Bybee memo, a document that provided the legal framework by which previous interpretations of the Geneva Convention and the United Nations Convention Against Torture were modified to expand Presidential authority to enable so-called "enhanced interrogation techniques". The memo was produced in response to a specific CIA request for clarification of the standards of interrogation under U.S. law, in the specific case of Abu Zabaydah, a man believed at the time to be a high-level al-Qaeda leader. In response, the Justice Department issued a classified August 1, 2002, memo to the CIA from Jay Bybee, the Assistant Attorney General for the Office of Legal Counsel, and an August 1, 2002, legal opinion to Gonzales from Jay Bybee defining torture as an act specifically intended to inflict severe physical or mental pain or suffering. Journalists including Jane Mayer, Joby Warrick and Peter Finn, and Alex Koppelman have reported the CIA was already using these harsh tactics before the memo authorizing their use was written, and that it was used to provide after-the-fact legal support for harsh interrogation techniques. A Department of Justice 2009 report regarding prisoner abuses reportedly stated the memos were prepared one month after Abu Zubaydah had already been subjected to the specific techniques authorized in the August 1, 2002, memo. John Kiriakou stated in July 2009 that Abu Zubaydah was waterboarded in the early summer of 2002, months before the August 1, 2002, memo was written. The memo described ten techniques that the interrogators wanted to use: "(1) attention grasp, (2) walling, (3) facial hold, (4) facial slap (insult slap), (5) cramped confinement, (6) wall standing, (7) stress positions, (8) sleep deprivation, (9) insects placed in a confinement box, and (10) the waterboard." Many of the techniques were, until then, generally considered illegal. Many other techniques developed by the CIA were held to constitute inhumane and degrading treatment and torture under the United Nations Convention against Torture and Article 3 of the European Convention on Human Rights. As reported later, many of these interrogation techniques were previously considered illegal under U.S. and international law and treaties at the time of Abu Zubaydah's capture. For instance, the United States had prosecuted Japanese military officials after World War II and American soldiers after the Vietnam War for waterboarding. Since 1930, the United States had defined sleep deprivation as an illegal form of torture. Many other techniques developed by the CIA constitute