In new court filings, special counsel Patrick Fitzgerald has finally resolved one of the most disputed issues at the core of the long-running CIA leak controversy: Valerie Plame Wilson, he asserts, was a “covert” CIA officer who repeatedly traveled overseas using a “cover identity” in order to disguise her relationship with the agency.

Fitzgerald cites Wilson’s covert status as part of his argument—advanced in two strongly worded memos filed in recent days—that I. Lewis (Scooter) Libby, Vice President Dick Cheney’s former chief of staff, should be sentenced to up to three years in prison.