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7/24/2019 Woodell Statement of Facts
1/8
FILD
IN
OPEN
COURT
IN THE
U N IT ED S T TE S
D IS TR IC T C O UR T F O R T HE
OCT 2 R 2 5
E S TE R N D IS TR IC T O F
VIRGINI
Newport News Division
U N IT E D S T T E S OF MERIC
COURT
N W^CRT news va
Criminal No. 4:15mj
GLENN A. WOODELL
Defendant
S T TEM ENT
O F F C TS
The parties stipulate that the allegations in the Criminal Information and the following
facts are true and correct, and that had the matter gone to trial the United States would have
proven the following facts beyond a reasonable doubt:
1. Defendant, GLENN A. WOODELL, was an employee
of
the National Aeronautics
and Space Administration NASA ) from February 7, 1983 to January 2, 2015, and was
employed as an Engineering Technician at the N S Langley Research Center LaRC ) located
in Hampton, Virginia, during all times pertinent to this Information. While working at LaRC
during the 2010 to 2013 time period, WOODELL was assigned to work in the Electromagnetics
and Sensor Branch and, while there, worked with N S Research Physicist Daniel Jobson and
NASA Research Scientist Dr. Zia Rahmanon a NASA research and development project that was
known as Smart Visual Awareness SVA ) which involved the subject
of
visual information
processing technology for a NASA aviation safety program. WOODELL, Jobson and Rahman
together constituted the Visual Information Processing Lab the VIP Lab ). NASA is an
agency
of
the United States government responsible for managing the research and development
I
\ ^
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7/24/2019 Woodell Statement of Facts
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oftheU S civilian space program and
space science technology
and
for federal management
and
development of aeronautic and aerospace research.
2. Bo Jiang was a citizenof the People s Republic of China (the PRC ). Fromon or
about January
2011
through January
2013
Jiang was employed as a Research Scientist by the
National Institute of Aerospace ( NIA ), a non-profit research and graduate education institute
formed by a consortium of research universities to support the mission of NASA. For four
years prior to that, Jiang was a graduate student of Dr. Zia Rahman while at Old Dominion
University. While employed by NIA, Jiang was assigned to work under NIA Activity 2828 -
Pattern Recognition Research ( Activity 2828 ), which was a project designed to provide
research support to the VIP Lab at the NASA LaRC for the specific and limited task on
enhancing the VIP Lab s Multi-Scale Retinex with Color Restoration ( MSRCR ) so that it
would be possible to achieve the performance requirements needed for real-time applications.
3. During the time Jiang worked at the NASA LaRC VIP Lab under Activity 2828,
Jiang was under the supervision and direction of WOODELL and Daniel Jobson. While
WOODELL had responsibility for a range
of
NASA work assignments, from 2010 through the
end
of
2012 the majority
of
WOODELL s work was devoted to the enhancement
of
the MSRCR
for real-time application. Dr. Rahman had been working with WOODELL and Jobson on the
Atmospheric Environment Safety Technologies project (the
AEST
Project ) prior to Dr.
Rahman s death
in December
2010.
4. From in or about January 2011 through June 18, 2012, Jobson was assigned to serve
and assumed official responsibility as Jiang s NASA sponsor under a written NASA
Security/Technology Transfer Control Plan ( STTCP ). From June 18, 2012 until January
2013, WOODELL took over the role as
Jiang s NASA
sponsor pursuant to a written STTCP.
0/ ^
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7/24/2019 Woodell Statement of Facts
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This
STT
wasa
WTitten
security plan for the purpose of implementing and enforcing existing
NASA policies and procedures to prevent any unauthorized transfer of export controlled
information to Jiang in connectionwith his work at NASA, The STTCP requiredWOODELL
to ensure that Jiang s access to information was limited to information that was unclassified,
non-sensitive, non-export controlled that was directly applicable to the tasks assigned to Jiang.
Further, WOODELL stated that he had read and fully understood the STTCP and acknowledged
that Jiang was not authorized access to any other technical data, hardware or software, or IT
systems not otherwise specified in the STTP.
5. For the entire time WOODELL was employed as a NASA employee, he was
subject to and responsible for all NASA administrative rules, regulations, orders, policy
directives and NASA Procedural Requirements, including all those applicable to the security
of
NASA information technology and information security within the scope
of
his duties.
6. From in or about January 2011 through June 18, 2012, Jobson was Jiang s sponsor
and directed his NASA work with the VIP Lab under Activity 2828. From June 18, 2012 until
January 2013, WOODELL was Jiang s sponsor and directed his work with the VIP Lab under
Activity 2828. WOODELL and Jobson knew that during 2010 and 2011 there was in operation
an official NASA computer which had been used by then deceased NASA Research Scientist,
Dr. Zia
Rahman and which was
located
Dr.
Rahman s office
at the LaRC (the
Rahman NASA
Computer ). Prior to his death. Dr. Rahman had been working with WOODELL and Jobson on
the
AEST
Project until his death in
December
2010.
WOODELL
and Jobson
believed that the
Rahman NASA Computer contained digital and data information which related to Dr.
Rahman s
prior work, including work done for NASA. Both WOODELL and Jobson knew that the
Rahman
NASA
Computer had been connected to the central
NASA
Information Technology
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7/24/2019 Woodell Statement of Facts
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System
commonly
referred
to as the Orange Network )
prior
to
Dr.
Rahman s
death
in
D e c e m b e r 2 0 1 0
7. In early 2011, WOODELL and Jobson assisted Jiang in getting direct access to the
data stored in the Rahman NASA Computer because neither WOODELL nor Jobson had a
working knowledge or skills necessary to read or understand the programming language and
operating system of the Rahman NASA Computer. Subsequently, for this same reason,
WOODELL and Jobson provided Jiang with a copy
of
a digital image copy
of
the Rahman NASA
Computer hard drive because they believed that Jiang would be able read and possibly use the
programming code used by Dr. Rahman in support
of
the AEST Project. WOODELL and Jobson
asked Jiang to try to read and interpret the files stored in the Rahman NASA Computer to assist
with the ongoing AEST work, including any ofDr.
Rahman s
work that may have been relevant to
Activity 2828. WOODELL did not have any independent knowledge of any of the contents of the
Rahman NASA Computer given that he had never had any prior access to the computer. Thus, in
spring 2011, WOODELL and Jobson, through Branch management, asked another NASA
employee, CW 1, to archive and copy the Rahman NASA Computer in order to support of their
ongoing AEST Project. CW 1 was able to archive the entirety
of
the data on the Rahman NASA
Computer hard drive, but was not able to interpret any
of
the file contents. For these reasons,
WOODELL and Jobson allowed Jiang access to the archive copy
of
the Rahman NASA Computer
h a r d
dri ve
8. By 2011, the Rahman
NASA
Computer had been disconnected from the
NASA
Orange Network. Jobson provided the NASA employee with Dr. Rahman s prior User
Identifier information and password to facilitate access to the Rahman NASA Computer, which
information had been provided by a NASA central information technology computer system
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administrator. At the direction of WOODELL, Jobson and branch management, CW 1
transferred the information from the Rahman NASA Computer to the new, unused external hard
drive. WOODELL knew
of
the actions to (i) make a full image copy of the Rahman NASA
Computer; (ii) directly copy and image the Rahman NASA Computer without any access
restriction and without any provision for information review; and (iii) provide unrestricted access
of
the information contained in the Rahman NASA Computer to Jiang. At no time did
WOODELL ever act to secure, protect or fully restrict Jiang s access to the information
contained on the Rahman NASA Computer and thereby failed to protect NASA information
from unauthorized disclosure by providing a foreign national with complete and unrestricted
access to a
NASA
Computer and the information
contained
therein.
9. After NASA and NIA terminated Jiang s work on Project 2828 on or around
December 2012, Jiang made arrangements to leave the United States and return to his home in
the PRC. On March 16, 2013, Jiang attempted to travel from the United States to the PRC in
possession
of
a number
of
electronic devices. Specifically, he was attempting to take a Seagate
External Hard Drive, serial n umber 2 GH 2Y SJ R that contained the NASA unauthorized,
unrestricted access information from the Rahman NASA Computer. Prior to departure for the
United States, Jiang was interviewed by U.S. law enforcement officers, who conducted a border
search
of
his luggage in whieh the Seagate External Hard Drive, serial number 2GH2YSJR,
containing the NASA unauthorized, unrestricted access information of the Rahman NASA
Computer was
found
an d
detained.
10. NASA Policy Directive (the NPD ) 2810.ID, NASA Information Security
Policy, Section 1 states that it is NASA policy to (b) Protect information from unauthorized
Q
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disclosure.. .while the information is...stored. Section 2(a) states that NASA employees shall
abide by the requirements of this directive when they perform Agency missions.
11. NASA Policy Procedural Requirements 1600.4, Sections 4.1.1, 4.2.1 and 4.7.1,
Identity and Credential Management sets forth a range of mandatory security procedure
requirements for all NASA employees who sponsor a foreign national, including identifying
foreign nationals and controlling their access to resources such as NASA Information
Technology systems thorough user rights and restrictions. Specifically, Section 4.7.1 states that
any NASA employee serving as the sponsor for a foreign national will ensure that the foreign
national s access requirements as documented in the TTCP are adhered to throughout the foreign
national s [NASA] on-site assignment, which includes adhering to all required restrictions to
NASA
physical and Information Technology resources.
12.
NASA
Procedural Requirements (the NPR ) 2810.1A, Security
of
Information
Technology sets forth a range of mandatory security procedure requirements for all NASA
employees who use NASA Information Technology (referred to as a NASA User ). Section
1.2.3.13 states that the NASA User shall comply with all policy and procedures as required by
this NPR. Section 3.6.6.4 states that [t]he NASA User shall mitigate the risks of data loss by
securing and protecting media under their control, and the information contained on/within those
devices, through use
of
encryption, access restriction, and/or sanitization.
13. NASA Policy Directive 2810.ID, NASA Policy Procedural Requirement 1600.4,
and
NASA
Procedural Requirements 2810.1 A each constitute an Order
of
the
NASA
Administrator that was in existence at all times relevant to WOODELL s employment at NASA.
NASA Policy Directive 2810.ID,
NASA
Policy Procedural Requirements 1600.4 and
NASA
Procedural Requirements 2810.1A was promulgated for the protection of NASA Information
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Technology and all information contained therein from any unauthorized access disclosure or
use by all NASA employees and users
of
NASA Information Technology
14 During
2
and 2012
GLENN
A WOODELL had knowledge of NASA policy
and procedures that were in place and in force to prevent or restrict access of foreign nationals to
NASA information contained on the NASA Information Technology system By providing
Jiang with or causing Jiang to obtain access to information from the Rahman NASA Computer
and thereafter continuing to knowingly allow Jiang to exercise access thereto without taking any
action to protect that information from unauthorized disclosure or mitigating the risk of data loss
by securing and protecting this information while under his control through the use
of
encryption access restrictions and/or sanitation WOODELL acted in violation
of
NPD 2810 ID
NPR 1 6 4 a nd NPR
281 1
A
15 These events occurred in the Eastern District of Virginia
Respectfully submitted
ana
J
oente
United St^es Attorney
By:
Lisa R McKeel
Assistant United States Attorney
By:
A
Will iam
Mackie
Special Assistant United States Attorney
Trial Attorney
Counterespionage Section National Security Division
United States Department of Justice
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After consulting with myattorney andpursuant to the PleaAgreement enteredinto this
day between the defendant GLENN A
WOO ELL
and the United States I hereby stipulate
that the above Statement
of
Facts is true and accurate and that had the matter proceeded to trial
the United States would have proved the same beyond a reasonable doubt
G L E N N A W O O D E L L
I am GLENN A
WOODELL s
attorney I have carefully reviewed the above Statement
of Facts with him To my knowledge his decision to stipulate to these facts is an informed and
voluntary one
F e r n a n d o
G r o e n e
Attorney for GLENNT A WOODELL
Case 4:15-mj-00224-RJK Document 8 Filed 10/26/15 Page 8 of 8 PageID# 24
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