MEMORANDUM OPINION
JOHN D. BATES, District Judge.
The Project on Government Oversight ("POGO") is a self-described "independent nonprofit that investigates and exposes corruption and other misconduct in order to achieve a more accountable federal government." See POGO — About Us, http:// www.pogo.org/p/x/aboutus.html. On November 2, 1998, POGO paid Robert Berman, a senior economist at the Department of the Interior ("DOI"), a sum of...
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