clemency matters submitted to the convening authority that the defense counsel claim to have believed the pretrial agreement they'd worked out for their client could fall apart if they challenged Dr. Michael Welner during cross-examination in sentencing. You can review in-depth coverage of Welner's testimony here. Let's just say Welner's conclusions and areas of purported expertise were expansive.
UPDATE: Here are additional descriptions of the contents of the clemency matters, including a report that Administration officials don't want Welner to testify in future commission hearings. I found a couple of excerpts from Michelle Shephard (Toronto Star reporter) amusing:
Army Col. Patrick Parrish, the judge presiding over Khadr’s case, allegedly quipped to the defence that “Dr. Welner would have been as likely to be accurate if he used a Ouija board,” according to the motion.
In an emailed response to the Star Monday, Welner characterized the defence document as “slimy and pathetic.”