This letter from Goldsmith to Muller addresses the use of interrogation techniques on a certain high-value detainee and is a follow-up to 2 previous memos approving 33 techniques (an OLC memo approved 9 and a memo from Secretary Rumsfeld approved 24). This letter emphasized that approval is conditioned on adherance to the safeguards and limitations set forth in the memos and in the Army Field Manual. [OLC Vaughn Index #48]