Memorandum

From: Karl Rove
Subj: Justice "Cypher"
To: President Bush

When Justice O'Connor retires,
Who'll replace her? Why, Harriet Miers!
What's there to assail
With no paper trail
Of tenets to which she aspires?

Rove played an active role in selection of Miers
By Joseph Curl, The Washington Times, 10/6/05