On March 4, 1995, Deputy Attorney General Jamie Gorelick wrote a classified memo to FBI Director Louis Freeh and others, which reinforced ‘the wall’ between communication of criminal and intelligence investigations. ” ‘…we believe that it is prudent to establish a set of instructions that will clearly separate the counterintelligence investigation from the more limited, but continued, criminal investigations. These procedures, which go beyond what is legally required, will prevent any risk of creating an unwarranted appearance that FISA [Foreign Intelligence Surveillance Act] is being used to avoid procedural safeguards which would apply in a criminal investigation.’ ”

 – John Ashcroft, Never Again, Page 238