: The California Code of Civil Procedure and Ontario's Protection of Public Participation Act do so by enabling defendants to make a special motion to strike or dismiss during which discovery is suspended and which, if successful, would terminate the lawsuit and allow the party to recover its legal costs from the plaintiff. There are a variety of defences to defamation claims in common law jurisdictions. The two most fundamental defences arise from

6063-653: The Canadian Charter of Rights and Freedoms , the " necessary in a democratic society " test applied by the European Court of Human Rights in assessing limitations on rights under the ECHR, Section 36 of the post- Apartheid Constitution of South Africa , and Section 24 of the 2010 Constitution of Kenya. Nevertheless, the worldwide use of criminal and civil defamation , to censor, intimidate or silence critics, has been increasing in recent years. In 2011,

6204-592: The Center for Strategic and International Studies at Georgetown University at the time. All four testified that they believed the Soviet Union had provided material support, training and inspiration for various terrorist groupings. Ledeen was involved in the Iran–Contra affair as a consultant to National Security Advisor Robert C. McFarlane . Ledeen met with Israeli prime minister Shimon Peres , officials of

6345-444: The Commonwealth of Independent States , America, and Canada. Questions of group libel have been appearing in common law for hundreds of years. One of the earliest known cases of a defendant being tried for defamation of a group was the case of R v Orme and Nutt (1700). In this case, the jury found that the defendant was guilty of libeling several subjects, though they did not specifically identify who these subjects were. A report of

6486-726: The Italian Mitrokhin Commission . According to Craig Unger , "With Ronald Reagan newly installed in the White House, the so-called Bulgarian Connection made perfect Cold War propaganda. Michael Ledeen was one of its most vocal proponents, promoting it on TV and in newspapers all over the world." In the early 1980s, Ledeen appeared before the newly established Senate Subcommittee on Security and Terrorism alongside former CIA director William Colby , author Claire Sterling , and former Newsweek editor Arnaud de Borchgrave. Both Ledeen and de Borchgrave worked for

6627-694: The Pajamas Media website) and is often referenced by neoconservative writers advocating a more forceful and broader " war on terror ." In 1979, Ledeen was one of the first Western writers to argue that Ayatollah Ruhollah Khomeini was a " clerical fascist ", and that while it was legitimate to criticize the Shah's regime, if Khomeini seized power in Iran the Iranian people would suffer an even greater loss of freedom and women would be deprived of political and social rights. He presently believes that "No one in

6768-569: The Palestinian Liberation Organization . Five years later, in 1985, a Wall Street Journal investigation suggested that the series of Billygate articles written by Ledeen were part of a larger disinformation campaign intended to influence the outcome of that year's presidential election. According to the reporting, Francesco Pazienza , an officer of the Italian intelligence agency SISMI , alleged that Ledeen

6909-460: The Supreme Court of Canada rejected the actual malice test adopted in the US case New York Times Co. v. Sullivan . Once a claim has been made, the defendant may avail themselves of a defence of justification (the truth), fair comment, responsible communication, or privilege. Publishers of defamatory comments may also use the defence of innocent dissemination where they had no knowledge of the nature of

7050-595: The United Nations Human Rights Committee published their General comment No. 34 (CCPR/C/GC/34) – regarding Article 19 of the ICCPR. Paragraph 47 states: Defamation laws must be crafted with care to ensure that they comply with paragraph 3 [of Article 19 of the ICCPR], and that they do not serve, in practice, to stifle freedom of expression. All such laws, in particular penal defamation laws, should include such defences as

7191-689: The University of Wisconsin–Madison where he studied under the historian George Mosse . His doctoral dissertation eventually became Universal Fascism: The Theory and Practice of the Fascist International, 1928–1936 , first published in 1972. The book explored Italian leader Benito Mussolini 's efforts to create a Fascist international in the late 1920s and early 1930s. Ledeen taught at Washington University in St. Louis but left after being denied tenure. Some faculty indicated that questions about

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7332-787: The Yellowcake forgery scandal and the SISMI-Telecom affair , in which Marco Mancini, no. 2 of the SISMI already indicted in the Abu Omar case, was arrested by the end of 2006. The investigation also showed a connection between Scaramella and the CIA, in particular through Filippo Marino, one of Scaramella's closest partners since the 1990s and co-founder of the Environmental Crime Prevention Program , which

7473-401: The defence of truth and they should not be applied with regard to those forms of expression that are not, of their nature, subject to verification. At least with regard to comments about public figures , consideration should be given to avoiding penalizing or otherwise rendering unlawful untrue statements that have been published in error but without malice. In any event, a public interest in

7614-600: The "quality of his scholarship" and about whether or not Ledeen had "used the work of somebody else without proper credit" were issues, although some also noted that "the 'quasi-irregularity' at issue didn't warrant the negative vote on tenure." Ledeen subsequently moved to Rome , where he was hired as the Rome correspondent for The New Republic and was named a visiting professor at the University of Rome for two years until 1977. In Rome, Ledeen worked with Italian historian Renzo De Felice , who greatly influenced Ledeen, drawing

7755-579: The 1980 lead up to the US presidential election, Ledeen, along with Arnaud de Borchgrave , wrote a series of articles published in The New Republic and elsewhere about Jimmy Carter 's brother, Billy Carter 's contacts with the Muammar al-Gaddafi regime in Libya . Ledeen testified before a Senate subcommittee that he believed that Billy Carter had met with and been paid off by Yasser Arafat of

7896-565: The 2003 abduction of Hassan Mustafa Osama Nasr in Milan, a case of extraordinary rendition that gave rise to the Abu Omar case . According to the interceptions, Scaramella was to collect false witnesses among KGB refugees in Europe to support this aim. He was arrested at the end of December 2006 on charges of calumny and illegal weapons' trade. The investigation showed that Scaramella received some of his information from Litvinenko. Scaramella

8037-600: The Abu Omar case, as well as SISMI no. 2, Marco Mancini , who was arrested in July 2006 for the same reason, were some of the informers, alongside Scaramella, of Guzzanti. According to Salvitti, neside targeting Prodi and his staff, this network, also aimed at defaming General Giuseppe Cucchi (the then director of the CESIS), Milan's judges Armando Spataro, in charge of the Abu Omar case, and Guido Salvini , as well as La Repubblica reporters Carlo Bonini and Giuseppe D'Avanzo, who broke

8178-700: The Bulgarian Connection . Pazienza stated that Ledeen "was the person responsible for dreaming up the 'Bulgarian connection' behind the plot to kill the Pope." Ledeen admitted to the Vanity Fair to having been paid $ 10,000 by the SISMI in 1979 or 1980, allegedly on extradition matters with the United States. The Washington Post reporter Michael Dobbs , who had initially believed this conspiracy theory , later wrote that "the Bulgarian connection

8319-592: The CIA and the Federal Bureau of Investigation , was accused by many of his colleagues of "privileging the raison d'état over law". In its final report, issued on 15 March 2006, the Mitrokhin Commission mentioned on page 248 that Bruguière during the course of his investigations allegedly gained information, indicating that the assassination attempt on Pope John Paul II was orchestrated by the GRU ,

8460-825: The Department of Defense; Gabriel is currently a lieutenant in the United States Marines Corps serving his second tour in Iraq; Daniel too is currently a lieutenant in the USMC. He is married to his second wife, Barbara, who was a longtime staffer for Senator Chuck Grassley on the Senate Judiciary Committee until early 2021, when she retired from the Senate. Barbara Ledeen sparked controversy in 2015 when she tried to launch her own investigation into Hillary Clinton 's emails , while

8601-483: The Dutch Caribbean) gives rise to a claim by way of " actio iniuriarum ". For liability under the actio iniuriarum , the general elements of delict must be present, but specific rules have been developed for each element. Causation, for example, is seldom in issue, and is assumed to be present. The elements of liability under the actio iniuriarum are as follows: Under the actio iniuriarum , harm consists in

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8742-531: The High Court for any published statements alleged to defame a named or identifiable individual or individuals (under English law companies are legal persons, and allowed to bring suit for defamation ) in a manner that causes them loss in their trade or profession, or causes a reasonable person to think worse of them. In contemporary common law jurisdictions, to constitute defamation, a claim must generally be false and must have been made to someone other than

8883-593: The Israeli Foreign Ministry, and the CIA to arrange meetings with high-ranking Iranian officials, whereby Iranians supported by the US would be given weapons by Israel, and would proceed to negotiate with Hizbollah for the release of hostages in Lebanon. Ledeen's own version of the events is published in his book, Perilous Statecraft . Ledeen vouched for Iranian intermediary Manucher Ghorbanifar . According to Adnan Khashoggi in 1985, Ghorbanifar

9024-724: The Italian SISMI and the United States CIA are informed by the French DGSE that Rocco Martino , a former Italian intelligence agent, is trying to pass fake documents about Iraq obtaining yellowcake from Niger. However, the SISMI report that a lady, who is controlled by SISMI's Antonio Nucera, in the Niger embassy at Rome presents the fake documents in July 2002. Later, in March 2003, George Tenet incorrectly stated that Iraq, which had large quantities of yellowcake,

9165-621: The Italian SISMI to United States intelligence. These forgeries depicted an attempt by the regime of Iraq's Saddam Hussein to purchase uranium , in the form of yellowcake , from Niger during the Iraq armament crisis, and was part of the rationale for the Iraq War cited by the George W. Bush administration to support the 2003 invasion of Iraq . Guzzanti revived the old " Bulgarian connection " thesis concerning Mehmet Ali Ağca 's 1981 attempted assassination of Pope John Paul II . He stated in

9306-465: The Italian press in late 2006, showing that the two planned to discredit various political opposition figures by claiming ties with the KGB. The 2006 Italian general election , held on 9–10 April, was won by Prodi's centre-left coalition , The Union . In November 2006, the new Italian Parliament instituted a commission to investigate the Mitrokhin Commission for allegations that it was manipulated for political purposes. The inter-parliamentary commission

9447-403: The Italian secret services were all rejected in the 1990s by the Italian government. From 2003 to 2006, he worked for the Mitrokhin Commission. When a left-wing member of the commission questioned his credentials, he promptly remade one. Cited by La Repubblica , according to the investigations of Rome prosecutor Pietro Salvitti, who indicted Scaramella, Nicolò Pollari , head of SISMI indicted in

9588-530: The KGB" financed by Moscow in order to discredit him. In these interceptions, the two men also discussed plans to claim that Antonio Bassolino , president of the Campania region, was linked to the Camorra . According to the Corriere della Sera , these interceptions demonstrated that Scaramella was in contact with Italian police agents, penitentiary police agents, and two CIA agents, one of them being Robert Seldon Lady , former CIA station chief in Milan, indicted by prosecutor Armando Spataro for having coordinated

9729-453: The Pope wrote about it in his last book, Memory and Identity : Conversations Between Millenniums . The Pope wrote that he was convinced the shooting was not Ağca's initiative and that "someone else masterminded it and someone else commissioned it". Guzzanti's claims in the draft report were based on recent computer analysis of photographs that purported to demonstrate suspected conspirator Sergei Antonov 's presence in St Peter's Square during

9870-408: The President" to lobby Bill Clinton to remove Hussein from office. Regarding the "pre-emptive" invasion of Iraq , in 2002 Ledeen criticized the views of former National Security Adviser Brent Scowcroft , writing: Scowcroft has managed to get one thing half right, even though he misdescribes it. He fears that if we attack Iraq "I think we could have an explosion in the Middle East. It could turn

10011-421: The Shi'ite-Sunni conflict, leading reviewer Peter Beinart to note that his "effort to lay virtually every attack by Muslims against Americans at Tehran's feet takes him into rather bizarre territory." The New York Times describes Ledeen's views as "everything traces back to Tehran". Ledeen's phrase, " faster, please " has become a signature meme in Ledeen's writings (it is currently the title of his blog on

10152-500: The United Nations General Assembly against the intervention in Iraq, Ledeen outlined, in a column entitled "A Theory," a possibility that France and Germany , both NATO allies of the United States, "struck a deal with radical Islam and with radical Arabs" to use "extremism and terrorism as the weapon of choice" to weaken the United States. He stated, "It sounds fanciful, to be sure," but that, "If this

10293-470: The United States, criminal defamation is generally limited to the living. However, there are 7 states ( Idaho , Kansas , Louisiana , Nevada , North Dakota , Oklahoma , Utah ) that have criminal statutes regarding defamation of the dead. The Organization for Security and Co-operation in Europe (OSCE) has also published a detailed database on criminal and civil defamation provisions in 55 countries, including all European countries, all member countries of

10434-468: The United States. During his time in Italy, Ledeen endorsed the " Bulgarian connection " conspiracy theory concerning Grey Wolves member Mehmet Ali Ağca 's 1981 attempt to assassinate Pope John Paul II . The theory has since been attacked by various authors and journalists, including Washington Post reporter Michael Dobbs , who initially believed the story as well. The theory was adopted in 2005 by

10575-571: The West has yet supported Iranian democratic organizations" and that "aggressive support for those Iranians who wish to be free" would most likely work in ending the clerical government. According to Justin Raimondo , Ledeen "holds up Bill Clinton and Madeleine Albright as patsies for Khomeini—who supposedly believed that the Ayatollah overthrew Shah Reza Pahlavi because the Iranian government

10716-543: The affair to defend Ghorbanifar", he said that he considered Ghorbanifar to be a friend. During the summer of 2001, Alain Chouet and others with France's DGSE investigate an alleged deal known later as Nigergate in which Iraq was trying to obtain yellowcake from a country in Africa and, by May and June 2002, they investigate any connection with Niger but find that the rumors are entirely false. Furthermore, in July 2002,

10857-577: The alleged "KGB's man in Italy", his staff, Massimo D'Alema , Alfonso Pecoraro Scanio , General Giuseppe Cucchi (later director of the CESIS ), Milan's judges Armando Spataro, and Guido Salvini , both in charge of the Abu Omar case , as well as La Repubblica reporters Carlo Bonini  [ it ] and Giuseppe D'Avanzo  [ it ] , who broke the Niger uranium forgeries . This latter affair refers to falsified classified documents provided by

10998-535: The ancient methods of torture were routinely employed on dissidents of all sorts." Ledeen is currently against both an invasion of Iran or air-strikes within the country. He has argued that the latter may eventually become necessary if negotiations with the Iranian government fail, but it would only be the least bad option of many options and it would lead to many negative unforeseen consequences . The New York Times has called Ledeen's skepticism towards military action against Iran surprising given his opposition to

11139-513: The apparent failure of Allah to assure their victory. Ledeen was born in Los Angeles, California . Ledeen is an accomplished contract bridge player. He has won one American Contract Bridge League national-level tournament , the 2009 Senior Swiss Teams , on a team-of-four with Karen Allison, Lea Dupont and Benito Garozzo . He has also partnered Jimmy Cayne , who oversaw the collapse of Bear Stearns firm in 2007 and 2008. Consulted by

11280-435: The calumnies and injuries whenever its content is not correctly attributed to the corresponding source. Exceptions are expressions referring to subjects of public interest or that are not assertive (see Article 113). When calumny or injury are committed through the press, a possible extra penalty is the publication of the judicial decision at the expenses of the guilty (Article 114). He who passes to someone else information about

11421-412: The case told that the jury believed that "where a writing ... inveighs against mankind in general, or against a particular order of men, as for instance, men of the gown, this is no libel, but it must descend to particulars and individuals to make it libel." This jury believed that only individuals who believed they were specifically defamed had a claim to a libel case. Since the jury was unable to identify

11562-606: The country by elevating the fault element for public officials to actual malice – that is, public figures could win a libel suit only if they could demonstrate the publisher's "knowledge that the information was false" or that the information was published "with reckless disregard of whether it was false or not". Later the Supreme Court held that statements that are so ridiculous to be clearly not true are protected from libel claims, as are statements of opinion relating to matters of public concern that do not contain

11703-608: The court decision in Rome in March 1986." He recalled the Pope's comments dismissing those allegations during his May 2002 visit to Bulgaria. In an interview published in La Repubblica in November 2006, former KGB agent Yevgeny Limarev told how the working group of the commission purpose was to find connections between Italian political left exponents and KGB or Russia's Federal Security Service , presumably for political purpose. Asked about targeted persons, he said: "Without

11844-539: The crime, this report clearly shows a ruling based on group libel. Since laws restricting libel were accepted at this time because of its tendency to lead to a breach of peace, group libel laws were justified because they showed potential for an equal or perhaps greater risk of violence. For this reason, group libel cases are criminal even though most libel cases are civil torts. In a variety of Common Law jurisdictions, criminal laws prohibiting protests at funerals, sedition , false statements in connection with elections, and

11985-471: The criminal law should only be countenanced in the most serious of cases and imprisonment is never an appropriate penalty. It is impermissible for a State party to indict a person for criminal defamation but then not to proceed to trial expeditiously – such a practice has a chilling effect that may unduly restrict the exercise of freedom of expression of the person concerned and others. While each legal tradition approaches defamation differently, it

12126-538: The defences of absolute and qualified privilege, fair comment, and justification. While statutory law in the United Kingdom provides that, if the defendant is only successful in proving the truth of some of the several charges against him, the defence of justification might still be available if the charges not proved do not materially injure the reputation, there is no corresponding provision in India, though it

12267-478: The deputies Ferdinando Adornato , Gabriele Albonetti, Maurizio Bertucci, Valter Bielli, Francesco Carboni , Fabrizio Cicchitto , Giuseppe Cossiga , Oliviero Diliberto , Lino Duilio, Giuseppe Fallica, Vincenzo Fragalà, Pierfrancesco Emilio Romano Gamba, Francesco Giordano, Giuseppe Lezza, Giuseppe Molinari , Erminio Angelo Quartiani, Enzo Raisi, and Giacomo Stucchi. Allegations of KGB ties, which were denied and ruled defamatory in nature in court, included Prodi as

12408-473: The dissemination of which was regarded as particularly dangerous, and visited with very severe punishment, whether the matters contained in them were true or false. The Praetorian Edict, codified circa AD 130, declared that an action could be brought up for shouting at someone contrary to good morals: " qui, adversus bonos mores convicium cui fecisse cuiusve opera factum esse dicitur, quo adversus bonos mores convicium fieret, in eum iudicium dabo. " In this case,

12549-421: The doctrine in common law jurisdictions that only a false statement of fact (as opposed to opinion) can be defamatory. This doctrine gives rise to two separate but related defences: opinion and truth. Statements of opinion cannot be regarded as defamatory as they are inherently non-falsifiable. Where a statement has been shown to be one of fact rather than opinion, the most common defence in common law jurisdictions

12690-520: The draft of the report, without providing evidence to back his claim, that "leaders of the former Soviet Union were behind the assassination attempt", alleging that "the leadership of the Soviet Union took the initiative to eliminate Pope John Paul" because of his support for Solidarity , the Polish trade-union, relaying "this decision to the military secret services" and not the KGB. According to Frank Brodhead,

12831-543: The exact people who were being defamed, there was no cause to identify the statements were a libel. Another early English group libel which has been frequently cited is King v. Osborne (1732). In this case, the defendant was on trial "for printing a libel reflecting upon the Portuguese Jews". The printing in question claimed that Jews who had arrived in London from Portugal burned a Jewish woman to death when she had

12972-430: The first few decades of the twenty first century, the phenomenon of strategic lawsuits against public participation has gained prominence in many common law jurisdictions outside Singapore as activists, journalists, and critics of corporations, political leaders, and public figures are increasingly targeted with vexatious defamation litigation. As a result, tort reform measures have been enacted in various jurisdictions;

13113-402: The following remedies in an action for defamation: compensatory damages; an injunction to stop further publication; a correction or a retraction; and in certain cases, punitive damages. Section 28 of the Act allows for punitive damages only when a there is a flagrant disregard of the rights of the person defamed. As the law assumes that an individual suffers loss if a statement is defamatory, there

13254-598: The foreign military intelligence agency of the former Soviet Union. Bruguière's information supporting the "Bulgarian connection" in the attempted assassination allegedly sprang from the prosecution of Ilich Ramirez Sanchez , alias Carlos the Jackal, held in France since his capture in Sudan in 1994. Both Russia and Bulgaria condemned the report. Foreign ministry spokesman Dimiter Tzantchev said: "For Bulgaria, this case closed with

13395-651: The forged Italian documents that, according to the Left's narrative, were the basis for President Bush's "lie" in the 2003 State of the Union Address that Saddam Hussein had obtained yellowcake uranium (for nuclear-weapons construction) in Africa." During the 1990s, Ledeen was active in supporting the ousting of Saddam Hussein from Iraq. He was known as one of The Vulcans who also included John Bolton , Douglas Feith , Richard Perle , Paul Wolfowitz , Donald Rumsfeld , and David Wurmser who signed an "An Open Letter to

13536-533: The freedom of expression provisions of the European Convention on Human Rights. One notable case was Lingens v. Austria (1986). According to the Criminal Code of Albania , defamation is a crime. Slandering in the knowledge of falsity is subject to fines of from 40 000 ALL (c. $ 350) to one million ALL (c. $ 8350 ). If the slandering occurs in public or damages multiple people, the fine

13677-570: The implied constitutional limitation on governmental powers to limit speech of a political nature established in Lange v Australian Broadcasting Corporation (1997). In 2006, uniform defamation laws came into effect across Australia. In addition to fixing the problematic inconsistencies in law between individual States and Territories, the laws made a number of changes to the common law position, including: Michael Ledeen Michael Arthur Ledeen ( / l ə ˈ d iː n / ; born August 1, 1941)

13818-498: The infringement of a personality right, either "corpus", "dignitas", or "fama". Dignitas is a generic term meaning 'worthiness, dignity, self-respect', and comprises related concerns like mental tranquillity and privacy. Because it is such a wide concept, its infringement must be serious. Not every insult is humiliating; one must prove contumelia . This includes insult ( iniuria in the narrow sense), adultery, loss of consortium, alienation of affection, breach of promise (but only in

13959-474: The like, then it is slander. In contrast, libel encompasses defamation by written or printed words, pictures, or in any form other than spoken words or gestures. The law of libel originated in the 17th century in England. With the growth of publication came the growth of libel and development of the tort of libel. The highest award in an American defamation case, at US$ 222.7 million was rendered in 1997 against Dow Jones in favour of MMAR Group Inc; however,

14100-560: The military invasion of Iraq before it took place and I advocated—as I still do—support for political revolution in Iran as the logical and necessary first step in the war against the terror masters." Ledeen is a long-time foe of the Islamic regime of Iran. He believed that invading the country and regime change in Iran should have been the first priority in the " war on terror " in 2003 rather than Iraq. He believes that "everything traces back to Tehran" and that Iran manipulates both sides of

14241-547: The new conclusions brought by Guzzanti were based on the same information provided in the early 1980s by Michael Ledeen , an American neoconservative author tied to the SISMI and Ağca himself, which he said is "bogus at best and at worst deliberately misleading". The "Bulgarian connection" thesis was debunked by Francesco Pazienza , a member of Propaganda Due , cited in a 1987 article in The Nation , as well as by media analyst Edward S. Herman in 1986: The Rise and Fall of

14382-514: The offence was constituted by the unnecessary act of shouting. According to Ulpian , not all shouting was actionable. Drawing on the argument of Labeo , he asserted that the offence consisted in shouting contrary to the morals of the city (" adversus bonos mores huius civitatis ") something apt to bring in disrepute or contempt (" quae... ad infamiam vel invidiam alicuius spectaret ") the person exposed thereto. Any act apt to bring another person into disrepute gave rise to an actio injurarum . In such

14523-403: The offense lay in the content of the imputation, not in the manner of its publication. The truth was therefore a sufficient defense, for no man had a right to demand legal protection for a false reputation. In Anglo-Saxon England , whose legal tradition is the predecessor of contemporary common law jurisdictions, slander was punished by cutting out the tongue. Historically, while defamation of

14664-433: The person defamed. Some common law jurisdictions distinguish between spoken defamation, called slander , and defamation in other media such as printed words or images, called libel . The fundamental distinction between libel and slander lies solely in the form in which the defamatory matter is published. If the offending material is published in some fleeting form, such as spoken words or sounds, sign language, gestures or

14805-448: The private law is derived from French civil law). In common law provinces and territories, defamation covers any communication that tends to lower the esteem of the subject in the minds of ordinary members of the public. Probably true statements are not excluded, nor are political opinions. Intent is always presumed, and it is not necessary to prove that the defendant intended to defame. In Hill v. Church of Scientology of Toronto (1995),

14946-493: The regime. In July 2016 Ledeen co-authored with Lt. General Michael T. Flynn , at the time Donald Trump 's national-security adviser, The Field of Fight : How We Can Win the Global War Against Radical Islam and Its Allies . Flynn and Ledeen constructed a narrative in which the world is at war with a "great evil" and Iran is the central player on the enemy side. Ledeen also believed that Iran

15087-505: The reputation or rights of others. Additionally, restrictions of freedom of expression and other rights guaranteed by international human rights laws (including the European Convention on Human Rights (ECHR)) and by the constitutions of a variety of countries are subject to some variation of the three-part test recognised by the United Nations Human Rights Committee which requires that limitations be: 1) "provided by law that

15228-458: The right to a legal remedy for defamation, this right must be balanced with the equally protected right to freedom of opinion and expression. In general, ensuring that domestic defamation law adequately balances individuals' right to protect their reputation with freedom of expression and of the press entails: In most of Europe, article 10 of the European Convention on Human Rights permits restrictions on freedom of speech when necessary to protect

15369-486: The shooting and on information brought by the French anti-terrorist judge Jean-Louis Bruguière , a controversial figure whose last feat was to indict Rwandese president Paul Kagame , on the grounds that he had deliberately provoked the 1994 Rwandan genocide against his own ethnic group in order to take the power. According to Le Figaro , Bruguière, who was in close contacts with both Moscow and Washington, D.C., including

15510-490: The state rather than defamation suits; thus, for most of American history, the Supreme Court did not interpret the First Amendment as applying to libel cases involving media defendants. This left libel laws, based upon the traditional common law of defamation inherited from the English legal system, mixed across the states. The 1964 case New York Times Co. v. Sullivan dramatically altered the nature of libel law in

15651-533: The statement is true or is a statement of fact, it does not actually harm someone's reputation. It is also necessary in these cases to show that there is a well-founded public interest in the specific information being widely known, and this may be the case even for public figures . Public interest is generally not "what the public is interested in", but rather "what is in the interest of the public". Other defences recognised in one or more common law jurisdictions include: Media liability or defamation insurance

15792-451: The statement was defamatory. In an action for defamation per se , the law recognises that certain false statements are so damaging that they create a presumption of injury to the plaintiff's reputation, allowing a defamation case to proceed to verdict with no actual proof of damages. Although laws vary by state, and not all jurisdictions recognise defamation per se , there are four general categories of false statement that typically support

15933-547: The statement would be considered defamatory per se if false, if the defendant establishes that it is in fact true, an action for defamation per se cannot survive. The conception of what type of allegation may support an action for defamation per se can evolve with public policy. For example, in May 2012 an appeals court in New York, citing changes in public policy with regard to homosexuality , ruled that describing someone as gay

16074-399: The statement, it was not brought to their attention, and they were not negligent. Common law jurisdictions vary as to whether they permit corporate plaintiffs in defamation actions. Under contemporary Australian law, private corporations are denied the right to sue for defamation, with an exception for small businesses (corporations with less than 10 employees and no subsidiaries); this rule

16215-417: The subject matter of the criticism should be recognized as a defence. Care should be taken by States parties to avoid excessively punitive measures and penalties. Where relevant, States parties should place reasonable limits on the requirement for a defendant to reimburse the expenses of the successful party. States parties should consider the decriminalization of defamation and, in any case, the application of

16356-459: The truth of the remaining charges". Similarly, the American doctrine of substantial truth provides that a statement is not defamatory if it has "slight inaccuracies of expression" but is otherwise true. Since a statement can only be defamatory if it harms another person's reputation, another defence tied to the ability of a statement to be defamatory is to demonstrate that, regardless of whether

16497-413: The truthfulness of the statement; where the plaintiff is a celebrity or public official, they must additionally prove that the statement was made with actual malice (i.e. the intent to do harm or with reckless disregard for the truth). A series of court rulings led by New York Times Co. v. Sullivan , 376 U.S. 254 (1964) established that for a public official (or other legitimate public figure) to win

16638-543: The use of profanity in public, are also often used in contexts similar to criminal libel actions. The boundaries of a court's power to hold individuals in "contempt of court" for what amounts to alleged defamatory statements about judges or the court process by attorneys or other people involved in court cases is also not well established in many common law countries. While defamation torts are less controversial as they ostensibly involve plaintiffs seeking to protect their right to dignity and their reputation, criminal defamation

16779-607: The verdict was dismissed in 1999 amid allegations that MMAR failed to disclose audiotapes made by its employees. In common law jurisdictions, civil lawsuits alleging defamation have frequently been used by both private businesses and governments to suppress and censor criticism. A notable example of such lawsuits being used to suppress political criticism of a government is the use of defamation claims by politicians in Singapore's ruling People's Action Party to harass and suppress opposition leaders such as J. B. Jeyaretnam . Over

16920-408: The war against terror. Ledeen's statements prior to the start of the Iraq war such as "desperately needed and long overdue war against Saddam Hussein" and "dire need to invade Iraq" caused Glenn Greenwald to label his later statement that he "opposed the military invasion of Iraq before it took place" to be an "outright lie". However, Ledeen maintains these statements are consistent since: "I opposed

17061-582: The whole region into a caldron and destroy the War on Terror." One can only hope that we turn the region into a cauldron, and faster, please. If ever there were a region that richly deserved being cauldronized, it is the Middle East today. If we wage the war effectively, we will bring down the terror regimes in Iraq, Iran, and Syria, and either bring down the Saudi monarchy or force it to abandon its global assembly line to indoctrinate young terrorists. That's our mission in

17202-452: The world they are filed, since a compainant can look for a more favorable jurisdiction to file their claim. Investigative journalism usually requires higher insurance premiums, with some plans not covering investigative work altogether. Many common law jurisdictions recognise that some categories of statements are considered to be defamatory per se , such that people making a defamation claim for these statements do not need to prove that

17343-559: The wrongful conduct of the defender. For such reparation to be offered, however, the non-patrimonial interest must be deliberately affronted: negligent interference with a non-patrimonial interest will not be sufficient to generate liability. An actio iniuriarum requires that the conduct of the defender be 'contumelious' —that is, it must show such hubristic disregard of the pursuer's recognised personality interest that an intention to affront ( animus iniuriandi ) might be imputed. In addition to tort law, many jurisdictions treat defamation as

17484-400: Was 'excessively repressive and intolerant.' While it would not do to come right out and deny the savagery of the Shah's legendary SAVAK secret police, Ledeen informs us that, under the monarch's beneficent rule, 'Iran had become too modern, too tolerant—especially of women and of other religious faiths—and too self-indulgent. The shah had Westernized Iran'—except, perhaps, in his prisons, where

17625-411: Was aimed at giving sufficient scope for the discussion of a man's character, while it protected him from needless insult and pain. The remedy for verbal defamation was long confined to a civil action for a monetary penalty, which was estimated according to the significance of the case, and which, although punitive in its character, doubtless included practically the element of compensation. But a new remedy

17766-502: Was approached by Peter W. Smith , an aid close to Gingrich and who was also working with Michael Flynn who is a confidant of Barbara Ledeen's husband, who Tate said Smith was obtaining Clinton's emails independently of Barbara Ledeen's efforts which Grassley had told her to stop. To support Project Veritas in 2017 and 2018 and while she was a staff member on the Chuck Grassley led Senate Judiciary Committee, Barbara Ledeen

17907-587: Was composed by the following twenty senators and twenty deputies: the Senate president Paolo Guzzanti ; the vice-presidents Andrea Papini and Giovanni Mongiello; the secretaries Giampaolo Zancan and Salvatore Meleleo; the senators Giulio Andreotti , Guglielmo Castagnetti, Mario Cavallaro, Amedeo Ciccanti, Cinzia Dato, Luciano Falcier, Costantino Garraffa, Mario Gasbarri, Lauro Salvatore, Loris Giuseppe Maconi, Lucio Malan , Luigi Marino, Franco Mugnai, Gianni Nieddu, Lodovico Pace, Piergiorgio Stiffoni, Roberto Ulivi, Lodovico Pace, Piergiorgio Stiffoni, and Roberto Ulivi; and

18048-481: Was described as an empty shell according to the International Herald Tribune . Marino, who was living in the United States, acknowledged in an interview an association with former and active CIA officers, including Robert Seldon Lady , the former CIA station chief in Milan. The Mitrokhin Commission was shut down in March 2006 without any concrete result provided, and not one political figure

18189-432: Was exposed by the allegations, despite months of press speculation alimented by Berlusconi family newspaper Il Giornale . Following the 2006 general election and the nomination of Prodi as head of the new government, a parliamentary commission was instituted to investigate about this controversial Mitrokhin Commission. Libel Defamation is a communication that injures a third party's reputation and causes

18330-631: Was false, the court ruled in its favour, saying that libel of a public official requires proof of actual malice , which was defined as a "knowing or reckless disregard for the truth". Many jurisdictions within the Commonwealth (e.g. Singapore, Ontario, and the United Kingdom ) have enacted legislation to: Libel law in England and Wales was overhauled even further by the Defamation Act 2013 . Defamation in Indian tort law largely resembles that of England and Wales . Indian courts have endorsed

18471-599: Was introduced by the state of New South Wales in 2003, and then adopted nationwide in 2006. By contrast, Canadian law grants private corporations substantially the same right to sue for defamation as individuals possess. Since 2013, English law charts a middle course, allowing private corporations to sue for defamation, but requiring them to prove that the defamation caused both serious harm and serious financial loss, which individual plaintiffs are not required to demonstrate. Defamation in jurisdictions applying Roman Dutch law (i.e. most of Southern Africa, Indonesia, Suriname, and

18612-433: Was introduced with the extension of the criminal law, under which many kinds of defamation were punished with great severity. At the same time increased importance attached to the publication of defamatory books and writings, the libri or libelli famosi , from which is derived the modern use of the word libel ; and under the later emperors the latter term came to be specially applied to anonymous accusations or pasquils ,

18753-409: Was invented by Ağca with the hope of winning his release from prison. He was aided and abetted in this scheme by right-wing conspiracy theorists in the United States and William J. Casey 's Central Intelligence Agency (CIA), which became a victim of its own disinformation campaign." Guzzanti said that the commission had decided to re-open the report's chapter on the assassination attempt in 2005, after

18894-457: Was not an issue of defamation. Another example of libel is the case of New York Times Co. v. Sullivan (1964). The Supreme Court of the United States overruled a state court in Alabama that had found The New York Times guilty of libel for printing an advertisement that criticised Alabama officials for mistreating student civil rights activists. Even though some of what The Times printed

19035-570: Was obtaining yellowcake from Niger. According to a September 2004 article by Joshua Micah Marshall , Laura Rozen, and Paul Glastris in Washington Monthly : "The first meeting occurred in Rome in December, 2001. It included Franklin, Rhode, and another American, the neoconservative writer and operative Michael Ledeen, who organized the meeting. (According to UPI, Ledeen was then working for Undersecretary of Defense Douglas Feith as

19176-503: Was paid $ 120,000 for his work on Billygate and other projects. Pazienza and Ledeen were very active in disinformation efforts. At SISMI, Pazienza stated, Ledeen warranted a coded identification: Z-3. Pazienza was later tried and convicted in absentia for using "extortion and fraud to obtain embarrassing facts about Billy Carter". Ledeen worked for the Italian military intelligence agency SISMI in 1980, providing "risk assessment" and consulting on extradition matters between Italy and

19317-447: Was tasked to help discredit H.R. McMaster because he had stated that President Trump had the intelligence of a "kindergartner" and was an "idiot." She posted numerous comments on Facebook supporting Project Veritas including "We owe a lot to Erik Prince " because of his efforts to support Project Veritas and many disparaging posts about McMaster. Her involvement in the campaign to discredit McMaster led to Barbara Ledeen being named as

19458-597: Was the commission's consultant and became involved in the events surrounding the death of former KGB agent Alexander Litvinenko in Great Britain on 23 November 2006. In the interceptions, Guzzanti declared that the Mitrokhin Commission's unstated goal was to depict Prodi and Alfonso Pecoraro Scanio , leader of the Federation of the Greens and then minister of environment in second Prodi government , as "agents of

19599-468: Was the head of Iranian Prime Minister Mir Hussein Mousavi 's European intelligence and Ledeen was aware of this. In one interview after the scandal broke, Ledeen stated that he initially had "profound reservations" about Ghorbanifar, but that he proved himself to be reliable by opening a channel to Iranian leaders. In another report in which he was described as "perhaps the only person on the US side of

19740-576: Was then an obscure figure, described as by the International Herald Tribune as "a slew of media reports about him and his career here — which included trying to prove that some top Italian center-left politicians, including Prime Minister Romano Prodi, are Russian spies — have invariably included unflattering adjectives. They include: 'incurable liar', 'wannabe 007', 'braggart', 'bumbler' and 'swindler' — not to mention 'fool' and 'mental case'." His repeated offers to collaborate with

19881-488: Was very close to Italian politician Antonio Martino . Ledeen was also noted to have done work for Italian intelligence agency SISMI , having received over $ 100,000 in payment to offshore bank accounts for services including but not limited to training Italian intelligence operatives. Ledeen denies these allegations but admits he did do work for SISMI and was paid for it. Ledeen holds a Ph.D. in History and Philosophy from

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