Daphne Eviatar writes:
The Washington Independent » Memos Suggest Legal Cherry-Picking in Justifying Torture: The Office of Legal Counsel is where John Yoo and Jay Bybee, beginning in 2002, wrote a series of what came to be called the “torture memos,” defining torture so narrowly and the law so permissively that near-drowning, prolonged sleep deprivation, stress positions and many more “enhanced interrogation techniques” were deemed legal...
Come on, Daphne! The passive voice is to be avoided!
Do note write: "what came to be called the 'torture memos'..."
Write instead: "what Berkeley Law School Dean Chris Edley and many others call the 'torture memos'..."