From Holden:

I hope everyone has their Fitzmas stockings hung with great care, as Jason Leopold updates us on the latest in the Plame case.

…Fitzgerald is said to believe that there is a possibility Rove either hid or destroyed evidence related to his role in the leak, lawyers close to the case said.

[snip]

According to those familiar with the case, in February 2004, Fitzgerald had already obtained the cooperation of a key witness, former Deputy National Security Adviser for Vice President Dick Cheney, John Hannah. Hannah agreed to cooperate with Fitzgerald when the special prosecutor uncovered evidence tying Hannah to the leak and threatened to indict him, the sources said.

Hannah gave Fitzgerald the names of some White House officials who knew about Plame Wilson and disseminated her CIA status to reporters and other White House officials, the laywers said. One of the officials Hannah appears to have implicated was Rove, they added.

[snip]

The Chicago prosecutor briefed the second grand jury investigating the outing last week for more than three hours. During that time, he brought them up to speed on the latest developments involving Rove and at least one other White House official, the sources said. The attorneys refused to identify the second person.

[snip]

Rove’s alleged failure to disclose his conversations with Cooper and Novak and the fact that he didn’t turn over the Hadley email on two separate occasions is the reason he’s been in Fitzgerald’s crosshairs and may end up being indicted, people close to the investigation said.

It’s also the reason Fitzgerald had grown suspicious at the time that Rove may have hid or destroyed evidence related to his role in the leak, they said, adding that Fitzgerald may have already been aware of the existence of the email, perhaps even obtaining a copy from a witness or another White House official, and waited to see if Rove would cite it or his conversations with Cooper in his grand jury testimony.