This letter from Steven Bradbury to John Rizzo memorializes the advice that Bradbury gave to Rizzo regarding whether the conditions of confinement used by the CIA in its covert overseas facilities are consistent with common Article 3 of the 1949 Geneva Conventions. Bradbury concludes that none of the five conditions of confinement used by the CIA in these facilities, as described by Rizzo, violates common Article 3. This memo was also produced to us on August 24, 2009 in response to our December 2008 FOIA Request.