More Bush-era torture documents could be forthcoming, if the Obama administration delivers on its promise to review more than 200 internal Bush documents, including a top-secret Defense memo outlining torture methods that authorities allegedly misplaced. The documents in question are part of a longstanding ACLU Freedom of Information Act request pertaining to the death, treatment, and rendition of detainees. The Bush administration had originally dismissed the now-scrutinized documents as irrelevant to the ACLU's request, but the Obama administration reversed such a decision. Special Prosecutor John Durham, who was tasked by the Bush administration to investigate the CIA's destruction of interrogation videos, could stand in the way if he claims that releasing the documents interferes with his case.