Re filed Documents 1 and 3.  The polygraph charts which Doug taught others to manipulate are a witness to some aspect of the applicant's background and suitability for employment only to the extent that the paradigm which leads to the production of the charts is valid.

The government can't have it both ways--either there is witness tampering (some reason to believe the witness is reliable and credible in the absence of any tampering, i.e., the charts are accurate) or there is no reasonable facsimile of a witness involved and absent a witness--no witness tampering.

Doug's attorney should and presumably will argue this vigorously.

Document 2's request to exclude all who have taken a polygraph exam is way too broad and seeks to establish an unfair burden for the defendant, i.e., that those who will judge him must be ignorant of the process which he taught others to manipulate.