Roger Morris Gallery

MISLEADING THE AMERICAN PEOPLE AND MEMBERS OF CONGRESS TO BELIEVE IRAQ
POSSESSED WEAPONS OF MASS DESTRUCTION, SO AS TO MANUFACTURE A FALSE
CASE FOR WAR
In his conduct while President of the United States, George W. Bush, in violation of his constitutional
oath to faithfully execute the office of President of the United States and, to the best of his ability,
preserve, protect, and defend the Constitution of the United States, and in violation of his constitutional
duty under Article II, Section 3 of the Constitution “to take care that the laws be faithfully executed”,
has both personally and acting through his agents and subordinates, together with the Vice President,
executed instead a calculated and wide-ranging strategy to deceive the citizens and Congress of the
United States into believing that the nation of Iraq possessed weapons of mass destruction in order to
justify the use of the United States Armed Forces against the nation of Iraq in a manner damaging to
our national security interests, thereby interfering with and obstructing Congress’s lawful functions of
overseeing foreign affairs and declaring war.
The means used to implement this deception were and continue to be personally making, or causing,
authorizing and allowing to be made through highly-placed subordinates, including the President’s
Chief of Staff, the White House Press Secretary and other White House spokespersons, the Secretaries
of State and Defense, the National Security Advisor, and their deputies and spokespersons, false and
fraudulent representations to the citizens of the United States and Congress regarding Iraq’s alleged
possession of biological, chemical and nuclear weapons that were half-true, literally true but
misleading, and/or made without a reasonable basis and with reckless indifference to their truth, as well
as omitting to state facts necessary to present an accurate picture of the truth as follows:
(A) Long before the March 19, 2003 invasion of Iraq, a wealth of intelligence informed the President
and those under his direction and control that Iraq’s stockpiles of chemical and biological weapons had
been destroyed well before 1998 and that there was little, if any, credible intelligence that showed
otherwise. As reported in the Washington Post in March of 2003, in 1995, Saddam Hussein’s son-inlaw
Hussein Kamel had informed U.S. and British intelligence officers that “all weapons—biological,
chemical, missile, nuclear were destroyed.” In September 2002, the Defense Intelligence Agency
issued a report that concluded: “A substantial amount of Iraq’s chemical warfare agents, precursors,
munitions and production equipment were destroyed between 1991 and 1998 as a result of Operation
Desert Storm and UNSCOM actions…[T]here is no reliable information on whether Iraq is producing
and stockpiling chemical weapons or whether Iraq has-or will-establish its chemical warfare agent
production facilities.” Notwithstanding the absence of evidence proving that such stockpiles existed
and in direct contradiction to substantial evidence that showed they did not exist, the President and his
subordinates and agents made numerous false representations claiming with certainty that Iraq
possessed chemical and biological weapons that it was developing to use to attack the United States, to
wit:
(1) “[T]he notion of a Saddam Hussein with his great oil wealth, with his inventory that he already has
of biological and chemical weapons . . . is, I think, a frightening proposition for anybody who thinks
about it.” Statement of Vice President Cheney on CBS’s Face the Nation, March 24, 2002.
(2) “In defiance of the United Nations, Iraq has stockpiled biological and chemical weapons, and is
rebuilding the facilities used to make more of those weapons.” Speech of President Bush, October 5,
2002.
(3) “All the world has now seen the footage of an Iraqi Mirage aircraft with a fuel tank modified to
spray biological agents over wide areas. Iraq has developed spray devices that could be used on
unmanned aerial vehicles with ranges far beyond what is permitted by the Security Council. A UAV
launched from a vessel off the American coast could reach hundreds of miles inland.” Statement by
President Bush from the White House, February 6, 2003.
(B) Despite overwhelming intelligence in the form of statements and reports filed by and on behalf of
the CIA, the State Department and the IAEA, among others, which indicated that the claim was untrue,
the President, and those under his direction and control, made numerous representations claiming and
implying through misleading language that Iraq was attempting to purchase uranium from Niger in
order to falsely buttress its argument that Iraq was reconstituting its nuclear weapons program,
including:
(1) “”The regime has the scientists and facilities to build nuclear weapons, and is seeking the materials
needed to do so.” Statement of President Bush from White House, October 2, 2002.
(2) “The [Iraqi] report also failed to deal with issues which have arisen since 1998, including: . .
attempts to acquire uranium and the means to enrich it.” Letter from President Bush to Vice President
Cheney and the Senate, January 20, 2003.
(3) “The British Government has learned that Saddam Hussein recently sought significant quantities of
uranium from Africa .” President Bush Delivers State of the Union Address, January 28, 2003.
(C) Despite overwhelming evidence in the form of reports by nuclear weapons experts from the
Energy, the Defense and State Departments, as well from outside and international agencies which
assessed that aluminum tubes the Iraqis were purchasing were not suitable for nuclear centrifuge use
and were, on the contrary, identical to ones used in rockets already being manufactured by the Iraqis,
the President, and those under his direction and control, persisted in making numerous false and
fraudulent representations implying and stating explicitly that the Iraqis were purchasing the tubes for
use in a nuclear weapons program, to wit:
(1) “We do know that there have been shipments going . . . into Iraq . . . of aluminum tubes that really
are only suited to — high-quality aluminum tools [sic] that are only really suited for nuclear weapons
programs, centrifuge programs.” Statement of then National Security Advisor Condoleezza Rice on
CNN’s Late Edition with Wolf Blitzer, September 8, 2002.
(2) “Our intelligence sources tell us that he has attempted to purchase high-strength aluminum tubes
suitable for nuclear weapons production.” President Bush’s State of the Union Address, January 28,
2003.
(3) “[H]e has made repeated covert attempts to acquire high-specification aluminum tubes from 11
different countries, even after inspections resumed. …By now, just about everyone has heard of these
tubes and we all know that there are differences of opinion. There is controversy about what these tubes
are for. Most US experts think they are intended to serve as rotors in centrifuges used to enrich
uranium.” Speech of Former Secretary of State Colin Powell to the United Nations, February 5, 2003.
(D) The President, both personally and acting through those under his direction and control, suppressed
material information, selectively declassified information for the improper purposes of retaliating
against a whistleblower and presenting a misleading picture of the alleged threat from Iraq, facilitated
the exposure of the identity of a covert CIA operative and thereafter not only failed to investigate the
improper leaks of classified information from within his administration, but also failed to cooperate
with an investigation into possible federal violations resulting from this activity and, finally, entirely
undermined the prosecution by commuting the sentence of Lewis Libby citing false and insubstantial
grounds, all in an effort to prevent Congress and the citizens of the United States from discovering the
fraudulent nature of the President’s claimed justifications for the invasion of Iraq.
(E) The Senate Select Committee on Intelligence Report on Whether Public Statements Regarding Iraq
By U.S. Government Officials Were Substantiated By Intelligence Information, which was released on
June 5, 2008, concluded that:
(1) “Statements by the President and Vice President prior to the October 2002 National Intelligence
Estimate regarding Iraq’s chemical weapons production capability and activities did not reflect the
intelligence community’s uncertainties as to whether such production was ongoing.”
(2) “The Secretary of Defense’s statement that the Iraqi government operated underground WMD
facilities that were not vulnerable to conventional airstrikes because they were underground and deeply
buried was not substantiated by available intelligence information.”
(3) Chairman of the Senate Intelligence Committee Jay Rockefeller concluded: “In making the case for
war, the Administration repeatedly presented intelligence as fact when in reality it was unsubstantiated,
contradicted, or even non-existent. As a result, the American people were led to believe that the threat
from Iraq was much greater than actually existed.”
The President has subverted the national security interests of the United States by setting the stage for
the loss of more than 4000 United States service members and the injury to tens of thousands of US
soldiers; the loss of more than 1,000,000 innocent Iraqi citizens since the United States invasion; the
loss of approximately $500 billion in war costs which has increased our Federal debt with a long term
financial cost of between three and five trillion dollars; the loss of military readiness within the United
States Armed Services due to overextension, the lack of training and lack of equipment; the loss of
United States credibility in world affairs; and the decades of likely blowback created by the invasion of
Iraq.
In all of these actions and decisions, President George W. Bush has acted in a manner contrary to his
trust as President and Commander in Chief, and subversive of constitutional government, to the
prejudice of the cause of law and justice and to the manifest injury of the people of the United States.
Wherefore, President George W. Bush, by such conduct, is guilty of an impeachable offense warranting
removal from office.

MISLEADING THE AMERICAN PEOPLE AND MEMBERS OF CONGRESS TO BELIEVE IRAQ
POSED AN IMMINENT THREAT TO THE UNITED STATES
In his conduct while President of the United States, George W. Bush, in violation of his constitutional
oath to faithfully execute the office of President of the United States and, to the best of his ability,
preserve, protect, and defend the Constitution of the United States, and in violation of his constitutional
duty under Article II, Section 3 of the Constitution “to take care that the laws be faithfully executed”,
has both personally and acting through his agents and subordinates, together with the Vice President,
executed a calculated and wide-ranging strategy to deceive the citizens and Congress of the United
States into believing that the nation of Iraq posed an imminent threat to the United States in order to
justify the use of the United States Armed Forces against the nation of Iraq in a manner damaging to
our national security interests, thereby interfering with and obstructing Congress’s lawful functions of
overseeing foreign affairs and declaring war.
The means used to implement this deception were and continue to be, first, allowing, authorizing and
sanctioning the manipulation of intelligence analysis by those under his direction and control, including
the Vice President and the Vice President’s agents, and second, personally making, or causing,
authorizing and allowing to be made through highly-placed subordinates, including the President’s
Chief of Staff, the White House Press Secretary and other White House spokespersons, the Secretaries
of State and Defense, the National Security Advisor, and their deputies and spokespersons, false and
fraudulent representations to the citizens of the United States and Congress regarding an alleged urgent
threat posed by Iraq, statements that were half-true, literally true but misleading, and/or made without a
reasonable basis and with reckless indifference to their truth, as well as omitting to state facts necessary
to present an accurate picture of the truth as follows:
(A) Notwithstanding the complete absence of intelligence analysis to support a claim that Iraq posed
an imminent or urgent threat to the United States and the intelligence community’s assessment that Iraq
was in fact not likely to attack the United States unless it was itself attacked, President Bush, both
personally and through his agents and subordinates, made, allowed and caused to be made repeated
false representations to the citizens and Congress of the United States implying and explicitly stating
that such a dire threat existed, including the following:
(1) “States such as these [Iraq, Iran and North Korea] and their terrorist allies constitute an axis of evil,
arming to threaten the peace of the world. By seeking weapons of mass destruction, these regimes pose
a grave and growing danger. They could provide these arms to terrorists, giving them the means to
match their hatred. They could attack our allies or attempt to blackmail the United States. In any of
these cases, the price of indifference would be catastrophic.” President Bush’s State of the Union
Address, January 29, 2002.
(2) “Simply stated, there is no doubt that Saddam Hussein has weapons of mass destruction. He is
amassing them to use against our friends our enemies and against us.” Speech of Vice President
Cheney at VFW 103rd National Convention, August 26, 2002.
(3) “The history, the logic, and the facts lead to one conclusion: Saddam Hussein’s regime is a grave
and gathering danger. To suggest otherwise is to hope against the evidence. To assume this regime’s
good faith is to bet the lives of millions and the peace of the world in a reckless gamble. And this is a
risk we must not take.” Address of President Bush to the United Nations General Assembly, September
12, 2002.
(4) “[N]o terrorist state poses a greater or more immediate threat to the security of our people than the
regime of Saddam Hussein and Iraq.” Statement of Former Defense Secretary Donald Rumsfeld to
Congress, September 19, 2002.
(5) “On its present course, the Iraqi regime is a threat of unique urgency. . . . it has developed weapons
of mass death.” Statement of President Bush at White House, October 2, 2002.
(6) “But the President also believes that this problem has to be dealt with, and if the United Nations
won’t deal with it, then the United States, with other likeminded nations, may have to deal with it. We
would prefer not to go that route, but the danger is so great, with respect to Saddam Hussein having
weapons of mass destruction, and perhaps even terrorists getting hold of such weapons, that it is time
for the international community to act, and if it doesn’t act, the President is prepared to act with
likeminded nations.” Statement of Former Secretary of State Colin Powell in interview with Ellen
Ratner of Talk Radio News, October 30, 2002.
(7) “Today the world is also uniting to answer the unique and urgent threat posed by Iraq. A dictator
who has used weapons of mass destruction on his own people must not be allowed to produce or
possess those weapons. We will not permit Saddam Hussein to blackmail and/or terrorize nations which
love freedom.” Speech by President Bush to Prague Atlantic Student Summit, November 20, 2002.
(8) “But the risk of doing nothing, the risk of the security of this country being jeopardized at the
hands of a madman with weapons of mass destruction far exceeds the risk of any action we may be
forced to take.” President Bush Meets with National Economic Council at White House, February 25,
2003.
(B) In furtherance of his fraudulent effort to deceive Congress and the citizens of the United States into
believing that Iraq and Saddam Hussein posed an imminent threat to the United States, the President
allowed and authorized those acting under his direction and control, including Vice President Richard
B. Cheney, former Secretary of Defense Donald Rumsfeld, and Lewis Libby, who reportedly directly to
both the President and the Vice President, among others, to pressure intelligence analysts to tailor their
assessments and to create special units outside of, and unknown to, the intelligence community in order
to secretly obtain unreliable information, to manufacture intelligence, or to reinterpret raw data in ways
that would support the Bush administration’s plan to invade Iraq based on a false claim of urgency
despite the lack of justification for such a preemptive action.
(C) The Senate Select Committee on Intelligence Report on Whether Public Statements Regarding Iraq
By U.S. Government Officials Were Substantiated By Intelligence Information, which was released on
June 5, 2008, concluded that:
(1) “Statements by the President and the Vice President indicating that Saddam Hussein was prepared
to give weapons of mass destruction to terrorist groups for attacks against the United States were
contradicted by available intelligence information.”
Thus the President willfully and falsely misrepresented Iraq as an urgent threat requiring immediate
action thereby subverting the national security interests of the United States by setting the stage for the
loss of more than 4000 United States service members; the injuries to tens of thousands of US soldiers;
the deaths of more than 1,000,000 Iraqi citizens since the United States invasion; the loss of
approximately $527 billion in war costs which has increased our Federal debt and the ultimate costs of
the war between three trillion and five trillion dollars; the loss of military readiness within the United
States Armed Services due to overextension, the lack of training and lack of equipment; the loss of
United States credibility in world affairs; and the decades of likely blowback created by the invasion of
Iraq.
In all of these actions and decisions, President George W. Bush has acted in a manner contrary to his
trust as President and Commander in Chief, and subversive of constitutional government, to the
prejudice of the cause of law and justice and to the manifest injury of the people of the United States.
Wherefore, President George W. Bush, by such conduct, is guilty of an impeachable offense warranting
removal from office.

ILLEGALLY MISSPENDING FUNDS TO SECRETLY BEGIN A WAR OF AGGRESSION
In his conduct while President of the United States, George W. Bush, in violation of his constitutional
oath to faithfully execute the office of President of the United States and, to the best of his ability,
preserve, protect, and defend the Constitution of the United States, and in violation of his constitutional
duty under Article II, Section 3 of the Constitution “to take care that the laws be faithfully executed”,
has both personally and acting through his agents and subordinates, together with the Vice President,
illegally misspent funds to begin a war in secret prior to any Congressional authorization.
The president used over $2 billion in the summer of 2002 to prepare for the invasion of Iraq. First
reported in Bob Woodward’s book, Plan of Attack, and later confirmed by the Congressional Research
Service, Bush took money appropriated by Congress for Afghanistan and other programs and—with no
Congressional notification — used it to build airfields in Qatar and to make other preparations for the
invasion of Iraq. This constituted a violation of Article I, Section 9 of the U.S. Constitution, as well as a
violation of the War Powers Act of 1973.
In all of these actions and decisions, President George W. Bush has acted in a manner contrary to his
trust as President and Commander in Chief, and subversive of constitutional government, to the
prejudice of the cause of law and justice and to the manifest injury of the people of the United States.
Wherefore, President George W. Bush, by such conduct, is guilty of an impeachable offense warranting
removal from office.

INVADING IRAQ IN VIOLATION OF THE REQUIREMENTS OF HJRes114.
In his conduct while President of the United States, George W. Bush, in violation of his constitutional
oath to faithfully execute the office of President of the United States and, to the best of his ability,
preserve, protect, and defend the Constitution of the United States, and in violation of his constitutional
duty under Article II, Section 3 of the Constitution “to take care that the laws be faithfully executed”,
exceeded his Constitutional authority to wage war by invading Iraq in 2003 without meeting the
requirements of HJRes 114, the “Authorization for Use of Military Force Against Iraq Resolution of
2002″ to wit:
(1) HJRes 114 contains several Whereas clauses consistent with statements being made by the White
House at the time regarding the threat from Iraq as evidenced by the following:
(A) HJRes 114 states “Whereas Iraq both poses a continuing threat to the national security of the
United States and international peace and security in the Persian Gulf region and remains in material
and unacceptable breach of its international obligations by, among other things, continuing to possess
and develop a significant chemical and biological weapons capability, actively seeking a nuclear
weapons capability, and supporting and harboring terrorist organizations;”; and
(B) HJRes 114 states “Whereas members of Al Qaeda, an organization bearing responsibility for
attacks on the United States, its citizens, and interests, including the attacks that occurred on September
11, 2001, are known to be in Iraq;”.
(2) HJRes 114 states that the President must provide a determination, the truthfulness of which is
implied, that military force is necessary in order to use the authorization, as evidenced by the
following:
(A) Section 3 of HJRes 114 states:
“(b) PRESIDENTIAL DETERMINATION.—In connection with the exercise of the authority granted
in subsection (a) to use force the President shall, prior to such exercise or as soon thereafter as may be
feasible, but no later than 48 hours after exercising such authority, make available to the Speaker of the
House of Representatives and the President pro tempore of the Senate his determination that—
(1) reliance by the United States on further diplomatic or other peaceful means alone either (A) will not
adequately protect the national security of the United States against the continuing threat posed by Iraq
or (B) is not likely to lead to enforcement of all relevant United Nations Security Council resolutions
regarding Iraq; and
(2) acting pursuant to this joint resolution is consistent with the United States and other countries
continuing to take the necessary actions against international terrorist and terrorist organizations,
including those nations, organizations, or persons who planned, authorized, committed or aided the
terrorist attacks that occurred on September 11, 2001.”
(3) On March 18, 2003, President George Bush sent a letter to Congress stating that he had made that
determination as evidenced by the following:
(A) March 18th, 2003 Letter to Congress stating:
Consistent with section 3(b) of the Authorization for Use of Military Force Against Iraq Resolution of
2002 (Public Law 107-243), and based on information available to me, including that in the enclosed
document, I determine that:
(1) reliance by the United States on further diplomatic and other peaceful means alone will neither (A)
adequately protect the national security of the United States against the continuing threat posed by Iraq
nor (B) likely lead to enforcement of all relevant United Nations Security Council resolutions regarding
Iraq; and
(2) acting pursuant to the Constitution and Public Law 107-243 is consistent with the United States and
other countries continuing to take the necessary actions against international terrorists and terrorist
organizations, including those nations, organizations, or persons who planned, authorized, committed,
or aided the terrorist attacks that occurred on September 11, 2001.
(4) President George Bush knew that these statements were false as evidenced by:
(A) Information provided with Article I, II, III, IV and V.
(B) A statement by President George Bush in an interview with Tony Blair on January 31st 2003: [WH]
Reporter: “One question for you both. Do you believe that there is a link between Saddam Hussein, a
direct link, and the men who attacked on September the 11th?”
President Bush: “I can’t make that claim”
(C) An article on February 19th by Terrorism expert Rohan Gunaratna states “I could find no evidence
of links between Iraq and Al Qaeda. The documentation and interviews indicated that Al Qaeda
regarded Saddam, a secular leader, as an infidel.” [InternationalHeraldTribune]
(D) According to a February 2nd, 2003 article in the New York Times: [NYT]
At the Federal Bureau of Investigation, some investigators said they were baffled by the Bush
administration’s insistence on a solid link between Iraq and Osama bin Laden’s network. “We’ve been
looking at this hard for more than a year and you know what, we just don’t think it’s there,” a
government official said.
(5) Section 3C of HJRes 114 states that “Nothing in this joint resolution supersedes any requirement of
the War Powers Resolution.”
(6) The War Powers Resolution Section 9(d)(1) states:
(d) Nothing in this joint resolution–
(1) is intended to alter the constitutional authority of the Congress or of the President, or the provision
of existing treaties; or
(7) The United Nations Charter was an existing treaty and, as shown in Article VIII, the invasion of
Iraq violated that treaty
(8) President George Bush knowingly failed to meet the requirements of HJRes 114 and violated the
requirement of the War Powers Resolution and, thereby, invaded Iraq without the authority of
Congress.
In all of these actions and decisions, President George W. Bush has acted in a manner contrary to his
trust as President and Commander in Chief, and subversive of constitutional government, to the
prejudice of the cause of law and justice and to the manifest injury of the people of the United States.
Wherefore, President George W. Bush, by such conduct, is guilty of an impeachable offense warranting
removal from office.

INVADING IRAQ ABSENT A DECLARATION OF WAR
In his conduct while President of the United States, George W. Bush, in violation of his constitutional
oath to faithfully execute the office of President of the United States and, to the best of his ability,
preserve, protect, and defend the Constitution of the United States, and in violation of his constitutional
duty under Article II, Section 3 of the Constitution “to take care that the laws be faithfully executed”,
has launched a war against Iraq absent any congressional declaration of war or equivalent action.
Article I, Section 8, Clause 11 (the War Powers Clause) makes clear that the United States Congress
holds the exclusive power to decide whether or not to send the nation into war. “The Congress,” the
War Powers Clause states, “shall have power…To declare war…”
The October 2002 congressional resolution on Iraq did not constitute a declaration of war or equivalent
action. The resolution stated: “The President is authorized to use the Armed Forces of the United
States as he deems necessary and appropriate in order to 1) defend the national security of the United
States against the continuing threat posed by Iraq; and 2) enforce all relevant United Nations Security
Council resolutions regarding Iraq.” The resolution unlawfully sought to delegate to the President the
decision of whether or not to initiate a war against Iraq, based on whether he deemed it “necessary and
appropriate.” The Constitution does not allow Congress to delegate this exclusive power to the
President, nor does it allow the President to seize this power.
In March 2003, the President launched a war against Iraq without any constitutional authority.
In all of these actions and decisions, President George W. Bush has acted in a manner contrary to his
trust as President and Commander in Chief, and subversive of constitutional government, to the
prejudice of the cause of law and justice and to the manifest injury of the people of the United States.
Wherefore, President George W. Bush, by such conduct, is guilty of an impeachable offense warranting
removal from office.