The gist of it is Karl Rove may be in legal trouble for further disseminating the Valarie Plame story after Robert Novak had published his story outing her.

The memo argues that by repeating the leak to political consultants and journalists Mr. Rove was committing a crime separate from the original leak.

Mr. Rove made clear to the F.B.I. that he had only spread the story after Novak’s column went to print.

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