Woodell Statement of Facts

7/24/2019 Woodell Statement of Facts

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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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Case 4:15-mj-00224-RJK Document 8 Filed 10/26/15 Page 1 of 8 PageID# 17


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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.

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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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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

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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


Woodell Statement of Facts

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