Regarding Chief of the Office of Legal Counsel Dan Levin’s December 30, 2004, memo, which reformed interrogation practices, White House Legal Counsel Alberto Gonzales “made clear to Levin that unless he included language in his new legal memo declaring that nothing the Bush Administration had done in earlier interrogations was illegal, the Justice Department would not accept his opinion. In essence, Levin, the top legal adviser to the executive branch, was being virtually extorted for a written legal pardon. Levin was worried that unless he gave Gonzales what he wanted, the Bush Administration would scrap his memo, abandoning the whole effort to reform interrogation practices.”
– Jane Mayer, The Dark Side, Page 307