(A CIA affidavit states that this was a 1-page memo dated Aug. 4, 2004 from CIA to OLC and that it contained "communications from the CIA to OLC on a matter in which the CIA requested legal advice from OLC.")  The document itself shows that the CIA relied on the Justice Department's conclusion that certain interrogation techniques, "including the waterboard," did not violate the torture statute.  The document also indicates that, after the Supreme Court decided Rasul v. Bush in June 2004, the CIA was concerned about the possibility that its actions would ultimately be subject to judicial review.  [Oridinally identified in the ACLU's litigaiton as OLC 70]