Partner, Arnold & Porter LLP
John Bellinger heads the firm's Global Law and Public Policy practice. He joined the firm in 2009, after holding several senior Presidential appointments in the US government, including as the Senate-confirmed Legal Adviser to the Department of State and Senior Associate Counsel to the President and Legal Adviser to the National Security Council (NSC) at the White House in the George W. Bush Administration.
Mr. Bellinger represents individuals, corporations, and sovereign governments in litigation in US courts and before international institutions. He has extensive experience in US foreign relations litigation involving the Alien Tort Statute, the Foreign Sovereign Immunities Act, the Anti-Terrorism Act, and the diplomatic and official immunities of foreign governments and government officials. He advises clients on other public international law matters, including treaties and international agreements as well as international humanitarian law and human rights law. He also counsels US and foreign clients on national security legal and policy issues, including US and multilateral financial sanctions and asset controls, the extraterritorial application of US criminal and civil laws, and transactions reviewed by the Committee on Foreign Investment in the United States (CFIUS).
Chambers Global ranks Mr. Bellinger among the best international lawyers in the world, reporting that he has "second-to-none experience in public international law, international litigation and foreign sovereign immunity" and that his "experience at the highest levels of the Executive branch...gives him a distinct and important vantage point on legal issues." Chambers adds: "For any cross border work he's just extraordinary, he knows the area inside-out."
Mr. Bellinger was the State Department Legal Adviser–the most senior international lawyer in the US Government–from 2005 to 2009, serving under Secretary of State Condoleezza Rice. He directed more than 170 lawyers on domestic and international law matters affecting US foreign relations. Before joining the State Department, Mr. Bellinger managed Secretary Rice's Senate confirmation process and co-directed her State Department transition team. In 2009, Mr. Bellinger received the Secretary of State's Distinguished Service Award.
Mr. Bellinger has argued cases before the International Court of Justice (Mexico v. United States–(Medellin)) and the Iran-United States Claims Tribunal in The Hague. He has appeared on numerous briefs in US federal courts, including the Supreme Court, in litigation involving international law issues.
As Legal Adviser to the NSC from 2001 to 2005, Mr. Bellinger advised President Bush, Cabinet officials, National Security Advisor Rice, and NSC staff on a wide range of national security and international law issues, including counterterrorism issues after the 9-11 attacks. He was one of the principal drafters of the legislation that created the Director of National Intelligence.
Prior to his service in the Bush Administration, Mr. Bellinger served as Counsel for National Security Matters in the Criminal Division at the US Department of Justice (1997-2001); Of Counsel to the Senate Select Committee on Intelligence (1996); General Counsel of the Commission on the Roles and Capabilities of the US Intelligence Community (1995-1996); and Special Assistant to Director of Central Intelligence William Webster (1988-1991). Mr. Bellinger is an Adjunct Senior Fellow in International and National Security Law at the Council on Foreign Relations. He has testified before Congress on numerous occasions, is quoted regularly in the media on international and national security law matters, and has lectured at numerous US and foreign universities and law schools. He is the author of many law review articles and op-eds on international law, including op-eds in The Washington Post, The New York Times, and The Wall Street Journal. Mr. Bellinger is a senior contributor to the Lawfare blog.
Mr. Bellinger is a member of the Secretary of State's Advisory Committee on International Law. He served from 2005-2019 as one of four US Members of the Permanent Court of Arbitration in The Hague and a member of the US "National Group", which nominates judges to the International Court of Justice. He is also a member of the Council on Foreign Relations and the American Society of International Law. He is a member of the Council of the American Law Institute; the boards of directors of the American Ditchley Foundation, the Salzburg Global Seminar, and the Stimson Center; and the advisory committee of Foreign Affairs magazine.
Mr. Bellinger is a graduate of Princeton University's Woodrow Wilson School of Public and International Affairs, and he holds an MA in Foreign Affairs from the University of Virginia and a JD from Harvard Law School, where he was an editor of the Harvard International Law Journal.
Deputy Secretary of Transportation, US Department of Transportation
Steven G. Bradbury was sworn in as the Deputy Secretary of Transportation on March 13, 2025, following his confirmation by the U.S. Senate on March 11, 2025. In this role, he oversees the Department’s operating administrations and spearheads initiatives to ensure a safe, efficient, and modern transportation system that strengthens economic productivity and global competitiveness. Deputy Secretary Bradbury also assists Secretary Duffy in managing the Department’s activities, including its workforce of over 58,000 employees and an annual budget exceeding $109 billion.
Bradbury previously served as the 23rd General Counsel of the Department of Transportation from 2017 to 2021, as the Acting Deputy Secretary from 2019, and as Acting Secretary of Transportation in 2021. As General Counsel, he was the chief legal officer, advising on all legal matters and ensuring the integrity and compliance of the Department’s policies and programs.
Before rejoining DOT, Bradbury was a Distinguished Fellow at The Heritage Foundation from December 2022 to March 2025. He has extensive experience in the public and private sector, having served as Principal Deputy and Acting Assistant Attorney General at the U.S. Department of Justice and as a partner at Kirkland & Ellis LLP and Dechert LLP. Earlier in his career, he clerked for Justice Clarence Thomas and Judge James L. Buckley.
Bradbury holds a J.D., magna cum laude, from the University of Michigan Law School and a B.A. in English from Stanford University.
Executive Vice President of Global Governance, Chief Legal Officer and Corporate Secretary, Walmart Inc.
Rachel Brand is Walmart’s executive vice president of global governance, chief legal officer, and corporate secretary. She oversees the company’s global legal, compliance, ethics, corporate governance, digital citizenship, aviation, investigative, and corporate security functions, including Walmart’s Emergency Operations Center.
Immediately before joining Walmart, Rachel served as the United States Associate Attorney General and holds the distinction of being the first woman to serve in this role. She had previously served in the U.S. Department of Justice as the Assistant Attorney General for the Office of Legal Policy during President George W. Bush’s administration. Her other government service includes an appointment by President Obama to serve as a Member of the U.S. Privacy and Civil Liberties Oversight Board, service as an Associate Counsel to the President at the White House, and judicial clerkships with Justice Charles Fried of the Supreme Judicial Court of Massachusetts and Justice Anthony Kennedy at the Supreme Court of the United States. In the private sector, Rachel was a lawyer in private practice at two law firms in Washington, D.C. and served as the Vice President and Chief Counsel for Regulatory Litigation at the U.S. Chamber of Commerce Litigation Center.
Rachel serves on the board of directors for the Walmart Foundation and is the executive sponsor for Walmart’s Tribal Voices Associate Resource Group. Outside of Walmart, she serves on the board of directors for the International Justice Mission and is a member of The American Law Institute.
Rachel earned her Bachelor of Arts degree from the University of Minnesota-Morris and her J.D. from Harvard Law School.
Presiding Justice, Supreme Court of Georgia
Justice Sarah Hawkins Warren was appointed to the Supreme Court of Georgia by Governor Nathan Deal and was sworn in on September 17, 2018. She previously served as Solicitor General for the State of Georgia under Attorney General Chris Carr.
Justice Warren earned a B.A. in Public Policy and Spanish, magna cum laude, from Duke University. After graduation, Justice Warren served as Deputy Press Secretary for the White House Office of Management and Budget.
Justice Warren received her J.D., magna cum laude, from Duke University School of Law, where she served as Editor in Chief of Law and Contemporary Problems and on the Executive Committee of the Federalist Society.
Following her graduation from law school, Justice Warren served as a law clerk to then-Chief Judge J.L. Edmondson of the United States Court of Appeals for the Eleventh Circuit and to the Honorable Richard J. Leon of the United States District Court for the District of Columbia. She also practiced as a litigation partner at Kirkland & Ellis LLP in Washington, D.C., where she represented clients before state and federal courts and was outside counsel to Georgia in Florida v. Georgia, No. 142 Original (United States Supreme Court).
In 2015, Justice Warren and her family returned home to Georgia, where she began service in the Office of Attorney General Sam Olens as Deputy Solicitor General and Special Counsel for Water Litigation. In January 2017, she was appointed Solicitor General by Attorney General Chris Carr, and in that role served as the chief appellate lawyer for the State of Georgia and the primary constitutional law advisor to the Attorney General. As Solicitor General, Justice Warren represented Georgia in multi-state litigation and in appeals before state and federal courts, including in an argument before the United States Supreme Court.
Justice Warren currently serves on the Duke Law School Board of Visitors, the Berry College Board of Trustees, and the Advisory Board for the Atlanta Lawyers Chapter of the Federalist Society. She lives in Atlanta with her husband, Blaise, and their three children.
Deputy Secretary of Transportation, US Department of Transportation
Steven G. Bradbury was sworn in as the Deputy Secretary of Transportation on March 13, 2025, following his confirmation by the U.S. Senate on March 11, 2025. In this role, he oversees the Department’s operating administrations and spearheads initiatives to ensure a safe, efficient, and modern transportation system that strengthens economic productivity and global competitiveness. Deputy Secretary Bradbury also assists Secretary Duffy in managing the Department’s activities, including its workforce of over 58,000 employees and an annual budget exceeding $109 billion.
Bradbury previously served as the 23rd General Counsel of the Department of Transportation from 2017 to 2021, as the Acting Deputy Secretary from 2019, and as Acting Secretary of Transportation in 2021. As General Counsel, he was the chief legal officer, advising on all legal matters and ensuring the integrity and compliance of the Department’s policies and programs.
Before rejoining DOT, Bradbury was a Distinguished Fellow at The Heritage Foundation from December 2022 to March 2025. He has extensive experience in the public and private sector, having served as Principal Deputy and Acting Assistant Attorney General at the U.S. Department of Justice and as a partner at Kirkland & Ellis LLP and Dechert LLP. Earlier in his career, he clerked for Justice Clarence Thomas and Judge James L. Buckley.
Bradbury holds a J.D., magna cum laude, from the University of Michigan Law School and a B.A. in English from Stanford University.
Partner, Baker Hostetler LLP
David Rivkin is a member of the firm's litigation, international and environmental teams and is co-leader of the firm's national appellate practice. He has extensive experience in constitutional, administrative and international law litigation and has been involved in numerous high-profile cases. With his prior experience in the government sector, David draws on a wealth of knowledge when providing compliance advice to companies and handling enforcement proceedings before government agencies on issues arising out of multilateral and unilateral sanctions, the Foreign Corrupt Practices Act (FCPA), anti-boycott issues, bankruptcy and financial fraud matters, and environmental and energy issues.
David has developed and implemented legislative, regulatory and litigation initiatives for two presidential administrations. Over the years, he has published hundreds of articles, op-eds, book reviews and book chapters on a variety of international, legal, constitutional, defense, arms control, foreign policy, environmental and energy issues for various newspapers and magazines, including The Wall Street Journal, The Washington Post, The New York Times, USA Today and The Los Angeles Times, and has been a frequent commentator and guest on TV and radio shows including ABC, CBS, NBC, CNN, Fox News, NPR and PBS.
Professor of Constitutional Law, Pepperdine University School of Law
One of America's best known scholars and popular commentators on the law, Professor Douglas W. Kmiec holds the endowed chair in constitutional law at Pepperdine Law School. He came to this position after serving several years as dean and St. Thomas More Professor of Law at The Catholic University of America in Washington, D.C., and for nearly two decades, on the law faculty at the University of Notre Dame. As dean at Catholic University, Professor Kmiec did what many said would be impossible; he greatly increased academic quality and student selectivity at the same time he deepened the school's religious commitment. During his tenure, the law school moved into the upper tier of the U.S. News ranking from tier three. At Notre Dame, he was director of Notre Dame's Center on Law & Government, and the founder of its Journal of Law, Ethics & Public Policy. Beyond the university setting, Kmiec served Presidents Ronald Reagan and George Bush during 1985-89 as constitutional legal counsel (Assistant Attorney General, Office of Legal Counsel, U.S. Department of Justice).
A wide-ranging writer and engaging speaker, Professor Kmiec writes a syndicated column for the Catholic News Service, and for several years wrote a regular column in the Chicago Tribune. He is also a frequent contributor to the pages of the Los Angeles Times, Wall Street Journal, and other periodicals. He is the co-author (with legal historian Stephen Presser of Northwestern) of three books on the Constitution -- The American Constitutional Order; Individual Rights and the American Constitution and The History, Structure and Philosophy of the American Constitution. Another recent book, Cease-Fire on the Family (Crisis Books/Notre Dame) attracted scholarly and popular acclaim for proposing realistic ways for families to "end the culture war" by renewing personal virtue and civic responsibility within itself. He has also written The Attorney General's Lawyer (Praeger 1992), and several respected legal treatises.
Professor Kmiec's scholarly research spans legal and non-legal subjects, from the Constitution and the federal system, to land use and the organization of America society. He is a frequent guest on national news programs, such as Nightline, the Newshour, and NPR's Talk of the Nation, analyzing constitutional questions.
A White House Fellow (1982-83), Professor Kmiec is one of a few individuals who has received the Distinguished Service Award from two cabinet departments —the Department of Justice in 1987 and Housing and Urban Development in 1983. In 1988, he was awarded the Edmund J. Randolph Award by the attorney general. He has lectured on the U.S. Constitution in Asia as a Fulbright Distinguished Scholar.
An honors graduate of Northwestern, Professor Kmiec received his law degree from the University of Southern California, where he served on the Law Review and received the Legion Lex Commencement Prize for Legal Writing. He is a member of the bar of the U.S. Supreme Court and the state bars of Illinois and California.
B.A., with honors, Northwestern University, 1973
J.D., University of Southern California, 1976
Attorney, DePalma Law Firm, LLC
Bart DePalma practices trial law in Woodland Park, CO, located in a mountain valley at the foot of Pikes Peak, focusing on criminal defense and business law.
Prior to practicing law, Mr. DePalma served as an Army infantry officer during the Persian Gulf War and an intelligence officer in Germany.
In his spare time, Mr. DePalma authors the blog Citizen Pamphleteer, discussing politics, law, economics and military matters.
B.A., Florida Atlantic University; J.D., Florida State University
Distinguished Visiting Professor, Hofstra Law School
Scott Horton is a Distinguished Visiting Professor at Hofstra Law School and an adjunct professor at Columbia Law School. He teaches international commercial law and the law of armed conflict. He is also a contributing editor at Harper's Magazine and writes on law and legal policy issues for several other publications. A life-long human rights advocate, Scott served as counsel to Andrei Sakharov and Elena Bonner, among other activists in the former Soviet Union. He is a co-founder of the American University in Central Asia, where he currently serves as a trustee, and has been involved in some of the most significant foreign investment projects in the Central Eurasian region. Scott recently led a number of studies of issues associated with the conduct of the war on terror, including major studies of the introduction of highly coercive interrogation techniques and the program of extraordinary renditions for the New York City Bar Association, where he has chaired several committees, including, most recently, the Committee on International Law. He is also an associate of the Harriman Institute at Columbia University, a member of the board of the National Institute of Military Justice, Center on Law and Security of NYU Law School, the EurasiaGroup and the American Branch of the International Law Association and a member of the Council on Foreign Relations. He co-authored a recent study on legal accountability for private military contractors, Private Security Contractors at War. He appeared as a congressional witness five times in the last two years, offering testimony on issues under the law of armed conflict, military contractor liability and the extraordinary renditions program.
University Professor, Georgetown University Law Center
David Luban is University Professor of Law and Philosophy at Georgetown University. He holds a Ph.D. in philosophy from Yale University. Luban's books include Lawyers and Justice: An Ethical Study (Princeton University Press, 1988), Legal Modernism (University of Michigan Press, 1994), and Legal Ethics and Human Dignity (Cambridge University Press, 2007), as well as textbooks and anthologies on legal ethics. His books have been translated into Chinese and Japanese.
Luban has been a Guggenheim Fellow and a Fellow of the Woodrow Wilson Center, and has won the Keck Award and Levy Award for distinguished scholarship. He has published more than 150 articles on topics in international criminal law, moral and political philosophy, professional ethics, criminal law theory, just war theory, and-most recently-issues surrounding the War on Terror, particularly torture and the mistreatment of detainees.
Luban joined the Georgetown faculty from the University of Maryland, and has been a visiting professor of law at the Harvard, Stanford, and Yale Law Schools, and a visiting professor of philosophy at Dartmouth College and the University of Melbourne. His articles on the torture issue include "Liberalism, Torture, and the Ticking Bomb," 91 Va. L. Rev. 1425 (2005), "Torture and the Professions," 26 Criminal J. Ethics no. 2 (2007), "The Torture Lawyers of Washington," in Legal Ethics and Human Dignity, and "Unthinking the Ticking Bomb," forthcoming in Global Basic Rights (Beitz & Goodin eds., Oxford University Press).
Senior Fellow, National Review
Bestselling author Andrew C. McCarthy is a contributing editor at National Review, a senior fellow at National Review Institute, and a Fox News contributor. He is a former Chief Assistant United States Attorney in the Southern District of New York and led the terrorism prosecution against the “Blind Sheikh” (Omar Abdel Rahman) and eleven other jihadists for conducting a war of urban terrorism against the United States that included the 1993 World Trade Center bombing and a plot to bomb New York City landmarks. During is 20-year career as a prosecutor, he received numerous honors, including the Justice Department’s highest awards. Andy speaks and writes widely on law and national security, radical Islam, politics, and culture. He has testified before Congress as an expert on issues of constitutional law, counterterrorism, and law-enforcement. He is a columnist for The Hill, and his essays and book reviews appear frequently at The New Criterion. His most recent New York Times bestselling book is Ball of Collusion (Encounter Books, 2019), about the Russiagate controversy (an updated version was published in 2020). His other books include Willful Blindness (2008), The Grand Jihad (2010), Spring Fever: The Illusion of Islamic Democracy (2012), and Faithless Execution (2014). He has also written several pamphlets in the Broadside series published by Encounter Books, most recently Islam and Free Speech (2015).
Partner, Baker & Hostetler LLP
Lee A. Casey focuses on federal environmental, constitutional and international law and Alien Tort Statute issues. He also advises clients on compliance issues under the Foreign Corrupt Practices Act (FCPA), U.S. trade sanctions regimes, and federal ethics requirements. Mr. Casey’s practice includes federal, district and appellate court litigation, as well as matters before federal agencies. Prior to joining BakerHostetler, Mr. Casey was an associate with Hunton & Williams, practicing in international, environmental and constitutional law. From 2004 through 2007 he served as an member of the United Nations Subcommission on the Promotion and Protection of Human Rights.
From 1986 to 1993, Mr. Casey served in various capacities in the federal government, including the Office of Legal Policy (1986-90) and the Office of Legal Counsel (1992-93) at the U.S. Department of Justice and served as Deputy Associate General Counsel at the U.S. Department of Energy (1990-92). The Office of Legal Counsel is responsible for advising the Attorney General and the White House on issues of constitutional law and statutory interpretation. The Office of Legal Policy served as a strategic “think tank” for the Reagan Justice Department and was responsible for reviewing candidates for appointments to the federal bench.
Before joining the government in 1986, Mr. Casey was an associate in the Los Angeles firm of Mitchell, Silberberg & Knupp, practicing in the litigation section, with an emphasis on copyright, contract and First Amendment issues. From 1984 to 1985, Mr. Casey served as Law Clerk to the Honorable Alex Kozinski, then Chief Judge of the United States Claims Court. From 1982 to 1984, he practiced at the Detroit firm of Dykema Gossett, focusing on corporate, securities, commercial and intellectual property litigation, and from 1990 through 1994, he served as an Adjunct Professor of Law at George Mason University School of Law in Arlington, Virginia.
Among the chapters, articles and papers that Mr. Casey has authored or co-authored are: “International Law and the Nation-State at the U.N.,” Reclaiming the Language of Freedom at the United Nations: A Guide for U.S. Policymakers, The Heritage Foundation (2006) (with David B. Rivkin, Jr.); “The Dangerous Myth of Universal Jurisdiction,” A Country I Do Not Recognize (ed. Robert H. Bork) (2005) (with David B. Rivkin, Jr.); “Leashing the Dogs of War,” The National Interest (Fall 2003) (with David B. Rivkin, Jr.); “The Limits of Legitimacy: The Rome Statute’s Unlawful Application to Non-State Parties,” 44 Va.J.Int’l L. 63 (Fall 2003) (with David B. Rivkin, Jr.); “Devil’s Advocates: The Danger of Judging Lawyers By Their Clients,” Policy Review (Feb. and Mar. 2002) (with David B. Rivkin, Jr.); “The Case Against the International Criminal Court,” 25 Fordham Int’l L.J. 840 (2002); “Europe in the Balance: The Alarmingly Undemocratic Drift of the European Union,” Policy Review (June and July 2001) (with David B. Rivkin Jr.); “Against an International Criminal Court,” Commentary, May 1998 (with David B. Rivkin, Jr.); “Federalism (Cont’d.),” Commentary, December 1996 (with David B. Rivkin, Jr.); “Presidents and War Powers: Another View,” Common Sense, Winter 1996 (with David B. Rivkin, Jr.); “How Binding Are Contracts?” The American Enterprise, Nov./Dec. 1993 (with David B. Rivkin, Jr.); and “Pirate Constitutionalism: An Essay in Self-Government,” 8 J. of L. & Politics 477 (1992).
Mr. Casey is a member of the California, Michigan and District of Columbia Bar Associations.
Agnes Williams Sesquicentennial Professor of Federal Courts, Georgetown Law
Stephen I. Vladeck is a professor of law at the Georgetown University Law Center, and is a nationally recognized expert on the federal courts; the Supreme Court; national security law; and military justice.
Vladeck is author of the New York Times bestselling book, “The Shadow Docket: How the Supreme Court Uses Stealth Rulings to Amass Power and Undermine the Republic,” which won the 2023 Writers’ League of Texas Book Award for Non-Fiction and was a finalist for the 2024 ABA Silver Gavel Award for Media and the Arts. Vladeck is also a highly regarded appellate advocate, having argued three cases before the U.S. Supreme Court and over a dozen before various lower federal civilian and military courts. He has received numerous awards for his influential and widely cited legal scholarship, his prolific popular writing, his teaching, and his service to the legal profession—including the 2024 University of Texas President’s Research Impact Award and his selection by the Order of the Coif to serve as its Distinguished Visiting Professor for 2025.
Vladeck is CNN’s Supreme Court analyst and editor and author of “One First,” a popular weekly newsletter about the Supreme Court. Together with Bobby Chesney, Vladeck co-hosts the popular and award-winning “National Security Law Podcast.” He is also a co-author of Aspen Publishers’ leading national security law and counterterrorism law casebooks. And he is a member of the Board of Trustees of EarthJustice—the nation’s premier nonprofit public interest environmental law organization.
Vladeck graduated from Yale Law School in 2004—where he was executive editor of the Yale Law Journal and won the Harlan Fiske Stone Prize for outstanding moot court oralist and shared the Potter Stewart Prize for best moot court team performance. After law school, he clerked for the Honorable Marsha S. Berzon on the U.S. Court of Appeals for the Ninth Circuit and the Honorable Rosemary Barkett on the U.S. Court of Appeals for the Eleventh Circuit. He earned a B.A. summa cum laude with Highest Distinction in History and Mathematics from Amherst College in 2001—where he wrote his senior thesis on “Leipzig’s Shadow: The War Crimes Trials of the First World War and Their Implications from Nuremberg to the Present.” A native New Yorker and hopeless Mets fan, Vladeck lives in the District with his wife, Karen (Founder and Managing Partner of Risepoint Search Partners); their daughters, Madeleine and Sydney; and their eleven-year-old pug, Roxanna.
George C. Dix Professor in Constitutional Law, Northwestern University Pritzker School of Law
John O. McGinnis is a graduate of Harvard College and Harvard Law School where he was an editor of the Harvard Law Review. He also has an MA degree from Balliol College, Oxford, in philosophy and theology. Professor McGinnis clerked on the U.S. Court of Appeals for the District of Columbia. From 1987 to 1991, he was deputy assistant attorney general in the Office of Legal Counsel at the Department of Justice. He is the author of Accelerating Democracy: Transforming Government Through Technology (Princeton 2013) and Originalism and the Good Constitution (Harvard 2013) (with M. Rappaport). He is a past winner of the Paul Bator award given by the Federalist Society to an outstanding academic under 40. He has been listed by the United States on the roster of panelists who may be called upon to decide World Trade Organization Disputes.
IS It Legal? Legal Authority for the Campaign Against the Islamic State
DC Young Lawyers Chapter and The Alexander Hamilton Society
Washington, DCAgency v. Agency and Other Problems of Overlapping Jurisdiction
OLC Memos
David B. Rivkin, Douglas W. Kmiec, Bart DePalma, Scott Horton, David Luban, Andrew McCarthy, Lee A. Casey, Stephen I. Vladeck
On April 16, President Obama announced that he was declassifying and releasing to the public...
Office of Legal Counsel Releases Opinions
John O. McGinnis
Brought to you by the International & National Security Law Practice GroupOn March 1, 2009, the Department...