FWIW, I don't know that the memo was the only doc Berger may have stolen. I'm just as concerned about what he may have put back. In any case, whatever the Archives have on the subject of the Toon admin and terror is now worthless as far as I'm concerned.
I believe Berger stole on three occasions. It could have been to take something out. Have it "signed and/or altered" by someone and put back or replaced. This was shortly after Rathergate. Forgery was not an option.