UH OH: Did James Comey’s Document Leaks Violate The FBI Employment Agreement? “By his own account, it seems that Comey may not have followed the agency’s employee agreement, which places numerous restrictions on the use of information or documents acquired during an individual’s employment by the FBI. Paragraphs 2, 3, and 4 of the FBI employment agreement appear to cover Comey’s distribution of content he says he created on government property in his capacity as a government official. . . . o if Comey followed protocol and surrendered all government property, including the memos he produced in his capacity as an FBI employee, it would have been impossible for him to provide the memos to his friend. The fact that he was able to provide hard copies of the memos to both his friend and special counsel Robert Mueller suggests that Comey did not surrender them to authorities as required by the FBI employment agreement.”